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HomeMy Public PortalAboutPRR 16-2224RECORDS REQUEST (the "Request") Date of Request: 06.05.2016 Requestor's Request ID#: 1245 REQUESTEE: Custodian of Records Sweetaimle, 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'Bovle REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com Fax: 954-360-0807 or Contact Records Custodian at records(),commerce-group.com; Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Provide conies 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. 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 emplovees its Police Department, its Police Officers its counsel and the following law firms: Sweetavvle. Broeker & Varkas: Richman Greer. PA; and Jones, Foster. Johnston & Stubbs. (including, without limitation, the attorneys. emplovees and partners of each such law firm.) THIS REQUEST IS MADE PURSUANT TO ARTICLE L SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119, FLORIDA STATUTES IF THE PUBLIC RECORDS BEING SOUGHT ARE MAINTAINED BY YOUR AGENCY IN AN ELECTRONIC FORMAT PLEASE PRODUCE THE RECORDS IN THE ORIGINAL ELECTRONIC FORMAT IN WHICH THEY WERE CREATED OR RECEIVED. SEE 6I19.01(2)(F), FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM. IT IS REOVESTED 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 §J19.07(n(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 of any costs, asserted by the Agency (as defined in Florida Statute, Chapter 119.01 (Dentitions)), in advance of any 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". 1/P/NP/FLRR 07.282015 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). (1) Please provide a copy of all communications sent by Robert Sweetapple (or any member of his firm, Sweetapple, Broeker & Varkas, including their emplolyees or partners ("Sweetapple')) and/or the Town of Gulf Stream to Keven Tynan ("Tynan') regarding Jonathan O'Boyle or the o'boyle law firm (the "subject'). (2) Please provide a copy of all communications sent by Tynan to Sweetapple regarding the subject. The term "Town of Gulf Stream" shall mean each of the following: the Town of Gut( 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 lawfirm). (1) Please provide all records sent to the Florida Bar by the Town of Gulf Stream (including, without limitation, Robert Sweetapple) since January 1, 2013. (2) Please provide all records received from the Florida Bar by the Town of Gulf Stream (including, without limitation, Robert Sweetapple) since January 1, 2013. The term "Town of Gu f 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). 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. The original public record request can be found at the following links htto://www2.gulf- stream.org/weblink/0/doc/91327/Pagel.aspx. htto://www2.gulf- stream.org/weblink/0/doc/91328/Pagel.aspx, htto://www2.gulf- stream.org/weblink/0/doc/91330/Pagel.aspx, htto://www2.gulf- stream.org/weblink/0/doc/91331/Pagel.aspx, http://www2.gulf- stream.org/weblink/0/doc/91333/Pagel.aspx, and http://www2.gulf- stream.org/weblink/­O/­doc/`91334/Pagel.asp Please be advised that the Town of Gulf Stream is currently working on a large number of incoming public records requests. The Town will use its very best efforts to respond to you in a reasonable amount of time with the appropriate response or an estimated cost to respond. Sincerely, Town Clerk, Custodian of the Records TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail December 1, 2016 Martin E. O'Boyle [mail to: recordsl7a.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 ofthefollowing: the Town of Gulf Stream, its commissioners, its manager, its employees, its police department, its police officers and its councel and the following law firms: Sweetapple, Broeker & Yarkas; Richman Greer, PA; and Jones, Foster, Johnston & Stubbs, (including, without limitation, the attorneys, employees and partners of each such law 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 & Varkas; 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: recordsAcommerce-group.com]: 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: h!W://www2.gulf-stream.org/weblink/0/doc/91328/Pa eg l.asnx hqp://www2.gulf-stream.org/weblink/O/doc/91330/Pagel.asi)x 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, RR"Rltw" pn "ti As requested by Rita Taylor Town Clerk, Custodian of the Records Marty O'Boyle ("MEO") email to Joel Chandler ("Chandler"). Chandler email to Jonathan O'Boyle ("O'Boyle") and Ryan Witmer ("Witmer"). January 12, 2014 11:08 AM . MEO email to Chandler. January 12, 2014 11 MEO email to Chandler. . Witmer email to Chandler. Witmer email Chandler. Witmer email to Chandler. January 15, 2014 10:00 AM . MEO email to Chandler. i,anuary 20, 2014 9:09 AM Witmer email to Chandler. CAR is incorporated MEO email to Chandler. MEO email to Chandler. February _2, 2014 6:15 AM MEO email to Chandler. ry 4, 2014 8:10 PM . MEO email to Chandler. MEO email to Chandler. Marrett Hanna ("Hanna") email to Chandler. Hanna email to Chandler. February 14, 2014 8:32 AM Denise DeMartini ("DeMartini") email to Karla McCutcheon ("McCutcheon"). Chandler email to O'Boyle. . William Ring ("Ring") email to Chandler. Ring email to O'Boyle Law Firm. March 12, 2014 12:24 PM . Ring email to Chandler. March 18, 2014 2:07 PM . Ring email to Chandler. . Ring email to Chandler. Hanna email to Chandler. Chandler email to Hanna. March 27, 2014 5:08 PM Ring makes PRR on begalf of CAFI. March 28, 2014 11:51 AM O'Boyle email to Chandler. April 1, 2014 8:22 AM . Mohler email to Chandler. O'Boyle email to Chandler. . Hanna email to Chandler. . O'Boyle email to Chandler. April 4_eu14 9:06 AM- . Ring email to Chandler. April 9, 2014 6:47 AM DeMartini email to Chandler. Chandler email to O'Boyle Law Firm. . O'Boyle email to Chandler. . DeMartini email to Chandler. . DeMartini email to Chandler. April 28, 2014 L17 AM Giovani Mesa email to Chandler. April 28, 2014 12:28 PM Ring email to Nick Taylor ("Taylor"). . Mesa email to Chandler. . DeMartini email to Chandler. DeMartini email to Chandler. May T20149:57 AM Chandler sends Memo to Board of Directors May 15, 2014 . DeMartini email to Chandler. May 16, 2014 9:31 APA Meeting with Board to Discuss Litigation Authority, etc. Board agrees that Chandler will have sole authority to make PRRs and to commence and settle open government litigation. . Witmer email to O'Boyle. May,;,. du1, ;.031,M . DeMartini email to Chandler. May 26, 2014 3:04 PN1 . Chandler email to DeMartini. DeMartini tries to coax Chandler to draft lawsuits in spite of his concerns regarding UPL. DeMartini email to Chandler. May 28, 2Ui4 4.16NM DeMartini send email to Chandler demanding more cases. May 28, 2014 4:36 PM . Ring email to Chandler. Chandler email to Board of Directors. . Chandler meets with Gregg Thomas. . Chandler meets with Barbara Petersen. . Mohler email to Chandler. Mohler using CAFI email address and discussing PRRs that she is sending out on behalf of CAFI. June 16, 2014 7:31 AM . Ring email to Chandler. June 16, 2014 10:07 AM . Ring email to Chandler. . Mohler email to Chandler. . Mohler email to Chandler. CAFI files amendment with Florida Secretary fo State June 23 Mohler email to Chandler. June 25, 2014 9:03 AM Chandler email to Taylor. Ring email to Chandler. Jw,e 27. 2-0-1-4-1-1-:1-8 ANI Chandler resigns. June 30, 2014 3:30 PM DeMartini email to Chandler. . DeMartini email to Chandler. . MEO email to Chandler. DeMartini email to Chandler. July 3, 2014 7:05 AM__ _ • MEO email to Chandler. July 3, 2014 7:53 AM • DeMartini email to Chandler. Jt IV 3, 2014 8:29 AM • Chandler email to MEO. . DeMartini email to Chandler. MEO email to Chandler. July 7,_2U;4 z 4b PM . Ring email to Chandler. July 8, 2014 10:47 AM • EMBED