HomeMy Public PortalAboutPRR 16-2165RECORDS REQUEST (the "Request")
Date of Request: 04/25/2016
Requestor's Request ID#: 1219
REQUESTEE: Custodian of Records Sweetapple. Broeker & Varkas
Custodian of Records Jones, Foster. Johnston & Stubbs
Custodian of Records Town of Gulf Stream
Custodian of Records Richman Greer, P.A.
Custodian of Records Cole Scott & Kissane (Palm Beach Lakes)
Custodian of Records Cole Scott & Kissane. (Lakeview Avenue)
Custodian of Records Johnson Anselmo Murdoch Burke Piper & Hochman. P.A.
REQUESTOR: Martin E. O'Boyle
REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com
Fax: 954-360-0807 or Contact Records Custodian at recordsna commerce-groumcom:
Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST: Please provide a copy of the transcript (including all exhibits) resulting from the hearing of
June 16, 2015 and relating to the litigation styled: CG Acquisition Company. Inc. vs. Town of Gulf
Stream (Case No. 502014CA007123XXXXMB). To the extent that the documents requested are not in
the possession of any of the Requestees. please amend this Request on a daily basis until such time as the
requested documents are available.
ADDITIONAL INFORMATION REGARDING REQUEST:
THIS REQUEST IS MADE PURSUANT TO ARTICLE 1, SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119,
FLORIDA STATUTES
IF THE PUBLIC RECORDS BEING SOUGHT ARE MAINTAINED BY YOUR AGENCY IN AN ELECTRONIC FORMAT PLEASE
PRODUCE THE RECORDS IN THE ORIGINAL ELECTRONIC FORMAT IN WHICH THEY WERE CREATED OR RECEIVED.
SEE 6119.01(2)(F). FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS
RECORDS REOUEST BE FULFILLED ON Il X 17 PAPER, NOTE: IN ALL CASE (UNLESS IMPOSSIBLE) THE COPIES
SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2)
ALSO PLEASE TAKE NOTE OF 4119.07(I)(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT 'IF A CIVIL ACTION
IS INSTITUTED WITHIN THE 30 -DAY PERIOD TO ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO
THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF THE RECORD EXCEPT BY
ORDER OF A COURT OF COMPETENT JURISDICTION AFTER NOTICE TO ALL AFFECTED PARTIES."
ALL ELECTRONIC COPIES ARE REOUESTED TO BE SENT BY E-MAIL DELIVERY.
PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE.
It will be required that the Requester approve of any costs, asserted by the Agency (as deRned In Florida Statute, Chapter 119.01
(Detinitlons)), In advance of any casts imposed to the Requester by the Agency.
'BY FULFILLING THIS RECORDS REQUEST, THE AGENCY ACKNOWLEDGES THAT THE RESPONSIVE DOCUMENTS
ARE "PUBLIC RECORDS" AS DEFINED IN CHAPTER 119, FLORIDA STATUTES".
1/P/NP/FLRR - 07.28.20 15
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
April 27, 2016
Martin E. O'Boyle [mail to: records@commerce-group.com]
Re: GS #2161 (1216), #2164 (1212), #2165 (1219), #2166 (1218), #2167 (1220)
Provide a copy of all videos taken (or caused to be taken) of Joel Chandler on July 23, 2014 by
the Town of Gulf Stream (including, without limitation, any attorney's respresenting the Town of
Gulf Stream).
Please provide a copy of the transcript (including all exhibits) resulting from the depositon of
William Thrasher of January 30, 2015 and relating to the litigation styled: Martin O'Boyle vs
Town of Gut(Stream (Case No. 9:14 -CV -81248). To the extent that the documents requested are
not in the possession ofany ofthe requestees, please amend this request on a daily basis until such
time as the requested documents are available.
Please provide a copy of the transcript (including the exhibits) resulting from the hearing of June
16, 2015 and relating to the litgation styled: CGAcquistion Company, Inc. vs Town of Gulf Stream
(Case No. 502014CA007123AUM1B). To the extent that the documents requested are not in the
possession of any of the requestees, please amend this request on a daily basis until such time as
the requested documents are available.
Please provide a copy of the transcript (including the exhibits) resulting from the hearing of
February 3, 2015 and relating to the litgation styled: Martin O'Boyle vs Town of Gulf Stream
(Case No. 502014CA005189XX�L'1i IB). To the extent that the documents requested are not in the
possession ofany of the requestees, please amend this request on a daily basis until such time as
the requested documents are available.
Please provide a copy ofthe transcript (including the exhibits) resuultingfrom the hearing ofMarch
31, 2015 and relating to the litgation styled: Citizens Awareness Fouunation, Inc. vs Town of Gulf
Stream (Case No. 502014CA005771,UCC31B). To the extent that the documents requested are
not in the possession ofany ofthe requestees, please amend this request on a daily basis untilsuch
time as the requested documents are available.
Dear Martin E. O'Boyle [mail to: records@.commerce-u>_roun.coml,
The Town of Gulf Stream has received your public records requests dated April 25, 2016. The
original public record request can be found at the following links hU://www2.eulf-
stream.org/weblink/O/doc/89889/Pagel.asnx, htty://www2.uuulf-
stream.ore/weblink/O/doc/89971/Pagel.asp , htta://www2.gulf-
stream.org/weblink/0/doc/89972/Pagel.asox, hgp://www2.gulf-
stream.org/weblink/0/doc/89973/Pagel.asPx, and httn://www2.gulf-
stream.org/weblink/0/doc/89974/Pagel.aVxx. Please be advised that the Town of Gulf Stream is
currently working on a large number of incoming public records requests. The Town will use its
very best efforts to respond to you in a reasonable amount of time with the appropriate response
or an estimated cost to respond.
Sincerely, Town Clerk, Custodian of the Records
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Case No. 2014-CA007123AA
CG ACQUISITION COMPANY, INC.,
Plaintiff,
VS.
THE TOWN OF GULFSTREAM,
Defendant.
X
PROCEEDINGS BEFORE THE
HONORABLE PETER D. BLANC
June 16, 2015
2:30 p.m. - 3:10 pm.
205 N. Dixie Highway
West Palm Beach, FL 33401
Jennifer DiLorenzo, court reporter
June 16, 2015
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PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM 2
1 APPEARANCES OF COUNSEL
2
3 On behalf of the Plaintiff:
4 JONATHAN O'BOYLE, P.C.
BY: NICKALAUS TAYLOR, ESQ.
5 and GIOVANI MESA, ESQ.
1286 N. Newport Center Drive
6 Deerfield Beach, FL 33442
954-834-2209
7 ntaylor@oboylelawfirm.com
8
On behalf of the Defendant:
9
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
10 BY: JOANNE O'CONNOR, ATTORNEY-AT-LAW
505 S. Flagler Drive
11 Suite 1100
West Palm Beach, FL 33401
12 561-659-3000
joconnor@jonesfoster.com
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 Proceedings in the Matter of CG ACQUISITION COMPANY,
2 INC. vs. THE TOWN OF GULFSTREAM.
3 June 16, 2015
V
5 THE COURT: We are here on CG Acquisition
6 Company vs. The Town of Gulfstream, Plaintiff's
7 Motion for Protective Order. I received the
8 Plaintiff's motion and attached documents, I
9 received the Defendant's response with attached
10 case law.
11 I'll start with appearances of counsel,
12 please, first for the Plaintiff.
13 MR. TAYLOR: Yes, Your Honor. Nick Taylor
14 appearing for CG Acquisition.
15 THE COURT: Thank you.
16 MS. O'CONNOR: Joanne O'Connor for The
17 Town of Gulfstream.
18 THE COURT: Thank you.
19 Mr. Taylor, I have read your motion and
20 your attachments and your supporting authority
21 that I think came separately. What else do you
22 want to tell me about your motion?
23 MR. TAYLOR: Yes, Your Honor. What we
24 have here is essentially a simple public records
25 request case. We have filed a motion for
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protective order because the Defendant seeks to
depose the corporate representative of CG
Acquisition. The reason we filed this motion
for protective order is really simple, it's a
simple public records case.
Prior, Your Honor, I was here on a motion
for protective order I believe back in
September; similar cases, similar circumstances
for the same protective order. You did actually
deny that protective order and opposing counsel
is likely going to try to draw comparison with
the protective order that my client filed today.
The situations could not be anymore
different, and they're different because of
this: The deposition that was taken as a result
of that order happened September 15, 2014, that
deposition lasted eight hours, eight whole hours
of the deposition of Martin O'Boyle. Out of
that eight hours there was no more than 15
minutes of that deposition that actually
pertained to the facts of the public records
request, the rest of it was simply a fishing
expedition looking for anything possible to
prolong the deposition and, quite frankly,
harass my client.
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In this case we have a different scenario.
In this case it is a corporate representative
and they're seeking to depose the actual
corporate representative of the client. Case
law is clear --
THE COURT: Who is the corporate
representative?
MR. TAYLOR: One has not been designated
as of yet and likely will be, and which I don't
want to make an absolute assertion, but likely
William Ring, who I believe is vice-president of
the company, if I'm not mistaken.
THE COURT: Even now I think in your
responses they would be entitled to inquire into
two of the main areas listed.
MR. TAYLOR: Absolutely.
THE COURT: Is there any reason you
haven't designated the corporate representative
for those areas?
MR. TAYLOR: Well, the reason, Your Honor,
quite frankly, is just we were actually looking
for a blanket protective order based on case law
that limits, extremely limits actually, the
scope of depositions or the depositions at all.
They're extremely --
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THE COURT: Even now that have entitlement
to deposition in those two areas?
MR. TAYLOR: Yes, Your Honor.
THE COURT: You haven't designated a
corporate representative.
MR. TAYLOR: Not as of yet.
THE COURT: Okay.
MR. TAYLOR: And I was going to say, Your
Honor, if failing a complete blanket protective
order banning all depositions and all discovery,
we would at the very least request discovery
limited to an hour -and -a -half and be limited
only to the facts that are pertaining to the
public records request in that any depositions
and any discovery not get into the actual motive
of the requestor.
As 20 years of case law, and specifically
the Gadd case, which I can provide you a copy of
if you so want to, it provides that any
depositions that pertains to the motivation of
the requestor is irrelevant. In that specific
case the actual subpoena or the notice of
deposition was quashed. Would you like a copy
of that case, Your Honor.
THE COURT: I don't need it right now.
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CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 Thank you.
2 If I understand the issues in this case,
3 however, one of the issues in this is whether or
4 not all documents were produced as to one
5 request, because my understanding is that the
6 Town said they didn't have certain documents and
7 you basically say you don't believe them; and,
8 as far as the other, it was was their response
9 timely; in other words, was the timing of the
10 response reasonable or was it delayed
11 unreasonably? Doesn't that open up the
12 discovery to a bit broader area so that the
13 Court could use to determine those issues?
14 MR. TAYLOR: Your Honor, looking at the
15 Complaint, I believe the issues of the Complaint
16 is -- You're correct, the second count of the
17 Complaint actually states that they replied that
18 there were no records available. My client
19 disagrees with that and believes he has proof
20 that that's not the case.
21 THE COURT: If they have proof, wouldn't
22 the Defendant be entitled to see what that proof
23 is before trial, before a hearing on that?
24 MR. TAYLOR: Yes, Your Honor, and --
25 THE COURT: That's one of the areas they
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think should remain open.
MR. TAYLOR: Absolutely, Your Honor, and
the first --
THE COURT: What about they've suggested
in their response that there were hundreds of
public records requests made within a very short
period of time by what's in effect is the same
entity or similar entities or similar
identities, both individual and corporate, and
that affects what would be reasonable in terms
of the timing of their response?
MR. TAYLOR: Yes, and --
THE COURT: Wouldn't they be entitled to
some discovery on that as well?
MR. TAYLOR: Well, not in this case, Your
Honor, because if you look at the first count
that we amended, the first count the Defendant
essentially says they didn't produce the
documentation because the $1.54 copying fee was
not paid.
There's really no allegation that The Town
of Gulfstream didn't respond in time or that
they didn't do something correctly. The
allegation here is that they didn't produce the
records because the $1.54 was not paid.
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1 THE COURT: So I think Ms. O'Connor in her
2 pleadings suggested if you're willing to
3 stipulate that you're waiving any argument that
4 the response was untimely, that maybe some of
5 this discovery wouldn't be necessary; are you
6 telling me you're agreeing to her stipulation?
7 MR. TAYLOR: As to the $1.54 or --
8 THE COURT: As to the claim that their
9 response was untimely.
10 MR. TAYLOR: Yes, absolutely, Your Honor,
11 there's been -- The timeliness is not the issue.
12 The issue here is -- Well, I guess timeliness is
13 the issue if it's true that they have not
14 produced the documents at all because, I mean,
15 if they haven't produced it to now obviously
16 it's not in a timely manner, but their response
17 in saying that there were no documents available
18 or no documents existed, there's been no
19 allegation that that response from Gulf Stream
20 to the Plaintiff was not timely, so --
21 THE COURT: Well, there are two issues, as
22 I understand it; one is they say they don't have
23 any so they can't produce any, you challenge
24 that and said you don't believe them; the other
25 is the timeliness of the response.
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CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 I asked you if you received discovery of
2 information relating to other pending claims at
3 the time or within a short time frame within the
4 time of this claim as well as a number of public
5 records requests made; wouldn't all that be
6 discoverable in terms of their raising their
7 defense and your ability to challenge that
8 defense.
9 MR. TAYLOR: But the defense that they
10 would be raising would not be valid in this case
11 because, again, my client is not questioning the
12 timeliness of the response. We're saying that,
13 "You have documentation and you haven't provided
14 it," so whether they received --
15 THE COURT: You're talking about No. 2 and
16 I'm talking about No. 1.
17 MR. TAYLOR: Okay.
18 MS. O'CONNOR: There's two counts.
19 MR. TAYLOR: Yes, I'm aware of that. No.
20 1, the first count is essentially saying that
21 they --
22 THE COURT: They didn't respond timely.
23 They say, "Oh, we responded. We told them we
24 got it and we sent them a bill, an estimate of
25 the cost, and they never responded," I don't
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1 know whether you challenge that or not. If you
2 say, "We never received that," in effect it
3 seems to me you're saying, "They were untimely
4 in the response and on that basis that is just
5 like not giving us anything and so we should get
6 our fees."
7 MR. TAYLOR: Well, as it pertains to the
8 first count?
9 THE COURT: Yes.
10 MS. O'CONNOR: If I may, Judge.
11 THE COURT: Yes.
12 MS. O'CONNOR: I think the confusion Mr.
13 Taylor may have is that if you're looking at
14 your Amended Complaint, when they originally
15 filed the Complaint the Town's response had not
16 come out yet because they filed the Complaint we
17 submit prematurely, I mean, immediately.
18 Then they amended the Complaint after we
19 had actually responded and still pled it as an
20 unlawful refusal to provide any documents on
21 Count I when, in fact, we had responded, given
22 them an estimate, said, "We have 300 pages of
23 documents," this was back in June 2014.
24 THE COURT: Am I correct that your
25 response came about four weeks after the
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request?
MS. O'CONNOR: Correct.
THE COURT: So I'm assuming that there's
an issue whether the response four weeks later
is or is not timely, reasonable under the
MS. O'CONNOR: We submit so.
THE COURT: I assume you believe it is and
I'm assuming it was just a factual dispute
whether they sent you this estimate or didn't
send you this estimate, and you're not saying,
"Well, the estimate was too late even if they
did send it," then maybe a lot of this stuff
isn't an issue because it's just a question of
fact did they send you the estimate or did they
not?
If you're saying, "Well, they waited four
weeks and there's no reasonable basis under the
statute to wait four weeks," then that seems to
me the Court needs to consider what else was
going on at the time.
MR. TAYLOR: Your Honor, I think the issue
now in the Amended Complaint is actually the
$1.54, because we're stipulating that, you know,
they did actually let - we're stipulating that
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CG ACQUISITION vs. TOWN OF GULFSTREAM
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there was no issue regarding the timeliness with
this Amended Complaint.
What we're saying is with the $1.54 that I
guess Defendant is saying that they actually
produced the documentation and they produced the
letter stating that there was a $1.54 copying
charge, we do not have that, that was not in the
Amended Complaint. To be honest, I don't know
if it was sent. Again, I, as counsel, have not
seen it.
Now, if they did produce the documentation
and the amount has not been paid, that would be
something completely different. I think that we
would be able to take care of the first count as
it is.
If the actual $1.54 charge was not sent,
that will be an issue of fact, but at the same
time it would not have anything to do with
whether there was a timely response or not, it
would just be a question of fact as to whether
the notice of the $1.54 charge was sent or it
wasn't.
THE COURT: All right. I don't know where
it was that I saw it in your response, somewhere
you very cleverly stated the stipulations you
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1 thought would eliminate some of the discovery
2 request that you're making; can you pull that up
3 and read it into the record?
4 MS. O'CONNOR: Yes, Your Honor. Your
5 Honor, I don't see it here, but as to Count I we
6 would expect in order to avoid any discovery on
7 Count I, we would need a stipulation that the
8 Town's June 25, 2014 response to the first
9 public records request was timely provided.
10 In that request we provided an estimate,
11 advised Plaintiff - I don't know how much it was
12 for, I don't have our answer in front of me, but
13 we advised that we possessed 330 pages of
14 responsive records, so we need them to stipulate
15 that the Town did, in fact, respond to the first
16 request and did so timely.
17 As to Count II, in order to avoid --
18 THE COURT: Well, before you go to Count
19 II --
20 MS. O'CONNOR: Sure.
21 THE COURT: -- can you tell me what page
22 you're reading from?
23 MS. O'CONNOR: Sure, page 4, paragraph 9,
24 and I do have the correspondence attached as
25 Exhibit B to my opposition.
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THE COURT: Well, I can understand Mr.
Taylor doesn't want to stipulate that you sent
this and they received this notice of the cost,
but it seems to me the stipulation would really
have to say not that they are conceding they
received it, but they are conceding that aside
from that issue of whether it was sent or
received, they're waiving any other argument
that the response was unreasonable in its
timing; isn't that what you would have to have
to get you out of this discovery so you know
these other issues aren't really on the table
13 1 anymore?
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MR. O'CONNOR: Correct.
THE COURT: So if we're clear on Count I,
if what you're telling me is that the only issue
as to the reasonableness of their response is
whether they did or did not send this cost
estimate to you on the date they allege they did
it, then all this other stuff about the number
of cases pending, the number of claims pending
and all that may not have any relevance for
purposes of discovery.
MR. TAYLOR: That is correct, Your Honor,
if they did send that estimate. The only thing
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1 would be if they sent the estimate and the $1.54
2 was paid and then that was some months ago and
3 here it is June 16th --
4 THE COURT: Understood.
5 MR. TAYLOR: But to answer your question,
6 yes, Your Honor, if it was sent from The Town
7 and my client received it in a timely manner,
8 yeah, absolutely.
9 MS. O'CONNOR: Well, I think that
10 presupposes -- If he says his client received it
11 in a timely manner, that presupposes - I mean,
12 that creates a fact issue as to whether it was
13 timely.
14 MR. TAYLOR: Well, I'm --
15 THE COURT: Well, I'm not saying this
16 precludes all discovery. I'm still not clear on
17 what you're telling me, Mr. Taylor. Are you
18 agreeing the issue on the first request for the
19 public records that --
20 MS. O'CONNOR: And here's the response, by
21 the way. I don't know where the $1.54 comes
22 from or it's an estimate.
23 THE COURT: -- that you're willing to
24 agree that the only claim you're pursuing
25 against The Town for noncompliance is based upon
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CG ACQUISITION vs. TOWN OF GULFSTREAM
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the factual dispute as to whether The Town did
or did not produce to you timely this -- Let me
see if I can --
MR. TAYLOR: Your Honor, I believe when I
said, "$1.54," I believe that might be the page
amount because this I'm showing that the billing
is for two hours of administrative support for
$39.23. Again, I've never seen this until just
now.
THE COURT: I'm looking at paragraph 9 of
The Town's response, it says: On June 25, 2014
in response to the first request, The Town
advised Plaintiff that it was prepared to
produce responsive records to Plaintiff upon
payment by a deposit permitted under the Public
Records Act for the significant time and
expenses associated with gathering those
documents and the actual cost of duplication.
Now, am I correct that you've challenge
that, that allegation, that they gave you that
response on June 25th?
MR. TAYLOR: Your Honor, I do not know if
that --
THE COURT: You don't know whether you're
challenging that?
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MR. TAYLOR: No, I don't know if the
response was received on the 25th as of right
now.
THE COURT: It says The Town advised you
on June 25th. Is that fact in dispute as to the
accuracy of that allegation, that they provided
you with a cost estimate on June 25th?
MR. TAYLOR: Yes, that is in dispute as of
right now.
THE COURT: Knowing that that is in
dispute, whether it was produced, whether it
gave you the cost estimate, whether you received
it on or about that time, do you have any other
claims for noncompliance with the statute as to
Count I other than that specific issue?
In other words, Ms. O'Connor has raised on
behalf of The Town that the Court has to
consider all of the circumstances in determining
whether their response was reasonable and
timely, and so for that reason they want me to
open discovery regarding the other claims that
were pending; how many had been made in the past
few months; how many had been made that week,
that day, that sort of thing.
Are you telling me that you are not going
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1 to make an argument or that you're specifically
2 waiving any argument that based upon the
3 totality of the circumstances, their response
4 was deficient because of the timeliness or lack
5 of timeliness of it?
6 MR. TAYLOR: Yes, Your Honor, the argument
7 is not - we're not seeking to argue that their
8 response was not timely, that's why we believe
9 that any depositions that are taken or any
10 questions that are asked regarding how many
11 requests they received that week, whether it's
12 400 or 800 would be completely irrelevant.
13 THE COURT: So the basis then for your
14 claim that their response was not in compliance
15 with the statute is what specifically as to
16 Count I or Request I?
17 MR. TAYLOR: I guess, Your Honor, at this
18 point it would just be a simple matter of the
19 fees and whether the fees are actually adequate,
20 whether they're legally charged.
21 Again, I'm showing that there was a $1.54
22 amount and then I'm seeing this paper today
23 that's $39 and I believe 23 cents, so
24 essentially we're not challenging the actual
25 timeliness of the response of the letter that
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was sent from Gulf Stream, that would be the
only challenge, but, again, there is no
challenge to timeliness in the first count.
THE COURT: So you're only challenging as
to amount of the cost estimate that they gave to
you is being unreasonable.
MR. TAYLOR: Yeah. Oh, yeah.
THE COURT: And that's the only issue.
MR. TAYLOR: That's the only issue.
THE COURT: Okay. With that stipulation,
Ms. O'Connor, do you agree that limits your need
for discovery?
MS. O'CONNOR: Yes, Your Honor, to some
extent. We also have Count III for injunctive
relief in this case, and there's an allegation
there that claims that The Town's actions with
respect to providing records to the public
demonstrates a pattern of noncompliance with the
Public Records Act and a likelihood of future
harm in the form of denial of access to public
records to this Plaintiff and the public at
large.
I can tell you my concern. My concern is
I'm trying to move these cases towards
dispositive motion practice. I don't want to
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1 come in with an affidavit from The Town
2 outlining what was going on at The Town at the
3 time we received these public records requests;
4 i.e., we received 400 this month, we received
5 100 the week before, and have them try to refute
6 that evidence just prior to a summary judgment
7 hearing.
8 So, you know, I think I'm entitled to know
9 on what actions are they complaining about in
10 Count III. I don't want to go into -- And I can
11 represent to the Court that, and I think I've
12 told Mr. Taylor, I mean, the depositions -- And
13 I've tried to tee up depositions in a number of
14 cases and they've been met with motions for
15 protective order in every single one in which
16 we've tried to tee up a motion and trying to tee
17 up depositions.
18 I specifically picked the corporate
19 representative of the Plaintiff thinking that
20 would be the most fair. I'm not telling them I
21 need Mr. O'Boyle or Mr. Ring. I just want them
22 to come in with the corporate representative of
23 this Plaintiff with knowledge about the
24 allegations that have been made in this
25 Complaint.
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1 MR. TAYLOR: Well, Your Honor, that's
2 perfectly understandable, but based on past
3 practices not necessarily by Ms. O'Connor, but
4 The Town, other counsel with Gulf Stream, it's
5 clear that a lot of these depositions have
6 turned into fishing expeditions, marathons that
7 have either been meant to just drag out, have
8 nothing, nothing whatsoever to do with the facts
9 of the case, and just meant to drag out, they're
10 meant to harass.
11 Like I said earlier, the last deposition
12 that was on September 15th, seven to eight
13 hours, 15 minutes actually on the facts, and
14 it's not over, it never actually concluded.
15 That's what we're looking --
16 THE COURT: Let's right now try to limit
17 it to this particular case because you attached
18 transcripts from two other cases that I assume
19 are in front of me but aren't in front of me
20 today.
21 So your claim for injunctive relief, I'm a
22 little confused why it's paired in this cause of
23 action or grouped in this cause of action, is
24 probably more appropriate, in light of the fact
25 that you're telling me now the only defect
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1 you're claiming against The Town is that they
2 charged too much for copies.
3 Are you limiting your injunctive relief to
4 the same remedy, you want the Court to somehow
5 enter an injunction to say that, "Going
6 henceforward, The Town of Gulfstream can't
7 charge more or can't estimate more than X amount
8 of dollar per page," or something like that; is
9 that the limit of the injunctive relief you're
10 seeking as well?
11 MR. TAYLOR: Well, Your Honor, that isn't
12 the only thing. Again, we're alleging in Count
13 II that they have records that they just flatly
14 haven't produced. What my client is seeking is
15 an injunction based on these two actions that we
16 pled in this case.
17 THE COURT: The Count II, the
18 non -production, if I'm clear, you're not
19 claiming that has anything to do with an
20 unreasonable delay based upon the volume of
21 requests, you're saying they're not being
22 truthful with you, right?
23 MR. TAYLOR: Exactly, because they
24 produced some documentation or actually they
25 responded saying no documentation exists.
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1
THE COURT:
So is your request for
2
injunctive relief
today as part of this case
3
that's before the
Court today really just based
4
upon two different
grounds; one, that they have
5
to be truthful and
tell you what documents they
6
actually have that
are public records and
7
produce them and;
two, that they can't
8
overestimate the cost
of the production?
9
MR. TAYLOR:
Correct, Your Honor, and the
10
injunctive relief
is basically enjoining them
11
from violating Chapter 119 Florida Statutes.
12
THE COURT:
Well, that's a different issue
13
because there's a
lot of stuff in 119. If
14
you're telling me
today you're limiting your
15
injunctive relief
to those two things, then
16
again, I think that
may put some limits on the
17
discovery which Ms.
O'Connor's client is
18
entitled to.
19
MR. TAYLOR:
Yes, Your Honor.
20 THE COURT: Now, Ms. O'Connor, we have an
21 additional stipulation, that the issues here
22 relate to the first two counts only to
23 inappropriate cost assessments, they relate to
24 lack of candor in the documents that actually
25 exist, and that the third count for injunctive
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1 relief will seek relief only based on those two
2 grounds, so with that stipulation, what
3 discovery do you need?
4 MS. O'CONNOR: With that stipulation, Your
5 Honor, I'm just looking and it might be helpful
6 for us to walk through the topics of inquiry,
7 but what we need are - we would need the
8 discovery related to Count II, we would --
9 THE COURT: Can we do this, and maybe I'm
10 looking at the wrong thing, maybe you need to
11 direct me to the actual duces tecum.
12 MS. O'CONNOR: I have a copy.
13 THE COURT: I was looking at Mr. Taylor's
14 Notice of Filing Case Law, and on page 2 he
15 tells me they agree you should get topics 3 and
16 4, and then on the next two pages they list 1
17 through 15; are those all of the topics that we
18 need to address?
19 MS. O'CONNOR: I think he maybe got 3 and
20 4 from the - there's a document request as well,
21 that's the 30(b)(6) notice.
22 THE COURT: So you're asking me to look at
23 Exhibit B --
24 MS. O'CONNOR: Correct.
25 THE COURT: -- which has 15 different
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numbered paragraphs, and this is attached to the
Subpoena Duces Tecum Notice to CG Acquisition
with the case number that is hopefully, yes,
before the court today.
All right. So do items --
MS. O'CONNOR: I mean, it might --
THE COURT: Do Mr. Taylor's indication
that topics 3 and 4 --
MS. O'CONNOR: -- it might help --
THE COURT: -- relate to 3 and 4 on
Exhibit B?
MS. O'CONNOR: I think he meant the list
on Exhibit A.
THE COURT: All right. Let's take Exhibit
MS. O'CONNOR: Sure.
THE COURT: Does everybody have Exhibit B?
MS. O'CONNOR: Yes.
MR. TAYLOR: Yes.
THE COURT: All right. Let's go through
it, start with No. 1. Tell me what think you
need and why, Ms. O'Connor, what you think
you're entitled to and why.
MS. O'CONNOR: Well, this goes to - I
mean, if we'll have the stipulation on Counts I
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1 and III, then as to Count II, the Complaint is
2 replete with allegations that Plaintiff believes
3 there are additional documents.
4 So I don't know who they're going to
5 produce as the corporate representative, so I
6 think as a background matter I need to know who
7 are the related individuals, who are the
8 officers, directors, and employees that might
9 have information that they're going to come into
10 court at a hearing or in response to a summary
11 judgment and say, "Well, that wasn't our
12 30(b)(6) representative," but maybe they put up
13 Mr. Ring who's the vice-president as their
14 corporate representative, but then Marty O'Boyle
15 submits an affidavit saying, "I think there were
16 response to records and here's why," so I think
17 item one is clear background information.
18 Item two --
19 THE COURT: Have you asked for the
20 corporate representative pursuant to Carriage
21 Hills and the 1.130(b)(6).
22 MS. O'CONNOR: Correct, Your Honor.
23 THE COURT: So they're locked in on that.
24 If they produce Mr. Ring and Mr. Ring becomes
25 the spokesman for the corporation for those
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particular issues, so it wouldn't do Mr. O'Boyle
any good to come in and say, "Wait a minute, I'm
supposed to be it," because they've already
designated Mr. Ring.
MS. O'CONNOR: Hopefully so.
THE COURT: All right. Let's for now
eliminate 1. No. 2?
MS. O'CONNOR: I don't need No. 2, at
least at this point, depending on our
stipulation of Counts I and II.
THE COURT: No. 3?
MS. O'CONNOR: No. 3 is the foundation for
most of the other topics.
THE COURT: Okay. No. 4?
MS. O'CONNOR: I don't need 4 and 5 if
they're not challenging the timeliness of our
response.
THE COURT: Okay. No. 6, the purpose.
MS. O'CONNOR: Sure.
THE COURT: Most cases say the purpose
isn't really relevant.
MS. O'CONNOR: Well, if you look at Count
II they assert - and Count II goes to public
records request 549.
All four of these requests were made on
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1
the same day, May
13, 2014, and they all sought
2
to, according to
Plaintiff's allegation, to
3
trace the source
of funds that The Town received
4
pursuant to this
certain resolution. So when I
5
said the purpose
for the public records request,
6
it's going to - I
intended it to go to why did
7
they believe there
were documents? What were
8
they looking for?
20
9
They put at
issue in the allegations of
10
the Complaint why
they were looking for it,
11
what --
agreed, Mr. Taylor?
12
THE COURT:
So these are the ones, 548
13
through 551, that
you've said you don't have any
14
and they said, "We
don't believe you."
15
MS. O'CONNOR: 549 is the one that we said
16
we have nothing.
17
THE COURT:
Okay, 549.
18
MR. TAYLOR:
So, Your Honor --
19
THE COURT:
So I don't know that entitles
20
you to get to the
purpose, but I think you're
21
entitled to inquire why they believe you do have
22
documents related
to 549 and you say you don't;
23
agreed, Mr. Taylor?
24
MR. TAYLOR:
Absolutely, Your Honor.
25
THE COURT:
So not the purpose, but basis
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1 for belief that Defendant has responsive
2 documents, and that's 549 only.
3 Okay. Go on to No. 7.
4 MS. O'CONNOR: No. 7, again, this is Count
5 II, would go to attempts they've made to gather
6 documents that were responsive to this public
7 records request, and I can limit it here again
8 to 549, which is the subject of Count II. The
9 idea being if they have documents in their
10 possession in some sort of "gotcha" fashion
11 that, you know, we should know that they think a
12 certain document was responsive but wasn't
13 turned over, that's what we're trying to get to.
14 THE COURT: So No. 7, 549 only; agree, Mr.
15 Taylor?
16 MR. TAYLOR: I don't, Your Honor.
17 THE COURT: Tell me.
18 MR. TAYLOR: It refers to a third party.
19 For case law, it doesn't matter if a third party
20 has documentation.
21 THE COURT: Well, it seems like it would
22 be discoverable there because you're saying,
23 "They told us they don't have it, we think they
24 have it," so if they get to inquire already
25 under No. 6, what's the basis for your belief?
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So I'm thinking for under No. 6 they're able to
say, for instance, "Did you try to gather these
documents somewhere else related to 549; did you
get them?" Because that's really part and
parcel of - it may be part and parcel of why you
think they should be producing documents
pursuant to that request.
So it's not opening it up for every
document request, but if you, through your
attempts to gather documents, you found
documents responsive to 549 that they haven't
produced, I think they should be entitled to
that through discovery, so I'm going to give
them No. 7 as relates to 549 only.
Okay. No. 8?
MS. O'CONNOR: No. 8 is related to No. 7.
There are certain exhibits in the Amended
Complaint, A, B, and C that they've attached
when they walked through their allegations that
they believe that other documents exist.
THE COURT: Well, how does -- I don't have
A, B, and C in front of me, do they relate to
the request of 549?
MS. O'CONNOR: Yes. They're various --
There are certain receipts.
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1 MR. TAYLOR: There's receipts, there's
2 blind items for budgets, things of that nature.
3 I can't possibly see how they would actually --
4 MS. O'CONNOR: I --
5 MR. TAYLOR: -- how that would have
6 anything to do with the public records request
7 that's the subject of this proceeding.
8 THE COURT: Why are they attached to the
9 Complaint?
10 MR. TAYLOR: They're attached to the
11 Complaint, Your Honor, basically as proof to
12 show that Gulf Stream makes a pattern of
13 whatever they spend on -- This is really about a
14 specific fund, it's for I believe a construction
15 permit, it costs a certain amount, Gulf Stream
16 charges a certain amount, but it's not meant to
17 raise revenue, it's meant to offset certain
18 costs. My client simply wants to figure out
19 where the money is going.
20 The attachment to the Complaint is
21 essentially attached to show, look, they do keep
22 this documentation, they do code it when it's
23 spent on certain things, so because they do that
24 it's very hard to believe that, especially as it
25 pertains to Count II, that they have no
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documentation showing where they spend the money
or transfer it to.
THE COURT: So does it support your belief
that in response to Count II or to Request II
they have documents that they haven't produced?
MR. TAYLOR: It certainly suggests that,
but at the same time from what I'm gathering
from the information request they want to know
where the information came from.
MS. O'CONNOR: Your Honor --
MR. TAYLOR: What difference does it --
MS. O'CONNOR: -- I'd be willing to revise
8 to the effect we seek information on why you
believe that Exhibits A, B, and C support the
existence of additional responsive documents,
something to that effect, if that's acceptable.
THE COURT: So A, B, and C. Eight will
relate why and how Exhibits A, B, and C support
your belief that they haven't produced documents
under 549.
No. 9?
MS. O'CONNOR: No. 9 goes to Count I, and
the reason for No. 9 is even after amending the
Complaint they continued to allege that this was
an unlawful withholding count, just trying to
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1 think whether our stipulations --
2 THE COURT: Is it your position you got
3 the request but didn't pay it because it was
4 unreasonable or is it your position that you
5 didn't get the request for payment or is it your
6 position that either/or?
7 MR. TAYLOR: Really either/or, Your Honor.
8 THE COURT: Okay. So if part of your
9 claim is that you didn't think you should have
10 to pay this, they may certainly maybe entitled
11 to ask why you didn't think you should pay it.
12 MR. TAYLOR: Understood.
13 THE COURT: So that will be allowed.
14 No. 10?
15 MS. O'CONNOR: No. 10 is just generally --
16 MR. TAYLOR: Ten I don't --
17 MS. O'CONNOR: Ten, you're okay?
18 MR. TAYLOR: I don't have a problem with
19 10.
20 THE COURT: Ten is okay.
21 MR. TAYLOR: Yes.
22 THE COURT: Eleven?
23 MS. O'CONNOR: Eleven again goes to the
24 idea that there are additional documents, what
25 did they understand the terms of the process by
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1
which we collect
these fees?
2
THE COURT:
Sounds to me more like it goes
3
to -- Well, this
549, are those the zoning
4
review fees?
5
MS. O'CONNOR:
Correct. The request was
6
for any documents
that show how we used those
7
monies that came
in. Our position, these are
8
commingled funds,
they're not tracked as they go
9
out, they come in
in a particular line item, but
10
they're not going
out as any given line item,
11 1 so.
12 MR. TAYLOR: Your Honor, if I may, the
13 reason I object to that is because part of the
14 reason for asking for the records was to gain
15 knowledge. Whether the Plaintiff had knowledge
16 of the zoning review fees or not, it has nothing
17 to do with whether Gulf Stream should have to
18 produce the documentation under Chapter 119 or
19 not.
20 THE COURT: I think the relation of
21 paragraph 11 to the non -production of documents
22 claim would be covered by the other requests
23 that I've already allowed you to go into, so I
24 will disallow No. 11.
25 No. 12, again, that's the Plaintiff's
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1 knowledge question, as is No. 13, and I'm not
2 sure, Ms. O'Connor, how that would need to be
3 discoverable at this point based upon the
4 stipulation by Mr. Taylor.
5 MS. O'CONNOR: I think 10 is probably an
6 umbrella to cover that.
7 THE COURT: So we'll leave 12 and 13 out
8 as encompassed as relates to 549.
9 Fourteen, litigation history including
10 public record requests, that wouldn't seem to
11 have relevance based in this case anyway based
12 upon the stipulation.
13 MS. O'CONNOR: Agreed.
14 THE COURT: And 15.
15 MS. O'CONNOR: Fifteen --
16 THE COURT: You have a claim for
17 attorney's fees.
18 MS. O'CONNOR: Correct.
19 THE COURT: So I'm not sure what
20 relationship between Plaintiff and its counsel
21 including, but not limited to, retention of
22 counsel would have to do, but it seems to me you
23 would be entitled to a retainer fee agreement
24 that would specify the hourly rate and that sort
25 of thing.
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1 MR. TAYLOR: My only comment to that, Your
2 Honor, would be you would be absolutely right,
3 but our position, our client's position, is that
4 Chapter 119 allows for fees when there's a
5 determination that Chapter 119 has been
6 violated. As that has not happened as of yet,
7 it's our position the issue is moot. Now --
8 THE COURT: Premature?
9 MR. TAYLOR: Yes.
10 THE COURT: So what you're willing to do
11 is to stipulate if the Court finds in your favor
12 that you will then produce those documents prior
13 to an attorney's fees hearing.
14 MR. TAYLOR: Or Ms. O'Connor's willing to
15 stipulate to judgment today, but I don't think
16 that's going to happen.
17 THE COURT: I don't think you're going to
18 that.
19 All right. So as far as being premature,
20 Ms. O'Connor, if the Court makes the
21 determination of entitlement to fees, you'll get
22 it well in advance of the fee hearing?
23 MS. O'CONNOR: That's fine, Your Honor.
24 We were just trying to move it along.
25 THE COURT: All right. So does that cover
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1 all of the outstanding requests?
2 MS. O'CONNOR: I believe so.
3 THE COURT: Which of you would like to
4 prepare the order?
5 MS. O'CONNOR: I'll be happy to prepare
6 the order.
7 THE COURT: You'll be happy to prepare the
8 order, okay.
9 MS. O'CONNOR: Sure. Anything else on
10 this?
11 MR. TAYLOR: No.
12 MS. O'CONNOR: While we're here, and I
13 apologize, I didn't raise it with Mr. Taylor,
14 but we have a case coming to you from Judge
15 Brunson and it involves redactions of a public
16 records request, and pursuant to the Public
17 Records Act when there are work product
18 exemptions that are redacted the Court reviews
19 the unredacted.
20 What it is is invoices from Mr.
21 Sweetapple's law firm and some items were
22 redacted that reflect work product we submit in
23 an ongoing matter, and the Public Records Act
24 contemplates that you review it in -camera, about
25 five pages.
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1 I actually haven't ever had a dispute over
2 a privilege log where the privileged documents
3 were submitted in camera, so my question for you
4 is whether you have - in terms of how we submit
5 to you evidence.
6 So, for example, you know, I may need to
7 submit an affidavit to you from Mr. Sweetapple
8 who says, "Okay. The witness whose name is
9 listed on August 15th entry was a - or the
10 person whose name is listed is a potential
11 witness in this case to support the exemption."
12 THE COURT: Let me interrupt you. I want
13 you to understand, although it sounds like most
14 of these cases are coming to this division,
15 you've been living with the intricacies, both of
16 you, more than I have. I have about
17 1,200 cases, I don't mean that disrespectful.
18 It's hard for me to take in exactly the totality
19 of the circumstances that you're talking about
20 that's going to lead to this potential in -camera
21 review by this court.
22 what I would suggest, if you all meet and
23 if you all have a process that works, send it to
24 me in a agreed order in that case and I'll look
25 at it. If I understand it and agree with it
ESQUIRE 800.211.DEPO (3376)
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
40
1 I'll sign off on it. If I don't understand it I
2 can bring you in for a brief hearing or if I
3 don't agree with it, assuming I understand the
4 proposal, I'll tell you why I don't agree and
5 send an order out to you that way.
6 You know that in a couple months you're
7 going to have a different judge on this.
8 MS. O'CONNOR: Yes.
9 THE COURT: So if I thought I was here for
10 the long-term it would make sense to try and
11 rush this through, or not rush this through, try
12 to get it to me to keep things moving, but I
13 think you're going to have to bring another
14 judge up to speed on all of this in a couple
15 months anyway, so you decide whether you want me
16 to keep addressing these issues until I'm gone
17 or whether you want to wait and educate the next
18 judge, I believe it's Judge Oftedal. I have no
19 preference on that, whatever works for all of
20 you is fine with me.
21 For today, I appreciate you guys getting
22 your materials ahead of time and you'll submit
23 the proposed order as long as Mr. Taylor agrees
24 to the form and content and I'll sign off on
25 that.
ESQUIRE
800.211.DEPO (3376)
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
41
1 My question for you since you're here, I
2 got something on a different case but related to
3 that, and I forget the name of the parties and
4 it's an attorney from Orlando that may be
5 representing one of the public records
6 requestors, and I can't tell you which one, but
7 they sent me a cover letter with a thumb drive
8 taped to it. I haven't put it on my computer
9 and will not, but I had my JA call and say, "set
10 this for hearing," and that call was made
11 June 8th and I haven't heard a thing, so I'm
12 getting ready to send that back unless you can
13 me something about it or something I should
14 know.
15 MS. O'CONNOR: Is it a Gulf Stream case,
16 do you know?
17 THE COURT: Good question. Do you want to
18 wait a minute and I'll grab it?
19 MS. O'CONNOR: Sure.
20 (Short break.)
21 THE COURT: Okay. This is Christopher
22 O'Hare vs. Town of Gulf Stream, it's 13CA17717,
23 the cover letter from Mr. Roeder.
24 MR. TAYLOR: Roeder.
25 THE COURT: Says, "Enclosed please find a
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
42
1 computer flash drive containing digital copies
2 of video depositions referenced in companion
3 motions for protective order in the above
4 referenced case. Copies have also been sent to
5 Joanne O'Connor and Robert Sweetapple.
6 Respectfully, Louis Roeder.
7 I was away last week, but my JA called Mr.
8 Roeder's office on June 8th and said, "set this
9 for hearing," and we've heard nothing, so I'm
10 inclined to send this back unless there's
11 something I missed.
12 MR. TAYLOR: Your Honor, what's the case
13 number on that?
14
THE COURT:
13CA17717.
15
MR. TAYLOR:
Okay. Thank you.
16
THE COURT:
All right. So I'll hold it a
17
couple more days.
If you can give me any
18
clarification or
I get a call back from the
19
office that they're
setting it for hearing, then
20
I'll hold on to it.
Whether I'll put it into my
21
computer and look
at the video depositions I
22
don't know because
I haven't seen the motion, I
23
haven't reviewed
the motion it's attached to. I
24
wasn't going to review
that unless I knew it was
25
set for hearing,
so we'll see what happens next.
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
43
All right. Thank you, folks. Have a good day.
MR. TAYLOR: Thank you.
MS. O'CONNOR: Thank you.
(The hearing concluded at 3:10 p.m.)
ESQUIRE
800.211.DEPO (3376)
EsquireSol utions. com
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
CERTIFICATE
STATE OF FLORIDA )
COUNTY OF PALM BEACH )
June 16, 2015
44
I, JENNIFER D. DiLORENZO, Shorthand
Reporter, certify that I was authorized to and did
stenographically report the foregoing proceedings and
that the transcript is a true and complete record of
my stenographic notes.
Dated this 7th day of July, 2015.
(� r I �e)AZI7P
JENNIFER D. DiLORENZO,
COURT REPORTER
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
10:16,20
25:16
26:21
28:7
1,200
39:17
1.130(b)(6)
27:21
10
34:14,15,
19 36:5
100
21:5
11
35:21,24
119
24:11,13
35:18
37:4,5
12
35:25
36:7
2
2
10:15
2 5: 14
28:7,8
20
6:17
2014
4:16
11:23
14:8
17:11
2 9: 1
2015
3:3
23
19:23
25
14:8
17:11
4
4
14:23
25:16,20
26:8,10
28:14,15
400
19:12
21:4
5
5
28:15
548
29:12
549
28:24
29:15,17,
22 30:2,
June 16, 2015
Index: $1.54 -additional
8,14
31:3,11,
14,23
33:20
35:3 36:8
551
29:13
6
6
28:18
30:25
31:1
7
7
30:3,4,14
31:14,16
8
8
31:15,16
33:13
800
19:12
8th
41:11
42:8
9
9
14:23
17:10
33:21,22
23
A
ability
10:7
absolute
5:10
absolutely
5:16 8:2
9:10 16:8
2 9: 24
37:2
acceptable
33:16
access
20:20
accuracy
18:6
Acquisition
3:1,5,14
4:3 26:2
Act
17:16
20:19
38:17,23
action
22:23
actions
20:16
21:9
23:15
actual
5:3 6:15,
22 13:16
17:18
19:24
25:11
additional
24:21
27:3
33:15
ESQUIRE 800.211.DEPO (3376)
6 0 l.=. 0 H 5 EsquireSolutions.com
13
25th
$
29:1
17:21
36:1,7
18:2,5,7
$1.54
13CA17717
8:19,25
41:22
3
9:7 12:24
42:14
13:3,6,
15
3
16,21
4:16,19
25:15,19
16:1,21
22:13
26:8,10
17:5
25:17,25
28:11,12
19:21
36:14
30 (b) (6)
$39
15th
25:21
19:23
22:12
27:12
$39.23
39:9
300
17:8
16
11:22
3:3
330
1
16th
14:13
16:3
3:10
1
43:4
10:16,20
25:16
26:21
28:7
1,200
39:17
1.130(b)(6)
27:21
10
34:14,15,
19 36:5
100
21:5
11
35:21,24
119
24:11,13
35:18
37:4,5
12
35:25
36:7
2
2
10:15
2 5: 14
28:7,8
20
6:17
2014
4:16
11:23
14:8
17:11
2 9: 1
2015
3:3
23
19:23
25
14:8
17:11
4
4
14:23
25:16,20
26:8,10
28:14,15
400
19:12
21:4
5
5
28:15
548
29:12
549
28:24
29:15,17,
22 30:2,
June 16, 2015
Index: $1.54 -additional
8,14
31:3,11,
14,23
33:20
35:3 36:8
551
29:13
6
6
28:18
30:25
31:1
7
7
30:3,4,14
31:14,16
8
8
31:15,16
33:13
800
19:12
8th
41:11
42:8
9
9
14:23
17:10
33:21,22
23
A
ability
10:7
absolute
5:10
absolutely
5:16 8:2
9:10 16:8
2 9: 24
37:2
acceptable
33:16
access
20:20
accuracy
18:6
Acquisition
3:1,5,14
4:3 26:2
Act
17:16
20:19
38:17,23
action
22:23
actions
20:16
21:9
23:15
actual
5:3 6:15,
22 13:16
17:18
19:24
25:11
additional
24:21
27:3
33:15
ESQUIRE 800.211.DEPO (3376)
6 0 l.=. 0 H 5 EsquireSolutions.com
PROCEEDINGS
CG ACQUISITION
vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: address -care
34:24
40:22
appearing
41:4
belief
address
allegation
3:14
attorney's
30:1,25
25:18
8:21,24
area
36:17
33:3,19
addressing
9:19
7:12
37:13
believes
17:20
7:19 27:2
40:16
areas
August
18:6
5:15,19
39:9
bill
adequate
20:15
19:19
29:2
6:2 7:25
authority10:24
administrat
allegations
argue
3:20
billing
ive
21:24
19:7
avoid
17:6
17:7
27;2 29;9
argument
14:6,17
bit
advance
31:19
9:3 15:8
aware
7:12
37:22
allege
19:1,2,6
10:19
blanket
advised
15:19
assert
5:22 6:9
14:11,13
33:24
28:23
B
blind
17:13
alleging
assertion
32:2
18:4
23:12
5:10
back
break
affects
allowed
assessments
4:7 11:23
41:20
8:10
34:13
24:23
41:12
bring
affidavit
35:23
assume
42:10,18
40:2,13
21:1
amended
12:8
background
broader
27:15
8:17
22:18
27:6,17
7:12
39:7
11:14,18
assuming
banning
12:23
Brunson
agree
12:3,9
6:10
38:15
16:24
13:2,8
40:3
20:11
31:17
based
budgets
attached
5:22
25:15
amending
3:8,9
16:25
32:2
30:14
33:23
14:24
19:2 22:2-
39:25
amount
22:17
23:15,20
C
40:3,4
13:12
26:1
24:3 25:1
agreed
17:6
31:18
36:3,11
call
29:23
19:22
32:6,10,
basically
41:9,10
36:13
20:5 23:7
21 42:23
7:7 24:10
42:18
39:24
32:15,16
attachment
32:11
called
agreeing
anymore
32:20
basis
42:7
9:6 16:18
4:13
attachments
11:4
agreement
15:13
3:20
12:18
camera
39:3
36:23
apologize
attempts
19:13
38:13
29'25
candor
agrees
30:5
30:25
24:24
40:23
appearances
31:10
ahead
3:11
attorney
behalf
care
18:17
13:14
ESQUIRE 800.211.DEPO (3376)
11 EsquireSolutions.com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
Carriage
27:20
case
3:10,25
4:5 5:1,
2,4,22
6:17,18,
22,24
7:2,20
8:15
10:10
2 0: 15
22:9,17
23:16
24:2
25:14
26:3
30:19
36:11
38:14
39:11,24
41:2,15
42:4.12
cases
4:8 15:21
20:24
21:14
22:18
28:20
39:14,17
cents
19:23
CG
3:1,5,14
4:2 26:2
challenge
9:23 10:7
11:1
17:19
20:2,3
challenging
17:25
19:24
2 0: 4
28:16
Chapter
24:11
35:18
37:4,5
charge
13:7,16,
21 23:7
charged
19:20
23:2
charges
32:16
Christopher
41:21
circumstanc
es
4:8 18:18
19:3
39:19
claim
9:8 10:4
16:24
19:14
22:21
34:9
35:22
36:16
claiming
23:1,19
claims
10:2
15:21
18:14,21
20:16
clarificati
on
42:18
clear
5:5 15:15
16:16
22:5
23:18
2 7: 17
cleverly
13:25
client
4:12,25
5:4 7:18
10:11
16:7,10
23:14
24:17
32:18
client's
37:3
code
32:22
collect
3 5: 1
comment
37:1
commingled
35:8
companion
42:2
company
3:1,6
5:12
comparison
4:11
complaining
21:9
Complaint
7:15,17
11:14,15,
16,18
12:23
13:2,8
21:25
27:1
29:10
31:18
June 16, 2015
Index: Carriage -count
32:9,11,
20 33:24
complete
6:9
completely
13:13
19:12
compliance
19:14
computer
41:8
42:1,21
conceding
15:5.6
concern
20:23
concluded
22:14
43:4
confused
22:22
confusion
11:12
constructio
n
32:14
contemplate
s
38:24
content
40:24
continued
33:24
copies
23:2
42:1,4
copy
6:18,23
25:12
copying
8:19 13:6
corporate
4:2 5:2,
4,6,18
6:5 8:9
21:18,22
27:5,14,
20
corporation
27:25
correct
7:16
11:24
12:2
15:14,24
17:19
24:9
25:24
27:22
35:5
36:18
correctly
8:23
corresponds
nce
14:24
cost
10:25
15:3,18
17:18
18:7,12
20:5
24:8,23
costs
32:15,18
counsel
3:11 4:10
13:9 22:4
36:20,22
count
7:16
8:16,17
ESQUIRE 800.211.DEPO (3376)
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PROCEEDINGS
CG ACQUISITION
vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: counts -documents
10:20
19:13
deposit
discovery
11:8,21
20:4,8,10
D
17:15
6:10,11,
13:14
21:11
deposition
15 7:12
14:5,7,
22:16
8:14 9:5
date
4:15,17,
17,18
23:4,17
15:19
18,20,24
10:1
15:15
24:1,3,
14:1,6
18:15
12,20
day
6:2,23
15:11,23
22:11
19:16
25:9,13,
18:24
16:16
20:3,14
22,25
29:1 43:1
depositions
18:21
21:10
26:4,7,
days
5:24
20:12
23:12,17
10,14,17,
42:17
6:10,14,
24:17
24:25
20 27:10,
20 19:9
25:3,8
25:8 27:1
19,23
decide
21:12,13,
31:13
28:22,23
28:6,11,
40:15
17 22:5
dispositive
30:4,8
14,18,2042:2
defect
21
20:25
32:25
29:12,17,
22:25
designated
33:4,22,
19,25
5:8,18
dispute
25
30:14,17,
Defendant
12:9 17:1
21 31:21
4:1 7:22
6:4 28:4
18:5,8,11
counts
32.8
8:17 13:4
determinati
39:1
10:18
24.22
33:3,17
30:1
on
disrespect£
26:25
34:2,8,
Defendant's
37:5,21
ul
28:10
13,20,22
3:9
determine
39:17
couple
35:2,20
36:7,14,
defense
7:13
division
40:6,14
16,19
10:7,8,9
determining
39:14
42:17
37:8,10,
deficient
18:18
document
court
11,17,20,
19:4
difference
25:20
3:5,15,18
25 38:3,
delay
33:11
30:12
5:6,13,17
7'18
23:20
digital
31:9
6:1,4,7,
39:12,21
40:9
delayed
42:1
documentati
25 7:13,
21,25
41:17,21,
7:10
direct
on
8:4,13
25 42:14,
demonstrate
25:11
8:19
16
10:13
9:1,8,21
s
directors
13:5,11
10:15,22
cover
20:18
27:8
23:24,25
11:9,11,
36:6
denial
disagrees
30:20
24 12:3,
37:25
20:20
7:19
32:22
8,20
41:7,23
33:1
13:23
deny
disallow
35:18
14:18,21
covered
4:10
35:24
15:1,15
35:22
documents
depending
diecoverabl
3:8 7:4,6
16:4,15,
creates
28:9
e
23 17:10,
16:12
9:14,17,
24 18:4,
depose
10:6
18 11:20,
10,17
4:2 5:3
30:22
23 17:18
36:3
24:5,24
ESQUIR111 E EsquireSol �on,
s.com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
27:3
27:8
18:7,12
29:7,22
Enclosed
20:5 23:7
30:2,6,9
41:25
evidence
31:3,6,
10,11,20
encompassed
21:6 39:5
33:5,15,
36:6
exemption
19 34:24
39:11
enjoining
35:6,21
24:10
exemptions
37:12
38:18
39:2
enter
23:5
Exhibit
dollar
14:25
23:8
entities
25:23
8:8
drag
26:11,13,
22:7,9
entitled
14,17
5:14 7:22
draw
8:13 21:8
exhibits
4:11
24:18
31:17
drive
26;23
33:14,18
41:7 42:1
29:21
exist
31:12
24:25
duces
34:10
31:20
25:11
26;2
36:23
existed
entitlement
9:18
duplication
17:18
6:1 37:21
existence
entitles
33:15
29:19
exists
E
entity
23:25
8:8
earlier
expect
22:11
entry
14:6
educate
39.9
expedition
40:17
essentially
4:23
effect
3:24 8:18
expeditions
10:2022:6
8:7 11:2
19:24
33:13,16
32:21
expenses
either/or
17:17
estimate
34:6,7
10:24
extent
Eleven
11:22
20:14
34:22,23
12:10,11,
extremely
eliminate
12,15
5:23,25
14:1 28:7
14:10
15:19,25
employees
16:1,22
ESQUIRE
F
June 16, 2015
Index: dollar -frankly
12 11:15,
16
Filing
£act 25:14
11:21 find
12:15 41:25
13:17,20
14:15 finds
16:12 3 7: 11
18:5
22:24
facts
4:21 6:13
22:8,13
factual
12:9 17:1
failing
6:9
fair
21:20
fashion
30:10
favor
37:11
fee
8:19
36:23
37:22
fees
11:6
19:19
35:1,4,16
36:17
37:4,13,
21
Fifteen
36:15
figure
32:18
filed
3:25 4:3,
fine
37:23
40:20
firm
38:21
fishing
4:22 22:6
flash
42:1
flatly
23:13
Florida
24:11
folks
43:1
forget
4 1: 3
form
20:20
40:24
found
3 1: 10
foundation
28:12
Fourteen
36:9
frame
10:3
frankly
4:24 5:21
800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
front
grab
hearing
14:12
41:18
7:23 21:7
22:19
grounds
27:10
31:22
37:13,22
24:4 25:2
fund
40:2
grouped
41:10
32:14
22:23
42:9,19,
funds
25 43:4
guess
29:3 35:8
9:12 13:4
helpful
future
19:17
25:5
20:19
Gulf
henceforwar
9:19 20:1
d
G
22:4
23:6
32:12,15
Hills
35:17
Gadd
27:21
41:15,22
6:18
history
Gulfstream
gain3:2,6,17
36:9
8:22 23:6
hold
gather
42:16,20
30:5
guys
40:21
honest
31:2,10
13:8
gathering
17:17
H
Honor
3:13,23
33:7
happen
4:6 5:20
gave
37:16
6:3,9,24
17:20
7:14,24
18:12
happened
8:2,16
20:5
4:16 37:6
9:10
generally
happy
12:22
34:15
38:5,7
14:4,5
15:24
give
harass
16:6
31:13
4:25
17:4,22
42:17
22:10
19:6,17
giving
hard
20:13
11:5
32:24
22:1
39:18
23:11
good
24:9,19
28:2
harm
25:5
41:17
20:20
27:22
43:1
heard
29:18,24
gotcha
41:11
30:16
30:10
42:9
32:11
33:10
June 16, 2015
Index: front..intricacies
34:7 39:20
35:12
37:2,23
42:12
hour -and -a -
half
6:12
hourly
36:24
hours
4:17,19
17:7
22:13
hundreds
8:5
I
i.e.
21:4
idea
30:9
34:24
identities
8:9
II
14:17,19
23:13,17
25:8 27:1
28:10,23
30:5,8
32:25
33:4
III
20:14
21:10
27:1
immediately
11:17
in -camera
38:24
inappropria
to
24:23
inclined
42:10
including
36:9,21
indication
26:7
individual
8:9
individuals
27:7
information
10:2
27:9,17
33:8,9,13
injunction
23:5,15
injunctive
20:14
22:21
23:3,9
24:2,10,
15.25
inquire
5:14
29:21
30:24
inquiry
25:6
instance
31:2
intended
29:6
interrupt
39:12
intricacies
39:15
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: invoices -motion
invoices
18
lead
39:2
materials
38:20
judgment
39:20
long
40:22
involves
21:6
leave
40:23
matter
38:15
27:11
36:7
3:1 19:18
long-term
irrelevant
37:15
legally
40:10
27:6
6:21
June
19:20
30:19
lot
38:23
19:12
3:3 11:23
letter
12:13
issue
14:8 16:3
13:6
22:5
meant
9:11,12,
17:11,21
19:25
24:13
22:7,9,10
13 12:4,
18:5,7
41:7,23
26:12
41:11
Louis
32:16,17
14,22
42:8
light
42:6
13:1,17
22:24
meet
15:7,16
39:22
16:12,18
g
likelihood
M
18:15
20:19
met
21:14
20:8,9
knew
limit
made
24:12
42:24
22:16
minute
29:9 37:7
23:9 30:7
1
18:
8:222,23,23
28:2
Kn18i g
41:18
issues
:107:2,3,13,
limited
21:24
6:12
28:25
minutes
15 9:21
knowledge
36:21
30:5
4:20
15:12
21:23
41:10
22:13
24:21
35:15
limiting
28:1
36:1
23:3
main
missed
4 0:16
24:14
5:15
42:11
item
limits
make
mistaken
L
5:23
5:10 19:1
5:12
27:17,18
40:10
35:9,10
lack
20:11
money
24:16
makes
32:19
items
19:4
26:5 32:2
24:24
list
32:12
33:1
38:21
25:16
37:20
monies
large
26:12
making
35:7
20:22
listed
14:2
month
J
lasted
5:15
manner
21:4
4:17
39:9,10
9:16
JA
months
41:9 42:7
late
litigation
16:711
,
16:2
12:12
36:9
marathons
18:23
Joanne
law
22:6
40:6,15
3:16 42:5
living
3:10 5:5,
39:15
Martin
moot
judge
22 6:17
11:10
25:14
locked
4:18
37:7
38:14
30:19
27:23
Marty
motion
40:7,14,
38:21
log
27:14
3:7,8,19,
ESQUIRE 800.211.DEPO (33 76)
EsquireSol utions. com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: motions.. pertains
22,25
number
13,15,18
40:5,23
24:2
4:3,6
10:4
37:20,23
42:3
31:4,5
20:25
15:20,21
38:2,5,9,
originally
34:8
21:16
21:13
12 40:8
35:13
11:14
42:22,23
26:3
41:15,19
Parties
42:13
42:5 43:3
Orlando
motions
41:3
41:4
21:14
numbered
O'connor's
42:3
26:1
24:17
outlining
Party
30:18,19
37:14
21.2
motivation
6:20
0
O'hare
outstanding
Past
18:22
41:22
38:1
motive
22:2
6:15
O'boyle
object
overestimat
pattern
move
4:18
35:13
a
20:18
20:24
21.21
office
24.8
32:12
27:14
37:24
42:8,19
28:1
Pay
moving
officers
F
34:3,10,
40:12
O'connor
27:8
11
3:16 9:1
10:18
offset
p.m.
Payment
43:4
N
11:10,12
32:17
17:15
12:2,7
Oftedal
Pages
34:5
nature
14:4,20,
40:18
11:22
Pending
32.2
23 15:14
14:13
10:2
16:9,20
ongoing
25:16
15:21
necessarily
18:16
38:23
38:25
18:22
22:3
20:11,13
open
paid
Nick
22:3
7:11 8:1
8:20,25
Perfectly
3:13
24:20
18:21
13:12
22.2
25:4,12,
16:2
period
non-
19,24
opening
8:7
production
26:6,9,
31:8
paired
23:18
12,16,18,
opposing
22:22
Permit
35:21
22,24
4:10
paper
32:15
noncomplian
27:22
19:22
permitted
opposition
ce
28:5,8,
17:15
14:25
paragraph
16:25
12,15,19,
18:14
22 29:15
order
14:23
person
17:10
39:10
20:18
30:4
3:7 4:1,
31:16,24
4,7,9,10,
35:21
pertained
notice
32:4
12,16
paragraphs
4:21
6.22
13:21
33:10,12,
5:22 6:10
26:1
pertaining
15:3
22 34:15,
14:6,17
parcel
6:13
17,23
21:15
25:14,21
35:5
38:4,6,8
31:5
pertains
P
26:2
36:2,5,
39:24
part
6:20 11:7
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: picked.. received
32:25
precludes
7:4 9:14,
16:19
10:11
picked
P
16:16
15 13:5
17:15
questions
21:18
preference
18:11
20:1719
,,
19:10
40:19
23:14,24
20,21
Plaintiff
31:12
21:3 24:6
—
3:12 9:20
premature
33:5,19
28:23
R
14:11
37:8,19
29:5 30:6
producing
17:13,14
prematurely
31:6
32'6
raise
20:21
11:17
36:10
32:17
21:19,23
product
38:15,16,
38:13
27;2
prepare
38:17,22
23 41:5
35:15
38:4,5,7
raised
production
pull
36:20
p rep ared
:
14:2
18:16
Plaintiff's
17:13
raising
3:6,8
prolong
Pr
Purpose
10:6,10
presupposes
4:248
28:16,20
29:2
35:25
16:10,11
proof
29:5,20,
rate
25
36:24
prior
7:19,21,
pleadings
4:6 21:6
22 32:11
purposes
read
9'2
37:123:19
proposal
15:23
14:3
pled
privilege
40:4
pursuant
reading
11:19
39:214:22
27:20
23:16
proposed
privileged
40:23
29:4 31:7
ready
point
39:2
38:16
41:12
19:18
protective
28:9 36:3
Problem
3:7 4:1,
Pursuing
reason
34:18
4,7,9,10,
16:24
4:3 5:17,
position
34:2,4,6
Proceeding
12 5:22
put
20 18:20
35:7
32:7
6:9 21:15
24:16
33:23
27:12
35:13,14
37:3,742'3
Proceedings
provide
2g:g 41:8
reasonable
possessed
3:1
6:18
42:20
7:10 8:10
14:13
process
11:20
12:5,18
possession
34:25
provided
Q
18:19
30:10
39:23
10:13
reasonablen
possibly
Produce
14:9,10
quashed
ess
32:3
8:18,24
18:6
6;23
15:17
9:23
potential
13:11
Providing
question
receipts
39:10,20
17:2,14
20:17
12:14
31:25
practice
24:7
public
13:20
32:1
20:25
27:5,24
3:24 4:5,
16:5 36:1
received
35:18
21 6:14
39:3
3:7,9
practices
37:1241:1,17
8:6 10:4
10:1,14
22:3
produced
14`9
questioning
11:2
ESQUIRE 800.211.DEPO (3376)
1 EsquireSolutions. com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
15:3,6,8
relate
representat
16:7,10
24:22,23
ive
18:2,12
26:10
4:2 5:2,
19:11
31:22
4,7,18
21:3,4
33:18
6:5
29:3
related
21:19,22
record
25:8 27:7
27:5,12,
14:3
29:22
14,20
36:10
31:3,16
representin
records
41:2
g
3:24 4:5,
relates
41:5
21 6:14
31:14
request
7:18 8:6,
36:8
3:25 4:22
25 10:5
relating
6:11,14
14:9,14
7:5 12:1
10.2
16:19
14:2,9,
17:14,16
relation
10,16
20:17,19,
35:20
16:18
21 21:3
relationshi
17:12
23:13
19:16
p
24:6
36:20
24:1
27:16
25:20
28:24
relevance
28:24
29:5 30:7
15:22
29:5 30:7
32:6
36:11
31:7,9,23
35:14
relevant
32:6
38:16,17,
28:21
33:4,8
23 41:5
34:3,5
relief
35:5
redacted
20:15
38:16
38:18,22
22:21
redactions
23:3,9
requestor
38:15
24:2,10,
6:16,21
15 25:1
requestors
referenced
42:2,4
remain
41:6
8:1
requests
refers
30:18
remedy
8:6 10:5
23:4
19:11
reflect
21:3
38:22
replete
23:21
refusal
27:2
28:25
11:20
replied
35:22
7:17
36:10
refute
38:1
21:5
represent
21:11
resolution
ESQUIRE
29:4
respect
20:17
Respectful
y
42:6
respond
8:22
10:22
14:15
responded
10:23,25
11:19,21
23:25
response
3:9 7:8,
10 8:5,1
9:4,9,16
19,25
10:12
11:4,15,
25 12:4
13:19,24
14:8
15:9,17
16:20
17:11,12
21 18:2,
19 19:3,
8,14,25
27:10,16
28:17
33:4
June 16, 2015
Index: record -scope
result
4:15
retainer
1 36:23
retention
36:21
revenue
32:17
review
35:4,16
38:24
39:21
42:24
reviewed
42:23
reviews
1 38:18
revise
33:12
responses
5:14
responsive
14:14
17:14
30:1,6,12
31:11
33:15
rest
4:22
Ring
5:11
21:21
27:13,24
28:4
Robert
42:5
Roeder
41:23,24
42:6
Roeder's
42:8
rush
40:11
s
scenario
5:1
scope
5:24
800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM Index: seek -Taylor
seek
similar
27:25
stuff
25:1
4:8 8:8
12:13
T
start
33:13
simple
3:11
15:20
seeking
3:24 4:4,
26:21
24:13
table
5:3 19:7
5 19:18
subject
15:12
stated
23:10,14
simply
13:25
30:8 32:7
talking
seeks
4:22
submit
10:15,16
states
4:1
32:18
11:17
39:19
7.17
send
single
12:7
taped
statin
12:11,13,
21:15
41:8
15 15:18,
13:68
39:427
situations
40:22
Taylor
25 39:23
statute
40:5
4:13
12:6,19submits
3:13,19,
41:12
sort
18:14
27:15
23 5:8,
42:10
18:24
19:15
16,20
submitted
6:3,6,8
30:10
sense
36:24
Statutes
39:3
7:14,24
40:10
24:11
8:2,12,15
sou ht
g
subpoena
9:7,10
separately
stipulate
6:22 26:2
3:21
29:1
9:3 14:14
10:9,17,
sounds
15:2
suggest
19 11:7,
September
35:2
37:11,15
39:22
13 12:22
4:8,16
39:13
suggested
15:2,24
22:12
stipulating
16:5,14,
set
source
12:24,25
8:4 9:2
17 17:4,
41:9
29.3
stipulation
suggests
22 18:1,8
42:8,25
specific
9:6 14:7
33:6
19:6,17
6:21
15:4
summary
20:7,9
setting
18:15
20:10
21:6
21:12
42:19
32:14
24:21
27:10
22:1
short
25:2,4
23:11,23
8:6 10:3
specificall
26.25
support
24:9,19
41:20
y
28:10
17.7
26:19
6:17
36:4,12
33:3,14,
29:18,23,
show
19:1,15
18 39:11
24 30:15,
32:12,21
21:18
stipulation
supporting
16,18
35:6
speed
s
3:20
32:1,5,10
showing
40:14
13:25
33:6,11
34:1
supposed
17:6
34:7,12,
sp32a13
28:3
19:21
Stream
16,18,21
33:1
9:19 20:1
Sweetapple
35:12
33:1
22:4
39:7 42:5
36:4
sign
40:1,24
a pent
p
32:12,15
Sweetapplet
37:1,9,14
32:23
35:17
38:11,13
significant
spokesman
41:15,22
s
38:21
40:23
17:16
41:24
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM Index: Taylors -William
42:12,15
43:2
Taylor's
25:13
26:7
tecum
25:11
26:2
tee
21:13,16
telling
9:6 15:16
16:17
18:25
21:20
22:25
24:14
tells
25:15
Ten
34:16,17,
20
terms
8:10 10:6
34:25
39:4
thing
15:25
18:24
23:12
25:10
36:25
41:11
things
24:15
32:2,23
4 0: 12
thinking
21:19
31:1
thought
14:1 40:9
thumb
41:7
time
8:7,22
10:3,4
12:21
13:18
17:16
18:13
21:3 33:7
40:22
timeliness
9:11,12,
25 10:12
13:1
19:4,5,25
20:3
28:16
timely
7:9 9:16,
20 10:22
12:5
13:19
14:9,16
16:7,11,
13 17:2
18:20
19:8
timing
7:9 8:11
15:10
today
4:12
19:22
22:20
24:2,3,14
26:4
37:15
40:21
told
10:23
21:12
30:23
topics
25:6,15,
17 26:8
28:13
totality
19:3
3 9: 18
Town
3:2,6,17
7:6 8:21
14:15
16:6,25
17:1,12
18:4,17
21:1,2
22:4
23:1,6
29:3
41:22
Town's
11:15
14:8
17:11
20:16
trace
29:3
tracked
35:8
transcripts
22:18
transfer
33:2
trial
7:23
true
9:13
truthful
23:22
24:5
turned
22:6
30:13
G
umbrella
36:6
understand
7:2 9:22
15:1
34:25
39:13,25
40:1,3
understands
ble
22:2
understandi
ng
7:5
Understood
16:4
34:12
unlawful
11:20
33:25
unreasonabl
e
15:9 20:6
23:20
34:4
unreasonabl
y
7:11
unredacted
38:19
untimely
9:4,9
11:3
V
valid
10:10
vice-
president
5:11
27:13
video
42:2,21
violated
37:6
violating
24:11
volume
23:20
ri
wait
12:19
28:2
40:17
41:18
waited
12:17
waiving
9:3 15:8
19:2
walk
25:6
walked
31:19
week
18:23
19:11
21:5 42:7
weeks
11:25
12:4,18,
19
whatsoever
22:8
William
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM Index: withholding..zoning
--,-----•_•-••_•-_•
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
May 3, 2016
Martin E. O'Boyle [mail to: records@commerce-group.com]
Re: GS # 2165 (1219)
Please provide a copy of the transcript (including the exhibits) resulting from the hearing ofJuune
16, 2015 and relating to the litgation styled: CGAcquistion Company, Inc. vs Town of Gulf Stream
(Case No. 502014C4007123IB). To the extent that the documents requested are not in the
possession of any of the requestees, please amend this request on a daily basis until such time as
the requested documents are available.
Dear Martin E. O'Boyle [mail to: records(a)commerce-aroW.coml,
The Town of Gulf Stream has received your original record requests dated April 25, 2016. Your
original public records request can be found at the following link: http://www2.eulf-
stream.ore/weblink/O/doc/89972/Pagel.asox. Please refer to the referenced number above with
any future correspondence. Please allow this response to be responsive for all parties involved.
You will find the responsive documents attached to this email as well as at the same above link.
We consider this closed.
Respectfully,
Town Clerk, Custodian of the Records