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Home My Public Portal AboutPRR 15-1784REQUESTEE: RECORDS REQUEST (the "Request") Date of Request: 212/2015 Requestor's Request ID#: 1036 Custodian of Records Town of Gulf Stream REQUESTOR: Our Public Records, 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 billings and payments from and to the law firm of Sweetapple, Broeker & Varkas, P.L. (including Robert Sweetapple singularly) for the billing period January 2015. ADDITIONAL INFORMATION REGARDING REQUEST: 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. ,FF 4119.OI(2)(Fl. 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 BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALSO PLEASE TAKE NOTE OF 41 19.07(11(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT -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 THE RECORD EXCEPT BY ORDER OF A COURT OF COMPETENT.IURISDICrION AFTERNOTICE 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 11/28/3014 (�j Receive and review letter; Revise O'Hare second U B.S. .80 5280.00 request to produce; Initial review amended of motion of O'Hare. 11/30/2014 Conference with Scott; Outline all projects on all B.S. 4.20 $1,470.00 pending Gulfstreatn adv.O'I-lare and O'Boyle cases; Prepare strategy regarding Receive an reytcty tco Ictli letter and nfiidavit•, Receivc and Bergen's review motion; Work on -, (Date 11/38). 1211/3014 Meeting with client and paralegal regarding projects. B.S. .30 5105.00 (O'Hare). 12/1/3014 Mceting with client and A. Varkas regarding B.S. .50 5175.00 supplement and response; Conference regarding -. (O'Boyle). 12/1/2014 A4celing with A. Varkas regarding response to B.S. .75 5262.50 supplement; Conference with Joanne regarding siretegy 1211/2014 Firm conference regarding O'Hare and O'Boyle D.P.V. .30 560.00 motions to disqualify; R. Sweclapplc instructions regarding 1211/2014 Review O ay es supp emonl to o0on to A.D.V. 4.00 51,400.00 Disqualify; Research issues .1) cvtcw ortg na ouon to NlounlWantasponse; Read and summarize case law and treatise. 12/3/2014 Receive and review O'Boyle resonse and letters; B.S. .90 $315.00 Conference with A. Varkas regarding our response to supplement. 12/3/2014`!5) Index trnnscripl /leasing (11/18114) on schedule A.D.V. 350 51,22i.00 conference; Dictate the response to supplement to Motion to Disqualify Counsel. 12/3/2014 Draft response to supplennent to Motion la C.O. 1.00 $125.00 Disqualify dictated by A. Varkos. (O'Boyle). 13/3/2014 %' Receive and review cnnails and conference regarding B.S. 7i $26350 Berger response and sanctions; Conference with D. Vitale regarding Case an 13/3/2014 1313/3014 Ravi ct Mixtingtyitit A.D.V. i0 5175.00 B.S. 1314/3014 Revise draft a tcsponse to Supplement. .30 5105.00 A.D.V. 1.50 5535.00 12/4/2014 Draft notice of filing per R. Sweettipple; Compare D.P.V. deposition testimony for exhibit on the notice .70 5140.00 regarding discrepancy; Conference with C. Bailey. 12/5/1014 Travel and attend meeting in oil cases and work on B.S. new pleadings; Meeting with Eric, Gerry, Scott and 650 $2,275.00 Joanne at Gerry's office; Meeting Willi client rcgarding Redacted per Fla. Stat. 119.071(1)(d) TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 6, 2015 Our Public Records, LLC [mail to: records @commerce- group.com] Re: GS #1784 (1036) Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker & varkas, P.L. (including Robert Sweetapple singularly) for the billing period January 2015. Dear Our Public Records, LLC [mail to: recordsaa.commerce- eroup.coml, The Town of Gulf Stream has received your public records requests dated February 2, 2015. If your request was received in writing, then the requests can be found at the following link: http: / /www2.gulf- stream. ore/ WebLink8 /0 /doc /35938/Pagel.aspx. 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 Rebecca Tew From: Bill Thrasher Sent: Wednesday, January 28, 2015 12:43 PM To: Rebecca Tew Subject: FW: Cost Deposit - Town of Gulf Stream Please process. From: Cynthia Bailey [mailto:cbailey @sweetapplelaw.com) Sent: Wednesday, January 28, 2015 9:13 AM To: Bill Thrasher Subject: Cost Deposit - Town of Gulf Stream Good morning, Would you please provide our office with a $2,500.00 cost deposit made payable to the Sweetapple, Broker & Varkas, PL Trust Account? This money will be used for any associated fees for filing, service of process, court reporters, etc. Thank you. CYNTHIA J. BAILEY Certified Paralegal /Florida Certified Paralegal /Florida Registered Paralegal Sweetapple, Broeker & Varkas, P.L. 20 SE 3rd Street Boca Raton, FL 33432 (561) 392- 1230(t) x. 305 (561) 394- 6102(f) cbailev @sweetapplelaw.com STATEMENT OF CONFIDENTIALITY The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate, maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this message to any person other than the intended recipient(s) is not intended in any way to waive privilege or confidentiality. TOWN OF GULF STRE *PAYMENT APPROVED4 Check # a Sweetapple, Broeker & Varkas 20 SE 3rd Street Boca Raton, F133432 Phone: 561 -392 -1230 1 Fax: 561-394-6102 Account Statement Prepared for Town of Gulf Stream Re: O'Boyle: O'Hare Previous Balance $0.00 Current Charges $21,320.50 New Balance $21,320.50 Adjustments $0.00 Payments $(26,150.00) Now Due $21,320.50 Trust Account $0.00 VN OF GULF STREAM 0- PAYMENT APPROVED ).3 ?D .50 V Date L # �aCe,2a Date 912 15 Sweetapple, Broeker & Varkas Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Attorney's Fees 20 SE 3rd Street Boca Raton, F133432 Phone: 561-392-1230 1 Fax: 561-394-6102 INVOICE Invoice Date: January 23, 2015 Invoice Number: 10012 Invoice Amount: $21,320.50 Matter: O'Boyle: O'Hare 12/21/2014 Review and prepare RAS Depo by O'Hare R.S. 1.30 $455.00 tomorrow. 12/22/2014 Prep and attend DEPO of RAS and conference R.S. 4.00 $1,400.00 Joanne. 12/23/2014 Conference w/ RAS re: counterclaims and research. D.P.V. .20 $40.00 12/23/2014 Meeting with clerk re Declaratory Judgment R.S. 1.25 $437.50 complaint. Conference Gerry re strategy and revised draft of his complaint. Conference Scott re Martin letters and confidential mediation. 12/23/2014 Westlaw research re: 1) Forum shopping and claim D.P.V. .70 $140.00 splitting 2) Similar claims. Annotate case law and summarize for RAS. 12/23/2014 Annotate 11th circuit case for RAS review re: forum D.P.V. .10 $20.00 shopping. 12/23/2014 Prepare memorandum for RAS re: forum shopping. D.P.V. .20 $40.00 12/28/2014 Review latest Federal Rico complaint. Review R.S. 1.30 $455.00 memo and cases re state jurisdiction re affirmative defenses and Declaratory Judgment Counterclaim. Review O'Boyle Motion to Strike. 1/2/2015 Work on Counterclaim re revocation of Corporate R.S. .70 $245.00 Charters. Conference law clerk re case law and statute. 1/2/2015 Work on counterclaim. Review O'Hare Response R.S. 1.60 $560.00 1/5/2015 Conference w/ RAS re: affirmative defenses and D.P.V. .10 $20.00 counterclaims 1/5/2015 Meet with clerk re Declaratory Judgement. Work on R.S. 1.25 $437.50 scheduling conference. 1/5/2015 Westlaw Research re: 1) Revocation of CAM D.P.V. 1.10 $220.00 charter and 2) Revocation of OBLF charter. Annotate case law and treatises and summarize for RAS review. 1/5/2015 Westlaw research 1) amending pleadings (not D.P.V. .30 $60.00 charged) and 2) various searches on confidentiality (not charged) 1/5/2015 Draft motion to amend pleading to add AD, CC, and D.P.V. .10 $20.00 DJ per RAS 1/5/2015 Draft motion for leave to amend re: affirmative D.P.V. .80 $160.00 defenses and counterclaim. Westlaw research re: same (not charged). 1/5/2015 Review initial answer to MOB pleading; Draft D.P.V. .40 $80.00 affirmative defenses and counterclaims per RAS instructions 1/5/2015 Draft initial amended pleading to be attached as D.P.V. .40 $80.00 exhibit to motion for leave to amend. 1/5/2015 Exchange emails re Depo and bar matters. R.S. .25 $87.50 1/6/2015 Call w RAS and Scott Morgan re: case status and D.P.V. .20 $40.00 amended pleadings 1/6/2015 Call w RAS and Joanne O'Conner D.P.V. .20 $40.00 1/6/2015 Conferences with Scott and Joanne and Dave re R.S. .40 $140.00 strategy and developments. Attorney General Revication. 1/6/2015 Email case law research re: revocation of corporate D.P.V. .10 $20.00 charter to RAS for client review 1/8/2015 Review emails and respond Hanna and O'Conner. R.S. .20 $70.00 1/9/2015 Review proposed order from Berger. Meet with R.S. .80 $280.00 Clerk and work on Scheduling Order. Call from Mayor Morgan. Exchange emails Hanna. 1/9/2015 Additional emails re depos. R.S. .20 $70.00 1/11/2015 Draft affirmative defenses and counterclaim per D.P.V. 5.50 $1,100.00 RAS. Conference w RAS to review and edit as needed. Westlaw research related to same (not billed - accessing saved files). Edit per RAS final comments. 1/11/2015 Saturday and Sunday. Work on Counterclaim and R.S. 7.50 $2,625.00 Request. Dictate compliance with Order and letters 1/12/2015 Conferences and work on pleading. R.S. .70 $245.00 1/12/2015 Email correspondence w/ JO and RAS re: D.P.V. .10 $20.00 scheduling conference. 1/12/2015 Meeting Gerry, conferences Scott and Dave. Review R.S. 1.50 $525.00 email and revisions. 1/12/2015 prepare letter to opposing counsel re 57.105 motion D.S. .40 $50.00 1/13/2015 Prepare letters. Finalize filings with court including R.S. 2.75 $962.50 scheduling disclosure, Answer and Amended Affirmative Defenses and Counterclaim. Review client comments and changes. Prep for deposition. 1/13/2015 review motion to amend,amended answer, A.D.V. 1.00 $350.00 affirmative defenses, and counterclaim. conference with ras. 1/13/2015 Deposition of Jonas and conference with Joanne R.S. 1.50 $525.00 1/13/2015 Conference w/ RAS re: finalized affirmative D.P.V. .10 $20.00 defenses and counterclaim. Conference w/ RAS re: Jonas deposition. 1/13/2015 Review O'Hare count from Joanne and letter and R.S. .30 $105.00 filing from Berger. 1/13/2015 Format and update O'Hare Motion for Leave to File C.B. .40 $50.00 Amended Answer, Affirmative Defenses and Counterclaim w. RAS changes 1/14/2015 Update Motion for Leave; emails w. J. O'Connor re: C.B. .30 $37.50 depos for PRR 1/14/2015 Update O'Boyle Motion for Leave with RAS C.B. 1.70 $212.50 changes; update Compliance with RAS changes; d/f Notice of Filing; finalize letters to M. Berger and Judge Blanc; e -file Motion for Leave and Notice of Filing Compliance 1/14/2015 Conference w/ RAS and draft complaint to Attorney D.P.V. 1.40 $280.00 General. 1/14/2015 Review FCIR story and email correspondence re: D.P.V. .10 $20.00 same. 1/15/2015 Revise Oboyle affirmative defenses and R.S. 1.75 $612.50 counterclaim. Prepare O'Hare affirmative defenses and counterclaim. Conference Gerry yesterday. Review and incorporate his corrections. Review investigative reporter update. Prep for meeting all counsel tomorrow. Conference Joanne. 1/15/2015 Conference w/ RAS re: counterclaims v. O'Hare and D.P.V. 2.30 $460.00 O'Boyle. Edit same re: comments, as well as comments by Joanne and Gerry. Insert additional claim re: O'Hare. Conference w/ RAS re: final draft and status of the OLF. Finalize per RAS comments and put in final form. 1/15/2015 Work on Attorney General case. R.S. .60 $210.00 1/15/2015 Conference call w Dave and Mayor Morgan. R.S. .10 $35.00 1/16/2015 Travel to and from meeting at Richman Greer re D.P.V. 4.00 $800.00 finalizing RICO complaint, et al. 1/16/2015 Meeting with all counsel. Work on all pleadings in R.S. 4.00 $1,400.00 all cases and Attorney General issues. Review new Oboyle cases and strategies. 1/16/2015 Letter to Roberto Mendez; compile exhibits to letter; C.B. .50 $62.50 email and mail. 1/17/2015 Review Berger filings and conference Mayor R.S. .60 $210.00 Morgan. 1/19/2015 Review lengthy response and prepare for hearing. R.S. .50 $175.00 1/20/2015 Review pleadings binder. Outine arguments for R.S. 1.50 $525.00 hearing. 1/20/2015 Westlaw research re: sanctions for perjury (not D.P.V. .20 $40.00 billed); Edit motion per case law. 1/20/2015 Conference w/ RAS. Prepare draft answer, a/d, and D.P.V. 1.00 $200.00 counterclaim to new lawsuit per RAS instructions. Submit for his review. 1/20 /2015 Travel and attend hearing. Meeting with Joanne. R.S. 3.50 $1,225.00 Conference Berger. Conference Hanna. Conference Mayor Morgan. Begin work on pending Blanc and Barkdull cases. 1/20/2015 Review small claims court materials. Confer w/ AJV D.P.V. .20 $40.00 re: small claims procedure. Conference w/ RAS re: same. 1/21/2015 Meeting with Dave. Work on answer, affirmative R.S. 1.50 $525.00 defenses and counterclaim in new O'Boyle suit. Work on discovery. 1/21/2015 Conference w/ RAS re: new cases and counterclaim. D.P.V. 1.60 $320.00 Edit answer to new case per edits from RAS. Finalize for RAS and AV review. Email correspondence concerning case log. Edit Attorney General complaint per feedback from prior week's meeting. 1/21/2015 Finalize pleadings in newly filed O'Boyle case. R.S. .40 $140.00 Review Amended Opposition. 1/23/2015 Review email from Mayor and all exhibits. R.S. 1.50 $525.00 Conference and research re violation of confidentiality agreement. Review recent opinions. 1/23/2015 Work on RICO and discovery all defendants. R.S. 1.75 $612.50 1/23/2015 Westlaw research to pull case law for RAS re: CAFI D.P.V. .30 $60.00 v. SBV SUBTOTAL: 71.20 $20,922.50 Costs 1/21/2015 Filing fees for Counterclaim and Summons $398.00 SUBTOTAL: $398.00 Matter Ledgers 12/19/2014 Balance before last invoice $0.00 12/19/2014 Invoice 10003 $26,150.00 12/26/2014 Check No. 12536 $(26,150.0 0) 1/23/2015 Invoice 10012 $21,320.50 SUBTOTAL: $21,320.50 Trust Account 1/23/2015 Previous Balance $0.00 Available in Trust: $0.00 TOTAL $21,320.50 PREVIOUS BALANCE DUE $0.00 CURRENT BALANCE DUE AND OWING $21,320.50 W TOWN OF GULF STREAM OPERATING ACCOUNT To: SWEETAPPLE, BROEKER & VARKAS, P.L. 20 S.E. 3rd STREET BOCA RATON, FL 33432 12622 2/2/2015 INVOICENUMBER .. 10012 1/23/2015 Legal $21,320.50 $0.00 $21,320.50 Deposit 1/26/2015 deposit for filiag V $2,500.00 $0.00 $2,500.00 Totals: $23,820.50 $0.00 $23,820.50 UU 3 -» a U -D a -I U Begat JCMICe5 - Aamm 12622 TOWN OF GULF STREAM SUNTRUST BANK pFRAUD- VARHOR OPERATING ACCOUNT 63- 2151631 100 SEA ROAD CHECK DATE CHECK NO. GULF STREAM, FL 33483 -7427 (561) 276 -5116 2/2/2015 12622 00949 CHECKAMOUNT "Twenty three thousand eight hundred twenty and 50/100 Dollars" PAY 23,820.50 TO THE ORDER ! OF SWEETAPPLE, BROEKER & VARKAS, P.L. ' 20 S.E. 3rd STREET a. lVN�9�Y0 BOCA RATON, FL 33432 °` " °' "` °` - _°RI°INwr- 1300 iHIHH39 - , M, AUTHORIZED SIGNATURE t ii'0 1 26 2 2iia TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 12, 2015 Our Public Records, LLC [mail to: records @commerce- group.com] Re: GS #1784 (1036) Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker & varkas, P.L. (including Robert Sweetapple singularly) for the billing period January 2015. Dear Our Public Records, LLC [mail to: records(ia commerce- eroup.coml, The Town of Gulf Stream has received your public records requests dated February 2, 2015. If your request was received in writing, then the requests can be found at the following link htty: / /www2.gulf- stream. ore/ WebLink8 /0 /doc /35938/Pagel.ast)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 link. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records