HomeMy Public PortalAboutPRR 14-1298RECEIVED 08/00/2014 13:55 5613946102 SBV
1298
0810812014 14:17 Commerce Group 00543600807 P.0021003
RECORDS REQUEST (the "Request'?
Date of Request: 8/8/2014
Requester's Request ID#: 117
REQUESTEE: Custodian of Records - Sweetapple, Breeker, Varkas, P.L.
REQUESTOR: Asset Enhancement, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: mconjs@oommoroe-group.com
Fax: 954 -360 -0807; Address; 1280 West Newport Center Drive, Deerfield Beach, FL 33442
1.,11911
Provide all Public Records confirming the statement made by Attorney Sweetapple
in numbered paragraph 8 of the Defendant's Motion For Sanctions Against Plaintiff,
Martin oy e, ounsa o eco a oy e w rm, . ., onat an O'Boyle
ted-by Actor
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 NUDE
PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA
CONSTITUTION.
IT IS REQUESTED THAT THIS RECORDS REQUEST BE ZnOLLED.IN ELECTRONIC
FORM. IF NOT AVAILABLE IN ELECTRONIC FORM IT IS gEOUE TED THAT THIS
RECORDS REOUEST BE FULFH.LED ON II X 17 PAPER. NOTE: IN ALL CASES (UNLEa5
IMPOSSIBLE) THE COPIES SHOULD B TWO SIDED AND SHOULD .H . BILLED IN
ACCORDANCE WITH Section 119,07(4) (a) (2)
ALL ELECTRONIC COPIES ARE REOUESTED TO BE SENT 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 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.
1:FMPRIFRR
04.22.13 FORM
RECEIVED 08/013/2014 13:55 5613946102 SEV
08/08/2014 14:18 Commerce Group TAR}9543600807 P.003l003
Mnrtln E. O'Boyle V. Town of Gulfstream
CASE N0.502014CA004474XXXXMBAC (PALM BEACH COUNM
1. 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 least four (4) pro hac 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 Sled "the Motion", plaintiff Martin O'Boyle (hereinafter
"O'Boyle') and his counsel, William Ring, requested a meeting with Joanne M. O'Connor, John C.
Randolph and Sidney Stubbs of the Jones Faster 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 seltiemenL However, plaintiff then proceeded to issue implicit threats, stating that as a
result of the Motion, which was directed at O'Boyle's son's law fum, 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."
g. O'Boyle further stated that he was going to open sober houses throughout the Town of Gulf
Stream.
9. These statements were made for 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 oFFm oasweerArna, BROURR & VARY-As,
20 S.E.3w Srnesr, BOCARATON. FLDRIDA 334 911
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