HomeMy Public PortalAboutO'Boyle Transcript - 5/16/161
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Martin O'Boyle
May 16, 2016
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 9:14-cv-81250-KAM
MARTIN E. O'BOYLE,
Plaintiff,
VS.
ROBERT A. SWEETAPPLE and
TOWN OF GULF STREAM,
Defendants.
DEPOSITION OF MARTIN E. O'BOYLE
May 16, 2016
10:50 a.m. - 5:15 P.M.
555 West Railroad Avenue
West Palm Beach, Florida 33401
Stenographically Reported By:
RICHARD GREENSPAN, FAPR, RMR, CRR, FPR
U.S. Legal Support Job No. 1403046
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Martin O'Boyle
May 16, 2016
APPEARANCES
On Behalf of the Plaintiff:
MARTIN E. O'BOYLE, Pro Se
moboyle@commerce-group.com
1280 West Newport Center Drive
Deerfield Beach, Florida 33442
(954) 360-7713
Limited Appearance for the Plaintiff:
THE O'BOYLE LAW FIRM, P.C.
1286 West Newport Center Drive
Deerfield Beach, Florida 33442
(954)570-3533
BY: JONATHAN R. O'BOYLE, ESQ.
(Admitted in Pennsylvania)
joboyle@oboylelawfirm.com
On Behalf of the Defendant Town of Gulf Stream:
JOHNSON ANSELMO MURDOCH
BURKE PIPER & HOCHMAN, P.A.
2455 East Sunrise Boulevard, Suite 1000
Fort Lauderdale, Florida 33304
(954) 463-0100
BY: HUDSON C. GILL, ESQ.
hgill@jambg.com
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Martin O'Boyle
May 16, 2016
APPEARANCES (Continued)
On Behalf of Co -Defendant Robert Sweetapple, Esq.
COLE SCOTT & KISSANE
Espirante Building
222 Lakeview Avenue
West Palm Beach, Florida 33401
(561) 681-5523
BY: JOSHUA GOLDSTEIN, ESQ.
Joshua.Goldsteinmcsklegal.com
Also Present:
Chris O'Hare
Doug Stacey
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Martin O'Boyle
May 16, 2016
WITNESS:
MARTIN E. O'BOYLE
By Hudson Gill
By Joshua Goldstein
EXHIBITS:
Defendant's Ex 1
Defendant's Ex 2
Defendant's Ex 3
Defendant's Ex 4
Defendant's Ex 5
Defendant's Ex 6
Defendant's Ex 7
Defendant's Ex 8
Defendant's Ex 9
Defendant's Ex 10
Defendant's Ex 11
INDEX
DIRECT CROSS REDIRECT RECROSS
9
DESCRIPTION:
165
64 177
IDENTIFIED:
Answers to Interrogs.
7
Amended Answers to
7
Interrogatories
Diagram
41
14\1
41
Letter
51
Letter
51
Sunbiz Printout
88
Responses
95
Second Amended Complaint
100
Minutes
143
Doc Entitled "Damages"
154
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Martin O'Boyle
May 16, 2016
P R O C E E D I N G S
THE COURT REPORTER: Do you solemnly swear
to tell the truth, the whole truth and nothing but
the truth in these proceedings?
THE WITNESS: I affirm to tell the truth.
Thereupon,
MARTIN E. O'BOYLE,
having been first duly sworn, was examined and
testified as follows:
DIRECT EXAMINATION
BY MR. GILL:
Q. Good morning, Mr. O'Boyle. You have been
deposed before, so can I forego with the general
guidelines for how depositions work?
A. I prefer that you didn't.
Q. This is a process where I am going to ask
you a series of questions. You need to answer those
questions verbally and out loud so the court reporter
can take everything down, because shakes of the head
and nods don't come out clearly.
If there is something about a question that
I ask you you don't understand, please ask me to
clarify and I will do my best, because if you answer
the question, I will assume that you understood it.
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Martin O'Boyle
May 16, 2016
A. You are going a little bit too fast for me.
I apologize.
Q. All right.
A. I got the verbally out loud and then the
second one I missed.
Q. If you don't understand something of my
question, please ask me to clarify.
A. Yes, sir.
Q. If you need to take a break for any reason,
just, please, let me know and I will do my best to
accommodate you.
Also try to allow us -- I am going to finish
my question before you start speaking even if you
know what I am asking, because if we talk over each
other it is not clear for the record. Do you
understand that?
A. Yes. Let me just make sure.
By the way, my walker didn't make it here
with me, my wife is dropping it off, and when she
does, I am going to have to run to the bathroom
quickly, so I will just tell you that.
Q. Okay, fair enough.
A. After the break you were saying something
else, talking over each other?
Q. Yes.
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Martin O'Boyle
May 16, 2016
A. Okay.
(Defendant's Exhibit 1 was marked for
identification.)
(Defendant's Exhibit 2 was marked for
identification.)
Q. Mr. O'Boyle, I would like you to look at
what's already been marked as Exhibits 1 and 2 for
the deposition and just see if you can identify your
signature on the last page of each of those
documents.
A. Yes, they are my signatures.
Q. I will state that those are your answers to
interrogatories and then your amended answers, and my
questions initially are going to focus on answers 7
and 8 of Exhibit 2. So if you want to take a moment
to review those, please do so.
A. Do you want me to read them first?
Q. You can if you want to just familiarize
yourself. I am going to ask you about specific
things in there and I will go over things in more
detail, but if you will read questions 7 and 8,
that's what my questions are going to focus on.
A. Okay. I assume I can't mark this, meaning
ink it?
Q. No, because it is going to be an exhibit.
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Martin O'Boyle
May 16, 2016
A. Okay. You'll excuse me.
(A recess was taken.)
Q. Back on the record?
A. Yes.
Q. With respect to your answer to interrogatory
7, you listed seven individual paragraphs. Are those
all the First Amendment activities that you are
seeking protection for in this lawsuit?
A. I don't think so. I think they are all the
ones that came to mind. I think there is a
significant number, a greater number, I think.
Q. So that's not a complete answer?
A. I think it was as complete as you can get
the day it was answered.
Q. Okay. Are there events since then that you
are seeking protection for in this lawsuit?
A. I don't know since then, but I think before
then, around then, maybe since then.
Q. Okay, what are those activities that are not
contained in your answer?
A. Well, as I said, this was put together at
the time based upon my, my knowledge and recall.
Q. Okay.
A. And what you are asking me to do is to alter
that, and I don't mind accommodating you. A few
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Martin O'Boyle
May 16, 2016
things that I could think of off the top of my head,
the -- the town, they passed a decorum ordinance to
prohibit speech.
The town passed a -- um, a sign ordinance,
which prohibited the Pope from coming to Gulf Stream.
Q. I'm asking you about activities you have
engaged in that are protected.
The next question talks about acts by the
town that you are claiming were retaliatory. Let's
focus on what you have done that you claim is
protected by the First Amendment that you are seeking
protection for in this lawsuit.
A. Right. If the Pope can't come, neither
could I.
Q. Okay. But what First Amendment activity did
you engage in that's not reflected in the answer to 7
that you are seeking protection for in this lawsuit?
A. Speech.
Q. Okay, what activity of speech, other than
what's engaged in there, are you claiming the town
retaliated against you for?
A. Well, that's a very -- um, it's very hard to
answer that question sitting here. If I had known
you were going to ask me that question, I would have
spent a couple of days and given you a hopefully
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Martin O'Boyle
May 16, 2016
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complete list or more complete list, but I think the
sign ordinance that they passed I think was directed
towards me, and I think that sign ordinance also
prohibited me from, as an example, of having a hat.
To me that's speech. A hat that says Hudson Gill for
Mayor, that's speech.
Q. Let's focus on what you actually did first
and then we will talk about what the town did. So I
need, whatever, if you claim there are things that
aren't reflected in the answer to 7, and there is a
pretty big list we will go through, but I want to
make sure that this is what this lawsuit is about.
A. Okay, how did I not answer you? I thought I
did.
Q. Well, because you are talking about
hypotheticals in what you could have done. I want to
focus on what you have done that's protected by the
First Amendment, and maybe it's, it's reflected in
here and we will go through those, but I want to make
sure there is not something that's not in your answer
that you prepared.
A. Okay, going back to the sign ordinance, they
passed a sign ordinance which made me in violation of
the sign ordinance.
Q. Okay, and is that what, if you look at
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Martin O'Boyle
May 16, 2016
paragraph 5, when you talk about running for the
commission, are those the signs that you are
referring to?
A. Not in the answer that I just gave you.
Q. Okay, are there other signs that you placed
up that you claim were protected by the First
Amendment that were impacted by the sign ordinance?
A. They passed -- well, the sign ordinance, I
am not sure that the sign ordinance that I am
speaking of was singularly a modification of the sign
ordinance. I am just not recalling as I sit here
today. But what I do know is that the sign ordinance
they passed I believe was directed towards me and it
put me in violation virtually based on whatever I
did.
Q. Okay. Since that, have you placed signs
that have been, that you received a citation for?
A. I would have to do a timeline, but I think
the answer is yes.
Q. Okay, when were you cited under the new
ordinance for placing signs up?
A. Okay, now, when you say under the new
ordinance, I am not sure what you mean.
Q. Okay. Well, my understanding, and I thought
you were referring to that, maybe I assumed, the town
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Martin O'Boyle
May 16, 2016
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had a sign ordinance in place that was amended and
then there was a new sign ordinance in place; is that
your understanding?
A. Sort of.
Q. Okay, what is your understanding?
A. I think there may have been a couple of
amendments, but I am not sure, but I do know that
there was a new sign ordinance, which as an example
would prohibit the Pope from coming to Gulf Stream.
Q. Since that new --
A. The Pope sign ordinance you are talking
about?
Q. Yes. Have you ever been cited under that
new sign ordinance?
A. What do you mean by cited?
Q. Has the town given you any type of notice or
citation or fine or anything that you were in
violation of that new sign ordinance?
A. I think Mr. Thrasher -- no formal citation,
but I think he -- I'm not sure if scolded is the
right word, but said I couldn't have it.
Q. Have what?
A. The sign, whatever it was, it may have been
on my truck, it may have been -- it may have been in
a place that I can't find. It may have been for
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Martin O'Boyle
May 16, 2016
this.
Q. And what are you referring to so it's clear
for the record?
A. Yes, sure. This is a button like a
political button about the size, I'd say it's maybe
2 inches by 2 inches and it says Dump or Save Gulf
Stream, Dump Morgan.
Q. And that's reflected in subparagraph 7 of
interrogatory 7?
A. If you call it an anti -Mayor Morgan, which I
think I would call it, then I think it is in
paragraph 7.
Q. That's your answer to the interrogatory,
correct?
A. Yes, that's what I said. I said I think I
would call it that.
Q. So with respect to that, I believe you said
Bill Thrasher scolded you for wearing that?
A. I don't know that scolded is the right word,
but I think he, um, one of those ones you shouldn't
be wearing that, that's in violation, and that kind
of -- it was nothing like -- he didn't get out the
whips and chains.
Q. Okay, was anyone present when he said that
to you?
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Martin O'Boyle
May 16, 2016
No. Well, maybe Mr. O'Hare, but I don't
z
Q. All right, when was that conversation?
A. I don't know.
Q. Where was that conversation?
A. Well, I shouldn't say I don't know. It was
after receipt of this.
Q. Okay.
A. And it was outside the back door of the town
hall.
Q. Okay, other than having a conversation with
Mr. Thrasher about it, have you spoken to any other
town official regarding your anti -Morgan political
button?
A. You are talking about a town official?
Q. A town official or employee regarding your
anti -Mayor Morgan political button.
A. Maybe.
Q. Who else?
A. I don't -- um, I just said maybe, that's --
Q. Okay, do you specifically remember any other
conversations with any other town representatives or
employees regarding your anti -Mayor Morgan political
button?
A. I seem to remember wearing it when I was in
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Martin O'Boyle
May 16, 2016
the company of Joanne O'Connor. I seem to remember
that. And perhaps Skip -- again, I would have to
look at a time period, because if I obtained these in
October, I sure couldn't have had a meeting in
September. So I would have to look at a timeline,
but I think it was Joanne and maybe Skip.
Q. Okay, did you have a conversation with them
about the button?
A. If I did, it was short, incidental and
spirited.
Q. Okay. Have you ever received any written
notices of violation or fine or anything like that
regarding your wearing the button from the town?
A. I thought I answered that already, didn't I?
Q. I just want to make sure it's clear for the
record. Maybe I misrecall, so.
A. Okay, the only person that I recall is
having the conversation with Mr. Thrasher, and I used
the term scolded, if that brings back your memory.
Q. You still wear the button from time to time
today?
A. Yes.
Q. In I guess it's the first sentence of your
answer to paragraph, to interrogatory 7, which goes
from page 3 to 4, you make reference to practices
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Martin O'Boyle
May 16, 2016
IC
religion, assembles, associates with other groups and
family members. Are you claiming that the town
retaliated against you for practicing your religion
in this case?
A. We are in paragraph 1, are we?
Q. No, no, no, it's before paragraph, it's the
first sentence of your response, which goes from page
3 to paragraph 4, just above subparagraph 1.
A. Okay. Okay, what's your question?
Q. Are you claiming that the town has
retaliated against you for practicing your religion
in this lawsuit?
A. I don't see where you have directed me to
refer to retaliation.
Q. Well, the question is asking for each
occasion of protected activity in this matter, and
this matter is a First Amendment retaliation claim.
So you are claiming you engaged in First
Amendment activity and the town retaliated against
you in some way and I just want to make sure we have
got everything that you are claiming you engaged in
that the town retaliated against you.
A. Just as a general statement, I don't think
that this is comprehensive, and it's not because we
are hiding anything, it's just that there is so much.
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Martin O'Boyle
May 16, 2016
It would be like asking you your grades in every
class through high school. You are not going to be
able to do that for me, but I think we have done the
best that we can here.
When you say in connection with religion,
when I went over this with my counsel, Mr. DeSouza --
MR. O'BOYLE: I'm going to say you should
not talk about communications with your counsel.
THE WITNESS: Okay.
Q. I am not asking things that you had with
previous counsel.
MR. GILL: I am also directing to
Mr. O'Boyle, you haven't entered an appearance as
counsel and it is not appropriate for you to
engage in speaking objections because you are not
in this lawsuit.
MR. O'BOYLE: Just for the record, I stated
earlier that I am here for a limited appearance.
I am not entering an appearance. Mister -- is it
Mr. Gill?
MR. GILL: Yes.
MR. O'BOYLE: -- instructed me to refer to
the Local Rules of the Southern District of
Florida. I have reviewed them and I can find
nowhere where I am required to file a limited
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Martin O'Boyle
May 16, 2016
appearance. So just move this along.
Q. Well, can you answer that question without
disclosing what you discussed with your previous
attorney?
1C
A. I don't see how.
Q. Okay, focusing on subparagraph 1, you
referenced banner speech from airplanes and trucks,
and then you identify a number of dates which -- for
the banner planes; is that correct?
A. It appears to be, yes.
Q. And you flew the banner planes or you had
someone on your behalf fly the banner planes around
the town critical of the officials?
A. First of all, I don't think they were around
the town. I think that's an improper statement.
Q. Okay. Okay. Where were they?
A. Where were?
Q. The banner planes that you are seeking
protection for in this lawsuit.
A. They would have been or could have been in
Delray, in West Palm Beach, and I don't know where
else they could have been.
Q. And the banner planes were flown on your
behalf?
A. Um, the banner planes were flown, I
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Martin O'Boyle
May 16, 2016
authorized them, if that's your question.
Q. Okay, and then you also referenced a banner
truck. How many banner trucks did you have?
A. None.
Q. Okay. How many banner trucks did you
authorize to be displayed in and around the Town of
Gulf Stream?
A. None.
Q. Okay, how are you seeking protection for a
banner truck if you didn't authorize one or have it
placed around the Town of Gulf Stream?
A. Because the banner truck wasn't being driven
around the Town of Gulf Stream.
Q. I don't think I said driven, but if I did, I
apologize.
A. All right, it wasn't around the Town of Gulf
Stream --
Q. Okay.
A. -- whether it was driven or pushed or
pulled.
Q. Okay, did you authorize the banner truck
that you are referencing in subparagraph 1?
A. Did I authorize it?
Q. To do whatever it did. This is your answer.
I need the information from you, Mr. O'Boyle.
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Martin O'Boyle
May 16, 2016
A. Yes. Well, the answer is I parked it in my
driveway with a banner on it.
Q. Okay.
A. So I authorized that.
Q. Okay.
A. We parked it at city hall --
Q. Okay.
A. -- with a canvas banner on it, so I
authorized that. We parked it in Delray Beach on
Federal Highway with a banner on it, so I authorized
that. And I think there is more, but I just don't
remember.
Q. Do you think there is more locations in the
Town of Gulf Stream that you parked the truck other
than the two you just referenced?
A. If I did, it would be at the police station,
which is 50 feet away, but I don't recall doing that.
Q. Your wife was cited for parking the vehicle
in the town parking lot once?
A. Yes. That's nice, huh?
Q. Is that true?
A. I don't know.
Q. Okay, you don't know if your wife was cited
for having the banner truck parked in the town
parking lot?
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Martin O'Boyle
May 16, 2016 21
A. I don't know. I know that they towed her,
they towed the truck, which belonged to her. I do
know that. Whether they cited her, I don't remember
any magistrates hearings or any of that kind of
stuff.
Q. Okay, other than the one time it was towed,
was it ever towed again?
A. I don't think we parked it there again.
Q. Okay, so you haven't parked it there since
the time it was towed?
A. Well, no. With the threats that were going
on from the town, you wouldn't do it either.
Q. Per the town ordinance, could you still park
your vehicle in the town parking lot?
A. Well, that's, that's a question that I
wouldn't even know how to start answering.
Q. Okay, so you don't have an answer to that
question?
A. To that question?
Q. Yes.
A. No, I do not have an answer to that
question.
Q. Did you receive any kind of citation or did
your wife for parking it in Delray?
A. I don't think so.
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Martin O'Boyle
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Q. Can you recall the content of the banner
planes that you authorized to be flown I guess in
Palm Beach County?
A. Um, as I sit here I can't, but I think it's
in this document, and if you want, I can find it and
read it and confirm it for you, if it will help you.
Q. Please do.
A. Well, it must have been something else I
read or else I'm just missing it. I don't see it.
Q. From memory can you remember the content of
the signs?
A. I remember there was one or two about Jones
Foster, I think there was one or two or three about
Mr. Sweetapple, and I think there was one or two or
three or four about the Town of Gulf Stream and/or
their constituency.
Q. Do you recall anything else about the
content about the ones about the Town of Gulf Stream
and their constituency?
A. I don't, but I can confirm it if you told
Q. What about the ones about Jones Foster?
A. I don't remember them exactly, but one of
them I think said "Watch your bills," and I forget
what the other one said.
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Q. What specific acts of retaliation are you
claiming the town took against you because you
flew -- had the banner planes flown around Palm Beach
County?
A. Well, I think, and I said it before, I think
Mr. Sweetapple prepared the biggest piece of shit
pleading that I think I have ever seen -- and I told
him that before and it's on the record -- against my
son on the basis that they were going to collapse my
son, put him in jail, take away his future in an
effort to get me, but boy, was he wrong.
Q. When you say pleading, what are you
referring to?
A. He filed something that said, and I don't
remember, but he said, it said something about my son
was engaged in the unpracticed license of law, and
when I saw it, I just said, "This is the biggest
piece of shit I have ever seen."
Q. Are you referring to the complaints with the
Bar or something other than that?
A. I'm not really sure whether it's the
complaints with the Bar or something other than that,
or both. All I know, it was a piece of shit.
Q. Are there any other acts that you claim the
town took to retaliate against you for the banner
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planes specifically?
A. Again, I don't remember what I have just
gone through. I added a little flavor for it, but I
think, I think the town has -- well, they filed a
RICO action, which is absolutely unheard of, and I
think it made national news, because I think most of
the people that I talked to said, "Who in the hell
was the smacked ass that did this?"
Q. Are you claiming that the RICO lawsuit was
done to retaliate against you for the banner planes?
A. Absolutely. Well, not necessarily for the
banner planes, but for the whole enchilada.
Q. Okay, I will ask specifically about the
banner planes right now and we'll go and talk about
the interrogatory that talks about the things of
retaliation and RICO is in there, but is there
anything you specifically claim, other than what we
just talked about, that was done in retaliation for
the banner planes?
A. We will have to look at the videos of the
various town meetings, which I have them online and
we can do that, and I think that would answer all of
your questions.
Q. Okay, what about the town meetings would
answer the question?
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A. What about them?
Q. What about the videos of the town meetings
would help me answer my question?
A. Do you want me to pull them up?
Q. I don't want to go through all the town
meetings because I am sure there are a lot of them,
but I just want to know what you believe and what
your memory is what you are claiming the retaliation
is for in the lawsuit.
A. You have given me a plateful here, and it
has been a while since I have addressed this, and I
got in town late last night, so I haven't had a lot
of time to deal with this, but nonetheless, that's
not your fault, that's my fault.
I have given you what I have recalled on the
day that we went through it. As we go through this
deposition, my sense is that I will make some
additional recollections, and as I do, I will
interrupt you, unless you prefer me not to do that,
and I will provide you with the answers as I recall
them.
Q. The next paragraph references, and this is
subparagraph 2, it says, "Plaintiff has spoke at Gulf
Stream public meetings and quasi-judicial hearings on
and off since 2013."
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What are you referring to by "quasi-judicial
hearings"?
x
A. You know, I don't know. When I say I don't
know, I'm not a lawyer, so I can't tell what a
quasi-judicial meeting is as opposed to a town
meeting. I can't tell you about my conversations,
but that's the best I can tell you.
Q. Have you spoken at any other meetings, other
than commission, meetings with the town?
A. I would say yes, I did.
Q. What other type of meetings have you spoken
of?
A. I think a handful of architectural -- I
don't know whether it's called Architectural Review
Commission, whatever.
Q. Okay. During any of those meetings were you
ever issued a citation by the town for your conduct
during those meetings?
A. I always had good conduct during those
meetings. Why would they cite me?
Q. So the answer is no?
A. The answer is they wouldn't cite me, no.
Q. What specific acts of retaliation are you
claiming the town took against you for statements
that you made during public meetings?
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A. I think they belittled me. I think they
implied, if not directly said, I was a liar. I think
they stated I didn't know how to read. I think they
stated that I did not know how to take words and put
them in proper context and from that get a meeting --
I'm sorry, a meaning.
I don't remember your question exactly.
They put up trees so they couldn't see my
car. That was a good one.
Q. When you said, referring to what was -- you
said they belittled you at town meetings. Who is the
they you are referring to?
A. Well, for the most part, I can't think of
her name, but the lady whose family sells alcohol.
You know, alcohol kills people? I can't think of her
name right now. She is a blonde. They are in the
alcohol business.
Q. Is she a commissioner?
A. Yes.
Q. Okay.
A. I can't think of her name right now.
Q. Okay.
A. And then I would say the mayor. I would say
those two.
Q. Okay, and when you referred to a few
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examples of them calling you a liar and saying you
can't read, were those the two people that you are
referring to?
A. For the most, for the most part, I think the
answer is yes. Being accused not to be able to read
is an interesting experience, particularly when you
are being scolded by a person -- well, by another
person.
Q. Were you being critical of the town and some
of its decisions during the meetings when the
belittling took place?
A. I don't know that I would be critical. I
would just say that they were out and out off the
charts.
Q. I'm sorry, I don't -- I don't understand
your answer. I mean, you said you weren't being
critical, but you were saying they were off the
charts?
A. I thought you said they were -- I'm sorry.
Q. I'll start over. When this belittling took
place, were there meetings where you began to speak
out against the town and any of its decisions?
A. Probably.
Q. You reference in subparagraph 3 to The
Patriot, the paper called The Patriot. How many
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issues has the paper published?
A. I think, I think we published -- I think we
published two hard and maybe more online, but I'm --
don't count on that.
Q. When you say we, who is we?
A. As far as the content, me. As far as
picking the font, somebody in my office.
Q. And who was the person at your office?
A. How would I know?
Q. Who would you talk to once you would finish
it about getting it published online or published in
hard copy?
A. I don't know. A lot of people are there.
Q. So you have no recollection of how you went
from -- do you have any idea in your head from
getting it published and then mailed out?
A. I bet you don't know who you got your pencil
from this morning.
Q. The answer is no?
A. The answer is no.
Q. When was the last time you published one
online or in hard copy?
A. That was quite a while ago, quite a while.
Q. Have you ever spoken to anyone at the town
about The Patriot?
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A. Probably.
Q. Do you have a specific recollection of
speaking to anyone from the town, either an elected
official or an employee, regarding The Patriot?
A. I'm sorry, did any --
Q. Do you have a specific recollection of any
conversations with any town employee or town
representative regarding The Patriot?
all
A. Yes.
Q. Who?
A. Mr. Thrasher.
Q. Okay, when did you speak to Mr. Thrasher
about The Patriot?
A. They have a pile of the local newspaper is
called the -- I don't know what it's called. There
is a local newspaper, Coastal Star, and they had a
pile this high on their desk. So I put a pile of the
Patriots this high and then came back about
20 minutes later and they were all gone. What does
that tell you?
Q. Okay, did you talk to anyone about that
though?
A. Yes. I said, "What's going on?" Nobody
knew anything.
Q. who did you talk to about it that didn't
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know anything?
A. I think -- yeah, I think it was Mr. Thrasher
and/or Rita, but it may have been both.
Q. And what was the substance of the
conversation?
A. "Where is all the Patriots? They were here.
They were here a half hour ago. What did you do?
Have a line outside trying to get them? Come on,
what did you do with them?" I mean, it was pretty
obvious to me they stole them.
Q. And what was their response to your
conversation?
A. "We don't know."
Q. Other than that, have you spoken to anyone
else at the town about The Patriot?
A. I'm sorry?
Q. Other than that conversation, do you have a
specific recollection of any other conversations with
town employees or officials regarding The Patriot?
A. I can't tell you.
Q. Subparagraph 5 references you running for
town commission and posting campaign signs during the
election cycle of 2014, correct?
A. Well, whatever it says it says.
Q. Is -- and that is -- that activity is
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subject to another federal lawsuit, is it not?
A. It is placed in a lawsuit and it says what
it says, and I don't know more you want from me.
Q. Well, maybe my question is inartful. You
have another federal lawsuit against the town
regarding your campaign signs during the election, do
you not?
A. I don't know.
Q. What specific acts of retaliation are you
claiming the town took against you for running for
town commission on posting campaign signs during the
election cycle in 2014?
A. Well, my personal view is the commissioners
of the town are nothing more than thugs in suits, so
let's get that out there.
As far as running for town commission, I did
do that. And the only reason I did that is there is
21 years when they didn't have an election, and I
thought this is America, we should be having
elections, and of course you agree with that, all
right?
Q. It's your deposition, you have to answer the
questions.
A. I appreciate that, but I was just thinking
that you might agree with it, elections every 21
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years, okay, but if you don't, I understand.
Town commission and posting campaign signs
during the election cycle 2014. Doug Stacey has
knowledge of these signs as well as town personnel
who removed them and the private citizens who likely
aided the town. The signs were placed between
February and March, which it wasn't.
Q. What acts of retaliation are you claiming
the town took over the campaign signs?
A. They stole my signs.
Q. I know I asked you this, but I will try
again. Maybe your memory has been jogged. There is
a lawsuit about that, is there not?
A. I came here to talk about this lawsuit and
that's why I'm here. If there is another lawsuit
about that, please depose me in connection with that
lawsuit and I'll answer any questions you might have.
Q. Well, I did depose you in that lawsuit.
A. Okay, then, there you go.
Q. So there is another lawsuit over that
activity. So it is being addressed by another
federal court, right?
A. I have answered you.
Q. Subparagraph 6 says, "Filed lawsuits against
the town and/or appealing or petitioning courts for
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redress of grievances or administrative agencies."
I think I understand what filing lawsuits
against the town means, but the second part of the
sentence "or appealing or petitioning courts for
redress of grievances or administrative agencies,"
what did you mean by that?
A. I think it's a broad form of saying the same
thing.
Q. Okay, going back to subparagraph 5, who is
Doug Stacey?
A. Doug Stacey is a fellow who is a wonderful
young man, who works very hard and I'm proud to know
his acquaintance.
Q. Okay, who does he work for?
A. I'm not 100 percent sure.
Q. Okay, what is your non -certain understanding
of who he works for?
A. I'm not 100 percent sure.
Q. How do you know him?
A. I have known Doug for maybe 20 years.
Q. And what brought him into your circle so
that you got to know him?
A. My wife introduced him to me.
Q. Do you know how your wife knows Doug?
A. No idea.
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Q. Now I'm going to ask you some questions
about your answer to interrogatory 8. So did you
have a moment to review that already? Yes?
A. Yes. When I smile that means yes.
Q. It doesn't come out on the record though, so
you have to answer verbally.
A. With all these cameras here, I could go like
this (indicating).
Q. Subparagraph A refers to that the town has
falsely claimed that the plaintiff is not trustworthy
because he breached a settlement agreement reached
with the town in 2013. What are you referring to in
that?
A. What am I what?
Q. What are you referring to in that?
A. The town has falsely claimed that plaintiff
is not trustworthy. I don't know what more you can
say.
Q. When did the town claim that?
A. Oh, I think they have been claiming it since
2013 through this afternoon.
Q. Okay, in what context?
A. That I breached the settlement agreement.
Q. In what context was the town claiming that?
A. You know, it's not really clear to me,
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because no matter how you slice it, no matter how you
dice it, they breached the settlement agreement, not
me.
Q. Was this in a legal proceeding that they
claimed this?
A. No.
Q. It was not? The answer references a case
number.
A. Okay, what's your question?
Q. What is that case about as you understand
it?
A. It must be about what is the content of the
settlement agreement.
Q. What is your understanding of what the
lawsuit was filed over, what relief was sought?
A. I think this would have been filed over, and
you want me to guess, correct?
Q. I want you -- these are your answers to
interrogatories and you referenced something in them,
I want you to explain what your understanding of
what's referenced in your answers to interrogatories
are.
A. Okay. Well, my answer to interrogatory is I
am assuming it had something to do with the
settlement agreement. Beyond that I don't know. It
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could have been a writ of certiorari by Charlie
Siemens. I don't know.
Q. In that answer, in the second to last
sentence, you reference that the town filed this
frivolous lawsuit in hopes that plaintiff would stop
engaging in speech petitioning as well as for
punishment for plaintiff running for election. How
do you know that?
A. Well, because as you just pointed out, there
was a lawsuit filed in the very next town -- in the
very next sentence it says it was a frivolous lawsuit
in hopes that I would stop engaging in speech
petitioning as well as a punishment for plaintiff
running for election, but if it's occurred, it is
incurring attorneys fees in defending the lawsuit by
the town.
Q. What facts do you have that make you believe
that that lawsuit referenced there was filed to make
you stop engaging in speech as well as punishment for
running for election?
A. Well, it was three years ago, so my memory
might be a little bit on the stale side, but
everything that this town did that I can recall,
except for perhaps some minor innocuous items, was to
chill my speech, and I think that that's what that's
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talking about. The town turned down my proposed
retrofit of my home. When they did, I was very
honest with them and I told them if they didn't
approve it, I was going to retrofit my home in
accordance with the First Amendment of the United
States Constitution. I did that.
They didn't like it at all. I think they
did cite me. We had a hearing before the magistrate.
They issued a full written apology and paid $180,000.
So that will show you where they came out.
Q. Are you done?
A. Yes.
Q. With respect to the retrofit, you said you
would retrofit it in accordance with the First
Amendment. What did you do?
A. I put -- um, I don't know what you would
call them, but I put graphics on the -- on my house.
Q. Can you describe the content of those
graphics?
11
A. Yes. I put a donkey with a Shrek-like
character that said "vice mayor" and I had a
buckteeth, bucktooth blonde sitting on the top of the
donkey reminiscent of what Mayor -- I can't think of
her name. She was the mayor then. And then it says,
"I'm taking this ass to the town hall."
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Q. Anything else you recall?
A. Yeah, and then I put in Tweedle Dee and
Tweedle Dum, and I can't remember which one Judge
Marra called Dum. I just can't remember it.
Q. Which one Judge Marra called Dum?
A. Yes.
Q. When did Judge Marra do that?
A. I think in an order.
Q. And who was he referring to?
A. I don't know. It was either Thrasher or the
mayor, I don't -- one of the two.
Q. Those are the two people you put as Tweedle
Dee and Tweedle Dum?
A. Yeah.
Q. Were you interviewed by the media about
that?
A. I'm not sure about that, but yes. Yes,
about the, the entire goings on, so to speak.
Q. There was local news coverage of the
paintings on the side of your house, correct?
A. It went all the way to London.
Q. Okay, so it was international news?
A. International, yes.
Q. Do you know if you can still find those
stories online?
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A. I never looked.
Q. Do you know what the outcome of the lawsuit
referenced in subparagraph A was?
A. I just told you.
Q. Okay, you think that's the lawsuit that
resulted in the settlement agreement?
A. I don't see any other lawsuits and I know
that there was a lawsuit and I know that there was a
settlement agreement, and two and two usually equals
four.
Q. With respect to subparagraph B that talks
about the truck banners and the ordinance that was
passed and hedges that were built, where were the
hedges built?
A. I would have to draw a plan.
Q. Okay, can you just draw a rough sketch?
A. Have you got a piece of paper? It shows up
much better on yellow. The heavy red is where the
trees were.
Now, that may not be exact, but the
intention of the trees were to block the visibility
of anybody who parked here. So if I parked my truck
here, the trees were certainly high enough that you
would not be able to see.
As an example, if I put a suppository
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statement about Mr. Sweetapple, you would not be able
to see it.
MR. GILL: I would like to mark this as
Exhibit 3.
(Defendant's Exhibit 3 was marked for
identification.)
Q. Just so I make sure I understand, it says
rear exit on there, is that what that says?
A. It does.
Q. And that's town hall, correct?
A. Yes, it is.
Q. And then what is this, Sea Road?
A. Yes, it is.
Q. How tall were the hedges?
A. Taller than me.
Q. Are you aware of any other vehicles that
have been parked at town hall in violation of
ordinance 14\1 that weren't cited?
A. May I see 14\1?
Q. Sure.
MR. GILL: Mark this as the next exhibit.
(Defendant's Exhibit 4 was marked for
identification.)
Q. Mr. O'Boyle, are you aware of any other
vehicles that have been parked in the town parking
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lot after 7 p.m. and before 7 a.m. that weren't
cited?
A. When?
Q. Since the passage of the ordinance governing
parking in the town parking lot.
A. Say your question again.
Q. Are you aware of any other vehicles, other
than the truck with the banner on it, that have been
cited or towed for parking in the town parking lot
after 7 p.m. and before 7 a.m. since the passage of
the town's ordinance governing parking?
A. So you are only saying towed or what else?
Q. Cited.
A. Cited. Just limited to that?
Q. Yes. We will start there.
A. Okay. Not I can recall.
Q. Okay. And just so I am clear, are you aware
of any vehicles that have parked after 7 p.m. and
7 a.m. in the town parking lot and have not been
cited or towed since the passage of the parking
ordinance?
A. I don't think I have ever -- I don't think
we have ever parked there considering the hours in
the parking ordinance.
Q. I'm sorry, I don't understand that.
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A. Okay, why don't you ask your question again.
Q. Okay. Are you aware of any vehicles, other
than the banner truck, that were parked in the town
parking lot after 7 p.m. or before 7 a.m. and were
not towed since the passage of the town's parking
A. I don't think there was ever a car or a
truck parked there.
Q. Okay.
A. I may be wrong, but I just can't remember.
I know the truck for sure.
Q. In paragraph subparagraph C, the answer to
number 8, you say, "For the airplane banners, the
town filed a motion for sanction -- a motion to
sanction plaintiff and his attorneys in 2014CA004474
as well as to enter in a prior restraint against
further speech." Do you know what that refers to?
A. If you let me read it I can tell you.
Q. Okay.
A. Yes. This I think was about the time that
we were -- we ran one or more airplanes, and I think
probably some sissy wrote this up and tried to wine
to the court.
Q.
Wrote
what up?
Wrote
what?
A.
That
whatever
it says
here, motion to
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sanction plaintiff and his attorneys.
Q. Okay, do you know what the outcome of that
Q. Okay.
A. But I'm not sure.
Q. Okay. You would agree with me though, that
for any motion that's filed in court to be granted,
the judge has to rule on it, correct?
A. Unless the appellate court decides
otherwise.
Q. Okay, so some either the trial judge or the
appellate court has to adjudicate the matter?
A. Well, or the Supreme Court or the federal
z
courts.
Q. Right. So before a motion can be granted,
some court has to act upon it; is that correct?
A. To my knowledge, yes. Bear in mind I am not
a lawyer now.
Q. Subparagraph 5 references Bar complaints, a
UPI, complaint and letters to the Board of Bar
Examiners for plaintiff's son Jonathan, correct?
A. I can't find paragraph 15. Where would it
be?
Q. It's just below subparagraph C, there is a
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MR. O'BOYLE: It's a D, for clarity.
A. You didn't make a mistake, did you?
Q. I did. We are all human, Mr. O'Boyle.
A. I thought you were superior to me.
Q. I know, it's easy to assume that, but
subparagraph D, which references the Bar complaints,
UPI, complaint and letters to the Board of Bar
Examiners for the plaintiff's son Jonathan, correct?
A. Yes.
Q. And your son Jonathan is here, I guess, on
some limited appearance for you today?
A. He is here and I'm not sure of the technical
aspects. All I know is you said that the rule said
one thing and he said the rules say another, and I'm
assuming you were once again incorrect.
Q. He is appearing in some fashion as your
attorney, correct?
A. He is preparing -- he is appearing in some
fashion I guess in a legal sense. What that legal
sense is I really don't know, except to say that you
made a statement early on, he made a statement early
on, he is still here, it appears you were incorrect.
Q. And he is admitted to the Florida Bar,
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A. Pardon?
Q. He is admitted to the Florida Bar, correct?
A. I'm -- I have no reason to believe he is
not.
M
Q. Do you know that to be true or not?
A. I have never been to the Florida Bar, so I
don't know what it's like over there.
Q. And he is admitted in other states to
practice law, is he not?
A. You really should ask him. I don't have the
subtleties of where he is admitted, what he is
admitted, what conditions there are, what he had to
go through. You should ask him.
Q. Okay.
MR. O'BOYLE: Do you need any clarification
on the Bar in the Southern District of Florida
or --
MR. GILL: I don't need any clarification, I
just wanted to know if you your father knows, and
he references you in here, so I just asked a
question about his knowledge.
MR. O'BOYLE: I wanted to know if you wanted
to short circuit it and get to the ultimate facts.
MR. GILL: No, I don't. I wanted to know
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what your father knows.
Q. Do you know when he graduated from law
school?
A. What?
Q. Do you know when he graduated from law
school?
A. Which one?
Q. For his JD.
A. Drexell University.
Q. Do you know what year that was?
A. No.
Q. Was it before these Bar complaints, the UPL
complaint and the letters to the Board of Bar
Examiners that you reference here were sent?
A. Of course.
Q. When these were sent, he was already
admitted to practice law in another state, correct?
A. You have to ask.
Q. You don't know?
A. Well, I mean, I know from my point of view,
I don't know from a legal point of view, and that's
what you are looking for, and I don't want you to say
that I said something which is untrue or
inappropriate.
I know he went to Drexell University. To
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the best of my knowledge, he is a member of the
Pennsylvania bar, he is a member of the New Jersey
bar, he is a member of the Florida Bar, no thanks to
this guy at the end who tried to make him a felon.
Q. Okay, and to the best of your knowledge was
he already admitted to the New Jersey and
Pennsylvania Bar before these Bar complaints, UPI,
complaint and the letters were sent?
A. I don't know what letters you are talking
about.
Q. They are the letters that are referenced in
subparagraph D on page 7 and B.
A. D?
Q. Yes.
A. Okay, I will look at it right now. Okay,
what's your question?
Q. To the best of your knowledge, was he
already admitted to practice in Pennsylvania and New
Jersey before those Bar complaints and letters were
sent?
A. Of course. There is no stinkers up there.
Q. In subparagraph F you reference being asked
by Town Manager Thrasher, with a police officer
standing by, whether you were filming a conversation.
Can you explain that event?
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A. What's your question?
Q. Can you provide any more detail, other than
what's provided in subparagraph F, regarding what
happened at that time?
A. Well, I was in the town hall. I was
engaging in First Amendment activity. I was asked by
the town manager. There was no police officer
standing by that I can recall. There may have been,
but I don't recall. And by the way, it's all on tape
if you want to look.
Whether he was causing a public conversation
to be -- let's see here. Plaintiff was asked whether
he was causing public conversation to be recorded.
The obvious intonation was that plaintiff would be
arrested if he admitted so under the wiretapping
statute. What's your question?
Q. Okay, why were you in town hall in September
2014?
A. Um, I don't know. Why did you eat steak on
January 9?
Q. Was it a town meeting?
A. It would be easy enough for you to find out
by looking at the town meetings. I don't recall.
Q. Okay, so you don't recall. Do you have an
independent recollection of this event?
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A. I do.
Q. Okay, is there anything other than what you
read in the answer that you remember?
A. I remember that someone other than me was
recording. Thrasher got in his face strong and asked
if he was being recorded, and he was pressing -- when
I say pressing, his face kept coming closer and more
angry at this individual, and I grabbed the camera
from him and I put the camera facing Mr. Thrasher,
and he came up and he put his nose and his nose hairs
all over the camera. I had to clean those nose hairs
off of the camera afterwards. I didn't like that.
Q. Did you file a lawsuit over that?
A. I think we did, yes.
Q. And that's been adjudicated, correct?
A. No.
Q. Do you know if the court found that that
lawsuit was frivolous?
A. Is that on appeal?
Q. I don't think anymore it's on appeal.
A. Well, then, I can't answer you.
Q. Paragraph G references the RICO complaint,
correct?
A. Well, I see the word "RICO" in there, if
that's your question.
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Q.
Okay, and it also
references
a June 2, 2014
letter
and a March 26, 2015
letter?
A.
I see it in there,
if that's
your question.
Q.
Is this the letter
that you
are referring
A. There is no way I could know it. There is
no way I can know without juxtaposing the official
record of the Town of Gulf Stream.
Q. Okay, so you don't know if that is the June
2, 2014 letter that is referenced in subparagraph G?
A. It sure looks like it, but I don't want to
commit to it with -- based on your word.
MR. GILL: I would like that as the next
exhibit, and then we have another one.
(Defendant's Exhibit 5 was marked for
identification.)
(Defendant's Exhibit 6 was marked for
identification.)
Q. Is this the March 26 letter that you
referenced in your answer?
A. Once again, it looks like it, but without
juxtaposing it, I don't know how I could possibly say
that it is, but it certainly looks like it.
Q. When you spoke to the media regarding the
graphics you painted on your house, did you get in
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touch with the media or did they contact you?
A. When I spoke to the who?
Q. You spoke to the media I believe you said,
or you said you were interviewed?
A. I thought you said VDF. When I spoke to the
media, they contacted me.
Q. Had you in the past been interviewed by the
local media regarding, you know, certain First
Amendment activities you engaged in?
A. I can't think of any.
Q. Were you interviewed in connection with
banners you flew about the State Attorney?
A. Was I what?
Q. Were you ever interviewed by the media
regarding any banners you flew critical of the State
Attorney?
A. You have to say it for me one more time
slowly.
Q. Okay. Were you ever interviewed by the
media regarding any airplane banners you have flown
that were critical of the Palm Beach State Attorney?
A. I don't think so.
Q. Mr. O'Boyle, I want to now ask you some
questions now about the answer to interrogatory 3 in
Exhibit 2.
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A. Is this the one that starts off, "With
respect to each item"?
Q. Yes.
A. Okay, I have it.
Q. On page 2, the first sentence refers to
11$74,000 in fees and costs in connection with this
action." Do you see that?
A. Nope, still reading.
Q. Okay, take your time. Let me know when you
are finished.
A. Okay, I have read it.
Q. On page 2, the first sentence, which refers
to $74,000 in fees and costs in connection with this
action" --
A. Uh-hum.
Q. -- were you referring to Mr. DeSouza's fees?
A. I'm sorry?
Q. Are you referring in that sentence to
Mr. DeSouza's legal fees?
A. I don't know.
Q. Okay, what are you referring to with that
$74,000 in fees and costs?
A. $74,000 in fees.
Q. What fees and costs are they?
A. I did not know that I had to parse them. I
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thought we just had to give an amount, and that's
what we did. If you ask me to parse them, I can't
help you.
Q. You can or can't?
A. Can't.
Q. Okay, the second sentence on that page
refers to $608,000, 608,000 in defense of the town's
federal RICO action, state court counterclaims. Is
that merely for your defense of those claims or is
that globally for other parties?
A. To the best of my knowledge, it's for my
defense of the claims. As a matter of fact, I am
virtually certain.
Q. Okay, so not for any other parties that were
part of the RICO, just for you?
A. No, you weren't included.
Q. For example, was Jonathan O'Boyle included
in that?
r_��or m
Q. Okay.
A. Of course, you have Chris O'Hare.
Q. Was Chris O'Hare included in that?
A. No.
Q. And the next, I think it's the fourth
sentence, refers to 35,000 in fees and costs for
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Culver Smith representation of plaintiff in
connection with the plaintiff's motion for sanctions
in case 2014CA4474. Do you know what motion for
sanctions that's referring to?
A. Plaintiff also incurred approximately 35,000
in fees and costs for Culver Smith's representing in
connection with Gulf Stream's motion. Okay, what's
your question?
Q. Do you know what motion for sanctions that's
referring to?
A. No.
Q. Do you know if that lawsuit is still
on-going?
A. What lawsuit?
Q. The one that you reference in your answer
A. I see. The answer is I don't really know,
but I am sure you can look at that very easily.
Q. A little over halfway down that page you
state the plaintiff also believes that Gulf Stream's
retaliatory conduct in smearing of plaintiff's name
in the community has caused plaintiff substantial
reputational and business damage in an amount no less
than $250,000. Do you see that?
A. I do.
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Q. What business damage are you referring to?
A. I think socially and business -wise they
destroyed me and I think $250,000 is a slap in the
face.
Q. So in this lawsuit you are seeking money for
damages to your business?
A. I am seeking money for damages to my
business and damages to my personal life.
Q. Okay, you have previously objected to
providing information regarding your income. I think
if you are seeking business damages I am entitled to
that information.
A. You can make whatever entitlements you want.
I think what I am saying is this is on-going. If you
want to check my business records, and there is only
140 entities, so it wouldn't take you that long, if
you want to check them for the next six or seven
years, I invite you.
Q. Okay, so you are claiming that your entities
have been damaged because of the town's conduct?
A. I'm -- you are saying what?
Q. I just want to be clear. You are claiming
the town's conduct has damaged those business
entities?
A. The township has damaged those business
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entities, and let me just say one other thing, which
I don't think I said right and I don't think you are
clear on. You can't examine nothing. As an example,
if the business entities are nothing, how can you
examine nothing? Can you answer me?
Q. How are you going to establish that your
business has been damaged?
A. Get an expert.
Q. Okay, how did you come up with the $250,000
A. I can't answer you. I think it's way, way,
way, way, way too low.
Q. Later on in that paragraph you referenced
commercial real estate deals and contracts that you
have likely lost?
A. Okay.
Q. Can you identify any specific commercial
real estate deals and contracts you have lost as a
result of the town's alleged conduct?
A. I don't think -- I think you got it wrong.
I don't think you are grasping. When you lose a
deal, they don't say to you, "By the way, we are
going to take this deal away from you because good
'ole Bob Sweetapple filed a RICO suit." No, they
just say we won't deal with him.
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9W
Q. If I wanted to look at documents or figures
that would show me how your business damage -- your
business has been damaged because of the town's
conduct, what should I look at?
A. You should look at whatever our expert
provides.
Q. Nothing beyond what your expert provides?
A. I don't know what else you have, unless it's
magic.
Q. Looking at Exhibit 1, which is your other
answers to interrogatories.
A. Okay.
Q. Looking at question 2.
A. Okay.
Q. Do you maintain that objection regarding
relevance, the fact that you are claiming business
damages?
A. It has no relevance.
Q. Why do you think it has no relevance?
A. Because I know it has no relevance.
Q. Okay, what facts are you basing that
conclusion on?
A. My 46 years in business.
Q. Okay, what about that makes it not relevant
to your claim that you have lost some business
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59
damages or commercial real estate contacts because of
the town's conduct?
A. You say here you are requesting
information -- plaintiff objects to -- I am going now
to the answer, of course, to this interrogatory as
requesting information is not relevant to any party's
claim or defense.
You want to know what the gross income for
each year for the period from January 1, 2010 through
the current date. Now, you only want six years. I
don't even know if we keep our records six years, but
let's just, for the sake of this discussion, say we
do keep our records six years. Tell me what gross
income is going to get you. Tell me.
Q. Again, it's your deposition.
A. It won't get you anything.
Q. Okay, what would I need to look at then?
A. Pardon?
Q. What would I need to look at then?
A. Look at our expert's report and you will
see, and there is no way in hell that you could look
at gross income and determine income. None. Zero.
Q. I don't want income, I want to know what
damages you have allegedly had to your business
because of the town's conduct.
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A. I have answered you.
Q. Who is your expert?
A. I don't know that we have decided yet.
Maybe Obama.
Q. With respect to damage to your reputation
and being, I think you say you were a pariah in your
own community. You would agree that some of your
conduct could have caused that also, could it have
not?
A. No.
Q. All the public records compliance and
lawsuits?
A. I am entitled, as a matter of right under
the Florida Constitution, to get as many public
records as I choose. The people who made a big deal
out of it are Mr. Sweetapple by filing that piece of
shit that he admits is a piece of shit, the mayor,
Mr. Thrasher. So they are the ones who have made
myself, and I'm going to say Mr. O'Hare to a degree,
a pariah in the community.
I have never had anyone walk up to me and
say, "Gee, the actions you took in exercising your
Constitutional rights were absolutely horrible." I
have never had anybody walk up to me and say, "You,
enforcing your Constitutional rights, is absolutely
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horrible," except for the handful of groupies that
hang at city hall, the commissioners and their hacks.
Q. Isn't it like your business deals, nobody is
going go come up and hit you on the shoulder and say
you did that; isn't that right?
A. Pretty much.
Q. Didn't they speak when they voted in the
last election?
A. No, I voted -- I did very well, extremely
Q. Compared to what?
A. Well, I'll tell you compared to what. We
had a meeting, myself George Elmore, Tom Lodonnie and
Joan, I can't think of her last name, the mayor at
the time, and she said to me I would not get three
votes. I told her, "Then I won't get three votes."
The election came, and if you look at the
other five and you bundle them together and divide it
by five and then at what I got, that's pretty close.
I didn't win, but that was okay, I won an election.
After 21 years, an election. America we live in. An
election. That's what I wanted.
Q. Mr. O'Boyle, I don't think I have any
further questions at this time for you.
A. I'm saddened.
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Q. I'm sure we will get to do this again.
A. You are a good guy. I appreciate it.
MR. GILL: It is 12:48.
MR. SWEETAPPLE: Take a break for lunch?
MR. GILL: Do you want to break for lunch?
MR. O'BOYLE: I'm fine for that.
THE WITNESS: Goldstein, how much longer
have you got?
MR. GOLDSTEIN: It is really depending on
your answers. I would probably say a couple of
hours, two or three hours.
THE WITNESS: You really think it will take
that long?
MR. GOLDSTEIN: We'll see.
THE WITNESS: If you want to go an extra
one, I'll just make a phone call and we can go to
3.
MR. GOLDSTEIN: To where?
THE WITNESS: 3.
MR. GOLDSTEIN: 3:00 or three hours?
THE WITNESS: I'm joking.
MR. GILL: What time do you want to come
back?
THE WITNESS: I don't know, what time is it?
MR. GILL: 12:48.
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THE WITNESS: Do you want to come back at
2:00, is that good, or earlier?
MR. O'BOYLE: Whatever you guys want.
MR. GILL: We'll say and hour, so 10 to 2.
(Luncheon recess at 12:48 p.m.)
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AFTERNOON SESSION
1:43 p.m.
MARTIN E. O'BOYLE,
having been previously duly sworn, resumed and
testified further as follows:
CROSS-EXAMINATION
a
Q. Good morning or good afternoon, Mr. O'Boyle.
My name is Josh Goldstein. I represent the defendant
Robert Sweetapple. I have got some questions to ask
you. Some of them are follow-up to some of the
things you testified to previously when Mr. Gill was
asking you questions. I am trying to refresh your
memory.
Towards the end, before we broke for lunch,
you had testified that nobody has ever come up to you
and said or criticized you for your exercising of
your First Amendment rights, correct; do you recall
testifying to that?
A. Well, generally stated, I would say yes.
The First Amendment rights are just ever so broad.
Frankly, I'm not a lawyer, so I don't know where they
begin and where they end, but no one has come up to
me and said to me we are angry with you because of
thus and so. I have never had that happen. It's
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Martin O'Boyle
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more of let's just walk on the opposite side of the
street, it's him, because the mighty Mayor Morgan
says that he is a bad guy and he is bankrupting the
town.
Q. So no one has ever personally said to you,
"You know, we don't like the fact that you are doing
all these public records requests"?
A. Well, Mr. Sweetapple certainly said that,
but I don't know what that means. The mayor
certainly said it. Mr. Ganger, who is a witness in
this case, he certainly said it.
Now, when I say they said it, they may not
have come up to me and said it, they may have said it
to others, they may not have said it in those exact
words, but generally stated, I was ostracized.
Q. That's the your personal feeling, that you
felt like you were ostracized?
A. No, I think it was a matter of fact.
Q. Okay, what evidence do you have to support
that fact?
A. What I just told you and more.
Q. Okay, well, tell me what else you have.
A. You know, as I sit here today, it's very,
very difficult for me to give you the entire litany
of years of communications, conversations, dates,
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Martin O'Boyle
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speeches, letters. It's very hard for me to do that.
All I can tell you, unless if I think of something,
of course, I'll alert you immediately, but what I
have told you I think is generally what I am telling
you.
M -
It doesn't -- you don't have to necessarily
say the words to say the meaning.
Q. So whatever you just testified is best to
your knowledge presently what you believe supports
you, your feeling that you were ostracized?
A. I would say that whatever I just testified
to is demonstrative that I was ostracized, but I
think with a little bit of time I can certainly
enhance those responses, and may be able to during
this deposition, and I think I may have even done it
with Mr. Gill.
Q. Now, you said, you also testified that you
can't recall back to the time or history. How long
would you say this dispute has been going on with the
Town of Gulf Stream?
A. What's been going on?
Q. Well, you have been having a dispute with --
you said that comments made by the town made you feel
ostracized. So how long has, would you say has your
dispute with the Town of Gulf Stream been going on,
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Martin O'Boyle
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because you said there is a long history of speeches
and statements and conversations?
A. Which dispute?
Q. In general, your general dispute with the
Town of Gulf Stream?
A. Well, there is more than one dispute.
Q. Well, your issues with the Town of Gulf
Stream started somewhere, correct?
Let's backtrack. Let's strike that.
A. Sure.
Q. When did you move to the Town of Gulf
Stream?
A. 1981.
Q. In 1961 was the home in the Town of Gulf
Stream tc be your permanent residence or is it a
winter home?
A. Well, I'm not sure that I made that
declaration in 1981, but I believe it was to be my
permanent residence, and indeed it has been for 35
years.
Q. So it's fair to say since 1981 your home in
Gulf Stream has been where you primarily reside the
majority of the time?
A. That's where I am domiciled.
Q. Now, you said you have had multiple disputes
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Martin O'Boyle
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96,
with the Town of Gulf Stream. When do you recall
your first dispute?
A. I don't think I said I had multiple disputes
with the Town of Gulf Stream.
Q. Okay, you have had multiple issues with the
Town of Gulf Stream?
A. I don't think I said I had multiple issues.
Q. I'm pretty sure you said disputes, but when
was the first time you had a dispute with the Town of
Gulf Stream?
A. When I went to redo my house in 19 -- not
19, 2012 or 113, in that area. It may have even been
'll, but I think it's more like 112 or 113.
Q. So 2012 or 113. And what -- the issues with
redoing your house, what issues arose there?
A. My house was an 180s model and it's a big
house, and it needed to be transformed, so I hired
the best people, if not in the United States,
certainly in the area, and we formed a team and we
came up with an absolutely beautiful plan, and the
mayor, who was a woman at the time, I can't think of
her -- Joan, I can't think of her last name, she said
that the plan was massing. I had been doing this for
46 years and I had never heard the term massing. So
I didn't realize, I was a little surprised that an
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Martin O'Boyle
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alcohol salesman would know more than me after 46
years of building.
But anyway, it is what it is, and it was
pretty clear that she was going to turn it down,
which, frankly, from a professional point of view,
and just to give you an idea of my team, I had Pete
DeLeo, who has a graduate degree from MIT; Bob
Currie, who is a Harvard architect; Duane King, who
has 30 years experience in design; me, I have 46
years in design and building and development, and so
forth, and she overrode all four of us. Amazing.
So what I said is, "I don't know what you
are going to do here, but I have a funny feeling what
you are going to do, and should you decide to deny
me, I am going to remodel my house nonetheless in
accordance with the First Amendment of the United
States Constitution, and I will guarantee you won't
like it," and they voted to deny me, and then I went
ahead and I remodeled my house in accordance with the
First Amendment of the United States Constitution.
Q. Did they deny the entire project or just
part of the project?
A. I wouldn't even know how to answer that
question.
Q. Now, you testified previously about painting
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Martin O'Boyle
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a Shrek and a donkey on the side of your house?
A. Yes.
Q. Is that what you mean by remodeling your
house pursuant to the First Amendment?
A. It certainly is.
Q. So your first real dispute was when you
decided to paint -- after they denied you, you
decided to paint the side of your house with Shrek
and the donkey?
A. That wasn't a dispute, it was a promise.
Q. Okay, so if you made a promise that if you
deny me, I was going to do X?
A. Yes.
Q. And X was the painting of Shrek and the
donkey --
A. Yes.
Q. -- on side of your house?
A. Yes.
Q. You also said that you posted signs out in
front of your house calling commissioners thugs?
A. I don't think I said that.
Q. My notes reflect it.
A. I don't care what your notes reflect. I
don't think I said it.
Q. Did you in fact put a sign out in front of
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Martin O'Boyle
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your house calling the commissioner thugs?
A. No.
Q. Okay, so you didn't put a sign with pictures
of a Ku Klux Klan hood painted with the words,
"Commissioner Thug"?
A. You are talking now about the wall of my
house. There was not a Ku Klux Klan hood as you
might call it. I don't know what you were thinking,
but it was not, it was not that.
Q. What would you call it?
A. It did say "Commissioner Thug" and it said,
"Satire." And by the way, I didn't authorize that to
be put up, but nonetheless, I wasn't home.
Q. At the same point in time did you start
filing public records requests on the Town of Gulf
Stream in 2013?
A. I started filing public records requests on
or about the time that I painted Tweedle Dee and
Tweedle Dum.
Q. And that was in 2013?
A. I can't say that. It's when I painted
Tweedle Dee and Tweedle Dum.
Q. Do you have a rough idea as to when you
painted Tweedle Dee and Tweedle Dum on the side of
your house?
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A. It would have been after they denied the
approval of my home and before the settlement.
Q. So after 2013 -- so you were denied in 2013,
correct?
n�01rem
Q. I believe that's what you just testified to.
A. No. I didn't.
Q. Somewhere between 2012 and 2013?
A. That's a difference, 2013 versus 2012 and
2013, and I also said it could have been 2011. So
please, please, if you are going to quote me, do it
right.
Q. I was giving you the benefit of the last
date possible.
A. I would appreciate if you wouldn't do that
going forward.
Q. That's fine. So sometime between 2011 and
what time, when was the settlement?
A. Sometime between 2011 and 2013.
Q. Okay, so sometime between 2012 and 2013 you
started sending public records requests to the town?
A. I think that's right.
Q. Okay, and prior to that time period had you
ever sent any public records requests to the town?
A. Before then I had never even been to the
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Martin O'Boyle
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town hall. I wouldn't even know where it was.
Q. So would it be fair to say then that the
denial of the plans to remodel your house was what
prompted you to send, start sending public records
requests to the Town of Gulf Stream?
A. I don't think it's -- it brings about that
clarity, that much clarity. I started sending
records requests to the Gulf -- Town of Gulf Stream
because I thought it was appropriate that I do so.
Q. So starting sometime between 2011 and 113,
you decided it was appropriate to do so?
A. I thought it was appropriate to -- whatever
ones I sent, I thought it was appropriate to do so.
Q. And why didn't you feel that you needed to
send public records requests between 1981 and 2011?
A. Because, A, I didn't know what a public
records request was and, B, I didn't even know where
city hall was.
Q. So you are saying between 1981 and 2011, you
didn't know what a public records request was?
A. That's right.
Q. Okay. Do you personally own any other homes
or own an entity that owns any other homes?
A. Where is this relevant?
MR. O'BOYLE: Mr. Goldstein, you are
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Martin O'Boyle
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inquiring into the intent of the records request,
which, as you know, is completely inappropriate.
MR. GOLDSTEIN: All right, for starters, you
can object on form, you can object on privilege.
MR. O'BOYLE: How about if I objected as
privileged?
MR. GOLDSTEIN: That he -- whether or not he
owns another home, that is objected on privilege?
MR. O'BOYLE: No, no, no, whether,
whether --
MR. GOLDSTEIN: I'm not going into --
MR. O'BOYLE: What his intentions were.
MR. GOLDSTEIN: There is no intention. I
asked him if he owned another home, so I am not
sure what the intention objection is. I'm not
inquiring as to any intention. I asked him when
he started filing records. That's all I asked,
timeframe.
He then testified that he didn't know when
the records -- when records were -- what public
records requests were from 1981 to 2011.
I moved on to another question, asking him
if he personally or as an owner of an entity, a
member of an entity owns any other homes. So.
A. Okay, I am not going to answer that
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Martin O'Boyle
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Q. Do you own a home in Longport, New Jersey?
A. No, I do not.
Q. Is there an entity of which you are a member
or shareholder of in Longport, New Jersey?
A. I'm not going to answer that question.
Q. What is the basis for you not answering that
question?
A. I am just not answering it. It is not
relevant and I am not going to answer it. This is a
case about a slander suit in Florida, and what it has
to do with an entity that owns a property in
Longport, New Jersey is beyond me. I'm not answering
it. Move on, counsel.
Q. I am able or capable of inquiring into the
evidence that I believe is relevant to this case or
leads to discovery of admissible evidence. You have
put things forth and testified earlier that the town
has made you a pariah because of your filing of
public records pursuits. I am inquiring as to
whether or not you moved, and I believe my question
is relevant to that. And in fact, you have deposed
individuals in the Town of Longport, New Jersey in
this case.
A. I'm not going to answer the question.
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76
Q. Moreover, I would say that relevance is not
even a standard to object to in a deposition.
A. I'm sorry?
Q. That relevance is not a proper objection in
a deposition.
A. I'm pro se. I am doing the best I can.
Q. You have counsel here who has "entered his
limited appearance" based upon his own statements for
this deposition.
A. I am pro se. I am doing the best I can.
MR. GOLDSTEIN: So then I would move to
strike any objection as raised by Mr. Jonathan
O'Boyle.
Q. Have you ever filed suit against the Town of
Longport, New Jersey?
A. I am not going to answer that question.
Q. The basis for your objecting?
A. It is we are here on a slander suit with the
Town of Gulf Stream.
Q. I am fully aware of what the suit is,
Mr. O'Boyle.
A. Do you want me to finish or not?
Q. You have raised issues about your damages to
your reputation, have you not?
A. I have answered you. Let's move on.
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77
Q. Fine, I'll ask. Have you asserted that your
reputation has been damaged?
A. I have answered that question.
Q. Okay, you have testified that prior to 2011
or between 1981 and 2011 you didn't know what a
public records request is; is that correct?
A. That is correct.
Q. This would go directly, at the very least,
towards your impeachment.
A. That's not true. Let's move on.
Q. Mr. O'Boyle, did you not send records
requests to the Town of Longport, New Jersey and then
file suit against them back in 2008?
A. No.
Q. So at no point in time you have never filed
a public records requests to the Town of Gulf
Stream -- Longport, New Jersey?
A. I have answered. That's the end.
Q. Okay, are they known as something else in
New Jersey, particularly under OPRA or OPRO?
A. What about them?
Q. Are those what public records requests are
referred to in New Jersey?
A. What's it stand for?
Q. I'm not familiar with the law in New Jersey.
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Martin O'Boyle
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My understanding is that the short name or acronym
for them is called OPRO or OPRA.
A. What does it stand for, can you tell me?
Q. Again, I am not here to answer your
questions.
A. Okay. Well.
Q. You never made any type of request for
documents to the Town of Longport, New Jersey?
A. I have made requests for documents in the
Town of Longport akin to I have made requests for
documents in at least 1,000 towns in the United
States of America.
Q. At least?
A. At least.
Q. Would that also include -- when did you
start making records requests to the Town of
ow
Longport?
A. I am not going to answer that question.
Q. I guess we will be back here, Mr. O'Boyle.
A. Pardon?
Q. I guess we will be back here.
A. Is that a question?
Q. No, it's a statement based upon your refusal
to answer questions. We will just let the court
decide and we will come back.
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79
Here, I have the answer for you. OPRA, Open
Public Records Act. Part of the New Jersey statute.
Do you know how many OPRA requests between 2007 and
2008 you filed to the Town of Longport?
A. I don't.
Q. Do you recall whether or not your filing of
Open Public Records Act requests to the Town of
Longport came after you were cited for zoning,
planning and zoning violations in the Town of
Longport?
A. I would say that it hit both sides of that
date.
Q. What hit both sides of the date?
A. You asked me if I made any requests based on
this date, right?
Q. No, I asked if you ever made -- if your
requests came after you were cited for zoning
violations.
A. Okay, and this is the date I was cited for
zoning violations, as you would say it, and some came
on this side and some came on this side. Is that
clear enough for you?
Q. So you are saying that prior to you made
requests and after you made requests?
A. That's my recollection.
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Q. Did you ever -- with relation to your filing
of Open Public Records Act cases, did you also file a
case for slander against another resident in the Town
of Longport?
A. I did.
Q. Was that individual Peter Isen?
A. Yes, sir.
Q. And do you recall the basis of why you filed
the suit against him for slander?
A. Yes. He called me the enemy of the people
of Longport.
Q. And do you know why he called you the enemy
of the people of Longport?
A. Yes. He said that -- I don't want to put
words in his mouth.
Q. What is your opinion in why he said it?
A. Because he is a creep.
Q. So your feeling is the only reason he said
it was because he was a creep?
A. I think he is a creep, yes.
Q. It had nothing to do with your Open Public
Records Act requests that you had been serving on the
Town of Longport?
A. I don't know why somebody in the world,
somebody would call you the enemy of the people for
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Martin O'Boyle
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exercising your Constitutional rights. Maybe you
would, Mr. Goldstein, but I am not going to do it,
and I don't know of anybody with a reasonable mind
that would do it.
Q. That's a matter of your opinion, correct?
A. Pardon?
Q. That's a matter of your opinion, correct?
A. I said what I said.
Q. Do you recall ever serving any public
records requests on the State's Attorney's Office of
Palm Beach County?
A. I do.
Q. Do you recall when those were served?
A. I don't. I shouldn't say I don't. If I had
to guess, in 2007, 2008. It wasn't last night.
Q. So to the best of your recollection, it was
2007 or 2008?
A. Yes.
Q. At that point in time were they called
public records requests in Florida?
A. Before I answer that, what does this have to
do with a slander suit?
Q. I'm not here to answer your questions.
A. Okay, I am not going to answer that
question.
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M
MR. O'BOYLE: Can you give a proffer for the
record?
MR. GOLDSTEIN: Is he pro se --
THE WITNESS: Yes.
MR. GOLDSTEIN: -- or are you representing
him?
THE WITNESS: Yes.
MR. GILL: It is one or the other, because
he started to say he is pro se.
A. I'm pro se. Can you give a proffer for the
record?
Q. Who is proffering?
A. You.
Q. I am not proffering.
A. Okay.
Q. If they were in fact called public records
requests at the time when you made the request on the
State's Attorney's Office, would it then go to show,
would you agree that your testimony previously that
you said you didn't know what public records requests
prior to 2011 was inaccurate?
A. It is not what you asked me.
Q. No, it was what your testimony was.
A. No, it wasn't.
Q. Your testimony was prior to 2000 -- prior to
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12011, you didn't know what a public records request
I was.
A. And that was what I answered and it stands.
Q. And then I asked you if you had testified
whether or not you sent public records requests to
the State's Attorney's Office for Palm Beach County.
A. Well, if 2008 was the right date, then I
would have sent them to the Palm Beach County office.
If it would have been 2011 or later, I wouldn't have
known. So if I erred, I apologize.
Q. Do you recall whether or not you had a
dispute with the State's Attorney's Office prior to
sending public records requests?
A. Yes, I do.
Q. And did you have a dispute with the State's
Attorney's Office prior to sending public records
requests?
A. I don't think so.
Q. That's the best of your recollection here
today, correct?
A. Yes. What was your question again? Let me
just double-check.
Q. Whether or not you had a dispute with the
State's Attorney's Office prior to sending public
records requests.
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M
A. Well, I had a dispute with the State
Attorney's Office. I don't remember when that
dispute was. I thought it was earlier than 2011. It
could very well be that it was after 2011. I don't
know.
Q. Okay, but my question was whether or not the
timing as to when you sent records requests was after
the dispute arose or prior to.
A. I don't see what this has to do with this
suit. I wish it did. If you could explain it to me
you would find me much, much more cooperative, but it
sounds to me like you are on a fishing expedition,
and I am not going to go along with it.
Q. So you are refusing to answer the question?
A. I am not going to answer any other
questions, except as they have to do with this
particular litigation.
Q. Okay, but my deposition is not limited by
that. I can ask you background information, I can
ask you -- there is no limitation, no protective
order with respect to your deposition here today.
A. I understand.
Q. So if you are refusing to answer, then we
can take it up with the judge.
A. I understand.
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Q. These questions are particularly relevant.
They go directly to some of the things that you are
seeking, some of the things that you have set forth
in your complaint.
A. I understand.
Q. That's fine. We will take it up with the
You testified earlier that you flew banners
in Palm Beach County. Two or three of them were --
mentioned my client, Mr. Sweetapple; is that correct?
A. I think so.
Q. Do you recall what the banners where my
client's name was mentioned, what they said?
A. I don't, but I still, again, am struggling
to understand the relevance.
Q. Relevance is not a proper objection or
standard in this, so you need to answer my question.
A. I have answered.
Q. My understanding is you don't recall what
the banner said?
A. Um, although I don't think it's appropriate
that I answer, I will, and the answer is no, I do
not.
Q. When Mr. Gill was asking you questions, you
testified that you had authorized the banner to be
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flown; do you recall that?
A. I do.
Q. Okay, besides authorizing the banner to be
flown, do you know who actually authored the message
that was set, that was on the banner that was flown?
A. I would say -- I would say, generally
stated, the buck stops here.
Q. All right. So in terms of interpreting your
answer, it is your testimony that you are the person
who authored what was on the banner?
A. Generally stated.
Q. Do you recall whether or not one of the
banners that you flew over Palm Beach County stated
"Sweet apples are best boiled in oil"?
A. First of all, I didn't fly them.
Q. Well, authorized somebody to fly them?
A. That's a big difference. The answer is I
believe that's correct.
Q. Do you recall authorizing a plane to fly a
banner around Palm Beach County which stated that
"Sweet apples are rotten apples, right JF"?
A. I don't remember that, but I -- I could see
where that would fit into one that I would fly, yes.
Q. And one that you would have authored?
A. I can't say that.
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Q. Okay, do you recall whether or not you
authorized a banner be flown around Palm Beach County
stating that "Bob Sweetapple lays smelly farts"?
A. I do.
Q. I saw a smile on your face. Do you
particularly like that one?
A. No, no, I was looking at the smile on your
face and I thought you must have particularly liked
it.
Q. Do you recall whether or not you
incorporated a business known as Sweet Apple Sober
House?
A. I think my office may have done it, and I
think you got the name wrong, but I think, generally
stated, there was an entity that was formed with --
with maybe similar names to that.
Q. Sweet Apples Sober Houses, does that sound
familiar?
A. Just as familiar as the one before that.
Q. Do you recall when your office incorporated
that entity?
A. Pardon?
Q. Do you recall when your office incorporated
Actually, I misled you. That was
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shortly before I had made a records request to the
town about sober houses and then there was a
deposition where I brought Mr. Sweetapple's trailer
on the beach, you know the one with all the dents,
where you won't let people walk on the beach, you
know, that one, and he was whining about the name,
which I thought was a cute name because it was not
Sweetapple, it was Sweet Apple.
MR. GOLDSTEIN: Mark this as 7. It is a
printout from the Sunbiz website for Sweet Apple
Sober Houses.
(Defendant's Exhibit 7 was marked for
identification.)
Q. Does this document help refresh your
recollection as to when Sweet Apple Sober Houses was
incorporated?
A. If it is true and correct, the answer is
yes.
I -
Q. Do you have any reason to believe this?
A. I have no reason to believe it is and I have
no reason to believe it isn't.
Q. Were you the sole manager of the entity
known as Sweet Apples Sober Houses?
A. I couldn't answer you.
Q. Based upon this document, does it reflect
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that you were the sole manager?
A. No.
Q. Okay, is there any other manager listed on
the document or printout?
A. No, but I'm not sure that that means that
you are the sole manager.
Q. Was there a particular reason you decided to
incorporate this entity, Sweet Apple Sober Houses?
A. I was going to make it Joshua Goldstein
Sober Houses, but I like Sweet Apple Sober Houses
Fair to say you didn't know me in 2014,
A. Yes, but I still like that name Joshua
Goldstein.
Q. So again, other than you liking the name
Sweet Apple, was there any other basis behind you
incorporating this entity known as Sweet Apple Sober
Houses?
A. None.
Q. So there was nothing intended to retaliate
or harass against Mr. Sweetapple, was there?
A. How is that a retaliation? I don't even
think even think your question warrants an answer.
It's a nonsensical question.
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M
Q. It is certainly your opinion --
A. Thank you.
Q. -- but I am entitled to my answer.
A. Thank you. What's your question?
Q. The question was was this done in
retaliation to Mr. Sweetapple's representation of the
Town of Gulf Stream?
A. Oh, absolutely not, otherwise I would have
done Joanne O'Connor's Sweet Houses or Sober Houses,
LLC or Skip Randolph or Hudson Gill, but I didn't.
Sweet Apple is a good name.
Q. Just Sweet Apple?
A. Pardon me?
Q. Just Sweet Apple?
A. Out of the group that I knew, yes.
Q. You testified previously that you also
authorized the flying of banners regarding Jones
Foster, correct?
A. Yes. I think it was one, but it may have
been more. You will tell me.
Q. And those banners had nothing to do with
their representation of the Town of Gulf Stream,
correct?
A. I don't know what banners you are talking
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Q. You testified previously that you flew one
to three banners, one to three or four banners --
authorized to fly over Palm Beach County, which
discussed or made reference to Jones Foster.
A. Well, I'm not sure that's what I said, but
if you show me or tell me, I'll give you an answer.
Q. So did you authorize a banner to be flown
that stated "Jones Foster's clients, check your
bills"?
A. Yes. Or maybe not those exact words, but
the theme, yes.
Q. And it had nothing to do with -- the
authorizing flying that banner had nothing to do with
Jones Foster's representation of the Town of Gulf
Stream?
A. It had something to do with being a --
alerting the public that they ought to look at their
bills.
Q. Do you recall authorizing the flying of a
banner that said, "JF, don't drink and drive, we'll
be watching"?
A. Yes, I did.
Q. That had nothing do with the fact that they
were representing the Town of Gulf Stream in suits in
which you were adverse?
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A. Absolutely not. It had nothing to do with
money. JF, who knows what JF is? It may be Judson
Film. Nobody knows what it is.
And driving under the influence, I'm not
sure if that's something that you do on a regular
basis, I certainly don't do that on a regular basis,
and to say to someone else don't you do it I think is
a good thing to do and I think that it's a
responsible thing to do and I think that the people
ought to applaud you for doing it.
Q. So you are saying it was a public service
announcement?
A. Yes. Yes. I wish I could have put it in
those short a words. That's why you are a great
lawyer and I'm just a hamburger salesman.
Q. Right. Did you authorize flying a banner
that said, "Jones Foster, your bills make me puke"?
A. I don't think I said that in a banner. I
may have. I know that I stood before the town
commission and I said, "Your bills make me puke."
And the only reason I said that is because their
bills make me puke, as do Mr. Sweetapple's. The two
of them are raping, hear me, raping this town.
Q. Mr. Sweetapple's representation of the town
is purely related to a cause of action that you filed
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against the town, correct?
A. I have no idea. Ask him.
Q. I'm here to know what you know today, not
what my client knows.
A. How would I possibly know? He goes behind
doors with the commissioners and they make a
decision, not me. I was never invited, nor was I
invited for Thanksgiving dinner.
Q. Were you personally offended that you
weren't invited for Thanksgiving dinner?
A. No, no, no, no. No, I would rather go out
on Halloween and get some candy.
Q. Do you have any knowledge as to the number
of public records requests you have actually -- you
have personally served on the Town of Gulf Stream?
A. No.
Q. You don't keep track?
A. No. I do, but I can tell you this. They
put up a board saying how many were, I don't know,
how many were filed, I guess, by Mr. O'Hare and me,
and they put up a list of aliases, which was an
absolute damn lie. I don't know who was behind it.
The only one I could suspect, Mr. Sweetapple was
behind it, but it was a damn lie.
And I tried to fix it, but in that town,
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seen.
Q. The town is the closest thing to Syria, is
that what you said?
A. Yes, the closest thing to Syria that I have
ever seen is what I said.
Q. Have you ever been to Syria?
A. Have I ever been to Syria? No, I saw it on
TV, on CNN. Have you ever watched it?
Q. So you don't know -- so you make a reference
to the town being the closest thing to a country you
have never been to?
A. You don't -- in today's world you don't have
to be there to see it, and if you watch a little more
TV, particularly the news, particularly where they
are showing the towns overseas, I don't think you
would ask that question.
Q. Now can you go back to answering my
question?
A. It all depends what it was.
Q. The question was that you are basing your
reference to the town being the closest thing to
Syria that you have ever seen without actually having
ever been to Syria; is that correct?
A. Can you say it again? Why don't we have him
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Q. Sure.
MR. GOLDSTEIN: Can you read it back?
(A portion of the record was read by the
reporter.)
A. That's correct.
Q. Let me show you what I am going to mark as
Exhibit 8. This is your responses to
Mr. Sweetapple's first set of interrogatories.
(Defendant's Exhibit 8 was marked for
identification.)
M
A. Okay.
Q. Take a look at the last page. Is that your
signature on the last page?
A. I'm sorry, yes, it is.
Q. Is that a true and accurate copy of your
responses to Mr. Sweetapple's first set of
interrogatories?
A. I can't say that for sure without
juxtaposing it against our file copy, but it
certainly looks like it.
Q. Do you have any reason to believe that this
isn't a true and accurate copy of your responsive --
A. I just answered you.
Q. Why don't we go to your response to number 3.
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A. What is that?
Q. To number 3. There is no page numbers, so I
can't direct you to the page numbers --
A. Okay.
Q. -- but I am going to go with being the third
A. Okay.
Q. Are you done looking at it?
Let's take the first part of your answer.
It states that, "In July of 2014, Sweetapple said to
Mark Hanna," the attorney representing Chris O'Hare,
"that Mr. O'Hare must dismiss his lawsuits against
the Town of Gulf Stream or else he would be named in
a RICO lawsuit against plaintiff." Were you present
when these statements were made?
A. No.
Q. How did you come to find out that those
statements were allegedly made?
A. I don't remember who told me, and there was
a bit of complexity to it, and you sort of have to
put the parts together.
First of all, Mr. O'Hare was screwing
Mr. Sweetapple's wife, as he well knows. Mr. O'Hare,
I think they were brought into a meeting, although I
wasn't there, so I don't know, but Mr. O'Hare, my
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understanding was, was unwilling to dismiss this
lawsuit, and that Mr. Sweetapple wanted to finish up
with Mr. O'Hare, get a confidentiality, I guess to
protect his wife from it getting on the street of
her, you know what, and then to have Mr. O'Hare be on
the side of the town, and I guess they wanted to pump
him full of lies to say that you can join the
ostracization crowd.
So I think it's threefold. I think it's the
screwing of his wife, I think it's getting rid of the
litigation, and I think it's trying to put me to
sleep. G -d bless him.
MR. GOLDSTEIN: Move to strike everything
but the first sentence there. The rest was
nonresponsive.
A. Well, you asked me to read it, but okay.
Q. No, I asked you who you heard it from, not
the rest of the commentary, Mr. O'Boyle.
A. Okay.
Q. It would go a lot smoother if you answer the
questions that are asked.
A. Okay.
Q. Then in the next answer it states that,
"Plaintiff has been informed as follows: On April
25, 2014 Sweetapple said in an out of the court
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Martin O'Boyle
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statement that he was going to go after and
investigate plaintiff's son in response to multiple
lawsuits that plaintiff had filed against Gulf
Stream."
Do you know who was there present to hear
those statements?
A. Mark Hanna, Joanne O'Connor, and
Mr. Sweetapple was threatening to come after me by
destroying my son, and that did not sit well for me,
and as of today it doesn't sit well with me either.
Q. And after -- after -- when did you hear
about those statements?
A. I think shortly, when I say shortly, a day,
two, a week. I mean, it was shortly, it wasn't a
long period of time, but it was -- the mosaic was
clear where Mr. Sweetapple was going and I
understand.
x
Q. And who told you about the statements?
A. You know, I don't remember. There was a
slew of people who apparently knew about them, and it
could have been Ms. O'Connor.
Q. So you think Ms. O'Connor told you?
A. I just said it could have been Ms. O'Connor.
Q. Could it have been anyone else?
A. Yes, it could have been someone else. I
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guess it could have been Mr. Rader, I guess it could
have been Mr. O'Hare, I guess it could have been one
of the lawyers from my son's office.
Q. Were they present? But they weren't present
for this discussion?
A. I can't -- you asked me a question. I have
answered your question. If you don't like it, I
don't know what to tell you.
Q. I'm just asking how they would have known.
A. I gave you what I can tell you.
Q. So you don't know who conveyed the message
to anybody who was outside of the three people you
named that you knew were present?
A. Well, what I told you was my first guess was
Joanne O'Connor, because that's who Mr. Sweetapple
was sitting there bragging, saying that he is going
to get my son. He wouldn't have the guts to say it
MR. SWEETAPPLE: You weren't there. I never
said that.
THE WITNESS: Who is talking to you?
MR. SWEETAPPLE: You are looking straight at
me, so I am answering you.
MR. GOLDSTEIN: Bob.
A. That's what I figured.
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Q. Sorry, did you have something to say?
A. No, no, no, no, no. No, I was just doing
some addition. I said that's what I figured.
(Defendant's Exhibit 9 was marked for
identification.)
Q. This is Exhibit 9.
A. We are going to have to take about ten
minutes at 3 p.m., okay?
Q. Okay.
A. Thank you.
Q. What is marked as Exhibit 9 is a copy of the
Second Amended Complaint. Do you recognize the
document?
A. Again, like the others, it appears to be the
Second Amended Complaint, but I haven't gone through
it. I'm reasonably comfortable it's the right
document.
Q. Okay. That's got markings on the top
showing that it was the docket entry and that it was
filed?
A. It has markings on the top. Where they came
from, I don't know, but again, I think we can both
pretty much rely on it.
Q. Why don't we go to page 6, looking at
paragraph 32. Are you ready?
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Q. In paragraph 32, you allege in the Second
Amended Complaint, for example, on several occasions
in the last four months, Sweetapple has spoken to
friends, colleagues, business associates and
attorneys for plaintiff to convey the same message to
each: Plaintiff is a criminal. He has violated the
federal and Florida RICO acts.
Who are the friends, colleagues, business
associates and attorneys that Mr. Sweetapple has
spoken to?
A. After we take his deposition, I'll be able
to enhance that. In the meantime, I can tell you
Gerald Richman, I can tell you Joel Chandler, I can
tell you the commissioners in Gulf Stream, I can tell
you Joel, Jo, Joanne -- I can't think of her last
name, Jo O'Connor, and I think a myriad of friends
and colleagues. At least that's my understanding.
Q. I need -- I would like to know the names of
the friends and colleagues that you believe these
statements were made to.
A. I believe one of them was Reeve Bright.
Q. How do you spell that?
A. B -R -I -G -H -T. I believe another one may have
been Bob Currie.
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Q. I'm sorry, how do you spell the last name?
A. C -U -R -R -I -E, and I believe several of the
townspeople, but I would, I would have to take
testimony from them.
Q. What, townspeople?
A. Uh-hum.
Q. And who are the townspeople that you believe
that the statements were made to that you need to
take testimony of?
A. Patsy Randolph, William Thrasher. I can't
think of the older woman that makes it to town hall.
Rita Taylor. That's all I can think of as I sit
here, but as I -- if I think of additional as I am
sitting here, I will certainly alert you.
Q. The three individuals you just named, Patsy
Randolph, William Thrasher and Rita Taylor, am I
correct that they are all employees of the Town of
Gulf Stream?
A. You are incorrect.
Q. So who is not an employee of the Town of
Gulf Stream?
A. Patsy Randolph, and if she is, it is recent
and I don't know about it.
Q. Who told you that these statements were
made?
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A. A myriad of people.
Q. Okay, provide me with the names of those
people.
A. I don't think I can do that. It's more or
less in sort of a passing kind of way. It's not
there is a center stage with a microscope and 100
people in the audience. It's more of a, "What in the
world is going on with this RICO suit? What are you
talking about? Well, Bob Sweetapple says that you
are a criminal, you are going to go to jail." I know
he said that about Chris O'Hare and myself, and my
response is, "Don't listen to him."
But it was those kind of people who would
come up to me. Sometimes people that I didn't even
know, where they might be down at the beach with one
of my children and then they would ask, "You are
Marty O'Boyle? You are the guy involved in
racketeering? No, I'm not the guy involved with
racketeering. Where did you hear that? Well, there
is a lawyer named Sweetapple or a lawyer named" -- I
don't think they ever mentioned Jones or whatever.
That's about what I could tell you.
Q. So just random people on the beach came up
to you and said, you know, Sweetapple told them this?
A. What I just told you is what I just told
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you. If you want to play it back, you can ask
whatever questions.
Q. I heard what you just told me. I want the
record to be clear that these people came up to you
and said that Bob Sweetapple specifically told them
that you were a criminal.
A. Would you be kind enough to play that? Bob
Sweetapple specifically told them I was a criminal?
Q. That he told those people, that's what they
told you.
A. I said that's what you said they told me.
Q. I'm asking you a question.
A. And he is going to read it back and that
will be the answer.
Q. No, I want you to testify -- so the record
is clear, I am asking you to testify, not for the
court reporter to read it back, so the record is
clear, that these individuals came up to you on the
beach and said that Bob Sweetapple had a specific
conversation with them and said that you were -- and
told you, told them that you were a criminal.
A. I have answered your question. We will have
the court reporter read it back if you like and that
way you will see I answered your question, and if I
didn't answer your question --
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Q. It is a separate question, Mr. O'Boyle.
A. Sure.
105
Q. If you are refusing to answer the question,
that's fine, we can let the court decide.
A. I am not refusing at all. I am not refusing
at all. As a matter of fact, I want to answer it.
Q. So answer.
A. Well, let the court reporter --
Q. I am asking for you to answer it, not for
the court reporter to read it back.
A. Well, I can't answer a question in the
abstract.
Q. It's not in the abstract. I am asking
you -- you had just testified, and I heard your
testimony loud and clear, that random people that you
may not even have known came up to you and said that
this guy Sweetapple says that you are a criminal and
you violated RICO.
So did they specifically say that Bob
Sweetapple had a conversation with them and he said
to those people, "Oh, that O'Boyle guy, he is a
criminal and is violating RICO"?
A. Why don't we have the answer read back.
Q. It's a different question, Mr. O'Boyle. So
either you are going to answer or you are going to
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Martin O'Boyle
May 16, 2016
106
refuse to answer and we will let the court decide and
we can come back here and do it again.
A. We can come back any time you like. I am
willing to answer the question. I think I have. If
I haven't, I'm willing to do it. You obviously don't
want the court reporter to read the question back for
reasons that are clear to me, so let's move on.
Q. No, I want you to answer as to your
knowledge. It's a different question.
A. What's the question that's different?
Q. I asked if these individuals that came up to
you and spoke to you specifically said they had
conversations with Mr. Sweetapple, my client, and he
told them specifically in a face-to-face conversation
that you are a criminal and you violated the RICO
statute.
A. No.
Q. These conversations that these individuals,
that when they came up to you on the beach, was this
before or after the town had approved the filing of
the RICO claim?
A. You know, I don't know. I think
Mr. Sweetapple was going around town with his John
Hancock, not John Hancock, John -- who is the guy in
New England, with his bell, shaking it, and how me
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Martin O'Boyle
May 16, 2016
107
and Chris O'Hare are going to go to jail and the town
is going get all their money back, and guess who got
rich? The one and only Mr. Sweetapple.
Q. So do you have any --
A. Sucked their blood.
Q. Do you have any proof or have any evidence
or can you give me names of people who saw
Mr. Sweetapple running around town screaming to his
heart's content that you are a criminal and you
violated the RICO statute?
A. No.
A. When you say that in fact, I don't know what
that is.
Q. You just testified that you envisioned
Mr. Sweetapple running around town ringing his bell.
A. That's not what I said. Let's read it back.
I am sick of this. Now let's read it back and we are
going to -- if I have answered it, I have answered
it, and if not, you can ask a different question.
Q. I am asking a different question, but you
are not letting me finish asking my question. If you
do not interrupt me, I can finish asking my question.
A. Go ahead.
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Martin O'Boyle
May 16, 2016
Q. So I am just confirming that you have no
evidence that Mr. Sweetapple was running around town
telling everybody that you were a criminal and
violated the RICO statute.
THE WITNESS: Can you read that question
back, sir, the one that I was asking about?
MR. GOLDSTEIN: I'm not sure what question
he is asking about, but you can read back the
question I just asked.
THE WITNESS: You don't have to because I am
not going to answer it.
Q. So you are refusing to answer?
A. I just said I am not going to answer it, I
didn't say I am refusing.
Q. Who is Reeve Bright?
A. He is a -- he is my wife's friend's husband.
Q. Does he live in Gulf Stream?
A. Pardon?
Q. Does he live in Gulf Stream?
A. I don't think so, but I don't know where he
lives. I don't think it's Gulf Stream though.
Actually it's Delray.
Q. What did Mr. Bright tell you specifically
regarding the statements of Mr. Sweetapple?
A. You know, you are asking for sort of subtle
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Martin O'Boyle
May 16, 2016
conversations that you and I may have walking to
lunch, and when you ask -- if I asked you that two
years later, I think you would struggle to answer
that, I really do.
Reeve mentioned it to me and I think, I
109
think, if I am remembering right, I am just now
remembering, that at the Gulf Stream Bath and Tennis
it was a big issue, and as far as -- I wasn't there,
so I can only give you what I remember from a couple
of years back, which was incidental, and I think
it's, you are being very difficult to ask me to give
you precise answers from two years ago. If you can
tell me what you had for breakfast on February 9,
2014, I will give you your answer.
Q. I could tell you, but I am not going to.
So what did Reeve Bright say to you in your
passing conversation?
A. He generally stated that Sweetapple was
running around with the -- is it John Henry?
Somebody -- about RICO, racketeering, criminal and so
forth, and I believe that that was, that Reeve -- I
think I may have even been out of town. I believe
that Reeve was the first one who mentioned it to me.
As a matter of fact, to help you guys out a
little bit, you will need it, the Coastal Star, Reeve
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May 16, 2016
110
wrote an editorial, not mentioning names, pretty good
in theme. You ought to read it.
Q. About what?
A. About this entire episode, about this
entire, the RICO.
Q. Again, it is still not clear to me what
Reeve told you.
A. Well, I think I have done the best that I
possibly can. If it is not clear to you,
Mr. Goldstein, I apologize. If I can think of
something that will make the mosaic clear, I will
certainly pass it on to you.
Q. When did you have this discussion with
Reeve?
A. I don't know. It was either before or after
the RICO filing.
Q. Did Reeve tell you that he had specific
conversations with Mr. Sweetapple?
A. You know, I don't remember. I mean, I just
don't remember. It was kind of a flowing, easy-going
conversation. It was not a tense, heated
conversation.
Q.
What
did Bob Currie
tell you?
A.
Bob
-- and I'm going
to make
a suggestion.
That way
you
can stick right
with that
question. We
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Martin O'Boyle
May 16, 2016
111
have a 3:00 call which we alerted you to. It's 2:59
now. Do you mind if we step out?
Q. That will be fine.
(A recess was taken.)
Q. The question pending was who was Bob Currie.
A. Bob Currie is -- I guess you would say he is
an architect in Delray Beach.
Q. How do you know Mr. Currie?
A. How do I know him?
Q. Uh-hum.
A. He was the architect who represented me when
I went in for my house in whatever year it was.
Q. So sometime 2011, 2013?
A. In that area.
Q. What did Mr. Currie say to you about
Mr. Sweetapple's statements?
A. It was again more of -- I think your
perception and my perception, I think you are looking
for a steak dinner, I am looking for a hamburger.
I think your perception is much more rigid
than mine. It was just sort of a relaxing
conversation which, just to give you a theme, "What
in the world is going on over there? I heard that
you are being charged with racketeering. Somebody
told me that has a 20 year prison sentence."
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Martin O'Boyle
May 16, 2016
112
He said something else about the
racketeering, and I don't know, and he said to me, I
don't know if he mentioned Mr. Sweetapple by name,
but I said, "Bob, where would you get this? Where
are you coming up with this stuff?" And I think he
said, "The town's lawyer," and I guess that would be
Mr. Richman or Mr. Sweetapple. They were the two
that were working on that lawsuit.
Q. Do you know if Mr. Currie had specific
conversations with Mr. Sweetapple or Mr. Richman?
A. Again, it was a very light, loose, you know,
walking down the steps or walking down the street
conversation. It wasn't tense like, "Gee, did you
hear our best friend Fred has cancer of the brain?"
where you stop and you say, "Oh, my G -d," but it
wasn't in that league.
Q. How was, how did this conversation
transpire, was it by phone, was it in person?
A. It was in person.
Q. It was in person?
A. It was in person, yes.
Q. When did this conversation happen?
A. Somewhere before or after the filing of the
RICO action.
Q. If it was before, how soon before the
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Martin O'Boyle
May 16, 2016
113
A. I can't answer you.
Q. You said he is an architect in Delray Beach.
Does that mean he lives in Delray Beach?
A. I don't know.
Q. Or he works in Delray Beach?
A. I think he works all over the country.
Q. Where is his principal place of business?
A. Delray Beach.
Q. And where does he live?
A. I don't know.
Q. To your knowledge, has Mr. Currie ever
attended any Gulf Stream Commission meetings?
A. Yes.
Q. Other than the one to approve the
renovations to your house?
A. The answer is I have no firsthand knowledge,
but I believe the answer is yes.
Q. So it's possible that he was at a commission
meeting when this discussion came up?
A. It's possible he was at the Last Supper when
it came up. I don't know.
Q. Just so I am clear, Mr. Currie testified
that or may have mentioned the town's attorney may
have mentioned Mr. Richman's or Mr. Sweetapple's
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Martin O'Boyle
May 16, 2016
came up?
114
A. What you just said makes no sense.
Q. Did he specifically mention Mr. Sweetapple's
name when you were having a discussion regarding the
RICO suit with Mr. Currie?
A. I have already answered that for you.
Q. I am just trying to clarify; that is, you
don't recall if Mr. Sweetapple's name was
specifically mentioned; is that correct?
A. I have already answered that question.
Q. So you are refusing to answer just for
clarification so the record is clear?
A. No, I am refusing to answer more than once.
Q. Other than the one conversation you just
testified to with Mr. Currie, did you have any
further conversations with him regarding the RICO
suit?
A. I'm sorry?
Q. Did you have any further conversations with
Mr. Currie regarding the RICO suit other than the
conversations you just testified to?
A. Maybe. When I say maybe, I'm not sure if I
did or I didn't, but I know -- I'm just -- what was
your question again?
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Martin O'Boyle
May 16, 2016
115
Q. Other than the conversation you just
testified to with Mr. Currie, did you have any other
conversations with him regarding the RICO suit or the
allegations set forth in the RICO suit?
A. Well, I don't know what the allegations set
forth in the RICO suit are because I don't have it.
It's 50 some pages.
Q. I'm not asking you whether or not you know
what the allegations are, I am asking you if you had
any conversations with Mr. Currie in addition to what
you have already testified to regarding the RICO suit
or the allegations set forth in the RICO suit.
A. Well, I certainly didn't have any regarding
the allegations set forth in the RICO suit because
it's 50 pages and I didn't memorize it.
As far as the existence of the RICO suit,
maybe.
Q. Did you have any further conversations about
any statements that Mr. Currie had heard from
Mr. Sweetapple?
A. As I sit here I am hitting a wall. I can't
think of any.
Q. Would any further conversations have been in
writing, in person, phone, text message?
A. Well, if I don't remember any conversation
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Martin O'Boyle
May 16, 2016 116
or any communications --
Q. Well, you said maybe to a previous answer,
so I am asking in general, did you have any
additional conversations you may have had with
Mr. Currie regarding the RICO suit about
Mr. Sweetapple, would those have been in person, by
phone, email, text message?
A. To the extent that I -- the maybe becomes a
yes, then I would have, I guess, had some type of
communications. The fashion in which I had them I
don't know, but I don't think it was a text message
because I don't think Bob texts.
Q. Going back to your -- did you have any other
communications besides the one you testified earlier
with Reeve Bright regarding the RICO suit or
statements made by Mr. Sweetapple?
A. Maybe.
Q. As we sit here today, you are not aware of
any conversations?
A. No. Reeve wrote that editorial in the local
paper, the Coastal Star, and when I saw it -- I was
out of town, but when I came back in town somebody
brought it to my attention, and I don't remember who,
and I called Reeve, and I just don't remember whether
I spoke to him or I spoke to his son. I just don't
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Martin O'Boyle
May 16, 2016
Q. Who is Patsy Randolph?
A. She is one of the Morgan Brigade.
Q. I'm sorry, could you clarify what you mean
by the Morgan Brigade?
A. She is a groupie.
Q. She is a Mayor Morgan groupie, is that what
your testimony is?
A. Yes. Uh-huh.
Q. Why do you refer to Ms. Randolph as a Mayor
117
Morgan groupie?
A. Because she is a Mayor Morgan groupie.
Q. Okay, and what evidence do you have to
support the fact that you say she is a Mayor Morgan
groupie?
A. Because I watch -- watched her actions when
I am at the commission meetings or somewhere around
city hall, and I have seen groupies in my almost 50
years in this world, in the business world, and she
is a groupie.
Q. What do you mean by a groupie?
A. Well, I don't know how many more times I can
explain it to you, but I'll try my best.
Q. I think you have explained it once, but
please go ahead.
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Martin O'Boyle
May 16, 2016
118
A. Well, I will explain it 32 times if you
would like. A groupie is a person who wants to be
part of the in crowd, wants to be, wants to have
recognition, wants to be, wants to be there with the
in crowd. That would be the best explanation I think
that I could give you.
Q. And now, what did Ms. Randolph tell you?
A. Well, the thing that stands out the most,
which I don't think is what you are looking for, is
that she was saying to the commissioners that they
have to find a way to keep myself and Mr. O'Hare out
of the commission meetings, the nice woman that she
is.
I think it was right out the front door, not
the back door. Actually I think it may have even
been more than once, it may have even been inside the
building where she said we support this. These
racketeers, these criminals, these -- I forget how
she put it, ought to be -- these are my words now --
sort of taken off the street, and then I heard her
outside in the front vestibule of the building -- I
am just trying to think, it was -- I couldn't hear
the whole conversation, but it was sort of like,
something like these guys, and I think it may have
been, and I may be mistaken, but I think it may have
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Martin O'Boyle
May 16, 2016
119
been, we can probably look at the tapes, when
Mr. Sweetapple went up there and gave his speech, he
must have needed more money, and she said something
like, "We got to get rid of them, they are, you know,
nothing but a bunch -- you know, he and O'Hare, they
are nothing but a bunch of criminals," and so forth.
And it was not just her, it was other people I didn't
know. I don't know too many people in that town.
Q. So she never had any specific conversation
with you, directly with you, where she told you about
any statements Mr. Sweetapple said?
A. Well, I don't know about that, but I don't
recall any that she had directly with me regarding
the subject matter of being a criminal or being a
racketeer. I don't think she had any directly with
me.
Q. Okay, when do you recall Ms. Randolph
getting up and stating that you were a criminal or
racketeer?
A. Sometime between here and there.
Q. Can you give me a more specific timeframe as
to where here is, the date of here and the date of
there?
A. Well, we have been talking about Ill to 113
all day. It just changed ten seconds ago. So let's
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120
stick with 'll to 113, because that's the best dates
that I can give you, and you can certainly, you can
ask Mr. Sweetapple. Certainly he will give you
whatever dates you want, or you can ask the town and
you will get the precise dates.
Q. I want to know what your knowledge is and
the dates that you recall.
A. Well, we have been through this probably 40
times today.
Q. And we'll keep going through it.
A. Well, I have given you my answer and you can
take that answer and utilize it going forward.
Q. You said that it was after a speech that
Mr. Sweetapple gave?
A. I said what was after a speech?
Q. That Ms. Randolph's statements occurred
after a speech that Mr. Sweetapple gave?
A. No, that's not what I said.
Q. Okay, what did you say?
THE WITNESS: Can you play that back, sir?
Q. No, we can't play it back.
MR. GILL: I thought that's what you said
[..
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121
Mr. Sweetapple. 'He probably needed more money."'
A. Yeah, I think what I said was that I don't
remember exactly what she said and where she said it.
She said it once inside the council chamber and then
once out on the front vestibule with other people
that I didn't know, and she didn't mention
Mr. Sweetapple's name. Now, that's what I said.
Q. Okay.
A. The same thing I said before.
Q. Why didn't you sue her for defamation?
A. I might.
Q. I'm going back to I believe it's Exhibit 9,
the Second Amended Complaint. Actually let's go to
Mr. Thrasher. Who is Mr. Thrasher?
A. Who is Mr. Thrasher?
Q. Correct.
A. He is -- he purports to be the town manager.
Q. What conversations did you have with
Mr. Thrasher about Mr. Sweetapple's statements
regarding RICO violations?
A. I'm sorry, what was your question again?
Q. What conversations did you have with
Mr. Thrasher wherein he told you about statements
made by Mr. Sweetapple? By statements, I mean
specifically related to the alleged RICO violation or
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May 16, 2016
122
A. Well, I think that he said it from the dais,
and that would have been a general statement, and
then I think he made a more specific statement, but I
don't think he used Mr. Sweetapple's name, and that
would have been in the kitchen or directly out the
back door.
Q. When he made a statement from the dais, what
did he say?
A. I don't remember, except that they were
proceeding with -- they were talking about the RICO
action, and as a matter of fact, I think -- I think
they mentioned myself and Mr. O'Hare, and I think he
brought up a mounted board which showed a $5 million
pot, you lawyers must love that, of which I think it
was 2 million and -- out of the budget, 2 million in
like a bond or a loan or something like that, and
then 1 million with the Salvation Army lady out there
with the bell taking donations.
Q. Okay, what was this board reflecting?
A. Pardon?
Q. What was the purpose or what was the board
reflecting?
A. That they wanted to spend $5 million.
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May 16, 2016
123
That's the way I took it.
Q. So it was a budget meeting of the
commission?
A. I have no idea what it was.
Q. Were you present when this occurred?
A. I was, yes.
Q. Did you ask questions as to what it was?
A. No, it was pretty evident.
Q. It was evident to what it was?
A. Yes.
Q. But you just told me you had no idea what it
was.
A. I don't think that's what I said.
Q. What was the sign trying to depict or show
or evidence that Mr. Thrasher held up with the sign
showing $5 million and a breakdown of where it was
going?
A. Oh, I think what he was showing is that we
are proceeding with the RICO suit, which is
racketeering, which is criminal, and then what I
said, in case you weren't listening, it was out in
the kitchen and/or out the rear door.
Q. We will get to that. I am just dealing with
the first one.
A. Okay, I thought you were dealing with more.
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124
Q. No, just the first one.
A. Okay.
Q. When you said he was making the statement
from the diocese --
A. From the dais.
Q. -- From the dais. What did you mean by
that? I am clearly not as smart as you, so.
A. This is the table.
Q. So you were sitting at a table?
A. No, this is a table.
Q. Understood.
A. And where they sit up high, you know,
commissioners and legislators, that's called a dais.
Q. So it was clear it was at a commission
meeting then that he was making this statement or
report?
A. I can't imagine -- the answer is I don't
know, but I can't think of anything else that it
would have been.
Q. Now, the second statement he said, you said
he was in the kitchen. Is that in the town hall?
A. That would be -- well, it depends what you
call the town hall, but it was in the building where
Gulf Stream has its library, has its offices, has its
kitchen, has its accounting department, has its
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counsel chambers, and probably a few that I am
missing.
Q. Going back to the first statement on the
dais, where, do you recall when that was made or the
timeframe the statement was made?
A. We went through this now. I'm going to do
it one more time.
Q. I'm going to ask it every time.
A. Okay, and I'm not going to answer it any
125
more times.
Q. Okay.
A. Between 'll and 113 is the best date that I
can give you as I sit here today, and that is going
to be over and over and over again. If you want
specific dates, you have the sources in front of you,
I don't. If you ask me a specific date, I would be
more than happy, to the extent that I know it, to
provide you with that advice.
Q. Do you have any issues with memory from 2013
going forward?
A. I remember Mr. Sweetapple.
Q. That wasn't my question. My question was do
you have any issues with recalling things that
occurred after 2013?
A. Oh, I'm certain I do.
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126
Q. Okay, and is it a medical issue that you
have? Without getting into what the medical issue
is, is it a medical issue that affects your memory?
A. I would, I would tell you that I may not
understand or remember this gentleman's name next
week, so it does, it affects my memory. I can't tell
you, all I can tell you is in the last three years
I'm certain there are things that I have forgot or
mispronounced.
Q. Do you know when Mr. Sweetapple was hired by
the Town of Gulf Stream?
A. I think 2014.
Q. Does that help refresh your recollection as
to when maybe Mr. Thrasher had made these statements,
was there any discussion prior to Mr. Sweetapple --
strike that. We will move on.
A. Thank G -d.
Q. All right, now, the statement that you said
you heard Mr. Thrasher state either out the back door
or in the kitchen, what did you hear Mr. Thrasher
say?
A. It was something along the lines of
racketeer, racket, RICO, criminal. It wasn't -- I
wasn't, I didn't have my ear up against where he was,
it was more of a passing kind of, you know, you pick
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127
up a word, you pick up a word and so forth. So
that's what I picked up. I did not hear
Mr. Sweetapple's name at all.
Q. Okay. To the best of your recollection,
that was the same 2011-2013 time period?
A. What was the 2011?
Q. When the statement was made.
A. When that statement was made, I don't know
what time period it was, because I don't know how far
in advance they were planning this ill-conceived RICO
suit. I didn't know that the attorneys needed money
that bad.
Q. Do you recall Mr. Thrasher specifically
using the word criminal?
A. I wish I could tell you yes, but I'm just
not sure enough to say that.
Q. What about Ms. Rita Taylor?
A. What about her?
Q. Well, you testified she made statements to
you about Mr. Sweetapple's statements, so what did
Ms. Taylor tell you?
A. I don't recall me saying that.
Q. I have got her name written down.
A. Oh, I believe you have her name written
down. I remember saying her name because I couldn't
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remember her last name, so I remember saying it, but
I don't think that's what I said.
Q. That's where I got the names from, based
A. Well, let's mark it in the record and --
Q. Did Ms. Taylor ever tell you anything or say
anything, make any comments to you about statements
that Mr. Sweetapple made?
A. I don't know.
Q. Going back to what was previously marked as
Exhibit 7, which is your interrogatory responses,
particularly number 3, the last part of your response
states that, "Plaintiffs informed that Sweetapple
made statements on September 3, 2014 to Mark Hanna,
Lou Rader, an attorney representing Chris O'Hare, and
Chris O'Hare. Plaintiff has informed that Sweetapple
made the same statements in out-of-court statements
to other residents of Gulf Stream, the details of
such statements will be identified through discovery
in this matter."
Going back to the September 3, 2014
communications between Mr. Sweetapple, Mr. Hanna,
Rader and O'Hare, who advised you of the
conversations that occurred at the September 3, 2014
meeting?
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A. I'm not sure.
Q. To your knowledge, do you have any
recollection of whether or not you had any
conversations with Mr. Hanna?
A. Oh, I have had conversations with Mr. Hanna
129
for sure.
Q. Regarding the September 3, 2014 meeting?
A. Pardon?
Q. Regarding the statements that were allegedly
made on September 3, 2014?
A. I don't think I had any conversations with
Hanna, Rader, O'Hare, Sweetapple, Morgan, O'Connor,
any of them. The only thing that I know of is the
substance.
Q. How did you become aware of the substance of
the discussions of what transpired on September 3,
2014?
A. Well, somebody told me about the meeting and
they -- they opened my eyes because they had said
that Mr. O'Hare was, pardon the expression, screwing,
had screwed Mr. Sweetapple's wife, and they wanted
to -- they offered Mr. O'Hare to dismiss his case or
cases and they would leave him out of the RICO suit
and just come after me, and I think this was -- I
mean, I'm guessing, but I think this was all as a
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Martin O'Boyle
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result of Mr. Sweetapple did want on the street that
Mr. O'Hare was screwing his wife.
Q. Okay, and who told you about the meeting?
A. I don't know.
Q. Who told you that O'Hare was having
relations with Mr. Sweetapple's wife?
A. The same person who told me about the
meeting, I believe.
Q. Was that discussed at that meeting to your
knowledge?
130
A. I don't -- you know, I don't know. I'm
assuming it was, but I don't know.
Q. Again, just so I am clear, you don't recall
who told you what transpired at that meeting? And we
are referring to the September 3, 2014 meeting.
A. Well, I think that there was what was said
and what was not said, and I think the what was said
was you drop all your lawsuits and we won't charge
you with RICO, but that they were going to then
charge me with RICO, and I said -- what wasn't said I
think was the -- whatever sexually happened between
Mr. Sweetapple's wife and Mr. O'Hare.
Q. Again, where did you hear this information
from?
A. I don't know. A lot of people who I think
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131
knew about this, heard about it, and I don't know
whether it came from the town side, our side, I don't
know where it came from. All I remember is somebody
mentioned it to me and I just said, "Wow."
Q. So you just repeated that information
without having any knowledge or facts about the fact
that Mr. O'Hare had relations with Mr. Sweetapple's
wife?
A.
I
never
repeated it.
Q.
I
think
you stated it several times today,
A. Yes. We have a litigation privilege here,
Q. I'm not answering questions on legal issues,
Mr. O'Boyle.
A. That's quite all right.
Q. Wasn't this meeting that occurred on
September 3, 2014 some or part of the primary
allegations regarding the statements made by
Mr. Sweetapple that were set forth in the Second
Amended Complaint?
A. Well, you went too fast for me and you
went -- you glossed over everything. If you go slow
and show me, I will answer your question.
Q. I am asking you isn't it true that the
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September 3, 2014 meeting that you became aware of
was the primary emphasis behind your filing of the
complaint in this matter as evidenced by the
paragraphs 33 and 34?
A. Okay, what is your question?
Q. That the September 3, 2014 meeting was the
primary basis for your slander claims against
Mr. Sweetapple as set forth in paragraphs 33 and 34
of the complaint.
A. Just -- so I didn't hear. The September
3 --
132
Q. 2014 meeting that you referred to in your
interrogatory responses --
A. Right.
Q. -- is the same meeting you are referring to
in paragraphs 33 and 34 of the Second Amended
Complaint?
A. Well, do you know where it is in my
interrogatories? If not, I'm going to have to find
it.
Q. Yes. We have been discussing the same
interrogatory responses.
A. I understand. My question is do you know
where it is?
Q. Page 3, response to request number 3.
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A. Is this the one with no pages?
Q. No page numbers.
A. So it's number 3?
133
Q. It's response to request number 3.
A. Okay.
Q. And you wrote, your response is, "Plaintiff
is informed that Sweetapple made all these
statements" -- and at this point I am referring to
your first amended complaint -- "on September 3, 2014
to Mark Hanna, Lou Rader, an attorney representing
Chris O'Hare and Chris O'Hare."
A. Okay. I don't know how good I will do, but
I tried.
Q. I am waiting for your answer, Mr. O'Boyle.
A. You will have to tell me the question.
MR. GOLDSTEIN: Can you read back the
question, please.
THE WITNESS: No, don't read it back, let
him tell me.
Q. I am asking him to read back the question.
It is my deposition, Mr. O'Boyle, you can't instruct
the court reporter as to whether or not he should
read it back or not.
A. I apologize.
MR. GOLDSTEIN: I am asking the court
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134
reporter to read back the question.
THE WITNESS: I apologize.
(A portion of the record was read by the
reporter.)
A. May I impose upon you to do that one more
time? I'm not grasping it.
Q. It's fine. I am not going to make the court
reporter read it back again.
The question is whether or not the September
3, 2014 meeting is the meeting that you based your,
the statements that you based your complaint on, your
Second Amended Complaint, specifically on paragraphs
33 and 34, where you are referring to where
Mr. Sweetapple allegedly made defamatory statements
about you.
A. Well, I can't tell you whether it's what I
based my complaint on unless I read my entire
complaint.
Q. I am going specifically -- I directed you to
two paragraphs, Mr. O'Boyle.
A. Right, but you asked me a question.
Q. With respect to the claims against
Mr. Sweetapple.
A. Okay. And is it in this entire Second
Amended Complaint? Is 33 and 34 the only claims
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135
Q. I am referring you to those paragraphs as to
the places where you believe that Mr. Sweetapple made
statements regarding defaming you regarding RICO and
said you were a criminal.
A. And I didn't answer that, is that what you
are saying?
Q. That's correct, Mr. O'Boyle.
A. Okay, can you say it again?
MR. GOLDSTEIN: I'm going to repeat my
question again, Mr. Reporter.
Q. The question pending, at the September 3
meeting, where Mr. Hanna, Rader and O'Hare were
present, was a meeting that you are referring to in
your complaint; is that correct?
A. I see it's on -- I see it in an
interrogatory, I don't see it in the complaint, but I
will look for it.
Q. Paragraph 34, the last sentence:
"Sweetapple further called a confidential meeting
with this individual whereupon information I believe
Sweetapple further defamed plaintiff in making
additional RICO allegations and additional threats."
A. And where is September 3, where is that at?
Q. Doesn't specifically state September 3. I
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Martin O'Boyle
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am asking you to confirm whether or not that
September 3 meeting is the meeting that you are
referring to.
136
A. I can't tell you for sure.
Q. Did you in fact file a lawsuit against the
town as well as Mr. Sweetapple regarding a
confidential settlement meeting between the town and
Mr. O'Hare?
A. You know, I don't think so, but I may have.
Q. Have you ever had any conversations with
Mr. Hanna regarding the statements made -- alleged
statements made by Mr. Sweetapple?
A. I was at Mr. Hanna's deposition, if that's
what you mean.
Q. No, I am asking about conversations that you
specifically had between you and Mr. Hanna regarding
statements made by Mr. Sweetapple.
A. Maybe.
Q. And if you did in fact have these
conversations, would they have been in writing, would
they have been e-mail, phone conversation, in person?
A. Probably in person, if I did.
Q. Has Mr. Hanna ever represented you as
counsel, as your attorney?
A. I don't think so.
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Q. Has Mr. Hanna ever represented any entities
to which you are a member or owner as its attorney?
A. I don't think so.
Q. To your knowledge, have you personally or
any of your entities ever paid Mr. Hanna's legal
fees?
A. Pardon?
Q. Have you personally or any of your entities
ever paid Mr. Hanna's legal fees?
A. What does this have to do with the slander
137
Q. Again, your relevance objection is not -- it
serves no merit. I can inquire as to this. It goes
directly to Mr. Hanna's veracity to tell the truth if
you really must know, but it's relevant, it doesn't
matter.
A. Well, the answer is no, but I still don't
think it's an appropriate question.
Q. Okay. Have you ever had any conversations
with Mr. Lou Rader regarding any of the statements
made by Mr. Sweetapple?
A. I don't think so.
Q. You don't think so or you don't recall?
A. I don't recall.
Q. What about Mr. O'Hare, have you ever had any
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138
conversations with Mr. O'Hare about any alleged
statements by Mr. Sweetapple?
A. I believe I did, but I -- I believe I did.
Q. Do you recall when you had these
conversations?
A. I think somewhere between 'll and 114 now.
Whatever. It was before or after the RICO filing.
Q. In your conversations with Mr. O'Hare, were
they over the phone, in person, was there any written
communications between you and Mr. O'Hare regarding
any statements made by Mr. Sweetapple?
A. It would have likely been over the phone or
in person.
Q. Do you guys ever correspond by e-mail, you
and Mr. O'Hare?
A. Once in a blue moon maybe.
Q. Do you ever correspond by text message?
A. Never.
Q. What did Mr. O'Hare tell you that
Mr. Sweetapple said?
A. That I was a criminal.
Q. He said specifically that Mr. Sweetapple
said, used those specific words, called you a
criminal?
A. I believe that's the craze -- I believe that
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that's correct. Is there a possibility it was
slightly askew of that, I guess the answer is yes,
but in theme it was pretty clear.
Q. Can you tell me, besides the people you
already named, can you provide me with the names of
any other residents of the Town of Gulf Stream that
Mr. Sweetapple made statements to or stated to that
you were a criminal?
A. I don't think more than what I have given
you, except with a little bit of time I'm sure
something will pop into my head, but I suggest to you
that from him, he was directly or indirectly, it's
town -wide.
Q. I'm sorry, what was the last part?
A. Town wide.
Q. No, I heard town -wide. The directly or
indirectly, what were you referring to?
A. Well, directly or indirectly.
Q. So the town members heard it indirectly or
directly?
A. I think that's right, yes.
Q. But you don't know where the town members
were when they heard the statements?
A. I'm smiling because I wasn't over their
house for dinner. I didn't give them a bath. I
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didn't wash their dishes. I didn't mow their lawn.
I don't know where they were.
Q. So they didn't tell you what they heard or
how they heard it?
A. That's not what you asked. What you asked
was where were they.
Q. Right. Well, I asked because they could
have been at a commission meeting, they could have
just seen the news.
A. Right.
Q. So you don't know if they actually
specifically heard any statements made by
Mr. Sweetapple, correct?
A. I would say they would have directly or
32
indirectly, yes.
Q. That wasn't what I asked. I asked whether
or not they specifically heard statements made by
Mr. Sweetapple.
A. I can't answer that question.
Q. And by heard indirectly or directly, they
could have heard indirectly or directly that the town
was filing a RICO suit or the RICO suit was in fact
filed, correct?
A. They could have heard that or they could
have heard that there are some racketeers in town and
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141
we are filing a RICO suit to burn their ass, which is
what the approach that Mr. Sweetapple took, because
if you would only see his fees (whistle), you will
understand where he is coming from.
Q. When did you become aware that this RICO
suit was being considered by the Town of Gulf Stream?
A. Considered? I can't answer that because
considered is such a vague, nebulous term.
Q. How many commission meetings would you say
you attend a year?
A. I don't know, but it would be easy enough to
go into their Website and it will tell you right on
the front cover.
Q. So if there was -- if you attended a town
commission meeting if there were discussions
regarding a decision or considering the decision of
whether or not to file a RICO suit, were you present?
A. Well, you ask a question with the broadest
of brushes. I'm considering punching you in the
mouth. Does that mean I am going to do it?
Q. I don't know.
A. I'm not, but I'm considering it. I'm
considering hitting my son in the head. I'm not
going to do it.
So when you say consider, I don't know what
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142
consider means. People consider a lot of things and
do nothing.
Q. Mr. O'Boyle, use the common language
definition of the term consider and please answer my
question. When did you become aware that the town
was considering filing a RICO suit?
MR. GOLDSTEIN: Let the record reflect it
appears that Mr. O'Boyle is looking up the word
consider.
Q. We'll go at it this way. We will rephrase
the question because Mr. O'Boyle is clearly having
difficulty with the term consider.
A. Please don't tell me what difficulty I am
having or not.
Q. I am asking you a question. I am asking you
a question, Mr. O'Boyle.
Mr. O'Boyle, when did the town first start
discussing -- when did you first become aware that
the town was discussing the filing of a RICO lawsuit?
A. I can't answer you.
Q. Is it that you can't answer because you
don't recall or you are refusing to answer?
A. Oh, no, it's because I can't recall. I'm
sorry.
Q. Do you recall whether or not you attended
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A. I do not.
Q. Do you recall whether or not you submitted a
letter to the commission for the October 10, 2014
meeting which you insisted be read to the town
commissioners?
A. Well, I don't know that I submitted a letter
and I don't know that I insisted as you say.
Q. Did you request at your behest that it be
read to the town commissioners?
A. That what be read?
Q. That a note or letter from you to the town
commission.
A. If I could see it I probably would be able
to help you.
Q. I'm asking if you recall doing it.
A. I have already answered that and I said I
don't recall.
Q. I believe this is 10, which is the minutes
from the October 10, 2014 meeting.
(Defendant's Exhibit 10 was marked for
identification.)
Q. Specifically I direct you to page 48 of
Exhibit 10.
A. Is there anything you would like me to do?
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144
Q. Does that refresh your recollection?
A. My recollection of what?
Q. As to whether or not he submitted a note to
the commission on October 10, 2014 meeting that you
requested be read to the commission.
A. Okay.
Q. Does that refresh your recollection as to
whether or not you submitted a note and requested it
be read to the town commission on October 10, 2014?
A. The answer is I did not submit a note.
Someone submitted it and suggested that I wanted it
read before the commission.
Q. Do you know who submitted the note?
A. You know, I don't.
Q. Did you authorize somebody to submit the
note?
A. I'm thinking the answer is yes.
Q. Did you draft the note?
A. I don't know.
Q. Is it possible that you dictated the note
for someone else to draft?
A. It is certainly possible.
Q. If you were to dictate the note, who would
you have dictated it to?
A. Whoever was available.
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Q. Someone at your office?
A. Or one of our offices.
Q. By our, what are you referring to?
A. By what?
Q. When you said one of our offices, what were
you referring to by our?
A. Well, we have -- Florida is not our only
office.
145
Q. Again, who are you referring to as our?
A. When it's a company, it's not an individual.
Q. I understand. I am asking what company or
companies you are referring to as our.
A. I am not going to answer that question.
Q. The basis for you refusing to answer the
question is what?
A. I am not going to answer the question. It
is not relevant. There is no reason that you should
know whether I have another office in Alaska. It has
nothing to do with a slander suit in Florida. And if
you think it does, I'm going to agree with you that
we should take it up with the judge.
Q. Mr. O'Boyle, I am just asking you follow-up
questions to your own testimony hours ago. So I am
asking for you to define where it was or what
entities that you are referring to, but if you don't
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Martin O'Boyle
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is
want to answer, that's fine, we can take it up with
the judge and move on.
Does the manner in which the note was read,
is that accurate, that you were -- I'll read it for
the record. "In connection with the proposed RICO
action, Mr. O'Boyle wished to provide the commission
with a warning that any such launch will be met with
an unfriendly response."
Do you recall authorizing or authoring that
or dictating a threat to the town or a warning that
if they file a RICO, you are going to go after them?
A. I think you have to read the entire entry in
context. I don't think you can do what you did.
Q. I am asking you a question about a specific
statement that was made in it.
A. But it's out of context. I think you have
to ask it in context.
Q. This is my deposition. You cannot dictate
to me how I am asking the questions, Mr. O'Boyle.
A. I agree with you.
Q. So therefore, I am asking you to answer my
question.
A. What was your question again?
Q. My question was do you recall either
dictating or authoring the warning and/or threat made
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to the Town of Gulf Stream that if they filed the
RICO suit, it will be met with an unfriendly
response?
147
A. Say it again.
Q. Did you author or dictate the paragraph that
I just read into the record?
A. Can you say it again, because when you read
it, you shortcut it.
Q. I am not asking the question again,
Mr. O'Boyle, I have asked it four times.
A. That's fine. Let's move on.
Q. So you are not going to answer the question?
A. I am if we get the questions correct.
Q. I have asked the question four times.
A. I understand. You have told me that. Now,
do you want to answer it -- ask it so that I
understand it, I will answer it. If you want.
Q. It is a simple question, Mr. O'Boyle.
A. If you want to ask it so that I understand
it, I will answer it. If you want to be obstinate,
you can be obstinate and I'm not going to answer it.
What's your pleasure?
Q. Quite frankly, my question was did you
author or dictate the warning or threat to the Town
of Gulf Stream that if they filed the RICO suit, it
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will be met with an unfriendly response?
A. And where is the word threat?
Q. I'm not asking a direct quote. I'm asking
based -- Mr. O'Boyle, I am not answering your
questions. Please answer my question.
A. Based on your question, I did not, I did
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Q. And your statement that you did not is
because the word threat is not in there?
A. You have asked me to answer a question. I
have answered it.
Q. I asked a follow-up question, Mr. O'Boyle.
Please answer the question.
A. What else -- I didn't catch what else may
not be in there. If you want to read it again, I
will mark specifically what else is not in there and
I will do it very quickly so we can get beyond this.
Q. Mr. O'Boyle, did you dictate or authorize or
author the quote that I previously read into the
record.
A. I can't tell you whether or not. I can't
tell you.
Q. Is it that you don't recall or you just
don't know?
A. Well, I don't know the genesis of this and I
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am not going to rely on the town, on their minutes.
Q. If you had authorized somebody to draft this
note for you, would that be something that's still in
your records, the actual note that was to be
submitted, or a copy of it?
A. Probably not, but I don't know. It would
certainly be in the town's records though, wouldn't
it?
Q. I am not asking whether or not it's in the
town's records, I am asking whether or not it would
be in your records.
A. Okay. And I have answered you.
Q. Do you further recall making the statement
that if the town was to proceed going forward in
filing the RICO action, it would likely result in
Gulf Stream's demise?
A. I remember something akin to that. Whether
it was in writing, whether it was a letter read,
whether it was me up at the podium, whether it was
Mr. O'Hare up at the podium or whether it was someone
else, I don't know.
I can't give you the satisfaction of saying
yes, that I did it and, yes, these are my exact
words, because I would not be telling you the truth,
because I just don't know. So that's probably what I
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can tell you.
Q. Can you tell me how your reputation in the
community has been damaged by the alleged statements
of Mr. Sweetapple?
A. I think I have been ostracized.
Q. In your opinion you have been ostracized?
A. Yes.
Q. Now, I believe you testified previously,
earlier, that you don't know a lot of people in the
town?
A. I don't.
Q. So how is it that you have been ostracized
in a town where you don't really know anybody?
A. I didn't say I didn't know anybody. I said
I didn't know that many people, remember?
Q. That's fine.
A. I told it to you a minute ago.
Q. That's fine.
A. Do you want to start again?
Q. Excuse me, I don't appreciate your pointing
your finger at me.
A. And I don't appreciate you putting words in
my mouth.
Q.
I am
not putting words in
your mouth.
A.
You
certainly are. Let's
go.
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Q. I am asking you questions, Mr. O'Boyle --
A. Let's go.
Q. -- and you refuse to answer them.
A. Let's go.
Q. That's fine. My question was, again, if you
are going to answer it, how is it that you are
ostracized in a town that you don't know a lot of
people?
A. Although I don't know a lot of people, that
doesn't mean a lot of people don't know about people,
so that's how.
Q. Are you able to differentiate the damages
between what Mr. O'Boyle said versus the filing of
the RICO suit?
A. I have no idea what you just asked.
Q. Sure. Are you able to differentiate, to
tell me the difference between the damages you
incurred based upon the alleged statements of
Mr. Sweetapple and the alleged damages you received
as a result of the filing of the RICO suit?
A. I still don't understand.
Q. Can you tell me the difference, if you are
able to determine the difference between damages that
you may have received as a result of Mr. Sweetapple's
alleged statements versus damages that you may have
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A. You are saying perceived versus what?
Q. No, I'm asking you to differentiate --
A. Between?
152
Q. -- between the statements of Mr. Sweetapple
and the actual filing of the RICO suit?
A. You didn't use the word perceived?
Q. I didn't use the word perceived at all.
A. Okay.
Q. I said differentiate.
A. I hate to ask you this, but can you say it
again?
Q. Are you able to differentiate between your
damages resulting from Mr. Sweetapple's statements
and the actual filing of the RICO suit?
A. I think they are one in the same.
Q. What are your specific damages related to
the alleged statements of Mr. Sweetapple and the
filing of the RICO suit?
A. This is a question that was asked of me
earlier, either by you or by Mr. Gill, and the answer
is as soon as we get our expert report, we will be
glad to supply it to you.
Q. I think it's a different question, but
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can you provide me what the damages are for
Mr. Sweetapple's alleged statements?
A. You mean to break it apart?
Q. What are your alleged damages with respect
to the statements made by Mr. Sweetapple?
A. I am not sure I can do that. I think you
have to wait for our expert, but please don't lose
sight that this is slander per se.
Q. I'm fully aware. I am asking you for you to
tell me what your damages are.
A. And I have answered you.
THE WITNESS: You look lonely.
MR. GILL: No, I am enjoying the good
company.
Q. I'm close to done, but I want to take a five
minute break.
A. Well, why don't we get done.
Q. Well, I would like to take a five minute
break so I can use the restroom.
MR. GILL: I am going to have some recross.
Not much, but a little.
THE WITNESS: You are going to try to double
cross me?
MR. GILL: Recross. Recross.
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154
(Defendant's Exhibit 11 was marked for
identification.)
Q. I show you what has been marked as Exhibit 11.
A. Okay.
Q. Do you recognize this document?
A. It has my handwriting.
Q. Did you write this?
A. It looks like it.
Q. Is this a document you listed out for
damages with respect to this claim?
A. I don't think so.
Q. So you don't think this has to do with your
alleged damages in this claim?
A. I said I don't think so.
Q. So why would you have written this out?
A. I am going to assert the attorney-client
privilege.
Q. Okay, is there a reason you produced this
document in discovery?
A. It must have been erroneously produced.
Q. Are you asserting that the document is a
privileged correspondence or privileged communication
with your lawyer?
A. I am a pro se litigant and this is a
document that shouldn't be here, and what label you
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Martin O'Boyle
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put on it I can't respond to, I don't have the
education or the experience, except to say to the
best of my knowledge it's not relevant to this.
Q. So you would agree that you are not seeking
damages in this matter with respect to any emotional
distress or mental anguish, frustration,
sleeplessness?
155
MR. O'BOYLE: Let me just interject here.
Are you reading from a privileged document?
MR. GOLDSTEIN: I am reading from a document
that was produced.
MR. O'BOYLE: I think that we need to bring
this matter up with the judge then. I mean, you
have something that has been claimed as
privileged.
MR. GOLDSTEIN: It was produced by his
counsel, so.
MR. O'BOYLE: And errors aren't made?
MR. GOLDSTEIN: So are you asking me, so you
are saying that it needs to be returned to you.
Send me something in writing and it will be
returned to you if it was produced in error.
Q. I can go back. Are you asserting any
damages in respect to this claim for emotional
distress, sleeplessness, any other type of intangible
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Martin O'Boyle
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A. Well, as it applies to this document, the
one that is entitled "Damages," that's a privileged
document.
Q. That's fine. I am not referring to that
156
document anymore.
A. As it applies to the damages that we are
seeking, when we get our expert report, we will be
glad to provide it to you at that time.
Q. I'm asking for nonmonetary damages. I'm
asking are you seeking any damages with respect to
any claims for emotional distress and suffering,
irritability, sleeplessness?
A. Again, I think our expert will take all of
those into consideration, and when we have that
information, we will be glad to provide it.
Q. Mr. O'Boyle, you previously testified that
you are obtaining an expert with respect to loss of
business and that you are obtaining an expert to
testify as to loss of business, not whether or not
you have incurred any emotional distress or pain and
suffering.
So I'm not sure how that expert with respect
to -- are you saying that you are going to retain an
expert to testify as to whether or not you had
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Martin O'Boyle
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incurred any emotional distress damages as well?
A. What I am saying is we are going to obtain
an expert to deal with this prong of the litigation.
Q. You mean with respect to all of your
157
damages?
A. Well, that's what you say.
Q. Well, I'm asking for clarification as to
what you are trying to tell me, Mr. O'Boyle.
A. I'll say exactly what I just said again, and
that is in connection with this prong of the
litigation, we intend to hire an expert. Once that
expert is made available and we have his report, we
will be more than happy to provide it to you.
Q. And by this prong, are you referring to the
questioning that I have been engaging in regarding
your damages?
A. I'm not sure I understand your question.
Q. My question -- the questions I have just
asked you all relate to your purported damages in
this claim. So is that the prong you are referring
to in your response?
A. Can you say that again?
Q. The questioning I have just been asking you,
it's related to your alleged damages in this claim.
So is that the prong you are referring to in your
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response?
A. Is this the prong?
Q. No, the damages portion of your claim, is
that the "prong" you are referring to?
A. Well, this is the damage portion. See, it
says "Damages" right up top.
Q. I am not asking about that document,
Mr. O'Boyle. You testified you will hire an expert
with respect to that prong of this suit. I am asking
what your definition of that prong is. By that prong
do you mean the damages portion of this suit?
A. There is -- the way I see it, and I'm not an
expert, so let's understand that. I see it that you
have the effect on your business and there is damages
and then I see an effect on your personal life and
there is damages. That's the way I see it.
Q. So can you tell me, as you sit here today,
what the effect has been on your personal life of
Mr. Sweetapple's alleged statements?
A. I cannot. That's an expert's
responsibility.
Q. Mr. O'Boyle, wouldn't you agree that you are
in the best position to testify as to how something
affected your own personal life?
A. Absolutely not.
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Q. Okay, so as you sit here today, you are
unable to testify to any means as to how any of the
alleged statements by Mr. Sweetapple has affected
your life?
A. In a negative, in a negative, in a highly
negative way.
159
Q. In what way? Can you provide me specifics
as to how it's affected you in a negative way?
A. Well, I think there are a multitude of
areas, humiliation, embarrassment, you point out
ostracization, outrageous contact, loss of face.
There is a whole plethora. I don't know what that
plethora is. I have not been examined. I don't know
what effect it has.
I may have a psychiatrist -- I may talk to
you and you say, "I think you need a psychiatrist,"
and I say, "No, no, I don't," and get a psychiatrist
and he says, "You need one bad."
So you can't ask me those kind of questions
because I can't answer them.
Q. Have you been treated by a psychiatrist or a
psychologist for your damages with respect to this
claim?
A. No. Have I been? The answer is I'm not
going to answer that question.
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M
Q. Mr. O'Boyle, it goes directly towards your
damages. I need to know whether or not you have been
under treatment for the alleged statements of
Mr. Sweetapple.
A. No, sir, you do not, and I'm not going to
answer it.
Q. Okay, so we will take that up with the court
too, because you have no reason not to answer.
Have you sought any medical treatment for
any -- arising from any of the alleged statements by
Mr. Sweetapple?
A. I'm not going to answer that question.
Q. Okay, we will take that up.
Have you lost any sleep as a result of the
statements alleged by Mr. Sweetapple?
A. Probably.
Q. Okay, have you seen a doctor regarding your
loss of sleep?
A. No.
Q. Have you lost the ability to enjoy life as a
result of the alleged statements by Mr. Sweetapple?
A. You are asking me to opine on psychiatric
issues. I'm not going to do it.
Q. I am not asking you to opine on psychiatric
issues, Mr. Sweetapple -- Mr. O'Boyle, I am asking
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you to tell me how this has personally affected you,
and the only person who I would be able, who should
be in the best position to tell me how something has
affected the person is the person affected.
A. Well, that's what you say. I disagree with
you. I think the person who is an expert is the one
who could answer the question.
Q. Right. Wouldn't that expert have to
interview you to find out what your position was in
order to find out -- to opine to that?
A. My sense is the answer is yes; however --
Q. Why wouldn't --
A. However, however, the expert is not
necessarily going to have the same viewpoint or
approach things the same way that I will. That's why
they call them experts. We will have an expert here.
You will look at the expert report. You could ask
him all the questions that you like -- him or her. I
apologize.
Q. But I would like to know what your position
is, what you have to say. I don't care about your
expert because there is no expert right now. I want
to know what you have to testify to, what your
position is. How has it affected your life?
A. I have answered your question.
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162
Q. In fact you haven't.
A. Okay.
Q. So we will take that up with the court as
well seeing as now you are refusing to answer.
Has there been any adverse effect on your
life or health that you haven't described here today
as a result of the alleged statements by
Mr. Sweetapple?
A. I am not going to answer that question.
Q. Okay, is there a reason you are refusing to
answer?
A. Yes, because I think it has to do with an
expert. I think it has to do with medical and I
don't think it has to do with you.
Q. Why don't you take a look at what's been
marked as Exhibit 1.
MR. O'BOYLE: I'm not sure what Exhibit 1
was. 1 should be either over here -- is this 1
and 2?
Q. I'm sorry, yes, 1 and 2 should be in there.
A. Okay. We have 1.
Q. Specifically page 2, response to question 4,
and I'll just read it for the record. Question 4
says, "If you seek damages in this matter for alleged
intangible injuries, including emotional stress, pain
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Martin O'Boyle
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and suffering, state the date you first began to
suffer each such injury, conduct, communication or
circumstances which give -- gave rise to each such
injury, giving the name and address of each witness
with personal knowledge of each such injury and the
name and address of each witness with personal
knowledge of any, of any consultation, therapy or
treatment for such injury, including any healthcare
provider or member of the clergy."
In your response to that question you
stated, "Plaintiff has not asserted a claim in this
matter for intangible injuries."
MR. O'BOYLE: I just want to clarify,
Exhibit No. 1 is the Town of Gulf Stream's
interrogatory, right?
MR. GOLDSTEIN: That's correct.
MR. O'BOYLE: Okay.
Q. Do you recall providing the Town of Gulf
Stream and myself with your response to that
question, that you are not seeking any intangible
injuries?
A. Did I intend what?
Q. That you are not seeking, that you have not
asserted a claim in this matter for intangible
injuries?
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1 1 A. To?
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164
Q. In response to the town's request
interrogatory number 4.
A. So you just said a moment ago to your
request. That's --
Q. No, I said to the town's request.
A. Okay.
Q. It was the town's interrogatory.
A. I know. They were your words. And what is
your question again?
Q. Do you recall agreeing to the answer that
says that you are not asserting, that you have not
asserted in this claim, in this matter for intangible
injuries?
A. Well, it's written there, so I must have, I
must have agreed to it or it must mean something that
neither of us are focusing on.
Q. Have you ever received any letters or other
written communications from anyone regarding the
statements that Mr. Sweetapple allegedly made?
A. Have I ever what?
Q. Received any letters or other written
communications about Mr. Sweetapple's alleged
statements.
A. No, they are not the kind of things you
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165
receive in the mail.
Q. I'm saying something like a note from a
friend in the town or Mr. O'Hare, Mr. Rader or
Mr. Hanna, or anybody else you may know in the Town
of Gulf Stream.
A. I think I have answered that, but the answer
Q. I personally don't have anything further at
this time. Of course, I reserve on many of your
objections and refusals to answer, and may have a
follow-up depending upon how Mr. O'Boyle --
A. All the ones you want to challenge, maybe
what we should do is brief them and then we will
submit them to the judge.
MR. GILL: There is a procedure. There is a
special order for how it is supposed to be done.
THE WITNESS: Okay. I am just trying to be
helpful, you know.
REDIRECT EXAMINATION
BY MR. GILL:
Q. A few questions. On cross-examination at
the beginning you mentioned Commissioner Ganger?
A. Uh-huh.
Q. What is your opinion of Commissioner
Ganger's involvement with the allegations in your
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complaint?
A. I think -- I have to give you a general
statement. I can't give you a 2:00 last night he
told three people at dinner.
Q. No specifics, right? That's the theme?
A. He was one of the big proponents of this
RICO action and he is one of the big proponents of
eliminating the Constitutional rights of the people
of Florida to get public records.
Q. As a town commissioner?
A. No, I think as an individual too.
Q. What has he done as an individual to do
that?
A. Well, I know he went to Tallahassee to
testify before whatever.
Q. Okay.
A. I know he stood and talked to Chris O'Hare
and I, outside the rear entrance this time, of the
town hall, if we want to call it that, and we talked
about, we talked about things there, and I would have
to -- I would have to play back the meetings.
Q. Okay.
A. It's hard to remember sitting here.
Q. At the meetings he is there as a
commissioner, correct?
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A. At the meetings -- well, I don't know that I
agree with you. When he is on the dais, I think he
is there as a commissioner. When he is in the
kitchen, I don't.
Q. Okay. Would those recordings, would the
recordings of the meetings show what happened in the
kitchen?
A. I don't think so, but I think the ones in
Tallahassee will show what happened in the kitchen.
Q. Okay. Okay. I'm sorry, the ones in
Tallahassee will show what happened in the kitchen?
A. I'm joking. It's getting late.
Q. Try not to joke and try to just answer the
questions and you will get out of here much faster,
Mr. O'Boyle.
A. I apologize. The ones in Tallahassee, he is
not on the dais, he is up there, he is testifying as
Bob Ganger, the man.
Q. Okay. So we have got Tallahassee, I got
that. I understand that. The things in the dais, he
is a town commissioner?
A. Yes.
Q. Did you have a conversation in the kitchen?
A. No. I think it was Chris and I had one
outside at the rear entrance to the building.
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Q. Okay. Was this -- approximate, when was
this in time?
A. It would be either right before or right
Im
Q. What was the subject matter of your
conversation?
A. The RICO action.
Q. Okay, what did he say to you?
A. You know, I don't remember exactly, but it
was we are going to file or we are getting ready to
file or we are considering filing -- it must have
been before they filed -- this RICO action, and I
remember Chris saying, "Your crazy, it's going to
cost you $5 million," and he said, "It will never
cost that much money."
And then, of course, they came later with a
big board that showed it's going to cost $5 million,
and I believe that it's probably going to cost more
than $5 million because of --
Q. Was there anything else discussed in the
conversation, as you recall, that you just described
to me?
A. I think Chris probably -- Chris is more
active than me. He is a lot smarter than me, by the
way. I think Chris, you know, was trying to say to
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Martin O'Boyle
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him, "What are you doing? You are taking all -- as a
matter of fact, I'm certain he said it, although I do
get confused. "It cost 12-, $1500 to settle these
suits. You are letting Bob Sweetapples of the world
build it up for 50,000 apiece. All he is doing is
sucking your blood." And, of course, in order for
things to work out, sometimes you have to have your
listening ears on.
Q. Let's focus on what was said, not the
opinion part. What did Mr. Ganger say back to you,
if you recall?
A. You know, the answer is I don't know. It
was a general themed conversation, like, "What are
you doing? Why are you spending a dollar when on
your best day you're getting a nickel? Why?"
And that was the general theme of the
conversation, and then Chris, as he always does, he
loves the town, Chris tried to talk some sense into
him, but he didn't have his listening ears on.
Q. Okay, so we have talked about things he did
on the dais, which you don't remember but said go
back to listen to the tapes; we have talked about
what happened in Tallahassee; we talked about a
conversation behind the kitchen. Is there anything
else that Commissioner Ganger had to do with the
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allegations in your complaint as you sit here today?
A. I think he also -- I'm not sure, but I think
he also went to Bob Currie's office.
Q. Okay, what is your basis for that knowledge?
A. Bob Currie told me.
Q. Okay, what did Bob Currie tell you?
A. That Ganger was -- stopped by, and he said
something like, "I don't know what's gotten into this
guy lately, but he was bad mouthing you," and I don't
remember whether he said "bad mouthing you" or
"MF'ing" you, I don't remember, but it was that tone,
that theme.
Q. Okay. When did approximately you have this
consideration with Bob Currie where he claims
Commissioner Ganger came by his office?
A. I wouldn't be able to -- I wouldn't be able
to tell you.
Q. Okay, is there any other involvement you
think Commissioner Ganger had with the allegation in
your complaint?
A. The answer is yes to your question, but if
you follow-up and say to me tell me about him, I
can't.
Q. Well, this is my one shot to depose you,
Mr. O'Boyle, so what you say today is what you get
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stuck with, so you need to think if there is
something else you want to tell me about Commissioner
Ganger.
A. Yes. Thank G -d you don't make the rules,
but I have given you the best that I could, and if I
think of something, I will certainly alert you.
Q. You testified, and I'm paraphrasing so
correct me, about trying to -- there was a sign put
up about the number of public records requests that
have been done and you tried to fix the sign or
something?
A. Yes.
MR. O'BOYLE: Wait, wait, wait. You are
talking about an instance that's currently being
charged criminally by the Town of Gulf Stream. I
am going to instruct Fifth Amendment privilege.
MR. GILL: Okay. First of all, you are not
an attorney in this suit. So he brought it up.
He can certainly describe about what just
happened. Okay, he brought it up.
A. I apologize, I am pro se. I don't know any
better.
Q. So you are going to refuse to answer the
question about you fixing a sign regarding public
records which you referred to previously?
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A. Previously?
Q. Yes. I didn't -- this didn't come out of
this out of nowhere. You testified about fixing a
sign and then I am asking a follow-up question. I
just want to clarify that you are going to assert the
privilege on anything regarding that.
A. I have no idea what you said, but whatever I
said I said in error. Please remember, I am pro se,
but there are criminal charges pending and I want to
assert my Fifth Amendment privilege.
Q. Do you personally, as Martin O'Boyle, enter
into commercial real estate contracts?
A. No.
Q. Do you personally, as Martin O'Boyle, have
any business deals?
A. That's like saying how long is a road. I
don't know what you are saying.
Q. I think you are seeking damages for lost
business opportunities; is that correct?
A. Uh-hum.
Q. You have to answer verbally.
A. Yes. I'm sorry.
Q. Would those be business opportunities that
you personally entered into as Martin O'Boyle where
it was your name on the contract?
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Martin O'Boyle
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A. Probably not. As a matter of fact, very
likely not, but yeah, likely not.
Q. With respect to the Bar complaint, Bar
complaints that were filed, those were all against
attorneys who had represented you in some fashion,
correct?
A. You got me.
Q. You make allegation in your complaint that
one of the acts of retaliation is a Bar complaint
that was filed, correct?
A. Can you show me where?
173
Q. Sure, or we can go to the interrogatories.
That might be easier. We will go to 2.
A. I have 2.
Q. If you go to page 7.
A. I'm there.
Q. Subparagraph D, you reference Bar
complaints, UPI, complaint and letters to the Board of
Bar Examiners.
A. Uh-huh.
Q. Do you see that?
A. Yes, I do.
Q. The persons that those were directed to,
that the complaints were made about, were all people
who represented you as an attorney, correct?
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Martin O'Boyle
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174
Did you say
Q. No, the complaints that were made --
A. Yes.
Q. -- to the Bar, you understand the process of
how a Bar complaint works?
A. Sort of, but yes.
Q. They were complaining about a specific or
several attorneys actually, right?
A. Right.
Q. Those attorneys had represented you at some
point previously, correct?
A. Right.
Q. Is that correct?
A. When you say previously, I'm not sure if
it's previously or then currently or presently
currently, but these are all bogus complaints. These
are all made up by Mr. Sweetapple. He knows, he sat
there as I called it the biggest piece of shit I have
ever seen. You remember that, Mr. Sweetapple, I'm
sure. It's right on the record.
Q. Let's focus on the answer to my question,
which you still haven't.
A. Okay.
Q. So the attorneys that were the subject of
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Martin O'Boyle
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those complaints had all represented you, correct?
A. No, I didn't say that. What I say is they
then represented me, they now may represented me, or
they may have represented me somewhere in between.
Q. So you think there were attorneys that
hadn't yet represented you that were named in the Bar
complaint?
A. You know, the answer is I don't know
everybody who is named in the Bar complaint, so I
can't really say for sure, but I don't -- I don't
think it's the case. I think, you know, it's what
you say.
Q.
You
think I am
correct
in your
statement?
A.
What
was your
statement
again?
We will find
Q. That the attorneys in the complaint had
represented you.
A. I think that's correct. Don't rely on it,
but I think it's correct.
Q. Your son had already represented you in
Florida, correct?
A. My son had already represented me in New
Jersey, correct.
Q. And he had also appeared pro hac vice in the
State of Florida? He had asked to be -- I'll
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Martin O'Boyle
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rephrase it, that he asked to be admitted for the
purpose of one case to represent you in Florida
before the Bar complaint was filed.
A. Which case would that be?
Q. I think the previous sign case perhaps or
the initial sign case.
A. I can't say, and by the way, just to point
out, every one of these Bar complaints, UPL
complaints, they all went down in flames, just like
they should have.
176
MR. SWEETAPPLE: Mr. Gill, that's not
accurate. There is a letter that actually -- so
it's just another misstatement by Mr. O'Boyle, so
we will talk to that outside the record.
A. Just call me Misstatement Marty.
Q. Have you ever been prevented from attending
a Town of Gulf Stream Commission meeting?
A. Never.
Q. Have you ever been escorted out of a Town of
Gulf Stream Commission meeting?
A. Never.
Q. Have you ever had the decorum policy
enforced against you?
A. Never. By the way, you should read that
decorum policy.
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Martin O'Boyle
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Q. You were asked some questions about a JF
reference in some of the banner, airplane banner
signs.
A. I think that's right, yes.
Q. Do you know who you were referring to with
I JF?
177
A. I knew what I was referring to, but I don't
think the other 350 million people in the United
States did.
Q. What were you referring to?
A. Jones Foster.
Q. I don't have any further questions of you at
this time, Mr. O'Boyle.
MR. GOLDSTEIN: I have one follow-up
question.
RECROSS -EXAMINATION
BY MR. GOLDSTEIN:
Q. You stated, when Mr. Gill was asking you
some cross and recross, that Mr. Sweetapple, my
client, drafted the unauthorized practice of law
complaint. Do you have any evidence that would
prove, that would establish that Mr. Sweetapple
actually in fact drafted that complaint?
A. Yes.
Q. What evidence do you have that he in fact
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Martin O'Boyle
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A. He signed it.
Q. He signed the unauthorized practice of law
complaint submitted to the Bar?
P_�dzlw
Q. He signed it?
A. Yes, as did Joanna O'Connor.
Q. Not Mayor Morgan?
A. No. No, I think Morgan signed the Bar
complaints, if that's where you are heading.
Q. So Morgan signed the Bar complaints?
A. I believe so.
178
Q. And you are referring to something
completely separate?
A. Yes. The unauthorized practice of law is a
bit more serious, don't you think?
Q. I am not here to answer your questions,
Mr. O'Boyle.
A. That's true. There will come a day.
MR. SWEETAPPLE: That means he is going to
sue you too, so you'll join the club.
Q. So these were letters that were submitted
for the unauthorized practice of law?
A. Pardon?
Q. There were letters submitted. Have you
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Martin O'Boyle
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produced those? Have you produced those letters in
this case?
A. I have never seen them.
Q. So how do you know Mr. Sweetapple signed
179
A. Because I went up to see Jones Foster and
they had it on the table, and I said, "Whose brain
child was this piece of shit?"
Q. You just testified you have never seen it.
A. This was signed by him. It was a pleading.
Q. It was a motion.
A. A motion. Okay, yeah.
Q. Perhaps a motion to disqualify, Mr. O'Boyle?
A. I don't think so.
Q. Okay, I have got nothing further at this
time. However, again, I reserve my right to renew
this deposition, depending upon the court's ruling.
MR. GILL: You have the right to read your
deposition once it has been transcribed to ensure
that it has been transcribed accurately or you can
waive that right and assume it's been done. It is
your right to say on the record whether you want
to read it or waive it.
THE WITNESS: Pardon?
MR. GILL: You need to go on the record and
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Martin O'Boyle
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say whether you want to read the deposition to
ensure that it's been transcribed accurately or
whether you want to waive that right.
THE WITNESS: And I have to do that right
now?
MR. GILL: You have go on the record and say
read or waive. You can always waive later on, so.
THE WITNESS: I appreciate that. Read.
(Time noted: 5:15 p.m.)
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C E R T I F I C A T E O F O A T H
STATE OF FLORIDA
COUNTY OF PALM BEACH
ME
I, RICHARD GREENSPAN, FAPR, RMR, CRR, FPR,
Notary Public, State of Florida, certify that MARTIN
E. O'BOYLE personally appeared before me on
May 16, 2016 and was duly sworn.
Signed May 24, 2016.
RICHARD GREENSPAN, FAPR, RMR, CRR, FPR
NOTARY PUBLIC - STATE OF FLORIDA
My Commission #FF 076190
Expires: March 12, 2018
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Martin O'Boyle
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C E R T I F I C A T E
STATE OF FLORIDA
182
I, RICHARD GREENSPAN, FAPR, RMR, CRR, FPR,
certify that I was authorized to and did
stenographically report the deposition of MARTIN E.
O'BOYLE, pages 1 through 180; that a review of the
transcript was requested; and that the transcript is
a true record of my stenographic notes.
I further certify that I am not a relative,
employee, attorney, or counsel of any of the parties,
nor am I a relative or employee of any of the
parties' attorneys or counsel connected with the
action, nor am I financially interested in the
action.
Dated May 24, 2016.
9/ �
RICHARD GREENSPAN, FAPR, RMR, CRR, FPR
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Martin O'Boyle
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183
ERRATA SHEET
DO NOT WRITE ON THE TRANSCRIPT, ENTER CHANGES ON THIS PAGE
IN RE: O'Boyle v. Sweetapple
Martin E. O'Boyle
May 16, 2016
PAGE LINE CHANGE
REASON
Under penalties of perjury, I declare that I have
read my deposition transcript, and it is true and
correct subject to any changes in form or substance
entered here.
DATE
MARTIN E. O'BOYLE
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Martin O'Boyle
May 16, 2016 184
May 23, 2016
Martin E. O'Boyle
1280 West Newport Center Drive
Deerfield Beach, Florida 33442
In Re: O'Boyle v. Sweetapple
Deposition taken on May 16, 2016
U.S. Legal Support Job No. 1403046
Please call to schedule an appointment between the
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Please complete your review with 30 days.
Sincere y,
1
Richard Greenspan, FAPR, RMR, CRR, FPR
U.S. Legal Support, Inc.
444 West Railroad Avenue, Suite 300
West Palm Beach, Florida 33401
561-835-0220
CC via transcript:
Hudson Gill, Esq.
Joshua Goldstein, Esq.
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350 177:8
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3:00 62:20
111:1
4
4 15:25 16:8
41:22 162:22,
23 164:3
40 120:8
46 58:23
68:24 69:1,9
48 143:23
5
5 11:1 31:21
34:9 44:20
45:1 51:15
50 20:17
115:7,15
117:18
50,000 169:5
6
6 33:24 51:17
100:24
608,000 54:7
7
7 7:14,21 8:6
9:16 10:10
13:8,9,12
15:24 42:1,
10,18,19 43:4
45:1 48:12
88:9,12
128:11 173:15
8
8 7:15,21
35:2 43:13
45:2 48:12
95:8,10
3
He 68:16
9 49:20
100:4,6,11
109:13 121:12
A
a.m. 42:1,10,
19 43:4
ability
160:20
absolute
93:22
absolutely
24:5,11
60:23,25
68:20 90:8
92:1 158:25
abstract
105:12,13
accommodate
6:11
accommodating
8:25
accordance
38:5,14
69:16,19
accounting
124:25
accurate
95:16,23
146:4 176:12
accused 28:5
acquaintance
34:13
acronym 78:1
act 44:17
79:2,7 80:2,
22
action 24:5
53:7,14 54:8
92:25 112:24
122:13 146:6
149:15 166:7
Martin O'Boyle
May 16, 2016
168:7,12
actions 60:22
117:16
active 168:24
activities
8:7,19 9:6
52:9
activity
9:15,19
16:16,19
31:25 33:21
49:6
acts 9:8
23:1,24 26:23
32:9 33:8
101:8 173:9
actual 149:4
152:7,16
added 24:3
addition
100:3 115:10
additional
25:18 102:13
116:4 135:23
address
163:4,6
addressed
25:11 33:21
adjudicate
44:13
adjudicated
50:15
administrative
34:1,5
admissible
75:17
admits 60:17
admitted
45:25 46:3,9,
12,13 47:17
48:6,18 49:15
176:1
advance
127:10
adverse 91:25
162:5
advice 125:18
advised
128:23
affected
158:24 159:3,
6 161:1,4,24
affects
126:3,6
affirm 5:6
afternoon
35:21 64:1,8
agencies
34:1,5
agree 32:20,
25 44:7 60:7
82:19 145:20
146:20 155:4
158:22 167:2
agreed 164:16
agreeing
164:11
agreement
35:11,23
36:2,13,25
40:6,9
ahead 69:19
107:25 117:25
aided 33:6
airplane
43:13 52:20
177:2
airplanes
18:7 43:21
akin 78:10
149:17
Alaska 145:18
alcohol
27:14,15,17
69:1
alert 66:3
102:14 171:6
alerted 111:1
alerting
91:17
aliases 93:21
allegation
170:19 173:8
U.S. LEGAL SUPPORT
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allegations
115:4,5,9,12,
14 131:19
135:23 165:25
170:1
allege 101:2
alleged 57:19
121:25 136:11
138:1 150:3
151:18,19,25
152:19 153:3,
5 154:13
157:24 158:19
159:3 160:3,
10,15,21
162:7,24
164:23
allegedly
59:24 96:18
129:9 134:14
164:20
alter 8:24
Amazing 69:11
amended 7:13
12:1 100:12,
15 101:3
121:13 131:21
132:16 133:9
134:12,25
Amendment 8:7
9:11,15 10:18
11:7 16:17,19
38:5,15 49:6
52:9 64:18,21
69:16,20 70:4
171:16 172:10
amendments
12:7
America 32:19
61:21 78:12
amount 54:1
55:23
and/or 22:15
31:3 33:25
123:22 146:25
angry 50:8
64:24
t'.
anguish 155:6
announcement
92:12
answering
21:16 75:7,9,
13 94:18
99:23 131:14
148:4
answers 7:12,
13,14 25:20
36:18,21
58:11 62:10
109:12
anti -mayor
13:10 14:17,
23
anti -morgan
14:13
anymore 50:20
156:6
apiece 169:5
apologize 6:2
19:15 83:10
110:10 133:24
134:2 161:19
167:16 171:21
apology 38:9
apparently
98:20
appeal 50:19,
20
appealing
33:25 34:4
appearance
17:13,18,19
18:1 45:13
76:8
appeared
175:24
appearing
45:18,20
appears 18:10
45:24 100:14
142:8
appellate
44:10,13
applaud 92:10
Martin O'Boyle
May 16, 2016
Apple 87:11
88:8,10,15
89:8,10,17,18
90:11,12,14
apples 86:14,
21 87:17
88:23
applies
156:2,7
approach
141:2 161:15
approval 72:2
approve 38:4
113:15
approved
106:20
approximate
168:1
approximately
55:5 170:13
April 97:24
architect
69:8 111:7,11
113:3
architectural
26:13,14
area 68:12,19
111:14
areas 159:10
arising
160:10
Army 122:19
arose 68:15
84:8
arrested
49:15
askew 139:2
aspects 45:15
ass 24:8
38:25 141:1
assembles
16:1
assert 154:16
172:5,10
asserted 77:1
163:11,24
164:13
asserting
154:21 155:23
164:12
associates
16:1 101:5,10
assume 5:25
7:23 45:7
assumed 11:25
assuming
36:24 45:17
130:12
attend 141:10
attended
113:13 141:14
142:25
attending
176:16
attention
116:23
attorney 18:4
45:19 52:12,
16,21 96:11
113:24 128:15
133:10 136:24
137:2 171:18
173:25
Attorney's
81:10 82:18
83:6,12,16,24
84:2
attorney-
client 154:16
attorneys
37:15 43:15
44:1 101:6,10
127:11 173:5
174:9,11,25
175:5,16
audience
103:7
author 147:5,
24 148:19
authored
86:4,10,24
authoring
146:9,25
authorize
19:6,10,21,23
U.S. LEGAL SUPPORT
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71:12 91:7
92:16 144:15
148:18
authorized
19:1 20:4,9,
10 22:2 85:25
86:16 87:2
90:17 91:3
149:2
authorizing
86:3,19
91:13,19
146:9
aware 41:16,
24 42:7,17
43:2 76:20
116:18 129:15
132:1 141:5
142:5,18
153:10
B
B -r -i -g -h -t
101:24
back 8:3
10:22 14:9
15:19 30:18
34:9 62:23
63:1 66:18
77:13 78:19,
21,25 94:18
95:1,3 104:1,
13,17,23
105:10,23
106:2,3,6
107:2,18,19
108:6,8
109:10
116:13,22
118:15
120:20,21
121:12 122:8
125:3 126:19
128:10,21
133:16,18,20,
23 134:1,8
155:23 166:21
169:10,22
9
background
84:19
backtrack
67:9
bad 65:3
127:12 159:18
170:9,10
bankrupting
65:3
banner 18:7,
9,11,12,18,
23,25 19:2,3,
5,10,12,21
20:2,8,10,24
22:1 23:3,25
24:10,12,14,
19 42:8 43:3
85:20,25
86:3,5,10,20
87:2 91:7,13,
20 92:16,18
177:2
banners 40:12
43:13 52:12,
15,20 85:8,12
86:13 90:17,
21,24 91:2
bar 23:20,22
44:20,21
45:8,9,25
46:3,7,17
47:12,13
48:2,3,7,19
173:3,9,17,19
174:5,6
175:6,9
176:3,8
178:4,9,11
based 8:22
11:14 51:12
76:8 78:23
79:14 88:25
128:3 134:10,
11,17 148:4,6
151:18
basing 58:21
94:21
basis 23:9
Martin O'Boyle
May 16, 2016
75:7 76:17
80:8 89:17
92:6 132:7
145:14 170:4
bath 109:7
139:25
bathroom 6:20
beach 18:21
20:9 22:3
23:3 52:21
81:11 83:6,8
85:9 86:13,20
87:2 88:4,5
91:3 103:15,
23 104:19
106:19 111:7
113:3,4,6,9
Bear 44:18
beautiful
68:20
began 28:21
163:1
begin 64:23
beginning
165:22
behalf 18:12,
24
behest 143:9
believes
55:20
belittled
27:1,11
belittling
28:11,20
bell 106:25
107:17 122:20
belonged 21:2
benefit 72:13
bet 29:17
big 10:11
60:15 68:16
66:17 109:8
166:6,7
168:17
biggest 23:6,
17 174:19
Bill 13:18
bills 22:24
91:9,18
92:17,20,22
bit 6:1 37:22
66:13 96:20
109:25 139:10
178:16
bless 97:12
block 40:21
blonde 27:16
38:22
blood 107:5
169:6
blue 138:16
board 44:21
45:9 47:13
93:19 122:15,
21,23 168:17
173:18
Bob 57:24
69:7 87:3
99:24 101:25
103:9 104:5,
7,19 105:19
110:23,24
111:5,6 112:4
116:12 167:18
169:4 170:3,
5,6,14
bogus 174:17
boiled 86:14
bond 122:18
bottom 45:1
boy 23:11
bragging
99:16
brain 112:14
breached
35:11,23 36:2
break 6:9,23
62:4,5 153:4,
17,20
breakdown
123:16
breakfast
109:13
U.S. LEGAL SUPPORT
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Brigade
117:3,5
Bright 101:22
108:15,23
109:16 116:15
bring 155:12
brings 15:19
73:6
broad 34:7
64:21
broadest
141:18
broke 64:15
brought 34:21
88:3 96:24
116:23 122:15
171:18,20
brushes
141:19
buck 86:7
buckteeth
38:22
bucktooth
38:22
budget 122:17
123:2
build 169:5
building
69:2,10
118:17,21
124:23 167:25
built 40:13,
14
bunch 119:5,6
bundle 61:18
burn 141:1
business
27:17 55:23
56:1,6,8,11,
15,23,25
57:4,7 58:2,
3,16,23,25
59:24 61:3
67:11 101:5,9
113:8 117:19
156:19,20
158:14
0
172:15,19,23
business -wise
56:2
button 13:4,5
14:14,17,24
15:8,13,20
1i
C -u -r -r -i -e
102:2
call 13:10,
11,16 38:17
62:16 71:8,10
80:25 111:1
124:23 161:16
166:19 176:15
called 26:14
28:25 30:15
39:4,5 78:2
80:10,12
81:19 82:16
116:24 124:13
135:20 138:23
174:19
calling 28:1
70:20 71:1
camera 50:8,
9,11,12
cameras 35:7
campaign
31:22 32:6,11
33:2,9
cancer 112:14
candy 93:12
canvas 20:8
capable 75:15
car 27:9 43:7
care 70:23
161:21
case 16:4
36:7,10 55:3
65:11 75:11,
16,24 80:3
123:21 129:22
175:11 176:2,
4,5,6
Martin O'Boyle
May 16, 2016
cases 80:2
129:23
catch 148:14
caused 55:22
60:8
causing
49:11,13
center 103:6
certiorari
37:1
chains 13:23
challenge
165:12
chamber 121:4
chambers
125:1
Chandler
101:14
changed
119:25
character
38:21
charge
130:18,20
charged
111:24 171:15
charges 172:9
Charlie 37:1
charts 28:14,
18
check 56:15,
17 91:8
children
103:16
chill 37:25
choose 60:15
Chris 54:21,
22 96:11
103:11 107:1
128:15,16
133:11 166:17
167:24
168:13,23,25
169:17,18
circle 34:21
circuit 46:24
circumstances
163:3
citation
11:17 12:17,
19 21:23
26:17
cite 26:20,22
38:8
cited 11:20
12:13,15
20:18,23 21:3
41:18 42:2,9,
13,14,20
79:8,17,19
citizens 33:5
city 20:6
61:2 73:18
117:18
claim 9:10
10:9 11:6
16:17 23:24
24:17 35:19
58:25 59:7
106:21
154:10,13
155:24
157:20,24
158:3 159:23
163:11,24
164:13
claimed
35:10,16 36:5
155:14
claiming 9:9,
20 16:2,10,
18,21 23:2
24:9 25:8
26:24 32:10
33:8 35:20,24
56:19,22
58:16
claims 54:9,
12 132:7
134:22,25
156:12 170:14
clarification
46:16,19
114:13 157:7
U.S. LEGAL SUPPORT
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clarify 5:24
6:7 114:8
117:4 163:13
172:5
clarity 45:3
73:7
class 17:2
clean 50:11
clear 6:15
13:2 15:15
35:25 42:17
56:22 57:3
69:4 79:22
98:16 104:4,
16,18 105:15
106:7 110:6,
9,11 113:23
114:13 124:14
130:13 139:3
clergy 163:9
client 85:10
93:4 106:13
177:20
client's
85:13
clients 91:8
close 61:19
153:16
closer 50:7
closest 94:1,
3,5,11,22
club 178:21
CNN 94:9
Coastal 30:16
109:25 116:21
collapse 23:9
colleagues
101:5,9,18,20
comfortable
100:16
commentary
97:18
comments
66:23 128:7
commercial
57:14,17 59:1
172:12
5
commission
11:2 26:9,15
31:22 32:11,
16 33:2 92:20
113:13,19
117:17 118:12
123:3 124:14
140:8 141:9,
15 143:1,4,13
144:4,5,9,12
146:6 176:17,
20
commissioner
27:18 71:1,5,
11 165:22,24
166:10,25
167:3,21
169:25
170:15,19
171:2
commissioners
32:13 61:2
70:20 93:6
101:15 118:10
124:13 143:6,
10
commit 51:12
common 142:3
communication
154:22 163:2
communications
17:8 65:25
116:1,10,14
128:22 138:10
164:19,23
community
55:22 60:7,20
150:3
companies
145:12
company 15:1
145:10,11
153:15
compared
61:11,12
complaining
174:8
Martin O'Boyle
May 16, 2016
complaint
44:21 45:9
47:13 48:8
50:22 85:4
100:12,15
101:3 121:13
131:21 132:3,
9,17 133:9
134:11,12,17,
18,25 135:15,
17 166:1
170:1,20
173:3,8,9,18
174:6 175:7,
9,16 176:3
177:21,23
178:4
complaints
23:19,22
44:20 45:8
47:12 48:7,19
173:4,18,24
174:3,17
175:1 176:8,9
178:10,11
complete
8:12,13 10:1
completely
74:2 178:14
complexity
96:20
compliance
60:11
comprehensive
16:24
conclusion
58:22
conditions
46:13
conduct
26:17,19
55:21 56:20,
23 57:19 58:4
59:2,25 60:8
163:2
confidential
135:20 136:7
confidentialit
y 97:3
confirm 22:6,
20 136:1
confirming
106:1
confused
169:3
connection
17:5 33:16
52:11 53:6,13
55:2,7 146:5
157:10
consideration
156:15 170:14
considered
141:6,7,8
constituency
22:16,19
Constitution
38:6 60:14
69:17,20
Constitutional
60:23,25 81:1
166:8
consultation
163:7
contact 52:1
159:11
contacted
52:6
contacts 59:1
contained
8:20
content 22:1,
10,18 29:6
36:12 38:18
107:9
context 27:5
35:22,24
146:13,16,17
contract
172:25
contracts
57:14,18
172:12
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conversation
14:3,5,11
15:7,18 31:5,
12,17 48:24
49:11,13
104:20 105:20
106:14 109:17
110:21,22
111:22
112:13,17,22
114:1,15
115:1,25
118:23 119:9
136:21 167:23
168:6,21
169:13,17,24
conversations
14:22 26:6
30:7 31:18
65:25 67:2
106:13,18
109:1 110:16
112:10
114:17,20,22
115:3,10,18,
23 116:4,19
121:18,22
128:24 129:4,
5,11 136:10,
15,20 137:19
138:1,5,8
convey 101:6
conveyed
99:11
cooperative
84:11
copy 29:12,22
95:16,20,23
100:11 149:5
correct 13:14
18:9 31:23
36:17 39:20
41:10 44:9,
17,22 45:10,
19 46:1,3
47:17 50:15,
23 64:18 67:8
72:4 77:6,7
81:5,7 83:20
9
85:10 86:18
88:17 89:13
90:18,23 93:1
94:24 95:6
102:17 114:10
121:16 135:8,
15 139:1
140:13,23
.147:13 163:16
166:25 171:8
172:19 173:6,
10,25 174:12,
14 175:1,13,
18,19,21,23
correspond
138:14,17
correspondence
154:22
cost 168:14,
15,17,18
169:3
costs 53:6,
13,22,24
54:25 55:6
council 121:4
counsel 17:6,
8,11,14 75:14
76:7 125:1
136:24 155:17
count 29:4
counterclaims
54:8
country 94:11
113:7
County 22:3
23:4 81:11
83:6,8 85:9
86:13,20 87:2
91:3
couple 9:25
12:6 62:10
109:9
court 5:3,19
33:22 43:23
44:8,10,13,
14,17 50:17
54:8 78:24
85:7 97:25
Martin O'Boyle
May 16, 2016
104:17,23
105:4,8,10
106:1,6
133:22,25
134:7 160:7
162:3
courts 33:25
34:4 44:15
cover 141:13
coverage
39:19
craze 138:25
crazy 168:13
creep 80:17,
19,20
criminal
101:7 103:10
104:6,8,21
105:17,22
106:15 107:9
108:3 109:20
119:14,18
122:2 123:20
126:23 127:14
135:5 138:21,
24 139:8
172:9
criminally
171:15
criminals
118:18 119:6
critical
18:13 28:9,
12,17 52:15,
21
criticized
64:17
cross 153:24
177:19
cross-
examination
64:6 165:21
crowd 97:8
118:3,5
Culver 55:1,6
current 59:10
Currie 69:8
101:25 110:23
111:5,6,8,15
112:9 113:12,
23 114:6,16,
21 115:2,10,
19 116:5
170:5,6,14
Currie's
170:3
cute 68:7
cycle 31:23
32:12 33:3
dais 122:3,9
124:5,6,13
125:4 167:2,
17,20 169:21
damage 55:23
56:1 58:2
60:5 158:5
damaged
56:20,23,25
57:7 58:3
77:2 150:3
damages 56:6,
7,8,11 58:17
59:1,24 76:23
151:12,17,19,
23,25 152:15,
18 153:2,5,11
154:10,13
155:5,24
156:3,7,10,11
157:1,5,16,
19,24 158:3,
6,11,14 16
159:22 160:2
162:24 172:18
damn 93:22,24
date 59:10
72:14 79:12,
13,15,19 83:7
119:22
125:12,16
163:1
dates 18:8
65:25 120:1,
U.S. LEGAL SUPPORT
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4,5,7 125:15
day 8:14
25:16 98:13
119:25 169:15
178:19
days 9:25
deal 25:13
57:22,23,25
60:15 157:3
dealing
123:23,25
deals 57:14,
18 61:3
172:15
decide 69:14
78:25 105:4
106:1
decided 60:3
70:7,8 73:11
89:7
decides 44:10
decision 93:7
141:16
decisions
28:10,22
declaration
67:18
decorum 9:2
176:22,25
Dee 39:2,13
71:18,22,24
defamation
121:10
defamatory
134:14
defamed
135:22
defaming
135:4
defendant
64:9
defendant's
7:2,4 41:5,22
51:15,17
88:12 95:10
100:4 143:21
154:1
7
defending
37:15
defense 54:7,
9,12 59:7
define 145:24
definition
142:4 158:10
degree 60:19
69:7
Deleo 69:7
Delray 18:21
20:9 21:24
108:22 111:7
113:3,4,6,9
demise 149:16
demonstrative
66:12
denial 73:3
denied 70:7
72:1,3
dents 88:4
deny 69:14,
18,21 70:12
department
124:25
depending
62:9 165:11
depends 94:20
124:22
depict 123:14
depose 33:16,
18 170:24
deposed 5:14
75:22
deposition
7:8 25:17
32:22 59:15
66:15 76:2,5,
9 84:18,21
88:3 101:12
133:21 136:13
146:18
depositions
5:15
describe
38:18 171:19
Martin O'Boyle
May 16, 2016
design 69:9,
10
desk 30:17
Desouza 17:6
Desouza's
53:16,19
destroyed
56:3
destroying
98:9
detail 7:21
49:2
details
128:18
determine
59:22 151:23
development
69:10
dice 36:2
dictate
144:23 146:18
147:5,24
148:18
dictated
144:20,24
dictating
146:10,25
difference
72:9 86:17
151:17,22,23
differentiate
151:12,16
152:4,11,14
difficult
65:24 109:11
difficulty
142:12,13
dinner 93:8,
10 111:19
139:25 166:4
diocese 124:4
direct 5:11
96:3 143:23
148:3
directed 10:2
11:13 16:13
134:19 173:23
directing
17:12
directly 27:2
77:8 85:2
119:10,13,15
122:7 137:14
139:12,16,18,
20 140:14,20,
21 160:1
disagree
161:5
disclosing
18:3
discovery
75:17 128:19
154:19
discussed
18:3 91:4
130:9 166:20
discussing
132:21
142:18,19
discussion
59:12 99:5
110:13 113:20
114:5 126:15
discussions
129:16 141:15
dishes 140:1
dismiss 96:12
97:1 129:22
displayed
19:6
dispute
66:19,22,25
67:3,4,6
68:2,9 70:6,
10 83:12,15,
23 84:1,3,8
disputes
67:25 68:3,8
distress
155:6,25
156:12,21
157:1
District
17:23 46:17
U.S. LEGAL SUPPORT
(561) 835-0220
divide 61:18
docket 100:19
doctor 160:17
document 22:5
88:14,25 89:4
100:13,17
154:5,9,19,
21,25 155:9,
10 156:2,4,6
158:7
documents
7:10 58:1
78:8,9,11
dollar 169:14
domiciled
67:24
donations
122:20
donkey 38:20,
23 70:1,9,15
door 14:9
118:14,15
122:8 123:22
126:19
doors 93:6
double 153:23
double-check
83:22
Doug 33:3
34:10,11,20,
24
draft 144:18,
21 149:2
drafted
177:20,23
178:1
draw 40:15,16
Drexell 47:9,
25
drink 91:20
drive 91:20
driven 19:12,
14,19
driveway 20:2
driving 92:4
drop 130:18
dropping 6:19
Duane 69:8
duly 5:9 64:4
Dum 39:3,4,5,
13 71:19,22,
24
Dump 13:6,7
E
e-mail 136:21
138:14
ear 126:24
earlier 17:18
63:2 75:18
84:3 85:8
116:14 150:9
152:22
early 45:23
ears 169:8,19
easier 173:13
easily 55:18
easy 45:7
49:22 141:11
easy-going
110:20
eat 49:19
editorial
110:1 116:20
education
155:2
effect
158:14,15,18
159:14 162:5
effort 23:11
elected 30:3
election
31:23 32:6,
12,18 33:3
37:7,14,20
61:8,17,20,
21,22
elections
32:20,25
eliminating
166:8
Martin O'Boyle
May 16, 2016
Elmore 61:13
email 116:7
embarrassment
159:10
emotional
155:5,24
156:12,21
157:1 162:25
emphasis
132:2
employee
14:16 30:4,7
102:20
employees
14:23 31:19
102:17
enchilada
24:12
end 48:4
64:15,23
77:18
enemy 80:10,
12,25
enforced
176:23
enforcing
60:25
engage 9:16
17:15
engaged 9:7,
20 16:18,21
23:16 52:9
engaging
37:6,12,19
49:6 157:15
England
106:25
enhance 66:14
101:13
enjoy 160:20
enjoying
153:14
enter 43:16
172:11
entered 17:13
76:7 172:24
entering
17:19
entire 39:18
65:24 69:21
110:4,5
134:17,24
146:12
entities
56:16,19,24
57:1,4 137:1,
5,8 145:25
entitled
56:11 60:13
90:3 156:3
entitlements
56:13
entity 73:23
74:23,24
75:4,12
87:15,21,24
88:22 89:8,18
entrance
166:18 167:25
entry 100:19
146:12
envisioned
107:16
episode 110:4
equals 40:9
erred 83:10
erroneously
154:20
error 155:22
172:8
errors 155:18
escorted
176:19
establish
57:6 107:12
177:22
estate 57:14,
18 59:1
172:12
event 48:25
49:25
events 8:15
U.S. LEGAL SUPPORT
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evidence
65:19 75:16,
17 107:6,12
108:2 117:13
123:15
177:21,25
evidenced
132:3
evident
123:8,9
exact 40:20
65:14 91:10
149:23
EXAMINATION
5:11 165:19
examine 57:3,
5
examined 5:9
159:13
Examiners
44:22 45:10
47:14 173:19
examples 28:1
excuse 8:1
150:20
exercising
60:22 64:17
81:1
exhibit 7:2,
4,15,25 41:4,
5,21,22
51:14,15,17
52:25 58:10
88:12 95:8,10
100:4,6,11
121:12 126:11
143:21,24
154:1,3
162:16,17
163:14
Exhibits 7:7
existence
115:16
exit 41:8
expedition
84:12
experience
28:6 69:9
9
155:2
expert 57:8
58:5,7 60:2
152:23 153:8
156:8,14,18,
19,23,25
157:3,11,12
158:8,13
161:6,8,13,
16,17,22
162:13
expert's
59:20 158:20
experts
161:16
explain 36:20
48:25 84:10
117:23 118:1
explained
117:24
explanation
118:5
expression
129:20
extent 116:8
125:17
extra 62:15
extremely
61:9
eyes 129:19
F
face 50:5,7
56:4 87:5,8
159:11
face-to-face
106:14
facing 50:9
fact 54:12
58:16 65:6,
18,20 70:25
75:22 82:16
91:23 105:6
107:13,14
109:24 117:14
122:13 131:6
136:5,19
Martin O'Boyle
May 16, 2016
140:22 162:1
169:2 173:1
177:23,25
facts 37:17
46:24 56:21
131:6
fair 6:22
67:21 73:2
89:12
falsely
35:10,16
familiar
77:25 87:18,
19
familiarize
7:18
family 16:2
27:14
farts 87:3
fashion
45:18,21
116:10 173:5
fast 6:1
131:22 174:1
faster 167:14
father 46:20
47:1
fault 25:14
February 33:7
109:13
federal 20:10
32:1,5 33:22
44:14 54:8
101:8
feel 66:23
73:14
feeling 65:16
66:10 69:13
80:18
fees 37:15
53:6,13,16,
19,22,23,24
54:25 55:6
137:6,9 141:3
feet 20:17
fellow 34:11
felon 48:4
felt 65:17
figure 57:10
figured 99:25
100:3
figures 58:1
file 17:25
50:13 77:13
80:2 95:20
136:5 141:17
146:11
168:10,11
filed 23:14
24:4 33:24
36:15,16
37:4,10,18
43:14 44:8
57:24 76:14
77:15 79:4
80:8 92:25
93:20 98:3
100:20 140:23
147:1,25
168:12 173:4,
10 176:3
filing 34:2
60:16 71:15,
17 74:17
75:19 79:6
80:1 106:20
110:16 112:23
113:1 132:2
138:7 140:22
141:1 142:6,
19 149:15
151:13,20
152:1,7,16,20
168:11
Film 92:3
filming 48:24
find 12:25
17:24 22:5
39:24 44:23
49:22 84:11
96:17 118:11
132:19 161:9,
10 175:14
U.S. LEGAL SUPPORT
(561) 835-0220
Z
fine 12:17
15:12 62:6
72:17 77:1
85:6 105:4
111:3 134:7
146:1 147:11
150:16,18
151:5 153:1
156:5
finger 150:21
finish 6:12
29:10 76:22
97:2 107:23,
24
finished
53:10
firsthand
113:17
fishing 84:12
fit 86:23
fix 93:25
171:10
fixing 171:24
172:3
flames 176:9
flavor 24:3
flew 18:11
23:3 52:12,15
85:8 86:13
91:1
Florida 17:24
45:25 46:3,7,
17 48:3 60:14
75:11 81:20
101:8 145:7,
19 166:9
175:21,25
176:2
flowing
110:20
flown 18:23,
25 22:2 23:3
52:20 86:1,4,
5 87:2 91:7
fly 18:12
86:15,16,19,
23 91:3
flying 90:17
91:13,19
92:16
focus 7:14,22
9:10 10:7,17
169:9 174:22
focusing 18:6
164:17
follow-up
64:11 145:22
148:12 165:11
170:22 172:4
177:14
font 29:7
forego 5:14
forget 22:24
118:18
forgot 126:8
form 34:7
74:4
formal 12:19
formed 68:19
87:15
forward 72:16
120:12 125:20
149:14
Foster 22:13,
22 90:18 91:4
92:17 177:11
Foster's
91:8,14
found 50:17
fourth 54:24
frankly 64:22
69:5 147:23
Fred 112:14
friend 112:14
165:3
friend's
108:16
friends
101:5,9,17,20
frivolous
37:5,11 50:18
front 70:20,
25 118:14,21
121:5 125:15
Martin O'Boyle
May 16, 2016
141:13
frustration
155:6
full 38:9
97:7
fully 76:20
153:10
funny 69:13
future 23:10
G
G -d 97:12
112:15 126:17
171:4
Ganger 65:10
165:22 167:18
169:10,25
170:7,15,19
171:3
Ganger's
165:25
gave 11:4
99:10 119:2
120:14,17
163:3
Gee 60:22
112:13
general 5:14
16:23 67:4
116:3 122:4
166:2 169:13,
16
generally
64:20 65:15
66:4 66:6,11
87:14 109:18
genesis
148:25
gentleman's
126:5
George 61:13
Gerald 101:14
get all 107:2
Gill 5:12
10:5 17:12,
20,21 41:3,21
46:19,25
51:13 62:3,5,
22,25 63:4
64:12 66:16
82:8 85:24
90:10 120:22
152:22
153:14,21,25
165:15,20
171:17 176:11
177:18
give 54:1
65:24 69:6
82:1,10 91:6
107:7 109:9,
11,14 111:22
118:6 119:21
120:2,3
125:13 139:25
149:22 163:3
166:2,3
giving 72:13
163:4
glad 152:24
156:9,16
globally
54:10
glossed
131:23
goings 39:18
Goldstein
62:7,9,14,18,
20 64:7,9
73:25 74:3,7,
11,13 76:11
81:2 82:3,5
88:9 89:9,15
95:3 97:13
99:24 108:7
110:10
133:16,25
135:10 142:7
155:10,16,19
163:16
177:14,17
good 5:13
26:19 27:9
57:23 62:2
63:2 64:8
U.S. LEGAL SUPPORT
(561) 835-0220
90:11 92:8
110:1 133:12
153:14
governing
42:4,11
grabbed 50:8
grades 17:1
graduate 69:7
graduated
47:2,5
granted 44:8,
16
graphics
38:17,19
51:25
grasping
57:21 134:6
great 92:14
greater 8:11
grievances
34:1,5
gross 59:8,
13,22
group 90:15
groupie
117:6,7,11,
12,15,20,21
118:2
groupies 61:1
117:18
groups 16:1
guarantee
69:17
guess 15:23
22:2 36:17
45:12,21
78:19,21
81:15 93:20
97:3,6 99:1,
2,14 107:2
111:6 112:6
116:9 139:2
guessing
129:25
guidelines
5:15
11
Gulf 9:5 12:9
13:6 19:7,11,
13,16 20:14
22:15,18
25:23 51:8
55:7,20
66:20,25
67:5,7,11,14,
22 68:1,4,6,
10 71:15
73:5,8 76:19
77:16 90:7,22
91:14,24
93:15 96:13
98:3 101:15
102:18,21
108:17,19,21
109:7 113:13
124:24 126:11
128:18 139:6
141:6 147:1,
25 149:16
163:14,18
165:5 171:15
176:17,20
guts 99:17
guy 48:4 62:2
65:3 103:17,
16 105:17,21
106:24 170:9
guys 63:3
109:24 118:24
138:14
i
hac 175:24
hacks 61:2
hairs 50:10,
11
half 31:7
halfway 55:19
hall 14:10
20:6 38:25
41:10,17
49:5,17 61:2
73:1,18
102:11 117:18
Martin O'Boyle
May 16, 2016
124:21,23
166:19
Halloween
93:12
hamburger
92:15 111:19
Hancock
106:24
handful 26:13
61:1
handwriting
154:6
hang 61:2
Hanna 96:11
98:7 128:14,
22 129:4,5,12
133:10 135:13
136:11,16,23
137:1 165.4
Hanna's
136:13 137:5,
9,14
happen 64:25
112:22
happened 49:4
130:21 167:6,
9,11 169:23
171:20
happy 125:17
157:13
harass 89:22
hard 9:22
29:3,12,22
34:12 66:1
166:23
Harvard 69:8
hat 10:4,5
hate 152:12
head 5:20 9:1
29:15 139:11
141:23
heading
178:10
health 162:6
healthcare
163:8
hear 92:23
98:5,11
103:19 112:14
118:22 126:20
127:2 130:23
132:10
heard 68:24
97:17 104:3
105:14 111:23
115:19 118:20
126:19 131:1
139:16,19,23
140:3,4,12,
17,20,21,24,
25
hearing 36:8
hearings 21:4
25:24 26:2
heart's 107:9
heated 110:21
heavy 40:18
hedges 40:13,
14 41:14
held 123:15
hell 24:7
59:21
helpful
165:18
Henry 109:19
hiding 16:25
high 17:2
30:17,18
40:23 124:12
highly 159:5
Highway 20:10
hire 157:11
158:8
hired 66:17
126:10
history 66:18
67:1
hit 61:4
79:11,13
hitting
115:21 141:23
(home 38:2,4
67:14,16,21
U.S. LEGAL SUPPORT
(561) 835-0220
12
71:13 72:2
74:8,14 75:2
homes 73:22,
23 74:24
honest 38:3
hood 71:4,7
hopes 37:5,12
horrible
60:23 61:1
hour 31:7
63:4
hours 42:23
62:11,20
145:23
house 38:17
39:20 51:25
68:11,15,16,
17 69:15,19
70:1,4,8,17,
20 71:1,7,25
73:3 87:12
111:12 113:16
139:25
houses 87:17
88:2,11,15,23
89:8,10,19
90:9
Hudson 10:5
90:10
human 45:5
humiliation
159:10
husband
108:16
hypotheticals
10:16
I
idea 29:15
34:25 69:6
71:23 93:2
123:4,11
151:15 172:7
identification
7:3,5 41:6,23
51:16,18
88:13 95:11
100:5 143:22
154:2
identified
126:19
identify 7:8
18:8 57:17
ill-conceived
127:10
imagine
124:17
immediately
66:3
impacted 11:7
impeachment
77:9
implied 27:2
impose 134:5
improper
18:15
inaccurate
82:21
inappropriate
47:24 74:2
inartful 32:4
inches 13:6
incidental
15:9 109:10
include 78:15
included
54:16,17,22
including
162:25 163:8
income 56:10
59:8,14,22,23
incorporate
89:8
incorporated
87:11,20,23
88:16
incorporating
89:18
incorrect
45:17,24
102:19
incurred 55:5
151:18 152:1
Martin O'Boyle
May 16, 2016
156:21 157:1
incurring
37:15
independent
49:25
indicating
35:8
indirectly
139:12,17,18,
19 140:15,20,
21
individual
8:6 50:8 80:6
135:21 145:10
166:11,12
individuals
75:23 102:15
104:18
106:11,18
influence
92:4
information
19:25 56:10,
12 59:4,6
84:19 130:23
131:5 135:21
156:16
informed
97:24 128:13,
16 133:7
initial 176:6
initially
7:14
injuries
156:1 162:25
163:12,21,25
164:14
injury 163:2,
4,5,8
ink 7:24
innocuous
37:24
inquire
137:13
inquiring
74:1,16
75:15,20
inside 118:16
121:4
insisted
143:5,8
instance
171:14
instruct
133:21 171:16
instructed
17:22
intangible
155:25 162:25
163:12,20,24
164:13
intend 157:11
163:22
intended
89:21
intent 74:1
intention
40:21 74:13,
15,16
intentions
74:12
interesting
28:6
interject
155:8
international
39:22,23
interpreting
86:8
interrogatorie
s 7:13 36:19,
21 58:11
95:9,18
132:19 173:12
interrogatory
8:5 13:9,13
15:24 24:15
35:2 36:23
52:24 59:5
128:11
132:13,22
135:17 163:15
164:3,8
interrupt
25:19 107:24
U.S. LEGAL SUPPORT
(561) 835-0220
13
interview
161:9
interviewed
39:15 52:4,7,
11,14,19
intonation
49:14
introduced
34:23
investigate
98:2
invite 56:18
invited 93:7,
8,10
involved
103:17,18
involvement
165:25 170:18
irritability
156:13
Isen 80:6
issue 109:8
126:1,2,3
issued 26:17
38:9
issues 29:1
67:7 68:5,7,
14,15 76:23
125:19,23
131:14
160:23,25
item 53:2
items 37:24
J
jail 23:10
103:10 107:1
January 49:20
59:9
JD 47:8
Jersey 48:2,
6,19 75:2,5,
13,23 76:15
77:12,17,20,
23,25 78:8
79:2 175:23
JF 86:21
91:20 92:2
177:1,6
Jo 101:16,17
Joan 61:14
68:22
Joanna 178:7
Joanne 15:1,6
90:9 98:7
99:15 101:16
Joel 101:14,
16
jogged 33:12
John 106:23,
24 109:19
join 97:7
178:21
joke 167:13
joking 62:21
167:12
Jonathan
44:22 45:10,
12 54:17
76:12
Jones 22:12,
22 90:17
91:4,8,14
92:17 103:21
177:11
Josh 64:9
Joshua 89:9,
14
judge 39:3,5,
7 44:9,12
84:24 145:21
146:2 155:13
165:14
Judson 92:2
July 96:10
June 51:1,9
juxtaposing
51:7,22 95:20
K
kills 27:15
Martin O'Boyle
May 16, 2016
kind 13:21
21:4,23
103:5,13
104:7 110:20
126:25 159:19
164:25
King 69:8
kitchen 122:7
123:22
124:21,25
126:20 167:4,
7,9,11,23
169:24
Klan 71:4,7
Klux 71:4,7
knew 30:24
90:15 98:20
99:13 131:1
177:7
knowledge
8:22 33:4
44:18 46:22
48:1,5,17
54:11 66:9
93:13 106:9
113:12,17
120:6 129:2
130:10 131:6
137:4 155:3
163:5,7 170:4
Ku 71:4,7
L
label 154:25
lady 27:14
122:19
language
142:3
late 25:12
167:12
launch 146:7
law 23:16
46:10 47:2,5,
17 77:25
177:20 178:3,
15,23
lawn 140:1
lawsuit 8:8,
16 9:12,17
10:12 16:12
17:16 18:19
24:9 25:9
32:1,2,5
33:13,14,15,
17,18,20
36:15 37:5,
10,11,15,18
40:2,5,8
50:13,16
55:12,14 56:5
96:14 97:2
112.8 136:5
142:19
lawsuits
33:24 34:2
40:7 60:12
96:12 98:3
130:18
lawyer 26:4
44:19 64:22
92:15 103:20
112:6 154:23
lawyers 99:3
122:16
lays 87:3
leads 75:17
league 112:16
leave 129:23
legal 36:4
45:21 47:21
53:19 131:14
137:5,9
legislators
124:13
letter 51:2,
4,10,19
143:4,7,12
149:18 176:12
letters 44:21
45:9 47:13
48:8,9,11,19
66:1 164:18,
22 173:18
178:22,25
U.S. LEGAL SUPPORT
(561) 835-0220
N
letting
107:23 169:4
liar 27:2
28:1
library
124:24
license 23:16
lie 93:22,24
lies 97:7
life 56:8
158:15,18,24
159:4 160:20
161:24 162:6
light 112:11
liking 69:16
limitation
84:20
limited
17:18,25
42:14 45:13
76:8 64:18
lines 126:22
list 10:1,11
93:21
listed 8:6
89:3 154:9
listen 103:12
169:22
listening
123:21 169:8,
19
litany 65:24
litigant
154:24
litigation
84:17 97:11
131:12 157:3,
11
live 61:21
108:17,19
113:10
lives 108:21
113:4
LLC 90:10
loan 122:18
local 17:23
30:14,16
39:19 52:8
116:20
locations
20:13
Lodonnie
61:13
London 39:21
lonely 153:13
long 56:16
62:13 66:18,
24 67:1 98:15
172:16
longer 62:7
Longport
75:2,5,13,23
76:15 77:12,
17 78:8,10,17
79:4,8,10
80:4,11,13,23
looked 40:1
loose 112:11
lose 57:21
153:8
loss 156:18,
20 159:11
160:18
lost 57:15,18
58:25 160:14,
20 172:18
lot 20:19,25
21:14 25:6,12
29:13 42:1,5,
9,19 43:4
97:20 130:25
142:1 150:9
151:7,9,10
168:24
Lou 128:15
133:10 137:20
loud 5:19 6:4
105:15
love 122:16
loves 169:18
low 57:12
lunch 62:4,5
64:15 109:2
Martin O'Boyle
May 16, 2016
luncheon 63:5
M
made 10:23
24:6 26:25
45:23 60:15,
18 66:23
67:17 70:11
75:19 78:7,9,
10 79:14,16,
23,24 82:17
88:1 91:4
96:15,18
101:21 102:8,
25 116:16
121:24 122:5,
9 125:4,5
126:14 127:7,
8,19 128:8,
14,17 129:10
131:19 133:7
134:14 135:3
136:11,12,17
137:21 138:11
139:7 140:12,
17 146:15,25
153:6 155:18
157:12 164:20
173:24 174:2,
3,18
magic 58:9
magistrate
38:8
magistrates
21:4
mail 165:1
mailed 29:16
maintain
58:15
majority
67:23
make 6:17,18
10:12,19
15:15,25
16:20 25:17
37:17,18 41:7
45:4 48:4
56:13 62:16
89:9 92:17,
20,22 93:6
94:10 110:11,
24 128:7
134:7 171:4
173:8
makes 58:24
102:11 114:3
making 78:16
124:3,15
135:22 149:13
man 34:12
167:18
manager 48:23
49:7 88:22
89:1,3,6
121:17
manner 146:3
March 33:7
51:2,19
mark 7:23
41:3121 88:9
95:7 96:11
98:7 128:5,14
133:10 148:16
marked 7:2,4,
7 41:5,22
51:15,17
88:12 95:10
100:4,11
128:10 143:21
154:1,3
162:16
markings
100:18,21
Marra 39:4,5,
7
Martin 5:8
64:3 172:11,
14,24
Marty 103:17
176:15
massing
68:23,24
matter 16:16,
17 36:1 44:13
54:12 60:13
U.S. LEGAL SUPPORT
(561) 835-0220
15
65:18 81:5,7
105:6 109:24
119:14 122:13
128:20 132:3
137:16 155:5,
13 162:24
163:12,24
164:13 168:5
169:2 173:1
mayor 10:6
27:23 38:21,
23,24 39:11
60:17 61:14
65:2,9 68:21
117:7,10,12,
14 178:8
meaning 7:23
27:6 66:7
means 34:3
35:4 65:9
89:5 142:1
159:2 178:20
meantime
101:13
media 39:15
51:24 52:1,3,
6,8,14,20
medical
126:1,2,3
160:9 162:13
meeting 15:4
26:5,6 27:5
49:21 61:13
96:24 113:20
123:2 124:15
128:25 129:7,
18 130:3,8,9,
14,15 131:17
132:1,6,12,15
134:10
135:13,14,20
136:2,7 140:8
141:15 143:1,
5,20 144:4
176:17,20
meetings
24:21,24
25:2,6,24
26:8,9,11,16,
18,20,25
27:11 28:10,
21 49:23
113:13 117:17
116:12 141:9
166:21,24
167:1,6
member 46:1,
2,3 74:24
75:4 137:2
163:9
members 16:2
139:19,22
memorize
115:15
memory 15:19
22:10 25:8
33:12 37:21
64:14 125:19
126:3,6
mental 155:6
mention 114:4
121:6
mentioned
85:10,13
103:21 109:5,
23 112:3
113:24,25
114:10 122:14
131:4 165:22
mentioning
110:1
merit 137:13
message 86:4
99:11 101:6
115:24 116:7,
11 138:17
met 146:7
147:2 148:1
MF'ING 170:11
microscope
103:6
mighty 65:2
million
122:15,17,19,
25 123:16
168:14,17,19
177:8
Martin O'Boyle
May 16, 2016
mind 8:10,25
44:18 61:3
111:2
mine 111:21
minor 37:24
minute 150:17
153:17,19
minutes 30:19
100:8 143:19
149:1
misled 87:25
mispronounced
126:9
misrecall
15:16
missed 6:5
missing 22:9
125:2
misstatement
176:13,15
mistake 45:4
mistaken
118:25
Mister 17:19
MIT 69:7
model 68:16
modification
11:10
moment 7:15
35:3 164:4
money 56:5,7
92:2 107:2
119:3 127:11
168:15
money.' 121:1
months 101:4
moon 138:16
Morgan 13:7,
10 14:17,23
65:2 117:3,5,
7,11,12,14
129:12 178:8,
9,11
morning 5:13
29:18 64:8
mosaic 98:15
110:11
motion 43:14,
25 44:3,8,16
55:2,3,7,9
mounted
122:15
mouth 80:15
141:20
150:23,24
mouthing
170:9,10
move 18:1
67:11 75:14
76:11,25
77:10 97:13
106:7 126:16
146:2 147:11
moved 74:22
75:21
mow 140:1
multiple
67:25 68:3,5,
7 98:2
multitude
159:9
myriad 101:17
103:1
N
named 96:13
99:13 102:15
103:20 139:5
175:6,9
names 87:16
101:19 103:2
107:7 110:1
126:3 139:5
national 24:6
nebulous
141:8
necessarily
24:11 66:6
161:14
needed 68:17
73:14 119:3
121:1 127:11
negative
U.S. LEGAL SUPPORT
(561) 835-0220
M
159:5,6,8
news 24:6
39:19,22
94:15 140:9
newspaper
30:14,16
nice 20:20
118:12
nickel 169:15
night 25:12
81:15 166:3
nods 5:21
non -certain
34:16
nonetheless
25:13 69:15
71:13
nonmonetary
156:10
nonresponsive
97:15
nonsensical
89:25
nose 50:10,11
note 143:12
144:3,8,10,
13,16,18,20,
23 146:3
149:3,4 165:2
notes 70:22,
23
notice 12:16
notices 15:12
number 8:11
18:8 36:8
43:13 93:13
95:25 96:2
128:12 132:25
133:3,4 164:3
171:9
numbers 96:2,
3 133:2
0
O'boyle 5:8,
13 7:6 17:7,
13,17,22
19:25 41:24
45:3,5 46:16,
23 52:23
54:17 61:23
62:6 63:3
64:3,8 73:25
74:5,9,12
76:13,21
77:11 78:19
82:1 97:18
103:17 105:1,
21,24 131:15
133:14,21
134:20 135:8
142:3,8,11,
16,17 145:22
146:6,19
147:10,18
148:4,12,18
151:1,13
155:8,12,18
156:17 157:8
158:8,22
160:1,25
162:17
163:13,17
165:11 167:15
170:25 171:13
172:11,14,24
176:13 177:13
178:18
O'connor 15:1
98:7,21,22,23
99:15 101:17
129:12 178:7
O'connor's
90:9
Where 14:1
54:21,22
60:19 93:20
96:11,12,22,
23,25 97:3,5
99:2 103:11
107:1 118:11
119:5 122:14
128:15,16,23
129:12,20,22
130:2,5,22
Martin O'Boyle
May 16, 2016
131:7 133:11
135:13 136:8
137:25 138:1,
8,10,15,19
149:20 165:3
166:17
Obama 60:4
object 74:4
76:2
objected 56:9
74:5,8
objecting
76:17
objection
58:15 74:15
76:4,12 85:16
137:12
objections
17:15 165:10
objects 59:4
obstinate
147:20,21
obtain 157:2
obtained 15:3
obtaining
156:18,19
obvious 31:10
49:14
occasion
16:16
occasions
101:3
occurred
37:14 107:13
120:16 123:5
125:24 128:24
131:17
October 15:4
143:1,4,20
144:4,9
offended 93:9
offered
129:22
office 29:7,8
81:10 82:18
83:6,8,12,16,
24 84:2
87:13,20,23
99:3 145:1,8,
18 170:3,15
officer 48:23
49:7
offices
124:24 145:2,
5
official
14:13,15,16
30:4 51:7
officials
18:13 31:19
oil 86:14
older 102:11
ole 57:24
on-going
55:13 56:14
online 24:21
29:3,11,22
39:25
Open 79:1,7
80:2,21
opened 129:19
opine 160:22,
24 161:10
opinion 80:16
81:5,7 90:1
150:6 165:24
169:10
opportunities
172:19,23
opposed 26:5
opposite 65:1
OPRA 77:20
78:2 79:1,3
OPRO 77:20
78:2
order 39:6
84:21 161:10
165:16 169:6
ordinance
9:2,4 10:2,3,
22,23,24
11:7,8,9,11,
12,21,23
12:1,2,8,11,
U.S. LEGAL SUPPORT
(561) 835-0220
17
14,18 21:13
40:12 41:18
42:4,11,21,24
43:6
ostracization
97:8 159:11
ostracized
65:15,17
66:10,12,24
150:5,6,12
151:7 152:1
out-of-court
128:17
outcome 40:2
44:2
outrageous
159:11
overrode
69:11
overseas
94:16
owned 74:14
owner 74:23
137:2
owns 73:23
74:8,24 75:12
i
p.m. 42:1,10,
18 43:4 63:5
64:2 100:8
pages 115:7,
15 133:1
paid 38:9
137:5,9
pain 156:21
162:25
paint 70:7,8
painted 51:25
71:4,18,21,24
painting
69:25 70:14
paintings
39:20
Palm 18:21
22:3 23:3
52:21 81:11
83:6,8 85:9
86:13,20 87:2
91:3
paper 28:25
29:1 40:17
116:21
paragraph
11:1 13:12
15:24 16:5,6,
8 25:22 43:12
44:23 50:22
57:13 100:25
101:2 135:19
147:5
paragraphs
8:6 132:4,8,
16 134:12,20
135:2
paraphrasing
171:7
pardon 46:2
59:18 78:20
81:6 87:22
90:13 108:18
122:22 129:8,
20 137:7
178:24
pariah 60:6,
20 75:19
park 21:13
parked 20:1,
6,9,14,24
21:8,9 40:22
41:17,25
42:18,23
43:3,8
parking
20:18,19,25
21:14,24
41:25 42:5,9,
11,19,20,24
43:4,5
parse 53:25
54:2
part 27:13
28:4 34:3
54:15 69:22
Martin O'Boyle
May 16, 2016
79:2 96:9
118:3 128:12
131:18 139:14
169:10
parties
54:10,14
parts 96:21
party's 59:6
pass 110:12
passage 42:4,
10,20 43:5
passed 9:2,4
10:2,23 11:8,
13 40:13
passing 103:5
109:17 126:25
past 52:7
Patriot 28:25
29:25 30:4,8,
13 31:15,19
Patriots
30:18 31:6
Patsy 102:10,
15,22 117:2
pencil 29:17
pending 111:5
135:12 172:9
Pennsylvania
48:2,7,18
people 24:7
27:15 28:2
29:13 39:12
60:15 68:18
60:10,13,25
88:5 92:9
98:20 99:12
103:1,3,7,13,
14,23 104:4,9
105:15,21
107:7 119:7,8
121:5 130:25
139:4 142:1
150:9,15
151:8,9,10
166:4,8
173:24 177:8
perceived
152:3,8,9
percent
34:15,18
perception
111:18,20
period 15:3
59:9 72:23
98:15 127:5,9
permanent
67:15,19
person 15:17
28:7,8 29:8
86:9 112:18,
19,20,21
115:24 116:6
118:2 130:7
136:21,22
138:9,13
161:2,4,6
personal
32:13 56:8
65:16 158:15,
18,24 163:5,6
personally
65:5 73:22
74:23 93:9,15
137:4,8 161:1
165:8 172:11,
14,24
personnel
33:4
persons
173:23
Pete 69:6
Peter 80:6
petitioning
33:25 34:4
37:6,13
phone 62:16
112:18 115:24
116:7 136:21
138:9,12
pick 126:25
127:1
picked 127:2
picking 29:7
pictures 71:3
piece 23:6,
18,23 40:17
U.S. LEGAL SUPPORT
(561) 835-0220
N
60:16,17
174:19
pile 30:14,17
place 12:1,2,
25 28:11,21
113:8
places 135:3
placing 11:21
plaintiff
25:23 35:10,
16 37:5,7,13
43:15 44:1
49:12,14
55:1,5,20,22
59:4 96:14
97:24 98:3
101:6,7
128:16 133:6
135:22 163:11
plaintiff's
44:22 45:10
55:2,21 96:2
Plaintiffs
128:13
plan 40:15
68:20,23
plane 86:19
planes 18:9,
11,12,18,23,
25 22:2 23:3
24:1,10,12,
14,19
planning 79:9
127:10
plans 73:3
plateful
25:10
play 104:1,7
120:20,21
166:21
pleading
23:7,12
pleasure
147:22
plethora
159:12,13
podium
149:19,20
point 47:20,
21 69:5 71:14
77:15 81:19
133:8 159:10
174:12 176:7
pointed 37:9
pointing
150:20
police 20:16
48:23 49:7
policy
176:22,25
political
13:5 14:13,
17,23
pop 139:11
Pope 9:5,13
12:9,11
portion 95:4
134:3 158:3,
5,11
position
158:23 161:3,
9,20,24
possibility
139:1
possibly
51:22 93:5
110:9
posted 70:19
posting 31:22
32:11 33:2
pot 122:16
practice
46:10 47:17
48:18 177:20
178:3,15,23
practices
15:25
practicing
16:3,11
precise
109:12 120:5
prefer 5:16
25:19
Martin O'Boyle
May 16, 2016
prepared
10:21 23:6
preparing
45:20
present 13:24
96:14 98:5
99:4,13 123:5
135:14 141:17
presently
66:9 174:16
pressing
50:6,7
pretty 10:11
31:9 61:6,19
68:8 69:4
100:23 110:1
123:8 139:3
prevented
176:16
previous
17:11 18:3
116:2 176:5
previously
56:9 64:4,12
69:25 82:19
90:16 91:1
128:10 148:19
150:8 156:17
171:25 172:1
174:12,15,16
primarily
67:22
primary
131:18 132:2,
7
principal
113:8
printout
88:10 89:4
prior 43:16
72:23 77:4
79:23 82:21,
25 83:12,16,
24 84:8
126:15
prison 111:25
private 33:5
privilege
74:4,8 131:12
154:17 171:16
172:6,10
privileged
74:6 154:22
155:9,15
156:3
pro 76:6,10
82:3,9,10
154:24 171:21
172:8 175:24
procedure
165:15
proceed
149:14
proceeding
36:4 122:12
123:19
proceedings
5:5
process 5:17
174:5
produced
154:18,20
155:11,16,22
professional
69:5
proffer 82:1,
10
proffering
82:12,14
prohibit 9:3
12:9
prohibited
9:5 10:4
project
69:21,22
promise
70:10,11
prompted 73:4
prong 157:3,
10,14,20,25
158:2,4,9,10
proof 107:6
proper 27:5
76:4 85:16
U.S. LEGAL SUPPORT
(561) 835-0220
19
property
75:12
proponents
166:6,7
proposed 38:1
146:5
protect 97:4
protected
9:7,11 10:17
11:6 16:16
protection
8:8,16 9:12,
17 18:19 19:9
protective
84:20
proud 34:12
prove 177:22
provide 25:20
49:2 103:2
125:18 139:5
146:6 153:2
156:9,16
157:13 159:7
provided 49:3
provider
163:9
providing
56:10 163:18
psychiatric
160:22,24
psychiatrist
159:15,16,17,
21
psychologist
159:22
public 25:24
26:25 49:11,
13 60:11,14
65:7 71:15,17
72:21,24
73:4,15,16,20
74:20 75:20
77:6,16,22
79:2,7 80:2,
21 81:9,20
82:16,20
83:1,5,13,16,
24 91:17
92:11 93:14
166:9 171:9,
24
published
29:1,2,3,11,
16,21
puke 92:17,
20,22
pull 25:4
pulled 19:20
pump 97:6
punching
141:19
punishment
37:7,13,19
purely 92:25
purported
157:19
purportedly
122:1
purports
121:17
purpose
122:23 176:2
pursuant 70:4
pursuits
75:20
pushed 19:19
put 8:21
11:14 23:10
27:4,8 30:17
38:16,17,20
39:2,12 40:25
50:9,10 70:25
71:3,13 75:18
80:14 92:13
93:19,21
96:21 97:11
118:19 155:1
171:8
putting
150:22,24
Cal
quasi-judicial
25:24 26:1,5
Martin O'Boyle
May 16, 2016
question
5:22,25 6:7,
13 9:8,23,24
16:9,15 18:2
19:1 21:15,
18,19,22
24:25 25:3
27:7 32:4
36:9,42:6
43:1 46:22
48:16 49:1,16
50:25 51:3
55:8 58:13
69:24 74:22
75:1,6,8,21,
25 76:16 77:3
78:18,22
81:25 83:21
84:6,14 65:17
89:24,25
90:4,5 94:17,
19,21 99:6,7
104:12,22,24,
25 105:1,3,
11,24 106:4,
6,9,10
107:21,22,23,
24 108:5,7,9
110:25 111:5
114:11,25
121:21 125:22
131:24 132:5,
23 133:15,17,
20 134:1,9,21
135:11,12
137:18 140:19
141:18 142:5,
11,15,16
145:13,15,16
146:14,22,23,
24 147:9,12,
14,18,23
148:5,6,10,
12,13 151:5
152:21,25
157:17,18
159:25 160:12
161:7,25
162:9,22,23
163:10,20
164:10 170:21
171:24 172:4
174:22 177:15
questioning
157:15,23
questions
5:18,19 7:14,
21,22 24:23
32:23 33:17
35:1 52:24
61:24 64:10,
13 78:5,24
81:23 64:16
85:1,24 97:21
104:2 123:7
131:14 145:23
146:19 147:13
148:5 151:1
157:18 159:19
161:18 165:21
167:14 177:1,
12 178:17
quickly 6:21
148:17
quote 72:11
120:24 148:3,
19
MZ
racket 126:23
racketeer
119:15,19
126:23
racketeering
103:18,19
109:20 111:24
112:2 123:20
racketeers
118:18 140:25
Rader 99:1
128:15,23
129:12 133:10
135:13 137:20
165:3
raised 76:12,
23
U.S. LEGAL SUPPORT
(561) 835-0220
20
ran 43:21
Randolph
90:10 102:10,
16,22 117:2,
10 118:7
119:17
Randolph's
120:16
random 103:23
105:15
raping 92:23
reached 35:11
read 7:17,21
22:6,9 27:3
28:2,5 43:18
50:3 53:11
95:1,3,4
97:16 104:13,
17,23 105:10,
23 106:6
107:18,19
108:5,8 110:2
133:16,18,20,
23 134:1,3,8,
17 143:5,10,
11 144:5,9,12
146:3,4,12
147:6,7
148:15,19
149:18 162:23
176:24
reading 53:8
155:9,10
ready 100:25
168:10
real 57:14,18
59:1 70:6
172:12
realize 68:25
rear 41:8
123:22 166:18
167:25
reason 6:9
32:17 46:4
80:18 88:19,
20,21 89:7
92:21 95:22
145:17 154:18
160:8 162:10
reasonable
81:3
reasons 106:7
recall 8:22
15:17 20:17
22:1,17 25:20
37:23 39:1
42:16 49:8,9,
23,24 64:18
66:18 68:1
79:6 80:6
81:9,13 83:11
85:12,19
86:1,12,19
87:1,10,20,23
91:19 114:9
119:13,17
120:7 125:4
127:13,22
130:13
137:23,24
138:4 142:22,
23,25 143:3,
16,18 146:9,
24 148:23
149:13 163:18
164:11 168:21
169:11
recalled
25:15
recalling
11:11 125:23
receipt 14:7
receive 21:23
165:1
received
11:17 15:11
151:19,24
164:18,22
recent 102:22
recess 8:2
63:5 111:4
recognition
118:4
recognize
100:12 154:5
Martin O'Boyle
May 16, 2016
recollection
29:14 30:2,6
31:18 49:25
79:25 81:16
83:19 88:15
126:13 127:4
129:3 144:1,
2,7
recollections
25:18
record 6:15
8:3 13:3
15:16 17:17
23:8 35:5
51:8 82:2,11
95:4 104:4,
15,17 114:13
128:5 134:3
142:7 146:5
147:6 148:20
162:23 174:21
176:14
recorded
49:13 50:6
recording
50:5
recordings
167:5,6
records 56:15
59:11,13
60:11,15 65:7
71:15,17
72:21,24
73:4,8,15,17,
20 74:1,17,
20,21 75:20
77:6,11,16,22
78:16 79:2,7
80:2,22
81:10,20
82:16,20
83:1,5,13,16,
25 84:7 88:1
93:14 149:4,
7,10,11 166:9
171:9,25
recross
153:21,25
177:19
RECROSS -
EXAMINATION
177:16
red 40:18
REDIRECT
165:19
redo 68:11
redoing 68:15
redress 34:1,
5
Reeve 101:22
108:15 109:5,
16,21,23,25
110:7,14,17
116:15,20,24
refer 16:14
17:22 117:10
reference
15:25 28:24
37:4 47:14
48:22 55:15
91:4 94:10122
173:17 177:2
referenced
18:7 19:2
20:15 36:19,
21 37:18 40:3
48:11 51:10,
20 57:13
references
25:22 31:21
36:7 44:20
45:8 46:21
50:22 51:1
referencing
19:22
referred
27:25 77:23
132:12 171:25
referring
11:3,25 13:2
23:13,19 26:1
27:10,12 28:3
35:12,15 39:9
51:4 53:16,
18,21 55:4,10
56:1 130:15
132:15 133:8
U.S. LEGAL SUPPORT
(561) 835-0220
21
134:13 135:2,
14 136:3
139:17 145:3,
6,9,12,25
156:5 157:14,
20,25 158:4
177:5,7,10
178:13
refers 35:9
43:17 53:5,12
54:7,25
reflect
70:22,23
88:25 142:7
reflected
9:16 10:10,18
13:8
reflecting
122:21,24
refresh 64:13
88:14 126:13
144:1,7
refusal 78:23
refusals
165:10
refuse 106:1
151:3 171:23
refusing
84:14,23
105:3,5
108:12,14
114:12,14
142:22 145:14
162:4,10
regular 92:5,
6
relate 157:19
related 92:25
121:25 152:18
157:24
relation 80:1
relations
130:6 131:7
relaxing
111:21
relevance
58:16,18,19,
20 76:1,4
85:15,16
137:12
relevant
58:24 59:6
73:24 75:10,
16,22 85:1
137:15 145:17
155:3
relief 36:15
religion
16:1,3,11
17:5
rely 100:23
149:1 175:18
remember
14:21,25 15:1
20:12 21:3
22:10,12,23
23:15 24:2
27:7 39:3,4
43:10 50:3,4
84:2 86:22
96:19 98:19
109:9 110:19,
20 115:25
116:23,24
117:1 121:3
122:11 125:21
126:5 127:25
128:1 131:3
149:17 150:15
166:23 168:9,
13 169:21
170:10,11
172:8 174:20
remembering
109:6,7
reminiscent
38:23
remodel 69:15
73:3
remodeled
69:19
remodeling
70:3
removed 33:5
renovations
113:16
Martin O'Boyle
May 16, 2016
repeat 135:10
repeated
131:5,9
rephrase
142:10 176:1
report 59:20
124:16 152:23
156:8 157:12
161:17
reporter 5:3,
19 95:5
104:17,23
105:8,10
106:6 133:22
134:1,4,8
135:11
represent
64:9 176:2
representation
55:1 90:6,22
91:14 92:24
representative
30:8
representative
s 14:22
represented
111:11 136:23
137:1 173:5,
25 174:11
175:1,3,4,6,
17,20,22
representing
55:6 82:5
91:24 96:11
128:15 133:10
reputation
60:5 76:24
77:2 150:2
reputational
55:23
request
73:17,20 74:1
77:6 78:7
82:17 83:1
88:1 132:25
133:4 143:9
164:2,5,6
requested
144:5,8
requesting
59:3,6
requests 65:7
71:15,17
72:21,24
73:5,8,15
74:21 77:12,
16,22 78:9,
10,16 79:3,7,
14,17,24
80:22 81:10,
20 82:17,20
83:5,13,17,25
84:7 93:14
171:9
required
17:25
reserve 165:9
reside 67:22
residence
67:15,19
resident 80:3
residents
128:18 139:6
respect 8:5
13:17 38:13
40:11 53:2
60:5 84:21
134:22 153:5
154:10 155:5,
24 156:11,18,
23 157:4
158:9 159:22
173:3
respond 155:1
response 16:7
31:11 95:25
98:2 103:12
128:12 132:25
133:4,6 146:8
147:3 148:1
157:21 158:1
162:22
163:10,19
164:2
U.S. LEGAL SUPPORT
(561) 835-0220
22
responses
66:14 95:8,17
128:11
132:13,22
responsibility
158:21
responsible
92:9
responsive
95:23
rest 97:14,18
restraint
43:16
restroom
153:20
result 57:19
130:1 149:15
151:20,24
160:14,21
162:7
resulted 40:6
resulting
152:15
resumed 64:4
retain 156:24
retaliate
23:25 24:10
89:21
retaliated
9:21 16:3,11,
19,22
retaliation
16:14,17 23:1
24:16,18 25:8
26:23 32:9
33:8 89:23
90:6 173:9
retaliatory
9:9 55:21
retrofit
38:2,4,13,14
returned
155:20,22
review 7:16
26:14 35:3
reviewed
17:24
rich 107:3
Richman
101:14 112:7,
10
Richman's
113:25
RICO 24:5,9,
16 50:22,24
54:8,15 57:24
96:14 101:8
103:8 105:18,
22 106:15,21
107:10 108:4
109:20 110:5,
16 112:24
114:6,17,21
115:3,4,6,11,
12,14,16
116:5,15
121:20,25
122:1,12
123:19 126:23
127:10 129:23
130:19,20
135:4,23
138:7 140:22
141:1,5,17
142:6,19
146:5,11
147:2,25
149:15
151:14,20
152:1,7,16,20
166:7 168:7,
12
rid 97:10
119:4
rights 60:23,
25 64:18,21
81:1 166:8
rigid 111:20
ringing
107:17
rise 163:3
Rita 31:3
102:12,16
127:17
Martin O'Boyle
May 16, 2016
road 41:12
172:16
Robert 64:10
rotten 86:21
rough 40:16
71:23
rule 44:9
45:15
rules 17:23
45:16 171:4
run 6:20
running 11:1
31:21 32:10,
16 37:7,14,20
107:8,17
108:2 109:19
S
saddened
61:25
sake 59:12
salesman 69:1
92:15
Salvation
122:19
sanction
43:14,15 44:1
sanctions
55:2,4,9
sat 174:18
Satire 71:12
satisfaction
149:22
Save 13:6
school 17:2
47:3,6
scolded 12:20
13:18,19
15:19 28:7
screaming
107:8
screwed
129:21
screwing
96:22 97:10
129:20 130:2
Sea 41:12
seconds
119:25
seek 162:24
seeking 8:8,
16 9:11,17
18:18 19:9
56:5,7,11
85:3 155:4
156:8,11
163:20,23
172:18
sells 27:14
send 73:4,15
77:11 155:21
sending 72:21
73:4,7 83:13,
16,24
sense 25:17
45:21,22
114:3 161:11
169:18
sentence
15:23 16:7
34:4 37:4,11
53:5,12,18
54:6,25 97:14
111:25 135:19
separate
105:1 178:14
September
15:5 49:17
128:14,21,24
129:7,10,16
130:15 131:18
132:1,6,10
133:9 134:9
135:12,24,25
136:2
series 5:18
served 81:13
93:15
serves 137:13
service 92:11
serving 80:22
81:9
SESSION 64:1
U.S. LEGAL SUPPORT
(561) 835-0220
23
set 85:3 86:5
95:9,17
115:4,5,12,14
131:20 132:8
settle 169:3
settlement
35:11,23
36:2,13,25
40:6;9 72:2,
18 136:7
sexually
130:21
shakes 5:20
shaking
106:25
shareholder
75:5
shit 23:6,18,
23 60:17
174:19
short 15:9
46:24 78:1
92:14
shortcut
147:8
shortly 88:1
98:13,14
shot 170:24
shoulder 61:4
show 38:10
58:2 82:18
91:6 95:7
123:14 131:24
154:3 167:6,
9111 173:11
showed 122:15
168:17
showing 94:16
100:19
123:16,18
shows 40:17
Shrek 70:1,8,
14
Shrek-like
38:20
sick 107:19
side 37:22
39:20 65:1
70:1,8,17
71:24 79:21
97:6 131:2
sides 79:11,
13
Siemens 37:2
sight 153:9
sign 9:4
10:2,3,22,23,
24 11:7,8,9,
10,12 12:1,2,
8,11,14,18,23
70:25 71:3
123:14,15
171:8,10,24
172:4 176:5,6
signature 7:9
95:14
signatures
7:11
signed 178:2,
3,6,9,11
significant
8:11
signs 11:2,5,
16,21 22:11
31:22 32:6,11
33:2,4,6,9,10
70:19 177:3
similar 87:16
simple 147:18
singularly
11:10
sir 6:8 80:7
108:6 120:20
160:5
sissy 43:22
sit 11:11
22:4 65:23
98:9,10
102:12 115:21
116:18 124:12
125:13 158:17
159:1 170:1
sitting 9:23
38:22 99:16
Martin O'Boyle
May 16, 2016
102:14 124:9
166:23
size 13:5
sketch 40:16
Skip 15:2,6
90:10
slander 75:11
76:18 80:3,9
81:22 132:7
137:10 145:19
153:9
slap 56:3
sleep 97:12
160:14,18
sleeplessness
155:7,25
156:13
slew 98:20
slice 36:1
slightly
139:2
slow 131:23
slowly 52:18
smacked 24:8
smart 124:7
smarter
168:24
smearing
55:21
smelly 87:3
smile 35:4
87:5,7
smiling
139:24
Smith 55:1
Smith's 55:6
smoother
97:20
sober 87:11,
17 88:2,11,
15,23 89:8,
10,18 90:9
socially 56:2
sole 88:22
89:1,6
solemnly 5:3
son 23:9,10,
15 44:22
45:10,12
98:2,9 99:17
116:25 141:23
175:20,22
son's 99:3
sort 12:4
96:20 103:5
108:25 111:21
118:20,23
174:7
sought 36:15
160:9
sound 87:17
sounds 84:12
sources
125:15
Southern
17:23 46:17
speak 28:21
30:12 39:18
61:7
speaking 6:13
11:10 17:15
30:3
special
165:16
specific 7:19
23:1 26:23
30:2,6 31:18
32:9 57:17
104:19 110:17
112:9 119:9,
21 122:5
125:15,16
138:23 146:14
152:18 174:8
specifically
14:21 24:1,
13,17 104:5,8
105:19
106:12,14
108:23 114:41
10 121:25
127:13
134:12,19
135:25 136:16
U.S. LEGAL SUPPORT
(561) 835-0220
24
138:22
140:12,17
143:23 148:16
162:22
specifics
159:7 166:5
speech 9:3,
18,19 10:5,6
18:7 37:6,12,
19,25 43:17
119:2 120:13,
15,17,25
speeches 66:1
67:1
spell 101:23
102:1
spend 122:25
spending
169:14
spent 9:25
spirited
15:10
spoke 25:23
51:24 52:2,3,
5 106:12
116:25
spoken 14:12
26:8,11 29:24
31:14 101:4,
11
Stacey 33:3
34:10,11
stage 103:6
stale 37:22
stand 77:24
78:3
standard 76:2
85:17
standing
48:24 49:8
stands 83:3
118:8
Star 30:16
109:25 116:21
start 6:13
21:16 28:20
42:15 71:14
73:4 78:16
142:17 150:19
started 67:8
71:17 72:21
73:7 74:17
82:9
starters 74:3
starting
73:10
starts 53:1
state 7:12
47:17 52:12,
15,21 54:8
55:20 84:1
126:19 135:25
163:1 175:25
State's 81:10
82:18 83:6,
12,15,24
stated 17:17
27:3,4 64:20
65:15 86:7,
11,13,20
87:15 91:8
109:18 131:10
139:7 163:11
177:18
statement
16:23 18:15
41:1 45:23
78:23 98:1
122:4,5,9
124:3,15,20
125:3,5
126:18 127:7,
8 146:15
148:8 149:13
166:3 175:13,
14
statements
26:24 67:2
76:8 96:15,18
98:6,12,18
101:21 102:8,
24 108:24
111:16 115:19
116:16 119:11
120:16
Martin O'Boyle
May 16, 2016
121:19,23,24
122:1 126:14
127:19,20
128:7,14,17,
19 129:9
131:19 133:8
134:11,14
135:4 136:11,
12,17 137:20
138:2,11
139:7,23
140:12,17
150:3 151:18,
25 152:6,15,
19 153:3,6
158:19 159:3
160:3,10,15,
21 162:7
164:20,24
states 38:6
46:9 68:18
69:17,20
78:12 96:10
97:23 128:13
177:9
stating 87:3
119:18
station 20:16
statute 49:16
79:2 106:16
107:10 108:4
steak 49:19
111:19
step 111:2
steps 112:12
stick 110:25
120:1
stinkers
48:21
stole 31:10
33:10
stood 92:19
166:17
stop 37:5,12,
19 112:15
stopped 170:7
stops 86:7
stories 39:25
straight
99:22
Stream 9:5
12:9 13:7
19:7,11,13,17
20:14 22:15,
18 25:24 51:8
66:20,25
67:5,8,12,15,
22 68:1,4,6,
10 71:16
73:5,8 76:19
77:17 90:7,22
91:15,24
93:15 96:13
98:4 101:15
102:18,21
108:17,19,21
109:7 113:13
124:24 126:11
128:18 139:6
141:6 147:1,
25 163:19
165:5 171:15
176:17,20
Stream's
55:7,20
149:16 163:14
street 65:2
97:4 112:12
118:20 130:1
stress 162:25
strike 67:9
76:12 97:13
126:16
strong 50:5
struggle
109:3
struggling
85:14
stuck 171:1
stuff 21:5
112:5
subject 32:1
119:14 168:5
174:25
U.S. LEGAL SUPPORT
(561) 835-0220
25
submit
144:10,15
165:14
submitted
143:3,7
144:3,8,11,13
149:5 178:4,
22,25
subparagraph
13:8 16:8
18:6 19:22
25:23 28:24
31:21 33:24
34:9 35:9
40:3,11 43:12
44:20,25
45:1,8 48:12,
22 49:3 51:10
173:17
substance
31:4 129:14,
15
substantial
55:22
subtle 108:25
subtleties
46:12
Sucked 107:5
sucking 169:6
sue 121:10
178:21
suffer 163:2
suffering
156:12,22
163:1
suggest
139:11
suggested
144:11
suggestion
110:24
suit 57:24
75:11 76:14,
18,20 77:13
80:9 81:22
84:10 103:8
114:6,18,21
115:3,4,6,11,
12,14,16
116:5,15
122:1 123:19
127:11 129:23
137:11 140:22
141:1,6,17
142:6 145:19
147:2,25
151:14,20
152:2,7,16,20
158:9,11
171:16
suits 32:14
91:24 169:4
Sunbiz 88:10
superior 45:6
Supper 113:21
supply 152:24
support 65:19
117:14 118:17
supports 66:9
supposed
165:16
suppository
40:25
Supreme 44:14
surprised
68:25
suspect 93:23
swear 5:3
Sweet 86:14,
21 87:11,17
88:8,10,15,23
89:8,10,17,18
90:9,11,12,14
Sweetapple
22:14 23:6
41:1 57:24
60:16 62:4
64:10 65:8
85:10 87:3
88:6 89:22
93:23 96:10
97:2,25 98:8,
16 99:15,19,
22 101:4,10
103:9,20,24
104:5,8,19
Martin O'Boyle
May 16, 2016
105:17,20
106:13,23
107:3,8,17
108:2,24
109:18 110:18
112:3,7,10
115:20 116:6,
16 119:2,11
120:3,14,17
121:1,24
125:21
126:10,15
128:8,13,16,
22 129:12
130:1 131:20
132:8 133:7
134:14,23
135:3,20,22
136:6,12,17
137:21 138:2,
11,20,22
139:7 140:13,
18 141:2
150:4 151:19
152:6,19
153:6 159:3
160:4,11,15,
21,25 162:8
164:20
174:18,20
176:11
177:19,22
178:20
Sweetapple's
88:3 90:6
92:22,24
95:9,17 96:23
111:16 113:25
114:4,9
121:7,19
122:6 127:3,
20 129:21
130:6,22
131:7 151:24
152:15 153:3
158:19 164:23
Sweetapples
169:4
sworn 5:9
64:4
Syria 94:1,3,
5,7,8,23,24
OA
table 124:8,
9,10
taking 38:25
122:20 169:1
talk 6:14
10:8 11:1
17:8 24:14
29:10 30:21,
25 33:14
159:15 169:18
176:14
talked 24:7,
18 166:17,19,
20 169:20,22,
23
talking 6:24
10:15 12:11
14:15 38:1
48:9 71:6
90:24 99:21
103:9 119:24
122:12 171:14
174:1
talks 9:8
24:15 40:11
tall 41:14
Tallahassee
166:14 167:9,
11,16,19
169:23
Taller 41:15
tape 49:9
tapes 119:1
169:22
Taylor
102:12,16
127:17,21
128:6
team 68:19
69:6
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technical
45:14
telling 66:4
108:3 149:24
ten 100:7
119:25
Tennis 109:7
tense 110:21
112:13
term 15:19
68:24 141:6
142:4,12
terms 86:8
testified
5:10 64:5,12,
16 66:8,11,17
69:25 72:6
74:19 75:18
77:4 83:4
85:8,25 90:16
91:1 105:14
107:16 113:23
114:16,22
115:2,11
116:14 127:19
150:8 156:17
158:8 171:7
172:3
testify
104:15,16
156:20,25
158:23 159:2
161:23 166:15
testifying
64:19 167:17
testimony
82:19,23,25
86:9 102:4,9
105:15 117:8
145:23
text 115:24
116:7,11
138:17
texts 116:12
Thanksgiving
93:8,10
theme 91:11
110:2 111:22
139:3 166:5
169:16 170:12
themed 169:13
therapy 163:7
thing 34:8
45:16 57:1
92:8,9 94:1,
3,5,11,22
118:8 121:9
129:13
things 7:20
9:1 10:9
17:10 24:15
64:12 75:18
85:2,3 125:23
126:8 142:1
161:15 164:25
166:20 167:20
169:7,20
thinking
32:24 71:8
144:17
thought 10:13
11:24 15:14
28:19 32:19
45:6 52:5
54:1 73:9,12,
13 84:3 87:8
88:7 120:22
123:25
Thrasher
12:19 13:18
14:12 15:18
30:11,12 31:2
39:10 48:23
50:5,9 60:18
102:10,16
121:14,15,19,
23 123:15
126:14,19,20
127:13
threat
146:10,25
147:24 148:2,
9
threatening
98:8
Martin O'Boyle
May 16, 2016
threats 21:11
135:23
threefold
97:9
Thug 71:5,11
thugs 32:14
70:20 71:1
time 8:22
15:3,20 21:6,
10 25:13
29:21 43:20
49:4 52:17
53:9 61:15,24
62:22,24
66:13,18
67:23 68:9,21
71:14,18
72:18,23
77:15 81:19
82:17 98:15
106:3 125:7,8
127:5,9 134:6
139:10 156:9
165:9 166:18
168:2 177:13
timeframe
74:18 119:21
125:5
timeline
11:18 15:5
times 117:22
118:1 120:9
125:10 131:10
147:10,14
timing 84:7
today 11:12
15:21 45:13
65:23 83:20
84:21 93:3
98:10 116:18
120:9 125:13
131:10 158:17
159:1 162:6
170:1,25
today's 94:13
told 22:20
23:7 38:3
40:4 61:16
65:21 66:4
96:19 98:18,
22 99:14
102:24
103:24,25
104:3,5,8,9,
10,11,21
106:14 110:7
111:25 119:10
121:23 123:11
129:18 130:3,
5,7,14 147:15
150:17 166:4
170:5
Tom 61:13
tone 170:11
top 9:1 38:22
100:18,21
158:6
touch 52:1
towed 21:1,21
6,7,10 42:91
12,20 43:5
town 9:2,4,9,
20 10:8 11:25
12:16 14:9,
13,15,16,22
15:13 16:2,
10,19,22
18:13,15
19:6,11,13,16
20:14,19,24
21:12,13,14
22:15,18
23:2,25 24:4,
21,24 25:2,5,
12 26:5,9,17,
24 27:11
28:9,22 29:24
30:3,7 31:15,
19,22 32:5,
10,11,14,16
33:2,4,6,9,25
34:3 35:9,12,
16,19,24
37:4,10,16,23
38:1,25
41:10,17,25
42:5,9,19
U.S. LEGAL SUPPORT
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43:3,14 48:23
49:5,7,17,21,
23 51:8 65:4
66:20,23,25
67:5,7,11,14
68:1,4,6,9
71:15 72:21,
24 73:1,5,8
75:18,23
76:14,19
77:12,16
78:8,10,16
79:4,7,9
80:3,23 88:2
90:7,22
91:14,24
92:19,23,24
93:1,15,25
94:3,11,22
96:13 97:6
102:11,17,20
106:20,23
107:1,8,17
108:2 109:22
116:22 119:8
120:4 121:17
124:21,23
126:11 131:2
136:6,7
139:6,15,19,
22 140:21,25
141:6,14
142:5,17,19
143:5,10,12
144:9 146:10
147:1,24
149:1,14
150:10,13
151:7 163:14,
18 165:3,4
166:10,19
167:21 169:18
171:15
176:17,19
town's 42:11
43:5 54:7
56:20,23
57:19 58:3
59:2,25 112:6
113:24 149:7,
10 164:2,6,8
town -wide
139:13,16
towns 78:11
94:16
township
56:25
townspeople
102:3,5,7
track 93:17
trailer 68:3
transformed
68:17
transpire
112:18
transpired
129:16 130:14
treated
159:21
treatment
160:3,9 163:8
trees 27:8
40:19,21,23
trial 44:12
truck 12:24
19:3,10,12,21
20:14,24 21:2
40:12,22 42:8
43:3,8,11
trucks 18:7
19:3,5
true 20:21
46:6 77:10
88:17 95:16,
23 131:25
178:19
trustworthy
35:10,17
truth 5:4,5,6
137:14 149:24
turn 69:4
turned 38:1
TV 94:9,15
Tweedle 39:2,
3,12,13
71:18,19,22,
Martin O'Boyle
May 16, 2016
24
type 12:16
26:11 78:7
116:9 155:25
U
Uh-huh 117:9
165:23 173:20
Uh-hum 53:15
102:6 111:10
172:20
ultimate
46:24
unable 159:2
unauthorized
177:20 178:3,
15,23
understand
5:23 6:6,16
28:15 33:1
34:2 36:10
41:7 42:25
84:22,25
85:5,15 98:17
126:5 132:23
141:4 145:11
147:15,17,19
151:21 157:17
158:13 167:20
174:5
understanding
11:24 12:3,5
34:16 36:14,
20 78:1 85:19
97:1 101:18
understood
5:25 124:11
unfriendly
146:8 147:2
146:1
unheard 24:5
United 38:5
68:18 69:16,
20 78:11
177:8
University
47:9,25
unpracticed
23:16
untrue 47:23
unwilling
97:1
UPL 44:21
45:9 47:12
48:7 173:18
176:8
utilize
120:12
V
vague 141:6
VDF 52:5
vehicle 20:18
21:14
vehicles
41:16,25
42:7,18 43:2
veracity
137:14
verbally 5:19
6:4 35:6
172:21
versus 72:9
151:13,25
152:3
vestibule
118:21 121:5
vice 38:21
175:24
videos 24:20
25:2
view 32:13
47:20,21 69:5
viewpoint
161:14
violated
101:7 105:18
106:15 107:10
108:4
violating
105:22
violation
10:23 11:14
U.S. LEGAL SUPPORT
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12:18 13:21
15:12 41:17
121:25
violations
79:9,18,20
121:20
virtually
11:14 54:13
visibility
40:21
voted 61:7,9
69:16
votes 61:16
W
wait 153:8
171:13
waiting
133:14
walk 60:21,24
65:1 88:5
walker 6:18
walking 109:1
112:12
wall 71:6
115:21
wanted 46:20,
23,25 58:1
61:22 97:2,6
122:25 129:21
144:11
warning
146:7,10,25
147:24
warrants
89:24
wash 140:1
watch 22:24
94:14 117:16
watched 94:9
117:16
watching
91:21
wear 15:20
wearing
13:18,21
14:25 15:13
website 88:10
141:12
week 98:14
126:6
West 18:21
whining 88:6
whips 13:23
whistle 141:3
wide 139:15
wife 6:19
20:18,23
21:24 34:23,
24 96:23
97:4,10
129:21 130:2,
6,22 131:8
wife's 108:16
William
102:10,16
win 61:20
wine 43:22
winter 67:16
wiretapping
49:15
wished 146:6
woman 68:21
102:11 118:12
won 61:20
wonderful
34:11
word 12:21
13:19 50:24
51:12 127:1,
14 142:8
148:2,9
152:8,9
words 27:4
65:15 66:7
71:4 80:15
91:10 92:14
118:19 138:23
149:24
150:22,24
164:9
work 5:15
34:14 169:7
Martin O'Boyle
May 16, 2016
working 112:8
works 34:12,
17 113:6,7
174:6
world 80:24
94:13 103:8
111:23 117:19
169:4
Wow 131:4
writ 37:1
write 154:7
writing
115:24 136:20
149:18 155:21
written 15:11
38:9 127:23,
24 138:9
154:15
164:15,19,22
wrong 23:11
43:10 57:20
87:14
wrote 43:22,
24 110:1
116:20 133:6
is
year 47:10
59:9 111:12,
25 141:10
years 32:18
33:1 34:20
37:21 56:18
58:23 59:10,
11,13 61:21
65:25 67:20
68:24 69:2,9,
10 109:3,10,
12 117:19
126:7
yellow 40:18
young 34:12
Z
zoning 79:8,
9,17,20
U.S. LEGAL SUPPORT
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