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Home My Public Portal AboutPRR 15-1993From: Jonathan O'Boyle[mailto:ioboyle(oboboylelawfirm.comj Sent: Monday, October 12, 2015 1:02 PM To: OConnor, Joanne M. Cc: Maria Sciolto Alvarez Subject: RE: Records Request - JRO 7/14/15 Hey Joanne, I am writing to get back to you on the records request. First, is there anything else out there with regard to the Board of Bar Examiners? This request can now take the slow route so I would categorize it as a "low priority." Second, I disagree that Jones Foster or Mr. Sweetapple's firm are "outside counsel." As such, if records exists that concern ethical rules that I have referenced previously, I would kindly ask that you let me know that they exist and state a basis for why the Town or JF thinks that such records do not constitute public records — I think that is fair under Due Process and a reasonable good -faith response. Then I can make a determination as to whether to alert the Attorney General's office for mediation or — as per usual, I suggest that the Town seek an advisory opinion from the Attorney General. I would consider this one a "low priority." Third, I would kindly ask that text messages, voicemails, memoranda, or whatever reflecting my UPL File or Character and Fitness be released. Both investigations are now over, yet according to the Bar Rules, neither was adversarial with respect to the Town. Additionally I want to alert you again that insofar as those records reflect litigation strategy or were used for other purposes, it is my position that they are releasable. Again "low priority." I will note that under Chapter 119, searches are not compensable, if you intend to assess a special "search" charge, please let me know the Town's authority so I can reconsider. Fourth, I would like a copy of a records request I made to Rita Taylor in the fall/winter of 2013. I cannot right now remember what was in it precisely, but I remember she made me write it out on a piece of yellow notebook paper (Legal Size if I remember) and it references being put on the "bad list" with Mr. O'Hare. I know it is the only request I made by hand in 2013 so that should be enough information to locate the record. It is a one -pager. "Mid - Priority." Penultimately, there was an incident at Town Hall regarding Martin O'Boyle on September 22, 2015 at the Town Hall Meeting. I would like any incident reports or charging documents that stemmed from that incident including the drafts or memoranda reflecting the Town's version of the events and decisions regarding what charges to make against Matin O'Boyle — this includes any video, audio, or writings which reflect the events. I want to put you on notice that I will likely be asking for all public records generated from that incident as well as the employment file and application of the officers involved as well as any other Brady information — but not yet. For now, I am also seeking whatever manual's are out there reflecting the Town's policing policies/ employment policies as well as any policies reflecting the Town's ADA or Federal Rehabilitation Act duties: "High Priority." Lastly, I am requesting all Lexis reports run on myself, or any of the Defendant's in the RICO suit as well as their friends, family, or entities. I also want any public records reflecting the authority to run those reports, or the direction from the Town. Additionally, I want all public records generated subsequent to those reports that discuss those reports. As I stated previously, I have asked for information about a week or so ago, I heard nothing, so I am following up with this request. I want to know everything about my report, other reports, and what was said prior and subsequent to those reports regarding the same. I hope that helps you understand my request better. To be clear I am asking for these records under the Florida Constitution, Chapter 119, and the common law right of access/right to know. While my motivations are irrelevant under the positive Florida Laws, I have worked with the common law right to know before, there motivation is relevant and the test for what constitutes a public record is more broad, so let me explain. I believe that numerous criminal acts have been committed to attain my federally protected private information, I have a compelling interest in understanding why my privacy rights have been violated and if it has occurred to other individuals so that I can take the appropriate action to preserve my privacy rights and make efforts to stop any unlawful behavior. If the Town does not believe those records are public, again please explain. If the Town believes that they have an interest in non -disclosure, please explain. I will note that I just need the first page of the reports and the name of the individual — all else can be redacted to ameliorate any privacy interests in non -disclosure. Although I am going two-steps ahead here, I also have no intent to publish anyone else's reports (which should ameliorate the Town's interest in non -disclosure further) but I reserve the right to bring them to the appropriate State/Federal judicial/executive branches. "High Priority." As always, I do not wish to incur fees without my consent and we can discuss a production schedule if necessary. Also, if you need any clarification or spot a record that you think might be responsive but are not sure, let me know and we can work it out accordingly. Thanks. From: OConnor, Joanne M.[mailto:JOConnor@jonesfoster.com] Sent: Friday, October 16, 2015 1:13 PM To: Jonathan O'Boyle <joboyle@oboylelawfirm.com> Cc: Maria Sciolto Alvarez <malvarez@dldlawyers.com>; Kelly Avery <kavery@gulf-stream.org> Subject: RE: Records Request -JRO 7/14/15 Jonathan — In response to your fourth item below, the public records request you assert was made in fall/winter 2013, please advise that the Town possesses no responsive record. I note that the General Records Schedule GS1-SL addresses Item #23 "Information Requests" and provides for a 1 year retention schedule for public records requests. The Town considers its response to this request to be complete. Regards, Joanne JONESFOSTER jofl.%=N&M. Ri.P.L Joanne M. O'Connor Attorney Direct Dial: 561.650.0498 1 Pas: 561.650.5300 1 joconnor@ionesfoster.com Jones, Foster, Johnston & Stubbs, P.A. 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