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Home My Public Portal AboutPRR 14-12851285 RECEIVED 08/08/2014 13:16 5613946102 S13V 0810812014 13:37 Commerce Group OM)954350a807 P.002/003 RECORDS REQUEST (die "Request") Date of Request: 8/8/2014 Requestor's Request ID#: 119 REQUESTEE: Custodian of Records - Sweetapple, Broeker, Varkas, P.L REQUESTOR: Commerce GP, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commercegroup.com Fax: 954. 360.0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: 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 e, Cnymswl of Record The O'Boyle I aw Firm P C,, Innwthan rf R yle And William Ring Esquire that John Randolph wrote William Ring. 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 ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER NOTE: IN ALL CASES (UNLESS ESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARF REOUESTF BE SENT BY E-MAIL 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 Requestor by the Agency. L•PMR/FRR 04.22.13 FORM RECEIVED 08/08/2014 13:16 5613946102 SBV 08108/2014 1337 Commerce Group ffAX)954360W P.0031003 Martin B. O'Boyle V. Town of Ga treani CASE NO.302014CA004474,M)p(MBAO (PALM BEACH ro 10. Following the meeting, Jolm Randolph wrote a letter to William Ring informing him that the meeting did not involve settlement discussions and therefore it would not be treated as confidcndal, Exhibit 111". 11. After the meeting, O'Boyle commenced to have airborne banners flown on a daily basis over Palm Beach County. Some of the banners read: 12. On June 6, 2014, O'Boyle had his attorney and business associate, William Ring, Esquire, form a Florida limited liability company called "Sweet Apple Sober Houses, LLC", Exhibit "2 ", an Obvious reference to a defense counsel's surname. 13. In addition, on June 13, 2014, O'Boyle appeared before a meeting of the Gulf Stream Town Commission and made false and defamatory allegations against Gulf Stream's co-counsel, Robert Sweetapple, stating that a Judge of the First District Court of Appeal had found that' Mr. Sweetapple consistently misrepresented testimony and failed to acknowledge well - established case law, including Supreme Court precedonts," (Exhibit 9") This statement is patently unimc, and was made to undermine the Town's confidence in its attorney. 14. The above threats and conduct have occurred with the knowledge, cooperation and complicity Of WMAM Bing, Jonathan O'Boyle and the O'Boyle Law Firm. Specifically, this misconduct is being LAW Omcss or SwesrAmH, ExoaKot & VAarns, P.L. 20 SS 3' SrrwT, BocA RAMA FLOan1A 33432.3911 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