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Home My Public Portal AboutPRR 16-2277RECORDS REQUEST (the "Request") Date of Request: 07.19.16 Requestor's Request ID#: 1253 REQUESTEE: Custodian of Records Sweetapple. Broeker & Varkas Custodian of Records Jones, Foster. Johnston & Stubbs Custodian of Records Town of Gulf Stream Custodian of Records Richman Greer, P.A. Custodian of Records Cole Scott & Kissane (Palm Beach Lakes) Custodian of Records Cole Scott & Kissane. (Lakeview Avenue) Custodian of Records Johnson Anselmo Murdoch Burke Piper & Hochman. P.A. REQUESTOR: Martin E. O'Boyle REQUESTOR'S CONTACT INFORMATION: E -Mail: records@commerce-group.com Fax: 954-360-0807 or Contact Records Custodian at records(acommerce-group.com; Phone: 954-360-7713; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442 REQUEST: Please provide conies of all communications (including, without limitation. E -Mails, letters, memos, notes and other forms of communications) between Ms. Candace Friis and the Town of Gulf Stream beginning January 1, 2013 through the date of this Reguest. ADDITIONAL INFORMATION REGARDING REQUEST: The term "Town of Gulf Stream" shall mean each of the following: the Town of Gulf Stream. its Commissioners, its Manager, its emplovees. its officers, its staff, its Police Department, its Police Officers its counsel and the following law firms: Sweetapple. Broeker & Varkas: Richman Greer, PA: Jones- Foster, Johnston & Stubbs: Cole. Scott & Kissane. P.A.: and Johnson Anselmo Murdoch Burke Piper & Hochman. P.A. (including, without limitation, the attorneys, employees and partners of each such law firm.) THIS REQUEST IS MADE PURSUANT TO ARTICLE I, SECTION 24 OF THE FLORIDA CONSTITUTION AND CHAPTER 119, FLORIDA STATUTES IF THE PUBLIC RECORDS BEING SOUGHT ARE MAINTAINED BY YOUR AGENCY IN AN ELECTRONIC FORMAT PLEASE PRODUCE THE RECORDS IN THE ORIGINAL ELECTRONIC FORMAT IN WHICH THEY WERE CREATED OR RECEIVED. SEE 61 19.01(2)(Fl. FLORIDA STATUTES. IF NOT AVAILABLE IN ELECTRONIC FORM, IT IS REQUESTED THAT THIS RECORDS REQUEST BE FULFILLED ON Il X 17 PAPER. NOTE: IN ALL CASES (UNLESS IMPOSSIBLE) THE COPIES SHOULD BE TWO SIDED AND SHOULD BE BILLED IN ACCORDANCE WITH Section 119.07(4)(2) (2) ALSO PLEASE TAKE NOTE OF §1 19,0741)(H) OF THE FLORIDA STATUTES, WHICH PROVIDES THAT "IF A CIVIL ACTION IS INSTITUTED WITHIN THE 30 -DAY PERIOD TO ENFORCE THE PROVISIONS OF THIS SECTION WITH RESPECT TO THE REQUESTED RECORD, THE CUSTODIAN OF PUBLIC RECORDS MAY NOT DISPOSE OF THE RECORD EXCEPT BY ORDER OF A COURT OF COMPETEN-r JURISDICTION AFTER NOTICE TO ALL AFFECTED PARTIES." ALL ELECTRONIC COPIES ARE REQUESTED TO BE SENT BY E-MAIL DELIVERY, PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC RECORDS REQUEST IN ADVANCE. It will be required that the Requester approve orany costs, asserted by the Agency (as defined In Florida Statute, Chapter 119.01 (Definitions)), in advance of any costs Imposed to the Requestor by the Agency. 'BY FULFILLING THIS RECORDS REQUEST, THE AGENCY ACKNOWLEDGES THAT THE RESPONSIVE DOCUMENTS ARE "PUBLIC RECORDS" AS DEFINED IN CHAPTER 119, FLORIDA STATUTES". I/P/NP/FLRR - 07.28.2015 TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail July 20, 2016 Martin E. O'Boyle [mail to: records@commerce-group.com] Re: GS #2277 (Records Request #1253) Please provide copies of all communications (including, without limitation, E -Mails, letters, memos, notes and other farms of communications) between Ms. Candace Friis and the Town of Gulf Stream beginning January 1, 2013 through the date of this Request. Dear Martin E. O'Boyle [mail to: records@commerce-group.com], The Town of Gulf Stream has received your public records request dated July 19, 2016. The original public record request can be found at the following link httD://www2.eulf- stream.ore/weblink/O/doc/97487/Pa eg l.ast)x. 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 June 20, 2016 Martin E. O'Boyle [mail to: recordsna,commerce-erouo.com] Re: GS #2277 (Records Request #1253) Pleaseprovide copies ofall communications (inchiding, without limitation, E -Mails, letters, memos, notes and other forms of communications) between Ms. Candace Friis and the Town of GufStream beginning January 1, 2013 through the date of this Request. Dear Martin E. O'Boyle [mail to: records(i4ommerce-erouo.coml, The Town of Gulf Stream received your public records requests on June 19, 2016. You should be able to view your request at the following link: h_ttp://www2.eulf- stream.ore/weblink/0/doc/97487/Paeel.asnx . In future correspondence, please refer to this public records request by the above referenced numbers. The Town's initial review of your request has generated several dozen e-mails between the town staff during the relevant time period. Additionally, Candace Friis is also a town resident in which she receives bi-monthly water bills and newsletters from the Town Mayor. We invite you to clarify the public records that you seek with more specificity. The Town estimates that to respond to your request will require approximately one hour of administrative support at $28.92 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 @ 28.92 = 28.92) — (.25 hours @ 28.92 = 7.23) = Deposit Due: $21.69 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 closed. Respectfully, Town Clerk, Custodian of the Records 7212016 GM i1 Re: FW: Oboyle subpoena 1 message Jdh on, Anselmo, Murdoch, Burke Mail - Re: FW: Oboyle subpoena Jeff Hochman <hochman@jambg.com> Jeff Hochman <hochman@jambg.com> Tue, Jun 7, 2016 at 6:48 PM To: "Friis, Candace" <Candace.Fri is@corcoran.com> Cc: Hudson Gill <hgili@jambg.com>, Karen Ericksen <Edcksen@jambg.com> Bcc: Jeff Hochman <hochman@jambg.com> Ms. Friis: As we discussed, my office represents the Town of Gulf Stream in this matter. Because I am not in a position to provide you with any legal advice, I would recommend that you consult with your own attorney. If you elect not to consult with an attorney, you should still consider expressing your concerns about the subpoena in a detailed letter directed to the clerk of the court. With respect to the Issues of untimely service and the absence of a witness fee, please note that some federal courts have held that the failure to meet both the service and witness fee requirements of Rule 45 of the Federal Rules of Civil Procedure results in ineffective service of the subpoena. Seg In the Matter of Dennis, 330 F. 3d 696, 704 (5th Cir. 2003) (stating that the plain meaning of Rule 45(b)(1) requires simultaneous tendering of witness fees and the reasonably estimated mileage allowed by law with service of a subpoena); Kimbroueh v. City of Cocoa, No. 6:05-cv-471-Od-31KRS, 2006 WL 3412258, at '1 (M.D. Fla. Nov. 27, 2006)(quashing a subpoena for failing to comply with the requirements of Rule 45, including tendering witness fees and mileage to witness). Despite these authorities, the judge in this case is still entitled to review all of the relevant facts and to make an Independent determination as to the validity of your subpoena. As a result, whether you decide to rely upon an attorney or to write your own letter, prompt action is recommended. I would only ask that you email me a copy of any document you submit to the clerk of the court. Jeff Jeffrey L. Hochman, Esq. Johnson, Anselmo, Murdoch, Burke, 2455 East Sunrise Blvd., Suite 1000 Fort Lauderdale, FL 33304 Office: (954) 463-0100 ext. 2917 Fax: (954)463-2444 Hochman@jambg.com Piper & Hochman, P.A. On Mon, Jun 6, 2016 at 10:18 PM, Friis, Candace <Candace.Friis@corcoran.com> wrote: Dear Jeff, I am a real estate broker at Corcoran and a dear friend of Scott and Lisa Morgan. I was served a subpoena on Wednesday June 1 from Martin O'boyle with the lawyer's name and email below. When I phoned him to let him know I was not going to be in the country, he told me he was not Mr. O'boyle's lawyer and that I would need to email Mr. O'boyle directly to let him know and I did. I was under the impression, you needed to be served a subpoena at least a week in advance. Am I correct in that? Please let me know what I should do. You can reach me on my cell or via email. Best, Candace Candace Friis Corcoran Group 561.573.9966 candace.fOis@coreoran.com www.candacefrils.com WSJ Top 250 USA t*ps9lm eil.google.comlmailluU'?d=2&ik=6c3163b5f6&vier=pt&q=Cwdace.Frils%40corcwan.com&qs=true&search=query&lig 1552o0dfl5f69f928siml=1552.. 12 721/2016 Johnson, Amelmo, Murdoch, Burke Mall - Re: FW: Oboyla subpoena From: Fnis, Candace Sent: Wednesday, June 01, 2016 4:22 PM To: ddesouzaCdesouzalaw.com Subject: Oboyle subpoena If you have Martin's email please let me know as I am not in the country on June 6th and will need to reschedule. Best, Candace Candace Friis Broker Associate The Corcoran Group 901 George Bush Blvd. Delray Beach, FL 33483 Direct: 561.573.9966 www.candacef6is.com Email: candace.friis@corcoran.com WSJ TOP 250 USA On 6/1116, 8:23 AM, "C454@corcoran.com" <C454@corcoran.com> wrote: All material herein is intended for information purposes only and has been compiled from sources deemed reliable. Though information is believed to be correct, it is presented subject to errors, omissions, changes or withdrawal without notice. Nothing in this email shall be deemed to create a binding contract to purchase/sell real estate. The sender of this email does not have the authority to bind a buyer or seller to a contract via written or verbal communications including, but not limited to, email communications. The information in this electronic mail message is the senders business confidential and may be legally privileged. It is Intended solely for the addressee(s). Access to this Internet electronic mail message by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. The sender believes that this E-mail and any attachments were free of any virus, worm, Trojan horse, and/or malicious code when sent. This message and its attachments could have been infected during transmission. By reading the message and opening any attachments, the recipient accepts full responsibility for taking protective and remedial action about viruses and other defects. The sender's company is not liable for any loss or damage arising in any way from this message or Its attachments. The Corcoran Group is a licensed real estate broker. hup0mail.google.cam/mailhd6"7u1=2&ik=6c3163b5f6&view=pt&q=Candace.Frlis%40cwca m.com&qs=we&search=query&th= 1552dOdf15169W&simI=1552.., 7/2 721/2016 Johnsen, Anselmo, Murdoch, Burke Mail - Case # 9:14-CV-81250-KAM Motion to Compel Gmii Jeff Hochman <hochman@jambg.com> Case # 9:14-CV-81250-KAM Motion to Compel 1 message Friss, Candace <Candace.Fdis@corcoran.com> Mon, Jun 20, 2016 at 11:26 AM To: Marty O'Boyle <moboyle@commerce-group.cam>, "hgili@jambg.com" <hgill@jambg.com>, "hochman@jambg.com" <hochman@jambg.com>, "joshua.goldstein@csklegal.cam"<joshus.goldstein@csklegal.com>, Damon Gasser <dgasser@simons igalos.com> Please see below the letter which was mailed to Judge Marra with the attached documentation. Dear Judge Kenneth A. Marra, I am writing to motion for a protective order to prevent a deposition from going forward with regards to Case N 9:14-CV- 81250-KAM. Please find attached the documentation supporting my request. Thank you kindly, Candace Friis Candace Friis T!1,; Corvnra-t Q (ty ' ,A C•. .;, , E:%d. r . ...- I", .; . FL 331f,3 6':: t 561.573.9966 www.candacefrils.com Em-: - candace.friis@corcoran.com WSJ TC, n 1. 1 Ili: All material herein is intended for information purposes only and has been compiled from, sources deemed reliable. Though information is believed to be correct, it is presented subject to errors, omissions, changes or withdrawal without notice. Nothing in this email shall be deemed to create a binding contract to purchase/sell real estate. The sender of this email does not have the authority to bind a buyer or seller to a contract via written or verbal communications including, but not limited to, email communications. The information in this electronic mail message is the sender's business confidential and may be legally privileged. It is intended solely for the addressee(s). Access to this Internet electronic mail message by anyone else Is unauthorized. if you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. The sender believes that this E-mail and any attachments were free of any virus, worm, Trojan horse, and/or malicious code when sent. This message and its attachments could have been infected during transmission. By reading the message and opening any attachments, the recipient accepts full responsibility for taking htlps://m ai I.google.com/mal I/u/0'7u=2&Ik=8c3163b5f6&vie v--pt&q=Candace.Fri is-1.40=wran.com&gs=true&search=query&th=1 S56e6bf3ea86cl3&siml=155... 12 7212016 Johmon, Atudmo, Murdoch, Burke Mall - Case #9:14-CV-61250•KAM Motion to Compel protective and remedial action about viruses and other defects. The sender's company is not liable for any loss or damage arising in any way from this message or its attachments. The Corcoran Group Is a licensed real estate broker. 2 attachments tea:•ol! r: ; lM tf. i Bahamas ticket ordecJPG `f 122K t. I J Ltr to O'Boyle 6.10.16.pdf 221K https:ffmail.google.camfmail/W0/7u1=28I k=6c3163b5f6&vlm=ptW—Candace.Fri is%40corcoran.com 8gs=lrue&search=gr4ry8th=1956e6bf3ea66c1385i m1=165... 212 da.. Avas"�Iwaw�aaa»I TO ^�w1�al r �t wAn Wr 1. 70M0r AM Thank you for choosing SIIvor Afr ayaf 1I.r W. a M .= I. ..." -- GcfJ4 .. nN I, V n!ti f1YA/P1a1[T NW MOM IntenraKion Baas riift RMI a hr• we a N'Mns" b /o✓ a bo, prpr b da Wrf/a w a ndaty /a .'a anW Wai Car a� UaM Ma Ulaal da aN..r�yagr al alMrar+wya f.M� R you woad Yn V ^.rMpa r W ~ Rir bays W*- VI W n M Daaknif a TnICawC arc l To OwaY TrVC.11u* do or, M Dan. OWw 6: Michael W. Simon George L. Sigalos *"0 Damon E. Gasser JenniferBoussy Carroll Heather E. Kruzyk Stephanie A. Young -Admitted Florida, Ohio **Admitted Florida. Illinois 0 Florida Board Certified Business Litigation _&S_ Simon & Sigalos, LLP Attorneys And Ceumelors At Iaw 3839 NW Boca Raton Boulevard Suite 100 Boca Raton, Florida 33431 June 10, 2016 VIA EMAIL: mobovle a..commerce-eroua.com & FACSIMILE (954) 360-0807 ONLY Martin E. O'Boyle c/o Commerce Group, Inc. 1280 W. Newport Center Drive Deerfield Beach, FL 33442 Re: O'Boyle v. Robert Sweetapple et al. Case No.: 9:14-CV-81250-KAM Dear Mr. O'Boyle: Telephone(561)447-0017 Facsimile (561) 447.0018 This firm represents non-party Candice Friis with respect to the Subpoena To Testify At a Deposition In A Civil Action ("Subpoena") which you had served on her in the above case, and with respect to the Motion to Compel and Memorandum, both of which are dated June 7, 2016. Ms. Friis received the Subpoena on May 31, 2016. She promptly notified you the following day that she would be out of the country on June 6, 2016 — the date you had unilaterally noticed her for deposition. At your request, Ms. Friis subsequently emailed you a copy of her airline ticket stub to substantiate this. Ms. Friis did not have internet access when you sent your follow up email demanding proof showing when she purchased her airline ticket. Despite Ms. Friis having put you on notice that she would be out of the country when you unilaterally scheduled her deposition for June 6, 2016, and her providing you with a copy of her airline ticket stub substantiating that fact, you nevertheless elected to proceed with her deposition, to obtain a certificate of non-appearance, and to file a motion to compel her deposition and memorandum with the court. This pattem of conduct is all the more egregious since the Subpoena and your service of it did not comply with the Federal Rules of Civil Procedure and the Local Rules of the United States District Court for the Southem District of Florida. First, S.D. Fla. L.R. 26.1(h) provides that a party desiring to take a deposition shall give notice to all other parties and to the deponent at least 7 days in advance of the deposition. It continues that "Failure to comply with this rule obviates the need for protective order." The Subpoena you served on Ms. Friis on May 31, 2016 requiring compliance on June 6 provided her with less than 7 days' notice and thus facially failed to comply with S.D. L.R. 26.1(h). Ms. Friis was therefore under no duty to seek a protective order in response to it. Second, Fed.R.Civ.P. 45(b)(1) requires that Ms. Friis receive the required witness fee with the Subpoena. She received no such witness fee, however, contrary to the clear requirements of the rule. Several courts have denied motions to compel a non-party's deposition where the required witness fee did not accompany the subpoena. Smith v. Fla. Dept, of Corrections, 369 Fed. Appx. 36, 2 (1 I'b Cir. 2010); Pride Family Brands, Inc. v. Carls Patio, Inc., 2013 WL 4647216 (S.D. Fla. 2013)(holding that the party shall serve the non-party with a proper subpoena pursuant to Rule 45, with the required witness fee, and that the deposition of the non-party would take place at a mutually agreed upon date and time by a date certain). Third, FedRCiv.P. 45(a)(B) provides that the subpoena shall include the method of taking the testimony. The Subpoena which you had served on Ms. Friis did not include this language required by the rule. Finally, I understand that the Subpoena misrepresents that Daniel DeSouza, Esq., assisted you with the preparation of it. After Ms. Friis received the Subpoena, she called Mr. DeSouza at the phone number listed on the Subpoena. He informed her that he was your former counsel but that he was no longer assisting you with this case. Given the above fact pattern, Ms. Friis respectfully requests that you immediately file a notice withdrawing your motion to compel against her and the memorandum which you filed in support. If you fail to file a notice withdrawing your motion to compel and memorandum in support by the close of business on Monday June 13, 2016 and to provide me with proof of the filed document then, out of an abundance of caution, Ms. Friis may file an appropriate motion with the court. If she does so, then she will seek all reasonable attomey's fees and costs against you which she incurs in connection with the motion. Nothing herein shall waive the rights, remedies, claims, or defenses of Candice Friis, all of which are specifically reserved. Very truly yours, sti Damon E. Gasser DEG/ cc: Client Jeff L. Hochman, Esq., (via email: Hochman(@,iambp.com ONLY) Case 9:14-cv-81250-KAM Document 138 Entered on FLSD Docket 06/22/2016 Page 1 of 6 June 20, 2016 Judge Kenneth A. Marra Federal Building and US Courthouse 701 Clematis Street Suite #316 West Palm Beach, Florida 33401 Re: O'Boyle v Robert Sweetapple et al. Case No: 9:14-CV-81250-KAM Dear Judge Kenneth A. Marra, I am writing to motion for a protective order to prevent a deposition from going forward with regards to Case # 9:14-CV-81250-KAM. Please find attached the documentation supporting my request. Thank you kindly, Candace Friis 4001 N. Ocean Blvd. Gulf Stream, Florida 33483 561.573.9966 candace.friis@corcoran.com Casa 9:14-cv-81250-KAM Document 138 Entered on FLSD Docket 06/22/2016 Page 2 of 6 Michad W. Simon George L. Sigalos 410 Damon E. Gasser Jennifer Bousry Carton Heatha E. Yjuzyk Stephanie A Young 'Admitted Florida. Ohio '•Admitted Florida. Illinois 0 Florida Board Certified Business Litigation —&S— Simon & Sigalos, LLP Artemcy, And C:ounselur, A, law 3839 NW Boca Raton Boulcvard Suite 100 Boca Ratoq Florida 33431 June 10, 2016 VIA EMAIL: mobovlena commerce-eroun.com & FACSIMILE (954)360-0807 ONLY Martin E. O'Boyle c/o Commerce Group, Inc. 1280 W. Newport Center Drive Deerfield Beach, FL 33442 Re: O'Boyle v. Robert Sweetapple et al. Case No.: 9:14 -CP 81250-KAM Dear Mr. O'Boyle: Tercphone (561) 447-0017 Facsimile (561) 447-0018 This firm represents non-party Candice Friis with respect to the Subpoena To Testify At a Deposition In A Civil Action ("Subpoena") which you had served on her in the above case, and with respect to the Motion to Compel and Memorandum, both of which are dated June 7, 2016. Ms. His received the Subpoena on May 31, 2016. She promptly notified you the following day that she would be out of the country on June 6, 2016 — the date you had unilaterally noticed her for deposition. At your request, Ms. Friis subsequently emailed you a copy of her airline ticket stub to substantiate this. Ms. Flus did not have internet access when you sent your follow up email demanding proof showing when she purchased her airline ticket. Despite Ms. Friis having put you on notice that she would be out of the country when you unilaterally scheduled her deposition for June 6, 2016, and her providing you with a copy of her airline ticket stub substantiating that fact, you nevertheless elected to proceed with her deposition, to obtain a certificate of non-appearance, and to file a motion to compel her deposition and memorandum with the court. This pattern of conduct is all the more egregious since the Subpoena and your service of it did not comply with the Federal Rules of Civil Procedure and the Local Rules of the United States District Court for the Southern District of Florida. First, S.D. Fla. L.R. 26.1(h) provides that a party desiring to take a deposition shall give notice to all other parties and to the deponent at least 7 days in advance of the deposition. It continues that "Failure to comply with this rule obviates the need for protective order." - Cas. 9:14-cv-81250-KAM Document 138 Entered on FLSD Docket 06/22/2016 Page 3 of 6 The Subpoena you served on Ms. Friis on May 31, 2016 requiring compliance on June 6 provided her with less than 7 days' notice and thus facially failed to comply with S.D. L.R. 26.1(h). Ms. Friis was therefore under no duty to seek a protective order in response to it - Second, Fed,R.Civ.P. 45(b)(1) requires that Ms. Friis receive the required witness fee with the Subpoena. She received no such witness fee, however, contrary to the clear requirements of the rule. Several courts have denied motions to compel anon -party's deposition where the required witness fee did not accompany the subpoena. Smith v. Fla. Dept. of Corrections, 369 Fed Appx. 36, 2.(11 m Cir. 2010); Pride Family Brands, Inc. v. Carls Patio, Inc., 2013 WL 4647216 (S.D. Fla. 2013)(holding that the party shall serve the non-party with a proper subpoena pursuant to Rule 45, with the required witness fee, and that the deposition of the non-party would take place at a mutually agreed upon date and time by a date certain). Third, Fed.R.Civ.P. 45(a)(B) provides that the subpoena shall include the method of taking the testimony. The Subpoena which you had served on Ms. His did not include this language required by the rule. Finally, I understand that the Subpoena misrepresents that Daniel DeSouza, Esq., assisted you with the preparation of it. After Ms. Friis received the Subpoena, she called Mr. DeSouza at the phone number listed on the Subpoena. He informed her that he was your former counsel but that he was no longer assisting you with this case: Given the above fact pattern, Ms. Friis respectfully requests that you immediately file a notice withdrawing your motion to compel against her and the memorandum which you filed in support. If you fail to file a notice withdrawing your motion to compel and memorandum in support by the close of business on Monday June 13, 2016 and to provide me with proof of the filed document then, out of an abundance of caution, Ms. Friis may file an appropriate motion with the court. If she does so, then she will seek all reasonable attorney's fees and costs against you which she incurs in connection with the motion. Nothing herein shall waive the rights, remedies, claims, or defenses of Candice Friis, all of which are specifically reserved. Very truly yours, Damon E. Gasser DEG/ cc: Client Jeff L. Hochman, Esq., (via email: Hocbman(djamb-g.com ONLY) Case 9:14'cv-8125M.,t A4 t ume�t 139 Entered'on FL 06/2 room ImobfMatwn Vb�fvM VW i hre rs"dw" to y'& rw✓) 0noe b 000rwM. w we ao* VW w Wbot v u W Wo .M�r M MM ipM rb:.�wca+ �e swr�ev.�y� m.- R fw.odr n RWrW" M 01 ro.+ WW A000" ovok�. ya, cap+ do w try WVg&V • TfopC oo=jr4 to auft hpCow bo=ot dak on ft brvvw OMow it d S&VEit AlftArS og" X1 M Cw,w r. T.Nit". 02 Am" NOW&" A&ribsrPA4u9FAry1rt WIAU rYli'iFn �7�•• :y 0 i l' tH MARSH HAMOUR, BAHAMAS 3.14FM Anivai: PBI WEST PALM BEACH, FL 4:14PM Please verify flight times prior to departure Class: Economy 's Aircraft: SAAB 340 TURBOPROP Mr Nile Frits Seags): 04D/Confirmed Add to Calendar View Trip In TripCase PrW itinerary Passenger name(s) and confirmation numbers) Mrs Candace L Frils: 4482100879406 Mr Nile Frfis: 4482100879405 Duration: Distance (in Miles): anti Orninuts(s) `+ ,. red Monday, 06 June, 0 0 c' 3 m m m I hour(s) and Ominule(s) 0 r At m O O 0 Mrs Candace L Friis v seal(s): uA!Confirmed m N N O F+ O, v N 0 m Sl*(ver a,iawars NAME F R I I S %CAN DAC E ORIGIN DESTINATION SEQUENCE PBI: MHH 035 DATE 02JUN16 FLIGHT 3M 98 BOARDING TIME 09:41A CLASS SENT T 4A Case 9:14-cv-81250-KAM Document 184 Entered on FLSD Docket 07111/204j&—Page 1 of 3 FILED BY /1' D.C. JUL 0 8 2046 STEVEN M. LARIMORE CLERK U.S. DIST. CT. July 8, 2016 Judge Kenneth A. Marra Federal Building and US Courthouse 701 Clematis Steet Suite #316 West Palm Beach, Florida 33401 Dear Judge Marra, Please find the legal bill from Mr. Gasser for his prior help in this matter in the amount of $1000. 1 received yesterday via email a Motion to reconsider your decision regarding Case No: 9:14-CV-81250-KAM. I sincerely hope that the Motion to Reconsider which Mr. O'boyle has just emailed me will not be granted. Please accept this letter as my request that his motion not be granted. Attached is the bill from Mr. Gasser, Thank you kindly, 0QyVl,� '- Candace Friis 4001 N. Ocean Blvd. Gulf Stream, Florida 33483 561.573.9966 candace.friis@corcoran.com Case 9:14-cv-81250-KAM Document 184 Entered on FLSD Docket 07/11/2016 Page 2 of 3 SIMON & SIGALOS, LLP 3839 NW Boca Raton Blvd. Suite 100 Boca Raton, FL 33431 Telephone (561)447-0017 Fax (561)447-0018 Invoice submitted to: Candace Friis Go The Corcoran Group 901 George Bush Blvd. Delray beach, FLO 33483 July 01, 2016 In Reference To: Friis, Candace Re: O'Boyle v. Robert Sweetapple et al Invoice #70272 Client #: 2532.01 Professional Services Hrs/Rate Amount 6/8/2016 Telephone conference with new client regarding subpoena for deposition on 0.40 180.00 third party witness, received email from client with information on subpoena 450.001hr and directions regarding same. 6/92016 Reviewed motion, subpoena, notice of deposition and additional documents 2.30 632.50 regarding Ms. Friis' deposition. Telephone conference with Ms. Friis 275.00/hr regarding same. Brief legal research regarding defects in subpoena for deposition. Drafted demand letter to Mr. O'Boyle. Followed up with client regarding same. 6/142016 Reviewed email from Mr. O'Boyle. Followed up with Ms. Fdis regarding 0.40 110.00 same. Telephone conference with Ms. Fdis regarding Mr. O'Boyle's email 275.00/hr and regarding potential responses to same. Followed up with Mr. Hochman regarding Mr. O'Boyle's email and requested copy of pretrial order. 6/162016 Reviewed email from attorney Hochman regarding O'Boyle's response to our 020 55.00 letter. Followed up with client regarding same. 275.00/hr 6/17/2016 Reviewed client's email and replied to the same regarding Mr. O'Boyle's 0.70 192.50 attempts to depose her. Drafted lengthy email to client outlining client's 275.00/hr options. Telephone conference with client regarding same. Reviewed client's email confirming date she purchased her airline ticket Drafted follow up email to Ms. Friis confirming we are taking no further action in the case. 624/2016 Briefly reviewed Mr. O'Boyle's response to Ms. Friis' filing/lefter. Followed up 0.20 55.00 with Ms. Friis regarding same. 275.00/hr Case y:14-cv-81?bU-KAM Document 184 Entered on F -LSU UOCI<et U//11/LU16 Page 3 of 3 Candace Friis page 2 Hrs/Rate Amoun 6/30/2016 Reviewed client's email and order denying O'Boyle's motion to compel Ms. 0.60 165.00 Frils' deposition and granting her motion for protective order. Followed up 275.00/hr with Ms. Friis regarding same. For professional services rendered 4.80 $1,390.00 6/30/2016 Courtesy Credit ($390.00) Total payments and adjustments ($390.00) Balance due $1,000.00 Please make checks payable to Simon & Sigalos, LLP and deliver to Simon & Sigalos, LLP 3839 NW Boca Raton Blvd., Suite 100 Baca Raton, Florida 33431 Payment is due upon receipt of statement Thankyou. Foryour convenience, we accept VISA, Mastercard, Discover and American Express. Any payments made via credit card in excess of $5,000 will include an additional 3% service charge on the amount paid. TOWN OF GULF STREAM PALM BEACH COUNTY, FLORIDA Delivered via e-mail July 26, 2016 Martin E. O'Boyle [mail to: records@commerce-group.com] Re: GS #2277 (PRR 1253) Please provide copies of all communications (including, without limitation, E -Mails, letters, memos, notes and other forms of communications) between Ms. Candace Friis and the Town of Gulf Stream beginning Janumy 1, 2013 through the date ofthis Request. Dear Martin E. O'Boyle [mail to: records(d)commerce-erouo.coml, The Town of Gulf Stream has received your public records request dated July 20, 2016. You may view your original request at the following link: hup://www2.gulf- stream.ore/weblink/0/doc/97487/Paeel asox. Please allow this response to be responsive for all parties involved. Please allow this correspondence to supplement the Town of Gulf Stream's July 20, 2016 response to your public records request. The Town is providing a partial production of responsive documents at the same link above. These documents are communications between the Town's outside counsel and Ms. Candace Friis with regard to O'Boyle v. Morgan, Case No. 14- cv-81250 (S.D. Fla.). Should you seek any additional records responsive to your request, the Town's prior estimate stands. Sincerely, Town Clerk Custodian of the Records