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Home My Public Portal AboutPRR 15-1757RECORDS REQUEST (the "Request ") Date of Request: 1/27/2015 Requestor's Request ID#: 1012 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: Airline Highway, LLC 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 communications as referred to in the 12th entry on page 4 of Invoice No. 177399 (File No. 13147.00001), dated December 31, 2014, received or sent by Michael Piper beginning on January 1 2014 through the date of this Reguest. ADDITIONAL INFORMATION REGARDING REQUEST: Attached is page 4, of Invoice No. 177399 (File No. 13147.00001), dated 17)arpmhPr31 2n14 _ THIS REQUEST 1S MADE PURSUANT TO ARTICLE I, SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119, FLORIDA STATUTES 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 6119.01(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(1)(H) OF THE FLORIDA STATUTES, WHICH PROVIDES TI IAT °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 C-OMPF.TENT 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 Requester approve of any costs, asserted by the Agency (as dented In Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requester 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 ". UP/NP /FLRR 1.12.2015 Jones, Foster, Johnston & Stubbs, P.A. Town of Gulf Stream December 31, 2014 Town of Gulf Stream - General Invoice No. 177399 File No. 13147.00001 Page 3 FOR PROFESSIONAL SERVICES RENDERED: DATE DESCRIPTION OF SERVICES HOURS INDV 11/23/14 TELEPHONE CALL WITH KELLY AVERY 0.20 MMM 11/24114 MEETING WITH KELLY AVERY 2.50 MMM 12/01/14 TELEPHONE CALL WITH K Y AVERY 0.20 MMM 3 12/02/14 REVIEW PUBLIC REC D EQUESTS 8 COMPLIANCE 0.30 KWR 2/02/14 RECEIVE AND REVIE ETTER FROM M. DAHLMEIER 0.20 JCR 2/14 MEETING WITH K. RIZZARDI 0.30 MMM 12/02/14 TELEPHONE CALL WITH KELLY AVERY 0.20 MMM 12/03/14 TELEPHONE CONFERENCE WITH K. AVERY RE PUBLIC 0.30 JMO RECORDS REQUESTS AND RESPONSES 12/03/14 TELEPHONE CONFERENC ITH K.AVERY RE: PUBLIC 0.40 KWR RECORDS Z 12/03/14 REVIEW PUBLIC ORDS REQUEST 0.30 KWR 12/03114 OFFICE CONFERENCE WITH K. RIZZARDI 0.30 JCR 12/03/14 RECEIVE AND REVIEW A PB AGENDA 0.20 JCR 12/04/14 CONFER WITH KK�ARTMANN AT DELRAY B 0,20 JMO 12/04/14 TELEPHONE CAFLf Y nvGRX— 0.20 MMM REVIEW CORRESPONDENCE FROM BERGER'S OFFICE AND 0.40 JMO C :COMPLAI FROM TOZIAN RE MORGAN AUTHORITY TO SUBMIT UPL NT TO FLORIDA BAR; CONFER WITH ASSOCIATE GARDNER RE SAME 12/05/14 ATTENTION TO PUBLI ECORDS RESPONSES 0.20 JMO 12/05/14 RECEIVE AND REVIEW RESEARCH ASSIGNMENT REGARDING 0.20 KAG MAYOR AUTHORITY. 12/05/14 OUTSIDE CONFERENCE WITH PLAINTIFF'S COUNSEL 4.50 JMO 12/05/14 CONFER WITH D6LOY BEACH RE PUBLIC RECORDS 0.20 JMO REQUESTS 12/05/14 TELEPHONE CONFERENCE WITH RITA TAYLOR 0.20 JCR TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail January 30, 2015 Airline Highway, LLC [mail to: records @commerce- group.com] Re: GS #1757 (1012), #1764 (1019) Provide a copy of all communications as referred to in the 12th entry on page 4 of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014, received or sent by Michael Piper beginning on January 1, 2014 through the date of this request. Attached is page 4, of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014. Provide copies of all public records requests regarding Joel Chandler as referred to in the 12th entry on page 6 of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014. Attached is page 6, of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014. Dear Airline Highway, LLC [mail to: recordsna,commerce- group.coml, The Town of Gulf Stream has received your public records requests dated January 27, 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 /35268 /Pagel.asjx and httt : / /www2.gulf- stream.org/WebLink8 /0 /doc /35282/Pa eg 1_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 Matias, Sally From: Mary Zepeda <zepeda @jambg.com> Sent: Friday, December 05, 2014 4:49 PM To: Bill Thrasher Cc: Randolph, John C.; Mike Piper Subject: Chris O'Hare v. Town of Gulf Stream Attachments: 0 'Hare.Ltr.Thrasher.12.4.14.pdf; Order.of.Transfer.pdf Chris O'Hare v. Town of Gulf Stream Claim No.: GC2011072748 D.O.I.: August 2011 Case No.: 13 -cv- 81053 -KLR Our File No.: 640/33569 Dear Mr. Thrasher: Please seethe attached correspondence from Michael Piper, Esq. Should you have any questions or you are unable to open the attached document, please do not hesitate to contact me directly. Thank you. Mary C. Zepeda, Assistant to Michael R. Piper, Esq. Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, P.A. 2455 East Sunrise Blvd., Suite 1000 Fort Lauderdale, FL 33304 (954) 463 -0100, Ext. 2910 Fax - (954) 463 -2444 Zepeda@ iambg.com Confidentiality Notice: This communication is covered by the Electronic Communications Privacy Act, 1B U.S.C. SB 2510 -2521. It is legally privileged (including attachments) and Is Intended only for the use of the Individuals) or entity(ies) to which it is addressed. It may contain information that is confidential, proprietary, privileged, and /or exempt from disclosure under applicable law. Any review, retransmission, dissemination or other use of, or taking of any action In reliance upon this Information by persons or entities other than the intended recipient Is strictly prohibited. If you have received this communication in error, please notify us so that we may take the appropriate action and avoid troubling you further. If you are not the Intended recipient(s), please destroy this message, and any attachments, and notify the sender by return e-mail I,AW OFFICES JOHNSON, ANSELMO, MURDOCH, BURKE, PIPER & HOCHMAN, P,A A PROFESSIONAL ASSOCIATION DAWAN H. ALBERT, P.A. W. HAMPTON JOHNSON CV SCOTT D. ALEXANDER, P.0. yg56 EAST SUNRISE BOULEVARD J, MARCOS MARTINEZ CHRISTOPHER AMBROSIO, P.A. SURE 1000 FORT LAUDERDALE, FL 33M4 ROBERT E. MURDOCH MICHAEL T. BURKE' MICHAEL R. PIPER' HUDSON C. GIU, PA. DAVID M. SCHWEIGER, P.A. JEFFREY HOCHMAN, PA CHRISTOPHER L SMITH E. BRUCE JOHNSON ` (854) 4630100 Bro"d CHRISTOPHER J. STEARNS, PA (6911640-7448 WPB Mmtn TELECOPIER(954)4532444 RONALDP.ANSELMO 'aa.VIDCFnT1FllDOlanuLUiRFxi BURLF. GEORGE December 4, 2014 Via electronic mail: bthrasherQc lf- stream.ore William Thrasher Town Manager Town of Gulf Stream 100 Sea Rd. Gul.f Stream, FL 33483 -7427 Re: Chris O'Hare v. Town of Gulf Stream Claim No.: GC201 1 072 74 8 Our File No.: 640/33569 Dear Mr, Thrasher: Enclosed please find a copy of federal district Judge Ryskamp's order of transfer of above - captioned matter to federal district Judge Middlebrooks. - As always, ifyou have any questions or comments, please do not hesitate to contact me. T will continue to keep you advised. Very truly yours, V4_ u t �C Michael R. Piper For the Firm MRP /mcz Enclosure cc: John Randolph, Esq. REDACTED PER FLA. STAT. 119.071(1)(d) 4%�. 3 -cv- 61053 -DMM Document 68 Entered on FLSD Docket 11/20/2014 Page 1 of 2 j. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION Case No,: 13 -CV- 81053- RYSKAMP/HOPKINS CHRIS O'HARE, Plaintiff, V. TOWN OF GULF STREAM et al., Defendants. ORDER OF TRANSFER THIS CAUSE comes before the Court sua sponge. The above - styled case is a retiled action from the case styled O'Hare v. Town of Gulf Stream, Case No, 13-80432 - MIDDLEBROOKS/BRANNON. The prior matter was dismissed without prejudice pursuant to an agreed order on May 30, 2013, by Judge Donald M. Middlebrooks. Pursuant to Local Rule 3,9, it is hereby ORDERED AND ADJUDGED that this case is TRANSFERRED to the Honorable Donald M. Middlebrooks. DONE AND ORDERED in Chambers at West Palm Beach, Florida this /f day of November 2014. Z444ao<420ZL� ET -NETN L. RYSK P UNITED STATES DISTRICT JUDGE ECEI V l NOV 2 0 20111 LS': '2'9:13 -cv- 81053 -DMM Document 68 Entered on FLSD Docket 11/20/2014 Page 2 of 2 After reviewing the Court file in the above - numbered case, the undersigned hereby accepts the transfer of said case, Accordingly, it is hereby ORDERED AND ADJUDGED that all pleadings hereinafter filed shall bear the case number 13- 81053- MIDDLEBROOKS /BRANNON, thereby indicating the Judge to whom all pleadings should be routed or otherwise brought for attention, The foregoing transfer is herewith accepted I 2 UNITED STATES DISTRICT JUDGE TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 24, 2015 Airline Highway, LLC [mail to: records @commerce - group.com] Re: GS #1757 (1012) Provide a copy of all communications as referred to in the 12th entry on page 4 of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014, received or sent by Michael Piper beginning on January 1, 2014 through the date of this request. Attached is page 4, of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014. Dear Airline Highway, LLC [mail to: recordsacommerce- aroun.coml, The Town of Gulf Stream has received your public records requests dated January 27, 2015. If your request was received in writing, then the requests can be found at the following link http: / /www2.gulf- stream. org/ WebLink8 /0 /doc /35268/Pagel.asi)x. 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 the responsive documents at the same above link. Please note that 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. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records CORRECTED —CASE NUMBER TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 24, 2015 Airline Highway, LLC [mail to: records @commerce- group.com] Re: GS #1757 (1012) Provide a copy of all communications as referred to in the 12th entry on page 4 of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014, received or sent by Michael Piper beginning on January 1, 2014 through the date of this request. Attached is page 4, of invoice no. 177399 (file no. 13147.00001), dated December 31, 2014. Dear Airline Highway, LLC [mail to: recordsna,commerce- groun.coml, The Town of Gulf Stream has received your public records requests dated January 27, 2015. If your request was received in writing, then the requests can be found at the following link httn: / /www2.gulf- stream. org/ WebLink8 /0 /doc /35268/Pagel.aslx. 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 the responsive documents at the same above link. Please note that 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. The case specifically is Case #13 -CV -81053 (U.S. District Court for the South District of Florida). We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records