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