The URL can be used to link to this page

Home My Public Portal AboutPRR 14-1293RECEIVED 08/08/2014 13:55 5613946102 SBV 1 2 9 3 0810812014 14:15 Commerce Group TAXASA3600807 P.0021003 RECORDS REQUEST (the "Request' Date of Request 8/8 /2014 Requester's Request ID#: 121 REQTIESTEE: Custodian of Records - Sweetapple, Broelter, Varkas, P.L. REQUESTOR: Asset Enhancement, Inc. REQUESTOR'S CONTACT' INFORMATION: E -Mail: recotds@commerce-group,eom Fax: 954. 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple In numbered paragraph 12 of the befendant s lotion Foi Sanctions Against P air,, G Boylejeounseh f Record, - The O'Boyle Low Firm P.C., Jonathan O'Boyle And William Ring, Esquire which was filed by Attorney Sweetapple. 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 RIGITTS 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 TT IS REOUESTED THAT THIS RECORDS REQUEST BE FULFILLED .N -X 17 PAPER. NOTE: IN ALI., CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD D BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE IMO JESTED TO BE SENT BY E-M &jI DELIVERY 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. I:P/NPR/FRR 04.22.13 FORM RECEIVED 08/00/2014 13:55 5613946102 SBV 03108/2014 14:16 Commerce Group (FW543M07 P.0031003 O'BOYIe V. Town of oullknam CASE N0.502014CA004474XXXX?,9AO (PALM BEACH COI3NPY1 30. Following the meeting, John Randolph wrote a letter to William Ping infomling him that the meeting did not involve settlement discussions and therefore it would not be treated as confidential, Exhibit 191". 11. After the meeting, O'Boyle commenced to have airbome banners flown on a daily basis over Palm Beach County, Some of the banners road; 12. On June 6, 2014, O'Boyle had his attorney and business associate, William Ring, Esquire, form a Florida limited liability company called "Sweet Apple Sober Houses, LLC" , Exhibit 4211, an obvious reference to a defease 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's co- counsel, Robert Sweetapple, stating that a Judge of the First District Court of Appeal had found that "W. Sweetapple consistently misrepresented testimony and failed to ackmowledge well- established case law, including Supreme Court precedents." (Exhibit 11311) 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 Firm. Specifically, this misconduct is being 4 LAW Orfrcmae or SweerMnS, Baceam& VAM A9, P.L. 20S -8.3 Siaerr. EecARAma, PICKWA33432.3911 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail October 30, 2014 Asset Enhancement, Inc. [mail to: records @commerce- group.com] Re: GS #1293 (121), #1296 (115), #1297 (116), #1298 (117), #1301 (109), #1304 (98) Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 12 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, which was filed by Attorney Sweetapple. Please provide all Public Records confirming the statement in numbered paragraph 5 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 wherein Attorney Sweetapple states "Immediately after Defendant filed "the Motion ", Plaintiff,' Martin O'Boyle (hereinafter "O'Boyle').... requested a meeting with ..... the Jones Foster lawfrm. Provide all Public Records which confirm all of the statements made by Attorney Sweetapple in numbered paragraph 7 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, which was filed by Attorney Sweetapple. Provide all Public Records confirming the statement of Attorney Sweetapple in numbered paragraph 8 of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Records, The O'Boyle Law Firm, P. C., Jonathan O'Boyle And William Ring, Esquire, which was filed by Attorney Sweetapple. Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the statements that he made in numbered subparagraph 4i. (excluding subparagraphs 4, 4a., 4b., 4c., 4d., 4e., 4f., 4g., 4h., 4j., 4k., 41. And 4m.) of the Defendant's Motion For Sanctions Against Plaintiff, Martin E. 0Boyle, 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 4i. of the referenced Motion is attached. Please provide all Public Records which confirm the validity of the statement made by Attorney Sweetapple in numbered paragraph 3 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'fsicj And William Ring, Esquire, which was filed by Attorney Sweetapple. A copy ofparagraph 3 of the referenced Motion is attached. Dear Asset Enhancement, Inc. [mail to: recordsecommerce- group.coml, This letter provides you with the full production of public records you have requested on August 8, 2014. Your original request can be viewed at the following links: http://www2.gulf- stream. ore /WebLink8 /0 /doc /20086/Pagel.asRx, http://www2.gulf- stream.org/WebLink8 /0 /doc /20089/Pagel.aspx, http://www2.gulf- stream.org/WebLink8 /0 /doc /20090/Pagel.aspx, http://www2.gulf- stream.org/WebLink8 /0 /doc /20091/Pagel.asyx, http://www2.gulf- stream.org/WebLink8 /0 /doc /20094/Pagel.aspx, and ht_pt : / /www2.gulf- stream.org/WebLink8 /0 /doc /20097/Pagel .aspx. Similar requests were made to the town and the responsive documents are as follows: For GS# 1293, responsive documents can be found at the following link: http://www2.gulf- stream.org/WebLink8 /0 /doc /17343/Page l .aspx. For GS# 1296, responsive documents can be found at the following link: httv://www2.gulf- stream.org/WebLink8 /0 /doc /17391/PageLam. The attached correspondence is being produced to you solely in an abundance of caution and without waiving the Town's position that it is not a public record as it was not copied or forwarded to the Town. The Town further responds that the only other responsive public record is a June 6, 2014 memorandum by counsel for the Town reflecting the reflecting counsel's mental impressions and conclusions, which memorandum is exempt pursuant to Fla. Stat. § 119.071(1)(d). The exempt information here relates to pending and reasonably anticipated imminent litigation involving the Town, William Thrasher, Garrett Ward, Scott Morgan and Robert Sweetapple, on the one hand, and Martin O'Boyle and entities controlled by or affiliated with him including, but not limited to, Commerce GP, Inc., the Commerce Group, Inc., Commerce Realty Group, Asset Enhancement, Inc., CG Acquisition Company, Inc., Citizens Awareness Foundation, Inc., Airline Highway, LLC, N984AC Caravan LLC, CRO Aviation, Inc., and STOPDIRTYGOVERNMENT, LLC., and Christopher O'Hare, on the other hand. For GS# 1297, the responsive documents can be found at the following link: http://www2.gulf- stream.org/WebLink8 /0 /doc /17335/Pagel.aspx. The attached correspondence is being produced to you solely in an abundance of caution and without waiving the Town's position that it is not a public record as it was not copied or forwarded to the Town. The Town further responds that the only other responsive public record is a June 6, 2014 memorandum by counsel for the Town reflecting the reflecting counsel's mental impressions and conclusions, which memorandum is exempt pursuant to Fla. Stat. § 119.071(1)(d). The exempt information here relates to pending and reasonably anticipated imminent litigation involving the Town, William Thrasher, Garrett Ward, Scott Morgan and Robert Sweetapple, on the one hand, and Martin O'Boyle and entities controlled by or affiliated with him including, but not limited to, Commerce GP, Inc., the Commerce Group, Inc., Commerce Realty Group, Asset Enhancement, Inc., CG Acquisition Company, Inc., Citizens Awareness Foundation, Inc., Airline Highway, LLC, N984AC Caravan LLC, CRO Aviation, Inc., and STOPDIRTYGOVERNMENT, LLC., and Christopher O'Hare, on the other hand. For GS# 1298, responsive documents can be found at the following link: http://www2.gulf- stream.org/WebLink8 /0 /doc /17463/Pagel.asnx. The attached correspondence is being produced to you solely in an abundance of caution and without waiving the Town's position that it is not a public record as it was not copied or forwarded to the Town. The Town further responds that the only other responsive public record is a June 6, 2014 memorandum by counsel for the Town reflecting the reflecting counsel's mental impressions and conclusions, which memorandum is exempt pursuant to Fla. Stat. § 119.071(1)(d). The exempt information here relates to pending and reasonably anticipated imminent litigation involving the Town, William Thrasher, Garrett Ward, Scott Morgan and Robert Sweetapple, on the one hand, and Martin O'Boyle and entities controlled by or affiliated with him including, but not limited to, Commerce GP, Inc., the Commerce Group, Inc., Commerce Realty Group, Asset Enhancement, Inc., CG Acquisition Company, Inc., Citizens Awareness Foundation, Inc., Airline Highway, LLC, N984AC Caravan LLC, CRO Aviation, Inc., and STOPDIRTYGOVERNMENT, LLC., and Christopher O'Hare, on the other hand. For GS# 1301, responsive documents can be found at the following link: http://www2.gulf- stream.org/WebLink8 /0 /doc/l 7379/1agel .asox. For GS# 1304, responsive documents can be found at the following link: http://www2.gulf- stream.orelWebLink8 /0 /doc / 17384/Pagel .asox. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records