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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
Case No.:______________________
TOWN OF GULF STREAM, a municipality organized
and existing under the laws of Florida on its own
behalf and on behalf of those municipalities similarly
situated, and WANTMAN GROUP, INC., a domestic
company on its own behalf and on behalf of those
companies similarly situated,

CLASS ACTION

Plaintiffs,
vs.
MARTIN E. O’BOYLE, an individual, CHRISTOPHER
O’HARE, an individual, WILLIAM RING, an
individual, JONATHAN R. O’BOYLE, an individual, DENISE
DEMARTINI, an individual, GIOVANI MESA, an individual,
NICKLAUS TAYLOR, an individual, RYAN WITMER, an
individual, AIRLINE HIGHWAY, LLC, COMMERCE GP, INC.,
CG ACQUISITION CO., INC., CRO AVIATION, INC., ASSET
ENHANCEMENT, INC., COMMERCE REALTY GROUP, INC.,
PUBLIC AWARENESS INSTITUTE, INC., CITIZENS
AWARENESS FOUNDATION, INC., OUR PUBLIC RECORDS,
LLC, STOPDIRTYGOVERNMENT, LLC, COMMERCE
GROUP, INC., and THE O’BOYLE LAW FIRM, P.C., INC.,

Defendants.
__________________________________________________/
CLASS ACTION COMPLAINT
I.

Introduction.
1.

The TOWN OF GULF STREAM (“Gulf Stream” or “Town”) brings this lawsuit

as a class action, by and on behalf of state and local municipalities, municipal agencies, and their
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private contractors located in the state of Florida that have been victimized by a scheme to
defraud and extort being carried out by a RICO Enterprise created by, and composed of, the
Defendants. Through their RICO Enterprise, the Defendants have associated-in-fact with the
sole purpose of unlawfully and illegally extracting settlement payments from the Class Members
by first using the mails and the wires to deliver and advance frivolous public records request that
are often intentionally inconspicuous. Then, the Defendants, through their RICO Enterprise,
immediately use the mails and the wires to extort their victims by demanding that these
municipal entities and agencies immediately settle with them and pay their allegedly incurred
attorneys’ fees and costs as provided for in the public records statute, or, face protracted
litigation and a flurry of additional frivolous public records request and lawsuits. The amount
demanded by the Defendants to reimburse them for their attorneys’ fees and costs is fraudulent—
far exceeding the actual costs and fees incurred in the frivolous public records request, resulting
in a profit windfall for the Defendants. At least one Court has labeled these actions as an
“unreasonable and flagrant abuse of the state [Public Records Act],” amounting to “nothing more
than a scam.” (See ¶18, p.6, Final Order Denying Relief Under Public Records Act, entered by
the Hon. Jack M. Schemer, Circuit Court Judge, Duval County, Florida, attached hereto as
Exhibit “A.”).
2.

The Defendants are prolific in their efforts—from March 5, 2013, through July

17, 2013, the RICO Enterprise filed over 400 public records request with Gulf Stream alone.
From August of 2013 through present, the RICO enterprise filed more than 1,500 additional
public records requests bringing the total number of public records requests to almost 2,000.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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(See the Public Records Request Log attached hereto as Composite Exhibit “B”).1

For

purposes of context—Gulf Stream is a tiny community, having a population of 974 residents and
only 17 full time employees (four of whom work at Town Hall), with a land mass of less than
one square mile.
3.

The Defendants also target private entities that have contracted with

municipalities, arguing that by virtue of their business relationship with a public entity, they are
subject to the public records laws of Florida. The Wantman Group, Inc. brings this lawsuit as a
class action on behalf of itself and other private entities that have been victimized by
Defendants’ scheme to defraud and extort.
4.

The Wantman Group is a multidisciplinary consulting firm which provides

engineering, surveying and mapping, and environmental and planning services. The Wantman
Group has six offices throughout the state of Florida. As part of its business, the Wantman
Group has signed contracts with various municipalities and government agencies. For example,
the Wantman Group signed a contract with the South Florida Water Management District,
(“SFWMD”) through which it was to provide professional services to the SFWMD.
II.

Jurisdictional Allegations.
5.

As this is an action brought under 18 U.S.C. §§ 1961, 1962 and 1964, this Court

has original jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§ 1331.
Additionally, this Court has original jurisdiction over the subject matter of this action pursuant to
18 U.S.C. §§ 1964 (a)-(c). Finally, this Court has personal jurisdiction over the Defendants
pursuant to 18 U.S.C. § 1965.
1

This chart includes all public records request made to the Town, only a handful of which were not done by the
Defendants.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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6.

Venue is appropriate in this district pursuant to 18 U.S.C. § 1965(a) as well as 28

U.S.C. § 1391(b)(1) and (2), as the Defendants reside in this district and a substantial part of the
events or omissions giving rise to Plaintiffs’ claims occurred in this district.
III.

Parties.
7.

Plaintiff, TOWN OF GULF STREAM, is a municipality organized and existing

under the laws of the State of Florida.
8.

Plaintiff, WANTMAN GROUP, INC., is a Florida corporation, which maintains

its principal place of business at 2035 Vista Pkwy, Suite 100, West Palm Beach, Florida, 33411
in Palm Beach County, Florida.
9.

Defendant MARTIN E. O’BOYLE, is a resident of Florida, residing in Palm

Beach County, and more specifically, in the Town of Gulf Stream. Martin O’Boyle is also: (i)
the President and owner of Defendants Commerce Group, Inc., Commerce GP, Inc., Commerce
Realty Group, Inc., and CRO Aviation, Inc.; (ii) the sole member of Defendants
Stopdirtygovernment, LLC, Our Public Records, LLC and Airline Highway, LLC; and (iii) a
director of Defendant Public Awareness Institute, Inc.
10.

Defendant WILLIAM F. RING (“Ring”) is an attorney licensed to practice law in

the state of Florida, and upon information and belief, is practicing with and a partner or
shareholder of Defendant The O’Boyle Law Firm, P.C., Inc., as well as its registered agent.
Ring is also: (i) Vice-president of Defendants Commerce Group, Inc., CG Acquisition Co., Inc.,
Commerce Realty Group, Inc., and Asset Enhancement, Inc.; (ii) the founding President of
Defendant Citizens Awareness Foundation, Inc., (iii) and the registered agent for Defendants Our

RICHMAN GREER, P.A.
Miami  West Palm Beach

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Public Records, LLC, and Stopdirtygovernment, LLC. Ring has worked for Martin E. O’Boyle
in some capacity for at least 25 years.
11.

Defendant CHRISTOPHER O’HARE (“O’Hare”) is a resident of Florida,

residing in Palm Beach County, and more specifically, the Town of Gulf Stream. O’Hare is also
a client of Defendant The O’Boyle Law Firm, P.C., Inc.
12.

Defendant JONATHAN R. O’BOYLE is a resident of Florida, residing in Palm

Beach County, and while not an attorney that is licensed to practice law in Florida; he is the
founding principal of Defendant The O’Boyle Law Firm, P.C., Inc. and currently its President,
sole director and manager. Jonathan O’Boyle is the son of Defendant Martin O’Boyle, and is
also a director of Defendant Public Awareness Institute, Incorporated.
13.

Defendant DENISE DEMARTINI (“DeMartini”) is a resident of Florida, residing

in Martin County. DeMartini is also: (i) an employee of Defendant Commerce Group, Inc.; (ii)
Secretary of Defendant Commerce Realty Group, Inc.; and (iii) the current President and director
of Defendant Citizens Awareness Foundation, Inc. DeMartini, while not a lawyer, managed the
operations of Defendant The O’Boyle Law Firm during the time at issue in this suit. Like
Defendant Ring, DeMartini has worked for Martin O’Boyle for more than 25 years.
14.

Defendant COMMERCE GROUP, INC. (“Commerce Group”) is a Florida

Corporation with its principal place of business located at 1280 W Newport Center Dr., Deerfield
Beach, Florida 33442. Commerce Group is run by Martin O’Boyle.
15.

Defendant CITIZENS AWARENESS FOUNDATION, INC. (“CAFI”), purports

to be a Florida non-profit corporation, with its principal place of business located at 1280 West

RICHMAN GREER, P.A.
Miami  West Palm Beach

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Newport Center Drive, Deerfield Beach, Florida 33442. Defendant Martin O’Boyle, together
with his son Jonathan O’Boyle and Defendant Ring, created CAFI in or around January of 2014.
16.

Defendant STOPDIRTYGOVERNMENT, LLC, (“Stopdirtygovernment” or

“SDG”) is a Florida limited liability company with its sole member being Martin O’Boyle, and
its principal place of business located at 1280 West Newport Center Drive, Deerfield Beach,
Florida 33442.
17.

Defendant OUR PUBLIC RECORDS, LLC, (“OPR”) is a Florida limited liability

company with its sole member being Martin O’Boyle, and its principal place of business located
at 1280 West Newport Center Drive, Deerfield Beach, Florida 33442.

Defendant Martin

O’Boyle created OPR in or around April of 2013.
18.

Defendant PUBLIC AWARENESS INSTITUTE, INC. (“PAI”) purports to be a

Florida non-profit corporation with its principal place of business located at 1280 West Newport
Center Drive, Deerfield Beach, Florida 33442.

Defendants Martin O’Boyle and Jonathan

O’Boyle, along with their family member Sheila O’Boyle (wife of Martin and mother of
Jonathan), are the directors of PAI, which was created in or around May of 2013.
19.

Defendant AIRLINE HIGHWAY, LLC (“AH”) is a Florida limited liability

company with its sole member being Martin O’Boyle, and its principal place of business located
at 1280 West Newport Center Drive, Deerfield Beach, Florida 33442.
20.

Defendant, COMMERCE GP, INC. (“Commerce GP”), is a Florida profit

corporation with its principal place of business located at 1280 West Newport Center Drive,
Deerfield Beach, Florida 33442. Defendant Martin O’Boyle is the President of Commerce GP.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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21.

Defendant CG ACQUISITION CO., INC. (“CGA”), is a Florida profit

corporation with its principal place of business located at 1280 West Newport Center Drive,
Deerfield Beach, Florida 33442. Defendant Martin O’Boyle is the Director of CGA with
Defendant Ring being its Vice-President.
22.

Defendant, CRO AVIATION, INC. (“CRO”), is a Florida profit corporation with

its principal place of business located at 1280 West Newport Center Drive, Deerfield Beach,
Florida 33442. Defendant Martin O’Boyle is the President of CRO.
23.

Defendant, ASSET ENHANCEMENT, INC. (“AE”), is a Florida profit

corporation with its principal place of business located at 1280 West Newport Center Drive,
Deerfield Beach, Florida 33442. Defendant Martin O’Boyle is the President of AE with
Defendant Ring being the Vice-President.
24.

Defendant, COMMERCE REALTY GROUP, INC. (“CRG”), is a Florida profit

corporation with its principal place of business located at 1280 West Newport Center Drive,
Deerfield Beach, Florida 33442. Defendant Martin O’Boyle is the President, Defendant Ring the
Vice-President and Defendant DeMartini the Secretary of CRG.
25.

In addition to the fact that they are all housed at the offices of Martin O’Boyle’s

company Commerce Group, Defendants O’Boyle, Ring, DeMartini, CG, CAFI, SDG, OPR, PAI,
AH, Commerce GP, CGA, CRO, AE, CRG all share the internet domain commerce-group.com
and utilize the email address records@commerce-group.com.
26.

Defendant, THE O’BOYLE LAW FIRM, P.C., INC., (“O’Boyle Law Firm”), is a

foreign corporation, a law firm, having its alleged principal address located at 1001 Broad Street,
Johnstown, Pennsylvania and a Florida office at 1286 West Newport Center Drive, Deerfield
RICHMAN GREER, P.A.
Miami  West Palm Beach

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Beach, Florida 33442. Defendant Jonathan O’Boyle is the sole officer and director of the
O’Boyle Law Firm, but is not licensed to practice law in the State of Florida. While serving as an
officer of Defendant CAFI, a client of the O’Boyle Law Firm, Defendant DeMartini
simultaneously managed the O’Boyle Law Firm’s operations. After resigning as an officer of
CAFI, but retaining his position as an officer of several other firm clients, including Defendants
CG, CGA, CRG and AE, Defendant Ring is now a partner with the O’Boyle Law Firm.
27.

Defendant, RYAN WITMER, is an attorney licensed to practice law in the state

of Florida and a resident of New York. A law school classmate of Jonathan O’Boyle, Witmer
helped to establish the O’Boyle Law Firm and thereafter filed and prosecuted scores of public
records lawsuits throughout the State of Florida against the putative class members on behalf of
clients of the O’Boyle Law Firm, including, but not limited to, Defendants Martin O’Boyle,
O’Hare and CAFI.
28.

Defendant, GIOVANI MESA, is an attorney licensed to practice law in the state

of Florida, practicing with the O’Boyle Law Firm. Mesa has filed and prosecuted scores of
public records lawsuits throughout the State of Florida against the putative class members on
behalf of clients of the O’Boyle Law Firm including, but not limited to, Defendants Martin
O’Boyle, O’Hare and CAFI.
29.

Defendant, NICKALAUS TAYLOR, is an attorney licensed to practice law in the

state of Florida since 2008, who practices with the O’Boyle Law Firm. Taylor has filed and
prosecuted scores of public records lawsuits throughout the State of Florida against the putative
class members on behalf of clients of the O’Boyle Law Firm including, but not limited to,

RICHMAN GREER, P.A.
Miami  West Palm Beach

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Defendants Martin O’Boyle, O’Hare, Commerce Group, CAFI, OPR, AH, CGA, CRO, AE and
CRG.
IV.

Appropriateness of Class Action Treatment.
30.

Plaintiffs bring this action on behalf of themselves and all others similarly situated

pursuant to Fed. R. Civ. P. 23(b)(3). This action satisfies the numerosity, commonality,
typicality, adequacy, predominance and superiority requirements of Rule 23.
31.

The proposed Class is defined as:

All state or local municipalities, municipal agencies, or private contractors in the
State of Florida, who have been served with a public records request by any of the
Defendants and who either (a) paid a settlement amount in conjunction with, or to
resolve the public records request; or (b) incurred attorneys’ fees and costs to
respond to or litigate against public records requests from any of the Defendants.
32.

Plaintiffs reserve the right to modify or amend the definition of the proposed

Class before the Court determines whether certification is appropriate.
33.

Plaintiffs do not currently know the exact number of Class Members or their

identities. However, Plaintiffs believe that Class Members number in the hundreds, and are thus
sufficiently numerous and geographically dispersed so that joinder of all Class Members is
impracticable.
34.

Attached hereto as Composite Exhibit “C” are a series of charts listing the

current known potential Class Members, along with the style, case number, and county where the
lawsuits were brought against them as part of the scheme to defraud and extort. As composite
Exhibit “C” illustrates, there are at least 121 different Class Members (including Plaintiffs)

RICHMAN GREER, P.A.
Miami  West Palm Beach

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composed of approximately 31 municipalities or agencies, and 90 private contractors in suits
brought in nearly 2 dozen counties around the State.2
35.

Plaintiffs further believe that each Class Member, including themselves, have

claims with a common origin and share a common basis. The claims of all Class Members, as
well as the Plaintiffs, originate from the Defendants’ pattern of racketeering activity and use of
the RICO Enterprise to carry out such activities.
36.

The claims of the Plaintiffs are typical of the Class, in that Plaintiffs, like all Class

Members, were injured in their business or property by reason of the Defendants’ pattern of
racketeering activity carried out by the RICO Enterprise, including the predicate acts of mail
fraud, wire fraud, and extortion.
37.

The RICO Enterprise, created by the Defendants, used the mail and the wires to

send out what is usually an inconspicuous and frivolous public records request to the Class
Members, often times under the guise of a false non-profit organization, and with a stated or
implied purpose of advancing the public’s interest in government transparency.3 In reality, this
bogus public records request was an essential first-step of the RICO Enterprises’ scheme to
defraud and extort money from the class members—it was nothing more than bait, a records
request for documents that the RICO Enterprise had no intention of reviewing, and instead,
intended to be overlooked or missed by the receiving class member so as to trigger the next step
in the RICO Enterprises’ scheme.

2

Exhibit “C” reflects suits brought by only Defendant CAFI, albeit, in advancing the goal of the RICO Enterprise.
Upon information and belief, the number of class members will increase substantially.
3
The purpose for disguising the identity of the requesting party was twofold: (1) to fool the recipient into thinking a
not-for-profit had a genuine desire to see the documents requested; and (2) to try and circumvent the conditional
payment provided for in the Public Records law allowing a municipality to condition production of the requested
documents on payment of costs and expenses. (See, Fla. Stat. §119.07(4)(d)).
RICHMAN GREER, P.A.
Miami  West Palm Beach

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38.

After the bogus records request was sent and hopefully overlooked, the RICO

Enterprise would then use the mail and the wires to: (i) demand a settlement of the records
request in excess of the actual attorneys’ fees and costs incurred by the Defendants; or (ii) file a
frivolous lawsuit against the recipient of the bogus records request followed by the demand for
settlement. The settlement demand was directly or indirectly accompanied by a threat of harm to
property in the form of more bogus records requests, to be followed up with even more frivolous
litigation.
39.

This racketeering conduct damaged and injured the class members in three ways:

(i) by requiring additional expenditures by the class members (i.e. hiring additional staff, paying
overtime, etc.) to review and respond to the massive volume of bogus records requests;4 (ii) by
coercing and sometimes extracting an inflated settlement amount from the Class Member to
“make this go away,”; and (iii) by requiring the Class Member to defend against several spurious
lawsuits brought only to increase the pressure and ultimately force the Class Member to accept
the extorted settlement amount.
40.

Pursuant to Rule 23(b)(3), there are numerous questions of law and fact common

to the Class and those common questions predominate over any questions affecting only
individual Class Members, including whether Defendants:
a.

are associated, organized and acting as an enterprise with the purpose of carrying
out a scheme to defraud and extort;

b. devised, followed, and actively pursued a scheme to defraud and extort, and what
the scheme to defraud and extort consisted of, including;

4

See note 3, supra
RICHMAN GREER, P.A.
Miami  West Palm Beach

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i. manipulation of the public records laws of Florida for financial gain,
including the filing of frivolous, meaningless, and often inconspicuous
public records request with no real need or intention to ever review or
obtain the public records, but rather, simply set the stage for the next step
in the scheme to defraud and extort;
ii. advance fraudulent and inflated settlement demands as a matter of
practice, policy, and pattern by fraudulently misrepresenting attorneys’
fees incurred by the O’Boyle Law Firm and its co-Defendant clients,
including a substantial profit margin to be shared between the O’Boyle
Law Firm and its so-called “non-profit” clients;
iii. as a matter of practice, policy, and pattern, extorted compliance with the
fraudulent and inflated settlement demands by threatening scores of
additional frivolous public records requests to be followed by scores of
additional fraudulent and inflated settlement demands with the sole
intended consequence of the class members having to spend resources on
responding to the bogus public records request and defending the frivolous
litigation;
iv. set up false and fraudulent companies, both non-profit and profit, in
furtherance of the scheme to defraud, and using the mails and wires to
incorporate, indoctrinate, or otherwise create these bogus companies in the
State of Florida;

RICHMAN GREER, P.A.
Miami  West Palm Beach

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v. established a captive Florida law firm run by a non-Florida attorney for the
sole purpose of generating attorneys’ fees from settlements demanded
through the use of the mails and wires;
c. have engaged in conduct that constitutes a pattern of racketeering activity in
furtherance of their scheme to defraud and extort;
d. committed the predicate criminal acts of mail fraud, wire fraud, or extortion in
furtherance of their scheme to defraud and extort;
e. made false statements or misrepresentations of material fact regarding their
identity so as to induce Defendants to act in reliance by foregoing the assessment
of a special service charge to which Defendants would otherwise have been
entitled under Fla.Stat. § 119.07(4)(d);
41.

Additionally, another common question of law and fact is the appropriate measure

of damages sustained by Plaintiffs and other Class Members.
42.

A class action is superior to other methods for the fair and efficient adjudication

of this controversy. Treatment as a class action will permit a large number of similarly situated
persons to adjudicate their common claims in a single forum simultaneously, effectively, and
without the duplication of effort and expense, and risk of inconsistent rulings that numerous
individual actions would cause. Class treatment will also permit the adjudication of relatively
small claims by Class Members who otherwise might not be able to afford to litigate their claims
individually. This class action presents no difficulties in management that would preclude
maintenance as a class action.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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43.

This forum is particularly desirable for the prosecution of this class action because

Defendants all are residents in, or maintain a principal place of business in, this district, and
presumably maintain many of those corporate records which are particularly germane to this
action here. As a result of the foregoing, litigating on a class action basis in this forum will
likely decrease the cost of discovery and prosecution, generally.
44.

Plaintiffs have suffered the harm alleged on behalf of the Class, and have no

interests antagonistic to the interests of any other Class Members. They are committed to the
prosecution of this action and have retained counsel experienced in the prosecution of class
actions, and in complex commercial actions in particular. Accordingly, Plaintiffs are adequate
representatives and will fairly and adequately protect the interests of the Class. Plaintiffs are not
aware of any other pending litigation concerning this controversy that involves Class Members,
other than the individual cases brought by Defendants to enforce the frivolous and fraudulent
public records requests.
45.
V.

Finally, the Class is readily definable.
General Allegations.
a. Florida Public Records Law

46.

Pursuant to Chapter 119, Florida Statutes, commonly referred to as the Sunshine

law, the legislature has determined that: “It is the policy of this state that all state, county, and
municipal records are open for personal inspection and copying by any person. Providing access
to public records is a duty of each agency.”

RICHMAN GREER, P.A.
Miami  West Palm Beach

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47.

Florida prides itself on the transparency required of its elected officials, and its

elected officials often pride themselves on providing such transparency to those that have elected
them to serve.
48.

Accordingly, pursuant to section 119.07, all qualifying entities: “shall permit the

record(s) to be inspected and copied by any person desiring to do so, at any reasonable time,
under reasonable conditions….” In furtherance of this transparency, “a custodian of public
records and his or her designee must acknowledge requests to inspect or copy records promptly
and respond to such requests in good faith. A good faith response includes making reasonable
efforts to determine from other officers or employees whether such a record exists and, if so, the
location at which the record can be accessed.”
49.

The Public Records Act authorizes a custodian to collect a fee, prior to disclosing

the records, for the cost of copying the records. Fla. Stat. § 119.07(4) (providing the custodian
“shall furnish a copy ... of the record upon payment of the fee prescribed by law”). The custodian
may also collect a special service charge for requests that “require extensive use of information
technology resources or extensive clerical or supervisory assistance ....” (Fla. Stat. §
119.07(4)(d)).
50.

Chapter 119 also extends the transparency requirement, as well as an obligation to

respond to public records request, to a “contractor,” defined as “an individual, partnership,
corporation, or business entity that enters into a contract for services with a public agency and is
acting on behalf of the public agency….” See section 119.0701.
51.

In addition to criminal penalties, public officers (or “contractors”) are subject to

prevailing party attorneys’ fees in civil court upon a showing of “unlawful refus[al] to permit a
RICHMAN GREER, P.A.
Miami  West Palm Beach

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public record to be inspected or copied…” Notably, this prevailing party fee provision is onesided and can only be invoked by the party making the public records request, and not the agency
or contractor responding to the request.
52.

It is this threat of prevailing party attorneys’ fees that is the nucleus around which

the Defendants created their scheme to defraud and extort, and organized their RICO Enterprise
to carry out that scheme.
a. The Origins of the Scheme to Defraud and Extort.
i. Martin O’Boyle gets a taste of the potential ill-gotten gains associated
with exploiting the Public Records Act.
53.

Martin O’Boyle already had an extensive history filing public records requests in

New Jersey, Florida and elsewhere. Martin O’Boyle previously used the public records process
in an abusive fashion to file thousands of requests and vexatious and frivolous lawsuits, to
cripple local governments into granting his development plans and other demands.
54.

By way of example, in the case of Martin E. O’Boyle v. Peter Isen, 2014 WL

340104 (N.J.Super.A.D.)5, the Superior Court of New Jersey, Appellate Division, noted:
From September 2007 through early July 2008, plaintiff [Martin
O’Boyle] and members of his family filed multiple requests pursuant to the Open
Public Records Act (OPRA), N.J.S.A. 47:1A-1 to -13. Longport’s only clerk
worked part-time, and she did not address the requests within the time required by
statute. At one point, the clerk went to the emergency room because of the stress
she attributed to the flood of OPRA requests. And, in February 2008, the
Borough’s solicitor notified plaintiff that it would not accept any additional
OPRA requests he filed, explaining that the numerous requests were substantially
disrupting governmental services. The solicitor claimed that Longport had
received 190 requests on October 16 and 17 and thirty filed October 31, 2007.

5

In the Isen case, Martin O’Boyle sued a resident of Longport for claiming Martin O’Boyle was “the enemy of
Longport”. The suit for defamation was dismissed by summary judgment and affirmed by the appellate court.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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55.

Similarly, when his daughter was being prosecuted for driving under the influence

in Palm Beach County, Florida, Martin O’Boyle inundated the Palm Beach County State
Attorney’s Office both individually and through some of the other Defendants with over 1,300
requests for public records.
56.

At one point, Martin O’Boyle had an application with four variance requests

pending before the Town when his vexatious campaign of public records requests began in 2013.
One of the variances in the request was granted, but O’Boyle was sent a letter of denial
pertaining to the other three requests on March 24, 2013.
57.

From February 2013 to July 2013, Martin O’Boyle filed hundreds of public

records requests with the Town, overwhelming the records custodian with a nearly constant
barrage of requests. When the Town’s limited staff could not keep up with the records requests
in what Martin O’Boyle believed to be a reasonable period of time, he began filing public
records lawsuits.
58.

From April to July 2013, Martin O’Boyle filed approximately 16 public records

lawsuits in his name and that of his affiliated entities, including Defendants Commerce Group
and AH. Many were filed as separate actions on the same day to further burden the Town in
responding to the complaints and to increase the costs of the litigation.
59.

In July 2013, the Town settled with Martin O’Boyle and paid him $180,000.00,

an amount Martin O’Boyle claimed to have accrued in attorney’s fees although his suits had
been prosecuted pro se.
60.

As a result of the foregoing experiences, and with Jonathan O’Boyle having

graduated from law school in 2012, Martin O’Boyle and Jonathan O’Boyle realized that they
RICHMAN GREER, P.A.
Miami  West Palm Beach

17

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could use the Public Records Act not just to frustrate the workings of city governments, but also
to generate an ill-gained profit for themselves. Thus, no longer was Martin O’Boyle’s goal
simply to torment local governments, bullying them into caving to his demands. The purpose
was now to extort money.
61.

In or around January 2014, Martin O'Boyle and his son, Jonathan O’Boyle, met

for the purposes of developing a scheme to defraud and extort whereby they would form one or
more contrived not-for-profit corporations. The purpose of the not-for-profit corporations would
be to file thousands of public records requests with municipalities, government entities and state
contractors throughout the State of Florida. Receipt and review of the requested records was not
the O’Boyle’s priority. What Martin O’Boyle and Jonathan O’Boyle were really interested in
was trying to cause the recipient of the public records request to overlook the request and then
slap the recipient with a lawsuit or pre-suit settlement demand for an amount far in excess of
their costs and fees and from which they would pocket a generous profit.
ii. Creation of the O’Boyle Law Firm and Its Feeder Individuals and
Entities.
62.

Accordingly, and despite the fact that Jonathan O’Boyle was not a Florida lawyer,

he opened and ran the O’Boyle Law Firm as a foreign profit corporation on February 10, 2014.
This law firm was opened and operated from his father’s corporate offices of the Commerce
Group, located in Deerfield Beach Florida. Both Martin O’Boyle and Commerce Group financed
all activities of the O’Boyle Law Firm.
63.

Once they had the law firm in place, Martin O’Boyle, Jonathan O’Boyle, and the

O’Boyle Law Firm required “clients” —pre-textual plaintiffs that they could use in sending out
frivolous and fraudulent public records requests and accompanying lawsuits.
RICHMAN GREER, P.A.
Miami  West Palm Beach

18

Accordingly,

 Case 9:15-cv-80182-KAM Document 1 Entered on FLSD Docket 02/12/2015 Page 19 of 49

Martin O’Boyle and Jonathan O’Boyle, along with Ring and DeMartini, decided to activate
several of Martin O’Boyle’s dormant corporations and not-for-profits, and to form several new
not-for-profit entities, including Defendants CAFI, OPR, and PAI, as a front to make public
records requests and create litigation for the O'Boyle Law Firm which then could be used to
defraud and extort Class Members into paying inflated settlement amounts and line their pockets
with the proceeds derived therefrom.
64.

Martin O’Boyle, Jonathan O’Boyle, Ring and DeMartini knew that they could

not, on the surface, own and control the non-profits they now intended to create as well as the
law firm to which all of the so-called “clients” would be referred. So, to further wrap their
scheme to defraud and extort in a shroud of legitimacy, they needed someone who is familiar
with government transparency—someone that had vast experience in making public records
request and someone with a reputation for doing so. They found that someone in Joel Chandler.
b. Joel Chandler is Used to Lend Legitimacy To the Scheme To Defraud and
Extort.
65.

In January 2014, Martin O’Boyle and Jonathan O’Boyle contacted Joel Chandler

(hereinafter referred to as “Chandler”). At the time Chandler had been working as a selfemployed civil rights and public information activist. Chandler had considerable experience in
making public records requests and in public records request litigation throughout the State of
Florida, and had garnered a reputation as being a government transparency advocate.
66.

Chandler was invited to the O’Boyle home in Gulf Stream, Florida, where both

Martin and Jonathan O’Boyle resided. At the initial meetings, Chandler, the O’Boyles, and
Witmer discussed the O’Boyle Law Firm’s capacity for handling public records litigation
throughout the state.
RICHMAN GREER, P.A.
Miami  West Palm Beach

19

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67.

As a result of the meetings, Martin O'Boyle incorporated an alleged not-for-profit

entity. Now, Martin O’Boyle and his various entities were funding not only the O’Boyle Law
Firm, but also a feeder organization—CAFI.6
68.

Martin O’Boyle, on his own and through his other entities, provided actual cash to

CAFI and the O’Boyle Law Firm as well as other consideration such as free rent, use of
employees, and vehicles. To do this, Martin O’Boyle used both his own personal assets, and the
assets of his business, Commerce Group.
69.

Martin O’Boyle caused the entity, CAFI, to be incorporated in Florida and

directed that his three close business associates, William Ring, Denise DeMartini, and Brenda
Russell be named as the board of directors.
70.

Martin O’Boyle also agreed with Chandler that he would hire Chandler to serve

as the Executive Director of CAFI at a six-figure salary as well as substantial benefits. .
71.

Chandler’s actual duty was to travel the state making hundreds of public records

requests to public entities and state contractors. Thereafter, any evidence that would serve as a
pretext for a lawsuit was to be forwarded immediately to Jonathan O’Boyle for the filing of
litigation. Both CAFI and the O’Boyle Law Firm were operating from a room located in
Commerce Group’s offices.
72.

Prior to meeting the O’Boyles, Chandler had earned approximately $5,000.00

during the year 2013. Upon opening the alleged foundation, Martin O’Boyle agreed to pay
Chandler $120,000.00 per year and to provide him with a car to drive around the state to make
public records requests. Martin O’Boyle advised Chandler that he would entirely fund the
6

So-called “Feeder” relationships have previously drawn the scrutiny of the Florida Bar, which has found them to
be unethical (See FL Eth. Op. 02-8).
RICHMAN GREER, P.A.
Miami  West Palm Beach

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foundation and law firm on an unlimited basis, including the payment of all court filing fees.
Martin O’Boyle, Jonathan O’Boyle, Ring and DeMartini did not tell Chandler at the time, but
had planned that they were going to require that all of CAFI’s clients be represented by the
O’Boyle Law Firm, that Chandler would not have exclusive control over whether a claim is
settled and for how much, and that the O’Boyle Law Firm, CAFI, Martin O’Boyle, and Jonathan
O’Boyle intended to obtain fraudulent settlements from unwitting defendants by claiming their
fees and costs are an amount far in excess of what they actually were.
73.

On January 27, 2014, Chandler was hired to act as Executive Director and CAFI

was incorporated.
74.

As instructed, and in furtherance of the scheme to defraud and extort, albeit

unwittingly, Chandler began creating public records requests and legal claims and referred these
to the newly created O’Boyle Law Firm.
c. O’Hare’s Involvement.
75.

In or about 2013, Chandler had previously met with Defendant Christopher

O’Hare to discuss public records litigation. O’Hare was upset with the Town over the denial of
his zoning application regarding construction of a metal roof.
76.

In an attempt to force the Town to approve his roof, O’Hare recruited Chandler

and along with the co-Defendants began to inundate the Town with public records requests.
77.

O’Hare met regularly with Martin O’Boyle and Jonathan O’Boyle and agreed to

work in concert with them and to file hundreds of public records requests in his own name as
well as under fictitious names with the clerk for the Town of Gulf Stream.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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78.

O’Hare further agreed that after the Town was incapacitated and unable to timely

and fully respond to the public records requests, the O’Boyle Law Firm would represent him in
litigation against the Town, to generate money for the firm and the members of the Enterprise.
79.

O’Hare began making public records requests to the Town in July 2013.

80.

Initially, those public records requests were made by O’Hare in his own name or

using anonymous email addresses ultimately determined to be associated with O’Hare.7
81.

Although O’Hare would make numerous requests in a single day, the Town

initially did not assess any special service charges to him for extensive use of information
technology resources or extensive clerical or supervisory assistance before making responsive
records available.
82.

In response to sixty (60) individual public records requests O’Hare submitted to

the Town in a single day - on January 16, 2014, the Town wrote to O’Hare to advise that since
August 2013, O’Hare had made more than 500 public records requests, that the Town had
already spent more than 200 hours responding to Mr. O’Hare’s prior requests, that O’Hare had
failed to retrieve the vast majority of documents gathered by the Town in response to his
requests, and that O’Hare had failed to pay the copy charges associated with those documents
that had been made available or to pay estimates associated with other requests.
83.

Thereafter, the Town began to assess special service charges against O’Hare for

his extensive use of information technology resources and/or extensive clerical or supervisory
assistance associated with responding to his requests.

7

See note 3, supra
RICHMAN GREER, P.A.
Miami  West Palm Beach

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84.

To avoid those special service charges associated with the time spent responding

to requests from a single individual and make the Town believe that numerous individuals were
requesting records, O’Hare began making public records requests in a single day or within a few
days to the Town using fictitious or fraudulent personal identification. The fraudulent aliases
used by O’Hare, many of which mock the names of Town officials including Town Manager Bill
Thrasher, Mayor Scott Morgan and Commissioners Donna White, Joan Orthwein and Robert
Ganger, include:
Irnawaty Tirtarahardja
irnawatyt@gmail.com8
Janto Djajaputra
jantodjajaputra@gmail.com9
Rodrigo Tejera
tejeratejeratejera@gmail.com10
Nevada Smith
nevadasmithcowboy@gmail.com11
Frank Smith
frank.smith.iconoclast@gmail.com12
Hokuikekai Keihanaikukauakahihuliheekahaunaele
ll0i0i00lll0ii0llll00i0ii0llll@gmail.com
Buffy Howell
buffyhowell@gmail.com
Bobby Gangrene
bobbygangrene@gmail.com
Billy Trasher
billytrasher@gmail.com

8

When a cursor hovers over this email address, a link appears to chrisoharegulfstream@gmail.com. O’Hare has
filed at least one public records lawsuit seeking recovery under the Public Records Act for a public records request
filed in the name of Irnawaty Tirtarahardja. See O’Hare v. Gulf Stream, Case No. 2014CA008327XXXXMB AF
(15th Judicial Circuit in and for Palm Beach County).
9

When a cursor hovers over this email address, a link appears to chrisoharegulfstream@gmail.com. Moreover,
O’Hare has filed public records lawsuits seeking recovery under the Public Records Act for a public records request
filed in the name of Janto Djajaputra. See O’Hare v. Gulf Stream, Case No. 2014CA006848XXXXMB AB (15 th
Judicial Circuit in and for Palm Beach County); O’Hare v. Gulf Stream, Case No. 2014CA007516XXXXMB AD
(15th Judicial Circuit in and for Palm Beach County).
10

When a cursor hovers over this email address, a link appears to c@gmail.com. O’Hare has filed at least one public
records lawsuit seeking recovery under the Public Records Act for a public records request filed in the name of
Rodrigo Tejera. See O’Hare v. Gulf Stream, Case No. 2014CA006848XXXXMB AB (15th Judicial Circuit in and
for Palm Beach County).
11

When a cursor hovers over this email address, a link appears to chrisoharegulfstream@gmail.com.

12

When a cursor hovers over this email address, a link appears to c@gmail.com.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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 Case 9:15-cv-80182-KAM Document 1 Entered on FLSD Docket 02/12/2015 Page 24 of 49

Scotty Morgin
Gonna White

scottymorgin@gmail.com
gonnawhite@gmail.com

Freddy Farnsworth

Frederick.freddy.farnsworth@gmail.com

Groan Orthwein
Americo Vespuchi
Patrick Henry
Wyatt Burp
Prigs Hypocrites
Harry LaFarge

groanorthwein@gmail.com
discover.the.record@gmail.com
no.gov.secrets@gmail.com
ok.coral.record@gmail.com
prigs.and.hypocrites@gmail.com
lafargetech@gmail.com13

85.

O’Hare has made hundreds of additional public records requests to the Town

using fictitious or fraudulent personal identification and continues to do so in order to
fraudulently induce the Town not to assess special service charges against him associated with
the extensive use of resources and clerical or supervisory assistance.
86.

O’Hare has turned the nearly one thousand public records requests he has made

against the Town into more than two dozen lawsuits.
87.

O’Hare has been a client of the O’Boyle Law Firm generally, and Jonathan

O’Boyle in particular, since the firm’s inception in January 2014. The O’Boyle Law Firm
represents him in approximately 10 of the public records suits he has brought against the Town,
with the first such suit filed by the O’Boyle Law Firm on his behalf on January 22, 2014.
88.

On May 8, 2014, O’Boyle and O’Hare formally joined forces as Plaintiffs against

the Town with the filing of a Complaint to Enforce Florida’s Public Records and Open Public
Meetings

Act.

See

O’Boyle

and

O’Hare

v.

13

Town

of

Gulf

Stream,

Case

No.

O’Hare has filed at least one public records lawsuit seeking recovery under the Public Records Act for a public
records request filed in the name of Harry LaFarge. See O’Hare v. Gulf Stream, Case No. 2014CC012274XXXMB
AB (15th Judicial Circuit in and for Palm Beach County).
RICHMAN GREER, P.A.
Miami  West Palm Beach

24

 Case 9:15-cv-80182-KAM Document 1 Entered on FLSD Docket 02/12/2015 Page 25 of 49

2014CA005628XXXXMB AG (Circuit Civil Division, 15th Judicial Circuit in and for Palm
Beach County).
c. Chandler Realizes He is Being Used.
89.

Towards the end of March and in early April 2014, Chandler learned that Ring

and Martin O'Boyle were making public records requests directed to the Town of Gulf Stream,
allegedly at the behest of CAFI, without his knowledge or consent.
90.

In April 2014, when Chandler inquired as to why he was not informed about all

lawsuits filed by CAFI, the organization over which he was the executive director, DeMartini
explained to Chandler that she was Martin O'Boyle's key employee and the director on the board
of CAFI to whom Chandler was to report. DeMartini further explained that she would be
directing the flow of litigation to the O’Boyle Law Firm and that she would be calling the shots.
91.

DeMartini, a non-lawyer, attended law firm meetings with Chandler and

participated in reviews of all client matters, not just CAFI cases. She made personnel decisions
for the O’Boyle Law Firm and managed the alleged law firm’s finances while claiming to be a
board member of CAFI.
92.

During this same time, DeMartini demanded that Chandler produce a minimum

quota of 25 new lawsuits a week for the O’Boyle Law Firm to file.
93.

In May 2014 DeMartini notified Chandler that she had full access to all of the

O’Boyle Law Firm’s internal records and client files. She shared all client reports with Chandler,
not just reports concerning CAFI.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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 Case 9:15-cv-80182-KAM Document 1 Entered on FLSD Docket 02/12/2015 Page 26 of 49

94.

After discovering that public records requests were being filed in the name of the

foundation without his knowledge, Chandler again directed that all public records requests on
behalf of CAFI be made by himself, or at the very least, that he be advised they are being made.
95.

On May 16, 2014, DeMartini asked Chandler for a recap of the number of cases

referred by CAFI to the O’Boyle Law Firm from January through May. DeMartini expressed her
frustration to Chandler that he has only generated 211 cases in the 12 weeks since CAFI was
created.
96.

During May 2014 Chandler learned that the O’Boyle Law Firm had no written fee

agreements or engagement letters between the O’Boyle Law Firm and CAFI.
97.

By the end of May, DeMartini and Jonathan O'Boyle continued to express their

frustration to Chandler. Chandler insisted on reviewing and verifying all lawsuits to be filed by
CAFI. DeMartini and O’Boyle expressed concern that Chandler’s review was slowing down the
flow of litigation generated by the firm.
98.

By this point, it had become abundantly clear to Chandler that DeMartini, Ring

and O’Boyle were only concerned with the volume of cases that could be generated, and of
course the profits that could be had in such cases by way of fraudulent settlement demands,
rather than any public service. This suspicion was confirmed when Chandler’s repeated attempts
to inform Ring and DeMartini of opportunities to work with civil rights groups, public agencies,
student groups and journalists on open government issues were completely ignored.
99.

In June 2014, it came full circle. Chandler learned that Martin O’Boyle, Jonathan

O’Boyle, the O’Boyle Firm, Commerce Group, CAFI, Ring, and DeMartini were operating a

RICHMAN GREER, P.A.
Miami  West Palm Beach

26

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RICO Enterprise that was engaged in a scheme to defraud and extort the defendants with the
hundreds if not thousands of public records requests that were made.
100.

The scheme involved the firm demanding monetary settlements on behalf of

CAFI (or others) far beyond the actual attorneys’ fees and expenses incurred and contemplated in
F.S. §119.12, and to keep all of the proceeds, including the “windfall”. If the demands were not
met, then the scheme called for intimidation via threat of additional bogus public records
requests and frivolous litigation until the demands were met.
101.

On June 30, 2014 Chandler arrived at the Commerce Group/CAFI/O'Boyle Law

Firm office and presented his letter of resignation to Ring. Immediately thereafter, Martin
O’Boyle demanded that Chandler retract his statement (in an email) confirming Jonathan
O’Boyle’s complicity in the scheme to defraud and extort. Martin O’Boyle threatened Chandler
that if he did not retract his statements concerning Jonathan O’Boyle’s involvement in the
“windfall” scheme, Chandler would “force us to respond by making your life very unpleasant”.
Thereafter Chandler refused to retract the emails and Martin O’Boyle repeated his threats several
times.
102.

As part of the scheme, the O’Boyle Law Firm has now filed hundreds of spurious

lawsuits on behalf of O’Boyle, O’Hare, CAFI, and other pretextual entities and individuals
including Defendants CG, SDG, OPR, PAI, AH, Commerce GP, CGA, CRO, AE, CRG. These
defendants have become engaged in a massive scheme to generate and collect attorneys’ fees
from Florida agencies and state contractors beyond any fees actually earned.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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d. How the scheme operates: the Example of Gulf Stream.
103.

The Town Of Gulf Stream has become the epicenter of the RICO Enterprises’

scheme—a sort of example, of what the Enterprise will do to all Class Members if allowed to
continue with its pattern of racketeering activity.
104.

Through the RICO Enterprise, Defendants have joined forces to barrage the Town

with nearly 2,000 public records requests from fictitious e-mail addresses and purported not-forprofits. (See Composite Exhibit “B.”) Shortly thereafter, Defendants file suit against the Town,
asserting unreasonable delay and seeking fees under the Public Records Act. At the same time,
they threaten the Town that if it will not settle, it will be faced with hundreds of additional public
records requests and dozens of lawsuits, along with the crippling associated costs of both.
105.

For instance, in the first 28 days of September, 2013, the Town received 121

public records requests or approximately 6 requests per business day. All of those requests were
made by Defendant Chris O’Hare (115) or Joel Chandler (6). With the exception of two requests
made by O’Hare’s attorney, Lou Roeder, Esq., all of O’Hare’s requests were made to the Town
by inconspicuous e-mail addresses that failed to indicate the requests were made on behalf of
O’Hare:

emailfinder.mail.mail@gmail.com,

permit.record.search@gmail.com,

publicdocsearch@gmail.com,

record.public@yahoo.com,

and

account-

information@pacificwest.com.
106.

O’Hare’s requests were not spread over time; instead, he barraged the Town with

multiple requests in a single day, e.g., 18 requests on September 4, 2013, 24 requests on
September 20, 2013 and 58 requests on September 23, 2013. (See Composite Exhibit “B.”). On
September 29, 2013, a Sunday, O’Hare sent the Town approximately 40 public records requests
RICHMAN GREER, P.A.
Miami  West Palm Beach

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in a four (4)-hour period. The Town responded to the requests, producing documents, providing
estimates of fees authorized by the Public Records Act or advising O’Hare that no responsive
documents existed. O’Hare ultimately filed 7 lawsuits over those September 29, 2013, requests,
alleging that the Town unreasonably delayed in responding to his requests, and has continued to
litigate those suits solely to extract settlement payouts from the Town -- even though documents
have been produced, he has failed to pay the required estimates or he has been unable to identify
responsive records that exist but were not produced.
107.

In the first 20 days of January 2014, O’Hare made approximately 94 public

records requests to the Town by e-mail. Then, on January 21, 2014, O’Hare and O’Boyle joined
forces to hit the Town with 15 public records requests in a single day; O’Hare making his
requests by e-mail and O’Boyle making his in person. One of these was a request by O’Boyle for
a copy of the Town’s sign-in-log. Although the Town produced the record to O’Boyle in less
than 2 business days, the newly formed O’Boyle Law Firm seized on the opportunity to sue the
Town on O’Boyle’s behalf, asserting unreasonable delay and seeking attorney’s fees.
108.

By June 2014, the Enterprise had made more than 1,000 public records requests to

the Town and filed more than two dozen public records suits against it, including more than one
dozen suits seeking statutory attorneys’ fees filed by The O’Boyle Law Firm. In the month of
June 2014 alone, the Enterprise hit the Town with approximately 180 public records requests.
These requests were made by e-mail from Defendants O’Hare (using fictitious names), O’Boyle,
CAFI, SDG, CGA, AH and Commerce GP. As noted infra, O’Boyle and O’Hare then appeared
at the July 11, 2014 Town Commission meeting overtly threatening to cause the Town to spend
increased legal fees or settle with him at risk of continued public records requests and lawsuits.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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e. How the scheme operates: the example of Wantman Group.
109.

On Saturday, April 19, 2014, Wantman Group received an email from “An

Onomy” seeking the “Certificate of Insurance referenced on Page 6 of 16 of the South Florida
Water Management District contract 4600002690.” A true and correct copy of the email is
attached as part of Composite Exhibit “D.”
110.

Approximately 3 weeks later, on or around May 8, 2014, and without any further

inquiry to the Wantman Group, including a simple confirmation that the public records request
was in fact received, CAFI, through its attorneys, Defendants Taylor and the O’Boyle Law Firm,
filed a two-count complaint seeking a copy of the requested record, an immediate hearing, a
declaration that Wantman Group violated Section 119.11, and of course, an award of attorneys’
fees and costs. A true and correct copy of the two-count complaint is attached hereto as part of
Composite Exhibit “D.”
111.

In response to the two-count complaint, Wantman Group, through counsel, sent a

letter advising Mr. Taylor and CAFI that “Wantman was not aware of the Chapter 119 request,”
as it was sent to an obscure individual and not the records custodian of Wantman. The letter also
attached a copy of the requested document “in the spirit of cooperation,” and demanded that the
lawsuit be dismissed. A true and correct copy of the May 29, 2014 letter from counsel is
attached hereto as part of Composite Exhibit “D.”
112.

Before Wantman Group even filed its Answer and Defenses to the complaint,

Defendants Taylor, O’Boyle Law Firm, and CAFI sent an email to Wantman Group’s counsel
offering to settle the public records dispute for $3,923.00. A true and correct copy of the email

RICHMAN GREER, P.A.
Miami  West Palm Beach

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and attached draft settlement agreement from Defendants Taylor, O’Boyle Law Firm and CAFI
is attached hereto as part of Composite Exhibit “D.”
113.

Notwithstanding the document had now been produced voluntarily, Defendants

Taylor, the O’Boyle Law Firm, and CAFI refused to dismiss the lawsuit, requiring Wantman
Group to Answer the same.
114.

Upon receipt of the Answer, Defendants Taylor, O’Boyle Law Firm, and CAFI

immediately sent form discovery (not even tailored to the Wantman Group, but containing things
completely inapplicable to Wantman) as an indirect threat that more litigation is to follow if the
settlement demands are not assented to.
115.

In all, Wantman Group has incurred substantial damages in having to respond to

the bogus records request and then defend against the frivolous litigation.
116.

This scheme to defraud and extort has directly injured the Class members as well

as the Plaintiffs. To date, Gulf Stream has been injured in the amounts and categories set forth in
Composite Exhibit “E” and Exhibit “F” hereto.
117.

In light of the foregoing, Plaintiffs were damaged as a direct result of the RICO

Enterprise based on Defendants’ fraudulent claims, backed-up by Defendant’s extortion and
threats calculated to cause Class Members to spend money responding to bogus public records
requests and defending frivolous lawsuits.
VI.

COUNT I—Violation of 18 U.S.C. § 1964(a) and (c).
118.

Plaintiffs’ adopt and incorporate by reference paragraphs 1 through 117 above as

though fully set forth herein.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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119.

Plaintiffs’ seek relief under 18 U.S.C. § 1964(a) of RICO to prevent and restrain

Defendants from committing future violations of section 1962, including, but not limited to,
ordering the Defendants to divest themselves of their interest in the Enterprise; impose
reasonable restrictions on the future activities or investments of the Defendants to ensure no
further engagement in a similar endeavor as described herein; and order dissolution of all
corporate defendants.
120.

Plaintiffs also seek relief under 18 U.S.C. § 1964(c) of RICO, and seek threefold

the damages sustained by the Plaintiffs and the Class Members, along with costs of this suit,
including a reasonable attorney fee.
121.

The Plaintiffs, and each Class Member that Plaintiffs represent are persons within

the meaning of 18 U.S.C. § 1964(c) and § 1961(3).
122.

18 U.S.C. § 1962(c) makes it unlawful “for any person employed by or associated

with any enterprise engaged in, or the activities of which affect, interstate or foreign commerce,
to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through
a pattern of racketeering activity.” Through § 1964(c), “any person injured in his business or
property by reason of a violation of section 1962 of this chapter may sue therefore in any
appropriate United States District Court and shall recover threefold the damages he sustains and
the cost of the suit, including a reasonable attorney’s fee.…” Because the Plaintiffs, along with
the Class Members, were injured in their business or property by Defendants’ violation of 1962,
they are entitled to threefold their damages, attorneys’ fees and costs.
a. The Enterprise.

RICHMAN GREER, P.A.
Miami  West Palm Beach

32

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123.

The Defendants, through themselves and through their employees and agents,

formed a union and association-in-fact enterprise that engages in, and the activities of which
affect, interstate commerce. This Enterprise has as its goal, a scheme to defraud and intimidate
through acts of extortion, municipalities, municipal agencies, private contractors of
municipalities and anyone else subject to, or even arguably subject to, the Sunshine Law, into
paying unjustified, grossly inflated and fraudulent settlement amounts so as to create and
increase profits to the Enterprise.
124.

Every Defendant had a role or position in the Enterprise, all of which worked

together towards the common goal of defrauding or extorting municipalities, municipal agencies,
private contractors of municipalities and anyone else subject to or even arguably subject to the
Sunshine Law. The Defendants’ respective roles and their importance to the Enterprise, as well
as how it advanced the interest of the Enterprise are as follows:
a. Martin O’Boyle: Martin O’Boyle is one of the engineers of the Enterprise’s
scheme to defraud and extort, as well as its principal financier through his various
business entities. Martin O’Boyle directs the Enterprise, and is responsible for the
following actions taken to advance the goal of the Enterprise:
i. Financing the opening and continued existence of the O’Boyle Law Firm,
along with his son, Jonathan O’Boyle;
ii. Financing the opening and continued existence of CAFI, OPR and PAI;
iii. Directing the operations of CAFI, OPR and PAI through his appointed
directors and key employees of his other business entities such as
Commerce Group.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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iv. Utilizing his other business entities including Commerce Group, SDG,
AH, CGA, CRO, AE and CRE to make spurious, frivolous, and baseless
public records requests and to file resulting lawsuits to either generate
windfall fees for himself, Jonathan O’Boyle, Ring, DeMartini and the
O’Boyle Law Firm; or to extort a settlement payment for the victims.
v. Mandating, under threat of no funding, that:
1. CAFI file no less than 25 cases per week;
2. All cases filed by CAFI and the other Defendants be referred to the
O’Boyle Law Firm; and,
3. All cases be settled for an amount substantially in excess of the
fees and costs incurred in the case.
b. Jonathan O’Boyle. Jonathan O’Boyle is one of the engineers of the Enterprise’s
scheme to defraud and extort, along with his father Martin O’Boyle. To advance
the interest of the Enterprise, Jonathan O’Boyle has taken the following actions:
i. Creating, and sustaining the O’Boyle Law Firm, a necessary element of
the Enterprise;
ii. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate windfall fraudulent and extortive fees
for Martin O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle
Law Firm;
iii. Directing the prosecution of hundreds of public records suits filed by the
O’Boyle Law Firm throughout the State of Florida on behalf of other
RICHMAN GREER, P.A.
Miami  West Palm Beach

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members of the Enterprise including, but not limited to, his father Martin
O’Boyle, O’Hare, CAFI, Commerce Group, OPR, PAI, AH, CGA, CRO,
AE, and CRG.
iv. Ordering that public records suits be filed on behalf of Florida plaintiffs,
such as Chandler, without knowledge or consent of the Plaintiffs; and,
v. Ordering that, as a pattern and practice, all public records suits would be
settled for an amount substantially in excess of the actual fees and costs
incurred to generate a profit for the Enterprise, and directing that
settlement demands be made by the O’Boyle Law Firm to the Class
Members in accordance with this pattern and practice using the mail or
wires.
c. Christopher O’Hare.

Christopher O’Hare has taken the following actions to

advance the Enterprise’s scheme to defraud:
i. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fees for himself, Martin O’Boyle,
Jonathan O’Boyle and the O’Boyle Law Firm and,
ii. Fraudulently misrepresenting his identity in order to induce violation of
the Public Records Act and to avoid fees owed by him thereunder.
d. William Ring. William Ring is one of the engineers of the Enterprise’s scheme to
defraud and extort, having served as Martin O’Boyle’s “right-hand” for more than
25 years. To advance the interest of the Enterprise, Ring has taken the following
actions:
RICHMAN GREER, P.A.
Miami  West Palm Beach

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i. Assisting with the creation of not-for-profit Defendants CAFI, PAI and
OPR for the sole purpose of generating fraudulent, extortive and windfall
attorney’s fees by the filing and prosecution of frivolous public records
lawsuits;
ii. Directing the operations of CAFI through key employees of Martin
O’Boyle’s other business entities such as Commerce Group.
iii. Mandating under threat of no funding, that:
1. All cases filed by CAFI and the other Defendants be referred to the
O’Boyle Law Firm; and,
2. All cases be settled for an amount substantially in excess of the
fees and costs incurred in the case.
iv. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fees for Martin O’Boyle, Jonathan
O’Boyle, Ring, DeMartini and the O’Boyle Law Firm;
v. Ordering, that as a pattern and practice, all public records suits would be
settled for an amount substantially in excess of the actual fees and costs
incurred to generate a profit for the Enterprise; and,
vi. Purporting to serve as the Florida supervising attorney of the O’Boyle
Law Firm (notwithstanding his total lack of litigation experience) in order
to hide the fact that non-Florida attorney Jonathan O’Boyle is truly
directing the firm’s activities, all in violation of the Rules Regulating the
Florida Bar.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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e. Denise DeMartini. Denise DeMartini is one of the engineers of the Enterprise’s
scheme to defraud and extort, having served as Martin O’Boyle’s “left-hand” for
more than 25 years. To advance the interest of the Enterprise, DeMartini has
taken the following actions:
i. Assisting with the creation of not-for-profit Defendants CAFI, PAI and
OPR for the sole purpose of generating fraudulent, extortive and windfall
attorney’s fees by the filing and prosecution of frivolous public records
lawsuits;
ii. Directing the operations of CAFI through key employees of Martin
O’Boyle’s other business entities such as Commerce Group.
iii. Mandating under threat of no funding, that:
1. CAFI file no less than 25 cases per week;
2. All cases filed by CAFI and the other Defendants be referred to the
O’Boyle Law Firm; and,
3. All cases be settled for an amount substantially in excess of the
fees and costs incurred in the case.
iv. Ordering, that as a pattern and practice, all public records suits would be
settled for an amount substantially in excess of the actual fees and costs
incurred to generate a profit for the enterprise; and,
v. Managing the operations of the O’Boyle Law Firm while simultaneously
serving as an officer of its clients, including CAFI, and sharing
confidences of those clients.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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f. Commerce Group. To advance the interest of the Enterprise, Martin O’Boyle’s
real estate development company, the Commerce Group, has taken the following
actions:
i. Financing the opening and continued existence of the O’Boyle Law Firm
and the not-for-profit Defendants CAFI, OPR and PAI; and,
ii. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fees for Martin O’Boyle, Jonathan
O’Boyle, Ring, DeMartini and the O’Boyle Law Firm.
g. Public Awareness Institute, Inc. To advance the interests of the Enterprise, the
Florida not-for-profit PAI has taken the following actions:
i. Incorporating as a Florida not-for-profit corporation for the sole purpose
of generating windfall attorney’s fees by the filing and prosecution of
frivolous public records lawsuits; and,
ii. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate windfall fees for Martin O’Boyle,
Jonathan O’Boyle, Ring, DeMartini and the O’Boyle Law Firm.
h. Citizens Awareness Foundation, Inc. To advance the interests of the Enterprise,
the Florida not-for-profit CAFI has taken the following actions:
i. Incorporating as a Florida not-for-profit corporation for the sole purpose
of generating windfall attorney’s fees by the filing and prosecution of
frivolous public records lawsuits; and,

RICHMAN GREER, P.A.
Miami  West Palm Beach

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ii. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fraudulent, extortive, and windfall
fees for Martin O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the
O’Boyle Law Firm.
i. Our Public Records, LLC. To advance the interests of the Enterprise, the
Florida not-for-profit OPR has taken the following actions:
i. Incorporating as a Florida not-for-profit corporation for the sole purpose
of generating windfall attorney’s fees by the filing and prosecution of
frivolous public records lawsuits; and,
ii. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fraudulent, extortive and windfall fees
for Martin O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle
Law Firm.
j. Stopdirtygovernment, LLC. To advance the interests of the Enterprise, SDG has
filed spurious, frivolous, and baseless public records requests as well as resulting
lawsuits solely to generate fraudulent, extortive and windfall fees for Martin
O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle Law Firm.
k. Airline Highway, LLC. To advance the interests of the Enterprise, AH has filed
spurious, frivolous, and baseless public records requests as well as resulting
lawsuits solely to generate fraudulent, extortive and windfall fees for Martin
O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle Law Firm.

RICHMAN GREER, P.A.
Miami  West Palm Beach

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l. Commerce GP, Inc.. To advance the interests of the Enterprise, Commerce GP
has filed spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fraudulent, extortive and windfall fees for
Martin O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle Law Firm.
m. CG Acquisition Co., Inc. To advance the interests of the Enterprise, CGA has
filed spurious, frivolous, and baseless public records requests as well as resulting
lawsuits solely to generate fraudulent, extortive and windfall fees for Martin
O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle Law Firm.
n. CRO Aviation, Inc.. To advance the interests of the Enterprise, CRO Aviation,
Inc. has filed spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fraudulent, extortive and windfall fees for
Martin O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle Law Firm.
o. Asset Enhancement, Inc. To advance the interests of the Enterprise, Asset
Enhancement, Inc. has filed spurious, frivolous, and baseless public records
requests as well as resulting lawsuits solely to generate fraudulent, extortive and
windfall fees for Martin O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the
O’Boyle Law Firm.
p. Commerce Realty Group, Inc. To advance the interests of the Enterprise, CRG
has filed spurious, frivolous, and baseless public records requests as well as
resulting lawsuits solely to generate fraudulent, extortive and windfall fees for
Martin O’Boyle, Jonathan O’Boyle, Ring, DeMartini and the O’Boyle Law Firm

RICHMAN GREER, P.A.
Miami  West Palm Beach

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q. The O’Boyle Law Firm. At the center of the Enterprise’s scheme to defraud, the
O’Boyle Law Firm has taken the following actions to advance the Enterprise’s
interests:
i. Profiting from improper illegal, and unethical feeder and fee-sharing
relationships and sharing space with its non-lawyer clients, including
Defendants Commerce Group, CAFI, OPR and PAI;
ii. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits on behalf of its feeder clients, all of which are entities
affiliated with and funded by the Enterprise or its members; and,
iii. Using the mail and wires to demand that putative Class Members settle
public records lawsuits in an amount substantially in excess of the actual
fees and costs incurred to generate a profit for the Enterprise and
fraudulently misrepresenting the amount of those fees and costs.
r. Ryan Witmer. Ryan Witmer is one of the engineers of the Enterprise’s scheme to
defraud, along with his law school classmate and friend Jonathan O’Boyle. To
advance the interest of the Enterprise, Witmer took the following actions:
i. Creating the O’Boyle Law Firm and agreeing to serve as its purported
Florida supervising attorney in order to hide the fact that non-Florida
attorney Jonathan O’Boyle is truly directing the firm’s activities, all in
violation of the Rules Regulating the Florida Bar;
ii. Causing the O’Boyle Law Firm to profit from improper illegal and
unethical feeder and fee-sharing relationships and to share space with its
RICHMAN GREER, P.A.
Miami  West Palm Beach

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non-lawyer clients, including Defendants Commerce Group, CAFI, OPR
and PAI;
iii. Facilitating the unlicensed practice of law by Jonathan O’Boyle;
iv. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits; and,
v. Using the mail and wires to demand that putative Class Members settle
public records lawsuits in an amount substantially in excess of the actual
fees and costs incurred to generate a profit for the Enterprise and
fraudulently misrepresenting the amount of those fees and costs.
s. Giovani Mesa. An attorney with the O’Boyle Law Firm, Mesa has taken the
following actions to advance the Enterprise’s scheme to defraud:
i. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits; and,
ii. Using the mail and wires to demand that putative Class Members settle
public records lawsuits in an amount substantially in excess of the actual
fees and costs incurred to generate a profit for the Enterprise and
fraudulently misrepresenting the amount of those fees and costs.
t. Nickalaus Taylor. An attorney with the O’Boyle Law Firm, Taylor has taken the
following actions to advance the Enterprise’s scheme to defraud:
i. Filing spurious, frivolous, and baseless public records requests as well as
resulting lawsuits; and,

RICHMAN GREER, P.A.
Miami  West Palm Beach

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ii. Using the mail and wires to demand that putative Class Members settle
public records lawsuits in an amount substantially in excess of the actual
fees and costs incurred to generate a profit for the Enterprise and
fraudulently misrepresenting the amount of those fees and costs.
125.

The members of the Enterprise set forth above, function in a fashion so as to

become a continuing unit which furnishes a vehicle for the commission of the racketeering
activity set forth below. The continuity of the Enterprises’ actions will be repeated in the future
if it is allowed to continue.
a. Pattern of Racketeering.
126.

Pursuant to 18 U.S.C. § 1961(1), “racketeering activity” includes the predicate

crimes of mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and extortion (18 U.S.C.
1951). Under to 18 U.S.C. § 1341, “whoever, having devised or intending to devise any scheme
or artifice to defraud, or for obtaining money or property by means of false or fraudulent
pretenses, representations, or promises…for the purpose of executing such scheme or artifice or
attempting so to do” and uses the mails or other commercial carrier to do so, commits mail fraud.
Similarly, under 18 U.S.C. § 1343, “Whoever, having devised or intending to devise any scheme
or artifice to defraud, or for obtaining money or property by means of false or fraudulent
pretenses, representations, or promises, transmits or causes to be transmitted by means of wire,”
commits wire fraud. Under 18 U.S.C. § 1951, extortion is “the obtaining of property from
another, with his consent, induced by wrongful use of actual or threatened force, violence, or fear
(including fear of economic loss) ….”

RICHMAN GREER, P.A.
Miami  West Palm Beach

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127.

All members of the Enterprise have committed at least one predicate act of mail

fraud, wire fraud, or extortion, which, when combined, constitutes a pattern of racketeering
undertaken by the Enterprise to accomplish the goals of the Enterprise. Examples of predicate
acts by each member of the Enterprise is set forth on the charts attached hereto as Composite
Exhibit “B”14 and Exhibit “F.” (these charts are exemplary, and by no means exhaustive). In
addition to the mail and/or wire fraud predicate acts committed by the RICO Enterprises’
members, O’Hare and Martin O’Boyle have blatantly threatened to cause the Town to spend
increased legal fees or settle.
128.

For example, at the July 11, 2014 Town Commission Meeting, O’Boyle said to

the commissions; “why would you spend $1,700 when on your very best day, best day you win
$450? …You want to lower the legal fees, you want to get rid of the lawyer fees? What you
spent you could have settled with this guy [O’Hare]…You would have spent half the money and
everyone would have been happy.”
129.

At this same meeting, Martin O’Boyle, when addressing the Town’s budget,

suggested that “you won’t have to worry about millage rate” if the Town would “sit down and
try to solve” the issues with O’Hare—described by O’Boyle as “the guy that wants to do nothing
but file law suits….”
130.

However, Mr. O’Hare’s most obvious act of extortion occurred at a September

12, 2014 Commission Tentative Budget Hearing, when, while referencing the outstanding public
records requests, he stated: “There’s a lot on the board and a lot more comin’. Be so much easier
just to get this settled instead of spending more money each time the lawyers write a letter than it
14

Unless otherwise indicated, each of the Public Records request contained in Composite Exhibit “B” was made via
email or facsimile and constitutes a use of the wires.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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would take to settle some of these things.” A month later, Mr. O’Hare reiterated these threats at
the October 10, 2014 Town Commission meeting, stating that “So many of these cases could be
resolved by just admitting guilt [and] paying the attorneys’ fees….I meant a typical public
records case settled for …..what was Joel Chandlers? Was it $1,500 to make him go away? And
yet you spend $20,000 saying no, we’re not guilty and we’re not gonna cooperate. That’s just
not a good use of public money.”
131.

In addition to the verbal threats, Martin O’Boyle and O’Hare have also attempted

mutiny-styled rallies of the citizens to try and pressure the Town into settling the scores of public
records requests. In January of 2015, Martin O’Boyle and O’Hare published the “Gulf Stream
Patriot,” a professionally prepaid bulletin in large part devoted to seeking support to force
settlement of all of the public records lawsuits. In this bulletin, O’Boyle and O’Hare suggest to
the residents of the Town that: “Because of the stout costs, [of the public records litigation] the
residents are the ones being punished! Let’s all hope a resolution is in sight; and the costs
disappear.”
132.

On the back page, the “Gulf Stream Patriot” states that the “hottest topic” in the

Town right now is the public records litigation. Accordingly, the bulletin then asks the readers to
answer the following question in an online survey: “Are you in favor of the Town reaching a
peaceful resolution with Mr. O’Boyle and Mr. O’Hare, which would end all the expenses and
litigation in a prompt fashion?”
133.

Each of these statements made by either O’Boyle or O’Hare is an overt threat that

additional frivolous public records requests and accompanying litigation will follow if the Town

RICHMAN GREER, P.A.
Miami  West Palm Beach

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does not agree to settle the current cases. Accordingly, each of these statements is an act of
extortion, carried out to further the goal of the scheme to defraud and extort.
134.

Each of these actions is a regular way of doing business for the enterprise’s

members and threatens repetition in the future.
b. Reliance.
135.

The frivolous and often inconspicuous public records requests, as well as the false

and disguised identity of the requester, along with the fraudulent settlement demands that were
sent by the mails and the wires were justifiably relied upon by Plaintiffs and Class Members
when they paid the fraudulent and inflated settlement demands or when they retained additional
staff and spent additional resources in responding to the same.
c. Proximate Cause and Damages.
136.

The wrongful conduct of the enterprise set forth above, including the acts of mail

fraud, wire fraud, and extortion have directly harmed the Plaintiffs and the Class Members. The
Plaintiffs and the Class members were and are being extorted to pay inflated and fraudulent
settlement demands based on the frivolous and often inconspicuous public records requests made
by the enterprise, amounts they would not otherwise have paid.
137.

In addition, when the volume of the frivolous public records request began to

increase exponentially as the scheme to defraud and extort progressed, the Plaintiffs and Class
Members were forced to incur additional internal costs associated with having to try and respond
to the same. See the spreadsheet attached hereto as Composite Exhibit “E,” setting forth the
amount of additional internal costs the Town was forced to absorb as a result of the Enterprises’
pattern of racketeering.
RICHMAN GREER, P.A.
Miami  West Palm Beach

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138.

Finally, the acts of extortion were directly intended to cause the Plaintiffs to spend

money defending frivolous actions having no nexus or relation to the original settlement
demands as to which they were being coerced to comply with and pay. The Plaintiffs had a preexisting right to be free from the threats of the previously unrelated public records requests and
frivolous litigation, and the resolution of the threatened public records requests and litigation
would not impact the resolution of the case in which the threats were made but for the
extortionate nature of the threats. The threatened public records requests and frivolous litigation
were simply used as leverage to influence and gain compliance with fraudulent settlement
demands made in unrelated cases—a tool to extort additional money from the Plaintiffs. See the
spreadsheet attached hereto as Exhibit “F” outlining the amount spent in defending against the
frivolous public records requests and accompanying litigation brought to achieve a simple yet
calculated goal of causing the Town to hemorrhage money and consider settling.
139.

There is no person who has more directly sustained these injuries than the

Plaintiffs and Class Members, and the injuries are a direct and intended result of the enterprise’s
scheme to defraud the Plaintiffs, as well as the mail and wire fraud acts undertaken as part of the
scheme to defraud the Plaintiffs and Class Members.
140.

Pursuant to 18 U.S.C. § 1964(c), Counter-Plaintiff requests an award of attorneys’

fees and costs for having to bring the instant suit.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs, on their own behalf and on behalf of all other similarly
situated, pray for relief and judgment as follows:

RICHMAN GREER, P.A.
Miami  West Palm Beach

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a. Certifying the proposed Class and approving Plaintiffs Town of Gulf Stream and
Wantman Group, Inc. as class representatives;
b. Appointing Richman Greer, P.A as class counsel;
c. Awarding Plaintiffs and the Class treble damages in an amount to be proven at
trial, along with costs, interest, an attorneys’ fees; and
d. Entering whatever orders the Court deems necessary to divesting the Defendants
from their interest in the enterprise and imposing reasonable restrictions on the
future activities or investments of the Defendants to prohibit them from engaging
in a similar type endeavor;
e. Awarding any further relief the Court deems just and proper.
JURY DEMAND
Plaintiffs demand a trial by jury on all issues so triable.
Respectfully submitted this 12th day of February, 2015.
RICHMAN GREER, P.A.
Counsel for Plaintiffs
One Clearlake Centre, Suite 1504
250 Australian Avenue, South
West Palm Beach, Florida 33401-5016
Telephone: (561) 803-3500
Facsimile: (561) 820-1608

By:

/s/ Gerald F. Richman __________

GERALD F. RICHMAN
Florida Bar No.: 066457
grichman@richmangreer.com
dcostonis@richmangreer.com
ERIC M. SODHI
Florida Bar No.: 0583871
esodhi@richmangreer.com
mramirez@richmangreer.com

RICHMAN GREER, P.A.
Miami  West Palm Beach

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LEORA B. FREIRE
Florida Bar No.: 0013488
lfreire@richmangreer.com

RICHMAN GREER, P.A.
Miami  West Palm Beach

49