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Home My Public Portal AboutPRR 14-1279RECEIVED 08/08/2014 13:10 5613946102 SBV 0810812014 13:32 Commerce Group MWX=7 RECORDS REQUEST (the "Request ") Date of Request: 8/8/2014 Requestor's Request ID#: 102 REQUESTEE: Custodian of Records- swestapple, Broeker, Varkas, P.L. REQUESTOR: Our Public Records, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: reeords@commerce- group.com Fax: 954 -360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records pursuant to which Attorney Swestappie relied upon to make the ., 4c., 4d., 4e., 4L, 49., 4h., 4f., 41., 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' Islc) And William Ring, Mquire , was i a y rney ea pp e, copy o s perap . o e erenead Motion Is attached. 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 BE FULFILLED FD IN ELECTRONIC FO L IF NOT AVARLABLE IN ELECTRONIC: FogM, IT IS RE0UESTEDMj&tTflIS RECORDS REOU EST BE FULFILLED ON 11 X 17 PAPER NOTE IN ALL CASES (UNLESS IMPOSSIBLEI THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH bectign 119 07(4) (a) f21 ALL ELECTRONI OPI S ARE REQUESTED TO BE SENT BY E -MAIL PFr iVERY PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requestor approve of say costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency, IWNPRIM 04.22.13 FORM 1279 P.0021005 RECEIVED 08/08/2014 13:10 5613946102 08108/2014 13:32 Commerce Group Filing M 15549445 Electronically FOed 07/03/2014 01:14:36 PM MARTIN E. O'BOYLE, Plaintiff, V. TOWN OF GULF STREAM, Defendant SBV TA*543500807 P.0031005 IN THE CIRCUIT COURT OF THE 1STH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA0044743CX CKNm DIVISION: AG 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 Finn, 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 I. On May 30, 2014, Defendant, through its counsel, Sweetapple, Broeker & Varkas, P.L., and Jones, Foster, Johnson & Stubbs, P.A., filed Defendant's Motion to Disqualify the O'Boyle Law Fimr, P.C, Inc, or in the Altemative, for an Evidentiary Hearing (hereinafter the "Motion'). 2. This Motion has been withdrawn without prejudice as Defendant is seekutg other remedies with regard to the matters addressed in the Motion. 3. Significantly, the O'Boyle Law Finn, P.C., Inc., registered as a Florida forelga profit corporation on February 10, 2014, claiming its principal office as 2146 E. Huntingdon Street, Philadelphia, 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'), as it Florida foreign profit corporation, the O'Boyle Law Firm LAW Orrrm cF SwnTA"L%tlROMR R VARKAt, RL. 20 SY -3 atanar, B= R=w. FLOawn334323911 RECEIVED 08/08/2014 13:10 5613946102 5BV 0810812014 13:32 Commerce Group ffAX19543M7 P.0041005 V, Town of oulfa0xam t'0 appears to have had no real business presence in Philadelphia, Pennsylvania Although it was registered as a Pennsylvania Corporation on November 14, 2013, it further appears that: a. 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. e. The O'Boyle Law Firm did not obtain an occupational license to conduct business in the City of Philadephia. £ 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. JOnathanO' BoyleisamemberofthePennsylvaniaBar ,butnotoftheFloridaBar. h. Jonathan O'Boyle advised the Pennsylvania Bar that he is an out- af-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 at 23 N. Hidden Harbour Drive, his parent's home address. j. At the time of the opening of the O'Boyle TAw 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 Law Orncaa OF awaeraepi.e, 8r=FA a: Vaasu,P.L, 20 S.E.30 Sttv:ar, BooatWog FLouaa33432dB1) RECEIVED 08/08/2014 13:10 5613946102 S13V 08/0812014 13:32 Commerce Group ffAMSU60W P.0051005 Martin E. O'Boyle V. Town of Gulfaaeam CASE No. 502014CAO04474XXXXMBAG (PALM BEACH COUNTY) 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. 5. Immediately after Defendant Sled "the Motion ", Plaintiff, Martin O'Boyle (hereinafter "O'Boyle'o 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 called forthe purpose of arriving at a settlement, However, Plaintiff than 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 stating, "You know I've never been a Violent person, These hands have never touched anyone." O'Boyle inquired regarding opposing counsel, Joel= O'Connor's, marital status and threatened to hire investigators to "watch counsel's daughter to see if she slips up," g• O'Boyle further stated that he was going to open sober houses throughout the Town of Oulf Stream. 9. These statements were made far 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 OPncss oP9WIFTAPPLa, BROa1Qa & VAReA6, P.L, 20 9.& 3- su=-BOCA BATON, FLORmA33432 -3911 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 16, 2014 Our Public Records, LLC [mail to: records @commerce- group.com] Re: GS #1279 (102) Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4b. (excluding subparagraphs 4, 4a., 4c., 4d., 4e., 4f., 4g., 4h., 4i., 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'[sicj And William Ring, Esquire was filed by attorney Sweetapple. A copy of subparagraph 4b. of the referenced Motion is attached. Dear Our Public Records, LLC [mail to: records @commerce- group.com], This letter is in response to the public records you have requested in your email received August 9, 2014. This correspondence is reproduced at the following link: http://www2.¢ulf- stream .org /WebLink8 /0 /doc/20072/Page l .asox. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records