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Home My Public Portal AboutPRR 14-12961299 RECEIVED 08/08/2014 13:55 5613946102 SBV 0810812014 14:17 Commerce Group ffAX)9543600807 P.0021003 RECORDS REQUEST (the "Request") Date of Request: 8/812014 Requestor's Request ID#: 115 REQUESTEE: Custodian of Records- Sweetapple, Brooker, Varkas, P.L. REQUESTOR Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION. E- Mail: records@commerce•group.com Fax: 954360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: 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, squire wherein Attorney Sweetapphs states "Immediately after Defendant filed "the Motion" Plaintiff, Martin O'Boyle (hereinafter "O'Boyle ")... requested a meeting with... the Jones Foster law firm. 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 RE ORDB REQUEST BE FULFILLED IN Er rCTRONTC FQRM. IF NOT AVAILABLE IN ELE MMC FORM IT IS UOUESTED THAT THIS RECORDS REOUEST BE FULFILLED ON 11 X 17 PAPER. NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BET O SID DA HOULD B BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REOU STED TO BE SENT BY EMAIL 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 cosh, asserted by the Agency (as defined In Florida Statute, Chapter 119.01 (Definitions)), in advance orany costs imposed to the Requestor by the Agency. I:PMPR/FRR 0422.13 FORM RECEIVED 08/08/2014 13:55 5613946102 SEV 0810812014 14:17 Commerce Group TAX19543800807 P.0031003 Martin E. O'Boyle V. Town of Gulfstream CASE NO.502014CA004474XXXXMBAG (PALM BEACH COUNTY) L Since opening the O'Boyle Law Firm, Jonathan O'Boyle has had a constant presence in the State of Florida handling legal matters for his father and his father's businesses, including at law four (4) pro hae vice appearances. m. Jonathan O'Boyle has misrepresented his residence as part of his filings with the Court and/or the Bar. 5. Immediately after Defendant filed "the Motice, Plaintiff, Martin O'Boyle (hereinafter "O'BoyWD and his counsel, William Ring requested a meeting with Joanne K O'Connor, John C. Randolph and Sidney Stubbs of the Jones Foster law firm. 6. On June 4, 2014, O'Boyle, William Ring, Joanne O'Connor, and John Randolph met in the offices of Jones Foster. Mr. Stubbs was not in attendance. 7. O'Boyle indicated-the meeting should be confidential in nature as it was called for the. purpose of arriving at a settlement However, Plaintiff than proceeded to issue implicit threats, stating that as a result of the Motion, which was directed at O Boyle's son's law firm, O'Boyle intended to take steps against opposing counsel and their children. O'Boyle also made an implicit threat of physical violence stating, "You know I've never been a violent person. These hands have never touched anyone." O'Boyle inquired regarding opposing counsel, Joanne O'Connor's, marital status and threatened to hire investigators to "watch counsel's daughter to see if she slips up." 8. O'Boyle farther stated that he was going to open sober houses throughout the Town of Gulf Stream, 9. These statements were made far the purpose of intimidating counsel, including undersigned counsel. The above conduct has caused undersigned counsel's co- counsel to become witnesses with regard to these events and this motion, 3 LAW OF, ica o ?SW=APgA, aRGE t k VARBAS. P,L 20 8.13.3'° Sraa6r, BOLA R M4,FLOWDA 33432 -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