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Home My Public Portal AboutPRR 16-2276From: Jonathan O'Boyle[mailto:joboyle@oboylelawfirm.com] Sent: Friday, July 15, 2016 5:12 PM To: OConnor, Joanne M. <JOConnor@jonesfoster.com> Cc: Richard Conforti <rconforti@dldlawyers.com>; Bill Thrasher<bthrasher@gulf-stream.org> Subject: RE: Records Request Joanne, I would also like a copy of the records which reflect Mr. Sweetapple's scope of employment and/or fee agreements with the Town. Thank you, standard provisions apply — estimates, productions schedules, ect prior to production. I think that this one should be easier then my outstanding requests. So if possible, I would like this request to take priority since I think it will get resolved more expediently than my other requests for litigation records —there I expect us to be working together to cull and streamline the process, especially since I think I am not the only one who has asked for RICO and Ward Case records. As per usual, just shoot me an email back if there is anything we can do to get from point A to Z as efficiently as possible. I am pretty open to suggestions. Jonathan O'Boyle, Esq., LLM. Licensed In Pennsylvania* Licensed In New Jersey* Licensed in Florida* The O'Boyle Law Firm, P.C. www.oboylelawfirm.com Pennsylvania Office 1001 Broad St. Johnstown, PA 15906 Tel: 814-535-5175 Fax: 215-893-3641 jobovle@oboylelawfirm.com New Jersey Office 10 Grove St. Haddonfield, NJ 08033 Tel: 814-535-5175 Fax: 215-893-3641 jobovle@oboylelawfirm.com Florida Office 1286 West Newport Center Drive Deerfield Beach, FL 33442 Office: 954-570-3533 Fax: 754-212-2444 jobovle@oboylelawfirm.com IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax -related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax -related matter(s) addressed herein. ----------------------------------------------------------- ----------------------------------------------------------- NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE INTENDED RECIPIENT OF THE TRANSMISSION, AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVED THIS E- MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND PLEASE DELETE THIS MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION. From: OConnor, Joanne M.[mailto:]OConnor(o)ionesfoster.coml Sent: Friday, July 15, 2016 8:45 AM To: Jonathan O'Boyle Cc: Richard Conforti; Bill Thrasher Subject: RE: Records Request Jonathan — I want to make sure that your records request below relates to Case No. 14-cv-81248, which has always been handled by Jeff Hochmann's firm and not by Sweetapple. Thanks, Joanne JONESFOSTER _JOWM N&Itaas,t., Joanne M. O'Connor Attorney 'Telephone: 561.650.0498 1 Fax: 561.650.5300 1 joconnor@ionesfoster.com Jones, Foster,) ohnston & Stubbs, P.A. Flagler Center Tower, 505 South Hagler Drive, Suite 1100, W est Palm Beach, Florida 3.3401 561-659-3000 1 www.ionesfoster.com Incoming emails are filtered which may delay receipt. 'Ibis email is personal to the named recipient(s) and may be privileged and confidential. If Von 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: Jonathan O'Boyle[mailto:ioboyle(a)obovlelawfirm.coml Sent: Wednesday, July 13, 2016 2:37 PM To: OConnor, Joanne M. Cc: Richard Conforti; Bill Thrasher; Jonathan O'Boyle Subject: RE: Records Request This message originated from outside your organization There was no opposition. The Plaintiff did not object. The Plaintiff agreed that funds should be disbursed and the records released under Chapter 119. Unless the Town wishes to appeal its own motion for costs, I don't see what the issue is. So how about we start production with emails where Scott Morgan or Robert Sweetapple received or sent an email. Where do we stand with the RICO request? I will note that I made it almost a year ago and gave the Town a large large lead time in getting ready for that. Jonathan O'Boyle, Esq., LLM. Licensed In Pennsylvania* Licensed In New Jersey* Licensed in Florida* The O'Boyle Law Firm, P.C. www.oboyielawfirm.com Pennsylvania Office 1001 Broad St. Johnstown, PA 15906 Tel: 814-535-5175 Fax: 215-893-3641 iobovle@obovlelawfirm.com New Jersey Office 10 Grove St. Haddonfield, NJ 08033 Tel: 814-535-5175 Fax: 215-893-3641 ioboyle@obovielawfirm.com Florida Office 1286 West Newport Center Drive Deerfield Beach, FL 33442 Office: 954-570-3533 Fax: 754-212-2444 iobovle@obovielawfirm.com IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax -related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax -related matter(s) addressed herein. ----------------------------------------------------------- ----------------------------------------------------------- NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE INTENDED RECIPIENT OF THE TRANSMISSION, AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVED THIS E- MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND PLEASE DELETE THIS MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION. From: OConnor, Joanne M.[mailto:JOConnor(aljonesfoster.com] Sent: Wednesday, July 13, 2016 12:32 PM To: Jonathan O'Boyle Cc: Richard Conforti; Bill Thrasher Subject: RE: Records Request Jonathan — Contrary to your representation below, the court docket in USDC Case No. 14-cv-81248 reflects that the litigation is not concluded. Instead, Plaintiffs have objected and yesterday filed a response (docket entry no. 56) to Defendant's motion to disburse funds in the court registry. The case will not be final unless and until this issue is fully resolved. Until the case is final, significant review of the file will need to occur relative to work product exemptions under the Public Records Act. I would suggest that you withdraw this public records request and resubmit it after this case is closed. Please let me know how you want to proceed. Thanks, Joanne JONESFOSTER louns to. a sIunas, 1� Joanne M. O'Connor \ttomey Telephone: 561.650.0498 1 Fax: 561.650.5300 ioeonnor(crejonesfoster.com Jones, Foster, Johnston & Stubbs, P.A. Flaglcr Center Power, 505 South Flagler Drive, Suite 1100, Rest Palin 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: Jonathan O'Boyle[mailto:ioboyle(@obovlelawfirm.coml Sent: Monday, July 11, 2016 8:17 PM To: OConnor, Joanne M.; Bill Thrasher Cc: Richard Conforti; Jonathan O'Boyle Subject: Records Request This message originated from outside your organization I would like copies of everything related to O'Boyle v. Thrasher, Ward, and Gulf Stream: Case No. 14 -CV - 81248. I want the file, all communications related to this case, every public record available. No redactions are necessary since the litigation has concluded. Thanks for the estimate in advance. If production needs to be tiered out in tranches, let me know, I am amenable. Thank you for your prompt reply. P.S. Joanne, now that Scott has determined that the Town has ceased to pursue the RICO case, is the Town willing to start production. I really don't want to litigate and get these things through an immediate hearing, but these records are very important to me. Jonathan O'Boyle, Esq., LLN1. Licensed In Pennsylvania* Licensed In New Jersey* Licensed in Florida* The O'Boyle Law Firm, P.C. www.obovielawfirm.com Pennsylvania Office 1001 Broad St. Johnstown, PA 15906 Tel: 814-535-5175 Fax: 215-893-3641 iobovle@oboylelawfirm.com New Jersey Office 10 Grove St. Haddonfield, NJ 08033 Tel: 814-535-5175 Fax: 215-893-3641 jobovle@oboylelawfirm.com Florida Office 1286 West Newport Center Drive Deerfield Beach, FL 33442 Office: 954-570-3533 Fax: 754-212-2444 jobovle@obovielawfirm.com IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax -related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax -related matter(s) addressed herein. ----------------------------------------------------------- ----------------------------------------------------------- NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE INTENDED RECIPIENT OF THE TRANSMISSION, AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVED THIS E- MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND PLEASE DELETE THIS MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION. TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail July 19, 2016 Jonathan O'Boyle [mailto: iobovle(a)obovlelawfirm.coml Re: GS #2276 (RE: Records Request) I would also like a copy ofthe records which reflect Mr. Sweetapple's scope ofemployment and/or fee agreements with the Town. Thank you, standard provisions apply — estimates, productions schedules, ect prior to production. Dear Jonathan O'Boyle [mailto: iobovlena,obovlelawfirm.coml, The Town of Gulf Stream has received your public records request dated July 15, 2016. The original public record request can be found at the following link http://www2.gulf- stream.ore/weblink/O/doc/97447/Pagel.asnx. Please refer to the referenced number above with any future correspondence. The responsive records can be found at the following links: http://www2.culf- stream.ore/weblink/O/doc/5978/Pagel.asyx; htti)://WWW2.gulf- stream.org/weblink/O/doc/6696/Pagel.asvx. We consider this matter closed. Respectfully, Town Clerk, Custodian of the Records From: OConnor, Joanne M. [mailto:JOConnor@jonesfoster.com] Sent: Wednesday, July 20, 2016 11:55 AM To: Jonathan O'Boyle <joboyle@oboylelawfirm.com> Cc: Richard Conforti <rconforti@dldlawyers.com>; Bill Thrasher <bthrasher@gulf-stream.org> Subject: RE: Records Request Jonathan — With regard to your request in the first paragraph below, the Town would additionally identify the minutes of the December 12, 2014 Commission Meeting, which are publicly available on the Town's website. There are no conflict waivers responsive to your request other than the waiver by Scott Morgan that permitted Bob Sweetapple to represent the Town as well as him individually. With regard to your request in the second paragraph below for "all public records which have anything to do with the Florida Character and Fitness Committee or Gavagni or the Florida Board of Bar Examiners since 2013," please advise if this is intended to be different from prior requests you have made for the "UPL file" and communications between the Town and the Florida Board of Bar Examiners, e.g., PRR 1852 by you dated 6/11/15 to which the Town has previously responded, or you are asking whether there are any supplemental records since the Town's last response to that request. If the latter, I am believe that there are not, but will confirm. To the extent that you seek records "that have anything to do with...", you have failed to sufficiently specify the records that you seek with sufficient particularity to enable the Town to provide a good faith response. I would request that you clarify and we will endeavor to respond appropriately. Regards, Joanne JONESFOSTER Jou"mq & STuaas. ra. Joanne M. O'Connor :Attorney Telephone: 561.650.0498 1 Fax: 561.650.5300 1 joconnor(@,jonesfoster.com Jones, Foster, Johnston & Stubbs, P.A. Hagler Center Tower, 505 South Flagler Drive, Suite 1100, West Palm Beach, Florida 33401 561-659-3000 1 www.ionesfoster.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: Jonathan O'Boyle [mailto:jobovle@)obovlelavfirm.coml Sent: Tuesday, July 19, 2016 1:48 PM To: Bill Thrasher Cc: OConnor, Joanne M.; Richard Conforti Subject: RE: Records Request This message originated from outside your organization Thank you Mr. Thrasher. Your response here outlines 2 documents. The Minutes of Meeting 3.28.14 Commission and an April 16, 2016 letter of acceptance. I wanted to follow up and see if there were any additional documents which authorized Mr. Sweetapple to perform investigations, communicate with the Florida Bar, or work on any federal matters. I want to make it clear that my expectation is that when the Town expands Mr. Sweetapple's role from the circuit court civil litigation listed on his April 16, 2014 letter that such an expansion is a litigation expenditure decision responsive to my request as it defines the scope of his duties. Also, are there any waivers for potential conflicts of interest that may limit the scope of Mr. Sweetapple's authority, I would like any such waivers. If it is the Town's position that Mr. Sweetapple's work with the Florida Bar was exclusively to gain an advantage in the O'Boyel v. G.S. and O'Hare v. G.S. litigations listed on the April 16 letter, just let me know. I note that because Mr. Sweetapple wrote a letter to the Florida Bar Character and Fitness Board about me and I wanted the public records which show that such a letter was authorized by the Town or if it was outside the scope of his employment. As such, I would now like all public records which have anything to do with the Florida Character and Fitness Committee or Gavagni or the Florida Board of Bar Examiners since 2013. 1 suspect that the only topic of responsive documents will be the litigation and myself. Thank you guys so much. Jonathan O'Boyle, Esq., LLM. Licensed In Pennsylvania* Licensed In New Jersey* Licensed in Florida* The O'Boyle Law Firm, P.C. www.oboyfelawfirm.com Pennsylvania Office 1001 Broad St. Johnstown, PA 15906 Tel: 814-535-5175 Fax: 215-893-3641 ioboyleL@oboyielawfirm.com New Jersey Office 10 Grove St. Haddonfield, NJ 08033 Tel: 814-535-5175 Fax: 215-893-3641 'Coyle@ oboylelawfirm.com Florida Office 1286 West Newport Center Drive Deerfield Beach, FL 33442 Office: 954-570-3533 Fax: 754-212-2444 iabovlet@oboylelawfirm.com IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax -related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax -related matter(s) addressed herein. NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE INTENDED RECIPIENT OF THE TRANSMISSION, AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVED THIS E- MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND PLEASE DELETE THIS MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION. From: Bill Thrasher [mailto:bthrasher( lgulf-stream.orol Sent: Tuesday, July 19, 2016 12:30 PM To: Jonathan O'Boyle Subject: RE: Records Request Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s). If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Florida has a very broad public records law. Written communications regarding Town of Gulf Stream business are public records available to the public upon request. Your e-mail communications are therefore subject to public disclosure. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing.