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Home My Public Portal AboutPRR 15-1716RECORDS REQUEST (the "Request ") Date of Request: 1/14/2015 Requestor's Request ID#: 988 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- greup.com Fax: 954- 360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide all records that demonstrate that Joanne O'Connor is counsel to the Town of Gulf Stream in related matters filed by the Plaintiff, Martin O'Boyle and that she is fully aware of the litigation and public information requests tactics of Martin O'Boyle. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO ARTICLE L 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 5119.01(2)(F). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON I I 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 §119.07(11(11 OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WITHIN THE 30 -DAY PERIOD 1'0 ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF THE RECORD EXCEPT BY ORDER OF A COURT OF COMPETENT JURISDICTION 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 denned 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 ". I/P/NP/FLRR 1.12.2015 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 #1716 (988) Provide all records that demonstrate that Joanne O'Connor is counsel to the Town of Gulf Stream in related matters f led by the Plaintiff, Martin OBoyle and that she is fully aware of the litigation and public information requests tactics of Martin O'Boyle. Dear Asset Enhancement, Inc. [mail to: recordsaa,commerce- eroup.coml, The Town of Gulf Stream has received your public records requests dated January 14, 2015. If your request was received in writing, then the requests can be found at the following link: hqp: / /www2.gulf- stream. org/ WebLink8 /0 /doc /33905/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 April 15, 2015 Asset Enhancement, Inc. [mail to: recordsacommerce- grouo.coml, Re: GS #1716 (988) Provide all records that demonstrate that Joanne O'Connor is counsel to the Town of GulfStream in related matters filed by the Plaintiff, Martin O'Boyle and that she is fully aware of the litigation and public information request tactics of Martin O'Boyle. Dear Asset Enhancement, Inc. [mail to: records(a,commerce- group.coml, The Town of Gulf Stream received your public records requests on January 14, 2015. You should be able to view your original requests at the following links http://www2.gulf- stream. org/ WebLinkg /0 /doc /33905/Pagel.asux. 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 numbers. As you are well aware, prior to the time that this request was made, Martin O'Boyle and his affiliated entities, including you, had in 2014 and 2015 alone filed at least 15 public records suits against the Town of Gulf Stream. Attorney Joanne O'Connor is counsel to the Town of Gulf Stream in all of those suits. These suits, which remain pending, include: O'Boyle v. Town of Gulf Stream, Case No. 502014CA000834 AH O'Boyle v. Town of Gulf Stream, Case No. 502014CA001572 AJ O'Boyle v. Town of GulfStream, Case No. 502014CA000834 AH O'Boyle v. Town of Gulf Stream, Case No. 502014CA001572 AJ Stopdirrygovernment, LLC v. Town of Gulf Stream, Case No. 502014CA003721 AH O'Boyle v. Town of Gulf Stream, Case No. 502014CA004474 AA O'Boyle v. Town of GulfStream, Case No. 502014 CA 005189 AE O'Boyle and Christopher F. O'Hare v. Town of Gulf Stream, Case No. 502014CA005628 AA CG Acquisition Company, Inc. v. Town of Gulf Stream, Case No: 502014CA007123 AA O'Boyle v. Town of Gulf Stream, Case No: 502014CA008076 AD Stopdirrygovernment, LLC and O'Boyle v. Town of GulfStream, Case No: 502014CCO08529 RL Asset Enhancement, Inc. v. Town of Gulf Stream, Case No: 502014CA010216 AF O'Boyle, et al. v. Town of Gulf Stream Case No. 2014CA011940 AO O'Boyle v. Jones Foster Service, LLC and Town of Gulf Stream, Case No. 14 -14780 (17`h Judicial Circuit in and for Broward County, County Court) O'Boyle v. Gulf Stream, Case No. 2014CC015050 RL Your request is not only extremely broad, it encompasses internal communications and memoranda shared with the Town's attorney in the course of ongoing litigation that would be exempt under Florida Statute 119.0171(1)(d) l until the conclusion of the litigation. To search for responsive documents, assess whether they constitute public records and determine if any exemption applies will require significant time and expense. The Town estimates 6 hours of administrative support at $36.39 per hour, 10 hours of administrative support at $50 per hour, and at least 8 hours of attorney support to review for exemptions related to ongoing litigation at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). (6 hours @ 36.39 = 218.34) - (.25 hour @ 36.39= 9.10) + (10 hours @ 50.00 = 500.00) + (8 hours @ 235.00 = 1,880.00) = Deposit Due: $2,589.24 in cash or check. The Town of Gulf Stream is currently working on a large number of incoming public records requests. Upon receipt of your deposit, 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