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