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Home My Public Portal AboutPRR 15-1794REQUESTEE: RECORDS REQUEST (the "Request") Date of Request: 2/13/2015 Requestor's Request ID#: 1041 Custodian of Records Town of Gulf Stream REQUESTOR: CRO Aviation, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- group.com Fax: 954360 -0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide copies of all communications where the law firm of Richman Greer (including any of its lawyers) is the recipient or the sender. This would include any Retainer /Retention Agreements and would include any billings and payments or other documents. This Request is for the period beginning March 1, 2014 through the date of this Request. ADDITIONAL INFORMATION REGARDING REQUEST: 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 4119,01 00). 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(l)(11) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT -IF A CIVIL ACTION IS INSTITUTED WPTHIN TIIE 30 -DAY PERIOD TO ENFORCE THE PROVISIONS OFTHIS SECTION WITH RESPECTTO THE REQUESTED RECORD, TIIE CUSTODIAN OF PUBLIC RECORDS MAY Nor DISPOSE OF THE RECORD EXCEPT BY ORDER OFA COURTOF COMPETENTJURISDIC ION 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 Requester approve of any costs, asserted by the Agency (as denned in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs Imposed to the Requesmr 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". 1 /P/NP /FLRR 1.12.2015 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 27, 2015 CRO Aviation, Inc. [mail to: records @commerce- group.com] Re: GS #1794 (1041) Provide all documents which relate to the Letter and Exhibits to Roberto Mendez as identified in the January 23rd billing ofSweetapple, Invoice 10012, in a line entry dated January 16, 2015 (see attached). Dear CRO Aviation, Inc. [mail to: records(a),commerce- grouo.coml, The Town of Gulf Stream has received your public records requests dated February 13, 2015. If your request was received in writing, then the requests can be found at the following link: httv://www2.gulf-stream.org/WebLink8/0/doc/37658/Pagel.asRx. 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 From: Records [mailto :records @commerce- group.com) Sent: Tuesday, March 03, 2015 11:10 AM To: Bill Thrasher Subject: RE: GS #1794 (1041) Please revise the attached Records Request #1041 (Your number #1794) to read as follows: Please provide copies of all communications where the law firm of Richman Greer (including any of its lawyers) is the recipient or the sender for communications sent to or received by the Town of Gulf Stream (including its employees and attorneys \paralegals (including Robert Sweetapple, the Jones, Foster firm, Joanne O'Connor and John Randolph)). This would include any Retainer /Retention Agreements between the Richman Law Firm and the Town of Gulf Stream and would include any billings and payments to or from the Town of Gulf Stream. This Request is for the period beginning March 1, 2014 through the date of this Request. qhRICHMAN GREER PROFESSIONAL ASSOCIATION Richman Greer, P.A. 396 Alhambra Circle North Tower, 14th Floor Miami, FL 33134 305- 3734000 Fed. Tax I.D. 959- 1172536 TOWN OF GULF STREAM WILLIAM THRASHER, TOWN MANAGER 100 SEA ROAD GULF STREAM, FL 33483 ID: 9469-0000001 - GFR Re: TOWN OF GULF STREAM - O'BOYLE ETAL FOR PROFESSIONAL SERVICED RENDERED THROUGH CURRENT FEES TOTAL CURRENT CHARGES TOTAL DUE 5,385.00 22, 2015 Invoice 70964 January 22, 2015 Page:I 5,385.00 5,385.00 TRUST BALANCE 0.00 TOWN OF GULF STREAM ► PAYMENT APPROVED 4 Amount Jr %6.00 By lA1 Dat /)/ Check # 1,0- 4$1 Date,2 Ag RICHMAN GREER PROFESSIONAL ASSOCIATION Richman Greer, P.A. 396 Alhambra Circle North Tower, 14th Floor Miami, FL 33134 305- 3734000 Fed. Tax I.D. #59- 1172536 TOWN OF GULF STREAM WILLIAM THRASHER, TOWN MANAGER 100 SEA ROAD GULF STREAM, FL 33483 ID: 9469 - 0000001 - GFR Re: TOWN OF GULF STREAM - O'BOYLE ETAL FOR PROFESSIONAL SERVICED RENDERED THROUGH BALANCE FORWARD CURRENT FEES 45,397.95 CURRENT DISBURSEMENTS 367.62 TOTAL CURRENT CHARGES TOTAL DUE TRUST BALANCE 0.00 31, 2015 RTOWN OF GULF STREAM �> PAYMENT APPROVED Amount 45 7(e . 5D gy DateL� Check # Invoice 71293 February 11, 2015 Page: 1 5,385.00 45,765.57 51,150.57 uci.in u�we rv.ee.0 �, N�a ewn viauwaw rvuua a,uu, rvc uav uuu,uv,, OOV.YGG.W /G TOWN OF GULF STREAM OPERATING ACCOUNT To: Richman Greer Professional Association 396 Alhambra Cir. North Tower, 14th Floor 61 12681 2/19/2015 70964 1/228015 legal $5,385.00 $0.00 $5,385.00 71293 2/118015 legal svcs $45,765.57 50.00 $45,765.57 Totals: $51,150.57 $0.00 $51,150.57 001 - 53110- 513 -10 Legal Scrviccs - Admin TOWN OF GULF STREAM OPERATING ACCOUNT 100 SEA ROAD GULF STREAM, FL 33483 -7427 (561) 276 -5116 SUNTRUST BANK UJARM o— 12681 63- 215/631 CHECK DATE CHECK NO. PAY "Fifty one thousand one hundred fifty and 57/100 Dollars" TO THE ORDER OF Richman Greer Professional Association 396 Alhambra Cir. ....... EIR -- North Tower, 14th Floor otllolN<-. Miami, FL 33134 3� 3N tlN3 7 G ENUINr_. DE I.NI`JItlO. lV AUTHORIZED SIGNATURE II■❑ 1 268 ill' 2/19/2015 12681 i CHECKAMOUNT $" 51,150.57 e , I i iE I! TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail June 5, 2015 CRO Aviation, Inc. [mail to: records @commerce- group.com], Re: GS #1794 (1041) Please provide copies of all communications where the lawfrm of Richman Greer (including any of its lawyers) is the recipient or the sender. This would include any retainer /retention agreements and would include any billings or other documents. This request is for the period beginning March 1, 2014 through the date of this request. (Revised 313115 - Please provide copies of all communications where the law firm of Richman Greer (including any of its lawyers) is the recipient or the sender for communications sent to or received by the Town of Gulf Stream (including its employees and attorneyslparalegals (including Robert Sweetapple, the Jones, Foster firm, Joanne O'Connor and John Randolph)). This would include any Retainer /Retention Agreements between the Richman Law Firm and the Town of Gulf Stream and would include any billings and payments to or from the Town of GulfStream. This Request is for the period beginning March 1, 2014 through the date of this Request. Dear CRO Aviation, Inc. [mail to: records(a),commerce- grouo.coml, The Town of Gulf Stream received your public records requests on February 13, 2015. You should be able to view your original requests at the following link htty://www2.gulf- stream.org/weblink/0 /doc /37658 /Pagel.aWx,. In future correspondence, please refer to this public records request by the above referenced numbers. We have produced partial production of the invoices and payments that can be found at the same above link. Minutes and any correspondence documenting retainer of Richman Greer can be found at the following links: hqp://www2.gulf-stream.org/weblink/O/doc/28917/Pagel.aspx and httv://www2.gulf-strearn.org/weblink/O/doc/28919/Pagel.asi)x. As you are well aware, the Town filed a putative class action against you and others in federal court along with co- plaintiff the Wantman Group, Inc. on February 12, 2015 and that litigation is pending. See Town of Gulf Stream and Wantman Group, Inc. v. O'Boyle, et al., Case No. 9-15 - cv- 80182 -KAM (S.D. Fla.). The Town and the Wantman Group, Inc. are represented in that litigation by Richman Greer, P.A. Your request broadly seeks all internal communications of the Richman Greer law firm, communications among the Town's outside counsel and communications between outside counsel and the Town related to that suit. It thereby encompasses internal communications, memoranda and drafts of pleadings prepared by the Town's attorneys exclusively for the litigation or in anticipation of imminent litigation and that reflect the mental impressions, conclusions, litigation strategies, or legal theories of the Town's attorney or the Town and would be exempt under Florida Statute 119.0171(1)(d)1 until the conclusion of the litigation. To search for responsive documents, assess whether they constitute public records and determine if any exemption applies will require significant time and expense. The Town estimates 4 hours of administrative support at $36.39 per hour, 8 hours of administrative legal support at $50 per hour, and at least 4 hours of attorney support to review for exemptions related to the ongoing litigation at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). If the costs of producing these documents will exceed your deposit, the Town will provide you with an initial production of responsive records and an estimate for the production of any additional responsive records. If the costs of production are less than the deposit, the Town will provide you with the responsive records and a refund. (4 hours @ 36.39 = 145.56) — (.25 hours @36.39 = 9.10) + (8 hours @ 50.00 = 400.00) + (4 hours @ 235.00 = 940.00) = Deposit Due: $1,476.46 in cash or check. The Town of Gulf Stream is currently working on a large number of incoming public records requests. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. Sincerely, Town Clerk