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Home My Public Portal AboutPRR 14-1306RECEIVED 08/88/2014 14:16 5613946182 SgV 1306 0810812014 14:37 Commerce Group IFAX)9rA360W P.002/005 RECORDS REQUEST (the "Request") Date of Request: 8/8/2014 Requestar's Request ID#: 113 REQUESTEE: Custodian of Records - Sweetapple, Breaker, Varkas, P.L. REQUESTOR. StopDirtyGovernment, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: m=rds@commerce- gmup.com Fax: 954 - 360.0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: In subparagraph 41., please provide all Public Records which confirm the statement of Attorney Sweetapple In his Defendant's Motion For Sanetione Against Piafntlff, Martin E. Mwn , . i of a Th rna yl i r P r r lb n� &nd William Ring, Esquire that Jonathan O'Boyle had a "constant presence' in the State of Florida since the opening of the O'Boyle Law Firm and that during that Constant prosenco, he was his fadI90 ARGI his least four (4) pro hoc vice appearances. 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 RLFCrR0Dj1C FORM. IF NOT AVAILABLE IN ELECTRONIC FORM IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 111{ 17 PAPER, NOTE IN ALL CASES (UNLESS IMPOSSIBLE) THE C )PIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY &MAIL DE IVEAv 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 (Definitions)), in advance of any costs Imposed to the Requestor by the Agency. CP/NPR/FRR 04.22.13 FORM RECEIVED 0B/08/2014 14:16 5613946102 08108/2014 14:37 Commerce Group FiBny N /5549445 Elachvnieally Filed 0710312014 01:14 :36 FM MARTIN E. O'BOYLE, Plaintiff, V. TOWN OF GULF STREAM, Defendant SBV ffWg8547 P.0031005 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502014CA0044700Jt7tmB 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, Sweetappie, Broel= & Varkas, F.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 oa February 10, 2014, claiming its principal office as 2146 E, Huntingdon Street, Philadelphia, Pennsylvania. 4, Upan information and belief, at the time of registering the O'Boyle Law Firm, P.C., Inc, (hereinafter the "O'Boyle Law Firm'), as a Florida foreign profit corporation, the O'Boyle Law Firm LAW OrFKM or SwearAnrce, PROM= k VAWCA9, Pi 20 S-F- 30 Sneer, npCA RATON, FLORIDA 334723911 RECEIVED 08/08/2014 14:16 5613946102 SBV 08/0812014 14:38 Commerce Group (FArAS43800807 P.0041005 Martin E. O'Boyle v. Town oroulf stream Wears to have had no real business presence in Philadelphia, Pennsylvania. Although it was registered as It Pennsylvania Corporation an November 14, 2013, it further appears that: L The O'Boyle Law Firm did not own or lease any commercial space there. b. The O'Boyle Law Flan 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 bad no employees. e. The O'Boyle Law Firm did not obtain an occupational license to conduct business in the City of Pltiladepbia, f. The O'Boyle Law Firm's sole principal, officer and director, Jonathon O'Boyle, used his Florida all phone number (561 -758- 1223), as the firm telephone number, g. Jonathan O'Boyle Is a mettlber of the Pennsylvania Bar, but not oftha Florida Bar. h. 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. Atthetime of the opening of the O'BOY18 Law Firm in Florida, Jonathan O,Boyle resided and was domiciled in Florida. k. When the O'Boyle Law Firth opened in Florida, it was operated out of his father, Martin O'Boyle "% 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, LAW ORIX73 or SwearA"L413aoacea & VAmus, P.L. 205.8.3"Srars, BOLA lATCH.F'gatnA33432.3911 RECEIVED 08/08/2014 14:16 5613946102 SBV 0810812014 14:38 Commerce Group (FAX)9543600807 P.0051005 Martin E. O'Boyle V. Town of Oullerream CASE NO.502014CAGN474XXXXMBAG (PALM BEACH COUNTY) 1• 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 pert 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 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 tire 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, 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'Conaoes, 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 On'= nPSVTrrAPPLB, BnoLK a & VmuxAS, P1,. 20 S•& 3'D SIMLT, BOCA RATON, FLORMA33432 -3911 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 1, 2014 Stopdirtygovernment, LLC [mail to: records @commerce- group.coml Re: GS #1306 (113) In subparagraph 41., please provide all Public Records which confirm the statement ofAttorney Sweetapple in his 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 that Jonathan O'Boyle had a "constantpresence" in the State of Florida since the opening of the O'Boyle Law Firm and that during that constant presence, he was handling legal matters for his father and his father's businesses, including at least four (4) pro hac vice appearances. Dear Stopdirtygovemment, LLC [mail to: recordsna,commerce- grouo.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: http://www2.aulf- stream. orWWebLink8 /0 /doc/20099/Pagel.asnx. There was a similar request that we have previously sent you the responsive documents for. You can find these responsive documents at the following link: httv://WWW2.gulf- stream.org/WebLinkS/O/doc/17459/Paael.ast)x. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records