The URL can be used to link to this page

Home My Public Portal AboutPRR 14-1287RECEIVED 88/08/2014 13:16 5613946102 SBV 0810812014 13:37 Commerce Group 0:AM543600807 RECORDS REQUEST (the "Request") Date of Request: 8/8/2014 Requestor's Request ID #: 104 REQUESTEE: Custodian of Records - Sweetapple, Broeker, Varkas, P.L. REQUESTOR: Commerce GP, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce- group.com Fax: 954 - 360-0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records pursuant to which Attorney Swealapple retied upon to make the state mants that he me a nnum ere su paragrep exc u rng su paragre a e., 44., 4c.. 4e..4 ., 4a.. 4h. 41 41.,4k., 41 and 4m) of the Defendant's Motion For Sanctions Anainst Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Lew Arm, P.C., Jonathan D'(sic) And William Ring, Esquire, which was fled by Atmrney Sweatapple. A copy of subparagraph 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 REQUESTER PROVIDED IN THE FLORIDA CONSTITUTION. IT IS REOUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC EQ II IF NOT AVAILABLE IN EL CTROM FORM IT IS REOUESTED THAT TffiS RECORDS RE UE T B ULFIL ED ON 11 X ER NOTE: IN AL . CASES UNLESS IMPOSSIBLE) THE COPIES SHO1 DBE TWO 1DED AND SHOULD RE BILLED IN ACCORDANCE WITH Section 119.07(4) fal 1`21 ALL ELECTRONIC C nrTEg ARE REOUESTFn TO 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 dellned in Florida Statute, Chapter 119.01 [Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:PMPR/FRR 0422.13 FORM 1287 P.0021005 RECEIVED 08108/2014 13:16 5613946102 0810812014 13:38 Commerce Group Filing # 15549445 Elentmnically Filed 07/03!1014 01:14:36 PM MARTIN E. O'BOYLE, Plaintiff, v. TOWN OF GULF STREAM, Defendant SBV ffX09543600807 P.003/005 IN THE CIRCUIT COURT OF THE I5� JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA004474IOCxXmB DIVISION: AO Defendant, Town Of Gulf Stream, moves this Court for the imposition of sanctions against Plaintiff, Martin E. O'Boyle, Counsel of Record, the O'Boyle Law Firm, P.C., Inc., its President, Jonathan O'Boyle, and William Ring, Esquire, for unprofessional, unethical and abusive litigation tactics, and as grounds therofore would show the Court that: 1. On May 30, 2014, Defendant, through its counsel, Sweetapple, Braeker & Varkas, P.L., and Jones, Foster, Johnson & Stubbs, P.A., filed Defendant's Motion to Disqualify the O'Boyle Law Firm, P,C, Inc., or in the Alternative, for an Evidentiary Hearing (hereinafter the "Motion'). 2. This Motion has been withdrawn without prejudice as Defendant is seeking otherremedies with regard to the matters addressed in the Motion. 3. Signifioaatly, the O'Boyle Law Firm, P.C., Inc., registered as a Florida foreign profit corporation on February 10, 2014, claiming its principal office as 2146 a Huntingdon Shoot, Philadelphia, Pennsylvania. 4. Upon information and belief✓ at the time of registering the O'Boyle Law Finn, P.C., Inc, (hereinafter the "07Boyle Lew Fimt'), as a Florida foreign profit corporation, the O'Boyle Law Firm LAW Or =CPSWeaAMABwrxaaa:VAUU,P.L, 26S.8.305TRW. BacARAroa. PLM OPA33432.3011 RECEIVED 06/OB/2014 13:16 5613946102 S3V 0810612014 13:38 Commerce Group (FAX )9543600807 P.0041005 Martin E. O'Boyle Y. Town of Oulfhvhm CASE NO.502014CA004474)CXX)aIMAO (PALM BEACH COUNTY) appears to have had no real business presence in Philadelphia, Pennsylvania. Although it was registered as a Pennsylvania Corporation on November 14, 2013, it further appears that: IL The O'Boyle Law Firm did not own or lease any commercial space there. b. The O'Boyle Law Firm did not have a business telephone line. c, The O'Boyle Law Firm had no employees and paid no salaries. d. The O'Boyle Law Firm did not pay city, state or federal taxes because it had no employees. e. The O'Boyle Law Firm did not obtain an occupational license to conduct business in the City of Philadephia. f. The O'Boyle Law Firm's sole Principal, officer and director, Jonathan O'Boyle, used his Florida cell phone number (561 -758- 1223), as the firm telephone number. B. Jonathan O'Boyle is a member of the Pennsylvania Bar, but not of the Florida Bar. h. Jonathan O'Boyle advised the Pennsylvania Bar that he is an out -of -state attorney with an address in Florida, i. Jonathan O'Boyle advised the Pennsylvania Bar that his address is in the Town of Oulf Strewn, Florida at 23 N. Hidden Harbour Drive, his parent's home address. J. At the time of the opening of the O'Boyle Law Firm in Florida, Jonathan O'Boyle resided and was domiciled in Florida. k. When the O'Boyle Law Firm opened in Florida, it was operated out of his father, Martin O'Boyle's, office at WestNewport Center Drive, Deerfield Beach, Florida. It is still operated out of this building, which is owned or controlled by Martin O'Boyle, 2 LAw 0"= or SwEerApece, 13ROEM & VARTAS. P.L. 20 S.B. 3" STarar, BWARATON, PLOamA334323911 RECEIVED 08/08/2014 13:16 5613946102 SBV 0810812014 1338 Commerce Group 0!05436OW P.0051005 Mudn E. O'Boyle v. Town of Guiiitream CASE NO.502014CA004474XXXXMBAO (BALM BEACH COUNTY) 1. Since opening the O'Boyle Law Firm, 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 hae vice appearances. m. Jonathan O'Boyle has misrepresented his residence as part of his filings with the Court and/or the Bar. 5. Immediately after Defendant filed "the Motion", Plaintiff, Martin O'Boyle (hereinafter 'O'Boyle') and his counsel, William Ring, requested a meeting with Joanne M. O'Connor, John C. Randolph and Sidney Stubbs of the Jones Foster law fine. 6. On June 4, 2014, O'Boyle, William Ring, Joanne O'Connor, and John Randolph met in the oti'rces of Janes Foster, Mr. Stubbs was not in attendance. 7. O'Boyle indicated the meeting should be confidential in nature as it was called for the purpose of arriving at a settlement:However, Plaintiff then proceeded to issue implicit do ats, stating that as a result of the Motion, which was directed at O'Boyle's son's law faro, O'Boyle intruded 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 ()'Co=or's, marital status and threatened to hire investigators to 'watch counsel's daughter to see if she slips up," g. O'Boyle further stated that he was going to open sober houses throughout the Town of Gulf 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 E LAWO"MMor3WISTAM BaQflKMa'VAacas,P.4 20 S.B.3 w 53aee , BOCA Ritot{ PtA1aoA 33432 -3911 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 23, 2014 Commerce GP, Inc. [mail to: records @commerce- group.com] Re: GS #1281 (138), #1287 (104), #1288 (103) In 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'Boyle And William Ring, Esquire, please provide all Public Records pursuant to which Attorney Sweetapple is using to challenge that Jonathan O'Boyle has an interstate law firm. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4d. (excluding subparagraphs 4, 4a., 4b., 4c., 4e., 4f., 4g., 4h., 4i., 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 was filed by Attorney Sweetapple. A copy of subparagraph 4d. of the referenced Motion is attached. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4c. (excluding subparagraphs 4, 4a., 4b ... 4d., 4e., 4f., 4g., 4h.,4i.,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' [sicj And William Ring, Esquire, which was f led by Attorney Sweetapple. A copy of subparagraph 4c. of the referenced Motion is attached. 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: http://www2.gulf- stream. ore /WebLink8 /0 /doc /20074/Paeel.asnx. http://www2.gulf- stream.or¢/WebLink8 /0 /doc /20080/Pa eg l.aspx, and htty://www2.gulf- stream.orWWebLink8 /0 /doc /20081 /Pagel .aspxx. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records