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Home My Public Portal AboutPRR 14-1548RECORDS REQUEST (the "Request') Date of Request: 10/2/2014 Requestor's Request ID#: 921 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTER: 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: Provide a copy of the Request to Produce from O'Hare as set forth on the August 31, 2014 Jones, Foster billing (Invoice #174285) with a billing date of 8/2312014. Please also provide all Responsive Documents and all communications regarding the aforementioned Request to Produce from O'Hare and /or the Responsive Documents. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA CONSTITUTION. IT 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 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E -MAIL DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requestor approve of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:P/NPR/FRR 09.12.14 FORM TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail October 20, 2014 Asset Enhancement, Inc. [mail to: records @commerce- group.com] Re: GS #1539 (912), #1548 (921) Please provide any drafts of the response of Public records request #797 Provide a copy of the request to produce from O'Hare as set forth on the August 31, 2014 Jones, Foster billing (Invoice #174285) with a billing date of 812312014. Please also provide all responsive documents and all communications regarding the aforementioned request to produce from O'Hare and /or the responsive documents. Dear Asset Enhancement, Inc. [mail to: records(a),commerce- erouo.coml, The Town of Gulf Stream received your public records request on October 2, 2014. If your request was received in writing, then the request can be found at the following links: htto: / /www2.¢ulf- stream .org /WebLink8 /0 /doc /22827/Pa eg l.aspx and htty://www2.gulf- stream.org/WebLink8 /0 /doc /22836/Pagel.aspx. 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 R�l COMMERCE GROUP mobovle(alcommerce -group. corn Direct Dial Telephone #954 -570 -3505 October 21, 2014 VIA E -MAIL: bthrasher6Fkulf- stream.ore TELEPHONE #561- 276 -5116 Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Attn: William H. Thrasher, Town Manager Re: Records Request #921 Requestor. Asset Enhancement, Inc. Dear Mr. Thrasher: Reference is made to the captioned Request which was submitted to the Town of Gulf Stream on October 2, 2014. A copy of the Request is attached for convenience. It is the Requestor's belief that the Town of Gulf Stream is purposely delaying the fulfilling of the Request. It is implausible that the fulfilling of this Request is taking this long. I write you this letter to alert you that if the captioned Request is not fulfilled by the close of business on Friday, October 24, 2014 (the "Deadline "), that the Requestor will, with great reticence, institute suit. Of course, if you cannot accommodate the Deadline and you alert us at least 24 hours before the Deadline, articulating a bona fide reason for not being able to accommodate the Deadline, the Requestor will consider extending the Deadline to a reasonable date considering the circumstances, which circumstances would have to be reasonable in themselves. Sincerely yours, COMMERCE GROUP, INC.. Martin E. O'Boyle President Enclosure P/NPR/FRR www.commerce-group.com TEL 954.360.7713 • 17 x 954.360,0807 1280 WEFT NmroxT Correa Dmw, DEEKmE BEACH, FwxioA 33442 RECORDS REQUEST (the "Request") Date of Request: 10/2/2014 Requestor's Request ID#: 921 REQUESTEE: Custodian of Records Town of Gulf Stream 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: Provide a copy of the Request to Produce from O'Hare as set forth on the August 31, 2014 Jones, Foster billing (Invoice #174285) with a billing date of 8/23/2014. Please also provide all Responsive Documents and all communications regarding the aforementioned Request to Produce from O'Hare and /or the Responsive Documents. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT, CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY STATUTORY RIGHT OF ACCESS, AS APPLICABLE). TffiS REQUEST IS ALSO MADE PURSUANT TO THE RIGHTS OF THE REQUESTER 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 119.07(4) (a) (2) ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E -MAIL DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requestor approve of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requestor by the Agency. I:P/NPR/FRR 09.12.14 FORM Filing # 17405295 Electronically Filed 08/22/2014 11:29:36 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CHRISTOPHER F. O'HARE, Plaintiff, CASE NO.: 2014CA000824 AD V. TOWN OF GULFSTREAM, Defendant, NOTICE OF SERVING PLAINTIFF'S SECOND REQUEST FOR PRODUCTION TO DEFENDANT Plaintiff, Christopher F. O'Hare, ( "Plaintiff'), by and through undersigned Counsel, hereby gives notice of serving, by e-mail its Second Request for Production to Defendant, Town of Gulf Stream. CERTIFICATE OF SERVICE I�EREBY CERTIFY true and correct copies of the foregoing have been hand delivered this day of August, 2014. Respectfully Submitted, The O'Boyle Law Firm P.C., Inc. Attorneys for Plaintiff 1286 West Newport Center Drive Deerfield Beach, FL 33442 Telephone: (954) 574 -6885 Facsimile: (954) 360 -0807 vwilliams@oboylelawfirm.com By: /s/Verhonda Williams Verhonda Williams, Esq. Florida Bar #92607 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CHRISTOPHER F. O'HARE, Plaintiff, CASE NO.: 2014CA000824 AD V. TOWN OF GULFSTREAM, Defendant, PLAINTIFF'S SECOND REQUEST FOR PRODUCTION FOR DEFENDANT Plaintiff, Christopher F. O'Hare, ( "Plaintiff'), pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, requests the Defendant, the Town of Gulf Stream, ( "Defendant" or the "Town "), to produce the following documents within thirty (30) days of service of this Request. CERTIFICATE OF SERVICE I HEREBY CERTIFY true and correct copies of the foregoing have been hand delivered this _ day of August, 2014. Respectfully Submitted, The O'Boyle Law Firm P.C., Inc. Attorneys for Plaintiff 1286 West Newport Center Drive Deerfield Beach, FL 33442 Telephone: (954) 574 -6885 Facsimile: (954) 360 -0807 vwilliams@obovlelawfirm.com By: /s/Verhonda Williams Verhonda Williams, Esq. Florida Bar #92607 DEFINITIONS 1. The term "document' shall mean any kind of written, recorded or graphic matter, however produced or reproduced, of any kind or description, whether sent or received by the Plaintiff or neither, including originals, copies or drafts and both sides thereof, and including but not limited to: papers, books, letters, correspondence, telegrams, cables, facsimile transmissions, telex messages, memoranda, notes, notations, work papers, inter - office or internal memoranda, transcripts, minutes, reports and recordings of telephone or other conversations, or of interviews, or of conferences, or other meetings, affidavits, subpoenas, notices, statements, summaries, opinions, reports, studies, analyses, evaluations, contracts, agreements, joumals, statistical records, desk calendars, appointment books, diaries, lists, tabulations, video recordings, sound recordings, computer print -outs, computer software and discs, data processing input and output, microfilms, and other records kept by electronic, photographic, or other mechanical means, minutes of meetings of board of directors, executive committees, or any other writings or recordings similar to any of the foregoing, however denominated by the Responding Party or its present or former partners, attomeys, counsel, accountants, auditors, agents, employees and all persons acting or previously acting on its behalf. The term "document' includes all of the above materials, whether asserted privileged or not. 2. The use of a verb in any tense shall be construed as the use of a verb in all other tenses, whenever necessary to bring within the scope of the specification all responses which might otherwise be construed to be outside its scope. 3. Terms in the singular include the plural and terms in the plural include the singular. 4. The term "relating to" as used herein is defined to mean referring to, evidencing, pertaining to, consisting of, reflecting, conceming or in any way logically or factually connected with the matter discussed. 5. "Acid" as well as "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the specification all responses which might otherwise be construed to be outside its scope. "Each" and "every" shall be construed synonymously, as shall the words '`any" and "all'. 6. The terms "Defendant," "you," "your," or any synonym thereof are intended to and shall embrace and include Defendant including its present and former legal representatives, subsidiaries, divisions, departments, affiliated companies, successors and assigns, as well as their respective officers, directors, employees, agents, attorneys and any others who are in possession of or may have obtained information or documents for or on behalf of the Defendant. INSTRUCTIONS 1. Manner of Production - Documents produced pursuant to this request shalt be separately produced for each paragraph of this request, or, in the alternative, shall be identified as complying with the particular paragraph or paragraphs of the request to which they are responsive, if the documents produced by inspection are produced as they are kept in the usual course of business. 2. Privileged Documents - In the event the responding party wishes to assert attorney /client privilege, work product exclusion or any other privilege as to any document requested, then as to each such document subject to such assertion, the responding party shall provide an identification of the document, including a) the nature of the document, b) the date of the document, and c) the author, sender, and recipient, together with a summary statement of the subject matter of such document in sufficient detail to permit the Court to reach a ruling in the event of a motion to compel and an indication of the factual and legal basis for the assertion of the privilege. 3. Documents Not In Possession, Custody, or Connrol - If you are unable to produce any document requested, state the reasons why you are unable to produce such document. A negative response to any request without further explanation will be deemed to be your response that the requested document is not in your possession, custody, or control, as interpreted by controlling case law. 4. Documents No Longer In Possession, Custody, or Control - With respect to documents of which the Defendant once had possession, custody or control, but no longer has possession, custody or control, please identify the document and state why the document is no longer in the Defendant's possession, custody, or control and identify the person who currently has possession, custody or control of the documents. DOCUMENTS REQUESTED 1. The document Defendant acknowledges receiving from Plaintiff on December 4, 2013, stating "Any and all records disposition documents relative to the destruction of any and all public records during the period of January 1, 2013 through to the date when you substantially responded to this Public Record Request," as referenced in paragraph twenty (20) of the Defendant's complaint. 2. Any and all documents that were "gathered and made available to Plaintiff to pick up at the Town Hall, as communicated to Plaintiff on or about December 6, 2013," as referenced in paragraph twenty -three (23) of Defendant's answer. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502014CA000824XXXXMB AG CHRISTOPHER F. O'HARE, Plaintiff, VS. TOWN OF GULF STREAM, Defendant. DEFENDANT'S RESPONSES TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION Defendant, TOWN OF GULF STREAM, responds to Plaintiff's Second Request for Production dated August 22, 2014 (Nos. I and 2) as follows: DOCUMENTS REQUESTED The document Defendant acknowledges receiving from Plaintiff on December 4, 2013, stating "Any and all records disposition documents relative to the destruction of any and all public records during the period of January 1, 2013 through to the date when you substantially responded to this Public Record Request," as referenced in paragraph twenty (20) of the Defendant's complaint. RESPONSE: Responsive document attached. 2. Any and all documents that were "gathered and made available to Plaintiff to pick up at the Town Hall, as communicated to Plaintiff on or about December 6, 2013," as referenced in paragraph twenty -three (23) of Defendant's answer. RESPONSE: Responsive documents have previously been identified in the answer to Interrogatory No. 11 and produced on June 30, 2014 by e-mail from the office of the undersigned to rwitmer(a,oboylelawfirm.com. Specifically, two PDFs of the 1 8 %: x 11 document and 5 8 %: x 14 documents that the Town made available to Plaintiff on December 6, 2013 and that Plaintiff picked up from the Town on February 5, 2014 were attached to that e-mail. They are attached again as a courtesy. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by email to Ryan L. Witmer, Esquire, The O'Boyle Law Firm, PC, 1286 West Newport Center Drive, Deerfield Beach, FL 33442 (rwitmer(2.obovlelawfimi.coml and Robert Sweetapple, Esquire, Sweetapple Broeker & Varkas, PL, 20 SE Third Street, Boca Raton, Florida 33432 ( leadings u,sweetapplelaw.com) this 191h day of September, 2014. JONES, FOSTER, JOHNSTON & STUBBS, P.A. Attorneys for Defendant Town of Gulf Stream 505 South Flagler Drive, Suite 1100 Post Office Box 3475 West Palm Beach, FL 33402 -3475 Telephone: (561) 659 -3000 Facsimile: 1) 650-5300 By /s/ Lr�r� L John ;and olph Florida Bar No. 129000 irandoluh a,ionesfoster.com Joanne M. O'Connor Florida Bar No. 0498807 i oconnor(@,,i onesfoster. com\ p .\does \13147\00047 \pid \I k60738.docx SA ATE ENOFTA OEPnTMEa OF STATE RECORDS DISPOSITION REQUEST 18 , eM.c�`r .LSSE10r114.93 .wuur i NO. PAGE OF_T PAGES 1, AGM OF GULF, SIMA� 2. DIVISION CLERK TOM 3. BUREAU 4. ADDRESS (Street, City, and Zip Code) 5, CONTACT (Name and Telephone Number) 100 Sea Road, Gulf Stream, FL 33483 Rita Taylor 561 -276 -5116 SUBMIT TO: 6. SUBMITTED BY: I hereby unify that the records to be disposed of are correct, represented below, that any audit requirements for the records have been fully Florida Department of Slate Justified, and that further retention Is not required for any litigation pending or Bureau of Archives and Records Management imminent. Mall Station A ' The Capitol Tallahassee FL 32399.0250 Signaaa(((yyyrrr�� Dale ! J' A c•7�--� Q r Name andStlea Taylor Town Clerk 1tOOFF , 7, BUREAU OF ARCHIVES b RECORDS MANAGEMENT REVIEW 6. NOTICE INTENTION (FOR DIVISION USE ONLY) The scheduled records listed in Item 9 are In be disposed or in the manner checke, below (specify only one): TECHNICIAN REVIEW ?S a. Destruction _b. Microfilming and Destruction ANALYST REVIEW c. Other ARCHIVIST REVIEW SUPERVISOR REVIEW 9. LIST OF RECORD SERIES a, b. c. Titre d. Retention e. Inclusive I. Volume g. Disposition Schedul Item (Division Use Doles In Cubic Action and Dale ahem No. Only) Feet Completed After Authorization GS -3 10 Ballots, Official Local: Undergrounding Utilities (Spec, non -ad valorurn assort) 2 -7 -11 .36 Landfill GSl -SL 16 Qualifying Records- Candidate 3 -1996/ 1 -31 -13 3 -2002 .12 17 Correspondence, Adm. (read file) 12131509 .16 28 Phone Records -Long Dist. (Fax) 10 -1 -06/ 12 -31 -09 .06 71 Bid Records:Cap. IBlpr,(Unsuccessful Bid) 1 -1 -86/ 12 -31 -07 .06 89'Calendars 1 -1 -06/ 12 -31 -08 .02 124 Ibnthly Police Activity Reports- 1 -1 -97/ Operational & Statistical Reports 12 -31 -06 .09 229 Ordinance Supporting Doc. (Zoning Code 1 -1 -94/ Amendments 12 -3I -00 .45 v I 25 Arch. /Bldg. Plns. Resid. -ARPB Review Thru 1995 5,48 GS6 6 Building Plans Resid. 1985/9-30-97 12.1 •.NOTE «FOR CONTINUATION USE Forth LSSE10a' - 10. DISPOSAL AUTHORIZATION (FOR DIVISION USE ONLY) 11. DISPOSAL CERTIFICATE: The above listed records have been disposed of in Disposal for the above listed secords Is duthorized: •Aey deletions or the mapKrand on the Ste shown in column g, modifications are Indicated. f' � / (Sly /••-_. Signature ' Dale 1 -3 1 Rita L. Taylor, Tbwn Clerk Director, Division of Library Date and Information Services Name Title - ss , NOTE: U on dfs osition'retaln This fartn far our records , . _. __..�.r . , . 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Of 3 alb a`foo Avehue AO.�,� ..... 3D N,�.. 6153 -335 Stay n also �Y�3 3soo SS a 11 35,5 -7 r/ Macfarlane, Mary From: Chris O'Hare < chrisoharegulfstream @gmail.com> Sent: Wednesday, December 04, 2013 6:39 PM To: Bill Thrasher Subject: PUBLIC RECORDS REQUEST record destruction audit PUBLIC RECORDS REQUEST Pursuant to Article 1, Section 24 of the Florida Constitution and Chapter 119.07 of the Florlda Statutes I wish to make a public records request of your agency for the following records: Any and all records disposition documents relative to the destruction of any and all public records during the period from January 1, 2013 through to the date when you substantially respond to this Public Record Request. If you contend that any of the records I am seeking, or any portion thereof, are exempt from inspection or disclosure please cite the specific exemption as required by 6I 19.07(1)(e) of the Florida Statutes and state in writing and with particularity the basis for your conclusions as required by 5I 19.070)(f) of the Florida Statutes. Please take note of 4119.07(c) Florida Statues and your affirmative obligation to (1) promptly acknowledge receipt of this public records request and (2) make a good faith effort which "includes making reasonable efforts to determine from other ofcers or employees within the agency whether such a record exists and ifso, the location at which the record can be accessed." I am, therefore, requesting that you notify every individual in possession of records that may be responsive to this public records request to preserve all such records on an immediate basis. If the public records being sought are maintained by your agency in an electronic format please produce the records in the ro ieinal electronic format in which they were created or received. See 6119.01(2)(f). Florida Statutes, If you anticipate the production of these public records to exceed $1.00 please notify me in advance of their production with a written estimate of the total cost. Please be sure to itemize any estimates so as to indicate the total number of pages and/or records, as well as to distinguish the cost of labor and materials. All responses to this public records request should be made in writing to the following email address: chrisohareeu IfstreamQemail.com Kelly Avery From: eservice @myFlcourtaccess.com Sent: Friday, September 19, 2014 5:13 PM Subject: SERVICE OF COURT DOCUMENT - CASE NUMBER 502014CA000824XXXXMB Attachments: Response To Req To Produce.pdf Notice of Service of Court Documents E- service recipients selected for service: Name Email Address Joanne M. O'connor ioconnor ionesfoster.com Filer: mmacfarlane a,lonesfoster.com Robert A Sweetapple pleadings n,sweetapplelaw.com cbailey(@.sweetapplelaw.com rsweetapple(@,sweetapplelaw.com Ryan L. Witmer obovlecourtdocs n oboylelawfirm.com rwitmerna,oboyl elawfinn.com E- service recipients deselected for service: Name Email Address John C. Randolph irandol h ionesfoster.com Filer: smatias a,ionesfoster.com Verhonda K Williams vwilliams a,obovlelawfirm.com obovlecourtdocs (&oboylelawfirm.com Filing Information Filing #: 18465810 Filing Time: 09/19/2014 05:13:24 PM ET Filer: Joanne M. O'connor 561- 659 -3000 Court: Fifteenth Judicial Circuit in and for Palm Beach County, Florida Case #: 502014CA000824XXXXMB Court Case #: 2014CA000824 Case Style: O'HARE, CHRISTOPHER F VS TOWN OF GULFSTREAM, Documents second request production.pdf To Req To Produce This is an automatic email message generated by the Florida Courts E- Filing Portal. This email address does not receive email. Thank you, The Florida Courts E- Filing Portal request_id #:18465810;Audit #: 62295492; UCN #:502014CA000824XXXXMB; z Filing # 18465810 Electronically Filed 09/19/2014 05:13:24 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502014CA000824XX3iXMB AG CHRISTOPHER F. O'HARE, Plaintiff, VS. TOWN OF GULF STREAM, Defendant. DEFENDANT'S RESPONSES TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION Defendant, TOWN OF GULF STREAM, responds to Plaintiffs Second Request for Production dated August 22, 2014 (Nos. 1 and 2) as follows: DOCUMENTS REQUESTED The document Defendant acknowledges receiving from Plaintiff on December 4, 2013, stating "Any and all records disposition documents relative to the destruction of any and all public records during the period of January 1, 2013 through to the date when you substantially responded to this Public Record Request," as referenced in paragraph twenty (20) of the Defendant's complaint. RESPONSE: Responsive document attached. 2. Any and all documents that were "gathered and made available to Plaintiff to pick up at the Town Hall, as communicated to Plaintiff on or about December 6, 2013," as referenced in paragraph twenty -three (23) of Defendant's answer. RESPONSE: Responsive documents have previously been identified in the answer to Interrogatory No. 11 and produced on June 30, 2014 by e-mail from the office of the undersigned to rwitmer(i,obovlelawfirm.com. Specifically, two PDFs of the 18 %: x 11 document and 5 8 % x 14 documents that the Town made available to Plaintiff on December 6, 2013 and that Plaintiff picked up from the Town on February 5, 2014 were attached to that e-mail. They are attached again as a courtesy. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by email to Ryan L. Witmer, Esquire, The O'Boyle Law Firm, PC, 1286 West Newport Center Drive, Deerfield Beach, FL 33442 (rwitmeraoboylelawfirm.com) and Robert Sweetapple, Esquire, Sweetapple Broeker & Varkas, PL, 20 SE Third Street, Boca Raton, Florida 33432 ( pleadings(a,,sweetapplelaw.com) this 19'h day of September, 2014. JONES, FOSTER, JOHNSTON & STUBBS, P.A. Attorneys for Defendant Town of Gulf Stream 505 South Flagler Drive, Suite 1100 Post Office Box 3475 West Palm Beach, FL 33402 -3475 Telephone: (561) 659 -3000 Facsimile:f3fkl) 65p -5300 p: \dots \13147 \00047 \pld \1k60738.docx John ¢/Randolph Florida Bar No. 129000 irandolvh@ionesfoster.com Joanne M. O'Connor Florida Bar No. 0498807 ioconnor a,ionesfoster.com\ TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail October 28, 2014 Asset Enhancement, Inc. [mail to: records @commerce - group.com] Re: GS #1548 (921) Provide a copy of the request to produce from O'Hare as set forth on the August 31, 2014 Jones, Foster billing (Invoice #174285) with a billing date of 812312014. Please also provide all responsive documents and all communications regarding the aforementioned request to produce from O'Hare and/or the responsive documents. Dear Asset Enhancement, Inc. [mail to: recordsacommerce- groun.coml, The Town of Gulf Stream received your public records requests on October 2, 2014. You should be able to view this request at the following link: htto://www2.eulf- stream. ore,/ WebLink8 /0 /doc /22836/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 number. The Town may incur expenses for the production of documents. You are responsible for the costs of duplication, as allowed by Chapter 119, Florida Statutes, and you may also incur a special service charge for the labor needed to respond to this request. The Town is producing the referenced request to produce and the response thereto including all responsive documents produced. To the extent that you seek "all communications regarding the aforementioned request to produce ", the Town of Gulf Stream estimates the need for 1 hour of administrative support at $39.23 per hour, and Jones, Foster estimates the need for 1 hour of attorney support at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). If the costs of producing these documents will exceed your deposit, the Town will provide you with an initial production of responsive records and an estimate for the production of any additional responsive records. If the costs of production are less than the deposit, the Town will provide you with the responsive records and a refund. If you would like to narrow the scope of your request, for example, by identifying a particular document type or date range, the Town may be able to provide these records at a lower cost. (1 hours @ 39.23 = 39.23) - (.25 hour @ 39.23= 9.81) + (1 hours @ $235.00= 235.00) _ Deposit Due: $264.42 in cash or check. The Town of Gulf Stream is currently working on a large number of incoming public records requests. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. Sincerely, Town Clerk