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Home My Public Portal AboutPRR 16-2251From: Chris O'Hare [mailto:chrisoharegulfstream@gmail.com] Sent: Saturday, June 25, 2016 7:31 AM To: Bill Thrasher <bthrasher@gulf-stream.org>; Rita Taylor <RTaylor@gulf-stream.org>; GRichman@richmangreer.com Subject: Request to Inspect Public Records - RICO comm between and/or among attorneys at Richman Greer 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 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 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 eve v 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 4119.07(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 4119.011021of 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@gmall.com 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 January 4, 2017 Chris O'Hare [mail to: chrisohareeulfstream(Za gmail.coml Re: GS 92251 (RICO comm between and/or among attorneys at Richman Greer) 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 f rm 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. Dear Chris O'Hare [mail to: chrisohareeulfstream(& mail.coml: The Town of Gulf Stream received your public records requests on June 25, 2016. You should be able to view your request at the following link: htty://www2.gulf-stream.ore/weblink/O/doc/94678/Pa ee l.asyx In future correspondence, please refer to this public records request by the above referenced numbers. After hearing back from Richman Greer, P.A., the Town estimates to respond to your request will require approximately six hours of paralegal time at $175.00 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. (Six hours @ $175.00) = Deposit Due: $1,050.00 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 1z"I JZ4Wl.4-. D44d As requested by Rita Taylor Town Clerk, Custodian of the Records