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Home My Public Portal AboutPRR 14-1294RECEIVED 08/08/2014 13:55 5613946102 SBV 1294 08108/2014 14:16 Commerce Group T008543M07 P.0021003 RECORDS REQUEST (the "Request") Date of Request: 8/8/2014 Requestoes Request ID#: 122 RBQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTOR: Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records@i:ommerve.group.com Fax; 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: In numbered paragraph 13 of the Defendant's Motion For Sanctions Against Plalnd", Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P.C., ' � s 1�Il�pgstle validity of the Innt ■wnfe; to of that pnregrenh 14 as made h� Attorney Swee:tapple, 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 REOLIFgT BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAU,ABLE IN ELECTRONIC FORM IT IS REQUESTED MAT TIIIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAP R NOTE IN ALL s c rU[yLESS IMF OSS[BLE1 THE COPIES SHOU .D B TWO SIDED AND SHOULD BE BILLED IN ACr.ORPMCH,wrrH section 119.07 4 a ALL ALLELECCTRONIC COPIES ARE REOUESTED TO BE RENT 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 defined in Florida Statute, Chapter 119.01 (Definitions)), In advance of any costs imposed to the Requestor by the Agency, I:P/NPRIFRR 0412,13 FORM RECEIVED 08/08/2014 13:55 08/0812014 14:16 Commerce Group Martin E. O'Boyle v. Town of Qulatrum 5613946102 SEV (FAX)9543600807 P.0031003 10. 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 "1 ". 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; DATE TIME ACTIVITY MESSAGE 12. On June 6, 2014, O'Boyle had his attorney and business associate, William Ring, Eaquire, form a Florida limited liability company called "Sweet Apple Sober Houses, LLC ", Exhibit 42 ", an Obvious reference to a defense counsel's surname. 13, In addition, on June 13, 2014, O'Boyle appeared before a meeting of the Oolf Stream Town Commission and made false and defamatory allegation against Otilf Stream's co� counsel, Robert Sweetapple, stating that a Judge of the First District Court of Appeal had found that I%& Sweetapple consistently misrepresented testimony and failed to acknowledge well-established case taw, including Supreme Courtpiacedentg." (Exhibit 911) 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 laaowledge, cooperation and complicity Of WilliamRing, Jonathan O'Boyle and the O'Boyle Law Firm. Specifically, this misconduct is being 4 LAW Orr m orSwaaTMtL4 BROeaaa k VAMAr, P1. 205.8.3" Smaar, Been BAtor; Fwuon33432 -3911 rune -J V14= MSTER CLIENTS, CHECK YOUR BILLS" 06/06/14 @2 :00 pm Banner Plane "JF DON'T DR_ INK & DRWB — WELL BE WATCHINOn 06/10/14 @2;00 pm Banner Plane "HAS JONES POSTER EMBRACED A BAD 06/13/14 (x)11:10 am Banner Plane APPLET. "JONES FOSTER —YOUR BILLS MAKB ME PUKE" 06/20/13 @11:00 am Banner Plane "SWEET APPLES ARE ROTTEN APPLES RTOiiT JF" 06/24/14 @10:38 am Banner Plane ' APPLES ARE BEST BOILED IN OIL" 12. On June 6, 2014, O'Boyle had his attorney and business associate, William Ring, Eaquire, form a Florida limited liability company called "Sweet Apple Sober Houses, LLC ", Exhibit 42 ", an Obvious reference to a defense counsel's surname. 13, In addition, on June 13, 2014, O'Boyle appeared before a meeting of the Oolf Stream Town Commission and made false and defamatory allegation against Otilf Stream's co� counsel, Robert Sweetapple, stating that a Judge of the First District Court of Appeal had found that I%& Sweetapple consistently misrepresented testimony and failed to acknowledge well-established case taw, including Supreme Courtpiacedentg." (Exhibit 911) 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 laaowledge, cooperation and complicity Of WilliamRing, Jonathan O'Boyle and the O'Boyle Law Firm. Specifically, this misconduct is being 4 LAW Orr m orSwaaTMtL4 BROeaaa k VAMAr, P1. 205.8.3" Smaar, Been BAtor; Fwuon33432 -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