HomeMy Public PortalAboutChandler Transcript pt 1- 2/24/161
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 9:14-cv-81250-KAM
MARTIN E. O'BOYLE,
Plaintiff,
-vs-
ROBERT A. SWEETAPPLE AND
MAYOR SCOTT MORGAN,
Defendants.
February 24, 2016
1
DEPOSITION OF JOEL CHANDLER
Taken By Counsel for Defendant, Sweetapple
Volume 1 of 2
(Pages 1-195)
Wednesday, February 24, 2016
10:30 a.m. - 4:50 p.m.
Esquire Deposition Solutions
4927 Southfork Drive
Lakeland, Florida
Reported By:
Megan M. Soria
Notary Public
State of Florida at Large
Esquire Deposition Solutions - Tampa Office
Phone - 813.221.2535, 800.838.2814
Esquire Job No. 118775
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 2
MEW-M-T]_�_k
2 DANIEL DESOUZA, ESQUIRE
DeSouza Law, PA
3 1515 North University Drive, Suite 209
Coral Springs, Florida 33071
4 954.780.8262
5 On Behalf of Plaintiff
(Appeared via telephone conference call)
6
7 JOSHUA A. GOLDSTEIN, ESQUIRE
Cole, Scott & Kissane, PA
8 222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
9 561.383.9200
10 1 On Behalf of Defendant, Sweetapple
11
12 HUDSON C. GILL, ESQUIRE
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, PA
13 2455 East Sunrise Boulevard, Suite 1000
Fort Lauderdale, Florida 33304
14 954.463.0100
15 1 On Behalf of Defendant, The Town of Gulf Stream
16 LOUIS ROEDER, III
Law Office of Louis Roeder
17 7414 Sparkling Lake Road
Orlando, Florida 32819
18 407.352.4194
19 1 On Behalf of Chris O'Hare
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 3
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
4
1 Deposition was taken before Megan M. Soria, Court
2 Reporter and Notary Public in and for the State of
3 Florida at Large, in the above cause.
4 - - - - - - - - - -
5 THE COURT REPORTER: Do you swear or affirm that
6 the testimony you're about to give will be the truth,
7 the whole truth, and nothing but the truth?
8 THE WITNESS: I do.
9 THE COURT REPORTER: Thank you.
10 THEREUPON,
11 JOEL CHANDLER,
12 having been duly sworn or affirmed, was examined and
13 testified as follows:
14 DIRECT EXAMINATION
illi=fe3•1KRAwe[GymlftVON Ila
16 Q. Good morning, Mr. Chandler. My name is Joshua
17 Goldstein from the law firm of Cole, Scott, Kissane. I
18 represent Robert Sweetapple.
19 MR. DESOUZA: Josh, you're going do have to speak
20 up.
21 MR. GOLDSTEIN: No problem.
22 BY MR. GOLDSTEIN:
23 Q. I represent Robert Sweetapple in this matter.
24 I'm going to ask you a series of questions today, not
25 trying to trick you, not trying to get you to answer
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 5
1 something you don't know. If you don't understand my
2 questions, or if I tend to mumble, or if I swallow my
3 words, please feel free to ask me to repeat the
4 question.
5 A. Okay.
6 Q. Can you state your name for the record.
7 A. Joel Edward Chandler.
8 Q. How do you prefer to be addressed?
9 A. Joel is fine.
10 Q. I assume you have been deposed before.
11 A. I have.
12 Q. Just as a reminder, we have a court reporter here
13 today. We also have Mr. DeSouza over the phone.
14 Therefore, it's imperative for you to wait for me to
15 finish asking my questions, and I will do my best to
16 wait for you to finish your answers, so we don't talk
17 over each other; that's fine?
18 A. Sure.
19 Q. In addition, with Mr. DeSouza over the phone, he
20 can't see you nodding your head yes or no, and the court
21 reporter can't take that down, so your responses need to
22 be verbal. So if it's a yes or no question, your answer
23 should be yes or no.
24 A. I understand.
25 Q. If at any time you need to take a break or use
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 6
1 the restroom, let us know. I'm happy to take a break
2 for that.
3 A. I appreciate that.
4 Q. What is your current address?
5 A. 1355 Forest Park Street, Lakeland, Florida 33803.
6 If I go too fast, let me know.
7 Q. Is that your primary residence?
8 A. It is.
9 MR. DESOUZA: Josh, I can hear Joel just fine,
10 but you tend to trail off on the questions a little
11 bit. I don't know if you can get a little closer to
12 the mic.
13 MR. GOLDSTEIN: I will look at the phone when I
14 ask.
15 MR. DESOUZA: Like I said, I can hear Joel just
16 fine.
17 MR. GOLDSTEIN: I will look towards the phone
18 when I ask my questions.
19 MR. DESOUZA: Thanks.
20 BY MR. GOLDSTEIN:
21 Q. Did you do anything to prepare for your
22 deposition here today?
23 A. I did.
24 Q. What did you do?
25 A. I read some notes.
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 7
Q. What are the notes that you reviewed?
A. I reviewed some e-mails, I read the transcript of
the 2004 examination that I did a few months ago. I
re -read most of the sworn statement that I gave to Bob
Sweetapple back in 2014, and reviewed a timeline that I
created for my own purposes in preparation for that
sworn statement. And then I also reviewed some personal
notes that I made, as well as a number of e-mails.
(Enter Mr. Roeder.)
BY MR. GOLDSTEIN:
Q. And the notes that you reviewed or the timeline,
what was the timeline based upon? How did you create
the timeline?
A. From e-mails and notes that I made for myself
when I was employed for the Citizens Awareness
Foundation, and then also from e-mails and notes that I
created after I resigned my position there.
Q. And these were e-mails and notes that were done
contemporaneously when you were employed and not
employed?
A. Yes. I would refer to them as primary documents.
They were original documents that I created
contemporaneously with the events. And I used a
software program that allowed me to put it into a
timeline so it was easier to visualize.
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 8
Q. Are you presently employed?
A. Not in any traditional sense of the word. I
prefer to describe it as being self -unemployed.
Q. Self -unemployed?
A. Yes.
Q. What do you mean by that?
A. I'm a civil rights activist. I don't get a
paycheck. I don't work for anybody in particular.
Q. And so you have never been contracted by someone
to help with whatever civil rights interest they need
assistance with?
A. No. I don't think that would be -- I wouldn't
say I have ever been contracted with anybody, not that I
can think of. I mean, from time to time, I will be
contacted by attorneys. I have done some consulting
work with law firms periodically. Very often I'm not
compensated for that. Sometimes I am. Only one time
that I can remember, off the top of my head, have I ever
been paid by a civil rights organization, and that was
for just a project that I worked on. It was with the
Council on American Islamic Relations.
Q. How long ago was that?
A. That was before I went to work for the Citizens
Awareness Foundation. They contracted with me to do --
they got a grant, and part of that grant was to be used
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JOEL CHANDLER Volume 1 of 2
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February 24, 2016
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1 to pay me. I think I was paid $2,500. And I basically
2 did some public records research. They have staff
3 attorneys and I was consulting with them on how to
4 better access public records. There were several civil
5 rights issues that relate to Muslim -Americans that they
6 asked my help with, which I was delighted to do. In
7 fact, I had actually done quite a bit of work with them
8 prior to that without being compensated. That was just
9 a one-time thing.
10 I can't recall ever actually receiving any
11 remuneration from any other civil rights organizations
12 except a couple times I think I got a free lunch from an
13 organization called the Poor Minority Justice
14 Association. I have worked with them more than any
15 other civil rights organization. I have also done some
16 work for the ACLU but it was not compensated.
17 Q. You said Poor and Minority...
18 A. Poor and Minority Justice Association, PMJA, they
19 are a very small, primarily African-American
20 organization here in Polk County. And as I say, I have
21 worked with them, have not gotten any compensation other
22 than one of their members owns a small soul food
23 restaurant, and I have eaten there a couple times on the
24 house.
25 Q. In terms of being a civil rights activist, what
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
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1 type of civil rights would you believe you're an
2 activist for?
3 A. well, generally speaking --
4 MR. DESOUZA: Sorry to interrupt. I didn't hear
5 the question.
6 MR. GOLDSTEIN: I asked in terms of being a civil
7 rights activist, what type of civil rights would he
8 say he's an activist for?
9 MR. DESOUZA: Thank you.
10 A. Broadly speaking, constitutional rights, federal
11 and state constitutional rights, also generally
12 speaking, I would say social and economic justice
13 issues. My particular area of interest is poor minority
14 rights issues, which is why I have worked so much with
15 the PMJA, Poor and Minority Justice Association.
16 My area of expertise, or I guess the reason I get
17 involved with organizations -- and I have worked with
18 many other organizations as well, is I have some level
19 of experience with access to public records. And so I
20 very frequently will work with organizations to try to
21 help them better understand how to access public
22 records, what sort of records they can get to try to
23 help them navigate obstructions that are very often put
24 up in their effort to get access to public records.
25 I have worked with religious organizations. I
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JOEL CHANDLER Volume 1 of 2
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work with social justice organizations, gender equality
organizations. So my real interest is people being
treated fairly with dignity, and so I take exception to
generally the establishment that doesn't treat people
fairly, particularly here in Polk County at the hands of
our Sheriff.
For example, when the Sheriff was sending
undercover minority deputies in to spy on
African-American churches, or when the State Attorney
suggested they use a peaceful civil rights rally as an
opportunity for a K9 exercise. So what I do is, I get
the e-mails and the documents from those organizations
that expose their unsavory conduct.
In addition to that, just recently, for example,
I also work with government agencies. I did a seminar
just a few weeks ago for 9 or 10 local agencies up in
Levy County. There were a couple of sheriffs that were
there. There were a number
of
-- they were
primarily
law enforcement agencies.
So I
was asked --
this is the
second time I have done this. I was asked to go up
there and visit with them about my experiences as an
advocate for open government, primarily trying to
describe to them about how I think they should behave in
a way that would help them avoid public records
litigation. So I try to help them avoid litigation.
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JOEL CHANDLER Volume 1 of 2
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In addition to that, they wanted my perspective
on the best way for law enforcement to interact with
activists. The first time I went up there was during
the kerfuffle that was going on in Ferguson when a lot
of local agencies were concerned they might have similar
situations going on in their jurisdictions. They asked
me to come and talk to them about -- I think the way
they put it was, "Tell us how not to be on YouTube."
I also work loosely with organizations that are
-- what I would describe as first amendment type
organizations, Photography is Not a Crime, for example.
I have helped them a number of times to try to get
access to public records.
Q. How did you become involved in or find yourself
having an expertise in public records requests?
A. Back in 2007, I made a public records request. I
had been reading in the newspaper every year in Florida,
now it's a national observation, what they call Sunshine
Week. It's scheduled to coordinate loosely with the
birthday of James Madison, who was widely regarded as
the father of open government in the United States.
And every year, or most years, various members of the
Florida Newspaper Editors Association, newspapers around
the state, would write editorials or articles about open
government, the importance of open government. And one
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1 of the things they very often would do in coordination
2 with the Florida First Amendment Foundation, which I'm a
3 member of, they would send out reporters incognito. So
4 for example, they might send a reporter from Lakeland
5 down to Sarasota, or from Miami to Tampa, to make public
6 records requests. Then they would write stories about
7 how they were treated, did they get access to the
8 records the way they were supposed to. I was intrigued
9 by that. I'd read those articles over a periods of
10 years. And just out of sheer curiosity, I decided to go
11 down to Bartow, which is our county seat, and I visited
12 four or five different agencies and made public records
13 requests.
14 I knew nothing about public records law. It was
15 frightening how little I knew. All I knew is what
16 little I'd gleaned from reading newspaper articles. The
17 agencies I went to, they all gave me the records, and it
18 seemed to be sort of a nonevent until I went to the Polk
19 County School Board. When I went to the Polk County
20 School Board, the first thing they did was demand that I
21 had to sign in. And they demanded that I had to
22 disclose other personal information. They said I had to
23 make my public records request in writing. They wanted
24 to know why I wanted the records. And I didn't know
25 1 very much, but I knew they weren't supposed to do that.
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1 So I ended up leaving empty handed, and I went straight
2 from -- foolishly, straight from their offices to the
3 State Attorney's Office, thinking the State Attorney
4 would do something about it.
5 The State Attorney's Office, they were very nice,
6 but didn't seem very interested. But they did make a
7 phone call to the school board and basically told them
8 they had to give me the records, which they did. And so
9 I was curious, because behind the front desk in the
10 lobby is a seal that says "Knowledge is Power," which
11 sort of seems to go hand-in-hand with the concept of
12 transparency in government and access to public records.
13 So I was curious as to why they had done what
14 they did as far as making these unlawful demands that I
15 disclose personal information and make the request in
16 writing, et cetera. So I scheduled a meeting with the
17 -- at the time, a woman by the name of Gale McKenzie,
18 who was the Superintendent of Polk County School Direct.
19 She's not here anymore. And a couple of weeks later, I
20 met with her. In that meeting, she had two attorneys in
21 attendance, both of whom I know socially. And she
22 proceeded to tell me that my experience was -- and I'm
23 using her word, "non -normative."
24 And I was trying to understand, and I couldn't
25 come up with any other options here. Either it was
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1 deliberate, their violation of the Public Records Act,
2 or it was done out of ignorance, which I found both of
3 those to be troubling. They are a government entity and
4 they know the law. Or if they don't know the law,
5 they're an educational institution and they assert that
6 knowledge is power. I just wanted to know why it went
7 that way.
8 So she just assured me that I got them on a bad
9 day, it's not the way they normally do business. So we
10 left it at that. That was February or March of 2007.
11 So I waited a year. And in -- I guess it was about
12 March of 2008. I tried to think of the most offensive,
13 invasive thing that I could ask for that I was pretty
14 confident they wouldn't want to let me have. So I went
15 back down there and made a public records request for
16 the health insurance enrollment information for all of
17 their employees and all of their dependants, which at
18 the time, was nonexempt and subject to disclosure. And
19 they told me they wouldn't let me have the records, and
20 they sent me an e-mail, this e-mail had all of these
21 statutory citations and I didn't really understand what
22 those were, but I took it upon myself to read those
23 statutory citations, and not one of them had anything to
24 do with public records, much less any kind of an
25 exemption.
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 16
So they wouldn't let me have the records. So at
the time, I had the resources economically to do it. So
I hired an attorney and sued them. And spent -- I
probably racked up about $50,000 in legal fees, and
wrote tens of thousands of dollars of checks to get
access to those records. When we finally went to court,
the judge asked them for their defense, and their
attorney, sort of meekly, said, "Your Honor, we don't
have a defense." And I think this is an exact quote.
"Your Honor, we don't have a defense. We just didn't
want to give him the records."
I was blown away by that. It was shocking to me.
It was the only time I've ever heard a judge use
profanity on the record. His response was, "Why the
hell are we here?" That was an eye opening experience
for me to realize there are people in power who will
willfully, deliberately break the law just because they
want to. They don't have any good reason for doing it.
They just don't want to. As it turns out, I got this
information as a result of the whole series of public
records requests I made at the Polk County School
District. The reason they didn't want me to have it was
because they were selling it. They were selling the
same information to credit card companies, to financial
planning companies, to insurance companies. In fact,
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1 one of the school board members who had opposed me
2 getting the records had bought the same exact
3 information and used it in his political campaign to
4 become a school board member.
5 I ended up getting my legal fees back, and
6 frankly, it was a little bit like playing blackjack. I
7 decided double down, let's go again. So I made the same
8 exact request to every school district in the state, and
9 most of them gave me the middle finger. They just
10 wouldn't let me have the records. So I sued ten more,
11 and I won all of those. And then I made a public
12 records request -- this is probably one of the most eye
13 opening experiences I've ever had as an advocate. I
14 made a public records request to every school district
15 for any records they had referring to my public records
16 request. And to and behold, what I got was -- I think
17 it was Madison County, who I did not sue, and who had
18 given me the records in the first place. What I got
19 from them were thousands of communications between
20
school
board attorneys.
There was an organization I had
21
never
even heard of, the
Florida Association of School
22 Board Attorneys. And they had this list serve where
23 they kept talking to each other. And there were school
24 board attorneys saying, yes, we have the records, but
25 we're not going to give them to him. And they were
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1 engaged in a criminal conspiracy. You had attorneys
2 saying, well, we're going to tell him that we don't have
3 the records. Another attorney would say, well, we are
4 going to tell him that the records only exist in a hard
5 copy, so it will cost him a lot of money to get those
6 copies. Then there were other attorneys saying, well,
7 we're going to tell them that they are just
8 inaccessible.
9 1 To their credit, there were some school board
10 attorneys who came right and said, what you -all are
11 doing is illegal, that you may not like it, but he's
12 entitled to the records and you've got to give them up.
13 Those e-mail threads lead to the criminal prosecution
14 and conviction of the Polk County School Board's General
15 Counsel for criminal violation of the Public Records
16 1 Act.
17 That was a really eye opening experience for me
18 to realize that there were public officials, people
19 being paid to follow the law and do what is in the best
20 interest of their constituents, who were very willing to
21 break the law. It was deliberate. It wasn't
22 incidental. It wasn't, golly gee, we don't know what
23 we're doing. These are guys who went to law school, who
24 passed the Florida Bar, who apparently are supposed to
25 know the law, but just decided they where going to break
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1 it. So that is sort of where I got started.
2 From there, I started making other requests for
3 other things, and realized the power of public records
4 access. I filed with legal counsel, I don't know how
5 many, a few dozen lawsuits, and won all of them. And I
6 was very, very fortunate. The law firm that I first
7 hired, Thomas & LaCicero, who's still my principal legal
8 representation, are, in my opinion. The preeminent open
9 government litigators in the state of Florida. In fact,
10 Greg Thomas, who is their senior partner, is the
11 gentleman who has litigated many of the landmark public
12 records cases in Florida. They are regularly used as
13 citations by both sides.
14 He was very patient, very kind, and eventually
15 suggested that I might find it educational to file a
16 lawsuit pro se, which I did. And I have since then,
17 both with legal counsel and as a pro se litigant, filed
18 hundreds of public records lawsuits. Recently, just a
19 few days ago, I was doing some research that required me
20 to go to the Polk County Clerk of Courts web portal.
21 And I think I saw that I had filed just in Polk County,
22 I think 80 or 90 public records lawsuits. And of course
23 I file public records lawsuits all over the state. I
24 lost count of exactly how many there have been. My last
25 calculation, 99.6 percent of them had either been
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JOEL CHANDLER Volume 1 of 2
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adjudicated in my favor by the court or had been settled
in favor of access, meaning that the records were
ultimately produced and the offending agency agreed to
take some sort of remedial action to correct the
problem.
So I guess my knowledge about open government
litigation is sort of the school of hard knocks, figured
it out.
By the way, I do not only do -- I
do my own
public
records litigation,
although right
now I don't
think --
I think I have 30,
a little over
30 pending
public records cases that are still ongoing. Only three
of those were with legal representation. But I also, in
addition to doing public records litigation, I also get
contacted from time to time by state agencies asking me
to consult with them, with their legal counsel, on
either how to improve public access, or strategies on
how to defend against public records lawsuits. I did
one not long ago with the Department of Economic
Opportunity. They had a fee hearing and I was helping
them prepare for a fee hearing. And I think they were
successful in getting their fees reduced by about
$50,000, although they wouldn't have paid a penny if
they obeyed the law in the first place.
Q. So you said you filed about 80 or 90 in Polk
County since 2007, would you say?
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1 A. My first public records lawsuit was in 2008
2 against Polk County School Board.
3 Q. So from 2008 to present, how many, in total,
4 would you say you personally have filed?
5 A. As a plaintiff, you mean?
6 Q. Correct.
7 A. Both with and without counsel?
8 Q. Correct.
9 A. I could only estimate. I would say -- I would be
10 shocked if it's not well over 300. I don't think it's
11 1 400 yet, yet.
12 Q. So approximately 300 public records cases?
13 A. If somebody -- I have never bothered to do this.
14 If somebody got on LexisNexis and figured it out and
15 told me there were 350, that would not surprise me.
16 Q. Now, prior to 2007 when you started making these
17 public records requests, what were you doing?
18 A. I had spent about 20 years as a copy machine
19 salesman. About 11 years of that -- about 2 years as a
20 salesman, then about 8 or 9 years in management. I
21 worked for a couple of different multinationals. And
22 then I decided to quit, and I started consulting with
23 office equipment dealers, people that sell copy
24 machines, all over the United States. I had clients in
25 probably 25 different states. Essentially what I would
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do is, I would do research in their particular market,
identify their competitors' most vulnerable accounts,
and sell to them a database that they could use to
basically take accounts away from their competitors.
The office equipment business is a very predatory
business, extraordinarily so. It's very rare that
somebody goes out and sells a business their first copy
machine. You are taking an account away from somebody
else. That's how it works.
Ironically, I was using public records to do
I didn't think of them that way. In fact, that
was one of the first abuses that I experienced, but
didn't realize I was being abused. It was a state
contractor who operates the UCC program for the State of
Florida, Universal Commercial Code for the State of
Florida. They catalog them, manage them, and provide
access to them. I went to -- this is just one example
of why what I do, I think, is important.
I went to the state archives and wanted to get
I was shocked they let me have them. I
didn't know that the public could even get those things.
And the guy at the state archives, when I asked him how
much it would cost, he told me he was going to charge me
$50 a CD, and there were I don't know how many CDs, but
there were going to be thousands and tens of thousands
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February 24, 2016
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1 of dollars to get this stuff, and didn't have that kind
2 of money. And subsequent to that meeting, the State
3 hired this private company, Image API, to manage this
4 for them. So this is a for-profit company that is doing
5 it. When I quit working for somebody else and went to
6 work with my own consulting business, which was just me.
7 It wasn't even a corporation. I contacted Image API to
8 get these records and they charged me thousands and
9 thousands and thousands of dollars, of which I paid.
10 And years later, sometime after 2008 when I started to
11 have a clue about public records access, I went back and
12 looked at it, and sure enough, they had screwed me.
13 They had overcharged me by about $4,000. So I sued
14 them. I think they ended up paying $12,000 of my legal
15 fees and they refunded the $4,000 they had stolen from
16 1 me.
17 1 And this happens all the time. That is one of
18 the most common mechanisms used by public entities, both
19 public -operated agencies and those that operate on their
20 behalf, like Image API, to frustrate access. They use
21 it as a profit center, or they use confiscatory fees in
22 an effort to try to frustrate access.
23 So anyway, I had a consulting business, which I
24 lost interest in sometime after 2008. I was still doing
25 that when I started the public records -- my first
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February 24, 2016
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1 public records request. And the more access I got to
2 records and the more experiences I had where I was being
3 frustrated in my access to records, that's when I
4 started doing more and more litigation, and then I began
5 to sort of reevaluate my view of the world as far as how
6 poor minority people are being treated, and realized
7 that they desperately need access to public records. So
8 I basically quit my consulting gig and started on this.
9 Q. Now, of the public records requests that you have
10 or the lawsuits that you have filed where you have been
11 represented by counsel, related to public records
12 requests, what law firms have you used or attorneys?
13 A. I'm sorry. Say that again.
14 Q. For the lawsuits that you've filed with respect
15 to the public records request where you have been
16 represented by counsel, which law firms would you say
17 you've used?
18 A. I don't know that I could give you a full
19 accounting of that off the top of my head because there
20 have been quite a number. Thomas and LaCicero would be
21 my principal law firm. The O'Boyle Law Firm represented
22 me in a few cases. A guy by the name of John McKnight
23 represented me in a few cases. There was a law firm
24 here locally, Pinkett &Pinkett, that represented me in a
25 few -- I say a few, probably a dozen or so cases. Who
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1 else? A guy by the name of Eric Abrahams down in South
2 Florida represented me in one or two cases. Nathan
3 Carney is representing me in three cases presently.
4 Matt Weidner represented me briefly in a few cases. He
5 has since changed the nature of his practice, so I'm
6 taking three of those back to do pro se. There may have
7 been others. That is not a definitive list.
8 Q. But you say the majority of the cases that you
9 did have counsel was with Thomas and LaCicero?
10 A. I don't know if a majority would be the right way
11 to put it. The most interesting cases have been with
12 Thomas & LaCicero. A lot of the more run of the mill
13 stuff, you know, it's not real complex, and frankly
14 doesn't take a great legal mind to do, numerically, I
15 couldn't tell you. I'm sure by this point, the vast
16 majority of the cases that I have litigated I have done
17 pro se.
18 Q. Do you know the Plaintiff in this matter, Martin
19 O'Boyle?
20 A. I do.
21 Q. How did you come to meet Mr. O'Boyle?
22 A. Sometime in 2013, I want to say it was earlier in
23 the year, I got a phone call or e-mail from Barbara
24 Peterson, who is the President of the Florida First
25 Amendment Foundation, who I would describe as a
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colleague and a personal friend. She contacted me
saying she was going to have a meeting with a guy named
Marty O'Boyle down in South Florida. She was going to
meet for breakfast or coffee or something, and that he
had expressed a real interest in open government
advocacy, and she thought if I was available, it might
be worth taking time to meet with her and him.
So I drove down to West Palm Beach, and we met at
-- I think it was a Holiday Inn near the West Palm Beach
Airport, as I recall. It was sort of a nonevent. We
clicked. It was very friendly, cordial conversation.
It wasn't really substantive. It was just sort of
public records, open government issues generally. That
was the first time I had ever had any contract with him.
It was a very pleasant meeting.
Q. 2013?
A. Early part of 2013, as I recall. I can't say
that definitively.
Q. Was there -- just so I'm clear, just general open
government discussions that occurred at that meeting?
A. Yes. I don't remember any of the particulars
about the topics of conversation other than I'm
confident that it was just general discussions about
open government. There was no particular agenda.
Q. Do you recall if there was any discussion about,
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1 I guess, prior open government --
2 MR. DESOUZA: Josh, I hate to do this, but I have
3 to have you speak up. I can hear you, then towards to
4 end of the sentence I can't hear you. It's probably
5 because you're looking at Mr. Chandler when you're
6 asking the question.
7 MR. GOLDSTEIN: Or looking at my notes.
8 BY MR. GOLDSTEIN:
9 Q. The question I started asking, was there any
10 discussion about prior experiences in making public
11 records requests or comparison of notes of prior
12 experiences in making public records requests?
13 A. It wouldn't surprise me if that was part of what
14 was discussed. I don't really remember. I just
15 remember it being a very cordial meeting, and my sense
16 when I left -- and I think Barbara and I may have
17 communicated afterwards either by e-mail or phone, we do
18 both, was that -- I came away from it with kind of a
19 sense that here's a guy who apparently has some means,
20 and seems very earnest about open government issues,
21 seems really passionate about open government issues.
22 She operates a nonprofit. And my advocacy for open
23 government and for civil rights generally has been an
24 economic disaster for me personally. So it was -- the
25 1 sense I came away with was here's somebody who might
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1 actually be, at some point, a benefactor, I guess, might
2 be the right word, somebody who seems they are serious
3 about it who actually has some resources.
4 So many people that I deal with -- and I get
5 contacted all the time. I get contacted by reporters a
6 lot asking for help on open government issues, and also
7 looking for stories. I very regularly source for
8 reporters around the state of Florida and nationally for
9 various stories, and I don't get compensated for that,
10 and that's fine.
11 I get contacted by citizens, very often, who are
12 getting frustrated by access to records. They don't
13 have any money. Most of my advocacy work is done with
14 poor minority people, who by definition, don't have any
15 resources. I get contacted sometimes by government
16 agencies, examples I've given you earlier, sheriff's
17 offices -- even the Sheriff's Office here in Polk
18 County, which I have had a fairly adversarial
19 relationship with, I have been contacted by them to
20 consult on public records issues. I don't get paid for
21 any that.
22 So most of the people that I deal with, most of
23 the people that contact me, don't have a pot to piss in.
24 So it certainly, you know, was notable in my mind that I
25 was actually talking to somebody who seemed passionate
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1 about the issue, who actually had resources. That was
2 interesting to me. Neither one of us -- at least
3 nothing was communicated between us, me and Barbara,
4 that we didn't have any nefarious plans to try to get
5 his money. But it was like okay, that's kind of cool.
6 Most people that contact her and most of the people that
7 contact me bring nothing to the table other than hey,
8 can you help me? Which I'm happy to do. But it was
9 very notable that we were dealing with somebody who
10 seemed passionate and had means.
11 But just to be clear, there was never any -- it
12 was a purely social event. Marty bought breakfast. I
13 remember I had coffee and pancakes and he had oatmeal.
14 But that was the -- there was no compensation. There
15 was no promise of money. It wasn't like he was offering
16 to be a benefactor. He just seemed interested and
17 interesting.
18 Q. Was there anyone else at that meeting besides the
19 people you have mentioned?
20 A. No; just the three of us.
21 Q. Do you recall if there is any discussion
22 regarding public records requests that were sent to the
23 City of Longport in New Jersey during that meeting?
24 A. Don't recall.
25 Q. At this early 2013, were you aware of the Town of
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1 Gulf Stream? Had you heard of the Town of Gulf Stream?
2 A. I can't say I never heard of it. I don't -- it
3 had no special meaning to me. I mean, it's very
4 possible by 2013, I would be surprised if I had not, at
5 some point, made a public records request to Gulf Stream
6 by that point. There are 412 municipalities in Florida,
7 and I have probably made public records requests to
8 every single one of them multiple times. I'm sure there
9 is a government agency some place in Florida that I
10 haven't found yet, yet. But, you know, so I don't know.
11 Like I said, it had no more special meaning to me than
12 Nakomis or Mulberry or any other town in Florida.
13 Q. Following that meeting, did you ever meet with
14 Mr. O'Boyle again?
15 A. Yes, many times.
16 Q. When would you say your next meeting with Mr.
17 O'Boyle was?
18 A. I don't know if it was weeks or months, but
19 1 sometime following that meeting with Barbara and with
20
Marty, I
was contacted
-- I believe it was by Ryan
21
Witmer,
who was working
for the Commerce
Group, which is
22
the company
that Marty
owns. I'm pretty
sure it was
23
Ryan that
contacted me
and said they had
some public
24
records
issues they were
working on, and
would I be
25
willing
to come down to
Deerfield Beach and meet with
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1 1 them to discuss open government issues, to consult with
2
their attorneys -- not
with Marty, but with Bill Ring,
3
who was
the attorney.
And Ryan, at the time, as I
4
recall,
had passed the
Bar in New York and had passed
5
the Bar
in Florida. I
think he was still waiting to get
6
his law
license. I'm
not sure of that, but I think that
7 1 was the case.
8 So anyway, at their invitation, and they were
9 very insistent that they would cover my cost of going
10 down there and paying me to go down there. I have
11 mouths to feed, so I was happy to do it. It wasn't a
12 lot. I think it was -- I don't know. I want to say it
13 was $25 an hour or something. My total thing going down
14 there was like 600 bucks or something. So I went down
15 there, and met with Bill Ring. It was the first time I
16 met Bill Ring, first time I met Ryan in person, was a
17 lovely guy. And Marty was there. And I remember it
18 would have been in April because they were right in the
19 middle of doing a bunch of tax stuff. So that timeline
20 makes sense to me. It would have been in April because
21 I remember there were gobs and gobs and gobs of tax
22 documents spread out all over their conference table.
23 So that would have been a few weeks -- a month or so
24 after I met with Barbara and Marty for the first time.
25 So it would have been early 2013.
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I think I just went down there -- I don't think I
spent the night. I think I just went down there for the
day. No. I take that back. I did spend the night. I
spent the night at Marty's house, because after that
meeting, which I remember vividly, because the highlight
of the meeting was a hot pastrami sandwich that I got.
It was amazing, the best pastrami sandwich I had ever
eaten. They ordered in for lunch.
Q. Pickle Barrel?
A. That may have been it. It was very good, the
second best. The best place is down in Miami, Stevens.
Have you ever been to Stevens?
Q. No.
A. Pastrami, out of this world how good it is.
MR. SWEETAPPLE: I'm getting hungry now.
A. But we had a delightful -- we had a really nice
dinner. Marty took Ryan and me to a very nice
restaurant in -- I don't know, Delray or some place, had
a lovely meal. I remember I had risotto.
Q. This was April of 2013?
A. Yes. It would have been -- I'm guessing, I'm
guessing it would have been 14, 15.
Q. Don't want to guess. So if you recall...
A. My recollection is -- I'm certain about the tax
stuff going on. Marty kept popping in. He was not in
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1 the meeting the whole time. He kept popping in ad out
2 because he had tax stuff to do. The nature of the
3 meeting was they had a bunch of public records requests
4 that had been made to the State Attorney's Office. And
5 they were -- "they," being the attorney and Ryan, his
6 paralegal, I guess -- were contemplating filing a public
7 records lawsuit or a number of public records lawsuits.
8 So essentially, what they were asking me to do was to
9 review the requests that were made and the responses,
10 the facts of these potential cases, and give them my
11 candid assessment of whether or not they were worthy of
12 litigation. And my assessment was in every instance was
13 they were not. They shouldn't file suit.
14 Q. At the time, were you aware of the facts
15 surrounding the basis for the public records request
16 sent to the State Attorney's Office?
17 A. I don't think that I was, and frankly, I didn't
18 really care. It wouldn't make any difference to me.
19 Motivation doesn't matter. I know that a lot of people
20 get hung up on that. It just doesn't matter. I found
21 out at some point, some of the vague facts. I know
22 there had been some issue -- I think his daughter had
23 been arrested on a DU I or something. I don't know all
24 of the details. Even now I don't know all of the
25 details. I know he had some sort of ongoing
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1 disagreement with Dave Aronburg who, I guess, was the
2 state attorney at the time. I don't know if he still
3 is. But I didn't really care. One of the things that I
4 think I've been pretty consistent in my civil rights
5 career, I don't care what somebody's motivation is. It
6 doesn't matter to me. I suppose if I found out there
7 was an organization of pedophiles that might want my
8 help with public records access, I probably wouldn't be
9 too interested in helping them. But I worked with, like
10 I mentioned, the Council on Islamic -American Relations.
11 I'm not a Muslim. I have no interest in whatever it is
12 they're doing. But if they need help getting access to
13 records, I'm happy to help them do that. I have worked
14 with the Atheists of Florida. I've worked with the
15 ACLU. I've worked with people who are interested in
16 getting records because they are advocates for
17 preventing cruelty to animals. It doesn't matter why
18 somebody wants access to records. I don't think it was
19 really an issue.
20 Q. But you would agree of those organizations you
21 previously listed and just listed, typically when they
22 are making a public records request, they have a
23 specific interest in the actual information they are
24 seeking, as opposed to just seeking benign or just
25 general information?
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1 A. No. I wouldn't agree with that.
2 Q. So you're saying that the Islamic foundation
3 would just make a public records request for any type of
4 information regardless of whatever their objective is?
5 MR. DESOUZA: Objection.
6 A. I would make the distinction between objective
7 and motivation. And it's a nuance, but very significant
8 distinction. I very frequently, when people contact me
9 asking for help, and I say people euphemistically,
10 organizations, people, whoever, when I'm contacted for
11 help, I don't condition my willingness to help on their
12 motivations. But I very frequently ask them what the
13 objective is, because that very often has something to
14 do with how, if I were similarly situated, how I would
15 make the request.
16 I very frequently, and I'm sure this is true of
17 many of the people I have worked with, make requests for
18 records because I have a very specific objective for
19 getting the records. There is a reason why I want them.
20 But there are also times when I have made public records
21 requests, and I think this is probably true of some of
22 the people who I have helped over the years, who are
23 making the requests for no other reason than sheer
24 curiosity. The first public records request I ever
25 made, I couldn't care less about the records. That
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wasn't the issue. I went down to Bartow and went to
those four or five public agencies. I wanted to see
what would happen. Again, motivation's an impermissible
issue in the context of public records access. It's
something that the custodian can't consider. The courts
can't consider it. It's irrelevant. I wouldn't agree
with your assessment at all. I think sometimes people
make requests because they really need the records for a
particular reason. I think other times they make the
request because they want to see what is going to
happen.
I don't know
their walls with
Maybe they want to use it to paper
I don't know. It doesn't matter.
That's the beauty of it. The problem with allowing
people to take into consideration motivations -- and
this is true, by the way, not just in a disparity of
views between people like me and the establishment, but
it's also between people like me and other people like
me. I have recently had a conversation with somebody
who's done a fair amount of open government litigation,
and has been successful at it, and they were taking a
very condescending view of anybody who makes a public
records request, quote, "just because they can." And my
response to that is that's morally, logically, and
legally the equivalent of saying that Rosa Parks didn't
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1 really want to go anywhere on a bus. Or that's like
2 saying that four black men walked into a Woolworth's in
3 Greensboro, North Carolina in 1960 and weren't really
4 hungry. That is not the point. See what I mean?
5 Q. Sort of.
6 A. Motivation -- what I'm getting at is even among
7 activists, it's surprising to me how quick some
8 activists are to dismiss the motivations and objectives
9 of other activists. Because they aren't important to
10 me, then they are not important. But the reality is my
11 rights are no more secure than your rights are. And
12 that's a fundamental principal of civil rights activism
13 generally. Whether in the context of open government or
14 otherwise, besides my world life view, which dictates
15 that I care about how other people are being treated, I
16 ought to be aware enough of my own self interest.
17 The reason I don't want the police to use attack
18 dogs on peaceful civil rights protestors is I don't want
19 them using them on me. See what I mean? And the same
20 thing is true with access to public records. If
21 somebody doesn't like the reason that Marty O'Boyle is
22 making public records requests, again, my response is it
23 doesn't matter, his motivation. Now, we can talk about
24 a whole lot of other issues that I've got with Marty
25 O'Boyle, but that ain't one of them. If somebody wants
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to make a public records request because they are pissed
off at some town, or pissed off at some public official,
they have the right to do that. The dangers is once you
start scrutinizing why someone is making the request,
then I think you get to a slippery slope that inevitably
leads to a place where you're going to say, well, I
don't like your reasons for doing it. Mine's okay, but
yours isn't. As soon as you do that, my right to do it
is in jeopardy.
So again, I am confident that I, in no way, with
Marty or anybody, said, "I want to know why you're doing
it before I come help you."
Q. But you would inquire as to their objective?
A. Yes, absolutely, what is the end game? What are
we trying to do here? What are we trying to get at?
Q. So when you met with Ryan Witmer, Bill Ring, back
in April of 2013, did you inquire what their objective
was in terms of their public records request on the
state attorney's office?
A. I may have. I don't recall. It wouldn't
surprise me -- well, frankly I would be surprised if I
didn't ask that question.
Q. So would you be okay in, I guess, advocating
public records requests where the objective is purely
just to harass the town, or to harass the state
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1 attorney, or harass whatever entity the records requests
2 are being sent to?
3 MR. DESOUZA: Objection, form.
4 A. That would be a little bit like asking me if I
5 had a problem with the Immokalee farm workers protesting
6 out in front of Publix; why are they doing it? Well, I
7 suppose part of the reason they're doing it is probably
8 to raise public awareness about Publix being too damn
9 cheap to be willing to pay a penny a pound more so poor
10 farm workers can actually try to feed their children.
11 I suppose, depending on your perspective, you
12 might say they're trying do it to try to harass Publix.
13 If they are not breaking the law, they're not engaged in
14 violence, they are not blocking public thoroughfares,
15 they're not in some other way violating some
16 constitutionally sounds statute, I wouldn't call it
17 harassment. Now, if I was a stockholder in Publix, I
18 might feel like I was being very much harassed. But I
19 guess harassment is in the eye of the beholder.
20 And again, if you were to ask me if that's a
21 prudent approach, to pound some little town with gobs
22 and gobs and gobs of public records requests, no. I
23 think that is really imprudent. And when I ultimately
24 went to work for the Citizens Awareness Foundation, one
25 of the conditions of my employment was there can't be
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1 any enemies lists. But that has nothing to do with
2 whether or not I think somebody has the right to make a
3 bunch of public records requests to a little town. I
4 wouldn't do it, not on the scale that I think it has
5 been done.
6 But having said that, just to kind of give you a
7 different -- this is sort of the fable of three blind
8 men describing an elephant. Everybody comes away with a
9 very different perspective depending on what part of the
10 elephant you're touching.
11 So I recently had a lawsuit against this little
12 town in Polk County. I made a public records request
13 because I wanted their -- for a very particular reason,
14 I wanted -- I had a very definite objective and a very
15 sound motivation. I wanted to know if the City
16 Commissioners were having conversations they weren't
17 supposed to be having. Because every time I went to one
18 of these public meetings, it was amazing how incredibly
19 efficient they were at making decisions. It was as
20 though they had already talked about it. They would
21 walk in, and make a decision to enter into a
22 multi -million -dollar contract, have two minutes of
23 discussion, and they would do it. This was a little,
24 tiny town.
25 I just wanted all of the e-mails of the city
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1 commissioners from their city e-mail address. And the
2 town came back and told me it was going to cost, I don't
3 know, like $2,000 or something for each of the city
4 commissioners. It was going to cost me like $20,000 to
5 get these e-mails.
6 Well, okay. So what I ended up doing was
7 breaking it down. If you want to take -- this is a real
8 simple public records request. They shouldn't be
9 talking about anything they're not supposed to be
10 talking about. There shouldn't be anything exempt or
11 confidential in there. So what I ended up doing,
12 because I didn't have the money to pay $20,000 to get a
13 bunch of e-mails. I made a separate public records
14 request for each of the city commissioners per day. I
15 want all of the e-mail addresses for this city
16 commissioners on January 1st, 2015, and same for each
17 one of them. And I did that for I think about 100 days.
18 And it wasn't that I was trying to harass the town. It
19 was they were putting me in a position where they
20 weren't giving me the records. They were records I was
21 entitled to. They weren't records that would have taken
22 any significant amount of time to gather. There
23 shouldn't have been anything exempt or confidential in
24 there.
25 1 Now, they, I'm sure, would take the position that
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I was harassing them. I wasn't harassing them. I was
breaking it down and making small public records
requests that would fall under 15 minutes so I could get
the records at little or no cost.
And by the way, when they finally produced all of
them, not one of them had a redaction in it, nothing was
redacted because there wasn't anything exempt or
confidential. But they jacked me around. So some
people would say that's harassment. That's not
harassment. They're skirting the law. They are trying
to block my access to records based on cost. So again,
harassment is in the eye of the beholder.
Q. So in April 2013, how long would you say you were
down there assisting Witmer and Ring?
A. I think I was down there for a day, as I recall.
And I think maybe what I did was went down the night
before, and we went to dinner. Maybe that's the way it
worked. Then the next day was a full day in the office.
I think that was it. I went down on a Sunday evening,
and then we had dinner in Delray, Marty, Ryan, and
myself. And then the next day was with Bill Ring, had
that delicious sandwich, and drove home.
Marty was very hospitable. He offered to put me
up in a hotel or let me stay at his house, and I opted
to stay in his very nice home.
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Q. At the time of this meeting in April 2013, were
you aware of any prior relationship or, I guess I'll
call it relationship between Dave Aronberg and Mr.
O'Boyle?
A. Prior to going down there, I'm sure I didn't
recollection is that after dinner, we went back to
Marty's house, the three of us, Ryan, too. And pretty
early in the evening, Marty excused himself and turned
My
in for the night. And Ryan and I sat up and, at Marty's
invitation, took advantage of his very well stocked bar.
And we sat out by the pool, and he and I talked at
length about the law, and about just law generally, and
about civil rights issues in particular. He seemed
pretty passionate about civil rights issues. And I
think at that time -- we were out there until very late,
early morning hours. And I think as I recall, he shared
with me some of the details about Marty's issues with
Aronberg.
Q. Do you recall what those issues were?
A. Just that he felt -- as I recall, that Marty felt
his daughter had not been treated fairly.
Q. You don't recall any additional discussion
regarding whether or not there was a prior relationship
between Mr. O'Boyle and Dave Aronberg?
A. No. I think anything I learned about that
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1 probably came from newspaper articles that I read
2 subsequent to that.
3 Q. Do you recall what you had read in the newspaper
4 articles?
5 A. The general recollection I have is that his
6 daughter had been charged with DUI, and that -- I don't
7 know any of the details of that at all, but just that
8 Marty came away from that feeling his daughter had not
9 been treated fairly, which wouldn't surprise me that
10 Marty would feel that way, and it wouldn't surprise me
11 that his daughter wasn't treated fairly, given my
12 experience with people on the abused end of law
13 enforcement.
14 There was some -- one of our newspaper articles I
15 read, there was some issue about Aronberg flying in
16 Marty's plane or something, and whether or not that was
17 a campaign contribution or something. And to the best
18 of my recollection, I don't think Marty and I have ever
19 discussed it, certainly none of the details about his
20 daughter.
21 Q. Just so I'm clear, you have no actual knowledge
22 as to the, I guess, facts surrounding the circumstances;
23 correct?
24 A. Don't know and, frankly, don't care. And just to
25 kind of give this a background from my perspective on
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1 this, the Poor Minority Justice Association, for
2 example -- this, I think, may be helpful to you in
3 understanding why I would be so disinterested in the
4 facts. Before I went to work for Citizens Awareness
5 Foundation, I was, on a fairly regular basis, I would go
6 over to Winter Haven and to an African-American
7 ministry. His name is Clayton Cowhart. And he has a
8 radio show that his audience is largely poor
9 African-Americans. He asked me to be a guest on the
10 radio show. And the radio show went from 5:00 to 6:00
11 on a Thursday. At the end of the radio show, he said --
12 it was a call-in radio show and people were calling in
13 with civil rights issues. He said just before he closed
14 out the radio broadcast, he said, Brother Chantler, is
15 what he called me, Brother Chantler is going to be at
16 the church at 6:15. If you've got an issue, you can
17 meet Brother Chantler over there. I had no idea that
18 was part of the agenda.
19 So I went over to his church, which is in a very
20 poor part of Polk County. And there were probably 50
21 people waiting for me. And they were all
22 African-American, maybe one or two Latinos; no Whites.
23 And I spent the next several hours talking to people.
24 Obviously I can't give legal advice, but they are
25 describing to me various issues they've got. And most
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1 of them, the vast majority of them, they had a child, or
2 a spouse, or a loved one who was either in jail, in
3 prison, or being prosecuted. And for those folks, none
4 of them have private attorneys. All have public
5 defenders. And the common denominator that I got in
6 that first night over there was that the public
7 defenders were doing virtually no meaningful discovery
8 in these criminal prosecutors. So I spent every
9 Thursday night for the next nine months to a year going
10 over there, meeting with these people. And I can't give
11 them legal advice, but I can tell them if my kid was
12 being prosecuted, here is what I would be asking for.
13 If I had some dipshit attorney who wasn't doing his job
14 defending my child, and my kid was being prosecuted
15 because supposedly he dropped a bag of crack cocaine at
16 his feet as the officer turned the corner, the first
17 thing I would want to do is impeach the character of
18 those police officers. They are the only witnesses. So
19 I would help them get access to public records.
20 Some of those people that I helped -- and there
21 were a shocking number of them that ultimately ended up
22 being acquitted, because what we found out is the police
23 officers are very well documented liars in many
24 instances. You have a guy who, if you look at his IA
25 summary, and his internal affairs investigations,
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1 everybody in town knows that he's a notorious liar, yet
2 we are going to prosecute some kid on the word of this
3 guy. And there were people who ended up being
4 acquitted.
5 There are some of the people that I'm sure were
6 guilty as sin. There was one woman and her husband,
7 they had an 18 -year-old boy who had been charged with
8 first degree murder. And the more time I spent getting
9 access to records and the more documents I saw, the more
10 convinced I was that he was probably guilty. But I
11 still sat with them around their kitchen table, and we
12 still sat there and cried together trying to figure out
13 a way to give him the best possible defense he could
14 get. Him being guilty had nothing to do with it. I
15 don't care. What I want is for him to be defended and
16 to get his fair day in court. It doesn't matter to me
17 what somebody's motivations are what or somebody's
18 circumstances are. It's irrelevant.
19 So I don't care whether Marty's daughter was
20 fairly or unfairly treated by the State Attorney's
21 Office. If Marty wants to make public records requests
22 to the State Attorney's Office, I'm happy to do that.
23 Q. After this meeting in April 2013, when was the
24 next time you spoke with Mr. O'Boyle?
25 A. I don't know. We communicated a little bit. I
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do remember my wife and I went down to South Florida. I
don't even remember why we were down there, probably
some sort of civil rights meeting. And on the way back
up, Marty kind of left me an open invitation to stop by
and see him any time, so I called him, and my wife and I
stopped by at his office, and mainly so she could put a
face with the name. And we chatted at his office for a
little bit. He actually invited to take us to dinner,
but we wanted to hurry and get home.
There may have been -- I don't remember. There
may have been another meeting or two in there. I just
don't recall. But it was in very early January of 2014.
I got a very nice e-mail from Marty. And I don't know
if we -- we may have talked on the phone a time or two,
or probably exchanged e-mails a time or two from April
2013 until the January e-mail I'm talking about.
I think it was January 4th, 2014, I got this very
nice e-mail wishing me a Happy New Year. The e-mail
said something to the effect of, I hope 2014, you get
everything you deserve. And I remember thinking, I'm
not sure I want everything I deserve, but I very much
got the sense he wanted to talk. In fact, he said in
his e-mail that he wanted to schedule a visit. And then
it was some time after that, I ended up -- I think it
was January 22nd that I actually went down to meet with
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February 24, 2016
49
Q. You believe it was the 22nd of January?
A. I believe it was 22nd of January.
MR. GOLDSTEIN: I will show you what we are going
to mark as Exhibit 1, which appears to be a timeline,
which was previously marked as Exhibit 1 to your 2004
examination.
(Defendant's Exhibit No. 1 was marked for
identification.)
THE WITNESS: As a former copy machine salesman,
I have to tell you, I'm very offended.
BY MR. GOLDSTEIN:
13 Q. Do you recognize this document?
14 A. I can't authenticate it. It looks vaguely
15 familiar.
16 Q. Does it look like the timeline you may have
17 created?
18 A. It looks like it might be, but again, I can't --
19 without going through and doing a detailed comparison of
20 what you've handed me with what I created, I couldn't
21 tell you for sure whether it is or isn't. The quality,
22 as you say, is very poor.
23 Q. I recognize that. I believe you testified that
24 you first -- that you got an e-mail early 2014 from Mr.
25 O'Boyle wishing you a Happy New Year?
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JOEL CHANDLER Volume 1 of 2
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A. Yes.
February 24, 2016
50
Q. Was there any discussion regarding meeting with
him, if you recall, during the course of that e-mail?
A. Yes. As I recall, the e-mail was something to
the effect of Happy New Year, I hope you get everything
you deserve. And I couldn't tell whether it was a
blessing or a curse. And something to the effect that
-- I don't remember if it was that e-mail or a
subsequent e-mail, but in very short order it was, "I
would like to meet with you." It was sort of a, "Let me
know if you're going to be down here," or something to
that effect. I very much got the -- at that point, I
very much had the impression that there was going to be
some substance to whatever our meeting was going to be
about.
Q. So looking at what has been marked as Exhibit 1
in the first page, there is a notation that says, "Marty
O'Boyle e-mail to Chandler, January 4, 2014, MEO, which
you indicate is Mr. O'Boyle, invites Chandler to meeting
to discuss what would later become known as Citizens
Awareness Foundation."
A. Yes, CAFI.
Q. Is that accurate?
A. That is my recollection, yes.
Q. So this initial e-mail, there was some discussion
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1 about trying to form -- to meet to discuss forming a
2 public records foundation?
3 A. Yes. The e-mail was not, hey, let's get together
4 to talk about forming a foundation. It was just Happy
5 New Year, hope you get everything you deserve. Let's
6 get together, was the gist of it. There was no
7 substance to it beyond that. My sense that there was
8 going to be some substance to the conversation was
9 purely my intuition. Now, it turns out that that
10 intuition was right. And it gave further credence or
11 substance to that intuition as a result of conversations
12 that I had with Jonathan O'Boyle, with Ryan Witmer,
13 which are notated on the second page of this.
14 I had a conversation with Ryan and Jonathan. I'm
15 sort of perpetually on the -- not anymore, but I used to
16 be sort of perpetually on the lookout for attorneys that
17 might be able to help me with public records litigation
18 or be attorneys I can refer to somebody for public
19 records litigation. Many of the contacts that I receive
20 from the public are asking for a referal to an attorney,
21 for which I get no compensation from either side.
22 So I've also been interested -- I'm not so
23
interested
anymore, but at
the time I was very
24
interested
in cultivating
relationships with potential
25
attorneys.
Conversations
I'd had in person with Ryan
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1 and with Jonathan gave me the sense they were probably
2 interested in that sort of thing. Then we had telephone
3 conversations, and we had kind of, in very general
4 terms, talked about maybe doing some work together,
5 either me referring people to them, again, for no
6 compensation, maybe them representing me in some cases,
7 although I don't think I would have been terribly
8 excited about that, because my experience, no offense to
9 them, but with anybody -- you know, you graduate from
10 law school, you pass the bar, you still don't know how
11 to practice law. You don't even know how to file a
12 lawsuit. You don't know where the lawsuit gets filed,
13 much less how to draft one. I have already gone down
14 that road more than once with recent law school
15 graduates and it's not a pretty picture. I don't think
16 I was that excited about them representing me, but -- in
17 the course of our discussions, I remember saying to them
18 that there's this plethora of open government litigation
19 simply because there's so many violations of the Public
20 Records Act. There are a lot less now today than there
21 used to be, by the way.
22 When I first started doing what I do, according
23 to Barbara Peterson, about 60 percent of all public
24 records requests were met with an unlawful response. I
25 don't think it was quite that high. My experience was
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1 it was closer to 50 percent. Today, with public
2 operated entities like the Town of Gulf Stream, for
3 example, violations only occur about 30 percent of the
4 time. So there's been a very dramatic improvement in
5 the response of publically operated agencies.
6 When I started concentrating on state contractors
7 whose contracts explicitly make them subject to the
8 Public Records Act, i.e., 287.058, if you don't respond
9 properly to public records requests, we can immediately
10 and unilaterally terminate your multi -billion -dollar
11 contract, where it just says it. The compliance rate
12 was about 2 percent. Today it's probably closer to 50
13 percent. And I am confident that the reason we have had
14 that improvement is education, which happens sometimes
15 in a seminar -type setting, sometimes it happens
16 one-on-one or consultative setting. But very often it's
17 an education program that happens at the courthouse.
18 But I was telling them that there is a lot of
19 public records litigation out there. Only a tiny
20 fraction of the cases that could be filed, get filed
21 because most people don't have the resources to do it.
22 And -- but I was saying to them in this
23 conversation that -- in fact, I can remember where I
24 was. It was on Hillsborough Avenue in Tampa standing
25 outside of a Dunkin' Donuts when I had this conversation
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1 with them that the best way to do this would not be
2 individuals, but a nonprofit for a whole lot of reasons,
3 as a client. And their response was something to the
4 effect that well, you are really going to like the
5 conversation you are going to have with Marty. So it
6 was this sort of this sense that -- they didn't say it
7 but, I got the impression that's kind of what Marty had
8 in mind. And I was so convinced of that that in the
9
week
leading up to my meeting with Marty,
I actually sat
10
down,
and gave some real thought to what I
might ask for
11
if I
was given an opportunity to have that
conversation
12
with
Marty, which I did have, ultimately.
13
Q.
What prompted you to call Ryan Witmer
and
14
Jonathan
O'Boyle?
15
A.
I think they called me, if I'm not
mistaken.
16
MR. DESOUZA: Josh, mind if we take
a 5 minute,
17 1 10 minute break?
18 1 (Recess from 11:51 a.m. to 12:53 p.m.)
19 BY MR. GOLDSTEIN:
20 Q. We left off regarding your call with Jonathan
21 O'Boyle and Ryan Witmer where you were discussing the
22 public types of cases that this law firm could -- their
23 new law firm could handle. What was the name of that
24 law firm?
25 A. At the time, I don't know that they even gave me
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1
a name. It ultimately was the O'Boyle
Law Firm. I
2
don't
recall if we got into that on the
telephone
3
conversation.
4
Q.
Did you call them or they reached
out to you?
5
A.
I think they called me.
6
Q.
Do you know where they were when
they called you?
7
A.
I don't know.
8
Q.
Do you know if they were in the
same room or if
9
they were on two different lines?
10
A.
I don't know.
11
Q.
Do you know Jonathan O'Boyle was
in Florida when
12 1 you
13 A. Don't know.
14 Q. Now, in your discussions with them, it sounded
15 like they could basically set up shop and become an
16 exclusive public records law firm. That was what your
17 recollection of the discussion was?
18 A. No; not necessarily. I mentioned earlier that I
19 didn't remember how many times I had been down to see
20 Marty before the January meeting. There was at least
21 one other -- at least one other in-person visit, because
22 I remember having a conversation with Jonathan and Ryan
23 in person, and we were, again, taking advantage of
24 Marty's very well stocked bar, where we had talked about
25 not only open government litigation, but civil rights
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1 issues generally. And that conversation left me very
2 favorably disposed philosophically. They both seemed to
3 be very earnest about civil rights issues generally. So
4 the sense that I think I had in this conversation we had
5 in January of 2014 was that open government litigation
6 would have just been one part of their practice. But
7 that would have been the part that I would have been
8 talking to them about. But I don't think that it
9 necessarily was limited to just open government.
10 Q. To your knowledge, at that point in time, was the
11 O'Boyle Law Firm, had it been formed yet?
12 A. I don't know.
13 Q. Do you have any idea as to when the O'Boyle Law
14 Firm was created?
15 A. I don't know exactly. No.
16 Q. And you testified that -- you said, I guess, in
17 your discussions with them, that the best way to set
18 this up was to do it through a not-for-profit entity; is
19 that correct?
20 A. In my opinion, and that wasn't a legal opinion.
21 That was more political than anything else. I think
22 there are some real advantages to having a nonprofit
23 function as an advocacy organization for open government
24 for a whole lot of reasons. It makes it less personal.
25 And frankly, there are so many problems with having lots
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1 of different plaintiffs. As I mentioned to you earlier,
2 I get contacted very regularly, if not daily, many times
3 a week, by citizens who have some hobbyhorse they are
4 riding that somehow they feel they need to get access to
5 public records. On a number of occasions, I have
6 referred those people to law firms. In fact, I referred
7 some to the O'Boyle Law Firm. I have referred to other
8 law firms as well.
9 One of the problems you run into -- and I say
10 this, I think, from the perspective more of the attorney
11 than anybody else. Plaintiffs are not always easy to
12 control. At the end of the day, the plaintiff is the
13 one in charge. They get to make the decisions. They
14 get to make the choices about settlement, and litigation
15 strategies, et cetera. If you have lots, and lots, and
16 lots of different plaintiffs, many of whom are very
17 passionate about a particular issue, I think very often
18 that clouds their judgment when it comes to how they
19 perceive the litigation.
20 And one of the advantages of having a nonprofit,
21 you would have more certainty from a legal side of
22 things. You would have more certainty about what you're
23 dealing with. For example, what I usually tell
24 attorneys that represent me, I'm usually willing to go
25 as far as they want to go. When they decide they want
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1 to hang up the spurs and resolve the litigation, I'm
2 happy to do that, as long as we do it in a way that is
3 resolved in favor of access. If an attorney wants to
4 keep going, and they want to do The Full Monty, I'm
5 perfectly fine doing that. The problem you run into,
6 and I've seen this first hand, you get a plaintiff who
7 is upset about some issue with their local government,
8 and all they want is their pound of flesh. And they
9 want to keep going, and they want to duke it out, and
10 they don't have any conception of the risk that the
11 attorney is taking as far as costs, and lost billable
12 hours, et cetera. And I understand that from the
13 plaintiff's perspective, because there was a time where
14 I was a neophyte, and I suppose my very early public
15 records lawsuit, I probably was not the ideal client.
16 Let's go for the throat. I want my day in court. I
17 want to be vindicated. That would be very trying for a
18 law firm to have lots, and lots, and lots, and lots of
19 people who have bees in their bonnets, who don't really
20 understand the legal process.
21 If you had a principal client that was a
22 nonprofit that was being controlled by someone who
23 understands the legal process and understands that the
24 objective is to get the records, but ultimately it's
25 compliance. That's what we are really about; not being
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1 1 vindictive. That would have been a better solution than
2 having a whole bunch of different clients, although
3 there is something to be said for having more than one
4 client, certainly, but that was my rationale for that.
5 Q. Obviously, these law firms, or in particular, the
6 O'Boyle Law Firm, is getting paid a fee to provide these
7 services; correct?
8 A. In my experience, the vast majority of public
9 records litigation ends up being done on a contingency.
10 It is pretty rare -- especially when we are talking
11 about if the plaintiff is an individual. I think it is
12 very rare that you have somebody who is willing to step
13 up to the plate and say, "I will be on the hook for a
14 whole bunch of money." I did that early on because I
15 had the money to do it. There was a time where I could
16 write a $50,000 check. That's a very distant memory.
17 I think that in that respect, I was exceptional
18 as a client, early on. I had the means to do it, and I
19 was willing to do it. Most people simply don't have
20 that capacity. And because of that, most cases are
21 litigated on behalf of individuals on a contingency
22 basis, so the firm is taking a lot of risks; costs they
23 may never get back, and of course under 119.12, the
24 attorney fee provision, it's reasonable attorneys fees.
25 And as you probably know, one of the tactics that is
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OBOYLE -vs- SWEETAPPLE
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60
1 very often employed by public agencies who find
2 themselves in public records litigation, is even one
3 liability has been established, at least all of the
4 examples that I'm familiar with personally, the judge
5 will say, I'm going to award attorneys fees, but I'm
6 going to reserve jurisdiction over the amount of fees.
7 You guys go work it out.
8 The problem for the plaintiff is they're still
9 paying their attorney. And that money that they spend
10 paying their attorney to negotiate the fees is not
11 compensable. So for example, you might have run up
12 $50,000 in legal fees, but you might spend another
13 $25,000 wrangling over the amount of fees. So you are
14 faced with sort of this okay, maybe I will get my 50,
15 but I will spend 75 in the process of doing it.
16 So the -- I don't think it would be a fair -- I
17 wouldn't say that they are being paid to do it. They
18 may get paid at the end. But again, it really comes
19 down to what the court awards.
20 Q. Understood. But ultimately, they are taking it
21 on a contingency with the expectation that after looking
22 at the file, they are going to prevail -- in their
23 opinion, they are going to prevail, and therefore, be
24 able to get a fee based upon the statute?
25 A. Well, if I'm consulting with them, they will
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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prevail.
MR. DESOUZA: Hold on, Joel. Objection to form.
Go ahead and answer.
A. I did. If I'm consulting with them, they will
win. And the reason that is, I won't be involved with a
case unless I'm confident of the facts. I don't care
about the motivations. I don't care what the objectives
are. Why somebody makes a request doesn't matter to me.
But I care very much about the quality of the facts. I
don't want to be involved with any public records
litigation at all unless I'm supremely confident that
it's going to prevail because bad facts make bad law.
I've been very fortunate. Most of the cases that
I've been involved with, the facts were very, very
clear, and thankfully, the judges were able to make the
right decision based on the case law. Unfortunately
that's not always the case.
BY MR. GOLDSTEIN:
Q. Understood. Following this conversation with
Jonathan O'Boyle and Ryan Witmer, did you have any
subsequent conversations with them in January 2014,
either verbally, by e-mail?
A. I can't say with certainty, but I think that was
probably the case. We probably did talk more than once.
Q. Do you have an idea of how many times? Was it 10
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OBOYLE -vs- SWEETAPPLE 62
1 times? 5 times?
2 A. I don't know.
3 Q. Why don't you take a look at Page 2 of what was
4 marked as Exhibit 1, and see if that helps refresh your
5 recollection as to the number of times you may have
6 spoken with them.
7 A. It looks like according to this, which again, I
8 cannot authenticate, one, two, three, four different
9 communications with Ryan -- four or five, one, two,
10 three, four.
11 Q. So that refreshes your recollection as to the
12 number of times you may have spoken with --
13 A. Well, again, I can't rely on this because I can't
14 authenticate it. Based on what you've shown me in this
15 exhibit, there are -- on this page, there appear to be
16 four indications that there were e-mails exchanged
17 between myself and Ryan Witmer. If I could authenticate
18 this, then I would have some confidence in saying yes,
19 that refreshes my memory, but it doesn't.
20 Q. When was the next time you spoke with Mr.
21 O'Boyle?
22 A. I don't know. I would be reasonably confident
23 that we must have talked, probably at least by phone,
24 about my travel arrangements to come down there when we
25 met on the 22nd. I actually, when I got down there to,
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February 24, 2016
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1 -- I guess it would have been in Delray. I went to a
2 Panera Bread and called him, and was having difficulty
3 reaching him on the phone, and ultimately went to his
4 house. And he came to his house and met me there that
5 night. And from there, he and I -- he said he wanted to
6 talk to me individually, just the two of us. And that
7 was the first time that he actually approached me about
8 creation of the foundation, and me going to work for the
9 foundation. And it was after that that he and I left
10 his house and went to in Italian restaurant. I had
11 chicken parmesan. It was really good -- or veal
12 parmesan. And that's when I met Jonathan. I think I
13 met him once before in person. The three of us had
14 dinner, kind of talked about things.
15 Q. That was in Florida?
16 A. Yes, in Delray, I think.
17 Q. And you said that was in -- when was it, January
18 22nd, 23rd?
19 A. I believe it was January 22nd. That's my
20 recollection.
21 Q. 2014?
22 A. Yes.
23 Q. During that meeting, did Jonathan O'Boyle
24 indicate what he was doing or where he was working?
25 A. Yes. As I recall, he -- and I mean this in a
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kind way. He was short of disheveled, looked like a guy
who had just come back from working a really long day.
He was commenting about getting the law practice up and
going and he was staying very busy.
Q. Did he mention where his office was or anything
along those lines?
A. I don't remember during that dinner if there was
any discussion about that. I don't remember.
Q. But he looked like he had been working on getting
his law practice up and going?
A. Yes.
Q. So in all likelihood, given the fact that you
were in Florida, that he was there trying to get his law
practice up and going in Florida? Would you agree
that's a fair statement?
MR. DESOUZA: Object to form.
A. You're asking me to speculate, in all fairness,
they own planes, and he is a pilot. So who knows. My
-- the context of that discussion was, yes, that he was
this was getting the law practice up and running in
Florida. That was my impression. I can't assert any
certitude about that. That's a redundancy. I can't be
certain about that.
BY MR. GOLDSTEIN:
Q. At that point in time, were you aware as to
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1 whether or not Jonathan O'Boyle was admitted to practice
2 law in Florida?
3 A. Yes. I was -- it was my understanding that he
4 had passed the Bar, but had not yet been licensed in
5 Florida. He's a very bright young guy. As I recall, he
6 was already licensed in two other states, I think New
7 Jersey and Pennsylvania. And my layperson's
8 perspective, I expected anybody that was smart enough to
9 do that in two states wouldn't have any trouble in
10 Florida.
11 Q. Now, following this dinner, is that when you had
12 the meeting just with Martin O'Bolye?
13 A. No. we had the meeting beforehand. And our
14 meeting sort of continued. we went to dinner, had a
15 very nice dinner with Jonathan. And after the dinner,
16 Marty and I, we rode there together in Marty's car, and
17 we rode back to his house in his car. And we actually
18 sat in the parking lot of the restaurant and chatted for
19 a bit, and kind of talked more about some of the
20 mechanics of -- he had already made an offer to me, and
21 we were kind of batting back and forth. And this was
22 actually, over the course of several days I was there.
23 And we kind of went back and forth about how we were
24 going to work things out, and what it would look like
25 for me to actually go to work for the foundation.
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1 Q. What were the specifics of your conversation with
2 Mr. O'Boyle regarding the foundation?
3 A. Well, his initial offer was actually quite
4 generous. He offered to pay me $75,000 a year, and that
5 they would give me a new car, and cover all of my travel
6 expenses. So this was -- for me, felt like Christmas.
7 I do most of -- all of my advocacy for free at my own
8 expense. And it's been economically disastrous for me.
9 So for somebody to suddenly say that I didn't have to
10 worry about putting food on the table, was a huge
11 relief. But much more important to me than that were
12 the economic resources that I would have to do my
13 advocacy.
14 I think it's pretty clear from my economic
15 history since I have been doing advocacy that I'm not
16 money motivated. I don't care. I have been broke for a
17 long time and I'm perfectly happy to continue to be
18 broke. I'd rather not be broke, but I don't do this for
19 the money. I do it because I believe in civil rights.
20 And to have somebody with Marty's resources tell me
21 that, I will fund your work that you are already doing
22 for free, was an enormous positive for me. Because not
23 only did it mean that I could keep doing my work, but it
24 meant that I could do it much more effectively. I could
25 reach out to a lot more people. I could impact, I think
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1 positively, a lot more lives.
2 So part of this was trying to plumb the depths of
3 the commitment, because I have a pretty vivid
4 imagination. So when somebody who is wealthy tells me,
5 "I'm going to fund your advocacy," I'm trying to figure
6 out what does that look like? Let's get down to
7 numbers. And Marty is very coy, and very charming, and
8 just enormously winsome. And each time I asked him, it
9 was sort of, "Whatever it takes," was his response.
10 So for example, I was trying to get a sense of
11 what would my budget be for travel, because what I'm
12 imagining is going around and meeting with black
13 churches all over the state of Florida and talking to
14 people about civil rights issues, or meeting with
15 student groups. I'm thinking I'm going to be zigzagging
16 all over the state. What is my budget?
17 His response each time was, "Whatever it takes."
18 And then of course the issue of litigation came
19 up. My -- I'm not naive. I understood that his son was
20 starting a law practice. I already talked to Jonathan
21 about at least part of the nature of the law practice
22 being open government litigation. I know from my own
23 experience, and even at that time, that if you do the
24 kind of work that I do, you're going to run into
25 violations of the law that if they are going to be
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1 resolved, they are going to have to be resolved in
2 court. And that generates lawsuits and that generates
3 legal fees. So I got that part of this was a business
4 decision, that financing my advocacy very likely would
5 have a byproduct of lawsuits that needed to be
6 litigated.
7 So I asked him, what is your tolerance for pain
8 for filing fees, for example, as you know, usually $400
9 plus service, plus summons, all that, costs 500 bucks
10 just to get a case started. He said, "Whatever it
11 takes." So he asked me, "Well, how many cases do you
12 think you could come up with?"
13 My response was, "What about 100?"
14 He was like, "No problem."
15 So I was like, "What if I came up with 100 in a
16 month?"
17 "No problem."
18 Well, that would be 1,200 in a year. What if it
19 was 2,000? No problem. What if it was 3,000? No
20 problem.
21 So we never really came up with any kind of
22 concrete budget, but it was, I will pay you 75,000 a
23 year, cover all of the expenses -- reasonable expenses
24 you've got for doing your work, and he suggested that I
25 hire an assistant. And we talked -- I think the number
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JOEL CHANDLER Volume 1 of 2
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he suggested -- and these were only suggestions, I
think, I pay them $60,000 a year or something.
And this conversation kind of went back and
forth. One of the things that I -- the only real
hang-up that he and I had in this discussion was that I
wanted to continue to be able to do my own thing. I
wanted to be able to continue to do pro se litigation.
And he felt very strongly -- in fact, this is one of the
things we talked about outside of the restaurant that
first night on the 22nd, was that he did not want me
doing that. He wanted my full attention. And so over
the next several days, I kind of toyed with what that
looked like for me.
So ultimately, one afternoon we were sitting
outside his house by the pool, and that's when we kind
of finalized things. I said I want 120 grand a year,
and he agreed to that, and off to the races we went.
Now, during that discussion, I laid out some
conditions. One was that there could not be an enemies
list. What I meant by that was, I don't care about
people's motivations, and I don't care about other
people's objectives. I care very much about my
motivations and I care very much about my objectives.
I don't judge somebody for making a bunch of
public records requests for whatever it is they want, to
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JOEL CHANDLER Volume 1 of 2
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1 whatever agency they want. They have the right to do
2 that. That does not necessarily mean that's good
3 advocacy. What I'm interested in is strengthening the
4 public's right to know; not doing things that are
5 deleterious to that right. And for that reason, I
6 thought it would be disastrous if the foundation was
7 picking on one agency, or conversely, was -- I want to
8 be sure nobody was off limits. I don't care if you are
9 golfing buddies with the governor -- not saying that he
10 is. If the deal is I can't go after the governor, then
11 screw it. I'm not in. I have to have carte blanche, I
12 can go after whoever I want to go after, and I don't
13 have to go after anybody in particular. And he was very
14 agreeable to that.
15 I was very concerned about the independence of
16 the foundation. I thought it would be disastrous if it
17 turned out that the foundation was nothing more than one
18 individual's instrumentality. I got his assurances that
19 it would be independent. I insisted that I would have
20 sole discretion about litigation. Obviously, I knew I
21 would serve at the pleasure of a board of directors,
22 which I'm perfectly fine with. In fact, I welcomed not
23 having to worry about finances, and I won't have to
24 balance a checkbook or any of that stuff. Just give me
25 a paycheck, cover my expenses, let me do my thing. But
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1
I was very concerned that
it be independent, that nobody
2
would be directing behind
the
scenes what happened. I
3
wanted to be able to make
the
requests that I wanted to
4
make, and I wanted to be
able
to engage in the
5
litigation that I thought
was
appropriate.
6
One of the reasons
for
that concern was in my
7
first visit to their offices
in
2013 when I reviewed all
8
of these
public records requests
made
to
the
State
9
Attorney's
Office, I rejected all
of
them
as
far as
10 whether or not they were worthy of litigation. And in a
11 very nice way -- he was not ugly about it, but Marty
12 made it clear that he was disappointed that I was so
13 persnickety about the quality of the cases.
14 I have tried to winnow out in my own work,
15 anything that -- if it's got a whiff of a good defense,
16 1 I don't want to do it. And I did not want to be in a
17 position where I had to constantly argue with people
18 about whether a case was worth litigating or not
19 litigating. Cases are so plentiful. Violations of the
20 Public Records Act are so common, and very often very
21 egregious. It's not hard to get really, really good
22 facts. And you've got to be really -- in my opinion,
23 you have to be really picky.
24 And so that was one of my real concerns. I
25 1 wanted to be sure there wouldn't be any pressure from
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 72
anybody else. I got to make those decisions. while I
was very, very willing to give the lion's share of cases
to the O'Boyle Law Firm, I also wanted the discretion to
be able to give cases to other law firms when I thought
it was appropriate.
So that was sort of the nature of our
conversations. And as I said, that transpired over
several days. It was never adversarial. It was very
pleasant. Marty is a very hospitable man.
Q. You testified you were very willing to give the
lion's share of the work to the O'Boyle Law Firm. Was
that one of the conditions?
A. No. It was not. And I made that point that I
wouldn't do this if the condition was -- I understand
that if I go out and I make 100 public records requests,
I know from experience that if I make those public
records requests to publicly operated agencies, cities,
counties, whatever, that about 30 percent of those are
going to give me the middle finger. And I'm not talking
about little, minor technical violations. I mean tell
us your name or you don't get the records. Or you have
to make your requests and it has to be notarized, and it
has to be sent to us by certified mail.
I know that if I go out and make 100 public
records requests to municipalities, that I'm going to
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JOEL CHANDLER Volume 1 of 2
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1 1 get about 30 of those. Now, that doesn't mean all 30 of
2 them are worth litigating. But certainly, I would guess
3 on average, about 20 of those would be. They've --
4 somebody's got to litigate them. One of the real
5 problems that I had with law firms prior to this was
6 bandwidth. Most law firms didn't have the capacity to
7 take on a lot of public records lawsuits because they
8 are contingency, and they've got bills to pay. They
9 need some certainty, and they have somebody waving a
10 check at them, they are going to take the guy that is
11 willing to pay as he goes versus a contingency case.
12 And then the other issue is the cost. The filing fees
13 alone can be prohibitive if you're doing a lot of
14 lawsuits.
15 So here I have two young attorneys who seem very
16 passionate about open government, about civil rights
17 issues in particular. They know a lot more than most
18 attorneys in Florida about public records issues, which
19 isn't saying very much, because I could take the
20 collective knowledge of most attorneys, and it wouldn't
21 fit on a postage stamp when it comes to open government
22 issues in Florida. But they seemed pretty knowledgeable
23 in comparison with most other attorneys. And I had
24 somebody who was willing to finance it. It didn't need
25 to be a condition, because I knew going into it that
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 74
it's not like there's some other law firm saying, "give
us 50 cases in a month." I don't know anybody that
could do that. It wasn't a condition. It was just a
fact. It was a circumstance. Here you have two guys
who are well financed and are hungry for the work. If
somebody is going to be paying me to go out and do my
thing, then there's a good chance that there are going
to be cases needing to be litigated.
But it was never -- in our preliminary
discussions, it was never in my agreement to work with
the Citizens Awareness Foundation, that you have to go
out and get X number of cases and give them to the
O'Boyle Law Firm completely. Now, eventually, that very
much became the case. But I would never have agreed to
do it had that been a condition in the first place.
Q. Backtrack to a couple things you said; the first
being, you said that you have these two young attorneys
who are well financed. How did you know they were well
financed?
A. They would have -- I didn't understand how the
financing was going to be done. I didn't know if --
when I asked Marty, what if I come up with 100 cases in
a month, or 3,000 in a year, what is your tolerance for
pain? He was -- clearly, my understanding was he was
the guy that was going to make those funds available. I
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JOEL CHANDLER Volume 1 of 2
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1 didn't know if those funds were going to go to the
2 Citizens Awareness Foundation, and the Citizens
3 Awareness Foundation was going to pay its own filing
4 fees, or if the money was going directly to the law
5 firm. I didn't know. But what I was being told is the
6 bandwidth that I was always concerned about with other
7 law firms, was a nonissue here. We have all of the
8 bandwidth you want. We can take as much as you bring
9 us. Now, that ended up not being true. They couldn't
10 keep up. But you know, I'm prolific.
11 Q. So was it your understanding that Mr. O'Boyle was
12 financing, in one way or another, both the foundation
13 and the law firm?
14 A. Yes. That was my understanding. I don't recall
15 ever seeing any documents that would show that, but that
16 was my understanding.
17 Q. You agree you weren't privy to whatever documents
18 or agreements that would have been put together in terms
19 of financing of the law firm; correct? You more than
20 likely wouldn't have been privy to any financing
21 agreement or respect to that for the law firm.
22 A. No. I had no -- never had any access to any
23 financial anything. I mean, for the foundation or for
24 the law firm. I mean, I wasn't a party of the law firm,
25 so that goes without saying. But even the foundation, I
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1 didn't have access to checks. I didn't have accesses to
2 cash. I ultimately got a credit card. I used Marty's
3 card for awhile until the foundation got its own credit
4 card. I didn't want any of that. That is not my cup of
5 tea. I just didn't want it because I didn't want it.
6 But beyond that, I was relieved not to have that
7 responsibility.
8 The reason I believe in open government is
9 because I believe all men are utterly and totally
10 depraved. I believe in total depravity. And I have no
11 doubt that if I were given an unlimited budget and no
12 accountability, I would abuse it. And I think everybody
13 at this table would. And I was relieved to not have to
14 worry about that. I had to answer to somebody else for
15 how I spent the foundation's money, and I didn't have to
16 worry about accounting.
17 Q. Just so I'm clear, was it your understanding or
18 impression that Mr. O'Boyle was financing both the
19 O'Boyle law firm and Citizens Awareness Foundation?
20 A. Yes. Just call it CAFI. Yes, that was my
21 understanding.
22 Q. When you had these discussions was CAFI already
23 formed --
24 A. No.
25 Q. -- entity?
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JOEL CHANDLER Volume 1 of 2
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Q. Do you know when CAFI was, in fact, formed?
A. I believe it was January 27th. So the timeline
goes like I go down there on the -- Marty and I have
e-mail exchanges, phone calls, whatever, first part of
January. I'm contemporaneously having conversations
with Jonathan and Ryan about maybe working together,
figuring out some way to do that. Then the idea of a
foundation or a nonprofit kind of floated out there in
this sort of amorphous way. January 22nd, I meet with
Marty. This is the first time we actually had this
discussion about any concrete, hey, this is really what
I want to do. I'm delighted at that. Then I stayed at
his house. He was very, very -- he and his wife --
MR. DESOUZA: You guys are silent. Is that on
purpose? We haven't heard anything for the past 30
seconds.
THE WITNESS: Can you hear me?
MR. DESOUZA: Yes, I hear you. I didn't know if
you had taken a pause.
THE WITNESS: No. I've been talking this whole
time.
MR. DESOUZA: We haven't heard anything for the
last 30 seconds.
THE WITNESS: Can you give us an idea of where
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1 that goes back to?
2 THE WITNESS: What's the last thing you heard,
3 Dan?
4 MR. DESOUZA: That's a good question. You're
5 putting me on the spot. We had been talking about you
6 and Marty, and you had given a pretty long answer,
7 then Josh asked you another question -- or he was
8 starting to ask you a question, but then I didn't hear
9 what the last question was.
10 MR. GOLDSTEIN: Or the answer?
11 MR. DESOUZA: I assume I didn't hear the answer
12 either. It just got quiet for about 30 seconds.
13 Maybe if you go back to whatever the last question
14 was, that would be helpful for us.
15 THE COURT REPORTER: The last question was, "When
16 you had these discussions, was CAFI already formed as
17 an entity?"
18 And the answer was "No."
19 The next question was, "Do you know when CAFI
20 was, in fact, formed?"
21 The answer was, "I believe it was January 27th,"
22 and then he began talking about the timeline.
23 Had you gotten any of that, or do I need to go
24 back farther?
25 MR. GOLDSTEIN: Dan, do you need us to start
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2 MR. DESOUZA: If that was the last question, the
3 question was when was CAFI formed, then Joel gave an
4 answer, I'm fine if you move on to the next question.
5 I will just get the transcript and see what the full
6 answer is, as opposed to repeating the full answer.
7 MR. GOLDSTEIN: I don't think he was done.
8 THE WITNESS: It was started on -- I believe it
9 was January 27th. So I was getting ready to say I go
10 down there on the 22nd. I stayed at Marty's house. I
11 was getting ready to pay Marty and Sheila a compliment
12 about what wonderful hosts they were. They were very,
13 very super sweet hosts. So I stayed at their house.
14 And we had these discussions.
15 And leading up to that, we had a conversation,
16 "we" being me, and Marty, and I think Bill Ring may
17 have been part of this -- that there was already a
18 not-for-profit that had been created. And I don't
19 know the name of it. Jonathan was on the board. So
20 the suggestion was we would just use that. And I
21 objected to that. And again, it wasn't adversarial.
22 I just didn't think it was a good idea. They talked
23 about we will remove Jonathan from the board. I said,
24 well, the problem with that, it's already public
25 records, and it wouldn't take a rocket scientist to
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figure out he had been on the board. And I just, for
appearance sake -- I didn't think it was a legal
issue, but for appearance sake, I didn't think it was
a good idea, that we should start fresh. It was
sometime after that that they came back and I think
Bill Ring is the one that came up with the name, which
nobody consulted me about that, which is fine. I
wasn't crazy about the name. But I was told it's
Citizens Awareness Foundation. That's who you work
for.
And I actually went out and started working on
the 27th. That was my first day. The day it was
created is the day I went to work.
BY MR. GOLDSTEIN:
Q. What was the name of the nonprofit that Jonathan
O'Boyle was on the board of?
A. I don't know. I already said I don't know.
Q. I believe you testified that there was supposed
to be an independent board of directors for CAFI;
correct?
A. Yes.
Q. Do you know who the initial board of directors
were for CAFI?
A. Yes. I believe that there were three, if I'm not
mistaken. Bill Ring was the president. Denise
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1 DiMartini was an officer and Brenda Russel was an
2 officer.
3 Q. Would you say that those three individuals were
4 free of influences of Mr. O'Boyle?
5 A. No. They were not.
6 MR. DESOUZA: Objection, form.
7 BY MR. GOLDSTEIN:
8 Q. Do you know what William Ring's relationship to
9 Martin O'Boyle was?
10 A. They worked together. I have described all three
11 of them as longtime employees. And again, I don't know
12 which exact corporations they worked for or technically
13 what their working relationship is with Marty, but they
14 have worked for Marty or with Marty for a very long
15 time.
16 And I was a little, at first, a little concerned
17 that gee, these are -- I was not crazy about them being
18 the board members just because it looked like -- because
19 of the connection. With that said, I had not yet met
20 Denise. I had never even talked to her on the phone. I
21 met Brenda a couple of times. She's a very nice lady.
22 And I had met Bill a number of times and really liked
23 him. He was very, very nice, very pleasant, always very
24 cordial.
25 But it was clear to me from my discussions with
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Bill that he was not super knowledgeable about open
government law in Florida, and I kind of assumed that
was probably the case with Denise, and that was very
much my impression from Brenda. They didn't strike me
as being -- they struck me as being ambivalent about
open government issues in Florida, not hostile and not
all hopped up about it either. And frankly, I sort of
view them as figureheads. They're going to watch the
piggybank so Joel doesn't steal any money, and they're
not really going to interfere with what I do. We have
to have somebody on the board of directors and I have
somebody I'm responsible to for the money. But other
than that, they are really not going to interfere with
me. So I kind of let it go at that point.
MR. GOLDSTEIN: I'm going to show you what I'm
going to mark as Composite Exhibit 2.
(Defendant's Exhibit No. 2 was marked for
identification.)
MR. GOLDSTEIN: Composite Exhibit 2, just so you
know, Dan, is a printout from Florida Division of
Corporations and the filings for Citizens Awareness
Foundation.
MR. DESOUZA: The stuff you pull off of Sunbiz?
MR. GOLDSTEIN: Correct.
MR. DESOUZA: Okay.
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1 BY MR. GOLDSTEIN:
2 Q. Have you seen those documents before?
3 A. I have seen documents from Sunbiz relating to the
4 corporate registration of Citizens Awareness Foundation.
5 Q. Do you believe that the corporation documents
6 that are attached to what was marked as Composite
7 Exhibit 2 accurately reflect your recollection of who
8 the initial board of directors were?
9 A. I can't authenticate it because I didn't get it
10 off Sunbiz myself, but it looks like a Sunbiz document
11 to me, and the filing date is January 27th, 2014, which
12 is my recollection. And the initial boards of directors
13 conforms with my recollection as well. Looking at the
14 Articles of Incorporation, it lists William Ring, Brenda
15 Russel, and Denise DiMartini as the directors.
16 Q. What was your understanding of Mrs. DiMartini's
17 relationship with Mr. O'Boyle?
18 A. That she worked for him.
19 Q. And the same for Brenda Russel?
20 A. Yes.
21 Q. And you said that you went to work for CAFI
22 immediately the next day; is that my understanding?
23 A. The day it was started on January 27th, if I'm
24 not mistaken; that's my recollection. And I will look
25 at my calendar. I believe that was a Monday, if I'm not
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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wrong. It was a Monday. I met with Marty on Wednesday
the 22nd. That's when I first came down. I stayed at
his house, then on the 27th I went to work. I actually
went out and started doing my thing that day.
Q. So you went out from Mr. O'Boyle's house and you
started making public records requests?
A. As I recall, yes. That weekend I went ahead and
-- I think I went home that weekend just for a day. And
then there was a fellow that I knew through PMJA, a guy
named Terrell Elliston. When I went back down to South
Florida, I didn't stay at Marty's house. I checked into
a hotel and had Terrell and his wife, Angel, drive down
from Winter Haven to meet with me because I wanted to
hire him to be my coworker at the foundation. And I if
I'm not mistaken, I think they came down Sunday evening,
and we met at the hotel. And I -- with funding from
Marty or the foundation, I got a hotel room, took them
to dinner, and talked to him about coming to work for
me. And Angel stayed at the hotel that Monday, and
Terrell and I actually went down to -- we started in
Florida City. And we just went from one little
Miami -Dade County municipality to another making public
records requests, and it was just the Wild West. It was
unbelievable how lawless they are down there.
Q. So Terrell was his name?
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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A. Yes.
Q. Did he ultimately start working for the
foundation?
A. Yes and no; we agreed that he would come work for
the foundation. I told Marty that he was going to come
to work for the foundation. And Terrell and I are very
close and have a very good relationship. But I think he
was down there for a day or two, then he went back to
Winter Haven and called me and said he changed his mind
and didn't want to do it. It was -- part of that, I
guess, was money, and I don't know. It was sort of --
we left on -- we parted on very good terms and we are
still on very good terms, but -- so he actually never
got paid. I wanted -- I insisted that we pay him for
the day or two he worked, and he refused, very
graciously. It wasn't hostile.
So anyway, I was back working by myself. And not
long after that I hired a woman by the name of Cathy
Zollo, Z -o-1-1-0, who is an award winning investigative
journalist, newspaper journalist in Sarasota that I had
done some work with. And so she came to work for the
foundation. She stayed in Sarasota. At least when I
was with the Citizens Awareness Foundation, she never
went to the offices. I had her come over and meet me
one day in Deerfield Beach with a guy by the name of
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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Dylan Boucher, which I can't spell, who I hired as an
intern through a civil rights activist friend of mine
that introduced us.
I was actually out the first day. If I'm not
mistaken, the first day I came back with 10 smoking hot
perfect fact lawsuits. They were just -- the very first
place we went was Florida City, and the police
lieutenant, when I asked to inspect and photograph their
sign -in log and visitor log, which was public record and
couldn't possibly be exempt because they hand it to
everybody who walks through the door and makes them sign
it. The response I got was, you have to make your
request in writing, it has to be notarized, and you have
to send it certified, certified mail. And they were all
like that, just one right after the other, egregious
violations of the Public Records Act.
Q. Who got those lawsuits?
A. The O'Boyle Law Firm.
Q. And prior to assigning those 10 smoking hot
lawsuits to the O'Boyle Law Firm, you had never done any
work with them previously; is that correct?
A. Yes, that's true, with the O'Boyle Law Firm.
Right.
Q. And you gave those cases to them despite your
ability to assign them to anybody?
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1 A. Yes. They were -- wanted the work. They had
2 communicated to me both in word and deed that they were
3 open to my critique and wishes as far as how cases would
4 be litigated. Both Jonathan and Ryan were very --
5 seemed very eager for my input to try to benefit from my
6 experience. They were local. They're in South Florida.
7 It wasn't Miami -Dade County, but they're local. And the
8 experience that I did have with -- I didn't have any
9 experience with the O'Boyle Law Firm, but I did have
10 some experience with Ryan. He had worked as Bill's
11 paralegal, and Bill represented me in my one and only
12 lawsuit that I filed against Gulf Stream before the
13 foundation was created. So I knew that he had
14 experience, limited experience, but they seemed to do a
15 pretty good job. When I sued Gulf Stream, they seemed
16 responsive to my concerns as a client. We were,
17 thankfully, able to resolve that lawsuit very amicably
18 and very cost effectively. I think they -- the town
19 ended up paying my attorneys fees, which were something
20 like $1,200, something very modest. So I felt pretty
21 good about giving it to them.
22 Q. Just so I'm clear, prior to the foundation, you
23 had used the O'Boyle Law Firm?
24 A. No. I had not used the O'Boyle Law Firm. I had
25 worked with Ryan, who had passed the Bar, but had not
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1
been yet licensed,
and was working as a
paralegal
for
2
Bill Ring, who was
a licensed attorney,
who took
the
3
case against Gulf
Stream. The way that
they had
far as civil
4
interacted with me
as a client made me
feel good
about
5
the personalities
involved. And Ryan was
now, as
I
6
understood it, a managing
partner of the
O'Boyle
Law
7 Firm, and Ryan had been very pleasant. He was -- I
8 liked him. We really clicked on a personal level.
9 Philosophically we seemed to be aligned about advocacy
10 and the importance for civil rights and importance of
11 open government. He seemed to be very much aligned with
12 my perspective on how we should handle litigation. And
13 I felt that way about Ryan pretty much the whole way
14 through my experience with the O'Boyle Law Firm. I
15 don't really have any -- off the top of my head, I
16 really don't have anything to offer that would be a
17 criticism of Ryan other than, you know, I wish he had
18 been more forceful about some of the ultimate concerns
19 that we both shared. But I think Ryan was a good guy.
20 I think he was a good attorney. So I had no problems
21 giving it to him.
22 I didn't have any experience with Jonathan as an
23
attorney, but
he seemed very
bright and
articulate.
24
From personal
conversations I
had with
him, it seemed
25
like we were
philosophically
aligned as
far as civil
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1 rights issues were concerned. I had certainly worked
2 with other law firms with whom I had a lot less contact
3 than the principals of the O'Boyle Law Firm, and I had
4 been willing to give business, my own business, to other
5 attorneys, which for the most part, didn't turn out
6 well. So I felt pretty good about it.
7 Q. Now, correct me if I'm wrong, but is it my
8 understanding that Bill Ring was actually in-house
9 counsel for the Commerce Group?
10 A. My understanding is he's an attorney, and he
11 works for the Commerce Group. I don't know that he's
12 their in-house counsel. My impression -- this is purely
13 my impression, is that Bill's career has not really been
14 as a litigator. I very much got the impression in the
15 lawsuit that he represented me in against Gulf Stream,
16 that this was -- he had not done very many lawsuits.
17 That was the impression I got. It wasn't in any sense
18 of a lack of competence on his side. He just -- my
19 impression was he didn't really use his law license very
20 much for what he did for work day-to-day with the
21 Commerce Group. I could be completely wrong about that.
22 That was just the sense that I had.
23 Q. At the time he represented -- Mr. Ring
24 represented you individually, do you know where his
25 office was?
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JOEL CHANDLER Volume 1 of 2
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A. I assume it was at the Commerce Group. I was not
aware of him having any other address. I never visited
him or talked to him at any other location that I can
recall.
Q. Citizens for Awareness Foundation, when it was
incorporated, did it have an office?
A. It's Citizens Awareness; not Citizens for
Awareness, CAFI. I worked out of my home here in
Lakeland. But whenever I went down to South Florida to
Deerfield Beach, the address that is on the articles of
incorporation and the address that I had on my business
cards, and the address that I used for Citizens
Awareness Foundation was the same address as the
Commerce Group.
Q. Did the O'Boyle Law Firm have physical office
space?
A. Yes.
Q. Where was their office space?
A. A big room in the back of the same office.
Q. So the O'Boyle Law Firm was in the back of the
office space where CAFI was?
A. Yes. I mean, again, CAFI, at this point, not
necessarily on the 27th, because I don't remember the
exact date that Cathy Zollo came to work for the
foundation. It was within a few weeks. She never went
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1 there, as far as I know, never. She never was there
2 when I was there.
3 There were no other employees. It's not like
4 there was a CAFI staff. It's not like we had our own
5 lunchroom or even an office. When I was there, I would
6 use whatever empty desk was around. I didn't -- as far
7 as I know, I don't think I had an extension or anything.
8 I'd use an empty -- it's a big office. I would find
9 some empty spot, and that's where I would light for a
10 little while. But most of the time I was there, I was
11 back talking to the attorneys because we had cases to
12 litigate. And most of my work didn't involve being
13 inside an office. Most of my work involved going out
14 and meeting people, either meeting public officials or
15 meeting with civil rights groups, or citizens groups, or
16 student groups.
17 MR. DESOUZA: Just confirming we didn't lose
18 sound?
19 MR. GOLDSTEIN: No. I'm looking at my notes.
20 MR. DESOUZA: I'm going to say on the record,
21 given that it is nearly 2:00 o'clock, Mr. Chandler is
22 not my witness, so obviously I don't control his
23 schedule or anything. But we have been going for a
24 few hours now and I don't know what any of these
25 questions have to do with Mr. O'Boyle's slander claim
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1 against your client or the retaliation claims asserted
2 against Gulf Stream. So I'm going to assert a
3 standing relevance objection to all of this. And
4 you'll do what you'll do, but I'm saying it's 2:00
5 o'clock, and I don't know that we've heard a single
6 question relevant to slander at this point.
7 MR. GOLDSTEIN: I think it goes directly to the
8 truth of the alleged statements. You can make
9 whatever relevance objection you want, but I believe
10 it goes directly to defense of the fact that the
11 statements that were made were, in fact, true.
12 MR. DESOUZA: Yes, but I think Judge Marra might
13 disagree with you. He's already denied an entire RICO
14 claim based on these exact allegations. I'm not going
15 to argue with you over the phone about it. I'm just
16 saying, at some point, I would like to ask Joel some
17 questions, as well, that actually relate to what your
18 client said and when. I guess if we don't get there
19 today, then we will come back and bother Mr. Chandler
20 again to actually ask him questions that I think are
21 relevant.
22 But go ahead. I don't want to interrupt or cause
23 this to go any further than it has to.
24 THE WITNESS: I hope you guys brought overnight
25 bags.
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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MR. GOLDSTEIN: No.
BY MR. GOLDSTEIN:
Q. Did you enter into any kind of employment
agreement with CAFI or Mr. O'Boyle with respect to your
retention there?
A. Yes. That was one of the other sticking points
with Marty. And again, when I say "sticking points,"
all of our conversations leading up to my employment
were always very civil. In fact, I don't remember ever
having a conversation with Marty that wasn't civil up
until my resignation, and after my resignation. But I
wanted a contract. I proposed a five-year contract, and
he demurred. And then I proposed at least a one-year
contract, and he again demurred and said we should try
it and see how it works out.
So I think in sort of a compromise, he asked me
to draft a memorandum of understanding that outlined our
agreement, and I did that, and sent it back and forth to
him several times, and he would make -- mark it up and
make suggestions about changing it, and ultimately we
came to one we both, I think, agreed to. I executed it
and gave it to -- I don't know if I gave to Marty or I
gave it to Brenda Russel, but I gave it to somebody
there and I never got a copy of it back. But that was
the basis of my employment arrangement.
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1 All of the discussions I had about going to work
2 for CAFI were with Marty. I never had any discussions
3 with any of the board members about it.
4 Q. So following your starting to work on the day
5 that the foundation was formed on the 27th, did you have
6 any subsequent conversations during the month of January
7 with Mr. O'Boyle?
8 A. Yes, sure.
9 Q. When was the next time you spoke to Mr. O'Boyle?
10 A. I couldn't tell you when. I was in and out of
11 the office a lot because I was concentrating my efforts
12 in South Florida for several reasons. One is it's the
13 Wild West. And it's not very hard to find examples of
14 egregious violations of the Public Records Act. And to
15 put that in context, it wasn't just me going out and
16 seeing if I could find a lawsuit. I was videotaping
17 these encounters and ultimately published many of these
18 videos as examples of what public officials should not
19 do, a whole bunch of these.
20 And so I was -- and the other reason I was
21 concentrating on South Florida, it was convenient for
22 all of the parties involved. If we are going to do
23 litigation, might as well do it some place where the
24 attorneys don't have to drive a long way. And I also
25 love South Florida and I love the ethnic culture, and
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the food, and the Neapolitan nature of the vibe down
there. So I was there a lot. And I stayed at Marty's
house when it was convenient, and he was very, very
gracious about that. And I mean I had the access code
to get in the house. And in fact, I shared many family
meals with Marty and Jonathan and Sheila, his wife,
Marty's wife, who is a lovely, lovely lady.
And then I would see Marty some in the office.
He travelled a good bit, but when he was there, I'd see
him, and he was always very gregarious. So we talked a
lot. And when I stayed at his house, if -- I only
stayed at his house when he was in town. He's an early
riser, and I knew that seeing him at the office was
sometimes difficult because he had a lot of businesses
he was running. So very often, I guess probably every
time that he was there at the house and I was there, I
would meet him downstairs for coffee 5:30 or 6:00 in the
morning. And we, just the two of us, would sit there in
the dark, and drink coffee, and have conversations about
life, and open government, and sort of how my job was
going. And they were always very pleasant
conversations.
Q. Do you recall having any conversations with a
Robert Tweel?
A. Yes. Yes. I don't know that I would
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characterize it as me having a conversation. It was
more that I was sitting in on a conversation. I think I
talked very little. But Marty contacted a guy named Bob
Tweel who, as I understand it, is a very accomplished
tax attorney in West Virginia. And we had a
conversation about -- or discussion about the nonprofit
status or gaining nonprofit status as a 501C3.
Completely uncharted territory for me, and I got the
impression it was uncharted territory for Marty, and we
were trying to make sure we were on the right side of
the law and doing things that wouldn't get us into
trouble.
Q. Did you recall any of the conversations as to
some of the things that were required in order to give
an appearance of being an appropriate nonprofit
corporation?
MR. DESOUZA: Hold on, Joel.
Josh, could you repeat the beginning of that
question. It blanked out and I got the second half of
it.
BY MR. GOLDSTEIN:
Q. Sure. The question was, do you recall what was
discussed with Mr. Tweel in terms of the requirements as
far as 503 --
MR. DESOUZA: I'm going to object on the basis of
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1 privilege at this point, because if Mr. Chandler was
2 working as a representative of CAFI, and CAFI and
3 Marty were seeking legal advice from Mr. Tweel, I'm
4 going to instruct Joel not to answer on the basis of
5 privilege because it sounds like he was a CAFI
6 director or whatever his position was with CAFI at the
7 time. So I think unless you establish otherwise, I'm
8 instructing him not to answer.
9 MR. GOLDSTEIN: What was the position that Mr.
10 O'Boyle had with CAFI?
11 MR. DESOUZA: Well, I think it's entirely
12 plausible that Mr. O'Boyle and CAFI are jointly
13 seeking legal advise from an attorney, this guy named
14 Bob Tweel.
15 1 MR. GOLDSTEIN: He's not a director or officer of
17 MR. DESOUZA: What part of "jointly" is hard to
18 understand? It's entirely plausible that Mr. O'Boyle
19 individually, and CAFI as an entity, who has some
20 financial relationship between them, are seeking tax
21 advice from an attorney.
22 MR. GOLDSTEIN: So if Mr. O'Boyle had a
23 conversation with Robert Tweel wherein Mr. Chandler
24 just so happened to be present, you believe there is a
25 privilege? Is that my understanding?
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JOEL CHANDLER Volume 1 of 2
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MR. DESOUZA: Let me make this a little bit
simpler for you, Josh.
Joel, I'm instructing you not to answer. If you
choose to answer, that's your prerogative. I'm
instructing you as the attorney for Mr. O'Boyle, in a
separate case, the attorney for CAFI, not to answer
the question.
And Josh, we can go at it until we are blue in
the face, but that's my instruction.
MR. GOLDSTEIN: But you don't represent Mr.
Chandler here today; correct?
MR. DESOUZA: I do not. However, as a
representative -- look. We can keep going on the
transcript back and forth like this. I gave my
instruction, told you why I thought it was privileged.
I don't control Mr. Chandler. If he wants to answer
the question, he can answer the question. If he
chooses to follow the instruction, he chooses to
follow the instruction. We are not talking rocket
science here.
MR. GOLDSTEIN: It's up to you whether or not you
want to answer the question or not.
THE WITNESS: Well, I'm not going to refuse to
answer the question, but I certainly take great value
in the attorney-client privilege and I'd loathe to do
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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something that somebody else feels would violate their
own privilege. I'm not in any adversarial posture
here with either of the attorneys speaking on the
record now. But I'm sort of at a loss of whether I
should answer the question. If you want to contact
the judge and let the judge instruct me, I'm more than
happy to defer to the judge. But in the absence of
that, I'm inclined to not answer the question, not
because -- I don't have any objection to it, but I'm
uncomfortable if somebody is asserting attorney-client
privilege. Seriously, if you want to get the judge on
the phone, I'm more than happy to do whatever the
judge wants me to do.
MR. GOLDSTEIN: Just so I'm clear, you are not --
you are refusing to answer the question or not going
to answer the question based upon Mr. DeSouza's
instruction?
THE WITNESS: No. I'm not refusing to do
anything. I'm asking that since I don't have legal
counsel -- let me finish.
MR. GOLDSTEIN: That's fine.
THE WITNESS: Since I don't have legal counsel
here today, I do not want to do anything that would
imperil me with -- I don't want to give Mr. O'Boyle a
cause of action against me. He has already
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1 demonstrated his litigious nature and wanting to fuck
2 up my life by dragging me into court for bullshit.
3 I'm not real inclined to do something that I'm not
4 sure -- I don't know whether he'd have a legitimate
5 beef if I did that.
6 MR. GOLDSTEIN: That's fine.
7 THE WITNESS: So on the record, I'm not refusing.
8 I'm inviting you to get the judge on the phone, and
9 the judge can tell me. If he wants me to answer, I'm
10 more than happy to answer the question.
11 MR. GOLDSTEIN: We will take up with the judge
12 and certify the objection.
13 (The question beginning on Page 96, Line 14 was
14 certified.)
15 MR. GOLDSTEIN: Why don't we mark this Exhibit 3.
16 (Defendant's Exhibit No. 3 was marked for
17 identification.)
18 MR. DESOUZA: What are we marking, Josh?
19 MR. GOLDSTEIN: The affidavit of Joel Edward
20 Chandler.
21 THE WITNESS: Do you guys mind if we take a
22 five-minute break?
23 (Recess 2:05 p.m. to 2:13 p.m.)
24 BY MR. GOLDSTEIN:
25 Q. We are looking at what we have marked as Exhibit
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101
A. Yes.
Q. Do you recognize this document?
A. It appears to be an affidavit.
Q. Is it your affidavit of Joel Chandler?
A. I can't authenticate it without comparing it word
for word, but it looks familiar. I can't vouch for its
authenticity.
Q. Why don't you go to Page 11.
A. Yes.
Q. Is that your signature there?
A. That appears to be my signature.
Q. Do you recall executing an affidavit on October
27, 2014?
A. I executed an affidavit. I couldn't swear to the
date, but I did execute an affidavit in 2014.
Q. On Page 11 it reflects a date of October 27,
2014.
19 A. I'm not disputing that this is, in fact, that
20 affidavit. I couldn't vouch for 11 pages of the
21 document without reading every single word of it, but it
22 looks familiar.
23 Q. Why don't you look at Page 2 of what's been
24 marked as Exhibit 3, specifically Paragraph 9.
25 A. Okay.
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JOEL CHANDLER Volume 1 of 2
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Q. You see Paragraph 9 where the affidavit discusses
discussions with Robert Tweel?
A. Yes.
Q. In this affidavit, does it state that the
discussions with Tweel regarding the necessity that CAFI
be a legitimate not-for-profit entity?
MR. DESOUZA: Josh, you're asking whether that is
something that he wrote in the affidavit, or whether
the conversation happened?
MR. GOLDSTEIN: That he wrote in this affidavit
that part of his discussions with Robert Tweel had to
do with the necessity for CAFI to be a legitimate
not-for-profit entity.
MR. DESOUZA: My perspective -- obviously we have
a privilege ongoing issue. But if you are just asking
him if that's what the affidavit says, I'm fine with
those questions.
BY MR. GOLDSTEIN:
Q. Do you agree that's what is reflected in the
affidavit?
A. Just so we are clear, what the affidavit says at
9 is, "During January or February 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
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JOEL CHANDLER Volume 1 of 2
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absolute necessity that CAFI be a legitimate
not-for-profit. 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." That's what it says.
Q. As we sit here today, is there anything that you
know now that you didn't know at the time you executed
the affidavit that would lead you to believe the
statement in your affidavit is not true and accurate?
A. Can you ask that again.
Q. As you sit here today, is there anything to your
knowledge now, that would deem the statement set forth
in Paragraph 9 of this affidavit to not be true and
accurate?
A. Not that I'm aware of.
Q. Now, do you recall receiving a memorandum from
Mr. O'Boyle to Robert Tweel on February 28, 2014
memorializing whatever conversations that were had?
A. Can you restate that.
Q. Do you recall whether or not you ever received a
memorandum after the conversation that Mr. O'Boyle had
with Robert Tweel, setting forth or memorializing things
that were discussed?
A. Yes.
Q. And you were carbon -copied on that e-mail or that
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2 A. I received a memorandum, yes.
3 Q. At any point in time, to your knowledge, did Mr.
4 O'Boyle have a position in CAFI?
5 A. No. I mean, he controlled CAFI. He created it.
6 He directed it through his -- as his instrumentality.
7 But no; he was not a director. He was not a board
8 member, not an owner. But make no mistake, it has been
9 my contention, it is my contention, and will continue to
10 be my contention that Martin O'Boyle absolutely
11 controlled CAFI. It was his instrumentality and solely
12 his instrumentality.
13 Q. What do you mean by "controlled"?
14 A. He financed it. The board members -- I never
15 interacted with Brenda Russel as a board member. I
16 interacted with her -- although she was a board member,
17 and I interacted with her during the time she was a
18 board member, my interactions with her purely -- I
19 submitted my -- early on, submitted my receipts and that
20 sort of thing to Brenda Russel. The only two board
21 members that I interacted with in that capacity would
22 have been Bill Ring and Denise DiMartini. And there was
23 no question in my mind that they were operating at the
24 behest, direction, and for the benefit of Martin
25 O'Boyle. There was never any question in my mind about
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1 that.
2 Q. So my understanding then, is that he was advising
3 or telling Denise DiMartini and William Ring as to how
4 things were to be done, and they were then directing
5 you?
6 A. Yes.
7 Q. Now, were you, at any point in time, able to use
8 other law firms other than the O'Boyle Law Firm?
9 A. No.
10 Q. Who told you that you weren't allowed to use any
11 law firms?
12 A. Bill Ring, as the president of the foundation.
13 Q. What specifically did he tell you?
14 A. There was a case that I wanted to litigate, the
15 Barnes & Noble College Book Stores operate on behalf,
16 standing in the shoes of the University of South Florida
17 on campus, the book store. They sell more than just
18 books. They sell all sorts of things like T-shirts, and
19 jerseys, and that sort of thing, but they operate a book
20 store. And I went there with one of my brothers. We
21 just happened to meet for lunch in Tampa, and it was
22 convenient. We were close by, and just for the fun of
23 it, we decided to go over there and make a public
24 records request. He had met -- he was a student there.
25 He is now a graduate assistant there. But he had met a
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1 woman in one of his classes that worked for a competitor
2 of Barnes & Noble off campus, and they had tried to get
3 -- this competitor had tried to get the adoption list
4 from Barnes & Noble. These adoption lists are used --
5 they basically send out a form around to all of the
6 faculty asking them what books they are going to need
7 for the upcoming semester, and the college book store
8 orders them. These adoption forms are public record,
9 and they are critical for anybody who wants to sell
10 textbooks to students at a particular university, in
11 this case, University of South Florida. If you don't
12 have the textbooks on hand, you can't sell them.
13 And Barnes & Noble had told this young woman,
14 allegedly, that she had to pay a confiscatory fee for
15 getting them, the request had to be made in person.
16 They made her jump through a bunch of hoops to get these
17 records. And this exact same issue had already been
18 litigated in the Third DCA in 188 or 189. Barnes &
19 Noble was the defendant in that case and they lost
20 because the court held that they were standing in the
21 shoes of the state, and the records that were being
22 requested in that case, adoption forms, were public
23 record.
24 So knowing that Barnes & Noble had already been
25 taken to the wood shed on this issue, I went over there
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 107
to find out if they were still doing the same thing. It
turned out they were. After I went over there and made
that request, and it was videotaped, my brother was with
me, and he has done some open government litigation and
advocacy as well, he made a similar request at the same
time. So within seconds of each other, I made a request
and he was standing next to me and made a similar
request.
Subsequent to that, he had a conversation with
Ana Clara Anderson who, at the time, was an associate at
Thomas & LaCicero who had represented me and my brother
separately in public records lawsuits. In this social
discussion, the issue of what happened at Barnes & Noble
came up, and Ana Clara expressed an interest in the
case. And given Thomas & LaCicero's reputation and the
stature that they have in open government litigation,
and their interest in the issue, and the fact that it
was in Tampa Bay, I thought that if there was ever a
case that I was going to give to another law firm, that
would be it. Black and white facts; just imagine going
to court and the citation is Barnes & Noble in another
case with identical facts.
And so I -- and I also thought that it would help
to burnish the reputation of the foundation to be
represented by a firm like Thomas & LaCicero on a case
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1 that is so clear cut. And I, frankly, thought it was be
2 cool to have a -- right out of the gate, to get an
3 appellate decision with CAFI's name on it. So I sent an
4 e-mail to Bill, and said that I wanted to do that, and
5 he came back and told me no; I couldn't do it, that all
6 of the cases had to go to the O'Boyle Law Firm.
7 Q. Were there any threats if you didn't send all of
8 your cases to the O'Boyle Law Firm?
9 A. No. But he was the president of the foundation.
10 I serve to the pleasure of the board, and he told me I
11 couldn't do it.
12
Q.
Were you ever told that if you didn't continue to
13
send cases
to the O'Boyle Law Firm, that the funds to
14
run the
foundation would no longer be -- would be cut
15
off?
16
A.
Yes.
17
Q.
Who told you that?
18
A.
Bill Ring and Denise DiMartini.
19
Q.
Do you recall when that was?
20
A.
It would have been in May sometime, as I recall.
21
I think
it was in May.
22
Q.
Why don't you look at what was previously marked
23
as Exhibit
1, which is the timeline, and look at Page 5
24
for the
date, says February 6th.
25
A.
These pages aren't numbered.
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1 MR. DESOUZA: I'm sorry, Josh. You said we're on
2 the timeline now?
3 MR. GOLDSTEIN: Yes. We're on the timeline,
4 which is 1. I'm referring to Page 5 of the timeline,
5 the time period between February 4th and February 6th,
6 2014.
7 MR. DESOUZA: Thanks.
8 THE WITNESS: Okay.
9 BY MR. GOLDSTEIN:
10 Q. And it says, "MEO e-mails Chandler, MEO tells
11 Chandler to toll referrals of new cases to the O'Boyle
12 Law Firm, said this was in response to MEO being told no
13 by Witmer on some minor issue. MEO responded by
14 threatening to stop the flow of money."
15 So Mr. O'Boyle also threatened to not continue
16 funds if you --
17 A. You're talking about two completely different
18 things. One has nothing to do with the other.
19 Q. This e-mail February 5th, what did that have to
20 do with?
21 A. Marty got pissed off. I don't remember. Marty
22 got pissed off about something. Ryan, to his credit,
23 told Marty no, and Marty is a person that doesn't like
24 being told no. And I remember Marty telling me, "Don't
25 give any more cases to the O'Boyle Law Firm." He didn't
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1 tell me to give them to anybody else. He just told me
2 to quit giving them to the O'Boyle Law Firm, which
3 caused some consternation on my part because I'm
4 thinking if Marty's objective ultimately is that he is
5 going to fund my advocacy with the hope that my advocacy
6 generates lawsuits, that ultimately his son is going to
7 litigate some of, or most of, or a large portion of.
8 Now all of a sudden he's mad because Ryan told him no
9 about something, it was just -- this was my introduction
10 to a side of Marty that I hadn't seen much of, and
11 thankfully, I didn't get much of it until much later in
12 my relationship with him, what I have heard people refer
13 to as Good Marty and Bad Marty. This was Bad Marty.
14 This was Marty being pissed off and throwing a fit. It
15 blew over. But that had nothing to do with the Barnes &
16 Noble case.
17 1 Q. You said the Barnes & Noble case was sometime in
18 March?
19 A. I don't know if I said that or not. I don't
20 think I said that, but it may have been.
21 Q. Why don't you flip forward to the timeline, time
22 period of March 26, 2014, March 28, 2014.
23 A. Okay. March 26, you're saying?
24 Q. Correct.
25 A. Okay. All right.
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JOEL CHANDLER Volume 1 of 2
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Q. So is this the -- what it says here is, "Chandler
asked the board for authorization to pursue a case, CAFI
v. Barnes & Noble to Thomas & LaCicero." This is the
case that you are referring to?
A. Yes.
Q. So that was in March of 2014?
A. Yes.
Q. What was your understanding of your role as the
chief executive of CAFI?
A. My role was to be a civil rights activist and to
advocate for government transparency, to -- essentially
what I have been doing before, which is to come along
side citizens, and citizens groups, and civil rights
groups, and help them better understand their ability to
get access to records, kind of help them navigate the
process of getting records. I also made myself
available to public agencies. In fact, during the time
I was with Citizens Awareness, I had meetings with some
public agencies, cities, at their invitation, to help
them develop public records policies and training
issues. That was my job. And to that end, I bought, I
don't know, hundreds of "Government in the Sunshine"
manuals from the Florida First Amendment Foundation. We
bought boxes and boxes. They were 18 bucks a pop. I
bought so many they had to go to a second publishing. I
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1 gave those away. Anybody wanted one, I gave them away
2 for free. So that was my job.
3 And then in addition to that, my responsibility
4 was to direct Dylan Boucher, who was our intern, then to
5 direct Cathy Zollo. And essentially what they did, I
6 had developed a series of projects that were related to
7 public records, and I wanted them to basically do
8 investigative journalistic type work. We were not
9 intending to be a media organization. The idea was
10 whatever we found, we would either write about on the
11 blog, which we had, or more likely, we would give that
12 information to other -- to news organizations so they
13 could do an expose, which I have done a lot of. And so
14 we -- that was a lot of what I spent my time on.
15 For example, a lot of things that later came to
16 light about the abuses that were going on in the
17 Department of Corrections, school resource officers,
18 that sort of thing.
19 Q. Was any part of your responsibility determining
20 the public records requests to make and the entities to
21 make the public requests to?
22 A. Yes. I was very -- we only had three employees;
23
me, Cathy,
and Dylan. And
Cathy and Dylan were not
24
allowed to
make any public
records requests without my
25
explicit authorization. I
wanted to see them. I wanted
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1 to see the requests before they went out. No one was
2 making requests -- nobody that worked for CAFI was
3 making any requests apart from my involvement. And I
4 was adamant about that.
5 Q. What about directing lawsuits or determining
6 lawsuits to file?
7 A. Nobody was supposed to be filing them. I was the
8 only person that was supposed to be filing lawsuits, or
9 authorizing them. No lawsuits were supposed to be going
10 out. We had a -- Jonathan and I had a disagreement that
11 Denise was involved with where they wanted to start
12 filing cases that weren't verified complaints, because
13 they felt it was sort of a bottleneck for me to have to
14 review and sign off on all these complaints. And I
15 absolutely refused to do that. No way, no how, we are
16 not doing that. If they don't have my signature, they
17 aren't getting filed. And that wasn't just because I'm
18 a control freak. It was a quality assurance issue. I
19 wanted to be sure that the facts were right. We didn't
20 -- I don't think we filed any cases that were the result
21 of either Dylan or Cathy making a public records
22 request. If I'm not mistaken, and I'm pretty confident
23 all of the cases that I was intending to file were based
24 on facts that I was involved with. And since I was
25 there, or since I was the one that sent the request,
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1 whether I made it in person or by e-mail, it only made
2 sense to me that they be verified complaints.
3 And so it was kind of a hassle. I would have to
4 print them out -- if I wasn't there, I would have to
5 print them out, and I'd have to go find a notary public,
6 and have to overnight them down to the law firm. But to
7 me, it seemed like it was a good practice to be sure
8 that the person who was actually alleging the facts is
9 the person who is signing off on the lawsuit.
10 And I didn't want any other lawsuits being filed.
11 As I mentioned earlier, I was really concerned going
12 into this that my standards for what should and
13 shouldn't be litigated might be very different than
14 other people's. What I have found is over the years, my
15 standards for litigating a case continue to rise. There
16 are cases that I would have litigated two years ago that
17 I wouldn't litigate today. They were great cases,
18 wonderful facts, but I have just become much more
19 discerning about what I wanted to litigate, and I wanted
20 to be the only person that made those decisions. And it
21 was my understanding that was going to be the case.
22 Q. With regards to controlling the litigation,
23 determining settlement amounts, was that also your
24 responsibility?
25 I A. Yes.
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1 Q. Now, you said that was my understanding of what
2 was to be the case. What, in fact, happened?
3 A. In fact, they were -- "they," being the
4 attorneys, were not consulting me about settlements.
5 And they were acting unilaterally, which I was
6 epiplectic about. I was mad as hell about that. I
7 think I'm a great client. I think most of the attorneys
8 that I have worked with, most of them would say the same
9 thing. The reason I had such a long and flourishing
10 relationship with Thomas & LaCicero is because as much
11 of as asshole as I may be, and as persnickety as I may
12 be, and as much of a flake as I may be, I'm a really
13 good client. And I just have no tolerance for attorneys
14 making unilateral decisions. It's a Bar violation.
15 It's unethical. It's not truthful. It's a had
16 practice. And I found out that the attorneys were
17 demanding settlement conditions I was not aware of and I
18 would have never agreed to.
19 I have settled cases, my own cases. I have
20 settled cases where I didn't get a penny, not one red
21 cent, not even my costs. I have settled a lot of cases
22 like that. But I don't settle cases -- even when
23 someone is waving a check at me, I don't settle the case
24 unless we resolve the fundamental issue, which is access
25 to records and taking some remedial action.
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I am far more interested in fixing the problem
and insuring public access than I am in the money part
of it. It was clear to me that was not the case with
the O'Boyle Law Firm.
In addition to that, I found out Marty was
directing Commerce Group employees to make public
records requests in the name of and on behalf of the
Citizens Awareness Foundation.
Q. So unbeknownst to you, CAFI was making public
records requests to entities that you didn't authorize?
A. That's exactly right. People who were not
employees of CAFI, they weren't volunteers of CAFI, they
had no relationship with CAFI whatsoever other than
Marty O'Boyle directed them to make public records
requests, and to do it in the name of CAFI. And they
weren't particularly sophisticated about it either.
They were making it from a Commerce Group fax machine
that had their name and phone number on it.
And in addition to -- I had a huge philosophical
problem with that, and that was exactly the kind of
stuff I was concerned about early on, about blurring the
lines of independence. And I get it. Marty is a rich
guy. He's got a son who's trying to build a law
practice. Marty finances Joel's activism, and as a
result of that, maybe the O'Boyle law firm gets a bunch
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1 of lawsuits. I don't have a problem with that. I don't
2 have a problem with it philosophically, legally. I
3 don't think there is anything wrong with that as long as
4 it's not, we are not paying Joel to go out and get
5 lawsuits, and as long as we are all transparent. We're
6 demanding transparency from other people. We've got to
7 be transparent. We've got to be an open book. What we
8 are really doing, "we," being the foundation, because
9 Marty is using it as his toy, is he has somebody else
10 making public records requests using a wire, using a
11 telephone, or an e-mail, making public records requests
12 of Gulf Stream, purportedly on behalf of CAFI. It
13 ain't.
14 I mean it's one or the other. Either Marty
15 really does control it and has the authority to do that,
16 which makes it okay, or Marty doesn't control CAFI, and
17 is just this semi senile benefactor who is giving money
18 away to this civil rights organization. It's one or the
19 other. I mean, which is it? That's my problem with
20 this whole thing, right, is that if Marty has the power,
21 if he really does have control over CAFI so that he can
22 direct people to do things on behalf of CAFI, then it's
23 not independent. It is marty's instrumentality, which
24 is what I have been contending all along. Or somebody
25 was committing wire fraud, sending out public records
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1
requests to
a public agency in
the name of CAFI when
2
they don't
work for CAFI, have
no affiliation with CAFI,
3
and aren't
authorized to do it.
It is sort of one or
4
the other.
If I seem animated
now, just imagine how
5
fucking livid
I was when I found out this shit was going
6
on. I went
fucking ape shit.
I had a meeting. I
7 demanded a meeting with Bill and Denise, and I was just
8 as brutally blunt as I can be that either this shit
9 stops or I was going to quit right fucking then and
10 there.
11 And to kind of put this in context, I drove my
12 own car instead of a rental -- I was renting a car this
13 whole time. They never bought a new car, which was
14 fine. We figured out it was cheaper for me to rent a
15 car. I didn't take a rental car down that day for that
16 trip. I drove my own car, and I checked out of my hotel
17 room that morning, fully intending that I was going to
18 be driving back home unemployed after this meeting. And
19 Denise had this very condescending tone, "You're not
20 going to quit a $120,000 a year job."
21 My response was fucking watch me. You fucking
22 watch how fast I quit. We aren't doing this. I'm not
23 going to be part of this. Either -- either we are going
24 to do it like straight arrows, or we're not, because I'm
25 not going to be part of it. That's when I got the
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1 whole, "That's the way Big Daddy wants it, and if Big
2 Daddy doesn't get it that way, he's going to turn of the
3 spigot of money."
4 And my response was to Bill was well, this Big
5 Daddy ain't going to do it that way. And Bill was like,
6 oh, so it's just a pissing match between you and Marty,
7 and I was like yeah, watch who wins. I'm not going to
8 do this. I've got no problem going toe -to -toe with the
9 biggest swinging dick in Florida. I'll sue the
10 governor, I'll sue whoever. I don't care. I am not
11 even slightly intimidated by law enforcement. I will
12 stand up and advocate for the little old Black lady, and
13 I'm more than happy to throw down in court with any
14 mother fucker who wants to fuck with somebody like that.
15 But we are going to do it by the book. we are going to
16 be straight arrows about it. I'm not going to do -- as
17 I explained to them in a memo, written memo, where I
18 warned them that I was going to quit if this shit didn't
19 stop, if you're going to go after the man, if you are
20 going to fight the establishment, they are going to look
21 for every opportunity they can find to fuck with you.
22 And I have experienced that firsthand. I don't trust
23 the establishment any farther than I can throw it. It's
24
utterly, completely, totally corrupt.
And
knowing
that
25
that's the way the system works, why
make
it easy
for
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1 them? So my blood pressure was probably slightly
2 elevated during this whole time.
3 Q. Understood. So just so I'm clear, who was the --
4 where were these public records requests being sent from
KOL11a m
6
A. Very
sweet lady
named Jill Muller, who was the
7
receptionist
at Commerce
Group, who I greeted every time
8
I went in and
out. She
always had this big stack -- her
9
desk was --
it was just
kind of overwhelming, the stacks
10
of stuff she
had on her
desk. I didn't really pay any
11
attention to
it because
she didn't work for me, and she
12
was -- she wasn't
even
a coworker. She was just
13 1 somebody who worked at an office that I sometimes went
i[liT.7
15 And then to and behold, I don't remember off the
16 top of my head, maybe it will come to me, how it came to
17 my attention, but it turns out these were all public
18 records requests that were being sent out. These stacks
19 of things were public records requests that she was
20 being instructed to send out in the name of CAFI.
21 Q. Where are these public records requests being
22 sent?
23 A. Gulf Stream.
24 Q. All of them to Gulf Stream?
25 A. I can't say that all of them went to Gulf Stream.
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Q. Was it fair to say the vast majority of the them
A. That's my perception, yes. Mathematically, I
can't say that definitively. I don't take any of this
personally, the public records litigation stuff, I
don't. I take the civil rights stuff very personally.
When I see the state trying to destroy some young black
kid, or when I see the state talk about -- making jokes
about using a peaceful civil rights rally as an
opportunity for a K9 exercise, or when I find out the
sheriff of Polk County is sending undercover minority
deputies in to infiltrate Black churches -- and I don't
mean just attend, I mean infiltrate, like COINTELPRO, J.
Edgar Hoover bullshit. I take that very personally.
But I don't take public records stuff personally.
I don't have an ax to grid with Gulf Stream, they
fucked up, I sued them. I'm not mad about it. I hope
they're not mad about it. I hope we fixed the problem.
We wrapped it up for $1,200, we move on, no problem
there. But I was not interested in using my talents as
Marty's instrumentality to exercise some vendetta he's
got against Gulf Stream. There's just way more
interesting thing to me.
Gulf Stream is this little tiny town filled with
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1 millionaires who are in a pissing match, and they've got
2 some blood feud going on. I don't really give a shit
3 whether Marty doesn't like Scott Morgan, or Scott Morgan
4 doesn't like Marty. I don't care. They are a bunch of
5 rich people who are entitled, and I don't give a crap.
6 I wanted to spend my time working with poor people,
7 helping them be able to defend themselves against the
8 prosecution of the State, or discovering that a school
9 resource officer supplied to the Hillsborough County
10 School District by the Tampa Police Department, while he
11 was a school resource officer, was under investigation
12 for aggravated sexual battery on a minor. That's the
13 stuff I'm interested in.
14 And to find out what was happening was that Marty
15 was having somebody who didn't report to me, didn't work
16 for the foundation, using the foundation and its name
17 and its resources and my association with it, just as
18 this instrumentality to screw with Gulf Stream, I just
19 didn't want any part of that. What made it worse was
20 that we weren't being honest about it.
21 Q. Why weren't you being honest about it?
22 A. When I say "we," I don't mean me. I mean the
23 foundation, because you have somebody who doesn't work
24 for the foundation making public records requests in the
25 name of the foundation, and they are transmitting that
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1 by fax or e-mail. That's wire fraud. I'm not a lawyer,
2 and I'm not really in a position to draw any legal
3 conclusions, but I'm pretty sure that's fucked up.
4 Q. Was the O'Boyle Law Firm filing lawsuits without
5 CAFI or your authorization?
6 A. My recollection is that one lawsuit got filed
7 against Gulf Stream that I didn't know about until after
8 the fact. And again, I went ape shit.
9 Q. So O'Boyle Law Firm had whatever records requests
10 they sent to Gulf Stream --
11 1 A. A request that I didn't make, but alledgedly was
12 1 made on behalf of the foundation, and then the
13 foundation, without my authorization or knowledge, files
14 a lawsuit against Gulf Stream. And by the way -- and I
15 don't remember even the causes of action in this
16 particular instance, but I do remember thinking this is
17 a shitty lawsuit to begin with. It doesn't meet my
18 standards, which I readily acknowledge are impeccable
19 and extraordinarily high, which is why I win, which is
20 why I think the litigation I do is, in fact, good
21 advocacy.
22 And in spite of the bullshit that the Florida
23 League of Cities tries to say I file all these lawsuits
24 and I'm trying to get rich, I haven't gotten rich,
25 number one, and I only file on a tiny, tiny percentage
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1 1 of the violations I witness, because I would much rather
2 use other means to get compliance than litigation.
3 Litigation is the last resort. They make it sound like
4 it's a hair trigger and it's gotcha. It's not. I ask
5 for records, they don't give it to me, I beg them, I
6 plead, I try to work with them. They give me two middle
7 fingers, then I file suit.
8 That's not what was happening here. This was
9 let's -- I think fraudulently, dishonestly, with no
10 integrity, let's use this foundation to harass Gulf
11 Stream. And I don't have any problem -- I just want to
12 be really clear. Making the request is not the abuse.
13 It's making it saying you're the foundation when you're
14 not. That's the problem.
15 Had I been told at the beginning, part of the
16 deal -- we are going to pay you $500,000 a year. We are
17 going to give you a million dollars a year as an expense
18 account, and hell, we will buy you a Rolls Royce. But
19 part of the deal is we are going to pound the shit of
20 out Gulf Stream with thousands of public records
21 requests, I would never have agreed to it.
22 I think the fundamental misunderstanding of both
23 sides here, I think what Marty still doesn't get, and
24 what I'm confident the League of Cities doesn't get is
25 that I don't give a fuck about the money. I don't. I
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1 care about civil rights. I care about access to
2 records. I care about people doing the right thing,
3 and let's all play by the rules. And that's why Marty's
4 done all the stupid shit that he's done trying to fuck
5 with my life. And this is why the Florida League of
6 Cities is backing this ridiculous, absurd legislation,
7 which, by the way, will do nothing to stop Marty
8 O'Boyle. Let me know if I wasn't clear about any of
9 that.
10 Q. Let's go back to -- you said that you became
11 aware that the O'Boyle Law Firm was settling lawsuits
12 without your knowledge?
13 A. Yes. We weren't getting closing statements,
14 which was a problem. There was no -- at least none that
15 I executed. There were no fee agreements. There were
16 no engagement letters, which is an issue I raised
17
repeatedly. I thought
it was deeply
problematic for a
18
lot of reasons. One is
I think it's
important to --
19
again, we are going to
ask people to
be transparent. We
20
need to be willing to be transparent.
We need to be
21
sure we're documenting
what we do. I
think that you --
22
if I were contacted, as
I sometimes am,
by a publicly
23
operated agency who is
being sued over
a public records
24
lawsuit, one of the first
things I would
tell them to do
25
-- I have given advice
on this issue.
You have to take
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 126
a clinical approach. You need to be dispassionate. Was
there a violation? Even if you want to call it a
technical violation, was there a violation? If the
answer is yes, admit liability -- produce records, admit
liability, and demand a fee hearing. And when you get
to the fee hearing, one of the first things you need to
do is demand to see the engagement letter. If there
isn't one, I would dispute any liability for the fees.
The Florida Bar is very clear about this. If you take a
case on a contingency, there's got to be an engagement
letter.
I was concerned about that happening to us, but
that never got rectified. And there were cases that I
think were being filed without my knowledge, at least
one I know of against Gulf Stream. And I think there
were settlements that were being negotiated that were
not in conformity with my wishes as the executive
director of CAFI.
Q. Were there settlements that were being negotiated
that were in excess of the fees, in fact, incurred?
A. Yes. And that was that was one of the issues.
You know, if I file a lawsuit against -- let's say a
state contractor whose contract explicitly makes them
subject to the Public Records Act. The facts of the
case are clear, it's an egregious violation, there's no
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JOEL CHANDLER Volume 1 of 2
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dispute of the facts. Very often those result in a
settlement. And those settlements always include at
least two things, and one is that they have to produce
the records, or if they produce the records, they have
to affirm they have produced all potentially responsive
records, because unfortunately, as a requester, I don't
always know what records you may or may not have that
are fully responsive. So you gave me two records. I
don't know if there are ten.
Secondly, you have to agree to take some remedial
I don't want to have to come back and sue you
again. I want you to actually fix the problem. So
training, getting a sunshine manual and placing, keeping
it in the lobby were records are normally created,
received, or maintained, those are always two
non-negotiables for me.
The third is if you want me to forego my right to
be vindicated in court, you are asking me for something
you are not entitled to, because during the litigation,
the only thing either one of us is entitled to is due
process. I very often will invite defendants to agree
to a modest monetary settlement for my time, and effort,
and frustration, having to dick around with them making
them do the right thing, which they should have been
doing in the first place, which, by the way, they have
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1 been paid to do. I don't think there is anything wrong
2 with that. I think it's entirely ethical. I think it's
3 entirely appropriate. It's the policy of the State of
4 Florida, according to the Florida Supreme Court, to
5 encourage settlements, otherwise the courts would be
6 clogged.
7 I think it's an entirely different matter when
8 you are an attorney, and as part of the settlement
9 negotiation, you are implying, suggesting, or stating
10 that your legitimate, reasonable billables are $5,000
11 when they are only $2,000. I think that's really
12 problematic for a lot of reasons. One is it's an
13 integrity issue. But beyond that, what happens to the
14 windfall? Because I have been telling legislators, and
15 I've been telling members of the press that CAFI was not
16 making money from public records litigation, we weren't
17 getting any of that money. So if the O'Boyle Law Firm
18 is billing at, say, 250 an hour, and they've got 10
19 hours in a case, and they have another $500 in costs, so
20 now they have $3,000, why would you ask for $4,000 or
21 $5,000? And if the defendant pays that, what happens to
22 that extra $1,000 or $2,000, where does it go? I don't
23 want it. I don't want the foundation getting it. And
24 it sort of mystifies me. You are paying an attorney
25 $60,000 a year to sit there and churn out public records
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lawsuits. That's $25 an hour. You are billing them out
at $250 an hour, and I can give them more cases than
they know what to do with, so it's not like they aren't
working all 8 hours a day. Why get greedy? What's the
point. Why do you need to ask -- you are making a bunch
of money. There is a lot of profit in a case of $2,500
if you are billing out at $250 an hour. There is a lot
of profit in that, especially when you've got more cases
than you can keep up with.
But I found out that, in fact, they were just
making up numbers and demanding monetary portions of
settlements that could not be justified by their
billables.
Q. Did you ever review or receive any billables or
time records for O'Boyle Law Firm?
A. No. I didn't get any closing statements, which
is one of the reasons I wanted to see them. This isn't
my first rodeo. I have run into a similar issue with
another attorney before that. Come to find out, they're
settling for a whole bunch more money than they're
telling me about. Regular folks, that's called
stealing. For attorneys, maybe they have a special word
for it. But for the rest of us, it's stealing.
And this ultimately reared its ugly head just
days before I resigned. I resigned June 30th, and I was
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contacted the week before that
by a
very nice
gentleman
who was the executive director
for
a nonprofit
that has
a state contract, I believe with either Department of
Corrections or Department of Juvenile Justice called
gentleman. And as an attorney, you will appreciate
this. So imagine you have the defendant or corporate
representative of the defendant contacting the corporate
representative of the plaintiff directly, not going
through attorneys, which was very unusual. And he and I
had a lovely conversation. Turns out, just kind of
funny how the world works, turns out this gentleman and
I have a whole bunch of common acquaintances. I move in
those circles and so does he. And we start, well, you
know brother so-and-so, and pastor so-and-so, and sister
so-and-so? Yes, I just had dinner with them.
And he basically says, "We blew it. We got the
public records request," which I made on behalf of CAFI.
Yes, we didn't respond the way we should have. We are
wrong. We want to fix the problem. I went to your
website, your Fog Watch website, which is my personal
blog. I saw that you do training for people, and you
don't charge anything for it, and you want to help
people comply. I talked to brother so-and-so, and he
told me you're a good guy and you're willing to work
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1 with us. Absolutely.
2 He's doing everything that I could possibly want
3 a defendant to do. He's admitted liability. He's
4 trying to fix the problem. He said, we offered to
5 settle for $500 and the O'Boyle Law Firm said no. I
6 told him, you know, in all fairness, they've got that in
7 costs plus they're going to have some attorneys fees.
8 It's going to be more than that. I don't know how much
9 it is. I asked him, what did they offer? And he -- I
10 think the number he told me was $4,000, which struck me
11 as awfully high, given they are using a template. The
12 lawsuit they are using is a template that I wrote. This
13 is plug and play, mail merge, and it takes 15, 20
14 minutes to do a complaint.
15 So I call Nick Taylor, who is one of the
16 attorneys at the O'Boyle Law Firm, and I talk to him
17 about it, and he told me they had -- you will have to go
18 back and look at the documents that I have provided Bob
19 Sweetapple earlier. I want to say that e-mail said
20 something to the effect that they had $2,000 -- less
21 than that even, $1,500 in costs, costs and attorneys
22 fees at $250 an hour. So my question to Nick was why in
23 the hell are you asking this poor Black guy who is
24 running a nonprofit trying to help drug addicts, why are
25 you demanding $4,000? His response was that's the
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1 1 O'Boyle Law Firm policy.
February 24, 2016
132
2 MR. DESOUZA: Joel, before you continue, and not
3 to interrupt the flow of all of the questions and
4 answers here, I'm just going to assert a standing
5 objection. There's obviously issues going on in other
6 litigation, Joel, that you're not aware of. As to
7 privilege and CAFI communications, what you have
8 disclosed already, but basically CAFI has taken the
9 position that while you were -- whatever your position
10 was with CAFI, your communications with its attorney
11 of a legal nature such as what you are describing
12 right now, are privileged. You didn't have the right
13 to waive that privilege after you left. You may
14 dispute that. Sweetapple's lawyers may dispute that.
15 I'm just stating on the record, that is an issue that
16 has been made. CAFI is standing by that assertion of
17 privilege. And what you testify about today, CAFI is
18 not backing off of that privilege assertion at all.
19 And I guess in due course, at some point in time,
20 those issues will be resolved.
21 THE WITNESS: Dually noted. And just so you
22 understand my rationale for the record, since Marty
23 decided to raise this issue himself during my 2004
24 examination on his bullshit fishing expedition, I'm
25 going to assert that that privilege has long since
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February 24, 2016
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2 MR. DESOUZA: Look. I --
3 THE WITNESS: Dan, Dan, I'm not going to argue
4 with you about it. I'm going to answer the question.
5 MR. DESOUZA: I'm just saying, I don't have the
6 ability to tell you not to answer the question.
7 THE WITNESS: Only one of us can talk at a time,
8 and I'm the star of the show here for the time being,
9 so just let me answer the question. I have heard
10 everybody's objections, dually noted. Just zip it for
11 a minute.
12 I talked to Nick Taylor about this. He told me
13 it was the policy of the O'Boyle Law Firm to do
14 settlement negotiations that way. I sent him an e-
15 mail memorializing that conversation, asking him to
16 confirm that was what was said. And he, moments
17 later, sent me an e-mail back, and this e-mail has
18 been provided to everybody at this table. He
19 confirmed that, that was, in fact, the policy. That
20 was on a Friday. I drove down to Deerfield Beach on
21 that following Monday, which was June 30th, and I
22 resigned. That was the straw that broke the camel's
23 back.
24 And just so we are clear, I already warned the
25 board in writing and verbally that I anticipated that
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1 if things did not change, I was going to resign. But
2 once it became clear that it didn't matter what I
3 said, didn't matter any objections I made, my opinion,
4 my view as the executive director of CAFI was
5 irrelevant. Their view was that I was their whore
6 that was supposed to go out and gin up public records
7 lawsuits and ethics, advocacy, doing what is best for
8 open government in Florida, it doesn't really matter.
9 It's just about ginning up legal fees. I'm out of
10 here, so I quit.
11 MR. GOLDSTEIN: First, Dan, I would ask you to
12 refrain from speaking objections. If you want to
13 object under privilege, that's fine, but again, please
14 refrain from speaking objections.
15 1 BY MR. GOLDSTEIN:
16
Q.
So just so I'm clear by your position, it's that
17
it was
your understanding that the purpose of CAFI was
18
to drum
up public records lawsuits to feed them to the
19
O'Boyle
Law Firm to drum up fees?
20
A.
You asked me if that was my understanding?
21
Q.
That was your impression of what was occurring.
22
A.
No. That's what was occurring. That wasn't my
23
impression.
That's what was occurring. That was not
24
what I
was told when I was hired. And for the first few
25 1 weeks or couple of months, it seemed like they were
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135
1 going to pretty much let me do my thing and everything
2 was cool. But once Denise DiMartini started getting
3 really involved, and started sending me e-mails telling
4 me I had a quota, and I had to do 25 lawsuits a week,
5 100 lawsuits a month, where are the lawsuits? Bring in
6 more lawsuits. When I realized she was managing the law
7 firm, she was actually managing the law firm meetings
8 where they were discussing not only CAFI cases, but
9 other client cases, clients that I referred to them, and
10 clearly violating attorney-client privilege, when it
11 became clear that Denise was trying to pressure me into
12 the unlicensed practice of law by directing me, as a
13 non -attorney, to draft lawsuits, I knew the handwriting
14 was on the wall. And I was -- I took weeks. I agonized
15 over this decision to quit, I really did, for a whole
16 lot of reasons. And I talked to -- I think I talked to
17 13 or 14 attorneys about this, about what was going on.
18 And trying to get two attorneys to agree on anything, as
19 we have seen today, is nearly impossible. But trying to
20 get 13 or 14 to all say the same thing is pretty
21 shocking. Well, the response was unanimous. And over
22 and over again, what I got was, why are you still there?
23 You have got to leave. You can't continue to be a part
24 of this.
25 1 So I think I was 99.9 percent of the way there.
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1
Then
when I
had
that
exchange with Nick Taylor,
I just
2
made
up my
mind
that
I was done.
clear, one
3
Q.
Now,
you
said
Denise DiMartini told you
that you
4 1 had a quota?
5
A. Yes.
She
kept demanding
that I produce
100
6
lawsuits a
month,
which, by the
way, just so we
are
7
clear, one
of the
great -- one
of many ironies
of this
8 whole thing is that I was there starting on January
9 27th. So let's just call it February, March, April,
10 May, and I left at the end of June. So I was there for
11 five months. During that time, I probably -- I would
12 estimate that the total number of cases that I generated
13 that could have been ultimately referred to the O'Boyle
14 Law Firm with perfect facts was probably between 400 and
15 500 cases. All of those didn't get referred to the law
16 firm because, towards the end, I just -- I was still
17 doing my thing, but I wasn't sending a bunch of cases to
18 them. They weren't keeping up with what I already sent.
19 They could have had -- had they just left me alone, and
20 had we all just played by the agreement that we
21 originally had, they could have had what they wanted.
22 Jonathan could have had, I think, an enormously
23 successful law firm, and I think I could have had a very
24 fruitful career as a civil rights activist, and I think
25 the citizens of Florida would have benefitted enormously
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 137
from the work that I could have done at CAFI. But
instead, they just ignored what I kept telling them: If
you do this, it's going to blow up in our faces.
Q. To your knowledge, was Jonathan O'Boyle involved
in the O'Boyle Law Firm meetings and discussions and
directing how things were done?
A. Yes, yes, yes, I was in the room when he did it
repeatedly. He was directing -- early on, it was stated
that Jonathan doesn't have his law license yet, so
technically he can't direct anybody. Ryan is the
managing partner. He is the Florida licensed attorney.
Jonathan is licensed elsewhere in this multi -state law
practice. So there was a clear acknowledgment that
that's what was supposed to happen, but that's not what
happened. Jonathan, I mean, I was in the room. I was
standing next to him when he would direct attorneys on
litigation strategies and settlement strategies.
The debate that I had with Nick about all of this
at the very end was that's the way Jonathan wants to do
it. My response was I don't give a fuck how Jonathan
wants to do it. It's not his decision. He's the
fucking attorney. He's not the client. I mean, the law
is a noble profession. And I'm going to sound like a
racist when I say this, but some of my best friends are
attorneys. But the fact is, at the end of the day, the
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1 attorney works for the client, not the other way around.
2 And I understand that some attorneys get all worked up
3 because they went to law school, and they got a degree
4 hanging on the wall, and a mountain of student loans
5 they've got to pay off and will be paying off until they
6 are 60 years old. And they are really indignant when
7 they think some layperson is going to tell them what to
8 do, but that's the way it works, or at least that's the
9 way it's supposed to work. And I think the O'Boyle Law
10 Firm had great difficulty understanding that.
11 MR. GILL: Can we take a break?
12
A.
MR. GOLDSTEIN: Sure.
remember.
13
Q.
(Recess from 3:09 p.m. to
3:21 p.m.)
14
BY MR.
GOLDSTEIN:
15
Q.
You resigned from CAFI in
June of 2014?
16
A.
Yes, June 30th.
Barbara Peterson, John
17
Q.
And you said prior to resigning,
you had
18
discussions
with several lawyers.
I think you said 12
19 1 or 13?
20
A.
13 or 14, I don't
remember.
21
Q.
Did you recall the
lawyers, the names of the
22
lawyers
you spoke to?
23
A.
Some of them, yes,
off the top of my head, Greg
24
Thomas,
Ana Clara Anderson,
Barbara Peterson, John
25
Toracco,
Keith Merit. I
would have to go back and look.
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1 I There were a bunch.
February 24, 2016
139
2 Q. They all had the same response to you, why are
3 you still there?
4 A. Yes. You need to leave. Why are you still
5 there?
6 Q. Now, following your resignation, did you have any
7 -- strike that.
8 Did you assist the O'Boyle Law Firm in any way in
9 terms of how to handle public records request lawsuits?
10 Did you go with them to any seminars? Did you draft any
11 formal complaints for them?
12 A. That's kind of a compound question.
13 Q. Well, we'll take it one at a time. Did you go to
14 any seminars with the O'Boyle Law Firm on public records
15 or First Amendment issues?
16 A. Not that I recall.
17 MR. DESOUZA: Josh, are you asking the questions
18 during his employment or after?
19 MR. GOLDSTEIN: Scratch the after, but I was
20 discussing while he was still employed.
21 MR. DESOUZA: Okay. This is only from January to
22 June, that timeframe?
23 MR. GOLDSTEIN: Correct.
24 THE WITNESS: The only thing that would even
25 approach that was the luncheon that we had in
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OBOYLE -vs- SWEETAPPLE 140
1 Tallahassee. The First Amendment Foundation every
2 year does an awards luncheon at the Governor's Club,
3 which is attended primarily by newspaper publishers
4 and members of the Florida government. At my
5 suggestion, the foundation sponsored a table there.
6 We paid $1,000 for a table. The Speaker of the House
7 was there, and the President of the Florida Senate sat
8 with at our table, somebody who I know. And at my
9 urging, the O'Boyle Law Firm, several of the
10 attorneys, four of the attorneys from the O'Boyle Law
11 Firm flew to Tallahassee to attend that. But it
12 wasn't really a seminar. It was more of a luncheon.
13 The only other thing I can think of that would
14 have been a seminar would have been things I did. I
15 actually did an open government seminar very early on
16 within the first couple of weeks of working for the
17 foundation. I did an open government seminar. There
18 were some -- a few civil rights activists who attended
19 it, and Giovanni Mesa, who is one of the attorneys who
20 I like very much, by the way, a real gentleman,
21 attended that seminar where I kind of did my dog and
22 pony show about Public Records 101.
23 Very early on I did have a one-on-one, a very
24 lengthy one-on-one discussion with Marrett Hanna, who
25 is one of the attorneys with the O'Boyle Law Firm,
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1 about open government issues generally and about what
2 I do. But I do recall us going to somebody else's
3 seminar.
4 BY MR. GOLDSTEIN:
5 Q. The First Amendment Foundation luncheon, who
6 purchased the table?
7 A. The foundation did. I made the arrangements to
8 do that.
9 Q. And do you know how the members of the O'Boyle
10 Law Firm got to the luncheon?
11 A. They told me they flew. My understanding from
12 them was they chartered a private plane and flew up the
13 morning of the luncheon. I remember this because I was
14 actually in Deerfield Beach at the offices, and I had
15 been suggesting that we do this for some time. One, I
16 wanted to give support to the First Amendment
17 Foundation, which I have been a member of for a number
18 of years. They do extraordinarily fine work. One of
19 the other ways we supported them is we bought hundreds
20 of these Sunshine manuals, which is one of the minor
21 sources of revenue for the first amendment foundation.
22 And I thought it would be an really excellent
23 opportunity for the O'Boyle Law Firm to get some
24 exposure as a business, because you have newspaper
25 publishers who are some of the principal litigants in
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142
1 open government issues. And you are sitting with some
2 of the most powerful people in the State of Florida,
3 people who actually make a difference when it comes to
4 public records legislation and developing a rapport with
5 these folks, I think, is a good thing.
6 It took some convincing. They seemed sort of
7 reluctant to go. I think it was two days before the
e luncheon. I was in Deerfield, because my wife and I
9 drove up the day before, spent the night at a hotel in
10 Tallahassee, and then attended the luncheon. There was
11 a lot of debate about whether the O'Boyles were going to
12 fly, fly commercially, or drive, or whatever. And even
13 at one point I suggested we all drive together, because
14 I figured if nothing else, we could have some
15 conversations about open government issues, or even,
16 frankly, they could get some billables because we could
17 talk about some of the cases, particularly the cases
16 that were being litigated.
19 And I remember vividly because they were supposed
20 to come up the night before. We had actually talked
21 about all trying to stay at the same hotel. And I
22 remember sitting in their office talking with their
23 paralegal about making those hotel reservations, and
24 they had settled on staying at a Best Western. My wife
25 and I ended up staying somewhere else because they ended
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1 up not coming until the morning. I remember because
2 they were late getting there, even though they flew.
3 Q. So they had booked a hotel; is that what you're
4 saying?
5 A. My understanding is they booked a hotel.
6 Q. Was there any issue with that hotel subsequently
7 that you are aware of?
8 A. My understanding is that they booked the hotel
9 reservation, and then they did not use the hotel
10 reservation. And in an effort to get out of paying for
11 it, they -- the story I heard was they claimed -- they
12 had disputed the charges on a credit card by saying they
13 had showed up to check in, and the desk clerk wouldn't
14 let them check in and gave their rooms away, which if
15 that story was true, would be utter nonsense, because
16 they didn't show up until the day of.
17 Q. You testified previously that you had sent the
18 O'Boyle Law Firm something between the range of 400 or
19 500 cases during the time that you were at CAFI; is that
20 correct?
21 A. Yes.
22 Q. And were all of those suits, in fact, filed, to
23 your knowledge?
24 A. All of those suits filed? No.
25 Q. How many suits, during your time at CAFI, do you
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1 I believe were filed?
February 24, 2016
144
2 A. Say that again.
3 Q. While you were at CAFI, how many public records
4 suits were filed in the name of CAFI?
5 A. I don't know.
6 Q. Do you know who paid for the filing fees for
7 these lawsuits?
8 A. The law firm did, as far as I know. As far as I
9 know, CAFI didn't pay for them.
10 Q. So as far as you know, there were no checks
11 written for the filing fees?
12 A. Not that I know of; that was not really my
13 province at the foundation. I didn't have anything to
14 do with finances.
15 Q. Now, you said you had to review all of the
16 complaints before they were filed. That is what your
17 requirement was, and you wanted them verified with your
18 signature.
19 A. Say that again.
20 Q. You testified earlier, if I recall correctly,
21 that it was your position that you wanted to review and
22 verify all of the complaints filed on behalf of the
23 foundation prior to them being filed.
24 A. Yes.
25 Q. How many suits are you aware of that were filed
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 145
that didn't have your signature?
A. I don't know.
Q. Are you aware of any suits that were filed --
A. Yes, I believe some were.
Q. Were some of those suits the ones that were filed
against the Town of Gulf Stream?
A. I believe at least one of them against the Town
of Gulf Stream.
Q. During your time at -- well, during the time
where you started having concerns while you were at
CAFI, who did you express those concerns to?
A. Marty, Denise DiMartini, Bill Ring, Jonathan
O'Boyle, Ryan Witmer, Giovanni Mesa, Nick Taylor, and
Marrett Hanna.
Q. Did any of them share in your concerns?
A. Yes, I believe they did. At least they said they
did.
Q. Which of the individuals that you spoke to said
they had shared in your concerns?
A. Ryan Witmer, Giovanni Mesa, and Marrett Hanna.
Q. Do you recall, was there any -- what specifically
did Ryan Whitmer express to you?
A. "We're going to fuck this up." That's a direct
quote.
Q. What about Giovanni Mesa or Marrett Hanna?
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1
A. I think that Giovanni, I
think expressed concerns
2
about just the --
how things were
being done, a lot of
3
the same ethical
concerns that I
had about the
4 settlements, about trying to maintain an appearance of
5 propriety with respect to the nature of the
6 relationships between Marty and the foundation, and the
7 foundation and the law firm, about the fact that Denise
8 DiMartini, who is not an attorney, was directing the
9 attorneys, that Jonathan, who is not an attorney, was
10 directing attorneys.
11
Marrett had
many
of the same concerns.
In fact,
12
when I
mentioned to
you
earlier, one of the
sticking
13
points
Marty and I
had
was he did not want me doing any
14 pro se work once I went to work for them. And I
15 actually had several pending cases that had been filed
16 prior to my going to work for the foundation. And even
17 though I think technically, because they had been filed
18 before, that wouldn't have been a violation of my
19 agreement with Marty, I wanted to wash my hands of it
20 and wanted to concentrate solely on my responsibilities
21 to CAFI. So I retained the O'Boyle Law Firm to
22 represent me in those cases. And I think there were
23 three, maybe four.
24 And Marrett, who was assigned to at least one of
25 those cases -- and I was very pleased with her work.
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1 She and I really -- and I would say the same thing about
2 Giovanni, and to a very large extent, the same thing
3 about Ryan. I think we all kind of clicked on the same
4 wavelength, Marrett and I probably more so than anybody
5 else. She seemed deeply concerned about ethics. I
6 think she was very concerned about the potential
7 ramifications to her career if things weren't done in a
8 way that was above board. I think she had a real
9 concern about going after public agencies, and the cost
10 to tax payers, and wanting to be sure that if we sued
11 public operative agencies, municipalities, for example,
12 that we really had tried to resolve things without
13 litigation. And I think to a very great extent, I put
14 her mind at ease that was not how I did things, that I
15 1 wanted to -- she and I shared the same concerns.
16 I actually, during one of her discussions with
17 opposing counsel, one of my personal cases, I actually
18 sat in on that. I didn't talk. She had me on speaker
19 phone and I listened, mainly because I wanted to see how
20 she did it. Not only for my own cases, but I thought
21 that might be an indicator of how she was for cases for
22 CAFI. And I was very impressed. I thought she was very
23 knowledgeable. She was dispassionate in her discussion
24 with opposing counsel. She didn't make it personal.
25 In spite of my being very pleased with her
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performance in representing me personally, she was,
without my knowledge, consent, no discussion with me,
she was removed by Jonathan from managing my cases, and
Ryan stepped into her place. I was very pleased with
Ryan's work, but I had a huge problem with them just
unilaterally deciding that this attorney I was very
pleased with was -- they didn't discuss it with me.
I cannot imagine any -- I cannot imagine Thomas &
LaCicero pulling a stunt like that. Why would somebody
do that? And I think there were just deep philosophical
The impression that I got was she was
being marginalized. She was excluded from meetings, and
that it was unfortunate. It's kind of ironic, because
of all of the attorneys that I worked with there, she
was the one that without a doubt, I had the greatest
confidence in.
One of the things that I have come to appreciate
in an attorney is someone who is willing to tell me no,
and somebody who is willing to challenge my assumptions
and my assertions. And she was very willing to do that.
She was willing to be the devil's advocate when we would
discuss cases. She and I didn't always agree, but I
think it's important when you have an attorney that they
are dispassionate and they try to take a clinical
approach to things, and sometimes that requires them
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1 challenging the assertions of the client. The client
2 still gets to make the final decisions as long as they
3 are ethical and legal. I don't think that that was a
4 good fit for what was going on at the O'Boyle Law Firm.
5 She was not somebody who just would do what she
6 was told to do without questioning things, and I
7 applauded her for that, and I think it cost her her job.
8 Q. So it resulted in being terminated, to your
9 knowledge?
10 A. I don't know whether she was terminated, or she
11 quit. She certainly did not leave on good terms. That
12 is the impression I have gotten. She and I have talked
13 a few times since she left. We don't keep in close
14 contact. I think she was the exceptional attorney of
15 the group. I think that Giovanni had real promise. I
16 don't know what he's doing now. I don't know if he's
17 still there. I have nothing but warm regard for
18 Giovanni, both professionally and personally. I feel
19 very much the same way about Ryan. I think Ryan was
20 sort of in a no-win position.
21 Here you have somebody basically handing you a
22 partnership in a law firm on a silver platter, and it
23 looks like great, and you have a great opportunity. But
24 like I said, his exact words to me was, "We're going to
25 fuck this up. We are the ones that are going to mess it
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1 up. It's ours to lose, and we are going to lose it."
2 And it was because of all of this silliness. If
3 you -- I recognize that many of the Bar rules are
4 somewhat archaic. But for the most part, I think they
5 are there for a good reason. There is a reason why you
6 have an engagement letter. There is a reason whey you
7 have a retainer. There is a reason why there is
8 attorney-client privilege. There is a reason why the
9 client ultimately, as long as it's legal and ethical,
10 makes the decisions. These are tried and true
11 practices, and that's the way it's supposed to be. I
12 think they had great difficulty with that.
13 Q. The three lawsuits that you were handling
14 initially pro se, were they brought to conclusion while
15 you were still at CAFI?
16 A. My recollection is that they were. If I'm not
17 mistaken, there was some debate about the settlement
18 amounts, which again, if I'm pro se, it's one thing for
19 me to make a settlement proposal for something I'm not
20 entitled to. They're asking for something they're not
21 entitled to. They want the case dismissed. They are
22 not entitled to that. I'm not entitled to money.
23 That's the whole nature of the settlement negotiation.
24 We are going to ask for things we are not entitled to
25 and try to come to some accommodation. It's legal,
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JOEL CHANDLER Volume 1 of 2
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ethical. That's the way it's supposed to work.
It's another thing entirely when you begin to put
it in the context of these are fees that we have earned.
If you haven't earned them, but you're say that you
have, that's problematic. And it's particularly
problematic whether you're doing it without discussing
it with your client.
Q. So were those cases settled with your knowledge
and discussing with you, or were they just settled
without your knowledge?
A. I mean, ultimately, I executed the settlement
agreements, if I'm not mistaken. But the machinations
of that, I don't think were entirely transparent to me.
And I have been spoiled. Thomas & LaCicero, for
example, they have been doing this a long time, and they
are very, very good at what they do. And they are, you
know, almost agonizingly scrupulous. But they don't --
I mean, my instructions to them -- if there was -- Greg
Thomas is somebody I would literally trust with a
million dollars cash. I would trust him with my life,
and I mean that literally. I would trust him with my
life. But even with that relationship, and I have never
had a negative experience with Thomas & LaCicero in the
however many years they have represented me, but they
are not allowed to send communications to opposing
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 152
counsel without my seeing it. They don't file anything
without me looking at it first. It's not that I don't
trust them. It's I want to know how the sausage is
made. And that, by the way, is how I figured out how to
do pro se litigation. I'm sure I was a pain in the ass,
because I wanted to see every little thing they did, and
they were very gracious about letting me see it.
So I have very little patience with attorneys who
want to pat me on the head and do things without me
knowing about it. That's a sure fire way for me to fire
an attorney.
Q. Are you aware as to whether or not any of the
settlements that were negotiated by the O'Boyle Law Firm
on behalf of CAFI, if the settlement amounts were ever
paid by an entity's insurance carrier?
A. I don't know. Again, I didn't get closing
statements. I was not given the detail -- level of
detail that I was accustomed to or wanted, which was a
beef that I had with them ongoing.
Q. So would you agree that the settlements would
become further problematic if they were, in fact, with
insurance carriers, and the amounts that were due that
the settlement was for, was for more than what was, in
fact, attorneys fees that were accrued?
MR. DESOUZA: Objection, form. I'm not sure what
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JOEL CHANDLER Volume 1 of 2
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February 24, 2016
153
A. This is why seeing communications with opposing
counsel is so important to me. I think it would depend
on how you couch it. At a risk of sounding like Bill
Clinton, it depends on what definition of "is" is. If I
say to you that our attorneys fees are $5,000 when
really our attorneys fees and costs are only $2,500,
then I think that is potentially fraudulent. If on the
other hand you say that my client has authorized me to
offer to settle for the following conditions, one of
which is a monetary payment of $5,000, and we
acknowledge that we are not entitled to that any more
than you are entitled to a notice of voluntary
dismissal, I think that's very different.
I think that creates other ancillary issues when
you're talking about having an attorney versus being pro
se, because then there's the issue of is it contingency?
And if it's contingency, is this potentially fee
splitting? There are issues there. But as far as
defrauding somebody, I think it really comes down to the
language that is used, which is why I want to see
communications. If somebody is representing me, I want
to see what it is they're saying on my behalf.
It's rare. It's really, really rare that I have
an attorney that goes to a hearing and I'm not there. I
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mean, I just had a case management conference, and it
attorney that is representing me in that case has been
practicing law for a long time. He was in the Clinton
Whitehouse. This is somebody that actually knows what
they're doing, and I still went to a case management
conference.
Part of it is I want to learn, and part of it is
I want to see what somebody is doing on my behalf. So
in an answer to your question, I think that when you --
if you were to say -- I would be very uncomfortable
saying to an insurance carrier, "I'm entitled to X."
When I know I'm not. I would be very uncomfortable
saying that to anybody, which is why when I talk to
opposing counsel, I'm very blunt about the fact that I'm
asking for something that I'm not entitled to, just like
your client is asking for something they're not entitled
to. If we're going to talk about entitlements, then
we're going to have to litigate.
Q. Now, after your resignation from CAFI, have you
had any discussions or communications with Martin
O'Boyle?
A. Oh, Lord, yes.
Q. What have those communications with Martin
O'Boyle entailed?
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A. When I went down to resign on June 30th, I --
before I went down, I turned in my rental car here in
Lakeland. I drove down in my car, my old beat up Volvo.
And I had all of my stuff that belonged to them, a hard
drive, scanner, whatever stuff I had that belonged to
the foundation, and I had it all boxed up, and I took it
in on a little hand truck that I have. And I went in to
see Bill Ring, and handed him my resignation letter.
And inside that envelope was the credit card, foundation
credit card. And he was kind of like, "What's this?"
I said, that's my letter of resignation.
When is this effective?
It was effective about five minutes ago. I'm
done. And it was a very brief -- we didn't really talk.
Here's your stuff, and I'm leaving. It was not ugly,
but there was not a lot of back and forth. On my way
out, I stepped across the hallway to Brenda Russel,
Marty's long-time secretary, and said, "Would you please
have Marty give me a call?" He wasn't there. And the
reason I wanted him to call was to simply say to him
thank you for the opportunity, and I appreciate your
willingness to take a chance on me. And I'm sorry
things didn't work out, but you go your way, I will go
mine, no hard feelings.
On my way back to Lakeland from his office, I got
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a phone call with Marty -- it was a conference call with
Martin O'Boyle, Denise DiMartini and Bill Ring. It
started out fairly pleasant, kind of like, oh, gee, what
happened? Why did you quit? And I kind of -- I didn't
really want to go through the whole thing again. I
already laid all this out. I kind of went through it
very briefly and was hoping we could go our separate
ways. And it seemed like maybe that was going to happen
until Marty started with the whole, why did you send
that e-mail to Nick Taylor, the one about the -- what I
thought were confiscatory fees that were being demanded
from Miami's River of Life. Then he told me that he
wanted me to retract or rescind that e-mail. I don't
know how you would do that. The e-mail has been sent.
I don't know how you rescind something like that. And
it was not just my e-mail. It was an exchange. And I
told him that wasn't going to happen. He told me if I
didn't, he was going to bring great unpleasantness into
my life. I told him, "Don't threaten me," and he did it
again, and I told him, "Don't threaten me," and he did
it again. Probably at least three or four times he said
he was going to bring great unpleasantness in my life,
and I made it very clear that I perceived that as a
threat.
Before I resigned, I had prepared a press
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1 release, and it was a pretty innocuous press release,
2 just saying that I had left the Citizens Awareness
3 Foundation because we had irreconcilable, philosophical
4 differences. I didn't really get into any details. And
5 many of these press releases went to reporters that I
6 have good relationships with, and I figured they would
7 get it without me having to get into any details. I had
6 not planned to grant any interviews. I knew I that I
9 would be asked for interviews. I wasn't planning to
10 give any. I wasn't planning to get into any detail, so
11 long as -- so long as they let me just leave.
12 But I'm a thoughtful person. "Machiavellian" has
13 such a negative connotation to it, but I like to think
14 things through. And weeks before I left, knowing that I
15 might leave, and knowing that there was a side of Marty
16 that I didn't think was trustworthy, and that I had seen
17 him pound the shit out of Gulf Stream, and I had seen
18 him get -- I very much had a sense that when Marty got
19 the bit between his teeth, he wouldn't stop. So I made
20 sure that I had lots of documents that corroborated -- I
21 mean like the e-mails with Denise telling me to draft
22 lawsuits, and me telling her that's the unlicensed
23 practice of law, Denise. well, do it anyway. I can't.
24 I'm not going to do it.
25 Or her sending me the e-mail with the nonsense
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1 about 25 lawsuits a week, where are more of the
2 lawsuits? And the e-mails about her saying she's in
3 there running a law firm meeting. I gathered all of
4 that stuff up together in a nice little package with a
5 bow on it. And I was ready to push the button. And
6 when Marty threatened me, I pushed the button. In
7 addition to sending out a press release, I also sent out
8 an e-mail to as many of the attorneys representing
9 defendants that were being sued or had been sued by the
10 Citizens Awareness Foundation offering to be of
11 assistance in any way I could. And here we are.
12 Marty -- well, Citizens Awareness Foundation
13 filed a lawsuit against me for breach of contract and
14 for fiduciary duty or some nonsense, and we have had
15 tangled since then. I was financially on life support
16 before I went to work for Marty. I had just enough
17 1 money to rent a car to get down there, and wasn't sure I
18
had enough
gas to get there. And if things hadn't
19
worked out,
I probably wouldn't
have had the gas to get
20
home. I filed
Chapter 13 after
I went to work for
21
Citizens.
Now all of a sudden
I had money coming in,
22
and I was concerned about being
protected from
23
creditors.
Once I resigned, I
went back to not having
24
an income.
So we dismissed the
Chapter 13 bankruptcy
25 1 and I waited until I was qualified, then filed
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JOEL CHANDLER Volume 1 of 2
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CAFI and Marty both have alleged that they're
creditors, and that I owe money. CAFI is claiming that
I owe them a million dollars. Marty is claiming that I
owe him a million dollars. And they have showed up a
couple times for 2004 examinations, the bankruptcy
version of a deposition, which Marty proceeded with the
nonsensical threats once more in front of my attorney,
and in front of my wife, and in front of Mr. DeSouza,
who did not object to his client threatening me, by the
way. I just want to be sure we're on the record with
that.
So yes, I have had plenty of conversations with
Mr. O'Boyle, none of which have been particularly
pleasant, which is sad, because I really like Marty. I
think he's actually a really nice guy when he's not
being a dick.
Q. So you're saying -- I believe you testified
before that there are two sides to Mr. O'Boyle?
A. Yes. There's this -- the thing -- I really --
and I mean this. I genuinely like Marty O'Boyle. He's
a funny, smart guy. He's winsome, charming. He -- I
have had -- I have really warm, happy memories of
spending time with him at his house, hanging out, having
a cup of coffee. He's a delightful guy, as long as he
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JOEL CHANDLER Volume 1 of 2
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gets his way. When he doesn't get his way, then, you
know, the mask comes off.
We are all that way, right, to some extent. Ask
my kids. As long as they do what I want them to do, I'm
probably pretty cool. When they don't, I'm probably not
so cool. The problem is that in my experience, my
personal experience, Marty is very willing to use the
courts as a weapon. I mean, I think what he has done to
me in this nonsensical lawsuit that is still pending, by
the way, from CAFI, is vexatious litigation. That's
exactly what it is. It's the definition of vexatious
litigation. There's no basis to it. The allegations
are false. Of the 50 -something claims -- allegations
that are in this complaint, the only two that are true
-- and I mean this literally, is that my name is Joel
Edward Chandler and I live in Polk County. Other than
that, it's not true. It doesn't matter. Whether it's a
good lawsuit or not, it doesn't matter.
That's a terrible thing to do to somebody. I
didn't do anything wrong. I wanted to walk away. Leave
me alone. Let me walk away. And I told him that.
Don't threaten me. You go your way, I'll go mine.
Let's just pretend this never happened.
Q. So CAFI has filed a lawsuit again you?
A. Yes.
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JOEL CHANDLER Volume 1 of 2
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Q. Has Mr. O'Boyle personally filed a lawsuit
against you?
A. No. Mr. O'Boyle has not personally filed a
lawsuit against me, although he claims that he has a
cause of action against me for slander. But the CAFI
lawsuit is nonsensical for a whole host of reasons, not
the least of which is Mr. O'Boyle is not named as one of
the plaintiffs, and he is clearly an indispensable
unnamed party. And on that basis alone, I'm confident
that case will be dismissed.
Needless to say, you're kind of back to what I
have been saying all along. Either he really does
control CAFI, right, or somebody committed wire fraud.
Take your pick. It's one or the other. I don't see an
alternative to that dichotomy. It's one or the other.
Q. Now, what has he said to you is his claimed
slander claim?
A. All of the stuff that I -- the documents that I
gave to Bob Sweetapple, when I contacted -- and I
contacted Bob. Bob did not contact me. I talked to
Joann O'Connor. I sent them e-mails, and they
ultimately responded to me, to my invitation to help
them in any defense of public records lawsuit that were
filed by CAFI, which is sort of ironic because -- not
the Gulf Stream cases, but many, maybe most of the other
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162
1 cases, I was the person that actually made the request.
2 So I know the facts intimately. I would not be helpful
3 in defending the underlying facts of the public records
4 lawsuit; right? My advice would be the same thing that
5 I told the Department of Economic Opportunity. You
6 broke the law. Admit liability, produce the records,
7 and go for a fee hearing.
8 And by the way, if you did that -- and feel free,
9 Hudson, to share this with the Florida League of Cities
10 and all of their constituents. If you did that, you
11 would remove all economic motivation for public records
12 litigation. Let me just say this on the record since
13 you're here. Let me make this very crystal clear to
14 everybody. If they did that, then the plaintiff would
15 have to go to court; right? They would have to go to a
16 fee hearing. In the fee hearing, you're going to have
17 to hire an expert witness and justify your costs. None
18 of that's compensable. Once liability is established,
19 the toll stops running. The meter stops running. You
20 are not entitled to any more attorneys fees for
21 plaintiff.
22 It would be a losing economic proposition if
23 every agency did that. Public records litigation would
24 virtually stop because you -- you wouldn't even get your
25 costs back doing that. The down side of that is, of
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1
course,
how many
times
could you admit
liability without
2
setting
yourself
up for
an injunction;
right?
3 Q. Very true.
4 A. Which is why they won't do it, because they want
5 to keep giving the citizens of Florida the middle finger
6 and not complying with the law. We are back to the way
7 to fix public records litigation is everybody just start
8 complying with the law, and there wouldn't be any.
9 What was your question?
10 Q. Thus you have a conundrum.
11 What was the slander suit?
12 A. That I gave Bob Sweetapple the keys to the
13 kingdom. I sat down. I was happy to do. It was
14 voluntary. Bob -- it was the first time I ever met Bob.
15 We had talked on the phone just coordinating things. I
16 think we had a preliminary conversation, as I recall,
17 and the rest of our conversations before we met in
18 person were purely scheduling, what is convenient.
19 Then when we sat down, we did a videotaped sworn
20 statement, and I basically told the same story I told
21 here today, which is the truth, which is why it's so
22 easy to remember, and Marty didn't like that.
23 Q. So he's threatened with you with a sland er suit.
24
When
he
said he
was
going
to sue
you
for slander, was
25
that
by
e-mail?
Or
did he
call
you
on the phone?
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1 A. He asserted that to the bankruptcy court, to the
2 trustee. He claims that he has a claim against me. The
3 -- and that it's not dischargable in the bankruptcy
4 because allegedly it's fraud or whatever. His claim in
5 the -- you probably already know this. His claim and
6 the CAFI claim, we stipulated to the bankruptcy court
7 that that be removed from the bankruptcy and the stay be
8 lifted so that those could proceed so that my bankruptcy
9 could be resolved, which it still hasn't been resolved,
10 although no other creditors have objected.
11 Q. Are CAFI and O'Boyle the ones that have objected?
12 A. Yes. No other creditors objected to anything. I
13 said it earlier. If you fuck with the establishment and
14 you're not a straight arrow, you are begging for
15 trouble. I'm a straight arrow. I play by the rules. I
16 know people don't like me, but I don't really care. My
17 bankruptcy was squeaky clean, no hiccups, no nothing. I
18 filed December 8, 2015, and here we are in almost March
19 of 2016, and it still hasn't been discharged. The
20 reason is -- it should have been discharged in March of
21 last year. The reason it hasn't is because Marty was
22 dicking around with me, and harassing me, and harassing
23 my wife.
24 But that's not the threat he made. The threat he
25 made was that if I didn't back off, and if I kept
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 165
keeping his son from getting his law license, that Marty
has a lot of money, and I'll hunt you to the ends of the
earth and make your life miserable.
Q. Is he trying to do that now?
A. I don't know. I feel like in spite of my
vociferous opinion about things, which isn't going to
change no matter what, I don't have any ax to grind with
Marty. I really don't. The way we've left things the
last time I talked to him was kind of what I suggested
in the first place. You go your way, I go mine. I want
my bankruptcy discharged so I can move on with my life.
One of the ironies of this whole thing is it's
Chapter 7 bankruptcy. It's not like my creditors are
screwing with me. It doesn't really effect the
day-to-day operation of my life, but I would like to get
it behind me. I would like to move on.
But the -- what still remains is, of course, the
threat that he could potentially file a lawsuit for
slander for prebankruptcy, the nonsensical claims that
he says he has, which he doesn't really have. Then of
course there is still the CAFI ligation that I have to
deal with on my very limited resources.
Q. Have you had any discussions with Mr. O'Boyle's
counsel in this matter, Daniel DeSouza?
A. About what?
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 166
Q. Who represents CAFI in the suit that was filed
against you?
A. It's changed from week to week, seems like. I
think Dan is the one that is representing him now.
There was -- I don't know. Somebody else represented
him before. They may have changed a couple times.
Q. So have you had --
A. I can't believe that Dan would have drafted that
lawsuit. He's a much better attorney than that.
MR. GOLDSTEIN: I will show you what we will mark
as Exhibit 4.
(Defendant's Exhibit No. 4 was marked for
identification.)
BY MR. GOLDSTEIN:
Q. It's a copy of the complaint, CAFI v. Joel
Chandler. Is this the complaint you're referring to?
A. Yes, this work of fiction, yes.
Q. It is your understanding that Mr. DeSouza is now
handling this matter on behalf of CAFI?
A. I believe that's the case.
Q. And is it also your understanding that Mr.
DeSouza is representing Mr. O'Boyle here today?
A. Yes. That is what I understood.
Q. Are you aware as to whether or not the -- did you
have any meetings with DeSouza or Mitchell Berger
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1 regarding the documents that you provided?
2 A. Yes, yes, I did.
3 Q. Did you provide Mr. DeSouza and Mitchell Berger
4 those documents?
5 A. I don't remember if I gave them to Berger. He is
6 the guy with the giant ego; right? Isn't that the guy
7 we're talking about?
6 MR. DESOUZA: Which are the documents we are
9 talking about now, Josh?
10 MR. GOLDSTEIN: We are talking about the
11 documents that Mr. Chandler provided to Mr.
12 Sweetapple.
13 THE WITNESS: Yes. I gave -- they made a very
14 vague CAFI, O'Boyle, whatever, that whole kerfuffle,
15 made document demands, which I produced. It was a
16 very, very, very significant number of documents that
17 I produced.
18 BY MR. GOLDSTEIN:
19 Q. Those were the same documents that you also
20 produced to my client?
21 A. We are talking about -- I think that we are
22 talking about hundreds of thousands of pages. Not
23 hundreds of thousands of files, but I want to say this
24 was something in the order of about 64,000 documents,
25 and some of those would have been many, many, many
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1 pages. We are talking about hundreds of thousands of
2 pages. As I recall, it was over one terabit of data.
3 So I can't -- I don't know that I would be willing to
4 say with certainty that every single file was there, but
5 they should have been about the same.
6 Q. Do you know who Mr. Berger represented?
7 A. I believe he represented Marty, was my
8 impression. They flew up here and we met for drinks at
9 a really nice Irish pub downtown. I say "nice," meaning
10 it is a shit hole. It's in a Irish pub. That's what
11 they're supposed to be. And I say that as an Irishman.
12 It has a very authentic feel.
13 So we met down there, and had drinks, and we
14 chatted, and they made overtures. And they didn't buy
15 my drinks, they didn't buy my dinner. I was very
16 disappointed in that, very, very disappointed.
17 Q. What were your discussions with them while you
18 were at this pub?
19 A. The gist of the conversation was trying to kind
20 of, everybody climb down off the ledge. This wasn't --
21 I don't remember the exact date or anything. This was
22 not long after I had the nuclear option, which was you
23 are threatening me. Fuck you. Let's go, and I turned
24 both keys.
25 I think they kind of -- I don't know. Basically
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1 one of the issues was help us get rid of all these cases
2 CAFI's got, like an albatross hanging around our neck.
3 Help us do something with them. There weren't any real
4 concrete proposals. It was just kind of the way Mitch
5 Berger -- he's a nice guy, as long as you want to listen
6 to him tell you everybody he's ever met.
7 He like, you know, you and Marty are going to be
8 at each other's throats for the rest of your lives.
9 Let's try to work this out. So they -- there was a
10 proposal -- I say a proposal. It was a suggestion, I
11 guess, possibility that hey, we will just give you the
12 foundation. We will just give it all to you. I was
13 like, what would I do with it? I don't want anything to
14 do with it. I've extricated myself from it.
15 And I -- plus, it would be expensive to deal with
16 all that stuff, all those cases. So the question was,
17 what would it take economically -- and they were very
18 clear, to their credit, that they were not offering to
19 pay me any money directly, but what would it cost to do
20 all of this? They told me to think about it and give
21 them a proposal, which I did a few days later. My
22 proposal was that I would take -- they could sign the
23 foundation over to me, and I would take responsibility
24 for disposing of all of the litigation, which would have
25 been really easy, and I wanted Marty to make a
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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contribution to the charity of my choice, which would
have been the First Amendment Foundation, for 2.75
million dollars. Do that, and I will step in and help.
Don't do that, and you're on your own. But I wouldn't
get any of the money. I would have not -- my proposal
did not involve me getting a penny.
Q. That clearly didn't occur?
A. It did not.
Q. Now, you said when you got threatened, you
reached out to numerous attorneys that were involved in
CAFI lawsuits.
A. Yes.
Q. Do you recall who you reached out to?
A. I want to say I talked to Jerry Richmond at one
point. He was representing Wantman Group, I think, one
of the defendants. I talked to Grier Wells. There were
not nearly as many as I would have thought, frankly. I
would have thought they would be like, hey, help us out.
But it wasn't that many. I was surprised how few were
interested.
MR. DESOUZA: Joel, I'm sorry to interrupt. What
was the name that you said after Jerry Richmond?
THE WITNESS: The Wantman Group and Grier Wells.
MR. DESOUZA: Grier Wells.
THE WITNESS: He is an attorney somewhere in
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1 North Florida.
2 MR. SWEETAPPLE: Gray Robinson.
3 MR. GOLDSTEIN: I think it's Gray Robinson, Dan.
4 MR. DESOUZA: Is Grier Wells the name of an
5 attorney?
6 THE WITNESS: Yes. He's on the Board of
7 Governors for the Florida Bar, if I'm not mistaken.
8 MR. DESOUZA: So it's Grier Wells of Gray
9 Robinson?
10 THE WITNESS: Yes.
11 MR. DESOUZA: Thank you. Sorry about that.
12 THE WITNESS: That does sound like a law firm
13 name, I have to admit.
14 BY MR. GOLDSTEIN:
15 Q. And you reached out to my client, Mr. Sweetapple?
16 A. Yes.
17 Q. And then you contacted him subsequently? He
18 responded to your e-mail?
19 A. Yes. And I was really curious. By all the
20 descriptions I got from Mary, I was expecting to see a
21 guy with horns and a tail. I thought he might have a
22 pitchfork, but he didn't.
23 Q. What did Marty tell you about Mr. Sweetapple?
24 A. I don't remember exactly, just that he's a bad
25 guy, whatever. It's his nemesis. It's like a cartoon
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JOEL CHANDLER Volume 1 of 2
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character or something.
Q. So Marty had a fair amount of animosity toward
Mr. Sweetapple?
A. I would say so. That was my impression.
Q. How many times did you speak with my client?
A. We have talked quite a few times. It's not like
we hang out. I think this is only the second time we
have actually seen each other face to face. All of my
interactions with Bob have been very pleasant. They've
been cordial. I am confident that he and I probably see
the world very differently on many, many issues. But I
don't -- like I say, I don't make this stuff personal.
Leave me and my family alone, and we are good. Start
fucking with little old Black ladies, and we are going
to have a problem. But other than that, I don't really
care. I like Bob. He's been nice to me. I don't agree
with everything that I have heard, but I don't know that
everything I have heard is true.
Q. And by everything you heard, you mean everything
you have heard from Mr. O'Boyle?
A. Yes. I mean, I think that -- I thought that the
-- I thought the RICO lawsuit was ill advised for a
whole host of reasons, not the least of which is making
a public records request, in and of itself, is not a
criminal act. I'm not a RICO attorney, so what do I
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February 24, 2016
173
1 know? I watch the Sopranos, but what do I really know
2 about that kind of stuff.
3 I, frankly, have been very disappointed in the
4 approach that the establishment has taken, and Bob is
5 not the establishment, but he is an attorney for the
6 establishment, which doesn't make him a bad guy. I,
7 like most people, try -- I think of people on the other
8 side of me, "other," as being somewhat monolithic, and I
9 recognize that's a fallacy. But I do think the
10 establishment's taking the wrong approach to try to
11 resolve the complaints they've got with people like
12 Marty O'Boyle.
13 I vehemently disagree with -- I don't know that
14 this is necessarily Bob's doing, but the Town going
15 after Chris O'Hare, I completely disagree with that.
16 And my perception is, based particularly on a RICO
17 complaint, that there is sort of this lumping Chris and
18 Marty into the same cabal. I just don't have any -- my
19 experience with Chris has been nothing but -- I don't
20 have anything negative to say about Chris, and I'm
21 baffled as to why he's hanging out with Marty. But we
22 all make poor choices sometimes.
23 Q. So you met with Mr. Sweetapple?
24
A.
Yes.
25
Q.
And I
believe you testified previously that you
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JOEL CHANDLER Volume 1 of 2
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February 24, 2016
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1 agreed to provide him with a sworn statement?
2 A. I did. And just for the record, just for the
3 record, we had lunch together at Palace Pizza. And if
4 I'm not mistaken, he bought me a slice of pizza. So I
5 want to be sure we have full disclosure here.
6 Q. Was that prior to or after the sworn statement?
7 A. I think we took a lunch break. But I just want
8 to be sure that everybody understands that my testimony
9 was in no way influenced by a slice of pizza.
10 MR. GOLDSTEIN: Let me show you what I will mark
11 as Exhibit 5 for identification purposes.
12 (Defendant's Exhibit No. 5 was marked for
13 identification.)
14 BY MR. GOLDSTEIN:
15 Q. Exhibit 5 is the sworn statement of Joel
16 Chandler. Does that transcript look familiar to you?
17 A. Seriously, when you hand me -- hold on. Let me
18 finish. When you hand me -- how many pages is this?
19 Dan will tell you how this works. If you ask me to
20 authenticate this, I'm going to sit here and read every
21 last word of if. If you're going to ask me if this is
22 my -- I have no choice but to read 193 pages. I read
23 almost all of the transcript that I was provided
24 previously. This appears to be that. But if it is or
25 not, I don't know. There is no way for me to know
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 175
1 without reading it.
2 Q. Would you say that the testimony that you gave in
3 the sworn statement in July 23rd, 2014, was true and
4 accurate?
5 A. Yes.
6 Q. Is there anything you know today that would
7 change the fact of whether or not that testimony in the
8 sworn statement from July 23rd, 2014, is no longer true
9 and accurate?
10 A. No.
it Q. Thank you. I believe you testified recently or
12 previously that you had a 2004 examination that Mr.
13 O'Boyle --
14 A. I had two of them.
15 Q. When was the last one, if you recall?
16 A. I want to say it was in -- I want to say
17 November. I'm not sure. I can't speculate.
18 Q. Do you recall testifying at your 2004 examination
19 that you were aware of the RICO suit that was filed, but
20 felt that it was dismissed imprudently?
21 MR. DESOUZA: I'm sorry. I didn't catch the
22 question, Josh.
23 MR. GOLDSTEIN: The question was, does he recall
24 testifying at the 2004 examination in October 2015,
25 that he was aware of the RICO case, but he believes
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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that it was dismissed by the federal court
imprudently, in his opinion?
A. I don't recall saying that. I think that is the
exact opposite of what I said. I believe that it was
filed imprudently. And I thought that the appeal -- and
I don't know whether it was ultimately appealed or not.
I know Joann O'Connor called and talked to me about it
at one point. And I shared with her my belief that it
was imprudent to appeal it. If it got appealed, I'm
delighted. I think it would be great, because I think
it will be -- the dismissal will be upheld by the
Eleventh Federal Circuit in Atlanta, which I think
actually is a good thing for public records access. I
think it was imprudent to file it. I think the court
got it right.
Now, some of the things in the judge's opinion, I
may not agree with entirely. But overall, I thought it
was a good decision.
Q. Do you think that the actions that were being
taken by CAFI and the O'Boyle Law Group when you were
involved, that eventually caused you to leave CAFI,
those things that were going on, do you think they were
appropriate or proper acts?
A. No. I think they were terrible.
Q. Do you think there is clearly some kind of
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
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violation of law that was occurring, given what was
going on?
A. I think there was. I think there was the
unlicensed practice of law going on. I think that
again, we are back to either Marty really does control
CAFI --
MR. DESOUZA: Joel, before you go on, I just want
to note my objection to form on the record before the
answer goes on.
A. Okay. We are back to this -- we're on the horns
of a dilemma. Either Marty really controls CAFI, and
the O'Boyle Law Firm, and whole mess, which I think
creates some serious ethical and legal issues, or the
alternative is that among other things, in addition to
the unlicensed practice of law, you had wire fraud going
on because public records requests were being made on
behalf of a foundation that wasn't making those public
records requests.
Do I think there were criminal things going on?
I'm not an attorney. But as a layperson, not trying to
render a legal opinion, but as a layperson, do I think
there were potentially illegal things going on? Yes, I
do.
My issue
with
the --
and
again, I'm
not
trying to
be funny when I
say
this.
The
totality of
what
I know
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February 24, 2016
178
1 about RICO is from watching the Sopranos. I don't
2 understand the ins and outs of RICO. What I think I
3 understand is that there has to be an underlying
4 criminal activity. I don't think that making a public
5 records request in and of itself, or even making
6 thousands of public records requests on the Town of Gulf
7 Stream is an illegal action. There may be a whole bunch
8 of other illegal actions.
9 I mean, I'm mystified, really mystified, given
10 what I think are just clear evidence that I have
11 provided to anybody that wants to see it, that there was
12 the unlicensed practice of law going on, both on behalf
13 of Jonathan O'Boyle and Denise DiMartini. I think that
14 there are really serious Bar issues as far as not having
15 engagement letters, and not providing closing
16 statements, and engaging in settlement negotiations
17 without the consent of the client, and demanding
18 settlement amounts that are beyond entitlements when I
19 think they're being presented as entitlements. I can
20 think of a whole bunch other issues to go after them on.
21 I just don't agree with the public records part of it.
22 Q. During your discussions with Mr. Sweetapple, did
23 he ever say to you that he felt Mr. O'Boyle was a
24 criminal?
25 A. I don't remember him using those words. No.
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February 24, 2016
179
1 Q. Now, you said you had dealings with Mr. O'Hare?
2 A. Yes.
3 Q. What were your dealings with Mr. O'Hare?
4 A. I was contacted by his attorney, Lou Roeder,
5 sometime in -- this is way before I went to work for the
6 foundation. And Lou -- not Chris, Lou invited me down
7 to meet with them in Delray, I think is where Chris's
8 business is. I'd never met Chris. I'm not sure I even
9 talked to him before that. I may have, but I don't
10 think I did. And Lou, as an attorney, asked me -- hired
11 me to come in and talk to him about open government
12 issues, which is something I do frequently with all
13 sorts of attorneys.
14 Chris sat in on that discussion, and it was
15 nothing more than a Public Records 101, these have been
16 my experiences. And speaking to Lou -- and Lou is the
17 person who paid me. Chris did not pay me anything, and
18 they covered my expenses coming down there and paid me a
19 little bit for my time. I just basically gave them a
20 private Public Records 101 seminar, is what it amounted
21 to.
22 Q. Do you recall when this was?
23 A. I don't. It would have been after I met Marty
24 for the first time, which would have been early 2013,
25 and before I went to work for CAFI in early 2014, so mid
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JOEL CHANDLER Volume 1 of 2
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to late 2013, I would guess.
February 24, 2016
180
Q. Do you know how Mr. Roeder got your information
or knew to contact you?
A. My understanding is that he was referred to me, I
guess, by Marty or Jonathan. I don't know. I may have
known at one point. I don't recall.
Q. So Chris could have been referred to you by
Marty?
A. I wouldn't say Chris was. I would say Lou was.
I was very clear in my communications with Lou about
this, that I was being retained by Lou. I'm not an
attorney. And I'm very, very circumspect about the UPL
issue. I make it very, very clear when lay people ask
me questions, my response is, "I'm not an attorney. I
can't give you legal advice. I can tell you what I
would do if I was similarly situated, but I can't give
you legal advice."
I was very clear that if you are paying me to
come in -- this is exactly what happened when I was
hired by Bill Ring to come down and talk to him and his
then paralegal, Ryan Witmer, about open government
issues. I was giving my perspective to attorneys, which
that, I can do. I can't do that with non -attorneys.
Q. And prior to meeting Marty O'Boyle or Chris
O'Hare, had you ever filed a public records request to
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JOEL CHANDLER Volume 1 of 2
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the Town of Gulf Stream?
February 24, 2016
181
A. Well, as I mentioned earlier, there are 412
municipalities, or at least 412 members of the Florida
League of Cities, and I have probably made at least one
public records request to all of those. Many of them I
would have made many public records requests to, for
various reasons, various times, just like I have made
public records requests to virtually every state agency
and every local agency in Florida. I'm sure there are
some I haven't gotten to yet, but I will get there
eventually. So I may have. I don't really remember.
Q. Do you recall when in 2013 you met with Chris
O'Hare, like what month?
A. No. Like I said, I'm guessing it would have been
mid to late 2013, but I don't really know. If you
haven't figured it out yet, I love to talk about open
government issues, and I have at least one or two
opinions on the issue. So somebody who is willing to
actually buy my lunch and pay me a little bit of money
to come and talk to them, sign me up. I will do that
all day long. We had a really -- it was a really,
really nice visit, and we really clicked, and they
seemed genuinely -- both Lou and Chris seemed genuinely
interested in open government issues. It was fun. For
me, that's a good time.
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JOEL CHANDLER Volume 1 of 2
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182
Q. Do recall filing five public records requests to
the Town of Gulf Stream in September of 2013?
A. No. I don't specifically. That wouldn't
surprise me if I did. I would be surprised -- like I
said, I would be shocked if you could find a
municipality in Florida that I have not made a public
records request to. If you do, please let me know, so I
can catch up with them.
Q. Are you aware as to the number of public records
requests Mr. O'Hare has made to the Town of Gulf Stream?
A. No. I don't know the number.
Q. Would you be surprised if it was well over 2,000?
A. No. I don't think I would be surprised.
Q. When was the last time you spoke with Mr. O'Hare?
A. Last night.
Q. What did you guys discuss?
A. He -- it was the first time I talked to Chris in
a long time. He was asking me my opinion about the
legislative stuff that is going on, specifically, the --
everybody gets focused -- I can't remember the bill
number, but the one about the fee thing. That's what
everybody is all worked up about, which by the way, is
not going to fix the problem. But I keep offering to
share that with whoever wants to listen. I can tell
them how to fix the problem, but nobody has bothered to
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 183
give me a call, except Chris did.
We chatted about that. I asked him if he was
coming up for the deposition. He said he thought he
was, and that Lou would probably come up, and I hadn't
seen either one of them in a long time, and I consider
both of them to be friends. I told him I looked forward
to seeing him. I'm sorry he didn't make it.
Q. Your first dealing with Chris O'Hare was in 2013
after Mr. Roeder met with you?
A. As I recall, we met together. It was all three
of us. Chris was in and out. He's a -- Chris is a
working man. He's a man's man. He would come in all
covered in dust. In fact, the first time I laid eyes on
Chris he was operating a forklift.
Q. Do you recall receiving a subpoena to appear here
today?
A. Was it a subpoena or just a notice? I got
something. I know I'm supposed to be here.
Q. The subpoena was served back in -- it was
originally for deposition in June of 2015.
A. I don't know. I have a lot of litigation going
on. It's hard to keep track of it all.
MR. GOLDSTEIN: I will show you what we will mark
as Exhibit 6.
(Defendant's Exhibit No. 6 was marked for
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 184
identification.)
BY MR. GOLDSTEIN:
Q. It's actually a composite exhibit, subpoena,
Exhibit A to the subpoena, and re -notice -- should be
re -notice of deposition for today.
A. Okay. I'm here, so apparently I got it.
Q. It requested that you produce documents. Did you
bring any documents with you here today?
A. No.
Q. Is there a reason --
A. I have already objected to them. I sent you an
e-mail about this.
Q. And your objection is based upon what?
A. I don't remember the e-mail exactly that I sent
you. One is most of it is duplicative. As I have
mentioned to you in the e-mail, and as Dan DeSouza well
knows, I get a little touchy about this issue. I have
very limited resources. And you guys, you, and Dan, and
Marty, keep asking me to produce the same fucking
documents over and over again. It takes -- you have no
idea how long it takes to copy like 1.2 terabytes of
data using USB3 connections. Right. And I am not about
to go out and buy a thunderbolt connection to satisfy
you guys' sick perversion for wanting the same shit over
and over again.
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 185
1 If we were to count the actual files that you
2 asked for, the documents, I suspect that 99.9 percent of
3 what you've asked for, I've already given to Bob, and I
4 already gave to Dan, and when Marty asked for it and
5 thought I was going to show up with a fucking dump truck
6 full of hard copies, I brought it on a hard drive, and
7 he wouldn't take it.
8 I keep giving you the same stuff over and over
9 again. I'm not even a party to the litigation. So
10 there is no way in hell the judge is going to tell me
11 that I've got to do that shit. So that's one. It's
12 duplicative. It's enormously burdensome. I have very
13 limited resources. I'm not going to go spend my money
14 to buy a hard drive to satisfy some attorney's
15 perversion for getting more crap they've already got.
16 Q. You're assuming I have it.
17 A. Your client does. And I know that's the same
18 shit that Dan and Marty pulled. Well, Marty, I don't
19 have it. Dan's got it. But you guys probably came in
20 the same car, just like Dan and Marty flew up in the
21 same fucking plane. And everybody's like, "I don't have
22 it. He's got it."
23 Here's the thing. We all know -- let's put our
24 cards on the table. We all know -- I am an open book.
25 I've got nothing to hide. And the reason I have no
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
186
1 trouble with this instant recall with all these dates
2 and stuff is because I'm telling the truth. I don't
3 have to remember where I hid the truth because I didn't
4 hide it. And I am more than happy to be cooperative
5 with whoever it is. I'm in a deposition. I'm going to
6 tell the truth. I think that everybody -- to be really
7 blunt here, I think everybody in the room here is fucked
8 up except for the court reporter, me, and Lou Roeder. I
9 like Bob. Bob and I have gotten along very well. The
10 only wrinkle that's ever come in my relationship with
11 Bob is that fucked up shit you sent me demanding all of
12 those documents, because I have already given them to
13 Bob.
14
Let me finish. You asked
the question. I'm
15
going to finish. I don't believe
for one second that a
16
judge is going to tell me that I
have got to produce the
17
same documents again at my expense,
using enormous
18
amounts of my time, and tying up
the only computer I
19
have, the only way I have to make
a living, for
20
something you guys already have.
I just don't believe
21
he's going to make me do that. If
you don't agree with
22
that, then let's go to the judge
and have him get an
23
order to compel, and I will be more
than happy to
24
respond to it.
25
Let me finish. We agreed
you will let me finish.
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JOEL CHANDLER Volume 1 of 2
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The other stuff that you have asked for, the only
communications that I recall having with Dan DeSouza
about anything are scheduling issues. The only -- they
have nothing to do with any of this. There's nothing
useful there whatsoever, scheduling stuff.
If I got any e-mails from Mitch Berger, which you
guys put in there twice -- and by the way, you didn't
ask for Dan DeSouza. You asked for Danielle DeSouza,
and I don't know a Danielle DeSouza. Unless Dan's got a
really ugly sister, I don't know a Danielle DeSouza.
MR. DESOUZA: I only go by "Daniel" on Tuesday
nights.
THE WITNESS: I advocate for those folks, too, so
we are in good shape.
The -- I don't know that I got any communications
from Mitch Berger. I did get some from whoever his
sidekick was, who you didn't name in the duces tecum.
But again, it would have been purely scheduling stuff.
There is nothing meaningful there.
The communications that I had -- I did have some
communications with Mark Hanna because Mark Hanna and
I actually had some discussions, which are my
attorney-client privilege, because he and I were
discussing some cases I was contemplating having him
do. You're not getting those ever.
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1 I have had some conversations with Lou Roeder
2 that I am asserting my attorney-client privilege,
3 because he and I have had some conversations about
4 doing some work together.
5 I do think that -- I can't assert Chris O'Hare's
6 privilege for him, but I think that much of the
7 communications that I've had with Lou Roeder are
8 attorney-client privilege. And the communications I
9 have had with Chris O'Hare have been like he sent me
10 an e-mail about his divorce. Well, you know what?
11 Fuck you. I'm not giving it to you. And if you want
12 to go in front of a judge over that issue, let's go.
13 As I said to you in my e-mail, I have been
14 extraordinarily cooperative with you, just like I was
15 cooperative with Bob giving the sworn testimony, just
16 like I have been cooperative with Dan DeSouza. I am
17 willing to be cooperative. But if I get even so much
18 as a whiff of somebody bullying me or asking for shit
19 they're not entitled to, fuck you. It's not going to
20 happen. So that's why I didn't bring them.
21 If you want to go to a judge, and you want to
22 discuss this with the judge, we can do that. If you
23 want to ask me for something, if there is something
24 specific you are looking for, just ask me and I will
25 be happy to find it for you. But that's very
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February 24, 2016
189
1 different than you better bring it, or else, and we're
2 going to ask you to bring a dump truck full of crap
3 that's going to take you literally days. I will be
4 tying up my only source of income dicking around with
5 the stuff that you guys already have. I'm not going
6 to do that. I would much rather spend my time driving
7 my happy ass down to South Florida and going in front
8 of a judge.
9 BY MR. GOLDSTEIN:
10 Q. So if I provided you with a hard drive, you
11 wouldn't --
12 A. Did you do that?
13 Q. I'm asking you now. If I sent you a hard
14 drive --
15 A. Fuck no. I just said, the only computer that I
16 have access to is this one, which is not even mine. I
17 don't even own it. And the only -- I do what I do by
18 writing, and this is it. So no. I'm not going to do
19 that. You want to get access to another computer?
20 Fine. Because that's the problem. I've got one hard
21 drive over here.
22 MR. SWEETAPPLE: We will work with you. It's not
23 going to be adversarial.
24 BY MR. GOLDSTEIN:
25 Q. I'm not trying to be adversarial.
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1 A. Hold on a second. You and I are going to get
2 along just fine. Okay. We are good. But -- which is
3 why I sent you that e-mail. And I really thought about
4 that e-mail first. I thought about calling Bob and
5 saying hey, look, ask and I'm happy to -- if you are
6 looking for something, if you want to burn Marty
7 O'Boyle's ass to the ground, and you need help finding a
8 document to do it, just ask me. I will try to help you.
9 No problem there.
10 But when you start -- you say we're not trying be
11 adversarial. What the fuck do you think a subpoena is,
12 dude? It's a fucking adversarial instrument.
13 MR. SWEETAPPLE: It's a matter of course.
14 A. Let me finish. I'm not done yet. I will tell
15 you when I'm done. When you send me a subpoena telling
16 me that I've got to give you something, that is
17 adversarial. If you had called me up -- if you had
18 called me up and said hey, we are looking for this. Do
19 you think you could put your hands on it? Yes, okay,
20 sure. No problem. See the difference?
21 BY MR. GOLDSTEIN:
22 Q. I understand the difference.
23 A. I'm done now.
24 Q. All right. You also have to understand there is
25 a matter of course and chain of custody and process in
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
191
which I have to be able to acquire things to show I got
them from you.
A. We could have done that without a subpoena.
Q. We will work with you.
A. Work with me. I'm happy to do it.
MR. GOLDSTEIN: I don't think I have anything
further. I just need five minutes to talk with my
client to make sure, and I think I should be done.
(Recess from 4:40 p.m. to 4:50 p.m.)
MR. GOLDSTEIN: I have nothing further.
(End of Volume 1 of 2.)
(Deposition continues in Volume 2.)
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 192
1 1 DEPOSITION ERRATA SHEET
2
3
4 Our Assignment No. 118775
5 Case Caption: O'Boyle vs. Sweetapple
6
7
8 DECLARATION UNDER PENALTY OF PERJURY
9 I declare under penalty of perjury that I have
10 read the entire transcript of my Deposition taken in
11 the captioned matter or the same has been read to me,
12 and the same is true and accurate, save and except for
13 changes and/or corrections, if any, as indicated by me
14 on the DEPOSITION ERRATA SHEET hereof, with the
15 understanding that I offer these changes as if still
16 under oath.
17
18
19
20
21
22
23
24
25
Signed on the day of
JOEL CHANDLER
20
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9
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13
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15
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17
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20
21
22
23
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
193
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DEPOSITION ERRATA SHEET
Page No.
Line
No.
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to:
Reason for
change:
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to:
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change:
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to:
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SIGNATURE:
DATE:
JOEL CHANDLER
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8
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
194
O ESQUIRE
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DEPOSITION ERRATA SHEET
Page No.
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No.
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to:
Reason for
change:
Page No.
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change:
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SIGNATURE:
DATE:
JOEL CHANDLER
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3
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
CERTIFICATE OF REPORTER
STATE OF FLORIDA )
COUNTY OF HILLSBOROUGH)
February 24, 2016
195
I, Megan M. Soria, certify that I was authorized to
and did stenographically report the deposition; that a
review of the transcript was requested; and that the
foregoing pages are a true and complete record of my
stenographic notes taken during said deposition.
I further certify that I am not a relative, employee,
attorney, or counsel of any of the parties, nor am I a
relative or employee of any of the parties' attorneys or
counsel connected with the action, nor am I financially
interested in the action.
Dated this 9th day of March, 2016.
Megan M. Soria
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
$1,000
128:22
140:6
$1,200
87:20
121:20
$1,500
131:21
$12,000
23:14
$120,000
118 :2 0
$2,000
41:3
128:11,22
131:20
$2,500
9:1 129:6
153:7
$20,000
41:4,12
$25
31:13
129:1
$25,000
60:13
$250
129:2,7
131:22
$3,000
128:20
$4,000
23:13,15
128:20
131:10,25
$400
68:8
$5,000
128:10,21
153:6,11
$50
22:24
$50,000
16:4
20:22
59:16
60:12
$500
128:19
131:5
$500,000
124:16
$60,000
69:2
128:25
$75,000
66:4
1
1
49:5,6,8
50:16
62:4
108:23
109:4
191:11
1,200
68:18
1.2
184:21
10
11:16
54:17
61:25
86:5,19
128:18
100
41:17
68:13,15
72:15,24
74:22
135:5
136:5
101
140:22
179:15,20
11
21:19
101:9,17,
20
119.12
59:23
11:51
54:18
12
138:18
120
69:16
12:53
54:18
13
135:17,20
138:19,20
158:20,24
1355
6:5
14
32:22
100:13
135:17,20
138:20
15
32:22
42:3
131:13
18
111:24
18 -year-old
4 7: 7
193
174:22
1960
3 7: 3
let
41:16
2
2
21:19
53:12
62:3
82:16,17,
19 83:7
101:23
191:11,12
2,000
68:19
182:12
2.75
170:2
20
21:18
73:3
131:13
2004
7:3 49:6
132:23
159:6
175:12,
18,24
2007
12:16
15:10
2 0: 25
2 1: 16
2008
15:12
21:1,3
23:10,24
February 24, 2016
Index: $1,000..2016
2013
25:22
26:16,17
29:25
30:4
31:25
32:20
38:17
42:13
43:1
47:23
48:16
71:7
179:24
180:1
181:12,15
182:2
183:8
2014
7:5
48:12,17,
19 49:24
50:18
56:5
61:21
63:21
83:11
101:14,
16,18
102:22
103:17
109:6
110:22
111:6
138:15
175:3,8
179:25
2015
41:16
164:18
175:24
183 :2 0
2016
164:19
ESQUIRoE 800.211.DEPO (33 76)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
22nd
2:13
48:25
100:23
49:2,3
62:25
63:18,19
3
69:10
77:10
3
79:10
100:15,16
84:2
101:1,24
23rd
3,000
63:18
68:19
175:3,8
74:23
25
30
21:25
20:10
135:4
53:3
158:1
72:18
73:1
250
77:16,24
128:18
78.12
26
300
110:22,23
21:10,12
27
30th
101:14,17
129:25
27th
133:21
77:3
138:16
78:21
155:1
79:9
33803
80:12
6:5
83:11,23
84:3
350
90:23
21:15
94:5
3:09
136:9
138:13
28
3:21
103:17
138:13
110:22
287.058
4
53:8
2:00
4
91:21
50:18
92:4
166:11,12
2:05
400
100:23
21:11
136:14
143:18
412
30:6
181:2,3
4:40
191:9
4:50
191:9
4th
48:17
109:5
5
5
54:16
62:1
108:23
109:4
174:11,
12,15
50
45:20
53:1,12
60:14
74:2
50 -
something
160:13
500
68:9
136:15
143:19
501C3
96:7
503
96:24
5:00
45:10
5:30
95:17
5th
109:19
February 24, 2016
Index: 22nd..absence
164:18
80
19:22
20:24
88
106:18
89
6 106:18
183:24,25
60
52:23
138:6
600
31:14
64,000
167:24
6:00
45:10
95:17
6:15
45:16
6th
108:24
109:5
7
7
159:1
165:13
75
60:15
75,000
68:22
8
21:20
12 9: 4
p
9
11:16
21:20
101:24
102:1,22
103:13
90
19:22
20:24
96
100:13
99.6
19:25
99.9
135:25
185:2
A
a.m.
54:18
ability
86:25
111:14
133:6
Abrahams
25:1
absence
99:7
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
absolute
103:1
absolutely
38:14
104:10
113:15
131:1
absurd
125:6
abuse
76:12
124:12
abused
22:13
44:12
abuses
22:12
112:16
access
9:4
10:19,21,
24 12:13
13:7
14:12
16:6 19:4
20:2,16
22:17
23:11,20,
22 24:1,
3,7 28:12
34:8,12,
18 36:4
37:20
42:11
46:19
47:9 57:4
58:3
75:22
76:1 95:4
111:15
115:24
116:2
125:1
176:13
189:16,19
accesses
76:1
accommodati
on
150:25
accomplishe
d
96:4
account
22:8
124:18
accountabil
ity
76:12
accounting
24:19
76:16
accounts
22:2,4
accrued
152:24
accurate
50:23
103:9,14
175:4,9
accurately
83:7
accustomed
152:18
acknowledge
123:18
153:12
acknowledgm
ant
137:13
ACLU
9:16
34:15
acquaintanc
es
130:13
acquire
191:1
acquitted
46:22
47:4
act
15:1
18:16
52:20
53:8
71:20
86:16
94:14
126:24
172:25
acting
115:5
action
20:4
99:25
115:25
123:15
161:5
178:7
actions
127:11
176:19
178:8
activism
37:12
116:24
activist
8:7 9:25
10:2,7,8
86:2
111:10
136:24
activists
12:3
37:7,8,9
February 24, 2016
Index: absolute..advocacy
140:18
activity
178:4
acts
176:23
actual
34:23
44:21
185:1
ad
33:1
adamant
113:4
addicts
131:24
addition
5:19
11:14
12:1
20:13
112:3
116:5,19
158:7
177:14
additional
43:22
address
6:4 41:1
90:2,10,
11,12,13
addressed
5:8
addresses
41:15
adjudicated
20:1
admit
126:4
162:6
163:1
171:13
admitted
65:1
131:3
adoption
106:3,4,
8,22
advantage
43:10
55:23
advantages
56:22
57:20
adversarial
28:18
72:8
79:21
99:2
189:23,25
190:11,
12,17
advice
45:24
46:11
97:3,21
125:25
162:4
180:15,17
advise
97:13
advised
172:22
advising
105:2
advocacy
26:6
27:22
28:13
56:23
66:7,13,
15 67:5
68:4 70:3
88:9
107:5
r ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
110:5
123:21
134:7
advocate
11:22
17:13
111:11
119:12
148:21
167:13
advocates
34:16
advocating
38:23
affairs
46:25
affidavit
100:19
101:4,5,
13,15,16,
20 102:1,
4,8,10,
16,20,21
103:8,9,
13
affiliation
118:2
affirm
4:5 127:5
affirmed
4:12
African-
american
9:19 11:9
45:6,22
130:5
African -
americans
45:9
afternoon
69:14
agencies
11:15,16,
19 12:5
13:12,17
20:14
23:19
28:16
36:2 53:5
60:1
72:17
111:17,19
147:9,11
agency
20:3 30:9
70:1,7
118:1
125:23
162:23
181:8,9
agenda
26:24
45:18
aggravated
122:12
agonized
135:14
agonizingly
151:17
agree
34:20
35:1 36:6
64:14
75:17
102:19
127:10,21
135:18
148:22
152:20
172:16
176:17
178:21
186:21
agreeable
70:14
agreed
20:3
69:17
74:14
85:4
93:21
115:18
124:21
174:1
186:25
agreement
74:10
75:21
93:4,18
136:20
146:19
agreements
75:18
125:15
151:12
ahead
61:3 84:7
92:22
Airport
26:10
albatross
169:2
aligned
88:9,11,
25
alledgedly
123:11
allegations
92:14
160:12,13
alleged
92:8
159:2
allegedly
106:14
164:4
February 24, 2016
Index: advocate..appealed
alleging
114:8
allowed
7:24
105:10
112:24
151:25
allowing
36:14
alternative
161:15
177:14
amazing
32:7
40:18
ambivalent
82:5
amendment
12:10
13:2
25:25
111:23
139:15
140:1
141:5,16,
21 170:2
American
8:21
amicably
87:17
amorphous
77:10
amount
36:20
41:22
60:6,13
172:2
amounted
179:20
amounts
114:23
150:18
152:14,22
178:18
186:18
Ana
107:10,14
138:24
ancillary
153:15
Anderson
107:10
138:24
Angel
84:12,19
animals
34:17
animated
118:4
animosity
172:2
answers
5:16
132:4
anticipated
133:25
anymore
14:19
51:15,23
ape
118:6
123:8
API
23:3,7,20
apparently
18:24
27:19
184:6
appeal
176:5,9
appealed
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: appearance..attorney-client
176:6,9
71:17
164:1
5:10
46:13
appearance
92:15
asserting
78:11
51:20
80:2,3
133:3
99.10
90:1
57:10
96:15
Aronberg
188:2
assumed
58:3,11
103:4
43:3,18,
82:2
59:24
assertion
60:9,10
146:4
24 44:15
132:16,18
assuming
88:2,20,
appears
Aronburg
assertions
185:16
23 89:10
49:5
34:1
148:20
assumptions
96:5
101:4,12
arrangement
149:1
148:19
97:13,21
174:24
93:25
98:5,6
appellate
assessment
assurance
102:24
arrangement
33:11,12
113:18
128:8,24
108:3
a
36:7
assurances
129:19
applauded
62:24
asshole
70:18
130:6
149:7
141:7
115:11
132:10
approach
arrested
assured
137:11,22
39:21
33:23
assign
15:8
138:1
126:1
86:25
Atheists
146:8,9
139:25
arrow
assigned
assigned
34:14
148:6,18,
148:25
146:24
23 149:14
Atlanta
173:4,10
arrows
assigning
176:12
152:11
118:24
153:16,25
approached
119:16
86.19
attached
154:3
63:7
assist
83:6
159:8
articles
approximate
12.24
139:8
attack
166:9
ly
13:9,16
assistance
37:17
170:25
21:12
44:1,4,14
8:11
171:5
attend
172:25
April
83:14
158:11
121:14
173:5
31:18,20
90:10
assistant
140:11
177:20
32:20
articulate
68:25
attendance
179:4,10
38:17
88:23
105:25
14:21
180:12,14
42:13
43:1
ass
assisting
attended
attorney's
47:23
152:5
42:14
140:3,18,
14:3,5
48:15
189'7
associate
21 142:10
33:4,16
136:9
190:7
107:10
38:19
attention
47:20,22
archaic
assert
association
69:11
150:4
15:5
9:14,18
120:11,17
18
185:: 14
archives
64:21
92:2
10:15
attorney
22:19,22
12:23
attorney -
132:4,25
87:21
11:9 14:3
client
area
188:5
4
16:3,8
98:25
10:13,16
asserted
22
122::17
18:3 31:3
99:10
33:5 34:2
135:10
argue
92:1
assume
39:1
150:8
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
187:23
188:2,8
attorneys
8:15 9:3
14:20
17:20,22,
24 18:1,
6,10
24:12
31:2 46:4
51:16,18,
25 57:24
59:24
60:5
73:15,18,
20,23
74:17
87:19
89:5
91:11
94:24
99:3
115:4,7,
13,16
129:22
130:10
131:7,16,
21
135:17,18
137:16,25
138:2
140:10,
19,25
146:9,10
148:14
152:8,24
153:6,7
158:8
162:20
170:10
179:13
180:22
audience
4 5: 8
authentic
168:12
authenticat
e
49:14
62:8,14,
17 83:9
101:6
174:20
authenticit
y
101:8
authority
117:15
authoriza.ti
on
111:2
112:25
123:5,13
authorize
116:10
authorized
118:3
153:9
authorizing
113:9
Avenue
53:24
average
73:3
avoid
11:24,25
103:4
award
60:5
85:19
awards
60:19
140:2
aware
29:25
33:14
37:16
43:2
64:25
90:2
103:15
115:17
125:11
132:6
143:7
144:25
145:3
152:12
166:24
175:19,25
182:9
awareness
7:15 8:24
39:8,24
45:4
50:21
74:11
75:2,3
76:19
80:9
82:21
83:4
85:23
90:5,7,8,
13 111:18
116:8
157:2
158:10,12
awhile
76:3
ax
121:17
165:7
B
back
7:5 12:16
15:15
17:5
February 24, 2016
Index: attorneys.. Barnes
23:11
25:6 32:3
38:16
41:2 43:6
48:3
59:23
64:2
65:17,21,
23 69:3
78:1,13,
24 80:5
84:10
85:8,17
86:5
90:19,20
91:11
92:19
93:18,24
98:14
108:5
118:18
125:10
127:11
131:18
133:17,23
138:25
155:16,25
158:23
161:11
162:25
163:6
164:25
177:5,10
183:19
background
44:25
backing
125:6
132:18
Backtrack
74:16
bad
15:8
61:12
110:13
115:15
171:24
173:6
baffled
173:21
bag
46:15
bags
92:25
balance
70:24
bandwidth
73:6
75:6,8
bankruptcy
158:24
159:6
164:1,3,
6,7,8,17
165:11,13
bar
18:24
31:4,5
43:10
52:10
55:24
65:4
87:25
115:14
126:9
150:3
171:7
178:14
Barbara
25:23
27:16
29:3
30:19
31:24
52:23
138:24
Barnes
105:15
O ESQUIRE 800.211.DEPO (3376)
Esquire Solutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: Barrel..blood
106:2,4,
batting
130:18
big
12:20
13,18,24
65:21
144:22
90:19
bit
107:13,21
152:14
91:8
Bay
6:11 9:7
110:15,17
153:23
119:1,4
107:18
17:6 39:4
111:3
154:9
120:8
Beach
166:19
47:25
Barrel
biggest
48:8
26:8,9
177:17
32'9
119:9
65:19
30:25
178:12
Bartow
85:25
bill
95:9 98:1
behave
157:19
13:11
90:10
31:2,15,
11:23
179:19
36:1
133:20
16 38:16
141:14
behest
42:21
181:19
based
104:24
79:16
black
7:12
beat
42:11
155:3
behold
80:6,25
37:2
60:24
17:16
81:22
67:12
beauty
82:1
107:20
61:16
120:15
36:14
87:11
119:12
62:14
92:14
beef
beholder
88:2 89:8
121:8,13
99:16
100:5
39:19
104:22
131:23
113:23
152:19
42:12
105:12
172:14
173:16
bees
belief
108:4,18
blackjack
184:13
176:8
118: 7
17:6
58:19
119:4,5
basically
beg
believes
145:12
blanche
9:1 14:7
124:5
175:25
153:4
70:11
22:4 24:8
belonged
g
155:8
blanked
55:15
began
155:4,5
156:2
96:19
106:5
24:4
180:20
112:7
78:22
benefactor
182:20
blessing
130:17
begging
g4:14
28'1
50:7
132:8
29:16
Bill's
16
16
117:17
87:10
blew
149:21
begin
89:13
110:15
163:20
benefit
130:17
168:25
123:17
87:5
billable
179:19
151:2
104:24
58:11
blind
basis
beginning
benefitted
billables
40:7
33:15
96:18
136:25
128:10
block
45:5
100:13
129:13,14
42:11
59:22
124:15
benign
142:16
blocking
93:25
behalf
34:24
billing
39:14
96:25
23:20
Berger
97:4
59:21
166:25
128:16
blog
129:1,7
112:11
160:12
105:15
167:3,5
161:9
116:7
168:6
bills
130:22
battery
117:12,22
169:5
73:8
blood
122:12
123:12
187:6,16
birthday
120:1
ESQUIRE 800.211.DEPO (3376)
I 1.EsquireSol utions. corn
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: blow..button
122:2
163:12,14
bow
135:5
123:22
172:9,16
158:5
156:18,22
132:24
blow
137:3
173:4
boxed
184:8
bullying
185:3
188:20
155:6
188:18
blown
186:9,11,
189:1,2
16:12
13 188:15
boxes
bunch
broadcast
blue
190:4
111:24
31:19
45:14
33:3 40:3
98:8
Bob's
boy
Broadly
41:13
blunt
173:14
47:7
10:10
59:2,14
118:8
bonnets
breach
69:24
broke
154:15
58;19
158:13
94:19
66:16,18
186:7
book
Bread
133:22
106:16
blurring
105:15,
63:2
162:6
116:25
116:21
17,19
122:4
break
brother
129:5,20
board
106:7
5:25 6:1
45:14,15,
130:13
13:19,20
117:7
16:17
17 107:3,
136:17
14:7
119:15
18:21,25
11
139:1
17:1,4,
185:24
54:17
130:15,24
176:7,20
20,22,24
booked
100:22
18:9 21:2
143:3,5,8
138:11
brothers rs05:20
burdensome
70:21
174:7
185:12
books
79:19,23
brought
burn
105:18
breakfast
80:1,16,
92:24
190:6
106:6
26:4
19,22
150:14
29:12
burnish
81:18
bother
185:6
82:11
92:19
breaking
107:24
brutally
83:8 94:3
39:13
bun
bothered
118:8
104:7,14,
41:7 42:2
37:1
21:13
15,16,18,
182:25
Brenda
bucks
business
20 108:10
81:1,21
31:14
15:9
111:2
bottleneck
68:9
82.4
22;5,6,7
133:25
113:13
83:14,19
111:24
23:6,23
147:8
Boucher
93:23
buddies
68:3 89:4
171:6
86:1
104:15,20
70:9
90:11
Board's
112:4
155:17
budget
141:24
18:14
bought
briefly
67:11,16
179:8
boards
17:2
25:4
68:22
businesses
83:12
29:12
156:7
76:11
95:14
Bob
111:21,
bright
build
busy
24,25118:13
7:4 96:3
65:5
116:23
64:4
97:14
141:19
88.23
bullshit
button
102:24
174:4
bring
100:2
158:5,6
131:18
29:7 75:8
121:15
161:19,20
ESQUIRE 800.211.DEP0 (3376)
5 0 L U i 1 0 M 5 Esquire Solutions.com
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: buy..cases
buy
135:8
183:1
carbon-
carte
124:18
137:1
copied
70:11
call-in
168:14,15
138:15
103:25
45:12
cartoon
181:19
143:19,25
card
171:25
184:23
144:3,4,9
called
185:14
145:11
9:13
16:24
case
76:2,3,4
146:21
45:15
31:7
byproduct
143:12
147:22
48:5
61:6,16,
68:5
155:9,10
150:15
54:15
17,24
152:14
55:5,6
cards
68:10
C
154:20
63:2 85:9
90:12
71:18
159:2,3
129:21
185:24
73:11
cabal
160:10,24
130:4
care
74:14
173:18
161:5,13,
176:7
33:18
82:3 88:3
24 164:6,
190:17,18
34:3,5
98:6
CAFI
11 165:21
calling
35:25
105:14
50:22
166:1,15,
45:12
37:15
106:11,
76:20,22
19 167:14
19,22
190:4
44:24
77.2
170:11
47:15,19
107:15,
78:16,19
176:20,21
calla
19,22,25
61:6,7,9
79:3
177:6,11
77'5
110:16,17
80:19,23
179:25111:2,4
camel s
66:16
69:20,21,
83:21
CABINS
133:22
22,23
114:15,21
90:8,21,
115:2,23
2 2 91: 4
108:3
campaign
P 9'n
70:8
116.3
93:4 94:2
169:2
17:3
119:10
126:10,25
97:2,5,6,
calculation
44:17
122:4
128:19
10,12,16,
19:25
125:1 2
,
129:6
campus
164:16
19 98:6
calendar
105:17
172:16
150:21
102:5,12
83:25
106:2
154:1,3,6
103:1,3
career
161:10
104:4,5,
call
candid
34:5
166:20
11 111:2,
12:18
33:11
89:13
175:25
9 113:2
14:7
capacity
136:24
116:9,12,
25:23147:7
59:20
cases
13,15
39:16
73:6
19:12
Carney
20:11
117:12,
43:3
104:21
25:3
21:12
16,21,22
54:13,20
118:1,2
55:4
car
Carolina
24:22,23,
120:5,20
76:20
65:16,17
37:3
25 25:2,
123:5
126:2
66:5
3,4,8,11,
126:18
131:15
118:12,
carrier
16 33:10
128:15
136:9
13,15,16
152:15
52:6
155:2,3
154:12
53:20
130:18
154:2
132:7,8,
155:19,20
158:17
carriers
54:22
10,16,17
156:1
185:20
152:22
59:20
134:4,17
163:25
61:13
00 ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
68:11
71:13,19
72:2,4
74:2,8,
12,22
86:24
87:3
91:11
108:6,8,
13
109:11,25
113:12,
20,23
114:16,17
115:19,
20,21,22
126:13
129:2,8
135:8,9
136:12,
15,17
142:17
143:19
146:15,
22,25
147:17,
20,21
148:3,22
151:8
161:25
162:1
169:1,16
187:24
cash
76:2
151:20
catalog
22:16
catch
175:21
182:8
Cathy
85:18
90:24
112:5,23
113:21
cattle
154:2
caused
110:3
176:21
CD
22:24
CDS
22:24
cent
115:21
center
23:21
certainty
57:21,22
61:23
73:9
168:4
certified
72:23
86:14
100:14
certify
100:12
certitude
64:22
cetera
14:16
57:15
56:12
chain
190:25
challenge
148:19
challenging
149:1
chance
74:7
155:22
Chandler
4:11,16
5:7 27:5
50:18,19
91:21
92:19
97:1,23
98:11,16
100:20
101:5
109:10,11
111:1
160:16
166:16
167:11
174:16
change
134:1
165:7
175:7
changed
25:5 85:9
166:3,6
changing
93:20
Chantler
45:14,15,
17
Chapter
158:20,24
159:1
165:13
character
46:17
172:1
characteriz
e
96:1
charge
22:23
57:13
130:23
February 24, 2016
Index: cash..circumspect
charged
23:8 44:6
47:7
charges
143:12
charity
170:1
charming
67:7
159:22
chartered
141:12
chatted
48:7
65:18
168:14
183:2
cheap
39:9
cheaper
118:14
check
59:16
73:10
115:23
143:13,14
checkbook
70:24
checked
84:11
118:16
checks
16:5 76:1
144:10
chicken
63:11
chief
111:9
child
46:1,14
children
39:10
choice
170:1
174:22
choices
57:14
173:22
choose
98:4
chooses
98:18
Chris
173:15,
17,19,20
179:6,8,
14,17
180:7,9,
24
181:12,23
182:17
183:1,8,
11,14
188:5,9
Chris's
179:7
Christmas
66:6
church
45:16,19
churches
11:9
67:13
121:13
churn
128:25
circles
130:14
Circuit
176:12
circumspect
O ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: circumstance -collective
180:12
city
claims
clerk
clogged
circumstanc
29:23
92:1
19:20
128:6
40:15,25
160:13
143:13
e
close
74:4
41:1,3,
161:4
clicked
85:7
14,15
164:2
circumatanc
84:21
165:19
26:11
105:22
88:8
149:13
as
86:7
Clara
147:3
44:22
closed
civil
107:10,14
181:22
47:18
45:13
8:7,10,19
138:24
citation
9:4,11,
client
closer
54:3
107:21classes
15,25
6:11
106:1
58:15,21
citations
10:1,6,7
59:4,18
53:1,12
15:21,23
11:10
Clayton
87:16
closing
19:13
27:23
45:7
88:4
125:13
cities
34:4
clean
92:1,18
129:16
37:12,18
164:17
115:7,13
152:16
72.17
43:13,14
111:19
45:13
clear
135:9
178:15
123:2348
:3
26:19
137:22
clouds
124:24
55:25
29:11
138: 1
57:18
125:656:3
44:21
149:1
162:9
66:19
61:15
150: 9
Club
181:4
67:14
66:14
151:7
140:2
citizens
73:16
71:12
153:9
clue
86:2
76:17
154:17
23:11
7:15 8:23
159:10
28:11
88:10,25
81:25
167:20
cocaine
39:24
91:15
87:22
171:15
46:15
45:4
99.14
50:20
111:100
111:10,13
102:21
172:5
code
117:
108:1
178:17
22:15
57:3
116:3
185:17
95:4
74:11
121:77,, 10
191:8
75;2
125:1
120:3
coffee
76:19
136:24
124:12
clients
26:4
80:9
140:18
125:8
21:24
29:13
82:21
claim
126:9,25
59:2
95:17,19
83:4
133:24
135:9
159:25
91:25
134:2,16
85:23
92:14
135:11
climb
COINTELPRO
90:5,7,12
161:17
168:20
121:14
136:7
91:15
164:2,4,
137:13
clinical
Cole
111:13,18
5,6
116:8
156:23
126:1
4:17
136:25
claimed
162:13
148:24
colleague
157:2
143:11
169:18
Clinton
26:1
158:10,
161:16
178:10
153:5
180:10,
collective
12,21
claiming
154:4
163:5
159:3.4
13,18
73:20
ESQUIRE11
800.211.DEPO (3376)
Esquire Solutions. corn
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
college
105:15
106:7
commenting
64:3
Commerce
30:21
89:9,11,
21 90:1,
14 116:6,
17 120:7
Commercial
22:15
commerciall
y
142:12
commissions
rs
40:16
41:1,4,
14,16
commitment
67:3
committed
161:13
committing
117:25
common
23:18
46:5
71:20
130:13
communicate
d
27:17
29:3
47:25
87:2
communicati
ons
17:19
62:9
132:7,10
151:25
153:2,22
154:21,24
180:10
187:2,15,
20,21
188:7,8
companies
16:24,25
company
23:3,4
30:22
comparing
101:6
comparison
27:11
49:19
73:23
compel
186:23
compensable
60:11
162:18
compensated
8:17 9:8,
16 28:9
compensatio
n
9:21
29:14
51:21
52:6
competence
89:18
competitor
106:1,3
competitors
22:4
competitors
9
22:2
complaint
131:14
160:14
166:15,16
173:17
complaints
113:12,14
114:2
139:11
144:16,22
173:11
completely
74:13
89:21
96:8
109:17
119:24
173:15
complex
25:13
compliance
53:11
58:25
124:2
compliment
79:11
comply
130:24
complying
163:6,8
composite
82:16,19
83:6
184:3
compound
139:12
compromise
93:16
computer
186:18
February 24, 2016
Index: college -confirmed
189:15,19
concentrate
146:20
concentrati
ng
53:6
94:11,21
concept
14:11
conception
58:10
concern
71:6
147:9
concerned
12:5
70:15
71:1 75:6
81:16
89:1
114:11
116:21
126:12
147:5,6
158:22
concerns
71:24
87:16
88:18
145:10,
11,15,19
146:1,3,
11 147:15
conclusion
150:14
conclusions
123:3
concrete
68:22
77:12
169:4
condescendi
ng
36:22
118:19
condition
35:11
72:14
73:25
74:3,15
conditions
39:25
69:19
72:12
115:17
153:10
conduct
11:13
conference
31:22
154:1,7
156:1
confidence
62:18
148:16
confident
15:14
26:23
38:10
53:13
61:6,11
62:22
113:22
124:24
161:9
172:10
confidentia
1
41:11,23
42:8
confirm
133:16
confirmed
133:19
ESQUIRE800.211. Esquire oEPons.com)
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: confirming -convinced
confirming
constitutio
contacts
40:22
163:18
91:17
nally
51:19
53:11
conversatio
confiscator
39:16
contemplati
93:12,14
n
y
consult
ng
126:23
26:11,22
23:21
20:15
33:6
130:3
36:19
106:14
28:20
187:24
158:13
51:8,14
156:11
31:1
contracted
53:23,,25
contemporan
conformity
consultativ
eously
8:9,13,24
54:5,11
126:17
a
7:19,23
contractor
55:3,22
53:16
77:6
22:14
56:1,4
conforms
61:19
83:13
consulted
contending126:23
66:1 69:3
connection
80:7
117:24
contractors
79:15
81:19
consulting
contention
53:6
93:10
184:23
8:15 9:3
104:9,10
contracts
96:1,2,6
21:22
53:7
97:23
connections
context
102:9,23
184:22
23:6,23
36:4
contributio
103:21
24:B
connotation
60:25
37:13
n
107:9
157:13
61:4
64:19
44:17
130:11
94:15
170:1
133:15
consent
115:4
118:11
control
163:16
148:2
contact
151:3
57:12
168:19
1
28:23
contingency
91:22
coaversatio
considerati
29:6,7
59:9,21
98:16
35:8 89:2
ns
on
60:21
113:18
40:16
36:15
99:5
73:8,11
117:15,
51:11,25
consistent
149:14
161:20
126:10
16,21
52:3
34:4
180:3
153:17,18
161:13
61:21
conspiracy
continue
177:5
72:7 77:6
contacted
66:17
controlled
88:24
18:1
8:15
69:6,7
58:22
93:8 94:6
constantly
20:14
104:9
104:5,11,
95:19,22,
71:17
23:7 26:1
108:12
13
23 96:13
coneternati
28:5,11,
15,19
109:15
controlling
g
103:18
142:15
30:20,23
132:2
114:22
159:13
110:3
35:10
135:23
controls
163:17
constituent
57:2 96:3
177:11
188:1,3
e
125:22
continued
18:20
130:1
65:14
conundrum
conversely
162:10
161:19,20
continues
163:10
70:7
constitutio
171:17
191:12
convenient
conviction
nal
179:4
94:21
18:14
Contract
10:10,11
contacting
26:14
95:3
convinced
130:8
105:22
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800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: convincing -credence
47:10
corporation
coats
28:18
cover
54:8
23:7 83:5
58:11
40:12
31:9 66:5
96:16
59:22
45:20
68:23
convincing
142:6
corporation
68:9
84:22
70:25
115:21
87:7
s
covered
cool
128:19
121:12
81:12
179:18
29:5
131:7,21
122:9
82.21
183:13
108:2
153:7
160:16
135:2
correct
162:17,25
Cowhart
couple
160:5,6
20:4
45:7
couch
9:12,23
cooperative
21:6,8
153:4
11:17
coworker
44:23
186:4
14:19
84:14
56:19
Council
188:14,
21:21
120:12
59:7
8:21
15,16,17
74:16
75:19
34:10
coy
coordinate
80:20
81:21
67:7
12:19
82:24
counsel
134:25
18:15
140:16
crack
coordinatin
86:21
19:4,17
159:6
46:15
g
98:11
20:15
166:6
c ra p
163:15
110:24
21:7
court
122:5
coordinatio
139:23
24:11,16
4:1,5,9
185:15
n
143:20
25:9
5:12,20
189:2
13:1
89:9,12
16:6 20:1
Corrections
99:20,22
crazy
copies
112:17
147:17,24
47:16
80:8
18:6130:4
152:1
58:16
81:17
185:6
153:3
60:19
create
correctly
68:2
copy
144:20
154:15
78:15
7'12
18:5
165:24
corroborate
100:2
created
21:18,23
d
count
106:20
7:6,17,22
22:7
157:20
19:24
107:21
49:17,20
49:10
185:1
119:13
56:14
93:24
corrupt
counties
127:18
79:18
166:15
119:24
128:4
80:13
184:21
72:18
coat
162:15
87:13
cordial
18:5
county
164:1,6
104:5
26:11
22:23
9:20
176:1,14
127:14
27:15
31:9
11:5,17
186:8
41:2,4
13:11,19
creates
14:18
courthouse
153:15
72:
1 10
172:1,
42:411
53:17
177:13
16:21
73:12
corner
87:18
17:17
courts
creation
46:16
147:9
18:14
19:20
63:8
corporate
149:7
19:20,21
36:5
credence
83:4
169:19
20:25
128:5
51:10
130:7.8
21:2
160:8
ESQUIRE 800.211.DEPO (3376)
6 0 1 U T 10 N 5 Esquire Solutions.com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: credit..Deerfield
credit
13:10
Daniel
94:4
decide
16:24
35:24
165:24
118:15
57:25
18'9
187:11
129:4
curious
decided
76:2,3
14:9,13
Danielle
137:25
13:10
109:22
171:19
187:8,9,
142:9
17:7
143:12
143:16
10
16:25
155:9,10
current
181:21
169:18
6:4
dark
21'22
day-to-day
105:23
95:19
creditors
curse
89:20
132:23
158:23
50:7
data
165:15
deciding
159:3
custodian
168:2
days
148:6
164:10,12
36:5
184:22
165:13
19:19
decision
custodydatabase
41:17
cried
190:25
22:3
65:22
601:16
47:12
date
69:12
68:4
Crime
cut
83:11
72: 8
108:3
12:11
108:1,14
90:24
129: 25
135:15
-
101:16,17
142:7
137:21
criminal
D
108:24
169:21
176:18
18:1,13,
--- - -
168:21
189:3
15 46:8
decisions
172:25
Daddy
dates
DCA
40:19
177:19
119:1,2,5
186:1
106:18
57:13
178:4,24
daily
daughter
deal
72:1
critical
57:2
33:22
28:4,22
114:20
106:9
damn
43:21
70:10
115:14
44:6,8,
124:16,19
149:2
criticism
39:8
11,20
165:22
150:10
88:17
Dan
47:19
169:15
deed
critique
78:3,25
dealers
87:2
87:3
82:20
Dave
21:23
133:3
34:1
deem
cruelty
134:11
43:3,24
dealing
103:12
34:17
166:4,8
day
29'9
deep
p
crystal
171:3
15:9 32:3
148:10
162:13
174:19
41:14
103:5
184:16,18
42:15,18,
183:8
deeply
cultivating
125:17
185:4,18,
21 47:16
dealings
51:24
20 187:2,
57:12
179:1,3
147:5
culture
8 188:16
58:16
Deerfield
94:25debate
64:2
30:25
Dan's
137:18
cup
185:19
80:12,13
142:11
85:25
76:4
187:9
83:22,23
150:17
90:10
159:25
84:4,8
133:20
dangers g
85:8,15,
December
141:14
curiosity
38:3
25 86:4,5
164:18
142:8
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: defend..destroy
defend
definitivel
131:25
depending
Desouza
20:17
y
136:5
39:11
4:19
122:7
26:18
178:17
40:9
5:13,19
defendant
121:5
186:11
depends
6:9,15,19
106:19
defrauding
demands
153:5
10:4,9
128:21
153:20
14:14
27:2 35:5
deposed
39:3
130:7,8
degree
de g
167:15
5:10
54:16
131:3
47:8
demonstrate
deposition
61:2
defendant's
138:3
d
64:16
4:1 6:22
49:8
deleterious
100:1
159:7
77:15,19,
82:17
70:5
demurred
183:3,20
23 78:4,
100:16
93:13,14
184:5
11 79:2
166:12
deliberate
81:6
174:12
15:1
denied
186:5
82:23,25
183:25
18:21
92:13
191:12
91:17,20
defendants
deliberatel
Denise
depraved
92;12
127:21
y
80:25
76:10
96:17,25
158:9
16:17
81:20
depravity
97:11,17
170:16
delicious
82:3
76:10
98:1,12
83:15
100:18
defended
42:22
104:22
depths
102:7,14
47:15
delighted
105:3
67.2
109:1,7
defenders
9:6 77:13
108:18
deputies
132:2
46:5,7
176:10
113:11
11:8
133:2,5
defending
delightful
118:7,19
121:13
139:17,21
46:14
32:16
135:2,11
describe
152:25
162:3
159:25
136: 3
11:23
159:9
145:12
12:
12:10
165:24 �
defense
Delray
146:7
166:18,
16:7,9,10
32:18
156:2
25:25
22,25
47:13
42:20
157:21,23
describing
167:3,8
71:15
63:1,16
178:13
40:8
170:21,24
92:10
179:7
45:25
171:4,8,
161:23
denominator
132:11
11 175:21 i
demand
46:5,
defer
13:20
description
1
99:7
126:5,7
Department
s
18844::11 6
20:18
171:20
187:2,8,
definite
demanded
112:17
9,10,11
40:14
13:21
122:10
deserve
188:16
definition
118:7
130:3,4
48:20,21
Desouza's
156:11
162:5
50:6 51;5
28:14
99:16
153:5
demanding
depend
desk
160:11
115:17
153:3
14:9 91:6
desperately
117:6
120:9,10
24:7
definitive
129:11
dependants
143:13
destroy
25:7
15:17
ESQUIRoE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: detail -discussions
121:8
157:4
112:4,5
disappoints
27:14
detail
differently
117:22
d
44:19
152:17,18
172:11
137:10,16
71:12
96:23
157:10
145:23
168:16
102:25
difficult
173:3
103:23
detailed
95:14
directed
104:6
disaster
discusses
49:19
difficulty
116:14
27:24
102:1
details
63:2
directing
disastrous
discussing
33:24,25
138:10
43:17
150:12
71:2
66:8
54:21
44:7,19
105:4
70:6,16
135:8
dignity
113:5
139:20
157:4,7
discerning
11:3
116:6
151:6,9
determining
dilemma
135:12
114:19
167:24
112:19
177:11
137:6,8
dischargabl
discussion
113:5
146:8,10
e
114:23
Dimartini
164:3
26:25
81:1
direction
27:10
develop
104:24
discharged
29;21
83:15
111:20
104:22
directly
164:19,20
40:23
developed
105:3
75;4
165:11
43:22
112:6
108:18
92:7,10
disclose
50:2,25
developing
135:2
130:9
13:22
55:17
136:3
169:19
14:15
64:6,19
142:4
145:12
69:5,18
devil's
146:8
director
disclosed
77:12
148:21
156:2
97:6,15
132:8
96:6
dichotomy
178:13
104:7
disclosure
107:13
126:18
15:18
140:24
161:15
Dimartini's
130:2
174:5
147:23
dick
83:16
134:4
148:2
119:9
dinner
directors
discovering
179:14
127:23
32:17
70:21
122:8
discussions
159:17
42:17,20
80:19,22
discovery
26:20,23
dicking
43:6 48:6
82:11
46:7
52:17
164:22
63:14
83:8,12,
discretion
55:14
189:4
64:7
15
70:20
56:17
dictates
65:11,14,
disagree
72:3
74:10
15 84:18
92:13
76:22
37:14
130:16
discuss
78:16
difference
168:15
173:13,15
31:1
79:14
33:18dipahit
disagreemen
50:20
81:25
142:3
46:13
t
51:1
94:1,2
190:20,22
34:1
148:7,22
102:2,5,
direct
113:10
182:16
11 137:5
differences
4:14
188:22
148:11
14:18
138:18
discussed
147:16
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
154:21
165:23
168:17
178:22
187:22
disheveled
64:1
dishonestly
124:9
disinterest
ed
45:3
dismiss
37:8
dismissal
153:14
176:11
dismissed
150:21
158:24
161:10
175:20
176:1
disparity
36:16
dispassiona
to
126:1
147:23
148:24
disposed
56:2
disposing
169:24
dispute
126:8
127:1
132:14
disputed
143:12
disputing
101:19
distant
59:16
distinction
35:6,8
district
16:22
17:8,14
122:10
Division
82:20
divorce
188:10
document
49:13
83:10
101:3,21
167:15
190:8
documented
46:23
documenting
125:21
documents
7:21,22
11:12
31:22
47:9
75:15,17
83:2,3,5
131:18
157:20
161:18
167:1,4,
8,11,16,
19,24
184:7,8,
20 185:2
186:12,17
dog
140:21
dogs
37:18
dollars
16:5
23:1,9
124:17
151:20
159:4,5
170:3
Donuts
53:25
door
86:11
double
17:7
doubt
76:11
148:15
downstairs
95:17
downtown
168:9
dozen
19:5
24:25
draft
52:13
93:17
135:13
139:10
157:21
drafted
166:8
dragging
100:2
dramatic
53:4
draw
123:2
drink
February 24, 2016
Index: disheveled..e-mail
95:19
drinks
168:8,13,
15
drive
84:12
94:24
142:12,13
155:5
185:6,14
189:10,
14,21
driving
118:18
189:6
dropped
46:15
drove
26:8
42:22
118:11,16
133:20
142:9
155:3
drug
131:24
drum
134:18,19
DU
33:23
dually
132:21
133:10
duces
187:17
dude
190:12
due
127:20
132:19
152:22
DUI
44:6
duke
58:9
duly
4:12
dump
185:5
189:2
Dunkin'
53:25
duplicative
184:15
185:12
dust
183:13
duty
158:14
Dylan
86:1
112:4,23
113:21
E
e-
133:14
e-mail
15:20
18:13
25:23
27:17
41:1,15
48:13,16,
18,23
49:24
50:3,4,8,
9,16,25
51:3
61:22
77:5
103:25
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
108:4
109:19
114:1
117:11
123:1
131:19
133:17
156:10,
13,14,16
157:25
158:6
163:25
171:18
184:12,
14,16
188:10,13
190:3,4
e-mails
7:2,8,14,
16,18
11:12
40:25
41:5,13
48:15
62:16
109:10
135:3
157:21
158:2
161:21
187:6
eager
87:5
earlier
25:22
28:16
55:18
57:1
114:11
131:19
144:20
146:12
164:13
181:2
early
26:17
29:25
31:25
43:8,16
48:12
4 9: 24
58:14
59:14,18
95:12
104:19
116:21
137:8
140:15,23
179:24,25
earned
151:3,4
earnest
27:20
56:3
earth
165:3
ease
147:14
easier
7:25
easy
57:11
119:25
163:22
169:25
eaten
9:23 32:8
economic
10:12
20:18
27:24
66:12,14
162:5,11,
22
economicall
y
16:2 66:8
169:17
Edgar
12 1: 15
editorials
12:24
Editors
12:23
education
53:14,17
educational
15:5
19:15
Edward
5:7
100:19
160:16
effect
48:19
50:5,7,12
54:4
131:20
165:14
effective
155:12,13
effectively
66:24
87:18
efficient
40:19
effort
10:24
23:22
127:22
143:10
efforts
94:11
ego
167:6
egregious
71:21
February 24, 2016
Index: e-mails..enormously
86:15
94:14
126:25
elephant
40:8,10
elevated
120:2
Eleventh
176:12
Elliston
84:10
else's
141:2
employed
7:15,19,
20 8:1
60:1
139:20
employees
15:17
81:11
91:3
112:22
116:6,12
employment
39:25
93:3,8,25
139:18
empty
14:1
91:6,8,9
encounters
94:17
encourage
128:5
end
27:4
38:14
44:12
45:11
57:12
60:18
111:21
136:10,16
137:19,25
191:11
ended
14:1 17:5
23:14
41:6,11
46:21
47:3
48:24
75:9
87:19
142:25
ends
59:9
165:2
enemies
40:1
69:19
enforcement
11:19
12:2
44:13
119:11
engage
71:4
engaged
18:1
39:13
engagement
125:16
126:7,10
150:6
178:15
engaging
178:16
enormous
66:22
186:17
enormously
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
67:8
136:22,25
185:12
enrollment
15:16
entailed
154:25
enter
7:9 40:21
93:3
entire
92:13
entities
23:18
53:2
112:20
116:10
entitled
18:12
41:21
122:5
127:19,20
150:20,
21,22,24
153:12,13
154:12,
16,17
162:20
188:19
entitlement
6
154:18
178:18,19
entity
15:3 39:1
56:18
76:25
78:17
97:19
102:6,13
entity's
152:15
envelope
155:9
epiplectic
115:6
equality
11:1
equipment
21:23
22:5
equivalent
36:25
er
163:23
Eric
25:1
essentially
21:25
33:8
111:11
112:5
establish
97:7
established
60:3
162:18
establishme
nt
11:4
36:17
119:20,23
164:13
173:4,5,6
establishme
nt's
173:10
estimate
21:9
136:12
ethical
128:2
146:3
149:3
150:9
151:1
177:13
ethics
134:7
147:5
ethnic
94:25
euphemistic
ally
35:9
evening
42:19
43:8
84:15
event
29:12
events
7:23
eventually
19:14
74:13
176:21
181:11
everybody's
133:10
185:21
evidence
178:10
exact
16:9
17:2,8
81:12
90:24
92:14
106:17
149:24
168:21
176:4
examination
4:14 7:3
February 24, 2016
Index: enrollment -expected
49:7
132:24
175:12,
18,24
examination
e
159:6
examined
4:12
examples
28:16
60:4
94:13,18
excellent
141:22
exception
11:3
exceptional
59:17
149:14
excess
126:20
exchange
136:1
156:16
exchanged
48:15
62:16
exchanges
77:5
excited
52:8,16
excluded
148:12
exclusive
55:16
excused
43:8
execute
101:16
executed
93:21
101:15
103:7
125:15
151:11
executing
101:13
executive
111:9
126:17
130:2
134:4
exempt
41:10,23
42:7
86:10
exemption
15:25
exercise
11:11
121:11,22
exhibit
49:5,6,8
50:16
62:4,15
82:16,17,
19 83:7
100:15,
16,25
101:24
108:23
166:11,12
174:11,
12,15
183:24,25
184:3,4
exist
18:4
expectation
60:21
expected
65:8
ESQUI 10E EsquireSo�os.com)
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
expecting
171:20
expedition
132:24
expense
66:8
124:17
186:17
expenses
66:6
68:23
70:25
179:18
expensive
169:15
experience
10:19
14:22
16:15
18:17
44:12
52:8,25
59:8
67:23
72:16
87:6,8,9,
10,14
88:14,22
151:23
160:6,7
173:19
experienced
22:12
119:22
experiences
11:21
17:13
24:2
27:10,12
179:16
expert
162:17
expertise
10:16
12:15
explained
119:17
explicit
112:25
explicitly
53:7
126:23
expose
11:13
112:13
exposure
141:24
express
145:11,22
expressed
26:5
107:14
146:1
extension
91:7
extent
147:2,13
160:3
extra
128:22
extraordina
rily
22:6
123:19
141:18
188:14
extricated
169:14
eye
16:15
17:12
18:17
3 9: 19
42:12
eyes
183:13
F
fable
40:7
face
48:7 98:9
172:8
faced
60:14
faces
137:3
fact
9:7 16:25
19:9
22:11
48:22
53:23
57:6
64:12
69:8
70:22
74:4 77:2
78:20
86:6
92:10,11
93:9 95:5
101:19
107:17
111:17
115:2,3
123:8,20
126:20
129:10
133:19
137:25
143:22
146:7,11
152:21,24
154:15
175:7
February 24, 2016
Index: expecting -fee
183:13
facts
33:10,14,
21 44:22
45:4
61:6,9,
12,14
71:22
107:20,22
113:19,24
114:8,18
126:24
127:1
136:14
162:2,3
faculty
106:6
fair
36:20
4 7: 16
60:16
64:15
121:2
172:2
fairly
11:3,5
28:18
43:21
44:9,11
45:5
47:20
156:3
fairness
64:17
131:6
fall
42:3
fallacy
173:9
false
160:13
familiar
4 9: 15
60:4
101:7,22
174:16
family
95:5
172:13
farm
39:5,10
farther
78:24
119:23
fast
6:6
118:22
father
12:21
favor
20:1,2
58:3
favorably
56:2
fax
116:17
123:1
February
15:10
102:22
103:17
108:24
109:5,19
136:9
federal
10:10
176:1,12
fee
20:19,20
59:6,24
60:24
106:14
125:15
126:5,6
153:18
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: feed..firm
162:7,16
84:9
124:7
182:1
129:19
182:21
felt
126'22
filin s
182:5
152:1
188:25
feed
43:20
82:21
31:11
66:6 69:8
165:18
finding
168:4
filled
39:10
87:20
190:7
176:14
121:25
134:18
88:13
fine
89:6
filed
final
feel
5:9,17
113:13
19:4,17,
149:2
5:3 39:18
6:9,16
44:10
175:20
21 20:24
finalized
28:10
57:4 88:4
178:23
21:4
69:16
58:5
24:10,1452:12
149:18
Ferguson
finally
70'22
162:8
12:4
16:6 42:5
79:4 80:7
53:20
165:5
99'21
168:12
feud
87:12
finance
100:6
122:2
113:17,20
73:24
102:16
feeling
fiction
114:10
financed
118:14
44:8
166:17
123:6
74:5,18,
134:13
feelings
fiduciary
126:14
19 104:14
141:18
155:24
143:22,24
158:14189:20
144:1,4,
finances
feels
fight
16,22,23,
70:23
190:2
99'1
119:20
25 145:3,
116:24
finger
fees
5 146:15,
144:14
17:9
figure
17
72:19
16:4 17:5
47:12
158:13,
financial
163:5
20:21
67:5 80:1
16:24
23:15,21
20,25
75:23
fingers
g
59:24
figured
160:24
97:20
124:7
60:5,6,
20:7
161:1,3,
10,12,13
21:14
24 164:18
financially
finish
68:3,8
118:14
166:1
158:15
5:15,16
73:12
142:14
175:19
financing
99:20
75:4
152:4
176:5
68:4
174:18
87:19
157:6
180:25
74:21
186:14,
126:8,20
181:16
files
75:12,19,
15,25
190:14
131:7,22
figureheads
123:13
20 76:18
134:9,19fire
g2;g
167:23
144:6,11
185:1
find
152:10
151:3
figuring
12:14
152:24
77:8
filing
19:15
firm
68:8
60:1 91:8
4:17 19:6
153:6,733:6
fila
73:12
94:13,16
24:21,23
156:11
19:15,23
75:3
107:1
54:22,23,
162:20
33:13
83:11
114:5
24 55:1,
feet
52:11
113:7,8,
119:21
16 56:11,
46:16
60:22
12 123:4
121:11
14 57:7
fellow
113:6,23
144:6,11
122:14
58:18
123:23,25
59:6,22
�� ESQUIRE 800.211.DEPO (3376)
6 0 1 Y• 1 0 X 6 EsquireSolutions.com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: firms -foundation
72:3,11
24:12,16
floated
189:7
61:2
74:1,13
57:6,8
77:9
64:16
flourishing
75:5,13,
59:5 72:4
81:6
Florida
115:9
19,21,24
73:5,6
106:5
4:3 6:5
76:19
75:7 89:2
flow
152:25
12:17,23
86:18,20,
103:3
109:14
177:8
13:2
22 87:9,
105:8,11
132:3
17.21
formal
23,24
firsthand
18:24
fly
139:11
88:7,14
119:22
19:9,12
142:12
89:3
formed
90:15,20
fishing
22:15,16
flying
56:11
105:8
132:24
25'2'24
44:15
76:23
26:3 28:8
107:19,2577:2
fit
30:6,9,12
focused
108:6,8,
73:21
31:5
182:20
78:16,20
13
110:14
34:14
79:3 94:5
109:12,25
149:4
48:1forming
Fog
110:2
130:21
114:6
five-minute
55:11
51:1,4
63:15
folks
116:4,25
100:22
46:3
forme
123:4,9
five-year
64:13,1
129:21
106:8,22
21 65:2,,
125:11
93:125,10
142:5
fortunate
128:17
fix
67:13
187:13
19:6
129:15
127:12
73:18,22
follow
61:13
131:5,16
132:1
130:20
82;2,6,20
18:19
forward
133:13
131:4
84:11,21
98:18,19
110:21
134:19
163:7
86:7 87:6
food
183:6
135:7
182:23,25
90:9
9'22
found
94:12,21,
136:14,
fixed
66:10
15:2
25 105:16
16,23
121:19
106:11
95'1
30:10
137:5
fixing
111:23
foolishly
33:20
138:10
116:1
119:9
14:2
34:6
139:8,14
46:22
140:9,11,
flake
123:22
for-profit
112:10
125:5
25
115:12
23:4
114:14
126:9
141:10,23
flesh
128:4
forceful
115:16
143:18
58:8
134:8
88:18
116:5
144:8
136:25
118:5
146:7,21
flew
forego
129:10
149:4,22
140:11
137:11
127:17
152:13
141:11,12
140:4,7
foundation
142:2
Forest
7:16 8:24
158:3
143:2
6:5
171:12
168:8
162'9
13:2
177:12
185:20
163:5
forklift
25:25
171:1,7
183:14
35:2
firms
flip
181:3,9
39:24
8:16
110:21
182:6
form
45:5
39:3 51:1
ESQUIRE
800.211.DEPO (3376)
Esquire Solutions. corn
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
50:21
fraction
26:1 86:2
51:2,4
53:20
friendly
63:8,9
frankly
26:11
65:25
66:2
17:6
friends
25:13
70:6,16,
137:24
33:17
17 74:11
183:6
38:21
75:2,3,
44:24
frightening
12,23,25
56:25
13:15
76:3,19
77:9 80:9
82:7
front
82'22
108:1
14:9 39:6
83:4
142:16
159:8,9
84:14,17
170:17
188:12
85:3,5,6,
173:3
189:7
22,23
fraud
fruitful
87:13,22
117:25
136:24
90:5,13,
123:1
25 94:5
161:13
frustrate
105:12
164:4
23:20,22
107:24
177:15
frustrated
108:9,14
fraudulent
24:3
111:23
153:8
28:12
116:8
117:8
fraudulentl
frustration
122:16,
y
127:23
23,24,25
124:9
fuck
123:12,13
freak
100:1
124:10,13
113:18
119:14,21
128:23
124:25
140:1,5,
free
125:4
17 141:5,
5:3 9:12
137:20
7,17,21
66:7'22
145:23
144:13,23
81'4
149:25
146:6,7,
112:2
164:13
16 155:6,
162:8
168:23
9 157:3
frequently
168:11,19
158:10,12
10:20
189:15
169:12,23
35:8,12,
190:11
170:2
16 179:12
fucked
177:17
fresh
121:18
179:6
80:4
123:3
foundation'
186:7,11
Friday
s
133:20
fucker
76:15
119:14
friend
ESQUIRE
February 24, 2016
Index: foundation's..gee
fucking 177:25
118:5,6,
9,21
137:22
172:14
184:19
185:5,21
190:12
full
24:18
42:18
58:4
69:11
79:5,6
174:5
185:6
189:2
fully
118:17
127:8
fun
105:22
181:24
function
56:23
fund
66:21
67:5
110:5
fundamental
37:12
115:24
124:22
funding
84:16
funds
74:25
75:1
108:13
109:16
funny
130:12
159:22
G
gaining
96:7
Gale
14:17
game
38:14
gas
158:18,19
gate
108:2
gather
41:22
gathered
158:3
gave
7:4 13:17
17:9
51:10
52:1
54:10,25
79:3
86:24
93:22,23
98:14
112:1
127:8
143:14
161:19
163:12
167:5,13
175:2
179:19
185:4
gee
18:22
81:17
156:3
800.211.DEP0 (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: gender -governor
gender
134:9
12,20
24
157:6
11:1
Giovanni
180:15,16
102:10,18
160:18
general
140:19
183:1
109:3,9
172:13
18:14
145:13,
190:16
134:11,15
176:13,18
26:19,23
20,25
giving
138:12,14
181:25
34:25
146:1
41:20
139:19,23
187:14
44:5 52:3
147:2
87:21
141:4
190:2
149:15,18
86:21
166:10,14
gotoha
generally
167:10,18
10:3,11
gist
110:2
171:3,14
124:4
11:4
51:6
117:17
174:10,14
government
26:13
168:19
163:5
175:23
11:15,22
27:23
180:22
183:23
12:21,25
37:13
give
185:8
184:2
14:12
4:6 14:8
188:11,15
43:12
16:11
189:9,24
15:3 19:9
56:1,3
17:25
gleaned
190:21
20:6
141:1
18:12
13:16
191:6,10
26:5,13,
generated
24:18
gobs
golfing
20,2427;1,20,
136:12
33:10
31:21
70:9
40:6
39:21,22
21,23
generates
golly
28:6,15
44:25
Goldstein
18:22
30:9 31:1
1 :6 10
110:
4:15,17,
36:20
46:10
good g
generous
4
47:13
21,22
16
37:13
66:4
66:5
6:13,17,
16:18
16:1
52:18
20 7:10
55:25
gentleman
70'24
10:6
32:10,14
56:5,9,23
19:11
72:2,4,
27:7,8
63:11
58:7
130:1,6,
10,19
49:4,12
70:2
67:22
12 140:20
74:1,12
54:19
74:15,
73:16,21
77:25
721
74:7 8:4
genuinely
89:4
61:18
79:22
76:8
159:2196:14
64:24
80:4
82:2,6
181:23
99:24
78:10,25
85:7,12,
88:11
get all
107:19
79:7
13 87:15,
95:20
60:14
107:4,16
138:2
109:25
81:7
21 88:4,
111:11,22
095:9
giant
82:15,19,19
134:8
112:11
89:6
167:6
122:2,5
24 83:1
110:13
140:4,15,
91:19
17 141:1
gig
124:5,6,
114:7
24:8
17,25
92.7
115:13
149:1,15
93:1,2
179:11
129.2
123:20
GILL
96:21
180:21
137:20
130:25
138:11
97.9,15,
181:17,24
141:16
142:5
22 98:10,
gin
155:19
21 99:14,
149:4,11
governor
134:6
157:10
150:5
70:9,10
21 100:6,
169:11,
151:16
119:10
ginning
11,15,19,
ESQUIRE
800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: Governor's.. happen
Governor's
Greg
92:18
65:5
153:9
140:2
19:10
95:15
73:10
155:7
138:23
132:19
74:25
174:17,18
Governors
171:7
151:18
169:11
84:9
hand -in -
gregarious
180:1,5
85:25
hand
gracious
95:10
guessing
88:19
14:11
95:15247
grid
32:21,22
97:13
handed
graciously
121:17
181:14
116:23
14:1
85:16
Grier
guest
130:25
49:20
170:16,
45e9
131:23
155:8
graduate52.9
23,24
guilty
159:16,
handing
171:4,8
47:6,10,
22'25
149:21
105:25
167:6
graduates
grind
14
169:5
handle
52:15
165:7
Gulf
171:21,25
54:23
ground
30:1,5
173:6
88:12
grand
53:2
139:9
69:16
190:7
87:12,15
guys
18:23
handling
_
grant
group
88:3
60:7 74:4
150:13
30:21
89:15
166:19
57
89:9,11,
92:2
77:15
157:8
1 :
21 90:1,
117:12
92:24
hands
Gray
14 116:6,
120:23,
100:21
11:5
171:2,3,8
17 120:7
24,25
182:16
146:19
great
149:15
121:1,3,
184:18
190:19
25:14
17:15,23
17,23,25
185:19
handwriting
98:24
1766:20
122:18
186:20
135:13
114:17
groups
123:7,10,
187:7
14
189:5
hang
115:7
67:15
136:7
91:15,16
124:10,20
guys'
56:1
138:10
111:13,14
126:15
184:24
172:7
147:13
145:6,8
hang-up
149:23
guess
157:17
_
69:5
150:12
10:16
161:25
H
156:18,22
15:11
178:6
hanging
176:10
20:6 27:1
181:1
hair
138:4
28:1
182:2,10
124:4
159:24
greatest
32:23
169:2
148:15
33:6 34:1
guy
half
173:21
38:23
22:22
96:19
greedy
24:22
Hanna
129:4
39:19
hallway
140:24
43:2
25:1 26:2
155:17
145:14,
Greensboro
44:22
27:19
37:3
56:16
31:17
hand
20,25
46:24
58:6
187:21
greeted
63:1 73:2
85:11
47:3 64:1
86:10
happen
120:7
106:12
ESQUIRE 800.211.DEPO (3376)
5 0 L U. 1 0 N s Esquire Solutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: happened.. hostile
36:3,11
harassed
heard
190:5,18
Holiday
137:14
39:18
16:13
hiccups
26:9
156:8,17
harassing
17:21
164:17
home
188:20
30:1,2
42:1
77:16,23
hid
42:22,25
happened
164:22
48:9 84:8
78:2 92:5
186:3
71:2
harassment
110:12
90:8
97:24
hide
118:18
102:9
39:17,19
133:9
185:25
158:20
105:21
42:9,10,
143:11
186:4
12
172:17,
honest
107:13
hard
18,19,20
high
122:20,21
115:2
52:25
137:15
18:4 20:7
hearing
Honor
123:19
156:4
71:21
20:19,20
131:11
16:8,10
160:23
94:13
126:5,6
hook
180:19
97:17
153:25
highlight
155:4,24
162:7,16
32:5
59:13
happening
183:22
hoops
122:14
held
Hillsboroug
185:6,14
h
106:16
124:8
106:20
126:12
189:10,
53:24
Hoover
13,20
hell
122:9
121:15
happy
16:15
6:1 29:8
hassle
115:6
hire
hope
31:11
114:3
124:18
68:25
48:19
34:13
hate
131:23
84:14
50:5 51:5
47:22
27:2
185:10
162:17
92:24
48:18110:5
Haven
helped
hired
49:25
45:6
12:12
16:3 19:7
121:18,19
50:5 51:4
84:13
35:22
23:3
hoping
58.2
85:9
46:20
85:18
156:7
66:17
86:1
99:7,12
head
helpful
134:24
hopped
100:10
5:20 8:18
45:2
179:10
82.7
119:13
24:19
78:14
180:20
horns
159:23
88:15
162:2
171:21
163:13
120:16
helping
history
177:10
186:4,23
129:24
66:15
188:25
138:23
20:19
hobbyhorse
hos stable
189:7
152:9
349
.
57:3
42:23
122:7
72:9
190:5
health
hold
191:5
15:16
helps
host
62:4
61:2
161:6
harass
hear
96:17
38:25
6:9,15
hey
174:17
172:23
39:1,12
10:4
29:7 51:3
190:1
hostile
41:18
27:3,4
77:12
82:6
124:1077:18,19
169:11
hole
85:16
170:18
168:10
78:8,11
ESQUIRE 800.211.DEPO (3376)
1 11 1 1 . EsquireSolutions. corn
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
Index:
February 24, 2016
hosts..independent
hosts
148:5
82:18
99:24
imprudently
79:12,13
hundreds
100:17
impermissib
175:20
hot
19:18
166:13
le
176:2,5
32:6
111:22
174:11,13
36:3
in-house
86:5,19
141:19
184:1
89:8,12
implying
hotel
167:22,23
identify
128:9
in-person
42:24
168:1
22:2
55:21
importance
84:12,16,
hung
ignorance
12:25
inaccesaibl
17,19
33:20
15:2
88:10
e
118:16
hungry
ill
18:8
142:9,21,
important
23 143:3,
32:15
172:22
22:18
incidental
5,6,8,9
37:4 74:5
illegal
37:9,10
18:22
hour
hunt
18:11
66:11
inclined
165:2
177:22
125:18
31:13
99v8
128:18
hurry
178:7,8
148:23
100:3
129:1,2,7
48:9
Image
153:3
include
131:22
husband
23:3,7,20
impossible
127.2
hours
47:6
imagination
135:19
included
43:16
67:4
impressed
103:2
45:23
147:22
58:12
I
imagine
incognito
107:20
impression
13:3
91:24
118:4
50:13
128:19
i.e.
130:7
54:7
income
129:4
53:8
148:8
64:21
158:24
house
IAimagnng
76:16
189:4
9:24 32:4
46:24
imagining
67.12
82'4
incorporate
42:24
idea
89:12,13,
d
43:7immediately
45:17
14,17,19
90:6
63:4,10
56:13
53:9
96:9
65:1761:25
83:22
134:21,23
incorporati
69:15
77:8,25
Immokalee
148:11
on
77:14
79:22
39:5
149:12
83:14
79:10,13
80:4
168:8
90:11
84:3,5,11112:9
impact
172:4
incredibly
95:3,5,
184:21
66:25
improve
40:18
11,12,16
ideal
impeach
20:16
incurred
140:6
46:17
159:24
58:15
improvement
126:20
identical
impeccable
123:18
53:4,14
dIne endenc
p
Hudson
162:9
107:22
imprudent
e
imperative
39:23
70:15
huge
identificat
5:14116:22
176:9,14
66:10
ion
49:9
imperil
independent
116:19
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
70:19
71:1
80:19
117:23
indications
62:16
indicator
147:21
indignant
138:6
indispensab
le
161:8
individual
59:11
individual'
s
70:18
individuall
y
63:6
89:24
97:19
individuals
54:2
59:21
81:3
145:18
inevitably
38:5
infiltrate
121:13,14
influenced
174:9
influences
81:4
information
13:22
14:15
15:16
16:20,24
17:3
34:23,25
35:4
112:12
180:2
initial
50:25
66:3
80:22
83:8,12
initially
150:14
injunction
163:2
Inn
26:9
innocuous
157:1
input
67:5
inquire
38:13,17
ins
178:2
inside
91:13
155:9
insisted
70:19
85:14
insistent
31:9
inspect
86:8
instance
33:12
123:16
instances
46:24
instant
186:1
institution
15:5
instruct
97:4 99:6
instructed
120:20
instructing
97:8
98:3,5
instruction
98:9,15,
18,19
99:17
instruction
s
151:18
instrument
190:12
instrumenta
lity
70:18
104:6,11,
12 117:23
121:22
122:18
insurance
15:16
16:25
152:15,22
154:12
insuring
116:2
integrity
124:10
128:13
intending
112:9
113:23
118:17
interact
February 24, 2016
Index: indications -invite
12:2
interacted
88:4
104:15,
16,17,21
interaction
s
104:16
172:9
interest
8:10
10:13
11:2
18:20
23:24
26:5
34:11,23
37:16
107:14,17
interested
14:6
29:16
34:9,15
51:22,23,
24 52:2
70:3
116:1
121:21
122:13
170:20
181:24
interesting
25:11
29:2,17
121:24
interfere
82:10,13
intern
86:2
112:4
internal
46:25
interrupt
10:4
92:22
132:3
170:21
interviews
157:8,9
intimately
162:2
intimidated
119:11
intrigued
13:8
introduced
86:3
introductio
n
110:9
intuition
51:9,10,
11
invasive
15:13
investigati
on
122:11
investigati
ons
46:25
investigati
ve
85:19
112:8
invitation
31:8
43:10
48:4
111:19
161:22
invite
127:21
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: invited..Josh
invited
47:18
43:13,14,
77:3,6,10
166:15
48:8
134:5
17,19
78:21
170:21
179:6
Islamic
45:13,25
79:9
174:15
invites
8:21 35:2
56:1,3
83:11,23
177:7
50:19
67:14
94:6
Joel
Islamic-
73:17,18,
102:22
inviting
american
22 82:6
136:8
116 116::24
100:8
34:10
89:1
139:21
John
involve
issue
111:21
jeopardy
24.22
91:12
29:1
126:21
38:9
138:24
170:6
33:22
132:5,20
jointly
34:19
139: 15
Jerry
97:12,17
involved
141:1
170:14,22
10:17
36:1,4
142:1,15
jokes
44:15
Jersey
12:14
45:16
153:15,19
29:23
121:9
61:5,10,
57:17
169:1
65:7
Jonathan
14 88:5
58:7
172:11
51:12,14
91:13
67:18
177:13
jerseys
52:1
94:22
73:12
178:14,20
105:19
54:14,20
113:11,24
80:3
179:12
Jill
55:11,22
135:3
102:15
180:22
120:6
61:20
137:4
106:17,25
181:17,24
63:12,23
170:10
107:13,17
187:3
Joann
65: 1,15
176:21
161:21
109:13
Italian
176:7
67:2200
involvement
113:18
63:10
77:7
113:3
115:24
job
79:19,23
Irish
125:16,25
46:13
80:15
128:13
J
87:15
87:4_
168:9,10
129:18
95:20
88:22
Irishman
132:15,23
jacked
111:21
95:6
168:11
143:6
42:8
112:2
113:10
ironic
153:17
jail
118:20
136:22
148:13
177:24
149:7
137:4,9,
161:24
180:13
46:2
Joel
12,15,19,
181:18
James
4:11 5:7,
20 145:12
Ironically
184:17
12:20
g 6:9,15
146:9
22:10
188:12148:3
January
61:2 79:3
ironies
issues
41:16
82:9
178:13
136:7
9:5
48:12,16,
92:16
180:5
165:12
10:13,14
17,25
96:17
Josh
irreconcila
26:13
49:2,3
97:4 98:3
4:19 6:9
ble
27:20,21
50:18
100:19
27:2
157:3
28:6,20
55:20
101:5
54:16
30:24
56:5
117:4
78:7
irrelevant
31:1
61:21
132:2,6
96:18
36:6
37:24
63:17,19
160:15
98:2,8
ESQUIRE 800.211.DEPO (33 76)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: Joshua..Latinos
100:18
155:1
kids
knew
25:9,12
102:7
183:20
160:4
13:14,15,
107:11,25
109:1
jurisdictio
kind
25 70:20
111:3
139:17
73:25
115:10
n
15:24
167:9
60:6
19:14
84:9
148:9
175:22
87:13
151:14,23
jurisdictio
23.1
95:13
Joshua
27:18
Lacicero's
ns
135:13
4:16
12.6
29:5 40:6
107:15
44:25
157:8
journalist
justice
48:4 52:3
180:3
lack
85:20
9:13,1889:18
54:7
knocks
journalisti
10:12,15
63:14
20:7
ladies
c
11:1 45:1
64:1
172:14
knowing
112:8
130:4
65:19,21,
106:24
lady
judge
justified
23 67:24
119:24
81:21
16:7,13
129:12
68:21
152:10
95:7
60:4
justify
69:3,12,
157:14,15
119:12
69:24
15 77:9
120:6
92:12
162:17
82:2,14
knowledge
99:6,7,
Juvenile
93:3
14:10
laid
11,13
130:4
111:15
15:6 20:6
69:18
100:8,9,
114:3
44:21
156:6
11 185:10
116:20
56:10
183:13
186:16,22
K
118:11
73:20
Lakeland
188:12,
120:9
103:12
6:5 13:4
21,22
K9
130:11
104:3
90:9
189:8
11:11
139:12
123:13
155:3,25
121:11
140:21
125:12
judge's
147:3
126:14
landmark
176:16
keeping
148:13
137:4
19:11
judges
127:13
155:10
143:23
language
61:15
136:18
156:3,4,6
148:2
153:21
165:1
161:11
149:9
judgment
Keith
165:9
151:8,10
large
57:18
138:25
168:19,25
knowledgeab
4:3 110:7
July
kerfu£fle
169:4
le
147:2
175:3,8
12:4
173:2
73:22
largely
jump
167:14
176:25
82:1
45:8
106:16
kingdom
147:23
late
keys
163:13
43:15
June
163:12
129:25
168:24
Kissane
L
143:2
133:21
kid
4;17
180:1
136:10
46:11,14
kitchen
Lacicero
181:15
138:15,16
47:2
47:11
19:7
Latinos
139:22
121:9
24:20
45:22
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: law -legally
law
105:8,11
lawsuit
144:7
157:11,15
4:17 8:16
107:19
19:16
150:13
160:20
11:19
108:6,8,
21:1 33:7
157:22
172:13
12:2
13
40:11
158:1,2
176:21
13:14
109:12,25
52:12
170:11
leaving
15:4
110:2
58:15
lawyer
14:1
16:17
114:6
87:12,17
123:1
155:15
18:19,21,
116:4,23,
89:15
23,25
25 119:11
94:16
lawyers
ledge
19:6
123:4,9
114:9
132:14
168:20
20:23
125:11
123:6,14,
138:18,
left
24:12,16,
128:17
17 125:24
21,22
15:10
21,23
129:15
126:22
lay
27:16
31:6
131:5,16
131:12
180:13
48:4
39:13
132:1
158:13
54:20
42:10
133:13
160:9,18,
layperson
56:1 63:9
43:12
134:19
24 161:1,
138:7
85:12
44:12
135:6,7,
4,6,23
177:20,21
132:13
52:10,11,
12
162:4
layperson's
136:10,19
14 54:22,
136:14,
165:18
65:7
149:13
23,24
15,23
166:9
157:2,14
55:1,16
137:5,9,
172:22
lead
165:8
56:11,13
12,22
lawsuits
18:13
57:6,7,8
138:3,9
103:8
legal
58:18
139:8,14
,
123
leading
g
16:4 17:5
59:5,6
140:9,10,
222,23
54:9
19:4,7,17
61:12,16
25
20:17
79:15
20:12,15
64:3,10,
141:10,23
24:10,14
93:8
23:14
13,20
143:18
33.7
25:14
65:2
144:8
68:2,5
leads
45:24
67:20,21,
146:7,21
73:7,14
38:6
46:11
25 72:3,
149:4,22
86:6,17,
League
56:20
4,11
152:13
20 82
123:23
57:21
73:5,6
154:4
107:112
124:24
58:20,23
74:1,13
157:23
110:6
125:5
60:12
75:4,7,
158:3
113:5,6,
162:9
68:3 80:2
13,19,21,
162:6
8,9
181:4
97:3,13
24 76:19
163:6,8
114:10
99:19,22
82:2
165:1
117:
learn
123:2
86:18,20,
171:12
4,5
123:
154:8
132:11
22 87.9,
176:20
125:1111
learned
134:9
23,24
177:1,4,
129:1
43:25
149:3
88:6,14
12,15
134:7,18
150:9,25
89:2,3,19
178:12
135:4,5,
leave
177:13,21
90:15,20
6,13
135:23
180:15,17
lawless
136:6
139:4
96:11
84:24
139:9
149:11
legally
103:3
ESQUIRE 800.211.DEP0 (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: legislation.. log
36:25
liar
185:13
25:16
169:24
117:2
47:1
limits
59:21
183:21
legislation
liars
70:8
68:6 74:8
185:9
125:6
46:23
87:4
litigator
lines
106:18
142:4
license
55:9 64:6
114:13,16
89:14
legislative
31:6
116:22
142:18
litigators
182:19
89:19
lion's
litigating
19.9
legislators
137:9
72:2,11
71:18,19
litigious
128:14
165:1
73:2
100:1
list
legitimate
licensed
17:22
114:15
live
100:4
65:4,6
25:7
litigation
160:16
102:6,12
88:1,269'20
11:25
137:11,12
lives
103:1
106:3
20:7,9,13
67:1
128:10
lieutenant
listed
24:4
169:8
length
86:8
34:21
33:12
43:12
life
36:20
livid
37:14
listen
51:17,19
118:5
lengthy
95'20
169:5
52:18
living
140:24
100:2
182:24
53:19
186:19
letter
125:5
listened
55:25
126:7,11
130:5
147:19
56:5
to
150:6
151:20,22
57:14,19
17:16
155:8,11
156:12,
lists
58:1 59:9
120:15
19,22
40:1
60:2
loans
lettere
158:15
83:14
61:11
138:4
125:16
106:4
67:18,22
178:15
165:3,11,
loathe
15
literally
69:7
98:25
letting
151:19,21
70:20
152:7
lifted
160:15
71:5,10
lobby
164:8
189:3
88:12
14:10
level
10:18
ligation
litigant
94:23
127:14
88:8
165:21
19:17
107:4,16
local
114:22
152:17
light
121:6
11:16litigants
Levy
gl:g
141:25
123:20
12:5 58:7
11:17
112:16
124:2,3
87:6,7
litigate
181:9
Lexisnexia
likelihood
73:4
127:19
64:12
128:16
locally
21:14
91:12
132:6
24:24
liability
limited
105:14
137:17
56:9
110:7
location
60:3
87:14
114:17,19
147:13
90:3
126:4,5,8
152:5
131:3
103:2
154:19
160:10,12
log
162:6,18
165:22
litigated
162:12,23
86:9
163:1
184:18
19:11
163:7
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: logically -make
logically
lookout
135:16
lunchroom
122:19
36:24
51:16
142:11
91:5
123:12
long
loosely
146:2
130:18
155:16
132:16
8:22
12:9,19
M
20:18
165:2
134:3
Lord
183:21
136:2
42:13
154:23
Machiavelli
141:7
58:2 64:2
lots
66:17
lose
56:25
an
152:4
78:6
91:1757:15,16
157:12
156:23
81:14
150:1
58:18
machination
157:19
162:1
85:18
losing
157:20
s
164:24,25
162:22
Lou
151:12
167:13,15
115:9
115:9
loss
179:4,6,
machine
168:14
117:3,5
99:4
10,16
21:18
177:16
132:25
180:9,10,
22:8
181:4,6,7
149:2
lost
11 181:23
49:10
182:6,10
150:9
19:24
183:4
116:17
151:15
23:24
186:8
Madison
154:4
58:11
machines
12:20
157:11
106:19
188:1,7
21'24
17:17
159:25
love
mad
mail
160:4
lot
94:25
110:
72:23
168:22
12:4 18:5
181:16
115:66
169:5
25:12
86:14
28:6
loved
121:18,19
131:13
181:21
31:12
46:2
made
133:15
182:18
183:5
33:19
lovely
7:8,14
maintain
184:21
37:24
31:17
12:16
146:4
52:20
32:19
13:12
long-time
53:1895:7
15:15
maintained
155:18
54:2
130:11
16:21
127:15
longer
56:24
lumping
17:7,11,
majority
108:14
59:22
14 30:5,7
25:8,10,
173:17
175:8
65:18
33:4,9
16 46:1
66:25
lunch
35:20,25
59:8
Longport
67:1
9:12 32:8
40:12
121:2
29:23
73:7,13,
105:21
41:13
make
longtime
17 89:2
174:3,7
65:20
81:11
94:11
181:19
71:8,12
13:5,23
14:6,15
looked
95:2,11,
luncheon
72:13
33:18
14
88.4
23:12
139:25
35:3,6,
112:13,
92:11
64:1,9
140:2,12
15,17
14,15
106:15 16,
69:13
141:5,10,
36:8,9
115:21
107:2,5,
81:18
13 142:8,
38:1
183:6
125:18
10
6,7
40:2,21
128:12
111:16
129:6,7
114:1,20
47:21
ESQUIRE 800.211.DEPO (33 76)
S 0 L U., a N S EsquireSolutions.com
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: makes..marty's
53:7
27:10,12
141:20
147:4
22,24
57:13,14
34:22
March
Martin
117:9,14,
61:12,15
35:23
16,20
15:10,12
25:18
71:3,4
37:22
119:6
110:18,
65:12
72:1,15,
38:4
122:3,4,
22,23
81:9
16,22,24
40:19
14 124:23
111:6
102:23,25
74:25
42:2
125:7
136:9
104:10,24
86:12
69:24
132:22
164:18,20
154:21,24
92:8
84:6,22
145:12
93:19,20
113:2,3,
marginalize
156:2
146:6,13,
96:10
21 115:14
d
Marty
19 155:19
98:1
116:9,17
148:12
26:3
156:1,9
104:8
117:10,11
mark
29:12
157:15,18
105:23
121:9
49:5
30:20,22
158:6,12,
112:20,
122:24
82:16
31:2,17,
16 159:2,
21,24
124:12,13
93:19
24 32:17,
4,7,15,21
116:6,14
127:23
100:15
25 37:21,
160:7
119:25
128:16
166:10
24 38:11
163:22
123:11
129:5,11
174:10
42:20,23
164:21
124:3
142:23
183:23
43:8,20
165:1,8
142:3
172:23
187:21
44:8,10,
168:7
147:24
177:17
18 47:21
169:7,25
149:2
178:4,5
marked
48:4,13
171:23
150:19
49:6,8
50:17
172:2
162:13
man
50:16
54:5,7,9,
173:12,
165:3
72.9
62:4
12 55:20
18,21
169:25
119:19
82;17
65:16
177:5,11
172:12
183:12
83:6
67:7
179:23
173:6,22
man's
100:16,25
71:11
180:5,8,
180:13
183:12
101:24
72:9
24 184:19
183:7
108:22
74:22
185:4,18,
186:19,21
manage
166:12
77:4,11
20 190:6
22;16
191:8
174:12
78:6
23:3
183:25
79:11,16
marty'e
kes
ma31:20
management
8:1,17 :13,14
21:20
market
844
43:7,9,17
36:22
154:1,6
22:1
85:5
44:16
56:24
marking
93:7,:210,
47:19
61:8
managing
100:18
55:24
86:11
88:6
22 94
65:16
117:16
135:6,7
Marra
95:6,8
6620
126:23
137:11
92:12
96:3,9
76:2
150:10
148:3
Marrett
79'10
109 :
109:21,
making
manual
140:24
23,24
84:11
14:14
127:13
145:14,
110:10,
95'2'7
19:2manuals
20'25
13,14
110:4
21:16
111:23
146:11,24
116:5,14,
117:23
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
121:22
125:3
155:18
Mary
171:20
mask
160:2
match
119:6
122:1
Mathematica
lly
121:4
Matt
25:4
matter
4:23
25:18
33:19,20
34:6,17
36:13
37:23
47:16
61:8
128:7
134:2,3,8
160:17,18
165:7,24
166:19
190:13,25
Mckenzie
14:17
Mcknight
24:22
meal
32:19
meals
95:6
meaning
20:2
30:3,11
168:9
meaningful
46:7
187:19
means
27:19
29:10
59:18
124:2
meant
66:24
69:20
mechanics
65:20
mechanisms
23:18
media
112:9
meekly
16:8
meet
25:21
26:4,7
30:13,25
45:17
48:25
50:10
51:1
77:10
84:13
85:24
95:17
105:21
123:17
179:7
meeting
14:16,20
23:2
26:2,15,
20 27:15
29:18,23
30:13,16,
19 32:5,6
33:1,3
43:1
46:10
47:23
48:3,11
50:2,14,
19 54:9
55:20
63:23
65:12,13,
14 67:12,
14 91:14,
15 118:6,
7,18
158:3
180:24
meetings
40:18
111:18
135:7
137:5
148:12
166:25
Megan
4:1
member
13:3 17:4
104:8,15,
16,18
141:17
members
9:22
12:22
17:1
81:18
94:3
104:14,21
128:15
140:4
141:9
181:3
memo
119:17
memorandum
93:17
103:16,21
104:1,2
memorializi
ng
103:18,22
133:15
memories
159:23
memory
59:16
62:19
men
37:2 40:8
76:9
mention
64:5
mentioned
29:19
34:10
55:18
57:1
114:11
146:12
181:2
184:16
MHO
50:18
109:10,
12,13
merge
131:13
Merit
138:25
Mesa
140:19
145:13,
20,25
mess
149:25
177:12
met
February 24, 2016
Index: Mary -mill
14:20
26:8
31:15,16,
24 38:16
52:24
62:25
63:4,12,
13 81:19,
21,22
84:1,16
105:24,25
163:14,17
168:8,13
169:6
173:23
179:8,23
181:12
183:9,10
meter
162:19
Miami
13:5
32:11
Miami Ia
130:5
156:12
Miami-dade
84:22
87:7
mic
6:12
mid
179:25
181:15
middle
17:9
31:19
72:19
124:6
163:5
mill
25:12
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: million -mystified
million
minutes
153:11
58:4
Mulberry
124:17
40:22
30:12
money
morally
151:20
42:3
18:5 23:2
36:24
Muller
159:4,5
131:14
28:13
120:6
170:3
155:13
Morgan
29:5,15
191:7
122:3
multi -
millionaire
41:12
billion -
s
miserable
59:14,15
morning
dollar
122:1
165:3
60:9
4:16
53:10
mind
mistake
66:16,19
43:16
75:4
95:18
multi -
25:14
104:8
76:15
118:17
million -
28:24
mistaken
82:9,12
141:13
dollar
54:8,16
54:15
85:11
143:1
40:22
85:9
100:21
80:25
109:14
mother
multi -state
104:23,25
83:24116:2
119:14
137:12
84:15
117:17
136:2
86:5
119:3
motivated
multination
147:14
113:22
124:25
66:16
als
mine
150:17
128:16,17
motivation
21:21
86:2
151:12
129:6,20
33:19
multiple
155:24
171:7
150:22
34:5 35:7
30:8
160:22
174:4
158:17,21
37:6,23
165:10
misundersta
159:3
40:15
mumble
189:16
nding
165:2
162:11
5.2
Mine's124:22
169:19
municipalit
170:5
motivation'
ies
38:7
Mitch
181:19
s
30:6
ministry
169:4
185:13
36:3
72.25
45:7
187:6,16
motivations
147:11
monolithic
minor
Mitchell
173:8
35:12
181:3
72:20
166:25
36:15
municipalit
109:13
167:3
month
37:8
122:12
31:23
47:17
y
141:20
modest
68:16
61:7
84:22
87:20
74:2,23
69:21,23
182:6
minority
127:22
94:6
murder
9:13,17,
135:5
mountain
47:8
16 10:13,
moments
133:16
136:6
138:4
15 11:8
181:13
mouths
Muslim
24:6
Monday
34:11
28:14
83:25
months
31:11
Muslim -
45:1
64:1,19
7:3 30:18
move
121:12
133:21
46:9
79:4
americana
9:5
134:25
121:20
minute
monetary
136:11
130:13
mystified
54:16,17
127:22
165:11,16
178:9
133:11
129:11
Monty
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: mystifies.. November
mystifies
173:14
85:20
107:13,21
160:9
128:24
necessity
140:3
110:16,17
161:6
141:24
111:3
165:19
102:5,12
N
103:1
newspapers
137:23
North
12:23
nodding
37:3
neck
naive
169:2
nice
5:20
171:1
67:19
needed
14:5
non- -
not-for-
32:16,17
attorney
profit
Nakomis
68:5
42:25
135:13
56:18
30:12
needing
48:13,18
79:18
named
74:8
65:15
non -
102:6,13
attorneys
26:2
Needless
71:11
180:23
103:2
84:10
161:11
81:21,23
notable
96:3
130:1
non-
97:13
nefarious
158:4
negotiables
28:24
120:6
29:4
159:16
127:16
29'9
161:7
negative
168:9
non-
notarized
names
151:23
169:5
normative
72'22
138:21
157:13
172:16
14:23
86:13
173:20
181:22
notary
Nathan
nonevent
25:2
negotiate
Nick
13:18
4:2 114:5
60:10
131:15,22
26:10
notated
national
133:12
12:18
negotiated
136:1
nonexempt
51:13
nationally
126:16,19
137:18
15:18
notation
28:9
152:13
145:13
nonissue
50:17
negotiation
156:10
75:7
note
nature
128:9
night
177'8
25:5 33:2
nonprofit
67:21
150:23
32:2,3,4
27:22
noted
72:6 95:1
negotiation
42:16
54:2
132:21
100:1
a
43:9
56:22
133:10
132:11
133:14
46:6,9
57:20
146:5
178:16
63:5
58:22
notes
150:23
69:10
77:9
6:25
nemesis
142:9,20
80:15182:15
8,11,14,
14,
navigate
171:25
16,18
96:6,7,15
10:23
neophyte
130:2
27:7,11
111:15
58:14
nights
91:19
187:12
1
31:24
Neapolitan
notice
95:1
news
no-win
nonsense
153:13
112:12
149:20
143:15
183:17
necessarily
newspaper
157:25
55:18
12:17,23
noble
158:14
notorious
56:9 70:2
13:16
105:15
nonsensical
47:1
90:23
106:2,4,
44:1,3,14
13,19,24
159:8
November
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: nuance -offering
175:17
30:14,17
129:15
181:13
69:22,23
nuance
37:21,25
131:5,16
182:10,14
observation
43:4,24
132:1
183:8
35:7
12:18
47:24
133:13
188:9
nuclear
49:25
134:19
obstruction
168:22
50:18,19
136:13
O'hare's
s
188.5
number
51:12
137:4,5
10:23
7:8 11:18
54:14,21
138:9
oatmeal
occasions
12:12
55:1,11
139:8,14
29:13
57:5
24:20
56:11,13
140:9,10,
obeyed
33:7
57:7 59:6
25 141:9,
20:23
occur
46:21
61:20
23 143:18
53:3
57:5
62:21
145:13
object
170:7
62:5,12
63:23
146:21
64:16
occurred
68:25
65:1 66:2
149:4
96:25
26:20
74:12
72:3,11
152:13
134:13
81:22
74:13
154:22,25
159:10
occurring
116:18
75:11
156:2
objected
134:21,
123:25
76:18,19
159:14,
79:21
22,23
131:10
80:16
19,21
164:10,
177:1
136:12
81:4,9
161:1,3,7
11,12
October
141:17
83:17
164:11
184:11
101:13,17
167:16
86:18,20,
166:22
175:24
182:9,11,
22 87:9,
167:14
objection
23,24
172:20
35:5 39:3
offended
21
88:6,14
173:12
61:2 81:6
49:11
numbered
89:3
175:13
92'3'9
offending
108:25
90:15,20
176:20
99:9
20:3
numbers
93:4
177:12
100:12
offense
67:7
94:7,9
178:13,23
132: 5
129:11
97:10,12,
180:24
152:25
52:8
18,22
177:8
offensive
numerically
98:5
O'boyle's
184:13
15:12
25:14
84:5
99:24
91:25
objections
offer
numerous
102:23,25
165:23
133:10
65:20
170:10
103:17,21
190.7
134:3,12,
66:3
104:4,10,
14
88:16
25 105:8
O'boylea
131:9
p
108:6,8,
142:11
objective
-
35:4,6,
153:10
O'bolye
13
109:11,
O'connor
13,18
offered
65:12
15,25
161:21
38:13,17,
42:23
116:2
176:7
24 40:14
66:4
O'bo le
y
11 6:4,14,
O'hare
58:24
131:4
24:21
25 123:4,
173:15
110:4
offering
25:19,21
9 125:8,
179:1,3
objectives
29:15
26:3
11 128:17
180:25
37:8 61:7
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: office -package
158:10
one-on-one
opening
opposed
34:20
169:18
53:16
16:15
17:1
35:10
182:23
140:23,24
17:13
34:24
112:12
office
one-time
16:17
79:6
original
14:3,5
9:9
operate
opposing
7:22
21:23
one-year
23:19
147:17,24
originally
22:5
105:15,19
151:25
93:13
136:21
28:17
operated
op
153:2
183:20
33:4,16
ongoing
154:15
38:19
20:11
53:2,5
other's
72:17
opposite
42:18
33:25
169:8
125:23
176:4
47:21,22
102:15
outlined
48:6,7
152:19
operates
opted
93:17
64:5 71:9
22:14
42:24
89:25
open
11:22
27:22
option
outs
90:6,15,
12:21,24,
operating
168:22
178:2
18,19,21
25 19:8
104:23
overcharged
91:5,8,13
20:6
183:14
options
23:13
94:11
26:5,13,
14:25
95:8,13
operation
overnight
120:13
165:15
order
50:9
92.24
120
27.4
142:22114:6
21,22
operative
96:14
155:25
28:6 31:1
147:11
167:24
overtures
officer
36:20
opinion
186:23
168:14
46:16
37:13
19:8
ordered
overwhelmin
81:1,2
48:4
56:20
32:8
g
97:15
52:18
60:23
120:9
122:9,11
55:25
71:22
orders
officers
56:5,9,23
134:3
106:8
owe
159:3,4,5
46:18,23
67.22
165:6
organizatio
112:17
73:16,21
176:2,16
n
owner
76:8
177:21
8:19
104:8
offices
82:1,6
182:18
9:13,15,
14:2
87:3
20 17:20
owns
28:17
88:11
o p inions
34:7
9022
71:7
95:20
181:18
56:23
30:22
85:24
107:4,16
opportunity
112:9
141:14
117:7
11:11
117:18
p
official
134:8
20:19
organizatio
38:2
140:15,1754:11
p.m.
141:1
119:21
no
9:11
54:18
officials
142:1,15
121:11
100:23
18:18
179:11
141:23
10:17,18,
91:14
180:21
149:23
20,25
138:13
94:18
181:16,24
155:21
11:1,2,12
191:9
185:24
162:5
12:9,11
package
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: pages -people
158:4
88:1
parties
9:1 39:9
20:10
142:23
94:22
41:12
146:15
pages
101:20
180:21
partner
66:4
160:9
108:25
Park
19:10
68:22
Pennsylvani
167:22
6:5
88:6
69:2
a
168:1,2
137:11
73:8,11
65:7
Parkin g
75:3
174:18,22
65:16
partnership
79:11
penny
paid
Parks
149:22
85:14
20:22
8:19 9:1
36:25
party
106:14
39:9
18:19
75:24
120:10
115:20
20:22
Parmesan
161:9
124:16
170:6
23;9
63:11,12
138:5
185:9
people
28:20
Part
144:9
11:2,4
59:6
8:25
pass
169:19
16:16
60:17,18
26:17
52:10
179:17
18:18
85:14
27;13
passed
181:19
21:23
128:1
39:7 40:9
18:24
paycheck
24:6
140:6
45:18,20
31:4 65:4
8:8 70:25
28:4,14,
144:6
56:6,7
87:25
22,23
152:15
67:2,21
payers
29:6,19
179:17,18
68:3 77:5
Passionate
147:10
27:21
3:19
3
pain
79:17
28.25
paying
34:15
68;7
85:10
29.10
23:14
35:8,9,
74:24
89:5
43:14
31:10
10,17,22
152:5
97:17
57:17
60:9,10
36:7,15,
Palace
102:11
73:16
74:6
17,18
174:3
110:3
87:19
37:15
112:19
past
117:4
42:9
Palm
116:2
77:16
128:24
44:12
26:8,9
118:23,25
pastor
138:5
45:12,21,
pancakes
122:19
130:15
143:10
23 46:10,
29:13
124:15,19
180:18
20 47:3,5
128:8
pastrami
52:5
Panera
135:23
32:6,7,14
Payment
53:21
63:2
150:4
pat
153:11
57:6
paper
154:8
152;9
pays
58:19
36:12
178:21
128:21
59:19
patience
Paragraph
parted
152:8
peaceful
66:25
101:24
85:12
11:10
67:14
patient
37:18
71:17
102:1
participate
19:14
91:14
103:13
d
121:10
110:12
paralegal
102:22
Pause
pedophiles
116:11
33:6
particulars
77:20
34:7
117:6,22
87:11
26:21
pay
pending
122:5,6
ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: people's -platter
125:2,19
periods
perspective
163:15,25
30:9
130:22,24
13:9
12:1
photograph
32:11,18
142:2,3
perpetually
39:11
86:8
38:6
164:16
40:9
74:15
173:7,11
51:15,16
44:25
Photography
86;7
180:13
persnickety
57:10
12:11
94:23
people's
71:13
56:13
Physical
127:25
69:21,22
115:11
65:8
90:15
148:4
114:14
person
88:12
Pick
165:10
31:16
102:14
placing
perceive
51:25
180:22
161:14
127:13
57:19
55:23
perversion
P
picking
P g
perceived
63:13
184:24
70:7
plaintiff
156:23
106:15
185:15
Pickle
21:5
109:23
25:18
percent
P
Peterson
32:9
57:12
113:8
19:25
114:1,8,
25:2458:6
picky
52:23
9,20
52:23
71:23
59:11
53:1,3,
138:24
60:8
12,13
157:12
picture
130:9
72:18
162:1
philosophic
52:15
163:18
al
162:14,21
135:25
179:17
116:19
piggybank
,
plaintiff's
185:2
82:9
personal
148:10
58:13
percentage
157:3
pilot
7:7 13:22
plaintiffs
123:25
14:15
philosophic
64:18
57:1,11,
perception
26:1
ally
Pinkett
16 161:8
121:4
56:24
56:2
24:24
plane
173:16
88:8,24
88:9,25
perfect
130:21
117:2
piss
28:23
44:16
141:12
86:6
147:17,24
phone
185:21
136:14
160:7
5:13,19
pissed
172:12
38:1,2
planes
perfectly
6:13,17
109:21,22
64:18
58:5
Personaliti
14:7
66:17
es
25:23
110:14
planned
70:22
88:5
27:17
pissing
157:8
performance
ersonall
P y
48:14
119:6
planning
21:4
62:23
122:1
16:25
148:1
27.24
63:3 77:5
pitchfork
157:9,10
period
60:4
81:20
171:22
109:5121:6,7,
92:15
plans
110:22
99:12
pizza
29:4
15,16
periodicall
148:1
100:8
174:3,4,9
plate
149:18
116:18
place
59:13
y
8:16
161:1,3
147:19
17:18
platter
156:1
20:23
149:22
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: plausible..prerogative
plausible
84:9
16:21
123:2
142:2
97:12,18
point
18:14
132:9
practice
play
25:15
19:20,21
134:16
25:5
20:24
144:21
125:3
28:1
52:11
131:13
30:5,6
21:2
149:20
56:6
164:15
33:21
28:17
positive
64:3,10,
40:12
played37:4
45:20
66:22
14,20
136:20
50:12
121:12
positively
65:1
56:10
67:20,21
playing
64:25
160:16
67:1
114:7
17:6
72:13
pony
possibility
115:16
plead
82:14
140:22
169:11
116:24
124:6
90:22
pool
possibly
135:12
92:6,16
43:11
137:13
pleasant
97:1
69:15
131:2
131:2
157:23
26:15
104:3
177:4,15
72:9
105:7
poor
postage
178:12
81:23
129:5
9:13,17,
73:21
88:7
132:19
18 10:13,
practicesposture
95:21
142:13
15 24:6
150:11
99:2
156:3
170:15
28:14
practicing
159:15
176:8
39:9
Pot
154:4
172:9
180:6
45:1,8,20
28:23
prebankrupt
pleased
points
49:22
potential
cy
146:25122:6
93:6,7
33:10
165:19
147:25
146:13
131:23
51:24
148:4,7
173:22
147:6
Predatory
police
22:5
pleasure
37:17
pop
potentially
70:21
111:24
127:5
preeminent
46:18,22
19:8
108:10
86:7
popping
153:8,18
plentiful
122:10
32:25
165:18
prefer
33:1
177:22
5:8 8:3
71:19
policies
plenty
111:20
portal
Pound
preliminary
159:13
19:20
39:9,21
74:9
policy
58:8
163:16
plethora
128:3
portion
124:19
52:18
132:1
110:7
157:17
Preparation
133:13,19
portions
7.6
plug
power
131:13
political
129:11
14:10
Prepare
plumb
17:3
position
15:6
?
56:21
7:17
16:16
2020
67.2
Polk
41:19,25
19:3
prepared
PMJA
9:20 11:5
71:17
117:20
156:25
9:1B
13:18,19
97:6,9
powerful
prerogative
10:15
14:18
104:4
ESQUIRE 800.211.DEPO (3376)
Esquire Solutions. corn
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: present -proposals
98:4
160:5
146:16
19 119:8
17,20
present
prevail
174:6
121:19,20
profanity
21:3
60:22,23
180:24
124:11,14
16:14
97:24
61:1,12
prison
125:14
127:12
Profession
presented
preventing
46:3
130:20
137:23
178:19
34:17
private
131:4
profession
presently
previously
23:3 46:4
148:5
lly
8:1 25:3
34:21
141:12
160:6
149:18
49:6
179:20
172:15
president
86:21
privilege
182:23,25
Profit
25:24
189:20
23:21
80:25
108:22
97:1,5,25
190:9,20
129:6,8
105:12
143:17
98:25
108:9
173:25
99:2,11
problematic
Program
140:7
174:24
102:15
125:17
7:24
175:12
132:7,13,
128:12
22:14
press
primarily
17,18,25
151:5,6
53:17
128:15
9:19
134:13
152:21
prohibitive
156:25
11:18,22
135:10
problems
73:13
157:1,5
150:8
158:7
140:3
187:23
56:25
project
primary
188:2,6,8
57:9 73:5
8:20
pressure
6.7 7'21
88:20
71:25
privileged
projects
120:1
principal
98:15
Proceed
112:6
135:11
19:7
132:12
164:8
prolific
pretend
24'21
privy
proceeded
75:10
160:23
37:12
17,20
14:22
58:21
159:7
promise
pretty
141:25
pro
29:15
15:13
19:16,17
Process
149:15
30:22
Principals
25:6,17
58:20,23
89:3
60:15
prompted
34:4
69:7
54:13
43:7,14
print
146:14
111:16
52:15
114:4,5
150:14,18
127'21
proper
59:10
152:5
190:25
176:23
P
66:14
82:20t
153:16
produce
properly
67:3
Problem
126:4
53:9
73:22
prior
127:3,4
78:6
9:8 21:16
4:21 20:5
136:5
proposal
Pro P
87:15,20
27:1,10,
36:14
162:6
150:19
88:13
11 43:2 ,
39:5 58:5
184:7,19
169:10,
89;5
5,23 73:5
60:8
186:16
21,22
113:22
86:19
68:14,17,
170:5
123:3
87:22
19,20
produced
proposals
135:1,20
138:17
79:24
20:3 42:5
169:4
157:1
144:23
116:1,20
127:5
117:1,2,
167:15,
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: proposed.. putting
proposed
prudent
47:21
142:4
purchased
93:12,13
39:21
51:2,17,
144:3
141:6
proposition
pub
18,20
147:9,11
purely
162:22
168:9,10,
52:19,23
161:23
29:12
18
53:1,8,9,
162:3,11,
38:24
propriety
19 54:22
23 163:7
146:5
public
55:16
172:24
51:9
4:2 9`2'4
57:5
176:13
89:12
prosecute
104:18
47:2
10:19,21,
58:14
177:16,17
24 11:24
59:8
178:4,6,
163:18
Prosecuted
12:13,15,
60:1,2
21
187:18
46:3,12,
16 13:5,
61:10
179:15,20
purportedly
14
12,14,23
69:25
180:25
117:12
prosecution
14:12
71:8,20
181:5,6,8
purpose
18:13
15:1,15,
72:15,16,
182:1,6,9
77:16
122:8
24 16:20
24 73:7,
public's
134:17
17:11,14,
18 79:24
prosecutors
15 18:15,
84:6,22
70.4
purposes
46:8
18 19:3,
86:9,16
public-
7:6
protected
11,18,22,
91:14
operated
174:11
158:22
23 20:9,
94:14,18
23:19
pursue
protesting
11,13,16,
105:23
P ublicallY
111:2
17 21:1,
106:8,22
53:5
39:5
12,17
107:12
push
protestors
22:10,21
111:17,
publicly
158:5
37:16
23:11,18,
19,20
72:17
pushed
provide
25 24:1,
112:7,20,
125:22
158:6
22:16
7 9,11,15
21,24
published
59:6
26:13
113:21
94:17
put
27:10,12
114:5
7:24
167:3
28:20
116:2,6,
Publishers
10:23
174:1
29:22
9,14
140:3
12:8
provided
30:5,7,23
117:10,
141:25
25:11
131:18
33:3,6,7,
11,2542:23
publishing
133:18
15 34:8,
118:1
111:25
48:6
167:1,11
22 35:3,75:18
120:4,17,
174:23
20,24
19,21
Publix
94:15
178:11
36:2,4,22
121:6,16
39:6,8,
118:11
189:10
37:20,22
122:24
12,17
147:13
providing
38:1,2,
124:20
pull
151:2
178:15
18,24
125:23
82:23
185:23
39:8,14,
126:24
187:7
province
22 40:3,
128:16,25
pulled
190:19
144:13
12,18
130:18
185:18
putting
provision
41:8,13
134:6,18
pulling
41:19
59:24
42:2
139:9,14
148:9
66:10
46:4,6,19
140:22
78:5
C)ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
n
qualified
158:25
quality
49:21
61:9
71:13
113:18
question
5:4,22
10:5
27:6,9
38:22
78:4,7,8,
9,13,15,
19 79:2,
3,4 92:6
96:19,22
98:7,17,
22,24
99:5,8,
15,16
100:10,13
104:23,25
131:22
133:4,6,9
139:12
154:10
163:9
169:16
175:22,23
186:14
questioning
149:6
questions
4:24 5:2,
15 6:10,
18 91:25
92:17,20
102:17
132:3
139:17
180:14
quick
37:7
quiet
78:12
quit
21:22
23:5 24:8
110:2
118:9,20,
22 119:18
134:10
135:15
149:11
156:4
quota
135:4
136:4
quote
16:9
36:23
145:24
R
races
69:17
racist
137:24
racked
16:4
radio
45:8,10,
11,12,14
raise
39:8
132:23
raised
125:16
rally
11:10
121:10
ramificatio
ns
147:7
range
143:18
rapport
142:4
rare
22:6
59:10,12
153:24
rate
53:11
rationale
59:4
132:22
re -notice
184:4,5
re -read
7:4
reach
66:25
reached
55:4
170:10,13
171:15
reaching
63:3
read
6:25 7:2
13:9
15:22
44:1,3,15
174:20,22
readily
123:18
reading
12:17
13:16
February 24, 2016
Index: qualified -recall
101:21
175:1
ready
79:9,11
158:5
real
11:2
2 5: 13
26:5 41:7
54:10
56:22
69:4
71:24
73:4
100:3
140:20
147:8
149:15
169:3
reality
37:10
realize
16:16
18:18
22:13
realized
19:3 24:6
135:6
reared
129:24
reason
10:16
16:18,22
35:19,23
36:9
37:17,21
39:7
4 0: 13
53:13
61:5 70:5
76:8
94:20
115:9
150:5,6,
7,8
155:20
164:20,21
184:10
185:25
reasonable
59:24
68:23
128:10
reasons
38:7 54:2
56:24
71:6
94:12
125:18
128:12
129:17
135:16
161:6
172:23
181:7
recall
9:10
26:10,17,
25 29:21,
24 31:4
32:23
38:20
42:15
43:16,19,
20,22
44:3
48:12
50:3,4
55:2
63:25
65:5
75:14
84:7 90:4
95:23
96:13,22
101:13
103:16,20
108:19,20
138:21
4)ESQUIRE 800.211.DEPO (3376)
S o l Y T 10 N 5 EsquireSolutions.com
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: receipts.. reflected
139:16
100:23
11,21
71:8,20
179:15,20
141:2
138:13
17:2,10,
72:15,17,
180:25
144:20
191:9
12,14,15,
21,25
181:5,6,8
145:21
18,24
73:7,18
182:1,7,9
recognize
163:16
49:13,23
18:3,4,
79:25
rectified
168:2
12,15
84:6,23
101:3
126:13
170:13
19:3,12,
86:16
175:15,
150:3
18,22,23
94:14
red
173.9
18,23
20:2,9,
105:24
115:20
176:3
recollectio
11,13,17
106:17,21
redacted
179:22
n
21:1,12,
107:12
42:7
180:6
32:24
17 22:10,
111:15,
181:12
43:6
20 23:8,
16,20
redaction
182:1
44:5,18
11,25
112:7,20,
42:6
183:10,15
50:24
24:1,2,3,
24 113:21
reduced
186:1
55:17
7,9,11,15
115:25
20:21
187:2
62:5,11
26:13
116:7,10,
63:20
27:11,12
14
redundancy
receipts
83:7,12,
28:12,20
117:10,
64:22
104:19
13,24
29:22
11,25
reevaluate
receive
123:6
30:5,7,24
120:4,18,
24:5
51:19
150:16
33:3,7,15
19,21
129:14
record
34:8,13,
121:6,16
refer
7'21
received
5:6 16:14
16,18,22
122:24
51:18
103:20
86:9
35:3,18,
123:9
110:12
104:2
91:20
19,20,24,
124:5,20
127:15
99:4
25 36:4,
125:2,23
referal
100:7
8,23
126:4,24
51:20
receiving
106:8,23
37:20,22
127:4,6,
referrals
9:10
132:15,22
38:1,18,
7,8,14
109:11
103:16
159:11
24 39:1,
128:16,25
183:15
162:12
22 40:3,
129:15
referred
recent
174:2,3
12 41:8,
130:18
57:6,7
52:14
177;8
13,20,21
134:6,18
135:9
42:2,4,11
139:9,14
136:13,15
recently
records
46:19
140:22
180:4,7
11:14
9:2,4
47:9,21
142:4
referring
19:18
10:19,22,
51:2,17,
144:3
36:19
24 11:24
19 52:20,
161:23
17:15
40:11
12:13,15,
24 53:8,
162:3,6,
52:5
175:11
16 13:6,
9,19
11,23
109:4
receptionis
8,12,14,
55:16
163:7
111:4
166:16
t
17,23,24
57:5
172:24
120:7
14:8,12
58:15,24
176:13
reflect
15:1,15,
59:9 60:2
177:16,18
83:7
recess
19,24
61:10
178:5,6,
reflected
54:18
16:1,6,
69:25
21
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: reflects.. request
102:19
relating
62:13
removed
representat
reflects
83:3
remains
148:3
ion
101:17
Relations
165:17
164:7
19:8
8:21
remuneratio
20:12
refrain
remedial
134:12,14
34:10
20.4
n
representat
relationshi
115:25
9:11
ive
refresh
97.2
p
127:10
render
62:4
98:13
28:19
remember
177:21
130:8,9
refreshes
43:2,3,23
1
62:11,19
81:8,13
262
represented
re
1
118:14
refunded
83:17
27:14,15
158:17
24:11,16,
23:15
85:7
29:13
21,23,24
97:20
rental
25:2,4
refuse
110:12
31:17,21
118:12,15
87:11
98:23
115:10
32:5,19
155:2
89:15,23,
48:1,2,
refused
116:13
10,20
renting
24
85:15
151:22
50:8
118:12
107:11,25
113:15
186:10
52:17
151:24
repeat
166:5
refusing
relationshi
53:23
5:3 96:18
168:6,7
99:15,18
ps
55:19,22
100:7
51:24
64:7,8
repeatedly
representin
146:6
90:23
125:17
g
regard
157:6
93:9
137:8
25:3
149:17
release
109:21,24
repeating
52:6,16
regarded
157:1
120:15
79:6
148:1
12:20
158:7
123:15,16
153:22
138:20
report
t
154:3
registratio
releases
141:13
122:15
158:8
n
157:5
142:19,22
reporter
166:4,22
83:4
relevance
143:1
4:2,5,9
170:15
regular
92:3,9
163:22
5:12,21
represents
45:5
167:5
13:4
166:1
129:21
relevant
168:21
78:15
92:6,21
171:24
186:8
reputation
regularly
19:12
relief
178:25
reporters
107:15,24
28:7 57:2
66:11
181:11
13:3
request
rejected
relieved
182:20
184:14
12:16
71:9
76:6,13
186:3
1 5
57:
157:5
13:23
14:15
relate
religious
reminder
represent
15:15
9:5 92:17
10:25
5:12
4:18,23
17:8,12,
related
reluctant
57:24
14,16
142:7
remove
98:10
24:1,15
24:11
79:23
103:4
30:5
112:6
rely
162:11
146:22
33:15
ESQUIRE
800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: requested -retention
34:22
40:3 42:3
reservation
29:1
responsibil
35:3,15,
47:21
a
53:21
ity
24 36:10,
52:24
142:23
66:12,20
76:7
23 38:1,
53:9
122:17
112:3,19
reserve
4,18
69:25
165:22
114:24
60:6
40:12
71:3,8
184:18
169:23
41:8,14
72:15,17,
residence
185:13
responsible
61:8
22,25
6:7
respect
82:12
86:13
84:6,23
resign
24:14
105:24
112:20,
134:1
59:17
responsive
106:15
21,24
155:187:16
75.21
107:3,5,
113:1,2,3
127:5,8
6,8
116:7,10,
resignation
93:4
93:11
146:5
rest
113:22,25
15
129:23163:17
123:11
117:10,11
139:6
respond
124:12
118:1
154:20
53:8
169:8
130:18
120:4,18,
155:8,11
130:19
139:9
19,21resigned
186:24
restate
162:1
122:24
7;17
responded
103:19
172:24
123:9
129:25
109:13
restaurant
178:5
124:21
133:22
161:22
9:23
180:25
177:16,18
138:15
171:18
32:18
181:5
178:6
156:25
63:10
182:7
181:6,8
158:23
response
65:18
requested
182:1,10
16:14
69:9
resigning
36:24
106:22
required
138:17
37:22
restroom
184:7
19:19
52:24
6:1
96:14
resolve
requester
58:1
53:5 54:3
result
127:6
requirement
87:17
67:9,17
16:20
requests
103:3
115:24
68:13
51:11
12:15
144:17
147:12
86:12
113:20
13:6,13
requirement
173:11
109:12
116:25
16:21
a
118:21
127:1
resolved
119:4
19:2
96:23
58:3 68:1
131:25
resulted
21:17
requires
132:20
135:21
149:8
24:9,12
148:25
164:9
137:20
retained
27:11,12
29:22
rescind
resort
139:2
146:21
30:7
156:13,15
124:3
180:14
180:11
33:3,9
research
resource
responses
retainer
35:17,21,
9:2 19:19
112:17
5:21 33:9
150:7
23 36:8
22:1
122:9,11
responsibil
retaliation
37'22
38:24
reservation
resources
ities
92:1
39:1,22
143:9,10
16:2
146:20
retention
28:3,15
ESQUIRE
800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: retract..sausage
93:5
14 45:13
risotto
143:14
7,13,17,
48:3
32:19
19 109:22
retract
Rosa
156:13
55:25
River
36:25
110:8
56:3
137:10
revenue
66:19
130:5
Royce
145:13,
156:12
141:21
67:14
124:18
20,22
review
73:16
road
rules
147:3
33:9
86:2
52:14
125:3
148:4
113:14
88:10
Robert
150:3
149:19
129:14
89:1
4:18,23
164:15
180:21
144:15,21
91:15
95:24
Ryan's
111:10,13
97:23
run
148:5
reviewed
117:18
25:12
102:2,11,
7:1,2,5,
121:7,10
24
57:9 58:5
7,11 71:7
125:1
60:11
s
103:17,22
67:24
-
rich
136:24
116:22
140:18
Robinson
108:14
sad
171:2,3,9
129:18
122:5
Ring
159:15
123:24
31:2,15,
rocket
running
Richmond
16 38:16
79:25
64:20
sake
80:2,3
170:14,22
42:14,21
98:19
95:15
79:16
rode
131:24
salesman
RICO
80:6,25
65:16,17
158:3
21:19,20
92:13
83:14
162:19
49:10
172:22,25
88:2
rodeo
Russel
sandwich
173:16
89:8,23
129:18
81:1
32:6,7
175:19,25
104:22
Roeder
83:15,19
42:22
178:1,2
105:3,12
7:9 179:4
93:23
rid
108:18
180:2
104:15,20
Sarasota
169:1
145:12
183:9
155:17
13:5
155:8
186:8
85:20,22
ridiculous
156:2
188:1,7
Ryan
154:2
125:6
180:20
30:20,23
sat
riding
role
31:3,16
43:9,11
Ring's
111:8,10
32:17
57:4
61.847:11,12
rights
Rolle
38:1
54:9
rise
124:18
38:16
65:18
8:7,10,19
114:15
42:20
9:5,11,
room140:7
43:7,9
15,25
riser55:8
51:12,14,
147:18
10:1,7,
95:13
84:17
25 54:13,
163:13,19
10,11,14
risk
90:19
21 55:22
179:14
11:10
58:10
118:17
61:20
satisfy
27:23
153:4
137:7,15
62:9,17
184:23
34:4
186:7
77:7
185:14
37:11,12,
risks
87:4,10,
18 43:13,
59822
rooms
25 88:5,
sausage
ESQUIRE 800.211.DEPO (3376)
6 O l U T 1 0 N 5 EsquireSolutions.com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
152:3
scale
4 0: 4
scanner
155:5
scenes
71:2
schedule
48:23
91:23
scheduled
12:19
14:16
scheduling
163:18
187:3,5,
18
school
13:19,20
14:7,18
16:21
17:1,4,8,
14,20,21,
23 18:9,
14,23
20:7 21:2
52:10,14
112:17
122:8,10,
11 138:3
science
98:20
scientist
79:25
Scott
4:17
122:3
Scratch
139:19
screw
70:11
122:18
screwed
23:12
screwing
165:14
scrupulous
151:17
scrutinizin
g
38:4
seal
14:10
seat
13:11
seconds
77:17,24
78:12
107:6
secretary
155:18
secure
3 7: 11
seeking
34:24
97:3,13,
20
self -
unemployed
8:3,4
sell
21:23
22:3
105:17,18
106:9,12
selling
16:23
sells
22:7
semester
106:7
semi
117:17
seminar
11:15
140:12,
14,15,17,
21 14 1: 3
179:20
seminar -
type
53:15
seminars
139:10,14
Senate
140:7
a end
13:3,4
86:14
106:5
108:7,13
120:20
151:25
156:9
190:15
sending
11:7
117:25
121:12
135:3
136:17
157:25
158:7
senile
117:17
senior
19:10
sense
8:2
27:15,19,
25 31:20
48:22
51:7 52:1
54:6 56:4
67:10
89:17,22
114:2
157:18
sentence
27:4
separate
41:13
98:6
156:7
separately
107:12
September
182:2
series
4:24
16:20
112:6
serve
17:22
70:21
108:10
served
183:19
service
68:9
services
59:7
set
55:15
56:17
103:12
setting
53:15,16
103:22
163:2
settle
115:22,23
131:5
153:10
settled
February 24, 2016
Index: scale -shared
20:1
115:19,
20,21
142:24
151:8,9
settlement
57:14
114:23
115:17
127:2,22
128:8
133:14
137:17
150:17,
19,23
151:11
152:14,23
178:16,18
settlements
115:4
126:16,19
127:2
128:5
129:12
146:4
152:13,20
settling
125:11
129:20
sexual
122:12
shape
187:14
share
72:2,11
145:15
162:9
182:24
shared
43:16
88:19
95:5
145:19
147:15
C)ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
176:8
shed
106:25
sheer
13:10
35:23
Sheila
79:11
95:6
sheriff
11:6,7
121:12
sheriff's
28:16,17
sheriffs
11:17
shit
118:5,6,8
119:18
122:2
123:8
124:19
12 5: 4
157:17
168:10
184:24
185:11,18
186:11
188:18
shitty
123:17
shocked
21:10
22:20
182:5
shocking
16:12
46:21
135:21
shoes
105:16
106:21
shop
55:15
short
50:9 64:1
show
45:8,10,
11,12
4 9: 4
75:15
82:15
133:8
140:22
143:16
166:10
174:10
183:23
185:5
191:1
showed
143:13
159:5
shown
62:14
sick
184:24
side
51:21
57:21
89:18
96:10
110:10
111:13
157:15
162:25
173:8
sidekick
187:17
sides
19:13
124:23
159:19
sign
13:21
86:11
113:14
169:22
181:20
sign -in
86:9
signature
101:11,12
113:16
144:18
145:1
significant
35:7
41:22
167:16
signing
114:9
silent
77:15
silliness
150:2
silver
149:22
similar
12:5
107:5,7
129:18
similarly
35:14
180:16
simple
41:8
simpler
98:2
simply
52:19
59:19
155:20
sin
47:6
February 24, 2016
Index: shed..Sopranos
single
3 0: 8 92:5
101:21
168:4
sister
130:15
187:10
sit
95:18
103:6,11
128:25
174:20
sitting
69:14
96:2
142:1,22
situated
35:14
180:16
situations
12:6
skirting
42:10
eland
163:23
slander
91:25
92:6
161:5,17
163:11,24
165:19
slice
174:4,9
slightly
119:11
120:1
slippery
38:5
slope
38:5
small
9:19,22
42:2
smart
65:8
159:22
smoking
86:5,19
so-and-so
130:15,
16,24
social
10:12
11:1
2 9: 12
107:12
socially
14:21
software
7:24
sole
70:20
solely
104:11
146:20
solution
59:1
somebody's
34:5
47:17
73:4
son
67:19
110:6
116:23
165:1
sophisticat
ed
116:16
Sopranos
173:1
178:1
O ESQUIRE 800.211.DEPO (3376)
EsquireSol utions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: Soria -state
Soria
171:12
35:18
spoke
106:20
4:1
sounded
188:24
47:24
107:7
sort
55:14
specificall
62:20
132:4,16
137:16
10:2294:9
soundingY
138'22
13:18
101:24
star
153:4
145:18
14:11
105:13
133:8
16:8 19:1
sounds
145:21
182:14
20:4,7
39:16
182:3,19
spoken
start
38:4
24:5
97:5
Specifics
62:6,12
78:25
26:10,12
source
66:1
sponsored
80:4 85:2
33:25
28:7
140:5
113:11
37:5 40:7
189:4
speculate
130:14
48:3
64:17
spot
163:7
50:10
sources
175:17
78:5 91:9
51:15,16
141:21
172:13
spell
spouse
190:10
52:2 54:6
South
86:1
46:2
60:14
25:1 26:3
started
65:14
48:1
spend
spread
19:1,2
67:9 72:6
84:10
32:3
31:22
21:16,22
77:10
87:6 90:9
60:9,12,
spurs
23:10,25
82:7
94:12,21,
15 122:6
58:1
24:4,8
85:11
25 105:16
185:13
27:9
93:16
106:11
189:6
SPY
52:22
95:2011:8
189:7
spending
53:6
99:4
159:24
Squeaky
68:10
104:20
space
164:17
79:8
105:19
90:16,18,
spent
80:11
112:18
21
16:3
stack
83:23
113:13
speak
21:18
120:8
84:4,6,20
118:3
4:19 27:3
32'2'4
stacks
135:2,3
128:24
172:5
45:23
120:9,18
145:10
142:6
46:8 47:8
156:3,9
speaker
76:15
staff
149:20
140:6
112:14
9:2 91:4
starting
161:24
147:18
142:9atam
67:20
173:17
p
78:8 94:4
aorta
speaking
spigot
73'21
136:8
105:18
10:3,10,
119:3
stand
179:13
12 99:3
spite
119:12
state
134:12,14
4:2 5:6
soul
179:16
123'22
standards
10:11
9:22
147:25
114:12,15
11:9
special
165:5
123:18
12:24
sound
40:15
30:3,11
splitting
standing
14:3,5
129:22
17'8
91:18
153:19
53:24
124:3
specific
spoiled
92:3
19: 9,23
137:23
34:23
151:14
105:16
20:1144
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. corn
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
22:13,14,
15,19,22
23:2 28:8
33:4,16
34:2
38:19,25
47:20,22
53:6
67:13,16
71:8
102:4
106:21
121:8,9
122:8
126:23
128:3
130:3
142:2
181:8
stated
137:8
statement
7:4,7
64:15
103:9,12
163:20
174:1,6,
15 175:3,
8
statements
92:8,11
125:13
129:16
152:17
178:16
states
12:21
21:24,25
65:6,9
stating
128:9
132:15
stature
107:16
status
96:7
statute
39:16
60:24
statutory
15:21,23
stay
42:24,25
84:11
142:21
164:7
stayed
77:13
79:10,13
84:2,19
85:22
95:2,11,
12
staying
64:4
142:24,25
steal
82:9
stealing
129:22,23
step
59:12
170:3
stepped
148:4
155:17
Stevens
32:11,12
sticking
93:6,7
146:12
stipulated
164:6
stocked
43:10
55:24
stockholder
39:17
stolen
23:15
stop
48:4
109:14
119:19
125:7
157:19
162:24
stopped
48:6
stops
118:9
162:19
store
105:17,20
106:7
Stores
105:15
stories
13:6
28:7,9
story
143:11,15
163:20
straight
14:1,2
118:24
119:16
164:14,15
strategies
20:16
57:15
137:17
straw
133:22
Stream
30:1,5
February 24, 2016
Index: stated -subsequent
53:2
87:12,15
88:3
89:15
92:2
117:12
120:23,
24,25
121:1,3,
17,23,25
122:18
123:7,10,
14
124:11,20
126:15
145:6,8
157:17
161:25
178:7
181:1
182:2,10
Street
6:5
strengtheni
ng
70:3
strike
82:4
139:7
strongly
69:8
struck
82:5
131:10
student
67:15
91:16
105:24
138:4
students
106:10
stuff
23:1
25:13
31:19
32:25
33:2
70:24
82:23
116:21
120:10
121:6,7,
16 122:13
155:4,5,
15 158:4
161:18
169:16
172:12
173:2
182:19
185:8
186:2
187:1,5,
18 189:5
stunt
148:9
stupid
125:4
subject
15:18
53:7
126:24
submitted
104:19
subpoena
183:15,
17,19
184:3,4
190:11,15
191:3
subsequent
23:2 44:2
50:9
61:21
94:6
107:9
ESQUI 10E Esqu �eSo��ons.com)
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: subsequently -talk
subsequentl
suggestion
support
surprising
-
y
79:20
141:16
37:7
T
143:6
140:5
158:15
surrounding
171:17
169:10
supported
33:15
T-shirts
substance
suggestions
141:19
44:22
105:18
50:14
69:1
suppose
suspect
table
51:7,8,11
93:20
34:6
185:2
29:7
substantive
suit
39:7,11
31:22
swallow
26:12
33:13
58:14
47:11
5.2
successful
124:7
supposed
66:10
163:11,23
swear
76:13
20:21
13:8,25
166:1
4:5
133:18
36:21
18:24
175:19
101:15
140:5,6,8
136:23
40:17
suits
41:9
sweet
141:6
sudden
143:22,
80:18
79:13
185:24
110:8
24,25
113:7,8,9
120:6
tactics
158:21
144:4,25
134:6
Sweetapple
59:25
suddenly
145:3,5
137:14
4:18,23
tail
66:9
summary
138:9
7:5 32:15
171:21
sue
46:25
142:19
131:19
17:17
150:11
161:19
takes
119:9,10
summons
151:1
163:12
67:9,17
127:11
66:9
166:11
167:12
68:11
163:24
Sunbiz
183:18
171:2,15,
131:13
82:23
supposedly
23 172:3
184:20,21
sued
83:3,10
46:15
173:23
taking
16:3
17:10
Sunday
Supreme
p
178:22
22:8 25:6
189:22
26:7
23:13
42:19
128:4
190:13
36:21
87:15
84:15
supremely
55:23
121:18
Sweetapple
sunshine
61:11
58:11
125:23
s
12:18
59:22
147:10
111:22
surprise
132:14
158:9
21:15
60:20
127:13
swinging
115:25
suggested
141:20
27:13
119:9
173:10
38:21
11:10
super
44:9,10
sworn
talents
19:15
79:13
182:4
4:12 7:4,
121:21
68:24
82:1
7 163:19
69:1
surprised
talk
142:13
Superintend
30:4
,
15
5:16 12:7
17;:
15 175:3,
165:9
ant
38:21
37:23
8 188:15
14:18
170:19
48:22
suggesting
128:9
supplied
182:4,12,
system
51:4
141:15
122:9
13
119:25
61:24
63:6
ESQUIRE 800.211.DEPO (3376)
11 7EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: talked -things
121:9
45:23
126:3
terminate
188:15
131:16
48:16
technically
53:10
textbooks
133:7
56:8
81:12
terminated
106:10,12
142:17
59:10
137:10
149:8,10
147:18
67:13
thankfully
146:17
154:14,18
72:19
terms
61:15
155:14
77:21
tecum
9:25 10:6
87:17
179:11
78:5,22
187:17
38:18
110:11
180:20
91:11
teeth
52'4
thin g
181:16,20
98:19
157:19
75:18
9:9 13:20
191:7
109:17
85:12,13
15:13
142:22
telephone
96;23
talked
31:1337:20
153:16
52:2 55:2
139:9
40:20
167'7'9'
102:23
149:11
43:11
117:11
46:17
48:14
10,21,22
Terrell
52:2 69:6
52:4
168:1
telling
84:10,12,
70:25
55:24
Tallahassee
53:18
20,25
74:7 78:2
62:23
140:1,11
105:3
85:6
84:4
63:14
142:10
109:24
terrible
104:20
65:19
128:14,15
105:19
67:20
Tampa
129:21
160:19
107:1
68:25
13:5
135:3
176:24
112:18
69:9
53:24
137:2
terribly
115:9
79'22
105:21
157:21,22
52:7
117:20
81:20
107:18
186:2
territory
121:24
84:18
122:10
190:15
96:8,9
125:2
90:3
tangled
tells
127:20,24
95:10
158:15
67:4
testified
135:1,20
96:3
tax
109:10
4:13
136:8,17
130:24
49:23
139:24
133:12
31:19,21
template
56:16
140:13
135:16
32:24
131:11,12
72:10
142:5
142:20
33:2 96:5
tea
147:1,2
149:12
97:20
17:10
143:1
143:17
150:18
161:20
102:24
127:9
144:20
151:2
163:15
147:10
159: 18
152:6
165:9
Taylor
tend
173:25
156:5
170:14,16
131:15
5:2 6:10
175:11
159:20
172:6
133:12
tens
testify
160:19
176:7
136:1
16:5
132:17
162:4
179:9
145:13
22:25
165:12
182:17
156:10
testifying
176:13
terabit
175:18,24
182:21
talking
tea
168:2
17:23
76:5
testimony
185:23
28:25terabytes
4:6 174:8
things
technical
184:21
175:2,7
41:9,10
72:20
13:1 19:3
4)ES QUIRE
800.211.DEPO (3376)
L U. 1 0 N S
EsquireSolutions.com
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: thinking -times
22:21
25:9,12
threat
26:7,14
141:15
34:3
107:11,
156:24
28:5
143:19,25
57:22
15,25
164:24
31:3,15,
145:9
63:14
111:3
165:18
16,24
151:15
65:24
115:10
33:1,14
154:4
threaten
69:4,9,16
138:24
34:2
159:24
156:19,20
70:4
148:8
40:17
163:14
160:22
74:16
151:14,
41:22
165:9
96:11,14
19,23
threatened
43:1,15
172:7
103:22
109:15
47:8,24
179:19,24
thoroughfar
105:4,18
158:6
48:5,14,
181:25
109:18
es
163:23
15,24
182:14,
39:14
112:15
170:9
51:23
17,18
117:22
thought
threatening
53:4
183:5,13
120:19
26:6
109:14
54:25
186:18
125:24
54:10
159:10
56:10
189:6
126:6
70:6,16
168:23
58:13
timeframe
127:3
71:5 72:4
59:15
134:1
98:15
threats
62:20
139:22
137:6
107:18,23
108:7
63:7
timeline
140:14
108:1
159:8
64:25
7:5,11,
146:2
125:17
throat
66:17
12,13,25
147:7,12,
141:22
58:16
67:8,17,
31:19
14
147:20,22
23 77:11,
49:5,16
148:17,25
156:11
throats
22 81:15
77:3
149:6
170:17,18
169:8
89:23
78:22
150:24
171:21
throw
91:10
108:23
152:9
172:21,22
119:13,23
94:9
109:2,3,4
155:23
176:5,17
95:16
110:21
157:14
183:3
throwing
97'7
110:14
times
158:18
185:5
103:7
9:12,23
163:15
190:3,4
thunderbolt
104:3,17
12:12
165:6,8
thoughtful
184:23
105:7
30:8,15
176:16,22
157:12
Thursday
107:6,10
35:20
177:14,
45:11
109:5
36:9
19,22
thousands
h
110:21
16:5
46:9
55:19
191:1
111:17
57:2
17:19
time
112:14
thinking
61:25
22:25
5:25
118:13
14:3
23:8,9
8:14,17
120:2,7
62:1,5,12
48:20
81:21,22
124:20
11:20
122:6
67:15
167:22,23
12:3
127:22
19
110:4
168:1
14:17
129:15
149:13
149:1
123:16
178:6
15:18
156:21
132:19
159:6
Thomas
threads
16:2,13
133:7,8
163:1
19:7,10
18:13
20:14
136:11
166:6
24:20
23:17
139:13
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: tiny..turned
172:5,6
134:24
touchy
14:12
true
181:7
136:3
184:17
111:11
35:16,21
tiny
141:11
town
117:6
36:16
40:24
149:6
29:25
transparent
37:20
53:19
156:12,
30:1,12
117:5,7
75:9
121:25
17,19,20
38:2,25
125:19,20
86:22
160:21
92:11
123:25
39:21
151:13
162:5
103:9,13
today
163:20
40:3,12,
transpired
143:15
4:245:13
169:20
24 4 :2,
72:7
150:10
6:222
183:6
18 477:1
53:2
travel
160:14,17
52:20
tolerance
87:18
62:24
163:3
53:1,12
68:7
95:12
66:5
172:18
92:19
74:23
121:25
67:11
175:3,8
98:11
99:23
115:13
145:6,7
travelled
trust
103:6,11
toll
173:14
95:9
119:22
114:17
109:11
178:6
151:19,
181:1
treat
20,21
132:17
162:19
11:4
135:19
182:2,10
152:3
163:21
tone
toy
treated
trustee
166:22
118:19
117:9
11:3 13:7
164:2
175:6
top
24:6
183:16
8:18
toyed
37:15
trustworthy
184:5,8
24:19
69:12
43:21
157:16
88:15
track
44:9,11
truth
toe -to -toe
120:16
183:22
47:20
4:6,7
119:8
138:23
traditional
trick
92:8
told
topica
8:2
4:25
163:21
14:7
26:22
186:2,3,6
15:19
trail
trigger
21:15
Toracco
6:10
124:4
truthful
22:23
138:25
training
trip
115:15
41:2 75:5
total
111:20
118:16
Tuesday
80:8 85:5
21:3
127:13
187:11
98:15
trouble
31:13
130:22
65:9
turn
105:10
106:13
76:10
transcript
96:12
89:5
108:5,10,
136:12
7:2 79:5
164:15
119:2
12,17
totality
98:14
186:1
turned
109:12,
177:25
174:16,23
troubling
43:8
23,24
totally
transmittin
15:3
46:16
110:1,870:17
76`9
g
124:15
119:24
122:25
truck
107:2
130:25
155:7
155:2
131:6,10,
touching
transparenc
185:5
168:23
17 133:12
40:10
y
189:2
O ESQUIRE 800.211.DEPO (3376)
EsquireSol utions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
turns
55:1
16:19
58:24
51:9
60:20
120:17
63:3
130:11,12
69:14
76:2 85:2
Tweel
99:10
U
93:20
95:24
undercover
UCC
94:17
96:4,23
11:8
22:14
110:4,6
97:3,14,
121:12
ugly
129:24
23 102:2,
underlying
71:11
136:13
5,11,24,
162:3
129:24
150:9
25
178:3
155:15
151:11
103:17,22
understand
97:25
161:22
tying
176:6
186:18
10:21
189:4
unanimous
115:1
135:21
type
15:21
20:3
unbeknownst
10:1,7
72:14
46:21
116:9
12:10
96:4
35:3
unbelievabl
112:8
e
ESQUIRE
97:18
84:24
types
115:14
54:22
uncharted
typically
96'8'9
34:21
uncomfortab
le
178:2,3
99:10
U
154:11,13
190:22,24
undercover
UCC
115:5
understandi
11:8
22:14
United
45:3 65:3
121:12
ugly
12:21
74:24
underlying
71:11
21:24
75:11,14,
162:3
129:24
Universal
21 83:16,
178:3
155:15
university
187:10
understand
97:25
5:1,24
ultimate
111:8
10:21
88:18
14:14
115:1
14:24
ultimately
15:21
20:3
58:12,20
39:23
72:14
46:21
74:20
54:12
96:4
ESQUIRE
97:18
unilateral
111:14
115:14
132:22
unilaterall
138:2
y
178:2,3
53:10
190:22,24
115:5
understandi
148:6
ng
United
45:3 65:3
12:21
74:24
21:24
75:11,14,
16 76:17,
Universal
21 83:16,
22:15
22 89:8,
university
10 93:17
105:16
97:25
106:10,11
105:2
111:8
unlawful
114:21
14:14
115:1
52:24
134:17,20
unlicensed
138:10
135:12
141:11
157:22
143:5,8
177:4,15
166:18,21
178:12
180:4
unlimited
understands
76:11
58:23
174:8
unnamed
161:9
understood
60:20
unpleasantn
61:19
ess
67:19
156:18,22
88:6
unsavory
120:3
11:13
166:23
unusual
unemployed
130:10
118:18
upcoming
unethical
106:7
115:15
upheld
unfairly
176:11
47:20
UPL
unfortunate
180:12
148:13
February 24, 2016
ndex: turns..verified
upset
58:7
urging
140:9
USB3
184:22
utter
143:15
utterly
76:9
119:24
V
vague
33:21
167:14
vaguely
49:14
variety
103:3
vast
25:15
46:1 59:8
121:2
veal
63:11
vehemently
173:13
vendetta
121:22
verbal
5:22
verbally
61:22
133:25
verified
113:12
114:2
144:17
800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: verify -weeks
verify
67:25
116:12
40:13,14,
82:8
144:22
71:19
Volvo
15,25
118:21,22
version
72:20
155:3
48:9,22,
119:7
86:16
23 63:5
130:21
159:7
94:14
vouch
69:6,7,11
173:1
versus
124:1
101:7,20
71:3,4,25
,Hatching
73:11
violence
vulnerable
72:3
178:1
153:16
39:14
22:2
84:13
vexatious
85:14
wavelength
Virginia
87:1
147:4
160:10,11
96:5
W
93:12
waving
vibe
102:24
105:14
73:9
95:1
virtually
wait
108:4
115:23
videos
46:7
5:14,16
112:1,7,
94:18
162:24
25
wayswaited
113:11,19
141:19
view
181:8
15:11
114:19
156:8
24:5
visit
158:25
122;6
wealthy
36:22
11:21
waiting
129:17
67:4
37:14
48:23
31:5
136:21
82:8
55:21weapon
45:21
141:16
134:4,5
71:7
144:17,21
160:8
views
181:22
waive
146:19,20
web
132:13
36:17
visited
147:15,19
19:20
13:11
waived
152:6,18
vindicated
website
g0:2
133:1
155:20
58:17
130:21
156:13
127:18walk
visitor
160:20
Wednesday
vindictive
86:9
40:21
169:25
84:1
160:20,21
59:1
visualize
wanting
week
violate
7:25
walked
100:1
12:19
37:2
99:1
vivid
147:10
54:9 57:3
violating
67:3
walks
184:24
130:1
86:11
135:4154:2
39:15
vividly
Wantman
135:10
32:5
wall
170:15,23
142:19
135:14
158:1
violation
warm
166:3
138:4
15:1
vociferous
149:17
18:15165:6
walls
159:23
weekend
115:14
36:13
84:7,8
Volume
warned
126:2,3,
191:11,12
wanted
119:18
weeks
25 146:18
12:1
133:24
11:16
177:1
voluntary
13:23,24
14:19
violations
153:13
15:6
wash
30:18
52:19
163:14
22:19
146:19
31:23
53:3
volunteers
36:2
watch
90:25
ESQUIRE 800.211.DEPO (3376)
5 0 L U 1 1 0 N 5 Esquire Solutions.com
JOEL CHANDLER Volume 1 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: Weidner -working
134:25
wife
161:13
174:21
158:16,20
135:14
48:1,5
177:15
166:17
words
140:16
77:14
wishes
5:3
169:9
157:14
84:12
179:5,25
87:3
149:24
Weidner
95'6'7
126:17
178:25
188:4
142:8,24
189:22
25:4
159:9
wishing
work
191:4,5
welcomed
164:23
48:18
8:8,16,23
worked
70:22
49:25
9:716
Wild
8:20
Wells
84:23
Witmer
10:,
9:14,21
11: 11,, 15
170:16,
94:13
30:21
10:14,17,
12:9 23:6
23,24
38:16
25 21:21
willfully
28:13
171:4,8
42:14
34:9,13,
16:17
39:24
West
51:12
45:4 52:4
14,15
William
54:13,21
35:17
26:
60:7 63:8
84:2233
81:8
61:20
65:24,25
42:18
94:13
83:14
62:17
66:21,23
81:10,12,
96:5
105:3
109:13
67:24
14 83:18
102:24
willingness
145:13,20
68:24
85:15
35:11
180:21
71:14
87:10,25
Western
155:22
witnesses
72:11
89:1 90:8
142:24
106:1
46:18
74:5,10
whatsoever
win
80:9,13
113:2
116:13
61:5
woman
115:8
187:5
123:19
14:17
83:21
120:13
47:6
84:3,18
whey
windfall
85:4. ,6,21
138:2
128:14
85:18
148:14
150:6
106:1,13
8621
158:19
whiff
winning
87:1
182:22
85:19
won
89:20
71:15
17:11
90:24
workers
188:18
winnow
19:5
91:12,13
39:5,10
white
71:14
wonderful
94:1,4
working
107:20
wins
79:12
112:8
23:5
Whitehouse
119:7
114:18
118:2
30:21,24
120:11
154:5
winsome
wood
63:24
122:15,23
Whites
106:25
124:6
64:2,9
159:
159.22
77.7
45:22
Woolworth's
130:25
80:11
Whitmer
Winter
37:2
137:1
81:13
45:6
138:9
145:22
word
85:2,17
84:13
141:18
whore
85:9
8:2 14:23
146:14,
97:2
134:5
28:2 47:2
16,25
1 22:
122:6
wire
87:2
129:4
widely
117:10,25
101:6,7,
148:5
140:16
12:20
123:1151:1
21 129:22
183:12
155:23
ESQUIRE 800.211.DEPO (33 76)
EsquireSolutions. com
JOEL CHANDLER Volume 1 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: works..Zollo
works
133:25
138:6
22:9
189:18
141:16
89:11
written
151:24
93:15
119:17
York
119:25
144:11
31:4
130:12
138:1,8
wrong
you -all
174:19
84:1
18:10
89:7,21
world
Young
117:3
24:5
65:5
128:1130:20
32:14
73:15
37:14
74:17
160:20173:10
130:12
106:13
172:11
121:8
wrote
worry
Youtube
16:5
66:10
12:8
102:8,10
70:23
131:12
76:14,16
Z
worse
122:19
Y
Z -o-1-1-0
worth
85:19
year
26:7
12:17,22
zigzagging
71:18
15:11
67:15
73:2
25:23
zip
worthy
46:9
133:10
33:11
48:18
71:10
49:25
Zollo
50:5 51:5
85:19
wrangling
66:4
90:24
60:13
68:18,23
112:5
wrapped
69:2,16
121:20
74:23
wrinkle
118:20
186:10
124:16,17
128:25
write
140:2
12:24
164:21
13:6
59:16
Years
112:10
12:22
13:10
writing
21:18,19,
13:23
20 23:10
14:16
35:22
86:13
114:14,16
ESQUIRE 800.211.DEPO (3376)
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