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RECEIVED 08/08/2014 14:25 5613946102 S0V
0810812014 14:46 Commerce Grog TM)6436=7 P.0021002
RECORDS REQUEST (the "Request ")
Date of Request: 8/8/2014
Requester's Request R) #: 142
REQUESTEE: Custodian of Records - Sweetappie, Brooker, Varkas, P.L.
REQUESTOR: Airline Highway, LLC
REQUESTOR'S CONTACT INFORMATION: E -Mail: cecordsQcommeme- gmup.com
Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
Provide all Public Records which demonstrate that Attorney Sweatepple alleged that a party
to a lidgefion had committed fraud, when the other party (hie client) confirmed that the other
did not nemmif hand Wh } .N re In k' g re h r� In Iegpl nl d1 g9,wnd rn fl g
relative to the subject matter of the legal pleadings.
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.
AT 1S REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC
FORM IF NOT AVAILABLE IN ELECTRONIC FORM. IT IS REQUESTED THAT THIS
RECQRDS REOUEST BE F n FILL FD ON I I X 17 PAPER NOTE- IN ALL CASES (UNLESS
IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN
ACCORDANCE WITH Section 119,07(4) (a 2
ALL ELECTRONIC COPIES ARE REQUESTED TO BF RENT BY E MA nELIVERY.
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 costs, asserted by the Agency (as defined In
Florida Statute, Chapter 119.01 (Def)nldons)), in advance of any costs imposed to the Requestor by
the Agency.
I:P/NPIVFRR
04.22.13 FORM
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
September 29, 2014
Airline Highway, LLC [mail to: records @commerce- group.com]
Re: GS #1307 (141), #1308 (142), #1311 (127), #1312 (128), #1313 (129), #1314 (101)
In connection with the first indented paragraph under numbered paragraph 27 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, please provide us with all
Public Records which demonstrate that Attorney Sweetapple and/or any of his clients (during
Attorney Sweetapple's representation) were sanctioned or given a rebuke by a judge, a mediator
or an arbitrator.
Provide all Public Records which deomonstrate that Attorney Sweetapple alleged that a parry to
a litigation had committed fraud, when the other party (his client) confirmed that the other did
not commit fraud. What we are looking for here is legal pleadings and communications relative
to the subject matter of the legal pleadings.
In numbered paragraph 16 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, Attorney Sweetapple states the following "The misconduct is unprofessional, unethical
and it constitutes an egregious litigation abuse ". Please provide all Public Records which
demonstrate that the misconduct (as defined by Attorney Sweetapple) is unprofessional.
In numbered paragraph 16 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, Attorney Sweetapple states the following "The misconduct is unprofessional, unethical
and it constitutes an egregious litigation abuse ". Please provide all Public Records which
demonstrate that the misconduct (as defined by Attorney Sweetapple) is unethical.
In numbered paragraph 16 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, Attorney Sweetapple states the following "The misconduct is unprofessional, unethical
and it constitutes an egregious litigation abuse ". Please provide all Public Records which
demonstrate that the misconduct (as defined by Attorney Sweetapple) constitutes an egregious
litigation abuse.
Provide all Public Records pursuant to which Attorney Sweetapple relied upon to make the
statements that he made in numbered subparagraph 4a. (excluding subparagraphs 4, 4b.,
4c.,4d., 4e., 4f., 4g., 4h.,4,4j., 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 Sweetapple. A copy of
subparagraph 4a. of the referenced Motion is attached.
Dear Airline Highway, 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 links: htty://www2.gulf-
stream. ore /WebLink8 /0 /doc /20100/Pagel.asnx, http://www2.gulf-
stream. org/ WebLink8 /0 /doc/20101/Pagel.aslx, http://www2.gulf-
stream. org/ WebLink8 /0 /doc/20104/Pagel.aspx, htto://www2.gulf-
stream.org/WebLink8 /0 /doc /20105/Pagel.asnx, http://www2.gulf-
stream.org/WebLink8 /0 /doc /20106/Pagel.asyx, and http://www2.gulf-
streatn.org/WebLink8/0/doc/20107/Pagel.asi)x.
Be advised that no such records exist.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records