The URL can be used to link to this page

Home My Public Portal AboutPRR 14-1278I2 78 RECEIVED 08/08/2014 13:10 5613946102 S13V 08108)2014 13:31 Commerce Group TA)095435=7 P.0021005 RECORDS REQUEST (the "Request' Date of Request: 5/8/2014 Requestor's Request ID #: 107 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkao, P.L. REQUESTOR: Commerce Group, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: rccords@commerce- gmup.com Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records pursuant to which Attorney Swestapple railed upon to make the statements at c ma e e n num ere su paregrap g, exc u ng su paragraP , ., 4b., 4e 4d. 4e. 41 4h. 4i. 4k. 41. and 4m. of the Defendant's Merlon For Sanctions A alnst Plointilf, Martin E O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O'[sic) And 1MInam Ring, Esquire, which was filed by Attorney Sweetapple. A copy of subparagraph 4g..ofthe reramnced Mat' tt gd ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA CONSTITUTION. IT IS REQUESTED THAT THIS RECORDS REQUEST HE FULFILLED IN ELECTRONIC FORM. W N01 AVAILABLE IN ELECTRONIC FORM. IT IS REQUESTED THAT THIS RECORDS BAOURST HE FULFILLED QN 11 X 17 PAPER ALL CASE IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Se 'on I1 . 7 4 e 2 ALL ELECTRONIC COPIES ARE REQUESTED TO BE Sr. IVT BYE MAIL DELI D PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requester approve of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requester by the Agency. 1:P/NPRIFRR 0422.13 FORM RECEIVED 08/88/2014 13:10 5613946102 08108/2014 13:31 Commerce Group Filing S 15549445 Eleetrmicelly Fled 07/03/201401:14:36 PM MARTIN E. O'BOYLE, Plaintiff V. TOWN OF GULF STREAM, Defendant. SBV ffA*54351M P.0031005 IN THE CIRCUIT COURT OF THE 15n, JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA0044741O XXMB DIVISION: AO Defendant, Town Of Gulf Stream, moves this Court for the imposition of sanctions against Plaintiff, Martin E. O'Boyle, Counsel of Record, the O'Boyle Law Firm, P.C., Inc., its President, Jonathan O'Boyle, and William Ring, Esquire, for unprofessional, unethical and abusive litigation tactics, and as grounds therefore would show the Court that: 1. On May 30, 2014, Defendant, through its counsel, Sweetapple, Brooker & Varkas, P.L., and Jones, Foster, Johnson & Stubbs, P.A., filed Defendant's Motion to Disqualify the O'Boyle Law Firm, P.C., Inc., or In the Alternative, for an Evidentiary Hearing ( hereinafter the "Motion'j. 2. This Motion has been withdrawn without prejudice as Defendant is seeking other remedies with regard to the matters addressed in the Motion. 3. Significantly, the O'Boyle Law Firm, P.C., Inc., registered as a Florida foreign profit corporation on February 10, 2014, claiming its principal office as 2146 B. Huntingdon Street, Phlladelphlis, Pennsylvania 4. Upon information and belief, at the time of registering the O'Boyle Law Firm, P.C., Inc. (hereinafter the "O'Boyle Law Firm'7, as a Florida foreign profit corporation, the O'Boyle Law Firm LAW OFF=eFSWFFMPXA BKnEKEa & VARKM, P.L. 20 a,8.3'eftwr, BoexRA*mx, Pwwoe33432 -3911 RECEIVED 00/00/2014 13:10 5613946102 SBV 0810812014 13:31 Commerce Group TAXA 7 Martin B. O'Boyle v Town of Oulfsneam CASE NO.5020tdCAflndAUvvvv, •n.�..... -_. appears to have had no real business presence in Philadelphia, Penusylvanl& Although it was registered as a Pennsylvania Corporation on November 14, 2013, it further appears that. IL The O'Boyle Law Firm did not own or lease any commercial space there. b. The O'Boyle Law Finn did not have a business telephone line. c. The O'Boyle Law Firm had no employees and paid no salaries. d. The O'Boyle Law Firm did not pay city, state or federal taxes because it had no employees. C. The O'Boyle Law Finn did not obtain an ocoupadonal license to conduct business in the City of Philadephia. f. The O'Boyle Law Firm's sole principal, officer and director, Jonathan O'Boyle, used his Florida cell Phone number (561- 758 - 1223), as the firm telephone number, g. JOnstban O'Boyle is a tn=ber ofthe Pennsylvania Bar, but not ofthe Florida Bar. h. Jonathan O'Boyle advised the Pennsylvania Bar that he is an out -of -state attorney with an address in Florida. i. Jonathan O'Boyle advised the Pennsylvania Bar that his address is in the Town of Gulf Stream, Florida et 23 N. Hidden Barbour Drive, his parent's home address. j. At the time of the opening of the O'Boyle Law Firm in Florida, Jonathan O'Boyle resided and was domiciled in Florida. k. When the O'Boyle Law Firm opened in Florida, it was operated out of his father, Martin O'Boyle's, office at West Newport Center Drive, Deerfield Beach, Florida It is still operated out of this building, which is owned or controlled by Martin O'Boyle. 2 L,w OrncraorawaerAP)L6,Ba0UZR&vAKw P.G. 208- E.3^eauES7�,B0eAPAMN ptp1, 132 o 33-3911 P.0041005 RECEIVED 08/08/2014 13:10 5613946102 S3V 08/08/2014 13:31 Commerce Group ffAX)9543600807 Martin E_O'Boyb v. Town of Gulfaveam 1. Since opening the O'Boyle Law Firm, Jonathan O'Boyle has had a constant presence in the State of Florida handling legal matters for his father and his father's businesses, including at least four (4)pro hac vice appearances. m. Jonathan O'Boyle has misrepresented his residence as part of his filings with the Court and/or the Bar. S. Immediately after Defendant filed "the Motion ", Plaintiff, Martin O'Boyle (hereinafter "O'Boyle") and his counsel, William Ring, requested a meeting with Joanne M. O'Connor, John C. Randolph and Sidney Stubbs of the Jones Foster law firm. 6. On June 4, 2014, O'Boyle, William Ring, Joanne O'Connor, and John Randolph met in the offices of Jones Foster. Mr. Stubbs was not in attendance. 7. O'Boyle indicated the meeting should be confidential in nature as it was palled for the purpose of arivhig at a settlement. However, Plaintiff then proceeded to issue implicit threats, stating that as a result of the Motion, which was directed at O'Boyle's son's law firm, O'Boyle intended to take steps against opposing counsel and their children. O'Boyle also made an implicit threat of physical violence staling, "you )mow I've never been a violent person. These hands have never touched anyone" O'Boyle inquired regarding opposing counsel, Joanne O'Connor's, marital status and threatened to hire investigators to "watch counsel's daughter to see if she slips up." 8. O'Boyle further stated that he was going to open sober houses throughout the Town of Gulf Stream, 9. These statements were made for the purpose of intimidating counsel, including undersigned counsel. The above conduct has caused undersigned counsel's co- counsel to become witnesses with regard to these events and this motion. 3 LAW 0"Ficas OF SWMAFPLa, DROars,n & VAM4 P.L 20 S33, 39° STRBar, ROCA BATON, FWRIvA 33432.3911 P.0051005 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail October 30, 2014 Commerce GP, Inc. [mail to: records @commerce - group.com] Re: GS #1278 (107), #1280 (137), #1283 (140), #1285 (119) Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4g. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 4e., 4f., 4h.,4,4j., 4k., 41. And 4m) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O' [sic] And William Ring, Esquire, which wasfiled by Attorney Sweetapple. A copy ofsubparagraph 4g. of the referenced Motion is attached. In Connection with paragraph 23 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O' [sicj And William Ring, Esquire, which was filed by Attorney Sweetapple, please provide all Public Records which Attorney Sweetapple has relied upon in making the statements he did in that paragraph 23. In connection with the last line of numbered paragraph 26 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C, Jonathan O'[sicj And William Ring, Esquire, please provide all Public Records which Attorney Sweetapple referred to or utilized when making the statement that "[Martin E. O'Boyle's] has engaged in the use of intimidation, threats, extortion or slurs, in connection with Jonathan O'Boyle's alleged interstate law firm. Please provide a copy of any communications sent by William Ring to John Randolph in response to the statement made by Attorney Sweetapple in numbered paragraph 10 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O'Boyle And William Ring, Esquire that John Randolph wrote William Ring. Dear Commerce GP, Inc. [mail to: recordsaa commerce- group.coml, This letter provides you with the full production of public records you have requested on August 8, 2014. Your original request can be viewed at the following links: hgp: / /www2. sulf- stream. ors/ WebLink8 /0 /doc /20071/Pagel.asnx, htty: / /www2.eulf- stream. ore /WebLink8 /0 /doc /20073/Pagel.asyx, http://www2.gulf- stream.org/WebLink8/0/doc/20076/Pagel.asnx, and hftv://www2.gulf- stream.org/)VebLinkS/0/doc/20078/Pagel.asi)x. Similar requests were made to the town and the responsive documents are as follows: For GS# 1278, responsive documents can be found at the following link: httv://WWW2.gulf- stream.org/WebLink8/0/doc/17387/Pagel.aspx. For GS# 1280, responsive documents can be found at the following link: httt)://www2.gulf- stream.org/WebLink8/0/doc/17436/Pagel.asiix. For GS# 1283, The Town responds that the only responsive public record is a June 6, 2014 memorandum by counsel for the Town reflecting the reflecting counsel's mental impressions and conclusions, which memorandum is exempt pursuant to Fla. Stat. 119.071(1)(d). For GS# 1285, responsive documents can be found at the following link: him://www2.gulf- stream.org/WebLink8 /0 /doc /17339/Page l .aspx. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records