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Home My Public Portal AboutPRR 14-1312RECEIVED 08/08/2014 14:27 5613946102 08/0812014 14:48 Commerce Group RECORDS REQUEST (the "Request') Date of Request: 8/8/2014 Requestor's Request M#: 128 1312 SSV OW)OR3500807 P.0021003 REQUESTEE: Custodian of Records - Sweetapple, Broeker, Varkas, P.L REQUESTOR: dine Highway, LLC REQUESTOWS CONTACT INFORMATION: E -Mail: reoords@commcree- group.com Fax: 954.360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: In numbered paragraph 16 of the Defendanfa Motion For Sanctions Against .._... .., ..._. _.. - -_J._, ....... ......... ......... .,, . nc v wy,c w" rnu,, r.w., Jonathan 07sir] And William Ring. _Esquire, Attompy Swel f Role 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 SWee%pple) is unethical. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND 1S 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. T IS REQUESTED THAT THIS RECORDS REOUEST BE FULFILLED IN ELECTRONI FORM. IF NOT AVAILABLE IN ELECTRONIC FORM IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 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) (21 ALL ELECTRONIC COPIES ARE REQUESTED TO BE 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 cosh, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any touts imposed to the Requestor by the Agency. 00.2113 FORM RECEIVED 08/0B/2814 14:27 5613946102 SBV 0810812014 14:48 Commerce Group (FAX)9543600607 P.0031003 Martin E. O'Boyle V. Town of Gulfstream CASE N0.502014CA004474XXXXKBAC (PALM BEACH COUNTY) undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the O'Boyle Law Firm is a bona fide Interstate Law Firm, 15. The issue of whether the O'Boyle Law Firm 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 are designed to i terf i t h 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 free 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 of Justice. 18, It is well settled that the trial corm 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 cormsci, their client and families. 19. While O'Boyle has the right to continue to make a spectacle ofhimsclf, he, 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 a novelty for O'Boyle, who has left a historic trail of abusive litigation. 5 LAw Otrcrs orSwaarnpper, BROSIoa & VARYAS, P.L. 20 S.E. 3"STREST, BCcA RATON. PLMDA 33432-3911 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