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HomeMy Public PortalAboutPRR 15-1838REQUESTEE: REQUESTOR: RECORDS REQUEST (the "Request ") Date of Request: 4/24/15 Requestor's Request ID#: 1081 Custodian of Records Town of Gulf Stream Asset Enhancement, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records @commerce- group.com Fax: 954- 360 -0807 or Contact Jill Mohler, Records Custodian at imohler(a )commerce- 13out).com: (954) 570 -3507; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: 1. Please provide copies of all communications sent by or received by either Jones Foster Johnston to s, P.A. an or the Town of u tream including its partners, attorneys, employees, paralegals and legal secretaries including administrative personne , as we as the Town of u Stream's Commissioners, employees, managers and Police) for the period from January 1, 2014 to the date of this Request. 2. Provide all copies of all billings and payments from and to Richman Greer, P.A. by the Town of Gulf Stream or by Robert Sweetappple or Sweetapple Broeker & Varkas (but as to Robert Sweetapple or Sweetapple Broeker 8s Varkas only If such billings and payments relate tote Town of tream or any of its Commissioners, employees, managers and Police). This Request is made for the period November 1, 2014 to the date of this Request. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO ARTICLE L SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119, FLORIDA STATUTES IF THE PUBLIC RECORDS BEING SOUGHT ARE MAINTAINED BY YOUR AGENCY IN AN ELECTRONIC FORMAT PLEASE PRODUCE THE RECORDS IN THE ORIGINAL ELECTRONIC FORMAT IN WHICH THEY WERE CREATED OR RECEIVED. SEE 5119.010)(F). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON It X 17 PAPER NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALSO PLEASE TAKE NOTE OF §1 19.07(l)(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WITHIN THE 30 -DAY PERIOD TO ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF THE RECORD EXCEPT BY ORDER OF A COURT OF COMPETENT JURISDICTION AFTER NOTICE TO ALL AFFECTED PARTIES." ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E -MAIL DELIVERY. PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requestor approve orany costs, asserted by the Agency (as defined In Florida Statute, Chapter 119.01 (DeMitlons)), in advance orany costs imposed to the Requestor by the Agency. 'BY FULFILLING THIS RECORDS REQUEST, THE AGENCY ACKNOWLEDGES THAT THE RESPONSIVE DOCUMENTS ARE "PUBLIC RECORDS" AS DEFINED IN CHAPTER 119, FLORIDA STATUTES ". I/P/NP/FLRR 3.2.2015 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail April 26, 2015 Asset Enhancement, Inc. [mail to: records @commerce- group.com] Re: GS #1838 (1081) 1. Please provide copies of all communications sent by or received by either Jones Foster Johnston & Stubbs, P.A. and /or the Town of Gulf Stream (including its partners, attorneys, employees, paralegals, and legal secretaries including administrative personnel, as well as the Town of Gulf Stream's Commissioners, employees, managers and Police) for the period from January 1, 2014 to the date of this request. 2. Provide all copies of all billings and payments from and to Richman Greer, P.A. by the Town of Gulf Stream or by Robert Sweetapple or Sweetapple Broeker & Varkas (but as to Robert Sweetapple or Sweetapple Broeker & Varkas only if such billings and payments relate to the Town of Gulf Stream or any of its Commissioners, employees, managers and Police). This request is made for the period November 1, 2014 to the date of this request. Dear Asset Enhancement, Inc. [mail to: records(a),commerce- group.coml, The Town of Gulf Stream has received your public records requests dated April 24, 2015. If your request was received in writing, then the requests can be found at the following link: hU: / /www2.gulf- stream. org/ WebLink8 /0 /doc /48077/Pagel.asnx. If your request was verbal, then the description of your public records request is set forth in the italics above. Please refer to the referenced number above with any future correspondence. The Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk, Custodian of the Records RICHNIAN GREER PROhLSS1OHAL ASSOCIATION Richman Greer, P.A. 396 Alhambra Circle North Tower, 14th Floor Miami, FL 33134 305- 373 -4000 Fed. Tax I.D. #59- 1172536 TOWN OF GULF STREAM Invoice 71622 WILLIAM THRASHER, TOWN MANAGER March 10, 2015 100 SEA ROAD Page: I GULF STREAM, FL 33483 ID: 9469 - 0000001 - GFR Re: TOWN OF GULF STREAM - O'BOYLE ETAL FOR PROFESSIONAL SERVICED RENDERED THROUGH February 28, 2015 PREVIOUS BALANCE PAYMENTS RECEIVED BALANCE FORWARD CURRENT FEES CURRENT DISBURSEMENTS TOTAL CURRENT CHARGES TOTAL DUE TRUST BALANCE Check # lue 15,919.90 1,045.36 I APPROVED-4 965. '16 51,150.57 (51,150.57) 0.00 16,965.26 16,965.26 ` 12758 TOWN OF GULF STREAM OPERATING ACCOUNT 3116/21115 To Richman Greer Professional Association 396 Alhambra Cir. North Tower, loth Floor 310,2015 legal 001 - 53110- 513 -10 Legal Services - .Admin TOWN OF GULF STREAM OPERATING ACCOUNT 100 SEA ROAD GULF STREAM, FL 33483 -7427 j (561) 276 -5116 SUNTRUST BANK 63- 215/631 PAY "Sixteen thousand nine hundred sixtyfive and 26/100 Dollars" I TO THE ORDER I OF Richman Greer Professional Association 396 Alhambra Cie North Tower, 14th Floor WOU�Onlmil Miami, FL 33134 — AUTHORIZED SIGNATURE 11'01275811' 1: \r�ARMOR' CHECK DATE 12758 CHECK NO. 3/16/2015 12758 CHECKAMOUNT c $" 16,965.26 i RICHNIAN GREER PROFESSIONAL ASSOCIATION Richman Greer, P.A. 396 Alhambra Circle North Tower, 14th Floor Miami, FL 33134 305- 373 -4000 Fed. Tax I.D. 459- 1172536 TOWN OF GULF STREAM Invoice 71994 WILLIAM THRASHER, TOWN MANAGER April 10, 2015 100 SEA ROAD Page: 1 GULF STREAM, FL 33483 ID: 9469 - 0000001 - GFR Re: TOWN OF GULF STREAM - O'BOYLE ETAL FOR PROFESSIONAL SERVICED RENDERED THROUGH March 31, 2015 PREVIOUS BALANCE PAYMENTS RECEIVED BALANCE FORWARD CURRENT FEES 24,408.50 CURRENT DISBURSEMENTS 385.81 TOTAL CURRENT CHARGES TOTAL DUE TRUST BALANCE 0.00 TUWN OF GULF STREAM ® PAYMENT APPROVED-4 Amount .31 By � 6c Date Check #__j2 Date 7 16,965.26 (16,965.26) 0.00 24,794.31 24,794.31 0 ' 12861 TOWN OF GULF STREAM OPERATING ACCOUNT 4/17/2015 To: Richman Greer Professional Association 396 Alhambra Lit. North Tower, 14th Floor Miami, FL 33134 . ., DESCRIPTION 71994 4110 2015 Legal $24,794.31 $0.00 $24,794.31 Totals: $24,794.31 $0.00 $24,794.31 001 -53110 -513 -10 Legal Services - Admin x x x 12861 TOWN OF GULF STREAM SUNTRUSTBANK Ell Ell ARMOR OPERATING ACCOUNT 63- 2151631 100 SEA ROAD CHECK DATE CHECK NO. GULF STREAM, FL 33463 -7427 (561) 276 -5116 4/17/2015 12861 CHECKAMOUNT "Twenty four thousand seven hundred ninety four and 31/100 Dollars" PAY $" 24,794.31 F E TO THE ORDER OF Richman Greer Professional Association 396 Alhambra Cir. .� North Tower, 14th Floor o. " „” Nye Miami, FL 33134 ' ce „ui „r_- ae m• � AUTHORIZED SIGNATURE II.01 ME, Ills qhRICHMAN GREER PROFESSIONAL ASSOCIATION Richman Greer, P.A. 396 Alhambra Circle North Tower, 14th Floor Miami, FL 33134 305- 3734000 Fed. Tax I.D. 959- 1172536 TOWN OF GULF STREAM WILLIAM THRASHER, TOWN MANAGER 100 SEA ROAD GULF STREAM, FL 33483 ID: 9469-0000001 - GFR Re: TOWN OF GULF STREAM - O'BOYLE ETAL FOR PROFESSIONAL SERVICED RENDERED THROUGH CURRENT FEES TOTAL CURRENT CHARGES TOTAL DUE 5,385.00 22, 2015 Invoice 70964 January 22, 2015 Page:I 5,385.00 5,385.00 TRUST BALANCE 0.00 TOWN OF GULF STREAM ► PAYMENT APPROVED 4 Amount Jr %6.00 By lA1 Dat /)/ Check # 1,0- 4$1 Date,2 Ag RICHMAN GREER PROFESSIONAL ASSOCIATION Richman Greer, P.A. 396 Alhambra Circle North Tower, 14th Floor Miami, FL 33134 305- 3734000 Fed. Tax I.D. #59- 1172536 TOWN OF GULF STREAM WILLIAM THRASHER, TOWN MANAGER 100 SEA ROAD GULF STREAM, FL 33483 ID: 9469 - 0000001 - GFR Re: TOWN OF GULF STREAM - O'BOYLE ETAL FOR PROFESSIONAL SERVICED RENDERED THROUGH BALANCE FORWARD CURRENT FEES 45,397.95 CURRENT DISBURSEMENTS 367.62 TOTAL CURRENT CHARGES TOTAL DUE TRUST BALANCE 0.00 31, 2015 RTOWN OF GULF STREAM �> PAYMENT APPROVED Amount 45 7(e . 5D gy DateL� Check # Invoice 71293 February 11, 2015 Page: 1 5,385.00 45,765.57 51,150.57 uci.in u�we rv.ee.0 �, N�a ewn viauwaw rvuua a,uu, rvc uav uuu,uv,, OOV.YGG.W /G TOWN OF GULF STREAM OPERATING ACCOUNT To: Richman Greer Professional Association 396 Alhambra Cir. North Tower, 14th Floor 61 12681 2/19/2015 70964 1/228015 legal $5,385.00 $0.00 $5,385.00 71293 2/118015 legal svcs $45,765.57 50.00 $45,765.57 Totals: $51,150.57 $0.00 $51,150.57 001 - 53110- 513 -10 Legal Scrviccs - Admin TOWN OF GULF STREAM OPERATING ACCOUNT 100 SEA ROAD GULF STREAM, FL 33483 -7427 (561) 276 -5116 SUNTRUST BANK UJARM o— 12681 63- 215/631 CHECK DATE CHECK NO. PAY "Fifty one thousand one hundred fifty and 57/100 Dollars" TO THE ORDER OF Richman Greer Professional Association 396 Alhambra Cir. ....... EIR -- North Tower, 14th Floor otllolN<-. Miami, FL 33134 3� 3N tlN3 7 G ENUINr_. DE I.NI`JItlO. lV AUTHORIZED SIGNATURE II■❑ 1 268 ill' 2/19/2015 12681 i CHECKAMOUNT $" 51,150.57 e , I i iE I! TOWN OF GULF STREAM LITIGATION PUBLIC RECORD SUITS AS OF 04/24/15 1. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA015012 AJ (Goodman), Served 10/3/13; pending 2. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA015380 AF (Janis Keiser), Served 10/11/13; pending 3. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA016864 AD (Gregory Keyser), Served 11/21/13; pending 4. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA017717 AA (Blanc), Served 12/5/13; pending 5. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA017793 AA (Blanc), Served 12/11/13; pending 6. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA018093 AA (Blanc), Served 12/17/13; pending 7. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA018095 AA (Blanc), Served 1/10/14; pending 8. Christopher F. O'Hare vs Town of Gulf Stream, Case No 502013CA018098 AA (Blanc), Served 1/17/14; pending 9. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA018100 AA (Blanc), Served 1/21/14; pending 10. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502013CA018101 AA (Blanc), Served 1/24/14; pending 11. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA000824 AA (Blanc), Served 1/22/14; pending 12. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA000835 AG (Hafele), Served 1/22/14; pending 13. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA000894 AN (Cox), Served 1/24/14; pending 14. Martin E. O'Boyle vs Town of Gulf Stream, Case No. 502014CA000834 AH (Small), Served 1/31/14; pending 15. Martin E. O'Boyle vs Town of Gulf Stream, Case No. 502014CA001572 AJ (Goodman), Served 2/7/14; pending 16. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA001776 AJ (Goodman), Served 2/18/14; pending 17. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA01833 AJ (Goodman), Served 2/21/14; pending 18. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA002311 AN (Cox), Served 3/11/14; pending 19. Martin E. O'Boyle vs Town of Gulf Stream, Case No. 502014CA002728 AO (Brunson), Served 3/14/14; pending 20. Stopdirtygovernment, LLC vs Town of Gulf Stream, Case No. 502014CA003721 AH (Small), Served 3/31/14; pending 21. Martin E. O'Boyle vs Town of Gulf Stream, Case No. 502014CA004474 AA (Blanc), Served 4/15/14; pending 22. Martin E. O'Boyle vs Town of Gulf Stream, Case No. 502014 CA 005189 AE (Ticktin), Served 5/6/14; pending 23. Martin E. O'Boyle and Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA005628 AA (Blanc), Served 5/12/14; pending 24. Citizens Awareness Foundation, Inc. vs Town of Gulf Stream and Brannon Gillespie, LLC, Case No. 502014CA006112 AG (Hafele), Served 5/22/14; pending 25. Citizens Awareness Foundation, Inc. vs Town of Gulf Stream, Case No. 502014CA006360 AN (Cox), Served 5/30/14; pending 26. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 502014CA006848 AB (Barkdull), Served 6/11/14; pending 27. CG Acquisition Company, Inc. vs Town of Gulf Stream, Case No: 502014CA007123 AA (Blanc), Served 6/16/14; pending 28. Martin E. O'Boyle vs Town of Gulf Stream, Case No: 502014CA008076 AD (Gregory Keyser), Served 7/3/14; pending 29. Christopher F. O'Hare vs Town of Gulf Stream, Case No: 502014CA008142 AB (Barkdull), Served 7/7/14; pending 2 30. Christopher F. O'Hare vs Town of Gulf Stream, Case No: 502014CA008327 AF (Janis Keyser), Served 7/10/14; pending 31. Christopher F. O'Hare vs Town of Gulf Stream, Case No: 502014CA007516 AD (Gregory Keyser), Served 7/17/14; pending 32. Stopdirtygovernment, LLC and Martin E. O'Boyle vs Town of Gulf Stream, Case No: 502014CC008529 RL (Panse), Served 7/25/14; pending 33. Asset Enhancement, Inc. vs Town of Gulf Stream, Case No: 502014CA010216 AF (Janis Keyser), Served 8/21/14; pending 34. MARTIN E. O'BOYLE, AIRLINE HIGHWAY, LLC, a domestic organization, COMMERCE GROUP, INC., a domestic corporation, COMMERCE REALTY GROUP, INC., a domestic corporation, and CRO AVIATION, INC., a domestic corporation, OUR PUBLIC RECORDS, LLC., a domestic limited liability company, and CG ACQUISITION COMPANY, INC. a domestic corporation, Case No. 2014CA011940 AO (Brunson), Served 10/17/14; pending 35. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 2014CC010685 RE (Nancy Perez, J., County Court), Served 11/11/14; pending 36. Christopher F. O'Hare vs Town of Gulf Stream, Case No. 2014CC010712 RB (Ted Booras, J., County Court), Served 11/11/14; pending 37. Martin O'Boyle vs Jones Foster Service, LLC and Town of Gulf Stream, Case No. 14 -14780 (17th JDC, County Court), Served 12/31; amended 1/13/15 38. Martin O'Boyle vs Gulf Stream, Case No. 2014CC015050 RL, Served 1/7/15; pending 39. Christopher O'Hare vs Gulf Stream, Case No. 2014CC012269 RJ, Served 1/10/15; pending 43. Christopher O'Hare vs Gulf Steam, Case No. 2014CC012274RF, Served 1/10/15; pending OTHER CASES 1. Chris O'Hare vs Town of Gulf Stream; Town of Gulf Stream Commission; Town Manager William Thrasher; Town Special Magistrate Lara Donlon; Officer David Ginsberg; Sergeant Adam Gorel; Steven Tobias and Marty Minor (S.D. Fla. Case No. 13 -CV -81053 KLR); served 10/17/13; pending 2. Christopher F. O'Hare vs Town of Gulf Stream and William H. Thrasher, Jr., Case No. 2014CA000720 Al (Sasser); filed 1/20/14; pending 3 3. Martin E. O'Boyle vs Town of Gulf Stream, Case No. 14 -80317 CIV (S.D. Fla.) (Middlebrooks); filed 3/5/14; pending 4. Christopher F. O'Hare vs Town of Gulf Stream, Case No: 502014CA007327 AY (Certiorari); served 6/27/14; pending 5. Martin E. O'Boyle vs Robert A. Sweetapple and Mayor Scott Morgan, Case No. 9:14 -cv- 81250 -KAM (S.D. Fla.) (Marra);Served 9/15/14; pending 6. Martin O'Boyle vs William Thrasher, Garret Ward and Town of Gulf Stream (42 U.S.C. 1983; battery; assault); USDC Case No. 9:14 -cv- 81248 -DTKH (Hurley /Hopkins); served 9/30/14; pending 8. Martin E. O'Boyle v Town of Gulf Stream, Case No. 502015Ca001498XXXXMB AI (Sasser); Filed 02/06/15; pending 9. Town of Gulf Stream/Wantman Group, Inc. v Martin O'Boyle, Case No: 9:15 -cv- 80182 KAM (S.D. Fla.); filed 02/12/15 10. Martin O'Boyle /Asset Enhancement v Town of Gulf Stream, Morgan, JCR, Sweetapple and JMO, Case No: 502015CA001737XXXXMB AJ (Goodman); Filed 02/12/15; pending. pAdocs \13147100033\doc \t m59435.docz .Q TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail May 21, 2015 Asset Enhancement, Inc. [mail to: records @commerce - group.com], Re: GS #1838 (1081, 1082, 1083, 1084) 1. Please provide copies of all communications sent by or received by either Jones Foster Johnston & Stubbs, P.A. and for the Town of Gulf Stream (including its partners, attorneys, employees, paralegals and legal secretaries including administrative personnel, as well as the Town of Gulf Stream's Commissioners, employees, managers and Police) for the period from January 1, 2014 to the date of this Request. 2. Provide all copies of all billings and payments from and to Richman Greer, P.A. by the Town of Gulf Stream or by Robert Sweetapple or Sweetapple Broeker & Farkas (but as to Robert Sweetapple or Sweetapple Broeker & Yarkas only ifsuch billings and payments relate to the Town of Gulf Stream or any of its Commissioners, employees, managers and Police). This Request is made for the period November 2, 2014 to the date of this Request. Dear Asset Enhancement, Inc. [mail to: records(a.commerce- groun.coml, The Town of Gulf Stream and its outside counsel at Jones, Foster, Johnston & Stubbs, P.A., Sweetapple, Broeker & Varkas, and Richman Greer P.A. received your public records requests on April 24, 2015. You should be able to view your original requests at the following link httv://www2.gulf-streain.org/weblink/O/doc/48077/Paizel.aspx. In future correspondence, please refer to this public records request by the above referenced numbers. Request #1 for Communications since January 1 2014 As to Request #1, your request for "all communications" sent or received by the Town or its outside counsel at Jones Foster Johnston & Stubbs, P.A. ( "Jones Foster ") for the 16 -month period from January 1, 2014 to the date of the request on April 24, 2015 is extremely broad. During that time period, the Town received more than 1,300 public records requests, in addition to conducting the business of municipal government. Furthermore, your request is extremely vague, ambiguous, and overbroad and seeks documents far beyond those affiliated with any public entity including the Town of Gulf Stream, as it not only seeks documents relating to identified topics or clients, but seeks all documents sent or received by certain persons regardless of the content or relationship to a particular client or matter. In this manner, your request encompasses documents that are not public records and which may be protected by the attorney client and work product privileges. For those reasons, the Town and its counsel reject your request for documents beyond those limited public records which may be permissibly obtained. Moreover, and as you are well aware, as of April 24, 2015, dozens of lawsuits had been filed and remain pending against the Town of Gulf Stream. A list of those suits is attached at the same above link. Your request thus also encompasses documents prepared by the Town's attorneys exclusively for the litigation or in anticipation of imminent litigation and that reflect the mental impressions, conclusions, litigation strategies, or legal theories of the Town's attorney or the Town and would be exempt under Florida Statute 119.0171(1)(d)I until the conclusion of the litigation by and between the individuals and entities identified on the attached list. To search for responsive communications, assess whether they constitute public records and determine if any exemption applies will require significant time and expense. The Town estimates 16 hours of administrative support at $36.39 per hour and at least 8 hours of attorney support to review for exemptions related to ongoing litigation at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § I I9.07(4)(d). (40 hours @ 36.39 = 1,455.60) - (.25 hour @ 36.39= 9.10) + (16 hours @ 235.00 = 3,760) _ Deposit Due: $5,206.50 in cash or check. If you would like to narrow the scope of your request, for example, by identifying a particular document type or date range, the Town may be able to provide these records at a lower cost. Please note that many public records requests have been made for "communications" to and from the Town during the past 18 months. As you are aware, all of the public records requests made to the Town and responses provided to those requests to date are available on the Town's website. To determine whether particular communications have previously been requested and whether such communications exist and have been produced, you can go to the Town's website and search the Public Records Logs for 2014 and 2015 for "communications" and then go to the individual public records request by number to review the response provided. Request #2 for Billings/Payments to Richman Greer Documents responsive to this request are available at the following link http://www2.gulf- stream.org/weblink/O/doc/48077/Pagel.aspx. The Town of Gulf Stream is currently working on a large number of incoming public records requests. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. Sincerely, Town Clerk TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail May 21, 2015 Asset Enhancement, Inc. [mail to: records@commerce-group.com], Re: GS #1838 (1081, 1082,1083,1084) 1. Please provide copies of all communications sent by or received by either Jones Foster Johnston &Stubbs, P.A. andlor the Town of Gulf Stream (includingitspartners, attorneys, employees, paralegals and legal secretaries including administrative personnel, as well as the Town of Gulf Stream's Commissioners, employees, managers and Police) for the period from January 1, 1014 to the date of this Request. 1. Provide all copies of all billings and payments from and to Richman Greer, P.A. by the Town of Gulf Stream or by Robert Sweetapple or Sweetapple Broeker & Farkas (but as to Robert Sweetapple or Sweetapple Broeker & Farkas only if such billings and payments relate to the Town of Gulf Stream or any of its Commissioners, employees, managers and Police). This Request is made for the period November 2, 1014 to the date of this Request. Dear Asset Enhancement, Inc. [mail to: recordsiia commerce-group.coml, The Town of Gulf Stream and its outside counsel at Jones, Foster, Johnston & Stubbs, P.A., Sweetapple, Broeker & Varkas, and Richman Greer P.A. received your public records requests on April 24, 2015. You should be able to view your original requests at the following link http://www2.gulf-stream.org/weblink/0/doc/48077/Pa el asnx. In future correspondence, please refer to this public records request by the above referenced numbers. Request #1 for Communications since January 1, 2014 As to Request #1, your request for "all communications" sent or received by the Town or its outside counsel at Jones Foster Johnston & Stubbs, P.A. ("Jones Foster") for the 16 -month period from January 1, 2014 to the date of the request on April 24, 2015 is extremely broad. During that time period, the Town received more than 1,300 public records requests, in addition to conducting the business of municipal government. Furthermore, your request is extremely vague, ambiguous, and overbroad and seeks documents far beyond those affiliated with any public entity including the Town of Gulf Stream, as it not only seeks documents relating to identified topics or clients, but seeks all documents sent or received by certain persons regardless of the content or relationship to a particular client or matter. In this manner, your request encompasses documents that are not public records and which may be protected by the attorney client and work product privileges. For those reasons, the Town and its counsel reject your request for documents beyond those limited public records which may be permissibly obtained. Moreover, and as you are well aware, as of April 24, 2015, dozens of lawsuits had been filed and remain pending against the Town of Gulf Stream. A list of those suits is attached at the same above link. Your request thus also encompasses documents prepared by the Town's attorneys exclusively for the litigation or in anticipation of imminent litigation and that reflect the mental impressions, conclusions, litigation strategies, or legal theories of the Town's attorney or the Town and would be exempt under Florida Statute 119.0171(1)(d)I until the conclusion of the litigation by and between the individuals and entities identified on the attached list. To search for responsive communications, assess whether they constitute public records and determine if any exemption applies will require significant time and expense. The Town estimates 16 hours of administrative support at $36.39 per hour and at least 8 hours of attorney support to review for exemptions related to ongoing litigation at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). (40 hours @ 36.39 =1,455.60) - (.25 hour @ 36.39= 9.10) + (16 hours @ 235.00 = 3,760) _ Deposit Due: $5,206.50 in cash or check. If you would like to narrow the scope of your request, for example, by identifying a particular document type or date range, the Town may be able to provide these records at a lower cost. Please note that many public records requests have been made for "communications" to and from the Town during the past 18 months. As you are aware, all of the public records requests made to the Town and responses provided to those requests to date are available on the Town's website. To determine whether particular communications have previously been requested and whether such communications exist and have been produced, you can go to the Town's website and search the Public Records Logs for 2014 and 2015 for "communications" and then go to the individual public records request by number to review the response provided. Request #2 for Billings/Payments to Richman Greer Documents responsive to this request are available at the following link hn://www2.gulf- streain.org/weblink/O/doc/48077/Pagel.asvx The Town of Gulf Stream is currently working on a large number of incoming public records requests. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. Sincerely, Town Clerk Kelly Avery From: Bill Thrasher Sent: Thursday, May 21, 2015 3:52 PM To: 'Records' Subject: GS #1838 (1081, 1082, 1083, 1084) Attachments: GS #1838 (1081, 1082, 1083, 1084)_dep.pdf Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business are public records available to the public upon request. Your e-mail communications are therefore subject to public disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing. CORRECTION TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -mail May 21, 2015 Asset Enhancement, Inc. [mail to: records@commerce-group.com], Re: GS #1838 (1081,1082,1083,1084) 1. Please provide copies of all communications sent by or received by either Jones Foster Johnston & Stubbs, P.A. andlor the Town of Gulf Stream (including its partners, attorneys, employees, paralegals and legal secretaries including administrative personnel, as well as the Town of Gulf Stream's Commissioners, employees, managers and Police) for the period from January 1, 2014 to the date of this Request. 2. Provide all copies of all billings and payments from and to Richman Greer, P.A. by the Town of Cnelf Stream or by Robert Sweetapple or Sweetapple Broeker & Farkas (but as to Robert Sweetapple or Sweetapple Broeker & Farkas only if such billings and payments relate to the Town of Gulf Stream or any of its Commissioners, employees, managers and Police). This Request is made for the period November 2, 2014 to the date of this Request. Dear Asset Enhancement, Inc. [mail to: recordsOcommerce-aroup.coml, The Town of Gulf Stream and its outside counsel at Jones, Foster, Johnston & Stubbs, P.A., Sweetapple, Broeker & Varkas, and Richman Greer P.A. received your public records requests on April 24, 2015. You should be able to view your original requests at the following link hU://www2.gulf-stream.org/weblink/O/doc/48077/Pagel.aspx. In future correspondence, please refer to this public records request by the above referenced numbers. Request #1 for Communications since January 1 2014 As to Request #1, your request for "all communications" sent or received by the Town or its outside counsel at Jones Foster Johnston & Stubbs, P.A. ("Jones Foster") for the 16 -month period from January 1, 2014 to the date of the request on April 24, 2015 is extremely broad. During that time period, the Town received more than 1,300 public records requests, in addition to conducting the business of municipal government. Furthermore, your request is extremely vague, ambiguous, and overbroad and seeks documents far beyond those affiliated with any public entity including the Town of Gulf Stream, as it not only seeks documents relating to identified topics or clients, but seeks all documents sent or received by certain persons regardless of the content or relationship to a particular client or matter. In this manner, your request encompasses documents that are not public records and which may be protected by the attorney client and work product privileges. For those reasons, the Town and its counsel reject your request for documents beyond those limited public records which may be permissibly obtained. h CORRECTION Moreover, and as you are well aware, as of April 24, 2015, dozens of lawsuits had been filed and remain pending against the Town of Gulf Stream. A list of those suits is attached at the same above link. Your request thus also encompasses documents prepared by the Town's attorneys exclusively for the litigation or in anticipation of imminent litigation and that reflect the mental impressions, conclusions, litigation strategies, or legal theories of the Town's attorney or the Town and would be exempt under Florida Statute 119.0171(1)(d)1 until the conclusion of the litigation by and between the individuals and entities identified on the attached list. To search for responsive communications, assess whether they constitute public records and determine if any exemption applies will require significant time and expense. The Town estimates 40 hours of administrative support at $36.39 per hour and at least 16 hours of attorney support to review for exemptions related to ongoing litigation at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § I I9.07(4)(d). (40 hours @ 36.39 =1,455.60) - (.25 hour @ 36.39= 9.10) + (16 hours @ 235.00 = 3,760) _ Deposit Due: $5,206.50 in cash or check. If you would like to narrow the scope of your request, for example, by identifying a particular document type or date range, the Town may be able to provide these records at a lower cost. Please note that many public records requests have been made for "communications" to and from the Town during the past 18 months. As you are aware, all of the public records requests made to the Town and responses provided to those requests to date are available on the Town's website. To determine whether particular communications have previously been requested and whether such communications exist and have been produced, you can go to the Town's website and search the Public Records Logs for 2014 and 2015 for "communications" and then go to the individual public records request by number to review the response provided. Request #2 for Billings/Payments to Richman Greer Documents responsive to this request are available at the following link http://WWW2.g-ulf- stream.org/weblink/0/doc/48077/Pagel.aspx. The Town of Gulf Stream is currently working on a large number of incoming public records requests. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. Sincerely, Town Clerk Kelly Avery From: Bill Thrasher Sent: Thursday, May 28, 2015 3:33 PM To: 'Records' Subject: GS #1838 (1081, 1082, 1083, 1084)- correction Attachments: GS #1838 (1081, 1082, 1083, 1084)_depcorrection.pdf Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business are public records available to the public upon request. Your e-mail communications are therefore subject to public disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing.