Court Records
Filing # 115858207 E-Filed 10/29/2020 04:37:00 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.
PLAINTIFF'S MOTION TO DIRECT THE CLE
JEFFREY EPSTEIN GRAND JURY FILES
INVENT
?SWPlaintiff, CA HOLDINGS, LLC " Pa Beach Post') moves for an Order Directing the
Clerk of the Court to Unseal the Je n Grand Jury Files to create an inventory and provide
the Court and The Palm Beach t wi the inventory and states:
1. The Palm ost is a daily community newspaper published by Plaintiff CA
Florida Holdings, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
2. t Sharon R. Bock ("Clerk") is the duly elected Clerk and Comptroller of Palm
Beach C , orida. She is sued in her official capacity as her office is in possession of Grand Jury
documents that are the subject of this action.
3. On October 21, 2020, The Palm Beach Post dropped State Attorney Dave Aronberg
from the case pursuant to Fla. R. Civ. P. 1.250(b).
CO SA
ACT COURT TO UNSEAL THE
NVENTORY AND FOR AN
Greenberg Traung, P.A. • <01 East In Olas Boulevard. Sone 2000 • Ft. Laudardolo, Rode 33301 • Tel [Phone Redacted] • Fax [Phone Redacted] • wrivcrilaw.com
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 10/29/2020 04:37:00 PM ***
EFTA02732951
Epstein Grand Jury materials and c
7. The Palm Beach
Jury files, and that the C
Plaintiff's Motion To Direct The Clerk Of The Court
To Unseal The Jeffrey Epstein Grand Jury Files
4. By this action, The Palm Beach Post seeks access to the grand jury materials related
to the State of Florida's prosecution of the late Jeffrey Epstein to determine why Epstein received a
lenient criminal charge and a minimal work release sentence, where there was significant evidence
that Epstein was and remained a serial sexual abuser of underage girls.
5. The Palm Beach Post alleges that the First Amendment to ited States
Constitution, when read in conjunction with Fla. Stat section 925.07, and un is of this case,
compel the lowering of the cloak of grand jury secrecy to resolve th wered questions
surrounding Epstein's under and unprosecuted crimes and to inf thellfiblic whether justice was
served.
6. Based upon discovery responses provi b lerk, and conversations between the
Clerk's office and The Palm Beach Post, the d Jury files are being held by the Clerk in
a sealed container. Further, the Clerk h t pe ed and does not possess an inventory of the
4 hat materials are in its possession.
ests that the Clerk be permitted to unseal the Epstein Grand
ted to create a written inventory of the items in its possession.
8. Als m Beach Post seeks an order that permits the Clerk to provide its
inventory to T each Post and to the Court.
e purpose of this inventory is to understand what is contained in the Clerk's files so
that The Palm Beach Post will be able to more precisely advocate for the future release of specific
Epstein Grand Jury materials.
10. It is understood that the Clerk does not oppose this Motion.
2
Greenberg Traurig. V.A. • 401 East In Olas Boulevard. Suite 2000 • Ft. Lauderdale. Florida 33301 • lel [Phone Redacted] • Far [Phone Redacted] • www.gtlaw.com
EFTA02732952
Plaintiff's Motion To Direct The Clerk Of The Court
To Unseal The Jeffrey Epstein Grand Jury Files
11. To protect the privacy of victims and witnesses, The Palm Beach Post accepts that
their names and other identifying information should be redacted in the inventory. It reserves the right
to seek the release of such information at a later date.
WHEREFORE, The Palm Beach Post requests that its Motion be granted and that the Clerk
be permitted to unseal the Epstein Grand Jury files, the Clerk be directed to create amatory of the
Epstein Grant Jury materials, with redactions for identifying information, th wide a copy of
the inventory report to The Palm Beach Post and to the Court, and that nt such other and
further relief it deems just and proper.
+6s
'S fitted, Resp i 1 u
RG TRAURIG, P.A.
s for CA Florida Holdings, LLC, Publisher
Palm Beach Post
ephen 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
[Email Redacted]
smithl®gtlaw.com
[Email Redacted]
3
Greenberg Frew's. V.A. • 401 East In Ola s Boulevard. Suite 2000 • Ft. Lauderdale. Florida 33301 • lel 95.4.765.05CC • Far [Phone Redacted] • www.gtlaw.com
EFTA02732953
Plaintiff's Motion To Direct The Clerk Of The Court
To Unseal The Jeffrey Epstein Grand Jury Files
By: /s/ Michael J Grygiel
MICHAEL J GRYGIEL
(Admitted Pro Hac Vice)
54 State Si, 6th Floor
Albany, New York 12207
Telephone: ([Phone Redacted]
Facsimile: ([Phone Redacted]
[Email Redacted]
By: Is/ Nina D. Boyajian
NINA D. BOYAJIAN
(Admitted Pro Hac Vice)
1840 Century Park East
Los Angeles California
Telephone: (310) 5 -7
Facsimile: (310
bo
riveraa
E
I HEREBY CERTIFY that on thi f October, 2020, a true and correct copy of the
foregoing has been filed with the Cl ourt using the State of Florida e-filing system, which
fwill send a notice of electronic s C ) ice all parties of record herein
/s/ Stephen A. Mendelsohn
STEPHEN A. MENDELSOHN
ACTIVE 53423583v3
4
Greenberg 'Frew's. V.A. • 401 East In Ola s Boulevard. Suite 2000 • Ft. Lauderdale. Florida 33301 • lel 95.4.765.05CC • Fax [Phone Redacted] • www.gtlaw.cam
EFTA02732954