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HomeMy Public PortalAboutPRR 15-1774RECORDS REQUEST (the "Request ") Date of Request: 112812015 Requestor's Request ID#: 1028 REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: Commerce Group, 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 communications as referred to in the 7th entry on page 3, dated 12/8/2014 on Invoice No. 10003, dated December 9, 2014, as marked with an "I ". 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, 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 $119.01(2)(F). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REOUEST 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 51 I9.07(I)(111 OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IFA CIVIL ACTION IS INSTITUTED WITHIN THE 3")AN' PERIOD TO ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO THE REQUESTED RECORD, THE CUS'T'ODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF T11E RECORD EXCEPT BY ORDER OF A COURT OF COMI'ETENT.IURISDICTION 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 ". I/P/NP/FLRR 1.12.2015 15 12/5/2014 evise droll one response to Sapp entent to Motion A.D.V. 1.00 S350.00 to Disqualify. 12;5/3014 Notice of riling preparation regarding deposition D.P.V. 5.50 $1,100.00 testimony; Travel to and from conference Willi client, Gerry, Joanne and R. Sweetapple. 12/6/2014 Saturday: Conrerence Willi Scott regarding B.S. 1.60 S560.00 mediation and strategy; Conference With D. Vitale regarding perjury ntotian and- • ecenve and review emails rrom week; Review article. 13/7/3014 N Prepare I'or meeting with Joanne, Gerry and Scott; B.S. 1.20 $420.00 Review all projects; Revise response; Entail. (Date 12/06). 12/SP-014 Westlaw search: Remedies for— i.e. A.D.V. 3.50 $1,225.00 (read case law and treatise); halt Supplement to Amended Motion for Sanctions. 12/8/3014 Work on second motion ror sanction - O'Boyle; B.S. .70 5245.00 Respond to supplement. 12/8/2014 • Conrerence Willi Joanne regarding O'Hare; Ennil B.S. 1.10 S385.00 Z response regarding O'Boyle and late regarding disclosure to Berger by CAF (evening). 1218/2014 Canfcrence Willi opposing causal; Prepare Motion B.S. .70 $245.00 regarding O'Hare; Review O'Hare response. 12/82014 Firm conference with R. Sweetapple regarding case D.P.V. ISO $300.00 and deposition testimony; Conrerence with A. Varkas; Research regarding —; Conference With A. ar cus; of cc of filing research and drafting. 12/9/3014 Conrerence with R. Sweetapple and A. Varkas D.P.V. .40 $80.00 regarding Motion to Disqualify and related testimony; Receive instructions an drafting. 12/912014 1Vesilnt vscarch:1) Use ofrormurdeposition A.D.V. 1.50 $535.00 f testimony (read treatise and case law) 2) Discovery while Motion to Dismiss pending; Discuss Willi R. Sweetapple bolstering Response to Supplement. 12/9/3014 Confcrence with Joanne; Review Hanna's filing; B.S. .70 $245.00 Revise response With clerk; Confcrence regardina sanction's motion with A. Varkas. 13/1012014 Confcrence with R. Sweetapple regarding unrelated D.P.V. 3.40 $650.00 party privilege; Conference Willi A. Varkas k/ regarding same; Edit motion per R. Sweetapple instructions; Research atiorriLy- client privilege; Review deposition transcript and hearing transcript; Review allegations in verified complaint and supplement; Complete draft for R. Swcetapple review. 12/10/2014 Conference with R. Sweetapple and edit response D.P.V. 30 560.00 per his request; Prepare ror final review. 12/10/3014 Conference with Hanna and Joanne regarding set B.S. 1.25 S43750 Redacted per Fla. Stat. 119.071(1)(d) TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 1, 2015 Commerce Group, Inc. [mail to: records @commerce- group.com] Re: GS #1774 (1028), #1775 (1030) 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 "T" Attached is page 3 of invoice no. 10003, dated December 9, 2014. Provide a copy of the deposition transcript and hearing transcript as referred to in the 13th entry on page 3, dated 1211012014 on invoice no. 10003, dated December 9, 2014, as marked with a "K ". Attached is page 3 of invoice no. 10003, dated December 9, 2014. Dear Commerce Group, Inc. [mail to: recordsna,commerce- proun.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 link: hn: / /www2.gulf- stream. ore /WebLink8 /0 /doc /35607/Pasel.asox and htto://www2.eulf- stream.ors/WebLink8 /0 /doc /35609/Pagel.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