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HomeMy Public PortalAboutPRR 14-1292RECEIVED 08/08/2014 13:53 5613946102 g8V 1 a -72 0810812014 14:14 Commerce Group TA)09543t:M7 P.0021003 RECORDS REQUEST (the "Request ") Date of Request: $1812014 Requester's Request M #: 136 REQUESTEE: Custodian of Records - Sweetapple, Bmeker, Varkas, P.L. REQUESTOR: Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commeroe- group.com Fax: 954360 -0807; Address, 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: 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 abused the local system In several states Please provide all Public Records pursuant to which Attorney Sweetapple relied upon in making the statement in "quotes ". 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 REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORt p TE IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD HE BILLED IN ACCORDANCE WITH Section 119,07(4) (a) (2) ALL ELECTRONIC COPIES AAE EOU STS D TO BE SENT BY MAII , nrf iVER 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(Detinitions)), in advance of any costs Imposed to the Requester by the Agency. LPIRRIFRR 0472.13 FORM RECEIVED 00/08/2014 13:53 5613946102 SBV 08108!2014 14:14 Commerce Group fA49543600H07 P.0031003 Martin B. O'Boyla V. Town of Outthae´┐Żn CASE NO.502014CAU04474XXXXMBAG (PALM BEACH COUNTY) 21. O'Boyle has abused the legal system in several states by overwhelming local municipal governments and a State Attorney's office with the filing of thousands of public records requests and abusive litigation. 22, The MeofMartinE. O'Boyle s. Peter lsen, 2014WL340104 (N.J.Super.A.D.), issued bythe Superior Court of New Jersey, Appellate Division, on appeal from case no, L- 2341.08, is attached hereto as Exhibit "411. The Court noted, From September 2007 through early July 2008, plaintiff and members of his family filed multiple requests pursuant to the Open Public Records Act COPRA), N.J.S.A. 47.-IA-1 to -13, Longport's only clerk worked part (OPRA), and she did not address the requests within the time required by statute. At one point, the Clerk went to the emergency room because of the stress she attnbu0ed to the flood of OPRA requests, And, in February 2008, the Borough's solicitor notified plaintiff that it would not accept any additional OPRA requests he filed, explaining that the numerous requests were substantially disrupting governmental services. The solicitor claimed that Longport had received 190 requests on October 16 and 17 end thirty filed October 31, 2007, In the Ash case, O'Boyle sued a resident of Longport for claiming O'Boyle was "the enemy of Longport". The suit for defamation was dismissed by summary judgment and affirmed by the appellate court 23, Similarly, when He daughter was being prosecuted for driving under the influence, O'Boyle Inundated the Palm Beach County State Attorney's Office both individually and through companies he controls with over 1,300 requests for public records. (attached hereto as Exhibit "5'o. 24, In an interview with the Palm Beach post discussing his dealings with then candidate rave Arenberg, O'Boyle stated, My view in life is: Take whatever shots you like at me, because I'm a big boy and I can handle them, But don'tmess with my kids, my wife ormyhome. Don't do it. Don't Because I'll come at you with every resource I have. And there's a lot (attached hereto as Exhibit "619), 6 GLW ORRCES or SWENTAFPLe, Baom;mt A VAaxAS, P.L 20 S.E. 3'° Sraeer, BccA RAteN, POCamw33432.3911 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