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Home My Public Portal AboutPRR 15-1695RECORDS REQUEST (the "Request ") Date of Request: 1/7/2015 Requester's Request ID#: 971 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 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 LINUTATION, 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 Requester 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 January 7, 2015 Asset Enhancement, Inc. [mail to: records @commerce - group.com] Re: GS #1695 (971) Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker & Parkas, P.L (including Robert Sweetapple singularly) for the billing period beginning November 21, 2014 to the date of this request. Dear Asset Enhancement, Inc. [mail to: recordsna,commerce- eroup.coml, The Town of Gulf Stream received your public records request on January 7, 2015. If your request was received in writing, then the request can be found at the following link htty://www2.gulf- stream. org/ WebLink8 /0 /doc /33268/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 Sweetapple, Broeker & Varkas 20 SE 3rd Street Boca Raton, Fl 33432 Phone: 561-392-1230 1 Fax: 561-394-6102 Account Statement Prepared for Town of Gulf Stream Re: O'Boyle: O'Hare Previous Balance $0.00 Current Charges $26,150.00 New Balance $26,150.00 Adjustments $0.00 Payments $0.00 Now Due $26,150.00 Trust Account $0.00 TOWN OF GULF STREAM P' PAYMENT APPROVED .4 Amount 2L 50. Do BY W Datel K / Check # - 1053(, nnm r9h,Iid Sweetapple, Broeker & Varkas Town of Gulf Stream 100 Sea Road Gulf Stream, PL 33483 Attorney's Fees 20 SE 3rd Street Boca Raton, Fl 33432 Phone: 561-392-1230 1 Fax: 561-394-6102 INVOICE Invoice Date: December 19, 2014 Invoice Number: 10003 Invoice Amount: $26,150.00 Matter: O'Boyle: O'Hare 11/3/2014 Update request for production with R. Sweetapple's C.B. .30 $3750 changes and file; Finalize letter to M. Fianna enclosing 57.105 Motion and response. Email. 11/20/2014 Review email and response from Scott; Prepare B.S. 1.70 $595.00 request to produce; Outline in O'Boyle and O'Hare cases; Review emails including regarding — Conference with Joanne; on erence with Scott. 11/21/2014 Work on per R. Sweetapple's D.P.V. .40 $80.00 instructions and comments. 1 1/21/2014 Review and revise Town response to motion to A.D.V. .50 $175.00 disqualify R. Sweetapple. 11/22/2014 Edit first draft and outline additional facts in B.S. 1.00 $350.00 complaint. 11/23/2014 Review letter regarding expedited hearings. B.S. .10 535.00 11/25/2014 Receive and review letter and conferences. B.S. .60 $210.00 11/25/2014 Review amended motion by O'Hare; Conferences B.S. 1.20 $420.00 and case law. 1 1/26/2014 Revise all documents filed; Draft motion to strike B.S. .80 $280.00 verification. 11/26/2014 Prepare report to Scott regarding Prepare epositton notices; Work on 57.105 and O'Hare; Review request and supplement motion; Prepare letter to Berger and Hanna. 11/27/2014 Finn conference regardine motion to disqualify R. D.P.V. .10 $20.00 Sweetapple. Redacted per Fla. Stat. 119.071(1)(d) 11/28/2014 Receive and review letter; Revise O'Hare second B.S. .80 $280.00 request to produce; Initial review amended of motion of O'Hare. 11/330/2014 Conference with Scott; Outline all projects on all B.S. 4.20 $1,470.00 pending Gulfstream adv. O'Hare and O'Boyle cases; Prepare strategy regarding � Recerve an revtew tco letti letter and affidavit; Receive and review Berger's motion; Work on —. (Date 11/28). 12/1/2014 Meeting with client and paralegal regarding projects. B.S. 30 $105.00 (O'Hare). 12/1/2014 Meeting with client and A. Varkas regarding B.S. .50 $175.00 supplement and response; Conference regarding —. (O'Boyle). 12/1/2014 Meeting with A. Varkas regarding response to B.S. .75 $262.50 supplement; Conference with Joanne regarding strategy 12/1/2014 Firm conference regarding O'Hare and O'Boyle D.P.V. .30 $60.00 motions to disqualify; R. Sweetapple instructions regarding 12/1/2014 Review O oyes supplement to otton to A.D.V. 4.00 $1,400.00 Disqualify; Research issues evtew origtna otton to Pisqua ouse; Read and summarize case law and treatise. 12/2/2014 Receive and review O'Boyle resonse and letters; B.S. .90 $315.00 Conference with A. Varkas regarding our response to supplement. 12/2/2014 Index transcript/leasing (11/18/14) on schedule A.D.V. 3.50 $1,225.00 conference; Dictate the response to supplement to Motion to Disqualify Counsel. 12/3/2014 Draft response to supplement to Motion to C.B. 1.00 $125.00 Disqualify dictated by A. Varkas. (O'Boyle). 12/3/2014 Receive and review emails and conference regarding B.S. .75 $26250 Berger response and sanctions: Conference with D. Vitale regarding ease an 12/3/2014 Reviet A.D.V. .50 $175.00 12/3/2014 Meeting with B.S. .30 $105.00 12/4/2014 Revise draft oTTZ77ponse to Supplement. A.D.V. 1.50 $525.00 12/4/2014 Draft notice of filing per R. Sweetapple; Compare D.P.V. .70 $140.00 deposition testimony for exhibit on the notice regarding discrepancy; Conference with C. Bailey. 12/5/2014 Travel and attend meeting in all cases and work on B.S. 650 $2,273.00 new pleadings; Meeting with Eric, Gerry, Scott and Joanne at Gerry's office; Meeting with client regarding Redacted per Fla. Stat. 119.071(1)(d) 12/52014 Revise dratt one response to supp ement to Motion A.D.V. 1.00 5350.00 to Disqualify. 12/5/2014 Notice of filing preparation regarding deposition D.P.V. 550 $1,100.00 testimony; Travel to and from conference with client, Gerry, Joanne and R. Sweetapple. 12/6 /2014 Saturday: Conference with Scott regarding B.S. 1.60 $560.00 mediation and strategy; Conference with D. Vitale regarding perjury motion and Receive and review emails from week; Review article. 12/72014 Prepare for meeting with Joanne, Gerry and Scott; B.S. 1.20 $420.00 Review all projects; Revise response; Email. (Date 12/06). 12/8/2014 Westlaw search: Remedies for— i.e. A.D.V. 350 $1,225.00 (read case law and treatise); Draft Supple—ment to Amended Motion for Sanctions. 12/82014 Work on second motion for sanction - O'Boyle; B.S. .70 $245.00 Respond to supplement. 12/8/2014 Conference with Joanne regarding O'Hare; Email B.S. 1.10 $385.00 response regarding O'Boyle and law regarding disclosure to Berger by CAF (evening). 12/82014 Conference with opposing cousel; Prepare Motion B.S. .70 $245.00 regarding O'Hare; Review O'Hare response. 12/8/2014 Firm conference with R. Sweetapple regarding case D.P.V. 1.50 $300.00 and deposition testimony; Conference with A. Varkas; Research regarding —; Conference with . ar -as; ottce o filing research and drafting. 12/92014 Conference with R. Sweetapple and A. Varkas D.P.V. .40 $80.00 regarding Motion to Disqualify and related testimony; Receive instructions on drafting. 12/92014 Westlaw search: 1) Use of former deposition A.D.V. 1.50 5525.00 testimony (read treatise and case law) 2) Discovery while Motion to Dismiss pending; Discuss with R. Sweetapple bolstering Response to Supplement. 12/92014 Conference with Joanne; Review Hanna's filing; B.S. .70 $245.00 Revise response with clerk; Conference regarding sanction's motion with A. Varkas. 12/10 /2014 Conference with R. Sweetapple regarding unrelated D.P.V. 3.40 $680.00 party privilege; Conference with A. Varkas regarding same; Edit motion per R. Sweetapple instructions; Research attorney- client privilege; Review deposition transcript and hearing transcript; Review allegations in verified complaint and supplement; Complete draft for R. Sweetapple review. 12/102014 Conference with R. Sweetapple and edit response D.P.V. .30 $60.00 per his request; Prepare for final review. 12/102014 Conference with Hanna and Joanne regarding set B.S. 1.25 $437.50 Redacted per Fla. Stat. 119.071(1)(d) 12/11/2014 12/11/2014 12/11/2014 12/11/2014 12/11/2014 12/11/2014 12/11/2014 12/13/2014 12/12/2014 12/12/2014 12/13/2014 13/13/2014 12/15/2014 12/13/2014 12/16/2014 13/16/2014 12/17/2014 12/17/2014 12/18/2014 12/19/2014 12/19/2014 12/19/2014 SUBTOTAL: Costs SUBTOTAL: deposition Shelly O'Hare; Tentative deposition; Revise motion for expedite hearing regarding O'Hare. Receive and review email. Prepare response. Conference with Scott re meeting with and progress report. Meeting with Dave re contempt and perjury charges Martin O'Boyle. Supplement sanctions motion re additional perjury. Revise and add section to Supplement to Motion for Sanctions Dictate 3rd motion for sanctions re allened additional perjury of Martin O'Boyle. Organize all exhibits. (Evening) Evening conference with client. Review draft. Start revising Supplement to Motion for Sanctions (O'Boyle) Conference AV re adding perjury case law and editing motion Conference with counsel. Mcct with staff re pending motions. Revise and file Second sanctions. Work on additional perjury motion revise &review second motion for sanctions; research: perjury (r & s cases and treatise) Conference Mayor. Conference clerk re motion to amend and all alTrmative defenses and counterclaims. Review Hanna Noticed and Desousa email. Firm conference re: show cause order and confidentiality arguments. Discuss possible defenses to said arguments. Meeting with AV re answer and counterclaim. Review case law re privilege as it relates Conference w/ RAS and AV re: CAFI /O'Boyle privilege and waiver. Conference Joanne. Conference Dade County attorney. Conf Scott. Work on counterclaims. review file and prepare 57.105 for filing Con F-. Conference Scott. Work on CC and DEPO prep. Review article. Review and Depo prep. Conference w S re: Rio and response to show cause. Edit same per discussion. Prep travel and take Depo. S. O'Hare Report to Mayor B.S. .10 B.S. 25 B.S. .80 B.S. 1.50 B.S. 1.50 B.S. .50 A.D.V. 50 B.S. 20 B.S. 1.75 A.D.V. 125 B.S. .50 D.S. .20 D.P.V. .30 B.S. 1.20 D.P.V. .10 B.S. 2.40 A.D.V. .25 B.S. 1.00 B.S. 2.50 D.P.V. .30 B.S. 4.00 B.S. .10 81.25 Redacted per Fla. Stat. 119.071(1)(d) $35.00 $8750 $280.00 $.525.00 $525.00 $175.00 $175.00 $70.00 $612.50 $437.50 $175.00 $70.00 $60.00 5420.00 $20.00 $840.00 $87.50 $350.00 $875.00 $60.00 $1,400.00 $35.00 $26,150.00 $0.00 Matter Ledgers 13/19/2014 Balance before last invoice $0.00 12/19/2014 Invoice 10003 $26,150.00 SUBTOTAL: $36,150.00 Trust Account 12/19/2014 Previous Balance Available in Trust: $0.00 $0.00 TOTAL $26,150.00 PREVIOUS BALANCE DUE $0.00 CURRENT BALANCE DUE AND OWING $26,150.00 0 12536 TOWN OF GULF STREAM OPERATING ACCOUNT 12/238014 To: SWEETAPPLE, BROEKER & VARKAS, P.L. 20 S.E. 3rd STREET BOCA RATON, FL 33432 10003 12d 19/2014 legal S26,150.00 Sl)M0 S'6,I50.110 Totals: $26,150.00 511.110 $26,150.00 UU1- 53110- 513 -1U Legal Services- Admin TO THE 26,150.00 8 ORDER OF SWEETAPPLE, BROEKER & VARKAS, P.L. 20 S.E. 3rd STREET mom BOCA RATON, FL 33432 ORIGp Ea ]9 3NIIIN391 Q Y CIE NUIM! M .OF -- - - - - - -- R - NI ?I•a AUTHORIZED SIGNATURE z J 11.0 i 2 5 36111 a TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail January 20, 2015 Asset Enhancement, Inc. [mail to: records @commerce - group.com] Re: GS #1695 (971) Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker & Farkas, P.L (including Robert Sweetapple singularly) for the billingperiod beginning November 21, 2014 to the date of this request. Dear Asset Enhancement, Inc. [mail to: recordsAcommerce- group.com], The Town of Gulf Stream has received your public records requests dated January 7, 2015. If your request was received in writing, then the requests can be found at the following link http: / /www2.L,ulf- stream .org /WebLink8 /0/doc/33268/Pa eg l.asox. 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. You will find all responsive documents by going to 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, 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. Please 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