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Home My Public Portal AboutPRR 14-12801280 RECEIVED 00/08/2014 13:12 5613946102 SBV 08108/2014 1333 Commerce Group 1FAMS43800807 P.0021003 RECORDS REQUEST (the "Request ") Date of Request: 8/8/2014 Requester's Request ID#: 137 REQUESTEE: Custodian of Records - Sweetapple, Broeker, Varkas, P.L. REQUESTOB: Commerce GP, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: reeor&@commerce- group.com Fax: 954 - 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: 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., on an 0 isicj i tam mg, squ re, w 1c was t e orney Sweetapple, -Pl4mae- pmovide- all-ft In making the statements he did in that paragraph 23. 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 IN ELECTRONIC FORM. IF NOT AVAILABLE IN Er ECTRONIC FORM IT IS REQUESTED THAT THIS RECORDS RZOUESTBE FULFILLED ON 11 X 17 PAP NOTE: IN ALL CASES UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD D H BILLED IN ACCORDANCE, WITH Section 119.07(4) (e 2 ALL ELECTRONIC COPIES ARE REQUESTED TO BE S4NT BY E -MAIL D, 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 coal, 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. 1:P/NFR/FRR 04.22.13 FORM RECEIVED 08/08/2014 13:12 5613946102 5BV 0810812014 13:33 Commerce Group ffW543600807 P.0031003 Martin B. O'Boyle v. Town of Gulfsneam CASE NO.502014CA004474XXXXMBAO (PALM BEACH cOUNTI) 21. O'Boyle has abused the legal system in several states by overwhelming local municipal governments and a State Attorney's office with the {Bing of thousands ofpublic records requests and abusive litigation. 22, The case of Martin E. O'Boyle v. Peter Isen, 2014 WL 340104 (N,J,SuperA.D.), issued by the Superior Court of New Jersey, Appellate Division, on appeal from case no. L- 2341.08, is attached hereto as Exhibit "411. The Court noted, From September 2007 through early July 2008, plaintiff and members of his family filed multiple requests pursuant to the Open Public Records Act (OPkA), N.I.S.A. 47;IA -1 to -13. Longport's only clerk worked part-time, end she did not address the requests within the time required by statute. At one point, the clerk went to the emergency mom because of the stress she attributed to the flood of OPRA requests. And, in February 2008, the Borough's solicitor notified plaintiff that it would not accept any additional OPRA requests he filed, explaining that the numerous requests were substantially disrupting governments] services, The solicitor claimed that Longport had received 190 requests on October 16 and 17 and thirty filed October 31, 2007. In the lren case, O'Boyle sued a resident of Longport for claiming O'Boyle was "the enamy of Longport". The suit for defamation was dismissed by summary ,judgment and affirmed by the appellate court. 23. Similarly, when his daughter was being prosecuted for driving under the influence, O'Boyle inundated the Palm Beach County State Attorney's Office both individually and through companies he controls with over 1,300 requests for public records. (attached hereto as Exhlbit "if)). 24. In an interview with the Palm Beach Post discussing his dealings with then candidate Dave Aronberg, O'Boyle stated, My view in life is: Take whatever shots you like at me, because I'm a big boy and I can handle them. But don't mess with my kids, my wife ormy home. Don't do it Don't. Because I'll come at you with every resource I have. And there's a lot. (attached hereto as Exhibit 116 "). 6 LAW OFMU orSWMrrA14La, Baoexaa& VARXA.%P.L. 203.E- 3`' 3n=, B= RArcW, KONDA33432.3911 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