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