The URL can be used to link to this page

Home My Public Portal AboutPRR 14-1299RECEIVED 08/08/2014 14:10 5613946102 SBV 1299 0810812014 1431 Commerce Group ttTAX)95436M7 P.002 1004 RECORDS REQUEST (the "Request ") Date of Request; $/812014 Requestor's Request ID#; 111 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTOR Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mall: records ®commerce- group.com Fax: 954. 360.0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records pursuant to which Attorney Sweetapple railed upon to make the ., 4b., 4c., 4d., 4s., 4f., 49.,4h., 41., 4j., 41. and 4m.) of the Defendanrs Motion For Sanctions Against Plaintiff, Martin E. O'Boyle, Counsel of Record, The O'Boyle Lew Firm, P.C., Jonathan O' laic] Ano iam King, "quire, w c was e y rtrey woo pp a. copy o u parepreph 4k. of the referenced Motion Is attached. 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 ORDC >r0MT RF FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE F IN Etz—C—TRICINIC FORM 1'I' IS REQUESTED THAT THIS RECORDS REOUEST BE FULFILLED ON II X 17 PAPER NOTE. IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119 07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO B et~ nrr nv o MAE, DELIVERY PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will he required that the Requester approve of any costa, asserted by the Agency (as defined in Florida Statute, Chapter 119.01(Deilnitions)), In advance of any costs imposed to the Requestor by the Agency. t:PINPWRR 04,22,13 FORM RECEIVED 08/08/2014 14:10 5613946102 08/0812014 14:31 Commerce Group Filing M 15549445 Eketmnieaay Filed 07/032014 01:14:36 PM MARTIN E. O'BOYLE, Plainely v. TOWN OF GULF STREAM, Defendant. S3V TAMS436=7 P.0031004 IN THE CIRCUIT COURT OF THE 15T11 JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA004474XX xmB DIVISION: AG Defendant, Town Of Gulf Stream, moves this Court for the imposition of sanctions against Plaintiff, Martin E. O'Boyle, Counsel of Record, the O'Boyle Law Firm, P.C., Inc., its President Jonathan O'Boyle, and William Ring, Esquire, for unprofessional, unethical and abusive litigation tactics, and as grounds therefore would show the Court that; 1. On May 30, 2014, Defendant through its counsel, Sweetapple, Broeker & Varkas, P.L., and Jones, Foster, Johnson & Stubbs, P.A., filed Defendant's Motion to Disqualify the O'Boyle Law Finn, P,C, Inc., or in the Alternative, for an Evidentiary Hearing (hereinafter the "Motion'). 2. This Motion has been withdrawn without prejudice as Defendant is seeking other remedies with regard to the matters addressed in the Motion. 3. Significantly, the O'Boyle Law Firm, P.C., inc., registered as a Florida foreign profit corporation on February 10, 2014, claiming its principal office as 2146 E. Huntingdon Street, Philadelphia, Pennsylvania. 4, Upon information and belief, at the time of registering the O'Boyle LAW Firm, P.C., Inc. (hereinafter the "O'Boyle Law Fi m "I as a Florida foreign profit corporation, the O'Boyle Law Firm LAW OFFXUCW SWMrAPnA BK01=& VAPKAP, PI.. 20 S.B. 3'OSrsaar, BwARMUN, FLORIDA 33432.3911 RECEIVED 08/06/2014 14:10 5613946102 SBV 0810612014 14:31 Commerce Group (TAX)9543600807 P.0041004 Martin S. O'Boyle v. Town ofOalfsesem CASE NO. 502014CA004474X) XXMAO (PALM BEACH COUNTY) appears to have had no real business presence in Philadelphia, Pennsylvania. Although it was registered as a Pennsylvania Corporation on November 14, 2013, it further appears that a, The O'Boyle Law Frrm did not own or lease any commercial space them, b. The O'Boyle Law Firm did not have a business telephone line, C. The O'Boyle Law Firm had no employees and paid no salaries, I The O'Boyle Law Firm did not pay city, state or federal taxes because it had no employees. e. The O'Boyle Law Firm did not obtain an occupational license to conduct business in the City of Philadephia. E The O'Boyle Law Firm's sole principal, otHcar and director, Jonathan O'Boyle, used his Florida cell phone number (561 - 758 - 1223), as the firm telephone number. X Jonathan O'Boyle is a member ofthc Pennsylvania Bar, but not of the Florida Bar. h. Jonathan O'BoyIe advised the Pennsylvania Bar that he is an out-of-state, attorney with an address in Florida. i. Jonathan O'Boyle advised the Pennsylvania Bar that his address is in the Town of Ou1PStream, Florida at 23 N. Hidden Harbour Drive, his parent's home address. j. At the time of the opening ofthe O'Boyle Law Firm in Florida, Jonathan O'Boyle resided and was domiciled in Florida k, when the O'Boyle Law Firm opened in Florida, it was operated out of his father, Martin O'Boyle's, ofce at west Nawport Center Drive, Deerfield Beacb, Florida. It is still operated out of this building, which is owned or controlled by Martin O'Boyle, 2 LAW OFFICES or SWWArrta, BWWsx& VARxA4 P.L. 20 S.E.3 STArar, BtxARAMM, Pt.ownA 33432-3911 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