Loading...
HomeMy Public PortalAboutPRR 14-12901290 P.ECEIVED 03/08/2014 13:53 5613946102 SBV 0810812014 14:13 Commerce Group ffA8A543600807 P.0021003 RECORDS REQUEST (the "Request ") Date of Request: 81812014 Requestor's Request M#: 134 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTOR: Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: recordsQo eommeroagroup.com Fax: 954-360 -0807; Address: 1260 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide all Public Records which confirm that stated by Attorney Sweetapple In paragraph 19 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., Jonathan O1[sic] Ancl am ng, qu re, w c was 1 e y orney Sweetapplo. 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 RRQUESTED THAT THIS RECORDS REQUEST BE FU FILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM Tf Ie REOuEsTED THAT THIS RECORDS RE01VENT BE pULEILLEr) ON 11 X 17 PAPER. NOTE: IN ALL S IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND HO LD V& BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E -MAIL DEL LVFRY PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requester 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. IT/NPRIFAR 04.2213 FORM RECEIVED 08/88/2014 13:53 5613946102 SBV 0810812014 14:13 Commerce Group ffp)gl Martin B. O'Boyle V. Town of Oulfeemm undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the O'Boyle Law Firm is a bona fide Interstate Law Finn. 15. The issue of whether the O'Boyle Law Firm is a bona fide Interstate Law Firm is one that should be resolved according to law. Xt should nut be the subject of harassment, intimidation and air raids by opposing counsel and their client I6. The misconduct is unprofessional, unethical and it constitutes an egregious example of litigation abuse. These tactics go beyond zealous representation and am designed to interfere with defense counsels' ethical obligation to their client. Such conduct undermines society's eommlhnent to the resolution of disputes in courts of law, rather than in the street or in the sky, 17. While citizens enjoy the constitutional right of free speech, that protection is afforded to truthful speech, and while attorneys must zealously represent their client's interests, they are also officers of the court, and arc prohibited from disparaging witnesses and attorneys, or otherwise undermining the administration ofjustire. 18. It is well settled that the trial court has inherent jurisdiction to sanction parties and their counsel for litigation abuse. TO, this instance, Plaintiff and his counsel have sought to cease any litigation or determination of the bona fides of the O'Boyle Law Firm by threatening and instituting reprisals against counsel, their client and families. 19, While O'Boyle has the right to continue to make a spectacle ofhims4 he, with the assistance of counsel, cannot impugn, malign and attempt to extort opposing parties or their counsel a$ part of the litigation process. 20. Abusive conduct is not a novelty for O' Boyle, who has left a historic trail Of abusive litigation. Lnw OFH= OPSWaarAms, BsanKM& VN1KA8, P.L. 203.& 3"° BTRM HOCARATOK FL=A334323911 P.003/003 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 23, 2014 Asset Enhancement, Inc. [mail to: records @commerce - group.com] Re: GS #1290 (134), #1291(135), #1292 (136), #1294 (122), #1299 (111), #1302 (105), #1303 (97) Please provide all Public Records which confirm that stated by Attorney Sweetapple in paragraph 19 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. Please provide all Public Records which Attorney Sweetapple relied upon in making the statement in paragraph 20 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C, Jonathan U[sic] And William Ring, Esquire, which was filed by Attorney Sweetapple. In paragraph 21 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, Attorney Sweetapple states "O'Boyle has abused the legal system in several states... ". Please provide all Public Records pursuant to which Attorney Sweetapple relied upon in making the statement in "quotes ". In numbered paragraph 13 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 confirming the validity of the last sentence of that paragraph 13 as made by Attorney Sweetapple. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4k. (excluding subparagraphs 4, 4a., 4b., 4c., 4d., 4e., 4f., 4g., 4h.A, 4j., 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 ofsubparagraph 4k. 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 4e. (excluding subparagraphs 4, 4a., 4b., 4c.,4d., 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 Sweetappple. A copy of subparagraph 4e. of the referenced Motion is attached. Please provide all Public Records which elaborate on the "other remedies" that the "Defendant" is seeking as set forth in numbered paragraph 2 of that certain Motion titled "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 paragraph 1 of the referenced Motion is attached. Dear Asset Enhancement, 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.eulf- stream. ore/ WebLink8 /0 /doc/20083/Pagel.asnx, http://www2.gulf- stream. orel WebLink8 /0 /doc/20084/Pagel.aspx, hlw://www2.gulf- stream.org/WebLink8 /0 /doc /20085/Pagel.asox, httv://www2.gulf- stream.org/WebLink8 /0 /doc /20087/Pagel.asix, httr)://www2.gulf- stream.orgfWebLink8 /0 /doc /20092/Pa el.aspx,, ht_pt : / /www2.gulf- stream.org/WebLink8 /0 /doc /20095/Pagel.asox, and http://www2.gulf- stream.org/W ebLink8 /0 /doc /20096/Pagel .asox, Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records