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Extracted Text #

his cu. job, has returned Si 10,000 to him becauethe 
Palm Beach scandal, the New York Daily News has 
reported. 
Rather than file charges, the state attorney's office 
presented the case to a county grand jury. The panel 
indicted Epstein last week on a single, less serious charge of 
felony solicitation of prostitution. 
The case raised eyebrows because the state attorney's office 
rarely, if ever, kicks such charges to a grand jury. And it 
increases the.difficulty of prosecuting child sex abuse cases 
especially when the defendant is enormously wealthy 
can hire high-priced, top -tier lawyers. 
At least one of Epstein's alleged victims told police 12w 
she was underage when the two of them got naked for 
massages and sexual activity. She was t6 years old at the 
time and said Epstein asked her questions about her high 
school, according to police re 
A girl who said she met Epst when she was IS said he 
/ told her if she told an hat happened at his house, 
bad things could , the police reports state. 
Epstein's youhgest alleged victim was 14 when she says she 
gave hima-massage that included some sexual activity. She 
ow 16. The girl's father says he doesn't know whether 
old Epstein her age. 
y daughter has kept a lot of what happened from me 
because of sheer embarrassment," he said. "But she very 
much looked 14. Any prudent man would have had second 
thoughts about that." 
Defense attorney Jack Goldberger maintains that not only 
did Epstein pass a polygraph test showing he did not know 
the girls were minors, but their stories weren't credible. 
The state attorney's office also implied that their credibility 
was an issue when it decided not to charge Epstein directly, 
but instead give the case to the grand jury. 
CA/Aropirrat0Q1A2qa r -1,m BEACH COUNTY, FL, ABRUZZO, CLERK. 3/23/2023 1:49:29 PM 
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"A prilitor has to look at it in a much broader fact,' a 
state attorney's spokesman said last week. 
714ff V int 
IIIMMELLIGEblI pv9r 
Epstein hired Harvard law Professor Al tz 
when he became aware he was under on, and 
Dershowitz gave prosecutors info a n at some of the 
alleged victims had spoke of coh land marijuana on 
a popular Web site, accor4g to m Beach police 
report. 
Prosecutors alder two things in deciding 
whether to arge ebody with sex-related offenses 
against minor ether there is sufficient evidence and 
whethe is a public interest in doing so, Delde said. 
o teens are in a sexual relationship and: the boy turns 
before the girl, he could be charged with a sex crime if 
e sex continues. There would be no public interestin 
pursuing that, Dekle said. 
1 
1 
But where there is a large gap in ages - and especially in 
cases of teachers with students - there is a public interest in 
prosecuting, he said. Likewise if the accused has a track 
record of sex with minors. 
CA/Arople#01.29.4. PLUM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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Still teis a "universal: constant" in prosecuting, 
cases, Dekle said. Men who exploit underage children for 
sex often carefully choose their victims in ways that will 
minimize the risk to them, he said. 
Victims usually are from a lower social status, and they may 
suffer from psychological problems, Dekle said. 
"Lou of child sexual abuse victims have been victimized by 
multiple people over a period of time. Then the act of abuse 
produces behavior in the victims that further damages their 
credibility." Examples include promiscuous behavior and 
drug abuse. 
O Some of the alleged victims.in the Epstein case re ned o 
his home multiple times for the massage secs` e 
S200 to S300 he typically paid them per. •wotild 
be a definite problem for the ptosecu ettyResch, 
,..,k alm.Beach 
\ 
who prosecuted crimes against c 
County for five years and no rivate practice in Lake wi( ,
Worth. 
"The victim becom 
'But she's a vi 
Most men tli 
pathetic to a jury, Resch said, 
eless. She's skid? 
with sex crimes against minors loOk 
norm e said. A jury expecting to see a monster 
irsci 
f the defendant in a trial, Dekle said. fit . o 
. And the victims' ages work against them and in 
OAe, a child and ai adult tell different stories and both swear 
they're telling the truth, adult jurors are more likely to 
'believe the adtilt, Dekle said. 
!You have all these things working against. you in a child 
set abuse case. Prosecutors normally try to be very careful 
in filing those cases because they know what they're getting 
into. There is no such thing as an iron-clad child sexual 
abuse case." 
CA/Aronbera, 012Q5. I i .UPPALfV1 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735851

TeePalm Beach Poet REAL NEWS SIART$ HIRE 
Epstein camp calls female accusers 
bars Posted Aug 8, 2006 at 12:111 AM 
Updated Oct 3, 2019 at 3:35PM 
(EDITOR'S NOTE: This story originally published in The 
Paint Beach Post on Aug. 8, 2006) 
Attorneys and publicists for Palm Beach financierie 
Epstein went on the offensive Monday, contendin 
teenage girls who have accused Epstein of sexual 
shenanigans at his waterfront home ire liar ying 
that the Palm Beach Police.Department ' 
"There never was any sex betwee 
c;;1underage women," his lead a 11  a • Goldberger, n\nfrom Idaho where he was tio ' g with his family. 
and any 
said 
Epsteindid have): n come to his house to give 
him massages, said. 14n Epstein absolutely 
insisted any. dy w came: to.his house be over the age of 
18. How he v d that, I don't know. The question is, did 
anythin occur. The law was not violated here, 
ad no explanation as to why Epstein would pay girls or 
oinen with no massage training - as the alleged victims 
d was the case - $200 to $300 for their visits. "The 
credibility of these witnesses has been seriously 
questioned,' Goldberger said. 
Epstein, 53, was indicted by a county grand jury last month 
on a charge of felony solicitation of prostitution. After at: 
11;inonth investigation that included.sifting through 
Epstein's trash and surveilling his home, Palm Beach police 
concluded there was enough evidence to charge him with 
sexual activity with minors. When the-grand jury indicted 
CA/ArTlierViek BEACH COUNTY, FL, III ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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Epstein, the less serious charge, Police Chief Mi. 
Reiter referred the case to the FBI to determine whether 
there were federal law violations. 
After a spate of stories about the case last week, New York 
publicist Dan Klores - whose client list has included Paris 
Hilton and Jennifer - said on Saturday that Epstein's 
camp was ready "to get their story out." 
They did that Monday via Goldberger and a Los Angeles 
publicist for Miami criminal defense attorney Roy Black, 
who also has represented. Epstein in the case. 
"We just think there has been a distorted view of thi c 
in the media presented by the Palm Beach police," 
Goldberger said. 
Reiter has consistently declined to co ect case 
and did not respond to a request < fo t Monday. Ac,
The implication that State Attorney Barry Krischer was 
easy on Epstein by presenting the case to a grand jury 
rather than filing charges directly against him is wrong, 
Goldberger said. 
CA/Aropke90 9-/%12971L,wi BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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The *Beach Police Department was "happy an® 
ecstatic" that the panel was going to review the evidence. 'I 
think what happened is they weren't happy with the result. 
They decided to use the press to embarrass Mr. Epstein." 
But records show that Reiter wrote Krischer on May 1 -
well before the case went to the grand jury - suggesting that 
Krischer "consider if good and sufficient reason exists to 
require your disqualification from the prosecution of these 
cases." 
Rather than flat-out decline to charge Epstein, Krischer 
referred the case to the grand jury to "appease" the chief,—
Goldberger said. 
A state attorney's spokesman would say only thast,thenffice 
refers cases to the grand jury when there su with the 
viability of the evidence or witnesses' 
Both the state attorney and dit jui5r concluded there 
was not sufficient evidence4kat s in had sex with 
minors, according to Goldberger. "It was just a childish 
performance by thePthltni3each Police Department," 
Goldberger said. ../L
The defense a'ttottiey said one of the alleged victims who 
claimed the was a minor was in fact over the age of 181 
ther alleged victim who was subpoenaed to testify to 
rand jury failed to do so. Epstein's accusers, he added, 
ve histories of drug abuse and thefts. "These women are 
Jars. We've established that." 
But why would they all invent their stories about meeting. 
Epstein for sexual massages? 
"I don't have an answer as CO what was the motivation for 
these women to come forward and make these allegations," 
Goldberger said. 
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cAffir°14130993 ;a1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
.•;
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Reiter focus of fire in Epstein case 
Clipped By.
reitoim 
Sal, Apr 21 20;7 
Copyright 012019 Nevespapers.com. All Rigid,. Reserved. 
NgfaSiPwr 
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CA/Aroitepb512al. NUM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735855

4  Palm Beach Post REAL NEWS STARTS HERE 
Delays in Epstein case unusual, 
lawyers say Posted Mar 13, 2007 at 12:01 AM 
Updated Oct 3, 2019 at 3:48 PM 
(EDITORS NOTE: This story originally published in The Palm 
Beach Post March 13, 2007) 
AS,A federal probe or a plea deal could explain the wait in
Palm Beacher's solicitation case. 
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Nearly eight months after Palm Beach rycoolUtfr c 1 
Epstein was charged with felony solicitation of plostitution, 1 , 
there has been no discernible progress in his case. No 1 s 
witnesses deposed. No trial date set. Nothiii, save for 1 
routine court hearings reset without explanation.
i 
`Usually that would be unusual," said criminal defense 1 
attorney Glenn Mitchell, who has no involvement in the i 1 
i case. i / 1 
"As a general tgleyit would be unusual for nothing to have i 
happened," ag. Michael Dutko, a criminal defense 
a rneyin Fort Lauderdale. He represents 
2
4o 
.of Palm Beach, potentially a key witness in the 
() se
+ A routine hearing for Epstein was pulled from the court 
docket last week and reset for May 16. The delays and 
inaction could be due to a potential federal probe of Epstein 
or because a plea deal is in the works, attorneys say. 
Unusual is the word that best describes everything about 
the case against Epstein, 54, an enigmatic money manager 
in New York City who counts Bill Clinton and Donald 
Trump among his friends. 
CA/AroilieL,c01 A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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"High"'usual" is how Palm Beach Police Chief Ape! 
Reiter described State. Attorney Barry Krischer's handling 
of the case in a bluntly critical letter to Krischer last year 
before Epstein was indicted. 
Reiter referred the matter to the FBI to determine whether 
any federal laws had been violated. Epstein's allies 
countered by attacking the chief personally and 
professionally. 
Reiter's department investigated Epstein for 11 months. 
Police sifted repeatedly through his trash and conducted 
surveillance on his five-bedroom, 7 1/2 -bath, 7,234-sq 
foot home on the Intracoastal Waterway. 
Police said Epstein paid women and girls as ctO 
give him erotic massages at his home. 1,Po) ' t,ht there 
was probable cause to charge him withickwf sex acts 
with a minor and lewd and lascivious nwlestation. 
Epstein responded by hiring/1%g of lawyers. One of 
them, Harvard law pro 
provided the state 
alcohol and 
they were wi 
for and author Alan Dershowitz, 
ffice with information about 
by some of the girls who said 
ProsecV en referred the case to the grand jury rather 
t file arges directly against Epstein. S e
st m'S attorneys deny he had sex with underage girls. 
e lawyers say the girls' stories are not credible. But if the 
court file is any indicator, they've made no effort to depose 
the girls. 
Neither prosecutors nor defense attorneys have sought to 
question , said Dutko, her attorney. She recruited 
teenage girls to visit Epstein for massages and sexual 
activity, Palm Beach police said, and presumably would be a 
key witness. 
s; 
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rnr?Qt L
aQ1 tuft) P M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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Epsteettorney Jack Goldberger did not return 
messages. 
A source close to the case suggested it is languishing 
pending a decision by the FBI on whether to refer it to 
federal prosecutors. 
"We still have a pending case," FBI spokeswoman Judy 
Orihuela said Monday. 
State Attorney Krischer did not return a call for comment. 
His spokesman, Mike Edmondson, declined to say whether 
federal investigators are delaying the Epstein case. But, 
added, "if another agency is looking at something, we 
wouldn't want to step on their toes." 
Attorneys say inertia in a criminal case oft to a 
pending plea deal. 
"It would not surprise me if some‘ugS lat appened that's 
not reflected in the court "' ' Disko, such as an 
agreement that will be ford ater. 
Defense attorney diner said defense attorneys 
sometimes pu conducting discovery -- deposing 
witnesses, r est g documents and the like -- because 
doings tea more work for harried prosecutors who 
may bee e angry and not offer a plea deal. 
es defense lawyers, knowing that, will try and do 
covery without taking depositions," said. Shiner, a former 
prosecutor for 13 years. 
Instead, they may conduct a below-the -radar probe such as 
having a private investigator check out leads, he said. 
Shiner and others say a plea deal for Epstein probably 
would result in pretrial intervention, in which a defendant 
may be ordered to undergo a psychological evaluation, 
counseling or other conditions in return for dropping the 
charge. 
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CAIAIDPItrirnial BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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Edmcillim, spokesman for State Attorney Krischeid 
there is no plea offer and no request for the prosecution to 
show its cards. 
"To my knowledge, it's never happened before on a filed 
case," he said. 
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Ciar0pira01113Cia ALM BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735859

• • 252 / 278 - Thursday, October 18, 2007 
Edition: FINAL 
Section:. LOCAL 
Page: 5B 
Source: The Associated Press 
Illustration:, PHOTO (B&W) 
Memo: Ran all editions. 
Dateline: NEW YORK 
WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD. SEX WHEN Sfl WAS 16 
A billionaire investor, already facing jail in Palm Beach County on charges of erage 
prostitutes, is being sued by a young woman who says he had sex with her w IS and had 
sought his help becoming a model, 
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, say tna2Aied7effrey Epstein had 
the teen perform a. sex act When she brought photographs of herself for to eview in his Upper 
East Side mansion sometime in 2000. 
Epstein, 54, a money manager, told the teen he managed finan i ctoria's Secret and "could get 
you into the catalog" jfshe were "nice" to him, court papers 1  pers say, being "nice" 
included massages and other favors. 
When the girl told Epstein, "I am 16 years old and just del," he replied, "Don't worry, l 
Went tell anybody;" court papers say. 
Epstein, said by London's Mail on Sunday to be d of England's Prince Andrew, has been 
indicted in Palm Beach on charges of soliciting prostitutes. That case is pending. 
The girl visited Epstein "several times ove I months and engaged in bizarre and unnatural 
sex acts" while she was a minor, the law 
Epstein "repeatedly requested that ( rn with her 14-, 1$-, and 10-year-old girlfriends, 
stating, Conte by with your frien next time. Don't bring Sherrie (a mutual friend in her 
40s). I love girls your age.' " 
The young woman, now 23, kept rZM a tg to Epstein because she has "mental issues," said her 
lawyer, William J. Unroch. fused to elaborate, but court papers say she was "disabled as a result 
of severe mental dis e and of ct:" 
Epstein's lawyer in Yo Gerald Lefeourt, said, "The girl has admitted she is insane, but she can 
read a tiewspape ize the word 'rich.'" 
Lefcourt also sta ute of limitations has expired forthe woman's case criminally and civilly, 
and will a ly be dismissed. 
He refus ment on Epstein's Florida charges. 
Meanwhile, h, 57, also acknowledged. hat his.client was living with him and was at the center 
of a $10 million lawsuit he filed last year against a neighbor who said he was having sex, with 
underage girls. That case is pending. 
"What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said 
Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve 
the case out of court.
CA/Arctine feiYel BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2021 1:49:29 PM 
EFTA02735860

it  Palm Beach Ptst REAL NEWS S1ARTS HERE 
Palm Bucher pleads in sex case Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 3, 2019 at 1:47 PM 
(EDITORS NOTE; This story originally published in The 
Palm Beach Post on July 1, 2000 
Jeffrey Epstein will serve 1 1/2 years on teen solicitation 
charges. 
He lives in a Palm Beach waterfront mansion and 
company with the likes of President Clinton, Prin 
VAndrew and Donald Trump, but investme er Jeffrey 
Epstein will call the Palm Beach Coun for the 
/C 4'a elony
next 18: months. 
Epstein, 55, pleaded guilty solicitation of 
prostitution and procu " under the age of 18 for 
prostittgion. After se onths in lail, :he will be 
under house air r. And he will have a lifelong 
obligation to a sex offender. He must submit to 
an HIV test 48 hours, with the results being 
provid *his victims or their parents. ti, vir,
km o the plea deal, federal investigators agreed to drop 
e et riveatigatiOn of Epstein, which they had taken to a 
rand jury; two law. enforcement sources said. 
Epstein was indicted two years ago after an 11-month 
investigation by Palm Beach police. They received a 
complaint from a relative of a 14-year-old girl who had 
given Epstein a naked massage at his five-bedroom, 7;234-
square-foot, 88.5 million Intracoastal home. 
Police concluded that there were several other girls brought 
in 2004 and 200S to an upstairs room at the home for 
similar massages and sexual touching. 
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CA/Aroften 5911.a  30.5. BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735861

1 The Aliment charged Epstein only with felony 
solicitation of prostitution. The state attorney's office later 
added the charge of procuring underage girls for that 
purpose. 
Prosecutor Lanna Belohlavek said of the plea: 'I took into 
consideration the length the trial would have been and 
witnesses having to testify" about sometimes embarrassing 
incidents. 
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Epstein may have made a serious mistake soon after he was  i Attic 
charged. He rejected an offer to plead guilty to one count o 
aggravated assault with intent to commit a felony, , 1 ; t 
according to police documents. He would have gotten- i 
years' probation, had no criminal record and not b el ) I 
registered sex offender, the documents indi 
Epstein arrived in court Monday wit 5 ree 
c 
s
He wore a blue blazer, e . ' ,, blue jeans and 
iesii4„ I I A4"
and gray sneakers. Afte C 't rludge Deborah Dale 
Pucillo accepted the plea, vasTtgerprinted. Epstein i i 
then removed his bla Ihandcuffed for the trip to ; jail while his atto to shield him from I 
photographe 
reen 
=Ile Ic d
When he eve y is released to house arrest, E stein will p 
have to rve a 10 p.m. to 6 a.m. curfew, have no 
supentsed contact with anyone younger than 18 and 
r own nor possess pornographic or sexual materials 
at are relevant to your deviant behavior," the judge said. 
Epstein will be allowed to leave home for work. The New 
York-based money manager told the judge he has formed 
the not-for-profit Florida Science Foundation to finance 
scientific research. I'm there every day," Epstein said. 
The foundation was incorporated in November. Epstein 
said he already has awarded money to Harvard and MIT. 
QCA/ArorlieR 599t36. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735862

Whets released from jail, there is a chance thattein 
will be forced to move. Sex offenders are not allowed to live 
within 1,000 feet of a school, park or other areas where 
children may gather. No determination has been made as to 
whether Epstein's home complies, but attorneys said it 
likely does. 
Sex offenders also typically must attend counseling sessions. 
Belohlavek said that was waived for Epstein because his 
eke 
private psychiatrist is working with him. The judge was 
skeptical but agreed to it.
Epstein's legal woes don't end with Monday's plea. The
are four pending federal civil lawsuits and one in state-
related to his behavior. At least one woman has suelC511i in 
New York, where he owns a 51,000-square- anhattan 51,000-square-
mansion. 
"It's validation of what we're sayi vil cases: said 
Miami attorney Jeffrey Herm tepresents the alleged 
victims in the federal lawsa Palm Beach attorney 
Ted Leopold represents-one a ged victim in a civil suit in 
state court. He sa e gtiOates amending that lawsuit to 
add "a few ot ikc t as well. LIn the crimin , police went so far as to scour Epstein's 
trash a nduct surveillance at Palm Beach International 
c Ton i' here they watched for his private jet so they 
amo Id know when he was in town. They concluded that 
paid girls $200 to $300 each after the massage 
A sessions. 
"I'm like a Heidi Fleiss," now 22, told police 
about her efforts in recruiting girls for Epstein. 
There was probable cause to charge Epstein with unlawful 
sex acts with a minor and lewd and lascivious molestation, 
police concluded. 
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CA/Arorken0M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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The sliknorneyl office said questions aboutthee 
credibility led it to take the unprecedented.step of 
presenting the evidence against Epstein to a grand jury, 
rather than directly charging him.. 
Palm Beach Police Chief Michael Reiterwas furious with 
State Attorney Barry Krischert saying in a May 2006 letter 
that. the prosecutor should disqualify himself.. continue to 
find your office's treatment of these cases highly unusual; 
he:Wrote. He.then asked for and got a federal investigation. 
IA addition to mansions in Palm. Beach ttan, 
Epstein owns homes in New Mexico rgin Islands; 
He's a frequent contributor to De it arty candidates: 
He also donated $30 million rd in 2003. 
Epstein hired a phalanx of high-priced lawyers - including A' 
Harvard :law professor and author Alan Dershowitx -
public relations people who questioned Reiter% co 
and the victims' truthfulness. C 0) 
Former New York Gov io pitxer returned a $50,000 
campaign contribu" pstein after his indictment, 
then resigned ring his own sex scandal. And the 
same Palm ach P ce Department that vigorously 
investi ated n returned his 590,000 donation forthe 
pur rearms.
writer Eliot Kleiriberg and former stiff researcher 
elle Quigley contributed to chi; gory. 
CA/Aropliefib, A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735864

• 
Tte Palm 13e REAL NEWS STARTS NME 
Jeffrey Epstein: Scientist, 
stuntman, `sex slave' visit jailed 
tYc0011 By LARRY _% Palm Beach Post Staff Writer 
Posted Aug 13, 2008 at 12:01 AM 
Updated Jul 16, 2019 at 4:54 PM 
Tycoon Jeffrey Epstein mingled with an eclectic mix of 
people, including beautiful young women, before he gq 
into trouble for paying teenage girls to give him se 
massages at his Palm Beath mansion: 
Not muth has changed; even though he es is a 
.dorm at the Palm Beach County Sfie$ e s I7-acre, 
%7 -bed stockade near the fairg 
S tDuring his first month.of fin nt, Epstein was visited 
by the female assistan o, g told police, had escorted 
them to the room on where they gave him 
naked massagC 
Also trekking e jail was a young woman whom Epstein 
purpo scribed as his Yugoslavian sex slave. 
wealthy financier antl science wonk also has been. 
sited by an expert on artificial intelligence, as well as a 
an who is a mixed martial arts aficionado and sometime 
movie stuntman. 
The only other people to visit him at the jail, according to 
records, are a Island man and an individual who 
listed' Epstein's Palm Beach address as his own. 
Epstein, 55, pleaded guilty on June 30 to two prostitution -
related charges and was sentenced to 18 months in jail, 
followed by a year of house arrest. Epstein paid teenage 
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girls Alio 8300.in 2004 and 2005 for massages 11) home that sometimes included sexual touching, Palm Beach 
police said. 
His jail visitors in July included; 
.29, who some of the teen masseuses said 
phoned them when Epstein was in town and escorted them 
upon their arrival at his Palm BeaCh waterfront home to an 
upstairs yowl, where she prepared the massage table and 
provided the oils for their encounters with him. 
visitor's log. -.lists a Manhattan home address. O 
Reached by telephone, she declined to discuss Epst
ACt., 
visited Epstein three times in July, according to a jail 
- Nadia MartinIcOvai 23, whose family in Yu 
Epstein paid money to so that he could b the 
United States to be his 'sex slave: tw. : :'rls told 
polite. One girl told police that E cted 
and het to kiss a - teat while he' itched It t
and masturbated. Motile 'd s S s ngaged in sex with 
at Epstei arcinkova visited Epstein i i 
in jail four times he lists her address as on the. 
Upper East si attan, not far from Epstein's 
enormous a 
I 
- Roger Schtink, 62, founder of the Institute for Learning, 
ieticest Northwestern University and an expert on 
'al intelligence, paid one visit to Epstein. Schank has 
ritten numerous books on that subjectand has a doctorate 
degree front Yale University in linguistics: He was one of 19 
people who applied to be president of Florida Atlantic 
University in 2001 He became 'chief learning officer at the 
online Trump University in 2005. Schank listed his address 
as being in Stuart, and records show he also owns a home 
in Lake Worth. 
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Epstees financed a number of scientists over theirs, 
including Nobel Prizewinners.. He gave. $30 million to 
Harvard University in 2003. In November, he formed the 
not-for-profit Florida Science Foundation, which he said 
finances scientific research. 
- Igor Zinoviev, a Russian mixed martial arts fighter, who 
coaches a Chicago team in the International Fight League. 
He also has worked as a persOnal trainer, celebrity 
bodyguard and movie stuntman, according to the leagues 
Web site. The New jersey resident visited Epstein seven 
times in July. 
Zinoviev, Schank and 
comment. 
Could not be 
Staff researcher Niels Heimeriks contrib s story. 
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-ern Beach Daily News 
Billionaire sex offender leaves jail 
six days a week for work Posted Jul 1; 2008 at 12:01 AM 
Updated Oct 4, 2019 at 927 AM 
Palm Beach. billionaire Jeffrey Epstein, who's serving 18 
months in jail for soliciting an underage girl for 
prostitution, is allowed to leave the Palm Beach County 
Stockade six days a week on a work-release program. 
Teri Barbera, spokeswoman for the Palm Beach 
Sheriffs Office, confirmed that Epstein, 55, 
work -release program since Oct. 10. 
lie works six days ameelc Friday ednesday 10 
a.m. to 10 pm.; Barbera said (He) works at his 
local West Pains BeaCh o red on air acute GPS 
system (he wears an e b t).. Mr. Epstein hires a 
permh deputy, for his own security at his 
workplace duri he is out 
Miami attorn 0y:1-lett:Ian tepteSerits six young 
women ye sued Epstein, claiming he sexually abused 
t)em at s Palm Eteadh home when they were minors. 
Clogram from the U.S. Attorney's Office within the past 
e an said he received a letter about the work-release 
+ few days. But Herman says Epstein had been out on work-
release for several weeks before the notification. 
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'My clients expressed shock and disappointment," Herman 
said. "I find it incredible that he's on work -release in the 
community and my.clients aren't notified of this and we get 
this letter weeks after the fact? 1 
Jack Goldberger, Epstein's criminal attorney, said the 
• 
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arrant/int is not unusual. • lie goes to work every single day and goes back to jail at • 
night, just like everybody else (in the program),' 
Goldberger said. 
Epstein pleaded guilty June 30 to two felony counts: 
soliciting prostitution and procuring a person under 18 for 
prostitution. As part of the plea agreement, Epstein must 
serve one year of house arrest and register as a lifelong sex 
offender. 
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It Pain REAL Maga 101. 
Women want. Epstein sex pleaded 
unsealed Posted Jul 1, 2008 at 12:01 AM 
Updated Oct Z 2019 at 213 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post June 10, 2(09) 
Their attorneys will ask a judge to open Jeffrey.Epstein' "S rO 
records. 
When wealthy money manager Jeffrey Epstei f
Beach pleaded guilty last year to produrin 
prostitution, his case detoured aroun; state rules 
regarding the sealing of court d 
At a plea conference on the es, a judge, a defense 
lawyer and a prosecutor h T  at the bench and decided 
that a deal Epstein with federal prosecutors to 
avoid charges s aled) according to a transcript of 
the hearing. 
And so r 
<IS t,Flori a rules ofjudicial administration, as well as rules 
Of +
Palm Beach County court system, require public 
deification that a court document has been or will be 
sealed, meaning kept from public view. i.e rules also 
require a judge to find a significant reason to seal, such as 
protecting a trade secret Or a compelling government 
interest.. 
Yet no notification pr reason occurred in Epstein's case, 
according to court records: 
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Epstelewn attorneys, in federal filings, have ref$ to 
his confidential deferred prosecution agreement with the 
U.S. attorney's office, struck in September 2007, as 
"unprecedented" and "highly unusual." And it was "a 
significant inducement" for Epstein to accept the state's 
deal, observed the state judge who accepted his plea, 
County Judge Deborah Dale Pucillo. 
Epstein now faces at least a dozen civil lawsuits in federal 
and state courts filed by young women who said they had 
sex with him and now are seeking damages. 
Attorneys for some of those women want his agreeme 
with, federal prosecutors unsealed and will ask Cir 
Jeffrey Colbath to do so today. 
"It is against public policy for these docu,k e have 
been sealed and hidden from public scruti4r. A a member 
of the public, E.W. has a right to ve these documents tl .,
unsealed: u former Cir ' u e Bill Berger, now in cin w
er‘ ,,private practice and repre • 'ng e of the women. 
The Palm Beach Post 41sdPwill ask Colbath to unseal the 
agreement. P st attorney Deanna Shullman will argue that 
the public has • ht to know the specifics of Epstein's deal. 
licr *Ac ordin _to various media accounts, Epstein moved in 
es that included President Clinton, Donald Trump and 
0 'n e Andrew. "International Moneyman of Mystery," 
4 dared a 2002 New York magazine profile of Epstein„ 
Epstein, 56, is in the Palm Beach County Stockade, serving 
an 18-month sentence after pleading guilty nearly a year 
ago to felony solicitation of prostitution and procuring 
teenagers for prostitution. 
He is allowed out from 7 a.m. to II p.m., escorted by a 
deputy, said Palm Beach County Sheriffs Office 
spokeswoman Ted Barbera. 
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The Florida Supreme Co as 2ipressed "serious concern" 
and launched an all-outinqui into sealing procedures 
across the state following media reports in 2006 of entire 
cases being sealed aiscridisappearing from court records. ni
"The public's c titutional right of access to court records 
must remaih inviolate, and this court is fully committed to 
eguarding this right, justices wrote in their final report. 
office on Tuesday referred any questions to 
Goldberger, who declined to comment. Pucillo also has 
declined to comment. 
Duritealm Beach Police Department investigaefive 
victims and 17 witnesses gave statements. They told of 
young women brought by his assistants to Epstein's 
mansion on El Brillo Way for massages and sexual activity, 
and then being paid afterward. 
At Epstein's plea conference last year, his attorney, Jack 
Goldberger, and then-Assistant State Attorney Lanna 
Belohlavek approached Pucillo in a sidebar conference. 
Pucillo, who had left the bench nine years earlier, was 
Filling in temporarily as a senior judge. 
SAccording to a transcript, Goldberger told Pucillo that  ' -- 
Epstein had entered a confidential agreement withithe U.S._ 
) 1 s 
i 
attorney's office in which federal prosecutors brokered not I 9
pursuing charges against him if he pleadedgnifi Qn state
s court. Pucillo then said she wanted a se f the44 5e. 1 
agreement filed in his case, and Gold ncurred that ; 
he wanted it sealed. Belohlavek e d off on it. I 
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0 The Palm Beach Post REAL NEWS STARTS HERE 
Epstein secret pact with: Feds 
reveals "highly unusual" terms Posted Jun 10, 2009 at 12:01 AM 
Updated Oct 4, 2019 at 9:23 AM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on September 19, 2009) 
A secret non-prosecution agreement multimillionaire 
financier Jeffrey Epstein struck with federal prosecutors is 
being called "highly unusual" by former federal prosecutors 
and downright outrageous by attorneys nogg rEpgesenting 
young women who serviced him. 
St'The deal reveals that the FBI and h . onney's Office 
investigated him for several f rimes, including 
engaging minors in corn ial . he crimes are 
punishable by anywh years to life in prison. 
But federal pro rbicked down and agreed to recall
grand jury subpoena if Epstein pleaded guilty to 
prostitution -related felonies in state court, which he 
ultimatebrdid. He received an 18-month jail sentence, of 
ch he served 13 months. 
Ohe .S. Attorney's Office also agreed not to charge any of 
A pstein's possible co-conspirators: a 
M, Lesley Groff and 
The deal was negotiated in part by heavyweight New York 
criminal defense attorney Gerald Lefcourt. 
Unsealed on Friday after attorneys for some of Epstein's 
victims and The Palm Beach Post sought its release, it offers 
the first public look at the deal Epstein's high-powered legal 
counsel brokered on his behalf. 
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MarkSson of Stuart, a former federal prosecuti41) 
described the disparity in potential sentences as unusual, 
but even more so a provision on attorney payment. 
The first draft of the agreement in September 2007 
required that Epstein pay an attorney -- tapped by the U.S. 
Attorney's Office and approved by Epstein -- to represent 
some of the victims. That attorney is prominent Miami 
lawyer Bob Josefsberg. 
But an addendum to the agreement signed the following 
fSmonth struck Epstein's duty to pay Josefsberg if he and the 
victims did not accept settlements -- capped at $150,000 --
and instead pursued lawsuits. 
said it appears the government wasstgc 
balance the lesser sentence for Epstein with ecolring 
$150,000 for each. victim. "I've never, anything 
like that in my life: he said. "It's ' h ual."„‘„ 
The deal does not say whethAty ctims were contacted 
or consulted before the eal w'y made. 
/'• Attorney Brad Edwards Fort Lauderdale, who represents 
three of the young women, believes that none of the 30 to 
40 woman identified as victims in the federal investigation 
were told ahead of time. said his clients received 
1 rs &bin the U.S. Attorney's Office months after the deal 
w signed, assuring them Epstein would be prosecuted. 
O 
"Never consulting the victims is probably the most 
outrageous aspect of it," said. "It taught them that 
someone with money can buy his way out of anything. It's 
outrageous and embarrassing for United States Attorney's 
Office and the State Attorney's Office." 
Epstein now faces many civil lawsuits filed by the women, 
who are represented by a variety of attorneys. In many, the 
allegations are the same: that Epstein had a predilection for 
teenage girls, identified poor, vulnerable ones and used 
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otherlig women to lure them to his Palm Beal. 
mansion. They walked away with between $200 and 
S1O00. 
Fortner. Circuit Judge Bill.Retger,.also representing victims, 
called. the agreement a 'sweetheart deal: 
"Why was it so important for the government to make this 
deal?" Berger. asked rhetorically. 'We have not yet had an 
honest explanation by anypublic official as to why it was 
made and why the violins were sold down the river: 
Former federal prosecutor Ryon McCabe described the 
agreement as 'very unorthodox:" Such agreements, 
are usually reserved for corporations, not individ 
"Ifs very, very rare. I've never seen or he? 
procedure that was setup here," said 
involvement in any Epstein litiga 
"He's• essentially avoiding fe rajecution because he 
can afford to pay that y e to help those victims 
review their cases..., n has: no money, he couldn't 
be able to strike this and avoid federal 
prosecution. 
The b oom deal with federal prosecutors is all the more 
ineresn light of the legal powerhouses who have 
or Epstein, including Harvard profetsor Alan 
Oe 
e owitz and Bill Clinton investigator Kenneth Starr. 
+ fcourt is a past president of the National Association of 
CriMinal Defense Lawyers.. 
Epstein's local defense attorpey,fadt Goldberger, issued a 
statement Friday saying he had fought the release of the 
sealed agreement to protect the third parries named there. 
"Mr. Epstein has fully abided by all of its terms and 
conditions. Re is looking forward to putting this difficult 
period in his life behind him. He is continuing his long-
standing history of science philanthropy: 
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The litigation triggered tensions between porn!!l 
prosecutors, with then-Palm Beach thief Michael Reiter 
saying in a May 2006 letter to then-State Attorney Barry 
Krischer that the chief prosecutor should disqualify hiniself.-
1 continue to find your office's treatment of these cases 
highly unusual;" Reiter wrote. He then asked for and got 
the federal investigation that ended in the sealed deal. 
'The Jeffrey Epttein matter was an eXperience of what a 
many-million-dollar defense can accomplish: Reiter told 
the Palm Beach Daily News upon his retirement. 
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• 
187/ 278 - Wednesday, January 27,2010 
Edition: FINAL 
Section: LOCAL cfc BUSINESS 
Page: 3B 
Source: By JANE MUSGRAVE Palm Beach Post Staff Writer 
Dateline: WEST PALM BEACH 
JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS 
In a decision that could spark a constitutional showdown over privacy rights ge 
Tuesday gave lawyers representing multimillionaire sex.offender Jeffrey the right to 
subpoena abortion records from women who are seeking millions in ap a the part-
time Palm Beach resident. 
Palm Beach County Circuit Judge Donald Hafele said the records c uld h 1p Epstein rebut 
the women's claims that they suffered psychological ills after b ing o give him 
sexually-charged massages at his Palm Beach mansion whet vete as young as 14. 
Hafele told'Epstein's attorneys they cpuldn't2o on a fish' e ion. The medical records, 
he said,. can't be sought until the women ate asked wh aye ever had an abortion,. 
howmany and where. Further, he said, the records. made public and might not 
be admissible during trial. 
But, be said, since the women claim Epstein, responsible for their emotional 
distress, his attorneys can explore the. imp of o events. Medical records, Hafele said, 
are a better source of information than a, rso memory. 
Attorney Louis Silver, who tepttathnithe Presi aide( Weaten'allealth Centers a West Patin 
Beach clinic where abortions are rmV, warned Hattie that he was stepping on shaky 
constitutional grounds. 
"These records are protected stitutional right of privacy," he said, referring to the 
Florida Constitution. 
After the hearing, Sily aid an appeal won't be necessary until Epstein attorneys seek the 
records. 
In another ruli Vedne y, Hafele also said that videos from depositions in the state cases 
can't be tel out a court order. The ruling came after.Epstein attorney.Robert Critton 
complain eo of Epstein being asked. whether he: had an "egg-shaped" penis 
became .tom sensation. It fitst appeared. On The: Palm Beach Post Web site. 
Critt ttorney Spencer Kuvin for releasing it. Kuvin said it was public record. 
The ci began mounting after Epstein agreed to plead guilty to two state charges: 
procu i a minor for prostitution and soliciting prostitution: He served 13 months of an 18-
month sentence; As part of 'the deal brokered with federal prosecutors, he agreed not to 
contest the accusations in the civil lawsuits. Henan argue the women don't deserve the 
millions they are seeking. 
—[Email Redacted] 
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Tee Palm Beach. Post REAL NEWS STARTS HERE 
Epstein Journal's Findings COM 
Resurrect Case 
By Jane Musgrave 
Posted Sep 17, 2019 at 12:01 AM 
Updated Oct 1, 2019 at 10:51 AM 
(EDITORS NOTE This story originally published in The 
Pal* Beath Post on March 20, 2010) 
A purloined journal that is said to contain the naines 
"hµndredC of victims of convicted sex offenderie 
Epstein could be used to reopen. the investig in e 
multi-millionaire's appetite for teenage orney 
representing seven of the yictimssai\ 
New details about the coated, ;nal were released 
this week when.Alfredo R gt ho worked as a 
property manager for each resident, pleaded 
guilty to obstnicti for lying to federal agents 
when asked if information about his former 
bate crimin He later tried to sell the journal he 
stole from Ep for $50,000 to an unidentified person, 
who ale thorities, according to court records. 
ofthe plea agreement, federal prosecutors said the 
umal 'contains information material to the Epstein 
investigation, including the names of material witnesses 
and additional victims! 
`Had the items been produced in response to the inquiries 
of state or federal authorities... the materials would have 
been presented to the federal grand jury: federal 
prosecutors wrote. 
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Insteafibosectitors short-circuited the grand jury® 
investigation and cut a deal with' Epstein. They agreed not 
to pursue federal charges if he didn't contest prostitution-
related felonies in state court The money manager pleaded 
guilty in July 2008 to procuring a Minor for prostitution 
and soliciting prostitution. He served 13 months of an 18-
month sentence. 
Attorney Adam Horowitz; who represents seven of the 
roughly 18 women who have filed civil suits against 
Epstein, said the new information could trump the so-
called non-prosecution agreement 
The multifaceted agreement, he said, deals only wi 
specific list of victims that the U.S. Attorneys Offi 
about when it penned the deal in 2007. If a 
are listed in the journal Rodriguez stole 
federal prosecutors could reopen th 
O al victims 
said 
It opens the door for further tion," he said. 
in addition to turning urnal to federal agents, 
Rodriguez told the his former boss was having 
sex with unde en he worked for him in 2004 
and 2005. H naked girls, who looked like minors, 
in the opca of ein's $8.6 million mansion. He had seen lot
pornog images of young girls on Epstein's computer, 
rditi to court records. 
either Epstein's criminal defense attorney, Jack 
Goldberger, nor attorney Robert Critton, who represents 
Epstein in the civil lawsuits, could be reached, Federal 
prosecutors have consistently declined comment. 
The wording of the controversial agreement is unclear. It 
says federal prosecutors would provide Epstein's attorneys 
"with a list of individuals whom it has identified as victims.' 
Miami attorney Robert Josefsberg was appointed to 
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reprelliany of the victims on the list who wanteilD 
pursue Epstein in civil court: As partof the agreement, 
Epstein, is to pay for Jotefsberg to represent the women, 
Some of the women, most identified as Jane Doe in 
lawsuits, had. already hired attorneys to represent diem. 
Some have since settled their suits with Epstein, although 
terms were not disclosed. 
Horowitz said he has filed court papers to get the journal 
that Rodriguez stole. "(t's another piece of evidence that 
shows our clients: were at Epstein's mansion, he said. 
Rodriguez told prosecutors he didn't turn over the j 
when both FBI and Palm Beach police asked for it 
he wanted money for it. He also said he was 
would make him 'disappear." The infor told 
investigators, was his Insurance polj 
He faces a maximum 20 years en he is 
sentenced on June 18. 
jane_musgrave@pb 
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• 
The Palm each Post. REAL NEWS STARTSAERE _ _ _ 
Epstein paid three women $54 Million to end ;ilederager 
sex lavaiiits By line Mosinee.
Posted Oct 3,2017 at 12:01 AM 
Updated Oct 4, 2017 at12A6 AM 
Ending years of speculation about h6W witch Palat Beach billibnaire Jeffr  paid young 
women who claimed he used them as sex toys, court documents filed show .he shelled C )
out S5.5 million to settle lawsuits with three of more than two doze teen who sued him. 
Responding to requests. from Epstein's attorneys in a. comp 
sex scandal, attorney said the politica 
offender paid more than. $1 million to each of the• 
it that was spawned by the 
d 64-year-old convicted sex 
it i represented. 
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1 Identified in court papers only by their ird onyms because of the nature of the
allegations and their youthful ages, L.M. w SI million, E.W: $2 million and Jane Doe 1 
511.5 million,. said of the settle a negotiated with Epstein. to. end the lawsuits. 1 
I 
Jack Goldberger, one pf Epste defense attorneys,.on Tuesday declined comment on
the revelations, citing confide i agreements that. were part of the settlements. For the 
same reason, he detlin ay whether Epstein paid similar amounts to settle toughly two 
dozen lawsuits file ryOung-Women against Epstein, claiminghe paid them forsex i 
when some we ung as 14 years old. 
a, who is representing M, said his client was compelled to divulge 
settlements to answer questions posed by.Epstein's attorneys. 'Brilliant move 
he said. 
Even if Epstein's attorneys hadn't opened the door, Scarcila said the information would have 
likely come out He says the information will help him undermine Epstein's claims that 
"ginned up" the allegations to help his former law partner, imprisoned and disbarred 
Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme. 
Ciam PirLN5W 2A BEACH COUNTY, FL, 
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• • The revelations of diesettlements came as parr Of an.ohgoing lawsuit that started as a dispute 
between Epstein and Rothstein, both billionaires. 
A year after Epstein in 1008 pleaded guiltytololicitation of prostitution and procuring a 
minor for prostitution, he sued Rothstein and M, claiming they trumped up the 
allegations of sexual Molestation to perpetuate the Ponzi. scheme. 
Rothstein was sentenced to 50 yeart in prison in 2010 after admitting he had built hi wildly ith
successful law firm by forging the names of federal judges and others to persuade'  • v stors he 
A ehad negotiated settlements in lawsuits against high-profile people. Investors c tol ey 
could .get a cut of the cash. 
One of the high-profile people Rothstein used to lure investorswas psteO  ., according to a 
lawsuit West Palm Beach attorney Robert Critton mid on Eps ' 's I According to the 
lawsuit, Rothstein told investors: Epstein, a money Manager, eed to settle the lawsuits: 
with the teens lot-4200million— a claim Critton descr' ' oniplete fabrication.' As ti
After Epstein dropped the lawsuit in 2012, Edw 
Epstein'of filing the lawsuit maliciously top 
Although 
no evidence 
was a partner inRot 
was involved i 
charged other attorneys and me
tisaid in the malicious prosecu 
e the tables on him. accused 
or representing.the young women. 
w defunct firm, Scarola claims Epstein had 
- scheme. Federal prosecutors successfully 
firm, but. was never implicated, Scarola 
The revelation's about th ey Epstein paid to three of the young woman came last week in 
documents filed fogs hea Tuesday in preparation for a December trial on the lawsuit. 
0 
Attorney ,‘) ' Haddad Coleman,: who represents Epstein, on Tuesday sought a delay of the 
trial, in pe, because she claimed she has been unable to talk to her client since his estate on his 
private island in the U.S. Virgin. Islands was devastated last month by Hurricane Irma. "I've had 
no ability to communicate with Mr. Epstein,' she said.. 
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• • Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge 
Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those 
victimized by the storm that hammered the Caribbean and roared through South Florida, he 
said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims. 
Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide 
before the case goes to trial. 
Despite Scarola's insistence that had nothing to do with Rothstein's Po erne, 
Coleman said the evidence indicates otherwise. Why else would he try to de pst n's 
well-known friends, such as now President Donald Trump, former Presi linton and 
illusionist David Copperfield, she asked. He used the celebrities as a aid. 
"The Epstein cases were used to fleece money and defraud invest, A
Edward's malicious prosecution case has been difficult 
n have refused to answer questions. As he di 
his Fifth Amendment right against self-incrimi 
pschas claimed that much of the information E ern 
privilege. 
( t y4,The malicious prosecution lawsuit o e o hotly-contested lawsuits that continue to pit 
n against Epstein. Edwards als suing the U.S. attorney's office, claiming it violated 
i the federal Crime Victims Rights Act when it negotiated anon -prosecution agreement with 
Epstein. 
s e said. 
es because both Epstein and 
lawsuits, Epstein has invoked 
questioned by Scarola.n 
is protected by attorney -client 
17 1.4rOnly after feslera ecutors agreed to drop their investigation of Epstein, did he agree to 
plead guilty t tw r 'union charges in Palm Beach County Circuit Court. In federal court 
records, p s claim one of the key reasons they agreed to drop their case was Epstein's 
agreeme o settle lawsuits filed against him by dozens of his underage victims. 
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Palm Beach Daily News, 
Judge= rules feds' agreement with 
Jeffrey Epstein pact violated teen 
victims' rights 
By Jane Musgrave 
Posted Sep 17, 2019 at 4:02 PM 
Updated Oct 8, 2019 at 12:31 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on February 22, 2019) 
Federal prosecutors violated the rights of Jeffrey E te C i9is 
teenage victims by failing to reveal they had dropped plans 
to prosecute the billionaire on dozens of federal .charges in 
connection with the girls' claims thathe paid them for sex 
at his Palm Beach mansion, U.S. Districtjudge Kenneth 
Marra ruled on Thursday. 
In a blistering 33-page ruling, Marra meticulously and 
methodically detailed thezumerous steps federal 
prosecutors t k tah 
young wome 
w)ide the agreement from more than 40 c 
claim Epstein paid them for sex when 
they w as young as 14. as
hik t e government spent untold hours negotiating the 
and implications of the NPA with Epstein's attorneys, 
Giant information was shared with the victims," Marra 
A46. 
wrote. "Instead, the victims were told to be 'patient' while 
the investigation proceeded." 
By then, it was too late. A deal had already been cut with 
then -South Florida U.S. Attorney Alex Acosta and Epstein's 
attorneys to shelve a 52-page federal indictment against 
Epstein, a former math teacher turned money manager 
who counts Presidents Donald Trump and Bill Clinton 
among his friends. 
CA/Aronboraz00, 3Z8 1-111:1J: rlAuvl BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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Proseills failure'to alert the young women abo$ 
deal violated the Crime Victims' Rights. Act, Marra ruled. 
"At a bare minimum the (act) required the government to 
inform (the young women) that it intended to enter into an 
agreement not.to prosecute Epstein; he wrote. 
Still, Marra said he wasn't second-guessing prosecutors' 
decision not to pursue Epstein on federal charges if he 
pleaded, guilty to minor state prostitution charges and 
agreed to compensate his victims for the trauma he caused. 
'The court-is not ruling that the decision not to prosecute A 
was improper,' Marra, wrote: The court is simplynil' 
that, under the facts of this case, there was a Viol-at 
the CVRA.-
Further, he made no decision about wha dy 
should be. He gave prosecutors and presenting 
the toting women 15 days-to in T i how to unravel 
the complex legal web that • hanging over Epstein in
and his young victims fore a decade. 
The chances an ac r reached are slim, said 
attorney Jack o is representing the two Jane 
Does who loge the prosecutors' actions. 
Furthe id, there is no road map to. follow. The 
suit orney filed on behalf of the two 
titled young women, claiming prosecutors violated 
e federal act, is unique, he said. 
We. are treading. on virgin ground, to use what is probably 
an inappropriate phrase in this situation,' he said: 
Starola said he and will ask that the non-
prosecution agreement be thrown out, That would open. 
the possibility that the long-shelved federal indictment 
could be dusted off and filed against the 66-year-old 
Epstein, who. spends most of his time on a private island he 
owns in the U.S. Virgin Islands, 
i 
CA/Aroftegispotna 13B EACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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"I dor. the government conceding to that rem. 
Scarola admitted. Further, he said, it is likely Epstein will be 
allowed to weigh in. Miami attorney Roy Black years ago 
filed papers asking to intervene on Epstein's behalf. 
The U.S. Attorney's Office said it wouldn't comment on 
Marra's ruling. Neither Black nor New York City attorney 
Jay Lefkowitz, who led efforts to bury the federal 
indictment, responded to emails or phone calls for 
comment. West Palm Beach attorney Jack Goldberger, who 
represents Epstein, also didn't respond. 
Scarola, said it is likely Epstein's star-studded legal team -S ,
argue that Epstein fully complied with the terms of 
agreement he made in 2007 with federal prosecut 
therefore the agreement can't be undone. 
As he promised, Epstein pleaded guiltyin,c in 008 to state 
charges of soliciting a minor for non and soliciting 
prostitution. He served 13 mo an 18-month jail term 
in a vacant wing of the couy st ade that he was allowed 
to leave 12 hours a d week. 
Further, as agr settlements to the young women 
who sued hi . Whi the settlements were confidential, 
court records he paid three women a total of $5.5 
million. 
( SeIn turn, federal prosecutors held up their end of the 
rgain. Their investigation ceased. 
Having done all that prosecutors asked of him, Scarola said 
Epstein will make a simple argument: "You can't turn 
around and deprive me of the benefits I bargained for." 
However, Scarola said, using Marra's ruling, he will counter 
that the contract Epstein signed was illegal and therefore 
unenforceable. 
r. 
cA' ArTil egi91 1XITI BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
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Even •rra agrees to toss oatthe non-prosecutie 
agreement, Scarola conceded that doesn't mean Epstein will. 
face federal charges. 
"The contract can be set aside and.the federal government 
can attempt to enter into. the same agreement," he said: 
"Exceptthe spotlight of public attention will be on them 
and the 40 victims will be able to explain to the court. why 
this sweetheart deal should notbe approved? 
Scarola said that prnatittors may have had good reason not 
to pursue Epstein. "There may be a reasonable explanation 
but we don't know what that reason may have been: b 
said. 0 
In court papers, federal protetutors have sai. . tm 
the young women were afraid to cross 
politically connected money manage y refused to 
testify against him. 
In other cases, they "said, hanged their stories, 
Jape: Poe 2, who is t the non-prosecution 
agreement thrown y described Epstein as "ari. 
awesome man rotecutots she hoped "nothing 
happen? to e shelater agreed to testify against 
Epstein, prose rs laid they feared Epstein's. attorneys 
would words to destroy her'if she ever took the 
d. 
arm, however, said the young woman s comments.didn't 
mean she wasn't entitled to know about the prosecutor? 
plans to drop the charges.. `There is no dispute that Epstein 
sexually abused Jane Doe 2 while she was a minor," he 
wrote. "Therefore, regardless of her comments to the 
prosecutor, she was a victim." 
Before the case is finally resolved, Scarola predicted that 'a 
lot of people are going to have to answer a lot of questions." 
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In hiseg i Marra detailed what appeared to be aS 
relationship between Acosta, his line prosecutors and 
Epstein's team of lawyers. His phalanx of lawyers included 
noted Harvard law professor Alan Dershowitz and Kenneth 
Starr, the former U:S. solicitor general whose investigation 
led to the impeachment of President Clinton. 
Marra describes an.October 200, breakfast meeting 
between Acosta, who is nOW U:S: labor secretary; and 
Lefkowitt shortly after the non -prosecution agreement was 
inked. 
After the meeting; .Lefkowitz.sent Acosta ante. tbanid S
him for 'the commitment you Made to th e during 
October 12 meeting in which you assured me that 
Office would not .,. contact any of the iden 
individuals, potentialvimesses, orpote aiMantt: 
and their respective counsel in this 
saks orMarti quoted an. equally plea t e then-Palm Beach 
County State Attorney B ris er sent to Assistant U.S. 
Attorney Villaf w as the lead prosecutor in 
Epsteiti's case. "G d get this worked out for 
reasons I wo Ong; Kriscler wrote, shortly 
after the non ros ution agreement was signed. "After this 
is reso I would love to buy you a cup at Starbucks and 
l 
b o
have eac v  nation.,."
oithe notes that were exchanged deilt with 
osecutors' and Epstein's lawyers' shared desire.to keep the 
deal secret from Epstein's accusers. In a September email, 
Villafana asked Lefkowitz for guidance about what she 
should reveal: "And can we have a conference call to discuss 
what .I may disclose to ... the girls regarding the 
Agreement," she asked. 
I 
1 
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Such liberation between prosecutors and defense 
attorneys is unusual, Marra said. "it was .a deviation from 
the government's standard practice to negotiate with 
defense counsel about the extent of crime victim 
notifications; he wrote. 
Further,he noted, that when and his two young 
clients asketifor information, they were repeatedly misled: 
"The CRVA was designed to protect victims' tight and 
ensure their involvement in, the criminal justice process," 
Marra wrote. "When the government gives information to 
victims it cannot be, misleading.' 
Ultimately, the terms of the non-prosecution agree 
were revealed only after and attorneys fo 
press successfully sued to make them public 
[Email Redacted] 
@pbpcourts
CA/Aroit Aeger.33. LM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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• 
76 / 278 - Tuesday, July 9, 2019 
Edition: Final 
Section: A Section 
Page: 1A 
Source: By Jane Musgrave, The Palm Beach Post 
Zpstein: indicted oit sex Charges 
Part-time Palm Beacher pleads not giiilty to sex 
trafficking, conspiracy charges in federal court in 
Manhattan.
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on M 
to charges accusing him of creating a vast network of girls as 
for his sexual pleasure at his homes in Palm Beach and M 
The 66-year-old money manager's appearance in U.S. rt in New York City 
capped more than a decade of recriminations by you and their attorneys who 
claimed Epstein used his money and political. infl ce. oid federal prosecution. 
Epstein's attorney Reid Weingarten dismissed e o-to t indictment on sex trafficking 
charges as "essentially a do-over" of allege 4e4 Epstein in the Palm Beach 
County Jail for 13 months more than a d 
However, unlike in 2007 when then-$ 
shelve a 53-page federal indictmen 
prostitution charges, prosecuto 
now U.S. labor secretary: 
"The alleged behavior shoc 
Berman said at a 
morning news conferen 
is still profoundly, 
deserve their 
At a detentipnhearIa,g scheduled for Monday, Berman said he will ask a federal judge to 
keep Bpstefit behind bars until he is tried on charges of sex trafticking.ena conspiracy to 
commit ‘x trafficking. Epstein paid dozens of young women to give him nude massages 
that, ost, led to se; he said. 
If convNisd of exploitiiiiiozens of young women, including many Palm Beach County girls 
who were students at palm Beach High School, Epstein faces a maximum 45-year 
prison sentence. 
Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin 
Islands, New Mexico and Paris and his ownership of two jets, Berman said there are few 
conditions that could keep Epstein from fleeing to a. foreign country to evade prosecution. 
leaded not guilty 
4 that he exploited 
U.S. Attorney Alex Acosta agreed to 
in agreed to plead guilty to two state 
ork indicated they aren't willing to deal,.Acesta is 
rucience," New York City U.S. Attorney Geoffrey 
d while the charged conduct is from a number of years ago, it 
o many of the alleged victims, .now young women. They 
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• • 
"We think he's• a significant flight risk," Berman said of the man who ferried Britain's Prince 
Andrew, actor Kevin Spacey„ famed Harvard law professor Alan Dershowitz and former 
President Bill Clinton on his jet, dubbed the Lolita Express. 
Berman's hard-line stance was welcomed by young women who for years have been told that 
Epstein couldn't be touched because Acosta signed off on the nonpresecution agreement, 
promising not to charge Epstein in federal court. 
Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning 
her into his sex slaveand forcing her to have sex with others, including Dershowitz and 
Prince Andrew, praised Berman. He showed the tale is "being taken in a setiont. ," she 
told the Associated Press. Dershowitz has vehemently denied Guiffres claims. 
New York prosecutors were able-to ignore the controversial nOpproSecution a 
because it contained some significant fine print, said former federal Judge P 11, who 
for years has fought to get the agreement thrown out. It tot only that it tild be 
filed against Epstein in South Florida, he said. 
Berman agreed. "That agreement only binds, by its terms; only bin the outhern District of 
Florida," he said.'The Southern District of New York is net bound t agreement and 
wasn't a signatory of it." 
That means the sordid allegations that have been leveled for years are now part of 
a federal indictment, 
Contrary to Epstein's claims, he knew the women his homes in New York and 
Palm Beach were minors because they told him i ccording.to the indictment. 
Epstein preyed on young girls: because he knevrQJte ere. "vulnerable to exploitation," 
prosecutors added. 
AS part of a carefully orchestrated sex tin id or his associates would call girls while 
he was in New York so they would ilabl for sex once he returned to Palm Beath, the 
indictment says. The employees w1ete,1 ed. They were identified only as "Employee-1," 
"Employee-2" and "Employee-
To ensure he had a steady str g girls, Epstein.would turn some-victims into 
recruiters. He would pay the. ebing new girls to his home on.E1Brillo Way along the 
Intracoastal Waterway •• Palm'. each or to his palatial townhouse on New York's Upper East 
Side. 
"This allowed E 
In both New Y 
of Epstein' 
clothes be 
tate an ever-expanding web of new victims," Berman said. 
nd Palm Beach, the lurid operation was similar. Unidentified employees 
d rt the teens intha room. They were told to take off all or most of their 
mg the naked billionaire massages, according to the indictment. 
"Epstein wo lso typimill>, masturbate during these encounters, ask victims to touch him 
while hz aturbated, and touch victims' genitals with his hands or with sex toys," the 
indictment says. 
As part of the criminal complaintr prosecutors are asking that Epstein be forced to turn over 
his multimillion-dollar townhouse on East 71st Street. The complaint does not seek forfeiture 
of Epstein's house in Palm Beach. 
While heartened that Epstein n0W faces serious criminal charges in New York, Cassell said 
he would continue to-push a West Palm Beach-based federal judge to throw out the 
nonprotecution agreement that Acosta forged With Epttein's star-studded legal team. 
I 
I 
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• 
U.S. District. Judge Kenenth Marra has already ruled that Acosta violated:the federal Crime 
Victims' Rights Act by not telling Epstein's victims about the agreement before it.was inked. 
Cointidentally, Cassell and Efitteifi attorney ROy Black had to file papers by midnight 
Monday, explaining what action Mama should take to redress that wrong. 
Cassell insisted Epstein should face charges in federal court in Wett Pitt Beach. "Florida 
victims deserve justice in Florid S' aid Cassell, who is working on behalf of Epstein's 
Victims with attorneys and Jack Seattle. 
Since its likely Florida women will get to testify against Epstein in New York, Scarola said 
he's not focused on whether Epstein will face charges here. Instead, he. said he wan to know 
how and why the agreement was reached. 
"There's been no explanation as to how a deal like this could have been cut w 
federal government could have been involved in a conspiracy to violate f w;" Scarola 
said of his interest in continuing the legal battle over the nonprosecution t. 
When Acosta agreed to drop the federal investigation, Epstein in 2008101 -guilty to two 
prostitution charges and Served 13 months of an 18-month sentencet2cant wing of the 
Palm Beach County Jail a cell he was allowed to leave 12. ho a ysx days a week. He 
was. also forced to register as a sex offender and settle civil sit more than 30 young 
winner' filed against him. 
U.S. Rep. Lois Frankel, D-West Palm Beach, said she la's interest in finding out 
how the agreement came to be."1. am especially mo d in why Epstein got the deal 
he got," Frankel said. "We need to know why he ry such an easysentence. 
While she has asked the House Oversight Co investigate Acosta, Frankel said she 
is not sure that will happen, "It just seems a it, s a travesty that this guy got off the 
way he did and, withoutpreiudging it, h proper court case," Frankel said. 
Former Palm Beach Police Chief Mi er was inflamed in 2006 when then-State 
Attorney Barry Krischer refused t stein with serious crimes..Reiter took the 
information his officers had gam fj ti. dozens of Epstein's victims to Acosta, believing 
he would prosecute Epstein. 
Reiter said he was heartened JJ years later, Epstein will finally face justice. 
"Thankfully, U. S. Att Berman and the other authorities in New York have the. good 
judgment to investigate ecute Epstein in the way that should have occurred in 
Florida.over a e as Reiter said:in a statement. 
And, Scarola $ d, ere are signals that Berman's investigation is far from over. 
Berman d to. wer questions about whether others, such as- Epstein's high-powered 
friends, o d b= charged. He brushed offquestions about the significance that the 
inv being handled by the Public Corruption Unit. 
While ents on Saturday were arresting Epstein aboard his private jet at. the Teterboro 
Airport i ew Jersey after returning from Paris, other officers were searching his New York 
City townhouse. Agents seized nude photos of young girls who appeared to be minors, 
Berman said. 
He said. his focus was on finding more women who were exploited and abused by Epstein. 
Turning to a poster, detailing the charges that had been filed against Epatein, he pointed a 
finger at a photo of the convicted sex offender who was once described as "a man of 
mystery." 
CA/Arlit egi3Writ BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735892

"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you," 
Berman said. A special number, 1-800-CALLFBI, will link victims of authorities. 
Bill Sweeney, assistant director of the FBI's New York office, said after years of being 
ignored by federal agents, the victims' voices will be heard. 
"The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said. 
Turning to address Epstein's victims directly, he said: "Your bravery may empower others to 
speak out against crimes against them." 
[Email Redacted] 
1 
CA/Aronlaerat0Q123,7, rALm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735893

• • 
Def.Ex.A-5 
cO g
<<9
(S ,
CAIAMPIteR1990 41 BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 1:49:29 PM 
EFTA02735894

• • 
Defendants. 
IN Tk1E CIRCUIT COURT of THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
v. CASE NO: 2019-CA-.014681 
Palm Beach County, Florida, SHARON R. A 
DAVE ARONBERG, as State Attorney of 
BOCK, 
 / 
C AS
as Clerk 8e Comptroller, Palm Beach County, 
Florida, O
DEFENDANT, DAVE ARONBERG, AS STATE ATTORNEY NALM BEACH COUNTY. 
FLORIDA'S ANSWER TO FIRST AM E DED COMPLAINT 
AND MOTION TO DISMI Ut T II .
Defendant, DAVE ARONBERG, as State A o alm Beach County; Florida, ("SAO"), 
aSlipp,S hlby and through the undersigned attorney, here outit I of the Firtt Amended Complaint of 
At m.,.Plaintiff; CA Florida Holdings; LLC, Pu t of e Palm Reach Post ("Post"), and files a Motion 
to Dismiss Count II, as follows: 
JURISDICTION 
1. Admitted urisdictibnal purposes. 
PARTIES 
2. 
( 701 nied that Defendant Aronberg or the Office of the State Attorney for the Fifteenth 
Judicial ircuit is in possession and/or control of documents that are the subject of this action. 
Otherwise admitted. 
4. Admined. 
INTRODUCTION 
5. Paragraph Scontains the Post's statement of the case and legal arguments to which no 
CAMr0pire111339. L,M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735895

• 
response is required. To the extent that a response is required. the SAO is without knowledge or 
information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 
5, and therefore denies the allegations and demands strict proof thereof. 
6. Paragraph 6 contains the Post's statement of the case and legal arguments to which no 
response is required. To the extent that a response is required, the SAO admits only that section 
aile sv905.27(1)(0, Florida Statute authorizes the disclosure of grand jury proceedings certain 
circumstances. 
S 
7. Paragraph 7 contains 
to which no response is required. To the extent that a response is re the SAO is without 
knowledge or information sufficient to form a belief as to the tru actual allegations contained 
in paragraph 7, and therefore denies the allegations and d proof thereof. 
no response is required. To the extent that a equired, the SAO is without knowledge or 
and demands strict proof thereof. 
information sufficient to form a belief as milte truth of any factual allegations contained in paragraph 
8, and therefore denies the 
allegationsthe  1)a1t n Beach Post's statement of the egal arguments 
,
_ . -nr—
_ 
8. Paragraph 8 sets forth the Post's e case and legal arguments to which 
9. Paragraph 8 set forth the Post's statement of the case and legal arguments to which 
no response is required. the extent 'that a response is required, the SAO is without knowledge or li
information %Aileen to form a belief as to the truth of any factual allegations contained in paragraph \ 
9,and therefor e the allegations and demands strict proof thereof. 
FACTUAL BACKGROUND 
The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 10, and therefore denies the allegations and demands 
strict proof thereof. 
A. First Epstein Sex Crimes Ins estigation, Indictment, and Plea Agreement: 2005-2008. 
11. The SAO is without knowledge or information sufficient to form a belief as to the truth 
2 
CA/ArOprieN A091340. LM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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• • 
of any factual allegations contained in paragraph 11, and therefore denies the allegations and demands 
strict proof thereof. 
12. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 12, and therefore denies the allegations and demands 
strict proof thereof. 
13. The SAO is without knowledge or information sufficient to form a belie he truth 
of any factual allegations contained in paragraph 13, and therefore denies the allega and demands 
strict proof thereof. 
0 
14. The SAO is without knoWledgeot information SutTicient t ort belief as to the truth 
of any factual allegations contained in paragraph 14, and thereto the allegations and demands 
strict proof thereof. 
15. The SAO is without knowledge or infoCatio indent to form a belief as to the truth 
of any factual allegations contained in paragraph15, and therefore denies the allegations and demands 
strict proof thereof. 
(1) Police Chief Reiterlic.etter to the State Attorney 
16. The SAO is without knoWledge or information sufficient to form a belief as to the truth 
of any factual allegationvuoinaincd in paragraph 16, and therefore denies the allegations and demands 
strict proof thereon-
17. , SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 17, and therefore denies the allegations and demands 
strict proof thereof. 
(2) The July 2006 State Grand Jury Presentation 
18. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 18, and therefore denies the allegations and demands 
strict proof thereof. 
3 
CA/Aronlaarok0101. 341 AL M BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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• 
19. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 19, and therefore denies the allegations and demands 
strict proof thereof. 
?0. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 20, and therefore denies the allegations and demands 
strict proof thereof. 
21. The SAO is without knowledge or information sufficient to form a as to the truth 
of any factual allegations-contained in paragraph 21, and therefore denies th s and demands 
strict proof thereof. 
22. The SAO is without knowledge or information su 
of any factual allegations contained in paragraph 22, and t 
strict proof thereof. 
(3) A IThe FBI's Investigation and Epttei ,s on-Prosecution Agreement with Federal 
Authorities. 
form a belief as to the truth 
es the allegations and demands 
23. The SAO is without mformation sufficient to form a belief as to the truth 
of any factual allegations containedin aph 23, and therefore denies the allegations and demands 
strict proof thereof. 
Thr24. The SAO Wit out knowledge or information sufficient to form a belief as to the truth 
of any factual alleg ons contained in paragraph 24, and therefore denies the allegations and demands 
\ `'y 
strict proof Mere° N 
\ The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 25, and therefore denies the allegations and demands 
strict proof thereof. 
26. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 26, and therefore denies the allegations and demands 
4 
cNAR TIl eff t5991\IS BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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• 
strict proof thereof. 
27. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 27, and therefore denies the allegations and demands 
strict proof thereof. 
28. The SAO is without knowledge or information sufficient to form a belief as to the truth 
-I, 
of any factual allegations contained in paragraph 28, and therefore denies the allegations demands 
strict proof thereof. 
29. The SAO is without knowledge or infOrmation sufficient to as to the truth 
of any factual allegations contained in paragraph 29, and therefore denies ations and demands 
strict proof thereof. 
30. The SAO is without knowledge or informa - I ' nt to form a belief as to the truth to
/-- of any factual allegations contained in paragraph 30, and titer it denies the allegations and demands 
. \ 
strict proof thereof. 
31. The SAO is without knowledge or information sufficient to form a belief as to the truth 
. / of any factual allegations contained in paragraph 31, and therefore denies the allegations and demands 
strict proof thereof. 
(4) The Crime Victims' Rimhts Act Lineation. 
32. SAO iSwithout knowledge or information sufficient to form a belief as to the truth 
of any factual allegati contained in paragraph 32, and therefore denies the allegations and demands 
strict prodf thereof. 
33,. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 33, and therefore denies the allegations and demands 
strict proof thereof. 
34. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 34, and therefore denies the allegations and demands 
5 
CA/AroplinNa BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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• 
strict proof thereof. 
35. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 35, and therefore denies the allegations and demands 
strict proof thereof. 
36. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 36, and therefore denies the allegationM 1 mands t% 
strict proof thereof. 
37. The SAO is without knowledge or information sufficient to 
of any factual allegations contained in paragraph 37, and therefore denies 
strict proof thereof. 
B. Second Epstein Sex Crimes Investigation. IndictniC hSed ide: 2019. 
38. Admitted. 
f as to the truth 
gations and demands 
39. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in parpgrnph 39, and therefore denies the allegations and demands 
strict proof thereof. 
40. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegationsisMailied in paragraph 40, and therefore denies the allegations and demands 
strict proof therein/ S 
41. /rite S O is without knowledge or information sufficient to form a belief as to the truth. 
4 I 
of any fachmi allegations contained in paragraph 41, and therefore denies the allegations and demands 
strict prdof thereof. 
42. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 42, and therefore denies the allegations and demands 
strict proof thereof. 
43. The SAO is without knowledge or information sufficient to form a belief as to the truth 
6 
CA/Amble:G.70a 344 l'ILL:1): FIALA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
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• 
of any factual allegations contained in paragraph 43, and therefore denies the allegations and demands 
strict proof thereof. 
44. Admitted. 
C. The August 27, 2019. SDNY Hearinn: Epstein's Victims Sneak. 
45. The SAO is without knowledge or information sufficient to form a belief as to the 
4, 
ketruth of any factual allegations contained in paragraph 44, and therefore denies the alleg 'iniR and 
demands strict proof thereof. 
AS 
46. Admitted that United States Senior Judge Richard M. Be d a hearing on 
August 27, 2019, but the SAO is without knowledge or information suffic fto orm a belief as to the 
truth of any remaining factual allegations contained in par  and therefore denies the 
allegations and demands strict proof thereof. 
47. The SAO is without knowledge or infoCation fficient to form a belief as to the truth 
of any factual allegations contained in paragraph 47, and therefore denies the allegations and demands 
strict proof thereof. 
48. The SAO is without knowledge  or information sufficient to forma belief as to the truth \•„:, , 
of any factual allegations contained in paragraph 48, and therefore denies the allegations and demands 
strict proof thereof. 
49. AO is ithout knowledge or information sufficient to form a belief as to the truth 
of any factu contained in paragraph 49, and therefore denies the allegations and demands 
strict proo f. 
The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations paragraph 50, and therefore denies the allegations and demands strict proof 
thereof. 
51. The SAO is without knowledge or information sufficient to form a belief as to the truth 
of any factual allegations contained in paragraph 51, and therefore denies the allegations and demands 
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EFTA02735901

strict proof thereof. 
D. The Palm Beach Post's Standine and the Public Interest. 
(1) The Palm Beach Post Has Reported Extensively On Epstein's Crimes For Nearly 
15 Years. 
52. Admitted. 
53. Admitted. 
54. Admitted that the Post has extensively investigated and reported on the al)egations 
against, the law enforcement investigation of, and the crimes committed by Epstein, but lacks sufficient 
knowledge to admit or deny any factual allegations remaining in paragraph 54,'arid therefore denies 
the allegations and demands strict proof thereof. 
55. The SAO is without knowledge or information sufficient to form a belief as to the 
truth of any factual allegations contained in paragraph-55,44therefore denies the allegations and 
demands strict proof thereof. 
(2) The Palm Beach Post's Standine and the Public Interest. 
56. Paragraph 56 of the ded Complaint contains the Palm Beach Post's 
statement of the case and legaLatu to which no response is required. To the extent that a 
response is required, the SAO fits the press has a constitutional right of access to criminal 
proceedings, but is withou ledge or information sufficient to form a belief as to the truth of any 
remaining factuttickgations contained in paragraph 56, and therefore denies the allegations and 
demands ustler sttopf thereof. 
Paragraph 57 sets forth the Post's statement of the case and legal arguments to which 
no response is required. To the extent that a response is required, the SAO is without knowledge or 
information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 
57, and therefore denies the allegations and demands strict proof thereof. 
58. Paragraph 58 sets forth the Post's statement of the case and legal arguments to which 
CA/Aro PPIelei l NI. BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735902

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no response is required. To the extent that a response is required, the SAO is without knowledge or 
information sufficient to form a belief as to the truth of any (actual allegations contained in paragraph 
57, and therefore denies the allegations and demands strict proof thereof. 
59. Paragraph 59 of the First Amended Complaint contains the Palm Beach Post's 
statement of the case and legal arguments to which no response is required. To the extent that a 
response is required, the SAO admits that Fla. Stat. 905.27 allows a court to make the itination 
of disclosure but is without knowledge or information sufficient to form a belief as trtu h of any 
remaining factual allegations contained in paragraph 59. and therefore d egations and 
demands strict proof thereof. 
E. The Court's Jurisdiction and Authority. 
(1) The Court's Supervision of the Grand Ju t and Its Authorits to Order 
Public Disclosure of the Epstein Evidence, 
60. Paragraph 60 of the First Amended-Complaint contains the Palm Beach Post's 
statement of the case and legal arguments t8 N71jFh no response is required. To the extent that a 
response is required, the SAO admits t1 has a constitutional right of access to criminal 
/ 
proceedings, but is without kno Idtig itkormation sufficient to form a belief as to the truth of any 
remaining factual allegations c 
tus 
'rid in paragraph 60, and therefore denies the allegations and 
demands strict proof the 
61. ddlfljEted. 
fitted. 
Paragraph 63 sets forth the Post's statement of the case and legal arguments to which 
no response is required. To the extent that a response is required, the SAO is without knowledge or 
information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 
63, and therefore denies the allegations and demands strict proof thereof. 
64. Paragraph 64 of the First Amended Complaint contains the Palm Beach Post's 
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statement of the case and legal. arguments to which no response is required. To the extent that a 
response is required, the SAO is without knowledge or information sufficient to forma belief as to the 
truth of any remaining factual allegations contained in paragraph 64, and therefore denies the 
allegations and demands strict proof thereof. 
(2) The Court's Jurisdiction To Declare Riehts And Construe Statutes. 
66. Admitted. 40A 
65. Admitted. 
67. Admitted. 
COUNT!  
as O 
(Declaratory Relief - Florida Stat. Sections 86 els ;) 
68. The SAO reincorporates and re-alleges its 
L`
s o paragraphs 1 through 
69. Admitted. 
'C c\
s 
67 above. 
70. Paragraph 70 contains the Po terrfentt of the case and legal arguments to which 
no response is required. To the exten onse is reqUired, the SAO is without knowledge or 
information sufficient to form a Oche I e truth of any factual allegations contained in paragraph 
70, and therefore denies the allegations and demands strict proof thereof. 
71. Admitted t t The Palm Reach Post is seeking a declaration front this Court but 
denies the retnai oIParagraph it. 
4.
rai r hied 
. Denied. 
7  Paragraph 74 contains the Post's legal argtiment to which no reSponstis required. 
To the extent that a response is required, the SAO i,s: without knowledge or information sufficient to 
form a belief as to the truth of any factual allegations contained in paragraph 74, and therefore denies 
the allegations and demands strict proof thereof. 
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CA/Arm:them:0 a4B, run): r lAut.i BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735904

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MOTION TO DISMISS COUNT II 
(Florida Stat. Section 905.27) 
Defendant, DAVE ARONBERG, as State Attorney of PiIm Beach County,.Florida, pursuant 
to the Florida Rules of Civil Procedute 1.420, hereby files this Motion to Dig-Mist Count II of Plaintiff's 
First Amended Coniplaint for failure to state a cause of action, and in support thereof stater: 
L Standard of Review 
When confronted with a motion to dismiss, the Court. must detemiinc wha c plaint 
as phrased within its four corners sufficiently states a cause of action, whereb c tr be granted. 
Fox v. Professional Wrecker Operations 801 SO. 2d 175, 178 (Fit 5 '.1). A. inotitin. tO 
dismiss tests whether the plaintiff has stated.a cause of action. Th for tion:to dismiss under g 
Florida Rule of CiVil Procedure 1.140(h) is whether the plea u  ve any set of feels as alleged 
in the Complaint to support his or her claim. Is, 89 So; 2d 482, 484 (Fla. 
1956); Wasua Ins. Co. v. HaVries 683 So..2d 1123 DCA 1996). 
In order to meet this test, "a compi of st lege sufficient ultimate facts to show that a 
pleader is entitled to relief." W.R. To tr.. Inc. v. Jensen Civ. Constr. Inc., 728 So. 2d 297, 
300 (Fla. 1st DCA 1999) (quoti etekvlCoserove  464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. 
R. Civ. P. 1.110(b)). The couritbeeA not accept internally inconsistent factual claims, conclusory 
allegations, unwarranted ons, or merelegal conclusions made by a party. Kt (citing Jtesoonse, 
Oncoloev, Inc. ealth Insurance Co„ 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Asset 
97 F.3d 1182, 1188 (11th Cir. 2002) ("(On a motion to dismiss,) the plaintiff's 
ons are accepted as true.... However, legal conclusions masquerading as facts will not 
prevent dismissal."). To avoid distniSsal, a pleading "mist allege a cause of action recognized Under 
law' against the defending party. Kislak v. 1Creedian 95 So. 2d 510, 514 (Fla. 19.57). 
Q. Arpu men t 
a.. Neither Defendant A ronberg, nor the Office of the State Attorney for the 
Fifteenth Judicial Circuit is in possession and/or control of documents that 
I 1 
cA ' Arctifft5991a BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735905

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are the subject or this action. 
It is significant to emphasize that despite Plaintiff's allegations to the contrary, Defendant 
Aronbcrg and the Office of the State Attorney for the Fifteenth Judicial Circuit arc not in custody or 
control of the records sought herein, and therefore Defendant Aronberg is not a proper party to this 
action. In fact, Defendant, Sharon R. Bock, as Clerk and Comptroller of Palm Beach County, Florida, 
admits that it is the custodian in possession of the documents that are the subject of t 
b. Plaintiff Fails to State a Cause of Action 
Plaintiffattempts to assert a cause of action, in the interest of "furthe 
Statute § 905.27; however, a review of the statute in question reveals that n 
for therein and consequently Count II of Plaintiff's First 
matter of law. Despite Plaintiff's extensive recitation o 
Epstein and the testimony and evidence presented 
Florida, Fla. Stat. § 905.27, merely explains thelxce 
',under Florida 
of action is provided 
aint must be dismissed as a 
background regarding Jeffery 
grand jury in Palm Beach County, 
o s to the disclosure of grand jury testimony 
and does not set forth in any way a cause of` tion upon which to initiate a valid law suit. 
Moreover, a review of the tyre sue clearly indicates that even if § 905.27, Fla. Stat. 
provided a basis for a cause of a Lion, Pliintiff is barred from access to the records it seeks. To wit, in 
pertinent part, Fla. Stat. §- 9_05.27(2) states: 
When sucfrdisclostire is ordered by a court pursuant to subsection (I) for use in a civil 
case, it maybe disclosed to all panics to the case and to their attorneys and by the latter 
to their kgal associates and employees. However, the erand jury testimony afforded 
such persons by the court can only be used in the defense or nroseention of the civil or 
crinithakase and !Or no other purpose whatsoever. 
ierc, despite the clear statutory guidelines for disclosure of grand jury materials in a civil case, 
Plaintiff is improperly seeking the requested 2006 grand jury materials for the purposes of public 
disclosure pursuant to the court's inherent authority and supervisory powers over the grand jury. [See, 
Complaint cifil 8, 63]. Again, even if Plaintiff properly asserted a cause of action under Fla. Stat. 905.27, 
the statute unambiguously states that grand jury testimony "can only be used in the defense or 
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prosecution of the civil or criminal case and for no other purpose whatsoever", which is distinctly 
different from Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla. Stat. 
905.27(2). 
WHEREFORE, based on the foregoing argument and supporting authority, Defendant, DAVE 
ARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this 
Honorable Court gane the instant Motion and dismiss Count Il of Plaintiff's First Mithilkmplaint 
with prejudice, and gant Defendant Aronberg all other and further relief deeme ft and proper, 
including attomey's fees and costs for defending this frivolous action. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 24th day of January, 202 py of the foregoing has been 
electronically filed with the Florida E-File Portal for all e-serviceprf parties of record herein. 
\ \ _„,"" 
,4(4 611S SCHOLZ & WYLER, LLC 
(SS ouglas A. Wyler 
13 
Arthur I. Esq. 
Fla. Bar No.: 10249 
Richard J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-I 
Fcmandina Beach, Florida 32034 
([Phone Redacted] 
([Phone Redacted] Fax 
Primary: jacobsscholzlaw®comcast.net 
General Counsel for tire Florida Prosecuting 
Attorney's Association 
CA/ArctpeN 59,15:1, ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735907

Def.Ex.A-6 
4C
A 
COAS
MA 9 111,1599ala BEACH COUNTY, FL, ABRUZZO, CLERK, 3/28/2023 1:49:29 PM 
EFTA02735908

COPY 
In the Matter Of: 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
50-2019.CA-014681 
HEAR'
June ,010 
UIRE DEPOSITION SOLUTIONS 
800.211.DEPO (3376) 
EsquireSolutions.com 
cA'ArTirti59901 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735909

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A Cog 
CA/AWN:LC(1PM BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 I:49:29 PM 
EFTA02735910

• HEARING June 03, 2020 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 1 
IN THE CIRCUIT COURT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. : SO -2019 -CA -014681 
CIRCUIT CIVIL DIVISION: "AG" 
CA FLORIDA HOLDINGS LLC PUBLISHER 
OF THE PALM BEACH POST, 
Plaintiff/Petitioner 
-vs-
DAVE ARONBERG, 
SHARON R. BOCK, 
so 
HEARIN 
Defendant/Respondents\ 
AS 1)
THE HONORABLE KRISTA MARX 
Cos 
(ZOOM CONFERENCE) 
Wednesday, June 3, 2020 
10:08 a.m. - 10:28 a.m. 
REMOTE ZOOM CONFERENCE 
Port Saint Lucie, Florida 
Stenographically Reported By: 
SONJA M. 
Court Reporter 
ESQUIRE NIOMWMSMWW” 
800.211.DEPO (3376) 
EsquireSolutions. corn 
CA/Aropire:00.1.35A tv rALm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735911

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
2 
APPEARANCES: 
On behalf of the Plaintiff/Petitioner: 
GREENBERG TRAURIG, P.A. 
1840 Century Park East 
Suite 1900 
Los Angeles, California 90067 
[Phone Redacted] 
boyajianOgtlaw.com 
BY: NINA D. BOYAJIAN, ESQUIRE 
On behalf of the Defendant/Respondent: 
JACOB, SCHOLZ & WYLER, LLC 
961687 Gateway Boulevard 
Suite 2011 
Fernandina Beach, 
[Phone Redacted] 
[Email Redacted] 
BY: DOUGLAS A. WYLER, ES 
Florida 32034 
4Ni ti; On behalf of the Defendant/Ras ndent: 
CLERK & COMPTROLLE 'icAy4 BEACH COUNTY 
P.O. Box 229 
West Palm Beach,_ 'de 33401 
[Phone Redacted] 
nfingerhutOm 
BY: NICOLE 
rrA
achclerk.com 
ERHUT, ESQUIRE 
ESQUIRE 'ow Our 
800.211.DEPO (3376) 
EsquireSolutions.corn 
CA/Aroniaenar0Q 356 Hui) P1ALN1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735912

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
3 
PROCEEDINGS 
THE COURT: We are here today for a very 
limited purpose. I'm sure the attorneys are aware of 
that, but I just don't want there to be any 
confusion. We are here on Defendant Dave Arof g 
and Defendant Sharon Bock for the Comptrol and the 
State Attorney's motion to dismiss Cou t 
You're all acutely aware as the rs that 
this is a question of law. So w= re of going to be 
diving into facts and the Coin not be deciding 
the merits of this motion '' rning. We are 
A I,c)simply here for the solA 
S
tur u se of that motion to 
dismiss. So I just wanted to make sure that we all 
stay on track and/Werre all on that same page. 
So, Ms. B'yagian, I'll send it to you first, 
i'''. i -- o course, we all know that the Law 101, 
I must look the four corners of the motion, which 
alleg hat the State Attorney, David Aronberg, and 
ti erk and comptroller, Sharon Bock, actually have t
'7S-ody and control of these grand jury proceeding. 
Whether that is true or not is not for this 
court to determine because I'm looking simply at the 
four corners of the complaint. But, not iOr nothing, 
I think we all know that they don't have control and 
ESQUIRE m".."."m" 800.211.DEPO (3376) 
EsquireSolutions.com 
CA/ArOplieN9912 L57. AM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735913

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
4 
custody of the records. But I'm going to assume that 
it's correct because that's what has been alleged. 
So what I first want to hear from is the 
attorney for Florida Holdings with regard to, 
assuming arguendo, that Florida Statute 905.27 does 
create a cause of action, what relief is it t 
you're seeking from -- in Count II, specifi 
Not the dec action. We're not here on 
what is it you hope to get, a judgmen 
V 
MS. BOYAGIAN: Thank you, yo nor. Good 
d y 
morning, and thank you for the ' ege of appearing 
before this court. 
-4\ 
The relief we are is disclosure of the 
grand jury records, s t to the Furtherance of 
Justice Exception .27. And under the First 
Amendment. 
The press, your Honor is aware, has a right 
of access u the First Amendment as a surrogate of 
the p 
COURT: Let me just stop you for a minute. 
-ledike you to answer my specific question. 
So I am not particularly convinced -- and I'd 
like for you to address that. So we're not going to 
dive into facts or the press's standing because 
that's not something we're here to discuss today. 
ESQUIRE ".."..." 800.211.DEPO (3376) 
EsquireSolutions.com 
CA/Aronberat0Q1.3.58. -rilattr PADVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735914

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
5 
And I have read the voluminous paperwork --
I've received paperwork as -- and -- five-minute ago 
from some of the other parties. But I deeply 
appreciate the fact that you sent this to me so much 
in advance and I have been able to spend some time 
with, as I said, the voluminous paperwork thatwaits 
provided. Agq,/r
But as you know, , we are he fo. such an 
extremely limited issue today, and th t t eir motion 
to dismiss where they state "you Uing the wrong 
people"; that the court has t cords. 
ACAnd so, more importan want you to address 
talkywhether Section 905.27 ' s you a private cause of 
egc .action against the s to ttorney and the clerk. 
Again, I'm 6 o assume the facts are true 
that are asser -td the motion. Whether they are or 
Lig not -- because hink we can all agree we're not for 
sure if the e -- that the state attorney doesn't 
have tfh e records. So what is it you're seeking in 
Cg I -- not the dec action. I know you want the 
ds. I've got that. But in Count II, 
specifically, what do you -- what's the relief you're 
seeking and, more importantly, how under this statute 
do you get to assert a private action -- a private 
cause of action against the state attorney and the 
ESQUIRE ."".... 800.211.DEPO (3376) 
EsquireSolutions.com 
CA/Aronigeraz0W35.9 tiLty: rAN1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735915

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
6 
clerk? 
MS. BOYAGIAN: Your Honor, we are aware, of 
course, that there is no expressed private right of 
action, 905.27. But that does not end the inquiry. 
As the Florida Supreme Court stated: 
forbids an act which is to 46C
"Where a statute like 905.27 
ASlyPlaintiff's 
injury, the party injured should haVi::)
an action." 
And that's the Smith Piezo case in the volume 
- h 
of materials that we sent you. //i / 
zi 
There's no question here that the denial of the 
FIRST AMENDMENT right to the press is an injury which 
gives rise to a right_  of action. (--, /
Stated another 7'looking at the analysis 
7 
that the Fisch Mepalf Court looked at, there are 
three factors irk-determining whether there is a 
private rig of action where a statute does not 
express provide for one. 
is whether the Plaintiff is part of the 
-olaes for which the statute is intended to protect; 
second is a legislative history; and the third is the 
underlying purposes of the statutory scheme. 
The first factor I already addressed, that the 
press is part of the class that the statute is 
ed„, ESQUIRE w" 0".." 800.211.DEPO (3376) 
EsquireSolutions.com 
CA/ArOplie AR509136.0. LM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735916

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
7 
intended to benefit, being the surrogate of the 
public and exercising its first amendment right. 
The second issue of legislative history and the 
purpose -- statutory purpose are somewhat related. 
We were unable to find much legislative history, on 
this issue of a private right of action unde 
statute. 
AC;Ir There is nothing that says we int create 
a private action, but there's certain •thing that 
says we do not want to create a to right of 
action. 
What we do have is t 994, the same time 
that 905.27 was reenact tatute that pertains to 
the secrecy of State ra Jury statewide grand 
juries was also That provision, which is 
905.395, has ex tions for -- for revealing these 
records. By co ast, the legislature intentionally 
enacted_905Y27 with the Furtherance of Justice 
Exce 
the public through the press can't bring a 
to right of action to enforce that exception or 
to seek relief under that exception, that 
intentionally placed exception of furthering justice 
is essentially rendered hollow --
(Speaking simultaneously.) 
ESQUIRE 800.211.DEPO (3376) 
EsquireSolutions. corn 
CA/Aropaer.a,0011.A
361 ILEA) PLM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735917

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ase the 
HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
8 
THE COURT: Okay. Pause for a minute. 
I don't think anybody is saying that there 
isn't a cause of action or that the press doesn't 
have standing. That's not what I'm asking you. I'm 
asking you, how are the clerk and the state attorney 
the proper defendants? 
So, yOu know, nowhere have I said the )isn't a 
cause of action. Clearly there is. I'M puzzled by 
the procedural posturing of this cage:naming the 
state attorney. 
And, you know, I'm further,gtvmiedr by the fact 
that you allege in your compleint that they have 
particularly David Aronberg the State Attorney 
that he has these recd 
But I'm goin sume that's true. So I'm 
not telling yo don't have a cause of action. 
I'm just sayin kay, let's run this all the way 
out. Let's you win and you get a judgment 
again he State Attorney Dave Aronberg. 
is he supposed to do with it? He can't 
grand jury testimony. He has no 
authority whatsoever to do that. 
MS. BOYAGIAN: Well, your Honor, as you stated, 
this is a motion to dismiss stage, and we are 
entitled to discovery on the issue of possession, 
ESQUIRE 800.211.DEPO (3376) 
EsquireSolutions.corn 
CA/Aroplaent81A362 tun 99A-Lm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735918

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
9 
custody, and control. My understanding is that the 
state attorney has asserted that he does not have 
possession. It's not my understanding that the clerk 
has taken that position. So the clerk may indeed be 
the -- someone who does have possession, custody, and 
control. 
In any event, we would submit that the state 
attorney, even it does not have actual, possession at ,,- 
this time, it might be able to have the power to 
control or direct the entity or perebns who do have 
control and possession to rele nthose -- to effect 
the judgment. 
THE COURT: So let you this: So the 
clerk is the keeper record. But even if you 
got a judgment a  n per -- let's say you asserted 
ainst the (:: 
this cause of c 1 and let's say you win and you 
get a judgment clerk. The clerk cannot 
release gra Ty testimony to you. Only the court 
can. 
really -- all I'm saying to you is I do not 
AT144orstand the way this case was filed or why these 
E
are the defendants because it's impossible for them 
to perform. 
I mean, I'm going to assume, based on your 
motion, again, that they do have the records. But we 
ESQUIRE "..0" 800.211.DEPO (3376) 
EsquireSolutions. corn 
cA' ArcfrE COPA191 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735919

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
10 
all know -- everyone in the room knows they do not --
that only the court -- they're -- they're with a 
court interpreting. And only the court can release 
the records. 
So if you get a judgment against either the 
Aistate attorney or the clerk, they cannot I sk, I 
guess what you're saying to me is, well, we t o 
do discovery and we want them to say unec¢ ally "I 
have these records" or "I don't have 
And -- I mean, the law is abUildantly clear. 
You cannot do it without a court determining whether, 
- 
-/ 
in the furtherance of justice, the release is 
appropriate. 
MS. BOYAGIAN: And that is a determination 
we're asking your  to make, and we're asking for 
an order from yOur\cohrt. 
THE COURT:' -.When we get to the merits of the 
case, sure it—As. But, again, you're asking me to 
make that determination and for me to make a 
determination of whether the grand jury records 
41d be released. And the only thing we're here 
today about is why should the clerk and the state 
attorney have to defend a civil action when it's a 
possibility of performance? They -- even if you were 
to win and get a judgment against them, they cannot 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
11 
give you what they don't have. 
So -- I mean, it's as simply as this: Are 
you -- you just want to engage in some discovery for 
them to absolutely assert, particularly, the state 
attorney, nI don't have these records"; look to the I 
rules that say the moment the grand jury's oveL,c 
they're sealed and they're turned over and y 
cannot be released without court order 
So I'm not addressing the merits hether you 
have an exception or you're able o rgue that 
there's an exception in the f nce of justice. 
We're not getting there to 'm simply saying why 
should these two entiti Aida to defend this lawsuit 
when even down the they win they can't give 
you what they do e. 
MS. BOYAG A -ii. N: )s your Honor stated, I'm not 
(h) thee ase with the clerk. That was not in sure that's 
their th issue was not stated in their papers. 
COURT: Let me ask you this, then: Do you 
if you got a judgment and I or the court 
t make the determination that the grand jury 
records should be released, that the clerk would be 
able to perform? 
Would they be able to say "here you go"? I 
mean, could the clerk just make that unilateral 
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• • HEARING June 03, 2020 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 12 
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decision "I'm going to release the records, sealed 
confidential records"? 
Does she have any authority to do that? 
MS. BOYAGIAN: My understanding, your Honor, is 
that 905.27 requires a court order before the records 
are unsealed. 
THE COURT: EXactly. Exactly. 
All right. Let me hear from Mr. A 
attorney, Mr. Wyler. 
MR. WYLER: Thank you, your Igo . May it 
please the Court 
s 4,./
THE COURT: Good morning i 
MR. WYLER: Good myerntng 
Your Honor, I ju t -WSnted to let you know that 
I spoke with counsel tarythe clerk, Ms. Fingerhut, a 7 \- 
couple of days (befoxe ithis hearing, and we decided 
that I would jUst.,-Make the presentation for both of 
of us, bein'4ithat our arguments overlap except for 
the farett who this claim whether they have the 
record or not, which, of course, we've said we don't 
custody of the records. 
But, nonetheless, our arguments overlap. The 
Plaintiff is attempting to assert a cause of action 
under Section 905.27. That statute settled testimony 
not to be disclosed exceptions. So it's just 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
13 
explaining exceptions to the disclosure of the grand 
jury testimony. 
Our position is that it doesn't set forth a 
cause of action and that it's impossible for us to 
perform what they're asking. 
I know you said you didn't really want t 
ilinto the Furthering Justice Exception, but A% now 
that's what they're using as their bas' et to 
these. But it's our position that th 
30(::, unambiguous statutory language, ' ows that this 
disclosure only applies to a v.1 r criminal case, 
and that within that civil minal 
(Speaking simultan ) 
THE COURT: Aga -- I'm sorry. As I told 
Plaintiff's couns 
MR. WYLER Lan only be used in the defense 
for --
THE COURT: Okay. We're not there. We're not 
discus/sing the merits of the case, and -- I'm not 
rya o cross that bridge. I'm here for a very, 
limited heating today. 
So just as I stopped Plaintiff's counsel from 
arguing the merits of the case and whether or not the 
Furtherance of JUstice Exception will apply in this 
instance, we're not even there yet. 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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I'm only here for the purpose of determining 
whether or not the clerk and state attorney should be 
dismissed. And I am bound by the four corners of the 
document, which assert that you do have control and 
custody over it. 
ilkSo if you'll fashion your argument with r rd 
to that limited purpose, I would appreciate. 
MR. WYLER: No problem, your Honor. 
apologize. 
Within the four corners of theircomplaint, our 
position is that they failed to/state' a cause of 
action under 905.27. It does not provide for -- it 
doesn't list that there cpelement that they have 
adequately pled to as r a cause of action under 
that. There's -- only thing they're asking 
for is records ittki don't have. 
There's rem not much more to it, your Honor. 
And we would ask that you would grant our motion to 
dismissNfor failure to state a cause of action. 
— 
THE COURT: Okay. Ms. Fingerhut, are you still 
ron he phone? 
MS. FINGERHUT: Yes, your Honor. 
THE COURT: Is there anything you wish to add? 
MS. FINGERHUT: We agree with the state 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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attorney's position, and we also agree with what the 
Court has said, that the plain language of the 
statute, a cause of action doesn't exist. And we 
really cannot -- we'll be defending something without 
the four corners. We're simply involved in this 
4Aa;caction becaUse the clerk is the custodian of
records. 
r 
THE COURT: Okay. Thank you, 
II. Boyagian, back to you. 
MS. BOYAGIAN: Your Honor, ike to note 
that in the Butterworth case h the Supreme 
Court limited the applica .27 by saying that a 
witness can reveal her tZ timony and prohibiting 
that they violate t Fi t Amendment --
THE COURT: iat again, please. 
MS. BOYA AN n the SUpreme Court case, the 
Butterworth caste' in which the Supreme Court ruled 
that 905.27V Can't restrict a Grand Jury witness from 
revealing her own testimony, that would be a 
violation of First Amendment, in that case, the state \ -1„2 
-.'ttorney was, in fact, a party. 
THE COURT: Well, I assume the state attorney 
that was present -- I Mean, I don't find that that'S 
diese to what we're talking about here, and that's 
whether or not -- I mean, as we know, this was in 
ee ESQUIRE ."m."." 800.211.DEPO (3376) 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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2006. Certainly Dave Aronberg wasn't even the state 
attorney then. But this is about the release of 
records. 
I want to give you ample opportunity -- and 
again, I sincerely appreciate that all of the case 
law and the way that it was presented to the t in 
such a timely fashion. I really do. And I s end 
some time with it. But i want to give a ever 
opportunity you want to take to convir a me that it 
is in -- as to Count 2, again. N e dec action 
whether these would be the app ' e defendants. 
And, you know, really, you to boil it 
down for me as to this - s take it all the way 
down the road. You wyou get a judgment against 
the clerk and the ttorney. 
I know th her reasons why you might have 
filed it this But I'm just simply puzzled 
because I dO/hear what the clerk and the state 
attorney\are saying, and that is, performance is 
impossible. They don't have the records and 
cannot -- absolutely. There's not even an inch of 
wiggle room -- that they could release the records 
even if you got a judgment. It is solely a 
determination for the court. 
I, frankly, think, you know, there's ways to 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June O3, 202O 
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get to your records. There's ways to get 
confidential records. But it isn't by suing the 
state attorney and the clerk. 
So I just want to hear your last final argument 
on how Count II, the appropriate defendants are the 
clerk and the state attorney. Even assuming iikr4u.endo 
they have the records -- we know they don't you 
were to get a judgment against them, h ld you 
expect them to perform? 
M.S. BOYAGIAN: Two points, onor: One is 
that, again, the clerk did no t in her papers 
i 
that she does not have conAk That is a position 
s that the State Attorney i ce has asserted. It is 
e4;411 our allegation, and ate y ,r Honor noted, allegations __
must be accepted as  -- as true at this stage of 
the proceedingS.
Second, i'IA also our understanding that the 
state a torOy and the clerk intend to block access 
to th records. So our allegation is that they do 
h p.Ssession, custody, or control, which the clerk 
AMW%Stiof denied; and second, that they are trying to 
block access to the records 
THE COURT: What do you mean? What do you 
mean? They're not trying to block it. They're 
saying that despite the fact -- let's just talk about 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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the clerk, because we all know the state attorney 
doesn't have it. 
So the clerk is the custodian of records. 
That's her main job. There's no doubt about it. We 
all know that. But we also know, unequivocally 
unequivocally, only the court can make the 
determination of whether the moving party 
satisfied that there is an exception th se 
should be released. 
So, again, I ask you -- she s, in f)act, the 
custodian of the records 
i-- 
i •ur opinion that 
if you got a judgment Sayi tJ tie and comptroller 
gets a judgment against that she can release 
the records without urt -- without the court 
weighing in, without court making that 
determination as' required by law? 
MS. BOYAGIANi No, your Honor. We are asking 
your Honor „ to Order the clerk to do that under your 
discretion. 
TIE COURT: All right. 
====_ Mr. -- Ms. Fingerhut, you wish to be heard on 
that? 
MS. FINGERHUT: Your Honor, our position is 
that we're not trying to block access to the 
records --
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MS. FINGERHUT: -- custodian the records and 
that he cannot release the records without court --I,
THE COURT: Exactly. 
Okay. All right. Anything further, Mr. Wyler? 
MR. WYLER: No, your Honor. I concur with the 
attorneys for the clerk's office that4t 1,s impossible 
for us to release these records. /Thitre's no intent rjr \ zip 
to hide them or block anything from ,-the Plaintiff. 
THE COURT: Okay. An .19 further, 
MS. FINGERHUT: of  ur Honor. o
THE COURT: S. Boyagian, anything 
further, 
II. BOYAGIAN: Nothing further, your Honor. 
THE 
quickly Thank you, folks so much. And I'll see you 
ext round. Thanks a lot. 
MS. BOYAGIAN: Thank you, your Honor. 
MR. WYLER: Thank you, your Honor. 
(The proceedings Concluded at 10:28 a.m.) 
S 
HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
19 
(Speaking simultaneously.) 
THE COURT: Can you hear? Can the attorneys 
hear? 
Ms. Fingerhut? 
COURT: Okay. I will get an order out 
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CERTIFICATE OF REPORTER 
I, Sonja M. 1M, Court Reporter, certify that 
I was authorized to and did stenographically report the 
foregoing proceedings, and that the transcript, paisee 1 
through 19, is a true and complete record of 
(:stenographic notes. 5:)
'S IP,Iit) Dated this 3rd day of , 20. 
As s,
A 
Sonja M. 
-V Court Repille! 
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• • 
De£Ex.A-7 
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• • IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CIRCUIT CIVIL DIVISION AG 
CASE NO.50-2019-CA-014681-XXXX-MB 
CA FLORIDA HOLDINGS LW PUBLISHER OF THE PALM BEACH POST, 
Plaintiff/Petitioner 
vs. 
DAVE AROINI13ERG, 
SHARON R BOCK, 
Defendant/Respondents. 
ORDER GRANTING DEFENDANTS MOTIONS TO DISMISS COUNT II OF 
PLAINTIFF'S FIRST AMENDED COMPLAINT WITH PREJUDICE 
THIS CAUSE came before the Court on Dave Aronbe SatimAitomey of Palm 
Beach County's ("State Attorney") and Sharon R. Bock, as e orrptroller of Palm Beach ? 
County's, ("Clerk") respective Motions to Dismiss CottQt rBf A Florida Holdings, LLC, 
Publisher of the Palm Beach Post's ("The Post") 
case is assigned to Division AG, which is c 
Hafele. However, the undersigned, as 
ed Complaint (DE## 22, 24). This 
ded over by the Honorable Donald 
e of the Fifteenth Judicial Circuit, presided 
over the June 3, 2020 hearing on the State Attorney and Clerk's Motions as the Motions 
implicate records of the Palm each Connty grand jury, over which the Chief Judge presides. 
See § 905.01, Fla. Stat. (2019). r careful consideration of the pleadings and the arguments 
presented at the hearing, ourt grants the Motions for the following reasons. 
Background 
The Post a outlet which has heavily reported on the 2006 Palm Beach County criminal 
pros effrey Epstein. Through the instant civil lawsuit, The Post seeks "immediate 
access testimony, minutes, and other evidence presented in 2006 to the Palm Beach 
County grand jury" in Mr. Epstcin's case and alleges that both the State Attorney and Clerk are 
"in possession and/or control of [those] documents." (DE # 17, First Arrtnded Complaint at 11 
3,4, and 77). Specifically, The Post seeks declaratory judgment as to its rights to obtain the 
grand jury testimony in Mr. Epstein's case from the State Attorney and Clerk (Count 1) as well as 
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Case No.50-2019-CA•681-XXXX-MB 
judgment against the State Attorney and the Clerk pursuant to section 90527, Florida Statutes, 
which sets forth the parameters of grand jury secrecy in Florida. (Count II). Both the State 
Attorney and the Clerk move to dismiss Count II of The Post's First Amended Coniplaint, 
arguing that that section 90527 does not create a private cause of action. (DE## 22, 24). The 
Court agrees. 
Analysis 
"In reviewing a motion to dismiss for failure to state a cause of action, the court must adcept the 
allegations of the complaint as true and construe them in the light most favorable4 the plaintiff." 
Almarante v. Art Institute of Fort Lauderdale, Inc., 921 So. 2d 703, 704-05 (Fla.4tliDCA 
2006). The motion should only be granted if the moving party demonstrates that the plaintiff 
cannot provide any facts that would support a cause of action. id,=It follciWs that if the cause of 
action alleged is nonexistent under Florida law, dismissal is,wanniated. Cummings v. Dawson, 
444 So. 2d 565, 566 (Fla. 1st DCA 1984) (affirming d'g( ss of cause of action not recognized 
by Florida law). 
Section 90527, Florida Statutes (2019), is " timony not to be disclosed, exceptions," 
and states: 
(1) A grand juror, state attorneZns Cant state attorney, reporter, stenographer, 
interpreter, or any other person appearing before the grand jury shall not disclose the 
testimony of a witness examined before the grand jury or other evidence received by it 
except when required by a court to disclose the testimony for the purpose of: 
a. Ascertaining yhether it is consistent with the testimony given by the witness before 
the court; 
b. Determining whether the witless is guilty of perjury; or 
c. ,Furthering justice. 
(2) t is unlawful for any person knowingly to publish, broadcast, disclose, divulge, or 
cotnrrarnicate to any other person, or knowingly to cause or permit to be published, 
broadcast, disclosed, divulged, or commutated to any other person, in any manner 
whatsoever, any testimony of a witness examined before the grand jury, or the content, 
gist, or import thereof, except when such testimony is or has been disclosed in a court 
proceeding. When a court orders the disclosure of such testimony pursuant to subsection 
(I) for use in a criminal case, it may be disclosed to the prosecuting attorney of the court 
in which such criminal case is pending, and by the prosecuting attorney to his or her 
assistants, legal associates, and employees, and to the defendant and the defendant's 
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Case No.50-2019-CA- i4681-XXXX-MB 
attorney, and by the latter to his or her legal associates and employees. When such 
disclosure is ordered by a court pursuant to subsection (I) for use in a civil case, it may be 
disclosed to all parties to the case and to their attorneys and by the latter to their legal 
associates and employees. However, the grand jury testimony afforded such persons by 
the court can only be used in the defense or prosecution of the civil or criminal case and 
for no other purpose whatsoever. 
(3) Nothing in this section shall affect the attorney-client relationship..A client shall have 
the right to communicate to his or her attorney any testimony given by the client to the 
grand jury, any matters involving the client discussed in the client's presence before the 
grand jury, and any evidence involving the client received by or proffered to grand jury 
in the client's presence. 
(4) Persons convicted of violating this section shall be guilty of a misdemeanor of the first 
degree, punishable as provided in s. 775.083, or by fine not exceeding $5,000, or both. 
(5) A violation of this section shall constitute criminal contempt of court. 
§ 90527, Fla. Stat. (2019). 
As the State Attorney and Clerk argue and T oncedes, section 90527 
1‘
\ 
4(makes no express provision fora civil suit or civi ay. onctheless, The Post maintains that Aste
it is entitled to seek the grand jury records v riv cause of action pursuant to the "furthering 
justice" exception to grand jury sccrec c in subsection905.27(1Xc). Therefore, the 
limited question for this Court's COOSOCI3 n is whether a cause of action under section 90527 
7--  ‘- 
y 
' 
should be judicially implied. See Murth / v. N. Sinha Corp., 644 So. 2d 983, 985 (Fla. 1994). 
In advocating thatit may maintain a cause of action against the State Attorney and Clerk ii
under section 90527, The'Post urges the Court to examine three factors "(1) whether the 
plaintiff is one Of the class for whose special benefit the statute was enacted; (2) whether there 
is any any indication, either explicit or implicit, of a legislative intent to create or deny such a 
remedy; and (3) whether judicial implication is consistent with the underlying purposes of the 
legislative scheme" (Plaintiff's Opposition to Defendant, Dave Aronberg, As State Attorney of 
Palm Beach County, Florida's Motion to Dismiss Count II of the First Attended Complaint at 
page 13 (citing Fischer v. Metcalf, 543 So. 2d 785 (Fla. 3d DCA 1989)). Within these three 
factors, The Post recognizes that there is no indication of legislative intent to create a cause of 
action, but leans heavily on the benefit factor, arguing that the "furthering justice" exception to 
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Case No.50-20 I9-CA•- 468 I-XXXX-MB 
grand jury secrecy outlined in section 90527(I)(c) was meant to benefit the public at large, for 
which the press acts as a surrogate. The Post's arguments are unpersuasive as to the discrete 
issue of whether a private cause of action lies in section 90527. 
To begin with, The Post's reliance on the benefit factor is misplaced. Per the Florida 
Supreme Court's 1994 opinion in Murthy, "the question of whether a statute establishes a duty to 
take precautions to protector benefit a particular class of persons is no longer determinative on 
the question of whether a cause of action should be recognized." Sorenson v. Prof! 
Compounding Pharmacists of W. Pa., Inc., 191 So. 3d 929 (Fla. 2d DCA 2016) (citing Murthy, 
644 So. 2d at 985). Instead, "whether a statutory cause of action should be judicially implied is a 
question of legislative intent." Horowitz v. Plantation Gen. Hosp. Ltdcrsl itipi959 So. 2d 176, 
182 (Fla. 2007). See also QBE Ins. Cap. v. Chalfinte Condo. A'. en s'n, Inc., 94 So. 3d 
541, 551 (Fla. 2012) ("Since Marshy, we have reaffirmed tlyrp that whether a statutory 
cause of action should be judicially implied is a questio 
& Cas. Ins. Co. v. Loftus, 276 So. 3d 849, 851 (F 
alive intent"); Universal Prop. 
As is always the case when a court undo hakes legislative intent analysis, the plain 
language of the statute is the starting, and ciften ending, point. See Horowitz, 959 So. 2d at 182. 
"When the statute is clear and unambiguote, courts will not look behind the statute's plain 
\ *.c:language for legislative intent pr resortto rules of statutory construction to ascertain intent." 
Loftus, 276 So. 3d at 85l(Fla.41111)CA 2019))(quoting Daniels v. Fla. Dell! of Health, 898 So. 
2d 61, 64 (Fla. 2005)). "HOwever, a single part of a statute should not be read in isolation." 4/. 
/ "Instead, 'all part:kfa statute must be read together in order to achieve a consistent whole."' Id. 
c -S\,., y \(quoting ,F sythe' . Longboat Key Beach Erosion Control Dist., 604 So. 2d 452, 455 (Fla. .‘,..__) 
1992)).—, 
As The Post acknowledges, "there is a dearth of legislative history surrounding Section 
90527 and the The Palm Beach Post was unable to locate any documents capturing any 
legislative intent regarding the possibility of a private right of action." (Plaintiff's Opposition to 
Defendant, Dave Aronberg, As State Attorney of Patin Beach COunty, Florida's Motion to 
Dismiss Count II of the First Amended Complaint at page 14). While the lack of any legislative 
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Case No. 50-20 I9-CAPP468I-XXXX-MB 
history indicating an intent to create a private right of action is telling, it is not diapositive as the 
plain language of the section 90527 is clear an unambiguous and, therefore, controls. Horowitz, 
959 So, 2d at 182. 
Examining the plain language of section 90527 in its entirety which requires the Court to 
look at more than just the "furthering justice" provision of section 90527(IXc) relied on by The 
Post, it is clear that the intent of the Legislature in passing section 905.27 was to limit, not 
facilitate, disclosure of grand jury records. In no uncertain tents, the Legislature provided that 
no "person appearing before the grand jury" may "disclose" testimony or evideoCe presented 
except when "required by a court" under certain limited circumstances. §905.2.711 Fla. Stat. In 
solidifying that its intent was to prohibit disclosure without court pe gislature 
provided that disclosure without a court order is a criminal offen:s 9 (4), Fla. Stat. 
Therefore, to the extent section 90527 could be read as itrposulgrayhtyon the State Attorney 
ta‘H/2and Clerk, the duty imposed is one of secrecy, not disclos 
/-
In stun, there is nothing in the text of sectio .90 27 flint which one can deduce that the 
Legislature contemplated a member of the one else for that Matter, having a private 
cause of action to compel the State Attorney and Clerk to disclose grand jury records. Indeed, 
to the contrary, section 90527 prolibits theState Attorney and the Clerk (assuming that, as 
\/ pleaded by The Post, they a the dOeurnents) from disclosing the documents without first 
being ordered to do so by the et5uttLa Reading section 90527 as creating a private cause of 
action against the State Aitiarney and Clerk is, therefore, not only unsupported by the language of 
section 90527, but is actually paradoxical to its plain language of the statute. As such, this Court 
lacks the power to construe the unambiguous language of section 90527 in a way that would 
extenditsapreSs terms and create a cause of action where none exists. "To do so would be an 
abroga 'tiOt of legislative power." Horowitz 959 So. 2d 176. 182 (quoting Holly v. Auld 450 So 
2d 217. 219 (Fla. 1984)1 
Conclusion 
Based on the foregoing, the Court funds Count II of The Post's First Attended Complaint 
must be dismissed with prejudice as it pursues a nonexistent cause of action under section 
Page 5 of 7 
CA/ArOppeR5991.3all AINI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735936

Case No. 50-2019-CA- 14681-XXXX-MB 
90527. In arriving at this conclusion, the Court does not suggest The Post has no available 
mechanism to obtain a court order granting it access to the grand jury proceedings. The Court 
also does not render any opinion as to whether releasing these records is appropriate for the 
purpose of "furthering justice" within the meaning of section 90527. Rather, the Court's 
dismissal of Count Il is necessitated by precedent and the simple fact that a civil lawsuit against 
the State Attorney and Clerk under section 905.27 is not the proper mechanism for The Post to 
pursue its goal. 
Therefore, it is hereby 
ORDERED AND ADJUDGED that Dave Aronberg, as State Attorney bf Palm Beach 
County's and Sharon R. Bock, as Clerk & Comptroller of Palm BeachCounly's; respective 
Motions to DismiSs Count TI of CA Florida Holdings, LLC, Publisher of the Palm Beach Post's 
First Amended Complaint arc GRANTED and Count II ofPlaintiff's first Amended Complaint is 
A \ 
DONE AND ORDERED, in West Palm Beieft Patin Beach County, Florida this 8th day 
ST\(  
hereby DISMISSED with prejudice. 
of June, 2020. 
) 
10;25 .1eaki0146 :950. 0 p124.120 
Isti'M au( aCtilin yap 
_ 
50.2019.CA.014681..XX X X-MB 06/08/2020 
Krista Man 
Chief Judge 
al The Court notes that, if there was a court order directing the State Attorney or the Clerk to 
disclosereeords and the State Attorney or the Clerk refused, the remedy for disobeying a corm order 
is contempt or, in some instances, a mandamus proceedings — not a civil lawsuit. 
COPIES TO: 
DOUGLAS A. WYLER 
No Address Available 
961687 GATEWAY BLVD 
SUITE 201-I 
FERNANDINA BEACH, FL 
Page 6 of 7 
No E-rrnil Address Available 
doug.wylen@corrcastnet 
CA/Aropit  laWRIA 80. rett.m BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735937

Case No. 50-20 I9-CA.681-XXXX4v1B • 32034 
MICHAEL GRYGIEL 54 STATE 'STREET 
6TH FLOOR 
ALBANY, NY 12207 
No Address Available 
POST OFFICE BOX 229 
WEST PALM BEACH, FL 
33401 
MICHAEL J. GRYGIEL 
NICOLE R. FINGERHUT 
NINA p.poy.AnAN 
NINA D. BOYAJIAN 
STEPHEN A. 
MENDELSOHN,. ESQ 
No. Address Available 
1840 CENTURY PARK 
EAST 
SUITE 1900 
LOS ANGELES, CA 90067 
5100 TOWN CENTER CIR 
SUITE 400 
BOCA RATON, FL 33 
Page 7 of 7 
GRYG1ELM®GTLAW.COM 
[Email Redacted] 
CLERK & 
SERVICE@MYPALMBEACH 
CLERK_COM 
rifingerhut@mypalmbeacliclerk 
corn 
boyajann@gdaw 
riveiaal@gtla 
No E.-mail( a vailable 
elsolms®gtlaw.com 
®gdaw.com 
rvice®gdaw.com 
CA/Ar°P1c11-95NAVI BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735938

• • 
Def.Ex.A-8 
• (S. 
0..PM  BEACH CO., .1211.0, CLERK 31.13.3 1:49:29 PM 
EFTA02735939

• • 
TIC. LAW. OFFICES OF 
ASSOCIATEC.P:A. 
ARTHUR,. 
SCHOLZ LLC. 
A 
Lo. A LIMI LIASIUTY.  COMPANY or PROIC.,SIONAL ASSOCIATIONS 
ATTORNEYS AT LAW 
GATEWAY TO AMELIA ' 
9SISS7 GATEWAY SLVD.. SUITE COI.! 
FEatimainin BEACH. FLORIDA 32034 
TELEPHONE (OOA) ESI-369S 
nx NO. (110.) 261.7679 
June 8, 2020 
VIA ELECTRONIC & U.S. MAIL 
Stephen A. Mendelsohn, Esq. 
Greenburg Traurig, P.A. 
5100 Town Center Circle, Suite 400 
Boca Raton, FL 33486 
RE: CA Florida Holdings, LLC v. Dave Aronbe 
Palm Beach County, Case No.: 2019-CA-0 
Dear Mr. Mendelsohn: 
RICHARD J. SCHOLZ. P.A. 
RICHARD J. SCAOLZ 
DOUGLAS A. WYLER, P.A. 
DOUGLAS A. WY1.04 
A Co's 
As you are aware our firm represents the inteteg f Aronbergi as State Attorney of Palm Beach 11 ,
County, Florida, in the above referenced matt u se of this letter is to demand the voluntary 
dismissal of your First Amended Complaint, "Co plaint"), dated January 17, 2020. This demand 
is made pursuant to section 57.105, Florj 
As you know, Section 57.1 
(I) Upon the court's ttiitiat vT or motion Of any party; the court shall award a 
reasonable attOme , including .prejudgment interest, to be paid to the 
prevailing p equal amounts by the. losingparty and the losing-party's attorney 
on any clai nse at any time during a civil proceeding or action in which 
the c find I. at the losing party or the losing party's attorney knew 9r should 
hav own that a claim or defense when initially presented to the court or at any 
trial: 
as not supported by the material facts necessary to establish the. laith Or 
defense; or 
b. Would not be supported by the application of then-existing' law to those 
material facts. 
Today; Judge Marx granted, with prejudice, Defendant Aronherg's Motion to Dismiss Count II of the 
Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action 
consists of Count I, foeDeclaratory Relief. Accordingly, we believe that the Complaint filed herein 
and its sole remaining Count for DeclanitorY Relief is not supported by the Material facts necessary to 
establish the claims asserted, and that your claims are not supported by the application of current law 
to said. material facts. 
CAlitm i liat tna l iel BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735940

• • 
First and foremost, the Complaint is not supported by the material-facts necessary to establish the 
claims asserted because neither Defendant Aronberg, nor The Office of the State. Attorney for the 
Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein. 
Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are 
impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to 
this action because no matter what, he.and his office do not have possession, custody, or control of the 
requested materials. 
In addition.to the foregoing material facts that negate the claims asserted, in, the Complaint, your claims 
are also not supported by the application of current law.. Specifically, your action for dec tory relief 
fails based on the clear, unambiguous statutory language found in Section 905.27(2), i a Statutes, 
which states: 
When such disclosure is ordered by a court pursuant to subsection (1) 
case, it may be disclosed Wall Parties to the case and to their attom 
to their legal associates end employees. However the grand i 
such persons by the court con only be used in the defense or two utish 
criminal case and for no other purpose whatsoever. 
Moreover, even if the Plaintiff Were to prevail in the declarat 
to comply with any court order granting disclosure of t 
Aronberg• nor The Office of the State Attorney for 
custody, or control of the 2006 Epstein grand jury 
Based on the foregoing, if the Complaint is n 
the enclosed Motion for Attorney's Fees wi 
and yout firth, recovery of the legal ex 
Please govern yourself accordingl 
At A —
Douglas A. Wyler, Esq. 
For the Firm 
Encl.: Defen 
IC
civil 
e latter 
afforded 
of the civil or 
r. Aronberg would be unable 
documents because neither Mr. 
Judicial Circuit have possession, 
within 21 days of the service of this letter, 
nd we will seek as sanctions, from yourclient 
Inc d in defending this frivolous action.. 
Motion for Attorneys' Fees 
CA/Arotahero c0G 385. t !Lev: r iAtdm BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735941

IN THE CIRCUIT COURT OF pj :EIFitiNtH JUDICIAL CIRCUIT • 
IN AND FOR. PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
v. 
• 
DAVE AkONBERG, as State Attorney of 
Palm Beach County; Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
CASE NO.:19-C -014081 Abet 
O 
ItDEFENDANT, DAVE ARONBERG'S MO ,ATTORNEYS' FEES 1/40
Defendant, DAVE ARCINBERO, as Stat n f Palm Beach County, Florida, by and 
through the undersigned attorneys, moves ursuant to 'Florida Statutes, Section 57.105, 
tto award' him reasonable attorneys' f r th defense of Plaintiff's First Amended Complaint, 
(the "Complaint"), and as ?nun 
a copy of this Motion, top 
Would show that on June 8, 2020, Plaintiff was served 
a letter from the undersigned attorney, in accordance with 
subsection (4) oldie a Statute, demanding dismissal of the Complaint, at.least .21 days.prior It
to the filing of s li . In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish. t plaint is without support of the facts or the law. 
FORE, Defendant, DAVE ARONBEriG, as State Attorney of Palm Beach 
County, lorida, respectfully reqtaests the Court enter an Order requiring Plaintiff and Plaintiff's 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 
CAlArlt eErteM1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735942

CERTIFICATE OF SERVICE 
I hereby certify that on this day •, 2020, the foregoing was electronically filed 
via the Florida E-File Portal for electronic service on the parties of record herein. 
SCHOLZ & WYLER, LLC 
Is/ Douglas A. Wider 
Arthur I. Esquire 
Fla. Bar No.: 108249 
Richard J. Scholz, Esq 
Fla. Bar No:: 002126 
Douglas A. Wyler 
Fla. Bar No.: 11 
961687 Gatewa , Suite 201-I 
Femandina BQch, orida 32034 
(904)2 '69 
(901k" 
aw®comcast.net 
44S4. ys for Defendant 
CNArotter.900138 rtall BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735943

• • 
Def.Ex.A-9 
C... .WM BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2. I:49.n pm 
EFTA02735944

• GT GreenbergTraurig 
Stephen A. Mendelsohn 
lel 561.955./629 
Fax [Phone Redacted] 
mendelsohnslagtlaw.com 
June 23, /020' 
Douglas A. Wyler 
Jacob Scholz do Wyler, LLC 
961687 Gateway Blvd. 
Suite 201-I.
Fernandina Beach, Fl. 32034 
Re: CA Florida Holdings, LLC v. Dave Aronberg et al. 
Case No. 1019-CA-0146H 
Dear Mr. Wyler: 
We are in receipt of your letter of/tine 8, 2010 with yo 
In your letter and your proposed motion, you ass 
firm of Greenberg Traurig, P.A.. should he liab 
Attorney Aronberg alter the date of your I 
(a) and (b) for support. As shown below, 
and we expect that if the State Attorne 
Your fetter ornits a citation to s 
may not be awarded, where 
reversal of eisisfinglaw or the 
a reasonable expectation of su 
A &As 
Fla. gtat. section 57:105 motion. 
orida Holdings; LLC and the law 
attorneyS' fees to be incurred by State 
tter cites to Ha. .Stet. sections 57.105(1) 
no 'basis for a FM. Stat:section 57.105 motion, 
e such a motion, the court should deny it. 
!(3). Subsection 57,105(3)(a) provides that sanctions 
ood faith argument for the extension, modification or 
&haft of hew law, as it it apPliedlo the material facts, with. 
We have such a good faith argument. 
Contrary to your alysi f la. Stat. section 905.27, there are actually three instances where a 
court may order relea  of grand jury materials. As we argue, the court. may order release "in 
furtherance o ti. " There are few cases in Florida reviewing this provision and its. scope. It is 
an open ah va 1 qu tion as to whether the toxin may Order teldate of grand _limy it:kiwi -pa ki 
them h the statute and the FirstAmendinent to the US Constitution in furtherance 
e statutory language you cite refers to instances where a person is seeking grand jury 
materi for use in a civil or in a criminal case. In these limited situations; •the statute allows for 
such us and for no other reason. However, the statute does not state, as you assert, that where 
the media seed grand jury materials based upon its constitutional standing, which the Circuit 
Court acknowledged at. the June 2, 2020 heating includes The Palm Beach Post, that the statutory 
Greenberg Tratulg. P.A. I Attorneys at Law 
5100 Town adder Orcle I Suite 400 lama Raton. Florida 33486 I T 41 [Phone Redacted] Fe'l [Phone Redacted] 
Albany. Amsterdam. Atlanta. Austin. Berlin: Boa Raton. Boston. Chimp. Dallas. Delaware. Deaver. Foil Laudaidaln Houston. Lis Vegas. London! Los Angeles. 
Mateo City: Miami Hinneaphlis. Nashville. New Jersey. New York. Horniest Virginia. Orange County. Orlando. Philadelphia. Phoenix. Sacrament,. 
San Frandsen Seoi.,Shangbal Sutton Valley. Tallahassee. Tampa. Tel anir:Tokyo: Wmar:Warbiagton, D.C. West Palm Beach. Westchester County. 
"veutetteeteae-tet —. "eel weeeeree.e-t- - 
view glow oxn 
CAJAroppeaf19,1.189. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735945

Correspondence to Douglas A. Wyler 
June 23, 2020 
Page 2 
use limitation you cite applies. No reported Florida case has addressed this issue and there is a 
good faith basis for our view of Fla. Stat. section 903.27 
Your letter also argues that sanctions are applicable because the State Attorney has alleged that it 
does not possess the Jeffrey Epstein grand jury transcripts. This allegation is also contained in the 
State Attorney's Answer. ASS-timing that the. State Atuatty does not currently kW physical 
possession of the Epstein grand jury materials, which has yetto be demonstrated, this not end 
the matter. The State Attorney was named as a party not simply as a custodia jury 
records. The State Attorney was named in his official capacity as his office has its rimaty 
interest the protection of its grand jury system."'[Italics in original.] In re Grand Jury Proceedines, 
832 F. 3d 554, 559 (11° Circuit 1987). In that cast, the US petitioned at to ju ge to order the 
State Attorney to turn over grand jury transcripts. The State Attorney rtheir release 
citing to Fla. Stat. section 905.27. Later, a federal grand jury sub e Broward County 
State Attorney for delivery of state grand jury testimony. The B Attorney advised the 
federal court that it would produce the transcripts, thereby ling that while it may not' 
have phytical possession of the materials, he had legal a Obtain and deliver them. It 
should also be rioted that the State Attcitney.moved t subpoena arguing that it was 
unlawful under Florida law and Fla.. Stat. section 905 indicates that where one seeks 
grand jury materials, the relevant State Attorney i party in order 'to protect the grand 
jury that the Office of State Attorney supervi e arguments, if need be, against release 
of the grand jury materials. These are some sa ns why the State Attorney was named 
in this case. 
Also, assuming the State Attorney ye physical possession of the grand jury materials, 
there is nothing in Florida law is the State Attorney from requesting that the Clerk 
provide.copies to the State Att.. pter 905, Fla. Stets. does not contain a prohibition against 
a State Attorney demand that i grant his office access to grand fr y materials, even after a 
criminal case has concl ed. Upon. information and belief, the Clerk's office maintains a log that. 
tracks release of grand terials to the State Attorney upon its request. Please confirm 
whether the State ttom has accessed grand jury materials from the Clerk's office in other 
instances or dr as never done so. If the Clerk has such a log, then its contents should be 
discoverablg, ub to Florida Public records laws. O 
Greenberg Tranrig. P.A. I Attorneys at Law 
vms.gPinv.can 
CA/Arop lie/09,1 A BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735946

• Correspondence to Douglas A. Wyler 
June 23, 2020 
Page 3 
For these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed 
against the Office of the State Attorney. We expect that your demand will be withdrawn. 
Thank you, 
Very truly yours, 
/s/Stephen Mendelsohn 
Stephen Mendelsohn 
SAM:ls 
ACTIVE 51108I659v/ 
Greenberg Tranrig. P.A. I Attorneys at Law 
cos 
wswatlew.can 
CA/ArofteR 59913R1. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735947

• • 
Def.Ex.A-10 
couna, mz.o. 1:49:39 PM 
EFTA02735948

• 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
v. CASE NO.: I9 -CA- 14681 
CO S
DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigied attorneys, moves th suant to Florida Statutes, Section 57.105, 
to award him reasonable attorneys' f the fense of Plaintiff's First Amended Complaint, 
(the "Complaint"), and as groun o 4 ould show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, togeth wi a letter from the undersigned attorney, in accordance with 
subsection (4) of the above Aiptute, demanding dismissal of the Complaint, at least 21 days prior 
to the filing of thie Motion: In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish that the Cothplaint is without support of the facts or the law. 
REFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach 
County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 
DAVE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
CAbe1/49- 41:LeErVilaVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735949

• 
ciRl'IFICATE OF SERVICE 
I hereby certify that on this. 1st day July, 2020, the foregoing was electronically filed via 
the Florida E-File Portal for electronic service on the parties of record herein. 
SCHOLZ & WYLER, LLC 
Is/ Douglas A. Wyler 
Arthur 1. Jacobs, Esquire 
Fla. Bar No.: 108249 
Richard J. Scholz, Esquire 
Fla. Bar No.: 0021261 
Douglas A, Wyjer, 
Fla. Bar No.: 11 
961687 Gateway d uite.2014 
Ferriandin F orida 32034 
(904) 26 
(904 
Ns 
suncast.net 
"cts v n ib?. Defendant, Dave Aronberg 
CA/Arc/PIM/Ma BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735950

• • 
CNAMPtE. EVRIVI BEACH cowry, EL, ABRUZZO, CLERIC 3,8/2023 1:49:29 PM 
EFTA02735951

IN THE CIRCUIT COURT OF THE.FIFTEENTH. JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
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. 
CASE NO.: 19-CA-014681 
cos 
DEFENDANT DAVE ARONBERG'S MOTION FO MARY FINAL JUDGMENT 
AND MEMORANDUM OF LAW IN wr THEREOF 
Defendant DAVE ARONBERG, as St' l of Palm. Beach County, Florida, 
(hereinafter. "Arenberg"), by and through cou be d pursuant to Rule 1,51.0:Florida Rules of' 
Civil Procedure, moves for entry of su mal judgment in his favor as to the remaining claim for 
Declaratory Relief in Plaintiff's F' Complaint', and in support thereof states as follows:.
STAT ME OF THE UNDISPUTED FACTS 
The following is nt of facts material to this motion for summary judgment as to which 
there is no genii issue: 
1. nt of Plaintiff's First. Amended Complaint, (hereinafter "Complaint"), filed 
Janua , seeks Declaratory. Relief pursuant to Section 86.011, Florida Statutes. 
Specifically, Plaintiff's Count 1 seeks a court order "declaring that pursuant to Ha Stat. 
Section 905.27(IXe) and the Court's inherent authority, The Pafin !leach Post may gain access to the 
testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand. jury" that 
I On June 8, 2020, thisCourt entered its Order Granting Defendants Motion to Dismiss Count II of the Plaintiff's First 
Amended Complaint with Prejudice. 
CA/Aroppegb09,1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735952

• • 
was empaneled during the first. Jeffrey Epstein, (hereinafter "Epstein"), sex abuse investigation. 
(hereinafter "Requested Materials"). Complaint pg. 20 
3. Plaintiff seeks to use the Requested Materials "for the'purpose of informing the public." 
Id. 
4. Plaintiff seeks the above-referenced declaratory relief, including copies of the 
Requested Materials, from both Aronberg, as State Attorney of Palm Beach Connty4jda, and 
(11‘14 ,Defendant, Sharon R. Bock, as Ckrk and Comptroller of Palm Beach County, Plod ereinafter the 
"Clerk"). 0 5. Neither. Aronberg nor the. Office of the Sulk Attorney for Fi fl nth Judicial Ciretlit, 
("SAO"), is.in control, custody„ or possession of the Requested I Arenberg Aff 13, attached 
as Exhibit "A". 
6. The declaratory' elief sought by the3i tiff etks materials that are impossible for 
Aronberg or the SAO to produce. Exhibit "A.(" N, 1c #
7. Neither Arenberg nor th Q ha .the legal authority to obtain and/or deliver The 
Requested,Materials. Exhibit "A" 
8. The undisputed is t forth above in paragraphs 6-7 have been repeatedly made 
evident by Arenberg tot aintiff and the public thltaigh not only the pleadings and correspondence 21  
h.r in this matter, bu, t On office press release and Aronberg'spublic social media accounts. 
Exhibit "A" 
then Aronberg nor the SAO has the authority to demand that the Clerk grant the 
SAO ac s to grand jury materials after a criminal case ha's concluded. Exhibit "A" ¶ 7. 
IQ. During Arenberg's administration, neither he nor his office has accessed grand jury 
materials from the Clerk's office in this or any other instance. Exhibit "A" ¶ 8. 
2 
cAffir TIMNI 1/4114 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735953

• • 
II. As provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody 
and possession of the Requested Materials, which can only be released by the Clerk pursuant to an 
order of the Court. Exhibit "A" 99. 
MEMORANDUM OF LAW 
I. Legal Standard Governing Motions For Summary Judgment 
1.510, Fla. R. Civ. P. It is appropriate to resolve a declaratory action on 
here, the decree seeks a legal interpretation of a statute. Rahimi 
So. 3d 804 (Fla. 5th DCA 2018). 
II. The Requested Materials Can Only Be ReaSS  The Clerk Pursuant To A Court 
Order 
Notably, neither Aronberg nor the SAO is in control, custody, or possession of the Requested 
Materials. Exhibit "A" 1 3. Nonethe s, ant to Section 905.27(1)(c),. Florida Statutes and the 
Court's inherent authority, Plai L iff se court order declaring that Aronberg provide copies of the 
"The judgment sought shall be rendered forthwith if the pleadings, depositio swers to 
interrogatories, and admissions on file together with the affidavits, if any, show that this no genuine 
issue of material fact and that the moving party is entitled to a judgment of law." Rule 
judgment when, as 
Discoveries, Ltd., LLC, 252 
Requested Materials to The Pa l h Post for the purpose of informing the public. Complaint pg. 
20-21. Plaintiff is seekthg' declaratory relief alleging its entitlemeni to the Requested Materials 
pursuant to the Ahering justice" exception to grand jury secrecy. § 905.27, Fla. Stat. (2020). 
Eteispite ringing its declaratory relief claim pursuant to Section 905.27, Florida Statutes, "a 
singl€pattofa statute should not be read in isolation." Universal Prop. & Cas. Ins. Co. v. Loftus, 276 
So. 3d 849, 851 (Fla. 4th DCA 2019). "Instead, 'all parts of a statute must be read together in order to 
achieve a consistent whole.'" Id. (quoting Forsythe v. Longboat Key Beach Erosion Control Dist, 
604 So. 2d 452, 455 (Ha. 1992). 
3 
CAMK TPLeff 5993a1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735954

Section 905.17(1), Florida Statutes makes clear that grand jury records, like the Requested 
Materials in this matter, are to be maintained with the Clerk, and can only be released by the Clerk 
pursuant to a court order TO Wit 
The stenographic 'records, holds, and transeriptiods made by the court reporter or 
stenographer shall be filed with the clerk who shall keep them in a scaled container not 
subject to public inspection. The notes, records, and transcriptions are confidential 
and exempt from the provisions of s. 1.19.07(1) and s. 24(a). Art I of the St e. 
Constitution and shall be released by the clerk only on request by a grand jury 
by the grand jury or on order of the court pursuant to s. 905..27. 
Section 905.17(1); Florida Statutes (2020). (Emphasis added.) 
Text, context, and purpose are the ordinary tools used. for disce ng sta . meaning, with 
the overarching principle being "that judges lack the power to co an ambiguous statute in a 
way which would extend, modify, or limit its express terms or le and obvious implications. 
To do so would be an abrogation of egislative power." e plain language of section 905.17 
is clear and unambiguous and, therefore, controls. 4 lour v. Plan:O&M Oen. flop, Ltd. P'slio, 
959 So.. 2d 176, 182 (Fla. 2007). 
Accordingly, based on the clew ous statutory language set forth in section 905.17(1), 
Only the Clerk, not the State A release grand jury materials-pursuant to an order of the 
court. Thus, it is apparent that A g and the SAO lack the legal authority 'to obtain and.deliver the 
Requested Materials. Ex " 15. Likewisel the declaratory relief sought.by the Plaintiff seeks 
materials that a ible for Aronberg or the SAO to produce. 'Exhibit "A" 1 4. Again, the Clerk. 
has sole d possession of the. Requested. Materials. These facts have been repeatedly made 
evid- berg to the Plaintiff and the.public through not only the pleaditigs and correspondence 
in this matter, but also thittigh an office presS release and Atonberfs public social Media accounts. 
Exhibit "A" 16. 
Although the above-referenced statutory authority illuminates the fact that only the Clerk may 
release grand jury records lilcethe Requested Materials herein, it remains signi (leant to note that neither 
4 
CA/AroneR 551.392. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735955

• • 
Aronberg nor the •SAO has the authority to demand that the Clerk grant the SAO access to grand jury 
materials after a criminal case has concluded. Exhibit "A" 1 7. Hence, during Aronberg's 
administration, neither he for his office has accessed grand jury materials from the. Clerk's office in 
this or any other instance. Exhibit "A" 1 8. 
III. Conclusion 
The ultimate facts underlying the lawsuit are not in dispute. The Court is fully were(' to 
dispose of this matter based on application of the undisputed facts to the plain Ian e of Section 
905.17, Florida Statutes, which renders the Plaintiff's action for'declaratory possibility for 
Aronberg to perform and that must be denied as a matter of law. 
WHEREFORE, Defendant, DAVE ARONBERG, as S Att. of Palm Beach County, 
Florida, respectfully requests that this motion be granted 
in his favor consistent' ith this motion, and hereby 
Complaint with prejudice and grant such.other 
deems fit and proper under the *cut -milt 
mary final judgment be entered 
requests that this Court dismiss the 
ding attorney's fees and costs, as this Court 
I HEREBY CERTIFY 18th day of August, 2020, a copy of the foregoing has been 
electronically filed with otida E-File Portal for e-service on all parties of record herein. tic5 pLer
+6s
5 
SCHOLZ & WYLEFt, L.LC. 
/s/ Douglas A. Wyler 
Arthur
Fla. Bar No.: 10249 
Richard J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq, 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Femandina Beach, Florida 32034 
([Phone Redacted] 
([Phone Redacted] Fax 
Primary: [Email Redacted] 
CAffirt)PrELE9MS1 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735956

General Counsel for :1/4  Honda Proseiming 
Attorney's Assatiorion 
6 
CNA BEACH COUNTY, FL, ABRUZZO, CLERIC 3/2842023 1:49:29 PM 
EFTA02735957

• • 
EXHIBIT "A" 
EXHIBIT "A" 
CA/AmpbetaaKMA0a ILETE rALm BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735958

• 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
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. 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
CASE NO.: 19-CA-01468 I 
C O S
AFFIDAV OF DAVID ARONB s, 
I. /.." APS My name is David (Dave) Arenberg, a am the State Attorney for the Fifteenth Judicial 
Circuit/Palm Beach County, Florida, since 2013, and a Defendant in the above-captioned matter. 
2. Plaintiff is seeking declaratory relief, pursuant to Fla. Stat. 905.21(I)(c) and the Court's 
inherent authority, allowing Plaintiff access, to the testimony, minutes, and other evidence presented in 2006 
to the Palm Beach County grand jury, (the "Requested Materials"), and to use those materials for the 
purpose of informing the public. 
3. Despite Plaintiff's above-described action for declaratory'relief, neither myself nor the 
Office of the State Attorney for the Fifteenth Judicial Circuit, ("SAO"), is in control, custody, or possession 
of the Regorge' aterials. el y,
(...) such, the declaratory relief sought by the Plaintiff seeks materials that are impossible 
for* my. ffice to produce. 
- z s - - - 5. To be clear, neither myself nor the SAO has the legal authority to obtain and deliver the 
ReqUested Materials. 
6. I have repeatedly made these facts evident to the Plaintiff and the public through not only 
the pleadings and correspondence in this matter, but also through an office press release and my public 
social media accounts. 
Before me, the undersigned authority personally ap ARONBERG, being first duly sworn, 
states: 
CA/Aropharcienntman. n_712.WPAL1V1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735959

7. Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to 
demand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded. 
8. Moreover, during my administration, neither myself nor my office has accessed grand jury 
materials from the Clerk's office in this or any other instance. 
9. As provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody and 
possession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the 
Court. 
FURTHER AFFIANT SAYETH NAUGHT. 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
Syectrn to and subscribed before me this. 3 
Cpersonally known)to me or has shown 
By: 
20, by DAVID ARONBERG, who is 
as personal identification. 
C ciame  talleidoen4
Public d Notary's Stamp or SAInitt  LATosiatownxica
eals e carrosiscesrmu 
s 0 Wen sane °to m e. Naiad alitasIplie lot 
cAlAr 9 311W590 1/41196 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735960

• • 
DeLEx.A-12 
EFTA02735961

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
v. CASE NO.: 19-CA-014681 
DAVE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
AFFIDAVIT OF DAVID ARONB 
states: 
"' PPS 
Before me, the undersigned authority personally a ARONBERG, being first duly sworn, 
I. My name is David (Dave) Arenberg, a  am the State Attorney for the Fifteenth Judicial 
Circuit/Palm Beach County, Florida. since 2913, and a Defendant in the above-captioned matter. 
2. Plaintiff is seeking declaratory AM', pursuant to Fla. Stat. 905.21( I Xc) and the Court's 
inherent authority, allowing Minaret:Cass to the testimony, minutes. and other evidence presented in 2006 
to the Palm Beach County grand jury, (the "Requested Materials"), and to use those materials for the 
purpOse of informing the public. -2
3. Despite plaintiff's above-described action for declaratory. relief, neither myself nor the 
Office of the State Attorney for the Fifteenth Judicial Circuit, ("SAO"), is in control, custody, or possession 
of the Requ(st-Vaterials. 
. a rauch, the declaratory relief sought by the Plaintiff seeks materials that are impossible 
for -any, Rice to produce. 
-S. To be clear, neither myself nor the SAO has the legal authority to obtain and deliver the 
Reqbested Materials. 
6. I have repeatedly made these facts evident to the Plaintiff and the public through not only 
the pleadings and correspondence in this matter, but also through an office press release and my public 
social media accounts.
CA/Aronbata:00, 40,6 run/ ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735962

7. Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to 
demand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded. 
8. Moreover, during my administration, neither myself nor my office has accessed grand jury 
materials from the Clerk's office in this or any other instance. 
9. As provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody and 
possession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the 
Court 
FURTHER AFFIANT SAYETH NAUGHT. 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
Sworn to and subscribed before me this Dud 
personally knowino me or has shown 
Br 
0, by DAVID ARONBERG, who is 
as personal identification. 
a(  Public 
doriot
Notary's Stamp or Seal, tArCrsitatoirrE0000E 
'3464: ea , myna mit 
cansmasearts 
Icg nes
CA/Aroppity930 ar lA4aLivi BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735963

• • 
CNAIVEHIB9RM BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 I:49:29 PM 
EFTA02735964

Filing it 115383.434 E-Filed 10/21/204 04:13:35 PM.
CA FLORIDAHOLDINGS, LLC, 
Publisher of THE piamBEACHPOST, 
Plaintiff; 
v. 
DAVE ARONBERG, a State Attorney of 
Palm Beach CoUntY, Florida; SHARON R. 
BOCK,- as clerk and Comptroller of Palm 
Beachtounty, Florida, 
. .• Defendants. .. 
• 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT DI AND' 
FOR PALM BEACH COUNTY, FLORIDA 
CASa NG.: 504010-CA-014681-X3CX;c7Ivia 
DIVISION: AG 
PLAINTIFF CA HOLDING • NOTICE OF DROPPING STATE ATTO E ARONBERG 
Plaintiff; ck HOLDINGS, LLC, pursuant to F . R. b), herebytnorifies the panics that 
,it has dropped State Attorney, Dave Aronber ihec ve case. 
* .espectfully subMitted, 
GREENBERG TFtAURIG, Attorneys for CA Florida Holdings, LLC, Puhlishei,
of the Polly Beach Post 
Stephen A. Mendelsohn, Esq. 
401 East Las Olas Boulevard Suite 2000 
Boca Raton, Florida 33.486 
Telephone: ([Phone Redacted] 
Facsimile: ([Phone Redacted] • 
By: /v/ Stephen A. Mendelsohn 
STEPHEN A: MENDELSOHN. 
Florida BarNo. 849324 
mendelsohnVkutlaw.com 
sinithlactlaw.coria 
FLServiccectlaw.com 
• 
CA/AmPtieLE9599411901 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735965

By: Isl Michael J Gneziel 
MICHAEL J GRYGIEL 
(Admitted Pr6 Het Vice) 
54 'State St., 6th Floor 
Albany, NeW York 12207 
Telephone: ([Phone Redacted],
Facsimile:: (5.18) 689-1499 
givgielmggtlaw.coin 
By: /s/ Nina D. Bovaiian 
NINA D. BOYAJIAN: 
(Admitted Pro Hoc Yice) 
1840 Century Park East, Suite 
Los Angeles California 90067 
Telephone: (310) 586-77 
Facsimile: (310) 586-78 
vaiianntTetlaw.coin 
CERTIFICATE OF SE 
I HEREBY CERTWY tha; on this 21u to re, 2020, a true and correct copy of the 
foregoing has been filed with the Clerk.of dFje ourt g the State of Florida e-filing system, which 
will send a notice of electronic servi 
ACTIVE 5331734M 
/s/ Sienhen A. Mendelsohn 
STEPHEN AyMENDEL50HN 
CA/Ampt etignlA BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735966

• • 
Def.Ex.A-14 
CJ 
CAMI‘t entiM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735967

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY!.FLCIRIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
v. CASE NO.: 19-CA-014681 
DAVE ARONBERG, as State Attorney of 
Palm Beach. County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
co DEFENDANT DAVE ARONBERG'S AMENDED MOTI FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Att m Beach County, Florida, by and 
.4\Through  undersigned counsel, hereby moves _t Itle Court, pursuant to Rule 1.525, Fla. 
R. Civ. P. to enter an award of attorneys 
HOLDINGS, LW, publisher of th, 
following: 
SC R)A%VARDING ATTORNEYS' FEES 
in . is favor against Plaintiff, CA FLORIDA 
ACH POST, and, in support thereof states the 
I. On A ovenilfer 14,2019, CA FLORIDA HOLDINGS, LLC, publisher of the PALM 
BEACH PO tiff") filed a complaint apinst DAVE ARONBERG, as State Attorney of 
Palm ou ty, Florida (the "State .Attomey" or."Defendant.Aronberg") and SHARON R. 
BOCK, s Clerk and.Comptroller of Palm Beach County, Florida (the "Clerk"). The basis of the 
action was asking the Court to order the State Attorney and the Clerk to diseloSe the 2006 Jeffrey 
Epstein grand jury materials, (the "Requested Materials"), pursuant to § 905:27(1) FM. Stat. 
CA/Aroptey99, ALM2.141  BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735968

• • 
2. On December 6, 2019, the State Attorney filed his Motion to Dismiss, then on 
December 13, 2019, the Clerk also filed a Motion to Dismiss. In response, Plaintiff filed its First 
Amended Complaint on January 17, 2020, which in addition to its original claim under § 905.27 
Fla. Stat. (Count II) added a claim for Declaratory Relief (Count I) that sought an ordcr declaring 
that the State Attorney and the Clerk disclose the Requested Materials to Plaintifftot th purpose 
of informing the public. 
C eS )3. On January 24, 2019, both the State Attorney and the Clerk 
r 
' Answer to 
the First Amended Complaint and Motion to Dismiss Count 11 ("Ans*er ' n to -Dismiss). 
Notably, the State Attorney's Answer/Motion to Dismiss assertecLits right to attorneys' fees for 
defending the action and requested such relief from the Court. 
4. On June 8, 2020, the Court entered its Order.Granting Defendants Motions to 
/.• Dismiss Count II of Plaintiff's First Amended CcImplatrit with Prejudice ("Order"). 
5. Immediately following the Court's Order, on June 8, 2020, the State Attorney, 
_ 
through the undersigned counsel, served Plaintiff with a demand pursuant to § 57.105 Fla. Stat., 
to voluntary dismiss/withdraw the First/Amended Complaint and the claims against the State 
Attorney, along with a Motion -for Attorneys' Fees ("57.105 Demand"). See, Exhibit "A". 
Specifically, because of e Court's Order only Count I of Plaintiffs Amended Complaint 
remained, whic sought Declaratory Relief under § 86.011, Fla. Stat. 
_Here, in properly serving his 57.105 Demand on Plaintiff, the State Attorney also 
properlyTut Plaintiff on notice that he would seek sanctions by filing the 57.105 Motion for 
Attorneys' Fees if Plaintiff failed to dismiss the remainder of its First Amended Complaint within 
21 days of service of the 57.105 Demand and Motion for Attorneys' Fees. 
cAmi Tli etentlA BEACH COUNTY, FL, ARRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735969

7. On June 23, 2020, Plaintiff's counsel sent a response to the 57.105 Demand 
refusing to withdraw the remainder of the First Amended Complaint. See, Exhibit "B". 
8. §. 57.105, Florida Statutes states the following: 
A motion by a party seeking sanctions under this section must be served but may 
not be filed with or presented to the court unless, within 21 days after service of the 
motion, the challenged paper, claim, detente, contention, allegation, or denial is not 
withdrawn or appropriately corrected. 
9. Accordingly, after receiving Plaintiff's June 23, 2020, respoinsc4 refuting to 
withdraw the remainder of the First Amended Complaint and waiting the , prereguisite "21 days 
after service of the motion" the State Attorney's Motion for Attorney:1/4 :y was filed with this 
Court on July I, 2020. See, Exhibit "C". 
ice710. Thereafter, on August 18, 2020, the Stat led his Motion for Summary 
Judgment ("Motion") and proceeded, on October 2 0, file a Motion to Set• Hearing on the 
State Attorney's Motion ("Motion to Set") a ante clear that there would be no resolution 
of this matter without the Court's inte 
11. Nonetheless, later y, rather than setting and participating in a hearing 
on the merits as to State And non, Plaintiff filed its Notite of Dropping the State Attorney 
("Notice") from the instils. See, Exhibit "D". As a consequence of filing its Notice, Plaintiff 
has effectively uhi,e an admission that its allegations against the State Attorney have no basis in 
fact or law 
'An essential distinction between a notice of dropping a party and a voluntary 
dismissal is that the former concludes the action as to the dropped party while the latter is generally 
utilized to conclude the action in its entirety." Carter v. Lake County, 840 So. 2d 1153, 1155 (Fla. 
5th DCA 2003). 
3 
CA/Aropir9°B,silet BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735970

• • 
13. Specifically! Plaintiffs Notice states: "Plaintiff; [sic], pursuant to Fla. IL Civ. P. 
1.250(b), hereby notifies the patties that it has dropped State Attorney, Dave Aronberg from the 
above case." 
14. Rule 1.250(b), Fla. R. Civ. P. states: 
(b) Dropping Parties. Parties may be dropped by an adverse parry in the 
provided for voluntary dismissal in rule.1.420(a)(1) subject to the exceptions 
in that rule. If notice of Its pendens has been filed in the action against a 
dropped, the notice of dismissal shall be recorded and cancels the n f 11 
pendens without-the necessity of a court order. Parties may be dropp-: r of 
court on ifs own initiative or the motion of any party at any stage o on 
such terms as are just. 
1.5.. Rule 1.420(aX I), Fla. R. Civ..P., Voluntary Dismi 
(I) .13y Parties. Except in actions' in which Ism . Seized or is in 'the 
custody of the tourt,.an action, a Clain; or any ction or claim may be 
disMissed by plaintiff without order of court al by serving, or during 
trial by stating on the record, a notice of di y time before a hearing on 
motion for summary judgment, or if non or if the motion is denied, before 
retirement of the jury in a case tried e a or before submission of a nonjury 
case to the court for decision, or B b in a stipulation of dismissal signed by 
all current parties to the action. s o ite stated in the notice orstipulation, 
the dismissal is without prej t that 4 notice of dismissal operates as an 
adjudication. on the m.eri vi by a plaintiff who has once dismissed in 
any court an aefion b.a chiding the same claim. 
16. Notably, "[R]ule 0(b) expressly incorporates the procedural aspects of Florida 
Rule of Civil P 
be dropped 
exception s that rule,'"Siboni . v. M, 52 So. 3d 719,780 (Fla. 5th DCA 2010). 
17. 
2 (aWI) governing voluntary dismissal by providing that parties may 
nner provided for voluntary dismissal in rule 1.420(aXI) Subject to the 
Likewise, because Rule 1.250(b) specifies that a party is dropped "in the manner 
provided for-voluntary dismissal in Rule I.420(a)(1), theSiboni court concluded that"the manner" 
includes the same entitlement to. costs and attorney's fees which would have been enjoyed had the 
dismissal occurred entirely under Rule 1.420(a)(1). eit 781. 
4 
CAMmitie lik igl BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735971

• • 
IS. Accordingly, the Siboni court held that a "party dropped from litigation under rule 
1.250(6) is subject to the time limitation contained in rule 1.525 governing service of a motion 
seeking a judgment for costs and attorney's fees." Id. 
19. Although Plaintiff filed its Notice the claims asserted by Plaintiff have been, since 
the filing of its initial complaint, completely without support of the facts or the law. At !heir very 
core, all of Plaintiff's claims are based on the presumption that the State Attorney h authority 
to disclose the Requested Materials. Nonetheless, Section 905.17(1), Florid makes clear 
that Plaintiff's Requested Materials can only be released by the Clerk is a court order. 
The stenographic records, notes, and transcriptions made th ofiirt reporter or 
stenographer shall be filed with the clerk who shall kee the n a sealed container 
not subject to public inspection. The notes, records', an transcriptions are 
confidential and exempt from the provisions of s. 119.07(1) and s. 24(a), Art. I of 
the State Constitution and shall be released by the clerkonlv  on request by a grand 
July for use by the grandjury or on order orthecourt pursuant to s. 905.27. 
Section 905.17(1), Florida Statutes (2020). 
20. The State Attorney has o bjectIon to the Clerk producing and disclosing the 
Requested Materials should the ran order to that effect, however, it is impossible for 
the State Attorney to con* the relief sought by Plaintiff in its remaining claim for 
declaratory relief as he dotr,uot possess or control the Requested Materials and is statutorily barred 
from any disclosure. 
21. " Although the State Attorney was prepared to make his argument to the Court, 
--- Plaintrffdecided instead to drop him as a party. Despite Plaintiff's decision, the Florida Rules of 
Civil ProCedure and the above authorities make clear that because Rule 1.250 specifies that a party 
is dropped "in the manner provided for voluntary dismissal in Rule 1.420(a)(1)," it therefore 
"operates as an adjudication on the merits." See, Siboni v. M,  52 So. 3d 779, 781 (Fla. 5th 
DCA 2010); Rule 1.420(a)(1) Fla. R. Civ. P. 
.5 
CAlArOphene9a1Ala ILtE) I'AM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735972

• 
22. Consequently, the filing of Plaintiff's Notice triggered Rule 1.525, Ha. R. Civ. P. 
and therefore: 
Under (§ 57.105], the legislature has expressed its unequivocal intent that where a 
party files a meritless claim, suit or appeal, the party who is wrongfully required to 
expend funds for attorneys' fees is entitled to recoup those fees. 
County Conservation Alliance v. County, 73 So. 3d 856, 857 (Ea. 1st DCA 2011) 
(finding that "Courts are not at liberty to disregard the legislative mandate that courWsfiall impose 
sanctions in cases without foundation in material fact or law. The word "shall" in 57.105, Fla. 
Stat., evidences the legislative intent to impose a mandatory penalty to clistoutagehaseless claims, 
by placing a price tag on losing parties who engage in these activifies;Section 57.105 expressly 
states courts "shall" assess attorney's fees for bringing, or faili\nst to dismiss, baseless claims or 2(
N 
7 
23. In fact, "Section 57.105(1) clearly and explicitly confers upon the trial court-the 
defenses."). 
authority to award attorney's fees to the prevailing party upon the court's initiative, if 'the court 
finds that the losing party . . . lcnew or shal'have known that a claim or defense when initially / 
presented to the court or at any nme-hofbre trial . [wJas not supported by the material facts 
necessary to establish the clatm-ordefense." 
2010). 
v. 47 So. 3d 320, 324 (Fla. 2d DCA 
plc fact of the matter is that Plaintiff failed to withdraw its Amended 
Compli the State Attorney within the 21-day period provided for in section 57.105(4), 
and the fore the State Attorney was permitted to file his 57.105 Motion for Attorneys' Fees as 
sanctions. 
25. Furthermore, based on the impossible nature of Plaintiffs demand of the State 
Attorney, it was proper to demand withdrawal of Plaintiffs remaining claim for declaratory relief 
6 
CA/Aroplwz?te /. 41 !LED r iA Lm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735973

• • 
and serve the 57.105 Motion for Attorneys' Fees due to Plaintiff's claim lacking any basis in fact 
or law. Again, neither the State Attorney nor his office has possession, custody or control of the 
Requested Materials. Likewise, the State Attorney has no objection, and never has had any 
objection, to the Clerk releasing the records sought by Plaintiff, as disclosure of the Requested 
Materials sought by Plaintiff lies solely within the providence of the Clerk pursuant to an order of 
the Court. Amitc 
26. Consequently, the State Attorney is entitled to recover 'reasonable 
attorneys' fees in defending this suit by virtue of 57.105, Florida Statu 
REASONABLENESS AND AMOUNT OF ATTOFtN 8) FEES 
27. From the service of the 57.105 Demand to the date of this motion, the attorneys for 
the State Attorney have rendered 42.2 hours of legal rvices for a total amount of $18,275.00 in 
defending this action. See time sheets detailin th mount of hours by each timekeeper, the 
timekeeper's hourly rate, and a descriptio e asks done during those times, on attached 
Exhibit "E" Of that amount, the has been paid $0.00 as the engagement with the 
State Attorney is on a pure co thigen basis. The undersigned expects to incur an additional 
4.0 hours at $425.00 an hour in ring for and attending the hearing on attorneys' fees. Thus, 
the total amount o ourl att mcys' fees the State Attorney is seeking is 46.2 hours for a total of 
$19,975.00. fu set forth below, the State Attorney also seeks a multiplier of 2.0, which 
when a i es the grand total attorneys' fees as sanctions sought herein $39,950.00. 
An Affidavit of Attorneys' Fees is attached hereto as Exhibit "F", which details 
and breaks down the attorneys' fees sought herein. 
7 
CA/Aropirpc<0 PA
01418, L-rr LM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735974

29. The State. Attorney would offer the following facts and arguments as they relate to 
the factors promulgated in Rule 4-1:5 of the Rules Regulating the Florida Bar and Florida Patient's 
Compensation Fund v.= 472 So. 2d 1145 (Fla. 1985): 
Factor Facts and Arguthents 
(A) the time and labor 
required, the novelty. 
complexity, and difficulty 
of the questions involved, 
and the skill requisite to 
perfomi the legal service 
properly 
The time involved by counsel was substantial, consu n nearly 
75 hours of legal work. Moreover, the issues in co , .v ere 
novel'and complex in. that Plaintiff sought tci cre IL) w nyate 
StanitorycaUse of action under Florida Statute mplicated 
several '1st Amendnimit issues, and f t declaratory 
relief pursuant to said Statute. Finally is li on has been 
ongoing.for nearly a year and required s and nowledge in' hese 
areas of the law. 
(B) the likelihood that the 
acceptance of the 
particular employment 
will preclude other 
employment by the lawyer 
Because of the amount of ti inv. ed in this litigation and 
considering the relative smal 1 e. firm representing the State 
Attorney, the undersign a were forced to turn away or 
delay representing oth ts pecially during critical, stages of 
the litigation, due to red in the instant matter. 
(C) the fee, or rate of fee, 
customarily charged in the 
locality for .legal services 
of a comparable or similar 
nature 
The base fees co n S;425.00/hour for Mr. Wyler's services 
and $475.00 fo r. services are reasonable. for 
lawyers i el pective communities possessing equal 
experie S • . 
(D) the significance of, or 
amount involved in, the 
subject matter of the 
rtpretentation, and the 
results obtained 
T of this case is of great public significance to the State 
f Flo as it pertains to the disclosure of grand jury records and 
ro . of the State Attorney concerning such disClosure. Here, 
the results obtained were the maximum sought by Defendant 
onberg as he was dismissed from the case, albeit not within the 
time constraints of the safe-harbor provision within § 51.105, Fla. 
Stat. 
(E) the time limi tat 
imposed by the cilient or 
by the ciremnances and, 
as 107; , . 'Itutorney and 
client, additional or 
special tithe demands or 
requests 'of the attorney by 
the client 
There were not any extraordinary limitations imposed by the client, 
however, Defendant Aronberg expected and received zealous 
representation, with the desirethat the case be dispensed of quickly 
and efficiently.. 
(F) the:nature. and length 
of the professional 
relationship with the client 
As general counsel for the .FPAA the undersigned counsel has 
represented Defendant Aronberg since the beginning of his tenure 
as State Attorney in civil matters throughout the State of Florida as 
well as matters before the Florida Legislature. 
8 
CA/AmPlfL9459RIVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735975

(0) the experience, 
reputation, diligence, and 
This representation required experience in .a fi eld available to few' 
lawyers, which included defending the State Attorney from claim's 
ability of the lawyer or of a media entity and lawyers from multiple states regarding the 
lawyers performing the release of information with a nationwide interest. Accordingly, the 
service and the skill, 
expertise, or efficiency of 
undersigned counsel conducted the representation with skill and 
efficiency wherein Defendant Aronberg was dismissed from the 
effort reflected in the 
actual. providing of such 
services 
action prior, to any hearing on the merits before the court. 
(H) whether the fee is The fee arrangement .herein was. entirely contingeat, wherein 
fixed or contingent, and, if obtaining a fee was conditioned upon prevailing a. ' of aining an 
fixed as to the amount or 
rates•then whether the 
clieors ability to pay 
rested to any significant 
degree on the outcome of 
the representation..
order awarding fees. 
CO 
JUSTIFICATION  FOR MU 
30: Defendant Aronberg was able to pro 
receives court order awarding contingency bas s' fees upon achievement of asnceessfid 
outcome in this case. See, Exhibit "G^ i en and the fact that counsel risked a total of 74S 
hours of work for no pay, of whi 3 .. um is subject to the 57.105 Demand, Defendant 
Aronberg submits that r of ould be appropriate in this cast Based .upon-the hours 
expended, the hourly rags firid a .multiplier, Defendant Atonbetg respectfully requests an award 
of attorneys' fees ns as stated herein. 
s litigation only if counsel would 
31. ard to the application of a multiplier.; the court must analyze the three 
factors Jd Standard Guaranty Insurance. Co. v. Qua nstrom, 555 So. 2d 828 (Fla. 1990): 
whether the relevant market requires a contingency fee multiplier to obtain 
c mpetent counsel; (2) whether the attorney was able to mitigate of 
nonpayment in any way; and (3) whether any of the factors set Rath in are 
applitable, especially the amount involved, the results obtained, and the. type o fee 
arrangement between the attorney and his client. 
See, Citizens Prop. Ins. Corp. v. Pulloquinga, 183 So. 3d 1134 (Fla. 3d DCA 2015). 
9 
cAmr° PtieL50599.1ti2A BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735976

• • 
32. Here, as to the first factor there was no other counsel in the relevant market who 
would agree to represent Defendant Aronberg under the contingency fee agreement needed due to 
the financial situation of the Office of the State Attorney as a public entity funded entirely by the 
taxpayers of the State of Florida. Although "Risk Mitigation" within the Florida Department of 
Financial Services and the Office of the Attorney General indeed represent the State A orney in 
some instances, this case was not picked up by either and Defendant Aronberg w eeding 
representation by other, private counsel. Although the undersigned counsel law firm area General Counsel for the Florida Prosecuting Attorneys' Association, 
matter did not fall within the scope of representation for the 
the instant 
required a separate 
engagement between Defendant Aronberg and the and Counsel. Accordingly, the 
undersigned counsel and his law firm agreed to repres,e dant Aronberg on a contingency 
fee basis and to try the case to final judgment co that there was no other counsel willing 
to represent Defendant Aronberg on such term 
33. With respect to the other`factors to be considered in applying a multiplier as set 
forth in Quonstroto, here Defendant Aronberg was unable to mitigate against non-payment of fees 
because as a purely taxpayer funded entity, the Office of State Attorney had no other means by 
/ - which to pay the underst‘med counsel. Additionally, Defendant Aronberg meets each of the 
N 
individual Rowe faciors as set forth in the table located above on pages 8-9. Accordingly, based 
on the foregoing the application of a multiplier herein is proper. In this vein, the Rowe court set 
guidelines for the size of a multiplier, as follows: 
Based on our review of the decisions of other jurisdictions and commentaries on 
the subject, we conclude that in contingent fee cases, the lodestar figure calculated 
by the court is entitled to enhancement by an appropriate contingency risk 
multiplier in the range from 1.5 to 3. When the trial court determines that success 
was more likely than not at the outset, the multiplier should be 1.5; when the 
likelihood of success was approximately even at the outset, the multiplier should 
10 
CAM"Pit eN59M il BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735977

• • 
be 2; and, when success was unlikely at the time the case was initiated, the 
multiplier should be in the range of 2.5 to 3. 
Florida Patient's Compensation Fund v. M, 472 So. 2d 1145 (Fla. 1985). 
34, Additionally, the Quanstrom courtsonftrmed and modified the 
follows: 
approach, as 
However; we find that the multiplier in should be modified as follows:1 
trial court determines that success was more likely than not at  outse 
apply a multiplier of I to 1,5; if the trial court determines that the lik o 
success was improximately.even at the outset, the trial judge may app tier 
of 1.5 to 2.0; and if the trial court determines that success was unlike utset 
Of the case, it may apply a multiplier of2.0 to 2.5. Accordingly ecision 
is modified to allow a multiplier from 1 to 2.5. 
Standard Guaranty lusimance Co. v. Quanstroin, 555. So. 2d (Fla. 1990). Thus, based 
upon all of the foregoing factors, Defendant Aronberg r ubmits that a multiplier of 2.0 
is appropriate for this representation. 
CERTIFICATION OF GO? 
A.
F. T Fro R-r TO RESOLVE 
The The undersigned certifies that  fai effort was made to resolve the issues raised in 
this motion by agreement of the - e parties were: unable to resolve by agreement the 
issues of entitlement to feet o omit of feet. 
toclWHEREFORE, ant, DAVE ARONBERG, as State Attorney of Palm Beach 
County, Florida stint is Honorable Court will enteran Order awarding Defendant Aronberg 
his teas° eye fees with a multiplier of 2.0 against the Plaintiff, CA FLORIDA 
HOLD L'LC, publisher of the PALM BEACH POST, in the amount of S39,950.00.. 
CERTIFICATE OF SERVICE 
1 HEREBY CERTIFY that on this 9th day of November, 2020, a copy of the foregoing 
Defendant, Dave Aronberg's Amended Motion for Attorneys' Fees has been electronically filed 
with the Florida E-File Portal for e-service on all parties oftecord herein. 
11 
CAIA9 411%9P9a 2A BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735978

• • 
SCHOLZ Si WYLER, LLC 
/s/ Douglas A. Wyler 
Arthi q. 
Fla. Bar. No.: 10249 
Richard J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 
Fernandina. Beach, Florida 
(904) 26 l -3693 rt% 
([Phone Redacted] Fax 
Primary! jaeobssc il mcast.net 
AlWrZ <Se
12 
Dave Aronberg 
CA/AMPItegb53S1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735979

• 
EXHIBIT "A" 
EXHIBIT "A" 
3282023 1,9:29 P. 
EFTA02735980

• IllFriday, September 18, 2020 at 1:09:24 Eastern Daylight Time 
Subject: SERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, LLC V. 
DAVE ARONBERG ET AL. 
Date: Monday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time 
From: Douglas Wyler 
To: '[Email Redacted]', [Email Redacted], [Email Redacted], [Email Redacted], 
[Email Redacted], [Email Redacted] 
Attachments: 2020-06-08 Aronberg 57.105 Demand and Motion for Attorneys' Fees.pdf 
Please see attached and below in this matter. 
Court: Circuit Court of the Fifteenth Judicial Circuit, in and for Palm Beathillt , 
Florida 
Case No: Case No. 2020-CA-014681 
Plaintiff: CA Florida Holdings, LLC 
O SDefendant: Dave Aronberg 
Title of Documents 
Served: 
• Fla. Stat. § 57.105 Demand Letter C ) 
• Defendant, Dave Aronberg's Motion for Attorney? Fees 
Sender's Name and 
Number: 
Douglas Wyler 
([Phone Redacted] L'A)Telephone 
Sincerely, 
Dop,Wyler, Esq. 
Scholz & Wyler, LLC 
961687 Gateway Blvd., STE 201-I 
Fernandina Beach, FL 32034 
[Phone Redacted] 
[Phone Redacted] (fax) 
[Email Redacted] 
Please be advised that this e-mail andI files transmitted with it are confidential attorney-client 
communication or may otherwise be privileged or confidential and are intended solely for the individual or 
entity to whom they are addressed. If you are not the intended recipient, please do not read, copy or 
retransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or 
copying of this co unit:400n is strictly prohibited. 
Page 1 of 1 
CA/Aroppeffeit num1425. BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735981

• • 
THE LAW OPICCS or 
ASSOCIATES. PA. 
ARTHUR I. 
SCHOLZ-M illiAllA ILITYCOMP 010 8C  
. 
 NAL. ASSOCIATIONS 
LC. 
ATTORNEYS AT LAW 
GATEWAY TO /*Alba ' 
1.61097 GATEWAY OLVO.. SUITE t01-1 
POINANDEVA Brace FLORIDA 32634 
TELEPHONE (904) 26141693 
FAX NO. (904) 26 1-7979 
June 13, 2020 
VIA ELECTRONIC & US. MAIL 
Stephen A. Mendelsohn, Esq. 
Greenburg Traurig, P.A. 
5100 Town Center Circle, Suite 406 
Boca Raton, FL 33486 
RE: CA Florida Holdings, LLC v. Dave Aronbe 
Palm. Beach County, Case No.: 2019-CA-0 
Dear Mr. Mendelsohn: 
As you are aware our rem itprtsents the inters≤ 
County, Florida, in the above referenced matt 
dismissal of your First Amended Complaint, 
is made pursuant to section 57.105, Florj 
As you know, Section 57.1 
RICHARD ../..SCHOLZ. I.A. 
RICHARD J. SCHOLZ 
DOUGLAS A. WYLCR, P.A. 
DOUG SA. NYLON 
cps 
e Ai'onberg, as State. Attorney of Palm Beach 
se of ihis, letter is to demand the voluntary 
Co plaint"), dated January 17. 2020. This demand 
(I) Upon the court's nitiai v or motion of any pafty, the court shall award a 
reasonable attome , including prejudgment interest, to be paid to the 
prevailing in equal amounts by the.lOsiritparty and the losinsparty's attorney 
on any claim rise at any time during a civil proceeding or action in which 
the c find at the losing party or the losing party's attorney knew or should 
own that a claim or defense when initially presented to the court or at any 
trial:: 
Was not supported by the material facts necessary to establish the claim.or 
defense; or 
b. Would not be supported by the application of then-existing law to those 
material facts. 
Today; Judge Marx granted, with prejudice, Defendant Aronberg's Motion to DismiaS Count 11 of the 
Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiffs only remaining cause of action 
consists of. Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein 
and its sole remaining Count for-Declaratory Relief is not supported by the maierial fails necessary to 
• establish the claims asserted, and that your claims are not supported by the application of current law 
to said material facts. 
CiatrOppefie9 )1426. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735982

• • 
First and foremost, the Complaint is not supported by the material facts necessary to establish the 
claims asserted because neither Defendant Aronberg, nor The ()flirt of the State.. Attorney for the 
Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein. 
Simply pm, the declaratory relief sought by the Plaintiff, seeks records from my client that are 
impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to 
this action because no matter what, he:and his office do not have possession, custody, or control of the 
requested materials. 
In addition .to the foregoing material facts that neva; the clainns asserted, in. the Complaint, your claims 
are also not supported by the application ofcurrent law.. Specifically, your action fordec tog relief 
fails based on the clear, unambiguous Statutory language found in Section 005.27(2),,1 a Statutes, 
which states: 
When such disclosure is ordered by a court pursuant to subsection (I civil 
case, it may bc disclosed to  parties to the case and to their attom e latter 
to their legal associates and employees. However the grand i tes  afforded 
such persons by the court can only be used in the defense or pro cuti n of the civil or 
criminal case and for no other purpose whatsoever. 
Moreover, even if the Plaintiff were to prevail in the declara 
to comply with any court order granting disclosure. f t 
Aronberg nor The Office of the State Attorney for 
custody, or control of the 2006 Epstein grand jury 
Based on the foregoing, if theComplaint is n 
the enclosed Motion for AttoMey's Fees w 
and your firm, recovery of the legal ex 
Please govem yourself accordingl 
Douglas A. Wyler, Esq 
For the Firm 
End.: Defend Motion for Attorneys' Fees 
r. Aronberg would be unable 
documents because neither Mr. 
Judicial Circuit have possession, 
within 21 days of the service of this letter, 
and we will seek as sanctions, from your client 
in defending this frivolous action. 
CA/ArTit ehrt99/4. 2I4 BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 1:49:29 PM 
EFTA02735983

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY., FLORIDA 
• 
CA FLORIDA HOLDINGS, LLC, 
PUblisher of the PALM BEACH POST* 
Plaintiff, 
v. CASE NO.: 19-CA-0146g1 
DAVE ARONBERO, as Stic Attorney of • Palm Beach County, Florida; SHARON fte 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. CO S
 / 
DEFENDANT, DAVE ARONBERG'S MOTIOVCATTORNEYS' FEES 
Defendant, DAVE A RONBERG, as State \of Palm Beach County, Florida, byand 
through the undersigned attorneys. moves ursuant to Florida Statutes, Section 57.105, 
to awarthim reasonable attorneys' f r th defense of Plaintiff's First Amended Complaint, 
. (the "Cortmlainn, and as groun would show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, toge er wi a letter from the undersigned anon*, in accordance with
subsection (4) of the Statute; demanding dismissal of the Complaint at least 21 days prior aIlv iir
to the filing Of olio . In.said letter, Defendant's attorney advised Plaintiff of the facts which 
establish plaint is without support. of the facts or the law. 
FORE, Defendant, DAVE ARONBEftG, as State Attorney of Palm Beach 
County, lorida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of thiS Motion. . 
CA/AmPlieffelki 2101 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735984

S 
CERTIFICATE OF SERVICE 
I hereby certify that on this day , 2020, the foregoing was electronically filed 
vii the Florida E-File Portal for etectronic service on the parties of record herein. 
SCHOLi & WYLER, LLC 
Douglas A. Wylei; 
Arthur I.  Esquire 
RA. Bar No.: 108249 
Richard 3. Scholz, aqui 
Fla. Bar No:: 002126 
Douglas A. Wyler 
Fli. Bar No.: 11 
961687 Cratewa c Iv, ',Suite 201-1 
Fernandi orida 32034 
(904) 2 
(901 
j 
k„ 
),‘ [Email Redacted] 
4io eys for Defendant 
(s\cwt 
CA/ArTintNAVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735985

• • 
EXHIBIT "B" 
EXHIBIT "B" 
CNAI~~~a~ BEACH COUNTY, FL, _ ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735986

GT 
• Greenberg-Rating
Stephen A. me:Welton:1 
Tel [Phone Redacted] 
Fax [Phone Redacted] 
mendelsolln5.011aw corn 
June 23, 2020 
Douglas A. Wyler 
Jacob. Scholz .& Wyler, LLC 
961687 Gateway Blvd. 
Suite 201-I 
Fernandina Beach, Fl. 32034 
Re: CA Florida Holdings, LLC v. Dove Aronberg et al. 
Case No. 2019-CA-014681 
Dear Mr. Wyler: 
Cos 
We are in receipt of your letter of June 8, 2620 with yo Fla. Stat. section 57.105 motion. 
In your letter and your proposed motion, you ass orida Holdings, LLC and. the law 
lion of Greenberg Tratirig, P.A. should be I.: attorneys' fees to be incurred by State 
Attorney Aronberg after the date of your 1 otter cites to Fla. Stat. sections 57.105(1) 
(a) and (b) for support. As shown below, th no asis for a Fla. Stat. section 57.105 motion, 
and we expect that if the State Attorney ake such a motion, the court should deny it. 
Your letter omits a citation to 
may not be awarded where 
reversal of existing law or the 
a reasonable expectation of suc 
Contrary to your 
court may orde 
furtherance 
an open air va 
the m 
of j 
materia 
such us 
(3). Subsection 57A05(3)(a) provides that sanctions 
ood faith argument for the. extension, modification or 
hirient of new law, as it is appliedio the material facts,. with 
We have such a good faith argument. 
alysi of Fla. Stat. section 905.27, there are actually three instances where a 
releas of grand jury materials. As we argue, the court may order release "in 
" There are few cases in Florida, reviewing this provision and its scope. It is 
estion as to Whether the court Ailey order release of grand jury transcripts: to 
h the statute and the First: Amendment to the US Constitution in furtherance 
,.statutory language you cite refers to instances where a person is seeking grand jury 
for use in a. civil or iu a criminal case. In these limited situations, the statute allows for 
and for no other reason. However, the statute does not state, as you assert, that where 
the media seeks grand jury materials based upon its constitutional standing, which the Circuit 
Court acknowledged at the June 2, 2020 heating includes The Palm Beach Post, that the statutory 
Greenberg Trawls. Pat. I Attorneys at Law 
5100 Town Center Cade I State 400 I Dote Retc4i, Florida 33486 I 7 +[Phone Redacted] I F +[Phone Redacted] 
Albany. Amsterdam. Atlanta. Austin. Berliri Boca Raton. Boston. Chicago. Dallas. Delaware. Deaver. Fori Loudermilk. Houston. Las Vegas. London! Las Andes. 
Wales CUP: Miami Haan'. Minneapolis. Nashville. New Jersey. New York Norther° Virginia. Orange Countt. Orlando. PlaidelphiLltmenia. Sacramento. 
Sao Francisco. Seoul; .Shanshai. Silicon Valley:Tallahassee. Tampa. Tel AAV: Tokyo: Warsaw:Washita:ma; D.C. Wut Pan Ileaeli.Westchester County. 
'ate„ viosavws 4.2ngngiCiri•O•niteraTe.ii.S. • or: • I'M. 4.. ;e eakinq••••0 41" C..40 .14 
twm.gthew.com 
CA/AropiteifinMal. ALM BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735987

• • Correspondence to Douglas A. Wyler 
June 23, 2020 
Page 2 
use limitation you cite applies. No reported Florida case has addressed this issue and there is a 
good faith basis for our view of Fla. Stat. section 905.27 
Your letter also argues that sanctions are applicable because the State Attorney has alleged that it 
does not possess the Jeffrey Epstein grand jury transcripts. This allegation is also contained in the 
State Attorney's Ans%ver. Attaining that the. State Attorney does not currently hay= physical 
possaction of the Epsteingrand jury materials, which has yet-to be demonstrated, t not end 
the matter. The State Attorney was named as a party not simply as a custodi jut)! 
records. The State Attorney was named in his official capacity as his office has" its primary 
interest the protection of its grand jury system." [Italics in original.] In re Grand J Ines, 
832 F. 3d 554, 559 (1 1 o' Circuit 1987). In that case, the US petitioned a state judge to order the 
State Attorney to turn over grand jury transcripts. The State Attorney argued S/nut their release 
citing to Fla. Stat. section 905.27. Later, a federal grand . jury suhpo*he Broward County 
State Attorney for delivery of state grand jury testimony. The 13roward Sta e Attorney advised the 
federal court that it would produce the transcripts, thereby demonstrating that while it may not 
have physical possession of the materials, he had legal kttlioriry to obtain and deliver thaw It 
should alto be rioted that me State AM:laity. moved t rAsh the subpoena arguing that it was 
unlawful under Florida law and Fla.. Stat. section 905 is case indicates that where one seeks 
grand jury materials, the relevant State Attorney ry partyin order to protect the grand 
jury that the Office of State Attorney supervi to e arguments, if needbe, against release 
of the grand jury materials. These are some a sa reasons why the State Attorney was named 
in this case. 
Also, assuming the State Attorney ave physical possession of the grand jury materials, 
there is nothing in Florida law its the State Attorney from requesting that the Clerk 
provide copies to the State Aft ey. pter 905, Fla. Stets. does not contain a prohibition against 
a State Attorney demand that t k grant his office attest to grand jury materials, even after a 
criminal case has Coda Upon. inforMation and belief, the Clerk's office maintains a log that 
tracks release of grand terials to the State Attorney upon its request. Please confirm 
whether the Stat [torn has accessed grand jury materials from the Clerk's office in other 
instances or th as never done so. If the Clerk has such a log, then its contents should be 
(discoverabl )ubj to Florida Public records laws. t6m.
Greenberg Tranrig. PS I Attorneys at Law 
WasOlattoom 
CNARVIM39 /0&4 431 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02735988

• • 
Correspondence to Douglas A. Wyler 
June 23, 2020 
Page 3 
For these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed 
against the Office of the State Attorney. We expect that your demand will be withdrawn. 
Thank you, 
Very truly yours, 
/s/Stephen Mendelsohn 
Stephen Mendelsohn 
SAM:1s 
ACTIVE 51081659vI 
Greenberg Traurig. P.A. I .41tortlevs at law 
A Co's 
-4)
cwt 
wMx.O19M.00111 
CA/ArOppegi90.433. 
ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735989

• • 
EXHIBIT "C" 
cc 
EXHIBIT "C" 
... Mr.. BEACH COUNTY, FL, AMLUZZO, CLERK 328.331.4F29 F. 
EFTA02735990

• • 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACII COUNTY, FLORIDA 
CA FLORIDA HOLDINGS. LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
v. CASE NO.: 19-CA-014681 
DAVE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned attorneys, moves th ourt, pursuant to Florida Statutes, Section 57.105, 
to award him reasonable attorneys' fense of Plaintiff's First Amended Complaint, 
(the "Complaint"), and as groun ould show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, togeth wit a letter from the undersigned attorney, in accordance with 
subsection (4) of the ab we, demanding dismissal of the Complaint, at least 21 days prior 
to the filing of* oiion. In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish t plaint is without support of the facts or the law. 
FORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach 
County, rida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 
CNAM PPLeig551 ,<K1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735991

• 
CERTIFICATE OF SERVICE 
I hereby certify that on this.Ist day July, 2020, the foregoing was electronically filed via 
the Florida E-File Portal for electronic service on the parties of record herein. 
SCHOLZ & WYLER, LLC 
/s/ Douglas A. Wyler 
Anhur L Jacob's, Esquire 
Fla. Bar No.: 108249 
-,,r.S .,
Richard J. Scholz, Esquire 
Fla. Bar No.: 0021261 
Douglas A. Wyler, 
Fla. Bar No.: 119 
961687 Gateway uite 20 NI 
Feniandin , F orida 32034 
(904) 2 
(904 61 
ja [Email Redacted] 4\'Ct n s for Defendant. Dave Arenberg 
+6s
cAthr liasb iWiel BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735992

• 
EXHIBIT "D" 
EXHIBIT "D" 
CNA: TM:MR& BEACH COUNTY, FL, ABRUZZO, CLERK, 3/28/2023 1.4919 PM 
EFTA02735993

411 Filing ft 115353.434 E-Filed 10/21/2020 04,13:35 PM 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND.
FOR PALM BEACH COUNTY, FLORIQ,A 
CA FLORIDA HOLDINGS, LLC, cmg NO.: 5072019-CA-014681-XXX,p1vIB 
Publisher of THE PALkiBEACH POST, • DIVISION: A'G 
• Plaintiff;
v. - 
DAVE ARÓNBERG, as State Attorney of 
Palm Beach CouritY, Flerida; SHARON R. 
BOCK, as CSC and Comptroller of Palm 
Bea tounty, Florida, 
Defendants.
PLAINTIFF CA HOLDING 
NOTICE OF DROPPING STATE ATT E ARONBERG 
Plaintiff; CA HOLDINGS, LLC, pursuant tó Fla. R b), hereby notifies the parties that 
it has dropped State Attorney, Dave Aronbe ve case. 
respectfully sUbrriiitid, 
- 
GREENBERG TRAURIG, P,A, Anorneys for CA Florida Holdings, LLC, Publisher . 
Of The. Pain? Beach Post ..
Stephen A.Mendelsohn, Esq. 
401 East Las Olas Boulevard Suite 2000 
Ikea Raton, Florida 33486 
Telephone: (S61) 955-7629 . 
FacSiinile: (561) p8-7099 • 
By: Is/Stephen A. Mendelsohn . 
STEPHEN A: MENDELSOHN. 
Florida Bar No. 849324 
mendelsohns4tttlaw.com 
smithVagtlaw.com 
FLServicceetlaw.com 
CA/AMPitsg0. 1493" BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735994

By. /5/ Michael J 
MICHAEL J GRYGIEL 
(Admitted Pro Hoc Vice) 
54 State St:, 6th Floor 
• Albany, NeW yotk 12207
Telephorte: ([Phone Redacted]. 
Facsimile; (518) 68.9-1490 
givaielnautlaw.coni 
By. Is/ Mho D. Bowlike; 
NINA D. BOYAJIAN 
(Admitted Pro He Vice) 
1840 Cannily Park East, Suite 
LoaAngeles Califomia 90067 
Telephone:. (310) 586.77 
Facsimile: (310) 586-78 
*I.HEREBY CERTIFY that oWthis 213'd to r, 2020,. a true and 'correct copy of the \ ft
foregoing has been filed with the Clerk of ourt lig the State of Florida e-filing system, which 
will send a notice of electronic servi t Zjj Il parties of record herein • 
ACTIVE 533I7341O 
Stephen A. Mendelsohn • 
STEPHEN. &-MENDELSOHN 
2 • . • 
CA/Arctlat99401 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735995

• • 
EXHIBIT "E" 
EXHIBIT "E" 
cam 04 BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 1.49:29 PM 
EFTA02735996

ni l Scholz & Wyler, LLC 
Gateway Blvd., Suite 2011 
Femandina Beach, FL 32034 
United States 
[Phone Redacted] 
Dave Aronberg 
Scholz & Wyler, LLC 
Balance 
Invoice # 
Invoice Date 
Payment Term 
Due Date 
Aronberg (SAO15) adv. CA Florida Holdings, LLC 
C 5)
Time Entries 
$32,440.00 
00307 
November 6, 2020 _ 
Date SE Activity Description Rate Hours Line Total 
1126/2019 DW Review 
dea‘N /
Initial review of summons are coMplaiffl.- $425.00 1.5 $637.50 
11/26/2019 DW Review Reviewed motion for pro hac vice and Judge 
Halele' order granting $425.00 0.2 $85.00 
11/26/2019 DW Teleconference Teleconference W Ment,i`e: response to lawsuit $425.00 0.5 $212.50 
11/26/2019 DW Draft Drafted engagement fetter and sent to client $425.00 0.3 $127.50 
11/2612019 OW RevieW Reviewed I 5th Circuit local nres $425.00 1.0 $425.00 
11/26/2019 AU Review Wiest review of complaint $475.00 1.0 3475.00 
11/26/2019 AIJ Meeting Meeting w/ DAW to discuss lawsuit and strategy $475.00 0.5 $237.50 
1126/2019 OW Meeting Meeting w/ AU to discuss lawsuit and strategy 3425.00 0.5 $212.50 
11/26/2019 AU Teleooplerence ".- Teleconference w/ Client, re: response to lawsuit $475.00 0.5 $237.50 
12/02/2019 DW earcn tesRes • . - Preparation Research and prep for Motion to dismiss $425.00 2.0 $850.00 
12/02/2019 DW Draft 1st Draft motion to dismiss $425.00 1.0 $425.00 
12/02/2019 DW Teleconference Teleconference w/ Client, re: draft motion to 
dismiss $425.00 0.5 $212.50 
12/02/2019 AIJ Review Reviewed 1st Draft MTDismiss $475.00 0.3 $142.50 
12/02/2019 AIJ Teleconference Teleconference w/ client, re: draft motion to 
dismiss 3475.00 0.5 $237.50 
12/03/2019 AIJ Meeting Meeting w/ DAW, re: motion to dismiss $475.00 0.2 $95.00 
12/03/2019 DW Meeting Meeting w/ AU, re: MTDismiss $425.00 0.2 $85.00 
12/06/2019 DW Draft 0.7Completed final draft of motion to dismiss; filed with 
Court $425.00 $297.50 
12/06/2019 OW Teleconference Spoke w/ client, re: final draft of motion to dismiss $425.00 0.5 $212.50 
CA/Aropi : I'm  re40.1.44, )/ BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735997

12/06/2019 DW Teleconference Spoke with Clerk's attorney, re: response $425.00 0.5 $212.50 
12/062019 AIJ Review Reviewed final &aft MTDismiss $475.00 0.2 $95.00 
12/06/2019 AIJ Review Reviewed Clerk's MTDismiss $475.00 0.2 $95.00 
12/13/2019 DW Review Reviewed Clerk's Motion to Dismiss $425.00 0.5 $212.50 
01/16/2020 DW Review Reviewed Order Selling Hearing on Defendants' 
MTDismiss $425.00 0.1 $42.50 
01/16/2020 DW Review Reviewed motion for pro hac vice $425.00 0.1 $42.50 
01/17/2020 DW Review Reviewed Prs Amended Complaint $425.00 1.0 $425.00 
01/17/2020 DW Teleconference Spoke with client, re: Amended Complaint $425.00 0.5 $212.50 
01/17/2020 DW Revievi Reviewed PI'S notice of filing $425.00 0.1 542.50 
01)20/2020 AIJ Review Reviewed Pl's Am. Compl $475.00 0.3 $142.50 
01)21/2020 DW Review Reviewed Judge Marx's Order Cancelling 
MTDismiss Hearing 
$625.00 0.1 $42.50 
0121/2020 DW Review Reviewed Pl's Objection to Defendants' MTDismiss 5425.00 0.2 $85.00 
01/21/2020 DW Teleconference Spoke with client, re: Amended complaint $425.00 0.5 $212.50 
01/21/2020 AIJ Meeting Meeting w/ DAW, re: respOnse to Am. Comps $475.00 0.2 $95.00 
01/21/2020 DW Meeting Meeting w/ AU, re: response to Am. Cornet $425.00 0.2 $85.00 
01)22/2020 DW Review Reviewed Order granting pro hac vice isdritission $425.00 0.1 $42.50 
01/22/2020 DW Research & Draft Researched and drafted response to Amended 
Complaint $425.00 1.0 $425.00 
01/23/2020 DW Teleconference Spoke with Clerk's attorney, re: response to 
amended complaint $425.00 0.2 $85.03 
01/242020 DW Various Completed Answer/MTDismiss Amended 
Com plaint; filed W4111 Colin; sent copy to Client $425.00 1.0 $425.00 
01/24/2020 DW Draft Drafted and filed Notice of Unavailability $425.00 0.4 $170.00 
01/24/2020 Al.) Review Reviewed Mel Answer/MTDismiss $475.00 0.2 595.00 
01/27/2020 DW Review Reviewed Clerk's Answer/MTDismiss $425.00 0.3 $127.50 
02/03/2020 DW Review Reviewed Order setting hearing on Deft' 
MTDismiss $425.00 0.1 $42.50 
02/03/2020 DW Teleconference SPoke w/ client, re: order setting .MTDismiss 
hearing for March 24, 2020 $425.00 0.5 $212.50 
03/13/2020 DW Review Reviewed Prs Opposition to Aronberg MTDismiss 
8 Clerk's MTDismiss $425.00 1.5 $637.50 
03/13/2020 ALL Review Reviewed Pl's Opposition to Aronberg MTDisiniss 
8 Clerk's MTDismiss $475.00 0.7 3332.50 
OW18/2O2O DW Teleconference Reviewed email from Pl's counsel, re: motion to 
continue hearing $425.00 0.1 $42.50 
03/16/2020 DW Review Reviewed Pf's unopposed motion for continuance $425.00 0.1 $42.50 
03/18/2020 DW Email Emalls w/ Clerk's counsel, re: PI% request to 
continue hearing $425.00 02 $85.00 
03/19/2020 DW E-mail Reviewed email from PI, re: agreed order 8 
responded $425.00 0.1 $42.50 
03/20/2020 DW Review Reviewed Court's agreed order continuing hearing $425.00 0.1 $42.50 
CA/AropkeNnt442, ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735998

04/21/2020 DW Review 
Reviewed order rescheduing hearing on Deis' 
MTDismiss $425.00 0.1 $42.50 
04/21/2020 DW Teleconference Spoke w/ client, re: order reschedufing MTDismiss 
hearing for June 3, 2020 $425.00 0.3 $127.50 
04/21/2020 AIJ Review Reviewed Order rescheduling MTDismiss hearing $475.00 0.1 $47.50 
0522/2020 DW Review Reviewed order setting Zoom hearing, re: 
MTDismiss $425.00 0.1 $42.50 
05/22/2020 DW Teleconference Spoke w/ client, re: hearing will be via Zoom $425.00 0.2 $85.00 
05/27/2020 DW Review Reviewed Clerk's filing: change of any of record $425.00 0.1 $42.50 
05/27/2920 DW Teleconference Spoke with Clerk's new counsel, Nicole Fingerhut $425.00 , 0.2 $85.00 
05/28/2020 DW E-mail Reviewed Ks email, re: cases and authorities for 
MTDismiss heating; responded $425.00 04 $42.50 
05/29/2020 DW Preparation Began oral argument prep for 6/8 MTDismiss 
hearing $425.00 1.0 $425.00 
06/01/2020 DW E-mail Respondedviewed email from Judge Marx's JA and re $425.00 0.1 $42.50 
06/02/2020 OW Various Reviewed Ks 500+ page binder, re: MTDisrnisS & 
prepped for hearing 
$425.00 3.0 $1,275.00 
06/02/2020 DW E-mail Drafted and sent email to client, re: MM hearing 
tomorrow $425.00 0.1 $42.50 
06/03/2020 DW Attend Hearing Prepped for and attended MTDismisshearing via 
Zoo m $425.00 1.5 $637.50 
06/03/2020 DW Teleconference Spoke w/ Client, re: *frier MTDismiss hearing $425.00 0.5 $212.50 
06/03/2020 OW E-mail Entailed courtesy copies al Aronberg's Answer and 
MTDismiss toJudge Marx 
$425.00 0.1 $42.50 
08/03/2020 OW Email Reviewed response from Client and replied $425.00 0.1 $42.50 
06/03/2020 AIJ Attend Hearing Attended MTDistniss hearing via Zoom $475.00 1.0 $475.00 
06/03/2020 AIJ Review Reviewed order granting MTDismiss w/ prejudice $475.00 0.3 $142.50 
06/08/2020 DW Review Reviewed Courts Order Granting Defendants 
MTDismiss Count II w/ Prejudice $425.00 0.5 $212.50 
06/08/2020 DW Various Shared order col Client and spoke w/, re: result and Shared
plan going forward. re: 57.105 0.5 $212.50 
06/08/2020 DW VariopS 
Researched § 57.105 Fla Stat.; drafted 57.105 
demand letter and proposed motion for attorneys' 
lees/sanctions; Served Prs counsel with demand 
letter and proposed motion. 
$425.00 2.0 $850.00 
06/08/2020 AIJ Meeting Meeting w/ DAW, re: Order & 57.105 $475.00 0.3 $142.50 
06/08/2020 DW Meetinp Meeting w/ AIJ, re: Order & 57.105 $425.00 0.3 $127.50 
06/08/2020 AIJ Review Reviewed 57.105 demand and proposed motion for 
sanction 
$475.00 0.2 595.00 
06/10/2020 DW Various Reviewed notice of change of attorney; re: Clerk: 
called and spoke w/ new counsel Cynthia Guerra $425.00 0.3 $127.50 
06/23/2020 DW Various 
Reviewed Pte letter refusing to voluntarily dismiss 
amended complaint despite 57.105 demand; called 
and spoke w/ client, re: Pt's refusal & next steps 
$425.00 1.0 $425.00 
CAlAroplin99144,1 Atm BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02735999

06/23/2020 DW E-mail Sent dient copy of Prs letter refusing to dismiss 
complaint  $425.00 0.1 $42.50 
06/23/2020 All Review Reviewed Prs letter refusing to dismiss Count Mar 
Comp. $475.00 0.1 $47.50 
07/01/2020 DW Various 
Spoke w/ client, re: filing of 57.105 motion for 
fees/sanctions; filed motionfor attorneys' lees 
based on Prs failure to voluntarily dismiss 
amended complaint count 1 
$425.00 0.5 $212.50 
07/02/2020 DW E-mail Email to client, re: affidavit and summary judgment $425.00 0.1 $42.50 
07/08/2020 OW Teleconference Discussed w/ Client drafting arid filing Motion for 
Summary Judgment and 14S1 evidence $425.00 0.7 $297.50 
07/08/2020 AIJ Teleconference Discussed w/ Client drafting and filing Motion for 
Summary Judgment and MSJ evidence $475.00 ,, 1'0.7 $332.50 
07/10/2020 DW Draft Created 1st draft of Arenberg Afridavit; shared w/ 
client $425.00 1.0 $425.00 
07/10/2020 AIJ Various Reviewed draft affidavit and discussed w/ DAW $475.00 0.3 $142.50 
07/10/2020 DW Meeting Discussed draft affidavit w/ AU $425.00 0.2 $85.00 
07/13/2020 DW Review Reviewed Prs Request to Produce, re: Clerk $425.00 0.1 $42.50 
07/13/2020 DW Teleconference Spoke w/ Clerk's counsel, re: Request to Pr&bee $425.00 0.2 $85.00 
07/27/2020 OW Review Reviewed Prs Amended Request to Prod.uce. re: 
Clerk $425.00 0.1 $42.50 
07/27/2020 DW Teleconference Spoke wo e! Clerk's counsel, re:Amended Request to 
Produce $425.00 0.1 $42.50 
07/28/2020 DW Draft Revised Arenberg 8111gevil $425.00 0.5 $212.50 
07/29/2020 OW Draft Finalized Arenberg Affidavit and sent to dent $425.00 0.5 $212.50 
07/28/2020 DW Research 8 
Preparation 
Research rini prep for Motion for Summary 
Judgment zi- $425.00 to $425.00 
07/30/2020 DW Various Received exec reed Arenberg Affidavit $425.00 0.1 $42.50 
07/30/2020 DW Draft Began drafting Motion for Summary Judgment $425.00 2.0 $850.00 
08/05/2020 DW Draft. Continued drafting Motion for Summary Judgment $425.00 1.0 $425.00 
08/07/2020 DW Review Reviewed email from Plaintiff attempting to set 
hearing on 57.105 motion for fees/sanctions $425.00 0.1 $42.50 
08/10/2020 DW E-mail Sent responsive email to Rs counsel $425.00 0.1 $42.50 
08/17/2020 DW. Meeting Discussed draft MSJ w/AIJ $425.00 0.2 $85.00 
08/17/2020 AIJ Various Reviewed draft MSJ and met w/ DAW to discuss $475.00 0.5 $237.50 
08/18/2020 DW Draft Finalized Motion for Summary Judgment; filed iv/ 
court along with Aronberg affidavit $425.00 2.0 $850.00 
08/27/2020 DW Teleconference Spoke w/ Clerk's counsel. re: request to produce $425.00 0.1 $42.50 
09/01/2020 OW Various Reviewed Pt's email and accepted conference call 
invite for 9/2/20 $425.00 0.1 $42.50 
09/02/2020 DW Review Reviewed Clerks response to request for 
production $425.00 0.2 $85.00 
09/02/2020 DW Teleconference 
Spoke w/ Prs counsel, re: dispute as to whether 
MSJ should be heard before 57.105 fee motion or 
vis versa - call was unsuccessful 
5425.00 0.5 $212.50 
CA/ArOpper&OQ1444, 
YALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736000

09/02/2020 AU Meeting. Discussed w/ DAW phone call w/ Prs counsel $475.00 0.2 $95.00 
09/02/2020 OW Meeting Discussed w/ AU phone call w/ Prs counsel $425.00 0.2 $65.00 
09/16/2020 OW E-mail 
Reviewed email from Prs counsel requested 
Aronberg to withdraw sanctions motion w/o 
prejudice 
$425.00 0.1 $42.50 
09/17/2020 DW Meeting Discussed w/ AU fling motion for CMC $425.00 0.1 $42.50 
09/17/2020 AIJ Meeting Discussed w/ DAW filing motion for CMC $475.00 0.1 $47.50 
09/18/2020 DW Various Drafted and filed motion to set case management 
conference; re: MSJ 1st or Fee hearing 1st $425.00 0.5 $212.50 
09/18/2020 DW Email 
Responded to Prs 9/16120 °mai and refused to 
withdraw 57.105 motion; provided copy of motion to 
set CMC and available dates for hearing 
$425.00 0.1 $42.50 
09/18/2020 DW E-mail Reviewed Prs email insisting that 57.105 motion be 
withdrawn $425.00 0.1 $42.50 
09/18/2020 OW E-mail 
Replied to to Prs counsel that the 57.105 motion for 
sanctions will not be withdrawn and asking for 
response, re: CMC 
$425.00 0.1 $42.50 
09/18/2020 DW E-mail Sent client copy of email exchange w/ Prs counsel; 
called and spoke w/ Client 
$425.00 0.5 $212.50 
09/22/2020 DW Various Drafted and filed Notice of Hearing on 10/15/20344 
up Court Call; spoke w/ client, re: nearing date 
 $425.00 0.7 $297.50 
10/02/2020 DW Review Reviewed Prs Memo of Law opposing Aronberg's 
57.105 motion for fees/sanctions $425.00 0.7 $297.50 
10/02/2020 OW Review Reviewed Prs Response to Aironberg's request to 
schedule 57.105 motion for fees alter MS)  $425.00 0.5 $212.50
1042/2020 • Review Reviewed Pr of LEA opposing 57.105 
motion $475.00 0.5 $237.50 
10/02/2020 AU Review Reviews(' Prs Response to Aronberg's request to 
schedule P.105 motion after MSJ $475.00 0.4 $190.00 
10/12/2020 OW Research Researdicaselaw & statutes, re: response to Prs 
Memo of Law $425.00 1.0 $425.00 
10/1a/2020 OW Research & 
Anakfie 
Continued researching caselaw, re: response to 
Prs memo of law $425.00 1.0 $425.00 
10/13/2020 OW Dtatt Created 1st draft of Response to Prs Memo of Law 
and shared w/ Client $425.00 4.0 $1,700.00 
10/13/2020 DW Meeting Discussed w/ AU caselaw and draft response to 
memo 
$425.00 0.5 $212.50 
10/13/2020 AIJ Various Reviewed draft MSJ, discussed draft w/ DAW and 
caselaw $475.00 0.7 $332.50 
10/14/2020 DW Draft Finalized and filed Response to Prs Memo of Law $425.00 1.0 $425.00 
10/14/2020 DW Telephone Spoke w/ Client, re: memo of law $425.00 0.2 $85.00 
10/14/2020 I3W Telephone Spoke w/ client again, re: response to memo of law $425.00 0.1 $42.50 
10/15/2020 DW Attend Hearing Attended hearing. re: Motion to Set CMC; called 
client to discuss $42560 1.5 $637.50 
10/15/2020 DW Various Reviewed email and letter Isom PI, re: settlement. 
Sent copy to Client and called to discuss. $425.00 0.5 $212.50 
cA'Am Pil eLt9PNI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736001

10/15/2020 OW Telephone Spoke w/ Ks counsel, re: settlement $425.00 0.1 $42.50 
10/15/2020 OW Telephone Spoke w/ client, re: Pt's settlement proposal $425.00 0.2 $65.00 
10/15/2020 AU Various Attended hearing, re: motion to set CMC; 
discussed w/ client 
$475.00 1.0 $475.00 
10/15/2020 AIJ Various Discussed Prs settlement proposal w/ DAW and 
then w/ Giant $475.00 0.4 $190.00 
10/15/2020 OW Meeting Discussed Prs settlement proposal w/ AU $425.00 0.2 $85.00 
10/16/2020 DW Various Drafted and shared proposed order wf Prs counsel $425.00 OS $212.50 
10/16/2020 OW Telephone Spoke w/ Prs counsel, re: settlement $425.00 0.2 $85.00 
10/16/2020 OW Telephone Spoke w/ client. re: Prs settlement proposal $425.00 Th 0.5 $212.50 
10/16/2020 OW Meeting Discussed Prs settlement proposal w/ AU $425.00 "0.2 $85.00 
10/16/2020 AU Meeting DiscuSsed Prs settlement PropoSal w/ DAW $475.00 0.2 $95.00 
10/19/2020 DW Various Uploaded proposed order, re: CMC for Judge 
Hefei') $425.00 0.1 $42.50 
10/19/2020 DW Telephone Spoke ve client, re: Prs settlement proposal $425.00 0.2 $85.00 
10/19/2020 OW Telephone Spoke w/ Pt's counsel, re: settlement U25.00 0.1 $42.50 
10/19/2020 AU Meeting Discussed Prs settlement proposal w/ DAW $475.00 0.2 $95.00 
10/19/2020 DW Meeting Discussed Prs settlement proposal w/ AU. $425.00 0.2 $85.00 
10/20/2020 DW Various Reviewed email from PI, re:settlement sent copy 
to Client and called to discuss. $425.00 0.5 $212.50 
10/20/2020 DW Telephone Spoke 'w/ client, re: tettleerient $425.00 0.4 $170.00 
10/20/2020 OW Telephone Spoke w/ Firs counsel, re: settlement $425.00 0.1 $42.50 
10/20/2020 OW Telephone Spoke w/ client, re: settlement $425.00 0.1 $42.50 
10/29/2020 DW Meeting Discussed Ors settlement proposal w/ AU $425.00 0.2 $85.00 
10/29/2020 AU Meeting Discussed Prs settlement proposal w/ DAW $475.00 0.2 $95.00 
10/21/2029 DW Various 
Drafted and filed Motion to Set Hearing en 
As oriberp MS.1; drafted proposed order granting 
motion to set: checked court availability: mailed 
Pr's counsel, re: choose date for hearing 
$425.00 1.0 $425.00 
10/21/2020 DW Revievs Reviewed Order, re: CMC unnecessary 3425.00 0.1 $42.50 
10/21/2020 DW Telephone Spoke wl client, re: media response $425.00 0.2 $85.00 
10/21/2020 DW Telephone Spoke w/ client, re: media response $425.00 0.1 $42.50 
10/21/2020 OW Telephone Spoke w/ client, re: media response $425.00 0.1 $42.50 
10/21/2020 DW Telephone Spoke w/ client, re: media response $425.00 0.1 $42.50 
10/21/2020 DW Telephone Spoke w/ client, re: media response $425.00 0.1 $42.50 
10/21/2020 OW E-mail Sent email w/ Aronberg statement to media $425.00 0.1 $42.50 
10/21/2020 AIJ Meeting Discussed media response w/ DAW $475.00 0.3 $142.50 
10121/2020 DW Meeting Discussed media response w/ AU $425.00 0.3 $127.50 
1022/2020 DW Various 
Reviewed Pt's Notice of Dropping Aronberg as 
party: spoke w/ Client and AIJ, re: notice and next 
steps 
$425.00 0.5 $212.50 
CA/Aronlaesck001446 HEW PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736002

Reviewed Pis Notice of Dropping Aronberg as 
102a'2020 AIJ Various party; spoke w/ Client and DAHL re: notice and next 
steps 
$475.00 0.5 $237.50 
Totals: 74.8 $22.440.00
Tame Entry Sub-Total: $32,440.00 
Sub-Total: $32,440.00 
Total: $32,440.00 
Amount Paid: $0.00 
Balance Due: $32,440.00 
cos 
CNArcritteMill BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736003

• • 
EXHIBIT "F" 
EXHIBIT "F" 
CA/AMPIrfieWL 4A BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02736004

IN. THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
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. 
STATE OF FLORIDA 
COUNTY OF NASSAU 
AFFIDAVIT OF ATTORNEYS' F 
ACIAiBEFORE ME, the undersigned auth p r ed Douglas A. Wyler, Esq., who, after 
being first duly sworn, deposes and say 
1. Affiant is a BS, SCHOL2 & WYLER, LtC, counsel for 
- Defendant, DAVE ARONB e Attorney of Palm Beach County, Florida, ("Aronberg"), 
as well as general counsel totIA Glbrida Prosecuting Attorneys Associatibti, ("FPAA"), and makes 
this Affidavit of his o nal knowledge.. 
2. ant is licensed to practice law in the State of Florida, is an active member of 
the F o in goad standing and has engaged in the practice of law in the State of Florida since 
CASE NO.: I9-CA 4681 
Cci d? '
3. As detailedterein, the services rendered by Affiant and his firm pertain to Affiant's . 
demand letter and:motion for attorneys' fees sent to Plaintiff's counsel pursuant M § 57,105, 
'FlotidiStittotearAmell; 2020;-indefentlititi -gaitistColinritif " " • 
cA ' Arcit etbNiel% BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02736005

. . 
and Plaintiff's October: 21, 2020 Notice of Dropping State Attorney, Dave Aronberg from the 
above-captioned layisuit. See, Exhibits "A" turd attached hcifto... 
4. The totattime Affiant's law firm has expended services rendered to date is 74,8 
• • „ 
hours, however, from: the. date of Defendant Aronberg's 57,105 demand, Affiant'S fiern'has 
expended a total of 42.2 hinna. the42.2)iours'expended since Defendant Aronberg' 57.105 
demand was served, the Affiant 
5. Of the 42.2 hours expended since Defendant Aronberg's 57.105 demand was 
served, the total time Affiant has expended services rendered to date i( 35.4 hours at the rate of 
S425.00 per hour. Likewise, the total time Affiant's law partner rthur I. Jacobs, has expended 
services renderedto date is 6.8 hours et the rate of $475.00 
, ,
6: Accordingly;  since Defendant Aronbcr_ mind was served, Defendant 
14, ,,ArOnberg's cotinsel, , SCHOLZ & W  L , has rendered services in the amount o
of $18,275.00, in conjunction with the def of t s 'nstant action pursuant to § 57.105, Florida 
Statutes. See, Exhibit "C" aitathed 
7. Affiant expects ditional 4.0 hours at $425.00 an hour in preparing for 
and attending the hearing o alto e fees. Thus, the total amount of hourly attorneys' fees the . 
State Attorney is see ' is 46.2 hours fora total of 519,975.00. Additionally, the State Attorney IrT er
seeks a mult4 r of 2. which when applied makes the grand total attorneys' fees sought herein 
539,9 
day of November, 2020. 
FURTHER AFFIANT SAYETH NOT. 
wyietzEwma: N67119979- 
cAthr ff it ettcilkiltil BEACH COUNTY, FL, ABRUZZO, CLERIC. 3/28/2023 1:49:29 PM 
EFTA02736006

STATE OP FLORIDA 
COUNTYpt NASSAU. 
The foregoing instrument was acknowledged before me this 9th day of November, 2020, 
by Do Wyler, Esquire, who is personally known to me and wfio did take an oath. 
otary Public — State of Florida 
Barak R. 1-Ackson 
TOVit It maw Hour, roar • State of 
%al l My Comm. Eiaanputesi4 3 2923 
landed through Net 
Name typed, printed or stamped 
CERTIFICATE OF SERVICE 
. I HEREBY CERTIFY that on thii 9th day 61Noverhbe a copy of the foregoing has V 
ost 4been .electronically filed with the Florida E.:File Portal f - ' n all patties or record herein. 
HOLZ &-WYLER, LLC 
uglas A. Wyler 
Arthur Esq, 
Fla. Bar No.: 10249 
Richard J. Scholz. ESq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq, 
Fla. Bar No:: 119979 • 
961687 Gateway Blvd., Suite 201-I 
Fernandina Beach, Florida 32034 
([Phone Redacted] 
([Phone Redacted] Fax 
Printery: jacobsscholzlaw®comcast.net 
.Attorneys for Defendant. Dave Aronberg 
CA/AroniaerobM0 4S1. H .P.1): PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736007

卫x篡] 
C闷AropH鳓09 蔚枭BEACH COUNTY , FL,—— ABRUZZO , CLERIL 3忽8/2023 1:49:29 I'M 
EFTA02736008

• Friday, Seritember 18, 2020 at 11:09:24 Eastern Daylight Time 
Subject: ' SERVICE OF COURT D0CHMENt•CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, u.ev: 
DAVE ARON BERG ET AL. 
Date: Monday, June 8, 20204 3:58:58 PM Eastern Daylight Time 
From: Douglas Wyler • . .• •• 
To: '[Email Redacted]', smitidg0gtlaw.ciirp,.fiserviceeltiaw.Corn, BoyijianNegilaw.COm; 
[Email Redacted], [Email Redacted] . 
Attachments: 2020-66-08 Arenberg 57.105 bernandand Motion for Attorneys' Fees.pelf 
Court: 
Case No: 
Plaintiff: 
Defendant: 
Title of Documents 
Served: 
Sender's Name and 
Telephone Number: 
Sincerely, 
CliCiallt Court of the Fifteenth Judicial Circuit, in ana for Palm Be 
Florida 
CaseiNo..2020-CA-014681 
CA Florida Holdings, LLC 
Davej Arenberg • 
4); Fla. Stet: § 57.105 Demand Letter 
el Defendant, Dave Aronberg's minion fQL for s~Fees 
Douglas Wyler 
([Phone Redacted] 
Doug Wyler, Esq. 
Scbolzfit Wyler, LLC 
961687 Gateway Blvd., STE 2014 
Fernandina Beach, FL 32034 
[Phone Redacted]. 
[Phone Redacted] (fax) 
Pleasebe advised that this e- y files transmitted with it are confidential attorney-client 
communication or may otherwise ileged or confidential and are intended solely for the individual or 
entity to whom they are essed. If you are not the intended recipient, please do not read, copy or 
retransmit this tommuni bat destroy it immediately. Any unauthcirited dissemination, distribution or 
copying of this co .yrdca is strictly prohibited. S y
Page 1 of 1 
cAmroptettP9xs BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736009

711EIAWORINCCISOI.
JACOaR • PA aitam0ir • 
JACOBS SCHOLZ 8c WYLER, LLC. EIMITEO.LIABIUTY COMPANY CE PI4OrESSIONAL ASSOCIATIONS 
• . ATTORNEYS AT LAW 
• GATEWAY TO AMEUA
• : NOTRO7 OATCWAY SVITC (oh; 
FERNSNDRIA BROM FLOR' IDS oao34. 
TtLI.PRORL CO04) awl -ages 
r.sx rgs. main i41-viive 
June 8, 2020 ' 
ELECT/IONIC & U.S. MAIL 
MendelSolik, Esq.
Greinbuit Inning, P.A. 
5100 Town Center Circle, Suite 400 
Bata Raton, FL 33486 
RE: CA Florida Holdings, LLC v. Dave Aronbe 
Palm Beach County, Case No.: 2019-CA-0 
Dear Mr. Mendelsohn: 
As you are aware our firm represents the interests 
COunty. Florida; in the above referenced matter 
dismissal of your First Amended Complaint 
is made pursuant to'section 57.105, Elori ;es 
As you know, Section St.10 
MONATE O J. SoWL1.144., 
ONCRIAMINE SONCII2 . . ESOINILA,A.Irfiali, SOUCILOR A- 116a 
nberg,.as State Attorney of Paint Beach. 
se of thit letter is to demand the voluntary 
kink"), dated January 17, 2020. This demand 
(1).Upon the court's we & motion of any party, the court shall award a 
reasonable att including, prejudgment interest, to be paid to the 
prevailing part equ amounts by the losing party and the losing party's attorney 
on any claim or se at any time during a civil proceeding or action in which 
the coy s that the losing pang or the losing party's attorney knew or should nVor
have kno a claim or defense when initially presented to the court or at any 
tipttbefo ial: 
' Was not supported by the material facts necessary to establish the claim or 
tense; or
O ly. Would not be supported by the application of then-existing law- to those 
material facts. 
ay. udge Marx granted, with prejudice. Defendant Aronberg's Motion to Dismiss Count II of the 
Plat sirs Coniplaint. Pursuant to the Court s ruling, the Plaintiff's only remaining cause:of action 
consists of Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filiiibetein. 
and its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to. 
establish the claims asserted, and that your claims are not supported by the aPplication of current law 
...to.Said:rnaterial facts._ 
CA/Aroilypith09,1454. ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736010

• • 
' . . • • i . - First and foremost, the Complaint is not supported by the material • facts necessary to establish the claims 'seined because neithei Defendant Aronberg, nor The Office of the State Attorney for the - Fifteenth Judicial: Circuit is  custody or control of the 2006 grand jury materials sought therein. Simply put, the declaratory relief 'sought by the Plaintiff, seeks records from my client. that are impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper patty to • this action because no matter what, he.and his office do not have possession, custody, or control of the requested materials.  • .   . . .. . . • . - . . . . . . In' ddition to the foregoing material facts.that negate the.claims asserted intbe Complajny larclalms .are alio not supported by the application of current law, .SpecificallY, your action fer.dec or relief • fails based on the clear, unambiguous statutory language found in Sectien 905.27.0); Statutes, '• Which states:
When such disclosure is ordered by a emir/ pursuant to subsection(I ) 
case, it .may be disclosed to-all parties to the case and to their anon( 
to their legal associates and employees. However the rand is 
such persons by the court can only be used in the defense or pro 
criminal dose and for no Either ourvose whatsoever. 
Moreover,.even-if the Plaintiff were to prevail in the declare 
to comply With any court order granting disclosure of ; 
Arenberg nor The Office 'of the State Attorney for 
custody,. or control of the 2006 Epstein grand jury - 
Based on the foregoing, if the Complaint is n 
the enclosed Motion for Attorney's Fees w* 
and your firm, recovery of the legal expen 
Please govern yourself accordingly 
A-Douglas A. Wyler, Esq. 
For the Firm 
Encl.: Defendant's tvarrfor Attorneys' Fees 
• 
its 
it0 
ivi I 
latter 
afforded 
ofthe civil or 
Aronberg would be unable, 
documents because neither Mr, 
Judicial Circuit have postettion. 
within 21 days of the service of this letter, 
we will seek as sanctions, from your client 
in defending this frivolous action. 
CA/Alt Pirge 391301 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02736011

&TEE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
AND:FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS; LLC, 
Publisher of the PALM BEACH POST, 
• 
• DAVE AP.ONDEED; as State Attorney of 
.Palm Bench Comity, Florida; SHARON .R. 
BOCKa:s Clerk slid CoMptroller of Palm 
Beach County., Florida. 
Defendants. 
CASE NO.: 19-CAM14681 
cdr 
DEFENDANT. DAVE ARONBERG'S MOT TTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State.lRto alm Beach County, Floridb, byand 
through the undersigned attorneys, moves t u7 truant to Florida Statutes, Section 57..105; 
to award him reasonable attorneys' fees o e d tense of Plaintiff's First Amended Complaint,. 
(the "Complaint"), and asgroun h ould show that on June e, 2020, Plaintiff was served 
a copy of this Motion, to letter from the undersigned. attorney, in accordance with 
subsection (4) of the above, demanding disthissril of the Complaint, at least 21 days prior 
to the filing of di's In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish l 6 t Cdrn faint is withodt support of the facts or the law. 
ORE, Defendant, DAVE ARONEEkb, as State Attorney. of Palm Beach 
Ad, respectfully requests the Courfenter an Order requiring Plaintiff and Plaintiff's 
atto eyi to pay said Defendant's attomeys fees incurred herein after service of this Motion. 
cAlArliteLeb99101 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736012

• 
CERTIFICATE OF SERVICE 
I hereby certify that on this day , 2020, the foregoing was electronically filed 
via the Florida E-File Portal for electronic service on the parties otrec.old herein. 
ScliQ1 2  & tNY•iini Etc 
/s/ Douglas A Wyler 
Arthur LIM, Esquire 
Fla Bar No.: 10.8'249. . 
Richarckl.fiCholi,Esquire 
Fla. Bar No.: 002126 
Douglas A. Wyler 
Fla. Bar No.: 11 
961687 Gateµa Suite 201-I 
Fernandina Beach. .ride 32034 
(904) 261-36 
(904 1 
wiglcomcast.net 
stfor Defendant 
CAthr Tieg,,MEI BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02736013

曲/Aropfl擞，D9JG齄BEACH COUNTY, FL,—— ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736014

CA FLORIDA HOLDINGS, LIC, • 
'Publisher of THE PALM BE4al POST.: 
Plug 115383434 F.-Filed 1:0)21/2020.04:13:35 PM 
• 
' Plaintiff.. 
• . 
DAVE AltONBER0, as State Aitpincy of 
Palm Beach County, Floridk SHARON R. 
BOCK,Iis Clerk and Comptroller of Palm 
Bach County; Florida, 
• Defendants. 
IN THE CIRCUIT COURT OF THE 
FIFIF,ENT11 JUDICIAL CIRCUIT NAND . 
FOR PALM BEACH.CONTY, FLORIDA . . • . . . • . • . • . • • ..
CASE NO.: 50-20197C-A-0146814OOO544B 
DIVISION: AG ,. • 
PLAINTIFF CA HOLDINGS 
NOTICE OF DROPPING STATE /VITO . . y 
. • Plaintiff, CA HOLDINGS, LLC, pursuant Sr Fla. R. . hereby notifies the panics that 
it has dropped State Attorney, Dave Amber's As v f 
pectfully submitted, 
A RONBERG 
GREENBERG TRAI.JIRIG, 
Attorneys or CA Florida jloldiiigc. LLC. Publisher 
• of The Palm Beach Past 
Stephen A. Mendelsohn..Esq. 
401 East Las O1as Boultvard Suite 2000 
Boca Raton, Florida 33486 
Telephone: ([Phone Redacted] 
Facsimile: ([Phone Redacted] 
By: /s/ Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 ' 
mendelsohnstibgilaw:com 
smithVagtlaw.com 
FLServicetalgtlaw.com 
CA/Ar0pte LgeniA59, ALM BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02736015

MICHAEL J GRYG1EL 
(Admitied Pro Ficic:Viee) 
54 Stafe St.,fith Elam 
Albany, Nevi York 12207 
Telephone: (518) 689t1406 
Fac!ini i le: (518)0f541499 
t  ' 
By: Isl Nina D. Bovaiicin 
NINA D. BOYAJIAN. 
(Adinitied Pro kriC Vice) 
1840 Century Park East. Suite I 
• Los Angeles.California 90067 
Telephone: (310)586-77 
Facsimile: (310) 586-7 
bovoliamviairtlaw com 
riv tlaw. 
CERTIFICATE OF ‘ICF, 
I HEREBY CERTIFY that on this 21" daylf October, 2020, a true and correct copy of the-
foregoing has been filed with the Clerk of using the State of Florida e-fding system, which 
will send a 'otice of electroniC service for II ies of record herein 
AS slimai
O TA* X0173410 
kV Stephen A. Mendehohn 
STEPHEN A. MENDELSOHN 
2 
• . . 
CA/AropirOpuso. A  BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02736016

_ EXHIBIT "C" 
CA/Amppe 09, 1 BEACH COUNTY, FL, ABRUZZO, CLERK 3/28/2023 1:49:29 PM 
EFTA02736017

• 
Jacobs Scholz & Wyler, 
961687 Gateway Blvd:, Stlite.201I 
Fernandina Beadh,,t P2034 United States . . 
[Phone Redacted] • 
Dave Aronberg 
Aronberg (SA015) adv. CA. Florida Holdings, LLC 
TimiEribles 
Jacobs Scholz & Wyler, LLC 
Balance 
Invoice # 
Invoice Date 
Payment Terms 
Due Date 
Date '  EE . • Attivihi Description r - Rate •  kotini " gnii TOW. 
11126/2019 DW Retitle* Initial review  of sr./mimeo razspo 1.5 3637.52 
11/2612019 ow Fume... Renewed motion for: . and - . e 
Halele• order grand?, sos.op .. 0 sois.00 
11/262019 OW Teleconference Teleoonference I. re: nse to lawsuit 5405.00 • . 0.5 $2 2.50 
111262019 OW Drah Drafted engege*ent tettriTand sent to dient $42300 at . 5127.$0 
11/26/2019 or Review Revieratd 1 Ra3 localr r  ruleSSiti m $425.00  IA $42500 
11/26/2019 Al.) Review inigarmvierre9cOmplaint 6475.00; .. IA Si P: 139. 
1 urinous AU Meeting Meeting ,SAW to discuss lawsuit and strategy 54750 0.5 ' ' • $237.50 
11/26/3319 ova Meeting i:aspelirG w/ AU to discuss lawsuit ,nd Strategy sizscip as 5212.50 
11/26/2019 AU Teleton r Teleconference w/ Client. re: response to lawsuit 5475.00 0.5 t $237.50 
12/024019 OW mit & . y Research and prep for Motion lo cliimiss seise° io taso.00 
12/02/2019 • all ist Drift mown:ides:nits siissiio co sato° 
12/02/2019 , T ' nterence Teleconference w/ Client. re: Pratt motion to dismiss $425.00 0.5. $21250 
1 I Review Reviewed 1st Draft MTDismi$s 5475.00 • 0.3 • $142.50 
12/07/2019: AU Teleconference Teleconference widient, re: drab motion to 
dismiss
,Seis.00 .0.5 . S211.54 .... . 
121034019 AU Seating Meeting w/ DAW. re: motion to dismiss 5175.00 0.2 . 695.00 
alSit : OW_ Meeting. . .. _ Meting W/. AU, re: MTDiswiss .. Istzsee _ 02 _.:: 05.0k 
DW D0I0
crprispletap Mel drah 01 niolin: n le thsrniss: fled with. 
Cotrl :6425.00' . 0:7 6297.50I* 061201$ 
12/092019 OW Tileconierence : Spoke w/ diem. re: finid draft 01 motion to cresmiss . $435,00 0.5 • :5i12:50 
CAMIllpefflplin462. 
A LIVI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736018

12/062019 DW Teleconference Spoke with Clerk's attomey, re: response . $425.00 • 0.S.  $212.50 
12/0612019 AU Renew Reviewed final drahMIDismiss • 3475.00 6.2 • .- - '495.00 . ... 
12/06/2019 AU Review Reviewed Cark's MTDiimiss 5475.00  0.2  395.00 
'2/13/2019 DVV. Revtevi Revlinved Clerk's- Motion to Dismiss 5425.00 0.5 5212.50 
0.1/16/2020 OW Review Reviewed Order Setting Hearing on Defendants' 
MTDisrniss 5425.00 0.1 '342.50 
01/1612020 OW Review Reviewed motion for pro lac Vice 5425.00 0.1 542.50 
01/17/2020 ow Review Reviewed Pis Amended Conoilaint  542500 1.0. 3425.00 
01/17/2090 DVi Teleconference Spoke.toiln cient, re. Arneeded Complaint 5425.00 0.5 3212.50 
01/172020 . DW Review Reviewed. Pre notice of filing 542500 0.1 $42.50 
01/20/2020 ' AU Review ReViewed Prs Ani Compi 5475.00 0.3' 314250 
01/21/2020 
, . 
OW Review Reviewed kidge kian's Order Canceeing 
MTDiscnies Hearing 3425.00 0.1 .3.450 
01/21/2020 OW Review Revieived Pt's Objection to Defendants' MTDessysiss 7 -23495.00 0.2 . 446.60 
01/21/2020 OW Teleconference Spoke with client: re: Amended complaint l $425.4" 0.5 $212.50 
0121/2020 AU Meeting Meeting W/ CAW, se: response to Am. Camp wit65.00 0.2 395.00 
01/21/2020 OW ' Meeting Meeting w/ AU, re: response to Am. Cork . 1 3425.00 0.2 585.00 
(1122.2020 OW Review Reviewed Order granting pro had'. gad V 3425.00 0.1 542.50 
01/2212020 DW Reiearch & Draft Resear ched 
Complaint 
and drafted 
* S i
3425.00 1.0 $425:00 
01/232020 OW Teleconference SP°ke veith Clines att r is to 
amended complain 5425.00 0.2 585.00 
01/24/2020. DW Various Completed Ans •  ' Amended Completed
Complaint: MedWith : sern copy to Ctienl 1.0 $425.00 
01/24/2020 OW Draft Drafted and tetairectlfce of UnaVailabelity 5425.00 0.4 3170.00 
01/24/2020 AU Review Reviewed final Answer/MTDismiss 3475.00 0.2 395.00 
01/27/2020 OW RIVKIN, ..: Revievreclaerlis Answer/MTDismiss 342500 0.3 3127.50 
02/032020 OW Review Revisited Order setting nearing-on Dels' 
MTOssmiss • . . . 
. 
5425.00 01 542.50 
021032920 OW 't .7/ .• TelKonference Spoke w/ client re: order setting MTDrsmiss . . hearing for March 24, 2029 542$00 0.5 $212.50 
03/13/2020 OW__ __ . Review.. Reviewed Pis Opposition to Arenberg AATOismiss 
8 Clerk's MTOistnist $425.00 1.5 5637.50
03/132020 AU Review Reviewed Pri Opposition to Arenberg MTDismiss 
& CIerkS MIOisMise 5475.00 0.7 5332.50 
03/18/2020 DW Teleconference Reviewed email tram Pis counsel, re: motion to 
continue hearing $425.00 0.1 $42.50 
03/18/2020 OW Review Reviewed Pis unopposed motion for conlinuance 342500 0.1 342.50 
03/18/2020 DW •E-mail Emails et/ Clerks counsel, re: Prs request to 
continue hearing 
3425.00 0.2 14500 
03/19/2020, OW Email respoolidReviewed email from P1. re: agreed order & . 5425.00 0.1 542.50 
03/20/2020 DW Review Reviewed Courts agreed order continuing hearing 5425.00 0.1 $42.50 
CA/ArO i?pirfat.0014fia 
PALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736019

'04/21,2929 OW Review 
RevieweDDrder htealisrdiding hearing on Deli 
lArDelfillees Sinc ip. Oil . _ .5° 
' 
04,214-02o ow Teie‘ nstionc. Spoke ;f ora Jlentlit;z : ofider:teseheduSno MTDismiss 5425.00 0.0 
. 
$127. SO 
0412.172.020 :. 4i •Rev_feir Reviewed Ordrii reseliadulingMTDieriess hearing S475.00 ' 4.14  $47.50 
0920080 ''. 
.. 
r20! OS,* Reels-end order set n* Zeornhearing, re: : 
IFOismiss 542840 0.1 
.. . 
. 542.50 
OraingO2O bw  Teleconference Spoke w/ Client. re: hearing a be via Zoom $42.5.00 .,• • . - 02 .. 
.. . 
%SOO 
.agr2WOWO : OW tWvie* z. i3eviswoo Clerk's Nino: orange olatty c4 reraard  $425.00 0.1 • ..$4250 . 
irafer4D20 : OW 200MinferenCe Sp.okeWith Clerk's neiv (*vitae]. NicoriFingeihtit' : 025.00 505.0.0 
052 ow mail Email02020 Reviewed PS email, re: cases and authorilies for 
MIDiSMiSS hearing: responded SilO5.004, 41 . , S42.50 
0518,02080 OW. Preparation Began oral argument prep for 6/8 MTDismiss
healing 
Cillic ill06/01/2020 OW E.rnall viewed Re email from Judge Marx's JA and 
responded e 0.1 $42.50
06+01/2020 'OW Various 0435.66 ,ReVicrived Prs,500+ page binder, re: MT 
popped iOr heating 
. 
3.0 3O766o 
.06/02/2080 , OW E.mal Drafted and sem email to dient, re: 
tomorrow • $425.01) 0.1 '548.50 
. 
66410/2020 OW: Mend Hearing Prepped for and attended SATOH he Ma 
zoom / 
--e...‘, )'• 
1425.60. 1.5 ; 63759 
0602020 ' OW Teleconference Spoke w/ Client. re: debit!! MT hiss hearing $4a00 ' 0.D $212.50 
0620020200002/8020 OW Email Emailed.000rtesy copies d arnberg's Answer arid 
MTDismiss to Judge gag 
.. 0o 0.1 542.50 
06f03/2020 - OW E.Mall Revieked respcinseDoni Chem and repaed 04:115.0°' 6.1 542.50.
06/032020 AU Attend Hearing Attended MTDismiss hearing via Zoom $475.00, 1.0 .$47.5.00 
00003/2020 AU Review Reviewed order granting MTITismiss w/ prejudice $470.00. 03 . : $142.00 
06/08/2020 OW Review Reviewed Courit0tder Granting Defendants 
MTDismiss CouM HAW Pritlefice. 5415.00 0.5 
.... , 
52.12.50 
06/08/2020 OW Varies* Shahad fader w/ orientandspoice vd: re: result and 
plan going fonvard, ref 57.105 . • 
',.,..,;., aco.Y.Y .0.5: 821250 
Researched § 57.105 Fla. Star: drafted 57.105 
demand letter and proposed noon for attorneys' - lees/sanctions: Served IfTs counsel will;demand 
tenet and *Posed motion. 
$42DOD 2.0 V15.0:00 
atiter25 e 
Meeting w/ DAW. re:arder & 57.106 . $475.00 in $142.50 
'06108/4020Sif . Meeting w/ AU, re: Order A S7.105.2 .° 42§'45°' .0.3 . ,s127.56 
0605/2020 AU Review Reviewed 5T.165 demand and proposed meson Son 
tauxtion 
sins .® 02, $85.06 
066/02020 OW 'Various Rainey/0 noraol change Of attorney, re: credit 
caledand spoke rd new counsel:Cynthia Guerra ammo . • - 94 5.127.50 
08211/8020 OW Various 
ReViewed Prs letter refusing to voluntarily dismiss 
amended complaint despite 57:105 demand: called 
and spoke w/ client. re: ers refusal& next steps 
$42500 1.0 
.
$425.00 
cAll "PirLEV.33eL6A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736020

08232020 OW E.-mail Sent 'client Copy of Prs letter refusing to dismiss 
complaint,
Reviewed 
' 3.4s .06 0,1 $42.50 
0523/2020 AU• Review Prs letter reiterate to dismiss Courd vAm. 
Cornet $475.00 0.1 $47.50 
07/012020 OW Various 
Spoke vr/ client, re: firing of 57.105•enotion for 
feesisanctioni; filed Motion for ationleys' fees 
based on Prs failure tia Voluntarily dismiss 
amended complaint count I 
$425.00 0.5 $212.50 
01/022020 DW E-mail Email to client, re: affidavit and summary judgment  $425.00 0.1 $42.50 
07/082080 DW Teleconference $425.00 Discussed w/ Client drafting and fifing Metier'. Ion.
Summary Judgment and MSJ evident 'PI $297..50 
07/052020 AU Teleconference $475.00 Discussed w/ Client drafting andfifing Motion for 
Summary Judgment and MSJ, evidence • 4 z0.7 
."'Ilk 
$332.50 
07/10.2020 OW Draft Created 1st draft of Arenberg Affi.davit: shared w/ 
Sent $4."54), N, 1.0 $425.00 
07/10/2020 AIJ Various Reviewed draft affidavit and discussed wi OAW --24.O5-°° 0.3 $142.50 
0 7/1012020 DW Meeting biscusCed draft affidavit w/ ALI III!, $425.00 02 585.00 
07/13/2020 DW Review Reviews Prs Request to ProdUce. re: Clerk area_ $425.00 0.1 $42.50 
0 7/13/2020 OW Teleconference Spoke WI Clerk's counsel. re:Request to)(ioducel $425.00 0.2 585.00 
072 OW Review Reviewed Prs Amended Request to:produce. \ /  - - Clerk /7/2020 - 1. • 
 $425.00 a i s42.50 
0727/2020 OW Teleconference 
,- 
Spoke  col Clerk's counsel. re;--Amerided Request to 
Produce .. 
$42500 0.1 $42.50 
07/28/2020 DW Draft Revised Arenberg Oda* $425.00 0.5 $212.50 
07/292020 OW Draft Finalized Arenberg Affidavit and sent to client $425.00 0.5 $212.50 
07/29/2020 DW Research 8 
Preparation 
Research and prep for Motion fOr Summary 54.25.00 1.0 $425.00 
07/30/2020 DW Various Reolihreftexectiled Arenberg Affidavit $425.00 0.1 542.50 
07/30/2020 OW Draft Began riellnig Motion for Summary.Judgment $425.00 2.0 5850.00 
08/05/2920 DW Draft ..frontinned drafting Motion for Summary Judgment $425.00 1.0 $425.00 
08/07/2020 OW Review ,, $425.00 
i 
Reviewed email from Plaintiff attempting to set 
hearing' on 57.105 motion for fees/sanctions 0.1 $42.50 
08/10/2020 OW Eirrall Seal reSponsive ernaff to Prs counsel 5425.00 0.1 $42.50 
08,17/2020 DW Meiligg Discussed draft MSJ w/ AU $425.00 0.2 $85.00 
08/17/2020 AU Various Reviewed draft MSJ and (net w/ OAW to discuss 5475.00 0.5 $237.50 
08/18/2020 OW Draft Finalized Molion.for Summary Judgment'. feed W/ 
court along with Arenberg affidavit $425.00 2.0 $850.00 
08/272020 DW Teleconference 'Spoke wl Clerics counsel. re: request to produce $425.00 0.1 $42.50 
09/01/2020 OW Various Reviewed Prs email and acceptedconference cae 
invite lot 92120 $425.00 0.1 $42.50 
09/02/2020 ._. _.. .. . DW Review Renewed Clerk's response to request for 5425.00 0.2 $85.00
09/022020 OW Teleconference 
Spoke ver Prs counsel, re: dispute as to whether 
MSJ Should be neard before 57.105 lee motion or 
vis versa - aill was unsuccessful - 
$425.03  0.5 $212.50 
CA/Arc:1311Tb° BIA49.511.1 BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736021

03/022020 . AU Meeting Diseased w/ DAW.plione cillnPis cpyinol • 
. . 
$.474•00. 0.2 • $95.00 
09/02/2020 OW . .Meeting . 
.. .. 
Discussed ve/AUtionecall vi/ Pl's counsel $425.00 .0.i ' $85.00 
09/162020 DW E-mail 
Reviewed 
 $425.00 0.1 $42.50.
email from Pre teunsel requested 
Arenberg to withdraw sannons motion w/o 
penickee - 
09/17/2020 OW Meting Discussed w/ AU filing motion for CMC $425.00 0.1 $42.50 
09/17.2020 AU Meeting Discussed w/ DAW filing motion log CMC . $475.00 0.1 $47.50 
09/113/2020 ow Various Dialled .and riled motion to set case management 
conference; re: MSJ tiler Fee hearing isi $425.00 0.5 : $212.50 
09452020 ow &mai 
Region:led to Prs 94620 email and refund to - 
wittidraVe. 57. iO5 (notion; provided copy Of motion to 
set CMC andenilable dates for hearing 
$425.00 0.1 542.50 
09/41/2020 OW Email Ile:; st Frt's tined in  that 57.105 motion be • • withdrawn 5425.00 0.1 542.50 
09118/2020 OW E-mail 
RePTed  to PIS counsel that the 57.105 motion for 
sant:liens will not be  and asking for 
tesporde, re: CMC 
*a; 0.1 542.50 
09/18,2020 OW Email Sent client copy of email eichange we Pre counsel; 
called and spoke w/ Client 25.00 0.5 $212.50 
09222020 DW Various Drafted and filed Hence of Hearing on.10/1 
tip Court Can: $130k0 1W client, re: flearingiel4t 
$425.00 0.7 $297.50 
10/022020 OW Review Re:dewedPIS Memo of Law apron/Ong dronberg's 
57.105 motion for teesisancdons • S425.00 0.7 5297.50 
10/0212020 OW Review Reviewed prn Responee to Aropliels request lo 
schedule 57.105 motion for lees after MSJ • $425.00 05 $21Z 50 
10/02/2020 AU Review Reviewed PIS Merno of Law opposing 57.105 
motion .-  5075.00 0.5 11237.50 
1002/2020 AU Review Reviewed Pit Rename to Arenberg 's request to 
schnrie j57.105 motion after MSJ $475.00 0.4 5190.00 
10/12/2020 OW Research -Reseal* canine t statutes, re: response to Prs . .„, 
Memo of Law 5425.00 1.0 5425.00 
10/132020 DW Research a 
Analyze ,7,:z-r
begieriiima researching caselaw, re: response to 
Prs memo of law.  5A25.00 1.0 5625.00
10/13/2020 OW ""/ Orals 7 . I'v 
Created 1St draft cif Response to PIS Memo of Law 
and shared ve/ Client 
$4g5.00 4.0 51.m® 
10/3/2020 OW Meeting Discussed iv/ AU caselaw and drahresponse to 
memo 5425.00 0.5 5212.50 
10/13/2020 AU Various Reviewed (hell MSJ. discussed drali w/ DAW and case law $475.00 0.7 $332.50 
10/142020 - OW Draft Financed and filed Response to Ms Memo of Law 5425.00 1.0 $425.00 
10142020 DW Telephone Spoke wi client. re: memo of law $425.00 0.2 $85.00 
10/142020 OW Telephone Spoke iv/ client again, le: response to memo of law $425.00 0.1 $42.50 
10el 5/2020 OW Mend Hearing • Attended hearing re: Motion to Set C Caned' '  - • lAt • 542500 15 __ _ 563730 
10/192020 OW Various Reviewed emaii.and tenet frOm Pt, re: settlement. 
Sent copy to and Client  called to discuss. $425.00 0.5 . $212.50 
CA/AropRoipilt466 ALM BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736022

10/152020 OW Telephone Spoke vie Prs counsel, re; settlement $425.00 0.1 . $42.50 
10/15/2020 OW Telephone Spoke wider% re: Prs settlement proposal $425.00 0.2 $85.00 
10/15/2020 AU - Various Attended hearing, re: motion to set CMG: 
discussed w/ client 
$475.00 1.0 S475.00 
10115/2020 AU Various • 
Discussed Prs settlement proposal wl DAW and Discussed
Wen wi Client 0.4 $190.00 
10/15/2020 OW Meeting Discussed Ks settlement proposal w/ AU $425.00 0.2 585.00 
10/162020 OW Various Drafted and shared proposed order w/ Prs counsel $425.00 0.5 $212.50 
10/162020 OW Telephoto Spoke v/ Prs Counsel, re: settlement 4425.60 0.2 : sastio 
10/1612020 DW Telephone Spoke wr client: re: Prs settlement proposal $425.00 4.5 $212.$0 
10/16/2020 OW Meeting Discussed Pt's settlement weasel w/ AIJ $425.00 62 $85.00 
10/16/2020 AU Meeting Discusied Rs settlement proposal w/ OAW $475.00 0.2 $95.00 
10/19/2020 DW Venous Uploaded proposed order, re: CMC for Judge 
Halele 
1 
_A‘tor00 / 0.1 542.50 
10/19(2020 OW Telephone Spoke w/ client, re: Prs settlement proposal  $425..00 0.2 $85.00 
10719/2020 OW Telephone Spoke w/ Prs counsel, re: settlement .00 0.1 $42.50 
10/19/2020 AU Meeting Discussed Prs settlement proposal w/. DA/Ic $475.00 0.2 $95.00 
i0/19/2020 DW Meeting Discussed Prs settlement proposal A $425.00 0.2 $85.00 
10170/2020 OW Various Reviewed email from Pl. re: 1 Reviewed
to Client and called 1p 6 0.5 $212.50 
10/20:2020 DW Telephone Spoke w/ client. re: sent: $425.00 0.4 $170.00 
10/20/2020 OW Telephone Spoke wi Prs counsel, reNttl t* $425.00 0.1 $42.50 
10/20/2020 DW Telephone Spoke.wf client. re: settlement 5425.00 0.1 $42.50 
1020/2020 DW Meetihg Discussed Prs setllemeni proposal w/ AU $425.00 0.2 585.00 
1020/2020 AU Meeting DiscuSeed Prs settlement rxoptlsal w/ DAW $475.00  0.2 $95.00 
1021/2020 OW Various 
Deaftea WA* Motion to Set Hearing on 
/yonberg MSJ: drafted proposed order granting 
motlonlo set: checked court availability; emaleil 
Pllitbunsel, re: choose date for hearing 
5425.00 1.0 $425.00 
10/21/2020 OW Review Reviewed Order, re: CMC unnecessary 5425.00 0.1 $42.50 
1021/2020 OW Telephone 'iv Spoke w/ dent. re: media response 5425.00 0.2 $85.00 
10/21/2020 OW Telephone Spoke client. re: media response 5425.00 0.1 $42.50 
10/21/2020 OW TelephOne Spoke w/ client, re: media response $425.00 0.1 $42.50 
1021/2020 OW Telephone Spoke w/ client. re: media response 5425.00 0.1 542.50 
1021/2020 OW Telephone Spoke wr Oen!, re: media response $425.00 0.1 $42.50 
10/212020 OW E-mai Sent email vet Arenberg statement to media $425.00 0.1 642.50 
1021/2020 AU Meeting Discussed media response w/ OAW 5475.00 0.3 $142.50 
10/21/2020 OW Meeting Discussed media response w/ AU 5425.00 0.3 $127.50 
..._, . _ _. _ 
10/22/2020 
.._-.. ..._ 
OW 
__ .... 
Various party: spoke W/ Client and AU, re: notice and next 
steps 
5425.00 0.5 $212.50 
CA/Aropirty599t4A7 
ALIA BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736023

. . , . 
Otevie:wed Pre Model of Dropping Arenterg • • . . as . •
70/222020 AU Various party' epees' wi Giese,  and DAVy. re: notice- lane flex! S4.7i00 e' 05 
. .• 
.50 
- 
4400: 
tine Entry Sub-75 qt: $32,4140.00 
• Sub-total: 142,440.00 
Amount Paid: $0.00 
BaliMmioue: $32,440.00 
ANN (
CA/A[1610,1.46 Lm 8. A BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736024

• • 
EXHIBIT "G" 
Cog
A
EXHIBIT "G" 
CJVAMPh leilieffil BEACH COUNTY, FL, ABRUZZO, CLERIC 3/28/2023 1.49.29 PM 
EFTA02736025

DIC us arras or 
ASSOCIATES. PA. 
Jarmo* I. JACOBS 
JACOBS- SCHOLZ 8c WYLER, LLC. MIMEO umnurr COMPANY OF PAOFOSSIONAI.ASSOC!ATIONS 
• ATTORNEYS AT IAN 
OATOWAY.i0 ^MOJA 
fl it., *AMWAY DINO:. SUITE 101.! 
FESCHAIthIXA BRACikEL3IttiLL 02034 • 
Itt.CPMONE <004) 141-303 rig' MO. II)04) Eel .7.79 
November 26, 2019 
Office of the State Attorney 
15th Judicial Circuit 
Attn: Jeanne Howard 
401 North Dixie Highway 
West Palm Beacli, FL 33401 
Re: CA Florida Holdings, LLC v. Dave Aronberg et al. 
Case No.: 2019-CA-01468I 
Dear Mrs. Howard: 
The purpose of this letter is to confirm that Schol C will represent you regarding the 
above-referenced matter. 
MGM ARO 4. SCHOLZ. P.A. 
A. HARD J. S.C•001.2 
Oin.04.JUB A. WYLCA. PA. 
GOOGAAA A one. 
Our fees will be contingent upon our success iyius att You will not be liable or required to pay any 
monies to our office unless we are successful in our representationof you regarding the above-referenced 
litigation and receive a court order awarding attorneys' fees. 
Accordingly, should we be successful in this matter, you agree to be billed for the time incurred in defending 
this action at our current hourly rates, At this time, our current hourly rates are: S475.00/hour for senior 
partners, S425.00/hour for other partners; S375.00/hour for associate attorneys, and $l25:00/hour for 
paralegal tithe.
Furthermore, the attorneys' fees paid to our firm shall be calculated by the above listed hourly rates 
multiplied by the nunibei of hours expended in defending this action or the total fee mandated and awarded 
by the court order herein, whichever is greater. 
By signing below; you agree to the terms as set forth above. Please return a signed and dated copy of this 
letter to tthr.office. If you have any questions or concerns, please contact our office. On behalf of the 
firm,,weart proud to represent you in this matter. 
Sincerely, 
Douglas A. A. Wyler, Esq. 
For the Firm 
AlLiejb
Date 
CA/AwiteRM IRI BEACH COUNTY, FL, ABRUZZO, CLERK. 3/28/2023 1:49:29 PM 
EFTA02736026