HomeMy Public PortalAboutPRR 14-12841284
RECEIVED 08/08/2014 13:14 5613946102 SBV
0810812014 13:35 Commerce Group ft )09543600807 P.0021003
RECORDS REQUEST (the "Request')
Date of Request: 8/8/2014
Requestor's Request M#: 118
REQUESTEE: Custodian of Records - Sweetapple, Breaker, Varkas, P.L.
REQUESTOR: Commerce GP, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: records&ommerce- group.com
Fax: 954.360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
Provide copies of all Public Records confirming the validity of the statements
made by Attorney Sweetappie In numbered paragraph 9 of the Defendant's
,
The O'Boyle Law Firm P.C., Jonathan O'Boyle And William Rine Esquire
ADDITIONAL INFORMATION REGARDING REQUEST:
THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT,
CHAPTER 1I9 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 W THE FLORIDA
CONSTfTUTION.
IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULITILLED IN EL FCTRONiC
FORM IF NOT AV IS REOUESM THAT THIS
RECORDS REQUEST BE Fiti F r FD ON Il X 17 PAP R NOTE Int ♦r were (UNLESS
IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND $ILO XDjRE_pILrtp IN
_ACCORDANCE WITH 6ec +I�n
ALL ELECTRONIC COPIES ARE REQUESTED TO BE NT BY R.YL411, DELIVERY
PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC
RECORDS REQUEST IN ADVANCE.
It will be required that the Requestor 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.
I:PINPPJPRR
042213 FORM
RECEIVED 08/08/2014 13:14
08108/2014 13:36 Commerce Group
Mcnln E.
V. Town of Gulfstrcam
5613946102 SBV
ffW095A3800807 P.0031003
1. Since opening the O'Boyle Law Finn, 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 hoc 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'Beyie'D and his counsel, William Ring, requested a meeting with Joanne M. O'CoilrrOr, 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 itwas called for the purpose
Of arriving 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 stating, "'You know 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 tip."
8. O'Boyle further stated that he was going to open sober houses throughout the Town of Oulf
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 OFFICES DFSWEVrAFFi,y BROMM 8 VA8%16, P1,
20 S.E. 3m Srarsr, BOLA RATOK Pi.0a1DA33432.3911
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
November 4, 2014
Commerce GP, Inc. [mail to: records @commerce- group.com]
Re: GS #1284 (118)
Provide copies ofall Public Records confirming the validity of the statements made by Attorney
Sweetapple in numbered paragraph 9 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.
Dear Commerce GP, Inc. [mail to: records(a),commerce- aroup.coml,
This letter is in response to the public records you have requested which we received August 8,
2014. Your original requests can be found at the following link http://www2.gulf-
stream.org/WebLink8/0/doc/20077/PaLzel.ast)x.
Be advised that no such records exist.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records