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.