Court Records
GT GreenbergTraurig
Michael I. Grygiel
Tel: [Phone Redacted]
Fax: [Phone Redacted]
grygielml0gtlaw.com
October 9, 2019
VIA ELECTRONIC MAIL AND
UPS OVERNIGHT DELIVERY
State Attorney David Aronberg
401 North Dixie Highway
West Palm Beach, Florida 33401
Email: Oarcinbera(u sa15.state.fLus
Re: The Palm Beach Post's Public Records Law Re
Dear State Attorney Aronberg:
As you know from my colleague Steve
August 27, 2019, and September 17, 2019, our fi
the "Newspaper") in connection with its Flop
concerning your office's investigation of
The Newspaper has carefully
Attorney's October 1, 2019, respon
these materials, significant info
attention to the following, wh
the ordinary course:
1.
O S
Cf14 y Epstein
previous correspondence dated
is The Palm Beach Post ("PBP" or
lic Records Law requests for documents
sex abuser Jeffrey Epstein.
supplemental disclosures provided in the State
r Jane Musgrave. Based on. PBP's examination of
rently remains undisclosed. We specifically call your
it would be maintained by the State Attorney's office in
Case Jo -- we understand that, as a matter of policy and practice,
Florida S rosecutors routinely compile and maintain this document,
fu ions as a comprehensive ledger that keeps track of all
ative activities in a given criminal prosecution, on .a step-by step,
logical basis.
AC System -- the Newspaper advises that documents from this system,
which is also routinely utilized by Florida State Attorneys and provides a
repository for any and all investigative notes, including those of any witness
interviews, have not been provided.
These omissions are conspicuous given the high profile and public importance of the
investigation and prosecution of Jeffrey Epstein. Indeed, and with all due respect, the absence of
any investigative notes -- including those of witness interviews -- from your office's previous
disclosures raises a serious question as to its good faith compliance with its disclosure obligations
under the Florida Public Records Law. We respectfully request expedited production of the above
information, and in any event no later than COB (5:00 p.m. Eastern) on October 16, 2019. If the
Party JOINT Greenberg Traurig, LLP I Attorneys at Law
59 State Street 16th Flow I Albany.NY 1220) I T n S18.689.1403) [Phone Redacted]
CA/Aronberg-001604
ID#. J37 EV6. Joint Exhibit
DATE ADMITTED
Case No. 20t9CA•01451rt J37
FILED: PALM BEACH COUNTY, FL, ABRUZZO,trAcTitaridn 20:48 PM
EFTA02735595
•
State Attorney David Aronberg
October 9, 2019
Page 2
State Attorney's position is that the foregoing categories of documents do not exist, we respectfully
request certification to that effect from appropriate personnel in your office.
In making this request, we are mindful of and thank your office for producing responsive
documents to date. Nevertheless, I am compelled to emphasize the extreme public interest in the
information requested herein, as well as the extreme importance of the public issues it 'mplicates,
in requesting that it be produced by the above date in order to avoid litigation.
Thank you for your continuing consideration in this matter.
Very truly yours,
GREENBERG TRAURIG, LLP
Michael J.
MJG/Imd ACTIVE 46491241v1
? S r.
C) .<)*
Greenberg Traurig. LLP I Attorneys at Law
mvw.gtlaw.com
CA/Aronberg-001605
FILED: PALM BEACH COUNTY, FL, ABRUZZO, CLERIC 3/27/2023 4:20:48 PM
EFTA02735596
State Attorney David Aronberg
October 9, 2019
Page 3
bcc: Ms. Holly Baltz
Senior Editor, Investigations
The Palm Beach Post
Mr. Joel Engelhardt
Investigative Team Editor
The Palm Beach Post
Edwin M.. Esq.
Chief Litigation Counsel
GateHouse Media, LLC
Greenberg TraurIg, UP I Attorneys at Law
www.g tlawcorn
CNAronberg-001606
FILED: PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/27/2023 4:20:48 PM
EFTA02735597