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Home My Public Portal AboutPRR 14-142109:33:J]i.m.09 -19 -3014 i 1 9543E00307 0911712014 09:35 Commerce Group (FAX)9543600807 P.0011002 CG ACQUISITION COMPANY, INC. 1280 West Newport Center Drive Deerfield Beach, FL 33442 Telephone: 954 -360 -7713 Te I eco py: 954-360-0807 TELECOPIER TRANSMITTAL PAGE DATE: 9/17/214 TO: FROM: Custodian of Records Town of Gulf Stream (561) 737 -0188 CG Acquisition Company, Inc. NUMBER OF PAGES INCLUDING TRANSMITTAL PAGE IF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL #954- 360 -7713 _ Original will not follow Original will follow via: _ Regular Mail Overnight Delivery Hand Delivery Other: D9 : 33'. 07 a. M. 09 -17 -3019 ] 9M30=01 0911712014 09:35 Commerce Group RECORDS REQUEST (the "Request ") Date of Request: 9/1612014 Requestor's Request ID #: 831 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: CG Acquisition Company, Inc. O:AX)9543600807 P.0021002 REQUESTOR'S CONTACT INFORMATION: E -Mail: records ®commerce- group.com Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide all communications to or from anyone with the last name Chandler. 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 15 REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED IN ELECTRONIC FORMM IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS CORDS REQUEST BE FULFILLED ON 11 X I7 PAPER. NOTE: 1pi ALL CASES (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 REQUESTED TQBE 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 defined In Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:P/NPR/FRR 04.22.13 FORM TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail October 9, 2014 CG Acquisition Company, Inc. [mail to: records @commerce- group.com) Re: GS #1421 (831) Please provide all communications to orfrom anyone with the last name Chandler. Dear CG Acquisition Company, Inc. [mail to: records @,commerce- groun.comlI The Town of Gulf Stream received your public records request on September 17, 2014. If your request was received in writing, then the request can be found at the following link: httv: / /www2 .gulf- streatn.org/WebLink8 /0 /doc /21014 /Pagel.aspxx. If your request was verbal, then the description of your public records request is set forth in the italics above. In future correspondence, please refer to this public records request by the above referenced number. 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 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail April 13, 2015 CG Acquisition Company, Inc. [mail to: records @commerce- group.com] Re: GS #1421 (831) Please provide all communications to orfrom anyone with the last name Chandler. Dear CG Acquisition Company, Inc. [mail to: recordsna.commerce- eroup.com], The Town of Gulf Stream received your public records requests on September 17, 2014. You should be able to view your original requests at the following link htto://www2.eulf- stream.orgtWebLink8 /0 /doc /21014/Paeel.asox. If your request was verbal, then the description of your public records request is set forth in the italics above. In future correspondence, please refer to this public records request by the above referenced numbers. To the extent that you seek all public records received from, sent to or created by Joel Chandler, a partial production of records are available at a similar records request found at: httv://www2.pulf- stream.ore/WebLink8 /0 /doc /20415/Pa¢el.asox. These documents include: • Communications received from or sent to Mr. Chandler or his counsel Please be advised that a sworn statement of Mr. Chandler taken by counsel for the Town on July 23, 2014 was previously produced to you care of your counsel, Nickalaus Taylor, Esq., Daniel DeSouza, Esq. and Mitchell Berger, Esq. and his associates on November 5, 2014 in response to a request to produce from you in O'Boyle v. Gulf Stream, Case No. 2014CA004474XXXXMBAA. Because your counsel at the O'Boyle Law Firm has asserted that the statement contains privileged information of the Citizens' Awareness Foundation, Inc., the Town is unable to reproduce that statement here. See Citizens Awareness Foundation, Inc. v. Sweetapple, Broeker & Parkas, P.L, Case No. 502014CA011941XXXXMB AA and O'Hare v. Gulf Stream, Case No. 2014 -CA- 008327X XXMB AF. There are additional records received from, sent to or created by Joel Chandler in the possession of the Town's outside counsel, Robert Sweetapple, Esq. Even assuming that those records and any communications between Mr. Sweetapple and Mr. Chandler that have not been shared with the Town are public records as defined in Chapter 119, Florida Statutes, which the Town does not concede, your counsel at the O'Boyle Law Firm claims in pending litigation that Mr. Chandler has provided to Mr. Sweetapple confidential and privileged information of CAFI. See Citizens Awareness Foundation, Inc. v. Sweetapple, Broeker & Yarkas, P.L, Case No. 502014CA011941XXXXMB AA and O'Hare v. Gut( Stream, Case No. 2014 -CA- 008327XXXXMB AF. The Town further asserts that any communications from Mr. Sweetapple to Mr. Chandler are exempt per Fla. Stat. 119.071(1)(d)l as reflecting Mr. Sweetapple's mental impressions, conclusions, litigation strategies or legal theories and were prepared exclusively for civil litigation involving the Town adverse to you, your employees and/or officers (Martin O'Boyle, Denise DeMartini, William Ring), your affiliated entities (including, but not limited to, CAFI, Stopdirtygovernment, LLC, Commerce Group, Inc., Airline Highway, LLC, CRO Aviation, Inc., Our Public Records, LLC and Asset Enhancement, Inc.), your present and former attorneys at the O'Boyle Law Firm (Jonathan O'Boyle, Ryan Witmer, Giovani Mesa, Nickalaus Taylor) and Christopher O'Hare. To search the Town's files and Mr. Sweetapple's files for additional responsive documents, assess whether they constitute public records and determine if any exemption applies will require significant time and expense. The Town estimates 1 hour of administrative support at $36.39 per hour, 2 hours of paralegal support at $125.00 per hour, and 1 hour of attorney support at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). (1 hours @ 36.39 = 36.39) - (.25 hour @ 36.39= 9.10) + (2 hours @ 125.00 = 250.00) + (1 hour @ 235.00 = 235.00) = Deposit Due: $512.29 in cash or check. Finally and in particular since you have made a broad request for "all communications," the Town estimates that to conduct a thorough review of its hard and electronic files to determine that it has not missed any additional documents will require 1 hours of administrative support at $36.39 per hour, 1 hour of information technology support at $120.00 per hour, and 1 hour of attorney support to review for exemptions related to ongoing litigation at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). (1 hours @ 36.39 = 36.39) + (1 hours @ 120.00 = 120.00) + (1 hour @ 235.00 = 235.00) _ Deposit Due: $391.39 in cash or check. The total deposit for both parts of the records request would be = $903.68 in cash or check. The Town of Gulf Stream is currently working on a large number of incoming public records requests. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of rime. Sincerely, Town Clerk