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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
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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