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HomeMy Public PortalAboutPRR 14-13051305 RECEIVED 136/88/21314 14:16 5613946182 SBV 0810812014 14:37 Commerce Group 00954360W P.0021005 RECORDS REQUEST (the " Requesteh Date of Request: 8/8/2014 Requestor's Request ID#: 112 REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L. REQUESTOR: StopDlrtyGovemment, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: reconis@commerce- group.com Fax 954 - 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all Public Records which set forth the state In which Jonathan O'Boyle had a driver's license in that state on the date that the Defendant's Motion For anctione Against Plainti ,Martin y1a, Counsel of Ring, Esquire was filed. 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 FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONI FO M_- IT IS REOUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED 4ND SHOULD BE BILLED IN ACCORDANCE WITH Section 119,07(4) (a) (2) ALL ELECTRONIC COPIES ARE REOUEMD 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(Deflaitions)), In advance of any costs imposed to the Requestor by the Agency, LPWRIFRR 04.22.13 FORM RECEIVED 08/08/2014 14:16 5613946102 08/0812014 1437 Commerce Group Filing 815549445 ElectrunicaUy Filed 07/03/2014 0 1:14:36 PM MARTIN E. O'BOYLE, Plaintiff, V. TOWN OF GULF STREAM, Defendant. SBV (FA%)9543600807 P.0031005 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA0044743CCKKMB 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 thet: 1. On May 30, 2014, Defendant, through its counsel, Sweetapple, Breaker & Varkas, P.L„ and Jones, Foster, Johnson & Stubbs, P.A., filed Defendant's Motion to Disqualify the O'Boyle Law Film, 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 seeldng other remedies with regard to the matters addressed in the Motion. 3. Significantly, the O'Boyle Law Finn, 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 mud belief; at the time of registering the O'Boyle Law Finn, P.C., Inc, (hereinafter the "O'Boyle Law Firm "), as a Florida foreign profit corporation, the O'Boyle Law Firm LAW 0PYX= OF SWCETAPPLA SIONK:a & VAWAS, P1, 20 S.£. 3"Sratxr, BOCARATOK FLMOA 334125911 RECEIVED 08/08/2014 14:16 5613946102 SBV 0810812014 14:37 Commerce Group (FAX)9543600807 P.0041005 Martin E. O'Boyle v. Town of OulNieam CASE NO.302D14CA0D4474XXXXMEAO (PALM BEACH COt = 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 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. £ The O'Boyle Law Firm's sole principal, offim and director, Jonathan O'Boyle, used his Florida cell phone member (561- 758- 1223), as the fimr 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 Oulf 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'Boyle's, office at WestNeMmrt Center Drive, Deerfield Beech, Florida It is still operated out of this building, which is owned or controlled by Martin O'Boyle. 1ww 0mcs or SwearAnrl.e.Baoeaea & VAaaAa,RL. 20 3.E 3"S7arar. BOCARA 014 FceainA33432 -1911 RECEIVED 08/88/2014 14:16 0810812014 14:37 Commerce Group Martin B. O'Boyle Y. Town of Gulfatnaar 5613946102 SBV 9:AU543800807 P.0051005 1. Since opening the O'Boyle Law Finn, 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 filed "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 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 astute as itwas called for the purpose of arriving 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 anyone." O'Boyle inquired regarding opposing counsel, Joanne O'Conaor's, marital status and threatened to hire investigators to "watch counsel'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 Oulf 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 Orricra orSWaRrnprtr, BEo:JRe& V;,WaU, P.L. 20 S.B.3u Stars[, Barn RmmN FlnRMA33432.3911 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 23, 2014 Stopdirtygovemment, LLC [mail to: records @commerce- group.com] Re: GS #1305 (112) Provide all Public Records which set forth the state in which Jonathan O'Boyle had a driver's license in that state on the date that 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, was filed. Dear Stopdirtygovemment, LLC [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 link: h": / /www2.gulf- stream.org/WebLinkB /0 /doc/20098 /Pagel . asox. Be advised that no such records exist. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records