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HomeMy Public PortalAboutPRR 14-13091309 RECEIVED 0B/08/2014 14:25 5613946102 SEV 08/08/2014 14;48 Commerce Group ffAXAM600807 P.0021003 RECORDS REQUEST ('the "Request'l Date of Request: 8/8/2014 Requester's Request ID #: 143 REQUESTEE: Custodian of Records - Sweetappie, Broeker, Varkas, P.L. REQUESTOR: Airline Highway, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: rwor&@commerce- group.com Fax: 954.360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: In numbered paragraph 28 of the Defendarifs Motion For Sanctions Against Plaintiff, Mardn E. O'Boyle, Counsel of ecord, The O'Boyle Law Firm, ., Jonathan sic am Rine Esquire, Attorney Sweatapple says that FMart1n O'Bovlel is oar etuatino unethical and abusive activities ". In that connection, we would ask Attorney Sweetapple to provide all Public Records which demonstrate such unethical and abusive activities 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 REQUESTER PROVIDED IN THE FLORIDA CONSTITUTION. IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC FORM. IF NOT AVAILABLE IN ELECTRONIC FORM. IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON to X 17 PAPER NOTE: IN ALL CAGES (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 REOLES P IQ RE 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 de0ned in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requester by the Agency. LPlNFR/FRR 04.22.13 FORM RECEIVED 08/08/2014 14:25 5613946102 SBV 08/0812014 14:46 Commerce Group ffA>n954M807 p.0031003 Munn E. O'Boyle v. Town of Oulatreem CASE NO.5020I4CA004474XXXXMBAG (PALM BEACH COUNM administration of justice, Including to knowingly ... disparage ... witnesses ... or other lawyers on any basis,., '), Rules Regulating The Florida Bar, When professional judgment does not restrain a Iawyer's zealous advocacy, however, the courts must act to assure that aggressive advocacy does not frustrate or disrupt the administration of judicial proceedings. Seeln Re Terry, 128 U.S. 289, 302, 9 S.Ct. 77, 79, 32 L.Ed. 405 (1888); Sandstrom v. State, 309 So.2d 17 (Fla. 4th ACA 1975), cart. dismissed, 336 So.2d 572 (Fla, 1976); see also Louis S. Raveson, Advocacy and Contempt. Constitwional Limitations on the Judicial Contempt Power, Part one.. The Confliat Between Advocacy and Contempt, 65 Wash.L.Rev. 477, 539 -40 (1990). Carnival Corp a Beverly, 744 So.2d 489 (Fla. 1't DCA 1999) 28. The O'Boyle Law Firm and William Ring have continued to represent O'Boyle in perpetrating these unethical and abusive activities. That conduct should also be sanctioned. WHEREFORE, Defendant prays this Court enter appropriate sanctions for litigatioh abuse against Plaintiff, Martin E. O'Boyle, his Counsel of Record, the O'Boyle Law Finn, F.C„ Inc., Jonathan O'Boyle, President of the O'Boyle Law Finn, and William Ring, Esquire, includingstriking Plaintiff s pleadings, entering an order prohibiting Plaintiff from exploiting his right to litigate in a mamer that impugns and threateas opposing counsel, Defendant also seeks an award of attorneys' fees and costs for bringing the motion. Respectfully submitted, S WEETAPPLE, BROEKER & VARKAS, PL CO-Counsel for Defendants 20 S.E. 3" Street Boca Raton, Florida 33432 Telephone: (561) 392 -1230 E-ma*d-.Pleadinss@sweetapplelaw.com By: col _ ROBERT A. SWEETAPPLE Florida Bar No. 0296988 8 LAW OrrrcMorSWnTAerta. BReaxaa & VARKA%F,L 20 S.E.3" S'raear, 6oGRAYOa, FLWMA33432.3911