Gmail - Records Request Page 1 of 36 Eric McDonough Records Request 34 messages Eric McDonough Sun, Jun 5, 2016 at 11:15 PM To: estetting@wsh-law.com Cc: agreenstein004@hotmail.com, Gary Ostrow , craig@weissberglegal.com, Pro , Felipe Hemming , Sam Zeskind , "David M. Wolpin" Dear Mr. Stetting, I am hereby filing a formal 119 request with you personally as a custodian of public records under Florida law. Under the provisions of FSS. 119.0701(1)(a), you are a contractor and are obligated under law to provide me with copies of public records upon request under FSS. 119.0701(2)(b). I am therefore requesting: 1) All emails between you, your firm, and the city, excluding any direct communications between you and your Client Mr. Murguido, relating to your defense of Murguido. 2) Any other non-exempt/non-confidential documents, records, communications, etc, ad infinitum related to the city's decision to defend Murguido, or the defense of Murguido. 3) Explicitly cited exemptions for each redaction and/or refused record/document. 4) The number of billable hours you have charged/worked/billed to date in the defense of Murguido. The hourly billing rate you are charging the city, and the total amount to dollars charged or to be billed to the city as of the date of this email, including the time you spend reading and responding to this email and request. Your expeditious compliance with this lawful request is greatly appreciated, and will alleviate the need for the filing of additional law suits and/or complaints against you personally in this specific matter. Reducing both the amount of litigation and/or the number of litigants/defendants. Which is what we all want in the name of judicial economy right? Further, as a well-seasoned and licensed attorney, you surely are aware that these records are not exempt or confidential, and they do not fall under the provisions of attorney-client privilege either, as has been falsely claimed in the past by either you, your colleagues, and/or your clients. Although, you seemed ignorant and confused about this facet of law when we met at court, with your astounding intelligence, I'm sure after reading the provided links, you will come to the same legal conclusion as have I, and promptly provide me with the requested documents ASAP as required by law. My patience for playing games and general stupidity is wearing thin. http://www.myfloridalegal.com/ago.nsf/Opinions/BA424F66B626E94785256513005FEC8F https://scholar.google.com/scholar_case? case=696342418946563908&q=public+records+attorney+client+privilege&hl=en&as_sdt=4,10 Any attempt to stall or refusal to provide the requested records may subject you to civil and/or criminal liability under the law. As you are likely aware one civil suit has already been filed against the city for their unlawful non-compliance in a similar request filed with them. Several of my attorneys are copied, as well as media contacts, and a couple of your colleagues. My publisher is also included as failure to produce public records by the government and/or their attorneys is a very exciting and newsworthy story for our organization. Hopefully you will promptly comply with your requirements under the law. Remembering any automatic delay is a violation of the law, and as an attorney who has been duly warned any unlawful violation or unlawful failure to produce will be a knowing violation, FSS. 119.10(1)(b). https://mail.google.com/mail/u/0/?ui=2&ik=0e34f33ef3&view=pt&q=in%3Asent%20estet... 5/16/2017 Gmail - Records Request Page 2 of 36 Further, I am sure you are also aware of the legal extreme legal ramifications of concealing public records with a corrupt intent, FSS. 838.022(1)(b), and do not need to be warned against participating in any such illegal activity. I look forward to a prompt response from you, since you are now under due notice of my request and the law. Thank you and God bless. Dr. James Eric McDonough . ). https://mail.google.com/mail/u/0/?ui=2&ik=0e34f33ef3&view=pt&q=in%3Asent%20estet... 5/16/2017