Court Records
Filing # 198838685 E-Filed 05/21/2024 03:20:00 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 50-2019-CA-01468I-XXXX-MB DIVISION: AG CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST, Plaintiff, v. ABRUZZO, as Clerk and Comptroller of Palm Beach County, Florida, Defendant. CLERK OF THE CIRCUIT CO MPTROLLER'S ANSWER TO THE SECON D COMPLAINT Defendant, Abruzzo in his acity as the Clerk of the Circuit Court & Comptroller, Palm Beach County (th by and through his undersigned counsel, hereby files his Answer to the Second omplaint and states as follows: JURISDICTION I. Para ph 1Yodtains a legal conclusion and characterization of this action to which no response is i To the extent a response is required, the Clerk admits that this Court has jurisdictiohfQ s action. PARTIES 2. The Clerk admits the allegations contained in Paragraph 2. 3. The Clerk admits the allegations contained in Paragraph 3. FILED: PALM BEACH COUNTY. FL. ABRUZZO. CLERK. 05/21/2024 03:20:00 PM EFTA02736993 INTRODUCTION 4. Paragraph 4 contains a characterization of the Palm Beach Post's (the "Post") action to which no response is required. To the extent that a response is required, the Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 4. 5. Paragraph 5 contains legal arguments and a characterization of thi to which no response is required. To the extent that a response is required, the e s the Post to section 905.27, Florida Statutes as the statute speaks for itself a information sufficient to form a belief as to the truth of the rem • • a ations. 6. Paragraph 6 contains legal arguments and zation of this action to which no response is required. To the extent that a res e r uired, the Clerk refers the Post to c‘ n issection 905.27, Florida Statutes as it speaks 1 d is without knowledge or information c m sufficient to form a belief as to the truth e re ining allegations. F BACKGROUND 7. The Clerk is wit ut wledge or information sufficient to form a belief as to the irltruth of the allegations co ' in Paragraph 7. A. First Ea ex Crimes Investigation, Indictment, and Plea Agreement: 2005-2008 Niiiiitekledc is without knowledge or information sufficient to form a belief as to the truth of th Ilegations contained in Paragraph 8. 9. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 9. 10. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 10. ut knowledge or Page 2 of 10 EFTA02736994 truth of the allegations contained in Paragraph 13. II. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph II. 12. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 12. (1) Police Chief Reiter's Letter to the state Utortitn. 13. The Clerk is without knowledge or information sufficient to form as to the AS 14. The Clerk is without knowledge or information suffciFfiito a belief as to the truth of the allegations contained in Paragraph 14. /IN (2) The July 2006 State Grand Ju P(esentation. 15. The Clerk is without knowledge or i 'olt sufficient to form a belief as to the truth of the allegations contained in Paragrapc 16. The Clerk is without kno ge o nformation sufficient to form a belief as to the truth of the allegations contained i a 16. 17. The Clerk is wit ut wledge or information sufficient to form a belief as to the truth of the allegations co in Paragraph 17. 18. lerk is ithout knowledge or information sufficient to form a belief as to the truth of the a ns contained in Paragraph 18. e Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 19. (3) The FBI's Investigation and Epstein's Non-Prosecution Agreement With Federal Authorities. 20. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 20. Page 3 of 10 EFTA02736995 21. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 21. 22. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 22. 23. The Clerk is without knowledge or information sufficient to form a belief as to the A truth of the allegations contained in Paragraph 23. A ,24. The Clerk is without knowledge or information sufficient t belief as to the truth of the allegations contained in Paragraph 24. 25. The Clerk is without knowledge or information ie form a belief as to the truth of the allegations contained in Paragraph 25. 26. The Clerk is without knowledge or i 'ci sufficient to form a belief as to the ge truth of the allegations contained in Paragrap 27. The Clerk is without kno o nformation sufficient to form a belief as to the truth of the allegations contained irr a f 27. 28. The Clerk is wi ut wledge or information sufficient to form a belief as to the 1 51truth of the allegations co ' in Paragraph 28. T7 Crime Victims' Rights Act Litigation. 29. lerk is without knowledge or information sufficient to form a belief as to the truth o ations contained in Paragraph 29. 30. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 30. 31. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 31. Page 4 of 10 EFTA02736996 truth of the allegations contained in Paragraph 34. 32. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 32. 33. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 33. 34. The Clerk is without knowledge or information sufficient to form a belief as to the A S9B. Second Epstein Sex Crimes Investigation, Indictment, Sui • • 1 . 35. The Clerk is without knowledge or information suffici rt o a belief as to the truth of the allegations contained in Paragraph 35. li ,36. The Clerk is without knowledge or inform o ci s ient to form a belief as to the ktruth of the allegations contained in Paragraph 36. iSlis v37. The Clerk is without knowled fo ation sufficient to form a belief as to the is r truth of the allegations contained in P h 3 38. The Clerk is witho e or information sufficient to form a belief as to the truth of the allegations contain graph 38. 39. The Clerk ' out knowledge or information sufficient to form a belief as to the truth of the alleg s con fined in Paragraph 39. 40. lerk is without knowledge or information sufficient to form a belief as to the truth o ations contained in Paragraph 40. 41. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 41. Page 5 of 10 EFTA02736997 C. The August 27. 2019. SDNY Hearing: Epstein's Victims Speak. 42. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 42. 43. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 43. 44. The Clerk is without knowledge or information sufficient to form as to the truth of the allegations contained in Paragraph 44. 45. The Clerk is without knowledge or information suffic. c0 e4Ct 'belief as to the truth of the allegations contained in Paragraph 45. 46. The Clerk is without knowledge or inform cs itfient to form a belief as to the truth of the allegations contained in Paragraph 46. to fris„ 47. The Clerk is without knowled fo c ation sufficient to form a belief as to the truth of the allegations contained in Pa h 4 ?s; 48. The Clerk is witho e or information sufficient to form a belief as to the truth of the allegations contain in P graph 48. D. The August 27,2019, SDNY Hearing: Epstein's Victims Speak. (1) The Palm Beach Post Has Reported Extensively On Epstein's ‘N -Crimes For Nearly 15 Years. Clerk admits the allegations contained in Paragraph 49. 50. The Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 50. 51. The Clerk admits that the Post has extensively investigated and reported on the allegations against, the law enforcement investigation of, and the crimes committed by, Epstein and his co-conspirators. The Clerk, however, is without knowledge or information sufficient to Page 6 of 10 EFTA02736998 form a belief as to the truth of the remaining allegations contained in Paragraph 51, including subparts and Exhibit 1. 52. The Clerk admits the allegations contained in Paragraph 52. (2) The Palm Beach Post's Standing and the Public Interest. 53. Paragraph 53 contains legal arguments to which no response is required. To the extent that a response is required, the Clerk is without knowledge or information sd tt to form a belief as to the truth of the allegations contained in Paragraph 53. AS - 54. Paragraph 54 contains legal arguments to which no r p n required. To the extent that a response is required, the Clerk is without knowled )in anon sufficient to form ia belief as to the truth of the allegations contained in Pam h \ A55. Paragraph 55 contains legal argumen n c cterization of this action to which no response is required. To the extent that a e quired, the Clerk is without knowledge or information sufficient to form a belie to t th of the allegations contained in Paragraph 55. 56. Paragraph 56 co ins e al arguments and a characterization of this action to which no response is required. extent that a response is required, the Clerk refers the Post to section 905.27 as statut speaks for itself. The Court's Jurisdiction To Declare Rights And Construe Statutes. 57>> Paragraph 57 contains a legal conclusion to which no response is required. To the extent that a response is required, the Clerk refers the Post to section 86.011 as the statute speaks for itself. Page 7 of 10 EFTA02736999 58. Paragraph 58 contains a legal conclusion to which no response is required. To the extent that a response is required, the Clerk refers the Post to section 86.011 as the statute speaks for itself. 59. Paragraph 59 contains a legal conclusion to which no response is required. To the extent that a response is required, the Clerk refers the Post to section 86.011 as the statute speaks 44,4' COUNT 1 N C id(Declaratory Relief — Florida Stat. Sections 86.01 e 60. The Clerk re-alleges and reincorporates its respo to graphs 1 through 59 as if fully set forth herein. 115, 61. Paragraph 61 contains a characteri is action to which no response is c v required. To the extent that a response is t Clerk admits that the Second Amended ., Complaint purports to be an action for d ratoN relief pursuant to Chapter 86, Florida Statutes, and other supplemental relief. 62. Paragraph 62 c fain g characterization of this action to which no response is rrequired. To the extent th pone is required, the Clerk admits that the Post is requesting that the Court declare uant Fla. Stat. Sections 905.27(1) and (2Xc) that it is entitled access to the testimony, m and other evidence presented in 2006 to the Palm Beach County grand jury. he Clerk admits that the Post has sought access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury. As for the remaining allegations, the Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations. for itself. Page 8 of 10 EFTA02737000 64. Paragraph 64 contains a legal conclusion to which no response is required. To the extent that a response is required, the Clerk is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 64. 65. Paragraph 65 contains legal arguments and a characterization of this action to which no response is required. To the extent that a response is required, the Clerk refers the Post to CA Fla. Holdings, LLC v. Aronberg, et at, 360 So. 3d 1149 (Fla. 4th DCA 20 he matter 0 a belief as to the speaks for itself. 66. The Clerk is without knowledge or information suffici truth of the allegations contained in Paragraph 66. COUNT H (Florida Stat. SecailS, it67. The Clerk re-alleges and reinco 1 ts responses to Paragraphs I through 66 as if fully set forth herein. 68. The Clerk is witho e or information sufficient to form a belief as to the truth of the allegations contain in P graph 68. 69. Paragraph ms legal arguments and a characterization of this action to which no response is re T the extent that a response is required, the Clerk admits that the Post is requesting th t it a. t e public be granted immediate access to the testimony, minutes, and other evide ted in 2006 to the Palm Beach County grand jury. 70. Paragraph 70 contains legal arguments and a characterization of this action to which no response is required. To the extent that a response is required, the Clerk refers the Post to sections 905.27(1Xc) and (2Xc) as the statutes speak for themselves. Page 9 of 10 EFTA02737001 Dated: May 21, 2024 Respectfully submitted, CLERK OF THE CIRCUIT COURT & COMPTROLLER, PALM BEACH COUNTY By: s/ Collin D. Collin D. Esq. (FL Bar No 1 8081) Clerk of the Circuit Court & Co Palm Beach County P.O. Box 229 West Palm Beach, FL 3 Tel.: ([Phone Redacted] E-mail: eservice®rn chclerk.com CERTIFICATE OF SE I hereby certify that on May 21, 2024 the f following via the Florida ePortal System: Stephen A. Mendelsohn Greenberg Traurig, P.A. 5100 Town Center Circle, Suite Boca Raton, FL 33486 E-mails: mendelsohns gtlaw om; [Email Redacted] Nina D. Boyajiant Greenberg Trau 1840 Centu Los Ang E riveraal t, Ste. 1900 0067 ann®gtlaw.cotn; law.com ti ocument was furnished upon the Michael J. Grygiel Greenberg Traurig, PA. 54 State St., 6th Floor Albany, NY 12207 E-mail: [Email Redacted] By: s/ Collin D. Collin D. Esq. Page 10 of 10 EFTA02737002