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Home My Public Portal AboutPRR 14-1302RECEIVED 00/08/2014 14:11 5613946102 SBV 0810812014 14:33 Commerce Group ffAXAS43600807 RECORDS REQUEST (the "Request j Date of Request. 81812014 Requestor's Request ID#: 105 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTER: Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: recotds@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 relied upon to make the 4b., 4c., 4d„ 4f., 49., 4h., 41., 4J., 4k, 41. and 4m.) of the Delendanea Motion For Sanctions Against Plalntlf, Martin E O'Soyla, Ccueeel of Record, The O'Boyle Lew Firm, P.C„ Jonathan 0119101 And WHIjam w w wa i pp a. ph 4e, of the referenced Motion Is attached. ADDITIONAL INFORMATION REGARDING REQUEST: 1302 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 FULFILLED IN ELECTRONIC FORM. 1F NOT AVAILABLE IN ELECTRONIC FORMM, IT ISIREOUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON II X 17 PAORD NOTE WALL C9SEa rUNLESS IMPOSSIBLE) THE COPIES SHOULD BI MO SIDED AND SHOULD BE BH, ED IN ACCORDANCE WITH Section 119,07f4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BF SENT gY E -MATT, b 7 N rzv PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFML 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. L•PMPPJFRR 64.22.13 FORM P.0021005 RECEIVED 00/00/2014 14:11 5613946102 0810812014 14:34 Commerce Group Filing N 15549445 Eltttnnlcaiky Filed 07/03/1014 01:14:36 PM MARTIN E. O'BOYLE, Plaintiff; V. TOWN OF GULF STREAM, Defendant SBV RU543WC7 P.0031005 IN THE CIRCUIT COURT Op THE 1ST" JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA0044747 XmW DIVISION: AG Defendant, Town Of Gulf Stream, moves this Conn 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, onetltical and abnsivc litigation tactics, and as grounds therefore would show the Court that; 1. On May 30, 2014, Defendant, through Its counsel, SweetappIa, Brooker & Varkas, P.I.,, and Jones, Foster, Johnson & Stubbs, P.A., filed Defendant's Motion to Disqualify the O'Boyle Law Firm, P.C., Inc„ or in the Altemstive, 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 Finn, p,C., Ina, registered as a Florida foreign profit corporation on February 10, 2014, claiming its principal o81cs as 2146 B. Huntingdon Street, Philadelphia, Pennsylvania. 4. Upon information and belief, at the time of registering the O'Boyle Law Firm, F.C., Inc. (hereinafter the "O'Boyle Law Firm'), as a Florida foreign profit corporation, the O'Boyle Law Firm LAW OrraW Of SWWArt A BgOSM & VAA%A4, P.L. 20 8,5, 3" Snsgr BOCARMK FLORIDA 33432 -3911 RECEIVED 08/08/2014 14:11 5613946102 SBV 08/08/2014 14:34 Commerce Group TAMS436M7 P.004/005 Martin B. O'Boyle V. Town of Oult3lream CASE NO, 502014CAOD4474X]O XN(BA0 (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 Firm did not own or lease any commercial space there, 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, d. The O'Boyle Law Finn did not pay city, state or federal taxes because it had no employees. e. The, O'Boyle Law Finn did not obtain an occupational license to conduct business in the City of Philadephia. f. The O'Boyle Law F'irm's sole principal, officer and director, Jonathan O'Boyle, used his Florida cell phone number (561 - 758 - 1223), as the firm telephone number. g, Jonathan O'Boyle is a member of the Pennsylvania Bar, but not ofthe Florida Bar. IL Jonathan O'Boyle 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 Gulf Stream, Florida at 23 N. Hidden Harbour Drive, his parent's home address. j, At the time of the opening of the 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'Boyles, 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 OvemeorS =App,, OR ER &VARKA.%P.L. 70 S.E. 3'° SrAMBOCABATOM FL MpA 33432,3911 RECEIVED 08/09/2014 14:11 5613946102 SBV 08108/2014 14:34 Commerce Group ffMS43600607 V. Town ofGult§neam 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 least four (4) pro hoc vice appestances. m. Jonathan O'Boyle has misrepresented his residence as part of his filings with the Court and/or the Bar, S. Immediately after Defendant filed "the Motion ", Plaintiff, Martin O'Boyle (hereinafter "O'Boyle') and his counsel, William Ring, requested a meeting with JoEmne 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 Ofarriving at a settlement. 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 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 anyenc." O'Boyle inquired regarding opposing counsel, Joanne O'Comor's, marital status and threatened to hire investigators to "Watch counsel's daughter to see if she slips up." 8. 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 OFFICa9 oeSweernppin, BROCA2 & Vnexgs, P.L. 208.8,3° SMa ,ECCAidn'roa,FLORmA3343i -391t P.0051005 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