HomeMy Public PortalAboutPRR 16-2223RECORDS REQUEST (the "Request")
Date of Request: 06.05.2016
Requestor's Request ID#: 1244
REQUESTEE: Custodian of Records Sweetonle, Broeker & Varkas
Custodian of Records Jones, Foster. Johnston & Stubbs
Custodian of Records Town of Gulf Stream
Custodian of Records Richman Greer, P.A.
Custodian of Records Cole Scott & Kissane (Palm Beach Lakes)
Custodian of Records Cole Scott & Kissane. (Lakeview Avenue)
Custodian of Records Johnson Anselmo Murdoch Burke Piper & Hochman. P.A.
REQUESTOR: Martin E. O'Boyle
REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com
Fax: 954-360-0807 or Contact Records Custodian at records(i commerce-groumcom:
Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST: Provide copies of all records provided to the Town of Gulf Stream from Joel Chandler
between the period of January 1. 2014 and the date of this Request.
ADDITIONAL INFORMATION REGARDING REQUEST: The term "Town of Gulf Stream" shall
mean each of the following: the Town of Gulf Stream. its Commissioners. its Manager, its employees, its
Police Department, its Police Officers its counsel and the following law firms: Sweetapple, Broeker
& Varkas; Richman Greer. PA: and Jones. Foster. Johnston & Stubbs. (including, without limitation, the
attorneys, employees and partners of each such law firm.)
THIS REQUEST IS MADE PURSUANT TO ARTICLE 1, SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119,
FLORIDASTATUTES
IF THE PUBLIC RECORDS BEING SOUGHT ARE MAINTAINED BY YOUR AGENCY IN AN ELECTRONIC FORMAT PLEASE
PRODUCE THE RECORDS IN THE ORIGINAL ELECTRONIC FORMAT IN WHICH THEY WERE CREATED OR RECEIVED.
SEE 5I19.01(2)(F), FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS
RECORDS REQUEST BE FULFILLED ON 11 X 17 PAPER. NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES
SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4) (a) (2)
ALSO PLEASE TAKE NOTE OF §I19.0701(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IF A CIVIL ACTION
IS INSTITUTED WITHIN THE 30 -DAY PERIOD TO ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO
THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF THE RECORD EXCEPT BY
ORDER OF A COURT OF COMPETENT JURISDICTION AFTER NOTICE TO ALL AFFECTED PARTIES."
ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E-MAIL DELIVERY.
PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE.
It will be required that the Requestor approve orany costs, asserted by the Agency (as defined In Florida Statute, Chapter 119.01
(Definitions)), in advance orany costs Imposed to the Requesmr by the Agency.
`BY FULFILLING THIS RECORDS REQUEST, THE AGENCY ACKNOWLEDGES THAT THE RESPONSIVE DOCUMENTS
ARE "PUBLIC RECORDS" AS DEFINED IN CHAPTER 119, FLORIDA STATUTES".
UP/NP/FLRR
07.28.2015
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
June 6, 2016
Martin E. O'Boyle [mail to: records@commerce-group.com]
Re: GS #2222 (PRR 1239), #2223 (PRR 1244), #2224 (PRR 1245), #2225 (PRR 1241), #2227
(PRR 1242), #2228 (PRR 1243)
Please provide all transcripts, including all exhibits, (including any and all portions of the
transcripts and any copies which have not yet been certified) (the "Transcripts received by the
Town of Gulf Stream) resulting from the deposition of Anthony Granziano dated June 1, 2016
relating to the litigation styled: Martin O'Boyle vs Robert Sweetapple and the Town of Gulf Stream.
Case NO. 9:14-CV-81250-KAM. The term "Town of Gulf Stream" shall mean each of the
following: the Town of Gulf Stream, its commissioners, its manager, its employees, its police
department, its police officers and its councel and the following law firms: Sweetapple, Broeker
& Varkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without
limitation, the attorneys, employees and partners of each such law firm).
Provide copies of all records provided to the Town of Gulf Stream from Joel Chandler between
the period of January 1, 2014 and the date of this request. The term "Town of Gulf Stream" shall
mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its
employees, its police department, its police officers and its councel and the following law firms:
Sweetapple, Broeker & Varkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs,
(including, without limitation, the attorneys, employees and partners of each such law firm).
Provide copies of all records provided by the Town of Gulf Stream to Joel Chandler between the
period of January 1, 2014 and the date of this request. The term "Town of Gulf Stream"shall mean
each of the following: the Town of Gulf Stream, its commissioners, its manager, its employees, its
police department, its police oficers and its councel and the following law firms: Sweetapple,
Broeker & Varkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without
limitation, the attorneys, employees and partners of each such law firm).
Provide copies ofall legal and related invoices received by the Town of Gulf Stream in connection
with the matter commonly called the Sunshine Litigation including copies of all payments for such
invoices. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf
Stream, its commissioners, its manager, its employees, its police department, its police officers
and its councel and the following law firms: Sweetapple, Broeker & Varkas; Richman Greer, PA;
and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and
partners of each such law firm).
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
December 1, 2016
Martin E. O'Boyle [mail to: records(a commerce-erouo.coml
Re: GS #2223 (PRR 1244) and GS #2224 (PRR 1245)
Provide copies of all records provided to the Town of Gulf Stream FROMJoel Chandler
between the period of January 1, 2014 and the date of this request. The term "Town of Gulf
Stream "shall mean each of the following: the Town of Gulf Stream, its commissioners, its
manager, its employees, its police department, its police officers and its councel and the
following law firms: Sweetapple, Broeker & Yarkas; Richman Greer, PA; and Jones, Foster,
Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of
each such law firm).
Provide copies of all records provided by the Town of Gu f Stream TO Joel Chandler between
the period of January 1, 2014 and the date of this request. The term "Town of Gulf Stream"shall
mean each of the following: the Town of Gulf Stream, its commissioners, its manager, its
employees, its police department, its police officers and its councel and the following law firms:
Sweetapple, Broeker & Yarkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs,
(including, without limitation, the attorneys, employees and partners of each such law firm).
Dear Martin E. O'Boyle [mail to: records(a),commerce-group.coml:
The Town of Gulf Stream has received your public records requests dated June 5, 2016. You
should be able to view your original requests and a partial response at the following links:
http://www2.gulf-stream.org/weblink/O/doc/91328/Page l .asox
htti)://www2.gulf-stream.org/weblink/O/doc/91330/Paizel.asvx
The Town notes that it has previously responded to requests — including requests from you
and/or your affiliated entities or officers — for records that appear to seek a subset of the present
request. To find the aforementioned requests and responses, go to www.gulf-stream.org, click
on "Find a Town Record", click on "Public Records Requests", click on the year you desire,
click on "Public Request Number Log" and search "Chandler" and then search by the number of
the desired public records request in the folder "Public Records Requests" (of desired year).
Some of these requests include GS #'s 1704, 1669, 1668, 1644, 1556 and 1421.
The Town estimates that to fully respond to your request will require an additional two hours of
paralegal time in the amount of $125.00 per hour, and two hours of administrative support in the
amount of $35.60 per hour, the labor cost of the personnel providing the service, per Fla. Stat. §
I I9.07(4)(d). The Town possesses a hard drive of data that was produced by Joel Chandler in
the matter of O'Boyle v. Robert A. Sweetapple and Town of Gulf Stream, Case No. 9:14-cv-
81250-KAM (Marra), in response to a Subpoena for Deposition Duces Tecum issued to Mr.
Chandler by Mr. O'Boyle. The cost of a hard drive to duplicate these records onto will be
$129.99.
If the costs of producing these documents will exceed your deposit, the Town will provide you
with an initial production of responsive records and an estimate for the production of any
additional responsive records. If the costs of production are less than the deposit, the Town will
provide you with the responsive records and a refund.
(Two hours @ 35.60 + two hours @ $125.00 + $129.99) = Deposit Due: $451.19 in cash or
check.
Upon receipt of your deposit, the Town will use its very best efforts to further respond to your
public records request in a reasonable amount of time. If we do not hear back from you within
30 days of this letter, we will consider these requests closed.
Sincerely,
{z'a rI ROW" 3"d
As requested by Rita Taylor
Town Clerk, Custodian of the Records
Marty O'Boyle ("MEO") email to Joel Chandler
("Chandler").
January 4 <J'::.
Chandler email to Jonathan O'Boyle ("O'Boyle") and
Ryan Witmer ("Witmer").
!an,rvy 12, 2014 11 0" 4"a
MEO email to Chandler.
MEO email to Chandler.
Witmer email to Chandler.
Witmer email Chandler.
Janua: y 15, 2014 4:59 AM
Witmer email to Chandler.
January 15. 2014 10:00 AM
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