HomeMy Public PortalAboutChris O'Hare Transcript 6/18/15CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
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UNITED STATES DISTRICT COURT
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I N D E X
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FOR THE SOUTHERN DISTRICT OF FLORIDA
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CASE N0. ll-ev-83053-XLR
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WITNESS: DIRECT moss REDIRECT RECROSS
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CHRIS O -HARE
CHRIS O'KARE,
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BY MR. STEARNS 4
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BY MR. HANNA 128
Plaintiff,
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BY MR. STEARNS 152
va.
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TOWN OF GULF STREAM;
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TOWN OF GULF STREAM COMMISSION;
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TOWN MANAGER WILLIAM THRASHER,
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E X H I B I T S
Town Manager, in his individual capacity and official
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capacity as the Town Manager for the Town of Gulf Stream;
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NUMBER FACE
TOM SPECIAL MAGISTRATE LANA DONLON,
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Special Magistrate, in her individual and official capacity
as a Special Magistrate for the Town of Gulf Stream;
DEFENDANT'S EXHIBIT C FOR ID 139
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OFFICER DAVID GINSBERG, Officer, in his individual capacity
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and official capacity as an Sergeant for the Town of Gulf
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Stream; STEVEN TOBIAS, Building Official, in his individual
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capacity and official capacity as a Building Official for
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the City of Delray Beach; and
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MARTY MINOR, Flaming Consultant, in his individual capacity
CERTIFIED QUESTIONS
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and official capacity as a Planning Consultant for the
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Town of Gulf Stream
PAGE LINE
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Defendants.
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87 2
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VIDEOTAPED
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DEPOSITION OF CHRIS O'HARE
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Thursday, June Is, 2015
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9:50 a.m. to 1:45 p.m.
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100 Sea Road
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Gulf Stream, Florida
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Reported By:
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PROCEEDINGS
DEBORAH LAWRENCE, Court Reporter
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videotaped deposition taken before DEBORAH LAWRENCE,
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Notary Public, State of Florida
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Esquire Deposition solutions
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Court Reporter and Notary Public in and for the Stale of
Sob q 342912
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Florida at Large, In the above cause.
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Thereupon,
APPEARANCES.
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(CHRIS O -HARE)
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On behalf of the Plaintiff
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having been duly swum or affirmed, was examined and
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MARK HANNA, ESQUIRE
GMM/ Madison P.A.
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testified as follows:
e
401 South County Road
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DIRECT EXAMINATION
Palm Beach, Florida 33480
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BY MR. STEARNS:
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On behalf of the Plaintiff
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Q. Please state your name for the record?
JONATHAN R. O'BOYLE, ESQUIRE
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The O'Boyle Law Firm, P.C.
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A. Chris Frances O'Hare.
1286 W. Newport Center Dr.
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Q. Good morning, Mr. O'Hare. As you know, my name Is
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Deerfield Beach, Florida 33442
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Christopher Stearns. I am here to take your deposition in
On behalf of the Defendants
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the federal litigation that you filed against the town and
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CHRISTOPHER STEARNS, ESQUIRE
Johnson, Anselmo, Murdoch, Burke, Piper A Hochman, P.A.
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David Ginsberg and Bill Thrasher.
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2455 E. Sunrise Blvd.
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Have you given a deposition before?
Ft. Lauderdale, Florida 33304
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A. Yes.
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Q. How many times?
ALSO PRESENT: Anthony Barbaro, Videographer
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William Thrasher
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A. A lot.
Officer Garrett Ward
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Q. For what purposes do you typically give
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depositions?
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A. I was deposed for hours in the motion to
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disqualify Robert Sweelapple as having represented me
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before. I have been deposed in a public records case. I've
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
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been deposed in a Intellectual property case in federal
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Designs.
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court in New York. I was deposed in another case in Arizona
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Q. You said also that you have other interests. What
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for a breach of contract.
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does that mean?
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Q. Okay.
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A. Real estate and Investments.
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A. That's about It.
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0. Where do you own real estate?
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Q. Clearly, you know the rules. I know you've been
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A. I have real estate holdings in Gulf Stream and
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sitting here and we discussed It. So let's try to make sure
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Ocean Ridge and unincorporated Palm Beach County. Boynton
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everything is oral. If you don't understand my question,
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Beach, North Carolina. I think that's all.
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let me know and I will rephrase that for you.
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Q. Are we talking homes?
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A. Yes, I do. I also ask that you speak up a little
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A. Industrial commercial property, duplexes and
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bit cause my ears are really ringing.
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homes.
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Q. No problem. Are you currently employed?
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0. How many lots do you own in Gulf Stream?
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A. Yes.
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A. Right now three.
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Q. Where?
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Q. What are those addresses?
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A. I own a company called Pineapple Grove Designs and
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A. Those are homes.
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a company called Reef Sales and a number of other interests.
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Q. What are the address?
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Q. What does Pineapple Grove Designs do?
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A. Sorry, I didn't hear you. The address is 2520
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A. We are sculpturing ornaments and medallions and
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Avenue Au Soleil, 2516 Avenue Au Soleil and 960 — sorry,
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works of art for a lot of government agencies, federal
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935 Orchid Lane. I think It's 935. It might be 930.
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government, municipalities, slates, office buildings,
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Q. You own so many properties you don't remember all
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schools, universities. Things like that.
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the addresses?
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Q. Are you the president?
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A. Well, my wife handles that. I'm the one that goes
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A. Yes.
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over and checks out the bathrooms and fridge. She manages
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Q. How many employees?
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paying the bills so she's mare familiar with the addresses
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A. Currently I would say about a dozen.
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than I am.
Page 6age
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Q. How much business do you do on a yearly basis?
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Q. What's your wife's name?
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A. Um, well, we were doing around $5 million a year.
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A. Shelly Childers O'Hare.
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Right now we are probably doing around a million and a
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Q. How long have you been married to Shelly?
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quarter, million and half. Depends on the DOT. They are
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A. Not long enough. I want to say about 35 years.
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pretty generous to us.
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Q. Where were you married?
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Q. A lot of your work comes from them. If they stop
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A. Ft. Lauderdale.
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asking for as much you take a bit of a downturn?
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Q. Do you have any children?
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A. Well, our work actually comes from architects who
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A. Two children.
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we market to. We market to 23,000 around the country. They
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Q. What are their names and ages?
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put us on the plans and the agencies will call us up to
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A. August O'Hare and Remi O'Hare.
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supply the product.
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Q. How old is August?
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Q. What does the second company Reef do?
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A. They are four months apart. They are both 16.
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A. Reef Sales, we make artifical reefs for the
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Q. They are four months apart?
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county, Department of Environmental Resources for years. We
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A. Different birth mothers. We adopted them. Very
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make memorial reefs for fallen firefighters, police
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lucky.
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officers. Right now we are doing a memorial reef for
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Q. You adopted them when they were babies?
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Jupiter inlet for a fellow whose son died last year at this
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A. We supported the mothers when they were pregnant.
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time. That is about 40 units that the Department of
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Adopted them, I think the rule was three days later. And
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Environmental Resources is going to deploy in about a month.
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the formal adoption in the court was six months after that.
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Q. How much business does Reef Sales do in?
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Q. You said they are both 16?
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A. Well, that is about $40,000 this year but that is
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A. Yes.
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lust reimbursement for materials and labor. We don't charge
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Q. What address do you currently live at? What
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any profit or overhead on that.
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address do you live at?
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Q. Are you the president?
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A. Right now 2520 Avenue Au Soleil.
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A. Yes. It is actually a d/b/a of Pineapple Grove
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Q. How long have you lived there?
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
1 A. Since we bought the place in 2011.
2 Q. Do you remember what month in 2011 you bought it?
3 A. I believe it was the very beginning of the year.
4 Might have been — I can't recall that exactly. It is
5 approximately In the spring.
6 Q. Tell me about 2520? How big a house is it?
7 A. Three bedrooms, three and a half bath with a
8 garage and a porch. Maybe 4,000 square feet. 3,500.
9 Something like that.
10 Q. How much did you purchase it for?
11 A. Um, around a half million I think.
12 Q. And when you purchased it you moved into it
13 Immediately?
14 A. Yes. I was very concerned for obtaining the
15 homestead exemption so we moved in immediately.
16 Q. Why do you say you were very concerned for
17 obtaining the homestead?
18 A. Cause I think the rules say you have to live in
19 the house to claim homestead exemption.
20 Q. Where were you living before to 2520?
21 A. We lived at 530 Middle Road in Gulf Stream.
22 Q. Was that property Homesteaded at that time?
23 A. It was the day we sold it.
24 Q. When did you sell ill
25 A. Just before the purchase of the 2520 property.
1 Q. So you sold 530 and moved directly into 2520 at
2 that time?
3 A. I think so. I think we had a little overlap there
4 before we closed on 2520.
5 Q. You switched the homestead from 530 to 2520
6 Immediately?
7 A. When we were legally allowed to we filled out the
8 paperwork.
9 Q. What type of work did 2520 need when you moved in?
10 A. It was filthy. Basically had to clean It up. We
11 Intended on remodeling but not right away. It was livable.
12 It just needed cleaning.
13 Q. Did you do any work that would require permits?
14 A. I didn't think so at the time. Then it was
15 brought to my attention that I did which I immediately got
16 the permit for a few days later. Then I come to find out 1
17 didn't need a permit. So to answer your question yes, no
18 and yes. Or no, yes and no.
19 Q. Okay. Let's explain that to me if you could.
20 What was the work that you were doing that you were then
21 told you need permits for?
22 A. The house had been built in the 70s and never
23 modified to my knowledge. Just didn't appear to be. The
24 Flooring had this 12 inch, one Inch thick Mexican clay tile
25 which was popular back then with the baby's footprint and
ESQUIRE
June 18, 2015
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1 the bicycle track in It. All kind of dated. So we took out
2 all the tile. The floors were uneven. We were going to
3 pour a levelling compound on the floors to reale. The
4 doors were pretty banged up and very inexpensive so we
5 replaced those with solid panel doors. Replaced the trim.
6 Replaced the dated cabinets. The electrical outlet had six
7 coats of paint. We were planning on replacing the outlets.
8 Of course painting and taking out the carpel. There was
9 some wood paneling on the wall too which was pretty awful.
10 You know, if was fine for somebody but we didn't like It.
11 So that's basically the work we planned on doing.
12 Q. Who did you hire to do this work?
13 A. Um, John Gundlach was hired to do some of the
14 finish work. He's really good at setting doors and detail
15 trim. Then a friend of a friend recommended this fellow
16 named Ramon who Is Spanish and he had some Cuban workers
17 that he brought a crew in basically. That crew did all the
18 rough work and some of the rougher carpentry the work.
19 Tile was his specialty.
20 Q. What about electrical outlets?
21 A. I was doing that myself.
22 Q. What experience do you have that would allow you
23 to do electrical work like that?
24 A. Well, when we came down here after my father died
25 my mother bought an apartment building. It was my job In
1 high school to take care of It. So I learned pretty early
2 how to do simple things like that. Later on I became a
3 general contractor and then after that I became a landscape
4 architect. After that manufacturing but I had a lifetime of
5 fixing places up.
6 Q. Okay. Let's actually walk through your work
7 experience, if you could. You just gave me a brief summary.
8 Give me a little more Information about where you did this
9 and what you've done professionally?
10 A. Well, I left University of Florida in the early
11 '80s. No, that would be in the'70s. Late'70s and
12 continued to help my mother with her real estate
13 maintenance. My brother Gregory O'Hare and I became
14 partners starting with landscaping. Then the landscaping
15 led to waterfalls, swimming pools, decks, gazebos. Most of
16 the exterior accoutrements of home Improvement. From there
17 we graduated Into general construction. We had experience
18 working for other fines and we both sat for our GC exam and
19 passed it the first time. proud to say. And opened up shop
20 offering light construction remodeling.
21 Q. Where was that?
22 A. That was mostly Ft. Lauderdale and In Hollywood
23 and Miami.
24 Q. What was the name of your shop?
25 A. It was O'Hare & O'Hare.
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
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Q. How long did O'Hare & O'Hare exist?
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A. I am sometimes surprised, I am in President
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A. I am thinking about 10 years.
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Obama's neighborhood in Hawaii. My pieces are all over the
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Q. Is this the'90s?
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place and I didn't know it. Kind of gratifying.
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A. This would have been In the'80s.
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Q. Can you describe a piece for me? What are those
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Q. And then you broke up, shut down, what happened?
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—
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A. Um, very difficult to make money. We decided that
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A. — these would be medallions, freezes or
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we were going to pursue different things. My brother became
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architectural panels. Pas Reil sculptures, P -A -S, R -E -1-L
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— worked for the City of Hollywood and became an Inspector
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which are shallow sculptural panels. Flowers, birds,
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and then later on a building official. So he went right up
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geometric shapes. Metal people, commemorative things. We
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to the top. And I started, I sal for my landscaping
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did a scuba diver reef to commemorate the fellow who founded
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architecture license and took that test. It was a three day
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Delray Ocean Rescue. Things like that. Anything you can
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test. Passed. I passed that. I was proud of that. 1
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Imagine that would be in a public place.
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practiced landscape architecture. I had clients, some of
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Q. You have anything to do with that reef that was
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the same clients that we had worked for earlier moving up
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dropped the other day?
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building bigger homes. That work was concentrated in Miami
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A. That was so unfortunate. That poor woman, she
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Beach for people like the Chrislies, K -Mart or Palm Beach
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spent a half million dollars and those guys, you have to
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for assorted very wealthy people up there.
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have — you know, it is not like Michelangelo. Actually,
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Q. How long did you do that work?
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Michelangelo is pretty big engineer. But you have to have
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A. I did that about 10 years.
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engineering knowledge to do public art. That fiasco was
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Q. We are now sometime in the '90s?
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really, you could see it coming.
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A. Right. Shelly and I decided that we really wanted
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Q. Is that the kind of work you do?
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to make something. The problem with design work Is, you
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A. No. God help those people. They did the best
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know, It Is somewhat artful but it is not long-lasting. It
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they could but that was really tacky. I try to slay more
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will be remodeled as soon as someone changes their mind or
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fine art.
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has a better idea. I always wanted to sculp. So I started
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Q. 1 mean, the reef aspect of it, you construct the
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age 16
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sculpting. Started marketing my sculpture but soon found
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reef?
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that's a hard way to make a living. Came up with the Idea
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A. No, we have done memorial reefs that are artistic.
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of marketing to architects for architectural sculpture. One
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The reefs we are doing now for the foundation are strictly
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commission led to another. There was many times when we
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geared towards attracting fish. But it also attracts divers
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were about to close the door but then a commission would
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to take pressure off the natural reef. The county's focus
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come in. And it just grew and grew from a garage to a small
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now is on producing reefs that bring divers away from the
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warehouse to 45,000 square foot facility.
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natural reef. The concept we came up with was to make an
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Q. That is the company you're running now?
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artificial reef that looks real. Like rocks. Yet it's got
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A. Yes, except in 2008 we cut back and now I only
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enough effective cavities of surface to be so much more
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occupy I think about 20,000 square feet.
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bio -effective than, say than just a pile of rocks.
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Q. Is that Pineapple Designs?
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Q. What's your date of birth?
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A. Yeah.
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A. April 8 — sorry, April 8, 1954.
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Q. When did you start that?
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Q. Your Social Security number?
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A. 1988 is when I carved my first panel. '91,'93 is
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A. Do I have to give that?
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when we started getting all the copyrights for all the
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MR. HANNA: I will provide It to you.
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additional work that we subsequently sold from Guam to Abu
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MR. STEARNS: Have him write it down.
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Dhabi.
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THE WITNESS: That's fine. The reason I say that
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Q. You're an artist?
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is the town has a bad history of Social Security
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A. I like to think of myself that way. But on the
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numbers being public records.
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other hand, I don't market myself that way. 1 have always
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MR. STEARNS: I won't make it part of the
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marketed the work and not promoted myself. If you do a
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transcript but I am entitled to it.
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search on me you're not going to find my sculpting. If you
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THE WITNESS: Thank you.
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look at any major municipality you're going to see my work
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BY MR. STEARNS:
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everywhere.
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Q. Who lives at the 2516 address?
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Q. Yeah?
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A. Right now it is vacant except I use it
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CHRIS OHARE
June 18, 2015
OHARE vs. TOWN OF GULF STREAM
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occasionally. We are looking for a tenant.
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A. No, no.
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Q. So you do rent it?
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Q. Who was doing the work?
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A. Yeah, we had it rented to a really lovely couple
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A. Ramon pulled all that drywall off for me. Started
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that have since — they were remodeling a house on North
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In one spot and I told him keep going until you get all the
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Ocean. They lived in our house for a year or so while they
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mold out.
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remodeled their house.
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Q. There was mold in what part of the house?
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Q. You were here for Mr. Gundlach's deposition half
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A. That would be that main living room kitchen area.
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an hour ago, 45 minutes ago?
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Q. That would be the area adjacent to the front
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A. Yeah.
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screen there?
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Q. He said something about your children living in
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A. If you could imagine the house is a letter H. It
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there?
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would be the crossbar.
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A. Right.
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Q. Could you describe the house for me? Basically
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Q. Has that ever been the case, your children lived
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let's do it this way. We have got here what's marked as
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in that house?
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exhibit B. We are looking at what?
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A. Just for a short period of time. Couple months.
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A. We are looking from the west facing east. This is
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Q. The children lived over there by themselves?
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the porch. It is a flat deck porch that is attached to the
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A. No, my wife was there with them. Basically I was
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rear of the house. The street is in the opposite side and
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there a lot of the time but I felt I needed to sleep at 2520
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there is a street on the north side. There is a six foot
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and have my clothes there just to make it legal for
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fence around the entire backyard.
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homesteading.
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Q. We are looking from the west; right?
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Q. So this is when all the work was going on?
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A. Actually, the picture was taken from the backyard
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A. When I was removing all the mold, as soon as I got
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of 2516 over the fence to the back of the house.
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that out of there then they came back In.
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Q. So this is the west. This Is east. This is
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Q. During the time of the alleged unlawful searches
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north, south?
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is when this was happening?
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A. This would be north, south.
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A. You mean the trespass?
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Q. Let me write that down. North, south. Okay. And
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Q. Whatever you want to call it.
2
you're saying there is a right on the north side?
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A. Yeah, October 28 the kids, they had their bedrooms
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A. There's a road on the north side of the house.
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and clothes next door. I was domiciled at 2520.
4
Q. And there's a road on the east side of the house?
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Q. So as of the date Mr. Ginsberg came to your
5
A. Yes.
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property October 28, 2011 your wife and the children were
6
Q. So you are in a comer lot?
7
living In the other address 2516?
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A. Right.
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A. Well, sleeping there. Their clothes were there.
8
Q. Okay. And what we are looking at here is a front
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Q. Fine. You were staying at 2520 by yourself for
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porch area?
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purposes of maintaining your homestead exemption?
10
A. This wall, screen wall actually returns back to
11
A. Right, and a portion of the house that wasn't
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the house about five or six feet on the south side and
12
under construction. We had TV, family time there. So
12
there's a screen door at the porch there. This screen of
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basically we were living in both places. But I was
13
course had been removed at the time.
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concerned for their well-being. That's why I took them out
14
Q. Why was the screen removed?
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of there.
15
A. Flaco, one of Ramon's men, which means skinny in
16
Q. You were concerned for their well-being because
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Spanish, funny guy. Flaco had backed through with it some,
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there was an extensive mold problem?
17
1 think he was taking a calling fan down and tore a big gash
18
A. Oh, yeah.
18
in it. And there was paint splattered on It from previous
19
Q. Describe that?
19
work. And we just decided It's going to be replaced, let's
20
A. Well, it was black and fuzzy. It was pervasive.
20
tale it out now. Helped get a breeze through there cause
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There was mold everywhere. I shouldn't say. There was mold
21
the flat roof was kind of hot to work under.
22
in the main portion of the house. I didn't find any in the
22
Q. Has it been re-screened?
23
bedrooms.
23
A. Oh, yeah. Screened just soon after that.
24
Q. Did you hire a remediation company to deal with
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Q. What we are looking at here is the screen again.
25
that?
25
Then you mentioned what rooms are adjacent to that
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CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM 21-24
1 screened -in area?
2 A. Okay. Do it from upside down. On this end of the
3 house is the bedroom.
4 Q. When you say this, we need to say?
5 A. The north side of the house are the bedrooms and
6 master bath and garage and laundry room. On the south of
7 the side of the house are two bedrooms and two bathrooms and
8 the kitchen area. So we are looking at the major great room
9 which it was called back then and the kitchen to the south
10 side of it.
11 Q. You heard Mr. Guncilach's testimony today?
12 A. Yeah.
13 Q. He said that Mr. Ginsberg stepped into the front
14 porch area and then would be the kitchen area then?
15 A. Well, the porch is about 16 or 18 feet deep. 1
16 believe I heard him testify that Officer Ginsberg went past
17 him in the doorway, walked through the porch over the
18 threshold of the sliding glass doors and into the great room
19 by a few feel. Five or six feet I think he said.
20 Q. The great room you're saying is -- I thought you
21 said the kitchen was over here on the south side?
22 A. When I'm pointing to this I mean this whole area
23 here is the great room. At the south end of the great room
24 is the kitchen area. So he is basically standing at the
25 divide between those rooms.
1 trailer and a container costs about $600 to get there and
2 about $300 where we live. And I thought we were doing this
3 on such a small scale I'll just put In the back of my
4 trailer and haul it back to the dumpster at my industrial
5 route.
6 Q. Were you making efforts to hide the fact that the
7 work was going on?
8 A. No. Neighbors are coming and going. No, we
9 didn't make any effort to hide anything.
10 Q. All right. Let's talk about that day. October
11 28, 2011. Where were you when everything went down?
12 A. I was at my business running a crew there and on
13 my way to the house when Mr. Gundlach called me on my cell
14 phone.
15 Q. What phone number was that?
16 A. I think It's the same one I have now. (561)
17 350-7551,
18 Q. Who is the carrier?
19 A. Verizon now. At the time it might have been AT&T.
20 1 can't remember though.
21 Q. On a typical day back in 2011 were you in the
22 office 9 to five? Did you go part-time? What did you do?
23 A. No, never. Very rarely I'm In the office. I'm
24 usually out in the production area or up in the carving
25 studio. At the time I think I had four sculptures working
1
Q. What was In the great room at this time?
1
up there and I was supervising all their work. So I was
2
A. We had removed the kitchen cabinets. We had
2
jumping from one task to another.
3
removed the drywall. We had chipped up the tile. There was
3
Q. You would leave the workers at the home by
4
part of the Floor had been poured with the self -levelling
4
themselves?
5
material. There was piles of trash from the attic. 1
5
A. Occasionally, yes.
6
believe there was a water heater and a lot of wire,
6
Q. On this day they were unsupervised?
7
telephone wire, security cable. It seemed every contractor
7
A. Typically I would be there first thing In the
8
ever did any work on the house never took his trash with
8
morning and meet them. You know, have some coffee, do some
9
him. Just pushed it aside in the attic and his put his new
9
bonding. Explain to them in their broken English and my
10
work next to it. So I wanted to get all that out. It had
10
broken Spanish what I wanted to accomplish. Leave them
11
been pulled out. There was a lot of insulation piled up
11
there while I went to the plant to work. I called the
12
which had animals nesting in it. There was one funny
12
building a plant. Then I would come back midday and then
13
incident when they were pulling down a piece of drywall
13
come back again the end of the day.
14
cover mold, this four foot snake fell out on the ground.
14
0. Come back midday, have lunch, check in on them and
15
They all jumped back. It was so funny. There was a lot of
15
then leave?
16
trash. Anyway, there was a lot of trash. It was all there
16
A. Yeah. Usually bring them lunch, make sure nobody
17
in a giant jungle. One thing I learned about construction
17
is getting hurt.
18
sites, you got to keep them clean. Officer Ginsberg just
18
0. How long was It that the work had been going on at
19
happened to be there the day when it wasn't clean.
19
the house as of this time?
20
Q. It was a mess?
20
A. I would say we started in September by removing
21
A. It was a mess. Probably looked horrendous.
21
some dead trees. A lot of work Shelly and I were doing
22
Q. Why was it that the trash was being kept in the
22
ourselves. So I would say sporadically probably started the
23
great room as opposed to bringing in a big garbage container
23
day we moved in. I don't think we could tolerate that awful
24
to get rid It?
24
shag carpet. Technically the work started the day we took
25
A. I didn't see the need for the container. I had a
25
possession of the property.
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OHARE vs. TOWN OF GULF STREAM
25-28
Page 25
Page ZI
1
Q. But you are not sure when that was?
1
There's no investigation of your background. You just pay
2
A. It is a matter of record. I'm sure we can find
2
the fee, you get a sticker and then you can work in the
3
that for you.
3
town. I guess the town uses the sticker so they can drive
4
Q. Let's estimate. The work had been going on for a
4
by and know that people are supposed to be there who are
5
couple months by this time?
5
there. I could see the sense in that.
6
A. No, no. To be clear, the kind of work I think
6
Officer Ginsberg took me aside and in response to
7
you're eluding to was probably going on for a couple of
7
my Inquiries said some bad things that kind of Incised me
8
weeks.
8
which I responded to.
9
0. 1 am talking about whatever It was that was going
9
Q. I would like to know what the bad things were?
10
on as October 28?
10
A. He said do you know that they are building a
11
A. Chopping tile, taking drywall off. Things like
11
Walmart across the street and — I have to get this in the
12
that might have been going on for maybe a week or so.
12
right order. He said something about the Walmart being
13
Q. When is it that the screen doors were pulled down
13
across the street and the place was going to be overrun with
14
from the property?
14
people — I don't know if he used the word people, unless,
15
A. The whole back wall there, I can't remember
15
you know, he stayed on the ball and protected the homeowners
16
exactly when that happened. I know they were so filthy and
16
of Plaza Au Solei, the name of the development. Then he
17
it was so hot that we might have done that very soon just so
17
made an offhand remark if I don't keep these bearers in line
18
we could roll up the plastic sheets and have a breeze coming
18
they will never get the sticker for their car. Something
19
through.
19
like that.
20
Q. Was all that trash In the great room as well?
20
Q. Okay. Is that all you remember him saying that
21
A. No, we had been making trips so I don't think all
21
day?
22
the trash from the very beginning was there when Officer
22
A. When I responded to him I think he said something
23
Ginsberg came in.
23
else but I can't remember what that was. I Insinuated that
24
Q. Some of it had been taken out by then?
24
he was a racist and a Barney Fife.
25
A. Yeah. I'm sure I had at least thrown It in the
25
Q. So he said If I don't keep these beaners in line
age 26
age 28
1
carts that the city picks up. Small things.
1
then they will never gel the sticker?
2
0. Okay. You're talking about just the stuff you
2
A. Something to that effect.
3
take out to the side of the road?
3
Q. What did you say In response?
4
A. Right. We had like three or four of those. They
4
A. I said I thought that comment was pretty racist
5
would have Insulation In them or debris. Bundles of wires
5
and he was acting like a Barney Fife, a character from an
6
from the attic. Things like that. Plus, there was
6
old TV show.
7
furniture. Just the kind of junk people accumulate. The
7
Q. How did you respond to your statement?
8
house had been rented before us so there was a lot of things
8
A. He hulled up pretty badly. And I am not a really
9
left behind.
9
good judge of people. But his demeanor seemed to be pretty
10
Q. When did you first meet Officer Ginsberg?
10
angry. Then he left. And I think he said something like
11
A. When did I first meet him?
11
they need to get the sticker and stop working. That's It.
12
0. Yeah.
12
Q. Did they go get the sticker?
13
A. September. Mid September of 2011.
13
A. Yeah, they got the sticker. They came back and
14
Q. Tell me about that?
14
continued working. I remember asking — these guys don't
15
A. I had a crew recommend by my landscaper who were
15
have a lot of money. I mean, I was paying them a fair rate.
16
taking out a dead black olive tree. They were about a third
16
If they could have just kept working I think it would be
17
of the way into it. I was there cause I wanted to make sure
17
easier on them monetarily. Either way, they came back and
18
nobody got hurt. Officer Ginsberg arrives on the scene and
18
did the work.
19
1 guess noticed they didn't have an official sticker on
19
Q. What are we talking about for the registration
20
their truck and came up to me and told me that these guys
20
fee?
21
had to stop working and go get a sticker. And the guys were
21
A. Maybe 50 bucks.
22
ready to do that and I asked Officer Ginsberg If it would be
22
Q. Did you offer to pay It for them?
23
okay if they continued working while one of them went to get
23
A. Yeah, It was part of the bill.
24
the sticker. It's the kind of thing, It's a perfunctory
24
Q. That didn't really have any Impact on them. They
25
thing that the town usually says as soon as you walk in.
25
went, took a break, came back and did the job?
O
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
29-32
Page 29
Page 31
1
A. No, I guess I was always just thinking of trying
1
Q. What did Mr. Gundlach tell you?
2
to stand In their shoes. You know, they don't want to do
2
A. He said there's a policeman in your living room.
3
just one job. They want to go to the next job and find some
3
1 said what does he want. He said something like not a
4
money.
4
clue. I said well, ask him to leave, he Is not supposed to
5
Q. Do you remember any other things that he said
5
be there.
6
other than calling them beaners?
6
Q. Did you stay on the phone while he asked him to
7
A. You mean besides ordering them to get the
7
leave?
8
stickers?
8
A. No, I said — I think I actually told him hang up
9
Q. Right.
9
and go tell him to leave.
10
A. That's about all I can recall. That is what stuck
10
Q. Did you learn if he did that?
11
this in my mind.
11
A. He told me later that the whole incident what
12
Q. You were offended by the statement?
12
happened.
13
A. Yes, I was.
13
Q. What did he tell you?
14
Q. Did you go to anyone at the town and Inform them
14
A. He said that officer was on the phone. That he
15
of the statement?
15
was talking to somebody at town hall. He didn't know who
16
A. No, I think I was still Ingo along to get along
16
but it sounded like he was talking to somebody at town hall.
17
mode.
17
1 don't know how he reached that conclusion. And that
18
Q. And you see the chief silting back there. Did you
18
Gundlach said Mr. O'Hare wants you to leave and that the
19
give him a call say one of your guys called the people
19
officer said to him something to the effect no, it is you
20
beaners?
20
guys that have to leave. And with a sweep of his arm
21
A. No, that Is not something I would have done.
21
basically told everybody to get out. Pack their stuff and
22
Q. So you just told the officer he was a Barney Fife
22
go.
23
and went on with your life?
23
Q. To your knowledge they did not actually leave at
24
A. I didn't see — you know, I thought it was an
24
that point; correct?
25
indiscretion but I didn't see it worth trying to get him in
25
A. Well, they started packing their stuff up.
Page 30
Page
1
trouble. That's the only thing that would have resulted.
1
Q. They were still there when you got there?
2
Would come down on him. Maybe he was just having a bad day.
2
A. When I got there which wasn't too much later, a
3
Q. Between September 2011, whatever date that was,
3
few minutes I think, they were in the process of packing up
4
and the October 28, 2011 time when he came to your property
4
and undoing their half done work and putting their tools in
5
did you have —
5
their truck. Then Shelly arrived a few minutes after me
6
THE WITNESS: — my head is splitting. Can we
6
with lunch that she bought for everybody. I told them as
7
stop so I can get some water?
7
long as you stop working let's have lunch and then you guys
8
MR. STEARNS: Absolutely.
8
can gc. We sat there and had lunch.
9
(Bdef recess was taken.)
9
Q. You got there a few minutes after you spoke with
10
BY MR. STEARNS:
10
Mr. Gundlach?
11
Q. The question that I was trying to ask is from the
11
A. Yeah.
12
beaners Incident, the day of that through October 2, 2011
12
Q. And was the officer gone at that time?
13
when Mr. Ginsberg came to your property, did you have any
13
A. Yeah, he wasn't there. And judging by the time
14
over interactions with him at any time?
14
stamp on the first photo that would probably place me there
15
A. No, I didn't see him again.
15
right after that and before the second time stamp.
16
Q. So, October 28, 2011, move back to that date
16
Q. You're saying that because this photo says October
17
again. You have your morning meeting with the workers. You
17
28, 2011 at 11:34?
18
head off to your job; right?
18
A. Right, and the other one says 1:14. So between
19
A. Right.
19
11:34 and 1:141 showed up with Shelly.
20
Q. And then you eventually got a phone call?
20
Q. Do you know what time it was that you showed up?
21
A. On the way back to the job I got the phone call
21
A. It was in that period but I don't know when.
22
from Mr. Gundlach.
22
Actually, given that he look the picture at 11:34 he must
23
Q. You were already on the way back to your house?
23
have had to walk back around to his car. It must have been
24
A. I just remember I was driving. I might have been
24
15 minutes.
25
running an errand on the way back. I was in my car.
25
Q. Where is it you believe this photograph exhibit B
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CHRIS OHARE
June 18, 2015
OHARE vs. TOWN OF GULF STREAM
33-36
age 33
age 35
1
was taken from?
1
his sons.
2
A. Well, there is only one place It could have been
2
Q. So you get home a few minutes after Ginsberg
3
taken from because the angles on the property, I forget what
3
leaves. You sit down, you have lunch with the guys. They
4
they call it in the marines. When you take your vectors and
4
eventually pack up and leave?
5
tum. That would have to be directly west on the property
5
A. They were packed up by then so once we cleared
6
of 2516.
6
away all the food cause I won't have food on a construction
7
Q. 2516 abuts 2520?
7
site because of the rodents. We had enough rodents In that
8
A. Yes.
8
house. Yeah, they all left. Got in their vehicles and
9
Q. Is there a fence between the two properties?
9
left.
10
A. A six foot fence around the properties.
10
Q. Did you leave?
11
Q. Okay. Is there any other property on this, the
11
A. I don't know. I was pretty upset. I don't
12
west side of your 2520?
12
remember what I did that afternoon.
13
A. No, that property line is shared by Just those two
13
Q. Did you call anyone at the town to Inquire about
14
houses.
14
why a police officer had been to your property?
15
Q. Just 2516, 2520?
15
A. You know, I don't think I called the town. 1
16
A. On the west property line. The entire west
16
think a police officer came to the door a few hours later
17
property line of 2520 is shared with 2516 only.
17
and delivered an envelope for Mr. Thrasher. I can't sure
18
0. Is there any type of easement between the two
18
when that was. I know I signed a receipt for it so there is
19
properties?
19
probably one existing somewhere In the public record with
20
A. No.
20
the time on it.
21
Q. utilities easement, anything?
21
0. You're saying that was the same day?
22
A. No, not that I'm aware of.
22
A. Yes, we were visited by the Town of Gulf Stream
23
Q. You believe this photograph was taken over the
23
three times that day.
24
fence from 2516 to see the back of 2520?
24
Q. Okay. So, the first time is Officer Ginsberg,
25
A. Yeah, I can't imagine any other way it was taken.
25
what we learns to be Officer Ginsberg? We learned that was
34
ago 36
1
osed oft?
Q. Is the backyard of 2516 closed
1
Officer Ginsberg?
2
A. The entire area around the side yard and the
2
A. Right. Then later when we were having lunch
3
backyard of 2516 is dosed off and the gates are basically
3
Officer Ginsberg and another gentleman tried to gain entry,
4
flush with the face of the house.
4
knocked on the door and then turned the handles and rattled
5
Q. So you are saying to get Into the back of 2516 he
5
the door. Then went and did the garage door. I was kind of
6
would have to go through a gate?
6
freaked out and I told everybody don't answer the door.
7
A. Another self-closing gate which my landscape
7
Let's finish our lunch and be on your way. And that's It.
8
maintenance man who was standing at the first gate and
8
So we didn't answer the door.
9
talked with Officer Ginsberg was actually at the second gate
9
Q. You heard someone knocking and you Ignored it?
10
when Officer Ginsberg came there and walked past him again
10
A. Heard the pounding, knocking. I didn't Ignore it.
11
through that gate.
11
1 looked out the window.
12
Q. The same person happened to be at both gates?
12
Q. You looked out the window, you see it was an
13
A. Kismet.
13
officer?
14
Q. Who is this guy?
14
A. I seen an officer. 1 thought you know what, I am
15
A. His name is Vincent, a Mexican American who was
15
In my home, I am not answering the door.
16
doing my landscape maintenance.
16
Q. Did you know what officer It was?
17
Q. Is he one of the guys who did not have a
17
A. The same officer that was there before according
18
registration with the town?
18
to Gundlach who was still in the house.
19
A. No, I believe he does. He's been around a long
19
Q. Did Gundlach tell you what officer it was?
20
time.
20
A. He said the same officer. He didn't know his
21
Q. Do you know any more Information other than
21
name.
22
Vincent?
22
Q. So Gundlach looked out the window as well and saw
23
A. Gonzalez Is his last name.
23
him?
24
0. What company does he work for?
24
A. I might have remembered his name from the eariler
25
A. Vincent's Lawn Service. It is his company with
25
tree incident but I don't know if I did or not. I can't
4)
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
37-40
Page 37
Page 39
1
recall now.
1
Q. As of October 2, 2011.
2
Q. They knock on the door, rattle the handle. You
2
A. When I wrote the letter I thought um, guy doing
3
guys ignore them. And they leave?
3
his job. Maybe overzealously. But certainly not very
4
A. Eventually they left. When we left we found that
4
sympathetically. But I thought he was doing his job and 1
5
they had put big stickers on the doors saying stop work.
5
needed to respond.
6
Q. What did you do at that lime?
6
Q. You weren't having any problems with him at that
7
A. I don't recall. I just remember that later on we
7
time?
8
got a delivery from another police officer.
8
A. No, not really.
9
Q. Did you — strike that. Did you tell the workers
9
Q. You say you wrote a letter. Did you hand deliver
10
not to come back tomorrow, let me figure out what's going on
10
It, fax it, what did you do with it?
11
here?
11
A. I think the top of the letter may say via hand
12
A. I think I told them that I am going to have to go
12
delivery. I might have dropped it off Monday morning but
13
straighten this out and I will call you when it is
13
I'm not sure.
14
straightened out, you can come back.
14
Q. Nonetheless, did you go in and try to speak to
15
Q. You said there is a third visit. That Is a
15
someone on Monday morning about the work and how to resolve
16
different officer?
16
it?
17
A. Yeah, this was a different officer I believe who
17
A. I had previously the month before spoken to Ms.
18
was delivering an envelope from Mr. Thrasher.
18
Rita Taylor the town clerk about our plans for the house.
19
Q. Do you know who the officer was?
19
But not — that is not what we were doing then. We are just
20
A. I can't recall that.
20
basically doing Investigation to see how extensive the
21
Q. Okay. And did you have to sign for that document?
21
damage was. We didn't know when we were going to start
22
A. Yeah. I can't recall If It was me or my wife. 1
22
pulling drywall. I'm sorry, I lost my train of thought.
23
know we got a letter that we had to sign for.
23
Q. That's okay. Let's step back. Before beginning
24
Q. What did the letter say?
24
all of this work that you're doing as of October and
25
A. Basically said you're doing work without a permit,
25
September 2011 had you spoken vrith the town about your
Page 38
Page 40
1
you got to get a permit, you got to stop working, don't do
1
Intent to do this work?
2
any more work until you have the permit. To that effect.
2
A. Yeah, I spoke to Rita, Ms. Taylor.
3
Q. This is the same day; right?
3
Q. What conversation did you have with Rita Taylor?
4
A. I think it was the same day, yeah. I think it was
4
A. I might have been inhere getting a sticker for my
5
a Friday as a matter of fact.
5
dash, one of those little things that Identify town
6
Q. What did you do In response to receiving that
6
residents for whatever purpose that serves. I mentioned to
7
letter?
7
her that we just moved from Middle Road to Plaza Au Solei
8
A. I wrote a letter back to Mr. Thrasher.
B
and that we had to do some work. How does it work now
9
Q. You wrote a letter back?
9
because the last time I had done work it was through Palm
10
A. A letter basically said and we can produce it
10
Beach County. Now the City of Delray I heard was in charge.
11
later for you if you like. Said I apologize if 1
11
1 wanted to know where to pick up the permits, what fors
12
misunderstood, I didn't think I needed a permit for taking
12
she had. Things like that. To prepare that for a later
13
the drywall out or the other work. But if you say I do, 1
13
time.
14
guess I do and I'll go get one first thing Monday.
14
Q. What you're saying is that the City of Delray was
15
Q. Why did you write a letter? Why not just pick up
15
now the building official and providing the building
16
the phone and call?
16
services to the town?
17
A. Um, I think it was cause it was the weekend. I am
17
A. As I understand it they are providing review of
18
not sure when I came in — if I didn't sign for it and I did
18
building applications and inspection services.
19
it was after five. Probably assumed that Mr. Thrasher
19
Q. You understood and that is based upon your
20
wouldn't be in town hall over the weekend.
20
background?
21
Q. Did you know Mr. Thrasher at this time?
21
A. Well, my experience, yeah. You can pull a permit.
22
A. I had met him a few times before.
22
Somebody has to come out. In this case it is Delray Beach
23
Q. What was your perception of Mr. Thrasher at this
23
Instead of Palm Beach County.
24
time?
24
Q. What work did you tell Rita you wanted to do?
25
A. At this time?
25
A. I think we were going to change out our air
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4114
1
Page 41
conditioning, get a roof. Retile, new cabinets, doors.
1
Page 43
Incised. You're a father. Your kids mean everything to
2
Things like that.
2
you. You start seeing mold In the house and it is like you
3
Q. Some of those things you certainly agree you knew
3
stop thinking about procedure and start thinking about I got
4
you needed a permit for?
4
to get this out of my house.
5
A. No, I just told her that was the scope of the
5
Q. Permits were second to getting this stuff out of
6
work.
6
here for the family's sake?
7
Q. You knew If you're going to do work on the roof
7
A. When It came to the mold Imagine if It was a
8
you need a permit?
8
federal building or commercial project where they had all
9
A. Certainly knew a roof.
9
sorts of professional remediators whatever they are called.
10
Q. Replace an air conditioner you need a permit?
10
In my case I saw this mold and get rid of it.
11
A. Yeah, mechanical equipment you need a permit.
11
Q. Okay. The stop work orders are posted?
12
Q. Would you agree with me if you're changing
12
A. Yeah.
13
electrical outlets that require removing them, doing
13
Q. And you do go in that next week Monday, Tuesday,
14
electrical work you need a permit for that?
14
something like that?
15
A. No, I talked to the electrical inspector of
15
A. I think it was Monday, yeah.
16
Boynton Beach once and again the Delray inspector. My
16
Q. Who did you meet with?
17
understanding was there are thresholds that trigger a
17
A. I don't know. I know I dropped off the letter I
18
permit. For Instance, replacing a light fixture with
18
think and got the forms. Went down to Delray, got their
19
replacement light fixture you don't need a permit.
19
forms and filled them out. But I can't tell you who I met
20
Replacing a receptacle you dont' need a permit.
20
with or how long it took.
21
Coincidentally, later on I got an e-mail from Mr. Thrasher
21
Q. Did you talk to Bill Thrasher at all?
22
saying that it was his understanding that you didn't need a
22
A. I don't know if I did or not.
23
permit to add anything on to existing circuit which I don't
23
Q. You were able to get the permits pretty quickly?
24
think that is true. But we were not going there anyway. We
24
A. Yeah, cause it was a pretty simple permit. 1
25
were just replacing some little plug-in receptacles that
25
remember the clerk in Delray saying why are you getting a
age 42
44
1
were covered In paint.
1
permit for this. I said well, covering all my bases. Iage
2
Q. As of October 28, 2011 had you started any of the
2
want to make sure I'm following the rules.
3
work that you do believe required a permit?
3
Q. The work resumed within a day or two?
4
A. At the time, no. Now I think and I am not sure
4
A. After I got the permit people came back and we
5
about it, I think you need a permit to take out drywall.
5
started to do the work, yeah.
6
But my dilemma was I didn't know how much drywall I was
6
Q. Are you claiming that Mr. Ginsberg acted somewhat
7
taking out. To pull a permit you're filling out a legal
7
retaliatory for calling him a racist?
8
document which you attest to the value of construction.
8
A. I wondered about that. At the time I don't know
9
That Is based, your permit fee is based on the value of the
9
if I suspected that or not. I don't think I did. I don't
10
construction and that is sent to the property, Palm Beach
10
usually assign even with tensions to people, I think they
11
County Property Appraiser and the permit amount affects the
11
are going to do the right thing.
12
value of the house for tax purposes. So it has got legal
12
Q. Are you claiming that now? Do you believe that is
13
consequences. So we were doing exploratory work at the time
13
why he accessed your property that day?
14
seeing how extensive the mold was. I wasn't really prepared
14
A. It is hard forme not to come to that conclusion
15
to fill out a form yet.
15
based on everything that followed.
16
Q. When you fill out the form you're giving your best
16
Q. So that Is your opinion?
17
estimate as to the reasonable value of that construction is;
17
A. Today I think so, yeah.
18
right?
18
Q. That is what your complaint says?
19
A. That's a good argument. There are some building
19
A. Well, that Is how I feel today considering all the
20
officials that might disagree with that.
20
other actions that happened.
21
Q. When you're done with it there's a process by
21
Q. How else do you believe you were retaliated
22
which you can come in and do a reconciliation saying you
22
against for calling him a racist and a Barney Fife that you
23
know what, I thought it was this, it ended up costing me?
23
said?
24
A. Yeah, that's true. Normally we would have
24
A. Well, Officer Ginsberg had returned a few times as
25
followed that procedure. I would have. But I was so
25
well. I had prior to October 28 pulled a permit for the
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1
roof with the Intention of going from the barrel file which
1
without complaint. I was more socially conscious back then.
2
had been on it for so long to a fiat white tile like we had
2
Maybe I just wanted to make things, you know, give in a
3
on Middle Road. When we started looking more closely at the
3
little bit, let things follow their course and join the
4
roof after it was off I think this guy Sam Hams who was
4
crowd.
5
the foreman for Roof Tech pointed out to me that the roof
5
Q. When did that happen?
6
seemed to have a bit of a sag in it. So I had thought maybe
6
A. That was around 2006. 1 think I met Mr. Thrasher
7
the heavy concrete file wasn't the best way to go. When we
7
when I first moved in around 2004 maybe.
8
approached the town saying we wanted to change it we pretty
8
Q. What other trees did you see?
9
much told no metal roofs, period. And that raised my
9
A. What other trees did I see?
10
suspicions because I had seen other metal roofs in town. 1
10
Q. You said you stepped back.
11
mean, sitting right here we can see metal roofs next door
11
A. Sorry?
12
here. I pursued the Issue with Mr. Thrasher asking for an
12
Q. What other conduct do you believe you engaged in
13
explanation, etc. Eventually got an engineer to look at it.
13
that caused them to retaliate against you by denying your
14
The engineers conclusion was that I did need to not put
14
permit.
15
that heavy weight on there. But Mr. Thrasher Insisted 1
15
A. That was It basically. I never really came to any
16
did. And I found a section in the code that said there was
16
commission meetings. I don't know what was going on in
17
an exemption if I mel certain criteria. So I asked the
17
their heads. But looking at it it looks like I might have
18
engineer to read that and give me whatever I needed to make
18
been a little bit too outspoken.
19
his point. But the town, Mr. Thrasher still said no which
19
Q. But the denial of the permit was approximately
20
seemed kind of strange cause the code seems so clear. We
20
March 2012; right?
21
appealed that decision.
21
A. No, we had that roof discussion in December.
22
Basically Mr. Thrasher is saying you got to let us
22
November or December of 2011. And then by the spring of
23
verify — let me back up. I'm getting too far ahead of
23
2012 we were appealing to the commission.
24
myself. We supplied the certified letter from the engineer.
24
Q. The commission's decision —
25
Mr. Thrasher said no, you're either going to have to let us
25
A. —sitting as the board of adjustment.
Page 46
PageW
I
Inspect it or gel a variance. So we appealed to the
1
Q. Sitting at the board of adjustment actually, It
2
commission which is what the code allows for. As a matter
2
was May 2012 looks like?
3
of fact, if I can make a point, my very first public record
3
A. That could be, yeah. Could be.
4
was when I bought this house I asked for a code book. I was
4
Q. And are you claiming that the commission's
5
using that to base all my decisions on when I asked Mr.
5
decislon to deny your appeal as sitting at the board of
6
Thrasher about the certified letters, etc. So when we
6
adjustment was related to any First Amendment speech that
7
appealed to the commission and had a hearing we paid for, it
7
you engaged in?
8
was $400, they basically after two hearings sided with Mr.
8
A. Yeah, I was just shocked at the decision.
9
Thrasher that yes, indeed we need a variance to get that
9
Q. That is a yes or no question?
10
metal roof unless I was going to let the town's engineer
10
A. Okay. I think it was in retaliation to a speech.
11
come in to inspect to see if my engineer was accurate or
11
1 think, you know, there Is an old saying In Japan with
12
verify my engineers work. It all seemed very fishy.
12
Samurai the head that sticks up above the crowd is the one
13
Q. Are you saying that the denial of your permit was
13
that meets the sword. And I think my head was sticking up a
14
In retaliation for you wiling Mr. Ginsberg a racist and a
14
little bit too high.
15
Barney Fife?
15
Q. What speech is it that you believe you engaged in
16
A. Well, It's more than that. Cause looking back
16
that caused them to retaliate against you?
17
now, you know, when you step out of the forest you can
17
A. By that time I had been In discussions with the
18
basically see all the trees. Looking back now I see maybe
18
chief, the town manager, the town attorney objected to the
19
there was more than that going on as well. Cause I had met
19
October 28 trespass and asking what they are going to do
20
Mr. Thrasher when I first moved to town after being a
20
about it. I felt I was getting lip service. But I think 1
21
commissioner in Ocean Ridge. We had a long discussion in
21
was making people uncomfortable.
22
his office then. I had a bit a problem with Mr. Thrasher on
22
Q. See that's what I need. I need to know what those
23
my house in Middle Road when he gave me a permit to do some
23
specifics are?
24
work for. Then came out and said no, can't do this, take it
24
A. The words or sentiments?
25
out. Again, to go along In order to get along I took it out
25
Q. Who exactly you talked to and what you said.
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OHARE vs. TOWN OF GULF STREAM 49-52
1
A. Talking to Mr. Thrasher, Chief Ward, Mr. Randolph.
1
Q. Yeah. r aye J
2
And I can't tell you the exact thing. You know, we do have
2
A. No, no. But if I can finish? I didn't Invent the
3
an attorney who was there as well. Maybe his memory is
3
Barney Fife thing. I had heard that from Sam Harris who was
4
better as to exactly what was said but the gist of it was --
4
the guy on the roof of my neighbor Peter Bennett's house who
5
1 do remember one thing. I came Into that meeting at this
5
witnessed Officer Ginsberg banging like a maniac on the
6
very table and sitting there I said something to the effect
6
garage door. Also had his own Interactions with Officer
7
that I was so mad I could flip this table. Which Mr.
7
Ginsberg. He's the one who said yeah, we call him Barney
8
Thrasher later testified he thought I was threatening his
8
Fife. Iljust came out.
9
life but I wasn't. I was just mad I could flip this table.
9
Q. Okay. So you mentioned that you believe you were
10
Or I could bang my fist on this table. You know, trying to
10
retaliated against by Ginsberg coming to the back of your
11
contain myself and be reasonable I didn't do that. I just
11
property and by the denial of your permits.
12
verbalized It.
12
Any other way?
13
Q. You're a big strong guy. You could have flipped
13
A. Yeah, It goes on for three years. You want it In
14
this table if you wanted lo?
14
chronological order?
15
A. Yeah. I mean, the hulk could come out but let's
15
Q. Sure.
16
hope that never happens. It hasn't happened yet. So I had
16
A. Okay. I'm sorry, my memory is not as good as it
17
said things to them that I was concerned for my family. It
17
was three years ago. I get confused now. Let's see. After
18
wasn't right, shouldn't have done that, what are you going
18
they denied me the permit I filed a writ of certiorari which
19
to do about It. He Is still working here, recommend
19
1 found out is the way you're supposed to that. I did a lot
20
anything in his file.
20
of research, found out the code doesn't allow for variances
21
Q. Your complaint says —
21
like they ordered me to get. Which I thought was really
22
A. —the complaint?
22
peculiar since who should know their code better than them.
23
Q. The complaint I'm saying here says that your First
23
But I applied for a garage door. I wanted a smooth garage
24 Amendment speech was your statement to Officer Ginsberg? 24 door like we had gotten a permit for on Middle Road, Which
25 A. Well, it is one giant ball of wax. If you want me 25 happened to be considered by the town a Bermuda style house
1 to dissect it and say yes, that was part of my speech, that
2 1 don't think the town represented by Gulf Stream and later
3 anybody he might have told which I don't have first-hand
4 knowledge of. Yeah, I would think they were retaliating
5 against that
6 Q. Did you tell any of the commissioners what you had
7 said about Officer Ginsberg?
8 A. I don't think I spoke to any commissioners. Not
9 until the roof hearing.
10 Q. Did you tell Mr. Thrasher what you had called Mr.
11 Ginsberg?
12 A. No. Again, I thought Mr. Ginsberg at the time
13 might have been a minor, an indiscretion, something maybe
14 out of character. I didn't see any reason to ruin the guy's
15 reputation by talking about that.
16 Q. You weren't running around telling people that you
17 thought he was a racist?
18 A. I don't do that.
19 Q. And you didn't tell anybody —
20 A. — I must confess.
21 Q. Now you're talking over me.
22 A. I'm sorry.
23 Q. That's all right. You didn't tell anybody you
24 thought he was a Barney Fife?
25 A. Yes. Tell the town?
1 1 wanted a smooth garage door this time. Made a permit. 1
2 think I got a message back through Gail, one of the people
3 in the staff or through Mr. Thrasher that I couldn't have
4 the smooth garage door because he had determined with Marty
5 Minor, a consultant to the town, that my house, even though
6 the code was the other style, was now actually a Bermuda,
7 Gulf Stream Bermuda style. The style dictates much more
8 extensive regulations in the zoning code. So I pointed out
9 to them there were other permits for smooth doors on Bermuda
10 style. By the way, my house is not Bermuda style. The code
11 doesn't even say Is Bermuda. Bermuda style is just
12 ambiguous language that says It has to comply with the style
13 by Mr. Thrasher's determination. So I thought him deciding
14 that 1 couldn't have a smooth door was just a way for him to
15 dig at me, to retaliate because maybe I was making his life
16 a little bit hard on him.
17 I'm sorry If I am bodng you.
18 Q. No.
19 A. Yeah, they told me not only couldn't I have a
20 smooth garage door even though my neighbors could but that
21 my house was now changed In the code book. No hearing. No
22 asking me my opinion. And since I found out they have never
23 done that to anybody else but my house was now going to be
24 Bermuda style and because of that all these other
25 regulations are now In effect and you couldn't have your
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OHARE vs. TOWN OF GULF STREAM 53-56
1
door. So I objected to that. Then the next Instance 1
1
Q. Okay. But I am asking you what speech it Is?
2
believe —
2
A. Same speech as before. And the fact that we had
3
Q. — wait, before we go to the next one. Did you
3
discussions ongoing where I started asking for public
4
appeal the denial of that application for a smooth garage
4
records and asking for Officer Ginsberg's police file to see
5
door?
5
if he had ever been reprimanded or if he even still worked
6
A. No.
6
there. I think I was being a pain in their side.
7
Q. What speech exactly is it that you believe led Mr.
7
Q. The six foot fence that your neighbor had, was It
8
Thrasher to deny the permit at his level?
B
a new fence or was it existing?
9
A. Lim, you want to know what words I said that caused
9
A. Brand new. The rationale, even though it was
10
him to do what he did?
10
being constructed, the permit had been granted prior to the
11
Q. Correct.
11
code being written and therefore, the plan was grandfathered
12
A. Let's see. I guess my answer would be the speech
12
in, if not the actual fence. Something to that effect.
13
1 already told you about.
13
Q. Okay. The neighbor, what's the name?
14
Q. Okay. Now we can go on to the next thing?
14
A. That was a spec house. I have to tell you I don't
15
A. Okay. There's a regulation exclusive to Plaza Au
15
know the name of the people who moved in.
16
Solei and another place that you can't have fences over six
16
Q. How about the address?
17
foot. I noticed the house under construction across the
17
A. Maybe 25 — 2535. Something like that. In that
18
street where I had seen Officer Ginsberg before had a fence
18
range.
19
over six feet and a gate. So I said I would like to have
19
Q. Around this timeframe the code did change for what
20
the very same on my house. I made an application for, 1
20
was permitted in that area?
21
think it was 60 inch or 52 Inch fence and gate on the side
21
A. I don't know exactly when the code was changed and
22
of my house.
22
what the prior code was. But I think that actual code was
23
Q. Four feet four inches?
23
written back in'97.
24
A. Yes. The code says you can't over be four feet
24
Q. You were told — strike this. The code was
25 but I asked for 52 inch. Basically the gate had two columns 125 written in'97. You said their permit application was
1 on the side and It went up slightly larger than 52 Inches.
2 Q. You're saying 52 inches is four feet four inches?
3 A. Right. So it's four inches over the regulated
4 height.
5 Q. You asked for that?
6 A. Right, I asked for that. Considering my neighbor
7 had it since everybody is treated equal maybe they were not
8 enforcing that regulation. That was the sketch I made.
9 Q. When did this occur?
10 A. Sometime I think in 2012 or 2013.
11 0. And you submitted an application for this four
12 feel four inch fence?
13 A. Yes.
14 Q. What was the result?
15 A. Turned down.
16 Q. By whom?
17 A. Well, I guess Mr. Thrasher. He is the building
18 official.
19 Q. Okay. Did you appeal his determination to the
20 commission?
21 A. No, I was of the mind at the time that appeals
22 were kind of a waste of time.
23 Q. And the same speech that you engaged in?
24 A. I think he was selecting me out for special
25 consideration, yeah.
1 permitted before the code change?
2 A. Well, the discrepancy is it's based on what
3 reality is versus what I am told by the town. I know the
4 town had a major code creation of the design manual in the
5 late'90s after an architectural style review determined my
6 house was other style. It wasn't any particular style. And
7 that Is when the design manual was written. I believe it
8 was established that Plaza Au Solei should be open even
9 though a third of the houses weren't open, whatever that
10 means, and that Included having low fences.
11 Q. Okay.
12 A. Again, you're exposing the dilemma and frustration
13 1 face when I see the reality of enforcement versus the
14 actuality of the zoning code.
15 Q. How do you believe that Mr. Thrasher had the
16 opportunity to retaliate against you?
17 A. This might not be in chronological order but Mr.
18 Thrasher e-mailed and I found this out through public
19 records request. He e-mailed my neighbors around me and 1
20 guess he had the e-mail addresses through the homeowners
21 association and asked them if they had any issues with my
22 landscaping. Being a landscape architect I take pride in
23 the landscape of my home and we had done work periodically
24 over the course of the year putting in trees and bushes and
25 taking things out. So he solicited the opinion of my
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1
neighbors and asked if they are happy with it, he would do
1
Coe vary well. I commented on this big stand of Rhapis
2
nothing. If they didn't like it, he was basically going to
2
palm. He said on, yeah, help yourself, have some. So we
3
come down on me.
3
planted them on Middle Road and when I moved I took some of
4
Q. Was your landscaping in violation of certain
4
them with me and planted them at my house at 2520. So now 1
5
aspects of the code?
5
was being cited in violation for having lady palms in my
6
A. Absolutely not.
6
yard because they were not on the list of plants found in
7
Q. What did your neighbors say?
7
the town. It wasn't a prohibition list. Just a guideline.
8
A. Well, Mr. Randolph quoted what they said in my
8
But the zoning code, that portion of the zoning code for the
9
code enforcement hearing on the very matter. Basically this
9
design manual is both standards of design as well as
10
fellow said I was flipping the bird to the town. Which
10
guidelines. And this particular guideline said here's some
11
completely shocked. it seems so out decor of the whole
11
plants found in town. And here's some plants that are
12
procedure. One neighbor said I was flipping the bird to the
12
native plants. They are also found in town. So my lady
13
town. Another neighbor said it looked better than it was
13
palms and a few other things were not on the list. And
14
before but still could be improved. And another e-mail said
14
therefore, I had to defend myself before the special
15
something like go get them, to that effect.
15
magistrate and Mr. Randolph asking me if I was flipping the
16
Q. So your neighbors weren't happy with you trying to
16
bird to the town.
17
make yourself different than the community aesthetic?
17
Q. Were there any other code prohibitions you were
18
MR. HANNA: Object to fort.
18
alleged to have violated at that time?
19
THE WITNESS: Well, in actuality and having
19
A. Yeah, it was — we had broken parts in our
20
worked on so many projects I could tell you that it is
20
concrete driveway from moving vans. I don't know what. But
21
like making sausage. It's not pretty. Or making laws.
21
there was some broken create on the driveway we had removed.
22
But the final result Is attractive. And if you go by
22
And a section of the driveway, rause it was all, It had
23
my house I think you would agree It's very attractive.
23
control joints which in concrete work is where you make a
24
Probably one of the most attractive but at the time it
24
line in the concrete where it will hopefully crack later.
25
was under construction so it is not attractive. That
25
They have a wide crack going through the field of concrete.
age
Page 60
1
is what people are reacting. It seemed in my design
1
And these control joints, basically zones between control
2
experience that many people don't visualize the final
2
joints had a bunch of broken concrete which we look out. So
3
result. There is no reason why they should visualize
3
1 was found in violation of removing fill from my property.
4
it cause they never really came to me and said what are
4
However, the code specifically says a special magistrate
5
you doing, what's your plans.
5
shall not have jurisdiction over that. So that was
6
But out of the blue Mr. Thrasher solicited their
6
Immediately dismissed. Then there was the violation that 1
7
advice or direction and he acted on it. I found myself
7
did not have an open front lawn. Who knows what that means.
8
noticed of a code enforcement violation and
8
That is one of my gripes. In studying the town my
9
subsequently had a hearing right here in this mom.
9
Investigation was the code Is very vague and very ambiguous.
10
BY MR. STEARNS:
10
So we finally asked Mr. Thrasher at the code hearing does it
11
Q. The code enforcement violation was for violating
11
mean to have an open front lawn so we'll know to be in
12
which provision of the code?
12
compliance. So he says I need to see the front door from
13
A. Well, I asked and asked and asked. And finally
13
the street. So the next time we had the hearing cause there
14
they cited certain sections of the code. And I asked how 1
14
was a second follow-up we showed him photos.
15
was In violation of that and I never did get an answer until
15
Oh, I'm sorry, we asked the special magistrate
16
we actually showed up to the hearing.
16
after she ruled, you know, we have pictures of the house
17
Q. What were you told then?
17
that show the front door but she wouldn't. We asked her —
18
A. It was 70-150 1 believe which has a list of plants
18
we did a motion to reconsider and she wouldn't have anything
19
found In town. And my code violation was for using these
19
of it so that stood. We were required to remove any plants
20
plants that weren't on the list. Now, the reason I laugh is
20
that we weren't there originally when we started
21
because some of the plants were lady palms. Rhapls Excelsa,
21
landscaping, return it to some condition in the past. But
22
R -H -A -P -1-S, E -X -C -E -L -S-A. Lady palm. I gat the lady
22
the condition wasn't really spelled out so it's kind of a
23
palms from Mayor BIII Coe (phonetic) because my house on
23
guessing game so we took out half the material. All the
24
Middle Road was across the canal from his house. We
24
lady palms worth maybe $3,000 gone. Nobody wants your old
25
developed somewhat of a relationship. I knew his son BIII
25
stuff. So then Mr. Thrasher as his role came to the house
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61-64
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1
to decide if we were in compliance and he did tell the
1
to confine whether or not your roof needed a metal roof?
2
special magistrate not to start dally fines. And he came
2
A. Right.
3
with a photograph, I guess taken from Google Earth street
3
Q. Right?
4
view that showed the house from about two years prior and
4
A. Yes.
5
said I can't approve this cause it doesn't look like this
5
Q. And you said no?
6
picture. The picture was introduced into evidence. Which
6
A. Yes.
7
is something he showed us for the first time. Said its got
7
Q. Why?
8
to look like this. I don't remember what I said. But 1
8
A. I was taken aback by that. I mean, I supplied
9
think we took out more material and then finally he
9
lots of engineering documents, surveys that are done by my
10
acquiesced. That whole thing was dismissed.
10
engineers. Calculations, drawings. All sorts of things.
11
But it was just a complete fabrication of a code
11
The whole air conditioning is up. Roofers have engineers
12
that didn't exist and misappropriation — misapplication of
12
sometimes do inspections and their inspections say a roof
13
the code. It was so stressful. You are here. You know the
13
tag inspection would be supplied to a town in place of the
14
ramifications. I am paying experts, I'm paying attorneys.
14
actual inspector coming out. I never had anybody in
15
I actually got the landscape architect who wrote the book
15
authority question an engineer's report or certified letter.
16
that's referenced in the landscape portion of the code. 1
16
1 mean, the engineer is bound by the Department of
17
said here's the expert, he'll tell you I have an open front
17
Professional Regulations and who knows what other
18
lawn.
18
regulations to tell the truth and be accurate. No engineer
19
Q. Who was the hearing officer?
19
in their right mind is going to fabricate something and put
20
A. You know, it's so expensive. I'm sorry. A woman
20
their license at risk. The fellow that I have been using,
21
named Donna Nolan. Donlon, D -O -N -L -O -N.
21
he's a pillar of the engineering community. The fellow has
22
Q. Laura Donlon?
22
got a heck of a resume working for the building officials in
23
A. Laura Donlon, that's right. Who I subsequently
23
Dade County. He's just been around. Very smart,
24
found out didn't have authority to be the special magistrate
24
knowledgeable guy. I took it as an affront that they would
25
cause the town's code requires that the special magistrate
25
somehow reject his letter but never have rejected anyone
Page 62
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1
be approved by the commission. She never was.
1
else's.
2
Q. Did you appeal that in the Circuli Court?
2
Q. Who else has submitted a letter that wasn't
3
A. I made the mistake of making a writ of — wait a
3
rejected?
4
minute. I can't remember if I made a write of certiorari on
4
A. When I say letter 1 mean an engineer's work. Work
5
that or not. I don't know if I did. So much litigation 1
5
product.
6
can't remember it all.
6
Q. It is essentially a one page certification
7
Q. Okay. You said you Incurred expenses for experts
7
basically saying my opinion it can't support a tile roof?
8
and attorneys?
8
A. Yeah. Seems pretty flimsy to some people.
9
A. Yeah, plus the cost of doing those changes to my
9
Q. Yeah. Seems pretty flimsy to me.
10
house which I really shouldn't have had to do.
10
A. It is exactly what the code requires. And to do
11
Q. What attorneys were you paying at that time?
11
more than what the code requires seems to me — let's not
12
A. It was Mr. Louis Roeder, R -O -E -D -E -R.
12
even go there.
13
Q. How much did you pay Mr. Roeder?
13
Q. Doesn't it seem like you're kind of cutting off
14
A. I couldn't tell you now. I don't think I ever
14
your nose to spite your face? You want a new roof; right?
15
delineated that portion of his bills for just that effort.
15
A. You know, at this point I drew lines in the sand.
16
Q. Mr. Roeder on retainer for you?
16
And I did not want to do anything more than I was obligated
17
A. Yeah, he does a lot of work forme.
17
to do.
18
Q. What type of work does he do?
18
Q. So you're sitting here three years later without a
19
A. He reviews real estate contracts and advises me on
19
new roof?
20
business decisions.
20
A. You have to understand my dilemma at the time.
21
Q. Is he your attorney In this litigation?
21
And the three year period, one thing follows another thing.
22
A. I believe he has made a notice of appearance now.
22
You can go on to that later. The point I want to make about
23
1 think he has.
23
my dilemma is I have an engineer who looks at my roof and
24
Q. I want to step back to the roof issue. Okay. The
24
says lightweight roof, shingles, shakes, metal roof. I
25
town asked for an opportunity to get their engineer in there
25
would have gone for any of those. The only one that was
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allowed by the code is the metal roof. The town, on the
1
A. The Interpretation?
2
other hand, is saying heavy concrete roof. Now, a metal
2
Q. Yeah, you're saying that this letter is
3
roof weighs about, I don't want to talk In squares. Just
3
sufficient. The town Is says it is not?
4
figure about a pound per square foot In an area about like
4
A. No, it wasn't up to me. That's why I sued. It is
5
this. Concrete the roof Is 14 pounds. Tremendous. You
5
up to the judge. Let the judge decide the interpretation of
6
add that all up over the course of the roof It's a
6
the code.
7
tremendous load. My engineer says don't put your family out
7
Q. Didn't you actually already take this to a Florida
8
there with that load and the town says you don't have any
8
court and lose?
9
choice. Who am I going to listen to? So we asked the town
9
A. We made a writ of certiorari and I believe what's
10
in the hearing if we use your engineer and he says, because
10
called a PCA.
11
you know, engineers want to cover their buffs. Excuse me,
11
Q. Which means you lost?
12
they want to protect themselves. They always estimate on
12
A. Which means denied without opinion.
13
the careful side of the equation.
13
Q. Yes.
14
So if the town engineer says I need the concrete
14
A. I don't know if It was denied on a technicality
15
tile roof regardless of whether i need it or not he just
15
basis. I don't know If It was denied because we forgot to
16
wants to please his employer. And he wants to protect
16
cross a T and dot an 1. 1 don't know. I am not familiar
17
himself from liability. And I put it on and we asked the
17
with it and I didn't get any direction of the court. 1
18
town will you be liable for that? If It falls or I don't
18
didn't even know anyone what to appeal. You can't appeal a
19
want to say this Is worse case scenario but another scenario
19
PCA. You're stuck with it.
20
Is if I sell the house and it fails on them, now there's a
20
Q. The simple fact is you challenged the decision?
21
whole chain of liability. It's just, I didn't know what to
21
A. Yes.
22
do. I can't put the heavy tile on there if the engineer
22
Q. Of the town in Florida courts and your petition
23
says no. I have no choice but to try to right It against
23
was denied; right?
24
the town.
24
A. I want to make sure I am speaking accurately cause
25
Q. Why not submit an application with a true report
25
1 don't really recall. I believe we did challenge It. I
Page 66
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1
and calculations?
1
believe the write of certiorari was denied. And I believe
2
A. Code did not require that.
2
we appealed the writ and that PCA.
3
Q. Don't you think slitting here three years later
3
Q. In fact —
4
when you could arguably submit such a document and have a
4
A. — as a matter of fact, I'm sorry to interrupt
5
different result It's a little crazy to not actually comply
5
you.
6
with that request?
6
Q. I'm sorry, you also sought a writ of mandamus?
7
MR. HANNA: Object to the forth.
7
A. Yeah, and the town said in defense of that that
8
THE WITNESS: If you go to court and the judge
8
the code read we may. If you do this — I'm sorry. You may
9
says I want you to wear a beanie with a spinning wheel
9
get a metal roof if you give us a certified letter. May.
10
on that would you do it?
10
And the town's defense was when we use the word may in the
11
BY MR. STEARNS:
11
code we actually could mean may not. It Is up to us to
12
Q. That's what you equate this with, a request for
12
decide. So I went through the code and I looked for all
13
mathematical calculations showing the reason and necessity
13
places where may. Cause may is really like if you do this,
14
for a metal roof versus some judge telling me to go to court
14
we will do this. Quid pro quo. So if you do this, you may
15
and wear a beanie with a spinning thing on top?
15
get this if you do that. Now the town is saying you may or
16
MR. HANNA: Object to form. Mischarecterizes —
16
may not get it if you do that. That's like the teacher
17
THE WITNESS: —1f the IRS tells me, you know,
17
saying to you if you finish your homework you may go out and
18
you paid your taxes but we want you to pay more taxes
18
play. Or you may not go out and play. It is like being in
19
cause It's the right thing to do should I pay more?
19
Alice in Wonderland.
20
Should I comply with rules that do not exist? Should
20
Q. You're a smart guy. You read the code —
21
1?
21
A. —thanks.
22
BY MR. STEARNS:
22
Q. You have been a Town of Gulf Stream resident for a
23
Q. It is your Interpretation of the code verus the
23
number of years; right?
24
town's Interpretation of Its own code. Do you agree with
24
A. Yeah.
25
that?
25
Q. So you knew this provision existed when you bought
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2520?
1
A. — pretty important point.
2
A. No, I didn't know about that. I didn't read every
2
Q. No, the point is they told you what they want
3
word of the code.
3
which is actual calculations. Because the fact of the
4
Q. You had been a town resident before purchasing
4
matter is —
5
2520?
5
A. —yes, and I remember if I can quote Commissioner
6
A. Yeah, but a visitor of the town for 30 years.
6
Orthwein who was Mayor Orthwein at the time. She said it
7
Town residents since 2003 maybe.
7
doesn't matter what the code says that's what we want.
8
Q. What is the current status of your roof?
8
Q. The town is the one that interprets its own code?
9
A. We are living under a paper roof.
9
A. No, the code was written by previous commission.
10
0. Why do that?
10
And the town is obligated to enforce this code.
11
A. Man, my wife asks me that every damn day. Excuse
11
Q. Yes, absolutely.
12
me. My wife is very upset about that, especially during
12
A. You can't change the code on a whim.
13
Hurricane Sandy, Hurricane Irene. Any storm where the rein
13
Q. How about this. Wouldn't you agree with me that
14
is coming down and I am going around with a bucket to catch
14
you requested a metal roof before any analysis was done of
15
drips. She asks me why are we doing this.
15
the viability and the need for a metal roof?
16
Q. I am asking you as well?
16
A. Yes, that was my gut reaction.
17
A. If I knew then what I know now would I have made
17
Q. You wanted it?
18
the same decision? I don't know. What I know that I am
18
A. When I found out that the roof was in not strong
19
invested. I have gotten this far. And there is things at
19
enough for concrete tile.
20
play here that go to my very soul and I cannot back down
20
Q. That was your decision. You were the —
21
from what I am doing now. I need to get this resolved
21
A. — no, I had been talking to the engineer. We
22
through a court. I have to have a judge Intercede and make
22
didn't have out a letter yet.
23
a decision.
23
Q. Well, your complaint doesn't say that. I will
24
Q. You understand that the court isn't addressing the
24
read to you.
25
viability and whether or not your denial of your permit was
25
A. Well, read it to me and I will tell you if I agree
Page 70
Page 72
1
appropriate, don't you?
1
with it.
2
A. I'm sorry?
2
0. Okay. Complaint says in paragraph 51. On or
3
Q. The federal judge isn't going to say give you a
3
October 26, 2011 Mr. O'Hare contacted his mofer to let him
4
permit for a metal roof.
4
know he was concerned that his roof would not support much
5
MR. HANNA: Object to forth.
5
heavier concrete flat metal roof and wanted to change the
6
THE WITNESS: I am hoping that the federal judge
6
requested roof covering materials on his residence from
7
will look at this entire situation and give me some
7
concrete Bat tile to a substantially layered metal roof.
8
kind of remedy. Whatever that might be. It's up to
8
It was you in your complaint who first determined
9
him to decide.
9
that it wasn't going to work and you wanted a metal roof?
10
BY MR. STEARNS:
10
A. Well, I did —
11
Q. What remedy is it that you want?
11
MR. HANNA: — object to form.
12
A. I have already been told that I could have the
12
THE WITNESS: I did but I didn't make a decision
13
metal roof if I just play along. And I think eventually
13
In a vacuum.
14
when we settle this that I will be allowed to follow my
14
BY MR. STEARNS:
15
engineer's recommendations to put on a metal roof. If not a
15
Q. But the complaint doesn't mention what other parts
16
metal roof, a shingle roof. Something that is not going to
16
—
17
kill my family.
17
A. — It doesn't exclude anyone either.
18
Q. You sat through depositions of Joan Orthwein,
18
Q. Okay. Well, what else existed In that non -vacuum?
19
Mayor Scott Morgan, Fritz Debit (phonetic) and they say we
19
A. I'm sorry what else existed?
20
want to see calculations, confirm that it's actually
20
Q. What else existed in that non -vacuum. What
21
necessary and you get it?
21
knowledge did you have that led you to wanting —
22
A. Well, actually that's not what I remember Mr.
22
A. — well, my personal experience remodeling houses
23
Debit saying. Mr. Debit said he never saw a certificate
23
In the past. The roof just, after we had looked at it,
24
from the engineer.
24
after the roofer pulled off the tile and we could actually
25
Q. That is not my point —
25
see the slope of the ridge I had my own personal doubts.
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Ramon, In his broken English, looked at it and goes oh. 1
1
what the sign actually said. But yeah, gave them a
2
had my suspicions. They were based on my experience and my
2
heads-up.
3
personal observations.
3
Q. Here's my artwork, come purchase it? Come by, see
4
Q. Wouldn't you agree with me that the fad that you
4
It and buy it; right?
5
submitted an application for a metal roof without any of the
5
A. No, it wasn't for sale. Just my political speech.
6
required calculations first kind of weighed against the
6
Q. You just wanted to show it off?
7
validity of the argument that It was done because it needed
7
A. Yeah. I wanted to get my message out there.
8
it?
8
Q. Your website refers to it as artwork; right?
9
A. I'm not following you. I submitted that because
9
A. I think It Is artwork.
10
at the time It seemed to me reasonable to ask for a metal
10
Q. Okay.
11
roof. I didn't realize there was a prohibition against
11
A. Among other things.
12
metal roofs having seen metal roofs in town. I mean, Harry
12
Q. Among other things?
13
Sargent has a metal roof. There is a metal roof right
13
A. Yeah, It's artwork, political speech,
14
there. There's metal roofs across the street. I can see it
14
Illustration, graphic signs. Whatever you want to call It.
15
from here. There's a metal roof. I didn't think there was
15
It is what It Is.
16
a prohibition against metal roofs. So it seemed reasonable
16
Q. But you don't dispute the fact that it is artwork?
17
to me. I talked to my wife from a design standpoint and we
17
A. Yeah, I think It Is art.
18
decided, you know what, maybe this is not the way to go,
18
Q. All right. And If you're going to consider It
19
let's err on the side of caution and ask for a metal roof.
19
public speech you were aware that the town had an ordinance
20
Q. What's the next thing that you believe Mr.
20
which limited such signs to two on your property?
21
Thrasher or anyone at the town did to retaliate against you?
21
A. At that time I am not sure what the sign ordinance
22
A. Gash, where are we?
22
read at the time. I know there's a new one. I'm not sure
23
Q. We were up at the garage door.
23
at the time It was two signs.
24
A. I might be overlooking things. My head is still
24
Q. You displayed more than two signs?
25
pounding. But I believe Mr. Thrasher cited me or threatened
25
A. I think there might have been seven or eight.
age 74
age 76
1
to cite me for objects des art In my house.
1
Q. And what happened?
2
Q. Okay.
2
A. Well, I wasn't cited for anything to do with signs
3
A. You know what that Is? I'm sorry, you're not
3
but rather Mr. Thrasher dug up this obscure little thing in
4
answering questions.
4
the design manual that says you can't have objects des art
5
C. I will answer it. Objects des art?
5
visible from the street.
6
A. Mayor Morgan couldn't tell us. Neither could
6
Q. You were given what? A letter saying take down
7
Commissioner Orthweln. Mr. Thrasher couldn't tell us.
7
your objects des art?
8
Q. Artwork. We all know what we are talking about
8
A. I think like two days. Take them down in two days
9
here; right? It's your signs?
9
or else.
10
A. Yeah, political signs. Two dimensional graphic
10
Q. What did you do?
11
illustrations showing Mr. Thrasher riding a horse dressed as
11
A. I wrote him, I believe or somehow communicated
12
Napoleon.
12
with him and said, you know, why. I think I objected.
13
Q. In fact, you refer to them as artwork?
13
Eventually I did take them down when he sent me a notice of
14
A. Well, I think they are artwork. I take pride in
14
code enforcement violation cause I didn't want to go through
15
that. I'm an artist. It was a lot of photo shop. Maybe a
15
that again.
16
little too much time spent on things like that. But yeah, 1
16
Q. You looked at them, you said arguably they are
17
was proud of those and I thought they were communicating a
17
artwork, I don't want to deal with this and I might be wrong
18
pretty clear political message.
18
here and I might get cited and you took them down?
19
Q. And you have come to the commission meetings and
19
MR. HANNA: Object to form.
20
described them as artwork; right?
20
THE WITNESS: I'm becoming more of an advocate 1
21
A. I did come to a meeting and announce that I was
21
guess for speech at the time and due process. In my
22
going to have an exhibit exhibition on display in my home.
22
layman's opinion due process means everybody is treated
23
Anybody that was happy to come by. I think I showed them
23
the same. Since I knew of objects des art according to
24
one where the commissioners were, their faces were
24
what I think his definition was all over town I sent
25
superimposed on a gaggle of monkeys. And I can't remember
25
him about 50 pictures, residences with graphic
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Illustrations.
1
As I said, I was in fear for future or more retaliation.
2
BY MR. STEARNS:
2
Q. Okay. But you took it down?
3
Q. Remember we talked about before the depo about
3
A. I removed those pieces.
4
answering my questions?
4
Q. Thank you. Okay. When you are next talking about
5
A. I think I am answering your questions.
5
you said you went around and canvassed everybody else's
6
Q. No, you're talking about something else. I am
6
property?
7
talking about your decision-making in taking down the
7
A. I drove around town and took some pictures from
8
artwork.
B
the street of objects des art all over town. As far as 1
9
MR. HANNA: He's trying to answer your question
9
understood objects des art to be. The Information I got
10
the best he can.
10
from the town.
11
MR. STEARNS: No, he's not. He's talking about
11
Q. What things did you term to be objects des art?
12
other people. I want to talk about him right now.
12
A. One person has a five foot diameter sun face, sun
13
THE WITNESS: Well, why don't you write down what
13
with radiating lines coming out of It. Another has
14
you'd like my answer to be and I'll read it back to
14
decorative clock. There's finials of fruit baskets. There
15
you?
15
were dogs, stone Whippet dogs at the mayor's house. There's
16
MR. STEARNS: I'll do that for you if you'd like.
16
little plaques with filigree and leaves. I mean, it is so
17
BY MR. STEARNS:
17
Ironic because there's are the kinds of things I make for
18
Q. What I am saying to you Is you reviewed the
18
other people, decorative objects so I have an eye for that.
19
letter, the notice saying this is objects des art, take it
19
1 am seeing them all over the place. There Is even painted
20
down or we are going to Issue code enforcement proceedings
20
tile, looks like a painting. Actually, it might even be a
21
against you; right?
21
painting on Gulf Stream Road. It is still there today. As
22
A. Right.
22
a matter of fact, drove by it this morning. Weather veins
23
Q. You made an independent decision to take it down
23
that showed Images of golfers hitting a ball. Stone
24
after looking at what you had up there and what you were
24
rabbits. All sorts of things that are considered I think,
25
potentially being cited for; right?
25
1 mean a reasonable person would say it could be objects des
Page 78
Page 80
1
A. I believe I —
1
art.
2
Q. — that's a yes or no question and then I'll let
2
Q. Could be you're saying?
3
you explain?
3
A. Reasonable person would come to that conclusion,
4
A. Yeah, I believe I wrote a letter to Mr. Thrasher
4
yeah.
5
and explained to him that I objected, disagreed with him but
5
Q. What did you want done about these other objects
6
1 couldn't go through that code enforcement thing again.
6
des art as you reference them?
7
And under duress and objection I was going to take them
7
A. Well, what I really wanted done was to call
8
down.
8
attention to the fact that hey, you're pulling off some
9
Q. Okay. So yes, the answer to that question Is yes,
9
obscure code, dusting it off to throw at me but it seems
10
you decided to take it down after receiving that notice;
10
that it has been in violation of it all over the place for
11
right?
11
who knows how long and do you really think this is fair.
12
A. I just answered the question.
12
But In so many words what I said here's something I think is
13
Q. I want a yes or no answer and then you can
13
a violation of town code, basically what are you going to do
14
explain. My question is this.
14
about it.
15
A. I'm a round guy. You want me to go In a square
15
Q. Okay. Did you receive any response?
16
hole.
16
A. Never.
17
Q. No, it's not that hard. It's actually a yes or no
17
Q. When did you —
18
question.
18
A. — sorry, let me back up. I made a public records
19
A. The world is not black and white.
19
request months later and said, you know, regarding what had
20
Q. You reviewed the notice. You saw what you had on
20
been done about it. Was told by the clerk who is also the
21
your property and you decided to remove the artwork from
21
custodian of records no records exist. That's the terse
22
your yard?
22
answer for meaning nothing has been done.
23
A. I disagreed with the notice.
23
Q. Okay. When did you provide this information to
24
Q. Fair enough.
24
the town?
25
A. Disagreed with the notice. Took the things down.
25
A. You know, 1 still do. It has been ongoing since
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then.
1
Q. What's the name of the inlet?
2
Q. You would like to see those objects removed?
2
A. Well, it's actually called South Palm Beach Inlet.
3
A. No, no. I say in my letter that I think the
3
It's also called the Boynton Inlet. Bird Island Inlet.
4
property owner has every right to display them. I think
4
Basically a shallow area in the estuary where boaters
5
they are reasonable. I think they are somewhat quite
5
frequently moor their boats on the weekends.
6
attractive. But I am calling your attention for the sake of
6
Q. Okay. You said you moored it there. Where else
7
due process that everybody is treated the same, what are you
7
had you moored it?
8
going to do about it.
8
A. Well, primarily In Polo Cove.
9
Q. Did you ever post your artwork at your property a
9
Q. What is Polo Cove?
10
second time?
10
A. Polo Cove is lake that I believe Lakeview Drive
11
A. I can't remember now. I think yeah, as a matter
11
was named after. It's a body of water appendaged off the
12
of fact, I did.
12
intercoastal or waterway that is surrounded by homes except
13
Q. When do you that?
13
for the egress point. And I believe It Is town property.
14
A. For Christmas I put some holiday banners up. 1
14
The submerged land.
15
think it was a Christmas tree and a noel, Santa Claus, a
15
Q. The submerged land of Polo Cove Is town property?
16
snowman. I don't know if there was any political banners at
16
A. I believe according to the Palm Beach County
17
that time.
17
records it is designated as belonging to the Town of Gulf
18
Q. Was Mr. Thrasher's face on the snowman, Christmas
18
Stream. As opposed to some of the coves that are actually
19
tree, anything like that?
19
property of the adjacent homeowners. Their property line
20
A. I can't recall that. That would have been funny
20
goes out to the middle of the cove.
21
though. No. But I wouldn't have put him on Santa Claus.
21
Q. When you moored the boat at South Palm Beach
22
Maybe the Grinch. But I don't think I did that. I can't
22
Inlet/Boynton Inlet had you had any communications with the
23
recall that.
23
town about that?
24
Q. So It was traditional holiday decorations you put
24
A. The only time they talked to me was when — It was
25
up?
25
communicated to me was when it was in Polo Cove and then
Page 82
Page84
1
A. Yeah, yeah. There were holidays decorations
1
later when my neighbor had notified them that the boat was
2
similar to what my neighbors do. They put up flag when
2
submerged in the coast because it had sunk. And there was
3
someone is having a birthday. Call attention to it.
3
also communication when I asked the police to file a report
4
Valentine Day things.
4
because It was evident the lines to the boat had been cut.
5
Q. What I am asking you was there any time that you
5
Q. All right. Soto answer my question, no there had
6
put up your artworktpolilical satire documents that you
6
been no communications about South Palm Beach Inlet?
7
referred to up at your property?
7
A. I thought you asked me the times where I was in
8
A. When I wasn't persecuted?
8
communications with the town. So no, I was only notified by
9
Q. Yeah, other than the one time that you look it
9
the town I believe when It was In Polo Cove and when it was
10
down.
10
sunk In the Intercoastal.
11
A. I'm sorry, you're saying on my property or town
11
Q. So when it is in Polo Cove which is town property;
12
property?
12
right?
13
Q. I'm talking about on your property.
13
A. Yeah.
14
A. On my property I don't recall.
14
Q. What did the town say to you?
15
Q. Okay. And now you say on town property. Tell me
15
A. I'm sorry, say that again?
16
about that?
16
Q. What communications did you have with the town
17
A. Yeah, my opportunities for speech were getting
17
about the boat In Polo Cove.
18
narrower and narrower. So I was racking my brain. I got
18
A. I was given a hand-delivered letter on a Sunday
19
the website trying to call attention to some of these things
19
morning that Mr. Thrasher had written earlier that morning
20
which nobody seems to care much which is reasonable.
20
that referenced a complaint from, I believe it was Mayor
21
Everybody's got their life to live. This is my concern. It
21
Orthwein the night before, Saturday night. And the
22
occurred to me that I could put banners, political signs,
22
policeman delivered the letter telling me to get the boat
23
artwork, if you will, whatever, on my boat and moor the boat
23
out of the cove or face the consequences. Words to that
24
In the intercoastal. Put it at the inlet in Delray or In
24
effect.
25
the waters of the Town of Gulf Stream.
25
Q. What was their reason for telling you to get it
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85-88
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1
out of the cove?
1
A. I can't recall. 1 don't think so.
2
A. I believe he said I was trespassing on town
2
Q. What's your fee arrangement with Mr. Hanna in this
3
property.
3
case?
4
Q. What did do you?
4
MR. HANNA: Object to the form. Instruct the
5
A. I know that we moved the boat. We were moving the
5
witness not to answer.
6
boat in and out of there anyway. I am not sure how soon
6
MR. STEARNS: On what basis? You're seeking
7
after we moved the boat. Again, with that threat I thought
7
attorney's fees?
8
well, here's another speech opportunity I am not going to be
8
MR. HANNA: Ones we are entitled to.
9
able to use. Eventually yeah, we moved the boat.
9
MR. STEARNS: It is discoverable.
10
Q. The boat was basically a 20 footer? Something
10
MR. HANNA: Instruct the witness not to answer.
11
like that?
11
MR. STEARNS: Please certify that for me.
12
A. 16. Very tiny.
12
THE WITNESS: I pay him. He represents me. 1
13
Q. 16 foot boat with your artwork displayed on it?
13
pay him.
14
A. We had some banners hanging from it.
15
Q. Banners being critical of the town?
14
BY MR. STEARNS:
16
A. Printed on canvas. Pictures of Mayor Orthwein.
15
Q. How much do you pay him an hour?
17
Q. What did your neighbor say to you about this, your
16
A. Too much.
18
conduct in displaying these banners?
17
Q. How much?
19
A. You know, that is an Interesting question because
18
A. Probably not enough in his eyes. No, I don't want
20
when I move to Plaza Au Solei, you know, you meet your
19
to go any further than that. I do pay him.
21
neighbors walk at night on the street. People walking their
20
Q. How about Mr. O'Boyle?
22
dogs, riding their bicycles. We had lots of conversations.
21
A. Yeah, nobody works for free.
23
Lots of criticism. That's typical. People usually
22
Q. Mr. Roeder?
24
criticize authority, complain about things.
23
A. He doesn't work for free either.
25
Q. Criticisms about the town or criticisms of you?
24
Q. So when all three of these guys are sitting
86
25
here —
age 86
Page -W
1
A. Oh, no, this is of the town. I got some really
1
A. — I work for flee.
2
goad comments though. One guy — mostly from the kids. The
2
Q. All three of these guys are silting here in all
3
kids whose parents I guess wouldn't want to comment one way
3
these depositions you're paying all of them?
4
or the other. Man, we laughed when we saw that. And
4
A. Yeah, yeah. I feel like I need that
5
another kid said yeah, my parents think that is right -on but
5
representation. How many attorneys does the town have?
6
they will never tell you. Things like that.
6
Six, eight?
7
Q. Okay. So you're directed to remove the boat from
7
Q. Just me.
8
town property; right?
8
A. That Is not true. I am just.
9
A. Yeah. Threatened with trespass.
9
MR. STEARNS: You're instructing him not to talk
10
Q. You do it?
10
about your hourly rate?
11
A. Actually, now that I think about It I was actually
11
MR. HANNA: I think he already did.
12
sued for trespass for having the boat on town property.
12
MR. STEARNS: No, he didn't say what the rate is.
13
Q. Okay. What was the result of that suit?
13
MR. HANNA: I don't know if he even knows.
14
A. I wish there was a result cause these rases never
14
THE WITNESS: We are now in —
15
seem to come to fruition.
15
MR. HANNA: — let's take a quick break so I can
16
Q. Is it pending?
16
clarify.
17
A. That is pending.
17
(Brief recess was taken.)
18
Q. Are you represented by an attorney In this case?
18
BY MR. STEARNS:
19
A. Yes.
19
Q. What's the hourly rate?
20
Q. Is that Mr. Roeder?
20
A. Mr. Hanna is $375 an hour.
21
A. I think he made a notice of appearance on that.
21
Q. About Mr. O'Boyle?
22
Q. Who else represents you?
22
A. Gee, I don't remember. It is less.
23
A. I think Mr. Hanna has made a notice of appearance
23
MR. O'BOYLE: I will just jump in. It's $200.
24
but I can't recall right now who else. I think that was it.
24
BY MR. STEARNS:
25
O. What about Mr. O'Boyle?
25
Q. Mr. Roeder?
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OHARE vs. TOWN OF GULF STREAM
89-92
Page
age 91
1
A. I don't know. I don't know. Usually like — he's
1
But I just thought she was pretty shabbily treated and
2
four to $6,000 a month. It Is all kind of jumbled together.
2
wouldn't have been treated that way unless she was my
3
He would have to parcel his hours to answer to question.
3
mother. Subsequent to that October of 20141 sat in a
4
Q. Fair enough. Can you tell me what is the next
4
commission meeting and listened to again, being accused of
5
Item or activity, conduct of the town that you believe was
5
all the town's troubles. And Mayor Morgan now at the time
6
retaliatory for your First Amendment speech?
6
saying that I was destroying the town by a thousand cuts.
7
A. I believe after Mayor Morgan was elected in March
7
And Instead of that, they were going to get rid of all of my
8
the next thing the town did was hire an attorney who used to
8
litigation by suing me Instead and introduced an attorney
9
represent me who I believe had Intimate knowledge of me and
9
named Richman who was on the phone. And laid out their
10
my affairs. Then the town started a campaign of publicity
10
plans for Instituting a RICO against me for committing
11
publishing articles in the Coastal Star accusing me of all
11
organized crime. For asking for too many public records and
12
their woes and legal expenses and other expenses in regards
12
for suing the town, for all these other Issues which the
13
to public records. And the mayor occasionally would send
13
mayor described as totally frivolous and maliciously — no,
14
out letters basically blaming me for their troubles. The
14
scandalously malicious. So you can Imagine the effect that
15
most recent letter I see still Is still on display out in
15
has when I would go around, see people.
16
the lobby, I picked it up, where the mayor basically tells
16
Q. Okay. What conduct do you believe that the RICO
17
everyone in town that I have been complaining about other
17
lawsuit is the related to?
18
residents and list the properties I complained about which 1
18
A. Well, I read the complaint. It says that I asked
19
had never, ever heard anybody ever do before. And the
19
for too many records and I have too many lawsuits, that I am
20
ramifications of that Is after that letter was mailed out my
20
somehow calluding with other entitles to punish not only
21
good friend Peter across the street was livid, stopped me in
21
this town but other towns and the state.
22
his car and to the point where he was talking and spitting
22
Q. Okay. Is there any other way that you believe you
23
at the same time. He was so upset and couldn't understand
23
have been retaliated against by the town for any First
24
why I would bring any of the town's attention on his
24
Amendment speech?
25
property. Let's see.
25
A. 1 want more on the house.
Page
age 92
1
After that, I think this was after the RICO.
1
Q. 1 am just asking you, sir, if there Is anything
2
Probably the most egregious — well, not the most egregious.
2
else that you are claiming in this lawsuit?
3
One of them. On Valentine's Day of 2014 I had Invited my
3
A. I can't recall at the moment. I am sure during
4
elderly mother to come visit and said just for laughs why
4
trial we have all sorts of posters laying it all out.
5
don't you come to the commission meeting, you can see your
5
Q. This is the time for you to tell me though. As
6
son speak to the commission. She's in a wheelchair and that
6
you sit here today right now is there something else you can
7
turned into a fiasco with commissioners laughing at her,
7
remember?
8
asking her if she could really walk. Asking her If I was
8
A. I'm sorry, my head is pounding and I can't recall
9
really her son. And it was very humiliating and
9
anything else.
10
embarrassing both for her and for me. You can see now
10
Q. You also sued the town for claim of Intentional
11
there's little papers taped around town explaining if you
11
infliction of emotional distress?
12
need wheelchair assistance just ask. Things like that.
12
A. Yeah.
13
That wasn't there that day. Of course, she had a heck of a
13
Q. Okay.
14
time. Not wanting to go through, put her through the strain
14
A. Sort of a catch-all tens that doesn't come close
15
of litigation we did not pursue any ADA action. But that
15
to describing it.
16
was a very embarrassing day. And I think that they would
16
Q. You sued David Ginsberg for Intentional Infliction
17
not have treated, certainly not a resident of town, but any
17
of emotional distress. What has Mr. Ginsberg done to you?
18
other old lady that way that hadn't been my mother.
18
What type of conduct has he engaged in that you believe was
19
Q. Who was it that said these things to your mother?
19
outrageous?
20
A. Joan Orthwein. She wasn't mayor at the time. Mr.
20
A. Um, after that Incident when I had discussions
21
Thrasher. I think Kelly Avery talked to my mother. One of
21
with my wife about whether we want to go on to live in this
22
the ladles said that Kelly said that she said she could
22
town and abandon our Investment I guess my daughter
23
walk. Which unfortunately my mother's mental state Is she
23
overheard that. She once asked me when those policeman
24
likes to think she can do things. Probably thinks she has a
24
parked in front of our house for a couple of hours, she said
25
Jaguar. But she can't. But she is cognizant most of time.
25
Papa, is that one of the good policeman or the bad
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OHARE vs. TOWN OF GULF STREAM
93-96
Page 93
Page 95
1
policeman. And I thought man, this Is not the way I want to
1
A. He made me question whether we are In the 21st
2
raise my kid to have any suspicion of any policeman. But
2
century or not. I mean, this kind of behavior you would
3
besides my daughter Remi, I was raised a certain way. There
3
expect In the south in the '50s. For a police officer to
4
were certain influences on my life that made me what I am
4
come in your house that changed my perspective to the point
5
today. And that person, you know, we all have self -Images
5
where I am not the same person.
6
and since Officer Ginsberg's actions and the subsequent
6
Q. Okay. We are talking about the October 28, 2011
7
actions, my self -Image is completely changed. I do not feel
7
Incident?
8
like the protector, like the patron like some of my Spanish
8
A. And the fact that other things reprocussed, if
9
relatives call me. I don't feel like I am capable of coming
9
that's the word, from that. It's like throwing a rock in a
10
to people's defenses. The whole concept of democracy is
10
pond. The ripple effect that, of the behavior of certain
11
stuff I learned in the Boy's Scouts, civics class and
11
town officials which I think are from that incident and
12
politicking for Shelly's relatives or the legislature. 1
12
maybe what things Mr. Ginsberg might have said to other
13
don't believe it anymore. It is completely — I know It's a
13
people in town. Yeah, I see that all as a single
14
perception thing but I don't look at the world the same as 1
14
retaliation.
15
did back then.
15
Q. Well, the thing is the town is Immune. You can't
16
Q. You still participate in the town's government and
16
sued for claims of intentional Infliction of emotional
17
attend meetings?
17
distress.
18
A. Yeah, and I still try to mitigate the damage by
18
A. Shouldn't be.
19
responding to the Coastal Star. Of course, it's on the
19
Q. That's the law though. So the law is you can
20
website. I don't know if you read it. And I still try to
20
bring that claim only against this sovereign employee which
21
speak up. But it has almost become obsessive. I mean, when
21
in this case is David Ginsberg. You told me about the
22
the kids were small we used to go snow skiing, go out on the
22
October 28, 2011 incident.
23
boat all the time. And now if I have any spare time when 1
23
Is there anything else that David Ginsberg did
24
am not working which I don't get any joy in work anymore. 1
24
that you believe was outrageous?
25
am at home on the computer and I'm reading state statutes
25
A. Chris, I appreciate the little law lecture. And I
Page 94
Page 96
1
and constitution and case law. Going over all these cases.
1
am sure you are probably right. I don't know the finesses
2
Maybe I've become somewhat obsessed about it. My home life
2
of the whole thing. But If Ginsberg Is the only person who
3
has completely changed from where it was three years ago.
3
Is personally responsible then I can lay the blame for
4
Q. I thank you for that. I want to go back to what 1
4
Initiating this whole thing at Officer Ginsberg's feet.
5
asked originally.
5
Q. So that's it. There is nothing else he directed
6
A. I'm sorry if I'm not answering completely.
6
at you? Any of the conduct he did?
7
Q. Talking about the claim of Intentional Infliction
7
A. Well, I think his fictitious Incident report was
8
of emotional distress against Officer Ginsberg. You told me
8
also pretty devastating to me. To think that a person in a
9
about Ginsberg going in the back of your yard and then
9
position of authority and trust would fabricate and then lie
10
walking in the house on October 28, 2011?
10
about those other things that Mr. Gundlach testified to and
11
A. Yes.
11
perhaps Mr. Harris will as well. It just blows me away.
12
Q. Is that the basis for your claim of intentional
12
Just destroys my confidence in the system.
13
Infliction or Is there some other conduct that you engaged
13
Q. We are back to the October 28, 2011 incident;
14
In that you believe is outrageous?
14
right?
15
A. Well, just about everything the town has done over
15
A. Well, his Incident report of that Incident and
16
the last three years.
16
communications from him through the town attorney that I
17
Q. Not the town. Mr. Ginsberg —
17
received afterwards as well.
18
A. — as an agent of the town. Okay. Yeah,
18
Q. Okay. That is something new. What communications
19
individually and as an agent yeah, I believe Mr. Ginsberg
19
did you hear from David Ginsberg through the town attorney?
20
had a hand in all this.
20
A. The town attomey said that Officer Ginsberg
21
Q. The claim in the lawsuit is against David Ginsberg
21
denied that he ever stood In the street with his hands on
22
individually.
22
his hips, legs apart in a belligerent and threatening
23
A. Okay.
23
manner. Denied that he ever —
24
Q. So what I want to know is what David Ginsberg did
24
Q. — that's not something you told me about. That's
25
that you believe was outrageous conduct?
25
what I'm looking for is an Incident where he did something
jrc�)
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97-100
Page 97
Page -99
1
like that to you?
1
Plus, we haven't been able to examine our discovery yet
2
A. Okay. Officer Ginsberg came back to the house.
2
from you which I think they are doing tomorrow.
3
Never on the property but driving by on the street with his
3
BY MR. STEARNS:
4
camera laking pictures.
4
Q. I am not talking about that. I'm talking about as
5
0. When did that happen?
5
you sit here right now?
6
A. I got an exact dale cause I wrote an e-mail about
6
A. You're asking me what evidence I might have?
7
It to the attorneys. Right now I can only say it happened
7
Q. Yeah, right now. What do you know?
8
in the spdng of 2012. -
8
A. Well, technically I have that evidence but I
9
Q. What happened when he drove by taking pictures?
9
haven't looked at it.
10
A. Well, he drove by laking pictures and I felt
10
Q. The question Is simple, Chris. What do you know
11
threatened. I felt like I was under the microscope.
11
as you sit here today? You may have learned something
12
Q. Because he drove by and look pictures of your
12
later. Maybe you will find it in a public record. But as
13
property?
13
you sit here today what evidence do you have?
14
A. Well, he drove by holding a camera going click,
14
And that is, a statement, an e-mail, a letter,
15
click, click as he drove slowly by.
15
anything indicating that some protected First Amendment
16
0. Were you stili doing work at your house at that
16
speech motivated somebody to retaliate against you some In
17
lime?
17
specific way?
18
A. Still doing work today. And from that time
18
MR. HANNA: Object to form.
19
forward, yeah. I am always doing work on the house.
19
THE WITNESS: That's what we have been talking
20
Q. You just said something about him stopping and
20
about. I have plenty of letters. So many letters from
21
putting his hands on his hips and looking at you?
21
Mr. Thrasher. I've got articles from the Coastal Star.
22
A. There was another incident. I can't tell you what
22
1 have letters from Mayor Morgan. I have got letters
23
order it is in. I remember I was leaving my house when he
23
handed-dellvered by policemen. I have got code
24
was across the street presumably checking the tags on
24
enforcement transcripts that show fictitious codes
25
people's trucks for workers across the street. And when he
25
Invented for the purpose of showing my speech, you
Page 98
Page 100
1
saw me he turned, stood In the center of the street with his
1
know, for lack of a betterword. I got piles of it.
2
legs apart, fists on his hips and basically staring at me.
2
You are entitled to ask for it but. I didn't ask for
3
1 thought this guy Is a nutcase. I got In my car. Now,
3
it.
4
personal opinion, I don't know if he is a nutcase or not.
4
BY MR. STEARNS:
5
Got in my car, was shuffling some papers and looking up, he
5
0. No, I am asking you right now for the Information.
6
is still there. Eventually I think it took me a minute or
6
That is did Mr. Thrasher ever say I am doing this to you
7
so to leave. I looked at him in my rear view mirror in that
7
because of X, because you called me a bad guy?
8
posture while I drove away. I guess it was a form of, you
8
A. Not in those words, no.
9
know, let's see who's boss.
9
Q. Anything like that?
10
Q. He glared at you?
10
A. What I took from those letters was basically
11
A. Yeah, that's one way of putting It.
11
better start shutting up. The head that was looking for the
12
0. Did he take his gun out and point it at you?
12
sword.
13
A. No, thank God.
13
Q. That Is something you, yourself have taken out of
14
Q. Have you told me about all of your Interactions
14
the letters and that's what you suspect?
15
with Officer David Ginsberg?
15
A. Yeah, the way I feel and whatever consequences
16
A. For standing, banging on the door, trying to get
16
from feeling that way I attribute to this three years of
17
In. I think that's about it.
17
awfulness.
18
Q. Okay. What evidence do you have that any
18
Q. Nothing has happened to you other than people
19
particular town employee was motivated by an Intent to
19
saying bad things since basically 2012 when your last permit
20
retaliate against you for any First Amendment speech?
20
application was dented?
21
MR. HANNA: Object to form.
21
MR. HANNA: Object to form.
22
THE WITNESS: You know, I have made so many
22
THE WITNESS: Well, when you say happened to me
23
public records requests trying to get to the bottom of
23
nobody has pointed a gun at me.
24
this whole thing. I can't tell you right now what
24
BY MR. STEARNS:
25
evidence I might have that I haven't even looked at.
25
Q. I'm talking more simple. There is nothing you
O
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101-104
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1
sought from the town that has been denied like a permit
1
marijuana and all sorts of things. I was at first
2
application? You haven't been issued any citations,
2
suspicious that he was trying to bait me or get to me to say
3
violations?
3
something that would be Inappropriate. He basically told me
4
MR. HANNA: What timeframe are you talking about?
4
that I should cut it out.
5
MR. STEARNS: I said in the last three years.
5
Q. What exactly did he tell you?
6
THE WITNESS: Last three years?
6
A. I didn't have a tape recorder and I don't have a
7
BY MR. STEARNS:
7
photographic memory. I have a recollection of the
8
Q. Yeah.
8
conversation and the Intent.
9
A. Code enforcement was in 2013 1 believe.
9
Q. Basically you should cut what out?
10
Q. For the open front lawn aspect?
10
A. That a reasonable person would not be, you know,
11
A. Yeah, that and planting lady palms. I wanted a
11
would be — you know, I am afraid I am going to misquote him
12
permit for a target in the back of my backyard. I wanted a
12
and I can't quote him. I can only tell you what my feelings
13
permit for a solar energy roof. All these things exempt
13
were of the conversation. My feelings were that 1 should
14
from local regulation by the state which the town thumbed
14
cut it out, that I should hold back on some of these things
15
Its nose at. I mean, that's what we have been talking
15
1 was doing to call so much attention to cause the town so
16
about. You want me to give you a list of documents7
16
much trouble.
17
Q. Sure.
17
Q. Did he tell you that he had been Instructed to
18
A. There is a lot of them. There is hundreds and
18
single you out for any type of enforcement?
19
hundreds of them.
19
A. No, the only time he said something like that was
20
Q. Hundreds of them. And they say no, Chris, Mr.
20
when he delivered a note about my sunken boat saying that
21
O'Hare, you can't that have this because you called me a bad
21
the Florida Fish and Wildlife said get it out of the water
22
guy?
22
quick or I'd face all sorts of fines.
23
A. You know, English Is my first language. And I was
23
Q. So that was a note from Florida Fishing and
24
also taught to read between the lines and yeah, get that.
24
Wildlife?
25
Q. So It's lot of supposition on your part?
25
A. No, it was a note from dispatch in town. Somebody
Page 102
Page TOT
1
MR. HANNA: Object to the form.
1
In the police development. I think it might have been
2
THE WITNESS: Not sure what supposition means.
2
Officer Pasagiatti (phonetic) that he was delivering to me.
3
You mean am I —
3
It was kind of strange cause the boat had only sunk the
4
BY MR. STEARNS:
4
night before but he was saying he was carrying the order
5
Q. Speculation?
5
around for three days trying to get a hold of me.
6
A. You mean am I fabricating this —
6
Q. There's a conspiracy out thereto sink your boat
7
Q. — not fabricating. Saying you're deducting,
7
and then get this letter for you?
8
deducing?
8
A. I'm sorry?
9
A. You agree with me it's not a fabrication then?
9
Q. You're basically asserting that there was a
10
Q. I don't know if it is.
10
conspiracy to prepare a letter three days before, sink your
11
A. Okay. Now, my feeling is that there's a lot of
11
boat and then deliver the letter.
12
retribution. I know I've got a lot of anxiety over this.
12
A. No, not at all. My boats, according to Peters
13
It is killing my family. Not literally. It is very
13
wife across the street cause she's the one who called it
14
upsetting. I have a lot of documentation.
14
Into town, Ann, was that there was a sunken boat. The town,
15
Q. Did any town employee ever tell you that things
15
1 guess from the shoreline on the golf course or the numbers
16
are happening to you because of something you said?
16
of the hull that was sticking up, determined it was my boat.
17
A. Yeah.
17
They had written a note that was taken from a call from Fish
18
Q. Who?
18
and Wildlife or maybe they called Fish and Wildlife. 1
19
A. An Officer Christ Harrod.
19
don't know. There was a note saying get your boat out of
20
Q. Harrod?
20
the waterway or face fines. He mentioned that he had
21
A. H -A -M -O -R -I.
21
gotten, been carrying it around a few days but he might have
22
Q. What did Officer Harrod tell you?
22
just made a mistake.
23
A. He has come to my house a number of limes and we
23
Q. Are you accusing someone of sinking your boat?
24
had a lot of discussions about his previous work experience
24
A. I took pictures of the two lines. It had two
25
and his experience with the courts, his family growing
25
anchors for stability with a seven to one rod as you're
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105-108
Page 105
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1
supposed to do. And both lines had been severed cleanly the
1
now, like I said, right now my spare time is spent in front
2
same length from the hull as if you had grabbed a boat and
2
of the computer. I am consumed with that. And I could tell
3
sliced through the line. To me that looks suspicious. Now,
3
you physically in 2011 October I was 80 pounds lighter. 1
4
1 asked Officer Pasagiatti to Investigate that. He filed a
4
find a lot of comfort in stuffing my face. You know, it
5
police Incident report. Doubt If anything ever happened
5
doesn't matter If I start out with desert and end up with
6
after that. I felt an obligation to at least do the proper
6
steak and stuffing my face. I have no feeling of satiation.
7
channel thing.
7
I just have this need. But beyond that, I mean, the
8
Q. Had the boat drifted away from the mooring spot?
8
backache, the neck aches, the headaches. Just really
9
A. Yeah, it was about 50 feet away. It had rained
9
stressful. It is embarrassing. I see people.
10
pretty heavily. There was a lot of weather events that day.
10
1 will go Into A-1 Industrial where I buy steel
11
So It took me until about 11 o'clock at night to get the
11
sometimes. And the girl there Penny I have known for 20
12
tide right where I could get with another boat and retrieve
12
years and she'll say, you are in organized crime. Most
13
It. get it out of the waterway. I didn't want to get a
13
people, I don't want to say they are dumb. But they believe
14
hazards notification.
14
what they read. Gullible or naive. They are not used to
15
Q. So what you are saying is somebody cut the ropes?
15
the back and forth of the legal fight, whatever. And they
16
A. It appeared to me that way. I told Officer
16
all read the Coastal Star. I can't believe how pervasive
17
Pasaglatti but I don't know for sure.
17
that paper is. But the 7 -Eleven where I buy my coffee in
18
Q. Who did you believe did it?
18
the morning. This woman Peaches, she points her finger at
19
A. No Idea. For all I know It could have been kids.
19
me and says oh, you're In organized crime. You know, most
20
Q. So you're not accusing the town of doing that?
20
folks want to give me a high -five like somehow that is a
21
A. I never did that. That wouldn't be paranoid. 1
21
badge of honor. Like Jesus.
22
don't think that would happen. These are mostly responsible
22
I never was a self-promotor but I have a
23
people we are dealing with here.
23
self -Image. When you try to validate your self -Image to
24
Q. Thank you.
24
your actions. I always felt my actions coming here,
25
A. No, I agree. In most aspects I think they are
25
publically speaking validated my self-image my self -Image
Page 106
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1
doing thelrjob. For some reason though there are aspects
1
now Is Fluid. It's a target that Is kind of moving around.
2
of it that are very frightening to me.
2
1 don't feel like I am the protector anymore. Like I can't
3
Q. Is there any other town employee that you had a
3
stralght-faced tell my kids, you know, always comply with a
4
conversation with which indicated that you are of subject of
4
policeman or, you know, the town is out there for your
5
retaliation for something?
5
well-being. Everything is just upside down.
6
A. I'm sorry, stay that again?
6
Q. This whole Issue that you have with police, you
7
Q. Is there any other town employee other than that
7
have had essentially one Incident with Officer Ginsberg and
8
officer whom you ever had any discussions with who informed
8
that has now painted your entire view of police?
9
you that you are a target for retaliation.
9
A. No, no. That was just the proverbial single straw
10
A. No, I can't recall right now. I don't think there
10
on the camel's back.
11
were.
11
Q. So there are other unrelated Incidents to this?
12
0. All right. Tell me about your damages. How do
12
A. I wouldn't say unrelated. I see it all as one big
13
you believe you have been damaged by this retaliatory
13
bundle of bad.
14
conduct?
14
0. You said the proverbial straw that broke the
15
A. You mean besides the fortune I am paying these
15
camel's back yet It was the first Incident you are
16
guys?
16
complaining about?
17
Q. Yeah.
17
A. The camel's back is not broken yet. There seems
18
A. My wife wants to divorce me. She doesn't want to
18
to be more straws there daily.
19
divorce me. She wants to divorce herself from this. I am
19
0. What other things have the police done to you that
20
not going to stop this but of course her feelings are very
20
you believe was Improper?
21
paramount to my mind. So I have been able to assuage her
21
A. I don't know why they packed for hours at a time
22
fears and assure her that everything will eventually work
22
outside my house. I assume I think just maybe sitting there
23
out. But it has put a hell of a burden on our relationship.
23
writing a report, having their lunch. Whatever. At first
24
My kids do not have the benefit of their father that 1
24
It was disconcerting. It is not so much the police because
25
thought they would have when I adopted them because right
25
1 have already spoken at town commissions during the budget
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OHARE vs. TOWN OF GULF STREAM
1 that I think the police In this town are a real asset. And
2 most of these guys are great. And being a resident of the
3 town in aspect of the police is great. Cause a lot of town
4 you're not given very — you're not given the service you
5 get here.
6 Q. Crime is low here?
7 A. Yeah, crime is low. But the attitude is
8 different. The police are friendly. Its just that some of
9 them are questionable. It also is disturbing that when this
10 questionability Is brought to the attention of town leaders
11 nothing is done about it.
12 Q. Who else other than David Ginsberg is
13 questionable?
14 A. Um, you know, I hate getting anybody In trouble.
15 It really doesn't any bearing on this except that my overall
16 feeling — I don't know how to answer your question.
17 Q. The simple fact is that you just told me that the
18 haressmentlretaliation by the town and its police department
19 has made It so you can't tell your kids to trust the police
20 anymore.
21 I'm asking you --
22 A. — not completely.
23 Q. 1 am asking you what else has happened other than
24 this incident you mentioned with David Ginsberg? Give me
25 names of other Individuals that you believe have done
June 18, 2015
109-112
1 want people to be heros. You want to stand up and do the
2 right thing and not, you know, pull back the curtains to
3 suggest that the world is disgusting that way. Corrupt.
4 Q. Who else in the town do you believe has been a
5 subject of retaliation for First Amendment speech?
6 A. I don't know. You're talking about the whole
7 history of the town?
8 Q. I am talking about anything else that you believe
9 has been a subject of retaliation.
10 A. I believe there is a lot of people who have been
11 given a little taste and decided back off, play the game.
12 But I can't give you a whole bunch of names.
13 Q. A single name?
14 A. You know, you hear at cocktail parties. You hear
15 conversations of people moaning and bitching. I can't even
16 give you a single name. And If I had it, I would be very
17 hesitant to give it because I don't want to expose anybody
18 else to this.
19 Q. What damages did you incur as a result of the
20 alleged unlawful entry of your 2520 home?
21 A. I don't get any joy at work anymore. I have
22 thrown myself into the reef construction cause it's a good
23 cause. I have commissions coming in now in Hawaii and
24 Virginia. 1 can't get into it.
25 0. You don't work any more because they came out to
1
something Improper to you?
1
your house —
2
A. Well, Officer Hamorl's comments were really
2
A. — I force myself. There's no pleasure in it.
3
disturbing to me as well. However, not to the level of
3
Q. Let me finish the question.
4
Officer's Ginsberg action. But they basically contributed
4
A. I'm sorry.
5
to the overall threats I felt by the town. But again, 1
5
Q. You're saying that you're not working as much as
6
can't say Officer Hamori was Intentional. I don't want to
6
you once did because Mr. Ginsberg came up to your project
7
get him In trouble. I don't know what his motivations were.
7
that was undergoing and entered your home when you weren't
8
Some of the things he said were bothersome.
8
there?
9
Q. I take that conversation that you had with Officer
9
MR. HANNA: Object to the form. Mischamctadzes
10
Hamori to be very different than you're saying it now. It
10
what he said.
11
sounded the first time you were talking about it that he was
11
THE WITNESS: I think I am working just as hard
12
there looking out for your well-being, saying be careful,
12
but I don't get any pleasure out of it.
13
don't do these things. Now, it seems that you're saying it
13
BY MR. STEARNS:
14
was a threat.
14
Q. Not as much fun?
15
Which one is it?
15
A. When I try to — you have to focus in art. For
16
A. Not a threat. Well, for instance, Officer Hamori
16
some artists you maybe just — Jackson Pollock you throw
17
told me about doing work in his own home without a permit.
17
paint on the canvas. Or Helen Frankenthale, you know,
18
1 felt like he was trying to encourage me to make some kind
18
splash some color and you got your art. To me it Is more
19
of admission that would help the town's case. So I thought
19
cerebral and I can't focus on that stuff without thinking of
20
that was kind of unprofessional. He told me about when he
20
all this stuff. I wake up at four in the morning and 1
21
first started as an officer working for some court. I don't
21
think about this. And when I finally do wake up at six it's
22
know he was a bailiff or something but he would deliver
22
like I'm exhausted and It Is hard to work. I mean, I do the
23
messages to the judges of the golf course and tell me about
23
work. I get it done. I meet my obligations but It Is no
24
conversations between judges and state attorneys and how it
24
fun. So that is part of it. The other part would be my
25
Is all an inside game and I should really reconsider. You
25
wife and I —
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113-116
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Page 1 15
1
Q. — we are talking about two different things at
1
to divulge the actual confidential information that was
2
the same time. Basically you state that number one, you
2
shared.
3
have a claim for violation of the Fourth Amendment which is
3
MR. STEARNS: Well, under federal and Florida law
4
the unlawful search of your property.
4
if you're seeking emotional damages that is that Issue
5
You understand that?
5
and I am entitled to know everything about it. This is
6
A. I'm sorry, my ringing Is bugging me. Say again?
6
something I would go the judge and I will seek
7
Q. You have a claim for an Illegal search of your
7
attorneys fees If he's not answering this question.
8
property related to David Ginsberg's conduct on October 28,
8
MR. HANNA: He is not going to answer the
9
2011.
9
question that Is divulging —
10
What damages do you have related to that claim?
10
THE WITNESS: — a long time ago.
11
A. You want me to take all my damages and divide it
11
MR. O'BOYLE: This is a therapist a long time
12
up and say this went to that, this went to the town's demand
12
ago. We are talking garden variety emotional distress.
13
to search my property and this went to this? I'm not
13
MR. HANNA: It Is not related to this. It's
14
prepared to that do now.
14
related to something in Ocean Ridge. To the extent the
15
Q. You said that you suffered loss of emotional
15
only reason it is related to this is Bob Sweetapple was
16
well-being. That is what the complaint says. Is that true?
16
representing him.
17
A. Yeah, that is one way to put it.
17
MR. STEARNS: So you're claiming that any
18
Q. You lost a sense of security?
18
emotional damage and his mental condition in the past
19
A. That is definitely one way to put it.
19
is irrelevant to a claim for emotional damages lost in
20
Q. All right. Did you go to any mental health
20
this case? And I am not entitled to ask questions
21
practitioner of any kind for this emotional loss that you
21
about it?
22
suffered?
22
THE WITNESS: Well, if I can clarify that? 1
23
A. I see people In the past and pretty much got
23
didn't feel like I suffered emotional damages from that
24
turned off of the whole process. The last therapist I saw
24
in the past. I suffered — well, I just didn't trust
25
was recommended by attorney Bob Sweetapple. After seeing
25
the guy.
Page
age 116
1
him for six months It turned out he wasn't a therapist and
1
BY MR. STEARNS:
2
he was telling Bob a lot of what was going on. I don't feel
2
Q. You sought treatment with him about emotional
3
comfortable with that.
3
Issues, mental issues. You talked to him about stressors In
4
Q. Who was that therapist?
4
your life?
5
A. Heath King was his name.
5
A. Right, but that doesn't really have much to do
6
Q. What other therapists, mental health practitioners
6
with this case.
7
have you seen In your lifetime?
7
Q. Sure It does. It goes to your emotional
8
A. None since him. I can't recall before.
8
well-being In the past.
9
Q. You don't remember the names of anybody you went
9
A. I also want to correct what Mr. O'Boyle said. I
10
to before?
10
don't consider this garden variety at all.
11
A. Some family therapist when I was first married.
11
Q. Exactly. In fact, you have got a claim for
12
You know, just typical lame things. Nothing serious. 1
12
intentional Infliction of emotional distress which is great
13
can't recall the name.
13
emotional loss. That's what you're claiming.
14
Q. When did you go to this Heath King person?
14
A. Why don't you ask me a detailed question and I'll
15
A. That would have been in 1998 through'99.
15
decide if I can answer it.
16
Q. So way back in'98,'99 this guy was breaching
16
Q. Okay. What reasons did you treat with Heath King?
17
confidentiality and giving whatever information you had to
17
A. Emotional reasons.
18
Bob Sweetapple?
18
Q. What emotional reasons?
19
A. That's my opinion, yeah.
19
A. I had anxiety about my behavior and I needed to
20
Q. What evidence do you have of that?
20
work It out with someone who was dispassionate about It.
21
A. Comments Mr. Sweetapple made to me. Do you really
21
Q. What behavior was It that you had anxiety about?
22
want to get Into that here?
22
A. You know, this puts a lot of people in jeopardy
23
Q. Sure. Tell me?
23
and I don't know If I want to take the risk or just pay you
24
MR. HANNA: Actually, I mean we can get Into —
24
your attorneys fees for having to come back and ask me a
25
he has already testified about this but he's not going
25
second time. There were certain things I did that I felt
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OHARE vs. TOWN OF GULF STREAM 117-120
1 bad about. I talked to Heath King about it.
2 Q. Did you violate the law? Did you -- are we
3 talking cheating on a spouse? What are we talking about?
4 MR. HANNA: Chris, why don't you just assert your
5 privilege? Deal with it.
6 THE WITNESS: Okay. Assert the privilege there.
7 I'll tell you about the times we met, the frequency,
8 the duration but I don't want to tell you about the
9 content.
10 MR. STEARNS: Please certify that question.
11 BY MR. STEARNS:
12 Q. Is there any other mental health practitioners you
13 treated with in your lifetime?
14 A. No. No one since Mr. King. Dr. King. Mr. King,
15 whatever.
16 Q. Who your primary care physician?
17 A. That's a fellow named Cohen in Boca Raton.
18 Q. Do you remember his first name?
19 A. It's Meyer, M -E -Y -E -R.
20 Q. Have you and your wife sought any counseling for
21 the marital stress you're having?
22 A. No. Except with discussions with Meyer Cohen.
23 Q. Do you claim you lost any wages as a result of any
24 of the incidents in this case?
25 A. Well, because I am self-employed that would be
Page 119
1 clalm?
2 A. Well, I have not got there yet, no.
3 Q. You also state that you suffered impairment of
4 your reputation. Please describe that to me?
5 A. Well, most recently I was meeting with Dale
6 Sugarman, the ex -manager for the City of Boynton who is now
7 with the foundation, the Andrew Red Harris Foundation. Also
8 with members from the Fish and Wildlife Commission. The
9 elephant in the room is basically this RICO accusation.
10 That has been written up in the Stetson Law Review and all
11 sorts of other publications and things and has now become
12 common knowledge by a bunch of people in municipal work
13 since a majority of my work is with the government I feel
14 like it is impaired. My reputation Is impaired.
15 Q. I get that was very conclusory. But who thinks
16 less of you? Who has ever told you they believe you're not
17 the person you once were?
18 A. Like I said before, Peaches thinks I am better now
19 being Involved in organized crime. Penny looks at me kind
20 of slanted. And my friends, engineers who work for the town
21 who don't want the town to know that they know me cause 1
22 guess it will reflect badly on them. Just a lot of people
23 In my circle that I think.
24 Q. Who will testify on your behalf and say hey, 1
25 think less of Chris O'Hare because of what happened in this
1
difficult to document, attribute to that exactly. But 1
1
case?
2
believe I have.
2
A. Most people are too polite to do that.
3
Q. Are you claiming that in the lawsuit?
3
Q. So you can't give me the names of anyone who will
4
A. Yeah.
4
come forward and say something like that?
5
Q. All right. How much wages have you lost?
5
A. I can only tell that you my wife goes to lots of
6
A. I Imagine that will be yet to be evaluated. We
6
functions. Me personally, I don't go out anymore. I don't
7
are not done.
7
socialize. But she does. She comes back usually pretty
8
Q. Where have you lost wages? Which employer?
8
upset that — you know, we have friends all over the place.
9
A. Well, I am self-employed.
9
In government. I guess they all talk to each other. She
10
Q. Sure. Which company?
10
comes back and is pretty upset that she is getting an earful
11
A. Pineapple Grove Designs is my main source of
11
about this RICO and other things that upsets her and it
12
Income.
12
comes and upsets back me. That is the source for most of my
13
Q. And how have you lost Income at Pineapple Grove?
13
knowledge about my reputation being sullied.
14
A. I've lost some jobs I couldn't perform on a timely
14
Q. Which town employees/officials do you believe have
15
basis.
15
been motivated by an Intent to side against you? You
16
Q. For what reason could you not perform them on a
16
certainly told me about Mr. Thrasher.
17
timely basis?
17
Who else?
16
A. Because the creative process In my opinion and by
18
A. Mr. Thrasher basically runs the show. I don't
19
my experience requires me to actively, emotionally and
19
know for sure that when he sent out Marty Minor to do
20
intellectually participate. Right now I feel kind of numb
2D
certain things, he sent Steve Tobias, a building official in
21
toward It all.
21
Delray to do certain things, what his motivations are but
22
Q. Have you retained an expert to address any of
22
they appear to me to be pretty sinister.
23
these wage losses?
23
Q. Pretty sinister. That is Mr. Thrasher again?
24
A. Sorry, expert about what?
24
A. Mr. Thrasher, beyond the scope of his
25 Q. Economist, someone to analyze your purported wage 125 responsibilities and duties maybe even more what his moral
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CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM 121-124
1 compass should be.
2 0. Have you ever had any conversations with Mr.
3 Thrasher about your First Amendment speech as you refer to
4 ill
5 A. At the commission meeting I think I objected when
6 1 wasn't given an opportunity to speak once on an issue.
7 Mr. Thrasher forms the agenda. It's published. The agenda
8 didn't call for any opportunity to speak. I think I might
9 have voiced my objection to that.
10 Q. Anything else?
11 A. I certainly sent him lots of letters. Or e -malls.
12 0. I'm talking about oral conversations right now?
13 A. Okay. Can you ask me again so I can more clearly
14 answer your question?
15 0. Have you ever had any conversations with Mr.
16 Thrasher about anything that you believe to be First
17 Amendment speech. Could be your signs? Could be —
18 A. Yeah. Yes. The answer is yes.
19 0. Tell me about them, please?
20 A. I can't give you a specific date or narrative.
21 But I know, I have been in town hall on a number of
22 occasions, engaged Mr. Thrasher in conversation. I always
23 try to keep It reasonable and polite. But I might have lost
24 my temper a time or two. But I know we've talked about
25 these things.
1 to Ms. Taylor who is the clerk. She is supposed to review
2 if for whatever. And qualified me as a committee that was
3 officially then authorized to go out and collect signatures
4 on a ballot initiative basically.
5 From what I recall now it was basically Ignored to
6 the point where eventually when I did bring it up during
7 discussion of the charter I said I applied for this a while
8 ago. Ms. Taylor then reacted by contacting me to fill out
9 the correct paperwork. By that time I think the procedure
10 and time constraints and all the other things had to happen
11 between that date and election had already passed the point
12 of no return so it was not worth going forward for that
13 election cycle.
14 0. Have you resubmitted your application?
15 A. To Ms. Taylor, yeah.
16 Q. When?
17 A. It was prior to that meeting cause I spoke up and
18 said how come you haven't —
19 Q. — no, I mean after this timeframe. Like in the
20 last year or two have you resubmitted it?
21 A. No, no. Pretty much gave up on that idea.
22 Q. Who Is John Carter?
23 A. He Is one of my attorneys. No longer In my
24 employ.
25 0. What type of work did he do for you?
1
Q. What has he said to you?
1
A. He represented me at the code enforcement hearing.
2
A. I don't know why that's blocked but I can't recall
2
He consulted with me extensively on this federal retaliation
3
anything he ever said to me.
3
and trespass claim. He interacted with the town attorney,
4
Q. You believe that the town did something Improper
4
town manager. Basically provided legal counseling.
5
to you related to your effort to form some type of a PAC?
5
Q. What's your relationship with Martin O'Boyle?
6
A. What?
6
A. He Is my neighbor. My friend. We don't talk much
7
0. Some political committee.
7
lately. He Is the father of one of my attorneys. He
8
A. Oh, you're talking about the amendment to the town
8
Inspired me to do certain things In the summer of 2013.
9
charter.
9
Q. What things were those?
10
Q. Describe that whole?
10
A. Well, up to that point I was being very polite and
11
A. Well, I wanted to — I learned that the town was
11
reasonable. Doing things the way I assume things should be
12
considering amending Its charter. I think it was a movement
12
done by trying to get the town to resolve this Issue with
13
sponsored by the Gulf Stream Civic Association which when
13
Officer Ginsberg and was basically getting lip service.
14
they speak the town apparently listens. So there was
14
Here it was 2013. It was about a year and a half or longer
15
discussion about amending the charter. I remember prior to
15
and nothing was happening. No response at all. Except some
16
that, I am not sure how I got the Idea. I know what it was.
16
promises by attorney Randolph which turned out to be empty
17
1 wanted to propose a charter amendment that the town's
17
promises. Then I read in the paper that Mr. O'Boyle painted
18
zoning code be clarified, that It not be so vague, that it
18
some cartoons on his house which I thought was classic use
19
be applied uniformly. That It be reasonably understood by
19
of free speech and low and behold, the town reacted quickly.
20
or understood, rather, by any reasonable person. And 1
20
Immediately. And rectified the situation. Mr. O'Boyle was
21
thought the commission didn't seem Interested In doing that,
21
remedied on his way. And I thought damn, I am just not
22
perhaps the voters would vote on a charter amendment, put
22
doing this right. I took him as inspiration for some
23
that in the charter. So I had called up the stale, found
23
further political speech.
24
out what was required. I was referred to the county. Found
24
Q. So he prompted you to engage in the speech that
25
out from them. Basically I had to fill out a torn, get it
25
you have done?
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June 18, 2015
125-128
Page 125
Page 127
1
A. Not Intentionally. I just learn by example.
1
read so ambiguously. But there was a long, protracted
2
Q. Have you ever gotten in any disputes with any
2
litigation or threat of litigation about that. At which
3
other municipalities?
3
time the woman who I requested be replaced on the board and
4
A. Yeah, I had an issue with the Town of Ocean Ridge.
4
some other of her friends created quite a hullabaloo.
5
Q. What was that Issue?
5
Q. Resulting in what?
6
A. I was elected to the commission and the very first
6
A. Resulting In me hiring Mr. Sweetapple who did an
7
thing I did at the meeting cause when you swear in the new
7
admirable job and explained to the town how they are telling
B
commissioner you also reappoint all the board members. And
8
me now that I can't do something that they have given people
9
having being active in the town, in the garden club,
9
permission to do before and after and wanted to change their
10
volunteer programs I knew there has been a lot of criticism
10
mind so it can end right here. Which they did. We had a
11
of the board of adjustment. Basically it was run by an
11
agreement and we all went on our way.
12
elderly woman who had been on it for years and years and
12
Q. You left the commission?
13
years. She had one answer to everybody and the answer was
13
A. I left the commission about a year after that 1
14
no. She had an instance of being rude to people saying if 1
14
think. But I still was active on the commission. Still
15
can't have an extra bedroom for my grandkids, why should you
15
doing volunteer work and beautification projects. I had a
16
have one for yours. So I thought it was time that the lawn
16
lot of support. I didn't want to serve anymore.
17
reconsidered that appointment. That a lot of other people
17
Q. Was that the last time you ran for political
18
wanted to serve. And made that case. Unfortunately, 1
18
office?
19
didn't realize how tight-knit that group was and that led to
19
A. That was the last time I ran for office, yeah.
20
some political problems that I had to repair.
20
Q. Had you been a commissioner at any other city
21
Unfortunately, I didn't repair them well enough.
21
before?
22
During this very same time, my wife and I had
22
A. No, I have done a lot of work for other elected
23
found a rundown building on Tropical Drive. Broken window,
23
officials. I served an boards but never as an elected
24
weeds, septic tank overflowing. Just God awful place. Was
24
official.
25
an out of town lawyer who awned it. We settled on a price
25
Q. Had you ever sought to serve on any board here in
Page 126
-
Pages Ta
I
quickly and we bought it and started to clean It up. We got
1
Gulf Stream?
2
a permit, did everything by the book. Especially being a
2
A. No, I don't think so.
3
commissioner, you want to make sure — I have lots of
3
Q. When did you buy your first property in Gulf
4
friends in politics and they said once you're elected
4
Stream?
5
everything has got to be squeaky clean by the book. No
5
A. Around 2000 maybe. When I first met Mr. Thrasher.
6
appearance of anything wrong. So we made sure all our Ts
6
Q. Have you ever been arrested?
7
were crossed and our I's dotted. Got our permit. And the
7
A. No.
8
neighbor who had been trying to buy the building we later
8
MR. STEARNS: I have no more questions.
9
found out and was unhappy that we bought it out from under
9
MR. HANNA: I just have a couple follow-up
10
him complained that we had blocked his view of the ocean
10
questions.
11
with our new roof. It was a flat roof. Got a permit for a
11
CROSS EXAMINATION
12
pitched roof. He was mad. I think the real reason he was
12
BY MR. HANNA:
13
mad is cause he lost the deal. But he made a complaint
13
Q. If I'm not talking loud enough?
14
about it. Basically it was based on the town's section of
14
A. I'll tell you If I can't hear you.
15
the code that had to do with non-conformity which was
15
Q. I want to clarify the discovery of the mold in the
16
written by an attorney named Bill Booze who I think since
16
house when you first — before the construction started or
17
has gone to jail. But at that time he wrote a very vague
17
the renovations. How did that happen?
18
and obscure regulation that basically said if there is any
18
Did you suspect mold or did you discover it?
19
non-conformity you cannot do anything with the building. So
19
A. No, I did not suspect mold. The house had that
20
regardless of whether your non-conformity is on this side
20
kind of an old Palm Beach smell. Kind of a mixture of
21
and you have an opportunity to legally do something here you
21
cockroaches, cedar, cypress. Red carpet. There was fake
22
can't do it cause you're not conforming.
22
wood paneling in part of the house. We wanted to get rid of
23
So he used that section of the code to threaten
23
that. Usually that's tacked on top of drywall. We pulled
24
the town with a lawsuit. I thought it was completely
24
it up, there was no drywall. Just that very thin eight
25
unfair. I don't know if it was frivolous cause code the did
25
Inch, that crummy stuff. And we saw some mold there. Then
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OHARE vs. TOWN OF GULF STREAM
June 18, 2015
129-132
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Page 129
Page TST
1
1 was taking out a receptacle and found mold there. I got
1
attic, was this something you had planned on taking out the
2
suspicious not knowing how extensive it was so I pulled the
2
roof?
3
drywall off surrounding the electrical outlet.
3
A. No, I knew the house was old. I'm sorry?
4
Q. Where was the electrical outlet?
4
Q. Had you anticipated taking out the ceiling.
5
A. In the living room.
5
A. No, no.
6
Q. Were you living In the house at that point?
6
Q. And again, when was this in relation to Officer
7
A. Yeah, I moved In.
7
Ginsberg entering the house?
8
Q. What about your family? Were they living there?
8
A. About the previous week and a half. I didn't
9
A. Yes, yeah. We were all there. We had already
9
waste any time with the mold. I was getting out of the
10
taken out the carpet and cleaned the place to where it was
10
house.
11
habitable. Cleaned out the cabinets and things. When I saw
11
Q. At what point did you move your family cut?
12
the mold I kind of went a little nuts and wanted to get it
12
A. The day that I found the mold went more than just
13
all out cause I know from speaking to people in the past how
13
a few feet. I thought I could correct It by spraying some
14
dangerous some of that could be. We started taking the mold
14
bleach but I started finding the mold was more extensive.
15
out. Got cans of pump sprayers with bleach.
15
Not knowing just how extensive It was I wanted to err on the
16
Q. You are by the receptacle. You see the mold.
16
side of caution.
17
What did you do after that?
17
Q. Now, getting back to that tlmefreme too. You made
18
A. Removed the drywall in that Immediate area.
18
public records of what the town requested?
19
Q. Okay. What did you see?
19
A. Quite a few.
20
A. I was hoping I would only see a little bit of mold
20
Q. Did you make these requests prior to 2013?
21
but it went to the limits of what I removed. So I took out
21
A. I made my first request in 2011 for the code book
22
some more. And basically conducted my own Investigation to
22
before any of this started. Then In the spring of 2012 1
23
see the extent of the damage. I hadn't anticipated doing
23
was making requests regarding Officer Ginsberg's personnel
24
that but I saw it as an Immediate need that needed taking
24
file. And I had heard about a bicycle Incident where he had
25
care of.
25
caused people to fall off their bikes and I wanted to get a
Page 130
Page 132
1
Q. Now, when was the timeframe in relation to Officer
1
copy of that police report. I was making requests for that.
2
Ginsberg's entering the house that we talked about?
2
Q. Okay. Now, and this was before you ever heard of
3
A. About maybe a week and a half.
3
Martin O'Boyle and what he had done with the town in 20137
4
Q. Also how much of the drywall did you eventually
4
A. I had not heard of him or met him until the summer
5
take out?
5
of 2013.
6
A. Just about the entire living room area which that
6
Q. Do you also have a website regarding the Town of
7
already is called the great room. Walls and ceiling.
7
Gulf Stream?
8
0. Now, regarding the ceilings what did you find In
8
A. Yes.
9
the attic?
9
Q. What's the website about?
10
A. Well, a lot of Insulation had been pat down. It's
10
A. It is a mixture of my personal experience and town
11
funny because there's — well, let me back up. The
11
news and Information. I basically modeled it off the town's
12
insulation had been pat down. There was evidently a nesting
12
website and put it on steroids. So I have a lot of contact
13
going on. Bees and Insects. Like I mentioned before, the
13
Information for FPL, state government, all sorts of
14
snake. A lot of debris left over from previous workers.
14
resources. In addition to having articles and copies of
15
The wire. Wood pieces. Rotten wood and an old water
15
lawn's minutes, policies and things like that. Basically a
16
heater. Air conditioner.
16
catch-all for anything anybody who would want to know about
17
0. And how did you get that stuff out of the attic?
17
the town.
18
A. We just had the guys on ladders handing It down.
18
Q. Do you criticize any of the town's official on
19
Q. Did you have to create openings?
19
that?
20
A. We had started through the crawl space In the top
20
A. No, there was a time when I had posted some of my
21
ladder. But then when we were doing the mold removal we had
21
artwork, my political cartoons. And some of the articles
22
created enough openings in the drywall just to take it up
22
are critical. But that wasn't the purpose of it. It was
23
that way.
23
more to Inform them. I didn't want It to be labeled the
24
Q. Again, when this began was this something, debris
24
crackpot website. I wanted to have more information there
25
and the Items that you testified that you found in the
25
that a reasonable person would find helpful.
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
133-136
Page 133
Page 135
1
Q. Was some of the stuff critical of the town
1
A. At the hearing and later in discussions out In the
2
officials?
2
vestibule he said that we are entitled to get the roof, we
3
A. Yeah, yeah.
3
satisfied the code, it was up to the town to determine if
4
Q. Did you have videos that you created?
4
they had enough Information. If they wanted to have an
5
A. Yes, jibjab videos where you superimpose a
5
engineer Inspect my house It was their prerogative
6
person's face and they dance an Irish jig or sing a
6
basically. But that 1 did meet the code and I was entitled
7
Halloween song.
7
to the roof.
8
Q. Okay. And whose faces did you superimpose on
8
Q. Did the town ever ask you for more Information
9
that?
9
about your engineer or did they want to gel somebody in to
10
A. Who do you think? The commission and Mr.
10
your house?
11
Thrasher. Very funny too. Got a lot of favorable comments
11
A. They didn't seem too concerned about engineer
12
on that. It is always fun to poke fun at people. In this
12
Lunn. They didn't say anything about his resume or his
13
case it was also serving my purpose. I wanted to call
13
letter. Their insistence was that their engineer be allowed
14
attention to the articles and the way to call attention to
14
to come in the house and do his own investigation. It
15
the articles is to provide entertainment. That is the world
15
wasn't anything that I remember about him examining the
16
we live in.
16
calculations or the numbers. It was just that, like Officer
17
Q. And the drawings on the website, are they similar
17
Ginsberg before him, the engineer would now be allowed to
18
to what you had displayed In your yard and on the boat?
18
come in and look around. And we asked well, what if he
19
A. Yeah, just digital replicas.
19
disagrees, do we get a third engineer. Because as you
20
Q. Now, referring you to the meeting with town
20
probably know, experienced engineers, their opinions could
21
attorney Randolph where there was discussion about flipping
21
be all over the place. They have different motivations. If
22
the table. Was there any discussion with immigration?
22
the two engineers disagree will we have a third engineer and
23
A. Not at that meeting. Mr. Roeder had been going
23
what would be the ramifications if the engineer said put it
24
back and forth, back and forth trying to get to the bottom
24
on, would they be liable for any resulting damages if the
25
of what's going on. Attorney Randolph had said there was
25
first engineer happened to be more right than him. It's all
Page
age 136
1
burglaries which we later found out hadn't occurred. And
1
very scarey.
2
then said nothing else happened except it's in the Incident
2
Q. Now, since then in 2014 you applied for a couple
3
report which contradicted the very photographs we were
3
of types of roofs. A solar roofing system?
4
given. Then Mr. Randolph said at one time well, Officer
4
A. Yeah, I had already approached the town about
5
Ginsberg said he was looking for Illegal aliens and that's
5
perhaps a windmill. Then reconsidered that because of
6
why he slapped.
6
potential for bird damage. You know, having spinning
7
0. Who said that?
7
blades. I came across this solar sandwich roof it is called
8
A. Attorney Randolph said that to attorney Roeder
8
which is a combination of a photovoltaic film applied to a
9
that Officer Ginsberg had said to him.
9
metal surface with water pipes underneath. The purpose
10
Q. Now, how did the town officials react to that
10
being that photovoltaic films are harmed by too much heat.
11
comment?
11
They like the solar radiation to produce electricity. They
12
A. The Illegal alien comment?
12
don't like the heat. Makes them fall apart. This system of
13
0. Yeah.
13
having the water pipe actually take away the heal, capture
14
A. I don't know how they reacted —
14
that heat for the motor heaters, would reduce that
15
Q. — in the meeting did they express anything to
15
electrical demand. At the same time photovoltaic would
16
you?
16
produce electricity after a while. Great. So I approached
17
A. Um, I don't think that comment was made at the
17
the town to install that which by state statute the town is
18
meeting. That was something that Mr. Roeder forwarded to me
18
exempt from regulating.
19
that he had heard from Mr. Randolph. I don't think that
19
Q. Now, the town labeled that as being another
20
comment was made in the meeting. I could be wrong there.
20
application for a metal roof?
21
The mistiness of my memory in the past just tells me that it
21
A. Yeah, they looked at it and all they could see was
22
was passed on to Mr. Roeder.
22
metal roof. Reminds me of something I learned when 1
23
Q. What did — now, referring to the metal roof, the
23
studied yoga. You know, when pickpockets sees a saint all
24
Initial application. What did attorney Randolph say about
24
he's sees is his pocket. I think when the town saw me, all
25
this meeting requirement of the code?
25
they saw was metal roof.
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CHRIS OHARE
June 18, 2015
OHARE vs. TOWN OF GULF STREAM
137-140
Page 137
Page 139
1
Q. Now, regarding some of the activities by the Gulf
1
guess to the police since they came out. She commented to
2
Stream Police Department did they ever serve your wife with
2
me and her husband commented to me as well from across the
3
a video camera?
3
water.
4
A. Yeah, yeah. They delivered a letter to her. You
4
Q. What did they say to you?
5
mean like a service, a subpoena?
5
A. Mr. Orthwein wasn't too happy. He's yelling but 1
6
Q. Serve a document to her with a videotape?
6
can't remember the exact words. Now I don't remember what
7
A. With a letter. I found out from a record request
7
Mayor Orthwein said to Channel 12 or to the Coastal Star but
8
through an e-mail that a video had been made. So 1
8
1 am sure we could find It.
9
requested the video. It is basically like a dash cam video
9
Q. You were testified about — I will mark this as C?
10
that was made when he delivered with the document.
10
A. Yeah, this Is a letter I just saw out in the
11
Q. Do you remember what officer it was?
11
lobby.
12
A. No, It's wasn't someone I recognized.
12
(Defendant's Exhibit C was marked for
13
Q. Now with Officer Ginsberg, what did he
13
identification.)
14
specifically say about what the Walmart going in across the
14
BY MR. HANNA:
15
street in relation to your workers?
15
Q. Okay. Has there been more than —what's the date
16
A. He was bringing to my attention to the fad that
16
of that letter!
17
the Walmart was being built which I guess I knew about but
17
A. March 26, 2015.
18
didn't really care. And that the people who frequented the
18
Q. And what is basically that letter about?
19
stare, as I understand it, would be Inclined to Invade the
19
A. That is a little message to the residents of Gulf
20
neighborhood. He was going to protect me from that.
20
Stream about the goings on about town.
21
Q. And what did you do after he said that?
21
Q. And are you discussed in that letter?
22
A. Well, later I did some public records request and
22
A. Yes.
23
sure enough there was a lot of discussion about the Walmart
23
Q. Now, who sent that letter?
24
In town. A lot suspicions, a lot of fighting trying to
24
A. It Is signed very truly yours, Scott W. Morgan.
25
convince Boynton Beach not to do It or somehow restrict
25
Q. Has Mayor Morgan sent any other letters similar
Page 138
Page 140
1
them. There was a major concern In the town at the time. 1
1
like that since March?
2
really didn't do anything after that except looking for
2
A. I think I received Indirectly cause It Is never
3
public records about it. I'm sorry, if I remember your
3
addressed to me. Always get this addressed to the other
4
question you asked the Walmart?
4
properties I own which Is Gulf Stream Holdings. Maybe It
5
Q. Yes. Was there a statement by the police
5
was old one. But I've never gotten one of these to my
6
regarding Riviera Beach busting the heads of black people?
6
house. I've done a public records request asking for It.
7
A. Yeah.
7
They won't give me it. But yeah, I came Into possession of
8
Q. What was that about?
8
this letter through one of the other properties. I have
9
A. That was officer Hamod.
9
since gotten maybe a half, four or a half dozen of them.
10
Q. What did he say?
10
Q. Okay. And what are the letters usually minutes or
11
A. His previous employment was with the City of
11
—
12
Riviera Beach and he said that it was more fun there than in
12
MR. STEARNS: — object to form.
13
this rich town because everybody here lawyer's up and there
13
THE WITNESS: Frequently, yes. This is the very
14
people solve their own problems. He said only once in a
14
same sentiments expressed In the Coastal Star articles.
15
while we have to bust some heads together.
15
BY MR. HANNA:
16
Q. Now, getting to the objects des art were you ever
16
Q. And regarding those letters does your wife ever
17
cited for holiday decorations?
17
see those letters?
18
A. No, no. Never. As far as I knew through public
18
A. Yeah, she gets it.
19
records no one else has ever been either.
19
Q. How does she react to those?
20
Q. And regarding the Polo Cove Is Mayor Orthwein,
20
A. And she hears it from neighbors. I don't want to
21
then Major Orthwein's house, on Polo Cove?
21
say her standard reaction but her typical reaction Is one of
22
A. Yes.
22
great dread. She does not like this.
23
Q. Now, did she make any comments to you about the
23
Q. There was an election in 2014. Did you witness
24
boat?
24
anything regarding the election signs for Martin O'Boyle?
25
A. She commented to Channel 12. She commented I
25
A. Yeah.
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CHRIS OHARE
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June 18, 2015
141-144
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Page 143
1
Q. What did you see? Tell us about that?
1
about that?
2
A. I saw election signs being pulled from people's
2
A. No, I don't think so. I think I spoke to the
3
property and from the right of ways. And I saw one police
3
county, Susan in financials.
4
officer's car with a bunch of signs in the back seat. Also
4
Q. Would the election, the campaign committee that
5
saw at the day of the election really disgusting too. There
5
you wanted to call?
6
was Martin O'Boyle had put political signs around town hall.
6
A. Yeah, complaining rause I thought I was getting
7
1 believe the supervisor of elections had instructed they be
7
the run-around and I called the county a couple times to
8
a certain distance. And I guess the town determined that he
8
verify that I absolutely had to wait for the town clerk to
9
had violated that distance. But I think I counted as many
9
respond before I could do anything.
10
as six officers marching in lock step across Sea Road here
10
Q. What happened with that?
11
and grabbing his signs to throw Into a town truck.
11
A. I think I sent a few inquiries. Nothing happened
12
And, you know, It's funny you remind me this. I'd
12
until the public meeting where I stood there at the podium
13
forgotten all about it. Martin O'Boyle tried to hold his
13
and mentioned it.
14
signs. He wasn't touching the policemen. He was holding
14
Q. Did the town ever approve it?
15
his signs. They were basically yanking them from him,
15
A. Yes, Ms. Taylor sent me a letter telling me that
16
throwing them In the truck. I think the truck almost ran
16
my form met the standards that she was authorized to review
17
over his foot. I mean, it was disgusting. It wasn't
17
it for.
18
democracy. Politely you talk to people and you tell them
18
Q. Okay. When did that occur in relation to the
19
they are in violation of a law and you give them at least a
19
actual election?
20
moment to correct it. But to just yank those signs that's
20
A. That happened soon after I made the comments at
21
not the kind of Gulf Stream I want to think about.
21
the public meeting. How soon before the election? I think
22
Q. Now, you were talking about a metaphor of straw
22
we are talking about a couple of months maybe. I am not
23
that broke the camel's back and Isolating that Officer
23
sure.
24
Ginsberg coming Into your house somehow was the incident
24
Q. Okay. It actually was approved a couple months
25
that caused all your distress.
25
before the election?
Page
age
—144
1
Was it one of them?
1
A. Well, yeah. You see, time sequencing, you have a
2
A. It was one of them, yeah. One of the first.
2
certain period of time to collect signatures. Then there's
3
Q. Okay. Would you describe it as starting the
3
a period of time for those signatures to be reviewed by the
4
occurrences or the events?
4
county and authenticated. Then something else has to
5
A. No, looking back now I think it started when 1
5
happen. Then a judge has to say that your language is clear
6
actually met with Mr. Thrasher when I first moved to town.
6
and singular. There is a number of standards or thresholds
7
1 don't think I said the right things.
7
that have to be reached before it actually happens. And
8
Q. Would you describe it as a snowball effect?
8
each of them has a time sequence and It just wasn't time to
9
A. Well, that is exactly it. And it sort of —
9
gel it on the ballot. Then the commission also has to
10
little things that normally you would dismiss or just take,
10
approve the language. It was all new to me but leaming
11
you know, with your thick skin and move on got progressively
11
about it I realized there was no way I could go forward by
12
worse to the point where it just couldn't be Ignored. And I
12
that time.
13
guess a reasonable person would have taken steps to reverse
13
Q. Now, in relation to when you called the Florida
14
It. I was of a mind to stand up for my rights and that made
14
State Election Board did Rita Taylor ratify the application
15
the snowball tum Into a avalanche.
15
on the same day?
16
Q. Now, the Incident with Officer Ginsberg and the
16
A. No. What happened was when I made the comment to
17
subsequent Incident after that, were they all combined
17
the commission I got a letter from Ms. Taylor soon after
18
regarding your emotional distress?
18
that was basically I reviewed it and It meets the standard.
19
A. I'm sorry, you're asking me if they all
19
Something like that.
20
contributed to it?
20
MR. HANNA: Take a break.
21
Q. Yes.
21
(Brief recess was taken.)
22
A. Yes, everyone.
22
BY MR. HANNA:
23
Q. I'm trying not to stretch this out too long by
23
Q. Mr. O'Hare, the only other Issue I want to talk
24
going through each Individual act. But getting back to the
24
about Is clarifying or elaborating a little bit on your
25
election signs did you ever complain to the election board
25
emotional distress claim, how this has affected you, what
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CHRIS OHARE
June 18, 2015
OHARE vs. TOWN OF GULF STREAM
145-148
age 145
age 1-47-
1
you've gone through with the town.
1
horrendous.
2
What are some of the physical manifestations that
2
Q. Okay. Now, on the house since it doesn't have a
3
you have or physical ailments that you're having?
3
roof are you able to get Insurance?
4
A. Well, since this started I get these headaches.
4
A. Can't get Insurance. I can't get a mortgage. I
5
Backaches, neck. But I think this is me causing that
5
can't finance on the house because I don't have insurance.
6
because I just tense up. I can't sit at the computer very
6
You can't get financing without Insurance. I can't
7
long without my pain going up my back. You know, at first 1
7
technically sell the house. I'm basically a prisoner in
B
thought it is just age. But it just seems to recur when 1
8
that house because I can't put a roof on it. And, you know,
9
am in these situations where I am most Involved Win the
9
banks and Insurance companies work hand In hand, protect
10
town. When I come In here, I mean, my ears ring so loud 1
10
each other. Without a roof it is like living in a tent.
11
can barely hear what the mayor Is saying. I have to put up.
11
Q. Now, some of these physical manifestations that
12
Just the ringing Is unbelievable. I used to think that was
12
you talked about, did you have those before the Incidents
13
ear damage but it Is not there unless I am involved in the
13
with Ginsberg and the subsequent Incidents?
14
town business. Or thinking about the town or thinking about
14
A. I have noticed the ear ringing since college.
15
the RICO or any of the other things. In addition to that,
15
Usually at exam time. It kind of went away for a long time.
16
just waking up with my mind racing and not being able to
16
It would be very rare when I had that. Maybe some stress
17
focus on certain things. Cause it always goes back to this.
17
from work. But that is pretty much since October.
18
This is the most pressing Issue. It occupies my thoughts
18
Q. October of when, 2012?
19
most of the time.
19
A. 2011. It's getting progressively worse. It is
20
The relationship with Shelly is strained,
20
debilitating. It sounds like literally there is jet engines
21
especially she goes and hears from other people about things
21
behind me or the room Is full of crickets. And I have to
22
and then brings It home. It all starts over again. When we
22
hear through fog of white noise.
23
had the weather events loo that was particularly
23
Q. You attribute that to the ongoing Issues with -
24
debilitating to her. Then it would come back on me cause 1
24
A. -well, first I thought It was just purely
25
felt like my role as protector was cut off at the knees.
25
neurological. Now I am thinking I am making an association.
age146
age 148
1
Q. What specifically about the weather are you
1
I'm thinking it is occurring because of the stress. That is
2
referring lo? What's that Issue about?
2
not the only concern I have. The relationship I have with
3
A. For the first year when it would rein cause we get
3
Shelly - I don't take any joy. I told you I don't take any
4
some real rains. Occasionally a leak would develop through
4
joy In work except when I'm doing the reefs. I don't take
5
the paper and she would see all of her furniture and all of
5
any joy in our marital relations. I don't have any Interest
6
her efforts In jeopardy. And then that would lead to when
6
In it. That is completely different from, you know, me
7
are we going to get a roof, you know, why can't we just put
7
three years ago.
8
on a stone roof. And It's like well, if it collapses what
8
Q. Now, the town sued you as part of this RICO
9
then. There was a lot of that anxiety that would play on
9
conspiracy claim. How did that affect your family?
10
me. I would think about it. Like I said, I felt no longer
10
A. Oh, man. Shelly was - well, she is concerned
11
capable of being the protector and sometimes even question
11
about protecting our assets anyway but she was told by a Ft.
12
my own judgment considering the duration of this whole
12
Lauderdale attorney that you better kiss all your savings
13
fiasco. But I am committed.
13
good-bye, that people who are accused of RICO lose
14
Q. Well, that's the point. Back when this started
14
everything. She was pretty much talking about criminal RICO
15
did you expect that it would be going on Into 2015?
15
where they can freeze up all your assets. You can't even
16
A. No, no never. I thought every step of the way 1
16
defend yourself. She is not making a distinction in her
17
thought well, this is It, we have a resolution coming up. 1
17
head. And a lot of her friends aren't either. They see
18
would assure my wife this is it. You know, surely the
18
RICO Is organized crime. You know, I might as well be a
19
judge is going to see what the town did. I mean, saying
19
Gambino or Meyer Lansky.
20
that I need to get a variance when the code doesn't even
20
Q. How about your daughter's friends?
21
allow a variance for particular Items. Their very own code
21
A. She goes to Lake Worth Christian. She has had
22
says you can't do what you do and the judge didn't focus on
22
schoolmates who have parents in Gulf Stream and the
23
that. Focused on something else. So okay, now maybe the
23
schoolmates will come up to her and say your father Is in
24
next is going to solve it. Then the next thing after that.
24
organized crime, like it's a great thing. And, you know,
25
Little by little It's gotten deeper and broader and more
25
kids are funny. The things that they think are cool they
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
149-152
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Page 149
Page 151
1
will remember later on as adults when they change their
1
does RICO state it's stated in the complaint. I am not
2
perception. And now that guy was a criminal. Oh, I know
2
agreeing that we are trying this by Implication since
3
his daughter. That kind of thing. So it has a long-term
3
you're questioning him about this.
4
repercussion to your reputation. While I don't personally
4
MR. HANNA: Two more follow-up questions.
5
care that much about promoting myself I still want to be
5
MR. STEARNS: Okay.
6
considered a responsible member of society. To have
6
MR. HANNA: And I'll be done.
7
strangers come up to me about the RICO thing, it's just
7
BY MR. HANNA:
8
humiliating. It's devastating.
8
Q. Why do you feel that they threatened you with the
9
Q. Now, before the RICO case was instituted against
9
RICO case?
10
you were you ever — did I ever convey an offer to you from
10
A. Well, I know why they threatened me. Mr.
11
the town?
11
Sweetapple and Mr. Morgan and mister attorney Richman made
12
A. Yeah.
12
it clear why they are threatening me with RICO.
13
Q. What was that offer?
13
Q. What was It?
14
A. That was maybe six months prior you had told me
14
A. To make me go away. To make me dismiss all my
15
that you had met on some other occasion for some other
15
claims. Mr. Morgan's very words. Mr. Richman too. This
16
reason and Mr. Sweetapple had said to you speaking on behalf
16
will solve the town's problem, this will make these guys go
17
of Mayor Morgan and the town that unless I withdraw every
17
away.
18
single public records complaint and any other complaint 1
18
Q. Just to be clear, those statements were made at
19
had that they were going to slap me with this RICO case that
19
public meetings?
20
they had already cobbled together. It was 40 pages thick.
20
A. October 10, 2014 1 believe. At this meeting right
21
1 remember you going like this. It was a thick document. 1
21
here. Mr. Richman was on the phone. His words were picked
22
was going to be in it and I had a choice. I could either
22
up by Ms. Taylor and it was all part of the public meeting.
23
dismiss everything, gel it out of there and basically shut
23
There were members of the audience. It was a pretty packed
24
up or face the music.
24
house.
25
Q. Who was the primary focus of the RICO case at that
25
Q. The conversation you were talking about regarding
Page
age 152
1
point?
1
my conversation with attorney Sweetapple was a July 24, 2014
2
A. Well, there is a number of co-defendants. Members
2
status conference?
3
of the O'Boyle law firm, Martin O'Boyle and myself.
3
A. Yes, it was a status conference. It wasn't
4
Q. And what relation did you have to any of those
4
anything else except you were discussing procedural things.
5
co-defendants at that point?
5
1 think again a few months later you mentioned again you had
6
A. At that point Jonathan O'Boyle was representing me
6
talked to Mr. Sweetapple and he reiterated the same thing.
7
in some cases. And Martin O'Boyle was my friend and
7
And then again in Mr. Sweetapple's lobby of his office
8
neighbor. The other attorneys at the firm were also
B
during one of our depositions I think of me he said outside
9
representing me in a few public records cases.
9
as well, you know, you better wise up or this RICO thing is
10
Q. You have no business relationship with them or any
10
going to destroy you.
11
kind of arrangement with them?
11
MR. HANNA: I don't have any further questions.
12
A. I paid money to the O'Boyle law firm for services
12
MR. STEARNS: I have a couple of questions.
13
rendered. I was never involved in anything against any of
13
REDIRECT EXAMINATION
14
the municipalities. I don't have anything in common with
14
BY MR. STEARNS:
15
Martin O'Boyle, save for one case which for judicial
15
Q. These physical aches that have manifested, what
16
expediency, that was an anti -shush case where we were both
16
doctors are you treating with for the body aches and
17
denied the ability to speak which we were constitutionally
17
headaches?
18
entitled to. We both, for the sake of judicial expediency
18
A. Well, my general rare physician Meyer Cohen.
19
and to save some attorneys fees, filed that together. But
19
Q. Anybody else?
20
that is the only relationship I had with Martin O'Boyle in
20
A. No.
21
regard to any litigations.
21
Q. You mentioned your concerns about neurological
22
MR. STEARNS: Mark, to be clear here you're
22
deficits. Have you treated with a neurologist?
23
questioning ostensively about the RICO and the public
23
A. You mean an audio neurologist, yeah.
24
records aspect of the case. And you know that it Is my
24
Q. Any type of neurologist?
25
position that it is not part of this lawsuit. Not once
25
A. If that's what he is. Ear doctor.
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
153-156
1
Q. Who is that? age 153
1
DEPOSITION ERRATA SHEET
age 155
2
A. Or ENT. I can't remember his name now. It Is In
2
Page No._Line
No._Change
to:
3
Boynton Beach. We can supply you with that.
3
4
Reason for
change:
4 Q. Will you agree to do that through your attorney?
5
A. Yeah, butt can't recall.
5
Page No._Line
No._Change
to:
6
Q. But you have a record at home or something?
6
T
Reason for
change:
7 A. I am sure I could find it.
8
Q. Are there any other doctors you treated with as it
E
Page NO._Line.No._Change
to:
9
relates to your aches and complaints about the town's
9
10
Reason for
change:
10 conducl7
11
A. I have another doctor In New York who looked at my
11
12
Page No._Line
No._Change
to:
12 ears. I can't remember his name either.
13
MR. STEARNS: I Just ask that you give that to
13
14
Reason for
change:
14 Mark to send that to me.
15
THE WITNESS: Okay.
1s
Page No._Line
No._Change
to:
16
MR. STEARNS: No more questions.
36
17
Reason for
change:
17 MR. HANNA: We'll read.
18
MR. STEARNS: Thank you. I will take it.
1E
Page No._Line
No._Change
to:
19
(The witness was excused.)
19
20
Reason for
change:
20 (Deposition was concluded at 1:43 p.m.)
21
21
Page No.Line
No._Change
to:
22
22
23
Reason for
change:
23
24
24
SIGNATURE:
DATE:
25
25
CHRIS
O'HARE
JOB R 342912
Page 154
Page 156
1
DEPOSITION ERRATA SHEET
1
DEPOSITION
ERRATA SHEET
2
2
Page No._Line
No._Change
to:
3
3
4
Reason for
change:
4 Assignment No. R 342912
5
Case Name: O'Hare vs. Town of Gulf Stream at. al.
5
Page No._Line
No._Change
to:
6
6
7
Reason for
change:
7 DECLARATION UNDER PENALTY OF PERJURY
S
a
Page No._Line
No._Change
to:
9
9
10
Reason for
change:
10 I declare under penalty of perjury that I have read the
11
entire transcript of my deposition/examination under oath
11
Page No.Line
No._Change
to:
12
taken in the captioned matter or the game has been read
12
13
Reason for
change:
13 to me, and the same is true and accurate, save and except
14
for changes and/or corrections, if any, as indicated by
14
Page No._Line
No._Change
to:
15
me on the DEPOSITION ERRATA SHEET, hereof, with the
15
16
Reason for
change:
16 understanding that I offer these changes as if still
17
under oath.
17
Page No._Line
No._Change
to:
18
18
19
Reason for
change:
19 Signed on the 26th of June, 2015.
20
20
Page No._Line
No._Change
to:
21
21
22
Reason for
change:
22
23
CHRIS O'HARE
23
24
Job # 342912
24
SIGNATURE:
DATE:
25
25
CHRIS O'RARE
Sob k
342912
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
157-158
Page 157
1 STATE OF FLORIDA
2 COUNTY OF PALM BEACH
3
4
5
6 I, the undersigned authority, certify that
7 CHRIS O -HARE personally appeared before me on the
B 18th of June, 2015, and was duly sworn.
9
10 Dated this 26th of June, 2015.
11
12
13
14
15
16
17
A
20
21 DEBORAH LAWRENCE
Notary Public, State of Florida
22 My Commission Expires: 4/2/2016
My Commission No: EE184677
23
24 Job 8 342912
25
Page 158
1 CERTIFICATE
2
THE STATE OF FLORIDA
3
COUNTY OF PALM BEACH
4
5 I, DEBORAH LAWRENCE, Court Reporter and Notary
public in and for the State of Florida at Large, do
6 hereby certify that the aforementioned witness was by
me first duly sworn to testify the whole truth; that I
7 was authorized to and did report said deposition in
stenotype and that the foregoing pages are a true and
e correct transcription of my shorthand notes of said
deposition.
9
I further certify that said deposition was taken at
10 the time and place hereinabove set forth and that the
taking of said deposition was commenced and completed
11 as hereinabove set out.
12 I further certify that I am not an attorney or
counsel of any of the parties, nor am I a relative or
13 employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
14 action.
15 The foregoing certification of this transcript does
not apply to any reproduction of the same by any means
16 unless under the direct control and/or direction of the
certifying reporter.
17
DATED this 26th of e, 2015.
1B
19
20
DEBORAH LAWRENCE, Court Reporter
21
Job p 342912
22
23
24
25
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: $200..52
139:7
47:6
146:15
95:6,22
$
14
2008
21st
96:13
65:5
14:9
95:1
113:8
$200
15
2011
23,000
88:23
32:24
9:1,2
6:9
3
$3,000
18:6
16
24
60:24
23:11,21
3,500
8:12,20
152:1
$300
21:15
26:13
9:8
30:3,4,
25
23:2
85:12,13
30
12,16
55:17
$375
18
32:17
69:6
2516
88:20
21:15
39:1,25
7:18
35
$40,000
1954
42:2
16:24
8:4
6:21
16:12
47:22
18:7
350-7551
72:3
19:22
23:17
$400
1988
94:10
46:8
14:14
95:6,22
,
15 15,1717,,24
$5
1998
96:13
34:1,3,5
4 _
6:2
114:15
107:3
113:9
2520
4,000
$6,000
1:14
131:21
7:17 8:24
89:2
32:18,19
147:19
9:6,20,25
9'8
$600
1:43
10:1,4,5,
40
23:1
153:20
2012
9 17:16
6:18
47:20,23
18:4,9
149:20
48:2
33:7,12,
45
(
2
54:10
15,17,24
97:8
59:4
17:8
(561)
2
100:19
69:1,5
45,000
23:16
30:12
131:22
111:20
14:7
147:18
39:1
2535
—
1
20
2013
55:17
5
54:10
85:10
101:9
26
10
107:11
124:8,14
72:3
50
13:2,19
20,000
131:20
139:17
28:21
151:20
14:10
132:3,576:25
28
105:9
11
2000
2014
18:3,6
105:11
128:5
90:3 91:3
23:11
50s
136:2
25:10
95:3
11:34
2003
140:23
30:4,16
51
32:17,19,
69:7
151:20
32:17
72:2
22
2004
152:1
42:2
12
47:7
44:25
52
10:24
2015
48:19
53:21,25
138:25
2006
139:17
94:10
54:1,2
ESQUIRE 800.211.DEPO (3376)
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CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM Index: 530 -afternoon
530
930
26:7
137:1
47:25
9:21
7:19
48:1,6
accurate
activity
10:1,5
125:11
935
46:11
B9:5
7:19
63:18
admirable
actual
6
960
accurately
55:12,22
127:7
7:18
67:24
63:14
admission
60
71:3
110:19
97
accusation
53:21
55:23,25
119:9
115:1
adopted
143:19
8:14,16,
98
accused
7
actuality
18 106:25
114:16
91:4
148:13
56:14
adoption
99114:15,16
57.19
7 -eleven
8:19
accusing
107:17
89:11
ADA
adults
90:15
70-150
104:23
149:1
58:18
A
105:20
add
advice
41:23
70s
aches
58:7
A-1
65:6
10:22
107:10
107:8
advises
12:11
152:15,16
addition
62:19
aback
153:9
132:14
63:8
145:15
advocate
8
acquiesced
76:20
abandon
61:10
additional
92:22
14:16
aesthetic
8
act
57:17
16:12
ability
142:24
address
150:17
7:16,17
affairs
80
acted
107:3
absolutely
44:6 58:7
8:22 23
89:10
30:8 57:6
16:24
affect
BOB
71:11
acting
18:7
148:9
12:11
143:8
28:5
55:16
13:4
action
118:22
affected
Abu
144:25
90:15
addressed
9
14:16
110:4
140:3
affects
abuts
42:11
actions
addresses
9
33:7
44:20
7:14,21,
affirmed
23:22
accessed
93:6,7
24 56:20
4:7
90s
44:13
107:24
addressing
affront
13:3,20
accomplish
active
69:24
63:24
56:5
24:10
125:9
adjacent
afraid
91
accoutremen
127:14
19:8
103:11
14:14
is
actively
20:25
afternoon
12:16
118:19
83:19
35:12
93
14:14
accumulate
activities
adjustment
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
age
59:18
animals
145:8
111:20
22:12
agencies
allowed
Ann
5:19 6:10
10:7 65:1
104:14
agenda
70:14
announce
121:7
135:13,17
74:21
ambiguous
agent
answering
52.12
94:18,19
36:15
60:9
74:4
ages
ambiguously
77:4,5
8.9
127:1
94:6
agree
amending
115:7
41:3,12
122:12,15
anti -shush
57:23
66:24
amendment
150:16
71:13,25
48:6
anticipated
73:4
49:24
129:23
102:9
89:6
131:4
105:25
91:24
anxiety
153:4
98:20
102:12
99:15
agreeing
116:19,21
151:2
111:5
146:9
113:3
agreement
121:3,17
anymore
127:11
122:8,17,
93:13,24
ahead
22
108:2
45:23109:20
American
111:21
ailments
34:15
120:6
145:3
amount
127:16
air
42:11
apartment
40:25
analysis
11:25
41:10
71:14
apologize
63:11
analyze
38:11
130:16
118:25
Alice
apparently
anchors
122:14
68:19
104:25
appeal
alien
Andrew
48:5 53:4
134:12
119:7
54:19
aliens
62;2
angles
134:5
67:16
33:3
alleged
appealed
17:24
angry
45:21
28:10
ESQUIRE
46:1,7
68:2
appealing
47:23
appeals
54:21
appearance
62:22
86:21,2
126:6
appeared
105:16
appendage
83:11
applicatio
53:4,20
54:11
55:25
65:25
73:5
100:20
101:2
123:14
134:24
136:20
144:14
applicatio
s
June 18, 2015
Index: age..argument
approve
61:5
143:14
144:10
approved
62:1
143:24
approximate
3 ly
9:5 47:19
April
16:12
d architect
12:4
56:22
n 61:15
architects
6:8 14:3
architectur
al
14:3 15:7
56:5
architectur
e
40:18
applied
51:23
122:19
123:7
136:2,8
appointment
125:17
Appraiser
42:11
approached
45:8
136:4,16
13:11,13
area
19:7,8
20:9
21:1,8,
14,22,24
23:24
34:2
55:20
65:4 83:4
129:18
130:6
arguably
66:4
76:16
argument
42:19
73:7
800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
Arizona
5:2
arm
31:20
arrangement
87:2
150:11
arrested
128:6
arrived
32:5
arrives
26:18
art
5:19
15:19,24
74:1,5
75:17
76:4,7,23
77:19
79:8,9,11
80:1,6
112:15,18
138:16
artful
13:23
articles
89:11
99:21
132:14,21
133:14,15
140:14
artifical
6:13
artificial
16:8
artist
14:18
74:15
artistic
16:2
artists
112:16
artwork
74:8,13,
14,20
75:3,8,9,
13,16
76:17
77:8
78:21
81:9
82:23
85:13
132:21
artwork/
political
82:6
asks
69:11,15
aspect
15:25
101:10
109:3
150:24
aspects
57:5
105:25
106:1
assert
117:4,6
asserting
104:9
asset
109:1
assets
148:11,15
assign
44:10
assistance
90:12
association
56:21
122:13
147:25
assorted
13:17
assuage
106:21
assume
108:22
124:11
assumed
38:19
assure
106:22
146:18
AT&T
23:19
attached
19:16
attend
93:17
attention
10:15
80:8 81:6
82:3,19
89:24
103:15
109:10
133:14
137:16
attest
42:8
attic
22:5,9
26:6
130:9,17
131:1
attitude
109:7
attorney
48:18
June 18, 2015
Index: Arizona -baby's
49:3
62:21
86:18
89:8 91:8
96:16,19,
20 113:25
124:3,16
126:16
133:21,25
134:8,24
148:12
151:11
152:1
153:4
attorney's
87:7
attorneys
61:14
62:8,11
88:5 97:7
110:24
115:7
116:24
123:23
124:7
150:8,19
attracting
16:4
attractive
57:22,23,
24,25
81:6
attracts
16:4
attribute
100:16
118:1
147:23
Au
7:18 8:24
27:16
40:7
53:15
56:8
65:20
audience
151:23
audio
152:23
August
8:10,11
authenticat
ed
144:4
authority
61:24
63:15
85:24
96:9
authorized
123:3
143:16
avalanche
142:15
Avenue
7:18 8:24
Avery
90:21
aware
33:22
75:19
awful
11:9
24:23
125:24
awfulness
100:17
B
babies
8:16
baby's
10:25
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: back -beginning
back
133:24
123:4
17:17
baskets
10:25
141:4,23
144:9
18:13
79:14
14:9
142:5,24
ban
19:12
bath
17:23
145:7,17,
21:24
49:10
9:7 21:6
19:22
24 146:14
31:21
20:10
banged
34:3
bathrooms
backache
21:9
11:4
37:25
7:23 21:7
107:8
22:15
banging
38:10
Beach
23:3,4,21
Backaches
51:5
39:20
7:7,8
24:12,13,
145:5
98:16
45:22
13:16
14 25:15
backed
46:8,18
40:10,22,
28:13,17,
20:16
banks
47:15
23 41:16
25 29:18
1479
.
53:25
42:10
30:16,21,
background
banners
57:2,9
83:2,16,
23,25
27:1
81:14,16
60:1 64:7
21 84:6
32:23
40:20
82:22
80:13
128:20
33:24
backyard
85:14,15,
83:4
137:25
34:5
19:19,21
18
85:10
138:6,12
37:10,14
34:1,3
89:14,16
153:3
38:8,9
101:12
barely
98:2
39:23
145:11
100:10,19
beaners
44:4
bad
Barney
103:3,9
27:17,25
45:23
16:18
27:24
104:9
29:6,20
46:16,18
27'7'9
28:5
110:4
30:12
47:1,10
30: 2
29:22
113:2
beanie
51:10
92: 25
44:22
119:9
66:9,15
52:2
100:7,19
46:15
120:18
55:23
101:21
50:24
122:25
bearing
62:24
108:13
51:3,7
123:4,5
109:15
69:20
117:1
124:4,13
beautificat
barrel
77:14
badge
125:11
ion
80:18
107:21
45:1
126:14,18
127:15
93:15
base
129:22
badly
bedroom
94:4,9
46:5
132:11,15
28:8
21:3
96:13
119:22
based
135:6
125:15
97.2
40:19
137.9
101:12
bailiff
139:18
bedrooms
42.9
103:14
110:22
141:15
9:7 18:3,
44:15
107:15
bait
56:2 73:2
144:16
23 21:5,7
108:10,
103:2
126:14
147:7
Bees
15,17
149:23
111:2,11
ball
bases
130:13
bass
i
114:1627:15
44: 1
began
116:24
49:25
basically
6:1 67:15
87:6
130:24
120:7,10,
79:23
10:10
94:12
beginning
12 130:11
ballot
11:11,17
118:15,17
9:3 25:22
131:17
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: behalf -broken
39:23
28:23
blaming
Bob
119:6
behalf
43:21
89:14
113:25
137:25
119:24
58:23,25
bleach
114:2,18
153:3
149:16
126:16
129:15
115:15
brain
bills
131:14
Boca
82:18
behavior
95:2,10
7:24
blocked
117:17
Brand
116:19,21
62:15
122:2
body
55:9
bio-
126:10
83:11
behold
breach
effective
152:16
124:19
blows
5:3
16:10
96:11
bonding
belligerent
breaching
bird
24:9
96:22
blue
114:16
57:10,12
58:6
book
belonging
59:16
break
83:17
83:3
board
46:4
28:25
52:21
benefit
136:6
47:25
61:15
88:15
48:1,5
144:20
106:24
birds
126:2,5
15:8
125:8,11
131:21
breeze
Bennett's
127:3,25
20:2025:18
51:4
birth
142:25
Booze
Bermuda
8:14
144:14
126:16
51:25
16:11
boards
boring
bring
birthday
127:23
52:17
166
52:6,7,9,
24:16
10,11,24
82:3
boat
boas
89:24
bicycle
bit
82:23
98:9
95:20
11:1
5:11 6:7
83:21
123:6
bothersome
131:24
45:6
84:1,4,
110:8
bringing
bicycles
46:22
17,22
22;23
85:22
47:3,18
85:5,6,7,
bottom
137:16
48:14
9,10,13
98:23
big
52:16
86:7,12
133:24
brings
9:6 15:18
129:20
93:23
bought
145:22
20:17
144:24
103:20
9:1,2
broader
22:23
bitching
104:3,6,
11:25
146:25
37:5
111:15
11,14,16,
32;6 46:4
49:13
19,23
broke
68:25
59:1
black
105:2,8,13:5
126:1,9
108:12
18:20
12 133:18
108:14
bigger
26:16
138:24
bound
141:23
13:15
78:19
boaters
63:16
broken
bikes
138:6
83.4
Boy's
24:9,10
131:25
blades
93:11
59:19,21
136:7
boats
60:2 73:1
bill
83:5
Boynton
Bo Yn
108:17
4:16
blame
104:12
7:7 41:16
125:23
96:3
83:3
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: brother -case
brother
burden
29:19
141:23
carpentry
12:13
106:23
30:20,21
11:18
camera
13:7
burglaries
33:4
97:4,14
carpet
brought
134:1
35:13
137:3
11:8
37:13
10:15
24:24
bushes
38:16
campaign
11:17
128:21
56:24
51:7
89:10
109:10
129:10
business
75:14
143:4
bucket
6:1,20
80:7
canal
carrier
69:14
23:12
82:3,19
58:24
23:18
bucks
62:20
93:9
carrying
28:21
145:14
103: 15
cane
104:4,21
150:10
104:17
129:15
budget
121:8canvas
Carter
108:25
bust
133:13,14
123:22
85:16
bugging
138:15
143:5
112:17
cartoons
113:6
busting
called
canvassed
124:18
building
138:6
5:15,16
79:5
132:21
11:25
butts
21:9
carts
13:9,15
65:11
23:13
capable
26:1
24:12
24:11
93.9
buy
29:19
146:11
carved
27:10
40:15,18
75:4
35:15
capture
14:14
42:19
107:10,17
43:9
136:13
carving
43:8
126:8
50:10
23:24
54:17
128:3
67:10
car
83:2,3
27:18
case
30:25
4:25 5:1,
20
1 :20
120:2
C
100:7
32:23
2 17:13
125:23
101:21
89:22
40:22
126:8,19
cabinets
104:13,18
98:3,5
43:10
122.23
buildings
11:6 22:2
141:4
65:19
130:7
5:20
41:1
86:18
136:7
care
129:11
87:3 94:1
built
143:7
12:1
10:22
cable
144:13
82:20
95:21
137:17
22:7
calling
117:16
115:20
bunch
calculation
29:6
129:25
116:6
137:18
60:2
s
44:7,22
117:24
149:5
111:12
63:10
46:14
120:1
152:18
119:12
66:1,13
81:6
125:18
141:4
70:20
careful
133:13
cam
bundle
71:3 73:6
137.9
65:13
149:9,19,
135:16
110:12
25
108:13
camel's
150:15,
call
Carolina
Bundles
108:10,
16,24
6:10 18:2
7.8
26:5
15,17
151:9
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: cases -clean
cases
certificati
character
119:25
civics
86:14
on
28:5
Christ
93:11
94:1
64:6
50:14
102:19
claim
150:7,9
certified
charge
9:19
Christian
catch
45:24
6:22
92:10
148:21
69:14
46:6
40:10
94:7,12,
Christies
21 95:20
catch-all
.63:15
charter
68:9
13:16
113:3,7,
92:14
122:9,12,
132:16
certify
15,17,22,
Christmas
10 115:19
87:11
23 123:7
81:14,15,
116:11
caused
117:10
lg
117:23
47:13
cheating
119:1
48:16
certiorari
117:3
Christopher
124:3
53:9
51:18
check
4:14
144:25
131:25
62:4 67:9
24:14
chronologic
148:9
141:25
68:1
al
claiming
checking
causing
chain
51:14
44:6,12
145:5
65:21
97.24
56:17
48:4 92:2
caution
challenge
checks
circle
115:17
73:19
67:25
7.23
119:23
116:13
131:16
challenged
chief
circuit
118:3
cavities
67:20
29:18
41:23
claims
16:9
48:18
62:2
95:16
change
a
49:1
151:15
cedar
40:25
citations
128:21
45:8
Childers
101:2
clarified
55:19
8:2
122:18
ceiling
cite
20:17
56:1
children
74:1
clarify
Y
130:7
71:12
8.7'8
88:16
72:5
17:10,13,
cited
115:22
131:4
127:9
16 18:6
58:14
128:15
ceilings
149:1
chipped
59:5
130:8
73:25
clarifying
changed
22:3
76:2,18
144:24
cell
52:21
choice
77:25
class
23:13
55:21
65:9,23
138:17
93:11
center
93:7 94:3
149:22
98:1
95:4
city
classic
Chopping
13:8 26:1
124:18
century
changing
25:11
40:10,14
95:2
41:12
119:6
Claus
channel
chris
127:20
81:15,21
cerebral
4:6,12
112:19
105:7
95:25
138:11
clay
138:25
99:10
Civic
10:24
certificate
139:7
70:23
101:20
122:13
clean
117:4
10:10
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. corn
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: cleaned.. committing
22:18,19
club
66:2,23,
college
14:4,5
126:1,5
125:9
24 67:6
147:14
46:2,7
cleaned
clue
68:8,11,
colluding
47:16,23
129:10,11
31:4
12,20
91:20
54:20
69:3
62:1 71:9
cleaning
co-
71:7,8,9,
color
74:19
10:12
defendants
10,12
112:18
90:5,6
cleanly
150:2,5
76:14
columns
91:4
105:1
coast
77:20
53:25
119:8
84:2
78:6
121:5
clear
80:9,13
combination
122:21
25:6
Coastal
99:23
136:8
125:6
45:20
89:11
101:9
combined
127:12,
74:18
93:19
122:1813,14
142:17
144:5
99:21
124:1
133:10
150:22
107:16
126:15,
comfort
144:9,17
151:12,18
139:7
23,25
107:4
cleared
140:14commission,
131:21
comfortable
35:5
coats
134:25
114:3
s
47:24
clerk
11:7
135:3,6
commemorate
48:4
146:20,21
39:18
cobbled
15:10
commissione
43:25
149:20
codes
commemorati
r
80:20
cockroaches
99:24
vs
46:21
123:1
128:21
Coe
15:9
71:5 74:7
143:8
58:23
125:8
click
cocktail
59:1
comment
126:3
111:14
28:4 86:3
97:14,15
coffee
134:11,
127:20
clients
code
24:8
12,17,20
commissione
13:13,14
45:16,20
107:17
144:16
ra
46:2,4
50:6,8
clock
51:20,22
cognizant
commented
79:14
52:6,8,
90:25
59:1
74:24
90:7
close
10,21
Cohen
138:25
14:5
53:24
117:17,22
139:1,2
commissions
92:14
55:11,19,
152:18
comments
108:25
21,22,24
86:2
111:23
closed
56:1,4,14
Coincidenta
110:2
committed
10:4
57:5,9
lly
114:21
146:13
34:1,341:21
58:8,11,
closely
12,14,19
colla
collapses
P
133:11
138:23
committee
45:3
59:8,17
146:8
143:20
122:7
60:4,9,10
123:2
clothes
61:11,13,
collect
commercial
143:4
17:19
16,25
123:3
7:10 43:8
committing
18:4,6
64:10,11
144:2
commission
91:10
65:1
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: common.. contacting
common
complaint
concern
85:18
51:25
119:12
44:18
82:21
89:5
79:24
150:14
47:1
138:1
91:16
149:6
communicate
49:21,22,
148:2
92:18
conspiracy
d
23 71:23
concerned
94:13,25
104:6,10
76:11
72:2,8,15
9:14,16
96:6
148:9
84:20
106:14
83:25
91:18
18:14,16
113:8
constitutio
communicati
113:16
49.17
153:10
n
ng
126:13
72:4
94:1
135:11
conducted
74:17
149:18
148:10
129:22
constitutio
communicati
151:1
nally
on
complaints
concerns
conference
150:17
152:21
152:2,3
84:3
153:9
constraints
communicaticoncluded
complete
confess
123:10
153:20
50:20
ons
61:11
construct
83:22
conclusion
confidence
completely
15:25
84:6,8,16
31:17
96:12
96:16,18
57:11
44:14
constructed
93:7,13
confidentia
55:10
community
94:3,6
45:14
1
57:17
109:22
80:3
115:1
constructio
63:21
126:24
conclusory
confidentia
n
companies
148:6
119:15
lity
12:17,20
18:12
147:9
compliance
concrete
114:17
22.17
company
60:12
45:7
confirm
35:6
5:15,16
61:1
59:20,23,
63:1
42:8,10,
24,25
6:12 14:8
comply
70:20
17 53:17
60:2
18:24
52:12
conforming
57:2565:2,5,14
34:24,25
66:5,20
126:22
111:22
118:10
108:3
71:19
128:16
72`5'7
confused
compass
compound
condition
51:17
consultant
121:1
11:3
52:5
60:21,22
complain
computer
115:18
conscious
consulted
47:1
85:24
93:25
124:2
conditioner
142:25
107:2
41:10
consequence
consumed
complained
145:6
130:16
s
107:2
42:13
89:18
concentrate
conditionin
84:23
contact
126:10
d
g
100:15
132:12
complaining
13:15
41:1
considerati
contacted
89:17
concept
63:11
on
72:3
108:16
143:6
16:7
93:10
conduct
54:25
contacting
47:12
considered
123:8
ESQUIRE 800.211.DEPO (33 76)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: container -cypress
container
convince
122:24
crackpot
criticisms
22:23,25
137:25
143:3,7
132:24
85:25
23:1
cool
144:4
crawl
criticize
content
148:25
county's
130:20
85:24
117:9
16:5
132:18
copies
crazy
continued
132:14
couple
66:5
cross
12:12
17:3,15
67:16
co
create
26:23
132:1
25:5,7
128:11
59:21
28:14
92:24
130:19
crossbar
copyrights
128'9
contract
14:15
136:2
created
19:11
5:3
143:7,22,
127:4
crossed
corner
contractor
20:6
24 152:12
130:22
126:7
12:3 22:7
133:4
correct
court
crowd
contracts
4:3 5:2
creation
47:4
31:24
62:19
53:11
8:19 62:2
56:4
48:12
contradicts
116:9
66:8,14
creative
crummy
d
123:9
67:8,17
118:18
128:25
134:3
131:13
69:22,24
141:20
110:21
crew
Cuban
contributed
11:17
11:16
110:4
Corrupt
courts
23:12
142:20
111:3
67:22
26:15
current
102:25
69:8
control
coat
crickets
59:23
62:9
cove
147:21
curtains
60:1
83:8,9,
111:2
costing
10,15,20,
crime
custodian
conversatio
42:23
25 84:9,
91:11
80:21
n
costs
11,17,23
107:12,19
40:3
23:1
85:1
109:6,7
cut
103:8,13
138:20,21
119:19
14:9 84:4
106:4
counseling
148:18,24
103:4,9,
110:9
117:20
cover
14 105:15
121:22
124:4
22:14
criminal
145:25
151:25
65:11
148:14
counted
149:2
cuts
152:1
141:9
covered
91:6
42:1
criteria
conversatio
country
45:17
cutting
ns
6:9
covering
64:13
85:22
44:1 72:6
critical
110:24
county
85:15
cycle
111:15
6:14 7:7
coves
132:22
123:13
121:2,12,
40:10,23
83:18
133:1
15
42:11
crack
cypress
criticism
128:21
convey
63:23
59:24,25
85:23
83:16
149:10
125:10
ESQUIRE Esqu�eSol to800. 211. DEPOn)
s.com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
Index:
June 18, 2015
D-o-n-I-o-n..denial
18:5
8:18
decision
defense
D
30:3,16
10:16
45:21
68:7,10
97:6
76:8
47:24
defenses
D -o -n -1 -o -n
121:20
104:5,10,
48:5,8
93:10
123:11
21
67:20
61:21
139:15
69:18,23
deficits
d/b/a
dead
71:20
152:22
dated
24:21
6:25
11:1,6
26:16
72:12
definition
Dade
77:23
76:24
daughter
deal
63:23
92:22
18:24
decision-
delineated
daily
93:3
76:17
making
62:15
61:2
149:3
117:5
77:7
deliver
108:18
daughter's
126:13
decisions
39:9
Dale
148:20
dealing
46:5
104:11
119:5
105:23
62:20
110:22
David
damage
4:16
debilitatin
deck
delivered
39:21
92:16
g
19:16
35:17
93:18
94:21,24
145:24
decks
84:22
115:18
95:21,23
147:20
12:15
103:20
129:23
96:19
137:4,10
Debit
decor
136:6
98:15
70:19,23
57:11
delivering
145:13
109:12,24
37:18
damaged
113:8
DEBORAH
decorations
104:2
106:13
day
4:2
81:24
82:1
delivery
damages
9:23
debris
138:17
37:8
106:12
13:11
26:5
39:12
15:14
130:14,24
decorative
111:19
22`19
79:14,18
Delray
113:10,11
December
115:4,19,
23:10,21
47:21,22
deducing
15:11
23 135:24
24:6,13,
102:8
40:10,14,
23,24
decide
22 41:16
damn
27:21
61:1 67:5
deducting
43:18,25
69:11
30:2,12
68:12
102:7
82:24
124:21
35:21,23
70:9
deep
120:21
dance
38:3,4
116:15
21:15
demand
133:6
44:3,13
decided
113:12
69:11
13:6,21
deeper
136:15
dangerous
82:4
146:25
129:14
90:3,13,
20:19
73:18
defend
demeanor
dash
16 105:10
78:10,21
59:14
28:9
40:5
131:12
111:11
148:16
democracy
137:9
141:5
93:10
deciding
defendant's
144:15
141:18
date
52:13
139:12
16:11
days
denial
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: denied..disputes
46:13
des
determinati
64:20,23
47:21
47:19
74:1,5
on
dimensional
122:15
51:11
76:4,7,23
52:13
123:7
74:10
53:4
77:19
54:19
133:21,22
69:25
79:8,9,
DIRECT
137:23
determine
denied
11,25
135:3
4.9
discussions
51:18
80:6
directed
48:17
138:16
determined
67:12,14,
86:7 96:5
55:3
52:4 56:5
15,23
describe
72;8
direction
92:20
68:1
15:4
104:16
58:7
102:24
96:21,23
18:19
141:8
67:17
106:8
100:20
19:12
117:22
101:1
119:4
devastating
directly
135:1
150:17
122:10
96:8
10:1 33:5
disgusting
den y
142:3,8
149:8
disagree
48:5 53:8
describing
develop
42.20
141:5,17
92:15
146:4
135:22
denying
dismiss
47:13
desert
developed
disagreed
142:10
107:5
58:25
78:5,23,
149:23
department
25
6:14,18
design
development
151:14
63:16
13:22
27:16
disagrees
dismissed
109:18
56:4,7
104:1
135:19
60:6
137:2
58:1 59:9
Dhabi
disconcerti
61:10
Depends
P
73:17
14:17
n4
dispasaiona
6:4
76:4
108:24
to
diameter
deploy
designated
79:12
discover
116:20
6:19
83:17
dictates
128:18
dispatch
depo
Designs
52:7
discoverabl
103:25
77.3
5:15,17
died
a
display
7:1 14:11
87:9
74:22
deposed
118:11
6:17
4:23,25
11:24
discovery
81:4
5:1,2
destroy
99:1
89:15
152:10
difficult
128:15
displayed
deposition
13:6
4:2,14,17
destroying
118:1
discrepancy
75:24
17:7
91:6
56:2
85:13
dig
133:18
153:20
destroys
52:15
discussed
depositions
96:12
5:7
displaying
4:22
detail
digital
139:21
85:18
133:19
70:18
11:14
discussing
dispute
88:3
detailed
dilemma
152:4
75:16
152:8
42:6116:14dis
56:12
discussion
disputes
P
46:21
125:2
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: disqualify -easier
disqualify
37:21
25:13
97:3
120:25
4:24
42:8 66:4
37:5 41:1
dropped
dissect
118:1
52:9
15:14
E
50:1
137:6,10
doorway
39:12
149:21
21:17
43:17
distance
e-mail
documentati
141:8,9
dot
drove
41:21
distinction
on
102:14
6:4 67:16
79:7,22
56:20
148:16
dotted
97:9,10,
57:14
documents
12,14,15
97:6
distress
63:9 82:6
126.7
98:8
99:14
92:11,17
101:16
Doubt
137:8
drywall
ryw
94:8
105:5
dogs
19:3
e-mailed
95:17
79:15
doubts
22:3,13
56:18,19
115:12
85:22
72:25
25:11
116:12
e-mails
141:25
dollars
downturn
38:13
121:11
142:18
15:16
6:7
39:22
42:5,6
E -x -c -e-1-
144:25
domiciled
dozen
128:23,24
s -a
disturbing
18:4
5:25
129:3,18
58:22
109:9
Donlon
140.9
130:4,22
ear
110:3
61:21,22,
draw
due
145:13
diver
23
64:15
76:21,22
147:14
15:10
Donna
drawings
81:7
152:25
divers
61:21
63:10
dug
earful
16:4,6
dont'
133:17
76:3
120:10
divide
41:20
dread
duly
earlier
21:25
140:22
4:7
13:14
door
113:11
14:5 18:4
dressed
dumb
36:24
divorce
20:12
74:11
107:13
84:19
106:18,19
35:16
drifted
dumpster
early
divulge
36:4,5,6,
105:8
23:4
12:1,10
8,15 37:2
115:1
45:11
drips
p
duplexes
ears
divulging
51:6,23,
69:15
7:10
5:11
145:10
115:9
24 52:1,
drive
duration
153:12
doctor
4,14,20
27:3
117.8
152:25
53:15
,
83:10
146:12
Earth
153:11
60:12,17
125:23
61:3
doctors
73:23
driveway
duress
78:7
easement
152:16
98:16
59:20,21,
33:18,21
153:8
doors
22
dusting
easier
11:4,5,14
80:9
28:17
documentdriving
21:18
30:24
duties
O ESQUIRE
800.211.DEPO
(33 76)
Esquire Sol utions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
east
19:15,23
20:4
Economist
118:25
effect
28:2
31:19
38:2 49:6
52:25
55:12
57:15
84:24
91:14
95:10
142:8
effective
16:9
effort
23:9
62:15
122:5
efforts
23:6
146:6
egregious
90:2
egress
83:13
elaborating
144:24
elderly
90:4
125:12
elected
89:7
125:6
126:4
127:22,23
election
123:11,13
140:23.24
141:2,5
142:25
143:4,19,
21,25
144:14
elections
14 1: 7
electrical
11:6,20,
23 41:13,
14,15
129:3,4
136:15
electricity
136:11,16
elephant
119:9
else 'a
64:1 79:5
eluding
25:7
embarrassin
9
90:10,16
107:9
emotional
92:11,17
94:8
95:16
113:15,21
115:4,12,
18,19,23
116:2,7,
12,13,17,
18 142:18
144:25
emotionally
118:19
employ
123:24
employed
5:12
employee
95:20
98:19
102:15
106:3,7
employees
5:24
employees/
officials
120:14
employer
65:16
118:8
employment
138:11
empty
124:16
encourage
110:18
end
21:2,23
24:13
107:5
127:10
ended
42:23
energy
101:13
enforce
71:10
enforcement
56:13
57:9
58:8,11
76:14
77:20
78:6
99:24
101:9
103:18
124:1
June 18, 2015
Index: east -equation
enforcing
54:8
engage
124:24
engaged
47:12
48:7,15
54:23
92:18
94:13
121:22
engineer
15:18
45:13,18,
24 46:10,
11 62:25
63:16,18
64:23
65:7,10,
14,22
70:24
71:21
135:5,9,
11,13,17,
19,22,23,
25
engineer's
45:14
46:12
63:15
64:4
70:15
engineering
15:19
63:9,21
engineers
63:10,11
65:11
119:20
135:20,22
engines
147:20
English
24:9 73:1
101:23
ENT
153:2
entered
112:7
entering
130:2
131:7
entertainme
nt
133:15
entire
19:19
33:16
34:2 70:7
108:8
130:6
entities
91:20
entitled
16:21
87:8
100:2
115:5,20
135:2,6
150:18
entry
36:3
111:20
envelope
35:17
37:18
Environment
al
6:14,19
equal
54:7
equate
66:12
equation
I ESQUIRE 800.211.DEPO (3376)
< < EsquireSolutions.com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
65:13
equipment
41:11
err
73:19
131:15
errand
30:25
essentially
64:6
108:7
established
56:8
estate
7:4,5,6
12:12
62:19
estimate
25:4
42:17
65:12
estuary
83:4
evaluated
118:6
events
105:10
142:4
145:23
eventually
30:20
35:4 37:4
45:13
70:13
76:13
85:9 98:6
106:22
123:6
130:4
Everybody's
82:21
evidence
61:6
98:18,25
99:6,8,13
114:20
evident
84:4
evidently
130:12
ex -manager
119:6
exact
49:2 97:6
139:6
exam
12:18
147:15
4:9
128:11
152:13
examine
99:1
examined
4:7
examining
135:15
Excelsa
58:21
exclude
72:17
exclusive
53:15
Excuse
65:11
69:11
excused
153:19
exempt
101:13
136:18
exemption
9:15,19
18:10
45:17
exhausted
112:22
exhibit
19:14
32:25
74:22
139:12
exhibition
74:22
exist
13:1
61:12
66:20
80:21
existed
68:25
72:18,19,
20
existing
35:19
41:23
55:8
expect
95:3
146:15
expediency
150:16,18
expenses
62:7
89:12
expensive
61:20
experience
11:22
12:7,17
40:21
June 18, 2015
Index: equipment -faces
58:2
72:22
73:2
102:24,25
118:19
132:10
experienced
135:20
expert
61:17
118:22,24
experts
61:14
62:7
explain
10:19
24:9
78:3,14
explained
78:5
127:7
explaining
90:11
explanation
45:13
exploratory
42:13
expose
111:17
exposing
56:12
express
134:15
expressed
140:14
extensive
18:17
39:20
42:14
52:8
129:2
131:14,15
extensively
124:2
extent
115:14
129:23
exterior
12:16
extra
125:15
eye
79:18
eyes
87:18
F
fabricate
63:19
96:9
fabricating
102:6,7
fabrication
61:11
102:9
face
34:4
56:13
64:14
79:12
81:18
84:23
103:22
104:20
107:4,6
133:6
149:24
faces
74:24
133:8
eE+ ESQUIR800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: facility -find
facility
129:8
feeling
24 53:18,
fill
14:7
131:11
100:16
21 54:12
42:15,16
facing
148:9
102:11
55:7,8,12
60:3
19:15
family9s
107:6
fences
122:25
43:6
109:16
53:16
123:8
fact
feelings
56:10
filled
23:6 38:5
fan
46:3 55:2
20:17
103:12,13
fiasco
.10:7
67:20
106:20
15:19
43:19
father
68:3,4
fees
90:7
filling
11:24
71:3 73:4
87:7
146:13
42:7
43:1
74:13
106:24
115:7
fictitious
film
75:16
116:24
124.7
96:7
136:8
79:22
150:19
80:8
148:23
99:24
films
81:12
favorable
feet
field
136:10
9:8 14:10
95:8
133:11
20:11
59:25
filthy
109:17
fax
21:15,19
Fife
10:10
116:11
39:10
53:19,23,
27:24
25:16
137:16
fear
24 54:2,
28:5
final
fails
79:1
12 96:4
29:22
57:22
65:18,20
105:9
44:22
58:2
fears
131:13
46:15
fair
106:22
50:24
finally
28:15
federal
fall
51:3,8
78:24
22:14
60:10
60:10
80:11
4:15 5:1,
fight
89:4
19 43:8
fellow
61:9
70:3,6
6:17
107:1
107:15
112:21
fake
115:3
11:15
finance
128:21
124:2
15:10
fighting
147:5
57:10
137:24
fall
fee
63:20,21
financials
131:25
27:2
117:17
figure
143:3
136:12
28:20
37:10
felt
65:4
financing
fallen
42:9 87:2
6:15
17:18
file
147:6
feel
48:20
49:20
find
familiar
44:19
97:10,11
55:4 84:3
10:16
7:24
88:4
105:6
131:24
14:22
67:16
93:7,9
107:24
18:22
family
100:15
110:5,18
filed
25:2 29:3
18:12
108:2
116:25
4:15
90 12
49:17
114:2
145:25
51:18
107:4
65:7
115:23
146:10
105:4
130:8
118:20
150:19
70:17
fence
132:25
102:13,25
119:13
19:19,22
filigree
139:8
151:8
114:11
33:9,10,
79:16
153:7
D ESQUIRE
800.211.DEPO
(3376)
9
0 l U T 10 H S
Esquire Solutions.com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
finding
131:14
fine
11:10
15:24
16:17
18:9
fines
61:2
103:22
104:20
finesses
96:1
finger
107:18
finials
79:14
finish
11:14
36:7 51:2
68:17
112:3
firefighter
s
6:15
firm
150:3,8
12
firms
12:18
first-hand
50:3
fish
16:4
103:21
104:17,18
119:8
Fishing
103:23
fishy
46:12
fist
49:10
fists
98:2
fixing
12:5
fixture
41:18,19
Flaco
20:15,16
flag
82:2
flat
19:16
20:21
45:2
72:5,7
126:11
flee
88:1
flimsy
64:8,9
flip
49:7,9
flipped
49:13
flipping
57:10,12
59:15
133:21
floor
22:4
flooring
10:24
floors
11:2,3
Florida
4:4 12:10
67:7,22
103:21,23
115:3
144:13
Flowers
15:8
fluid
108:1
flush
34:4
focus
16:5
112:15,19
145:17
146:22
149:25
Focused
146:23
fog
147:22
folks
107:20
follow
47:3
70:14
follow-up
60:14
128:9
151:4
food
35:6
foot
14:7
19:18
22:14
33:10
53:17
55:7 65:4
79:12
85:13
141:17
footer
85:10
footprint
10:25
force
112:2
foreman
45:5
forest
46:17
forget
33:3
forgot
67:15
forgotten
141:13
form
42:15,16
57:18
66:7,16
70:5
72:11
76:19
87:4
98:8,21
99:18
100:21
102:1
112:9
122:5,25
140:12
143:16
formal
8:19
forms
40:11
43:18,19
121:7
fortune
106:15
forward
97:19
120:4
123:12
June 18, 2015
Index: finding -free
144:11
forwarded
134:18
found
14:1 37:4
45:16
51:19,20
52:22
56:18
58:7,19
59:6,11,
12 60:3
61:24
71:18
122:23,24
125:23
126:9
129:1
130:25
131:12
134:1
137:7
foundation
16:3
119:7
founded
15:10
Fourth
113:3
FPL
132:13
Frances
4:12
Frankenthal
e
112:17
freaked
36:6
free
87:21,23
124:19
jESQUIRE Esqui 1.DEP0 (33orn
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
freeze
148:15
freezes
15:6
frequency
117:7
frequented
137:18
frequently
83:5
140:13
Friday
36:5
fridge
7:23
friend
11:15
89:21
124:6
150:7
friendly
109:8
friends
119:20
120:8
126:4
127:4
148:17,20
frightening
106:2
Fritz
70:19
frivolous
91:13
126:25
front
19:8 20:8
21:13
60:7,11,
12,17
61:17
92:24
101:10
107:1
fruit
79:14
fruition
86:15
frustration
56:12
Ft
8:6 12:22
148:11
full
147:21
fun
112:14,24
133:12
138:12
functions
120:6
funny
20:16
22:12,15
81:20
130:11
133:11
141:12
148:25
furniture
26:7
146:5
future
79:1
fuzzy
18:20
G
gaggle
74:25
Gail
52:2
gain
36:3
Gambino
148:19
game
60:23
110:25
111:11
garage
9:8 14:6
21:6 36:5
51:6,23
52:1,4,20
53:4
73:23
garbage
22:23
garden
115:12
116:10
125:9
gash
20:17
gate
34:6,7,8,
9,11
53:19,21,
25
gates
34:3,12
gave
12:7
46:23
75:1
123:21
gazebos
12:15
GC
12:18
geared
16:4
Gee
88:22
general
12:3,17
152:18
generous
6:5
gentleman
36:3
geometric
15:9
get all
19:4
22:10
get along
29:16
46:25
giant
22:17
49:25
Ginsberg
4:16 18:5
21:13,16
22:18
25:23
26:10,18,
22 27:6
30:13
34:9,10
35:2,24,
25 36:1,3
44:6,24
46:14
49:24
50:7,11,
12 51:5,
7,10
53:18
92:16,17
94:8,9,
17,19,21,
June 18, 2015
Index: freeze -give
24 95:12,
21,23
96:2,19,
20 97:2
98:15
108:7
109:12,24
110:4
112:6
124:13
131:7
134:5,9
135:17
137:13
14 1: 24
142:16
147:13
Ginsberg -s
55:4 93:6
96:4
113:8
130:2
13 1: 23
girl
107:11
gist
49:4
give
4:21 12:8
16:14
29:19
45:18
47:2 68:9
70:3,7
101:16
107:20
109:24
111:12,
16,17
120:3
121:20
140:7
141:19
153:13
C)ESQUIRE 800.211.DEPO (3376)
. EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: giving..Hamori
giving
132:13
22:14
82:25
Is
42:16
grabbed
group
83:17
50:14
114:17
122:13
105:2
125:19
guys
glared
128:1,3
15:16
grabbing
Grove
132:7
98:10
26:20,21
141:11
5:15,17
137:1
28:14
glass
graduated
6:25
139:19
29;19
21:18
118:11,13
140:4
12.17
31:20
God
growing
141: 21
32;7
grandfather
148:22
15:22
ed
102:25
34:17
98:13
55:11
Guam
Gullible
35:3 37:3
125:24
14:16
107:14
87:24
grandkids
88:2
goings
125:15
guess
gun
106:16
139:20
26`19
98:12
109:2
golf
granted
27:3 29:1
100:23
130:18
55:10
104:15
38:14
Gundlach
151:16
110:23
graphic
53:12
11:13
golfers
74:10
54:17
23:13
75:14
56:20
30:22
H
79:23
76:25
61:3
31:1,18
Gonzalez
gratifying
76:21
32:10
H -a -m -o -r -i
34:23
15:3
86:3
36:18,19,
102:21
good
92:22
22 96:10
habitable
great
98:8
4:13
21:8,18,
104:15
Gundlach's
129:11
11:14
20,2317:7
119:22
half
28:9
22:1,2321:11
120:9
6:4 9:7,
42:19
25:20
137:17
gut
11 15:16
51:16
86:2
109:2,3
139:1
71:16
17:7 32:4
89:21
116:12
141:8
60:23
130:7guy
142:13
124:14
92;25
136:16
2016
:
130:3
111:22
140:22
guessing
34:14
131:8
good-bye
148:24
60:23
39:2 45:4
140:9
148:13
guideline
49:13
Gregory
51:4
hall
Google
g
12:13
59:7,10
63:24
31:15,16
61:3
grew
guidelines
68:20
38:20
Gosh
14:6
59:10
78:15
121:21
73:22
Gulf
86:2 98:3
141:6
Grinch
100:7
government
81:22
7:6,12
101:22
Halloween
5:19,20
9:21
133:7
gripes
35:22
114:16
93:16
60:8115:25
50:2 52:7
Hamori
119:13
149:2
102:19,
120:9
g round
68:22
20,22
79:21
ESQUIRE Esquire o��ons.comJ
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: Hamori's..hey
110:6,10,
99:18
happy
145:4
heat
16 138:9
100:21
57:1,16
152:17
136:10,
Hamori's
101:4
74:23
heads
12,13,14
110:2
102:1
139:5
47:17
heater
112:9
harassment/
138:6,15
22:6
hand
114:24
retaliation
130:16
14:20
115:8,13
heads -up
, 39:9,11
117:4
109:18
75:2
heaters
65:2
128:9,12
hard
health
136:14
94:20
139:14
14:2
113:20
Heath
147:9
140:15
44:14
114:6
114:5,14
hand-
144:20,22
52:16
117:12
116:16
delivered
151:4,6,7
78:17
117:1
84:18
152:11
112:11,22
hear
153:17
harmed
7:17
heavier
handed-
96:19
72:5
delivered
happen
136:10
111:14
99:23
47:5 97:5
Harris
128:14
heavily
105:22
45:4 51:3
145:11
105:10
handing
123:10
96:11
147:22
heavy
130:18
128:17
119:7
45:7,15
handle
144:5
heard
65:2,22
37:2Harry
21:11,16
happened
73:12
36:9,10
heck
handles
13:5
40:10
63:22
7:22 36:4
22:19
hate
51:3
90:13
25:16
109:14
hands
31:12
89:19
height
96:21
haul
131:24
54:4
97:21
34:12
23:4
132:2,4
44:20
Hawaii
134:19
Helen
hang
49:16
112:17
31:8
51:25
15:2
hearing
76:1
111:23
46:7 50:9
hell
hanging
97:7,9
hazards
52:21
106:23
85:14
100:18,22
105:14
57:9
Helped
Hanna
105:5
58:9,16
20:20
16:15
109:23
he'll
60:10,13
57:18
119:25
61:17
61:19
helpful
66:7,16
134:2
head
65:10
132:25
70:5
135:25
30:6,18
124:1
heros
72:11
143:10,
48:12,13
135:1
111:1
76:19
11,20
73:24
hearings
hesitant
77:9
144:16
92:8
46:8
111:17
86:23
ha
happening
pp g
100:11
hears
hey
148:17
10 88:11,
17:25
140:20
80:8
13,15,20
102:16
headaches
145:21
119:24
124:15
107:8
98:21
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
hide
Hollywood
horrendous
23:6,9
12:22
22:21
13:8
147:1
high
58:23,24
humiliating
12:1
home
horse
48:14
12:16
74:11
high -five
24:3 35:2
hot
19,20
36:15
107:20
Hurricane
20:21
hips
96:22
97:21
98:2
hire
11:12
18:24
89:8
hired
11:13
hiring
127:6
history
16:18
111:7
hitting
79:23
hold
103:14
104:5
141:13
holding
97:14
141:14
holdings
7:6 140:4
hole
78:16
holiday
81:14,24
138:17
holidays
82:1
56:23
74:22
93:25
94:2
110:17
111:20
112:7
145:22
153:6
homeowners
27:15
56:20
83:19
homes
7:9,11,15
13:15
83:12
homestead
9:15,17,
19 10:5
18:10
Homesteaded
9:22
homesteadin
4
17:20
homework
68:17
honor
107:21
hope
49:16
hoping
70:6
129:20
ESQUIRE
25:17
hour
17:8
87:15
88:20
hourly
88:10,19
hours
4:23
35:16
89:3
92:24
108:21
house
9:6,19
10:22
17:4,5,6,
14 18:11,
22 19:6,
10,12,17,
22 20:3,
4,11
21:3,5,7
22:8
23:13
24:19
26:8
3 0: 23
34:4 35:8
36:18
39:18
42:12
43:2,4
46:4,23
51:4,25
52:5,10,
21,23
June 18, 2015
Index: hide.. illustration
53:17,20,
105:2
22 55:14
hullabaloo
56:6
127:4
57:23
58:23,24
humiliating
59:4
90:9
60:16,25
149:8
61:4
hundreds
62:10
101:16,
65:20
19,20
74:1
79:15
Hurricane
91:25
69:13
92:24
hurt
94:10
24:17
95:4
26:18
97:2,16,
19,23
husband
102:23
139:2
108:22
112:1
1
124:18
128:16,
I s
19,22
126:7
129:6
130:2
idea
131:3,7,
13:25
10 135:5,
14:2
10,14
105:19
138:21
122:16
140:6
123:21
141:24
identificat
147:2,5,
ion
7,8
139:13
151:24
identify
houses
40:5
33:14
56:9
ignore
72:22
36:10
37:3
huffed
28;8
illegal
113:7
hulk
134:5,12
49:15
illustratio
hull
n
104:16
800.211.DEPO (3376)
Esquire Solutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: illustrations -intellectual
75:14
12:16
111:19
100:5
inspection
illustratic
inappropria
incurred
114:17
40:18
ns
to
62:7
115:1
63:13
74:11
103:3
132:11,
inspections
independent
13,24
77.1
inch
77:23
135:4,8
63:12
images
10:24
indicating
informed
inspector
79:23
53:21,25
13:8
99:15
106:8
54:12
41:15,16
imagine
128:25
indirectly
initial
63:14
15:12
19:10
inches
140:2
134:24
inspiration
33:25
53:23
indiscretio
initiating
124:22
43:7
54:1,2,3
n
96:4
inspired
91:14
29;25
incident
initiative
124:8
118:6
50:13
22:13
123:4
immediately
30:12
individual
install
inlet
136:17
9:13,15
31:11
142:24
10:6,15
36:25
individuall
6.17
82;24
instance
60:6
92:20
41:18
y
83:1,2,3,
124:20
95:7,11,
94:19,22
22 84:6
53:1
immigration
22 96:7,
110:16
13,15,25
individuals
Inlet/
125:14
133:22
87;22
109:25
boynton
instituted
immune
105:5
industrial
83:22
149:9
95:15
108:7,15
7:10 23:4
inquire
impact
109:24
107:10
35:13
instituting
28:24
131:24
91:10
134:2
inexpensive
inquiries
Instruct
impaired
141:24
11:4
27:7
87;4,10
119:14
142:16,17
infliction
143:11
instructed
impairment
incidents
92:11,16
insects
119:3
108:11
94:7,13
130:13
103:17
95:16
141:7
implication
117:24
inside
151:2
147:12,13
116:12
110:25
instructing
important
incised
influences
insinuated
88.9
27:7 43:1
93:4
insulation
71:1
27:23
inform
22:11
improper
inclined
insisted
26:5
108:20
137:19
29:14
45:15
130:10,12
132:23
110:1
122:4
included
information
insistence
insurance
56:10
135:13
147:3,4,
12:8
improved
income5,6,9
34:21
inspect
57:14
118:12,13
79:9
46:1,11
intellectua
improvement
incur
80:23
135:5
1
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
5:1
intellectua
lly
118:20
intended
10:11
intent
40:1
98:19
103:8
120:15
intention
45:1
intentional
92:10,16
94:7,12
95:16
110:6
116:12
intentional
ly
125:1
interacted
124:3
interaction
a
30:14
51:6
98:14
intercede
69:22
intercoasta
1
82:24
83:12
84:10
interest
148:5
interested
122:21
interesting
85:19
interests
5:16 7:2
interpretat
ion
66:23,24
67:1,5
interprets
71:8
interrupt
68:4
intimate
89:9
introduced
61:6 91:8
invade
137:19
invent
51:2
invented
99:25
invested
69:19
investigate
105:4
investigati
on
27:1
39:20
60:9
129:22
135:14
investment
92:22
investments
7:4
invited
90:3
involved
119:19
145:9,13
150:13
Irene
69:13
Irish
133:6
ironic
79:17
irrelevant
115:19
IRS
66:17
Island
83:3
isolating
141:23
issue
45:12
62:24
77:20
108:6
115:4
121:6
124:12
125:4,5
144:23
145:18
146:2
issued
101:2
issues
56:21
91:12
116:3
147:23
item
89:5
items
130:25
146:21
June 18, 2015
Index: intellectually -junk
J
Jackson
112:16
Jaguar
90:25
jail
126:17
Japan
48:11
jeopardy
116:22
146:6
Jesus
107:21
jet
147:20
jibjab
133:5
jig
133:6
Joan
70:18
9 0:2 0
job
11:25
28:25
29:3
30:18,21
39:3,4
106:1
127:7
jobs
118:14
John
11:13
123:22
join
47:3
joints
59:23
60:1,2
Jonathan
150:6
joy
93:24
111:21
148:3,4,5
judge
28:9
66:8,14
67:5
69:22
70:3,6
115:6
144:5
146:19,22
judges
110:23,24
judging
32:13
judgment
146:12
judicial
150:15,18
July
152:1
jumbled
89:2
jump
88:23
jumped
22:15
jumping
24:2
jungle
22:17
junk
26:7
ESQUIRE 800.211.DEPO (3376)
0 L U. I a h S EsquireSolutions.com
CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM Index: Jupiter -lawyer's
Jupiter
113:21
knowing
148:21
58:20
6:17
118:20
129:2
Lakeview
laughed
jurisdictio
119:19
131:15
83:10
86:4
n
128:20
knowledge
129.12
lame
laughing
60:5
10:23
141:21
114:12
90:7
15:19
147:15
31:23
land
laughs
K
'149:3
50:4
83:14,15
90:4
150:11
72.21
landscape
laundry
K -mart
kinds
89:9
12:3
21:6
13:16
79:17
119:12
13:13
Kelly
King
120:13
34:7,16
Laura
61:22,23
90:21,22
114:5,14
knowledgeab
56:22,23
kid
116:16
le
61:15,16
law
86:5 93:2
117:1,14
63:24
landscaper
94:1
95:19,25
kids
Kismet
26:15
115:3
18:3 43:1
34:13
L
landscaping
117:2
86:2,3
kiss
12:14
119:10
93:22
148:12
labeled
13:10
141:19
105:19
132:23
56:22
150:3,12
kitchen
106:24
19:7
136:19
57.4
lawn
108:3
60:21
21:8,9,
labor
34:25
109:19
14,21,24
6:22
Lane
60:7,11
148:25
22.2
7:19
61:18
kill
lack
101:10
knees
100:1
language
70:17
145:25
52:12
LAWRENCE
killing
ladder
101:23
4:2
knew
130:21
102:13
41:3,7,9
144:5,10
laws
kind
58:25
ladders
Lansky
57:21
11:1
68:25
130:18
148:19
lawsuit
15:3,21
69:17
ladies
Large
91:17
20:21
76:23
90:22
4:4
92:2
25:6
125:10
lady
94:21
26:7,24
131:3
larger
58:21,22
118:3
27:7 36:5
137:17
54:1
59:5,12
126:24
45:20
138:18
60:24
late
150:25
54:22
knock
90:18
12:11
60:22
37:2
101:11
56:5
lawsuits
64:13
91:19
70:8 73:6
knocked
laid
Lauderdale
lawyer
89:2 95:2
36:4
91:9
8:6 12:22
125:25
104:3
knocking
lake
148:12
108:1
36:9,10
83:10
laugh
lawyer's
110:18,20
136:13
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: lay -lobby
lay
lecture
76:6
93:4 94:2
literally
96:3
95:25
77:19
116:4
102:13
layered
led
78:4 81:3
lifetime
147:20
72:7
12:15
84:18,22
12:4
litigation
14:4 53:7
89:15,20
114:7
4:15
laying
Y g
99:14
92:4
72:21
117:13
62:5,21
125:19
104:7,10,
90:15
layman's
11 135:13
light
76:22
left
137:4,7
12:20
127:
127:2
12:10
139:10,
41:18,19
lead
26:9
16,18,21,
lighter
litigations
146:6
28:10
23 140:8
150:21
107:3
leaders
35:8,9
143:15
livable
109:10
37:4
144:17
lightweight
10:11
127:12,13
64:24
leak
130:14
letters
live
146:4
46:6
likes
8:22,23
legal
89:14
90:24
learn
17:19
99:20,22
limited
9:18 23:2
82:21
31:10
42:7,12
100:10,14
75:20
92:21
125:1
89:12
121:11
learned
107:15
139:25
limits
133:16
12:1
124:4
140:10,
129:21
lived
22:17legall
y
16,17
lines
8:25 9:21
35:25
10:7
level
64:15
17:5,13,
93:11
126:21
53:8
79:13
16
99:11
110:3
84:4
lives
122:11
legislature
101:24
16:24
136:22
93:12
levelling
104:24
lege
11:3
105:1
livid
learning
89:21
144:10
96:22
liability
lip
98:2
65:17,21
48:20
living
learns
9:20 14:2
35:25
length
liable
124:13
17:10
105:2
65:18
list
18:7,13
leave
letter
135:24
58:18,20
19:7 31:2
24:3,10,
31:4,
19:10
license
59:6,7,13
69:9
7,9,18,
7,
37:23,24
13:11
89:18
129:5,6,8
20,23
38:7,8,9,
63:20
101:16
130:6
35:4,10
10,15
lie
listen
147:10
37:3 98:7
39:2,9,11
96:9
65:9
load
43:17
leaves45:24
life
listened
65:7,8
35:3
63:15,25
29:23
91:4
lobby
79:16
64:2,4
49:989:16
listens
leaving
67:2 68:9
52:15
122:14
139:11
97:23
71:22
82:21
152:7
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: local -manager
local
loss
lots
69:17
22 14:2
101:14
113:15,21
7:12 63:9
77:23
16:7,20
lock
116:13
85:22,23
80:18
17:19
141:10
losses
120:5
86:21,23
23:9
121:11
93:4 95:1
24:16
long
118:23
126:3
98:22
26:17
8:3,4,25
lost
104:22
44:2
loud
13:1,18
39:22
109:19
45:18
128:13
24:18
67:11
114:21
46:3 47:2
145:10
32:7
113:18
125:18
57:17
34:19
115:19
Louis
126:6,13
59:23
43:20
117:23
62:12
131:17,21
64:22
45:2
118:5,8,
lovely
134:17,20
67:24
46:21
13,14
17:3
137:8,10
69:22
80:11
121:23
142:14
72:12
115:10,11
126:13
low
143:20
79:17
127:1
lot
56:10
144:16
110:18
142:23
4:20 5:19
109:6,7
151:11,18
126:3
145:7
124:19
131:20
6:6 17:18
magistrate
147:15
20:6
lucky
59:15
138:23
long-
22:6,11,
8:15
60:4,15
151:14,16
lasting
15,16
lunch
61:2,24,
Makes
13:23
24:21
24:14,16
25
136:12
long-term
g-
26:8
32:6,7,8
mailed
making
149:3
28:15
35:3
89:20
23:6
51:19
36:2,7
25:21
longer
62:17
108:23
main
123:23
74:15
18:22
48:21
124:14
101:18,25
Lunn
19:7
52:15
146:10
102:11,
135:12
118:11
57:21
62:3
looked
12,14,24
maintaining
131:23
22:21
105:10
M
18:10
132:1
36:11,12,
107:4-
147:25
109:3
maintenance
22 57:13
111:10
M -a -y -e -r
12:13
148:16
68:12
114:2
117:19
34:8,16
malicious
72:23
73:1
116:22
mad
major
91:14
76:16
119`22
49:7,9
14:23
maliciously
98:7,25
125:10,17
126:12,13
21:8 56:4
91:13
99:9
127:16,22
made
138:1,21
136:21
130:10,14
man
132:12
27:17
majority
34:8
153:11
133:11
52:1
119:13
69:11
lose
137:23,24
53:20
make
86:4 93:1
67:8
146:9
54:8
5:7 6:13,
148:10
148:13
148:17
62:3,4,22
67:9
15 13:6,
manager
ESQUIRE
800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
Index:
June 18, 2015
manages -metal
48:18
marked
mayor
125:7
40:6 51:9
124:4
19:13
58:23
133:20,23
104:20
139:12
70:19
134:15,
109:24
manages
71:6 74:6
18,20,25
130:13
7:23
market
84:20
143:12,21
143:13
6:9 14:20
mandamus
85:16
151:20,22
152:5,21
68:6
marketed
89:7,13,
meetings
mess
14:21
16 90:20
maniac
47:16
22:20,21
51:5
marketing
91:5,13
74:19
14:1,3
99:22
93:17
message
manifestati
138:20
52'
ons
married
139:7,25
151:19
74:18
145:2
8:3,5
145:11
meets
75:7
147:11
114:11
149:17
48:13
139:19
manifested
Martin
mayor's
144:18
messages
152:15
124:5
79:15
member
110:23
132:3
149:6
manner
140:24
meaning
met
96:23
80:22
members
38:22
141:6,13
manual
150:3,7,
means
119:8
43:19:17
56:4,7
15,20
20:15
125:8
4150:2
59:9 76:4
455:19
Marty
56:10
151:23
47:6
manufacturi
52;4
60:7
117:7
ng
120:19
67:11,12
memorial
128:5
12:4
76:22
6:15,16
master
102:2
16:2
132:4
March
21:6
142:6
47:20
mechanical
memory
143:16
89:7
material
41:11
49:3
149:15
139:17
22`5
medallions
51:16
metal
140:1
60:23
103:7
61:9
5:18 15:6
134:21
15:9
marching
meet
45:9,10,
141:10
materials
men
11 46:10
6:22 72:6
24:8
20:15
63:1
marijuana
mathematics
26:10,11
43:16
mental
64:24
103:1
1
85:20
90:23
65:1,2
marines
66:1366:14
112:23
113:20
33:4
135:6
114:6
68:9
matter
70:4,13,
marital
25:2 38:5
meeting
115:18
15,16
117:21
46:2 57:9116:3
30:17
71:14,15
148:5
68:4
117:12
49:5
72:5,7,9
mark
71'4,7
74:21
mention
73:5,10,
139:9
79:22
90:5 91:4
72:15
12,13,14,
150:22
81:11
119:5
mentioned
15,16,19
153:14
107:5
121:5
20:25
134:23
123:17
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: metaphor.. movement
136:9,20,
142:14
mixture
month
mother
22,25
145:16
128:20
6:19 9:2
11:25
metaphor
minor
132:10
39:17
12:12
89:2
90:4,18,
141:22
50:13
moaning
52:5
111:15
months
19,21
Mexican
91:3
120:19
8:12,13,
10:24
mode
34:15
minute
29:17
19 17:15
mother's
25:5
90:23
62:4 98:6
Meyer
modeled
80:19
117:19,22
minutes
132:11
114:1
mothers
148:19
17:8
modified
143:22,24
8:14,17
152:18
32:3,5,9,
149:14
motion
10:23
Miami
24 35:2
152:5
4:23
132:15
mold
60:18
12:23
140:10
17:22
moor
13:15
82:23
motivated
18:17,21
Michelangel
mirror
19:5,6
83:5
98:19
98:7
99:16
0
22:14
moored
15:17,18
misapplicat
42:14
83:6,7,21
120:15
ion
43:2,7,10
motivations
microscope
61:12
128:15,
mooring
110:7
97:11
105:8
18,19,25
120:21
Mid
misappropri
129:1,12,
moral
135:21
ation
26:13
14,16,20
120:25
61:12
motor
midday130:21
Morgan
136:14
Mischaracte
131:9,12,
24:12,14
70:19
rizes
14
move
middle
66:16
74'6 89'7
30:16
9:21 40:7
112:9
moment
91:5
85:20
45:3
92:3
99:22
131:11
46:23
misquote
141:20
139:24,25
103:11
149:17
142:11
51:24
Monday
58:24
mistake
38:14
151:11
moved
59:3
62:3
39:12,15
Morgan's
9:12,1510:1,9
83:20
104:22
43:13,15
151:15
24:23
million
mister
monetarily
morning
40:7
6:2,3,4
151:11
28:17
4:13 24:8
46:20
9:11
mistinessmoney
30:17
47:7
15:16
39:12,15
55:15
134:21
13:6
mind
28:15
79:22
59:3
misundersto
84:19
85:5,7,9
13:24
od
29:4
29:11
150:12
107:18
129:7
54:21
38:12
112:20
142:6
63:19
mitigate
monkeys
mortgage
movement
106:21
93:18
74:25
147:4
122:12
127:10
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
Index:
June 18, 2015
moving -objected
moving
native
neurologica
104:17,19
13:14
59:12
1
notice
O
59:20
natural
147:25
62:22
85:5
16:5,7
152:21
76:13
O'boyle
108:1
neurologist
77:19
86:25
necessity
municipal
152:22,
78:10,20,
87:20
66:13
119:12
23,24
23,25 _
88:21,23
municipalit
neck
news
86:21,23
115:11
107:8
116:9
iea
132:11
noticed
145:5
124:5,17,
5:20
night
g
26:19
20 132:3
125:3
needed
53:17
150:14
10:12
84:21
140:24
17:18
85:21
147:14
147:
141:6,13
municipalit
38:12
104:4
150:3,6,
y
39:5 41:4
105:11
notificatio
7,12,15,
14:23
45:18
noel
n
20
music
63:1 73:7
81:15
105:14
O hare
149:24
116:19
notified
4:6,12,13
129:24
noise
84:1,8
8:2,10
147:22
N
neighbor
November
12:13,25
51:4 54:6
Nolan
47:22
13:1
55:7,13
61:21
31:18
naive
57:12,13
non-
numb
72:3
107:14
84:1
conformity
118:20
101:21
named
85:17
126:15,
number
119:25
11:16
124:6
19,20
5:16
144:23
61:21
126:8
16:13
Obama's
non -vacuum
83:11
150:8
72:18,20
23:15
15:2
91.9
68:23
117:17
neighborhoo
Nonetheless
102:23
object
126:16
d
39:14
113:2
57:18
15:2
121:21
66:7,16
names
137:20
north
70:5
8:9
7:8 17:4
144:6
72:11
109:25
neighbors
19:18,24,
150:2
76:19
111:12
23:8
25 20:1,
numbers
87:4
114:9
52.20
2,3 21:5
16:19
98:21
56:19
120:3
57:1,7,16
nose
104:15
99:18
Napoleon
82:2
64:14
135: 16
100:21
74:12
85:21
101:15
nutcase
102:1
narrative
140:20
Notary
98:3,4
112:9
140:12
121:20
nesting
4:3
nuts
22:12
note
129:12
objected
narrower
130:12
48:18
82:18
103:20,
53:1
23,25
ESQUIRE 800.211.DEPO (3376)
Esquire Solutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
Index:
June 18, 2015
objection.. order
76:12
121:22
offer
106:8
56:8,9
78:5
28:22
108:7
60:7,11
occupies
121:5
149:10,13
110:2,6,
61:17
145:18
objection
offering
9, 16,21
101:10
occupy
y
124:13
12:20
opened
14:10
130:1
121:9
offhand
131:6,23
12:19
objects
occur
54:9
27:17
134:4,9
openings
74:1,5
143:18
office
135:16
130:19,22
76:4,7,23
5:20
137:11,13
opinion
77:19
occurred
138:9
23:22,23
44:16
79:8,9,
82:22
46:22
141:23
52:22
11,18,25
134:1
127:18,19
142:16
56:25
80:5 81:2
occurrences
152:7
officer's
64:7
138:16
142:4
officer
110:4
67:12
obligated
occurring
21:16
141:4
76:22
64:16
148:1
22:1898:4
officers
officers
71:10
114:19
ocean
2522
:
118:18
obligation
7;7 15:11
26:10,18,
141:10
105:6
17:5
22 27:6
official
opinions
obligations
46:21
29.22
13:9
135:20
112:23
115:14
31:14,19
26:19
opportuniti
125:4
32:12
40:15
es
obscure
126:10
34:9,10
82:17
76:3 80:9
35:14,16,
54:18
126:18
October
24 25
120:20
opportunity
18:3,6
36:1,3,
127:24
56:16
observation
23:10
13,14,16,
132:18
62:25
s
73:3
25:10
17,19,20
officially
85:8
30:4,12,121:6,8
37:8,16,
123:3
obsessed
16 32:16
17,19
126:21
94:2
39:1,24officials
44:24
42'2
42:20
opposed
obsessive
49:24
63:22
22:23
93:21
44:25
50:7
95:11
83:18
48:19
51:5,6
obtaining
72:3 91:3
53:18
127.23
opposite
9:14,17
94:1055:4
133:2
19:17
occasion
95:6,22
61:19
134:10
oral
149:15
96:13
93:6 94:8
olive
5:8
107:3
95;3
26:16
121:12
occasionall
113:8
96:4,20
y
147:17,16
97;2
ongoing
Orchid
17:1 24:5
151:20
98:15
55:3
7:19
89:13
80:25
146:4
offended
102:19,22
147:23
order
29:12
104:2
27:12
occasions
105:4,16
open
46:25
ESQUIRE 800.211.DEPO (3376)
z 11EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: ordered -pay
51:14
92:19
packing
11:9
151:22
56:17
94:14,25
31:25
128:22
part-time
97:23
95:24
32:3
panels
23:22
104:4
outspoken
pages
15:7,8
participate
ordered
47:18
149:20
Papa
93:16
51:21
overflowing
paid
92:25
118:20
ordering
125:24
46:7
paper
parties
29:7
overhead
66:18
69:9
111:14
orders
6:23
150:12
107:17
partners
43:11
overheard
Pain
124:17
12:14
ordinance
92;23
55:6
146:5
145:7
parts
75:19,21
overlap
papers
59:19
organized
10:3
Paint
90:11
72;15
11:7
98:5
91:11
overlooking
20:18
Pas
107:12,19
Paperwork
73:24
42:1
15:7
119:19
10:8
148:18,24
overrun
112: 17
123;9
Pasagiatti
27:13
painted
104:2
originally
paragraph
60:20
overzealous
79:19
72:2
105:4,17
94:5
ly
108:8
passed
39:3
124:17
paramount
12:19
ornaments
106:21
5:18
owned
painting
13:12
11:8
paranoid
123:11
125:25
Orthwein
79;20,21
105:21
134:22
70:18
owner
palm
parcel
past
71:6 74:7
81:4
7:7 13:16
89:3
21:16
84:21
85:16
40:9,23
parents
34:10
90:20
P
42:10
86:3,5
60:21
138:20
58:22
148:22
72:23
139:5,7
P -a -s
59:2
113:23
15:7
83:2,16,
parked
115:18,24
Orthwein's
21 84:6
92:24
116:8
138:21
P•m•
128:20
108:21
129:13
ostensively
153:20
palma
part
134:21
150:23
PAC
58:21,23
16:20
pat
outlet
122:5
59:5,13
19:6 22:4
130:10,12
11:6
Pack
60:24
28:23
Patron
129:3,4
31:21
101:11
50:1
93:8
35:4
101:25
outlets
panel
112:24
pay
11:7,20
packed
11:5
128:22
27:1
41:13
35:5
14:14
148:8
28:22
151:23
paneling
150:25
62:13
outrageous
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CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM Index: paying.. pictures
66:18,19
105:23
38:1,2,12
person's
61:3
87:12,13,
107:9,13
40:21
133:6
photographi
15,19
111:1,10,
41:4,8,
Personal
c
116:23
15 113:23
10,11,14,
7
103:7
116:22
18,19,20,
paying
119:12,22
23 42:3,
733::33 98:4
Photographs
7.24
132:10
120:2
5,7,9,11
134:3
28:15
61:14
125:14,17
43:24
personally
photos
62:11
127:8
44:1,4,25
96:3
60:14
129:13
46:13,23
120:6
88:3
131:25
47:14,19
149:4
photovoltai
106:15
133:12
51:18,24
personnel
c
PCA
137:18
52:1 53:8
131:23
136:8,10,
67:10,19
138:6,14
55:10,25
15
68:2
141:18
69:25
perspective
p
physical
Peaches
145:21
70:4
95:4
145:2,3
107:18
148:13
100:19
pervasive
147:11
119:18
people's
101:1,12,
18:20
152:15
peculiar
93:10
13 110:17
107:16
physically
126:2,7,
51:22
97:25
11
Peter
107:3
141:2
51:4
pending
permits
physician
86:16,17
Perception
8921
:
117:16
38:23
10:13,21
Penny
40:11
Peter's
152:18
107:11
93:14
43:5,23
104:12
pick
149:2
119:19
51:11
petition
38:15
perform
52:9
67:22
40:11
people
118:14,16
13:16,17
permitted
phone
picked
15:9,22
Perfunctory
55:20
23:14,15
89:16
26:7
26:24
56:1
30:20,21
151:21
27:4,14
period
persecuted
31:6,14
pickpockets
28:9
17:15
82:8
38:16
136:23
29:19
32:21
91:9
44:4,10
45:9
Person
151:21
picks
48:2164:21
34:12
phonetic
26:1
50:16
144:2,3
79:12,25
58:23
picture
52:2
periodicall
80:3 93:5
95:5
70:19
19:21
55:15
104:2
32:22
58:1,2
y
96:2,8
61:6
64:8
56:23
103:10
photo
77:12
permission
114:14
32:14,16
pictures
79:18
127:9
119:17
74:15
60:16
85:21,23
permit
122:20
Photograph
76:25
91:15
132:25
79.7
95:13
10:16,17
142:13
32:25
85:16
37:25
33:23
97:4,9,
100:18
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: piece-posters
10,12
places
56:8
37:8 55:4
politics
104:24
12:5
85:20
B4:3 95:3
126:4
piece
18:13
pleasure
104:1
Pollock
15:4
68:13
112:2,12
105:5
112:16
22:13
plan
108:6,8,
plenty
19,24
Polo
pieces
55:11
99:20
109:1,3,
83:8,9,
15:2 79:3
planned
plug-in
8,18,19
10,15,25
130:15
11:11
41:25
132:1
84:9,11,
pile
131:1
137:2
17
16:10
planning
pocket
138:5
138:20,21
11:7
136:24
139:1
pond
p fled
podium
141:3
95:10
22:11
plane
6:10
143:12
policeman
pools
piles
39:18
point
31:2
12:15
22:5
58:5
31:24
84:22
100:1
91:10
45:19
92:23,25
poor
pillar
46:3
93:1,2
15:15
63:21
plant
64:15,22
108:4
popular
24:11,12
Pineapple
PP
70:25
policemen
p
10:25
5:15,17
planted
71:1,2
99:23
porch
6:25
59:3,4
83:13
141:14
9:8 19:16
14:11
planting
89:22
20:9,12
118:11,13
101:11
5:4policies
98:12
132:15
21:14,15,
98:1
pipe
planta
123:6,11
polite
17
136:13
58:18,20,
124:10
120:2
portion
pipes
21 59:6,
129:6
121:23
18:11,22
136:9
11,12
131:11
124:10
59:8
60:19
142:12
61:16
itched146:14
Politely
62:15
plaques la ea
150:1,5,6
141:18
79 16
position
placepointed
political
96:9
9:1 15:3,
plastic
45:5 52:8
74:10,18
150:25
12 27:13
25:18
100:23
75:5,13
32:14
play
81:16
possession
33:2
68:18
pointing
82:22
24:25
53:16
69:20
21:22
122:7
140:7
63:13
70:13
points
124:23
post
79:19
111:11
107:18
125:20
81:9
80:10
146:9
127:17
120:8
poke
132:21
posted
125:24
Plaza
133:12
141:6
43:11
27:16
132:20
129:10
40.7
police
politicking
135:21
53:15
6:15
93:12
posters
35:14,16
92:4
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: posture.. property
posture
15:1
primary
81:7
124:16,17
98:8
117:16
113:24
pressing
promoted
potential
145:18
149:25
118:18
136:6
Printed
produce
pressure
promoting
potentially
16:5
85:16
38:10
149:5
77:25
Prior
136:11,16
pretty
prompted
44:25
producing
pound
6:5 11:4,
124:24
65:4
9 12:1
55:10,22
16:6
15:18
61:4
Product
proper
pounding
122:15
105:6
28:4,8,9
6:11 64:5
36:10
35:11
123:17
properties
73:25
43:23,24
131:20
production
7:20
92:8
45:8
149:14
23:24
33:9,10,
pounds
57:21
prisoner
professions
19 89:18
65:5
64:8,9
147:7
1
140:4,8
107:3
71:1
privilege
43:9
property
pour
74:18
117:5,6
63:17
5:1 7:10
11:3
91:1 96:8
professions
9:22,25
105:10
Pro
lly
18:6
poured
113:23
68:14
22:4
12:9
24:25
120:7,10,
problem
25:14
practiced
P
22.23
5:12
profit
30:4,13
13:13
123:21
13:22
6.23
33:3,5,
practitione
147:17
18:17
programs
11,13,16,
148:14
46:22
125:10
17 35:14
r
113:21
151:23
151:16
progressive
42:10,11
practitione
previous
problems
ly
44:13
20:1851:11
39:6
142:11
ra
71.9
125:20
147:19
60:3
114:6
102:24
138:14
75:20
117:12
130:14
prohibition
78:21
pregnant
131:8
procedural
59:7
79:6
8:17
138:11
152:4
73:11,16
81:4,9
prepare
previously
Procedure
prohibition
82:7,11,
40:12
39:17
42:25
s
12,13,14,
43:3
59:17
15 83:13,
104:10
price
57:12
15,19
prepared
125:25
123:9
project
84:11
42:14
pride
43:8
85:3
113:14
proceedings
112:6
86:8,12
56:22
4:1 77:20
projects
89:25
prerogative
74:14
135:5
process
57:20
97:3,13
primarily
32:3
127:15
113:4,8,
president
83:8
42:2113
128:3
5:22 6:24
76:21,22
promises
141:3
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
propose
56:18
pump
122:17
75:19
129:15
protect
80:18
punish
65:12,16
89:13
91:20
122:22
91:11
132:12
137:20
98:23
purchase
147.9
99:12
9:10,25
protected
131:18
75:3
27:15
137:22
purchased
99:15
138:3,18
9:12
protecting
140:6
143:12,21
Purchasing
148:11
149:18
69:4
protector
150:9,23
purely
93:8
151:19,22
147:24
108:2
145:25
publically
purported
146:11
107:25
118:25
protracted
Publication
purpose
127:1
s
40:6
119:11
99:25
proud
12:19
Publicity
132:22
89:10
133:13
13:12
136:9
74:17
published
proverbial
121:7
purposes
4:21
108:9,14
publishing
18:10
provide
89:11
42:12
16:15
pull
80:23
40:21
pursue
13:7
133:15
42:7
90:15
provided
111:2
pursued
124:4
pulled
45:12
providing
19:3
22:11
pushed
40:15,17
25:13
22:9
provision
44:25
put
58:12
72:24
6:10 22:9
68:25
128:23
23:3 37:5
public
129:2
45:14
4:3,25
141:2
63:19
15:12,19
pulling
65:7,17,
16:19
22:13
22 70:15
35:19
39:22
81:14,21,
46:3 55:3
80:8
24 82:2,
June 18, 2015
Index: propose..R-h-a-p-i-s
6,22,24
146:11
90:14
questionabi
106:23
lity
113:17,19
109:10
122:22
132:12
questionabl
135.23
e
141:6
145:11
146:7
147:8
puts
116:22
putting
32:4
56:24
97:21
98:11
Q
qualified
123:2
quarter
6:4
question
5:8 10:17
30:11
48:9
63:15
77:9
78:2,9,
12,14,18
84:5
85:19
89:3 95:1
99:10
109:16
112:3
115:7,9
116:14
117:10
121:14
138:4
109:9,13
questioning
150:23
151:3
questions
74:4
77:4,5
115:20
128:8,10
151:4
152:11,12
153:16
quick
88:15
103:22
quickly
43:23
124:19
126:1
Quid
68:14
quo
68:14
quote
71:5
103:12
quoted
57:8
R
R -e -i-1
15:7
R -h -a -p -i -s
58:22
ESQUIRE Esqu �eSolution�
s.com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: R-o-e-d-e-r..reconciliation
R -o -a -d -e -r
127:17,19
134:14
rear
receipt
62:12
141:16
19:17
35:18
reacting
rabbits
Randolph
58:1
98'7
receive
79:24
49:1 57:8
reaction
reason
80:15
59:15
16:17
racing
71:16
received
124:16
50:14
145:16
140:21
96:17
133:21,25
58:3,20
racist
134:4,8,
read
66:13
140:2
27:24
19,24
45:18
84:25
receiving
28:4
68:8,20
106:1
38:6
44:7,22
range
69:2
115:15
78:10
55:18
46:14
71:24,25
118:16
recent
50:17
rare
75:22
126:12
89:15
racking
147:16
77:14
149:16
91:18
recently
82:18
rarely
reasonable
93:20
119:5
radiating
23'23
101:24
42:17
49:11
receptacle
79:13
rate
107:14,16
28:15
124:17
7:10,16
41:20
radiation
799:25
129:1,16
136:11
88:10,12,
127:1
19
153:17
80:3 81:5
receptacles
rain
82:20
41:25
69:13
ratify
reading
103:10
146:3
144:14
93:25
121:23
recess
rationale
ready
122:20
30:9
rained
55'9
124:11
88:17
105:9
26'22
144:21
132:25
rains
Raton
real
142:13
recognized
146:4
117:17
7:4,5,6
137:12
12:12
reasons
raise
rattle
16:8
116:16,
recollectio
93:2
37:2
62:19
17,18
n
raised
rattled
109:1
recall
103:7
45:9 93:3
36:4
126:12
9:4 29:10
recommend
re -screened
146:4
37:1,7,
26:15
rami£icatio
20'22
reality
20,22
49:19
ns
61:14
reached
56:3,13
67:25
recommendat
81:20,23
89:20
31:17
realize
82:14
ions
135:23
144:7
73:11
70:15
86:24
Ramon
react
125:19
87:1
recommended
11:16
134:10
realized
92:3,8
11:15
19:3 73:1
140:19
144:11
106:10
113:25
Ramon's
reactedreappoint
114:8,13
reconciliat
20:15
123:8
125:8
122:2
ion
124:19
123:5
42:22
ran
153:5
ESQUIRE 800.211.DEPO (3376)
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CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
Index:
June 18, 2015
reconsider.. rent
reconsider
reef
regulation
124:5
149:1,21
60:18
5:16
53:15
145:20
153:2,12
110:25
6:12,13,
54:8
148:2
remembered
reconsiders
16,20
101:14
150:10,20
36:24
d
15:10,13,
126:18
relatives
25 16:1,
Remi
125:17
regulations
93:9,12
5,7,8
8:10 93:3
136:5
52:8,25
111:22
63:17,18
remark
remind
record
27.17
reefs
141:12
4:11 25:2
Reil
35:19
6:13,15
15.7
remediation
Reminds
46:3
16:2,3,6
18:24
136:22
148:4
reimburseme
remediators
nt
remodeled
1 :7 37
137:7
refer
6:22
43:9
13:24
153:6
74:13
remedied
17:6
recorder
121:3
reiterated
124:21
152:6
remodeling
103:6
reference
remedy
10:11
records
80:6
reject
70:8,11
12:20
63:25
4:25
referenced
remember
17:4
16:19
61:16
rejected
72:22
7.20 9.2
55:4
84:20
63:25
23:20
removal
56:19
referred
64:3
25:15
130:21
80:18,21
82:7
related
27:20,23
83:17
122:24
48:6
28:14
remove
89:13
60:19
91:17
29:5
91:11,19
referring
78:21
113:8,10
30:24
98:23
133:20
115:13,
35:12
86.7
131:18
134:23
14,15
37:7
removed
137:22
146:2
122:5
43:25
20:13,14
138:3,19
refers
49:5 61:8
22:2,3
140:6
75:8
relates
62:4,6
59:21
149:18
153:9
70:22
79:3 81:2
150:9,24
reflect
relation
71:5
129:18,21
119:22
rectified
130:1
74:25
removing
124:20
regard
131:6
77:3
17:22
150:21
137:15
81:11
24:20
recur
143:18
88:22
145:8
registratio
41:13
144:13
92:7
60:3
Red
n
28:19
150:4
97:23
119:7
114:9
rendered
34:18
relations
128:21
148:5
117:18
150:13
regulated
122:15
renovations
REDIRECT
54:3
relationahi
135:15
152:13
128:17
regulating
P
137:11
reduce
136:18
58:25
138:3
rent
136:14
106:23
139:6
17:2
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: rented -review
rented
86:18
73:6
responding
48:16
17:3 26:8
124:1
122:24
93:19
52:15
repair
representin
requirement
response
56:16
125:20,21
g
134:25
27:6 28:3
73:21
115:16
38:6
98:20
repercussio
requires
99:16
150:6,9
80:15
n
61:25
124:15
retaliated
149:4
represents
64:10,11
86:22
118:19
responsibil
44:21
rephrase
51:10
87'12
es
it120
5:9
Rescue
91:23
reprimanded
15:11
120 :25
Replace
p
retaliating
55:5
responsible
41:10
research
50:4
reprocussed
51:20
96:3
replaced
105:22
retaliation
11:5,6
95'8
residence
149:6
46:14
20:19
reputation
72:6
48:10
restrict
127:3
50:15
residences
137:25
79:1
replacement
119:4,14
76.25
95:14
41:19
120:13
resubmitted
106:5,9
149:4
resident
123:14,20
111:5,9
replacing
68:22
124:2
11:7
request
69.4
result
41:18,20,
56:19
90:17
54:14
retaliatory
25
66:6,12
109:2
57:22
44:7 89:6
80:19
58:3 66:5
106:13
replicas
131:21
residents
86:13,14
133:19
137:7,22
40:6 69:7
111:19
retile
report
140:6
89:18
117:23
11:3 41:1
63:15
requested
139:19
resulted
retribution
65:25
71:14
resolution
30:1
102:12
84:3
72:6
146:17
retrieve
resultingresolve
96:7,15
127:3
127:5,6
105:12
105:5
131:18
39:15
135:24
return
108:23
137:9
124:12
60:21
132:1
resume
134:3
requests
resolved
63:22
123:12
98:23
69:21
135:12
returned
Reporter
131:20,23
4:3
132:1
resources
resumed
44:24
6:14,19
44:3
returns
represent
require
132:14
20:10
89:9
10:13
retained
representat
41:13
respond
118:22
reverse
ion
66'2
28:7 39:5
retainer
142:13
143:9
88:5
required
62:16
review
42:3
responded
40:17
represented
retaliate
4:24 50:2
60:19
27:8,22
47:13
56:5
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
Index:
June 18, 2015
reviewed..Sales
119:10
85:22
104:25
136:7,20,
23:5
123:1
right -on
rodents
22,25
rude
143:16
146:7,8
86:5
35:7
125:14
reviewed
147:3,8,
rights
Roeder
10
ruin
77:18
142:14
62:12,13,
50:14
78:20
roofer
16 86:20
144:3,18
ring
72;3,24
rule
87.22
145:10
8:18
reviews
88:25
Roofers
62:19
ringing
133:23
63:11
ruled
5:11
134:8,18,
60:16
Rhapis
roofing
58:21
113:6
22
136:3
rules
145:12
59:1
role
9:18
147:14
roofs
4
60:25
4:
44:2
rich
45:9,10,
ripple
145:25
66:20
138:13
11 73:12,
95:10
roll
14,16
run
Richman
risk
25:18
136:3
125:11
91:9
151:11,
63:20
roof
room
run-around
116:23
15,21
20:21
19:7
143:7
RICO
Rita
41:1,7,9
21:6,8,
rundown
90:1
39;16
45:1,4,5
18,20,23
125:23
40:2,3,24
46:10
22:1,23
91:10,16
144:14
47:21
25:20
running
119:9
14:8
120:11
Riviera
50:9 51:4
31:2 58:9
145:15
138:6,12
62:24
119:9
23:12
63:1,12
129:5
30:25
148:8,13,
road
64:7,14,
130:6,7
50:16
14,18
9:21
19,23,24
147:21
runs
149:7,9,
20:3,4
65:1,2,3,
120:18
19,25
26:3 40:7
5,6,15
rooms
150:23
45:320:25
_.
66:14
151:1,9,
46:23
21.25
S
68:9
12 152:9
51:24
69:8,9
ropes
___..
rid
58:24
70:4,13,
105:15
sag
22:24
59:3
15,16
Rotten
45:6
43:10
79:21
71:14,15,
91:7
141:10
18 72:4,
130:15
saint
128:22
Robert
5,6,7,9,
rough
136:23
ridge
4:24
23 73:5,
11:18
sake
7:7 46:21
11,13,15,
rougher
43:6 81:6
72:25
rock
19 101:13
11:18
150:18
115:14
95.9
126:11,12
sale
125:4
rocks
131:2
round
75:5
16:8,10
134:23
78:15
riding
135:2,7
route
Sales
74:11
rod
5:16
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
6:13,20
Sam
45:4 51:3
Samurai
48:12
sand
64:15
sandwich
136:7
Sandy
69:13
Santa
81:15,21
Sargent
73:13
sat
12:18
13:10
32:8
70:18
91:3
satiation
107:6
satire
82:6
satisfied
135:3
Saturday
84:21
sausage
57:21
save
150:15,19
savings
148:12
scale
23:3
scandalousl
y
91:14
scarey
136:1
scenario
65:19
scene
26:18
school
12:1
schoolmates
148:22,23
schools
5:21
scope
41:5
120:24
Scott
70:19
139:24
Scouts
93:11
screen
19:9
20:10,12,
14,24
25:13
Screened
20:23
screened -in
21:1
scuba
15:10
sculp
13:25
sculpting
14:1,22
sculptural
15:8
sculpture
14:1,3
sculptures
15:7
23:25
sculpturing
5:18
Sea
141:10
search
14:22
113:4,7,
13
searches
17:24
seat
141:4
section
45:16
59:22
126:14,23
sections
58:14
security
16:13,18
22:7
113:18
seek
115:6
seeking
87:6
115:4
sees
136:23,24
selecting
54:24
self-
closing
34:7
self -
employed
117:25
118:9
self-image
93:7
107:23,25
self-images
93:5
self -
levelling
22:4
self -
promotor
107:22
sell
9:24
65:20
147:7
send
89:13
153:14
sense
27:5
113:18
sentiments
48:24
140:14
September
24:20
26:13
30:3
39:25
septic
125:24
sequence
144:8
sequencing
144:1
serve
125:18
127:16,25
137:2,6
June 18, 2015
Index: Sarn-sheets
served
127:23
serves
40:6
service
34:25
48:20
109:4
124:13
137:5
services
40:16,18
150:12
serving
133:13
setting
11:14
settle
70:14
settled
125:25
severed
105:1
shabbily
91:1
shag
24:24
shakes
64:24
shallow
15:8 83:4
shapes
15:9
shared
33:13,17
115:2
she'll
107:12
sheets
25:18
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM Index: Shelly -Solei
Shelly
shuffling
6,11,14,
5:7 29:18
97:15
8:2,3
98:5
15,20
45:11
small
13:21
shut
142:25
47:25
14:6 23:3
24:21
13:5
similar
48:1,5
26:1
32:5,19
49:6
149:23
82:2
93:22
145:20
64:18
148:3,10
shutting
g
133:17
66:3
smart
100:11
139:25
87:24
-63:23
Shelly's
simple
88:2
68:20
93:12
side
19:17,18
12:2
108:22
smell
shingle
43:24
20:2,3,4,
situation
128:20
70:16
67:20
11 21:5,
99:10
70:7
smooth
shingles
7,10,21
100:25
124:20
51:23
64:24
26:3
109:17
situations
52:1,4,9,
shocked
33:12
145:9
14,20
34:2
sing
48:8
53:4
53:21
133:6
sketch
57:11
54:1 55:6
54:8
snake
single
shoes
65:13
22:14
95:13
skiing
29:2
73:19
130:14
103:18
93:22
shop
120:15
108:9
snowskin
12:19,24
126:20
111:13,16
93:22
74:15
131:16
149:18
142:11
snowball
shoreline
sided
singular
skinny
142:8,15
104:15
46:8
144:6
20:15
sign
slanted
snowman
short
sinister
81:16,18
17:15
37:21,23
120:22,23
119:20
38:18
slap
Social
show
75:1,21
sink
16:13,18
28:6
104:6,10
149:19
socialize
60:17
signatures
sleep
75:6
123:3
sinking
17:18
120:7
99:24
144:2,3
104:23
socially
sleeping
120:18
signed
sir
47:1
18.8
showed
35:18
92:1
society
32:19,20
139:24
sit
sliced
149:6
105:3
58:16
signs
35:3 92:6
solar
60:14
74:9,10
99:5,11,
sliding
101:13
61:4,7
75:14,20,
13 145:6
21:18
136:3,7,
74:23
23,24
site
slightly
11
79:23
76:2
35:7
54:1
showing
82:22
sold
121:17
sites
slope
9:23 10:1
66:13
140:24
22:18
72:25
14:16
74:11
99:25
141:2,4,
sitting
slowly
Solei
O ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. corn
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
27:16
4 0: 7
53:16
56:8
85:20
Soleil
7:18 8:24
solicited
56:25
58:6
solid
11:5
solve
138:14
146:24
151:16
son
6:17
58:25
90:6,9
song
133:7
sons
35:1
sort
92:14
142:9
sorts
43:9
63:10
79:24
92:4
103:1,22
119:11
132:13
sought
68:6
101:1
116:2
117:20
127:25
soul
spec
69:20
55:14
sounded
special
31:16
54:24
110:11
59:14
sounds
60:4,15
61:2,24,
147:20
25
source
118:11
120:12
south
19:24,25
20:1,11
21:6,9,
21,23
83:2,21
84:6 95:3
sovereign
95:20
space
130:20
Spanish
11:16
20:16
24:10
93:8
spare
93:23
107:1
speak
5:10
39:14
90:6
93:21
121:6,8
122:14
150:17
speaking
67:24
107:25
129:13
149:16
specialty
11:19
specific
99:17
121:20
specificall
y
60:4
137:14
146:1
specifics
48:23
Speculation
102:5
speech
48:6,10,
15 49:24
50:1
53:7,12
54:23
55:1,2
75:5,13,
19 76:21
82:17
85:8 89:6
91:24
98:20
99:16,25
111:5
121:3,17
124:19,
23,24
spelled
60:22
spent
15:16
74:16
107:1
spinning
66:9,15
136:6
spite
64:14
spitting
89:22
splash
112:18
splattered
20:18
splitting
30:6
spoke
32:9 40:2
50:8
123:17
143:2
spoken
39:17,25
108:25
sponsored
122:13
sporadicall
y
24:22
spot
19:4
105:8
spouse
117:3
sprayers
129:15
spraying
131:13
spring
June 18, 2015
Index: Soleil-Star
9:5 4 7: 22
97:8
131:22
square
9:8 14:7,
10 65:4
78:15
squares
65:3
squeaky
126:5
stability
104:25
staff
52:3
stamp
32:14,15
stand
29:2 59:1
111:1
142:14
standard
140:21
144:18
standards
59:9
143:16
144:6
standing
21:24
34:8
98:16
standpoint
73:17
Star
89:11
93:19
99:21
107:16
139:7
140:14
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: staring -street
staring
136:17
16,17
28:1,11,
37:14
98:2
144:14
87:6,9,
12,13
strain
151:1
11,14
40:4
start
90:14
14:13
stated
88:9,12,
stickers
18,24
strained
39:21
151:1
29:8 37:5
99:3
145:20
43:2,3
statement
100:4,24
sticking
61:2
strange
100:11
28:7
101:5,7
48:13
45:20
29:12,15
102:4
104:16
107:5
104:3
49:24
112:13
sticks
started
99:14
115:3,17
strangers
48:12
13:10,25
138:5
116:1
149:7
14:1,15
statements
117:10,11
stone
straw
19:3
151:18
128:8
79:15,23
108:9,14
24:20,22,
140:12
146:8
141:22
24 31:25
states
150:22
stood
42:2 44:5
5:20
151:56:19
straws
45:3 55:3
status
152:12,14
966:21
108:18
60:20
69:8
153:13,
98:1
Stream
89:10
152:2,3
16,18
143:12
7:6,12
110:21
9:21
126:1
statute
steel
stop
128:16
136:17
107:10
6:6 26:21
35:22
50:2 52:7
129:14
statutes
step
28:11
68:22
130:20
93:25
39:23
30:7 32:7
79:21
131:14,22
46:17
37:5 38:1
82:25
142:5
stay
62:24
43:3,11
83:18
145:4
15:23
141:10
106:20
122:13
146:14
31:6
146:16
stopped
128:1,4
106:6
starting
stepped
89:21
132:7
12:14
stayed
21:13
134:6
137:2
142:3
27:15
47:10139:20
stopping
starts
ata in
stayin
steps
97'20
140:4
18:9
141:21
145:22
142:13
store
148:22
state
steak
steroids
137:19
107:6
street
4:3,11
132:12
storm
19:17,18
90:23
Stearns
Stetson
69:13
27:11,13
91:21
4:10,14
119:10
straight-
53:18
93:25
16:16,20,
60:13
101:14
23 30:8,
Steve
faced
61:3
110:24
10 58:10
120:20
108:3
73:14
113:2
66:11,22
sticker
straighten
76:5 79:8
119:3
70:10
26:19,21,
37:13
85:21
122:23
72:14
24 27:2,
straightens
89:21
132:13
77:2,11,
3,18
d
96:21
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. corn
CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM Index: stress -system
97:3,24,
133:1
suffered
supplied
93:2
25 98:1
stuffing
113:15,22
45:24
suspicions
104:13
115:23,24
63:8,13
107:4,6
45:10
137:15
119:3
style
supply
73:2
stress
sufficient
6:11
137:24
51:25
117:21
67:3
153:3
52:6,7,
suspicious
147:16
10,11,12,
Sugarman
support
103:2
148:1
24 56:5,6
119:6
64:7 72:4
105:3
stressful
subject
suggest
127:16
129:2
61:13
106:4
111:3
supported
swear
107:9
111:5,9
8:17
125:7
suing
stressors
submerged
91:8,12
supposed
sweep
116:3
83:14,15
suit
27:4 31:4
31:20
stretch
84:2
51:19
86:13
Sweetapple
142:23
submit
105:1
4:24
sullied
123:1120:13
strictly
65:25
113:25
16:3
66:4
supposition
114:18,21
strike
submitted
summary
101:25
115:15
12:7
102:2
127:6
37:9
54:11
55:24
64:2
summer
surely
149:16
73:5,9
124:8
146:18
151:11
strong
132:4
152:1,6
49:13
subpoena
surface
Sweetapple'
71:18
137:5
sun
16:9
79:12
136:9
s152:7
stuck
subsequent
29:10
91:3 93:6
Sunday
surprised
67:19
142:17
84:18
15:1
swimming
studied
147:13
sunk
surrounded
12:15
136:23
subsequentl
84:2,10
83:12
switched
y
104:3
10:5
studio
surrounding
23:25
14:16
sunken129:3
sword
58:9
103:20
48:13
studying
61:23
104:14
surveys
100:12
60:8
63:9
substantial
superimpose
sworn
stuff
ly
133:5,8
Susan
4:7
26:2
72;7
143:3
sympathetic
31:21,25
superimpose
sued
d
suspect
ally
43:5
60:25
67:4
74;25
100:14
39:4
86:12
128:18,19
93:11
92:10,16
supervising
system
112:19,20
24:1
suspected
96:12
128:25
95:16
44:9
136:3,12
130:17
148:8
supervisor
141:7
suspicion
0 ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
T
table
49:6,7,9,
10,14
133:22
tacked
128:23
tacky
15:23
tag
63:13
tags
97:24
taking
11:8
20:17
25:11
26:16
38:12
42:7
56:25
77:7
97:4,9,10
129:1,14,
24 131:1,
4
tale
20:20
talk
23:10
43:21
65:3
77:12
88:9
120:9
124:6
141:18
144:23
talked
34:9
41:15
48:25
73:17
77:3
83:24
90:21
116:3
117:1
121:24
130:2
147:12
152:6
talking
7:9 25:9
26:2
28:19
31:15,16
49:1
50:15,21
71:21
74:8
77:6,7,11
79:4
82:13
89:22
94:7 95:6
99:4,19
100:25
101:4,15
110:11
111:6,8
113:1
115:12
117:3
121:12
122:8
128:13
141:22
143:22
148:14
151:25
tank
125:24
tape
103:6
taped
90:11
target
101:12
106:9
108:1
task
24:2
taste
111:11
taught
101:24
tax
42:12
taxes
66:18
Taylor
39:18
40:2,3
123:1,8,
15 143:15
144:14,17
151:22
teacher
68:16
Tech
45:5
technicalit
y
67:14
technically
24:24
99:8
147:7
telephone
22:7
telling
50:16
66:14
84:22,25
114:2
127:7
143:15
tells
66:17
89:16
134:21
temper
121:24
tenant
17:1
tense
145:6
tensions
44:10
tent
147:10
term
79:11
92:14
terse
80:21
test
13:11,12
testified
4:8 49:8
96:10
114:25
130:25
139:9
testify
21:16
119:24
testimony
21:11
therapist
113:24
114:1,4,
11 115:11
therapists
114:6
June 18, 2015
Index: table -things
thick
10:24
142:11
149:20,21
thin
128:24
thing
22:17
24:7
26:24,25
30:1
38:14
44:11
49:2,5
51:3
53:14
61:10
64:21
66:15,19
73:20
76:3 78:6
89:8
93:14
95:15
96:2,4
98:24
105:7
111:2
125:7
146:24
148:24
149:3,7
152:6,9
things
5:21 12:2
13:7
15:9,11
25:11
26:1,6,8
27:7,9
29:5
40:5,12
41:2,3
47:2,3
4 9: 17
O ESQUIRE 800.211.DEPO (3376)
EsquireSol utions. corn
CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM Index: thinking..time
56:25
119:15,18
50:10
41:17
34:20
59:13
thought
52:3 53:8
144:6
35:20,24
63:10
54:17
37:6
21.20
throw
69:19
56:15,18
38:21,24,
23.2 28.4
80.9
73:24
58:6
25 39:7
29:24
112:16
74:16
36:14
60:10,25
141:11
40:9,13
75:11,12
73:21,25
42:4,13
78:25
39:2,4,22
74:7,11
throwing
44:8
42:23
79:11,17,
76:3 78:4
95:9
48:17
45:6 49:8
24 82:4,
84:19
141:16
50:12
50:12,17,
19 85:24
24 51:21
90:21
thrown
52:1
86:6
52:13
99:21
25:25
54:21,22
90:12,19,
74:17
100:6
111:22
57:24
24 95:8,
120:16,
59:18
12 96:10
84:7 85:7
18,23,24
thumbed
60:13
100:19
91:1 93:1
121:3,7,
101:14
61:7
98:3
101:13
106:25
16'22
tide
62:11
102:15
110:19
128:5
105:12
64:20
103:1,14
133:11
71:6
122:21
tight -knit
108:
142:6
73:1
110:88,, 13
124:18,21
125:19
74:166
125:16
Thrasher's
113:1
126:24
52:13
tile
75:21,22,
114:12
131:13
81:18
10:24
23 76:21
116:25
143:6
11:2,18,
81:10,17
119:11
threat
19 22:3
82:5,9
145:8
120:11,
85:7
25:11
83:24
146:16,17
20,21
110:14,16
45:1,2,7
89:23
147:24
121:25
127:2
64:7
90:14,20,
123:10
thoughts
threaten
65:5,15,
25 91:5
124:8,9,
145:18
126:23
22 71:19
92:5
11 129:11
thousand
72:7,24
93:23
132:15
91:6
threatened
79;20
97:17,18
142:7,10
73:25
103:19
145:15,
Thrasher
86:9
time
107:1
17,21
4:16
97:11
6`18 9:22
108:21
148:25
35:17
151:8,10
10:2,14
110:11
152:4
37:18
threatening
12:1917:15,18,
113:2
38:8,19,
49.8
115:10,11
thinking
21,23
24 18:12
13:2 29:1
41:21
96:22
20:13
116:25
43:3
43:21
151:12
22:1
121:24
112:19
45:12,15,
threats
23:19,25
123:9,10
145:14
19,22 25
110:5
24:19
125:16,22
147:25
4
25:5
126:17
148:1
threshold
30:4 14
127:3,17,
200,22
21:18
,,13,
19 131:9
thinks
47:6
32:1222
132:20
90:24
49:1,8
thresholds
15 20
134:4
ESQUIRE 800.211.DEPO (33 76)
Esquire Solutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: timeframe..treated
136:15
50:3
26:25
92:10,22
town's
138:1
52:19
27:3
94:15,17,
46:10
144:1,2,
53:13
29:14
18 95:11,
61:25
3,8,12
55:24
31:15,16
13,15
66:24
145:19
56:3
34:18
96:16,19,
68:10
147:15
58:17
35:13,15,
20 98:19
89:24
timeframe
70:12
22 38:20
101:1,14
91:5
71:2
39:18,25
102:15
93:16
55:19
80:20
40:5,16
103:15,25
110:19
101:4
94:8
45:8,10,
104:14
113:12
123:19
95:21
19 46:20
105:20
122:17
130:1
96:24
48:18
106:3,7
126:14
131:17
98:14
50:2,25
108:4,25
132:11,
timely
103:3
51:25
109:1,3,
15,18
118:14,17
105:16
52:5
10,18
151:16
times
109:17
56:3,4
110:5
153:9
4:19 14:4
110:17,20
57:10,13
111:4,7
towns
35:23
119:16
58:19
119:20,21
91:21
38:22
120:16
59:7,11,
120:14
44:24
148:3,11
12,16
121:21
track
84:7
149:14
60:8
122:4,8,
11:1
102:23
tolerate
62:25
11,14
traditional
117:7
24:23
63:13
124:3,4,
81:24
143:7
65:1,8,9,
12,19
tomorrow
14,18,24
125:4,9,
trailer
tiny
37:10
67:3,22
16,25
23:1,4
85:12
99:2
68:7,15,
126:24
train
Tobias
tools
22 69:4,
127:7
39:22
120:20
32;4
6,7 71:8,
131:18
10 73:12,
132:3,6,
transcript
today
top
21 75:19
10,17
16:21
21:11
13:10
76:24
133:1,20
transcripts
44:17,19
39:11
79:7,8,10
134:10
99:24
79:21
66:15
80:13,24
135:38
92:6 93:5
128:23
82:11,15,
136:4,,17,
trash
97:18
130:20
25 83:13,
19,24
22.58
99:11,13
tore
15,17,23
137:24
16,22
25:20,22
told
20:17
84:8,9,
138:1,13
10:21
11,14,16
139:20
treat
19:4
totally
85:2,15,
141:6,8,
116:16
26:20
91:13
25 86:1,
11 142:6
treated
29:22
touching
8,12 88:5
143:8,14
54:7
31:8,11,
141:14
89:5,8,
145:1,10,
76:22
21 32:6
town
10,17
14 146:19
81:7
36:6
4:15
90:11,17
148:8
90:17
37:12
16:18
91:6,12,
149:11,17
91:1,2
41:5 45:9
21,23
ESQUIRE 800.211.DEPO (3376)
Esquire Solutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
117:13
152:22
153:8
treating
152:16
treatment
116:2
tree
26:16
36:25
81:15,19
trees
24:21
46:18
47:8,9
56:24
tremendous
65:5,7
trespass
18:1
48:19
86:9,12
124:3
trespassing
85:2
trial
92:4
trigger
41:17
trim
11:5,15
trips
25:21
Tropical
125:23
trouble
30:1
103:16
109:14
110:7
troubles
89:14
91:5
truck
26:20
32:5
141:11,16
trucks
97:25
true
41:24
42:24
65:25
88:8
113:16
trust
96:9
109:19
115:24
truth
63:18
Tuesday
43:13
turn
33:5
142:15
turned
36:4
54:15
90:7 98:1
113:24
114:1
124:16
TV
18:12
28:6
type
10:9
33:18
62:18
92:18
103:18
122:5
123:25
152:24
types
136:3
typical
23:21
85:23
114:12
140:21
typically
4:21 24:7
unbelievabl
e
145:12
uncomfortab
le
48:21
undergoing
112:7
underneath
136:9
understand
5:8 40:17
64:20
69:24
89:23
113:5
137:19
understandi
ng
41:17,22
understood
40:19
79:9
122:19,20
undoing
32:4
June 18, 2015
Index: treating -vectors
uneven
11:2
unfair
126:25
unfortunate
15:15
unhappy
126:9
uniformly
122:19
unincorpora
ted
7:7
units
6:18
universitie
s
5:21
University
12:10
unlawful
17:24
111:20
113:4
unprofessio
nal
110:20
unrelated
108:11,12
unsupervise
d
24:6
upset
35:11
69:12
89:23
120:8,10
upsets
120:11,12
upsetting
102:14
upside
21:2
108:5
Utilities
33:21
V
vacant
16:25
vacuum
72:13
vague
60:9
122:18
126:17
Valentine
82:4
Valentine's
90:3
validate
107:23
validated
107:25
validity
73:7
vans
59:20
variance
46:1,9
146:20,21
variances
51:20
variety
115:12
116:10
vectors
33:4
O ESQUIRE 800.211.DEPO (33 76)
Esquire Solutions. corn
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: vehicles -well-being
vehicles
141:9
118:23,25
51:23
wax
35:8
violating
wages
52:1
49:25
71:17
veins
58:11
117:23
ways
72'5'9
79:22
118:5,8
141:3
violation
75:6,7
verbalized
57:4
wait
80:7
wealthy
49:12
58:8,11,
53:3 62:3
101:11,12
13:17
verify15,19
143:8
122:11,17
wear
45:23
59:5
wake
125:18
66:9,15
46:12
60:3,6
112:20,21
127:9
76:14
128:22
weather
143:8
80:10,13
waking
129:12
79:22
Verizon
113:3
145:16
131:15,25
105:10
23:19
141:19
walk
132:24
145:23
versus
violations
12:6
133:13
146:1
56:3,13
101:3
26:25
135:4
website
66:14
32:23
143:5
75:8
Virginia
85:2182:19
wanting
varus
111:24
66:23
90:8,23
72:21
93:20
visible
walked
90:14
132:6,9,
vestibule
76:5
12,24
135:2
21:17
Ward
133:17
visit
34:1049:1
viability
37:15
weeds
69:25
90:4
walking
warehouse
125:24
71:15
85:21
14:7
visited
94:10
week
video
35:22
waste
25:12
137:3,8,9
wall
54:22
43:13
visitor
11:9
131:9
videos
69:6
20:10
130:3
133:4,5
25:15
water
131:8
visualize
22:6 30:7
weekend
videotape
58:2,3
Walls
83:11
137:6
voiced
130:7
103:21
38:17,20
view
121:9
Walmart
130:15
weekends
61:4 98:7
27:11,12
136:9,13
83:5
108:8
volunteer
137:14,
139:3
weeks
125:10
126:10
127:15
17,23
waterfalls
25:8
Vincent
138:4
12:15
weighed
vote
34:15,22
122:22
wanted
waters
73:6
Vincent's
13:21,25
82:25
weighs
34:25
voters
22:10
65:3
122:22
24:10
waterway
violate
26:17
83:12
weight
117:2
40:11,24
104:20
45:15
violated
W
45:8 47:2
105:13
well-being
59:18
49:14
wage
ESQUIRE
800.211.DEPO (33 76)
EsquireSolutions. com
CHRIS OHARE
OHARE vs. TOWN OF GULF STREAM
June 18, 2015
Index: west -wrote
18:14,16
Wildlife
words
93:24
111:3
108:5
103:21,24
48:24
97:16,18,
133:15
110:12
104:18
53:9
19 102:24
worse
113:16
119:8
80:12
106:22
65:19
116:8
windmill
84:23
110:17
142:12
100:8
111:21,25
west
136:5
147:19
139:6
112:22,23
19:15,20,
window
151:15,21
116:20
worth
23 33:5,
36:11,12,
119:12,
29:25
12,16
work
22 125:23
13,20
60:24
6:6,8
wheel
123:25
123:12
wire
10:9,13,
66:9
22:6,7
20 11:11,
127:15,22
148:21
wheelchair
130:15
12,14,18,
147:9,17
writ
90:6,12
23 12:6
148:4
51:18
wires
whim
26:5
13:15,18,
worked
62:3 67:9
71:12
22 14:16,
13:8,14
68:2,6
wise
21,23
55:5
write
Whippet
152:9
15:21
57:20
16:16
79:15
withdraw
17:21
workers
20:1
white
149:17
19:2
11:16
38:15
45:2
witnessed
20:19,21
24:3
62:4 68:1
78:19
51:5
22:8,10
30:17
77:13
147:22
23:7
37:9
woes
24:1,11,
writing
wide
89;12
18,21,24
97:25
108:23
59:25
130:14
woman
25:4,6
137:15
written
wife
15:15
27:2
55:11,23,
7:22
28:18
working
25 56:7
17:17
61:20
32:4
12:18
71:9
18:6
107:18
34:24
23:25
84:19
37:22
125:12
37:5,25
26:21,23
104:17
69:11,12
127:3
38:2,13
28:11,14,
119:10
73:17
wondered
39:15,24
16 32:7
126:16
92:21
44:8
40:1,8,9,
38:1
104:13
24 41:6,
49:19
wrong
Wonderland
63:22
76:17
106:18
68:19
7,14
112:25
42:3,13
93:24
126:6
117:20
wood
43:11
110:21
134:20
120:5
11:9
44:3,5
112:5,11
wrote
125:22
128:22
46:12,24
works
38:8,9
137:2
130:15
56:23
5:19
39:2,9
140:16
word
59:23
87:21
61:15
146:18
27:14
62:17,18
76:11
68:10
64:4 72:9
world
78:4 97:6
wife's
69:3 95:9
87:23
78.19
126:17
8:1
88:1
93:14
100:1
ESQUIRE
800.211.DEPO (3376)
Esquire Solutions. com
CHRIS OHARE June 18, 2015
OHARE vs. TOWN OF GULF STREAM Index: yank..zoning