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HomeMy Public PortalAboutPRR 15-2050From: Chris O'Hare [mailto:chrisoharegulfstream@gmail.com] Sent: Wednesday, November 11, 2015 11:54 AM To: Bill Thrasher <bthrasher@gulf-stream.org> Subject: Follow up record request - Fwd: GS #2037 (sweetapple conditional letter) Dear Custodian of Records, Thank you for responding to my recent request for a public record. Forwarded herein for your reference is your response with my request. Your response includes a link to a page on the Town website where I found the apparent record. This page is also attached for your reference. I note that my record request was made to you on October 29, 2015 but the record you produced in response to this request is dated yesterday, November 10, 2015, the very same day you sent it to me. This surprises me because you have previously stated to me that: 1) The Town does not produce records that are created or received AFTER the date of the request - this record is dated 12 days after you received my request. 2) The Town does not create a record in response to a request - this record was apparently created because I asked for it. I am writing you now to inquire further about this matter. I have fashioned my inquiry into the form of a public record request to insure a response. Thank you for your attention to this additional request. This email is a singular request for a public record. Please respond to this public record request in a singular manner and do not combine this public record request with any other public record requests when responding. Before making this public record request, I first searched the public records portion of your agency's website hoping I could locate the public record I seek without having to trouble you for it. Unfortunately I can not find the records I wish to examine and I am therefore writing you now to request it. I request you provide for my inspection the public record which is: Any payment to, and bills from, Cole, Scott & Klssane, P.A. for legal work completed on behalf of Robert Sweetapple since January 2015. Any payment to, and bills from, Sweetaople, Broeker &Varkas, P.L. (or any other firm in which Mr. Sweetapple has an Interest) for legal work completed on behalf of Robert Sweetapple since January 2015. Any communication between the Town and anyone at Cole, Scott & Kissane, P.A. regarding the production of their Nov 10, 2015 letter. I make this request pursuant to Article 1. Section 24 of the Florida Constitution and Chapter 119 of the Florida Statutes. If you contend that any of the records I am seeking, or any portion thereof, are exempt from inspection or disclosure please cite the specific exemption as required by $119.07(1)(e) of the Florida Statutes and state in writing and with particularity the basis for your conclusions as required by § 119.07(1)(f) of the Florida Statutes. Please take note of 5119.07(1)(c) Florida Statues and your affirmative obligation to (1) promptly acknowledge receipt of this public records request and (2) make a good faith effort which "includes making reasonable efforts to determine from other officers or employees within the agency whether such a record exists and, ifso, the location at which the record can be accessed." I am, therefore, requesting that you notify every individual in possession of records that may be responsive to this public records request to preserve all such records on an immediate basis. 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 §I19.01(2)(f). Florida Statutes. Please provide only those records for inspection that do not require extensive use of information technologies or extensive staff time or both in excess of 15 minutes. Please take note of 4119.070)(01(d) Florida Statues and if you anticipate that any records exist, the production for inspection of which will require extensive use of information technologies or extensive staff time or both in excess of 15 minutes, then please advise me of the cost you anticipate to be incurred by your agency prior to incurring this cost. Please do not incur any costs on my behalf without fast obtaining my written authorization to proceed. If you anticipate the need to incur any costs that I would be statutorily required to pay in order to inspect these public records which would exceed $1.00 please notify me in advance of your incurring that cost with a written estimate of the total cost. Please be sure to itemize any estimates so as to indicate the total number of pages and/or records, as well as to distinguish the cost of labor and materials. Again, please do not incur any costs on my behalf without fast obtaining my written authorization to proceed. I hereby reserve all rights granted to me under the Florida Constitution and Florida Statutes. Please provide for my inspection the requested records within ten (10) days of your receipt of this request. All responses to this public records request should be made in writing to the following email address: chrisoharegulfstream(a),gmail.com TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 16, 2015 Chris O'Hare [mail to: chrisoharegulfstream@gmail.com] Re: GS #2050 (Follow up record request - Fwd: GS #2037 (sweetapple conditional letter)) (1) Any payment to, and bills from, Cole, Scott & Kissane, P.A. for legal work completed on behalf of Robert Sweetapple since January 2015. (2) Any payment to, and bills from, Sweetaople, Broeker &Parkas, P.L. (or any other firm in which Mr. Sweetapple has an interest) for legal work completed on behalf of Robert Sweetapple since January 2015. (3) Any communication between the Town and anyone at Cole, Scott & Kissane, P.A. regarding the production of their Nov 10, 2015 letter. Dear Commerce Group, Inc. [mail to: recordsna,commerce-srouo.coml, The Town of Gulf Stream has received your public records requests dated November 11, 2015. The original public record request can be found at the following link: http://www2.eulf- stream.ore/weblink/O/doc/70266/Pagel.asl2x. 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 Rebecca Tew From: Sent: To: Cc: Subject: Attachments: www.csklegal.com Joshua A. Goldstein <Joshua.Goldstein@csklegal.com> Tuesday, November 10, 2015 12:12 PM Rebecca Tew Lisa Daye; Cynthia Bailey (cbailey@sweetapplelaw.com) FW: O'Boyle v. Sweetapple, et al. Town of Gulf Stream Ltr dated 11-10-15.PDF Joshua A. Goldstein, Es( Joshua.Goldstein@csklegal.com Tel: 561-383-9256 Fax: 561-683-8977 222 Lakeview Avenue, Suite 120 West Palm Beach, FL 33401 From: Lisa Daye Sent: Tuesday, November 10, 2015 11:44 AM To: rtw@gulf-stream.org Ce: Joshua A. Goldstein; cbailey@sweetapplelaw.com Subject: O'Boyle v. Sweetapple, et al. Dear Sir or Madam: Attached please find correspondence from Mr. Goldstein regarding the above. Thank you. www.csldegal.com Lisa Daye Legal Assistant to Attorneys: Lisa.Daye@csklegal.com Tel: 561-681-9208 Fax: 561-683-8977 222 Lakeview Avenue, Suite 120 West Palm Beach, FL 33401 Confidentiality Notice: This communication is covered by the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510- 2521. It is legally privileged (including attachments) and is intended only for the use of the individual(s) or entity(ies) to which it is addressed. It may contain information that is confidential, proprietary, privileged, and/or exempt from disclosure under applicable law. Any review, retransmission, dissemination or other use of, or tatting of any action in reliance upon this information by persons or entities other than the intended recipient is strictly prohibited. If you have received this communication in error, please notify us so that we may take the appropriate action and avoid troubling you further. If you are not the intended recipient(s), please destroy this message, and any attachments, and notify the sender by return e-mail. Thank you for your cooperation. November 10, 2015 E -Mail: RTW( eulf-stream.ore Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483-7477 222 LAKEVIEW AVENUE, SUITE 120 WEST PALM BEACH, FLORIDA 33401 TELEPHONE (551) 383-9200 FACSIMILE (561) 583.8977 WEBSITEw osklegal.com DIRECT LINE (581) 383-9258 EMAIL Joshua. Goldstein@csklegal.com RE: Plaintiff Martin O'Boyle Defendants Robert A. Sweetapple and Mayor Scott Morgan/Town of Gulf Stream Case No. 0:14-CV-81250-KAM Our File No. 1601-0062-00 Sir or Madam: Please be advised that the undersigned law firm of Cole Scott Kissane, P.A., has been retained to represent Robert Sweetapple, Esq. of Sweetapple, Broeker & Varkas, P.L. on behalf of Lawyer's Protector Plan® regarding the above. Our client's deductible is $25,000.00 and our hourly rates are as follows: TYPE RATE Partners $150.00 Associates $125.00 Paralegals $50.00 To date, the costs incurred in this matter are $590.17, we note this does not include attorney's fees. Thank you and if you have any questions, please do not hesitate to contact us. Very 7AG/ld L. Postman A. Goldstein cc: Cynthia Bailey (e-mail) 1:U601-8062-(lo\rormspondenm*vemnteot agency\town orgull'stream.00I rc confirmingourmpmsenlation.docz LAW OFFICES OF SWEETAPPLE, BROEKER & VARKAS, P.L. DOUGLAS C. BROEKER, P.A. 44 West Flagler Street, Ste. 1500 Miami, Flwida 33130 -UI7 Telephone: (305) 374 -5623 Facsimile: (305)355.1023 ROBERT A. S W EEFAPPLE •, •• DOUGLASC. BROEKER ALEXANDER D. VARKAS, JR. KADISHA D. PHELPS ALEXANDER D. VARKAS, Ill ASHLEIGH M. GREENE February 27, 2015 • eoAaa axnneo ausoassimwTamAnoara;r ,• aeAPa 60.T61FDC1V6Ta1ALA1taPNEY VIA EMAIL William Thrasher — City Manager Town of Gulf Stream 100 Sea Road Gulf Stream, Florida 33483 SWEETAPPLE & VARKAS, P.A. 20 S.E. 3i0 Sheet Boca Raton, Florida 33432 -4914 Tclephone:(561) 392 -1230 Facsimile: (561) 394 -6102 Please Reply To: Boca Raton E -Mail: tsweempple@sweetapplelaw.00m avatkas@sweetappkiaw.com nivukas@sweempplelaw.com ebailcy@swectapplelaw.com dsmith@sweetapplelaw.com Paralegals: Cynthia J. Bailey, CP, FCP, FRP Deborah Smith, CP, FRP Jamie Ardcn, FRP Re: O'Boyle v. Robert A. Sweetapple and Mayor Scott Morgan Case No.:9:14 -CV- 81250- KAM;USDC Dear Bill: Enclosed is the deductible invoice from my attorneys with regard to the indemnified Martin O'Boyle Federal claim against me. Please remit payment in the amount of $8,842.13 directly to Cole Scott & Kissane regarding invoice 457478. RAS:dls ec:Joshua Goldstein, Esquire (via email) Very truly yours, ROBERT A. SWEETAPPLE VN OF GULF ST - -- R q A PAYMENT APPROVED unt w Sµ2.13 eck # Invoice No. 457478 Total This Invoice PaYor Bill Summary Sweetapple, Broeker & Varkas, P.L. 100.0000 % Total Fees 100.0000 % Total Disbursements Total Due Page: 20 February 17, 2015 58,842.13 $8,712.50 $129.63 8,842.13 Deductible amount as per Agreement is $25,000 to be paid by Sweetapple, Broeker & Varkas, P.L. Deductible amount paid to date by Sweetapple, Broeker & Varkas, P.L. is $0.00 Sweetapple, Broeker & Varkas, P.L. Responsibility for this invoice is $8,842.13 CC: Elizabeth Mulligan Robert Sweetapple io) C�I fill MIAMI -WEST PALM BEACH - TAMPA - KEY WEST -FT. LAUDERDALE EAST- FT LAUDERDALE WEST - NAPLES JACKSONVILLE - ORLANDO - PENSACOLA - SONRA SPRINGS Elizabeth Mulligan Brown & Brown, Inc. 655 North Franklin Street, Suite 1900 Suite 1900 Tampa FL 33602 Brown & Brown, Inc. Re: 0062 -00 — Martin E. O'Boyle v. Robert A. Sweetapple and Scott Morgan Claim Number 4020140930001 For Professional Services Rendered through November 30, 2014 ACCOUNTING DEPARTMENT DADELAND CENTRE it 9150 SOUTH DADELAND BOULEVARD SURE 1400 MIAMI, FLORIDA 33156 TELEPHONE (305) 350 -530D FACSIMILE (305) 373 -2294 E -Mail: a=unVrKi95cskIwal=m WEBS I"Exw mklegal.wm FEDERALTAX IDn 65- 0792149 February 17, 2015 Client ND. 1601 Invoice ND. 457478 COPY Date Atty Description Hours 09/30/14 BAP Email exchange with claims handler, Elizabeth Mulligan, discussing this 0.10 new matter, the parties involved and our defense. 10/01/14 SJV Exchange of extensive correspondence with Elizabeth Mulligan relative to 0.80 the new assignment and strategy for upcoming defense of case (I0 emails). 10/01/14 SJV Receipt and review of Complaint (13 pages). 0.00 10/01/14 BAP Email exchange with Claim Handler with regard to the new case and the 0.30 manner in which it will be handled. 10101/14 BAP Review and analysis of documents provided with regard to new claim, 0.50 specifically the Complaint, to determine the nature of the action and begin the process of strategizing with regard to the defense efforts. 10/01/14 BAP Preparation of correspondence t0 client with regard to retention. 0.10 10/01/14 BAP Review and analysis of docket sheet. 030 10/01/14 BAP Review and analysis of information obtained from the intemet with regard 040 to the Plaintiff. 10/01/14 BAP Email exchange with Claims Handler. 0.00 10/02/14 SJV Receipt and review of correspondence from Kelly Pressler relative to the 0.10 wiring of funds and further strategy moving forward. Invoice No. 457478 Page: 2 February 17, 2015 10/02/14 SJV Receipt and review of additional correspondence from Kelly Pressler 0.10 relative to the wiring of funds and further strategy moving forward. 10/02/14 SJV Receipt and review of correspondence from Brandon Marton relative to the 0.10 wiring of funds and further strategy moving forward. 10/02/14 SJV Receipt and review of additional correspondence from Brandon Marton 0.10 relative to the wiring of funds and further strategy moving forward. 10/02/14 JHR Corresponded with opposing counsel regarding an extension of time to file 0.20 10/09/14 BAP a response to Plaintiffs Complaint. 0.10 10/03/14 JHR Corresponded with Mayor's (co- defendant) counsel regarding the removal 0.20 of the case to federal court and contact information regarding parties. 10/06/14 BAP Preparation of correspondence to Client relative to potential removal. 0.10 10/06/14 BAP Attendance of lengthy conference call client relative to facts of case and 0.50 future handling. 10/06/14 JHR Reviewed and extensively analyzed Plaintiffs Complaint to determine 1.30 future litigation strategy. 10/06/14 JHR Conducted extensive legal analysis in preparation to file response to 1.50 Plaintiffs Complaint including applicable affirmative defenses and grounds for a motion to dismiss Plaintiffs Complaint in preparation to draft a response to Plaintiffs Complaint. 10/07/14 JHR Corresponded with Co- defendant's counsel regarding consent to removal of 0.20 case to federal court via telephone and later confirmed via email. 10/07/14 JHR Continued conducting extensive legal analysis regarding the sufficiency of 3.10 Plaintiffs six counts under Florida law, as alleged in Plaintiffs Complaint, in preparation for drafting a response to Plaintiffs Complaint. 10/08/14 BAP Review and analysis of the removal documents to ensure the 0.30 appropriateness of same and determine its impact oil case. 10/08/14 JHR Drafted detailed factual background and procedural history of Defendant's 0.90 Motion to Dismiss Plaintiffs Complaint, 10/08/14 JHR Conducted extensive legal analysis in preparation to file response to 2.10 Plaintiffs Complaint including applicable affirmative defenses and grounds for a motion to dismiss Plaintiffs Complaint in preparation to draft a response to Plaintiffs Complaint. 10/09114 BAP Review and analysis of Federal Court docket with regard to removal. 0.30 10/09/14 BAP Review and analysis of Judicial Assignment. 0.10 CC: Elizabeth Mulligan Robert Sweetapple CC: Elizabeth Mulligan Robert Sweetapple Page: 3 Invoice No. 457478 February 17, 2015 10/09/14 BAP Preparation of correspondence to client with regard to removal. 0.10 10/09/14 BAP Review and analysis of Notice of Pendency of Other Action, 0.10 10/09/14 BAP Review and analysis of Notice of Appearance. 0.10 10%09/14 BAP Review and analysis of information provided by client regarding related 0.40 matter. 10/09/14 JHR Drafted legal standard for governing a motion to dismiss within 0.40 Defendant's Motion to Dismiss Plaintiffs Complaint. 10/09/14 JHR Conducted extensive legal analysis regarding Counts 1 and II of Plaintiffs 1.20 in preparation of drafting Motion to Dismiss regarding such counts. 10/10/14 JHR Drafted Count I and Count 11 sections of Defendant's Motion to Dismiss 2.50 Plaintiffs Complaint. Specifically, argued that Defendant's alleged statements constituted non actionable opinion, Plaintiff is a quasi - public figure, and that Plaintiff failed to demonstrate and allege actual /special damages. 10/13/14 BAP Preparation of correspondence to the claims handler, Elizabeth Mulligan, 0.20 relative to this new matter and discussing our recommendations for future handling. 10/13/14 BAP Preparation of correspondence to the insured discussing our 0.20 recommendations for future handling and defense. 10/13/14 JHR Conducted extensive legal analysis regarding Count III of Plaintiffs 1.00 Complaint regarding state actor requirement under 42 U.S.C. § 1983 and the three various tests that the Eleventh Circuit employs to determine whether an individual can be deemed a state actor in preparation to draft corresponding segment of Defendant's Motion to Dismiss related to this Count. 10/13/14 JHR Drafted Count III segment of Defendant's Motion to Dismiss Plaintiffs 1.40 Complaint arguing that Defendant cannot be deemed a state actor under 42 U.S.C. § 1983 under each of the three tests that the Eleventh Circuit utilizes. 10/13/14 JHR Conducted extensive legal analysis regarding Count IV of Plaintiffs 0.80 Complaint to determine whether such a cause of action is recognized under Florida law and how federal courts have ruled on such. 10/14/14 JHR Drafted Count IV segment of Defendant's Motion to Dismiss Plaintiffs 050 Complaint for failure to state a recognizable claim under Florida law. 10/15/14 JHR Conducted extensive legal analysis regarding Counts V and VI of 0.30 Plaintiffs Complaint in preparation for drafting of such sections or CC: Elizabeth Mulligan Robert Sweetapple CC: Elizabeth Mulligan Robert Sweetapple Page: 4 Invoice No. 457478 February 17, 2015 Defendant's Motion to Dismiss Plaintiffs Complaint. 10115114 JHR Drafted Count V and VI segments of Defendant's Motion to Dismiss 0.90 Plaintiffs Complaint, 10/15/14 JHR Edited Defendant's Motion to Dismiss Plaintiffs Complaint in its entirely. 0.80 10/17/14 BAP Assistance with regard to preparation of detailed comprehensive Motion to 1.00 Dismiss (not all time billed). 10/19/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against 1.50 Sweetapple, specifically revising and drafting additional facts to section setting forth factual and procedural background in this matter, including additional facts evidicing O'Boyle's stature as a quasi public figure as well as vexatious litigant. 10/19/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against 0.50 Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff has failed to assert a claim for slander per se. 10/20/14 JAG Drafting legnthy and detailed motion to dismiss O'Boyle's claims against 0.90 Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff has failed to assert a claim for slander per se. 10/20114 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against 1.50 Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth the requisite material facts which would support and maintain a claim for slander per se. 10/21/14 JAG Exchange correspondence with Plaintiffs counsel regarding and discussing 0.10 issues associated with responding to complaint. 10121114 JAG Draft lengthy and detailed motion for extension of time to respond to 0.40 complaint in this matter. Exchange correspondence with Plaintiffs counsel regarding and discussing issues associated with responding to complaint. 10/22/14 JAG Review order granting our motion for extension of time to answer 0.10 complaint. 10/22/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against 1.50 Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff cannot maintain a slander per se claim based on the failure to show Sweetapple acted with malice as required by Plaintiffs position as a limited public figure. 10/22/14 JAG Receipt, review and analysis of Co- Defendant, Mayor Scott's motion to 0.50 dismiss Plaintiffs complaint in order to assess arguments and facts raised in same. CC: Elizabeth Mulligan Robert Sweetapple Invoice No. 457478 1023/14 JAG Page: 5 February 17, 2015 Review and analyze Co- Defendant Morgan's lengthy motion for rule 11 0.30 sanctions and incorporated memorandum of law. 1024/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a viable cause of action for slander. 1024114 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a viable cause of action for First Amendment Retaliation under 42 USC 1983. 1024/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a viable cause of action for First Amendment Retaliation under 42 USC 1983, specifically Sweetapple is not acting under the color of state law and is not a state actor. 1.30 1.40 2.70 1024/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against 1.40 Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a viable cause of action for First Amendment Retaliation under 42 USC 1983, specifically, Plaintiff was not engaged in protected activity and the purported conduct does not rise to any level or retaliation. 1027/14 BAP Assistance with regard to the preparation of the lengthy and detailed Motion to Dismiss by adding additional argument and revision of Motion to Dismiss (vast majority of time not billed due the involvement of a second attorney on this project). 10/27/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a claim for civil conspiracy as such a claim cannot stand on its own. 1027/14 JAG Draft correspondence to R. Sweetapple regarding and discussing issues associated with this matter in particular proposed motion to dismiss this matter. 100-7/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a claim for civil conspiracy on the basis of slander or First Amendment retaliation. 1027/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a claim for civil conspiracy on the basis of slander in that there are insufficient facts to even support the conspiracy. CC: Elizabeth Mulligan Robert Sweetapple tt 1.40 0.20 1.30 1.30 Page: 6 Invoice No. 457478 February 17. 2015 10/27/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against 1.40 Sweetapple, specifically revising and drafting memorandum of law section setting forth position that Plaintiff fails to set forth a claim for civil conspiracy on the basis First Amendment retaliation in that there are insufficient facts to even support the conspiracy. 10/27/14 JAG Drafting lengthy and detailed motion to dismiss O'Boyle's claims against 1.40 Sweetapple, specifically drafting memorandum of law section setting forth position that Plaintiffs claims all fail as the action taken by Sweetapple are all subject and protected by the litigation immunity privilege. 10/28/14 JAG In further preparation of drafting motion to dismiss in this matter, commence review and analyze motion for scheduling order in related matter between Gulfstream and O'Boyle in particular lengthy affidavit of J. Chandler. (166 pages). 10/29/14 JAG In further preparation of drafting motion to dismiss in this matter, finalize review and analyze motion for scheduling order in related matter between Gulfstream and O'Boyle in particular lengthy affidavit of J. Chandler. (166 pages). 10/29/14 JAG Exchange correspondence with R. Sweetapple regarding and discussing issues associated with affidavit of J. Chandler as well as motion to dismiss complaint. 11/03/14 BAP Lengthy telephone call with the boss of Sweetapple to discuss and confer regarding status. 11/03/14 JAG Exchange correspondence with R. Sweetapple regarding and discussing issues associated with this matter in particular removal to federal court and procedures going forward. 11/04/14 JAG Exchange correspondence with counsel for Plaintiff, D. DeSouza regarding and discussing issues associated with filing reply to Defendant's motion to dismiss. 11/04/14 JAG Exchange correspondence with counsel for Plaintiff, D. DeSouza regarding and discussing issues associated with court ordered joint pre -trial scheduling conference and issues associated with same, including but not limited to required proposed scheduling order necessary for same. 11/04/14 JAG 11 /05/14 JAG 11/05/14 JAG CC: Elizabeth Mulligan Robert Sweetapple Receipt, review and analysis of Plaintiffs motion for extension of time to respond to Co- Defendant, Morgan's motion to dismiss. Review Order granting plaintiffs motion for extension to file response to Defendant Morgan's motion to dismiss. Exchange correspondence with counsel for Plaintiff, D. DeSouza regarding and discussing issues associated with joint pre -trial conference per -court order. 0.60 0.40 0.60 0.20 0.40 0.40 0.60 0.20 0.10 0.40 Invoice No. 457478 Page: 7 February 17, 2015 11/05/14 JAG Receipt, review and analaysis of correspondence from counsel for Plaintiff, 0.10 D. DeSouza regarding and discussing issues associated with joint pre -trial conference per -court order and proposed pre -trial plan. 11/05/14 JAG Receipt, review and analysis of proposed pre -trial plan in preparation of 030 court mandated conference. 11105114 JAG Attendance at lengthy court mandated teleconference regarding and 0.60 discussing required pre-trial plan. 11/06/14 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.30 associated with joint scheduling report pursuant to court order, proposed discovery plan and settlement discussions between underlying parties and effect on this matter and any potential counterclaim. 11/07/14 JAG Receipt, review and analysis of correspondence from R. Sweetapple 0.10 regarding and discussing issues associated with this matter, in particular proposed discovery as well as answer and affirmative defenses. 11!07/14 JAG Receipt, review and analysis of R. Sweetapple's proposed initial request for 0.20 production of documents. 11/07114 JAG Receipt, review and analysis of R. Sweetapple's proposed answer and 0.30 affirmative defenses if motion to dismiss is denied. 11/07/14 JAG Receipt, review and analysis of R. Sweetapple's proposed subpoena duces 0.10 tecum to be served upon Brenda Russel as it relates to Citizen's Awareness Foundation and entity run by O'Boyle. 11/13/14 JAG Teleconference with R. Sweetapple reagrding and discussing discovery 0.40 plan and actions of O'Boyle in furtherance our defensive strategy. 11/13/14 JAG Review and analysis of Florida new paper article addressing actions of 0.30 O'Boyle, pursuant to interview of former partner at Citizens awareness fund putting further proof to the alleged statements made by Sweetapple. 11/13/14 JAG Receipt, review and analysis of correspondence from R. Sweetapple 0.10 regarding and discussing proposed revised request for production. 11113/14 JAG Inimial receipt, review and analysis of R. Sweetapple's proposed revised 0.10 request for production. 11/14/14 JAG Review and analysis ofSweetapples ' revised proposed request for 0.30 production in order to assess validity of requests and determine other case specific requests to propound. 11/14/14 JAG Commence drafting additional voluminous case specific requests for 0.40 production to be propounded on Plaintiff related to claims set forth in Complaint, elements of said claims, Plaintiffs purported damages as well potential counterclaim by Sweetapple. CC: Elizabeth Mulligan Robert Sweetapple CC: Elizabeth Mulligan Robert Sweetapple Page: 8 Invoice No. 457478 February 17, 2015 11/17/14 JAG In preparation of drafting initial disclosures in this matter review and 0.80 analyze additional information with respect to R. Sweetapple as well as Plaintiff, O'Boyle in order to ensure all pertinent information will be included. 11/17/14 JAG Continue drafting additional voluminous case specific requests for 0.90 production to be propounded on Plaintiff related to claims set forth in Complaint, elements of said claims, Plaintiffs purported damages as well potential counterclaim by Sweetapple. 11/17/14 JAG Commence drafting additional lengthy and detailed initial disclosures 0.50 purusant to Fed. R. Civ. P. 26.1. 11118/14 JAG Teleconference with R. Sweetappple regarding and discussing issues 0.30 associated with this matter, in paritcular the filing and serving on Rule I 1 Letter and Motion. 11/18/14 JAG Review and analysis of case law and statutory authority with respect to safe 0.30 harbor time period in which party can dismiss claims before Rule 1 I motion can be filed. 11/18/14 JAG In further preparation of drafting additional case specific requets for 0.40 production to be propounded on Plaintiff, review and analyze both the allegations in the complaint as assertions set forth in motions to dismiss same. 11/18114 JAG Continue drafting additional voluminous case specific requests for 0.40 production to be propounded on Plaintiff related to claims set forth in Complaint, elements of said claims, Plaintiffs purported damages as well potential counterclaim by Sweetapple. 11/19/14 JAG Finalize drafting additional voluminous case specific requests for 2.30 production to be propounded on Plaintiffrelated to claims set forth in Complaint, elements of said claims, Plaintiffs purported damages as well potential counterclaim by Sweetapple. 11/24/14 JAG Review Plaintiffs second extension of time to file his response to our 0.20 motion to dismiss. 11/24/14 JAG Commence drafting lengthy and detailed correspondence to counsel for 2.50 Plaintiff regarding and discussing requirement to comply with Fed. R. Civ. P. 11, wherein Plaintiff has been requested to dismiss its claims as they lack merrit of Defendant will seek sanctions by way of attorney's fees and costs. 11/24/14 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.40 discussing issues associated with response in opposition to motion to dismiss. 11/25/14 JAG Review Order granting plaintiffs second extension of time to file a 0.10 response to our motion to dismiss. CC: Elizabeth Mulligan Robert Sweetapple Page: 9 Invoice No. 457478 February 17, 2015 1125/14 JAG Commence drafting lengthy and detailed motion pursuant to Fed. R. Civ. P. 2.90 11, wherein Plaintiff has been requested to dismiss its claims as they lack merit of Defendant will seek sanctions by way of attorney's fees and costs. 1125114 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.40 issues associated with proposed discovery requests and Rule 1 I letter /motion. Total Hours 68.20 Summary of Services Attv Hours Rate Value BAP Postman, Barry A. 6.30 150.00 945.00 JAG Goldstein, Joshua A. 40.90 125.00 5,112,50 JHR Railey, Jonathan H. 19.80 125.00 2,475.00 SJV Vine, Jonathan 1.20 150.00 180.00 Total Fees 68.20 $8,712.50 Disbursements Cast Description Amount Doctor/Hospital/Medical VENDOR: Palm Beach County Clerk of the 25.00 Records Expense Courts INVOICE #: 10062014 DATE: 10162014 lRequested By Earle, Kelly A. Messenger Service VENDOR: BDS Courier INVOICE #: 509968 40.00 DATE: 10/172014 lRequested By Earle, Kelly A. Copies (Qty: 253.0000 Qa 0.25) 63.25 Postage 1.38 Total Disbursements $129.63 Matter Summary 0062 -00— Martin E. O'Boyle v. Robert A. Sweetapple and Scott Morgan Total Fees Total Disbursements CC: Elizabeth Mulligan Robert Sweetapple $8,712.50 $129.63 Page: 10 Invoice No. 457478 February 17, 2015 Pavor Bill Summate Brown & Brown, Inc. Total This Invoice $8,842.13 Total Fees $0.00 Total Disbursements $0.00 Total Due 0.00 Deductible amount as per Agreement is $25,000 to be paid by Sweetapple, Bracket- & Varkas, P.L. Deductible amount paid to date by Sweetapple, Broeker & Varkas, P.L. is $0.00 Sweetapple, Broeker & Varkas, P.L. Responsibility for this invoice is $8,842.13 CC: Elizabeth Mulligan Robert Sweetapple a U 12720 TOWN OF GULF STREAM OPERATING ACCOUNT 3/6/21115 To. Cole Scott & Kissane PA Atut. Accounting Dept, 9150 South Dadeland Blvd., Ste. 1400 2/27/2015 Sweetapple Deductible 12720 TOWN OF GULF STREAM SUNTRUST BANK qq FRAUD 01—ARMOR- OPERATING ACCOUNT 63- 2151631 100 SEA ROAD CHECK DATE CHECK NO GULF STREAM, FL 33483 -7427 (561) 276 -5116 3/6/2015 12720 CHECK AMOUNT "Eight thousand eight hundred forty two and 13/100 Dollars" PAY $" 8,842.13 TO THE ORDER OF Cole Scott & Kissane PA Attn: Accounting Dept. p 9150 South Dadeland Blvd., ° {ro Ste. 1400 �>,a`. 33156 —_ AUTHOR= SIGNATURE 11001272011' LMM3 1641 YW�ValR WNRId.I/Ya.4l MILT Wf[I�W[Wlll MNII-4[aWWu,[�dWco R��V[O4 BWY VIaaa-!I WiORWII YV November 10, 2015 E -Mail: RTWniaaeulf-stream.ore Town of Gulf Stream 100 Sea Road Gulf Stream, FL 33483-7477 222 LAKEVIEW AVENUE, SUITE 120 WEST PALM BEACH, FLORIDA 33401 TELEPHONE (581) 383-9209 FACSIMILE (561) 683-6977 WESSITEw .wklegal.com DIRECT LINE (561) 383-9256 EMAIL Joshua.Goldstein@aklegal.com RE: Plaintiff Martin O'Boyle Defendants Robert A. Sweetapple and Mayor Scott Morgan/Town of Gulf Stream Case No. 0:14-CV-81250-KAM Our File No. 1601-0062-00 Sir or Madam: Please be advised that the undersigned law firm of Cole Scott Kissane, P.A., has been retained to represent Robert Sweetapple, Esq. of Sweetapple, Broeker & Varkas, P.L. on behalf of Lawyer's Protector Plan® regarding the above. Our client's deductible is $25,000.00 and our hourly rates are as follows: TYPE RATE Partners $150.00 Associates $125.00 Paralegals $50.00 To date, the costs incurred in this matter are $590.17, we note this does not include attorney's fees. Thank you and if you have any questions, please do not hesitate to contact us. Very JAG/Id L. Postman A. Goldstein cc: Cynthia Bailey (e-mail) IAI601-0062-001camspondence\guvemment agencyltown orgulrstream-001 re confirming our representation.doex MIAMI -WEST PALM BEACH -TAMPA- KEY WEST- FT. LAUUEROALE EAST - Ft. LAUDERDALE WEST- NAPLES JACKSONVILLE- ORLANDO-PENSACOLA-BONITA SPRINGS Robert Sweetapple Sweetapple, Bracket & Varkas, P.L. 20 S.E. 3rd Street Boca Raton FL 33432 Sweetapple, Broeker & Varkas, P.L. Re: 0062-00— Martin E. O'Boyle v. Robert A. Sweetapple and Scott Morgan Claim Number 4020140930001 For Professional Services Rendered through May 31, 2015 ACCOUNTING DEPARTMENT DADELAND CENTRE II 9150 SOUTH DADELAND BOULEVARD SURE 1400 MIAMI, FLORIDA 33156 TELEPHONE (305) 350.5300 FACSIMILE (305) 373.2294 E -Mail: acmunlJnaAc klwal wm WEBSITEw .cskle9alwm FEDERALTAX IDR 55-0792149 June 9, 2015 Client No. 1601 Invoice No. 478934 Date Attv Description (lours 03/02/15 JAG Review Mayor Scott Morgan's Unopposed motion for Extension of Time to 0.10 file reply to plaintiffs response to his motion to dismiss. 03/02/15 JAG Review and analyze plaintiffs lengthy memorandum of law in opposition 0.50 to defendant' Morgan's motion to stay discovery. 03/02/15 JAG Exchange correspodnence with counsel for Plaintiff reagrding and 0.40 discussing issues associated with reply in support of motion to dismiss to be filed in this matter. 03/02/15 JAG Draft detailed and lengthy agreed upon motion for extension of time to file 0.40 reply in support of motion to dismiss the amended complaint in this matter. 03/03/15 JAG Review court order granting Defendant Morgan's extension of time to file a 0.10 response to motion to dismiss. 03/03/15 JAG Review court order granting our extension of time to file a response to 0.10 motion to dismiss. 03/05/15 JAG In prepation of drafting extremely lengthy reply in support of motion to 1.20 dismiss Plaintiffs amended complaint review and analyze additional case law and statutory authority regarding whether or not Defendant was a state actor. 03/05/15 JAG In prepation of drafting extremely lengthy reply in support of motion to 1.00 dismiss Plaintiffs amended complaint review and analyze additional case law and statutory authority regarding Plaintiffs inability to maintain a claim for civil conspiracy. 03/05/15 JAG Commence drafting extremely lengthy reply in support of motion to 2.90 CC: Elizabeth Mulligan Robert Sweetapple Page: 12 Invoice No. 478934 June 9, 2015 dismiss Plaintiffs amended complaint specifically section reiterating position that Plaintiff has failed to set forth fact sufficient to assert a viable claim for slander per se. 03/05/15 JAG Drafting extremely lengthy reply in support of motion to dismiss Plaintiffs 2.80 amended complaint specifically section reiterating position that Plaintiff has not addressed or refuted Defendant's position that its statements were of pure opinion precluding a slander per se claim and thus cannot defeat the motion to dismiss. 03/05/15 JAG Drafting extremely lengthy reply in support of motion to dismiss Plaintiffs 3.10 amended complaint specifically section reiterating position that Plaintiff as a public figure or limited public figure remains unable to estbalish that Defendant acted with the requisite malice to sustain a claim for slander let alone slander per se. 03/06/15 JAG Review and analyze Defendant, Mayor Scott Morgan's Reply in Support of 0.60 His Motion to Dismiss (12 pages). 03/06/15 ES Draft responses and objections to plaintiffs voluminous first request for 2.20 admission (42 requests) to Defendant, Sweetapple. 03/06/15 ES Draft responses and objections to Plaintiffs first set of interrogatories to 1.60 Defendant, Sweetapple. 03/06/15 ES Draft responses and objections to Plaintiffs first set of requests for 2.60 production (45 requests) to Defendant, Sweetapple. 03/06/15 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.30 discussing issues associated with responses to discovery. 03/06/15 JAG Drafting extremely lengthy reply in support of motion to dismiss Plaintiffs 3.00 amended complaint specifically section reiterating position that Plaintiff cannot maintain a claim for first amendment retaliation under 1983 action as Defendant was not and cannot be a state actor or a private actor under the color of authority of the state law. 03/06/15 JAG Drafting extremely lengthy reply in support of motion to dismiss Plaintiffs 3.00 amended complaint specifically section reiterating position that Plaintiff cannot maintain an independent claim for civil conspiracy as the limited requisite elements to maintain such a claim are not part of this matter. 03/06/15 JAG Drafting extremely lengthy reply in support of motion to dismiss Plaintiffs 2.90 amended complaint specifically section reiterating position that Plaintiff cannot maintain its claim for conspiracy for slander per se or retaliation as the are no valid underlying torts or wrongs for which the conspiracy claim stands. 03/09/15 JAG Supplemenatl drafting lengthy and detailed responses and objections to 1.80 Plaintiffs voluminous requests for production in this matter. CC: Elizabeth Mulligan Robert Sweetapple CC: Elizabeth Mulligan Robert Sweetapple Page: 13 Invoice No. 478934 June 9, 2015 03/09/15 JAG Supplemenatl drafting lengthy and detailed responses and objections to 1.40 Plaintiffs voluminous requests for admissions in this matter. 03/09/15 JAG Supplemental drafting lengthy and detailed responses and objections to 1.40 Plaintiffs voluminous interrogatoires in this matter. 03/09/15 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.30 discussing issues associated with Plaintiffs responses to Defendant's first set of interrogatories in effort to respolve same. 03/09/15 JAG Receipt, review and analysis of correspondence from R. Sweetapple 0.10 regarding and discussing issues associated with additional law suit filed against same. 03/09/15 JAG Receipt, review and analysis of further correspondence from R. Sweetapple 0.10 regarding and discussing issues associated with additional law suit filed against same. 03/09/15 JAG Draft correspondence to It Sweetapple regarding and discussing issues 0.20 associated with discovery in this matter, in particular written responses to same. 03/09/15 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.40 discussing issues associated with discovery in this matter, in particular written responses to same. 03/10/15 ES Conduct extensive and specific analysis of Florida judicial authorities 0.80 arising under factual circumstances similar to the above -referenced matter re: whether an attomey-client privilege exists when representing a municipality, in preparation for preparing response and objections to Plaintiffs discovery requests. 03/10/15 ES In preparation for responding and objecting to plaintiff's discovery requests 0.70 and to ensure a proper objection to same, prepare a detailed response to inquiries pertaining to whether there exists an attomey-client relationship when representing a municipality, noting that section 286.011(8) was enacted to enable a governmental entity to meet privately with its attorney provided certain conditions are met, and that the communications at issue likely did not violate the exemption of the Sunshine Law because it did not go beyond the permissible scope of a strategy session. 03/10/15 JAG Teleconference with R Sweetapple regarding and discussing issues 0.20 associated with proposed discovery responses in this matter. 03/10/15 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.30 issues associated with proposed discovery responses in this matter. 03/10/15 JAG Follow up teleconference with R. Sweetapple regarding and discussing 0.20 issues associated with pmposed discovery responses in this matter. 03/10/15 JAG Teleconference with C. Bailey, paralegal for R. Sweetapple regarding and 0.10 CC: Elizabeth Mulligan Robert Sweetapple Invoice No. 478934 Page: 14 June 9, 2015 discussing issues associated with proposed discovery responses in this matter. 03/10/15 JAG Attendance at meeting with R. Sweetapple regarding and discussing issues 1.30 associated with discovery in this matter in effort to finalize same. 03/10/15 JAG Further supplement responses and objections to Plaintiffs voluminous first 0.90 request for production pursuant to meeting with client. 03/10/15 JAG Further supplement responses and objections to Plaintiffs voluminous first 0.60 request for admissions pursuant to meeting with client. 03/11/15 JAG Further supplement and finalize responses and objections to Plaintiffs 1.00 voluminous first request for admissions pursuant to meeting with client. 03/11/15 JAG Further supplement and finalize responses and objections to Plaintiffs 2.80 voluminous first set of interrogatories pursuant to meeting with client. 03/11/15 JAG Teleconference with cousnel for Gulf Stream in Federal Rico matter. 0.10 03/11/15 JAG Exchange correspondence with cousnel for Gulf Stream in Federal Rico 0.30 matter. 03/11/15 JAG Receipt, review and initial analyziz of Exhibits to Complaint in the Town 0.90 of Gulf Stream's Federal Rico matter in support of our defensive position. 03/11/15 JAG Draft correspondence to R Sweetapple regarding and discussing issues 0.20 associated with discovery in this matter. 03/12/15 JAG Review and analyze defendant Mayor Scott Morgan's Reply in Support of 0.30 his Motion to Stay Discovery. 03/13/15 JAG Teleconference with C. Bailey, paralegal for R. Sweetapple, regarding and 0.10 discussing issues associated with finalizing discovery responses. 03/13/15 JAG Teleconference with R. Sweetapple, regarding and discussing issues 0.20 associated with finalizing discovery responses. 03/13/15 JAG Exchange correspondence with C. Bailey, pamlgeal for R. Sweetapple, 0.30 regarding and discussing issues associated with finalizing discovery responses. 03/13/15 JAG Finalize drafting and supplementing responses and objections to Plaintiffs 1.50 voluminous first request for admissions pursuant to discussion with R. Sweetaple. 03/13/15 JAG Finalize review, analyzing and preparing responsive documents to be 0.50 produced to counsel for Plaintiffs counsel in this matter. 03/17/15 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.30 discussing issues associated with resposnes to Defendant first set of CC: Elizabeth Mulligan Robert Sweetapple Invoice No. 478934 Page: 15 June 9, 2015 CC: Elizabeth Mulligan Robert Sweetapple interrogatories. 0324/15 JS2 Conduct, analyze and highlight results of an online investigation conducted 0.50 of Florida license plate WER3X through Accurint. 0326/15 JAG Teleconference with counsel for Town of Gulf Stream, J. O'Connor 0.20 regarding and discussing issues associated with Rule 26 disclosures and recently filed sunshie law lawsuit. 0326/15 JAG Draft followup correspondence to counsel for Town of Gulf Stream, J. 0.20 O'Connor regarding and discussing issues associated with Rule 26 disclosures and recently filed sunshie law lawsuit. 0328/15 JAG Exchange correspondence from counsel for Plaintiff regarding with 0.20 discussing issues associated with responding to Defendant's interrogatories. 03/30/15 JAG Review and analyze Plaintiffs Responses and Objections to our First Set of 0.70 Interrogatories. 03/31/15 JAG Commence lengthy and detailed initial case analysis in this matter, 1.50 specifically section setting forth lengthy factual and procedural history in this matter including but not limited Plaintiffs long hisony with the Town of Gulf Stream. 03/31/15 JAG Draft correspondence to R. Sweetapple regarding, discussing and analyzing 0.20 Plaintiffs responses to Interrogatories and handling of this matter going forward based upon same. 04/01/15 JAG Analysis of Trial Order & Discovery Deadlines & Referring Case to 0.60 Mediations to determine deadline dates of discovery, amending pleadings, motions and joint pretrial stipulation and requirements of the court regarding exhibits and jury instructions and prepare trial sheet containing same. 04/01/15 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.20 associated with Plaintiffs discovery responses as well as strategy in proceeding forward with same. 04/01/15 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.40 issues associated with Plaintiffs discovery responses as well as strategy in proceeding forward with same. 04/15/15 JAG Teleconference with R. Sweetapple regarding and discussing another suit 0.10 filed against him by O'Boyle under Florida's Sunshine laws. 0422/15 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.60 discussing issues associated with this matter, in particular outstanding discovery issues. 0422/15 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.20 issues associated with third suit filed by O'Boyle. CC: Elizabeth Mulligan Robert Sweetapple CC: Elizabeth Mulligan Robert Sweetapple Page: 16 Invoice No. 478934 June 9, 2015 0422/15 JAG Receipt, review and analysis of motions to dismiss filed in third suit filed 0.30 by O'Boyle against Sweetapple, this one for sunshine law violations. 0424/15 JAG Exchange further communication with counsel for Plaintiff regarding and 0.60 discussing issues associated with outstanding discovery and conferal with respect to same. 05111115 JAG Teleconference with counsel for Town of Longport, NJ regarding and 0.50 discussing subpoena served on former mayor as it relates to this matter and issues with respect to same. 05/11/15 JAG Exchange correspodnence with counsel for Town of Longport, NJ 0.40 regarding and discussing subpoena served on former mayor as it relates to this matter and issues with respect to same. 05/11/15 JAG Exchange correspodnence with counsel for Plaintiff, regarding and 0.30 discussing subpoena served on former mayor of Longport, NJ as it relates to this matter and issues with respect to same in particular failure to provide counsel notice of same. 05/11/15 JAG Teleconference with counsel for Mayor Morgan regarding and discussing 0.10 subpoena served on former mayor for Longport, NJ as it relates to this matter and issues with respect to same. 05/11/15 JAG Receipt, review and analysis of subpoena served on former mayor of 0.10 LongpoM NJ as it relates to this matter in order to assess issues with respect to same. 05/11/15 JAG Draft correspondence to B. Sweetapple regarding and discussing subpoena 0.20 served on former mayor of Longport, NJ as it relates to this matter and issues with respect to same in particular failure to provide counsel notice of same. 05/12/15 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.40 issues associated with subpoena served on former mayor for town of Longport, NJ and handling of same. 05/12/15 JAG Exchange correspondence with D. DeSouza regarding and discussing issues 0.30 associated with subpoena served on former mayor for town of Longport, NJ and handling of same. 05/12/15 JAG Teleconference with R. Sweetapple regarding and discussing numerous 0.20 issues in this matter with respect to discovery and handling matter going forward. 05/13/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 0.80 report, specifically further setting forth issues as it relates to factual background in this matter. 05/13/15 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.30 CC: Elizabeth Mulligan Robert Sweetapple Page: 17 Invoice No. 478934 June 9.2015 discussing issues associated with numerous discovery issues to be resolved. 05/13/15 JAG Teleconference with counsel for Town of Longport, NJ regarding and 0.20 discussing issues associated with subpoena served on former mayor as it relates to this matter. 05/13/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 1.30 report, specifically forth critical issues to be addressed in this matter as it relates to liability damages, experts as to liability and damages and keys to this matter. 05/14/15 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.20 associated with this matter, in particular deposition of witnesses and proposed handling of same. 05/14/15 JAG Exchange correspondence with counsel for Town of Longport, NJ 0.30 regarding and discussing issues associated with deposition of former mayor in effort to resolve same. 05/14/15 JAG Teleconference with counsel for Town of Longport, NJ regarding and 0.20 discussing issues associated with deposition of former mayor in effort to resolve same. 05/14/15 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.20 issues associated with recently filed bar complaint by C. O'Hare as it relates to this matter. 05/14/15 JAG Initial review and analysis of extremely lengthy and detailed bar complaint 0.40 filed by O'Hre against Sweetapple in order to assess claims and determine appropriate response to same. 05/14/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 1.50 report, specifically forth critical issues to be addressed in this matter as it relates to liability damages, experts as to liability and damages and keys to this matter. 05/15/15 JAG Exchange correspondence with counsel for O'Boyle regarding and 0.80 discussing numerous issues associated with discovery in order to resolve same. 05/15/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 0.90 report, specifically forth critical issues to be addressed in this matter as it relates to liability damages, experts as to liability and damages and keys to this matter. 05/15/15 JAG Teleconference with counsel for Town of Longport, NJ regarding and 0.30 discussing issues associated with depositions of several town residents to be taken by O'Boyle. 05/15/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 0.60 report, specifically forth key evolutions in this matter as to the strengths and CC: Elizabeth Mulligan Robert Sweetapple Invoice No. 478934 Page: IS June 9, 2015 CC: Elizabeth Mulligan Robert Sweetapple weaknesses with respect to the calms and defenses. 05/17/15 JAG Exchange correspondence with counsel for Plaintiff regarding and 0.50 discussing issues associated with proposed deposition to occur on NJ Longport residents. 05/18/15 SJV Receipt and review of correspondence from Elizabeth Mulligan relative to 0.10 issues in the case and strategy moving forward with response and extension to respond. 05/18/15 JAG Exchange correspondence with E. Mulligan regarding and discussing issues 0.00 associated with bar complaint filed by C. O'Hare as related to this matter. 05/18/15 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.30 issues associated with but complaint filed by C. O'Hare as related to this matter. 05/18/15 JAG Receipt, review and analysis of lengthy and detailed bar complaint and 2.60 correspondeing exhibits filed by C. O'Hare as relates to this matter. 05/19/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 0.90 report, specifically forth key evalutions in this matter as to the strengths and weaknesses with respect to the calms and defenses. 05/19/15 JAG Exchange correspondence with counsel for Plaintiff, regarding and 0.30 discussing issues associated with the Deposition of former mayor for town of longport, NJ and objections to same. 05/19/15 JAG Receipt, review and analysis of notice of chage of address for counsel for 0.10 Plaintiff. 05/19/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 1.30 report, specifically forth key evalutions as it relates to the possibility of joint and several liability in this matter. 05/19/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 1.40 report, specifically forth key evalutions as it relates to the possibility contibutory and or comparative negligence considerations. 05/19/15 JAG Continue drafting lengthy and detailed initial legal analysis of management 0.50 report, specifically case management and settlement considerations. 0522/15 JAG Review and analyze Subpoena to Testify at a Deposition Duces Tecum 010 directed to Nicholas Russo in New Jersey. 0522/15 JAG Review and analyze Subpoena to Testify at a Deposition Duces Tecum 020 directed to Peter Isen in New Jersey. 0522/15 JAG Exchange correspondence with counsel for town in NJ regarding 0.20 subpoena's duces tecum issued to several residents who were previously sued by O'Boyle for slander claims. CC: Elizabeth Mulligan Robert Sweetapple Page: 19 Invoice No. 478934 June 9, 2015 0529/15 JAG Teleconference with M. Hann, counsel for Chris O'Hare regarding and 0.20 discussing issues associated with deposition of same. 0529/15 JAG Teleconference with L. Roeder counsel for Chris O'Hare regarding and 0.10 discussing issues associated with deposition of same. Total Hours 74.00 Summary of Services Atty Hours Rate Value ES Sprechman, Eric 7.90 50.00 395.00 JAG Goldstein, Joshua A. 65.50 125.00 8,187.50 JS2 Spiegel, Jennifer 0.50 50.00 25.00 S1V Vine, Jonathan 0.10 150.00 15.00 Total Fees 74.00 $8,622.50 Disbursements Cost Description Amount Copies (Qty: 562.0000 Qn.0.25) 140.50 Total Disbursements $140.50 Matter Summary 0062-00 — Martin E. O'Boyle v. Robert A. Sweetapple and Scott Morgan Total Fees $8,622.50 Total Disbursements $140.50 Total This Invoice $8,763.00 Payor Bill Summary Sweetapple, Broeker & Varkas, P.L. CC: Elizabeth Mulligan Robert Sweetapple Invoice No. 478934 100.0000 % Total Fees 100.0000 % Total Disbursements Total Due SUMMARY OF OUTSTANDING INVOICES Invoice # Invoice Date Total Billed 464314 March 26, 2015 $11,672.54 478934 June 9, 2015 $4,485.33 Total Due this Matter for all OUTSTANDING INVOICES for Sweetapple, Broeker & Varkas, P.L. Page: 20 June 9, 2015 $4,356.47 $128.86 $4,48533 Total AR $11,672.54 $4,485.33 $16,157.87 Deductible amount as per Agreement is $25,000 to be paid by Sweetapple, Broeker &Varkas, P.L. Deductible amount paid to date by Sweetapple, Broeker & Varkas, P.L. is $8,842.13 Sweetapple, Broeker & Varkas, P.L. Responsibility for this invoice is $4,485.33 T®WfV ®F GULF STRE 0, PAYMENT APPROVED -4 CC: lCheck #, Elizabeth Mulligan Robert Sweetapple Page: 24 Invoice No. 464314 March 26, 2015 Cost Description Amount Copies (Qty: 529.0000 @ 0.25) 132.25 Long Distance Telephone 2.79 Charges Total Disbursements $135.04 Matter Summary 0062-00 — Martin E. O'Boyle v. Robert A. Sweetapple and Scott Morgan Total Fees $11,537.50 Total Disbursements $135.04 Total This Invoice $11,672.54 Payor Bill Summary Sweetapple, Broeker & Varkas, P.L. 100.0000 %Total Fees $11,537.50 100.0000 %Total Disbursements $135.04 Total Due $11,672.54 VN OF GULF STREAM ► PAYMENT APPROVED -4 11 1.12.6,f- CC: .12.5,f- CC: lCheck #. Elizabeth Mulligan Robert Sweetapple MIAMI - WEST PALM BEACH - TAMPA- KEY WEST- FT. LAUDERDALE EAST- FT. LAUDERDALE WEST- NAPLES JACKSONVILLE- ORLANDO - PENSACOLA- BONITA SPRINGS Robert Sweetapple Sweetapple, Broeker & Varkas, P.L. 20 S.E. 3rd Street Boca Raton FL 33432 Sweetapple, Broeker & Varkas, P.L. Re: 0062-00—Martin E. O'Boyle v. Robert A. Sweetapple and Scott Morgan Claim Number 4020140930001 For Professional Services Rendered through February 28, 2015 ACCOUNTING DEPARTMENT OADELAND CENTRE II 9150 SOUTH DADELAND BOULEVARD SUITE 1400 MIAMI, FLORIDA 33156 TELEPHONE (305) 350.5300 FACSIMILE (305)373-2294 E -Mail: acmuntina0=kleaal com WEBSITEv .csklegal.com FEDERAL TAx ID# 65-0792149 March 26, 2015 Client No. 1601 Invoice No. 464314 Date Atm Descrlotion Hours 12/08/14 JAG Receipt, review and analysis of Plaintiffs Motion for leave to file an 0.30 Amended Complaint. 12/08/14 JAG Receipt, review and initial analysis of Plaintiffs Amended Complaint in 0.90 order to asses new claims set forth in same as well as basis for motion to dismiss. 12/08/14 JAG Receipt, review and analysis of correspondence from counsel for Plaintiff 0.10 regarding and discussing issues associated with the filing of his amended complaint. 12/08/14 JAG Receipt, review and analysis of correspondence from counsel for Plaintiff 0.10 regarding and discussing issues associated with the proposed joint scheduling order and corresponding report. 12/08/14 JAG Receipt, review and analysis of the proposedjoint scheduling order to be 0.10 filed with the court in this matter. 12/08/14 JAG Receipt, review and analysis of the proposed joint scheduling report. 0.10 12/09/14 JAG Exchange correspondence with counsel for Mayor Morgan regarding and 0.30 discussing issues associated with the finalized proposed scheduling order and report to be submitted per order of court. 12/09/14 JAG Exchange voluminous correspondence with counsel for all parties 0.90 regarding and discussing issues associated with the finalized proposed scheduling order and report to be submitted per order of court in effort to resolve same. 12/09/14 JAG Conduct further review and analysis of Plaintiffs Amended Complaint in 1.20 Invoice No. 464314 order to assess and compare difference with orginal complaint and determine what if any basis for dismissal of said claims exist. 12/09/14 JAG Draft correspondence to R. Sweetapple regarding and discussing issues in this matter, in particular recently filed amended complaint and assessment of same. 12/10/14 JAG In preparation of drafting Defendant's initial disclosures as well as additional discovery requests, and in furtherance of defensive efforts in this matter, review and analyze deposition of Plaintiff Martin O'Boyle taken by Robert Sweetapple in underlying matter. 12/10/14 JAG Receipt, review and analysis of correspondence from R. Sweetapple regarding and discussing issues associated with this matter in particular actions of O'Boyle and rule 26 disclosures. 12/10/14 JAG Receipt, review and analysis of correspondence of Gulf Stream's response to motion to disqualify filed in underlying action is furtherance of defensive efforts. 12/10/14 JAG Teleconference with R. Sweetapple regarding and discussing issues associated with this matter, in particular defensive efforts and Rule 26 disclosures. 12/10/14 JAG In preparation of drafting Defendant's Rule 26 Disclosures commence review and analysis of background on Martin O'Boyle and entitles to ensure that all individuals who have been subject to the same scheme and strategy of O'Boyle are potential witnesses in this matter. 12/11/14 JAG Review and analyze lengthy order setting trial date & discovery deadlines, referring case td mediation & referring discovery motions to magistrate. 12/11/14 JAG Review and analysis of Gulf Streams response in opposition to motion to disqualify Sweetapple as counsel in order to further assess underlying actions and purported claims against Defendant in this matter as well as additional factual support. (37 pages) 12/11/14 JAG Teleconference with counsel for Mayor Morgan regarding and discussing isses associated with amended complaint as well as discovery in this matter and strategy in proceeding forward with same. 12/11/14 JAG Exchange correspondence with counsel for Mayor Morgan, H. Gill regarding and discussing numerous additional law suits filed by Plaintiff against other entities in similar fashion to those at issue in this matter including slander claims. 12/11/14 JAG In preparation of drafting Defendant's Rule 26 Disclosures continue review and analysis of background on Martin O'Boyle and entitles to ensure that all individuals who have been subject to the same scheme and strategy of O'Boyle including slander claims are listed as potential witnesses in this matter as well as all known associates. CC: Elizabeth Mulligan Robert Sweetapple Page: 14 March 26, 2015 0.20 2.50 0.10 0.10 0.20 1.50 0.30 1.20 0.40 0.40 1.30 CC: Elizabeth Mulligan Robert Sweetapple Page: 15 Invoice No. 464314 March 26, 2015 12/11/14 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.30 issues associates with this matter in particular the court's issuance of its scheduling order. 12/12/14 JAG Commence drafting lengthy and detailed interrogatories to propound on 0.70 Plaintiff regarding and specifically tailored to claims for defamation and slander. 12/12/14 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.20 associated with suit filed by CAM and claims being asserted in same. 12/12/14 JAG Receipt, review and analysis of CAFI's motion to file exhibits under seal as 0.30 it relates to motion for entry of order to show cause and return of documents allegedly in possession of R. Sweetapple, in furtherance of our defensive efforts and O'Boyles counter actions taken against same. (41 pages). 12/12/14 JAG Receipt, review and analysis of Sweetapple's motion to dismiss complaint 0.10 against same by CAFI, in furtherance of our defensive efforts and O'Boyles counter actions taken against same. 12/12/14 JAG Receipt, review and analysis of Sweetapple's motion to strike complaint 0.10 filed by CAFI filed against same as a sham, in furtherance of our defensive efforts and O'Boyles counter actions taken against same. 12/12/14 JAG Receipt, review and analysis of Sweetapple's motion to compel deposiiton 0.10 of CAFI corporate representative and potential integral witness in this matter, D. De Martini, in furtherance of our defensive efforts and O'Boyles counter actions taken against same. 12/12/14 JAG Receipt, review and analysis of CAFI's Motion for Order to show cause as 0.60 to Sweetapple, for alleged possession of documents which could be integral in this matter, claiming said documents are confidential and privileged in nature and wrongfully acquired, in furtherance of our defensive efforts and O'Boyles counter actions taken against Sweetapple. (39 pages). 12/12/14 JAG Receipt, review and analysis of CAFI's Complaint against Sweetapple, for 0.00 alleged possession of documents which could be integral in this matter, claiming said documents are confidential and privileged in nature and wrongfully acquired, in furtherance of our defensive efforts and O'Boyles counter actions taken against Sweetapple. (10 pages). 12/15/14 BAP Review and analysis of motions filed by CCAFI describe Complaint, for 0.50 directive verdict, for Sanctions in Order to Show Cause relative to documents as well as other issues. 12/15/14 BAP Preparation of an outline of manner in which we will proceed in response to 0.20 motions filed by CCAFI. 12/15/14 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.80 CC: Elizabeth Mulligan Robert Sweetapple Page: 16 Invoice No. 464314 March 26, 2015 issues associated with claims filed by CAFI and handling of same 12/15/14 JAG Commence drafting lengthy and detailed initial disclosures, pursuant to 1.30 Federal Rules of Civil Procedure, Rule 26, setting forth over 40 potential factual witness, and informatio/knowledge with respect to same. 12/16/14 JAG Further review and analysis of motion to show cause and complaint filed in 1.50 CAFI matter, pursuant to discussions with R. Sweetapple, as same provides additional facts and potential witnesses to put forth in Rule 26 disclosures. 12/17/14 JAG Review and analyze Order Setting Discovery Procedure on pre -hearing 0.30 communication and discovery motions from Magistrate Matthewman. (Attorney review required by Local Rules and ECF Rules) 12/17/14 JAG Continue drafting lengthy and detailed initial disclosures, pursuant to 3.80 Federal Rules of Civil Procedure, Rule 26, setting forth over 40 potential factual witness, as well as their location and informatio/knowledge they are each individually expected to present. 12/17/14 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.50 associated with this matter in particular information expected from several disclosed witnesses, additional witneeses to add as well as handling of CAFI matter. 12/18/14 JAG Review and analyze Plaintiffs Initial Disclosures, including individuals 0.70 likely to have discoverable information, location and description of documents and things, computation of damages and insurance agreements. 12/18/14 JAG Continue drafting lengthy and detailed initial disclosures, pursuant to 0.80 Federal Rules of Civil Procedure, Rule 26, setting forth over 40 potential factual witness, as well as their location and informatio/knowledge they are each individually expected to present. 12/18/14 JAG In furtherence of drafting detailed initial disclosures, review and analyze 1.00 additional information and backgrounds on several of the proposed witneeses who were subject to similar suits of Plaintiff in New Jersey and Tennessee. 12/18/14 JAG Continue drafting lengthy and detailed interrogatories to propound on 1.00 Plaintiff regarding and specifically tailored to claims for defamation and slander. 12/22/14 JAG Commence drafting lengthy and detailed initial case analysis in this matter, 2.00 specifically setting forth the attenuated factual and procedural history in this matter, and background on Plaintiff. 12/22/14 JAG Continue drafting lengthy and detailed initial disclosures, pursuant to 0.80 Federal Rules of Civil Procedure, Rule 26, setting forth over 40 potential factual witness, as well as their location and informatio/knowledge they are each individually expected to present. CC: Elizabeth Mulligan Robert Sweetapple Page: 17 Invoice No. 464314 March 26, 2015 12/23/14 JAG In preparation of finalizing Sweetapple's initial disclosures pursuant to Rule 0.90 26, conduct additional review and analysis of affidavit of Joel Chandler to assess any additional individuals to be named as well as other documents provided by client. 12/23/14 JAG Finalize drafting lengthy and detailed initial disclosures, pursuant to 0.80 Federal Rules of Civil Procedure, Rule 26, setting forth over 40 potential factual witness, as well as their location and informatio/knowledge they are each individually expected to present. 12/24/14 JAG Continue drafting lengthy and detailed interrogatories to propound on 1.80 Plaintiff regarding and specifically tailored to claims for defamation and slander. 12/24/14 JAG Finalize drafting lengthy and detailed initial disclosures, pursuant to 1.90 Federal Rules of Civil Procedure, Rule 26, setting forth over 40 potential factual witness, as well as their location and infornatio/knowledge they are each individually expected to present. 12/24/14 JAG Draft correspondence to R. Sweetapple regarding and discussing issues 0.20 assoicated with discovery in this matter, in particular, our initial disclosures as well as Plaintiffs. 12/29/14 JAG Review and analyze plaintiffs lengthy response and objections to our first 1.30 request for production in order to prepare a reply to same. (16 pages) 12/29/14 JAG Exchange correspodnence with counsel for Plaintiff regarding and 0.50 discussing issues associated with service of discovery and handling of same. 12/29/14 JAG Exchange correspodnence with counsel of record regarding and discussing 0.40 issues associated with mediation in this matter. 12/30/14 JAG Exchange correspodence with counsel of record regarding and discussing 0.30 proposed mediator in this matter and issues with respect to same. 12/30/14 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.10 associated with Rule 26 disclosures and proposed revisions to same. 12/31/14 JAG Revise Rule 26 Initial Disclosures pursuant to discussion with R. 0.50 Sweetapple. 12/31/14 JAG Exchange correspodnence with R. Sweetapple regarding and discussing 0.30 revisions to Rule 26 Disclosures, 12/31/14 JAG Exchange correspodnence with R. Sweetapple regarding and discussing 0.30 issues relative to proposed mediators in this matter and assessment of same. 12/31/14 JAG Exchange correspondence with counsel of regarding regarding and 0.70 discussing issues associated with service of Sweetapple's Initial Rule 26 disclosures. CC: Elizabeth Mulligan Robert Sweetapple Page: 18 Invoice No. 464314 March 26, 2015 12/31/14 JAG Receipt, review and analysis of correspodnence regarding and discussing 0.10 issues associated with Co -Defendant, Morgan's Initial Rule 26 disclosures. 12/31/14 JAG Receipt, review and analysis Co -Defendant, Morgan's Initial Rule 26 0.40 disclosures. 12/31/14 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.20 issues associated with Co -Defendant, Morgan's initial disclosures. 12/31/14 JAG Commence drafting Motion to Dismiss Plaintiffs Amended Complaint in 2.10 this matter, specifically, drafting section setting forth revised factual and procedural history in this matter based upon addtional allegations set forth in the complaint. 01/02/15 BAP Review and analysis of correspondence from Claim Handler, Elizabeth 0.10 Mulligan, with regard to mediation. 01/02/15 BAP Preparation of responsive correspondence to Claim Handler, Elizabeth 0.10 Mulligan, with regards to mediation and other issues associated with same. 01/02/15 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.10 associated with this matter and related CAF[ matter as well as served Rule 26 Disclosures. 01/02/15 JAG Draft correspomdence to R. Sweetapple regarding and discussing issues 0.20 associated with this matter and related CAM matter as well as served Rule 26 Disclosures. 01/02/15 JAG Exchange correspondence with E. Mullins regarding and discussing issues 0.10 associated with proposed mediators in this matter. 01/06/15 BAP Review and analysis of court order on Motion to Dismiss. 0.10 01/06/15 JAG Review and analyze Order denying as moot our Motion to Dismiss for 0.00 Failure to State a Claim because the court granted plaintiffs Motion for Leave to File Amended Complaint. 01/08/15 JAG Exchange correspondence with counsel for O'Boyle, D. DeSouza regarding 0.30 and discussing issues associated with mediation in this matter and proposal with respect to same to comply with court order. 01/09/15 JAG Receipt, review and analysis of Plaintiffs lengthy and detailed amended 1.10 complaint, filed in compliance with the court's order, in order to assess response to same. 01/09/15 JAG Exchange further communications with Plaintiffs counsel regarding and 0.30 discussing issues associated with mediation in this matter. 01/12/15 JAG Draft extremely lengthy and detailed correspondence to Plaintiffs counsel 4.90 setting forth the numerous deficiencies in his responses and objections to CC: Elizabeth Mulligan Robert Sweetapple Invoice No. 464314 our first request for production in an effort to resolve same without court intervention. 01/12/15 JAG Commence drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically section setting forth summary of the factual and background allegations as set forth in same to the extent said allegations benefit future legal arguments. 01/14/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically memorandum of law section setting forth position that Plaintiff has failed to assert a vialble cause of action for slander per se. 01/14/15 JAG Exchange correspondence with counsel for Plaintiff regarding and discussing issues associated with discovery deficiency and requirement to meet and confer. 01/14/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically memorandum of law section setting forth position that Plaintiffs slander per se allegations fail as there are insufficient facts to maintain said claim. 01/14/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically memorandum of law section setting forth position that Plaintiffs slander per se allegations fail as the purported statements are not actionable as opinion as a matter of law. 01/14/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically memorandum of law section setting forth position that Plaintiffs slander per se allegations fail as he cannot establish that Sweetapple acted with the requisite malice. 01/15/15 JAG Teleconference with counsel for Plaintiff in order to meet and confer with respect to discovery issues set forth in deficiency letter. 01/16/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically memorandum of law section setting forth position that Plaintiff cannot maintain a claim for first amendment retaliation. 01/16/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically further draft memorandum of law section setting forth position that Plaintiffs slander per se allegations fail as he cannot establish that Sweetapple acted with the requisite malice. 01/19/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically memorandum of law section setting forth position that Plaintiffs claim for first amendment retaliation claim fails as Sweetaaple is not a state actor or acting under the color of state law. 01/19/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended Complaint, specifically memorandum of law section setting forth position that Plaintiffs claim for first amendment retaliation claim fails as Plaintiff CC: Elizabeth Mulligan Robert Sweetapple Page: 19 March 26, 2015 `tt 0.90 0.40 0.90 0.90 0.80 0.90 0.90 1.80 0.90 CC: Elizabeth Mulligan Robert Sweetapple Page: 20 Invoice No. 464314 March 26, 2015 has not been engaged in a protected activity and/or the purported conduct does not amount to retaliation. 01/19/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended 0.90 Complaint, specifically memorandum of law section setting forth position that Plaintiffs claim for civil conspiracy fails as Florida law does not recognize an independent claim for same. 01/19/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended 1.10 Complaint, specifically memorandum of law section setting forth position that Plaintiffs claim for conspiracy to commit slander per se and/or first amendment retaliation fails. 01/20/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended 1.80 Complaint, specifically memorandum of law section setting forth position that Plaintiffs claim for conspiracy to commit slander per se and/or first amendment retaliation fails as it does not allege fact sufficient to establish an actual conspiracy. 01/20/15 JAG Draft correspondence to R. Sweetapple regarding and discussing issues 0.10 associated with finalized motion to dismiss Plaintiffs Amended Complaint. 01/20/15 JAG Drafting lengthy and detailed motion to dismiss Plaintiffs Amended 2.60 Complaint, specifically memorandum of law section setting forth position that Plaintiffs claims in total are barred by Florida's litigation immunity privilege despite Plaintiffs attempt to plead around such a position in his amended complaint. 01/21/15 JAG Exchange correspondence with counsel for Gulf Stream, H. Gill regarding 0.30 and discussing issues associated with motion to dismiss the amended complaint by same. 01/22/15 JAG Initial receipt, review and analysis of Plaintiffs First Request for 0.40 Production onf Sweetapple. 01/22/15 JAG Initial receipt, review and analysis of Plaintiffs First Request for 0.20 Production on Morgan. 01/22/15 JAG Initial receipt, review and analysis of Plaintiffs First set of interrogatories 0.40 on Sweetapple. 01/22/15 JAG Initial receipt, review and analysis of Plaintiffs First set of interrogatories 0.20 on Morgan. 01/22/15 JAG Initial receipt, review and analysis of Plaintiffs First set of Admissions on 0.40 Sweetapple. 01/22/15 JAG Initial receipt, review and analysis of Plaintiffs First set of Admissions on 0.20 Morgan. 01/22/15 JAG Finalize drafting lenthy and detailed fact specific interrogatories at it relates 2.30 CC: Elizabeth Mulligan Robert Sweetapple Page: 21 Invoice No. 464314 March 26, 2015 to claims for slander per se and retaliation. 01/22/15 JAG Draft correspondence to R. Sweetapple regarding and discussing issues 0.20 associated with this matter, specifically Plaintiffs discovery requests as well as out proposed interrogatories. 01/23/15 JAG Teleconference with R. Sweetapple regarding and discussing isses 0.20 associated wiht discovery propounded by Plaintiff. 01/23/15 JAG Receipt, review and analysis of correspondence from R. Sweetapple 0.10 regarding and discussing counterclaim filed against O'Boyle in town suit by Sweetapple as it relates to claims in this matter. 01/25/15 JAG Exchange correspondence with R. Sweetapple regarding and discussing 0.40 issues associated with proposed interrogatories as well as claims set forth in cross claim against O'Boyle in town suit. 01/26/15 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.20 associated with this matter, in particular interrogatories. 01/26/15 JAG Receipt, review and analysis of correspodnence from R. Sweetapple 0.10 regarding and discussing issues associated with this matter, in particular interrogatories. 01/26/15 JAG Exchange correspodnence with R. Sweetapple regarding article on public 0.20 records request fraud. 01/26/15 JAG Review and analysis of recent article publised on public records request 0.20 fraud as it relates to actions of O'Boyle and defense of claims against Sweetapple. 01/26/15 JAG Initial receipt and review of motion to dismiss amended complaint filed by 0.10 Mayor Morgan. 01/27/15 JAG Review and analysis of countercliaim/third-party complaint filed against 2.20 O'Boyle in underlying suit against town, as claims set forth in counterclaim have a direct impact on claims in this matter, in particular claims for slander per se. 01/27/15 JAG Review and analysis of lengthy and detailed motion to dismiss amended 0.50 complaint filed by Mayor Morgan in order to assess claims and defensive positions is this matter. 01/30/15 JAG Teleconference with J. O'Connor regarding and discussing issues 0.30 associated relative O'Boyle or an entity continues to make public records request. 01/30/15 JAG Commence preparation of responding to Plaintiffs volumnous request for 0.50 production and assess location of responsive documents. 02/04/15 JAG Finalize drafting interrogatories to propound on Plaintiff pursuant to 0.60 CC: Elizabeth Mulligan Robert Sweetapple Invoice No. 464314 Page: 22 March 26, 2015 CC: Elizabeth Mulligan Robert Sweetapple discussions with R. Sweetapple. 02/04/15 JAG Teleconference with R. Sweetapple regarding and discussing additional 0.20 interrogatories to propound on Plaintiff. 02/05/15 JAG Exchange correspondence with counsel for O'Boyle regarding and 0.30 discussing issues associated with response to our motion to dismiss. 02/06/15 JAG Review plaintiffs agreed motion for extension of time to file a response to 0.20 Sweetappple and Morgans motions to dismiss. 02/06/15 JAG Exchange correspodence with counsel for O'Boyle regarding and 0.30 discussing issues associated with responding to motion to dismiss the complaint. 02/09/15 JAG Review Order granting Plaintiffs motion for extension of time to file 0.10 response/reply to both defendants motion to dismiss. 02/10/15 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.20 associated with discovery served in this matter. 02/10/15 JAG Exchange coffespodnence with R. Sweetapple regarding and discussing 0.40 issues associated with discovery served in this matter. 02/10/15 JAG Teleconference with R. Sweetapple regarding and discussing issues 0.50 associated with response to Plaintiffs propounded discovery in this matter. 02/11/15 JAG Receipt, review and analysis of correspondence from counsel for Mayor 0.10 Morgan regarding and discussing request to seek a stay of same pending ruling on their motion to dismiss. 02/12/15 JAG Receipt, review and analysis of correspondence from counsel for O'Boyle 0.10 regarding and discussing issues associated with stay of discovery. 02/13/15 JAG Receipt, review and analysis of recently filed Class Action RICO suit filed 3.10 by Town of Gulf Stream against O'Boyle and other related entites as allegations and claims set forth in same go directly to defense of this matter, in particular defamation claims for truth. (50 pages w/o exhibits). 02/16/15 JAG Exchange correspondence with counsel of record regarding and discussing 0.40 issues associated with Mayor Morgan's request to stay discovery pending outcome of motions to dismiss. 02/17/15 JAG Review and analyze Defendam Mayor Scott Morgan's 25 page Motion to 0.40 Stay Discovery Pending Deterninatio of Entitlement to Qualified Immunity. 02/17/15 JAG Further review and analysis of extremely lengthy Federal Class Action 1.10 Rico matter filed by the Town of Gulf Stream in support of our defense in this matter. CC: Elizabeth Mulligan Robert Sweetapple Summary of Services Attv Hours Rate Page: 23 Invoice No. 464314 1.00 150.00 March 26, 2015 02/17/15 JAG Commence drafting lengthy and detailed responses and objections to 1.30 Plaintiffs first set of interrogatories propounded on Sweetapple. $11,537.50 02/18/15 JAG Teleconference with E. Mulligan regarding and discussing issues associated 0.10 with this matter and status as it relates to same. 02/19/15 JAG Initial receipt, review and analysis of Plaintiffs opposition to Sweetapple's 0.10 Motion to Dismiss. 02/19/15 JAG Initial receipt, review and analysis of Plaintiffs opposition to Mayor 0.10 Morgan's Motion to Dismiss. 02/23/15 JAG Review Defendant, Mayor Scott Morgan's Objections to the Plaintiffs 0.20 Initial Discovery Dated 1.21.15. 02/23/15 JAG Review and analysis of Plaintiffs lengthy response in opposition to 1.30 Sweetapple's motion to dismiss this matter in preparation of drafting response to same. 02/23/15 JAG Review, analysis and shepardize case law and statutory authority cited in 1.00 Plaintiffs lengthy response in opposition to Sweetapple's motion to dismiss in preparation of drafting response to same. 02/24/15 JAG Exchange correspondence with counsel for O'Boyle regarding and 0.30 discussing issues associated with responding to discovery propounded on Sweetapple and resolution of same. 02/26/15 JAG Draft correspondence to R. Sweetapple in order to provide status update as 0.20 to same, in particular proceeding forward with motion to dismiss as well as discovery in this matter. 02/28/15 JAG Commence drafting lengthy and detailed response in support of motion to 2.20 dismiss Plaintiffs Amended complaint responding to arguments raised in Plaintiffs opposition with respect to independent actions for conspiracy. Total Hours 92.10 Summary of Services Attv Hours Rate Value BAP Postman, Bary A. 1.00 150.00 150.00 JAG Goldstein, Joshua A. 91.10 125.00 11,387.50 Total Fees 92.10 $11,537.50 Disbursements CC: Elizabeth Mulligan Robert Sweetapple 13381 'OWN OF GULF STREAM OPERATING ACCOUNT 11/13/2015 To: Cole Scott & Kissane PA Ann: Accounting Dept. 9150 South Dadeland Blvd., Ste. 1400 464314 3262015 Legal-sweetapple $11,672.54 S0.00 S11,672.54 478934 6'9121115 legal-sweetapple $4,485.33 $0.00 $4,485.33 Totals: $16,157.87 $0.00 $16,157.87 001-531 III -51.1-I0 Legal Services - Admin TOWN OF GULF STREAM OPERATING ACCOUNT 100 SEA ROAD GULF STREAM, FL 33483-7427 (561) 276-5116 SUNTRUST BANK 63-215/631 PAY "Sixteen thousand one hundred fifty seven and 87/100 Dollars" TO THE ORDER OF Cole Scott & Kissane PA Attn: Accounting Dept. 9150 South Dadeland Blvd., Ste. 1400 Miami, FL 33156 AUTHORIZED SIGNATURE 11.01338Lill ®Shield CHECK DATE 13381 CHECK NO. 11/13/2015 13381 m CHECK AMOUNT e $" 16,157.87 8 , 4 Im 16� TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail January 8, 2016 Chris O'Hare [mail to: chrisoharegulfstream@gmail.com] Re: GS #2050 (Follow up record request - Fwd: GS #2037 (sweetapple conditional letter)) (1) Any payment to, and bills from, Cole, Scott & Kissane, P.A. far legal work completed on behalf of Robert Sweetapple since January 2015. (2) Any payment to, and billsfrom, Sweetaople, Broeker & Parkas, P.L. (or any otherfirm in which Mr. Sweetapple has an interest) for legal work completed on behalf of Robert Sweetapple since January 2015. (3) Any communication between the Town and anyone at Cole, Scott & Kissane, P.A. regarding the production of their Nov 10, 2015 letter. Dear Chris O'Hare [mail to: chrisohareeulfstream(a.email.coml, The Town of Gulf Stream received your original public records request on November 11, 2015. You should be able to view your request at the following link htto://www2.gulf- stream.or¢/weblink/O/doc/70266/Pagel.aVx. In future correspondence, please refer to this public records request by the above referenced numbers. For part 1 and 3, you will find the responsive records at the same above link. For part 2, no such records exist. We consider this closed. Sincerely, Town Clerk, Custodian of the Records From: Chris O'Hare <chrisoharegulfstream@gmail.com> Sent: Thursday, October 29, 2015 6:13 PM To: Bill Thrasher Subject: Public Record Request - sweetapple conditional letter Dear Custodian of Records, This email is a singular request for a public record. Please respond to this public record request in a singular manner and do not combine this public record request with any other public record requests when responding. Before making this public record request, I first searched the public records portion of your agency's website hoping I could locate the public record I seek without having to trouble you for It. Unfortunately I can not find the records I wish to examine. Background of the request: The adopted minutes of the Town Commission Meeting of Jan. 9, 2015 indicate that a motion by Mr. Ganger, amended by Mr. Stanley and seconded by Ms. White was passed unanimously by the Commission. The adopted amended motion was: Approve reimbursement of his (attorney Sweetapple's) legal expenses up to $25,000 with the condition that the Town be reimbursed if those fees are recoverable and as a condition of approval we (the Commission) should have a letter advising the name of the law firm handling the suit air behalf of Mr. Sweetapple's law firm, that they are indeed handling the case on behalf of the carrier and confirming the amount of the deductible and their hourly rate, along with the amount of expense that has been incurred to date. This record request is for that letter. I make this request pursuant to Article 1. Section 24 of the Florida Constitution and Chapter 119 of the Florida Statutes. If you contend that any of the records I am seeking, or any portion thereof, are exempt from inspection or disclosure please cite the specific exemption as required by 5119.07(1 Ne) of the Florida Statutes and state in writing and with particularity the basis for your conclusions as required by 4119.07(1)(f) of the Florida Statutes. Please take note of 4119.07(1)(c) Florida Statues and your affirmative obligation to (1) promptly acknowledge receipt of this public records request and (2) make a good faith effort which "includes making reasonable efforts to determine from other officers or employees within the agency whether such a record exists and, if so, the location at which the record can be accessed." I am, therefore, requesting that you notify every individual in possession of records that may be responsive to this public records request to preserve all such records on an immediate basis. 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(2)(f). Florida Statutes. Please provide only those records for inspection that do not require extensive use of information technologies or extensive staff time or both in excess of 15 minutes. Please take note of 4119.07(4)(a)3.(d) Florida Statues and if you anticipate that any records exist, the production for inspection of which will require extensive use of information technologies or extensive staff time or both in excess of 15 minutes, then please advise me of the cost you anticipate to be incurred by your agency prior to incurring this cost. Please do not incur any costs on my behalf without first obtaining my written authorization to proceed. If you anticipate the need to incur any costs that I would be statutorily required to pay in order to inspect these public records which would exceed $1.00 please notify me in advance of your incurring that cost with a written estimate of the total cost. Please be sure to itemize any estimates so as to indicate the total number of pages and/or records, as well as to distinguish the cost of labor and materials. Again, please do not incur any costs on my behalf without first obtaining my written authorization to proceed. I hereby reserve all rights granted to me under the Florida Constitution and Florida Statutes. All responses to this public records request should be made in writing to the following email address: chrisohareclulfstroam(@qmaii.com TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail November 10, 2015 Chris O'Hare [mail to: chrisoharegulfstream@gmail.com] Re: GS #2037 (sweetapple conditional letter) Background of the request: The adopted minutes of the Town Commission Meeting ofJan. 9, 2015 indicate that a motion by Mr. Ganger, amended by Mr. Stanley and seconded by Ms. White was passed unanimously by the Commission. The adopted amended motion was: Approve reimbursement of his (attorney Sweetapple's) legal expenses up to $25, 000 with the condition that the Town be reimbursed if those fees are recoverable and as a condition of approval we (the Commission) should have a letter advising the name of the law firm handling the suit on behalf of Mr. Sweetapple's law firm, that they are indeed handling the case on behalf of the carrier and confirming the amount of the deductible and their hourly rate, along with the amount of expense that has been incurred to date. This record request is for that letter. Dear Chris O'Hare [mail to: chrisohareeulfstreamOa gmail.coml, The Town of Gulf Stream received your public records request on October 29, 2015. You should be able to view your request at the following link http://www2.gulf- stream.org/weblink/O/doc/69567/Pagel.ppxx. In future correspondence, please refer to this public records request by the above referenced numbers. The responsive document is available at the same link. We consider this matter closed. Sincerely, Town Clerk, Custodian of the Records