Court Records
Filing II 110771414 E-Filed 07/24/2020 03:23:53 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CA FLORIDA HOLDINGS, LLC, CASE NO.: 50-2019-CA-014681-XXXX-MB Publisher of THE PALM BEACH POST, DIVISION: AG Plaintiff, v. DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida, Defendants. SI) lSrAMENDED REOUEST FOR PRO 0 OF DOCUMENTS Q SA \-1 Plaintiff, CA FLORIDA HOLDINGS tsher of THE PALM BEACH POST, by and through their undersigned counsel, by r uests that Defendant, SHARON R. BOCK, as Clerk and Comptroller of Palm B , Florida, produce all materials requested herein at the offices of the undersigned e 'thin thirty (30) days from the date hereof, or such shorter time as may be ordered b urt, pursuant to Rule 1.350, Fla. R. Civ. P. EFINITIONS AND INSTRUCTIONS 1. d Jury Materials" shall refer to all evidence, testimony, documents, transc , bills and other items used in or presented to the grand jury in and for Palm Beach County, Florida in the prosecution of Jeffrey E. Epstein, date of birth January 20, 1953, Palm Beach Circuit Court Case No. 50-2006-CF-009454 AXX. 2. "Clerk" shall refer to the Office of the Clerk and Comptroller of Palm Beach County, Florida established by the Fla. Constitution, Article V, Section 16. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 07/24/2020 03:23:53 PM *** EFTA02732819 CASE NO.: 50-2019-CA-014681-XXXX-MB Plaintiff's Amended Request for Production of Documents 3. "State Attorney" shall refer to the Office of State Attorney for Palm Beach County, Florida established by Fla. Constitution, Article V, Section 17. DOCUMENTS REOUESTED I. Copies of all logs, notations, registers, lists and entries that show the delive of Epstein Grand Jury Materials from the Clerk to the State Attorney. The specific material red need not be disclosed or produced. 2. Copies of all logs, notations, registers, lists and entries that o return of Epstein Grand Jury Materials by the State Attorney to the Clerk. The s • c m erials returned need not be disclosed or produced. 3. Copies of all communications between the erTha Ythe State Attorney concerning the storage, possession, delivery, receipt and conAtil tein Grand Jury Materials. The specific materials referenced need not be disclose pr ced. 4. Copies of all logs, notatio ybgs rs, lists and entries that show the general types of ion of the Clerk, without revealing their contents. Epstein Grand Jury Materials in 5. Copies of all logs, Sons, registers, lists and entries that show the delivery of Epstein Grand Jury Mate the ederal Bureau of Investigation. The specific materials referenced need not be disci aced. 6. f all logs, notations, registers, lists and entries that show the delivery of Epstein Grand Jury Materials to the United States Department of Justice and/or any Office of the United States Attorney. The specific materials referenced need not be disclosed or produced. 2 EFTA02732820 CASE NO.: 50-2019-CA-014681-XXXX-MB Plaintiff's Amended Request for Production of Documents 7. Copies of all subpoenas and any judicial process served upon the Clerk for production of Epstein Grand Jury Materials. 8. Copies of all communications between the Clerk and the United States Department of Justice, or the Federal Bureau of Investigation or any Offices of the United Staffs Attorney concerning Epstein Grand Jury Materials. The specific materials referenced n ti iisclosed or produced. electro CERTIFICATE OF SERVICE cI HEREBY CERTIFY that on this 24th day of July 20 opy of the foregoing has been 2nically filed with the Florida E-File Portal for e-se 4 ties of record herein. Ily submitted, *GREENBERG TRAURIG, P.A. Attorneys for CA Florida Holdings, LLC, Publisher of The Palm Beach Post Stephen A. Mendelsohn, Esq. 5100 Town Center Circle, Suite 400 Boca Raton, Florida 33486 Telephone: ([Phone Redacted] Facsimile: ([Phone Redacted] By: /s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 mendelsohnsegtlaw.com [Email Redacted] [Email Redacted] 3 EFTA02732821 CASE NO.: 50-2019-CA-014681-XXXX-MB Plaintiff's Amended Request for Production of Documents By: Michael J Grygiel AC ( S 1 nM51MW O MICHAEL J GRYGIEL (Admitted Pro Hac Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: ([Phone Redacted] Facsimile: (51tla 8) . om689-1499 grygielm@gwc By: Is/ Nina D. Bovajian 46A' NINA D. BOYAHAN (Admitted Pro Hac Vice O 00 1840 Century Park Eat Los Angeles Califomi Telephone: (310 -7 Facsimile: (31 800 bo liann 4 EFTA02732822