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HomeMy Public PortalAboutPRR 14-1286RECEIVED 08/08/2014 13:16 5613946102 SBV 1 2 8 6 0810812014 13:37 Commerce Group TOSI:I600907 P.0021003 RECORDS REQUEST (the "Requesr� Date of Request: 818/2014 Requestor's Request ID#: 120 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTOR: Commerce GP, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mall: records@commerce- group.com Fax: 954- 360.0807; Address: 1280 West Newport Center Drive, Deerfield Beach, PL 33442 REQUEST: Please provide all Public Records which confirm the statement made in numbered Paragraph 11 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E William Rine Esegire by Attorney Sw anplo s hlch reds as fell A the meeting, O'Boyle commenced to have airborne banners flown on a daily basis over Peim Beach County. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER I19 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 STED THAT THIS RECORDS R Ot TST BE FULFILLED IN ELECTRONIC FORM. IF NOT.AVAILABLE_I_N ELECTRONIC FORM IT IS REQUESTED THAT THIS RECORDS REOUEST BE FULFILLED ON I I X 17 PACER NOTE DP ALL CASES (UNLESS IMP 4$IBLE) THE COPLS SHO Lp B TWO SIDF,D AND SHOULp BE BILLED IN ACCORDANCE WITH Section 11907(4) (a) (2) ALL ELECTRONIC COPIES A R REpUECTFA TO BE SENT BY E -- DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE It will be required that the Requestor approve of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), In advance of any costs imposed to the Requestor by the Agency. ITINPRIFRR 04.22.13 PORK RECEIVED 08/06/2014 13:16 5613946102 SBV 0810812014 13:37 Commerce Group Q:M5436tg807 P.0031003 Martin E. 0.130y1e v. Town of Oulatcam CASE NO.502014CAD04474XXXXMBAO (PALM BEACHCOUNM I0. Following the meeting, John Randolph wrote a letter to William Ring informing him that the meeting did not involve settlement discussions and therefore it would not be treated as confidential, Exhibit 1111. 11. After the meeting, O'Boyle commenced to have airborne banners flown on a daily basis over Palm Beach County. Some of-the banners read: 12. On June 6, 2014, O'Boyle had his attorney and business associate, William Ring, Esquire, form a Florida limited liability company called "Sweat Apple Sober Houses, LLC ", Exhibit "211, an obvious reference to a defense counsel's surname. 13. In addition, on June 13, 2014, O'Boyle appeared before a meeting of the Gulf Stream Town Commission and made false and defamatory allegations against Gulf Stream,$ co- counsel, Robert SweetePP1% stating that a Judge of the First District Court of Appeal had found that "Mr. Sweetapple consistently misrepresented testimony and failed to acknowledge wen.established case law, including supreme Court precedents." (Exhibit " 3") This statement is patently untrue, 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 William Ring, Jonathan O'Boyle and the O'Boyle Law Finn. Specifically, this misconduct is being 4 LAW OFFiwa OF SwaerArrra, BIMIR& VAaaAa. P.L. 20 S.E. 30 StnM, 80CA RA10 ,iURM33432.391 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 29, 2014 Commerce GP, Inc. [mail to: records @commerce- group.com] Re: GS #1286 (120) Please provide all Public Records which confirm the statement made in numbered paragraph 11 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 by Attorney Sweetapple which reads as follows: 'After the meeting, O'Boyle commenced to have airborne banners flown on a daily basis over Palm Beach County. Dear Commerce GP, Inc. [mail to: records @commerce- group.com], This letter is in response to the public records you have requested in your email received August 8, 2014. This correspondence is reproduced at the following links: htti)://www2.gulf- streatn.org/WebLink8/0/doc/20079/Pagel.asDx. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records