HomeMy Public PortalAboutPRR 16-2256From: Chris O'Hare [mailto:chrisoharegulfstream@gmail.comj
Sent: Wednesday, June 29, 2016 7:29 AM
To: Rita Taylor <RTaylor@gulf-stream.org>; Bill Thrasher <bthrasher@gulf-stream.org>;
cbailey@sweetapplelaw.com; rsweetapple@sweetapplelaw.com
Subject: Request to Inspect Public Records - Commissioner comm. with attorneys at Sweetapple,
Broeker & Varkus about RICO
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 - namely
Robert Sweetapple and/or Sweetapple, Broeker & Varkus. As a courtesy to you and your contractor and to
assist in expediting my access to records responsive to this request I am notifying Robert Sweetapple
and Sweetapple, Broeker & Varkus 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
entities 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).
" P r o v i d e t h o s e r e c o r d s f o r i n s p e c t i o n t h a t d o n o t r e q u i r e e x t e n s i v e u s e o f i n f o r m a t i o n t e c h n o l o g i e s o r
e x t e n s i v e s t a f f t i m e o r b o t h i n e x c e s s o f 1 5 m i n u t e s a n d a l o n g w i t h t h e p r o d u c t i o n o f t h o s e r e c o r d s
p r o v i d e t h e c o s t f o r p r o d u c i n g t h e b a l a n c e o f t h e r e s p o n s i v e r e c o r d s .
A s b a c k g r o u n d t o t h i s r e q u e s t I c a l l y o u r a t t e n t i o n t o t h e d i s m i s s a l o f t h e T o w n ' s R I C O c o m p l a i n t b y
t h e E l e v e n t h C i r c u i t , f i l e d 0 6 / 2 1 - 2 0 1 6 i n C a s e : 1 5 - 1 3 4 3 3 . 1 u n d e r s t a n d t h i s d e c i s i o n c o n c l u d e s t h e
l i t i g a t i o n o f t h e R I C O p r o s e c u t i o n o f C h r i s t o p h e r O ' H a r e b y t h e T o w n o f G u l f S t r e a m . T h e r e f o r e r e c o r d s
p r e v i o u s l y e x e m p t f r o m s . 1 1 9 . 0 7 ( 1 ) a n d s . 2 4 ( a ) , A r t . I o f t h e S t a t e C o n s t i t u t i o n a r e n o l o n g e r
e x e m p t a n d m u s t b e p r o d u c e d f o r i n s p e c t i o n . H e r e i s t h a t s t a t u t e f o r y o u r r e f e r e n c e :
1 1 9 . 0 7 1 G e n e r a l e x e m p t i o n s f r o m i n s p e c t i o n o r c o p y i n g o f p u b l i c r e c o r d s .
( 1 ) A G E N C Y A D M I N I S T R A T I O N . ( d ) 1 . A p u b l i c r e c o r d t h a t w a s p r e p a r e d b y a n a g e n c y
a t t o r n e y ( i n c l u d i n g a n a t t o r n e y e m p l o y e d o r r e t a i n e d b y t h e a g e n c y o r e m p l o y e d o r r e t a i n e d b y
a n o t h e r p u b l i c o f f i c e r o r a g e n c y t o p r o t e c t o r r e p r e s e n t t h e i n t e r e s t s o f t h e a g e n c y h a v i n g
c u s t o d y o f t h e r e c o r d ) o r p r e p a r e d a t t h e a t t o r n e y ' s e x p r e s s d i r e c t i o n , t h a t r e f l e c t s a m e n t a l
i m p r e s s i o n , c o n c l u s i o n , l i t i g a t i o n s t r a t e g y , o r l e g a l t h e o r y o f t h e a t t o r n e y o r t h e a g e n c y , a n d
t h a t w a s p r e p a r e d e x c l u s i v e l y f o r c i v i l o r c r i m i n a l l i t i g a t i o n o r f o r a d v e r s a r i a l a d m i n i s t r a t i v e
p r o c e e d i n g s , o r t h a t w a s p r e p a r e d i n a n t i c i p a t i o n o f i m m i n e n t c i v i l o r c r i m i n a l l i t i g a t i o n o r
i m m i n e n t a d v e r s a r i a l a d m i n i s t r a t i v e p r o c e e d i n g s , i s e x e m p t f r o m s . 1 1 9 . 0 7 ( 1 ) a n d s . 2 4 ( a ) , A r t . I
o f t h e S t a t e C o n s t i t u t i o n u n t i l t h e c o n c l u s i o n o f t h e l i t i g a t i o n o r a d v e r s a r i a l a d m i n i s t r a t i v e
p r o c e e d i n g s .
I r e q u e s t t o i n s p e c t a l l r e c o r d s o f c o m m u n i c a t i o n b e t w e e n a n y T o w n C o m m i s s i o n e r o f t h e T o w n o f G u l f
S t r e a m a n d a n y a t t o r n e y a t t h e f i r m o f S w e e t a p p l e , B r o e k e r & V a r k u s t h a t i s w h o l l y o r p a r t l y
c o n c e r n i n g R I C O * . P l e a s e d o n o t i n c l u d e a n y r e c o r d s o f c o m m u n i c a t i o n t h a t a r e a l r e a d y a v a i l a b l e
o n l i n e a s p a r t o f t h e T o w n ' s p u b l i s h e d m i n u t e s o f p u b l i c m e e t i n g s . T h e r e c o r d s I r e q u e s t t o
i n s p e c t m a y i n c l u d e b u t n o t b e l i m i t e d t o e l e c t r o n i c r e c o r d s s u c h a s e m a i l s , v o i c e
m a i l , t e x t m e s s a g e s , s o c i a l m e d i a , a n d d i g i t a l f i l e s l o c a t e d o n c e l l p h o n e s ,
c o m p u t e r h a r d d r i v e s , f l a s h d r i v e s , s e r v e r s , c l o u d s t o r a g e , g o o g l e d r i v e a n d
s i m i l a r f o r m s o f h a r d a n d s o f t e l e c t r o n i c d e v i c e s c a p a b l e o f c o n t a i n i n g e l e c t r o n i c
r e c o r d s .
F I R S T P R O D U C E R E C O R D S T H A T D O N O T R E Q U I R E E X T E N S I V E U S E O F I N F O R M A T I O N
T E C H N O L O G I E S O R E X T E N S I V E S T A F F T I M E O R B O T H I N E X C E S S O F 1 5 M I N U T E S A N D A L O N G
W I T H T H O S E R E C O R D S P R O V I D E T H E C O S T F O R P R O D U C I N G T H E B A L A N C E O F T H E R E S P O N S I V E
R E C O R D S .
* T h e p h r a s e " R I C O " a s u s e d a b o v e m e a n s t h e e n t i r e s c o p e o f t h e T o w n o f G u l f S t r e a m ' s R I C O
c o m p l a i n t p r o c e s s f r o m i n i t i a l i n s p i r a t i o n t h r o u g h c o n s i d e r a t i o n , p l a n n i n g , i n i t i a t i o n , a p p l i c a t i o n ,
a p p e a l a n d r e s o l u t i o n .
I ask you to take note of §119.07(1 Kc) 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)(a) 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 5119.07(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.
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 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.
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.
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.
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 §119.011(12)of the Florida Statutes.
Please contact me at the email address shown below and request clarification if there is any part of this record
request you do not understand.
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 30, 2016
Chris O'Hare [mail to: chrisohareeulfstreamtaDemail.coml
Re: GS #2256 (Commissioner comm. with attorneys at Sweetapple, Brooker & Varkus about
RICO)
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 Sweetapple, Broeker & Varkus 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 similarforms ofhard and soft electronic devices capable
of containing electronic records. FIRST PRODUCE RECORDS THAT DO NOT REQUIRE
EXTENSIVE USE OF INFORMATION TECHNOLOGIES OR EXTENSIVE STAFF TIME OR
BOTH IN EXCESS OF 15 MINUTES AND ALONG WITH THOSE RECORDS PROVIDE THE
COST FOR PRODUCING THE BALANCE OF THE RESPONSIVE RECORDS. *The phrase
"RICO" 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.
Dear Chris O'Hare [mail to: chrisohareeulfstreamtaD¢mail.coml,
The Town of Gulf Stream has received your public records requests dated June 29, 2016. The
original public record request can be found at the following link htti3://www2.gulf-
stream.org/weblink/0/doc/95013/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 e-mail
August 18, 2016
Chris O'Hare [mail to: chrisohareeulfstream(a)gtnail.com
Re: GS #2256 (Commissioner comm. with attorneys at Sweetapple, Broeker & Varkus
about RICO)
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 Sweetapple, Broeker & Varkus 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. FIRST PRODUCE RECORDS THAT DO NOT
REQUIRE EXTENSIVE USE OF INFORMATION TECHNOLOGIES OR EXTENSIVE STAFF
TIME OR BOTH IN EXCESS OF 15 MINUTES AND ALONG WITH THOSE RECORDS
PROVIDE THE COST FOR PRODUCING THE BALANCE OF THE RESPONSIVE
RECORDS. *The phrase "RICO" 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.
Dear Chris O'Hare [mail to: chrisoharegulfstream(a)gmail.coml,
The Town of Gulf Stream has received your public records request dated June 29, 2016. The
original public record request can be found at the following link:
http://www2.gulf-stream.org/weblink/0/doc/95013/Pagel.aspx.
Please be advised that there are no such records. We consider this request closed.
Sincerely,
Town Clerk
Custodian of the Records
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
December 13, 2016
Chris O'Hare [mail to: chrisohareeulfstreatn6it mail.coml
Re: GS #2256 (Commissioner comm. with attorneys at Sweetapple, Brocker & Varkus
about RICO)
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 Sweetapple, Broeker & Varkus 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. FIRST PRODUCE RECORDS THAT DO NOT
REQUIRE EXTENSIVE USE OF INFORMATION TECHNOLOGIES OR EXTENSIVE STAFF
TIME OR BOTH IN EXCESS OF 15 MINUTES AND ALONG WITH THOSE RECORDS
PROVIDE THE COST FOR PRODUCING THE BALANCE OF THE RESPONSIVE RECORDS.
*The phrase "RICO" 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.
Dear Chris O'Hare [mail to: chrisohareeulfstream(7a.wnail.coml:
The Town of Gulf Stream received your public records requests on June 29, 2016. You should
be able to view your request at the following link:
http://www2.gulfstream.org/weblink/O/doc/95013/Pa eg l_asQx
In future correspondence, please refer to this public records request by the above referenced
numbers.
Thank you for your clarification, dated October 1, 2016. Based on that clarification, please see
the attached documents. The updated response can be found at the above link. The Town has
spent at least 15 minutes on your request and now estimates that to respond to your request will
require approximately an additional hour of paralegal support at $125.00 per hour, an additional
hour of legal support at $350.00 per hour and an additional half hour 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.
(One hour @ $125.00 + One hour @ $350.00 + One half hour @ $35.60) = Deposit Due:
$510.60 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,
Dn� "� �""A�
t 41d RIOWf. I pfv7,cc
As requested by Rita Taylor
Town Clerk, Custodian of the Records
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:12 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: 3-2-15 email re conference
This message originated from outside your organization
From: scottmorgan75(@gmail.com
Sent: Monday, March 02, 2015 2:37 PM
To: Robert Sweetaoole ; Gerry Richman ; Eric Sodhi ; Joanne O'Connor
Subject: Telephone Conference- Gulf Stream v. O'Boyle et al.
Gerry,
Would you have your office schedule a status telephone conference for some time this week?
Thanks.
Scott W. Morgan
(561) 752-1936
Renee Basel
From: scottmorgan75@9mail.com
Sent: Tuesday, November 1, 2016 3:12 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: 3-3-15 email
This message originated from outside your organization
From: scottmorgan75(@smail.com
Sent: Tuesday, March 03, 2015 5:14 PM
To: Dottie Costonis
Subject: Re: Telecon re GULF STREAM, TOWN OF - O'BOYLE, Et Al.
OK
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
From: Dottie Costonis
Sent: Tuesday, March 03, 2015 5:06 PM
To: ioconnor(aljonesfoster.com ; rsweetapple(o sweetaoolelaw.com ; mailto:cbailey(alsweetapplelaw.com ;
mailto:scottmorgan750omail.com ; dsmith(alsweetaoolelaw.com
Cc: Gerald F. Richman ; Eric M. Sodhi
Subject: RE: Telecon re GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Mr. Richman's meeting is running late and he wanted to know if everyone would be available at 5:30p.m. for the call?
Please let me know if that will work for everyone.
Thanks,
-Rodney
qhRICHMAN GREER
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonis@richmangreer.com
www.RichmanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited Please immediately notify us by email and delete the original message.
From: Dottie Costonis
Sent: Tuesday, March 03, 2015 3:38 PM
To: 'joconnor@jonesfoster.com'; 'rsweetapple@sweetapplelaw.com'; Cynthia Bailey (cbailey@sweetapplelaw.com); Scott
Morgan (scottmorgan75@gmail.com); dsmith@sweetapplelaw.com
Cc: Gerald F. Richman; Eric M. Sodhi
Subject: RE: Telecon re GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Please see call-in information for Status Conference today at 5:15p.m. We can use call in number 561-803-3535;
Conference number: 652; Access Code: 250.
Thanks,
-Rodney
(Please let me know if there is an issue with time)
From: Dottie Costonis
Sent: Tuesday, March 03, 2015 12:42 PM
To: 'joconnor@jonesfoster.com'; 'rsweetapple@sweetapplelaw.com'; Cynthia Bailey (cbailev @sweetaoplelaw.com); Scott
Morgan (scottmoroan75(a1gmail.com)
Cc: Gerald F. Richman; Eric M. Sodhi
Subject: RE: Telecon re GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Good afternoon all,
Mr. Richman is available after Sp.m.(EST) today for the status conference. This looks like our only chance for this week
seeing that Mr. Richman is unavailable tomorrow and Mr. Sweetapple is out of town for deposition on Thursday and
Friday. Please let me know if this time works for you.
Thanks,
-Rodney
From: Dottie Costonis
Sent: Tuesday, March 03, 2015 10:51 AM
To: 'joconnor@jonesfoster.com'; 'rsweetapple@sweetapplelaw.com'; Cynthia Bailey (cbailev@sweetapplelaw.com); Scott
Morgan (scottmoraan75(&Qmail.com)
Cc: Gerald F. Richman; Eric M. Sodhi
Subject: RE: Telecon re GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Good morning,
Please provide your availability for a status telephone conference for this week.
Thanks,
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:11 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: 3-5-15 email
This message originated from outside your organization
From: scottmorgan750gmail.com
Sent: Thursday, March 05, 2015 11:24 AM
To: Ingrid Bascobert ; joconnor(alionesfoster.com ; Bill Thrasher ; grichman(&richmangreer.com ; Eric Sodhi ; Robert
Sweetaoole
Subject: Re: O'Hare/O'Boyle Public Records Requests
Thank you, Ingrid.
I forwarded your email to Eric.
This spreadsheet is interesting because it confirms a pattern of PRR activity. Using a 5 day work week and
removing holidays, these two men have, individually or through their agents, have maintained a fairly constant
stream of public records requests, averaging about 5 per day since September 2013.
Scott W. Morgan
(561)752-1936
From: Ingrid Bascobert
Sent: Thursday, March 05, 2015 11:04 AM
To: joconnor(abionesfoster.com ; Bill Thrasher ; scottmorgan75C&gmall.com ; grichman@richmangreer.com
Subject: O'Hare/O'Boyle Public Records Requests
Hello,
Attached is an excel spreadsheet of all the public records requests from O'Hare and O'Boyle from 2013-2015.
The excel doc includes a spreadsheet of each year (2013, 2014, 2015), as well as a spreadsheet with the total number of
requests, a spread sheet of high volume requests, and a spreadsheet of aliases used by both O'Hare and O'Boyle. I hope
this finds you well and that it is useful! Additonally, I do not have an email address for Mr. Eric Sohdi so I would greatly
appreciate it if one of you could forward this email to him. Thank you so much.
Regards,
INGRID B. BASCOBERT
Administrative Assistant
Sweetapple, Broeker & Varkas, P.L.
20 SE 3rd Street
Boca Raton, FL 33432
(561) 392-1230 (t) x. 306
(561) 394-6102 (f)
ibascobert(@sweetapplelaw.com
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message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate,
maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this
message to any person other than the intended recipient(s) is not intended in any way to waive privilege or
confidentiality.
Renee Basel
From:
scottmorgan75@gmail.com
Sent:
Tuesday, November 1, 2016 3:09 PM
To:
Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject:
3-31-15 email and 4-6-15 email
This message originated from outside your organization
From: scottmoraan75Calgmail.com
Sent: Monday, April 06, 2015 5:12 PM
To: Gerry Richman ; Eric Sodhi ; Joanne O'Connor ; Robert Sweetaoole
Subject: Fw: O'Boyle v. Gulf Stream
Status, please.
From: scottmoroan75(0omail.com
Sent: Tuesday, March 31, 2015 2:29 PM
To: Gerry Richman ; Eric Sodhi ; Joanne O'Connor ; Robert Sweetaoole
Subject: O'Boyle v. Gulf Stream
Hi Gerry,
Would you please give us an update on the status of forwarding the RICO Complaint to the statewide
prosecutor, attorney general and/or state attorney for the 15th judicial district? The Town Commission
authorized this action in February and I would like to report back to them at April's meeting on the 10th.
Also, any further word from the city of Miami Beach?
Thank you.
Scott W. Morgan
(561) 752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:11 PM
To: Hudson Gill; Trey Nazzaro; OConnor, Joanne M.
Subject: another 3-5-15 email
Attachments: Public Records Requests 2013-2015 FINAL.xlsx
This message originated from outside your organization
From: scottmorgan75Ca)gmail.com
Sent: Thursday, March 05, 2015 11:15 AM
To: Eric Sochi
Subject: Fw: O'Hare/O'Boyle Public Records Requests
Eric,
Please see below.
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561)752-1936
From: Ingrid Bascobert
Sent: Thursday, March 05, 2015 11:04 AM
To: ioconnorCalionesfoster.com ; Bill Thrasher ; scottmorgan75acimail.com ; grichmanCa)richmanoreer.com
Subject: O'Hare/O'Boyle Public Records Requests
Hello,
Attached is an excel spreadsheet of all the public records requests from O'Hare and O'Boyle from 2013-2015.
The excel doc includes a spreadsheet of each year (2013, 2014, 2015), as well as a spreadsheet with the total number of
requests, a spread sheet of high volume requests, and a spreadsheet of aliases used by both O'Hare and O'Boyle. I hope
this finds you well and that it is useful! Additonally, I do not have an email address for Mr. Eric Sohdi so I would greatly
appreciate it if one of you could forward this email to him. Thank you so much.
Regards,
INGRID B. BASCOBERT
Administrative Assistant
Sweetapple, Broeker & Varkas, P.L.
20 SE 3rd Street
Boca Raton, FL 33432
(561) 392-1230 (t) x. 306
(561) 394-6102 (f)
ibascobert0sweetapplelaw.com
STATEMENT OF CONFIDENTIALITY
The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this
message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate,
maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this
message to any person other than the intended recipient(s) is not intended in any way to waive privilege or
confidentiality.
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:13 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: 2-13-15 email: Civil RICO Class Action Complaint
This message originated from outside your organization
From: scottmorcian75(&gmail.com
Sent: Friday, February 13, 2015 12:28 PM
To: esodhi .
Subject: Re: Civil RICO Class Action Complaint
Thank you Eric.
Would you please send me a copy of the Exhibits after they are filed.
Regards,
Scott W. Morgan
(561) 752-1936
From: esodhi .
Sent: Thursday, February 12, 2015 10:38 PM
To: grichmanCabrichmangreer.com ; JOConnor(Mones-foster.com ; rsweetapple(d)sweetapplelaw.com ;
scottmorgan75Colgmail.com ; esodhi ; Maria Ramirez ; dcostonis(o richmangreer.com
Subject: Civil RICO Class Action Complaint
El
Attached, please find the filed version of the Civil RICO Class Action Complaint. The Exhibits will be filed under
separate cover tomorrow morning. Thank you.
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:37 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: 1-6-15 EMAIL O'Boyle, O'Hare- Town of Gulf Stream
Attachments: Scan_pdf
This message originated from outside your organization
From: scottmorgan75Cabgmail.com
Sent: Tuesday, January 06, 2015 8:55 AM
To: Gerry Richman ; Joanne O'Connor ; Robert Sweetaoole
Subject: O'Boyle, O'Hare- Town of Gulf Stream
Hello Gerry,
I hope you had a nice holiday.
When you get a chance, would you please update me on the status of the federal court action?
We have a Commission meeting on Friday and the Commissioners will be looking for an update.
Also, attached are two letters just received from Mr. Mendez, the Florida Bar Counsel assigned to investigate
the Bar complaint. I spoke to Mr. Mendez last week and he said that he has read a copy of Chandler's
summarized statement but he wants to review the entire stenographic statement.
Bob—would you please send it to Mr. Mendez on my behalf?
Thanks.
Scott
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:19 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: 2-2-15 email: O'Boyle information
This message originated from outside your organization
From: scottmorean75CcDBmail.com
Sent: Monday, February 02, 2015 2:29 PM
To: Robert Sweetaoole ; Joanne O'Connor ; Eric Sodhi ; Gerry Richman
Subject: O'Boyle information
Last week, two of our Town employees were deposed by O'Boyle's lawyer, Giovanni Mesa of the O'Boyle Law
Firm. Martin O'Boyle was then deposed by our insurance carrier attorney, Hudson Gill. The case involves
federal issues surrounding Gulf Stream's "sign" ordinance and the removal of O'Boyle's election signs that he
had placed in the public right of way.
During the deposition of Bill Thrasher, our town manager, Chris O'Hare, who was sitting in the audience,
approached the deposition table, handed a note to O'Boyle, who in turn handed it to Attorney Mesa for
purposes of framing a line of questioning.
Some of the questioning of Thrasher involved a flurry of emails sent "by a resident" last week complaining of
irregularities in the enforcement of Gulf Stream's new sign law, which was passed on second reading last
Monday. (Those 20 or so emails were sent by O'Hare) During a break in testimony, O'Boyle and O'Hare
huddled with Mesa, after which Mesa continued to question Thrasher on other details about that "resident's"
emails regarding signs. The point is that O'Boyle and O'Hare are obviously working in concert on this and other
cases, even if O'Hare is not an actual party.
During Martin O'Boyle's deposition, he became agitated (according to Thrasher) when questioned about his
connection to Mark Dougan, who had been identified in discovery as someone with knowledge about the sign
removal case. It seems that Mr. Dougan was discharged from one of the local Sheriff's Departments for certain
improprieties, but has found work with the O'Boyles, although O'Boyle was evasive and nonresponsive
regarding what this man's duties were. Martin offered only that Dougan provides services like flying plane
banners.
In addition, when asked about Doug Stacey, who is Mr. O'Boyle's "driver", O'Boyle said Stacey does not work
for him; rather, he is employed by Mrs. Sheila O'Boyle. Stacey is the person who drives Mrs. O'Boyle's sign
laden truck to Town Commission meetings.
Regards,
Scott W. Morgan
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:06 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: 4-23-15 email Attorney General Letter
Attachments: Letter to Attorney General re Revoking CAR Charter 4-27-15.docx
This message originated from outside your organization
Not sure if this is responsive to the PRR that Renee sent today but I'm forwarding it anyway.
From: scottmorgan75Co>gmail.com
Sent: Thursday, April 23, 2015 11:04 AM
To: Robert Sweetaoole
Subject: Attorney General Letter
E
Attached is the letter I will send to the Attorney General. Note that I added Exhibit F to include the RICO
Complaint.
Unless you advise to the contrary, I will have this letter along with all of the exhibits, including the RICO
Complaint, prepared and mailed to AG Bondi on Monday.
Thanks.
Scott W. Morgan
(561) 752-1936
1
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:05 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: 7-7-15 email conference
This message originated from outside your organization
From: scottmorgan75 gmail.com
Sent: Tuesday, July 07, 2015 4:06 PM
To: Macfarlane. Mary
Subject: Re: Gulf Stream
4:00 Thursday is good for me.
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
From: Macfarlane, Mary
Sent: Tuesday, July 07, 2015 2:51 PM
To: scottmorgan75(agmail.com; mailto:rsweetapple(dsweetapplelaw.com
Cc: OConnor, Joanne M. ; mailto:cbailey(alsweetapplelaw.com
Subject: Gulf Stream
Mr. Richman and Mr. Sodhi are available for a conference call on Thursday, July 9 at 4:00 p.m. Please confirm that you
are available and, if so, I'll send call-in information to all. Thank you.
JONES FOSTER
Mary T. Macfarlane Secretary to I -I. Adams Weaver and Joanne NI. O'Connor
Direct Dial: 561.650.0496 Fax: 561.650.5300 1 mmacfarlaneQ onesfoster.com
Jones, Foster, Johnston & Stubbs, P.A.
Flagler Center Tower, 505 South Flagler Drive, Suite 1100, West Palm Beach, Florida 33301
561-659-3000 1 www.jonesfoster.com
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged
and confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying
of this email is prohibited. Please immediately notify us by email and delete the original message.
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:04 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: 7-21-15 email RICO appeal
This message originated from outside your organization
From: scottmorgan75Calgmail.c0m
Sent: Tuesday, July 21, 2015 3:25 PM
To: Joanne O'Connor ; Robert Sweetaoole
Subject: RICO appeal
Hi Joanne,
The Commission voted last week to authorize an appeal.
Per our conversation, would you please diary for the filing date.
Thanks.
Scott
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:03 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: 10-1-15 email Conference Call on Brief
This message originated from outside your organization
From: scottmorgan75Calgmail.com
Sent: Thursday, October 01, 2015 12:59 PM
To: Joanne O'Connor ; Robert Sweetapple ; Eric Sodhi
Subject: Conference Call on Brief
Joanne,
Would you please make sure everyone has a copy of your brief and then set up a telephone conference in the
next few days to go over it?
Thanks.
Scott W. Morgan
(561) 752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:36 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: Email 1-8-15 Friday - RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et AI.
This message originated from outside your organization
From: scottmorgan75Ca)gmail.com
Sent: Thursday, January 08, 2015 12:03 PM
To: Dottie Costonis
Subject: Re: Friday - RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
That's good.
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
From: Dottie Costonis
Sent: Thursday, January 08, 2015 11:41 AM
To: Cynthia Bailey ; mailto:scottmorgan75Calgmail.com
Subject: Friday - RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Mayor Morgan:
Could you be available on Friday for a meeting at 10:00 a.m.?
0
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
1
Direct: 561.803.3506
Email: DCostonis@riclimangreeccom
www.RichmanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the reamed recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited. Please immediately notify us by email and delete die original message..
From: Cynthia Bailey [mailto:cbailey@sweetapplelaw.com]
Sent: Thursday, January 08, 2015 11:23 AM
To: Dottie Costonis
Subject: RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Yes. He had as depo but it is being rescheduled so he is free all day. Let me know what time you are thinking and I will
put it on his calendar. Thanks!
CYNTHIA J. BAILEY
Certified Paralegal/Florida Certified Paralegal/Florida Registered Paralegal
Sweetapple, Broeker & Varkas, P.L.
20 SE 3rd Street
Boca Raton, FL 33432
(561) 392-1230 (t) x. 305
(561) 394-6102 (f)
cbailev@sweetaoolelaw.com
STATEMENT OF CONFIDENTIALITY
The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this
message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate,
maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this
message to any person other than the intended recipient(s) is not intended in any way to waive privilege or
confidentiality.
From: Dottie Costonis [mailto:DCostonisCalrichmangreer.coml
Sent: Thursday, January 08, 2015 11:21 AM
To: Cynthia Bailey; Scott Morgan (scottmoraan7561omail.com); Robert Sweetapple
Cc: Gerald F. Richman; Eric M. Sodhi; Leora B. Freire; ioconnorCcljonesfoster.com
Subject: RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Probably 1-2 hours. Is he available late Friday morning?
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonis(a4ichmangreer.com
www.RichmanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited. Please immediately notify us by email and delete the original message..
From: Cynthia Bailey[mailto:cbailevca)sweetapplelaw.coml
Sent: Thursday, January 08, 2015 11:03 AM
To: Dottie Costonis; Scott Morgan (scottmorgan75(olgmail.com); Robert Sweetapple
Subject: RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Hi Dottie,
Friday would be better for Bob. How long do you expect the meeting to take? Thank you.
CYNTHIA J. BAILEY
Certified Paralegal/Florida Certified Paralegal/Florida Registered Paralegal
Sweetapple, Broeker & Varkas, P.L.
20 SE V Street
Boca Raton, FL 33432
(561) 392-1230 (t) x. 305
(561) 394-6102 (f)
cbailev@sweeta oolelaw.com
STATEMENT OF CONFIDENTIALITY
The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this
message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate,
maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this
message to any person other than the intended recipient(s) is not intended in any way to waive privilege or
confidentiality.
From: Dottie Costonis[maiito:DCostonis(arichmanareer.com]
Sent: Thursday, January 08, 2015 10:59 AM
To: Scott Morgan (scottmorgan75(ftmail.com); Cynthia Bailey; Robert Sweetapple
Subject: FW: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Mr. Sweetapple and Mayor Morgan:
Are you available either Thursday or Friday next week for a meeting? Thanks.
0
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonisCebrichmangreer.com
www.RiclimanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited. Please immediately notify us by email and delete the original message..
From: OConnor, Joanne M.[mailto:]OConnorCabionesfoster.com]
Sent: Thursday, January 08, 2015 10:03 AM
To: Dottie Costonis
Subject: RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Thursday and Friday are good. Can't do Tuesday until about 330
JONESFOSTER
—M1 IWt" kAl CNet, PA.
Joanne M. O'Connor Attorney
Direct Dial: 561.650.0498 1 Fax: 561.650.5300 1 joconnor@ionesfoster.com
Jones, Foster, Johnston & Stubbs, P.A.
Flagler, Center lower, 505 South Hagler Drive, Suite 1100, \Fest Palm Beach, Florida 33401
561-659-3000 1 www.jonesfoster.com
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged
and confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying
of this email is prohibited. Please immediately notify, us by email and delete die original message.
From: Dottie Costonis[mailto:DCostonis(cbrichmanareer.coml
Sent: Wednesday, January 07, 2015 5:29 PM
To: Robert Sweetapple; scottmoraan75(damail.com: Cynthia Bailey; OConnor, Joanne M.
Cc: Gerald F. Richman; Leora B. Freire; Eric M. Sodhi; Rodney Trice
Subject: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Please let me know your availability for a meeting at our office on either Tuesday (1/13) at 2:00 p.m. or later; Thursday
(1/15) or Friday 1/16) morning or afternoon. Thank you.
0
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostoniserichmanereer.com
www.RichmanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to tic named recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited. Please immediately notify us by email and delete the original message..
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:34 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: Email 1-16-15 Letters from O'Boyle
Attachments: Scan_pdf
This message originated from outside your organization
From: scottmoroan75Ca)gmail.com
Sent: Friday, January 16, 2015 1:37 PM
To: esodhKDrichmanareer.com ; Gerry Richman
Subject: Fw: Letters from O'Boyle
Eric ---attached are the two letters I recently received from O'Boyle. One of them addresses his desire for
settlement.
From: scottmorean75(0Rmail.com
Sent: Tuesday, December 23, 2014 8:44 AM
To: Joanne O'Connor ; Robert Sweetaoole ; Gerry Richman
Subject: Letters from O'Boyle
Yesterday, the attached two letters were hand -delivered to Town Hall.
Please advise how you wish to respond.
Scott W. Morgan
(561) 752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:34 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: Email 1-19-15First Quarterly 2015 Gulf Stream Patriot
Attachments: G U LFSTREAM PATRIOT 1 _pdf
This message originated from outside your organization
From: scottmoraan75Ca1gmail.com
Sent: Monday, January 19, 2015 11:58 AM
To: Robert Sweetaople ; Joanne O'Connor ; Gerry Richman
Subject: Fw: First Quarterly 2015 Gulf Stream Patriot
Gulf Stream residents received this email today.
While O'Hare and O'Boyle have not made individual settlement demands in their public records cases against
the Town, both of them have requested global settlements to resolve all of the cases at one time. This
website/newsletter is another example, and follows the settlement letter from O'Boyle in December and the
Public Comment requests for settlement by O'Hare and O'Boyle at several Gulf Stream Commission Meetings.
Scott W. Morgan
1315 Neptune Dr.
Boynton Beach, FL 33426
(561)752-1936
From: Gulf Stream Patriot
Sent: Monday, January 19, 2015 11:02 AM
To: Gulfstreampatriot(ftmail.com
Subject: First Quarterly 2015 Gulf Stream Patriot
Dear Gulf Stream Resident:
Attached to this email, please find the first quarterly edition of the Gulf Stream Patriot. We hope you enjoy it.
Additionally, the Patriot can be viewed on-line at www.guIfstreampatriot.com. We look forward to hearing
your comments and hope that you participate in the Survey Question.
Your thoughts and comments are welcome!
Have a wonderful day.
Gulf Stream Patriot
Administrator
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:32 PM
To: Hudson Gill; Trey Nazzaro; OConnor, Joanne M.
Subject: Fw: EMAIL 1-21-15 Gulf Stream Patriot Invites You to Participate In Our Survey
This message originated from outside your organization
From: scottmoraan75Ca�gmail.com
Sent: Wednesday, January 21, 2015 10:16 AM
To: Robert Sweetaoole ; Gerry Richman ; Eric Sodhi ; Joanne O'Connor
Subject: Fw: Gulf Stream Patriot Invites You to Participate In Our Survey
Below is an email that was apparently sent last night to all Gulf Stream residents. It is obviously designed to
build public support for settling the lawsuits.
I am not certain but I believe O'Boyle is the author of Gulf Stream Patriot.
Regardless, O'Boyle and O'Hare are trying to convince the Town residents and Commissioners to settle the
lawsuits they have filed against Gulf Stream.
This email is an electronic act and The Gulf Stream Patriot polemic was both e-mailed and sent by US Mail to
every resident. (I will send you the actual hard copy) In addition, both O'Boyle and O'Hare have made public
comments at Commission Meetings designed to pressure the Town into settling their cases (I am having these
statements typed up for you), plus O'Boyle sent the letter of settlement to me both in hard copy and in e-mail
form.
We now have ample evidence of O'Boyle and O'Hare using the legal system to achieve "settlements".
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561)752-1936
From: Gulf Stream Patriot
Sent: Tuesday, January 20, 2015 7:16 PM
To: Gulf Stream Patriot
Subject: Gulf Stream Patriot Invites You to Participate In Our Survey
We invite you to participate in our survey question:
Are you in favor of the Town reaching a peaceful resolution with Mr. O'Boyle and Mr. O'Hare, which would
end all the expense and litigation in a prompt fashion?
Click here: http://www.gulfstreampatriot.com/survey.htmI
Thank you for participating!
Renee Basel
From: scottmorgan7S@gmail.com
Sent: Tuesday, November 1, 2016 3:21 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: Email 1-23-15 Gulf Stream Commission Meeting- Settlement Requests
Attachments: Budget Meeting Sept_ 12, 2014_pdf; Commission Meeting Dec_ 12, 2014_pdf;
Commission Meeting Jan_ 9, 2015_pdf; Commission Meeting July 11, 2014_pdf;
Commission Meeting Nov_ 14, 2014_pdf; Commission Meeting Oct_ 10, 2014_pdf
This message originated from outside your organization
From: scottmorean75@Rmail.com
Sent: Friday, January 23, 2015 11:03 AM
To: Robert Sweetaoole ; Joanne O'Connor ; Gerry Richman ; Eric Sodhi
Subject: Gulf Stream Commission Meeting- Settlement Requests
Attached are portions of public comments made by O'Boyle and O'Hare at Gulf Stream Commission Meetings
between July 2014 and January 2015.
The texts are not completely accurate because our Town Clerk typed them while listening to the audio -tapes
of the meetings so there are spelling and grammatical errors and some sentences don't flow completely and
words are missed or mistaken because of difficulty hearing the taped voices or hand -typing from voice
recordings.
Overall, however, two things become clear:
First, both O'Boyle and O'Hare are trying to persuade the Town to sit down with them to settle their lawsuits.
They threaten additional lawsuits and they threaten the Town with insolvency caused by legal fees --because
they will not withdraw any of their lawsuits absent a settlement agreement.
Second, O'Hare has publicized both the written agreement as well as the substance of the confidential
discussions occurring at the Mediation Conference at Bob Sweetapple's office last year. Both O'Boyle and
O'Hare reference the meeting in comments and in threats of retaliatory action designed to bring Gulf Stream
to the settlement table.
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:15 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: Email 2-9-15 Filing of RICO action this week
This message originated from outside your organization
From: scottmorgan7SC gmail.com
Sent: Monday, February 09, 2015 10:43 AM
To: Eric Sodhi ; Gerry Richman ; Robert Sweetapple ; Joanne O'Connor
Subject: Filing of RICO action this week
Good morning Eric,
Our next Gulf Stream Commission Meeting is this Friday.
I would like to have the RICO action filed before then, as I want to be in a position to announce the RICO filing
to the public and then to seek authority from the Commissioners to file a Complaint against CAN next week
with the Florida Office of Attorney General.
Would you please confirm when the action gets filed?
Scott W. Morgan
(561) 752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:14 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: Email 2-10-15 Defendants in RICO Complaint
This message originated from outside your organization
From: scottmorgan75@Rmail.com
Sent: Tuesday, February 10, 2015 10:47 AM
To: Eric Sodhi ; Robert Sweetaoole ; Joanne O'Connor ; Gerry Richman
Subject: Defendants in RICO Complaint
Eric,
I believe that you should identify, if you have not already done so, both Giovani Mesa and Nickalaus Taylor as
co-conspirators and name them as Defendants in the RICO action.
Bar Complaints have been filed against these two so they should be included along with the other lawyers in
the Complaint.
Regards,
Scott W. Morgan
(561)752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:08 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: Email 4-22-15 Martini-Russell-CAFI
Attachments: Letter to Attorney General re Revoking CAFI Charter (1.26.15).docx; Exhibits to Attorney
General re Revoking CAFI Charter_pdf
This message originated from outside your organization
From: scottmorgan75(&gmail.com
Sent: Wednesday, April 22, 2015 2:37 PM
To: Robert Sweetaoole
Subject: Fw: CAFI
We have not done anything regarding this request to the attorney general, as we were following the progress
of the RICO lawsuit and also awaiting some decisions in various other cases.
Do you recommend that we file it now or continue to wait?
CAFI filed its Annual Report today, which shows the Officers/Directors as Brenda Russell, Denise Demartini,
Kathleen Laca & Peter Dileo.
Scott W. Morgan
(561) 752-1936
From: Cynthia Bailey
Sent: Tuesday, January 27, 2015 3:51 PM
To: scottmorgan75(obgmail.com
Cc: Robert Sweetaoole
Subject: CAFI
Mayor Morgan,
Please see attached correspondence with attachments for your review. Thank you.
CYNTHIA J. BAILEY
Certified Paralegal/Florida Certified Paralegal/Florida Registered Paralegal
Sweetapple, Broeker & Varkas, P.L.
20 SE 3rd Street
Boca Raton, FL 33432
(561) 392-1230(t) x. 305
(561) 394-6102(f)
cba ileyCa)sweetapplelaw.com
STATEMENT OF CONFIDENTIALITY
The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this
message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate,
maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this
message to any person other than the intended recipient(s) is not intended in any way to waive privilege or
confidentiality.
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:42 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: EMAIL 10-13-14 RICO Action- O'Boyle
This message originated from outside your organization
From: scottmoroan75Ca�gmail.com
Sent: Monday, October 13, 2014 1:16 PM
To: orichmanCalrichmangreer.com
Cc: rsweetaoDle(&sweetaoDlelaw.com
Subject: RICO Action- O'Boyle
Hi Jerry,
Thank you for participating in our Town Commission meeting on Friday. As you know, the Commission voted
unanimously to retain your firm to advance the federal class action RICO claims against O'Boyle, O'Hare and
related entities and individuals.
At your convenience, would you please send a representation letter to our town manager, William Thrasher,
acknowledging the terms of your representation, which will be based on the 50% hourly/35% contingency rate
approved by the Commission.
Mr. Thrasher's address is:
TOWN OF GULF STREAM
100 SEA RD.
GULF STREAM, FL 33483
Please feel free to speak with Bob Sweetapple or Joanne O'Connor regarding any information or assistance
needed in preparing the Complaint.
Best regards,
Scott W. Morgan
w-561-752-1936
c-561-573-6006
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:42 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: EMAIL 10-25-14 Gulf Stream legal action
This message originated from outside your organization
From: Scott Morgan
Sent: Saturday, October 25, 2014 12:07 PM
To: grichmanCalrichmangreer.com ; ioconnor(&ionesfoster.com ; rsweetaooleCalsweetaoolelaw.com
Subject: Gulf Stream legal action
If the three of you are available on Tuesday or Wednesday, I think we should meet to discuss everyone's
thoughts on the type of actions to be filed against O'Boyle and O'Hare. There are arguments to be made for
federal vs. state court RICO as well as for a separate conspiracy to abuse process action. I would like to have a
consensus on moving forward.
Let me know if Tues or Wed works for you.
Scott
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:41 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw: Email 11-11-14 Telephone Conference - Town of Gulf Stream
This message originated from outside your organization
From: scottmoroan75@gmail.com
Sent: Tuesday, November 11, 2014 3:09 PM
To: Dottie Costonis
Subject: Re: Telephone Conference - Town of Gulf Stream
Anytime is fine for me.
Thanks.
Scott Morgan
Sent from my iPhone
On Nov 11, 2014, at 2:52 PM, Dottie Costonis <DCostonis@rich manareer.com> wrote:
Please let me know your availability for a telephone conference tomorrow, November 12, in the
afternoon. I will circulate a call in number when we have a time good for all. Thanks.
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonis@richmangreer.com
www.RichmanGreer.com
1
D
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not
intended to be and cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be
privileged and confidential. If you are not the intended recipient, you received this in error. If so, any review,
dissemination, or copying of this email is prohibited. Please immediately notify us by email and delete the original
message..
From: Gerald F. Richman
Sent: Monday, November 10, 2014 2:09 PM
To: Scott Morgan
Cc: Robert Sweetapple; Joanne OConnor
Subject: Re: Telephone Conference
I have asked Dottie to schedule for. Wednesday
On Nov 10, 2014, at 8:43 AM, "Scott Morgan" <scottmorean75 n pmail.com> wrote:
Gerry,
I would like to have a short conference with the lawyers to review the recent Fla
Ctr for Investigative Reporting article and to plan out our next steps in the
litigation.
Would you have your secretary schedule a time?
Thanks.
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:40 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: EMAIL 11-18-14 Any developments in the CAR case?
This message originated from outside your organization
From: Scott Morgan-Gmail
Sent: Tuesday, November 18, 2014 9:24 PM
To: Robert Sweetaople
Subject: Re: Any developments in the CAFI case?
I am interested to know if O'boyle is dismissing ongoing cases.
Just the fact that he would withdraw several of them would suggest they were knowingly filed in bad faith and
would tend to help with the RICO claim.
Scott
On Nov 18, 2014, at 5:50 PM, Robert Sweetapple <rsweetapple@sweetapplelaw.com> wrote:
Regards, Bob Sweetapple
Begin forwarded message:
From: Pleadings <pleadinas@sweetapplelaw.com>
Date: November 18, 2014 at 12:53:31 PM EST
To: Cynthia Bailey <cbaileyC@sweetapplelaw.com>, Robert Sweetapple
<rsweetapple@sweetapplelaw.com>, Deborah Smith
<dsmith@sweetapplelaw.com>
Subject: FW: Any developments in the CAR case?
From: tris.korten@gmail.com on behalf of Tristram
Korten [SMTP:KORTEN @ FCI R.ORG
Sent: Tuesday, November 18, 2014 12:52:07 PM
To: Pleadings
Subject: Any developments in the CAR case?
Auto forwarded by a Rule
Hi Bob,
I'm checking with you to see what has transpired since the article came out. One
defendant, Blue Water Ranch, contacted me to say that CAFI/O'Boyle voluntarily
dismissed their case, and I'm wondering if you've heard of others. Also, I've
heard rumors of the AG appointing a special prosecutor, any knowledge of that?
Let me know.
Best,
Tristram Korten
Editor
Florida Center for Investigative Reporting
www.fcir.org
(305) 609-8262
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:39 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: EMAIL 11-19-14 Joel Chandler email RE: Gulf Stream v. OHare - RICO
Attachments: JoelEMail_111714_pdf; OHARE public comments 11-14-14.docx
This message originated from outside your organization
From: scottmoroan75Cc1gmail.com
Sent: Wednesday, November 19, 2014 5:10 PM
To: Robert Sweetaoole ; Joanne M. OConnor
Subject: Fwd: Joel Chandler email RE: Gulf Stream v. OHare - RICO
Sent from my Whone
Begin forwarded message:
From: "Chris O'Hare"<chrisoharegulfstream@gmail.com>
Date: November 19, 2014 at 10:45:29 AM EST
To: "scottmorgan75@gmail.com" <scottmorgan75@gmail.com>, smorgan@gulf-stream.org,
rwganger@bellsouth.net, rganger@gulf-stream.org, loanorthwein@gmail.com,
lorthwein@gulf-stream.org, tom@macmillanstanlev.com, tstanlev@gulf-stream.org,
Pasodonna@gmail.com, dwhite@gulf-stream.org
Subject: Joel Chandler email RE: Gulf Stream v. OHare - RICO
Dear Scott,
I am sending you by attachment a copy of an email written recently by Mr. Joel Chandler. He wrote this
email after having read a transcript of the comments I made during the public meeting of the Town
Commission on November 14, 2014. Those comments are attached as well for your reference.
My purpose in sharing Mr. Chandler's email with you is to again encourage you to seriously reconsider
the merits of spending public money and Town resources to pursue a RICO action against me simply
because I will not dismiss my claims against the Town. Mr. Chandler's comments should leave no doubt
in your mind that I am innocent of any activity which you have publicly claimed where the reason for your
intended RICO action against me.
It is my opinion that much grief and expense could be saved by all concerned if you had knowledge of Mr.
Chandler's email - sooner rather than later.
Sincerely,
Chris O'Hare
---------- Forwarded message ----------
Date: Wed, Nov 19, 2014 at 8:56 AM
Subject: Joel's e-mail
Sent from my iPhone
Begin forwarded message:
> From: "Chris O'Hare" <chrisoharegulfstream@gmail.com>
> Date: November 19, 2014 at 10:45:29 AM EST
> To: "scottmorgan75@gmail.com" <scottmorgan75@gmail.com>, smorgan@gulf-stream.org,
rwganger@bellsouth.net, rganger@gulf-stream.org, joanorthwein@gmail.com, jorthwein@gulf-stream.org,
tom@macmillanstanley.com, tstanley@gulf-stream.org, pasodonna@gmail.com, dwhite@gulf-stream.org
> Subject: Joel Chandler email RE: Gulf Stream v. OHare - RICO
> Dear Scott,
> I am sending you by attachment a copy of an email written recently by Mr. Joel Chandler. He wrote this
email after having read a transcript of the comments I made during the public meeting of the Town
Commission on November 14, 2014. Those comments are attached as well for your reference.
> My purpose in sharing Mr. Chandler's email with you is to again encourage you to seriously reconsider the
merits of spending public money and Town resources to pursue a RICO action against me simply because I will
not dismiss my claims against the Town. Mr. Chandler's comments should leave no doubt in your mind that I
am innocent of any activity which you have publicly claimed where the reason for your intended RICO action
against me.
> It is my opinion that much grief and expense could be saved by all concerned if you had knowledge of Mr.
Chandler's email - sooner rather than later.
> Sincerely,
> Chris O'Hare
>---------- Forwarded message ----------
> Date: Wed, Nov 19, 2014 at 8:56 AM
> Subject: Joel's e-mail
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:38 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: Email 11-20-15 CONFIRMING TELECON TODAY 3:30 PM RE: Regarding: GULF
STREAM, TOWN OF - O'BOYLE, Et Al.
This message originated from outside your organization
From: Scott Morgan
Sent: Thursday, November 20, 2014 12:10 PM
To: Dottie Costonis
Subject: Re: CONFIRMING TELECON TODAY 3:30 PM RE: Regarding: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Can we do 2:30. That is better for Bob Sweetapple and myself.
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
From: Dottie Costonis
Sent: Thursday, November 20, 2014 10:23 AM
To: joconnor(a ionesfoster.com ; rsweetaooleCalsweetapplelaw.com ; mailto:scottmorgan75ecimail.com ;
mailto:cbai Iey(&sweetapplelaw.com
Cc: Gerald F. Richman ; Leora B. Freire
Subject: CONFIRMING TELECON TODAY 3:30 PM RE: Regarding: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Confirming a telephone conference call today at 3:30 p.m. Call in number: 561-803-3535; conference
number: 652; Access code: 250
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonis@richmangreer.com
www.RichmanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited. Please immediately notify us by email and delete the original message..
From: Dottie Costonis
Sent: Wednesday, November 19, 2014 3:15 PM
To: 'joconnor@jonesfoster.com';'rsweetapple@sweetapplelaw.com'; Scott Morgan (scottmorgan75@gmail.com)
Cc: Gerald F. Richman; Leora B. Freire
Subject: Regarding: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Please let me know your availability for a telephone conference on Thursday, November 20. When time is confirmed I
will send out a call in number. Thanks.
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:37 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw: EMail 12-16-14 O'Boyle update
This message originated from outside your organization
From: scottmorgan75Colgmail.com
Sent: Tuesday, December 16, 2014 10:26 AM
To: Gerry Richman ; Robert Sweetaoole ; Joanne O'Connor
Subject: O'Boyle update
Good morning Gerry,
When your office has completed its research, would you please schedule a telephone conference to update us
on the status of claims against O'Boyle and O'Hare?
Thanks.
Scott W. Morgan
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:20 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw:1-23-15 email: Decision- Gray v. Lutheran Social Services --CHANDLER
This message originated from outside your organization
From: scottmoroan75Colymail.com
Sent: Friday, January 23, 2015 4:25 PM
To: Robert Sweetaoole
Cc: Joanne O'Connor ; Gerry Richman ; Eric Sodhi
Subject: Re: Decision- Gray v. Lutheran Social Services --CHANDLER
Let's discuss this first. You should double check the dates of Chandler's involvement, as it may affect his
credibility as a witness in our case.
Judge Schemer says at paragraph 5: "Chandler picked up Gray and drove him to LSS and several other places
that day for the sole purpose of making public records requests." (That day being June 16, 2014.)
But according to the information you obtained from Chandler, and as set forth in paragraph 67 of the
Counterclaim for Declaratory Judgment, Chandler did not submit his resignation to CAR until June 30, 2014,
two weeks after he assisted Gray with the public records request from LSS. (Which Judge Schemer called
"bogus", paragraph 20).
Certainly, by May, Chandler was feeling misled and deceived by O'Boyle and CAR, and by mid-June, he had
received advice from attorneys to immediately resign his position with CAR. Perhaps he waited until June 30
to actually submit his resignation because of timing and the distance between his home and the office. (would
timing involve a paycheck?) I am sure that by June 16, Chandler felt no loyalty to his employer and to
personally hand in a resignation was simply a formality. That being said, he was still technically employed by
CAR on June 16 (presumably being paid) and his assistance to Jeffrey Gray did not serve CAR's interests.
Scott
From: Robert Sweetaoole
Sent: Wednesday, January 21, 2015 10:06 PM
To: scottmoroan75(@omail.com
Cc: Robert Sweetaoole ; Joanne O'Connor ; Gerry Richman ; Eric Sodhi
Subject: Re: Decision- Gray v. Lutheran Social Services --CHANDLER
I think we should file a Request for Judicial Notice before Judge Blanc.
Regards, Bob Sweetapple
On Jan 20, 2015, at 9:48 AM, "scottmorean75@gmail.com" <scottmorean75C0Demail.com> wrote:
Attached is a Notice of Filing in Gray v. Florida East Coast Railway regarding Duval County Judge
Jack Schemer's December 1, 2014 decision in Gray v. Lutheran Social Services.
It appears that as soon as Chandler resigned from Citizen's Awareness, he began working with
Jeffrey Gray and attorney Abraham Shakfeh to generate "gotcha" Public Records Act lawsuits.
Judge Schemer quickly saw through the scam; his decision is particularly critical of the actions
and misbehavior of these men in perverting the intent of the P.R.A.
You might consider contacting Daniel Bean, Esq. (attorney for Lutheran Social Services) and
Jennifer Mansfield (attorney for Florida East Coast Railway) for information helpful to the RICO
case and our state counterclaims.
Scott W. Morgan
1315 Neptune Dr.
Boynton Beach, FL 33426
(561) 752-1936
<Gray v Lutheran Social Services.pdf>
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:15 PM
To: OConnor, Joanne M.; Hudson Gill; Trey Nazzaro
Subject: Fw:2-18-15 email: Chandler v. Gulf Stream
Attachments: 1GQ0770-summons-pdf; 1GQ0968-complaint enforce public records act-pdf; 1 H62157 -
transcript closed door session september 13 2013 -PDF; 1 HW7317-release of all claims
fully executed -PDF; 1 HI -1948 -ring enclosing settlement check and documents_pdf
This message originated from outside your organization
From: scottmorgan75Co1gmail.com
Sent: Wednesday, February 18, 2015 3:16 PM
To: Robert Sweetaoole
Subject: Fw: Chandler v. Gulf Stream
:..
I don't know if you've seen these items from the Chandler v. Gulf Stream case where the Town paid a
settlement to Chandler. As Joanne points out below, Bill Ring was involved in this scam. And I have to wonder
how someone like Ring got involved with Chandler in the first place, and whether Ring then helped persuade
O'Boyle to use Chandler to pursue the scam on a grander scale.
Scott
From: OConnor, Joanne M.
Sent: Monday, December 08, 2014 3:50 PM
To: Scott Morgan
Cc: Randolph, John C.
Subject: FW: Gulf Stream
Scott —
have sent this information along to Eric Sodhi and Gerry Richman. From February to June 2013, during the
time that O'Boyle was making public records requests, Joel Chandler walked into Gulf Stream on April 15,
2013 with O'Boyle and Ryan Witmer (former lawyer with the O'Boyle Law Firm — had not been admitted in
Florida at the time) and all three made records requests. Bill Ring with Ring PA filed suit on Chandler's behalf
against the Town on May 6, 2013 and served the Town on July 9, 2013. We sent them $1500 on November
1511 and it was dismissed in December 2013. 1 have a call in to Skip for more information re how it came about.
This may provide us with a hook re Gulf Stream paying out a settlement in reliance on the conspirators windfall
scheme although it places Chandler right in the mix. While not a suit filed by the O'Boyle Law Firm, it was filed
by Bill Ring who is now the supervising attorney of the O'Boyle Law Firm after heading up CAR.
Joanne
JONESFOSTER
Joanne M. O'Connor Attorney
Direct Dial: 561.650.0498 1 Fax: 561.650.5300 1 ioconnor(a,jonesfoster.com
Jones, Poster, Johnston R Stubbs, P.A.
Flagler Center Tower, 505 South Flagler Drive, Suite 1100, West Palm Beach, Florida 33401
561-659-3000 1 www.jonesfoster.com
Incoming cmads are filtered which may delay receipt. This email is personal to the named recipient(s) and may be Privileged
and confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copting
of this email is prohibited. Please immediately notify us by email and delete the original message.
Renee Basel
From: scottmorgan75@gmail.com
Sent: Tuesday, November 1, 2016 3:36 PM
To: Hudson Gill; OConnor, Joanne M.; Trey Nazzaro
Subject: Fw:Email Jan 8 2015 Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
This message originated from outside your organization
From: scottmoraan75Cagmail.com
Sent: Thursday, January 08, 2015 12:02 PM
To: Dottie Costonis
Subject: Re: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et AL
I am available Thurs or Fri.
Scott W. Morgan
HUMIDIFIRST
1315 Neptune Dr.
Boynton Beach, FL 33426
(561)752-1936
From: Dottie Costonis
Sent: Thursday, January 08, 2015 11:20 AM
To: Cynthia Bailey ; mailto:scottmoroan75Ca1gmail.com ; Robert Sweetaoole
Cc: Gerald F. Richman ; Eric M. Sodhi ; Leora B. Freire ; ioconnorCalionesfoster.com
Subject: RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Probably 1-2 hours. Is he available late Friday morning?
i
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonis@richmangreer.com
www.RichmanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communication issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited. Please immediately notify us by email and delete the original message..
From: Cynthia Bailey [mailto:cbailey@sweetapplelaw.com]
Sent: Thursday, January 08, 2015 11:03 AM
To: Dottie Costonis; Scott Morgan (scottmorgan75@gmail.com); Robert Sweetapple
Subject: RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Hi Dottie,
Friday would be better for Bob. How long do you expect the meeting to take? Thank you.
CYNTHIA J. BAILEY
Certified Paralegal/Florida Certified Paralegal/Florida Registered Paralegal
Sweetapple, Broeker & Varkas, P.L.
20 SE 3rd Street
Boca Raton, FL 33432
(561) 392-1230 (t) x. 305
(561) 394-6102 (f)
cbailev(@sweetapplelaw.com
STATEMENT OF CONFIDENTIALITY
The information in this e-mail is confidential and may be legally privileged. If you are not the named addressee, or if this
message has been addressed to you in error, you are directed not to read, disclose, reproduce, distribute, disseminate,
maintain, save or otherwise use this email. Please contact the sender at the above number immediately. Delivery of this
message to any person other than the intended recipient(s) is not intended in any way to waive privilege or
confidentiality.
From: Dottie Costonis [ma !Ito: DCostonis@richmanoreer.coml
Sent: Thursday, January 08, 2015 10:59 AM
To: Scott Morgan (scottmorgan75(a@mail.com); Cynthia Bailey; Robert Sweetapple
Subject: FW: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Mr. Sweetapple and Mayor Morgan:
Are you available either Thursday or Friday next week for a meeting? Thanks.
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonisRrichmangreer.com
www.RichmanGreer.com
U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and
cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged and
confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying of this email
is prohibited. Please immediately notify us by email and delete the original message..
From: OConnor, Joanne M. [mailto:JOConnor(&ionesfoster.coml
Sent: Thursday, January 08, 2015 10:03 AM
To: Dottie Costonis
Subject: RE: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Thursday and Friday are good. Can't do Tuesday until about 330
JONESFOSTER
___.._...___�..� )1ML�NU\ x an "fl . r M.
Joanne M. O'Connor Attorney
Direct Dial: 561.650.0498 1 Fax: 561.650.5300 1 joconnor(a�,,jonesfoster.com
Jones, Foster, Johnston & Stubbs, P.A.
Flagler Center Tower, i05 South Flagler Drive, Suite 1100, \\ est Palm Beach, Florida 33401
561-659-3000 1 www.jonesfoster.com
Incoming emails are filtered which may delay receipt. This email is personal to the named recipient(s) and may be privileged
and confidential. If you are not the intended recipient, you received this in error. If so, any review, dissemination, or copying
of this email is prohibited. Please immediately notify us by email and delete the original message.
From: Dottie Costonis [mailto:DCostonis(arichmanareer.coml
Sent: Wednesday, January 07, 2015 5:29 PM
To: Robert Sweetapple; scottmoraan75Culamail.com; Cynthia Bailey; OConnor, Joanne M.
Cc: Gerald F. Richman; Leora B. Freire; Eric M. Sodhi; Rodney Trice
Subject: Meeting RE: GULF STREAM, TOWN OF - O'BOYLE, Et Al.
Please let me know your availability for a meeting at our office on either Tuesday (1/13) at 2:00 p.m. or later; Thursday
(1/15) or Friday 1/16) morning or afternoon. Thank you.
0
Dottie Costonis / Legal Assistant to Gerald F. Richman
Richman Greer P.A.
One Clearlake Centre
Suite 1504
250 Australian Avenue South
West Palm Beach, Florida 33401
Office: 561.803.3500
Fax: 561.820.1608
Direct: 561.803.3506
Email: DCostonis@,richmangreer.com
www.RichmanGreer.com
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