HomeMy Public PortalAboutPRR 14-13001300
RECEIVED 08/08/2014 14:11 5613946102 SBV
0810812014 14:32 Commerce Group ffAR)IS43 OM7 P.0021005
RECORDS REQUEST (the "Request'
Date of Request 8/8/2014
Requester's Request I)q: 1110
REQUESTEE: Custodian of Records - Sweetapple, Broeker, Varkas, P.L.
REQUESTOR: Asset Enhancement, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce•group.eom
Fax: 954 - 360.0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
Provide all Public Records pursuant to Which homey sweetapple MET upon me a e
statements that he made in numbered subparagraph 41 (excluding subparagraphs 4 4a , 4b., 4e.,
4d., 4s., 4f., 40., 4h., 41., 4k., 41, and 4m.) of the Defendant's Motion For Sanctions Against Plaintiff,
McMn E. O'Boyle, Counsel of Record, The O'Boyle Law Flrm, P.C., Jonathan O' Celt] And William
_Rine. Eaquirs. which wm, M d by Attorney ••set pole A cony of suldlaragroph 41 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 RECORDS REQUEST BE F li E r ED IN ELECTRONIC
FORM. IF NOT AVAILABLE IN ELECTRONIC FORM_ IT IS REO 1E TED THAT T_ER
RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER NOTE, ALL CASE (UNLESS
IM_POSSIRLEI THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN
ACCORDANCE WITH Section 119.07(4) (a) (2)
ALL ELECTRONIC COPIES ARE REQUESTEp TO BE SENT BY MAH, j) r IVEgy
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 costa, 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.
ITINPRIFRR
04.22.13 FORM
RECEIVED 08/08/2014 14:11 5613946102
OBIOBM14 1432 Commerce Group
Filing B 15549445 ElmtMniMlly Filed 07/0312014 01:14:36 PM
MARTIN E. O'BOYLE,
Plairdin;
V.
TOWN OF GULF STREAM,
Defendant.
SBV
NXX430007 P.0031005
IN THE CIRCUIT COURT OF THE 15T"
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 502014CA004474)0CKx 1B
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:
I. 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
Firm, 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 Finn'), as it Florida foreign profit corporation, the O'Boyle Law Firm
LAW 0nWS50FSWWrArna, BR0KM & VAXKAa, P.L
2a S.E. 30 STUu, eOCARATOW, FLMDA 334323911
RECEIVED 08/08/2014 14:11 5613946102 S13V
0810812014 1432 Commerce Group TAX95436007 P.0041005
Nerd B. O'Boyle V. Town of Oulfstreaut
CASE NO.502014CA004474XXXnMAO (PALM BEACH COUNT-y)
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 Firm did not own or lease any commercial space there
b. The O'Boyle Law Finn did not have a business telephone line.
e. The O'Boyle Law Firm had no employees and paid no salaries.
d. The O'Boyle Law Firm did not pay city, state or federal taxes because it bad no
employees.
e. The O'Boyle Law Firm did not obtain an occupational license to conduct business
in the City ofPhiledephis.
f The O'Boyle Law Firm's sole principal, offioar and director, Jonathan O'Boyle,
used his Florida cell phone number (561- 758- 1223), as the firm telephone number,
g. Jonathan O'BoyIe is a member of the Pennsylvania Bar, but not of the Florida Bar.
b. Jonathan O'Boyle advised the Pennsylvania Bar that he is an out -of -state attorney
with an address in Florida.
1. Jonathan O'Boyle advised the Pennsylvania Bar that his address is in the Town of
Gulf Stream, Florida at 23 N. Hidden Harbour Drive, his parent's home address.
j. At the time of the opening of tilt O'Boyle Law Firm in Florida, Jonathan O'Boyle
resided and was domiciled in Florida.
k. When the O'BoyIe Law Firm opened in Florida, it was operated out of his father,
Marlin O'Boyle's, office at West Newport Center Drive, Deerfield Beach, Florida.
It is still operated out of this building, which is owned or controlled by Martin
O'Boyle,
2
LAW QMCa4 CPSWMAPXN 89Q is&VM AB p,L.
20S.B. 30 rinser, BOCAAATON. FWX=33432.3911
RECEIVED 08/08/2014 14:11 5613946102 SBV
0810812014 14:33 Commerce Group ffA1g9543t100807 P.005/005
Mardn E. O'Boyle v. Town of Gulf ream
CASE N0.592014CA004414XXXXMBAG (PALM BEACH COUNTY)
I. 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 hoc 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 Motion", Plairltifi; 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 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, Plaiudff then proceeded to issue implicit threats, stating that as a
result of the Motion, which was directed at O'Boyle's son,a 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
agyonm" O'Boyle inquired regarding opposing counsel, Joe= O'Connor's, marital at" and
threatened to hire investigators to "watch counael's daughter to see if she slips up."
S. O'Boyle further stated that he was going to open sober houses throughout the Town of Gulf
Stream,
% These statements were made for the purpose of intimidating counsel, including undersigned
counsel. The above conduct has caused undersigned counsel's co- couaeel to become witnesses with
regard to these events and this motion.
LAW OPPICn9 cPSWiSrAerrS Baoessa & Vmmm, P.L.
209.8, 3'm"STM, Boon iG70N,FUmmA33432d91I
PA Attorney Information I Pennsylvania Disciplinary Board
Page 1 of 1
The Disciplinary Board
of the Supreme Court of Pennsylvania
PA Attorney Information
Jonathan Reilly O'Boyle
PA Attorney ID:
314500
Current Status:
Active
Date of Admission:
11/13/2012
Lawfrm:
Other Organization:
District:
O
County:
5 ul f State
Public Access
Address:
23N HIDDEN HARBOUR DR
GULFSTREAM, FL 33483
Tel:
1 758 -1223
Fax:
Professional Liability
Insurance:
I do not maintain Professional Liability Insurance pursuant to the provisions of Rule of
Professional Conduct 1.4(C), but I do have private clients and/or a possible exposure to
malpractice actions.
Comment:
Discipline:
02007.2014 The Obdplimry aaartl d" Supnma Caul d Pave nla.l pi.Clalme r
Fm questlom ar ammentu r ardW the websile, please coded w at web.suwo dts a oum.ua
http : / /www.padisciplinaryboard.org /look- up /pa- attomey - info.php ?id = 314500 &pdcount =0 4/4/2014
" �� I N T A B C I R C U I T C O U R T O F T H E 1 5 ' J U D I C I A L . c a c u r r , W A N D
F O R P A L M R E A M , C O U N T Y , n O R I D A
" r '
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W I I S I A M B . T f f i t A S H & R
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V E R I F L B D M O T I O N F O R A D A U S S J O N T O A F P T A R A R O f f A C P T C B
M S U A N T T O F L O R I D A R D L E O F J U D I C I A L A D M I N I S T R A T I O N 2 5 1 0
C o m e s n o W J O N A T A A N R . O ' B O Y L & M o v a m t h e r e i o , a n d r e s p e e t t b i i y r e p m e n t s
t h e f o l l o w i n g :
1 . M o v a n t l o m a t h a a l L O ' B o y l e i s d o m i c i l e d a n d p e r m e a m t l y r e s i d m i a L O N O F O R T ,
N E W J E R S E Y . M o v e n t i s n o t i t p c o n a u e n t r e s i d e o t o f t h e S t a t e o f F l o r i d a .
M o v a a t 7 o m a t b m R O ' B o y l e 3 s a t e m p o r a r y r e s i d e n t o f m o S t a t e o f F l m i d a a n d h s s a n
a p p l i c a t i o n p m d i n g f o r a d m i s s i o n t o n o F l o r i d a 1 3 m � s a d b a s n o t R r e v i o u s l y h e m d m i e d
a d m i s s i o n t o 1 h e F l o r i d a B a r .
2 . M o v a n t i s a n n u o m e y a n d a t i e m b e r o f t h e h a w f i r a a f ( o r p r a o d e e s l a w o r d e r t h e
m m n e o i ) I l e O ' B o v l e T A W F i r m ' P . C . ( F o r a t e A v i m m y n a s J o n a t h a n R O ' B o ��L e F C ) w i t h
o f d a a e t 2 1 4 6 B . A m t i m e d c n S t P b i t a d e l p M
M a d c l a l a P e u n s v i v a n i a 9 1 M 5 6 1 - 7 5 8 - 1 2 2 3
( C o u n t y ) ( S t a t e ) ( Z i p ' C o d e ) ( ' T e l e p h o n e )
3 . M o v a n t h a s b e m r e t a i n e d p e r s o v a l i y o r a s a m e m b e r o f t h e a b o v o n e r n e d l a w f l a n o n
J a n u a r y 1 0 , 2 0 1 4 b y C h r i s t o p h e r O ' B a r e y i a h i s F L a t t o m e v L o u R o e d e r
( D a t e R e p t r s e n t a t i o r t C o m m c a c e d ) ( N a m e o f P t t y o r P a r t i a v )
t o p r o v i d e l e g a l r e p r e s e n t a t i o n i a a o r m c c t i o n w i t h t h e a b o v o " s t A e d m s t t e r n o w p e a d m g b o � o r e
t h e a b o v y n e m o d c o u r t o f t h e S t a t e o f F l o r i d a .
4 . M o v a n t i s a a a c d v e m e m b w i n g o o d s t a n d i n g s a d c t t y e l i g r b L e t o p r a e t i m l a w i n
E M
.� tbetbllowingjurisdictioa( s): Iaetudo stftmoycrberm®bor(s)_(Aftwh on additionalsheetif
necessary.)
i JUBISDICTION ATfORNVMB aNONMER
�• �'"6pgT��n� 3W�Sba
5, There an, no discipIl aryproceedings pending against Havant, acept as provided
below (give judadictioa of disciplinary action, date ofdisciplinnyaclioa, mmm of thevdolatim
and the sanction ifany, imposed):
(AttarXen additional sheatlfnecessary.)
6. Vy f3ia thep=Rvo (S) yea®, Movaathas notb=mbjttt tc my disciplinary
pmecuUnba, exceptasprovWAbelaw (givo jntisdiclion of discip)inary action, aate of
dish inary action, nenae ofthe violation mdthtsanetion, ifaoy, imposed):
(Atterh m edditioae! shcctifnecessary.)
7. MovmAhas nevecbeea mbjectto anysuspemimpro=d'hW, ampteapmvided
below (give judsdlction. oftlisedplinary action, deft of diselplinaryaetion, naboe ofthaviolation
and the sancdoq,ifany, imposed):
(Attach m additional sheet if necessary.)
8. Movnntha owKbwasubjwttnanydislk m tpmceedings,o=ptaspmvided
below (givnjnrisdidion.of disciplinary sotian, date ddisciplinary scion, namm oftheviolutlon
and the sanction, ifdny, imposed):
(Attack an addifiannlsbeet aecassary.)
9. Mavaat, citbcr byresigoaHon, withdraws], or odmrwise, naverhss tenoinated or
attempted to temrinate Movant's office as an atfameyin order• to avoid administrative,
disciplinary, disbarment, a umpeosionproceedings.
10. Havant is aotanimcpva mombaoETLe FlaridaBar.
11. MovantianntnawamemberafThe FloridaBa..
12. Havant is not a suspended member o£The FluridaBur.
13. Movantis not a Obsrrd member nfTbc Florida 11r= bas Movantteeoiveda
ftciplinaryresigaadoa £ram The Florida Bar.
14. Movantlm notprevlouslybeen4isciplined orhddin mntemptbymmaof
mismndnctmmmlitedwhri1e mgagedin representatioaputnommt to Florida Rule of Judicial
Administration 2510, except as pmvidedbdow (give date ofdisciptimny action m contempt,
reasaasd=Dfm; sadmmtimposingmntcmpt):
(Attach an additional ahect ifnecessary.)
. 15. Moventhas Aed= Vm( s) tnappaazaseovoscli nFloridastatecomiv daringthe
post five (5) years in $e follawingmetteam (Attach an eddiEcralsheetifnecessM.)
DateofMot asa m
ion C Nae CastNumher Court Dab:Mation Granted/Denied
N114
16. local cannse[ ofmcorrl associatedwi0rMovmrtimfhismattaris
Rye e -1a,�. a� o�o7s63 who is ga acaveromberin good standing oflboFlorida
(Nave and Plodda Hu Nvofic) y
Barantdlusafficesat (I�ic �},� • 1�Wg-.C\ Cfe kk 17(`:JC
ACYSC4.4.�d C�par�. tsr�aenda�,) FL 'S3�1y2.
(CRY) 0.5>d 51u -ERRS Vibe) Op Cede)
(rdepm=W1ma=eode)
(Iflocal comsel is not in activsmamber of ThoFlodda Berio gondsnmding plmopmvide
inEamedoa as to local counsel's membership status 1
17. Movanthas read the applieablepmvisions ofPlorids. Rule of judicial Adminishnfion
2.510 and Me 1 -3.10 nf8te Rules. RegulafingThePlocida Bar and catl£es thattida vedfxd
motion complies withthmamles.
I8. Movent agces to camplywith theprgvisions of Hue Florida Rules ofProiessimal
Conduct end consents to tho jmisdiefim of the couria end theBaroMoState of Flarido.
WBERBFORH, Movmtrrspectfaymgncats permission to appear in this amid forthis
cause only.
pATRD this day of_J fA W 20JLL.
Movaot
d
/11+0 n nuil"JIVUL)UN S> Page 1 oft
%W
211146 E HUNTINGDON ST ACCOUNT #
314138000
Assessment Tax LOOP
Account Information
OWNER($)
O'BOYLE KELLY L
MAILING ADDRESS
2146 E HUNTINGDON ST
Philadelphia PA
191251427
PROPERTY UNIT
None
PROPERTYZIP
191251427
SALE DATE
8/1812009
SALE PRICE
$193,500
HOMESTEAD
$30,000
Property Characteristics
LAND AREA
1,260 SgFt
1MPROVEMENT.AREA
1,548 SgFt
IMPROVEMENT DESCRIPTION
httn: / /nrnnertv.nhiln onv/ > ^ „1 „' —•
/140 r;' rIu 1w4um.0N Ni
ROW 2 STY MASONRY
BEGINNING POINT
200'E OF COLLINS ST
EXTERIOR CONDITION
New / Rehabbed
ZONING
RSA5 Residential /Residential Mixed -Use
Page 2 of 2
Certified Valuation History
ASSESSED
ASSESSED
ASSESSED.
ASSESSED
MARKET
LAND
IMPROVEMENT
LAND
IMPROVEMENT
TOTAL
YEAR
VALUE
(TAXABLE)
(TAXABLE)
(EXEMPT)
(EXEMPT)
ASSESSMENT
2015
$138,400
$18,648
$119,752
$0
$0
$138,400
2014
$138,400
$18,648
$119,752
$0
$0
$138,400
2013
$27,800
$2,159
$6,737
$0
$0
$8,896
2012
$27,800
$2,159
$6,737
$0
$0
$8,896
2011
$27,600
$2,159
$6,737
$0
$0
$8,896
2010
$27,800
$2;159
$6,737
0
$0
$8,896
2009
$27,800
$2,159
$6,737
$0
$0
$8,896
Nate: The Department of Revenue is responsible for collecting real estate taxes. Please visit the
Department of Revenue. Website (http: / /www.phila.gov /ievenue) for information regarding the billing,
collecting and accounting of real estate taxes or call 215- 686 -6442.
New Search
View Tax Balances
(http: /Iwww.phila.gov/ revenue /RealEstateTaxIDefault.aspx?
bdBRTNo= 314138000)
Submit an Inquiry (http: / /opa.phila.gov /opa.apps /Help /CitizenMain.aspx?
sch= Ctrl2 &s =1 &url= search &id = 4406002146)
httn! / /nrnn&jty nh9B on.+/
n
IN'THE FIFTEENTH JUDICIAL CIRCUIT COURT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 2014- CA- 003938AB «
4ERTiFfEb
C0PY
JASON WEEKS, 'CONDENSED
Petitionex,
vs.
TOWN OF PALL] BEACH,
Respondent.
TRANSCRIPT OF 'TESTIMONY AND PROCEEDINGS HAD
BEFORE THE HONORABLE THOMAS BARKDULL
DATE: APRIL 10, 2014
TIME: 9 :00 - 10:30 A.M.
PLEASANTON, GREENHILL, MEEK & MARSAA
561/833.7811
s
2
4
1 INDEX
1
PROCEEDING S- '
2 TESTIMONY AND PROCEEDINGS
2
THE COURT. Jason Weeks vs. Town of Palm
3 APR0. 10, 2014
3
Beach, Who Is here on behalf ofthe plalmlV
4
6 WITNESSES FOR DEFENDANT
4
MR. MESA: Good morning, Your Honor.
6 DIRECT CROSS REDIRECT
5
GlovaN Mesa on behalf of plaintiff, Jason
7 DANIELLE OLLON
B
Weeks.
8 Sy Ma,Cooper 13 29
7
THECOURT, AndwhodoyouhavowHhyou7
By Mr. Mesa 25
B,
Mr. Weeks?
9
10 SPENCER WILSON
a
MR. O'SOYLE: No, air. My name is Jon
11 13y Ms. Cooper 30
10
O'Boyle. I'm acting as Mn Mesa's law clerk.
By Mr, Mesa 31
11
I'm a Pennsylvania lawyer.
12
13 KATHRYN DYSON
12
THE COURT: Let me ask you a quesgon, Mr.
14 By Ms. Cooper 33
13
O'BoAa. Anyralation to the O'Boyle in the
By Mr. Mess 34
14
O'Boyle Low Firm, P.C.?
15
16
MR. O'80YLE Yes, Your Honor.
16 EXHIBITS
17 IN EVIDENCE
18
THE COURT: What's the relation?
is
17
MR. OBOYLE That Is my name on the law
19 Respondent's Exhibit No. 1 37
18
linn. it's on lnlen;talsiewfirm.
Letter
19
THE COURT: How do you — It's an
2D
20
Interstate law 8rtn with a Florida address?
21 Respondent's Exhibit No. 2 37
Emei s
21
MR.O'BOYLE: There's a Florida address
22
22
and a Pennsylvania address.
23 Petitioners Exhibit No. 1 30
23
THE COURT., And you're down here
E•maps
24
practicing with a fine w1thout being a member
24
25
of the Florida Bar?
25
3
S
1 APPEARING ON BEHALF OF PETITIONER;
1
MR. O'BOYLE: No, sir.
2 Glavonl Mesa, Esq.
2
THE COURT: Are you a member o( the
THE O'BOYLE LAW FIRM, P.C.
3
Florida Bar7
3 1286 West Newport Center Drive
4
MR. O'BOYLE: No, sir.
Ogerfield Beach, Florida 33432
5
THE COURT: Why do you think you have any
4
6 APPEARING ON BEHALF OF RESPONDENT.
0
right to stand at thatiable7
6 Margaret L. Cooper, Esq.
7
MR. O'BOYLEi I don't have any fight other
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
0
than to assist Mr. Mesa.
7 505 South Flagler Orn
9
THE COURT: Good. You step back because
Suite 1100
10
we're about to discuss the Illegal practice of
6 West Palm Beach, Florida 33401
11
Iawwhhout being a member of the Florida Bar.
9
10 ALSO PRESENT: Jonathen O'Boyle, Esq,
12
MR. O'SOYLE Yes, Your Honor.
11 ___
13
THE COURT: Mr. Mesa, are you a member of
12 BE IT REMEMSERED.that the following testimony
14
the Florida Bar?
13 and proceedings were had In the above•antitlod cause
i5
MR, MESA: Yes, I am, Your Honor.
14 before the HanombleThomas Sarkdull, in the Palm
18
THE COURT: How long have you been 'a
15 Beach County Courthouse, City of West Palm Beach,
17
member of the Florida Bar?
is Slate of Florida, on Thursday, the 10th day of
17 April 2014, In Wit
18
MR.MESA: Sinca Novemberof2010.
1B ___
19
THE COURT: Are you a padnerin the,
19
20
quote, O'Boyle Lawl'i m?
20
21
MR. MESA: I am nol, Your Honor.
21
22
THECOURT. How many attorneys are them
22
23
In the O'Boyle Law Finn?
23
24
MR, MESA: Four —five at the moment,
24
25
Your Honor
25
PLEBSANTONr GREENMLLr MESA & XbRSAA
561/833.7811
PLEASANMON, 6REENHILL, MEEK k MAAaAA
561/8.33.7811
6
8
,
I
THE COURT: How many are totaled In the
1
she admitted receiving an e,msll from Kathryn.
2
State of Florida?
2
THE COURT: Okay. So there's one amall
3
MR. MESA: Four, Your Honor.
3
at Issue,
4
THE COURT: Okay. Who are the partners In
4
MR, MESA: Thatwam aware of, Your
5
the Florida Gan?
6
Honor.
6
MR. MESA; Brian Wilmer and Jon O'Boyle,
6
THE COURT. And what date Is the dale of
7
THE COURT: This gentleman Is a partner in
7
that alleged email?
B
the Florida firm?
8
MR.MESAt It's MaySth.
9
MR. MESA: It's s mullf -state firm, Your
9
THECOURT: Ofwhatyear7
10
Honor. To be quite frank with you, I'm not
10
MR. MESA: 2011, Your Honor.
11
sure how Its Incorporated but l know that
11
THECOURT: May5th,2011.
12
Edon Wilmer is a partner In the firm and he Is
12
Ms. Cooper, what Is your clients position
13
a Fladda allomay,
13
on this?
14
THE COURT: Who's here for the defense?
14
MS. COOPER: Your Honor, there is no
15
MS. COOPER: I am, Your Honor, Margaret
16
emaill. Let me explain. And lheywere advised
18
Cooper.
16
that there is no a -mail Mr. Weeks is confused
17
THE COURT: Welcome, Ms. Cooper,
17
and IwOl explain what, happened. Mr. Weeks
to
MS,COOPER: Thankyou.
1e-
glad a complaint with the HR department on
19
THE COURT: All right. Mr. Mesa, you—
19
May 5. Mrs, Olson Is Ilse HR director.
20
whols Ashley A. Richman?
20
THE COURT: Is Mr. Weeks an employee?
21
MS. COOPER: Ashles Richman Is a lawyer In
21
MS. COOPER: He was at the lime. He's.
22
the few rinn of Jones, Foster, Johnston 8
22
been terminated now and ware In other
23
Stubbs,
23
litigation with Mr. Weeks.
24
THE COURT: Iapologize, Igrabbed the
24
THE COURT: Okay.
25
wrong pleading. Let made what was Glad by
26
MS. COOPER: Mrs. Olson who is the HR
7
e
1
the plaintiff here who called my office
1
dlrectorwas al an impasse hearing across the
2
yesterday jumping up and down saying this is an
2
street In another building. Ms. Dyson
3
ameryency.
3
contacted her to advise her that a complaint
4
Mr, Mesa tiled this, Okay. Mr. Mesa,
4
had been Initiated by Mr. Weeks, Later on when ,
5
what do you believe your client needs that your
5
Mrs, Olson was being Interviewed, It was about
6
client is not recelving other than one latter
6
maybe six, eight months later, whatever d was,
7
orange -m2117
7
she knew that there had been an a -mall
a
MR MESA: It's the Initial e-mail that
8
communicalion between she and Mm. Dyson and
9
was made between Kathryn and Danielle who are
9
she made a mistake and she mLlspoke and she
10
both human resources personnel with the Town of
10
cold l 1n11lally pot the Information by e-mail
11
Palm Beach. Your Honor, specifically twos a
11
from Mrs. Dyson. That wee a mistake, It was
12
request that was made by Mr. Weeks foranyand
12
either an Instant —
13
all emalls, (Messages, communications and any
13
THE COURT: Okay. 6o IN the town's
14
documents between Danielle Olson and Kathryn
14
position that, one, It doesn't MW7
15
Dyson, and as staled, both ofwhom are human
15
M5, COOPER It doesn't exist. And I
1S
resource personnel With the Town of Palm Beach
16
apologize, l thoughtyou just wanted to heir
17
on May 6th, 2011.
17
Gram the lawyers today. Mrs, Olson Is an her
18
Your Honor, Mr. Weeks received a portion
IS
way to testify, she'it be here In Ova minutes.
IS
of en e-mail communication, an "ell chain,
19
It Just simply does not exist and we rant
20
that is. However, it it missing thelnlilel
20
produce what's not.
21
e-mail from Kathryn to Danielle. His
21
THECOURT: Okay. Itdoosnlexisfso
22
apparent just on a clear view of the documents
22
have you advised Mr. Mesa of this?
23
that were provided that the Initial amall is
23
MS,.COOPER: Wejustgolthlalawsuit
24
missing. In addition, YourHanon them is a
24
glad, Mr. Weeks was advised but l was atthe
25
mwrdedinlarvlswwlth Donlells Dlsonwhfch
25
2nd OCA arguing a case yesterday and this was
PLEASANMON, 6REENHILL, MEEK k MAAaAA
561/8.33.7811
PL'EABAMOD7, r_m>.MM3:LL, b=K & UTAISAA
561/933,7811
10
12
1
ail happerdnli veryfest 1 was getarg ready!
• 1
you go to law sohool7
2
to—
2
MR. O'BOYLE: Drexal Law UnNereky In
3
THE COURT., That's why l wanted to do It
3
Philadelphia, Pennsylvania,
4
very qulc* because It seems to be a really
4
THE COURT: Are you from Fladda
6
simple Issue. One a -mall, If It exists and
6
originally?
6
Its not privileged, It needs to be fumed
B
MR. O'BOYLE: Yes, Your Hanar.
7
over, If B doesn't exist, 8 d0030 exist,
7
THE COURT: Whereabouts?'
8
and l'B take testimony today and well
B
MR O'BOYLE Gullstmem, Florida
9
determine whether It exists or It doesn't and
9
THE COURT: Okay. Congratulations on
10
this was will be over.
10
passing the Florida Bar, Good luck on getting
11
Mr, O'Boylerheveyou moved to bb admitted
11
admitted.
12
pro hao vlw In Florida at 907
12
All tight. As Boon as ourwhrosas
13
MR, O'BDYI.V: Yes, Your Honor,
13
appear, I'll hearlostlmony. Just advise my
14
THE COUfM. Flow many limes?
14
deputy andwe'p deal with IL Yerygaod.
15
MR. O•BOYLE: Dom Your Honor.
75
(Theroupon, a recos was had.) '
THE COURT: My suggestion is If you think
18
THE COURT; Good morning and welcome,
17
you're going to keep a law firm In Florida and
17
everyone. Welcome back. Okay. We am hem on
Is
walkup to counsel table like you're counsel in
18
the case of Weeks va,Town of Palm Beach on
19
Florida that you take the Florida Bar.
i9
mqueal for an emergency hearing on the Issue
29
MR. O'BOYLE: Yes, Your Honor.
20
of whetherpgbllc.records are available and
21
THECOURT: How long has your firm been
21
whethertheyshouldbe produced. I heardthe
22
operating down hem?
22
Initial arguments of counsel. The town's
23
MR. O'BOYLE: Since January, mld January;
23
position, as I understand h, Ms. Cooper, 13
24
Your Honor.
24
that they requested an a -mall that does not
25
THE COURT: Have you signed up for the
25
exist, Is that correct?
11
13
1
Florida Earysl?
1
MS. COOPER That is cored, Your Honor,
2
MR. O'BOYIE Yes, Your Honor, and 1
2
THE COURT. Okay. You may tali your first
3
passed it actually,
3
witness.
4
THECOURT. Congratulations. Whenamyou
4
MS; COOPER; I'll oil Danielle Olson.
5
belogswomin?
5
THECOURT: M*m, ifyou'll Please take
5
MR. O'SOYLE That is to be determined,
6
IhowNnesastand. Please watch yourslep,
7
Your. Honar.
7 THEREUPON,
B
THE COURT: Having Trouble with your
a
DANIELLEOLSON,
9
batk9mund check orwhy amnl you being sworn
9 called an a witness by the Defendent, having been
10
In If you passed the Florida Bar?
10 find duty awom by the Court, In answer to
11
MR, O'SOYLE: Yes, Your Honor, I posed
11 questions pmpoi n lad, was examined and testified as
12
the New Jersey Bar as wall and—
12 follows:
13
THE COURj. Well,we'renolln New Jersey.
1s
THE COURT: Counsel, you may lnqulm.
14
MR, O'BOYLE: Your Honor, correct, but
14
M9,COOPER Thankyou,YourHonor,
15
FlorklalswahingforNewJeney.theV
16
DIRECTEXAMINATION
16
process to be completed until they wiA further
16 BY MS. COOPER
17
process my file.
17
Q Would you state your name, plasse?
18
THE COURE Have you been admitted In any
16
A Danlells Olson,
19
state?
19
C Mrs. Olson, what Is your pos�on with the
20
MR.O'BOYLEr Yes, Your Honor,
20 Town of Palm Baach7
21
Pennsyhgle.
21
A Dlraclorof human resources,
22
THE COURT: When Them you admitted In
22
q And have you been Involved In the search
23
Pennsylvania?
23 h
response to Mr. WeeW public document request
24
MR,O'BOYLE: November 2012, Your Honor.
24 seeking "211a¢ahveen You and Mrs. Dyson —
25
THE COURT. November of 2012. Whom did
25
A Yes. '
PL'EABAMOD7, r_m>.MM3:LL, b=K & UTAISAA
561/933,7811
. lob S. I3f� S-1
Address
Address
Lae .yaIV -U-1�i @`6us3
qty, Statq Zip Code
SW -7<rA 1D?,
Telepboua Number
STATROF
1. :F l.- 44A R, 't .dobaeby sivrar or etium uudrspcmaltYoi
perjury that I em fh* Wvmtin the abowstyled matter, tbatIhavoread the foregoing Motion
and knowthe contents thereof, and the =tcnte are tme ofmy owaknowledge andbelle£
lrfavent
Ihereby crosam to be assodatedas local wtsel ofmcord'mr Olio cavaeputsamtt[o
Florida Role of Judicial Adminiatmtion 2 .510.
DATED tkis' �d dayof TAhaii.ey .20�.
Local Counsel ofRecord
M.M. W. NLgtt� (,eaelee ,-
Address
Address
Case 9 :1,4-t\-80530 -DMM Document 25 Entered on FLSD Docket
a r
UNITED STATES DISTRICT COURT JUN 17 1013
0 a EVEN
SOUTHERN DISTRICT OF FLORIDA e aFOyunrM�E
oisr
Case No, 13.80530- 905/30- MIDDLEBROOKS
MARTIN E. O'BOYLE ! 3- 50�3o
Plaints$
VS.
TOWN OF GULF STREAM
Defeddant.
MOTION TO APPEAR PROXAC WCE. CONSENT TO DESIGNATION
.AND REOUEST TO ELECTRONICALLY RECEIVE NOTICES OF
ELECTRONIC FILINGS
In accordance with Local Rules 4(b) of the Special Rules Governing the Admission and
Practice of Attorneys of the United States District Court for the Southern District of Florida, the
undersigned respectiirlly moves for the admission pro hac vice of Jonathan R. O'Boyle of
2146 E. Huntingdon SL, Philadelphia, PA 19125, 561- 758 -1223, for purposes of appearance as co-
counsel on behalf of Martin E. O'Boyle in the above -styled case only, and pursuant to Rule 213 of
the CMSCF Administrative Procedures, and to permit Jonathan R. O'Boyle to receive electronic
filings in this case, and in support hereof states as follows:
1. Jonathan R. O'Boyle is not admitted to practice in the Southern District of
Florida and is a member in good standing of the Pennsylvania Supreme Court (PA
Barli314500).
2. Movant Robert S. Gershman, Esquire, of the law fimt of GER$HMAN &
GERSHMAN, P.A, 2160 W, Atlantic Avenue, 2d Floor, 561 -684 -8898, is a member in good
standing of the The Florida Bar and the United States District Court for the Sormhem District of
Florida, maintains an office in this State for the practice of law, and is authorized to file through
the Court's electronic filing system. V, 2AJ;�•;�
Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 0611712013 Page 2 of S
Movant consents to be designated as a member of the Bar of this Court with whom the Court and
opposing counsel may readily communicate regarding the conduct ofthe ease; upon whom filings
shall be served, who shall be required to electronically file all documents and things that maybe
filed electronically, and who shall be responsible for filing documents in compliance with
the CM/ECF AdministmtiveProcedures, See Section 2B of the CMIECF Administrative
Procedures.
3. In accordance with the local rules of this Court, Jonathan R. O'Boyle has made
payment of this Court's $75 admission fee. A certification in accordance with Rule 4(b) is attached
boreto.
•4. Jonathan R. O'Boyle, by and through designated counsel andpursuant to Section 2B
CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic
Filings to Jonathan R, O'Boyle at email address; Jonathamnboylr@gmail,com.
WHEREFORE, Robert S. Genhman, moves this Court to enter an Order Jonathan R.
O'Boyle, to appear before this Court onbebalf ofMartio E. O'Boyle, for all purposes. relating to the
proceedings in the above -styled matter and directing the Clerk to provide notice of electronic
filings to Jonathan R. O'Boyle.
Date: June 17, 2013
Respectfully submitted,
R art S. G_ �msh)—man
Flo 'da Bar No. 91,7397
Robert@rglawt-maus
GERSIWAN & GERSHMAN, P.A.
2160 W. Atlantic Avenue, 2d Floor
Delray Beach, FL 33445
(561) 684 -8898 (telephone)
(561) 998 -5868 (facsimile)
Attorney for Martin E. O'Boyle
Case 9:13 -cv- 00530 -DMM Document 25 Entered on FLSD Docket. 05 /1712013 Page 3 of S
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 13- 8 0 5 3 0- Civ-M@DLEBROOKS
MARTIN R O'BOYLB
Plaintiff,.
VS.
TOWN OF GULF STREAM
Defendant.
CERTIFICA77ON OF JONATHAN R. O'BOYLE
Jonathan R. O'Boyle, Esquire, pursuant to Rule 4(b) of the Special Rules
Governing the Admission and Practice ofAttomcys, hereby certifies that (1) 1 have studied
the Local Rules of the United States District Court for the Southern District of Florida; and
(2) I am amember in good standing of the Pennsylvania Supremo Court.
M,, reV O'Boyle
rg314500
Case 9:13-cv- 80530 -DMM Document 25 Entered on FLSD Docket 06/17/2013 Page 4 al 5
CERTIFICATE OF SERVICE
. IHEREEY CERTIFY that atrue and correct copy of the foregoing Motion to
Appear Pro Hocc Kee, Consent to Designation and Request to Electronically Receive
Notices ofElectmnic Filings Was served by uploading same to the'Ch4/BCF.
SERVICE LIST
Josnne M. O'Connor
joconnor@jonesfostu:wm
JONES FOSTER JOHNSTON & STUBBS,.P.A.
505 South Flagler Drive Sulto 11 DO
West Palm Beech, FL 33401
561-659.3000 (talcphaue)
561 -650 -5300 (famimlle)
Attorneys for Defenda t
Town ofOulfStmam
Case 9:13 -cv- 80530 -DMM Document 25 Entered on FLSD Docket 06117/2013 Page 5 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No, 13- 80530•CIV- MIDDLEBROOKS
MARTINE. O'BOYLE
Plaintiff,
Vs.
TOWN OF GULF STREAM
Defendant.
ORDER GRANTING MOTION TO
APPEAR PRO HAC VICE, CONSENT TO DESIGNATION AND
REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF
ELECTRONIC FILING
THIS CAUSE having come before the' Court on the Motionto AppearPro Hac Vice
farJonathanR, O' Boyle, CormnftoDesignation, and Reque MEtecttonicalIyRecelveNotices of
Electronic Filing (the "Motion"), pursuant to the Special Rules Governing the Admission
and Practice of Attorneys in the United States District Court for the South District of Florida
and Section 213 of the CMIECF Administrative Procedures. This Court having considered
the motion and all other relevant factors, it is hereby of Florida.
ORDERED OR ADJUDGED that:
The Motion is GRANTED. Jonathan R. O'Boyle, may appear and participate in this
action on behalf of Martin E. O'Boyle, The Clerk shall provide electronic notification of all
electronic filings to Jonathan R. O'Boyle at Jonathmraboyle@gmail.com.
DONE AND ORDERD in Chambers, West Palm Beach, Palm Beach County,
Southem District of Florida, on June , 2013,
DONALD MIDDLEBROOKS
United States District Judge
Copies Annished to:
All Counsel of Record
Case 9:13 -cv- 80530 -DMM Document 27 Entered on FLSD Docket 06/19/2013 Page 1 of 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.13- 80530- CIV- AMDLEBROOKS
MARTIN E. O'BDYLE,
Plaintiff,
Vs.
TOWN OF GULF STREAM,
Defendant.
'i
o
THIS CAUSE comes before the Court upon a Motion to Appear Pro Hac Vice, Consent to
Designation, and Request to Electronically Receive Notice of Electronic Filings (DE 25) ( "Motion "),
filed June 17, 2013. The Court has reviewed the record and is fully advised in the premises.
Pursuant to Local Rule 4(b) of the Special Rules Governing the Admission and Practice of
Attorneys in the United States District Court for the Southern District of Florida, the Motion requests
permission for the limited appearance of Jonathan R. O'Boyle, of 2146 E. Huntington St., Philadelphia,
PA 19125, as co- counsel on behalf of Plaintiff in this matter. The Motion has been properly filed with the
required documentation, and the attorney appears to be in good standing.
Accordingly, it is hereby
ORDERED AND ADJUDGED that the Motion to Appear Pro Hac Vice, Consent to
Designation, and Request to Electronically Receive Notice of Electronic Filings (DE 25) is GRANTED.
Jonathan R. O'Boyle may appear and participate as co- counsel in this action on behalf of Plaintiff. The
Clerk shall provide electronic notification of all electronic filings to Jonathan R. O'Boyle at
ionathanrobovlee mail.com.
DONE AND ORDERED in Chambers at West Palm Beach lorida, this /09 day of June,
2013•
UNITED STATES DISTRICT JUDGE
Copies to: Counsel of Record
E
1.
f
i
l
Y
S
I
,
UNI'1Tc15 STATES DISTRICT COURT F xniE SOUTIIRF,N DISTRICT OF nORMA
wES'T PALM BEACH brVI$ION
CASE NQ; lir13- cv,81053 -41i
C13Tt1S O'HARi
Plajntiff,
Va.
TOWN OF GULF STREAM et, al.
Darimastuts.
MOTTONT7OST A IPPr A'R1,2OjV 'SBYTO ]gs' Ti ANDREQTTiFMTO
LCTRONCA1VRTP,CrTVr NOTT. ORT ()Mr
Te Mr,
in accordance with Local Rules 4(b) of the Special Rules Oovoming the Admiksion and Practice
ol'Attomeysofthe:United States District Court far the Southern District of Florida, theuudcrslgndd
respectfrdly modee'for the admissienproltaevieeof Jonathan R . O'Boyle of2146RIlunfingdon. St,,
Philadelpitla PA 19125, 561- 758 -1223, For purposes ofnppeamrico as oo- cormsol on behalf of Chrls
O'llare In the above - styled case only, and pirrsgant to Rule 213 of the CM/ECF Administrative
Procedures, to permitYou dhau R. Q'Beyloto recotve•elccltonic filings In this.ouse, and hisupport thereof
states as follows:
Jonathan R. O'Boyle is not admitted to praotfoo in the Southern District of Florida and is a
member in good standing of the Pennsylvania Supreme Court (PA Bar# 314500).
Tire undgesigned is a member in good dtonding of the Th &Florida. Bar and the United States
District Coutt for tiro Southern Disirict of Clorida, maintains an office in this State for the practice
of taw, and is authorized to file through the Court's electronic filing system. Movant ponsents to
be designated as a member of the Bar of this Court with.whom the Court acd Opposing counsel
may readily communicate regarding the conduct of the case; upoa whmh filings shall be served,
who shall be required to electronically file all documents and things that may be filed
oleotronically, dnd who shalt be responsible fat filing documents in compliance with the CM/BCF
Administrative procedures. See Section 2B of the CM /5CF Administrative Procedure,
' ;. F JAN 13 2014
, -
3. In accordance with idle, local. rules of this Court, Jonathan R O'Boyle has made paymantof this
Court's 475 admission, foe. Acertification. in secordance tivlih lisle 4(b) is being fired
eantemporaneously wide this Motion. A copy is attached hereto,
4. Jonathan R. O'Boyle, by and through designotbd counsel and pursuant to Section 213 CIYYBCF
Administrative Procedures, hereby rdquesfs the Court to proJide Notice ofTaleotmnio Filing to
Jonathan R. O'Boyle at emoil addmss: fonathanmboylc@gmail.com.
WHEREFORE, Mark J. Hanna moves this Court to an ter an Order p slitting Jonathan R
O'Boyle to appear before (his Court on bob alf of Chris O'Hare fpr all purposes reldting to the pr6'eeadings
In the above -Ayled matter and directing the Clcrk to proyido notice of eleotroblo filings to Jonathan R.
O'Boyle.
30 9101 a Q
I HEREBY CERTIFY that an January 10, 2014,1 filed the foregoing 4ocumeut with the Cleric of
Court via conventional method due to the nalute of the motion. T fbrlher certifyllaat matted tlto Cregoing
documentvla prepaid first cinsi U.S.rnailto the following:
Nochaol R Piper
CWistopherJ. Steamg
JOHNSON, ANSELMQ, MURDOCN, BW=R , PIPER & HOCMYfAN, P.A.
2155 East Suariso Boulevard, Salto 1000
Fart,Lauderdalo, Florlda 33304
Tolophone.: (954) 463 -0100
pipuQjataabg.cam
ateorrts(ajambg.00m
Dated., Juhuary 7, 2014 OMV4&f :DTSON P.A.
4.Q1 South,GVltply Rua,
Palm Bga 3 80
Ta1.5 611 -a) 999
i
Flo0a Bar'Np. 0o4525 i
561 -721 -8284 (cell & text)
UNnUD STATES UISTRICT COURT FORME SOUTHERRNDISPRICP OF FLORIDA
WWTPALrdRAACfl DnTnON
CASE NO: 9:13- Y.91053.RLR
wn�
Flalgtifl,
vs.
TORN OF GULF STREAK eL aL
Dolbudauts.
Ism.0 Btu Y gP' 1e: YI cat 1:11
Jonadma R O'Boyly Fsgpfro, pursuant ta Rgie 4(61 of Due Special Rules Oovemiugtm
Admlulary end PrscOco OfAtomeys, herolry cetfigeP Chet( )Ilu va studied the LOCeI Rules dithaUuw
States Disttfot Cause for the Southem District ofFlprlda, and (2) Tqm a member ingwd standing of the
pennsylvmlin Supranl a Cwrt
Iroadhgn O'Boyl Beq.
Jonathan R. O'Boyle, P.C.
2146E Huntingdon SL
Phhloddlpldi, PA 19125
161;561 -7$$ -1223
FW215 -553 -3641
Pwnsylvenia BnNm314500
1 HERBBY CERTIFY dint on January 10, 2014, I filed the foregoing dnmtmwtwltih We Clerk of
Carat viauomreritonal method due (q the nature of the motion. I Ruther certify Met mulled the foregaing
documentviapropoid first alms US. mail to the fbllowing
Mlolhdol IL Piper
Cl rlsmplag1. Stoums
JOHNSON, ANMUO, MURDOCK BURKE, PW9S. &HO.CIAQAN, PA.
2455 But SunriseB'wlevord, Suite 1000
Fort wderdala, Florida 33304
TPlapboaw(954) 463 -0100
piper(rr mnbg.com
slenms&ambg.wm
Dialed: January 1, 2014 ONSWAUMON P.A.
401 South Cwnry Road #3272
Pohn Boacb FL334S0.9991
TC1:561.22i -9990
Me* J. Mesa
Vmlda73uNo. 0045251
561. 7,23 -5234 (call #t text)
mhmmaQg3mlM'wm
w
UNMI) STATES DISTRICT COURTFOR TLTE SOUTMR -N DISTRICT OF FLORIDA
WRST PALM BLACII DIVISION
CASE NO.9x13- ev- S105A -T<LR
,Nat767�7i:i:SiTr
Plaintiff,
VS.
l OWN OF GUM? STREAM et al.
Defendaat4.
THIS CAUSE having conic before ibb Court on.the Motion to Appear Nn Mm Vice for Jonathan
R, O'Boyle; Consent to Designation, and Request to Eleetrohically Receive Notices of Elcolmnic Filing
(the "Motion "), pursuant to tho Special Rules Caeveming vre Admission and Prowled ofAttomays in vie
United States District Cohltfor the Southern Dist lot ofPloridaand Section 2 B ofthe CMIECF
Administrative Procedures. This Court having considered the motion and all other relevantf4etors,itis
hereby ofFlorlda
ORDERED OR ADJUDGED that
The Motion is GRANTED. Ionnthan IL O'Boyle, may appear and participate is this nation on
behalf ofChrlsO' Hare. The Clark sh" provldoelectmnicnotificadot rof all electronic filings to
Jonathan R. O'Boyle at jbmthanmboylc@gmall,com.
DONE AND ORDEREp is Cbambers, WestMan Beach, Palm Beach County, Soulhem District
of Florida, on January 2014,
KENNM'H L. RYSI <AMP
United States District Judge
Copies famished to:
All Counssl of Reoord
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TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
November 1, 2014
Asset Enhancement, Inc. [mail to: records @commerce- group.com]
Re: GS #1300 (110)
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4j. (excluding subparagraphs 4, 4a., 4b.,
4c.,4d., 4e., 4f., 4g., 4h.,4i., 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 Sweetapple. A copy ofsubparagraph 4j.
of the referenced Motion is attached.
Dear Asset Enhancement, Inc. [mail to: records(a)commerce- eroun.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 link: hqp://www2.gulf-
stream.org/WebLink8/0/doc/20093/Pagel.aspx.
You can find the responsive documents at the same link.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records