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Home My Public Portal AboutPRR 15-1793RECORDS REQUEST (the "Request") Date of Request: 2/1212015 Requestor's Request ID#: REQUESTEE: Custodian of Records Town of Gulf Stream REQUESTOR: CG Acquisition Company, Inc. 1040 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 all documents which relate to the Letter and Exhibits to Roberto Mendez as Identified In the January 23rd billing of Sweetapple, Invoice 10012, in a line entry dated January 16, 2015. (See attached ). ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO ARTICLE L 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 61 19.01(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 BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALSO PLEASE TAKE NOTE OF 41 I9.070l(H) OF THE FLORIDA STATUTES, \1111CH 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.IURI.SDICTION AFTER NOTICE 1'O 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 cleaned in Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs imposed to the Requester 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 1113/2015 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; a -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. 111512015 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 1/200-015 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. TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail February 27, 2015 CG Acquisition Company, Inc. [mail to: records @commerce - group.com] Re: GS #1793 (1040) 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 CG Acquisition Company, Inc. [mail to: records(ia commerce- erouu.coml, The Town of Gulf Stream has received your public records requests dated February 12, 2015. If your request was received in writing, then the requests can be found at the following link: ho://www2.gulf-stream.org/WebLink8/0/doc/37680/Pagel.awx. 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 a -mail August 28, 2015 CG Acquisition Company, Inc. [mail to: records@commerce-group.com] Re: GS #1793 (1040) Provide all documents which relate to the Letter and Exhibits to Roberto Mendez as identified in the January 23rd billing of Sweetapple, Invoice 10012, in a line entry dated January 16, 2015 (see attached). Dear CG Acquisition Company, Inc. [mail to: recordsna,commerce-group.coml, The Town of Gulf Stream received your original public records request on February 12, 2015. You should be able to view your original request at the following link httv://www2.gulf- stream.org/weblink/0/doc/37680/Pagel.asi3x. In future correspondence, please refer to this public records request by the above referenced numbers. Your request sought records related to an Unlicensed Practice of Law ("UPL") investigation by The Florida Bar regarding a third party, which investigation was ongoing and confidential at the time of the request. Indeed, the president of your organization, Martin O'Boyle, filed a motion with the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County in April 2015 asking that any records relating to that inquiry be filed under seal and not in the public record. On June 22, 2015, Mr. O'Boyle withdrew that motion and on June 26, 2015 all responsive records were produced to Jonathan O'Boyle in response to a separate public records request. Please allow this letter to confirm that all records responsive to your request have been produced and are available at b=://www2.gulf-stream.orWweblink/O/doc/56250/Pa egel_asgx. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records