HomeMy Public PortalAboutPRR 14-1609RECORDS REQUEST (the "Request ")
Date of Request: 111512014
Requestor's Request ID#:
944
REQUESTEE: Custodian of Records Town of Gulf Stream
REQUESTOR: STOPDIRTYGOVERNMENT, LLC
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 all text messages sent or received by Joanne O'Connor at the
deposition of Chris O'Hare which was held on October 24, 2014.
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
November 6, 2014
Stopdirtygovernment, LLC [mail to: records @commerce- group.com]
Re: GS #1609 (944)
Provide a copy of all text messages sent or received by Joanne O'Connor at the deposition of
Chris O'Hare which was held on October 24, 2014.
Dear Stopdirtygovemment, LLC [mail to: records @commerce- uroun.coml,
This letter is in response to the public records you have requested which we received November
5, 2014. Your original requests can be found at the following link httl)://www2.gulf-
stream.org/WebLink8/0/doc/27974/PaLzel.asi)x.
Be advised that no such records exist.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records
Kelly Avery
From: OConnor, Joanne M. <JOConnor @jonesfoster.com>
Sent: Friday, October 24, 2014 12:08 PM
To: Bill Thrasher
Cc: Kelly Avery
Subject: PRR 1247/765
IMO
Does Gulf Stream have a noise ordinance?
Joanne
Sent from my Whone
Kelly Avery
From: OConnor, Joanne M. <JOConnor @jonesfoster.com>
Sent: Friday, October 24, 2014 3:53 PM
To: Kelly Avery
Subject: Text message
Attachments: photo.PNG; ATT00001.txt
Sent from my iPhone
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Kelly Avery
From: Bill Thrasher <bthrasher @gulf - stream.org>
Sent: Friday, October 24, 2014 2:47 PM
To: OConnor, Joanne M.
Subject: RE: PRR 1020
J,
Yes, employee and family coverage. It is part of the overall "benefit" package for employees.
To my knowledge there aren't individual written "policy" provided. Kelly will be providing you /yours with a copy of the
certificate made out to Town. It is a coverage that exist while an individual is employed by the Town and doesn't extend
to post employment unless the employee chooses to pay for it themselves.
- - - -- Original Message---- -
From: OConnor, Joanne M. [ mailto :JOConnor @jonesfoster.comj
Sent: Friday, October 24, 2014 2:41 PM
To: Bill Thrasher
Cc: Kelly Avery
Subject: PRR 1020
We have a request re any life insurance policy issued by Standard insurance and paid for by the town in 2013. Do we
have life insurance policies for employees paid for by the town?
Sent from my iPhone
Kelly Avery
From: OConnor, Joanne M. <JOConnor @jonesfoster.com>
Sent: Friday, October 24, 2014 1:24 PM
To: Vrenda Cain
Cc: Randolph, John C.; Macfarlane, Mary
Subject: Re: Motion for Summary Judgment Issues
I need you to provide at least the general basis for disqualification before we can make a decision regarding next week's
hearing.
Sent from my iPhone
On Oct 24, 2014, at 12:46 PM, "Vrenda Cain" <vcainPoboylelawfirm.com> wrote:
Joanne-
I wanted to reach out to you and let you know that based on the advice of our counsel, we are going to
immediately need to file a motion to continue the hearing on summary judgment next Friday, as our
firm will be filing for a motion to disqualify Jones Foster from all of the cases in which we are involved. I
will get the motion to continue and the motion to disqualify in as quickly as possible. As a result, unless
Jones Foster is agreeable to this continuance, we will need to set a date on next week's calendar for us
to attend UMC on this matter. Please let me know what dates you are available for UMC next week. I am
truly sorry for any inconvenience and will get you over both motions on or before Monday.
Vrenda Cain
The O'Boyle Law Firm P.C.
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Telephone : 754- 212 -4219
Fax : 754- 212 -2444
Email: vcain@obovlelawfirm.com
Kelly Avery
From:
Vrenda Cain <vcain @oboylelawrirm.com>
Sent:
Friday, October 24, 2014 12:45 PM
To:
OConnor, Joanne M.
Subject:
Motion for Summary Judgment Issues
Joanne-
I wanted to reach out to you and let you know that based on the advice of our counsel, we are going to immediately
need to file a motion to continue the hearing on summaryjudgment next Friday, as our firm will be filing for a motion to
disqualify Jones Foster from all of the cases in which we are involved. I will get the motion to continue and the motion
to disqualify in as quickly as possible. As a result, unless Jones Foster is agreeable to this continuance, we will need to set
a date on next week's calendar for us to attend UMC on this matter. Please let me know what dates you are available for
UMC next week. I am truly sorry for any inconvenience and will get you over both motions on or before Monday.
Vrenda Cain
The O'Boyle Law Firm P.C.
1286 West Newport Center Drive
Deerfield Beach, FL 33442
Telephone : 754- 212 -4219
Fax : 754-212-2444
Email: vcain @oboylelawfirm.com
Kelly Avery
From: Bill Thrasher <bhrasher @gulf - stream.org>
Sent: Friday, October 24, 2014 2:47 PM
To: OConnor, Joanne M.
Subject: RE: PRR 1020
Yes, employee and family coverage. It is part of the overall "benefit" package for employees.
To my knowledge there aren't individual written "policy" provided. Kelly will be providing you /yours with a copy of the
certificate made out to Town. It is a coverage that exist while an individual is employed by the Town and doesn't extend
to post employment unless the employee chooses to pay for it themselves.
- - - -- Original Message---- -
From: OConnor, Joanne M. [ mailto :JOConnor @jonesfoster.comj
Sent: Friday, October 24, 2014 2:41 PM
To: Bill Thrasher
Cc: Kelly Avery
Subject: PRR 1020
We have a request re any life insurance policy issued by Standard insurance and paid for by the town in 2013. Do we
have life insurance policies for employees paid for by the town?
Sent from my iPhone
Kelly Avery
From: OConnor, Joanne M. <JOConnor @jonesfoster.com>
Sent: Friday, October 24, 2014 1:47 PM
To: Kelly Avery
Subject: Today
Can we talk about 3pm today re complaint I sent you yesterday and our response?
Sent from my Whone
Kelly Avery
From:
Kelly Avery <kavery@gulf - stream.org>
Sent:
Friday, October 24, 2014 12:22 PM
To:
OConnor, Joanne M.
Subject:
RE: PRR 913, 914, 915, 919
I answered 915 & 919, but haven't heard anything for responses on 913 & 914.
KeUy ,4 very
Deputy Clerk
Town of Gulf Stream
100 Sea Rd.
Gulf Stream, FL 33483 -7427
561 -276 -5116
561- 737 -0188 fax
(NverilC qaQ- rlre�
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: OConnor, Joanne M. [mailto:JOConnor @jonesfoster.com]
Sent: Thursday, October 23, 2014 9:43 PM
To: Kelly Avery
Subject: PRR 913, 914, 915, 919
Do you need anything more on these?
Kelly Avery
From: Bill Thrasher <bhrasher @gulf - stream.org>
Sent: Friday, October 24, 2014 2:57 PM
To: OConnor, Joanne M.
Subject: RE: PRR 1020
I have told Kelly.
- - - -- Original Message---- -
From: OConnor, Joanne M. [ mailto :JOConnor @jonesfoster.com]
Sent: Friday, October 24, 2014 2:53 PM
To: Bill Thrasher
Cc: Kelly Avery
Subject: Re: PRR 1020
I don't need to see it but we need to produce "the first page indicating the name of the insured" of any such policy -just
if issued by standard
Sent from my iPhone
> On Oct 24, 2014, at 2:49 PM, "Bill Thrasher" <bthrasher @gulf - stream.org> wrote:
> J,
> Yes, employee and family coverage. It is part of the overall "benefit" package for employees.
> To my knowledge there aren't individual written "policy" provided. Kelly will be providing you /yours with a copy of the
certificate made out to Town. It is a coverage that exist while an individual is employed by the Town and doesn't extend
to post employment unless the employee chooses to pay for it themselves.
>B
> - - - -- Original Message---- -
> From: OConnor, Joanne M. [ mailto :JOConnor @jonesfoster.com]
> Sent: Friday, October 24, 2014 2:41 PM
> To: Bill Thrasher
> Cc: Kelly Avery
> Subject: PRR 1020
> We have a request re any life insurance policy issued by Standard insurance and paid for by the town in 2013. Do we
have life insurance policies for employees paid for by the town?
> Sent from my iPhone
Kelly Avery
From: OConnor, Joanne M. <JOConnor @jonesfoster.com>
Sent: Friday, October 24, 2014 2:41 PM
To: Bill Thrasher
Cc: Kelly Avery
Subject: PRR 1020
We have a request re any life insurance policy issued by Standard insurance and paid for by the town in 2013. Do we
have life insurance policies for employees paid for by the town?
Sent from my iPhone
Kelly Avery
From: Bill Thrasher <bthrasher @gulf - stream.org>
Sent: Friday, October 24, 2014 1:24 PM
To: OConnor, Joanne M.
Subject: RE: PRR 1247/765
Joanne,
Only for generators. Nothing overall. Verification of the dba level seemed problematic for our staff size.
MR
- - - -- Original Message---- -
From: OConnor, Joanne M. [mailto:JOConnor @jonesfoster.com]
Sent: Friday, October 24, 2014 12:08 PM
To: Bill Thrasher
Cc: Kelly Avery
Subject: PRR 1247/765
OW
Does Gulf Stream have a noise ordinance?
Joanne
Sent from my iPhone
Kelly Avery
From: OConnor, Joanne M. <JOConnor @jonesfoster.com>
Sent: Friday, October 24, 2014 12:19 PM
To: Kelly Avery
Subject: PRR 1354
Why not give them the date the temp was hired and then tell them that all public records since that date are available
online
Sent from my iPhone
OConnor, Joanne M.
From:
Sent:
To:
Subject:
Attachments:
Kelly Avery
Deputy Clerk
Town of Gulf Stream
100 Sea Rd.
Gulf Stream, Fl. 33483 -7427
561- 276 -5116
561- 737 -0188 fax
kPLn @4ulf sir "M,
Kelly Avery <kavery@gulf- stream.crg>
Friday, October 24, 201412:29 PM
OConnor, Joanne M.
RE: PRR 905, 907, 908
GS #1532 (905)_clarify.docx
Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended reciplent(s). If
you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original
message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business
are public records available to the public upon request. Your e-mail communications are therefore subject to public
disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in
response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in
writing.
From: OConnor, Joanne M. imailtoJOConnorPlonesfoster .coml
Sent: Thursday, October 23, 2014 9:45 PM
To: Kelly Avery
Subject: PRR 905, 907, 908
REDACTED PER FLA. STAT.119.071(1)(d)1
1
Town of GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via a -mail
October 24, 2014
Martin E. O'Boyle [Mail to: records @commerce - group.com]
Re: GS 91532 (905)
Provide a copy of the inquiry, Re: Response to public records request as shown on the Jones,
Foster bill (entry date 81412014). The bill is dated August 31, 2014 and it is Invoice number
174284.
Dear Martin E. O'Boyle (Mail to: records @commerce - group.com],
This letter is in response to the public records you have requested in your email received October
2, 2014. This correspondence is reproduced at the following link: htti)://www2.galf-
stream. ore/ WebLink8 /0 /doc/22820/Paeel.asox.
You have failed to sufficiently identify the documents that you seek with reasonable particularity
that would allow the Town to identify responsive public records. This letter requests clarification
of your request before determining whether to provide you with an estimate of deposit for the
extensive use of information technology resources or extensive clerical or supervisory assistance
as described in Fla. Stat. § 119.07(4)(d). This request for clarification is done as a courtesy to
you to ensure the Town is able to accurately and promptly provide you with either an estimate, if
necessary, or production of the public records you seek.
Please clarify the above request as indicated and the Town of Gulf Stream will proceed with
fulfilling your request, or providing you an estimate of the cost of production based on your
clarification.
Sincerely,
Town Clerk
Custodian of the Records
OConnor, Joanne M.
From: Bill Thrasher <bthrasher @gulf- stream.org>
Sent: Friday, October 24, 20142:22 PM
To: OConnor, Joanne M.
Subject: RE: PRR 1247/765
We do have an ordinance to control generator noise, dba rating criteria. Kelly would normally provide the link
to municode on the Town's website to such PRRs.
We have other codes that do not attempt to control noise levels but restricts the type of work activity, such as
jack hammering and pile driving, that can occur during the "season ". Although they do not use any dba ratings
as a control barometer, they do restrict/prohibit that sort of noise producing work activities. These ordinances
are also found in our code located on the Town's website.
— Original Message —
From: OConnor, Joanne M. f maiito :JOConnor(cDionesfoster.coml
Sent: Friday, October 24, 20141:45 PM
To: Bill Thrasher
Cc: Kelly Avery
Subject: Re: PRR 1247/765
There is a request for "any laws which restrict or limit sounds which emanate from residential property in Gulf
Stream."
Sent from my iPhone
> On Oct 24, 2014, at 1:26 PM, "Bill Thrasher" <bthrashernc.culf- stream.om> wrote:
> Joanne,
> Only for generators. Nothing overall. Verification of the dba level seemed problematic for our staff size.
> Bill
> — Original Message -
> From: OConnor, Joanne M. f mailto :JOConnor(cDionesfoster.coml
> Sent: Friday, October 24, 201412:08 PM
> To: Bill Thrasher
> Cc: Kelly Avery
> Subject: PRR 1247 1765
> Bill -
> Does Gulf Stream have a noise ordinance?
> Joanne
REDACTED PER FLA. STAT. 119.071(1)(d)1
OConnor, Joanne M.
From:
OConnor, Joanne M.
Sent:
Friday, October 24, 2014 12:15 PM
To:
kavery@gulf- stream.org
Subject:
PRR 1258/776
Sent from my iPhone
REDACTED. PER FLA. STAT. 119.071(1)(d)1
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via a -mail
November 21, 2014
Stopdirtygovernment, LLC [mail to: records @comerce - group.com]
Re: GS #1609 (944)
Provide a copy of all text messages sent or received by Joanne O'Connor at the deposition of
Chris O Hare which was held on October 24, 2014. Amended 1116114 - Please amend Request
#944 to include E -Mails as well as text messages.
Dear Stopdirtygovemment, LLC [mail to: recordsna,comerce- erouo.coml,
This letter provides you with the full production of public records you originally requested on
November 5, 2014 and amended on November 6, 2014. Your original request can be viewed at
the following link http: / /www2.gulf- stream. org/ WebLink8 /0 /doc /27974/Paeel.asyx.
The responsive documents for your request can be found at the same link. Be advised that exempt
information has been redacted from the documents attached pursuant to Fla. Stat. 119.071(1)(d)
because that information reflects the mental impressions and work product of Ms. O'Connor. The
exempt information here relates to pending and reasonably anticipated imminent litigation
involving the Town, William Thrasher, Garrett Ward, Scott Morgan and Robert Sweetapple, on
the one hand, and Martin O'Boyle and entities controlled by or affiliated with him including, but
not limited to, Commerce GP, Inc., the Commerce Group, Inc., Commerce Realty Group, Asset
Enhancement, Inc., CG Acquisition Company, Inc., Citizens Awareness Foundation, Inc., Airline
Highway, LLC, N984AC Caravan LLC, CRO Aviation, Inc., and STOPDIRTYGOVERNMENT,
LLC., and Christopher O'Hare, on the other hand.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records