HomeMy Public PortalAboutPRR 15-2001RECORDS REQUEST (the "Request")
Date of Request: 10/16/15
Requestor's Request ID#: 1151
REQUESTEE: Custodian of Records Town of Gulf Stream
REQUESTOR: Commerce Group, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-igoup.com
Fax: 954-360-0807 or Contact Records Custodian at records(a,commerce-aroup.com;
Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST: Provide a cony 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'Bovle 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, 2015o
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 emnlovees. its
Police Devartment, its Police Officers and its Counsel (including, without limitation, the following law
firms) Sweetanole, Broeker & Varkus: Richman Greer, PA: and Jones. Foster. Johnston & Stubbs.
(including, without limitation, the attorneys, employees and partners of each such law firm.)
THIS REQUEST IS MADE PURSUANT TO ARTICLE L SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119,
FLORIDASTATUTES
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 4119.01(2HF). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS
RECORD_S_REQUEST BE FULFILLED ON l l 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 §119.070)(111 OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IF A CIVIL ACTION
IS INSTITUTED WITHINTHE 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 TIIE 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 of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01
(Definitions)), In advance of any costs Imposed to the Requesmr 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
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
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
December 8, 2015
Commerce Group, Inc. [mail to: records@commerce-group.com]
Re: GS #2001 (1151)
Provide a copy of all depositions related to all litigations between the Town of Gu f 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)
Dear Commerce Group, Inc. [mail to: recordsecommerce-eroun.coml,
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 htto://www2.gulf-
stream.ore/weblink/O/doc/68569/Pagel.asix. 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
disputes that depositions in the possession of the outside counsel, which have not been shared with
Town employees or staff, are public records. Notwithstanding this objection, the Town has made
available online those depositions as provided to it by the Town's outside counsel. You can find
those by going to www.gulf-stream.org, click on "Find a Town Record", click on "Legal", click
on "depositions", and then you can click on any of the folders listed to see the depositions related
to lawsuits that have been filed.
We consider this closed.
Sincerely, Town Clerk