HomeMy Public PortalAboutPRR 14-1671RECORDS REQUEST (the "Request ")
Date of Request: 12/17/2014
Requestor's Request ID #:
959
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 all billings and payments from and to the law firm of Sweetapple,
Broeker & Varkas, P.L. (including Robert Sweetapple singularly) for the billing period
November. 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 e-mail
December 19, 2014
Asset Enhancement, Inc. [mail to: records @commerce - group.com]
Re: GS #1671 (959)
Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker &
Varkas, P.L. (including Robert Sweetapple singularly) for the billing period November, 2014.
Dear Asset Enhancement, Inc. [mail to: records(&commerce- grouo.coml,
The Town of Gulf Stream received your public records request on December 17, 2014. If your
request was received in writing, then the request can be found at the following link
http: / /www2.gulf- stream. ore/ WebLink8 /0 /doc /31647/Pagel.asyx. 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
Sweetapple, Broeker, Varkas, P.L.
20 South East 3rd. Street
Boca Raton, FL 33432
Telephone: (561)392-1230
Fax: (561)394-6102
TOWN OF GULF STREAM
►PAYMENT APPROVED-4
Town of Gulf Stream
100 Sea Road
Gulf Stream, FL 33483
November 21, 2014
Invoice No. 10216
Client Number: 00949 Town of Gulf Stream
Matter Number: 1679 O'Boyle vs. Town of Gulf Stream
For Services Rendered Through 11/21/2014.
Fees
Date
Tmknr
Description
Hours Amount
10/22/2014
RS
Conference with Scott regarding new public records request;
2.20 $770.00
Conference with Joanne; Prepare for O'Hare deposition; Review
all documents regarding O'Hare; Conference with Morgan's
counsel.
10/2212014
RS
Conference with Scott; Conference with A. Varkas; Call to
2.00 $700.00
Chandler; Prepare for O'Hare's deposition.
10/22/2014
DV
Complete index of deposition testimony for R. Sweetapple.
2.60 $520.00
10/24/2014
AV
Attend deposition of Chris O'Hare.
6.00 $2,100.00
10/24/2014
RS
Travel and take O'Hare deposition.
6.00 $2,100.00
10/25/2014
RS
Conference with Scott; Receive and review entails; Meeting with
1.00 $350.00
law clerk regarding projects (O'Boyle and O'Hare).
10/26/2014
RS
Review Chandler's edits.
0.20 $70.00
10/27/2014
RS
Revise Motion; Call to Chandler; Conference with Joanne; Review
1.30 $455.00
litigation privilege regarding RICO, state and federal; Prepare for
conference with Gerry.
10/272014
DV
Research statutes and case law re: MOB'S banners.
0.80 $160.00
10282014
RS
Conference with clerk; Review O'Hare website.
0.50 $175.00
Continued On Next Page
Client Number: 00949
Matter Number: 1679
11212014
Page: 2
10282014 RS
Conference with Joanne, Gerry and Scott regarding pending cases;
1.75 $612.50
Work on files, Conference with Chandler; Call to opposing
counsel.
10282014 AV
Westlaw search;Draft and revise motion.
1.00 $350.00
10292014 RS
Research regarding fee entitlement; Proposal for settlement; Read
1.60 $560.00
Morgan's letter and latest documents request; Multiple emails with
opposing counsel.
10/302014 RS
Work on request to produce; Conference.
0.30 $105.00
10/31/2014 RS
Conference with Morgan, Chandler and Joanne; Conference with
1.60 $560.00
A. Varkas regarding disqualification and 57.105 letters and emails
with opposing counsel; Meeting with law clerk regarding research.
10/312014 AV
Draft motion 57.105; Demand letter; Revise response to motion to
1.50 $525.00
disqualify, notice of filing motion; Westlaw search procedure.
10/31/2014 AV
Draft motion 57.105; Demand letter; Revise response to motion to
1.50 $525.00
disqualify, notice of filing motion; Westlaw search procedure.
(O'Hare).
10/3112014 AV
Draft request to produce to Plaintiff O'Hare.
0.50 $175.00
11/022014 RS
Conference with Scott (Sat) ;Prepare request to produce regarding
1.50 $525.00
RICO claims; Emails. .
11103/2014 RS
Prepare multiple emails to opposing counsel; Work on RICO suit;
1.50 $525.00
Conference with Scott; Conference with law clerk regarding
project.
11/032014 RS
Work on O'Hare request and 57.105 package; Conference with G.
1.25 $437.50
Richman; Work on O'Boyle 57.105 package; Work on O'Hare
57.105 package.
11/042014 RS
Prepare letter and notice; Conference.
0.30 $105.00
11/052014 RS
Review extensive request to produce from O'Boyle; Conference
0.60 $210.00
with opposing counsel.
1 1/05/2014 RS
Meeting with law clerk; Work on RICO case.
0.70 $245.00
11/052014 RS
Conference with Scott and Chandler; Receive and review emails;
2.00 $700.00
Conference regarding RICO and work on discovery request.
11/07/2014 RS
(11/7/14 - 1 1/9/14) Conferences and emails. Review article and
1.60 $560.00
work on discovery.
11/102014 RS
Conference with Email. Work on RICO. Work on and
2.75 $962.50
review responses to request to produce. Conference with Scott
Morgan.
11/112014 RS
Conference with co- counsel and Scott Morgan and Clerk
0.40 $140.00
Continued On Next Page
Client Number: 00949
Matter Number: 1679
11/21/2014
Page: 3
11/12/2014 RS
Conference with Gerry Richman, Joanne O'Connor and Scott
1.50 $525.00
Morgan regarding and strategy on RICO suit.
Work on discovery for RICO suit.
11/13/2014 RS
Meet with law clerk regarding settlement proposal and strategy.
1.60 $560.00
Initial review of NJ transcript and witness conference. Revise
motion.
11/13/2014 RS
(O'Hare) Conference with Paul Nicoletti. Prepare affidavit and
0.70 $245.00
letter.
11/17/2014 DV
Conference w. Robert Sweetapple and Alexander Varkas re: status
0.10 $20.00
and responsive motion.
11/17/2014 RS
Conference re: all pending cases
0.25 $87.50
11/17/2014 RS
Conference with co- counsel; prepare for hearing
0.70 $245.00
11/18/2014 RS
Prepare, travel and attend hearing. Meeting with Joanne O'Connor.
3.00 $1,050.00
Conference with Scott Morgan. Meet with David Vitale regarding
R. Sweetapple appearance on alletter O'Boyle and O'Hare matters.
Meeting with Gerry Richman re: drafting RICO case; conference
woth co- counsel.
11/18/2014 RS
Conference w. Gerry Richman re: Berger settlement conference.
0.20 $70.00
11/18/2014 RS
Work on lawsuits (eve); Review pending cases to appear
0.50 $175.00
11/18/2014 DV
Conference w. R. Sweetapple re: motion to disqualify
0.20 $40.00
11/18/2014 DV
Conference with R. Sweetapple re: case status
0.50 $100.00
11/19/2014 RS
Receipt and review of entails. Conference with Joanne O'COnnor
0.75 $262.50
and law clerk re:
and strategy.
11/19/2014 RS
Receipt and review of entails; conference with Joanne O'Connor
0.50 $175.00
and Scott Morgan
11/20/2014 DV
Index Martin O'Boyle deposition from prior case per R.
2.00 $400.00
Sweetapple; create word document in support.
1 120/2014 DV
COnference call with R. Sweetapple, G. Richman, J. O'Connor and
0.60 $120.00
S. Morgan
11/21/2014 RS Conference with Scott Morgan; Conference with law clerk re: 1.25 $437.50
Motion to Compel and Request to Produce in sanctions case. Work
on O'Hare cases.
11/21/2014 DV Parse O'Hare deposition for facts /material to be inserted into 2.30 $460.00
responsive motion to disqualify; Insert into A. Varkas's initial draft
abd print for A. Varkas's review.; Conference with Cynthia Bailey
re: request for expedited hearing per R. Sweetapple's instruction
Continued On Next Page
Client Number: 00949
Matter Number: 1679
Cost Detail
113—te Description
10/272014 Postage - October 2014
10272014 Photocopy Charges - October 2014
Billable Hours / Fees:
Total Costs
11/21/2014
Page: 4
61.60 520,195.00
Amount
$2.88
8.00
$10.88
Check No.
Prior Balance:
Payments Received:
$24,352.50 Last Payment: 10272014
($24,352.50)
Current Fees:
$20,195.00
Advanced Costs:
510.88
TOTAL AMOUNT DUE: 520,205.88
PLEASE REMIT TO: S WEETAPPLE. BROEKER & VARKAS. P.L.
20 S.E. 3rd. STREET, BOCA RATON, FL 33432
PLEASE INDICATE INVOICE NUMBER ON CHECK. THANK YOU!
Bill Thrasher
From: Cynthia Bailey <cbailey @sweetapplelaw.com>
Sent: Friday, November 21, 2014 3:28 PM
To: Bill Thrasher
Subject: Town of Gulf Stream
Attachments: Invoice 10216.pdf
Mr. Thrasher,
Attached please find invoice no. 10216 for your review. Thank you.
CYNTHIA J. BAILEY
Certified Paralegal /Florida Certified Paralegal /Florida Registered Paralegal
Sweetapple, Broeker & Varkas, P.L.
20 SE P Street
Boca Raton, FL 33432
(561) 392 -1230 (t) x. 305
(561) 394 -6102 (f)
cbailev@sweetapplelaw.com
STATEMENT OF CONFIDENTIALITY
The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this
message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate,
maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this
message to any person other than the intended recipient(s) is not intended in any way to waive privilege or
confidentiality.
W
TOWN OF GULF STREAM OPERATING ACCOUNT
To. SWLET.APPLE, BROEKFR 3 VARKAS. P.L.
20 S.E. 3rd STREET
BOCA RATON, FL 33432
12470
11/25/2014
INVOICE DATE DESCRIPTION AMOUNT
10216 11,212014 Oct -Nov $20,205.88 •50.00 $20,205.88
Totals: $20,205.88 $0.00 $20,205.88
TOWN OF GULF STREAM SUNTRUST BANK
OPERATING ACCOUNT 63- 215/631
100 SEA ROAD
GULF STREAM, FL 33483 -7427
(561) 276 -5116
00949
PAY "Twenty thousand two hundred five and 88/100 Dollars"
TO THE
ORDER
OF SWEETAPPLE, BROEKER 8, VARKAS, P.L.
20 S.E. 3rd STREET
BOCA RATON, FL 33432 4,0 wl
CNUINE C
l•o
I AUMRIMDEIG URE
"'0 L 24 70,10
I FRAUD 12470
\•] ARMOR'
CHECK DATE CHECK NO.
11/25/2014 12470
i
CHECK AMOUNT
E
$" 20,205.88 IT
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TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via c -mail
January 6, 2015
Asset Enhancement, Inc. [mail to: records @commerce- group.com]
Re: GS #1671 (959)
Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker &
Varkas, P.L. (including Robert Sweetapple singularly) for the billing period November, 2014.
Dear Asset Enhancement, Inc. [mail to: recordsOcommerce- erouo.coml,
The Town of Gulf Stream has received your public records requests dated December 17, 2014. If
your request was received in writing, then the requests can be found at the following link
htty: / /www2.gulf- stream. ore/ WebLink8 /0 /doc /31647/Pagel.mxx. If your request was verbal,
then the description of your public records request is set forth in the italics above. Please refer to
the referenced number above with any future correspondence.
The responsive documents can be found at the same link. As reflected on the attached record,
exempt information has been redacted pursuant to Fla. Stat. § 119.071(1)(d). A public record that
was prepared by an agency attorney or at the attorney's express direction for imminent or ongoing
litigation that relates to counsel's mental impression, conclusion, legal strategy, or legal theory is
exempt pursuant to Fla. Stat. § 119.071(1)(d). 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, hic., Citizens
Awareness Foundation, Inc., Airline Highway, LLC, N984AC Caravan LLC, CRO Aviation, Inc.,
and STOPDIRTYGOVERNMENT, LLC., and Christopher O'Hare, on the other hand. Please also
note that the checking account number has been redacted pursuant to Fl. Stat. 119.071 (5)(b).
We consider this matter closed.
Sincerely,
Town Clerk, Custodian of the Records