HomeMy Public PortalAboutO'Hare Deposition Transcripts 2/19/15 Vol 1In The Matter Of:
CHRISTOPHER F. O'HARE v.
TOWN OF GULF STREAM
Deposition of CHRISTOPHER O'HARE
February 19, 2015
Vol I
DEBRA DURAN
A S S O C I A T E S
Rc-iwered Prolissionot Reporic'n
P.O. Box 2288
West Palm Beach, Florida 33402
561 - 313 -8000
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No.502013CA017717XXXXMB
CHRISTOPHER F. O'HARE,
Plaintiff,
-vs- VOLUME I
TOWN OF GULF STREAM,
Defendant.
VIDEOTAPED DEPOSITION OF CHRISTOPHER F. O'HARE
TAKEN AT THE INSTANCE OF THE DEFENDANT
Thursday, February 19, 2015
2:47 p.m. - 6:58 p.m.
5550 Glades Road
Suite 500
Boca Raton, Florida 33431
Reported By:
Debra Duran - Bornstein, RPR
Notary Public, State of Florida
Debra Duran & Associates
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APPEARANCES:
On behalf of the Plaintiff:
MARK J. HANNA, ESQUIRE
GMMM /MADISON P.A.
401 South County Road
Suite 3272
Palm Beach, Florida 33480
LOUIS L. ROEDER, III„ ESQUIRE
7414 Sparkling Lake Road
Orlando, Florida 32819
On behalf of the Defendant:
ROBERT A. SWEETAPPLE, ESQUIRE
SWEETAPPLE, BROEKER & VARKAS
20 S.E. 3rd Street
Boca Raton, Florida 33432
JOANNE O'CONNOR, ESQUIRE
JONES, FOSTER, JOHNSTON & STUBBS
505 South Flagler Drive, Suite 1100
West Palm Beach, Florida 33401
ALSO PRESENT:
Bo Cooper, Videographer
Mayor Morgan
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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WITNESS:
CHRISTOPHER O'HARE
BY MR. SWEETAPPLE:
NUMBER
I N D E X
DIRECT CROSS REDIRECT RECROSS
4
E X H I B I T S
DESCRIPTION
DEFENDANT'S EX. A DEPOSIT AND TRANSFER SLIP
DEFENDANT'S EX. B, C, DPICTURES
DEFENDANT'S EX. E PERIODICAL
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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105
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P R O C E E D I N G S
Thereupon,
Page 4
(CHRISTOPHER O'HARE)
having been first duly sworn or affirmed, was examined
and testified as follows:
DIRECT EXAMINATION
BY MR. SWEETAPPLE:
Q. Mr. O'Hare.
A. Yes, Bob.
Q. I'm now taking your deposition in your
personal capacity, not in your capacity as a corporate
representative. The same instructions I gave you
earlier applies.
Is that fair, since it was only within an hour
and a half I gave you the instructions? You do remember
them, right?
A. I remember that.
Q. Okay. Good. You provided some documents in
your supplemental response dated January 30, 2014, with
regard to your motion to disqualify me from representing
the Town of Gulf Stream.
The first document I'm going to show you is
marked as Exhibit A and purports to be a transfer and a
deposit slip. Do you recognize Exhibit A?
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A. Yes.
(Defendant's Exhibit A was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Where did you find that?
A. In a box, on a pallet, on a pallet rack --
Q. In --
A. -- in my plant.
Q. In your plant, okay. And your plant is
located in?
A. Boynton Beach.
Q. Okay. And when did you locate that?
A. Just prior to producing it for you.
Q. Okay. And what -- what box or file did you
find that in?
A. It was just a loose paper.
Q. Loose paper where?
A. Unidentified cardboard box.
Q. Just a cardboard box. From what year?
A. From eight months prior. Approximately eight
months prior.
Q. From eight months prior?
A. To when I found it.
Q. I'm saying, was there any date or any
identification on the box?
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A. No. No.
Q. Okay. So
A. You know, let me save you the trouble of
trying to go through all this. I had to empty out my
office in a rush to make room for another tenant.
Things were pushed -- dumped into boxes with the
intention of going through them later. Boxes were put
into random pallets, stored on pallet racks. No
identification on the boxes, just that they happened to
come from my office. That's where this came from.
Q. So it was just in an empty box?
A. No, not an empty box.
Q. In a box full of random things?
A. Notes, business cards, trade show brochures,
all the accoutrements of --
Q. Undated? Undated.
A. The box had no date on it.
Q. Okay. And did that -- was that Exhibit A in
any file?
A. No. It was in a box.
Q. Okay. Did it have anything in it that had a
date, anything that would help you identify when that
document is from?
A. No. There were -- there were other documents
in the box from the bottom of my desk drawers. Some of
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them might
have had dates. I can't testify to that.
Q.
So you located this how long ago?
A.
Just prior to turning it over to you.
Q.
Okay. And what is it?
A.
It looks like two sides of a deposit slip.
Q.
And on whose account?
A.
Shelley Childers, Christopher O'Hare,
22 Harbour
Drive South, Ocean Ridge.
Q.
So is that your account?
A.
This would have been my account, yes.
Q.
And when do you believe that was written?
A.
I believe this was written in 1998.
Q.
Okay. And all of the handwriting on that
check or on
those -- on those documents, whose
handwriting
is that?
A.
This is mine.
Q.
Okay. All the handwriting is yours?
A.
On this document, that's my handwriting.
Q.
Okay. And did you have this -- did you have
an account
at First Bank of Florida in 1998?
A.
That is a deposit slip that would have been
pulled out
of the deposit book, on the account that
Shelly, my wife, and I maintain.
Q.
So did you go -- is -- were both of these
documents
found in the box?
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A. That's a single document, two - sided. That was
found in the box.
Q. Just this, and this is both sides?
A. Both sides, yes.
Q. Okay. So was this -- is this -- this says
"profit distribution from Pineapple Grove Design to
cover Sweetapple payment and miscellaneous." And that
writing was on -- you have the original of this
document?
A. Yes.
Q. Okay. And that writing was on it when you
found it?
A. Yes.
Q. Okay. And the back -- the back side shows a
deposit of $12,000. Was it -- is this a deposit slip
that was actually deposited?
A. No. That shows a crossed -out notation on the
back and a correction on the front. And I believe from
when I saw that, I remembered that I was going to make a
deposit, but responding to the admonitions of my wife,
who handled the books at the time, was told not to.
Instead, we should make a transfer of -- whatever that
language is. May I examine the document?
Q. (Handing document.)
MR. HANNA: Did you mark that?
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BY MR. SWEETAPPLE:
Q. I'm going to mark this as Exhibit A to your
deposition.
A. Yes. I was prepared to write a check from
Pineapple Grove Designs, which is abbreviated as PGD,
for $12,000. Instead, Shelley said transfer it from
profit distribution, meaning we'll take it out as a
payment to me, and pay taxes on it as if it was salary,
and -- to cover Sweetapple payment and miscellaneous. I
suppose there were other bills at the time.
Q. So the first -- it says "deposit ticket."
There is money deposited. Okay. And you say that the
deposit ticket was actually deposited with the bank?
A. No.
Q. Did you ever -- this deposit slip that says
"Shelley, please transfer profit distribution from
Pineapple Grove Designs to cover Sweetapple payment and
miscellaneous." And then it says "PGD 12,000." So
nothing was ever done with this? It was not ever --
this -- this was never deposited, right?
A. My intention was to deposit it. My wife
corrected me, as she's done most often, said don't do it
that way; it's got to be a profit distribution. We
can't just write business checks for personal attorneys.
Q. So the answer to my question is, this document
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here that you've identified as Exhibit A was never
deposited with a bank, right?
A. It's just a note.
Q. Okay. My question -- my statement is, this is
a deposit slip; it was never deposited with a bank?
A. Right. Correct.
Q. So you have the original still?
A. My original what?
Q. The original of this document. You have it?
A. Yes, I have it.
Q. So if I noticed you to produce it at a trial
or hearing, you will have the original of this?
A. Yes.
Q. Is it written in pen or pencil?
A. May I examine that?
Q. Do you recall from having seen the original
recently?
A. This looks like pencil to me.
Q. Do you recall having seen it --
A. I think I recall it being pencil.
Q. Okay. And who -- and this is your
handwriting?
A. Yes.
Q. And you're saying that the second -- the
bottom part of Exhibit A is the other side of this
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Page I I
deposit slip, and the 12,000 was crossed out?
A. That's correct, Bob.
Q. Okay. And you believe that this account, this
First Bank of Florida account, 267085619 is the routing
number, and the account No. 0505017835 existed in 1998?
In other words, you're -- you're sure that this deposit
slip is from 1998?
A. Yes.
Q. And do you still bank with this bank?
A. That says "First Bank of Florida," which was
bought by Wachovia, which was bought by Wells Fargo.
And, yes, we still have that very same account. The
numbers may have changed, but, yeah, they're still our
bank.
Q. And it's your testimony that I was paid -- my
firm or me was paid in 1998 from this account, right,
this personal account?
A. No.
Q. What account was I paid from?
A. It was transferred from PGD as a profit
distribution. I don't know what account it might have
gone in or whether it was made out to you directly and
accredited as a personal distribution on the books. I
don't know.
Q. Have you found any -- other than handwriting
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on one of your deposit slips with my name on it, have
you found any bank record, such as a canceled check, a
wire transfer, or any record that shows you ever paid me
or my firm $1?
A. Believe me, we looked. We looked, and we
looked. Wachovia just does not have it.
Q. Would the answer to that question, Mr. O'Hare,
be simply no?
A. I'm sorry, to what question?
MR. SWEETAPPLE: Would you read the question
back to the witness, please.
(A portion of the record was read by the
reporter.)
THE WITNESS: The answer is we looked and we
looked. We cannot find it. Wells Fargo, which
used to be Wachovia, which used to be that bank,
says they do not have it. I tried. I do not -- I
cannot find any record.
BY MR. SWEETAPPLE:
Q. Have you found any retainer agreement that I
have ever signed with you, any of your family members,
or any entity that you have an interest in --
A. No.
Q. -- ever? Have you found any letter that I
have written that I've ever signed my name to?
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1 1 A. No.
2 Q. Have you found any -- I'm a trial lawyer. You
3 know that, right?
4 A. I'm getting that impression.
5 Q. Okay. When you look in the public records for
6 Palm Beach County, you will find hundreds of lawsuits
7 that me and my firm have been involved in over the last
8 35 years. Same thing is true for Broward County, Dade
9 County, to a lesser extent Okeechobee, Martin County,
10 and various jurisdictions throughout the country.
11 Have you found one legal pleading, one legal
12 document in any court anywhere that I have ever signed
13 on behalf of you or any family member or any entity in
14 which you have an interest?
15 A. I haven't looked.
16 MR. HANNA: Object to form.
17 THE WITNESS: I haven't looked.
18 BY MR. SWEETAPPLE:
19 Q. Okay.
20 A. But I don't believe I've ever seen anything
21 like that.
22 Q. Well, you did testify that you thought I
23 represented you in a lawsuit?
24 A. Yes.
25 Q. But you've never -- you didn't go look to see
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if you could find any pleading that had my name on it
and your name on it?
A. Well, define "lawsuit," sir.
Q. Well, have you -- have you looked to see if my
name appeared on any pleading or any paper that I had
signed on your behalf?
A. I don't believe your representation ever
extended to actually filing a claim against someone or
defending against a claim.
Q. Now, you have provided me with Exhibits B, C,
and D, which were attached to your response -- strike
that. Which were attached to your supplemental
response. And I'm going to mark these as B, C, and D.
You had them as B. I'm going to do them as B, C, and D
for the depo, defendants.
Can you tell me what these pictures are?
(Defendant's Exhibit Nos. B, C, D were marked
for identification.)
THE WITNESS: B, C, and D are all pictures
that I took of tapes -- taped testimony that I came
across in one of the boxes, found similar to the
other boxes, that had a note to Robert Sweetapple.
They're all pictures of the same note but in
different positions.
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BY MR. SWEETAPPLE:
Q. What do you mean "in different positions "?
A. Well, I mean, here the note is folded in
No. B. In No. C, the note is open on one side. In
No. D, the note is open with the reverse side showing.
Q. Why is that?
A. I was trying to produce the production of
evidence that you requested without you having to
physically have the tapes. I figured you would get
those later. But that's why I took the pictures.
Q. So how many stickums were there?
A. How many what?
Q. How many stickums? Those are stickums.
A. It's a single stickum. A single Post -it.
Q. Okay. And how many tapes were there?
A. I guess -- I'm sorry, eight. I'm counting
eight.
Q. So pass me those back. So you're saying you
recently found in a box, tapes, and attached to the
tapes was "to Robert Sweetapple "?
A. A single stick -- the tapes were bound
together with a rubber band with a sticker inside one of
the taped boxes.
Q. And the -- and the stickum said "to Robert
Sweetapple "?
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A. One side said "to Robert Sweetapple."
Q. And it was stuck onto the tapes?
A. It was inside one of the plastic cassette
boxes.
Q. Okay. And then this was the other side, "Bob,
these are the cassette tapes of Chief Hillary
interviewing my neighbors. Chris Curry is the guy with
the property next to" -- what's that say?
A. "Bob, these are the cassette tapes of Chief
Hillary interviewing my neighbors. Chris Curry is the
guy with the property next to 21 Tropical that was
designed by Commissioner Digby Bridges." Chris O'Hare,
signed.
Q. Okay. And you had all these tapes?
A. They were in a box, yes.
Q. Okay. Do you know if these tapes were ever
given to me?
A.
I remember
that in
the --
Q.
Yes or no?
Do you
know if these tapes were
ever given to me?
A. To my best recollection, they were.
Q. Okay. Where -- were they given to me?
A. I don't remember that.
Q. When were they given to me?
A. I don't remember that.
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Q. Who was present when you gave them to me?
A. I don't remember that.
Q. What -- what month was it?
A. I can't tell you that. I don't remember.
Q. What year was it?
A. 1998.
Q. And do you have -- and so why do you have --
if these were given to me, do you have the original
stickums?
A. Yes.
Q. Why would you have the original stickums if
you gave these tapes to me?
A. Because you gave them back to me.
Q. I did?
A. You gave me a bundle of material back when
that code enforcement action was over.
Q. Was this part of the code enforcement file?
A. Yes.
Q. And what -- what documents do you say were
given back to you?
A. I'm sorry?
Q. What documents do you say were given back to
you?
A. Everything that I had handed to you as
evidence in the code enforcement action for you to
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prepare your defense.
Q. Where did you find these tapes?
A. In a box.
Q. What else -- was there anything else in the
box that had my name written on it?
A. Photos.
Q. Of what?
A. 21 Tropical Drive.
Q. Anything else?
A. Yes. Everything that I produced for you was
in different boxes in the same general location.
Q. But in this box with the tapes was there any
retainer
agreement?
A.
I'm sorry?
Q.
Was there a
retainer
agreement?
A.
No. I never
found a
retainer.
Q.
Any letters
from me
or files that were there?
A.
Never found
anything
else. Just what I turned
over to you.
Q. Just these tapes in that box?
A. What I turned over to you.
Q. In that box was just these tapes?
A. I can't tell you now accurately whether that
box also contained the photos or the photos were in an
adjacent box, but they were all in the general -- the
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same vicinity.
Q. Okay. Where are the photos that you -- you
haven't provided me any photos in this case. Did you
find photos?
A. They should be turned over to you, sir.
Q. Okay. Well, they're not part of this file, I
don't believe, but let's -- I've got some diagrams but
not photos. So we'll go through what you produced, and
we'll see if you have any photos.
MR. ROEDER: Original. I think there's a
photo -- I think the photo you're referring to,
Chris --
MR. SWEETAPPLE: Let's not have any speaking
objections, please. We're having a deposition
here.
MR. ROEDER: I'm trying to clarify.
MR. SWEETAPPLE: Well, that's -- that's not
appropriate.
MR. ROEDER: Do it later.
BY MR. SWEETAPPLE:
Q. So your testimony is you gave me these tapes
with the stickum, and you got them back with the
stickum?
A. The stickum was on the inside of one of the
cassette boxes.
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Q. And these tapes refer to a -- a code violation
in the town of ocean Ridge?
A. Yes.
Q. In 1998?
A. Yes.
Q. Did you give these to Mr. Jonas?
A. I'm sorry?
Q. Did you give them to Mr. Jonas?
A. No.
Q. Was Mr. Jonas there when you gave them to me?
A. I don't recall that.
Q. Did you give them to me personally?
A. I can't recall that.
Q. Did you drop them off at my office?
A. I can't testify as to whether I dropped them
off or I sent them over.
Q. Did you send it by Federal Express?
A. No.
Q. Did you have a runner bring them over?
A. I can't remember that.
Q. Do you recall specifically bringing these to
my office?
A. No.
Q. Do you recall specifically getting them back
from me?
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Q.
You recall coming to get them?
A.
I remember the day that I got the check back
with the small
balance that was left over, being handed
a box with
different sundry things in it.
Q.
Okay. But you didn't testify to that when I
took your
deposition in October.
A.
I guess I didn't recall it at the time.
Q.
Okay. So now you recall that occurred?
A.
Having -- having seen these things, it
refreshed
my memory.
Q.
And in your last deposition, you told me you
had some --
well, let me ask you this. The -- the
representation
in 1998, had -- did it involve any public
records request?
A.
Yes.
Q.
There were public records requests?
A.
Yes.
Q. Who made public records requests in 1998?
A. I did.
Q. You did?
A. Yes.
Q. Who did you make them on?
A. Who did I make them what?
Q. What public records requests did you make in
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1998?
A. I requested the -- what is it called? The
construction file for 21 Tropical Drive, the permit
file. As well, I requested the permit files on similar
properties before and after my permit.
Q. Okay. So you went to city hall and did that,
town hall?
A. Yes, to Karen and whoever the other girl is
working there.
Q. Okay. And at the time -- how many public
records requests did you make in 1998?
A. To give you a range, it would be between maybe
5 and 15.
Q. And that was in the town of Ocean Ridge?
A. Yes.
Q. Do you have copies of those?
A. No.
Q. Have you gone back and tried to get copies of
those?
A. No.
Q. Okay. But you did go back, and you -- you
asked for any records from Ocean Ridge from 1998 that
involved you, right?
Your attorney went to Ocean Ridge and made a
public records request?
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A. Right.
Q. And -- and the only documents that they had in
Ocean Ridge were the documents that were attached to
Mr. Jonas' deposition transcript, right?
A. The -- I don't -- I don't know what records
they have now, but at the time I requested permit
application records for my property and similar other
properties. I don't know if the town still has those or
not. I don't have them.
Q. That's not my question.
A. Okay.
Q. My question, it's a fact, isn't it,
Mr. O'Hare, that your attorneys made a request on the
town of Ocean Ridge, and the only documents that were
produced by the town from 1998, pursuant to that
request, were the memo, the letter to Mr. Nicoletti, the
memo, and the settlement agreement regarding your code
violation, correct?
MR. HANNA: I'm going to object to the
question.
BY MR. SWEETAPPLE:
Q. Are you aware what was -- what was provided by
the city of -- or the town of Ocean Ridge to your public
records request?
A. Most of it, yes.
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Q. Okay. Did you make a request for copies of
your public records requests in 1998?
A. No.
Q. Have you ever made such a request?
A. No.
Q. And your sworn testimony is that in 1998, you
made public records requests of the town of Ocean Ridge?
A. Yes.
Q. And whose name did you do it in?
A. I don't even think I gave my name.
Q. And when did you make these requests?
A. In 1998?
Q. Uh -huh.
A. I can't tell you an exact date. I can tell
you that I went into town hall. I went up to the
window. I asked for these records. I think it took
them a little while to get them, and they brought the
records out.
Q. And when was that?
A. 1998.
Q. When in 1998?
A. It's going to be in the spring of 198.
Q. Okay. And do you have copies of those
records?
A. No.
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them.
Q. Okay. Are you saying they -- that you gave
them to me with the tapes?
A. I believe I did, yes.
Q. Okay. So when did you -- when did you give
them to me? The same answers as to the tapes? You have
no idea?
A. It's the spring of 198, but I can't give you a
date or a time or anything more accurate than that.
Q. You don't know who was there, where it was,
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Q.
Where are those records?
A.
I want to say they're not in the package that
I got back
from you, but I remember giving them to you.
Q.
So you believe that you gave me the records
you got from
the town, but you don't know?
A.
I -- I was told to get records to establish
the claim
that the town was guilty of violating my civil
rights. I
think it was called a 1983 action. I found
records of
permits granted for what I was denied before
my denial
and after my denial. I handed all those over
to you. I
can't recall what happened to them.
Q.
Are you sure you did that?
A.
I'm sure I did that.
Q.
Okay. And did you get them back?
A.
I just said I can't recall what happened to
them.
Q. Okay. Are you saying they -- that you gave
them to me with the tapes?
A. I believe I did, yes.
Q. Okay. So when did you -- when did you give
them to me? The same answers as to the tapes? You have
no idea?
A. It's the spring of 198, but I can't give you a
date or a time or anything more accurate than that.
Q. You don't know who was there, where it was,
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anything of that nature?
A. No.
Q. You just know you gave me records, without any
recollection as to any details of it?
A. Well, I know that because they were the
subject of conversations we had.
Q. Okay. And in 1998, had you made any public
records requests from the Town of Gulf Stream?
A. No.
Q. When's the first time you made any public
records requests from the Town of Gulf Stream?
A. I think the spring of 2012.
Q. And when did you first meet Mr. Chandler?
A. I can't recall that.
Q. Was it 2012, 2013?
A. It wasn't 2012, I don't think. It was perhaps
2013.
Q. Okay. So --
A. Or thereabouts.
Q. So you did not know Mr. Chandler in 1998,
right?
A. No.
Q. And when is the first time you met Martin
O'Boyle?
A. I don't recall that.
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Q. How long ago did you meet Martin O'Boyle?
A. Maybe a year, year and a half.
Q. Ago?
A. Yeah, maybe. Maybe a year ago.
Q. Okay. So 2013?
A. No. Well, around about. I can't be sure the
exact date.
Q. Who did you meet -- who did you meet first,
Mr. Chandler or Martin O'Boyle?
A. I think -- I think Mr. Chandler, but I can't
Q. Okay.
A. I think it was Mr. Chandler.
Q. Okay. And did you ever sue Ocean Ridge
regarding any public records requests in 1998?
A. Sue them?
Q. Yes.
A. No. They were very cooperative.
Q. Did you ever sue anyone regarding any public
records requests in 1998?
A. No.
Q. When's the first time you ever filed a lawsuit
regarding a public records request?
A. I don't know. I didn't memorize the date.
Q. Was it 2012?
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Page 28
A. No.
Q. 2013?
A. I can't be sure of the exact date.
Q. Well, how long ago was it? Do you recall if
it's more than two years ago?
A. To answer that question, I'd have to know the
date, and I can't tell you the exact date.
Q. Do you recall what the first public records
lawsuit you filed was, what it was about?
A. No.
Q. Do you recall who you sued?
A. You know, I want to clarify that. I believe
it was about Officer Ginsberg's personal file.
Q. Okay. And that would have been in Gulf
Stream?
A. Yes.
Q. All right. And had you met Joel Chandler at
the time you filed that complaint?
A. I -- I can't recall.
Q. You didn't know Mr. O'Boyle, Martin O'Boyle,
in 2008, did you?
A. No.
Q. I mean, in 1998.
A. No.
Q. And how many times have you met with
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Page 29
A. I can't recall that.
Q. Have you ever met with Mr. Chandler and
Mr. Roeder?
A. Yes.
Q. Have you ever paid Mr. Chandler any money?
MR. HANNA: I'm going to object. This is
getting beyond the update deposition for purposes
of disqualification.
MR. SWEETAPPLE: How is that?
MR. HANNA: It's getting into Joel Chandler
and his relationship with Joel Chandler and
payments to Joel Chandler. How does that have to
do with the motion to disqualify?
MR. SWEETAPPLE: Do you know what the standard
is for a motion to disqualify?
MR. HANNA: Yes, I do.
MR. SWEETAPPLE: What is it?
MR. HANNA: I'm not going to argue with you.
I'm just telling you --
MR. SWEETAPPLE: Do you know what it is? Why
don't you just put on the record what the legal
standard is since you --
MR. HANNA: I'm not going to argue with you
about --
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MR. SWEETAPPLE: The legal standard is you've
alleged that it is my -- that I represented him in
1998 --
MR. HANNA: Right.
MR. SWEETAPPLE: -- and that my representation
is substantially related to the matters of my
representation now.
MR. HANNA: Right.
MR. SWEETAPPLE: And I am attempting to take
discovery regarding the matters concerning my
representation now, to establish that the people,
the events, the causes of action, the
communications have absolutely nothing in the world
to do with what occurred in Ocean Ridge, according
to his testimony. So I'm permitted to go into this
area as a matter of law. So I would appreciate if
you allow me to continue my inquiry.
Please read the question back.
You're the one that put into issue whether or
not my representation -- and now we have the
lawsuit filed, and we can go through -- on the
record -- we can go through the record. Now
instead of speculating, as you were when you filed
your motion to disqualify, we can actually look at
the scope of my representation and see if it's
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substantially related to what happened in 1998 or
not, because that's what our trial is going to be
about.
MR. HANNA: And your trial also is about Edwin
Jonas, when you said you had no recollection of
ever meeting Mr. O'Hare.
MR. SWEETAPPLE: I don't.
MR. HANNA: And Edwin Jonas testified about
your handling -- being a point person for the code
enforcement hearing, at least for Mr. O'Hare, in
MR. SWEETAPPLE: So let's go on -- let's go on
with the testimony.
MR. HANNA: Okay. I'm just telling you,
getting into Joel Chandler, relationship and
payment to Joel Chandler, has nothing to do with
the motion to disqualify.
MR. SWEETAPPLE: Yes, it does. Yes, it does,
because this case involves paying people for --
paying people or getting consideration to file
public records requests as part of a scam and a
fraud, which has nothing to do with what --
MR. HANNA: This is updated deposition --
MR. ROEDER: You're going way broad.
MR. HANNA: -- for the motion to disqualify.
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Page 32
MR. SWEETAPPLE: That's right.
MR. HANNA: Okay.
MR. SWEETAPPLE: That's right.
MR. HANNA: You know what --
MR. SWEETAPPLE: Let me go on.
MR. HANNA: Go ahead.
BY MR. SWEETAPPLE:
Q. Mr. O'Hare, when you filed the motion to
disqualify, had I filed any pleadings in any case at the
time you filed the motion to disqualify?
A. You're asking me the same question over and
over.
Q. No.
A. There's no pleadings I know -- I'm sorry, ask
that question again.
Q. When you filed --
A. I want to make sure I -- I understand.
Q. Are you aware you filed a motion to disqualify
in a case where I had never filed a pleading?
MR. HANNA: I object to form. Confusing.
BY MR. SWEETAPPLE:
Q. Are you aware that you filed motions to
disqualify me in cases where I had never even appeared?
A. You're saying you never made a notice of
appearance in the cases I filed to disqualify you?
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Page 33
Q. About ten of them. Are you aware of that?
A. I'm sorry, ten that you didn't or did?
Q. Ten that I didn't. Are you aware that based
on an alleged conversation Mr. Hanna says he had with
me, that he filed motions to disqualify me in cases
where I hadn't even appeared?
MR. HANNA: Object to form.
Mischaracterization. There was an e -mail from
Mr. Sweetapple that said that I'm going to be
filing appearances in all cases by Mr. O'Hare.
BY MR. SWEETAPPLE:
Q. So are you aware that based on an e -mail,
Mr. Hanna on your behalf filed motions to disqualify me
in cases where I had not even appeared? Are you aware
of that? Yes or no?
A. You're telling me lawyers are going to lie to
each other about this?
Q. Yes or no? Are you aware as the client that
your lawyer filed motions to disqualify me in a number
of cases where I had not even appeared?
A. I don't have sufficient information to make an
answer to that.
Q. So you don't know the answer?
A. My answer is, you were intending to appear,
and we filed. Now, it's funny that on the one hand
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Page 34
you're -- you're giving me a hard time because I filed
it. The other hand you're giving me a hard time because
I waited too long to file it. This is kind of funny,
Bob, really.
Q. Well, that's because you don't understand the
point I'm making, clearly, from the grin on your face
and the remark --
A.
I'm not
a lawyer,
so...
Q.
-- the
remark you
just made. So in the -- in
the --
MR. ROEDER: Please ask the question.
BY MR. SWEETAPPLE:
Q. Okay. In order to disqualify a lawyer, you
have to show that the current representation is
substantially related to the prior representation. Are
you aware of that?
A. Yes.
Q. When you filed your motion to disqualify me in
cases where I hadn't even appeared, what did you
understand was going to be the scope of my
representation?
MR. HANNA: I'm going to object to form.
THE WITNESS: I understood you were joining
the town to file a RICO complaint against me to
represent them. As well, with the records that
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Page 35
I've seen from Jones Foster, et cetera, that you
had every intention of advocating for the town
against me.
BY MR. SWEETAPPLE:
Q. Okay. Against you on what -- what claims?
A. I think anything you could think up.
Q. Okay. Well, what claims -- when you filed the
motion -- when you filed the motion to disqualify me in
this case, had there been any pleadings filed by me?
Had I filed any pleadings against you?
A. I don't know that.
Q. Okay. Are you aware that I had just filed a
notice of appearance and had not filed any pleadings
against you when you moved to disqualify me on this case
that we're here on now?
A. I don't have enough information to answer
that; so the answer is, no, I wasn't aware.
Q. So when -- when I appeared in this case, what
did you understand that my representation was going to
relate to?
A. Public records, RICO action, trespass on
public property. Just about everything the town and I
are litigating.
Q. And so you -- you really were speculating as
to what the scope of my representation was going to be
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Page 36
when you filed your motion to disqualify, right?
MR. HANNA: Object to form.
THE WITNESS: I was relying on information
given to my attorneys, who I believe to be honest.
BY MR. SWEETAPPLE:
Q. Okay. And what exactly did your attorneys
tell you that you relied on that had you assert in a.
pleading that my current representation was going to be
substantially related to the prior representation,
because that would not be privileged? That --
MR. ROEDER: Yes, it is.
MR. HANNA: I'm going to object. Instruct the
witness not to answer. It calls for
attorney - client communication.
BY MR. SWEETAPPLE:
Q. Okay. When you communicated -- when you
authorized Mr. Hanna to file a motion that the
representation was substantially related, did you
communicate to him what you believed my representation
was going to be?
MR. HANNA: I'm going to object and
instruct --
BY MR. SWEETAPPLE:
Q. Without going into what you said, did you --
did you -- strike that.
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Page 37
Did you -- did you have any knowledge as to
what my representation was going to be?
MR. HANNA: I'm going to instruct the witness
not to answer the question.
MR. SWEETAPPLE: I was just asking if he had
any knowledge.
MR. HANNA: I'm asserting the privilege, so
you can move on to another question.
MR. SWEETAPPLE: Okay. Go ahead and certify
all these. Make a certificate for me.
BY MR. SWEETAPPLE:
Q. Did you understand that my representation
would have to do with allegations that you and your
coconspirators and agents, including Mr. Roeder, had
filed hundreds and hundreds of serial public records
requests against the Town of Gulf Stream?
MR. ROEDER: Object to form.
MR. HANNA: Object to form.
THE WITNESS: I don't have coconspirators,
sir.
BY MR. SWEETAPPLE:
Q. Okay. Are you -- are you currently
represented by Jonathan O'Boyle?
A. I have pro hac vice representation of
Jonathan.
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Page 38
Q. Of Jonathan. Do you have a fee agreement with
A. I don't recall exactly who's doing what right
Q. Have you ever paid Jonathan O'Boyle any fees?
MR. HANNA: I'm going to object to form --
SWEETAPPLE:
Q. Have you paid --
MR. HANNA: -- and also instruct the witness
not to test -- not to answer the question.
BY MR. SWEETAPPLE:
Q. In the case where you say I represented you,
you say you paid me fees, right?
A. Yes.
Q. With regard to this case, have you paid any
lawyers any fees?
A. Oh, boy, have I.
Q. Okay. What lawyers have you paid fees to?
MR. ROEDER: Objection.
MR. HANNA: I'm going to object and instruct
the witness not to answer.
MR. SWEETAPPLE: Why is that?
MR. HANNA: Attorney - client privilege.
MR. SWEETAPPLE: Okay. Under Florida and
federal law that the payment of --
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Page 39
MR. HANNA: Well, I'm not going to argue --
MR. SWEETAPPLE: Let me put on the record --
MR. HANNA: I'm not going to argue with you,
and there's no need to put it on the record. I
made the objection, instructed the witness not to
respond. You make the arguments in front of the
judge. No speaking objections. You -asked your
question; I asserted a privilege.
MR. SWEETAPPLE: And I'm going to put on the
record and proffer to you, because I've been
involved in this issue for many times and many
years, and you have to -- as a former US attorney,
the identity of the client, the payment of fees is
not a communication under federal or Florida law.
That is not covered by the attorney - client
privilege. So I'm going to ask --
MR. ROEDER: Then, Counsel, why did you -- why
did you not answer the question during your
deposition?
MR. SWEETAPPLE: Mr. Roeder, you're not
even -- you're not even counsel for this
deposition.
MR. HANNA: We're not arguing the point.
MR. SWEETAPPLE: Right. I'm just going to ask
it one more time, and then I'm going to -- then I'm
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Page 40
going to ask, have you paid --
MR. HANNA: It's also beyond the scope of an
updated deposition for purpose of the motion to
disqualify.
MR. SWEETAPPLE: No, it is not.
MR. HANNA: Okay. Bob, I'm not going to
argue.
BY MR. SWEETAPPLE:
Q. In this -- okay. Were you aware that part of
the scope of my representation would be to ascertain
your relationship with the O'Boyle Law Firm?
Were you aware that would be part of the scope
of my representation?
A. I'm sorry, I have to work this out in my head.
Your representation of the town in this public records
claim was going to include what?
Q. Your -- the scope of your relationship with
the O'Boyle Law Firm, the scope of your relationship
with Mr. Chandler, the scope of your -- your
relationship with Martin O'Boyle.
Did you understand when you filed your motion
to disqualify me that the scope -- one of the scopes of
my representation for the Town of Gulf Stream was to
ascertain the nature of your relationship with Jonathan
O'Boyle?
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Page 41
MR. HANNA: I'm going to object to the form,
but...
THE WITNESS: It never crossed my mind.
BY MR. SWEETAPPLE:
Q. Okay. Did it ever occur to you that the scope
of my representation was to ascertain the nature of your
relationship with Joel Chandler?
MR. HANNA: I'm going to object to form.
Well, actually, strike that.
THE WITNESS: I don't have an opinion on that.
BY MR. SWEETAPPLE:
Q. Were you aware -- were you aware that the
scope of my representation was to ascertain why you,
Jonathan O'Boyle, Mr. Roeder, and numerous others
associated with all of you, had filed almost 2,000
public records requests on the tiny town of Gulf Stream,
Florida?
MR. HANNA: Object to form.
THE WITNESS: I'm sorry, is this a question or
a speech?
. SWEETAPPLE:
Q. It's -- it's a question. Were you aware --
A. Am I aware --
Q. -- that was part of the scope of my
representation?
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Page 42
A. I don't have any knowledge of what your plans
are, your scope, or anything about what you're doing,
except that you're representing the town against me.
Q. So when you filed your motion, you had no idea
of what the scope of my representation was going to be?
A. Well, I already testified I believed you were
going to act on those cases that were currently pending
between the town and me.
Q. That I was going to come in to them and
represent the town?
A. Yes.
Q. But did you have any -- did you have any
knowledge of what the scope of my representation was
going to be when you filed the motion to disqualify me?
A. I guess what's bugging me is I don't
understand the word "scope."
Q. The -- the nature. What --
A. Your intention? The strategy? I don't know.
Q. The nature. What I was going to be attempting
to accomplish.
A. The nature?
Q. Right. What my goals were. What my -- what
the purpose of my employment was. Did you have any idea
what the purpose of my employment for Gulf Stream was
when you moved to disqualify me?
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MR. HANNA: I'm just going to object and note
for the record, I don't know if you're getting into
that confidential settlement meeting we had on
September 3rd, because you -- this was discussed --
MR. ROEDER: If you want to open it up, we'll
be glad to open it up.
MR. SWEETAPPLE: But your client's already
stood up, and he's already distributed information
regarding that to a number of people. I'll be
getting into that, but I'm not -- I'm not -- I do
not want you to discuss what was said at a
mediation, okay? I believe the motion to
disqualify was filed before the mediation.
MR. HANNA: It was after.
MR. ROEDER: It was not.
MR. SWEETAPPLE: After, okay. So I don't
want --
MR. ROEDER: But you're asking for his
impression.
BY MR. SWEETAPPLE:
Q. I don't want anything that was discussed at
the mediation. I don't want you --
A. I'm sorry, are you instructing me how I should
answer?
Q. Yeah. Do not -- I'm telling you, as your
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lawyers are telling you, that the law does not allow you
to discuss what happened at the mediation. You're aware
you were at a mediation?
MR. ROEDER: I object.
THE WITNESS: The agreement I signed?
BY MR. SWEETAPPLE:
Q. Yes.
A. Don't discuss anything covered by the
agreement that I signed?
Q. Right. Did you discuss with anyone what was
said at that -- at that meeting where the agreement was
signed?
MR. HANNA: Form.
THE WITNESS: Not in regard to what I signed.
BY MR. SWEETAPPLE:
Q. Did you discuss with anyone, other than
Mr. Hanna who was present and Mr. Roeder who was
present, what you -- what was discussed at that -- at
that mediation?
MR. HANNA: I'm going to object to the -- and
instruct the witness not to answer to the extent of
discussions that -- with any attorneys.
MR. SWEETAPPLE: Well, any attorneys that
weren't there are entitled to hear it.
MR. ROEDER: For the record --
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Page 45
1 MR. HANNA: There is no need to -- there is no
2 need to argue.
3 BY MR. SWEETAPPLE:
4 Q. Did you discuss with Jonathan O'Boyle or
5 anyone at the O'Boyle Law Firm what was discussed at
6 that mediation?
7 MR. HANNA: I'm going to object and instruct
8 the witness not to answer.
9 BY MR. SWEETAPPLE:
10 Q. Was Mr. Jonathan O'Boyle representing you with
11 regard to anything at that mediation?
12 MR. HANNA: I'm going to object and instruct
13 the witness not to answer, because you're getting
14 into the content of the --
15 MR. ROEDER: Getting into the content.
16 BY MR. SWEETAPPLE:
17 Q. Have you paid any money to Jonathan O'Boyle
18 ever?
19 MR. HANNA: I'm going to object and instruct
20 the witness not to answer.
21 BY MR. SWEETAPPLE:
22 Q. Have you paid the O'Boyle Law Firm any
23 attorney's fees ever?
24 MR. HANNA: I'm going to object and instruct
25 the witness not to answer.
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BY MR. SWEETAPPLE:
Q. And have you -- do you have any written fee
agreements with the O'Boyle Law Firm?
MR. HANNA: I'm going to object and instruct
the witness not to answer.
BY MR. SWEETAPPLE:
Q. You are seeking attorney's fees where the
O'Boyle Law Firm represents you, are you not? You have
cases that the O'Boyle Law Firm has brought?
A. Yes, I have cases where the O'Boyle Law Firm
represents me.
Q. And you were told that I was going to be
getting involved in those cases, right?
MR. HANNA: Object and instruct the witness
not to answer. Attorney - client. Unless it's --
MR. SWEETAPPLE: He's already testified that
that's what he was told, and that's why the motion
to disqualify was filed, so why are you invoking
the attorney - client privilege?
MR. ROEDER: Counsel, he was told by you.
MR. SWEETAPPLE: No. He says he was told that
by his attorney.
MR. ROEDER: No. That's what you just said.
MR. SWEETAPPLE: No. He's testified already.
He's testified already. It's in the record.
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THE WITNESS: Are you asking me again?
BY MR. SWEETAPPLE:
Q. Because I want to lay a predicate for the fact
that you moved to disqualify me in cases where the
O'Boyle Law Firm is your attorneys, have you not?
A. You mean the --
Q. Okay. Strike that.
A. -- cases that --
Q. Strike that. I'm going to -- I'll go about it
another way.
Do you have any written retainer agreements
with Mr. Hanna?
A. I'm sorry, what kind of agreements?
Q. Do you have any written retainer agreements
with Mr. Hanna?
A. Yes.
Q. Are you paying him hourly or on a
contingency --
MR. HANNA: I'm going to object to the form.
BY MR. SWEETAPPLE:
Q. -- regarding this case?
MR. HANNA: I'm going to object and instruct
the witness not to answer.
MR. SWEETAPPLE: You have a fee claim in this
case.
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MR. HANNA: I do, but until you -- you want to
stipulate to entitlement to fees and liability?
MR. SWEETAPPLE: I'm entitled to find out the
nature of your fee agreement.
MR. HANNA: Not at this juncture.
MR. SWEETAPPLE: Sure, I am. I'm not entitled
to find out the -- to get your bills, but I'm
entitled to find out.
MR. HANNA: I made my objection.
BY MR. SWEETAPPLE:
Q. Do you know -- do you --
MR. HANNA: He's not going to answer the
question.
BY MR. SWEETAPPLE:
Q. And -- and Mr. Roeder -- do you have a
written -- do you have a written fee agreement with
Mr. Hanna?
MR. ROEDER: Object. Same reasons.
BY MR. SWEETAPPLE:
Q. Do you have a written fee agreement with
Mr. Hanna regarding this case -- with Mr. Roeder? Do
you have one with Mr. Roeder?
MR. ROEDER: Objection. Please do not answer.
MR. SWEETAPPLE: You're not an attorney in
this deposition.
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MR. HANNA: Yes, he is.
MR. ROEDER: Yes, I am.
MR. SWEETAPPLE: Only one person can make
objections.
MR. HANNA: I'll object and instruct the
witness not to answer.
BY MR. SWEETAPPLE:
Q. And do you -- did you know Mr. -- did
Mr. Djajaputa -- putra, did you -- was he in your employ
in 1998?
A. I -- yeah, I think so. Yes.
Q. Okay. And did he ever file any public records
requests for you prior to 2013?
A. You're asking me if he's filed some but not
before?
Q. I just --
A. He's never filed -- he's never filed a record
request for me.
Q. He hasn't. Have you ever filed a record
request for him?
A. No.
Q. Are you aware of whether or not Mr. Djajaputra
has ever filed any public records requests with the city
of -- Town of Gulf Stream?
A. I would doubt that, but, no, I don't think so.
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Q. Okay. And are you -- have you ever filed suit
on behalf of Mr. Djajaputra with regard to public
records requests that were filed?
A. No.
Q. Do you have a -- do you have a power of
attorney for Mr. Djajaputra, D- j- a- j- a- p- u- t -r -a?
A. No.
Q. So has he ever given you permission to file a
public records request on his behalf?
A. No.
Q. Are you aware of any public records requests
that he's filed?
A. I'm sorry, am I --
Q. Are you aware of any public records requests
he's filed?
A. No.
Q. Okay. Irnawaty Tirtarahardja, did Irnawaty
Tirtarahardja work for you --
A. She would not --
Q. -- in 1998?
A. She would not like me to say her name like
that.
Q. Did she work for you in 1998?
A. Irnawaty, yes, worked for me in 198.
Q. Did she ever file any public records requests
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Page 51
to your knowledge in 1998?
A. Not that I know of.
Q. Okay. Has she filed any public records
requests in 2014?
A. I don't know of any she's ever filed.
Q. Have you ever filed any on her behalf?
A. No.
Q. Have you ever made any requests for public
records on her behalf?
A. No.
Q. Do you have any authority to make public
records requests on her behalf?
A. No.
Q. Has she ever told you she's made any public
records requests?
A. She's never said that to me.
Q. And have you ever filed a lawsuit where you
include her name as being someone who you were
authorized to make a public records request on behalf
of?
A. No.
Q. Have you ever -- do you have a power of
attorney from Irnawaty Tirtarajardja to bring public
records requests?
A. I'm sorry, say power of attorney --
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Q. Do you have a power of attorney to make
requests or file lawsuits on her behalf?
A. No. No.
Q. Are you aware whether or not she has, in fact,
made public records requests on April 14, May 3rd,
May 3rd, May 3rd, May 5th, May 18th, May 18th, May 18th,
May 18th, May 18th, May 23rd, May 23rd, May 23rd,
June 6, June 6, June -6, June 6, June 6, June 6,
April 27, April 27, April 27, April 14, April 14 of
2014?
I'm going to object to the form.
Q. Are you aware of any of those requests?
A. The question is, am I aware of those requests?
Q. Yes.
A. Yes.
Q. Okay. How are you aware of those requests?
A. I can see it on the piece of paper you're --
Q. Is that the first time you became aware of
them, was today?
A. No.
Q. When's the first time you became aware of
those requests?
A. When I made them.
Q. You made those requests?
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A. Yes.
Q. On behalf of who?
A. Me.
Q. How did you make those requests on behalf of
you?
A. With my e -mail account.
Q. And did you use her name?
A. Yes.
Q. Why did you use her name?
A. P -- what's -- what's the phrase -- Pictamara.
(phonetic) Used the name.
Q. Did you have permission to use her name?
A. Yeah.
Q. You asked her permission to use her name to
make public records requests?
MR. HANNA: Objection. Asked and answered.
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. So how did you have permission to use her
name?
A. To create Gmail account, Gmail account.
Q. You had her permission to create a Gmail
account?
A. Yes.
Q. Did you tell her what you were going to use
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the Gmail account for? Page 54
A. Yes.
Q. Did you tell her you were going to make public
record -- make serial public records requests at the
Town of Gulf Stream with her name?
A. What do you mean "serial "?
Q. I mean filing multiple requests, robo requests
in one day or in one week.
MR. HANNA: Object. I'm going to object to
the form.
THE WITNESS: What do you mean "robo "?
BY MR. SWEETAPPLE:
Q. I mean -- I mean sort of like what Mr. Roeder
does. Let's take Mr. Roeder, for example. Let's turn
to Mr. Roeder. What is your relationship to Mr. Roeder?
Is he your attorney?
A. Yes.
Q. Is he on your payroll? Is he a paid employee?
A. I'm not sure what you mean by that.
Q. Is he a paid employee?
A. No.
Q. Okay. Do you pay him -- do you have a written
fee agreement with him?
A. I think so, yes.
Q. And how long --
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Page 55
A. I take that back. I have an agreement with
him. I can't go into details of it.
Q. Is it in writing or oral?
A. It's a written agreement.
Q. Okay. How long have you had a written
agreement with him?
MR. ROEDER: I object to the --
BY MR. SWEETAPPLE:
Q. Have you ever -- have you ever authorized
Mr. Roeder to make public records requests for you?
A. Requested.
Q. You've asked him to?
A. Yes.
Q. And how many times have you asked him to make
public records requests for you?
MR. HANNA: I'm going to object and instruct
the witness not to answer.
BY MR. SWEETAPPLE:
Q. When you asked him to make public records
requests, you didn't do that with the expectation it
would be confident -- in confidence. You expected him
to go do that, right?
MR. ROEDER: Object.
MR. HANNA: I'm going to object and instruct
the witness not to answer. You're presuming that
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Page 56
every request that he's asked him to do has been
filed.
MR. ROEDER: Having trouble finding it?
MR. SWEETAPPLE: I'm looking at -- I'm amazed
at the number I'm looking at.
BY MR. SWEETAPPLE:
Q. Let's go back to Tahaty (Phonetic) I think.
When you -- when you -- with regard to Tahaty, did --
you told her you were going to be making public records
requests on the Town of Gulf Stream?
A. I said to Irene -- that's her nickname -- may
I use your name to create a Gmail account so I can use
it to make public record requests. I didn't ask her
permission. I just asked if I could use her name to
create the account, and I told her what I planned on
doing with it.
Q. Did you tell her how many public records
requests you were going to make in her name?
A. No.
Q. Did you ever show her the public records
requests you made?
A. I need to go back and clarify that. Your
question was, did I tell her how many I was going to
make in her name?
Q. Yeah.
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A. I didn't make any in her name.
Q. Did you ever use her name with regard to the
requests?
A. I used her name to create a Gmail account.
Q. Okay. And you made the requests in the Gmail
account name --
A. Yes.
Q. -- in that account?
A. Yes.
Q. Was that your account or her account?
A. I created the account. It would be my
account. I have the password. No one else had a
password to it.
Q. Okay. So it was your account, but you -- you
opened it up in someone else's name?
A. I used her name to create a Gmail -- I
don't -- I don't remember the exact term that Gmail uses
when you fill in the boxes, but it's basically a user
name.
Q. And why did you do that rather than making
public records requests in your name?
A. I was having trouble keeping track, and I
tried different methods to isolate my requests so that
the responses and the back and forth trying to finally
get a record -- I didn't get mixed up with all the other
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requests.
Q. And with regard to Janto D- j- a- j- a- p- u- t -r -a,
did you open up a Gmail account for him?
A. No.
Q. Did you open up an account for him?
A. It's identical to Irene's use of her name
and -- as a user..name far the Gmail account. I asked
Janto if I could use his name to open up an account
because I wanted to ask for public records, and it's
just a random name. It just occurred to me to use his
name. He didn't have a problem with it.
Q. And --
A. He gave me his permission to use his name.
Q. Did you tell him how many public records
requests you were going to make using his name?
A. No.
Q. Did you ask him permission to make public
records requests using his name?
A. No.
Q. And why did you make public records requests
using his name?
A. It just came into my head when I was opening
the account.
Q. What about Rodrigo Tejera, is that an employee
of yours?
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A. Yes.
Q. And did you open up a Gmail account in the
name of Rodrigo Tejera?
A. All answers are the same for the other two
people.
Q. Okay. These are all employees of Pineapple
Grove Designs, LLC?
A. The three you mentioned, yes.
Q. And Pineapple Grove Designs, LLC, pays their
salary?
A. Yes.
Q. Did any of those -- did Mr. Tejera ever submit
any of the public records requests, or were they all
submitted by you?
A. I submitted all the requests on those
accounts. They were my accounts.
Q. And what about Tina Martin, is she an employee
of yours?
A. Yes.
Q. And did you submit public records requests in
her name?
A. I used her name to create the account.
Q. And what about Billy Trasher? Who is Billy
Trasher? Is that a pseudonym that you use, Mr. O'Hare?
A. A pseudonym?
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Q. Is that a -- was that an alias that you use,
Billy Trasher?
A. It's just a name to create the account.
Q. Did you open up an account under the name of
Billy Trasher?
A. I opened up a Gmail account under Billy
Trasher.
Q. And why did you open up an account in the name
of Billy Trasher?
A. Because Gmail prompts you to put something in
there, and it's the first thing that came to my mind.
Q. And does that relate to Bill Thrasher, the --
the town manager at Gulf Stream? Is that how you came
up with the name?
A. How do you mean "relate "?
Q. Is that what gave you the idea to use the name
Billy Trasher instead of Bill Thrasher?
A. I don't know where the idea came from. It
just came to me.
Q. Okay. And did -- and you filed -- why did you
file public records requests under the name of Billy
Trasher?
A. Again, trying to isolate the number of
requests made by each Gmail account so I could keep
better track of the correspondence back and forth.
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Trying to get the records is not always easy.
Q. And how many -- and how many public records
requests did you make under the name Billy Trasher?
A. At that time, I believe I was stopping at ten.
However, that would not include the second request for
the same record or clarification e -mails or things like
that, but typically about ten.
Q. So you were stopping at ten per name you used?
A. Yeah. Just for the sake of not getting
overwhelmed with information, having to search for it.
Q. Okay. And in 1998, you didn't -- you didn't
know who Bill Thrasher was, did you?
A. 1998, no.
Q. Okay. And in 1998, you never talked with me
about filing serial public records requests using
pseudonyms, did you?
MR. HANNA: Object to form.
THE WITNESS: No. We never had that
conversation.
BY MR. SWEETAPPLE:
Q. And do you know a company by the name of
Air -- Airline Highway, LLC?
A. No.
Q.
Have
you ever
heard
of that
entity?
A.
I've
seen it
on the
town's
public record --
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Q. And do you -- do you know --
A. -- website.
Q. Do you know if that's an O'Boyle company?
A. No.
Q. Okay. Do you -- do you communicate by Martin
O'Boyle with e -mail -- by e -mail?
A. I'm sorry?
Q. Do you communicate with Martin O'Boyle by
e -mail? Have you ever communicated with him?
A. I have in the past, yes.
Q. Do you have his e -mail address in your phone?
A. Not in my phone, no.
Q. In your computer system?
A. Yes. Well, it's not in my system. It would
be on my Gmail accounts.
Q. Okay. And do you use any other server besides
Gmail for your e- mails?
A. Yes.
Q. What other servers do you use?
A. Mail.com.
Q. What is your -- what are your e -mail
addresses?
A. I'm sorry, I wasn't finished.
Q. Yeah. Please give me all your -- the Gmail,
what is your -- what is your real Gmail address as
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opposed to the ones you've used with -- that we just
discussed?
MR. ROEDER: Object to form.
BY MR. SWEETAPPLE:
Q. What is your actual Gmail --
MR. HANNA: I'm going to object to form.
BY MR. SWEETAPPLE:
Q. What is your Gmail e -mail address?
A. They're all -- they're all real.
Q. Okay. What are -- what are they?
A. I don't have them -- I haven't memorized them
Raw
Q. Okay. What is your -- do you have a Chris
O'Hare Gmail address?
A. I have chrisoharegulf --
chrisoharegulfstream @gmail.com.
Q. And what other e -mail addresses do you have?
A. I have pinegd @gmail.com.
Q. And what other?
A. I've got so many, I don't know.
Q. When you communicate --
A. I can't memorize them all.
Q. When you communicate with Martin O'Boyle,
what -- what e -mail address do you use?
A. I think that would -- that was probably
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limited to Pine GD.
Q. And what e -mail address is his, do you know?
A. No.
Q. Okay. Do you ever communicate with him by
text?
A. No.
Q. How many times have you e- mailed to Martin
O'Boyle in the last two years? Rarely or more than 100
times?
A. Are we still on this disqualification thing?
Q. Yeah, because I'm going to show that this has
absolutely -- what I'm doing in this case has absolutely
no relationship to anything that happened in 1998, and
I'm making a record of what I'm doing in this case for
that purpose, because your lawyer saw fit to open up
this area of inquiry, and I'm pursuing it.
MR. ROEDER: Do you have a question? I mean,
instead of going on a diatribe --
THE WITNESS: Just ask to be sure.
BY MR. SWEETAPPLE:
Q. Yes. I'm going to -- this does relate to the
scope of my representation that you're objecting to. So
how many -- how many times -- how -- how often do you
communicate with Mr. O'Boyle?
A. Oh, I have no way of testifying to that now.
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1
Q.
Have you e- mailed him more than 100 times in
2
the last two years?
3
A.
No.
4
Q.
Do you speak to him on the telephone?
5
A.
Once in a while.
6
Q.
How, by -- by portable phone, by cell phone?
7
A.
Cell phone, yes.
8
Q.
What is your cell phone number?
9
A.
My cell phone number?
10
Q.
Uh -huh.
11
A.
(561)350 -7551.
12
Q.
And is that AT &T?
13
A.
I think it's Verizon.
14
Q.
Okay. And do you know Mr. O'Boyle's cell
15
phone number?
16
A.
No.
17
Q.
Do you speak with Jonathan O'Boyle by cell
18
phone?
19
A.
Yes.
20
Q.
And what -- what is his cell phone number, do
21
you know?
22
A.
No. I have to confess, it's just a green
23
button on
my phone.
24
Q.
Okay. So you have him on speed dial?
25
A.
No. All my contacts just come up, and I don't
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know anybody's phone number anymore.
Q. Okay. And Americo Vespucci, is that -- is
that Christopher Columbus, or who is that really?
A. Just a made -up name.
Q. Okay. And did you make up the name Americo
Vespucci?
A.
Yes.
This --
that's my
creation.
Q.
Did
you create
an e -mail
account for Americo
Vespucci?
A. No.
Q. A Gmail account?
A. No.
Q. So when you made public records requests, why
did you use the name Americo Vespucci?
A. I'm not trying to be difficult. There's no
such thing. It's fictitious. I made the account up for
me. It's just a name I picked out of the air to create
the account, to make records requests for me.
Q. And on September 12, did you make a public
records request under the name Chris O'Hare on the Town
of Gulf Stream?
A. I don't have a Gmail account that says Chris
O'Hare.
Q. But did you make a request on the Town of Gulf
Stream in September 12th, 2014, in the name Chris
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O'Hare?
A. You're reading from a document. If you want
me to comment, I would be happy to examine the document.
Q. Do you recall whether or not you did?
A. On September 12th, I don't recall.
Q. And did you make a -- same day did you make a
request under the name thrasherlies?
A. I didn't memorize the dates I made requests.
Q. Did you ever make a request under
thrasherlies?
A. Yes.
Q. Are you aware you made one on September 12th,
the same day you made a request under the name Chris
O'Hare?
A. Yes.
Q. And are you aware on September 12th, 2014, you
also made a request under the name June Ellis?
A. Again, I can't testify to the date.
Q. Who is June Ellis?
A. Made -up name.
Q. Okay. That you made up?
A. Yes.
Q. And you gave that name to the town, right?
A. I gave that name to the town?
Q. Yeah, as part of a public records request.
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A. I used the name to create the account.
Q. And you also made a public records request to
the town on the same day, September 12, 2014, in the
name of William Bendex, (phonetic) correct?
A. I can't testify to the date. I don't know for
sure.
Q. Did you ever use the name William Bendex?
A. Yes.
Q.
Okay. Why
did you pick that name?
A.
Just came
into my head.
Q.
Is William
Bendex a real person?
A.
I have no
idea.
Q.
Is June Ellis
a real person?
A.
Married to
Jackie Gleason maybe. I don't
know.
Q. Okay. And then on September 12th, the same
day, you made a public records request on John Brewer.
Is that true?
A. I can't attest to the date. I didn't memorize
it.
Q. Okay. And do you -- is John Brewer an alias
that you have used?
A. I don't think those are aliases. I just
created the account using that name.
Q. And you made a public record request using
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that account, correct?
A. Yes.
Q. And is there a real John Brewer?
A. I don't know.
Q. And Harry Lafarge, have you used that name?
A. Yes.
Q. Is that a real person?
A. I don't know if there's a Harry Lafarge out
there.
Q. Okay. And then you -- there's one made out on
September 12th by Martin E. O'Boyle. Did you ever make
a public record request in Martin E. O'Boyle's name, or
did he just happen to make a request the same day that
you had made one, two, three, four, five, six, seven
requests in seven different names?
MR. HANNA: I'm going to object to form.
THE WITNESS: No. I have no idea what kind of
requests Mr. O'Boyle makes.
BY MR. SWEETAPPLE:
Q. Did you ever make a request in the name of
Martin E. O'Boyle on September 12th, 2014?
A. No, never.
Q. Do you know why he made a request the same day
you made one, two, three, four, five, six, seven
requests using your name and six aliases?
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A. I think he probably wanted a record.
Q. Did you talk to him on September 12th, 2014,
by cell phone?
A. I have no idea.
Q. Did you e -mail him on September 12th, 2014?
A. I have no idea.
Q. Did you ever discuss with Mr. O'Boyle that you
were filing records requests with the Town of Gulf
Stream?
A. Yes.
Q. How many times have you talked to Mr. Martin
O'Boyle about the fact that you were going to be filing
public records requests with the Town of Gulf Stream?
A. I couldn't -- I don't -- I don't know.
Q. More than a dozen?
A. Perhaps at each commission meeting we've
discussed things like that, but I couldn't give you a
number.
Q. Did you ever report to Mr. O'Boyle when you
were filing public records requests?
A. You mean as a subordinate?
Q. Did you ever, yeah, tell him -- just say,
Marty, I filed this many public records requests?
A. No, never coordinated anything or asked
permission or had any correspondence regarding my
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activity in public records, other than to say, I filed
public records requests, too.
Q. Did you ever tell him that you had filed
public records requests?
A. We discussed public records. I can't remember
whether I told him what you're asking me.
MR. HANNA: Bob.
BY MR. SWEETAPPLE:
Q. Did Mr. O'Boyle ever tell you when he was
filing a public record request?
A. I don't remember that.
MR. HANNA: Bob, can we take a break in a
little bit?
MR. SWEETAPPLE: Sure.
BY MR. SWEETAPPLE:
Q. What about We Love Gulf Stream; is that an
account you used?
A. Yes.
Q. What about Nevada Smith?
A. Yes. That's actually an employee, or was.
Q. Nevada Smith is an employee of yours?
A. Yeah, Frank Nevada Smith.
Q. Did you ask him permission to open up a Gmail
account?
A. I asked permission to use his name?
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Q. To make a -- to make a Gmail account?
A. Yeah. Just said, can I use your name to make
a Gmail account.
Q. And did you tell him that you were going to be
making public records requests?
A. -Yeah. I think I did, yes.
Q. And he gave you permission?
A. Yeah.
Q. You're sure of that?
A. I recall that. That's the best of my
recollection.
Q. Well, I'll find out from him, but that's your
best recollection.
A. He no longer works for me, by the way.
Q. And CG Acquisition Company, are you familiar
with that entity?
A. I'm sorry, I didn't hear you.
Q. CG Acquisition Company?
A. I have no idea who that is.
Q. Our Public Records, LLC?
A. No. I don't know who that is.
Q. These Gmail accounts that you've described,
none of those existed in 1998, did they?
A. No.
MR. SWEETAPPLE: All right. Let's take a
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break.
(At 3:52 p.m. a recess was taken.)
THE VIDEOGRAPHER: The time is 4:03. We're
back on the record.
BY MR. SWEETAPPLE:
Q. Now, Mr. O'Hare, are you aware that on
February 14th of last year, you served one, two, three,
four, five, six public records requests in your name;
and the same day, Citizens Awareness Foundation
submitted one, two, three, four, five, six?
A. I was not aware of that.
Q. Okay. And are you aware that on the 17th of
February, you submitted 1, 2, 3, 4, 5, 6, 7, 8, 9, 10,
11, 12, 13, 14, 15, 16, 17 public records requests on
February 17th?
A. No. I did not memorize the date when I make
my requests.
Q. But you -- are you aware that you made that
many requests on February 17?
A. I did not memorize the dates I make my
requests, sir.
Q. Okay. And are you aware that on the 18th of
February, you made one, two, three, four, five, six,
seven, eight requests?
A. Again, I didn't memorize it. I can see that I
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1
might have.
Probably did, but I don't know for sure.
2
Q.
February 19th you made three requests, and
3
Citizens
Awareness Foundation made one, two, three,
4
four, five
requests the same day? Are you aware of
5
that?
6
A.
No.
7
Q.
And the only requests made on those days are
8
you and
Citizens Awareness Foundation? Are you aware of
9
that?
10
A.
No. I didn't realize that.
11
Q.
Okay. And Mr. Roeder, on March 3rd, made 1,
12
2, 3, 4,
5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16
13
requests.
Was that -- was that done at -- I'm sorry. I
14
may have
miscounted. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11,
15
12, 13,
14, 15, 16 requests on March 3rd.
16
Did you direct Mr. Roeder to file public
17
records
requests on the Town of Gulf Stream in or about
18
March of
2014?
19
MR. HANNA: I'm going to object and instruct
20
the
witness not to answer.
21
THE WITNESS: Don't answer?
22
MR. HANNA: No.
23
BY MR. SWEETAPPLE:
24
Q.
Were you aware that Mr. Roeder was filing
25 public records requests?
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BY MR. SWEETAPPLE:
Q. You wouldn't use someone's name to -- to -- to
do something if you didn't have their permission, right?
A. If it was a living person, I would ask them.
Q. And then on March 4th, Mr. Roeder filed three
more requests, and the following day Martin O'Boyle
filed five requests. Are you aware of that?
A. No.
Q. Then on March 12th, Mr. Roeder filed another
one, two, three, four requests. Are you aware of that?
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A.
Yes.
Q.
Did you have copies of the requests?
A.
Not on me.
Q.
Did you use his name and file the requests?
A.
No, never.
Q.
Okay. Did you have his permission to use his
name?
A.
I never filed any requests using Mr. Roeder's
name.
Q.
You wouldn't do that, right?
A.
Do what?
Q.
Use his name to file a request.
A.
Absolutely not.
Q.
Because that would be fraudulent, right?
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. You wouldn't use someone's name to -- to -- to
do something if you didn't have their permission, right?
A. If it was a living person, I would ask them.
Q. And then on March 4th, Mr. Roeder filed three
more requests, and the following day Martin O'Boyle
filed five requests. Are you aware of that?
A. No.
Q. Then on March 12th, Mr. Roeder filed another
one, two, three, four requests. Are you aware of that?
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A. No.
Q. And on March 14th, Mr. Roeder filed another
four -- one, two, three, four, five -- five requests.
Are you aware of that?
A. No.
Q. Same day Jonathan O'Boyle filed two requests,
and Citizens Awareness Foundation filed one request.
Are you aware of that?
A. No.
Q. So on the 14th of March, the people who hit
the Town of Gulf Stream with public records requests
were Mr. Roeder, Jonathan O'Boyle, and Citizens
Awareness Foundation. Are you aware of that?
MR. HANNA: Object to form.
THE WITNESS: I wouldn't use the word "hit."
I think they were looking for records, but I wasn't
aware of that.
BY MR. SWEETAPPLE:
Q. And had -- were -- did you ever, in any of
your e -mails with Martin O'Boyle, discuss Citizens
Awareness Foundation?
A. Not that I can recall.
Q. Did you ever discuss with Mr. Chandler in 2013
the filing of public records requests?
A. Yes.
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Q. And did he ever come to your office and meet
with you?
A. Yes.
Q. And was your wife there?
A. I think she might have been there on one
occasion.
Q. How many times did you meet with Mr. Chandler
in 2013?
A. I don't remember that.
Q. More than once?
A. Perhaps.
Q.
Did you have e -mail exchanges with
Mr. Chandler?
A.
I may have e- mailed him once or -- I can't
attest to
how many times, though.
Q.
Okay. And did you ever text him?
A.
No.
Q.
Did you ever pay him money?
A.
I don't think directly.
Q.
What do you mean "directly "?
A.
I don't think I ever paid him directly.
Q.
Did you pay him indirectly?
A.
I believe there was a period when he was
working as
a paralegal, and he might have gotten
compensation
that way, but I can't recall that.
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A. I can't -- I don't know the date.
Q. Was it early 2013?
A. I can't recall that.
Q. Did Mr. -- and how long was Mr. Chandler a
paralegal for you?
A. I don't think it was for very long.
Q. A month, two months, a week?
A. I don't know. Don't know exactly.
Q. Did you -- did you indirectly provide him any
benefits?
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Q.
As a paralegal for who?
A.
I'm sorry?
Q.
Who was he a paralegal for?
A.
I only have knowledge of me.
Q.
So he was a paralegal for you.
A.
Well, not to me but in my behalf.
Q.
He was a paralegal on your behalf?
A.
I'm speculating. I don't have personal
knowledge
of that, but I believe that to be true.
Q.
When was he a paralegal for you?
A.
In the time period we're talking about.
Q.
What time period are we talking about?
A.
I think you said around 2013.
Q.
So when did Mr. Chandler first start doing
paralegal
work for you?
A. I can't -- I don't know the date.
Q. Was it early 2013?
A. I can't recall that.
Q. Did Mr. -- and how long was Mr. Chandler a
paralegal for you?
A. I don't think it was for very long.
Q. A month, two months, a week?
A. I don't know. Don't know exactly.
Q. Did you -- did you indirectly provide him any
benefits?
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1
A.
Benefits? You mean like buy him a soda?
2
Q.
Dinner, lunch, pay for his housing, buy him a
3
car, buy
him a soda, whatever.
4
A.
No.
5
Q.
So you said you didn't directly pay him. Did
6
you indirectly pay him?
7
A.
I think -- you know, I'm not sure. I don't
8
remember
exactly.
9
Q.
When he was a paralegal for you, was he
10
employed
by the O'Boyle Law Firm?
11
A.
Oh, no.
12
Q.
This was before the O'Boyle Law Firm existed?
13
A.
He would -- he would have been assisting
14
Mr. Roeder, I believe.
15
Q.
So he was Mr. Roeder's paralegal?
16
A.
I think that was his role.
17
Q.
Okay. And so --
18
A.
I didn't have direct knowledge of that.
19
Q.
And was Mr. Roeder your attorney at the time?
20
A.
Yes.
21
Q.
And did Mr. Roeder pay Mr. Chandler?
22
MR. ROEDER: Object.
23
BY MR. SWEETAPPLE:
24
Q.
Do you know if Mr. Roeder was paying
25 1 Mr. Chandler?
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MR. HANNA: I object to form. Or I'm going to
object and instruct the witness not to answer.
THE WITNESS: I'm sorry, I didn't hear you.
MR. HANNA: I'm going to instruct you not to
answer.
BY MR. SWEETAPPLE:
Q. Other than from anything Mr. Roeder told you,
do you know if Mr. Chandler was paid by Mr. Roeder's law
office?
A. I don't have access to Mr. Roeder's books.
Q. Okay. And so was Mr. Roeder representing you
regarding public records requests in 2013?
A. Mr. Roeder represents me on a lot of issues.
Q. So he was your attorney in 2013?
A. And it would include public records requests.
Q. Okay. And so in 2013, was Mr. Roeder involved
in representing you with regard to your roof claim?
A. 2013, yes.
Q. And you met with Mr. Chandler with Mr. Roeder?
A. On occasion.
Q. Okay. At Mr. Roeder's office?
A. No. At my office.
Q. At your office. And did Mr. Chandler help you
with any of these public records requests that were
filed with the Town of Gulf Stream?
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MR. HANNA: I'm going to object and instruct
the witness not to answer.
BY MR. SWEETAPPLE:
Q. Did Mr. Chandler ever tell you -- use the
words "head shot" or "kill shot" with regard to filing
public records requests that you heard?
MR. HANNA: I'm going to object and instruct
the witness not to answer if any statements were
made in the -- in conjunction with Mr. Roeder's
representation of you and Mr. --
BY MR. SWEETAPPLE:
Q. When you say Mr. Chandler was a paralegal for
Mr. Roeder --
A. Well, I can answer your question if you would
like.
Q. Sure.
A. The only time I ever saw the terms "head shot"
or "kill shot" that I can recall was in the RICO
complaint made against me, but I don't recall ever
hearing those terms or seeing those terms before.
Q. And you've never seen Mr. -- heard
Mr. Chandler use those terms or seen them in e- mails?
A. I can't recall that, no.
Q. With Mr. Whitmer or anyone else with Jonathan
O'Boyle?
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A. No. I don't recall ever seeing a head shot or
kill shot or any firearm -type.
Q. Did you hear your wife at any of these
meetings tell you she was disgusted by Mr. Chandler and
what he was doing?
A. I recall hearing some of that. Yeah.
Q. She told you that -- didn't she tell you that
she thought what you were doing was disgusting with
Mr. Chandler?
A. No.
Q. Didn't she tell you that the way Mr. Chandler
was operating himself was offensive?
A. I'm sorry.
Q. What did she say exactly?
A. What I recall her saying was she did not
like -- and I'm paraphrasing -- she did not like what
Mr. Chandler did with his fog -watch website and going
around asking for public records.
Q. And you knew that you were bringing
Mr. Chandler in to help you barrage the Town of Gulf
Stream with public records requests, right?
MR. HANNA: Object to form.
MR. ROEDER: Objection.
BY MR. SWEETAPPLE:
Q. That is why you and Mr. Roeder had
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Mr. Chandler brought down here.
MR. ROEDER: Objection.
MR. HANNA: Objection to form.
THE WITNESS: No. That's not true.
BY MR. SWEETAPPLE:
Q. And Mr. Chandler did give you instruction on
filing public recozds requests, right?
A. Yes. He was very helpful with regard to
making sure we did it the way it was supposed to be
done.
Q. Okay.
A. Citing the specific statutes and making sure
we were clear and not ambiguous as possible. He
basically explained -- and I think it was to make it
easier on the agency -- explained how to be as clear as
possible.
Q. In terms of your request?
A. In terms of getting a correct response back.
Q. And did he ever suggest to you that you should
file over 50 requests in one day to make sure you got a
response back?
MR. HANNA: I'm going to object.
BY MR. SWEETAPPLE:
Q. Did it ever occur to you that filing more than
50 requests in a day would not facilitate getting a
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response back?
A. No.
Q. Did it ever occur to you whether or not you
were overwhelming the clerk's office with requests?
A. No.
Q. So you never thought anything you were doing
was-burdensome-or overwhelming on them?
A. I was exercising my constitutional right.
Q. And it never occurred to you that what you
were doing was burdensome?
A. Burdensome. I don't understand.
Q. On the clerk; that you were dominating the
clerk's time and there was no way the clerk could comply
with your requests.
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. Did that ever occur to you?
THE WITNESS: I'm sorry. Are you instructing
me?
MR. HANNA: No.
THE WITNESS: Okay. I did not believe I was
burdening her. I thought I was asking her to do
her job.
BY MR. SWEETAPPLE:
Q. You never thought you were doing anything
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burdensome or unreasonable?
MR. HANNA: Object to form.
THE WITNESS: I'm sorry.
BY MR. SWEETAPPLE:
Q. You never thought you were doing anything
burdensome or unreasonable with the clerk of the Town of
Gulf Stream at any time?
A. With the entire staff, no.
Q. And did you introduce Joel Chandler to Martin
O'Boyle?
A. No.
Q. Did you tell Mr. O'Boyle about Joel Chandler?
A. Did I tell Joel -- tell him about?
Q. Joel. Did you tell him you were working with
him? Did you tell Martin you were working with Joel
Chandler?
A. It probably came up.
Q. And did you -- what did you tell Martin
O'Boyle about Joel Chandler?
A. I can't remember the exact conversation.
Q. Did you tell him that you were using his
services to make hundreds and hundreds of public records
requests against the Town of Gulf Stream?
A. To clarify that, in my answer, I talked to
Martin O'Boyle about Joel Chandler and his help on
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records requests; the hundreds and hundreds part, no, I
don't agree with that. I don't think I ever said
anything like that.
Q. Did you ever tell Mr. O'Boyle how many
requests you had made?
A. No.
Q. Did you ever tell Mr. O'Boyle you were using
fictitious names?
A. No.
Q. Did you ever discuss with him how many public
records requests you had made and any e -mails you had
with him?
A. I don't recall that, no.
Q. Do you recall in e -mails telling him you were
using fictitious names?
A. I don't recall that.
Q. And did you -- were you ever present at any
meetings where O'Boyle met with -- Martin O'Boyle met
with Mr. Chandler?
A. Yes.
Q. How many times were you present for meetings
between Mr. Chandler and Martin O'Boyle?
A. The only one I can remember was a party at
Mr. O'Boyle's house, where Mr. Chandler was there and a
number of other people. Maybe 60 people.
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Q. Was that in January of 2014?
A. I don't remember the date.
Q. Do you recall generally when it was?
A. It was around the time of the election. It
might have been an election -style party. So I'm
thinking it might have been March of 114.
Q. And what did Mr. O'Boyle and Mr. Chandler and
you discuss?
A. I don't remember discussing anything at the
party.
Q. You met Mr. Chandler there?
A. I saw Mr. Chandler at the party. I might have
said hello.
Q. Did you have any idea how he had come to know
Mr. O'Boyle?
A. No. I don't know how they met.
Q. You didn't introduce them?
A. No.
Q. You didn't tell Martin O'Boyle about
Mr. Chandler?
A. No.
Q. And you didn't discuss Mr. Chandler in any of
your e -mails with Mr. Martin O'Boyle prior to January of
2014?
A. I'd have to look at my e- mails. I don't
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remember.
Q. And was Jonathan O'Boyle at that party?
A. I think so.
Q. And did you discuss Citizens Awareness
Foundation, Inc., at that party?
A. I've never discussed Citizens Foundation,
Inc., with anybody..
Q. Didn't Mr. Chandler and Mr. O'Boyle tell you
that your so- called paralegal for public records
requests was going to now become the so- called head of a
public not - for - profit -- alleged to be public
not - for - profit called Citizens Awareness Foundation?
A. I never heard the word so- called. I never
heard CAFI or Citizens Awareness until I read about
it -- or I take that back. I heard about it in a
meeting I'm not allowed to discuss.
Q. The first time you heard about Citizens
Awareness Foundation, Inc., was in a confidential
meeting, a mediation meeting?
A. I can't recall ever hearing it before that.
Q. None of your e -mails discuss Citizens
Awareness Foundation. I'm talking about your e -mails
with Jonathan O'Boyle. I know you're going to claim
privilege until we allege the fraud exception. But none
of your e -mails with Jonathan O'Boyle, Martin O'Boyle,
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or Joel Chandler refer to Citizens Awareness Foundation,
Inc., before the date of mediation that Mr. Hanna and
Mr. Roeder appeared at.
MR. HANNA: I'm going to object and instruct
the witness not to answer in connection with any
kind of communication involving your attorneys.
BY MR. SWEETAPPLE:
Q. When did Mr. Chandler stop serving as a
paralegal to Mr. Roeder?
A. I don't know.
Q. He was not a paralegal to Mr. Roeder in
January of 2014, right?
A. January 2014? I don't believe so.
Q. And he wasn't at the time of the party in
March of 2014, at or about February or March, was he?
A. Let me clarify my previous answer. When I say
"paralegal," he was helping Mr. Roeder with issues
regarding requesting public records. I consider that
paralegal work. But I don't know if they did. That's
my interpretation.
Q. And did you continue talking to Mr. Chandler
throughout 2014?
A. I'm sorry. Did I what?
Q. Did you continue to talk to him even after --
was there a time in 2014 when you believed he stopped
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working with Mr. Roeder?
A. I didn't have personal contact with
Mr. Chandler.
Q. Did you ever meet with Mr. Chandler without
Mr. Roeder present?
A. Yes.
Q. And did you -- how many times did you meet
with Mr. Chandler without Mr. Roeder present?
A. That would be Mr. O'Boyle's party where
Mr. Roeder didn't go to that.
Q. Any other times?
A. I can't recall.
Q. Did you ever talk to Mr. Chandler on the
telephone?
A. I don't recall, but if it did happen, it was
very infrequent. I don't recall that.
Q. And did you ever exchange e -mails with
Mr. Chandler?
A. Initially, yes.
Q. Did you ever -- did you become aware that the
so- called O'Boyle Law Firm was being formed in early
2014?
MR. HANNA: Object to form.
THE WITNESS: I never heard the term
"so- called O'Boyle Law Firm." Are you talking
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about the O'Boyle Law Firm?
BY MR. SWEETAPPLE:
Q. What is claimed to be the O'Boyle Law Firm.
A. I never heard of "claimed to be." I've heard
of the O'Boyle Law Firm.
Q. When is the first time you heard that there
was a law firm by the name of the O'Boyle Law Firm?
A. I don't have the date memorized.
Q. Was it early 2014?
A. I don't know for sure.
Q. And did you ever learn from Mr. Chandler or
anyone else that lawyers in the O'Boyle Law Firm were
paying people to bring public records requests
throughout the state of Florida?
A. No. I have no knowledge of that.
Q. Do you know an individual by Mr. Gray? Did
you ever meet Mr. Gray?
A. The only time I've heard that name was on a
newspaper article, maybe within the last week or two. I
believe. I can't recall hearing anything earlier than
that.
Q. Did Mr. Chandler ever disclose to you that he
had a protege by the name of Mr. Gray who was -- did he
ever tell you he had a protege by the name of Mr. Gray?
MR. HANNA: Object to the form.
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THE WITNESS: I can't recall hearing the name,
seeing the name, or reading the name.
BY MR. SWEETAPPLE:
Q. Did Mr. Chandler ever tell you that he was
going around the state personally making public records
requests with wires on him to film state agencies?
A. Wires on him?
Q. Yes. With video and audio wires to record.
A. I recall Mr. Chandler said he used a cell
phone sometimes to memorialize his records requests.
Q. And did he tell you he was going around to
different -- did you know Mr. Chandler was going around
to different state governments and public -- private
contractors to make public records requests?
A. Yes. I did know that.
Q. And did you know that at the time that you
were using his services as a paralegal?
A. That was why I used his services, yes, because
of his experience.
Q. Were you aware that -- strike that.
Were you aware that Jonathan O'Boyle was
making public records requests from the Town of Gulf
Stream at the same time and on the same days as you
were? Ever?
A. No. Not the same time and same day.
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Q. Were you aware that Citizens Awareness
Foundation was often making public records requests on
the same time and same day as you were?
A. No. I don't know anything about Citizens
Awareness.
Q.
Are
you
aware that records show that you and
the O'Boyles made
records within moments of each other
on the same days.
A.
No.
I
have no idea about that.
Q.
And
are
you aware that Mr. Ring made record
requests
from
the
Town of Gulf Stream?
A.
No.
I
don't have any knowledge of that.
Q.
And
have
you ever paid the O'Boyle Law Firm
any money?
MR. HANNA: I'm going to object and instruct
the witness not to answer.
BY MR. SWEETAPPLE:
Q. Is the O'Boyle Law Firm providing
representation to you on a gratis or contingency basis
on any matter?
MR. HANNA: I'm going to object and instruct
the witness not to answer.
Did you say gratis?
MR. SWEETAPPLE: No payment. Volunteer basis.
MR. HANNA: I just wanted to make sure.
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BY MR. SWEETAPPLE:
Q. And Mr. Jonathan O'Boyle has appeared as a pro
hac vice attorney on your behalf. Okay.
A. Yes.
Q. And he currently is, correct?
A. Correct.
Q. With Mr. Hanna?
A. With Mr. Hanna.
Q. Co- counsel with Mr. Hanna?
A. I don't know.
Q. In a case where Mr. Hanna is his sponsoring
lawyer.
A. I don't have all the cases memorized. I
couldn't tell you.
Q. Has Mr. Jonathan O'Boyle ever said anything to
you as to whether or not he and his firm have
contingency agreements with public records requests,
plaintiffs, and are dividing their attorneys' fees with
plaintiffs?
A. I have no knowledge of how they conduct their
business.
Q. Well, you are a client of the firm, right?
A. I have knowledge of how they're conducting
their business with me. I don't have a knowledge of
what they're doing with other clients.
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Q. Have you ever met at the offices of the
O'Boyle Law Firm?
A. Yes.
Q. How many times have you been to the O'Boyle
Law Firm?
A. Maybe two or three.
Q. And when is the first time you went to the
O'Boyle Law Firm?
A. Within the last year, I would say.
Q. Okay. 2014?
A. I think so.
Q. When it first opened up, it was in the offices
of the Commerce Group, right?
A. I don't know who owns the building, what other
companies are in the building. I just showed up into a
conference room like this one.
Q. You were one of the first clients of the
so- called O'Boyle Law Firm, right?
MR. HANNA: Object to form.
THE WITNESS: I have no idea how many clients
or when they started getting clients.
BY MR. SWEETAPPLE:
Q. You weren't aware at the party that the law
firm was going to open up the -- in the Commerce Group
offices, and they were going to open CAFI up at the same
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Page 96
place; and they were going to hire Mr. Chandler to be
their runner to go create public records requests on
cases all over the state? Just like -- just like he had
showed you to do?
MR. HANNA: Object to the form.
THE WITNESS: At the party I did not know that
Mr. Chandler worked for anybody except himself. I
did not have any inkling about what CAFI is.
BY MR. SWEETAPPLE:
Q. And how many lawsuits did the O'Boyle Law Firm
file for you against the Town of Gulf Stream?
A. As opposed to Mr. Hanna, I can't tell you the
exact number.
Q. The first public records lawsuit you filed,
was it with the O'Boyle Law Firm?
A. You have me at a loss. I don't know.
Q. What about the second one?
A. I did not commit to memory. I have all these
lawsuits and I would have to refer to them to tell you
all the details of the suit.
Q. What about the third lawsuit?
A. I just answered that.
Q. Do you know how many lawsuits you filed in a
row with the O'Boyle Law Firm? How many public records
requests you filed in a row with the O'Boyle Law Firm?
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MR. HANNA: Object to form.
THE WITNESS: I don't think of it in those
terms, so I didn't commit that to memory.
BY MR. SWEETAPPLE:
Q. Do you know if the O'Boyle Law Firm filed
suits for other plaintiffs for public records against
Gulf Stream on the same day or within days of your
lawsuits?
A. I can't testify to the efficiency of their
operation.
Q. And at the time -- in 1998, you had no idea
that you were going to be involved in filing hundreds
and hundreds of public records requests against the Town
of Gulf Stream, did you?
A. In 1998, I had no idea what I would be doing
now.
Q. And in 1998, you had no idea who Mr. Chandler
was, right?
A. Right.
Q. And you had no idea who Mr. O'Boyle was,
right?
A. Yes.
Q. And you had no idea who Jonathan O'Boyle was?
A. Yes.
Q. And you had never sued any government for
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Page 98
public records.
A. No, I have not.
Q. So in 1998, when you say you were meeting with
me, that was about a code violation in the Town of Ocean
Ridge, right?
A. No. Well, correct that. That's part of it.
By the way, while we're on the subject of
correcting, I made a statement earlier about a photo
production. And I was confused. I think now, thinking
about it, that actually was part of the first set of
productions. There was no photo on the second set.
Pardon me for that.
Q. Thank you. And you don't know how many times
Jonathan O'Boyle appeared pro hac vice for you.
A. No. I'd have to refer back to the actual
claims.
Q. And do you have any written agreement with
Jonathan O'Boyle that refreshes your recollection?
MR. HANNA: Object to the form, and instruct
the witness not to answer.
MR. SWEETAPPLE: I just want to know if you
have any writings that would refresh your
recollection with Jonathan O'Boyle.
MR. ROEDER: Object to form.
MR. HANNA: I object and instruct the witness
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not to answer.
Q. You never had to sue the Town of Ocean Ridge
for public records, right?
A. No. They're very forthcoming.
Q. So that never became an issue with them.
A. That wasn't an issue at the time.
Q. When is the first time that you ever had any
issue regarding having to sue a town for public records,
in your opinion or your view?
A. That was the Town of Gulf Stream.
Q. 2013? 2012?
A. Whenever the first suit was. I can't give you
the date.
Q. Okay. What is the total number of public
records requests that you've filed against the Town of
Gulf Stream, either in your name or using other people's
names or using other agents?
MR. HANNA: Object to form.
THE WITNESS: I never filed a request against
the town. I just asked for a record.
BY MR. SWEETAPPLE:
Q. To the town. How many times have you filed a
request to the town in your name or allegedly on behalf
of someone with their authority?
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Page 100
A. I don't have -- I didn't commit to memory the
number of requests.
Q. Do you keep a log of the requests you make?
A. When you say "log," could you be more
specific?
Q. Did you ever keep a running record of all the
requests you've made?
A. I have a copy of all the requests, all the
responses, and all the records I've gotten.
Q. In a file?
A. Well, digital.
Q. Digital. That's kept where? At Pineapple
Grove?
A. My G -mail accounts. And in the possession of
my attorneys.
Q. And have you ever made requests for documents
with the Town of Gulf Stream and not picked them up?
A. I've done my best to get them all. I've asked
a number of times if there are any outstanding. I've
been told no. I believe I have picked -- if not all of
them up, then I'm not aware of the ones I haven't picked
up. I tried to find out.
Q. You're not aware that there are dozens of
requests that you made that you never went to pick up,
never made any effort to pick up?
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A. I know in your RICO claim you're asserting
records were to be picked up when actually, I believe,
estimates were made for the record. But I'm not aware
of records I haven't picked up. If there are records I
haven't picked up, I certainly will pick them up.
Q. Well, do you keep records of what you ask for
so that you make sure you go pick them up, or do you
just file the records requests to harass people?
MR. ROEDER: Objection.
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. Do you keep records of all the records
requests you made?
A. I have copies of the requests I've made.
That's one of the reasons I have multiple G -mail
accounts to keep track of it all.
Q. How does multiple accounts help you keep track
of it all as opposed to one account?
A. You have to understand -- this will come out
later. But you have to understand, when I ask for a
record and I'm told it doesn't exist, and I ask again
and maybe it exists, and I ask again and I have to ask a
different way, there could be multiple communications
going back and forth, sometimes with forwarding,
sometimes with attachments. It gets confusing. But the
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Page 102
town, sometimes it's like pulling teeth to finally get
the record.
Q. So why does having all these different names,
fake names and other people's names, help you to keep
track of whether or not you've picked up records?
MR. HANNA: Object to form and the
characterization that they're fake names. E -mail
addresses aren't required to be identified to the
person so in their RICO case, it's noted how they
just have a cursor over the e -mail address, and it
appeared Christopher O'Hare, their big
investigation, to try to find out who -- discover
who was sending the e -mail.
BY MR. SWEETAPPLE:
Q. Okay. That's a speaking objection, but go
ahead, Mr. O'Hare.
A. Can you ask the question again?
Q. How does multiple G -mail accounts help you
keep track of whether or not you picked up all of your
records you have requested?
A. Well, it could very well be my fault and not
G- mail's fault, but sometimes when you request a
record -- or I'm sorry -- sometimes when you send an
e -mail and there's a response and then you forward it
to someone, it changes position in the account.
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So sometimes you -- I spend a lot of time
searching; and my rationale was if I had multiple
accounts, at least those records would be isolated to
just a smaller electronic file to go digging through.
That was my rationale.
Q. How many times have you failed to go pick up
records that you've requested?
A. I hope none.
Q. How many have you; do you know?
A. How many have I not picked up?
Q. Yeah. How many times have you not picked up
records after you've asked for them?
A. If I had knowledge of any I hadn't picked up,
I would be over there picking them up. I don't think
there's any. But if the town is aware of some, I'll be
over there tomorrow.
Q. How do you decide what it is you're going to
request?
A. You're asking me a particular time period
or --
Q. Yes.
A. -- subject?
Q. When you met with Mr. Chandler, did he discuss
with you topics you could use to make requests?
A. No. I never had that kind of discussion.
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Q. Did he ever discuss with you any ways to make
requests so difficult or onerous that they can't be
responded to?
A. No. And I've made requests over and over
trying to be as clear and surgically precise as
possible.
Q. And you have wanted -- every document you
requested has been for some purpose.
A. Absolutely.
Q. Not just to harass the town or punish the town
or abuse the town.
A. I have no intention of harassing, punishing or
abusing anybody.
Q. Okay. Are you familiar with this Gulf Stream
Patriot?
A. I got that in the mail.
Q. Did you -- have you ever seen it before you
got it in the mail?
A. I saw parts of this by G -mail.
Q. Who did you see it from in G -mail?
A. I saw it from Mr. O'Boyle.
Q. Did Mr. O'Boyle send you a G -mail regarding
this document?
A. Yes.
Q. Did he -- do you still have that G -mail?
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Page 105
1 A. Probably.
2 Q. And did he write -- did he -- what did the
3 G -mail have in it?
4 A. He sent me a digital version of this, an
5 earlier version, and asked me if I saw anything that was
6 factually incorrect about it.
7 Q. Was it complete just like this with everything
8 that is in it? I'm going to mark this as Exhibit --
9 what number am I on?
10 COURT REPORTER: E.
11 MR. HANNA: Can I take a look at it? I've
12 never seen it.
13 MR. SWEETAPPLE: You didn't get one in your
14 mailbox?
15 (Defendant's Exhibit No. E was marked for
16 identification.)
17 THE WITNESS: I can't testify to whether it
18 was exactly like this or not. I don't know.
19 BY MR. SWEETAPPLE:
20 Q. You still have the G -mail, though, right, the
21 e -mail?
22 A. I believe I do, yes.
23 Q. And he asked you to proof it.
24 A. He asked me to see if there's any factual
25 inaccuracies with regard to me.
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Q. Did you make any edits?
A. Yes.
Q. Did you write any pieces to put into that?
A. I had written an article previous to this
about the town's fictitious open space policy; and he
had taken that, and I'm not sure how he got it. And he
had chopped it up and twisted the whole theme of it.
And I complained to him about that, because he was
making a different point than I was trying to make.
In addition to that, I asked him to delete an
article he had written I think about Officer Ginsberg.
I don't quite remember. But I know there's something in
here I asked him not to print, and he did take it out.
But he didn't use my edits. So I can't be held
responsible for this.
Q. So you told him to edit it, and he didn't.
A. Well, I suggested to him there was some
grammatical issues, and I asked him to take out the
article about some topic.
Q. Did he take that article out?
A. He did, but I don't remember what it was.
Q. Did you write any of the text that is in this
exhibit?
A. That is in this exhibit? No.
I'm sorry. I wrote the open space thing that
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was then heavily edited by Mr. O'Boyle.
Q. And did you write "Every Home Needs a Roof "?
A. No.
Q. So that was written by Mr. O'Boyle?
A. Give me a moment to read it. Make sure I
didn't write any part of that. What page is that on?
Q. The last page. The back.
A. I believe that -- well, I know that I had
written something similar to this that's on my website,
TownofGulfStream.com. And I think, from what I see
here, that Marty must have taken that off my website,
edited it, and regurgitated it on this.
Q. Did you give him permission to do that?
A. No.
Q. When he showed you the draft, did you object
to him putting that in?
A. No. I figured it was public knowledge. The
whole website is public information.
Q. But it was your writing. You copied -- that's
your copyright.
A. And I reserve the right to enforce my
copyright when I so chose.
Q. And you chose not to with regard to this. You
gave him permission.
A. I didn't see any reason -- he didn't ask for
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permission, and I didn't give him permission.
Q. Wasn't the request that you edit it the
request for your permission?
A. I don't connect the two.
Q. But you have e -mails back and forth regarding
this document, right?
A. Back and forth, maybe one or two e- mails.
Q. Okay. Did you pay for any of this
publication?
A. Pay for it? No. I had nothing to do with it.
Q. Did Mr. O'Boyle tell you he paid for it?
A. I don't recall him saying he paid for it. I
don't know who paid for it.
Q. Did he tell you who, if anybody else, was
involved in writing this?
A. I'm sorry. Say again.
Q. Did he tell you if anyone else had been
involved in writing this?
A. I don't remember that. I don't recall that.
Q. Did he tell you he wrote it?
A. That I -- yeah. I believe he wrote this. I
believe I told me he wrote it, too.
Q. He didn't tell he you hired somebody to write
it?
A. From reading it, I don't -- I think he should
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get his money back.
Q. What's that?
A. I mean, I like Marty, but this isn't very well
written.
Q. Well, he wrote -- he refers to you extensively
through this piece, and you didn't object, right?
A. Yeah. I know. It's flattering, and I'm glad
he's, you know, broadcasting the message I was trying to
use my website for. But I didn't write this. He wrote
it, I'm assuming from the style, but I have no knowledge
of anybody else being involved.
Q. It says "As these litigations begin to be
tried, the town will have to pay its legal costs and
costs incurred by Mr. O'Boyle and Mr. O'Hare." You see
that?
A. I'm sorry. Could you tell me where?
Q. Right here. The middle. "Since, after all,
even Mayor Morgan (a lawyer) stated on the record that
Mr. O'Boyle and Mr. O'Hare had meritorious claims."
So is it your goal with this litigation you
filed to get legal fees?
A. Can you show me the paragraph? Point to it.
Q. Sure. Right here. You see where it says "as
these" right here.
A. May I read from your highlighted?
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Page I10
Q. I'll highlight for you what I'm reading. I'll
do a little bracket.
A. Thank you.
Q. It says, "As these litigations begin to be
tried, the town will have to pay its legal costs and
costs incurred by Mr. O'Boyle and Mr. O'Hare since,
after all, even Mayor Morgan (a lawyer) stated on the
record that Mr. O'Boyle and Mr. O'Hare had meritorious
claims."
So did you approve Mr. O'Boyle saying that the
town is going to have to pay your legal fees?
A. No. And I think I've heard this before at
public comment parts of public meetings. This isn't the
first time I've heard this. But, no, I did not say put
this in. I did not say take it out. I did not say I'm
all for this. I had nothing to do with this.
Q. Did you file lawsuits against the town to get
attorney's fees and costs?
A. No. I filed lawsuits to -- I did not file
them just for getting attorney's fees and costs.
Q. But that was one of the factors in your
filing, right?
A. God, I hope I get my money back.
Q. Okay. And you realize that in order to obtain
attorney's fees in a public records request, there has
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Page I I 1
to be an unlawful refusal to provide the records.
A. That's why I would cite --
Q. When I say there has to be an unlawful refusal
to allow you to inspect, physically inspect and copy the
records. That is what the statute says.
A. Yes. That is my understanding.
Q. And you realize that while a town has to --
the town has to reasonably -- on reasonable notice and
make reasonable efforts to allow you to personally
inspect and copy a record --
A. Right.
Q. -- in the presence of the clerk or the record
custodian, correct?
A. I believe I've read that in the statute.
Q. How many times have you actually physically
gone to the clerk's office and made a request to inspect
and copy a document?
A. I could think of maybe a dozen times.
Q. Has the clerk ever said to you, I refuse to
give you that record?
A. No.
Q. And you realize the statute says a town or a
government may --
A. I'm sorry. May I clarify that?
Q. Yeah.
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A. She's never personally, physically to my face
said, no, you can't have that record.
Q. Has anyone -- has the clerk in any of those 12
times ever told you that something is exempt, and you
can't have it?
A. In those 12 times?
Q. Yes.
A. I don't recall any exemptions.
Q. Have you ever filed a lawsuit with regard to
anytime where you went to the clerk's office and asked
to inspect and copy a record where the clerk refused --
unlawfully refused to allow you to physically inspect
and copy a record?
A. I'm not recalling that.
Q. Are you aware that Florida Statute Section 119
talks about the fact that a government or a state
contractor may, if they chose, provide you with
documents electronically?
A. Yes.
Q. Are you aware that this statute regarding
attorney's fees does not echo the language in that
subsection; rather, it echos the subsection 1(a), which
says that you only get fees where there is an unlawful
refusal to allow you to inspect and copy the records?
A. You're asking me for a legal opinion?
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don't.
Q. Okay. And have you ever -- has it ever
occurred to you that it would not be reasonable to
expect the Town of Gulf Stream to be able to respond to
any public records request when they are inundated with
almost 2,000 requests by you and other clients of the
so- called O'Boyle Law Firm?
MR. HANNA: Object to form.
THE WITNESS: Sorry. What is your question?
BY MR. SWEETAPPLE:
Q. Has it occurred to you ever that it would not
be reasonable to expect the clerk to be able to timely
or competently respond to public records requests when
the clerk of Gulf Stream is inundated with almost
2,000 requests by you and other clients of the O'Boyle
Law Firm?
MR. HANNA: Object to form.
THE WITNESS: Okay. I thought you said
so- called. It has never occurred to me I was
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Q.
I'm asking you
in your desire for
legal fees,
have you
ever looked at
whether or not there
is even an
entitlement
for fees where
you don't make a
request to
inspect
and copy records
to a clerk that has
unlawfully
refused?
Have you ever
looked at that issue?
A.
I didn't know
that issue existed.
I still
don't.
Q. Okay. And have you ever -- has it ever
occurred to you that it would not be reasonable to
expect the Town of Gulf Stream to be able to respond to
any public records request when they are inundated with
almost 2,000 requests by you and other clients of the
so- called O'Boyle Law Firm?
MR. HANNA: Object to form.
THE WITNESS: Sorry. What is your question?
BY MR. SWEETAPPLE:
Q. Has it occurred to you ever that it would not
be reasonable to expect the clerk to be able to timely
or competently respond to public records requests when
the clerk of Gulf Stream is inundated with almost
2,000 requests by you and other clients of the O'Boyle
Law Firm?
MR. HANNA: Object to form.
THE WITNESS: Okay. I thought you said
so- called. It has never occurred to me I was
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inundating the town or overburdening them or that
they were not capable of answering my requests.
BY MR. SWEETAPPLE:
Q. And it never occurred to you that your actions
were in concert with other clients of the O'Boyle Law
Firm?
A. In concert? I'm sorry?
Q. That the O'Boyle Law Firm clients were doing
the same thing you were doing to Gulf Stream at the same
time and on the same day you were doing it.
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. That never occurred to you?
A. Well, I had knowledge of that.
Q. You had knowledge of that.
A. I have knowledge that Patsy Randolph, the Palm
Beach Post; a lot of people had been asking for records
in the same time period.
Q. But you knew -- you knew from public meetings
and otherwise that other clients of Gulf Stream -- other
clients of the O'Boyle Law Firm were making public
records requests at the same time you were making them
on the Town of Gulf Stream.
A. Bob, that information in itself is a public
record. It's on the town's website.
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every day?
A. No.
Q. How often did you look at it?
A. How often I looked at the town's website?
Q. Uh -huh.
A. I don't know.
Q. Your server will show that. But tell us your
best recollection.
A. I don't know.
Q. Okay. Did you look at the town's website
regularly to see who else was filing public records
requests?
A. I visited the town's website to search the
public records, so I don't have to ask them. If it's
there, there is no need to ask them. I also looked to
see what the agenda items are going to be, what the
minutes are from past agendas, who is going to be
speaking, what issues are going to be voted on.
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Q.
So you knew
that?
A.
I look at
the town's website,
and I see other
people
are making
requests.
Q.
And you
saw the volume of requests
that were
being made,
right?
A.
Yes. I
could see that on the
town's website.
Q.
You saw
it every day, right?
You looked at it
every day?
A. No.
Q. How often did you look at it?
A. How often I looked at the town's website?
Q. Uh -huh.
A. I don't know.
Q. Your server will show that. But tell us your
best recollection.
A. I don't know.
Q. Okay. Did you look at the town's website
regularly to see who else was filing public records
requests?
A. I visited the town's website to search the
public records, so I don't have to ask them. If it's
there, there is no need to ask them. I also looked to
see what the agenda items are going to be, what the
minutes are from past agendas, who is going to be
speaking, what issues are going to be voted on.
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I'll go to public records portion of the
website. The log is in there. But, no, I've never done
a search to see who else is asking for records.
Q. But you look at the log and it shows you who
is making public records requests, right?
A. I've seen that. Yes.
Q. And you've made public records requests on
days when you've looked at the log, and seen that
various O'Boyle entities and clients have also made
requests, right?
A. I've looked at the log, and I've seen that
lots of people make requests on the same day.
Q. The lots of people that are making requests,
sir, are you and other clients of the O'Boyle Law Firm
and their alter egos. You're aware of that, right?
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. There are no "lots of people making requests"
other than the O'Hare and O'Boyles and their alter egos;
are you aware of that?
A. I don't know who is behind those other G -mail
accounts.
MR. HANNA: Can we take a break? It is also
5:00 o'clock, and I want to -- do you have any
questions regarding the -- something related to the
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motion to disqualify? Because we're going to be
running out of time.
MR. SWEETAPPLE: I do. I have questions --
this is all related to the motion to disqualify.
MR. HANNA: That's --
MR. SWEETAPPLE: If you read the law. Read my
memo. You'll see what the standard is. My memo
sets forth that you have to show that my
representation in this case involving these facts,
these people, and these issues, somehow will
negatively impact something I accomplish --
MR. HANNA: I thought you only represented the
town in one case, one single case. That's what you
said before.
MR. SWEETAPPLE: Your allegation is that --
MR. HANNA: You're representing them in a RICO
case and all the cases --
MR. SWEETAPPLE: Right. That's why I'm asking
him about -- I'm asking him about every case that
you're alleging that I'm representing him in. And
I also filed a motion for leave to file a
counterclaim in this case, I believe.
MR. HANNA: And also you filed it in the same
case in numerous times. You don't --
MR. SWEETAPPLE: I'm going to be going
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through --
MR. HANNA: You can't file the same case 30
times.
THE WITNESS: Can we argue this --
MR. SWEETAPPLE: Yes, you can, if you move to
consolidate them and transfer them to a judge. And
I've already told Judge Blanc I'm doing that. Of
course I can.
MR. HANNA: You can file it one time.
MR. SWEETAPPLE: No, you can't. You can file
it in any case.
MR. HANNA: So if there's a car crash, I can
file 15 cases?
MR. SWEETAPPLE: This is not one car crash.
You're wrong on the law.
MR. ROEDER: Let's take a break.
THE VIDEOGRAPHER: The time is 4:52. We're
going of the record.
(At 4:52 p.m. a recess was taken)
(End of Volume I)
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Page 119
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I, the undersigned authority, certify that the
aforementioned witness personally appeared before me and
was duly sworn.
Dated this 4th day of March, 2015
Debra Duran - Bornstein, RPR, CLR
Notary Public - State of Florida
My Commission Expires: 8/20/15
My Commission No.: EE 112218
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Page 120
C E R T I F I C A T E
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I, Debra Duran - Bornstein, Registered
Professional Reporter and Notary Public in and for the
State of Florida at large, do hereby certify that I was
authorized to and did report said deposition in
stenotype; and that the foregoing pages are a true and
correct transcription of my shorthand notes of said
deposition.
I further certify that said deposition was
taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and
completed as hereinabove set out.
I further certify that I am not attorney or
counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
action.
The foregoing certification of this transcript
does not apply to any reproduction of the same by any
means unless under the direct control and /or direction
of the certifying reporter.
Dated this 4th day of March, 2015.
Debra Duran - Bornstein, RPR, CLR
Notary Public - State of Florida
My Commission Expires: 8/20/15
My Commission No.: EE 112218
Debra Duran & Associates
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Mark Hanna, Esquire
401 South County Road
Suite 3272
Palm Beach, Florida 33480
In Re: O'Hare vs. City of Gulf Stream
The referenced transcript has been completed and
awaits reading and signing.
Please have your client review your copy of
the transcript at your convenience or if a copy was not
ordered, to call our office at the below - listed number
to schedule an appointment between the hours of 9:00
a.m. and 3:30 p.m., Monday through Friday to make an
appointment to come to our office and read the
deposition. If desired, your client may also opt to
waive signature. If so, please have your client sign
their name at the bottom and mail to our office to be
attached to the original transcript.
If the transcript is not reviewed and signed
within 30 days, the original, which has already been
sent to the ordering attorney, may be filed with the
Clerk of the Court.
Very truly yours,
Debra Duran & Associates
224 Datura Street, Suite 402
West Palm Beach, Florida 33401
PH: 561) 313 -8000
I hereby waive my signature:
CHRISTOPHER O'HARE
CC: All Counsel
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 121
Page 122
1 C E R T I F I C A T E
2 - - -
3
THE STATE
OF FLORIDA)
4
COUNTY OF
PALM BEACH)
5
I hereby certify that I
have read the
6
foregoing
deposition by me given,
and that the
7
statements
contained herein are true
and correct to the
8
best of my
knowledge and belief,
with the exception of
9
any corrections
or notations made
on the errata sheet,
10
if one was
executed.
11
12
13 2014.
14
i
Dated this day of
19 I CHRISTOPHER O'HARE
20
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25
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Pagc 123
E R R A T A S H E E T
IN RE: O'HARE V CITY OF GULF STREAM C.R. DD
DEPOSITION OF: CHRISTOPHER O'HARE
TAKEN: 2 -19 -2015
DO NOT WRITE ON TRANSCRIPT — ENTER CHANGES HERE
PAGE # LINE # CHANGE REASON
Please forward the original signed errata sheet to this
office so that copies may be distributed to all parties.
Under penalty of perjury, I declare that I have read my
deposition and that it is true and correct subject to
any changes in form or substance entered here.
DATE:
OF DEPONENT:
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
$1 12:4
$12,000 8:15 9:6
0
0505017835 11:5
1
1 73:13 74:11,14
1(a) 112:22
10 73:13 74:12,14
100 64:8 65:1
11 73:14 74:12,14
119 112:15
12 66:19 68:3 73:14
74:12,15 112:3,6
12,000 9:18 11:1
12th 66:25 67:5,12,
68:16 69:11,21
70:2,5 75:24
13 73:14 74:12,15
14 52:5,9 73:14
74:12,15 87:6
14th 73:776:2,10
15 22:13 73:14
74:12,15 118:13
16 73:14 74:12,15
17 73:14,19
17th 73:12,15
18th 52:6,7 73:22
1983 25:8
1998 7:12,2011:5,
7,16 17:6 20:4
21:14,19 22:1,11,
22 23:15 24:2,6,12,
20,2126:7,20
27:15,20 28:23
30:3 31:1,1149:10
50:20,23 51:1
61:11,13,1464:13
72:23 97:11,15,17
98:3
19th 74:2
Y1
2 73:13 74:12,14
2,000 41:15
113:12,21
2008 28:21
2012 26:12,15,16
27:25 99:12
2013 26:15,1727:5
28:2 49:13 76:23
77:8 78:13,17
80:12,14,16,18
99:12
2014 4:20 51:4
52:10 66:25 67:16
68:3 69:2170:2,5
74:18 87:1,24
89:12,13,15,22,25
90:22 91:9 95:10
21 16:11 18:8 22:3
22 7:8
23rd 52:7
267085619 11:4
27 52:9
3
3 73:13 74:12,14
30 4:20 118:2
35 13:8
3:52 73:2
3rd 43:452:5,6
74:11,15
rl
4 73:13 74:12,14
4:03 73:3
4:52 118:17,19
4th 75:20
5
5 73:13 74:12,14
50 83:20,25
561350 -7551
65:11
5:00 116:24
5th 52:6
6
6 52:8 73:13 74:12,
14
60 86:25
7
7 73:13 74:12,14
8
8 73:13 74:12,14
9
9 73:13 74:12,14
98 24:22 25:23
50:24
A
abbreviated 9:5
absolutely 30:13
64:12 75:13 104:9
abuse 104:11
abusing 104:13
access 80:10
accomplish 42:20
117:11
account 7:6,9,10,
20,22 11:3,4,5,12,
16,17,19,2153:6,
21,23 54:156:12,
15 57:4,6,8,10,11,
12,14 58:3,5,7,8,23
59:2,22 60:3,4,6,8,
24 66:8,11,16,18,
22 68:1,24 69:1
71:17,24 72:1,3
101:18 102:25
accounts 59:16
62:15 72:22
100:14 101:16,17
102:18 103:3
116:22
accoutrements
6:15
accredited 11:23
accurate 25:24
accurately 18:23
Acquisition
72:15,18
act 42:7
action 17:16,25
25:8 30:12 35:21
actions 114:4
activity 71:1
actual 63:5 98:15
addition 106:10
address 62:11,25
63:8,14,24 64:2
102:10
addresses 62:22
63:17 102:8
adjacent 18:25
admonitions 8:20
advocating 35:2
affirmed 4:5
agencies 92:6
agency 83:15
agenda 115:23
agendas 115:24
agents 37:14 99:18
agree 86:2
agreement 12:20
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: $1- applies
18:13,15 23:17
38:144:5,9,11
48:4,16,2054:23
55:1,4,6 98:17
agreements 46:3
47:11,13,14 94:17
ahead 32:6 37:9
102:16
air 61:22 66:17
Airline 61:22
alias 60:168:21
aliases 68:23 69:25
allegation 117:15
allegations 37:13
allege 88:24
alleged 30:233:4
88:11
allegedly 99:24
alleging 117:20
allowed 88:16
alter 116:15,19
amazed 56:4
ambiguous 83:13
Americo 66:2,5,8,
14
answering 114:2
answers 25:21
59:4
anybody's 66:1
anymore 66:1
anytime 112:10
appearance 32:25
35:13
appearances
33:10
appeared 14:5
32:23 33:6,14,20
34:19 35:18 89:3
94:2 98:14 102:11
application 23:7
applies 4:14
approve 110:10
Approximately
5:20
April 52:5,9
area 64:16
argue 29:19,24
39:1,3 40:7 45:2
118:4
arguing 39:23
arguments 39:6
article 91:19
• 106:4,11,19,20
ascertain 40:10,24
41:6,13
assert 36:7
asserted 39:8
asserting 37:7
101:1
assisting 79:13
assuming 109:10
AT &T 65:12
attached 14:11,12
15:19 23:3
attachments
101:25
attempting 30:9
42:19
attest 68:19 77:15
attorney 22:24
39:12 46:22 48:24
50:6 51:23,25 52:1
54:16 79:19 80:14
94:3
attorney's 45:23
46:7 110:18,20,25
112:21
attorney - client
36:14 38:23 46:15,
19
attorneys 9:24
23:13 36:4,6
44:22,23 47:5 89:6
100:15
attorneys' 94:18
audio 92:8
authority 51:11
99:25
authorized 36:17
51:19 55:9
aware 23:22
32:1 B,22 33:1,3,12,
14,18 34:16 35:12,
17 40:9, 41:12,22,
23 44:2 49:22
50:11,14 52:4,13,
14,17,19,22 67:12,
1673:6,11,12,18,
22 74:4,8,24 75:22,
25 76:4,8,13,17
92:20,2193:1,6,10
95:23 100:21,23
101:3 112:15,20
116:15,20
Awareness 73:9
74:3,8 76:7,13,21
88:4,12,14,18,22
93:1,5
B
back 8:14,1812:11
15:18 17:13,15,20,
19:22 20:24 21:3
22:18,2125:3,14
30:18 55:156:7,22
57:24 60:25 73:4
83:18,21 84:1
98:15 101:24
107:7 108:5,7
109:1 110:23
balance 21:4
band 15:22
bank 7:20 9:13
10:2,5 11:4,9,10,14
12:2,16
barrage 82:20
based 33:3,12
basically 57:18
83:14
basis 93:19,24
Beach 5:11 13:6
114:17
begin 109:12 110:4
behalf 13:1314:6
33:13 50:2,9 51:6,
9,12,19 53:2,4
78:6,7 94:3 99:24
believed 36:19
42:6 89:25
Bendex 68:4,7,11
benefits 78:25
79:1
big 102:11
Bill 60:12,17 61:12
bills 9:1048:7
Billy 59:23 60:2,5,
6,9,17,2161:3
bit 71:13
Blanc 118:7
Bob 4:1011:2
16:5,9 34:4 40:6
71:7,12 114:24
book 7:22
books 8:21 11:23
80:10
bottom 10:25
bought 11:11
bound 15:21
box 5:6,14,18,19,
25 6:11,12,13,17,
20, 7:25 8:2 15:19
16:15 18:3,5,12,20,
22,24,25 21:5
boxes 6:6,7,9
14:21,22 15:23
16:4 18:11 19:25
57:18
boy 38:17
Boynton 5:11
bracket 110:2
break 71:12 73:1
116:23 118:16
Brewer 68:17,21
69:3
Bridges 16:12
bring 20:19 51:23
91:13
bringing 20:21
82:19
broad 31:24
broadcasting
109:8
brochures 6:14
brought 24:17
46:9 83:1
Broward 13:8
bugging 42:15
building 95:14,15
bundle 17:15
burdening 84:22
burdensome 84:7,
10,1185:1,6
business 6:14 9:24
94:21,24
button 65:23
buy 79:1,2,3
L
CAM 88:14 95:25
96:8
called 22:2 25:8
88:12
calls 36:13
canceled 12:2
capable 114:2
capacity 4:12
car 79:3 118:12,14
cardboard 5:18,
19
cards 6:14
case 19:3 31:19
32:9,19 35:9,14,18
38:12,15 47:21,25
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: approve -Chris
48:2164:12,14
94:11 117:9,13,17,
19,22,24 118:2,11
cases 32:23,25
33:5,10,14,20
34:19 42:7 46:9,
10,13 47:4,8 94:13
96:3 117:17
118:13
cassette 16:3,6,9
19:25
cell 65:6,7,8,9,14,
17,20 70:3 92:9
certificate 37:10
certify 37:9
cetera 35:1
CG 72:15,18
Chandler 26:13,
20 27:9,10,13
28:17 29:1,3,6,11,
12913 31:15,16
40:19 41:7 76:23
77:7,13 78:14919
79:21,25 80:8,19,
23 81:4,12,22 82:4,
9,11,17,20 83:1,6
85:9,12,16,19,25
86:19922924 87:7,
11,12,20,22 88:8
89:1,8,2190:394,8,
13,18 91:11,22
92:4,9,12 96:1,7
97:17 103:23
changed 11:13
characterization
102:7
check 7:149:4
12:2 21:3
checks 9:24
Chief 16:6,9
Childers 7:7
chopped 106:7
chose 107:22,23
112:17
Chris 16:7,10,
19:12 63:13 66:20,
22,25 67:13
chrisoharegulf
63:15
chrisoharegulfstr
eam @gmail.com.
63:16
Christopher 4:4
7:7 66:3 102:11
cite 111:2
Citing 83:12
Citizens 73:9 74:3,
8 76:7,12,20 88:4,
6,12,14,17,2193:1,
4
city 22:6 49:23
civil 25:7
claim 14:8,9 25:7
40:16 47:24 80:17
88:23 101:1
claimed 91:3,4
claims 35:5,7
98:16 109:19
110:9
clarification 61:6
clarify 19:1628:12
56:22 85:24 89:16
111:24
clear 83:13,15
104:5
clerk 84:12,13
85:6 111:12,19
112:3,11 113:4,18,
20
clerk's 84:4,13
111:16 112:10
client 33:18 39:13
94:22
client's 43:7
clients 94:25
95:17,20,21
113:12,21 114:5,8,
20,21 116:9,14
Co- counsel 94:9
coconspirators
37:14,19
code 17:16,17,25
20:123:17 31:9
98:4
Columbus 66:3
comment 67:3
110:13
Commerce 95:13,
24
commission 70:16
Commissioner
16:12
commit 96:18 97:3
100:1
communicate
36:19 62:5,8
63:21,23 64:4,24
communicated
36:16 62:9
communication
39:14 89:6
communications
30:13 101:23
companies 95:15
company 61:21
62:3 72:15,18
compensation
77:25
competently
113:19
complained 106:8
complaint 28:18
34:24 81:19
complete 105:7
comply 84:13
computer 62:13
concert 114:5,7
conduct 94:20
conducting 94:23
conference 95:16
confess 65:22
confidence 55:21
confident 55:21
confidential 43:3
88:18
confused 98:9
confusing 32:20
101:25
conjunction 81:9
connect 108:4
connection 89:5
consideration
31:20
consolidate 118:6
constitutional
84:8
construction 22:3
contact 90:2
contacts 65:25
contained 18:24
content 45:14,15
contingency
47:18 93:19 94:17
continue 30:17
89:21,24
contractor 112:17
contractors 92:14
conversation 33:4
61:19 85:20
conversations
26:6
cooperative 27:18
coordinated
70:24
copied 107:19
copies 22:16,18
24:1,23 75:2
101:14
copy 100:8111:4,
10,17 112:11,13,24
113:4
copyright 107:20,
Index: chrisoharegulf- deposition
22
corporate 4:12
correct 10:611:2
23:18 68:4 69:1
83:18 94:5,98:6
111:13
corrected 9:22
correcting 98:8
correction 8:18
correspondence
70:25
costs 109:13,14
110:5,6,18,20
counsel 39:17,21
46:20
counterclaim
117:22
counting 15:16
country 13:10
County 13:6,8,9
court 13:12105:10
cover 8:7 9:9,17
covered 39:15
44:8
crash 118:12,14
create 53:21,22
56:12,15 57:4,16
59:22 60:3 66:8,17
68:196:2
created 57:11
68:24
creation 66:7
crossed 11:141:3
crossed -out 8:17
current 34:14 36:8
Curry 16:7,10
cursor 102:10
custodian 111:13
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
10
D +a +a- p- u -t -r-
a 50:6 58:2
Dade 13:8
date 5:24 6:17,22
24:14 25:24 27:7,
24 28:3,7 67:18
68:5,19 78:16 89:2
91.•8 99:14
dated 4:20
dates 7:167:8
73:20
day 21:3 54:8 67:6,
13 68:3,17 69;13,
23 73:9 74:4 75:21
76:6 83:20, 92:25
93:3 97:7 114:10
115:7,8 116:12
days 74:7 92:23
93:8 97:7 116:8
decide 103:17
defendant's 5:2
14:17 105:15
defendants 14:15
defending 14:9
defense 18:1
define 14:3
delete 106:10
denial 25:10
denied 25:9
depo 14:15
deposit 4:25 7:5,
21,22 8:15,20 9:11,
13,15,21 10:5 11:1,
6 12:1
deposited 8:16
9:12,13,20 10:2,5
deposition 4:11
9:3 19:14 21:7,12
23:4 29:8 31:23
39:19,22 40:3
48:25
Design 8:6
designed 16:12
Designs 9:5,17
59:7,9
desire 113:1
desk 6:25
details 26:4 55:2
96:20
diagrams 19:7
dial 65:24
diatribe 64:18
difficult 66:15
104:2
Digby 16:12
digging 103:4
digital 100:11,12
105:4
Dinner 79:2
direct 4:7 74:16
79:18
directly 11:22
77:19,20,2179:5
disclose 91:22
discover 102:12
discovery 30:10
discuss 43:1144:2,
8,10,16 45:4 70:7
76:20,23 86:10
87:8,22 88:4,16,21
103:23 104:1
discussed 43:4,21
44:18 45:5 63:2
70:17 71:5 88:6
discussing 87:9
discussion 103:25
discussions 44:22
disgusted 82:4
disgusting 82:8
disqualification
29:9 64:10
disqualify 4:21
29:14,16 30:24
31:17,25 32:9,10,
18,23,25 33:5,13,
19 34:13,18 35:8,
14 36:140:4,22
42:14,25 43:13
46:18 47:4 117:1,4
distributed 43:8
distribution 8:6
9:7,16,23 11:21,23
dividing 94:18
Djajaputa 49:9
Djajaputra 49:22
50:2,6
document 6:23
7:18 8:1,9,23,24
9:25 10:9 13:12
67:2,3 104:7,23
108:6 111:17
documents 4:19
6:24 7:14,25
17:19,22 23:2,3,14
100:16 112:18
dominating 84:12
doubt 49:25
dozen 70:15
111:18
dozens 100:23
draft 107:15
drawers 6:25
Drive 18:8 22:3
drop 20:14
dropped 20:15
duly 4:5
dumped 6:6
E
e-mail 33:8,12
62:699,1192163:8,
17924 64:2 66:8
70:5 77:12 102:7,
10,13,24 105:21
e- mailed 64:7 65:1
77:14
e -mails 61:6 62:17
76:20 81:22 86:11,
14 87:23,25 88:21,
22,25 90:17 108:5,
7
earlier 4:14 91:20
98:8 105:5
early 78:17 90:21
91:9
easier 83:15
easy 61:1
echo 112:21
echos 112:22
edit 106:16108:2
edited 107:1,12
edits 106:1,14
Edwin 31:4,8
efficiency 97:9
effort 100:25
efforts 111:9
egos 116:15,19
election 87:4
election -style 87:5
electronic 103:4
electronically
112:18
Ellis 67:17,19
68:13
else's 57:15
employ 49:9
employed 79:10
employee 54:18,
20 58:24 59:17
71:20,21
employees 59:6
employment
42:23,24
empty 6:4,11,12
end 118:20
enforce 107:21
enforcement
17:16,17,25 31:10
entire 85:8
entities 116:9
entitled 44:24
48:3,6,8
entitlement 48:2
113:3
entity 12:2213:13
61:24 72:16
establish 25:6
30:11
estimates 101:3
events 30:12
evidence 15:8
17:25
exact 24:14 27:7
28:3,7 57:17 85:20
96:13
EXAMINATION
4:7
examine 8:23
10:15 67:3
examined 4:5
exception 88:24
exchange 90:17
exchanges 77:12
exempt 112:4
exemptions 112:8
exercising 84:8
exhibit 4:24,25 5:2
6:18 9:2 10:1,25
14:17 105:8,15
106:23,24
Exhibits 14:10
exist 101:21
existed 11:572:23
79:12 113:6
exists 101:22
expect 113:10,18
expectation 55:20
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: Design - fictitious
expected 55:21
experience 92:19
explained 83:14,
15
Express 20:17
extended 14:8
extensively 109:5
extent 13:9 44:21
F
face 34:6 112:1
facilitate 83:25
fact 23:1247:3
52:4 70:12 112:16
factors 110:21
facts 117:9
factual 105:24
factually 105:6
failed 103:6
fair 4:15
fake 102:4,7
familiar 72:15
104:14
family 12:2113:13
Fargo 11:11 12:15
fault 102:21,22
February 73:7,13,
15,19,23 74:2
89:15
federal 20:17
38:25 39:14
fee 38:146:247:24
48:4,16,20 54:23
fees 38:5,13,16,18
39:13 45:23 46:7
48:2 94:18 109:21
110:11,18,20,25
112:21,23 113:1,3
fictitious 66:16
86:8,15 106:5
figured 15:9
107:17
file 5:14 6:19 17:17
19:6 22:3,4 28:13
31:20 34:3,24
36:17 49:12 50:8,
25 52:2 60:21
74:16 75:4,12
83:20 96:11
100:10 101:8
103:4 110:17,19
117:21 1182,9,10,
13
filed 27:2228:9,18
30:21,23 32:8,9,10,
16,18,19,22,25
33:5,13,19,25 34:1,
18 35:7,8,9,10,12,
13 36:137:15
40:2141:15 42:4,
14 43:13 46:18
49:14,17,19,23
50:1,3,12,15 51:3,
5,6, l7 56:2 60:20
70:23 71:1,3 75:8,
20,22,24 76:2,6,7
80:25 96:14,23,25
97:5 99:16,20,23
109:21 110:19
112:9 117:21,23
files 18:1722:4
filing 14:8 33:10
54:7 61:15 70:8,
12,20 71:10 76:24
81:5 83:7,24 97:12
110:22 115:18
fill 57:18
film 92:6
finally 57:24102:1
find 5:5, 12:15,18
13:6 14:1 18:2
19:4 48:3,7,8
72:12 100:22
102:12
finding 56:3
finished 62:23
firearm -type 82:2
firm 11:16 12:4
13:7 40:11,18
45:5,22 46:3,8,9,10
47:5 79:10,12
90:21,25 91:1,3,5,
7,12 93:13,18
94:16,22 95:2,5,8,
18,24 96:10,15,24,
25 97:5 113:13,22
114:6,8,21 116:14
fit 64:15
flattering 109:7
Florida 7:2011:4,
10 38:24 39:14
41:17 91:14
112:15
fog -watch 82:17
folded 15:3
form 13:16 32:20
33:7 34:22 36:2
37:17,18 38:6
41:1,8,18 44:13
47:19 52:1154:10
61:17 63:3,6 69:16
75:15 76:14 80:1
82:22 83:3 84:15
85:2 90:23 91:25
95:19 96:5 97:1
98:19,24 99:19
101:10 102:6
113:14,23 114:11
116:16
formed 90:21
forthcoming 99:5
forward 102:24
forwarding
101:24
Foster 35:1
found 5:23 7:25
8:2,12 11:25 12:2,
20,24 13:2,11
14:21 15:19 18:16,
18 25:8
Foundation 73:9
74:3,8 76:7,13,21
88:5,6,12,18,22
89:193:2
Frank 71:22
fraud 31:22 88:24
fraudulent 75:14
front 8:18 39:6
full 6:13
funny 33:25 34:3
M
G-mail 100:14
101:15 102:18
104:19,20,22,25
105:3,20 116:21
G- mail's 102:22
gave 4:13,1617:1,
12,13,15 19:21
24:10 25:4,17 26:3
58:13 60:16 67:23,
24 72:7 107:24
GD 64:1
general 18:11,25
generally 87:3
Ginsberg 106:11
Ginsberg's 28:13
girl 22:8
give 20:6,8,22:12
25:20,23 62:24
70:17 83:6 99:13
107:5,13 108:1
111:20
giving 25:3 34:1,2
glad 43:6109:7
Gleason 68:14
Gmail 53:21,22
54:156:12 57:4,5,
16,17 58:3,7 59:2
60:6,10,24 62:15,
17,24,25 63:5,8,14
66:11,22 71:23
72:1,3,22
goal 109:20
goals 42:22
God 110:23
Good 4:19
government
97:25 111:23
112:16
governments
92:13
grammatical
106:18
granted 25:9
gratis 93:19,23
Gray 91:16,17,23,
24
green 65:22
grin 34:6
Group 95:13,24
Grove 8:69:5,17
59:7,9 100:13
guess 15:1621:8
42:15
guilty 25:7
Gulf 4:2226:8,11
28:14 37:16 40:23
41:16 49:24 54:5
56:10 60:13 66:21
24 70:8,13 71:16
74:17 76:1180:25
82:20 85:7,23
92:22 96:1197:7,
14 99:11, 100:17
104:14 113:10,20
114:9,20,23
guy 16:7,11
1;J
hoe 37:24 94:3
98:14
half 4:16 27:2
hall 22:6,7 24:15
hand 33:2534:2
handed 17:2421:4
25:10
handing 8:24
handled 8:21
handling 31:9
handwriting 7:13,
15,17,18 10:22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: figured -heard
11:25
Hanna 8:2513:16
23:19 29:7,11,17,
19,24 30:4,8 31:4,
8,14,23,25 32:2,4,
6,20 33:4,7,13
34:22 36:2,12,17,
2137:3,7,18 38:6,
9,20,23 39:1,3,23
40:2,6 41:1,8,18
43:1,14 44:13,17,
20 45:1,7,12,19,24
46:4,14 47:12,15,
19,22 48:1,5,9,12,
17,2149:1,5 52:11
53:16 54:9 55:16,
24 61:17 63:6
69:16 71:7,12
74:19,22 75:15
76:14 80:1,4 81:1,
7 82:22 83:3,22
84:15,20 89:2,4
90:23 91:25 93:15,
21,25 94:7,8,9,11
95:19 96:5,12 97:1
98:19,25 99:19
101:10 102:6
105:11 113:14,23
114:11 116:16,23
117:5,12,16,23
118:2,9,12
happen 69:13
90:15
happened 6:9
25:1 1,15 31:144:2
64:13
happy 67:3
harass 101:8
104:10
harassing 104:12
Harbour 7:8
hard 34:1,2
Harry 69:5,8
head 40:14 58:22
68:10 81:5,17 82:1
88:10
hear 44:24 72:17
82:3
heard 61:24 81:6,
2188:13,14,15,17
90:24 91:4,6,18
110:12,14
hearing 10:12
31:10 81:20 82:6
91:20 92:1
heavily 107:1
held 106:14
helpful 83:8
helping 89:17
highlight 110:1
highlighted
109:25
Highway 61:22
Hillary 16:6,10
hire 96:1
hired 108:23
hit 76:10,15
Home 107:2
honest 36:4
hope 103:8110:23
hour 4:15
hourly 47:17
house 86:24
housing 79:2
hundreds 13:6
37:15 85:22 86:1
97:12,13
I
idea 25:2242:4,23
60:16,18 68:12
69:17 70:4,6 72:19
87:14 93:9 95:20
97:11,15,17,20,23
identical 58:6
identification 5:3,
25 6:9 14:18
105:16
identified 10:1
102:8
identify 6:22
identity 39:13
impact 117:11
impression 13:4
43:19
inaccuracies
105:25
include 40:16
51:18 61:5 80:15
Including 37:14
incorrect 105:6
incurred 109:14
110:6
indirectly 77:22
78:24 79:6
individual 91:16
information
33:2135:16 36:3
43:8 61:10 107:18
114:24
infrequent 90:16
Initially 90:19
inkling 96:8
inquiry 30:17
64:16
inside 15:22 16:3
19:24
inspect 111:4,10,
16 112:11,12,24
113:4
instruct 36:12,22
37:3 38:9,20 44:21
45:7,12,19,24 46:4,
14 47:22 49:5
55:16,24 74:19
80:2,4 81:1,7 89:4
93:15,2198:19,25
instructed 39:5
instructing 43:23
84:18
instruction 83:6
instructions 4:13,
16
intending 33:24
intention 6:7 9:21
35:2 42:18 104:12
interest 12:22
13:14
interpretation
89:20
interviewing
16:7,10
introduce 85:9
87:17
inundated 113:11,
20
inundating 114:1
investigation
102:12
invoking 46:18
involve 21:14
involved 13:7
22:23 39:1146:13
80:16 97:12
108:15,18 109:11
involves 31:19
involving 89:6
117:9
Irene 56:11
Irene's 58:6
Irnawaty 50:17,24
51:23
isolate 60:23
isolated 103:3
issue 30:19 39:11
99:6,7,9 113:5,6
issues 80:13 89:17
106:18 115:25
117:10
items 115:23
J
Jackie 68:14
Janto 58:2,8
January 4:20
87:1,23 89:12,13
job 84:23
Joel 28:17 29:11,
12,13 31:15,16
41:7 85:9,12,13,14,
15,19,25 89:1
John 68:17,2169:3
joining 34:23
Jonas 20:6,8,10
31:5,8
Jonas' 23:4
Jonathan 37:23,
25 38:1,5 40:24
41:14 45:4,10,
65:17 76:6,12
81:24 88:2,23,25
92:2194:2,15
97:23 98:14,18,23
Jones 35:1
judge 39:7118:6,7
juncture 48:5
June 52:867:17,19
68:13
jurisdictions
13:10
LN
Karen 22:8
keeping 57:22
kill 81:5,18 82:2
kind 34:347:13
69:17 89:6 103:25
knew 114:19115:1
knowledge 37:1,6
42:1,13 51:178:4,
9 79:18 91.15
93:12 94:20,23,24
103:13 107:17
109:10 114:14,15,
16
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: hearing- litigating
L
Lafarge 69:5,8
language 8:23
112:21
law 30:16 38:25
39:14 40:11,18
44:145:5,22 46:3,
8,9,10 47:5 79:10,
12 80:8 90:21,25
91:1,3,5,7,12
93:13,18 95:2,5,8,
18,23 96:10,15,24,
25 97:5 113:13,22
114:5,8,21 116:14
117:6 118:15
lawsuit 13:23 14:3
27:22 28:9 30:21
51:17 96:14,21
112:9
lawsuits 13:652:2
96:10,19,23 97:8
110:17,19
lawyer 13:2 33:19
34:8,13 64:15
94:12 109:18
110:7
lawyers 38:16,18
44:191:12
lay 47:3
learn 91:11
leave 117:21
left 21:4
legal 13:1129:22
30:1 109:13,21
110:5,11 112:25
113:1
lesser 13:9
letter 12:24 23:16
letters 18:17
liability 48:2
lie 33:16
limited 64:1
litigating 35:23
litigation 109:20
litigations 109:12
110:4
living 75:19
LLC 59:7,9 61:22
72:20
locate 5:12
located 5:10 7:2
location 18:11
log 100:3,4 116:2,
4,8,11
long 7:227:128:4
34:3 54:25 55:5
78:19,21
longer 72:14
looked 12:5,6,14,
13:15,17 14:4
113:2,5 115:7,11,
22 116:8,11
loose 5:16,17
loss 96:16
lot 80:13 103:1
114:17
lots 116:12,13,18
Love 71:16
lunch 79:2
Ul
made 11:2221:19
22:24 23:13 24:4,
26:7,10 32:24 34:9
39:5 48:9 51:8,14
52:5,24,25 56:21
57:5 60:24 66:13,
16 67:8,12,13,17,
2168:2,17,25
69:10,14,23,24
73:18,23 74:2,3,7,
1181:9,19 86:5,11
93:7,10 98:8
100:7,16,24,25
101:3,13,14 104:4
111:16 115:5
116:7,9
made -up 66:4
67:20
mail 104:16,18
Mail.com. 62:20
mailbox 105:14
maintain 7 :23
make 6:5 8:19,22
21:23,24,25 22:11
24:1,1132:17
33:2137:10 39:6
49:3 51:11,19 52:1
53:4,15 54:3,4
55:10,14,19 56:13,
18,24 57:158:15,
17,20 61:3 66:5,18,
19,24 67:6,9 69:11,
13,20 72:1,2 73:16,
20 83:14,20 85:22
92:14 93:25 100:3
101:7 103:24
106:1,9 107:5
111:9 113:3
116:12
makes 69:18
making 34:6 56:9
57:20 64:14 72:5
83:9,12 92:5,22
93:2 106:9 114:21,
22 115:3 116:5,13,
18
manager 60:13
March 74:11,15,
18 75:20,24 76:2,
10 87:6 89:15
mark 8:25 9:2
14:13 105:8
marked 4:245:2
14:17 105:15
Married 68:14
Martin 13:9 26:23
27:1,9 40:20 59:17
62:5,8 63:23 64:7
69:11,12,2170:11
75:2176:20 85:9,
15,18,25 86:18,22
87:19,23 88:25
Marty 70:23
107:11 109:3
material 17:15
matter 30:16
93:20
matters 30:6,10
Mayor 109:18
110:7
meaning 9:7
mediation 43:12,
13,22 44:2,3,19
45:6,11 88:19 89:2
meet 26:13 27:1,8
77:1,7 90:4,7
91:17
meeting 31:643:3
44:1188:16,19
98:3
meetings 82:4
86:18,21 110:13
114:19
member 13:13
members 12:21
memo 23:16,17
117:7
memorialize
92:10
memorize 27:24
63:22 67:8 68:19
73:16,20,25
memorized 63:11
91:8 94:13
memory 21:11
96:18 97:3 100:1
mentioned 59:8
meritorious
109:19 110:8
message 109:8
met 26:23 28:17,25
29:3 80:19 86:18
87:11,16 95:1
103:23
methods 57:23
middle 109:17
mind 41:3 60:11
mine 7:16
minutes 115:24
miscellaneous 8:7
9:9,18
Mischaracterizati
on 33:8
miscounted 74:14
mixed 57:25
moment 107:5
moments 93:7
money 9:1229:6
45:17 77:18 93:14
109:1 110:23
month 17:3 78:22
months 5:20,21,
78:22
Morgan 109:18
110:7
motion 4:2129:14,
16 30:24 31:17,25
32:8,10,34:18
35:8 36:1,17 40:3,
2142:4,14 43:12
46:17 117:1,4,21
motions 32:22
33:5,13,19
move 37:8 118:5
moved 35:14
42:25 47:4
multiple 54:7
101:15,17,23
102:18 103:2
N
names 69:15 86:8,
15 99:18 102:3,4,7
nature 26:140:24
41:6 42:17,19,21
48:4
negatively 117:11
neighbors 16:7,10
Nevada 71:19,21,
22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: litigation -0'boyle
newspaper 91:19
nickname 56:11
Nicoletti 23:16
Nos 14:17
not - for - profit
88:11,12
notation 8:17
note 10:314:22,23
15:3,4,5 43:1
noted 102:9
Notes 6:14
notice 32:2435:13
111:8
noticed 10:11
number 11:5
33:19 43:9 56:5
60:23 65:8,9,15,20
66:170:18 86:25
96:13 99:15 100:2,
19 105:9
numbers 11:13
numerous 41:14
117:24
0
O'boyle 26:24
27:1,9 28:20 37:23
38:5 40:11,18,20,
25 41:14 45:4,5,10,
17,22 46:3,8,9,10
47:5 62:3,6,8
63:23 64:8,24
65:17 69:11,18,21
70:7,12,19 71:9
75:2176:6,12,20
79:10,12 81:25
85:10,12,19,25
86:4,7,18,22 87:7,
15,19,23 88:2,8,23,
25 90:21,25 91 :1,3,
5,7,12 92:2193:13,
18 94:2,15 95:2,4,
8,18 96:10,15,24,
25 97:5,20,23
98:14,18,23
104:21,22 107:1,4
108:11 109:14,19
110:6,8,10 113:13,
21 114:5,8,21
116:9,14
O'boyle's 65:14
69:12 86:24 90:9
O'boyles 93:7
116:19
O'bare 4:4,912:7
16:12 23:13 31:6,
10 32:8 33:10
59:24 63:14 66:20,
23 67:1,14 73:6
102:11,16 109:14,
19 110:6,8 116:19
object 13:16 23:19
29:7 32:20 33:7
34:22 36:2,12,21
37:17,18 38:6,20
41:1,8,18 43:1
44:4,20 45:7,12,19,
24 46:4,14 47:19,
22 48:18 49:5
52:1154:9 55:7,
16,23,24 61:17
63:3,6 69:16 74:19
75:15 76:14 79:22
80:1,2 81:1,7
83:22 84:15 85:2
89:4 90:23 91:25
93:15,2195:19
96:5 97:198:19,
24,25 99:19 101:10
102:6 107:15
109:6 113:14,23
114:11 116:16
objecting 64:22
objection 38:19
39:5 48:9,23 53:16
82:23 832,3 101:9
102:15
objections 19:14
39:7 49:4
obtain 110:24
occasion 77:6
80:20
occur 41:5 83:24
84:3,17
occurred 21:9
30:14 58:10 113:9,
17,25 114:4,13
Ocean 7:8 20:2
22:14,22,24 23:3,
14,23 24:7 30:14
98:4 99:3
October 21:7
offensive 82:12
office 6:5,10 20:14,
22 77:180:9,21,22,
23 84:4 111:16
112:10
Officer 28:13
106:11
offices 95:1,12,25
Okeechobee 13:9
onerous 104:2
open 15:4,43:5,6
58:3,5,8 59:2 60:4,
8 64:15 71:23
95:24,25 106:5,25
opened 57:15 60:6
95:12
opening 58:22
operating 82:12
operation 97:10
opinion 99:10
112:25
opposed 63:1
96:12 101:18
oral 55:3
order 34:13
110:24
original 8:8 10:7,
8,9,12,16 17:8,11
19:10
outstanding
100:19
overburdening
114:1
overwhelmed
61:10
overwhelming
84:4,7
owns 95:14
P
p.m. 73:2118:19
package 25:2
paid 11:15,16,19
12:3 29:6 38:5,8,
13,15,18 40:1
45:17,22 54:18,20
77:21 80:8 93:13
108:11,12,13
pallet 5:6 6:8
pallets 6:8
Palm 13:6 114:16
paper 5:16,1714:5
52:18
paragraph 109:22
paralegal 77:24
78:1,3,5,7,10,15,20
79:9,15 81:12
89:9,11,17,19
92:17
paraphrasing
82:16
Pardon 98:12
part 10:25 17:17
19:6 31:2140:9,12
41:24 67:25 86:1
98:6,10 107:6
parts 104:19
110:13
party 86:23 87:5,
10,12 882,5 89:14
90:9 95:23 96:6
pass 15:18
password 57:12,
13
past 62:10 115:24
Patriot 104:15
Patsy 114:16
pay 9:8 54:22
77:18,22 792,5,6,
21 108:8,10 109:13
110:5,11
Index: O'boyle's - portable
paying 31:19,20
47:17 79:24 91:13
payment 8:7 9:8,9,
17 31:16 38:25
39:13 93:24
payments 29:13
payroll 54:18
pays 59:9
pen 10:14
pencil 10:14,18,20
pending 42:7
people 30:11
31:19,20 43:9 59:5
76:10 86:25 91:13
101:8 114:17
115:3 116:12,13,18
117:10
people's 99:17
102:4
period 77:23
78:11,12 103:19
114:18
permission 50:8
53:12,14,19,22
56:14 58:13,17
70:25 71:23,25
72:7 75:6,18
107:13,24 108:1,3
permit 22:3,4,5
23:6
permits 25:9
permitted 30:15
person 31:9 49:3
68:11,13 69:7
75:19 102:9
personal 4:12 9:24
11:17,23 28:13
78:8 90:2
personally 20:12
92:5 111:9 112:1
PGD 9:5,1811:20
phone 62:11,12
65:6,7,8,9,15,18,
20,23 66:170:3
92:10
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
phonetic 53:11
56:7 68:4
photo 19:1198:8,
11
photos 18:6,24
19.2,3,4,8,9
phrase 53:10
physically 15:9
111:4,15 112:1,12
pick 68:9 100:24,
25 101:5,7 103:6
picked 100:17,20,
21 101:2,4,102:5,
19 103:10,11,13
picking 103:14
Pictamara 53:10
pictures 14:16,19,
23 15:10
piece 52:18 109:6
pieces 106:3
Pine 64:1
Pineapple 8:6 9:5,
17 59:6,9 100:12
pinegd @gmail.
com. 63:18
place 96:1
plaintiffs 94:18,19
97:6
planned 56:15
plans 42:1
plant 5:8,9
plastic 16:3
pleading 13:11
14:1,5 32:19 36:8
pleadings 32:9,14
35:9,10,13
point 31:9 34:6
39:23 106:9
109:22
policy 106:5
portable 65:6
portion 12:12
116:1
position 102:25
positions 14:24
15:2
possession 100:14
Post 114:17
Post -it 15:14
power 50:5 51:22,
25 52:1
precise 104:5
predicate 47:3
prepare 18:1
prepared 9:4
presence 111:12
present 17:1
44:17,18 86:17,21
90:5,8
presuming 55:25
previous 89:16
106:4
print 106:13
prior 5:13,20,21,
22 7:3 34:15 36:9
49:13 87:23
private 92:13
privilege 37:7
38:23 39:8,16
46:19 88:24
privileged 36:10
pro 37:24 94:2
98:14
problem 58:11
produce 10:11
15:7
produced 18:10
19:8 23:15
producing 5:13
production 15:7
98:9
productions
98:11
proffer 39:10
profit 8:69:7,16,
23 11:20
prompts 60:10
proof 105:23
properties 22:5
23:8
property 16:8,11
23:7 35:22
protege 91:23,24
provide 78:24
111:1 112:17
provided 4:19
14:10 19:3 23:22
providing 93:18
pseudonym
59:24,25
pseudonyms
61:16
public 13:5 21:14,
17,19,25 22:10,25
23:23 24:2, 26:7,
10 27:15,19,23
28:8 35:21,22
40:15 41:16 49:12,
23 50:2,9,11,14,25
51:3,8,11,14,19,23
52:5 53:15 54:3,4
55:10,15,19 56:9,
13,17,20 57:21
58:9,14,17,20
59:13,20 60:21
61:2,15,25 66:13,
19 67:25 68:2,17,
25 69:12 70:13,20,
23 71:1,2,4,5,10
72:5,20 73:8,14
74:16,25 76:11,24
80:12,15,24 81:6
82:18,21 83:7
85:22 86:10 88:9,
1189:18 91:13
92:5,13,14,22 93:2
94:17 96:2,14,24
97:6,13 98:199:4,
9,15 107:17,18
110:13,25 113:11,
114:19,21,24
115:18,21 116:1,5,
7
publication 108:9
pulled 7:22
pulling 102:1
punish 104:10
punishing 104:12
purports 4:24
purpose 40:3
42:23,24 64:15
104:8
purposes 29:8
pursuant 23:15
pursuing 64:16
pushed 6:6
put 6:7 29:22 30:19
39:2,4,9 60:10
106:3 110:14
putra 49:9
putting 107:16
W
question 9:2510:4
12:7,9,23:10,12,20
28:6 30:18 32:11,
15 34:1137:4,8
38:10 39:8,18
41:19,22 48:13
52:14 56:23 64:17
81:14 102:17
113:15
questions 116:25
117:3
1i
rack 5:6
racks 6:8
Randolph 114:16
random 6:8,13
58:10
range 22:12
Rarely 64:8
rationale 103:2,5
read 12:10,12
30:18 88:14 107:5
109:25 111:14
117:6
reading 92:2
108:25 110:1
real 62:25 63:9
68:11,13 69:3,7
realize 74:10
110:24 111:7,22
reason 107:25
reasonable 111:8,
113:9,18
reasons 48:18
101:15
recall 10:16,19,20
20:11,13,21,24
21:2,8,9 25:11,15
26:14,25 28:4,8,11,
19 29:2 38:3 67:4,
5 72:10 76:22
77:25 81:18,19,23
82:1,6,15 86:13,14,
16 87:3 88:20
90:12,15,16 91:20
92:1,9 108:12,19
112:8
recalling 112:14
recently 10:17
15:19
recess 73:2 118:19
recognize 4:25
recollection 16:21
26:4 31:5 72:11,13
98:18,23 115:15
record 12:2,3,12,
18 30:22 39:2,4,10
43:2 46:25 49:17,
19 54:4 56:13
57:25 61:6,25
64:14 68:25 69:12
70:171:10 73:4
92:8 93:10 99:21
100:6 101:3,21
102:2,23 109:18
110:8 111:10,12,20
112:2,11,13 114:25
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: portion-regard
118:18
records 13:5
21:15,17,19,25
22:11,22,25 23:5,7,
24 24.2,7,16,18,24
25:1,4,6,9 26:3,8,
1127:15,20,23
28:8 31:2134:25
35:2140:15 41:16
49:12,23 50:3,9,11,
14,25 51:3,9,12,15,
19,24 52:5 53:15
54:4 55:10,15,19
56:9,17,20 57:21
58:9,14,18,20
59:13,20 60:21
61:1,2,15 66:13,18,
20 67:25 68:2,17
70:8, 13,20,23 71:1,
2,4, 72:5,20 73:8,
14 74:17,25 76:11,
16,24 80:12,15,24
81:6 82:18,21 83:7
85:22 86:1,1188:9
89:18 91:13 92:5,
10,14,22 932,6,7
94:17 96:2,14,24
97:6,13 98:199:4,
9,16 100:9 101:2,4,
6,8,12 102:5,20
103:3,7,12 110:25
111:1,5 112:24
113:4,11,19
114:17,22 115:18,
21 116:1,3,5,7
refer 89:196:19
98:15
referring 19:11
refers 109:5
refresh 98:22
refreshed 21:11
refreshes 98:18
refusal 111:1,3
112:24
refuse 111:19
refused 112:11,12
113:5
regard 4:2138:15
44:14 45:1150:2
56:8 58:2 80:17
81:5 83:8 105:25
107:23 112:9
regularly 115:18
regurgitated
107:12
relate 35:20 60:12,
15 64:21
related 30:6 31:1
34:15 36:9,18
116:25 117:4
relationship
29:12 31:15 40:11,
17,18,20,24 41:7
54:15 64:13
relied 36:7
relying 36:3
remark 34:7,9
remember 4:16,
16:18,23,25 17:2,4
20:20 25:3 57:17
71:5,1177:9 79:8
85:20 86:23 87:2,9
88:1 106:12,21
108:19
remembered 8:19
report 70:19
reporter 12:13
105:10
represent 34:25
42:10
representation
14:7 21:14 30:5,7,
11,20,25 34:14,15,
2135:19,25 36:8,9,
18,19 37:2,12,24
40:10,13,15,23
41:6,13,25 42:5,13
64:22 81:10 93:19
117:9
representative
4:13
represented 13:23
30:2 37:23 117:12
representing 421
42:3 45:10 80:11,
17 117:16,20
represents 46:8,
1180:13
request 21:15
22:25 23:13,16,24
24:1,4 27:23
49:18,20 50:9
51:19 56:161:5
66:20,24 67:7,9,13,
17,25 68:2,17,25
69:12,13,20,23
71:10 75:12 76:7
83:17 99:20,24
102:22 103:18
108:2,3 110:25
111:16 113:3,11
requested 15:8
22:2,4 23:6 55:11
102:20 103:7
104:8
requesting 89:18
requests 21:17,19,
25 22:1124:2,7,11
26:8,1127:15,20
31:2141:16 49:13,
23 50:3,11,14,25
51:4,8,12,15,24
522,5,13,14,17,23,
25 53:4,15 54:4,7
55:10,15,20 56:10,
13,18,2157:3,5,21,
23 58:1,15,18,20
59:13,15,20 60:21,
24 61:3,15 66:13,
18 67:8 69:15,18,
25 70:8,13,20,23
712,4 72:5 73:8,
14,17,19,21,24
742,4,7,13,15,17,
25 75:2,4,8,21,22,
25 76:3,6,11,24
80:12,15,24 81:6
82:2183:7,20,25
84:4,14 85:23
86:1,5,11 88:10
91:13 92:6,10,14,
22 93:2,1194:17
96:2,25 97:13
99:16 100293,7,8,
16,24 101:8,13,14
103:24 1042,4
113:12,19,21
114:2,22 115:3,4,
19 116:5,7,10,12,
13,18
required 102:8
reserve 107:21
respond 39:6
113:10,19
responded 104:3
responding 8:20
response 4:20
14:11,13 83:18,21
84:1 102:24
responses 57:24
100:9
responsible
106:15
retainer 12:20
18:13,15,16 47:11,
14
reverse 15:5
RICO 34:24 35:21
81:18 101:1 102:9
117:16
Ridge 7:8 20:2
22:14,22,24 23:3,
14,23 24:7 30:14
98:5 99:3
rights 25:8
Ring 93:10
Robert 14:22
15:20,24 16:1
robo 54:7,11
Rodrigo 58:24
59:3
Roeder 19:10,16,
19 29:4 31:24
36:1137:14,17
38:19 39:17,20
41:14 43:5,15,18
44:4,17,25 45:15
46:20,23 48:15,18,
21,22,23 49:2
54:13,14,15 55:7,
10,23 63:3 64:17
74:11,16,24 75:20,
24 76:2,12 79:14,
19,21,22,24 80:7,
11,13,16,19 81:13
82:23,25 83:2
89:3,9,11,17 90:1,
5,8,10 98:24 101:9
118:16
Roeder's 75:8
79:15 80:8,10,21
81:9
role 79:16
roof 80:17107:2
room 6:595:16
routing 11:4
row 96:24,25
rubber 1522
runner 20:19 96:2
running 100:6
117:2
rush 6:5
S
sake 61:9
salary 9:8 59:10
save 6:3
scam 31:21
scope 30:25 34:20
35:25 40:2,10,12,
17,18,19,22 41:5,
13,24 422,5,13,16
64:22
scopes 40:22
search 61:10
115:20 116:3
searching 103:2
Section 112:15
seeking 46:7
send 20:17102:23
104:22
sending 102:13
September 43:4
66:19,25 67:5,12,
16 68:3,16 69:11,
2170:2,5
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: regularly -slips
serial 37:15 54:4,6
61:15
served 73:7
server 62:16
115:14
servers 62:19
services 85:22
92:17,18
serving 89:8
set 98:10,11
sets 117:8
settlement 23:17
43:3
Shelley 7:79:6,16
Shelly 7:23
shot 81:5,17,18
82:1,2
show 4:23 34:14
56:20 64:1193:6
109:22 115:14
117:8
showed 95:15 96:4
107:15
showing 15:5
shows 8:14,1712:3
116:4
side 8:14 10:25
15:4,5 16:1,5
sides 7:5 8:3,4
signed 12:21,25
13:12 14:6 16:13
44:5,9,12,14
similar 14:2122:4
23:7 107:9
simply 12:8
single 8:1 15:14,21
117:13
sir 14:3 19:5 37:20
73:21 116:14
slip 4:25 7:5,21
9:15 10:5 11:1,7
slips 12:1
small 21:4
smaller 103:4
Smith 71:19,21,22
so- called 88:9,10,
13 90:21,25 95:18
113:13,25
soda 79:1,3
someone's 75:17
sort 54:13
South 7:8
space 106:5,25
speak 65:4,17
speaking 19:13
39:7 102:15
115:25
specific 83:12
100:5
specifically 20:21,
24
speculating 30:23
35:24 78:8
speech 41:20
speed 65:24
spend 103:1
sponsoring 94:11
spring 24:22 25:23
26:12
staff 85:8
standard 29:15,23
30:1 117:7
start 78:14
started 95:21
state 91:14 92:5,6,
13 96:3 112:16
stated 109:18
110:7
statement 10:4
98:8
statements 81:8
statute 111:5,14,
22 112:15,20
statutes 83:12
stick 15:21
sticker 15:22
stickum 15:14,24
19:22,23,24
stickums 15:11,13
17:9,11
stipulate 48:2
stood 43:8
stop 89:8
stopped 89:25
stopping 61:4,8
stored 6:8
strategy 42:18
Stream 4:2226:8,
1128:15 37:16
40:23 41:16 49:24
54:5 56:10 60:13
66:21,25 70:9,13
71:16 74:17 76:11
80:25 82:2185:7,
92:23 96:1197:7,
14 99:11,100:17
104:14 113:10,20
114:9,20,23
strike 14:1136:25
41:9 47:7,9 92:20
stuck 16:2
style 109:10
subject 26:698:7
103:22
submit 59:12,20
submitted 59:14,
15 73:10,13
subordinate
70:21
subsection 112:22
substantially 30:6
31:134:15 36:9,18
sue 27:14,16,19
99:3,9
sued 28:1197:25
sufficient 33:21
suggest 83:19
suggested 106:17
suit 50:196:20
99:13
suits 97:6
sundry 21:5
supplemental
4:20 14:12
suppose 9:10
supposed 83:9
surgically 104:5
Sweetapple 4:8
5:4 8:7 9:1,9,17
12:10,19 13:18
14:22 15:1,20,25
16:1 19:13,17,20
23:2129:10,15,18,
2130:1,5,9 31:7,
12,18 32:1,3,5,7,21
33:9,1134:12 35:4
36:5,15,23 37:5,9,
11,2138:7,11,22,
24 39:2,9,20,24
40:5,8 41:4,11,21
43:7,16,20 44:6,15,
23 45:3,9,16,21
46:1,6,16,21,24
47:2,20,24 483,6,
10,14,19,24 49:3,7
52:12 53:18 54:12
55:8,18 56:4,6
61:20 63:4,7 64:20
69:19 71:8,14,15
72:25 73:5 74:23
75:16 76:18 79:23
80:6 81:3,1182:24
83:5,23 84:16,24
85:4 89:7 91:2
92:3 93:17,24 94:1
95:22 96:9 97:4
98:2199:2,22
101:11 102:14
105:13,19 113:16
114:3,12 116:17
117:3,6,15,18,25
118:5,10,14
sworn 4:5 24:6
system 62:13,14
Index: small - Tirtarajardja
T
Tahaty 56:7,8
taking 4:11
talk 70:2 89:24
90:13
talked 61:1470:11
85:24
talking 78:11,12
88:22 89:2190:25
talks 112:16
taped 14:2015:23
tapes 14:2015:9,
15,19,20,21 16:2,6,
9,14,16,19 17:12
18:2,12,20,22
19:21 20:1 25:18,
21
taxes 9:8
teeth 102:1
Tejera 58:2459:3,
12
telephone 65:4
90:14
telling 29:20 31:14
33:16 43:25 44:1
86:14
ten 33:1,2,3 61:4,7,
8
tenant 6:5
term 57:17 90:24
terms 81:17,20,22
83:17,18 97:3
test 38:10
testified 4:6 31:8
42:6 46:16,24,25
testify 7:1 13:22
20:15 21:6 67:18
68:5 97:9 105:17
testifying 64:25
testimony 11:15
14:20 19:2124:6
30:15 31:13
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
text 64:5 77:16
106:22
theme 106:7
thereabouts 26:19
thing 13:8 60:11
64:10 66:16
106:25 114:9
things 6:6,1321:5,
10 61:6 70:17
thinking 87:6 98:9
thought 13:22
82:8 84:6,22,25
85:5 113:24
117:12
Thrasher 60:12,
17 61:12
thrasherlies 67:7,
10
ticket 9:11,13
time 8:219:10 21:8
22:10 23:6 25:24
26:10,23 27:22
28:18 32:10 34:1,2
39:25 52:19,22
61:4 73:3 78:11,12
79:19 81:17 84:13
85:7 87:4 88:17
89:14,25 91:6,18
92:16,23,25 93:3
95:7 97:1199:7,8
103:1,19 110:14
114:10,18,22 117:2
118:9,17
timely 113:18
times 28:25 39:11
55:14 64:7,9,23
65:1 70:11 77:7,15
86:21 90:7,11 95:4
98:13 99:23
100:19 103:6,11
111:15,18 112:4,6
117:24 118:3
Tina 59:17
tiny 41:16
Tirtarahardja
50:17,18
Tirtarajardja
51:23
today 52:20
told 8:2121:12
25:6 46:12,17,20,
2151:14 56:9,15
71:6 82:7 100:20
101:21 106:16
108:22 112:4
118:7
tomorrow 103:16
topic 106:19
topics 103:24
total 99:15
town 4:22 20:2
22:7,14 23:8,14,15,
23 24:7,15 25:5,7
26:8,1134:24
35:2,22 37:16
40:15,23 41:16
42:3,8,10 49:24
54:5 56:10 60:13
66:20,24 67:23,24
68:3 70:8,13 74:17
76:1180:25 82:20
85:6,23 92:22
96:1197:13 98:4
99:3,9,11,16,21,23,
24 100:17 102:1
103:15 104:10,11
109:13 110:5,11,17
111:7,8,22 113:10
114:1,23 117:13
town's 61:25
106:5 114:25
115:2,6,11,17,20
Townofgulfstrea
m.com. 107:10
track 57:22 60:25
101:16,17 102:5,19
trade 6:14
transcript 23:4
transfer 4:248:22
9:6,16 12:3 118:6
transferred 11:20
Trasher 59:23,24
60:2,5,7,9,17,22
61:3
trespass 35:21
trial 10:11 31:2,4
Tropical 16:11
18:8 22:3
trouble 56:3 57:22
true 13:8 68:18
78:9 83:4
turn 54:14
turned 18:18,21
19:5
turning 7:3
twisted 106:7
two -sided 8:1
typically 61:7
u
Uh -huh 24:13
65:10 115:12
Undated 6:16
understand 32:17
34:5,20 35:19
37:12 40:2142:16
84:11 101:19,20
understanding
111:6
understood 34:23
Unidentified 5:18
unlawful 111:1,3
112:23
unlawfully 112:12
113:4
unreasonable
85:1,6
update 29:8
updated 31:23
40:3
user 57:18 58:7
V
Verizon 65:13
version 105:4,5
Vespucci 66:2,6,9,
14
vice 37:24 94:3
98:14
vicinity 19:1
video 92:8
view 99:10
violating 25:7
violation 20:1
23:18 98:4
visited 115:20
volume 115:4
118:20
Volunteer 93:24
voted 115:25
W
Wachovia 11:11
12:6,16
waited 34:3
wanted 58:9 70:1
93:25 104:7
ways 104:1
website 62:2 82:17
107:9,11,18 109:9
114:25 115:2,6,11,
17,20 116:2
week 54:8 78:22
91:19
Wells 11:11 12:15
When's 26:10
52:22
Whitmer 81:24
wife 7:23 8:20 9:21
77:4 82:3
William 68:4,7,11
window 24:16
wire 12:3
wires 92:6,7,8
word 42:1676:15
88:13
words 11:6 81:5
work 40:14 50:18,
23 78:15 89:19
worked 50:24 96:7
working 22:9
77:24 85:14,15
90:1
works 72:14
world 30:13
write 9:4,24 105:2
106:3,22 107:2,6
108:23 109:9
writing 8:8,11
55:3 107:19
108:15,18
writings 98:22
written 7:11,12
10:14 12:25 18:5
46:2 47:11,14
48:16,20 54:22
55:4,5 98:17
106:4,11 107:4,9
109:4
wrong 118:15
wrote 106:25
108:20,21,22
109:5,9
L'1
year 5:19 17:5
27:2,4 73:7 95:9
years 13:8 28:5
39:12 64:8 65:2
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: today -years