HomeMy Public PortalAboutChandler Transcript pt 2 - 2/24/161
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JOEL CHANDLER Volume 2 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
196
DEPOSITION OF JOEL CHANDLER
Taken By Counsel for Defendant, Sweetapple
Volume 2 of 2
(Pages 196-260)
Wednesday, February 24, 2016
4:50 p.m. - 6:18 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 2 of 2
OBOYLE -vs- SWEETAPPLE
DANIEL DESOUZA, ESQUIRE
DeSouza Law, PA
1515 North University Drive, Suite 209
Coral Springs, Florida 33071
954.780.8262
February 24, 2016
197
On Behalf of Plaintiff
(Appeared via telephone conference call)
JOSHUA A. GOLDSTEIN, ESQUIRE
Cole, Scott & Kissane, PA
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
561.383.9200
On Behalf of Defendant, Sweetapple
HUDSON C. GILL, ESQUIRE
Johnson, Anselmo, Murdoch, Burke, Piper & Hochman, PA
2455 East Sunrise Boulevard, Suite 1000
Fort Lauderdale, Florida 33304
954.463.0100
On Behalf of Defendant, The Town of Gulf Stream
LOUIS ROEDER, III
Law Office of Louis Roeder
7414 Sparkling Lake Road
Orlando, Florida 32819
407.352.4194
On Behalf of Chris O'Hare
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
VOLUME 2 INDEX
February 24, 2016
198
WITNESS PAGE
JOEL CHANDLER
Direct Examination by Mr. Gill..................199
Cross -Examination by Mr. DeSouza................228
Errata Sheet....................................256
Certificate of Reporter .........................259
Certificate of Oath.............................260
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 199
BY MR. GILL:
Q. Afternoon, Mr. Chandler. My name is Hudson Gill.
I represent the Town of Gulf Stream. I have a few
questions for you. I will try to be as brief as
possible, given the time?
A. Fire away.
Q. First of all, let's talk about the contact you
had with employees of the Town of Golf Stream. I know
there was some public records mentioned. Outside of
those, have you had any contact with employees of the
Town of Gulf Stream?
A. Yes.
Q. Okay. What employees have you had contact with?
A. One was a police officer. I have had two
contacts with police officers, Town of Gulf Stream. One
was a very cordial interchange with a gentleman. I went
to the Town of Gulf Stream early in the morning to
attend a public meeting. I got there early and was kind
of hanging out. He stopped to see what I was doing. He
was very nice. It was a nonevent.
The earlier experience I had was really
troubling. I had two very good friends of mine, who
were African-Americans, with me. And we were doing a
social experiment going down the east coast of Florida.
We started in Palm Beach and worked our way all the way
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February 24, 2016
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1
down to somewhere --
I think
Miami. And they would go
2
in and make a public
records
requests. And these guys,
3
neither one of them
have ever
been arrested. They have
4 no criminal history. They're both college graduates.
5 They're both gainfully employed.
6 Q. Before you go on, can I ask you when this
7 approximately occurred?
8 A. Before I went to work for the foundation, so
9
2013. The
most -- these guys
are total straight arrows.
10
They don't
cuss, drink, chase
woman, they don't smoke.
11
They're as
straight arrows as
you can imagine. Very
12
articulate,
but when they want
to they can kind of come
13 across like they're from the hood; not in any kind of a
14 bad way, just dialect; right?
15 So we started in Palm Beach, and Ocean Ridge, and
16 every little town going down the east coast, and they
17 would go in and make a public records request, and a few
18 days later I would double back and make a public records
19 request. The social experiment was would
20 African-Americans be treated differently than a White
21 guy, especially a White guy all these towns know.
22 Believe it or not, I have actually been into some
23 public agencies and seen my photograph taped up at the
24 front desk like be on the lookout, kind of thing.
25 So to try to make this experiment as legitimate
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1 as possible, I would -- it's Tilex and Terrell, Terrell
2 who ultimately came to work a couple days at the
3 foundation. So I would drop them off. They would go
4 and make their public records requests, and then go back
5 out on AlA, and they would walk a couple blocks, I would
6 stop and pick them up, and we would go on to the next
7 place.
8 We did that at Gulf Stream, and as I was waiting
9 for them, I saw a police car come out of the town -- of
10 the police department, and go down, and make a U-turn,
11 and stop where he was facing me. And so I would kind of
12 cruise back and forth waiting for them to come out, and
13 Tilex and Terrell, these two Black guys, come out, start
14 walking down the street. And I legally pull over, they
15 get in the car, and we go down the street. And I didn't
16 go 200 yards before I got pulled over.
17 And the police officer does the whole, "give me
18 your driver's license," and whatever. I handed it to
19 him. He went back, ran my information through David,
20 handed my driver's license back, called me by name, told
21 me have a nice day, which I very much took as we just
22 wanted to know who it was that was making those public
23 records requests, which I found very, very troubling.
24 That was the only city that did that.
25 So those are two employees I have had contact
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1 with. I talked to Bill Thrasher, is the City Manager;
2 right?
3 Q. Yes.
4 A. I talked to him very briefly one day when I was
5 out there going into a meeting. The city clerk -- what
6 is her name, the older lady? I talked to her when I
7 made a public records request. That's the one I ended
8 up litigating. I have had a conversation briefly with
9 Scott Morgan by the telephone, just sort of wasn't any
10 substance to it. I don't know that I -- I don't recall
11 any other contact with city employees.
12 Q. With respect to the conversation with Bill
13 Thrasher, when did that take place?
14 A. That took place during my tenure with Citizens
15 Awareness Foundation. It was the same morning I spoke
16 to the police officer that talked to me in the parking
17 lot. Again, he did not do anything he shouldn't have
18 been doing. He was being cordial, the police officer
19 was. I saw Bill Thrasher going into the meeting, and
20 shook hands with him, and it was just kind of a pleasant
21 exchange.
22 I think at some point, I believe that I actually
23 sent an e-mail to Gulf Stream offering to work with them
24 to try to resolve any public records struggles they
25 might be having; not to offer legal advice, of course,
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1 but just -- the way I present this to agencies is I can
2 -- if I'm talking to your attorney, I would be happy to
3 give your attorney some legal advice, but I can't give
4 anybody else legal advice. But I can share with you
5 what my experiences have been, in my experience, what
6 triggers litigation, and as an advocate, what I think
7 would probably be the best strategy for avoiding
8 litigation, and ideas about how to respond better to
9 public records requests, not only to avoid litigation,
10 but to improve transparency.
11 I actually talked to Marty about that, and Marty
12 poo-pooed the idea, like you're wasting your time, why
13 bother. My argument was isn't that what we are supposed
14 to be doing? If we are really going to be advocates for
15 open government, we can't just be suing people, which is
16 why, for example, I have done this seminar in Levy
17 County, where I talk to public officials about how to
18 avoid litigation, and how they shouldn't interact with
19 activists, and how not to end up on YouTube.
20 So that was -- I'm pretty sure I actually sent an
21 e-mail to Bill about that, if I'm not mistaken. You
22 could make a public records request to find out.
23 Q. With respect to your conversation with Bill, did
24 he mention Martin O'Boyle?
25 A. I don't think so. Our exchange -- he was very --
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1 I was -- I was surprised, frankly. He was very cordial.
2 I don't know what I was expecting, but he was very
3 polite, very civil. And I actually have a very warm
4 regard for Gulf Stream. I feel sorry for them in that I
5 think they have really struggled with how to wrap their
6 arms around dealing with public records requests.
7 And I'm happy to say this to you and on the
8 record: I have been contacted -- I wish it happened
9 more often, but I am contacted by public agencies asking
10 for help. I'm even, every now and then, contacted by
11 government contractors asking for help. And I think
12 it's noteworthy that I am unaware of a single instance
13 where an entity that is subject to the public records
14 act, that has contacted me asking for my help, has ever
15 been sued by me subsequent to that, or by anybody else,
16 over public records violation.
17 I can't say that I would be willing to offer
18 absolute immunity. But I can tell you what I have told
19 other public officials, and that is if we have a
20 dialogue, and I feel like there is somebody I can call
21 and talk to, to try to work things out, I would much,
22 much rather do that. I would much rather be viewed as a
23 resource than an adversary. Any day of the week I would
24 be happy to do that.
25 Q. You also mentioned you spoke to the clerk when
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JOEL CHANDLER Volume 2 of 2
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you made your public records request. Was Martin
O'Boyle brought up during that discussion?
A. He was there.
Q. What do you recall the clerk saying, if anything?
A. She was kind of snippy with me. I asked -- I
can't remember what record it was I asked for, but it
was something that was on an 11 by 17, the original
document. And she said she was going to impose a
special service charge which is provided for or
contemplated in 119.07(4) from the very first minute,
that if it took her a second to do it, she was going to
charge me for the labor. And I told her that was not
lawful, and she did it anyway, and I sued.
Q. Anything else from that conversation?
A. I mean, it wasn't ugly. And anybody that wants
to look, there are dozens, scores of videos on my
YouTube channel where you can see what it looks like
when I make a public records request.
Q. I'm just trying to understand specific to this
conversation.
A. I just want to be clear that unlike my exchange
with my friend Joshua here a little bit ago, I don't get
hostile. I don't get upset. I don't cuss. I don't
raise my voice. I play to the camera. The approach I
take, that I took with her, and the approach I take with
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1 all public officials when I interact with them is I
2 imagine for a moment that a jury is sitting there.
3 Q. I'm just trying to make sure. Did she say
4 anything about Martin O'Boyle during that conversation?
5 A. Marty was flirting with her, but Marty flirts
6 with all women.
7 Q. So she didn't say anything?
8 A. No. I don't think so. I don't remember anything
9 like that. I don't think he asked for her phone number,
10 but he usually does that with women.
11 Q. When was your conversation with Scott Morgan?
12 A. A few weeks ago.
13 Q. What was the conversation about?
14 A. It was a conversation with Bob Sweetapple and
15 with Scott Morgan, and I think it was scheduling for the
16 deposition. All it was -- my exchange with Scott Morgan
17 was nothing more than hi, how are you? I think we had
18 some common acquaintances, something to that effect.
19 Q. With respect to the one police contact where it
20 was cordial...
21 A. Both of them were cordial. I'm always nice.
22 Q. But the one that you described before the
23 meeting, was Martin O'Boyle brought up at all during
24 that conversation?
25 A. Not by name; Marty was doing his little
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1 theatrical routine, which I really admire, actually,
2 where he had his pickup truck, his old beater, parked
3 outside in front of City Hall with a sign on it. And I
4 was enjoying watching some of the residents of Gulf
5 Stream come by, and slow down, and you have these
6 housewives of Gulf Stream looking at it, and kind of
7 shaking their head, like what the hell is happening to
8 my little town? The officer and I kind of joked about
9 the eye sore that it was there.
10 Q. Did he mention Martin O'Boyle by name?
11 A. No. As far as I know, he didn't even know I had
12 any connection to Marty.
13 Q. Other than those six conversations and one e-mail
14 we just discussed, do you recall any other conversations
15 with the employees of the Town of Gulf Stream?
16 A. Well, I guess Jones Foster is the Town's
17 attorney, the law firm is. I have had several
18 conversations with Joann O'Connor, all of which have
19 been very cordial.
20 Q. Let's focus on employees. Any other ones with
21 employees that you can recall?
22 A. Not that I can recall.
23 Q. Have you met with or spoken with any other
24 commissioners other than the mayor?
25 A. Not that I'm aware of.
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1 Q. You mentioned Mr. O'Boyle's pickup truck.
2 A. Yes.
3 Q. Have you ever discussed that with Mr. O'Boyle?
4 A. Yes. He told me about it.
5 Q. What was your conversation with him?
6 A. Just that there was a pickup truck parked down
7 there, had some kind of -- I don't even know what the
8 sign was, some kind of political something or other.
9 Q. Did he ever discuss his motivation for putting
10 the truck there?
11 A. Not that I recall. I can't say that he didn't,
12 but I don't recall.
13 Q. I only want to hear about what you recall. Did
14 you ever discuss with Mr. O'Boyle, his campaign to be on
15 the Town Commission?
16 A. Yes.
17 Q. How many times did you discuss that with him?
18 A. He told me he was going to run. And he gave me a
19 button, which I still, ironically, have hanging up on my
20 wall in my office.
21 Q. Did he ever discuss with you his motivation for
22 running?
23 A. I don't recall. He may have, but I don't recall.
24 It's funny. If somebody asked me what Marty's
25 political persuasion is, I couldn't tell you. I don't
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JOEL CHANDLER Volume 2 of 2
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think we've talked about politics many times.
Q. I meant more specifically, his motivation for
running in that campaign?
A. I don't know.
Q. You don't recall him discussing it with you?
A. He may have, but I don't recall.
Q. Did you ever discuss or were you aware that Mr.
O'Boyle has planes flying around the town with various
messages from time to time?
A. I have heard about them.
Q. Have you ever seen them?
MR. DESOUZA: I didn't hear the question. I'm
sorry.
MR. GILL: I asked if he was aware that Mr.
O'Boyle, from time to time, hired planes to fly around
the town with banners.
MR. DESOUZA: Okay. Hired planes.
A. I know about them. I have heard about them. I
don't know that I have ever seen one. I have seen
pictures.
BY MR. GILL:
Q. Have you ever discussed that with Mr. O'Boyle?
A. Yes.
Q. What did you talk about?
A. It was in that -- at one time he also -- I don't
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1 know if he still has it. He had a blimp that had some
2 kind of Velcro contraption on the side where you could
3 swap out signs. And he asked me if -- he offered to
4 give it to the foundation. But I couldn't figure out if
5 he meant I was supposed to fly it. I didn't understand
6 how it was going to work. That didn't seem very
7 practical. Although, I love theater, so as an activist,
8 I really love theater. But I just didn't find any
9 practical application for it.
10 Q. With respect to that, what were your discussions
11 with Mr. O'Boyle about the banners?
12 A. He -- I can't remember any specific instances.
13 I'm confident that at various times, we discussed his
14 theatrical proclivities. And I generally admire them,
15 although I think sometimes it has potential to go over
16 the top. At some point, I suspect that I am inclined to
17 believe that they become counterproductive.
18 Q. Were you aware that Mayor Morgan sent a letter to
19 all town residents on June 2nd, 2014?
20 A. Not that I recall.
21 Q. Do you ever recall discussing some poison pen
22 letter that Mayor Morgan had written to all the town
23 residents regarding pending matters in the town, dated
24 June 2nd, 2014?
25 A. June when?
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 211
Q.
June
2nd,
2014.
A.
Not
that
I recall.
Q.
How
many
town meetings have you attended in Gulf
Stream?
A. I think only one.
Q. Do you remember the date of that meeting,
approximately?
A. I don't.
Q. Did anything of note happen during that meeting?
A. Yes. I went there because I -- Marty was going
to speak there. And I remember it because he was
wearing some kind of fancy shoes he was telling me
about. And as I recall, Chris O'Hare gave a very
impassioned, expletive -latent comment, which I
thoroughly appreciated and enjoyed.
Q. What was the content of Marty's speech, Mr.
O'Boyle Is?
A. I don't remember.
Q. What was the content of Mr. O'Hare's comment?
A. The gist was he felt like the town was screwing
with him and not treating him fairly.
Q. Did you ever discuss with Mr. O'Boyle any changes
to the town's sign ordinance?
A. I don't know that it would have been changes to
the sign ordinance. I know that he had some clever
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1 scheme, and I don't mean that in a pejorative, for kind
2 of getting around it as far as signs he had for a house
3 he was selling. I remember he had some issues with
4 that, and I also remember there were some issues with
5 some of his campaign signs being moved. I don't know
6 the particulars. I just remember it was sort of a
7 crisis kind of a texture to the whole thing, because it
8 was in the midst of the campaign, and they were
9 concerned about First Amendment issues, "they" being
10 Marty, and Jonathan, and Ryan.
11 Q. On your direct testimony, you mentioned like an
12 enemy's list. What do you mean by that?
13 A. Well, Gulf Stream is a great example. I don't
14 have any ethical or legal objections to a citizen making
15 however many public records requests they want to make
16 to an agency or entity that is subject to the Public
17 Records Act. I think that doing that very often can be
18
really,
really
counterproductive for a whole bunch of
19
reasons,
which
if you want me to elaborate on, I would
20
be happy
to.
vendetta, or some grudge, or
21
But as far
as using
the Citizens Awareness
22
Foundation to make
a bunch
of public records requests,
23
because somebody's
got some
vendetta, or some grudge, or
24
has some political
angle, or
whatever, that just struck
25
me as really inappropriate.
And I don't think it would
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JOEL CHANDLER Volume 2 of 2
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be illegal. I don't even know that it would necessarily
be unethical. It just wouldn't be -- conform with what
I thought the objectives of the foundation should be.
Q. When you're referring to -- I don't mean a
specific written list, but did you believe that there
was a list of enemies? And whose list was it, I guess?
A. As far as I know, there was no list. I mean, I
certainly understand the impulse to make a list. I have
a list. It's called my special projects list. And
there are a number of agencies in Florida that are on
that list, because they have fucked with me, and they
have either tried to harass or prosecute me. The
Florida League of Cities is on that list. There are
entities, agencies, that may have peeked my curiosity.
But I don't inundate them with public records requests.
I don't harass them. They have my attention. And I'm
guessing most of them would just as soon not have my
attention, but they haven't.
I am not aware of any actual list that Marty may
or may not have had. When I say an enemies list, what I
meant was specifically Gulf Stream or Dave Aronberg, or
whoever. Just because somebody has pissed you off, I'm
not interested in carrying your water to go screw with
them. I have been hired, for example, on a consulting
basis in a political campaign to do opposition research.
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I don't have a problem with that. That's a one-time,
one-off kind of a deal. It's a perfectly legitimate
thing that's common practice in political campaigns; not
Marty's, but somebody else.
Carrying water for somebody that just wants to
dig their heels into somebody, I have things in my life
I want to deal with. There are a lot more important
issues to me. There are kids that are being abused.
The Department of Juvenile Justice, they have a contract
with G4S to run the Avon Park Youth Academy, which
sounds like the kind of place you would want to put your
kids on a waiting list, but I assure you it's not. It's
just a children's prison.
And it took them almost a month to find out where
those 200 kids are. They couldn't produce an address.
The address they produced was an empty field without an
outhouse or a chicken coop. That kind of stuff has my
attention. Screwing with Gulf Stream, I couldn't care
less.
Q. You at least perceive that the Town of Gulf
Stream was Martin O'Boyle's target?
A. Again, I recognize that elephant analogy that we
used before. You get three blind men, they touch the
elephant, and everybody comes back with a very radically
different description of what they're touching.
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I realize that when I hear Marty O'Boyle's
perceived slights from the Town of Gulf Stream, they may
be perfectly real and perfectly legitimate. They may be
completely nonexistent. I don't know. What he related
to me in his initial battle with Gulf Stream over his
house struck me. My sense was -- and again, I recognize
I was only getting his side of it -- that he had a
legitimate beef. When he painted his house with the
cartoons and all that stuff, I thought that was funny.
I thought it was clever, protected First Amendment
speech. I like that.
But I knew he had some issues. He was -- he had
an ax to grind with Gulf Stream. I wasn't interested in
hiring out to do that for somebody. I hired out to
Council on American Islamic Relations because they
really had questions about how DJJ was accommodating or
not accommodating the religious interests of Muslims in
their custody. I'm fine with that kind of stuff. But
just going back and pounding on somebody over and over
again, what's the point? We are not saving lives. We
are not serving justice. All we are doing is screwing
with somebody. And I think that he has a right to do
that, I just don't want to be the guy that's doing it
for him. I'm just not interested in it.
Q. And you are referring to the Town of Gulf Stream?
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1 A. Yes. And I very much had the sense that is what
2 was happening. I felt like -- and again, I realize that
3 all I'm hearing is one side of it. But my perception is
4 that Chris O'Hare got screwed by the Town of Gulf
5 Stream. I think he had a legitimate beef. Again, I
6 haven't heard Gulf Stream's side of that.
7 I don't think that it's a good idea to send
8
hundreds or
thousands of public
records requests to an
9
agency, per
say. But like my rodeo that I had with Polk
10
City where
I described earlier,
they wanted to charge a
11
confiscatory amount of
money for a very
simple public
12
records request. So I
really don't have
a choice.
13
Either I don't get the
records or I make
a whole bunch
14
of small public records
requests, which
I realize
15 creates a lot more work for them, but that's their
16 choice.
17 I think that's different. I want to reserve
18 judgment when somebody tells me that Chris O'Hare has
19 made 2,000 public records requests to the Town of Gulf
20 Stream, that may sound extreme, and it might be. But
21 there again, I don't know the full context of that. It
22 might be the kind of thing where they have told him it's
23 going to be some outrageous amount of money to get the
24 records and he's breaking it down so that he stays
25 underneath the special service charge contemplated in
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1 119.7(4).
2 But I don't know that there was an actual list,
3 but I very much had the sense that Marty wanted to
4 sharpen his knife with Gulf Stream.
5 Q. You testified when you first met Mr. O'Boyle,
6 that you were excited for the opportunity to perhaps
7 work with Mr. O'Boyle, or he could be someone that would
8 be beneficial in your civil rights activity.
9 A. It was the first time that I had a conversation
10 with a person of means that seemed passionate about open
11 government issues and who maybe was being patronizing,
12 but it felt sincere, who seemed to appreciate what it is
13 that I do. I get people all the time that say, "what
14 you're doing is great," but they don't give me any
15 support.
16 Q. Has your opinion changed for Mr. O'Boyle with
17 respect to his First Amendment or public records
18 beliefs?
19 A. Yes, they have very dramatically.
20 Q. How have they changed?
21 A. He is not what I would call a true believer. I
22 have -- when I made my first public records request and
23 had to file suit against the Polk County School Board to
24 vindicate my right and the public's right to access
25 records, I had the ability to write a $50,000 check to
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1 my attorneys. I have never been wealthy, but at that
2 time I was firmly middle class, four kids, private
3 school, the whole nine yards, a couple of boats.
4 I have lost count of the number of yard sales
5 that I have had. I have cashed in my kids' college
6 education funds. I have sold -- I had a magnificent set
7 of Van Staal fishing reels, like a work of art. They
8 were one of the first things to go. The first yard sale
9 you have, you get rid of the crap you haven't used in a
10 year. By the time you get down to the tenth one, you
11 are making some hard choices. I have gone broke doing
12 what I do. I used to buy a brand new car every single
13 year. I did that for probably 14 years straight.
14 There have been times since I have been doing
15 this that I did not own a car. I didn't have one. I
16 couldn't afford a car. The car I have now is a 15, 16
17 year old Volvo that's a rattle trap. I feel like I put
18 my money where my mouth is. There was a time when a
19 number of municipalities in Florida were seeking to have
20 me criminally prosecuted because of an inadvertent,
21 irrelevant, and immaterial error on my indigent
22 application that I filed with the court, asking whether
23 or not I had a homestead, which whether you have a
24 million dollar house or not, that's not even part of the
25 formula. It wouldn't matter how I answered the
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But because of a little, tiny, less than
technical error, the Town of St. Cloud and a whole bunch
of other public agencies expressed their desire to have
me criminally prosecuted and give me the maximum
sentence, which would have been one year for each one of
the indigent applications that I filled out. I'd filled
out over a hundred of them. They wanted to put me in
prison for the rest of my life for an inadvertent,
immaterial, irrelevant error on an indigent application,
which ironically, when I appealed it, I filled out the
indigent application for the appellate court the way
they said I should have, made no difference. It made no
difference. It was completely irrelevant.
15 As I explained to St. Cloud's attorney, if you
16 succeed with this and you put me in prison for the rest
17 of my life, and I have no other responsibilities, what
18 the fuck do you think I'm going to do sitting in a
19 prison cell? How many public records requests do you
20 think I'm going to make? And how many public records
21 seminars am I going give to every convict in there. If
22 I go to prison for the rest of my life, I will still be
23 doing this.
24 I believe in this. I believe that we cannot have
25 1 good government without transparency. I believe that
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
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adamantly. And the reason I left the Citizens Awareness
Foundation was I came to believe that my continued
association with Marty O'Boyle and the Citizens
Awareness Foundation would, in fact, hurt my ability to
be an advocate for open government. It would hurt my
credibility. And as I have -- as I put in a memo to the
board, it's almost like I had a crystal ball. I said if
you guys keep doing this, this is where we're going to
end up. And guess what? That's where we are. The crap
that is going on in Tallahassee, which by the way, will
not achieve the goals that they think it's going to
achieve. It will actually -- mark my words on the
record. There will be more litigation; not less. Mark
that down. There will be more; not less.
Q. So you left because you were worried it was going
to damage your reputation in the communities?
A. Yes. So the difference that I see, the change
that you are asking about, my perception of Marty, it's
clear to me that he does not share that same sense of
value. I think that he uses public records access to
bludgeon people just like he uses litigation to bludgeon
people. I don't think it's illegally. And I guess in
the strictest sense, I wouldn't say that it's even
unethical. I think it's unseemly. I think it's
unfortunate. And I think he toys with it. And I think
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
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he was really reckless. I believe this. Every time I
prepared for a deposition -- and now I have lost count
how many depositions I have done in connection with all
this crap.
I have a real sense of loss and sadness when I
review everything that happened. I think about what it
could have been. I think that Jonathan O'Boyle could
have had an enormously successful law firm. I think the
Citizens Awareness Foundation could have been an
unbelievably valuable asset to the citizens of Florida.
I think that we could have done amazingly good work, and
I think we could have really, positively impacted the
lives of a lot of poor and minority people, and I think
that just got pissed away, and it got pissed away
because of Marty's ego and because of Jonathan's greed.
Q. So Mr. O'Boyle's conduct damaged his
representation in the First Amendment public records
community, in your opinion?
A. He's a pariah. And to some extent, I think I've
become one; not nearly as much. I still have very good
relationships with many of the people. I am still very
much a part of the First Amendment Foundation and the
Sunshine Coalition. There was a time when I sort of
came to expect that I would be invited to come to
Tallahassee, and meet with legislators, and testify. I
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
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was actually -- I literally dictated 119.0701 to Chris
Clark, who was Don Gates' chief of staff. They modified
it a little bit before it became law. I don't think
that will ever happen again. I think that I am damaged
goods to a very large extent. That's okay, I guess. My
focus moving forward is still going to be open
government, but it will be a lot more directly related
to poor minority people.
I can tell you that -- and I relish the
opportunity to say this on the record in front of you
gentlemen. If you guys -- if the establishment didn't
like what I was doing before, hold onto your fucking
hat. You're really not going to like what's coming.
Q. So you think that damaged reputation is from your
association with Martin O'Boyle?
A. Yes.
Q. Mr. Chandler, you have explained some of your
financial issues, and I don't want to delve too deeply,
but do you have any other source of income other than
what you do sort of when you -- you talked about getting
money from seminars. Do you have any other employment
or anything like that?
A. I guess you would have to define employment.
Q. You said you have mouths to feed. I'm just
trying to determine how you bring in money to do that.
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JOEL CHANDLER Volume 2 of 2
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A. When I'm not doing a yard sale, you mean?
Q.
Yes.
A.
Yes.
I do some public
records litigation. I
have, I think in the last -- I want to say in the last
year or so, I don't think that I have sued but one
publicly operated entity, which was Polk City. My real
interest has been much more on state contractors. And
so very frequently when I file suit against these
contractors, the defense that I get in spite of the
fact that their contract explicitly states that the
contract can be immediately and unilaterally terminated
for failure to comply with a public records request,
their defense is, "Golly, gee. We didn't know. We
didn't know we were subject to the Public Records Act.
We didn't know." Which of course, in my mind, means you
have been taking money to do a job you have no intention
of doing. And there's a word for that. It starts with
"F" and it ain't fraud. It's fucked up. If you take
money and not plan on doing the work -- but whatever.
So I only file suit when the facts are absolutely
clear and indisputable. So for example, I get accused
very often of engaging in gotcha litigation, waiting for
some little minor technical violation and pulling the
trigger. Some of the most recent income that I have
had, I made public records requests to contractors who
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1 were absolutely, unequivocally subject to the Public
2 1 Records Act based on the terms of the contract.
3 I sent an e-mail. They got it, and they ignored
4 me. I stent another e-mail, they got it, they ignored
5 me. I sent a fax. I got a fax confirmation. They
6 ignored me. I sent another fax, got a fax confirmation,
7 they ignored me. I sent a US Priority Mail delivery
8 notification, they got it, they ignored me, and I filed
9 suit. But before I filed suit, I also contacted the
10 sate agency and asked either the general counsel of the
11 state agency, the secretary of the state agency or the
12 contract manager to intervene and tell the vendor to
13 produce the records, which they didn't do. Then I filed
14 suit. And I really don't know what more a person could
15 do to get the records than that. And they know they are
16 going to lose, and they want to settle. And it's the
17 same thing. You've got to produce the records or
18 certify that after the belated production, that's
19 everything there is. You have to take some kind of
20 remedial action, and I want to be paid money I'm not
21 entitled to for my time, effort, and aggravation. And
22 if you don't want to do that, I'm perfectly okay with
23 that. I really truly am. My purposes are served by
24 going to court and having a judge say that you broke the
25 law. I'm all right with that. That's how I make a
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JOEL CHANDLER Volume 2 of 2
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living, by -- let me finish.
I make a living by getting people who are
breaking the law at tax payer expense, to start
complying with the law at their expense, and they pay me
for the time and effort it took to do that.
Q. You still don't do anything with copy machines or
anything like?
A. No.
MR. GILL: I don't have any further questions for
you, Mr. Chandler. Thank you very much.
Daniel?
MR. DESOUZA: What do you guys want to do at this
point, because 5:30, you guys have a 4 hour, 3 and a
half hour drive home, and I don't have a half hour of
questions, although I think our 7 hours is probably up
pretty soon.
Joel, correct me if I'm wrong. I don't know if
you want to be there all night.
THE WITNESS: Well, only if you're going to slip
into some sexy lingerie. But if you're not going to
do that, I don't want to be here all night.
MR. DESOUZA: Truth be told, I said I wasn't
wearing heels, but I didn't say what else I was
wearing.
THE WITNESS: Well, that's way too much
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JOEL CHANDLER Volume 2 of 2
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information. Let's change the line of questioning
here.
I'm fine. These guys are already up here. I
would hate for them to have a to make another trip up
to beautiful Polk County. I'm happy to hang out for
another 30 minutes, if you want to fire away with some
questions. I'm sure they'll be very easy questions
that are not confrontational in any way.
MR. DESOUZA: Not at all.
MR. GOLDSTEIN: How long do you think you have?
MR. DESOUZA: I can tell you I don't have half an
hour. I probably don't have an hour. I probably
don't have an hour and a half. Once we get beyond
that. It's hard to estimate.
THE WITNESS: Do you think we'll be here an hour?
MR. DESOUZA: I've got more than an hour and a
half, probably two hours worth of stuff. But it could
go longer than that. I don't want you guys to be on
the road at 9:00, 10:00 tonight, and then we've got 45
minutes left or something at that point.
THE WITNESS: What does everybody else want to
22 1 do?
23
24
25
MR. GOLDSTEIN: I don't particularly feel like
staying here until 7:00.
MR. DESOUZA: Let's take a five-minute break.
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1 (Recess from 5:31 p.m. to 5:36 p.m.)
2 MR. GOLDSTEIN: We would agree to adjourn and get
3 back on the record at a mutually agreeable time.
4 THE WITNESS: Are you okay with that, Dan?
5 MR. DESOUZA: I kind of wanted to get started
6 with another -- with some questions fresh on my mind
7 that I would like to ask. We are basically going to
8 have to come back, whether it's up to Lakeland with
9 you guys on the phone or with Joel down here,
10 hopefully not in the Volvo.
11 THE WITNESS: No. It won't be in the Volvo. The
12 cost is going to include a rental car, fuel, lodging,
13 because I will not come down and come back the same
14 day. I am not going to drive 8 hours. And my meals,
15 which I can't imagine would be anywhere near what you
16 guys are billing.
17 MR. DESOUZA: Is the court reporter already
18 packed up?
19 THE WITNESS: No. She's still typing.
20 MR. SWEETAPPLE: We are all packed up, Dan.
21 We're ready to get back.
22 MR. DESOUZA: I would like to go until 6:00. I
23 don't -- I'm not going to have a lot of subjects to
24 cover right now, but I would like to go until 6:00.
25 THE WITNESS: I don't care. It's all right with
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JOEL CHANDLER Volume 2 of 2
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me. All right, Dan. Fire away.
CROSS-EXAMINATION
February 24, 2016
228
BY MR. DESOUZA:
Q. Okay. Joel, after you left CAFI, and that was
June 30th, 2014; is that the timeframe?
A. Yes.
Q. Before leaving, had you ever spoken to Bob
Sweetapple at that point?
A. No.
Q. Before June 30th?
A. No.
Q. Before June 30th, had you ever spoken to Mayor
Morgan?
A. No.
Q. Before June 30th, had you ever spoken to Joann
O'Connor?
A. No.
Q. Now, I guess the corollary is after June 30th, at
some point you spoke to Sweetapple, and you said you had
sent some e-mails out, I believe was your testimony; is
that right?
A. Yes.
Q. When do you recall first sending an e-mail to Bob
Sweetapple?
A. I don't recall the exact date. It would have
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 229
been not long after I received the threats from Marty
O'Boyle.
Q. Would that be a period of weeks, months after
June 30th, 2014?
A. Hours or days.
Q. Do you recall what you said in that e-mail?
A. No. I don't remember the exact language.
Q. Do you recall the gist of it?
A. The gist of it was that I had left the Citizens
Awareness Foundation as a result of irreconcilable,
philosophical, and ethical differences, that the
recipient of the e-mail -- because I sent out the same
e-mail to a bunch of attorneys I believed were
representing somebody, an entity that was being sued by
Citizens Awareness Foundation. If I could be of
assistance, I would be happy to help free of cost.
Q. Do you remember if it was one e-mail or multiple
e-mails, like one e-mail where you carbon copied a bunch
of people, or a bunch of different e-mails?
A. I think it was more sophisticated than a carbon
copy. I think they were mail merged and sent out. So I
think each recipient got his or her own e-mail, as I
recall.
Q. And you think you sent that e-mail at least to
Bob Sweetapple hours or days after giving your
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1 resignation on June 30th?
2 A. It would have been very shortly after that. Once
3 the threats started, I -- operation Plan B went into
4 effect.
5 Q. I assume Bob responded to your e-mail at some
6 point; is that correct?
7 A. Yes. I don't remember how long. It was a delay.
8 I was -- frankly, my feelings were kind of hurt. I
9 thought he would respond right away and he didn't. If
10 I'm not mistaken, I think Joann O'Connor responded
11 before Bob did, as I recall.
12 Q. Do you believe you sent the same gist of an
13 e-mail to Joann O'Connor?
14 A. I believe I did.
15 Q. Do you recall what Joann O'Connor's response was?
16 A. I think she called me on the phone. And if I'm
17 not mistaken, she qualified to be sure that I was not
18 being represented by counsel, and that it was okay to
19 talk to her. And I assured her that it was. And we
20 just kind of talked briefly about my departure from CAFI
21 and my enthusiasm about helping people who were being
22 sued by CAFI.
23 Q. When you say "helping people that were being sued
24 by CAFI," did you offer an e-mail to help people win
25 lawsuits? What type of help were you offering to give?
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A.
As I
recall, the
people that I
talked to
-- and I
don't
recall
everything
that responded
to that
e-mail
thought went out. I want to say -- the number that
sticks in my head, and this may not be exact. I
probably sent out 60, or 70, or 80 e-mails, and I
probably had less than 20 people respond. And the gist
of the conversations I had with each one varied a little
bit, but the flavor of each one was that the facts of
your case suck, and you're going to lose. Your client
broke the law. But there are strategies that you can do
to, in my mind, mitigate their liability and resolve
this in a way that would eliminate or dramatically
reduce any economic incentive for the O'Boyle Law Firm
and CAFI to pursue you in litigation.
Q. Focussing just on the e-mails as opposed to the
telephone conversations, in your e-mail, did you just
volunteer to help, or was it more specific than that?
A. I think it was -- I don't remember being more
specific than that. It was -- because I'm -- I'm not a
lawyer. I'm not practicing law. I can certainly give
advice to an attorney, but my interest was much more in
trying to eliminate recurrences of what happened with
Miami's River of Life, where somebody was being told to
pay sums of money that were far beyond the actual costs
and reasonable attorneys fees, namely to demand a fee
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JOEL CHANDLER Volume 2 of 2
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hearing -- produce records, admit liability, and demand
a fee hearing.
But I also -- I remember vividly having this
was so willing to give that advice, which on its face
seems like it would undermine open government advocacy,
because why wouldn't people just keep doing that? And
the answer is because you are setting yourself up for an
injunction, then you're screwed. How many times can you
do that and the judge doesn't lower the boom.
Q. Obviously, as my colleague, Joshua Goldstein, is
intimately aware, there's an issue with documents that
you have in your possession or had in your possession
that were, at some point, produced to Mr. Sweetapple, to
myself, and to perhaps others. Is that a fair
characterization? There is an issue regarding these
documents?
A. Oh, yes.
Q. Without going back to your conversation with Mr.
Goldstein, in your e-mails after you left CAFI, you sent
to these attorneys that were adverse to CAFI at the
time, did you mention in any of the e-mails that you had
documents that could help them?
A. I don't recall. I don't recall. I don't think
so, but I don't recall.
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1 1 Q. Those e-mails, are those e-mails that you still
2 have copies of somewhere on your server or network?
3 A. Yes. And you have them, and Bob Sweetapple has
4 them, and anybody else that's made these duplicative
5 demands for documents has those. You guys have all that
6 stuff. And you will recall that I have repeatedly
7 offered to meet with you or anybody else that needs help
8 navigating those documents. I think that upon
9 examination, it will become very clear that they are
10 extraordinarily, neatly, and logically organized,
11 methodically so. But given the sheer volume of
12 documents, I can certainly understand why somebody would
13 be kind of overwhelmed. It was not a data dump. They
14 are neatly organized, but there are just a lot of them.
15 So I'm not going to do that at my expense. I don't
16 expect to be compensated for it, but if somebody is
17 going to have me do that, then certainly the cost of me
18 coming to do it is going to have to be covered.
19 Q. The documents that we are talking about and the
20 hard drive that has been produced to me before, these
21 are documents that were created, or were sent, or were
22 received at a time that you were working for CAFI; is
23 that right?
24 A. I believe -- if I'm not mistaken, it would be
25 documents that were created or received or maintained
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1
while I was at CAFI, then after I
left
CAFI,
if I'm not
2
mistaken,
because I don't think you made
that
demand for
3
documents
until much later.
4
Q. In
putting together this --
I'm
just
going to
5
call it a
hard drive of documents.
I
assume
you know
6
what I'm
talking about when I say
"the
hard
drive of
7
documents."
8 A. Yes.
9 Q. In compiling these documents, this was done where
10 in the timeline? So if we take June 30th as your exit
11 date from CAFI, when was this done in the timeline?
12 A. Well, it would have been done after the
13 nonsensical lawsuit was filed against me by CAFI.
14 Q. And again, I'm not referring to gathering the
15 documents for production to me in response to the
16 document request. I'm more referring to -- at some
17 point you put together a bunch of documents, I'm going
18 to call it, whether it was for my purposes, or to give
19 to Bob Sweetapple, or just to compile for yourself. And
20 I'm trying to figure out when that happened.
21 A. Well, I gave my -- I'm not sure when it was. I
22 gave my sworn statement to Bob Sweetapple. It would
23 have been in that timeframe, I think, that I first
24 produced documents to him. I say first. I think that's
25 the only time I produced documents for Bob, certainly
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 235
any -- the hard drive you're talking about.
Q. Let me ask you a different way. When you were
working for CAFI, you had access to all of these
documents, presumably; right?
A. Yes, I did. That's how I have them.
Q. Right. And when you left CAFI, how was it that
you still had these hundreds of thousands of pages of
documents?
A. Because part of my employment agreement with
Marty and CAFI was that were going to provide computer
equipment to me, which they never did. As a result, I
was using the computer that I have through an
arrangement with the Counsel on American Islamic
Relations, the Macbook Pro that I used then and the
Macbook Pro that is the same one I still have now
doesn't belong to me. It belongs to them. And it was a
result of a grant arrangement that paid for it, and I
will have to return it to them in October of this year.
So all of the documents were on gear that I owned. And
the only computer equipment that was paid for by CAFI
was a very nice, very large fire wire connected hard
drive, but I returned that with all of the documents,
all of the data that was on there. That was being used
as backup, purely as backup. So all of the documents
that I have were on the machine that belongs -- I don't
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1 own it, but is in my possession lawfully.
2 Q. Right. And you had testified, I think, earlier
3 today that -- hopefully I'm using your words and not
4 butchering them, that at some point, you saw the writing
5 on the wall as you prepared to exit from CAFI; is that
6 right?
7 A. Yes.
8 Q. And in seeing the writing on the wall, I think
9 you testified that you had started to gather documents,
10 whether to protect yourself or for some other reason; is
11 that right?
12 A. It wasn't that I was gathering documents. I
13 think that would not be a fair characterization. These
14 are documents that I would have had no matter what
15 happened, whether I thought I was going to leave or not
16 leave. The difference was that my e-mail exchanges were
17 such that they left little room for debate about what
18 was actually said. For example, Denise demanding that I
19 produce 25 cases per week or 100 cases a month, or her
20 demanding that I draft lawsuits. I artfully made sure
21 that those exchanges produced the full flower of her
22 meaning.
23 So I didn't create documents. I didn't gather up
24 documents. It wasn't like I was scouring through
25 somebody's filing cabinets and taking things that I
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1
wasn't supposed to have. What
I meant by anticipating
2
leaving and wanting to be sure
I had things well
3
documented, when Denise said, "Hey,
draft lawsuits," I
4
didn't just say no; I'm not to
going to do it. I laid
5
out, here's why I'm not going to
do it, because it's the
6
unlicensed practice of law. That's
what I mean. Or for
7
example, when I drafted the memo that I -- the written
8
memo that I placed in front of
Denise and Bill during
9
our meeting where I warned them
that if things didn't
10
change, I was going to quit, I
wrote that with an eye
11
towards where we are right now.
It was very deliberate.
12
But I didn't take documents or
squirrel away documents
13
that I wouldn't have otherwise
had. I made sure that
14 1 the documents I do have are clear.
15 Q. Prior to leaving CAFI, did you make any attempts
16 to organize documents or prepare what you thought were
17 documents in any sort of way?
18 A. No. They -- no. The organization that you will
19 find on the hard drive that I gave to you and that Bob
20 would find on the hard drive that I gave to him, is
21 generally reflective of the organization that I have for
22 all of my files. Like e-mails, for example, every
23 e-mail that I have exchanged with Bob Sweetapple has his
24 own folder. Every e-mail that I've ever exchanged with
25 Lou Roeder has its own folder. Every e-mail that I've
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1 ever exchanged with my wife has its own folder. I
2 probably have hundreds and hundreds of subfolders in my
3 e-mail client. That's just how I organize it.
4 So it's not like I created a new hierarchy for
5 file organization. I just basically took what was
6 already in existence and copied it to an external hard
7 drive. There would have been some minor changes just
8 because the root directories would have been different,
9 but for the most part it's the same.
10 Q. Since he endeavored to drive 3 and a half, 4
11 hours up there, I don't want to end the day without
12 talking about Mr. Sweetapple. You said that you sent
13 the e-mail to him, something to the gist of, I have left
14 and I can offer help, and it took him some time to
15 respond to you. Do you recall how Mr. Sweetapple
16 responded to you?
17 A. I don't remember whether it was an e-mail or
18 phone call. At some point we did talk on the phone.
19 Q. What do you recall about that phone conversation?
20 A. I remember he sounded much more human than I was
21 expecting.
22 Q. Why do you say that?
23 A. I thought there was going to we some kind of
24 dragon sounding voice, the way he had been described to
25 me by everyone down there. He was very pleasant. He
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JOEL CHANDLER Volume 2 of 2
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was very cordial. All of our exchanges have been very
pleasant. I have never had a cross word with Bob. It's
not like we are buddies and we hang out or anything, but
they have always been very cordial, very professional,
pleasant.
Q. How many cases was Bob Sweetapple involved in at
the time against Marty, or CAFI, or any of the entities
that were down here?
A. I have no idea.
Q. Who is it that would have described Bob in June
2014 to you in a negative light?
A. Well, I don't know that it was just in June 2014.
I just remember his name coming up very regularly at the
office there in Deerfield Beach, the CAFI, O'Boyle Law
Firm office. It came up a lot. And I remember I got
various descriptions, some of which from people that I
-- whose opinion I would have actually given credence
to. Marrett Hanna, for example, had a pretty negative
impression of him. But you know, he is an attorney. So
there's that. But I don't know. He was just -- he was
always described in a negative, adversarial kind of way.
Q. Well, at some point, Bob either e-mailed you or
called you after your initial e-mail. And what do you
recall discussing with him at that point?
MR. GOLDSTEIN: Asked and answered.
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JOEL CHANDLER Volume 2 of 2
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BY MR. DESOUZA:
Q. That's great. You can answer it again.
A. Okay.
Q. So this is just whatever initial conversation or
e-mail exchange you had with him; not in general over
the life of your discussions with Bob.
A. You say that -- I'm sorry, Dan. Say that again.
Q. I'm just asking, you sent an e-mail to Mr.
Sweetapple, and he responded to you in some fashion,
whether it be a phone call or an e-mail. I'm trying to
get a sense of what was discussed in that initial
contact with Mr. Sweetapple.
A. I can't say with certainty that it was limited to
our first conversation, but the first -- either the
first conversation or the first couple of however many
conversations we had -- it wouldn't have been very many.
We moved pretty quickly towards scheduling a visit here
in Lakeland for my sworn statement. We kind of
commiserated together about the difficulties of what was
going on in Gulf Stream, about the mess that was
becoming CAFI, or CAFI had become. We talked about
dealing with Marty. Had I not ever met Marty before and
relied solely on upon Bob Sweetapple's descriptive
powers, I would have expected Marty breathe fire, and
have horns, and a tail, and a pitchfork. So I get the
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JOEL CHANDLER Volume 2 of 2
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feeling that neither of them really like each other.
Although, I will say in some respects, they are
remarkably similar.
Q. During any of your initial conversations with
Bob, did the subject of documents that you had during
your tenure with CAFI come up?
A. Probably. I mean, it came up at some point, I
think, before he came to Lakeland, so yes, within our
first few conversations.
Q. What do you recall about that? What do you
recall saying to him, him saying to you?
A. I described the nature of some of what I would
think of as being some of the more damning documents,
Denise running the law firm, and trying to get me to
engage in unlicensed practice of law, or the quota for
generating lawsuits, and the fact that Denise had access
to the O'Boyle Law Firm client database, the cleo
software system, that she was in there running reports
and having access to all client information, not just
CAFI, which I had a problem with, including Jeff Gray,
and Jeff Frazier, and other people I had referred to the
O'Boyle Law Firm, which I found very distressing because
of attorney-client privilege issues, just those sorts of
things, documents that I thought made it very clear that
Marty was really using Cathy as his instrumentality of
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JOEL CHANDLER Volume 2 of 2
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vengeance on Gulf Stream, among other things.
Q. Is it fair to say that you recall discussing some
of your substantive complaints with Mr. Sweetapple as to
what you thought was unethical or improper conduct that
was going on at CAFI?
A. Yes, we probably did to some degree.
Q. Is it fair to say that you also discussed the
substance of what some of these CAFI documents would
show, what you would believe they showed with him?
A. I probably did. I think so. That's going to be
a fair assessment.
Q. Do you recall Mr. Sweetapple expressing any
hesitation or concern about talking to you about these
subjects after your exodus from CAFI?
A. Yes. I recall him going into great detail about
warning me about attorney-client privilege, both my own
and CAFI's attorney-client privilege. In fact, he did
that on the record during my sworn statement. I thought
that he went out of his way to guard against -- frankly,
I thought he was -- I don't think naively, I believe
this, but I think he genuinely was trying to be sure I
didn't waive any attorney-client privilege without being
conscious of doing that, for my own.
Q. But in terms of the timeline, you left June 30th,
and you gave the sworn statement, what, about a month
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 243
later; is that fair to say?
A. I don't know. We had the -- I don't have my
glasses. July 23rd, 2014 is when the sworn statement
was given.
Q. So a little less than a month later?
A. Yes.
Q. In terms of the timeline there, do you recall
discussing the substance of your complaints about CAFI
with Bob prior to the sworn statement?
A. I think I have already answered that.
Q. Well, I know you went on record in the sworn
statement, and Mr. Sweetapple made statements about
privilege and other items like that. But I'm trying to
figure out before the sworn statement, were these
conversations happening about the substance of your
complaints?
A. Yes. You have already asked me that question. I
answered it just a minute ago. We had discussions about
the substance of my complaints. Yes.
Q. Did Mr. Sweetapple warn you -- or not warn you,
but did Mr. Sweetapple discuss with you any concerns or
hesitations he had at that time with privilege waivers
and other items like that?
A. I don't recall that specific conversation. The
only point of reference I really have that I'm confident
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JOEL CHANDLER Volume 2 of 2
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in is the transcript of my sworn statement where I
thought he belabored that issue at the opening of the
discussion of my statement.
Q. But it's certainly possible that you discussed
the substance of your complaints with Mr. Sweetapple
prior to that, and Mr. Sweetapple did not express a
similar concern at that time of, here are all of the
issues of privilege and waiver in those earlier
conversations; is that right?
A. I'm going to object to form. It's possible I
could grow wings and fly, but that doesn't mean it's
going to happen. I don't know whether it's possible or
not. I guess it's possible.
Q. Let me switch the question then. Do you recall
in any of those earlier conversations, Mr. Sweetapple
telling you, "Hold on, Joel. You're telling me some
things that might be privileged or might be
confidential, and I've got some concerns with that"?
A. Again, I'm going to object to form. I don't
remember him making that statement. You said, did he
say, then you give me a quote of what he said. I don't
know. No. I don't -- let me say this as definitively
as I can, and maybe this will allow us to move on to
whatever other questions you have, because I can't wait
to hear them, because I know they will be good ones.
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 245
I don't recall whether or not, during my
telephone conversations or any e-mails exchanges that I
had with Bob prior to us meeting for the first time in
Lakeland, face to face, I don't recall whether or not we
discussed specifically, issues about attorney-client
privilege. I do know with certainty that he belabored
that issue when we did meet in person on the record. I
can't answer that any more clearly than that.
Q. Now, obviously you said some things to him about
what you thought were unethical or improper conduct.
But do you recall Mr. Sweetapple ever saying anything to
you on his opinion or what he thought was unethical or
improper or illegal conduct?
A. Yes.
Q. What do you recall about that?
A. I remember Bob telling me how much he appreciated
my willingness to come forward and disclose what I knew,
and that he found the conduct that I was describing
troubling. That was the gist of the conversation. I
don't remember the exact words. We actually had that
conversation -- I remember that conversation
specifically in an anteroom of the facility where we had
the sworn statement. He and I chatted for a few minutes
before we went on the record.
MR. GILL: Daniel, this is Hudson. It's 6:00
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1 o'clock. How much more do you want to go tonight?
2 MR. DESOUZA: I probably have another 10, 15
3 minutes tonight, then we will reconvene.
4 MR. GILL: I mean, you're the one that proposed
5 we adjourn before your questioning, then you went on
6 break, and now you want to go. You keep pushing the
7 time.
8 MR. DESOUZA: I'm also the one that is Plaintiff
9 in this case and has gotten all of 25 minutes to talk
10 to the witness versus the 6 and a half, 7 hours that
11 you guys took.
12 MR. GILL: No one is objectina to you auestionina
13 1 him again.
14
MR. DESOUZA:
That's great. We can argue for the
15
next 10 minutes about
it or I can ask him 10 more
16
minutes of questions.
17
THE WITNESS:
Dan, I'm fine. Go ahead with your
18
questions. But I
would be -- you know me. Ask me
19
what time it is, I'll
tell you how to make a watch.
20
I'm happy to keep
talking to you all night, but these
21
guys probably want
to get going. I would just
22
graciously suggest
that we try to limit it to maybe
23
another 10 minutes
so these guys can go.
24
MR. DESOUZA:
I'm not planning on going any
25 1 further than that.
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1 THE WITNESS: Okay.
2 BY MR. DESOUZA:
3 Q. In your conversations with Mr. Sweetapple --
4 actually, strike that.
5 You're aware that at some point, a federal RICO
6 lawsuit was filed by Gulf Stream and Wantman Group
7 against Martin O'Boyle and various other defendants;
8 correct?
9
A.
Yes.
10
Q.
Did you ever discuss the RICO lawsuit or the
11
prospective filing of the RICO lawsuit with Bob
12
Sweetapple?
13
A.
Yes.
14
Q.
When did that happen?
15
A.
Before it was filed; I don't know the date.
16
Q.
Did Bob Sweetapple tell you the Town of Gulf
17
Stream
would be filing a racketeering lawsuit against
18
Mr. O'Boyle and others?
19
A.
Yes.
20
Q.
How did that conversation come up?
21
A.
I don't recall how it came up. We were talking
22
on the
phone.
23
Q.
Well, what do you recall about it? What do
24
recall
Mr. Sweetapple saying to you?
25
A.
That they plan to file a RICO lawsuit against
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1 Marty and Chris O'Hare, and I guess there were other
2 people named in the lawsuit. I didn't follow that case
3 very closely.
4 Q. Did Mr. Sweetapple tell you why it is that he
5 considered this to be a valid lawsuit, or why it is they
6 were planning to file a racketeering lawsuit against
7 these individuals?
8 MR. GOLDSTEIN: Object to form.
9 A. I would assume -- no. I don't recall that
10 specifically. I have read at least portions of the
11 complaint, so I would presume that the gist of his
12 rationale was laid out there.
13 BY MR. DESOUZA:
14 Q. Well, do you recall Bob Sweetapple ever telling
15 you, we're suing them because they are committing
16 racketeering violations?
17 MR. GOLDSTEIN: Form.
18 A. I don't recall him using those words.
19 BY MR. DESOUZA:
20 Q. Other than saying, "we're going to file a RICO
21 lawsuit against Marty and others," do you recall Mr.
22 Sweetapple saying anything else about the forthcoming
23 RICO lawsuit?
24 A. I thought he expressed -- I thought he was
25 overconfident in it prevailing. As I have said earlier
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1 today, I readily acknowledge that I know very little
2 about RICO prosecution, so I do recall having a
3 conversation with Marrett Hanna about it. And her
4 perspective as a former prosecutor is they're very --
5 civil RICOs are very difficult to win. I was
6 particularly troubled, and I'm very confident that I
7 expressed to Bob and to Joann O'Connor, my
8 disappointment and concern that they were involving
9 Chris O'Hare. I have been, I think, very clear with
10 everybody that I have ever talked to about this issue,
11 that I think that's ill advised, unfair. I don't think
12 he's the bad guy here at all.
13 Q. Well, the RICO lawsuit was filed on February 12th
14 of 2015. Do you recall roughly how far before that this
15 conversation about a forthcoming RICO lawsuit happened?
16 A. I have no idea.
17 Q. Do you know whether it was 2014, 2015, or you
18 can't tell?
19 A. Already asked and answered. I don't know.
20 Q. Other than the one conversation we are talking
21 about with respect to RICO, do you recall having any
22 other conversations with Mr. Sweetapple about RICO,
23 racketeering?
24 A. I don't remember any specific conversations.
25 There was a brief period where Bob and I talked. I
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1 wouldn't say frequently, but we talked several times in
2 comparison with other periods where we have gone many
3 months without any communication at all. Sometimes my
4 feelings were kind of hurt. I feel like he's forgotten
5 me. But no. I don't remember how many times we talked
6 about it.
7 I like Bob. Bob seems like a good guy. I wasn't
8 being patronizing, but I don't really care about that
9 whole thing. The only interest I've got in the RICO is
10 I think it's -- I dont' think that Chris should have
11 been wrapped up in that, and I think Chris got screwed.
12 But other than that, I don't really care. If the
13 underlying issue -- and Bob and I have discussed this on
14 more than one occasion. If the underlying issue is just
15 making public records requests, I think it was ill
16 advised. If it deals with other issues, then there are
17 probably other issues that should be dealt with. But
18 again, I don't know enough about RICO to have an opinion
19 about it.
20 Q. Going back to this one conversation that we are
21 recalling prior to the RICO lawsuit being filed, do you
22 recall whether Mr. Sweetapple distinguished between
23 civil RICO, criminal RICO? Did he make any distinction
24 in that regard to you?
25 MR. GOLDSTEIN: Dan, you cut out in the middle of
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1 your question.
2 BY MR. DESOUZA:
3 Q. During this conversation pre RICO lawsuit where
4 Mr. Sweetapple told you something about RICO was going
5 to be coming, did he make any distinction between
6 criminal RICO or civil RICO?
7 A. I dont' remember ever hearing any discussions
8 about a criminal RICO.
9 Q. Well, that's what I'm asking. Was it, we are
10 going to be suing them in a civil lawsuit with respect
11 to RICO violations, or was it just, we are coming after
12 them for RICO, if you get what I'm saying?
13 MR. GILL: Object to the form.
14 MR. GOLDSTEIN: Join.
15 A. I will answer it. I don't remember there being
16 any discussion about any kind of criminal whatever.
17 What I remember is the civil RICO. And frankly, at that
18 point, I didn't know there was such a thing as a civil
19 RICO. We are talking about stuff I don't know anything
20 about. I just don't know. Like I said before. I watch
21 the Sopranos, but other than that, I don't know anything
22 about RICO.
23 Q. In this conversation with Mr. Sweetapple, was
24 there any reference to you possibly being a defendant in
25 this lawsuit coming up?
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1 A. No. Although I have heard rumors that if Bob
2 didn't get his way, that my head was going to be on a
3 pike. But that has never been my experience with Bob.
4 I have never received any kind of threatening aura or
5 words from Bob ever. There has never been any kind of
6 cooperate or else. I have never gotten that from him
7 ever, not a whiff of it. And I can assure you if I had,
8 he and I would not be on good terms.
9 Q. What about the inverse of that?
10 A. As an inducement, if you cooperate, we won't have
11 your head on a pike? Is that what you're asking me?
12 Q. Right.
13 A. I would have told him to go fuck himself if he
14 had said that. I didn't do anything wrong. My hands
15 are clean here.
16 Look. Just so we are clear, I'm going to
17 elaborate on that one. I have not gotten any kind of
18 inducement from anybody for anything that has anything
19 to do with any of the crap that's going on down in Gulf
20 Stream. The only -- the only person that has ever
21 threatened me in Gulf Stream is Marty. That's it.
22 That's the extent of it. Nobody else has ever
23 threatened me. Nobody else has ever made any promises
24 to me. Nobody has offered me a Hawaiian vacation.
25 Nobody has offered to not prosecute me. I have gotten
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
253
1 none of that. And frankly, if anybody had -- I would
2 perceive a, "we won't come after you if," as a threat.
3 And you know how I respond to threats.
4 Q. Let me ask you before we leave, this is probably
5 a good end question here. But since your first
6 conversation with Mr. Sweetapple, is there anything
7 that, in your opinion, you witnessed, observed, or
8 talked to Mr. Sweetapple about that you would consider
9 to be unethical on his part?
10 MR. GILL: Object to the form of the question.
11 MR. GOLDSTEIN: Object to the form as well.
12 MR. DESOUZA: You guys are whispering over there.
13 MR. GOLDSTEIN: I said object to form as well.
14 A. No. I have never -- I mean, today is only the
15 second time that I have seen Bob Sweetapple. Frankly,
16 if I passed him on the street, I'm not sure I would have
17 recognized him. So my direct contact with him has been
18 extremely limited. All of my conversations with him, I
19 have sensed that he seems like a -- for somebody who is
20 a member of the Bar, he seems like a pretty straight
21 guy. No. I think that's the -- the only issue I have
22 had with Bob is screwing around with Chris O'Hare, which
23 I guess ultimately I can blame his client for that. But
24 I think that shouldn't happen and I wish they'd leave
25 the guy alone. But that's just me. That's the only
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
1 1 issue I've got with Bob.
February 24, 2016
254
2 MR. DESOUZA: I want to keep my 10 minute promise
3 to Hudson and Josh. With the stipulation that we are
4 either coming back to Lakeland or Joel is coming back
5 down to Florida under some other arrangement, I assume
6 everyone has agreed to reschedule a further deposition
7 of Joel, and Joel, you have agreed to make yourself
8 available. If that's not correct, someone let me
9 know.
10 THE WITNESS: That's fine. That's fine. I just
11 want to get it on the record that it needs to be -- I
12 need to get reasonable notice. If everybody is
13 reasonable and nice, then I will be more than happy to
14 be a team player, although none of you will probably
15 like what I have to say.
16 MR. GILL: The Town agrees to that, Daniel.
17 MR. GOLDSTEIN: As well as Mr. Sweetapple.
18 MR. DESOUZA: I will go on record and say that
19 everyone here is reasonable and happy.
20 MR. GOLDSTEIN: Who else is there, Daniel?
21 MR. DESOUZA: I've got Marty here and I've got
22 Chris here.
23 MR. GOLDSTEIN: When did Chris join you?
24 MR. DESOUZA: Chris was here a couple hours ago.
25 THE WITNESS: I talked to Chris early in the day.
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 255
All right. Are we done?
MR. DESOUZA: We are done for the night. Josh,
you agree that there is no objection to reconvening?
MR. GOLDSTEIN: No. I have already stated my
non -objection.
(Deposition adjourned at 6:18 p.m.)
(End of Volume 2 of 2.)
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE 256
DEPOSITION ERRATA SHEET
Our Assignment No. 118775
Case Caption: O'Boyle vs. Sweetapple
DECLARATION UNDER PENALTY OF PERJURY
I declare under penalty of perjury that I have
read the entire transcript of my Deposition taken in
the captioned matter or the same has been read to me,
and the same is true and accurate, save and except for
changes and/or corrections, if any, as indicated by me
on the DEPOSITION ERRATA SHEET hereof, with the
understanding that I offer these changes as if still
under oath.
Signed on the day of 20
JOEL CHANDLER.
C)ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
257
�� ESQU,IRE
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DEPOSITION
ERRATA SHEET
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DATE:
JOEL CHANDLER
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
258
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DATE:
JOEL CHANDLER
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
CERTIFICATE OF REPORTER
STATE OF FLORIDA )
COUNTY OF HILLSBOROUGH)
February 24, 2016
259
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.
Atw m . Ste,
Megan M. Soria
r,� ESQUIRE
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is
16
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22
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2S
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
CERTIFICATE OF OATH
STATE OF FLORIDA )
COUNTY OF HILLSBOROUGH)
February 24, 2016
260
I, the undersigned authority, certify that
the witness in this matter personally appeared before me
and was duly sworn on the 24th day of February, 2016.
WITNESS my hand and official seal this 9th of March,
2016.
'4(Uq v, S�
Megan M. Soria,
Notary Public
State of Florida at Large
My Commission Number: FF934013
Expires: 6/18/2017
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
—
2,000
$
216:19
20
$50,000
231:6
217:25
200
--- - -
201:16
1
214:15
2013
10
200:9
246:2,15,
2014
23 254:2
223:14
210:19,24
100
211:1
236:19
228:5
229:4
10:00
activist
239:11,12
226:19
activists
201:5
243:3
11
249:17
205:7
217:8
220:4
2015
119.07(4)
249:14,17
205:10
217:2
23rd
119.0701
243:3
222:1
adamantly
224:1
25
119.7(4)
236:19
217:1
246:9
12th
2nd
249:13
210:19,24
14
211:1
218:13
15
3
218:16
255:6
246:2
3
16
225:13
218:16
238:10
17
30
205:7
226:6
2
2
255:7
30th
228:5,10
12, 15,18
229:4
230:1
234:10
242:24
4
4
225:13
238:10
45
226:19
5
5:30
225:13
5:31
227:1
5:36
227:1
F
6
246:10
60
231:5
6:00
227:22,24
245:25
6:18
255:6
7
7
225:15
246:10
70
231:5
7:00
226:24
February 24, 2016
Index: $50,000..adversarial
-
220:11,12
8
acknowledge
249:1
8
acquaintanc
227:14
ea
80
206:18
231:5
act
204:14
9
212:17
223:14
224:2
9:00
226:19
action
224:20
A
activist
210:7
Ala
activists
201:5
203:19
ability
activity
217:25
217:8
220:4
actual
absolute
213:19
204:18
217:2
231:24
absolutely
223:20
adamantly
224:1
220:1
abused
address
214:8
214:15,16
Academy
adjourn
214:10
227:2
246:5
access
217:24
adjourned
220:20
255:6
235:3
admire
241:16,19
207:1
accommodati
210:14
ng
admit
215:16,17
232:1
accused
adversarial
223:21
239:21
achieve
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
adversary
255:3
application
204:23
agreeable
s
219'7
adverse
227:3
232:21
appreciated
agreed
advice
254:6,7
211:15
245:16
202:25
agreement
203:3,4
approach
235.9
231:21
205:24,25
232:5
agrees
approximate
254:16
advised
ly
249:11
ahead
200:7
250:16
246:17
211:7
advocacy
amazingly
argue
232:6
221:11
246:14
advocate
Amendment
argument
203:6
212:9
203:13
220:5
215:10
217:17
arms
advocates
204:6
221:17,22
203:14
Aronberg
American
afford
213:21
215:15
218:16
235:13
arrangement
African-
235:13,17
amount
americans
216:11,23
254:5
199:23
arrested
200:20
analogy
200:3
214:22
Afternoon
199:2
angle
arrows
200:9,11
212:24
agencies
art
200:23
anteroom
218:7
203:1
245:22
204:9
anticipatin
artfully
213:10,14
236:20
g
219:4
237:1
articulate
agency
appealed
200:12
212:16
219:11
assessment
216:9
242:11
224:10,11
appellate
219:12
asset
aggravation
221:10
224:21
application
210:9
assistance
agree
218:22
229:16
227`2
219:10.12
ESQUIRE
February 24, 2016
Index: adversary..ball
association avoid
220:3 203:9,18
222:15
avoiding
assume 203:7
230:5
234:5
248:9
254:5
assure
214:12
252:7
assured
230:19
attempts
237:15
attend
199:18
attended
211:3
attention
213:16,18
214:18
attorney
203:2,3
207:17
219:15
231:21
239:19
attorney-
client
241:23
242:16,
17,22
245:5
attorneys
218:1
229:13
231:25
232:21
aura
252:4
Avon
214:10
aware
207:25
209:7,14
210:18
213:19
232:12
247:5
Awareness
202:15
212:21
220:1,4
221:9
229:10,15
ax
215:13
B
back
200:18
201:4,12,
19,20
214:24
2 15: 19
227:3,8,
13,21
232:19
250:20
254:4
backup
235:24
bad
200:14
249:12
ball
220:7
800.211.DEP0 (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
banners
209:16
210:11
Bar
253:20
based
224:2
basically
227:7
238:5
basis
213:25
battle
215:5
Beach
199:25
2 00: 15
239:14
beater
207:2
beautiful
226:5
beef
2 15: 8
2 16: 5
belabored
244:2
245:6
belated
224:18
beliefs
217:18
believed
229:13
believer
217:21
belong
235:16
belongs
235:16,25
beneficial
217:8
Bill
202:1,12,
19
203:21,23
237:8
billing
227:16
bit
205:22
222:3
231:8
Black
201:13
blame
253:23
blimp
210:1
blind
214:23
blocks
2 01: 5
bludgeon
220:21
board
217:23
22 0: 7
boats
218:3
Bob
206:14
228:7,23
229:25
230:5,11
233:3
234:19,
22,25
237:19,23
239:2,6,
10,22
240:6,23
241:5
243:9
245:3,16
247:11,16
248:14
249:7,25
250:7,13
252:1,3,5
253:15,22
254:1
boom
232:10
bother
2 03: 13
brand
218:12
break
226:25
246:6
breaking
216:24
225:3
breathe
240:24
briefly
202:4,8
230:20
bring
222:25
broke
218:11
224:24
231:10
brought
205:2
206:23
buddies
239:3
bunch
212:18,22
216:13
219:3
229:13,
18,19
234:17
butchering
236:4
button
208:19
buy
218:12
C
cabinets
236:25
CAFI
228:4
230:20,
22,24
231:14
232:20,21
233:22
234:1,11,
13 235:3,
6,10,20
236:5
237:15
239:7,14
240:21
241:6,20
242:5,8,
14 243:8
CAFIIS
242:17
call
2 04:2 0
217:21
234:5,18
238:18
240:10
called
201:20
February 24, 2016
Index: banners..cell
213:9
230:16
239:23
camera
205:24
campaign
2 08: 14
209:3
212:5,8
213:25
campaigns
214:3
car
201:9,15
218:12,
15,16
227:12
carbon
229:18,20
care
214:18
227:25
250:8,12
carrying
213:23
214:5
cartoons
215:9
case
231:9
246:9
248:2
cases
236:19
239:6
cashed
218:5
Cathy
241:25
cell
219:19
O ESQUIRE 800.211.DEPO (3376)
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: certainty..conscious
certainty
Chris
233:9
Commission
12,20
240:13
211:13
237:14
208:15
concern
245:6
216:4,18
241:24
commissions
242:13
certify
222:1
249:9
rs
244:7
248:1
252:16
224:18
207:24
249:8
249.9
cleo
Chandler
250:10,11
committing
concerned
241:17
199:2
253:22
2 48:15
212:9
222:17
254:22,
clerk
common
concerns
225:10
23,24,25
202:5
206:18
243:21
204:25
change
Cities
214:3
244:18
205:4
220:17
213:13
communicati
conduct
226:1
clever
citizen
on
221:16
237:10
211:25
212:14
250:3
242:4
changed
215:10
245:10,
citizens
communities
217:16,20
client
13,18
202:14
220:16
channel
212:21
231:9
confident
238:3
community
205:17
220:1,3
221:18
210:13
221:9,10
241:17,19
243:25
characteriz
253:23
ation
229:9,15
comparison
249:6
closely
250:2
232:16
city
confidentia
236:13
201:24
248:3
compensated
1
charge
202:1,5,
Cloud
233:16
244:18
205:9,12
11 207:3
219:3
compile
confirmatio
216:10,25
216:10
Cloud's
234:19
n
chase
223:6
219:15
compiling
224:5,6
200:10
civil
Coalition
234:9
confiscator
chatted
204:3
221:23
complaint
}'
217:8
216:11
245:23
249:5
coast
248:11
check
250:23
199:24
complaints
conform
217:25
251:6,10,
200:16
242:3
213:2
17,18
colleague
243:8,16,
confrontati
chicken
Clark
232:11
19 244:5
onal
214:17
222:2
college
completely
226:8
chief
class
200:4
215:4
connected
222:2
218:2
218:5
219:14
235:21
children's
clean
comment
comply
P 1
connection
214:13
252:15
211:14,19
223:12
207:12
choice
clear
commiserate
complying
221:3
216:12,16
205:21
d
225:4
conscious
choices
220:19
240:19
computer
242:23
218:11
223:21
235:10,
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JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
considered
205:14,20
248:5
206:4,11,
consulting
13,14,24
208:5
213:24
217:9
contact
232:4,19
199:7,10,
238:19
13 201:25
240:4,14,
202:11
15 243:24
206:19
245:19,21
240:12
247:20
253:17
249:3,15,
contacted
20 250:20
204:8,9,
251:3,23
10,14
253:6
224:9
conversatio
contacts
ns
199:15
207:13,
14,18
contemplate
231:7,16
d
240:16
205:10
241:4,9
216:25
243:15
content
244:9,15
211:16,19
245:2
247:3
context
249:22,24
216:21
253:18
continued
convict
220:2
219:21
contract
coop
214:9
214:17
223:10,11
224:2,12
cooperate
252:6,10
contractors
204:11
copied
223:7,9,
229:18
25
238:6
contraption
copies
210:2
233:2
conversatio
copy
n
225:6
202:8,12
229:21
203:23
cordial
199:16
202:18
204:1
206:20,21
207:19
239:1,4
corollary
228:18
correct
225:17
230:6
247:8
254:8
cost
227:12
229:16
233:17
costs
231:24
Council
215:15
counsel
224:10
230:18
235:13
count
218:4
221:2
counterprod
uctive
210:17
212:18
County
203:17
217:23
226:5
couple
201:2,5
218:3
240:15
254:24
February 24, 2016
Index: considered.. date
court
cruise
218:22
201:12
219:12
crystal
224:24
220:7
227:17
curiosity
cover
213:14
227:24
covered
233:18
crap
218:9
220:9
221:4
252:19
create
236:23
created
233:21,25
238:4
creates
216:15
credence
239:17
credibility
220:6
criminal
200:4
250:23
251:6,8,
16
criminally
218:20
219:5
crisis
212:7
cross
239:2
CROSS-
EXAMINATION
228:2
cuss
200:10
205:23
custody
215:18
cut
250:25
R
damage
220:16
damaged
221:16
222:4,14
damning
241:13
Dan
227:4,20
228:1
240:7
246:17
250:25
Daniel
225:11
245:25
254:16,20
data
233:13
235:23
database
241:17
date
211:6
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JOEL CHANDLER Volume 2 of 2 February 24, 2016
OBOYLE -vs- SWEETAPPLE Index: dated -documents
228:25
223:9,13
describing
219:13,14
245:5
234:11
245:18
220:17
250:13
define
247:15
236:16
222:23
description
discussing
dated
214:25
differences
209:5
definitivel
210:23
229:11
210:21
y
description
Dave
244:22
s
differently
239:24
213:21
239:16
200:20
242:2
degree
243:8
David
242:6
descriptive
difficult
discussion
201:19
240:23
249:5
delay
205:2
day
230:7
desire
difficultie
244:3
201:21
deliberate
219:4
s
251:16
202:4
240:19
237:11
desk
discussions
204:23
227:14
delivery
200:24
dig
210:10
238:11
224:7
DESOUZA
214:6
240:6
254:25
209:12,17
direct
243:18
delve
251:7
225:12,22
212:11
days
222:18
226:9,11,
253:17
distinction
200:18
demand
16,25
250:23
201:2
directly
231:25
227:5,17,
251:5
229:5,25
232:1
22 228:3
222:7
deal
234:2
240:1
directories
distinguish
214:2,7
demanding
246:2,8,
238:8
ed250:22
dealing
236:18,20
14,24
disappointm
204:6
247:2
ent
distressing
demands
248:13,19
249:8
241:22
240:22
233:5
251:2
deals
Denise
253:12
disclose
DJJ
250:16
236:18
254:2,18,
245:17
215:16
dealt
237:3,8
21,24
discuss
document
250:17
241:14,16
255:2
208:9,14,
205:8
debate
department p
detail
17,21
234:16
236:17
201:10
242:15
209:7
documented
214:9
tdeermine
211:22
237:3
deeply
243:21
222:18
departure
222:25
247:10
documents
230:20232:12,
dialect
Deerfield
discussed
17,23
239:14
deposition
200:14
207:14
233:5,8,
defendant
206:16
dialogue
208:3
12,19,21,
251:24
221.2
204:20
209:22
25 234:3,
254:6
210:13
5,7,9,15,
defendants
255:6
dictated
240:11
17,24,25
247:7
depositions
222:1
242:7
235:4,8,
defense
221:3
difference
244:4
19,22,24
ESQUIRE 800.211.DEPO (3376)
1 1 _ EsquireSolutions.com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: dollar.. expected
236:9,12,
201:3
199:17,18
203:19
establishme
14,23,24
254:25
220:9
nt
dump
237:12,
238:11
222:11
233:13
east
14,16,17
253:5
199.24
estimate
241:5,13,
duplicative
255:7
200:16
226:14
24 242:8
233:4
easyendeavored
ethical
dollar
238:10
26.7
212:14
218:24
E
ended
229:11
economic
Don
202:7
231:13
exact
222.2
e-mail
202:23
education
enemies
228:25
dont'
213:6,20
229:7
203:21
218:6
250:10
231:4
251:7
207:13
effect
enemy's
245:20
224:3,4
212:12
206:18
double
228:23
examination
230:4
engage
200:18
229:6,12,
233:9
13,17,18,
effort
2241:15
dozens
exchange
22,24
224:21
engaging
205:16
202:21
230:5,13,
225:5
223:22
draft203:25
24 231:2,
ego
enjoyed
205:21
236:20
16 236:16
221:15
211:15
206:16
237:3
237:23,
24,25
elaborate
enjoying
240:5
drafted
238:3,13,
212:19
207:4
ed
exchanged
g
237:7
17 239:23
252:17
enormously
237:23,24
dragon
240:5,8,
elephant
221:8
236:1
238:24
10
214:22,24
exchanges
enthusiasm
dramaticall
e-mailed
eliminate
230:21
236:16,21
y
239:22
231:12,22
239:1
217:19
entities
245:2
231:12
e-mails
employed
213:14
228'20
200:5
239:7
excited
drink
229:18,19
217:6
200:10
231:5,15
employees
entitled
199:8,10,
224:21
existence
drive
232:20,22
238:6
225:14
233:1
13 201:25
entity
227:14
237:22
202:11
204:13
exit
233:20
245:2
207:15,
212:16
234:10
234:5,6earlier
20,21
223:6
236:5
235:1,22
199:21
employment
229:14
exodus
237:19,20
216:10
222:21'23
equipment
242:14
238:7,10
236:2
235:9
235:11,20
expect
driver's
244:8,15
empty
221:24
201:18,20
248:25
214:16
error
233:16
218:21
drop
early
end
219:3,10
expected
ESQUIRE 800.211.DEPO (33 76)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
240:24
233:10
224:5,6
expecting
extreme
February
204:2
216:20
249:13
238:21
231:8
files
extremely
federal
expense
253:18
247:5
225:3,4
233:15
experience
199:21
203:5
252:3
experiences
203:5
experiment
199:24
200:19,25
explained
219:15
222:17
expletive -
latent
211:14
explicitly
223:10
express
244:6
expressed
219:4
248:24
249:7
expressing
242:12
extent
221:19
222:5
252:22
external
238:6
extraordina
rily
eye
207:9
237:10
F
face
232:5
245:4
facility
245:22
facing
201:11
fact
220:4
223:10
241:16
242:17
£acts
223:20
231:8
failure
223:12
fair
232:15
236:13
242:2,7,
11 243:1
fairly
211:21
fancy
211:12
fashion
240:9
fax
fee
231:25
232:2
feed
222:24
feel
204:4,20
218:17
226:23
250:4
feeling
241:1
feelings
230:8
250:4
fees
231:25
felt
211:20
216:2
217:12
field
214:16
figure
210:4
234:20
243:14
file
217:23
223:8,20
238:5
24 7: 25
248:6,20
filed
218:22
224:8,9,
February 24, 2016
Index: expecting -form
13 234:13
five-minute
247:6,15
226:25
249:13
flavor
250:21
231:8
files
flirting
237:22
206:5
filing
flirts
236:25
206:5
247:11,17
Florida
filled
199:24
219:7,11
213:10,13
financial
218:19
222:18
221:10
find
254:5
203:22
flower
210:8
236:21
214:14
fly
237:19,20
209:15
fine
210:5
215:18
244:11
226:3
flying
246:17
209:8
254:10
focus
finish
207:20
225:1
222:6
fire
Focussing
199:6
231:15
226:6
228:1
folder
235:21
237:24,25
240:24
238:1
firm
follow
207:17
248:2
221'8
forgotten
231:13
250:4
239:15
241:14,
form
17,22
244:10,19
248:8,17
firmly
251:13
218:2
253:10,
fishing
11,13
218:7
ESQUIRE 800.211.DEPO (3376)
11 <. EsquireSolutions.com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
formula
friend
218:25
205:22
forthcoming
friends
248:22
199:22
249:15
front
forward
200:24
222:6
207:3
245:17
222:10
237:8
Foster
207:16
fuck
found
219:18
252:13
201:23
241:22
fucked
245:18
213:11
foundation
223:18
200:8
fucking
201:3
222:12
202:15
fuel
210:4
227:12
212:22
213:3
full
220:2,4
216:21
221:9,22
236:21
229:10,15
funds
frankly
218:6
204:1
funny
230:8
208:24
242:19
215:9
251:17
253:1,15
--
G
fraud
223:18
G4s
Frazier
214:10
241:21
gainfully
free
200:5
229:16
Gates'
frequently
222:2
223:8
250:1
gather
236:9,23
fresh
227:6
gathering
234:14
ESQUIRE
236:12
gave
208:18
211:13
234:21,22
237:19,20
242:25
gear
235:19
gee
223:13
general
224:10
240:5
generally
210:14
237:21
generating
241:16
gentleman
199:16
gentlemen
222:11
genuinely
242:21
Gill
199:1,2
209:14,21
225:9
245:25
246:4,12
251:13
253:10
254:16
gist
211:20
229:8,9
230:12
231:6
238:13
245:19
248:11
February 24, 2016
Index: formula..guess
give 222:5
201:17
gotcha
203:3 223:22
210:4
217:14
219:5,21
230:25
231:20
232:5
234:18
244:21
giving
229:25
glasses
243:3
goals
220:11
Goldstein
226:10,23
227:2
232:11,20
239:25
248:8,17
250:25
251:14
253:11,13
254:17,
20,23
255:4
Golf
199:8
Golly
223:13
good
199:22
216:7
219:25
221:11,20
244:25
250:7
252:8
253:5
goods
government
203:15
204:11
217:11
219:25
220:5
222:7
232:6
graciously
246:22
graduates
200:4
grant
235:17
Gray
241:20
great
212:13
217:14
240:2
242:15
246:14
greed
221:15
grind
215:13
Group
247:6
grow
244:11
grudge
212:23
guard
242:19
guess
207:16
213:6
800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: guessing -ill
220:9,22
happy
214:6
hours
222:5,23
H
203:2
225:23
225:15
228:18
204:7,24
hell
226:17
244:13
212:20
227:14
half
207.7
248:1
226:5
229:5,25
253:23
225:14
229:16
helping
238:11
226:11,
246:20
230:21,23
246:10
guessing
13,17
213:17
238:10
254:13,19
hesitation
254:24
246:10
harass
242:13
house
Gulf
199:3,11,
Hall
213:12,16
hesitations
212:2
15,17
207:3
hard
243:22
215:6,8
218:24
201:8
handed
218:11
Hey
202:23
201:1820
,
226:14
237:3
housewives
204:4
233:20
207:6
207:4,6,
hands
234:5,6
hierarchy
15 211:3
202:20
235:1,21
238:4
Hudson
199.2
212:13
252:14
237:19,20
hired
245:25
213:21
hang
238:6
209:15,17
254:3
214:18,20
226:5
hat
213:24
215:2,5,
239:3
222:13
215:14
human
13,25
238:20
216:4,6,
hanging
hate
hiring
19 217:4
199:19
226:4
215:14
hundred
219:8
240:20
208:19
Hawaiian
history
242:1
Hanna
252:24
200:4
hundreds
247:6,16
239:18
216:8
252:19,21
249:3
head
hold
235:7
207:7
222:12
238:2
guy
happen
231.4
244:16
200:21hurt
211:9
252:2,11
home
215:23
222:4
220:4,5
249:12
244:12
hear
225:14
230:8
250:7
247:14
208:13
homestead
250:4
253:21,25
253:24
209:12
218:23
215:1
guys
happened
244:25
hood
I
200:2,9
204:8
200:13
201:13heard
221:6
horns
idea
220:8
231:22
209:1018
,
240:25
203:12
222:11
234:20
216:6
216:7
225:12,13
236:15
252:1
hostile
239:9
226:3,18
249:15
hearing
205:23
249:16
227:9,16
216:3
hour
233:5
happening
ideas
207:7
232:1,2
225:13,14
203:8
246:11,
251:7
226:12,
21,23
216:2
13,15,16
ill
253:12
243:15
heels
249:11
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. corn
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: illegal..justice
250:15
incentive
intention
Islamic
join
illegal
231:13
223:16
215:15
251:14
213:1
inclined
interact
235:13
254:23
245:13
210:16
203:18
issue
joked
illegally
include
206:1
232:12,16
207:8
220:22
227:12
interchange
244'2
Jonathan
245'7
imagine
including
199:16
249:10
212:10
200:11
241:20
interest
250:13,14
221'7
206:2
223:7
253:21
Jonathan's
income
227:15
231:21
254:1
221:15
222:19
immaterial
223:24
250:9
issues
Jones
218:21
indigent
interested
212:3,4,9
207:16
219:10
218:21
213:23
214:8
Josh
immediately
219:7,10,
215:13,24
215:12
254:3
223:11
12
interests
217:11
255:2
215:17
222:18
immunity
indisputabl
241:23
Joshua
204:18
a
intervene
244:8
205:22
impacted
223:21
224:12
245:5
232:11
221:12
individuals
intimately
250:16,17
judge
impassioned
248:7
232:12
items
224:24
211:14
inducement
inundate
243:13,23
232:10
important
252:10,18
213:15
_.
judgment
214:7
information
inverse
J
216:18
201:19
252:9
July
impose
205:8
226'1
invited
Jeff
243:3
241:19
221:24
241:20,21
June
impression
239:19
initial
involved
Joann
210:19,
215:5
239:6
207:18
24,25
improper
239:23
228:15
211:1
242:4
240:4,11
involving
230:10,
228:5,10,
245:10,13
241:4
249:8
13,15
12,15,18
improve
injunction
ironically
232:4
229:4
203:10
232:9
208:19
249:7
230:1
219:11
234:10
impulse
instance
job
239:10,12
213:8
204:12
irreconcila
223:16
242:24
inadvertent
instances
ble
Joel
229:10
jug,
218:20
210:12
225:17
206:2
219:9
irrelevant
227:9
instruments
218:21
228:4
3ustice
inappropria
lit y
219:10,14
244:16
214:9
to
241:25
254:4,7
215:21
212:25
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
Juvenile
214:9 L
K
kids
214:8,12,
15 218:2
kids'
218:5
kind
199:18
200:12,
13,24
201:11
202:20
205:5
207:6,8
208:7,8
210:2
211:12
212:1,7
214:2,11,
17 215:18
216:22
224:19
227:5
230:8,20
233:13
238:23
23 9:2 1
240:18
250:4
251:16
252:4,5,
17
knew
215:12
245:17
knife
217:4
labor
2 05: 12
lady
2 02: 6
laid
237:4
248:12
Lakeland
227:8
240:18
241:8
245:4
254:4
language
229:7
large
222:5
235:21
law
2 07: 17
221:8
222:3
224:25
225:3,4
231:10,
13,20
237:6
239:14
241:14,
15,17,22
lawful
205:13
lawfully
236:1
lawsuit
234:13
247:6,10,
11,17,25
248:2,5,
February 24, 2016
Index: Juvenile..lower
6,21,23
215:3,8
231:14
249:13,15
216:5
lives
250:21
letter
215:20
251:3,10,
210:18,22
221:13
25
Levy
living
lawsuits
203:16
225:1,2
230:25
236:20
liability
lodging
237:3
231:11
227:12
241:16
232:1
logically
lawyer
license
233:10
231:20
201:18,20
long
League
life
226:10
213:13
214:6
229:1
219:9,17,
230:7
leave
236:15,16
22 231:23
longer
240:6
253:4,24
226:18
light
leaving
lookout
228:7
239:11
200:24
237:2,15
limit
lose
246:22
left
224:16
220:1,15
limited
231:9
226:20
240:13
loss
228:4
253:18
221:5
229:9
lingerie
232:20
225:20
lost
234:1
218:4
235:6
list
221:2
236:17
212:12
lot
238:13
213:5,6,
202:17
242:24
7,8,9,11,
214:7
legal
13,19,20
216:15
202:25
214:12
221:13
217:2
203:3,4
222:7
212:14
literally
227:23
222:1
233:14
legally
239:15
201:14
litigating
202:8
Lou
legislators
237:25
221:25
litigation
203:6,8,
love
legitimate
9,18
210:7,8
200:25
220:13,21
214:2
lower
223:3,22
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: Macbook..money
232:10
225:2
248:1,21
meetings
million
226:4
252:21
211:3
218:24
237:15
254:21
M
member
mind
246:19
Marty's
253:20
223:15
250:23
Macbook
251:5
208:24
memo
227:6
21:16
231:11
235:14,15
254:7
220.6
2144:4
machine
making
221:15
237:7,8
mine
235:25
201:22
men
199.22
matter
machines
212:14
218:25
214:23
minor
225:6
218:11
236:14
mention
223:23
244:20
238:7
made
250:15
matters
203:24
207:10
minority
202:7
210:23
205:1
manager
232:22
221:13
216:19
202:1
maximum
mentioned
222:8
217:22
224`12
219:5
199:9
minute
219:13
mark
mayor
204:25
205:10
223:25
220:12,13
207:24
208:1
243:18
233:4
210:18,22
212:11
254:2
Marrett
234:2
228:12
239:18
merged
minutes
236:20
249:3
meals
229:21
226:6,20
237:13
227.14
245:23
241:24
Martin
mess
246:3,9,
243:12
203:24
meaning
240:20
252:23
205:1
236:22
15,16,23
messages
206:4,23
mistaken
magnificent
means
209:9
218:6
207:10
217:10
203:21
214:21
m et
230:10,17
223:15
mail
222:15
207:23
233:24
224:7
247:7
meant
217:5
234:2
229:21
209:2
240:22
Marty
mitigate
maintained
203:11
210:5
methodicall
231:11
213:21
233:25
206:5,25
237:1
y
modified
make
207:12
233:11
222:2
200:2,17,
211:10
meet
Miami
18,25
212:10
221:25
200:1
moment
213:19
233:7
206:2
201:4,10
245:7
Miami's
203:22
215:1
231:23
money
205:18
217:3
meeting
216:11,23
206:3
220:3,16
199:16
middle
218:18
212:15,22
229:1
202:5,19
218:2
222:21,25
213:8
235:10
206:23
250:25
223:16,19
216:13
239:7
211:6,9
midst
224:20
219:20
240:22,24
237:9
212:8
231:24
224:25
241:25
245:3
ESQUIIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
month
214:14 M
236:19
242:25
naively
243:5 242:20
months
named
229:3 248:2
250:3
ESQUIRoE
211:9
noteworthy
204:12
notice
254:12
notificatio
n
224:8
number
206:9
213:10
218:4,19
231:3
O
O'boyle
203:24
205:2
206:4,23
207:10
208:3,14
209:8,15,
22 210:11
211:22
217:5,7,
16 220:3
221:7
222:15
229:2
231:13
239:14
241:17,22
247:7,18
O'boyleIa
208:1
211:17
214:21
215:1
221:16
O'connor
2 07: 18
228:16
February 24, 2016
Index: month -operation
230:10,13
nature
Morgan
241:12
202:9
210:3
206:11,
navigating
15,16
233:8
210:18,22
neatly
228:13
233:10,14
morning
necessarily
199:17
213:1
202:15
office
253:22
negative
motivation
239:11,
208:9,21
18,21
209:2
officer
object
network
mouth
233:2
218:18
202:16,18
251:13
nice
mouths
199:20
222:24
201:21
move
206:21
244:23
235:21
254:13
moved
212:5
night
240:17
225:18,21
255:3
246:20
moving
older
212:14
255:2
222:6
one-off
multiple
non -
observed
objection
229:17
214:1
occasion
255:5
municipalit
203:15
nonevent
ies
199:20
218:19
220:5
200:7
nonexistent
Muslims
222:6
Ocean
215:4
215:17
nonsensical
mutually
244:2
235:18
234:13
227:3
operated
offer
note
ESQUIRoE
211:9
noteworthy
204:12
notice
254:12
notificatio
n
224:8
number
206:9
213:10
218:4,19
231:3
O
O'boyle
203:24
205:2
206:4,23
207:10
208:3,14
209:8,15,
22 210:11
211:22
217:5,7,
16 220:3
221:7
222:15
229:2
231:13
239:14
241:17,22
247:7,18
O'boyleIa
208:1
211:17
214:21
215:1
221:16
O'connor
2 07: 18
228:16
February 24, 2016
Index: month -operation
230:10,13
238:14
249:7
offered
O'connor's
210:3
230:15
233:7
252:24,25
Where
211:13
offering
216:4,18
202:23
248:1
230:25
249.9
office
253:22
208:20
Where's
239:14,15
211:19
officer
object
199:14
244:10,19
201:17
248:8
202:16,18
251:13
207:8
253:10,
officers
11,13
199:15
objecting
officials
246:12
203:17
objection
204:19
255:3
206:1
objections
older
212:14
202:6
objectives
one-off
213:3
214:2
observed
one-time
253:7
214:1
occasion
open
250:14
203:15
217:10
occurred
220:5
200:7
222:6
Ocean
232:6
200:15
opening
October
244:2
235:18
operated
offer
223:6
202:25
operation
204:17
230:3
230:24
800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: opinion -poison
opinion
217:11
period
place
217:16
P
250:8
229:3
201:7
221:18
249:25
249:25
202:13,14
pay
239:17
p.m.
periods
214:11
245:12
227:1
231:24
250:2
Plaintiff
250:18
255:6
246:8
253:7
payer
person
packed
225:3
217:10
plan
opportunity
217:6
227:18,20
peeked
224:14
223:19
222:10
pages
213:14
245:7
230:3
252:20
247:25
opposed
235:7
pejorative
231:15
paid
212:1
perspective
planes
249:4
209:8,15,
224:20
opposition
pen
17
213:25
235:17, 20
210:21
persuasion
painted
208:25
planning
ordinance
pending
246:24
Philosophic
211:23,25
210:23
248:6
al
Palm
lm
organizatio
people
229:11
play
n
199.25
203:15
205:24
200:15
phone
237:18,21
217:13
238:5
pariah
220:21,22
206:9
player
227:9
254:14
221:19
221:13,21
organize
222:8
230:16
pleasant
237:16
Park
238:18,19
225:2
202:20
238:3
214:10
240:10
229.19
238:25
organized
parked
230:21,
247:22
239:2,5
233:10,14
207:2
23,24
photograph
point
original
208:6
231:1,6
200:23
202:22
205:7
parking
232:7
pick
210:16
202:16
239:16
201:6
215:20
outhouse
241:21
214:17
part
248:2
pickup
:13
222255:20
218:24
207:2
outrageous
221.22
perceive
208:1,6
228:8,19
216:23
235:9
214:20
230:6
overconfide
238:9
253:2
pictures
232:14
nt
253:9
perceived
209:20
234:17
248:25
particulars
215:2
pike
236:4
252:3,11
238:18
overwhelmed
212:6
perception
239:22,24
233:13
passed
216:3
pissed
241:7
owned
253:16
220:18
213:22
243:25
235:19
perfectly
221:14
247:5
passionate
214:2
pitchfork
251:18
217:10
215:3
240:25
poison
patronizing
224:22
210:21
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions.com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
ESQUIRE
February 24, 2016
Index: police -question
police
practical
privilege
246:4
14,25
199:14,15
210:7,9
241:23
prosecute
224:1
201:9,10,
practice
242:16,
213:12
250:15
17
214:3
17'22
252:25
public's
202:16,18
237:6
243:13,22
217:24
206:19
244:8
prosecuted
241:15
245:6
218:20
publicly
polite
practicing
219:5
223:6
204:3
privileged
231:20
244:17
prosecution
pull
political
pre
249:2
201:14
208:8,25
Pro
212:24
251:3
235:14,15
prosecutor
pulled
213:25
prepare
249:4
201:16
Problem
214:3
237:16
214:1
prospective
pulling
politica
prepared
241:20
247:11
223:23
209:1
221:2
Proclivitie
protect
purely
236:5
Polk
s
236:10
235:24
216:9
present
210:14
protected
purposes
217:23
203:1
produce
215:10
224:23
223:6
presume
214:15
provide
234:18
226:5
248:11
224:13,17
235:10
pursue
poo-pooed
pretty
232:1
231:14
203:12
203:20
236:19
Provided
205:9
pushing
poor
225:16
produced
246:6
221:13
239:18
214:16
Public
222:8
240:17
232:14
199:9,18
put
253:20
233:20
200:2,17,
214:11
portions
234:24,25
18,23
218:17
248:10
prevailing
236:21
201:4,22
219:8,16
positively
248:25
202:7,24
220:6
221:12
prior
production
203:9,17,
234:17
237:15
224: 18
22 204:6,
possession
234:15
putting
243:9
9,13,16,
232:13
208:9
244:6
professions
19 205:1,
234:4
236:1
245:3
1
18 206:1
possibly
250:21
239:4
212:15,
-
251:24
Priority
projects
16,22
Q
potential
224:7
213:9
213:15
210:15
216:8,11,
qualified
prison
P
promise
14,19
230:17
pounding
214:13
254:2
217:17,22
215:19
219:9,16,
219:4,19,
question
19,22
Promisee
20 220:20
209:12
powers
252:23
221:17
219:1
240:24
private
218:2
proposed
223:3,12,
243:17
Esquire olutons.com)
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
244:14
251:1
253:5,10
questioning
226:1
246:5,12
questions
199:4
215:16
225:9,15
226:7
227:6
244:24
246:16,18
quickly
240:17
quit
237:10
quota
241:15
quote
244:21
7
racketeerin
4
247:17
248:6,16
249:23
radically
214:24
raise
205:24
ran
201:19
rationale
248:12
rattle
218:17
read
248:10
readily
249:1
ready
227:21
real
215:3
221:5
223:6
realize
215:1
216:2,14
reason
220:1
232:4
236:10
reasonable
231:25
254:12,
13,19
reasons
212:19
recall
202:10
205:4
207:14,
21,22
208:11,
12,13,23
209:5,6
210:20,21
211:2,13
228:23,25
229:6,8,
23
230:11,15
231:1,2
232:24,25
233:6
238:15,19
239:24
241:10,11
242:2,12,
15 243:7,
24 244:14
245:1,4,
11,15
247:21,
23,24
248:9,14,
18,21
249:2,14,
21 250:22
recalling
250:21
received
229:1
233:22,25
252:4
recent
223:24
recess
227:1
recipient
229:12,22
reckless
221:1
recognize
214:22
215:6
recognized
253:17
reconvene
246:3
reconvening
255:3
record
204:8
205:6
220:13
222:10
227:3
242:18
243:11
February 24, 2016
Index: questioning -remember
245:7,24
254:11.18
records
199:9
200:2,17,
18 201:4,
23 202:7,
24 203:9,
22 204:6,
13,16
205:1,18
212:15,
17,22
213:15
216:8,12,
13,14,19,
24
217:17,
22,25
219:19,20
220:20
221:17
223:3,12,
14,25
224:2,13,
15,17
232:1
250:15
recurrences
231:22
reduce
231:13
reels
218:7
reference
243:25
251:24
referred
241:21
referring
213:4
215:25
234:14,16
reflective
237:21
regard
204:4
250:24
regularly
239:13
related
215:4
222:7
Relations
215:15
235:14
relationshi
ps
221:21
relied
240:23
religious
215:17
relish
222:9
remarkably
241:3
remedial
224:20
remember
205:6
206:8
210:12
211:6,11,
18 212:3,
4,6
229:7,17
230:7
231:18
232:3
238:17,20
239:13,15
244:20
245:16,
20,21
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: rental -sense
249:24
19 219:19
230:15
rodeo
scheme
250:5
223:25
234:15
216:9
212:1
251:7,15,
250:15
responsibil
Roeder
school
17
reschedule
ities
237:25
217:23
rental
254:6
219:17
218:3
227:12
room
research
rest
236:17
scores
repeatedly
213:25
219:9,16,
205:16
root
233:6
22
reserve
238:8
Scott
reporter
216:17
result
202:9
roughly
227:17
residents
229:10
249:14
206:11,
reports
207:4
235:11,17
15,16
routine
241:18
210:19,23
return
207.1
scouring
represent
resignation
235:18
236:24
199:3
230:1
returned
rumors
screw
252.1
representat
resolve
235:22
213:23
ion
202:24
review
run
screwed
208:18
221:17
231:11
221:6
216:4
214:10
represented
resource
RICO
232:9
230:18
204:23
247:5,10,
running
250:11
208:22
11, 25
screwing
representin
respect
209:3
248'20'23
211:20
g
202:12
241:14,18
249:2,13,
214:18
229:14
203:23
15,21,22
Ryan
215:21
206:19
reputation
250:9,18,
212:10
253:22
220:16
210:10
21,23
217:17
secretary
222:14
251:3,4,
249.21
S
224:11
request
251:10
6,8,11,
200:17,19
12,17,19,
seeking
respects
22
sadness
218:19
202:7
203:22
241:2
RICOS
221:5
selling
205:1,18
respond
249:5
sale
212:3
216:12
203:8
218:8
217:22
230:9
rid
223:1
seminar
218:9
203:16
223:12
231:6
sales
234:16
238:15
Ridge
218:4
seminars
253:3
200:15
219:21
requests
sate
222:21
200:2
responded
rights
224:10
201:4,23
230:5,10
217:8
send
203:9
231:2
saving
216:7
204:6
238:16
River
231:23
215:20
sending
212:15,22
240:9
scheduling
228:23
213:15
road
206:15
216:8,14,
response
226:19
240:17
sense
ESQUIRE 800.211.DEPO (3376)
S 0 L U. 1 0 N S Esquire Solutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: sensed -stopped
215:6
shortly
snippy
speak
201:13
216:1
230:2
205:5
211:11
225:3
217:3
show
social
special
started
220:19,23
242:9
199:24
205:9
199:25
221:5
200:19
213:9
200:15
240:11
showed
216:25
227:5
242:9
software
sensed
230:3
241:18
specific
253:19
aide
236:9
210:2
sold
205:19
sentence
210:12
starts
215:7
218:6
219:6
213:5
223:17
216:3,6
solely
231:17,19
served
state
sign
240:23
243:24
224:23
223:7
207:3
somebody's
249`24
224:11
server
208:8
212:23
speci£icall
233:2
211:23,25
236:25stated
y
255:4
service
signs
sophiaticat
209:2
205:9
210:3
213:21
statement
ed
216:25
212:2,5
229:20
245:5,22
234:22
serving
similar
248:10
240:18
Sopranos
242:18,25
215:21
241:3
251:21
speech
243:3,9,
set
244:7
211:16
12,14
218:6
simple
sore
215:11
244:1,3,
207:9
setting
216:11
spite
20 245:23
232:8
sincere
sort
223`9
statements
202:9
settle
217:12
212:6
spoke
243:12
224:16
single
221:23
202:15
states
204:12
204:12
222:20
204:25
223:10
sexy
218:12
237:17
228:19
staying
shaking
sitting
sorts
spoken
226:24
206:2
241:23
207:23
207:
219:16
228:7,12,
stays
share
sound
15
216:24
slights
216:20
203:4
squirrel
stent
220:19
215:2
sounded
237:12
224:4
slip
238:20
sharpen
St
sticks
217:4
225:19
sounding
219:3,15
231:4
slow
238:24
sheer
Staal
stipulation
207:5
233:11
sounds
218:7
254:3
small
214:11
shoes
staff
stop
216:14
211:12
source
222:2
201:6,11
shook
smoke
222:19
start
stopped
200:10
202:20
ESQUIRE 800.211.DEPO (3376)
1 EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
199:19
straight
200:9,11
218:13
253:20
strategies
231:10
strategy
203:7
Stream
199:3,8,
11,15,17
201:8
202:23
204:4
207:5,6,
15 211:4
212:13
213:21
214:18,21
215:2,5,
13,25
216:5,20
217:4
240:20
242:1
247:6,17
252:20,21
Stream's
216:6
street
201:14,15
253:16
strictest
220:23
strike
247:4
struck
212:24
215:6
struggled
204:5
struggles
202:24
stuff
214:17
215:9,18
226:17
233:6
251:19
subfolders
238:2
subject
204:13
212:16
223:14
224:1
241:5
subjects
227:23
242:14
subsequent
204:15
substance
202:10
242:8
243:8,15,
19 244:5
substantive
242:3
succeed
219:16
successful
221:8
suck
231:9
sued
204:15
205:13
223:5
229:14
230:22,23
suggest
246:22
suing
203:15
248:15
251:10
suit
217:23
223:8,20
224:9,14
sums
231:24
Sunshine
221:23
support
217:15
supposed
203:13
210:5
237:1
surprised
204:1
suspect
210:16
swap
210:3
Sweetapple
206:14
227:20
228:8,19,
24 229:25
232:14
233:3
234:19,22
237:23
238:12,15
239:6
240:9,12
242:3,12
243:12,
20,21
244:5,6,
15 245:11
February 24, 2016
Index: straight -telling
247:3,12,
16,24
248:4,14,
22 249:22
250:22
251:4,23
253:6,8,
15 254:17
Sweetapple'
s
240:23
switch
244:14
sworn
234:22
240:18
242:18,25
243:3,9,
11,14
244:1
245:23
system
241:18
T
tail
240:25
taking
223:16
236:25
talk
199:7
203:17
204:21
209:24
230:19
238:18
246:9
talked
202:1,4,
6,16
203:11
209:1
222:20
230:20
231:1
240:21
249:10,25
250:1,5
253:8
254:25
talking
203:2
233:19
234:6
235:1
238:12
242:13
246:20
247:21
249:20
251:19
Tallahassee
220:10
221:25
taped
200:23
target
214:21
tax
225:3
team
254:14
technical
219:3
223:23
telephone
202:9
231:16
245:2
telling
211:12
244:16
245:16
248:14
O ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. corn
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: tells -1 -1 -turn
tells
214:6
25 217:9,
231:23
transparenc
216:18
218:8
13 218:2,
232:4
y
tenth
236:25
10,18
251:4
203:10
237:2,9
221:1,23
252:13
219:25
218:10
241:24
224:21
tonight
trap
tenure
242:1
225:5
202:14
244:17
227:3
226:19
218:17246:1,3
241:6
245:9
232:22
treated
terminated
thought
233:22
top
200:20
223:11
213:3
234:25
210:16
treating
terms
215:9,10
238:14
total
211:21
230:9
239:7
200:9
224:2
243:22
trigger
242:24
231:3
244:7
touch
223:24
243:7
236:15
245:3
triggers214:23
252:8
237:16
238:23
246:7,19
touching
203:6
Terrell
241:24
253:15
214:25
trip
201:1,13
242:4,18,
timeframe
town
226:4
testified
20 244:2
228:5
199:3,8,
217:5
245:10,12
234:23
11,15,17
troubled
236:2,9
248:24
timeline
200:16
249:6
testify
thousands
234:10,11
201:9
troubling
221:25
216:8
242:24
207:8,15
199:22
235:7
243:7
208:15
201:23
testimony
209:8,16
245:19
212:11
Thrasher
times
210:19,
228:20
202:1,13,
208:17
22,23
truck
19
209:1
211:3,20
207'2
texture
210:13
208:1,6,
212:7
threat
214:20
10
253:2
218:14
215:2,25
theater
232:9
216:4,19
true
210:7,8
threatened
250:1,5
219:3
217:21
252:21,23tiny
theatrical
247:16
Truth
207:1
threatening
219:2
254:16
225:22
210:14
252:4
today
towns
type
thing
threats
236:3
207:16
230:25
200:24
229:1
249:1
211:23
212:7
230:3
253:14
towns
typing
214:3
253:3
227:19
told
200:21
216:22
Tilex
201:20
224:17
201:1,13
204:18
toys
U
250:9
220:25
time
205:12
251:18
199:5
208:4,18
transcript
p
U-turn
things
203:12
216:22
244:1
201:10
204:21
209:9,15,
225:22
ESQUIRE 800.211.DEPO (3376)
Esquire Solutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
February 24, 2016
Index: ugly..work
ugly
unlike
violations
wanted
252:7
205:15
205:21
248:16
201:22
whispering
ultimately
unseemly
251:11
216:10
253:12
201:2
220:24
visit
217:3
219:8
White
253:23
240:17
upset
227:5
200:20,21
unaware
205:23
vividly
wanting
wife
204:12
232:3
237:2
238:1
unbelievabl
V
voice
Wantman
willingness
y
205:24
247`6
245:17
221:10
238:24
vacation
underlying
252:24
volume
warm
win
204:3
230:24
250:13,14
233:11
valid
249:5
undermine
248:5
255:7
warn
243:20
wings
232:6
volunteer
valuable
244:11
231:17
warned
underneath
221:10
237.9
W1re
216:25
Volvo
Van
235:21
understand
218:7
218:17
warning
227:10,11
242:16
witnessed
205:19
varied
253:7
210:5
wasting
231.7
213:8
W
203:12
woman
233:12
Velcro
200:10
watch
210:2
unequivocal
wait
246:19
women
ly
vendetta
244:24
251:20
206:6,10
224:1
212:23
waiting
watching
word
unethical
vendor
201:8,12
207:4
223:17
213:2
224:12
214:12
239:2
water
220:24
vengeance
223:22
213:23
words
242:4
242:1
waive
214:5
220:12
245:10,12
242:22
236:3
253:9
versus
wealthy
245:20
unfair
246:10
waiver
218:1
248:18
249:11
videos
244:8
wearing
252:5
unfortunate
205:16
waivers
211:12
work
220:25
viewed
243:22
225:23,24
200:8
204:22
walk
week
201:2
unilateral)
vindicate
201:5
204:23
202:23
y
223:11
217:24
walking
236:19
204:21
210:6
unlicensed
violation
201: 14
weeks
216:15
237:6
204:16
wall
206:12
217:7
241:15
223:23
208:20
229:3
218:7
236:5,8
whiff
221:11
ESQUIRE 800,211.DEPO (3376)
EsquireSolutions. com
JOEL CHANDLER Volume 2 of 2
OBOYLE -vs- SWEETAPPLE
223:19
223:5
235:18
worked
199:25
years
working
218:13
233:22
Youth
235:3
214:10
worried
Youtube
220:15
203:19
205:17
worth
226:17
wrap
204:5
wrapped
250:11
write
217:25
writing
236:4,8
written
210:22
213:5
237:7
wrong
225:17
252:14
wrote
237:10
Y
yard
218:4,8
223:1
yards
201:16
218:3
year
218:10,
13,17
219:6
ESQUIRE
February 24, 2016
Index: worked..Youtube
800.211.DEPO (3376)
EsquireSolutions. corn