HomeMy Public PortalAboutO'Hare Deposition Transcripts 2/19/15 Vol 2In The Matter Of:
CHRISTOPHER F. O'HARE v.
TOWN OF GULF STREAM
Deposition of CHRISTOPHER O'HARE
February 19, 2015
Vol II
DEBRA DURAN
A S S O C I A T E S
Registered Professional Reporters
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 II
TOWN OF GULF STREAM,
Defendant.
CONTINUED 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
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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I N D E X
WITNESS: DIRECT CROSS REDIRECT RECROSS
CHRISTOPHER O'HARE
BY MR. HANNA: 206
E X H I B I T S
NUMBER DESCRIPTION PAGE
DEFENDANT'S EX. F DEFENDANT'S RESPONSE TO 172
PLAINTIFF'S VERIFIED
MOTION
DEFENDANT'S EX. G NOTES FROM DAYTIME 193
DEFENDANT'S EX. H DAYTIMER NOTES, SKETCH 201
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Page 127
P R O C E E D I N G S
(Continued Proceedings)
THE VIDEOGRAPHER: The time is 5:06. We're
back on the record.
BY MR. SWEETAPPLE:
Q. In the Gulf Stream Patriot, which is an
exhibit, it talks about "We encourage you to visit us
online at www.gulfstreampatriot.com."
Are you part of the "we" that is set forth in
this?
A. No.
Q. So this was published without your -- without
your permission or with your permission?
A. I didn't give permission; I didn't withhold
permission.
Q. You did see it before it was published.
A. Yes.
Q. And when you saw it, it said in it that
"Mr. O'Boyle and Mr. O'Hare, two men with a desire to
end the disputes and return peace to the town."
And then it also said "Mr. O'Boyle and
Mr. O'Hare have both demonstrated a strong desire to
resolve the matters at hand and return Gulf Stream to
the quiet town it once was." Do you see that?
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A. Yes.
Q. Did Mr. O'Boyle have permission to say that
about you?
A. I didn't give permission or withhold
permission.
Q. You read that. Did you object to that when
you saw that?
A. I didn't have a problem with what he was
writing. It is his right to make free speech. He can
say whatever he wants.
Q. Do you have a strong desire to resolve the
matters at hand and return Gulf Stream to the quiet town
it once was?
A. Absolutely.
Q. But you want to get attorney's fees for filing
public records requests, right?
A. That would be up to a judge.
Q. Well, so then you don't want to settle; you
want to litigate public records requests to see if you
can get attorney's fees, right?
A. Absolutely not. As a matter of fact, in
public commission meetings, I said to the town, these
things could have gone away for just peanuts. For the
filing fee and the minimum amount, just to get the
record, instead of being turned into some giant 20,000
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or $30,000 fiasco. All they had to do was give me the
record and pay the filing fee.
Q. Are you aware of --
A. As a matter of fact, that was an offer I made
that they didn't act on.
Q. What's the offer you made?
A. I remember making an offer to them, giving
them seven or ten days, saying, give me the filing fee
and give me the record, and we'll dismiss this one.
Let's get the ball rolling.
Q. This one?
A. It was just -- well, one at a time. Yeah.
That was the first one.
Q. And are you aware whether or not the O'Boyle
Law Firm has been making written demands and filing fee
affidavits for fees in cases throughout the state that
were never, never incurred?
A. Just what I've read in the Coastal Star.
Q. Have you -- so you were represented by the
O'Boyle Law Firm in these cases.
A. These cases?
Q. In a number of these cases, public records
requests, you were represented by the O'Boyle Law Firm.
MR. HANNA: I'm going to object to the form of
the question. It's mischaracterizing that he had
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some type of -- the previous question.
BY MR. SWEETAPPLE:
Q. Let me -- you were represented by the O'Boyle
Law Firm, correct?
A. In my cases against the Town of Gulf Stream.
Q. Have you ever become aware that -- whether or
not the O'Boyle Law Firm, and attorneys in the O'Boyle
Law Firm, have been making demands for attorney's fees
of defendants in public records requests for fees that
were not earned?
or --
MR. HANNA: Are you talking about in his cases
THE WITNESS: No.
MR. HANNA: -- or other people's cases?
BY MR. SWEETAPPLE:
Q. In any cases. Yours or other people's cases.
A. No. I don't think that is true.
Q. You're unaware of that. You don't believe
that's happened.
A. I'm unaware of it, and it seems completely out
of character.
Q. Out of character for the O'Boyles?
A. To ask for money they didn't earn? Yes.
Q. Did Mr. Chandler ever talk to you about a
windfall scheme to use public records requests to make
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demand for attorney's fees that weren't incurred to hold
people up when you sued them?
A. Windfall? You mean like oil company windfall?
Q. Yeah. Like file a complaint that is in a form
and tell the defendant that if you pay $4,750, they will
dismiss the case.
A. You know, I've heard some people have
strategies where they would ask for money to not file a
case, but I think that's completely unethical. I would
never do that or condone anybody doing that.
Q. Were you ever aware of the O'Boyle Law Firm
filing a lawsuit and asking for thousands of dollars in
fees, when there had been no attorney's fees incurred or
minimal attorney's fees incurred?
A. No. I never heard anything like that.
Q. And have you -- strike that.
You never talked to Mr. Chandler about that
technique?
A. Technique? No.
Q. And about that being done in any public
records requests throughout the state by --
A. Asking for fees that were not earned?
Q. Right.
A. No.
Q. So your goal -- your goal right now is to get
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attorney's fees from Gulf Stream for the public records
request cases that you filed, right?
A. My singular goal? One of my goals? What are
you asking me?
Q. That is one of your goals?
A. No. I'm sorry. Ask it again.
Q. One of your goals -- one of your goals right
now -- when you talk about wanting to settle, one of
your goals is you want the Town of Gulf Stream to pay
attorney's fees for public records requests you filed?
A. I am seeking remedy in the court. The judge
is going to decide -- I would like to be made whole
again. I would like to have the record. Who knows what
is going to happen. But that's my goal.
Q. Are there any records right now that you
believe you haven't been given that you are entitled to?
A. I've got a number of complaints I filed and
others that I haven't filed, but I could. But there's a
lot of issues.
Q. Did you hear my question?
A. You asked me if I didn't get a particular
record I'm entitled to?
Q. Are there any records you've asked for that
you now presently believe you haven't received?
A. Are there any records I've asked for that I
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haven't received?
Q. Uh -huh.
A. Plenty.
Q. That you still haven't received?
A. Plenty. Thirteen months later.
Q. Well, you still don't have them.
A. Still don't have them. Or a response from the
town.
Q. And you filed lawsuits over those?
A. Not all of them, no. There's only so much I
could do.
Q. And do you ever represent yourself pro se?
A. I don't know if I've ever done that or not.
Q. Have you ever filed a lawsuit pro se and then
said you had assistance of counsel?
A. Yeah. I've done that.
Q. And you have done that recently?
A. You know, what do you mean "recently "?
Q. Within the last three months.
A. I don't think so.
Q. What cases have you represented yourself
pro se with the assistance of counsel?
A. Initially when I filed my complaint, I thought
I could handle that; but as soon as I got a couple of
transmissions from Mr. Randolph, I realized I was way
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out of my league and sought the assistance of counsel.
Q. So let's start with 9/29/2013, which was a day
that you filed 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12,
13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26,
27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39,
40 -- 41 public records requests. Do you remember that
day?
A. No.
Q. How long would it take you to file 41 public
records requests in one day?
A. 41, maybe 30 seconds each, so maybe 22
minutes.
Q. Thirty seconds --
A. If I was fast on my fingers.
Q. How did you decide what public records you
wanted on that day?
A. I didn't decide that day.
Q. When did you decide?
A. I probably worked on that list for weeks. I
just happened to file them all that day.
Q. How much time did you spend working on the
list?
A. I didn't work on a list. I would work on a
record, and another one would occur to me. If I had a
theme, there was an article I wanted to write about,
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there would be multiple requests about that.
Maybe there was some other reason. There
might be a few records requests about that and -- but it
never made a list.
Q. So why would you file 41 public records
requests in one day?
A. Well, I happened to have time at the computer.
I think it might have been a Sunday. I'm not sure what
day of the week it was. But that would have been my
habit to compose them as I had the time, and thought of
the record I wanted, and then just sat down and sent
them all out. Just like I would go to the library and
check out a bunch of books at one time, even though I
wasn't going to read them all at once.
Q. And did you ever consider how long it would
take the clerk to respond to the 41 requests that you
filed on September 29, 2013?
A. I never thought it would take a year.
Q. Did you ever think how long will it take?
A. I thought it would take a reasonable amount of
time.
Q. Did you always ask for a specific identified
document, or did you often ask for documents that would
take research to locate?
A. That's a very good question, Bob. Sometimes I
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knew a document would exist, and I would be as specific
as possible. Sometimes I had an idea a document would
exist, and I tried to describe the area where that
document might be.
And other times I would be told by the town,
or I would hear something at a town meeting, and I
wanted that document, but I wasn't quite sure what
document that document was. So I tried to frame my
question the way I thought would get what they were
talking about at the town meeting. So I couldn't always
be sure what I was asking for, but I knew it was there,
and I was throwing my -- I was reaching out to try to
find that document. You don't always know what
government records are there until you start asking.
Q. So you want them to go look through all their
records to find something in a topic that you mentioned,
right?
A. Well, I wanted to follow the law.
Q. And do you think that the law allows you just
to name some topic, and then the government has to go
look for every record that possibly mentions that word
or that topic? Is that reasonable?
A. I think that's exactly what the law says.
Q. You think it's reasonable when you make a
public records requests just to say, I want every letter
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that has Joe's name it, any letter that says Joe in it,
that's reasonable.
A. Joe who?
Q. Just Joe. I want you, Clerk, give me any
record that has the name "Joe" in it. And that is what
the law allows?
A. If I was at a commission meeting and
Commissioner Ganger said, well, I got something from
Joe. And he doesn't like this, but I might ask for all
the records with the name Joe in it. Yeah.
Q. And you think that is a legitimate public
record request, and the town has to go through and look
at every record it has, thousands, if not hundreds of
thousands of records, and find every document that has
the name Joe in it. And they don't give you every name
has Joe in it, you can sue them and get fees. That's
what you think?
A. If I ask for a record, an e -mail, with the
word "Joe" in it, I'm not an IT person, but I know you
go in a search function. You put in Joe. They all pop
up. You download it. Takes five minutes. And send it
off to Mr. O'Hare. How troublesome is that?
Q. That takes --
A. If it's not easy, then they say, we'll do it.
It's going to cost you a bunch of money. Are you
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willing to pay it? And then I can decide, is it worth
it to me to pay that much to get it.
Q. So you think it's just a matter of doing an
e -mail search for these documents that could be found
immediately.
A. If I'm asking for an e -mail that has whatever
the word is, maybe the word "complaint" or the word
"trespass" or some -- whatever issue I was looking for
because I happened to see something in a public meeting
or whatever, I think, yes, you put the word "trespass,"
and all the e -mails come up with that word in it.
Q. So you think -- the 41 e -mails that took you
30 second each to send out, how long do you think it
would take the clerk reasonably to respond to those 41
e- mails?
MR. HANNA: Object to form;
mischaracterization.
MR. ROEDER: Form.
THE WITNESS: Again, it didn't take me 31
seconds to make the request.
BY MR. SWEETAPPLE:
Q. Thirty seconds each to send them.
A. Yes. To send them. So how long to respond?
Q. How long do you think it would take the clerk
to respond to those, do you think?
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A. I think, not knowing exactly what requests are
on there, I would say less than 15 minutes each.
Because it depends what I was asking for.
Q. Did you ever ask the clerk how long it took
her to respond to your request?
A. The clerk usually volunteered that. I didn't
have to.
Q. What did the clerk tell you?
A. Depends on the period of time. The responses
seem to change and morph. Initially, we'll get back to
you in three days or thereabouts. Then they would start
sending formal estimates where the police chief might
say, well, I took 10 minutes, and I found these records,
and it's going to take 45 minutes to produce them.
Which doesn't make any sense to me, because if you found
them in 10 minutes, why does it take 45 minutes?
Regardless, that is how I would communicate with them.
I never asked them how long is it going to take you.
Q. Did the clerk ever complain to you that this
was burdensome and time consuming?
A. To me personally? I wouldn't call it a
complaint. Rita Taylor is very professional. She would
give me an e -mail that basically says this is what it's
going to take. It wasn't a complaint.
Q. She never said to you that you're filing far
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too many public records requests, and it's taking too
much of my time?
A. I recall a blockade - styled letter that said
you haven't paid for our estimates; therefore, we're not
going to process your requests anymore.
Q. Did Rita Taylor or anyone at the Town of Gulf
Stream ever tell you that your conduct was completely
unreasonable, and that they could not possibly comply
with the number of requests you were filing?
A. I don't recall ever having that conversation.
Q. Do you know the Digital Record? What is
Digital Record; do you know?
A. That would be a record that if I was inside
the computer would be composed of zeros and ones.
Q. So did you ever file a request under the name
Digital Record?
A. I'm sorry. I thought you were asking me if I
knew what a digital record was.
Q. No. Did you ever file a request under the
name Digital Record?
A. I think it might be Digital.Record.G -mail.
Something like that.
Q. Right. Did you ever do that?
A. Yeah. That sounds like one of mine.
Q. Okay. So what about Record.public@yahoo?
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A. That sounds like one of mine.
Q. So on 9/20 -- on 9/12, Mr. Roeder, on behalf
of you, filed two requests, and then Mr. Chandler on the
18th files five requests. And then you on September
20th filed 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13,
14, 15, 16, 17, 18, 19, 20, 21, 22 using
Record.public @yahoo.com.
A. That is probably true.
Q. And what about Archive Inquiry? Is that a
name you used?
A. I don't recognize that one.
Q. And what about mail to PineGD @G- mail.com.
That is you, right?
A. Say it again.
Q. Mail to PineGD. Is that Pineapple Grove?
A. I have an e -mail address that is PineGD. I
don't know about the "mail to."
Q. At G- mail.com?
A. Yes.
Q. Is that you?
A. Yes. That is me.
Q. So then what about Archive Inquiry? Is that
you?
A. I don't think that is me.
Q. So on September 23, three days after all of
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the Yahoo --
A. I'm sorry. To clarify, if I had an
opportunity to see what the record was, that Archive
Inquiry, I would probably recognize the record request.
But I don't recognize that name.
Q. That would have been -- let's just deal with
the ones that you presently recall. Are you, on
September 23, 2013, the "mail to PineGD @Pineapple
Grove "?
A. That's me.
Q. On that day, on 9/23/2013, you, under that
name, filed 1, 2,3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13,
14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27,
28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41,
42, 43, 44, 45, 46 public records requests. Are you
aware of that?
A. What is the sender name?
Q. Mail to PineGD @G- mail.com.
A. That must be a typo. It is PineGD @Gmail.com,
and, yes, I probably sent those. But what does that
have to with disqualification? I don't think there's
any claims on those.
Q. Were you aware when I appeared in this case
and you moved to disqualify me, that I was going to be
alleging in a complaint that your conduct was an abuse
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of process, and that you were abusing the Public Records
Act in order to extort other relief from the Town of
Gulf Stream?
A. Was that the RICO claim you're talking about?
Q. No. Abuse of process. Were you aware that I
was going to bring a counterclaim -- I intended, based
on my research, to bring a counterclaim against you for
abusing process based on your use of the Public Records
Act, in order to extort other benefits from the Town of
Gulf Stream? Were you aware that that was the scope of
my representation with regard to this case, based on my
investigation?
A. I --
Q. Did you have any idea of that?
A. I don't know if I can testify to that without
violating the confidential agreement.
Q. Well, you know now -- you know now, seeing the
counterclaim that I filed against you in this case --
A. The RICO?
Q. No, in this case, the counterclaim that I
filed.
A. Yes.
Q. For declaratory judgment, that I'm asking the
court to conclude that your conduct is an abuse of
process, right?
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1 A. I've seen that counterclaim.
2 Q. That is part of the scope of my
3 representation. You understand that, right?
4 A. Okay.
5 Q. I have never been involved in any case with
6 you that involves your involvement in any abuse of
7 process by filing public records requests, have I?
8 A. My initial answer would be no, but I'm not
9 sure what you mean by "case." You mean filing with the
10 court?
11 Q. Or making public records requests just to
12 extort relief from the court -- from the defendant
13 filing hundreds and hundreds of public records requests
14 in order to pound and abuse and extort Gulf Stream to
15 doing what you want them to do.
16 MR. ROEDER: Objection to form;
17 Mischaracterization.
18 THE WITNESS: I'm sorry.
19 BY MR. SWEETAPPLE:
20 Q. Have you ever been involved --
21 A. I don't know anybody doing that.
22 Q. Let me rephrase.
23 When you say I represented you in 1998, or my
24
firm
represented
you, were
you involved in
any conduct
25
where
you filed
hundreds of
public records
requests
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working with
Page 145
1
against
anyone?
2
A.
No.
3
Q.
Or where you filed 40 and 50 public records
4
requests
within an hour to a community?
5
A.
No.
6
Q.
That's something that you've only started
7
doing in
conjunction with Mr. Roeder and Mr. Chandler,
8
right?
9
A.
No.
10
Q.
You didn't do that before you met Mr. Roeder
11
and Mr.
Chandler, did you? You didn't file multiple
12
serial public
records requests until you met Mr. Roeder
13
and Mr.
Chandler, right?
14
MR. HANNA: Object to form.
15
MR. ROEDER: Objection.
16
BY MR. SWEETAPPLE:
17
Q.
After you met them, right? So before you met
18
them, you
went in and you asked for public records, and
19
they were
given to you very nicely, right?
20
A.
Where?
21
Q.
In Ocean Ridge.
22
A.
Ocean Ridge is very cooperative.
23
Q.
After you met Mr. Chandler, you started
24
working with
Mr. Chandler
and
Mr.
Roeder; Mr.
Roeder,
25
you, and Mr.
Chandler set
out
to
make multiple
robocall
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public record requests in order to cripple the Town of
Gulf Stream, right?
MR. HANNA: Objection. Do not answer.
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. And then right after you filed 40- something
requests on 9/23, Mr. Chandler filed a request the next
day; and then the 26th you filed another request; and
then on the 27th, Archive Inquiry, which happens to be
you, filed five more requests, right?
A. I don't know about Archive Inquiry. If I
could look at the documents you're talking about, I
might know better.
Q. When I take your depositions in all of the
cases you filed, I will be showing you all of the public
records requests that you have been involved in filing.
MR. ROEDER: You have the record here now? We
don't need to go on a --
MR. SWEETAPPLE: I don't have it now. I'm
going to ask him in his depo. He's asking for it
now. I'll show it to him when I take his
deposition in the 12 cases he filed.
BY MR. SWEETAPPLE:
Q. And on October 7th, under Digital Records, you
filed 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11 public records
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requests, didn't you?
A. What year is that?
Q. 2013.
A. I didn't commit the date to memory, but I'm
assuming it is correct.
Q. On the next day under Digital Record name, you
submitted 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14,
15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28,
29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42,
43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56,
57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70,
71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84,
85, 86, 87, 88, 89, 90 public records requests to Bill
Thrasher at the Town of Gulf Stream, didn't you, sir?
A. I'm sorry. I don't think you caught all those
numbers. Are you sure that's the right number?
Q. Ninety.
A. Because I heard you go from 80s to 90.
Q. Let's do it again. Let's do it again.
A. Also, could you give me the name. I don't
remember the name.
Q. Digital Record. Do you remember October 8 --
A. No.
Q. -- 2013? Was there something special about
October 8, 2013?
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85, 86, 87, 88, 89 -- 89 requests sent to Bill Thrasher
by you. 84 were by Digital Record, and 1, 2, 3, 4, 5
were in your name. Are you aware of that?
A. What does that mean "in my name ?"
Q. Chris O'Hare was the submitter as opposed to
Digital Record.
MR. HANNA: I'm going to object to form. We
have no idea what you're referring to. You don't
have the documents with you. You have a list that
was created by you.
BY MR. SWEETAPPLE:
Q. Are you aware, sir, that on September -- on
October 8th, that you filed over 80 public records
requests to Bill Thrasher using Digital Record as an
address?
A. No. I didn't commit the dates to memory.
Q. Why would you ever send over 80 public records
requests in one day to the town manager of Gulf Stream,
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A.
I
can't
think
of
anything.
Q.
1,
2,
3,
4, 5,
6,
7,
8, 9,
10,
11,
12,
13,
14,
15, 16,
17,
18,
19,
20,
21,
22,
23,
24,
25,
26,
27,
28,
29, 30,
31,
32,
33,
34,
35,
36,
37,
38,
39,
40,
41,
42,
43, 44,
45,
46,
47,
48,
49,
50,
51,
52,
53,
54,
55,
56,
57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70,
71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84,
85, 86, 87, 88, 89 -- 89 requests sent to Bill Thrasher
by you. 84 were by Digital Record, and 1, 2, 3, 4, 5
were in your name. Are you aware of that?
A. What does that mean "in my name ?"
Q. Chris O'Hare was the submitter as opposed to
Digital Record.
MR. HANNA: I'm going to object to form. We
have no idea what you're referring to. You don't
have the documents with you. You have a list that
was created by you.
BY MR. SWEETAPPLE:
Q. Are you aware, sir, that on September -- on
October 8th, that you filed over 80 public records
requests to Bill Thrasher using Digital Record as an
address?
A. No. I didn't commit the dates to memory.
Q. Why would you ever send over 80 public records
requests in one day to the town manager of Gulf Stream,
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A. Because I had the time to do it.
Q. And you have told numerous people that you do
not like Mr. Thrasher, right?
A. No. I don't think he is doing his job.
Q. And you've told people you don't like
Mr. Thrasher, right?
A. Personally, I don't care about him.
Q. And you told people you want to get rid of
him, right?
A. I think the town would be better served by
another town manager.
Q. And you've advocated him being fired, right?
A. I think the town would be better served.
Q. You have advocated that. You have told people
you think the town would be better served by him being
fired.
MR. HANNA: Object to form.
THE WITNESS: I don't understand the word
"advocate."
BY MR. SWEETAPPLE:
Q. You stated publicly on numerous occasions you
would like to see Bill Thrasher fired.
A. I think the town would be better served by
another town manager.
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Q. You stated that publicly, haven't you?
A. I spoke at a commission meeting, and I said
the town would be better served with another town
manager.
Q. You've said more than that; you said
Mr. Thrasher is incompetent, right?
A. I think he is.
Q. And you've said a number of nasty things about
Mr. Thrasher, haven't you, over the years?
MR. ROEDER: Object to form.
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. You said a number of derogatory things about
Mr. Thrasher on your website and publicly over the
years, haven't you?
A. As I've gotten more public records, I'm
changing that opinion. Now I'm thinking he is pretty
much doing what the town tells him to do, whereas before
I thought he was calling the shots.
Q. So you think he is evil and corrupt, right?
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. You think he's corrupt.
A. No. Not the definition of corrupt that the
state uses.
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Q. How would you describe his conduct?
A. Corrupt means taking money under the table, I
think.
Q. There are other types of corruption. You
think that --
A. In that case, maybe he is corrupt.
Q. You think he is breaking the law all the time,
right?
A. I think so. Definitely.
Q. And you have told people he should be fired,
right, because he is breaking the law?
A. I've told people that he is definitely doing
things that are not legal and -- if I can finish my
answer -- that the town would be better served with
another town manager.
Q. And you served over 80 public records requests
on him personally as part of your goal to get him fired,
right?
A. All my record requests were served to
Mr. Thrasher. For some reason, that's the way Rita
likes it.
Q. All of them were served to Mr. Thrasher?
A. I believe. 99 percent are going to be
BThrasher @gulfstream.com. And somehow Rita reads that
account -- I'm sorry, Ms. Taylor.
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Pagc 152
Q. And has anybody ever told you to serve
Mr. Thrasher with public records requests because he's
the clerk of the town?
A. I seem to recall in Rita's deposition, she
testified to that.
I'm not sure how that started. Yeah. I
e- mailed Mr. Thrasher. Rita somehow responds to it.
And, actually, Rita -- Rita writes a lot of letters for
him, as I understand it.
Q. And then three days later on the 11th, you
served Mr. Thrasher with 1, 2, 3, 4, 5, 6, 7, 8, 9 10,
11, 12 public records requests. And on the 15th,
Mr. Jonathan O'Boyle -- who is Asset Inventory, by the
way?
A. That is one of mine.
Q. So on the 15th, you --
A. That is an old one.
Q. On the 15th of October 2013, you served one
for Asset Inventory; and your lawyer, Jonathan O'Boyle,
at the same time, files 1, 2, 3, 4, 5, 6, 7, 8, 9, 10,
11 --
MR. ROEDER: Objection. Not proven that he
was acting as his lawyer at the time.
MR. SWEETAPPLE: The man who is your lawyer,
Jonathan O'Boyle, in numerous matters --
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Page 153
MR. ROEDER: Objection.
MR. SWEETAPPLE: Are you conducting -- why
don't you have your co- counsel, who is handling
this deposition --
MR. HANNA: I'm waiting for you to finish the
question.
BY MR. SWEETAPPLE:
Q. Okay. Let me rephrase it.
On the 15th, are you aware that you filed a
request under the name Asset Inventory, and then you
also filed one, two -- two under your own name; and on
that same day, at or about the same time, Jonathan
O'Boyle filed one, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10
requests.
A. No. I was not aware of that.
Q. And on the 23rd of October, you filed in your
name 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15,
16, 17, 18, 19, 20, 21, 22, 20 -- 20. Let me start over
again.
1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14,
15 requests.
A. What is your question?
Q. Are you aware that you did that; that you
filed 15 requests on October 23?
A. I didn't memorize the dates. I'm not aware of
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1 what you're referring to. If you show me the documents,
2 I'll be happy to comment.
3 Q. The next day you filed more requests. You
4 filed -- there were times when you filed requests every
5 day of the week, multiple requests. Are you aware of
6 that?
7 MR. HANNA: Object to the form.
8 THE WITNESS: Am I aware that I filed
9 requests?
10 BY MR. SWEETAPPLE:
11 Q. Every day of the week, multiple requests every
12 day of the week.
13 A. Which week?
14 Q. Are you aware of that?
15 A. Which week?
16 Q. Are you aware of ever doing that, where you
17 spent every day of the week filing multiple requests to
18 Bill Thrasher?
19 A. I have not committed to memory when I make my
20 requests.
21 Q. But you have a log of all this, right?
22 A. I have the log that is at the town's website,
23 and I have copies of my own requests, and the responses
24 when I get them.
25 Q. And on October 29th, you filed -- this is
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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2013 -- 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12 requests.
And then the next day you filed two requests.
And then on the 31st, the next day, you filed two
requests.
And then on the 1st you filed two more
requests.
And then on the second you filed 1, 2, 3, 4, 5
requests.
And then the 3rd you file two requests.
And then the 5th you file two requests.
On the 8th you file two requests.
On the 9th you file 1, 2, 3, 4, 5, 6, 7, 8, 9,
10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21 requests.
On the 10th of November, after that, you turn
around and file 1, 2, 3, 4,5, 6, 7, 8, 9 requests. Are
you aware of that?
MR. HANNA: Object to form.
THE WITNESS: Again, I didn't commit the dates
to memory.
BY MR. SWEETAPPLE:
Q. On the 11th, sir, you turn around and file 1,
2, 3 requests. The next day you file three more
requests.
The next day you file a request. After the
weekend on the 16th you file 1, 2, 3, 4, 5, 6 requests.
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Page 156
You're filing hundreds and hundreds of
requests in sequence along with Martin O'Boyle, Jonathan
O'Boyle, Citizens Awareness Foundation, Martin O'Boyle,
Citizens Awareness, Stop Dirty Government, Chris O'Hare;
dozens and dozens by all of you throughout February and
March and April of 2014, and you think that the Town of
Gulf Stream has not made reasonable effort to comply
with your requests?
MR. HANNA: Object to the form.
THE WITNESS: Is that a question?
BY MR. SWEETAPPLE:
Q. Yeah. You think the Town of Gulf Stream has
not made reasonable efforts to comply with your requests
in light of your conduct?
A. Sometimes they do.
Q. What do you think would happen if even ten
people in Gulf Stream behaved the way you do at the
clerk's office? What you do think would happen with the
Town of Gulf Stream?
A. I can imagine exactly what would happen.
Q. Would the clerk's office have to close?
A. I think the town would take some of that
$4 million they found for RICO and perhaps hire a few
more people to get a real record department like other
towns.
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Q. So you're doing this to make the town get a
real record department?
MR. HANNA: Object to form.
THE WITNESS: Absolutely not. Doing this to
obtain records.
BY MR. SWEETAPPLE:
Q. This is all done just to obtain records.
A. Is that a question?
Q. Yes. You want the jury to believe that this
conduct on your part is done in a good faith effort to
obtain records that you need and want.
MR. HANNA: Objection. What jury? We have a
motion to disqualify that's in front of the judge.
MR. SWEETAPPLE: This transcript will be used
in various jury trials.
MR. HANNA: So you are going beyond the motion
to disqualify here? The intent of this, we have an
updated deposition for the motion to disqualify.
MR. SWEETAPPLE: This case that this
deposition --
MR. HANNA: Are you going to ask questions
about any of the documents that we've provided to
you regarding the Daytimers, the other notes that
Mr. O'Hare has regarding your representation --
MR. SWEETAPPLE: Yes, I am.
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MR. HANNA: In 1997, 1998, 1998, 1999, 2005,
2006, and 2007?
MR. SWEETAPPLE: Yes, I am going to.
MR. HANNA: Move on to those.
MR. SWEETAPPLE: I don't have to do that.
This is a deposition that's noticed in this case --
MR. HANNA: I'm giving you an updated
deposition for the motion to disqualify. That's
what it was updated -- that is what the purpose of
the deposition was for, and that's what we agreed
to appear for.
MR. SWEETAPPLE: I'm asking him about this
case as well, which is the scope of my
representation. Okay. I have a pending.
MR. ROEDER: Are you willing to stipulate you
have more of a scope of representation than just a
public records request?
MR. SWEETAPPLE: Mr. Roeder, I have filed a
counterclaim and a motion for leave for a
counterclaim in this case. I have asked for a jury
trial to determine the issues in the declaratory
judgment. This transcript is being taken in this
case. It can be used in front of the jury, even
though it was the motion to disqualify.
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BY MR. SWEETAPPLE:
Q. So I'll ask the question again. Do you expect
the jury to believe that you are filing all of these
public records requests because you want these records,
and that's the only reason?
A. I expect to have a day in court. The facts
will all be known, and I pray that the judge and the
jury will see the reasonableness of all this.
Q. Do you know of anybody, anyone in the state of
Florida, who has done anything remotely like this?
A. Like what?
Q. Like filing almost a thousand public records
requests, 50 and 60 a day, day after day, barraging the
city manager with so many public records requests he
can't even see straight?
A. That's not what I did.
MR. HANNA: Object to form.
MR. ROEDER: Object to the form.
BY MR. SWEETAPPLE:
Q. Are you aware of anyone else, aside from the
O'Boyles, who undertook to do it as a living in an
alleged law firm, who have filed anywhere near the
public records requests that you have filed?
MR. HANNA: Object to the form.
MR. ROEDER: Object.
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MR. HANNA: Again, you're getting into --
Mr. O'Hare has nothing to do with the operation of
the O'Boyle Law Firm. And your questions keep
insinuating that somehow he is involved in that or
trying to make money off these public records
request cases.
MR. SWEETAPPLE: The O'Boyle Law firm, I
suggest, is working for him for free to compensate
him for his co- conspirator conduct. And I guess
we'll find that out as we take discovery.
We'll see if he has contingency agreements
when I move the court to compel, because the fact
is, Mr. Hanna, all those privileges you asserted
don't exist under the law. And you know it.
MR. HANNA: I'm quite confident I know you're
putting a show on.
MR. SWEETAPPLE: No, you don't know.
MR. HANNA: You are, Bob. Come on.
MR. SWEETAPPLE: Payment of fees is not a
privileged communication.
MR. ROEDER: If you're not going to ask
questions about the documents we provided, we need
to end this now.
BY MR. SWEETAPPLE:
Q. So you now know -- you now know the scope of
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my representation in the case that is pending before
Judge Blanc, because I have filed a motion for leave to
file an amended answer of affirmative defenses and
counterclaim, right?
A. I don't know what you're talking about.
Q. Have you had a chance to review, in this case
that you filed to disqualify me in, before I ever filed
a pleading -- are you aware that I have now filed a
motion for leave to file?
A. I'm aware of that.
Q. Are you aware that in an O'Boyle case before
Judge Blanc, I filed a similar motion and a similar
counterclaim?
A. I wasn't aware of that.
Q. Are you aware that Judge Blanc last week
ordered that I have leave to file a counterclaim to sue
you, the O'Boyle Law Firm, Jonathan O'Boyle, Martin
O'Boyle, William Ring and others?
A. Well, I'm sure whatever Judge Blanc ruled is
reasonable, but I'm not aware of that.
Q. You were not made aware that that ruling was
entered last week and that you were being served with a
counterclaim similar to --
A. I know I was served, but I'm not sure what
ruling you're talking about.
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Q. Are you aware that I moved for leave to file a
counterclaim in a Martin O'Boyle case that named you as
a counter - defendant?
A. Oh, I'm sorry. Yes. I knew that I was named
in some other counterclaim.
Q. Are you aware that I filed, in -this case that
you have moved to disqualify me, a similar counterclaim?
A. Yes. I'm aware of that.
Q. Did you read that counterclaim?
A. Yes. But I did not commit it to memory.
Q. But you know now or have some idea of the
scope of my representation in this case, right?
A. Oh, definitely. It's RICO. All over the
place.
Q. The case that I have filed seeks specifically
relief. Do you know what that relief is as you sit
here?
A. I'm sorry. The damages you're seeking?
Q. No. It doesn't seek damages at this time. It
seeks relief from the court.
A. I don't remember the relief you're seeking.
Q. Okay. Do you know if any of the relief I'm
seeking in this case has any relationship -- strike
that.
Do you know what the relief is I'm seeking in
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this case?
A. I don't remember it.
Q. Do you know any of it?
A. Do I know any of what?
Q. The relief I'm seeking in this case.
A. No. I read the claim.
MR. HANNA: Are you talking about the motion
to amend that hasn't been granted yet, so that
really --
MR. SWEETAPPLE: In this case.
MR. HANNA: -- is not at issue yet. Once you
get your motion to amend granted.
MR. ROEDER: It hasn't been granted yet,
Counsel.
MR. SWEETAPPLE: First of all, you've made a
representation in your motion as to what the scope
of my representation is before I filed anything,
which was pure speculation.
Now we have a motion that has been granted in
the O'Boyle case that shows what my scope is with
regard to --
MR. HANNA: Pure speculation.
MR. ROEDER: You've made the threats in a
private meeting.
MR. SWEETAPPLE: And we're --
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MR. ROEDER: That you won't let us bring out.
If you are going to make accusations, let's bring
it out.
MR. SWEETAPPLE: First of all, whatever we
discussed in a mediation in an attempt to settle
claims that I intended to bring is confidential.
Okay.
MR. ROEDER: Don't imply he's never been made
aware of it. You asked him has he ever been made
aware of any claims.
BY MR. SWEETAPPLE:
Q. What I want to know is, you've seen the scope
of my representation. You've seen that I brought -- I
sued you in an O'Boyle case and made you a
counter - defendant. You see that I'm bringing the same
claims, attempting to bring them in this case.
Are you aware of the claims that I have
brought against you in the O'Boyle case?
A. I believe it is a mirror image of what you've
done in my case.
Q. Or similar.
A. Very similar.
Q. Can you tell me what is the scope of my
representation of Gulf Stream that you object to? What
claims am I bringing that you think I'm precluded from
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bringing because of what I did for you in 1998,
according to you?
MR. HANNA: Object to the form; asked and
answered.
THE WITNESS: Yeah. The way you're phrasing
that is difficult for me to answer.
BY MR. HANNA:
Q. Well, you've told the court, and your lawyers
have told the court, that the representation of Gulf
Stream in this case is substantially related to what I
did for you 17 years ago.
A. Yes.
Q. In Ocean Ridge. That is what your motion
says.
A. Yes.
Q. Tell me what claims I am bringing that are
substantially related to the claims that I represented
you on in Gulf Stream.
What claims am I bringing against you on
behalf of Gulf Stream that are substantially related to
claims you say I represented you on in Ocean Ridge 17
years ago?
MR. HANNA: I'm going to object to form;
mischaracterization. Gulf Stream is also -- he is
also bringing claims against Gulf Stream for 1983
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Page 166
in a federal lawsuit for retaliation, which is
substantially what the allegations were regarding
all the conduct in Ocean Ridge.
THE WITNESS: You want to parrot that?
MR. SWEETAPPLE: That was a speaking
objection, and I plan on moving for sanctions on
it.
BY MR. SWEETAPPLE:
Q. But tell me what you think substantially
related in the claims that I brought against you, are
substantially related to anything that you say I handled
for you previously.
A. Bob, all the conversations we've had that were
privileged, and the representation you gave me where the
town was basically violating my civil rights, was
cooking up fake code violations, similar to what
Mr. Thrasher did. The advice you gave me on zoning
issues on permit issues. And now I see the very same
thing happening now. I don't understand where there is
any confusion about similarities.
Q. So the law requires that my representation of
this case would somehow have to negatively impact my
previous representation of you.
Is there anything that I'm doing in this case
that is going to affect the fact that your code
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violation in Ocean Ridge was settled?
A. I don't see any impact from your actions now
on previous actions with Ocean Ridge.
Q. Are you aware that that is a requirement under
the law to determine that there is a substantial
relationship; that under the case law, I cannot
undertake representation against a former client where
my current conduct would in any way impact the prior
result. That's the standard. Did anybody ever tell you
that before you filed this motion?
A. You're asking me for a legal opinion?
Q. I want to know --
MR. HANNA: Objection.
BY MR. SWEETAPPLE:
Q. Let me do it this way.
A. You're very clever. I don't know that.
Q. Is there anything that I'm doing now with
regard to representing Gulf Stream that is going to
impact in any way your permit issues regarding -- what
issues, what permit issues, were you talking about from
1998?
A. I'm sorry. Is this a different question?
Q. Yeah. You've said that you had zoning issues
in Ocean Ridge, okay. That is what your motion talks
about. Your motion doesn't talk about anything in 2006.
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It doesn't talk about anything in Gulf Stream.
A. Well, 2006 was the -- I discovered new
records, which we produced for you as soon as we
discovered them. And that one of those records I
produced was about a permit issue in Gulf Stream in 2005
or '6.
Q. For a -- permit for what?
A. I had been issued a permit, and Mr. Thrasher
came out and said, this can't be. Take it out. I
showed him the permit plan, and he said he didn't care.
Take it out. Not allowed.
I explained to him the same condition was
allowed to happen at the mayor's house and at other
houses. I gave him the addresses. He said he didn't
care. Take it out. And it was in regard to that.
Q. And did you take it out?
A. Yes. On your advice.
Q. So you say you called me about a permit in
2005 or 2006.
A. We spoke about it, and basically it was a cost
benefit analysis; it was going to be more money to fight
than it was to remove it.
Q. So you didn't hire me because it would cost
too much.
A. I'm sorry?
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Page 169
Q.
It would cost too much to fight it.
A.
I didn't fight it. I took it out.
Q.
So you didn't hire me to fight it?
A.
When you say did I specifically have an
engagement
letter with you....
Q.
You didn't give me money to fight that; you
decided it
would cost too much.
A.
No. I didn't pay you money.
Q.
What's the other permit issue?
A.
Permit issue. It was a zoning issue.
Q.
What's the zoning issue.
A.
The three -plus acres that we purchased around
that time.
I think it was 1999. We were going for
permission
to build the buildings we wanted to build.
And the City
of Boynton is very specific on use, not
just the structure
itself. And the issue was could we
have our use
and light industrial, and they were
insisting
it had to be heavy industrial. And finally we
prevailed,
and we were allowed to occupy the property.
Q.
Did I represent you anywhere?
A.
Just advice.
Q.
So you called me?
A.
We spoke.
Q.
And did I send you an engagement letter or get
a fee?
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23 personal knowledge of a lot of things that I don't want
24 the other counsel knowing, or being used against me, and
25 that's why we're here.
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Page 170
1
A.
No. I believe it was same arrangement you had
2
with Emille Dansue (phonetic).
3
Q.
You just called me and --
4
A.
Just called.
5
Q.
-- I nicely told you what I thought.
6
A.
Yeah. I appreciate that.
7
Q.
Okay.
8
A.
Just very --
9
Q.
So that was in --
10
A.
-- easy to work with at the time.
11
Q.
That was in Boynton Beach?
12
A.
That was in Boynton.
13
Q.
So is there anything that I'm doing for Gulf
14
Stream that's going to affect your zoning in Boynton
15
Beach?
16
A.
Well, I just found the records. I was told
17
look for
any records that had Sweetapple's name on them.
18
And I found
the records, and now they refresh my memory.
19
And I'm telling you, as far as whether it
20
impacts
Gulf Stream, I'm not a legal expert. I can't
21
give you
an opinion on that. All I know -- if I can
22
finish speaking -- is you represented us. You have
23 personal knowledge of a lot of things that I don't want
24 the other counsel knowing, or being used against me, and
25 that's why we're here.
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Page 171
Q. Mr. O'Hare, I've already made it clear to your
counsel that I'm going to be moving for fees, because I
believe your motion is a total sham under the law.
A. Sure. I understand that.
Q. The standard is that my representation in this
matter would have to have an adverse impact on a result
I obtained for you in some prior matter.
And so I'm going to ask you these questions
again very carefully. Is there anything that I'm doing
on behalf of Gulf Stream that is going to impact your
1998 case involving some zoning violation involving an
apartment building?
A. Well, I appreciate you explaining why you're
asking what you're asking; and I appreciate that you
might have a different opinion of the law. I have my
opinion. It's not a learned opinion; it's just my
opinion.
But I don't see any effect on those previous
whatever reason, I don't see any of that stuff taking a
left turn. It is done, completed. All we're talking
about now is how am I impacted by your representing the
town against me.
Q. So my current representation is going to have
no effect on the 1998 zoning matter, right?
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Page 172
A. I don't believe that.
Q. It's not -- correct?
A. Correct.
Q. And it's not going to have any adverse effect
on the zoning in Boynton Beach, right?
A. No.
Q. And it's not going to have any effect on your
decision in 2005 not to fight over your garage door,
right?
A. Garage door.
Q. What was it that you said? What was that
permit issue?
A. It was for a brick new wall that was put on
the seawall.
Q. There's nothing that I'm doing now for Gulf
Stream that is going to affect your decision in 2005,
right?
A. I no longer have the house, so no.
Q. I'm going to mark as - what's the next
exhibit?
THE COURT REPORTER: F.
(Defendant's Exhibit F was marked for
identification.)
BY MR. SWEETAPPLE:
Q. Did you receive the defendant, Town of Gulf
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Stream's, response to plaintiff's verified motion to
disqualify defense counsel?
A. I'm sorry. That was a big mouthful. Let me
look. You're asking if I received this document?
Q. Yes. Did you receive Exhibit F?
A. Exhibit F?
Q. Yes. That's what I filed in response to your
motion to disqualify me because I represented you
allegedly in 1998.
A. Okay. Yes. I did receive this.
Q. Did you read it?
A. Yes.
Q. Did you see the case law that was cited in the
motion?
A. I read the document.
Q. Am I doing anything now that attacks the work
product that I performed in the past, according to you?
A. Attacks the work product?
Q. What I did for you in the past, trying to undo
what I did in the past, according to you.
A. No.
Q. Are you aware that the courts have defined
"substantially related" to mean, specifically, matters
are substantially -- related for purposes of this rule
if they involve the same transaction or legal dispute,
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Page 174
or if the current matter would involve a lawyer
attacking work that the lawyer performed for the former
client."
And that's from the comments to the rule. Are
you aware of that?
A. I read the document.
Q. Let talk about -- so you concede that my -- my
claim, on behalf of my client, that you're acting with
unclean hands, and that you're acting in a conspiracy
with others to inundate the town with thousands of
public records requests, that has nothing to do with
anything that happened in 1998 or 2006, right?
A. I disagree with that completely.
Q. What does that have to do with 1998 or 2006?
A. I'm not acting with unclean hands, whatever
that means.
Q. I'm saying my claim, the fact that I'm
alleging that, has nothing to do with anything that
happened in 1998 or 2006, right?
A. You know, when I read that, I questioned
whether some of that might have been tailored based on
your knowledge of my "hot buttons," if I could use that
term.
Q.
What
are
hot buttons?
A.
You
know,
ways to bait people or get them to
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Page 175
react unfavorably. You know, hot buttons. Like, you
know, somebody has a short temper, so you poke them in
the chest and run like hell.
Q. Do you have a short temper?
A. I'm not going to talk about me or my medical
conditions, but I'm saying that it seemed like I
recognize things in there at the time that looked like
you had a good knowledge of me and my reactions to
things, and maybe that is how you tailored your
counterclaim.
Q. Give me some examples of that. Here's the
counterclaim. Give me some examples.
A. We're going to be here for me to read through
this.
MR. HANNA: Let's take a quick break.
MR. SWEETAPPLE: Sure. I told you we're going
to be here until 9:00.
THE VIDEOGRAPHER: The time is 6:02. We're
going off the record.
(At 6:02 p.m. a recess was taken.)
THE VIDEOGRAPHER: The time is 6:09. We're
back on the record.
BY MR. SWEETAPPLE:
Q. Mr. O'Hare, I realize it's late. I won't hold
you to this. Is there anything you read previously or
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Page 176
you've read in the short time you looked at that, that
is information that you believe I have obtained from you
in 1998 or anytime previously? Any of those allegations
about your conduct?
A. Well, no. My point was -- and I admit I read
up to page 15 and had sufficient -- I didn't have to --
had sufficient evidence. I didn't have to go further to
make my point. My point is, there's language in here
purely selected and used because you know that it would
effect me different than it might affect someone else.
Q. The language I used in pleading would affect
you differently. Okay.
A. Yes. I would be happy to --
Q. I don't need you to elaborate on that. It is
unnecessary.
A. Per your permission, I outlined it. But if
you don't want me to go there....
Q. The allegations in the pleading are
allegations of fact, of what has occurred?
A. Exactly.
Q. Your emotional reaction to those is of no
concern to me. I'm concerned in proving a case. This
is not a psychological profile of you. Everyone reacts
differently to allegations and complaints. That is your
subjective right.
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Page 177
A. I disagree with you.
Q. We'll each have our chance to present this to
Judge Blanc rather soon.
What I want to know, is there any information,
any facts in that complaint, that relate to anything you
previously told me or disclosed to me?
A. Well, as a matter of fact, I didn't cite any
facts. They're actually nonfacts. They're just
outright not true. But the words you used and things
you chose are the things that, to me, feel like you're
using information that you previously obtained to --
Q. Give me an example of what you're talking
about.
A. I'll be happy to now.
Q. Yes. It is so silly, I want to hear what
you're thinking.
A. Well, I don't want to introduce into the
record that very information that I am trying to
disqualify you for, so you don't share it with Jones
Foster and these other people, or used against me, but I
can tell you the passage.
On page 12 it starts, the purpose of
disguising their involvement, the word "conspirators,
scheme, ill- conceived requests." On page 13. Avoid
special service charges. Used fictitious or fraudulent
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Page 178
personal identification.
That's the extent of it. There are things
there that you and I should -- well, you share the
knowledge of me that I believe prompted you to use those
particular phrase or words. And I don't want to go into
what those things are because of the privilege and
knowledge -- privilege characteristic of them.
Q. So you think I used those terms in describing
your conduct in the Gulf Stream case because of
something I know about you?
A. Well, to answer your question, I think someone
who wanted to appear more evenhanded and statesmanlike
would have been more accurately -- would have been more
accurate and not as inflammatory in the language.
I think that the language there in stating
things that are known not to be true was meant to
capitalize on your information about me.
Q. So you think I'm alleging that you're involved
in a conspiracy with -- you're involved with a
conspiracy with Mr. Chandler and Mr. Roeder and the
O'Boyles and the O'Boyle Law Firm, where you were trying
to file hundreds and hundreds and hundreds of serial
requests against Gulf Stream, and you think that those
allegations shouldn't have been made --
MR. HANNA: Object to form.
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Page 179
BY MR. SWEETAPPLE:
Q. -- by me as the attorney for Gulf Stream?
MR. HANNA: Object to form.
THE WITNESS: Well, if it was written by
Clarence Darrow, it would be a lot different than
this. This is very inflammatory and meant to, I
think, push those buttons that I referred to
earlier.
BY MR. SWEETAPPLE:
Q. Is there anything else in there -- is there
any facts in this case that I've alleged that relate to
any facts in 2006 or 1998?
A. Any facts that relate to 1998?
Q. Any facts that are alleged in here, any of the
events or facts that even exist in 2006 or 1998.
A. I don't mean to be difficult, but the word
"facts" and "relate," I don't see any facts there that
would relate to 1998. But the word relation, I have a
hard time answering that because I'm not sure what the
definition of the word you're using in your question.
Or how you're intending to use them.
Q. Are you aware that Joanne O'Connor drafted the
allegations on page 12 regarding disguising their
involvement, ill- conceived requests, requests were
obscure and purely harassing?
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Page 180
Are you aware that Joanne O'Connor drafted
that language?
A. I'm sorry?
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. Are you aware that Joanne O'Connor drafted
that language, not me?
MR. HANNA: Object to form.
THE WITNESS: I have no idea how you split up
your workload.
BY MR. SWEETAPPLE:
Q. So you just presumed I prepared this?
A. Should I not assume that you edited that or
had any involvement at all in that?
Q. You think that people are picking words in the
pleading that are designed to make you mad -- is that
what you're saying? Or push your hot buttons?
A. That's what I testified to; push my hot
buttons. I didn't say make me mad.
Q. And you wouldn't expect when a lawyer pleads
that a conspiracy is occurring, that the words would be
inflammatory?
A. I would hope they would be truthful.
Q. Well, I think that's what we're going to have
a jury decide.
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Page 181
A. Right. This is a deposition. So can we move
on?
Q. So I've pled -- we've pled unclean hands, and
that there are bogus not - for - profits and alter egos and
fictitious names; and it's an enterprise to inundate the
town with thousands of public records requests. So that
has nothing to do with anything in 2008, right?
A. I just said it does.
Q. It does have -- what does this have to do with
2008? Is there anything you told me in 2008 that deals
with these facts?
A. Those aren't facts.
Q. With these allegations. Do these allegations
relate to anything that happened in 2000 -- in 1998?
A. The way they're written, I believe they do.
Q. So your full -- your whole objection to me
representing Gulf Stream is that I -- I write things,
I'm writing things in a way to get you upset?
MR. HANNA: Object to form.
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. Then what's the basis for your objection?
A. Well, it goes much more than that.
Q. What is it?
A. You have personal knowledge. You have
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Page 182
represented me and my wife. You know things about us.
You're now in a position where those things can be very
helpful to the town and unfairly disadvantage me.
Q. And what is the nature of these things that I
know about? Your wife isn't even sure she met with me,
so...
A. I'm not sure your definition of the word
"nature."
Q. Are you saying financial affairs; I know
something about your financial affairs? I know -- what
is the nature? What is the nature of this area that I
know about that you believe is giving me some unfair
advantage?
A. I would like to give you a specific answer.
Give me a specific question, please.
Q. What is the nature of, or the area of,
knowledge that you say I have about you that you believe
gives me an unfair advantage when I don't even remember
you?
MR. HANNA: I'm going to object and instruct
the witness to refrain from answering anything that
would divulge any kind of privilege you have with
Mr. Sweetapple but also with Heath King, regarding
your therapist and therapy that you had after
the -- involving the Ocean Ridge incident.
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Q. Was I ever present for any therapy with you
and Mr. King?
A. No.
Q. Do you have any information that I've ever
talked to Mr. King about you, Dr. King?
A. Yes.
Q. And what basis do you believe I talked to
Dr. King about you?
A. My memory.
Q. What do you remember?
A. That would be privileged.
Q. Your memory, or you're saying something I
said?
A. The items you're asking me to disclose, I
consider privileged.
Q. Okay. So you're moving to disqualify me, but
you're not going to testify as to what it is you believe
that I know that somehow is related, or that somehow
gives me an unfair advantage. So you're going to make a
motion, but you're not going to give the testimony or
the nature of it.
A. I struggled with how that might play out, how
I could communicate to the court without further
jeopardizing myself. And I'm still not sure how that is
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going to work, but...
Q. Are you --
A. I'm hoping -- if I could finish -- I'm hoping
Judge Blanc is certainly more knowledgeable than me in
those affairs, and he might be able to suggest a way.
Q. Are you aware that in 30 years of referring
people or recommending people, friends, family, clients,
strangers that I just meet to go to Heath King, that I
have never, ever asked Heath King to be a witness for me
in any case?
MR. HANNA: Object to form.
MR. SWEETAPPLE: Are you aware of that?
MR. HANNA: Council is testifying.
THE WITNESS: I'm not aware of that.
BY MR. SWEETAPPLE:
Q. Are you going to actually lie and say that I
sent you to Heath King for the purpose of having him
testify in a case?
A. See, this goes back to what I was talking
about with that pleading. You're asking me if I'm going
to lie?
Q. Are you going to lie? Are you saying that
somehow I told you to go to Heath King so that he would
be a witness in a case? Because if so, I will call
Dr. King in and establish that I've sent -- recommended
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over a hundred people to him, and I've never once, nor
would I ever ask him to be a witness in a case.
MR. HANNA: Object to the form.
MR. SWEETAPPLE: I refer people to him to try
to talk privately with him about their issues and
concerns.
MR. HANNA: Object to fprm.
BY MR. SWEETAPPLE:
Q. Rather than to talk to me about their issues
and concerns.
MR. HANNA: Object to form. Counsel's
testifying.
BY MR. SWEETAPPLE:
Q. Is it your position that you went to Heath
King as part of some lawsuit?
A. Okay. I'll try to answer your questions, the
multiple questions.
Q. Let me ask you this question. Is it your
position that you went to Heath King --
MR. HANNA: Again, let him finish.
THE WITNESS: You don't want me to answer the
question.
MR. HANNA: I'm advising you, be careful about
disclosing any kind of privileged communication you
had with Mr. Sweetapple or with Dr. King, or Heath
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King.
THE WITNESS: He is asking me, I believe --
I'm sorry. I'll answer the question.
BY MR. SWEETAPPLE:
Q. Is it your understanding that you were going
to Heath King for purposes of him testifying in some
case?
A. No.
Q. Okay.
A. And to answer the other part of your question,
no, I would not lie.
Q. So was there any time that you ever heard me
talk to Dr. King about you?
A. I'm sorry?
Q. Was there ever any time where I was present
and you were present, even on the phone or in person,
where I talked to Dr. King while you were there?
A. I can't go there. That's privileged.
Q. Did that happen ever? Not what was said. Did
it ever happen where you and me and Dr. King were in the
same room?
A. No.
Q. Did it ever happen we're on the same phone
call?
A. No.
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Q. Did you -- did I ever tell you that I had
spoken to Dr. King?
MR. HANNA: Okay. Again, you're getting into
privilege here.
THE WITNESS: I think that is privileged.
BY MR. SWEETAPPLE:
Q. So you're not going to offer any testimony on
that?
MR. HANNA: You're getting into a position
where you're forcing your former client to divulge
communications he had with you or with his
physician.
MR. SWEETAPPLE: If you're telling me you're
not going to be testifying about that at the
hearing --
MR. HANNA: I'm not --
MR. SWEETAPPLE: You're invoking the
privilege. It can't be a sword and a shield. I
will move on.
MR. HANNA: I understand that.
MR. SWEETAPPLE: You've invoked the privilege.
MR. HANNA: You are also putting your client
in a position where he has to divulge these
communications.
MR. SWEETAPPLE: No. No. You've put your
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client in a position where there is no substantial
relationship, and now you're trying a nonsense
fallback argument that I'm also trying to pierce
and you're also --
MR. ROEDER: Is there a question?
MR. SWEETAPPLE: -- trying to invoke the
privilege, and you can't invoke the privilege and
then hide behind the shield.
MR. ROEDER: Sir, ask the question and stop
pontificating.
THE WITNESS: Oh, just to clarify. They
didn't tell me to invoke the privilege there. I
just know that I cannot, on the record, tell you
what I discussed with you and what I discussed with
Mr. King, or Dr. King.
BY MR. SWEETAPPLE:
Q. And you have no intention of doing that at the
trial, or the hearing in this case?
A. I'm hoping that Judge Blanc will give me some
opportunity to communicate to the court without
further -- causing the damage that I suspect has already
been caused.
Q. So you have no intention of telling the court
anything that you said to Dr. King; and you have no
intention of telling the court anything you and I
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discussed. But you want the court to conclude that I
know something about you that gives me an advantage.
A. I never said that.
Q. Do you believe there's something I know about
you that is private that gives me an advantage in this
litigation?
A. Yes.
Q. Okay. And is it something psychological,
financial? What is the nature of it?
A. Again, definition of nature. I don't know
what it is you're asking me.
Q. Is there some kind of -- you're saying I have
some knowledge about your psyche that other people don't
have that gives me an advantage?
A. I'm not going to characterize it any further.
Q. Are you saying I have some knowledge about
your finances that gives me some advantage?
A. It has nothing to do with finances.
Q. Does it have to do with your temperament or
your medical condition or something?
A. I'm sorry. Is this like 21 questions?
Q. Well, I have to respond to your complaint that
you filed, okay. Your motion. And your motion doesn't
set any of this out. So I'm trying to find out, since I
pretty much have -- I believe established there is no
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substantial relationship between what I'm doing now and
what happened 17 years ago. Now I'm trying to figure
out if there's some other ground that you are asserting
for disqualifying me, and I'm clueless. Okay. So I
guess I'll just move on.
MR. ROEDER: Finally.
BY MR. SWEETAPPLE:
Q. Because you're invoking the privilege as to
anything you discussed with Dr. King, which I
understand; and you're invoking the privilege as to
anything you discussed with me, so you're not allowing
me to inquire into that.
A. Well --
Q. So I guess I'll move on. And I guess you'll
have a private conversation with Judge Blanc that I
won't be a party to, and you will ask him to do whatever
it is you want him to do.
A. If I can answer that, which I think is a
question. I'm hoping that Judge Blanc has an answer
that maybe in camera, or how the process works, and it
will be up to Judge Blanc to decide.
Q. So you think --
A. I'm not going to ask Judge Blanc not to
disclose anything to you.
Q. So you're going to ask for an in camera
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Page 191
hearing?
A. If that's the phrase. I'm not sure.
Q. Before Judge Blanc?
A. I'm not sure that's the proper phrase. And
pardon me if I use these legal terms that I'm not
completely familiar with. That is my intention, that
the judge will find some way to resolve this particular
issue we have.
Q. And you can't tell me what the issue is or the
nature of the issue.
A. I think we've already covered that.
Q. What is it?
A. That there is information that you have that I
think would be very damaging to me that I do not want
the town to have. If you haven't told them yet, I
appreciate that, but I don't know.
Q. I have no idea what you're talking about. So
can you tell me generally what type of information this
is?
A.
Not
more than what I've already
said.
Q.
Is it
medical information?
A.
Not
more than what I've already
said.
Q.
You're
not going to answer is it
medical
information?
You said it's not financial.
Is it
medical?
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Page 192
A. Not more than what I've already said.
Q. Is it psychological?
A. Bob, I know this is your technique, but I've
said all I can say on that.
Q. I'm trying to defend a motion, and you
basically said nothing. Obviously, when I file my
motion for summary judgment and sanctions, I'll point
out that there's been no answer --
MR. HANNA: Just ask a question.
MR. ROEDER: You said you were going to move
on and ask questions. Please do.
BY MR. SWEETAPPLE:
Q. Let's go to some of these exhibits.
This is an October 9, 2006 Daytimer. It is
stapled to some drawings. Is this drawing related to
the Daytimer?
A. Those are independent records. And that
drawing is related to the permit issue, in addition to
the brick wall that was the issue of that conservatory.
Q. Was this -- this knowledge that you say I have
about you, when was this obtained? What year?
A. I became aware of it in 1999.
Q. You became aware of it. And I became aware of
it in 1999?
A. Towards the end of 198, and then corresponds
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to the last visit I had with Dr. King.
Q. And what year was that?
A. 1999.
Q. So the last time you saw Dr. King was 1999?
A. Yeah. It is right there.
Q. So the knowledge I have, that you say I have
about you, I got in 1999?
A. Yes.
Q. Must have been real radical.
MR. HANNA: Ask a question and not
editorialize.
BY MR. SWEETAPPLE:
Q. This is so ridiculous. Can I have the next
Exhibit?
(Defendant's Exhibit No. G was marked for
identification.)
BY MR. SWEETAPPLE:
Q. So I take it with regard to what I've marked
as Exhibit G, which is your October 2006 Daytimer, that
when it says "Sweetapple," it is a Post It that you put
on it after you found -- after you found this record.
A. I put the Post -It on it for the purpose of
making -- finding the record on the page more quicker.
A little arrow Roy on the Post -It.
Q. That's a recent --
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A. The little Post -It is recent. I don't know
why it has been --
Q. It says here, Thrasher rejects conservatory.
Says new structure doesn't --
A. Would you like me to read it?
Q. Would you read that to me, please.
A. The Post -It is pointing to an entry on October
11th that says, Thrasher rejects conservatory. Says new
structure. Doesn't care about old screen. Sweetapple
says build it anyway. Exclamation point.
Q. " Sweetapple says build it anyway."
MR. HANNA: What year is that?
THE WITNESS: 2006, I believe.
BY MR. SWEETAPPLE:
Q. Okay. And this is written in pencil.
A. I don't know.
Q. And do you have this original page?
A. The lawyers have it.
Q. So you can produce this so it can be examined
forensically?
MR. HANNA: Yes.
MR. SWEETAPPLE: I'm going to want that.
BY MR. SWEETAPPLE:
Q. And it looks like you've written in
different -- that is the only pencil written on that
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Page 195
page, correct? Everything else is written in ink.
A. No. This looks like pencil as well. The
notation that says "Kirk Bowden 8284338392," and other
note on here that says "tarp on roof."
Looks like a sharper pencil, but when you
examine all the books, whenever that happens, you'll see
there's probably half a dozen pens and pencils used,
whatever was convenient at the time I•was making the
record.
Q. You called me in October 9, 2006, you believe,
about building something, and I said "build it anyway."
A. I believe it would be October 26th. Probably
not that date, because my habit is to just open up the
book. If I need to make a note for future reference, I
might have written it on a date other than when it
actually happened.
Q. This isn't part of your motion anyway. Okay.
So we have that as G.
You don't have anything about 2006 in your
motion. You have a 1998.
A. It is just a production of a record I
uncovered.
Q. I understand. And then the next thing is a
drawing of something.
A. That is a sketch of a conservatory that was
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Page 196
supplied to the Town of Gulf Stream and rejected because
Mr. Thrasher maintained that my screen enclosure that
had been destroyed in Hurricane Wilma was somehow not
attached to the house and, therefore, the replacement
screen was not attached and, therefore, it was a
separate structure, and it was going to have to go
through all sorts of approval processes.
Q. And I told you you should build it anyway;
just put it in.
A. When I talked to you about the details of
that, you said replace your screen. Put it in.
Q. Okay. Quick phone call. Didn't bill you?
A. I don't think it was very long a phone call.
I don't even know it was a phone call. But, yeah, we
communicated, obviously.
Q. How? A phone call?
A. I don't remember.
Q. Okay. And then the next one is December 17.
Where is anything that has to do with me?
A. If I might examine, I'll explain. I produced
this record because I didn't know whether it was
something you would be interested in or not. Basically
this is the quotation from the Brazilian fellows who
build the brick wall, and it shows the value of $3,000
for their labor for that portion. Because the record,
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Page 197
later on, that we decided it was a cost benefit
analysis, that record would have factored into that
other record. So I supplied it not knowing if it was
any value to you or not.
Q. This is how much you paid for that?
A. It was -- it was 3,000 for the brick labor in
the back. It all came to $10,000.
Q. You never discussed that with me?
A. Just the --
Q. The cost or --
A. It just supports -- I don't know if the proper
word is foundation, but it supports the calculation
later.
Q. There is a note here. Sweetapple note. Cost.
Cost benefit analysis, 5,000. Sweetapple to fight.
4,450 to remove.
And so I basically told you, you shouldn't get
involved in this.
A. I think I came to that conclusion myself. But
the idea was that the money I had into it was less than
the money it was going to cost to fight it. Was it
really worth it to me, and I reached the decision it
wasn't.
MR. HANNA: What is the date on that one?
THE WITNESS: That was December 29 of 2006.
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Page 198
Q. So you reached -- you did the math yourself
and reached that decision.
A. Yeah. But it has a reference here that 5,000
to Sweetapple. So for some reason I thought it was
going to cost 5,000 to have you go after Mr. Thrasher,
and I decided not to.
Q. Do you know if you had a conversation with me
at that time?
A. I don't know why I would have that number
otherwise. I believe I did have that correspondence
with you.
Q. You don't have any recollection of it?
A. I remember speaking, but I can't tell you if
it was over the phone, whether I ran into you at
Panera's, or whatever was the place we would go. I
don't know.
Q. There was no Panera's then.
A. That's what I'm saying. Whatever the place
was. I don't remember. I just remember you said get
serious. You don't have a whole bunch -- you didn't --
you didn't have a whole bunch of years left, but you
said don't waste your time on this. Something to that
effect.
Q. All right. There's a copy of your permit.
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This is your drawings. Anything else?
A. That's the brick -- the document you're
looking at now, which I'm not sure if you gave it an
exhibit number, that's the brick new wall on the seawall
that Mr. Thrasher permitted, and then said get it out.
Q. Okay. So you said "Sweetapple to call town
manager."
A. There was a Post -It on that, which when you
get the record you'll see the Post -It. That's what I
had on there.
Q. And do you know if you ever spoke to me about
calling the town manager on this?
A. My memory is hazy on that. I believe I did.
Q. So you don't have any specific recollection of
a conversation?
A. I don't know if it was phone, but I have this
idea that -- yeah, I think I remember that we had that
discussion. It was all part of the previous record as
well for the $5,000.
Q. But you never paid me $5,000 and never hired
me to do anything.
A. No. At the time you were giving me the same
service you were giving Emille Dansue (phonetic).
Q. Emille was a friend and the mayor, and you're
saying I was doing it for free.
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Dansue?
A. I don't know if it was at the time. I don't
know.
Q. I think I was representing him in 191, 192.
A. Yeah.
Q. Years before this. Probably five years before
this.
A. The reason I mentioned it is because in my
mind that was the rationale for --
Q. I was being a nice guy. You called and I
said -- and that was it.
A. Yeah. It was good advice. I appreciate the
advice you gave me.
Q. Okay.
A. You're a fine lawyer, and I benefited greatly
by your help.
Q. So let's see if there's anything else that has
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Pugc 200
A.
He was
also the father
of one of my
attorneys,
Charlotte.
That
is how I adopted
my children.
And we
had conversations
about the Dansues
and...
Q.
I don't
remember that.
Okay.
A.
We had
conversations --
well, okay.
Q.
So you
were represented
-- you know
Charlotte?
A.
Yes.
Q.
And at
the time, was I
representing
Mayor
Dansue?
A. I don't know if it was at the time. I don't
know.
Q. I think I was representing him in 191, 192.
A. Yeah.
Q. Years before this. Probably five years before
this.
A. The reason I mentioned it is because in my
mind that was the rationale for --
Q. I was being a nice guy. You called and I
said -- and that was it.
A. Yeah. It was good advice. I appreciate the
advice you gave me.
Q. Okay.
A. You're a fine lawyer, and I benefited greatly
by your help.
Q. So let's see if there's anything else that has
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Page 201
my name on it in stick -em's.
This is -- I'm looking at January. I'm not
going to mark -- I guess I'll mark this because -- I'll
make this a composite.
I'll make this H, because it the Stickum with
my name and December 31, 2006. This is H.
(Defendant's Exhibit No. H was marked for
identification.)
BY MR. SWEETAPPLE:
Q. And then E is what you provided. It was E to
your motion, but I'm going to make it G for the
deposition. It says "CFO 1999."
A. The purpose of producing that document was
just to show you the cover page of the entire datebook
that was pulled out of a binder.
Q. And then it looks like this is January of that
year, right? It says Heath King.
A. That Post -It was added after the fact to help
identify where the record was on the page.
Q. So Heath King down here.
A. Right.
Q. And Heath King, on the 12th of January. Any
other reason this is given to me? 12:30 also. Oh,
12:30 time. Is that the time?
A. Yes.
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Q. So you met with Heath in January. Okay. Then
"Heath- cancel," it says.
A. I can't read it from here.
That says "Heath, cancel 2/1 at 8:30 a.m. So
this record states that on February 1st, at the line
that represents 8:30, there's a notation that has
"Heath- cancel."
Q.
So you canceled the appointment with Heath.
A.
These are records I thought you would want
that just
shows the visits I had with Heath King.
Q.
How many times did you see Heath King?
A.
It was for perhaps a six, seven -month period.
Q.
How many times did you see him?
A.
Once a month, maybe twice a month sometimes.
Q.
So a total of seven times, eight times?
A.
Well, no. It was twice a month. I don't
know. You do the math. The record is right there.
Q.
This is all your meetings with him.
A.
Every meeting would be documented.
Q.
So you only saw him in 1999.
A.
I think we started in '98. Not sure.
Q.
December of '98?
A.
It would be under the '98 datebook.
Q.
Okay. And you met with him for like an hour
every time?
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Page 203
A. I think it was 50 minutes maybe.
Q. Okay.
A. Paid for an hour.
Q. So all of this is meetings with Heath.
A. I don't know. You'd have to look through
every page.
Q. Heath. Heath. Heath King.. In March. Heath
King in April 4/7. Heath King 4/15. Then it says
Sweetapple with a Stickum on April 19, I guess 1999.
What is this Stickum with my name on it?
A. Again, the Post -It with your name and arrow is
just for the sake of convenience to see where the record
was written on the date.
Q. What does it say?
A. The record is on the 20th, and it's basically
in the middle. It doesn't look like it is attributed to
any particular time. It says Boynton zoning issue,
W /land use, which means "with land use." Talked to
Sweetapple. Zoning director. City manager, question
mark, question mark.
So I had written in my book to talk to you. I
hadn't -- this isn't memorialized. This is me making a
note to call you.
Q. Should I call or question mark.
A. Yes. Well, no. There is no question mark
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Page 204
next to you. Next to the zoning director there is a
question mark and next to the city manager there is a
question mark. In other words, that was the issues I
was going to discuss with you.
Q. Did you call me on this day?
A. I don't have a recollection of that. I just
came across the notation.
Q. Okay. And then the next one is Heath.
A. I'm sorry?
Q. The next one is Heath.
A. That's what it says. Yes.
Q. Another meeting with Heath King. That was the
last meeting you had, April?
A. I think this notation to call you. Is that
the last document?
Q. Call Sweetapple about Heath.
A. Okay.
Q. Is that there?
A. Yeah. This is -- yeah. This is April 23,
1999. The notation I wrote was, called Sweetapple about
Heath.
On April 22nd, there's notation at 3:45 with
Heath's name on it, so that was a meeting, the very last
meeting I had with Heath King. And then I had notation
the next day to call you about Heath.
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Q.
Page 205
Q.
And did you?
A.
Yes, I did.
Q.
Okay. So that was in 1999.
A.
Yes.
Q.
And do you recall that conversation?
A.
Yes.
Q.
How long did it take?
A.
Just a few moments. A few minutes.
Q.
And where were you when you called me?
A.
I don't remember that.
Q.
Where was I?
A.
I don't know that either. The other end of
the line.
Q.
Q.
Was anybody else
present?
A.
No.
Q.
Do you recall what
you said?
A.
Yes.
Q.
And do you recall
what I said?
A.
Oh, yes.
Q.
Okay. And you're
not going to tell me,
obviously.
Or you're going
to tell
A.
Leave that up to
Judge Blanc.
Q.
Okay.
MR. SWEETAPPLE: I think that what I'll do is
suspend your deposition, and I'll ask the court for
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Page 206
guidance on that, because it is pretty hard for me
to prepare for a hearing and defend myself, when
you're going to make your case privately, I guess,
at some later date to the judge and not put any
allegations in a motion and not give me any general
information that I can verify by asking someone
else. So I'll suspend, and we'll take it up the
confidential matters that you have raised and the
other issues in this depo and the last depo.
And I will order it.
CROSS (CHRISTOPHER O'HARE)
BY MR. HANNA:
Q. I just -- when were you referred to Heath
King?
A. Sometime in '98; the end of '98.
Q. When you were referred to Heath King, who
referred you to Heath King?
A. You're going to lose your microphone.
That would be Mr. Bob Sweetapple.
Q. And did you have discussions with him about
your personal life before he referred you?
A. Yes.
Q. The incident -- or the 2006 conservatory, what
did that issue involve with the Town of Gulf Stream?
What was the -- how did the issue come up with the
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Page 207
conservatory? Was it something with the hurricane?
A. Hurricane Wilma destroyed part of the house,
the screen enclosure. I made a sketch for what Shelly
and I wanted to replace it with, another screen
enclosure with a slightly different shape, same
footprint. I took the sketch in to Mr. Thrasher, who
rejected it based on what I thought was unreasonable
information.
Q. Okay.
A. Interpretation of the code.
Q. And that was to replace the structure that had
been destroyed by the hurricane?
A. Mr. Thrasher contended that the structure did
not -- it was a separate structure independent of the
house, and it was to replace the structure that had been
torn up by the hurricane.
Q. And you talked to Mr. Sweetapple about that
issue?
A. Yes.
Q. What time -- when did you talk to him about
it? Before you applied for the permit or you dealt with
Mr. Thrasher at Gulf Stream?
A. No. I talked to him when Mr. Thrasher came
down with the decision I thought was unreasonable.
Q. What did you do after you talked to
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Page 208
Mr. Sweetapple?
A. Hired a contractor to put it up.
Q. Did you put that up?
A. Yes.
Q. And has anything happened regarding the
conservatory?
A. No. As a matter of fact, I believe -- well, I
can't say. Nothing else happened.
Q. And the actions that you took, was that based
on the conversation you had with Mr. Sweetapple?
A. Oh, yes.
MR. HANNA: I just need to look at two things.
I thought we were going to go until
9:00 o'clock.
MR. SWEETAPPLE: It's only a quarter to seven,
but I have suspended, so I didn't want to go
through....
MR. HANNA: I just want to get some stuff on
the record.
MR. SWEETAPPLE: Obviously I have questions
about the specific public records requests in this
case, but I'm --
done.
MR. HANNA: I just wanted to get a few things
MR. SWEETAPPLE: But that's until we actually
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Page 209
move beyond this hearing. I guess I'm going to
have a lot of questions about public records.
MR. HANNA: Here we go.
MR. SWEETAPPLE: Which is what these cases are
about.
THE WITNESS: This case is about getting the
records. It is open and shut. If the record
exists, I asked for it. I don't have it.
MR. SWEETAPPLE: That's what you think. It is
about --
THE WITNESS: I'm spending all this money.
MR. SWEETAPPLE: -- it is about abuse by a
group of people. That's totally unacceptable in a
civilized society.
BY MR. HANNA:
Q. When did you move from Harbor Drive in Ocean
Ridge?
A. Ninety -- maybe '93, 194.
Q. Where did you move to?
A. Gulf Stream.
MR. HANNA: I don't have anything further at
this point pending the --
MR. SWEETAPPLE: I'll take a copy.
THE VIDEOGRAPHER: The time is 6:48. This
marks the end of the deposition.
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THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
Page 211
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
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 212
: mDo -140 �QIWVEMWD
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.
�� .. I A 1
Debra Duran - Bornstein, RPR, CLR
Notary Public - State of Florida
My Commission Expires: 8/20/15
My Commission No.: EE 112218
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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March 4, 2015
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:
CC: All Counsel
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 213
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Page 214
C E R T I F I C A T E
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I hereby certify that I have read the
foregoing deposition by me given, and that the
statements contained herein are true and correct to the
best of my knowledge and belief, with the exception of
any corrections or notations made on the errata sheet,
if one was executed.
Dated this day of
2014.
CHRISTOPHER O'HARE
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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Page 215
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:
SIGNATURE OF DEPONENT:
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
$10,000 197:7
$3,000 196:24
$30,000 129:1
$4 156:23
$4,750 131:5
$5,000 199:19,20
1
1 134:3 141:5
142:12 146:25
147:7 148:2,9
152:11,20 153:13,
17,20 155:1,7,12,
15,21,25
10 134:3 139:13,16
141:5 142:12
146:25 147:7
148:2 152:11,20
153:13,17,20
155:1,13
10th 155:14
11 134:3 141:5
142:12 146:25
147:7 148:2
152:12,21 153:17,
20 155:1,13
11th 152:10155:21
194:8
12 134:3 141:5
142:12 146:22
147:7 148:2
152:12 153:17,20
155:1,13 177:22
179:23
12:30 201:23,24
12th 201:22
13 134:4 141:5
142:12 147:7
148:2 153:17,20
155:13 177:24
14 134:4141:6
142:13 147:7
148:2 153:17,20
155:13
15 134:4 139:2
141:6 142:13
147:8 148:3
153:17,21,24
155:13 176:6
15th 152:12,16,18
153:9
16 134:4 141:6
142:13 147:8
148:3 153:18
155:13
16th 155:25
17 134:4 141:6
142:13 147:8
148:3 153:18
155:13 165:11,21
190:2 196:18
18 134:4 141:6
142:13 147:8
148:3 153:18
155:13
18th 141:4
19 134:4 141:6
142:13 147:8
148:3 153:18
155:13 203:9
1983 165:25
1997 158:1
1998 144:23 165:1
167:21 171:11,25
173:9 174:12,14,19
176:3 179:12,13,
15,18 181:14
195:20
1999 158:1 169:13
192:22,24 193:3,4,
7 201:12 202:20
203:9 204:20
205:3
1st 202:5
2
2 134:3 141:5
146:25 147:7
148:2,9 152:11,20
153:13,17,20
155:1,7,12,15,22,
25
2,3 142:12
2/1 202:4
20 134:4 141:6
142:13 147:8
148:3 153:18
155:13
20,000 128:25
2000 181:14
2005 158:1 168:5,
19 172:8,16
2006 158:2 167:25
168:2,19 174:12,
14,19 179:12,15
192:14 193:19
194:13 195:10,19
197:25 201:6
206:23
2007 158:2
2008 181:7,10
2013 135:17142:8
147:3,24,25 152:18
155:1
2014 156:6
20th 141:5 203:15
21 134:4 141:6
142:13 147:8
148:3 153:18
155:13 189:21
22 134:4,11 141:6
142:13 147:8
148:3 153:18
22nd 204:22
23 134:4 141:25
142:8,13 147:8
148:3 153:24
204:19
23rd 153:16
24 134:4 142:13
147:8 148:3
25 134:4142:13
147:8 148:3
26 134:4 142:13
147:8 148:3
26th 146:8195:12
27 134:5 142:13
147:8 148:3
27th 146:9
28 134:5 142:14
147:8 148:3
29 134:5 135:17
142:14 147:9
148:4 197:25
29th 154:25
3
3 134:3 141:5
146:25 147:7
148:2,9 152:11,20
153:13,17,20
155:1,7,12,15,22,
25
3,000 197:6
30 134:5,11 138:13
142:14 147:9
148:4 184:6
31 134:5 138:19
142:14 147:9
148:4 201:6
31st 155:3
32 134:5142:14
147:9 148:4
33 134:5 142:14
147:9 148:4
34 134:5 142:14
147:9 148:4
35 134:5 142:14
147:9 148:4
36 134:5 142:14
147:9 148:4
37 134:5 142:14
147:9 148:4
38 134:5 142:14
147:9 148:4
39 134:5 142:14
147:9 148:4
3:45 204:22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: $10,000-5
3rd 155:9
4
4 134:3 141:5
142:12 146:25
147:7 148:2,9
152:11,20 153:13,
17,20 155:1,7,12,
25
4,450 197:16
4,5 155:15
4/15 203:8
4/7 203:8
40 134:6 142:14
145:3 147:9 148:4
40- something
146:6
41 134:6,9,11
135:5,16 138:12,
142:14 147:9
148:4
42 142:15 147:9
148:4
43 142:15 147:10
148:5
44 142:15 147:10
148:5
45 139:14,16
142:15 147:10
148:5
46 142:15 147:10
148:5
47 147:10 148:5
48 147:10 148:5
49 147:10 148:5
5
5 134:3 141:5
142:12 146:25
147:7 148:2,9
152:11,20 153:13,
17,20 155:1,7,12,
25
5,000 197:15
198:4,6
50 145:3 147:10
148:5 159:13
203:1
51 147:10 148:5
52 147:10 148:5
53 147:10 148:5
54 147:10 148:5
55 147:10 148:5
56 147:10 148:5
57 147:11 148:6
58 147:11 148:6
59 147:11 148:6
5:06 127:4
5th 155:10
L
6 134:3 141:5
142:12 146:25
147:7 148:2
152:11,20 153:13,
17,20 155:1,12,15,
25 168:6
60 147:11 148:6
159:13
61 147:11 148:6
62 147:11 148:6
63 147:11 148:6
64 147:11 148:6
65 147:11 148:6
66 147:11 148:6
67 147:11 148:6
68 147:11 148:6
69 147:11 148:6
6:02 175:18,20
6:09 175:21
6:48 209:24
7
7 134:3 141:5
142:12 146:25
147:7 148:2
152:11,20 153:13,
17,20 155:1,12,15
70 147:11 148:6
71 147:12 148:7
72 147:12 148:7
73 147:12 148:7
74 147:12 148:7
75 147:12 148:7
76 147:12 148:7
77 147:12 148:7
78 147:12 148:7
79 147:12 148:7
7th 146:24
8
8 134:3 141:5
142:12 146:25
147:7,22,25 148:2
152:11,20 153:13,
17,20 155:1,12,15
80 147:12 148:7,20,
24 151:16
80s 147:18
81 147:12 148:7
82 147:12 148:7
8284338392 195:3
83 147:12148:7
84 147:12 148:7,9
85 147:13 148:8
86 147:13 148:8
87 147:13 148:8
88 147:13 148:8
89 147:13 148:8
8:30 202:4,6
8th 148:20155x1
9
9 134:3 141:5
142:12 146:25
147:7 148:2
152:11,20 153:13,
17,20 155:1,12,15
192:14 195:10
9/12 141:2
9/20 141:2
9/23 146:7
9/23/2013 142:11
9/29/2013 134:2
90 147:13,18
91 200:12
92 200:12
93 209:18
94 209:18
98 192:25 202:21,
22,23 206:15
99 151:23
9:00 175:17208:14
9th 155:12
V
a.m. 202:4
Absolutely
128:14,21 157:4
abuse 142:25
143:5,24 144:6,14
209:12
abusing 143:1,8
account 151:25
accurate 178:14
accurately 178:13
accusations 164:2
acres 169:12
act 129:5 143:2,9
acting 152:23
174:8,9,15
actions 167:2,3
171:19 208:9
added 201:18
addition 192:18
address 141:16
148:22
addresses 168:14
admit 176:5
adopted 200:2
advantage 182:13,
18 183:20 189:2,5,
14,17
adverse 171:6
172:4
advice 168:17
169:21200:20,21
advising 185:23
advocate 149:20
advocated 149:13,
15
affairs 182:9,10
184:5
affect 166:25
170:14 172:16
176:10,11
affidavits 129:16
affirmative 161:3
agreed 158:10
agreement 143:16
agreements
160:11
allegations 166:2
176:3,18,19,
178:24 179:23
181:13 206:5
alleged 159:22
179:11,14
allegedly 173:9
alleging 142:25
178:18
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: 5,000- assuming
allowed 168:11,13
169:19
allowing 190:11
alter 181:4
amend 163:8,12
amended 161:3
amount 128:24
135:20
analysis 168:21
197:2,15
answering 179:19
182:21
anymore 140:5
anytime 176:3
apartment 171:12
appeared 142:23
applied 207:21
appointment
202:8
approval 196:7
April 156:6203:8,
9 204:13,19,22
Archive 141:9,22
142:3 146:9,11
area 136:3182:11,
16
argument 188:3
arrangement
170:1
arrow 193:24
203:11
article 134:25
asserted 160:13
asserting 190:3
Asset 152:13,19
153:10
assistance 133:15,
22 134:1
assume 180:13
assuming 147:5
attached 196:4,5
attacking 174:2
attacks 173:16,18
attempt 164:5
attempting
164:16
attorney 179:2
attorney's 128:15,
20 130:8 131:1,13,
14 132:1,10
attorneys 130:7
200:1
attributed 203:16
Avoid 177:24
aware 129:3,14
130:6 131:11
142:16,23 143:5,
148:10,19 153:9,
15,23,25 154:5,8,
14, 155:16 159:20
161:8,10,11,14,15,
20,21 162:1,6,8
164:9,10,17 167:4
173:22 174:5
179:22 180:1,
184:6,12,14
192:22,23
Awareness 156:3,
4
B
back 127:5139:10
175:22 184:19
197:7
bait 174:25
ball 129:10
barraging 159:13
based 143:6,8,11
174:21207:7
208:9
basically 139:23
166:15 168:20
192:6 196:22
197:17 203:15
basis 181:22 183:8
Beach 170:11,15
172:5
behalf 141:2
165:20 171:10
174:8
behaved 156:17
benefit 168:21
197:1,15
benefited 200:23
benefits 143:9
big 173:3
bill 147:13 148:8,
21 149:23 154:18
196:12
binder 201:15
Blanc 161:2,12,15,
19 177:3 184:4
188:19 190:15,19,
21,23 191:3 205:22
blockade - styled
140:3
Bob 135:25160:18
166:13 192:3
206:19
bogus 181:4
book 195:14
203:21
books 135:13
195:6
Bowden 195:3
Boynton 169:15
170:11,12,14 172:5
203:17
Brazilian 196:23
break 175:15
breaking 151:7,11
brick 172:13
192:19 196:24
197:6 199:2,4
bring 143:6,7
164:1,2,6,16
bringing 164:15,
25 165:1,16,19,25
brought 164:13,18
166:10
Bthrasher@
gulfstream.com.
151:24
build 169:14
194:10,195:11
196:8,24
building 171:12
195:11
buildings 169:14
bunch 135:13
137:25 198:21,22
burdensome
139:20
buttons 174:22,24
175:1 179:7
180:17,19
19
calculation
197:12
call 139:21 186:24
196:12,13,14,16
199:6 203:23,24
204:5,14,16,25
called 168:18
169:22 170:3,4
195:10 200:18
204:20 205:9
calling 150:19
199:12
camera 190:20,25
cancel 202:4
canceled 202:8
capitalize 178:17
care 149:8 168:10,
15 194:9
careful 185:23
carefully 171:9
case 131:6,9
142:23 143:11,18,
20 144:599 151:6
Index: attached - Commissioner
157:19 158:6,13,
20,23 161:1,6,11
162:2,6,12,15,23
163:1,5,10,20
164:14,16,18,20
165:10 166:22,24
167:6 171:11
173:13 176:22
178:9 179:11
184:10,18,24 185:2
186:7 188:18
206:3 208:22
209:6
cases 129:16,20,21,
22 130:5,11,14,16
132:2 133:21
146:15,22 160:6
209:4
caught 147:15
caused 188:22
causing 188:21
CFO 201:12
chance 161:6
177:2
Chandler 130:24
131:17 141:3
145:7,11,13,23,24,
25 146:7 178:20
change 139:10
changing 150:17
character 130:21,
22
characteristic
178:7
characterize
189:15
charges 177:25
Charlotte 200:2,6
check 135:13
chest 175:3
chief 139:12
children 200:2
chose 177:10
Chris 148:12
156:4
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
CHRISTOPHER
206:11
cite 177:7
cited 173:13
Citizens 156:3,4
city 159:14 169:15
203:19 204:2
civil 166:15
civilized 209:14
claim 143:4 163:6
174:8,17
claims 142:22
164:6,10,16,17,25
165:16,17,19,21,25
166:10
Clarence 179:5
clarify 142:2
188:11
clear 171:1
clerk 135:16 137:4
138:14,24 139:4,6,
8,19 152:3
clerk's 156:18,21
clever 167:16
client 167:7 174:3,
8 187:10,22 188:1
clients 184:7
close 156:21
clueless 190:4
co- conspirator
160:9
co- counsel 153:3
Coastal 129:18
code 166:16,25
207:10
comment 154:2
comments 174:4
commission
128:22 137:7
150:2
Commissioner
137:8
commit 147:4
148:23 155:18
162:10
committed 154:19
communicate
139:17 183:24
188:20
communicated
196:15
communication
160:20 185:24
communications
187:11,24
community 145:4
company 131:3
compel 160:12
compensate 160:8
complain 139:19
complaint 131:4
133:23 138:7
139:22,24 142:25
177:5 189:22
complaints
132:17 176:24
completed 171:21
completely 130:20
131:9 140:7
174:13 191:6
comply 140:8
156:7,13
compose 135:10
composed 140:14
composite 201:4
computer 135:7
140:14
concede 174:7
concern 176:22
concerned 176:22
concerns 185:6,10
conclude 143:24
189:1
conclusion 197:19
condition 168:12
189:20
conditions 175:6
condone 131:10
conduct 140:7
142:25 144:24
151:1 156:14
157:10 160:9
166:3 167:8 176:4
178:9
conducting 153:2
confident 160:15
confidential
143:16 164:6
206:8
confusion 166:20
conjunction 145:7
conservatory
192:19 194:3,8
195:25 206:23
207:1208:6
conspiracy 174:9
178:19,20 180:21
conspirators
177:23
consuming 139:20
contended 207:13
contingency
160:11
continued 127:3
contractor 208:2
convenience
203:12
convenient 195:8
conversation
140:10 190:15
198:8 199:15
205:5 208:10
conversations
166:13 200:3,5
cooking 166:16
cooperative
145:22
copies 154:23
copy 198:25
209:23
correct 130:4
147:5 172:2,3
195:1
correspondence
198:11
corresponds
192:25
corrupt 150:2023,
24 151:2,6
corruption 151:4
cost 137:25168:20,
23 169:1,7 197:1,
10,14,15,21 198:6
Council 184:13
counsel 133:15,22
134:1 163:14
170:24 173:2
Counsel's 185:11
counter -
defendant 162:3
164:15
counterclaim
143:6,7,18,20
144:1 158:19,20
161:4,13,16,23
162:2,5,7,9 175:10,
12
couple 133:24
court 132:11
143:24 144:10,12
159:6 160:12
162:20 165:8,9
172:21 183:24
188:20,23,25 189:1
205:25
courts 173:22
cover 201:14
covered 191:11
created 148:17
cripple 146:1
CROSS 206:11
current 167:8
171:24 174:1
D
damage 188:21
damages 162:18,
19
damaging 191:14
Dansue 170:2
199:23 200:9
Dansues 200:3
Darrow 179:5
date 147:4 195:13,
15 197:24 203:13
206:4
datebook 201:14
202:23
dates 148:23
153:25 155:18
day 134:2,7,10,16,
17,20 135:6,9
142:11 146:8
147:6 148:25
153:12 154:3,5,11,
12,17 155:2,3,22,
24 159:6,13 204:5,
25
days 129:8139:11
141:25 152:10
Daytimer 192:14,
16 193:19
Daytimers 157:23
deal 142:6
deals 181:10
dealt 207:21
December 196:18
197:25 201:6
202:22
decide 132:12
134:15,17,18 138:1
180:25 190:21
decided 169:7
197:1 198:7
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: commit — destroyed
decision 172:8,16
197:22 198:3
207:24
declaratory
143:23 158:21
defend 192:5
206:2
defendant 131:5
144:12 172:25
defendant's
172:22 193:15
201:7
defendants 130:9
defense 173:2
defenses 161:3
defined 173:22
definition 150:24
179:20 182:7
189:10
demand 131:1
demands 129:15
130:8
demonstrated
127:23
department
156:24 157:2
depends 139:3,9
depo 146:20 206:9
deposition 146:22
153:4 157:18,20
158:6,8,10 181:1
201:12 209:25
depositions
146:14
derogatory
150:13
describe 136:3
151:1
describing 178:8
designed 180:16
desire 127:20,23
128:11
destroyed 196:3
207:2,12
details 196:10
determine 158:21
167:5
differently
176:12,24
difficult 165:6
179:16
digital 140:11,12,
16,18,20 146:24
147:6,22 148:9,13,
21
Digital.record.g-
mail. 140:21
director 203:19
204:1
Dirty 156:4
disadvantage
182:3
disagree 174:13
177:1
disclose 183:15
190 :24
disclosed 177:6
disclosing 185:24
discovered 168:2,
4
discovery 160:10
discuss 204:4
discussed 164:5
188:14 189:1
190:9,11 197:8
discussion 199:18
discussions
206:20
disguising 179:23
dismiss 129:9
131:6
dispute 173:25
disputes 127:21
disqualification
142:21
disqualify 142:24
157:13,17,18
158:8,24 162:7
173:2,8 177:19
183:17
disqualifying
190:4
divulge 182:22
187:10,23
document 135:23
136:1,2,4,7,8,13
137:14 173:4,15
174:6 199:2
201:13 204:15
documented
202:19
documents 135:23
138:4 146:12
148:16 154:1
160:22
dollars 131:12
door 172:8,10
download 137:21
dozen 195:7
dozens 156:5
drafted 179:22
180:1,6
drawing 192:15,
18 195:24
drawings 192:15
199:1
Drive 209:16
E
e -mail 137:18
138:4,6 139:23
141:16
e- mailed 152:7
e -mails 138:11,12,
15
earlier 179:8
earn 130:23
earned 130:10
131:22
easy 137:24 170:10
edited 180:13
editorialize
193:11
effect 171:18,25
172:4,7 176:10
198:24
effort 156:7
157:10
efforts 156:13
egos 181:4
elaborate 176:14
Emilie 170:2
199:23,24
emotional 176:21
enclosure 196:2
207:3,5
encourage 127:8
end 127:21160:23
192:25 205:12
206:15 209:25
engagement
169:5,24
entered 161:22
enterprise 181:5
entire 201:14
entitled 132:16,22
entry 194:7
establish 184:25
established
189:25
estimates 139:12
140:4
evenhanded
178:12
events 179:15
evidence 176:7
evil 150:20
examine 195:6
196:20
examined 194:19
examples 175:11,
12
Exclamation
194:10
exhibit 127:8
172:20,22 173:5,6
193:14,15,19 199:4
201:7
exhibits 192:13
exist 136:1,3
160:14 179:15
exists 209:8
expect 159:2,6
180:20
expert 170:20
explain 196:20
explained 168:12
explaining 171:13
extent 178:2
extort 143:2,9
144:12,14
F
fact 128:21 129:4
160:12 166:25
174:17 176:19
177:7 201:18
208:7
factored 197:2
facts 159:6177:5,8
179:11,12,13,14,
15,17 181:11,12
faith 157:10
fake 166:16
fallback 188:3
familiar 191:6
family 184:7
fast 134:14
father 200:1
February 202:5
federal 166:1
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: details - financial
fee 128:24 129:2,8,
15 169:25
feel 177:10
fees 128:15,20
129:16 130:8,9
131:1,13,14,22
132:1,10 137:16
160:19 171:2
fellows 196:23
fiasco 129:1
fictitious 177:25
181:5
fight 168:21169:1,
2,3,6 172:8 197:15,
21
figure 190:2
file 131:4,8134:9,
20 135:5 140:15,19
145:11 155:9910,
11,12915,21,22,24,
25 161:3,9,16
162:1 178:22
192:6
filed 132:2,10,17,
18 133:9,14,23
134:3 135:17
141:3,5 142:12
143:18,21 144:25
145:3 146:6,7,8,10,
15,22,25 148:20
153:9,11,13,16,24
154:3,4,8925 155:29
3,5,7 158:18
159:22923 161:2,7,
8,12 162:6,15
163:17 167:10
173:7 189:23
files 141:4152:20
filing 128:15924
129:2,8,15 131:12
139:25 140:9
144:7,9,13 146:16
154:17 156:1
159:3,12
finally 169:18
190:6
finances 189:17,18
financial 182:9,10
189:9 191:24
find 136:13,16
137:14 160:10
189:24 191:7
finding 193:23
fine 200:23
fingers 134:14
finish 151:13
153:5 170:22
184:3 185:20
fired 149:13,17,23
151:10,17
firm 129:15,20,23
130:4,7,8 131:11
144:24 159:22
160:3,7 161:17
178:21
Florida 159:10
follow 136:18
footprint 207:6
forcing 187:10
forensically
194:20
form 129:24131:4
138:16,18 144:16
148:14 149:18
150:10,11,21 154:7
155:17 156:9
157:3 159:17,18,24
165:3,23 178:25
179:3 180:4,8
181:19 184:11
185:3,7,11
formal 139:12
Foster 177:20
found 138:4
139:13,15 156:23
170:16,18 193:21
foundation 156:3
197:12
frame 136:8
fraudulent 177:25
free 128:9 160:8
199:25
friend 199:24
friends 184:7
front 157:13
158:23
full 181:16
function 137:20
future 195:14
G- mail.com
141:18
Ganger 137:8
garage 172:8,10
gave 166:14,17
168:14 199:3
200:21
general 206:5
generally 191:18
giant 128:25
give 127:15128:4
129:1,8,9 137:4,15
139:23 147:20
169:6 170:21
175:11, 177:12
182:14,15 183:21
188:19 206:5
giving 158:7
182:12 199:22,23
goal 131:25 132:3,
14 151:17
goals 132:3,5,7,9
good 135:25
157:10 175:8
200:20
government
136:14,20 156:4
granted 163:8,12,
13,19
greatly 200:23
ground 190:3
group 209:13
Grove 141:15
142:9
guess 160:9190:5,
14 201:3 203:9
206:3 209:1
guidance 206:1
Gulf 127:7,24
128:12 130:5
132:1,9 140:6
143:3,10 144:14
146:2 147:14
148:25 156:7,12,
17,19 164:24
165:9,18,20,24,25
167:18 168:1,5
170:13,20 171:10
172:15,25 178:9,23
179:2 181:17
196:1206:24
207:22 209:20
guy 200:18
ID
habit 135:10
195:13
half 195:7
hand 127:24
128:12
handle 133:24
handled 166:11
handling 153:3
hands 174:9,15
181:3
Hanna 129:24
130:11,14 138:16
145:14 146:3
148:14 149:18
150:11,21 153:5
154:7 155:17
156:9 157:3,12,16,
21 158:1,4,7
159:17,24 160:1,
13,15,18 163:7,11,
22 165:3,7,23
167:13 175:15
178:25 179:3
180:4,8 181:19
182:20 184:11,13
185:3,7,11,20,23
187:3,9,16,20,22
192:9 193:10
194:12,21 197:24
208:12,18,23
209:3,15,21
happen 132:14
156:16,18,20
168:13 186:19,20,
23
happened 130:19
134:20 135:7
138:9 174:12,19
181:14 190:2
195:16 208:5,8
happening 166:19
happy 154:2
176:13 177:14
harassing 179:25
Harbor 209:16
hard 179:19206:1
hazy 199:13
hear 132:20136:6
177:15
heard 131:7,15
147:18 186:12
hearing 187:15
188:18 191:1
206:2 209:1
Heath 182:23
184:8,9,17,23
185:14,19,25 186:6
201:17,20,22
202:1,4,8,10,11
203:4,7,204:8,10,
12,16,21,24,25
206:13,16,17
Heath's 204:23
Heath - cancel
202:2,7
heavy 169:18
hell 175:3
helpful 182:3
hide 188:8
hire 168:23169:3
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: find-incident
hired 199:20208:2
hold 131:1175:24
hope 180:23
hoping 184:3
190:19
hot 174:22,24
175:1 180:17,18
hour 145:4 202:24
203:3
house 168:13
172:18 196:4
207:2,15
houses 168:14
hundred 185:1
hundreds 144:13,
25 156:1 178:22
hurricane 196:3
207:1,2,12,16
I
idea 136:2 143:14
148:15 162:11
180:9 191:17
197:20 199:17
Identification
172:23 178:1
193:16 201:8
Identified 135:22
identify 201:19
ill- conceived
179:24
image 164:19
imagine 156:20
immediately
138:5
impact 166:22
167:2,8,19 171:6,
10
impacted 171:22
impacts 170:20
imply 164:8
incident 182:25
206:23
incompetent
150:6
incurred 129:17
131:1,13,14
independent
192:17 207:14
industrial 169:17,
18
inflammatory
178:14 179:6
180:22
information
176:2 177:4,11,18
178:17 183:5
191:13,18,21,24
206:6 207:8
initial 144:8
Initially 133:23
139:10
ink 195:1
inquire 190:12
Inquiry 141:9,22
142:4 146:9,11
inside 140:13
insinuating 160:4
insisting 169:18
instruct 182:20
intended 164:6
intending 179:21
intent 157:17
intention 188:17,
23,25 191:6
interested 196:22
Interpretation
207:10
introduce 177:17
inundate 174:10
181:5
Inventory 152:13,
19 153:10
investigation
143:12
invoke 188:6,7,12
invoked 187:21
invoking 187:17
190:8,10
Involve 173:25
174:1206:24
involved 144:5,20,
24 146:16 160:4
178:18,19 197:18
involvement
144:6 177:23
179:24 180:14
involves 144:6
involving 171:11
182:25
issue 138:8 163:11
168:5 169:9,10,11,
16 172:12 191:8,9,
10 192:18,19
203:17 206:24,25
207:18
issued 168:8
issues 132:19
158:21 166:18
167:19,20,23
185:5,9 204:3
206:9
items 183:15
J
January 201:2,16,
22 202:1
jeopardizing
183:25
Joanne 179:22
180:1,6
job 149:5
Joe 137:1,3,4,5,9,
10,15,16,19,20
Joe's 137:1
Jonathan 152:13,
19,25 153:12 156:2
161:17
Jones 177:19
judge 128:17
132:11 157:13
159:7 161:2,12,15,
19 177:3 184:4
188:19 190:15,19,
21,23 191:3,7
205:22 206:4
judgment 143:23
158:22 192:7
jury 157:9,12,15
158:20,23 159:3,8
180:25
L'N
kind 182:22
185:24 189:12
King 182:23 183:3,
6,9 184:8,9,17,23,
25 185:15,19,25
186:1,6,13,17,20
187:2 188:15,24
190:9 193:1,4
201:17,20,22
202:10,11203:7,8
204:12,24 206:14,
16,17
Kirk 195:3
knew 136:1,11
140:18 162:4
knowing 139:1
170:24 197:3
knowledge 170:23
174:22 175:8
178:4,7 181:25
182:17 189:13,16
192:20 193:6
knowledgeable
184:4
L
labor 196:25197:6
land 203:18
language 176:8,11
178:14,15 180:2,7
Index: incompetent -March
late 175:24
law 129:15,20,23
130:4,7,8 131:11
136:18,19,23 137:6
151:7,11 159:22
160:3,7,14 161:17
166:21 167:5,6
171:3,15 173:13
178:21
lawsuit 131:12
133:14 166:1
185:15
lawsuits 133:9
lawyer 152:19,23,
24 174:1,2 180:20
200:23
lawyers 165:8
194:18
league 134:1
learned 171:16
leave 158:19
161:2,9,16 162:1
205:22
left 171:21 198:22
legal 151:13
167:11 170:20
173:25 191:5
legitimate 137:11
letter 136:25137:1
140:3 169:5,24
letters 152:8
library 135:12
lie 184:16,21,22
186:11
life 206:21
light 156:14
169:17
likes 151:21
limitations 171:19
list 134:19,22,23
135:4 148:16
litigate 128:19
litigation 189:6
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
living 159:21
locate 135:24
log 154:21,22
long 134:9135:15,
19 138:13,23,24
139:4,18 196:13
205:7
longer 172:18
looked 175:7
176:1
lose 206:18
lot 132:19 152:8
170:23 179:5
209:2
M
mad 180:16,19
made 129:4,6
132:12 135:4
156:7,13 161:21
163:15,23 164:8,9,
14 171:1 178:24
207:3
mail 141:12,15,17
142:8,18
maintained 196:2
make 128:9130:25
136:24 138:20
139:15 145:25
154:19 157:1
160:5 164:2 176:8
180:16,19 183:20
195:14 201:4,5,11
206:3
making 129:7,15
130:8 144:11
193:23 195:8
203:22
man 152:24
manager 148:25
149:12,25 150:4
151:15 159:14
199:7,12 203:19
204:2
March 156:6
203:7
mark 172:19201:3
203:20,24,25
204:2,3
marked 172:22
193:15,18 201:7
marks 209:25
Martin 156:2,3
161:17 162:2
math 198:2 202:17
matter 128:21
129:4 138:3 171:6,
7,25 174:1208:7
matters 127:24
128:12 152:25
173:23 206:8
mayor 199:24
200:8
mayor's 168:13
means 151:2
174:16 203:18
meant 178:16
179:6
mediation 164:5
medical 175:5
189:20 191:21,23,
25
meet 184:8
meeting 136:6,10
137:7 138:9 150:2
163:24 202:19
204:12,13,23,24
meetings 128:22
202:18 203:4
memorialized
203:22
memorize 153:25
memory 147:4
148:23 155:19
162:10 170:18
183:10,199:13
men 127:20
mentioned 200:16
mentions 136:21
met 145:10,12,17,
23 182:5 202:1,24
microphone
206:18
middle 203:16
million 156:23
mind 200:17
mine 140:24141:1
152:15
minimal 131:14
minimum 128:24
minutes 134:12
137:21 139:2,13,
14,16 203:1205:8
mirror 164:19
mischaracterizati
on 144:17165:24
mischaracterizin
g 129:25
moments 205:8
money 130:23
131:8 137:25
151:2 160:5
168:21 169:6,8
197:20,21209:11
month 202:14,16
months 133:5,19
morph 139:10
motion 157:13,16,
18 158:8,19,24
161:2,9,12 163:7,
12,16,19 165:13
167:10,24,25 171:3
173:1,8,14 183:21
189:23 192:5,7
195:17,20 201:11
206:5
mouthful 173:3
move 158:4160:12
181:1 187:19
190:5,14 192:10
209:1,16,19
moved 142:24
162:1,7
moving 166:6
171:2 183:17
multiple 135:1
145:11,25 154:5,
11,185:17
U
named 162:2,4
names 181:5
nasty 150:8
nature 182:4,8,11,
16 183:22 189:9,
191:10
negatively 166:22
nice 200:18
nicely 145:19
170:5
Ninety 147:17
209:18
nonfacts 177:8
nonsense 188:2
not - for - profits
181:4
notation 195:3
202:6 204:7,14,20,
22,24
note 195:4, 197:14
203:23
notes 157:23
noticed 158:6
November 155:14
number 129:22
132:17 140:9
147:16 150:8,13
198:10 199:4
numbers 147:16
numerous 149:3,
22 152:25
G7
O'boyle 127:20,22
128:2 129:14,20,23
130:3,7 131:11
152:13,19,25
153:13 156:2,
160:3,7 161:11,17,
18 162:2 163:20
164:14,18 178:21
O'boyles 130:22
178:21
O'connor 179:22
180:1,6
O'hare 127:20,23
137:22 148:12
156:4 157:24
160:2 171:1
175:24 206:11
object 128:6
129:24 138:16
148:14 149:18
150:10,11,21 154:7
155:17 156:9
157:3 159:17,18,
24,25 164:24
165:3,23 178:25
179:3 180:4,8
181:19 182:20
184:11 185:3,7,11
objection 144:16
145:15 146:3
152:22 153:1
157:12 166:6
167:13 181:16,22
obscure 179:25
obtain 157:5,7,11
obtained 171:7
176:2 177:11
192:21
occasions 149:22
occupy 169:19
occur 134:24
occurred 176:19
occurring 180:21
Ocean 145:21,22
165:13,21 166:3
167:1,3,24 182:25
209:16
October 146:24
147:22,25 148:20
152:18 153:16,24
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: mark - Patriot
154:25 192:14
193:19 194:7
195:10,12
offer 129:4,6,
187:7
office 156:18,21
oil 131:3
online 127:9
open 195:13 209:7
operation 160:2
opinion 150:17
167:11 170:21
171:15,16,17
opportunity
142:3 188:20
opposed 148:12
order 143:2,9
144:14 146:1
206:10
ordered 161:16
original 194:17
outlined 176:16
outright 177:9
P
p.m. 175:20
paid 140:4 197:5
199:20 203:3
Pancra's 198:16,
18
pardon 191:5
parrot 166:4
part 127:10 144:2
151:17 157:10
185:15 186:10
195:17 199:18
207:2
party 190:16
passage 177:21
past 173:17,19,20
Patriot 127:7
pay 129:2 131:5
132:9 138:1,2
169:8
Payment 160:19
peace 127:21
peanuts 128:23
pencil 194:15,25
195:2,5
pencils 195:7
pending 158:14
161:1209:22
pens 195:7
people 131:2,7
149:3,6,9915
151:10,12 156:17,
24 174:25 177:20
180:15 184:7
185:1,4 209:13
people's 130:14,16
percent 151:23
performed 173:17
174:2
period 139:9
202:12
permission
127:14,15,16
1282,4,5 169:14
176:16
permit 166:18
167:19920 168:5,7,
8,10,18 169:9,10
172:12 192:18
198:25 207:21
permitted 199:5
person 137:19
186:16
personal 170:23
178:1 181:25
206:21
personally 139:21
149:8 151:17
phone 186:16,23
196:12,13,14,16
198:15 199:16
phonetic 170:2
199:23
phrase 178:5
191:2,4
phrasing 165:5
physician 187:12
picking 180:15
pierce 188:3
Pineapple 141:15
Pinegd 141:15,16
Pinegd @g -mail.
com. 141:12
142:18
Pinegd @gmail.
com 142:19
Pinegd@
pineapple 142:8
place 162:14
198:16,19
plaintiffs 173:1
plan 166:6168:10
play 183:23
pleading 161:8
176:11,18 180:16
184:20
pleads 180:20
pled 181:3
Plenty 133:3,5
point 176:5,8
192:7 194:10
209:22
pointing 194:7
poke 175:2
police 139:12
pontificating
188:10
pop 137:20
portion 196:25
position 182:2
185:14,19 187:9,23
188:1
possibly 136:21
140:8
Post 193:20
Post -it 193:22,24
194:1,7 199:8,9
201:18 203:11
pound 144:14
pray 159:7
precluded 164:25
prepare 206:2
prepared 180:12
present 183:2
186:15,16 205:14
presently 132:24
142:7
presumed 180:12
pretty 150:17
189:25 206:1
prevailed 169:19
previous 130:1
166:23 167:3
199:18
previously 166:12
175:25 176:3
177:6,11
prior 167:8171:7
private 163:24
189:5 190:15
privately 185:5
206:3
privilege 178:6,7
182:22 187:4,18,21
188:7,12 190:8,10
privileged 160:20
166:14 183:12,16
185:24 186:18
187:5
privileges 160:13
pro 133:12,14,22
problem 128:8
Proceedings
127:3
process 140:5
143:1,5,8,25 144:7
190:20
processes 196:7
produce 139:14
194:19
produced 168:3,5
196:20
producing 201:13
product 173:17,18
production
195:21
professional
139:22
profile 176:23
prompted 178:4
proper 191:4
197:11
property 169:19
proven 152:22
provided 160:22
201:10
proving 176:22
psyche 189:13
psychological
176:23 189:8
192:2
public 128:16,19,
129:22 130:9,25
131:20 132:1,10
134:6,9,15 135:5
136:25 137:11
138:9 140:1
142:15 143:1,8
144:7,11,13,25
145:3,12,18 146:1,
15,25 147:13
148:20,24 151:16
152:2,12 158:17
159:4,12,14,23
160:5 174:11
181:6 208:21
209:2
publicly 149:22
150:1,14
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: pay -quiet
published 127:13,
17
pulled 201:15
purchased 169:12
pure 163:18,22
purely 176:9
179:25
purpose 158:9
177:22 184:17
193:22 201:13
purposes 173:24
186:6
push 179:7 180:17,
18
put 137:20138:10
172:13 187:25
193:20,22 196:9,11
206:4 208:2,3
putting 160:16
187:22
6:
quarter 208:15
question 129:25
130:1 132:20
135:25 136:9
153:6,22 156:10
157:8 159:2
167:22 178:11
179:20 182:15
185:18,22 186:3,10
188:5,9 190:19
192:9 193:10
203:19,20,24,25
204:2,3
questioned 174:20
questions 157:21
160:3,22 171:8
185:16,17 189:21
192:11208:20
209:2
quick 175:15
196:12
quicker 193:23
quiet 127:25
128:12
quotation 196:23
R
radical 193:9
raised 206:8
ran 198:15
Randolph 133:25
rationale 200:17
reached 197:22
198:2,3
reaching 136:12
react 175:1
reaction 176:21
reactions 175:8
reacts 176:23
read 128:6129:18
135:14 162:9
163:6 173:11,15
174:6,20 175:13,25
176:1, 194:5,6
202:3
reads 151:24
real 156:24 157:2
193:9
realize 175:24
realized 133:25
reason 135:2
151:20 159:5
171:20 198:5
200:16 201:23
reasonable 135:20
136:22,24 137:2
156:7,13 161:20
reasonableness
159:8
recall 140:3,10
142:7 152:4 205:5,
16,18
receive 172:25
173:5,10
received 132:24
133:1, 173:4
recent 193:25
194:1
recently 133:17,18
recess 175:20
recognize 141:11
142:4,5 175:7
recollection
198:13 199:14
204:6
recommended
184:25
recommending
184:7
record 127:5
128:25 129:2,9
132:13,22 134:24
135:11 136:21
137:5,12,13,18
140:11,12,13,16,
18,20 142:3,4
146:1,17 147:6,22
148:9,13,21 151:19
156:24 157:2
175:19,22 177:18
188:13 193:21,23
195:9, 196:21,25
197:2,3 199:9,18
201:19 202:5,17
203:12,15 208:19
209:7
Record.public@
yahoo 140:25
Record.public@
yahoo.com. 141:7
records 128:16,19
129:22 130:9,25
131:21 132:1,10,
15,23,25 134:6,10,
15 135:3,5 136:14,
16,25 137:10,14
139:13 140:1
142:15 143:1,8
144:7,11,13,25
145:3,12,18
146:16,24,25
147:13 148:20,24
151:16 152:2,12
157:5,7,11 158:17
159:4,12,14,23
160:5 168:3,4
170:16,17,18
174:11 181:6
192:17 202:9
208:21209:2,7
refer 185:4
reference 195:14
198:4
referred 179:7
206:13,16,17,21
referring 148:15
154:1 184:6
refrain 182:21
refresh 170:18
regard 143:11
163:21 167:18
168:15 193:18
rejected 196:1
207:7
rejects 194:3,8
relate 177:5
179:11,13,17,18
181:14
related 165:10,17,
20 166:10,11
173:23,24 183:19
192:15,18
relation 179:18
relationship
162:23 167:6
188:2 190:1
relief 143:2 144:12
162:16,20,21,22,25
163:5
remedy 132:11
remember 129:7
134:6 147:21,22
162:21 163:2
182:18 183:11
196:17 198:14,20
199:17 200:4
205:10
remotely 159:10
remove 168:22
197:16
rephrase 144:22
153:8
replace 196:11
207:4,11,15
replacement
196:4
REPORTER
172:21
represent 133:12
169:20
representation
143:11 144:3
157:24 158:14,16
161:1 162:12
163:16,17 164:13,
24 165:9 166:14,
21,23 167:7 171:5,
24
represented
129:19,23 130:3
133:21 144:23,24
165:17,21 170:22
173:8 182:1200:6
representing
167:18 171:22
181:17 200:8,12
represents 202:6
request 132:2
137:12 138:20
139:5 140:15,19
142:4 146:7,8
153:10 155:24
158:17 160:6
requests 128:16,
19 129:23 130:9,25
131:21 132:10
134:6,10 135:1,3,6,
16 136:25 140:1,5,
9 141:3,4 142:15
144:7,11,13,25
145:4,12 146:1,7,
10,16 147:1,13
148:8,21,25
151:16,19 152:2,12
153:14,21,24
154:3,4,5,9,11,17,
20,23 155:1,2,4,6,
8,9,10,11,13,15,22,
23,25 156:2,8,13
159:4,13,14,23
174:11 177:24
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: quotation- Roeder
178:23 179:24
181:6 208:21
requirement
167:4
requires 166:21
research 135:24
143:7
resolve 127:24
128:11 191:7
respond 135:16
138:14,23,25 139:5
189:22
responds 152:7
response 133:7
173:1,7
responses 139:9
154:23
result 167:9 171:6
retaliation 166:1
return 127:21,24
128:12
review 161:6
RICO 143:4,19
156:23 162:13
rid 149:9
Ridge 145:21,22
165:13,21 166:3
167:1,3,24 182:25
209:17
ridiculous 193:13
rights 166:15
Ring 161:18
Rita 139:22140:6
151:20,24 152:7,8
Rita's 152:4
robocall 145:25
Roeder 138:18
141:2 144:16
145:7,10,12,15,24
146:17 150:10
152:22 153:1
158:15,159:18,25
160:21 163:13,23
164:1,8 178:20
188:5,9 190:6
192:10
rolling 129:10
roof 195:4
room 186:21
Roy 193:24
rule 173:24 174:4
ruled 161:19
ruling 161:21,25
run 175:3
sake 203:12
sanctions 166:6
192:7
sat 135:11
scheme 130:25
177:24
scope 143:10144:2
158:13,16 160:25
162:12 163:16,20
164:12,23
screen 194:9
196:2,5,11207:3,4
search 137:20
138:4
seawall 172:14
199:4
seconds 134:11,13
138:20,22
seek 162:19
seeking 132:11
162:18,21923,25
163:5
seeks 162:15,20
selected 176:9
send 137:21
138:13,22,23
169:24
sender 142:17
sending 139:12
sense 139:15
separate 196:6
207:14
September 135:17
141:4,25 142:8
148:19
sequence 156:2
serial 145:12
178:22
serve 152:1
served 149:11,14,
16,24 150:3
151:14,16,19,22
152:11,18 161:22,
24
service 177:25
199:23
set 127:10 145:25
189:24
settle 128:18132:8
164:5
settled 167:1
seven -month
202:12
sham 171:3
shape 207:5
share 177:19178:3
sharper 195:5
Shelly 207:3
shield 187:18
188:8
short 175:2,4
176:1
shots 150:19
show 146:21 154:1
160:16 201:14
showed 168:10
showing 146:15
shows 163:20
196:24 202:10
shut 209:7
silly 177:15
similar 161:12,23
162:7 164:21,22
166:16
similarities
166:20
singular 132:3
sir 147:14 148:19
155:21 188:9
sit 162:16
sketch 195:25
207:3,6
slightly 207:5
society 209:14
sorts 196:7
sought 134:1
sounds 140:24
141:1
speaking 166:5
170:22 198:14
special 147:24
177:25
specific 135:22
136:1 169:15
182:14,15 199:14
208:21
specifically
162:15 169:4
173:23
speculation
163:18,22
speech 128:9
spend 134:21
spending 209:11
spent 154:17
split 180:9
spoke 150:2
168:20 169:23
199:11
spoken 187:2
standard 167:9
171:5
stapled 192:15
Index: rolling - Sweetapple
Star 129:18
start 134:2 136:14
139:11 153:18
started 145:6,23
152:6 202:21
starts 177:22
state 129:16
131:21 150:25
159:9
stated 149:22
150:1
states 202:5
statesmanlike
178:12
stating 178:15
statute 171:19
stick -cm's 201:1
Stickum 201:5
203:9,10
stipulate 158:15
stop 156:4188:9
straight 159:15
strangers 184:8
strategies 131:8
Stream 127:7,24
128:12 130:5
132:1,9 140:7
143:3,10 144:14
146:2 147:14
148:25 156:7,12,
17,19 164:24
165:10,18,20,24,25
167:18 168:1,5
170:14,20 171:10
172:16 178:9,23
179:2 181:17
196:1206:24
207:22 209:20
Stream's 173:1
strike 131:16
162:23
strong 127:23
128:11
structure 169:16
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
194:4,9 196:6
207:11,13,14,15
struggled 183:23
stuff 171:20
208:18
subjective 176:25
submitted 147:7
submitter 148:12
substantial 167:5
190:1
substantially
165:10,17,20
166:2,9,11 173:23,
24
sue 161:16
sued 131:2164:14
sufficient 176:6,7
suggest 160:8
184:5
summary 192:7
Sunday 135:8
supplied 196:1
197:3
supports 197:11,
12
suspect 188:21
suspend 205:25
206:7
suspended 208:16
Sweetapple 127:6
130:2,15 138:21
144:19 145:16
146:5,19,23 148:18
149:21 150:12,22
152:24 153:2,7
154:10 155:20
156:11 157:6,14,
19,25 158:3,5,12,
IS 159:1,19160:7,
17,19,24 163:10,
15925 164:4,11
166:5,8 167:14
172:24 175:16,23
179:1,9 180:5,11
181:21 182:23
183:1 184:12,15
185:4,8,13,25
186:4 187:6,13,17,
21,25 188:6,16
190:7 193:12,17,20
194:9,11,14,22,23
197:14,15 198:1,5
199:6 203:9,19
204:16,20 205:24
206:19 207:17
208:1,10,15,20,25
209:4,9,12,23
Sweetapple's
170:17
sword 187:18
T
table 151:2
tailored 174:21
175:9
takes 137:21,23
taking 140:1151:2
171:20
talk 130:24 132:8
167:25 168:1
174:7 185:5,9
186:13 203:21
207:20
talked 131:17
183:6,8 186:17
196:10 203:18
207:17,23,25
talking 130:11
136:10 143:4
146:12 161:5,25
163:7 167:20
171:21 177:12
184:19 191:17
talks 127:8 167:24
tarp 195:4
Taylor 139:22
140:6 151:25
technique 131:18,
19 192:3
telling 170:19
187:13 188:23,25
tells 150:18
temper 175:2,4
temperament
189:19
ten 129:8 156:16
term 174:23
terms 178:8191:5
testified 152:5
180:18
testify 143:15
184x8
testifying 184:13
185:12 186:6
187:14
testimony 183:21
187:7
theme 134:25
therapist 182:24
therapy 182:24
183:2
thereabouts
139:11
thing 166:19
195:23
things 128:23
150:8, 151:13
170:23 175:7,
177:9,10 178:2,6,
16 181:17,18
182:1,2,4 208:12,
23
thinking 150:17
177:16
Thirteen 133:5
Thirty 134:13
138:22
thought 133:23
135:10,18,20 136:9
140:17 150:19
198:5 202:9 207:7,
24 208:13
thousand 159:12
thousands 131:12
137:13,14 174:10
181:6
Thrasher 147:14
148:8,21 149:1,4,7,
23 150:6,9,14
151:20,22 152:2,7,
11 154:18 166:17
168:8 194:3,8
196:2 198:6 199:5
207:6,13,22,23
threats 163:23
three -plus 169:12
throwing 136:12
time 127:4129:12
134:21 135:7,10,
13,21 139:9,20
149:2 151:7
152:20,23 153:12
162:19 169:13
170:10 175:7,18,21
176:1 179:19
186:12,15 193:4
195:8 198:9,23
199:22 200:8,10
201:24 202:25
203:17 207:20
209:24
times 136:5154:4
202:11,13,15
told 136:5149:3,6,
9,15 151:10,12
152:1 165:8,9
170:5, 175:16
177:6 181:10
184:23 191:15
196:8 197:17
topic 136:16,20,22
torn 207:16
total 171:3 202:15
totally 209:13
town 127:21,25
128:12,22 130:5
132:9 133:8 136:5,
6,10 137:12 140:6
143.2,9 146:1
147:14 148:25
149:11,12,14,16,
24,25 150:3118
151:14,15 152:3
156:6,12,19,22
Index: Sweetapple's- wanted
157:1 166:15
171:23 172:25
174:10 181:6
182:3 191:15
196:1 199:6,12
206:24
town's 154:22
towns 156:25
transaction
173:25
transcript 157:14
158:22
transmissions
133:25
trespass 138:8,10
trial 158:21 188:18
trials 157:15
troublesome
137:22
true 130:17 141:8
177:9 178:16
truthful 180:23
turn 155:14,
171:21
turned 128:25
type 130:1 191:18
types 151:4
typo 142:19
U
Uh -huh 133:2
unacceptable
209:13
unaware 130:18,
20
unclean 174:9,15
181:3
uncovered 195:22
understand 144:3
149:19 152:9
166:19 171:4
187:20 190:10
195:23
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
understanding
186:5
undertake 167:7
undertook 159:21
undo 173:19
unethical 131:9
unfair 182:12,18
183:20
unfairly 182:3
unfavorably
175:1
unnecessary
176:15
unreasonable
140:8 207:7,24
updated 157:18
158:7,9
upset 181:18
MA
verified 173:1
verify 206:6
violating 143:16
166:15
violation 167:1
171:11
violations 166:16
visit 127:8193:1
visits 202:10
volunteered 139:6
W
W/land 203:18
waiting 153:5
wall 172:13 192:19
196:24 199:4
wanted 134:16,25
135:11 136:7,18
169:14 178:12
207:4 208:23
wanting 132:8
waste 198:23
ways 174:25
website 150:14
154:22
week 135:9 154:5,
11,12,13,15,17
161:15,22
weekend 155:25
weeks 134:19
wife 182:1,5
William 161:18
Wilma 196:3
207:2
windfall 130:25
131:3
withhold 127:15
128:4
word 136:21
137:19 138:7,10,11
149:19 177:23
179:16,18,20 182:7
197:12
words 177:9178:5
180:15,21204:3
work 134:23
170:10 173:16,18
174:2 184:1
worked 134:19
working 134:21
145:24 160:8
workload 180:10
works 190:20
worth 138:1
197:22
write 134:25
181:17
writes 152:8
writing 128:9
181:18
written 129:15
179:4 194:15,24,25
195:1,15 203:13,21
wrote 204:20
www.
gulfstreampatriot
.com. 127:9
!1
Yahoo 142:1
year 135:18147:2
192:21 193:2
194:12 201:17
years 150:9,15
165:11,22 184:6
190:2 198:22
200:14
Z
zeros 140:14
zoning 166:17
167:23 169:10,11
170:14 171:11,25
172:5 203:17,19
204:1
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: wanting — zoning