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Home My Public Portal AboutPRR 15-1706RECORDS REQUEST (the "Request") Date of Request: 1/13/2015 Requester's Request ID#: 983 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: Airline Highway, LLC REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- group.com Fax: 954360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all records which provided Scott Morgan (as Mayor of the Town of Gulf Stream) knowledge of the actions taken by Martin O'Boyle against the Town as well as the approval by the Town to file Federal and State RICO actions against Martin O'Boyle and other entities. The ahnva request amanatae frnm Pa - li 44 f Mayor Scott.Morgan'sRule26 Disclosures ( "The Morgan Disclosures ") in the Litigation styled as Martin E. O'Boyle, Plaintiff vs Robert A Sweetapple and Mayor Scott Morgan, Defendants, Case #: 9:14 -CV- 81250 -KAM. A copy of The Morgan Disclosures" are attached to this Records Request— Rule 26 Sweetapple. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO ARTICLE I, SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119, FLORIDASTATUTES IF 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. SEE 4119.01(2)(F). FLORIDA STATUTES. 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) ALSO PLEASE TAKE NOTE OF ill 19.07(I)(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WITHIN THE 30-DAY PERIOD TO ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF 771E RECORD EXCEPT BY ORDER OF A COURT OF COMPETENT .IL'RISDICTION AFTER NOTICE TO ALL AFFECTED PARTIES." 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. "BY FULFILLING THIS RECORDS REQUEST, THE AGENCY ACKNOWLEDGES THAT THE RESPONSIVE DOCUMENTS ARE "PUBLIC RECORDS" AS DEFINED IN CHAPTER 119, FLORIDA STATUTES ". VP/NP/FLRR 1.12.2015 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA MARTIN E. O'BOYLE, Plaintiff, V. CASE NO.: 9:14 -cv- 81250 -KAM ROBERT A. SWEETAPPLE and MAYOR SCOTT MORGAN, Defendants. DEFENDANT, MAYOR SCOTT MORGAN'S, RULE 26 DISCLOSURES Defendant, MAYOR SCOTT MORGAN, by and through undersigned counsel hereby files its Rule 26(a)(1)(A)(I) Disclosures, under Federal Rule of Civil Procedure 26 and the Court's Trial Order dated December 11, 2014, and states as follows: Mayor Scott Morgan, Defendant c/o Jeffrey L. Hochman, Esq. Hudson C. Gill, Esq. Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A. 2455 East Sunrise Blvd., Suite 1000 Fort Lauderdale, FL 33304 2. Robert A. Sweetapple, Defendant c/o Joshua A. Goldstein, Esq. Cole, Scott & Kissane, P.A. 1645 Palm Beach Lakes Blvd., 2 "e Floor West Palm Beach, FL 33401 O'Boyle v. Sweetapple and Morgan Case No.: 14- 81250 -CIV -Marra 3. Martin E. O'Boyle, Plaintiff c/o Daniel DeSouza, Esq. DeSouza Law, P.A. 1515 North University Drive, Suite 209 Coral Springs, FL 33071 4. William Thrasher, Town Manager c/o Jeffrey L. Hochman, Esq. Hudson C. Gill, Esq. Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A. 2455 East Sunrise Blvd., Suite 1000 Fort Lauderdale, FL 33304 6. Garrett Ward, Police Chief c/o Jeffrey L. Hochman, Esq. Hudson C. Gill, Esq. Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A. 2455 East Sunrise Blvd., Suite 1000 Fort Lauderdale, FL 33304 Rita Taylor, Town Clerk c/o Jeffrey L. Hochman, Esq. Hudson C. Gill, Esq. Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A. 2455 East Sunrise Blvd., Suite 1000 Fort Lauderdale, FL 33304 8. Joanne M. O'Connor, Town Attorney Jones, Foster, Johnston & Stubbs 505 South Flagler Drive, Suite 1100 P.O. Box 3475 West Palm Beach, FL 33402 9. John (Skip) C. Randolph, Esq. Jones, Foster, Johnston & Stubbs 505 South Flagler Drive, Suite 1100 P.O. Box 3475 West Palm Beach, FL 33402 O'Boyle v. Sweetapple and Morgan Case No.: 1481250-CIV -Marra 10. All individuals listed by Plaintiff. 11. All individuals listed by Co- Defendant, Robert A. Sweetapple. Exhibits All discovery requests, responses to discovery requests, and responses to subpoenas duces tecum in this matter. 3. All deposition transcripts and their attached exhibits. 4. All exhibits listed by the Plaintiff. 5. All statements of witnesses in this matter. 6. All reports prepared by an expert in this matter. The curriculum vitae of all experts in this matter. 8. Impeachment or rebuttal exhibits as may be necessary. 9. Demonstrative aids including enlargements of photographs of Plaintiff, Plaintiffs political signs, and enlargements of still shots of Plaintiff from surveillance. 10. Defendant reserves the right to use any exhibit listed by any other party. 11. Defendant reserves the right to amend this disclosure. O'Boyle v. Sweetapple and Morgan Case No.: 14- 81250 -CrV -Marra CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was served via Email to on this 31" day of December; 2014, upon Daniel DeSouza, Esq., Ddesouza@desouzalaw.com, c ellman .bple alg com DESOUZA LAW, P.A.,1515 N University Drive, Suite 209, Coral Springs, Florida 33071; and Joshua A. Goldstein, Esq., Barry Postman, Esq. Joshua.Goldsteln@cskleeal.com, barry_postman(a_lcskleeal.com natricia neal a esklegal.comCOLE, SCOTT & KISSANE,1645 Palm Beach Lakes Boulevard, Second Floor, West Palm Beach, Florida 33401. JEFFREY L. HOC FLA. BAR NO. 902098 HUDSON C. GILL FLA. BAR NO. 15274 Attorneys for Defendant, Mayor Scott Morgan JOHNSON, ANSELMO, MURDOCH, BURKE, PIPER & HOCHMAN, PA 2455 E. Sunrise Blvd., Suite 1000 Fort Lauderdale, FL 33304 Tel: 954463-0100; Fax: 954463 -2444 Hochman@,iamb2.com Heill(cr�,jamba.com TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail January 15, 2015 Airline Highway, LLC [mail to: records @commerce - group.com] Re: GS #1706 (983) Provide all records which provided Scott Morgan (as Mayor of the Town of Gulf Stream) knowledge of the actions taken by Martin O'Boyle against the Town as well as the approval by the Town to file Federal and State RICO actions against Martin O'Boyle and other entities. The above request emanates from Paragraph #4 of Mayor Scott Morgan's Rule 26 Discolosures ( "The Morgan Disclosures') in the litigation styled as Martin E. O'Boyle, Plaintiff vs Robert A Sweetapple and Mayor Scott Morgan, Defendants, Case #9:14 -CV -81250 KAM. A copy of "The Morgan Disclosures" are attached to the records request - Rule 26 Sweetapple. Dear Airline Highway, LLC [mail to: recordsacommerce- grouo.coml, The Town of Gulf Stream has received your public records requests dated January 13, 2015. If your request was received in writing, then the requests can be found at the following link: htto: / /www2. gulf - stream. org/ WebLink8 /0 /doc /33793/Pagel.aspxx. 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 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 respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 15, 2015 Airline Highway, LLC [Mail to: records@commerce-group.com] Re: GS #1706 (983) Provide all records which provided Scott Morgan (as Mayor of the Town of Gulf Stream) knowledge of the actions taken by Martin O'Boyle against the Town as well as the approval by the Town to fele Federal and State RICO actions against Martin O'Boyle and other entities. The above request emanates from Paragraph #4 of Mayor Scott Morgan's Rule 26 Disclosures ("The Morgan Disclosures') in the litigation styled as Martin E. O'Boyle, Plaintiff vs Robert A Sweetapple and Mayor Scott Morgan, Defendants, Case #9:14-CV-81250-KAM. A copy of "The Morgan Disclosures " are attached to the records request - Rule 26 Sweetapple. Dear Airline Highway, LLC [Mail to: records(a)commerce-groun.coml, This letter is in response to the public records you have requested which was received January 13, 2015. This correspondence is reproduced at the following link ft://www2.gulf- stream.org/weblink/O/doc/33793/Paizel.asi)x. The Town is required to furnish copies of records when you identify the record or the portion of a record with sufficient specificity to permit the records custodian to identify the record and when the required fee is paid. Your request, and the document it incorporates, are insufficient to identify any records. Among other things, the request cites to a pleading served by counsel for Robert Sweetapple in O'Boyle v. Sweetapple, et al., Case No. 9:14-cv-81250-KAM (S.D. Fla.), which in turn references unidentified "actions taken by O'Boyle against the Town." A responsive document can be found at the following link: http://www2.gulf- stream.org/weblink/O/doc/28919/Pagel.asvx. We consider this request closed unless we receive clarification on the above request within 30 days of this response. Sincerely, Town Clerk Custodian of the Records