HomeMy Public PortalAboutPRR 14-1311I ,y II
RECEIVED 08/08/2014 14:27 5613946102
08108/2014 14:48 Commerce Group
RECORDS REQUEST (the "Request ")
Data of Request: 8/8/2014
Requestor's Request ID#: 127
REQUESTEE: Custodian of Records - Sweetapple, Broeker,
REQUESTOR: Airline Highway, LLC
SBV
00543M7
P.L.
REQUESTOR'S CONTACT INFORMATION: E -Mail: records ®commerce- gmup.com
Fax: 954.360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
In numbered paragraph 16 of the Defendant's Motion For Sanctions Against
Pjamurr, Martin e, Counsel of ecor , I no UIJOY18 Law Firm, .,
following "Tire 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 Swestapple) Is unprofessional.
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 I$ REQUESTED THAT THIS RECORDS REOUEST BE FULFILLED IN ELECTRON[
FORM. IF NOT AVAILABLE IN ELECTRONIC FORM IT IS REQUESTED THAT THIS
RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER NOTE⢠IN ALL ASES (Untr FSS
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 BE SENT BY E-MATr DE TV FR V.
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 coats Imposed to the Requester by
the Agency.
UINFRIFRR
04.22.13 FORM
P.0021003
RECEIVED 08/08/2014 14:27 5613946102 S13V
0810812014 14:48 Commerce Group 0:A8p64960w P.0031003
Marlin E. O'Boyle Y. Town of GolOmnam
CASE No. 502014CA004474XXXXMBAG (PALM BEACH COV] tM
undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the
O'Boyle Law Finn is a bona fide Interstate Law Firm.
15. The issue of whether the O'Boyle Law Finn is a bona fide Interstate Law Firm is one that
should be resolved according to law. It should not be the subject of harassment, intimidation and air
raids by opposing counsel and their client,
16. The misconduct is unprofessional, unethical and it constitutes an egregious example of
litigation abuse. These tactics go beyond zealous representation and ate designed to interfere with
defense counsels' ethical obligation to their client. Such conduct undermines society's commitment
to the resolution of disputes in courts of law, rather than in the streets or in the sky.
17. While citizens enjoy the constitutional right of flee speech, that protection is afforded to
truthful speech, and while attorneys must zealously represent their client's interests, they are also
officers of the court, and are prohibited from disparaging witnesses and attorneys, or otherwise
undermining the administration cf justice.
18. It is well settled that the trial court has inherent jurisdiction to sanction parties and their
counsel for litigation abuse. In this instance, Plaintiff and his counsel have sought to cease any
litigation or determination of the bona fides of the O'Boyle Law Firm by threatening and instituting
reprisals against counsel, their client and families.
19. While O'Boyle has the right to continue to make a spectacle ofhimself, be, with the assistance
of counsel, cannot impugn, malign and attempt to extort opposing parties or their counsel as part of
the litigation process,
20. Abusive conduct is not anovelty for O'Boyle, who has left a historic trail of abusive litigation.
5
LAw 0mcas 0"W"rAPri$BaeMM& VAa1CA9, P.L.
20 SF. 30 Staoar, accARArnN, PWMA33432.3911
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