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Home My Public Portal AboutPRR 14-12951295 RECEIVED 08/08/2014 13:55 5GI3946102 SBV 08108/2014 14:16 Commerce Group ffAXAS43M7 P.0021004 RECORDS REQUEST (the "Requesr� Date of Request: 81812014 Requestor's Request ID#: 123 REQUESTEE: Custodian of Records - Sweetapple, Broeker, Varkas, P.L. REQUESTOR Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce- group.com Fax: 954- 360 -ND7; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide all Public Records which confirm Attorney Sweetapple's statement in the first sentence of numbered paragraph 14 of the Defendant's , The O'Boyle I aw Firm P S, Jonathan O'[sl0] And VLOliism Ring, Esquire, _wh h was filed by Attorney Swestapple. 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 REQUESTED THAT THIS RECORDS REOUEST BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAH,ABLE IN ELECTRONIC FORM IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER, NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE gOPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E-MAM 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 is Florida Statute, Chapter 119,01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:PRdPRIM 041113 FORM RECEIVED 08/08/2014 13:55 5613946102 SBV 08108/2014 14:16 Commerce Group ffAX)9543600807 P.003 /004 Mardn B. O'Boyle V. Town oraulbtream CASE NO.502014CA004474XXXX MBA(3 (PALM BEACH COUNTS') 10. Following the meeting; Jahn Randolph wrote a letter to William Icing informing him that the meeting did not involve settlement discussions and therefore it would not be treated as confidential, Exhibit "1 ", IL 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 MIX ACTIVITY MESSAGE 06105114 (x12:00 pm Banner Plane JONES FOSTER CLIENTS, CHECK yOUR HILLS" 06106/14 (12:00 pin Banner Plane "JF DON'T DRANK & DRIVE — WE'LL BE WATCHING" 06/10/14 @2:00 pm Banner Plane "HAS JONES FOSTER EMBRACED A BAD APPLE?" 06/13 /14 C1a 11:10 am Banner Plane "JONES FOSTER — YOUR BILLS MAKB ME PUKE" (x111:00 am Banner Plane "S WEFT APPLES ARE ROTTEN APPLES 710-6/24�/144 RIGHT JF" (x110:36 am Benner Plane "SWEET APPLES ARE HEST BOILED IN OIL" 12. On June 6, 20I4, O'Boyle had his attorney and business associate, William Ring, Esquire, form a Florida limited liability company called "Sweet Apple Sober Houses, LLC ", Exhibit "2 ", an obvious reference to a defense 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 ofAppeal had found that "Mr, Sweempple consistently misrepresented testimony and failed to aelmowledge well- established case law, including Supreme Court precedents," (Exhibit "3 ") This statement is patently untrue, and was made to underline the Town's confidence in its attomey, 14. The above threats and conducthave occurred with the knowledge, cooperation and complicity Of William Ring, Jonathan O'Boyl'o and the O'Boyle Law Finn. Specifically, this misconduct is being 4 LAWOPPfM Of SW&WPA BROEM &VARaA6, P,L, 20 S.B. 3 m $T=, Bock RATOy FLOR= 33432.391 I RECL-IVED 08/08/2014 13:55 5613946102 SBV 0810812014 14:17 Commerce Group ffAA)9543600807 P.004/004 Martin E. O'Boyle v. Tovm of cult4Croaro CASE N0.502014CA004474XXXXMBAC (PALM BEACH CO 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. It should not be the subject of harassment, intimidation and air raids by opposing counsel and their client. 16. The misconduct is unprofessional, unethical and it constitutes an egregious example of litigation abuse. These tactics go beyond zealous representation and are designed to interfere with defense counsels' ethical obligation to their client. Such conduct undermines society's commitment to the resolution of disputes in courts of law, rather than in the streets 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 are prohibited from disparaging witnesses and attorneys, or otherwise undermining the administration of justice. 18. It is well settled that the trial court has inherent jurisdiction to sanction parties and their counsel for litigation abuse. In 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 of himself, he, with the assistance Of counsel, cannot impugn, malign and attempt to extort opposing parties or their counsel as part of the litigation process, 20. Abusive conduct is not a novelty for O'Boyle, who has left a historic trail of abusive litigation. LAW OFF= OF SW66 MPLE, BaorM& VARK4 P.L. 20 S£ 3"° Smear, BocA RATon, FLosWA33432,791 I TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 4, 2014 Asset Enhancement, Inc. [mail to: records @commerce- group.com] Re: GS #1289 (133), #1295 (123) Please provide all Public Records confirming the language inserted in the last sentence of paragraph 18 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 filed by Attorney Sweetapple. Please provide all Public Records which confirm Attorney Sweetapple's statement in the first sentence of m(mbered paragraph 14 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. Dear Asset Enhancement, Inc. [mail to: recordsaa commerce- eroun.coml, This letter is in response to the public records you have requested which we received August 8, 2014. Your original requests can be found at the following link http://www2.gulf- stream.org/WebLink8/0/doc/20082/Pagel.asi)x and httv://www2.eulf- stream.ore/WebLink8 /0 /doc /20088/Paeel .asox. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records