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HomeMy Public PortalAboutRita Taylor Transcript 9/30/141 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2014 -CA -005189 AE MARTIN E. O'BOYLE, Plaintiff, VS. THE TOWN OF GULFSTREAM, Defendant. DEPOSITION OF RITA TAYLOR Tuesday, September 30, 2014 10:30 a.m. to 11:40 a.m. 100 Sea Road Gulfstream, Florida Reported By: DEBORAH LAWRENCE, Court Reporter Notary Public, State of Florida Esquire Deposition Solutions Job # 207862 ESQUIRE 800.211.DEPO (3376) EsquireSolutions.com 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 4 PROCEEDINGS Deposition taken before DEBORAH LAWRENCE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. Thereupon, (RITA TAYLOR) having been duly sworn or affirmed, was examined and testified as follows: DIRECT EXAMINATION BY MS. CAIN: Q. Please state your name for the record? A. Rita L. Taylor. Q. Ms. Taylor, where are you employed? A. I am the town clerk for the Town of Gulfstream. Q. How long have you been a clerk here in the Town of Gulfstream? A. Since 1990. Q. Now, have you ever had your deposition taken before? A. I have. Q. How many times would you say you had your deposition taken? A. Three or four probably. Q. You're familiar with the basics of what's going to go on here? ESQUIRE 800.211.DEPO (3376) EsquireSolutions.com RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 5 1 A. Sort of. 2 Q. You have been working here at Gulfstream since 3 1990. Have you always worked as town clerk? 4 A. Yes. 5 Q. Let's go prior to your employment at town clerk. 6 What did you do before working here? 7 A. I was town clerk. 8 Q. Where were you the town clerk? 9 A. Ocean Ridge. 10 Q. So right down the street? 11 A. Right. 12 Q. How long were you town clerk in Ocean Ridge? 13 A. 19 years. 14 Q. The past 29 years you served as town clerk in two 15 neighboring communities? 16 A. Longer than that. 40. 17 Q. Where were you prior to that? 18 A. I was in Indiana. 19 Q. Did you work as town clerk there also? 20 A. No, I did not. I worked for a trucking company. 21 Q. In what capacity did you work for the trucking 22 company there? 23 A. Almost anything except driving trucks or moving 24 the freight. 25 Q. Let's now ask you a little bit about your ESQUIRE 800.211.DEPO (3376) EsquireSolutions. corn 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 6 education. Did you go to college? A. I did not. job? Q. So you worked -- was the truck company your first A. No, I was working several years in a bank. Q. So you have a lot of office experience with that? A. Yes. Q. How long have you been in Florida in total? A. Since 1967. Q. Have you always lived down in Palm Beach County? A. Yes. Q. Have you ever been a party in a case before whether it be plaintiff or a defendant? Have you ever sued anyone or had to sue anyone? A. No. Q. You have never had any criminal -- have you ever had any criminal case brought against you? A. No. Q. How did you come upon getting the job as town clerk here at Gulfstream? A. Well, with the towns being close together we were all acquainted. Gulfstream was without a clerk and had been for a couple months and the then town manager, I was communicating with him over a number of years. He approached me and asked me to come to work for Gulfstream. ESQUIRE 800.211. DEPO (3376) EsquireSolutions.com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM 1 I That's what I did. September 30, 2014 7 2 Q. He asked you to come in directly as town clerk? 3 A. Yes. 9 Q. Who was the town manager back then? 5 A. Frank Flannery. 6 Q. Is he employed in any capacity in the town 7 anymore? 8 A. No. 9 Q. You said you had your deposition taken before. 10 Did you prepare for this deposition here today? 11 A. Just not really. How do you know to prepare? 12 Q. Did you have to sit down and meet with anyone 13 regarding the deposition today. 19 A. Just met with our attorney just prior. 15 Q. Just prior to it? 16 A. Yeah. 17 Q. How much time would you say met with Ms. O'Connor 18 prior to this deposition? 19 A. Half an hour. 20 Q. That was today or yesterday? 21 A. Today. 22 Q. Did you talk with anyone who is in the capacity of 23 Mr. Thrasher or any of the commissioners regarding the 29 deposition today? 25 A. None of the commissioners. Naturally Mr. Thrasher ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 8 and I have spoken. We speak every day. Q. What did you guys talk about when you talked about the deposition? A. Just public records. Q. When you say just public records any public records in particular? A. No, in general. Q. When you say you spoke did you speak about the policies of the public records did you speak about? A. Yep. Q. Can you go into more detail as to what you talked about? A. The preparation of the policy. Q. When was this conversation? A. This morning. Q. Let's move on to your position as town clerk. Can you tell me what are your basic everyday duties as town clerk? A. Well, the town clerk is keeper of the records or that is what they used to call us. Preparing agendas, taking minutes, waiting on customers, answering the telephone. Just about any type of office work that comes through the town hall. Q. 5o you say waiting on customers. What do you mean by that? Can you explain that a little bit to me? ESQUIRE 800.211.DEPO (3376) EsquireSolutions. cam RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 9 1 A. Well, we sell occupational licenses, we process 2 zoning permits. A lot of people have questions. We try to 3 help prepare applicants for various meetings. 4 Q. When you say you help out with the license or the 5 zoning do you make that decision or is it a group effort in 6 which it is decided as to whether they are approved or not 7 the licenses are approved? 8 A. If they have the proper documents there's no 9 decision to be made. We don't license them without having 10 the proper documents. 11 Q. As long as someone provides you with the proper 12 documents you just go ahead and you personally -- 13 A. -- no, no, no. There are two ladies that work 14 with me. Basically fill in. 15 Q. You said you have two ladies who work with you. 16 Who are they? 17 A. Kelly Avery and Rebecca Tew. 18 Q. How long have they been working for you? 19 A. Kelly has been here three or four years. Rebecca 20 has been here maybe a year. Maybe not quite. 21 Q. With regard to Rebecca and Kelly what are their 22 positions called? What could you call their positions here? 23 A. Kelly is deputy clerk. Rebecca is administrative 24 assistant. 25 Q. Ms. Avery, has she always worked in the capacity ESQUIRE 800.211. DEPO (3376) EsquireSolutions. com 1 2 3 9 5 6 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 10 as deputy clerk? A. As long as she has been in here, yes. Q. Always worked as deputy clerk. Is it the same case with Ms. Tew? A. Yes. Q. With regard to their duties you delegate some of your duties to them. What type of duties do you normally have them do on a daily basis? A. Rebecca handles the intake work for the zoning permits. She basically handles the contractors licensing, waits on customers if they have some questions. Answers the phone. Q. What about Ms. Avery? A. She helps me whenever mine spills over. She is the public records coordinator or the records coordinator. I forgot to tell you. Rebecca, she is handling the accounting. Before that Kelly handled the accounting so Kelly still helps out to the accounting. Q. Do you know if Rebecca has a degree in accounting or anything of that nature? A. I am not aware whether she has a degree or not but she has done that work. Q. Same with Kelly, do you know what regard to Kelly A. -- I don't know if she has a degree. She has done ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM 1 1 that work for quite a long time I understand. September 30, 2014 11 2 Q. You said Kelly was the public records coordinator. 3 Could you explain to me what that job entails? 4 A. She answers the requests that come in. Makes it a 5 record in our records. 6 Q. Do you ever have them answering any requests or 7 public records requests? 8 A. Sometimes. I basically help with collecting the 9 information. 10 Q. When you say collect the information is it 11 whatever the person asks for? 12 A. Finding it, analyzing it. 13 Q. Out of the majority of the public records requests 14 that come in who would you say -- who would you say handles 15 the majority of the public requests that come in? 16 MS. O'CONNOR: Objection. You can answer. The 17 time period is a little tricky. Are you talking now? 18 MS. CAIN: Rephrase it. 19 BY MS. CAIN: 20 Q. Within the past year or so who handles the 21 majority of the public records requests? 22 A. Well, when you say majority we all have different 23 -- handle different aspects of the same request many times. 24 With Kelly being the coordinator she probably has more 25 hands-on than any of us. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 12 Q. When you say you all handle can you explain some of the aspects you all review? Can you explain that to me exactly what you meant by that? A. Well, everything out of the material that is being requested can span over several departments or several areas. Whichever one of us is the closest with that area we try to handle that. Q. It is kind of an -- A. -- cooperative operation. Q. Effort. Now, you're allowed based on your job description or requirement, you're allowed to delegate these duties? A. Yes. Q. To other people. Who is your direct supervisor? A. Mr. Thrasher, the town manager. Q. You report basically -- do you report to him? A. Yes. Q. Any issues, everything regarding your position? A. Right. Q. How many people would you say work in your office within your area? A. Well, the two girls I mentioned. Then we have a full-time temp. Q. What's that person's name? A. Carol, I don't remember her last name. Sorry. ESQUIRE 800.211. DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 13 1 Q. It's okay. Anyone else? 2 A. Sometimes we have a part-time temp come in and 3 help with the meetings as far as taking minutes but not 4 full-time. 5 Q. Do you know his or her name? 6 A. We have different ones. 7 Q. Different? 8 A. Yeah. 9 Q. Do you use an agency to get a temp? 10 A. Yes. 11 Q. What agency do you use? 12 A. Apple. 13 Q. You say Carol is full-time. What does she do 14 within the office? 15 A. She handles public records. 16 Q. What are her hours like? Is she Monday through 17 Friday, 9 to five? 18 A. 9 to four. We don't break for lunch. 19 Q. Have you ever acted as code enforcement officer or 20 temporary town manager? 21 A. Yes. 22 Q. How many times would you say you have done that? 23 A. I wouldn't even hazard a guess. 24 Q. Would that be a lot? 25 A. When the town manager has to be away at meetings ESQUIRE 800.211.DEP0 (3376) EsquireSolutions.com 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 14 or something then I fill in for his spot. When he is on vacation. Q. Fill in? A. In Ocean Ridge we had a turnover of town managers. My tenure at that office was quite long sometimes. Q. You had acted as town manager quite often? A. Yeah. Q. You're pretty experienced at it? A. I don't think you ever get experienced being town manager. Q. Do you ever sign documents on behalf of the town manager when you're acting in that capacity? A. Yes, I do. Q. We are going to switch gears for a minute. Let's talk about the copy machine in your office. Do you know what type of copy machine you have? A. Xerox. Q. Is that the only copy machine? A. Yes. Q. During the everyday course of your job do you make copies? A. We all make copies. Q. Everyone does. What would you say you're mostly making copies of on a daily basis? A. Well, recently public records. ESQUIRE 800.211.DEPO (3376) EsquireSotutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 15 1 Q. When you say recently public records within what 2 time period would you say that has been? 3 A. Last year and a half. 4 Q. Have you made copies using the copier this year 5 for anything else? 6 A. Yes, it is the general office machine. 7 Q. So you print off of it? S A. Print, fax. It does everything. 9 Q. That is the only one you have in the office? 10 A. Yes, it is. 11 Q. You just said within the past year and a half you 12 had an increase in public records. Is that due to anyone in 13 general or any people in general? 14 A. Certainly. 15 Q. Would that be mainly Mr. O'Boyle and Mr. O'Hare? 16 A. Yes, ma'am. 17 Q. Have you met both of them? 18 A. Absolutely. 19 Q. How many times would you say you met Mr. O'Boyle? 20 A. At least weekly and more. 21 Q. When you say at least weekly is it because he 22 comes in here? 23 A. Yes, I don't go out. 24 Q. Would you say he comes into the office at least 25 1 once a week? ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 16 A. Average I would say. Q. What does he do when he comes here? Is he making public records requests? A. Sometimes that. Sometimes he is coming to meetings if there's a meeting going on in here. Q. What about? Hearings? A. Sometimes. Q. About once a week? A. Maybe not quite as often. Maybe every couple of weeks. Q. When he comes in what's he -- A. -- same thing. Q. He is attending town meetings? A. Yes, or architectural meetings. Whatever meeting is going on. Q. Is he making record requests also? A. Seldom does it verbally but we get a lot of them through the e-mail. Q. You said Mr. O'Boyle will make public records requests. How often would he make public records requests verbally? A. Almost every time he comes in. Q. Does he also make them electronically ever? A. Yes, ma'am. Q. These public records requests, within the past ESQUIRE 800.211. DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 17 1 I year how many would you say if you could answer have you 2 received from Mr. O'Boyle? 3 A. I couldn't say how many have come from each 4 individual. All together we have had well over 1,500. 5 Q. 1,500 different requests? 6 A. Yes. 7 Q. That's the total between O'Boyle and O'Hare and 8 whoever may have asked for them? 9 A. We have very few of those. 10 Q. There are very few other people besides O'Boyle 11 and O'Hare who come in asking for things? 12 A. Sometimes they come in other names but they are 13 through their companies. 14 Q. Tell me what do you know about Mr. O'Boyle? 15 A. He is a resident of our town. 16 Q. Did you have any -- prior to all of this public 17 records hoopla did you have many interaction with Mr. 18 O'Boyle prior to that? 19 A. No. 20 Q. So this is relatively recent; right? 21 A. Right. 22 Q. Have you heard any negative comments regarding Mr. 23 O'Boyle and your office? 24 A. Well, would you expect that if you got 1,500 25 1 requests in a year? ESQUIRE 800.211.DEPO (3376) EsquireSolutions. corn 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 18 Q. Okay. Give me an example of what's been said about Mr. O'Boyle? A. Well, let's see. What does he want this time, is he going to show up or is he not and is he going to run for commissioner in the election. I hope he doesn't win. Q. These elections, when are they? Approximately when was this? A. The election was in March. End of February. Q. Did he actually run? A. He did. Q. He ran for, was it mayor? A. They don't run for mayor. They run for the commission. Then the commission decides who the mayor is going to be. Q. Would you say Mr. O'Boyle has a negative reputation within the town? A. I believe so. Q. What about Mr. O'Hare? A. Same. Q. Same thing. Has Mr. Scott Morgan said anything in particular about Mr. O'Boyle? A. Not to me. Q. When you get a request from Mr. O'Boyle do you report that to anyone in particular? A. It's in our system. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 19 1 Q. So you enter it into a system. You are not 2 required to go to anyone else and say Mr. O'Boyle made 3 another request? 9 A. No. 5 Q. With all these public records requests coming in 6 do you have to seek advice? 7 A. Certainly. 8 Q. Who do you seek advice from? 9 A. Most generally from the attorneys office. The 10 town attorneys office. 11 Q. The town's attorneys are Jones and Foster? 12 A. Right. 13 Q. How often would you say you have to consult with 19 them regarding public records requests? 15 A. Well, I don't always know because the other girls 16 are free to seek it too and I don't always know. I would 17 say maybe 30 percent of the time. 18 Q. They help you abide with code? 19 A. If we have a question, you know, especially about 20 redacting and that sort of thing. 21 Q. You said within the last year and a half the town 22 have been getting an increase in public records requests. 23 How many of those would you say are requested in electronic 29 form? 25 A. All of them. The biggest majority of them are in ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 20 the beginning Mr. O'Boyle faxed quite a few. But he doesn't do that much lately. Few maybe. Q. How does he request to receive those? Does he ask to receive them CD, e-mail? A. Usually says electronically. Q. The majority of his -- would you say the majority of Mr. O'Boyle's requests are going to be received electronically? A. Yes. Q. How often does he request something in paper form? A. I guess whenever we can't furnish it electronically. Q. How often do you think that happens? A. Not very often. Maybe 10 percent. Q. Other than Mr. O'Hare and Mr. O'Boyle how many public records requests would you say you receive a year? A. Three or four. Q. Are those extensive numbers or is it -- A. -- normally not. Q. Do you know what format those few requests are normally requested in? A. Those are normally -- well, some of them and when I say some I would say about half of what we get we get electronically. The other probably personal visits with a verbal request. ESQUIRE 800.21 i.DEPO (3376) EsquireSolutions.com 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 21 Q. If they come in with a personal visit do you normally provide that to them in paper form? A. Yes. Q. How many pages? How many pages within the past year and a half would you say you printed out on the copier for public records? A. I couldn't even hazard a guess. Q. Would you say it is probably a lot or would you say the majority are electronic? A. Well, I would say the majority are electronic. Q. The machine you use is from Xerox? A. Yes. Q. You did tell me that was the only copy machine you have in the office? A. That's right. Q. Do you use it for printing? A. Yes. Q. Do you have any other printers you normally use or -- A. -- there is one small printer in the office that is in the town manager's office. Q. You would say the majority of printing is done on the Xerox machine. Everyone can use it? A. Yes. Q. With everyone, all the commissioners? C)ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 22 A. No, just the staff uses it. Q. Have you ever read the lease agreement with Xerox? A. Yes. Q. Who is responsible for procuring the lease with Xerox? A. Well, basically all of the staff meets together when it is time to decide on a machine. We all come to an agreement. It is bought or it is leased on State bid. Q. When you guys decided on the Xerox in your group opinion Xerox was the best deal you guys came upon or the most reliable? What was your deciding factor on choosing this machine, if you remember? A. The fact that it seemed to meet our needs better than anything else. We are limited on the amount of space we have got. We needed something that would be an all in one cause we don't have room for more than one machine in our office. It did everything that we thought we needed. It was on State bid. Q. Let's talk about the materials you need for the copier. I guess normally you just need paper for it? A. Yes. Q. How do you decide where you're going to get your paper from? A. Wherever is the cheapest. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 23 1 Q. Do you just shop around or happen to go out? How 2 do you figure out what's the cheapest paper? 3 A. I look everywhere. 4 Q. What are the places you normally look? 5 A. Sam's and Office Depot. We got some now from 6 Columbia. 7 Q. Is that online? 8 A. Well, I guess they are. That is how. 9 Q. Online service? 10 A. Yeah. That was just a recent thing. We buy paper 11 at different places because of the different size paper. 12 Some places don't carry oversized. 13 Q. Do you know what size you normally have to 14 purchase? 15 A. 8 1/2 x 11, 8 1/2 x 14 and 11 x 17. 16 Q. When you purchase paper is 8 1/2 x 11 -- 17 A. -- we use the most of. 18 Q. Do you normally by that by a ream or box of it? 19 How do you purchase your paper, the 8 1/2 x 11? 20 A. Usually by the case. 21 Q. Do you know where you normally get that from? 22 A. Biggest is Sam's. Like I said, we have been 23 buying some now from Columbia. 24 Q. That's recently? 25 A. Yes. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 24 Q. Have you ever heard the term actual cost of duplication? A. I have. Q. What does that mean to you? A. That means actually what it takes to make a copy. Q. What it takes to make a copy. Does it include anything else? A. Just supplies and the machine to do it with. Q. How would you define supplies? A. The various sizes of paper. The ink and materials and maintenance of the equipment. The rental of the equipment. Q. You have your paper. You have the equipment. Is there anything else that you need? What would you define materials as? A. Well, ink, the components that make the machine run which is all included. Q. With regards to the machine do you have to get it serviced a lot? Is there a regular service that comes in with regard to the Xerox? A. Only if we have a problem we call them and they come and they fix it. Q. Do they charge you for those visits? A. No. Q. Do you include any overhead costs in whenever you ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 25 1 1 total your actual cost of duplications? 2 A. No. 3 Q. These definitions, you came up with them on your 4 own? 5 MS. O'CONNOR: Objection. 6 BY MS. CAIN: 7 Q. With regards to when you say supplies, materials 8 as you just defined them to me you came up with those 9 definitions on your own. 10 Are those your own words? 11 A. Yeah. 12 Q. As to how you interpret it? 13 A. Yeah. 14 Q. Are you aware of how much is spent on the copy 15 machine rental per month? 16 A. 501 some odd cents. 17 Q. You guys pay that out of what funds? 18 A. It's our general fund expenditure. 19 Q. You have seen your policy books on public records 20 requests? 21 A. Yes. 22 Q. You have read it. When was the first time you 23 ever became acquainted with the policy book? 24 A. Ours? 25 Q. Yes. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. corn 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 26 A. It was just recently adopted a couple months ago. However, we had been following most of what was in the book for months and months. Q. How long ago would you say guys actually replaced the policy book? Do you remember when that was? A. I think it was two meetings ago. Two months ago. Q. Where your policy -- how much do you charge for 8 1/2 x 11 black and white copies? Do you know off the top of your head? A. 8 cents. Q. Is it the same price for one sided and two sided or do those prices vary? A. No, we just charge one fee. Q. How did you guys come up with the total of 8 cents? Can you give me a breakdown as far as explaining? A. Yes, I believe I can. We totaled from the Xerox invoices the number of copies that were made during the year and we averaged that to come down to a per copy against the 501 and added the cost of the paper to it which I said for 8 1/2 x 11 I think is 1 cent. Q. Does that include copies of everything in the office, that number you guys came up with or was it only public records? A. No, it is total of all copying. Q. How long would you say you guys have been charging ESQUIRE 800.211.DEP0 (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 27 1 1 8 cents? Has it been as long as you can remember? 2 A. No, it hasn't been. We used to charge by the 3 statutory price of 15 cents for one sided and 20 cents for 4 two sided. 5 Q. How long ago was that? 6 A. Well, we had always charged that up until I guess 7 about a year ago or maybe a little longer. 8 Q. Do you know what spurred the change in that, the 9 change from 15 and 20 cents to 8 cents? 10 A. Well, when the public records were becoming too 11 voluminous they decided to come up with a policy, to do a 12 policy. Then we had to do an analysis. That is what 13 evolved. 14 Q. You said you had to do an analysis. Do you 15 remember when you guys decided to do this analysis? 16 A. I believe it was October, November of last year. 17 Maybe a little before that started. 18 Q. Did you ever receive a memo from Edward Nazzaro? 19 A. I did. 20 Q. I am going to give you a copy. I am going to 21 refer to this as exhibit one. Is that the memo you received 22 from Mr. Nazzaro? 23 A. It appears to be. 24 (Plaintiff's Exhibit No. 1 was marked for 25 1 identification.) ESQUIRE 800.211.DEP0 (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM 1 1 BY MS. CAIN: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 September 30, 2014 28 Q. Is that what you solely relied on as to decide whether to charge the 8 cents? A. Yes. Q. Did you make any of your own calculations? A. Yes. Q. What were your own calculations? Were they similar to what's in exhibit one? A. Similar except this was done over a period of a year. As a comparison mixing out the average month and did the same math that he has done for a year and it's so close. Q. So when you say so close are we looking at 7.4? A. Yes, whether you raise it to the next digit. Q. With regards to this memo did you have any other contact with Mr. Nazzaro besides him sending you this memo? A. Yes, he used to come in frequently. We would consult with him. Q. You said he would come in frequently. Come to town hall, consult with him. What can you tell me about that? A. He acted as liaison and the attorneys office. Q. When he came out what would he do? In what capacity? A. He worked on this of course. We would ask him questions how he felt about something. If he didn't know ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 29 1 off the top of his head he would find out for us and report 2 back. 3 Q. Most of the time was it about public records? 4 A. Yes. speak with Mr. Rizzardi? 5 Q. This policy or memo, did he ever tell you which 6 attorney came up with the means of drafting it? 7 you ever speak with him MS. O'CONNOR: Objection. You can answer. 8 THE WITNESS: Came through Jones Foster's office. 9 BY MS. CAIN: Not in particular, no. 10 Q. But you don't know specifically which attorney 11 drafted it? regarding exhibit 12 A. I think it was Keith Rizzardi or at least part of 13 it. 14 Q. Why do you think it was him? 15 A. Trey used to converse with him. I assume he had a 16 1 hand in it. 17 Q. Do you know directly whether he had a hand in it? 18 Did you ever speak with Mr. Rizzardi? 19 A. Yes. 20 Q. Did you ever speak with him about public records 21 policy? 22 A. Not in particular, no. 23 Q. You never had a conversation with Mr. Rizzardi 24 regarding exhibit one, this memo, did you? 25 A. No. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 30 Q. Pretty sure -- how did you come up with the cost of 1 cent per page? A. I took the cost of the paper and divided it by the number of pages. At Sam's you get 750 sheets a package. Everywhere else you get 500. Q. So Sam's is a better deal? A. Yes. Q. You guys also had a meter cost in there; is that right? A. It comes on the Xerox invoice. Q. That is attached to the leasing with regards or with your Xerox lease? A. Yes. Q. Do you know what the meter cost was representing that? Did they ever tell you or do you know off the top of your head? A. Yes, I think it is 1 cent for black and white and I think it is 7 cents for color. Q. Did they tell you what meter cost means? Did they ever explain that to you? A. It is for every piece that goes through. Q. Is it possible that the meter cost is for ink? A. No, I believe the ink and all of those kinds of things are included in the 501 a month. Q. Do you know why they charge a different price for ESQUIRE 800.211.DEP0 (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM 1 1 black and white versus color? September 30, 2014 31 2 A. I can only assume that the ink for the color is 3 probably more costly. I don't know. 9 Q. Is it possible in your opinion that the meter cost 5 could be related to ink to some degree? 6 MS. O'CONNOR: Objection. 7 THE WITNESS: I don't think so. 8 BY MS. CAIN: 9 Q. Let's talk about the 6 cents. You say all of that 10 6 cents goes to for whatever public records you have to 11 release. 12 All of that goes to the payment of the Xerox 13 machine? 19 A. It goes to general fund revenue. 15 Q. From there it is decided or guessing whether it 16 goes to the Xerox machine or something else? 17 A. No, there is an accounting. It's a State 18 accounting system. They give the title all one liners. 19 This goes in a one line, says miscellaneous. There is 20 another one, I forget what it is. There is not a line 21 designated for copy costs. 22 Q. Would you say that this machine is used in your 23 regular course of business, your Xerox machine? 29 A. Yes. 25 Q. You're going to need that copy machine, let's say ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 32 there was no Mr. O'Boyle and no Mr. O'Hare. You would still need to utilize that copy machine? A. Certainly. Q. I am going to give a hypothetical. If one day Mr. O'Boyle came and asked for 10,000 public record copies in a month and it was for 8 1/2 x 11. That number puts it at, I want to say -- I want to do the math exactly for you. 10,000 public record requests were made by Mr. O'Boyle or Mr. O'Hare. They needed 10,000 sheets of 8 1/2 x 11 paper at 8 cents. That total comes out to be 800. Where would the additional money -- would that money go to the general revenue fund? MS. O'CONNOR: Assuming it is paid for? MS. CAIN: Assuming. THE WITNESS: The general fund is the only fund that is affiliated with any expenses or revenue as a result of the copies. BY MS. CAIN: Q. You said the Xerox machine is only 501 and some change a month. If you wound up making an additional 299 that exceeds the cost of the copier; is that right? The cost of the rental of the copier, is that right, monthly? A. I don't understand. Q. If monthly it is 501 and change; correct? If your ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 33 1 public records request happened to exceed -- generate an 2 amount that is greater than the 501 and change that exceeds 3 the actual cost of duplications in your opinion? 4 MS. O'CONNOR: Objection. 5 THE WITNESS: I don't know if it does or not. 6 BY MS. CAIN: 7 Q. Would you say that there is additional monies made 8 over the cost of the monthly rental if a large public 9 request like that was made? 10 A. I suppose maybe it could. I think that is highly 11 doubtful. 12 Q. Would you refer to that number -- if that did 13 happen would you refer to that number as -- how would you 14 refer to that excess amount of money? 15 A. It always goes into the general fund and it all 16 comes out of the general fund. 17 Q. Have you seen drafts of the proposed August 2014 18 town manual from your meeting in August? 19 A. What now? Say that again? 20 Q. Did you ever see a draft of your proposed -- a 21 minute agenda and draft of your town policy made during your 22 August meeting. 23 A. Do you mean the public record policy? 24 Q. Yes. 25 A. Yeah. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 34 Q. Show you exhibit two. Do you recognize that? A. Yes. (Plaintiff's Exhibit No. 2 was marked for identification.) BY MS. CAIN: Q. That is a draft Gulfstream intends to impose? A. We did adopt it. Q. In the adoption of public record policy you guys intended on keeping the 8 cents or keeping the cost as from what we just previously discussed? A. Yes, until such time as it might be changed. Q. And now to your knowledge there's no change? A. Haven't heard of any. Q. How would you define the word revenue in your office? A. Income into the town. Q. Is it just any income? A. Yes. Q. Who is the lowest paid employee in the town currently? A. Rebecca. Q. Do you know how much she makes off the top of your head? A. No, I don't. Q. Previously it was Ms. Frida? ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 35 1 A. That's right. 2 Q. Did she help with public requests? 3 A. Yes. 9 Q. Was this during the period where Mr. O'Boyle and 5 Mr. O'Hare were making extensive requests? 6 A. Yes. 7 Q. Do you know if she was fired or whether she quit? 8 A. She quit. 9 Q. When did she quit? 10 A. I don't know for sure. Must have been six or 11 eight months ago. 12 Q. Did she ever state a reason for her resignation? 13 A. Yes. 19 Q. What was that? 15 A. That there was just so much work in those public 16 records requests and she was a nervous wreck. It drove her 17 away as a matter of fact. 18 Q. So that was her direct reasoning. Did she make 19 this statement to you? 20 A. Yes. 21 Q. Did she make it to any others? 22 A. Oh, yes. 23 Q. Was this said verbally or did she send out an 29 e-mail or letter of resignation? 25 A. It was said verbally but I think she may have ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 36 mentioned that in her resignation letter but I am not sure. Q. Back to the 8 cent policy. How was this policy passed within the town? A. It was passed when that was adopted. When the policy was adopted but it was put into use long before that. Q. Did it go through the commissioners? A. No. Q. Was there a vote on it? A. No. Q. Was it ever proposed at a public meeting of the city? A. It was a staff thing. As I said, with a liaison with the attorneys office taking into consideration the Public Record Act of the State. Q. To your knowledge have the commissioners ever held executive session meeting since the implementation of that policy? Scratch that. What training have you received with regard to public record complaints, if any? A. We have had the ethics training and then of course the policy itself. We have all gone through that and discussed it among ourselves as staff on a staff level. Q. You said public ethics training. Do you remember when that was? A. We do it once a year. ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 37 Q. Who does it? A. Sometimes the gentleman from the ethics, County Ethics Board comes. Sometimes we do it over the website. Q. Does any of that directly relate to public records requests? A. Well, that is part of it. It is not the primary thing but it is a part of it. Q. Are you required to do that every year? A. Yes. Q. Have you ever heard of the Government In the Sunshine Manual? A. Yes. Q. Have you had a chance to read or it look it over? A. When they first came out with it and it was much smaller. Q. How long was that? A. No, we get them every year and we do review them. Q. With regards to this has anyone ever told you to alter a response to a public record request? MS. O'CONNOR: Objection. THE WITNESS: I don't know what you mean by alter. I mean, a request is a request. BY MS. CAIN: Q. No one ever asked you to change anything within a public record that is to be released? C)ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 38 A. No. Q. You said the city has hired -- has the city hired anyone specifically just to comply with public records requests? I know you have two temps. Are they general temps or are they solely to help you with the public records requests? A. The full-time one only does work with the public records. Q. That is her sole job basically is to help fulfill some of these public records requests? A. Scanning stuff and that sort of thing. Q. When was she hired? A. I am not sure. I think she has been here -- three or four months. Q. She came through Apple you said? A. Yes. Q. When you get a public record request and you have to redact something who is responsible for redacting that information? A. Well, Kelly determines if it's a document that needs to be considered for that. Then she turns to the attorneys office for direction. Q. The attorneys office is who specifically helps you determine what is exempt and what's not exempt? A. Yes. ESQUIRE 800.211.DEP0 (3376) EsquireSolutions. com RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 39 1 Q. You don't make any of those decisions unilaterally 2 1 here on your own? 3 A. Not when it comes to redacting, no. 4 Q. Jones Foster is the town attorney? 5 A. Yes. 6 Q. Do you know when was the last time you renewed 7 your contract with them? 8 A. We don't work under a contract. 9 Q. I believe there was John Randall or Skip Randolf 10 who was the town attorney before? 11 A. Is still. 12 Q. Does he still work as town attorney? 13 A. Yes. 14 Q. To your knowledge in this specific case and I know 15 there is a lot going on. In this specific case do you know 16 if Mr. Sweetapple is involved? 17 A. I have no knowledge of it. I don't know him. 18 Q. You haven't had to deal with him in this case at 19 all? 20 A. No. 21 Q. Do you have a security system here in town hall? 22 A. Yes. 23 Q. Can you tell me a little bit about that? 24 A. It is an alarm system that is a motion detector 25 for the whole building. Then we have on the door that goes ESQUIRE 800.211.DEPO (3376) EsquireSolutions. corn RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 40 1 into the office wing of the building, we have an intercom 2 system. We control that from our office inside. We find 3 out who it is and what they want. Sometimes we come out, 9 I discuss business if that is that kind of business out in the 5 lobby. Sometimes we invite them to come in. 6 Q. When you say you invite them to come in is it out 7 from the front door? 8 A. No, it is that door that you can see on the other 9 side of the hallway. It is that door. 10 Q. How long have you guys had a security system? 11 A. We always have the whole building. That one has 12 been in probably a month. 13 Q. Is it anything related to any of the issues with 19 the public records requests or just is it a new upgrade? 15 A. Well, most of the offices you can't walk right 16 into everybody's private office. That eliminates that 17 problem. 18 Q. Have you ever within the past year and a half told 19 someone that record requests must in writing? 20 A. I may have. I don't remember offhand. I know 21 that they don't have to be. I may have mentioned it when I 22 was very busy, write it down and I will get to it. 23 Something like that. 29 Q. In general for example, if a public record request 25 1 comes in and it is available on the town's website do you ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 41 1 1 consider that to be an adequate response to the request? 2 A. If we tell them where it is and how to get to it. 3 Q. Does the town prefer to do your records check 4 electronically or in person? Do you want it in paper 5 format? 6 A. Well, we prefer to do it in the least expensive 7 and efficient manner that we can. In this day and age it 8 seems to be electronically. 9 Q. Has the town received any advice or communicated 10 with Mr. Joel Chandler regarding any of these records 11 requests? 12 MS. O'CONNOR: The requests at issue in this 13 lawsuit? 14 MS. CAIN: In general. 15 THE WITNESS: Long time ago. 16 BY MS. CAIN: 17 Q. When you say a long time ago how long ago was 18 that? 19 A. Probably two years. 20 Q. Have you heard anyone within the town hall 21 recently discussing Mr. Joel Chandler? 22 A. No. 23 Q. What's your procedure for processing public 24 records lawsuits? 25 A. Well, once we are served we put them on the ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 9 5 6 7 8 9 10 11 12 13 19 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 42 website. We distribute copies to the attorneys for us. I set up a file under that number. Then we wait until the attorneys gets a hold of us. Q. Do you ever take any subsequent remedial measures? A. I don't understand that. Q. Let's say before you speak to the attorney if you figure out something was done wrong do you try to fix it within the public records? If it didn't comply with 119? MS. O'CONNOR: Objection. THE WITNESS: You mean if it has been filed do we try to get them to un -file it? BY MS. CAIN: Q. Let's say you make an error. A. In what? Q. With either missing something or not providing something properly. Do you make any remedial effort, do you try to fix any errors that are made? A. Absolutely. MS. O'CONNOR: Object to the hypothetical. BY MS. CAIN: Q. But do you attempt to fix whatever errors? A. We want things to be right. Q. Who is responsible for directing the town's litigation? ESQUIRE 800.211.DEPO (3376) EsquireSolutions.com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 43 1 A. The attorneys and the commission. 2 Q. That would be Mr. Morgan? 3 A. Yes, and the commissioner. 4 Q. Mr. Thrasher, you, all of you together? 5 A. No, staff doesn't. 6 Q. You have nothing to do with it? 7 A. No. 8 Q. Have you ever expressed any want or need to change 9 the public records policy within the past year? 10 A. Have I ever expressed a desire? 11 Q. Yes. 12 A. Maybe certain parts of it. 13 Q. When you say that what did you express and to who? 14 A. I probably expressed it publicly most likely that 15 there are parts of it that seem a little unfair. One part 16 was especially when the statute said you could charge 15 17 cents for one sided, 20 cents for two sided and anything 18 over 8 1/2 x 14 you could charge the actual cost. Now, at 19 that point I personally was not aware that the actual cost 20 is the way we now figure the actual cost. I thought that it 21 read that way because there was an assumption that if you 22 had to go to a bigger size you couldn't do it yourself and 23 you would have to send it out which would cost more money. 24 I thought that ought to be clarified. 25 Q. This was about how long ago? ESQUIRE 800.211. DEPO (3376) EsquireSolutions. com 1 2 3 9 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 29 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 44 A. Couple years. Q. Do you know and these are just going to be some final round -up questions. I am almost done. Do you know what percentage of the monthly copier fee specifically goes to ink usage? A. I have no way of knowing that. Q. How does the town define overhead? How do you use the dictionary's definition of that or do you use your own definition or are you told the definition? A. We don't use the dictionary. Overhead is what it costs to maintain the building and what it takes to run the copier and house the copier. Like the electricity, air conditioning, whatever. Q. Pretty sure we have gone over this. Ask just in case. Have you ever been convicted of a felony? A. Not yet. Q. Have you ever been convicted of a crime of dishonesty? A. Nope. Q. Do you have any interns or volunteers here? A. No. MS. CAIN: I have no further questions. MS. O'CONNOR: Couple questions. CROSS EXAMINATION BY MS. O'CONNOR: ESQUIRE 800.211. DEPO (3376) EsquireSofutio ns. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 45 Q. Joanne O'Connor. Ms. Taylor, you were just asked about overhead. You indicated overhead is what it takes to run and house the copier. Did you mean the electricity cost to turn the copier on and off? A. Certainly. MS. CAIN: Object to form. BY MS. O'CONNOR: Q. You were asked some questions about who the town has -- whether the town has specifically hired anyone to help with public records requests and you indicated there's a full-time temp here at town hall. What percentage of Kelly Avery's time would you estimate is dedicated to responding to public records requests? A. Probably I would say 75 percent. Q. Trey Nazzaro, the individual who wrote the memorandum that is marked as exhibit one, was he providing contract services to the town last year? A. Yes, through our attorneys office. Q. Would he come to town hall on a regular basis and assist with public records? A. Yes. Q. Approximately how many hours per week did Trey work last year? CESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 46 A. I think 20. Q. Is there someone this year who has worked on a contract basis, a law student to assist with public records requests and responses? A. Yes. Q. Who is that? A. Maxine Meltzer. Q. Does she work similar hours that Trey worked last year? A. Yes. Q. You were asked some questions about training regarding public records compliance. Would you consider the guidance provided by Trey Nazzaro and now Maxine Meltzer and also Keith Rizzardi to be a form of informal training? A. It would be. Q. You were asked questions about whether the town pays extra for the service of the copy machine and you indicated there is no extra charge. Do you remember that? A. Yes. Q. Is it your understanding that the service when a service professional comes out to service the copier, is it your understanding that is included in the monthly 501 fee? A. It is. Q. I want to mark -- we can mark this as exhibit ESQUIRE 800.211.DEPO (3376) 11 1 EsquireSolutions. com RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 47 1 three? Ms. Taylor, if you could take a look at that 2 document and I ask if you recognize that document? 3 A. I do. 9 Q. What is it? 5 A. It is the cost of six packages of 8 1/2 x 11 paper 6 from Sam's. 7 MS. CAIN: Can you tell me the date on that? 8 THE WITNESS: Purchased? May 9, 2013. 9 (Plaintiff's Exhibit No. 3 was marked for 10 identification.) 11 BY MS. O'CONNOR: 12 Q. There's a notation on that invoice that indicates 13 750 sheets in each six packages. Do you see that? 19 A. Yes. 15 Q. Is that because each package of 8 1/2 x 11 paper 16 that you purchased from Sam's contains 750 sheets? 17 A. That's right. 18 Q. In calculating .01 cents per 8 1/2 x 11 sheet did 19 you take 6.98 per package and divide it by 750 sheets? 20 A. I did. 21 MS. O'CONNOR: I don't have any questions. We 22 will read. 23 THE COURT REPORTER: Ms. O'Connor, if this is 29 ordered would you like a copy? 25 MS. O'CONNOR: Yes, if it's ordered we'll take a ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 48 — 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM DEPOSITION ERRATA SHEET Assignment No. # 207862 Case Name: O'Boyle vs. Town of Gulfstream DECLARATION UNDER PENALTY OF PERJURY September 30, 2014 49 I declare under penalty of perjury that I have read the entire transcript of my deposition/examination under oath taken in the captioned matter or the same has been read to me, and the same is true and accurate, save and except for changes and/or corrections, if any, as indicated by me on the DEPOSITION ERRATA SHEET, hereof, with the understanding that I offer these changes as if still under oath. Signed on the 6th of October, 2014. RITA TAYLOR Job # 207862 ESQUIRE 800.211. DEPO (3376) EsquireSolutions. com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 50 OAFESQUIRE 800.211. DEPO (33 76) EsquireSofutions. com DEPOSITION ERRATA SHEET Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: SIGNATURE: DATE: RITA TAYLOR JOB # 207862 OAFESQUIRE 800.211. DEPO (33 76) EsquireSofutions. com 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR O'BOYLE vs. TOWN OF GULFSTREAM September 30, 2014 51 DEPOSITION ERRATA SHEET Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: Page No. Line No. Change to: Reason for change: SIGNATURE: DATE: RITA TAYLOR Job # 207862 C)ESQUIRE 800.211. DEPO (3376) EsquireSolutions.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 52 RITA TAYLOR September 30, 2014 O'BOYLE vs. TOWN OF GULFSTREAM 53 1 1 CERTIFICATE VA THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 0 5 I, DEBORAH LAWRENCE, Court Reporter and Notary Public in and for the State of Florida at Large, do 6 hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that I 7 was authorized to and did report said deposition in stenotype and that the foregoing pages are a true and 8 correct transcription of my shorthand notes of said deposition. 9 I further certify that said deposition was taken at 10 the time and place hereinabove set forth and that the taking of said deposition was commenced and completed 11 as hereinabove set out. 12 I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or 13 employee of any attorney or counsel of party connected with the action, nor am I financially interested in the 14 action. 15 The foregoing certification of this transcript does not apply to any reproduction of the same by any means 16 unless under the direct control and/or direction of the certifying reporter. 17 DATED this 6th of October, 2014. 18 19 20 DEBORAH LAWRENCE, Court Reporter 21 Job # 207862 22 IC&] 24 25 ESQUIRE 800.211.DEPO (3376) EsquireSolutions. com