HomeMy Public PortalAboutPRR 16-2249From: Chris O'Hare[mailto:chrisoharegulfstream@gmail.com]
Sent: Friday, June 24, 2016 7:01 AM
To: Bill Thrasher <bthrasher@gulf-stream.org>; Rita Taylor <RTaylor@gulf-stream.org>;
10Connor@jonesfoster.com; Randolph, John C. <jrandolph@jonesfoster.com>
Subject: Request to Inspect Public Records - RICO comm with attorneys at Jones Foster
Dear Custodian of Records,
I request to inspect certain public records for the purpose of informing myself of the historic and current
workings of the Town of Gulf Stream and its associated entities, vendors, consultants, advisers, contractors
and agents. The records I wish to inspect may be material to current, anticipated or presently unforeseen legal
action. In addition, Inspection of these records is essential to my ability to make Informed comments in an
upcoming public hearing. The production of any and all responsive records is therefore urgent and must be
acted upon in compliance with Florida Statutes and established case law as soon as possible.
Before making this public record request, I first searched online and in the public records portion of your
agency's website hoping I could locate the public records I seek without having to write you directly.
Unfortunately I cannot find the records I request to inspect.Therefore I am writing you now and requesting you
make every effort as required by law to produce these public records without delay. I believe the records I seek
to inspect may be in your custody AND/OR in the custody of an entity under contract with your agency. As a
courtesy to you and your contractor and to assist in expediting my access to records responsive to this request
I am notifying the contractor of this request by copy of this email. Do not assume my act of copying the
contractor with this request relieves you of any of your duties under Florida Statute. I ask that you contact those
entitles yourself, Inform them of their obligations under Florida Statute and produce any responsive records in
their custody as soon as possible.
I make this request pursuant to Article 1, Section 24 of the Florida Constitution and Chapter 119 of the Florida
Statutes. I hereby reserve all rights granted to me under the Florida Constitution and Florida Statutes.
I ask that you take the following action:
• Read this entire request carefully and respond accordingly.
• If you are not the custodian of the public records described herein please determine who that person is
and notify me immediately in order that I may make this request to the appropriate person without
delay.
• Reference Florida Statutes and appropriate case law when responding to this record request.
• Do NOT produce any records other than records responsive to this request.
• Identify by name the person or persons responding to this request.
• Respond to this public record request in a singular manner and do not combine this request with any
other public record requests when responding to this request.
• Once you have determined that you do or don't have any records in your custody responsive to this
request, immediately act to obtain any responsive records that may be in the custody of
your contractor(s).
• Provide only those records for inspection that do not require extensive use of information technologies
or extensive staff time or both In excess of 15 minutes.
As background to this request I call your attention to the dismissal of the Town's RICO complaint by
the Eleventh Circuit, filed 06121-2016 in Case:15-13433.1 understand this decision concludes the
litigation of the RICO prosecution of Christopher O'Hare by the Town of Gulf Stream. Therefore records
previously exempt from s. 119.07(1) and s. 24(a), Art. I of the State Constitution are no longer
exempt and must be produced for inspection. Here is that statute for your reference:
119.071 General exemptions from inspection or copying of public records.—
(1) AGENCY ADMINISTRATION.—(d)1. A public record that was prepared by an agency
attorney (including an attorney employed or retained by the agency or employed or retained by
another public officer or agency to protect or represent the interests of the agency having
custody of the record) or prepared at the attorney's express direction, that reflects a mental
impression, conclusion, litigation strategy, or legal theory of the attorney or the agency, and
that was prepared exclusively for civil or criminal litigation or for adversarial administrative
proceedings, or that was prepared in anticipation of imminent civil or criminal litigation or
imminent adversarial administrative proceedings, is exempt from s. 119.07(1) and s. 24(a), Art. I
of the State Constitution until the conclusion of the litigation or adversarial administrative
proceedings.
I request to inspect all records of communication between any Town Commissioner of the Town of Gulf
Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire firm known
collectively as the Town Attorney) that is wholly or partly concerning RICO. Please do not include any
records of communication that are already available online as part of the Town's published minutes of
public meetings.
I ask you to take note of §119.07(1)(c) Florida Statues and your affirmative obligation to (1)
promptly acknowledge receipt of this public records request and (2) make a good faith effort which "includes
making reasonable efforts to determine from other officers or employees within the agency whether such a
record exists and, if so, the location at which the record can be accessed." I am, therefore, requesting that you
notify every individual and entity in possession of records that may be responsive to this public records request,
including individuals and entities under contract with your agency, to preserve and produce all responsive
records on an immediate basis.
If you contend that any of the records I am seeking, or any portion thereof, are exempt from inspection or
disclosure please cite the specific exemption as required by §119.07(1)(e) of the Florida Statutes and state in
writing and with particularity the basis for your conclusions as required by §119.07(1)(f) of the Florida Statutes.
Produce for my inspection all responsive records and ONLY redact that portion of the record that you consider
exempt. To be clear, if you consider an entire record to be exempt, produce that record in its entirety with all
portions redacted that you consider exempt. I specifically ask you to do this in order that I may inspect fully
redacted records for the purpose of challenging a particular redaction or establishing a reference for a future
request of a record that is only temporarily exempt, as in the case of a public record that was prepared by an
agency attorney exclusively for litigation and is only exempt from disclosure until the conclusion of the litigation.
I ask you to note that under §119.07(2)(a) of the Florida Statutes that a person who has custody of a public
record and who asserts that an exemption applies to a particular public record or part of such record shall
delete or excise from the record only that portion of the record with respect to which an exemption has been
asserted and validity applies, and such person shall produce the remainder of such record for inspection and
examination.
If the public records being sought are maintained by your agency or contactors for your agency, in an electronic
format please produce the records in the original electronic format in which they were created or
received. See §119.01(2)(f), Florida Statutes.
Again I ask that you provide only those records for inspection that do not require extensive use of information
technologies or extensive staff time or both in excess of 15 minutes. Take note of §119.07(4)(a)3.(d) Florida
Statues and if you anticipate that any records exist, the production for inspection of which will require extensive
use of information technologies or extensive staff time or both in excess of 15 minutes, then please provide
those records that can be produced within the first 15 minutes and advise me of the cost you anticipate to be
incurred by your agency for the remaining records prior to incurring this cost. Please do not incur any costs on
my behalf without first obtaining my written authorization to proceed. If you produce only a portion of all existing
responsive records, please tell me that your response Includes only a portion of all existing records responsive
to this request.
If you anticipate the need to incur any costs that I would be statutorily required to pay In order to inspect these
public records which would exceed $1.00 please notify me in advance of your incurring that cost with a written
estimate of the total cost. Please be sure to itemize any estimates so as to indicate the total number of pages
and/or records, as well as to distinguish the cost of labor and materials. Again, please do not incur any costs on
my behalf without first obtaining my written authorization to proceed.
The term public records, as used herein, has the same meaning and scope as the definition of Public records
adopted by the Florida Legislature as 4119.011(12)of the Florida Statutes.
A record that does not exist because of its disposition requires the creation of a disposition record. In all
instances where you determine a record does not exist please determine if the record once existed and in its
replacement provide the disposition record for my inspection.
All responses to this public records request should be made in writing to the following email address:
chrisoharegulfstream@gmail.com
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
June 24, 2016
Chris O'Hare [mail to: chrisohareeulfstream@email.coml
Re: GS #2249 (RICO comm with attorneys at Jones Foster)
As background to this request I call your attention to the dismissal of the Town's RICO
complaint by the Eleventh Circuit, filed 06/21-2016 in Case:15-13433. I understand this
decision concludes the litigation of the RICO prosecution of Christopher O'Hare by the Town
of Gulf Stream. Therefore records previously exempt from s. 119.07(1) and s. 24(a), Art. I of the
State Constitution are no longer exempt and must be produced for inspection. Here is that
statute for your reference:
119.071 General exemptions from inspection or copying of public records.—
(1) AGENCYADMINISTRATION.—(d)L A public record that was prepared by an agency
attorney (including an attorney employed or retained by the agency or employed or retained by
another public officer or agency to protect or represent the interests of the agency !raving
custody of the record) or prepared at the attorney's express direction, that reflects a mental
impression, conclusion, litigation strategy, or legal theory of the attorney or the agency, and
that was prepared exclusively for civil or criminal litigation or for adversarial administrative
proceedings, or that was prepared in anticipation of imminent civil or criminal litigation or
imminent adversarial administrative proceedings, is exempt from s. 119.07(1) and s. 24(a), Art.
I of the State Constitution until the conclusion of the litigation or adversarial administrative
proceedings.
I request to inspect all records of communication between any Town Commissioner of the Town
of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire
firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please
do not include any records of communication that are already available online as part of the
Town'spublished minutes ofpublic meetings.
Dear Chris O'Hare [mail to: chrisohareeulfstream@email.coml,
The Town of Gulf Stream has received your public records requests dated June 20, 2016. The
original public record request can be found at the following link http://www2.gulf-
stream.org/weblink/o/doc/94484/Pagel.aspx
Please be advised that the Town of Gulf Stream is currently working on a large number of
incoming public records requests. The Town will use its very best efforts to respond to you in a
reasonable amount of time with the appropriate response or an estimated cost to respond.
Sincerely, Town Clerk, Custodian of the Records
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via a -m
August 18, 2016
Chris O'Hare [mail to: chrisohareeulfstream(agrnail.com]
Re: GS #2185 (wantman - jf), GS #2186 (wantman — GS comm), GS #2188 (wantman — BS),
GS #2249 (RICO comm with attorneys at Jones Foster), GS #2251 (RICO comm between
and/or among attorneys at Richman Greer), GS #2252 (RICO comm with attorneys at
Jones Foster by Town staff), GS #2255 (records between and/or among attorneys at Jones
Foster Johnston & Stubbs P.A: RICO), GS #2257 (earliest 3 comm. between Sweetapple
and Richman about RICO), GS #2259 (earliest 3 comm. between Jones Foster and
Richman about RICO)
This is a request for records in your custody AND in the custody of contractors. Please
immediately forward this request to them for their production of records. Any and all public
records of communication between The Wantman Group (including all partners, employees and
agents) and the law firm of Jones Foster Johnston & Stubbs P.A. (including all attorney, partner
and employee members of that firm), the subject of which is wholly or partly regarding the
Town's RICO complaint and appeal against Christopher O'Hare.
This is a request for records in your custody AND in the custody of contractors. Please
immediately forward this request to them for their production of records. Any and all public
records of communication between The Wantman Group (including all partners, employees and
agents) and the Town of Gulf Stream (including all employees, appointees, ojficials, assignees,
and consultants including Town Manager, Town Clerk, Town Police Chief, Town
Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town
Engineer) the subject of which is wholly or partly regarding the Town's RICO complaint and
appeal against Christopher O'Hare.
This is a request for records in your custody AND in the custody of contractors. Please
immediately forward this request to them for their production of records. Any and all public
records of communication between The Wantman Group (including all partners, employees and
agents) and the law firm of Sweetapple, Broeker & IVarkus (including all attorney, partner and
employee members of that firm), the subject of which is wholly or partly regarding the Town's
RICO complaint and appeal against Christopher O'Hare.
I request to inspect all records of communication between any Town Commissioner of the Town
of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire
firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please
do not include any records of communication that are already available online as part of the
Town's published minutes ofpublic meetings.
I request to inspect all records of communication created by any attorney at the firm of Richman
Greer, P.A. that is wholly or partly concerning the Town of Gulf Stream's RICO complaint. I
remind you that any communication between and/or among attorneys at this firm that was made
on behalf of the Town is a record of the public's business and therefore it is a public record and
subject to disclosure as per §119.07 of the Florida Statutes and Article 1, Section 24 of the
Florida Constitution.
I request to inspect all records of communication between any member of the Town staff
(including Town Manager and Town Clerk) of the Town of Gulf Stream and any attorney at the
firm of Jones Foster Johnston & Stubbs P.A. (the entire firm known collectively as the Town
Attorney) that is wholly or partly concerning RICO. Please do not include any records of
communication that are already available online as part of the Town's published minutes of
public meetings.
I request to inspect any internal* record created by any attorney at the firm of Jones Foster
Johnston & Stubbs P.A. the subject matter of which is wholly orpartly concerning the Town of
Gulf Stream's RICO complaint**. These records I request to inspect include but are not limited
to any record that was prepared by any attorney at the firm of Jones Foster Johnston & Stubbs
P.A. or prepared at the express direction of any so described attorney, that: • reflects a mental
impression, conclusion, litigation strategy, or • legal theory of the attorney or the agency, or
that was prepared exclusively for civil or criminal litigation or for adversarial administrative
proceedings, or • that was prepared in anticipation of imminent civil or criminal litigation or
imminent adversarial administrative proceedings, These records may include but not be limited
to electronic records such as emails, voice mail, text messages, social media, and digital files
located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive
and similar forms of hard and soft electronic devices capable of containing electronic records.
PLEASE NOTE: • FIRST PRODUCE FOR MYINSPECTIONANYRECORDS OF INTERNAL
COMMUNICATIONBETWEENAND AMONG PERSONS 17V THE FIRMINCL UDING
RECORDS THAT MAYNOT HAVE BEEN COPIED OR SHARED WITHANYPERSONS
OUTSIDE THE FIRM. • PRODUCE RECORDS THAT DO NOT REQUIRE EXTENSIVE USE
OF INFORMATION TECHNOLOGIES OR EXTENSIVE STAFF TIME OR BOTH IN EXCESS
OF 15 MINUTESAND ALONG WITH THOSE RECORDS PROVIDE THE COST FOR
PRODUCING THE BALANCE OF THE RESPONSIVE RECORDS *The word "internal" as
used above means a record of communication between and among persons in the firm; a record
created by a person in the firm for the primary purpose of recording and making available
information or knowledge to persons in the firm; a record archived in the firm which documents,
memorializes or otherwise records an event, fact, impression, opinion, strategy, plan, or
conclusion. **The phrase "RICO complaint" as used above means the entire scope of the Town
of Gulf Stream's RICO complaint process from initial inspiration through consideration,
planning, initiation, application, appeal and resolution.
I request to inspect the three earliest created records of communication between any attorney at
the firm of Sweetapple, Broeker & Varkus and any attorney at the firm of Richman Greer, P.A.
that is wholly or partly concerning RICO*. Please do not include any records of communication
that are already available online as part of the Town's published minutes of public meetings. The
records I request to inspect may include but not be limited to electronic records such as emails,
voice mail, text messages, social media, and digital files located on cell phones, computer hard
drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft
electronic devices capable of containing electronic records.
I request to inspect the three earliest created records of communication between any attorney at
the firm of Jones Foster Johnston & Stubbs, P.A. and any attorney at the firm of Richman Greer,
P.A. that is wholly or partly concerning RICO*. Please do not include any records of
communication that are already available online as part of the Town's published minutes of
public meetings. The records I request to inspect may include but not be limited to electronic
records such as emails, voice mail, text messages, social media, and digital files located on cell
phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar
forms of hard and soft electronic devices capable of containing electronic records.
Dear Chris O'Hare [mail to: chrisoharegulfstream(@, mail.coml,
The Town of Gulf Stream has received your public records requests dated May 18, 2016, May
19, 2016, May 20, 2016, June 24, 2016, June 25, 2016, June 26, 2016, June 28, 2016, June 30,
2016, July 1, 2016 and July 2, 2016. The original public record requests can be found at the
following links:
http://www2.gulf-stream.org/weblink/0/doc/90746/Pa
eg l.asnx
http://www2.gulf-stream.org/weblink/O/doc/90745/Pagel.aspx
httT)://www2.gulf-stream.org/weblink/O/doc/90814/Pagel.asi)x
htW://www2.gulf-stream.org/weblink/O/doc/94484/Pagel.aspx
httv://www2.gulf-stream.org/weblink/O/doc/94678/Pagel.asvx
htW://www2.gulf-stream.org/weblink/O/doc/94684/Pagel.asl2x
htti)://www2.galf-stream.org/weblink/O/doc/94727/Pagel.asl)x
httv://www2.gulf-stream.org/weblink/O/doc/95015/Pagel.asi3x
http://www2.gulf-stream.org/weblink/O/doc/95239/Pagel.aspx
Your statement that records regarding the RICO lawsuit are no longer subject to the work
product exemption under the Public Records Act is incorrect.
Indeed, the RICO suit is not concluded for purposes of the work product exemption under the
Public Records Act because of your filing of post judgment motions. See Wagner v. Orange Cty,
960 So. 2d 785 (Fla. 5th DCA 2007). As a result, to respond to each of the foregoing requests
will require extensive clerical or supervisory assistance. Specifically, the records that you seek
will need to be reviewed by the Town's attorneys to determine if they were created by counsel
exclusively for litigation or in anticipation of imminent litigation and reflect the mental
impressions, conclusions, litigation strategies, or legal theories of the Town's attorneys or
otherwise exempt under Florida Statutes § 119.0171(1)(d)I until the conclusion of the litigation.
The Town is willing to hold this request in abeyance until such time as the RICO lawsuit is
concluded for purposes of the work product exemption under the Public Records Act. Please
advise whether you would like the Town to do so or whether you would like estimates of the cost
that will be incurred to review and redact all of the records that you seek for work product
privileged material.
Sincerely,
Town Clerk
Custodian of the Records
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
September 22, 2016
Chris O'Hare [mail to: chrisohareeulfstream(ia gmail.com
Re: GS #2185 (wantman - jt), GS #2186 (wantman — GS comm), GS #2188 (wantman — BS),
GS #2249 (RICO comm with attorneys at Jones Foster), GS #2251 (RICO comm between
and/or among attorneys at Richman Greer), GS #2252 (RICO comm with attorneys at
Jones Foster by Town staff), GS #2255 (records between and/or among attorneys at Jones
Foster Johnston & Stubbs P.A.- RICO), GS #2257 (earliest 3 comm. between Sweetapple
and Richman about RICO), GS #2259 (earliest 3 comm. between Jones Foster and
Richman about RICO)
This is a request for records in your custody AND in the custody of contractors. Please
immediately forward this request to them for their production of records. Any and all public
records of communication between The Wantman Group (including all partners, employees and
agents) and the law firm of Jones Foster Johnston & Stubbs P.A. (including all attorney, partner
and employee members of that firm), the subject of which is wholly or partly regarding the
Town's RICO complaint and appeal against Christopher O'Hare.
This is a request for records in your custody AND in the custody of contractors. Please
immediately forward this request to them for their production of records. Any and all public
records of communication between The Wantman Group (including all partners, employees and
agents) and the Town of Gulf Stream (including all employees, appointees, officials, assignees,
and consultants including Town Manager, Town Clerk, Town Police Chief, Town
Commissioners, Town Mayor, Town Departments, Town Police Officers, Town Employees, Town
Engineer) the subject of which is wholly or partly regarding the Town's RICO complaint and
appeal against Christopher O'Hare.
This is a request for records in your custody AND in the custody of contractors. Please
immediately forward this request to them far their production of records. Any and all public
records of communication between The Wantman Group (including all partners, employees and
agents) and the law firm of Sweetapple, Broeker & varkuus (including all attorney, partner and
employee members of that firm), the subject of which is wholly or partly regarding the Town's
RICO complaint and appeal against Christopher O'Hare.
I request to inspect all records of communication between any Town Commissioner of the Town
of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire
firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please
do not include any records of communication that are already available online as part of the
Town's published minutes ofpublic meetings.
I request to inspect all records of communication created by any attorney at the firm of Richman
Greer, P.A. that is wholly or partly concerning the Town of Gulf Stream's RICO complaint. I
remind you that any communication: between and/or among attorneys at this firm that was made
on behalf of the Town is a record of the public's business and therefore it is a public record and
subject to disclosure as per §119.07 of the Florida Statutes and Article 1, Section 24 of the
Florida Constitution.
1 request to inspect all records of communication between any member of the Town staff
(including Town Manager and Town Clerk) of the Town of Gulf Stream and any attorney at the
firm of Jones Foster Johnston & Stubbs P.A. (the entire firm known collectively as the Town
Attorney) that is wholly or partly concerning RICO. Please do not include any records of
communication that are already available online as part of the Town's published minutes of
public meetings.
I request to inspect any internal* record created by any attorney at the firm of Jones Foster
Johnston & Stubbs P.A. the subject matter of which is wholly or partly concerning the Town of
Gulf Stream's RICO complaint**. These records I request to inspect include but are not limited
to any record that was prepared by any attorney at the firm of Jones Foster Johnston & Stubbs
P.A. or prepared at the express direction of any so described attorney, that: • reflects a mental
impression, conclusion, litigation strategy, or • legal theory of the attorney or the agency, or
that was prepared exclusively for civil or criminal litigation or far adversarial administrative
proceedings, or • that was prepared in anticipation of imminent civil or criminal litigation or
imminent adversarial administrative proceedings, These records may include but not be limited
to electronic records such as emails, voice mail, text messages, social media, and digital files
located on cell phones, computer hard drives, flash drives, servers, cloud storage, google drive
and similar forms of hard and soft electronic devices capable of containing electronic records.
PLEASE NOTE: • FIRST PRODUCE FOR MYINSPECTIONANY RECORDS OF INTERNAL
COMMUNICATION BETWEENAND AMONG PERSONS IN THE FIRMINCLUDING
RECORDS THAT MAY NOT HAVE BEEN COPIED OR SHARED WITHANYPERSONS
OUTSIDE THE FIRM. • PRODUCE RECORDS THAT DO NOT REQUIRE EXTENSIVE USE
OF INFORMATION TECHNOLOGIES OR EXTENSIVE STAFF TIME OR BOTHINEXCESS
OF 15 MINUTES AND ALONG WITH THOSE RECORDS PROVIDE THE COST FOR
PRODUCING THE BALANCE OF THE RESPONSIVE RECORDS. *The word "internal" as
used above means a record of communication between and among persons in die firm; a record
created by a person in the firm for the primary purpose of recording and making available
information or knowledge to persons in the firm; a record archived in the firm which documents,
memorializes or otherwise records an event, fact, impression, opinion, strategy, plan, or
conclusion. **The phrase "RICO complaint" as used above means the entire scope of the Town
of Gulf Stream's RICO complaint process from initial inspiration through consideration,
planning, initiation, application, appeal and resolution.
I request to inspect the three earliest created records of communication between any attorney at
the firm of Sweetapple, Broeker & Varkus and any attorney at the firm of Richman Greer, P.A.
that is wholly or partly concerning RICO*. Please do not include any records of communication
that are already available online as part of the Town's published minutes ofpublic meetings. The
records I request to inspect may include but not be limited to electronic records such as emails,
voice mail, text messages, social media, and digital files located on cell phones, computer hard
drives, flash drives, servers, cloud storage, google drive and similar forms of hard and soft
electronic devices capable of containing electronic records.
I request to inspect the three earliest created records of communication between any attorney at
the firm of Jones Foster Johnston & Stubbs, P.A. and any attorney at the firm of Richman Greer,
P.A. that is wholly or partly concerning RICO*. Please do not include any records of
communication that are already available online as part of the Town's published minutes of
public meetings. The records I request to inspect may include but not be limited to electronic
records such as emails, voice mail, text messages, social media, and digital files located on cell
phones, computer hard drives, flash drives, servers, cloud storage, google drive and similar
forms of hard and soft electronic devices capable of containing electronic records.
Dear Chris O'Hare [mail to: chrisoharegulfstreamna,gmail.coml,
The Town of Gulf Stream has received your public records requests dated May 18, 2016, May
19, 2016, May 20, 2016, June 24, 2016, June 25, 2016, June 26, 2016, June 28, 2016, June 30,
2016, July 1, 2016 and July 2, 2016. The original public record requests can be found at the
following links:
httu://www2.gulf-stream.ore/weblink/0/doc/90746/Pagel.aspx
httn://www2.gulf-stream.org/weblink/O/doc/90745/Pagel.asvx
http://www2.gulf-stream.org/weblink/O/doc/90814/Pagel.ast)x
http://www2.gulf-stream.org/weblink/0/doc/94484/Pa eg l.asax
http://www2.gulf-stream.org/weblink/O/doc/94678/Pagel.aspx
httu://www2.gulf-stream.org/weblink/0/doc/94684/Pa eg 1_aspxx
httr)://www2.gulf-stream.org/weblink/O/doc/94727/Pagel.aspx
http://www2.gulf-stream.org/weblink/O/doc/95015/Pagel.asvx
hLtp://www2.gulf-stream.org/weblink/O/doc/95239/Pagel.asr)x
On August 18, 2016, we sent you an e-mail stating that the Town is willing to hold these requests
in abeyance until such time as the RICO lawsuit is concluded for purposes of the work product
exemption under the Public Records Act. Please advise whether you would like the Town to do
so or whether you would like estimates of the cost that will be incurred to review and redact all
of the records that you seekfor work product privileged material.
As you know, the Town's policy is if we do not hear back from you within 30 days of our
response to you, we will consider the request closed. It is now past the 30 day mark. We are
willing to give you an additional 30 days to advise whether you would like the Town to hold the
above record requests in abeyance until such time as the RICO lawsuit is concluded for purposes
of the work product exemption under the Public Records Act or whether you would like
estimates of the cost that will be incurred to review and redact all of the records that you seek for
work product privileged material. If we do not hear back from you within 30 days of this letter,
we will consider these requests closed.
Sincerely,
jz"I f oW". 9wr
As requested by Rita Taylor
Town Clerk, Custodian of the Records
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
December 30, 2016
Chris O'Hare [mail to: chrisoharesulfstreamPgtnail.coml
Re: GS #2249 (RICO comm with attorneys at Jones Foster)
I request to inspect all records of communication between any Town Commissioner of the Town
of Gulf Stream and any attorney at the firm of Jones Foster Johnston & Stubbs P.A. (the entire
firm known collectively as the Town Attorney) that is wholly or partly concerning RICO. Please
do not include any records of communication that are already available online as part of the
Town's published minutes ofpublic meetings.
Dear Chris O'Hare [mail to: chrisohareeulfstream(a)email.coml:
The Town of Gulf Stream has received your public records request dated June 24, 2016. You
should be able to view your original request at the following link:
http://www2.gulf-stream.org/weblink/O/doc/94484/Pagel.asi)x
You have asked that the Town only provide those records that do not require extensive use of
information technologies or extensive staff time or both in excess of 15 minutes and that the
Town provide an estimate of the cost that would be required to fulfill the request as permitted by
the Public Records Act. To that end, the Town has spent at least 15 minutes on your request and
now requests a deposit for an additional half hour of administrative support at $35.60 per hour,
the labor cost of the personnel providing the service, per Fla. Stat. § 119.07(4)(d). 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.
(1/2 hour at 35.60) = Deposit Due: $17.80 in cash or check.
Upon receipt of your deposit, the Town will use its very best efforts to further respond to your
public records request in a reasonable amount of time. If we do not hear back from you within
30 days of this letter, we will consider this request closed.
Sincerely, DD� �-n
Rit' Jz"M' DG.�ic�
As requested by Rita Taylor
Town Clerk, Custodian of the Records