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HomeMy Public PortalAboutPRR 15-1773RECORDS REQUEST (the "Request ") Date of Request: 1/28/2015 Requestor's Request ID#: 1027 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: CRO Aviation, 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 E- Mails, articles and other communications and readings beginning on 11/20/2014 through the date of this Request as referred to in the 4th entry on page 3 dated 121712014 on Invoice No. 10003 dated December 9 2014. ar, marked with an "li ". ADDITIONAL INFORMATION REGARDING REQUEST: Attached is page 3 of Invoice No. 10003, dated December 9, 2014. 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 5119.01(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 HE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALSO PLEASE TAKE NOTE OF §119.07(11(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WITHIN THE 30 -DAY PERIOD TO ENFORCE TIIE PROVISIONS OF THIS SECTION WITH RESPECT TO THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NO'r DISPOSE OF THE RECORD EXCEPT BY ORDER OF A COURT OF COMPETENT.IURI.SDICTION AFTER NOTICE TO ALL AFFECTED PARTIES." ALL ELECTRONIC COPIES ARE REQUESTED TO HE 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 or 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 ". I/P/NP/FLRR 1.12.2015 IS 13/52014 cvlse draft one response to suPP entent to Motion A.D.V. 1.00 $350.00 to Disqualify. 1215 /3014 Notice of filing preparation regarding deposition D.P.V. 5.50 $1,100.00 testimony; Travel to and from conference with client, Geny, Joanne and R. Sweetapple, 1216/2014 Saturday: Conference with Scott regarding B.S. 1,60 5560.00 mediation and strategy; Conference with D. Vitale regarding perjury motion ands Receive and review emails from week; Review article. 1217/30114 N Prepare for meeting Willi Joanne, Gerry and Scott; D.S. 1.20 5420.00 Review all projects; Revise response; Entail. (Date 12/06). 13/512014 Nestlaw search: Remedies for— i.e. A.D.V. 350 $1?25.00 (read case law and treatise); haft Supplement to Amended R9adan for Sanctions. 12/513014 Work on second motion for sanction - O'Boyle; B.S. .70 5345.00 Respond to supplement. 12/5/2014 Conference with Joanne regarding O'Hare; Email B.S. 1.10 $355.00 response regarding O'Boyle and law regarding disclosure to Berger by CAF (evening). 13/8/2014 Canlercnce with opposing couscl; Prepare Motion B.S. .70 $245.00 regarding O'Hare; Review O'1•lare response. 12/8R014 Firm conference with R. Sweclnpple regarding case D.P.V. 1.50 $300.00 and deposition testimony; Conference with A. Varkas; Reserver rc g —; Canfurcncc wit wish A. ar:us• Duce of Filing research and drafting. 12/912014 Conference with R. Sweetapple and A. Varkas D.P.V. .40 $50.00 regarding Motion to Disqualify and related testimony; Receive instructions an drafting. 13/9/2014 Rrestlaw search: 1) use of former deposition A.D.V. 1.50 5535.00 T testimony (read treatise and case law) 2) Discovery while Motion to Dismiss pending; Discuss Willi R. Sweetapple bolstering Response to Supplement. 12/9/3014 Conference Willi Joanne, Review Hanna's filing; B.S. .70 5245.00 Revise response with clerk; Conference regarding sanction's motion with A. Varkas. 12110/2014 Conference with R. Swcetapple regarding unrelated D.P.V. 3.40 5650.00 party privilege; Conference with A. Varkas regarding same; Edit motion per R. Sweelapplc instructions; Research ntorney- client privilege; Review deposition transcript and hearing transcript; Review allegations in verified complaint and supplement; Complete draft far R. Sweetapple review. 12110/3014 Conference with R. Sweetapple and edit response D.P.V. .30 560.00 per his request; Prepare for final review. 121100-01.1 Conference with Finnna and Joanne reearding set B.S. 125 543750 Redacted per Fla. Stat. 119.071(1)(d) TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail January 30, 2015 CRO Aviation, Inc. [mail to: records @commerce- group.com] Re: GS #1769 (1022), #1773 (1027) Provide a copy of the letter referred to in the 7th entry on page 1, the line item dated 11125114 on invoice no. 10003, dated December 9, 2014, as marked with a "C ". Attached is page 1 of invoice no. 10003, dated December 9, 2014. Provide a copy of all emails, articles and other communications and readings beginning on 11120112014 through the date of this request as referred to in the 4th entry on page 3, dated 121712014 on invoice no. 10003, dated December 9, 2014, as marked with an "H ". Attached is page 3 of invoice no. 10003, dated December 9, 2014. Dear CRO Aviation, Inc. [mail to: records(a.commerce- group.com], The Town of Gulf Stream has received your public records requests dated January 28, 2015. If your request was received in writing, then the requests can be found at the following link: http: / /www2.gulf -st ream .org(WebLink8 /0/doc/35597/Pa eg 1_aspx and http://www2.gulf- stream. ore/ WebLink8 /0 /doc /35605/Paeel.asnx. 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 21, 2015 Airline Highway, LLC, CRO Aviation, Inc.,and Commerce Group, Inc. [mail to: records @commerce - group.com] Re: GS #1772 (1026), #1773 (1027), #1774 (1028) Provide a copy of all emails and other communications as referred to in the 11th entry on page 2, dated 121312014 on invoice no. 10003, dated December 9, 2014, as marked with a "G ". Attached is page 2 of invoice no. 10003, dated December 9, 2014. Provide a copy of all emails, articles and other communications and readings beginning on 11120112014 through the date of this request as referred to in the 4th entry on page 3, dated 121712014 on invoice no. 10003, dated December 9, 2014, as marked with an "H ". Attached is page 3 of invoice no. 10003, dated December 9, 2014. Provide a copy of all communications as referred to in the 7th entry on page 3, dated 1212812014 on invoice no. 10003, dated December 9, 2014, as marked with an "1 ". Attached is page 3 of invoice no. 10003, dated December 9, 2014. Dear Airline Highway, LLC, CRO Aviation, Inc.,and Commerce Group, Inc. [mail to: records(oDcommerce- grouo.coml, The Town of Gulf Stream has received your public records requests dated January 28, 2015. If your request was received in writing, then the requests can be found at the following links htti)://www2.gulf-stream.org/WebLink8/0/doc/35603/Pagel.asox http://www2.aulf- stream.org/WebLink8 /0 /doc /35605/Pagel.aspxx, and htty://www2.gulf- stream.org/WebLink8 /0 /doc /35607/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. Please be advised that you have failed to identify with specificity the documents you are requesting in each of your requests. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records