HomeMy Public PortalAboutPRR 14-142309:32: 00 a.m. 09 -17 -2014 1 1 1 9M2 07
0911712014 09:34 Commerce Group (FAX)9543600807
Asset Enhancement, Inc.
1280 West Newport Center Drive
Deerfield Beach, FL53442
Td. phan e: 954.360.7713
T.lecOpy: 954.360.0807
TELECOPIER
TRANSMITTAL PAGE
DATE: 9117/2014
FROM: TO: Custodian of Records Town of Gulf Stream4wl
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P.0011002
09:32:50 a. m. 09 -17 -2014 1 2 1 9543000007
09117/2014 09:34 Commerce Group TAX)9543600807 P.0021002
RECORDS REQUEST (the "Request')
Date of Request: 9/16 /2014
Requestor's Request ID#: 832
REQUESTEE: Custodian of Records Town of Gulfstream
REQUESTOR: Asset Enhancement, Inc.
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:
Deposition of Martin O'Boyle on September 16, 2014 and which were
brought by Scott Morgan, William Thrasher, Bob Sweetapple and /or Joanne
u-L;onnor tine --NK•s--) we woula request a privilege log for any document
or other (PR's) which the Requestee asserts are privileged and which the
eques ee asserts that e Requestor s not entitled o rece ve sa 's.
As to the PR's, please identify which PR's came from each of the party's
above. enumerated
ADDITIONAL INFORMATION REGARDING REQUEST:
THIS REQUEST 15 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 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 11 X 17 PAPER. NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES
SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 10,0701(a) (2)
ALL ELECTRONIC COPIES ARE REQUESTED TO BE SED11 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 Requestor approve of any costs, asserted by the Agency (as defined in Florida
Statute, Chapter 119.01 (Definitions)), In advance of any costa imposed to the Requestor by the Agency.
h?/NPR/FRR
09.12.14 FORM
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
October 9, 2014
Asset Enhancement, Inc. [mail to: records @commerce- group.com]
Re: GS #1423 (832)
Provide a copy of all non privileged Public Records which were at the Deposition of Martin
O'Boyle on September 15, 2014 and which were brought by Scott Morgan, William Thrasher, Bob
Sweetapple and /or Joanne O'Connor (the "PR's') We would request a privilege log for any
documents or other (PR's) which the Requestee asserts are privileged and which the Requestee
asserts that the Requester is not entitled to received said PR's. As to the PR's, please identify
which PR's came from each of the party's enumerated above.
Dear Asset Enhancement, Inc. [mail to: recordsna,commerce- grouo.coml,
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:
http:// www2.gulf- stream.org/WebLink8 /0 /doe /21016/Pagel.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 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
March 11, 2015
Asset Enhancement, Inc. [mail to: records @commerce - group.com]
Re: GS #1423 (832)
Provide a copy of all non privileged Public Records which were at the Deposition of Martin
O'Boyle on September 15, 2014 and which were brought by Scott Morgan, William Thrasher, Bob
Sweetapple and /or Joanne O'Connor (the "PR's') We would request a privilege log for any
documents or other (PR's) which the Requestee asserts are privileged and which the Requestee
asserts that the Requestor is not entitled to receive said PR's. As to the PR's, please identify which
PR's came from each of the party's enumerated above.
Dear Asset Enhancement, Inc. [mail to: records6E4commerce- eroun.coml,
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 http://www2.gulf-
stream. ore/ WebLink8 /0 /doc /21016/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.
This request failed to identify documents you seek with specificity. Notwithstanding this fact,
the town responds that the exhibits to Mr. O'Boyle's deposition are public records which were at
the deposition September 15, 2014. The exhibits are embedded within the deposition transcripts
which are attached to the email.
We consider this matter closed.
Sincerely,
Town Clerk, Custodian of the Records
In The Matter Of:
MARTIN E. O'BOYLE v.
TOWN OF GULF STREAM
Deposition of'MARTIN O'BOYLE
September 15, 2014
Vol 11
DEBRA DURAN
A S S O C I A T E S
Hr�i�trretl /'rnJi'c�'inntt! Xr /tnrtrr�
Itrd��lq.�il4i i
West Palm Beach, Florida 33402
561- 313 -8000
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No.502014CA004474XXXXMB
MARTIN E. O'BOYLE,
Plaintiff,
-vs- VOLUME II
TOWN OF GULF STREAM,
Defendant.
CONTINUED VIDEOTAPED DEPOSITION OF MARTIN E. O'BOYLE
TAKEN AT THE INSTANCE OF THE DEFENDANT
Monday, September 15, 2014
9:50 a.m. - 5:47 p.m.
224 Datura Street
Suite 1405
West Palm Beach, Florida 33401
Reported By:
Debra Duran - Bornstein, RPR
Notary Public, State of Florida
Debra Duran & Associates
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APPEARANCES:
On behalf of the Plaintiff:
DANIEL DESOUZA, ESQUIRE
DESOUZA LAW, P.A.
1515 N. University Drive
Suite 209
Coral Springs, Florida 33071
NICK TAYLOR, ESQUIRE
THE O'BOYLE LAW FIRM P.C., INC.
1286 West Newport Center Drive
Deerfield Beach, Florida 33442
On behalf of Jonathan O'Boyle, William Ring
& The O'Boyle Law Firm PC., Inc.
CULVER SMITH, III, ESQUIRE
CULVER SMITH III, P.A.
500 Australian Avenue South
Suite 600
West Palm Beach, Florida 33401
Co- Counsel on behalf of the Defendant:
ROBERT A. SWEETAPPLE, ESQUIRE
SWEETAPPLE, BROEKER & VARKAS, PL
20 S.E. 3rd Street
Boca Raton, Florida 33432
Co- Counsel on behalf of the Defendant:
JOANNE O'CONNOR, ESQUIRE
JONES, FOSTER, JOHNSTON & STUBBS
505 South Flagler Drive, Suite 1100
West Palm Beach, Florida 33401
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 157
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ALSO PRESENT:
William Ring, Esquire
The O'Boyle Law Firm PC, Inc.
Jason Peterson, Videographer
Legal Graphicworks
Doug Stacy, Videographer
Scott Morgan, Mayor
Town of Gulf Stream
William Thrasher, Town Manager
Town of Gulf Stream
Christopher O'Hare
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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E X H I B I T S
DESCRIPTION PAGE
(DEFENDANT'S
EX.
7
AIRLINE HIGHWAY, LLC
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PRINTOUT
DEFENDANT'S
EX.
8
CRO AVIATION, INC
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CORPORATION DOCUMENT
DEFENDANT'S
EX.
9
STOP DIRTY GOVERNMENT LLC,
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CORP DOCS
DEFENDANT'S
EX.
10
OUR PUBLIC RECORDS LLC
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CORP DOGS
DEFENDANT'S
EX.
11
COMMERCE GP, INC
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DEFENDANT'S
EX.
12
CG ACQUISITION COMPANY
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DEFENDANT'S
EX.
13
ASSET ENHANCEMENT, INC.
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DEFENDANT'S
EX.
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STATEMENT OF CHANGE OF
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REGISTERED OFFICE
DEFENDANT'S
EX.
15
CITIZENS AWARENESS
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FOUNDATION CHANGE OF
REGISTERED AGENT
DEFENDANT'S
EX.
16
JUNE 6, 2014 LETTER TO
251
TOWN OF GULF STREAM
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 160
CONTINUED PROCEEDINGS
THE VIDEOGRAPHER: The time is 2:36 p.m.
We're back on the record.
BY MR. SWEETAPPLE:
Q. Thank you.
Mr. O'Boyle, the Citizens Awareness
Foundation, Inc., it doesn't have any income, does it?
A. I don't know.
Q. It just exists to bring public records
litigation, right?
A. I don't know.
Q. Weren't you the one that was involved in
having the entity formed?
A. I don't think so.
Q. And didn't you review and approve the mission
statement for the entity?
A. No. I think it was Mr. Chandler.
Q. Well, didn't you review it and approve it?
A. I don't think so.
Q. And weren't you aware that its sole purpose
was going to be to front litigation through your son's
law firm?
A. No.
Q. And are you aware of the Citizens Awareness
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Page 161
Foundation versus Joel Chandler lawsuit that was filed
in the Seventh Judicial Circuit on or about August of
this year -- December 6th. Were you aware that lawsuit
was filed?
A. Can you say that again?
Q. Were you aware that lawsuit was filed?
A. Which lawsuit would that be?
Q. Citizens Awareness Foundation, Inc., versus
Joel Chandler.
A. Can you tell me more about it?
Q. It's a suit against Mr. Chandler. It alleges
that he breached his fiduciary duty and other claims.
A. I believe I am aware of that, yes.
MR. DESOUZA: That's the Complaint?
MR. SWEETAPPLE: Yes, it's the Complaint.
BY MR. SWEETAPPLE:
Q. And did you have any involvement in the
preparation of this complaint?
A. No.
Q. Do you know who, at Citizens Awareness
Foundation, Inc., caused this complaint to be filed?
A. No.
Q. As part of the -- what is the purpose of
Citizens Awareness Foundation, Inc?
A. It is to educate the people in connection with
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Page 162
public records; and to make public records requests.
And to the extent public records requests are made and
they're not filled, to consider litigating the issue.
I think all of that is in the statement that
Mr. Chandler prepared. Mr. Chandler prepared it, and
whatever that says, we were going along with it.
Q. Okay. Well, he says that you absolutely were
not going along with any of the legitimate uses of
Citizens Awareness Foundation but, rather, you, Mr. Ring
and Ms. De Larmartini insisted that his sole purpose was
to go generate lawsuits and to give them to your son and
his law firm. Are you aware of that?
MR. TAYLOR: Objection.
MR. DESOUZA: Objection. Form.
MR. SMITH: Object to form.
MR. DESOUZA: He said this when?
BY MR. SWEETAPPLE:
Q. Are you aware of that, Mr. O'Boyle?
A. Can you say that again, please?
Q. Are you aware that it's Mr. Chandler's sworn
position that despite the fact that he intended to work
for those reasons, that is, that there were some social
purposes; that, in fact, your instructions, Mr. Ring's
instructions, and Ms. De Larmartini's instructions were
that he was to, on a full -time basis, go out and
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Awareness.
BY MR. SWEETAPPLE:
Q. You know nothing about Citizens Awareness
Foundation?
A. Nothing whatsoever.
Q. So any a -mails that are between you and
individuals regarding Citizens Awareness, that is really
not you?
A. Well, let me see them.
Q. Are you aware of any a -mails that you sent to
Mister --
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 163
generate
public record requests lawsuits so
that they
could be
prosecuted by your son and his law
firm?
MR. SMITH: Object to form.
MR. TAYLOR: Same.
MR. DESOUZA: Objection.
BY MR. SWEETAPPLE:
Q.
That's his sworn testimony.
A.
He lied under oath.
Q.
And, in fact, in the lawsuit that
was filed,
you allege that Mister --
MR. TAYLOR: Who's the plaintiff in
the case?
MR. SWEETAPPLE: Citizens Awareness
Foundation
Inc.
The entity that you are funding.
THE WITNESS: I know nothing about
Citizens
Awareness.
BY MR. SWEETAPPLE:
Q. You know nothing about Citizens Awareness
Foundation?
A. Nothing whatsoever.
Q. So any a -mails that are between you and
individuals regarding Citizens Awareness, that is really
not you?
A. Well, let me see them.
Q. Are you aware of any a -mails that you sent to
Mister --
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Page 164
A. I haven't seen any e- mails.
Q. Have you exchanged any a -mails with
Mr. Chandler this year?
A. Yes, I think I have. He stole a bunch of
money, and I asked him to please come back and bring it
back.
Q. He also accused your son of being involved in
a windfall scheme, including Mr. Taylor, where
defendants in Citizens Awareness Lawsuits were being
held up for fees that were not earned by the firm, and
you demanded that Mr. Chandler retract that e-mail,
correct?
MR. SMITH: Object to the form.
MR. DESOUZA: Objection. Form.
MR. TAYLOR: Objection.
THE WITNESS: No. That's not true.
BY MR. SWEETAPPLE:
Q. What happened?
A. He did send -- he came in, and I don't
remember the date. It was -- I think the first part of
June.
And my secretary called me and said, Joel
Chandler was here. He left a bag of stuff and an e -mail
saying he resigns effective immediately. And he wants
you to call him.
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Page 165
So I called him, and I couldn't get him. And
I either got him that night late, or the following day.
I just don't remember. And I forget your question.
Q. You said you called Mr. Chandler that night.
A. Yeah.
Q. Why did you call Mr. Chandler if you're not
involved with Citizens Awareness Foundation?
A. Because he asked me to call him. As an
example, if you asked me to call you, I would call you,
too.
Q. Mr. O'Boyle, my question dealt with the fact
that you were made aware that one reason Mr. Chandler
was resigning was because of communications between he
and Mr. Taylor involving your son's insistence that
lawsuits be settled with defendants of Citizens
Awareness Foundation for more money than was incurred in
attorney's fees and costs.
MR. DESOUZA: Objection to form.
MR. TAYLOR: Form.
BY MR. SWEETAPPLE:
Q. Are you aware of that?
A. I know there was an e -mail. I told you what I
know, I called him later on. And I said, "Where is the
stuff ?"
And he said, "You got everything you're
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Page 166
getting."
And he's never called back since. I've called
him several times after that.
Q. In fact, you made a demand of Mr. Chandler
that if he didn't retract the e-mail, you were going to
visit unpleasantness upon him, didn't you?
A. No. He made that -- he states that in an
e -mail.
Q. You never said that?
A. No. I never said that.
Q. And the only reason you were talking to
Mr. Chandler when he resigned from Citizens Awareness
Foundation is because he asked you to?
A. Well, I really wanted to get what he stole
back.
Q. And what did he steal?
A. Money.
Q. He stole money?
A. Yes.
Q. How much money did he steal?
A. I think 15 or 25,000. I don't remember.
Q. Who did he steal it from?
A. I guess -- what's the name of that company?
Citizens Awareness?
Q. And in Paragraph 10 of the Complaint,
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Page 167
Exhibit 6, the attorneys for Citizens Awareness
Foundation, Inc., which you claim to have no involvement
A. None.
Q. And I'm going to give you a chance to try to
retract your statement.
A. Lucky me.
Q. Are you telling us under oath that you were
not involved in any of the activities of Citizens
Awareness Foundation other than loaning them money?
A. Other than loaning them money and returning
Joel's e -mail. Yeah. A phone call.
Q. And we'll spend a little time on that when I
go through all of the communications that I have
chronicled here, including your threat -- your threat
on -- let's go through them so I can give you verbatim
quotes. That will be the best way to do it,
Mr. O'Boyle.
So it says in the lawsuit in Paragraph 10.
"Prior to February 17, 2014, Chandler filed hundreds of
lawsuits throughout Florida (including at least five in
this judicial district) relating to alleged violations
of the Public Records Act and Sunshine Laws."
Then he goes on in Paragraph 12. "Because of
Chandler's extensive and unique experience coinciding
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Page 168
with plaintiff's desire to promote government
transparency, then plaintiff actively sought out and
communicated with Chandler regarding his possible
employment with plaintiff."
You're the one who personally solicited
Mr. Chandler to work for an entity, and Citizens
Awareness Foundation was formed the very day that he was
hired, right?
MR. DESOUZA: Objection to form.
THE WITNESS: You asked two questions.
Q. Let me break it down for you.
You're the one who solicited, having
Mr. Chandler come work for a not- for - profit entity to
make public records requests claims and lawsuits, right?
A. No.
Q. And he stayed at your home for a period of
time in January, didn't he?
A. Yeah, a day.
Q.
Then
you put
him up in
a hotel, right?
A.
If he
did, I
don't know
what hotel he stayed
at.
Q. Well, he used your funds while he was down
here, right, to live?
A. When a guy works for you, you usually pay his
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Page 169
expenses.
Q. He was working for you, right?
A. Well, when I say "a guy works for you ", a guy
works -- I used the companies together and I shouldn't.
He needed a credit card in order to pay for a
hotel room. My secretary, Brenda, got him a credit
card. I've never seen it.
Q. But Citizens Awareness Foundation wasn't even
formed for weeks after that.
A. That could be.
Q. He was working for you at the time, right?
A. I don't think so, but...
Q. And it says, "After several lengthy
discussions over a period of approximately two weeks,
plaintiff and Chandler entered into a memorandum of
understanding on February 17th."
Who were those lengthy discussions with
between plaintiff and Chandler? Was that Martin O'Boyle
or somebody else, Mr. O'Boyle?
A. It was with no one. It was Mr. Chandler, who
prepared the memorandum, is my understanding. I don't
think anybody changed it.
Q. Well, it says "after several lengthy
discussions over a period of approximately two weeks,
plaintiff and Chandler entered into a memorandum of
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Page 170
understanding."
Who, on behalf of the plaintiff, was having
these communications?
A. Don't know.
Q. Wasn't it you?
A. No.
Q. And one of the agreements that Mr. Chandler
was required to specifically agree to between the
alleged plaintiff and Mr. Chandler, was "Chandler will
refer violations of open government laws encountered in
the course of his duties to legal counsel approved by
the Foundation." Do you remember that being one of the
terms of his employment?
A. No, I do not.
Q. Take a look at the lawsuit that was filed by
Citizens Awareness Foundation, Inc. And is Mr. Ring
still involved in that entity?
A. I don't know.
Q. And Ms. De Larmartini, is she still involved
in that entity?
A. I don't know.
Q. Didn't you direct that names of people be
changed; that Mr. Chandler become the president back in
June?
A. Not that I recall.
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Pagc 171
Q. Did you have any discussions with anybody
where you determined who were going to be the officers
of this entity?
MR. DESOUZA: Objection. Form.
THE WITNESS: I don't recall.
BY MR. SWEETAPPLE:
Q. And so do you have any idea who these
conversations were with between the plaintiff and the --
and Mr. Chandler where he agreed that he would refer
violations of open government laws encountered in the
course of his duties to legal counsel approved by the
Foundation?
A. I don't know.
Q. Who was the legal counsel approved by the
Foundation?
A. I don't know.
Q. Well, how many lawsuits has Citizens Awareness
Foundation filed in the state of Florida?
MR. DESOUZA: Bob, he is here as Martin
O'Boyle. He is not here as Citizens Awareness
Foundation. As far as I know, he is not a
plaintiff in that lawsuit. It appears at this
point you're trying to get a free bite at the apple
doing discovery in actions where this guy is not
even a party, so.
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MR. SWEETAPPLE: I think he is. I think he is
Citizens Awareness Foundation. That is going to be
part of my counterclaim. And when I go on to all
the facts I have here, you will see he is Citizens
Awareness Foundation and he is not telling me the
truth in his deposition.
MR. DESOUZA: Well, you're entitled to
believe --
MR. SWEETAPPLE: And that's what I'm going to
do. I'm going to take discovery to find out if he
is or not. And then you will decide on your own.
MR. SMITH: Excuse me. A counterclaim will be
against Mr. O'Boyle personally?
MR. SWEETAPPLE: Yes. And he is a plaintiff
in this case personally.
MR. SMITH: And it would be on behalf of the
Town of Gulf Stream, which has not been sued in
this case by CAFI.
MR. SWEETAPPLE: It has also been sued by
CAFI, and without Mr. Chandler's knowledge or
approval. And Mr. O'Boyle and his secretary, it is
alleged, have been filing public records requests
alleging it's under CAFI when it's him personally.
So please allow me to take my discovery, and
then you'll be able to look at the sworn testimony
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Page 173
of witnesses, and you'll be able to learn what has
happened in this case; and then you'll come to
understand all the claims that we'll be bringing
here, okay? So with regard --
MR. SMITH: Of course it would be nice if
you'd bring them, before you --
MR. SWEETAPPLE: With this gentleman I don't
want to bring anything until I have all my ducks in
a row, and all the lawyers I'm working with feel
the say way, Mr. Smith. I'm sure you can
understand why, because he sues opposing lawyers.
He sues people that say things. Mr. O'Boyle seems
to sue anybody he can intimidate or bully.
So I'm not filing anything until we have all
of the discovery. And I'm going to take
Mr. O'Boyle as many times and as long as I need to,
and the rest of the witnesses, as long as I need
to, and we are going to fully litigate all of the
matters that involve he, his son, and his son's law
firm. Okay?
MR. SMITH: Sorry for the interruption. I
don't need to be surprised.
MR. SWEETAPPLE: So that's what we're doing.
Please indulge me.
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Page 174
BY MR. SWEETAPPLE:
Q. So in this lawsuit, can you tell me if -- if
there is any legal counsel that has been approved by
CAFI other than the O'Boyle Law Firm?
A. I have nothing to do with CAFI. I'll say it
again and I'm saying it the last time. If you ask me
again, I won't answer.
Q. All right. Let's go through some specifics,
then.
In January, your son, Ryan Witmer and you met
with Mr. Chandler and discussed in writing the forming
of an entity to bring public records requests to the
O'Boyle Law Firm, correct?
A. If you can show me something, I'll look at it
and answer you. If not, the answer is I don't recall.
Q. And at that time Mr. Chandler was, in fact,
staying at your home; isn't that a fact?
A. If Mr. Chandler was staying at my home, I do
not recall.
Q. On January 27th, CAFI was incorporated, and
the board was designated to be William Ring, Denise De
Larmartini and Brenda Russell, correct?
A.
I have
nothing to
do with CAFI, and I'm not
going to
-- that's
the last
question I'm answering.
Q.
Is CAFI
a tenant
in any building that is owned
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by any entity that you control? Page 175
A. I'm not answering your question.
Q. Is CAFI paying rent to any entity that you
control?
A. I'm not going to answer anymore.
Q. CAFI's address, sir, is listed as the same
address as Commerce Group; are you aware of that?
A. I know nothing about CAFI.
Q. Well, how is it that CAFI -- isn't CAFI
occupying the same physical space as Commerce Group,
sir?
A. Not to my knowledge.
Q. Okay. Let's take a look.
Let's do it in the order I have it. It will
save us some time. An entity by the name of Airline
Highway, LLC; are you involved in that lawsuit? In that
entity?
A. I'm not sure.
Q. And it has been propounding public records
requests, correct?
MR. DESOUZA: He just said he doesn't know if
he has involvement.
BY MR. SWEETAPPLE:
Q. Well, you're the manager of the company,
aren't you, sir? And your wife is the registered agent?
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Page 176
MR. DESOUZA: Objection. Form.
BY MR. SWEETAPPLE:
Q. Isn't that the case?
A. I don't know.
Q. Let me show you what I'll mark as an exhibit
for you.
(Defendant's Exhibit No. 7 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Let me show you a Florida Department of State
Division of Corporations printout for Airline Highway,
LLC, that is a reinstatement. Date filed 6/21/2006. It
says manager, Martin E. O'Boyle, 1280 West Newport
Center Drive. And it says the registered agent is
Sheila L. O'Boyle, 23 North Hidden Harbor Drive, Gulf
Stream, Florida 33483. Please take a look at that.
1280 West Newport Center Drive is the address
that you gave me where the Commerce Group is located,
right?
A. Yes, sir.
Q. And the entity that owns that property -- do
you own the entity that owns that property?
A. I don't understand that question.
Q. Do you have an ownership interest in the
entity that owns 1280 West Newport Center Drive?
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A. I don't know. Page 177
Q. You don't know?
A. No, I don't know.
Q. Well -- and you don't know the name of the
entity that owns that property?
MR. DESOUZA: Objection. Asked and answered.
BY MR. SWEETAPPLE:
Q. Does Airline -- what is Airline Highway, LLC?
A. It's an LLC.
Q. What does it do?
A. I don't know.
Q. Does it own any aircraft?
A. No.
Q. You're the manager of the company. You don't
know what it does?
A. Where does it say I'm the manager?
Q. Doesn't it say you're the manager,
Mr. O'Boyle?
A. Not that I can see. Maybe you can show me.
Q. Okay. See where it says title "manager,
O'Boyle, Martin E. ?"
A. Where does it say "title manager ?"
Q. "Title MGRM."
A. How is that manager?
Q. What do you think that is?
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Debra Duran & Associates
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Page 178
A.
I have no idea.
Q.
Managing member. It's an LLC.
A.
Managing member.
Q.
Do you know what your title is in Airline
Highway,
LLC?
A.
I think I'm a member.
Q.
And what does this entity do?
A.
I don't know.
Q.
Does it have any formal legal documents?
MR. DESOUZA: Objection to form.
THE WITNESS: I don't know.
BY MR. SWEETAPPLE:
Q.
Does it have any -- does it keep any records,
corporate
records?
A.
I don't handle that stuff.
Q.
Who handles that for this entity?
A.
Probably either our accountant or my
secretary.
Q.
Which secretary?
A.
Brenda Russell.
Q.
So Brenda Russell is your secretary, and she
is one of
the directors of CAFI?
A.
I don't know if she is a director of CAFI.
Q.
I told you who the three directors are.
A.
That's what you told me. I don't believe you.
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Page 179
Q. So you don't know who they are?
A. I just told you I know nothing about CAFI.
Q. You don't know that it's -- your secretary
Brenda Russell, your attorney /business partner,
Mr. Ring, and Ms. De Larmartini, who has been with you
for over 25 years, you don't know those are the three
people you appointed to run CAFI, allegedly?
MR. DESOUZA: Objection to the form.
BY MR. SWEETAPPLE:
Q. You don't know that?
A. You don't know what you're talking about, and
I'm not going to answer anymore.
Q. So since I don't know what I'm talking about,
can you tell me what Airline Highway, LLC was formed to
do or what it does?
A. I already answered that question.
Q. You don't know?
A. I don't know.
Q. And what do you do for this company?
A. I don't think I do anything, but I don't know.
Q. Well, it has sent public records requests to
me. Do you know why this company or this LLC has sent
public records requests to me?
A. Because they like you.
Q. Okay. And who there likes me?
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A. Whoever sent it to you. Page 180
Q. Do you know who sent them?
A. I have no idea.
Q. What about CRO Aviation. Are you familiar --
MR. DESOUZA: Did you leave a copy of that on
the table somewhere, or did you take it back?
MR. SWEETAPPLE: Did I leave an exhibit or no?
MR. DESOUZA: I want to make sure I'm going to
get a set of exhibits when we get out of here.
MR. SWEETAPPLE: Did we mark it? You're
right. Seven. Let me mark this as 8.
(Defendant's Exhibit No. 8 was marked for
identification.)
MR. SWEETAPPLE: I have copies of this one.
MS. O'CONNOR: Did he give you the cover
letter for that one, too? Is 7 with the --
MR. DESOUZA: Seven is just --
MR. SWEETAPPLE: They can have the cover
letter, too.
MS. O'CONNOR: I gave him 7.
BY MR. SWEETAPPLE:
Q. What is CRO Aviation, Mr. O'Boyle?
A. It's a corporation.
Q. And did you cause it to be formed?
A. I don't know that I did or not.
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Page 181
Q. Its principal address is care of Commerce
Group, Inc.
A. Yes.
Q. Is it related to Commerce Group, Inc?
A. It has the same address.
Q. Are they a subsidiary or a related entity?
A. It has the same address.
Q. That's all you know?
A. That's it.
Q. And is CRO Aviation a tenant at that location?
A. I'm not really sure how to answer that
question, except that the address on all of our entities
that I have, that I'm involved in, in the corporate
governance is done out of 1280 West Newport Center
Drive.
Q. Does this company keep a corporate book with
minutes and have meetings?
A. I don't know.
Q. You're the president, secretary, treasurer,
right?
A. I don't know.
Q. Isn't that what this filing says?
A. What year is it?
Q. This says 2014. 4/28/2014 was the filed date,
so within the last four months.
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A. Okay. So.. Page 182
Q. What does this company do, Mr. O'Boyle?
A. I don't think anything.
Q. Does it own any planes?
A. Not right this minute, no.
Q. Did it own any planes?
A. I think it did. I'm not sure if it did. I
think it did.
Q. What planes do you think it owned?
A. I don't know. One of the four I told you
Q. And are there any planes that you or an entity
that you have an interest in, or that you have an
officership in, has ever been used to pull banners? Or
do you hire planes that you have no interest in?
A. You asked a lot of questions there again.
Q. When you have flown banners over the Palm
Beach County Courthouse during your daughter's case and
appeal, did you hire out planes, or did you use planes
that you had some ownership interest in?
A. First of all, I'm not sure that it was during
my daughter's case for the appeal. But I did not use
any planes that I had.
Q.
So
you
hired
planes
there?
A.
To
the
extent
I was
responsible for running
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Page 183
banner planes, they would have been hired, yes.
Q. Where did you hire them from?
A. I have no idea.
Q. Who did the hiring?
A. Michelle. The same person I told you last
time you asked.
Q. Do you know which airport the planes were
hired from?
A. No.
Q. And who do you use now to fly banners?
A. I think the same company. I think. I'm not
sure.
Q -
A.
Q -
currently?
A.
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Do you know the name of the company?
I don't.
Who handles the banners you're doing
Probably Brenda.
Brenda, the director of CAFI?
Brenda Russell.
Who is your secretary?
Yes.
And who pays Brenda's salary?
I don't know.
Does CAFI pay Brenda's salary?
No.
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Page 184
Q. Does one of your other entities pay Brenda's
salary?
A. I think so.
Q. Does Brenda serve as director of CAFI for
free?
A. I'm not going to answer any questions about
CAFI.
Q. Why is that?
A. Because I know nothing about CAFI, and
anything I say is a guess and I'm told not to guess.
Q. I'm going to see if I can help you in that
regard, Mr. O'Boyle.
A. Good. Good.
(Defendant's Exhibit No. 9 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Stop Dirty Government, LLC.
Are you familiar with that entity?
A. The name, yes.
Q. That's all you're familiar with is the name?
A. That's it, yes.
Q. Can I see that when you're done?
A. Sure.
Q. Thank you. It says you're the manager. It's
been in existence since 2011. And do you know the
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Page 185
purpose of this entity?
A. Yes. It is to deal with the government and
hopefully with the name to bring them down a notch or
two.
Q. Is it for purposes of filing public records
requests?
A. Not necessarily. It may, but the same way as
any entity.
Q. Has it filed public records requests?
A. I think it has, but I don't know for sure.
Q. Do you know how many it has filed?
A. I have -- just as I said, I think it has, but
I don't know for sure so how could I know how many are
filed.
Q. And do you know if it's filed any lawsuits,
become a plaintiff in any lawsuits?
A. Not to my knowledge, but I don't know.
Q. And let me show you the next one I'm going to
mark, which is Our Public Records, LLC.
(Defendant's Exhibit No. 10 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Did you cause Our Public Records, LLC to be
formed?
A. I think -- if I didn't, I certainly directed
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Debra Duran & Associates
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Page 186
it be formed.
Q.
Who formed this entity for you? Which person?
A.
Not a lawyer.
Q.
Who would you have had in your office do it?
A.
I really can't say.
Q.
Was it the same person that formed CAFI?
A.
I think -- CAFI was not formed. I don't know
who formed CAFI, but I can't answer your question.
Q.
And has that entity issued public records
requests?
A.
That entity, I think it has.
Q.
And has it been a plaintiff in public records
litigation?
A.
If it has, I know nothing about it.
Q.
And are you actively managing this company?
A.
This company is -- we're hoping it will be a
big company, and it's in its infancy.
Q.
What are you intending this company to become
big in?
A.
Public records.
Q.
Filing public records lawsuits?
A.
No. Educating the public about public
records.
Q.
And can I see that?
A.
Sure.
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Page 187
Q. What have you done in that regard with regard
to this entity, Our Public Records, LLC?
A. We have a website.
You're welcome to look at it. It is Our
Public Records.com. If you want, we can take a few
minute break, you can look at it. I think you would be
really impressed. I know you want to thank me.
Q. Commerce Group GP, Inc.
(Defendant's Exhibit No. 11 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Who formed this, Mr. O'Boyle? Which
individual?
A. Don't know.
Q. And it says that your wife is a registered
agent, correct?
A. That's what it says.
Q. It says are you the director, president,
treasurer, right?
A. Well, it says I'm DPT, whatever that is.
Q. Isn't that director, president, treasurer?
A. I don't know. You tell me.
Q. And Stop Dirty Government and you have filed a
lawsuit in Palm Beach County, haven't you? A public
records lawsuit?
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Page 188
A. I don't know. If we have, we have.
Q. You don't know?
A. No.
Q. Did you ask for any documents along with Stop
Dirty Government that you wanted?
MR. DESOUZA: Objection to form.
THE WITNESS: Not that I can think of.
BY MR. SWEETAPPLE:
Q. And what does Commerce Group GP, Inc., do?
A. I don't know.
Q. Why was it formed?
A. I don't know. It was formed almost 20 years
_..
Q. It has been in existence for 20 years?
A. Yeah.
Q. What has it done in the last 20 years?
A. I don't know.
Q. Has it occupied 1280 West Newport Center
Drive?
A. Yeah. It occupies that building and three
more like it.
Q. It is in three other buildings?
A. No, not at all.
Q. Just this building?
A. No.
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Inc.
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Page 189
Q.
Does it have a lease?
A.
It has that address for the sole purpose of --
the young
lady who handles our corporate governance is
there. So to have the forms made elsewhere is not a
very smart thing to do. So we mail them there. She
gets them,
and she files whatever forms are necessary to
keep them
current and in good standing.
Q.
Is this a company that is engaged in business?
A.
I don't know.
Q.
Do you know if it files tax returns?
A.
I don't know.
Q.
Do you know if it has income?
A.
I don't know.
Q.
Who would know that?
A.
I don't know.
Q.
Who is your accountant?
A.
I don't know.
Q.
And CG Acquisition Company.
(Defendant's Exhibit No. 12 was marked for
identification.)
BY MR. SWEETAPPLE:
Q.
Let's mark this as next.
What is CG Acquisition Company, Mr. O'Boyle?
A.
I think it's a corporation by Commerce GP,
Inc.
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Page 190
Q. And what does it do?
A. Pardon?
Q. What does it do?
A. I don't know.
Q. Is it engaged in moneymaking?
A. I don't know.
Q. Who formed it?
A. I don't know.
Q. What about Asset Enhancement, Inc., also
showing an address of 1280 Newport Center Drive. What
is that entity, sir?
(Defendant's Exhibit No. 13 was marked for
identification.)
THE WITNESS: This is an entity that was
incorporated 40 years ago, and I have no idea what
it does.
BY MR. SWEETAPPLE:
Q. Okay. So it's been in business for 40 years,
and your wife is a registered agent, and you are the
director, president, treasurer, right?
A. That's what you say.
Q. That's what the document says.
A. That's what you say.
Q. Okay. And you don't know what this company
does, right?
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Debra Duran & Associates
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Page 191
A.
Right.
Q.
And all these companies that you don't
know
what they
do, who manages it? Does someone manage these
companies
for you?
A.
Our accountants deal with them, and I don't
deal with
them at all.
Q.
And are your accountants in- house?
A.
No.
Q.
So who -- what are the names of the
accountants that deal with these?
A.
I don't know.
Q.
You really don't know your accountant's
name?
A.
I really don't know.
Q.
You don't know any of your accountants'
names?
A.
Flynn is one of them.
Q.
What's his last name?
A.
Flynn.
Q.
F -1 --
A.
I think it is y -n -n.
Q.
Where is he located?
A.
Roanoke, Virginia.
Q.
Who are the accountants for CAFI?
A.
I don't know.
Q.
And what about Commerce Group, Inc? Is
that a
company you're familiar with?
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Page 192
A. I'm -- yeah.
Q. And is that a company that you're actively
involved in?
A. I don't know.
Q. What does Commerce Group, Inc., do?
A. I don't know.
Q. Are you aware that you're listed as the DPT in
the Department of State records?
A. No.
Q. And the address is the same, 1280 Newport
Center Drive.
A. That's where we do our corporate governance
work.
Q. Okay. Is Commerce Group, Inc., your main
business?
A. No.
Q. I'm not going to mark Commerce Group, Inc. I
think it's pretty much the same as the others.
Let's go to CAFI. Now -- so your son, your
son's law firm leases 1286 West Newport Center Drive,
right?
A. Yes.
Q. And that is just for his law firm, right?
A. I don't know.
MR. DESOUZA: Objection. Form.
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Page 193
Q. Is there any another businesses that leases
that space?
A. You asked me, you said that's leased.
Q.
1286
West Newport
Center
Drive,
you say
there's
a door
between that
space
and your
offices,
right? Your businesses?
A. That's correct.
Q. And you told me that CAFI is not located in
your son's law office space, correct?
A. That's correct.
Q. And let me show you this statement of change
of registered office, or registered agent, for both
corporations showing the O'Boyle Law Firm is at 1286
West Newport Center Drive. And this printout is for
Citizens Awareness Foundation, Inc., with the same
address, 1286 West Newport Center Drive, Deerfield
Beach, Florida 33432. And then the help line is
888 - 830 -3769.
I'm going to mark these as the next two
exhibits and ask if you've ever seen either of them
before.
I'm going to make the statement of change of
registered office No. 14; and the sheet that says the
Citizens Awareness Foundation change of registered agent
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Page 194
No. 15. Have you ever seen No. 14 or No. 15 before
today?
(Defendant's Exhibit No. 14 was marked for
identification.)
(Defendant's Exhibit No. 15 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Have you ever seen No. 14 and No. 15 before?
MR. DESOUZA: Can I see these? I assume there
is only one copy?
MR. SWEETAPPLE: Let me see if I have more. I
think that's the only one I have of that.
MR. DESOUZA: For my own purposes, did you say
where this DX15 came from?
MR. SWEETAPPLE: I have not said that. I'm
asking if he recognizes it.
MR. DESOUZA: Okay. I wasn't sure if you said
that.
Can I ask you to read the pending question
back?
MR. SWEETAPPLE: Sure. Can you read it back?
(A portion of the record was read by the
reporter.)
MR. DESOUZA: I'll object to form on the
compound nature of it.
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Page 195
BY MR. SWEETAPPLE:
Q. Have you seen No. 14 before?
A. No.
Q. Have you seen No. 15 before?
A. No.
Q. Do you know who Ryan Witmer is?
A. Yes.
Q. And he has left the O'Boyle Law Firm; has he
not?
A. He has.
Q. Do you know why?
A. Yes.
Q. And what did he tell you?
A. He is in -- before he came here, he was
supposed to go and be a lawyer up in New York State. He
was supposed to be a partner with a fellow up there.
And they -- Matt -- I forget his last name -- and Matt
had a great deal of difficulty and was delayed for about
a year, and getting a character witness to approve him.
So Ryan came to work with us, and then one day he said
he wants to do immigration work.
Q. So he said to "us ", you mean you and Jonathan?
A. Jonathan, not me. He didn't tell me.
Q. You actually are involved in the overall law
firm, aren't you?
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Page 196
A. No.
Q. You fund that law firm, don't you?
A. I phone it?
Q. Fund it. And you pay lawyers' salaries
directly, don't you?
A. You mean --
Q. Through your entities; you and through your
entities you fund the --
A. You going to let me answer or not?
Q. Pardon?
A. Do you want to let me answer or not?
Q. I'm rephrasing it for you.
You or your entities fund the O'Boyle Law Firm
through making loans and by making direct payments to
lawyers, don't you?
A. No.
MR. DESOUZA: Objection. Form.
BY MR. SWEETAPPLE:
Q. And is the Citizens Awareness Foundation
located in the same address as your son's law firm?
A. Not to my knowledge.
Q. Is the Citizens Awareness Foundation located
in the building that your entity owns at 1280 West
Newport Center Drive?
A. I'm not answering anymore questions on
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Citizens Awareness.
Page 197
Q. And on February 5th, did you tell Mr. Chandler
to send all litigation to the O'Boyle Law Firm or you
will cut off the flow of money?
MR. SMITH: Object to the form.
THE WITNESS: Not that I know of.
BY MR. SWEETAPPLE:
Q. On March 22nd, did Mr. Ring and Ms.
De Larmartini insist that all cases from Citizens
Awareness Fund be sent to the O'Boyle Law Firm?
MR. DESOUZA: Object to the form.
THE WITNESS: I'm not going to answer that
question on the attorney- client privilege. And
I've told you, and this is the last time I'm
telling you, I'm not going to answer any questions
on Citizens Awareness Foundation. I have no
knowledge of that corporation and I'm not going to
continually go through this. So this ends right
here.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle, I have to ask the questions on a
one by one basis.
A. You ask me, I'm not going to answer.
Q. You decide that on each question basis and the
judge will decide if I'm going to get an answer or not.
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A. That's fine. Page 198
Q. On April 1, are you aware whether or not your
son offered to provide legal counsel to Mr. Chandler and
handled one of his personal Florida public records
requests cases?
A. No.
Q. Are you aware whether or not in March and
April Ms. De Larmartini was present telephonically for
law office administration meetings while she was on the
board of CAFI, and she went through the entire list of
all O'Boyle Law Firm cases while Mr. Chandler was
present?
MR. DESOUZA: Object to the form.
THE WITNESS: I can't imagine she would say
that, but...
BY MR. SWEETAPPLE:
Q. Are you aware that on April 14, your son wrote
Chandler and advised him that he was assigning a Florida
case to himself to handle?
A. Why don't you show me documents rather than
just flapping your lips.
Q. Well, I see from this lawsuit that apparently
you are saying -- the lawsuit alleges that Mr. Chandler
deleted all of the -- or deleted CAFI e- mails. Is that
accurate?
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Page 199
MR. DESOUZA: Which lawsuit are we talking
about?
MR. SWEETAPPLE: Talking about the suit, CAFI
against Chandler.
MR. DESOUZA: So you're talking about
Defendant's Exhibit 6 for clarity of the record?
MR. SWEETAPPLE: Six. Yes.
MR. DESOUZA: And the question?
THE WITNESS: I know nothing about CAFI. And
let me say it 100 times in a row and that way we
can save you all this time.
BY MR. SWEETAPPLE:
Q. You wrote Mr. Chandler and asked him to get
you the records for CAFI --
A. Let me see it.
Q. -- didn't you, sir?
A. Let me see them.
Q. I want to know whether you know.
A. Let's see them.
Q. Mr. O'Boyle.
A. Let's see them.
Q. You're going to see them.
A. Let's see them.
Q. You're going to see them, Mr. O'Boyle.
Believe me, you're going to see them. Did you write --
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Page 200
Q. -- to Mr. Chandler and ask him to please help
in getting all of the records to CAFI back to you
De Larmartini so that cases could be filed?
A. As I told you before, Mr. Chandler resigned at
the earlier part of June. He left a bag, and a letter
of resignation.
My secretary called me. She said, Joel wants
you to call him. I tried to call him moments later. I
didn't get him. Either that night or the next day I did
get a hold of him. And what he said is, "Everything you
need is in that bag."
And I -- I wasn't sure if he was even in
Florida, as I recall. So that's what I can tell you
about the e -mail.
Q. Didn't you write him on July 2nd and copy Ms.
De Larmartini and Mr. Ring, subject Joel Chandler. And
you wrote Joel Chandler and you indicated that the
office, our office and the law office are stuck in
quicksand since they can't gain access to certain files.
And then you went on to say, "It would sure be
helpful if you could get them through this, so they
could access and use the data. I also understand there
are new cases for the month of June that need to be
accessed.
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Page 201
"As to the new cases, Bill would really like
to get those cases to the attorneys as soon as possible.
A temporary solution would be for you to send the cases
to Denise in the format which has been previously used.
That way I can access them and disseminate them."
Isn't that what you wrote to Mr. Chandler on
July 2nd, 2014?
A. Can I see?
Q. No. I want to know if you remember that.
A. I don't memorize things.
Q. Does that refresh your recollection in any
way?
A. I'd have to see the e -mail.
Q. Okay.
MR. SMITH: You don't want to show him the
document?
MR. SWEETAPPLE: He'll see it when he gets the
lawsuit we're filing.
MR. DESOUZA: The phantom lawsuit we've been
talking about for the past 3 or 4 months?
MR. SWEETAPPLE: No, there is no phantom
lawsuits. We've been working on various lawsuits
for about two months, I would say. And I certainly
wanted to hear Mr. O'Boyle's testimony before we
filed it, and I'm certainly glad I did.
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Page 202
THE WITNESS: Boy, Mr. Sweetapple, that's
great. You're going to bankrupt this city.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle, that only appears to be your
goal, not mine.
A. It's not mine, but I'm going to watch you do
it.
Q. All right. And you put your son in a law
office in Broward County and called it the O'Boyle Law
Firm before he even had a license to practice law in the
state, right?
MR. DESOUZA: Objection. Form.
THE WITNESS: When you say "right ", you say it
with no basis whatsoever.
BY MR. SWEETAPPLE:
Q. Didn't you?
A. You're not an honorable man, so I'm not going
to answer those kind of questions. You got something to
show me, show me.
Q. Your son has been working full -time out of the
O'Boyle law office since it opened in Broward County and
living at your home full -time, correct, Mr. O'Boyle?
A. No, it's not correct. And you have no idea
what you're talking about.
Q. Okay. Are you aware that he listed in
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Debra Duran & Associates
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Page 203
Pennsylvania
his business phone number was his cell
phone number, his 561 cell phone number?
A.
Ah. He did that?
Q.
Yes. And are you aware that --
A.
What a terrible thing.
Q.
And are you aware from your cell phone records
you can tell where every phone call was made or
received?
A.
Am I aware? No.
Q.
And has mister -- does your son reside in New
Jersey?
A.
You ask him that.
Q.
Do you know if he has a voter registration in
New Jersey?
A.
I think he does.
Q.
And a driver's license in New Jersey?
A.
I think he does.
Q.
And that's where he resides?
A.
I think he does.
Q.
And has he been working full -time in your
offices in Fort Lauderdale?
A.
I don't think so.
Q.
And was he ever a partner with Mr. Witmer with
regard to
the O'Boyle Law Firm?
A.
I have no idea.
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Page 204
Q. And you were in such a rush to have your
O'Boyle Law Firm, that you actually put your son in a
position where you opened up an office called the
O'Boyle Law Firm in Broward County, Florida, before he
became a Florida lawyer.
MR. DESOUZA: Object to form. He is not
answering these questions. Why don't you ask him
something not argumentative or harassing.
THE WITNESS: You're just talking nonsense.
Q. WE
Mr. O'Boyle.
wife?
A. You want to tell me when I impregnated my
Q. Well --
MR. SMITH: Marty.
MR. DESOUZA: You don't need to engage him in
this type of stuff, Marty. Let him be the one that
is harassing and making ridiculous questions.
BY MR. SWEETAPPLE:
Q. You put your son in the position of engaging
in unauthorized practice of law, because you solicited
him to actually participate in your public records
litigation here in Florida.
MR. DESOUZA: Objection.
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MR. SMITH: Objection. Page 205
MR. TAYLOR: Objection.
MR. DESOUZA: I'm instructing the witness not
to answer at this point. If you want to ask --
MR. SWEETAPPLE: In fact.
MR. DESOUZA: -- questions that are not
closings and argumentive, that is fine.
BY MR. SWEETAPPLE:
Q. In fact Mr. Giovani Mesa complained to
Mr. Chandler in writing that Jonathan O'Boyle had
drafted cases and filed them in Mesa's name without
Mesa's knowledge or consent, correct? Are you aware of
that?
MR. SMITH: Objection. Argumentative.
BY MR. SWEETAPPLE:
Q. Are you aware whether or not -- on 4/28/2014
Mr. Giovani Mesa complained in writing to Chandler that
Jonathan O'Boyle was drafting lawsuits in Florida and
filing them in Mesa's name without Mesa's knowledge or
consent. Are you aware that occurred, sir?
MR. SMITH: That statement was made by
Giovani -- what is his name? Are you asking him
are you aware of that?
BY MR. SWEETAPPLE:
Q. Yes. That Mr. Mesa complained. A lawyer in
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Page 206
the office complained to Mr. Chandler that that occurred
with your son.
A. If that's what he did, that's what he did.
Q. Have you heard about that before?
A. Never. Never.
Q. And on 4/28, Ms. De Larmartini demanded a
minimum of 25 new public records request cases a week be
forwarded to the O'Boyle Law Firm by Citizens Awareness
Foundation; are you aware of that, in writing?
A. Was that before he committed bank fraud, or
bankruptcy fraud?
Q. This is Ms. De Larmartini's writing, sir.
A. I'm talking about Mr. Chandler. Is that
before or after he committed bankruptcy fraud? Which
one?
Q. Mr. O'Boyle.
A. Which one?
Q. I'm not talking about any statement that
Mr. Chandler made. I'm talking about a statement that
your secretary of over 25 years, your paralegal, the
director of CAFI, made in writing.
Have you -- were you ever aware that Ms.
De Larmartini demanded 25 new public records lawsuits be
filed a week for the O'Boyle Law Firm?
MR. SMITH: Objection. Argumentative.
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Page 207
THE WITNESS: No.
Q. Are you aware that on May 16, Ms.
De Larmartini complained that Mr. Chandler only
generated 211 cases in 12 weeks?
A. No, I'm not.
Q. And are you aware of whether or not CAFI has
ever had any fee agreements with the O'Boyle Law Firm?
A. How much longer do I have to answer about CAFI
when I know nothing?
Q. Oh, I think you will be answering for quite
some time, and I do think you know more than you're
letting on to, Mr. O'Boyle. So let's stop playing games
and see if you can answer my questions.
Are you aware whether or not there are any fee
agreements or engagement letters between CAFI, which you
are the sole funder of, and the O'Boyle Law Firm, which
you are also a funder of? Who are both located in your
building.
MR. DESOUZA: Objection.
MR. SMITH: Objection.
MR. TAYLOR: Objection.
MR. DESOUZA: Objection. A whole host of
objections. Argumentative. Form.
THE WITNESS: Who said I was the sole funder
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Page 208
of CAFI?
MR. DESOUZA: I think Bob said that.
BY MR. SWEETAPPLE:
Q. Who else has funded CAFI, Mr. O'Boyle?
A. I don't know.
Q. Are you aware of anyone besides you that has
provided funds to that entity?
A. I know nothing about CAFI.
Q. When the law firm collects money when it
settles CAFI cases, it doesn't give money to the entity,
does it?
A. What entity?
Q. To CAFI. It keeps all the money it gets when
it settles the cases, right? Or does it give you some?
MR. DESOUZA: Objection. Form.
BY MR. SWEETAPPLE:
Q. I'll break it down.
In the cases that CAFI has settled against
public governmental entities with state contractors, has
any money been given to CAFI, your debtor? Let's just
say that is all they are for the moment.
A. I don't know.
Q. How do you expect CAFI to pay you back?
A. Money.
Q. Pardon?
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A.
With money.
Q.
And how are they earning money?
A.
I didn't ask them.
Q.
Okay. Who would you have to ask to find out
how they're going to pay you back?
A.
I don't know.
Q.
What are the terms of their obligations? Is
there any
obligation to pay you back?
A.
I think so. We have -- yes.
Q.
You have any agreement on that?
A.
I think so. Generally stated, yes.
Q.
Who's the agreement with?
A.
I think it's just common knowledge with all of
our entities.
Q.
Who, at CAFI, specifically, do you have an
agreement
with regarding getting repaid?
A.
I don't think I have a specific agreement
laying out
with detail a 100 -page note.
Q.
What was CAFI's profit model where -- you have
a 100 -page
note, or you don't have a 100 -page note?
A.
I don't have a 100 -page note.
Q.
Do you have a one page note?
A.
No.
Q.
You have no note. Do you have loans written
on checks?
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Page 210
A. Maybe.
Q. How was this document a loan as opposed to
just a contribution?
A. How is it a loan? Because I think the parties
agree it's a loan.
Q. And who are the parties that agreed?
A. I guess CAFI and me.
Q. Who in CAFI made that agreement?
A. I have no idea.
Q. How can you have an agreement and not know who
it is with?
A. Because I think it's common knowledge that I'm
not giving them the money.
Q. Pardon?
A. I'm not giving them the money.
Q. Some entity is that you control?
A. No. No. They're not getting it free.
Q. Okay.
A. It's not a contribution.
Q. So it's a loan?
A. It is a loan, yes.
Q. What is the business that CAFI engages in that
they could ever repay you?
A. Maybe they won't. I'll take a tax write -off.
Q. If it's supposed to be a loan, if your intent
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is it's supposed to be a loan -- you're a very
sophisticated businessman.
A. Thank you.
Q. That's what they say at least.
A. But you don't believe that.
Q. I'm going to keep my beliefs to myself.
A. You should.
Q. So what I would like to know is whether or not
you had any expectation that CAFI had any business
whereby it could repay you?
A. No.
Q. What did you understand the activities that
CAFI was going to be; a not - for - profit foundation,
right?
A. Yes.
Q. And what was it going to do to make money?
Anything?
A. I don't think we've ever gotten that far.
Q. You knew that it was only going to be filing
lawsuits for your son's law firm, right?
A. That's not true.
Q. Well, has any other law firm represented it,
in any other lawsuits?
A. I have no idea.
Q. And does filing a public records request give
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Page 212
the plaintiff any right to remuneration, other than
attorneys' fees and costs by statute?
A. Are you talking about remuneration?
Q. Yeah, to the plaintiff himself.
A. You said enumeration.
Q. Remuneration.
A. What was your question?
Q. Do you understand whether or not CAFI, as a
plaintiff in a public records request, would be entitled
to any money?
MR. DESOUZA: You're asking him for his legal
understanding?
MR. SWEETAPPLE: To the extent he understands
having filed public records requests and funding
this entity.
THE WITNESS: I don't think I can answer you.
BY MR. SWEETAPPLE:
Q. Okay. So you don't know if there are any fee
agreements or engagement letters between CAFI and your
son's law firm?
A. I would have no idea.
Q. Are you aware on May 28, De Larmartini, again,
demanded more cases from Chandler for the O'Boyle Law
Firm?
A. No.
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Page 213
Q. Are you aware that on 6/2 Mr. Ring denied any
authority to send cases to any firm other than the
O'Boyle Law Firm?
A. I'm not.
Q. Are you aware that in June, Mr. Chandler
learned that you had been making public records requests
in the name of CAFI against Gulf Stream, the Town of
Gulf Stream, without his knowledge or consent in doing
so in the name of CAFI?
MR. DESOUZA: Objection. Form.
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. And that you were using your secretary,
Ms. Mohler, M- o- h- l -e -r.
A. No.
Q. Did you ever fax or e-mail, using Ms. Mohler,
public records requests to the Town of Gulf Stream in
the name of Citizens Awareness Foundation, Inc?
A. Not to my knowledge.
Q. And did you ever direct lawsuits, two
lawsuits, to be filed against Gulf Stream in the name of
CAFI without the knowledge or permission of
Mr. Chandler?
A. What period are you talking about?
Q. June. May and June. This year.
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Page 214
A. Mr. Chandler already resigned. He resigned in
May; the middle of May. So I don't know where you're
coming from. I guess he forgot to tell you that part.
Q. You believe that Mr. Chandler resigned in May?
A. Absolutely.
Q. So all his communications after May whatever
is no longer --
A. 16th. I think it was May 16. I'm not sure.
Q. May 16.
A. But I think it was May 16.
Q. How do you know that?
A. Ms. De Larmartini told me.
Q. Was it in writing or orally?
A. It was in writing.
Q. Didn't Ms. De Larmartini on May 26 ask
Mr. Chandler to prepare complaints for CAFI to use?
A. No idea.
Q. And didn't he refuse to, saying he was not a
lawyer?
A. Well, I don't know what he said, not being a
lawyer. But I can tell you he's certainly practicing
law without a license. Make no mistake about that
there. I can show you the Complaints that he prepared.
Q. So it's your testimony that when Denise
De Larmartini wrote Mr. Chandler on May 28 saying "I
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Page 215
understand that we are back to you certifying the
Complaints before they are filed," he wasn't working for
CAFI?
A. Yeah. I don't know that she knew about it at
Q. And on May 28 when she wrote him and said,
"Joel, I didn't see anything yesterday or today for new
cases this week. Were there any ?" He wasn't working
for CAFI when she was writing him asking for more cases?
A. I don't think that she knew at that time.
Q. Didn't Ms. De Larmartini tell you that
Mr. Chandler had resigned?
A. Well, depends on what time period you're on.
In the first part of June my secretary called me up and
said Joel was just here, he left a bag full of stuff and
a letter of resignation. He left immediately and said
he wants you to call him.
So that's resignation No. 1. Denise, when she
got the information -- Joel refused to give her access
to the computer data. She had to hire a computer
expert. And when she did the -- how to say it, but
they -- they were able to encrypt or unencrypt,
whatever, the documentation. And when they did, there
was a letter in there of May 15 or 16th saying "I
resign."
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Page 216
Q. And on June 9, Ms. De Larmartini was talking
to Mr. Chandler about him hiring his son to assist in
conducting electronic audits of state and local
agencies.
A. Yes. She must not have known by then.
Q. Who did know?
A. Mr. Chandler. I mean, he is a crook.
Q. And -- well, Mr. Ring was talking about
Mr. Chandler bringing in his son to work for CAFI in
June, right?
A. They never knew that he was a crook until they
found out he was a crook.
MR. DESOUZA: Bob, just so I'm clear, you're
asking him about his knowledge of conversations or
e -mails between people that he is not one of,
right?
MR. SWEETAPPLE: Not necessarily.
MR. DESOUZA: I think you're referring to
e- mails. You're not showing us the e -mails so I
can't say what the e -mails are, but if he's not on
these e- mails, you're asking him whether he knows
the existence of these e- mails, the existence of
these conversations? Is that what you're asking?
All right.
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Page 217
Q. And did Mr. Ring try to assure Mr. Chandler on
June 16th that he believed that the O'Boyle Law Firm was
free to exercise their legal business judgment as to the
amounts of a particular settlement; that he didn't have
to worry about the amount of attorneys' fees that were
actually incurred?
A. I don't know what Citizens Awareness
Foundation, Inc., did. Now, how many more times do I
have to tell you that before you get it through your
Q. And on June 19, Ms. De Larmartini copied
Mr. Ring re: CAFI. And said, "Bill, I intend to resign
from CAFI and make the following replacements. Cathleen
Flack (phonetic) a Commerce employee. Peter Delio
(phonetic). He is a trusted friend and contractor we
use. Joel Chandler. We would like to have him as
president /director.
Brenda Russell, Commerce employee will remain
as member. Do you see any problem with this? If not,
could you please send me the proper form to amend the
organizational documents."
You were unaware of that communication?
A. I'm not answering.
Q. On June 27th when Mr. Chandler wrote Nick
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Page 218
Taylor the following language, Nick -- on June 27 he was
not an employee of CAFI, right? Is that your testimony?
A. I'm not answering any questions regarding
Q. "Nick, I'm writing this e-mail to memorialize
our telephone conversation this morning. As we
discussed, I was contacted by the defendant in the case
He expressed his regret in his
failure to properly respond to CAFI's PRR, and asked for
our help in better understanding his obligations under
the Public Records Act. He also explained the dire
financial condition of his organization and said he
instructed his attorney to offer to settle the matter
for $1,500.
"In our conversation this morning, I
understood from you that the O'Boyle Law Firm has about
$1200 in costs and fees in the case up to this point. I
also understood that you have been instructed by
Jonathan O'Boyle to demand $3800 to settle the case.
"If such a demand is accepted by the
defendant, that would create a windfall of about 26
beyond actual fees and expenses. During that telephone
conversation, I expressed in unequivocal terms my
objections to such an arrangement. Until I received the
telephone call from the defendant yesterday, I was
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Page 219
unaware that any settlement discussions were taking
place with the defendant.
"I did not authorize any such discussions, nor
did I approve in any way the demand for payment of any
kind, much less demand for payments far beyond the
actual fees and expenses billed by the O'Boyle Law Firm.
"In sum, I understand that you were directed
to make the aforementioned settlement demand by Jonathan
O'Boyle, and I have not and do not approve of such
demands. Please confirm your receipt and understanding
of this e- mail."
And Mr. Taylor -- that was at 11:05 a.m.
Mr. Taylor responded to Mr. Chandler, "This e-mail is to
confirm our conversation today and to reiterate that all
offers of settlement are made pursuant to the policies
of the O'Boyle Law Firm."
Were you aware of any of that communication?
A. I'm not answering any questions regarding
CAFI.
MR. SMITH: For the record, I object to the
question as argumentative.
Q. So after -- after you saw the motion to
disqualify your son's firm, which argued the O'Boyle
firm is not a lawful interstate law firm, how is it that
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Page 220
a meeting was called with Mr. Ring and my co- counsel,
Joanne O'Connor and Mr. Randolph?
A. Mr. Ring and I spoke and we said this is --
MR. DESOUZA: Hold on. You said this to each
other or you said this to opposing counsel?
THE WITNESS: We said it to each other.
MR. DESOUZA: You shouldn't reveal the
substance of any conversation between you and
Mr. Ring.
BY MR. SWEETAPPLE:
Q. Was Mr. Ring serving as your attorney at the
A. Yes.
Q. Even though he wasn't counsel of record on any
A.
I'm not
going to
answer that question.
Q.
Well, he
-- you
just don't know the answer to
that question?
So you spoke to Mr. Ring. And then who
communicated with either Ms. O'Connor or Mr. Randolph?
A. I believe that Mr. Ring called Skip Randolph
and asked for a meeting with him, Ms. O'Connor and
Mr. Stubbs. And Skip Randolph got back to him, either
later that day or the next day. I just don't remember.
Q. And was there any discussion about including
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me at the meeting? Page 221
A. No. Because we knew you were a troublemaker,
and we knew having you there is like having cancer of
the face.
Q. Okay. So even though I was the attorney that
drafted the motion, you decided you did not want me
there.
A. Well, the motion was so full of lies, that to
have you there would have been unproductive. And then,
of course, obviously, when we gave the whatever, the 157
memo, Ms. O'Connor, I think she saw that discretion was
the better part of valor, and she dismissed her claim.
Q. And you think that that was dismissed because
the claims regarding the unauthorized practice of law
weren't being pursued?
A. Yes.
Q. So you think that the law firms involved with
the city have just ignored the facts that we've learned
in this proceeding?
A. I have no idea what you just said.
MR. DESOUZA: Object to form.
BY MR. SWEETAPPLE:
Q. Never mind.
A. Good.
Q. Now, you wanted to have Sid Stubbs at the
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Page 222
meeting,
right?
A.
Yes.
Q.
And Mr. Ring told Ms. O'Connor that it would
not be a
good idea to have me at the meeting, right?
A.
No. I believe he told that to Skip, but I
wasn't on the phone, so I don't know.
Q.
Did you prepare any memorandum at the time of
this meeting?
A.
The answer is yes.
Q.
And you have notes?
A.
Yes.
Q.
And did you write them yourself?
A.
Yes.
Q.
And did Mr. Ring prepare any notes?
A.
I don't know.
Q.
And you showed up at 2:00 o'clock with
Mr. Ring,
and Ms. O'Connor asked if it was -- if she had
the -- or
Mr. Randolph asked whether or not they had the
right to
speak directly to you and whether permission
was received
from the O'Boyle Law Firm, right?
A.
No.
Q.
So Mr. Randolph didn't ask if it was clear
that we have
the right to speak directly to Martin
O'Boyle and
whether permission was received from the
O'Boyle Law
Firm; and Bill Ring said, Yes. He checked
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Page 223
with the O'Boyle Law Firm and they gave that authority.
A. Not to my knowledge.
Q. Okay. And Mr. Randolph indicated I would need
something in writing from them, and he said he would get
that and send it to me by e-mail.
MR. SMITH: Excuse me, objection. I think
it's ambiguous what you're reading from, because --
MR. SWEETAPPLE: Let me make it clear. That
is a good objection. I'm sorry.
MR. SMITH: Thank you.
Q. Did Mr. Randolph say to you that he needed
something in writing that the O'Boyle Law Firm gave
Mr. Ring the permission for him and you to speak
directly with Mr. Randolph?
A. No.
Q. And then did you ask the next question, "Are
these settlement negotiations, and does everything stay
in this room ?" Did you ask that?
RAMENIVrel
Q. And did Mr. Randolph indicate that if there's
truly settlement negotiations and not discussion
relating to future litigation or threatened activity
that it would be privileged communications; did he ever
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Page 224
say that to you?
A. Can you read that back again?
Q. Did Mr. Randolph say if they are truly
settlement negotiations and not discussions relating to
future litigation or threatened activities, that it
would be privileged communication?
A. No.
Q. So Mr. Randolph didn't say that to you?
A. No.
Q. And did he say, "I advise, to the extent they
are settlement negotiations, even those could be shared
with our client and with other members of our law firm."
Did he say that to you?
A. I think he did. I think he did. Or some --
or something akin to that. I think so.
Q. Did you say, "Well, you can't go to the Palm
Beach Post," and Mr. Randolph responded, "Yes."
A. Responded what?
Q. Yes. You said you can't go to the Palm Beach
Post.
A. He responded yes. Yes, I did.
Q. Yes. Yes. Based on the fact if there are
going to be settlement negotiations, not discussions
about future litigation or threats.
A. I'm still confused.
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Pagc 225
Q. Did you ever mention the Palm Beach Post
during this?
A. No. Not that I remember.
Q. And did you begin by dropping the motion that
Joanne and I filed, and asking whose brain child was
this?
A. I threw them both on the table and I said,
"Whose brainchild was this ?"
Q. Did you do that?
A. Yes, I did.
Q. And Mr. Randolph said it was signed by, both,
our firm and the Sweetapple firm, right?
A. Yes.
Q. And you asked if I felt -- if Mr. Randolph
felt it was appropriate to bring family into this
dispute.
A. I don't remember that.
Q. And did he -- then did you say that once we
have attacked his family that we have crossed the
Rubicon; that the damage has been done and there was no
way to rectify it.
A. Can you read --
Q. Did you say at the meeting --
A. Can you read the prior statement back along
with that, please?
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Page 226
Q. Did you indicate that once we have attacked
his family, that we have crossed the Rubicon. Did you
ever state that?
A. I said can you read the prior, and that.
Q. You asked whose brainchild was this when
i'i� sl
A. After that.
Q. Okay. And you asked if I felt it was
appropriate to bring family into this dispute.
Did you ask that?
A. I thought you said Mr. Randolph said that.
Q. No, you said that. You asked if he felt it
was appropriate to bring family into this dispute.
A. I never said that.
Q. Did you ever say that once we have attacked
his family, we have crossed the Rubicon; did you ever
say that?
A. Whose family?
Q. Your family.
A. No.
Q. And so you never said that we have crossed the
Rubicon?
A. I don't recall saying we crossed the Rubicon.
Q. Did you ever say the damage has been done,
there was no way to rectify it.
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Page 227
A. No. Because we went there and we made it
clear we were there for settlement purposes. And the
only reason we would be there for settlement purposes
would be to rectify.
Q. What were you trying to settle?
A. Whatever case was there and whatever cases we
could, and your -- what is it called -- the motion that
you prepared. And when we tried to do that, it was
clear that Ms. O'Connor never even read it.
Q. She never read the motion?
A. Never read the motion.
Q. Did she tell you that?
A. No. You can tell because I asked her a couple
of questions on there. And she -- I thought it was
pretty clear that she didn't read it. And Skip
Randolph, I think he acknowledged -- my recollection is
that he acknowledged he didn't read it.
Q. Skip Randolph said he didn't read it?
A. I said I think he acknowledged he didn't read
it. I think I said to him, "Skip, did you read this
piece of junk ?"
Q. And then you asked if I had children. You
asked Mr. Randolph if he had children, right?
A. No.
Q. Did you --
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Page 228
MR. DESOUZA: Bob, hold on. Just for my
purposes, are you representing these are quotes in
the transcript?
MR. SWEETAPPLE: Yes. These are -- this is
Mr. Randolph's memo, and I have Ms. O'Connor's
memo, exactly what was said at this meeting.
MR. DESOUZA: I didn't know if you were
representing these as quotes.
BY MR. SWEETAPPLE:
Q. You asked whether Mr. Randolph had children,
right? And he indicated, yes, he did.
A. Well, again, you have to look at it in the
context. You can't take it into context. What I said
to him is something like, it's a shame that we have to
get the children involved. It's a shame.
And what Skip said to me is, Well, your son is
different. He is the one who's the plaintiff in these
cases."
And what I said is, "Well, if he's a plaintiff
in these cases, what does that have to do with trying to
take his license away from him? What does that have to
do with that ?"
Q. Your son is not the plaintiff in the case, is
he? He's a lawyer in the law firm.
A. No. What he was saying is that he -- in other
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Page 229
words, his firm -- and it was made very clear to me
then, it is very clear to me now that you want to go
after my son because you can't handle big daddy.
Q. Mr. O'Boyle.
A. We'll see.
Q. Mr. O'Boyle, did you ever say that you had
millions of dollars, and you would be willing to spend
millions of dollars in responding to this issue?
A. Never.
Q. Did you say if you think you've seen a lot of
activity from them now, you haven't seen anything yet?
A. I've seen a lot of activity from --
Q. If you haven't -- if you think you were seeing
a lot of activity, you haven't seen anything yet.
A. No.
Q. And did you say -- did you ask Mr. Randolph if
A. I don't think so.
Q. And Mr. Randolph responded "yes."
A. Could be.
Q. And then you said that your wife was going to
bed each night crying and how she got up this morning
and suggested that Marty hire a slew of private
investigators.
Did you ever make that statement that your
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Page 230
wife was going to bed crying at night and suggested that
morning that Marty hire a slew of private investigators?
A. She did -- she was going to bed at night
crying, yes, because of your activities. Now, as far as
private investigators, I don't really recall that. I
really don't. On the other hand, my opinion, it may not
have been a bad idea. But certainly we didn't do it.
Q. And did you then say to Mr. Randolph, you
needed to only hire two private investigators because
you have two targets?
A. Who were the two targets?
Q. Did you ever say you only need two private
investigators because you have two targets?
A. I don't think so.
Q. He asked you what you meant by that, and you
refused to explain. Did that occur?
A. My recollection is there were a couple of
points during the discussions that he asked me -- that
he asked me, and that I didn't answer him. But I don't
remember it here about two PIs.
Q. Did you ever make reference to any of the
attorneys' daughters?
A. No. I asked Miss -- I'm going to say
Ms. Morgan. I'm sure that's not it -- who's the girl
sitting next to you?
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Page 231
MR. SMITH: Ms. O'Conner.
BY MR. SWEETAPPLE:
Q. The one you said lied in federal court?
A. Yeah. Her.
Q. You don't know her name?
A. I just told you no.
Q. And what lie do you believe she said to
Mr. Middlebrooks -- Judge Middlebrooks.
A. She can read the -- she or Mr. Thrasher can
read the transcript. And now -- and if I get a chance,
if you'd like, I can read the transcript and I would be
glad to send it to you, Mr. Sweetapple, if counsel will
allow me to do so.
Q. I'm sorry. You said she lied to Judge
Middlebrooks.
A. Yes.
Q. Can you tell me what the lie was that you've
made such a terrible assertion of this member of the
bar?
A. Yes. Of that member of the bar she lied to a
federal judge. What she said is that the town allows
these type of signs, and I don't remember exactly what
type of signs.
But the town does not allow those type of
signs, and she lied.
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Page 232
Q. So she had an opinion of the law as to what
the town allowed, and you said that's a lie?
A. No. She didn't have an opinion on law.
Q. She was giving her opinion on what the town
allowed.
A. That's what you said.
Q. That's what you just said. I'm just quoting
you.
MR. DESOUZA: I don't think he said the "word
opinion of law." Why don't we just move on.
BY MR. SWEETAPPLE:
Q. And you indicated earlier that I have defamed
you. How have I defamed you?
MR. DESOUZA: I don't recall him saying that,
but...
BY MR. SWEETAPPLE:
Q. You did. You said I defamed you and you sued
me for defamation. Tell me how I defamed you.
A. Do you have the Complaint?
Q. You tell me how I defamed you, please.
A. I want you to read the Complaint.
Q. Can you tell me?
A. I'm not going to.
Q. You don't know?
MR. DESOUZA: That's not what he said.
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Page 233
THE WITNESS: You read the Complaint.
BY MR. SWEETAPPLE:
Q. Is there something you believe I said about
you that's untrue, Mr. O'Boyle?
A. You're going to read the Complaint and you
will find out.
Q. So you can't tell me as you sit here?
A. I just told you --
MR. DESOUZA: That's what he said, Bob.
BY MR. SWEETAPPLE:
Q. Did you ask Ms. O'Connor whether O'Connor was
her maiden name?
A. Yes, I did. And the reason I did, just -- I
don't think I asked her what her maiden name was. We
had run a Lexus -Nexus report, and it showed the name
like Boecker, B- o- e- c- k -e -r.
I asked Ms. O'Connor -- I got her name right
that time -- I asked Ms. O'Connor if Boecker was her
maiden name. She said, "No, that was my first husband's
name from my first marriage." That's where that came
from.
Q. Did you ever tell Ms. O'Connor and
Mr. Randolph that the pleading that was filed was quote,
a piece of shit, it was full of shit and that, you,
Mr. O'Boyle would get back at us for it. Did you ever
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say that? Page 234
A. No. But I'm certain I said it was a piece of
shit.
Q. Did you ever say you would get back at us for
it?
A. Never.
Q. So Mister --
A. I certainly had plenty of time since then.
Q. So Mr. Randolph is not telling the truth in
his memo here.
A. I have no idea what Mr. Randolph is -- wrote,
didn't write, says, didn't say. I'm just telling you
what I know.
Q. Did you ever say that you're not a violent
man; and that you've never been in a fistfight and
you've never touched anybody, and hold up your hands
while you said that?
A. Exactly. Let me give you the context of that.
I said, "Why do we have to get the kids
involved? It's crazy to get the kids involved."
I said, "The problem is, somebody is going to
end up getting hurt."
Q. Well, you --
A. I said, "Now, I don't mean violent, because
I've never touched anybody with these hands. Never
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Page 235
touched a human being with these hands." And that's the
extent of the way the conversation went.
Q. You got your son involved by having him move
a -- allegedly Pennsylvania law firm into your building,
and feed him hundreds of cases in a foundation that you
were funding, right?
MR. DESOUZA: Objection.
BY MR. SWEETAPPLE:
Q. Didn't you get him involved?
MR. SMITH: Objection. Augmentive.
MR. DESOUZA: Objection. Asked and answered.
He is not going to answer it again.
.. SWEETAPPLE:
Q. You called me a criminal with regard to the
way I treated your son. Do you think that the way
you've treated your son is appropriate here,
Mr. O'Boyle, or are you ashamed by what you've done?
MR. TAYLOR: Objection. Argumentative.
MR. DESOUZA: Objection. Argumentative.
BY MR. SWEETAPPLE:
Q. Do you realize that you have put your son in
an untenable position by having his firm serve as your
attorney so that your animosity and hatred and
vindictiveness can be served?
MR. DESOUZA: Hold on. Objection.
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Page 236
Argumentative.
MR. SMITH: Don't answer that question.
MR. DESOUZA: Marty, hold on.
MR. SMITH: Really, Bob.
MR. DESOUZA: Why don't you ask him an actual
question and answer instead of your argument asking
if you agree with it.
THE WITNESS: He can't.
BY MR. SWEETAPPLE:
Q. Did you tell Mr. Randolph and Ms. O'Connor
that you had properties in Gulf Stream and that you were
going to turn them into sober houses?
A. No. This was towards the end of the
discussion. And I don't remember exactly, but I
remember I used the word "landscaper." And Skip
Randolph went like a rocket in the air, and he said,
what have you got against landscapers? What is wrong
with a landscaper?
I said, "Whoa, whoa. Nothing is wrong with a
landscaper. But you wouldn't hire a landscaper, as an
example, to do brain surgery."
And then as we neared the end, I said, "you
know, maybe what I'll do is this. Maybe what I'll do is
just go ahead and put a sober house in the town, and
that will be it."
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Page 237
When I said that, the meeting abruptly ended.
They made it clear to me that handicapped people in the
Town of Gulf Stream, they better not show up there,
because they're not going to go anywhere, so...
Q. What did they say to you? Who said what to
you on that?
A. Mr. Randolph and Mr. Morgan and Mr. Thrasher.
They clearly --
Q. At this meeting -- this meeting was --
A. This meeting.
Q. We're talking about a meeting that took place
on June 4th between four people.
A. Right.
Q. And you were describing that to me and all of
a sudden you went into this --
A. What do you want to know?
Q. -- fantasy. I would like you to stick on the
topic.
A. It's not a fantasy, sir, and don't -- don't
start.
Q. Mr. O'Boyle, you were talking about a meeting
with four people. Okay? And I asked you whether or not
you said that you were going to turn properties in Gulf
Stream into sober houses. What was said in response to
that?
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Page 238
A. And I answered your question.
Q. Did Ms. O'Connor or Mr. Randolph respond to
A. Mr. Randolph told us to leave the building.
He said, "This meeting is over. Leave the building."
Q. And didn't you bring up the fact that Bill
Thrasher was supposed to be fired?
A. Bill Thrasher was certainly supposed to be
fired. He was supposed to be fired. I may have -- I
don't know if I brought it up at that meeting, but John
Worthline wanted to fire you. George Elmore. Tom
Ladony (phonetic). Marty O'Boyle. Jonathan O'Boyle.
That's five. And heck, I can't remember the other two
or three.
Q. At that meeting on the 4th of June, did you
say that you wanted Mr. Thrasher fired?
A. No. What I said was -- and I don't know how
we got on the subject. But we were talking about the
agreement we currently have. And he said, you breached
it. I said, breached it? What do you mean I breached
it? How could I have breached it? You breached it.
He said, how did we breach it? And I told
them that you were supposed to fire Bill Thrasher.
Joan, George Elmore, Tom Ladony, myself, Skip Randolph,
my son, and one or two others.
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Page 239
He said, "Well, you know that Joan doesn't
have the authority to do it on her own. She has to come
to the commission."
I said, "Yeah, I do know that."
He said, "Well, then, how could there have
been -- how could we breach the settlement agreement ?"
I said, "She never tried. She never even
tried."
Q. So you want Mr. Thrasher fired.
A. Oh, yeah. I would love to see him fired. He
should be fired.
Q. That's one of your goals.
A. Well, I wouldn't say it is one of my goals. I
think he should be fired to save the town a fortune.
Q. That was one of your platforms when you ran
for office, right?
A. Pardon?
Q. That was one of your platforms when you ran
for office?
A. Same as Mr. Morgan. Me and Mr. Morgan, same
thing. He said Mister -- Maybe it's time for
Mr. Thrasher to do his victory lap. Maybe his time has
passed and so on and so forth. So don't let him kid
you.
Q. So you made it -- it's your desire to have
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Bill Thrasher fired, right? rase zaa
MR. DESOUZA: Objection. Asked and answered.
BY MR. SWEETAPPLE:
Q. You've publicly stated repeatedly that you
goal is to have Mr. Thrasher fired, right?
A. Never. No.
Q. And you, at this meeting, stated that you
believe that the town was obligated to fire -- breached
a settlement agreement to fire Mr. Thrasher.
A. I said they breached the settlement agreement
by not firing Mr. Thrasher. That's exactly what I said.
Q. Is there any written settlement agreement that
required Mr. Thrasher to be fired?
A. No. But if you want to say George Elmore has
no credibility; you want to say that Skip Randolph has
no credibility; you want to say that Tom Ladony has no
credibility. I'm sure you will say I have no
credibility. But there are a few others as well.
Q. And immediately after leaving this meeting,
did you -- strike that.
Did you have permission from the O'Boyle Law
Firm to participate in this meeting on June 4th?
A. Yes.
Q. And who gave you that permission?
A. Bill Ring. I was with him.
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Debra Duran & Associates
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Page 241
Q.
Bill Ring was not at the
O'Boyle Law Firm at
that time.
He was not a member of
the law firm.
A.
I think he was.
Q.
When did he join the law
firm?
A.
You have to ask him.
Q.
I'll look at my chronology and I'll tell you.
(Discussion held off the
record.)
A.
I'm talking about cabs.
MR. DESOUZA: It's going
to be hard to
converse with you and take it
down at the same
time.
BY MR. SWEETAPPLE:
Q.
And is Mr. Ring employed
by the O'Boyle Law
Firm now?
A.
To my knowledge, yes.
Q.
And he gets remuneration
from them?
A.
To my knowledge, yes.
Q.
None of your entities employ him directly?
A.
I don't think so. But I
don't know. I mean,
again, I don't know.
Q.
And on June 19, didn't Mr. Ring e-mail
Mr. Chandler
and indicate he was going to become a
partner in
the firm, June 19?
A.
I don't know.
Q.
So when you were at this
meeting, was Mr. Ring
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Page 242
a member of the O'Boyle Law Firm or not?
A. Was what?
Q. Was Mr. Ring a member of the O'Boyle Law Firm
or not on June 4th at that meeting?
A. I'm assuming he was. If not, I'm assuming he
would have spoke to the appropriate people.
Q. And --
A. Whoever they may be.
Q. What settlement offer did you believe you made
at this meeting?
A. Well, I think it was a sort of a global kind
of settlement to talk about what do we have to do. The
first thing we did is we went in and we said -- I said
this meeting is for settlement purposes only, and for no
other purpose.
And Mr. Randolph, said, well, wait a minute
now. What if, you know, we talk about something else?
And I said, well, of course we're going to talk about
something else. I mean, we may digress and talk about
what we had for dinner last night. This is a settlement
conference.
And then he and Bill Ring went back and forth
quite a bit. And then I said to Bill, are we resolved?
And he said, yes.
And that's when we started the meeting. So if
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Page 243
not, I would have never -- I would have walked out of
the meeting. I would never have went into the meeting
without it being a settlement conference.
And what we did, I think the first thing we
talked about was your -- I don't know what you call it,
your motion. And we explained that it was a bad motion;
that there was no factual basis to it, and we were going
to -- if we didn't already. When I said "we", I don't
mean me as a lawyer, I want everybody to know that.
"We", meaning I was there; that we were going to file a
157, whatever it is called, sanction.
(Interruption.)
THE WITNESS: 157 sanction. And what we'd
like to try to do is get rid of this thing. And
then once we do, to talk about some of the other
things and how we might resolve them.
And as I recall, the way Joanne had signed
this, and she looked like she had buyer's remorse,
but I can't tell her facial expressions. But we
filed the sanctions, for sanctions, and her and
Skip withdrew the motion.
Because I think what happened was Skip
probably said, what is this all about? And
guessing now -- I shouldn't -- but in any event,
that was sort of the way it went. We talked about
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Page 244
the children, getting the children involved, which
is just plain stupid to get the children involved.
After all, your daughter is going to be a
lawyer very soon. How would you like if I put a
private detective on your daughter? I wouldn't do
it and I won't do it, but how would you like that?
Q. If my daughter engaged in the activities that
you and your son had engaged in, I would expect that
appropriate ramifications would occur. We have laws in
this state with regard to who practices law, how we
practice law --
A. How we get DUIs.
Q. Right. Exactly.
MR. DESOUZA: You don't need to make
statements back and forth.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle.
MR. DESOUZA:
BY MR. SWEETAPPLE:
Just questions and answers.
Q. Mr. O'Boyle, you're the one that put your son
in this position, not me.
A. You already told me that.
Q. And I'm sure it will be like your daughter's
DUI, the whole world will responsible but not you
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Page 245
because you're never responsible.
MR. SMITH: Bob -- objection.
MR. DESOUZA: Objection. Let's take a break.
At this point there is nothing beneficial going on
here.
MR. SWEETAPPLE: Let's take a break and as
long as you need. I'm about to go into the motion
to disqualify and the motion for sanctions and the
specific evidence.
MR. DESOUZA: Great.
THE VIDEOGRAPHER: The time is 4:20 p.m.
We're going off the record.
(At 4:20 p.m. a brief recess was had.)
THE VIDEOGRAPHER: The time is 4:36 p.m. We're
back on record.
BY MR. SWEETAPPLE:
Q. All right. As far as this meeting that
occurred on June 4th, did you or Mr. Ring make any
settlement proposal?
A. Yes. In a general way.
Q. What did you propose?
A. We proposed, first of all, to get rid of that
motion; the one that we said, "whose brainchild was
this." And then we talked about the other -- I think we
talked generally about the other lawsuits.
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Q. What proposal did you make to settle? Page 246
A. I think we talked about resolving and getting
rid of the motion as a condition precedent to then going
in and talking about the various record suits.
Unfortunately, we didn't get beyond that part.
Q. So there was never a formal settlement offer
made by either side?
A. I wouldn't say that.
Q. Was there a formal settlement offer made by
either side?
A. I think so.
Q. Who made a formal offer?
A. I think we did.
Q. What did you offer to do to settle -- to
settle all the cases?
A. I think what we said was that this motion is a
piece of garbage.
Q. You said it was a piece of shit, actually.
A. Piece of shit. You're right. I did say it
was a piece of shit. I'm glad you recognize it as such.
Q. I don't. I don't think the people that review
this are going to recognize it as that either.
A. Okay. But in any event, we talked about
getting rid of that. And then we talked about, I think,
how many other suits there were pending. And let's see.
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Page 247
If we can get rid of this and let's address that.
Q. And so you were unable to meet the condition
precedent, correct?
A. No. No. You were unable to -- unwilling to
meet the conditions precedent.
Q. When you say "you ", you're talking about
Mr. Randolph and Ms. O'Conner?
A. Yes. Uh -huh.
Q. So you never got to the issue of a global
A. Well, I wouldn't say that. I would say that
we started off talking about the motion. That's where
we started. And then you sort of migrate, and sometimes
after that happened, there's no telling where it would
have went, this way, that way, the other way. This was
the main event in our eyes.
Q. So you wanted to get rid of the motion?
A. Yes.
Q. What were you willing to do if they got rid of
the motion to settle the litigation?
A. Well, they were willing to -- hopefully,
figure out a way to get rid of the records suits.
Q. All the lawsuits?
A. Well, I don't know, because we didn't get that
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Page 248
Q. Well, did you have a proposal in mind when you
went to that meeting to settle?
A. I think we -- the proposal that we had in mind
was to start with that motion. And that's exactly what
we did.
Q. You wanted the motion to be withdrawn and then
you were going to just discuss settlement?
A. That's the way that I'm familiar with how you
make a settlement.
Q. Well, normally you have a proposal in mind.
What was your proposal to settle all the cases?
A. Normally you may have a proposal in mind. I
do it my way, you do it your way. I told you the way I
do it, and let's move on.
Q. I'm just trying to understand what happened
because I haven't heard of a settlement proposal from
you and I haven't heard a settlement proposal recounted
in your testimony from Ms. O'Connor or Mr. Randolph.
I heard you call it a settlement conference.
Were there any proposals made by either side to settle
the litigation?
A. We made it clear that when we got there, that
the meeting was for settlement purposes only and for no
other reason. No other purpose. And then we talked
about the motion, and then it meandered a little bit
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Page 249
here and there. And then when it was clear that the
motion was not going to be resolved, then we talked
about some other things.
And then Mr. Randolph, when we talked about
handicapped people, he -- he shocked me. Handicapped
people and landscaper. He just shocked me.
Q. How did he shock you?
A. He asked us to leave. Shocked me. I mean, I
would never expected a Jones Foster lawyer to
discriminate against handicap people like that.
Q. What did he say to you that you thought was a
discrimination?
A. I'm trying to think for a second. When I
raised the sober house, I said, well, maybe what I'll do
is just put in a sober house down there. And he just
said, This meeting is over. Go ahead and leave. It's
over."
Q. That's all that happened?
A. Well, no. It was -- the meeting probably
lasted an hour and 45 minutes.
Q. I'm talking about the subject of you said he
discriminated against handicapped people. Did he say
something? He just said the meeting is over?
A. Well, no. But it was based upon a sober house
which is handicapped people.
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Page 250
Q. Well -- and you think that he didn't just
terminate the meeting because it was clearly your only
reason for being there was to try to intimidate and make
demands?
MR. DESOUZA: Objection.
THE WITNESS: First of all, I didn't try to
intimidate. Secondly, I didn't try to make
demands. Thirdly, if either of those two were his,
that was his goal, he would have said it long
before I ever raised the word sober house.
BY MR. SWEETAPPLE:
Q. And had you been thinking about opening sober
houses before that meeting?
A. I had been thinking about it, and thinking as
we sit here right now.
Q. Okay. And were you threatening that to the
town to try to get them to do something? Why did you
say that?
A. I just said it.
Q. Was it a threat?
A. No.
Q. Why were you bringing that up at that time?
A. I'm not sure. We may have -- we talked about
something in advance to that. And I remember a
landscaper. I raised a landscaper. So I don't
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Page 251
remember, but that is my recollection of what happened.
Q. Were you threatening that you were going to
open a sober house if the town didn't stop pointing out
the allegations regarding your son's law firm?
A. Well, it has been four months. Have I opened
up a sober house?
Q. Well, let's talk about that. Two days later
after the meeting you went to the town and gave them a
letter. If you'll mark this next, please.
(Defendant's Exhibit No. 16 was marked for
identification.)
Q. The next date, June 5th, you had a banner
flown, didn't you?
A. I don't know.
Q. Well, didn't you have a banner flown that says
"Jones Foster clients check your bills ?"
A. I think I had a banner flown that said that.
I don't know if it was the next day.
Q. Well, you don't -- did you -- are you the one
that arranged that banner?
A. Indirectly, yes.
Q. Indirectly, you mean you told someone to do
it?
A. Yes.
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Q. Who did you tell to do it? Page 252
A. I don't know.
Q. And what airline, what company did it?
A. I don't know.
Q. And who wrote the language, "Jones Foster
clients check your bills ?"
A. Probably me.
Q. And why did you have a banner that said,
"Jones Foster clients check your bills ?"
A. I thought, and I still think, that this whole
crowd is out of control. Jones Foster's bills went from
3 or 4,000 a month, to 50 -- 45, 50,000 a month, which
is awful high. And I think it is good for the people,
good for the town, good for everybody, for people to
check their bills.
Q. Weren't you implying that Jones Foster clients
were being ripped off in their billings?
A. No. You must -- you have a dirty mind.
Q. Isn't that a normal -- you said clients, Jones
Foster clients. You didn't refer to the town. You
referred to their clients.
A. Yes.
Q. So you wanted their clients to check their
bills?
A. Yes.
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Page 253
Q. You don't think it's a reasonable
interpretation that that is an implication that Jones
Foster somehow is overbilling their clients?
A. No.
Q. And you didn't intend to create that
impression when you had that banner flown?
A. No.
Q. So a jury shouldn't reasonably think that that
was a statement implicitly that Jones Foster is, in its
bills, ripping off its clients?
MR. DESOUZA: Objection to form.
THE WITNESS: No. Not at all.
BY MR. SWEETAPPLE:
Q. And then the next day you had a banner flown
up and down Palm Beach County; are you aware?
A. No.
Q. Do you remember it?
A. No.
Q. Do you recall there was a bar installation
meeting at the Breakers?
A. No.
Q. And you had a banner fly that said "JF don't
drink and drive, we'll be watching." Do you remember
that?
A. I remember the banner. I don't remember it
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Page 254
even going near the Breakers.
Q. Well, did you direct -- do you direct where
these banners go, where the planes fly?
A. Generally stated I would say yes.
Q. So where did you -- who do you talk to about
where you want the planes to fly?
A. My secretary.
Q. Okay. And where did you say you wanted the
"JF don't drink and drive we'll be watching" banner?
A. I don't remember. But it was between point A
and point B.
Q. So you don't remember the specifics of it?
A. No.
Q. And what about the "Jones Foster clients check
your bills." Did you give her a geographic area for
that?
MR. DESOUZA: Object to form.
BY MR. SWEETAPPLE:
Q. A geographic area to have the planes fly?
A. Yeah. The answer is -- I don't recall. I
mean, I just don't recall.
Q. And on June 6th, that same day that you had
the "JF don't drink and drive, we'll be watching you,"
you were doing this out of anger because Jones Foster
wouldn't dismiss the motion regarding disqualifying the
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law firm, right? Page zss
MR. TAYLOR: Object to form.
MR. DESOUZA: Same.
THE WITNESS: I thought you were a lawyer, not
a psychiatrist.
BY MR. SWEETAPPLE:
Q. I'm just asking you a question. That's really
why you did it.
A. Don't tell me about me being -- about anger.
Q. Well, I can lead my questions. What was your
motivation if it wasn't anger?
A. Why don't you read me your question again.
Q. When you had these two banners flown, was it
done out of anger?
A. No.
Q. Was it done for the purpose of retaliating?
A. No.
Q. Why was it done? Why was it done immediately
after this meeting that Mr. Randolph carefully details
in his two - and -half page memo?
MR. DESOUZA: The two- and -a -half page memo
that you're saying he carefully detailed that
you're not going to share with us?
MR. SWEETAPPLE: I'm going to wait to see if
you decide if this was a settlement meeting or not,
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Page 256
because if you take the position with the court
that it's a settlement meeting, I don't think
you're entitled to it.
If you admit it's not a settlement meeting, I
think you are. So I guess we'll have that
discussion before the judge when you decide what
side of the bed you're on. Your client seems to
think it's a settlement conference. I don't, but
we'll have a debate about it.
MR. DESOUZA: Bob, I'm simply referring to
your statement that Mr. Randolph carefully detailed
something you haven't shared with us.
MR. SWEETAPPLE: I read you excerpts from it
and you'll see Ms. O'Connor has one that is
remarkably similar to it. And contrary to
Mr. O'Boyle's statements, I know the both of them
to be ethical people. But anyone who relies on
Mr. O'Boyle's judge of character does so at their
own risk, I suggest.
MR. TAYLOR: You don't need to respond when
all he is doing is giving a speech.
MR. DESOUZA: Marty.
MR. SWEETAPPLE: I have sat here and listened
to him tell me my co- counsel lied to federal
judges.
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Page 257
Let's talk about this letter, Exhibit 16. You
wrote --
MR. DESOUZA: Hold on. Is this a one -copy
letter? Can I see it?
MR. SWEETAPPLE: Yes, you can.
MR. DESOUZA: Thank you. Do you have an extra
copy of this, or just the one?
MR. SWEETAPPLE: I do not. Apparently,
Mr. O'Boyle says it is floating all around Gulf
Stream. And he filed a lawsuit over that. It
concerns him that this letter would be floating all
over Gulf Stream.
MR. DESOUZA: Joanne, you have the letter?
MS. O'CONNOR: Yes. I'll get it.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle, do you recognize that letter?
MR. DESOUZA: It's not in front of him at this
point. Skip has it right now.
MR. SWEETAPPLE: Okay.
MR. SMITH: What is it? Six --
MR. DESOUZA: June 6.
THE WITNESS: Yes.
BY MR. SWEETAPPLE:
Q. Did you deliver this letter to the Town of
Gulf Stream?
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Page 258
A. May I?
Q. Sure.
A. It was delivered from my office. It appears
to be from my office.
Q. So it was not delivered by hand, it was
delivered electronically or by fax?
A. I would say so.
Q. Okay.
A. Not faxed.
Q. And so you made -- you personally made the
decision to form a company to acquire houses in Gulf
Stream for use as sober houses. "I intend to begin the
implementation of this program forthwith," right? Is
that what you stated in the letter?
A. You're reading it, not me.
Q. Is that what you stated in the letter? And
did you, in fact, on June 6, two days after the meeting
with Mr. Randolph and Ms. O'Connor, form a company for
the purpose of opening sober houses in Gulf Stream?
A. I don't know.
Q. Did you direct Mr. Ring to form a company by
the name of Sweet Apple Sober Houses, LLC on June 6?
A. No.
Q. 2014?
A. No.
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Page 259
Q. And the registered agent is indicated to be
William F. Ring, Jr. He is your attorney, right?
A. He is -- you can say he is my attorney, yeah.
Q. He was the attorney who was with you at the
meeting where you threatened to open sober houses,
right?
A. I didn't threaten anything.
Q. That's where you stated you were going to open
a sober house. He was the lawyer that was with you at
that meeting, right?
A. How about if I was going to open a hamburger
Q.
Mr.
Ring
was with you at that meeting, right?
A.
Is
that a
threat?
Q. Was Mr. Ring in the vicinity of you when you
said you were going to open up a sober house?
A. I don't know if he was or not.
Q. And after that statement was made,
Mr. Randolph asked you to leave his office, right?
A. Yes.
Q. And within two days, Mister -- who actually
filed the Sweet Apple Sober Houses, LLC, Florida Limited
Liability Company articles with the Secretary of State?
A. I don't know.
Q. Did you ask that it be done?
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A. Did I ask that it be done? Page 260
Q. Did you ask the secretary like Ms.
De Larmartini or someone to do that?
A. I would say yes.
Q. Who did you ask to do it?
A. I don't know.
Q. Was it Ms. De Larmartini?
A. I have no idea.
Q. Did you ask Mr. Ring if he was willing to be
the registered agent?
A. No.
Q. How did Mr. Ring's name get put on as the
registered agent?
A. We probably put it there.
Q. Without his permission?
A. Yes.
Q. Yes?
A. Yes.
Q. Since I filed the motion for sanctions, has
Mr. Ring asked to have his name removed as a registered
agent?
A. I don't think he knows it's there.
Q. Well, the motion was served on him and it
makes reference to this application. Do you know, has
Mr. Ring ever discussed with you -- have you discussed
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Page 261
with Mr. Ring the fact that his name is a registered
agent?
MR. DESOUZA: You can answer yes or no. I
don't want you to get into the substance of
conversations. You can answer whether you
discussed it or not.
THE WITNESS: What was your question again?
Q. Did you tell Mr. Ring you were putting his
name in as registered agent?
A. I don't recall that we did. That I did.
Q. You listed yourself as the manager, correct?
A. I don't know.
Q. And why did you pick the name Sweet Apple
Sober Houses, LLC? Was it in any reference to me?
A. It was a reference to -- the town was highly
objectionable to having sober houses. You, I thought,
were taking the position with the town that you were --
you're going to break them. And I thought we would put
that -- we would use that for a name, and that would be
the name. It was funny. And that ended up being the
name.
Q. So you did it because it was funny and you
thought I was taking the town in a way that would break
them?
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Page 262
A. I think that you're going to end up breaking
the town is what I -- if I didn't make that clear,
that's what I think.
Q. So that's why you put my name on the sober
house company?
A. No. No. What I said was, you have to take
the two of them together. And I took the two of them
together. And I thought that it was a combination that
would knock everybody down a notch or two. I thought it
was funny. Besides all of that, it is something that
the First Amendment of the constitution allows me to do.
Q. That's your legal conclusion?
A. Yes, it is.
Q. Okay. And so the purpose was to knock people
down a notch or two?
MR. DESOUZA: Objection. Misstates his
testimony.
. SWEETAPPLE:
Q. Did you say that was one of the purposes, was
to knock people down a notch or two?
A. No. What I said was that the town is out of
control. I think you're out of control. I put the two
names together, and we formed the company.
I thought it was funny. I thought it brought
smiles to people's face. And in addition, I thought
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Page 263
that it -- I thought -- I'm losing my train of thought
for a moment. Excuse me.
It would bring things down a notch or two, and
the First Amendment allows me to do it, so I did it.
Q. I guess we'll find out if the First Amendment
allows you to do it at some point.
A. Sure.
Q. But right now, what do you mean by "knock down
a notch or two ?" What are you referring to?
A. What I'm referring to is, when people get a
little high on their horse, you knock them down a notch
Q. So you use my name in order to knock me down a
A. I think so.
Q. In order to hurt my reputation to -- you
wanted to --
A. No, not at all.
Q. Did you want to affiliate me, my name as a
professional with your efforts to put sober houses in
Gulf Stream?
A. I wanted to layout the name -- can't think of
it now. Sweet Apple Sober Houses, because I thought it
was funny. I thought it would knock things down a notch
or two. Maybe make the people focus a little bit more.
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Page 264
Take a closer look. And I thought that it was not in
violation of the constitution, so...
Q. You don't think it's defamatory to put my name
with an activity that you believe is offensive to
residents of Gulf Stream?
MR. DESOUZA: Objection. Form.
THE WITNESS: It shouldn't be. If the -- if
the people of Gulf Stream are going to discriminate
against handicapped people, shame on them, starting
with the top down.
BY MR. SWEETAPPLE:
Q. What if I wanted to put a sign up in a house
next to your house in Gulf Stream that said Martin
O'Boyle's whorehouse? You think the First Amendment
gives me the right to use your name in conjunction with
whorehouse?
A. After I spoke with my counsel, I will give you
an answer.
Q. Did you get any legal advice from any lawyer
before you decided to use the name, Sweetapple Sober
Houses, with regard to your efforts to place a sober
house in Gulf Stream, Florida?
A. Well, you asked two questions there.
Q. Did you obtain any advice from any attorney
with regard to the issue of whether or not it would be
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Page 265
defamatory to associate my name with a sober house in
Gulf Stream, Florida?
A. Well, first of all, I don't think it's your
name, but put that aside for a moment -- because it is
two names -- when we designed the name, we designed it
with you in mind. So I will just tell you that.
Q. Who is "we", Mr. O'Boyle?
A. Me.
Q. You said "we". Who did you mean?
A. I know I said "we."
Q. You didn't have someone else that you did this
with?
A.
No.
Q.
Did you discuss it with your wife?
A.
No.
Q.
How about your son?
A.
No.
Q.
How about Mr. Ring?
A.
No.
Q.
Just you?
A.
Yeah.
Q.
So you had me in mind.
A.
Yes.
Q.
You wanted to bring me down a notch or two and
you thought it was funny.
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two or three.
Q. What about you? Do you think you have any
issues that maybe you need to confront?
A. No. But you're more than welcome, I would
invite you to utilize the First Amendment to take -- to
take any action that you wish that complies with
protect -- where you're protected by the First Amendment
against me. That's what it's there for and I would
encourage you to do it.
Q. Do you think you could open up something
called Sweet Apple's Whorehouse?
MR. DESOUZA: Objection.
MR. SMITH: Asked and answered.
MR. DESOUZA: Objection. You're asking him to
speculate at this point.
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Page 266
A.
Yeah, I
did think
it was funny.
Q.
And you
wanted to
bring
me down a notch or
two.
A.
Yeah.
I think you needed to go down a notch
or two.
Q.
And --
A.
And I think the --
Q.
And you
think the
First
Amendment protects
you?
A.
I think
these guys
need
to go down a notch or
two or three.
Q. What about you? Do you think you have any
issues that maybe you need to confront?
A. No. But you're more than welcome, I would
invite you to utilize the First Amendment to take -- to
take any action that you wish that complies with
protect -- where you're protected by the First Amendment
against me. That's what it's there for and I would
encourage you to do it.
Q. Do you think you could open up something
called Sweet Apple's Whorehouse?
MR. DESOUZA: Objection.
MR. SMITH: Asked and answered.
MR. DESOUZA: Objection. You're asking him to
speculate at this point.
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BY MR. SWEETAPPLE:
Page 267
Q. You're telling me your legal opinion as to the
First Amendment protects this. Did you give
consideration of whether or not you could say
"Sweetapple Unethical Law Firm" and put a sign up in
front of a building in Deerfield Beach? Just Sweetapple
Broeker and Vargas, rip -off lawyers. Do you think you
can put a sign up that said that, and that the First
Amendment protects you to do that?
A. The First Amendment protects you to do certain
things. Whether it protects you to do that, I don't
know.
Q. Do you think it protects you to directly or
indirectly defame people or to associate them with
businesses? You knew I had no association with this
business, right? I wasn't involved in this entity.
Strike that.
Did you believe that I had any involvement in
this company financially or otherwise?
A. I think I've answered the question multiple
times, and what I suggest is that we move on.
Q. Where would you like to move on to?
A. Wherever you would like.
Q. And after this letter was sent to the town,
did you become upset that people in the town obtained a
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copy of it?
Page 268
A. Well, I think -- no, not upset. It's just it
annoyed me, because when you send a letter to the town,
they are not to send it to their cronies to spread it
around and say O'Boyle is a bad guy. So several people
called me and told me they had a copy of it. So all I
wanted to do is find out who has got a copy and where
they got it from, and then I'll deal with it.
Q. Okay. Well, that letter was sent to the town,
right?
A. Yes.
Q. And it's a public record.
A. Yes.
Q. And anyone can ask for a copy of it.
A. I don't know about that, but, yeah, I think
so.
Q. Why couldn't anyone do like you do and go ask
for a copy of this letter?
A. I'm not answering that. I already answered.
Q. Didn't you expect when this letter was sent,
that it would become a public record?
A. What I didn't expect is that nobody would ask
for that public record and it be all over town. That's
what I didn't expect.
Q. How do you know no one asked for a copy?
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Page 269
A. Because they put their public records on line
and it isn't there. Mr. Thrasher wrote it in writing.
He said -- there hasn't been a written request. It's
Q. Are you saying that in order to request this
document under public records law someone would have to
do it in writing?
RANNINNUOV
Q. So why couldn't someone ask for this letter?
A. They could.
Q. And why couldn't it have been given to them?
A. They could. And after I take their
deposition, I'll know.
Q. Whose deposition?
A. Figure it out.
Q. You sued the town alleging that this letter
was disseminated improperly, right?
A. I don't think I said improperly, but maybe.
Q. You subpoenaed me because you want to know
what I know about how this letter was disseminated,
right?
A. Because it showed Mr. Thresher said it was
only disseminated to three people, he said to Miss -- I
can't think of your name again.
MS. O'CONNOR: O'Connor.
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Page 270
THE WITNESS: O'Connor, Mr. Randolph and you.
Q. So we got copies of this -- written copies of
A. Yeah.
Q. And you want my deposition because you don't
understand that any individual could walk in and get a
copy of this letter and, in fact, did?
A. That's not what I said.
MR. DESOUZA: Objection to form.
BY MR. SWEETAPPLE:
Q. We'll deal with that in your lawsuit.
A. We sure will.
Q. And you e- mailed Gordon Craft on June 15.
"Gordon, I feel no obligation to respond. I'm writing
to you now voluntarily. I have no intention of putting
a sober house in Gulf Stream for reasons inter alia.
"I wouldn't have a clue on how to run one. I
was, however, approached by an out of state company that
seems set on putting sober houses in Gulf Stream and the
surrounding areas, but only on the water in Gulf Stream.
For reasons unknown to me, they asked me to lead their
charge. They offered to pay me a very handsome sum.
I'm struggling with their offer whether to accept it or
not. As I said, it's a ton of money, and I know if I
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Page 271
don't take it, someone else will."
Did you write that e-mail?
A. I did.
Q. Why would it concern you that someone -- that
people in Gulf Stream would know of your stated
intention to open sober houses?
A. Because I think the hierarchy, the mayor,
Mr. Thrasher, I think they lie and I think they did it
in an effort to try to dirty me up. And all I want to
do is what I'm entitled to do, Mr. Sweetapple.
Q. Mr. O'Boyle, how would associating you with
your letter to open sober houses dirty you up?
A. You can ask them.
Q. I would like to know from you. You said you
didn't want this letter being disseminated because it
would dirty you up. Tell me how would it dirty you up?
A. It has been disseminated. People -- if you
read Mr. Kraft's letter, I think you'll learn a little
bit. It says there, "I can't believe you're going to
put a sober house. Your going to ruin the whole town."
So I think that gives you a little hint.
Q. So in other words, your neighbors got mad at
you because you were going to open a sober house.
MR. DESOUZA: Objection to form.
THE WITNESS: Let me tell you something. I
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Page 272
don't know whether my neighbors got mad at me or
not, but you know what? If my neighbors want to
discriminate against handicapped people and if the
mayor wants to and the town manager, to hell with
each other.
BY MR. SWEETAPPLE:
Q. Because you're going to open a sober house,
right?
A. We'll see.
Q. And you want to call it Sweet Apple's Sober
House?
A. I like that name. I do like that name.
Q. Good. We'll see how we deal with that,
Mr. O'Boyle.
A. Yeah.
MR. DESOUZA: Is that a question?
MR. SWEETAPPLE: No, that's not a question.
MR. DESOUZA: Great. Do you have a question?
BY MR. SWEETAPPLE:
Q. Which company, out of state company has
contacted you that has offered you money to open up a
sober house? Is that true or is that just something you
made up to further your intimidation?
A. No, it's true.
Q. What's the name of the company, Mr. O'Boyle?
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A. I think it was called Tin -- I think was Page 273
called Tin Turn Corporation, and they were out of -- I
think either Red Bank or New Silver [sic] New Jersey.
Q. And how did they contact you?
A. I guess one of my friends. I do have some
friends.
Q. Real friends?
A. Yeah. Yeah.
MR. DESOUZA: You don't have to answer that.
That is ridiculous.
THE WITNESS: Yeah. Probably mentioned that
I'm in Florida, I'm a real estate developer, and I
have some knowledge of high -end real estate.
BY MR. SWEETAPPLE:
Q. And who is it that contacted you?
A. I think it was called tin -- Tin Turn.
Q. And did they write you or call you?
A. They called me.
Q. Did they ever write you?
A. They may have.
Q. Do you have any a -mails from these people?
Any writings from these people?
A. I don't know.
Q. Who did you speak to there?
A. You know --
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Page 274
Q. You said they made an offer, very handsome
sum. How much did they offer you?
A. I think it was a quarter million dollars, the
project. I think.
Q. To get an approval or for the land, or what?
A. For -- to get it developed to where --
whatever had to be done. Go through the approval
process, and do whatever has to be done. I don't know.
As an example, maybe a bathroom has to have handicapped
facilities. It may have to -- I don't know.
Q. It was a very attractive offer, right?
A. I thought so.
Q. You were struggling with it, right?
A. I was struggling with it.
Q. Trying to decide if you could accept it or
not, right?
A. No. Trying to decide if I wanted to accept
it.
Q. So if you decided to accept it, who would you
contact to let them know you accepted? What's the name
of the person and the telephone number? Where do you
have that?
A. I don't know. I may have chucked it.
Q. So if I asked you in a request to produce for
the name of this supposed person that offered you a
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quarter of a million dollars and their contact
information, you think you chucked it?
A. We'll find out. You send a notice to produce
Q.
Do you
recall what
you did with it? Did you
ever write
that
information
down?
A.
I just
told you a
second ago that I didn't
know.
Q. I haven't asked you if you wrote it down. I
asked you if they wrote you. Now I'm asking you if
wrote this information down.
A. That's what you asked me. You asked me that.
And what I told you is the best I can tell you.
Q. Let's talk about the motion to disqualify the
O'Boyle Law Firm and in the alternative for an
evidentiary hearing, which --
MR. DESOUZA: The withdrawn motion?
MR. SWEETAPPLE: Well, it's going to be. It's
been, first of all, dealt with appropriately as
required by law. Second of all, it is going to be
an amended affirmative defense and counterclaim in
these cases, as well as be a part of other lawsuits
that are being filed.
But it has -- as the motion said, not been
abandoned. We decided we did not want to pursue
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the relief by just asking to have the law firm
disqualified. We want to seek more serious and
permanent relief.
MR. DESOUZA: I understand.
MR. SWEETAPPLE: Just a motion -- if you saw,
the motion was withdrawn without prejudice to all
the rights that are enumerated in that withdrawal,
which obviously we're obligated to pursue and we
will discharge all the law obligations.
MR. DESOUZA: And thank you for that. I was
just asking whether this is the withdrawn motion.
MR. SWEETAPPLE: Of course you knew that. You
saw that we withdrew it and said that's what we
were going to do. So again, you're editorializing
and being facetious. But that's okay. Let's go
through the motion that you said was shit,
Mr. O'Boyle.
MR. DESOUZA: Apparently, I'm editorializing
when Mr. Sweetapple has talked for hours in this
deposition just making statements without
questions.
MR. SWEETAPPLE: They're called leading
questions, Counsel. That is what I do with adverse
parties all the time. So I haven't heard a form
objection in five hours, and now you're giving
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speeches again about the depo. You haven't made
one form objection in five hours.
MR. DESOUZA: I tell you what. We go back
through the record and if you find a form objection
in the last five hours, do I get a prize?
Because I believe I have made several form
objections.
MR. SWEETAPPLE: When I'm leading the witness
you have never taken any objections to my making
statements and saying isn't that true. That's what
you do when you have an opposing party. That's how
you cross - examine, and that is how you're permitted
to depose an adverse party.
MR. DESOUZA: That's your 34 years of
experience talking, right?
MR. SWEETAPPLE: Yeah, you can lead.
MR. DESOUZA: Bob, I don't care what your
instructions are. Just ask your questions.
MR. SWEETAPPLE: Well, my question are
statements followed with "isn't that true" quite
often.
THE WITNESS: Listen to him. You'll learn.
MR. DESOUZA: I know --
MR. SWEETAPPLE: That's what I'm permitted to
do obviously. It should be clear. It should be
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Page 278
clear to you that is what you do.
THE WITNESS: You need to listen to him.
BY MR. SWEETAPPLE:
Q. Let's go back to the allegations regarding
your son, Mr. O'Boyle.
Was your son's firm originally called the
O'Boyle Law Firm and created in November 2013?
A. I don't know.
Q. Did it list with the Pennsylvania Department
of State its registered office address at 1001 Broad
Street, Johnstown, Pennsylvania, but no mailing address.
A. I don't know.
Q. Did you ever look at that? When you saw this
motion, did you ever investigate that?
A. Do you have any documents to show me? Then I
won't have to investigate it. We can resolve it right
now.
Q. I'm asking whether or not when you read
Paragraph 1 in the motion if you did anything to
investigate if the facts alleged in that paragraph were
true?
A. No, I didn't do anything.
Q. Did you speak to your son to ask him if the
facts were true?
A. No.
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Page 279
Q. Paragraph 2 says, "According to the Florida
Department of State, Division of Corporations, the
O'Boyle Law Firm PC, Inc., is a foreign profit
cooperation with a principal address in Deerfield Beach,
Florida. The corporation lists a mailing address at
2146 East Huntington Street in Philadelphia,
Pennsylvania."
Did you do anything to investigate whether
that paragraph was true?
A. No. But I do want to point out, that Kevin
Tyne (phonetic) who is an ethics lawyer, wrote to you in
connection with the inquiries that you made and said if
you have any questions to please contact him. Something
that you refuse to do. Go ahead.
Q. I'll be happy to show you my letter to him,
and his response which did not answer my questions that
I did pose to your son. In fact, it specifically
ignored numerous questions that I asked your son, and
did not dispute other assertions I made in my letter.
So we'll be happy to go over all that with you,
Mr. O'Boyle.
Let's go to No. 3. Do you want to answer with
regard to No. 2? Did you do anything to determine
whether or not the allegations in Paragraph 2 are true
or false when you got this motion?
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Page 280
MR. SMITH: I don't have the motion.
BY MR. SWEETAPPLE:
Q. I just read them to you.
"According to the Florida Department of State,
Division Of Corporations, the O'Boyle Law Firm PC, Inc.,
is a foreign profit corporation, with a principal
address in Deerfield Beach, Florida. The corporation
lists a mailing address at 2146 East Huntington Street
in Philadelphia, Pennsylvania."
Did you go and look at the Department of
State, Division of Corporation filing for the Florida
O'Boyle Law Firm PC, Inc., filing to see if that
statement was true?
A. I did not.
Q. Do you know if it's true or false, that
statement?
A. I don't know.
Q. Three. With regard to 2146 East Huntington
Street, Philadelphia, Pennsylvania, do you recognize
that address?
A. I don't.
Q. Is that an address where one of your children
resides?
A. Maybe.
Q. Is it where your daughter resides?
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A. It may be. Page 281
Q. You don't know for sure?
A. Don't know.
Q. Isn't it a townhouse in Philadelphia where
your daughter resides?
A. Don't know.
Q. Did Jonathan ever reside there?
A. Don't know.
Q. Did Jonathan ever conduct law out of that
location?
A. Don't know.
Q. Have you ever asked your son or your daughter
whether or not Jonathan, in fact, used 2146 East
Huntington as the address for the O'Boyle Law Firm?
A. Can you say that again?
Q. Did you ever ask your daughter or your son,
Jonathan, whether or not Jonathan ever practiced law out
of the address 2146 East Huntington Street,
Philadelphia, Pennsylvania?
A. Not that I can recall.
Q. And your son -- Paragraph 4 -- says that the
O'Boyle Law Firm PC, Inc., identified Jonathan R.
O'Boyle with an address of 2146 East Huntington Street,
Philadelphia, Pennsylvania as its president in its
filings with the Florida Department of State, Division
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Page 282
of Corporations. No other officers are identified.
Did you check the filing to see if there are
any other officers identified?
A. I did not.
Q. Prior to going to the meeting June 4th, were
you aware that your son indicated that the address of
his law firm was 2146 East Huntington Street,
Philadelphia, Pennsylvania?
MR. DESOUZA: Objection to form.
THE WITNESS: No, I was not.
BY MR. SWEETAPPLE:
Q. You were not aware he was using that address?
A. No.
Q. Did you believe that your son had a law firm
somewhere prior to or -- strike that -- in November or
December of 2013?
A. Can you say that again?
Q. Did you understand that your son had a law
firm somewhere in November or December of 2013?
A. I don't know.
Q. Did he ever tell you he had an office
somewhere?
A. I don't recall.
Q. Did you ever go to any opening of an office, a
party or anything for his office in
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November /December 2013?
Page 283
A. Not that I recall.
Q. Did you ever get an announcement that he had
opened an office anywhere in November or December of
2013?
A. Not that I recall.
Q. Did you ever get a business card that showed
an address and phone number for an office anywhere in
Pennsylvania in 2013 --
MR. DESOUZA: Objection form.
Q. -- for the O'Boyle Law Firm from your son?
A. Not that I recall.
Q. Did you ever see any stationary that your son
had prepared with the address 2146 East Huntington
Street, as an address for the O'Boyle Law Firm, PC?
A. Not that I recall.
Q. And did your son ever tell you that he was
practicing law with any lawyers in Pennsylvania as part
of the O'Boyle Law Firm?
A. Not that I can recall.
Q. Are you aware of any lawyers that practiced
law with your son in Pennsylvania in 2013?
A. Not that I can recall.
Q. Did he ever tell you he had a secretary in
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Pennsylvania?
A. Not that I recall.
Page 284
Q. Did he ever handle cases for you in
Pennsylvania or New Jersey in 2013?
A. I don't know.
Q. In Paragraph 5, I recited that, "However, as
of April 4, 2014, Pennsylvania has listed him as an
out -of- state - lawyer with an address at the home of his
father, Martin O'Boyle, at 23 North Hidden Harbor Drive
in Gulf Stream, Florida, and a telephone number with a
561 area code. Thus, as of April 4, 2014 the
Pennsylvania Supreme Court did not reflect that any
lawyer with the O'Boyle Law Firm actively practiced in
the state."
Did you do anything to determine whether or
not those allegations were correct?
A. I was unaware, and I don't have any knowledge.
Q. Were you aware that your son indicated on his
file with the Pennsylvania Bar that he was an
out -of -state lawyer and not practicing in the state of
Pennsylvania?
MR. SMITH: Object to form
THE WITNESS: Pardon?
MR. DESOUZA: Same.
MR. SMITH: Go ahead.
Argumentative.
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Page 285
THE WITNESS: I was unaware. I did not look
at the bar or whatever he was.
BY MR. SWEETAPPLE:
Q. When you received this motion, did you look at
any of the exhibits that were attached to it?
A. Probably not.
Q. So you just got enraged and didn't look at the
backup?
MR. DESOUZA: Objection.
BY MR. SWEETAPPLE:
Q. Did you get mad when you saw this motion for
the first time?
A. No. I realized who prepared it. How can I
get mad?
Q. So you just -- you weren't at all concerned
about it?
A. That's not what I said.
Q. So you just dismissed it because of who wrote
it.
A. That's not what I said either.
Q. Well, let me say this. Did you know that your
son, while he was telling -- strike that.
Were you aware that your son advised the
Pennsylvania Bar his address was your home address, 23
North Hidden Harbor Drive?
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Page 286
A. I have no knowledge.
Q. And were you aware that he provided the
Pennsylvania Bar with a Florida mobile telephone number
as his telephone contact?
A. No. But I think that's all right.
Q. Are you aware that the Florida Supreme Court
records as of April 4, 2014 did not reflect any lawyer
with the O'Boyle Law Firm actively practicing in the
state of Pennsylvania?
MR. DESOUZA: Florida records?
MR. SWEETAPPLE: Pennsylvania Supreme Court
records. Were you aware of that?
MR. SMITH: Object to form. Argumentative.
THE WITNESS: What's the -- what was it?
BY MR. SWEETAPPLE:
Q. Did you ever do anything to determine whether
or not the allegation in Paragraph 5, that as of April
4, 2014, the Pennsylvania Supreme Court did not reflect
that any lawyer with the O'Boyle Law Firm actively
practiced in the state?
Did you ever check to see as of April 4, 2014,
whether or not your son or any lawyer from the O'Boyle
Law Firm was registered with the Supreme Court as
activity practicing in Pennsylvania?
A. I did not -- did not check his -- no.
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Page 287
Q. Are you aware that after April 4, your son
reflected with the Pennsylvania Supreme Court he
practiced in Cambria County, Pennsylvania with an
address of 1001 Broad Street, Johnstown, PA?
A. What is your question?
Q. Are you aware that as of May 29, 2014, well
after the articles for the Florida O'Boyle firm were
filed, that your son listed with the Pennsylvania
Supreme Court -- indicated he practices in Cambria
County, Pennsylvania. Were you aware of that?
A. I was not.
Q. Are you aware of any address of 1001 Broad
Street, Johnstown, PA?
A. I am.
Q. Do you have property there?
A. I do.
Q. Do you have an office there?
A. I do.
Q. Does your son have a -- does the O'Boyle Law
Firm have an office there?
A. I don't know what the name is there, but my
son has an office there.
Q. Is there any lease with the O'Boyle Law Firm
at that address?
A. Yes. My son and I have agreements between us,
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Page 288
that are my son -- I don't need written agreements. I
trust him.
Q. So there is no written lease with the O'Boyle
Law Firm with regard to any space at that location?
A. Nor with my wife. I don't make her sign a
lease either.
Q. So who was your lease with? With Jonathan
O'Boyle?
A. We never discussed that.
Q. Well, it couldn't be with the corporation if
it's all for the rental of real estate.
A. Okay.
Q. How long is this lease for? How long are you
allowing him to stay there?
A. I told you, the details we never worked that
out. He is my son. It's my building. He is there, and
that's where we are, and let's move on.
Q. Does he have any residence in the vicinity of
Cambria County, Pennsylvania? Does he have an apartment
or a house that he resides in there?
A. I don't know.
Q. Does he work out of that location in
Johnstown, PA?
A. I don't know.
Q. You don't know?
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A. I don't know. Page 289
Q. You have never spoken to him about that?
A. I don't go over with him where he operates,
who he dates, what kind of car he drives. I don't do
that. You may do that with your daughter, but I don't
do it with my son.
Q. Okay. Well -- and so you don't know if he has
any residence within five hours even of Johnstown, PA
where he lives so he can practice law there, right?
A. He has no residence, to my knowledge, in the
world. So if that's helps you.
Q. Well, do you have any residential properties
in Pennsylvania that you have allowed him to live in?
A. No, but not very far away in West Virginia.
Q. How far in West Virginia?
A. How far?
Q.
From the
address
in Cambria
County.
A.
I don't
know. I
don't know.
Plus we had
property in Pittsburgh, so.
Q. Residential property?
A. Pardon?
Q. A house or residential property?
A. It can be used as a house, yes. 20 -miles away
from our house in West Virginia. I don't know how far
it is, but it's on the same identical road. Johnstown
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is just probably 30 -miles north west of Virginia. Page 290
But I don't ask Jonathan where he sleeps, what
he does. He does it on his own. And I don't think it's
any of your damn business where he sleeps.
Q. Well, it is my business whether or not he's
defrauding the courts of this state as member of a bar
where he's attempting to become a member of the bar.
It's very much my duty, sir. So have you given your son
permission to live in any abode in the vicinity of
Cambria County?
A. I'm not going to answer any questions about
where my son lives.
Q. Are you aware of whether or not your son has
resided at any point, has ever slept anywhere in the
vicinity of Cambria County during the year 2014 to date?
A. I'm not going to answer anymore questions
about where my son sleeps.
Q. And in Paragraph 7 we allege that as discussed
below, just two months after the O'Boyle Law Firm was
created as a Pennsylvania Professional Corporation in
November 2013, Jonathan R. O'Boyle moved to appear pro
hac vice in Florida state and federal cases. On
January 23, 2014, Jonathan R. O'Boyle filed a sworn
verified motion for admission to appear pro hac vice in
the case of Christopher F. O'Hare V Town of Gulf Stream
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and William H. Thrasher, Jr., and I list the case
pending before Meenu Sasser.
Did you do anything to determine if that
paragraph was correct?
A. I didn't know the paragraph existed.
Q. Well, didn't you read the motion that you said
was shit?
A. Yeah. But that paragraph was really shitty,
so I didn't want to read it.
Q. Paragraph 8 says that your son filed a sworn
verified motion in the case before Judge Sasser.
Did you look to see whether that was true or
not?
►•
Q. Do you believe there is anything untrue about
Paragraph 8?
A. No way I would know.
Q. You didn't look at Exhibit E?
A. I did not look at Exhibit E.
Q. Nine. "In said motion, Mr. O'Boyle swore in
Paragraph 2 that he is a member of the O'Boyle Law Firm
with offices at 2146 East Huntington Street,
Philadelphia, Pennsylvania."
Then it says, "This representation contradicts
both his Pennsylvania Supreme Court listing that he is
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either, (1) an out of state lawyer who can be reached at
his father's home in Florida; or (2), a lawyer
practicing at his 1001 Broad Street, Johnstown, PA; and
contradicts the O'Boyle Law Firm PC filing with the
Pennsylvania Department of State reflecting a business
address in Johnstown, not Philadelphia.
MR. SMITH: Object to form.
BY MR. SWEETAPPLE:
Q. Did you read Paragraph 9 to see whether or not
it was correct or incorrect?
A. I don't know whether I did or I didn't. But I
can't say it's correct.
Q. And you can't say it's incorrect?
A. Pardon?
Q. And you can't say it's incorrect either, can
you?
A. I could say that I'm not familiar with it. I
don't know.
Q. And you didn't look at Exhibits B, C or D when
you read the motion, right?
A. I did not look at your exhibits.
MR. DESOUZA: Bob, is there anyway to speed
this up instead of going paragraph by paragraph?
You want to put it in front him and say with
respect to paragraphs 1 through 35 of my motion,
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can you confirm any of these things are true?
MR. SWEETAPPLE: I don't think so,
unfortunately.
MR. DESOUZA: In that case I'm going to start
instructing him not to answer pretty soon. I can
see where this is going, and this is just not
fruitful. And you can take it up with the judge if
you want to, but I'd rather not be here until
8:00 o'clock.
MR. SWEETAPPLE: What time is it now, 5:30?
MR. DESOUZA: It is 5:30.
MR. SWEETAPPLE: So if you want to -- whenever
everybody wants to suspend, we'll suspend. I'm
going to be taking Mr. O'Boyle in at least a dozen
of his cases, and then there are a number of CAFI
cases, and some O'Hare cases that I'm going to be
deposing him in.
So there is no urgency in finishing this until
10:00 o'clock at night. I'll stay here until
midnight, or I'll suspend now. But before I
suspend, I do want to know Mr. O'Boyle's schedule,
because as I put on the record, Mr. Taylor stated
to Judge Blanc that Mr. O'Boyle was with his
grandchildren for two weeks. Mr. Smith was there.
And I, as an accommodation, agreed to today's date,
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 293
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September 15th, only to learn that Mr. O'Boyle has
been spending his time at city hall or town hall in
Gulf Stream rather than his grandchildren.
So Mr. O'Boyle, before I suspend the
deposition, what is your pleasure --
THE WITNESS: If I may respond to that?
MR. SWEETAPPLE: Sure.
MR. DESOUZA: You don't have to respond.
MR. SMITH: Don't.
MR. DESOUZA: There's not a question. You
don't need to respond.
MR. SWEETAPPLE: Can you --
MR. DESOUZA: Let's go over his schedule and
figure it out.
BY MR. SWEETAPPLE:
Q. Were you in New Jersey during the last two
weeks, Mr. O'Boyle?
A. I lose track of time. I was in New Jersey for
a week on a Wednesday, and then I came home on a
Wednesday night because our home flooded.
Q. And then you went to town hall for --
A. On Thursday I met with our engineer. We
resolved the problem. And I don't know if I went to
town hall on Friday, the following week. I don't know.
Q. You went with the videographer to film
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Mr. Thrasher's face.
A. That could be. But Nick has not represented
to -- Nick has represented nothing. I told him I was
gone for two weeks. My intentions were to go for two
weeks and, unfortunately, it didn't work out that way.
And I wish I would have been gone for two weeks. I
would have liked to spend more time up there.
Q. And what is your schedule for the rest of
September and October? Do you have any plans to be out
of the state?
A. Yes.
Q. What period of time do you plan on being out
of the state?
A. I'm going to likely leave tomorrow, and I'll
be back around the 23rd or 24th of October.
Q. You're going to be gone for approximately a
month?
A. Yeah.
Q. Where are you going to be?
A. In West Virginia.
Q. And it's your testimony you have no intention
of being here for a month?
A. That's correct.
Q. What is it you have to do in West Virginia for
a month? Because you have 12 cases here that we need to
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attend to, some of which you've asked for immediate
hearings in. So I'm going to have to compel the court
to have you appear at those cases.
A. That's fine. You do what you want.
Q. What is it you have to do in West Virginia for
a month that is more important than the cases that
you've demanded immediate hearings on?
A. I can answer you. My wife is up in New
Jersey, and I would like to spend some time with her
because we got cut off a week short.
My birthday is October the 12th, and every
year we go to West Virginia for my birthday. And we
usually get there a week in advance, because there has
to be preparation; buying food, you're buying -- so on
and so forth.
And then the following weekend is what they
call Bridge Day. It's where they -- if anybody has gone
whitewater rafting, the New River Bridge, they close it
and they jump off it. They base jump off it. And
that's the weekend after the weekend of the 12th. And
then after that, we'll clean up the house and come home.
Q. Well, you've filed a lawsuit against me and
Mr. Morgan. We need to take your deposition in that
case next week or the following week, so I'll be asking
the court to compel that as well as the cases where
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Page 297
you've asked for expedited hearings.
You're telling me you're just going for
pleasure, and you have instituted considerable
litigation that needs to be dealt with. These
apparently are very important matters that you want to
maintain. And I cannot accommodate anymore of your
requests for vacations. You asked for two weeks. And
I'm sure that you have people that can take care of
leaks in your home. You didn't have to come home to
address leaks, but we can take that up with the various
judges, Mr. O'Boyle.
MR. DESOUZA: There's no question.
BY MR. SWEETAPPLE:
Q. You're telling me you're not going to be
here -- you're not going to be here until after
October 23rd. That's your testimony.
A. I think that's -- let's just think again.
What day is the 12th? Is it Friday or Saturday?
MS. O'CONNOR: Sunday.
THE WITNESS: Sunday? Okay. So that would
mean six days later is the 18th and then 19th,
20th, 21st, 22nd, 23rd. Yeah.
MR. SWEETAPPLE: But you will have time to fly
banners addressing myself and Mr. Morgan and police
chiefs and other people, right?
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Page 298
THE WITNESS: Yeah, not only that, we'll
probably have circulars and we'll drop them out of
three states.
MR. SMITH: Marty, don't answer that.
MR. SWEETAPPLE: So you'll have time for that,
right?
MR. SMITH: Marty, don't answer it.
THE WITNESS: Don't be silly. Why don't you
be nice for a change?
MR. SWEETAPPLE: In terms of being silly, are
you the one who -- whenever it is you want to
suspend, just give me notice and I'll continue with
the questioning or suspend. Tell me what time you
want to go to.
MR. DESOUZA: Let's take a five minute break
and let's discuss it. We'll either suspend or go
for a little longer.
MR. SWEETAPPLE: I would like to go another 15
minutes to finish a couple of things up that I'm
on.
MR. DESOUZA: We'll take five and say --
THE VIDEOGRAPHER: The time is 5:38 p.m. We're
going off the record.
(At 5:38 p.m. a brief recess was taken.)
THE VIDEOGRAPHER: The time is 5:46 pm. We're
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Page 299
on the record.
MR. SWEETAPPLE: Yes. During the break, all
counsel have agreed that we're going to suspend the
deposition at this time. There's no way we can get
through it all. And while I'm not agreeing to wait
until October 23rd, I'll take that up with the
court with regard to not only concluding this depo,
but taking other depos in the other cases.
MR. DESOUZA: Sure.
MR. SWEETAPPLE: Thank you very much.
MR. DESOUZA: Thank you, Bob.
MR. SWEETAPPLE: I will take a copy, and I'll
need the exhibits.
THE VIDEOGRAPHER: The time is 5:47. We're
going off the record.
(Discussion held off the record.)
MR. SWEETAPPLE: I will put on the record
whether or not he wants to read that portion,
because I am ordering it.
MR. DESOUZA: Let's go back on. I want him to
read. We will take a copy as well.
(At 5:47 p.m.: m. the deposition was
adjourned.)
(End of Volume II.)
Debra Duran & Associates
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THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
Page 300
I, the undersigned authority, certify that the
aforementioned witness personally appeared before me and
was duly sworn.
Dated this 29th day of September, 2014.
�Vaw % 1
Debra Duran - Bornstein, RPR, CLR
Notary Public - State of Florida
My Commission Expires: 8/20/15
My Commission No.: EE 112218
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 301
C E R T I F I C A T E
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I, Debra Duran - Bornstein, Registered
Professional Reporter and Notary Public in and for the
State of Florida at large, do hereby certify that I was
authorized to and did report said deposition in
stenotype; and that the foregoing pages are a true and
correct transcription of my shorthand notes of said
deposition.
I further certify that said deposition was
taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and
completed as hereinabove set out.
I further certify that I am not attorney or
counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
action.
The foregoing certification of this transcript
does not apply to any reproduction of the same by any
means unless under the direct control and /or direction
of the certifying reporter.
Dated this 29th day of September, 2014.
EmMox-
Debra Duran - Bornstein, RPR, CLR
Notary Public - State of Florida
My Commission Expires: 6/20/15
My Commission No.: EE 112218
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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September 30, 2014
NICK TAYLOR, ESQUIRE
THE O'BOYLE LAW FIRM, P.C., INC.
1286 West Newport Center Drive
Deerfield Beach, Florida 33442
In Re: Martin O'Boyle Vs. Town of Gulf Stream
Deposition of: Martin O'Boyle
The referenced transcript has been completed and
awaits reading and signing.
Please have your client review your copy of
the transcript at your convenience or if a copy was not
ordered, to call our office at the below - listed number
to schedule an appointment between the hours of 9:00
a.m. and 3:30 p.m., Monday through Friday to make an
appointment to come to our office and read the
deposition. If desired, your client may also opt to
waive signature. If so, please have your client sign
their name at the bottom and mail to our office to be
attached to the original transcript.
If the transcript is not reviewed and signed
within 30 days, the original, which has already been
sent to the ordering attorney, may be filed with the
Clerk of the Court.
Very truly yours,
Debra Duran & Associates
224 Datura Street, Suite 402
West Palm Beach, Florida 33401
PH: 561) 313 -8000
I hereby waive my signature:
MARTIN E. O'BOYLE
Cc: All Counsel
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 302
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Page 303
C E R T I F I C A T E
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I hereby certify that I have read the
foregoing deposition by me given, and that the
statements contained herein are true and correct to the
best of my knowledge and belief, with the exception of
any corrections or notations made on the errata sheet,
if one was executed.
Dated this day of
2014.
MARTIN E. O'BOYLE
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 304
E R R A T A S H E E T
IN RE: O'BOYLE V TOWN OF GULF STREAM C.R. DD
DEPOSITION OF: MARTIN E. O'BOYLE
TAKEN: 9 -15 -2014
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
PAGE # LINE # CHANGE REASON
Please forward the original signed errata sheet to this
office so that copies may be distributed to all parties.
Under penalty of perjury, I declare that I have read my
deposition and that it is true and correct subject to
any changes in form or substance entered here.
DATE:
SIGNATURE OF DEPONENT:
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
$1,500 218:14
$1200 218:17
$3800 218:19
(1) 292:1
(2) 292:2
1
1 198:2215:18
278:19 292:25
10 166:25 167:19
185:20
100 199:10
100 -page 209:18,
20,21
1001 278:10 287:4,
12 292:3
10:00 293:19
11 187:9
11:05 219:12
12 167:24 189:19
207:5 295:25
1280 176:13,17,25
181:14 188:18
192:10 196:23
1286 192:20 193:5,
14,17
12th 296:11,20
297:18
13 190:12
14 193:24 194:1,3,8
195:2 198:17
15 166:21 194:1,5,8
195:4 215:24
270:14 298:18
157 221:10 243:11,
13
15th 294:1
16 207:3 214:8,9,
251:10 257:1
16th 214:8 215:24
217:3
17 167:20
17th 169:16
18th 297:21
19 217:12241:21,
23
19th 297:21
2
2 279:1,23,24
291:21
20 188:12,14,16
20 -miles 289:23
2011 184:25
2013 278:7 282:16,
19 283:1,5,9,23
284:4 290:21
2014 167:20
181:24 201:7
258:24 284:7,11
286:7,18,21287:6
290:15,23
20th 297:22
211 207:5
2146 279:6 280:8,
18 281:13,18,23
282:7 283:15
291:22
21st 297:22
22nd 197:8 297:22
23 176:15284:9
285:24 290:23
23rd 295:15
297:16,22 299:6
24th 295:15
25 179:6 206:7,20,
23
25,000 166:21
26 214:15 218:21
27 218:1
27th 174:20 217:25
28 212:22 214:25
215:6
29 287:6
2:00 222:16
2:36 160:3
2nd 200:16201:7
3
3 201:20 252:12
279:22
30 -miles 290:1
33432 193:18
33483 176:16
34 277:14
35 292:25
4
4 201:20281:21
284:7,11286:7,18,
21287:1
4,000 252:12
4/28 206:6
4/2812014 181:24
205:16
40 190:15,18
45 249:20 252:12
4:20 245:11,13
4:36 245:14
4th 237:12 238:15
240:22 242:4
245:18 282:5
5
5 284:6 286:17
50 252:12
50,000 252:12
561 203:2 284:11
5:30 293:10,11
5:38 298:22,24
5:46 298:25
5:47 299:14,22
5th 197:2 251:13
6
6 167:1 199:6
257:21258:17,22
6/2 213:1
6/21/2006 176:12
6th 161:3 254:22
7
7 176:7 180:16,20
290:18
8
8 180:11,12 291:10,
16
888 -830 -3769
193:19
8:00 293:9
9
9 184:14216:1
292:9
A
a.m. 219:12
abandoned
275:25
abode 290:9
abruptly 237:1
absolutely 162:7
214:5
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: $1,500-address
accept 270:24
274:15,17,19
accepted 274:20
access 200:20,23
201:5 215:19
accessed 200:25
accommodate
297:6
accommodation
293:25
accountant
178:17 189:16
accountant's
191:12
accountants
191:5,7,10,22
accountants'
191:14
accurate 198:25
accused 164:7
acknowledged
227:16,17,19
acquire 258:11
Acquisition
189:18,23
Act 167:23 218:11
action 266:16
actions 171:24
actively 168:2
186:15 192:2
284:13 286:8,19
activities 167:9
211:12 224:5
230:4 244:8
activity 223:24
229:11,12,14 264:4
286:24
actual 218:22
219:6 236:5
addition 262:25
address 175:6,7
176:17 181:1,5,7,
12 189:2 192:10
193:17 196:20
247:1278:10,11
279:4,5 280:7,8,20,
22 281:14,18,23
282:6,12 283:8,15,
16 284:8 285:24
287:4,12,24 289:17
292:6 297:10
addressing 297:24
adjourned 299:23
administration
198:9
admission 290:24
admit 256:4
advance 250:24
296:13
adverse 276:23
277:13
advice 264:19,24
advise 224:10
advised 198:18
285:23
affiliate 263:19
affirmative
275:21
aforementioned
219:8
agencies 216:4
agent 175:25
176:14 187:16
190:19 193:13,25
259:1260:10,13,21
261:2,10
agree 170:8 210:5
236:7
agreed 171:9
210:6 293:25
299:3
agreeing 299:5
agreement
209:10,12,16,17
210:8,10 238:19
239:6 240:9,10,12
agreements 170:7
207:8,16 212:19
287:25 288:1
ahead 236:24
249:16 279:14
284:25
air 236:16
aircraft 177:12
airline 175:15
176:11 177:8
178:4 179:14
252:3
airport 183:7
akin 224:15
alia 270:17
allegation 286:17
allegations 278:4
279:24 284:16
allege 163:10
290:18
alleged 167:22
170:9 172:22
278:20
allegedly 179:7
235:4
alleges 161:11
198:23
alleging 172:23
269:16
allowed 232:2,5
289:13
allowing 288:14
alternative 275:15
ambiguous 223:8
amend 217:21
amended 275:21
Amendment
262:11263:4,5
264:14 266:8,15,17
267:3,9,10
amount 217:6
amounts 217:5
anger 254:24
255:9,11,14
animosity 235:23
announcement
283:3
annoyed 268:3
answering 174:24
175:2 196:25
204:7 207:11
217:24 218:3
219:18 268:19
answers 244:19
anymore 175:5
179:12 196:25
290:16 297:6
apartment 288:19
apparently
198:22 257:8
276:18 297:5
appeal 182:19,22
appears 171:22
202:4 258:3
apple 171:23
259:22 261:14
263:23
Apple's 266:21
272:10
application
260:24
appointed 179:7
approached
270:19
appropriately
275:19
approval 172:21
274:5,7
approve 160:16,
195:19 219:4,9
approved 171:11,
14 174:3
approximately
169:14,24 295:16
April 198:2,8,17
284:7,11286:7,17,
21287:1
area 254:15,19
284:11
areas 270:21
argued 219:24
argument 236:6
argumentative
204:8 205:14
206:25 207:24
219:21235:18,19
236:1284:22
286:13
argumentive
205:7
arranged 251:21
arrangement
218:24
articles 259:23
287:7
ashamed 235:17
assertion 231:18
assertions 279:19
Asset 190:9
assigning 198:18
assist 216:2
associate 265:1
267:14
associating
271:11
association
267:15
assume 194:9
assuming 242:5
assure 217:2
attached 285:5
attacked 225:19
226:1,15
attempting 290:7
attend 296:1
attorney 218:13
220:11221:5
235:23 259:2,3,4
264:24
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: addressing -awful
attorney's 165:17
attorney - client
197:13
attorney /business
179:4
attorneys 167:1
201:2
attorneys' 212:2
217:6 230:22
attractive 274:11
audits 216:3
Augmentive
235:10
August 161:2
authority 213:2
223:1239:2
authorize 219:3
Aviation 180:4,22
181:10
aware 160:21,25
161:3,6,13 162:12,
18,20 163:24
165:12,21 192:7
198:2,7,17 202:25
203:4,6,9 205:12,
16,20,23 206:9,22
207:3,7,15 208:6
212:22 213:1,5
219:17253:15
282:6,12 283:22
284:18 285:23
286:2,6,12 287:1,6,
10,12 290:13
Awareness 160:7,
25 161:8,20,24
162:9 163:12,15,
17,21 164:9 165:7,
16 166:12,24
167:1,10 168:7
169:8 170:16
171:17,20 172:2,5
193:16,25 196:19,
22 197:1,10,16
206:8 213:18
217:8
awful 252:13
B
B- o- e- c -k-e -r
233:16
back 160:4164:5,6
166:2,15 170:23
180:6 194:20,21
200:3 208:23
209:5,8 215:1
220:23 224:2
225:24 233:25
234:4 242:22
244:16 245:15
277:3 278:4
295:15 299:20
backup 285:8
bad 230:7 243:6
268:5
bag 164:23 200:6,
12 215:15
bank 206:10273:3
bankrupt 202:2
bankruptcy
206:11,14
banner 183:1
251:13,16,18,21
252:8 253:6,14,22,
25 254:9
banners 182:14,17
183:10,15 254:3
255:13 297:24
bar 231:19,20
284:19 285:2,24
286:3 290:6,7
base 296:19
based 224:22
249:24
basis 162:25
197:22,24 202:14
243:7
bathroom 274:9
Beach 182:18
187:24 193:18
224:17,19 225:1
253:15 267:6
279:4 280:7
bed 229:22 230:1,3
256:7
begin 225:4 258:12
behalf 170:2
172:16
beliefs 211:6
believed 217:3
beneficial 245:4
big 186:17,19
229:3
Bill 201:1217:13
222:25 238:6,8,23
240:1,25 241:1
242:22,23
billed 219:6
billings 252:17
bills 251:17 252:6,
9,11,15,24 253:10
254:15
birthday 296:11,
12
bit 242:23 263:25
271:19
bite 171:23
Blanc 293:23
board 174:21
198:10
Bob 171:19208:2
216:13 228:1
233:9 236:4 245:2
256:10 277:17
292:22 299:11
Boecker 233:16,18
book 181:16
Boy 202:1
brain 225:5 236:21
brainchild 225:8
226:5 245:23
breach 238:22
239:6
breached 161:12
238:19,20,21
240:8,10
break 168:12
187:6 208:17
245:3,6 261:19,24
298:15 299:2
Breakers 253:20
254:1
breaking 262:1
Brenda 169:6
174:22 178:20,21
179:4 183:17,18,19
184:4 217:19
Brenda's 183:22,
24 184:1
Bridge 296:17,18
bring 160:10164:5
173:6,8 174:12
185:3 225:15
226:9,13 238:6
263:3 265:24
266:2
bringing 173:3
216:9 250:22
Broad 278:10
287:4,12 292:3
Brucker 267:7
brought 238:10
262:24
Broward 202:9121
204:4
building 174:25
188:20,24 196:23
207:19 238:4,5
267:6 288:16
buildings 188:22
bully 173:13
bunch 164:4
business 189:8
190:18 192:15
203:1210:22
211:9 217:4
267:16 283:7
290:4, 292:5
businesses 193:2,7
267:15
businessman
211:2
Index: B- o- e- c- k- e- r- Chandler's
buyer's 243:18
buying 296:14
C
cabs 241:8
CAFI 172:18,20,
23 174:4,5,20,23,
25 175:3,8,9
178:22,23 179:2,7
183:18,24 184:4,7,
9 186:6,7,8 191:22
192:19 193:9
198:10,24 199:3,9,
14 200:3 206:21
207:7,9,16 208:1,4,
8,10,13,18,20,23
209:15 210:7,8,22
211:9,13 212:8,19
213:7,9,22 214:16
215:3,216:9
217:13,14 218:2,4
219:19 293:15
CAFFS 175:6
209:19 218:9
call 164:25 165:6,
8,9 167:12 200:9
203:7 204:11
215:17 218:25
243:5 248:19
272:10 296:17
called 164:22
165:1,4,23 166:2
200:8 202:9 204:3
215:14 220:1,21
227:7 235:14
243:11 266:21
268:6 273:1,2,16,
18 276:22 278:6
Cambria 2873,9
288:19 289:17
290:10,15
cancer 221:3
car 289:4
card 169:5,283:7
care 181:1277:17
297:8
carefully 255:19,
22 256:11
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
case 163:11
172:15,18 173:2
176:3 182:18,22
198:19 218:7,17,19
227:6 228:23
290:25 291:1,11
293:4 296:24
cases 197:9198:5,
11200:4,24 201:1,
2,3 205:11206:7
207:5 208:10,14,18
212:23 213:2
215:8,9 220:15
227:6 228:18,20
235:5 246:15
248:11275:22
284:3 290:22
293:15,16 295:25
296:3,6,25 299:8
Cathleen 217:14
caused 161:21
cell 203:1,2,6
Center 176:14,17,
25 181:14 188:18
190:10 192:11,20
193:5,15,17 196:24
certifying 215:1
CG 189:18,23
chance 167:5
231:10
Chandler 160:18
161:1,9,11 162:5
164:3,11,23 165:4,
6,12 166:4,12
167:20 168:3,6,14
169:15,18,20,25
170:7,9,23 171:9
174:11,16,18 197:2
198:3,11,18,23
199:4,13 200:2,5,
17,18 201:6
205:10,17 206:1,
13,19 207:4 212:23
213:5,23 214:1,4,
16,25 215:12
216:2,7,9 217:2,17,
25 219:13 241:22
Chandler's
162:20 167:25
172:20
change 193:12,23,
25 298:9
changed 169:22
170:23
character 195:19
256:18
charge 270:23
check 251.•17
252:6,9,15,23
254:14 282:2
286:21,25
checked 222:25
checks 209:25
chiefs 297:25
child 225:5
children 227:22,
23 228:10,15
244:1,2 280:22
Christopher
290:25
chronicled 167:15
chronology 241:6
chucked 274:23
275:2
Circuit 161:2
circulars 298:2
Citizens 160:7,25
161:8,20,24 162:9
163:12,14,17,21
164:9 165:7,15
166:12,24 167:1,9
168:6 169:8
170:16 171:17,20
172:2,4 193:16,25
196:19,22 197:1,9,
16 206:8 213:18
217:8
city 202:2 221:18
294:2
claim 167:2 221:12
claims 161:12
168:15 173:3
221:14
clarity 199:6
clean 296:21
clear 216:13
222:22 223:9
227:2,9,15 229:1,
237:2 248:22
249:1262:2
277:25 278:1
client 224:12256:7
clients 251.17
252:6,9,16,19,20,
21,23 253:3,10
254:14
close 296:18
closer 264:1
closings 205:7
clue 270:18
co- counsel 220:1
256:24
code 284:11
coinciding 167:25
collects 208:9
combination
262:8
Commerce 175:7,
10 176:18 181:1,4
187:8 188:9
191:24 192:5,14,17
217:15,19
commission 239:3
committed
206:10,14
common 209:13
210:12
communicated
168:3 220:20
communication
217:23 219:17
224:6
communications
165:13 167:14
170:3 214:6
223:25
companies 169:4
1912,4
company 166:23
175:24 177:14
179:19,22 181:16
182:2 183:11,13
186:15,16,17,18
189:8,18,23 190:24
191:25 192:2
252.3 258:11,18,21
259:23 262:5,23
270:19 272:20,25
compel 296:2,25
complained
205:9,17,25 206:1
207:4
complaint 161:14,
15,18,21 166:25
232:19,21 233:1,5
complaints
214:16,23 215:2
complies 266:16
compound 194:25
computer 215:20
concern 271:4
concerned 285:15
concerns 257:11
concluding 299:7
conclusion 262:12
condition 218:12
246:3 247:2
conditions 247:5
conduct 281:9
conducting 216:3
conference 242:21
243:3 248:19
256:8
confirm 219:10,14
293:1
confront 266:13
confused 224:25
conjunction
264:15
connection 161:25
279:12
consent 205:12,20
213:8
considerable
297:3
consideration
267:4
constitution
262:11264:2
contact 273:4
274:20 275:1
279:13 286:4
contacted 218:7
272:21273:15
context 228:13
234:18
continually
197:18
continue 298:12
CONTINUED
160:1
contractor 217:16
contractors
208:19
contradicts
291:24 292:4
contrary 256:15
contribution
210:3,19
control 175:1,4
210:16 252:11
262:22
conversation
218:6,15,23 219:14
220:8 235:2
conversations
171:8 216:14,23
261:5
converse 241:10
cooperation 279:4
copied 217:12
copies 180:14
270:3
copy 180:5194:10
200:16 257:7
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: change-create
268:1,6,7,14,18,25
270:8 299:12,21
corporate 178:14
181:13,16 189:3
192:12
corporation
180:23 189:24
197:17 273:2
279:5 280:6,7,11
288:10 290:20
corporations
176:11 193:14
279:2 280:5 282:1
correct 164:12
174:13,22 175:20
187:16 193:8,10,11
202:22,23 205:12
247:3 261:12
284:16 291:4
292:10,12 295:23
costs 165:17 212:2
218:17
counsel 171:11,14
198:3 220:5,14
231:12264:17
276:23 299:3
counterclaim
172:3,12 275:21
County 182:18
187:24 202:9,21
204:4 253:15
287:3,10 288:19
289:17 290:10,15
couple 227:13
230:17 298:19
court 231:3 256:1
284:12 286:6,11,
18,23 287:2,9
291:25 296:2,25
299:7
Courthouse
182:18
courts 290:6
cover 180:15,18
Craft 270:14
crazy 234:20
create 218:21
253:5
created 278:7
290:20
credibility 240:15,
16,17,18
credit 169:5,6
criminal 235:14
CRO 180:4,22
181:10
cronies 268:4
crook 216:7,11,12
cross - examine
277:12
crossed 225:19
226:2,16,21,23
crowd 252:11
crying 229:22
230:1,4
current 189:7
cut 197:4296:10
FBI
daddy 229:3
damage 225:20
226:24
damn 290:4
data 200:23 215:20
date 164:20176:12
181:24 251:13
290:15 293:25
dates 289:4
daughter 244:3,5,
8 280:25 281:5,12,
16 289:5
daughter's
182:18,22 244:24
daughters 230:22
day 165:2168:7,19
195:20 200:10
220:24 251:19
253:14 254:22
296:17 297:18
days 251:7 258:17
297:21
De 162:10,24
170:19 174:21
179:5 197:9 198:8
200:4,17 206:6,12,
23 207:4 212:22
214:12,15,25
215:11216:1
217:12 260:3,7
deal 185:2 191:5,6,
10 195:18 268:8
270:12 272:13
dealt 165:11
275:19 297:4
debate 256:9
debtor 208:20
December 161:3
282:16,19 283:4
decide 172:11
197:24, 255:25
256:6 274:15,17
decided 221:6
264:20 274:19
275:25
decision 258:11
Deerfield 193:17
267:6 279:4 280:7
defamation
232:18
defamatory 264:3
265:1
defame 267:14
defamed 232:12,
13,17,18,20
defendant 218:7,
21,25 219:2
defendant's 176:7
180:12 184:14
185:20 187:9
189:19 190:12
194:3,5 199:6
251:10
defendants 164:9
165:15
defense 275:21
defrauding 290:6
delayed 195:18
deleted 198:24
Delio 217:15
deliver 257:24
delivered 258:3,5,
6
demand 166:4
218:19,20 219:4,5,
8
demanded 164:11
206:6,212:23
296:7
demands 219:10
250:4,8
denied 213:1
Denise 174:21
201:4 214:24
215:18
Department
176:10 192:8
278:9 279:2 280:4,
10 281:25 292:5
depends 215:13
depo 277:1299:7
depos 299:8
depose 277:13
deposing 293:17
deposition 172:6
269:13,14 270:6
276:20 294:5
296:23 299:4,22
describing 237:14
designated 174:21
designed 265:5
desire 168:1
239:25
DESOUZA
162:14,16 163:5
164:14 165:18
168:9 171:4,19
172:7 175:21
176:1 177:6
178:10 179:8
180:5,8,17 188:6
192:25 194:9,13,
17,24 196:17
197:11 198:13
199:1,5,8 201:19
202:12 204:6,17,25
205:3,6 207:20,23
208:2,15 212:11
213:10 216:13,18
220:4,7 221:21
228:1,7 232:9,14,
25 233:9 235:7,11,
19,25 236:3,5
240:2 241:9
244:15,19 245:3,10
250:5 253:11
254:17 255:3,21
256:10,22 257:3,6,
13,17,21261:3
262:16 264:6
266:22,24 270:10
271:24 272:16,18
273:9 275:17
276:4,10,18 277:3,
14,17,23 282:9
283:10 284:24
285:9 286:10
292:22 293:4,11
294:8,10,13 297:12
298:15,21299:9,
1 1,20
detail 209:18
detailed 255:22
256:11
details 255:19
288:15
detective 244:5
determine 279:23
284:15 286:16
291:3
determined 171:2
developed 274:6
developer 273:12
difficulty 195:18
digress 242:19
dinner 242:20
dire 218:11
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: created- dismissed
direct 170:22
196:14 213:20
254:2 258:21
directed 185:25
219:7
directly 196:5
222:19,23 223:16
241:18 267:13
director 178:23
183:18 184:4
187:18,21 190:20
206:21
directors 178:22,
24
dirty 184:17
187:23 188:5
252:18 271.9,12,16
discharge 276:9
discovery 171:24
172:10,24 173:15
discretion 221:11
discriminate
249:10 264:8
272:3
discriminated
249:22
discrimination
249:12
discuss 248:7
265:14 298:16
discussed 174:11
218:7 260:25
261:6 288:9
290:18
discussion 220:25
223:23 236:14
241:7 256:6
299:16
discussions
169:14,17,24
219:1,3 224:4,23
230:18
dismiss 254:25
dismissed 221:12,
13 285:18
dispute 225:16
226:9,13 279:19
disqualified 276:2
disqualify 219:24
245:8 275:14
disqualifying
254:25
disseminate 201:5
disseminated
269:17,20,23
271:15,17
district 167:22
Division 176:11
279:2 280:5,11
281:25
document 190:22
201:16 210:2
269:6
documentation
215:23
documents 178:9
188:4 198:20
217:22 278:15
dollars 229:7,8
274:3 275:1
door 193:6
dozen 293:14
DPT 187:20192:7
drafted 205:11
221:6
drafting 205:18
drink 253:23
254:9,23
drive 176:14,15,
17,25 181:15
188:19 190:10
192:11,20 193:5,
15,17 196:24
253:23 254:9,23
284:9 285:25
driver's 203:16
drives 289:4
drop 298:2
dropping 225:4
ducks 173:8
DUI 244:25
DUIS 244:13
duties 171:11
duty 161:12290:8
DX15 194:14
LEI
e -mail 164:11,23
165:22 166:5,8
167:12 200:15
201:13 213:16
218:5 219:11,13
223:6 241:21
271.•2
e- mailed 270:14
e -mails 163:20,24
164:1,2 198:24
216:15,19,20,21,22
273:21
earlier 200:6
232:12
earned 164:10
earning 209:2
East 279:6 280:8,
18 281:13,18,23
282:7 283:15
291:22
editorializing
276:14,18
educate 161:25
Educating 186:22
effective 164:24
effort 271:9
efforts 263:20
264:21
electronic 216:3
electronically
258:6
Elmore 238:11,24
240:14
employ 241:18
employed 241:13
employee 217:15,
19 218:2
employment
168:4 170:13
encountered
171:10
encourage 266:19
encrypt 215:22
end 234:22 236:13,
22 262:1299:24
ended 237:1
261:21
ends 197:18
engage 204:17
engaged 189:8
190:5 244:8,9
engagement
207:16 212:19
engages 210:22
engaging 204:21
engineer 294:22
Enhancement
190:9
enraged 285:7
entered 169:15,25
entire 198:10
entities 181:12
184:1 196:7,8,13
208:19 209:14
241:18
entitled 172:7
212:9 256:3
271:10
entity 160:14,17
163:13 168:6,14
170:17,20 171.•3
174:12 175:1,3,15,
17 176:21,22,25
177:5 178:7,16
181:6 182:12
184:18 185:1,8
1862,9,11 187:2
190:11,14 196:23
208:7,10,12 210:16
212:15 267:16
enumerated
276:7
enumeration
212:5
estate 273:12,13
288:11
ethical 256:17
ethics 279:11
event 243:24
246:23 247:16
evidence 245:9
evidentiary
275:16
excerpts 256:13
exchanged 164:2
Excuse 172:12
223:7 263:2
exercise 217:4
exhibit 167:1
176:5, 180:7,12
184:14 185:20
187:9 189:19
190:12 194:3,5
199:6 251:10
257:1291:18,19
exhibits 180:9
193:21285:5
292:19,21299:13
existed 291:5
existence 184:25
188:14 216:22
exists 160:10
expect 208:23
244:9 268:20,22,24
expectation 211:9
expected 249:9
expedited 297:1
expenses 169:1
218:22 219:6
experience 167:25
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: dispute - family
277:15
expert 215:21
explain 230:16
explained 218:11
243:6
expressed 218:8,
23
expressions
243:19
extensive 167:25
extent 162:2
182:25 212:13
224:10 235:2
extra 257:6
eyes 247:16
F
F -1 191:18
face 221:4 262:25
295:1
facetious 276:15
facial 243:19
facilities 274:10
fact 162:21,23
163:9 165:11
166:4 174:16,17
205:5,9 224:22
238:6 258:17
261:1 270:8
279:17 281:13
facts 172:4 221:18
278:20,24
factual 243:7
failure 218:9
false 279:25
280:15
familiar 180:4
184:18,20 191:25
248:8 292:17
family 225:15,19
226:2,9,13,16,18,
19
fantasy 237:17,19
father 284:9
father's 292:2
fax 213:16 258:6
faxed 258:9
February 167:20
169:16 197:2
federal 231:3,21
256:24 290:22
fee 207:8,15 212:18
feed 235:5
feel 173:9 270:15
fees 164:10 165:17
212:2 217:6
218:17,22 219:6
fellow 195:16
felt 225:14,15
226:8,12
fiduciary 161:12
figure 247:22
269:15 294:14
file 243:10 284:19
filed 161:1,4,6,21
163:9 167:20
170:15 171:18
176:12 181:24
185:9,11,14,15
187:23 200:4
201:25 205:11
206:24 212:14
213:21215:2
225:5 233:23
243:20 257:10
259:22 260:19
275:23 287:8
290:23 291:10
296:22
files 189:6,10
200:20
filing 172:22
173:14 181:22
185:5 186:21
201:18 211:19,25
280:11,12 282:2
292:4
filings 281:25
filled 162:3
film 294:25
financial 218:12
financially 267:19
find 172:10 209:4
233:6 263:5 268:7
275:3,277:4
fine 198:1 205:7
296:4
finish 298:19
finishing 293:18
fire 238:11,23
240:8,9
fired 238:7,9,16
239:9,10,11,14
240:1,5,13
firing 240:11
firm 160:23162:12
163:2 164:10
173:20 174:4,13
192:20,23 193:14
195:8,25 196:2,13,
20 197:3,10 198:11
202:10 203:24
204:2,4 206:8,24
207:8,17 208:9
211:20,22 212:20,
24 213:2, 217:3
218:16 219:6,16,
24,25 222:20,25
223:1,14 225:12
228:24 229:1
235:4,240:22
241:1,2,4,14,23
242:1,3 251:4
255:1267:5
275:15 276:1
278:6,7 279:3
280:5,12 281:14,22
282:7,14,19
283:12,16,20
284:13 286:8,19,23
287:7,20,23 288:4
290:19 291:21
292:4
firms 221:17
tistfight 234:15
Flack 217:15
flapping 198:21
floating 257:9,11
flooded 294:20
Florida 167:21
171:18 176:10,16
193:18 198:4,18
200:14 204:4,5,24
205:18 264:22
265:2 273:12
279:1,5 280:4,7,11
281:25 284:10
286:3,6,10 287:7
290:22 292:2
flow 197:4
flown 182:17
251:14,16,18
253:6,14 255:13
fly 183:10 253:22
254:3,6,19 297:23
Flynn 191:15,17
focus 263:25
food 296:14
foreign 279:3
280:6
forget 165:3
195:17
forgot 214:3
form 162:14,15
163:3 164:13,14
165:18,19 168:9
171:4 176:1
178:10 179:8
188:6 192:25
194:24 196:17
197:5,11 198:13
202:12 204:6
207:24 208:15
213:10 221:21
253:11 254:17
255:2 258:11,18,21
264:6 270:10
276:24 277:2,4,6
282:9 283:10
284:22 286:13
292:7
formal 178:9
246:6,9,12
format 201:4
formed 160:14
168:7 169:9
179:14 185:24
186:1,2,6,7,8
187:12 188:11,12
190:7 262:23
forming 174:11
forms 189:4,6
Fort 203:21
forthwith 258:13
fortune 239:14
forwarded 206:8
Foster 249:9
251:17 252:5,9,16,
20 253:3,9 254:14,
24
Foster's 252:11
found 216:12
foundation 160:8
161:1,8,21,24
162:9 163:12,18
165:7,16 166:13
167:2,10 168:7
169:8 170:12,16
171:12,15,18,21
172:2,5 193:16,25
196:19,22 197:16
206:9 211:13
213:18 217:9
235:5
fraud 206:10,11,14
free 171:23 184:5
210:17 217:4
Friday 294:24
297:18
friend 217:16
friends 273:5,6,7
front 160:22
257:17 267:6
292:24
fruitful 293:7
full 215:15 221:8
233:24
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: fantasy -give
full -time 162:25
202:20,22 203:20
fully 173:18
fund 196:2,4,8,13
197:10
funded 208:4
(under 207:17,18,
25
funding 163:13
212:14 235:6
funds 168:23
208:7
funny 261:21,23
262:10,263:24
265:25 266:1
future 223:24
224:5,24
G
gain 200:20
games 207:13
garbage 246:17
gave 176:18
180:20 221:10
223:1,14 240:24
251:8
general 245:20
generally 209:11
245:25 254:4
generate 162:11
163:1
generated 207:5
gentleman 173:7
geographic
254:15,19
George 238:11,24
240:14
Giovani 205:9,17,
22
girl 230:24
give 162:11 167:5,
16 180:15 208:10,
14 211:25 215:19
234:18 254:15
264:17 267:3
298:12
giving 210:13,15
232:4 256:21
276:25
glad 201:25 231:12
246:20
global 242:11
247:9
goal 240:5 250:9
goals 239:12,13
good 184:13189:7
221:24 222:4
223:10 252:13,14
272:13
Gordon 270:14,15
governance
181:14 189:3
192:12
government
168:1 171:10
184:17 185:2
187:23 188:5
governmental
208:19
GP 187:8 188:9
189:24
grandchildren
293:24 294:3
great 195:18 202:2
245:10 272:18
Group 175:7,10
176:18 181:2,4
187:8 188:9
191:24 192:5,14,17
guess 166:23
184:10 204:11
210:7 214:3 273:5
guessing 243:24
Gulf 172:17
176:15 213:7,8,17,
21236:11237:3,23
257:9,12,25
258:11,19 263:21
264:5,8,13,22
265:2 270:17,20,21
271:5 284:10
290:25 294:3
guy 168:25169:3
171:24 268:5
guys 266:10
H
hac 290:22,24
hall 294:2,21,24
hamburger
259:11
hand 230:6258:5
handicap 249:10
handicapped
237:2 249:5,22,25
264:9 272:3 274:9
handle 178:15
198:19 284:3
handled 198:4
handles 178:16
183:15 189:3
hands 234:16,25
235:1
handsome 270:23
274:1
happened 164:18
173:2 243:22
247:14 248:15
249:18 251:1
happy 279:15,20
harassing 204:8,
19
Harbor 176:15
284:9 285:25
hard 241:9
hatred 235:23
He'll 201:17
hear 201:24
heard 206:4
248:16,17,19
276:24
hearing 275:16
hearings 296:2,7
297:1
heck 238:13
held 164:10 241:7
299:16
hell 272:4
helpful 200:22
helps 289:11
Hidden 176:15
284:9 285:25
hierarchy 271:7
high 252:13 263:11
high -end 273:13
highly 261:16
Highway 175:16
176:11 177:8
178:5 179:14
hint 271:21
hire 182:15,19
183:2 215:20
229:23 230:2,9
236:20
hired 168:8182:24
183:1,8
hiring 183:4 216:2
hold 200:11220:4
228:1234:16
235:25 257:3
home 174:17,18
202:22 284:8
285:24 292:2
294:19,20 296:21
297:9
honorable 202:17
hoping 186:16
horse 263:11
host 207:23
hotel 168:20,21
169:6
hour 249:20
hours 276:19,25
277:2,5 289:8
house 236:24
249:14,15,24
250:10 251:3,6
259:9,16 262:5
264:12,13,22 265:1
270:17 271:20,23
272:7,11,22 288:20
289:22,23,24
296:21
houses 236:12
237:24 250:13
258:11,12,19,22
259:5,22 261:15,17
263:20,23 264:21
270:20 271:6,12
human 235:1
hundreds 167:20
235:5
Huntington 279:6
280:8,18 281:14,
18,23 282:7 283:15
291:22
hurt 234:22263:16
husband's 233:19
I
idea 171:7178:1
183:3 190:15
202:23 203:25
210:9 211:24
212:21214:17
221:20 222:4
230:7 234:11
260:8
identical 289:25
identification
176:8 180:13
184:15 185:21
187:10 189:20
190:13 194:4,6
251:11
identified 281:22
282:1,3
II 299:24
imagine 198:14
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: giving - insisted
immediately
164:24 215:16
240:19 255:18
immigration
195:21
implementation
258:13
implication 253:2
implicitly 253:9
implying 252:16
important 296:6
297:5
impregnated
204:13
impressed 187:7
impression 253:6
improperly
269:17,18
in -house 191:7
including 164:8
167:15,21220:25
income 160:8
189:12
incorporated
174:20 190:15
incorrect 292:10,
13,15
incurred 165:16
217:7
indirectly 251:22,
23 267:14
individual 187:13
270:7
individuals
163:21
indulge 173:24
infancy 186:17
information
215:19 275:2,6,11
inquiries 279:12
insist 197:9
insisted 162:10
insistence 165:14
installation
253:19
instituted 297:3
instructed 218:13,
is
instructing 205:3
293:5
instructions
162:23,24 277:18
intend 217:13
253:5 258:12
intended 162:21
intending 186:18
intent 210:25
intention 270:16
271:6 295:21
intentions 295:4
inter 270:17
interest 176:24
182:13,15,20
interpretation
253:2
interruption
173:21243:12
interstate 219:25
intimidate 173:13
250:3,7
intimidation
272:23
investigate
278:14,16,20 279:8
investigators
229:24 230:2,5,9,
13
invite 266:15
involve 173:19
involved 160:13
165:7 167:9
170:17,19 175:16
181:13 1923
195:24 221:17
228:15 234:20
235:3,9 244:1,2
267:16
involvement
161:17 167:2
175:22 267:18
involving 165:14
issue 162:3 229:8
247:9 264:25
issued 186:9
issues 266:13
J
January 168:18
174:10,20 290:23
Jersey 203:11,14,
16 273:3 284:4
294:16,18 296:9
JF 253:22 254:9,23
Joan 238:24239:1
Joanne 220:2
225:5 243:17
257:13
Joel 161:1,9
164:22 200:8,17,18
215:7,15,19 217:17
Joel's 167:12
John 238:10
Johnstown 278:11
287:4,13 288:23
289:8,25 292:3,6
join 241:4
Jonathan 195:22,
23 205:10,18
218:19 219:8
238:12 281:7,9,13,
17,22 288:7 290:2,
21,23
Jones 249:9
251:17 252:5,9,11,
16,19 253:2,9
254:14,24
Jr 259:2 291:1
judge 197:25
231:8,14,21256:6,
18 291:11293:7,23
judges 256:25
297:11
judgment 217:4
judicial 161:2
167:22
July 200:16201:7
jump 296:19
June 164:21
170:24 200:6,24
213:5,25 215:14
216:1,10217:3,12,
25 218:1237:12
238:15 240:22
241:21,23 242:4
245:18 251:13
254:22 257:21
258:17,22 270:14
282:5
junk 227:21
jury 253:8
Il
Kevin 279:10
kid 239:23
kids 234:19,20
kind 202:18 219:5
242:11289:4
knew 211:19
215:4,10 216:11
221:2,3 267:15
276:12
knock 262:9,14,20
263:8,1 1,13,24
knowledge 172:20
175:12 185:17
196:21 197:17
205:12,19 209:13
210:12 213:8,19,22
216:14 223:3
241:15,17 273:13
284:17 286:1
289:10
Kraft's 271:18
L
Ladony 238:12,24
240:16
lady 189:3
land 274:5
landscaper
236:15,18,20 249:6
250:25
landscapers
236:17
language 218:1
252:5
lap 239:22
Larmartini
162:10 170:19
174:22 179:5
197:9 198:8 200:4,
17 206:6,23 207:4
212:22 214:12,15,
25 215:11216:1
217:12 260:3,7
Larmartini's
162:24 206:12
lasted 249:20
late 165:2
Lauderdale
203:21
law 160:23 162:12
163:2 173:19
174:4,13 192:20,23
193:10,14 195:8,24
196:2,13,20 197:3,
10 198:9,11200:19
202:8,9,10,21
203:24 204:2,4,22
206:8,24 207:8,17
208:9 211:20,22
212:20,23 213:3
214:22 217:3
218:16 219:6,16,25
221:14,17 222:20,
25 223:1,14 224:12
228:24 232:1,3,10
235:4 240:21
241:1,2,4,13 242:1,
3 244:11,12 251:4
255:1267:5 269:6
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: insistence -leaks
275:15,20 276:1,9
278:7 279:3 280:5,
12 281:9,14,17,22
282:7,14,18
283:12,16,19,20,23
284:13 286:8,19,23
287:19,23 288:4
289:9 290:19
291:21292:4
lawful 219:25
laws 167:23 244:10
lawsuit 161:1,3,6,7
163:9 167:19
170:15 171:22
174:2 175:16
187:24,25 198:22,
23 199:1201:18,19
257:10 270:12
296:22
lawsuits 162:11
163:1 164:9
165:15 167:21
168:15 171:17
185:15,16 186:21
201:22 205:18
206:23 211:20,23
213:20,21 245:25
247:23 275:22
lawyer 186:3
195:15 204:5
205:25 214:19,21
228:24 243:9
244:4 249:9 255:4
259:9 264:19
279:11284:13,20
286:7,19,22 292:1,
2
lawyers 173:9,11
196:15 267:7
283:19,22
lawyers' 196:4
laying 209:18
layout 263:22
lead 255:10 270:22
277:16
leading 276:22
277:8
leaks 297:9,10
learn 173:1271:18
277:22 294:1
learned 213:6
221:18
lease 189:1287:23
288:3,6,7,13
leased 193:4
leases 192:20
193:2
leave 180:5,7
238:4,5 249:8,16
259:19 295:14
leaving 240:19
left 164:23 195:8
200:6 215:15,16
legal 171:11,14
174:3 178:9 198:3
212:11 217:4
262:12 264:19
267:2
legitimate 162:8
lengthy 169:13,17,
23
letter 180:16,19
200:6 215:16,24
251:9 257:1,4,11,
13,16,24 258:14,16
267:24 268:3,9,18,
20 269:9,16,20
270:8 271:12,15,18
279:15,19
letters 207:16
212:19
letting 207:13
Lexus -nexus
233:15
Liability 259:23
license 202:10
203:16 214:22
228:21
lie 231:7,17 232:2
271:8
lied 163:8 231:3,
14,20,25 256:24
lies 221:8
likes 179:25
Limited 259:22
lips 198:21
list 198:10 278:9
291:1
listed 175:6192:7
202:25 261:12
284:7 287:8
listen 277:22 278:2
listened 256:23
listing 291:25
lists 279:5 280:8
litigate 173:18
litigating 162:3
litigation 160:11,
22 186:13 197:3
223:24 224:5,24
247:20 248:21
297:4
live 168:24 289:13
290:9
lives 289:9 290:12
living 202:22
LLC 175:16
176:12 177:8,9
178:2,5 179:14,22
184:17 185:19,23
187:2 259:22
261:15
loan 210:2,4,5,20,
21,25 211:1
loaning 167:10,11
loans 196:14
209:24
local 216:3
located 176:18
191:20 193:9
196:20,22 207:18
location 281:10
288:4,22
long 173:16,17
245:7 250:9
288:13
longer 207:9 214:7
298:17
looked 243:18
lose 294:18
losing 263:1
lot 182:16229:10,
12,14
love 239:10
Lucky 167:7
T1
M- o- h -1 -e -r
213:14
mad 271:22 272:1
285:11,14
made 162:2165:12
166:4,7 189:4
203:7 205:21
206:19,21210:8
219:15 229:1
231:18 237:2
239:25 242:9
246:7,9,12 248:20,
22 258:10 259:18
272:23 277:1,6
279:12,19
maiden 233:12,14,
19
mail 189:5
mailing 278:11
279:5 280:8
main 192:14
247:16
maintain 297:6
make 162:1168:15
180:8 193:23
211:16 214:22
217:14 219:8
223:9 229:25
230:21244:15
245:18 246:1
248:9 250:3,7
262:2 263:25
288:5
makes 260:24
making 196:14
204:19 213:6
276:20 277:9
man 202:17234:15
manage 191:3
manager 175:24
176:13 177:14,16,
17,20,22, 184:24
261:12 272:4
manages 191:3
managing 178:2,3
186:15
March 197:8
198:7
mark 176:5
180:10,11 185:19
189:22 192:17
193:20 251:9
marked 176:7
180:12 184:14
185:20 187:9
189:19 190:12
194:3,5 251:10
marriage 233:20
Martin 169:18
171:19 176:13
177:21222:23
264:13 284:9
Marty 204:16,18
229:23 230:2
236:3 238:12
256:22 298:4,7
Matt 195:17
matter 218:13
matters 173:19
297:5
mayor 271:7 272:4
meandered
248:25
meaning 243:10
meant 230:15
Meenu 291:2
meet 247:2,5
meeting 220:1,22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: learn-mind
222:1,4,8 225:23
228:6 237:1,9,10,
11,21 238:5,10,15
240:7,19,22 241:25
242:4,10,14,25
243:2 245:17
248:2,23 249:16,
19,23 250:2,13
251:8 253:20
255:19,25 256:2,4
258:17 259:5,10,13
282:5
meetings 181:17
198:9
member 178:2,3,6
217:20 231:18,20
241:2 242:1,3
290:6,7 291:21
members 224:12
memo 221:11
228:5,6 234:10
255:20,21
memorandum
169:15,21,25 222:7
memorialize
218:5
memorize 201:10
mention 225:1
mentioned 273:11
Mesa 205:9,17,25
Mesa's 205:11,12,
19
met 174:10 294:22
MGRM 177:23
Michelle 183:5
middle 214:2
Middlebrooks
231:8,15
midnight 293:20
migrate 247:13
million 274:3
275:1
millions 229:7,8
mind 221:23
248:1,3,10,12
252:18 265:6,22
mine 202:5,6
minimum 206:7
minute 182:5
187:6 242:16
298:15
minutes 181:17
249:20 298:19
mission 160:16
Misstates 262:16
mistake 214:22
mister 163:10,25
203:10 234:7
259:21
mobile 286:3
model 209:19
Mohler 213:14,16
moment 208:21
263:2 265:4
moments 200:9
money 164:5
165:16 166:17,18,
20 167:10,11 197:4
208:9,10,13,20,24
209:1,2 210:13,15
211:16212:10
270:25 272:21
moneymaking
190:5
month 200:24
252:12 295:17,22,
25 296:6
months 181:25
201:20,23 251:5
290:19
Morgan 230:24
237:7 239:20
296:23 297:24
morning 218:6,15
229:22 230:2
motion 219:23
221:6,8 225:4
227:7,10,11243:6,
21 245:7,8,23
246:3,16 247:12,
17,20 248:4,6,25
249:2 254:25
260:19,23 275:14,
17,24 276:5,6,11,
16 278:14,19
279:25 280:1
285:4,11290:24
291:6,11, 292:20,
25
motivation 255:11
move 232:10 235:3
248:14 267:21,22
288:17
moved 290:21
multiple 267:20
N
names 170:22
191:9,14 262:23
265:5
nature 194:25
neared 236:22
necessarily 185:7
216:17
needed 169:5
223:13 230:9
266:4
negotiations
223:19,23 224:4,
11,23
neighbors 271:22
272:1,2
Newport 176:13,
17,25 181:14
188:18 192:10,20
193:5,15,17 196:24
nice 173:5 298:9
Nick 217:25 218:1,
5 295:2,3
night 165:2,4
200:10 229:22
230:1,3 242:20
293:19 294:20
nonsense 204:9
normal 252:19
north 176:15
284:9 285:25
290:1
not - for - profit
168:14 211:13
notch 185:3 262:9,
15,20 263:3,9,11,
14,265:24 266:2,4,
10
note 209:18,20,21,
22,24
notes 222:10,14
notice 275:3
298:12
November 278:7
282:15,19 283:4
290:21
November/
december 283:1
number 203:1,2
274:21283:8
284:10 286:3
293:15
numerous 279:18
O
O'boyle 160:7
162:18 165:11
169:18,19 171:20
172:13,21 173:12,
16 174:4,176:13,
15 177:18,21
180:22 182:2
187:12 189:23
193:14 195:8
196:13 197:3,10,21
198:11 19920,24
202:4,9,21,22
203:24 204:2,4,12
205:10,18 206:8,
16,24 207:8,13,17
208:4 212:23
217:3 218:16,19
219:6,9,16,24
222:20,24,25
223:1,14 229:4,6
233:4,25 235:17
237:21238:12
240:21241:1,13
242:1,3 244:18,21
257:9,16 265:7
268:5 271:11
272:14,25 275:15
276:17 278:5,7
279:3,21280:5,12
281:14,22,23
283:12,16,20
284:9,13 286:8,19,
22 287:7,19,23
288:3,8 290:19,21,
23 291:20,21292:4
293:14,23 294:1,4,
17 297:11
O'boyle's 201:24
256:16,18 264:14
293:21
O'conner 231:1
247:7
O'connor 180:15,
20 220:2,20,22
221:11222:3,17
227:9 233:1 1,17,
18,22 236:10 238:2
248:18 257:14
258:18 269:25
270:1297:19
O'connor's 228:5
O'hare 290:25
293:16
oath 167:8
object 162:15
163:3 164:13
194:24 197:5,11
198:13 204:6
219:20 221:21
254:17 255:2
284:22 286:13
292:7
objection 162:13,
14 163:5 164:14,15
165:18 168:9
171:4 176:1 177:6
178:10 179:8
188:6 192:25
196:17 202:12
204:25 205:1,2,14
206:25 207:20,21,
22,23 208:15
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: mine -office
213:10 223:7,10
235:7,10,11,18,19,
25 245:2,3 250:5
253:11 262:16
264:6 266:22,24
270:10 271:24
276:25 277:2,4
282:9 283:10
285:9
objectionable
261:17
objections 218:24
277:7,9
obligated 276:8
obligation 209:8
270:15
obligations 209:7
218:10 276:9
obtain 264:24
obtained 267:25
occupied 188:18
occupies 188:20
occupying 175:10
occur 223:2
230:16 244:10
occurred 205:20
206:1245:18
October 295:9,15
296:11297:16
299:6
offensive 264:4
offer 218:13 242:9
246:6,9,12,14
270:24 274:1,2,11
offered 198:3
270:23 272:21
274:25
offers 219:15
office 186:4
193:10,13,24 198:9
200:19 202:9,21
204:3 206:1
239:16,19 258:3,4
259:19 278:10
282:21,24,25
283:4,8 287:17,20,
22
officers 171:2
282:1,3
offcership 182:14
offices 193:6
203:21291:22
one -copy 257:3
open 171:10 251:3
259:5,8,11,16
266:20 271:6,12,23
272:7,21
opened 202:21
204:3 251:5 283:4
opening 250:12
258:19 282:24
operates 289:3
opinion 230:6
232:1,3,4,10 267:2
opposed 210:2
opposing 173:11
220:5 277:11
orally 214:13
order 169:5
175:14 263:13,16
269:5
ordering 299:19
organization
218:12
organizational
217:22
originally 278:6
out -of -state
284:20
out-of- state-
lawyer 284:8
overbilling 253:3
owned 174:25
182:9
ownership 176:24
182:20
owns 176:21,22,25
177:5 196:23
P
p.m. 160:3 245:11,
13,14 298:22,24
299:22
PA 287:4,13
288:23 289:8
292:3
Palm 182:17
187:24 224:16,19
225:1253:15
paragraph 166:25
167:19,24 278:19,
20 279:1,9,24
281:21284:6
286:17 290:18
291:4,5,8,10,16,21
292:9,23
paragraphs
292:25
paralegal 206:20
Pardon 190:2
196:10 208:25
210:14 239:17
284:23 289:21
292:14
part 161:23 164:20
172:3 200:6 214:3
215:14 221:12
246:5 275:22
283:19
participate
204:23 240:22
parties 210:4,6
276:24
partner 179:4
195:16 241:23
party 171:25
277:11,13 282:25
passed 239:23
past 201:20
pay 168:25169:5
183:24 184:1
196:4 208:23
209:5,8 270:23
paying 175:3
payment 219:4
payments 196:14
219:5
pays 183:22
PC 279:3280:5,12
281:22 283:16
292:4
pending 194:19
246:25 291:2
Pennsylvania
203:1 235:4 278:9,
11279:7 280:9,
281:19,24 282:8
283:9,19,23 284:1,
4,7,12,19,21
285:24 286:3,9,11,
18,24 287:2,3,8,10
288:19 289:13
290:20 291:23,25
292:5
people 161:25
170:22 173:12
179:7 216:15
237:2,12,22 242:6
246:21249:5,6,10,
22,25 252:13,14
256:17 262:14,20
263:10,25 264:8,9
267:14,25 268:5
269:23 271:5,17
272:3 273:21,22
297:8,25
people's 262:25
period 168:17
169:14,213:24
215:13 295:12
permanent 276:3
permission
213:22 222:19,24
223:15 240:21,24
260:15 290:9
permitted 277:12,
24
person 183:5
186:2,6 274:21,25
personal 198:4
personally 168:5
172:13,15,23
Index: officers- president/director
258:10
Peter 217:15
phantom 201:19,
21
Philadelphia
279:6 280:9,19
281:4,19,24 282:8
291:23 292:6
phone 167:12
196:3 203:1,2,6,7
222:6 283:8
phonetic 217:15,
16 238:12 279:11
physical 175:10
pick 261:14
piece 227:21
233:24 234:2
246:17,18,19,20
PIS 230:20
Pittsburgh 289:19
place 219:2237:11
264:21
plain 244:2
plaintiff 163:11
168:2,4 169:15,18,
25 170:2,9 171:8,
22 172:14 185:16
186:12 212:1,4,9
228:17,19,23
plaintiffs 168:1
plan 295:12
planes 182:4,6,9,
12,15,19,23,24
183:1,7 254:3,6,19
plans 295:9
platforms 239:15,
18
playing 207:13
pleading 233:23
pleasure 294:5
297:3
plenty 234:8
pm 298:25
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
point 171:23 205:4
218:17 245:4
254:10,11 257:18
263:6 266:25
279:10 290:14
pointing 251:3
points 230:18
police 297:24
policies 219:15
portion 194:22
299:18
pose 279:17
position 162:21
204:3,21244:22
256:1261:18
Post 224:17,20
225:1
practice 202:10
204:22 221:14
244:12 289:9
practiced 281.17
283:22 284:13
286:20 287:3
practices 244:11
287:9
practicing 214:21
283:19 284:20
286:8,24 292:3
precedent 247:3,5
prejudice 276:6
preparation
161:18 296:14
prepare 214:16
222:7,14
prepared 162:5
169:21214:23
227:8 283:15
285:13
present 198:8,12
president 170:23
181:19 187:18,21
190:20 281:24
president/
director 217:18
pretty 192:18
227:15 293:5
previously 201:4
principal 181:1
279:4 280:6
printout 176:11
193:15
prior 167:20
225:24 226:4
282:5,15
private 229:23
230:2,5,9,12 244:5
privilege 197:13
privileged 223:25
224:6
prize 277:5
pro 290:21,24
problem 217:20
234:21294:23
proceeding
221:19
160:1
process 274:8
produce 274:24
275:3
professional
290:20
profit 209:19
279:3 280:6
program 258:13
project 274:4
promote 168:1
proper 217:21
properly 218:9
properties 236:11
237:23 289:12
property 176:21,
22 177:5 287:15
289:19,20,22
proposal 245:19
248:1,3,10,11,12,
16,17
proposals 248:20
propose 245:21
proposed 245:22
propounding
175:19
prosecuted 163:2
protect 266:17
protected 266:17
protects 266:8
267:3,9,10,11,13
provide 198:3
provided 208:7
286:2
PRR 218:9
psychiatrist 255:5
public 160:10
162:1,2 163:1
167:23 168:15
172:22 174:12
175:19 179:21,23
185:5,9,19,23
186:9,12,20,21,22
187:2,5,24 198:4
204:23 206:7,23
208:19 211:25
212:9,14 213:6,17
218:11268:12,21,
23 269:1,6
publicly 240:4
pull 182:14
purpose 160:21
161.•23 162:10
185:1 189:2
242:15 248:24
255:16 258:19
262:14
purposes 162:23
185:5 194:13
2272,3 228:2
242:14 248:23
262:19
pursuant 219:15
pursue 275:25
276:8
pursued 221:15
put 168:20 202:8
204:2,235:21
236:24 244:4,21
249:15 260:12,14
261:19 262:4,22
263:20 264:3,12
265:4 267:5,8
269:1271:20
292:24 293:22
299:17
putting 261:9
270:16,20
I
quarter 274:3
275:1
question 165:3,11
174:24 175:2
176:23 179:16
181:12 186:8
194:19 197:13,24
199:8 212:7
219:21220:16,
223:18 236:2,6
238:1255:7,12
261:7 267:20
272:16,17,18
277:19 287:5
294:10 297:12
questioning
298:13
questions 168:10
182:16 184:6
196:25 197:15,21
202:18 204:7,19
205:6 207:14
218:3 219:18
227:14 244:19
255:10 264:23
276:21,23 277:18
279:13,16,18
290:11,16
quicksand 200:20
quote 233:23
quotes 167:17
228:2,8
quoting 232:7
R
rafting 296:18
raised 249:14
250:10,25
ramifications
244:10
ran 239:15,18
Randolph 220:2,
20,21,23 222:18,22
223:4,13,16,22
224:3,8,17 225:11,
14 226:11227:16,
18,23 228:10
229:16,19 230:8
233:23 234:9,11
236:10,16 237:7
238:2,4,24 240:15
242:16 247:7
248:18 249:4
255:19 256:11
258:18 259:19
270:1
Randolph's 228:5
reached 292:1
read 194:19,21,22
224:2 225:22,24
226:4 227:9,10,11,
15,17,18,19,20
231:9,10,11232:21
233:1,5 255:12
256:13 278:18
280:3 291:6,
292:9,20 299:18,21
reading 223:8
258:15
real 273:7,12,13
288:11
realize 235:21
realized 285:13
reason 165:12
166:11 227:3
233:13 248:24
250:3
reasonable 253:1
reasons 162:22
270:17,22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: pretty- rectify
recall 170:25
171:5 174:15,19
200:14 226:23
230:5 232:14
243:17 253:19
254:20,21261:11
275:5 281:20
282:23 283:2,6,13,
17,21,24 284:2
receipt 219:10
received 203:8
218:24 222:20,24
285:4
recess 245:13
298:24
recited 284:6
recognize 246:20,
22 257:16 280:19
recognizes 194:16
recollection
201:11227:16
230:17 251:1
record 160:4
163:1 194:22
199:6 219:20
220:14 241:7
245:12,15 246:4
268:12,21,23 277:4
293:22 298:23
299:1,15,16,17
records 160:10
162:1,2 167:23
168:15 172:22
174:12 175:19
178:13,14 179:21,
23 185:5,9,19,23
186:9,12,20,21,23
187:2,25 192:8
198:4 199:14
200:3 203:6
204:23 206:7,23
211:25 212:9,14
213:6,17 218:11
247:22 269:1,6
286:7,10,12
Records.com.
187:5
recounted 248:17
rectify 225:21
226:25 227:4
Red 273:3
refer 170:10 171:9
252:20
reference 230:21
260:24 261:15,16
referenced 218:8
referred 252:21
referring 216:18
256:10 263:9,10
reflect 284:12
286:7,18
reflected 287:2
reflecting 292:5
refresh 201:11
refuse 214:18
279:14
refused 215:19
230:16
regard 173:4
184:12 187:1
203:24 235:14
244:11264:21,25
279:23 280:18
288:4 299:7
registered 175:25
176:14 187:15
190:19 193:13,24,
25 259:1260:10,
13,20 261:1,
278:10 286:23
registration
203:13
regret 218:8
reinstatement
176:12
reiterate 219:14
related 181:4,6
relating 167:22
223:24 224:4
relief 276:1,3
relies 256:17
remain 217:19
remarkably
256:15
remember 164:20
165:3 166:21
170:12 201:9
220:24 225:3,17
230:20 231:22
236:14,15 238:13
250:24 251:1
253:17,23,25
254:10,12
remorse 243:18
removed 260:20
remuneration
212:1,3,6 241:16
rent 175:3
rental 288:11
repaid 209:16
repay 210:23
211:10
repeatedly 240:4
rephrasing
196:12
replacements
217:14
report 233:15
reporter 194:23
representation
291:24
represented
211:22 295.2,3
representing
228:2,8
reputation 263:16
request 206:7
211:25 212:9
269:3,5 274:24
requests 162:1,2
163:1 168:15
172:22 174:12
175:20 179:21,23
185:6,9 186:10
198:5 212:14
213:6,17 297:7
required 170:8
240:13 275:20
reside 203:10
281:7
resided 290:14
residence 288:18
289:8,10
residential
289:12,20,22
residents 264:5
resides 203:18
280:23,25 281:5
288:20
resign 215:25
217:13
resignation 200:7
215:16,18
resigned 166:12
200:5 214:1,4
215:12
resigning 165:13
resigns 164:24
resolve 278:16
resolved 242:23
249:2 294:23
resolving 246:2
respect 292:25
respond 218:9
238:2 256:20
270:15 294:6,8,11
responded 219:13
224:17,18,21
229:19
responding 229:8
response 237:24
279:16
responsible
244:25 245:1
rest 173:17 295:8
retaliating 255:16
retract 164:11
166:5 167:6
returning 167:11
returns 189:10
reveal 220:7
review 160:16,19
246:21
rid 243:14 245:22
246:3,24 247:1,17,
19,22
ridiculous 204:19
273:10
rights 276:7
Ring 162:9170:16
174:21 179:5
197:8 200:17
213:1216:8 217:2,
13 220:1,3,9,11,19,
21222:3,14,17,25
223:15 240:25
241:1,13,21,25
242:3,22 245:18
258:21259:2,13,15
260:9,20,25 261:1,
9 265:18
Ring's 162:23
260:12
rip -off 267:7
ripped 252:17
ripping 253:10
risk 256:19
River 296:18
road 289:25
Roanoke 191:21
rocket 236:16
room 169:6 223:20
row 173:9 199:10
Rubicon 225:20
226:2,16,22,23
ruin 271:20
run 179:7 233:15
270:18
running 182:25
rush 204:1
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: Red -settle
Russell 174:22
178:20,21 179:4
217:19
Ryan 174:10
195:6,20
S
salaries 196:4
salary 183:22,24
184:2
sanction 243:11,
13
sanctions 243:20
245:8 260:19
Sasser 291:2,11
sat 256:23
Saturday 297:18
save 175:15 199:11
239:14
schedule 293:21
294:13 295:8
scheme 164:8
secretary 164:22
169:6 172:21
178:18,19,21 179:3
181:19 183:20
200:8 206:20
213:13 215:14
254:7 259:23
260:2 283:25
seek 276:2
send 164:19 201:3
213:2 217:21
223:6 231:12
268:3,4 275:3
September 294:1
295:9
serve 184:4235:22
served 235:24
260:23
serving 220:11
set 180:9 270:20
settle 218:13,19
227:5 246:1,14,15
247:20 248:2,11,20
settled 165:15
208:18
settlement 217:5
219:1,8,15 223:19,
23 224:4,11,23
227:2,3 239:6
240:9,10,12 242:9,
12,14,20 243:3
245:19 246:6,9
247:10 248:7,9,16,
17,19,23 255:25
256:2,4,8
settles 208:10,14
Seventh 161:2
shame 228:14,15
264:9
share 255:23
shared 224:11
256:12
sheet 193:24
Sheila 176:15
shit 233:24 234:3
246:18,19,20
276:16 291:7
shitty 291:8
shock 249:7
shocked 249:5,6,8
short 296:10
show 174:14
176:5,10 177:19
185:18 193:12
198:20 201:15
202:19 214:23
237:3 279:15
showed 222:16
233:15 269:22
283:7
showing 190:10
193:14 216:19
sic 273:3
Sid 221:25
side 246:7,10
248:20 256:7
sign 264:12 267:5,
8 288:5
signed 225:11
243:17
signs 231:22,23,25
silly 298:8,10
Silver 273:3
similar 256:15
simply 256:10
sir 175:6,11,25
176:20 190:11
199:16 205:20
206:12 237:19
290:8
sit 233:7 250:15
sitting 230:25
Skip 220:21,23
222:5 227:15,18,20
228:16 236:15
238:24 240:15
243:21,22 257:18
skull 217:11
sleeps 290:2,4,17
slept 290:14
slew 229:23 230:2
smart 189:5
smiles 262:25
Smith 162:15
163:3 164:13
172:12,16 173:5,
10,21 197:5 201:15
204:16 205:1,14,21
206:25 207:21
219:20 223:7,11
231:1235:10
236:2,4 245:2
257:20 266:23
280:1284:22,25
286:13 292:7
293:24 294:9
298:4,7
sober 236:12,
237:24 249: 14,15,
24 250:10,12
251:3,6 258:12919,
22 259:5,9,16,22
261:15,17 262:4
263:20,23 264:20,
21265:1270:17,20
271.•6,12,20,23
272:7,10,22
social 162:22
sole 160:21 162:10
189:2 207:17,25
solicited 168:5,13
204:22
solution 201:3
son 162:11 163:2
164:7 173:19
174:10 192:19
198:3,17 202:8,20
203:10 204:2,21
216:2,9 228:16,23
235:3,15,16,21
238:25 244:9,21
265:16 278:5,23
279:17,18 281:12,
16,21282:6,14,18
283:12,14,18,23
284:18 285:22,23
286:22 287:1,8,19,
22,25 288:1,16
289:6 290:8,12,13,
17 291:10
son's 160:22
165:14 173:19
192:20 193:10
212:20 219:24
251:4 278:6
sophisticated
211:2
sort 242:11243:25
247:13
sought 168:2
space 175:10
193:3,6,10 288:4
speak 222:19,23
223:15 273:24
278:23
specific 209:17
245:9
specifically 170:8
209:15 279:17
Specifics 174:8
254:12
speculate 266:25
speech 256:21
speeches 277:1
speed 292:22
spend 167:13
295:7 296:9
spending 294:2
spoke 220:3,19
242:6 264:17
spoken 289:2
spread 268:4
stand 259:12
standing 189:7
start 237:20 293:4
started 242:25
247:12,13
starting 264:9
state 171:18
176:10 192:8
195:15 202:11
208:19 226:3
244:11259:23
270:19 272:20
278:10 279:2
280:4,11281:25
284:14,20 286:9,20
290:6,22 292:1,5
295:10,13
stated 209:11
240:4,7 254:4
258:14,16 259:8
271:5 293:22
statement 160:17
162:4167:6
193:12,23 205:21
206:18,19 225:24
229:25 253:9
256:11259:18
280:13,16
statements 256:16
276:20 277:10,20
states 166:7 298:3
stationary 283:14
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: settled-substance
statute 212:2
stay 223:19 288:14
293:19
stayed 168:17,21
staying 174:17,18
steal 166:16,20,22
stick 237:17
stole 164:4 166:14,
18
stop 184:17187:23
188:4 207:13
251.•3
Stream 172:17
176:16 213:7,8,17,
21236:11237:3,24
257:10,12,25
258:12,19 263:21
264:5,8,13,22
265:2 270:17,20,21
271:5 284:10
290:25 294:3
Street 278:11
279:6 280:8,19
281:18,23 282:7
283:16 287:4,13
291:22 292:3
strike 240:20
267:17 282:15
285:22
struggling 270:24
274:13,14
Stubbs 220:23
221:25
stuck 200:19
stuff 164:23
165:24 178:15
204:18 215:15
stupid 244:2
subject 200:17
238:18 249:21
subpoenaed
269:19
subsidiary 181:6
substance 220:8
261:4
sudden 237:15
sue 173:13
sued 172:17,19
232:17 269:16
sues 173:11,12
suggest 256:19
267:21
suggested 229:23
230:1
suit 161:11 199:3
suits 246:4,25
247:22
sum 219:7 270:23
274:2
Sunday 297:19,20
Sunshine 167:23
supposed 195:15,
16 210:25 211:1
238:7,8,9,23
274:25
Supreme 284:12
286:6,11,18,23
287:2,9 291:25
surgery 236:21
surprised 173:22
surrounding
270:21
suspend 293:13,
20,21294:4
298:12,13,16 299:3
Sweet 259:22
261:14 263:23
266:21272:10
Sweetapple 160:5
161:15,16 162:17
163:6,12,16 164:17
165:20 168:11
171:6 172:1,9,14,
19 173:7,23 174:1
175:23 176:2,9
177:7 178:12
179:9 180:7,10,14,
18,21 184:16
185:22 I87:I1
188:8 189:21
190:17 193:1
194:7,11,15,21
195:1 196:18
197:7,20 198:16
199:3,7,12 201:17,
21202:1,3,15
204:10,20 205:5,8,
15,24 207:2 208:3,
16 212:13,17
213:12 216:17
217:1219:22
220:10 221:22
223:9,225:12
228:4,9 231:2,12
232:11,16 233:2,10
235:8,13,20 236:9
240:3 241:12
244:7,17,20 245:6,
16 250:11251:12
253:13 254:18
255:6,24 256:13,23
257:5,8,15,19,23
261:8 262:18
264:11,20 267:1,5,
6 270:2,11271:10
272:6,17,19 273:14
275:18 276:5,12,
19,22 277:8,16,19,
24 278:3 280:2
283:11285:3,10
286:11,15 292:8
293:2,10,12 294:7,
12,15 297:13,23
298:5,10,18 299:2,
10,12,17
swore 291:20
sworn 162:20
163:7 172:25
290:23 291:10
T
table 180:6225:7
taking 219:1
261:18,24 293:14
299:8
talk 242:12,17,18,
19 243:15 251:7
254:5 257:1
275:14
talked 243:5,25
245:24,25 246:2,
23,248:24 249:2,4
250:23 276:19
talking 179:11,13
199:1,3,5 201:20
202:24 204:9
206:13,18,19 212:3
213:24 216:1,8
237:11,21 238:18
241:8 246:4 247:6,
12 249:21277:15
targets 230:10,11,
13
tax 189:10 210:24
Taylor 162:13
163:4,11 164:8,15
165:14,19 205:2
207:22 218:1
219:12,13 235:18
255:2 256:20
293:22
telephone 218:6,
22,25 274:21
284:10 286:3,4
telephonically
198:8
telling 167:8172:5
197:15 234:9,12
247:14 267:2
285:22 297:2,14
temporary 201:3
tenant 174:25
181:10
terminate 250:2
terms 170:13
209:7 218:23
298:10
terrible 203:5
231:18
testimony 163:7
172:25 214:24
218:2 248:18
262:17 295:21
297:16
thing 203:5 239:21
242:13 243:4,14
things 173:12
201:10 243:16
263:3,24 267:11
293:1298:19
thinking 250:12,
14
Thirdly 250:8
thought 226:11
227:14 249:11
252:10 255:4
261:17,19,24
262:8,9,24,25
263:1,23,24 264:1
265:25 274:12
Thrasher 231:9
238:7,8,16,23
239:9,22 240:1,5,9,
11,13 269:2 271:8
291:1
Thrasher's 295:1
threat 167:15
250:20 259:12,14
threaten 259:7
threatened 223:24
259:5
threatening
250:16 251:2
threats 224:24
Thresher 269:22
threw 225:7
Thursday 294:22
time 160:3167:13
168:18 169:11
174:6,16 175:15
183:6 197:14
199:11207:12
215:5,10,13 220:12
222:7 233:18
234:8 239:21,22
241:2, 245:11,14
250:22 276:24
285:12 293:10
294:2,18 295:7,12
296:9 297:23
298:5,13,22,25
299:4,14
times 166:3173:16
199:10 217:9
267:21
tin 273:1,2,16
title 177:20,22,23
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: sudden-treated
178:4
today 194:2 215:7
219:14
today's 293:25
told 165:22 178:24,
25 179:2 182:10
183:5 184:10
193:9 197:14
200:5 214:12
222:3,5 231:6
233:8 238:4,22
244:23 248:13
251:23 268:6
275:7,13 288:15
295:3
Tom 238:11,24
240:16
tomorrow 295:14
ton 270:25
top 264:10
topic 237:18
touched 234:16,25
235:1
town 172:17 213:7,
17 231:21,24
232:2,4 236:24
237:3 239:14
240:8 250:17
251:3,8 252:14,20
257:24 261:16,18,
24 262:2,21
267:24,25 268:3,9,
23 269:16 271:20
272:4 290:25
294:2,21,24
townhouse 281:4
track 294:18
train 263:1
transcript 228:3
231:10,11
transparency
168:2
treasurer 187:19,
21 190:20
treated 235:15,16
troublemaker
221:2
true 164:16 211:21
272:22,24 277:10,
20 278:21,24
279:9,24 280:13,15
291:12 293:1
trust 288:2
trusted 217:16
truth 172:6 234:9
turn 236:12 237:23
273:2,16
two- and -a -half
255:21
two- and -half
255:20
Tyne 279:11
type 204:18
231:22,23,24
U
Uh -huh 247:8
unable 247:2,4
unauthorized
204:22 221:14
unaware 217:23
219:1284:17
285:1
understand
173:3,11200:23
211:12 212:8
215:1219:7
248:15 270:7
276:4 282:18
understanding
169:16,21 170:1
212:12 219:10
understands
212:13
understood
218:16,18
unencrypt 215:22
unequivocal
218:23
Unethical 267:5
unique 167:25
unknown 270:22
unpleasantness
166:6
unproductive
221:9
untenable 235:22
untrue 233:4
291:15
unwilling 247:4
upset 267:25268:2
urgency 293:18
utilize 266:15
V
vacations 297:7
valor 221:12
Vargas 267:7
verbal 269:4
verbatim 167:16
verified 290:24
291:11
versus 161:1,8
vice 290:22,24
vicinity 259:15
288:18 290:9,15
victory 239:22
vindictiveness
235:24
violation 264:2
violations 167:22
171:10
violent 234:14,24
Virginia 191:21
289:14,15,24 290:1
295:20,24 296:5,12
visit 166:6
Volume 299:24
voluntarily
270:16
voter 203:13
W
wait 242:16 255:24
299:5
walk 270:7
walked 243:1
wanted 166:14
188:5 201:24
221:25 238:11,16
247:17 248:6
252:23 254:8
263:17,22 264:12
265:24 266:2
268:7 274:17
watch 202:6
watching 253:23
254:9,23
water 270:21
website 187:3
Wednesday
294:19,20
week 206:7,24
215:8 294:19,24
296:10,13,24
weekend 296:16,
20
weeks 169:9,14,24
207:5 293:24
294:17 295:4,5,6
297:7
west 176:13,17,25
181:14 188:18
192:20 193:5,15,17
196:23 289:14,15,
24 290:1 295:20,24
296:5,12
whatsoever
163:19 202:14
whitewater
296:18
whoa 236:19
Index: troublemaker -young
whorehouse
264:14,16 266:21
wife 175:25 187:15
190:19 204:14
229:17,21230:1
265:14 288:5
296:8
William 174:21
259:2 291:1
windfall 164:8
218:21
withdrawal 276:7
withdrawn 248:6
275:17 276:6,11
withdrew 243:21
276:13
Witmer 174:10
195:6 203:23
witnesses 173:1,17
word 232:9236:15
250:10
words 229:1
271:22
work 162:21
168:6,14 192:13
195:20,21216:9
288:22 295:5
worked 288:15
working 169:2,11
173:9 201:22
203:20 215:2,8
works 168:25
169:3,4
world 244:25
289:11
worry 217:6
Worthline 238:11
write 199:25
200:16 234:12
271:2 273:17,19
275:6
write -off 210:24
writing 174:11
205:10,17 206:9,
12,21214:13,14
Debra Duran & Associates
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215:9 223:5,14
269:2,7 270:15
writings 273:22
written 209:24
240:12 270:3
288:1,3
wrong 236:17,19
wrote 198:17
199:13 200:18
201:6 214:25
215:6 217:25
234:11252:5
269:2 275:9,10,
279:11285:18
Y
y -n -n 191:19
year 164:3181:23
195:19 213:25
290:15 296:12
years 179:6
188:12,14,16
190:15,18 206:20
277:14
yesterday 215:7
218:25
York 195:15
young 189:3
In The Matter Of-
A114 R TIN E. O'B0YLE v.
TOWN OF GULF STREAM
Deposition of MARTIN O'BOYLE
September 15, 2014
Vol II
DEBRA URAN
A S S O C I A T E S
Registered Professional Reporters
P.O. Box 2288
West Palm Beach, Florida 33402
561 - 313 -8000
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No.502014CA004474XXXXMB
MARTIN E. O'BOYLE,
Plaintiff,
-vs- VOLUME II
TOWN OF GULF STREAM,
Defendant.
CONTINUED VIDEOTAPED DEPOSITION OF MARTIN E. O'BOYLE
TAKEN AT THE INSTANCE OF THE DEFENDANT
Monday, September 15, 2014
9:50 a.m. - 5:47 p.m.
224 Datura Street
Suite 1405
West Palm Beach, Florida 33401
Reported By:
Debra Duran - Bornstein, RPR
(Notary Public, State of Florida
Debra Duran & Associates
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APPEARANCES.
On behalf of the Plaintiff:
DANIEL DESOUZA, ESQUIRE
DESOUZA LAW, P.A.
1515 N. University Drive
Suite 209
Coral Springs, Florida 33071
NICK TAYLOR, ESQUIRE
THE O'BOYLE LAW FIRM P.C., INC.
1286 West Newport Center Drive
Deerfield Beach, Florida 33442
On behalf of Jonathan O'Boyle, William Ring
& The O'Boyle Law Firm PC., Inc.
CULVER SMITH, III, ESQUIRE
CULVER SMITH III, P.A.
500 Australian Avenue South
Suite 600
West Palm Beach, Florida 33401
Co- Counsel on behalf of the Defendant:
ROBERT A. SWEETAPPLE, ESQUIRE
SWEETAPPLE, BROEKER & VARKAS, PL
20 S.E. 3rd Street
Boca Raton, Florida 33432
Co- Counsel on behalf of the Defendant:
JOANNE O'CONNOR, ESQUIRE
JONES, FOSTER, JOHNSTON & STUBBS
505 South Flagler Drive, Suite 1100
West Palm Beach, Florida 33401
Debra Duran & Associates
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ALSO PRESENT:
William Ring, Esquire
The O'Boyle Law Firm PC, Inc.
Jason Peterson, Videographer
Legal Graphicworks
Doug Stacy, Videographer
Scott Morgan, Mayor
Town of Gulf Stream
William Thrasher, Town Manager
Town of Gulf Stream
Christopher O'Hare
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NUMBER
E X H I B I T S
DESCRIPTION PAGE
DEFENDANT'S
EX.
7
AIRLINE HIGHWAY, LLC
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PRINTOUT
DEFENDANT'S
EX.
8
CRO AVIATION, INC
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CORPORATION DOCUMENT
DEFENDANT'S
EX.
9
STOP DIRTY GOVERNMENT LLC,
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CORP DOCS
DEFENDANT'S
EX.
10
OUR PUBLIC RECORDS LLC
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CORP DOCS
DEFENDANT'S
EX.
11
COMMERCE GP, INC
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DEFENDANT'S
EX.
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CG ACQUISITION COMPANY
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DEFENDANT'S
EX.
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ASSET ENHANCEMENT, INC.
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DEFENDANT'S
EX.
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STATEMENT OF CHANGE OF
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REGISTERED OFFICE
DEFENDANT'S
EX.
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CITIZENS AWARENESS
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FOUNDATION CHANGE OF
REGISTERED AGENT
DEFENDANT'S
EX.
16
JUNE 6, 2014 LETTER TO
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TOWN OF GULF STREAM
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Page 160
CONTINUED PROCEEDINGS
THE VIDEOGRAPHER: The time is 2:36 p.m.
We're back on the record.
BY MR. SWEETAPPLE:
Q. Thank you.
Mr. O'Boyle, the Citizens Awareness
Foundation, Inc., it doesn't have any income, does it?
A. I don't know.
Q. It just exists to bring public records
litigation, right?
A. I don't know.
Q. Weren't you the one that was involved in
having the entity formed?
A. I don't think so.
Q. And didn't you review and approve the mission
statement for the entity?
A. No. I think it was Mr. Chandler.
Q. Well, didn't you review it and approve it?
A. I don't think so.
Q. And weren't you aware that its sole purpose
was going to be to front litigation through your son's
law firm?
A. No.
Q. And are you aware of the Citizens Awareness
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Page 161
Foundation versus Joel Chandler lawsuit that was filed
in the Seventh Judicial Circuit on or about August of
this year -- December 6th. Were you aware that lawsuit
was filed?
A. Can you say that again?
Q. Were you aware that lawsuit was filed?
A. Which lawsuit would that be?
Q. Citizens Awareness Foundation, Inc., versus
Joel Chandler.
A. Can you tell me more about it?
Q. It's a suit against Mr. Chandler. It alleges
that he breached his fiduciary duty and other claims.
A. I believe I am aware of that, yes.
MR. DESOUZA: That's the Complaint?
MR. SWEETAPPLE: Yes, it's the Complaint.
BY MR. SWEETAPPLE:
Q. And did you have any involvement in the
preparation of this complaint?
A. No.
Q. Do you know who, at Citizens Awareness
Foundation, Inc., caused this complaint to be filed?
A. No.
Q. As part of the -- what is the purpose of
Citizens Awareness Foundation, Inc?
A. It is to educate the people in connection with
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public records; and to make public records requests.
And to the extent public records requests are made and
they're not filled, to consider litigating the issue.
I think all of that is in the statement that
Mr. Chandler prepared. Mr. Chandler prepared it, and
whatever that says, we were going along with it.
Q. Okay. Well, he says that you absolutely were
not going along with any of the legitimate uses of
Citizens Awareness Foundation but, rather, you, Mr. Ring
and Ms. De Larmartini insisted that his sole purpose was
to go generate lawsuits and to give them to your son and
his law firm. Are you aware of that?
MR. TAYLOR: Objection.
MR. DESOUZA: Objection. Form.
MR. SMITH: Object to form.
MR. DESOUZA: He said this when?
BY MR. SWEETAPPLE:
Q. Are you aware of that, Mr. O'Boyle?
A. Can you say that again, please?
Q. Are you aware that it's Mr. Chandler's sworn
position that despite the fact that he intended to work
for those reasons, that is, that there were some social
purposes; that, in fact, your instructions, Mr. Ring's
instructions, and Ms. De Larmartini's instructions were
that he was to, on a full -time basis, go out and
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generate public record requests lawsuits so that they
could be prosecuted by your son and his law firm?
MR. SMITH: Object to form.
MR. TAYLOR: Same.
MR. DESOUZA: Objection.
BY MR. SWEETAPPLE:
Q. That's his sworn testimony.
A. He lied under oath.
Q. And, in fact, in the lawsuit that was filed,
you allege that Mister --
MR. TAYLOR: Who's the plaintiff in the case?
MR. SWEETAPPLE: Citizens Awareness Foundation
Inc. The entity that you are funding.
THE WITNESS: I know nothing about Citizens
Awareness.
BY MR. SWEETAPPLE:
Q. You know nothing about Citizens Awareness
Foundation?
A. Nothing whatsoever.
Q. So any a -mails that are between you and
individuals regarding Citizens Awareness, that is really
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A. Well, let me see them.
Q. Are you aware of any a -mails that you sent to
Mister --
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Pagc 164
A. I haven't seen any e- mails.
Q. Have you exchanged any a -mails with
Mr. Chandler this year?
A. Yes, I think I have. He stole a bunch of
money, and I asked him to please come back and bring it
back.
Q. He also accused your son of being involved in
a windfall scheme, including Mr. Taylor, where
defendants in Citizens Awareness Lawsuits were being
held up for fees that were not earned by the firm, and
you demanded that Mr. Chandler retract that e-mail,
correct?
MR. SMITH: Object to the form.
MR. DESOUZA: Objection. Form.
MR. TAYLOR: Objection.
THE WITNESS: No. That's not true.
BY MR. SWEETAPPLE:
Q. What happened?
A. He did send -- he came in, and I don't
remember the date. It was -- I think the first part of
June.
And my secretary called me and said, Joel
Chandler was here. He left a bag of stuff and an e -mail
saying he resigns effective immediately. And he wants
you to call him.
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Page 165
So I called him, and I couldn't get him. And
I either got him that night late, or the following day.
I just don't remember. And I forget your question.
Q. You said you called Mr. Chandler that night.
A. Yeah.
Q. Why did you call Mr. Chandler if you're not
involved with Citizens Awareness Foundation?
A. Because he asked me to call him. As an
example, if you asked me to call you, I would call you,
too.
Q. Mr. O'Boyle, my question dealt with the fact
that you were made aware that one reason Mr. Chandler
was resigning was because of communications between he
and Mr. Taylor involving your son's insistence that
lawsuits be settled with defendants of Citizens
Awareness Foundation for more money than was incurred in
attorney's fees and costs.
MR. DESOUZA: Objection to form.
MR. TAYLOR: Form.
BY MR. SWEETAPPLE:
Q. Are you aware of that?
A. I know there was an e -mail. I told you what I
know, I called him later on. And I said, "Where is the
stuff ?"
And he said, "You got everything you're
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Page 166
getting."
And he's never called back since. I've called
him several times after that.
Q. In fact, you made a demand of Mr. Chandler
that if he didn't retract the e-mail, you were going to
visit unpleasantness upon him, didn't you?
A. No. He made that -- he states that in an
e -mail.
Q. You never said that?
A. No. I never said that.
Q. And the only reason you were talking to
Mr. Chandler when he resigned from Citizens Awareness
Foundation is because he asked you to?
A. Well, I really wanted to get what he stole
back.
Q. And what did he steal?
A. Money.
Q. He stole money?
A. Yes.
Q. How much money did he steal?
A. I think 15 or 25,000. I don't remember.
Q. Who did he steal it from?
A. I guess -- what's the name of that company?
Citizens Awareness?
Q. And in Paragraph 10 of the Complaint,
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Page 167
Exhibit 6, the attorneys for Citizens Awareness
Foundation, Inc., which you claim to have no involvement
with...
A. None.
Q. And I'm going to give you a chance to try to
retract your statement.
A. Lucky me.
Q. Are you telling us under oath that you were
not involved in any of the activities of Citizens
Awareness Foundation other than loaning them money?
A. Other than loaning them money and returning
Joel's e -mail. Yeah. A phone call.
Q. And we'll spend a little time on that when I
go through all of the communications that I have
chronicled here, including your threat -- your threat
on -- let's go through them so I can give you verbatim
quotes. That will be the best way to do it,
Mr. O'Boyle.
So it says in the lawsuit in Paragraph 10.
"Prior to February 17, 2014, Chandler filed hundreds of
lawsuits throughout Florida (including at least five in
this judicial district) relating to alleged violations
of the Public Records Act and Sunshine Laws."
Then he goes on in Paragraph 12. "Because of
Chandler's extensive and unique experience coinciding
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Page 168
with plaintiff's desire to promote government
transparency, then plaintiff actively sought out and
communicated with Chandler regarding his possible
employment with plaintiff."
You're the one who personally solicited
Mr. Chandler to work for an entity, and Citizens
Awareness Foundation was formed the very day that he was
hired, right?
MR. DESOUZA: Objection to form.
THE WITNESS: You asked two questions.
BY MR. SWEETAPPLE:
Q. Let me break it down for you.
You're the one who solicited, having
Mr. Chandler come work for a not - for - profit entity to
make public records requests claims and lawsuits, right?
A. No.
Q. And he stayed at your home for a period of
time in January, didn't he?
A. Yeah, a day.
Q. Then you put him up in a hotel, right?
A. If he did, I don't know what hotel he stayed
at.
Q. Well, he used your funds while he was down
here, right, to live?
A. When a guy works for you, you usually pay his
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Page 169
expenses.
Q. He was working for you, right?
A. Well, when I say "a guy works for you ", a guy
works -- I used the companies together and I shouldn't.
He needed a credit card in order to pay for a
hotel room. My secretary, Brenda, got him a credit
card. I've never seen it.
Q. But Citizens Awareness Foundation wasn't even
formed for weeks after that.
A. That could be.
Q. He was working for you at the time, right?
A. I don't think so, but...
Q. And it says, "After several lengthy
discussions over a period of approximately two weeks,
plaintiff and Chandler entered into a memorandum of
understanding on February 17th."
Who were those lengthy discussions with
between plaintiff and Chandler? Was that Martin O'Boyle
or somebody else, Mr. O'Boyle?
A. It was with no one. It was Mr. Chandler, who
prepared the memorandum, is my understanding. I don't
think anybody changed it.
Q. Well, it says "after several lengthy
discussions over a period of approximately two weeks,
plaintiff and Chandler entered into a memorandum of
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Page 170
understanding."
Who, on behalf of the plaintiff, was having
these communications?
A. Don't know.
Q. Wasn't it you?
A. No.
Q. And one of the agreements that Mr. Chandler
was required to specifically agree to between the
alleged plaintiff and Mr. Chandler, was "Chandler will
refer violations of open government laws encountered in
the course of his duties to legal counsel approved by
the Foundation." Do you remember that being one of the
terms of his employment?
A. No, I do not.
Q. Take a look at the lawsuit that was filed by
Citizens Awareness Foundation, Inc. And is Mr. Ring
still involved in that entity?
A. I don't know.
Q. And Ms. De Larmartini, is she still involved
in that entity?
A. I don't know.
Q. Didn't you direct that names of people be
changed; that Mr. Chandler become the president back in
June?
A. Not that I recall.
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Q. Did you have any discussions with anybody
where you determined who were going to be the officers
of this entity?
MR. DESOUZA: Objection. Form.
THE WITNESS: I don't recall.
BY MR. SWEETAPPLE:
Q. And so do you have any idea who these
conversations were with between the plaintiff and the --
and Mr. Chandler where he agreed that he would refer
violations of open government laws encountered in the
course of his duties to legal counsel approved by the
Foundation?
A. I don't know.
Q. Who was the legal counsel approved by the
Foundation?
A. I don't know.
Q. Well, how many lawsuits has Citizens Awareness
Foundation filed in the state of Florida?
MR. DESOUZA: Bob, he is here as Martin
O'Boyle. He is not here as Citizens Awareness
Foundation. As far as I know, he is not a
plaintiff in that lawsuit. It appears at this
point you're trying to get a free bite at the apple
doing discovery in actions where this guy is not
even a party, so.
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MR. SWEETAPPLE: I think he is. I think he is
Citizens Awareness Foundation. That is going to be
part of my counterclaim. And when I go on to all
the facts I have here, you will see he is Citizens
Awareness Foundation and he is not telling me the
truth in his deposition.
MR. DESOUZA: Well, you're entitled to
believe --
MR. SWEETAPPLE: And that's what I'm going to
do. I'm going to take discovery to find out if he
is or not. And then you will decide on your own.
MR. SMITH: Excuse me. A counterclaim will be
against Mr. O'Boyle personally?
MR. SWEETAPPLE: Yes. And he is a plaintiff
in this case personally.
MR. SMITH: And it would be on behalf of the
Town of Gulf Stream, which has not been sued in
this case by CAFI.
MR. SWEETAPPLE: It has also been sued by
CAFI, and without Mr. Chandler's knowledge or
approval. And Mr. O'Boyle and his secretary, it is
alleged, have been filing public records requests
alleging it's under CAFI when it's him personally.
So please allow me to take my discovery, and
then you'll be able to look at the sworn testimony
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of witnesses, and you'll be able to learn what has
happened in this case; and then you'll come to
understand all the claims that we'll be bringing
here, okay? So with regard --
MR. SMITH: Of course it would be nice if
you'd bring them, before you --
MR. SWEETAPPLE: With this gentleman I don't
want to bring anything until I have all my ducks in
a row, and all the lawyers I'm working with feel
the say way, Mr. Smith. I'm sure you can
understand why, because he sues opposing lawyers.
He sues people that say things. Mr. O'Boyle seems
to sue anybody he can intimidate or bully.
So I'm not filing anything until we have all
of the discovery. And I'm going to take
Mr. O'Boyle as many times and as long as I need to,
and the rest of the witnesses, as long as I need
to, and we are going to fully litigate all of the
matters that involve he, his son, and his son's law
firm. Okay?
MR. SMITH: Sorry for the interruption. I
don't need to be surprised.
MR. SWEETAPPLE: So that's what we're doing.
Please indulge me.
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BY MR. SWEETAPPLE:
Q. So in this lawsuit, can you tell me if -- if
there is any legal counsel that has been approved by
CAFI other than the O'Boyle Law Firm?
A. I have nothing to do with CAFI. I'll say it
again and I'm saying it the last time. If you ask me
again, I won't answer.
Q. All right. Let's go through some specifics,
then.
In January, your son, Ryan Witmer and you met
with Mr. Chandler and discussed in writing the forming
of an entity to bring public records requests to the
O'Boyle Law Firm, correct?
A. If you can show me something, I'll look at it
and answer you. If not, the answer is I don't recall.
Q. And at that time Mr. Chandler was, in fact,
staying at your home; isn't that a fact?
A. If Mr. Chandler was staying at my home, I do
not recall.
Q. On January 27th, CAFI was incorporated, and
the board was designated to be William Ring, Denise De
Larmartini and Brenda Russell, correct?
A. I have nothing to do with CAFI, and I'm not
going to -- that's the last question I'm answering.
Q. Is CAFI a tenant in any building that is owned
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by any entity that you control?
A. I'm not answering your question.
Q. Is CAFI paying rent to any entity that you
control?
A. I'm not going to answer anymore.
Q. CAFI's address, sir, is listed as the same
address as Commerce Group; are you aware of that?
A. I know nothing about CAFI.
Q. Well, how is it that CAFI -- isn't CAFI
occupying the same physical space as Commerce Group,
sir?
A. Not to my knowledge.
Q. Okay. Let's take a look.
Let's do it in the order I have it. It will
save us some time. An entity by the name of Airline
Highway, LLC; are you involved in that lawsuit? In that
entity?
A. I'm not sure.
Q. And it has been propounding public records
requests, correct?
MR. DESOUZA: He just said he doesn't know if
he has involvement.
BY MR. SWEETAPPLE:
Q. Well, you're the manager of the company,
aren't you, sir? And your wife is the registered agent?
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MR. DESOUZA: Objection. Form.
BY MR. SWEETAPPLE:
Q. Isn't that the case?
A. I don't know.
Q. Let me show you what I'll mark as an exhibit
for you.
(Defendant's Exhibit No. 7 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Let me show you a Florida Department of State
Division of Corporations printout for Airline Highway,
LLC, that is a reinstatement. Date filed 6/21/2006. It
says manager, Martin E. O'Boyle, 1280 West Newport
Center Drive. And it says the registered agent is
Sheila L. O'Boyle, 23 North Hidden Harbor Drive, Gulf
Stream, Florida 33483. Please take a look at that.
1280 West Newport Center Drive is the address
that you gave me where the Commerce Group is located,
right?
A. Yes, sir.
Q. And the entity that owns that property -- do
you own the entity that owns that property?
A. I don't understand that question.
Q. Do you have an ownership interest in the
entity that owns 1280 West Newport Center Drive?
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Pagc 177
A. I don't know.
Q. You don't know?
A. No, I don't know.
Q. Well -- and you don't know the name of the
entity that owns that property?
MR. DESOUZA: Objection. Asked and answered.
BY MR. SWEETAPPLE:
Q. Does Airline -- what is Airline Highway, LLC?
A. It's an LLC.
Q. What does it do?
A. I don't know.
Q. Does it own any aircraft?
A. No.
Q. You're the manager of the company. You don't
know what it does?
A. Where does it say I'm the manager?
Q. Doesn't it say you're the manager,
Mr. O'Boyle?
A. Not that I can see. Maybe you can show me.
Q. Okay. See where it says title "manager,
O'Boyle, Martin E. ?"
A. Where does it say "title manager ?"
Q. "Title MGRM."
A. How is that manager?
Q. What do you think that is?
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A.
I have no idea.
Q.
Managing member. It's an LLC.
A.
Managing member.
Q.
Do you know what your title is in Airline
Highway,
LLC?
A.
I think I'm a member.
Q.
And what does this entity do?
A.
I don't know.
Q.
Does it have any formal legal documents?
MR. DESOUZA: Objection to form.
THE WITNESS: I don't know.
BY MR. SWEETAPPLE:
Q. Does it have any -- does it keep any records,
corporate records?
A. I don't handle that stuff.
Q. Who handles that for this entity?
A. Probably either our accountant or my
secretary.
Q. Which secretary?
A. Brenda Russell.
Q. So Brenda Russell is your secretary, and she
is one of the directors of CAFI?
A. I don't know if she is a director of CAFI.
Q. I told you who the three directors are.
A. That's what you told me. I don't believe you.
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Q. So you don't know who they are?
A. I just told you I know nothing about CAFI.
Q. You don't know that it's -- your secretary
Brenda Russell, your attorney /business partner,
Mr. Ring, and Ms. De Larmartini, who has been with you
for over 25 years, you don't know those are the three
people you appointed to run CAFI, allegedly?
MR. DESOUZA: Objection to the form.
BY MR. SWEETAPPLE:
Q. You don't know that?
A. You don't know what you're talking about, and
I'm not going to answer anymore.
Q. So since I don't know what I'm talking about,
can you tell me what Airline Highway, LLC was formed to
do or what it does?
A. I already answered that question.
Q. You don't know?
A. I don't know.
Q. And what do you do for this company?
A. I don't think I do anything, but I don't know.
Q. Well, it has sent public records requests to
me. Do you know why this company or this LLC has sent
public records requests to me?
A. Because they like you.
Q. Okay. And who there likes me?
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A. Whoever sent it to you.
Q. Do you know who sent them?
A. I have no idea.
Q. What about CRO Aviation. Are you familiar --
MR. DESOUZA: Did you leave a copy of that on
the table somewhere, or did you take it back?
MR. SWEETAPPLE: Did I leave an exhibit or no?
MR. DESOUZA: I want to make sure I'm going to
get a set of exhibits when we get out of here.
MR. SWEETAPPLE: Did we mark it? You're
right. Seven. Let me mark this as 8.
(Defendant's Exhibit No. 8 was marked for
identification.)
MR. SWEETAPPLE: I have copies of this one.
MS. O'CONNOR: Did he give you the cover
letter for that one, too? Is 7 with the --
MR. DESOUZA: Seven is just --
MR. SWEETAPPLE: They can have the cover
letter, too.
MS. O'CONNOR: I gave him 7.
BY MR. SWEETAPPLE:
Q. What is CRO Aviation, Mr. O'Boyle?
A. It's a corporation.
Q. And did you cause it to be formed?
A. I don't know that I did or not.
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Q. Its principal address is care of Commerce
Group, Inc.
A. Yes.
Q. Is it related to Commerce Group, Inc?
A. It has the same address.
Q. Are they a subsidiary or a related entity?
A. It has the same address.
Q. That's all you know?
A. That's it.
Q. And is CRO Aviation a tenant at that location?
A. I'm not really sure how to answer that
question, except that the address on all of our entities
that I have, that I'm involved in, in the corporate
governance is done out of 1280 West Newport Center
Drive.
Q. Does this company keep a corporate book with
minutes and have meetings?
A. I don't know.
Q. You're the president, secretary, treasurer,
right?
A. I don't know.
Q. Isn't that what this filing says?
A. What year is it?
Q. This says 2014. 4/28/2014 was the filed date,
so within the last four months.
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Page 182
A. Okay. So...
Q. What does this company do, Mr. O'Boyle?
A. I don't think anything.
Q. Does it own any planes?
A. Not right this minute, no.
Q. Did it own any planes?
A. I think it did. I'm not sure if it did. I
think it did.
Q. What planes do you think it owned?
A. I don't know. One of the four I told you
about.
Q. And are there any planes that you or an entity
that you have an interest in, or that you have an
officership in, has ever been used to pull banners? Or
do you hire planes that you have no interest in?
A. You asked a lot of questions there again.
Q. When you have flown banners over the Palm
Beach County Courthouse during your daughter's case and
appeal, did you hire out planes, or did you use planes
that you had some ownership interest in?
A. First of all, I'm not sure that it was during
my daughter's case for the appeal. But I did not use
any planes that I had.
Q. So you hired planes there?
A. To the extent I was responsible for running
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banner planes, they would have been hired, yes.
Q. Where did you hire them from?
A. I have no idea.
Q. Who did the hiring?
A. Michelle. The same person I told you last
time you asked.
Q. Do you know which airport the planes were
hired from?
sure.
A. No.
Q. And who do you use now to fly banners?
A. I think the same company. I think. I'm not
Q. Do you know the name of the company?
A. I don't.
Q. Who handles the banners you're doing
currently?
A. Probably Brenda.
Q. Brenda, the director of CAFI?
A. Brenda Russell.
Q. Who is your secretary?
A. Yes.
Q. And who pays Brenda's salary?
A. I don't know.
Q. Does CAFI pay Brenda's salary?
A. No.
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Page 184
Q. Does one of your other entities pay Brenda's
salary?
A. I think so.
Q. Does Brenda serve as director of CAFI for
free?
A. I'm not going to answer any questions about
CAFI.
Q. Why is that?
A. Because I know nothing about CAFI, and
anything I say is a guess and I'm told not to guess.
Q. I'm going to see if I can help you in that
regard, Mr. O'Boyle.
A. Good. Good.
(Defendant's Exhibit No. 9 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Stop Dirty Government, LLC.
Are you familiar with that entity?
A. The name, yes.
Q. That's all you're familiar with is the name?
A. That's it, yes.
Q. Can I see that when you're done?
A. Sure.
Q. Thank you. It says you're the manager. It's
been in existence since 2011. And do you know the
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purpose of this entity?
A. Yes. It is to deal with the government and
hopefully with the name to bring them down a notch or
two.
Q. Is it for purposes of filing public records
requests?
A. Not necessarily. It may, but the same way as
any entity.
Q.
Has it
filed public
records
requests?
A.
I think
it has, but
I don't
know for sure.
Q.
Do you
know how many it has
filed?
A.
I have
-- just as I
said, I
think it has, but
I don't
know for
sure so how
could I
know how many are
filed.
Q. And do you know if it's filed any lawsuits,
become a plaintiff in any lawsuits?
A. Not to my knowledge, but I don't know.
Q. And let me show you the next one I'm going to
mark, which is Our Public Records, LLC.
(Defendant's Exhibit No. 10 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Did you cause Our Public Records, LLC to be
formed?
A. I think -- if I didn't, I certainly directed
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it be formed.
Q. Who formed this entity for you? Which person?
A. Not a lawyer.
Q. Who would you have had in your office do it?
A. I really can't say.
Q. Was it the same person that formed CAFI?
A. I think -- CAFI was not formed. I don't know
who formed CAFI, but I can't answer your question.
Q. And has that entity issued public records
requests?
A. That entity, I think it has.
Q. And has it been a plaintiff in public records
litigation?
A. If it has, I know nothing about it.
Q. And are you actively managing this company?
A. This company is -- we're hoping it will be a
big company, and it's in its infancy.
Q. What are you intending this company to become
big in?
A. Public records.
Q. Filing public records lawsuits?
A. No. Educating the public about public
records.
Q. And can I see that?
A. Sure.
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Q. What have you done in that regard with regard
to this entity, Our Public Records, LLC?
A. We have a website.
You're welcome to look at it. It is Our
Public Records.com. If you want, we can take a few
minute break, you can look at it. I think you would be
really impressed. I know you want to thank me.
Q. Commerce Group GP, Inc.
(Defendant's Exhibit No. 11 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Who formed this, Mr. O'Boyle? Which
individual?
A. Don't know.
Q. And it says that your wife is a registered
agent, correct?
A. That's what it says.
Q. It says are you the director, president,
treasurer, right?
A. Well, it says I'm DPT, whatever that is.
Q. Isn't that director, president, treasurer?
A. I don't know. You tell me.
Q. And Stop Dirty Government and you have filed a
lawsuit in Palm Beach County, haven't you? A public
records lawsuit?
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Page 188
A. I don't know. If we have, we have.
Q. You don't know?
A. No.
Q. Did you ask for any documents along with Stop
Dirty Government that you wanted?
MR. DESOUZA: Objection to form.
THE WITNESS: Not that I can think of.
BY MR. SWEETAPPLE:
Q. And what does Commerce Group GP, Inc., do?
A. I don't know.
Q. Why was it formed?
A. I don't know. It was formed almost 20 years
ago.
Q. It has been in existence for 20 years?
A. Yeah.
Q. What has it done in the last 20 years?
A. I don't know.
Q. Has it occupied 1280 West Newport Center
Drive?
A. Yeah. It occupies that building and three
more like it.
Q. It is in three other buildings?
A. No, not at all.
Q. Just this building?
A. No.
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Inc.
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Page 189
Q.
Does it have a lease?
A.
It has that address for the sole purpose of --
the young
lady who handles our corporate governance is
there. So to have the forms made elsewhere is not a
very smart
thing to do. So we mail them there. She
gets them,
and she files whatever forms are necessary to
keep them
current and in good standing.
Q.
Is this a company that is engaged in business?
A.
I don't know.
Q.
Do you know if it files tax returns?
A.
I don't know.
Q.
Do you know if it has income?
A.
I don't know.
Q.
Who would know that?
A.
I don't know.
Q.
Who is your accountant?
A.
I don't know.
Q.
And CG Acquisition Company.
(Defendant's Exhibit No. 12 was marked for
identification.)
BY MR. SWEETAPPLE:
Q.
Let's mark this as next.
What is CG Acquisition Company, Mr. O'Boyle?
A.
I think it's a corporation by Commerce GP,
Inc.
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Q. And what does it do?
A. Pardon?
Q. What does it do?
A. I don't know.
Q. Is it engaged in moneymaking?
A. I don't know.
Q. Who formed it?
A. I don't know.
Q. What about Asset Enhancement, Inc., also
showing an address of 1280 Newport Center Drive. What
is that entity, sir?
(Defendant's Exhibit No. 13 was marked for
identification.)
THE WITNESS: This is an entity that was
incorporated 40 years ago, and I have no idea what
it does.
BY MR. SWEETAPPLE:
Q. Okay. So it's been in business for 40 years,
and your wife is a registered agent, and you are the
director, president, treasurer, right?
A. That's what you say.
Q. That's what the document says.
A. That's what you say.
Q. Okay. And you don't know what this company
does, right?
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Page 191
A.
Right.
Q.
And all these companies that you don't
know
what they
do, who manages it? Does someone manage these
companies
for you?
A.
Our accountants deal with them, and I don't
deal with
them at all.
Q.
And are your accountants in- house?
A.
No.
Q.
So who -- what are the names of the
accountants that deal with these?
A.
I don't know.
Q.
You really don't know your accountant's
name?
A.
I really don't know.
Q.
You don't know any of your accountants'
names?
A.
Flynn is one of them.
Q.
What's his last name?
A.
Flynn.
Q.
F -1 --
A.
I think it is y -n -n.
Q.
Where is he located?
A.
Roanoke, Virginia.
Q.
Who are the accountants for CAFI?
A.
I don't know.
Q.
And what about Commerce Group, Inc? Is
that a
company you're familiar with?
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Page 192
A. I'm -- yeah.
Q. And is that a company that you're actively
involved in?
A. I don't know.
Q. What does Commerce Group, Inc., do?
A. I don't know.
Q. Are you aware that you're listed as the DPT in
the Department of State records?
A. No.
Q. And the address is the same, 1280 Newport
Center Drive.
A. That's where we do our corporate governance
Kge3V'.�
Q. Okay. Is Commerce Group, Inc., your main
business?
A. No.
Q. I'm not going to mark Commerce Group, Inc. I
think it's pretty much the same as the others.
Let's go to CAFI. Now -- so your son, your
son's law firm leases 1286 West Newport Center Drive,
right?
A. Yes.
Q. And that is just for his law firm, right?
A. I don't know.
MR. DESOUZA: Objection. Form.
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BY MR. SWEETAPPLE:
Q. Is there any another businesses that leases
that space?
A. You asked me, you said that's leased.
Q. 1286 West Newport Center Drive, you say
there's a door between that space and your offices,
right? Your businesses?
A. That's correct.
Q. And you told me that CAFI is not located in
your son's law office space, correct?
A. That's correct.
Q. And let me show you this statement of change
of registered office, or registered agent, for both
corporations showing the O'Boyle Law Firm is at 1286
West Newport Center Drive. And this printout is for
Citizens Awareness Foundation, Inc., with the same
address, 1286 West Newport Center Drive, Deerfield
Beach, Florida 33432. And then the help line is
888- 830 -3769.
I'm going to mark these as the next two
exhibits and ask if you've ever seen either of them
before.
I'm going to make the statement of change of
registered office No. 14; and the sheet that says the
Citizens Awareness Foundation change of registered agent
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No. 15. Have you ever seen No. 14 or No. 15 before
today?
(Defendant's Exhibit No. 14 was marked for
identification.)
(Defendant's Exhibit No. 15 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Have you ever seen No. 14 and No. 15 before?
MR. DESOUZA: Can I see these? I assume there
is only one copy?
MR. SWEETAPPLE: Let me see if I have more. I
think that's the only one I have of that.
MR. DESOUZA: For my own purposes, did you say
where this DX15 came from?
MR. SWEETAPPLE: I have not said that. I'm
asking if he recognizes it.
MR. DESOUZA: Okay. I wasn't sure if you said
that.
Can I ask you to read the pending question
back?
MR. SWEETAPPLE: Sure. Can you read it back?
(A portion of the record was read by the
reporter.)
MR. DESOUZA: I'll object to form on the
compound nature of it.
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Q. Have you seen No. 14 before?
A. No.
Q. Have you seen No. 15 before?
A. No.
Q. Do you know who Ryan Witmer is?
A. Yes.
Q. And he has left the O'Boyle Law Firm; has he
A. He has.
Q. Do you know why?
A. Yes.
Q. And what did he tell you?
A. He is in -- before he came here, he was
supposed to go and be a lawyer up in New York State. He
was supposed to be a partner with a fellow up there.
And they -- Matt -- I forget his last name -- and Matt
had a great deal of difficulty and was delayed for about
a year, and getting a character witness to approve him.
So Ryan came to work with us, and then one day he said
he wants to do immigration work.
Q. So he said to "us ", you mean you and Jonathan?
A. Jonathan, not me. He didn't tell me.
Q. You actually are involved in the overall law
firm, aren't you?
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A. No.
Q. You fund that law firm, don't you?
A. I phone it?
Q. Fund it. And you pay lawyers' salaries
directly, don't you?
A. You mean --
Q. Through your entities; you and through your
entities you fund the --
A. You going to let me answer or not?
Q. Pardon?
A. Do you want to let me answer or not?
Q. I'm rephrasing it for you.
You or your entities fund the O'Boyle Law Firm
through making loans and by making direct payments to
lawyers, don't you?
A. No.
MR. DESOUZA: Objection. Form.
BY MR. SWEETAPPLE:
Q. And is the Citizens Awareness Foundation
located in the same address as your son's law firm?
A. Not to my knowledge.
Q. Is the Citizens Awareness Foundation located
in the building that your entity owns at 1280 West
Newport Center Drive?
A. I'm not answering anymore questions on
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Citizens Awareness.
Q. And on February 5th, did you tell Mr. Chandler
to send all litigation to the O'Boyle Law Firm or you
will cut off the flow of money?
MR. SMITH: Object to the form.
THE WITNESS: Not that I know of.
BY MR. SWEETAPPLE:
Q. On March 22nd, did Mr. Ring and Ms.
De Larmartini insist that all cases from Citizens
Awareness Fund be sent to the O'Boyle Law Firm?
MR. DESOUZA: Object to the form.
THE WITNESS: I'm not going to answer that
question on the attorney - client privilege. And
I've told you, and this is the last time I'm
telling you, I'm not going to answer any questions
on Citizens Awareness Foundation. I have no
knowledge of that corporation and I'm not going to
continually go through this. So this ends right
here.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle, I have to ask the questions on a
one by one basis.
A. You ask me, I'm not going to answer.
Q. You decide that on each question basis and the
judge will decide if I'm going to get an answer or not.
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A. That's fine.
Q. On April 1, are you aware whether or not your
son offered to provide legal counsel to Mr. Chandler and
handled one of his personal Florida public records
requests cases?
A. No.
Q. Are you aware whether or not in March and
April Ms. De Larmartini was present telephonically for
law office administration meetings while she was on the
board of CAFI, and she went through the entire list of
all O'Boyle Law Firm cases while Mr. Chandler was
present?
MR. DESOUZA: Object to the form.
THE WITNESS: I can't imagine she would say
that, but...
BY MR. SWEETAPPLE:
Q. Are you aware that on April 14, your son wrote
Chandler and advised him that he was assigning a Florida
case to himself to handle?
A. Why don't you show me documents rather than
just flapping your lips.
Q. Well, I see from this lawsuit that apparently
you are saying -- the lawsuit alleges that Mr. Chandler
deleted all of the -- or deleted CAFI e- mails. Is that
accurate?
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MR. DESOUZA: Which lawsuit are we talking
about?
MR. SWEETAPPLE: Talking about the suit, CAFI
against Chandler.
MR. DESOUZA: So you're talking about
Defendant's Exhibit 6 for clarity of the record?
MR. SWEETAPPLE: Six. Yes.
MR. DESOUZA: And the question?
THE WITNESS: I know nothing about CAFI. And
let me say it 100 times in a row and that way we
can save you all this time.
BY MR. SWEETAPPLE:
Q. You wrote Mr. Chandler and asked him to get
you the records for CAFI
A. Let me see it.
Q. -- didn't you, sir?
A. Let me see them.
Q. I want to know whether you know.
A. Let's see them.
Q. Mr. O'Boyle.
A. Let's see them.
Q. You're going to see them.
A. Let's see them.
Q. You're going to see them, Mr. O'Boyle.
Believe me, you're going to see them. Did you write --
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A. No.
Q. -- to Mr. Chandler and ask him to please help
in getting all of the records to CAFI back to you
De Larmartini so that cases could be filed?
A. As I told you before, Mr. Chandler resigned at
the earlier part of June. He left a bag, and a letter
of resignation.
My secretary called me. She said, Joel wants
you to call him. I tried to call him moments later. I
didn't get him. Either that night or the next day I did
get a hold of him. And what he said is, "Everything you
need is in that bag."
And I -- I wasn't sure if he was even in
Florida, as I recall. So that's what I can tell you
about the e -mail.
Q. Didn't you write him on July 2nd and copy Ms.
De Larmartini and Mr. Ring, subject Joel Chandler. And
you wrote Joel Chandler and you indicated that the
office, our office and the law office are stuck in
quicksand since they can't gain access to certain files.
And then you went on to say, "It would sure be
helpful if you could get them through this, so they
could access and use the data. I also understand there
are new cases for the month of June that need to be
accessed.
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"As to the new cases, Bill would really like
to get those cases to the attorneys as soon as possible.
A temporary solution would be for you to send the cases
to Denise in the format which has been previously used.
That way I can access them and disseminate them."
Isn't that what you wrote to Mr. Chandler on
July 2nd, 2014?
way?
A. Can I see?
Q. No. I want to know if you remember that.
A. I don't memorize things.
Q. Does that refresh your recollection in any
A. I'd have to see the e -mail.
Q. Okay.
MR. SMITH: You don't want to show him the
document?
MR. SWEETAPPLE: He'll see it when he gets the
lawsuit we're filing.
MR. DESOUZA: The phantom lawsuit we've been
talking about for the past 3 or 4 months?
MR. SWEETAPPLE: No, there is no phantom
lawsuits. We've been working on various lawsuits
for about two months, I would say. And I certainly
wanted to hear Mr. O'Boyle's testimony before we
filed it, and I'm certainly glad I did.
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Page 202
THE WITNESS: Boy, Mr. Sweetapple, that's
great. You're going to bankrupt this city.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle, that only appears to be your
goal, not mine.
A. It's not mine, but I'm going to watch you do
it.
Q. All right. And you put your son in a law
office in Broward County and called it the O'Boyle Law
Firm before he even had a license to practice law in the
state, right?
MR. DESOUZA: Objection. Form.
THE WITNESS: When you say "right ", you say it
with no basis whatsoever.
BY MR. SWEETAPPLE:
Q. Didn't you?
A. You're not an honorable man, so I'm not going
to answer those kind of questions. You got something to
show me, show me.
Q. Your son has been working full -time out of the
O'Boyle law office since it opened in Broward County and
living at your home full -time, correct, Mr. O'Boyle?
A. No, it's not correct. And you have no idea
what you're talking about.
Q. Okay. Are you aware that he listed in
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Page 203
Pennsylvania his business phone number was his cell
phone number, his 561 cell phone number?
A. Ah. He did that?
Q. Yes. And are you aware that --
A. What a terrible thing.
Q. And are you aware from your cell phone records
you can tell where every phone call was made or
received?
A. Am I aware? No.
Q. And has mister -- does your son reside in New
Jersey?
A. You ask him that.
Q. Do you know if he has a voter registration in
New Jersey?
A. I think he does.
Q. And a driver's license in New Jersey?
A. I think he does.
Q. And that's where he resides?
A. I think he does.
Q. And has he been working full -time in your
offices in Fort Lauderdale?
A. I don't think so.
Q. And was he ever a partner with Mr. Witmer with
regard to the O'Boyle Law Firm?
A. I have no idea.
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Page 204
Q. And you were in such a rush to have your
O'Boyle Law Firm, that you actually put your son in a
position where you opened up an office called the
O'Boyle Law Firm in Broward County, Florida, before he
became a Florida lawyer.
MR. DESOUZA: Object to form. He is not
answering these questions. Why don't you ask him
something not argumentative or harassing.
THE WITNESS: You're just talking nonsense.
BY MR. SWEETAPPLE:
Q. Well, I guess that's what you call it,
Mr. O'Boyle.
A. You want to tell me when I impregnated my
wife?
Q. Well --
MR. SMITH: Marty.
MR. DESOUZA: You don't need to engage him in
this type of stuff, Marty. Let him be the one that
is harassing and making ridiculous questions.
BY MR. SWEETAPPLE:
Q. You put your son in the position of engaging
in unauthorized practice of law, because you solicited
him to actually participate in your public records
litigation here in Florida.
MR. DESOUZA: Objection.
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Page 205
MR. SMITH: Objection.
MR. TAYLOR: Objection.
MR. DESOUZA: I'm instructing the witness not
to answer at this point. If you want to ask --
MR. SWEETAPPLE: In fact.
MR. DESOUZA: -- questions that are not
closings and argumentive, that is fine.
BY MR. SWEETAPPLE:
Q. In fact Mr. Giovani Mesa complained to
Mr. Chandler in writing that Jonathan O'Boyle had
drafted cases and filed them in Mesa's name without
Mesa's knowledge or consent, correct? Are you aware of
that?
MR. SMITH: Objection. Argumentative.
BY MR. SWEETAPPLE:
Q. Are you aware whether or not -- on 4/28/2014
Mr. Giovani Mesa complained in writing to Chandler that
Jonathan O'Boyle was drafting lawsuits in Florida and
filing them in Mesa's name without Mesa's knowledge or
consent. Are you aware that occurred, sir?
MR. SMITH: That statement was made by
Giovani -- what is his name? Are you asking him
are you aware of that?
BY MR. SWEETAPPLE:
Q. Yes. That Mr. Mesa complained. A lawyer in
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Page 206
the office complained to Mr. Chandler that that occurred
with your son.
A. If that's what he did, that's what he did.
Q. Have you heard about that before?
A. Never. Never.
Q. And on 4/28, Ms. De Larmartini demanded a
minimum of 25 new public records request cases a week be
forwarded to the O'Boyle Law Firm by Citizens Awareness
Foundation; are you aware of that, in writing?
A. Was that before he committed bank fraud, or
bankruptcy fraud?
Q. This is Ms. De Larmartini's writing, sir.
A. I'm talking about Mr. Chandler. Is that
before or after he committed bankruptcy fraud? Which
one?
Q. Mr. O'Boyle.
A. Which one?
Q. I'm not talking about any statement that
Mr. Chandler made. I'm talking about a statement that
your secretary of over 25 years, your paralegal, the
director of CAFI, made in writing.
Have you -- were you ever aware that Ms.
De Larmartini demanded 25 new public records lawsuits be
filed a week for the O'Boyle Law Firm?
MR. SMITH: Objection. Argumentative.
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Page 207
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. Are you aware that on May 16, Ms.
De Larmartini complained that Mr. Chandler only
generated 211 cases in 12 weeks?
A. No, I'm not.
Q. And are you aware of whether or not CAFI has
ever had any fee agreements with the O'Boyle Law Firm?
A. How much longer do I have to answer about CAFI
when I know nothing?
Q. Oh, I think you will be answering for quite
some time, and I do think you know more than you're
letting on to, Mr. O'Boyle. So let's stop playing games
and see if you can answer my questions.
Are you aware whether or not there are any fee
agreements or engagement letters between CAFI, which you
are the sole funder of, and the O'Boyle Law Firm, which
you are also a funder of? Who are both located in your
building.
MR. DESOUZA: Objection.
MR. SMITH: Objection.
MR. TAYLOR: Objection.
MR. DESOUZA: Objection. A whole host of
objections. Argumentative. Form.
THE WITNESS: Who said I was the sole funder
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of CAFI?
MR. DESOUZA: I think Bob said that.
BY MR. SWEETAPPLE:
Q. Who else has funded CAFI, Mr. O'Boyle?
A. I don't know.
Q. Are you aware of anyone besides you that has
provided funds to that entity?
A. I know nothing about CAFI.
Q. When the law firm collects money when it
settles CAFI cases, it doesn't give money to the entity,
does it?
A. What entity?
Q. To CAFI. It keeps all the money it gets when
it settles the cases, right? Or does it give you some?
MR. DESOUZA: Objection. Form.
BY MR. SWEETAPPLE:
Q. I'll break it down.
In the cases that CAFI has settled against
public governmental entities with state contractors, has
any money been given to CAFI, your debtor? Let's just
say that is all they are for the moment.
A. I don't know.
Q. How do you expect CAFI to pay you back?
A. Money.
Q. Pardon?
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our entities.
Q. Who, at CAFI, specifically, do you have an
agreement with regarding getting repaid?
A. I don't think I have a specific agreement
laying out with detail a 100 -page note.
Q. What was CAFI's profit model where -- you have
a 100 -page note, or you don't have a 100 -page note?
A. I don't have a 100 -page note.
Q. Do you have a one page note?
A. No.
Q. You have no note.
on checks?
Do you have loans written
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Page 209
A.
With money.
Q.
And how are they earning money?
A.
I didn't ask them.
Q.
Okay. Who would you have to ask to find out
how they're going to pay you back?
A.
I don't know.
Q.
What are the terms of their obligations? Is
there any
obligation to pay you back?
A.
I think so. We have -- yes.
Q.
You have any agreement on that?
A.
I think so. Generally stated, yes.
Q.
Who's the agreement with?
A.
I think it's just common knowledge with all of
our entities.
Q. Who, at CAFI, specifically, do you have an
agreement with regarding getting repaid?
A. I don't think I have a specific agreement
laying out with detail a 100 -page note.
Q. What was CAFI's profit model where -- you have
a 100 -page note, or you don't have a 100 -page note?
A. I don't have a 100 -page note.
Q. Do you have a one page note?
A. No.
Q. You have no note.
on checks?
Do you have loans written
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Page 210
A. Maybe.
Q. How was this document a loan as opposed to
just a contribution?
A. How is it a loan? Because I think the parties
agree it's a loan.
Q. And who are the parties that agreed?
A. I guess CAFI and me.
Q. Who in CAFI made that agreement?
A. I have no idea.
Q. How can you have an agreement and not know who
it is with?
A. Because I think it's common knowledge that I'm
not giving them the money.
Q. Pardon?
A. I'm not giving them the money.
Q. Some entity is that you control?
A. No. No. They're not getting it free.
Q. Okay.
A. It's not a contribution.
Q. So it's a loan?
A. It is a loan, yes.
Q. What is the business that CAFI engages in that
they could ever repay you?
A. Maybe they won't. I'll take a tax write -off.
Q. If it's supposed to be a loan, if your intent
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is it's supposed to be a loan -- you're a very
sophisticated businessman.
A. Thank you.
Q. That's what they say at least.
A. But you don't believe that.
Q. I'm going to keep my beliefs to myself.
A. You should.
Q. So what I would like to know is whether or not
you had any expectation that CAFI had any business
whereby it could repay you?
A. No.
Q. What did you understand the activities that
CAFI was going to be; a not - for - profit foundation,
right?
A. Yes.
Q. And what was it going to do to make money?
Anything?
A. I don't think we've ever gotten that far.
Q. You knew that it was only going to be filing
lawsuits for your son's law firm, right?
A. That's not true.
Q. Well, has any other law firm represented it,
in any other lawsuits?
A. I have no idea.
Q. And does filing a public records request give
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the plaintiff any right to remuneration, other than
attorneys' fees and costs by statute?
A. Are you talking about remuneration?
Q. Yeah, to the plaintiff himself.
A. You said enumeration.
Q. Remuneration.
A. What was your question?
Q. Do you understand whether or not CAFI, as a
plaintiff in a public records request, would be entitled
to any money?
MR. DESOUZA: You're asking him for his legal
understanding?
MR. SWEETAPPLE: To the extent he understands
having filed public records requests and funding
this entity.
THE WITNESS: I don't think I can answer you.
BY MR. SWEETAPPLE:
Q. Okay. So you don't know if there are any fee
agreements or engagement letters between CAFI and your
son's law firm?
A. I would have no idea.
Q. Are you aware on May 28, De Larmartini, again,
demanded more cases from Chandler for the O'Boyle Law
Firm?
A. No.
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Q. Are you aware that on 6/2 Mr. Ring denied any
authority to send cases to any firm other than the
O'Boyle Law Firm?
A. I'm not.
Q. Are you aware that in June, Mr. Chandler
learned that you had been making public records requests
in the name of CAFI against Gulf Stream, the Town of
Gulf Stream, without his knowledge or consent in doing
so in the name of CAFI?
MR. DESOUZA: Objection. Form.
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. And that you were using your secretary,
Ms. Mohler, M- o- h- l -e -r.
A. No.
Q. Did you ever fax or e-mail, using Ms. Mohler,
public records requests to the Town of Gulf Stream in
the name of Citizens Awareness Foundation, Inc?
A. Not to my knowledge.
Q. And did you ever direct lawsuits, two
lawsuits, to be filed against Gulf Stream in the name of
CAFI without the knowledge or permission of
Mr. Chandler?
A. What period are you talking about?
Q. June. May and June. This year.
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A. Mr. Chandler already resigned. He resigned in
May; the middle of May. So I don't know where you're
coming from. I guess he forgot to tell you that part.
Q. You believe that Mr. Chandler resigned in May?
A. Absolutely.
Q. So all his communications after May whatever
is no longer --
A. 16th. I think it was May 16. I'm not sure.
Q. May 16.
A. But I think it was May 16.
Q. How do you know that?
A. Ms. De Larmartini told me.
Q. Was it in writing or orally?
A. It was in writing.
Q. Didn't Ms. De Larmartini on May 26 ask
Mr. Chandler to prepare complaints for CAFI to use?
A. No idea.
Q. And didn't he refuse to, saying he was not a
lawyer?
A. Well, I don't know what he said, not being a
lawyer. But I can tell you he's certainly practicing
law without a license. Make no mistake about that
there. I can show you the Complaints that he prepared.
Q. So it's your testimony that when Denise
De Larmartini wrote Mr. Chandler on May 28 saying "I
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understand that we are back to you certifying the
Complaints before they are filed," he wasn't working for
CAFI?
A. Yeah. I don't know that she knew about it at
that time.
Q. And on May 28 when she wrote him and said,
"Joel, I didn't see anything yesterday or today for new
cases this week. Were there any ?" He wasn't working
for CAFI when she was writing him asking for more cases?
A. I don't think that she knew at that time.
Q. Didn't Ms. De Larmartini tell you that
Mr. Chandler had resigned?
A. Well, depends on what time period you're on.
In the first part of June my secretary called me up and
said Joel was just here, he left a bag full of stuff and
a letter of resignation. He left immediately and said
he wants you to call him.
So that's resignation No. 1. Denise, when she
got the information -- Joel refused to give her access
to the computer data. She had to hire a computer
expert. And when she did the -- how to say it, but
they -- they were able to encrypt or unencrypt,
whatever, the documentation. And when they did, there
was a letter in there of May 15 or 16th saying "I
resign."
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Q. And on June 9, Ms. De Larmartini was talking
to Mr. Chandler about him hiring his son to assist in
conducting electronic audits of state and local
agencies.
A. Yes. She must not have known by then.
Q. Who did know?
A. Mr. Chandler. I mean, he is a crook.
Q. And -- well, Mr. Ring was talking about
Mr. Chandler bringing in his son to work for CAFI in
June, right?
A. They never knew that he was a crook until they
found out he was a crook.
MR. DESOUZA: Bob, just so I'm clear, you're
asking him about his knowledge of conversations or
e -mails between people that he is not one of,
right?
MR. SWEETAPPLE: Not necessarily.
MR. DESOUZA: I think you're referring to
e- mails. You're not showing us the e -mails so I
can't say what the e -mails are, but if he's not on
these e- mails, you're asking him whether he knows
the existence of these e- mails, the existence of
these conversations? Is that what you're asking?
All right.
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BY MR. SWEETAPPLE:
Q. And did Mr. Ring try to assure Mr. Chandler on
June 16th that he believed that the O'Boyle Law Firm was
free to exercise their legal business judgment as to the
amounts of a particular settlement; that he didn't have
to worry about the amount of attorneys' fees that were
actually incurred?
A. I don't know what Citizens Awareness
Foundation, Inc., did. Now, how many more times do I
have to tell you that before you get it through your
skull?
Q. And on June 19, Ms. De Larmartini copied
Mr. Ring re: CAFI. And said, "Bill, I intend to resign
from CAFI and make the following replacements. Cathleen
Flack (phonetic) a Commerce employee. Peter Delio
(phonetic). He is a trusted friend and contractor we
use. Joel Chandler. We would like to have him as
president /director.
Brenda Russell, Commerce employee will remain
as member. Do you see any problem with this? If not,
could you please send me the proper form to amend the
organizational documents."
You were unaware of that communication?
A. I'm not answering.
Q. On June 27th when Mr. Chandler wrote Nick
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Taylor the following language, Nick -- on June 27 he was
not an employee of CAFI, right? Is that your testimony?
A. I'm not answering any questions regarding
Q. "Nick, I'm writing this e-mail to memorialize
our telephone conversation this morning. As we
discussed, I was contacted by the defendant in the case
referenced above. He expressed his regret in his
failure to properly respond to CAFI's PRR, and asked for
our help in better understanding his obligations under
the Public Records Act. He also explained the dire
financial condition of his organization and said he
instructed his attorney to offer to settle the matter
for $1,500.
"In our conversation this morning, I
understood from you that the O'Boyle Law Firm has about
$1200 in costs and fees in the case up to this point. I
also understood that you have been instructed by
Jonathan O'Boyle to demand $3800 to settle the case.
"If such a demand is accepted by the
defendant, that would create a windfall of about 26
beyond actual fees and expenses. During that telephone
conversation, I expressed in unequivocal terms my
objections to such an arrangement. Until I received the
telephone call from the defendant yesterday, I was
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unaware that any settlement discussions were taking
place with the defendant.
"I did not authorize any such discussions, nor
did I approve in any way the demand for payment of any
kind, much less demand for payments far beyond the
actual fees and expenses billed by the O'Boyle Law Firm.
"In sum, I understand that you were directed
to make the aforementioned settlement demand by Jonathan
O'Boyle, and I have not and do not approve of such
demands. Please confirm your receipt and understanding
of this e- mail."
And Mr. Taylor -- that was at 11:05 a.m.
Mr. Taylor responded to Mr. Chandler, "This e-mail is to
confirm our conversation today and to reiterate that all
offers of settlement are made pursuant to the policies
of the O'Boyle Law Firm."
Were you aware of any of that communication?
A. I'm not answering any questions regarding
CAFI.
MR. SMITH: For the record, I object to the
question as argumentative.
BY MR. SWEETAPPLE:
Q. So after -- after you saw the motion to
disqualify your son's firm, which argued the O'Boyle
firm is not a lawful interstate law firm, how is it that
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a meeting was called with Mr. Ring and my co- counsel,
Joanne O'Connor and Mr. Randolph?
A. Mr. Ring and I spoke and we said this is --
MR. DESOUZA: Hold on. You said this to each
other or you said this to opposing counsel?
THE WITNESS: We said it to each other.
MR. DESOUZA: You shouldn't reveal the
substance of any conversation between you and
Mr. Ring.
BY MR. SWEETAPPLE:
Q. Was Mr. Ring serving as your attorney at the
time?
A. Yes.
Q. Even though he wasn't counsel of record on any
of the cases?
A. I'm not going to answer that question.
Q. Well, he -- you just don't know the answer to
that question?
So you spoke to Mr. Ring. And then who
communicated with either Ms. O'Connor or Mr. Randolph?
A. I believe that Mr. Ring called Skip Randolph
and asked for a meeting with him, Ms. O'Connor and
Mr. Stubbs. And Skip Randolph got back to him, either
later that day or the next day. I just don't remember.
Q. And was there any discussion about including
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me at the meeting?
A. No. Because we knew you were a troublemaker,
and we knew having you there is like having cancer of
the face.
Q. Okay. So even though I was the attorney that
drafted the motion, you decided you did not want me
there.
A. Well, the motion was so full of lies, that to
have you there would have been unproductive. And then,
of course, obviously, when we gave the whatever, the 157
memo, Ms. O'Connor, I think she saw that discretion was
the better part of valor, and she dismissed her claim.
Q. And you think that that was dismissed because
the claims regarding the unauthorized practice of law
weren't being pursued?
A. Yes.
Q. So you think that the law firms involved with
the city have just ignored the facts that we've learned
in this proceeding?
A. I have no idea what you just said.
MR. DESOUZA: Object to form.
BY MR. SWEETAPPLE:
Q. Never mind.
A. Good.
Q. Now, you wanted to have Sid Stubbs at the
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meeting, right?
A. Yes.
Q. And Mr. Ring told Ms. O'Connor that it would
not be a good idea to have me at the meeting, right?
A. No. I believe he told that to Skip, but I
wasn't on the phone, so I don't know.
Q. Did you prepare any memorandum at the time of
this meeting?
A. The answer is yes.
Q. And you have notes?
A. Yes.
Q. And did you write them yourself?
A. Yes.
Q. And did Mr. Ring prepare any notes?
A. I don't know.
Q. And you showed up at 2:00 o'clock with
Mr. Ring, and Ms. O'Connor asked if it was -- if she had
the -- or Mr. Randolph asked whether or not they had the
right to speak directly to you and whether permission
was received from the O'Boyle Law Firm, right?
A. No.
Q. So Mr. Randolph didn't ask if it was clear
that we have the right to speak directly to Martin
O'Boyle and whether permission was received from the
O'Boyle Law Firm; and Bill Ring said, Yes. He checked
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with the O'Boyle Law Firm and they gave that authority.
Did that occur?
A. Not to my knowledge.
Q. Okay. And Mr. Randolph indicated I would need
something in writing from them, and he said he would get
that and send it to me by e-mail.
MR. SMITH: Excuse me, objection. I think
it's ambiguous what you're reading from, because --
MR. SWEETAPPLE: Let me make it clear. That
is a good objection. I'm sorry.
MR. SMITH: Thank you.
BY MR. SWEETAPPLE:
Q. Did Mr. Randolph say to you that he needed
something in writing that the O'Boyle Law Firm gave
Mr. Ring the permission for him and you to speak
directly with Mr. Randolph?
A. No.
Q. And then did you ask the next question, "Are
these settlement negotiations, and does everything stay
in this room ?" Did you ask that?
A. No.
Q. And did Mr. Randolph indicate that if there's
truly settlement negotiations and not discussion
relating to future litigation or threatened activity
that it would be privileged communications; did he ever
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say that to you?
A. Can you read that back again?
Q. Did Mr. Randolph say if they are truly
settlement negotiations and not discussions relating to
future litigation or threatened activities, that it
would be privileged communication?
A. No.
Q. So Mr. Randolph didn't say that to you?
A. No.
Q. And did he say, "I advise, to the extent they
are settlement negotiations, even those could be shared
with our client and with other members of our law firm."
Did he say that to you?
A. I think he did. I think he did. Or some --
or something akin to that. I think so.
Q. Did you say, "Well, you can't go to the Palm
Beach Post," and Mr. Randolph responded, "Yes."
A. Responded what?
Q. Yes. You said you can't go to the Palm Beach
Post.
A. He responded yes. Yes, I did.
Q. Yes. Yes. Based on the fact if there are
going to be settlement negotiations, not discussions
about future litigation or threats.
A. I'm still confused.
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Q. Did you ever mention the Palm Beach Post
during this?
A. No. Not that I remember.
Q. And did you begin by dropping the motion that
Joanne and I filed, and asking whose brain child was
this?
A. I threw them both on the table and I said,
"Whose brainchild was this ?"
Q. Did you do that?
A. Yes, I did.
Q. And Mr. Randolph said it was signed by, both,
our firm and the Sweetapple firm, right?
A. Yes.
Q. And you asked if I felt -- if Mr. Randolph
felt it was appropriate to bring family into this
dispute.
A. I don't remember that.
Q. And did he -- then did you say that once we
have attacked his family that we have crossed the
Rubicon; that the damage has been done and there was no
way to rectify it.
A. Can you read --
Q. Did you say at the meeting --
A. Can you read the prior statement back along
with that, please?
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Q. Did you indicate that once we have attacked
his family, that we have crossed the Rubicon. Did you
ever state that?
A. I said can you read the prior, and that.
Q. You asked whose brainchild was this when
v[.r�
A. After that.
Q. Okay. And you asked if I felt it was
appropriate to bring family into this dispute.
Did you ask that?
A. I thought you said Mr. Randolph said that.
Q. No, you said that. You asked if he felt it
was appropriate to bring family into this dispute.
A. I never said that.
Q. Did you ever say that once we have attacked
his family, we have crossed the Rubicon; did you ever
say that?
A. Whose family?
Q. Your family.
A. No.
Q. And so you never said that we have crossed the
Rubicon?
A. I don't recall saying we crossed the Rubicon.
Q. Did you ever say the damage has been done,
there was no way to rectify it.
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A. No. Because we went there and we made it
clear we were there for settlement purposes. And the
only reason we would be there for settlement purposes
would be to rectify.
Q. What were you trying to settle?
A. Whatever case was there and whatever cases we
could, and your -- what is it called -- the motion that
you prepared. And when we tried to do that, it was
clear that Ms. O'Connor never even read it.
Q. She never read the motion?
A. Never read the motion.
Q. Did she tell you that?
A. No. You can tell because I asked her a couple
of questions on there. And she -- I thought it was
pretty clear that she didn't read it. And Skip
Randolph, I think he acknowledged -- my recollection is
that he acknowledged he didn't read it.
Q. Skip Randolph said he didn't read it?
A. I said I think he acknowledged he didn't read
it. I think I said to him, "Skip, did you read this
piece of junk ?"
Q. And then you asked if I had children. You
asked Mr. Randolph if he had children, right?
A. No.
Q. Did you --
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MR. DESOUZA: Bob, hold on. Just for my
purposes, are you representing these are quotes in
the transcript?
MR. SWEETAPPLE: Yes. These are -- this is
Mr. Randolph's memo, and I have Ms. O'Connor's
memo, exactly what was said at this meeting.
MR. DESOUZA: I didn't know if you were
representing these as quotes.
BY MR. SWEETAPPLE:
Q. You asked whether Mr. Randolph had children,
right? And he indicated, yes, he did.
A. Well, again, you have to look at it in the
context. You can't take it into context. What I said
to him is something like, it's a shame that we have to
get the children involved. It's a shame.
And what Skip said to me is, Well, your son is
different. He is the one who's the plaintiff in these
cases."
And what I said is, "Well, if he's a plaintiff
in these cases, what does that have to do with trying to
take his license away from him? What does that have to
do with that ?"
Q. Your son is not the plaintiff in the case, is
he? He's a lawyer in the law firm.
A. No. What he was saying is that he -- in other
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words, his firm -- and it was made very clear to me
then, it is very clear to me now that you want to go
after my son because you can't handle big daddy.
Q. Mr. O'Boyle.
A. We'll see.
Q. Mr. O'Boyle, did you ever say that you had
millions of dollars, and you would be willing to spend
millions of dollars in responding to this issue?
A. Never.
Q. Did you say if you think you've seen a lot of
activity from them now, you haven't seen anything yet?
A. I've seen a lot of activity from --
Q. If you haven't -- if you think you were seeing
a lot of activity, you haven't seen anything yet.
A. No.
Q. And did you say -- did you ask Mr. Randolph if
he has a wife?
A. I don't think so.
Q. And Mr. Randolph responded "yes."
A. Could be.
Q. And then you said that your wife was going to
bed each night crying and how she got up this morning
and suggested that Marty hire a slew of private
investigators.
Did you ever make that statement that your
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wife was going to bed crying at night and suggested that
morning that Marty hire a slew of private investigators?
A. She did -- she was going to bed at night
crying, yes, because of your activities. Now, as far as
private investigators, I don't really recall that. I
really don't. On the other hand, my opinion, it may not
have been a bad idea. But certainly we didn't do it.
Q. And did you then say to Mr. Randolph, you
needed to only hire two private investigators because
you have two targets?
A. Who were the two targets?
Q. Did you ever say you only need two private
investigators because you have two targets?
A. I don't think so.
Q. He asked you what you meant by that, and you
refused to explain. Did that occur?
A. My recollection is there were a couple of
points during the discussions that he asked me -- that
he asked me, and that I didn't answer him. But I don't
remember it here about two PIs.
Q. Did you ever make reference to any of the
attorneys' daughters?
A. No. I asked Miss -- I'm going to say
Ms. Morgan. I'm sure that's not it -- who's the girl
sitting next to you?
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MR. SMITH: Ms. O'Conner.
BY MR. SWEETAPPLE:
Q. The one you said lied in federal court?
A. Yeah. Her.
Q. You don't know her name?
A. I just told you no.
Q. And what lie do you believe she said to
Mr. Middlebrooks -- Judge Middlebrooks.
A. She can read the -- she or Mr. Thrasher can
read the transcript. And now -- and if I get a chance,
if you'd like, I can read the transcript and I would be
glad to send it to you, Mr. Sweetapple, if counsel will
allow me to do so.
Q. I'm sorry. You said she lied to Judge
Middlebrooks.
A. Yes.
Q. Can you tell me what the lie was that you've
made such a terrible assertion of this member of the
bar?
A. Yes. Of that member of the bar she lied to a
federal judge. What she said is that the town allows
these type of signs, and I don't remember exactly what
type of signs.
But the town does not allow those type of
signs, and she lied.
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Q. So she had an opinion of the law as to what
the town allowed, and you said that's a lie?
A. No. She didn't have an opinion on law.
Q. She was giving her opinion on what the town
allowed.
A. That's what you said.
Q. That's what you just said. I'm just quoting
you.
MR. DESOUZA: I don't think he said the "word
opinion of law." Why don't we just move on.
BY MR. SWEETAPPLE:
Q. And you indicated earlier that I have defamed
you. How have I defamed you?
MR. DESOUZA: I don't recall him saying that,
but...
BY MR. SWEETAPPLE:
Q. You did. You said I defamed you and you sued
me for defamation. Tell me how I defamed you.
A. Do you have the Complaint?
Q. You tell me how I defamed you, please.
A. I want you to read the Complaint.
Q. Can you tell me?
A. I'm not going to.
Q. You don't know?
MR. DESOUZA: That's not what he said.
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THE WITNESS: You read the Complaint.
BY MR. SWEETAPPLE:
Q. Is there something you believe I said about
you that's untrue, Mr. O'Boyle?
A. You're going to read the Complaint and you
will find out.
Q. So you can't tell me as you sit here?
A. I just told you --
MR. DESOUZA: That's what he said, Bob.
BY MR. SWEETAPPLE:
Q. Did you ask Ms. O'Connor whether O'Connor was
her maiden name?
A. Yes, I did. And the reason I did, just -- I
don't think I asked her what her maiden name was. We
had run a Lexus -Nexus report, and it showed the name
like Boecker, B- o- e- c- k -e -r.
I asked Ms. O'Connor -- I got her name right
that time -- I asked Ms. O'Connor if Boecker was her
maiden name. She said, "No, that was my first husband's
name from my first marriage." That's where that came
from.
Q. Did you ever tell Ms. O'Connor and
Mr. Randolph that the pleading that was filed was quote,
a piece of shit, it was full of shit and that, you,
Mr. O'Boyle would get back at us for it. Did you ever
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say that?
A. No
shit.
it?
Page 234
But I'm certain I said it was a piece of
Q. Did you ever say you would get back at us for
A. Never.
Q. So Mister --
A. I certainly had plenty of time since then.
Q. So Mr. Randolph is not telling the truth in
his memo here.
A. I have no idea what Mr. Randolph is -- wrote,
didn't write, says, didn't say. I'm just telling you
what I know.
Q. Did you ever say that you're not a violent
man; and that you've never been in a fistfight and
you've never touched anybody, and hold up your hands
while you said that?
A. Exactly. Let me give you the context of that.
I said, "Why do we have to get the kids
involved? It's crazy to get the kids involved."
I said, "The problem is, somebody is going to
end up getting hurt."
Q. Well, you --
A. I said, "Now, I don't mean violent, because
I've never touched anybody with these hands. Never
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touched a human being with these hands." And that's the
extent of the way the conversation went.
Q. You got your son involved by having him move
a -- allegedly Pennsylvania law firm into your building,
and feed him hundreds of cases in a foundation that you
were funding, right?
MR. DESOUZA: Objection.
BY MR. SWEETAPPLE:
Q. Didn't you get him involved?
MR. SMITH: Objection. Augmentive.
MR. DESOUZA: Objection. Asked and answered.
He is not going to answer it again.
BY MR. SWEETAPPLE:
Q. You called me a criminal with regard to the
way I treated your son. Do you think that the way
you've treated your son is appropriate here,
Mr. O'Boyle, or are you ashamed by what you've done?
MR. TAYLOR: Objection. Argumentative.
MR. DESOUZA: Objection. Argumentative.
BY MR. SWEETAPPLE:
Q. Do you realize that you have put your son in
an untenable position by having his firm serve as your
attorney so that your animosity and hatred and
vindictiveness can be served?
MR. DESOUZA: Hold on. Objection.
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Argumentative.
MR. SMITH: Don't answer that question.
MR. DESOUZA: Marty, hold on.
MR. SMITH: Really, Bob.
MR. DESOUZA: Why don't you ask him an actual
question and answer instead of your argument asking
if you agree with it.
THE WITNESS: He can't.
BY MR. SWEETAPPLE:
Q. Did you tell Mr. Randolph and Ms. O'Connor
that you had properties in Gulf Stream and that you were
going to turn them into sober houses?
A. No. This was towards the end of the
discussion. And I don't remember exactly, but I
remember I used the word "landscaper." And Skip
Randolph went like a rocket in the air, and he said,
what have you got against landscapers? What is wrong
with a landscaper?
I said, "Whoa, whoa. Nothing is wrong with a
landscaper. But you wouldn't hire a landscaper, as an
example, to do brain surgery."
And then as we neared the end, I said, "you
know, maybe what I'll do is this. Maybe what I'll do is
just go ahead and put a sober house in the town, and
that will be it."
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When I said that, the meeting abruptly ended.
They made it clear to me that handicapped people in the
Town of Gulf Stream, they better not show up there,
because they're not going to go anywhere, so...
Q. What did they say to you? Who said what to
you on that?
A. Mr. Randolph and Mr. Morgan and Mr. Thrasher.
They clearly --
Q. At this meeting -- this meeting was --
A. This meeting.
Q. We're talking about a meeting that took place
on June 4th between four people.
A. Right.
Q. And you were describing that to me and all of
a sudden you went into this --
A. What do you want to know?
Q. -- fantasy. I would like you to stick on the
topic.
A. It's not a fantasy, sir, and don't -- don't
start.
Q. Mr. O'Boyle, you were talking about a meeting
with four people. Okay? And I asked you whether or not
you said that you were going to turn properties in Gulf
Stream into sober houses. What was said in response to
that?
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A. And I answered your question.
Q. Did Ms. O'Connor or Mr. Randolph respond to
that?
A. Mr. Randolph told us to leave the building.
He said, "This meeting is over. Leave the building."
Q. And didn't you bring up the fact that Bill
Thrasher was supposed to be fired?
A. Bill Thrasher was certainly supposed to be
fired. He was supposed to be fired. I may have -- I
don't know if I brought it up at that meeting, but John
Worthline wanted to fire you. George Elmore. Tom
Ladony (phonetic). Marty O'Boyle. Jonathan O'Boyle.
That's five. And heck, I can't remember the other two
or three.
Q. At that meeting on the 4th of June, did you
say that you wanted Mr. Thrasher fired?
A. No. What I said was -- and I don't know how
we got on the subject. But we were talking about the
agreement we currently have. And he said, you breached
it. I said, breached it? What do you mean I breached
it? How could I have breached it? You breached it.
He said, how did we breach it? And I told
them that you were supposed to fire Bill Thrasher.
Joan, George Elmore, Tom Ladony, myself, Skip Randolph,
my son, and one or two others.
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He said, "Well, you know that Joan doesn't
have the authority to do it on her own. She has to come
to the commission."
I said, "Yeah, I do know that."
He said, "Well, then, how could there have
been -- how could we breach the settlement agreement ?"
I said, "She never tried. She never even
tried."
Q. So you want Mr. Thrasher fired.
A. Oh, yeah. I would love to see him fired. He
should be fired.
Q. That's one of your goals.
A. Well, I wouldn't say it is one of my goals. I
think he should be fired to save the town a fortune.
Q. That was one of your platforms when you ran
for office, right?
A. Pardon?
Q. That was one of your platforms when you ran
for office?
A. Same as Mr. Morgan. Me and Mr. Morgan, same
thing. He said Mister -- Maybe it's time for
Mr. Thrasher to do his victory lap. Maybe his time has
passed and so on and so forth. So don't let him kid
you.
Q. So you made it -- it's your desire to have
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Bill Thrasher fired, right?
MR. DESOUZA: Objection. Asked and answered.
BY MR. SWEETAPPLE:
Q. You've publicly stated repeatedly that you
goal is to have Mr. Thrasher fired, right?
A. Never. No.
Q. And you, at this meeting, stated that you
believe that the town was obligated to fire -- breached
a settlement agreement to fire Mr. Thrasher.
A. I said they breached the settlement agreement
by not firing Mr. Thrasher. That's exactly what I said.
Q. Is there any written settlement agreement that
required Mr. Thrasher to be fired?
A. No. But if you want to say George Elmore has
no credibility; you want to say that Skip Randolph has
no credibility; you want to say that Tom Ladony has no
credibility. I'm sure you will say I have no
credibility. But there are a few others as well.
Q. And immediately after leaving this meeting,
did you -- strike that.
Did you have permission from the O'Boyle Law
Firm to participate in this meeting on June 4th?
A. Yes.
Q. And who gave you that permission?
A. Bill Ring. I was with him.
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Q. Bill Ring was not at the O'Boyle Law Firm at
that time. He was not a member of the law firm.
A. I think he was.
Q. When did he join the law firm?
A. You have to ask him.
Q. I'll look at my chronology and I'll tell you.
(Discussion held off the record.)
A. I'm talking about cabs.
MR. DESOUZA: It's going to be hard to
converse with you and take it down at the same
time.
BY MR. SWEETAPPLE:
Q. And is Mr. Ring employed by the O'Boyle Law
Firm now?
A. To my knowledge, yes.
Q. And he gets remuneration from them?
A. To my knowledge, yes.
Q. None of your entities employ him directly?
A. I don't think so. But I don't know. I mean,
again, I don't know.
Q. And on June 19, didn't Mr. Ring e-mail
Mr. Chandler and indicate he was going to become a
partner in the firm, June 19?
A. I don't know.
Q. So when you were at this meeting, was Mr. Ring
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a member of the O'Boyle Law Firm or not?
A. Was what?
Q. Was Mr. Ring a member of the O'Boyle Law Firm
or not on June 4th at that meeting?
A. I'm assuming he was. If not, I'm assuming he
would have spoke to the appropriate people.
Q. And --
A. Whoever they may be.
Q. What settlement offer did you believe you made
at this meeting?
A. Well, I think it was a sort of a global kind
of settlement to talk about what do we have to do. The
first thing we did is we went in and we said -- I said
this meeting is for settlement purposes only, and for no
other purpose.
And Mr. Randolph, said, well, wait a minute
now. What if, you know, we talk about something else?
And I said, well, of course we're going to talk about
something else. I mean, we may digress and talk about
what we had for dinner last night. This is a settlement
conference.
And then he and Bill Ring went back and forth
quite a bit. And then I said to Bill, are we resolved?
And he said, yes.
And that's when we started the meeting. So if
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not, I would have never -- I would have walked out of
the meeting. I would never have went into the meeting
without it being a settlement conference.
And what we did, I think the first thing we
talked about was your -- I don't know what you call it,
your motion. And we explained that it was a bad motion;
that there was no factual basis to it, and we were going
to -- if we didn't already. When I said "we ", I don't
mean me as a lawyer, I want everybody to know that.
"We", meaning I was there; that we were going to file a
157, whatever it is called, sanction.
(Interruption.)
THE WITNESS: 157 sanction. And what we'd
like to try to do is get rid of this thing. And
then once we do, to talk about some of the other
things and how we might resolve them.
And as I recall, the way Joanne had signed
this, and she looked like she had buyer's remorse,
but I can't tell her facial expressions. But we
filed the sanctions, for sanctions, and her and
Skip withdrew the motion.
Because I think what happened was Skip
probably said, what is this all about? And
guessing now -- I shouldn't -- but in any event,
that was sort of the way it went. We talked about
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the children, getting the children involved, which
is just plain stupid to get the children involved.
After all, your daughter is going to be a
lawyer very soon. How would you like if I put a
private detective on your daughter? I wouldn't do
it and I won't do it, but how would you like that?
BY MR. SWEETAPPLE:
Q. If my daughter engaged in the activities that
you and your son had engaged in, I would expect that
appropriate ramifications would occur. We have laws in
this state with regard to who practices law, how we
practice law --
A. How we get DUIS.
Q. Right. Exactly.
MR. DESOUZA: You don't need to make
statements back and forth.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle.
MR. DESOUZA: Just questions and answers.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle, you're the one that put your son
in this position, not me.
A. You already told me that.
Q. And I'm sure it will be like your daughter's
DUI, the whole world will responsible but not you
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because you're never responsible.
MR. SMITH: Bob -- objection.
MR. DESOUZA: Objection. Let's take a break.
At this point there is nothing beneficial going on
here.
MR. SWEETAPPLE: Let's take a break and as
long as you need. I'm about to go into the motion
to disqualify and the motion for sanctions and the
specific evidence.
MR. DESOUZA: Great.
THE VIDEOGRAPHER: The time is 4:20 p.m.
We're going off the record.
(At 4:20 p.m. a brief recess was had.)
THE VIDEOGRAPHER: The time is 4:36 p.m. We're
back on record.
BY MR. SWEETAPPLE:
Q. All right. As far as this meeting that
occurred on June 4th, did you or Mr. Ring make any
settlement proposal?
A. Yes. In a general way.
Q. What did you propose?
A. We proposed, first of all, to get rid of that
motion; the one that we said, "whose brainchild was
this." And then we talked about the other -- I think we
talked generally about the other lawsuits.
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Q. What proposal did you make to settle?
A. I think we talked about resolving and getting
rid of the motion as a condition precedent to then going
in and talking about the various record suits.
Unfortunately, we didn't get beyond that part.
Q. So there was never a formal settlement offer
made by either side?
A. I wouldn't say that.
Q. Was there a formal settlement offer made by
either side?
A. I think so.
Q. Who made a formal offer?
A. I think we did.
Q. What did you offer to do to settle -- to
settle all the cases?
A. I think what we said was that this motion is a
piece of garbage.
Q. You said it was a piece of shit, actually.
A. Piece of shit. You're right. I did say it
was a piece of shit. I'm glad you recognize it as such.
Q. I don't. I don't think the people that review
this are going to recognize it as that either.
A. Okay. But in any event, we talked about
getting rid of that. And then we talked about, I think,
how many other suits there were pending. And let's see.
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If we can get rid of this and let's address that.
Q. And so you were unable to meet the condition
precedent, correct?
A. No. No. You were unable to -- unwilling to
meet the conditions precedent.
Q. When you say "you ", you're talking about
Mr. Randolph and Ms. O'Conner?
A. Yes. Uh -huh.
Q. So you never got to the issue of a global
settlement?
A. Well, I wouldn't say that. I would say that
we started off talking about the motion. That's where
we started. And then you sort of migrate, and sometimes
after that happened, there's no telling where it would
have went, this way, that way, the other way. This was
the main event in our eyes.
Q. So you wanted to get rid of the motion?
A. Yes.
Q. What were you willing to do if they got rid of
the motion to settle the litigation?
A. Well, they were willing to -- hopefully,
figure out a way to get rid of the records suits.
Q. All the lawsuits?
A. Well, I don't know, because we didn't get that
far.
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Q. Well, did you have a proposal in mind when you
went to that meeting to settle?
A. I think we -- the proposal that we had in mind
was to start with that motion. And that's exactly what
we did.
Q. You wanted the motion to be withdrawn and then
you were going to just discuss settlement?
A. That's the way that I'm familiar with how you
make a settlement.
Q. Well, normally you have a proposal in mind.
What was your proposal to settle all the cases?
A. Normally you may have a proposal in mind. I
do it my way, you do it your way. I told you the way I
do it, and let's move on.
Q. I'm just trying to understand what happened
because I haven't heard of a settlement proposal from
you and I haven't heard a settlement proposal recounted
in your testimony from Ms. O'Connor or Mr. Randolph.
I heard you call it a settlement conference.
Were there any proposals made by either side to settle
the litigation?
A. We made it clear that when we got there, that
the meeting was for settlement purposes only and for no
other reason. No other purpose. And then we talked
about the motion, and then it meandered a little bit
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here and there. And then when it was clear that the
motion was not going to be resolved, then we talked
about some other things.
And then Mr. Randolph, when we talked about
handicapped people, he -- he shocked me. Handicapped
people and landscaper. He just shocked me.
Q. How did he shock you?
A. He asked us to leave. Shocked me. I mean, I
would never expected a Jones Foster lawyer to
discriminate against handicap people like that.
Q. What did he say to you that you thought was a
discrimination?
A. I'm trying to think for a second. When I
raised the sober house, I said, well, maybe what I'll do
is just put in a sober house down there. And he just
said, This meeting is over. Go ahead and leave. It's
over."
Q. That's all that happened?
A. Well, no. It was -- the meeting probably
lasted an hour and 45 minutes.
Q. I'm talking about the subject of you said he
discriminated against handicapped people. Did he say
something? He just said the meeting is over?
A. Well, no. But it was based upon a sober house
which is handicapped people.
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Q. Well -- and you think that he didn't just
terminate the meeting because it was clearly your only
reason for being there was to try to intimidate and make
demands?
MR. DESOUZA: Objection.
THE WITNESS: First of all, I didn't try to
intimidate. Secondly, I didn't try to make
demands. Thirdly, if either of those two were his,
that was his goal, he would have said it long
before I ever raised the word sober house.
BY MR. SWEETAPPLE:
Q. And had you been thinking about opening sober
houses before that meeting?
A. I had been thinking about it, and thinking as
we sit here right now.
Q. Okay. And were you threatening that to the
town to try to get them to do something? Why did you
say that?
A. I just said it.
Q. Was it a threat?
A. No.
Q. Why were you bringing that up at that time?
A. I'm not sure. We may have -- we talked about
something in advance to that. And I remember a
landscaper. I raised a landscaper. So I don't
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remember, but that is my recollection of what happened.
Q. Were you threatening that you were going to
open a sober house if the town didn't stop pointing out
the allegations regarding your son's law firm?
A. Well, it has been four months. Have I opened
up a sober house?
Q. Well, let's talk about that. Two days later
after the meeting you went to the town and gave them a
letter. If you'll mark this next, please.
(Defendant's Exhibit No. 16 was marked for
identification.)
BY MR. SWEETAPPLE:
Q. The next date, June 5th, you had a banner
flown, didn't you?
A. I don't know.
Q. Well, didn't you have a banner flown that says
"Jones Foster clients check your bills ?"
A. I think I had a banner flown that said that.
I don't know if it was the next day.
Q. Well, you don't -- did you -- are you the one
that arranged that banner?
A. Indirectly, yes.
Q. Indirectly, you mean you told someone to do
it?
A. Yes.
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Q. Who did you tell to do it?
A. I don't know.
Q. And what airline, what company did it?
A. I don't know.
Q. And who wrote the language, "Jones Foster
clients check your bills ?"
A. Probably me.
Q. And why did you have a banner that said,
"Jones Foster clients check your bills ?"
A. I thought, and I still think, that this whole
crowd is out of control. Jones Foster's bills went from
3 or 4,000 a month, to 50 -- 45, 50,000 a month, which
is awful high. And I think it is good for the people,
good for the town, good for everybody, for people to
check their bills.
Q. Weren't you implying that Jones Foster clients
were being ripped off in their billings?
A. No. You must -- you have a dirty mind.
Q. Isn't that a normal -- you said clients, Jones
Foster clients. You didn't refer to the town. You
referred to their clients.
A. Yes.
Q. So you wanted their clients to check their
bills?
A. Yes.
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Q. You don't think it's a reasonable
interpretation that that is an implication that Jones
Foster somehow is overbilling their clients?
A. No.
Q. And you didn't intend to create that
impression when you had that banner flown?
A. No.
Q. So a jury shouldn't reasonably think that that
was a statement implicitly that Jones Foster is, in its
bills, ripping off its clients?
MR. DESOUZA: Objection to form.
THE WITNESS: No. Not at all.
BY MR. SWEETAPPLE:
Q. And then the next day you had a banner flown
up and down Palm Beach County; are you aware?
A. No.
Q. Do you remember it?
A. No.
Q. Do you recall there was a bar installation
meeting at the Breakers?
A. No.
Q. And you had a banner fly that said "JF don't
drink and drive, we'll be watching." Do you remember
that?
A. I remember the banner. I don't remember it
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even going near the Breakers.
Q. Well, did you direct -- do you direct where
these banners go, where the planes fly?
A. Generally stated I would say yes.
Q. So where did you -- who do you talk to about
where you want the planes to fly?
A. My secretary.
Q. Okay. And where did you say you wanted the
"JF don't drink and drive we'll be watching" banner?
A. I don't remember. But it was between point A
and point B.
Q. So you don't remember the specifics of it?
A. No.
Q. And what about the "Jones Foster clients check
your bills." Did you give her a geographic area for
that?
MR. DESOUZA: Object to form.
BY MR. SWEETAPPLE:
Q. A geographic area to have the planes fly?
A. Yeah. The answer is -- I don't recall. I
mean, I just don't recall.
Q. And on June 6th, that same day that you had
the "JF don't drink and drive, we'll be watching you,"
you were doing this out of anger because Jones Foster
wouldn't dismiss the motion regarding disqualifying the
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law firm, right?
MR. TAYLOR: Object to form.
MR. DESOUZA: Same.
THE WITNESS: I thought you were a lawyer, not
a psychiatrist.
BY MR. SWEETAPPLE:
Q. I'm just asking you a question. That's really
why you did it.
A. Don't tell me about me being -- about anger.
Q. Well, I can lead my questions. What was your
motivation if it wasn't anger?
A. Why don't you read me your question again.
Q. When you had these two banners flown, was it
done out of anger?
A. No.
Q. Was it done for the purpose of retaliating?
A. No.
Q. Why was it done? Why was it done immediately
after this meeting that Mr. Randolph carefully details
in his two- and -half page memo?
MR. DESOUZA: The two - and -a -half page memo
that you're saying he carefully detailed that
you're not going to share with us?
MR. SWEETAPPLE: I'm going to wait to see if
you decide if this was a settlement meeting or not,
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because if you take the position with the court
that it's a settlement meeting, I don't think
you're entitled to it.
If you admit it's not a settlement meeting, I
think you are. So I guess we'll have that
discussion before the judge when you decide what
side of the bed you're on. Your client seems to
think it's a settlement conference. I don't, but
we'll have a debate about it.
MR. DESOUZA: Bob, I'm simply referring to
your statement that Mr. Randolph carefully detailed
something you haven't shared with us.
MR. SWEETAPPLE: I read you excerpts from it
and you'll see Ms. O'Connor has one that is
remarkably similar to it. And contrary to
Mr. O'Boyle's statements, I know the both of them
to be ethical people. But anyone who relies on
Mr. O'Boyle's judge of character does so at their
own risk, I suggest.
MR. TAYLOR: You don't need to respond when
all he is doing is giving a speech.
MR. DESOUZA: Marty.
MR. SWEETAPPLE: I have sat here and listened
to him tell me my co- counsel lied to federal
judges.
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Let's talk about this letter, Exhibit 16. You
wrote --
MR. DESOUZA: Hold on. Is this a one -copy
letter? Can I see it?
MR. SWEETAPPLE: Yes, you can.
MR. DESOUZA: Thank you. Do you have an extra
copy of this, or just the one?
MR. SWEETAPPLE: I do not. Apparently,
Mr. O'Boyle says it is floating all around Gulf
Stream. And he filed a lawsuit over that. It
concerns him that this letter would be floating all
over Gulf Stream.
MR. DESOUZA: Joanne, you have the letter?
MS. O'CONNOR: Yes. I'll get it.
BY MR. SWEETAPPLE:
Q. Mr. O'Boyle, do you recognize that letter?
MR. DESOUZA: It's not in front of him at this
point. Skip has it right now.
MR. SWEETAPPLE: Okay.
MR. SMITH: What is it? Six --
MR. DESOUZA: June 6.
THE WITNESS: Yes.
BY MR. SWEETAPPLE:
Q. Did you deliver this letter to the Town of
Gulf Stream?
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A. May I?
Q. Sure.
A. It was delivered from my office. It appears
to be from my office.
Q. So it was not delivered by hand, it was
delivered electronically or by fax?
A. I would say so.
Q. Okay.
A. Not faxed.
Q. And so you made -- you personally made the
decision to form a company to acquire houses in Gulf
Stream for use as sober houses. "I intend to begin the
implementation of this program forthwith," right? Is
that what you stated in the letter?
A. You're reading it, not me.
Q. Is that what you stated in the letter? And
did you, in fact, on June 6, two days after the meeting
with Mr. Randolph and Ms. O'Connor, form a company for
the purpose of opening sober houses in Gulf Stream?
A. I don't know.
Q. Did you direct Mr. Ring to form a company by
the name of Sweet Apple Sober Houses, LLC on June 6?
A.
No.
Q.
2014?
A.
No.
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Q. And the registered agent is indicated to be
William F. Ring, Jr. He is your attorney, right?
A. He is -- you can say he is my attorney, yeah.
Q. He was the attorney who was with you at the
meeting where you threatened to open sober houses,
right?
A. I didn't threaten anything.
Q. That's where you stated you were going to open
a sober house. He was the lawyer that was with you at
that meeting, right?
A. How about if I was going to open a hamburger
stand? Was that a threat?
Q. Mr. Ring was with you at that meeting, right?
A. Is that a threat?
Q. Was Mr. Ring in the vicinity of you when you
said you were going to open up a sober house?
A. I don't know if he was or not.
Q. And after that statement was made,
Mr. Randolph asked you to leave his office, right?
A. Yes.
Q. And within two days, Mister -- who actually
filed the Sweet Apple Sober Houses, LLC, Florida Limited
Liability Company articles with the Secretary of State?
A. I don't know.
Q. Did you ask that it be done?
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Pagc 260
A. Did I ask that it be done?
Q. Did you ask the secretary like Ms.
De Larmartini or someone to do that?
A. I would say yes.
Q. Who did you ask to do it?
A. I don't know.
Q. Was it Ms. De Larmartini?
A. I have no idea.
Q. Did you ask Mr. Ring if he was willing to be
the registered agent?
A. No.
Q. How did Mr. Ring's name get put on as the
registered agent?
A. We probably put it there.
Q. Without his permission?
A. Yes.
Q. Yes?
A. Yes.
Q. Since I filed the motion for sanctions, has
Mr. Ring asked to have his name removed as a registered
agent?
A. I don't think he knows it's there.
Q. Well, the motion was served on him and it
makes reference to this application. Do you know, has
Mr. Ring ever discussed with you -- have you discussed
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Page 261
with Mr. Ring the fact that his name is a registered
agent?
MR. DESOUZA: You can answer yes or no. I
don't want you to get into the substance of
conversations. You can answer whether you
discussed it or not.
THE WITNESS: What was your question again?
BY MR. SWEETAPPLE:
Q. Did you tell Mr. Ring you were putting his
name in as registered agent?
A. I don't recall that we did. That I did.
Q. You listed yourself as the manager, correct?
A. I don't know.
Q. And why did you pick the name Sweet Apple
Sober Houses, LLC? Was it in any reference to me?
A. It was a reference to -- the town was highly
objectionable to having sober houses. You, I thought,
were taking the position with the town that you were --
you're going to break them. And I thought we would put
that -- we would use that for a name, and that would be
the name. It was funny. And that ended up being the
name.
Q. So you did it because it was funny and you
thought I was taking the town in a way that would break
them?
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A. I think that you're going to end up breaking
the town is what I -- if I didn't make that clear,
that's what I think.
Q. So that's why you put my name on the sober
house company?
A. No. No. What I said was, you have to take
the two of them together. And I took the two of them
together. And I thought that it was a combination that
would knock everybody down a notch or two. I thought it
was funny. Besides all of that, it is something that
the First Amendment of the constitution allows me to do.
Q. That's your legal conclusion?
A. Yes, it is.
Q. Okay. And so the purpose was to knock people
down a notch or two?
MR. DESOUZA: Objection. Misstates his
testimony.
BY MR. SWEETAPPLE:
Q. Did you say that was one of the purposes, was
to knock people down a notch or two?
A. No. What I said was that the town is out of
control. I think you're out of control. I put the two
names together, and we formed the company.
I thought it was funny. I thought it brought
smiles to people's face. And in addition, I thought
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that it -- I thought -- I'm losing my train of thought
for a moment. Excuse me.
It would bring things down a notch or two, and
the First Amendment allows me to do it, so I did it.
Q. I guess we'll find out if the First Amendment
allows you to do it at some point.
A. Sure.
Q. But right now, what do you mean by "knock down
a notch or two ?" What are you referring to?
A. What I'm referring to is, when people get a
little high on their horse, you knock them down a notch
or two.
Q. So you use my name in order to knock me down a
notch or two?
A. I think so.
Q. In order to hurt my reputation to -- you
wanted to --
A. No, not at all.
Q. Did you want to affiliate me, my name as a
professional with your efforts to put sober houses in
Gulf Stream?
A. I wanted to layout the name -- can't think of
it now. Sweet Apple Sober Houses, because I thought it
was funny. I thought it would knock things down a notch
or two. Maybe make the people focus a little bit more.
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Take a closer look. And I thought that it was not in
violation of the constitution, so...
Q. You don't think it's defamatory to put my name
with an activity that you believe is offensive to
residents of Gulf Stream?
MR. DESOUZA: Objection. Form.
THE WITNESS: It shouldn't be. If the -- if
the people of Gulf Stream are going to discriminate
against handicapped people, shame on them, starting
with the top down.
BY MR. SWEETAPPLE:
Q. What if I wanted to put a sign up in a house
next to your house in Gulf Stream that said Martin
O'Boyle's whorehouse? You think the First Amendment
gives me the right to use your name in conjunction with
whorehouse?
A. After I spoke with my counsel, I will give you
an answer.
Q. Did you get any legal advice from any lawyer
before you decided to use the name, Sweetapple Sober
Houses, with regard to your efforts to place a sober
house in Gulf Stream, Florida?
A. Well, you asked two questions there.
Q. Did you obtain any advice from any attorney
with regard to the issue of whether or not it would be
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Pagc 265
defamatory to associate my name with a sober house in
Gulf Stream, Florida?
A. Well, first of all, I don't think it's your
name, but put that aside for a moment -- because it is
two names -- when we designed the name, we designed it
with you in mind. So I will just tell you that.
Q. Who is "we", Mr. O'Boyle?
A. Me.
Q. You said "we". Who did you mean?
A. I know I said "we."
Q. You didn't have someone else that you did this
with?
A. No.
Q. Did you discuss it with your wife?
A. No.
Q. How about your son?
A. No.
Q. How about Mr. Ring?
A. No.
Q. Just you?
A. Yeah.
Q. So you had me in mind.
A. Yes.
Q. You wanted to bring me down a notch or two and
you thought it was funny.
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A. Yeah, I did think it was funny.
Q. And you wanted to bring me down a notch or
two.
A. Yeah. I think you needed to go down a notch
or two.
Q. And
A. And I think the --
Q. And you think the First Amendment protects
you?
A. I think these guys need to go down a notch or
two or three.
Q. What about you? Do you think you have any
issues that maybe you need to confront?
A. No. But you're more than welcome, I would
invite you to utilize the First Amendment to take -- to
take any action that you wish that complies with
protect -- where you're protected by the First Amendment
against me. That's what it's there for and I would
encourage you to do it.
Q. Do you think you could open up something
called Sweet Apple's Whorehouse?
MR. DESOUZA: Objection.
MR. SMITH: Asked and answered.
MR. DESOUZA: Objection. You're asking him to
speculate at this point.
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BY MR. SWEETAPPLE:
Q. You're telling me your legal opinion as to the
First Amendment protects this. Did you give
consideration of whether or not you could say
"Sweetapple Unethical Law Firm" and put a sign up in
front of a building in Deerfield Beach? Just Sweetapple
Broeker and Vargas, rip -off lawyers. Do you think you
can put a sign up that said that, and that the First
Amendment protects you to do that?
A. The First Amendment protects you to do certain
things. Whether it protects you to do that, I don't
know.
Q. Do you think it protects you to directly or
indirectly defame people or to associate them with
businesses? You knew I had no association with this
business, right? I wasn't involved in this entity.
Strike that.
Did you believe that I had any involvement in
this company financially or otherwise?
A. I think I've answered the question multiple
times, and what I suggest is that we move on.
Q. Where would you like to move on to?
A. Wherever you would like.
Q. And after this letter was sent to the town,
did you become upset that people in the town obtained a
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copy of it?
A. Well, I think -- no, not upset. It's just it
annoyed me, because when you send a letter to the town,
they are not to send it to their cronies to spread it
around and say O'Boyle is a bad guy. So several people
called me and told me they had a copy of it. So all I
wanted to do is find out who has got a copy and where
they got it from, and then I'll deal with it.
Q. Okay. Well, that letter was sent to the town,
right?
A. Yes.
Q. And it's a public record.
A. Yes.
Q.
And anyone can ask
for a
copy
of it.
A.
I don't know about
that,
but,
yeah, I think
SO.
Q. Why couldn't anyone do like you do and go ask
for a copy of this letter?
A. I'm not answering that. I already answered.
Q. Didn't you expect when this letter was sent,
that it would become a public record?
A. What I didn't expect is that nobody would ask
for that public record and it be all over town. That's
what I didn't expect.
Q. How do you know no one asked for a copy?
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A. Because they put their public records on line
and it isn't there. Mr. Thrasher wrote it in writing.
He said -- there hasn't been a written request. It's
all verbal.
Q. Are you saying that in order to request this
document under public records law someone would have to
do it in writing?
A. No.
Q. So why couldn't someone ask for this letter?
A. They could.
Q. And why couldn't it have been given to them?
A. They could. And after I take their
deposition, I'll know.
Q. Whose deposition?
A. Figure it out.
Q. You sued the town alleging that this letter
was disseminated improperly, right?
A. I don't think I said improperly, but maybe.
Q. You subpoenaed me because you want to know
what I know about how this letter was disseminated,
right?
A. Because it showed Mr. Thresher said it was
only disseminated to three people, he said to Miss -- I
can't think of your name again.
MS. O'CONNOR: O'Connor.
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THE WITNESS: O'Connor, Mr. Randolph and you.
BY MR. SWEETAPPLE:
Q. So we got copies of this -- written copies of
it?
A. Yeah.
Q. And you want my deposition because you don't
understand that any individual could walk in and get a
copy of this letter and, in fact, did?
A. That's not what I said.
MR. DESOUZA: Objection to form.
BY MR. SWEETAPPLE:
Q. We'll deal with that in your lawsuit.
A. We sure will.
Q. And you e- mailed Gordon Craft on June 15.
"Gordon, I feel no obligation to respond. I'm writing
to you now voluntarily. I have no intention of putting
a sober house in Gulf Stream for reasons inter alia.
"I wouldn't have a clue on how to run one. I
was, however, approached by an out of state company that
seems set on putting sober houses in Gulf Stream and the
surrounding areas, but only on the water in Gulf Stream.
For reasons unknown to me, they asked me to lead their
charge. They offered to pay me a very handsome sum.
I'm struggling with their offer whether to accept it or
not. As I said, it's a ton of money, and I know if I
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don't take it, someone else will.,,
Did you write that e-mail?
A. I did.
Q. Why would it concern you that someone -- that
people in Gulf Stream would know of your stated
intention to open sober houses?
A. Because I think the hierarchy, the mayor,
Mr. Thrasher, I think they lie and I think they did it
in an effort to try to dirty me up. And all I want to
do is what I'm entitled to do, Mr. Sweetapple.
Q. Mr. O'Boyle, how would associating you with
your letter to open sober houses dirty you up?
A. You can ask them.
Q. I would like to know from you. You said you
didn't want this letter being disseminated because it
would dirty you up. Tell me how would it dirty you up?
A. It has been disseminated. People -- if you
read Mr. Kraft's letter, I think you'll learn a little
bit. It says there, "I can't believe you're going to
put a sober house. Your going to ruin the whole town."
So I think that gives you a little hint.
Q. So in other words, your neighbors got mad at
you because you were going to open a sober house.
MR. DESOUZA: Objection to form.
THE WITNESS: Let me tell you something. I
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don't know whether my neighbors got mad at me or
not, but you know what? If my neighbors want to
discriminate against handicapped people and if the
mayor wants to and the town manager, to hell with
each other.
BY MR. SWEETAPPLE:
Q. Because you're going to open a sober house,
right?
A. We' 11 see.
Q. And you want to call it Sweet Apple's Sober
House?
A.
I like
that name.
I
do
like
that
name.
Q.
Good.
We'll see
how
we
deal
with
that,
Mr. O'Boyle.
A. Yeah.
MR. DESOUZA: Is that a question?
MR. SWEETAPPLE: No, that's not a question.
MR. DESOUZA: Great. Do you have a question?
BY MR. SWEETAPPLE:
Q. Which company, out of state company has
contacted you that has offered you money to open up a
sober house? Is that true or is that just something you
made up to further your intimidation?
A. No, it's true.
Q. What's the name of the company, Mr. O'Boyle?
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A. I think it was called Tin -- I think was
called Tin Turn Corporation, and they were out of -- I
think either Red Bank or New Silver [sic] New Jersey.
Q. And how did they contact you?
A. I guess one of my friends. I do have some
friends.
Q. Real friends?
A. Yeah. Yeah.
MR. DESOUZA: You don't have to answer that.
That is ridiculous.
THE WITNESS: Yeah. Probably mentioned that
I'm in Florida, I'm a real estate developer, and I
have some knowledge of high -end real estate.
BY MR. SWEETAPPLE:
Q. And who is it that contacted you?
A. I think it was called tin -- Tin Turn.
Q. And did they write you or call you?
A. They called me.
Q. Did they ever write you?
A. They may have.
Q. Do you have any a -mails from these people?
Any writings from these people?
A. I don't know.
Q. Who did you speak to there?
A. You know --
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Q. You said they made an offer, very handsome
SUM. How much did they offer you?
A. I think it was a quarter million dollars, the
project. I think.
Q. To get an approval or for the land, or what?
A. For -- to get it developed to where --
whatever had to be done. Go through the approval
process, and do whatever has to be done. I don't know.
As an example, maybe a bathroom has to have handicapped
facilities. It may have to -- I don't know.
Q. It was a very attractive offer, right?
A. I thought so.
Q. You were struggling with it, right?
A. I was struggling with it.
Q. Trying to decide if you could accept it or
not, right?
A. No. Trying to decide if I wanted to accept
it.
Q. So if you decided to accept it, who would you
contact to let them know you accepted? What's the name
of the person and the telephone number? Where do you
have that?
A.
I
don't
know. I
may have chucked it.
Q.
So
if I
asked you in a request to produce for
the name
of
this
supposed
person that offered you a
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Pagc 275
quarter of a million dollars and their contact
information, you think you chucked it?
A. We'll find out. You send a notice to produce
and we'll find out.
Q.
Do you
recall what
you did with it? Did you
ever write
that
information
down?
A.
I just
told you a
second ago that I didn't
know.
Q. I haven't asked you if you wrote it down. I
asked you if they wrote you. Now I'm asking you if
wrote this information down.
A. That's what you asked me. You asked me that.
And what I told you is the best I can tell you.
Q. Let's talk about the motion to disqualify the
O'Boyle Law Firm and in the alternative for an
evidentiary hearing, which --
MR. DESOUZA: The withdrawn motion?
MR. SWEETAPPLE: Well, it's going to be. It's
been, first of all, dealt with appropriately as
required by law. Second of all, it is going to be
an amended affirmative defense and counterclaim in
these cases, as well as be a part of other lawsuits
that are being filed.
But it has -- as the motion said, not been
abandoned. We decided we did not want to pursue
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the relief by just asking to have the law firm
disqualified. We want to seek more serious and
permanent relief.
MR. DESOUZA: I understand.
MR. SWEETAPPLE: Just a motion -- if you saw,
the motion was withdrawn without prejudice to all
the rights that are enumerated in that withdrawal,
which obviously we're obligated to pursue and we
will discharge all the law obligations.
MR. DESOUZA: And thank you for that. I was
just asking whether this is the withdrawn motion.
MR. SWEETAPPLE: Of course you knew that. You
saw that we withdrew it and said that's what we
were going to do. So again, you're editorializing
and being facetious. But that's okay. Let's go
through the motion that you said was shit,
Mr. O'Boyle.
MR. DESOUZA: Apparently, I'm editorializing
when Mr. Sweetapple has talked for hours in this
deposition just making statements without
questions.
MR. SWEETAPPLE: They're called leading
questions, Counsel. That is what I do with adverse
parties all the time. So I haven't heard a form
objection in five hours, and now you're giving
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speeches again about the depo. You haven't made
one form objection in five hours.
MR. DESOUZA: I tell you what. We go back
through the record and if you find a form objection
in the last five hours, do I get a prize?
Because I believe I have made several form
objections.
MR. SWEETAPPLE: When I'm leading the witness
you have never taken any objections to my making
statements and saying isn't that true. That's what
you do when you have an opposing party. That's how
you cross - examine, and that is how you're permitted
to depose an adverse party.
MR. DESOUZA: That's your 34 years of
experience talking, right?
MR. SWEETAPPLE: Yeah, you can lead.
MR. DESOUZA: Bob, I don't care what your
instructions are. Just ask your questions.
MR. SWEETAPPLE: Well, my question are
statements followed with "isn't that true" quite
often.
THE WITNESS: Listen to him. You'll learn.
MR. DESOUZA: I know --
MR. SWEETAPPLE: That's what I'm permitted to
do obviously. It should be clear. It should be
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clear to you that is what you do.
THE WITNESS: You need to listen to him.
BY MR. SWEETAPPLE:
Q. Let's go back to the allegations regarding
your son, Mr. O'Boyle.
Was your son's firm originally called the
O'Boyle Law Firm and created in November 2013?
A. I don't know.
Q. Did it list with the Pennsylvania Department
of State its registered office address at 1001 Broad
Street, Johnstown, Pennsylvania, but no mailing address.
A. I don't know.
Q. Did you ever look at that? When you saw this
motion, did you ever investigate that?
A. Do you have any documents to show me? Then I
won't have to investigate it. We can resolve it right
now.
Q. I'm asking whether or not when you read
Paragraph 1 in the motion if you did anything to
investigate if the facts alleged in that paragraph were
true?
A. No, I didn't do anything.
Q. Did you speak to your son to ask him if the
facts were true?
A. No.
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Q. Paragraph 2 says, "According to the Florida
Department of State, Division of Corporations, the
O'Boyle Law Firm PC, Inc., is a foreign profit
cooperation with a principal address in Deerfield Beach,
Florida. The corporation lists a mailing address at
2146 East Huntington Street in Philadelphia,
Pennsylvania."
Did you do anything to investigate whether
that paragraph was true?
A. No. But I do want to point out, that Kevin
Tyne (phonetic) who is an ethics lawyer, wrote to you in
connection with the inquiries that you made and said if
you have any questions to please contact him. Something
that you refuse to do. Go ahead.
Q. I'll be happy to show you my letter to him,
and his response which did not answer my questions that
I did pose to your son. In fact, it specifically
ignored numerous questions that I asked your son, and
did not dispute other assertions I made in my letter.
So we'll be happy to go over all that with you,
Mr. O'Boyle.
Let's go to No. 3. Do you want to answer with
regard to No. 2? Did you do anything to determine
whether or not the allegations in Paragraph 2 are true
or false when you got this motion?
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MR. SMITH: I don't have the motion.
BY MR. SWEETAPPLE:
Q. I just read them to you.
"According to the Florida Department of State,
Division Of Corporations, the O'Boyle Law Firm PC, Inc.,
is a foreign profit corporation, with a principal
address in Deerfield Beach, Florida. The corporation
lists a mailing address at 2146 East Huntington Street
in Philadelphia, Pennsylvania."
Did you go and look at the Department of
State, Division of Corporation filing for the Florida
O'Boyle Law Firm PC, Inc., filing to see if that
statement was true?
A. I did not.
Q. Do you know if it's true or false, that
statement?
A. I don't know.
Q. Three. With regard to 2146 East Huntington
Street, Philadelphia, Pennsylvania, do you recognize
that address?
A. I don't.
Q. Is that an address where one of your children
resides?
A. Maybe.
Q. Is it where your daughter resides?
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A. It may be.
Q. You don't know for sure?
A. Don't know.
Q. Isn't it a townhouse in Philadelphia where
your daughter resides?
A. Don't know.
Q. Did Jonathan ever reside there?
A. Don't know.
Q. Did Jonathan ever conduct law out of that
location?
A. Don't know.
Q. Have you ever asked your son or your daughter
whether or not Jonathan, in fact, used 2146 East
Huntington as the address for the O'Boyle Law Firm?
A. Can you say that again?
Q. Did you ever ask your daughter or your son,
Jonathan, whether or not Jonathan ever practiced law out
of the address 2146 East Huntington Street,
Philadelphia, Pennsylvania?
A. Not that I can recall.
Q. And your son -- Paragraph 4 -- says that the
O'Boyle Law Firm PC, Inc., identified Jonathan R.
O'Boyle with an address of 2146 East Huntington Street,
Philadelphia, Pennsylvania as its president in its
filings with the Florida Department of State, Division
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of Corporations. No other officers are identified.
Did you check the filing to see if there are
any other officers identified?
A. I did not.
Q. Prior to going to the meeting June 4th, were
you aware that your son indicated that the address of
his law firm was 2146 East Huntington Street,
Philadelphia, Pennsylvania?
MR. DESOUZA: Objection to form.
THE WITNESS: No, I was not.
BY MR. SWEETAPPLE:
Q. You were not aware he was using that address?
A. No.
Q. Did you believe that your son had a law firm
somewhere prior to or -- strike that -- in November or
December of 2013?
A. Can you
Q. Did you
firm somewhere in
A. I don't
Q. Did he
somewhere?
say that again?
understand that your son had a law
November or December of 2013?
know.
aver tell you he had an office
A. I don't recall.
Q. Did you ever go to any opening of an office, a
party or anything for his office in
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November /December 2013?
A. Not that I recall.
Q. Did you ever get an announcement that he had
opened an office anywhere in November or December of
2013?
A. Not that I recall.
Q. Did you ever get a business card that showed
an address and phone number for an office anywhere in
Pennsylvania in 2013 --
MR. DESOUZA: Objection form.
BY MR. SWEETAPPLE:
Q. -- for the O'Boyle Law Firm from your son?
A. Not that I recall.
Q. Did you ever see any stationary that your son
had prepared with the address 2146 East Huntington
Street, as an address for the O'Boyle Law Firm, PC?
A. Not that I recall.
Q. And did your son ever tell you that he was
practicing law with any lawyers in Pennsylvania as part
of the O'Boyle Law Firm?
A. Not that I can recall.
Q. Are you aware of any lawyers that practiced
law with your son in Pennsylvania in 2013?
A. Not that I can recall.
Q. Did he ever tell you he had a secretary in
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Pennsylvania?
A. Not that I recall.
Q. Did he ever handle cases for you in
Pennsylvania or New Jersey in 2013?
A. I don't know.
Q. In Paragraph 5, I recited that, "However, as
of April 4, 2014, Pennsylvania has listed him as an
out -of- state - lawyer with an address at the home of his
father, Martin O'Boyle, at 23 North Hidden Harbor Drive
in Gulf Stream, Florida, and a telephone number with a
561 area code. Thus, as of April 4, 2014 the
Pennsylvania Supreme Court did not reflect that any
lawyer with the O'Boyle Law Firm actively practiced in
the state."
Did you do anything to determine whether or
not those allegations were correct?
A. I was unaware, and I don't have any knowledge.
Q. Were you aware that your son indicated on his
file with the Pennsylvania Bar that he was an
out -of -state lawyer and not practicing in the state of
Pennsylvania?
MR. SMITH:
THE WITNESS
MR. DESOUZA
MR. SMITH:
Object to form
Pardon?
Same.
Go ahead.
Argumentative.
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THE WITNESS: I was unaware. I did not look
at the bar or whatever he was.
BY MR. SWEETAPPLE:
Q. When you received this motion, did you look at
any of the exhibits that were attached to it?
A. Probably not.
Q. So you just got enraged and didn't look at the
backup?
MR. DESOUZA: Objection.
BY MR. SWEETAPPLE:
Q. Did you get mad when you saw this motion for
the first time?
A. No. I realized who prepared it. How can I
get mad?
Q. So you just -- you weren't at all concerned
about it?
A. That's not what I said.
Q. So you just dismissed it because of who wrote
it.
A. That's not what I said either.
Q. Well, let me say this. Did you know that your
son, while he was telling -- strike that.
Were you aware that your son advised the
Pennsylvania Bar his address was your home address, 23
North Hidden Harbor Drive?
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A. I have no knowledge.
Q. And were you aware that he provided the
Pennsylvania Bar with a Florida mobile telephone number
as his telephone contact?
A. No. But I think that's all right.
Q. Are you aware that the Florida Supreme Court
records as of April 4, 2014 did not reflect any lawyer
with the O'Boyle Law Firm actively practicing in the
state of Pennsylvania?
MR. DESOUZA: Florida records?
MR. SWEETAPPLE: Pennsylvania Supreme Court
records. Were you aware of that?
MR. SMITH: Object to form. Argumentative.
THE WITNESS: What's the -- what was it?
BY MR. SWEETAPPLE:
Q. Did you ever do anything to determine whether
or not the allegation in Paragraph 5, that as of April
4, 2014, the Pennsylvania Supreme Court did not reflect
that any lawyer with the O'Boyle Law Firm actively
practiced in the state?
Did you ever check to see as of April 4, 2014,
whether or not your son or any lawyer from the O'Boyle
Law Firm was registered with the Supreme Court as
activity practicing in Pennsylvania?
A. I did not -- did not check his -- no.
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Q. Are you aware that after April 4, your son
reflected with the Pennsylvania Supreme Court he
practiced in Cambria County, Pennsylvania with an
address of 1001 Broad Street, Johnstown, PA?
A. What is your question?
Q. Are you aware that as of May 29, 2014, well
after the articles for the Florida O'Boyle firm were
filed, that your son listed with the Pennsylvania
Supreme Court -- indicated he practices in Cambria
County, Pennsylvania. Were you aware of that?
A. I was not.
Q. Are you aware of any address of 1001 Broad
Street, Johnstown, PA?
A. I am.
Q. Do you have property there?
A. I do.
Q. Do you have an office there?
A. I do.
Q. Does your son have a -- does the O'Boyle Law
Firm have an office there?
A. I don't know what the name is there, but my
son has an office there.
Q. Is there any lease with the O'Boyle Law Firm
at that address?
A. Yes. My son and I have agreements between us,
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that are my son -- I don't need written agreements. I
trust him.
Q. So there is no written lease with the O'Boyle
Law Firm with regard to any space at that location?
A. Nor with my wife. I don't make her sign a
lease either.
Q. So who was your lease with? With Jonathan
O'Boyle?
A. We never discussed that.
Q. Well, it couldn't be with the corporation if
it's all for the rental of real estate.
A. Okay.
Q. How long is this lease for? How long are you
allowing him to stay there?
A. I told you, the details we never worked that
out. He is my son. It's my building. He is there, and
that's where we are, and let's move on.
Q. Does he have any residence in the vicinity of
Cambria County, Pennsylvania? Does he have an apartment
or a house that he resides in there?
A. I don't know.
Q. Does he work out of that location in
Johnstown, PA?
A. I don't know.
Q. You don't know?
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A. I don't know.
Q. You have never spoken to him about that?
A. I don't go over with him where he operates,
who he dates, what kind of car he drives. I don't do
that. You may do that with your daughter, but I don't
do it with my son.
Q. Okay. Well -- and so you don't know if he has
any residence within five hours even of Johnstown, PA
where he lives so he can practice law there, right?
A. He has no residence, to my knowledge, in the
world. So if that's helps you.
Q. Well, do you have any residential properties
in Pennsylvania that you have allowed him to live in?
A. No, but not very far away in West Virginia.
Q. How far in West Virginia?
A. How far?
Q. From the address in Cambria County.
A. I don't know. I don't know. Plus we had
property in Pittsburgh, so.
Q. Residential property?
A. Pardon?
Q. A house or residential property?
A. It can be used as a house, yes. 20 -miles away
from our house in West Virginia. I don't know how far
it is, but it's on the same identical road. Johnstown
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is just probably 30 -miles north west of Virginia.
But I don't ask Jonathan where he sleeps, what
he does. He does it on his own. And I don't think it's
any of your damn business where he sleeps.
Q. Well, it is my business whether or not he's
defrauding the courts of this state as member of a bar
where he's attempting to become a member of the bar.
It's very much my duty, sir. So have you given your son
permission to live in any abode in the vicinity of
Cambria County?
A. I'm not going to answer any questions about
where my son lives.
Q. Are you aware of whether or not your son has
resided at any point, has ever slept anywhere in the
vicinity of Cambria County during the year 2014 to date?
A. I'm not going to answer anymore questions
about where my son sleeps.
Q. And in Paragraph 7 we allege that as discussed
below, just two months after the O'Boyle Law Firm was
created as a Pennsylvania Professional Corporation in
November 2013, Jonathan R. O'Boyle moved to appear pro
hac vice in Florida state and federal cases. On
January 23, 2014, Jonathan R. O'Boyle filed a sworn
verified motion for admission to appear pro hac vice in
the case of Christopher F. O'Hare V Town of Gulf Stream
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and William H. Thrasher, Jr., and I list the case
pending before Meenu Sasser.
Did you do anything to determine if that
paragraph was correct?
A. I didn't know the paragraph existed.
Q. Well, didn't you read the motion that you said
was shit?
A. Yeah. But that paragraph was really shitty,
so I didn't want to read it.
Q. Paragraph 8 says that your son filed a sworn
verified motion in the case before Judge Sasser.
Did you look to see whether that was true or
not?
A. No.
Q. Do you believe there is anything untrue about
Paragraph 8?
A. No way I would know.
Q. You didn't look at Exhibit E?
A. I did not look at Exhibit E.
Q. Nine. "In said motion, Mr. O'Boyle swore in
Paragraph 2 that he is a member of the O'Boyle Law Firm
with offices at 2146 East Huntington Street,
Philadelphia, Pennsylvania."
Then it says, "This representation contradicts
both his Pennsylvania Supreme Court listing that he is
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either, (1) an out of state lawyer who can be reached at
his father's home in Florida; or (2), a lawyer
practicing at his 1001 Broad Street, Johnstown, PA; and
contradicts the O'Boyle Law Firm PC filing with the
Pennsylvania Department of State reflecting a business
address in Johnstown, not Philadelphia.
MR. SMITH: Object to form.
BY MR. SWEETAPPLE:
Q. Did you read Paragraph 9 to see whether or not
it was correct or incorrect?
A. I don't know whether I did or I didn't. But I
can't say it's correct.
Q. And you can't say it's incorrect?
A. Pardon?
Q. And you can't say it's incorrect either, can
you?
A. I could say that I'm not familiar with it. I
don't know.
Q. And you didn't look at Exhibits B, C or D when
you read the motion, right?
A. I did not look at your exhibits.
MR. DESOUZA: Bob, is there anyway to speed
this up instead of going paragraph by paragraph?
You want to put it in front him and say with
respect to paragraphs 1 through 35 of my motion,
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can you confirm any of these things are true?
MR. SWEETAPPLE: I don't think so,
unfortunately.
MR. DESOUZA: In that case I'm going to start
instructing him not to answer pretty soon. I can
see where this is going, and this is just not
fruitful. And you can take it up with the judge if
you want to, but I'd rather not be here until
8:00 o'clock.
MR. SWEETAPPLE: What time is it now, 5:30?
MR. DESOUZA: It is 5:30.
MR. SWEETAPPLE: So if you want to -- whenever
everybody wants to suspend, we'll suspend. I'm
going to be taking Mr. O'Boyle in at least a dozen
of his cases, and then there are a number of CAFI
cases, and some O'Hare cases that I'm going to be
deposing him in.
So there is no urgency in finishing this until
10:00 o'clock at night. I'll stay here until
midnight, or I'll suspend now. But before I
suspend, I do want to know Mr. O'Boyle's schedule,
because as I put on the record, Mr. Taylor stated
to Judge Blanc that Mr. O'Boyle was with his
grandchildren for two weeks. Mr. Smith was there.
And I, as an accommodation, agreed to today's date,
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September 15th, only to learn that Mr. O'Boyle has
been spending his time at city hall or town hall in
Gulf Stream rather than his grandchildren.
So Mr. O'Boyle, before I suspend the
deposition, what is your pleasure --
THE WITNESS: If I may respond to that?
MR. SWEETAPPLE: Sure.
MR. DESOUZA: You don't have to respond.
MR. SMITH: Don't.
MR. DESOUZA: There's not a question. You
don't need to respond.
MR. SWEETAPPLE: Can you --
MR. DESOUZA: Let's go over his schedule and
figure it out.
BY MR. SWEETAPPLE:
Q. Were you in New Jersey during the last two
weeks, Mr. O'Boyle?
A. I lose track of time. I was in New Jersey for
a week on a Wednesday, and then I came home on a
Wednesday night because our home flooded.
Q. And then you went to town hall for --
A. On Thursday I met with our engineer. We
resolved the problem. And I don't know if I went to
town hall on Friday, the following week. I don't know.
Q. You went with the videographer to film
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Mr. Thrasher's face.
A. That could be. But Nick has not represented
to -- Nick has represented nothing. I told him I was
gone for two weeks. My intentions were to go for two
weeks and, unfortunately, it didn't work out that way.
And I wish I would have been gone for two weeks. I
would have liked to spend more time up there.
Q. And what is your schedule for the rest of
September and October? Do you have any plans to be out
of the state?
A. Yes.
Q. What period of time do you plan on being out
of the state?
A. I'm going to likely leave tomorrow, and I'll
be back around the 23rd or 24th of October.
Q. You're going to be gone for approximately a
month?
A. Yeah.
Q. Where are you going to be?
A. In West Virginia.
Q. And it's your testimony you have no intention
of being here for a month?
A. That's correct.
Q. What is it you have to do in West Virginia for
a month? Because you have 12 cases here that we need to
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attend to, some of which you've asked for immediate
hearings in. So I'm going to have to compel the court
to have you appear at those cases.
A. That's fine. You do what you want.
Q. What is it you have to do in West Virginia for
a month that is more important than the cases that
you've demanded immediate hearings on?
A. I can answer you. My wife is up in New
Jersey, and I would like to spend some time with her
because we got cut off a week short.
My birthday is October the 12th, and every
year we go to West Virginia for my birthday. And we
usually get there a week in advance, because there has
to be preparation; buying food, you're buying -- so on
and so forth.
And then the following weekend is what they
call Bridge Day. It's where they -- if anybody has gone
whitewater rafting, the New River Bridge, they close it
and they jump off it. They base jump off it. And
that's the weekend after the weekend of the 12th. And
then after that, we'll clean up the house and come home.
Q. Well, you've filed a lawsuit against me and
Mr. Morgan. We need to take your deposition in that
case next week or the following week, so I'll be asking
the court to compel that as well as the cases where
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you've asked for expedited hearings.
You're telling me you're just going for
pleasure, and you have instituted considerable
litigation that needs to be dealt with. These
apparently are very important matters that you want to
maintain. And I cannot accommodate anymore of your
requests for vacations. You asked for two weeks. And
I'm sure that you have people that can take care of
leaks in your home. You didn't have to come home to
address leaks, but we can take that up with the various
judges, Mr. O'Boyle.
MR. DESOUZA: There's no question.
BY MR. SWEETAPPLE:
Q. You're telling me you're not going to be
here -- you're not going to be here until after
October 23rd. That's your testimony.
A. I think that's -- let's just think again.
What day is the 12th? Is it Friday or Saturday?
MS. O'CONNOR: Sunday.
THE WITNESS: Sunday? Okay. So that would
mean six days later is the 18th and then 19th,
20th, 21st, 22nd, 23rd. Yeah.
MR. SWEETAPPLE: But you will have time to fly
banners addressing myself and Mr. Morgan and police
chiefs and other people, right?
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THE WITNESS: Yeah, not only that, we'll
probably have circulars and we'll drop them out of
three states.
MR. SMITH: Marty, don't answer that.
MR. SWEETAPPLE: So you'll have time for that,
right?
MR. SMITH: Marty, don't answer it.
THE WITNESS: Don't be silly. Why don't you
be nice for a change?
MR. SWEETAPPLE: In terms of being silly, are
you the one who -- whenever it is you want to
suspend, just give me notice and I'll continue with
the questioning or suspend. Tell me what time you
want to go to.
MR. DESOUZA: Let's take a five minute break
and let's discuss it. We'll either suspend or go
for a little longer.
MR. SWEETAPPLE: I would like to go another 15
minutes to finish a couple of things up that I'm
'070 I
MR. DESOUZA: We'll take five and say --
THE VIDEOGRAPHER: The time is 5:38 p.m. We're
going off the record.
(At 5:38 p.m. a brief recess was taken.)
THE VIDEOGRAPHER: The time is 5:46 pm. We're
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on the record.
MR. SWEETAPPLE: Yes. During the break, all
counsel have agreed that we're going to suspend the
deposition at this time. There's no way we can get
through it all. And while I'm not agreeing to wait
until October 23rd, I'll take that up with the
court with regard to not only concluding this depo,
but taking other depos in the other cases.
MR. DESOUZA: Sure.
MR. SWEETAPPLE: Thank you very much.
MR. DESOUZA: Thank you, Bob.
MR. SWEETAPPLE: I will take a copy, and I'll
need the exhibits.
THE VIDEOGRAPHER: The time is 5:47. We're
going off the record.
(Discussion held off the record.)
MR. SWEETAPPLE: I will put on the record
whether or not he wants to read that portion,
because I am ordering it.
MR. DESOUZA: Let's go back on. I want him to
read. We will take a copy as well.
(At 5:47 p.m.: m. the deposition was
adjourned.)
(End of Volume II.)
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Page 300
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I, the undersigned authority, certify that the
aforementioned witness personally appeared before me and
was duly sworn.
Dated this 29th day of September, 2014.
Debra Duran - Bornstein, RPR, CLR
Notary Public - State of Florida
My Commission Expires: 8/20/15
My Commission No.: EE 112218
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 301
C E R T I F I C A T E
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I, Debra Duran - Bornstein, Registered
Professional Reporter and Notary Public in and for the
State of Florida at large, do hereby certify that I was
authorized to and did report said deposition in
stenotype; and that the foregoing pages are a true and
correct transcription of my shorthand notes of said
deposition.
I further certify that said deposition was
taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and
completed as hereinabove set out.
I further certify that I am not attorney or
counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
action.
The foregoing certification of this transcript
does not apply to any reproduction of the same by any
means unless under the direct control and /or direction
of the certifying reporter.
Dated this 29th day of September, 2014.
Debra Duran - Bornstein, RPR, CLR
Notary Public - State of Florida
My Commission Expires: 8/20/15
My Commission No.: EE 112218
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 302
September 30, 2014
NICK TAYLOR, ESQUIRE
THE O'BOYLE LAW FIRM, P.C., INC.
1286 West Newport Center Drive
Deerfield Beach, Florida 33442
In Re: Martin O'Boyle Vs. Town of Gulf Stream
Deposition of: Martin O'Boyle
The referenced transcript has been completed and
awaits reading and signing.
Please have your client review your copy of
the transcript at your convenience or if a copy was not
ordered, to call our office at the below - listed number
to schedule an appointment between the hours of 9:00
a.m. and 3:30 p.m., Monday through Friday to make an
appointment to come to our office and read the
deposition. If desired, your client may also opt to
waive signature. If so, please have your client sign
their name at the bottom and mail to our office to be
attached to the original transcript.
If the transcript is not reviewed and signed
within 30 days, the original, which has already been
sent to the ordering attorney, may be filed with the
Clerk of the Court.
Very truly yours,
Debra Duran & Associates
224 Datura Street, Suite 402
West Palm Beach, Florida 33401
PH: 561) 313 -8000
I hereby waive my signature:
MARTIN E. O'BOYLE
CC: All Counsel
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 303
C E R T I F I C A T E
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I hereby certify that I have read the
foregoing deposition by me given, and that the
statements contained herein are true and correct to the
best of my knowledge and belief, with the exception of
any corrections or notations made on the errata sheet,
if one was executed.
Dated this day of
2014.
MARTIN E. O'BOYLE
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 304
E R R A T A S H E E T
IN RE: O'BOYLE V TOWN OF GULF STREAM C.R. DD
DEPOSITION OF: MARTIN E. O'BOYLE
TAKEN: 9 -15 -2014
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
PAGE # LINE # CHANGE REASON
Please forward the original signed errata sheet to this
office so that copies may be distributed to all parties.
Under penalty of perjury, I declare that I have read my
deposition and that it is true and correct subject to
any changes in form or substance entered here.
DATE:
CY iVyil i 03*1601DO 0Am
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
$1,500 218:14
$1200 218:17
$3800 218:19
(1) 292:1
(2) 292:2
1
1 198:2 215:18
278:19 292:25
10 166:25 167:19
185:20
100 199:10
100 -page 209:18,
20,21
1001 278:10 287:4,
12 292:3
10:00 293:19
11 187:9
11:05 219:12
12 167:24 189:19
207:5 295:25
1280 176:13,17,25
181:14 188:18
192:10 196:23
1286 192:20 193:5,
14,17
12th 296:11,20
297:18
13 190:12
14 193:24 194:1,3,8
195:2 198:17
15 166:21 194:1,5,8
195:4 215:24
270:14 298:18
157 221:10243:11,
13
15th 294:1
16 207:3 214:8,9,
251:10 257:1
16th 214:8 215:24
217:3
17 167:20
17th 169:16
18th 297:21
19 217:12241:21,
23
19th 297:21
2 279:1,23,24
291:21
20 188:12,14,16
20 -miles 289:23
2011 184:25
2013 278:7 282:16,
19 283:1,5,9,23
284:4 290:21
2014 167:20
181:24 201:7
258:24 284:7,11
286:7,18,21287:6
290:15,23
20th 297:22
211 207:5
2146 279:6 280:8,
18 281:13,18,23
282:7 283:15
291:22
21st 297:22
22nd 197:8 297:22
23 176:15 284:9
285:24 290:23
23rd 295:15
297:16,22 299:6
24th 295:15
25 179:6 206:7,20,
23
25,000 166:21
26 214:15 218:21
27 218:1
27th 174:20 217:25
28 212:22 214:25
215:6
29 287:6
2:00 222:16
2:36 160:3
2nd 200:16201:7
3
3 201:20 252:12
279:22
30 -miles 290:1
33432 193:18
33483 176:16
34 277:14
35 292:25
4
4 201:20281:21
284:7,11286:7,18,
21287:1
4,000 252:12
4/28 206:6
4/28/2014 181:24
205:16
40 190:15,18
45 249:20 252:12
4:20 245:11,13
4:36 245:14
4th 237:12 238:15
240:22 242:4
245:18 282:5
5 284:6286:17
50 252:12
50,000 252:12
561 203:2 284:11
5:30 293:10,11
5:38 298:22,24
5:46 298:25
5:47 299:14,22
5th 197:2 251:13
6
6 167:1 199:6
257:21258:17,22
6/2 213:1
6/21/2006 176:12
6th 161:3 254:22
7
7 176:7180:16,20
290:18
8
8 180:11,12 291:10,
16
888 - 830 -3769
193:19
8:00 293:9
9
9 184:14 216:1
292:9
A
a.m. 219:12
abandoned
275:25
abode 290:9
abruptly 237:1
absolutely 162:7
214:5
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: $1,500—address
accept 270:24
274:15,17,19
accepted 274:20
access 200:20,23
201:5 215:19
accessed 200:25
accommodate
297:6
accommodation
293:25
accountant
178:17 189:16
accountant's
191:12
accountants
191:5,7,10,22
accountants'
191:14
accurate 198:25
accused 164:7
acknowledged
227:16,17,19
acquire 258:11
Acquisition
189:18,23
Act 167:23 218:11
action 266:16
actions 171:24
actively 168:2
186:15 192:2
284:13 286:8,19
activities 167:9
211:12 224:5
230:4 244:8
activity 223:24
229:11,12,14 264:4
286:24
actual 218:22
219:6 236:5
addition 262:25
address 175:6,7
176:17 181:1,5,7,
12 189:2 192:10
193:17 196:20
247:1278:10,11
279:4,5 280:7,8,20,
22 281:14,18,23
282:6,12 283:8,15,
16 284:8 285:24
287:4,12,24 289:17
292:6 297:10
addressing 29724
adjourned 299:23
administration
198:9
admission 290:24
admit 256:4
advance 250:24
296:13
adverse 276:23
277:13
advice 264:19,24
advise 224:10
advised 198:18
285:23
affiliate 263:19
affirmative
275:21
aforementioned
219:8
agencies 216:4
agent 175:25
176:14 187:16
190:19 193:13,25
259:1260:10,13,21
261:2,10
agree 170:8 210:5
236:7
agreed 171:9
210:6 293:25
299:3
agreeing 299:5
agreement
209:10,12,16,17
210:8,10 238:19
239:6 240:9,10,12
agreements 170:7
207:8,16 212:19
287:25 288:1
ahead 236:24
249:16 279:14
284:25
air 236:16
aircraft 177:12
airline 175:15
176:11 177:8
178:4 179:14
252:3
airport 183:7
akin 224:15
alga 270:17
allegation 286:17
allegations 278:4
279:24 284:16
allege 163:10
290:18
alleged 167:22
170:9 172:22
278:20
allegedly 179:7
235:4
alleges 161:11
198:23
alleging 172:23
269:16
allowed 232:2,5
289:13
allowing 288:14
alternative 275:15
ambiguous 223:8
amend 217:21
amended 275:21
Amendment
262:11263:4,5
264:14 266:8,15,17
267:3,9,10
amount 217:6
amounts 217:5
anger 254:24
255:9,11,14
animosity 235:23
announcement
283:3
annoyed 268:3
answering 174:24
175:2 196:25
204:7 207:11
217:24 218:3
219:18 268:19
answers 244:19
anymore 175:5
179:12 196:25
290:16 297:6
apartment 288:19
apparently
198:22 257:8
276:18 297:5
appeal 182:19,22
appears 171:22
202:4 258:3
apple 171:23
259:22 261:14
263:23
Apple's 266:21
272:10
application
260:24
appointed 179:7
approached
270:19
appropriately
275:19
approval 172:21
274:5,7
approve 160:16,
195:19 219:4,9
approved 171:11,
14 174:3
approximately
169:14,24 295:16
April 198:2,8,17
284:7,11286:7,17,
21287:1
area 254:15,19
284:11
areas 270:21
argued 219:24
argument 236:6
argumentative
204:8 205:14
206:25 207:24
219:21235:18,19
236:1284:22
286:13
argumentive
205:7
arranged 251:21
arrangement
218:24
articles 259:23
287:7
ashamed 235:17
assertion 231:18
assertions 279:19
Asset 190:9
assigning 198:18
assist 216:2
associate 265:1
267:14
associating
271:11
association
267:15
assume 194:9
assuming 242:5
assure 217:2
attached 285:5
attacked 225:19
226:1,15
attempting 290:7
attend 296:1
attorney 218:13
220:11221:5
235:23 259:2,3,4
264:24
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: addressing -awful
attorney's 165:17
attorney - client
197:13
attorney /business
179:4
attorneys 167:1
201:2
attorneys' 212:2
217:6 230:22
attractive 274:11
audits 216:3
Augmentive
235:10
August 161:2
authority 213:2
223:1239:2
authorize 219:3
Aviation 180:4,22
181:10
aware 160:21,25
161:3,6,13 162:12,
18,20 163:24
165:12,21 192:7
198:2,7,17 202:25
203:4,6,9 205:12,
16,20,23 206:9,22
207:3,7,15 208:6
212:22 213:1,5
219:17 253:15
282:6,12 283:22
284:18 285:23
2862,6,12 287:1,6,
10,12 290:13
Awareness 160:7,
25 161:8,20,24
162:9 163:12,15,
17,21 164:9 165:7,
16 166:12,24
167:1,10 168:7
169:8 170:16
171:17,20 172.2,5
193:16,25 196:19,
22 197:1,10,16
206:8 213:18
217:8
awful 252:13
B
B- o- e- c -k -e-r
233:16
back 160:4164:5,6
166:2,15 170:23
180:6 194:20,21
200:3 208:23
209:5,8 215:1
220:23 224:2
225:24 233:25
234:4 242:22
244:16 245:15
277:3 278:4
295:15 299:20
backup 285:8
bad 230:7243:6
268:5
bag 164:23200:6,
12 215:15
bank 206:10273:3
bankrupt 202:2
bankruptcy
206:11,14
banner 183:1
251:13,16,18,21
252:8 253:6,14,22,
25 254:9
banners 182:14,17
183:10,15 254:3
255:13 297:24
bar 231:19,20
284:19 285:2,24
286:3 290:6,7
base 296:19
based 224:22
249:24
basis 162:25
197:22,24 202:14
243:7
bathroom 274:9
Beach 182:18
187:24 193:18
224:17,19 225:1
253:15 267:6
279:4 280:7
bed 22922 230:1,3
256:7
begin 225:4258:12
behalf 170:2
172:16
beliefs 211:6
believed 217:3
beneficial 245:4
big 186:17,19
229:3
Bill 201:1217:13
222:25 238:6,8,23
240:1,25 241:1
242:22,23
billed 219:6
billings 252:17
bills 251:17 252:6,
9,11,15,24 253:10
254:15
birthday 296:11,
12
bit 242:23 263:25
271:19
bite 171:23
Blanc 293:23
board 174:21
198:10
Bob 171:19 208:2
216:13 228:1
233:9 236:4 245:2
256:10 277:17
292:22 299:11
Boecker 233:16,18
book 181:16
Boy 202:1
brain 225:5 236:21
brainchild 225:8
226:5 245:23
breach 238:22
239:6
breached 161:12
238:19,20,21
240:8,10
break 168:12
187:6 208:17
245:3,6 261:19,24
298:15 299:2
Breakers 253:20
254:1
breaking 262:1
Brenda 169:6
174:22 178:20,21
179:4 183:17,18,19
184:4 217:19
Brenda's 183:22,
24 184:1
Bridge 296:17,18
bring 160:10164:5
173:6,8 174:12
185:3 225:15
226:9,13 238:6
263:3 265:24
266:2
bringing 173:3
216:9 250:22
Broad 278:10
287:4,12 292:3
Brucker 267:7
brought 238:10
262:24
Broward 202:9,21
204:4
building 174:25
188:20,24 196:23
207:19 238:4,5
267:6 288:16
buildings 188:22
bully 173:13
bunch 164:4
business 189:8
190:18 192:15
203:1210:22
211:9 217:4
267:16 283:7
290:4, 292:5
businesses 193:2,7
267:15
businessman
211:2
Index: B- o- e- c- k- e- r- Chandler's
buyer's 243:18
buying 296:14
cabs 241:8
CAF] 172:18,20,
23 174:4,5,20,23,
25 175:3,8,9
178:22,23 1792,7
183:18,24 184:4,7,
9 186:6,7,8 191:22
192:19 193:9
198:10,24 199:3,9,
14 200:3 206:21
207:7,9,16 208:1,4,
8,10,13,18,20,23
209:15 210:7,8,22
211:9,13 212:8,19
213:7,9,22 214:16
215:3,216:9
217:13,14 2182,4
219:19 293:15
CAR'S 175:6
209:19 218:9
call 164:25 165:6,
8,9 167:12 200:9
203:7 204:11
215:17 218:25
243:5 248:19
272:10 296:17
called 164:22
165:1,4,23 166:2
200:8 202:9 204:3
215:14 220:1,21
227:7 235:14
243:11266:21
268:6 273:1,2,16,
18 276:22 278:6
Cambria 287:3,9
288:19 289:17
290:10,15
cancer 221:3
car 289:4
card 169:5, 283:7
care 181.•127747
297:8
carefully 255:19,
22 256:11
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
case 163:11
172:15,18 173:2
176:3 182:18,22
198:19 218:7,17,19
227:6 228:23
290:25 291:1,11
293:4 296:24
cases 197:9 198:5,
11200:4,24 201:1,
2,3 205:11206:7
207:5 208:10,14,18
212:23 213:2
215:8,9 220:15
227:6 228:18,20
235:5 246:15
248:11275:22
284:3 290:22
293:15,16 295:25
296:3,6,25 299:8
Cathleen 217:14
caused 161:21
cell 203:1,2,6
Center 176:14,17,
25 181:14 188:18
190:10 192:11,20
193:5,15,17 196:24
certifying 215:1
CG 189:18,23
chance 167:5
231:10
Chandler 160:18
161:1,9,11 162:5
164:3,11,23 165:4,
6,12 166:4,12
167:20 168:3,6,14
169:15,18,20,25
170:7,9,23 171:9
174:11,16,18 197:2
198:3,11,18,23
199:4,13 200:2,5,
17,18 201:6
205:10,17 206:1,
13,19 207:4 212:23
213:5,23 214:1,4,
16,25 215:12
2162,7,9 217:2,17,
25 219:13 241:22
Chandler's
162:20 167:25
172:20
change 193:12,23,
25 298:9
changed 169:22
170:23
character 195:19
256:18
charge 270:23
check 251:17
252:6,9,15,23
254:14 282:2
286:21,25
checked 222:25
checks 209:25
chiefs 297:25
child 225:5
children 227:22,
23 228:10,15
244:1,2 280:22
Christopher
290:25
chronicled 167:15
chronology 241:6
chucked 274:23
275:2
Circuit 161:2
circulars 298:2
Citizens 160:7,25
161:8,20,24 162:9
163:12,14,17,21
164:9 165:7,15
166:12,24 167:1,9
168:6 169:8
170:16 171:17,20
172:2,4 193:16,25
196:19,22 197:1,9,
16 206:8 213:18
217:8
city 202:2 221:18
294:2
claim 167:2 221:12
claims 161:12
168:15 173:3
221:14
clarity 199:6
clean 296:21
clear 216:13
222:22 223:9
227:2,9,15 229:1,
237:2 248:22
249:1262:2
277:25 278:1
client 224:12 256:7
clients 251:17
252:6,9,16,19,20,
21,23 253:3,10
254:14
close 296:18
closer 264:1
closings 205:7
clue 270:18
co- counsel 220:1
256:24
code 284:11
coinciding 167:25
collects 208:9
combination
262:8
Commerce 175:7,
10 176:18 181:1,4
187:8 188:9
191:24 192:5,14,17
217:15,19
commission 239:3
committed
206:10,14
common 209:13
210:12
communicated
168:3 220:20
communication
217:23 219:17
224:6
communications
165:13 167:14
170:3 214:6
223:25
companies 169:4
191:2,4
company 166:23
175:24 177:14
179:19,22 181:16
182:2 183:11,13
186:15,16,17,18
189:8,18,23 190:24
191:25 192:2
252:3 258:11,18,21
259:23 262:5,23
270:19 272:20,25
compel 296:2,25
complained
205:9,17,25 206:1
207:4
complaint 161:14,
15,18,21 166:25
232:19,21233:1,5
complaints
214:16,23 215:2
complies 266:16
compound 194:25
computer 215:20
concern 271:4
concerned 285:15
concerns 257:11
concluding 299:7
conclusion 262:12
condition 218:12
246:3 247:2
conditions 247:5
conduct 281:9
conducting 216:3
conference 242:21
243:3 248:19
256:8
confirm 219:10,14
293:1
confront 266:13
confused 224:25
conjunction
264:15
connection 161:25
279:12
consent 205:12,20
213:8
considerable
297:3
consideration
267:4
constitution
262:11264:2
contact 273:4
274:20 275:1
279:13 286:4
contacted 218:7
272:21273:15
context 228:13
234:18
continually
197:18
continue 298:12
CONTINUED
160:1
contractor 217:16
contractors
208:19
contradicts
291:24 292:4
contrary 256:15
contribution
210:3,19
control 175:1,4
210:16 252:11
262:22
conversation
218:6,15,23 219:14
220:8 235:2
conversations
171:8 216:14,23
261:5
converse 241:10
cooperation 279:4
copied 217:12
copies 180:14
270:3
copy 180:5194:10
200:16 257:7
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: change-create
268:1,6,7,14,18,25
270:8 299:12,21
corporate 178:14
181:13,16 189:3
192:12
corporation
180:23 189:24
197:17 273:2
279:5 280:6,7,11
288:10 290:20
corporations
176:11 193:14
279:2 280:5 282:1
correct 164:12
174:13,22 175:20
187:16 193:8,10,11
202:22,23 205:12
247:3 261:12
284:16 291:4
292:10,12 295:23
costs 165:17 212:2
218:17
counsel 171:11,14
198:3 220:5914
231:12 264:17
276:23 299:3
counterclaim
172:3,12 275:21
County 182:18
187:24 202:9,21
204:4 253:15
287:3,10 288:19
289:17 290:10,15
couple 227:13
230:17 298:19
court 231:3256:1
284:12 286:6,11,
18,23 287:2,9
291:25 296:2,25
299:7
Courthouse
182x8
courts 290:6
cover 180:15,18
Craft 270:14
crazy 234:20
create 218:21
253:5
created 278:7
290:20
credibility 240:15,
16,17,18
credit 169:5,6
criminal 235:14
CRO 180:4,22
181:10
cronies 268:4
crook 216:7,11,12
cross - examine
277:12
crossed 225:19
226:2,16,21,23
crowd 252:11
crying 229:22
230:1,4
current 189:7
cut 197:4296:10
D
daddy 229:3
damage 225:20
226:24
damn 290:4
data 200:23 215:20
date 164:20176:12
181:24 251:13
290:15 293:25
dates 289:4
daughter 244:3,5,
8 280:25 281:5,12,
16 289:5
daughter's
182:18,22 244:24
daughters 230:22
day 165:2 168:7,19
195:20 200:10
220:24 251:19
253:14 254:22
296:17 297:18
days 251:7 258:17
297:21
De 162:10,24
170:19 174:21
179:5 197:9 198:8
200:4,17 206:6,12,
23 207:4 212:22
214:12,15,25
215:11216:1
217:12 260:3,7
deal 185:2 191:516,
10 195:18 268:8
270:12 272:13
dealt 165:11
275:19 297:4
debate 256:9
debtor 208:20
December 161:3
282:16,19 283:4
decide 172:11
197:24, 255:25
256:6 274:15,17
decided 221:6
264:20 274:19
275:25
decision 258:11
Deerfield 193:17
267:6 279:4 280:7
defamation
232:18
defamatory 264:3
265:1
defame 267:14
defamed 232:12,
13,17,18,20
defendant 218:7,
21,25 219:2
defendant's 176:7
180:12 184:14
185:20 187:9
189:19 190:12
194:3,5 199:6
251:10
defendants 164:9
165:15
defense 275:21
defrauding 290:6
delayed 195:18
deleted 198:24
Delio 217:15
deliver 257:24
delivered 258:3,5,
6
demand 166:4
218:19,20 219:4,5,
8
demanded 164:11
206:6, 212:23
296:7
demands 219:10
250:4,8
denied 213:1
Denise 174:21
201:4 214:24
215:18
Department
176:10 192:8
278:9 279:2 280:4,
10 281:25 292:5
depends 215:13
depo 277:1299:7
depos 299:8
depose 277:13
deposing 293:17
deposition 172:6
269:13,14 270:6
276:20 294:5
296:23 299:4,22
describing 237:14
designated 174:21
designed 265:5
desire 168:1
239:25
DESOUZA
162:14,16 163:5
164:14 165:18
168:9 171:4,19
172:7 175:21
176:1 177:6
178:10 179:8
180:5,8,17 188:6
192:25 194:9,13,
17,24 196:17
197:11 198:13
199:1,5,8 201:19
202:12 204:6,17,25
205:3,6 207:20,23
208:2,15 212:11
213:10 216:13,18
220:4,7 221:21
228:1,7 232:9,14,
25 233:9 235:7,11,
19,25 236:3,5
240:2 241:9
244:15,19 245:3,10
250:5 253:11
254:17 255:3,21
256:10,22 257:3,6,
13,17,21261:3
262:16 264:6
266:22,24 270:10
271:24 272:16,18
273:9 275:17
276:4,10,18 277:3,
14,17,23 282:9
283:10 284:24
285:9 286:10
292:22 293:4,11
294:8,10,13 297:12
298:15,21299:9,
11,20
detail 209:18
detailed 255:22
256:11
details 255:19
288:15
detective 244:5
determine 279:23
284:15 286:16
291:3
determined 171:2
developed 274:6
developer 273:12
difficulty 195:18
digress 242:19
dinner 242:20
dire 218:11
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: created - dismissed
direct 170:22
196:14 213:20
254:2 258:21
directed 185:25
219:7
directly 196:5
222:19,23 223:16
241:18 267:13
director 178:23
183:18 184:4
187:18,21 190:20
206:21
directors 178:22,
24
dirty 184:17
187:23 188:5
252:18 271:9,12,16
discharge 276:9
discovery 171:24
172:10,24 173:15
discretion 221:11
discriminate
249:10 264:8
272:3
discriminated
249:22
discrimination
249:12
discuss 248:7
265:14 298:16
discussed 174:11
218:7 260:25
261:6 288:9
290:18
discussion 220:25
223:23 236:14
241:7 256:6
299:16
discussions
169:14,17,24
219:1,3 224:4,23
230:18
dismiss 254:25
dismissed 221:12,
13 285:18
dispute 225:16
226:9,13 279:19
disqualified 276:2
disqualify 219:24
245:8 275:14
disqualifying
254:25
disseminate 201:5
disseminated
269:17,20,23
271:15,17
district 167:22
Division 176:11
279:2 280:5,11
281:25
document 190:22
201:16 210:2
269:6
documentation
215:23
documents 178:9
188:4 198:20
21722 278:15
dollars 229:7,8
274:3 275:1
door 193:6
dozen 293:14
DPT 187:20192:7
drafted 205:11
221:6
drafting 205:18
drink 253:23
254:9,23
drive 176:14,15,
17,25 181:15
188:19 190:10
192:11,20 193:5,
15,17 196:24
253:23 254:9,23
284:9 285:25
driver's 203:16
drives 289:4
drop 298:2
dropping 225:4
ducks 173:8
DUI 244:25
DUIS 244:13
duties 171:11
duty 161:12290:8
DX15 194:14
E
e -mail 164:11,23
165:22 166:5,8
167:12 200:15
201:13 213:16
218:5 219:11,13
223:6 241:21
271:2
e- mailed 270:14
e -mails 163:20,24
164:1,2 198:24
216:15,19,20,21,22
273:21
earlier 200:6
232:12
earned 164:10
earning 209:2
East 279:6280:8,
18 281:13,18,23
282:7 283:15
291:22
editorializing
276:14,18
educate 161:25
Educating 186:22
effective 164:24
effort 271:9
efforts 263:20
264:21
electronic 216:3
electronically
258:6
Elmore 238:11,24
240:14
employ 241:18
employed 241:13
employee 217:15,
19 218:2
employment
168:4 170:13
encountered
171:10
encourage 266:19
encrypt 215:22
end 234:22 236:13,
22 262:1299:24
ended 237:1
261:21
ends 197:18
engage 204:17
engaged 189:8
190:5 244:8,9
engagement
207:16 212:19
engages 210:22
engaging 204:21
engineer 294:22
Enhancement
190:9
enraged 285:7
entered 169:15,25
entire 198:10
entities 181:12
184:1 196:7,8,13
208:19 209:14
241:18
entitled 172:7
212:9 256:3
271:10
entity 160:14,17
163:13 168:6,14
170:17,20 171:3
174:12 175:1,3,15,
17 176:21,22,25
177:5 178:7,16
181:6 182:12
184:18 185:1,8
186:2,9,11 187:2
190:11,14 196:23
208:7,10,12 210:16
212:15 267:16
enumerated
276:7
enumeration
212:5
estate 273:12,13
288:11
ethical 256:17
ethics 279:11
event 243:24
246:23 247:16
evidence 245:9
evidentiary
275:16
excerpts 256:13
exchanged 164:2
Excuse 172:12
223:7 263:2
exercise 217:4
exhibit 167:1
176:5,180:7,12
184:14 185:20
187:9 189:19
190:12 194:3,5
199:6 251:10
257:1291:18,19
exhibits 180:9
193:21285:5
292:19,21299:13
existed 291:5
existence 184:25
188:14 216:22
exists 160:10
expect 208:23
244:9 268:20,22,24
expectation 211:9
expected 249:9
expedited 297:1
expenses 169:1
218:22 219:6
experience 167:25
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: dispute - family
277:15
expert 215:21
explain 230:16
explained 218:11
243:6
expressed 218:8,
23
expressions
243:19
extensive 167:25
extent 162:2
182:25 212:13
224:10 235:2
extra 257:6
eyes 247:16
F
F -1 191:18
face 221:4 262:25
295:1
facetious 276:15
facial 243:19
facilities 274:10
fact 162:21,23
163:9 165:11
166:4 174:16,17
205:5,9 224:22
238:6 258:17
261:1270:8
279:17 281:13
facts 172:4221:18
278:20,24
factual 243:7
failure 218:9
false 279:25
280:15
familiar 180:4
184:18,20 191:25
248:8 292:17
family 225:15,19
226:2,9,13,16,18,
19
fantasy 237:17,19
father 284:9
father's 292:2
fax 213:16 258:6
faxed 258:9
February 167:20
169:16 197:2
federal 231:3,21
256:24 290:22
fee 207:8,15212:18
feed 235:5
feel 173:9270:15
fees 164:10165:17
212:2 217:6
218:17,22 219:6
fellow 195:16
felt 225:14,15
226:8,12
fiduciary 161:12
figure 247:22
269:15 294:14
file 243:10 284:19
filed 161:1,4,6,21
163:9 167:20
170:15 171:18
176:12 181:24
185:9,11,14,15
187:23 200:4
201:25 205:11
206:24 212:14
213:21215:2
225:5 233:23
243:20 257:10
259:22 260:19
275:23 287:8
290:23 291:10
296:22
files 189:6,10
200:20
filing 172:22
173:14 181:22
185:5 186:21
201:18 211:19,25
280:11,12 282:2
292:4
filings 281:25
filled 162:3
film 294:25
financial 218:12
financially 267:19
find 172:10 209:4
233:6 263:5 268:7
275:3, 277:4
fine 198:1205:7
296:4
finish 298:19
finishing 293:18
fire 238:11,23
240:8,9
fired 238:7,9,16
239:9,10,11,14
240:1,5,13
(ring 240:11
firm 160:23162:12
163:2 164:10
173:20 174:4,13
192:20,23 193:14
195:8,25 196:2,13,
20 197:3,10 198:11
202:10 203:24
204.2,4 206:8,24
207:8,17 208:9
211:20,22 212:20,
24 213:2,217:3
218:16 219:6,16,
24,25 222:20,25
223:1,14 225:12
228:24 229:1
235:4, 240:22
241:1,2,4,14,23
242:1,3 251:4
255:1267:5
275:15 276:1
278:6,7 279:3
280:5,12 281:14,22
282:7,14,19
283:12,16,20
284:13 286:8,19,23
287:7,20,23 288:4
290:19 291:21
292:4
firms 221:17
fistfight 234:15
Flack 217:15
Flapping 198:21
floating 257:9,11
flooded 294:20
Florida 167:21
171:18 176:10,16
193:18 198:4,18
200:14 204:4,5,24
205:18 264:22
265:2 273:12
279:1,5 280:4,7,11
281:25 284:10
286:3,6,10 287:7
290:22 292:2
flow 197:4
flown 182:17
251:14,16,18
253:6,14 255:13
fly 183:10 253:22
254:3,6,19 297:23
Flynn 191:15,17
focus 263:25
food 296:14
foreign 279:3
280:6
forget 165:3
195:17
forgot 214:3
form 162:14,15
163:3 164:13,14
165:18,19 168:9
171:4 176:1
178:10 179:8
188:6 192:25
194:24 196:17
197:5,11 198:13
202:12 204:6
207:24 208:15
213:10 221:21
253:11254:17
255:2 258:11,18,21
264:6 270:10
276:24 277:2,4,6
282:9 283:10
284:22 286:13
292:7
formal 178:9
246:6,9,12
format 201:4
formed 160:14
168:7 169:9
179:14 185:24
186:1,2,6,7,8
187:12 188:11,12
190:7 262:23
forming 174:11
forms 189:4,6
Fort 203:21
forthwith 258:13
fortune 239:14
forwarded 206:8
Foster 249:9
251:17 252:5,9,16,
20 253:3,9 254:14,
24
Foster's 252:11
found 216:12
foundation 160:8
161:1,8,21,24
162:9 163:12,18
165:7,16 166:13
167:2,10 168:7
169:8 170:12,16
171:12,15,18,21
172:2,5 193:16,25
196:19,22 197:16
206:9 211:13
213:18 217:9
235:5
fraud 206:10,11,14
free 171:23184:5
210:17 217:4
Friday 294:24
297:18
friend 217:16
friends 273:5,6,7
front 160:22
257:17 267:6
292:24
fruitful 293:7
full 215:15221:8
233:24
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: fantasy -give
full -time 162:25
202:20,22 203:20
fully 173:18
fund 196:2,4,8,13
197:10
funded 208:4
funder 207:17,18,
25
funding 163:13
212:14 235:6
funds 168:23
208:7
funny 261:21,23
262:10, 263:24
265:25 266:1
future 223:24
224:5,24
G
gain 200:20
games 207:13
garbage 246:17
gave 176:18
180:20 221:10
223:1,14 240:24
251:8
general 245:20
generally 209:11
245:25 254:4
generate 162:11
163:1
generated 207:5
gentleman 173:7
geographic
254:15,19
George 238:11,24
240:14
Giovani 205:9,17,
22
girl 230:24
give 162:11167:5,
16 180:15 208:10,
14 211:25 215:19
234:18 254:15
264:17 267:3
298:12
giving 210:13,15
232:4 256:21
276:25
glad 201:25 231:12
246:20
global 242:11
247:9
goal 240:5 250:9
goals 239:12,13
good 184:13189:7
221:24 222:4
223:10 252:13,14
272:13
Gordon 270:14,15
governance
181:14 189:3
192:12
government
168:1 171:10
184:17 185:2
187:23 188:5
governmental
208:19
GP 187:8 188:9
189:24
grandchildren
293:24 294:3
great 195:18 202:2
245:10 272:18
Group 175:7,10
176:18 181:2,4
187:8 188:9
191:24 192:5,14,17
guess 166:23
184:10 204:11
210:7 214:3 273:5
guessing 243:24
Gulf 172:17
176:15 213:7,8,17,
21236:11237:3,23
257:9,12,25
258:11,19 263:21
264:5,8,13,22
265:2 270:17,20,21
271:5 284:10
290:25 294:3
guy 168:25169:3
171:24 268:5
guys 266:10
Lit
hac 290:22,24
hall 294:2,21,24
hamburger
259:11
hand 230:6 258:5
handicap 249:10
handicapped
237:2 249:5,22,25
264:9 272:3 274:9
handle 178:15
198:19 284:3
handled 198:4
handles 178:16
183:15 189:3
hands 234:16,25
235:1
handsome 270:23
274:1
happened 164:18
173:2 243:22
247:14 248:15
249:18 251:1
happy 279:15,20
harassing 204:8,
19
Harbor 176:15
284:9 285:25
hard 241:9
hatred 235:23
He'll 201:17
hear 201:24
heard 206:4
248:16,17,19
276:24
hearing 275:16
hearings 296:2,7
297:1
heck 238:13
held 164:10 241:7
299:16
hell 272:4
helpful 200:22
helps 289:11
Hidden 176:15
284:9 285:25
hierarchy 271:7
high 252:13 263:11
high -end 273:13
highly 261:16
Highway 175:16
176:11 177:8
178:5 179:14
hint 271:21
hire 182:15,19
183:2 215:20
229:23 230:2,9
236:20
hired 168:8182:24
183:1,8
hiring 183:4 216:2
hold 200:11220:4
228:1234:16
235:25 257:3
home 174:17,18
202:22 284:8
285:24 292:2
294:19,20 296:21
297:9
honorable 202:17
hoping 186:16
horse 263:11
host 207:23
hotel 168:20,21
169:6
hour 249:20
hours 276:19,25
2772,5 289:8
house 236:24
249:14,15,24
250:10 251:3,6
259:9,16 262:5
264:12,13,22 265:1
270:17 271:20,23
272:7,11,22 288:20
289:22,23,24
296:21
houses 236:12
237:24 250:13
258:11,12,19,22
259:5,22 261:15,17
263:20,23 264:21
270:20 271:6,12
human 235:1
hundreds 167:20
235:5
Huntington 279:6
280:8,18 281:14,
18,23 282:7 283:15
291:22
hurt 234:22263:16
husband's 233:19
I
idea 171:7178:1
183:3 190:15
202:23 203:25
210:9 211:24
212:21214:17
221:20 222:4
230:7 234:11
260:8
identical 289:25
identification
176:8 180:13
184:15 185:21
187:10 189:20
190:13 194:4,6
251:11
identified 281:22
282:1,3
II 299:24
imagine 198:14
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: giving- insisted
immediately
164:24 215:16
240:19 255:18
immigration
195:21
implementation
258:13
implication 253:2
implicitly 253:9
implying 252:16
important 296:6
297:5
impregnated
204:13
impressed 187:7
impression 253:6
improperly
269:17,18
in -house 191:7
including 164:8
167:15,21220:25
income 160:8
189:12
incorporated
174:20 190:15
incorrect 292:10,
13,15
incurred 165:16
217:7
indirectly 251:22,
23 267:14
individual 187:13
270:7
individuals
163:21
indulge 173:24
infancy 186:17
information
215:19 275:2,6,11
inquiries 279:12
insist 197:9
insisted 162:10
insistence 165:14
Installation
253:19
instituted 297:3
instructed 218:13,
18
instructing 205:3
293:5
Instructions
162:23,24 277:18
Intend 217:13
253:5 258:12
intended 162:21
intending 186:18
Intent 210:25
intention 270:16
271:6 295:21
intentions 295:4
inter 270:17
Interest 176:24
182:13,15,20
interpretation
253:2
interruption
173:21243:12
interstate 219:25
Intimidate 173:13
250:3,7
intimidation
272:23
investigate
278:14,16,20 279:8
investigators
229:24 230:2,5,9,
13
Invite 266:15
Involve 173:19
involved 160:13
165:7 167:9
170:17,19 175:16
181:13 192:3
195:24 221:17
228:15 234:20
235:3,9 244:1,2
267:16
involvement
161:17 167:2
175:22 267:18
involving 165:14
issue 162:3 229:8
247:9 264:25
Issued 186:9
issues 266:13
J
January 168:18
174:10,20 290:23
Jersey 203:11,14,
16 273:3 284:4
294:16,18 296:9
JF 253:22 254:9,23
Joan 238:24239:1
Joanne 220:2
225:5 243:17
257:13
Joel 161:1,9
164:22 200:8,17,18
215:7,15,19 217:17
Joel's 167:12
John 238:10
Johnstown 278:11
287:4,13 288:23
289:8,25 292:3,6
join 241:4
Jonathan 195:22,
23 205:10,18
218:19 219:8
238:12 281:7,9,13,
17,22 288:7 290:2,
21,23
Jones 249:9
251:17 252:5,9,11,
16,19 253:2,9
254:14,24
Jr 259:2 291:1
judge 197:25
231:8,14,21256:6,
18 291:11293:7,23
judges 256:25
297:11
judgment 217:4
judicial 161:2
167:22
July 200:16201:7
jump 296:19
June 164:21
170:24 200:6,24
213:5,25 215:14
216:1,10 217:3,12,
25 218:1237:12
238:15 240:22
241:21,23 242:4
245:18 251:13
254:22 257:21
258:17,22 270:14
282:5
junk 227:21
jury 253:8
L1
Kevin 279:10
kid 239:23
kids 234:19,20
kind 202:18 219:5
242:11289:4
knew 211:19
215:4,10 216:11
221:2,3 267:15
276:12
knock 262:9,14,20
263:8,11,13,24
knowledge 172:20
175:12 185:17
196:21 197:17
205:12,19 209:13
210:12 213:8,19,22
216:14 223:3
241:15,17 273:13
284:17 286:1
289:10
Kraft's 271:18
L
Ladony 238:12,24
240:16
lady 189:3
land 274:5
landscaper
236:15,18,20 249:6
250:25
landscapers
236:17
language 218:1
252:5
lap 239:22
Larmartini
162:10 170:19
174:22 179:5
197:9 198:8 200:4,
17 206:6,23 207:4
212:22 214:12,15,
25 215:11216:1
217:12 260:3,7
Larmartini's
162:24 206:12
lasted 249:20
late 165:2
Lauderdale
203:21
law 160:23162:12
163:2 173:19
174:4,13 192:20,23
193:10,14 195:8,24
196:2,13,20 197:3,
10 198:9,11 200:19
202:8,9,10,21
203:24 204:2,4,22
206:8,24 207:8,17
208:9 211:20,22
212:20,23 213:3
214:22 217:3
218:16 219:6,16,25
221:14,17 222:20,
25 223:1,14 224:12
228:24 232:1,3,10
235:4 240:21
241:1,2,4,13 242:1,
3 244:11,12 251:4
255:1267:5 269:6
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: insistence -leaks
275:15,20 276:1,9
278:7 279:3 280:5,
12 281:9,14,17,22
282:7,14,18
283:12,16,19,20,23
284:13 286:8,19,23
287:19,23 288:4
289:9 290:19
291:21292:4
lawful 219:25
laws 167:23 244:10
lawsuit 161.1,3,6,7
163:9 167:19
170:15 171:22
174:2 175:16
187:24,25 198:22,
23 199:1201:18,19
257:10 270:12
296:22
lawsuits 162:11
163:1 164:9
165:15 167:21
168:15 171:17
185:15,16 186:21
201:22 205:18
206:23 211:20,23
213:20,21245:25
247:23 275:22
lawyer 186:3
195:15 204:5
205:25 214:19,21
228:24 243:9
244:4 249:9 255:4
259:9 264:19
279:11284:13,20
286:7,19,22 292:1,
2
lawyers 173:9,11
196:15 267:7
283:19,22
lawyers' 196:4
laying 209:18
layout 263:22
lead 255:10 270:22
277:16
leading 276:22
277:8
leaks 297:9,10
learn 173:1271:18
277:22 294:1
learned 213:6
221:18
lease 189:1287:23
288:3,6,7,13
leased 193:4
leases 192:20
193:2
leave 180:5,7
238:4,5 249:8,16
259:19 295:14
leaving 240:19
left 164:23 195:8
200:6 215:15,16
legal 171:11,14
174:3 178:9 198:3
212:11217:4
262:12 264:19
267:2
legitimate 162:8
lengthy 169:13,17,
23
letter 180:16,19
200:6 215:16,24
251:9 257:1,4,11,
13,16,24 258:14,16
267:24 268:3,9,18,
20 269:9,16,20
270:8 271:12,15,18
279:15,19
letters 207:16
212:19
letting 207:13
Lexus -nexus
233:15
Liability 259:23
license 202:10
203:16 214:22
228:21
lie 231:7,17232:2
271:8
lied 163:8231:3,
14,20,25 256:24
lies 221:8
likes 179:25
Limited 259:22
lips 198:21
list 198-10278-9
291:1
listed 175:6192:7
202:25 261:12
284:7 287:8
listen 277:22 278:2
listened 256:23
listing 291:25
lists 279:5 280:8
litigate 173:18
litigating 162:3
litigation 160:11,
22 186:13 197:3
223:24 224:5,24
247:20 248:21
297:4
live 168:24 289:13
290:9
lives 289:9 290:12
living 202:22
LLC 175:16
176:12 177:8,9
178:2,5 179:14,22
184:17 185:19,23
187:2 259:22
261:15
loan 210:2,4,5,20,
21,25 211:1
loaning 167:10,11
loans 196:14
209:24
local 216:3
located 176:18
191:20 193:9
196:20,22 207:18
location 281:10
288:4,22
long 173:16,17
245:7 250:9
288:13
longer 207:9 214:7
298:17
looked 243:18
lose 294:18
losing 263:1
lot 182:16229:10,
12,14
love 239:10
Lucky 167:7
M
M- o- h -1 -e -r
213:14
mad 271:22272:1
285:11,14
made 162:2165:12
166:4,7 189:4
203:7 205:21
206:19,21210:8
219:15 229:1
231:18 237:2
239:25 242:9
246:7,9,12 248:20,
22 258:10 259:18
272:23 277:1,6
279:12,19
maiden 233:12,14,
19
mail 189:5
mailing 278:11
279:5 280:8
main 192:14
247:16
maintain 297:6
make 162:1 168:15
180:8 193:23
211:16 214:22
217:14 219:8
223:9 229:25
230:21244:15
245:18 246:1
248:9 250:3,7
262:2 263:25
288:5
makes 260:24
making 196:14
204:19 213:6
276:20 277:9
man 202:17 234:15
manage 191:3
manager 175:24
176:13 177:14,16,
17,20,22, 184:24
261:12 272:4
manages 191:3
managing 178:2,3
186:15
March 197:8
198:7
mark 176:5
180:10,11 185:19
189:22 192:17
193:20 251:9
marked 176:7
180:12 184:14
185:20 187:9
189:19 190:12
194:3,5 251:10
marriage 233:20
Martin 169:18
171:19 176:13
177:21222:23
264:13 284:9
Marty 204:16,18
229:23 230:2
236:3 238:12
256:22 298:4,7
Matt 195:17
matter 218:13
matters 173:19
297:5
mayor 271:7272:4
meandered
248:25
meaning 243:10
meant 230:15
Meenu 291:2
meet 247:2,5
meeting 220:1,22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: learn-mind
222:1,4,8 225:23
228:6 237:1,9,10,
11,21238:5,10,15
240:7,19,22 241:25
242:4,10,14,25
243:2 245:17
248:2,23 249:16,
19,23 250:2,13
251:8 253:20
255:19,25 256:2,4
258:17 259:5,10,13
282:5
meetings 181:17
198:9
member 178:2,3,6
217:20 231:18,20
241:2 242:1,3
290:6,7 291:21
members 224:12
memo 221:11
228:5,6 234:10
255:20,21
memorandum
169:15,21,25 222:7
memorialize
218:5
memorize 201:10
mention 225:1
mentioned 273:11
Mesa 205:9,17,25
Mesa's 205:11,12,
19
met 174:10294:22
MGRM 177:23
Michelle 183:5
middle 214:2
Middlebrooks
231:8,15
midnight 293:20
migrate 247:13
million 274:3
275:1
millions 229:7,8
mind 221:23
248:1,3,10,12
252:18 265:6,22
mine 202:5,6
minimum 206:7
minute 182:5
187:6 242:16
298:15
minutes 181:17
249:20 298:19
mission 160:16
Misstates 262:16
mistake 214:22
mister 163:10,25
203:10 234:7
259:21
mobile 286:3
model 209:19
Mohler 213:14,16
moment 208:21
263:2 265:4
moments 200:9
money 164:5
165:16 166:17,18,
20 167:10,11 197:4
208:9,10,13,20,24
209:1,2 210:13,15
211:16 212:10
270:25 272:21
moneymaking
190:5
month 200:24
252:12 295:17,22,
25 296:6
months 181:25
201:20,23 251:5
290:19
Morgan 230:24
237:7 239:20
296:23 297:24
morning 218:6,15
229:22 230:2
motion 219:23
221:6,8 225:4
227:7,10,11243:6,
21245:7,8,23
246:3,16 247:12,
17,20 248:4,6,25
249:2 254:25
260:19,23 275:14,
17,24 276:5,6,11,
16 278:14,19
279:25 280:1
285:4,11290:24
291:6,11,292:20,
25
motivation 255:11
move 232:10235:3
248:14 267:21,22
288:17
moved 290:21
multiple 267:20
names 170:22
191:9,14 262:23
265:5
nature 194:25
neared 236:22
necessarily 185:7
216:17
needed 169:5
223:13 230:9
266:4
negotiations
223:19,23 224:4,
11,23
neighbors 271:22
272:1,2
Newport 176:13,
17,25 181:14
188:18 192:10,20
193:5,15,17 196:24
nice 173:5 298:9
Nick 217:25 218:1,
5 295:2,3
night 165:2,4
200:10 229:22
230:1,3 242:20
293:19 294:20
nonsense 204:9
normal 252:19
north 176:15
284:9 285:25
290:1
not- far - profit
168:14 211:13
notch 185:3 262:9,
15,20 263:3,9,11,
14,265:24 266:2,4,
10
note 209:18,20,21,
22,24
notes 222:10,14
notice 275:3
298:12
November 278:7
282:15,19 283:4
290:21
November/
december 283:1
number 203:1,2
274:21283:8
284:10 286:3
293:15
numerous 279:18
M
O'boyle 160:7
162:18 165:11
169:18,19 171:20
172:13,21 173:12,
16 174:4,176:13,
15 177:18,21
180:22 182:2
187:12 189:23
193:14 195:8
196:13 197:3,10,21
198:11 199:20,24
202:4,9,21,22
203:24 204:2,4,12
205:10,18 206:8,
16,24 207:8,13,17
208:4 212:23
217:3 218:16,19
219:6,9,16,24
222:20,24,25
223:1,14 229:4,6
233:4,25 235:17
237:21238:12
240:21241:1,13
242:1,3 244:18,21
257:9,16 265:7
268:5 271:11
272:14,25 275:15
276:17 278:5,7
279:3,21280:5,12
281:14,22,23
283:12,16,20
284:9,13 286:8,19,
22 287:7,19,23
288:3,8 290:19,21,
23 291:20,21292:4
293:14,23 294:1,4,
17 297:11
O'boyle's 201:24
256:16,18 264:14
293:21
O'conner 231:1
247:7
O'connor 180:15,
20 220:2,20,22
221:11222:3,17
227:9 233:11,17,
18,22 236:10 238:2
248:18 257:14
258:18 269:25
270:1297:19
O'connor's 228:5
O'hare 290:25
293:16
oath 167:8
object 162:15
163:3 164:13
194:24 197:5,11
198:13 204:6
219:20 221:21
254:17 255:2
284:22 286:13
292:7
objection 162:13,
14 163:5 164:14,15
165:18 168:9
171:4 176:1 177:6
178:10 179:8
188:6 192:25
196:17 202:12
204:25 205:1,2,14
206:25 207:20,21,
22,23 208:15
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: mine -office
213:10 223:7,10
235:7,10,11,18,19,
25 245:2,3 250:5
253:11262:16
264:6 266:22,24
270:10 271:24
276:25 277:2,4
282:9 283:10
285:9
objectionable
261:17
objections 218:24
277:7,9
obligated 276:8
obligation 209:8
270:15
obligations 209:7
218:10 276:9
obtain 264:24
obtained 267:25
occupied 188:18
occupies 188:20
occupying 175:10
occur 223:2
230:16 244:10
occurred 205:20
206:1245:18
October 295:9,15
296:11297:16
299:6
offensive 264:4
offer 218:13 242:9
246:6,9,12,14
270:24 274:1,2,11
offered 198:3
270:23 272:21
274:25
offers 219:15
office 186:4
193:10,13,24 198:9
200:19 202:9,21
204:3 206:1
239:16,19 258:3,4
259:19 278:10
282:21,24,25
283:4,8 287:17,20,
22
officers 171:2
282:1,3
officership 182:14
offices 193:6
203:21291:22
one -copy 257:3
open 171:10251:3
259:5,8,11,16
266:20 271:6,12,23
272:7,21
opened 202:21
204:3 251:5 283:4
opening 250:12
258:19 282:24
operates 289:3
opinion 230:6
232:1,3,4,10 267:2
opposed 210:2
opposing 173:11
220:5 277:11
orally 214:13
order 169:5
175:14 263:13,16
269:5
ordering 299:19
organization
218:12
organizational
217:22
originally 278:6
out -of -state
284:20
out-of-state -
lawyer 284:8
overbilling 253:3
owned 174:25
182:9
ownership 176:24
182:20
owns 176:21,22,25
177:5 196:23
P
p.m. 160:3 245:11,
13,14 298:22,24
299:22
PA 287:4,13
288:23 289:8
292:3
Palm 182:17
187:24 224:16,19
225:1253:15
paragraph 166:25
167:19,24 278:19,
20 279:1,9,24
281:21284:6
286:17 290:18
291:4,5,8,10,16,21
292:9,23
paragraphs
292:25
paralegal 206:20
Pardon 190:2
196:10 208:25
210:14 239:17
284:23 289:21
292:14
part 161:23164:20
172:3 200:6 214:3
215:14 221:12
246:5 275:22
283:19
participate
204:23 240:22
parties 210:4,6
276:24
partner 179:4
195:16 241:23
party 171:25
277:11,13 282:25
passed 239:23
past 201:20
pay 168:25169:5
183:24 184:1
196:4 208:23
209:5,8 270:23
paying 175:3
payment 219:4
payments 196:14
219:5
pays 183:22
PC 279:3 280:5,12
281:22 283:16
292:4
pending 194:19
246:25 291:2
Pennsylvania
203:1235:4 278:9,
I 1 279:7 280:9,
281:19,24 282:8
283:9,19,23 284:1,
4,7,12,19,21
285:24 286:3,9,11,
18,24 287:2,3,8,10
288:19 289:13
290:20 291:23,25
292:5
people 161:25
170:22 173:12
179:7 216:15
237:2,12,22 242:6
246:21249:5,6,10,
22,25 252:13,14
256:17 262:14,20
263:10,25 264:8,9
267:14,25 268:5
269:23 271:5,17
272:3 273:21,22
297:8,25
people's 262:25
period 168:17
169:14,213:24
215:13 295:12
permanent 276:3
permission
213:22 222:19,24
223:15 240:21,24
260:15 290:9
permitted 277:12,
24
person 183:5
186:2,6 274:21,25
personal 198:4
personally 168:5
172:13,15,23
Index: officers- president/director
258:10
Peter 217:15
phantom 201:19,
21
Philadelphia
279:6 280:9,19
281:4,19,24 282:8
291:23 292:6
phone 167:12
196:3 203:1,2,6,7
222:6 283:8
phonetic 217:15,
16 238:12 279:11
physical 175:10
pick 261:14
piece 227:21
233:24 234:2
246:17,16,19,20
PIS 230:20
Pittsburgh 289:19
place 219:2237:11
264:21
plain 244:2
plaintiff 163:11
168:2,4 169:15,18,
25 170:219 171:8,
22 172:14 185:16
186:12 212:1,4,9
228:17,19,23
plaintiffs 168:1
plan 295:12
planes 182:4,6,9,
12,15,19,23,24
183:1,7 254:3,6,19
plans 295:9
platforms 239:15,
18
playing 207:13
pleading 233:23
pleasure 294:5
297:3
plenty 234:8
pm 298:25
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
point 171:23 205:4
218:17 245:4
254:10,11257:18
263:6 266:25
279:10 290:14
pointing 251:3
points 230:18
police 297:24
policies 219:15
portion 194:22
299:18
pose 279:17
position 162:21
204:3,21244:22
256:1261:18
Post 224:17,20
225:1
practice 202:10
204:22 221:14
244:12 289:9
practiced 281:17
283:22 284:13
286:20 287:3
practices 244:11
287:9
practicing 214:21
283:19 284:20
286:8,24 292:3
precedent 247:3,5
prejudice 276:6
preparation
161:18 296:14
prepare 214:16
222:7,14
prepared 162:5
169:21214:23
227:8 283:15
285:13
present 198:8,12
president 170:23
181:19 187:18,21
190:20 281:24
president/
director 217:18
pretty 192:18
227:15 293:5
previously 201:4
principal 181:1
279:4 280:6
printout 176:11
193:15
prior 167:20
225:24 226:4
282:5,15
private 229:23
230:2,5,9,12 244:5
privilege 197:13
privileged 223:25
224:6
prize 277:5
pro 290:21,24
problem 217:20
234:21294:23
proceeding
221:19
PROCEEDINGS
160:1
process 274:8
produce 274:24
275:3
professional
290:20
profit 209:19
279:3 280:6
program 258:13
project 274:4
promote 168:1
proper 217:21
properly 218:9
properties 236:11
237:23 289:12
property 176:21,
22 177:5 287:15
289:19,20,22
proposal 245:19
248:1,3,10,1 1,12,
16,17
proposals 248:20
propose 245:21
proposed 245:22
propounding
175:19
prosecuted 163:2
protect 266:17
protected 266:17
protects 266:8
267:3,9,10,11,13
provide 198:3
provided 208:7
286:2
PRR 218:9
psychiatrist 255:5
public 160:10
162:1,2 163:1
167:23 168:15
172:22 174:12
175:19 179:21,23
185:5,9,19,23
186:9,12,20,21,22
1872,5,24 198:4
204:23 206:7,23
208:19 211:25
212:9,14 213:6,17
218:11268:12,21,
23 269:1,6
publicly 240:4
pull 182:14
purpose 160:21
161:23 162:10
185:1 189:2
242:15 248:24
255:16 258:19
262:14
purposes 162:23
185:5 194:13
227:2,3 228:2
242:14 248:23
262:19
pursuant 219:15
pursue 275:25
276:8
pursued 221:15
put 168:20202:8
204:2, 235:21
236:24 244:4,21
249:15 260:12,14
261:19 262:4,22
263:20 264:3,12
265:4 267:5,8
269:1271:20
292:24 293:22
299:17
putting 261:9
270:16,20
6
quarter 274:3
275:1
question 165:3,11
174:24 175:2
176:23 179:16
181:12 186:8
194:19 197:13,24
199:8 212:7
219:21220:16,
223:18 236:2,6
238:1255:7,12
261:7 267:20
272:16,17,18
277:19 287:5
294:10 297:12
questioning
298:13
questions 168:10
182:16 184:6
196:25 197:15,21
202:18 204:7,19
205:6 207:14
218:3 219:18
227:14 244:19
255:10 264:23
276:21,23 277:18
279:13,16,18
290:11,16
quicksand 200:20
quote 233:23
quotes 167:17
228:2,8
quoting 232:7
R
rafting 296:18
raised 249:14
250:10,25
ramifications
244:10
ran 239:15,18
Randolph 220:2,
20,21,23 222:18,22
223:4,13,16,22
224:3,8,17 225:11,
14 226:11227:16,
18,23 228:10
229:16,19 230:8
233:23 234:9,11
236:10,16 237:7
238:2,4,24 240:15
242:16 247:7
248:18 249:4
255:19 256:11
258:18 259:19
270:1
Randolph's 228:5
reached 292:1
read 194:19,21,22
224:2 225:22,24
226:4 227:9,10,11,
15,17,18,19,20
231:9,10,11232:21
233:1,5 255:12
256:13 278:18
280:3 291:6,
292:9,20 299:18,21
reading 223:8
258:15
real 273:7,12,13
288:11
realize 235:21
realized 285:13
reason 165:12
166:11227:3
233:13 248:24
250:3
reasonable 253:1
reasons 162:22
270:17,22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: pretty- rectify
recall 170:25
171:5 174:15,19
200:14 226:23
230:5 232:14
243:17 253:19
254:20,21261:11
275:5 281:20
282:23 283:2,6,13,
17,21,24 284:2
receipt 219:10
received 203:8
218:24 222:20,24
285:4
recess 245:13
298:24
recited 284:6
recognize 246:20,
22 257:16 280:19
recognizes 194:16
recollection
201:11227:16
230:17 251:1
record 160:4
163:1 194:22
199:6 219:20
220:14 241:7
245:12,15 246:4
268:12,21,23 277:4
293:22 298:23
299:1,15,16,17
records 160:10
162:1,2 167:23
168:15 172:22
174:12 175:19
178:13,14 179:21,
23 185:5,9,19,23
186:9,12,20,21,23
187:2,25 192:8
198:4 199:14
200:3 203:6
204:23 206:7,23
211:25 212:9,14
213:6,17 218:11
247:22 269:1,6
286:7,10,12
Records.com.
187:5
recounted 248:17
rectify 225:21
226:25 227:4
Red 273:3
refer 170:10 171:9
252:20
reference 230:21
260:24 261:15,16
referenced 218:8
referred 252:21
referring 216:18
256:10 263:9,10
reflect 284:12
286:7,18
reflected 287:2
reflecting 292:5
refresh 201:11
refuse 214:18
279:14
refused 215:19
230:16
regard 173:4
184:12 187:1
203:24 235:14
244:11264:21,25
279:23 280:18
288:4 299:7
registered 175:25
176:14 187:15
190:19 193:13,24,
25 259:1260:10,
13,20 261:1,
278:10 286:23
registration
203:13
regret 218:8
reinstatement
176:12
reiterate 219:14
related 181:4,6
relating 167:22
223:24 224:4
relief 276:1,3
relies 256:17
remain 217:19
remarkably
256:15
remember 164:20
165:3 166:21
170:12 201:9
220:24 225:3,17
230:20 231:22
236:14,15 238:13
250:24 251:1
253:17,23,25
254:10,12
remorse 243:18
removed 260:20
remuneration
212:1,3,6 241:16
rent 175:3
rental 288:11
repaid 209:16
repay 210:23
211:10
repeatedly 240:4
rephrasing
196:12
replacements
217:14
report 233:15
reporter 194:23
representation
291:24
represented
211:22 295:2,3
representing
228:2,8
reputation 263:16
request 206:7
211:25 212:9
269:3,5 274:24
requests 162:1,2
163:1 168:15
172:22 174:12
175:20 179:21,23
185:6,9 186:10
198:5 212:14
213:6,17 297:7
required 170:8
240:13 275:20
reside 203:10
281:7
resided 290:14
residence 288:18
289:8,10
residential
289:12,20,22
residents 264:5
resides 203:18
280:23,25 281:5
288:20
resign 215:25
217:13
resignation 200:7
215:16,18
resigned 166:12
200:5 214:1,4
215:12
resigning 165:13
resigns 164:24
resolve 278:16
resolved 242:23
249:2 294:23
resolving 246:2
respect 292:25
respond 218:9
238:2 256:20
270:15 294:6,8,11
responded 219:13
224:17,18,21
229:19
responding 229:8
response 237:24
279:16
responsible
244:25 245:1
rest 173:17 295:8
retaliating 255:16
retract 164:11
166:5 167:6
returning 167
returns 189:10
reveal 220:7
review 160:16,19
246:21
rid 243:14 245:22
246:3,24 247:1,17,
19,22
ridiculous 204:19
273:10
rights 276:7
Ring 162:9170:16
174:21 179:5
197:8 200:17
213:1216:8 217:2,
13 220:1,3,9,11,19,
21222:3,14,17,25
223:15 240:25
241:1,13,21,25
242:3,22 245:18
258:21259:2,13,15
260:9,20,25 261:1,
9 265:18
Ring's 162:23
260:12
rip -off 267:7
ripped 252:17
ripping 253:10
risk 256:19
River 296:18
road 289:25
Roanoke 191:21
rocket 236:16
room 169:6 223:20
row 173:9 199:10
Rubicon 225:20
226:2,16,22,23
ruin 271:20
run 179:7 233:15
270:18
running 182:25
rush 204:1
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: Red -settle
Russell 174:22
178:20,21 179:4
217:19
Ryan 174:10
195:6,20
S
salaries 196:4
salary 183:22,24
184:2
sanction 243:11,
13
sanctions 243:20
245:8 260:19
Sasser 291:2,11
sat 256:23
Saturday 297:18
save 175:15199:11
239:14
schedule 293:21
294:13 295:8
scheme 164:8
secretary 164:22
169:6 172:21
178:18,19,21 179:3
181:19 183:20
200:8 206:20
213:13 215:14
254:7 259:23
260:2 283:25
seek 276:2
send 164:19 201:3
213:2 217:21
223:6 231:12
268:3,4 275:3
September 294:1
295:9
serve 184:4 235:22
served 235:24
260:23
serving 220:11
set 180:9270:20
settle 218:13,19
227:5 246:1,14,15
247:20 248:2,11,20
settled 165:15
208:18
settlement 217:5
219:1,8,15 223:19,
23 224:4,11,23
227:2,3 239:6
240:9,10,12 242:9,
12,14,20 243:3
245:19 246:6,9
247:10 248:7,9,16,
17,19,23 255:25
256:2,4,8
settles 208:10,14
Seventh 161:2
shame 228:14,15
264:9
share 255:23
shared 224:11
256:12
sheet 193:24
Sheila 176:15
shit 233:24 234:3
246:18,19,20
276:16 291:7
shitty 291:8
shock 249:7
shocked 249:5,6,8
short 296:10
show 174:14
176:5,10 177:19
185:18 193:12
198:20 201:15
202:19 214:23
237:3 279:15
showed 222:16
233:15 269:22
283:7
showing 190:10
193:14 216:19
sic 273:3
Sid 221:25
side 246:7,10
248:20 256:7
sign 264:12 267:5,
8 288:5
signed 225:11
243:17
signs 231:22,23,25
silly 298:8,10
Silver 273:3
similar 256:15
simply 256:10
sir 175:6,11,25
176:20 190:11
199:16 205:20
206:12 237:19
290:8
sit 233:7250:15
sitting 230:25
Skip 220:21,23
222:5 227:15,18,20
228:16 236:15
238:24 240:15
243:21,22 257:18
skull 217:11
sleeps 290:2,4,17
slept 290:14
slew 229:23 230:2
smart 189:5
smiles 262:25
Smith 162:15
163:3 164:13
172:12,16 173:5,
10,21 197:5 201:15
204:16 205:1,14,21
206:25 207:21
219:20 223:7,11
231:1235:10
236:2,4 245:2
257:20 266:23
280:1284:22,25
286:13 292:7
293:24 294:9
298:4,7
sober 236:12,
237:24 249:14,15,
24 250:10,12
251:3,6 258:12,19,
22 259:5,9,16,22
261:15,17 262:4
263:20,23 264:20,
21265:1270:17,20
271:6,12,20,23
272:7,10,22
social 162:22
sole 160:21 162:10
189:2 207:17,25
solicited 168:5,13
204:22
solution 201:3
son 162:11 163:2
164:7 173:19
174:10 192:19
198:3,17 202:8,20
203:10 204:2,21
216:2,9 228:16,23
235:3,15,16,21
238:25 244:9,21
265:16 278:5,23
279:17,18 281:12,
16,21282:6,14,18
283:12,14,18,23
284:18 285:22,23
286:22 287:1,8,19,
22,25 288:1,16
289:6 290:8,12,13,
17 291:10
son's 160:22
165:14 173:19
192:20 193:10
212:20 219:24
251:4 278:6
sophisticated
211:2
sort 242:11243:25
247:13
sought 168:2
space 175:10
193:3,6,10 288:4
speak 222:19,23
223:15 273:24
278:23
specific 209:17
245:9
specifically 170:8
209:15 279:17
specifics 174:8
254:12
speculate 266:25
speech 256:21
speeches 277:1
speed 292:22
spend 167:13
295:7 296:9
spending 294:2
spoke 220:3,19
242:6 264:17
spoken 289:2
spread 268:4
stand 259:12
standing 189:7
start 237:20293:4
started 242:25
247:12,13
starting 264:9
state 171:18
176:10 192:8
195:15 202:11
208:19 226:3
244:11259:23
270:19 272:20
278:10 279:2
280:4,11281:25
284:14,20 286:9,20
290:6,22 292:1,5
295:10,13
stated 209:11
240:4,7 254:4
258:14,16 259:8
271:5 293:22
statement 160:17
162:4 167:6
193:12,23 205:21
206:18,19 225:24
229:25 253:9
256:11259:18
280:13,16
statements 256:16
276:20 277:10,20
states 166:7298:3
stationary 283:14
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: settled-substance
statute 212:2
stay 223:19 288:14
293:19
stayed 168:17,21
staying 174:17,18
steal 166:16,20,22
stick 237:17
stole 164:4 166:14,
18
stop 184:17187:23
188:4 207:13
251:3
Stream 172:17
176:16 213:7,8,17,
21236:11237:3,24
257:10,12,25
258:12,19 263:21
264:5,8,13,22
265:2 270:17,20,21
271:5 284:10
290:25 294:3
Street 278:11
279:6 280:8,19
281:18,23 282:7
283:16 287:4,13
291:22 292:3
strike 240:20
267:17 282:15
285:22
struggling 270:24
274:13,14
Stubbs 220:23
221:25
stuck 200:19
stuff 164:23
165:24 178:15
204:18 215:15
stupid 244:2
subject 200:17
238:18 249:21
subpoenaed
269:19
subsidiary 181:6
substance 220:8
261:4
sudden 237:15
sue 173:13
sued 172:17,19
232:17 269:16
sues 173:11,12
suggest 256:19
267:21
suggested 229:23
230:1
suit 161:11 199:3
suits 246:4,25
247:22
sum 219:7270:23
274:2
Sunday 297:19,20
Sunshine 167:23
supposed 195:15,
16 210:25 211:1
238:7,8,9,23
274:25
Supreme 284:12
286:6,11,18,23
287:2,9 291:25
surgery 236:21
surprised 173:22
surrounding
270:21
suspend 293:13,
20,21294:4
298:12,13,16 299:3
Sweet 259:22
261:14 263:23
266:21272:10
Sweetapple 160:5
161:15,16 162:17
163:6,12,16 164:17
165:20 168:11
171:6 172:1,9,14,
19 173:7,23 174:1
175:23 176:2,9
177:7 178:12
179:9 180:7,10,14,
18,21 184:16
185:22 187:11
188:8 189:21
190:17 193:1
194:7,11,15,21
195:1 196:18
197:7,20 198:16
199:3,7,12 201:17,
21202:1,3,15
204:10,20 205:5,8,
15,24 207:2 208:3,
16 212:13,17
213:12 216:17
217:1219:22
220:10 221:22
223:9, 225:12
228:4,9 231:2,12
232:11,16 233:2,10
235:8,13,20 236:9
240:3 241:12
244:7,17,20 245:6,
16 250:11251:12
253:13 254:18
255:6,24 256:13,23
257:5,8,15,19,23
261:8 262:18
264:11,20 267:1151
6 270:2,11271:10
272:6,17,19 273:14
275:18 276:5,12,
19,22 277:8,16,19,
24 278:3 280:2
283:11285:3,10
286:11,15 292:8
293:2,10,12 294:7,
12,15 297:13,23
298:5,10,18 299:2,
10,12,17
swore 291:20
sworn 162:20
163:7 172:25
290:23 291:10
T
table 180:6 225:7
taking 219:1
261:18,24 293:14
299:8
talk 242:12,17,18,
19 243:15 251:7
254:5 257:1
275:14
talked 243:5,25
245:24,25 246:2,
23, 248:24 249:2,4
250:23 276:19
talking 179:11,13
199:1,3,5 201:20
202:24 204:9
206:13,18,19 212:3
213:24 216:1,8
237:11,21239:18
241:8 246:4 247:6,
12 249:21277:15
targets 230:10,11,
13
tax 189:10 210:24
Taylor 162:13
163:4,11 164:8,15
165:14,19 205:2
207:22 218:1
219:12,13 235:18
255:2 256:20
293:22
telephone 218:6,
22,25 274:21
284:10 286:3,4
telephonically
198:8
telling 167:8172:5
197:15 234:9,12
247:14 267:2
285:22 297:2,14
temporary 201:3
tenant 174:25
181:10
terminate 250:2
terms 170:13
209:7 218:23
298:10
terrible 203:5
231:18
testimony 163:7
172:25 214:24
218:2 248:18
262:17 295:21
297:16
thing 203:5 239:21
242:13 243:4,14
things 173:12
201:10 243:16
263:3,24 267:11
293:1298:19
thinking 250:12,
14
Thirdly 250:8
thought 226:11
227:14 249:11
252:10 255:4
261:17,19,24
262:8,9,24,25
263:1,23,24 264:1
265:25 274:12
Thrasher 231:9
238:7,8,16,23
239:9,22 240:1,5,9,
11,13 269:2 271:8
291:1
Thrasher's 295:1
threat 167:15
250:20 259:12,14
threaten 259:7
threatened 223:24
259:5
threatening
250:16 251:2
threats 224:24
Thresher 269:22
threw 225:7
Thursday 294:22
time 160:3167:13
168:18 169:11
174:6,16 175:15
183:6 197:14
199:11207:12
215:5,10,13 220:12
222:7 233:18
234:8 239:21,22
241:2,245:11,14
250:22 276:24
285:12 293:10
294:2,18 295:7,12
296:9 297:23
298:5,13,22,25
299:4,14
times 166:3173:16
199:10 217:9
267:21
tin 273:1,2,16
title 177:20,22,23
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: sudden-treated
178:4
today 194:2 215:7
219:14
today's 293:25
told 165:22178:24,
25 179:2 182:10
183:5 184:10
193:9 197:14
200:5 214:12
222:3,5 231:6
233:8 238:4,22
244:23 248:13
251:23 268:6
275:7,13 288:15
295:3
Tom 238:11,24
240:16
tomorrow 295:14
ton 270:25
top 264:10
topic 237:18
touched 234:16,25
235:1
town 172:17 213:7,
17 231:21,24
232:2,4 236:24
237:3 239:14
240:8 250:17
251:3,8 252:14,20
257:24 261:16,18,
24 262:2,21
267:24,25 268:3,9,
23 269:16 271:20
272:4 290:25
294:2,21,24
townhouse 281:4
track 294:18
train 263:1
transcript 228:3
231:10,11
transparency
168:2
treasurer 187:19,
21 190:20
treated 235:15,16
troublemaker
221:2
true 164:16211:21
272:22,24 277:10,
20 278:21,24
279:9,24 280:13,15
291:12 293:1
trust 288:2
trusted 217:16
truth 172:6234:9
turn 236:12237:23
273:2,16
two- and -a -half
255:21
two- and -half
255:20
Tyne 279:11
type 204:18
231:22,23,24
u
Uh -huh 247:8
unable 247:2,4
unauthorized
204:22 221:14
unaware 217:23
219:1284:17
285:1
understand
173:3,11200:23
211:12 212:8
215:1219:7
248:15 270:7
276:4 282:18
understanding
169:16,21 170:1
212:12 219:10
understands
212:13
understood
218:16,18
unencrypt 215:22
unequivocal
218:23
Unethical 267:5
unique 167:25
unknown 270:22
unpleasantness
166:6
unproductive
221:9
untenable 235:22
untrue 233:4
291:15
unwilling 247:4
upset 267:25 268:2
urgency 293:18
utilize 266:15
V
vacations 297:7
valor 221:12
Vargas 267:7
verbal 269:4
verbatim 167:16
verified 290:24
291:11
versus 161:1,8
vice 290:22,24
vicinity 259:15
288:18 290:9,15
victory 239:22
vindictiveness
235:24
violation 264:2
violations 167:22
171:10
violent 234:14,24
Virginia 191:21
289:14,15,24 290:1
295:20,24 296:5,12
visit 166:6
Volume 299:24
voluntarily
270:16
voter 203:13
W
wait 242:16255:24
299:5
walk 270:7
walked 243:1
wanted 166:14
188:5 201:24
221:25 238:11,16
247:17 248:6
252:23 254:8
263:17,22 264:12
265:24 266:2
268:7 274:17
watch 202:6
watching 253:23
254:9,23
water 270:21
website 187:3
Wednesday
294:19,20
week 206:7,24
215:8 294:19,24
296:10,13,24
weekend 296:16,
20
weeks 169:9,14,24
207:5 293:24
294:17 295:4,5,6
297:7
west 176:13,17,25
181:14 188:18
192:20 193:5,15,17
196:23 289:14,15,
24 290:1295:20,24
296:5,12
whatsoever
163:19 202:14
whitewater
296:18
whoa 236:19
Index: troublemaker -young
whorehouse
264:14,16 266:21
wife 175:25187:15
190:19 204:14
229:17,21230:1
265:14 288:5
296:8
William 174:21
259:2 291:1
windfall 164:8
218:21
withdrawal 276:7
withdrawn 248:6
275:17 276:6,11
withdrew 243:21
276:13
Witmer 174:10
195:6 203:23
witnesses 173:1,17
word 232:9 236:15
250:10
words 229:1
271:22
work 162:21
168:6,14 192:13
195:20,21216:9
288:22 295:5
worked 288:15
working 169:2,11
173:9 201:22
203:20 215:2,8
works 168:25
169:3,4
world 244:25
289:11
worry 217:6
Worthline 238:11
write 199:25
200:16 234:12
271:2 273:17,19
275:6
write -off 210:24
writing 174:11
205:10,17 206:9,
12,21214:13,14
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
215:9 223:5,14
269:2,7 270:15
writings 273:22
written 209:24
240:12 270:3
288:1,3
wrong 236:17,19
wrote 198:17
199:13 200:18
201:6 214:25
215:6 217:25
234:11252:5
269:2 275:9,10,
279:11285:18
VA
y -n -n 191:19
year 164:3181:23
195:19 213:25
290:15 296:12
years 179:6
188:12,14,16
190:15,18 206:20
277:14
yesterday 215:7
218:25
York 195:15
young 189:3
Supplemental responsive document
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
March 17, 2015
Asset Enhancement, Inc. [mail to: records @commerce - group.com]
Re: GS #1423 (832)
Provide a copy of all non privileged Public Records which were at the Deposition of Martin
O'Boyle on September 15, 2014 and which were brought by Scott Morgan, William Thrasher, Bob
Sweetapple and /or Joanne O'Connor (the "PR's') We would request a privilege log for any
documents or other (PR's) which the Requestee asserts are privileged and which the Requestee
asserts that the Requestor is not entitled to received said PR's. As to the PR's, please identify
which PR's came from each of the party's enumerated above.
Dear Asset Enhancement, Inc. [mail to: records (a),,commerce- eroun.coml,
The Town of Gulf Stream received your public records requests dated September 17, 2014. You
should be able to view your original requests at the following link h_pt : / /www2.eulf-
stream. ore/ WebLinkS /0 /doc /21016/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 numbers.
The supplemental responsive document is Volume 2 of the deposition transcripts. The exhibits
are embedded within the deposition transcripts which are attached to this email.
We consider this matter closed.
Sincerely,
Town Clerk, Custodian of the Records