HomeMy Public PortalAbout02 12 16 MeetingMINUTES OF THE REGULAR MEETING AND PUBLIC HEARING HELD BY THE TOWN
COMMISSION OF THE TOWN OF GULF STREAM ON FRIDAY, FEBRUARY 12, 2016 AT
G9:00 A.M. IN THE WILLIAM F. KOCH, JR. COMMISSION CHAMBERS OF THE TOWN
HALL, 100 SEA ROAD, GULF STREAM, FLORIDA.
O
O
I
II.
III
Call to Order.
Mayor Morgan called the meeting to order at 9:00 A.M.
Pledge of Allegiance.
The Mayor led the Pledge of Allegiance.
Roll Call.
Present and
Participating
Also Present &
Participating:
Scott W. Morgan
Robert W. Ganger
Joan K. Orthwein
Thomas M. Stanley
Donna S. White
John Randolph
William Thrasher
Rita Taylor
Garrett Ward
Ed Presney
Tom McClure
Barbara Sloan
Robert Sweetapple
Mayor
Vice Mayor
Commissioner
Commissioner
Commissioner
Town Attorney
Town Manager
Town Clerk
Police Chief
Pres. Ocean Ridge
Yacht Club
Boynton Coalition for
Responsible Develop.
Town Resident
Special Counsel
IV. Minutes of the Regular Meeting of January 8, 2016.
Vice Mayor Ganger moved to approve the minutes of January 8, 2016
and Commissioner Stanley seconded the motion with all voting AYE at the
roll call.
V. Additions, withdrawals, deferrals, arrangement of agenda items.
The Town Clerk requested to add as Item IX. E., Naming the Gulf
Stream Voting Delegates to the Palm Beach County League of Cities, which
would move the existing IX.E., Items by Mayor and Commissioners, to Item
IX.F. Mayor Morgan, noting that the Town's Special Counsel Attorney
Sweetapple is present, announced that he would be giving a report under
Item VIII.E.
VI. Announcements.
A. Regular Meetings and Public Hearings
1. March 11, 2016 @ 9:00 A.M.
2. April 8, 2016 @ 9:00 A.M.
3. May 13, 2016 @ 9:00 A.M.
4. June 10, 2016 @ 9:00 A.M.
5. July 8, 2016 @ 9:00 A.M.
There were no anticipated absences declared.
VII. Communication from the Public (5 min. maximum)
Town Commission Regular
Meeting & Public Hearing
2-12-16 at 9:00 A.M.
OMayor Morgan announced that there are two gentlemen from outside
of Town who would like to speak at this time.
Mr. Ed Presney, President of the Ocean Ridge Yacht Club introduced
himself and stated he wanted to share some comments regarding the
proposed 10 story, 325 unit rental apartment building planned for the
now vacant Winn Dixie site just across the Woolbright Bridge.
OHe pointed out that the site plan for this project shows that over 600
parking spaces will be required which will more than double the existing
300+ spaces. He said there was a traffic study that concluded this would
be O.K. but it is evident that it is not O.K. now with only 300 spaces.
He also reminded that this is before the Bright Line with 30 trains a
day comes in and additional bridge openings because of the higher tides.
In addition, he reported that the Boynton Beach Police Department
records show that there has been a 78% increase in accidents since 2012
at the intersection of Federal Highway and Woolbright Road. His main
concern is safety, remarking that the Boynton Beach Fire Department
serves several municipalities on the east side of the Intracoastal via
Woolbright Road & Bridge. He urged the municipalities on the east side
of the Waterway to go together and have a traffic study done that will
consider all of the real facts and the resulting impact of this
proposal.
Mr. Presney pointed out that there is an existing Mangrove area adjacent
n to this site that is owned by the developer and is in the process of
being surveyed and many are concerned about the precedent that may be
set for future development in the area. He said that the Boynton Beach
administration is encouraging additional development and the town seems
to be leaning in the direction of this leadership. In conclusion he
reported that there has been a group of citizens from both sides of the
Intracoastal Waterway that have formed an organization called The
Boynton Coalition for Responsible Development and he encouraged the
Commission and the town citizens to become pro -active in this matter as
this development and that which will follow will be detrimental to the
residents on both sides of the Intracoastal.
Mr. Tom McClure, President of the Boynton Coalition for Responsible
Development, was recognized and stated the organization is interested in
working with the city and the developer from the beginning to make sure
this is not a 10 story building with 326 rental units and 800 parking
Ospaces that chokes off the city. He said the CRA looked at this proposal
and had 133 comments as compared to the usual 4 or 5 per development. He
added that they will be working in partnership with the CRA, the
Planning and Zoning people and the Planning and Building people to let
them know the citizens do have an opinion and a voice regarding this
development. He also encouraged those in Gulf Stream to join in this
effort to control reasonable development in these areas that impact us
all. He distributed a release from the group that organized to provide
C� citizen oversight on the proposed Riverwalk Plaza Apartment Project.
2
Town Commission Regular
Meeting & Public Hearing
2-12-16 at 9:00 A.M.
Barbara Sloan commented that even now, without the 10 story building,
you have a problem getting a parking spot at Publix.
Mayor Morgan called attention to the new Town Hall Garden at the
fountain and stated there is now some discussion regarding repair of the
sidewalk in this area to the south, asking the Town Manager to discuss
the report from Anzco with regard to this matter.
OVIII. Reports.
A. Town Manager
1. Restoration of Town Hall front sidewalks-Anzco Inc.
Mr. Thrasher called attention to a proposal from Anzco, Inc. in the
amount of $13,460.00 to replace the sidewalk next to the mailbox and the
east and west sidewalk and acid wash and reseal the remaining sidewalks.
He added that if it were decided not to replace the east and west
sidewalk, just cover that area with grass, it would reduce the amount by
$2,000. Mr. Thrasher said he was not asking for approval to do any of
this at this meeting but would be bringing the matter before them at the
next meeting. He requested that everyone look at the area and report
back at the next meeting. Mayor Morgan believed there to be a safety
issue with the sidewalk next to the mailbox that should be addressed,
but with regard to the east/west sidewalk, it's a matter of esthetics
when it comes to replacing it.
C Commissioner White reminded there has been some interest in adding to
the Town Hall and she wondered if a future addition would be considered
for any of these areas. Mayor Morgan and Mr. Thrasher reported that
there have been some preliminary investigations that are still underway.
It was explained that there is some consideration with regard to
bringing the permitting in house which would require additional personal
and space to house the department. The costs involved are being
formulated with the thought that the fees collected would in time pay
for the expansion. They said that if this is feasible, the building
expansion would be on the west side of the building and would not impact
any of the area under consideration in this proposal.
2. Undergrounding of Utilities
Town Manager Thrasher reported that the pre-bid requirement meeting was
held on January 27, 2016 and three potential bidders for Phase 2 were in
attendance. The deadline for receiving bids is February 19, 2016 by 2
P.M. at which time they will be opened. They will be evaluated by Mr.
Brannon and a recommendation will be presented to the Commission at the
O
regular meeting on March 11, 2016, he said.
Vice Mayor Ganger asked what those newly installed, very large poles,
will be used for and was told they are a requirement from FPL and will
hold transformers as well as give the capability to loop our electric
from the west side of the Intracoastal and must be installed within our
municipality.
O3. Water Meters in Place Au Soleil
Mr. Thrasher said that since this was discussed at the last meeting, he
has received a document regarding training and future training of our
3
Town Commission Regular
Meeting & Public Hearing
2-12-16 at 9:00 A.M.
Opersonnel that was not provided to the Commission and therefore there
was not sufficient information for a decision. He said if he had been
given this document along with all of the other information, he would
not have recommended this project as we are not at this time geared up
for the electronics and related training they are requiring. He added
that there were some concerns voiced by Place Au Soleil residents that
we were doing this in their development rather than on the island as an
Oexperiment, which is not true. He confirmed that there will be no change
from the current method of operation and equipment that is in place.
4. Barrier Island Community Feasibility Survey -Matrix
Consulting Group
The Town Manager advised that Highland Beach has come back into the
Study and is sharing in the cost due to some current contract
Complications with Delray Beach. He further advised that the Towns met
as a group on Thursday to exchange ideas on how to present the findings
to the various governing bodies. He said Matrix is gathering data and
have been somewhat delayed in this as Palm Beach County has not provided
the information requested in relation to Manalapan and South Palm Beach.
He further said that they are working through this challenge and will be
successful, but as a result the timeline for completion of the study by
Matrix has been extended to, most likely, late March. He added that
there is an article in the paper advising that Palm Beach Gardens is
getting a new fire station at a cost of 2.6 million but has components
that we would not need. Vice Mayor Ganger encouraged residents to
O complete the survey Matrix has provided.
B. Architectural Review & Planning Board
1. Meeting Dates
a. March 24, 2016 @ 8:30 A.M.
b. April 28, 2016 @ 8:30 A.M.
c. May 26, 2016 @ 8:30 A.M.
d. June 23, 2016 @ 8:30 A.M.
e. July 28, 2016 @ 8:30 A.M.
f. September 22, 2016 @ 8:30 A.M.
C. Finance Director
1. Financial Report for January 2016
2. Water Usage as of January 31, 2016
There were no questions regarding the Financial Report or the Water
Usage Report and they were accepted as submitted.
D. Police Chief
1. Activity for January 2016
There were no questions and the report was accepted as submitted.
(�J\, E. Special Counsel Robert Sweetapple.
Attorney Sweetapple presented his report regarding the current state of
litigation and public records which is attached hereto and made a part
of the record.
IX. Items for Commission Action.
A. Ordinance No. 15/9; AN ORDINANCE OF THE TOWN COMMISSION OF
O THE TOWN OF GULF STREAM, PALM BEACH COUNTY, FLORIDA, AMENDING
THE CHAPTER 70 OF THE TOWN CODE OF ORDINANCES, THE GULF STREAM
DESIGN MANUAL, AT ARTICLE IV, SITE DEVELOPMENT REGULATIONS,
4
Town Commission Regular
Meeting & Public Hearing
2-12-16 at 9:00 A.M.
Gi� ELIMINATING SECTION 70-71(c) INCENTIVE FLOOR AREA RATIO;
AMENDING SECTION 70-77, FIRST FLOOR ELEVATION; AND 70-78,
SEAWALL HEIGHT; AMENDING CHAPTER 70, ARTICLE V, AREAWIDE
STANDARDS, DIVISION 1, GENERAL ARCHITECTURAL STANDARDS, AT
SECTION 70-100, ROOF AND EAVE HEIGHTS; SECTION 70-101,
WINDOWS; SECTION 70-105, GARAGES AND ACCESSORY BUILDINGS; AND
SECTION 70-106, COLOR; AMENDING CHAPTER 70, ARTICLE V,
G DIVISION 3, GENRAL LANDSCAPE STANDARDS, SECTION 70-148
PRINCIPLES; AND CREATING A NEW SECTION 70-151; APPLICABILIY
AND PERMITTING; AMENDING CHAPTER 70, ARTICLE V DIVISION 4,
GENERAL OUTDOOR LIGHTING STANDARDS, SECTION 70-166, PURPOSE,
CATEGORIES; AMENDING CHAPTER 70, ARTICLE VI DISTRICT
STANDARDS, SECTION 70-187, TABLE OF DISTRICT STANDARDS;
AMENDING CHAPTER 70, ARTICLE VII, PREDOMINATE ARCHITECTURAL
STYLES, DIVISION 2, SPANISH MEDITERRANEAN REVIVAL STYLE,
SECTION 70-218 ROOFS; AND ARTICLE VII, DIVISION 3, GULF
STREAM -BERMUDA STYLE, SECTION 70-238, ROOFS; PROVIDING FOR
SEVERABILITY; PROVIDING FOR REPEAL OF ORDINANCES IN CONFLICT;
PROVIDING FOR CODIFICATION; PROVIDING AN EFFECTIVE DATE.
(Second reading & adoption)
The Town Clerk read Ordinance No. 15/9 by title. Vice Mayor Ganger moved
for adoption of Ordinance No. 15/9 and Commissioner Orthwein seconded
the motion with all voting AYE at roll call.
B. Ordinance NO. 16/1; AN ORDINANCE OF THE TOWN COMMISSION OF THE
TOWN OF GULF STREAM, PALM BEACH COUNTY, FLORIDA, AMENDING THE
TOWN'S CODE OF ORDINANCES, TO AMEND SECTION 66-397, OPEN LAND
USES, TO ADD ADDITIONAL LANDSCAPING BUFFER REQUIREMENTS FOR
TWO-STORY HOMES WITHIN CERTAIN ZONING DISTRICTS; TO AMEND
SECTION 70-73, TWO-STORY STRUCTURES, TO PROVIDE ADDITIONAL
SECOND -STORY SETBACKS IN CERTAIN ZONING DISTRICTS; TO AMEND
SECTION 70-74, SETBACKS, TO REFERENCE SECOND -STORY SETBACK
CHANGES; PROVIDING FOR SEVERABILITY; PROVIDING FOR REPEAL OF
ORDINANCES IN CONFLICT; PROVIDING FOR CODIFICATION; PROVIDING
AN EFFECTIVE DATE. (Second reading & adoption)
Town Clerk Taylor read Ordinance No. 16/1 by title for adoption. Vice
Mayor Ganger moved to adopt Ordinance No. 16/1 and Commissioner Orthwein
seconded the motion for adoption with all voting AYE at roll call.
C.. Resolution No. 16-1; A RESOLUTION OF THE TOWN COMMISSION OF
THE TOWN OF GULF STREAM, PALM BEACH COUNTY, FLORIDA, OPPOSING
HR 461 THAT SEEKS TO FORCE LOCAL GOVERNMENTS AND THEIR
O TAXPAYERS TO PAY FOR THE COST OF RELOCATING UTILITY EQUIPMENT
ALONG PUBLIC RIGHTS-OF-WAY AND WITHIN PUBLIC UTILITY EASEMENTS
WHEN SUCH EQUIPMENT UNREASONABLY INTERFERES WITH A PUBLIC
ROADWAY MAINTENANCE, IMPROVEMENT, EXTENSION OR EXPANSION
PROJECT; FURTHER URGING THE FLORIDA GOVERNOR AND FLORIDA STATE
LEGISLATURE TO UPHOLD COMMON LAW AND THE CURRNT FLORIDA
STATUTE REQUIRING UTILITY PROVIDERS TO PAY FOR RELOCATION OF
THEIR EQUIPMENT UNDER SUCH CIRCUMSTANCES; PROVIDING FOR AN
EFFECTIVE DATE; AND FOR OTHER PURPOSES.
The Town Clerk read Resolution No. 16-1 by title. Vice Mayor Ganger
advised that these bills have been up for consideration in the
5
Town Commission Regular
Meeting & Public Hearing
2-12-16 at 9:00 A.M.
Olegislature for some time and the Florida League of Cities and others
have been fighting against it. He said that it is AT&T, not FP&L, that
is pushing it. He believes the bill will be passed but added that over a
long period of arguments it has been watered down to the point that all
others who were originally involved have dropped out leaving only AT&T
to pursue it. Vice Mayor Ganger moved to approve Resolution No. 16-1 and
Commissioner Orthwein seconded his motion with all voting AYE at roll
call.
D. Resolution No. 16-2; A RESOLUTION OF THE TOWN COMMISSION OF
THE TOWN OF GULF STREAM, FLORIDA SUPPORTING AND ENCOURAGING
EFFORTS BY THE TOWN OF LAKE CLARKE SHORES AND NEIGHBORING
MUNICIPALITIES TO PROCEED WITH IMPROVEMENTS TO THE CHAIN OF
LAKES, THE OCEAN TO TRAILS INITATIVE AND DEVELOPMENT OF A BOAT
LIFT AT THE C51 CANAL S155 CONTROL STRUCTURE; PROVIDING AN
EFFECTIVE DATE; AND FOR OTHER PURPOSES.
Town Clerk Taylor then read Resolution No. 16-2 by title. Vice Mayor
Ganger moved to approve Resolution No. 16-2 and Commissioner Orthwein
seconded his motion with all voting AYE at roll call.
E. Designating voting delegates to the Palm Beach County League
Of Cities.
Mr. Thrasher explained that in past years the Mayor has been named as
the voting delegate with all of the other Commissioners and the Town
Manager designated as Alternates. Vice Mayor Ganger said that Mr.
Thrasher's relationship to the League of Cities has been very
Ohelpful to Gulf Stream and he is to be commended for the extra work
and time he has put into it.
Commissioner Orthwein moved to designate Mayor Morgan the Voting
Delegate, with each of the other four Commissioners and Town Manager
Thrasher designated as Alternates. Vice Mayor Ganger seconded the
motion and all voted AYE at roll call.
F. Items by Mayor & Commissioners
Mayor Morgan praised Vice Mayor Ganger for his ongoing work with the
Legislature in moving along some amendments to the Public Records
Law. He then asked Commissioner Ganger for an up date.
Vice Mayor Ganger reported that the bill has been passed by 4
Committees and that there are two more committees before it goes to
the floor of the legislature. He was pleased to say that the vote in
the 4 committees that have reviewed the bill is 33 to 3 and in
private conversations with the 3 who voted against it in committee
C) have said they will vote for it when it comes before them on the
floor.
Mayor Morgan reminded that it has been a policy to allow each person
5 minutes under Public Comment. He pointed out that it is not a
question and answer period and that a comment should be able to be
completed within 3 minutes at the most. The Mayor noted that most
other municipalities limit public comment to 2 or 3 minutes and asked
the members of the Commission how each of them felt about changing
the allotted time to 3 minutes each.
A
Town Commission Regular
Meeting 6 Public Hearing
2-12-16 at 9:00 A.M.
OCommissioner Stanley supported reducing the time to 3 minutes
pointing out that there is more business before the Commission than
there was in the past and the Commission wants to hear from as many
of the residents as possible. Reducing the time to 3 minutes will
make it possible to hear from more residents.
Commissioner Orthwein supported 3 minutes remarking that in the past
there had been no limit but when attendance increased it became
necessary to establish limits. She felt that now there has been
experience with the 5 minutes and has become clear that 3 minutes
will be adequate.
Commissioner White stated that inasmuch as the public is allowed to
comment on each item on the agenda as they are addressed, 3 minutes
should be enough under Public Comment.
Vice Mayor Ganger was in favor of limiting public comment to 3
Minutes and hoped it would encourage more persons to express their
thoughts.
Mayor Morgan asked if there was a motion to change the existing
policy and Vice Mayor Ganger moved to change the existing policy of
allowing 5 minutes to each person speaking under public comment to
C; allow 3 minutes to each person speaking under the item on the agenda
entitled Public Comment. Commissioner Orthwein seconded this motion
and all voted AYE at roll call.
X. Adjournment.
Mayor Morgan adjourned the meeting at 10:30 A.M.
Rita L. Taylor
Town Clerk
7
LAW OFFICES OF
SNVEETAPPLE, BROEXER & VARKAS, P.L.
DOUGLAS C BROEKER, P.A.
44 West Flag erSn=4 Ste. 1500
14=4 Florida33130fi1117
Telephone: (305) 374-5623
Faalmile: (305)335.1023
ROBERTA. nTETAPPLE •,•'
DOUGLAS C. BROEKER
ALX&.\DEAD. VARKAS, JR.
KPDISHA D. PHELPS
ALEXANDER D. VARKAS, III
AS[]LEIGH M. GREENE
BERKLEY SWEETAPPLE VITALE
nM[J RAieRD CyUC]lUraA:l¢. ATILQZY
.� 90Aa'1 [FaTF1e0Ovala.e AT:it'Ita!1
February 18, 2015
VIA EMAIL
_ Scott W. Morgan, Mayor
Town of Gulf Stream Commission
100 Sea Road
Gulf Stream, Florida 33483
SWEETAPPLE & VARKAS, Pd.
20 S.E.3"Strw
Boca Rates, Florida 33432-4914
Teiephone: (561) 392-1230
Facsimile: (561) 394-6102
Please Reply To: Baca Ralon
rsweet3pPle@5%e=FPldaw.ro
avarkas@swcetapplelaw.eom
a,;varkL%&%eetapplclaw.com
bvitelcemeetapplelaw.com
ebaHV. &weetgVIclaw.com
dsmithrgsss ectapplelaw.com
Re: Martin O'Boyle, .Ionathan O'Boyle and Christopher O'Hare
Dear Mayor Morgan and Commission Members:
I have been asked to provide a report regarding the ongoing litigation and activities involving
Martin O'Boyle, Jonathan O'Boyle and his law firm, The O'Boyle Law Firm, and Christopher O'Hare.
PAST CONDUCT
1. Loneoort, N.J.
I believe it is important for you to understand that the Town's current disputes are not atypical
for Martin O'BoyIe. A New Jersey Law Journal reports that Mr. O'Boyle entered into a conflict with
the Town of Longport, New Jersey in 2007, when he was cited for a zoning violation. Mr. O'Boyle is
reported to have filed numerous lawsuits individually, through his corporation, Commerce Group
Construction, Inc., and his organization, Citizens for Open Government, LLC. These were lodged
against various individuals, the Town and the press. In the case of Martin F. O'Boyle v. Peter Isen, 2014
C WL 340104 (NJ. Super. A.D.) (a defamation case that Mr. O'Boyle brought and lost) the Superior
Court of New Jersey, Appellate Division, noted:
From September 2007 through early July 2008, plaintiff [Martin O'Boyle] and
members of his family filed multiple requests pursuant to the Open Public
Records Act (OPRA), N.J.S.A. 47:1A-1 to 13. Longport's only clerk worked
part-time, and she did not address the requests within the time required by
statute. At one point, the clerk went to the emergency room because of the
stress she attributed to the flood of OPRA requests. And, in February 2008, the
Mayor Scott Morgan February 18, 2016
Town of Gulf Stream Commission Page 12
Borough's solicitor notified plaintiff that it would not accept any additional
OPRA requests he filed, explaining that the numerous requests were
substantially disrupting governmental services. The solicitor claimed that
Longport had received 190 requests on October 16 and 17 and thirty filed
October 31, 2007.
The Longport dispute included published reports of the flying of planes and banners trailing
messages calling the Mayor a "puppet" and other more cryptic enunciation.
IT. Tennessee
In state court litigation in Tennessee, in the case of New Midland Plaza Associates, et. al. v.
Wachovia, et. al., Case Number &18053 in the Blount County Circuit Court, Fifth Judicial District,
Judge'K Dale Young found that:
O'Boyle's intent, purpose and strategy in pursuing his claims was to conduct
----this.litigation in a manner which had the maximum :financial impact on the----_ - ---
defendants....The purpose and strategy manifested itself in O'Boyle's
repeatedly making arguments and taking positions—irrespective of their
merits—that would maximize the inconvenience and costs to defendants.
More than seven years offrivolous litigation, litigation spawned by the zealous
C temperament of O'Boyle, has placed an extreme burden on the clerk of this
court over and above the everyday course of business
Judge Young also found that Mr. O'Boyle had filed "serial motions" denying he had given
inconsistent testimony, which motions "served dual improper purposes of attempting to re -litigate issues
upon which the Court had previously ruled and unnecessarily increasing the Defendants' costs." The
Court found this conduct sanctionable. An affidavit filed by the trial court noted that it had previously
sanctioned [the Plaintiffs] on two occasions in an amount totaling a quarter of a million dollars and
twice held them in contempt.
III. The Palm Beach County State Attorney
The Palm Beach Post reports that in one month, O'Boyle's company, Sweet Aron Boy Blimp
Co., LLC, submitted 1,328 request to Aronberg and the Office ofthe 19' Judicial Circuit State Attorney
Bruce Colton... that included 874 requests to Bruce Colton, State Attorney on the Treasure Coast, and
C 454 requests to Dave Aronberg, Palm Beach County State Attorney. More than 1,000 requests were
sent over three days, February 25 through 27.
IV. Gulf Stream
Mr. O'Boyle commenced his assault of public records requests on the Town of Gulf Stream in
the spring of 2013, after he was denied certain variance requests for work on his home. Some 400
Requests were followed by approximately 16 lawsuits. Ultimately, in an attempt to put an end to his
LAw Ornm or
SwErrAPFL4 aKOMER & VAKKAS. RL
Mayor Scott Morgan February 1 B, 2016
Town of Gulf Stream Commission Page 13
conduct, the Town settled with Mr. O'Boyle in July 2013, permitting the improvements he sought and
paying him 5180,000.00.
The current onslaught of Public Records Requests and Lawsuits began shortly after the Town
settled with Mr. O'Boyle in July 2013.
Specifically, just one month after the settlement, Mr. Christopher O'Hare began inundating the
Town with public records requests. From late August 2013, when the Town began keeping detailed
logs until the end of the year, Mr. O'Hare averaged in excess of 100 requests per month. By October
2013, just three months after the Town settled Mth Mr. O'Boyle, Mr. O'Hare had filed his first public
records suit. More than one dozen lawsuits had been served on the Town by January 2014.
The O'Boyle Law Firm, which had been formed by Jonathan O'Boyle in Pennsylvania in
November 2013, began operating in Florida in mid-January 2014 and immediately began filing public
records suits against the Town on behalf of both Mr. O'Hare, Mr. O'Boyle and Citizens Awareness
Foundation, Inc.
With dozens of lawsuits pending, Martin O'Boyle, Christopher O'Hare and various individuals
or entities affiliatedivith them continued to make hundreds of public records requests to the Town over
the past 2 %: years. Ultimately, they have made approximately 2,000 public records requests. These have
included numerous requests by Mr. O'Hare using pseudonyms mocking Town officials such as: Gonna
White, Groan Orthwein, Bil ly Trasher and Bobby Gangrene. Requests have also been routinely made by
email in high volumes and outside of regular business hours, malting it nearly impossible for Tot4Tr staff
to keep up. This includes 40 requests made in a 4 hour period on a Sunday.
V. Citizens Awareness Foundation, Inc.
During July of 2014 I received an unsolicited email from Joel Chandler, a former Director of
Citizens Awareness Foundation, Inc, ("CAM, an alleged Florida not-for-profit Company. Mr.
Chandler advised and swore in an affidavit that CAM and The O'Boyle Law Firm were established and
funded by Martin O'Boyle. Both were located in the O'Boyle offices and run by O'Boyle, his
employees, and designees. The ultimate goal of the enterprise was to file at least one hundred public
records lawsuits per month against public entities and State contractors throughout Florida All
litigation would then be fed to The O'Boyle Law Firm The law firm would then demand and collect
more in fees than it had expended in billable time in what Mr. Chandler described as the "windfall
scheme." Defendants would find it less expensive to settle than to engage counsel or litigate. (See
Chandler Affidavit and exchange of emails attached as composite Exhibit "A').
As a result of these alleged activities, Mr. Chandler quit his job and stated that he was notifying
victims of this conduct. He further indicated that Mr. O'Boyle personally caused hundreds of public
records requests and two lawsuits to be filed against the Town of Gulf Stream on behalf of CAFI
without Mr. Chandler's knowledge or approval.
Public records reveal that on behalf of CAFI as of one year ago, the O'Boyle Law Firm, has filed
Cmore than 100 lawsuits against various government entities, government contractors and not -far -profit
:.AW OFFICESCF
S W EL f.1Yi'LL aRCEKrR k VARR AS,? L
Mayor Scott Morgan February 19, 2016
Town of Gulf Strcam Commission Page 14
entities (including the Area Agency on Aging of Palm Beach Treasure Coast, Homeless Coalition of
Palm Beach County and the Hope Foundation for Autism). The Florida Bar News and other
publications have now extensively reported this conduct as a scam and the legislature is discussing
proposed changes to the Florida Statutes.
VI. Pendine Litieation
Cuaentiypending against the Town are nearly 40 public records cases which have been filed by
Mr. O'Hare, Mr. O'Boyle or entities owned or controlled by O'Boyle. These lawsuits are largely being
advanced by The O'Boyle Law Firm. Tn essence, Mr. O'Hare and Mr. O'Boyle have filed thousands of
Public Records Requests inundating the Clerk of the Town to frustrate her ability to comply with the
requests. Thereafter suits are brought complaining about the speed and accuracy of the responses and
sceldng attorney's fees and costs that the current version of the Public Records Act only permits a
plaintiff to recover. The plaintiffs have not succeeded on any of their public records claims and have
dismissed several of them after motions for sanctions were filed. The only case to have gone to
conclusion was won by the Town and has been appealed by Mr. O'Boyle. We intend to notice the
remainder of the cases for trial as soon as possible. -- ---
Various additional claims have been brought by Mr. O'Hare and Mr. O'Boyle against the Town
and its elected officials, employees and contractors including Mayor Morgan, Bill Thrasher, Special
Magistrate Lara Donlon, Chief Ward and Marty Minor with Urban Design Kilday for alleged Federal
C and State civil rights violations. These claims are being handled by insurance counsel. The Town has
obtained favorable dismissals of several of these suits, one of which was just affirmed on appeal by the
Federal Appeals Court and resulted in a favorable fee award against Mr. O'Boyle for his frivolous
filing. None of these claims have been decided in favor of Mr. O'Hare or Mr. O'Boyle.
Lawsuits have been Sled against the Town's attorneys, including three suits against my firm or
me personally and a lawsuit against Joanne O'Connor and Skip Randolph. Particularly frustrating is the
fact that one of these lawsuits arose after Mayor Morgan, Ms. O'Connor and I met to confidentially
discuss a potential settlement with Mr. O'Hare and his counsel, Louis Roeder and Mark Hanna. Mr.
O'Boyle has sued complaining that this settlement conference violated the Sunshine Law even though
Mayor Morgan was the only city government representative in attendance. Ethics Complaints have been
brought against me, Mr. Randolph and Mayor Morgan. These have all been dismissed.
Mr. O'Boyle has repeatedly flown planes towing banners over West Palm Beach and Gulf
Stream denigrating the Town's attorneys and officials.
More recently, the attempts to particularly target the attorneys defending the public records cases
has intensified as some 200 records requests were sent to almost every attorney at Mr. Randolph's law
firm in late November and December apparently by Mr. O'Hare.
VII. conclusian
In 35 years of practicing law and litigating cases throughout the State of Florida and the United
States I have never encountered this type of a concerted pattern of abusive conduct directed at a local
LAw OFP= w
SWnTAPPLL BROEKEa hVARXAS, P.L.
Mayor Scott Morgan February 18. 2016
Town of Gulf Stream Commission Page 15
government. It is clear to me that the O'Boyles and Mr. O'Hare engage in this conduct to cause the
Towtt to accede to their demands. 1 hope that my report has helped you understand the nature and scope
of the litigation and actions that the Tovm has been defending.
RAS:cjb
Enclosures
Regards.
ROBERT A. SWErTAPPLE
inw omcEs or
SWEETAPPLE, 9FOEIER h VARR.L. i 1.
AFFIDAVIT OF JOEL EDWARD CHANDLER
BEFORE ME, the undersigned authority, personally appeared JOEL CHANDLER, who
after being duly sworn, deposes and says that:
1. My name is JOEL CHANDLER,
2. I am over eighteen (1 B) years of age.
3. I am a resident of Polk County, Florida.
4. I have personal knowledge of every assertion made in this affidavit,
5. Citizens Awareness Foundation, Inc., (herein "CAFI"), was formed as a Florida
not-for-profit corporation by Martin O'Boyle in concert with his son, Jonathan
O'Boyle.
6. Jonathan O'Boyle is an attorney admitted in Pennsylvania and New Jersey, but not
admitted to practice in Florida.
7. In January 2014, I was solicited by Martin O'Boyle to lead a not-for-profit corporation
that was, he said, intended to promote open government. That not-for-profit
corporation was created at Martin O'Boyle's direction and became known as the
"Citizens Awareness Foundation, Inc." or "CAFE'
S. During my discussions with Martin O'Boyle, wherein he sought to hire me to serve as
the leader of CAFE, we explicitly agreed that CAFE would have an independent Board
of Directors; that the Board of Directors would be entirely free from the influence of
Martin O'Boyle or the O'Boyle Law Firm; that I would have absolute and sole
discretion regarding the commencement and resolution of open government litigation
on behalf of CAR, and; subject only to the independent Board of Directors, I would
have the authority to select and retain law firms for the purpose of engaging in open
government litigation.
EXHIBIT
9. During January or February of 2014, I participated in a telephone conversation with
Martin O'Boyle and Robert "Bob" Tweel, a tax attorney from West Virginia. Martin
O'Boyle and I discussed with Mr. Tweel the absolute necessity that CAFI be a
legitimate not-for-profit entity. This included, but was not limited to, the requirement
that CAFI use a variety of law firms to represent it so as to avoid the appearance of
self-dealing.
10. Martin O'Boyle indicated to Mr. Tweel and to me that he was going to loan all
necessary monies to fund CAFI and, after 501(c)(3) status was acquired, write off as a
charitable donation all of the monies he had loaned to CAFI. After leaving this
meeting I was particularly encouraged that Martin O'Boyle was genuine in his interest
to establish a bona fide not-for-profit entity of which I would serve as the Executive
Director and that CAFI would afford me the opportunity to more effectively continue
my work as a civil rights activist and advocate for open government.
11. Martin O'Boyle appointed Brenda Russell, William Ring and Denise DeMartini to the
CAFI Board.
12. Brenda Russell is Martin O'Boyle's long time secretary. She was never present for
meetings. In fact, no formal meetings of the Board were ever called or held. For a brief
time, Brenda Russell collected my travel and business receipts, all of which were
subject to the approval of Martin O'Boyle,
13. William Ring is Martin O'Boyle's longtime business associate and corporate attorney.
14. Denise DeMartini is the long-time employee of Martin O'Boyle or entities that he
controls.
15. All of my negotiations for employment by CAFI were with Martin O'Boyle. At no
time did I engage in any negotiations regarding the details of my employment,
including my compensations, with anyone other than Martin O'Boyle.
16. Al Martin O'Boyle's direction 1 drafted and signed a proposed memorandum of
understanding regarding my employment by CAFI. l have never received a copy of the
proposed memorandum of understanding signed or approved by the board of CAFI.
17. 1 served as the Executive Director of CAFI for approximately five (5) months, through
the end of June 2014.
18. 1 resigned because of repeated instances of conduct perpetuated by Martin O'Boyle,
Jonathan O'Boyle, William Ring, Denise DeMartini, and some of the attorneys at the
O'Boyle Law Firm, P.C., Inc., (herein the "O'Boyle Law Firm"), as set forth herein,
which I believe may be criminal, fraudulent and unethical.
19. My relationship with the O'Boyle Law Firm was not limited to my capacity as the
Executive Director of CAFI. As the individual plaintiff in several open government
lawsuits, l had retained the O'Boyle Law Firm as my personal legal counsel.
20. My communications with the attorneys of the O'Boyle Law Firm, including Jonathan
O'Boyle, affected both CAFI and me, as an individual client.
21. Martin O'Boyle and Jonathan O'Boyle told me that Martin O'Boyle was funding the
O'Boyle Law Finn.
22. Martin O'Boyle told me that he was also funding CAFI.
23. The Martin O'Boyle business entities, including Commence Group, Inc., CAFI, and the
O'Boyle Law Firm operated from the same physical location and were controlled by
Martin O'Boyle.
24. Despite assurances that CAFI would be independent and not-for-profit, Martin
O'Boyle and the O'Boyle Law Firm used CAF1 for the sole purpose of generating
attorney's fees for the O'Boyle Law Firm.
25. Throughout my tenure with CAFI, I repeatedly demanded that lawsuits not be filed or
settled without my direct authorization.
26. In spite of Martin O'Boyle's initial assurances to the contrary, I was not permitted to
retain legal counsel on behalf of CAFI, other than the O'Boyle Law Firm. William
Ring, CAFI's President and Martin O'Boyle's proxy, communicated this to me.
27. On numerous occasions, I learned that the O'Boyle Law Firm, on behalf of CAFI, had
filed lawsuits, without my knowledge or authorization.
28. The O'Boyle Law Firm routinely settled cases without written fee agreements,
contingency agreements or closing statements. No accountings of the monies received
were provided to me despite my repeated requests for that documentation.
29. Repeatedly, 1 advised Martin O'Boyle, William Ring and Jonathan O'Boyle that my
other personal attomeys had advised it was a serious Bar violation to disburse
settlement funds without client approval or closing statements.
30. Despite my protests, the O'Boyle Law Finn continued to file and settle lawsuits on
behalf of CAFI and to collect and keep settlement payments. At no time was I ever
presented with any form of accounting for legal fees or the disbursement of settlement
payments.
31. During the O'Boyle Law Firm's representation of CAFI and me, l was personally
present, or present by telephone, at numerous O'Boyle Law Firm meetings. Denise
DeMartini, Martin O'Boyle's executive assistant and Director of CAFI, conducted
these aw firm meetings. During these meetings, and in my presence, many pending
cases were discussed. These discussions included the details of cases to which neither
CAFI nor I were parties. Denise DeMartini is not a member of the Florida Bar.
32. It became commonplace for Martin O'Boyle to express his opinions and to offer his
advice with respect to litigation strategies and on the conduct of CAFI lawsuits as well
as the cases of other firm clients. Jonathan O'Boyle actively participated in these
discussions and, in my presence, directed the work of O'Boyle Law Finn attorneys and
made litigation decisions.
33. During the course of my employment I learned that Martin O'Boyle directed his
secretary to file in excess of 100 public records requests to the Town of Gulf Stream,
under the pretense that these were being filed on behalf of CAFI. He also ordered that
lawsuits be filed by CAFI against the Town of Gulf Stream. This was done without my
authority and litigation was filed over my objection.
34. When I complained about the fact that Martin and Jonathan O'Boyle were not
honoring the commitment that I would have sole authority to make public records
requests and conduct litigation, I was told by William Ring that this was "the way Big
Daddy wants it", i.e., Martin O'Boyle. Otherwise, "Big Daddy will turn-off the spigot
of money".
35. Jonathan O'Boyle advised me that he was not a member of the Florida Bar but would
be become a member within days. During the five months that I worked with CAR,
Jonathan O'Boyle worked full-time at the O'Boyle Law Firm providing legal advice,
directing the administration of cases, and assuming responsibility for cases.
36. The O'Boyle Law Firm and Jonathan O'Boyle prosecuted and filed some cases
without my permission and settled some cases without my knowledge or consent.
37. No retainer agreements were ever entered into with me on behalf of CAFI. No
contingency agreements were entered into with me on behalf of CAFI. No closing
statements were ever presented to me and it appears that all monies that were solicited
from defendants were paid directly to the O'Boyle Law Firm.
38. Martin O'Boyle, through his entities, funded all of the filing fees and expenses of
CAFI as well as the expenses of the O'Boyle Law Firm. CAFI has now filed scores, if
not hundreds, of cases against state and local agencies throughout Florida as well as
various state contractors.
39. The employees of all of Martin O'Boyle's entities, including The Commerce Group,
Inc., CAFI and the O'Boyle Law Firm were shared. Denise DeMartini and William
Ring worked for Martin O'Boyle, CAFI and the O'Boyle Law Firm.
40. Although Martin O'Boyle named Denise DeMartini a director of CAFI, she also
directed the operations of the O'Boyle Law Firm and conducted law firm meetings.
41. Denise DeMartini repeatedly stated that CAFI was required to file at least one hundred
lawsuits a month; that all lawsuits had to be directed to the O'Boyle Law Firm for
prosecution, and; that as my direct supervisor, she would evaluate my performance
based upon my ability to deliver a minimum of twenty-five case per week to the
O'Boyle Law Firm,
42. Through William Ring, Martin O'Boyle insisted that the O'Boyle Law Firm handle all
litigation.
43. Martin O'Boyle told me he had unlimited money to pay filing fees for CAFI cases and
I was to file as many cases as possible.
44. When I asked Martin O'Boyle to quantify how many cases he was willing to finance
he said it was virtually unlimited. When I again tried to clarify by asking him if he was
willing to finance three thousand (3,000) cases in a single year, he said "sure,"
45. When I learned it was the policy and practice of the O'Boyle Law Firm to demand
settlement of cases against government entities and state contractors for attorney's fees
in excess of the fees actually earned I was livid. In fact, I confronted William Ring,
Denise DeMartini and Jonathan O'Boyle in May of 2014 and stated in unequivocal
terms that I would resign if it didn't stop.
46. In one telephone conversation with Jonathan O'Boyle I warned him at least six times
that I was going to resign and that I objected to Denise DeMartini's demands that 1
produce 100 cases per month, her control of the O'Boyle Law Finn and the windfall
scheme of collecting more monies in attorney's fees from defendants, than had
actually been earned.
47. Despite these complaints, William Ring, Denise DeMartini and Jonathan O'Boyle told
members of the firm that I had authorized the windfall scheme. When I learned of this
I confronted those involved. Nick Taylor, Esquire confirmed that despite my objection,
the windfall scheme would continue as firm policy. Shortly thereafter, l announced my
resignation.
49. Ryan Witmer and Giovanni Mesa announced they were also going to resign.
49. William Ring announced he was going to become a member of the O'Boyle Law Firm
at about that time.
50. After I resigned, Martin O'Boyle contacted me by telephone and demanded that I
withdraw an email I had sent to Nick Taylor regarding Jonathan O'Boyle's unlicensed
practice of law and Jonathan O'Boyle's authorship of the windfall scheme. During that
call, which was my last conversation with Martin O'Boyle, he repeatedly threatened to
bring great "unpleasantness" to my life if I failed to renounce my email to Nick Taylor.
51. Thereafter, Martin O'Boyle repeatedly attempted to contact me by telephone and email
seeking my assistance to facilitate CAFI in filing additional lawsuits,
52. After resigning from CAFI I sent an email to numerous newspaper and television news
reporters announcing my resignation. I copied that announcement to dozens of
individuals, including Robert Sweetapple, Esquire, to notify them of my disassociation
and disapproval of the O'Boyles and their activities.
53. Within a few days of my resignation from CAFI, I granted an interview with a reporter
from the Lakeland Ledger and provided many of the details contained within this
affidavit.
54. Prior to emailing Robert Sweetapple, I had never met him, spoken to him, nor had he
or any members of his firm contacted me.
55. Prior to my emailing the law firm of Jones Foster, I had never had any contact with
Joanne O'Connor, Esquire, or any member of that law firm.
56. My subsequent contact with Robert Sweetapple and Joanne O'Conner was entirely the
result of own initiative.
57. I sent my email to Robert Sweetapple because I knew he represented the Town of Gulf
Stream, which I believed was being victimized by Martin O'Boyle and the O'Boyle
Law Firm and I was concerned that the conduct of Martin O'Boyle and the O'Boyle
Law Firm might be illegal and fraudulent.
58.1 believed that I had a duty to make all victims, including the Town of Gulf Stream,
aware of what I learned during my association with Martin and Jonathan O'Boyle. For
example, Martin O'Boyle's orchestration of more than one hundred public records
requests being served upon the Town of Gulf Stream, allegedly under the name of
CAFI, but without my authorization; Martin O'Boyle's direction that lawsuits be filed
by the O'Boyle Law Firm in the name of CAFI against the Town of Gulf Stream but
without my authorization, and; in spite of my objections, Martin O'Boyle's use of
CAFI as a weapon in his personal vendetta against the Town.
59. Prior to contacting Robert Sweetapple to make him aware of my concerns regarding
Martin and Jonathan O'Boyle's conduct, I met with numerous private attorneys. As a
result of those meetings I concluded that I had a duty to disassociate myself from the
O'Boyles and to make full disclosure of any illegal and fraudulent activities. I have
also contacted numerous other victims and their attorneys to advise them of the
conduct of the O'Boyles and to provide them with evidence of such conduct.
60. Before speaking with Robert Sweetapple on the phone I spoke with Joanne O'Connor
by telephone and made her aware of the misconduct.
61. I then provided to Robert Sweetapple evidence of what I believe may be fraudulent
and criminal conduct as well as a detailed chronology of events.
62. Thereafter, I spoke with Robert Sweetapple and gave him permission to meet with me
and to take a voluntary sworn video statement concerning my involvement with Martin
O'Boyle, Jonathan O'Boyle, CAFI and the O'Boyle Law Firm.
63. At all times Robert Sweetapple made me aware of the application of the lawyer -client
privilege, both as it pertained to CAFI and to me personally. I determined, based upon
independent legal advice, that [ was fully permitted and had a duty to disclose what I
believe to be the criminal and fraudulent conduct of Martin O'Boyle, Jonathan
O'Boyle, CAM and the O'Boyle Law Firm. I also voluntarily waived privileged
matters that arose from the joint representation by the O'Boyle Law Finn.
64. In spite of the many contrary assurances made by Martin O'Boyle to me, including the
exercise of my independent judgment and meaningful economic resources to be used
to promote the public's right to access government records and meeting, in reality
CAM's sole purpose is to serve as an exclusive in-house mechanism whereby the
O'Boyle Law Firm can generate legal fees by filing hundreds of open government
lawsuits.
65. The egregiousness of the scheme was exacerbated by the O'Boyle Law Firm's policy
of demanding excessive and unearned legal fees from defendants as a condition of
settlement.
66, Simply put, CAM is a profit -generating scheme funded by Martin O'Boyle to produce
fees for his son's legal practice.
67. Allegations that Joanne Otonner, Robert Sweetapple or their firms purposely
solicited and obtained confidential information from me is false. The allegation that
this was done to gain an unfair advantage in litigation is further false.
68. The information that I provided to Robert Sweetapple and Joanne O'Connor was not
intended to provide an unfair advantage to the Town of Gulf Stream, but to make the
Town and all other victims aware of what I believe to be the fraudulent, criminal and
professionally unethical conduct of Martin O'Boyle, Jonathan O'Boyle, CAM and the
O'Boyle Law Firm,
69. Robert Sweetapple and Joanne O'Connor did not solicit privileged information from
me. I voluntarily contacted them and made my own determination, after meetings with
10
independent counsel, as to what information and documents to provide to victims.
70. My sole motivation for contacting the media, victims and their attorneys, proving
evidence, inviting the taking of my sworn statements and authoring this affidavit is to
protect the essential civil right of all Floridians to know what their government is
doing in their name and at their expense. It is my considered opinion that the
unconscionable conduct of Martin O'Boyle, Jonathan O'Boyle, CAM and the O'Boyle
Law Firm serves as an example of the abuse of our legal system and will be used by
opponents of open govermnent as an excuse to limit the public's right to know.
FURTHER AFFIANT SAYETH NAUGH
JO ANDLER
SWORN TO AND SUBSCRIBED before me thisc�2�7 day of October, 2014.
,
;; �e�"bl,Fi AM6ER COLSOR KELLY
Holary PUNIC • Slala of Flmlda
' ` My Comm. Esplres May 71, 2015
,•�e61 Commission M EE 166909
Personally known
Produced Identification �.77
[denlification produced: �_ �Jt
C,
ARY PUBLIC
Printed Name of Notary,/
My Commissions Expires: no -y
Page 1 of 1
From: 'Ryan Witmer"<rwitmer@commercc-group.roav
Date: Tuesday, January 14, 2014 6:27 PM
To: "Joel Chandler" <joel.chendler@fogwatch.org>
Subject: RE: New case
Joel - regarding your second question below, " how many cases are your guys able to take
where you're paying the filing fees?` - what do you have in mind?
Ryan L Witmer, Esq.
1280 West Newport Center Drive
Deerfield Beach, FL 33442
Office: 954-574-6885
Cell: 717-201-3097
Fax: 954-360-0807
RWitmer@commerce-aroup.com
-----Original Message -----
From: Joel Chandler [mailtojoel.chandler@fogwatch.org)
Sent: Sunday, January 12, 2014 4:08 PM
To: Ryan Witmer
Subject New case
I have been having technical issues with DropBox and was just now able to send you a like to
the records and videos we discussed yesterday. Please confirm your access to those files.
At some point I'd like to talk again with you about our work. One obvious question that comes
to mind is how many cases are your guys able to take where you're paying the filing fees?
Joel Chandler
(863) 660-4244
ioel.chandier@fogwatch.org
www.FogWatch.org
7!1 Fnnt d
Page I of 3
From: "Ryan Witmer" <rwinner@commcrce-group.cum>
Date: Wednesday, January 15, 2014 9:59 AM
To: "Joel Chandler" <joel.cbandlcrra fogwatch.otg>
Subject: RE: New case
Joel - is there a good time to chat this afternoon?
Ryan L Witmer, Esq.
1280 West Newport Center Drive
Deerfield Beach, FL 33442
Office: 954-574-6885
Cell: 717-201-3097
Fax: 954-360-0807
RWitmer@commerce-group.com
- Original Message ----
From: Joel Chandler [mailtojoel.chandler@fogwatch.org]
Sent: Tuesday, January 14, 2014 8:14 PM
To: Ryan Witmer
Subject Re: New case
Well, that's an interesting question. In the Fall of 2012 an attorney asked me to come up with
public records cases with a very specific set of facts and I was able to bring him 101 cases in
the space of about six weeks. Each case had nearly perfect facts and was what I refer to as a
"triple A" or a "kill -shot"
What I'm trying to gauge is how many cases you guys are comfortable doing on a contingency
basis if 1.) you are fronting the filing fees; 2.)the cases have perfect facts; 3.) the denials are
either clearly stated in writing or video records if they are in person; 4). the plaintiff is ideal
(willing to settle or go as far as the attorneys want - no media issues, etc.). We need to figure
out the economics of this - who gets paid and how - and then how many cases we want to do
and roll with it.
The alternative to filing fees may be creating a state not-for-profit with no assets, income or
bank account and filing for indigent status. I am confident that we would have to litigate that
issue and it would go up on appeal. Once the establishment figured out what we are trying to
do they would expend enormous resources to stop us. But if we puled it off there would be no
limit to the number of cases that we could file.
The less conspicuous method is just to pay the filing fees and go for the throat and get paid
7l1611M A
Pagc 2 of 3
quickly.
Joel Chandler
(863) 660-4244
ioel.chandler@fogwatch.org
www.FogWatch.org
On Jan 14, 2014, at 6:27 PM, Ryan Witmer <naitmer@commerce-group com> wrote:
> Joel - regarding your second question below, " how many cases are your guys able to take
where you're paying the filing fees?" - what do you have in mind?
> Ryan L. Witmer, Esq.
> 1280 West Newport Center Drive
> Deerfield Beach, FL 334_4_2
> Office: 954-574-6885
> Cell: 717-201-3097
> Fax: 954-360-0807
> RWitmer@commerce-group.com
> ----Original Message-----
• From: Joel Chandler [mailtojoel.chandler@fogwatch.org)
> Sent Sunday, January 12, 2014 4:08 PM
> To: Ryan Witmer
> Subject New case
> I have been having technical issues with DropBox and wasjust now able to send you a like to
the records and videos we discussed yesterday. Please confirm your access to those files.
> At some point I'd like to talk again with you about our work. One obvious question that
comes to mind is how many cases are your guys able to take where you're paying the filing
fees?
> Joel Chandler
> (863) 660-4244
> joel.chandler@fogwatch.org
> www.FogWatch.org
7/1 Ann 1 d