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Home My Public Portal AboutPRR 15-2000RECORDS REQUEST (the "Request") Date of Request: 10/16/15 Requestor's RequestID#: REQUESTEE: 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(& commerce-grouc.com: Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide a copy of all pleadings related to all litigations between the Town of Gulf Stream and any other carry beginning January 1. 2010 and through October 16, 2015. ADDITIONAL INFORMATION REGARDING REQUEST: The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its Commissioners. its Manager, its employees. its Police_ Department, its Police Officers and its Counsel (including, without limitation, the following law firms) Sweetaoole. Broeker & Varkus; Richman Greer. PA: and Jones. Foster, Johnston & Stubbs. (including, without limitation, the attorneys, emplovees and partners of each such law firm.) THIS REQUEST IS MADE PURSUANT TO ARTICLE 1, 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 6119.01(2)(F). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON 1I 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 III 19.07(I)(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 AL1. 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 Requester approve of any costs, asserted by the Agency (as defined In Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs Imposed to the Requestar 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". UP/NP/FLRR 07.28.2015 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 12, 2015 Commerce Group, Inc. (mail to: records(a,commerce-sroun.coml Re: GS #2000 (1152), 2001 (1151), 2002 (1150), 2003 (1142) Provide a copy of all pleadings related to all litigations between the Town of Gulf Stream and any other parry beginning January 1, 2010 and through October 16, 2015. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its Commissioners, its Manager, its employees, its Police Department, its Police Officers and its Counsel (including, without limitation, the following law firms) Sweetapple, Broeker & Yarkus; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm.) Provide a copy of all depositions related to all litigations between the Town of Gulf Stream and (a) Martin O'Boyle (b) Chris O'Hare (c) the aliases of Martin O'Boyle and/or Chris O'Hare (as such aliases are determined by the Town of Gulf Stream) during the period beginning January 1, 2010 and through October 16, 2015. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its Commissioners, its Manager, its employees, its Police Department, its Police Officers and its Counsel (including, without limitation, the following law firms) Sweetapple, Broeker & Yarkus; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm) Provide a copy of any claims (including counterclaims) initiated by the Town of Gulf Stream against any of the following: (a) Martin O'Boyle (b) Chris O'Hare and (c) the aliases of Martin O'Boyle and/or Chris O'Hare (as such aliases are determined by the Town of Gulf Stream) during the period beginning January 1, 2012 and through October 16, 2015. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its Commissioners, its Manager, its employees, its Police Department, its Police Officers and its Counsel (including, without limitation, the following law firms) Sweetapple, Broeker & Yarkus; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm) Provide copies of all records (including, without limitation, communications and transcripts) wherein Joel Chandler was a Sender or Receiver; and the Town of Gulf Stream was a Sender or Receiver for the period January 1, 2013 through October 16, 2015 which are in possession of the Town of Gulf Stream. The term "Town of Gulf Stream " shall mean each of the following: the Town of Gulf Stream, its Commissioners, its Manager, its employees, its Police Department, its Police Officers and its Counsel (including, without limitation, the following law firms) Sweetapple, Broeker & Varkus; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm) Dear Commerce Group, Inc. [mail to: recordsna,commerce-group.coml, The Town of Gulf Stream has received your public records requests dated October 16, 2015. The original public record request can be found at the following link: http://www2.gulf- stream.org/weblink/0/doc/68567/Pagel.asyx http://www2.gulf- stream.org/weblink/0/doc/68569/Pagel.upxx http://www2.gulf- stream.org/weblink/0/doc/68571/Pagel.aspx, and http://www2.gulf- stream.org/weblink/0/doc/68584/Pagel.aspx. 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 TOWN OF GULF STREAM PENDING LITIGATION PUBLIC RECORD SUITS 1. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CA015012 AJ 2. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CAOI5380 AF Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CA016864 AD 4. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CAOI7717 AA 5. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CA017793 AA 6. Christopher F. O'Hare vs Town of Gulf Stream (15fl' Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CAOI8093 AA Christopher F. O'Hare vs Town of Gulf Stream (151h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CAOI8095 AA 8. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CA018098 AA 9. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502013CAO18100 AA 10. Christopher F. O'Hare vs Town of Gulf Stream (151h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No.502013CA018101 AA 11. Christopher F. O'Hare vs Town of Gulf Stream (15 h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA000824 AA 12. Christopher F. O'Hare vs Town of Gulf Stream (15"' Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA000835 AG 13. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA000894 AA 14. Martin E. O'Boyle vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA000834 AH 15. Martin E. O'Boyle vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA001572 AJ 16. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA00I776 AA 17. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA01833 AA 18. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA002311 AA 19. Martin E. O'Boyle vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA002728 AO 20. Stopdirtygovernment, LLC vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA003721 AH 21. Martin E. O'Boyle vs Town of Gulf Stream/ Town of Gulf Stream vs Martin E. O'Boyle, Ryan Witmer, Christopher O'Hare, William Ring, Jonathan R. O'Boyle, Denise DeMartini, Public Awareness Institute, Inc., Citizens Awareness Foundation, Inc., Our Public Records, LLA, Stopdirtygovemment, LLC, Commerce Group, Inc. and the O'Boyle Law Firm, P.C., Inc. (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA004474 AA 2 22. Martin E. O'Boyle vs Town of Gulf Stream (15 h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014 CA 005189 AE 23. Martin E. O'Boyle and Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA005628 AA 24. Citizens Awareness Foundation, Inc. vs Town of Gulf Stream and Brannon Gillespie, LLC (15 h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA006112 AG 25. Citizens Awareness Foundation, Inc. vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA006360 AA 26. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA006848 AA 27. CG Acquisition Company, Inc. vs Town of Gulf Stream (15Th Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 502014CA007123 AA 28. Martin E. O'Boyle vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 502014CA008076 AD 29. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 502014CA008142 AB 30. Christopher F. O'Hare vs Town of Gulf Stream (15'h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 502014CA008327 AF 31. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 502014CA007516 AA 32. Stopdirtygovernment, LLC and Martin E. O'Boyle vs Town of Gulf Stream (Cty. Ct. in and for Palm Beach Cty., Fla.) Case No: 502014CC008529 RL 3 33. Asset Enhancement, Inc. vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 502014CA010216 AF 34. Martin E. O'Boyle, Airline Highway, LLC, Commercial Group, Inc., Commercial Realty Group, Inc., CRO Aviation, Inc., Our Public Records, LLC, CG Acquisition Company, Inc. vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 2014CA011940 AO 35. Christopher F. O'Hare vs Town of Gulf Stream (Cty. Ct. in and for Palm Beach Cty., Fla.) Case No. 2014CC0I0685 RE 36. Christopher F. O'Hare vs Town of Gulf Stream (Cty. Ct. in and for Palm Beach Cty., Fla.) Case No. 2014CC010712 RB 37. Martin O'Boyle vs Jones Foster Service, LLC and Town of Gulf Stream Case No. 14-14780 (17`h Jud. Cir. in and for Broward Cty., Fla.) 38. Martin O'Boyle and Asset Enhancement, Inc. vs Town of Gulf Stream/ Town of Gulf Stream vs Martin E. O'Boyle, Ryan Witmer, Christopher O'Hare, William Ring, Jonathan R. O'Boyle, Denis DeMartini, Asset Enhancement, Inc. and The O'Boyle Law Firm, P.C., Inc. (15'h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 2015CA004564 AA 39. Christopher O'Hare vs Town of Gulf Stream/ Town of Gulf Stream vs Christopher O'Hare, Ryan Witmer, Martin E. O'Boyle, William Ring, Jonathan R. O'Boyle, Denis DeMartini, 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. (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 2015CA006710 AA 40. Christopher F. O'Hare vs Town of Gulf Steam (15a' Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 2015CA006067 AA 4 OTHER CASES Chris O'Hare vs Town of Gulf Stream, Town of Gulf Stream Commission; Town Manager, William Thrasher; Town Special Magistrate Laza Donlon; Officer David Ginsberg; Sergeant Adam Gorel; Steven Tobias and Marty Minor USDC Case No. 13 -CV -81053 KLR 2. Christopher F. O'Hare vs Town of Gulf Stream and William H. Thrasher, Jr. (IP Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 2014CA000720 Al 3. Martin E. O'Boyle vs Town of Gulf Stream USDC Case No. 14-80317 CIV Middlebrooks 4. Town of Gulf Stream vs Christopher F. O'Hare (151h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CA004631 AE 5. Christopher F. O'Hare vs Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 502014CA007327 AY 6. Martin E. O'Boyle vs Robert A. Sweetapple and Mayor Scott Morgan (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CAO11052 AO Martin O'Boyle vs William Thrasher, Garret Ward and Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502014CAO11806 AB 8. Martin E. O'Boyle v Town of Gulf Stream (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No. 502015Ca001498X)CXXMB AI 9. Town of Gulf Stream and Wantman Group, Inc. vs. Martin O'Boyle, Christopher O'Hare, Jonathan R. O'Boyle, Denies DeMartini, Giovani Mesa, Nicklaus Taylor, Ryan Witmer, Arline 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., Put Public Records, LLC, Stopdirtygovemment, LLC, Commerce Group, Inc. and The O'Boyle Law Finn, P.C., Inc., USDC Case No: 9:15-cv-80182 KAM 10. Martin E. O'Boyle and Asset Enhancement, Inc. vs. The Town of Gulf Stream, Scott Morgan, John C. Randolph, Robert Sweetapple, Joanne O'Connor (15`h Jud. Cir. in and for Palm Beach Cty., Fla.) Case No: 2015CA001737 AJ p:\dws\ 13147\00033\dm\ I nh4967. dmx 0 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 30, 2015 Commerce Group, Inc. [mail to: records@commerce-group.com] Re: GS #2000 (1152) Provide a copy of all pleadings related to all litigations between the Town of Gu f Stream and any other parry beginning January 1, 2010 and through October 16, 2015. The tern: "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its Commissioners, its Manager, its employees, its Police Department, its Police Officers and its Counsel (including, without limitation, the following law firms) Sweetapple, Broeker & Yarkus; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm.) Dear Commerce Group, Inc. [mail to: records(i�commerce-sroumcoml, The Town of Gulf Stream received your public records request on October 16, 2015. You should be able to view your request at the following link http://www2.gulf- stream.org/weblink/0/doc/68567/Paeel.asox. In future correspondence, please refer to this public records request by the above referenced numbers. As you are aware, the Town has been involved in more than 50 lawsuits during the time period you referenced. A chart detailing those cases is available at the same above link. The Town has made available online a significant number of the complaints and counterclaims as well as other pleadings provided to it by the Town's outside counsel. You can find those by going to www.eulf- stream.oreclick on "Find a Town Record", click on "Legal", and then you can click on any of the folders listed to see the lawsuits that have been filed. The Town disputes that pleadings in the possession of the outside counsel, which have not been shared with Town employees or staff, are public records. Notwithstanding its objection, the Town responds that to gather and produce all of the records you seek will require extensive use of clerical or supervisory assistance. You are responsible for the cost 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. The Town estimates that to respond to your request for "all pleadings" would involve at least 1 hour of time per case, some cases may require more or less time. If there are particular cases on the attached chart for which you seek proceedings, please clarify and the Town will provide a more specific estimate. The Town has already spent in excess of 15 minutes on this request. The Town estimates the need for 50 hours of administrative support at $40.51 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(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. (50hours @ 40.51= 2,025.50) = Deposit Due: $2,025.50 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