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Home My Public Portal AboutPRR 14-1629From: Wyatt Burp [mailto:ok.coral.records @gmail.com) Sent: Wednesday, November 12, 2014 5:28 PM To: Bill Thrasher Subject: RICO records - morgan, orthwein - Public Record Request THIS IS A PUBLIC RECORDS REQUEST Made on this 12th day of November, 2014 I make this request as per Article 1, Section 24 of the Florida Constitution and Chapter 119.07 of the Florida Statutes Records requested: The three most recent journal entries, notes, memos, emails, text messages or letters created by either Mayor Morgan or Commissioner Othwein that include the word RICO. If any part of these records, are exempt from inspection or disclosure please cite the specific exemption as required by &119.07(1)(f) of the Florida Statutes. Your affirmative obligation, as per 6119.07(c) Florida Statues is 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 officers or employees within the agency whether such a record exists and, if so, the location at which the record can be accessed." I request 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.lf the public records being sought are maintained by your agency in an electronic format please produce the records in the original electronic format in which they were created or received, refer to 6119.01(2)(f), Florida Statutes. If you anticipate the production of these public records to exceed $2.00 please notify requester in advance of the record production with a written estimate of the total cost. Itemize any estimates indicating the total number of pages and /or records, and distinguish the cost of labor and materials. Notify me immediately prior to any action by you that would cost to requester more than $2.00. Respond to requester at: ok.coral.records @smail.com TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 15, 2014 Wyatt Burp [mail to: ok.coral.records @gmail.com] Re: GS #1629 (RICO records - morgan, orthwein) The three most recent journal entries, notes, memos, emails, text messages or letters created by either Mayor Morgan or Commissioner Orthwein that include the word RICO Dear Wyatt Burp [mail to: ok.coral.records @ gmail.coml, The Town of Gulf Stream received your public records request on November 12, 2014. If your request was received in writing, then the request can be found at the following link: http: / /www2.gulf- stream. oryJWebLink8 /0 /doc /28656/Pagel.asoxx. 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 Kelly Avery From: Scott Morgan <scottmorgan75 @gmail.com> Sent: Wednesday, November 05, 2014 4:41 PM To: Gerald Richman; OConnor, Joanne M.; Robert Sweetapple Subject: Miami Beach inquiry into RICO case Gerry, The Town of Gulf Stream received a call from a paralegal for the City of Miami Beach re: the Coastal Star article and our intention to file a RICO case. This may or may not be in response to my telephone call to their mayor. Perhaps you could have Leora contact this paralegal to see what information they have on O'Boyle's case against Miami Beach (or anything else that might be useful to us). BRETT BECKER, PARALEGAL OFFICE OF CITY ATTORNEY 1700 CONVENTION CENTER DR. MIAMI BEACH, FL 33139 TEL: 305- 673 -7000 X 6409 EMAIL: BRETTBECKER(@M IAM I BEACH FL.GOV Thanks. Scott W. Morgan 1315 Neptune Dr. Boynton Beach, FL 33426 (561) 752 -1936 From: Scottmorgan75 @gmail.com [mailto:scottmorgan75 @gmail.com] Sent: Wednesday, October 22, 2014 3:01 PM To: Kelly Avery <kavery@gulf- stream.org> Subject: Mayor's letter to Residents Kelly, Please find attached a letter to be copied and mailed to all Gulf Stream residents. Thank you. Scott W. Morgan Sent from Windows Mail October 22, 2014 Dear Gulf Stream Residents, I am pleased to report that the South phase of our underground wiring project has been completed. All residents in the South section of Gulf Stream are now connected to the underground system. Landscape and streetscape repairs will be completed by the contractor within 30 days, and the final as -built construction drawings will be submitted to FPL, a requirement for FPL to remove their poles. The North half of the project will begin shortly, as a proposal from FPL is expected by the end of the month, and then Gulf Stream can evaluate bids to complete this final phase of the underground project. By way of update on our legal challenges, the Town of Gulf Stream is currently defending 12 Public Records lawsuits brought by Martin O'Boyle (or related entities) and 20 Public Records lawsuits brought by Chris O'Hare (or related entities) and 1 lawsuit brought by both O'Boyle & O'Hare. In addition, we have been sued in 8 other lawsuits by O'Hare and/or O'Boyle for, among other things, alleged slander and civil rights violations. Deposition testimony has been taken of several Town representatives, as well as a lengthy all -day questioning of Mr. O'Boyle. The transcripts of testimony will shortly be posted on -line at our Town website so that anyone interested in these matters can easily have access to the testimony. Mr. O'Boyle's deposition was also videotaped, and we will be posting either that video in total, or a link to the video, on the Town's website, as well. Legal fees charged by the Jones Foster law firm since January 2014, total approximately $370,000.00. Legal fees charged by special counsel Robert Sweetapple, Esq., total approximately $102,000.00. The Jones Foster fees include some typical legal services for Commission and ARPB meeting advice but the overwhelming bulk of those fees went toward defending the many O'Boyle and O'Hare lawsuits and on advising the Town regarding issues created by O'Boyle and O'Hare (including, but by no means limited to, control over intracoastal canal mooring; "sober house" and disabled person accommodations; security equipment and procedures for staff protection; regulating the private use of Town property, especially parking lots; and addressing indoor air quality complaints about Town buildings). Our attorneys have also rendered legal advice and services on defamation lawsuits filed by O'Boyle against Town officials (including one against our attorney, Robert Sweetapple) and in trying to protect a number of our residents, whom O'Boyle has, in my opinion, tried to intimidate and harass with subpoenas for the taking of their deposition testimony. I have asked the attorneys to take every step necessary to protect our residents from what seems to me to be an execrable attempt by O'Boyle to involve them in his lawsuits. Regarding the above - mentioned security equipment, the Town unfortunately has been forced to install an automatic door lock with audio /video monitoring on the doorway into staff offices. In years past, one of the wonderful things about Gulf Stream was the ease with which any resident could just walk into Town Hall and speak with the clerks. Now, as a result of Mr. O'Boyle's repeated disruptive behavior inside Town Hall, and because of reports of O'Boyle's inappropriate behavior toward some of our female staff, we felt it necessary to add security measures to protect our employees and to preserve some level of order and office decorum. As a result, you now will need to be announced and electronically buzzed into the offices to speak with Rita Taylor or Bill Thrasher, to submit documents, obtain vehicle stickers, or conduct any other public business. I am truly sorry this step had to be taken but am certain all of you understand and appreciate the reasons why. During the litigation of several of the public records cases, our lawyers learned that O'Boyle's public records requests and lawsuit activity have primarily been conducted through a law firm and non -profit company, which, in their opinion, was acting fraudulently and in concert as part of a money - making scheme. The public records lawsuits filed against Gulf Stream look to be part of a larger pattern of lawsuits being filed against municipalities, other government agencies and contractors across the state. Our attorneys' legal opinion is that the actions of O'Boyle and others violate the United States federal Racketeer Influenced and Corrupt Organizations Act ( "RICO "), and so on October 10, 2014, the Town Commission unanimously retained the law firm of Richman & Greer, an experienced commercial litigation firm, to file a class action RICO lawsuit against all appropriate defendants in federal court. The action will seek certification of a class of plaintiffs led by Gulf Stream to recover all damages, including legal fees, against these defendants. I believe that a favorable judgment in this lawsuit will end the threat posed by these two men and allow our Town to return to normalcy. Very truly yours, Scott W. Morgan From: scottmorgan75Cabgmail.com Sent: Monday, October 13, 2014 1:16 PM To: grichmanCalrichmangreer.com Cc: rsweetaooleCalsweetaoolelaw.com Subject: RICO Action- O'Boyle Hi Jerry, Thank you for participating in our Town Commission meeting on Friday. As you know, the Commission voted unanimously to retain your firm to advance the federal class action RICO claims against O'Boyle, O'Hare and related entities and individuals. At your convenience, would you please send a representation letter to our town manager, William Thrasher, acknowledging the terms of your representation, which will be based on the 50% hourly /35 %contingency rate approved by the Commission. Mr. Thrasher's address is: TOWN OF GULF STREAM 100 SEA RD. GULF STREAM, FL 33483 Please feel free to speak with Bob Sweetapple or Joanne O'Connor regarding any information or assistance needed in preparing the Complaint. Best regards, Scott W. Morgan w -561- 752 -1936 c- 561 -573 -6006 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail August 25, 2015 Wyatt Burp [mail to: ok.coral.records@gmail.com] Re: GS #1629 (RICO records - morgan, orthwein) The three most recent journal entries, notes, memos, emails, text messages or letters created by either Mayor Morgan or Commissioner Orthwein that include the word RICO. Dear Wyatt Burp [mail to: ok.coral.recordsna,gnail.coml, The Town of Gulf Stream received your original public records request on November 12, 2014. You should be able to view your original request at the following link htto://www2.gulf- stream.ore/weblink/O/doc/28656/Pagel.asox. In future correspondence, please refer to this public records request by the above referenced numbers. The responsive documents for Mayor Morgan can be found at the same above link. There were no such records for Commissioner Orthwein. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records