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HomeMy Public PortalAboutPRR 14-1347TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 9, 2014 Martin E. O'Boyle - Verbal [mail to: records @commerce - group.com] Re: GS 91346 (Richman & Greer bills), #1347 (Sweetapple Aug Bill), #1348 (Chandler communication), #1349 (Any payment to FL League of Cities), #1350 (Confidentiality Agreement), #1351 (Picture of documents on desk) Copies of any Richman & Greer Law Firm billing Copy ofAugust Sweetapple bill. Any communication to or from anyone with the last name Chandler. Any invoice & payment made to Florida League of Cities in 2014 - copies in 8112 x 11 (1 sided) Copy of signed confidentiality agreement with Sweetapple. Wanted to take a picture of documents on Bill Thrasher's desk. Dear Martin E. O'Boyle - Verbal [mail to: records @commerce - group.com], Thank you for your public records requests that were made verbally on September 5, 2014. This is just confirmation of receipt and production of the above requests as we understood them. GS #1346 — Informed you that we have no such records. GS #1347 — Informed you that I have to have the billing reviewed for possible redactions before I could release them to you. Once that is done, they will be available for you. GS #1348 — Informed you that it would take me some time to gather the responsive documents. You informed me that Doug Stacey would wait for them. I produced a deposit letter requesting $9.81 in order to produce the documents. He paid for the deposit and I gave him a receipt. GS #1349 — Gave you copies of 2 bills and payments for a total of $1.35 for 9 single sided 8 %: x 11 pages which you paid and I gave you a receipt for. GS #1350 — Informed you that we were not aware of such agreement, but would find out if any of our attorneys had knowledge of it and get back to you. GS #1351 — Refused to open Mr. Thrasher's door in order for you to take pictures because he has a private office and he was not there to give permission to allow us in his office. The Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. Sincerely, Town Clerk Rita Taylor From: Brenda Russell < brussell @commerce - group.com> Sent: Friday, September 05, 2014 5:34 PM To: Rita Taylor; Kelly Avery Cc: Kelly Humke; Giovani Mesa; William Ring; Marty O'Boyle Subject: O'Boyle letter regarding Sweetapple Law Firm Billings Attachments: Ms. Taylor and Ms. Avery Sweetapple Billings 09.05.14.pdf Brenda A. Russell Executive Assistant Office of Martin E. O'Boyle Commerce Group, Inc. 1280 West Newport Center Drive Deerfield Beach, FL 33442 Direct Dial #954 -570 -3513 Fax #954- 360 -0807 Main #954- 360 -7713 brussell @commerce- eroup.com COMMERCE GROUP mobovleOcommerce -group. com Direct Dial Telephone #954 -570 -3505 [MEODS506241.DS2] September 5, 2014 VIA E -MAIL: rtavlor(&�eulf- stream.ore TELEPHONE #561- 276 -5116 Rita L. Taylor, Custodian of Records Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 VIA E -MAIL: kaverv(aeulf- stream.ore TELEPHONE #561- 276 -5116 Ms. Kelly Avery Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Re: Sweetapple Law Firm Billings For the Period of August, 2014 Dear Ms. Taylor and Ms. Avery: This morning when I was at the Town Hall (before noon) I requested a copy of the billings as aforesaid. I was refused. I was told that the billings had to be reviewed for redactions and that no one in the Town Hall was capable of doing that, only the attorney. I asked why not get the attorney on the phone to see if there were any redactions necessary and if not to give me the documents; and if so to have the redactions done. Once again, I was denied and refused. I shall now seek counsel. Sincerely yours, CCE GROUP, INC i Martin E. O'Boyle President cc: Kelly E. Humke — E -Mail Giovani Mesa, Esquire —E -Mail William F. Ring, Jr., Esquire — E -Mail P/NPR/FRR- bar www.commerce-group.com TEL. 954.360.7713 . FAx 954.360.0807 1280 WEST NEwrou CerrER Dkm, DEERRELD BEACH, FLORIDA 33442 Sweetapple, Broeker, Varkas, P.L. 20 South East 3rd. Street Boca Raton, FL 33432 Telephone: (561)392-1230 Fax: (561)394-6102 TOWN OF GULF STREA ►PAYMENT APPROVED -4 Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Client Number: Town of Gulf Stream Matter Number: 1679 O'Boyle vs. Town of Gulf Stream For Services Rendered Through 8/2212014. 44 Fees August 22, 2014 Invoice No. 10182 Date Tmkpr Description - Hours Amount 07/26/2014 RS Meeting with regarding and 1.25 $437.50 (Saturday). 07/28/2014 RS Read treatise on and cases. (Sunday). 1.25 $437.50 07/29/2014 RS Work on Conference with opposing counsel. 3.00 $1,050.00 07/30/2014 RS Receive and review motion and emails; Work on 1.60 $560.00 Conference with A. Varkas regarding and 07/30/2014 RS Conference with Joanne; Review all additional PRRs emails; 2.30 $805.00 Conference with Hanna; Meeting with A. Varkas regarding 08/01/2014 AV Take notes. 1.75 $612.50 08/01/2014 JW Research and write memo of law on 8.00 $1,200.00 (Dates 07/22, 07/23, 07/31). 08/04/2014 CB Draft and finalize letter to Smith and Taylor enclosing Notice of 0.20 $0.00 Videotaped Deposition of M. O'Boyle; Draft and finalize Notice of Videotaped Deposition of M. O'Boyle. 08/04/2014 AV Conference reviewing and 2.00 $700.00 making notes. 08/04/2014 RS Review subpoenas and PRR; Conference. 1.25 $437.50 Continued On Next Page Client Number: Matter Number: 1679 08/22/2014 Page: 2 08/04/2014 RS Conference regarding 8.50 $2,975.00 Receive and review emails; Continue dictation of Review over 90 public records requests and articles; Conferences with Joanne; Set deposition and prepare letter. (Date 08/03). 08/042014 RS Continue work on (Evening). 2.00 $700.00 08/052014 CB Update with R. Sweetapple changes. 0.60 $0.00 08/052014 AV Finish reviewing Westlaw search (natural 3.00 $1,050.00 data base): (Read and summarize cases). 08/05/2014 RS Review case 0.60 $210.00 Conference regarding 08/05/2014 RS Receive and review Motion for P.O.; Set hearing; Revise 2.40 $840.00 Review memos provided by O'Boyle law firm regarding 57.105 08/062014 CB Draft and finalize Notice of Hearing on Plaintiff Motion for 0.20 $0.00 Protective Order; Email with opposing counsel; Send hearing package to Judge; Draft and finalize letter to Judge Blanc. 08/062014 RS Conference with Joanne; Conference in Richman office. 0.40 $140.00 08/072014 RS Conference with Joanne; Conference with opposing counsel; 4.00 $1,400.00 Prepare spoliation letters; Outline law; Draft Settlement conference; Receive and review emails. 08/07/2014 CB Draft and finalize spoilation letters; Email with opposing counsel; 1.00 $0.00 Update letter to Letter to Richman; Email the spoilation letters to: Commerce Group, J. O'Boyle, M. O'Boyle, D. Demartini, W. Ring, CAFI, R. Witmer, V. Taylor; Draft Amended Notice of Hearing for 8.12 file. 08/082014 RS Outline issues and dictate memo. 1.50 $525.00 08/082014 CB Prepare hearing folder for M. O'Boyle's Motion for Protective 0.50 $0.00 Order, Emails with opposing counsel. 08/112014 RS Work on 14.00 $4,900.00 Receive and review emails with Taylor; Receive and review emails with Hanna; Conference with Joanne and Scott; Begin review and outline . )Dates 08/09 and 08 /10). 08/12/2014 RS Prepare all and Meeting with Gerry Richman and Joanne 3.50 $1,225.00 O'Connor regarding cases; Conference with Scott Morgan. Continued On Next Page a Client Number: Matter Number: 1679 08122/2014 Page: 3 08/12/2014 RS Conference with Continue outline statement; Motion 2.75 $962.50 with Hanna regarding settlement O'Hare. 08/14/2014 RS Conference with Joanne; Review filing by O'Hare and O'Boyle law 1.00 $350.00 firth. 08/14/2014 RS Conference with Gerry regarding Conference with 0.80 $280.00 Joanne; Conference 08/15/2014 RS Emails to Hanna; Conference in Richman's office; Conference 0.40 $140.00 with Joanne. (Date 08114). 08/18/2014 RS Prepare for hearing (evening); Review multiple emails with Hanna 1.25 $437.50 regarding O'Hare. 08/18/2014 RS Conference with Scott; Travel and attend meetings with Joanne, 3.25 $1,137.50 Scott and Richman; Work on 08/18/2014 RS Conference with Scott and Delray's legal counsels. 0.50 $175.00 08/19/2014 RS Prepare travel and attend hearing; Conference with Joanne and 3.50 $1,225.00 Richman; Meeting with city manager and conference with Scott; Receive and review emails. 08/19/2014 RS Review letter and motion; Prepare letter. 0.50 $175.00 08/202014 RS Receive and review emails from Taylor; Conference. 0.30 $105.00 08202014 RS Prepare Motion and email; Conference with Joanne. 0.60 $210.00 08212014 RS Meeting with Scott; Conference with Joanne; Conference with 2.20 $770.00 witness; Conference with opposing counsel. 08212014 RS Conference with Joanne and Scott. 0.20 $70.00 08212014 RS Review motions; Prepare letter. 0.50 $175.00 Billable Hours / Fees: 82.55 $26,417.50 Cost Detail Date Description Amount Check No. 07232014 Mileage at $0.56 /mile $221.20 07282014 Postage - July 2014 4.80 07282014 Photocopy Charges - July 2014 283.75 08222014 Photocopy Charges - August 2014 343.00 Total Costs $852.75 Continued On Nest Page Client Number: 08/22/2014 Matter Number: 1679 Page: 4 Prior Balance: $17,902.50 Last Payment 07/31/2014 Payments Received: ($17,902.50) Current Fees: $26,417.50 Advanced Costs: $852.75 TOTAL AMOUNT DUE: $27,270.25 cot — 5,—' / to PLEASE REMIT TO: SWEETAPPLE, BROEKER & VARKAS, P.L. 20 S.E. 3rd. STREET. BOCA RATON. FL 33432 PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU! TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 18, 2014 Martin E. O'Boyle - Verbal [Mail to: records @commerce - group.com] Re: GS #1347 (Sweetapple Aug Bill) Copy ofAugust Sweetapple bill. Dear Martin E. O'Boyle - Verbal [Mail to: records @commerce - group.com], This letter provides you with the full production of public records you have requested verbally on dated September 5, 2014 that can be viewed at the following link: htty://www2.eulf- stream .or¢ /WebLink8 /0 /doc /20667/Paeel . asox. As reflected on the attached record, exempt information has been redacted pursuant to Fla. Stat. § 119.071(1)(d). A public record that was prepared by an agency attorney or at the attorney's express direction for imminent or ongoing litigation that relates to counsel's mental impression, conclusion, legal strategy, or legal theory is exempt pursuant to Fla. Stat. § 119.071(1)(d). The exempt information here relates to pending and reasonably anticipated imminent litigation involving the Town, William Thrasher, Garrett Ward, Scott Morgan and Robert Sweetapple, on the one hand, and Martin O'Boyle and entities controlled by or affiliated with him including, but not limited to, Commerce GP, Inc., the Commerce Group, Inc., Asset Enhancement, Inc., CG Acquisition Company, Inc., Citizens Awareness Foundation, Inc., Airline Highway, LLC, N984AC Caravan LLC, and STOPDIRTYGOVERNMENT, LLC., and Christopher O'Hare, on the other hand. We consider this matter closed. Sincerely, Town Clerk Custodian of the Records