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HomeMy Public PortalAboutPRR 16-2186From: Chris O'Hare[mailto:chrisoharegulfstream@gmaii.com] Sent: Thursday, May 19, 2016 11:01 AM To: Bill Thrasher <bthrasher@gulf-stream.org>; Rita Taylor <RTaylor@gulf-stream.org> Subject: public record request - wantman - GS comm Dear Custodian of Records, I request to inspect certain public records for the purpose of informing myself of the historic and current workings of the Town of Gulf Stream and its associated entities, vendors, consultants, advisers, contractors and agents. The records I wish to inspect may be material to current, anticipated or presently unforeseen legal action. The production of any and all responsive records is therefore urgent and must be acted upon in compliance with Florida Statutes and established case law as soon as possible. Before making this public record request, I first searched online and in the public records portion of your agency's website hoping I could locate the public records I seek without having to trouble you for it. Unfortunately I cannot find the records I request to inspect. Therefore I am writing you now and requesting you make every effort as required by law to produce these public records without delay. If you are not the custodian of the public records described herein please determine who that person is and notify me immediately in order that I may make this request to the appropriate person without delay. In all cases please reference Florida Statutes and appropriate case law when responding to this record request. Please read this entire request carefully and respond accordingly. This email is a singular request for public records. Please respond to this public record request in a singular manner and do not combine this public record request with any other public record requests when responding to this request. Do NOT produce any records other than records responsive to this request. Please identify by name the person or persons responding to this request. If the records I seek are in the custody of an entity under contract with your agency please contact that entity, inform them of their obligations under Florida Statute 119 and produce any responsive records in their custody. As Background to this request I call to your attention to the fact that The Wantman Group is a contractor to your agency and subject to Florida Statutes regarding public record inspection. This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the Town of Gulf Stream (including all employees, appointees, officials, assignees, and consultants including Town Manager, Town Clerk, Town Police Chief, Town Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town Engineer) the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. I make this request pursuant to Article 1, Section 24 of the Florida Constitution and Chapter 119 of the Florida Statutes. If you contend that any of the records I am seeking, or any portion thereof, are exempt from inspection or disclosure please cite the specific exemption as required by §119.07(1)(e) of the Florida Statutes and state in writing and with particularity the basis for your conclusions as required by §119.07(1)(f) of the Florida Statutes. Produce 31 consider exempt. I specifically ask you to do this in order that I may inspect fully redacted records for the purpose of challenging a particular redaction or establishing a reference for a future request of a record that is only temporarily exempt, as in the case of a public record that was prepared by an agency attorney exclusively for litigation and is only exempt from disclosure until the conclusion of the litigation. Please take note of §119.07(1)(c) Florida Statues and your affirmative obligation to (1) promptly acknowledge receipt of this public records request and (2) make a good faith effort which "includes making reasonable efforts to determine from other officers or employees within the agency whether such a record exists and, if so, the location at which the record can be accessed." I am, therefore, requesting that you notify every individual and entity in possession of records that may be responsive to this public records request, including individuals and entities under contract with your agency, to preserve and produce all responsive records on an immediate basis. If the public records being sought are maintained by your agency, or contactors for your agency, in an electronic format please produce the records in the original electronic format in which they were created or received. See §119.01(2)(f), Florida Statutes. Please provide only those records for inspection that do not require extensive use of information technologies or extensive staff time or both in excess of 15 minutes. Take note of §119.07(4)(a)3.(d) Florida Statues and if you anticipate that any records exist, the production for inspection of which will require extensive use of information technologies or extensive staff time or both in excess of 15 minutes, then please provide those records that can be produced within the first 15 minutes and advise me of the cost you anticipate to be incurred by your agency for the remaining records prior to incurring this cost. Please do not incur any costs on my behalf without first obtaining my written authorization to proceed. If you produce only a portion of all existing responsive records, please tell me that your response includes only a portion of all existing records responsive to this request. If you anticipate the need to incur any costs that I would be statutorily required to pay in order to inspect these public records which would exceed $1.00 please notify me in advance of your incurring that cost with a written estimate of the total cost. Please be sure to itemize any estimates so as to indicate the total number of pages and/or records, as well as to distinguish the cost of labor and materials. Again, please do not incur any costs on my behalf without first obtaining my written authorization to proceed. The phrase Town of Gulf Stream when used herein refers to the Town in its entirety including all employees, appointees, officials, assignees, counsel and consultants including Town Manager, Town Clerk, Town Police Chief, Town Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town Engineer, the law firm (Jones Foster Johnston & Stubbs P.A.) that claims to be the Town Attorney including all attorney, partner and employee members of that firm; the Town Counsel of Sweetapple, Broeker & Varkus including all attorney, partner and employee members of that firm, the Town Counsel of Richman Greer, P.A. including all attorney, partner and employee members of that firm and any other entity associated with the Town and subject to public records law. The term public records as used herein has the same meaning and scope as the definition of Public records adopted by the Florida Legislature as Statutes Chapter 119. A record that does not exist because of its disposition requires the creation of a disposition record. In all instances where you determine a record does not exist please determine if the record once existed and in its stead provide the disposition record for my inspection. I hereby reserve all rights granted to me under the Florida Constitution and Florida Statutes. All responses to this public records request should be made in writing to the following email address: chrisoharegulfstream@gmail.com TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail May 23, 2016 Chris O'Hare [mail to: chrisoharegulfstream@gmail.com] Re: GS #2186 (wantman - GS comm) As Background to this request I call to your attention to the fact that The Wantman Group is a contractor to your agency and subject to Florida Statutes regardingpublic record inspection. This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the Town of Gulf Stream (including all employees, appointees, officials, assignees, and consultants including Town Manager, Town Clerk, Town Police Chief, Town Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town Engineer) the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. Dear Chris O'Hare [mail to: chrisohareeulfstreamAgmail.coml, The Town of Gulf Stream has received your public records requests dated May 19, 2016. The original public record request can be found at the following links httv://www2.gulf- stream.org/weblink/O/doc/90745/Pagel.asi)x 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 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via a -m August 18, 2016 Chris O'Hare [mail to: chrisohareeulfstream(agrnail.com] Re: GS #2185 (wantman - jf), GS #2186 (wantman — GS comm), GS #2188 (wantman — BS), GS #2249 (RICO comm with attorneys at Jones Foster), GS #2251 (RICO comm between and/or among attorneys at Richman Greer), GS #2252 (RICO comm with attorneys at Jones Foster by Town staff), GS #2255 (records between and/or among attorneys at Jones Foster Johnston & Stubbs P.A: RICO), GS #2257 (earliest 3 comm. between Sweetapple and Richman about RICO), GS #2259 (earliest 3 comm. between Jones Foster and Richman about RICO) This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the law firm of Jones Foster Johnston & Stubbs P.A. (including all attorney, partner and employee members of that firm), the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the Town of Gulf Stream (including all employees, appointees, ojficials, assignees, and consultants including Town Manager, Town Clerk, Town Police Chief, Town Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town Engineer) the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the law firm of Sweetapple, Broeker & IVarkus (including all attorney, partner and employee members of that firm), the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. I request to inspect all records of communication between any Town Commissioner of the Town of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please do not include any records of communication that are already available online as part of the Town's published minutes ofpublic meetings. I request to inspect all records of communication created by any attorney at the firm of Richman Greer, P.A. that is wholly or partly concerning the Town of Gulf Stream's RICO complaint. I remind you that any communication between and/or among attorneys at this firm that was made on behalf of the Town is a record of the public's business and therefore it is a public record and subject to disclosure as per §119.07 of the Florida Statutes and Article 1, Section 24 of the Florida Constitution. I request to inspect all records of communication between any member of the Town staff (including Town Manager and Town Clerk) of the Town of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please do not include any records of communication that are already available online as part of the Town's published minutes of public meetings. I request to inspect any internal* record created by any attorney at the firm of Jones Foster Johnston & Stubbs P.A. the subject matter of which is wholly orpartly concerning the Town of Gulf Stream's RICO complaint**. These records I request to inspect include but are not limited to any record that was prepared by any attorney at the firm of Jones Foster Johnston & Stubbs P.A. or prepared at the express direction of any so described attorney, that: • reflects a mental impression, conclusion, litigation strategy, or • legal theory of the attorney or the agency, or that was prepared exclusively for civil or criminal litigation or for adversarial administrative proceedings, or • that was prepared in anticipation of imminent civil or criminal litigation or imminent adversarial administrative proceedings, These records may include but not be limited to electronic records such as emails, voice mail, text messages, social media, and digital files located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft electronic devices capable of containing electronic records. PLEASE NOTE: • FIRST PRODUCE FOR MYINSPECTIONANYRECORDS OF INTERNAL COMMUNICATIONBETWEENAND AMONG PERSONS 17V THE FIRMINCL UDING RECORDS THAT MAYNOT HAVE BEEN COPIED OR SHARED WITHANYPERSONS OUTSIDE THE FIRM. • PRODUCE RECORDS THAT DO NOT REQUIRE EXTENSIVE USE OF INFORMATION TECHNOLOGIES OR EXTENSIVE STAFF TIME OR BOTH IN EXCESS OF 15 MINUTESAND ALONG WITH THOSE RECORDS PROVIDE THE COST FOR PRODUCING THE BALANCE OF THE RESPONSIVE RECORDS *The word "internal" as used above means a record of communication between and among persons in the firm; a record created by a person in the firm for the primary purpose of recording and making available information or knowledge to persons in the firm; a record archived in the firm which documents, memorializes or otherwise records an event, fact, impression, opinion, strategy, plan, or conclusion. **The phrase "RICO complaint" as used above means the entire scope of the Town of Gulf Stream's RICO complaint process from initial inspiration through consideration, planning, initiation, application, appeal and resolution. I request to inspect the three earliest created records of communication between any attorney at the firm of Sweetapple, Broeker & Varkus and any attorney at the firm of Richman Greer, P.A. that is wholly or partly concerning RICO*. Please do not include any records of communication that are already available online as part of the Town's published minutes of public meetings. The records I request to inspect may include but not be limited to electronic records such as emails, voice mail, text messages, social media, and digital files located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft electronic devices capable of containing electronic records. I request to inspect the three earliest created records of communication between any attorney at the firm of Jones Foster Johnston & Stubbs, P.A. and any attorney at the firm of Richman Greer, P.A. that is wholly or partly concerning RICO*. Please do not include any records of communication that are already available online as part of the Town's published minutes of public meetings. The records I request to inspect may include but not be limited to electronic records such as emails, voice mail, text messages, social media, and digital files located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft electronic devices capable of containing electronic records. Dear Chris O'Hare [mail to: chrisoharegulfstream(@, mail.coml, The Town of Gulf Stream has received your public records requests dated May 18, 2016, May 19, 2016, May 20, 2016, June 24, 2016, June 25, 2016, June 26, 2016, June 28, 2016, June 30, 2016, July 1, 2016 and July 2, 2016. The original public record requests can be found at the following links: http://www2.gulf-stream.org/weblink/0/doc/90746/Pa eg l.asnx http://www2.gulf-stream.org/weblink/O/doc/90745/Pagel.aspx httT)://www2.gulf-stream.org/weblink/O/doc/90814/Pagel.asi)x htW://www2.gulf-stream.org/weblink/O/doc/94484/Pagel.aspx httv://www2.gulf-stream.org/weblink/O/doc/94678/Pagel.asvx htW://www2.gulf-stream.org/weblink/O/doc/94684/Pagel.asl2x htti)://www2.galf-stream.org/weblink/O/doc/94727/Pagel.asl)x httv://www2.gulf-stream.org/weblink/O/doc/95015/Pagel.asi3x http://www2.gulf-stream.org/weblink/O/doc/95239/Pagel.aspx Your statement that records regarding the RICO lawsuit are no longer subject to the work product exemption under the Public Records Act is incorrect. Indeed, the RICO suit is not concluded for purposes of the work product exemption under the Public Records Act because of your filing of post judgment motions. See Wagner v. Orange Cty, 960 So. 2d 785 (Fla. 5th DCA 2007). As a result, to respond to each of the foregoing requests will require extensive clerical or supervisory assistance. Specifically, the records that you seek will need to be reviewed by the Town's attorneys to determine if they were created by counsel exclusively for litigation or in anticipation of imminent litigation and reflect the mental impressions, conclusions, litigation strategies, or legal theories of the Town's attorneys or otherwise exempt under Florida Statutes § 119.0171(1)(d)I until the conclusion of the litigation. The Town is willing to hold this request in abeyance until such time as the RICO lawsuit is concluded for purposes of the work product exemption under the Public Records Act. Please advise whether you would like the Town to do so or whether you would like estimates of the cost that will be incurred to review and redact all of the records that you seek for work product privileged material. Sincerely, Town Clerk Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail September 22, 2016 Chris O'Hare [mail to: chrisohareeulfstream(ia gmail.com Re: GS #2185 (wantman - jt), GS #2186 (wantman — GS comm), GS #2188 (wantman — BS), GS #2249 (RICO comm with attorneys at Jones Foster), GS #2251 (RICO comm between and/or among attorneys at Richman Greer), GS #2252 (RICO comm with attorneys at Jones Foster by Town staff), GS #2255 (records between and/or among attorneys at Jones Foster Johnston & Stubbs P.A.- RICO), GS #2257 (earliest 3 comm. between Sweetapple and Richman about RICO), GS #2259 (earliest 3 comm. between Jones Foster and Richman about RICO) This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the law firm of Jones Foster Johnston & Stubbs P.A. (including all attorney, partner and employee members of that firm), the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the Town of Gulf Stream (including all employees, appointees, officials, assignees, and consultants including Town Manager, Town Clerk, Town Police Chief, Town Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town Engineer) the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them far their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the law firm of Sweetapple, Broeker & varkuus (including all attorney, partner and employee members of that firm), the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. I request to inspect all records of communication between any Town Commissioner of the Town of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please do not include any records of communication that are already available online as part of the Town's published minutes ofpublic meetings. I request to inspect all records of communication created by any attorney at the firm of Richman Greer, P.A. that is wholly or partly concerning the Town of Gulf Stream's RICO complaint. I remind you that any communication: between and/or among attorneys at this firm that was made on behalf of the Town is a record of the public's business and therefore it is a public record and subject to disclosure as per §119.07 of the Florida Statutes and Article 1, Section 24 of the Florida Constitution. 1 request to inspect all records of communication between any member of the Town staff (including Town Manager and Town Clerk) of the Town of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please do not include any records of communication that are already available online as part of the Town's published minutes of public meetings. I request to inspect any internal* record created by any attorney at the firm of Jones Foster Johnston & Stubbs P.A. the subject matter of which is wholly or partly concerning the Town of Gulf Stream's RICO complaint**. These records I request to inspect include but are not limited to any record that was prepared by any attorney at the firm of Jones Foster Johnston & Stubbs P.A. or prepared at the express direction of any so described attorney, that: • reflects a mental impression, conclusion, litigation strategy, or • legal theory of the attorney or the agency, or that was prepared exclusively for civil or criminal litigation or far adversarial administrative proceedings, or • that was prepared in anticipation of imminent civil or criminal litigation or imminent adversarial administrative proceedings, These records may include but not be limited to electronic records such as emails, voice mail, text messages, social media, and digital files located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft electronic devices capable of containing electronic records. PLEASE NOTE: • FIRST PRODUCE FOR MYINSPECTIONANY RECORDS OF INTERNAL COMMUNICATION BETWEENAND AMONG PERSONS IN THE FIRMINCLUDING RECORDS THAT MAY NOT HAVE BEEN COPIED OR SHARED WITHANYPERSONS OUTSIDE THE FIRM. • PRODUCE RECORDS THAT DO NOT REQUIRE EXTENSIVE USE OF INFORMATION TECHNOLOGIES OR EXTENSIVE STAFF TIME OR BOTHINEXCESS OF 15 MINUTES AND ALONG WITH THOSE RECORDS PROVIDE THE COST FOR PRODUCING THE BALANCE OF THE RESPONSIVE RECORDS. *The word "internal" as used above means a record of communication between and among persons in die firm; a record created by a person in the firm for the primary purpose of recording and making available information or knowledge to persons in the firm; a record archived in the firm which documents, memorializes or otherwise records an event, fact, impression, opinion, strategy, plan, or conclusion. **The phrase "RICO complaint" as used above means the entire scope of the Town of Gulf Stream's RICO complaint process from initial inspiration through consideration, planning, initiation, application, appeal and resolution. I request to inspect the three earliest created records of communication between any attorney at the firm of Sweetapple, Broeker & Varkus and any attorney at the firm of Richman Greer, P.A. that is wholly or partly concerning RICO*. Please do not include any records of communication that are already available online as part of the Town's published minutes ofpublic meetings. The records I request to inspect may include but not be limited to electronic records such as emails, voice mail, text messages, social media, and digital files located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft electronic devices capable of containing electronic records. I request to inspect the three earliest created records of communication between any attorney at the firm of Jones Foster Johnston & Stubbs, P.A. and any attorney at the firm of Richman Greer, P.A. that is wholly or partly concerning RICO*. Please do not include any records of communication that are already available online as part of the Town's published minutes of public meetings. The records I request to inspect may include but not be limited to electronic records such as emails, voice mail, text messages, social media, and digital files located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft electronic devices capable of containing electronic records. Dear Chris O'Hare [mail to: chrisoharegulfstreamna,gmail.coml, The Town of Gulf Stream has received your public records requests dated May 18, 2016, May 19, 2016, May 20, 2016, June 24, 2016, June 25, 2016, June 26, 2016, June 28, 2016, June 30, 2016, July 1, 2016 and July 2, 2016. The original public record requests can be found at the following links: httu://www2.gulf-stream.ore/weblink/0/doc/90746/Pagel.aspx httn://www2.gulf-stream.org/weblink/O/doc/90745/Pagel.asvx http://www2.gulf-stream.org/weblink/O/doc/90814/Pagel.ast)x http://www2.gulf-stream.org/weblink/0/doc/94484/Pa eg l.asax http://www2.gulf-stream.org/weblink/O/doc/94678/Pagel.aspx httu://www2.gulf-stream.org/weblink/0/doc/94684/Pa eg 1_aspxx httr)://www2.gulf-stream.org/weblink/O/doc/94727/Pagel.aspx http://www2.gulf-stream.org/weblink/O/doc/95015/Pagel.asvx hLtp://www2.gulf-stream.org/weblink/O/doc/95239/Pagel.asr)x On August 18, 2016, we sent you an e-mail stating that the Town is willing to hold these requests in abeyance until such time as the RICO lawsuit is concluded for purposes of the work product exemption under the Public Records Act. Please advise whether you would like the Town to do so or whether you would like estimates of the cost that will be incurred to review and redact all of the records that you seekfor work product privileged material. As you know, the Town's policy is if we do not hear back from you within 30 days of our response to you, we will consider the request closed. It is now past the 30 day mark. We are willing to give you an additional 30 days to advise whether you would like the Town to hold the above record requests in abeyance until such time as the RICO lawsuit is concluded for purposes of the work product exemption under the Public Records Act or whether you would like estimates of the cost that will be incurred to review and redact all of the records that you seek for work product privileged material. If we do not hear back from you within 30 days of this letter, we will consider these requests closed. Sincerely, jz"I f oW". 9wr As requested by Rita Taylor Town Clerk, Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail December 14, 2016 Chris O'Hare [mail to: chrisohareculfstreamna,email.coml Re: GS #2186 (wantman — GS comm) As Background to this request I call to your attention to the fact that The Wantman Group is a contractor to your agency and subject to Florida Statutes regarding public record inspection. This is a request for records in your custody AND in the custody of contractors. Please immediately forward this request to them for their production of records. Any and all public records of communication between The Wantman Group (including all partners, employees and agents) and the Town of Gulf Stream (including all employees, appointees, officials, assignees, and consultants including Town Manager, Town Cleric, Town Police Chief, Town Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town Engineer) the subject of which is wholly or partly regarding the Town's RICO complaint and appeal against Christopher O'Hare. Dear Chris O'Hare [mail to: chrisoharegulfstreamla,email.coml: The Town of Gulf Stream received your public records requests on May 19, 2016. You should be able to view your request at the following link: hgp://www2.gulf-stream.org/weblink/O/doc/90745/Pa eg 1_aslx The Town uses The Wantman Group for civil engineering services within Gulf Stream, so to look through "any and all public records ofcommunicalion" in possession of the Town regarding Wantman is going to require approximately an additional hour of IT support at $95.00 per hour and an additional hour of administrative support at $35.60 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). To the extent you seek "any and all public records of communication" regarding Wantman and Jones Foster or Sweetapple, Broeker and Varkus, the Town is handling the portion of records responsive to your request in public records requests GS #2185 and #2188 and refers you to those responses, or estimates, as part of the full response to this request. If the costs of producing these documents will exceed your deposit, the Town will provide you with an initial production of responsive records and an estimate for the production of any additional responsive records. If the costs of production are less than the deposit, the Town will provide you with the responsive records and a refund. (One hour @ $95.00 + One hour @ $35.60) = Deposit Due: $130.60 in cash or check. Upon receipt of your deposit, the Town will use its very best efforts to further respond to your public records request in a reasonable amount of time. If we do not hear back from you within 30 days of this letter, we will consider this request closed. Sincerely, D Jz"' )ZOM/" As requested by Rita Taylor Town Clerk, Custodian of the Records