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HomeMy Public PortalAboutPRR 14-13081308 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