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HomeMy Public PortalAboutPRR 16-2208RECORDS REQUEST (the "Request") Date of Request: 05/31/2016 Requestor's Request ID#: 1232 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 records(&commerce-ffoup.com; Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: 1. Provide a cony of all emails created, received or sent by the Town of Gulf Stream to Joel Chandler for the period beginning January 1. 2014 through the date of this Request. 2. Provide a copy of all emails created- received or sent by Joel Chandler to the Town of Gulf Stream for the period beginning January 1, 2014 through the date of this Request. ADDITIONAL INFORMATION REGARDING REQUEST: The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream- its Commissioners. its Manager, its emnlovees. its Police Department, its Police Officers and its Counsel and the following law firms: Sweetapple, Broeker & Varkas; Richman Greer. PA: and Jones. Foster. Johnston & Stubbs- (including, without limitation, the attorneys, emplovees and partners of each such law firm.) THIS REQUEST 1S MADE PURSUANT TO ARTICLE I, 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 5119.01(2)IF), FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON I I X 17 PAPER. NOTE: IN ALL CASES (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 §119.07(I)(H) OF THE FLORIDA STATUTES. WHICH PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WITHIN THE 10 -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 REQUESTED 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 Requestor approve of any costs, asserted by the Agency (as denned in Florida Statute, Chapter 119.01 (Dentitions)), in advance of any costs Imposed to the Requestor 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". I/P/NP/FLRR 07.28.2015 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail June 3, 2016 Martin E. O'Boyle [mail to: records@commerce-group.com] Re: GS #2208 (PRR 1232), #2209 (PRR 1233), #2210 (PRR 1234), #2211 (PRR 1235), #2212 (PRR 1236), #2213 (PRR 1237), #2214 (PRR 1238) (1) Provide a copy of all emails created, received or sent by the Town of Gulf Stream to Joel Chandler for the period beginning January 1, 1014 through the date of this request. (2) Provide a copy of all emails created, received or sent by Joel Chandler to the Town of Gulf Stream for the period beginning January 1, 1014 through the date ofthis request. The term "Town of Gulf Stream"shall mean each ofthefollowing: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Yarkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law fes). Provide a copy of all records, including, without limitation: (a) all communications, (b) attachments to such communications and © all documents which were sent by Peter Isen to any of the requestees and which were received by Peter Isen from any of the requestees for the period beginning January 1, 2013 through today. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Yarkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm). (1) Please provide a copy of any and all records requests created or sent by the Town of Gulf Stream (including their attorneys, commissioners, officers, Town Manager and employees) to any other governmental (or quasi -governmental) agency, for the period beginning January 1, 1013 through the date of this request. (1) Please provide a copy of any and all records requests received by the Town of Gulf Stream (including their attorneys, commissioners, officers, Town Manager and employees) from any other governmental (or quasi -governmental) agency, for the period beginning January 1, 2013 through the date of this request. The term "Town of GutrStream" shall mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Yarkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law f rm). (1) Provide copies of all trial transcripts, deposition transcripts, sworn statements, affidavits and other statements (the "Transcripts') made by Mr. Jeff Grey to the Town of Gudf Stream. This reques would include any and all portions of any of the Transcripts. (2) Provide copies of all communications between Jeff Grey and the Town of Gu f Stream where Jeff Gray was the sender or a receiver. (3) Please provide records, including, without limitation, all communications and transcripts emanating from Judge Barkhall's Courtroom regarding communications between Barkhall and Johnathan O'Boyle and/or Judge Barkhall and Robert Sweetapple and/or Joanne O'Connor and any other party who is (or was) a partner or employee ofJones Foster regarding Jonathan O'Boyle or the O'Boyle law firm. The term "Town of Gulf Stream"shall mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Varkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm). Provide all records including, without limitation, communications between the Town of Gulf Stream wherein the Town of Gulf Stream was the Sender or the receiver and any of the following firms were the sender and/or a receiver: Sweetapple, Broeker & Varkas, Jones, Foster, Johnston & Stubbs, Richman Greer, PA, Cole Scott & Kissane (Palm Beach Lakes), Cole Scott & Kissane (Lakeview Avenue) and Johnson Anselmo Murdoch Burke Piper & Hochman, PA during the period beginning on January 1, 2013 through the date of this request. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gudf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Varkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm). Please provide all transcripts, (including, without limitation, any and all sworn statements, deposition transcripts and trial and hearing transcripts (the "transcripts') and portions of any transcript and any transcripts which have not yet been certified), including all exhibits resulting from (a) the deposition of Robert Sweetapple dated May 27, 2016 relating to the litigation styled.- Martin tyled:Martin O'Boyle vs Robert Sweetapple and the Town of Gulf Stream. Case No.: 9:14-CV-81250- K4M,• and (b) any other transcripts involving Martin O'Boyle, Jonathan O'Boyle, Nick Taylor, Giovani Mesa, Ryan Witmer, the o'boyle law firm or Chris O'Hare. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Varkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law firm). Provide a copy of the video which was prepared concomitantly, with the sworn statement of Joel Chandler on July 23, 2014. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Varkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (inchiding, without limitation, the attorneys, employees and partners of each such law firm). Dear Martin E. O'Boyle [mail to: records(ia commerce-group.coml, The Town of Gulf Stream has received your public records requests dated May 31, 2016. The original public record request can be found at the following links http://www2.eulf- stream.org/weblink/0/doc/91280/`Pase1.aspx, htto://www2.eulf- stream.ore/weblink/0/doc/91281/Pa¢el.aspx, http://www2.¢ulf- stream.or¢/weblink/0/doc/91282/Paeel.aspx, http://www2.eulf- stream.ora/weblink/0/doc/91283/Pagel.aspx, http://www2.gulf- stream.ora/weblink/0/doc/91284/Pagel.aspx, http://www2.gulf- stream.ors/weblink/0/doc/91285/Paeel.asr)x, and htti)://www2.gulf- stream.org/weblink/O/doc/­9`­1286/Pagel.aspx. 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 e-mail August 11, 2016 Martin O'Boyle [mail to: records(a,commerce-eroup.com Re: GS #2208 (PRR #1232) (1) Provide a copy of all emails created, received or sent by the Town of Gulf Stream to Joel Chandlerfor the period beginning January 1, 2014 through the date of this request. (1) Provide a copy of all emails created, received or sent by Joel Chandler to the Town of Golf Stream for the period beginning January 1, 2014 through the date of this request. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following lawfirms: Sweetapple, Broeker & Yarkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such lawfirm). Dear Martin O'Boyle [mail to: recordsacommerce-erouo.comlI This letter provides you with the partial responsive production of public records requested on May 31, 2016. The original request can be found at the following link: htto://www2.gulf--stream.ore/weblink/O/doc/91280/Pagel.ast)x. In future correspondence, please refer to this public records request by the above referenced numbers. In response to your request, please be advised that there are no responsive emails between the domain gulf-stream.org and ioelchandlerafoewatch.ore during the pertinent time period. Responsive emails between jones-foster.com and joelchandler(iilfoewatch.ore are being produced to you at the same link above. The Town notes that it has previously responded to requests -- including requests from you and/or your affiliated entities or officers -- for records that appear to seek a subset of the present request. To find the aforementioned requests and responses, go to www.gulf-stream.org, click on "Find a Town Record", click on "Public Record Requests", click on the year you desire, click on either "Public Record Number Log" and search "Chandler" and then search by the number of the desired public records request in the folder "Public Record Requests (of desired year)". The Town understands that its outside counsel at Sweetapple, Broeker & Varkas may have additional public records responsive to your request. As you are aware, among the many pending lawsuits involving the Town are lawsuits by you against the Town and Mr. Sweetapple individually. To review e-mails during the pertinent time period to determine whether they constitute public records of the Town, as a threshold matter, and to thereafter determine whether those records are exempt under Florida Statute § I I9.0171(1)(d) and make redactions as necessary, will require extensive resources. The Town is advised that the review and production of any records in the possession of its outside counsel will require another hour of paralegal support at $125.00 per hour, and one hour of attorney support at $350.00 per hour, the labor cost of the personnel providing the service, per Fla. Stat. § I I9.07(4)(d). The Town has already spent in excess of 15 minutes responding to your request. The Town's estimate to fully respond to your request is therefore calculated as follows: (1 hour @ $125 _ $125) + (1 hour @ $350 = $350) _ $475) TOTAL = $475. The Town will complete this public records request upon payment by you of a deposit in the amount of the estimated special service fee of $475.00. 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. 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 closed. Regards, Town Clerk, Custodian of the Records Renee Basel From: Joel Chandler <joelchandler@fogwatch.org> Sent: Friday, July 18, 2014 8:19 PM To: pleadings@sweetapplelaw.com; joconnor@jonesfoster.com Subject: CAR Timeline Attachments: timeline.pdf Sorry for the delay in getting this to you. There are several ways to view the CAP Timeline. First, you can view the static version as a PDF attached below. Obviously, you'll need to zoom in. Second, you can view the Timeline in MS Powerpoint. It's in DropBox and linked here (https://www.dropbox.com/s/ulkivarblg9uy59/Timeline.pptx). Third, you can view an active version (each entry is linked to the corresponding supporting documents as a PDF in Document Cloud). It's on the web here: http://interactivetimeline.com/2808/cafi-timeline/ Let me know if you need anything else from me. Best regards, Joel Chandler joelchandler@FOGWatch.ors www.FOGWatch.org (863)660-4244 Renee Basel From: Robert Sweetapple <rsweetapple@sweetapplelaw.com> Sent: Wednesday, October 08, 2014 9:50 AM To: JOConnor@jonesfoster.com Subject: Fwd: O'Boyle Credit card fraud Regards, Bob Sweetapple Begin forwarded message: From: Pleadings < pleadings &,,sweetaonlelaw.com> Date: October 7, 2014 at 10:26:13 PM EDT To: Cynthia Bailey < cbailevna sweetaoolelaw.com>, Robert Sweetapple < rsweetanple(a sweetapnlelaw.com>, Deborah Smith < dsmithaa,sweetanolelaw.com> Subject: FW: O'Boyle Credit card fraud From: Joel Chandler[SMTP:JOELCHANDLER@FOGWATCH.ORG] Sent: Tuesday, October 7, 2014 10:26:08 PM To: Pleadings Subject: O'Boyle Credit card fraud Auto forwarded by a Rule M-1 I'm not sure if I mentioned this previously, but my understanding is that the firm may have engaged in some fraudulent activity in February or March. They were the guests of CAFI at an awards luncheon sponsored by the Florida First Amendment Foundation in Tallahassee. Originally they had planned to stay at a hotel overnight and booked some rooms. Then they decided to fly up to Tallahassee in a private charter plane the day of the event and flew back immediately afterwards. They then tired to beat the hotel out of the cost of the rooms by claiming in letter when they tried to check in the night clerk refused to give them their rooms. This was all in an attempt to save a few hundred dollars (with no regard for some poor working stiffs job). As I understand it the letter was signed by Beth Kanaly the firm's paralegal weeks but the event was before she even started with the firm. The letter to the hotel and the credit card company was actually drafted by Denise DeMartini. Let me know if you want more details. Sent from my iPad Renee Basel From: Robert Sweetapple <rsweetapple@sweetapplelaw.com> Sent: Tuesday, October 28, 2014 3:03 PM To: scottmorgan75@gmail.com; grichman@richmangreer.com; JOConnor@jonesfoster.com Subject: Fwd: Dan DeSouza's reply Regards, Bob Sweetapple Begin forwarded message: From: Cynthia Bailey < cbailey(cDsweetanplelaw.com> Date: October 28, 2014 at 11:43:31 AM EDT To: Robert Sweetapple < rsweetapple(@sweetapplelaw.com> Subject: FW: Dan DeSouza's reply fyi CYNTHIA J. BAILEY Certified Paralegal/Florida Certified Paralegal/Florida Registered Paralegal Sweetapple, Broeker & Varkas, P.L. 20 SE 3rd Street Boca Raton, FL 33432 (561) 392-1230 (t) x. 305 (561) 394-6102 (f) cba i Iev(Msweeta oolelaw.com STATEMENT OF CONFIDENTIALITY The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate, maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this message to any person other than the intended recipient(s) is not intended in any way to waive privilege or confidentiality. From: Joel Chandler[mailto:joelchandler(dfoawatch.oral Sent: Tuesday, October 28, 2014 11:30 AM To: Cynthia Bailey Subject: Dan DeSouza's reply Joel, I need to stick with November 6 at this point. Given your deposition currently scheduled in the CAFI/Bluefield Ranch case and your affidavit that we received last night in the O'Boyle/Gulf Stream case, I am going to need your deposition next week in connection with additional motions that are likely to be filed. -----Original Message ----- From: Joel Chandler[mailto:ioelchandlerCa.FOGWatch.orel Sent: Tuesday, October 28, 2014 10:19 AM To: Daniel DeSouza Subject: Can we reschedule to depo? Dan, Sent from my iPad Renee Basel From: Robert Sweetapple <rsweetapple@sweetapplelaw.com> Sent: Wednesday, July 02, 2014 8:04 PM To: scottmorgan75@gmail.com; JOConnor@jonesfoster.com Subject: Fwd: Joel Chandler has resigned as Executive Director of Citizens Awareness Foundation, Inc. Regards, Robert A. Sweetapple Begin forwarded message: From: Pleadings < pleadinss(asweetapalelaw.com> Date: July 2, 2014 at 1:17:50 PM EDT To: Cynthia Bailey < cbailey@sweetapplelaw.com>, Robert Sweetapple < rsweetapple(@,sweetanolelaw.com>, Deborah Smith < dsmith(a)sweetaoolelaw.com> Subject: FW: Joel Chandler has resigned as Executive Director of Citizens Awareness Foundation, Inc. From: Joel Chandler[SMTP:JOELCHANDLER@ FOGWATCH.ORG1 Sent: Wednesday, July 2, 2014 1:16:41 PM To: Pleadings Subject: Joel Chandler has resigned as Executive Director of Citizens Awareness Foundation, Inc. Auto forwarded by a Rule Only a few months ago I announced that I had agreed to serve as the Executive Director of the newly formed Citizens Awareness Foundation, Inc. The Foundation "is a non-partisan, not-for-profit organization dedicated to the proposition that members of the public have a right to know what their government is doing in their name and at their expense. To that end the Foundation seeks to empower citizens to exercise their `right to know' by providing free educational materials and programs, and when appropriate, taking legal action to enforce the public's right of access to public records and public meetings." Given the stated purpose of the Foundation, the promise of significant resources to accomplish that mission and the freedom that comes with a regular and very generous paycheck I was eager to take full advantage of the opportunity. On June 30, 2014, however, I resigned my position and brought my relationship with the Foundation to a definitive end. My decision to resign was the result of a series of irreconcilable philosophical and ethical differences. I have come to believe that my continued affiliation with the Foundation in spite of those differences would have eroded my credibility as a civil rights activist and negatively impacted the public's right to know. As an activist, my objective is to strengthen the public's right to know. While litigation may at times be a means to that end, for me it has never been - and will never be - the end in itself. Over the past five months it has become increasing clear that my judgment on this and other issues is at odds with the Foundation's Board of Directors. In spite of my reputation for being litigious, I don't love filing open government lawsuits although I am certainly willing to do so when the facts are right and the case will serve to improve the public's right to know. What I'm passionate about is helping regular folks gain access to the records and meetings they are entitled to. As much as I have enjoyed being paid $120,000 per year, driving a new car and having substantial resources at my disposal, I'd rather face financial uncertainty than to be a part of something that will hurt the cause that I've already sacrificed so much for. It should come as no surprise that I'm inclined to challenge authority. Frankly, that's what makes me good at what I do. No doubt, it also makes me difficult to manage and to work with. So here I am, back where I started, but with my integrity intact. Ironically, I find my new situation extraordinarily liberating. While it will require thrift, I believe I can be more effective without financial backing if the cost of that backing is service to an organization whose means and ends will, in my estimation, hurt the public's right to know. Moving forward I will be re -launching www.FOGWatch.ore and returning to my roots as a civil rights activist and an advocate for open government. The net effect of my decision to leave the Foundation will be greater freedom to work with citizens, civil rights groups, the media and public agencies on open government issues. Obviously, I will have to work within my limited material means, but I will continue to be available to work with folks who need help gaining access to their records and meetings. Best regards, Joel Chandler www.FOGWatch.ore j oelchandler0fogwatch.org (863)660-4244 Renee Basel From: Robert Sweetapple <rsweetapple@sweetapplelaw.com> Sent: Monday, October 20, 2014 2:50 PM To: JOConnor@jonesfoster.com Subject: Fwd: Tallahassee Trip Regards, Bob Sweetapple Begin forwarded message: From: Pleadings <pleadines(i4weetapplelaw.com> Date: October 20, 2014 at 10:26:44 AM EDT To: Cynthia Bailey < cbailev(@sweetapplelaw.com>, Robert Sweetapple < rsweetapple@sweetaoolelaw.com>, Deborah Smith < dsmith @,,sweetanulelaw.com> Subject: FW: Tallahassee Trip From: Joel Chandler[SMTP:JOELCHANDLER@ FOGWATCH.ORGI Sent: Monday, October 20, 2014 10:26:35 AM To: Pleadings Subject: Tallahassee Trip Auto forwarded by a Rule As we discussed, please find below a brief narrative regarding what I believe to be suspicious activity on the part of the O'Boyle Law Firm. Three current or former employees of the O'Boyle Law Firm have related virtually identical details regarding the making of hotel reservations by the O'Boyle Law Firm and the Firm's subsequent attempts to avoid paying for those hotel rooms. The folks who gave me these details have asked that I keep their names confidential due to fear of retaliation by Marty O'Boyle. In early 2014 (in March I think) the Citizens Awareness Foundation, Inc. sponsored a table at an awards luncheon for the Florida First Amendment Foundation. The luncheon was held at the Governor's Club in Tallahassee and was attended by numerous newspaper editors and the leadership of the Florida Legislature. In fact, Florida Senate President Don Gaetz sat at our table and House Speaker Will Weatherford was at the next table. In an effort to help the Firm network with other open government advocates, newspaper editors and Florida political leaders, I invited Jonathan O'Boyle and his attorneys to attend as my guests. Prior to the luncheon I worked with the Firm's paralegal, Norma Lenna, to coordinate travel and hotel arrangements. I thought it would be beneficial if I stayed at the same hotel as the Firm's attorneys because it would afford the opportunity for all of us to become better aquatinted in an informal setting. To that end Norma made reservations at a Best Western hotel in Tallahassee. My understanding is that she made reservations for the night before the luncheon for Jonathan O'Boyle, Ryan Witmer, Giovanni Messa and Marrett Hanna. In the end, the Firm's attorneys did not travel to Tallahassee the day before the luncheon. Instead, they chartered a private plane and flew up the morning of the event. In fact, they arrived late and left within minutes of the conclusion of the luncheon. That, of course, entirely negated the whole purpose of my invitation because there was no time to network with the room full of open government advocates, newspaper editors and political leaders. I have been told by three current and former Firm employees, that in a effort to avoid paying for the rooms reserved by Norma Lenna, Denise DeMartini drafted a letter or email to the hotel and the credit card company claiming that when the Firm's employees arrived the day before the luncheon at the hotel, the night desk clerk refused to allow them to check-in. Of course, they did not arrive the night before but late the morning of the luncheon. I also, understand that the letter drafted by Denise DeMartini was falsely signed by Beth Kanaly, Norma Lenna's replacement without Beth's knowledge. Renee Basel From: Robert Sweetapple <sweetapplel3@me.com> Sent: Thursday, May 21, 2015 7:51 PM To: joelchandler@fogwatch.org Subject: Re: Marty wants to take my deposition Joel Yes I will attend. Marty flipped out at a DEPO yesterday. I am filing with the court re his conduct. Regards, Bob Sweetapple > On May 21, 2015, at 11:26 AM, Joel Chandler <joelchandler@fogwatch.org> wrote: > Bob, > Today I was notified by my bankruptcy attorney, Frank Principe, that Dan DeSouza has decided he wants to proceed with my 2004 Examination (the bankruptcy version of a deposition). Dan has asked for available datea, but before I respond I wanted to see if you or someone from your team would like to attend. Obviously, you folks won't be representing me, however, the perimeters of the 2004 Examination or exceptionally broad (it's very much a fishing expedition) and is open to anyone who wishes to attend. After my last encounter with Dan and Marty I expect there will be more attempts at witness intimidation, etc. Since I have nothing to hide and my finances are already an open book, I thought your team might consider this an opportunity to sit in on the proceedings and ask your own questions. Since the basis of Marty's involvement in my bankruptcy is the CAR v. Chandler lawsuit and since my defenses to that lawsuit have already been filed with the Court and those facts (largely the same as those discussed in my sworn statement to you) are very much an appropriate topic of conversation as are Marty's attempts at intimidation this might afford your team with an opportunity to get more of those facts on the record. > Let me know if you have any interest and, if so, what dates work best for you. If you are interested, also let me know if you'd prefer to keep your appearance as a surprise. It is my understanding that there is no requirement to notice your appearance, but you'll want to double check that. > Best regards, > Joel Chandler > joelchandler@FOGWatch.org > www.FOGWatch.org > (863) 660-4244