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HomeMy Public PortalAboutPRR 15-1812L.. COMMERCE GROUP mobovlealcommerce- groun.com Direct Dial Telephone #954 -570 -3505 March 12, 2015 VIA E -MAIL: rtavlorQ¢ulf- stream.ore TELEPHONE #561- 276 -5116 Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Attn: Rita S. Taylor, Custodian of Records and Town Clerk Re: Records Request — Sweetapple, Broeker, Varkas, P.L. Billings/ Payments — February, 2015 Dear Ms. Taylor: Enclosed please find a copy of the captioned Records Request, which is being submitted with the expectation of receiving the Responsive Documents promptly. Either I or one of my affiliates will be making this very same Request on a monthly basis. Consequently, I wanted to put you on notice now so that you could alert the law firm to make any redactions that they intend to make either immediately before the submission of their bill to you; or immediately after their submission of their bill to you. I believe this mechanism will avoid the potential for future litigation based on timeliness, providing we receive cooperation from your end. As always, I would like to wish you a wonderful South Florida day! Sincerely yours, COMMERCE GROUP, INC. Lk_'�' -4.L� Martin E. O'Boyle President l Enclosure P /NPR /FRR www.commerce-group.com TEL. 954.360.7713 . FAX 954.360.0807 1280 WF Nmou CEr R DR , DURRELD BEACH, FwRIDA 33442 REQUESTEE: RECORDS REQUEST (the "Request ") Date of Request: 311212015 Requestor's Request ID#: 1068 Custodian of Records Town of Gulf Stream REQUESTOR: CRO Aviation, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- group.com Fax: 954- 360 -0807 or Contact Jill Mohler, Records Custodian at imohler @commerce- eroumcom; (954) 570 -3507; 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, roe er & Varkas, P.L. (including o ert Sweetapple singularly) for the billing period beginning on theday after the stday in which time was billed to Gulf Stream. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO ARTICLE 1, 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 6119.0101(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 TARE NOTE OF $119.07(H(H) OF THE FLORIDA STATUTES, 11911CI1 PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WIT] [IN 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 JURISDICrION 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 Requesmr approve of any costs, asserted by the Agency (as defined In Florida Statute, Chapter 119.61 (Delinitlons)), 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 ". UP/NP/FLRR 3.2.2015 Sweetapple, Broeker & Varkas 20 SE 3rd Street ` OWi GULF SIRE Boca Raton, Fl 33432 j 0� PAYMENT APPROVED-4 Phone: 561-392-1230 1 Fax: 561 -39 Ahwunt By INVOICE Check #tea Sweetapple, Broeker & Varkas 20 SE 3rd Street Invoice Date: January 27, 2015 Boca Raton, F133432 Invoice Number: 10013 Invoice Amount: $5,927.50 Matter: CAM v. SBV Attorney's Fees 12/15/2014 Review Motion for Entry of Order to Show Cause; A.D.V. 2.00 $700.00 Review relevant case law: 1) common interest privilege; 2) burden of proof: re: use of semi- privileged documents; 3) review treatise on disqualification and related case law; pull case law cited by CAFI in motion; review law re: replevin and order to show cause (Chap. 781). 12/15/2014 Review Motions. Meet with AV to review case law. R.S. 2.00 $700.00 Prepare Motion to Transfer and edit, 12/16/2014 draft response to motion to show cause (incorporate A.D.V. 1.50 $525.00 memo of law) 12/17/2014 revise response to motion to show cause A.D.V. .50 $175.00 12/19/2014 Work on motion to transfer and response to order to R.S. 3.20 $1,120.00 show cause. 1/8 /2015 Exchange emails Wednesday and Today. R.S. .30 $105.00 1/9/2015 Exchange emails opposing counsel. R.S. .10 $35.00 1/14/2015 prepare notice of hearing on our Motion to Transfer D.S. .20 $25.00 1/20/2015 Review plaintiff filing. R.S. .20 $70.00 1/20/2015 Meeting with AV to analyze plaintiff cited R.S. .40 $140.00 authorities. 1/20/2015 westlaw search: crime -fraud exception;attomey A.D.V. 2.50 $875.00 participation in fraud;(read and summarize case law) 1/21/2015 Draft Request for Judicial Notice; Compile C.B. 1.00 $125.00 exhibits;eFile Request; t/c w. Judge Small's JA. 1/26/2015 Firm conference re: case status D,P.V. .10 $20.00 1/26/2015 Prepare for hearing. Review all filings. R.S. 1.25 $437.50 1/27/2015 Prep travel and attend hearing. Conference with R.S. 2.50 $875.00 Is opposing counsel and Cc counsel. Conference Mayor. Prep motion and letter. SUBTOTAL: Costs SUBTOTAL: Matter Ledgers 1/27/2015 Balance before last invoice 1/27/2015 Invoice 10013 SUBTOTAL: Trust Account 1/27/2015 Previous Balance Available in Trust: 17.75 $5,927.50 gIM $0.00 $5,927.50 $5,927.50 $0.00 $0.00 TOTAL $5,927.50 PREVIOUS BALANCE DUE $0.00 CURRENT BALANCE DUE AND OWING $5,927.50 LAW OFFICES OF SWEETAPPLE, BROEKER & VARKAS, P.L. DOUGLAS C. BROEKER, P.A. 44 West Flagler Street, Ste. 1500 Miami, Florida 33130-6817 Telephone: (305)374-5623 Facsimile: (305) 358 -1023 ROBERTA. SWEEFAPPLE', DOUGLAS C. BROEKER ALEXANDER D. VARKAS, JR. KADISHA D. PHELPS ALEXANDER D. VARKAS, III ASHLEIGH M. GREENE • apAPa LE0.11P1 ®BUSMPSS IJTiGATiW1ATmRNEY •• aOARa L4aTlinD LMLiAIAL ATmPNEY VIA E -MAIL Joanne M. O'Connor, Esquire Jones, Foster, Johnston & Stubbs, P.A. Flagler Center Tower 505 South Flagler Drive, Suite l 100 West Palm Beach, Florida 33401 January 28, 2015 S WEETAPPLE do VARKAS. P.A. 20 S.E. P Street Boca Raton, Florida 334324914 Telephone: (561) 392 -1230 Facsimile: (561) 394.6102 Please Reply To: Boca Raton E -Mall: ns etapple©sweetappielaw.com avarkas@asweetapplelaw.com aivarkas@sweetapplelaw.com cbailey@sweetapplelaw.wm dsmith©sweetappielaw.com Paralegals: Cynthia J. Bailey, CP, FCP, FRP Deborah Smith, CP, FRP Jamie Arden, FRP Re: Citizens Awareness Foundation, Inc. v. Sweetapple, Broeker & Varkas, PL Case No.:2014 -CA- 011941 -AH, Palm Beach County Dear Joanne: As discussed, enclosed is our bill for defending the CAFI claim. We will be answering and filing affirmative defenses as well as a motion to intervene on behalf of the Town of Gulf Stream. Documents were delivered to me by Mr. Chandler as part of his reporting a crime and fraud scheme by CAM and others, including its legal counsel. As such, it is our position that no lawyer- client privilege attaches as a matter of law. Inasmuch as our law firm is the defendant in this action and we maintain Gulf Steam's right to possession and utilization of documents, our billing should be covered by the Town. Enclosed is our statement. Please process for payment as soon as possible. I have discounted my billing rate from $600 to $350 per our agreement. Regards, Apl_ ROBERT A. SWEETAPPLE RAS:cjb Enclosures Sweetapple, Broeker & Varkas 20 SE 3rd Street Boca Raton, F133432 Phone: 561-392-1230 1 Fax: 561-394-6102 Account Statement Prepared for Sweetapple, Broeker & Varkas Re: CAM v. SBV Previous Balance $0.00 Current Charges $5,927.50 New Balance $5,927.50 Adjustments $0.00 Payments $0.00 Now Due $5,927.50 Trust Account $0.00 TOWN OF GULF STREAM OPERATING ACCOUNT To: SWEETAPPLE, BROEKER & VARKAS, P.L. 20 S.E. 3rd STREET BOCA RATON, FL 33432 10013 1127/2015 Legal 001 - 53110- 513 -10 Legal Services - Admin 0 ! 12684 2/19/2015 $5,927.50 50.00 $5,927.50 Totals: 55,927.50 50.00 $5,927.50 TOWN OF GULF STREAM SUNTRUST BANK OPERATING ACCOUNT 63- 215/631 100 SEA ROAD GULF STREAM, FL 33463 -7427 (561) 276 -5116 00949 PAY * *Five thousand nine hundred twenty seven and 50/100 Dollars ** TO THE ORDER OF SW EETAPPLE, BROEKER & VARKAS, P.L. 20 S.E. 3rd STREET BOCA RATON, FL 33432 0: GIN.={ 39' 3NI ON391 GENUINE GE NI" lvf' 1v ' 'i � AURiORIZEO SIGNATURE 1268 Lilts 4 12684 qq FRAUD \t] ARHOR' CHECK DATE CHECK NO. 2/19/2015 12684 CHECKAMOUNT $" 5,927.50 4 Sweetapple, Broeker & Varkas 20 SE 3rd Street Boca Raton, Fl 33432 Phone: 561-392-1230 1 Fax: 561-394-6102 Account Statement Prepared for Town of Gulf Stream Re: O'Boyle: O'Hare. 1679 Previous Balance $0.00 Current Charges $26,724.38 New Balance $26,724.38 Adjustments $0.00 Payments $(21,320.50) Now Due $26,724.38 Trust Account $2,500.00 VN OF GULF 5 1 Kt PP PAYMENT APPROVED Check #. Sweetapple, Broeker & Varkas Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483 Attorney's Fees 20 SE 3rd Street Boca Raton, FI 33432 Phone: 561-392-1230 1 Fax: 561-394-6102 INVOICE Invoice Date: February 23, 2015 Invoice Number: 10026 Invoice Amount: $26,724.38 Matter: O'Boyle: O'Hare.1679 1/26/2015 Firm conference re: case status D.P.V. .10 $20.00 1/26/2015 Finalize Attorney General complaint per RAS D.P.V. .20 $40.00 comments. Conference w/ Cynthia re: same 1/26/2015 Review Bar Article. Conferences Joanne and Scott. R.S. 1.60 $560.00 Work on Motion to Strike re Ohare and memo re hearing. Work on Request to Produce. 1/27/2015 Email correspondence w/ Joanne re: case #762. D.P.V. .10 $20.00 1/27/2015 Email correspondence, review and send. Update D.P.V. 1.30 $260.00 amended answer per correspondence w/ Joanne and discussion w/ RAS. T/c w/ Cynthia Bailey re: filing amended answer per RAS email instructions. Finalize for filing. Begin draft motion to transfer to Division AA to Judge Blanc. 1/28/2015 Review new complaints. Finalize and file R.S. .40 $140.00 Counterclaim. 1/29/2015 Review email correspondence w/ RAS and JO. D.P.V. .10 $20.00 Conference call w/ Mayor Morgan. 1/29/2015 Conference with Mayor Morgan and Dave re R.S. 1.25 $437.50 appearing in all GULFSTREAM records cases and counterclaiming. Strategies. Review new suits. 2/2/2015 Exchange emails. Review order. Work on pleadings. R.S. .40 $140.00 2/3/2015 Review emails and conference. R.S. .40 $140.00 2/4/2015 Conference and email opposing counsel and Bill R.S. .75 $262.50 Thrasher. Review complaint. Conference Joanne and Scott. 2/5/2015 Prep letter. Prep compliance with Judge Blanc R.S. .80 $280.00 Order. Conferences with counsel. 2/7/2015 Conferences and work on pending cases. R.S. .60 $210.00 2/7/2015 Review and respond. R.S. .20 $70.00 2/8/2015 Prepare for hearings. Prepare detailed discovery all R.S. 1.40 $490.00 new parties. (Sunday) 2/9/2015 Conference with Joanne and Dave re pending cases. R.S. 2.20 $770.00 Meeting Dave re O'Boyle hearings and memo of law. Meeting with AV re O'Hare hearing work up. Prep response to Motion. 2/9/2015 Firm conference re case status. Discuss motion to D.P.V. .50 $100.00 amend and motion for expedited hearing and case law research re same. 2/9/2015 Review opposing party amended response in D.P.V. 1.40 $280.00 opposition to motion to amend. Westlaw research re: case law cited within said motion. Read and annotate same to distinguish. 2/10/2015 Call to counsel. R.S. .20 $70.00 2/10/2015 Prepare for hearings. Prepare motion and request. R.S. 1.10 $385.00 Conference Scott. 2/10/2015 Revise motion and conference. Prep for client R.S. .70 $245.00 meeting. Conference and additions re RICO complaint. Review crime fraud additional cases. 2/11/2015 Review motion for clarification filed by MOB. D.P.V. 1.60 $320.00 Westlaw research re: immediate hearing under 119.11, attorney's fees under 119.12, and case law re: same. Annotate findings and print. Conference w/ RAS in preparation for hearing. 2/11/2015 Prepare subpoenas O'Hare. Prepare for O'Hare R.S. 4.75 $1,662.50 hearing. Meet with AV re crossx of witnesses. Phone conference all lawyers re all pending matters and final draft of RICO complaint. Conferences with Scott. Review and revise. Prepare for AM hearing. 2/12/2015 Prepare, travel and attend hearing. Conference R.S. 3.50 $1,225.00 opposing counsel. Conference Joanne. Conference Scott. Conference Jax attorney re O'Boyle law firm improprieties. 2/12/2015 index shelly O'Hare depo transcript A.D.V. 2.00 $700.00 2/13/2015 index depo transcript of E. Jonas A.D.V. 1.50 $525.00 2/13/2015 Travel and attend calendar call O'Hare. Conference R.S. 4.50 $1,575.00 Hanna and O'Boyles attorneys. Conference Skip Smith. Attend town council meeting. Conference Dave and prepare for Tuesday hearing. 2/14/2015 Conference Scott and Research. Saturday. R.S. 1.50 $525.00 2/15/2015 Work on projects. Task list. Preparation for Tuesday R.S. 2.00 $700.00 hearing and Thursday deposition. 2/16/2015 Review motion in opposition to amend. Prepare D.P.V. 2.40 $480.00 memo for RAS summarizing law and arguments in response. Westlaw research related to same. Annotate case law. 2/16/2015 Conference w RAS to discuss tomorrow's hearing. D.P.V. .60 $120.00 T/c to Gray's attorney to request documents in preparation for hearing. 2/16/2015 2/16/2015 2/17/2015 2/18/2015 2/18/2015 2/19/2015 2/19/2015 2/20/2015 2/20/2015 2/20/2015 2/21/2015 2/22/2015 2/23/2015 SUBTOTAL: Costs 12/1/2014 12/3/2014 12/17/2014 12/22/2014 1/27/2015 1/28/2015 1/28/2015 2/9/2015 2/20/2015 SUBTOTAL: Matter Ledgers Read Berger notebook and cases. Outline plaintiff arguments. Review Our memo and cases. Meet with Dave. Conference Wells. Review Grey complaint and transcript. Finalize preparation for hearing. Review Supplement just filed by Berger. Finalize preparation conference with mayor. Preparation, travel and attend hearing. Conference Joanne and Scott. Prep depos O'Hare and emails. Index RAS depo O'Hare depo prep. Review Bar Rules and law re circuit court jurisdiction concerning dividing fees with non lawyers. Preparation for meeting with Scott and Joanne re all upcoming projects. Travel and meeting at Jones Foster w RAS and company regarding strategy and motion for SJ Travel and attend pending case meeting. Prep travel and take O'Hare deposition. Conference with Scott. Meeting with Dave re his projects. Meeting with AV re his research projects. Hearing preparation. westlaw search re: caselaw re:disqualify attorney based on knowledge of confidential matters to oppose O'Hare's motion to disqualify RAS (read ans summarize cases) Conference with all lawyers. Conference with Dave. Conference. Start Notice to Produce at hearing and Motions to compel. Work on summary chart and production requests to additional defendants. Dictate letter to Hanna. Dictate Notice to Produce at trial and exhibit list. Review of order. Conference with Joanne. Meeting with AV re Motion for Order to Show cause against O'Hare re Mediation disclosure. Research re scope of representation. Photocopy Charges - November 2014 Postage - November 2014 Westlaw Westlaw Westlaw Photocopies January 2015 Postage January 2015 Westlaw Westlaw R.S. 5.20 R.S. 1.25 R.S. 4.00 A.D.V. 2.00 R.S. 2.25 D.P.V. 3.60 R.S. 11.00 R.S. 2.00 A.D.V. 1.50 R.S. 1.00 R.S. 2.00 R.S. .60 R.S. 1.25 $1,820.00 $437.50 $1,400.00 $700.00 $787.50 $720.00 $3,850.00 $700.00 $525.00 $350.00 $700.00 $210.00 $437.50 77.70 $25,410.00 $6.50 $0.48 $202.73 $18.81 $354.48 $486.75 $2.70 $219.23 $22.70 $1,314.38 1/23/2015 Balance before last invoice 1/23/2015 Invoice 10012 2/3/2015 Check No. 12622 2/23/2015 Invoice 10026 SUBTOTAL: Trust Account 2/6/2015 Previous Balance 2/6/2015 SBV transfer operating to trust - Check No. 4995 Available in Trust: $0.00 $21,320.50 $(21,320.5 0) $26,724.38 $26,724.38 $2,500.00 $2,500.00 $2,500.00 TOTAL $26,724.38 PREVIOUS BALANCE DUE $0.00 CURRENT BALANCE DUE AND OWING $26,724.38 Sweetapple, Broeker & Varkas 20 SE 3rd Street Boca Raton, FI 33432 Phone: 561 -392 -1230 1 Fax: 561-394-6102 Account Statement Prepared for Sweetapple, Broeker & Varkas Re: CAFI v. SBV. 1711 Previous Balance $0.00 Current Charges $4,402.05 New Balance $4,402.05 Adjustments $0.00 Payments $(5,927.50) Now Due $4,402.05 Trust Account $0.00 TOWN OF GULF STREAM ►PAYMENT APPROVEDA heck # I,2i l3 Date -2 Sweetapple, Broeker & Varkas 20 SE 3rd Street Boca Raton, FI 33432 Phone: 561-392-1230 1 Fax: 561-394-6102 INVOICE Sweetapple, Broeker & Varkas 20 SE 3rd Street Invoice Date: February 25, 2015 Boca Raton, FI 33432 Invoice Number: 10028 Invoice Amount: $4,402.05 Matter: CAR v. SBV. 1711 Attorney's Fees 10/17/2014 Review complaint; Review chapter 812.035 and A.D.V. 3.50 $1,225.00 812.014; Review law regarding 1) Repleving (chapter 78) read case law and treatise (Fla.Jur.) 2) Commission (see case law and treatise). 10/20/2014 Continue research 1) Conversion 2) Replevin 3) F.S. A.D.V. 3.50 $1,225.00 812.035; Read and summarize case law for Motion to Dismiss. 10/20/2014 Review complaint; Conference with A. Varkas R.S. 2.25 $787.50 regarding research and motion to dismiss; Prepare letter and notice of deposition. 10/22/2014 Dictate Motion to Dismiss complaint. A.D.V. 1.00 $350.00 10/23/2014 Revise Motion to Dismiss; Additional argument A.D.V. .50 $175.00 based in case law. 10/27/2014 Revise Motion to Dismiss. A.D.V. .25 $87.50 10/29/2014 Update motion to strike as sham per RAS; File. C.B. .40 $50.00 11/3/2014 Prepare email; Conference with clerk. R.S. .20 $70.00 11/13/2014 Conference with R. Sweetapple regarding possible D.P.V. 1.30 $260.00 defamation counterclaim; Draft Motion to Compel per R. Sweetapple's instructions for his review and approval. SUBTOTAL: 12.90 $4,230.00 Costs 12/17/2014 Westlaw $43.96 2/9/2015 Westlaw $15.86 2/20/2015 Westlaw $112.23 SUBTOTAL: Matter Ledgers 1/27/2015 1/27/2015 2/20/2015 2/25/2015 SUBTOTAL: Balance before last invoice Invoice 10013 Check no. 12684 Invoice 10028 Trust Account 2/25/2015 Previous Balance Available in Trust: $172.05 $0.00 $5,927.50 $(5,927.50) $4,402.05 $4,402.05 $0.00 $0.00 TOTAL $4,402.05 PREVIOUS BALANCE DUE $0.00 CURRENT BALANCE DUE AND OWING $4,402.05 TOWN OF GULF STREAM OPERATING ACCOUNT To: SWEETAPPLE, BROEKER& VARKAS, P.L. 20 S.E. 3rd STREET BOCA RATON, FL 33432 10026 22312015 1679 10028 2125,2015 CAR 001 - 53110- 513 -10 Legal Services - Admin PAY TO THE ORDER OF • U 12713 2/27/2015 $26,724.38 $0.00 $26,724.38 54,402.05 SOHO $4,402.05 Totals: $31,126.43 $0.00 $31,126.43 pp 12713 TOWN OF GULF STREAM SUNTRU57 BANK ItJ ARMOR OPERATING ACCOUNT 63- 215/631 100 SEA ROAD CHECK DATE CHECK NO. GULF STREAM, FL 33483 -7427 (561) 276 -5116 00949 "Thirty one thousand one hundred twenty six and 43/100 Dollars" SWEETAPPLE, BROEKER & VARKAS, P.L. 20 S.E. 3rd STREET BOCA RATON, FL 33432 2/27/2015 12713 CHECK AMOUNT $" 31,126.43 E � I ^ItlJ. I l OP� . 39 �'3HInH' � 1 - '..,- AUTHORIZED SIGNATURE - - - - - -- 11'04271311' 1:0631021521:1 ❑001600731Soo TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail March 25, 2015 CRO Aviation, Inc. [mail to: records @commerce- group.com] Re: GS #1812 (1068) Provide a copy of all billings and payments from and to the law firm of Sweetapple, Broeker & Farkas, P.L. (including Robert Sweetapple singularly) for the billing period beginning on the day after the last billing period, through the last day in which time was billing to Gulf Stream. Dear CRO Aviation, Inc. [mail to: records(a)commerce -srouo com], The Town of Gulf Stream received your public records requests dated March 12, 2014. You should be able to view your original requests at the following link http://www2.eulf- stream.ore/WebLink8 /0 /doc /40912 /Paeel.asox. If your request was verbal, then the description of your public records request is set forth in the italics above. In future correspondence, please refer to this public records request by the above referenced numbers. We understand the responsive documents to be the billing ending February 23 2015. The responsive documents can be found at the same above link. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records