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Home My Public Portal AboutPRR 15-1930REQUESTEE: RECORDS REQUEST (the "Request") Date of Request: 9/17/15 Requestor's Request ID#: 1109 Custodian of Records Town of Gulf Stream REQUESTOR: Commerce Group, Inc. REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com Fax: 954-360-0807 or Contact Records Custodian at records(ailcommerce->3'ouo.com; Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide copies of all records (excluding invoices and payments) where Gerald F. Richman, Esquire (or anyone from the law firm of Richman Greer, PA.) were the creator, preparer, the sender, the receiver or were, at any time, in possession of any such records for the period begnning January 1, 2015. The records referred to shall relate only to the Town of Gulf Stream and the Racketeering Suit (which was filed in Federal Court in Palm Beach County) wherein the Town of Gulf Stream was the Plaintiff and Martin O'Boyle, et al. was the Defendant. ADDITIONAL INFORMATION REGARDING REQUEST: THIS REQUEST IS MADE PURSUANT TO ARTICLE I, 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 V 19.01(2)(F). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER. NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2) ALSO PLEASE TAKE NOTE OF §119.07(O(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT -IF A CIVIL ACTION IS INSTITUTED WITHIN THE 30 -DAY PERIOD TO F.NFORC1:'1 HE PROVISIONS OF THIS SECTION WITH RESPECI' TO THE REQUESTED RECORD, TIIE 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 (Definitions)), in advance of any 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 0728.2015 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 25, 2015 Commerce Group, Inc. [mail to: recordsacommerce-eroup.coml Re: GS #1930 (1109) Please provide copies of all records (excluding invoices and payments) where Gerald F. Richman, Esquire (or anyone from the law firm of Richman Greer, P.A) were the creator, preparer, the sender, the receiver or were, at any time, in possession of any such records for the period beginning January 1, 2015. The records referred to shall relate only to the Town of Gulf Stream and the Racketeering Suit (which was filed in Federal Court in Palm Beach County) wherein the Town of Gulf Stream was the Plaintiff and Martin O'Boyle, et al. was the Defendant. Dear Commerce Group, Inc. [mail to: records(@commerce-eroup.coml, The Town of Gulf Stream has received your public records requests dated September 17, 2015. The original public record request can be found at the following link: http://www2.gulf- stream.org/weblink/O/doc/65552/Pagel.asox. Please refer to the referenced number above with any future correspondence. 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 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail October 2, 2015 Commerce Group, Inc. [mail to: records@commerce-group.com] Re: GS #1930 (1109) Please provide copies of all records (excluding invoices and payments) where Gerald F. Richman, Esquire (or anyone from the law firm of Richman Greer, P.A) were the creator, preparer, the sender, the receiver or were, at any time, in possession of any such records for the period beginning January 1, 2015. The records referred to shall relate only to the Town of Gulf Stream and the Racketeering Suit (which was filed in Federal Court in Palm Beach County) wherein the Town of Gulf Stream was the Plaintiff and Martin O'Boyle, et al. was the Defendant. Dear Commerce Group, Inc. [mail to: records(a)commerce-group.coml, The Town of Gulf Stream received your public records requests on September 17, 2015. You should be able to view your original requests at the following link httv://www2.gulf- stream.org/weblink/0/doc/65552/Pagel.asi)x. In future correspondence, please refer to this public records request by the above referenced numbers. The Town may incur expenses for the production of documents. You are responsible for the costs of duplication, as allowed by Chapter 119, Florida Statutes, and you may also incur a special service charge for the labor needed to respond to this request. As you are aware, Gerry Richman, Esq. and the law firm of Richman, Greer, P.A. represent the Town of Gulf Stream in the pending litigation styled Town of Gulf Stream and Wantman Group, Inc. v. MARTIN E. O'BOYLE, an individual, CHRISTOPHER O'HARE, an individual, WILLIAM RING, an individual, JONATHAN R. O'BOYLE, an individual, DENISE DEMARTINI, an individual, GIOVANI MESA, an individual, NICKLAUS TAYLOR, an individual, RYAN WITMER, an individual, AIRLINE HIGHWAY, LLC, COMMERCE GP, INC., CG ACQUISITION CO., INC., CRO AVIATION, INC., ASSET ENHANCEMENT, INC., COMMERCE REALTY GROUP INC., PUBLIC AWARENESS INSTITUTE, INC., CITIZENS AWARENESS FOUNDATION, INC., OUR PUBLIC RECORDS, LLC, STOPDIRTYGOVERNMENT, LLC, COMMERCE GROUP, INC., and THE O'BOYLE LAW FIRM, P.C., INC. Appeal Case No.: 15-13433- DD and District Court Case No.: 9:15-cv-80182- KAMM . The overwhelming number of public records that you seek were prepared by Mr. Richman or attorneys at his firm or at their express direction for ongoing litigation and relate to counsel's mental impression, conclusion, legal strategy, or legal theory and are therefore exempt pursuant to Fla. Stat. 119.071(1)(d) relative to the parties to that litigation. Those records will remain exempt until the conclusion of the litigation. If you would nevertheless like the Town to review all potentially responsive records for the referenced 9 month period, determine whether they are public records of the Town and further determine whether they are exempt from production under the Public Records Act, it will involve significant expense to the Town. The Town will require .5 hours of administrative support at $36.39 per hour, 4 hours of clerical support at $50.00 per hour, and 8 hours of attorney support at $235.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § I I9.07(4)(d). If the costs of producing these documents will exceed your deposit, the Town will provide you with an initial production of responsive records and an estimate for the production of any additional responsive records. If the costs of production are less than the deposit, the Town will provide you with the responsive records and a refund. (.5 hours @ 36.39 =18.20) — (.25 hours @36.39 = 9.10) + (4 hours @ 50.00 = 200.00) + (8 hours @235.00 =1880.00) = Deposit Due: $2089.10 in cash or check. 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