{"efta_number": "EFTA02734027", "page_count": 338, "url": "https://epstein-data.com/EFTA02734027", "pdf_url": "https://epstein-data.com/pdf/EFTA02734027.pdf", "pages": [{"efta_number": "EFTA02734027", "page_number": 0, "text_content": "Filing II 132529617 E-Filed 08/12/2021 10:20:22 AM\n\nIN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of THE PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.:\nDIVISION:\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\n\n2019-CA-014681\nAG\n\ncos\n\nDefendants.\n\nA.\nAMENDED MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT DAVE\nFOR ATTORNEYS' FEES\nARONBERG'S AMENDED MOTI‘\n7\nDefendant, DAVE ARONBERG, asj \\e tt ey of Palm Beach County, Florida, (the\n\"State Attorney\"), by and through co\n\nI\n\nw, hereby submits the following Amended\nded Motion for Attorneys' Fees, as follows:\n\nMemorandum of Law in Support\n\nE\n\n,,,,y L NE & BACKGROUND\n\n1.\n\nOn Nove\n\nClerk seeking to\n\"furthering\nin 20\n\n2019, Plaintiff filed a Complaint against the State Attorney and\n\nrivate right of action under Fla. Stat. § 905.27, in the interest of\nto compel disclosure of the testimony, minutes, and other evidence presented\n\nalm Beach County grand jury, as to Jeffrey Epstein, (the \"Requested Materials\").\n\n[DelExA-1).\n2.\n\nOn November 26, 2019, the State Attorney and his office received an engagement\n\nletter and attorney-client contract from the undersigned, which was later executed. [Def.ExA-2].\n\n°** FILED: PALM BEACH COUNTY, FL\n\nABRUZZO, CLERK. 08/12/2021 10:20:22 AM ***\nEFTA02734027\n\n\f", "char_count": 1409}, {"efta_number": "EFTA02734027", "page_number": 1, "text_content": "3.\n\nOn December 6, 2019, the State Attorney filed his Motion to Dismiss, which put\n\nPlaintiff on notice that \"Defendant Aronberg is not in custody or control of the [Requested\nMaterials] and is therefore not a proper parry to this action.\" [Def.Ex.A-3].\n4.\n\nOn January 17, 2020, Plaintiff filed its First Amended Complaint, which in addition\n\nto its original claim under § 905.27 Fla. Stat., (\"Count 11\"), added a claim for Declaratory Relief,\n(\"Count 1\"), that sought an order declaring that the State Attorney and thelC efla\nrelease the Requested Materials. [Def.Ex.A-4].\n5.\n\nOn January 24, 2020, the State Attorney filed an An\n\nAmended Complaint and a Motion to Dismiss Count 11, which\n\n0\n\nclose and\n\nunt I of the First\n\ned Plaintiff that:\n\nDefendant Aronberg and the Office of the State A\nthe Fifteenth Judicial\nCircuit are not in custody or control of the r\nt herein, and therefore\nDefendant Aronberg is not a proper party so\n. In fact, Defendant, Sharon\nR. Bock, as Clerk and Comptroller of Pa\nch ounry, Florida, admits that it\nis the custodian in possession of the (ds\ne\nat are the subject of this action.\n[DelExA-5, p. 12].\n6.\n\nOn June 3, 2020,\n\nClerk's Motions to Dismiss Co\n7.\n\nOn June\n\nMarx held a hearing on the State Attorney's and\ne\n\nef.ExA-6].\nt\n\n0 the Court entered its Order Granting Defendants' Motions to\n\nDismiss Count 11\n\nlainti s First Amended Complaint with Prejudice, leaving only Plaintiff's\n\nCount 1 seek'\n\naratory relief. [Def.Ex.A-7].\n\n+Immediately thereafter, Plaintiff was served with a demand, pursuant to § 57.105\nFla. Stat., to voluntarily dismiss/withdraw the First Amended Complaint and the claims against\nthe State Attorney, along with a Motion for Attorneys' Fees (\"§ 57.105 Demand\"). [Def.Ex.A-8].\n\n2\n\nEFTA02734028\n\n\f", "char_count": 1755}, {"efta_number": "EFTA02734027", "page_number": 2, "text_content": "9.\n\nIn serving his § 57.105 Demand, the State Attorney properly put Plaintiff on notice\n\nthat he would seek sanctions by filing the § 57.105 Motion for Attorneys' Fees if Plaintiff failed\nto dismiss the remainder of the First Amended Complaint within 21 days.\n10.\n\nOn June 23, 2020, Plaintiff's counsel sent a response to the § 57.105 Demand\n\nrefusing to withdraw the remainder of the First Amended Complaint. [Def.ExA-9].\n11.\n\nAfter receiving Plaintiff's response and waiting the requisite \"21 dafifter service\n\nof the motion,\" the State Attorney's § 57.105 Motion for Attorneys' Fees\n\nwith the Court\n\non July 1, 2020, (\"First Motion for Attorneys' Fees\"). [Def.Ex.A-10\n12.\n\nOn August 18, 2020, the State Attorney filed hijS 4 tio\n\n[DelExA-11], which includes an Affidavit made by the\n13.\n\nOn October 21, 2020, Plaintiff fl\n\n8ilikti\n\npursuant to Rule 1.250(b), Fla.R.Civ.P. [Def.\n14.\n\nOn November 9, 2020, th\n\nFees, (\"Amended Motion\"), pursu\nof $19,975.00, plus a multiplie\nI.\n\nf 2.\n\nt\n\nor Summary Judgment,\n\ney. [DelEx.A-12].\nof Dropping the State Attorney,\n\n.\n\nto A\n\nmey filed his Amended Motion for Attorneys'\n\n.105, Fla. Stat., seeking attorneys' fees in the amount\nf.ExA-141.\n\nLEGAL STAND\nAs follow,\n\norida tatutes § 57.105(1) authorizes awards of attorneys' fees as sanctions:\n\nthe court's initiative or motion of any party, the coun shall award a\nattorney's fee, including prejudgment interest, to be paid to the\ng party in equal amounts by the losing party and the losing party's attorney\non y claim or defense at any time during a civil proceeding or action in which\nthe court finds that the losing party or the losing parry's attorney knew or should\nhave known that a claim or defense when initially presented to the court or at any\ntime before trial:\n(a) Was not supported by the material facts necessary to establish the\nclaim or defense; or\n(b) Would not be supported by the application of then-existing law to\nthose material facts.\n\n(1)\nreke\n\n3\n\nEFTA02734029\n\n\f", "char_count": 1976}, {"efta_number": "EFTA02734027", "page_number": 3, "text_content": "\"Section 57.105 does not require a finding of frivolousness to justify sanctions, but only a\nfinding that the claim lacked a basis in fact or law\" and \"does not require a party to show complete\nCounty Conservation Alliance v.\n\nabsence of a justiciable issue of fact or law.\"\n\nCounty, 73 So. 3d 856, 865 (Fla. 1st DCA 2011) (finding that \"Courts are not at liberty to disregard\nthe legislative mandate that courts shall impose sanctions in cases without foundation in material\nfact or law. The word \"shall\" in § 57.105, Fla. Stat., evidences the legislative intt\n\nimpose a\n\nmandatory penalty to discourage baseless claims, by placing a price tag n losing parties who\nengage in these activities. Section 57.105 expressly states courts \"sh\nbringing, or failing to dismiss, baseless claims or defenses.\").\nIn determining an award of sanctions under § 57t\nbased on substantial competent evidence\" and the it . itc\nctt\n\nttoniey's fees for\n\nc)\nt\n\nal court's findings \"must be\n\nust make an inquiry into what the\n\nlosing party knew or should have known due'c ites\np. „ -establishment process, both before and\nafter the suit was filed.\" See Trust Mort\nII.\n\nTHE STATE ATTORNE\nOF THE 21-DAY SAF\nWAS THE AMENDE\n\nLC\n\nerlanti, 193 So. 3d 997 (Fla. 4th DCA 2016).\n\nDED MOTION IS NEITHER IN VIOLATION\nR PROVISION IN FLA. STAT. § 57.105(4), NOR\nON MOOT UPON FILING.\n\n\"Section 57.105(TOn 'da Statutes creates an opportunity to avoid the sanction of\nattorney's fees by\nclaims.\" Day\nportio\n\n'ng safe period for withdrawal or amendment of meritless allegations and\nilynson, 268 So. 3d 762, 769 (Fla. 4th DCA 2019). Specifically, the relevant\n\ntatute states:\nA motion by a party seeking sanctions under this section must be served but may\nnot be filed with or presented to the court unless, within 21 days after service of the\nmotion, the challenged paper, claim, defense, contention, allegation, or denial is not\nwithdrawn or appropriately corrected.\n\nFla. Stat. § 57.105(4). Likewise, \"[t]he primary purpose of the safe h\n... [truncated, 2140 chars — for the full page use /api/corpus/document/EFTA02734027/3 or ?id=EFTA02734027&page=3]", "char_count": 2140}, {"efta_number": "EFTA02734027", "page_number": 4, "text_content": "fees with notice and the opportunity to withdraw or abandon a frivolous claim before sanctions are\nsought.\" MC Liberty Express, Inc. v. All Points Servs., 252 So. 3d 397, 404 (Fla. 3d DCA 2018).\nHere, Plaintiff contends that the State Attorney \"did not serve his Amended Motion at any\ntime before filing it, and thus failed to comply with the 21-day notice provision....\" [See, Plaintiff's\nMemorandum of Law in Response to Amended Motion for Attorneys' Fees, p.6.]. Plaintiff claims\nthat for this reason the Amended Motion should be denied and cites in support, L\nDesign, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013) (holding that \"if a p\n\na subsequent\n\nor amended motion for sanctions under section 57.105 and raises an\n\nat was not raised\n\nin the original motion for section 57.105 sanctions, the sub\n\nt\n\ncomply with the twenty-one-day 'safe harbor' provision\n\n7.105(4).\").\n\nThe instant case is distinguishable from LaS\n\n.itin\n\nKame By\n\non must independently\n\no, because the case was still active\n\nwhen the plaintiff's amended motion for att\n\nPs,\n'\n\ndefendant in compliance with the 21-da\n\nor provision before it was filed with the court,\n\npursuant to § 57.105, the defends\nand withdraw its offending mo\nHere, despite Pla\n\neh\n\nwas filed and was not served on the\n\nto notice and an opportunity to change its position\nre being subject to sanctions.\n\necision to drop the State Attorney as a party, the Florida Rules of\n\nCivil Procedure\n\nhe co\n\ndropped \"in\n\ni ner provided for voluntary dismissal in Rule 1.420(aX1),\" dropping a party\n\ntheref\n\nof Florida are clean Because Rule 1.250 specifies that a party is\n\nales as an adjudication on the merits.\" See, Siboni v. M,\n\n52 So. 3d 779. 781\n\n(Fla. 5th DCA 2010); Rule 1.420(a)(1) Fla. R. Civ. P. Notably, Plaintiff admits that \"the entire\n\nNotably, the court in Lego v. Kame By Design, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013),\ndespite finding that the plaintiff's amended motion for attorneys' fees was improper, the trial court\nwas instructed to rule as\n... [truncated, 2144 chars — for the full page use /api/corpus/document/EFTA02734027/4 or ?id=EFTA02734027&page=4]", "char_count": 2144}, {"efta_number": "EFTA02734027", "page_number": 5, "text_content": "action, which necessarily included Count I [of the First Amended Complaint], was dismissed as to\n[the State Attorney] on October 21, 2020. [See, Plaintiff's Memorandum of Law in Response to\nAmended Motion for Attorneys' Fees, p.7.]. Nonetheless, as a result of dropping the State Attorney\nfrom the case, Plaintiff not only effectively made an admission that its allegations against the State\nAttorney have no basis in fact or law, but also concluded the case as to the State Attorney and\nthereby became the losing party in this action.\nConsequently, unlike the fact scenario and timeline in Lago, .e\nbecr)\nthe instant litigation by dropping the State Attorney from the act' n\n\nconcluded\nthe filing of the\n\nAmended Motion, it was impossible to give Plaintiff an oppoAc ts, '\n\nto\n\nCount 1 of the First Amended Complaint since Plaintiff It\n\ndone so, thus there can be no\n\nviolation of the 21-day safe harbor provision set„S \"Ss,\nhot\nforegoing, the State Attorney's Amended Mot' ilw\nin\n'on\n\nbecause Plaintiff dropped him from th\ne\n\nr\n\npond and withdraw its\n\nStat. § 57.105(4). Based on the\n\nviolate the 21-day safe harbor provision\n\n'or to the filing of the Amended Motion, and\n\ning of the Amended Motion. Accordingly, as further\n\ntherefore Plaintiff was not prejudi\n\nb\n\nset forth below, Plaintiff has e\n\nifseIf to § 57.105 attorneys' fees as sanctions for failing to\n\ndrop the State Attorney\nAddition\nAmended M\nAmen\n\nwithin the 21-day safe harbor period.\nnothing improper about the First Motion for Attorneys' Fees or the\n\nd no argument or authority has been offered by Plaintiff that would make the\nn moot. In fact, amended motions for attorneys' fees are filed consistently as a\n\nmatter of course to include the entirety of fees in a lawsuit. Here, the State Attorney's total legal\nfees were able to be calculated and submitted at the time of filing the Amended Motion.\nFinally, despite Plaintiff's assertion that \"[a] motion for sanctions must be supported by\nthe record evidence at the time it is fi\n... [truncated, 2080 chars — for the full page use /api/corpus/document/EFTA02734027/5 or ?id=EFTA02734027&page=5]", "char_count": 2080}, {"efta_number": "EFTA02734027", "page_number": 6, "text_content": "it fails under the [Sitatute, Plaintiff has failed to provide any supporting authority and there is no\nstatutory requirement or language in § 57.105 that supporting record evidence must exist to\nproperly serve a § 57.105 demand and motion for attorneys' fees. [See, Plaintiff's Memorandum\nof Law in Response to Amended Motion for Attorneys' Fees, p.8.]. \"The central purpose of §\n57.105, Fla. Stat., is, and always has been, to deter meritless filings and thus streamline the\nadministration and procedure of the courts.\"\n\nv. Bailynson, 268 So. 3d 7\n\nDCA 2019). In this vein, a § 57.105 demand and accompanying motion f\nfiled at any time after a lawsuit is initiated, even directly in response\nregardless of whether any record evidence exists in support oft\nA\nConsequently, the foregoing indicates that the Stat\n\n14/ had i\n\nbeing notified why its First Amended C li lain\nsme\nforth at length above, the State A\nfiling it with the Court as Plai\nIII.\n\n1xh\n\n' fees can be\ng of a complaint,\n\n5\ns First Motion for Attorney's\n\nSsri , nctions from Plaintiff for its failure\n\nFees, as served and filed, is sufficient under § 57.10S\nto drop the State Attorney from the instant la\n\no\n\nFla. 4th\n\nn the 21-day safe harbor provision after\n\nno basis in fact or law. Furthermore, as set\n\nno obligation to serve his Amended Motion prior to\n\nready dropped him from the case when it was filed.\n\nTHE COMPETENT UBSTANTIAL EVIDENCE ON THE RECORD SHOWS\nTHAT T\nIS NO ARGUABLE BASIS IN LAW OR FACT FOR THE ISSUES\nRAISED\nPLAINTIFF'S COUNT I, WHICH NOT ONLY LACK A GOOD\nFAIT\nENT FOR THE INTERPRETATION OF EXISTING LAW OR\nEST\nENT OF A NEW LAW WITH A REASONABLE EXPECTATION\n0\nBUT ALSO ARE NEITHER NOVEL OR COMPLEX.\nPlaintiff relies on § 57.105(3Xa), which sets forth a scenario where sanctions are\n\nimproper under the Statute:\n3) Notwithstanding subsections (1) and (2), monetary sanctions may not be\nawarded:\n(a) Under paragraph (Mb) if the court determines that the claim or\ndefense was initially presented to the court as a goo\n... [truncated, 2121 chars — for the full page use /api/corpus/document/EFTA02734027/6 or ?id=EFTA02734027&page=6]", "char_count": 2121}, {"efta_number": "EFTA02734027", "page_number": 7, "text_content": "new law, as it applied to the materialfacts. with a reasonable expectation\nofsuccess.\nNotably, the § 57.105(3Xa) defense only applies to demands made under § 57.105(1Xb).\nAccordingly, Plaintiff's attempt to prevent an award of sanctions here only applies to whether\nPlaintiff or Plaintiff's attorney \"knew or should have known\" that the First Amended Complaint\n\"when initially presented to the court or at any time before trial... (b) would not be\nthe application of then-existing law to those material facts necessary to estab\n\nported by\neir laim.\" §\n\n57.105(1)(b), Fla. Stat.\nO\nRegarding the disclosure of grand jury materials, Florida Stat\nthat there is no arguable basis in law that the State Attorney\n\n5.17(1) makes clear\n\nvide he Requested Materials:\n\nThe notes, records, and transcriptions are confidenda and exempt from the\nprovisions of s. 119.07(1) and s. 24(a), Art.\nthe State Constitution and shall be\nreleased by the clerk only on request by it\njtiy for use by the grand jury or\non order of the court pursuant to s.\nFlorida Statutes § 90517(1). Based onAt\n\ntie\nlea\n\nguage of § 905.17(1), Fla. Stat. there can be\n\nno good faith reasonable expectati\n\ns for the State Attorney to produce and disclose the\n\nRequested Materials as he lac\n\nthe 1 gaI authority to obtain and deliver the Requested Materials\n\ndemanded by Plaintiff in\n\nof the First Amended Complaint\n\nEven if P\ndefense, Plai\nPlainti\n\ntiff is\n\nielded from § 57.105(1Xb) sanctions based on the § 57.105(3)(a)\n\nnonetheless subject to sanctions under § 57.105(I)(a), because Plaintiff or\ns \"knew or should have known\" that Count I \"when initially presented to the\n\ncourt or at any time before trial ... (a) was not supported by the materialfacts necessary to establish\nthe claim.\" Fla. Stat. § 57.105(1)(a). Specifically, based on Plaintiff's own research, statutory\nconstructive notice, the State Attorney's affidavit, all of the pleadings and correspondence in this\nmatter as well as through the State Attorney's office press relea\n... [truncated, 2053 chars — for the full page use /api/corpus/document/EFTA02734027/7 or ?id=EFTA02734027&page=7]", "char_count": 2053}, {"efta_number": "EFTA02734027", "page_number": 8, "text_content": "Chief Judge Marx's statements during the June 3, 2020 hearing, Plaintiff and Plaintiff's attorneys\nknew or should have known that Count 1 of the Amended Complaint was not supported by the\nmaterialjams necessary to establish the claim.\" See. Fla. Stat. § 57.10.5(1)(a).\nThe material facts showing that Plaintiff has no reasonable expectation of success and is\nunable to establish its claim for declaratory relief have been open, obvious, and apparent to\neveryone involved in this matter from the start. The State Attorney's position has\nneither he nor his office has possession, custody, or control of the R\ntherefore the declaratory relief sought by Plaintiff seeks materials th\nhis office to produce and he is not a proper party to this action.\nc\nthese material facts negating Plaintiff's declaratory relieit\nnot only set forth in the June 8, 2020, § 57.105 D\n\n'St\nn\n\nState Attorney's defense in every pleading, fil' 8,\n\n.,\n\nAccordingly, Plaintiff knew ors\n\nha\n\nit\ns\n\n)\n\n'm\n\nonsistent:\naterials and\nBible for him or\n\nx.A-12 1r] 3-4]. Again,\ninst the State Attorney were\n\nr, but have been the basis for the\n\ncorrespondence in this matter.\n\nknown that the First Amended Complaint was\n\nnot supported by the material f\n\nto establish the claim for declaratory relief. At the\n\nvery least, Plaintiff should ha\n\nthat its First Amended Complaint was not supported by\n\nthe material facts after Ju\n\nrx's statements during the June 3, 2020 hearing on Defendant's\n\nMotion to Dismis\n\nsinti s Count 11. During that hearing, Chief Judge Marx drew a bright line\n\nas to when P\n\nknew or should have known that Count 1 of the Amended Complaint had no\n\nbasis\n\naw since the relief sought thereby is impossible for the State Attorney to perform.\n\nSpecifically, Chiefludge Marx made several unequivocal statements on the record putting Plaintiff\non notice, if they weren't already, that the State Attorney does not have and cannot produce the\nRequested Materials. [Def.Ex.A-6, pgs. 3:18 - 4:1; 5:17-19; 8:4-22; 10:21 - 11:1\n... [truncated, 2068 chars — for the full page use /api/corpus/document/EFTA02734027/8 or ?id=EFTA02734027&page=8]", "char_count": 2068}, {"efta_number": "EFTA02734027", "page_number": 9, "text_content": "Additionally, Plaintiff's argument for novelty and complexity fails as to Count I, regardless\nof Plaintiff's reliance on \"Constitutional provisions and interpretive case law, along with Fla. Stat.\n§ 905.27\" ... \"to propose a good faith interpretation of existing law in support of its declaratory\nrelief claim in Count I.\" [See, Plaintiff's Memorandum of Law in Response to Amended Motion\nfor Attorneys' Fees, p.10.]. The simple fact of the matter is that Count I is neither novel or complex\nbecause Count I merely seeks declaratory relief and the State Attorney's lat\ncustody, or control in conjunction with § 905.17(1) creates an impossibilit\nCount I. Here, § 905.17(1) is abundantly clear that only the Clerk ca\n\nsession,\nnuance as to\nnd jury materials\n\npursuant to a court order. The record is likewise clear that not\n\nha\n\nState Attorney never\n\nhad possession, custody, or control of the Requested Mate\n\nalso lacks any legal authority\n\nto obtain and deliver the Requested Materials.\nThus, there is no arguable \"good fait\n\n• i 7aww' and/or fact as to Plaintiff's Count I.\n\nLikewise, under no set of facts does Plai • ha\nState Attorney in obtaining the R\nor control over them.\nimpossibility of the State\nthe action. Consegitly,\n\nIn\n\nreasonable expectation of success against the\n\nrials because he does not have possession, custody,\n, P\n\nmiff acknowledged, admitted, and acquiesced to the\n\ny providing the Requested Materials when he was dropped from\nactions against Plaintiff are appropriate under § 57.105, Fla. Stat.\nCONCLUSION\n\nn the foregoing, Defendant, Dave Aronberg, as State Attorney of Palm Beach\nCounty, Florida, respectfully requests the Court enter an order granting his Amended Motion for\nAttorneys' Fees as well as such other and further relief as the Court deems just or proper.\nSCHOLZ & WYLER, LLC\nIs/ Douglas A. Wyler\n\n10\n\nEFTA02734036\n\n\f", "char_count": 1857}, {"efta_number": "EFTA02734027", "page_number": 10, "text_content": "Arthur I. =,\nEsq.\nFla. Bar No.: 10249\nRichard J. Scholz, Esq.\nFla. Bar No.: 0021261\nDouglas A. Wyler, Esq.\nFla. Bar No.: 119979\n961687 Gateway Blvd., Suite 201-I\nFernandina Beach, Florida 32034\n(904) 261-3693\n(904) 261-7879 Fax\nPrimary: jacobsscholzJaw4,\nt.net\nAttorneysforDefendaj\n\nYtJronberg\n\nCERTIFICATE OF SERVICE\nI HEREBY CERTIFY that on this 12th day of August,\nbeen electronically filed with the Florida E-File Portal for\n\ny of the foregoing has\nn all parties of record herein.\nA. Wyler\n\n11\n\nEFTA02734037\n\n\f", "char_count": 514}, {"efta_number": "EFTA02734027", "page_number": 11, "text_content": "Def.Ex.A-1\n\nEFTA02734038\n\n\f", "char_count": 27}, {"efta_number": "EFTA02734027", "page_number": 12, "text_content": "\"\" CASE NUMBER: 502019CA0146890=MB Div: AG'\"\"\nFiling # 98869063 E-Filed 11/14/2019 11:06:37 AM\n\nIN THE CIRCUIT COURT, 15th\nJUDICIAL CIRCUIT, IN AND FOR\nPALM BEACH COUNTY, FLORIDA\n\nCASE NO.:\nCA FLORIDA HOLDINGS, LLC,\nPublisher of THE PALM BEACH POST\nPlaintiff,\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida, SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida,\n\nC\n\nDefendants.\nSUMMONS\nDEFENDANT:\n\nDave Aronberg, as State Attorney of\nPalm Beach County, Florida\n401 N. Dixie Highway\nWest Palm Beach, Florida 33401\n\nA lawsuit has been filed against you. You have 20 calendar days after this summons is\nserved on you to file a written response to the attached Complaint with the Clerk of this\nCourt. A phone call will not protect you. Your written response, including the case\nnumber given above and the names of the parties, must be filed if you want the Court to\nhear your side of the case. If you do not file your response on time, you may lose the\ncase, and your wages, money, and property may thereafter be taken without further\nwarning from the Court. There are other legal requirements. You may want to call an\nattorney right away. If you do not know an attorney, you may call an attorney referral\nservice or a legal aid office (listed in the phone book). If you choose to file a written\nresponse yourself, at the same lime you file your written response to the Court you must\nalso mail or take a copy of your written response to the: Stephen A. Mendelsohn,\nEsquire, Greenberg Traurig, P.A., 5100 Town Center Circle, Suite 400, Boca Raton,\nFlorida 33486, Telephone: (561) 955-7600.\n\nFILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11:06:37 AM\n\nEFTA02734039\n\n\f", "char_count": 1716}, {"efta_number": "EFTA02734027", "page_number": 13, "text_content": "THE STATE OF FLORIDA\nTO EACH SHERIFF OF THE. STATE: You are commanded to serve this Summons and\na copy of the Complaint in this lawsuit on the above named Defendant.\nDATED on November , 2019\n\nNOV15 2110\n\nSharon R. Bock\nAs Clerk & Comptroller of the Court\nBy:\n\nIMPORTANTE\n\niiitiy\nmouy\n\nC\n\nUsted ha sido demandado legalmente. liane 20 Dias, contados a partir del recibo de esta\nnotification, para contester la demanda adjunta, por escrito, y presentada ante este tribunal. Una Hamada\ntelefonica no la protegera Si usted desca que el tribunal considere su defense, debe presentar su respuesta\npor escrito, incluyendo el numero del casa y los nombres de las partes interesadas. Si usted no contesta la\ndemanda a tiempo, pudiese panier cl caso y podria sen despojado de sus ingresos y propiedades, o mincie\nde sus derechos, sin prcvio aviso del tribunal. Existen otros requisitos legates. Si lo data, puede usted\nconsultas a un abogado inmediatamente. Si no conoce a un abogado, puede (lamas a une de las oscines de\nasistencia legal que aparecen en le guis telefonica.\nSi desea responder a la demanda por su cucnta. al...mibo ticmpo en que presents su respuesta ante\nel tribunal, debera usted envier por CARCO o entregar unis Copia de su respuesta a la persona denominada\nabajo come \"PlaintifnPlaintiffs Attorney\" (Demandante o Abogado del Demandante).\nIMPORTANT\nDes poursuites judiciares ont etc entreprises contre vous. Vous avez 20 jours consecutifs a partir\nde la date de rassignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de cc\ntribunal. Un simple coup de telephone est Suffisant pour vous proteger. Vous etcs oblige de deposer\nvotre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nominees ici, si\nvous souhaitez que le tribunal entende voue cause. Si vous ne deposez pas votre repense ecrite dans le\nsciai requis, vous risquez de peste la cause ainsi que votre salaire, votre argent, et vos biens peuvent erre\nsaisis par l\n... [truncated, 2605 chars — for the full page use /api/corpus/document/EFTA02734027/13 or ?id=EFTA02734027&page=13]", "char_count": 2605}, {"efta_number": "EFTA02734027", "page_number": 14, "text_content": "Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM\n\nIN THE CIRCUIT COURT OF THE\nFIFTEENTH JUDICIAL CIRCUIT IN AND\nFOR PALM BEACH COUNTY, FLORIDA\n\nCA FLORIDA HOLDINGS, LLC,\nPublisher of THE PALM BEACH POST,\n\nCASE NO.:\n\nPlaintiff\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SI-IARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida,\nDefendants.\n\nCOMPLAIN\n\n7'\n\nCA Florida Holdings, LLC, publisher of The PS Beach Post, for its Complaint against\nDave Arenberg, the State Attorney for Palm Beach County, Florida, in his official capacity (\"State\nAttorney\"), and Sharon R. Bock, the Clerk of the Court for Palm Beach County, Florida, in her\nofficial capacity (\"Court Clerk\"), alleges as follows:\nJURISDICTION\nI.\nFla. Stat. Sec\n\nThi\n\nan action within the exclusive jurisdiction of the Circuit Court pursuant to\nI 1 (2)(a).\nPARTIES\n\n2.\n\nThe Palm Beach Post is a daily community newspaper published by Plaintiff CA\n\nFlorida Holdings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.\n3.\n\nDefendant Dave Aronberg is the duly elected State Attorney for the Fifteenth\n\nJudicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and\n\nEFTA02734041\n\n\f", "char_count": 1234}, {"efta_number": "EFTA02734027", "page_number": 15, "text_content": "has authority in grand jury proceedings pursuant to Fla. Stat. section 27.03. He is sued herein in\nhis official capacity as his office is in possession of documents that are the subject of this action.\n4.\n\nDefendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach\n\nCounty, Florida. She is sued herein in her official capacity as her office is in possession of\ndocuments that are the subject of this action.\nINTRODUCTION\n5.\n\nIn what is now widely if belatedly recognized as a colossal miscarriage of justice —\n\nwhich led to the further needless victimization of countless young girls and women — a wealthy,\npolitically connected, and powerful financier was not held accountable for, nor even forced to\nI4ki'si\nconfront, allegations of serious sex trafficking crimes.8i\"Whi\\ elt\n\nthat Jeffrey Epstein's 2008\n\ndeal with the State of Florida was not consistent w\n, Icire\n\"S kc, ence gathered against him, what\nremains shrouded in mystery is how that evides\npresented - to the grand jury that returned\n\ntin\nli; „\n\nindi\n\nse nted — and the extent to which it was\n\nent far more limited in scope than expected\n\nand deserved.\n6.\n\nThrough this acfi\n\nPalm Beach Post seeks public access to the testimony,\n\nminutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled\nduring the first Epstein sex abuse investigation. Typically, access to such materials is limited, for\nexample, in order to prevent the flight of those whose indictment may be contemplated and their\nability to conceal or destroy evidence; to ensure jurors' candor in deliberations: and to protect an\naccused who is later exonerated. However, these factors are inapplicable here. Also, Florida law\nexpressly authorizes the disclosure of grand jury proceedings under certain circumstances,\nincluding, as here, in the furtherance of justice. Fla. Stat. § 905.27(1 )(c).\n7.\n\nIt can no longer credibly be maintained that continued blanket secrecy over the\n\nproceedings that led to the egregiously \n... [truncated, 2077 chars — for the full page use /api/corpus/document/EFTA02734027/15 or ?id=EFTA02734027&page=15]", "char_count": 2077}, {"efta_number": "EFTA02734027", "page_number": 16, "text_content": "To the contrary, transparency is required to promote public understanding of the criminal justice\nsystem and public confidence in the fair administration of justice. As detailed below, Epstein was\naccused of sexually abusing and trafficking dozens of women and girls in south Florida (among\nother locations) over a period of several years while exploiting his wealth and political connections\nto obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury\nproceedings will shed light on the extent to which those in our government entrusted with the\nsolemn responsibility of enforcing our criminal laws equally as to all citizens fidfilled their duties\nin this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated\nlike others accused of similar heinous crimes, or (2) as appears more likely to be the case, those\nwho chose to give Epstein favorable — \"unusual,\" in the words of the Town of Palm Beach Police\nChief — treatment, are exposed and held accountable. From what limited information is now in the\npublic domain, the State Attorney's referral to the grand jury — which would be out of the ordinary\nfor this type of case — gives rise to a strong inference of favoritism and corresponding disregard\nfor the rights of the minor victims of Epstein's sex trafficking. Access to the grand jury materials\nwill allow the public to determine whether the grand jury process. and the secrecy that comes with\nit, was used to further justice or, instead, operated to shield Epstein and his co-conspirators from\nthe consequences of their criminal activities. Accordingly, F]a. Stat. Section 905.27 authorizes the\ndisclosure of Epstein's 2006 grand jury proceedings.\n8. -\n\nEven in the absence of such a statutory basis, this Court is empowered to order\n\npublic disclosure pursuant to its inherent authority and supervisory powers over the grand jury.\nIndeed, courts throughout the country in the past several decades have orde\n... [truncated, 2239 chars — for the full page use /api/corpus/document/EFTA02734027/16 or ?id=EFTA02734027&page=16]", "char_count": 2239}, {"efta_number": "EFTA02734027", "page_number": 17, "text_content": "as here, many of the details of Epstein's criminal misdeeds have already been made available in\nthe public domain through extensive news reporting by, among others, The Palm Beach Post; by\nthe many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.\n9.\n\nIn recognition of the sensitivity of the materials being sought, and in the interest of\n\nprotecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to\ncopies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County\ngrand jury first being submitted to this Court for in camera review, where they may be redacted,\nas appropriate, to protect those who deserve such protection.\nFACTUAL BACKGROUND\n10.\n\nThe following facts were gathered, in lar\n\nThe Palm Beach Post through various Florida Public ReS:Als\ng\n\n, from documents obtained by\nw requests, documents unsealed\n\nor publicly available in other related judicial proceedings, and information and documents in the\npublic record.\nA.\n\nFirst Epstein Sex Crimes Investigation, Indictment, and Plea Agreement:\n2005- 2008.\n11.\n\nThe investigation into Epstein's sex crimes began more than fourteen years ago,\n\nwhen a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that\nEpstein and othensvi\\worked for him arranged for her to give Epstein a \"massage.\" Epstein\nrequired the girl to strip, exposed himself and masturbated while touching her. The girl was paid\n$300. Epstein was 52 years old at the time.\n12.\n\nFollowing this initial report in 2005, the Town of Palm Beach Police, and later. in\n\n2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and\nseventeen witnesses revealed that the events described by the l4-year-old girl occurred, with\ndisturbingly similar details, with each of the other victims.\n\n4\n\nEFTA02734044\n\n\f", "char_count": 1902}, {"efta_number": "EFTA02734027", "page_number": 18, "text_content": "13.\n\nBoth the victim/witness interviews, as well as evidence retrieved following a search\n\nof Epstein's home, showed that some of the girls involved were under the age of 18. The police\nsearch of Epstein's residence also found two hidden cameras and, throughout the house, large\nnumbers of nude photos of girls, including victims whom the police had not interviewed in the\ncourse of their investigation.\n14.\n\nIn March 2006, a State grand jury was scheduled at which all of the victims were\n\nexpected to testify. The proceeding was postponed, however, due to meetings between the State\nAttorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan\nDershowitz.\n15.\n\nAnother grand jury was convened in April 2.le,butFanceled the day before it was\n\nto begin receiving evidence.\n(I)\n16.\n\nPolice Chief ReiterAtitt\n\nto the State Aftorney.\n\nOn May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a\n\n\"personal and confidential\" letter to then Palm Beach County State Attorney, Barry Krischer,\nstating:\n1 must renew my prior observation to you that I continue to find your office's\ntreatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to\ncommunicate in this manner, but my most recent telephone calls to you and those\nof the lead detective to your assigned attorneys have been unanswered and\nmessages remain =returned. After giving this much thought and consideration.\nI must urge you to examine the unusual count that your office's handling ofthis\nmatter has taken and consider if goodandsufficient reason exists to require your\ndisqualificationfrom the prosecution of these cases. (Emphasis supplied)\n17.\n\nChief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach\n\nPolice Department's probable cause affidavits charging Epstein and two of his assistants with\nmultiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested\n\n5\n\nEFTA02734045\n\n\f", "char_count": 1963}, {"efta_number": "EFTA02734027", "page_number": 19, "text_content": "that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges\nagainst him, which would be public.\n(2)\n18.\n\nThe Jul' 2006 State Grand Jury Presentation.\n\nInstead, State Attorney Krischer elected to refer the case to a grand jury, which is\n\nmandatory for capital cases but rarely used for all other crimes. According to an official\nspokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm\nReach County.\n19.\n\nIn July 2006, after State Attorney Krischer presented testimony and evidence from\n\none victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.\nThere is no mention in the indictment of the victim being a minor.\n20.\n\nOn information and belief, a second\n\nbefore the grand jury, but was unable to attend\n21.\n\nAStse\n\n'n's victims was supposed to testify,\na school exam.\n\nNo reasonable explanation has been provided as to why the numerous other known\n\nvictims were not presented as witnesses and crime victims to the grand jury convened in July 2006.\nNor has any reasonable explanation been provided as to why State Attorney Krischer, who was\ninitially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do\nso.\n\n22.\nwho testiliEd.\n\nn «formation and belief, during the grand jury appearance of the single victim\ne State Attorney presented evidence that vilified the victim and attacked her\n\ncredibility, including soliciting testimony regarding underage drinking and questionable personal\nbehavior that was unrelated to the charges against Epstein. Further upon information and belief,\nthis information was initially brought to the attention of the State Attorney's office by Epstein's\ndefense counsel.\n\n6\n\nEFTA02734046\n\n\f", "char_count": 1781}, {"efta_number": "EFTA02734027", "page_number": 20, "text_content": "(3)\n23.\n\nThe FBI's Investiaation and Enstcin's Non-Prosecution\nAgreement With Federal Authorities.\n\nOn information and belief, following the deficient July 2006 indictment, and with\n\nChief Reiter's encouragement, the FBI began its own investigation of Epstein.\n24.\n\nRecords unsealed in 2015 revealed that the FBI compiled reports on \"34 confirmed\n\nminors\" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI,\na 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. However, at the\nrequest of Epstein's lawyers, the indictment was never presented to a federal grand jury.\n25.\n\nInstead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,\n\nnegotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with\nfour named co-conspirators and any unnamed potential co-conspirators) from all federal criminal\ncharges.\n26.\n\nThroughout the remainder of 2007 and through the first half of 2008, Epstein's\n\nlawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and\nbelief, Epstein's lawyers insisted that (I) the victims not be notified, (2) the deal be kept\nconfidential and under seal, and (3) all grand jury subpoenas (including one that had already been\nissued for Epstein's computers) be withdrawn.\n27.\n\nOn June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of\n\nprostitution and one count of solicitation of prostitution with a minor under the age of 18. He was\nsentenced to 18 months in jail, followed by a year of community control or house arrest, and was\nadjudicated as a convicted sex offender required to register twice a year in Florida.\n28.\n\nThe plea deal, called a non-prosecution agreement (\"NPA\"), allowed Epstein to\n\nreceive immunity from federal sex-trafficking charges that could have sent him to prison for life.\n\n7\n\nEFTA02734047\n\n\f", "char_count": 1914}, {"efta_number": "EFTA02734027", "page_number": 21, "text_content": "On information and belief based on public records, former State Attorney Krischer communicated\nwith then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers.\n29.\n\nIndeed, Epstein was not incarcerated in a Florida prison for the State crimes for\n\nwhich he was convicted. Instead, he was placed in a private wing of the Palm Beach County\nStockade, where, after 3 1/2 months, he was allowed to leave the jail on \"work release\" for up to\n12 hours a day, 6 days a week. His private driver provided his transportation to and from \"work.\"\n30.\n\nEpstein was released five months early.\n\n31.\n\nUpon information and belief, Epstein violated the terms of his probation, but was\n\nnot prosecuted.\n(4)\n32.\n\nThe Crime Victims' Rights Act Litigation.\n\nEpstein's victims only learned after the actsbout his plea in State court and filed\n\nan emergency petition to force federal prosecu\n\nit\n\nply with the Crime Victims' Rights Act\n\n(18 U.S.C. § 3771, \"CVRA\"), which mandates certain rights for crime victims, including the right\nto be informed about plea agreements and the right to appear at sentencing. U.S. District Judge\nKenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify\nEpstein's victims before allowing him to plead guilty to only the two State offenses.\n33.\n\nThe prosecution's failure to keep the victims apprised, among other things, also\n\ncontravenes thCriiida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001.\nflowing publicity exposing the extraordinary leniency of the plea deal, dozens of\ncivil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court.\n35.\n\nIn 2010, Epstein was registered as a \"level three\" (i.e., high risk of repeat offense)\n\nsex offender in New York, a lifelong designation. In 2011, the New York County District\nAttorney's office unsuccessfully sought to lower his registration to low-risk \"level one.\"\n\n8\n\nEFTA02734048\n\n\f", "char_count": 1948}, {"efta_number": "EFTA02734027", "page_number": 22, "text_content": "36.\n\nUpon information and belief, during the course of the Town of Palm Beach and FBI\n\ninvestigations, Epstein retained private investigators to follow, harass, and photograph his victims\nand their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated\nthe case against Epstein.\n37.\n\nUpon information and belief, Epstein's victims were threatened against cooperating\n\nwith law enforcement and told that they would be compensated only if they did not cooperate with\nlaw enforcement.\nB.\n\nSecond Epstein Sex Crimes Investization, Indictment, Suicide: 2019.\n38.\n\nOn July 6, 2019, Epstein was arrested on federal sex trafficking charges.\n\n39.\n\nUpon information and belief, the United States government's investigation of new\n\nallegations and charges stemmed, in part, from continued press investigations into and reporting\non the mishandling of the 2006 charges and the civil suits that followed.\n40.\n\nIn a July 8, 2019, letter to the federal district court by the U.S. Attorney for the\n\nSouthern District of New York, Epstein was described as \"a serial sexual predator who preyed on\ndozens of minor girls over a period of years.\" The letter emphasized that \"the Government has real\nconcerns — grounded in past experience with this defendant — that if allowed to remain out on bail,\nthe defendant could attempt to pressure and intimidate witnesses and potential witnesses in this\ncase, including victims and their families, and otherwise attempt to obstruct justice.\" It also\ndescribed the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex\ntrafficking in the form of \"hundreds — and perhaps thousands — of sexually suggestive photographs\nof fully- or partially-nude females,\" including underage females. In a locked safe, compact discs\nwere found with handwritten labels including the descriptions: \"Young [Name) + [Name],\" \"Mist\nnudes 1,\" and \"Girl pics nude.\"\n\n9\n\nEFTA02734049\n\n\f", "char_count": 1937}, {"efta_number": "EFTA02734027", "page_number": 23, "text_content": "41.\n\nOn July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's\n\noffice for the Southern District of New York charged Epstein with sex trafficking and conspiracy\nto traffic minors for sex. The grand jury indictment alleges that \"dozens\" of underage girls were\nbrought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry\nover the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,\nAlexander Acosta, who by then was serving as U.S. Secretary of labor in the Trump\nadministration, resigned from office.\n42.\n\nEpstein was denied bail and was placed into pretrial detention at the federal\n\nMetropolitan Correction Center in lower Manhattan.\n43.\n\nOn August 10, 2019. Epstein was found dead in his cell at the Metropolitan\n\nCorrectional Center. His cause of death was determined to be suicide.\nC.\n\nThe August 27, 2019, SDNY Hearing; Epstein's Victims Speak\n44.\n\nOn account of his death, prosecutors sought to dismiss the indictment against\n\nEpstein, while maintaining that they would continue to investigate his co-conspirators.\n45.\n\nUnited States Senior District Judge Richard M. Berman ordered a hearing on\n\nAugust 27. 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to\nspeak at the hearing.\n46.\n\nIn the course of the hearing, more than two dozen victims delivered their personal\n\nstories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of\nviolent rape by Epstein. Many more victims were present in the courtroom but did not testify.\n47.\n\nWhile some questioned the reasoning behind the court's decision to give the victims\n\nvoice after Epstein's death, District Judge Bennan noted that \"a public hearing is [the] preferred\nvehicle of resolution,\" emphasizing that \"public hearings are exactly what judges do. Hearings\npromote transparency and they provide the court with insights and information which the court\n10\n\nEFTA02734050\n\n\f", "char_count": 1995}, {"efta_number": "EFTA02734027", "page_number": 24, "text_content": "may not otherwise be aware of\" Indeed, even Epstein's defense lawyer noted at the hearing that\nthe court \"is the institution that most people have confidence in, in these very troubled times.\"\n48.\n\nAt the August 27th hearing. the girls, now women, spoke about their \"exploitation\n\nand coercion,\" and to the fact that many of them \"were in very vulnerable situations and in extreme\npoverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their]\nbehalf....\" One victim lamented that \"as a victim, [she] never got to see what the agreement was\nor why the special treatment got approved\" in the Florida case years earlier. Another noted how\n\"completely different\" the investigators leading to the 2019 federal indictment were from the\nprosecutors in the Florida case, both in their treatment of her and their investigation of her\nvictimization by Epstein.\n49.\n\nA former federal judge in attendancek ethnin ugust 27th hearing emphasized that\n\n)11‘9\n\nSic • inal justice system.\"\n\n\"transparency is one of the overriding objectiv\n50.\n\nNearly all of the victims\n\nS\n\nt)the conviction that the secrecy that shielded\n\nEpstein has caused them \"irreparable harm\" and that an opportunity to address his criminal\nwrongdoings. and those of the individuals who enabled his sexual racketeering, would allow for\nat least some measure of justice to be served after his death. Indeed, one victim stated: \"Any efforts\nmade to protect Epstein's name and legacy send a message to the victims that he wins and that he\nis untouchab\npower, a\n\nther victim expressed fear that this is a world \"where there are predators in\nwhere people can avoid justice if their pockets run deep enough.\" In short, the\n\n\"unusual\" treatment Epstein received in Florida in 2006 based on his wealth, social status, and\nconnections severely eroded the public's faith in the integrity and impartiality of the criminal\njustice system.\n\n11\n\nEFTA02734051\n\n\f", "char_count": 1932}, {"efta_number": "EFTA02734027", "page_number": 25, "text_content": "D.\n\nThe Palm Beach Post's Standing and the Public Interest.\n51.\n\nPlaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm\n\nBeach County and the Treasure Coast vicinity.\n52.\n\nThe Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist\n\nthree other times.\n53.\n\nBeginning in 2004, The Palm Beach Post has extensively investigated and reported\n\non the allegations against, the law enforcement investigation of, and the crimes committed by,\nEpstein and his co-conspirators. The Newspaper's reportage has included publication of the\nfollowing articles:\n•\n\n\"The Man Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends\nv s ' tors Say, Underage Girls.,\" published on August 14, 2006, reporting that:\n, a local community college student, admitted in a sworn statement to\npolice that \"she had taken at least six girls to visit Epstein, all between the ages of 14\nand 16;\" Palm Beach Police \"interviewed five alleged victims and 17 witnesses;\"\n\"Dershowitz, the Harvard law professor, traveled to West Palm Beach with information\nabout the girls,\" including social media discussions about \"their use of alcohol and\nmarijuana;\" after meeting with Epstein's legal team, \"prosecutors postponed their\ndecision to take the case to a grand jury;\" Palm Beach Police subsequently \"received\ncomplaints that two of the victims or their families had been harassed or threatened;\"\n\"relations between police and prosecutors were fraying\" as the investigation continued;\nand \"one girl who was subpoenaed —the one who said she had sexual intercourse with\nEpstein — never showed up\" to testify before the grand jury.\n\n•\n\n\"Trump Snags Gosman Estate for S41 Million\" published on November 16, 2004,\nreporting on the bidding war between Donald Trump and Jeffrey Epstein for the\npurchase of a \"43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along\nthe storied 'Raider's Row' \" in Palm Beach.\n\n•\n\n\"Indictment: Billionaire Solicited 3 Times\" published on July\n... [truncated, 2593 chars — for the full page use /api/corpus/document/EFTA02734027/25 or ?id=EFTA02734027&page=25]", "char_count": 2593}, {"efta_number": "EFTA02734027", "page_number": 26, "text_content": "• \"After Long Probe, Billionaire Faces Solicitation Charge\" published on July 26, 2006,\nreporting that \"Palm Beach police thought there was probable cause to charge Epstein\nwith unlawful sex acts with a minor and lewd and lascivious molestation.\" The article\nfurther reported that \"Police Chief Michael Reiter was so angry with State Attorney\nBarry Krischer's handling of the case that he wrote a memo suggesting the county's\ntop prosecutor disqualify himself,\" and identified a 20-year-old on-the-record female\nsource who said \"she gave Epstein a massage in the nude, then brought him six girls,\nages 14 to 16, for massage and sex-tinged sessions at his home.\"\n•\n\n\"Police Say Lawyer Tried to Discredit Teenage Girls\" published on July 29, 2006,\nreporting that \"[gamed Harvard law professor Alan Dershowitz met with the Palm\nBeach County State Attorney's Office and provided damaging information about\nteenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein,\nsexually charged massages\" and that \"[t]he state attorney's office said it presented the\nEpstein case to a county grand jury this month rather than directly charging Epstein\nbecause of concerns about the girls' credibility.\"\n\n•\n\n\"Expert: Ignorance of Age Isn't Defense In Sex Cases\" published on August 5, 2006,\nreporting that \"[r]ather than file charges, the state attorney's office presented the case\nto a county grand jury\" which \"indicted Epstein last week on a single, less serious\ncharge of felony solicitation of prostitution,\" and that \"[t]he case raised eyebrows\nbecause the state attorney's office rarely, if ever, kicks such charges to a grand jury.\"\n\n•\n\n\"Epstein Camp Calls Female Accusers Liars\" published on August 8, 2006, reporting\nthat \"[a] state attorney's spokesman would say only that the office refers cases to the\ngrand jury when there are issues with the viability of the evidence or witnesses'\ncredibility.\"\n\n•\n\n\"Palm Beach Chief Focus of Fire In Epstein Case\" published on August 14, 2006,\n... [truncated, 3153 chars — for the full page use /api/corpus/document/EFTA02734027/26 or ?id=EFTA02734027&page=26]", "char_count": 3153}, {"efta_number": "EFTA02734027", "page_number": 27, "text_content": "offender,\" and that \"[a's part of the plea deal, federal investigators agreed to drop their\ninvestigation of Epstein, which they had taken to a grand jury.\"\n• \"Jeffrey Epstein: Scientist, Stuntman, `Sex Slave' Visit Jailed Tycoon\" published on\nAugust 13 2008 reporting that \"[d]uring his first month of confinement\" Epstein was\n, who allegedly escorted victims \"upon their arrival at his Palm\nvisited by\nBeach waterfront home to an upstairs room, where she prepared\nand\nprovided the oils for their encounters\" with Epstein, and by\nyoung woman whom Epstein purportedly described as his Yugoslavian sex slave.\"\n• \"Billionaire Sex Offender Leaves Jail Six Days a Week For Work\" published on July\n1, 2008, reporting that Epstein \"is allowed to leave the Palm Beach County Stockade\nsix days a week on a work-release program.\"\n•\n\n\"Women Want Epstein Sex Plea Deal Unsealed\" published on June 10, 2009, reporting\nthat attorneys for women suing Epstein in various courts \"want his [non-prosecution]\nagreement [NPA] with federal prosecutors unsealed\" and were moving to unseal the\nagreement in Circuit Court of the Fifteenth Judicial Circuit, and that \"Epstein now faces\nat least a dozen civil lawsuits in federal and state courts filed by young women who\nsaid they had sex with him and now\nseeking damages.\" On that date, The Palm\nReach Post moved to intervene in thelOtter for the purpose of obtaining public access\nto the NPA, which was ordered disclosed by this Court on June 25, 2009.\n\n• \"Epstein's Secret Pact With Feds Reveals `Highly Unusual' Terms\" published on\nSeptember 19, 2009, reporting that, owing to Epstein's non-prosecution agreement,\n\"federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein\npleaded guilty to prostitution-related felonies in tate c\n\"\n\"\nd not to\ncharge any of E stei s\n.ble co-conspirators:\n, Lesley\nGroff and\n.\" The article further reported that, according to an\nattorney representing three of Epstein's victims, \"none of the 30 to 40 wom[e]n\ni\n... [truncated, 3024 chars — for the full page use /api/corpus/document/EFTA02734027/27 or ?id=EFTA02734027&page=27]", "char_count": 3024}, {"efta_number": "EFTA02734027", "page_number": 28, "text_content": "•\n\n\"Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims'\nRights\" published on February 22, 2019, reporting on a ruling by U.S. District Judge\nKenneth Marra that \"Federal prosecutors violated the rights of Jeffrey Epstein's\nteenage victims [under the Crime Victims' Rights Act] by failing to reveal they had\ndropped plans to prosecute the billionaire on dozens of federal charges in connection\nwith the girls' claims that he paid them for sex at his Palm Beach mansion.\"\n\n• \"Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex\nTrafficking, Conspiracy Charges In Federal Court In Manhattan\" published on July 9,\n2019, reporting on Epstein's appearance in U.S. District Court for the Southern District\nof New York in which he \"pleaded not guilty to charges accusing him of creating a vast\nnetwork of girls as young as 14 that he exploited for his sexual pleasure at his homes\nin Palm Beach and Manhattan.\"\nA true and correct copy of the above news articles, in either the computerized format in which they\nare maintained in The Palm Beach Post's electronic archives or the news print edition in which\noriginally published, is annexed hereto as Exhibit 1.\n54.\n\nThe press has a constitutional right of access to criminal proceedings, see, e.g.,\n\nRichmond Newspapers Inc. v. Virginia, 448 U.S. 555, 573 (1980). including pre-trial criminal\nproceedings. M.\n\nv. Graddick, 6% F.2d 796 (11th Cir. 1983). Indeed, \"the integrity of the\n\njudicial process, which public scrutiny is supposed to safeguard, is just as much at issue in\nproceedings of this kind [pre- and post-trial] as at trial.\" Id. at 801; see also Miami Herald Publ.\nCo.\n\n426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a \"public surrogate\" in\n\nmatters concerning the closure of judicial proceedings). The press also has a First Amendment\ninterest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer\nCouncil, 425 U.S. 748, 756-57 (1976) (\"Where a sp\n... [truncated, 2456 chars — for the full page use /api/corpus/document/EFTA02734027/28 or ?id=EFTA02734027&page=28]", "char_count": 2456}, {"efta_number": "EFTA02734027", "page_number": 29, "text_content": "has \"standing to assert a right to receive speech\" by \"show[ing] that there exists a speaker willing\nto convey the information to her\").\n55.\n\nBecause of the unique role performed by the press as a \"public surrogate\" a-,\n\n426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about\ncriminal proceedings, news organizations \"presumptively have a right to access judicial records,\"\nComm 'r, Ala. Dep't of Corr. v. Advance Local Media, LLC. 918 F.3d 1161, 1166 (11th Cir. 2019),\nand \"standing to question the validity of an order restricting publicity because its ability to gather\nnews is directly impaired or curtailed.- M,\n\n426 So. 2d at 4; see also Carlson'v. United States,\n\n837 F.3d 753, 757-58 (7th Cir. 2016) (\"[a]s a member of the public, [the Reporters Committee]\nhas standing to assert [its] claim\" to grand jury materials because such materials are \"public records\nto which the public may seek access, even if that effc ‘ro\nis 'mately unsuccessful\").\n56.\n\nHere, the continued denial of access\n\nbehalf of its journalists and the public it eyves\n\ni\n\nrmation The Palm Beach Post seeks on\n\nquestionably constitutes irreparable injury.\"\n\nGainesville Woman Care. LLC v. State of Florida. 210 So. 3d 1243. 1263 (Fla. 2017); see also\n, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that \"the press' function as a vital\n\nZerilli v.\n\nsource of information is weakened whenever the ability of journalists to gather information is\nimpaired,\" as it is by Attorney General's refusal to disclose unredacted report and underlying grand\njury materials).\nE.\n\nThe Court's Supervision of the Grand Jury Process and Its Authority to Order\nPublic Disclosure of the Epstein Evidence.\n57.\n\nThe Florida Supreme Court has noted that \"in states such as Florida, where the\n\ngrand jury is preserved, it is an important appendage of the court which impanels it. At the same\ntime it should not be forgotten that the judge of that court is equally important and he is generally\ncharged \n... [truncated, 2115 chars — for the full page use /api/corpus/document/EFTA02734027/29 or ?id=EFTA02734027&page=29]", "char_count": 2115}, {"efta_number": "EFTA02734027", "page_number": 30, "text_content": "maintain the dignity and the integrity of both the grand jury and the presiding judge.\" State v.\nClemons, 150 So. 2d 231, 233-34 (Fla. 1963).\n58.\n\nChapter 905 of the Florida Statutes governs the empanelment and conduct of\n\nFlorida grand juries. The court gives the grand jury its initial charge and advises the grand jury\nabout its legal duties. Fla. Stat. § 905.18.\n59.\n\nFlorida Stat. Section 905.27(1) provides that \"the testimony of a witness examined\n\nbefore the grand jury . . . or other evidence received by it\" may be disclosed \"when required by a\ncourt . . . for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by\nthe witness before the court; (b) Determining whether the witness is guilty of perjury; or (c)\nFurthering justice.\" Fla. Stat. § 905.27(1Xa)-(c).\n60.\n\nFurther, disclosure is appropriate pursuant to this Court's inherent authority over\n\ngrand jury proceedings because of the exceptional public interest in this case and the compelling\ncircumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 (\"a district court\nhas the inherent power to disclose [grand jury] materials in exceptional circumstances and . . .\nhistoric importance can be a sufficient reason when there is little countervailing need for secrecy\").\nCOUNT I\n(Florida Stat. Section 905.27)\n61.\nRecords'\n\neon\n\ninformation learned by The Palm Beach Post through its Florida Public\n\nuests. law enforcement sources with direct knowledge of the grand jury evidence\n\nand proceedings, judicial documents obtained from independent but related court proceedings. and\ndocuments otherwise available in the public record, the State Attorney for Palm Beach County\npresented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner\n\n17\n\nEFTA02734057\n\n\f", "char_count": 1808}, {"efta_number": "EFTA02734027", "page_number": 31, "text_content": "that precluded his indictment for the serious crimes he committed, including sex trafficking and\nsexual assault.\n62.\n\nPursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's\n\nvictims and the public, and to provide public disclosure to illuminate whether Epstein received\nunreasonably lenient treatment based on the available evidence, The Palm Beach Post requests\nimmediate public access to the testimony, minutes, and other evidence present\n\nAr2006 to the\n\nPalm Beach County grand jury. In a case of this magnitude and importance, wher\n\ne accused is\n\ndead and so many of his crimes, as well as the identities and crimes of his co-conspirators, and the\nidentities of the victims have already been exposed, the need for grand jury secrecy is no more.\nSee United States v. Socony-Vacuton Oil Co., 310 U.S. 150,\"234 (1940) (\"[A]fter the grand jury's\nfunctions are ended, disclosure is wholly proper where the ends of justice require it.\").\nWHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla.\nStat. Section 905.27(1) and the Court's inherent authority, order the State Attorney and the Clerk\nof the Court to file with this Court copies of the testimony, minutes, and other evidence presented\nin 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so\nthat, following an in camera inspection, it can be made available to The Palm Beach Post and the\npublic on an expedite( basis, and grant any other and further equitable or legal relief the Court\ndeems just a\n\n18\n\nEFTA02734058\n\n\f\n\n[═══ TRANSCRIPT ═══]\nEXHIBIT 1 The Newspaper's Reportage on Jeffrey Epstein  EFTA02734060", "char_count": 1666}, {"efta_number": "EFTA02734027", "page_number": 32, "text_content": "Dated: November 14. 2019\n\nRespectfully submitted,\nGREENBERG TRAURIG, P.A.\nAttorneysfor CA Florida Holdings, LLC,\nPublisher of The Palm Beach Post\nStephen A. Mendelsohn, Esq.\n5100 Town Center Circle, Suite 400\nBoca Raton, Florida 33486\nTelephone: (561) 955-7629\nFacsimile: (561) 338-7099\nBy: is/ Stephen A. Mendelsohn\nSTEPHEN A. MENDELSOCSS\nFlorida Bar No. 849324\nmcndeisohnitectlaw.e\nhasenh@gtlaw.com\nFLService®gtla\nA\nBy: /s/ Michael flip;\nMICHAEL I RY IEL\n(Pro 1th ficzapplication forthcoming)\n54\nt, ‘th Floor\nYork 12207\ne: (518) 689-1400\ne: (518) 689-1499\neielnamlavv.com\n\n+6s\n\n: Is! Vincent H Chiefib\nVINCENT H. CHIEFFO\n(Pro Hew Vice application forthcoming)\n1840 Century Park East, Suite 1900\nLos Angeles CA 90067\nTelephone: (310) 586 7700\nFacsimile: (310 586 7800\nchicffovaityilaw.com\nriveraal©gtlaw.com\nBy: Is/ Nina D. Boraiian\nNINA D. BOYAJIAN\n(Pro Hac Vice application forthcoming)\n1840 Century Park East, Suite 1900\nLos Angeles CA 90067\nTelephone: (310) 586 7700\nFacsimile: (310) 586 7800\nboy& iarugalatlaw cam\nriveraallatnlaw.com\n\nACTIVE 45678709v3\n\n19\n\nEFTA02734059\n\n\f", "char_count": 1079}, {"efta_number": "EFTA02734027", "page_number": 33, "text_content": "EXHIBIT 1\nThe Newspaper's Reportage on Jeffrey Epstein\n\nEFTA02734060\n\n\f", "char_count": 71}, {"efta_number": "EFTA02734027", "page_number": 34, "text_content": "The Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nThe Man Who Had Everything: Jeffrey Epstein craved big\nhomes, elite friends and underage girls\nBy Andrew Marra\nPosted Jul 17, 2019 at 6:02 AM\n\nFrom the archives: When Palm Beach detectives started asking\nquestions and teenage girls started talking, a wave of legal resistance\nfollowed.\nEditor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after\nJeffrey Epstein's arrest in Palm Beach County on a charge offelony solicitation of prostitution.\nWINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach mansion. Inside,\nhidden cameras trolled two rooms, whilehe girljcame and went.\nFor the police detectives who sifted yFquglt the garbage outside and kept records of visitors, it\nwas the lair of a troubling target.\nEpstein, one of the most mysterious of the country's mega-rich, was known as much for his\nsecrecy as for his love of fine things: magnificent homes, private jets, beautiful women,\nfriendships with the world's elite.\nBut at Palm Beach police headquarters, he was becoming known for something else: the\nregular arrival of teenage girls he hired to give him massages and, police say, perform sexual\nfavors.\nEpstein was different from most sexual abuse suspects; he was far more powerful. lie counted\namong his friends former President Bill Clinton, Donald Trump and Prince Andrew, along\nwith some of the most prominent legal, scientific and business minds in the country.\nWhen detectives stared asking questions and teenage girls started talking, a wave of legal\nresistance followed.\n\nEFTA02734061\n\n\f", "char_count": 1599}, {"efta_number": "EFTA02734027", "page_number": 35, "text_content": "» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during workrelease\nIf Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.\nEpstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends\nquietly, always in the background as he navigated New York high society.\nWhen he first attracted notice in the early 1990s, it was on account of the woman he was\ndating: Ghislaine Maxwell, daughter of the late British media tycoon Robert\n\nell.\n\nIn a lengthy article, headlined \"The Mystery of Ghislaine Maxwell's Secret\n\n, the British\n\nMail on Sunday tabloid laid out speculative stories that the socialite' beau,was a CIA spook, a\nmath teacher, a concert pianist or a corporate headhunter.\n\"But what is the truth about him?\" the newspaper wonder\nflamboyant and intensely private.\"\n\n9\n\nMaxwell, Epstein is both\n\n<\\The media frenzy did not begin in full until a dtcSelcr.\nIn September 2002, Epstein was\nflung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to\nAfrica on his private jet.\nti\nSuddenly everyone wanted to kredi:iwh\n\nir\npstein was. New York magazine and Vanity Fair\n\npublished lengthy profiles. The New York Post listed him as one of the city's most eligible\nbachelors and began descri bic.\n' g him in its gossip columns with adjectives such as \"mysterious\"\nand \"reclusive.\"\nAlthough Ep\n\nno interviews, the broad strokes of his past started to come into focus.\n\nBuilding a life of extravagance\nHe was born blue-collar in 1953, the son of a New York City\n\ndepartment employee, and\n\nraised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree\nbut became a math teacher at the prestigious Dalton School in Manhattan.\nThe story goes that the father of one of Epstein's students was so impressed with the man that\nhe put him in touch with a senior partner at Bear Stearns, the global investment bank and\nsecurities firm.\n\nEFTA02734062\n\n\f", "char_count": 1973}, {"efta_number": "EFTA02734027", "page_number": 36, "text_content": "In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.\nEpstein and Co. That is when he began making his millions in earnest.\nLittle is known or said about Epstein's business except this: He manages money for the\nextremely wealthy. He is said to handle accounts only of $I billion or greater.\nIt has been estimated he has roughly 15 clients, but their identities are the subject of only\nspeculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a\nformer Palm Beacher who is said to have been a mentor to Epstein.\nWexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a\nblock on Manhattan's Upper East Side. It is reported to have, among its finer features, closedcircuit television and a heated sidewalk to melt away fallen snow.\nThat townhouse, thought to be the largest private residence in Manhattan, is only a piece of\nthe extravagant world Epstein built over time.\n%9\nIn New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch\noutside Santa Fe. Many believed it to be the largest home in the state.\nIn Palm Beach, he bought a waterfront home on El Brill° Way. And he owns a 100-acre\nprivate island in the Virgin Islands.\n» PHOTOS: The players in the,, of\n\nEpstein saga\n\nPerhaps as remarkable as hi avish homes is his extensive network of friends and associates at\nthe highest echelons of power. This includes not only socialites but also business tycoons,\nmedia moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often\nfunds.\n'just like other people collect art, he collects scientists,\" said\n\nNowak, who directs the\n\nProgram for Evolutionary Dynamics at Harvard University and was reportedly the recipient of\na $30 million research donation from Epstein.\nEpstein is said to have befriended former Harvard President Larry Summers, prominent law\nProfessor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort\nZucke\n... [truncated, 2022 chars — for the full page use /api/corpus/document/EFTA02734027/36 or ?id=EFTA02734027&page=36]", "char_count": 2022}, {"efta_number": "EFTA02734027", "page_number": 37, "text_content": "And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely\nphotographed.\n\"The odd thing is I never met him,\" said Dominick Dunne, the famous chronicler of the trials\nand tribulations of the very rich. \"I wasn't even aware of him,\" except for a Vanity Fair article.\nEpstein's friendship with Clinton has attracted the most attention.\nEpstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at\nan intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become\nclose friends until after Clinton left the Oval Office and moved to New York.\nEpstein has donated more than $100,000 to Democratic candidates' campaigns, including John\nKerry's presidential bid, the reelection campaign of New Mexico Gov. Bill\nSenate bids of Joe\n\nand the\n\n, Hillary Rodham Clinton, Christopher Dodd and Charles\n\nSchumer.\nPowerful friends and enemies\nA Vanity Fair profile found cracks in the veneer\n\nEpstein's life story. The 2003 article said he\n\nleft Bear Stearns in the wake of a federal probe and a possible Securities and Exchange\nCommission violation. It also pointed out that Citibank once sued him for defaulting on a $20\nmillion loan.\nThe article suggested that one of his business mentors and previous employers was Steven\nHoffenberg, now serving a prison term after \"bilking investors out of more than $450 million\nin one of the largest Ponzi schemes in American history.\"\nAs he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the\nman who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less\nthan $16,000 in furnishings.\nA former friend claimed Epstein backed out of a promise to reimburse him hundreds of\nthousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein\nowed him nothing.\n» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says\n\nEFTA02734064\n\n\f", "char_count": 1957}, {"efta_number": "EFTA02734027", "page_number": 38, "text_content": "\"It's a bad memory. I would rather not have ever met Jeffrey Epstein,\" said Michael Stroll, the\nretired former president of\n\nElectronics and Sega Corp. \"Suffice it to say I have\n\nnothing good to say about him:\nAmong the characteristics most attributed to Epstein is a penchant for women.\nHe has been linked to Maxwell, a fixture on the high-society party circuits in both New York\nand London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian\nmodel.\n\"He's a lot of fun to be with,\" Donald Trump told New York magazine in 2002. \"It is even said\nthat he likes beautiful women as much as I do, and many of them are on the younger side. No\ndoubt about it, Jeffrey enjoys his social life.\"\nInvestigation leads to Epstein\nAlthough he was not a frequenter of the Palm Beach social scene, he made his presence felt.\nAmong his charitable donations, he gave $90,000 to the Palm Beach Police Department and\n$100,000 to Ballet Florida.\nIn Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a\nHarley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a\nprivate chef and a small staff stood at the ready. From a window in his mansion, he could look\nout on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man\nwho had everything.\nBut extraordinary wealth can fuel extraordinary desires.\n» Epstei\n\nants to leave jail for mansion in sex-trafficking case\n\nIn March 2005, a worried mother contacted Palm Beach police. She said another parent had\noverheard a conversation between their children.\nNow the mother was afraid her 14-year-old daughter had been molested by a man on the\nisland.\nThe phone call triggered an extensive investigation, one that would lead detectives to Epstein\nbut leave them frustrated.\n\nEFTA02734065\n\n\f", "char_count": 1824}, {"efta_number": "EFTA02734027", "page_number": 39, "text_content": "Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm\nBeach police report detailing the criminal probe offers a window into what detectives faced as\nthey sought to close in on Epstein.\nDetectives interviewed the girl, who told them a friend had invited her to a rich man's house to\nperform a massage. She said the friend told her to say she was 18 if asked. At the house, she\nsaid she was paid $300 after stripping to her panties and massaging the man while he\nmasturbated.\nPolice interview 5 alleged victims\nAc\"\nThe investigation began in full after the girl identified Epstein in a phota\n\nman who had\n\npaid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift\nthrough it. They set up a video camera to record the comings and goings at his home. They\nmonitored an airport hangar for signs of his private jet's arrivals and departures.\nThey quickly learned that the woman who took the 14-year-old girl to Epstein's house was\na Palm Beach Community College student from Loxahatchee. In a sworn\nstatement at police headquarters,, then 18, admitted she had taken at least six girls to\nvisit Epstein, all between the ages of 14 and 16. E1\nDuring the drive back to her house,\n\npaid her for each visit, she said.\n\ntold detectives, \"I'm like a Heidi Fleiss.\"\n\nPolice interviewed five alleged victims and 17 witnesses. Their report shows some of the girls\nsaid they had been instructed to have sex with another woman in front of Epstein, and one said\nshe had direct intercourse with him.\nIn October, police searched the Palm Beach mansion. They discovered photos of naked, younglooking females, just as several of the girls had described in interviews. Hidden cameras were\nfound in the garage area and inside a clock on Epstein's desk, alongside a girl's high school\ntranscript.\nTwo of Epstein's former employees told investigators that young-looking girls showed up to\nperform massages two or three times a day when Epstein was \n... [truncated, 2172 chars — for the full page use /api/corpus/document/EFTA02734027/39 or ?id=EFTA02734027&page=39]", "char_count": 2172}, {"efta_number": "EFTA02734027", "page_number": 40, "text_content": "One employee told detectives he was told to send a down roses to one teenage girl after a high\nschool drama performance. Others were given rental cars. One, according to police, received a\n$200 Christmas bonus.\nThe cops moved to cement their case. But as they tried to tighten the noose, they encountered\nother forces at work.\nIn Orlando they interviewed a possible victim who told them nothing inappropriate had\nhappened between her and Epstein. They asked her whether she had spoken to anyone else.\nShe said yes, a private investigator had asked her the same questions.\n» Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal\nWhen they subpoenaed one of Epstein's former employees, he told them the same thing. He\nand a private eye had met at a restaurant days earlier to go over what the man would tell\ninvestigators.\nt '.St•,.%1C?\nDetectives received complaints that private eyes were posing as police officers. When they told\nEpstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the\nhigh-powered Miami lawyer who has defended the likes of Rush Limbaugh and William\nKennedy\nWhile the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law\nprofessor, traveled to West Palm Beach with information about the girls. From their own\nprofiles on the popular Web site MySpace.com, he obtained copies of their discussions about\ntheir use of alcohol and marijuana.\nHe took his research to a meeting with prosecutors in early 2006, where he sought to cast\ndoubt on the teens' reliability.\nThe private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only\ndid some of the girls have issues with drugs or alcohol but also some had criminal records and\nother troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she\ntold police she was younger than 18 when she started performing massages for Epstein.\nAfter the meeting, prosecutors postponed their decision to take the cas\n... [truncated, 2035 chars — for the full page use /api/corpus/document/EFTA02734027/40 or ?id=EFTA02734027&page=40]", "char_count": 2035}, {"efta_number": "EFTA02734027", "page_number": 41, "text_content": "In the following weeks, police received complaints that two of the victims or their families had\nbeen harassed or threatened. Epstein's legal team maintains that its private investigators did\nnothing illegal or unethical during their research.\nBy then, relations between police and prosecutors were fraying. At a key meeting with\nprosecutors and the defense, Detective Recarey, the lead investigator, was a no-show,\naccording to Epstein's attorney.\n\"The embarrassment on the prosecutor's face was evident when the police officeninscr\nshowed up for the meeting: attorney Jack Goldberger said.\nLater in April, Recarey walked into a prosecutor's office at the state atto\n\nffice and\n\nlearned the case was taking an unexpected turn.\nThe prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein\na plea deal that would not require him to serve jail time or receive a felony conviction.\nRecarey told her he disapproved of the plea offer. -S\n\n,\n\nThe deal never came to pass, however.\nFuture unclear after charge\nOn May 1, the department asked prosecutors to approve warrants to arrest Epstein on four\ncounts of unlawful sexual activity with a minor and to charge his personal assistant,\n\ne\n\n, now 27, for her alleged role in arranging the visits. Police officials also wanted to\ncharge\n, the self-described Heidi Fleiss, with lewd and lascivious acts.\nBy then, the department was frustrated with the way the state attorney's office had handled the\n\ncase. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter\nwrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if\nhe would not act.\nTwo weeks later, Recarey was told that prosecutors had decided once again to take the case to\nthe grand jury.\n\nEFTA02734068\n\n\f", "char_count": 1806}, {"efta_number": "EFTA02734027", "page_number": 42, "text_content": "It is not known how many of the girls testified before the grand jury. But Epstein's defense\nteam said one girl who was subpoenaed - the one who said she had sexual intercourse with\nEpstein - never showed up.\nThe grand jury's indictment was handed down in July. It was not the one the police\ndepartment had wanted.\nInstead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was\ncharged with one count of felony solicitation of prostitution, which carries a maximum penalty\nof five years in prison. He was booked into the Palm Beach County Jail early July 23 and\nreleased hours later.\nEpstein's legal team \"doesn't dispute that he had girls over for massages,\" Goldberger said. But\nhe said their claims that they had sexual encounters with him lack credibility.\n\"They are incapable of being believed,\" he said. \"They had criminal records. They had\naccusations of theft made against them by their employers. There was evidence of drug use by\nsome of them.\"\nWhat remains for Epstein is yet to be seen.\nThe Palm Beach Police Department has asked the FBI to investigate the case. It also has\nreturned the $90,000 Epstein donated in 2004.\nIn New York, candidates for governor and state attorney general have vowed to return a total\nof at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful\nfriends have remained silent as tabloids and Internet blogs feast on the public details of the\npolice investi at\nGoldbergermain\nat maimssins Epstein's innocence but says the legal team has not ruled out a future\nplea deal. He insists Epstein will emerge in the end with his reputation untarnished.\n\"He will recover from this,\" he said.\nStaff writer Larry\n\nand staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and\n\nMelanie Mena contributed to this story.\namarra@pbpost.com\n\nEFTA02734069\n\n\f", "char_count": 1848}, {"efta_number": "EFTA02734027", "page_number": 43, "text_content": "@AMarraPBPost\n\nEFTA02734070\n\n\f", "char_count": 30}, {"efta_number": "EFTA02734027", "page_number": 44, "text_content": "273 / 278 - Tuesday, November 16, 2004\nEdition: FINAL\nSection: A SECTION\nPage: IA\nSource: By PAUL OWERS Palm Beach Post Staff Writer\nIllustration: PHOTO (C & 2 B&W) & MAP (B&W)\nMemo: Ran all editions.\nDateline: WEST PALM BEACH\nTRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION\nWhen it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The\nDonald was not about to be trumped.\n\"Nobody was going to outbid me,\" the brash developer-turned-TV-personality said from his\nNew York office.\nTrump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,\nseven-bedroom estate on 6 oceanfront acres along the storied \"Raider's Row.\"\nBut Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at\n513 N. County Road. He wants to - what else? - sell it and make more money.\nThe star of the mega-hit The Apprentice said he intends to redevelop the site into a \"super\nluxury house\" that would be the \"finest anywhere in the United States.\" He might build\nanother house before flipping the entire package.\n\"I've known about this house for quite some time,\" Trump said. \"It's probably the best piece\nof land in Florida - and probably the country - for luxury real estate.\"\nAltho\np said he could subdivide the property into nine lots, Palm Beach Mis\nLeslyies m\naid zoning regulations allow for only two houses - and maybe a third.\nsaid she's not worried about Trump's plans.\n\"He's been a very good property owner in the town of Palm Beach,\" she said. \"He does his\nprojects very well. He's a perfectionist.\"\nMonday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of\nGosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual\ndistribution to creditors.\nThe auction began at exactly noon after Judge Steven\ndismissed an objection from\nan attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully\nthat Trump was not a qualified bidder because his contract stipulated that h\n... [truncated, 2558 chars — for the full page use /api/corpus/document/EFTA02734027/44 or ?id=EFTA02734027&page=44]", "char_count": 2558}, {"efta_number": "EFTA02734027", "page_number": 45, "text_content": "But\nallowed the offer to stand, and Puke and Trump went back and forth until\nPulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at\n$38.6 million.\nclosed the bidding 10 minutes after it started, leaving Trump with the right to buy\nthe 29.000-square-foot home (a typical Palm Beach County single-family house is about\n2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service\nquarters.\nThe closing could take place within a week but probably won't happen until next month.\nTrustee Joe Luzinski and creditors said they were pleased with the outcome.\n\"We knew we were dealing with some substantial people . who were going to bid it up a\nbit,\" Luzinski said.\n\"The system worked,\" said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.\n\"In bankruptcy court, the idea is to get the most for creditors, and that's what happened.\"\nThe auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer\nformer listing agent Sotheby's International Realty received was $32 million. Sotheby's won't\nreceive a commission, he said.\nPulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday.\n\"I got the feeling he was willing to go a lot higher, and I didn't want to chase it,\" Pulte said.\nPuke said Gosman asked him before the auction whether he would be willing to let him stay\nin the mansion after the closing until he decides where he wants to move. Trump and\nLuzinski said they have had no such discussions with Gosman.\nGosman, 75, had the house built after paying $12.1 million for the land in 1986.\nThe former health-care magnate declined interview requests before and after the auction\nMonday. He was at the courthouse but left before the auction took place.\nThe $41.35 million price tag eclipses the $30.35 million sale of Lowell \"Bud\" Paxson's Palm\nBeach home and guest house but falls short of the $45 million that Virginia home builder\nDwight Schar paid for Ron Perelman's 26,000\n... [truncated, 3441 chars — for the full page use /api/corpus/document/EFTA02734027/45 or ?id=EFTA02734027&page=45]", "char_count": 3441}, {"efta_number": "EFTA02734027", "page_number": 46, "text_content": "The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife\nan ownership interest in his home and other belongings only to avoid losing them in\nbankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in\n1999, well before he filed for bankruptcy.\nLessen is expected to rule in the next two months whether Gosman made improper transfers,\na decision that will affect how much money will be available to creditors.\nCimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were\nwilling to move forward, in part because the upkeep of the estate now exceeds their means.\n\"This is not a happy occasion for them, but at least we're moving to the next level,\" Cimo\nsaid. \"That's not a house you want to live in unless you're making large amounts of money\nlike Donald Trump.\"\npaul_owers®pbpost.com\nCO\n\n1.\n\nC/1\n\nEFTA02734073\n\n\f", "char_count": 900}, {"efta_number": "EFTA02734027", "page_number": 47, "text_content": "iiti I:iv p‘\n\nnocunent osponalle Joentea\n\nImes - MOWS - ine ran Deacn rost - noes( ran beaal. rL\n\nThe Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nIndictment: Billionaire Solicited 3 Times\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 2, 2019 at 2:30 PM\n(EDITOR S NOTE: This story originally published in The Palm Beach Post on July 25,\n2006)\nBillionaire money manager and Palm Beach pan-time resident Jeffrey E0tein\nsolicited or procured prostitutes three or more times between Aug. 1 and Oct. 31\nof last year, according to an indictment charging him with felony solicitation of\nprostitution.\nEpstein, 53, was booked at the Palm Beach Coun\n\nat at :45 a.m. Sunday. He\n\nwas released on $3,000 bond.\nEpstein's case is unusual in that suspected bts2ttution johns are usually charged\nwith a misdemeanor, and even a felony charge is typically made in a criminal\ninformation - an alternative to ate\n\ntnnent charging a person with the\n\ncommission of a crime.\nc 14\n/\nHis attorney, Jack Goldberg, declined to discuss the charge.\nState attorney's offic p3kesman Mike Edmondson also had little to say.\n\"Generally speaieing, there is a case that has a number of different aspects to it,\"\nEdmondson said of a prostitution-related charge being submitted to a grand jury.\n\"We first became aware of the case months ago by Palm Beach police.\"\nProsecutors and police worked together to bring the case to the grand jury, he\nsaid.\n\nhtftwliwww nalr/stswiwwxt earn/r~t/7/111A117111\n\n1/7\n\nEFTA02734074\n\n\f", "char_count": 1471}, {"efta_number": "EFTA02734027", "page_number": 48, "text_content": "ornament tmuonatre b011Obia 4 times - news - I ne ran peace rosi - west ram Donn, N.\n\nPalm Beach police confirmed that and said the department will release a report\ntoday regarding its investigation.\nEpstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a\npool and a boat dock on the Intracoastal Waterway since 1990, according to\nproperty records. A man answering the door there Monday said that Epstein\nwasn't home. A Cadillac Escalade registered to him was parked in the driveway,\nwhich is flanked by two massive gargoyles.\nEpstein sued Property Appraiser Gary Nikolits in 2001, contending that the\nassessment of his home exceeded its fair market value. He dismissed his lawsuit\nin December 2002.\nA profile of Epstein in Vanity Fair magazine said he owns what are believed to\nbe the largest private homes in Manhattan - 51,000 square feet - and in New\nMexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the\nU.S. Virgin Islands and fleet of aircraft.\nEpstein's friends and admirers, according to the magazine, include prominent\nbusinessmen, academics and scientists and famed Harvard law professor Alan\nDershowitz.\n\nhttroviAway na►nhaarhmat rnm/nowcOMAIT7f11finelirini^nOmIlinnainutnritiowLIJimaa\n\nEFTA02734075\n\n\f", "char_count": 1260}, {"efta_number": "EFTA02734027", "page_number": 49, "text_content": "Pater song prone, emanate man solicitation cnarge - news - r ne ram cloaca rust - avast ram neacn. rL\n\nI II I ULU II\n\nThe Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nAfter long probe, billionaire faces solicitation\ncharge\nPosted Jul 27, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 3:11 PM\n(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 26,\n2W6)\nPalm Beach billionaire Jeffrey Epstein paid to have underage girls and young\nwomen brought to his home, where he received massages and sometimes sex,\naccording to an investigation by the Palm Beach Police Department.\nPalm Beach police spent months sifting through Epstein's trash and watching his\nwaterfront home and Palm Beach International Airport to keep tabs on his\nprivate jet. An indictment charging Epstein, 53, was unsealed Monday, charging\nhim with one count of felony solicitation of prostitution.\nPalm Beach police thought there was probable cause to charge Epstein with\nunlawful sex acts with a minor and lewd and lascivious molestation.\nPolice Chief Michael Reiter was so angry with State Attorney Barry Krischer's\nhandling of the case that he wrote a memo suggesting the county's top\nprosecutor disqqcfy himself.\n\"I must urge you to examine the unusual course that your office's handling of this\nmatter has taken and consider if good and sufficient reason exists to require your\ndisqualification from the prosecution of these cases,\" Reiter wrote in a May 1\nmemo to Krischer.\nWhile not commenting specifically on the Epstein case, Mike Edmondson,\nspokesman for the state attorney, said his office presents cases other than\nmurders to a grand jury when there are questions about witnesses' credibility and\ntheir ability to testify.\n\nhlinclhwm. nahnhearhneltat nrwninave0WIR11777/0tarannn.nmtwa.hillionairoanvotanliritatinn-thamt.\n\n1M\n\nEFTA02734076\n\n\f", "char_count": 1830}, {"efta_number": "EFTA02734027", "page_number": 50, "text_content": "pin ifLUIV\n\nerror long prove. onnonarce races soacnanon awns - POWS • IIla ram 0411011 roar • vvest ram DOOM, rL\n\nBy the nature of their jobs, police officers look at evidence from a \"one-sided\nperspective,\" Edmondson said. \"A prosecutor has to look at it in a much broader\nfashion,\" weighing the veracity of witnesses and how they may fare under\ndefense attorneys' questioning, he said.\nEpstein's attorney, Jack Goldberger, said his client committed no crimes.\n\"The reports and statements in question refer to false accusations that were not\ncharged because the Palm Beach County state attorney questioned the credibility\nof the witnesses,\" Goldberger said. A county grand jury \"found the allegations\nwholly unsubstantiated and not credible,\" and that's why his client was not\ncharged with sexual activity with minors, he said.\nGoldberger said Epstein passed a lie detector test administered by a reputable\npolygraph examiner in which he said he did not know the girls were minors.\nAlso, a search warrant served on Epstein's home found no evidence to\ncorroborate the girls' allegations, Goldberger said.\nAccording to police documents:\n- A Palm Beach Community Colle\n\nstudent said she gave Epstein a massage in\n\nthe nude, then brought him sixgi\n\nes 14 to 16, for massage and sex-tinged\n\nsessions at his home.\n- A 27-year-old woman who worked as Epstein's personal assistant also\nfacilitated the liaisons, phoning the PBCC student to arrange for girls when\nEpstein was coming to town. And she escorted the girls upstairs when they\narrived, putting fresh sheets on a massage table and placing massage oils nearby.\n- Police took sworn statements from five alleged victims and 17 witnesses. They\ncontend that on three occasions, Epstein had sex with the girls.\nA money manager for the ultra-rich, Epstein was named one of New York's most\neligible bachelors in 2003 by The New York Post. He reportedly hobnobs with\nthe likes of former President Clinton, former Harvard University President\nSummers and Don\n... [truncated, 2202 chars — for the full page use /api/corpus/document/EFTA02734027/50 or ?id=EFTA02734027&page=50]", "char_count": 2202}, {"efta_number": "EFTA02734027", "page_number": 51, "text_content": "lir ruzuag\n\npurer long prow, aeronaut races soacnauon cnarge • news - Ina ram onus rest • vs•esi warm raison, n.\n\nHe has contributed tens of thousands of dollars to Democratic Party candidates\nand organizations, including Sen. John Kerry's presidential bid, and the Senate\ncampaigns of Joen,\n\nHillary Clinton,MIS\n\nDodd and Charles\n\nSchumer.\n\nk Cic;C)\nGoldberger is one of five attorneys Epsteika retained since he became the\nsubject of an investigation, Edmondson said. Among the others: Alan\nDershowitz, the well-known Harvard law professor and author, who is a friend\nof Epstein. Dershowitz could not be reached for comment.\nPolice said the woman who enlisted young girls for Epstein was\n20, of=\n\nPalm Beach.\n\nhas worked at an Olive Garden restaurant in\n\nWellington and said she was a journalism major at Palm Beach Community\nCollege when she was questioned by police last October. She has an unlisted\nphone number and could not be reached for comment.\n\na\n\nsaid she met Epstein when, at age 17, a friend asked her if she would like\n\nto make money giving him a massage. She said she was driven to his fivebedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs\nto a bedroom with a massage table and oils. Epstein and\n\nwere both naked\n\nduring the massage, she said, but when he grabbed her buttocks, she said she\ndidn't want to be touched.\n\nhting.//www nairnhAartnnat earn/nowniMIIIRA777/oftablnon.nenhortilllinnaen-fg~.enliribitinturhstrno\n\nEFTA02734078\n\n\f", "char_count": 1479}, {"efta_number": "EFTA02734027", "page_number": 52, "text_content": "Ansi tong prow etionaire races soaatation cnarge • news • r ne ram oeacn rest - nest earn neacn,\n\ntiiiizula\n\nEpstein said he'd pay her to bring him more girls - the younger the better,\n=\n\ntold police. When she tried once to bring a 23-year-old woman to him,\n\nEpstein said she was too old,\n=,\n\nsaid.\n\nwho has not been charged in the case, said she eventually brought six\n\ngirls to Epstein who were paid $200 each time=\n\nsaid. I'm like a Heidi\n\nFleiss,\" police quoted her as saying. The girls knew what to expect when they\nwere taken to Epstein's home=\n\nsaid. Give a massage - maybe naked - and\n\nallow some touching.\nOne 14-year-old girl=\n\ntook to meet Epstein led police to start\n\ninvestigation of him in March 2005. A relative of the girl called to s\nthought the child had recently engaged in sex with a Palm Beach man.\n\ne girl\n\nthen got into a fight with a classmate who accused her of being a prostitute, and\nshe couldn't explain why she had $300 in her purse.\nThe girl gave police this account of her meeting with Epstein:\nShe accompanied= and a second girl to Epstein's house on a Sunday in\nFebruary 2005. Once there, a woman she thought was Epstein's assistant told the\ngirl to follow her upstairs to a room featuring a mural of a naked woman, several\nphotographs of naked women on a shelf, a hot pink and\n\nsofa and a massage\n\ntable.\nShe stripped to her bra and panties and gave him a massage.\nEpstein gave the 14-year-old $300 and she and the other girls left, she said. She\nsaid =\n\ntold her that Epstein paid her $200 that day.\n\nOther girls told similar stories. In most accounts, Epstein's personal assistant at\nthe time,\n\n, now 27, escorted the girls to Epstein's bedroom.\n\nwhose most recent known address is in North Carolina, has not been\ncharged in the case.\nPalm Beach police often conducted surveillance of Epstein's home, and at Palm\nBeach International Airport to see if his private jet was there, so they would\nknow when he was in town. Police also arranged repeatedly to receive his\n... [truncated, 2123 chars — for the full page use /api/corpus/document/EFTA02734027/52 or ?id=EFTA02734027&page=52]", "char_count": 2123}, {"efta_number": "EFTA02734027", "page_number": 53, "text_content": "I imv IV\n\nAuer ang moo. eradiate races sandarac cnarge - news- Ice rain peace rost\n\nrain mace. rt.\n\nfrom Palm Beach sanitation workers, collecting papers with names and phone\nnumbers, sex toys and female hygiene products.\nOne note stated that a female could not come over at 7 p.m. because of soccer.\nAnother said a girl had to work Sunday - \"Monday after school?\" And still\nanother note contained the work hours of a girl, saying she leaves school at 11:30\na.m. and would come over the next day at 10:30 a.m.\nOnly three months before the police department probe began, Epstein donated\n$90,000 to the department for the purchase of a firearms simulator, said Jane\nStruder, town finance director. The purchase was never made. The mac was\nreturned to Epstein on Monday, she said.\n\nO\nC\n\n,S P\n\nhenerthresenararrasrient mortftwaraffellRf1727/aestraninnramIts-hIlinnelrearets-anliritstleneetame\n\nNR\n\nEFTA02734080\n\n\f", "char_count": 909}, {"efta_number": "EFTA02734027", "page_number": 54, "text_content": "route say lawyer tnea KO electron teenage guns - news - ram beam Lay news - rem eeacn. rL\n\nIII lozuly\n\nPalm Beach Daily News\nPolice say lawyer tried to discredit teenage\ngirls\nPosted Jul 29, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 2:00 PM\n(EDITOR'S NOTE: This story originally was published in The Palm Beads Pond)?\n29, 2000\nFamed Harvard law professor Alan Dershowitz met with the Patin Beach County\nState Attorney's Office and provided damaging information about teenage girls\nwho say they gave his client, Palm Beach billionaire Jeffrey T1pa sexually\ncharged massages, according to police reports.\nThe reports also state that another Epstein attorn‘reed\n'Cl\nto a plea bargain that\nwould have allowed Epstein to have no\nk\n\nI‘crialrecord.\ni\nHis current attorney\n\ndenies this happened.\n\nI\n\nAnd the documents also reveal tha\n\net ather of at least one girl complained that\n\nprivate investigators aggressively followed his car, photographed his home and\nchased off visitors.\nPolice also talked to somebody who said she was offered money if she refused to\ncooperate witI\\\nthe Palm Beach Police Department probe of Epstein.\nThe scat alto\n\noffice said it presented the Epstein case to a county grand\n\njury this month rather than directly charging Epstein because of concerns about\nthe girls' credibility. The grand jury indicted Epstein, 53, on a single count of\nfelony solicitation of prostitution, which carries a maximum penalty of five years\nin prison.\nPolice believed there was probable cause to charge Epstein with the more serious\ncrimes of unlawful sex acts with a minor and lewd and lascivious molestation.\nPolice Chief Michael Reiter was so angry that he wrote State Attorney Barry\nKrischer a memo in May suggesting he disqualify himself from the case.\n\nhltrwitutom nalmhowthitaihmnot nnentarantRINIMMAROVVS)10(1417S7A\n\nEFTA02734081\n\n\f", "char_count": 1839}, {"efta_number": "EFTA02734027", "page_number": 55, "text_content": "rot* say tawyer tneo to oiscoran teenage guns - MOWS • ram Deem twiny news • earn oeacn. I-L\n\nr V1lizinti\n\nThe case originally was going to be presented to the grand jury in February, but\nwas postponed after Dershowitz produced information gleaned from the Web\nsite myspace.com showing some of the alleged victims commenting on alcohol\nand marijuana use, according to the police report prepared by Detective=\nRecarey.\na 20-year-old =Palm Beach woman who told police she\nrecruited girls for Epstein, also is profiled on myspace.com. Her page includes\nphotos of her and her friends, including one using the name \"Pimpin' Made EZ.\"\nwho was not charged in the case, is a potential prosecution witness.\nAccording to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys\nDershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with\nEpstein, accepted the deal, in which Epstein would plead guilty to one count of\naggravated assault with intent to commit a felony, be placed on five years'\nprobation and have no criminal record. The deal also called for Epstein to submit\nto a psychiatric and sexual evaluation and have no unsupervised visits with\nminors, according to Recarey's report. The plea bargain was made in connection\nwith only one of the five alleged victims, the report states.\nFronstin - who declined to comment on the case - was subsequently fired and\nveteran defense attorney Jack Goldberger was hired. He denies there was any\nagreement by any of Epstein's attorneys to a plea deal.\n\"We absolutely did not agree to a plea in this case,\" he said. Neither Belohlavek\nnor a state attorney's spokesman could be reached for comment.\nThe parent or parents of alleged victims who complained of being harassed by\nprivate investigators provided license tag numbers of two of the men. Police\nfound the vehicles were registered to a private eye in West Palm Beach and\nanother in Jupiter, according to Recarey's report.\n\"I have no knowledge of it,\" defense attorney Goldberger s\n... [truncated, 2330 chars — for the full page use /api/corpus/document/EFTA02734027/55 or ?id=EFTA02734027&page=55]", "char_count": 2330}, {"efta_number": "EFTA02734027", "page_number": 56, "text_content": "rri entry\n\nrosa say wryer wee w onscreen teenage pro - news - rani deem yaw teens • ram maw. rt.\n\nwho did talk \"will be dealt with,\" the woman said she was told. Phone records\nshow the woman talked with the person who allegedly intimidated her around\nthe time she said, Recarey reported.\n\nPhone records also show that the person said to have made the threat then\nplaced a call to Epstein's personal assistant, who in turn called a New York\ncorporation affiliated with Epstein, the report states.\nThe issue in the Epstein case is not whether females came to his waterfront\nhome, but whether he knew their ages.\n\"He's never denied girls came to the house,\" Goldberger said. But when Ep.\nwas given a polygraph test, \"he passed on knowledge of age,\" the attorney said.\nAfter the indictment against Epstein was unsealed this week, Police Chief Reiter\nreferred the matter to the FBI. \"We've received the referral, and we're reviewing\nit,\" said FBI spokeswoman Judy Orihuela in Miami.\nThe chief himself has come under attack from Epalawyers and friends in\nNew York, where he has a home. The New York Post quoted Epstein's\nprominent New York lawyer, Gerald Lefcourt, as saying his client was indicted\nonly \"because of the craziness of the police chief.\"\nReiter has declined to comment on the case.\nProsecutors have not presented a sex-related case like Epstein's to a grand jury\nbefore, said Mike Edmondson, spokesman for the state attorney's office. \"That's\nwhat you do with a case that falls into a gray area: he said.\nThe state attorney's office did not recommend a particular criminal charge on\nwhich to indict Epstein, Edmondson said. The grand jury was presented with a\nlist of charges from highest to lowest, then deliberated with the prosecutor out of\nthe room, he said.\n\"People are surprised at the grand jury proceeding,\" West Palm Beach defense\nattorney Richard Tendler said. \"It's a way for the prosecutor's office to not take\nthe full responsibility for not filing the (charge), and not doing wh\n... [truncated, 2191 chars — for the full page use /api/corpus/document/EFTA02734027/56 or ?id=EFTA02734027&page=56]", "char_count": 2191}, {"efta_number": "EFTA02734027", "page_number": 57, "text_content": "voice say tawyer MO (0 OtSCISOR teenage spins - MVOs - ram owes Uglily NOM - earn 150300. rt.\n\nDefense attorney Robert Gershman was a prosecutor for six years. \"Those girls\nmust have been incredible or untrustworthy, I don't know,\" he said.\nOther attorneys said Epstein's case raises the issue of whether wealthy, connected\ndefendants like Epstein - whose friends include former President Clinton and\nDonald Trump - are treated differently from others. Once he knew he was the\nsubject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as\nDershowitz and Lefcourt, who is a past president of the National Association of\nCriminal Defense Lawyers.\nMiami lawyer Roy Black - who became nationally known when he sucNe ts\nfully\ndefended William Kennedy= on a rape charge in Palm Beacl\n\na\n\ninvolved at one point.\nSaid defense attorney=\n\nC\nSuskauer: \"I think it's unfortunate the public may\n\nget the perception that with power, you may be treated differently than the\naverage Joe.\"\n\\ 4 9%1\n\nhttnn\"livam natniNutelvIAlhman nuniartiriatNIAA079a/PaWS/144101757•A\n\n4(4\n\nEFTA02734084\n\n\f", "char_count": 1093}, {"efta_number": "EFTA02734027", "page_number": 58, "text_content": "The Palm\nBeach\nPost\nREAL NEWS STARTS KERE\nExpert: Ignorance of age isn't\ndefense in sex cases\nPosted Aug 5, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 1:38 PM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on Aug. 5, 2006)\nEven if Palm Beach money manager Jeffrey Epstein didn't\nknow that girls who police say gave him sexual massages at\nhis Intracoastal home were under the legal age, that alone\nwouldn't have exempted him from crimin cha ges of\nsexual activity with minors.\n\"Ignorance is not a valid defense,\"iad\n\\tob\n\nelde, a legal\n\nskills professor who was a Lake City prosecutor for nearly\n30 years, half of that time specializing in sex crimes against\nchildren.\n\"There is no knowledge element as far as the age is\nconcerned,\" Dekle said.\nAfter an 11-month investigation, Palm Beach police said\nthere was probable cause to charge Epstein, 53, with\nunlawful sex acts with a minor and lewd and lascivious\nmolestation. They contend that Epstein - friend of the rich\nand famous and financial patron of Democratic Party\norganizations and candidates - committed those acts with\nfive underage girls.\nIn the past week, New York Attorney General and\ngubernatorial candidate Eliot Spitzer has returned about\n$50,000 in campaign contributions he received from\nEpstein, and Mark\n\n, a candidate to replace Spitzer in\n\nEFTA02734085\n\n\f", "char_count": 1346}, {"efta_number": "EFTA02734027", "page_number": 59, "text_content": "his current job, has returned S10,000 to him because of the\nPalm Beach scandal, the New York Daily News has\nreported.\nRather than file charges, the state attorney's office\npresented the case to a county grand jury. The panel\nindicted Epstein last week on a single, less serious charge of\nfelony solicitation of prostitution.\nThe case raised eyebrows because the state attorney's office\nrarely, if ever, kicks such charges to a grand jury. And it\nincreases the difficulty of prosecuting child sex abuse cases;\nespecially when the defendant is enormously wealthy\ncan hire high-priced, top-tier lawyers.\nAt least one of Epstein's alleged victims told police he knew\nshe was underage when the two of them got naked for\nmassages and sexual activity. She was 16 years old at the\ntime and said Epstein asked her questions about her high\nschool, according to police r\nA girl who said she met E\n\nwhen she was 15 said he\n\ntold her if she told anybody what happened at his house,\nbad things could happen, the police reports state.\nEpstein's youngest alleged victim was 14 when she says she\ngave him a massage that included some sexual activity. She\nis now 16. The girl's father says he doesn't know whether\nshe told Epstein her age.\n+\n\nMy daughter has kept a lot of what happened from me\nbecause of sheer embarrassment,\" he said. \"But she very\nmuch looked 14. Any prudent man would have had second\nthoughts about that.\"\nDefense attorney Jack Goldberger maintains that not only\ndid Epstein pass a polygraph test showing he did not know\nthe girls were minors, but their stories weren't credible.\nThe state attorney's office also implied that their credibility\nwas an issue when it decided not to charge Epstein directly,\nbut instead give the case to the grand jury.\nEFTA02734086\n\n\f", "char_count": 1768}, {"efta_number": "EFTA02734027", "page_number": 60, "text_content": "\"A prosecutor has to look at it in a much broader fashion,\" a\nstate attorney's spokesman said last week.\n\nL\n\nEpstein hired Harvard law Professor Alan bershowitz\nwhen he became aware he was under investigation, and\nDershowitz gave prosecutors information that some of the\nalleged victims had spoke of using alcohol and marijuana on\na popular Web site, according to a Palm Beach police\nreport.\nProsecutors typically consider two things in deciding\nwhether to charge somebody with sex-related offenses\nagainst minors - whether there is sufficient evidence and\nwhether there is a public interest in doing so, Dekle said.\nIf two teens are in a sexual relationship and the boy turns\n18 before the girl, he could be charged with a sex crime if\nthe sex continues. There would be no public interest in\npursuing that, Dekle said.\nBut where there is a large gap in ages - and especially in\ncases of teachers with students - there is a public interest in\nprosecuting, he said. Likewise if the accused has a track\nrecord of sex with minors.\n\nEFTA02734087\n\n\f", "char_count": 1044}, {"efta_number": "EFTA02734027", "page_number": 61, "text_content": "Still there is a \"universal constant\" in prosecuting these\ncases, Dekle said. Men who exploit underage children for\nsex often carefully choose their victims in ways that will\nminimize the risk to them, he said.\nVictims usually are from a lower social status, and they may\nsuffer from psychological problems, Dekle said.\n\"Lots of child sexual abuse victims have been victimized by\nmultiple people over a period of time. Then the act of abuse\nproduces behavior in the victims that further damages their\ncredibility? Examples include promiscuous behavior and\ndrug abuse.\nSome of the alleged victims in the Epstein case returned to\nhis home multiple times for the massage sessions and the\n$200 to $300 he typically paid them per visit. \"That would\nbe a definite problem for the prosecutor,* said Betty Resch,\nwho prosecuted crimes against children in Palm Beach\nCounty for five years and novyisyg private practice in Lake\nWorth.\n\"The victim becomes less\nc ympatheti\nase\nc\" to a jury, Resch said.\n\"But she's a victim nevertheless. She's a kid.\"\nMost men charged with sex crimes against minors look\nnormal, Dekle said. A jury expecting to see a monster\nseldom will. And the victims' ages work against them and in\nfavor of the defendant in a trial, Dekle said.\nIf a child and an adult tell different stories and both swear\nthey're telling the truth, adult jurors are more likely to\nbelieve the adult, nettle said.\n\"You have all these things working against you in a child\nsex abuse case. Prosecutors normally try to be very careful\nin filing those cases because they know what they're getting\ninto. There is no such thing as an iron-clad child sexual\nabuse case.\"\n\nEFTA02734088\n\n\f", "char_count": 1673}, {"efta_number": "EFTA02734027", "page_number": 62, "text_content": "The Palm\nBeach\nPost\nPik IDS STORM ERE\nEpstein camp calls female accusers\nliars\nPosted Aug 8, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 3:35 PM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on Aug. 8, 2006)\nAttorneys and publicists for Palm Beach financier Jeffr\nEpstein went on the offensive Monday, contending tha\nteenage girls who have accused Epstein of sexual\nshenanigans at his waterfront home are liars and saying\nthat the Palm Beach Police Department is \"childish?\n\"There never was any sex between Jeffrey Epstein and any\nunderage women,\" his lead attorney, Jack Goldberger, said\nfrom Idaho where he was vacationing with his family.\nEpstein did have young women come to his house to give\nhim massages, Goldberger said. \"Mr. Epstein absolutely\ninsisted anybody who came to his house be over the age of\n18. How he verified that, I don't know. The question is, did\nanything illegal occur. The law was not violated here.\"\nHe had no explanation as to why Epstein would pay girls or\nwomen with no massage training - as the alleged victims\nsaid was the case - $200 to $300 for their visits. \"The\ncredibility of these witnesses has been seriously\nquestioned: Goldberger said.\nEpstein, 53, was indicted by a county grand jury last month\non a charge of felony solicitation of prostitution. After an\n11-month investigation that included sifting through\nEpstein's trash and surveilling his home, Palm Beach police\nconcluded there was enough evidence to charge him with\nsexual activity with minors. When the grand jury indicted\n\nEFTA02734089\n\n\f", "char_count": 1561}, {"efta_number": "EFTA02734027", "page_number": 63, "text_content": "Epstein on the less serious charge, Police Chief Michael\nReiter referred the case to the FBI to determine whether\nthere were federal law violations.\nAfter a spate of stories about the case last week, New York\npublicist Dan Klores - whose client list has included Paris\nHilton and Jennifer\n\n- said on Saturday that Epstein's\n\ncamp was ready \"to get their story out.\"\nThey did that Monday via Goldberger and a Los Angeles\npublicist for Miami criminal defense attorney Roy Black,\n\n.AL,\n\nwho also has represented Epstein in the case.\nIS'\n\"We just think there has been a distorted view of thisce\nin the media presented by the Palm Beach police,\"\nGoldberger said.\nReiter has consistently declined to conkekty the case\nand did not respond to a request r comment Monday.\n\nThe implication that State Attorney Barry Krischer was\neasy on Epstein by presenting the case to a grand jury\nrather than filing charges directly against him is wrong,\nGoldberger said.\n\nEFTA02734090\n\n\f", "char_count": 965}, {"efta_number": "EFTA02734027", "page_number": 64, "text_content": "The Palm Beach Police Department was \"happy and\necstatic\" that the panel was going to review the evidence. \"I\nthink what happened is they weren't happy with the result.\nThey decided to use the press to embarrass Mr. Epstein.\"\nBut records show that Reiter wrote Krischer on May I well before the case went to the grand jury - suggesting that\nKrischer \"consider if good and sufficient reason exists to\nrequire your disqualification from the prosecution of these\ncases.\"\nRather than flat-out decline to charge Epstein, Krischer\n\n4,41\n\nreferred the case to the grand jury to \"appease\" the chie\nGoldberger said.\n)\nA state attorney's spokesman would say only that the office\nrefers cases to the grand jury when there are issues with the\nviability of the evidence or witnesses' credibility.\nBoth the state attorney and the grand jury concluded there\nwas not sufficient evidence that Epstein had sex with\nminors, according to Goldberger. \"It was just a childish\nperformance by the Palm Beach Police Department,\"\nGoldberger said.\nThe defense attorney said one of the alleged victims who\nclaimed she was a minor was in fact over the age of 18.\nAnother alleged victim who was subpoenaed to testify to\nthe grand jury failed to do so. Epstein's accusers, he added,\nhave histories of drug abuse and thefts. 'These women are\nliars. We've established that.\"\nBut why would they all invent their stories about meeting\nEpstein for sexual massages?\n\"I don't have an answer as to what was the motivation for\nthese women to come forward and make these allegations,\"\nGoldberger said.\n\nEFTA02734091\n\n\f", "char_count": 1577}, {"efta_number": "EFTA02734027", "page_number": 65, "text_content": "News\n\nThe Palm Beach Post (West Palm Beach, fl otilla) • 14 Aug 2006, Mon\n\nPage 7\n\nDawnloaded on Nov 11.2019\n\nPalm 'Beath thief focus\n, of fire in Epstein case\n1 &IWO\n• •\n\nI\n••\n•\n•\n\n•\n\n• 44\nt. •\n• ilia.\nh.\n• bib\n•\nIsr • 4\n\n'.•\n\n.•\n\n-\n\n•\n•\n\n••• 41\n\n•\n\n*W.\n\n-• •\n\nII• •\n\n. wit ...•\nNA SI.\n•\n•\n•\n•\n•...\nI.\n. 44.••\nno\nW • 4•4\n••• I\na • • 4* I4:•• eta •\n.4.444\nI 11.\n••••••\n••••••••\n• ••••••••41 on.\n• • a/. I.\nI\n• •.• • • •• • FR\n• 44\nI\n•\n.\n• ea. In I\nla\n• a\nse•\n.\n.• • . .\n••.i l•\n• 4 _4.\n4.\n•\nb.\n..\nore\nIi•I\nis •••••• Nab\n• • •••t•l•\n•\nI\n•• •I sr •\n•I M11\nICP•\n844 I\nan .1.404\nass\nI I •\n4 • •••\n• .41 4W\n\n••••••\n\n.14 II\n\nIs\n•\n\n•••\n\nea\n\nrt s\n\nI\n\nsy\n• ••\n\n••\n• •••••• it..\n44 I\n—As . • •\n\n•-•\n\n•••••••• •\n\n•• Ms.\n\ntam\n\n•\n\n••••••••\n\n•\n\n•••••\n\n4.• :\n\n• • .• •\n\n•\n.•34st.\n\np\nlog\n' Oar •• •••\nYe.\nI\n4...•••••••••••••\n1.••\n•\nI rt..\n•••••• 4..\n••\n• sl•\nY.\n•\n1.•\n•\n• g•\nl••\n• III • •\n.11\nPitt.%\n•••••\n64... •\nr• .Moe1.\n•-• • ten t\n. ...dia...\nI.•••\nIP • ...as.\nbars.*\n44 •\n••. •\n• •••\nb•\n••\nI...\n• .\nnos std.\n••\nsr. • s NO sk\nb\nwe I l••••\n.4 4 .. •\n• •\n•\n...\nAft • •\n4. •\n••••\n•••\n•.-.\n.. a.\n•\n•• se\n-4•14•••\n•••\n•••Its.....44 • 414i.\n4.\n•••••\n•••\n•\n••\n0.•\nre.i\niv votes\n. •11 111.0\n• se\n. •\n• • • sr••••4I\nY.\n• .040i •\n•1.\nStill.\n1.•\n•••••14.01\n1..\n• •\n•\n. .• •\n•\n• .. ...• • •\n•• • •\ns\nsot IN an Ill,\n.1.1!4••• /4.0\n'rti\nlark\n▪\n04•11 • • • . •••• Vilna\n•\n\n••\n\neta\n.11 fl\n\n•\n\nloin., se.\nbi\n•••••\n•. 46••••es\n',IOW. ,\nI I' 40. 1\n•\n•••••••••••• *at\ned. 4•64\n•••• 4.• bd\nIA W.\n4044\n•\n• I.\n•\nt\n••\n•\n•• •• ••••\n.\n• 4- 44...4 mar /\n•\n•\nIs.\n•\n•\n•\n.•\n•••• •• 1. st.\n• •\n•••\n• I •\n•• • •\n.•• ••• ••\nI\n\n4.\n\nReiter focus of fire in\n\ns\n\nCV:tr.:V.'\neet.\n\nVal.\n\n•\nIn.,\n\n1004 a 1 I\n\nIle\nears. • .a\nI bo\nas\n•V\nI•••\nt I\n11 fl ir\n•\n44 .\nIP • 4\n••\n\n•\n\na\n•\n44•••\n\n'\n.;\n••••1.\n1\n...• • i••• •\n\nin case\n\nClipped By:\nreiter_m\nSat, Apr 22,2017\n\nCopyright Oli 2019 Newspapert•••\nA\n\n4\n\nrAna Awned.\n\n13\n\nEFTA02734092\n\n\f", "char_count": 1882}, {"efta_number": "EFTA02734027", "page_number": 66, "text_content": "The Palm Beach Post\nREAL NEWS STARTS ME\n\nDelays in Epstein case unusual,\nlawyers say\nPosted Mar 13, 2007 at 12:01 AM\nUpdated Oct 3, 2019 at 3:48 PM\n(EDITORS NOTE: This story originally published in The Palm\n\nAic\n\nBeach Post March 13, 2007)\nA federal probe or a plea deal could explain the wait ineS\nPalm Beacher's solicitation case.\nNearly eight months after Palm Beach tycoon Jeffrey\nEpstein was charged with felony solicitation of prostitution,\nthere has been no discernible progress in his case. No\nwitnesses deposed. No trial date set. Nothing, save for\nroutine court hearings reset itliV explanation.\n\"Usually that would bet\n\nsual, said criminal defense\n\nattorney Glenn Mitchell, ho has no involvement in the\ncase.\n'As a general rule, it would be unusual for nothing to have\nhappened; agreed Michael Dutko, a criminal defense\nattorney in Fort Lauderdale. He representsMa,\n20, of\n\nPalm Beach, potentially a key witness in the\n\ncase.\nA routine hearing for Epstein was pulled from the court\ndocket last week and reset for May 16. The delays and\ninaction could be due to a potential federal probe of Epstein\nor because a plea deal is in the works, attorneys say.\nUnusual is the word that best describes everything about\nthe case against Epstein, 54, an enigmatic money manager\nin New York City who counts Bill Clinton and Donald\nTrump among his friends.\n\nEFTA02734093\n\n\f", "char_count": 1371}, {"efta_number": "EFTA02734027", "page_number": 67, "text_content": "\"Highly unusual\" is how Palm Beach Police Chief Michael\nReiter described State Attorney Barry Krischer's handling\nof the case in a bluntly critical letter to Krischer last year\nbefore Epstein was indicted.\nReiter referred the matter to the FBI to determine whether\nany federal laws had been violated. Epstein's allies\ncountered by attacking the chief personally and\nprofessionally.\nReiter's department investigated Epstein for 11 months.\nPolice sifted repeatedly through his trash and conducted\nsurveillance on his five-bedroom, 7 1/2-bath, 7,234-sq\nfoot home on the Intracoastal Waterway.\nPolice said Epstein paid women and girls as young as 14 to\ngive him erotic massages at his home. Police thought there\nwas probable cause to charge him with unlawful sex acts\nwith a minor and lewd and lascivious molestation.\nEpstein responded by hiring a phalanx of lawyers. One of\nthem, Harvard law professor and author Alan Dershowitz,\nprovided the state attorney's office with information about\nalcohol and marijuana use by some of the girls who said\nthey were with Epstein.\nProsecutors then referred the case to the grand jury rather\ncharges directly against Epstein.\nAt.....\n\\\n\nO\n\npstein's attorneys deny he had sex with underage girls.\nThe lawyers say the girls' stories are not credible. But if the\ncourt file is any indicator, they've made no effort to depose\nthe girls.\n\nNeither prosecutors nor defense attorneys have sought to\n, said Dutko, her attorney. She recruited\nquestion\nteenage girls to visit Epstein for massages and sexual\nactivity, Palm Beach police said, and presumably would be a\nkey witness.\n\nEFTA02734094\n\n\f", "char_count": 1621}, {"efta_number": "EFTA02734027", "page_number": 68, "text_content": "Epstein's attorney Jack Goldberger did not return phone\nmessages.\nA source close to the case suggested it is languishing\npending a decision by the FBI on whether to refer it to\nfederal prosecutors.\n\"We still have a pending case,\" FBI spokeswoman Judy\nOrihuela said Monday.\nState Attorney Krischer did not return a call for comment.\nHis spokesman, Mike Edmondson, declined to say whethe\nfederal investigators are delaying the Epstein case. But,O\nadded, \"if another agency is looking at something,\nwouldn't want to step on their toes.\"\nAttorneys say inertia in a criminal case often points to a\npending plea deal.\n/ 4414/.\n\"It would not surprise me if something has happened that's\nnot reflected in the court file,\" said Dutko, such as an\nagreement that will be formalized later.\nDefense attorney Marc Shiner said defense attorneys\nsometimes put off overtly conducting discovery -- deposing\nwitnesses, requesting documents and the like -- because\ndoing so creates more work for harried prosecutors who\nmay become angry and not offer a plea deal.\n\"Sometimes defense lawyers, knowing that, will try and do\ndiscovery without taking depositions,\" said Shiner, a former\nprosecutor for 13 years.\nInstead, they may conduct a below-the-radar probe such as\nhaving a private investigator check out leads, he said.\nShiner and others say a plea deal for Epstein probably\nwould result in pretrial intervention, in which a defendant\nmay be ordered to undergo a psychological evaluation,\ncounseling or other conditions in return for dropping the\ncharge.\nEFTA02734095\n\n\f", "char_count": 1552}, {"efta_number": "EFTA02734027", "page_number": 69, "text_content": "Edmondson, spokesman for State Attorney Krischer, said\nthere is no plea offer and no request for the prosecution to\nshow its cards.\n\"To my knowledge, it's never happened before on a filed\ncase,\" he said.\n\nEFTA02734096\n\n\f", "char_count": 220}, {"efta_number": "EFTA02734027", "page_number": 70, "text_content": "252 / 278 - Thursday, October 18, 2007\nEdition: FINAL\nSection: LOCAL.\nPage: 5B\nSource: The Associated Press\nIllustration: PHOTO (B&W)\nMemo: Ran all editions.\nDateline: NEW YORK\nWOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16\nA billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage\nprostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had\nsought his help becoming a model.\nThe lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had\nthe teen perform a sex act when she brought photographs of herself for hint to review in his Upper\nEast Side mansion sometime in 2000.\nEpstein, 54, a money manager, told the teen he managed fmances for Victoria's Secret and \"could get\nyou into the catalog\" if she were \"nice\" to him, court papers\ne papers say being \"nice\"\nincluded maccages and other favors.\nWhen the girl told Epstein, \"I am 16 years old and just want model,\" he replied, \"Don't worry, I\nwon't tell anybody,\" court papers say.\nEpstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been\nindicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending.\nThe girl visited Epstein \"several times over the several months and engaged in bizarre and unnatural\nsex acts\" while she was a minor, the lawsuit says.\nEpstein \"repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends.\nstating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her\n40s). I love girls your age.'\"\nThe young woman, now 23, kept returning to Epstein because she has \"mental issues,\" said her\nlawyer, William I. Unroch. He refused to elaborate, but court papers say she was \"disabled as a result\nof severe mental disease and defect.\"\nEpstein's lawyer in New York, Gerald Lefcourt, said, \"The girl has admitted she is insane, but she can\nread a newspaper\n... [truncated, 2694 chars — for the full page use /api/corpus/document/EFTA02734027/70 or ?id=EFTA02734027&page=70]", "char_count": 2694}, {"efta_number": "EFTA02734027", "page_number": 71, "text_content": "The Palm\nBeach\nPost\nREAL, STARTSIRE\nPalm Beacher pleads in sex case\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 3, 2019 at 1:47 PM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on July 1, 2W8)\nJeffrey Epstein will serve 1 1/2 years on teen solicitation\ncharges.\nHe lives in a Palm Beach waterfront mansion and has kept\ncompany with the likes of President Clinton, Prince\nAndrew and Donald Trump, but investment banker Jeffrey\nEpstein will call the Palm Beach Count}J i-h me for the\nnext 18 months.\n<c\\\nEpstein, 55, pleaded guilty WS)\n, t felony solicitation of\nprostitution and procuring a person under the age of 18 for\nprostitution. After serving 18 months in jail, he will be\nunder house arrest for a year. And he will have a lifelong\nobligation to register as a sex offender. He must submit to\nan HIV test within 48 hours, with the results being\nprovided to his victims or their parents.\nAs part of the plea deal, federal investigators agreed to drop\ntheir investigation of Epstein, which they had taken to a\ngrand jury, two law enforcement sources said.\nEpstein was indicted two years ago after an 11-month\ninvestigation by Palm Beach police. They received a\ncomplaint from a relative of a 14-year-old girl who had\ngiven Epstein a naked massage at his five-bedroom, 7,234square-foot, $8.5 million Intracoastal home.\nPolice concluded that there were several other girls brought\nin 2004 and 2005 to an upstairs room at the home for\nsimilar massages and sexual touching.\nEFTA02734098\n\n\f", "char_count": 1512}, {"efta_number": "EFTA02734027", "page_number": 72, "text_content": "The indictment charged Epstein only with felony\nsolicitation of prostitution. The state attorney's office later\nadded the charge of procuring underage girls for that\npurpose.\nProsecutor Lanna Belohlavek said of the plea: \"I took into\nconsideration the length the trial would have been and\nwitnesses having to testify' about sometimes embarrassing\nincidents.\nEpstein may have made a serious mistake soon after he was\ncharged. He rejected an offer to plead guilty to one count of\naggravated assault with intent to commit a felony,\naccording to police documents. He would have gotten Ma.)\nyears' probation, had no criminal record and not hew)\nregistered sex offender, the documents indete.\nEpstein arrived in court Monday with kasethree\nattorneys. He wore a blue blazer, blue shirt, blue jeans and\nand gray sneakers. After Circuit Judge Deborah Dale\nPucillo accepted the plea, he was fingerprinted. Epstein\nthen removed his blazer and was handcuffed for the trip to\njail while his attorneys tried to shield him from\nphotographers' lenses.\nWhen he eventually is released to house arrest, Epstein will\nhave to observe a 10 p.m. to 6 a.m. curfew, have no\nunsupervised contact with anyone younger than 18 and\nneither own nor possess pornographic or sexual materials\n'that are relevant to your deviant behavior: the judge said.\nEpstein will be allowed to leave home for work. The New\nYork-based money manager told the judge he has formed\nthe not-for-profit Florida Science Foundation to finance\nscientific research. \"I'm there every day: Epstein said.\nThe foundation was incorporated in November. Epstein\nsaid he already has awarded money to Harvard and MIT.\n\nEFTA02734099\n\n\f", "char_count": 1667}, {"efta_number": "EFTA02734027", "page_number": 73, "text_content": "When he is released from jail, there is a chance that Epstein\nwill be forced to move. Sex offenders are not allowed to live\nwithin 1,000 feet of a school, park or other areas where\nchildren may gather. No determination has been made as to\nwhether Epstein's home complies, but attorneys said it\nlikely does.\nSex offenders also typically must attend counseling sessions.\nBelohlavek said that was waived for Epstein because his\nprivate psychiatrist is working with him. The judge was\nskeptical but agreed to it.\n\nakAlk\n\nEpstein's legal woes don't end with Monday's plea. The\narc four pending federal civil lawsuits and one in s\nrelated to his behavior. At least one woman has su\nNew York, where he owns a 51,000-square,\nmansion.\n\nanhattan\n\nIt's validation of what we're sap /Sircivil cases,\" said\nMiami attorney Jeffrey Her\nrepresents the alleged\nvictims in the federal laws\nt Palm Beach attorney\nTed Leopold represen\neged victim in a civil suit in\npates amending that lawsuit to\nstate court. He sat\nadd \"a few othdr diem as well.\nIn the criIr•\n\nycase, police wcnt so far as to scour Epstein's\ntras\nd c duct surveillance at Palm Beach International\nA rp\nwhere they watched for his private jet so they\nId know when he was in town. They concluded that\n\n+\n\npstein paid girls $200 to $300 each after the massage\nsessions.\n\n\"I'm like a Heidi Fleiss,\"\n, now 22, told police\nabout her efforts in recruiting girls for Epstein.\nThere was probable cause to charge Epstein with unlawful\nsex acts with a minor and lewd and lascivious molestation,\npolice concluded.\n\nEFTA02734100\n\n\f", "char_count": 1566}, {"efta_number": "EFTA02734027", "page_number": 74, "text_content": "The state attorney's office said questions about the girls'\ncredibility led it to take the unprecedented step of\npresenting the evidence against Epstein to a grand jury,\nrather than directly charging him.\nPalm Beach Police Chief Michael Reiter was furious with\nState Attorney Barry Krischer, saying in a May 2006 letter\nthat the prosecutor should disqualify himself. \"I continue to\nfind your office's treatment of these cases highly unusual,\"\nhe wrote. He then asked for and got a federal investigation.\nEpstein hired a phalanx of high-priced lawyers - includingtaS ,\nHarvard law professor and author Alan Dershowitz - aid\npublic relations people who questioned Reiter's competenc\nand the victims' truthfulness.\nIn addition to mansions in Palm Beach and Manhattan,\nEpstein owns homes in New Mexico and the Virgin Islands.\nHe's a frequent contributor to Democratic Parry candidates.\nHe also donated $30 million\n\nNard in 2003.\n\nFormer New York Gov. Eliot Spitzer returned a $50,000\ncampaign contribution from Epstein after his indictment,\nthen resigned this year during his own sex scandal. And the\nsame Palm Beach Police Department that vigorously\ninvestigated Epstein returned his $90,000 donation for the\npurchase of a firearms simulator.\nStaff writer Eliot Kleinberg and former staff researcher\nMichelle Quigley contributed to this story.\n\nEFTA02734101\n\n\f", "char_count": 1357}, {"efta_number": "EFTA02734027", "page_number": 75, "text_content": "The Palm Beach\nPost\nswami\nREAL NEWS\n\nJeffrey Epstein: Scientist,\nstuntman, `sex slave' visit jailed\ntycoon\nBy LARR%\n/ Palm Beach Post Staff Writer\nPosted Aug 13, 2008 at 12:01 AM\nUpdated Jul 16, 2019 at 4:54 PM\nTycoon Jeffrey Epstein mingled with an eclectic mix of\npeople, induding beautiful young women, before he g\ninto trouble for paying teenage girls to give him s\nmassages at his Palm Beach mansion.\nNot much has changed, even though he now resides in a\ndorm at the Palm Beach County Sheriffs Office's 17-acre,\n967-bed stockade near the fairgrounds.\nDuring his first month of confinement, Epstein was visited\nby the female assistant who, girls told police, had escorted\nthem to the room at his mansion where they gave him\nnaked massages.\nAlso trekking to the jail was a young woman whom Epstein\npurportedly described as his Yugoslavian sex slave.\nThe wealthy financier and science wonk also has been\nvisited by an expert on artificial intelligence, as well as a\nman who is a mixed martial arts aficionado and sometime\nmovie stuntman.\nThe only other people to visit him at the jail, according to\nrecords, are a\n\nIsland man and an individual who\n\nlisted Epstein's Palm Beach address as his own.\nEpstein, 55, pleaded guilty on June 30 to two prostitutionrelated charges and was sentenced to 18 months in jail,\nfollowed by a year of house arrest. Epstein paid teenage\n\nEFTA02734102\n\n\f", "char_count": 1386}, {"efta_number": "EFTA02734027", "page_number": 76, "text_content": "girls $200 to $300 in 2004 and 2005 for massages in Ms\nhome that sometimes included sexual touching, Palm Beach\npolice said.\nHis jail visitors in July included:\n- MEI\n\n29, who some of the teen masseuses said\n\nphoned them when Epstein was in town and escorted them\nupon their arrival at his Palm Beach waterfront home to an\nupstairs room, where she prepared the massage table and\nprovided the oils for their encounters with him.\nvisited Epstein three times in July, according to a jail\nvisitor's log.\n\nlists a Manhattan home address.\n\nReached by telephone, she declined to discuss Epstein.\n23, whose family in Yugoslavia\nEpstein paid money to so that he could bring her to the\nUnited States to be his \"sex slave,\" two teenage girls told\npolice. One girl told police that Epstein instructed\nand her to kiss and have sex while he watched\nand masturbated. Another said she engaged in sex with\nat Epstein's urging.\n\nvisited Epstein\n\nin jail four times in 13 days. She lists her address as on the\nUpper East side of Manhattan, not far from Epstein's\nenormous apartment.\n- Roger Schank, 62, founder of the Institute for Learning\nSciences at Northwestern University and an expert on\nartificial intelligence, paid one visit to Epstein. Schank has\nwritten numerous books on that subject and has a doctorate\ndegree from Yale University in linguistics. He was one of 19\npeople who applied to be president of Florida Atlantic\nUniversity in 2003. He became \"chief learning officer° at the\nonline Trump University in 2005. Schank listed his address\nas being in Stuart, and records show he also owns a home\nin Lake Worth.\n\nEFTA02734103\n\n\f", "char_count": 1622}, {"efta_number": "EFTA02734027", "page_number": 77, "text_content": "Epstein has financed a number of scientists over the years,\nincluding Nobel Prize winners. He gave $30 million to\nHarvard University in 2003. In November, he formed the\nnot-for-profit Florida Science Foundation, which he said\nfinances scientific research.\n- Igor Zinoviev, a Russian mixed martial arts fighter, who\ncoaches a Chicago team in the International Fight League.\nHe also has worked as a personal trainer, celebrity\nbodyguard and movie stuntman, according to the league's\nWeb site. The New Jersey resident visited Epstein seven\ntimes in July.\nZinoviev, Schank and\n\ncould not be reached for\n\ncomment.\nStaff researcher Niels Heimeriks contributed to this story.\n\\ 4 9%1\n\nI\n\n.4\n\nEFTA02734104\n\n\f", "char_count": 700}, {"efta_number": "EFTA02734027", "page_number": 78, "text_content": "Palm Beach Daily News\nBillionaire sex offender leaves jail\nsix days a week for work\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 4, 2019 at 9:27 AM\nPalm Beath billionaire Jeffrey Epstein, who's serving 18\nmonths in jail for soliciting an underage girl for\nprostitution, is allowed to leave the Palm Beach County\nStockade six days a week on a work-release program.\nTed Barbera, spokeswoman for the Palm Beach County\nSheriffs Office, confirmed that Epstein, 55, has been in the\nwork-release program since Oct. 10.\n\"He works six days a week: Friday through Wednesday 10\na.m. to 10 p.m.,\" Barbera said via e-mail. \"(He) works at his\nlocal West Palm Beach office, monitored on an active GPS\nsystem (he wears an ankle bracelet). Mr. Epstein hires a\npermit deputy, at his expense, for his own security at his\nworkplace due g theinne he is out.\"\nMiami attorneyJeffrey Herman represents six young\nwomen who've sued Epstein, claiming he sexually abused\nthettis\n+\n\nHe\n\nPalm Beach home when they were minors.\n\nan said he received a letter about the work-release\n\nprogram from the U.S. Attorney's Office within the past\nfew days. But Herman says Epstein had been out on workrelease for several weeks before the notification.\n\n\"My clients expressed shock and disappointment,\" Herman\nsaid. \"I find it incredible that he's on work-release in the\ncommunity and my clients aren't notified of this and we get\nthis letter weeks after the fact.\"\nJack Goldberger, Epstein's criminal attorney, said the\nEFTA02734105\n\n\f", "char_count": 1493}, {"efta_number": "EFTA02734027", "page_number": 79, "text_content": "arrangement is not unusual.\n\"He goes to work every single day and goes back to jail at\nnight, just like everybody else (in the program),\"\nGoldberger said.\nEpstein pleaded guilty June 30 to two felony counts:\nsoliciting prostitution and procuring a person under 18 for\nprostitution. As part of the plea agreement, Epstein must\nserve one year of house arrest and register as a lifelong sex\noffender.\n\nEFTA02734106\n\n\f", "char_count": 414}, {"efta_number": "EFTA02734027", "page_number": 80, "text_content": "The Palm Beach Post\nREAL *WS STARTS HIE\n\nWomen want Epstein sex plea deal\nunsealed\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 2, 2019 at 2:23 PM\n\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post June 10, 2009)\nTheir attorneys will ask a judge to open Jeffrey Epstein' AS,\nrecords.\nC )\nWhen wealthy money manager Jeffrey Epstein of PAIS\nBeach pleaded guilty last year to procuring teens for\nprostitution, his case detoured around local,\nregarding the sealing of court docs erit,91\n,\n\nstate rules\n\nAt a plea conference on the traSharges, a judge, a defense\nlawyer and a prosecutor huddled at the bench and decided\nthat a deal Epstein had struck with federal prosecutors to\navoid charges s ould be sealed, according to a transcript of\nthe hearing.\nAnd so it\nBut\nl i torida rules of judicial administration, as well as rules\nAra (of the Palm Beach County court system, require public\nnotification that a court document has been or will be\nsealed, meaning kept from public view. The rules also\nrequire a judge to find a significant reason to seal, such as\nprotecting a trade secret or a compelling government\ninterest.\nYet no notification or reason occurred in Epstein's case,\naccording to court records.\n\nEFTA02734107\n\n\f", "char_count": 1238}, {"efta_number": "EFTA02734027", "page_number": 81, "text_content": "Epstein's own attorneys, in federal filings, have referred to\nhis confidential deferred prosecution agreement with the\nU.S. attorney's office, struck in September 2007, as\n\"unprecedented\" and \"highly unusual.\" And it was \"a\nsignificant inducement\" for Epstein to accept the state's\ndeal, observed the state judge who accepted his plea,\nCounty Judge Deborah Dale Pucillo.\nEpstein now faces at least a dozen civil lawsuits in federal\nand state courts filed by young women who said they had\nsex with him and now are seeking damages.\nAttorneys for some of those women want his agreement\nwith federal prosecutors unsealed and will ask Circuit Judge\nJeffrey Colbath to do so today.\n\"It is against public policy for these documents to be have\nbeen sealed and hidden from public scrutiny. As a member\nof the public, E.W. has a right to have these documents\nunsealed: wrote former Circuit Judge Bill Berger, now in\nprivate practice and representing one of the women.\n\nThe Palm Beach Post also will ask Colbath to unseal the\nagreement. Post attorney Deanna Shulbnan will argue that\nthe public has a right to know the specifics of Epstein's deal.\nAccording to various media accounts, Epstein moved in\ncircles that included President Clinton, Donald Trump and\nPrince Andrew. \"International Moneyman of Mystery,\"\ndeclared a 2002 New York magazine profile of Epstein.\nEpstein, 56, is in the Palm Beach County Stockade, serving\nan 18-month sentence after pleading guilty nearly a year\nago to felony solicitation of prostitution and procuring\nteenagers for prostitution.\nHe is allowed out from 7 a.m. to 11 p.m., escorted by a\ndeputy, said Palm Beach County Sheriffs Office\nspokeswoman Teri Barbera.\n\nEFTA02734108\n\n\f", "char_count": 1700}, {"efta_number": "EFTA02734027", "page_number": 82, "text_content": "During a Palm Beach Police Department investigation, five\nvictims and 17 witnesses gave statements. They told of\nyoung women brought by his assistants to Epstein's\nmansion on El Brillo Way for massages and sexual activity,\nand then being paid afterward.\nAt Epstein's plea conference last year, his attorney, Jack\nGoldberger, and then-Assistant State Attorney Lanna\nBelohlavek approached Pucillo in a sidebar conference.\nPucillo, who had left the bench nine years earlier, was\nfilling in temporarily as a senior judge.\nAccording to a transcript, Goldberger told Pucillo that\nEpstein had entered a confidential agreement with the U.S.\nattorney's office in which federal prosecutors brokered not\npursuing charges against him if he pleaded guilty in state\ncourt. Pucillo then said she wanted a sealed copy of the\nagreement filed in his case, and Goldberger concurred that\nhe wanted it sealed. Belohlavek later signed off on it.\nThe Florida Supreme Court has expressed \"serious concern\"\nand launched an all-out inquiry into sealing procedures\nacross the state following media reports in 2006 of entire\ncases being sealed and disappearing from court records.\n\"The public's constitutional right of access to court records\nmust remain inviolate, and this court is fully committed to\nsafeguarding this right,\" justices wrote in their final report.\nEpstein's office on Tuesday referred any questions to\nGoldberger, who declined to comment. Pucillo also has\ndeclined to comment.\n\nEFTA02734109\n\n\f", "char_count": 1484}, {"efta_number": "EFTA02734027", "page_number": 83, "text_content": "The Palm\nBeach Post\nREAL WM STARTS HERE\nEpstein secret pact with Feds\nreveals \"highly unusual\" terms\nPosted Jun 10.2009 at 12:01 AM\nUpdated Oct 4, 2019 at 9:23 AM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on September 19, 2009)\nA secret non-prosecution agreement multimillionaire\nfinancier Jeffrey Epstein struck with federal prosecutors is\nbeing called \"highly unusual\" by former federal prosecutors\nand downright outrageous by attorneys no}I(repggsenting\nyoung women who serviced him.\nThe deal reveals that the FBI and cheat<l)c ttorney's Office\ninvestigated him for several federal crimes, including\nengaging minors in commercial sex. The crimes are\npunishable by anywhere from 10 years to life in prison.\nBut federal prosecutors backed down and agreed to recall\ngrand jury subpoenas if Epstein pleaded guilty to\nprostitution-related felonies in state court, which he\nultimately did. He received an 18-month jail sentence, of\nwhich he served 13 months.\nThe U.S. Attorney's Office also agreed not to charge any of\nEpstein's possible co-conspirators:\nLesley Groff and\nThe deal was negotiated in part by heavyweight New York\ncriminal defense attorney Gerald Lefcourt.\nUnsealed on Friday after attorneys for some of Epstein's\nvictims and The Palm Beach Post sought its release, it offers\nthe first public look at the deal Epstein's high-powered legal\ncounsel brokered on his behalf.\n\nEFTA02734110\n\n\f", "char_count": 1427}, {"efta_number": "EFTA02734027", "page_number": 84, "text_content": "Marti\n\nof Stuart, a former federal prosecutor,\n\ndescribed the disparity in potential sentences as unusual,\nbut even more so a provision on attorney payment.\nThe first draft of the agreement in September 2007\nrequired that Epstein pay an attorney -- tapped by the U.S.\nAttorney's Office and approved by Epstein -- to represent\nsome of the victims. That attorney is prominent Miami\nlawyer Bob Josefsberg.\nBut an addendum to the agreement signed the following\nmonth struck Epstein's duty to pay Josefsberg if he and the\nvictims did not accept settlements -- capped at $150\nand instead pursued lawsuits.\n\nM\n\nt said it appears the government was trying to\n\nbalance the lesser sentence for Epstein with recovering\n$150,000 for each victim. \"I've never, ever seen anything\nlike that in my life,\" he said. \"It's highly unusual.'\nThe deal does not say whether any victims were contacted\nor consulted before the deal was made.\nAttorney Brad Edwards of Fort Lauderdale, who represents\nthree of the young women, believes that none of the 30 to\n40 woman identified as victims in the federal investigation\nwere told ahead of time._\n\nsaid his clients received\n\nletters from the U.S. Attorney's Office months after the deal\n°signed, assuring them Epstein would be prosecuted.\n\n+\n\n\"Never consulting the victims is probably the most\noutrageous aspect of it,\"\n\nsaid. \"It taught them that\n\nsomeone with money can buy his way out of anything. It's\noutrageous and embarrassing for United States Attorney's\nOffice and the State Attorney's Office.\"\nEpstein now faces many civil lawsuits filed by the women,\nwho are represented by a variety of attorneys. In many, the\nallegations are the same: that Epstein had a predilection for\nteenage girls, identified poor, vulnerable ones and used\nEFTA02734111\n\n\f", "char_count": 1777}, {"efta_number": "EFTA02734027", "page_number": 85, "text_content": "other young women to lure them to his Palm Beach\nmansion. They walked away with between $200 and\n$1,000.\nFormer Circuit Judge Bill Berger, also representing victims,\ncalled the agreement a \"sweetheart deal.\"\n\"Why was it so important for the government to make this\ndeal?\" Berger asked rhetorically. \"We have not yet had an\nhonest explanation by any public official as to why it was\nmade ... and why the victims were sold down the river.\"\nFormer federal prosecutor Ryon McCabe described the\nagreement as \"very unorthodox.\" Such agreements, he\nare usually reserved for corporations, not individt\n\"It's very, very rare. I've never seen or heardra\nprocedure that was set up here,\" said Mctibet who has no\ninvolvement in any Epstein litiga\n\"He's essentially avoiding f\nution because he\ncan afford to pay that many lawyers to help those victims\nreview their cases. ... If a person has no money, he couldn't\nbe able to strike a deal like this and avoid federal\nprosecution.\"\nThe backroom deal with federal prosecutors is all the more\ninteresting in light of the legal powerhouses who have\nworked for Epstein, including Harvard professor Alan\nDershowitz and Bill Clinton investigator Kenneth Starr.\nLefcourt is a past president of the National Association of\nCriminal Defense Lawyers.\nEpstein's local defense attorney, Jack Goldberger, issued a\nstatement Friday saying he had fought the release of the\nsealed agreement to protect the third parties named there.\n\"Mr. Epstein has fully abided by all of its terms and\nconditions. He is looking forward to putting this difficult\nperiod in his life behind him. He is continuing his longstanding history of science philanthropy.\"\n\nEFTA02734112\n\n\f", "char_count": 1682}, {"efta_number": "EFTA02734027", "page_number": 86, "text_content": "The investigation triggered tensions between police and\nprosecutors, with then-Palm Beach Chief Michael Reiter\nsaying in a May 2006 letter to then-State Attorney Barry\nKrischer that the chief prosecutor should disqualify himself.\n\"1 continue to find your office's treatment of these cases\nhighly unusual,\" Reiter wrote. He then asked for and got\nthe federal investigation that ended in the sealed deal.\n\"The Jeffrey Epstein matter was an experience of what a\nmany-million-dollar defense can accomplish,\" Reiter told\n\nAi\nAL\n\nthe Palm Beach Daily News upon his retirement.\nO'S\n\n,S P\n\nEFTA02734113\n\n\f", "char_count": 597}, {"efta_number": "EFTA02734027", "page_number": 87, "text_content": "187 / 278 - Wednesday, January 27, 2010\nEdition: FINAL\nSection: LOCAL & BUSINESS\nPage: 3B\nSource: By JANE MUSGRAVE Palm Beach Post Staff Writer\nDateline: WEST PALM BEACH\nJUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS\nIn a decision that could spark a constitutional showdown over privacy rights, a judge\nTuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to\nsubpoena abortion records from women who are seeking millions in damages from the parttime Palm Beach resident.\nPalm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut\nthe women's claims that they suffered psychological ills after being paid to give him\nsexually-charged massages at his Palm Beach mansion when they were as young as 14.\nHafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,\nhe said, can't be sought until the women are asked whether they have ever had an abortion,\nhow many and where. Further, he said, the records ould not be made public and might not\nbe admissible during trial.\nBut, he said, since the women claim Epstein, no 7, responsible for their emotional\ndistress, his attorneys can explore the impact of other events. Medical records. Hafele said,\nare a better source of information than a person's memory.\nAttorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm\nBeach clinic where abortions are performed, warned Hafele that he was stepping on shaky\nconstitutional grounds.\n\"These records are protected by our constitutional right of privacy,\" he said, referring to the\nFlorida Constitution.\nAfter the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the\nrecords.\nIn another ruling Wednesday, Hafele also said that videos from depositions in the state cases\ncan't be released without a court order. The ruling came after Epstein attorney Robert Critton\ncomplained that a video of Epstein being asked whether he had an \"egg-sha\n... [truncated, 2610 chars — for the full page use /api/corpus/document/EFTA02734027/87 or ?id=EFTA02734027&page=87]", "char_count": 2610}, {"efta_number": "EFTA02734027", "page_number": 88, "text_content": "The Palm Beach Post\nREAL NEWS STARTS HERE\n\nEpstein Journal's Findings Could\nResurrect Case\nBy Jane Musgrave\nPosted Sep 17, 2019 at 12:01 AM\nUpdated Oct 1, 2019 at 10:51 AM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on March 20, 2010)\nA purloined journal that is said to contain the names of\n\"hundreds\" of victims of convicted sex offender Jeffrey\nEpstein could be used to reopen the investigation into the\nmulti-millionaire's appetite for teenage girls, an attorney\nrepresenting seven of the victims said Friday.\nNew details about the contents of the journal were released\nthis week when Alfredo Rodriguez, who worked as a\nproperty manager for the Palm Beach resident, pleaded\nguilty to obstruction of justice for lying to federal agents\nwhen asked if he had any information about his former\nboss' criminal activity. He later tried to sell the journal he\nstole from Epstein for $50,000 to an unidentified person,\nwho alerted authorities, according to court records.\nAs part of the plea agreement, federal prosecutors said the\njournal \"contains information material to the Epstein\ninvestigation, including the names of material witnesses\nand additional victims.\"\n\"Had the items been produced in response to the inquiries\nof state or federal authorities ... the materials would have\nbeen presented to the federal grand jury,\" federal\nprosecutors wrote.\n\nEFTA02734115\n\n\f", "char_count": 1395}, {"efta_number": "EFTA02734027", "page_number": 89, "text_content": "Instead, prosecutors short-circuited the grand jury\ninvestigation and cut a deal with Epstein. They agreed not\nto pursue federal charges if he didn't contest prostitutionrelated felonies in state court. The money manager pleaded\nguilty in July 2008 to procuring a minor for prostitution\nand soliciting prostitution. He served 13 months of an 18month sentence.\nAttorney Adam Horowitz, who represents seven of the\nroughly 18 women who have filed civil suits against\nEpstein, said the new information could trump the socalled non-prosecution agreement.\nThe multifaceted agreement, he said, deals only with a\nspecific list of victims that the U.S. Attorney's Office knew\nabout when it penned the deal in 2007. If additional victims\nare listed in the journal Rodriguez stole, Horowitz said\nfederal prosecutors could reopen the investigation.\n\"It opens the door for further\n( r 1,6\nvion,'\nIn addition to turning twit the\n\nhe said.\n\nurnal to federal agents,\n\nRodriguez told them he knew his former boss was having\nsex with underage girls when he worked for him in 2004\nand 2005. He had seen naked girls, who looked like minors,\nin the pool of Epstein's $8.6 million mansion. He had seen\npornographic images of young girls on Epstein's computer,\na&ording to court records.\n0\nara\\Neither Epstein's criminal defense attorney, Jack\nGoldberger, nor attorney Robert Critton, who represents\nEpstein in the civil lawsuits, could be reached. Federal\nprosecutors have consistently declined comment.\nThe wording of the controversial agreement is unclear. It\nsays federal prosecutors would provide Epstein's attorneys\n\"with a list of individuals whom it has identified as victims.\"\nMiami attorney Robert Josefsberg was appointed to\n\nEFTA02734116\n\n\f", "char_count": 1729}, {"efta_number": "EFTA02734027", "page_number": 90, "text_content": "represent any of the victims on the list who wanted to\npursue Epstein in civil court. As part of the agreement,\nEpstein is to pay for Josefsberg to represent the women.\nSome of the women, most identified as Jane Doe in\nlawsuits, had already hired attorneys to represent them.\nSome have since settled their suits with Epstein, although\nterms were not disclosed.\nHorowitz said he has filed court papers to get the journal\nthat Rodriguez stole. \"It's another piece of evidence that\nshows our clients were at Epstein's mansion,\" he said.\nRodriguez told prosecutors he didn't turn over the journal\nwhen both FBI and Palm Beach police asked for it because\nhe wanted money for it. He also said he was afraid Epstein\nwould make him \"disappear.\" The information, he told\ninvestigators, was his \"insurance policy.\"\nHe faces a maximum 20 years in prison when he is\nsentenced on June 18.\njane_musgrave@pbpost.com\n@pbpcourts\n\nEFTA02734117\n\n\f", "char_count": 928}, {"efta_number": "EFTA02734027", "page_number": 91, "text_content": "The Palm\nBeach\nPost\nREAL NEWS SHIRTS HERE\nEpstein paid three women $5.5 million to end underagesex lawsuits\nBy Jane Musgrave\nPosted Oct 3, 2017 at 12:01 AM\nUpdated Oct 4, 2017 at 12:46 AM\nEnding years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young\nwomen who claimed he used them as sex toys, court documents filed last week show he shelled\nout $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.\nResponding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the\nsex scandal, attorneya\n\nsaid the politically-connected 64-year-old convicted sex\n\noffender paid more than $1 million to each of the si\nr; ma\n, gmenM\nIdentified in court papers only by their initi\n\nrepresented.\n\n‘\nr pseudonyms because of the nature of the\n\nallegations and their youthful ages, L.M. was paid $1 million, E.W. $2 million and Jane Doe\n$2.5 million,M\n\nsaid of the settlements he negotiated with Epstein to end the lawsuits.\n\nJack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on\nthe revelations, citing confidentiality agreements that were part of the settlements. For the\nsame reason, he declined to say whether Epstein paid similar amounts to settle roughly two\ndozen lawsuits filed by other young women against Epstein, claiming he paid them for sex\nwhen some were as young as 14 years old.\nAttorney Jack Scarola, who is representing\n\n, said his client was compelled to divulge\n\nthe confidential settlements to answer questions posed by Epstein's attorneys. \"Brilliant move\non their part,\" he said.\nEven if Epstein's attorneys hadn't opened the door, Scarola said the information would have\nlikely come out. He says the information will help him undermine Epstein's claims that\n\"ginned up\" the allegations to help his former law partner, imprisoned and disbarred\nFort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.\n\nEFTA02734118\n\n\f", "char_count": 1969}, {"efta_number": "EFTA02734027", "page_number": 92, "text_content": "The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute\nbetween Epstein and Rothstein, both billionaires.\nA year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a\nminor for prostitution, he sued Rothstein and 1_\n\nclaiming they trumped up the\n\nallegations of sexual molestation to perpetuate the Ponzi scheme.\nRothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly\nsuccessful law firm by forging the names of federal judges and others to persuade investors he\nhad negotiated settlements in lawsuits against high-profile people. Investors were told they\ncould get a cut of the cash.\nOne of the high-profile people Rothstein used to lure investors was Epstein, according to a\nlawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the\nlawsuit, Rothstein told investors Epstein, a money manager, had agato settle the lawsuits\nwith the teens for $200 million — a claim Critton described as \"a complete fabrication.\"\nAfter Epstein dropped the lawsuit in 2012, Edwards turned the tables on him.\n\naccused\n\nEpstein of filing the lawsuit maliciously to punish him for representing the young women.\nAlthough\n\nwas a partner in Rothstein's now defunct firm, Scarola claims Epstein had\n\nno evidence\n\nwas involved in the Ponzi scheme. Federal prosecutors successfully\n\ncharged other attorneys and members of the firm, but\n\nwas never implicated, Scarola\n\nsaid in the malicious prosecutiozkwsuit.\nThe revelations about the\ndocuments filed fore,Sean\ny\nS\n\nEpstein paid to three of the young woman came last week in\nTuesday in preparation for a December trial on the lawsuit.\n\nAttorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the\ntrial, in part, because she claimed she has been unable to talk to her client since his estate on his\nprivate island in the U.S. Virgin Islands was devastated last month by Hurricane Irma. \"I've had\nno abilit\n... [truncated, 2062 chars — for the full page use /api/corpus/document/EFTA02734027/92 or ?id=EFTA02734027&page=92]", "char_count": 2062}, {"efta_number": "EFTA02734027", "page_number": 93, "text_content": "Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge\nDonald Hafele rejected her request. While saying he didn't want to appear insensitive to those\nvictimized by the storm that hammered the Caribbean and roared through South Florida, he\nsaid Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.\nStill, Hafele gave Coleman extra time to respond to various motions that he will have to decide\nbefore the case goes to trial.\nDespite Scarola's insistence that\n\nhad nothing to do with Rothstein's Ponzi scheme,\nColeman said the evidence indicates otherwise. Why else would he try to depose Epstein's\nwell-known friends, such as now President Donald Trump, former President Bill Clinton and\nillusionist David Copperfield, she asked. He used the celebrities as a draw, she said.\n\"The Epstein cases were used to fleece money and defraud investors,' she said.\nEdward's malicious prosecution case has been difficult for both sides because both Epstein and\nhave refused to answer questions. As he did in the civil lawsuits, Epstein has invoked\nhis Fifth Amendment right against self-incrimination when questioned by Scarola.=\nhas claimed that much of the information Epstein is seeking is protected by attorney-client\n\na\n\nprivilege.\nThe malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit\nalso is suing the U.S. attorney's office, claiming it violated\nagainst Epstein.\nthe federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with\nEpstein.\nOnly after federal prosecutors agreed to drop their investigation of Epstein, did he agree to\nplead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court\nrecords, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's\nagreement to settle lawsuits filed against him by dozens of his underage victims.\n\nEFTA02734120\n\n\f", "char_count": 1946}, {"efta_number": "EFTA02734027", "page_number": 94, "text_content": "Palm Beach Daily News\nJudge rules feds' agreement with\nJeffrey Epstein pact violated teen\nvictims' rights\nBy Jane Musgrave\nPosted Sep 17, 2019 at 4:02 PM\nUpdated Oct 8, 2019 at 12:31 PM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on February 22, 2019)\n\n0\n\nActe\n\nFederal prosecutors violated the rights of Jeffrey EC einis\n34/\n\nteenage victims by failing to reveal they had dropped plans\nto prosecute the billionaire on dozens of federal charges in\nconnection with the girls' claims that he paid them for sex\nat his Palm Beach mansion, U.S. District Judge Kenneth\nMarra ruled on Thursday.\nIn a blistering 33-page ruling, Marra meticulously and\nmethodically detailed the numerous steps federal\nprosecutors took to hide the agreement from more than 40\nyoung women who claim Epstein paid them for sex when\nthey were iyoung as 14.\nthe government spent untold hours negotiating the\nterms and implications of the NPA with Epstein's attorneys,\nscant information was shared with the victims,\" Marra\nwrote. \"Instead, the victims were told to be 'patient' while\nthe investigation proceeded.\"\nBy then, it was too late. A deal had already been cut with\nthen-South Florida U.S. Attorney Alex Acosta and Epstein's\nattorneys to shelve a 52-page federal indictment against\nEpstein, a former math teacher turned money manager\nwho counts Presidents Donald Trump and Bill Clinton\namong his friends.\n\nEFTA02734121\n\n\f", "char_count": 1422}, {"efta_number": "EFTA02734027", "page_number": 95, "text_content": "Prosecutors' failure to alert the young women about the\ndeal violated the Crime Victims' Rights Act, Marra ruled.\n\"At a bare minimum the (act) required the government to\ninform (the young women) that it intended to enter into an\nagreement not to prosecute Epstein,\" he wrote.\nStill, Marra said he wasn't second-guessing prosecutors'\ndecision not to pursue Epstein on federal charges if he\npleaded guilty to minor state prostitution charges and\nagreed to compensate his victims for the trauma he caused.\n\"The court is not ruling that the decision not to prosecute\nwas improper,\" Marra wrote. \"The court is simply ruling\nthat, under the facts of this case, there was a violation under\nthe CVRA.\"\nFurther, he made no decision about what the remedy\nshould be. He gave prosecutors and attorneys representing\nthe young women 15 days to meet to decide how to unravel\nthe complex legal web that has been hanging over Epstein\nand his young victims for more than a decade.\nThe chances an accord will be reached are slim, said\nattorney Jack Scarola, who is representing the two Jane\nDoes who challenged the prosecutors' actions.\nFurther, he said, there is no road map to follow. The\nlawsuit attorney\nfiled on behalf of the two\nunidentified young women, claiming prosecutors violated\nthe federal act, is unique, he said.\n\"We are treading on virgin ground, to use what is probably\nan inappropriate phrase in this situation,\" he said.\nScarola said he and\n\nwill ask that the nonprosecution agreement be thrown out. That would open\nthe possibility that the long-shelved federal indictment\ncould be dusted off and filed against the 66-year-old\nEpstein, who spends most of his time on a private island he\nowns in the U.S. Virgin Islands.\n\nEFTA02734122\n\n\f", "char_count": 1736}, {"efta_number": "EFTA02734027", "page_number": 96, "text_content": "\"I don't see the government conceding to that remedy,\"\nScarola admitted. Further, he said, it is likely Epstein will be\nallowed to weigh in. Miami attorney Roy Black years ago\nfiled papers asking to intervene on Epstein's behalf.\nThe U.S. Attorney's Office said it wouldn't comment on\nMarra's ruling. Neither Black nor New York City attorney\nJay Lefkowitz, who led efforts to bury the federal\nindictment, responded to emails or phone calls for\ncomment. West Palm Beach attorney Jack Goldberger, who\nrepresents Epstein, also didn't respond.\nScarola said it is likely Epstein's star-studded legal team will\nargue that Epstein fully complied with the terms of the\nagreement he made in 2007 with federal prosecutors and\ntherefore the agreement can't be undone.\nAs he promised, Epstein pleaded guilty in June 2008 to state\ncharges of soliciting a minor for prostitution and soliciting\nprostitution. He served 13 months of an 18-month jail term\nin a vacant wing of the county stockade that he was allowed\nto leave 12 hours a day, six days week.\nFurther, as agreed, he paid settlements to the young women\nwho sued him. While the settlements were confidential,\ncourt records show he paid three women a total of $5.5\nmillion.\nIn return, federal prosecutors held up their end of the\nbargain. Their investigation ceased.\nHaving done all that prosecutors asked of him, Scarola said\nEpstein will make a simple argument: \"You can't turn\naround and deprive me of the benefits I bargained for.\"\nHowever, Scarola said, using Marra's ruling, he will counter\nthat the contract Epstein signed was illegal and therefore\nunenforceable.\n\nEFTA02734123\n\n\f", "char_count": 1630}, {"efta_number": "EFTA02734027", "page_number": 97, "text_content": "Even if Marra agrees to toss out the non-prosecution\nagreement, Scarola conceded that doesn't mean Epstein will\nface federal charges.\n\"The contract can be set aside and the federal government\ncan attempt to enter into the same agreement,\" he said.\n\"Except the spotlight of public attention will be on them\nand the 40 victims will be able to explain to the court why\nthis sweetheart deal should not be approved.\"\nScarola said that prosecutors may have had good reason not\nto pursue Epstein. \"There may be a reasonable explanationAS\nbut we don't know what that reason may have been,\" h\nsaid.\nIn court papers, federal prosecutors have said that manyof\nthe young women were afraid to cross the powerful,\npolitically connected money manager and simply refused to\ntestify against him.\nIn other cases, they said, the women changed their stories.\nJane Doe 2, who is trying to have the non-prosecution\nagreement thrown out, initially described Epstein as \"an\nawesome man\" and told prosecutors she hoped \"nothing\nhappens\" to him. While she later agreed to testify against\nEpstein, prosecutors said they feared Epstein's attorneys\nwould use her words to destroy her if she ever took the\nwitness stand.\nMarra, however, said the young woman's comments didn't\nmean she wasn't entitled to know about the prosecutors'\nplans to drop the charges. \"There is no dispute that Epstein\nsexually abused Jane Doe 2 while she was a minor,\" he\nwrote. \"Therefore, regardless of her comments to the\nprosecutor, she was a victim.\"\nBefore the case is finally resolved, Scarola predicted that \"a\nlot of people are going to have to answer a lot of questions.\"\n\nEFTA02734124\n\n\f", "char_count": 1643}, {"efta_number": "EFTA02734027", "page_number": 98, "text_content": "In his ruling, Marra detailed what appeared to be a cozy\nrelationship between Acosta, his line prosecutors and\nEpstein's team of lawyers. His phalanx of lawyers included\nnoted Harvard law professor Alan Dershowitz and Kenneth\nStarr, the former U.S. solicitor general whose investigation\nled to the impeachment of President Clinton.\nMarra describes an October 2007 breakfast meeting\nbetween Acosta, who is now U.S. labor secretary, and\nLefkowitz shortly after the non-prosecution agreement was\ninked.\nAfter the meeting, Lefkowitz sent Acosta a note thanking\nhim for \"the commitment you made to me during our\nOctober 12 meeting in which you assured me that your\nOffice would not ... contact any of the identified\nindividuals, potential witnesses, or potential civil claimants\nand their respective counsel in this matter.\"\nMarra quoted an equally pleasant note then-Palm Beach\nCounty State Attorney Barry Krischer sent to Assistant U.S.\nAttorney IIIIVillafana, who was the lead prosecutor in\nEpstein's case. \"Glad we could get this worked out for\nreasons I won't put in writing,\" Krischer wrote, shortly\nafter the non-prosecution agreement was signed. \"After this\nis resolved I would love to buy you a cup at Starbucks and\nhave a conversation.\"\nMany of the notes that were exchanged dealt with\nprosecutors' and Epstein's lawyers' shared desire to keep the\ndeal secret from Epstein's accusers. In a September email,\nVillafana asked Lefkowitz for guidance about what she\nshould reveal. \"And can we have a conference call to discuss\nwhat 1 may disclose to ... the girls regarding the\nAgreement,\" she asked.\n\nEFTA02734125\n\n\f", "char_count": 1617}, {"efta_number": "EFTA02734027", "page_number": 99, "text_content": "Such cooperation between prosecutors and defense\nattorneys is unusual, Marra said. \"It was a deviation from\nthe government's standard practice to negotiate with\ndefense counsel about the extent of crime victim\nnotifications,\" he wrote.\nFurther, he noted, that when\n\nand his two young\n\nclients asked for information, they were repeatedly misled.\n\"The CRVA was designed to protect victims' right and\nensure their involvement in the criminal justice process:\nMarra wrote. \"When the government gives information to\nvictims it cannot be misleading.\"\nUltimately, the terms of the non-prosecution agreement\nwere revealed only after\n\nand attorneys fot\n\npress successfully sued to make them publi\njmusgrave@pbpost.com\n\nEFTA02734126\n\n\f", "char_count": 725}, {"efta_number": "EFTA02734027", "page_number": 100, "text_content": "76 / 278 - Tuesday, July 9, 2019\nEdition: Final\nSection: A Section\nPage: 1A\nSource: By Jane Musgrave, The Palm Beach Post\n\nEpstein indicted on sex charges\nPart-time Palm Beacher pleads not guilty to sex\ntrafficking, conspiracy charges in federal court n\nManhattan\n0\nDressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on MoCy.headed not guilty\nto charges accusing him of creating a vast network of girls as young as 14 that he exploited\nfor his sexual pleasure at his homes in Palm Beach and Manhattan.\nThe 66-year-old money manager's appearance in U.S. District Court in New York City\ncapped more than a decade of recriminations by young women and their attorneys who\nclaimed Epstein used his money and political influence to avoid federal prosecution.\nEpstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking\ncharges as \"essentially a do-over\" of allegations that landed Epstein in the Palm Beach\nCounty Jail for 13 months more than a decade ago.\nHowever, unlike in 2007 when then-South It\nU.S. Attorney Alex Acosta agreed to\nshelve a 53-page federal indictment after E\nagreed to plead guilty to two state\nprostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is\nnow U.S. labor secretary.\n\"The alleged behavior shocks the conscience,\" New York City U.S. Attorney Geoffrey\nBerman said at a\nmorning news conference\ni while the charged conduct is from a number of years ago, it\nis still profoundly important to many of the alleged victims, now young women. They\ndeserve their day in court.\"\nAt a detention hearing scheduled for Monday, Berman said he will ask a federal judge to\nkeep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to\ncommit sex trafficking. Epstein paid dozens of young women to give him nude massages\nthat, for most, led to sex, he said.\nIf convicted of exploillozens of young women, including many Palm Beach County girls\nwho were students at\nPalm Beach High School\n... [truncated, 2330 chars — for the full page use /api/corpus/document/EFTA02734027/100 or ?id=EFTA02734027&page=100]", "char_count": 2330}, {"efta_number": "EFTA02734027", "page_number": 101, "text_content": "\"We think he's a significant flight risk,\" Berman said of the man who ferried Britain's Prince\nAndrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former\nPresident Bill Clinton on his jet, dubbed the Lolita Express.\nBerman's hard-line stance was welcomed by young women who for years have been told that\nEpstein couldn't be touched because Acosta signed off on the nonprosecution agreement,\npromising not to charge Epstein in federal court.\nFormer Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning\nher into his sex slave and forcing her to have sex with others, including Dershowitz and\nPrince Andrew, praised Berman. He showed the case is \"being taken in a serious way,\" she\ntold the Associated Press. Dershowitz has vehemently denied Guiffrc's claims.\nNew York prosecutors were able to ignore the controversial nonprosecution agreement\nbecause it contained some significant fine print, said former federal Judge Paul Cassell, who\nfor years has fought to get the agreement thrown out. It says only that no charges could be\nfiled against Epstein in South Florida, he said.\nBerman agreed. \"That agreement only binds, by its terms, only binds the Southern District of\nFlorida,\" he said. \"The Southern District of New York is not bound by that agreement and\nwasn't a signatory of it.\"\nThat means the sordid allegations that have been leveled at Epstein for years are now part of\na federal indictment.\nContrary to Epstein's claims, he knew the women who came to his homes in New York and\nPalm Beach were minors because they told him their ages, according to the indictment.\nEpstein preyed on young girls because he knew they were \"vulnerable to exploitation,\"\nprosecutors added.\nAs part of a carefully orchestrated sex ring, Epstein or his associates would call girls while\nhe was in New York so they would be available for sex once he returned to Palm Beach, the\nindictment says. The employees weren't named. They were identified only as \"Employee-1\n... [truncated, 3345 chars — for the full page use /api/corpus/document/EFTA02734027/101 or ?id=EFTA02734027&page=101]", "char_count": 3345}, {"efta_number": "EFTA02734027", "page_number": 102, "text_content": "•\n\nU.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime\nVictims' Rights Act by not telling Epstein's victims about the agreement before it was inked.\nCoincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight\nMonday, explaining what action Marra should take to redress that wrong.\nCassell insisted Epstein should face charges in federal court in West Palm Beach. \"Florida\nvictims deserve justice in Flori \" said Cassell, who is working on behalf of Epstein's\nvictims with attorneys\nd Jack Scarola.\nSince ifs likely Florida women wr get to testify against Epstein in New York, Scarola said\nhe's not focused on whether Epstein will face charges here. Instead, he said hewar* to know\nhow and why the agreement was reached.\n\"There's been no explanation as to how a deal like this could have been cut and how the\nfederal government could have been involved in a conspiracy to violate federal law,\" Scarola\nsaid of his interest in continuing the legal battle over the nonprosecutio agr ment.\nWhen Acosta agreed to drop the federal investigation, Epstein in 20\nde guilty to two\nprostitution charges and served 13 months of an 18-month sentenc n a v ant wing of the\nPalm Beach County Jail - a cell he was allowed to leave 12 ho a\nix days a week. He\nwas also forced to register as a sex offender and settle civil\nsu more than 30 young\nwomen filed against him.\nU.S. Rep. Lois Frankel, D-West Palm Beach, said she\nla's interest in finding out\nhow the agreement came to be.\"I am especially mo\nin why Epstein got the deal\nhe got,\" Frankel said. \"We need to know why he\nsuch an easy sentence.\nWhile she has asked the House Oversight Co\na\ninvestigate Acosta, Frankel said she\nis not sure that will happen. \"It just seems\nit\na travesty that this guy got off the\nway he did and, without pre-judging it,\nhay proper court case,\" Frankel said.\nwas inflamed in 2006 when then-State\nFormer Palm Beach Police Chief Mi\ntein with serious crimes. Reiter took th\n... [truncated, 3282 chars — for the full page use /api/corpus/document/EFTA02734027/102 or ?id=EFTA02734027&page=102]", "char_count": 3282}, {"efta_number": "EFTA02734027", "page_number": 103, "text_content": "\"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you,\"\nBerman said. A special number, 1-800-CALLFBI, will link victims of authorities.\nBill Sweeney, assistant director of the FBI's New York office, said after years of being\nignored by federal agents, the victims' voices will be heard.\n\"The Jeffrey Epstein matter is No. 1 on the major case list in the country,\" Sweeney said.\nTurning to address Epstein's victims directly, he said: \"Your bravery may empower others to\nspeak out against crimes against them.\"\njmusgrave@pbpost.com\n\ncos\n\nEFTA02734130\n\n\f", "char_count": 586}, {"efta_number": "EFTA02734027", "page_number": 104, "text_content": "Def.Ex.A-2\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734131\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 105, "text_content": "Mill. SCHOLZ 8c WYLER, LW.\n\nINC LAW OFFICES OF\n. P.A.\n\nARTHUR I.\n\nAl!LITT COMPANY Or PROFESSIONAL ASSOC.AVORS\nATTORNEYS AT LAW\nGATEWAY TO AMELIA\nSHIMS? GATEWAY BLVD.. SUITE SCUT\nFERNANDINA Basra. FLORIDA 00034\n\nRICHAND a SCHOLZ. PA.\nArcnanc. J. SCHOLZ\nA. WV'S& P.A.\nDOUGLAS A VMS\n\n00U04Als\n\nTELEPHONE (904) EGI-31193\nFAX NO (004) to.7679\nNovember 26, 2019\n\nOffice of the State Attorney\n15th Judicial Circuit\nAnn: Jeanne Howard\n401 North Dixie Highway\nWest Palm Beach, FL 33401\nRe:\n\nC\n\nO SA\n\nCA Florida Holdings, LLC v. Dave Arenberg et al.\nCase No.: 2019-CA-014681\n\nDear Mrs. Howard:\nThe purpose of this letter is to confirm that\nabove-referenced matter.\n\nSchott & Wyler, LLC will represent you regarding the\n\nOur fees will be contingent upon our success in this matter. You will not be liable or required to pay any\nmonies to our office unless we are sores-Wu( in ow representation of you regarding the above-referenced\nlitigation and receive a court order awarding attorneys' fees.\nAccordingly, should we be successful in this matter, you agree to be billed for the time incurred in defending\nthis action at our current hourly rates. At this time, our current hourly rates are: $475.00/hour for senior\npartners, $425.00/hour for other partners. $375.00/hour for associate attorneys, and $125.00/hour for\nparalegal time.\nFurthermore, the attorneys' fees paid to our firm shall be calculated by the above listed hourly rates\nmultiplied by the number of hours expended in defending this action or the total fee mandated and awarded\nby the court order herein, whichever is greater.\nBy signing below, you agree to the terms as set forth above. Please return a signed and dated copy of this\nletter to our office. If you have any questions or concerns, please contact our office. On behalf of the\nfirm, we are proud to represent you in this matter.\nSincerely,\niji h\nk t —\nDouglas A. Wyler, Esq.\nFor the Firm\n\nLA/1,,ta-D\nDate\n\nEFTA02734132\n\n\f", "char_count": 1936}, {"efta_number": "EFTA02734027", "page_number": 106, "text_content": "Def.Ex.A-3\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734133\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 107, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-CA-014681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida: SHARON IL\nBOCK, as Clerk and Comptroller of Palm\nBeach County. Florida.\nDefendants.\n\nMOTION TO DISMISS\nDefendant. DAVE ARONBERG, as State Attome\nthrough the undersigned counsel, hereby files this Mot'\n\nto\n\nf a\n\neach County, Florida, by and\n\nss Plaintiff's Complaint for failure to\n\nstate a cause of action, and in support thereof state\nMOITON\n\nD\n\nWhen confronted with a moti~dI\nphrased within its four comers s\n\ncleat\n\nProfessional Wrecker Opevizir\nlions 8\nwhether the plaintiff\nCivil Procedure\nsupport hi\nHaynes,\n\nstat\n\nSTANDARD\n\nss, the Court must determine whether the Complaint as\nates a cause of action, whereby relief can be granted. Fox v.\n\nSo. 2d 175, 178 (Fla. 5th DCA 2001). A motion to dismiss tests\n\na cause of action. The test for a motion to dismiss under Florida Rule of\n\nwhether the pleader could prove any set of facts as alleged in the Complaint to\ni i See, Connolly v. Sebeco, Inc. 89 So. 2d 482, 484 (Fla. 1956): Wasua Ins. Co. v.\n\nSo. 2d 1123 (Fla. 4th DCA 1996).\n\nIn order to meet this test, \"a complaint must allege sufficient ultimate facts to show that a pleader\nis entitled to relief.\" W.R. Townsend Contr., Inc. v. Jensen Civ. Constr., Inc., 728 So. 2d 297, 300 (Fla.\n1st DCA 1999) (quoting MaSosgais,\n\n464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. R. Civ. P.\n\n1.110(b)). The court need not accept internally inconsistent factual claims, conclusory allegations,\nunwarranted deductions, or mere legal conclusions made by a party. a (citing Response Oncology, Inc.\n\nEFTA02734134\n\n\f", "char_count": 1761}, {"efta_number": "EFTA02734027", "page_number": 108, "text_content": "v. Metrahealth Insurance Co., 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Asset Meant. v. laharis,\n297 F.3d 1182, 1188 (11th Cir. 2002) (\"[Ou a motion to dismiss,] the plaintiff's factual allegations are\naccepted as true.... However, legal conclusions masquerading as facts will not prevent dismissal.\"). To\navoid dismissal, a pleading \"must allege a cause of action recognized under law\" against the defending\nparty. Kislak v. Kreedian 95 So. 2d 510, 514 (Fla. 1957).\nCOUNT I\n(Florida Statutes Section 905.27)\nPlaintiff attempts to assert a cause of action, in the interest of \"furtheri\n\n', under Florida\n\nStatute § 905.27; however, a review of the statute in question reveals that\n\no action is provided\n\nfor therein and consequently Plaintiff's Complaint must be dismissed\n\na of law. Despite\n\nPlaintiff's extensive recitation of the factual background regardpg\n\nEpstein and the testimony and\n\nevidence presented to the 2006 grand jury is Palm Beach4o\n\n'da, Fla. Stat. § 905.27, merely\n\nexplains the exceptions to the disclosure of grand j\nof action upon which to initiate a valid law suit\nMoreover, a review of the stain\nprovided a basis for a cause of acti\n\nit\n\nt\n\n'\n\nn?v\nand does not set forth in any way a cause\n\nclearly indicates that even if § 905.27, Fla. Stat.\nis barred from access to the records it seeks. To wit, in\n\npertinent part, Fla. Stat. § 905.27(\nWhen such disclos\ndered by a court pursuant to subsection (1) for use in a civil\ncase, it may disci\nto all parties to the case and to their attorneys and by the latter\nto their I\nis and employees. However, the grandpa\", testimony afforded such\npersons\nth\nurt can only be used in the defense or prosecution of the civil or\ncrinti\nand for no other purpose whatsoever.\nhe the clear statutory guidelines for disclosure of grand jury materials in a civil case,\nPlaintiff is ifnproperly seeking the requested 2006 grand jury materials for the purposes of public\ndisclosure pursuant to the court's inherent authority and supervisory po\n... [truncated, 2365 chars — for the full page use /api/corpus/document/EFTA02734027/108 or ?id=EFTA02734027&page=108]", "char_count": 2365}, {"efta_number": "EFTA02734027", "page_number": 109, "text_content": "Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla. Stat. & 905.27(2).\nFinally, it is significant to note that despite Plaintiffs allegations to the contrary, Defendant Aronberg is\nnot in custody or control of the records sought and is therefore not a proper party to this action.\nWHEREFORE, based on the foregoing argunient and suliportiag authority, Defendant, DAVE\nARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this Honorable\nCourt grant the instant Motion and dismiss Plaintiff's Complaint with prejudice, andrm Defendant\n\nigt\n\nAronberg all other and further relief deemed just and proper, including attorney'\ndefending this frivolous action.\n\nand costs for\n\nCERTIFICATE OF SERVICE\nI HEREBY CERTIFY that on this 6th day of December. 2\nelectronically filed with the Florida E-File Portal for e-seivice\n\n, copy of the foregoing has been\nit's of record herein.\nCHOLZ & WYLER, LLC\n\nuglas A. Wyler\n\n(se\nc)\n\nArthur I. =,\nEsq.\nFla. Bar No.: 10249\nRichard J. Scholz, Esq.\nFla. Bar No.: 0021261\nDouglas A. Wyler, Esq.\nFla. Bar No.: 119979\n961687 Gateway Blvd., Suite 201-I\nFernandina Beach, Florida 32034\n(904) 261-3693\n(904) 261-7879 Fax\nPrimary: jacobsscholzlaw®comcast.net\nGeneral Counselfor the Florida Prosecuting\nAttorney's Association\n\nEFTA02734136\n\n\f", "char_count": 1325}, {"efta_number": "EFTA02734027", "page_number": 110, "text_content": "Def.Ex.A-4\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734137\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 111, "text_content": "Filing ft 101840557 E-Filed 01/17/2020 12:23:06 PM\n\nIN THE CIRCUIT COURT OF THE\nFIFTEENTH JUDICIAL CIRCUIT IN AND\nFOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LW,\nPublisher of THE PALM BEACH POST,\n\nCASE NO.: 50-2019-CA-014681-XXXX-MB\nDiv.: AG\n\nPlaintiff,\n\nA\n\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida,\n\nCos\n\nDefendants.\n\nCA Florida Holdings, LW, publisher oSt6\n\nBeach Post, for its First Amended\n\nComplaint against Dave Aronberg, the St\n\ntto\n\nofficial capacity (\"State Attorney\"),\n\nR. Bock, the Clerk of the Court for Palm Beach\n\nCounty, Florida, in her official C\n\nc)\n\ny for Palm Beach County, Florida, in his\n\nourt Clerk\"), alleges as follows:\nJURISDICTION\n\n1.\nFla. Stat. Secti\n\nThis is an\n\n? oIrwithin the exclusive jurisdiction of the Circuit Court pursuant to\n(2Xa) and 86.011 et seq.\nPARTIES\n\n2.\n\nThe Palm Beach Post is a daily community newspaper published by Plaintiff CA\n\nFlorida Holdings, LW, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.\n3.\n\nDefendant Dave Aronberg is the duly elected State Attorney for the Fifteenth\n\nJudicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and\nhas authority in grand jury proceedings pursuant to Fla. Stat. Section 27.03. He is sued herein in\n\nEFTA02734138\n\n\f", "char_count": 1373}, {"efta_number": "EFTA02734027", "page_number": 112, "text_content": "his official capacity as his office is in possession and/or control of documents that are the subject\nof this action.\n4.\n\nDefendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach\n\nCounty, Florida. She is sued herein in her official capacity as her office is in possession and/or\ncontrol of documents that are the subject of this action.\nINTRODUCTION\n5.\n\nIn what is now widely if belatedly recognized as a colossal\n\ne of justice —\n\nwhich led to the further needless victimization of countless young gijls and wofuen — a wealthy,\npolitically connected, and powerful financier was not held ac\n\ntable for, nor even forced to\n\nconfront, allegations of serious sex trafficking crimes. WhAv\n• 't i\n\nthat Jeffrey Epstein's 2008\n\ndeal with the State of Florida was not consistent ,c • \\Vence\np\n\ngathered against him, what\n\nremains shrouded in mystery is how that evid its a\npresented - to the grand jury that return4iin\n\nresented — and the extent to which it was\n\ntment far more limited in scope than expected\n\nand deserved.\n6.\n\nThrough this ac on,S i )Palm Beach Post seeks public access to the testimony,\n\nminutes, and other evide\nduring the first E\nexample, in\nability\n\nesented in 2006 to the Palm Beach County grand jury empaneled\n\nin sex 'use investigation. Typically, access to such materials is limited, for\nevent the flight of those whose indictment may be contemplated and their\n\nl or destroy evidence; to ensure jurors' candor in deliberations; and to protect an\n\naccused who is later exonerated. However, these factors are inapplicable here. Also, Florida law\nexpressly authorizes the disclosure of grand jury proceedings under certain circumstances,\nincluding, as here, in the furtherance of justice. Fla. Stat. § 905.27(1Xc).\n7.\n\nIt can no longer credibly be maintained that continued blanket secrecy over the\n\nproceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law.\n2\n\nEFTA02734139\n\n\f", "char_count": 1956}, {"efta_number": "EFTA02734027", "page_number": 113, "text_content": "To the contrary, transparency is required to promote public understanding of the criminal justice\nsystem and public confidence in the fair administration of justice. As detailed below, Epstein was\naccused of sexually abusing and trafficking dozens of women and girls in south Florida (among\nother locations) over a period of several years while exploiting his wealth and political connections\nto obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury\nproceedings will shed light on the extent to NNhich those in our government ent>\n\nwith the\n\nsolemn responsibility of enforcing our criminal laws equally as to all citiz\n\ned their duties\n\nin this instance. Justice will be furthered where it is either (1) demonstel\n\nstein was treated\n\nlike others accused of similar heinous crimes, or (2) as app\n\nore likely to be the case, those\n\nwho those to give Epstein favorable — \"unusual,\" in the1St , o ,the Town of Palm Beach Police\nChief — treatment, are exposed and held accountable\n\nw t hailed information is now in the\n\npublic domain, the State Attorney's referral o\n\n' \\ case to the grand jury — which would be\n\nout of the ordinary for this type of ca\n\ngi\n\nrise to a strong inference of favoritism and\n\ncorresponding disregard for the ri\n\n' or victims of Epstein's sex trafficking. Access to\n\nthe grand jury materials will all w th\nsecrecy that comes with used\nhis co-conspirato\nSection 905.\n+\n\nublic to determine whether the grand jury process, and the\nto further justice or, instead, operated to shield Epstein and\n\nm t e consequences of their criminal activities. Accordingly, Fla. Stat.\noozes the disclosure of Epstein's 2006 grand jury proceedings.\n\nven in the absence of such a statutory basis, this Court is empowered to order\n\npublic disclosure pursuant to its inherent authority and supervisory powers over the grand jury.\nIndeed, courts throughout the country in the past several decades have ordered the disclosure of\nhigh-profile grand jury proceed\n... [truncated, 2186 chars — for the full page use /api/corpus/document/EFTA02734027/113 or ?id=EFTA02734027&page=113]", "char_count": 2186}, {"efta_number": "EFTA02734027", "page_number": 114, "text_content": "as here, many of the details of Epstein's criminal misdeeds have already been made available in\nthe public domain through extensive news reporting by, among others, The Palm Beach Post; by\nthe many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.\nIn recognition of the sensitivity of the materials being sought, and in the interest of\n\n9.\n\nprotecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to\ncopies of the testimony, minutes, and other evidence presented in 2006 to the P\ngrand jury first being submitted to this Court for in camera review, where\n\nh County\nbe redacted,\n\nas appropriate, to protect those who deserve such protection.\nFACTUAL BACKGRO\n10.\n\nThe following facts were gathered, in fart\n\nPalm Beach Post through various Florida Public iR ltirs„\ni\n\ndocuments obtained by The\nrequests, documents unsealed or\n\n, and information and documents in the\n\npublicly available in other related judicial p\npublic record.\nA.\n\nFirst Epstein Sex Crimes Investigation, Indictment, and Plea Agreement:\n2005-2008.\n11.\n\nThe investigatioNititel Epstein's sex crimes began more than fourteen years ago,\n\nwhen a 14-year-old _irl's\nEpstein and o\nrequired t\n$300. E\n12.\n\nii1 other repotted to police in the Town of Pahn Beach, Florida, that\n\n• worked for him arranged for her to give Epstein a \"massage.\" Epstein\ntrip, exposed himself, and masturbated while touching her. The girl was paid\nwas 52 years old at the time.\nFollowing this initial report in 2005, the Town of Pahn Beach Police, and later, in\n\n2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and\nseventeen witnesses revealed that the events described by the 14-year-old girl occurred, with\ndisturbingly similar details, with each of the other victims.\n\n4\n\nEFTA02734141\n\n\f", "char_count": 1850}, {"efta_number": "EFTA02734027", "page_number": 115, "text_content": "13.\n\nBoth the victim/witness interviews, as well as evidence retrieved following a search\n\nof Epstein's home, showed that some of the girls involved were under the age of 18. The police\nsearch of Epstein's residence also found two hidden cameras and, throughout the house, large\nnumbers of nude photos of girls, including victims whom the police had not interviewed in the\ncourse of their investigation.\n14.\n\nIn March 2006, a State grand jury was scheduled at which all of\n\nims were\n\nexpected to testify. The proceeding was postponed, however, due to meetings\n\neen the State\n)\nAttorney's office and Epstein's prominent criminal defense lawyetittd personal friend, Alan\nDershowitz.\n15.\n\nAnother grand jury was convened in April\n\n,\n\nanceled the day before it was\n\nto begin receiving evidence.\n(1)\n16.\n\nPonce Chief Reit\n( s Iffs\niritr f\\\n\nOn May 1, 2006, Town\n\n\"personal and confidential\" letter\n\nPa\nn\n\nto the State Attorney.\n\nBeach Police Chief Michael Reiter wrote a\n\nlm Beach County State Attorney, Barry Krischer,\n\nstating:\nI must renew an\nobservation to you that I continue to find your office's\ntreatment of the E\n] cases highly unusual. It is regrettable that I am forced to\ncommuni\nin thi manner, but my most recent telephone calls to you and those\nof the\nd tective to your assigned attorneys have been unanswered and\nmess es\naim unreturned. After giving this much thought and consideration, I\nmust urge you to examine the unusual course that your office's handling of this\nAttuer has taken and consider ifgood and sufficient reason enists to requireyour\ndisqualification from the prosecution of these cases. (Emphasis supplied)\n17.\n\nChief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach\n\nPolice Department's probable cause affidavits charging Epstein and two of his assistants with\nmultiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested\n\n5\n\nEFTA02734142\n\n\f", "char_count": 1929}, {"efta_number": "EFTA02734027", "page_number": 116, "text_content": "that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges\nagainst him, which would be public.\n(2)\n18.\n\nThe July 2006 State Grand Jury Presentation.\n\nInstead, State Attorney Krischer elected to refer the case to a grand jury, which is\n\nmandatory for capital cases but rarely used for all other crimes. According to an official\nspokesperson, this was the first time that a sex crimes case was presented to a\n\nin Palm\n\nBeach County.\n19.\n\nIn July 2006, after State Attorney Krischer presented t\n\none victim, the grand jury returned an indictment on a sole coyliLof\n\nCI\n\nd evidence from\n\ndnation of prostitution.\n\nThere is no mention in the indictment of the victim being\n20.\n\nOn information and belief, a sewnd\n\nbefore the grand jury, but was unable to atten\n21.\n\ns victims was supposed to testify\nf a school exam.\n\nNo reasonable explanation has berprovided as to why the numerous other known\ntaw'\n\nvictims were not presented as witnesses and crime victims to the grand jury convened in July 2006.\nNor has any reasonable explanation been provided as to why State Attorney Krischer, who was\ninitially eager to invest'\n\nd prosecute Epstein for his crimes, over time lost the desire to do\n\nso.\n\n22.\nwho t\n\nnS nuation\ne\nand belief, during the grand jury appearance of the single victim\nhe State Attorney presented evidence that vilified the victim and attacked her\n\ncredibility, including soliciting testimony regarding underage drinking and questionable personal\nbehavior that was unrelated to the charges against Epstein. Further upon information and belief,\nthis information was initially brought to the attention of the State Attorney's office by Epstein's\ndefense counsel.\n\n6\n\nEFTA02734143\n\n\f", "char_count": 1735}, {"efta_number": "EFTA02734027", "page_number": 117, "text_content": "(3)\n23.\n\nThe FBI's Investigation and Epstein's Non-Prosecution\nAgreement With Federal Authorities.\n\nOn information and belief, following the deficient July 2006 indictment, and with\n\nChief Reiter's encouragement, the FBI began its own investigation of Epstein.\n24.\n\nRecords unsealed in 2015 revealed that the FBI compiled reports on \"34 confirmed\n\nminors\" that were victims of Epstein's sexual predations. Based on evidence gather\n\nthe FBI,\n\na 53-page indictment was prepared by the U.S. Attorney's Office in June 200S\n\nowever,\n,\nat the\n\nrequest of Epstein's lawyers, the indictment was never presented to a fed\n\njury.\n\n25.\n\nInstead, then U.S. Attorney for the Southern District o\n\nnegotiated a plea deal with Epstein's team of lawyers to\nfour named co-conspirators and any unnamed potentia\n\nAlexander Acosta,\nty to Epstein (along with\n\nators) from all federal criminal\n\ncharges.\n26.\n\nThroughout the remainder ojj7\n\nlawyers and the U.S. Attorney contin\nbelief, Epstein's lawyers insisC\nconfidential and under seal, an,\nissued for Epstein's\n27.\nprostituti\nsenten\n\nmp\n\nJu\n\nid,\nt\n\ndtrd through the first half of 2008, Epstein's\n\nting the plea arrangement. Upon information and\n) the victims not be notified, (2) the deal be kept\ngrand jury subpoenas (including one that had already been\n\nbe withdrawn.\n\n0, 2008, Epstein pled guilty to State charges; one count of solicitation of\n\ncount of solicitation of prostitution with a minor under the age of 18. He was\n18 months in jail, followed by a year of community control or house arrest, and was\n\nadjudicated as a convicted sex offender required to register twice a year in Florida.\n28.\n\nThe plea deal, called a non-prosecution agreement (\"NPA\"), allowed Epstein to\n\nreceive immunity from federal sex-trafficking charges that could have sent him to prison for life.\n\n7\n\nEFTA02734144\n\n\f", "char_count": 1829}, {"efta_number": "EFTA02734027", "page_number": 118, "text_content": "On information and belief, based on public records, former State Attorney Krischer communicated\nwith then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers.\n29.\n\nIndeed, Epstein was not incarcerated in a Florida prison for the State crimes for\n\nwhich he was convicted. Instead, he was placed in a private wing of the Palm Beach County\nStockade, where, after 3 12 months, he was allowed to leave the jail on \"work release\" for up to\n12 hours a day, 6 days a week. His private driver provided his transportation to\n30.\n\nEpstein was released five months early.\n\n31.\n\nUpon information and belief, Epstein violated the t\n\n\"work.\"\n\n0\n\nAS\"\nobation, but was\n\nnot prosecuted.\n(4)\n32.\n\nThe Crime Victims' Rith\n\nEpstein's victims only learned after\n\nan emergency petition to force federal prosecu\n\nKenneth A. Marra recently nil\nEpstein's victims before\n33.\ncontravenes\n\n!\n\n'ut his plea in State court and filed\n\nply with the Crime Victims' Rights Act\nin rights for crime victims, including the right\n\n(18 U.S.C. § 3771, \"CVRA\"), which m\nto be informed about plea agreem\n\n4\n\nright to appear at sentencing. U.S. District Judge\nderal prosecutors violated the CVRA by failing to notify\n\nhim to plead guilty to only the two State offenses.\n\necu on's failure to keep the victims apprised, among other things, also\n\nT\n•\n\nConstitution, Article 1, § 16(b) and Fla. Stat. § 960.001.\n\nollowing publicity exposing the extraordinary leniency of the plea deal, dozens of\ncivil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court.\n35.\n\nIn 2010, Epstein was registered as a \"level three\" (i.e., high risk of repeat offense)\n\nsex offender in New York, a lifelong designation. In 2011, the New York County District\nAttorney's office unsuccessfully sought to lower his registration to low-risk \"level one.\"\n\n8\n\nEFTA02734145\n\n\f", "char_count": 1860}, {"efta_number": "EFTA02734027", "page_number": 119, "text_content": "36.\n\nUpon information and belief, during the course of the Town of Palm Beach and FBI\n\ninvestigations, Epstein retained private investigators to follow, harass, and photograph his victims\nand their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated\nthe case against Epstein.\n37.\n\nUpon information and belief, Epstein's victims were threatened against cooperating\n\nwith law enforcement and told that they would be compensated only if they did no\nlaw enforcement.\n\n38.\n\nOn July 6, 2019, Epstein was arrested on federal\n\n39.\n\nUpon information and belied the United St\n\non the mishandling of the 2006 charges and th #4144c\n40.\n\nSouthern District of New York, E\ndozens of minor girls over a\n\ncase, inclu\n\nw\n\n19.\n\ng charges.\n\ninvestigations into and reporting\n\nthat followed.\n\nal district cowl by the U.S. Attorney for the\n\nescribed as \"a serial sexual predator who preyed on\n.\" The letter emphasized that \"the Government has real\n\nconcerns — grounded in p\nthe defendant\n\nef\n\nIn a July 8, 2019, letter\n\ni\n\nent's investigation of new\n\nallegations and charges stemmed, in part, from con\ni ' iS\nu ts „\n\ndescri\n\na\n\niS\n\nSecond Epstein Sex Crimes Investigation, Indictment,\n\nB.\n\nrate with\n\nrience with this defendant — that if allowed to remain out on bail,\nto pressure and intimidate witnesses and potential witnesses in this\n\nand their families, and otherwise attempt to obstruct justice.\" It also\nsults of the FBI's search of Epstein's Manhattan townhouse: evidence of sex\n\ntrafficking in the form of \"hundreds — and perhaps thousands — of sexually suggestive photographs\nof fully- or partially-nude females,\" including underage females. In a locked safe, compact discs\nwere found with handwritten labels including the descriptions: \"Young [Name] + [Name],\" \"Misc\nnudes 1,\" and \"Girl pies nude.\"\n\n9\n\nEFTA02734146\n\n\f", "char_count": 1843}, {"efta_number": "EFTA02734027", "page_number": 120, "text_content": "41.\n\nOn July 8, 2019, prosecutors with the Public Conuption Unit of the U.S. Attorney's\n\noffice for the Southern District of New York charged Epstein with sex trafficking and conspiracy\nto traffic minors for sex. The grand jury indictment alleges that \"dozens\" of underage girls were\nbrought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry\nover the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,\nAlexander Acosta, who by then was serving as U.S. Secretary of Labor\n\nTrump\n\nadministration, resigned from office.\n42.\n\nEpstein was denied bail and was placed into pre\n\nOn\n\nat the federal\n\nMetropolitan Correction Center in lower Manhattan.\n43.\n\nOn or about August 6, 2019, Florida Govit\n\nantis ordered a state criminal\n\nAt\n\nState Attorney Krischer for their\n\nprobe into the actions of the Palm Beach Sheriff\nhandling of the Epstein underage sex traffic\n44.\n\nThe August 27, 2019,\n45.\n\nfound dead in his cell at the Metropolitan\n\nOn August 10, 2019, E\n\nCorrectional Center. His cause of\nC.\n\nAtis„\n\nOn accoif\n\netemuned to be suicide.\nHearing: Epstein's Victims Speak.\n\nirhis death, prosecutors sought to dismiss the indictment against\n\nEpstein, while maintaining at they would continue to investigate his co-conspirators.\n46.\nAugu\n\nMates Senior District Judge Richard M. Berman ordered a hearing on\n9, on the prosecutors' decision to dismiss the indictment and allowed victims to\n\nspeak at the hearing.\n47.\n\nIn the course of the hearing, more than two dozen victims delivered their personal\n\nstories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of\nviolent rape by Epstein. Many more victims were present in the courtroom but did not testify.\n\n10\n\nEFTA02734147\n\n\f", "char_count": 1778}, {"efta_number": "EFTA02734027", "page_number": 121, "text_content": "48.\n\nWhile some questioned the reasoning behind the court's decision to give the victims\n\nvoice after Epstein's death, District Judge Berman noted that \"a public hearing is [the] preferred\nvehicle of resolution,\" emphasizing that \"public hearings are exactly what judges do. Hearings\npromote transparency and they provide the court with insights and information which the court\nmay not otherwise be aware of.\" Indeed, even Epstein's defense lawyer noted at the hearing that\nthe court \"is the institution that most people have confidence in, in these very tro\n49.\n\nAt the August 27th hearing, the girls, now women, spoke a\n\nand coercion,\" and to the fact that many of them \"were in very vulnera\n\n<5\n\n. 51\n\n\"exploitation\nns and in extreme\n\npoverty, circumstances where [they] didn't have anyone on\n\nir\n\nbehalf...\" One victim lamented that \"as a victim, [she]\n\ng\n\nsee what the agreement was\n\nor why the special treatment got approved\" in thei\n\nyears earlier. Another noted how\n\n\"completely different\" the investigators lead'\nprosecutors in the Florida case, both .\n\nits\n' c.,\n\ne, to speak on [their]\n\n2019 federal indictment were from the\n\neir\n\ntment of her and their investigation of her\n\nvictimization by Epstein.\n50.\n\nA former fede\n\n\"transparency is one of t\n51.\nEpstein has\nwrong\n\nNe\n\nattendance at the August 27th hearing emphasized that\nding objectives in our criminal justice system.\"\n\nall o the victims expressed the conviction that the secrecy that shielded\nthem \"irreparable harm\" and that an opportunity to address his criminal\n\nd those of the individuals who enabled his sexual racketeering, would allow for\n\nat least some measure of justice to be served after his death. Indeed, one victim stated: \"Any efforts\nmade to protect Epstein's name and legacy send a message to the victims that he wins and that he\nis untouchable.\" Another victim expressed fear that this is a world `where there are predators in\npower, a world where people can avoid justice if their pockets run deep enough.\" In \n... [truncated, 2031 chars — for the full page use /api/corpus/document/EFTA02734027/121 or ?id=EFTA02734027&page=121]", "char_count": 2031}, {"efta_number": "EFTA02734027", "page_number": 122, "text_content": "\"unusual\" treatment Epstein received in Florida in 2006 based on his wealth, social status, and\nconnections severely eroded the public's faith in the integrity and impartiality of the criminal\njustice system.\nD.\n\nThe Palm Beach Post's Standing and the Public Interest.\n(1)\n52.\n\nThe Palm Beach Post Has Reported Extensively On Epstein's\nCrimes For Nearly 15 Years.\n\nPlaintiff, The Palm Beach Post, is a community newspaper serv-lc\n\nade in Palm\n\nBeach County and the Treasure Coast vicinity.\n53.\n\nThe Palm Beach Post has been a Pulitzer Prize winneiand nominated as a finalist\n\nthree other times.\n54.\n\nBeginning in 2004, The Palm Beach Pos\n\non the allegations against, the law enforcement\nEpstein and his co-conspirators. The Ne\n\nt\n\n.ga\n\nwely investigated and reported\n\nn of and the crimes committed by,\n\nortage has included publication of the\n\nfollowing articles:\n• \"The Man Who Ha\ng: Jeffrey Epstein Craved Big Homes, Elite Friends\nge Girls.,\" published on August 14, 2006, reporting that:\nand Investigators S\na1\nunity college student, admitted in a sworn statement to\npolice that \"s\ntaken at least six girls to visit Epstein, all between the ages of 14\nand 16;\" Palm\nh Police \"interviewed five alleged victims and 17 witnesses;\"\n\"DershoCitz,\naward law professor, traveled to West Palm Beach with information\nabout the • s,\" including social media discussions about \"their use of alcohol and\nqualm; after meeting with Epstein's legal team, \"prosecutors postponed their\nto take the case to a grand jury;\" Palm Beach Police subsequently \"received\naints that two of the victims or their families had been harassed or threatened;\"\nations between police and prosecutors were fraying\" as the investigation continued;\nnd \"one girl who was subpoenaed — the one who said she had sexual intercourse with\nEpstein — never showed up\" to testify before the grand jury.\n• \"Trump Snags Gosman Estate for $41 Million\" published on November 16, 2004,\nreporting on the bidding war between Donald Trump and Jeffrey Epste\n... [truncated, 2159 chars — for the full page use /api/corpus/document/EFTA02734027/122 or ?id=EFTA02734027&page=122]", "char_count": 2159}, {"efta_number": "EFTA02734027", "page_number": 123, "text_content": "• \"Indictment: Billionaire Solicited 3 Times\" published on July 25, 2006, reporting that\n\"Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein\nsolicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last\nyear, according to an indictment charging him with felony solicitation of prostitution.\"\nThe article further reported that \"Epstein's case is unusual in that suspected prostitution\njohns are usually charged with a misdemeanor, and even a felony charge is typically\nmade in a criminal information — an alternative to an indictment charging a person with\nthe commission of a crime.\"\n• \"After Long Probe, Billionaire Faces Solicitation Charge\" published on J 26, 2006,\ne Epstein\nreporting that \"Palm Beach police thought there was probable cause t\nwith unlawful sex acts with a minor and lewd and lascivious mol\ne article\nfurther reported that \"Police Chief Michael Reiter was so an a. a State Attorney\nBarry Krischer's handling of the case that he wrote a memo\ng the county's\ntop prosecutor disqualify himself,\" and identified a 20-ye\ni e-record female\nsource who said \"she gave Epstein a massage in the nude\nrought him six girls,\nages 14 to 16, for massage and sex-tinged sessions a\nho\n• \"Police Say Lawyer Tried to Discredit Teena\nublished on July 29, 2006,\nreporting that \"[flamed Harvard law prof\nrshowitz met with the Palm\nBeach County State Attomey's Office\ned damaging information about\nteenage girls who say they gave his\nP\nBeach billionaire Jeffrey Epstein,\nsexually charged massages\" and t\nh\nto attorney's office said it presented the\nEpstein case to a county grand\nonth rather than directly charging Epstein\nbecause of concerns about the\nbility.\"\n• \"Expert: Ignorance of A\nense In Sex Cases\" published on August 5, 2006,\nreporting that \"Mather\ncharges, the state attorney's office presented the case\nto a county grand jury\" w h \"indicted Epstein last week on a single, less serious\ncharge of felony solic on of prostitution,\" and that \"\n... [truncated, 3015 chars — for the full page use /api/corpus/document/EFTA02734027/123 or ?id=EFTA02734027&page=123]", "char_count": 3015}, {"efta_number": "EFTA02734027", "page_number": 124, "text_content": "• \"Woman Sues Billionaire Investor, Says They Had Sex When She Was 16\" published\non October 18, 2007, reporting on a lawsuit brought in New York State court against\nEpstein \"by a young woman who says he had sex with her when she was 16 and had\nsought his help becoming a model.\"\n• \"Palm Beadier Pleads In Sex Case\" published on July 1, 2008, reporting that \"Epstein,\n55, pleaded guilty . . . to felony solicitation of prostitution and procuring a person under\nthe age of 18 for prostitution,\" resulting in \"a lifelong obligation to register as a sex\noffender,\" and that \"[a]s part of the plea deal, federal investigators agreed to drop their\ninvestigation of Epstein, which they had taken to a grand jury.\"\n• \"Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon\" published on\nAugust 11.18ating that \"[d]uring his first month of co\nement\" Epstein was\nvisited by\nwho allegedly escorted victims \"upon heir, Nal at his Palm\nthe massaoe table and\nBeach waterfront home to an upstairs room, where she pre\nprovided the oils for their encounters\" with Epstein, an by\n\"a\nyoung woman whom Epstein purportedly described\nslavian sex slave.\"\n• \"Billionaire Sex Offender Leaves Jail Six Da\n1, 2008, reporting that Epstein \"is allowed t\nsix days a week on a work-release progr\n\nor Work\" published on July\nPalm Beach County Stockade\n\n• \"Women Want Epstein Sex Plea Dea\n' published on June 10, 2009, reporting\nthat attorneys for women suing\narious courts \"want his [non-prosecution]\nagreement [NPA] with federal\nors unsealed\" and were moving to unseal the\nagreement in Circuit Court\nth Judicial Circuit, and that \"Epstein now faces\nat least a dozen civil la\nederal and state courts filed by young women who\nsaid they had sex wi\nnow are seeking damages.\" On that date, The Palm\nBeach Post moved t\ne in the matter for the purpose of obtaining public access\nto the NPA, which\nered disclosed by this Court on June 25, 2009.\n• \"Epstein's S\nct With Feds Reveals 'Highly Unusual' Tenns\" published on\nSeptem\n... [truncated, 2882 chars — for the full page use /api/corpus/document/EFTA02734027/124 or ?id=EFTA02734027&page=124]", "char_count": 2882}, {"efta_number": "EFTA02734027", "page_number": 125, "text_content": "• \"Epstein Journal's Findings Could Resurrect Abuse Case\" published on March 20,\n2010, reporting that \"[a] purloined journal that is said to contain the names of\n'hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reopen\nthe investigation into the multi-millionaire's appetite for teenage girls.\"\n• \"Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits\" published\non October 4, 2017, reporting that, according to court documents, Epstein \"shelled out\n$5.5 million to settle lawsuits with three of more than two dozen teens who sued him.\"\n• \"Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated\nVictims'\nRights\" published on February 22, 2019, reporting on a ruling by U.\net Judge\nKenneth Marra that \"Federal prosecutors violated the rights o\ny pstein's\nteenage victims [under the Crime Victims' Rights Act] by fa'\nveal they had\ndropped plans to prosecute the billionaire on dozens of f\nm connection\nwith the girls' claims that he paid them for sex at his Palm\nion.\"\n• \"Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pldads Not Guilty to Sex\nTrafficking, Conspiracy Charges In Federal Court liManhattan\" published on July 9,\n2019, reporting on Epstein's appearance in U.S. District Court for the Southern District\nof New York in which he \"pleaded not guilty to charges accusing him of creating a vast\nnetwork of girls as young as 14 that he e loited for his sexual pleasure at his homes\nin Palm Beach and Manhattan.\"\nA true and correct copy of the above news art'\nSees,\nare maintained in The Palm Beach Po\n\nec\n\noriginally published, is annexed\n\nhIbit 1.\n\n55.\n\ner the computerized format in which they\n\nnic archives or the news print edition in which\n\nSince the filing dlhejhitial Complaint in this matter, The Palm Beach Post —along\n\nwith media worldwide —\nproceedings resu\nO\n\nNontinued to report on Epstein's crimes and the ongoing official\n\nm those crimes.\n(2)\n\nThe Palm Beach PosPs Standing and the Public Interest.\n\ne press has a consti\n... [truncated, 2459 chars — for the full page use /api/corpus/document/EFTA02734027/125 or ?id=EFTA02734027&page=125]", "char_count": 2459}, {"efta_number": "EFTA02734027", "page_number": 126, "text_content": "Co. v. M,\n\n426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a \"public surrogate\" in\n\nmatters concerning the closure of judicial proceedings). The press also has a First Amendment\ninterest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer\nCouncil, 425 U.S. 748, 756-57 (1976) (\"Where a speaker exists . . . the protection afforded [by\nthe First Amendment] is to the communication, to its source and to its recipients both.\"); Pittman\nv. M. 267 F.3d 1269, 1283 12.12 (11th Cir. 2001) (\"The Supreme Court has r\n\nthat the\n\nFirst Amendment offers protection to both speakers and those wishing to\n\nh.\"); see\n\nalso Stephens v. Qv. ofAlbemarle, Va., 524 F.3d 485, 492 (4th Cir. 20\nhas \"standing to assert a right to receive speech\" by \"show[in\nto convey the information to hee').\n57.\n\nth\n\ng that a plaintiff\nexists a speaker willing\n\nV\n\nBecause of the unique role performc‘i\n\n426 So. 2d at 6-7) in protecting the right of\n\nt\n\ness as a \"public surrogate\" (=,\nin reporting information about\n\ncriminal proceedings, news organizatio\n\nresu\n\nComm 'r, Ala. Dep't of Corr. v. Adv c\n\nI Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019),\n\nand \"standing to question the\nnews is directly unpaired\n\nyively\nt\nhave a tight to access judicial records,\"\n\nan order restricting publicity because its ability to gather\niled.\"\n\n426 So. 2d at 4; see also Carlson v. United States,\n\n837 F.3d 753, 75\n\n8 (7th 'Cir. 2016) (\"[a]s a member of the public, [the Reporters Committee]\n\nhas standin\n\n[its] claim\" to grand jury materials because such materials are \"public records\n\nto whi\n\nlic may seek access, even if that effort is ultimately unsuccessful\").\n58.\n\nHere, the continued denial of access to information The Palm Beach Post seeks on\n\nbehalf of its journalists and the public it serves \"unquestionably constitutes irreparable injury.\"\nGainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also\nZerilli v. M,\n\n656 F.2d 705, 711 (D.C. Cir. 1981) (not\n... [truncated, 2061 chars — for the full page use /api/corpus/document/EFTA02734027/126 or ?id=EFTA02734027&page=126]", "char_count": 2061}, {"efta_number": "EFTA02734027", "page_number": 127, "text_content": "source of information is weakened whenever the ability of journalists to gather information is\nimpaired,\" as it is by Attorney General's refusal to disclose unredacted report and underlying grand\njury materials).\n59.\n\nThe Palm Beach Post has the right to maintain this private right of action because\n\nthe furtherance of justice, an express legislative exception to grand jury secrecy, is intended for\nthe public benefit, and The Palm Beach Post seeks access on behalf of the\n\nFla. Stat.\n\n§ 905.27(1Xc). It is further express in Fla. Stat. § 905.27 that the legisla\n\nfor a court\n\nto be the party to make the determination of disclosure. Fla. Stat. § 9\nlegislature intended for recourse to the courts in considering\n\nee\n\n'\n\nother words, the\nng the propriety and\n\nscope of grand jury secrecy.\nE.\n\nThe Court's Jurisdiction And Authority.AC I \\ I„\n(1)\n60.\n\nThe Court's Supeitti of the Grand Jury Process and Its\nAuthority to Order Public Disclosure of the Eastein Evidence.\nnoted that \"in states such as Florida, where the\n\nThe Florida Supreme\n\ngrand jury is preserved, it is an\n\nppendage of the court which impanels it. At the same\n\ntime it should not be forgotten\n\njudge of that court is equally important and he is generally\n\ncharged with the superviseIi r ot'lthe grand jury's activities...It is, therefore, of vital importance to\nmaintain the 4:1.\nClemons,\n6\n\nthe integrity of both the grand jury and the presiding judge.\" State v.\n231, 233-34 (Fla. 1963).\n\nChapter 905 of the Florida Statutes governs the empanelment and conduct of\n\nFlorida grand juries. The court gives the grand jury its initial charge and advises the grand jury\nabout its legal duties. Fla. Stat. § 905.18.\n62.\n\nFlorida Stat. Section 905.27(1) provides that \"the testimony of a witness examined\n\nbefore the grand jury . . . or other evidence received by it\" may be disclosed \"when required by a\n\n17\n\nEFTA02734154\n\n\f", "char_count": 1887}, {"efta_number": "EFTA02734027", "page_number": 128, "text_content": "court . . . for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by\nthe witness before the court; (b) Determining whether the witness is guilty of perjury; or (c)\nFurthering justice.\" Fla. Stat. § 905.27(1)(a)-(c).\n63.\n\nFurther, disclosure is appropriate pursuant to this Court's inherent authority over\n\ngrand jury proceedings because of the exceptional public interest in this case and the compelling\ncircumstances supporting transparency. Carlson v. United States, 837 F.3d at 766\nhas the inherent power to disclose [grand jury] materials in exceptional\nhistoric importance can be a sufficient reason when there is little count\n64.\n\nThe Florida Supreme Court has confirmed that\n\nand that any \"potential harm to public officeholders\" fro\nown conduct, and not the consequence of an unr\nHerald Pub. Co. v. Marko, 352 So. 2d 51\nextraordinary exercise in citizen partici\n\nticl\n\nSiO\n' r\n\ntrict court\nces and . . .\n\need for secrecy\").\n\ndj\n\nsecrecy is not absolute\n\n\"will be the product of their\ny of misguided citizens.\" Miami\n\n\"The benefits to be derived from this\n\nn[idWhe grand jury] would be severely limited if the\n\nfruits of that activity were not ava\n\no\n\nthe power of the grand jury to\n\ne and expose official misconduct is the right of the people\n\nto be informed of its find\nrisk of reputatio\nofficeholders\nbody\n\npublic on whose behalf it is undertaken. Implicit in\n\ne public disclosure of grand jury findings inevitably entails the\ne, the legislature has ensured that any potential harm to public\n\nthe product of their own conduct, and not the consequence of an unrestrained\ned citizens.\").\n(2)\n\n65.\n\nThe Court's Jurisdiction To Declare Riahts And Construe\nStatutes.\n\nThis Court has jurisdiction to declare rights, status, and other equitable or legal\n\nrelations whether or not further relief is or could be claimed. Florida Stat. Section 86.011.\n\n18\n\nEFTA02734155\n\n\f", "char_count": 1905}, {"efta_number": "EFTA02734027", "page_number": 129, "text_content": "66.\n\nFlorida law specifically provides that a declaration may be sought from the Court\n\nconcerning a petitioner's rights under a statute. Florida Stat. Section 86.021 (\"Any person...whose\nrights, status, or other equitable or legal relations are affected by a statute, or any regulation made\nunder statutory authority,...may have determined any question of construction or validity arising\nunder such statute,...or any part thereof, and obtain a declaration of rights, status, orto her equitable\nor legal relations thereunder.\").\n67.\n\nThe Court's exercise of its power to declare rights \"is to be\n\nadministered\n\nand construed.\" Florida Stat. Section 86.101.\nCOUNT I\n(Declaratory Relief - Florida Stat. Sec\n68.\n\nThe allegations set forth in paragrap\n\n1\n\n1 et seq.)\n67 are incorporated by reference\n\nas if folly set forth herein.\n69.\n\nThis is an action for Dec\n\n(tor\nSit lief pursuant to Chapter 86, Florida Statutes,\n\nand other supplemental relief.\n70.\n\nThe Palm Beac\n\nFla. Stat. Section 905.27,E\npresented in 200\n\nost\n\nectfiilly requests that the Court declare that pursuant to\n\ns entitled access to the testimony, minutes, and other evidence\n\nhe Pa i Beach County grand jury because such disclosure and access would\n\nbe in the fit\n\ni e of justice. Fla. Stat. § 905.27(1X0). Because The Palm Beach Post is not\n\nseekin\n\ntenals in connection with either a civil or criminal case, it seeks a declaration that\n\nthe scope of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2).\n71.\n\nThe Palm Beach Post further seeks a declaration that disclosure of the testimony,\n\nminutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate\n\n19\n\nEFTA02734156\n\n\f", "char_count": 1704}, {"efta_number": "EFTA02734027", "page_number": 130, "text_content": "pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional\npublic interest in this case and the compelling circumstances supporting transparency.\n72.\n\nThe Palm Beach Post has sought from Defendants, but Defendants have refined to\n\nprovide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach\nCounty grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the\nrelief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith disput\nthe parties.\n73.\n\nThrough this Complaint, The Palm Beach Post presen\n\nconcerning its rights to obtain the 2006 grand jury materials purs\n\nto\n\ns between\n\nO\n\nAS\"\nliciable question\n\n. Stat. Section 905.27(1)\n\nand the Court's inherent authority.\n74.\n\nA bona fide, actual, present, and p12/ etiSilly\n\nfor the declaration exists in that\n\nDefendants have denied to The Palm BeachS\n\nr\n\nmaterials sought to be disclosed. The reli\n\nugh\n\nom the Court is therefore not merely the giving\n\nof legal advice or to answer hypo\n\nlions.\n\nWHEREFORE, The P\nrights and obligations of\n\nBe\n\nd to the public at large — the grand jury\n\nPost respectfully requests that the Court determine the\n\nes by declaring that pursuant to Ha. Stat. Section 905.27(1Xc)\nthority, The Palm Beach Post may gain access to the testimony,\n\nand the Court's\n\nrent\n\nminutes, and\n\nence presented in 2006 to the Palm Beach County grand jury and use those\n\nmaten\n\npurpose of informing the public.\n\nCOUNT\n(Florida Stat. Section 905.27)\n75.\n\nThe allegations set forth in paragraphs 1 through 74 are incorporated by reference\n\nas if fully set forth herein.\n\n20\n\nEFTA02734157\n\n\f", "char_count": 1672}, {"efta_number": "EFTA02734027", "page_number": 131, "text_content": "76.\n\nBased on infomuation learned by The Palm Beach Post through its Florida Public\n\nRecords Law requests, law enforcement sources with direct knowledge of the grand jury evidence\nand proceedings, judicial documents obtained from independent but related court proceedings, and\ndocuments otherwise available in the public record, the State Attorney for Palm Beach County\npresented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner\nthat precluded his indictment for the serious crimes he committed, including ser\n\nng and\n\nsexual assault.\n77.\n\nPursuant to Florida Stat. Section 905.27, in order to\n\nce for Epstein's\n\nvictims and the public, and to provide public disclosure to ill\nin , • to\nunreasonably lenient treatment based on the available e\nimmediate access to the testimony, minutes, and o Her\n\nc\n\n'ether Epstein received\n\ne Palm Beach Post requests\n\ns• r ce presented in 2006 to the Palm\n\nBeach County grand jury.\n78.\n\nIn a case of this magnitud\n\nof his crimes, as well as the identi\nvictims have already been e\nv. Socony-Vacuum Oil\nended, disclosure\n\nd im dance, where the accused is dead and so many\nes of his co-conspirators, and the identities of the\need for grand jury secrecy is no more. See United States\n\ni U.S. 150, 234 (1940) (\"[A]fter the grand jury's functions are\n\nholly roper where the ends of justice require it.\").\nThePahn Beach Post respectfully requests that this Court, pursuant to Fla.\n\nStat. S\n\n5.27(1) and the Court's inherent authority, order the State Attorney and the Clerk\n\nof the Court to file with this Court copies of the testimony, minutes, and other evidence presented\nin 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so\nthat, following an in camera inspection, it can be made available to The Palm Beach Post and the\n\n21\n\nEFTA02734158\n\n\f\n\n[═══ TRANSCRIPT ═══]\nCERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has been electroni\n... [truncated, 2154 chars — for the full page use /api/corpus/document/EFTA02734027/131 or ?id=EFTA02734027&page=131]", "char_count": 2154}, {"efta_number": "EFTA02734027", "page_number": 132, "text_content": "public on an expedited basis, and grant any other and further equitable or legal relief the Court\ndeems just and proper.\nDated: January 17, 2020\n\nRespectfully submitted,\nGREENBERG TRAURIG, P.A.\nAttorneys for CA Florida Holdings, LLC,\nPublisher of The Palm Beach Post\nStephen A. Mendelsohn, Esq.\n5100 Town Center Circle, Suite\nBoca Raton, Florida 33486\nTelephone: (561) 955-762\nFacsimile: (561) 338-7\nBy: Is/ Stephen A. Mende\nSTEPHEN A.\nELSOHN\n4\nFlorida Bar\nmendelso\ncorn\nhasenh\nm\nFLS\nw.com\nBy:\n\nel J Cnygiel\nCHAEL J GRYGIEL\nmitted Pro Hac Vice)\n4 State St., 6th Floor\nAlbany, New York 12207\nTelephone: (518) 689-1400\nFacsimile: (518) 689-1499\ngrygielm@gtlaw.com\n\nBy: /s/ Nina D. Banton\nNINA D. BOYAJIAN\n(Pro Hac Vice application pending)\n1840 Century Park East, Suite 1900\nLos Angeles CA 90067\nTelephone: (310) 586 -7700\nFacsimile: (310) 586 -7800\nboyajiann@gtlaw.com\nriveraal@gtlaw.com\n\n22\n\nEFTA02734159\n\n\f\n\n[═══ TRANSCRIPT ═══]\nEXHIBIT 1 The Newspaper's Reportage on Jeffrey Epstein  EFTA02734161", "char_count": 998}, {"efta_number": "EFTA02734027", "page_number": 133, "text_content": "CERTIFICATE OF SERVICE\nI HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has\nbeen electronically filed with the Florida E-File Portal for e-service on all parties of record herein.\n/s/Stevhen A. Mendelsohn\nSTEPHEN A. MENDELSOHN\n\n23\n\nEFTA02734160\n\n\f", "char_count": 279}, {"efta_number": "EFTA02734027", "page_number": 134, "text_content": "EXHIBIT 1\nThe Newspaper's Reportage on Jeffrey Epstein\n\nEFTA02734161\n\n\f", "char_count": 71}, {"efta_number": "EFTA02734027", "page_number": 135, "text_content": "The Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nThe Man Who Had Everything: Jeffrey Epstein craved big\nhomes, elite friends and underage girls\nBy Andrew Marra\nPosted Jul 17, 2019 at 6:02 AM\n\nFrom the archives: When Palm Beach detectives started asking\nquestions and teenage girls started talking, a wave of legal resistance\nfollowed.\n)\nEditor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after\nJeffrey Epstein's arrest in Palm Beach County on a charge offelony solicitation of prostitution.\nWINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach mansion. Inside,\nhidden cameras trolled two rooms, while the girls came and went\n137\nFor the police detectives who sifted\ne garbage outside and kept records of visitors, it\nwas the lair of a troubling targe\nEpstein, one of the most mysterious of the country's mega-rich, was known as much for his\nsecrecy as for his love of fine things: magnificent homes, private jets, beautiful women,\nfriendships with the world's elite.\nBut at Palm Beach police headquarters, he was becoming known for something else: the\nregular arrival of teenage girls he hired to give him massages and, police say, perform sexual\nfavors.\nEpstein was different from most sexual abuse suspects; he was far more powerful. He counted\namong his friends former President Bill Clinton, Donald Trump and Prince Andrew, along\nwith some of the most prominent legal, scientific and business minds in the country.\nWhen detectives started asking questions and teenage girls started talking, a wave of legal\nresistance followed.\n\nEFTA02734162\n\n\f", "char_count": 1595}, {"efta_number": "EFTA02734027", "page_number": 136, "text_content": "» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during workrelease\nIf Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.\nEpstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends\nquietly, always in the background as he navigated New York high society.\nWhen he first attracted notice in the early 1990s, it was on account of the woman he was\ndating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.\nIn a lengthy article, headlined \"The Mystery of Ghislaine Maxwell's Secret L e: the British\nMail on Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a\nmath teacher, a concert pianist or a corporate headhunter.\n\"But what is the truth about him?\" the newspaper won\nflamboyant and intensely private.\"\n\n7\"\n\n\\11?\n\ne Maxwell, Epstein is both\n\n\\\n\nThe media frenzy did not begin in full until a•deASde\nS' ter. In September 2002, Epstein was\nflung into the limelight when he flew Clk ton\n......iay actors Kevin Spacey and Chris Tucker to\nAfrica on his private jet.\nSuddenly everyone wanted to Ic‘tii\n\nEpstein was. New York magazine and Vanity Fair\n\npublished lengthy profiles. The New York Post listed him as one of the city's most eligible\nbachelors and began describing him in its gossip columns with adjectives such as \"mysterious\"\nand 'reclusive?\nAlthough\n\nno interviews, the broad strokes of his past started to come into focus.\n\nBuilding a l e of extravagance\ndepartment employee, and\nHe was born blue-collar in 1953, the son of a New York City\nraised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree\nbut became a math teacher at the prestigious Dalton School in Manhattan.\nThe story goes that the father of one of Epstein's students was so impressed with the man that\nhe put him in touch with a senior partner at Bear Stearns, the global investment bank and\nsecurities firm.\n\nEFTA02734163\n\n\f", "char_count": 1975}, {"efta_number": "EFTA02734027", "page_number": 137, "text_content": "In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.\nEpstein and Co. That is when he began making his millions in earnest.\nLittle is known or said about Epstein's business except this: He manages money for the\nextremely wealthy. He is said to handle accounts only of $1 billion or greater.\nIt has been estimated he has roughly 15 clients, but their identities are the subject of only\nspeculation. All except for one: Leslie Wexner, founder of The Limited retail chai\n4 and\n, a\nformer Palm Beacher who is said to have been a mentor to Epstein.\nWexner sold Epstein one of his most lavish residences: a massive townhouseC?at dominates a\nblock on Manhattan's Upper East Side. It is reported to have, amonc • stt\ncircuit television and a heated sidewalk to melt away fallen snow.\nThat townhouse, thought to be the largest private residence\nthe extravagant world Epstein built over time.\n\nIv\n\nfeatures, closed-\n\nis only a piece of\n\n/ 414/ACH\n\\l\nIn New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch\noutside Santa Fe. Many believed it to be the largest home in the state.\nIn Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre\nprivate island in the Virgin Islands.\n» PHOTOS: The players in thejeffrey Epstein saga\nPerhaps as remarkable as his lavish homes is his extensive network of friends and associates at\nthe highest echelons of power. This includes not only socialites but also business tycoons,\nmedia moguls\n\nli cians, royalty and Nobel Prize-winning scientists whose research he often\n\nfunds.\n\"Just like other people collect art, he collects scientists,\" said\n\nNowak, who directs the\n\nProgram for Evolutionary Dynamics at Harvard University and was reportedly the recipient of\na $30 million research donation from Epstein.\nEpstein is said to have befriended former Harvard President Larry Summers, prominent law\nProfessor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort\nZu\n... [truncated, 2025 chars — for the full page use /api/corpus/document/EFTA02734027/137 or ?id=EFTA02734027&page=137]", "char_count": 2025}, {"efta_number": "EFTA02734027", "page_number": 138, "text_content": "And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely\nphotographed.\n\"The odd thing is I never met him: said Dominick Dunne, the famous chronicler of the trials\nand tribulations of the very rich. \"I wasn't even aware of him,\" except for a Vanity Fair article.\nEpstein's friendship with Clinton has attracted the most attention.\nEpstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at\nan intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become\nclose friends until after Clinton left the Oval Office and moved to New York.\nEpstein has donated more than $100,000 to Democratic candidates' campaigns, including John\nKerry's presidential bid, the reelection campaign of New Mexico Gov. Bill\nand the\nSenate bids of Joe\nSchumer.\n\nHillary Rodham Clinton, Christopher Dodd and Charles\n4s 9 Y\n\nPowerful friends and enemies\na\n\\\nA Vanity Fair profile found cracks in the ven\nS 4,of Epstein's life story. The 2003 article said he\nleft Bear Stearns in the wake of a federal probe and a possible Securities and Exchange\nCommission violation. It also pointed out that Citibank once sued him for defaulting on a $20\nmillion loan.\nThe article suggested that one of his business mentors and previous employers was Steven\nHoffenberg, now serving a prison term after \"bilking investors out of more than $450 million\nin one of the largest Ponzi schemes in American history.\"\nAs he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the\nman who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less\nthan $16,000 in furnishings.\nA former friend claimed Epstein backed out of a promise to reimburse him hundreds of\nthousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein\nowed him nothing.\n» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says\n\nEFTA02734165\n\n\f", "char_count": 1966}, {"efta_number": "EFTA02734027", "page_number": 139, "text_content": "It's a bad memory. I would rather not have ever met Jeffrey Epstein,\" said Michael Stroll, the\nretired former president of\nElectronics and Sega Corp. \"Suffice it to say I have\nnothing good to say about him.\"\nAmong the characteristics most attributed to Epstein is a penchant for women.\nHe has been linked to Maxwell, a fixture on the high-society party circuits in both New York\nand London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian\nmodel.\n4414.\n\"He's a lot of fun to be with,\" Donald Trump told New York magazine in Sit\nthat he likes beautiful women as much as I do, and many of them are\n\nhe\n\nis even said\nunger side. No\n\ndoubt about it, Jeffrey enjoys his social life\nInvestigation leads to Epstein\n\n0\\,\n\nAlthough he was not a frequenter of the Palm Beachs\nAmong his charitable donations, he gave $90,\n$100,000 to Ballet Florida.\n\n,\n\nne, he made his presence felt.\nalm Beach Police Department and\n\n4\n\n_•••••,( SIOV\n\nIn Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a\nHarley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a\nprivate chef and a small staff stood at the ready. From a window in his mansion, he could look\nout on the Intracoastal W,tsterway\nzit and the West Palm Beach skyline. He seemed to be a man\nwho had everything.\nBut extraordinaFfseatlth can fuel extraordinary desires.\n» Epstein\n\nants to leave jail for mansion in sex-trafficking case\n\nIn March 2005, a worried mother contacted Palm Beach police. She said another parent had\noverheard a conversation between their children.\nNow the mother was afraid her 14-year-old daughter had been molested by a man on the\nisland.\nThe phone call triggered an extensive investigation, one that would lead detectives to Epstein\nbut leave them frustrated.\n\nEFTA02734166\n\n\f", "char_count": 1833}, {"efta_number": "EFTA02734027", "page_number": 140, "text_content": "Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm\nBeach police report detailing the criminal probe offers a window into what detectives faced as\nthey sought to close in on Epstein.\nDetectives interviewed the girl, who told them a friend had invited her to a rich man's house to\nperform a massage. She said the friend told her to say she was 18 if asked. At the house, she\nsaid she was paid $300 after stripping to her panties and massaging the man while he\nmasturbated.\n444..\nPolice interview 5 alleged victims\nThe investigation began in full after the girl identified Epstein in a photo as\n\nman who had\n\npaid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift\nthrough it. They set up a video camera to record the comings and goings at his home. They\nmonitored an airport hangar for signs of his private jet's arrivals and departures.\nThey quickly learned that the woman who took the 14-year-old girl to Epstein's house was\na Palm Beach Community College student from Loxahatchee. In a sworn\nstatement at police headquarters,\n\n, then 18, admitted she had taken at least six girls to\n\nvisit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said.\nDuring the drive back to her house,\n\ntold detectives, \"I'm like a Heidi Fleiss.\"\n\nPolice interviewed five alleged victims and 17 witnesses. Their report shows some of the girls\nsaid they had been instructed to have sex with another woman in front of Epstein, and one said\nshe had direct intercourse with him.\nIn October, police searched the Palm Beach mansion. They discovered photos of naked, younglooking females, just as several of the girls had described in interviews. Hidden cameras were\nfound in the garage area and inside a clock on Epstein's desk, alongside a girls high school\ntranscript.\nTwo of Epstein's former employees told investigators that young-looking girls showed up to\nperform massages two or three times a day when E\n... [truncated, 2183 chars — for the full page use /api/corpus/document/EFTA02734027/140 or ?id=EFTA02734027&page=140]", "char_count": 2183}, {"efta_number": "EFTA02734027", "page_number": 141, "text_content": "One employee told detectives he was told to send a dozen roses to one teenage girl after a high\nschool drama performance. Others were given rental cars. One, according to police, received a\n$200 Christmas bonus.\nThe cops moved to cement their case. But as they tried to tighten the noose, they encountered\nother forces at work.\nIn Orlando they interviewed a possible victim who told them nothing inappropriate had\nhappened between her and Epstein. They asked her whether she had spoken to anyone else.\nShe said yes, a private investigator had asked her the same questions.\n» Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal\nWhen they subpoenaed one of Epstein's former employees, he old them the same thing. He\nand a private eye had met at a restaurant days earlier to go\nthe man would tell\ninvestigators.\nDetectives received complaints that private eyes were posing as police officers. When they told\nEpstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the\nhigh-powered Miami lawyer who has dgfglded the likes of Rush Limbaugh and William\nKennedy\nWhile the private eyes were coiZctin a parallel investigation, Dershowitz, the Harvard law\nprofessor, traveled to West Palm Beach with information about the girls. From their own\nprofiles on the popular Web site MySpace.com, he obtained copies of their discussions about\ntheir use of alcohol and marijuana.\nHe took his research to a meeting with prosecutors in early 2O06, where he sought to cast\ndoubt on the teens' reliability.\nThe private eyes had dug up enough din on the girls to make prosecutors skeptical. Not only\ndid some of the girls have issues with drugs or alcohol but also some had criminal records and\nother troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she\ntold police she was younger than 18 when she started performing massages for Epstein.\nAfter the meeting, prosecutors postponed their decision to take the case to a grand jury.\n\nEFTA027\n... [truncated, 2008 chars — for the full page use /api/corpus/document/EFTA02734027/141 or ?id=EFTA02734027&page=141]", "char_count": 2008}, {"efta_number": "EFTA02734027", "page_number": 142, "text_content": "In the following weeks, police received complaints that two of the victims or their families had\nbeen harassed or threatened. Epstein's legal team maintains that its private investigators did\nnothing illegal or unethical during their research.\nBy then, relations between police and prosecutors were fraying. At a key meeting with\nRecarey, the lead investigator, was a no-show,\nprosecutors and the defense, Detective\naccording to Epstein's attorney.\n\"The embarrassment on the prosecutor's face was evident when the police officer never\nshowed up for the meeting,' attorney Jack Goldberger said.\nLater in April, Recarey walked into a prosecutor's office at the state attorney's office and\nlearned the case was taking an unexpected turn.\nThe prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein\na plea deal that would not require him to serve jail timevive a felony conviction.\nRecarey told her he disapproved of the plea offe\\ AS\\ ,\nThe deal never came to pass, however.\nFuture unclear after charge\nOn May 1, the department asked prosecutors to approve warrants to arrest Epstein on four\ncounts of unlawful sexual activity with a minor and to charge his personal assistant,\nnow 27, for her alleged role in arranging the visits. Police officials also wanted to\ncharge IMMI, the self-described Heidi Fleiss, with lewd and lascivious acts.\nBy then, the department was frustrated with the way the state attorney's office had handled the\ncase. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter\nwrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if\nhe would not act.\nTwo weeks later, Recarey was told that prosecutors had decided once again to take the case to\nthe grand jury.\n\nEFTA02734169\n\n\f", "char_count": 1801}, {"efta_number": "EFTA02734027", "page_number": 143, "text_content": "It is not known how many of the girls testified before the grand jury. But Epstein's defense\nteam said one girl who was subpoenaed - the one who said she had sexual intercourse with\nEpstein - never showed up.\nThe grand jury's indictment was handed down in July. It was not the one the police\ndepartment had wanted.\nInstead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was\ncharged with one count of felony solicitation of prostitution, which carries a Mxirnum penalty\nof five years in prison. He was booked into the Palm Beach County Jail earlyJuly 23 and\nreleased hours later.\nEpstein's legal team \"doesn't dispute that he had girls over for massages,\" Goldberger said. But\nhe said their claims that they had sexual encounters with him lack credibility.\n\"They are incapable of being believed,\" he said. \"They had criminal records. They had\naccusations of theft made against them by their e \\ ployess,There was evidence of drug use by\nsome of them.\"\nWhat remains for Epstein is yet to be se\nThe Palm Beach Police Departmet‘i\nreturned the $90,000 Epstein donated\n\ned the FBI to investigate the case. It also has\n2004.\n\nIn New York, candidates for governor and state attorney general have vowed to return a total\nof at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful\nfriends have remained silent as tabloids and Internet blogs feast on the public details of the\npolice investigation.\nGoldberger maintains Epstein's innocence but says the legal team has not ruled out a future\nplea deal. He insists Epstein will emerge in the end with his reputation untarnished.\n\"He will recover from this,\" he said.\nStaff writer Larry\n\nand staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and\n\nMelanie Mena contributed to this story.\namarrappbpost,com\n\nEFTA02734170\n\n\f", "char_count": 1835}, {"efta_number": "EFTA02734027", "page_number": 144, "text_content": "OAMarnPBPost\n\nI\n\nEFTA02734171\n\n\f", "char_count": 32}, {"efta_number": "EFTA02734027", "page_number": 145, "text_content": "273 / 278 - Tuesday, November 16, 2004\nEdition: FINAL\nSection: A SECTION\nPage: 1A\nSource: By PAUL OWERS Palm Beach Post Staff Writer\nIllustration: PHOTO (C & 2 B&W) & MAP (B&W)\nMemo: Ran all editions.\nDateline: WEST PALM BEACH\nTRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION\nWhen it came time to bid Monday for the palatial Palm Beach digs of\nan, The\nDonald was not about to be trumped.\n\"Nobody was going to outbid me,\" the brash developer-turnedality said from his\nNew York office.\nTrump bested two other bidders with a $41.35 million off fort 43,000-square-foot,\nseven-bedroom estate on 6 oceanfront acres along the storied \"Raider's Row.\"\nBut Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at\n513 N. County Road. He wants to - what else? - s If it'atl make more money.\nThe star of the mega-hit The Apprentice said\nds ro redevelop the site into a \"super\nluxury house\" that would be the \"finest an\ne United States.\" He might build\nanother house before flipping the entire p\n\"I've known about this house for quite\n,\" Trump said. \"It's probably the best piece\nof land in Florida - and probably\nfor luxury real estate.\"\nAlthough Trump said he could s\ne property into nine lots, Palm Beach\nLesly\nsaid zoning regul\nw for only two houses - and maybe a third.\nsaid she's not worried about T\nplans.\n\"He's been a very good property owner in the town of Palm Beach,\" she said. \"He does his\nprojects very well. He's a perfectionist.\"\nMonday's auction k place at U.S. Bankruptcy Court in West Palm Beach as part of\nGosman's Chap r ankruptcy case. Proceeds from the sale will go into escrow for eventual\ndistribution\nito\nThe aucti\nt exactly noon after Judge Steven\ndismissed an objection from\nan atto\nresenting money manager Jeffrey Epstein. The lawyer argued unsuccessfully\nthat T\nas not a qualified bidder because his contract stipulated that he would not close\non the sale unless title insurance was in place beforehand.\nWith Trump listening via conference call, Epstein began the\n... [truncated, 2428 chars — for the full page use /api/corpus/document/EFTA02734027/145 or ?id=EFTA02734027&page=145]", "char_count": 2428}, {"efta_number": "EFTA02734027", "page_number": 146, "text_content": "But\nallowed the offer to stand, and Puke and Trump went back and forth until\nPulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at\n$38.6 million.\nclosed the bidding 10 minutes after it started, leaving Trump with the right to buy\nthe 29,000-square-foot home (a typical Palm Beach County single-family house is about\n2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service\nquarters.\nThe closing could take place within a week but probably won't happen until next month.\nTrustee Joe Luzinski and creditors said they were pleased with the outcome.\n\"We knew we were dealing with some substantial people . .. who were going t, i it up a\nbit,\" Luzinski said.\n\"The system worked,\" said Charles Tatelbaum, a lawyer for creditor JPMoPChase Bank.\n\"In bankruptcy court, the idea is to get the most for creditors, and that's hat happened.\"\nThe auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer\nformer listing agent Sotheby's International Realty received was S32 million. Sotheby's won't\nreceive a commission, he said.\nMonday.\nPulte, 42, of Boca Raton, said he figured Trump wouldn't\n\"I got the feeling he was willing to go a lot higher, and\nt to chase it,\" Pulte said.\nPulte said Gosman asked him before the auction whe e e uld be willing to let him stay\nin the mansion after the closing until he decides w e\nis to move. Trump and\nLuzinski said they have had no such discussio\nman.\nGosman, 75, had the house built after payin 1\nlion for the land in 1986.\nThe former health-care magnate declined • t i requests before and after the auction\nMonday. He was at the courthouse but\nbefo the auction took place.\nThe $41.35 million price tag eclips\n5 million sale of Lowell \"Bud\" Paxson's Palm\nBeach home and guest house but\nof the $45 million that Virginia home builder\nDwight Schar paid for Ron Pe\n6,000-square-foot estate, Casa Apava, a designated\nlandmark.\nSchar also paid $18.6 m\" ion for lakefront \n... [truncated, 3290 chars — for the full page use /api/corpus/document/EFTA02734027/146 or ?id=EFTA02734027&page=146]", "char_count": 3290}, {"efta_number": "EFTA02734027", "page_number": 147, "text_content": "The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife\nan ownership interest in his home and other belongings only to avoid losing them in\nbankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in\n1999, well before he filed for bankruptcy.\nLessen is expected to rule in the next two months whether Gosman made improper transfers,\na decision that will affect how much money will be available to creditors.\nCimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were\nwilling to move forward, in part because the upkeep of the estate now exceeds their means.\n\"This is not a happy occasion for them, but at least we're moving to the next level Cimo\nsaid. \"That's not a house you want to live in unless you're making large amoun\nmoney\nlike Donald Trump.\"\npaul_owers®pbpost.com\n\nEFTA02734174\n\n\f", "char_count": 881}, {"efta_number": "EFTA02734027", "page_number": 148, "text_content": "Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL\n\n11/11/2019\n\nThe Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nIndictment: Billionaire Solicited 3 Times\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 2,2019 at 2:30 PM\n(EDITORS NOTE: This story originally published in The Palm Beath Post on July 25,\n2006)\nBillionaire money manager and Palm Beach part-time resident Jeffrey Ep.\nsolicited or procured prostitutes three or more times between Aug. 1 and Oct. 31\nof last year, according to an indictment charging him with felony solicitation of\nprostitution.\nEpstein, 53, was booked at the Palm Beach Cou\nwas released on $3,000 bond.\n\n:45 a.m. Sunday. He\n\nEpstein's case is unusual in that suspecte&\n( <'tution\n\\1\njohns are usually charged\nwith a misdemeanor, and even a felony charge is typically made in a criminal\ninformation - an alternative to an indictment charging a person with the\n\\S\"\ncommission of a crime.\n( 11\n4/\nHis attorney, Jack Goldberger, declined to discuss the charge.\nState attorney's office spokesman Mike Edmondson also had little to say.\n\"Generally speaking, there is a case that has a number of different aspects to it,\"\nEdmondson said of a prostitution-related charge being submitted to a grand jury.\n\"We first became aware of the case months ago by Palm Beach police.\"\nProsecutors and police worked together to bring the case to the grand jury, he\nsaid.\n\nhttps://www palmbeachposLcorninews/20080701/indiclment-billionaire-solicited-3-trnes\n\n1/2\n\nEFTA02734175\n\n\f", "char_count": 1516}, {"efta_number": "EFTA02734027", "page_number": 149, "text_content": "Indictment: Billionaire Solicited 3 Times • News - The Palm Beach Post • West Palm Beach, FL\n\nM1112019\n\nPalm Beach police confirmed that and said the department will release a report\ntoday regarding its investigation.\nEpstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a\npool and a boat dock on the Intracoastal Waterway since 1990, according to\nproperty records. A man answering the door there Monday said that Epstein\nwasn't home. A Cadillac Escalade registered to him was parked in the driveway,\nwhich is flanked by two massive gargoyles.\nEpstein sued Property Appraiser Gary Nikolits in 2001, contending that the\nassessment of his home exceeded its fair market value. He dismissed his lawsuit\nin December 2002.\nA profile of Epstein in Vanity Fair magazine said he owns what are believed to\nbe the largest private homes in Manhattan - 51,000 square feet - and in New\nMexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the\nU.S. Virgin Islands and fleet of aircraft.\nEpstein's friends anIN admirers, according to the magazine, include prominent\nbusinessmen, academics and scientists and famed Harvard law professor Alan\nDers\ner@pbpost.com\n\nhtLosifiwiwpalmbeachpostcominews/20080701findictment-Nlkonaite-solicited-3-times\n\n22\n\nEFTA02734176\n\n\f", "char_count": 1290}, {"efta_number": "EFTA02734027", "page_number": 150, "text_content": "After long probe, biboaaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL\n\n11/11/2019\n\nThe Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nAfter long probe, billionaire faces solicitation\ncharge\nPosted Jul 27, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 3:11 PM\n\n(EDITOR'S NOTE: This story originally published in The Palm Beadt Post o\n\nc2,6,\n\n2006)\nPalm Beach billionaire Jeffrey Epstein paid to have underage gfirl and oung\nwomen brought to his home, where he received massages and sometimes sex,\naccording to an investigation by the Palm Beach Police Department.\nPalm Beach police spent months sifting through Epstein's trash and watching his\nwaterfront home and Palm Beach International Airport to keep tabs on his\nprivate jet. An indictment charging Epstein, 53, was unsealed Monday, charging\nhim with one count of felony solicitation of prostitution.\nity')\n,probable cause to charge Epstein with\nPalm Beach police thought theec\nunlawful sex acts with a minor and lewd and lascivious molestation.\nPolice Chief Michael Reiter was so angry with State Attorney Barry Krischer's\nhandling of the case that he wrote a memo suggesting the county's top\nprosecutor disqualify himself.\n\"I must urge you to examine the unusual course that your office's handling of this\nmatter has taken and consider if good and sufficient reason exists to require your\ndisqualification from the prosecution of these cases,\" Reiter wrote in a May I\nmemo to Krischer.\nWhile not commenting specifically on the Epstein case, Mike Edmondson,\nspokesman for the state attorney, said his office presents cases other than\nmurders to a grand jury when there are questions about witnesses' credibility and\ntheir ability to testify.\n\nhttps://www.palmbeachpost.cominews/20060727/eftePlong-probe•binoneire-faces-sobcitabon-charge\n\n1/5\n\nEFTA02734177\n\n\f", "char_count": 1832}, {"efta_number": "EFTA02734027", "page_number": 151, "text_content": "1111/2019\n\nAfter long probe. billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach. FL\n\nBy the nature of their jobs, police officers look at evidence from a *one-sided\nperspective,\" Edmondson said. \"A prosecutor has to look at it in a much broader\nfashion,\" weighing the veracity of witnesses and how they may fare under\ndefense attorneys' questioning, he said.\nEpstein's attorney, Jack Goldberger, said his client committed no crimes.\n\"The reports and statements in question refer to false accusations that were not\ncharged because the Palm Beach County state attorney questioned the credibility\nof the witnesses,\" Goldberger said. A county grand jury \"found the allegations\nwholly unsubstantiated and not credible,\" and that's why his client was not\ncharged with sexual activity with minors, he said.\nGoldberger said Epstein passed a lie detector test administered by a reputable\npolygraph examiner in which he said he did not know the girls were minors.\nAlso, a search warrant served on Epstein's home found no evidence to\ncorroborate the girls' allegations, Goldberger said.\nAccording to police documents:\n- A Palm Beach Community College student said she gave Epstein a massage in\nthe nude, then brought him s' .gi‘ages 14 to 16, for massage and sex-tinged\nsessions at his home.\n- A 27-year-old woman\n\nc\nrivorked as Epstein's personal assistant also\n\nfacilitated the liaisons, phoning the PBCC student to arrange for girls when\nEpstein was coming to town. And she escorted the girls upstairs when they\narrived, putting fresh sheets on a massage table and placing massage oils nearby.\n- Police took sworn statements from five alleged victims and 17 witnesses. They\ncontend that on three occasions, Epstein had sex with the girls.\nA money manager for the ultra-rich, Epstein was named one of New York's most\neligible bachelors in 2003 by The New York Post. He reportedly hobnobs with\nthe likes of former President Clinton, former Harvard University President\nSummers\n... [truncated, 2211 chars — for the full page use /api/corpus/document/EFTA02734027/151 or ?id=EFTA02734027&page=151]", "char_count": 2211}, {"efta_number": "EFTA02734027", "page_number": 152, "text_content": "11/11/2019\n\nAfter long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL\n\nHe has contributed tens of thousands of dollars to Democratic Party candidates\nand organizations, including Sen. John Kerry's presidential bid, and the Senate\ncampaigns of Joe\n\n, Hillary Clinton,\n\nDodd and Charles\n\nSchumer.\n\nCos\ni\n\nGoldberger is one of five attorneys Epste‘Ba t etained since he became the\nsubject of an investigation, Edmondson said. Among the others: Alan\nDershowitz, the well-known Harvard law professor and author, who is a friend\nof Epstein. Dershowitz could not be reached for comment.\nPolice said the woman who enlisted young girls for Epstein was\n20, of\n\nPalm Beach.\n\nhas worked at an Olive Garden restaurant in\n\nWellington and said she was a journalism major at Palm Beach Community\nCollege when she was questioned by police last October. She has an unlisted\nphone tier\n\nand could not be reached for comment.\n\nsaid she met Epstein when, at age 17, a friend asked her if she would like\nto make money giving him a massage. She said she was driven to his fivebedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs\nto a bedroom with a massage table and oils. Epstein and\n\nwere both naked\n\nduring the massage, she said, but when he grabbed her buttocks, she said she\ndidn't want to be touched.\n\nhttps://www.palmbeachpost.cominewst20060727/after-long-probe-billionaire-taces-solicitation-charge\n\nEFTA02734179\n\n\f", "char_count": 1474}, {"efta_number": "EFTA02734027", "page_number": 153, "text_content": "After long probe, bilionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL\n\n11111/2019\n\nEpstein said he'd pay her to bring him more girls - the younger the better,\ntold police. When she tried once to bring a 23-year-old woman to him,\nEpstein said she was too old,\n\nM\n\nsaid.\n\n, who has not been charged in the case, said she eventually brought six\n\ngirls to Epstein who were paid $200 each time,\n\nsaid. \"I'm like a Heidi\n\nFleiss,\" police quoted her as saying. The girls knew what to expect when they\nwere taken to Epstein's home,\n\nsaid. Give a massage - maybe naked - and\n\nallow some touching.\nOne 14-year-old girl\n\ntook to meet Epstein led police to start the\n\ninvestigation of him in March 2005. A relative of the girl called to say she\nthought the child had recently engaged in sex with a Palm Beach man,. The girl\nthen got into a fight with a classmate who accused her of being a prostitute, and\nshe couldn't explain why she had $300 in her purse.\nThe girl gave police this account of her meeting with Epstein:\nShe accompanied\n\nand a second girl to Epstein's house on a Sunday in\n\nFebruary 2005. Once there, a woman she thought was Epstein's assistant told the\ngirl to follow her upstairs to a room featuring a mural of a naked woman, several\nphotographs of naked women on a shelf, a hot pink and\n\nsofa and a massage\n\ntable.\nShe stripped to her bra and panties and gave him a massage.\nEpstein gave the 14-year-old $300 and she and the other girls left, she said. She\nsaid Robson told her that Epstein paid her $200 that day.\nOther girls told similar stories. In most accounts, Epstein's personal assistant at\nthe time,\n\nnow 27, escorted the girls to Epstein's bedroom.\n\nwhose most recent known address is in North Carolina, has not been\ncharged in the case.\nPalm Beach police often conducted surveillance of Epstein's home, and at Palm\nBeach International Airport to see if his private jet was there, so they would\nknow when he was in town. Police also arranged repe\n... [truncated, 2148 chars — for the full page use /api/corpus/document/EFTA02734027/153 or ?id=EFTA02734027&page=153]", "char_count": 2148}, {"efta_number": "EFTA02734027", "page_number": 154, "text_content": "11/11/2019\n\nAfter long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL\n\nfrom Palm Beach sanitation workers, collecting papers with names and phone\nnumbers, sex toys and female hygiene products.\nOne note stated that a female could not come over at 7 p.m. because of soccer.\nAnother said a girl had to work Sunday - \"Monday after school?\" And still\nanother note contained the work hours of a girl, saying she leaves school at 11:30\na.m. and would come over the next day at 10:30 a.m.\nOnly three months before the police department probe began, Epstein donated\n$90,000 to the department for the purchase of a firearms simulator, said Jane\nStruder, town finance director. The purchase was never made. The mone\n\\ y was\nreturned to Epstein on Monday, she said.\n\nO\n\nC\n\nhttps/AwAv.palmbeachpost.cominewst20060727/atter-long-probe-billonaWe-faces-solicitabon-charge\n\n515\n\nEFTA02734181\n\n\f", "char_count": 926}, {"efta_number": "EFTA02734027", "page_number": 155, "text_content": "11111/2019\n\nPolice say lawyer tried to disaedit teenage girls - News - Palm Beach Dairy News • Palm Beach, FL\n\nPalm Beach Daily News\nPolice say lawyer tried to discredit teenage\ngirls\nPosted Jul 29, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 2:00 PM\n(EDITOR'S NOTE: This story originally was published in The Palm Beach Post on July\n29, 2006)\nFamed Harvard law professor Alan Dershowitz met with the Palm Beach County\nState Attorney's Office and provided damaging information about teenage girls\nwho say they gave his client, Palm Beach billionaire Jgffrey,pstein, sexually\ncharged massages, according to police reports.\nThe reports also state that another Epstein atEk ky- greed to a plea bargain that\nwould have allowed Epstein to have(no riVal record. His current attorney\ndenies this happened.\nAnd the documents also reveal dia\n91 ,.11\ne father of at least one girl complained that\nprivate investigators aggressively followed his car, photographed his home and\nchased off visitors.\nPolice also talked to somebody who said she was offered money if she refused to\ncooperate with the Palm Beach Police Department probe of Epstein.\nThe state attorney's office said it presented the Epstein case to a county grand\njury this month rather than directly charging Epstein because of concerns about\nthe girls' credibility. The grand jury indicted Epstein, 53, on a single count of\nfelony solicitation of prostitution, which carries a maximum penalty of five years\nin prison.\nPolice believed there was probable cause to charge Epstein with the more serious\ncrimes of unlawful sex acts with a minor and lewd and lascivious molestation.\nPolice Chief Michael Reiter was so angry that he wrote State Attorney Barry\nKrischer a memo in May suggesting he disqualify himself from the case.\n\nhttps://wmv.palmbeachdaynews.comlarticle/200607291NEWS/19C1917573\n\n1/4\n\nEFTA02734182\n\n\f", "char_count": 1860}, {"efta_number": "EFTA02734027", "page_number": 156, "text_content": "Police say lawyer tried to discseda teenage girls • News • Palm Beach Daily News • Palm Beach, Ft.\n\n11/11/2019\n\nThe case originally was going to be presented to the grand jury in February, but\nwas postponed after Dershowitz produced information gleaned from the Web\nsite myspace.com showing some of the alleged victims commenting on alcohol\nand marijuana use, according to the police report prepared by Detective\nRecarcy.\na 20-year-old\n\nPalm Beach woman who told police she\n\nrecruited girls for Epstein, also is profiled on myspace.com. Her page includes\nphotos of her and her friends, including one using the name \"Pimpin' Made EZ.\"\nwho was not charged in the case, is a potential prosecution vvittlesS\nAccording to Recarey, prosecutor Lanna Belohlavek offered Epstein\n\neys\n\nDershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with\nEpstein, accepted the deal, in which Epstein would plead guilty to one count of\naggravated assault with intent to commit a felony, be placed on five years'\nprobation and have no criminal record. The deal also called for Epstein to submit\nto a psychiatric and sexual evaluation and have no unsupervised visits with\nminors, according to Recarey's report. The plea bargain was made in connection\nwith only one of the five alleged victims, the report states.\nFronstin - who declined to comment on the case - was subsequently fired and\nveteran defense attorney jack Goldberger was hired. He denies there was any\nagreement by any of Epstein's attorneys to a plea deal.\n\"We absolutely did not agree to a plea in this case,\" he said. Neither Belohlavek\nnor a state attorney's spokesman could be reached for comment.\nThe parent or parents of alleged victims who complained of being harassed by\nprivate investigators provided license tag numbers of two of the men. Police\nfound the vehicles were registered to a private eye in West Palm Beach and\nanother in Jupiter, according to Recarey's report.\n\"I have no knowledge of it,\" defense attorney Goldberger\n... [truncated, 2330 chars — for the full page use /api/corpus/document/EFTA02734027/156 or ?id=EFTA02734027&page=156]", "char_count": 2330}, {"efta_number": "EFTA02734027", "page_number": 157, "text_content": "I t/11/2019\n\nPolice say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Pekn Beach, FL\n\nwho did talk \"will be dealt with: the woman said she was told. Phone records\nshow the woman talked with the person who allegedly intimidated her around\nthe time she said, Recarey reported.\n\nPhone records also show that the person said to have made the threat then\nplaced a call to Epstein's personal assistant, who in turn called a New York\ncorporation affiliated with Epstein, the report states.\nThe issue in the Epstein case is not whether females came to his waterfront\nhome, but whether he knew their ages.\n\"He's never denied girls came to the house,\" Goldberger said. But when Epstein\nwas given a polygraph test, \"he passed on knowledge of age,7 the attorney said.\nAfter the indictment against Epstein was unsealed this Alt, Police Chief Reiter\nreferred the matter to the FBI. \"We've received the referral, and we're reviewing\nit,\" said FBI spokeswoman Judy Orihuela in Miami.\nThe chief himself has come under attack from Epstein's lawyers and friends in\nNew York, where he has a home. The New York Post quoted Epstein's\nprominent New York lawyer, Gerald Lefcourt, as saying his client was indicted\nonly 'because of the craziness of the police chief.\"\nReiter has declined to comment on the case.\nProsecutors have not presented a sex-related case like Epstein's to a grand jury\nbefore, said Mike Edmondson, spokesman for the state attorney's office. 'That's\nwhat you do with a case that falls into a gray area: he said.\nThe state attorney's office did not recommend a particular criminal charge on\nwhich to indict Epstein, Edmondson said. The grand jury was presented with a\nlist of charges from highest to lowest, then deliberated with the prosecutor out of\nthe room, he said.\n\"People are surprised at the grand jury proceeding,\" West Palm Beach defense\nattorney Richard Tendler said. \"It's a way for the prosecutor's office to not take\nthe full responsibility for not filing the (c\n... [truncated, 2219 chars — for the full page use /api/corpus/document/EFTA02734027/157 or ?id=EFTA02734027&page=157]", "char_count": 2219}, {"efta_number": "EFTA02734027", "page_number": 158, "text_content": "11/11/2019\n\nPolice say lawyer tried to discredit teenage gills - News - Palm Beach Daily News - Palm Beath, Ft.\n\nDefense attorney Robert Gershman was a prosecutor for six years. *Those girls\nmust have been incredible or untrustworthy, I don't know,' he said.\nOther attorneys said Epstein's case raises the issue of whether wealthy, connected\ndefendants like Epstein - whose friends include former President Clinton and\nDonald Trump - are treated differently from others. Once he knew he was the\nsubject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as\nDershowitz and Lefcourt, who is a past president of the National Association of\nCriminal Defense Lawyers.\nMiami lawyer Roy Black - who became nationally known when he successfully\ndefended William Kennedy\n\non a rape charge in Palm Beach - also was\n114\n/ „,,\n\ninvolved at one point.\nSaid defense attorney\n\n)\nSuskauer: \"1 think it's unfortunate the public may\n\nget the perception that with power, you may be treated differently than the\naverage Joe.\"\nAgNic?\n\n? S'\n\nhttpc/Nowtpalmbeectidailynews.conVarticlel20060729/NEWS/190917573\n\n4/4\n\nEFTA02734185\n\n\f", "char_count": 1128}, {"efta_number": "EFTA02734027", "page_number": 159, "text_content": "The Palm\nBeach\nPost\nREAL NEWS STARTS ERE\nExpert: Ignorance of age isn't\ndefense in sex cases\nPosted Aug 5, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 1:38 PM\n\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on Aug. 5, 2006)\nEven if Palm Beach money manager Jeffrey Epstein didn't\nknow that girls who police say gave him sexual massages at\nhis Intracoastal home were under the legal age, that alone\nwouldn't have exempted him from criminal charges of\nsexual activity with minors.\n'Ignorance is not a valid defenseao\n1S )Delde, a legal\nskills professor who was a Lake City prosecutor for nearly\n30 years, half of that time speci$zing in sex crimes against\nchildren.\n\"There is no knowledge element as far as the age is\nconcerned,\" Deke said.\nAfter ant?-44ionth investigation, Palm Beach police said\nthere was probable cause to charge Epstein, 53, with\nunlawful sex acts with a minor and lewd and lascivious\nmolestation. They contend that Epstein - friend of the rich\nand famous and financial patron of Democratic Party\norganizations and candidates - committed those acts with\nfive underage girls.\nIn the past week, New York Attorney General and\ngubernatorial candidate Eliot Spitzer has returned about\n$50,000 in campaign contributions he received from\nEpstein, and Mark\na candidate to replace Spitzer in\n\nEFTA02734186\n\n\f", "char_count": 1338}, {"efta_number": "EFTA02734027", "page_number": 160, "text_content": "his current job, has returned $10,000 to him because of the\nPalm Beach scandal, the New York Daily News has\nreported.\nRather than file charges, the state attorney's office\npresented the case to a county grand jury. The panel\nindicted Epstein last week on a single, less serious charge of\nfelony solicitation of prostitution.\nThe case raised eyebrows because the state attorney's office\nrarely, if ever, kicks such charges to a grand jury. And it\n\n,\n\nincreases the difficulty of prosecuting child sex abuse casesfl\nespecially when the defendant is enormously wealthy a\ncan hire high-priced, top-tier lawyers.\n)\nAt least one of Epstein's alleged victims told police he knew\nshe was underage when the two of them got naked for\nmassages and sexual activity. She was 16 years old at the\ntime and said Epstein asked her questions about her high\nschool, according to police reports.\nA girl who said she met Ea\nwhen she was 15 said he\ntold her if she told anybody what happened at his house,\nbad things co d hair, the police reports state.\nEpstein's youngest alleged victim was 14 when she says she\ngave him a massage that included some sexual activity. She\nis now 16. The girl's father says he doesn't know whether\n\nc\n\nshe told Epstein her age.\n\n+\n\n\"My daughter has kept a lot of what happened from me\nbecause of sheer embarrassment,\" he said. \"But she very\nmuch looked 14. Any prudent man would have had second\nthoughts about that.\"\nDefense attorney Jack Goldberger maintains that not only\ndid Epstein pass a polygraph test showing he did not know\nthe girls were minors, but their stories weren't credible.\nThe state attorney's office also implied that their credibility\nwas an issue when it decided not to charge Epstein directly,\nbut instead give the case to the grand jury.\nEFTA02734187\n\n\f", "char_count": 1786}, {"efta_number": "EFTA02734027", "page_number": 161, "text_content": "\"A prosecutor has to look at it in a much broader fashion,\" a\nstate attorney's spokesman said last week.\n\nIL ;(- *:!(11tr.' elRIF\n\n11\n\n;.;\n\nCO\n\nEpstein hired Harvard law Professor AlanOshowitz\nwhen he became aware he was under investigation, and\nDershowitz gave prosecutors information that some of the\nalleged victims had spoke of using alcohol and marijuana on\na popular Web site, according to a Palm Beach police\nreport.\nProsecutors typically consider two things in deciding\nwhether to charge somebody with sex-related offenses\nagainst minors - whether there is sufficient evidence and\nwhether there is a public interest in doing so, Dekle said.\nIf two teens are in a sexual relationship and the boy turns\n18 before the girl, he could be charged with a sex crime if\nthe sex continues. There would be no public interest in\npursuing that, Dekle said.\nBut where there is a large gap in ages - and especially in\ncases of teachers with students - there is a public interest in\nprosecuting, he said. Likewise if the accused has a track\nrecord of sex with minors.\n\nEFTA02734188\n\n\f", "char_count": 1076}, {"efta_number": "EFTA02734027", "page_number": 162, "text_content": "Still there is a \"universal constant\" in prosecuting these\ncases, Dekle said. Men who exploit underage children for\nsex often carefully choose their victims in ways that will\nminimize the risk to them, he said.\nVictims usually are from a lower social status, and they may\nsuffer from psychological problems, Dekle said.\n\"Lots of child sexual abuse victims have been victimized by\nmultiple people over a period of time. Then the act of abuse\nproduces behavior in the victims that further damages their\ncredibility.\" Examples include promiscuous behavior and\ndrug abuse.\nSome of the alleged victims in the Epstein case returned to\nhis home multiple times for the massage sessions and the\n$200 to $300 he typically paid them per visit. \"That would\nbe a definite problem for the prosecutor,\" said Betty Resch,\nwho prosecuted crimes against children in Palm Beach\nCounty for five years and ngw tat private practice in Lake\nWorth.\n\"The victim becomg le sympathetic\" to a jury, Resch said.\n\"But she's a victim nevertheless. She's a kid.\"\nMost men charged with sex crimes against minors look\nnormal, Dekle said. A jury expecting to see a monster\nseldom will. And the victims' ages work against them and in\nor of the defendant in a trial, Dekle said.\nIf a child and an adult tell different stories and both swear\nthey're telling the truth, adult jurors are more likely to\nbelieve the adult, Dekle said.\n\"You have all these things working against you in a child\nsex abuse case. Prosecutors normally try to be very careful\nin filing those cases because they know what they're getting\ninto. There is no such thing as an iron-clad child sexual\nabuse case.\"\n\nEFTA02734189\n\n\f", "char_count": 1660}, {"efta_number": "EFTA02734027", "page_number": 163, "text_content": "The Palm Beach Post\nREAL NEWS STARTS PERE\n\nEpstein camp calls female accusers\nliars\nPosted Aug 8, 2006 at 12:01 AM\nUpdated Oct 3, 2019 at 3:35 PM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on Aug. 8, 2006)\nAttorneys and publicists for Palm Beach financier Jeffrey\nEpstein went on the offensive Monday, contending that\nteenage girls who have accused Epstein of sexual\nshenanigans at his waterfront home are lis tii\nand saying\nthat the Palm Beach Police Departmenc g\"c\niQ dish.\"\n\"There never was any sex betweeay\n\npstein and any\n\nunderage women,\" his lead\n\ntorney,Jack Goldberger, said\n\nfrom Idaho where he wa\n\ntioning with his family.\n\nEpstein did have\nhim massages, GO1\n\nmen come to his house to give\nrger said. \"Mr. Epstein absolutely\n\ninsisted anybody who came to his house be over the age of\n18. How he verified that, I don't know. The question is, did\nan ,,, hing illegal occur. The law was not violated here.\"\nha no explanation as to why Epstein would pay girls or\nmen with no massage training - as the alleged victims\nsaid was the case - $200 to $300 for their visits. \"The\ncredibility of these witnesses has been seriously\nquestioned,\" Goldberger said.\nEpstein, 53, was indicted by a county grand jury last month\non a charge of felony solicitation of prostitution. After an\n11-month investigation that included sifting through\nEpstein's trash and surveilling his home, Palm Beach police\nconcluded there was enough evidence to charge him with\nsexual activity with minors. When the grand jury indicted\n\nEFTA02734190\n\n\f", "char_count": 1551}, {"efta_number": "EFTA02734027", "page_number": 164, "text_content": "Epstein on the less serious charge, Police Chief Michael\nReiter referred the case to the FBI to determine whether\nthere were federal law violations.\nAfter a spate of stories about the case last week, New York\npublicist Dan Klores - whose client list has included Paris\nHilton and Jennifer\n\n- said on Saturday that Epstein's\n\ncamp was ready \"to get their story out.\"\nThey did that Monday via Goldberger and a Los Angeles\npublicist for Miami criminal defense attorney Roy Black,\nwho also has represented Epstein in the case.\n\"We just think there has been a distorted view of t\nin the media presented by the Palm Beach police,\nGoldberger said.\nReiter has consistently declined to commint,,\n\nthe case\n\nand did not respond to a request for comment Monday.\n\nThe implication that State Attorney Barry Krischer was\neasy on Epstein by presenting the case to a grand jury\nrather than filing charges directly against him is wrong,\nGoldberger said.\n\nEFTA02734191\n\n\f", "char_count": 953}, {"efta_number": "EFTA02734027", "page_number": 165, "text_content": "The Palm Beach Police Department was \"happy and\necstatic\" that the panel was going to review the evidence. \"I\nthink what happened is they weren't happy with the result.\nThey decided to use the press to embarrass Mr. Epstein.\"\nBut records show that Reiter wrote Krischer on May I well before the case went to the grand jury - suggesting that\nKrischer \"consider if good and sufficient reason exists to\nrequire your disqualification from the prosecution of these\ncases.\"\nRather than flat-out decline to charge Epstein, Krischer „S\nreferred the case to the grand jury to \"appease\" the chi0 ,\nGoldberger said.\nA state attorney's spokesman would say o\n\ne office\n\nrefers cases to the grand jury when ther\n\nwith the\n\nviability of the evidence or witnesses' credibility.\nBoth the state attorney and the grand jury concluded there\nwas not sufficient evidence that Epa\n\nhad sex with\n\nminors, according to Goldberger. \"It was just a childish\nperformance by the Palm Beach Police Department,\"\nGoldberger said.\nThe defense attorney said one of the alleged victims who\nclaimed she was a minor was in fact over the age of 18.\nAnother alleged victim who was subpoenaed to testify to\nthe grand jury failed to do so. Epstein's accusers, he added,\nhave histories of drug abuse and thefts. \"These women are\nliars. We've established that.\"\nBut why would they all invent their stories about meeting\nEpstein for sexual massages?\n\"I don't have an answer as to what was the motivation for\nthese women to come forward and make these allegations,\"\nGoldberger said.\n\nEFTA02734192\n\n\f", "char_count": 1553}, {"efta_number": "EFTA02734027", "page_number": 166, "text_content": "Newsi)al..:ery\n?\n\nThe Pah Beach Post ( '4051 Pen Beach, Florida) • 10 Aug 21:06. Mon • Pa. 7\n\n*mesa\n\nDerenial aCril on III:iv I I.2111S\n\n.\nPalm Beach chief kips\nof fire in Epstein case\nMWJMY\n\nL1\n4\n.=.\".51,,trht\namfisifrret\n\"'AI:\n\n. 21\n\n4\n\n4\n\n11•11antlaft\n\n-Si\n\n441\"\n.. 11\nri • ni:M.\n.1.14,.\nswan\n• sar\ner\naslela • ass. oll.1=\nitessara Susi\nOnset:ewe&\nIasi\nlab aSalbli•wer\n\nmai\nsatsW•ISIda\nha. Qin RC\nla\ntt\nal in:\n%e\nl I SS\nItIar\nSista\nloss IS Ss\nMao* INT thy es lee\nk• • va•\n\nPC\nisstrapol=\n:\nAt\nsola\nail To\ntubas\nII\naralSbelintleisla\nSA( a\nThri\nine. by lel Sinai\nbasks\n▪\nontrasaf\nWs Slatted ffr Pt MSS Ps\niiIM\n•••••••••Ms•SeIll.1•4\ndamn\nDna\nPIN It,.\nOde\n%WC a sa.\nSSW..\nZ I•\nfta. /takes\ninn .1i4S0Plal\nb\nin ~ant\n.\nla is\nABS NM est\n\n&in tine thr In• Ina\n\nr\n\nMal*\n\nUthra\nlIst\n\nMit\n\n4a=\n\nUn\nMf\nSs\n\na.\n\nsr b.ltt/\npal\nc.kc\niff ith\nasirsIS)46.\nSOO*\nOtt\nteeihnl\nI\nas\nalb\nYON Mie Ito efsail•Ir•\nWO. trine Minn\n\nc\n\nIre\ncal.\ntit\n01•1 a ma wit4Pes eon\n\n=\nte\na\nSao gas\nblIrt\naw\nw or4.•.•\nba\nPria\npro\nllar\nau der\nsh it*\nsis• awls'\nbrawl vat\nwin Maws Swot Po\n*\nmil 'Sr Sas\nEs, talks I.\nSe Yam\nIkaabeNst•.Inn/nse.)\nlassoad sno sla owls lass .1\nalsassalsl mikslf•Sia Solos\nMayes\nAin Lin\nk • Inn\nYf SISI Ws HIS MS !ass es\nIon\neel awl SA• S, Feess\n•\nrdltaslaIS\n\n.\n\nZs:est\nssaallsal\nIS sass\n1:;;;;W\nm•\n- I LIZ\nSelsl\n*Ste\notIls Pada...sir\nassla I. INN lir ...MS\nel\ntat lasses\nsill\nas\nAt\nWas Weis feetA.S•s•\nspan,n\nwan Et SS/a*\nUST ss\nPalallsa\n0 -pn ,\nless sults. • tarn\nsenses\nOSIZZAS\nNil% II vovhk.\notasa‘vls•IIP\nsow\"\n\nis, tn...\nsssia•\n\n1.00/4\nviestra\n\nYw\nas is\n\nrald d\nnail, Soros\nSin its\nsale. St oar sir\nSI•lausnsarferfilall bra..\ng.M.WMYIwwllk.s\n!St le sea\ny./. ...nal\ntat ist:\ngogotaSsas• IclooS IS ars,.\nyrs Yawns NM\n•Ist••••W\nfrmovisadast * IlasISSIse M\nw SSW Min Iii.Sont\nWIlitt Pim Mita%\nwry ICalierb Veiatri Sat\nPOssisswls.\nIll Sas/.\nInse•los•\nIs\nsi\n;la\nisisaisemak.\nIpsItrs.\nlen\ntielanald e.\nnsall•\nlevnIst\n,\nntssl aka'sSat\n%IN\nsand, gzr4\nIS mesa. sew\nWas s ar se\ntalval.s/\n•••••Ilw•\nIs ass saw\nbt1 ~VIEW ID\n\n... [truncated, 2207 chars — for the full page use /api/corpus/document/EFTA02734027/166 or ?id=EFTA02734027&page=166]", "char_count": 2207}, {"efta_number": "EFTA02734027", "page_number": 167, "text_content": "The Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nDelays in Epstein case unusual,\nlawyers say\nPosted Mar 13, 2007 at 12:01 AM\nUpdated Oct 3, 2019 at 3:48 PM\n\n(EDITORS NOTE: This story originally published in The Palm\nBeach Post March 13, 2007)\nA federal probe or a plea deal could explain the wait in theAS\n\n,\n\nPalm Beacher's solicitation case.\nNearly eight months after Palm Beach tycoornisffrec\nC\nEpstein was charged with felony solicitation of prostitution,\nthere has been no discernible progress in his case. No\nwitnesses deposed. No trial date set. Nothing, save for\nroutine court hearings reset\n? c 'ttt\n,.. i explanation.\n\"Usually that would beilhusu , said criminal defense\nattorney Glenn\ncase.\n\neNvho has no involvement in the\n\n\"As a general rule, it would be unusual for nothing to have\nhappened,' ag.\n\nMichael Dutko, a criminal defense\n\nattorney in Fort Lauderdale. He represents\n20, of\nPalm Beach, potentially a key witness in the\ncase.\n\nA routine hearing for Epstein was pulled from the court\ndocket last week and reset for May 16. The delays and\ninaction could be due to a potential federal probe of Epstein\nor because a plea deal is in the works, attorneys say.\nUnusual is the word that best describes everything about\nthe case against Epstein, 54, an enigmatic money manager\nin New York City who counts Bill Clinton and Donald\nTrump among his friends.\n\nEFTA02734194\n\n\f", "char_count": 1376}, {"efta_number": "EFTA02734027", "page_number": 168, "text_content": "\"Highly unusual\" is how Palm Beach Police Chief Michael\nReiter described State Attorney Barry Krischer's handling\nof the case in a bluntly critical letter to Krischer last year\nbefore Epstein was indicted.\nReiter referred the matter to the FBI to determine whether\nany federal laws had been violated. Epstein's allies\ncountered by attacking the chief personally and\nprofessionally.\nReiter's department investigated Epstein for 11 months.\nPolice sifted repeatedly through his trash and conducted\nsurveillance on his five-bedroom, 7 1/2-bath, 7,234-s\nfoot home on the Intracoastal Waterway.\nPolice said Epstein paid women and girls as young as 14 to\ngive him erotic massages at his home. Police thought there\nwas probable cause to charge him with unlawful sex acts\nwith a minor and lewd and lascivious molestation.\nEpstein responded by hiring a phalanx of lawyers. One of\nthem, Harvard law professor and author Alan Dershowitz,\nprovided the state attorney's office with information about\nalcohol and marijuana use by some of the girls who said\nthey were with Epstein.\nProsecutors then referred the case to the grand jury rather\nthat\n+\n\ncharges directly against Epstein.\n\n( lis\nEp tein's attorneys deny he had sex with underage girls.\nThe lawyers say the girls' stories are not credible. But if the\ncourt file is any indicator, they've made no effort to depose\nthe girls.\n\nNeither prosecutors nor defense attorneys have sought to\nquestion\n\n, said Dutko, her attorney. She recruited\n\nteenage girls to visit Epstein for massages and sexual\nactivity, Palm Beach police said, and presumably would be a\nkey witness.\n\nEFTA02734195\n\n\f", "char_count": 1624}, {"efta_number": "EFTA02734027", "page_number": 169, "text_content": "Epstein's attorney Jack Goldberger did not return phone\nmessages.\nA source close to the case suggested it is languishing\npending a decision by the FBI on whether to refer it to\nfederal prosecutors.\n\"We still have a pending case,\" FBI spokeswoman Judy\nOrihuela said Monday.\nState Attorney Krischer did not return a call for comment.\nHis spokesman, Mike Edmondson, declined to say whether\nfederal investigators are delaying the Epstein case. But, he\nadded, \"if another agency is looking at something, we\nwouldn't want to step on their toes.\"\nAttorneys say inertia in a criminal case often points to a\npending plea deal.\n\"It would not surprise me if some\n\nas happened that's\n\nnot reflected in the court file,\" said Dutko, such as an\nagreement that will be foi$lized later.\nDefense attorney Marc Shiner said defense attorneys\nsometimes put off overtly conducting discovery -- deposing\nwitnesses, requesting documents and the like -- because\ndoing so creates more work for harried prosecutors who\nmay\\ become angry and not offer a plea deal.\nt\n\n,..÷\n\netimes defense lawyers, knowing that, will try and do\n\n, discovery without taking depositions: said Shiner, a former\nprosecutor for 13 years.\nInstead, they may conduct a below-the-radar probe such as\nhaving a private investigator check out leads, he said.\nShiner and others say a plea deal for Epstein probably\nwould result in pretrial intervention, in which a defendant\nmay be ordered to undergo a psychological evaluation,\ncounseling or other conditions in return for dropping the\ncharge.\nEFTA02734196\n\n\f", "char_count": 1552}, {"efta_number": "EFTA02734027", "page_number": 170, "text_content": "Edmondson, spokesman for State Attorney Krischer, said\nthere is no plea offer and no request for the prosecution to\nshow its cards.\n\"To my knowledge, it's never happened before on a filed\ncase,\" he said.\n\nEFTA02734197\n\n\f", "char_count": 220}, {"efta_number": "EFTA02734027", "page_number": 171, "text_content": "252 / 278 - Thursday, October 18, 2007\nEdition: FINAL\nSection: LOCAL\nPage: 5B\nSource: The Associated Press\nIllustration: PHOTO (B&W)\nMemo: Ran all editions.\nDateline: NEW YORK\nWOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN.SUE WAS 16\nA billionaire investor, already facing jail in Palm Beach County on charges of +tL 'ngUnderage\nwas 16 and had\nprostitutes, is being sued by a young woman who says he had sex with her\nsought his help becoming a model.\nThe lawsuit, filed late Tuesday in Manhattan's state Supreme Court, sa\nJeffrey Epstein had\nthe teen perform a sex act when she brought photographs of herself for m review in his Upper\nEast Side mansion sometime in 2000.\nictoria's Secret and \"could get\nEpstein, 54, a money manager, told the teen he managed fin\nyou into the catalog\" if she were \"nice\" to him, court pape\npapers say being \"nice\"\nincluded massages and other favors.\nodel,\" he replied, \"Don't worry, I\nWhen the girl told Epstein, \"I am 16 years old and ju wart\nanybody,\"\ncourt\npapers\nsay.\nwon't tell\nend of England's Prince Andrew, has been\nEpstein, said by London's Mail on Sunday to\nindicted in Palm Beach on charges of solici\ne prostitutes. That case is pending.\nI months and engaged in bizarre and unnatural\nThe girl visited Epstein \"several times ov\nsex acts\" while she was a minor, the lavituit s ys.\nEpstein \"repeatedly requested that\ngirl) return with her 14-, 15-, and 16-year-old girlfriends,\nstating, 'Come by with your fries your age next time. Don't bring Sherrie (a mutual friend in her\n40s). I love girls your age.' \"\nreturning to Epstein because she has \"mental issues,\" said her\nThe young woman, now 23,\nsed to elaborate, but court papers say she was \"disabled as a result\nlawyer, William J. UnroO. H\nof severe mental disease and d ect.\"\nEpstein's lawyer in New\nk, Gerald Lefcourt, said, \"The girl has admitted she is insane, but she can\nread a newspaperiand recognize the word 'rich.'\"\nLefcourt also said the statute of limitations has expired for the woman'\n... [truncated, 2586 chars — for the full page use /api/corpus/document/EFTA02734027/171 or ?id=EFTA02734027&page=171]", "char_count": 2586}, {"efta_number": "EFTA02734027", "page_number": 172, "text_content": "Beach\nThe Palm\nPost\nREAL NEWS STARTS 161E\nPalm Beacher pleads in sex case\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 3, 2019 at 1:47 PM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on July 1, 2008)\nJeffrey Epstein will serve 1 1/2 years on teen solicitation\ncharges.\nHe lives in a Palm Beach waterfront mansion and has kept\ncompany with the likes of President Clinton, Prince\nAndrew and Donald Trump, but investment banker Jeffrey\nEpstein will call the Palm Beach CounwVil home for the\nnext 18 months.\n\n•\n\nEpstein, 55, pleaded guilty Motty\n\nfelony solicitation of\n\nprostitution and procuring a person under the age of 18 for\nprostitution. After serving 18 months in jail, he will be\nunder house arrest for a year. And he will have a lifelong\nobligation to register as a sex offender. He must submit to\nan HIV test within 48 hours, with the results being\nprovided to his victims or their parents.\nAs pan of the plea deal, federal investigators agreed to drop\ntheir investigation of Epstein, which they had taken to a\ngrand jury, two law enforcement sources said.\nEpstein was indicted two years ago after an 11-month\ninvestigation by Palm Beach police. They received a\ncomplaint from a relative of a 14-year-old girl who had\ngiven Epstein a naked massage at his five-bedroom, 7,234square-foot, $8.5 million Intracoastal home.\nPolice concluded that there were several other girls brought\nin 2004 and 2005 to an upstairs room at the home for\nsimilar massages and sexual touching.\nEFTA02734199\n\n\f", "char_count": 1517}, {"efta_number": "EFTA02734027", "page_number": 173, "text_content": "The indictment charged Epstein only with felony\nsolicitation of prostitution. The state attorney's office later\nadded the charge of procuring underage girls for that\npurpose.\nProsecutor Lanna Belohlavek said of the plea: \"I took into\nconsideration the length the trial would have been and\nwitnesses having to testify\" about sometimes embarrassing\nincidents.\nEpstein may have made a serious mistake soon after he was\ncharged. He rejected an offer to plead guilty to one count of\naggravated assault with intent to commit a felony,\naccording to police documents. He would have gotten five\nyears' probation, had no criminal record and not been a\nregistered sex offender, the documents in 'cate.,\nEpstein arrived in court Monday withC)ea§three\nattorneys. He wore a blue blazer, blue shirt, blue jeans and\nand gray sneakers. After Circuit Judge Deborah Dale\nPucillo accepted the plea, he was fingerprinted. Epstein\nthen removed his blazer and was handcuffed for the trip to\njail while his attorneys tried to shield him from\nphotographe tlens4./\nWhen he eventually is released to house arrest, Epstein will\nhave to observe a 10 p.m. to 6 a.m. curfew, have no\nunsupervised contact with anyone younger than 18 and\nneither own nor possess pornographic or sexual materials\n\"that are relevant to your deviant behavior: the judge said.\nEpstein will be allowed to leave home for work. The New\nYork-based money manager told the judge he has formed\nthe not-for-profit Florida Science Foundation to finance\nscientific research. \"I'm there every day,\" Epstein said.\nThe foundation was incorporated in November. Epstein\nsaid he already has awarded money to Harvard and MIT.\n\nEFTA02734200\n\n\f", "char_count": 1671}, {"efta_number": "EFTA02734027", "page_number": 174, "text_content": "When he is released from jail, there is a chance that Epstein\nwill be forced to move. Sex offenders are not allowed to live\nwithin 1,000 feet of a school, park or other areas where\nchildren may gather. No determination has been made as to\nwhether Epstein's home complies, but attorneys said it\nlikely does.\nSex offenders also typically must attend counseling sessions.\nBelohlavek said that was waived for Epstein because his\nprivate psychiatrist is working with him. The judge was\nskeptical but agreed to it.\nEpstein's legal woes don't end with Monday's plea. There\nare four pending federal civil lawsuits and one in state court\nrelated to his behavior. At least one woman has sued him in\nNew York, where he owns a 51,000-squar, fodManhattan\nmansion.\n\"It's validation of what we're sayiain\n'Si e civil cases,\" said\nMiami attorney Jeffrey Herman, who represents the alleged\nvictims in the federal lawsuits. West Palm Beach attorney\nTed Leopold represents one alleged victim in a civil suit in\nstate court. He said he anticipates amending that lawsuit to\nadd \"a few other clients\" as well.\nIn the criminal case, police went so far as to scour Epstein's\ntrash and conduct surveillance at Palm Beach International\nAirport, where they watched for his private jet so they\nwould know when he was in town. They concluded that\nEpstein paid girls $200 to $300 each after the massage\nsessions.\n\"I'm like a Heidi Fleiss,\"\n\nnow 22, told police\n\nabout her efforts in recruiting girls for Epstein.\nThere was probable cause to charge Epstein with unlawful\nsex acts with a minor and lewd and lascivious molestation,\npolice concluded.\n\nEFTA02734201\n\n\f", "char_count": 1633}, {"efta_number": "EFTA02734027", "page_number": 175, "text_content": "The state attorney's office said questions about the girls'\ncredibility led it to take the unprecedented step of\npresenting the evidence against Epstein to a grand jury,\nrather than directly charging him.\nPalm Beach Police Chief Michael Reiter was furious with\nState Attorney Barry Krischer, saying in a May 2006 letter\nthat the prosecutor should disqualify himself. \"I continue to\nfind your office's treatment of these cases highly unusual,\"\nhe wrote. He then asked for and got a federal investigation.\nEpstein hired a phalanx of high-priced lawyers - including\nHarvard law professor and author Alan Dershowitz public relations people who questioned Reiter's cod!)\nand the victims' truthfulness.\nIn addition to mansions in Palm Beach and Manhattan,\nEpstein owns homes in New Mexico and the Virgin Islands.\nHe's a frequent contributor to Democratic Party candidates.\nto licrvard in 2003.\nHe also donated $30 millio \\,..,\nFormer New York Gonliot pitzer returned a $50,000\ncampaign contribution from Epstein after his indictment,\nthen resigned this year during his own sex scandal. And the\nsame Palm Beach Police Department that vigorously\ninvestigated Epstein returned his $90,000 donation for the\npurchase of a firearms simulator.\nStaff writer Eliot Kleinberg and former staff researcher\nMichelle Quigley contributed to this story.\n\nEFTA02734202\n\n\f", "char_count": 1348}, {"efta_number": "EFTA02734027", "page_number": 176, "text_content": "The Palm\nBeach\nPost\nREAL I€WS STARTS HERE\nJeffrey Epstein: Scientist,\nstuntman, `sex slave' visit jailed\ntycoon\nBy LARRY\n\n/ Palm Beach Post Staff Writer\n\nPosted Aug 13, 2008 at 12:01 AM\nUpdated Jul 16, 2019 at 4:54 PM\n\nTycoon Jeffrey Epstein mingled with an eclectic mix of\npeople, including beautiful young women, before he\ninto trouble for paying teenage girls to give him sexu\nmassages at his Palm Beach mansion.\nNot much has changed, even though he now resides in a\ndorm at the Palm Beach County Sheriffs Office's I7-acre,\n967-bed stockade near the fairgrounds.\nDuring his first month of confinement, Epstein was visited\nby the female assistant who, girls told police, had escorted\nthem to the room at his mansion where they gave him\nnaked massages.\nAlso trekking to the jail was a young woman whom Epstein\npurportedly described as his Yugoslavian sex slave.\nThe wealthy financier and science wonk also has been\nvisited by an expert on artificial intelligence, as well as a\nman who is a mixed martial arts aficionado and sometime\nmovie stuntman.\nThe only other people to visit him at the jail, according to\nrecords, are a\nIsland man and an individual who\nlisted Epstein's Palm Beach address as his own.\nEpstein, 55, pleaded guilty on June 30 to two prostitutionrelated charges and was sentenced to 18 months in jail,\nfollowed by a year of house arrest. Epstein paid teenage\n\nEFTA02734203\n\n\f", "char_count": 1394}, {"efta_number": "EFTA02734027", "page_number": 177, "text_content": "girls $200 to $300 in 2004 and 2005 for massages in his\nhome that sometimes included sexual touching, Palm Beach\npolice said.\nHis jail visitors in July included:\n\nIMM 29, who some of the teen masseuses said\nphoned them when Epstein was in town and escorted them\nupon their arrival at his Palm Beach waterfront home to an\nupstairs room, where she prepared the massage table and\nprovided the oils for their encounters with him.\nvisited Epstein three times in July, according to a jail\nvisitor's log.\n\nlists a Manhattan home address.\n\nReached by telephone, she declined to discuss Epstein.\n23, whose family in Yugoslavia\nEpstein paid money to so that he could bring her to the\nUnited States to be his \"sex slave,\" two teenage girls told\npolice. One girl told police that Epstein instructed\nand her to kiss and have sex while he watched\nand masturbated. Another said she engaged in sex with\nat Epstein's urging.\n\nvisited Epstein\n\nin jail four times in 13 days. She lists her address as on the\nUpper East side of Manhattan, not far from Epstein's\nenormous apartment.\n- Roger Schank, 62, founder of the Institute for Learning\nSciences at Northwestern University and an expert on\nartificial intelligence, paid one visit to Epstein. Schank has\nwritten numerous books on that subject and has a doctorate\ndegree from Yale University in linguistics. He was one of 19\npeople who applied to be president of Florida Atlantic\nUniversity in 2003. He became \"chief learning officer\" at the\nonline Trump University in 2005. Schank listed his address\nas being in Stuart, and records show he also owns a home\nin Lake Worth.\n\nEFTA02734204\n\n\f", "char_count": 1620}, {"efta_number": "EFTA02734027", "page_number": 178, "text_content": "Epstein has financed a number of scientists over the years,\nincluding Nobel Prize winners. He gave $30 million to\nHarvard University in 2003. In November, he formed the\nnot-for-profit Florida Science Foundation, which he said\nfinances scientific research.\n- Igor Zinoviev, a Russian mixed martial arts fighter, who\ncoaches a Chicago team in the International Fight League.\nHe also has worked as a personal trainer, celebrity\nbodyguard and movie stuntman, according to the league's\nWeb site. The New Jersey resident visited Epstein seven\ntimes in July.\ncould not be reached for\n\nZinoviev, Schank and\ncomment.\n\nStaff researcher Niels Heimeriks contribut\n\nis story.\n\n?S'\"\n\nO\n\nEFTA02734205\n\n\f", "char_count": 688}, {"efta_number": "EFTA02734027", "page_number": 179, "text_content": "Palm Beach Daily News\nBillionaire sex offender leaves jail\nsix days a week for work\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 4, 2019 at 9:27 AM\nPalm Beach billionaire Jeffrey Epstein, who's serving 18\n\nmonths in jail for soliciting an underage girl for\nprostitution, is allowed to leave the Palm Beach County\nStockade six days a week on a work-release program. O\nTeri Barbera, spokeswoman for the Palm Beach Gouty\nSheriffs Office, confirmed that Epstein, 55, has been in the\nwork-release program since Oct. 10.\n\"He works six days a week: Friday through Wednesday 10\na.m. to 10 p.m.,\" Barbera said via e-mail. \"(He) works at his\nlocal West Palm Beach office, monitored on an active GPS\nsystem (he wears an ankle bracelet). Mr. Epstein hires a\npermit deputy, at his expense, for his own security at his\nworkplace during the7time he is out.\"\nMiami attorney Jeffrey Herman represents six young\nwomen who've sued Epstein, claiming he sexually abused\ntheiV his Palm Beach home when they were minors.\nrtnan said he received a letter about the work-release\nprogram from the U.S. Attorney's Office within the past\nfew days. But Herman says Epstein had been out on workrelease for several weeks before the notification.\n\n\"My clients expressed shock and disappointment,\" Herman\nsaid. \"I find it incredible that he's on work-release in the\ncommunity and my clients aren't notified of this and we get\nthis letter weeks after the fact.\"\nJack Goldberger, Epstein's criminal attorney, said the\nEFTA02734206\n\n\f", "char_count": 1495}, {"efta_number": "EFTA02734027", "page_number": 180, "text_content": "arrangement is not unusual.\n\"He goes to work every single day and goes back to jail at\nnight, just like everybody else (in the program),\"\nGoldberger said.\nEpstein pleaded guilty June 30 to two felony counts:\nsoliciting prostitution and procuring a person under 18 for\nprostitution. As part of the plea agreement, Epstein must\nserve one year of house arrest and register as a lifelong sex\noffender.\n\nEFTA02734207\n\n\f", "char_count": 414}, {"efta_number": "EFTA02734027", "page_number": 181, "text_content": "The Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nWomen want Epstein sex plea deal\nunsealed\nPosted Jul 1, 2008 at 12:01 AM\nUpdated Oct 2, 2019 al 2:23 PM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post June 10, 2009)\nTheir attorneys will ask a judge to open Jeffrey Epstei\nrecords.\nWhen wealthy money manager Jeffrey Epstein of Palm\nBeach pleaded guilty last year to procuring teens for\nprostitution, his case detoured around local and state rules\nell5s.\nregarding the sealing of court d\nAt a plea conference on t\n\n\\\n\n14/\nto charges, a judge, a defense\n\nlawyer and a prosecutor huddled at the bench and decided\nthat a deal Epstein had struck with federal prosecutors to\navoid charges( houldpe sealed, according to a transcript of\nthe hearing.\nAnd-so iltctir\nBut Florida rules of judicial administration, as well as rules\nof the Palm Beach County court system, require public\nnotification that a court document has been or will be\nsealed, meaning kept from public view. The rules also\nrequire a judge to find a significant reason to seal, such as\nprotecting a trade secret or a compelling government\ninterest.\nYet no notification or reason occurred in Epstein's case,\naccording to court records.\n\nEFTA02734208\n\n\f", "char_count": 1226}, {"efta_number": "EFTA02734027", "page_number": 182, "text_content": "Epstein's own attorneys, in federal filings, have referred to\nhis confidential deferred prosecution agreement with the\nU.S. attorney's office, struck in September 2007, as\n\"unprecedented\" and \"highly unusual.\" And it was \"a\nsignificant inducement\" for Epstein to accept the state's\ndeal, observed the state judge who accepted his plea,\nCounty Judge Deborah Dale Pucillo.\nEpstein now faces at least a dozen civil lawsuits in federal\nand state courts filed by young women who said they had\nsex with him and now are seeking damages.\nAttorneys for some of those women want his agreement\nwith federal prosecutors unsealed and will ask Circuit Judge\nJeffrey Colbath to do so today.\n\"It is against public policy for these documents to be have\nbeen sealed and hidden from public scrutiny. As a member\nof the public, E.W. has a right to have these documents\nunsealed: wrote former Circuit Judge Bill Berger, now in\nprivate practice and representing one of the women.\n\nThe Palm Beach Post also will ask Colbath to unseal the\nagreement. Post attorney Deanna Shullman will argue that\nthe public has a right to know the specifics of Epstein's deal.\nAccording to various media accounts, Epstein moved in\ncircles that included President Clinton, Donald Trump and\nPrince Andrew. \"International Moneyman of Mystery,\"\ndeclared a 2002 New York magazine profile of Epstein.\nEpstein, S6, is in the Palm Beach County Stockade, serving\nan 18-month sentence after pleading guilty nearly a year\nago to felony solicitation of prostitution and procuring\nteenagers for prostitution.\nHe is allowed out from 7 a.m. to 11 p.m., escorted by a\ndeputy, said Palm Beach County Sheriffs Office\nspokeswoman Teri Barbera.\n\nEFTA02734209\n\n\f", "char_count": 1700}, {"efta_number": "EFTA02734027", "page_number": 183, "text_content": "During a Palm Beach Police Department investigation, five\nvictims and 17 witnesses gave statements. They told of\nyoung women brought by his assistants to Epstein's\nmansion on El Brillo Way for massages and sexual activity,\nand then being paid afterward.\nAt Epstein's plea conference last year, his attorney, Jack\nGoldberger, and then-Assistant State Attorney Lanna\nBelohlavek approached Pucillo in a sidebar conference.\nPucillo, who had left the bench nine years earlier, was\nfilling in temporarily as a senior judge.\nAccording to a transcript, Goldberger told Pucillo that\nEpstein had entered a confidential agreement with the U.S.\nattorney's office in which federal prosecutors brokered not\npursuing charges against him if he pleaded guilty in state\ncourt. Pucillo then said she wanted a sealed copy of the\nagreement filed in his case, and Goldberger concurred that\nhe wanted it sealed. Belohlavek later signed off on it.\nThe Florida Supreme Court has expressed \"serious concern\"\nand launched an all-out inquiry into sealing procedures\nacross the state following media reports in 2006 of entire\ncases being sealed and disappearing from court records.\n\"The public's constitutional right of access to court records\nmust remain inviolate, and this court is fully committed to\nsafeguarding this right,\" justices wrote in their final report.\nEpstein's office on Tuesday referred any questions to\nGoldberger, who declined to comment. Pucillo also has\ndeclined to comment.\n\nEFTA02734210\n\n\f", "char_count": 1484}, {"efta_number": "EFTA02734027", "page_number": 184, "text_content": "The Palm\nBeach\nPost\nREAL NEWS SUMS MERE\nEpstein secret pact with Feds\nreveals \"highly unusual\" terms\nPosted Jun 10, 2009 at 12:01 AM\nUpdated Oct 4, 2019 at 9:23 AM\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on September 19, 2W9)\nA secret non-prosecution agreement multimillionaire\nfinancier Jeffrey Epstein struck with federal prosecutors is\nbeing called \"highly unusual\" by former federal prosecutors\nand downright outrageous by attorneys now repjesenting\nyoung women who serviced him.\nThe deal reveals that the FBI and tbSiS. Attorney's Office\ninvestigated him for several federal crimes, including\nengaging minors in commercial sex. The crimes are\npunishable by anywhere from 10 years to life in prison.\nBut federal prosecutors backed down and agreed to recall\ngrand jury subpoenas if Epstein pleaded guilty to\nprostitution-related felonies in state court, which he\nul 'mately did. He received an 18-month jail sentence, of\n\nd\n\nlueh he served 13 months.\ne U.S. Attorney's Office also agreed not to charge any of\n\nEpstein's possible co-conspirators:\n, Lesley Groff and\n\nThe deal was negotiated in part by heavyweight New York\ncriminal defense attorney Gerald Lefcourt.\nUnsealed on Friday after attorneys for some of Epstein's\nvictims and The Palm Beach Post sought its release, it offers\nthe first public look at the deal Epstein's high-powered legal\ncounsel brokered on his behalf.\n\nEFTA02734211\n\n\f", "char_count": 1429}, {"efta_number": "EFTA02734027", "page_number": 185, "text_content": "Mark\n\nof Stuart, a former federal prosecutor,\n\ndescribed the disparity in potential sentences as unusual,\nbut even more so a provision on attorney payment.\nThe first draft of the agreement in September 2007\nrequired that Epstein pay an attorney -- tapped by the U.S.\nAttorney's Office and approved by Epstein -- to represent\nsome of the victims. That attorney is prominent Miami\nlawyer Bob Josefsberg.\n,\n\nBut an addendum to the agreement signed the following\n\n4,..'\n\nmonth struck Epstein's duty to pay Josefsberg if he and the\nvictims did not accept settlements -- capped at $150,00O\nand instead pursued lawsuits.\nsaid it appears the government was trying to\nbalance the lesser sentence for Epstein with recovering\n$150,000 for each victim. I've never, ever seen anything\nlike that in my life,\" he said. \"It's highly unusual.\"\nThe deal does not say whether any victims were contacted\nor consulted before the deal was made.\nAttorney Brad Edwards of Fort Lauderdale, who represents\nthree of the young women, believes that none of the 30 to\n40 woman identified as victims in the federal investigation\nwere told ahead of time.\n\nsaid his clients received\n\nletters from the U.S. Attorney's Office months after the deal\n\nO\n\nsigned, assuring them Epstein would be prosecuted.\n\n'Never consulting the victims is probably the most\noutrageous aspect of it,\"\n\nsaid. \"It taught them that\n\nsomeone with money can buy his way out of anything. It's\noutrageous and embarrassing for United States Attorney's\nOffice and the State Attorney's Office.\"\nEpstein now faces many civil lawsuits filed by the women,\nwho are represented by a variety of attorneys. In many, the\nallegations are the same: that Epstein had a predilection for\nteenage girls, identified poor, vulnerable ones and used\nEFTA02734212\n\n\f", "char_count": 1782}, {"efta_number": "EFTA02734027", "page_number": 186, "text_content": "other young women to lure them to his Palm Beach\nmansion. They walked away with between $200 and\n$1,000.\nFormer Circuit Judge Bill Berger, also representing victims,\ncalled the agreement a \"sweetheart deal.\"\n\"Why was it so important for the government to make this\ndeal?\" Berger asked rhetorically. \"We have not yet had an\nhonest explanation by any public official as to why it was\nmade ... and why the victims were sold down the river.\"\nFormer federal prosecutor Ryon McCabe described th\nagreement as \"very unorthodox.\" Such agreements, h\nare usually reserved for corporations, not individuals.\n\"It's very, very rare. I've never seen or hea‘fNe\nprocedure that was set up here,\" said,It Gabg,who has no\ninvolvement in any Epstein litig\n\"He's essentially avoiding fecrecSprosecution because he\ncan afford to pay that many lawyers to help those victims\nreview their cases.... If a person has no money, he couldn't\nbe able to strike a deal like this and avoid federal\nprosecution.\"\nThe backroom deal with federal prosecutors is all the more\ninteresting in light of the legal powerhouses who have\nworked for Epstein, including Harvard professor Alan\nDershowitz and Bill Clinton investigator Kenneth Starr.\nLefcourt is a past president of the National Association of\nCriminal Defense Lawyers.\nEpstein's local defense attorney, Jack Goldberger, issued a\nstatement Friday saying he had fought the release of the\nsealed agreement to protect the third parties named there.\n\"Mr. Epstein has fully abided by all of its terms and\nconditions. He is looking forward to putting this difficult\nperiod in his life behind him. He is continuing his longstanding history of science philanthropy.\"\n\nEFTA02734213\n\n\f", "char_count": 1693}, {"efta_number": "EFTA02734027", "page_number": 187, "text_content": "The investigation triggered tensions between police and\nprosecutors, with then-Palm Beach Chief Michael Reiter\nsaying in a May 2006 letter to then-State Attorney Barry\nKrischer that the chief prosecutor should disqualify himself.\nI continue to find your office's treatment of these cases\nhighly unusual: Reiter wrote. He then asked for and got\nthe federal investigation that ended in the sealed deal.\n\"The Jeffrey Epstein matter was an experience of what a\nmany-million-dollar defense can accomplish,\" Reiter told\n\nAssc\n\nthe Palm Beach Daily News upon his retirement.\n\nEFTA02734214\n\n\f", "char_count": 584}, {"efta_number": "EFTA02734027", "page_number": 188, "text_content": "187 / 278 - Wednesday, January 27, 2010\nEdition: FINAL\nSection: LOCAL & BUSINESS\nPage: 3B\nSource: By JANE MUSGRAVE Palm Beach Post Staff Writer\nDateline: WEST PALM BEACH\nJUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS\nIn a decision that could spark a constitutional showdown over privacy righ\nTuesday gave lawyers representing multimillionaire sex offender Jeffrey\nTm the right to\nsubpoena abortion records from women who are seeking millions in\nm the parttime Palm Beach resident.\nPalm Beach County Circuit Judge Donald Hafele said the records uld elp Epstein rebut\nthe women's claims that they suffered psychological ills afte9sing\nto give him\nsexually-charged massages at his Palm Beach mansion when they were as young as 14.\nHafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,\nhe said, can't be sought until the women are asked whether they have ever had an abortion,\nhow many and where. Further, he said, the recor\nould not be made public and might not\nbe admissible during trial.\nBut, he said, since the women claim Epste'\nis responsible for their emotional\ndistress, his attorneys can explore the imp\no er events. Medical records, Hafele said,\nare a better source of information tha\nnon memory.\nAttorney Louis Silver, who represe is\nidential Women's Health Center, a West Palm\nBeach clinic where abortions are,\nric warned Hafele that he was stepping on shaky\nconstitutional grounds.\n\"These records are protected b\nonstitutional right of privacy,\" he said, referring to the\nFlorida Constitution.\nAfter the hearing, Silver\nappeal won't be necessary until Epstein attorneys seek the\nrecords.\nIn another ruli\nesday, Hafele also said that videos from depositions in the state cases\ncan't be rel\n'th • t a court order. The ruling came after Epstein attorney Robert Critton\ncomplain\nideo of Epstein being asked whether he had an \"egg-shaped\" penis\nbecam\n.com sensation. It first appeared on The Palm Beach Post Web site.\nCritton b ed attorney Sp\n... [truncated, 2490 chars — for the full page use /api/corpus/document/EFTA02734027/188 or ?id=EFTA02734027&page=188]", "char_count": 2490}, {"efta_number": "EFTA02734027", "page_number": 189, "text_content": "The Palm\nBeach\nPost\nRIAL NEWSSTARTS IRE\nEpstein Journal's Findings Could\nResurrect Case\nBy Jane Musgrave\nPosted Sep 17, 2019 at 12:01 AM\nUpdated Oct 1, 2019 at 10:51 AM\n\n(EDITOR'S NOTE: This story originally published in The\nPalm Beach Post on March 20, 2010)\nA purloined journal that is said to contain the names\n\"hundreds\" of victims of convicted sex offender Jeffrey I\nEpstein could be used to reopen the investigation into the\nmulti-millionaire's appetite for teenage girls, an. attorney\nrepresenting seven of the victims said Friday.\nNew details about the contents of the journal were released\nthis week when Alfredo Rodriguez, who worked as a\nproperty manager for the Palm Beach resident, pleaded\nguilty to obstruction of justice for lying to federal agents\nwhen asked if he had any information about his former\nboss' criminal activity. He later tried to sell the journal he\nstole from Epstein for $50,000 to an unidentified person,\nwho alerted authorities, according to court records.\n\nA÷\n\npart of the plea agreement, federal prosecutors said the\nurnal \"contains information material to the Epstein\ninvestigation, including the names of material witnesses\nand additional victims.\"\n\"Had the items been produced in response to the inquiries\nof state or federal authorities ... the materials would have\nbeen presented to the federal grand jury,\" federal\nprosecutors wrote.\n\nEFTA02734216\n\n\f", "char_count": 1393}, {"efta_number": "EFTA02734027", "page_number": 190, "text_content": "Instead, prosecutors short-circuited the grand jury\ninvestigation and cut a deal with Epstein. They agreed not\nto pursue federal charges if he didn't contest prostitutionrelated felonies in state court. The money manager pleaded\nguilty in July 2008 to procuring a minor for prostitution\nand soliciting prostitution. He served 13 months of an 18month sentence.\nAttorney Adam Horowitz, who represents seven of the\nroughly 18 women who have filed civil suits against\nEpstein, said the new information could trump the socalled non-prosecution agreement.\nThe multifaceted agreement, he said, deals only with a\nspecific list of victims that the U.S. Attorney's Office knew\nabout when it penned the deal in 2007. If additional victims\nare listed in the journal Rodriguez stoitch\nHorowitz said\nfederal prosecutors could reopen t til‘t' v tigation.\n\"It opens the door for furth\n? s ItS\n, s , tion,\" he said.\nIn addition to turning\n\ne journal to federal agents,\n\nRodriguez told them he\n\new his former boss was having\n\nsex with underage girls when he worked for him in 2004\nand 2005. He had seen naked girls, who looked like minors,\nin the pool of Epstein's $8.6 million mansion. He had seen\npc ttographic images of young girls on Epstein's computer,\nording to court records.\n\nNeither Epstein's criminal defense attorney, Jack\nGoldberger, nor attorney Robert Critton, who represents\nEpstein in the civil lawsuits, could be reached. Federal\nprosecutors have consistently declined comment.\nThe wording of the controversial agreement is unclear. It\nsays federal prosecutors would provide Epstein's attorneys\n\"with a list of individuals whom it has identified as victims.\"\nMiami attorney Robert Josefsberg was appointed to\n\nEFTA02734217\n\n\f", "char_count": 1724}, {"efta_number": "EFTA02734027", "page_number": 191, "text_content": "represent any of the victims on the list who wanted to\npursue Epstein in civil court. As part of the agreement,\nEpstein is to pay for Joscfsberg to represent the women.\nSome of the women, most identified as Jane Doe in\nlawsuits, had already hired attorneys to represent them.\nSome have since settled their suits with Epstein, although\nterms were not disclosed.\nHorowitz said he has filed court papers to get the journal\nthat Rodriguez stole. \"It's another piece of evidence that\nshows our clients were at Epstein's mansion,\" he said.\nRodriguez told prosecutors he didn't turn over the jodrnai\nwhen both FBI and Palm Beach police asked for it because\nhe wanted money for it. He also said he was afraid Epstein\nwould make him \"disappear.\" The information, he told\ninvestigators, was his \"insurance policy.\"\nHe faces a maximum 20 years itkcton when he is\nsentenced on June 18.\njane_musgrave@p\n@pbpcourts\n\nEFTA02734218\n\n\f", "char_count": 917}, {"efta_number": "EFTA02734027", "page_number": 192, "text_content": "The Palm\nBeach\nPost\nREAL NEWS STARTS HERE\nEpstein paid three women $5.5 million to end underagesex lawsuits\nBy Jane Musgrave\nPosted Oct 3, 2017 at 12:01 AM\nUpdated Oct 4, 2017 at 12:46 AM\nEnding years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young\nwomen who claimed he used them as sex toys, court documents filed last week show he shelled\nout $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.\nResponding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the\nsex scandal, attorney\nsaid the politically-connected 64-year-old convicted sex\noffender paid more than $1 million to each of the three women\n\nrepresented.\n\nIdentified in court papers only by their initials or pseudonyms because of the nature of the\nallegations and their youthful ages, L.M. was paid $1 million, E.W. $2 million and Jane Doe\n$2.5 million,\n\nsaid of the se ern, he negotiated with Epstein to end the lawsuits.\n\nf'14\n/\nJack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on\nthe revelations, citing confidentiality agreements that were part of the settlements. For the\nsame reason, he declined to say whether Epstein paid similar amounts to settle roughly two\ndozen lawsuits filed by other young women against Epstein, claiming he paid them for sex\nwhen some were as young as 14 years old.\nAttorney Jack Scarola, who is representing\n\n, said his client was compelled to divulge\n\nthe confidential settlements to answer questions posed by Epstein's attorneys. \"Brilliant move\non their part,\" he said.\nEven if Epstein's attorneys hadn't opened the door, Scarola said the information would have\nlikely come out. He says the information will help him undermine Epstein's claims that\n\"ginned up\" the allegations to help his former law partner, imprisoned and disbarred\nFort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.\n\nEFTA02734219\n\n\f", "char_count": 1964}, {"efta_number": "EFTA02734027", "page_number": 193, "text_content": "The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute\nbetween Epstein and Rothstein, both billionaires.\nA year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a\nminor for prostitution, he sued Rothstein and\n, claiming they trumped up the\nallegations of sexual molestation to perpetuate the Ponzi scheme.\nRothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly\nsuccessful law firm by forging the names of federal judges and others to persuade investors he\nhad negotiated settlements in lawsuits against high-profile people. Investors were told they\ncould get a cut of the cash.\nOne of the high-profile people Rothstein used to lure investors was Epstein, according to a\nlawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the\nlawsuit, Rothstein told investors Epstein, a money manager, had ag.\n\nto settle the lawsuits\n\nwith the teens for $200 million — a claim Critton described as \"a complete fabrication.\"\naccused\nAfter Epstein dropped the lawsuit in 2012, Edwards turned the tables on him.\nEpstein of filing the lawsuit maliciously to punish him for representing the young women.\nAlthough •\nno evidence\n\nwas a partner in Rothstein's now defunct firm, Scarola claims Epstein had\nwas involved in the Ponzi scheme. Federal prosecutors successfully\n\ncharged other attorneys and members of the firm, but\nsaid in the malicious prosecution lawsuit.\n\nwas never implicated, Scarola\n\nThe revelations about the money Epstein paid to three of the young woman came last week in\ndocuments filed for aVring Tuesday in preparation for a December trial on the lawsuit.\n\nAttorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the\ntrial, in part, because she claimed she has been unable to talk to her client since his estate on his\nprivate island in the U.S. Virgin Islands was devastated last month by Hurricane Irma. \"I've had\nno abil\n... [truncated, 2063 chars — for the full page use /api/corpus/document/EFTA02734027/193 or ?id=EFTA02734027&page=193]", "char_count": 2063}, {"efta_number": "EFTA02734027", "page_number": 194, "text_content": "Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge\nDonald Hafele rejected her request. While saying he didn't want to appear insensitive to those\nvictimized by the storm that hammered the Caribbean and roared through South Florida, he\nsaid Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.\nStill, Hafele gave Coleman extra time to respond to various motions that he will have to decide\nbefore the case goes to trial.\nDespite Scarola's insistence that\n\nhad nothing to do with Rothstein's Ponzilscheme,\n\nColeman said the evidence indicates otherwise. Why else would he try to depose Epstein's\nwell-known friends, such as now President Donald Trump, former President Bill Clinton and\nillusionist David Copperfield, she asked. He used the celebrities as a draw, she said.\n\"The Epstein cases were used to fleece money and defraud investor:1e said.\nEdward's malicious prosecution case has been difficult fdCb6'th des because both Epstein and\n\nillE have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked\nhis Fifth Amendment right against self-incrimination when questioned by Scarola.\nhas claimed that much of the information Epstein is seeking is protected by attorney-client\nprivilege.\nThe malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit\nagainst Epstein.\nalso is suing the U.S. attorney's office, claiming it violated\nthe federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with\nEpstein.\nOnly after federal prosecutors agreed to drop their investigation of Epstein, did he agree to\nplead guilty +prostitution charges in Palm Beach County Circuit Court. In federal court\nrecords, pi;seditors claim one of the key reasons they agreed to drop their case was Epstein's\nagreement to settle lawsuits filed against him by dozens of his underage victims.\n\nEFTA02734221\n\n\f", "char_count": 1936}, {"efta_number": "EFTA02734027", "page_number": 195, "text_content": "Palm Beach Daily News\nfudge rules feds' agreement with\nJeffrey Epstein pact violated teen\nvictims' rights\nBy Jane Musgrave\nPosted Sep 17, 2019 at 4:02 PM\nUpdated Oct 8, 2019 al 12:31 PM\n\n(EDITOR'S NOTE: This story originally published in The \"S e\nPaint Beach Post on February 22, 2019)\n\n0\neks\n\nFederal prosecutors violated the rights of Jeffrey\nteenage victims by failing to reveal they had dropped plans\nto prosecute the billionaire on dozens of federal charges in\nconnection with the girls' claims that he paid them for sex\nat his Palm Beach mansion, US. District Judge Kenneth\nMarra ruled on Thursday.\nIn a blistering 33-page ruling, Marra meticulously and\nmethodically detailed the numerous steps federal\nprosecutors took to hide the agreement from more than 40\nyoung women who claim Epstein paid them for sex when\nthe werts young as 14.\n\nA4\n\nIle the government spent untold hours negotiating the\nto s and implications of the NPA with Epstein's attorneys,\nscant information was shared with the victims,\" Marra\nwrote. \"Instead, the victims were told to be 'patient' while\nthe investigation proceeded.\"\nBy then, it was too late. A deal had already been cut with\nthen-South Florida U.S. Attorney Alex Acosta and Epstein's\nattorneys to shelve a 52-page federal indictment against\nEpstein, a former math teacher turned money manager\nwho counts Presidents Donald Trump and Bill Clinton\namong his friends.\n\nEFTA02734222\n\n\f", "char_count": 1419}, {"efta_number": "EFTA02734027", "page_number": 196, "text_content": "Prosecutors' failure to alert the young women about the\ndeal violated the Crime Victims' Rights Act, Marra ruled.\n\"At a bare minimum the (act) required the government to\ninform (the young women) that it intended to enter into an\nagreement not to prosecute Epstein,\" he wrote.\nStill, Marra said he wasn't second-guessing prosecutors'\ndecision not to pursue Epstein on federal charges if he\npleaded guilty to minor state prostitution charges and\nagreed to compensate his victims for the trauma he caused.\ne\n\"The court is not ruling that the decision not to prosecuteS AA\n\n--\n\nwas improper,\" Marra wrote. \"The court is simply ru9fisi)\nthat, under the facts of this case, there was a violation `undef\nthe CVRA.\"\nFurther, he made no decision about what the remedy\nshould be. He gave prosecutors and attorneys representing\nthe young women 15 days to meet to decide how to unravel\nthe complex legal web that has been hanging over Epstein\nand his young victims for mote than a decade.\nThe chances an actiird\n\nI be reached are slim, said\n\nattorney Jack Scarola, who is representing the two Jane\nDoes who challenged the prosecutors' actions.\nFurther, he said, there is no road map to follow. The\nlawsuit attorney\n\nfiled on behalf of the two\n\nunidentified young women, claiming prosecutors violated\nthe federal act, is unique, he said.\n\"We are treading on virgin ground, to use what is probably\nan inappropriate phrase in this situation,\" he said.\nScarola said he and\n\nwill ask that the non-\n\nprosecution agreement be thrown out. That would open\nthe possibility that the long-shelved federal indictment\ncould be dusted off and filed against the 66-year-old\nEpstein, who spends most of his time on a private island he\nowns in the U.S. Virgin Islands.\n\nEFTA02734223\n\n\f", "char_count": 1755}, {"efta_number": "EFTA02734027", "page_number": 197, "text_content": "\"I don't see the government conceding to that remedy,\"\nScarola admitted. Further, he said, it is likely Epstein will be\nallowed to weigh in. Miami attorney Roy Black years ago\nfiled papers asking to intervene on Epstein's behalf.\nThe U.S. Attorney's Office said it wouldn't comment on\nMarra's ruling. Neither Black nor New York City attorney\nJay Letkowitz, who led efforts to bury the federal\nindictment, responded to emails or phone calls for\ncomment. West Palm Beach attorney Jack Goldberger, who\nrepresents Epstein, also didn't respond.\nScarola said it is likely Epstein's star-studded legal team will\nargue that Epstein fully complied with the terms of the\nagreement he made in 2007 with federal prosecutors and\ntherefore the agreement can't be undone.\nAs he promised, Epstein pleaded guilty in.! tine 2008 to state\ncharges of soliciting a minor for prostitution and soliciting\nprostitution. He served 13 months of an 18-month jail term\nin a vacant wing of the county stockade that he was allowed\nto leave 12 hours a da\nFurther, as agreed,\n\ndays week.\naid settlements to the young women\n\nwho sued him. While the settlements were confidential,\ncourt records show he paid three women a total of $5.5\nmillion.\n(\neturn, federal prosecutors held up their end of the\nbargain. Their investigation ceased.\nHaving done all that prosecutors asked of him, Scarola said\nEpstein will make a simple argument: \"You can't turn\naround and deprive me of the benefits I bargained for.\"\nHowever, Scarola said, using Marra's ruling, he will counter\nthat the contract Epstein signed was illegal and therefore\nunenforceable.\n\nEFTA02734224\n\n\f", "char_count": 1622}, {"efta_number": "EFTA02734027", "page_number": 198, "text_content": "Even if Marra agrees to toss out the non-prosecution\nagreement, Scarola conceded that doesn't mean Epstein will\nface federal charges.\n\"The contract can be set aside and the federal government\ncan attempt to enter into the same agreement,\" he said.\n\"Except the spotlight of public attention will be on them\nand the 40 victims will be able to explain to the court why\nthis sweetheart deal should not be approved.\"\nScarola said that prosecutors may have had good reason not\nto pursue Epstein. \"There may be a reasonable explanatio\nbut we don't know what that reason may have been,\" e\nsaid.\nIn court papers, federal prosecutors have said that many of\nthe young women were afraid to cross the powerful,\npolitically connected money manager and simply refused to\ntestify against him.\nIn other cases, they said, the women changed their stories.\nJane Doe 2, who is trying to have the non-prosecution\nagreement thrown out, initially described Epstein as \"an\nawesome\n\ntold prosecutors she hoped \"nothing\n\nhappens\" to him. Valle she later agreed to testify against\nEpstein, prosecutors said they feared Epstein's attorneys\nw uld use her words to destroy her if she ever took the\nstand.\n-Marra, however, said the young woman's comments didn't\nmean she wasn't entitled to know about the prosecutors'\nplans to drop the charges. \"There is no dispute that Epstein\nsexually abused Jane Doe 2 while she was a minor,\" he\nwrote. \"Therefore, regardless of her comments to the\nprosecutor, she was a victim.\"\nBefore the case is finally resolved, Scarola predicted that \"a\nlot of people are going to have to answer a lot of questions.\"\n\nEFTA02734225\n\n\f", "char_count": 1627}, {"efta_number": "EFTA02734027", "page_number": 199, "text_content": "In his ruling, Marra detailed what appeared to be a cozy\nrelationship between Acosta, his line prosecutors and\nEpstein's team of lawyers. His phalanx of lawyers included\nnoted Harvard law professor Alan Dershowitz and Kenneth\nStarr, the former U.S. solicitor general whose investigation\nled to the impeachment of President Clinton.\nMarra describes an October 2007 breakfast meeting\nbetween Acosta, who is now U.S. labor secretary, and\nLefkowitz shortly after the non-prosecution agreement was\ninked.\nAfter the meeting, Leflcowitz sent Acosta a note thanking\nhim for \"the commitment you made to me during our\nOctober 12 meeting in which you assured me that your\nOffice would not ... contact any of the identified\nindividuals, potential witnesses, or potential civil claimants\nand their respective counsel in this matter.\"\nMarra quoted an equally pleasant note then-Palm Beach\nCounty State Attorney Barry Krischer sent to Assistant U.S.\nAttorney\n\nVill\n\nEpstein's case. ,\"4/1\nreasons I won't put in\n\nho was the lead prosecutor in\nuld get this worked out for\nriting,\" Krischer wrote, shortly\n\nafter the non-prosecution agreement was signed. \"After this\nis resolved,I would love to buy you a cup at Starbucks and\n\nhka a conversation.\"\ny of the notes that were exchanged dealt with\nprosecutors' and Epstein's lawyers' shared desire to keep the\ndeal secret from Epstein's accusers. In a September email,\nVillafana asked Lefkowitz for guidance about what she\nshould reveal. \"And can we have a conference call to discuss\nwhat I may disclose to ... the girls regarding the\nAgreement,\" she asked.\n\nEFTA02734226\n\n\f", "char_count": 1602}, {"efta_number": "EFTA02734027", "page_number": 200, "text_content": "Such cooperation between prosecutors and defense\nattorneys is unusual, Marra said. \"It was a deviation from\nthe government's standard practice to negotiate with\ndefense counsel about the extent of crime victim\nnotifications,\" he wrote.\nFurther, he noted, that when\n\nand his two young\n\nclients asked for information, they were repeatedly misled.\n\"The CRVA was designed to protect victims' right and\nensure their involvement in the criminal justice process,\"\nMarra wrote. \"When the government gives information to\nvictims it cannot be misleading.\"\nUltimately, the terms of the non-prosecution agreement\nwere revealed only after\nand attorneys fari litg\npress successfully sued to make them pubt .\njmusgrave@pbpost.com\n@pbpcourts\n\ns)\n\nEFTA02734227\n\n\f", "char_count": 746}, {"efta_number": "EFTA02734027", "page_number": 201, "text_content": "76 / 278 - Tuesday, July 9, 2019\nEdition: Final\nSection: A Section\nPage: 1A\nSource: By Jane Musgrave, The Palm Beach Post\n\nEpstein indicted on sex charges\nPart-time Palm Beacher pleads not guilty to sex\ntrafficking, conspiracy charges in federal court in\nManhattan\nDressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on MC day pleaded not guilty\nto charges accusing him of creating a vast network of girls as young as 14 that he exploited\nfor his sexual pleasure at his homes in Palm Beach and Manhattan.\nThe 66-year-old money manager's appearance in U.S. District Court in New York City\ncapped more than a decade of recriminations by young women and their attorneys who\nclaimed Epstein used his money and political influence to avoid federal prosecution.\nEpstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking\ncharges as \"essentially a do-over\" of allegations that landed Epstein in the Palm Beach\nCounty Jail for 13 months more than a decade ago.\nIlowever, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to\nshelve a 53-page federal indictment after Epstein agreed to plead guilty to two state\nprostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is\nnow U.S. labor secretary.\n\"The alleged behavior shocks the conscience,\" New York City U.S. Attorney Geoffrey\nBerman said at a\nmorning news conference. \"And while the charged conduct is from a number of years ago, it\nis still profoundly important to many of the alleged victims, now young women. They\ndeserve their day in court.\"\nAt a detention hearing scheduled for Monday, Berman said he will ask a federal judge to\nkeep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to\ncommit sex trafficking. Epstein paid dozens of young women to give him nude massages\nthat, for most, led to sex, he said.\nIf convicted of exploi&gilozens of young women, including many Palm Beach County girls\nwho were students at =\n\n... [truncated, 2352 chars — for the full page use /api/corpus/document/EFTA02734027/201 or ?id=EFTA02734027&page=201]", "char_count": 2352}, {"efta_number": "EFTA02734027", "page_number": 202, "text_content": "\"We think he's a significant flight risk,\" Berman said of the man who ferried Britain's Prince\nAndrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former\nPresident Bill Clinton on his jet, dubbed the Lolita Express.\nBerman's hard-line stance was welcomed by young women who for years have been told that\nEpstein couldn't be touched because Acosta signed off on the nonprosecution agreement.\npromising not to charge Epstein in federal court.\nFormer Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning\nher into his sex slave and forcing her to have sex with others, including Dershowitz and\nPrince Andrew, praised Berman. He showed the case is \"being taken in a serious way,\" she\ntold the Associated Press. Dershowitz has vehemently denied Guiffre's claims.\nNew York prosecutors were able to ignore the controversial nonprosecutio\nCassell, who\nbecause it contained some significant fine print, said former federal Judge\nfor years has fought to get the agreement thrown out. It says only that no char could be\nfiled against Epstein in South Florida, he said.\nBerman agreed. \"That agreement only binds, by its terms, only ln s the Southern District of\nt agreement and\nFlorida,\" he said. \"The Southern District of New York is not\nwasn't a signatory of it.\"\nfor years are now part of\nThat means the sordid allegations that have been level\na federal indictment.\nContrary to Epstein's claims, he knew the women\nhis homes in New York and\n, according to the indictment.\nPalm Beach were minors because they told hi\n\\ 'Were \"vulnerable to exploitation,\"\nEpstein preyed on young girls because he\nprosecutors added.\nEp in or his associates would call girls while\nAs part of a carefully orchestrated sex\nhe was in New York so they would\ne for sex once he returned to Palm Beach, the\ned. They were identified only as \"Employee-1,\"\nindictment says. The employees\n\"Employee-2\" and \"Employ\nTo ensure he had a steady s\nyoung girls, Epstein would turn some victims into\n... [truncated, 3209 chars — for the full page use /api/corpus/document/EFTA02734027/202 or ?id=EFTA02734027&page=202]", "char_count": 3209}, {"efta_number": "EFTA02734027", "page_number": 203, "text_content": "U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime\nVictims' Rights Act by not telling Epstein's victims about the agreement before it was inked.\nCoincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight\nMonday, explaining what action Marra should take to redress that wrong.\nCassell insisted Epstein should face charges in federal court in West Palm Beach. \"Florida\nvictims deserve justice in Flori \" said Cassell, who is working on behalf of Epstein's\nvictims with attorneys\nand Jack Scarola.\nSince it's likely Florida women will get to testify against Epstein in New York, Scarola said\nhe's not focused on whether Epstein will face charges here. Instead, he said he wents to know\nhow and why the agreement was reached.\n\"There's been no explanation as to how a deal like this could have been cut\no\ne\nfederal government could have been involved in a conspiracy to violate fede law,\" Scarola\nsaid of his interest in continuing the legal battle over the nonprosecutio# a\nent.\nWhen Acosta agreed to drop the federal investigation, Epstein in 2\npleaddd guilty to two\nprostitution charges and served 13 months of an 18-month sentenc in a vacant wing of the\nPalm Beach County Jail - a cell he was allowed to leave 12 h\na\n, six days a week. He\nwas also forced to register as a sex offender and settle civi\nmore than 30 young\nwomen filed against him.\nU.S. Rep. Lois Frankel, El-West Palm Beach, said s s\ncarola's interest in finding out\nhow the agreement came to be.\"I am especially m\ned in why Epstein got the deal\nhe got,\" Frankel said. \"We need to know why\nsuch an easy sentence.\nWhile she has asked the Howe Oversight C\no investigate Acosta, Frankel said she\nis not sure that will happen. \"It just seems\nit as a travesty that this guy got off the\nway he did and, without pre-judging it, let's ha a proper court case,\" Frankel said.\nFormer Palm Beach Police Chief Michael Reiter was inflamed in 2006 when then-State\nAttorney Barry Krisch\n... [truncated, 3377 chars — for the full page use /api/corpus/document/EFTA02734027/203 or ?id=EFTA02734027&page=203]", "char_count": 3377}, {"efta_number": "EFTA02734027", "page_number": 204, "text_content": "\"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you,\"\nBerman said. A special number, 1-800-CALLFBI, will link victims of authorities.\nBill Sweeney, assistant director of the FBI's New York office, said after years of being\nignored by federal agents, the victims' voices will be heard.\n\"The Jeffrey Epstein matter is No. 1 on the major case list in the country,\" Sweeney said.\nTurning to address Epstein's victims directly, he said: \"Your bravery may empower others to\nspeak out against crimes against them.\"\njmusgrave@,pbpost.com\n\nEFTA02734231\n\n\f", "char_count": 582}, {"efta_number": "EFTA02734027", "page_number": 205, "text_content": "Def.Ex.A-5\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734232\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 206, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LW,\nPublisher of THE PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO: 2019-CA-014681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida, SHARON R. BOCK,\nas Clerk & Comptroller, Palm Beach County,\nFlorida,\nO ASIA\n\nDefendants.\n\n)\nDEFENDANT, DAVE ARONBERG, AS STATE ATTO\nFLORIDA'S ANSWER TO FIRST AM\nAND MOTION TO DIS\nDefendant, DAVE ARONBERG, as State\n\nM o I)alm Beach County, Florida, (\"SAO\"),\n\nby and through the undersigned attorney, he\nPlaintiff, CA Florida Holdings, LW, Pjr\n\nOF PALM BEACH COUNTY.\nOM PLAINT\nU11'f II\n\nCount I of the First Amended Complaint of\nit gf The Palm Beach Post (\"Post\"), and files a Motion\n\nto Dismiss Count II, as follows: C\nJURISDICTION\n1.\n\nAdmitted\n\nsdictional purposes.\nPARTIES\n\nBed.\nMed that Defendant Aronbcrg or the Office of the State Attomcy for the Fifteenth\nJudicial Circuit is in possession and/or control of documents that arc the subject of this action.\nOtherwise admitted.\n4.\n\nAdmitted.\nINTRODUCTION\n\n5.\n\nParagraph 5 contains the Post's statement of the case and legal arguments to which no\n\nEFTA02734233\n\n\f", "char_count": 1169}, {"efta_number": "EFTA02734027", "page_number": 207, "text_content": "response is required. To the extent that a response is required, the SAO is without knowledge or\ninformation sufficient to form a belief as to the truth of any factual allegations contained in paragraph\n5, and therefore denies the allegations and demands strict proof thereof.\n6.\n\nParagraph 6 contains the Post's statement of the case and legal arguments to which no\n\nresponse is required. To the extent that a response is required, the SAO admits only that section\n905.27(1)(c), Florida Statute authorizes the disclosure of grand jury proccedin\n\ncr certain\n\ncircumstances.\n7.\n\nParagraph 7 contains the Palm Beach Post's statement of\n\nlegal arguments\n\nto which no response is required. To the extent that a response is r t\n\nr , the SAO is without\n\nknowledge or information sufficient to fonn a belief as to the\nin paragraph 7, and therefore denies the allegations and\n8.\n\nParagraph 8 sets forth the Post's s\n\nisSi\n\nfactual allegations contained\nct proof thereof.\n\no the ease and legal arguments to which\n\nno response is required. To the extent that a r\n\nQnsclf required, the SAO is without knowledge or\n\ninfonnation sufficient to form a belief\n\nth of any factual allegations contained in paragraph\n\n8, and therefore denies the allcg 'ens\n9.\n\nAmands strict proof thereof.\n\nParagraph 8 setststeiti c Post's statement of the ease and legal arguments to which\n\nno response is required. T\n\nxtent that a response is required, the SAO is without knowledge or\n\ninfonnation suffi\n\nform a belief as to the truth of any factual allegations contained in paragraph\n\n9, and therefo d\n\nthe allegations and demands strict proof thereof.\nFACTUAL BACKGROUND\n\n10.\n\nThe SAO is without knowledge or information sufficient to fonn a belief as to the truth\n\nof any factual allegations contained in paragraph 10, and therefore denies the allegations and demands\nstrict proof thereof.\nA.\n\nFirst Epstein Sex Crimes investigation. Indictment, and Plea Agreement: 2005-2008.\n11.\n\nThe SAO is without knowledge or information suff\n... [truncated, 2058 chars — for the full page use /api/corpus/document/EFTA02734027/207 or ?id=EFTA02734027&page=207]", "char_count": 2058}, {"efta_number": "EFTA02734027", "page_number": 208, "text_content": "of any factual allegations contained in paragraph 11, and therefore denies the allegations and demands\nstrict proof thereof.\nP.\n\nThe SAO is without knowledge or infonnation sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 12, and therefore denies the allegations and demands\nstrict proof thereof.\n13.\n\nThe SAO is without knowledge or infonnation sufficient to fonn a bell\n\nof any factual allegations contained in paragraph 13, and therefore denies the alle\n\nto the truth\ns and demands\n\nstrict proof thereof.\n14.\n\nThe SAO is without knowledge or information suffrcient%oyh a belief as to the truth\n\nof any factual allegations contained in paragraph 14, and there\n\ns the allegations and demands\n\nstrict proof thereof\n15.\n\nThe SAO is without knowledge or info\n\nktion sufficient to form a beliefas to the truth\n\nof any factual allegations contained in paragraph 15, and therefore dcnics the allegations and demands\nstrict proof thcrcof.\n\n(1)\n\nPolice Chief Reiter's Letter to the State Attorney\n\n16.\n\nThe SAO is without knowledge or infonnation sufficient to form a beliefas to the truth\n\nof any factual allegations\n\ncd in paragraph 16, and therefore denies the allegations and demands\n\nstrict proof thereo\n17,\\\n\nAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any trt*TIcgations contained in paragraph 17, and therefore dcnics the allegations and demands\nstrict proof thereof\n(2)\n\nThe July 2006 State Grand Jury Presentation\n\n1g\n\nThe SAO is without knowledge or infonnation sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 18, and therefore denies the allegations and demands\nstrict proof thereof\n3\n\nEFTA02734235\n\n\f", "char_count": 1742}, {"efta_number": "EFTA02734027", "page_number": 209, "text_content": "19.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 19, and thcrcforc dcnics the allegations and demands\nstrict proof thereof.\n20.\n\nThe SA() is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 20, and thcrcforc denies the allegations and demands\nstrict proof thereof.\n21.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 21, and thcrcforc dcnics the al llegations and demands\nstrict proof thercof.\n22.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 22, and therefore denies the allegations and demands\n/\nstrict proof thereof.\n(3)\n\nThe FBI's Investigation and Epstein's Non-Prosecution Agreement with Federal\nAuthorities.\n\n23.\n\nThe SAO is without knowledge or infonnation sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 23, and thcrcforc dcnics the allegations and demands\nstrict proof thereof.\n24.\n\n_\n\nThe SAO is without knowledge or information sufficient to fonn a bclicf as to the truth\n\nof any factual c IrguiionS contained in paragraph 24, and therefore dcnics the allegations and demands\n...„\nIl\nstrict proof the/ -1.\"\n25. ,\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 25, and therefore denies the allegations and demands\nstrict proof thereof.\n26.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 26, and thcrcforc dcnics the allegations and demands\n4\n\nEFTA02734236\n\n\f", "char_count": 1863}, {"efta_number": "EFTA02734027", "page_number": 210, "text_content": "strict proof thereof.\n27.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 27, and thcrcforc dcnics the allegations and demands\nstrict proof thereof.\n28.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 28, and therefore denies the allegatigatnd demands\nstrict proof thereof.\n29.\n\nThe SAO is without knowledge or information sufficient t\n\nlief as to the truth\n\nof any factual allegations contained in paragraph 29, and therefore dcnic\n\npilcgations and demands\n\nstrict proof thcrcof..\n30.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 30, and therefore denies the allegations and demands\nstrict proof thereof.\n31.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 31, and thcrcforc dcnics the allegations and demands\nstrict proof thereof.\n(4)\n\nThe Crime Victims' Riehts Act Litieation.\n\n32.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 32, and thcrcforc denies the allegations and demands\nstrict proof thcreof.\n33.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 33, and thcrcforc dcnics the allegations and demands\nstrict proof thereof\n34.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 34, and therefore dcnics the allegations and demands\n5\n\nEFTA02734237\n\n\f", "char_count": 1804}, {"efta_number": "EFTA02734027", "page_number": 211, "text_content": "strict proof thereof.\n35.\n\nThe SAO is without knowledge or information sufficient to form a beliefas to the truth\n\nof any factual allegations contained in paragraph 35, and therefore denies the allegations and demands\nstrict proof thereof\n36.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 36, and therefore denies the allegatiat9iad demands\nstrict proof thereof\n37.\n\nThe SAO is without knowledge or information sufficient t\n\nlief as to the truth\n\nof any factual allegations contained in paragraph 37, and therefore dcnic\n\nc legations and demands\n\nstrict proof thereof.\nB.\n\nSecond Epstein Sex Crimes Investiaation, Indicunerd,,Suicide: 2019.\n38.\n\nAdmitted.\n\n39.\n\nThc SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in\n\ny\n\n9, and therefore dcnics the allegations and demands\n\nstrict proof thereof.\n40.\n\nThe SAO is witho\n\nof any factual allegations\n\n6wledge or infonnation sufficient to form a belief as to the truth\n\ncd in paragraph 40, and therefore denies the allegations and demands\n\nstrict proof thereo\n41,\\\n\nAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any titt erAlcgations contained in paragraph 41, and therefore dcnics the allegations and demands\nstrict proof thereof\n42.\n\nThc SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations contained in paragraph 42, and therefore denies the allegations and demands\nstrict proof thereof\n43.\n\nThc SAO is without knowledge or infonnation sufficient to form a belief as to the truth\n6\n\nEFTA02734238\n\n\f", "char_count": 1714}, {"efta_number": "EFTA02734027", "page_number": 212, "text_content": "of any factual allegations contained in paragraph 43, and therefore denies the allegations and demands\nstrict proof thereof.\n44.\nC.\n\nAdmitted.\n\nThe August 27, 2019, SDNY Hearing: Epstein's Victims Speak.\n45.\n\nThe SAO is without knowledge or infonnation sufficient to fonn a belief as to the\n\ntruth of any factual allegations contained in paragraph 44, and therefore denies the all\n\nitpns and\n\ndemands strict proof thereof\n46.\n\nAdmitted that United States Senior Judge Richard M. B\n\nred a hearing on\n\nAugust 27, 2019, but the SAO is without knowledge or information suffi\n\nform a bclicf as to the\n\ntruth of any remaining factual allegations contained in p\n\n3, and therefore dcnics the\n\nallegations and demands strict proof thereof.\n47.\n\nThe SAO is without knowledge or inf.:Callon sufficient to form a beliefas to the truth\n\nof any factual allegations contained in paragraph 47, and therefore dcnics the allegations and demands\nstrict proof thcrcof.\n48.\n\nThe SAO is without knowledge or information sufficient to form a belief as to the truth\n\nof any factual allegations containaianiParagraph 48, and therefore dcnics the allegations and demands\nstrict proof thereof.\n49.\n\nTItG SAO is without knowledge or infonnation sufficient to form a bclicf as to the truth\n\nof any fac\n\nI lialleg ons contained in paragraph 49, and thcrcforc denies the allegations and demands\n\nstrict pro f` crcol\n50.\n\nThe SAO is without knowledge or information sufficient to fonn a bclicf as to the truth\n\nof any factual allegations paragraph 50, and thcrcforc dcnics the allegations and demands strict proof\nthereof\n51.\n\nThe SAO is without knowledge or information sufficient to form a bclicf as to the truth\n\nof any factual allegations contained in paragraph 51, and therefore dcnics the allegations and demands\n7\n\nEFTA02734239\n\n\f", "char_count": 1805}, {"efta_number": "EFTA02734027", "page_number": 213, "text_content": "strict proof thereof.\nD.\n\nThe Palm Beach Post's Standina and the Public Interest.\nThe Palm Beach Post Has Reported Extensively On Epstein's Crimes For Nearly\n15 Years.\n52.\n\nAdmitted.\n\n53.\n\nAdmitted.\n\n54.\n\nAdmitted that the Post has extensively investigated and reported\n\nagainst, the law enforcement investigation of, and the crimes committed by Ep\nknowledge to admit or deny any factual allegations remaining in para\n\nthe\n\nlegations\n\nlacks sufficient\nd therefore denies\n\nthe allegations and demands strict proof thereof.\n55.\n\nThe SAO is without knowledge or infonnat\n\ntruth of any factual allegations contained in paragr ha5\ndemands strict proof thereof\n\nfli>l nt to form a belief as to the\ntherefore denies the allegations and\n\n(CW\\\n\n(2)\n\nThe Palm Beach Post's Stinvli\n\nd the Public Interest.\n\n56.\n\nParagraph 56 of the/ First Amended Complaint contains the Palm Beach Post's\n\nfri‘'\nstatement of the case and legal Urguments to which no response is required. To the extent that a\nresponse is required, the !Mc) admits the press has a constitutional right of access to criminal\nproceedings, but is If\\\nithout\n, knowledge or infonnation sufficient to fonn a belief as to the truth of any\nremaining f\n\nleg tions contained in paragraph 56, and therefore denies the allegations and\n\nof thereof.\n\ndemand\n57.\n\nParagraph 57 sets forth the Post's statement of the cast and legal arguments to which\n\nno response is required. To the extent that a response is required, the SAO is without knowledge or\ninfonnation sufficient to form a belief as to the truth of any factual allegations contained in paragraph\n57, and therefore denies the allegations and demands strict proof thereof.\n58.\n\nParagraph 58 sets forth the Post's statement of the case and legal arguments to which\n8\n\nEFTA02734240\n\n\f", "char_count": 1781}, {"efta_number": "EFTA02734027", "page_number": 214, "text_content": "no response is required. To the extent that a response is required, the SAO is without knowledge or\ninformation sufficient to form a belief as to the truth of any factual allegations contained in paragraph\n57, and therefore denies the allegations and demands strict proof thereof.\n59.\n\nParagraph 59 of the First Amended Complaint contains the Palm Beach Post's\n\nstatement of the case and legal arguments to which no response is required. To the extent that a\nresponse is required, the SAO admits that Fla. Stat. 905.27 allows a court to make tho d'eStermination\nof disclosure but is without knowledge or information sufficient to form a belief as to the truth of any\nremaining factual allegations contained in paragraph 59, and therefore denies the allegations and\ndemands strict proof thereof.\nE.\n\n14\n/\n\nThe Court's Jurisdiction and Authority.\n0)\n\nThe Court's Supervision of the Grand turriro,cess and Its Authority to Order\nPublic Disclosure of the Epstein Evidence.\n\n60.\n\nParagraph 60 of the First\n\nied Complaint contains the Palm Beach Post's\n\nstatement of the case and legal arguments to which no response is required. To the extent that a\nresponse is required, the SAO admits the press has a constitutional right of access to criminal\nproceedings, but is without knowledge or information sufficient to form a belief as to the truth of any\nremaining factual allegations contained in paragraph 60, and therefore denies the allegations and\ndemands strict proo thereof\n(\n61.\nit\nt Znitted.\n63.\n\nParagraph 63 sets forth the Post's statement of the cast and legal arguments to which\n\nno response is required. To the extent that a response is required, the SAO is without knowledge or\ninformation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph\n63, and therefore denies the allegations and demands strict proof thereof.\n64.\n\nParagraph 64 of the First Amended Complaint contains the Palm Beach Post's\n9\n\nEFTA02734241\n\n\f", "char_count": 1962}, {"efta_number": "EFTA02734027", "page_number": 215, "text_content": "statement of the case and legal arguments to which no response is required. To the extent that a\nresponse is required, the SAO is without knowledge or information sufficient to form a belief as to the\ntruth of any remaining factual allegations contained in paragraph 64, and therefore denies the\nallegations and demands strict proof thereof.\n(2)\n\nThe Court's Jurisdiction To Declare Rights And Construe Statutes.\n\n65.\n\nAdmitted.\n\n66.\n\nAdmitted.\n\n67.\n\nAdmitted.\n\n7\n\nCOUNT 1\n(Declaratory Relief- Florida Stat. Sectionsc)\nThe SAO reincorporates and re-alleges its\n\n68.\n\nr\n\nC C)\net seq.)\nto paragraphs I through\n\n67 above.\n69.\n\nAdmitted.\n\n70.\n\nParagraph 70 contains the\n\nAI 'S\" \\\n\nno response is required. To the ex\ninfonnation sufficient to form a\n70, and therefore denies th\n71.\n\nAdt\n\nt's s\nt\n\ntent of the case and legal arguments to which\n\npone is required, the SAO is without knowledge or\nthe truth of any factual allegations contained in paragraph\n\ncgations and demands strict proof thereof.\n\ntrThe Palm Beach Post is seeking a declaration from this Court but\n\ndenies the remainder of7Paragraph 71.\n\\\n\nAdmitted.\n\n73. Y Denied\n74.\n\nParagraph 74 contains the Post's legal arguments to which no response is required.\n\nTo the extent that a response is required, the SAO is without knowledge or information sufficient to\nform a belief as to the truth of any factual allegations contained in paragraph 74, and therefore denies\nthe allegations and demands strict proof thereof.\n10\n\nEFTA02734242\n\n\f", "char_count": 1491}, {"efta_number": "EFTA02734027", "page_number": 216, "text_content": "MOTION TO DISMISS COUNT 11\n(Florida Stat. Section 905.27)\nDefendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, pursuant\nto the Florida Rules of Civil Procedure 1.420, hereby files this Motion to Dismiss Count II of Plaintiff's\nFirst Amended Complaint for failure to state a cause of action, and in support thereof states:\nL\n\nStandard of Review\n\nWhen confronted with a motion to dismiss, the Court must determine wh\nas phrased within its four corners sufficiently states a cause of action, where\nFox v. Professional Wrecker Operations 801 So. 2d 175, 178 (Fla 5\ndismiss tests whether the plaintiff has stated a cause of action.\nFlorida Rule of Civil Procedure 1.140(b) is whether the pl\nin the Complaint to support his or her claim. See\n\ncr\n\nomplaint\nbe granted.\n\nI)CT1001). A motion to\nfor a motion to dismiss under\n\nu\n\nrove any set of facts as alleged\n\nbcco Inc. 89 So. 2d 482, 484 (Fla.\n\n1956)• Wasua Ins. Co. v. Haynes, 683 So. 2d 11\n\nDCA 1996).\n\nIn order to meet this test, \"a\n\nallege sufficient ultimate facts to show that a\n\npleader is entitled to relief.\" W.R. T\n\nontr... Inc. v. Jensen Civ. Constr.. Inc. 728 So. 2d 297,\n\n300 (Fla. 1st DCA 1999) (quot\nR. Civ. P. 1.110(b)). Th\n\nCosgrove 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla.\n\nurn need not accept internally inconsistent factual claims, conelusory\n\nallegations, unwar gtbd deaLvtions, or mere legal conclusions made by a party. a (citing Response\nOncology. Incrik trallcalth Insurance Co. 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Asset\nMont. v. Jahar ij 97 F.3d 1182, 1188 (11th Cir. 2002) (\"fOn a motion to dismiss,1 the plaintiff's\nfactual allegations arc accepted as true.... However, legal conclusions masquerading as facts will not\nprevent dismissal.\"). To avoid dismissal, a pleading \"must allege a cause of action recognized under\nlaw\" against the defending party. Kislak v. Krecdian, 95 So. 2d 510, 514 (Fla. 1957).\nIL\n\nArgument,\na.\n\nNeither Defendant Aronbere, nor the Office of the State Attorne\n... [truncated, 2106 chars — for the full page use /api/corpus/document/EFTA02734027/216 or ?id=EFTA02734027&page=216]", "char_count": 2106}, {"efta_number": "EFTA02734027", "page_number": 217, "text_content": "are the subject of this action.\nIt is significant to emphasize that despite Plaintiff's allegations to the contrary, Defendant\nAronberg and thc Office of the State Attorney for the Fifteenth Judicial Circuit arc not in custody or\ncontrol of the records sought herein, and therefore Defendant Aronberg is not a proper party to this\naction. In fact, Defendant, Sharon R. Bock, as Clerk and Comptroller of Palm Beach County, Florida,\nadmits that it is the custodian in possession of the documents that arc the subject of t\nb.\n\non.\n\nPlaintiff Fails to State a Cause of Action\n\nPlaintiff attempts to assert a causc of action, in the interest of \"fu\n\n\", under Florida\n\nStatute § 905.27; however, a review of the statute in question reveals thatt\nfor therein and consequently Count II of Plaintiff's First Ante\nmatter of law. Despite Plaintiff's extensive recitation\nEpstein and the testimony and evidence present\n\nsc of action is provided\n\nplaint must be dismissed as a\nal background regarding Jeffery\n\n\"k4 2006 grand jury in Palm Beach County,\n\nFlorida, Fla. Stat. § 905.27, merely explains\n\n\\ ccp ons to the disclosure of grand July testimony\n\nand does not set forth in any way a cau\n\nupon which to initiate a valid law suit.\n\nMoreover, a review of t\n\nissue clearly indicates that even if § 905.27, Ha. Stat.\n\nprovided a basis for a cause of a\n\nlaintiff is barred from access to the records it seeks. To wit, in\n\npertinent part, Fla. Stat. § 9\n! .N(2) states:\nt\nWhen sucK\nosurc is ordered by a court pursuant to subsection (1) for use in a civil\nscloscd to all parties to the case and to thcir attorneys and by thc latter\nassociates and employees. However, the zrand fury testiinonv afforded\nby the court can only be used in the defense orprosecution ofthe civil or\nma case andfor no other purpose whatsoever.\nHere, despite the clear statutory guidelines for disclosure of grand jury materials in a civil case,\nPlaintiff is improperly socking the requested 2006 grand jury materials for the purposes of p\n... [truncated, 2329 chars — for the full page use /api/corpus/document/EFTA02734027/217 or ?id=EFTA02734027&page=217]", "char_count": 2329}, {"efta_number": "EFTA02734027", "page_number": 218, "text_content": "prosecution of the civil or criminal case and for no other purposc whatsoever\", which is distinctly\ndifferent from Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla. Stat.\n4 905.27(2)..\nWHEREFORE, based on the foregoing argument and supporting authority, Defendant, DAVE\nARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this\nHonorable Court grant the instant Motion and dismiss Count II of Plaintiff's FirstAmc\nwith prejudice, and grant Defendant Aronbcrg all other and further relict dcc\n\nComplaint\nst and proper,\n\nincluding attorney's fees and costs for defending this frivolous action.\nCERTIFICATE OF SERVICE\nI HEREBY CERTIFY that on this 24th day of January\nelectronically filed with the Florida E-File Portal for e-se\\ *c\n4 \"ct\n\nS\n7\n\n0\n\nopy of the foregoing has been\n\nb panics of record herein.\nSCHOLZ & WYLER, LLC\n\n/Douglas A. Wyler\nArthur I.\nEsq.\nFla. Bar No.: 10249\nRichard J. Scholz, Esq.\nFla. Bar No.: 0021261\nDouglas A. Wylcr, Esq.\nFla. Bar No.: 119979\n961687 Gateway Blvd., Suite 201-I\nFernandina Beach, Florida 32034\n(904) 261-3693\n(904) 261-7879 Fax\nPrimary: jacobsscholzlaw@comeast.net\nGeneral Counselfor the Florida Prosecuting\nAttorney's Association\n\n13\n\nEFTA02734245\n\n\f", "char_count": 1257}, {"efta_number": "EFTA02734027", "page_number": 219, "text_content": "Def.Ex.A-6\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734246\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 220, "text_content": "COPY\n\n•\nh the Matter Of:\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n50-2019-CA-014681\n\nJ:HEA\nK.-sVo\n\n(sv\n\n0\n\n•\nESQUIRE\nDEPOSITION SOLUTIONS\n\nEFTA02734247\n\n\f", "char_count": 150}, {"efta_number": "EFTA02734027", "page_number": 221, "text_content": "o\n\n9\nEFTA02734248\n\n\f", "char_count": 20}, {"efta_number": "EFTA02734027", "page_number": 222, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\nJune 03, 2020\n1\n\nIN THE CIRCUIT COURT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCASE NO.:\n50-2019-CA-014681\nCIRCUIT CIVIL DIVISION: \"AG\"\n\nCA FLORIDA HOLDINGS LLC PUBLISHER\nOF THE PALM BEACH POST,\nPlaintiff/Petitioner\n-vs-\n\nDAVE ARONBERG,\nSHARON R. BOCK,\n\n<\n\n/\n\n<\n\nIC\n\nC4)D\n\nHEARING\n\nEF\n( :E\nii\nlq THE\n75r HONORABLE KRISTA MARX\n(ZOOM CONFERENCE)\n\nO\n\nlt. Wednesday, June 3, 2020\n10:08 a.m. - 10:28 a.m.\n\nREMOTE ZOOM CONFERENCE\nPort Saint Lucie, Florida\n\n•\n\nStenographically Reported By:\nSONJA M.\nCourt Reporter\n\nESQUIRE\nDIPOSITI0M SOLUTIONS\n\n800.211.DEPO (3376)\nEsquireSolutions.corn\n\nEFTA02734249\n\n\f", "char_count": 640}, {"efta_number": "EFTA02734027", "page_number": 223, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\nJune 03, 2020\n2\n\nAPPEARANCES:\n\n3\n4\n5\n6\n7\n8\n9\n10\n11\n\nOn behalf of the Plaintiff/Petitioner:\nGREENBERG TRAURIG, P.A.\n1840 Century Park East\nSuite 1900\nLos Angeles, California 90067\n310.586.7700\nboyajianOgtlaw.com\nBY: NINA D. BOYAJIAN, ESQUIRE\n4/A\n1\nOn behalf of the Defendant/Respondent:\nJACOB, SCHOLZ & WYLER, LLC\n961687 Gateway Boulevard\nSuite 2011\nFernandina Beach, Florida 3 s,/\n904.261.3693\n2 14A1(15:Yr\ndoug.wylerecomcast.net\nBY: DOUGLAS A. WYLER, E\n\n12\n13\n14\n15\n\nOn behalf of the Defends\nspondent:\nM BEACH COUNTY\nCLERK & COMPTROLL\nP.O. Box 229\nWest Palm Beac s Flo ida 33401\n561.355.2983\nnfingerhut\n•eachclerk.com\nBY: NICOLE,\nGERHUT, ESQUIRE\n\n16\n17\n18\n19\n20\n21\n22\n23\n24\n\n•\n\n25\n\ng ESQUIRE\nDIPOSITIO* SOWTIONS\n\n800.211.DEPO (3376)\nEsquireSolutions.com\n\nEFTA02734250\n\n\f", "char_count": 817}, {"efta_number": "EFTA02734027", "page_number": 224, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\nJune O3, 2020\n3\n\nPROCEEDINGS\n2\nWe are here today for a very\n\n3\n\nTHE COURT:\n\n4\n\nlimited purpose.\n\n5\n\nthat, but I just don't want there to be any\n\n6\n\nconfusion.\n\n7\n\nand Defendant Sharon Bock for the Comptroller and the\n\n8\n\nState Attorney's motion to dismiss Count II.\n\n9\n\nI'm sure the attorneys are aware of\n\nWe are here on Defendant Dave Aronberg\n\nYou're all acutely aware as the lawyers that\n\n10\n\nthis is a question of law.\n\nSo we're not going to be\n\n11\n\ndiving into facts and the Courtwill not be deciding\n\n12\n\nthe merits of this motion this morning.\n\n13\n\nsimply here for the sole purpose of that motion to\n\n14\n\ndismiss.\n\n15\n\nstay on track and ,we'ire all on that same page.\n\nWe are\n\n0\n\n16\n\n•\n\nSo I just wanted to make sure that we all\n\nSo, Ms. Boyagian, I'll send it to you first,\n\n17\n\ncourse, we all know that the Law 101,\n\n18\n\nI must Zook at the four corners of the motion, which\n\n19\n\nalleges that the State Attorney, David Aronberg, and\n\n20\n\nrk and comptroller, Sharon Bock, actually have\n\n21\n\ncustody and control of these grand jury proceeding.\n\n22\n\nWhether that is true or not is not for this\n\n23\n\ncourt to determine because I'm looking simply at the\n\n24\n\nfour corners of the complaint.\n\n25\n\nI think we all know that they don't have control and\n\nESQUIRE\n.\",\".v\"\n\nBut, not for nothing,\n\n800.211.DEPO (3376)\nEsquireSolutions. corn\n\nEFTA02734251\n\n\f", "char_count": 1398}, {"efta_number": "EFTA02734027", "page_number": 225, "text_content": "June 03, 2020\n4\n\nHEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\ncustody of the records.\n\nBut I'm going to assume that\n\n2\n\nit's correct because that's what has been alleged.\n\n3\n\nSo what I first want to hear from is the\n\n4\n\nattorney for Florida Holdings with regard to,\n\n5\n\nassuming arguendo, that Florida Statute 905.27 does\n\n6\n\ncreate a cause of action, what relief is it that\nyou're seeking from\n\nin Count II, specifi ally.\nWe're not here on t\n\n8\n\nNot the dec action.\n\n9\n\nwhat is it you hope to get, a judgmen\n\n10\n\nMS. BOYAGIAN:\n\nThank you, y\n\ntoday\n\nonor.\n\nGood\n\n11\n\nmorning, and thank you for thp4t1y lege of appearing\n\n12\n\nbefore this court.\n\n13\n\nThe relief we are Aing\n\nis disclosure of the\n\n14\n\ngrand jury records, pursuant to the Furtherance of\n\n15\n\nJustice Exception to 905.27.\n\n16\n\nAmendment.\n\n17\n\nAnd under the First\n\nThe press, as your Honor is aware, has a right\n\n18\n\nof access under the First Amendment as a surrogate of\n\n19\n\nthe public --\n\n20\n\nTHE COURT:\n\n21\n\nlike you to answer my specific question.\n\n22\n\nSo I am not particularly convinced -- and I'd\n\nLet me just stop you for a minute.\n\n23\n\nlike for you to address that.\n\n24\n\ndive into facts or the press's standing because\n\n25\n\nthat's not something we're here to discuss today.\n\nESQUIRE\n\nSo we're not going to\n\n800.211.DEPO (3376)\nEsquireSolutions.corn\n\nEFTA02734252\n\n\f", "char_count": 1334}, {"efta_number": "EFTA02734027", "page_number": 226, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\n•\n\nAnd I have read the voluminous paperwork -2\n\nI've received paperwork as -- and -- five-minute ago\n\n3\n\nfrom some of the other parties.\n\n4\n\nappreciate the fact that you sent this to me so much\n\n5\n\nin advance and I have been able to spend some time\n\n6\n\nwith, as I said, the voluminous paperwork th\n\n7\n\nprovided.\nBut as you know,\n\n8\n\nBut I deeply\n\n, we are h\n\nwas\n\nr such an\nheir motion\n\n9\n\nextremely limited issue today, and t\n\nt\n\n10\n\nto dismiss where they state \"you\n\nuing the wrong\n\n11\n\npeople\"; that the court has\n\n12\n\nAnd so, more importa\n\ne records.\ny\n\nwant you to address\n\n13\n\nwhether Section 905.27\n\n14\n\naction against the\n\n15\n\nAgain, I'\n\n16\n\nthat are asser\n\n17\n18\n\nnot -- beca\nI think we can all agree we're not for\nt r\nsure i\nhey ever -- that the state attorney doesn't\n\n19\n\nhave\n\n0\n\n20\n\n•\n\nJune 03, 2020\n5\n\nyou a private cause of\n\nte attorney and the clerk.\no assume the facts are true\nn the motion.\n\nWhether they are or\n\ns records. So what is it you're seeking in\n1\nI -- not the dec action. I know you want the\n\n21\n\nrecords.\n\nI've got that.\n\n22\n\nspecifically, what do you -- what's the relief you're\n\n23\n\nseeking and, more importantly, how under this statute\n\n24\n\ndo you get to assert a private action -- a private\n\n25\n\ncause of action against the state attorney and the\n\ng ESQUIRE\n\nBut in Count II,\n\n800.211.DEPO (3376)\nEsquireSolutions.com\n\nEFTA02734253\n\n\f", "char_count": 1415}, {"efta_number": "EFTA02734027", "page_number": 227, "text_content": "June 03, 2020\n6\n\nHEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n1\n2\n\nclerk?\nMS. BOYAGIAN:\n\nYour Honor, we are aware, of\n\n3\n\ncourse, that there is no expressed private right of\n\n4\n\naction, 905.27.\n\nBut that does not end the inquiry.\n\n5\n\nAs the Florida Supreme Court stated:\n\n6\n\n\"Where a statute like 905.27\n\n7\n\nforbids an act which is to Plaintiff'\n\n8\n\ninjury, the party injured should\n\n9\n\nan action.\"\n\n10\n\nAnd that's the\n\nPiezo\n\n11\n\nof materials that we sent you\n\n12\n\nThere's no question h\n\n13\n\nFIRST AMENDMENT right t\n\n14\n\ngives rise to a righ\n\n15\n\nStated anoth\n\n4\na i:\ne\nIt :)\n\namain the volume\n\nat the denial of the\nress is an injury which\nion.\n\na , looking at the analysis\n\n16\n\nthat the Fischer Mel calf Court looked at, there are\n\n17\n\nthree factoxq\n\nn determining whether there is a\n\n18\n\nprivate righr\n\nof\ny action where a statute does not\n\n19\n\nexpressly provide for one.\n\n20\n\nSie is whether the Plaintiff is part of the\n\n21\n\ncla s for which the statute is intended to protect;\n\n22\n\nsecond is a legislative history; and the third is the\n\n23\n\nunderlying purposes of the statutory scheme.\n\n24\n25\n\nThe first factor I already addressed, that the\npress is part of the class that the statute is\n\nESQUIRE\n\n80(1211.DEPO (3376)\nEsquireSolutions.corn\n\nEFTA02734254\n\n\f", "char_count": 1260}, {"efta_number": "EFTA02734027", "page_number": 228, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\n•\n\n1\n\nintended to benefit, being the surrogate of the\n\n2\n\npublic and exercising its first amendment right.\n\n3\n\n•\n\nThe second issue of legislative history and the\n\n4\n\npurpose -- statutory purpose are somewhat related.\n\n5\n\nWe were unable to find much legislative history on\n\n6\n\nthis issue of a private right of action under the\n\n7\n\nstatute.\n\n8\n\nThere is nothing that says we intend to create\n\n9\n\na private action, but there's certainly nothing that\n\n10\n\nsays we do not want to create a\n\n11\n\naction.\n\n12\n\n0\n\nJune 03, 2020\n7\n\ni\n\nto right of\n\ni$'1994, the same time\n\nWhat we do have is t\n\n13\n\nthat 905.27 was reenac\n\n14\n\nthe secrecy of Stat\n\n15\n\njuries was also enacted.\n\n16\n\n905.395, has no exceptions for -- for revealing these\n\n17\n\nrecords.\n\n18\n\nenacted 905.27 with the Furtherance of Justice\n\n19\n20\n\nException.\n‘i\nt)\nthe public through the press can't bring a\n\n21\n\nprivate right of action to enforce that exception or\n\n22\n\nto seek relief under that exception, that\n\n23\n\nintentionally placed exception of furthering justice\n\n24\n\nis essentially rendered hollow --\n\n25\n\nd,\n\nstatute that pertains to\n\nra d Jury -- statewide grand\nThat provision, which is\n\nBy contrast, the legislature intentionally\n\n(Speaking simultaneously.)\n\nESQUIRE\n\n800.211.DEPO (3376)\nEsquireSolutions. corn\n\nEFTA02734255\n\n\f", "char_count": 1337}, {"efta_number": "EFTA02734027", "page_number": 229, "text_content": "G仁二①。w 袖 8 。\n曲\n\n工\nm ＞刀乏＠\n。＞m 尸。卫。＞工。尸。－z ~⑦＜劭。＞<m ＞刃Ozmm 刃○\n}-』\n\n问~阖 8 c 为\n问\n＂\n\nto\n\n砌 的扣誉昌囤 什\n5剑\n＂ 吕⑦吖①\nH q。昌－什 ＂三口对 剑口＜50Q ＜ 一\n\n．\n闩万锄＂-~ 口。什 笔5 钞\n什 闩 - 三 锄 幻 否 墨 ＜ O仁\n\n卜\ni\n\ns ＜\n⑦ ⑦＂锄8 旨⑥’\n\n留\n① H 仂岂Q 行\nO爵 ① ~ ① s＜\n⑦\nO 、＜。c 吞。事 岂\n\nci,\nO、\n曲\n\nq①哧①昌q 山口什①咱\n\n喝～。℃①烤\n\n。锄＝仞①\n什河①\n\n。「\n\nD 尸①｝嘱尸＜\n\n钮。什HO 口‘\n\nd 料。。①Qc 州皿←\n\n⑤行〉什①\n\nd 。们＂仁膊H 口C\n\n吖＝①烤①\n\n尸---\n\nH砌\n．\n\nU -髓悯←①Q\n\n\"DH 晚 。 扣 盼 P 口～＝尸昌C\n\nOH\n\n「＝①\n\n州-三 呻 μ 烤 什 灯 ~、咐咐 啸－己①Q 5＜ 什5 ① 富\n\n尸昌 ＜O μ州 Q℃舀～v尸山俐宫\n\n－励\n\n什万〉什 ＜Oc ①尸H ①囵①\n\n尸山\n\nG 尸助＂尸＜U 山＜吕＞烤。郫6g妒「5 ① 仂\n一 扣忭① ＞什什。烤口①＜\n℃御州g 。\n\n尸令\n\nd~ 扣廿 丁①\n\nH闼\n\n5锄饥\n\n尸④\nN。\n\n~5 ①＜\n\n5 锄＜①\n\n洲\n什5 ①确⑦ 村 8绨烤Q 硷\n\n仂。 H -三\nH日 ~O 坤蜀食湘。轰仂韵G 身⑨ ＂5 扣 -伯 竹样广①・\n\\）朋\n．\n曲 QO 口-\" 5澎＜① ） 。）G ⑦\n① O咋 山。n O岂\n什①H 二 口 ⑥ ＜。\n\nf\n憋O尤逻－一①什-仂 惴G ° g 暴 2 H 什5 ① 毛黝＜\n闩\n弓\n山\nG\nm\nd 加仰磋 u\n口。＂\n\n如\n\n尸钩\n\n什河钮什\n\nmμ什\n\n尸幼\n一\n\n°＜\n。「\n\n锄什什。～口①＜.\n\n愉\n尸\nH尸\nQ \" ＜。＝ 开口。笔“\n\n－尸\n\n○\n\nH① 什\n5① O\nH ①畔犬 〉昌Q g ① 砌什〉什① 扣 g 。烤口⑦＜\n5。\n毛 〉\n\n舢⑦埘旨山 ＜O ＝\n、\n＂了巾\n\n闩-三\n\n剑\n\nl/J\n\n5扣\n＂ g ① ℃忖①幻砌 Q。①m 昌 言\n＝誉-廿 纠 。锄G 确\n④ O『 剑OgO 口 O飕 ＂\n\nw\n尸。\n\n蛋＝⑦① 一\nO 吖 锄 弓旨~①．\n\nO虿 ＜\n\n腩\n\n艳 < ＜。c ＆ 口 9口q < 8 圜①什 〕 」G8三③昌叶\n\n。口＂\n檐\n\n劭\n\n侣 岂 诋 ’ 什 辙 加什 扣什①\n\n木\n学\n叽\n＂\n酚\n5①\n\n劬 什什。烤口①＜\n\n砌二℃吧 。 们 ① Q\n\n旨＜\nu\n\n寸~溜佯加① 吕 ① 田\n尺 剑口Q\n\nN匐\n\n锄“g。a \"＜毛万扣什 现。①＜峦 帐 ＂O\n〖吻’\n\nm。＜步° >\nz\"\n\nQO\n\n笔一\n\n5\n\n一什咱\n\n工①\n\nO剑容-什\n\n工①豆m 口\n。\n\nq。 什5 〉肃．\n\n客①尸尸悔\n\n＜。＝枵 T。口。，\n\nH\n-O口 吓n- g ①弓幂韵\n一\n砼 锄 三O 什\n一\n\n柏．\n\n什冒一\n\n险仞\n\n①口d 一 尸①Q \"O Q一幻nO ＜\n~ 闩＜ 0昌 昌 ①\n\n腊履侣抚涸\n\n步畔。巳V ①尺圜．\n\nn①⑦g 乌\n。\n口\n＜\n・\n\nN尸\n\nN④\n\n＂。\n\nU 剑＜①\n\n韵时〉圜①－\n\n剑价 ＜。＝ 价什扣什①P\n\n脚口Q 笔巾 渺氏①\n\n一\nm 加G ① 。『\n\n℃。韵团①切巳0 昌\n、\n\n劬8’帕美・。m为O ＾镳刘●辛\nm8c吗\n气\n①\n⑦\ng\nc鼍。西吻．。。s\n\nEFTA02734256\n\n\f", "char_count": 1470}, {"efta_number": "EFTA02734027", "page_number": 230, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\n•\n\n1\n\ncustody, and control.\n\n2\n\nstate attorney has asserted that he does not have\n\n3\n\npossession.\n\n4\n\nhas taken that position.\n\n5\n\nthe -- someone who does have possession, custody, and\n\n6\n\ncontrol.\n\n7\n\n0\n\nMy understanding is that the\n\nIt's not my understanding that the clerk\nSo the clerk may indeed be\n\nIn any event, we would submit that t\n\ntate\n\n8\n\nattorney, even it does not have actua\n\n9\n\nthis time, it might be able to have t e power to\n\n10\n\ncontrol or direct the entity or\n\n•ns who do have\n\n11\n\ncontrol and possession to rele\n\nhose -- to effect\n\n12\n\nthe judgment.\nSo le\n\nme\n\nession at\n\n13\n\nTHE COURT:\n\n14\n\nclerk is the keeper\n\nthe record.\n\n15\n\ngot a judgment\n\nher -- let's say you asserted\n\n16\n\nthis cause of\n\n17\n\nget a judgmencagainst the clerk.\n\n18\n\nrelease grand jury testimony to you.\n\n19\n\ncan.\n\nsk you this:\n\nSo the\n\nBut even if you\n\nti n and let's say you win and you\nThe clerk cannot\nOnly the court\n\n20\n\nSo really -- all I'm saying to you is I do not\n\n21\n\nunderstand the way this case was filed or why these\n\n22\n\nare the defendants because it's impossible for them\n\n23\n\nto perform.\n\n24\n\ne\n\nJune 03, 2020\n9\n\n25\n\nI mean, I'm going to assume, based on your\nmotion, again, that they do have the records.\n\nESQUIRE\n\".0..\n\nBut we\n\n800.211.DEPO (3376)\nEsquireSolutions.corn\n\nEFTA02734257\n\n\f", "char_count": 1341}, {"efta_number": "EFTA02734027", "page_number": 231, "text_content": "June 03, 2020\n10\n\nHEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\nknow -- everyone in the room knows they do not --\n\n1\n\nall\n\n2\n\nthat only the court -- they're -- they're with a\n\n3\n\ncourt interpreting.\n\n4\n\nthe records.\n\n5\n\nyou get a judgment against either the\n,I,\nmean, I\nstate attorney or the clerk, they cannot -- ;44Iftsr\n\n6\n\nAnd only the court can release\n\nSo if\n\nguess what you're saying to me is, well, want\n8\n\ndo discovery and we want them to say\n\n9\n\nhave these records\" or \"I don't have\n\n10\n\nAnd -- I mean, the law is ab\n\n11\n\nYou cannot do it without a co\n\n12\n\nin the furtherance of just\n\n13\n\nappropriate.\n\n14\n\nto\n\nllr\ncally \"I\n\nntly clear.\nermining whether,\n\nhe release is\n\nAnd that is a determination\n\nMS. BOYAGIAN:\n\n15\n\nwe're asking your Honor to make, and we're asking for\n\n16\n\nan order from your court.\n\n17\n\nTHE COURT:\n\nWhen we get to the merits of the\n\n18\n\ncase, sure iC is.\n\n19\n\nmakethat determination and for me to make a\n\n20\n\ndeAormination of whether the grand jury records\n\n21\n\nsholald be released.\n\n22\n\ntoday about is why should the clerk and the state\n\n23\n\nattorney have to defend a civil action when it's a\n\n24\n\npossibility of performance?\n\n25\n\nto win and get a judgment against them, they cannot\n\nESQUIRE\n.m\"mv..\n\nBut, again, you're asking me to\n\nAnd the only thing we're here\n\nThey -- even if you were\n\n800.211.DEPO (3376)\nEsquireSolutions.com\n\nEFTA02734258\n\n\f", "char_count": 1381}, {"efta_number": "EFTA02734027", "page_number": 232, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\nJune 03, 2020\n11\n\ngive you what they don't have.\n2\n\nSo -- I mean, it's as simply as this:\n\nAre\n\n3\n\nyou -- you just want to engage in some discovery for\n\n4\n\nthem to absolutely assert, particularly, the state\n\n5\n\nattorney, \"I don't have these records\"; look to the\n\n6\n\nrules that say the moment the grand jury's o\n\n7\n\nthey're sealed and they're turned over a:ui\n\n8\n\ncannot be released without court orde ''\n\n9\n\n:)\n\nSo I'm not addressing the merit(LP\no ) whether you\n\n10\n\nhave an exception or you're abl/\n.\n\n11\n\nthere's an exception in the furthArance of justice.\n\n12\n\nWe're not getting there today.\n\n13\n\nshould these two entities have to defend this lawsuit\n\n14\n\nwhen even down the road if they win they can't give\n\n15\n\nyou what they do\n\n16\n\nMS. BOYAG\n\nrgue that\n\nI'm simply saying why\n\nhave?\nAs your Honor stated, I'm not\n\ncase with the clerk.\n\n17\n\nsure that's\n\n18\n\ntheir Recthat issue was not stated in their papers\n\n19\n20\n\nOURT: Let me ask you this, then: Do you\n7\nAc\\\nthink, if you got a judgment and I or the court\n\n21\n\ndoesn't make the determination that the grand jury\n\n22\n\nrecords should be released, that the clerk would be\n\n23\n\nable to perform?\n\n24\n25\n\nThat was not in\n\nWould they be able to say \"here you go\"?\n\nI\n\nmean, could the clerk just make that unilateral\n\nESQUIRE\n.\"w.\"\".\"\n\n800.211.DEPO (3376)\nEsquireSolutions.com\n\nEFTA02734259\n\n\f", "char_count": 1393}, {"efta_number": "EFTA02734027", "page_number": 233, "text_content": "June 03, 2020\n12\n\nHEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n1\n\ndecision \"I'm going to release the records, sealed\n\n2\n\nconfidential records\"?\n\n3\n\nDoes she have any authority to do that?\n\n4\n\nMS. BOYAGIAN:\n\nMy understanding, your Honor, is\n\n5\n\nthat 905.27 requires a court order before the records\n\n6\n\nare unsealed.\nExactly.\n\n7\n\nTHE COURT:\n\nExactly.\n\n8\n\nAll right.\n\nLet me hear from Mr. A\n\n9\n\nattorney, Mr. Wyler.\n\n10\n\nMR. WYLER:\n\n11\n\nplease the Court --\n\n12\n\nTHE COURT:\n\nGood morn\n\n13\n\nMR. WYLER:\n\nGood\n\n14\n\nYour Honor, I\n\nwJtted to let you know that\n\n15\n\nI spoke with coup\n\nr the clerk, Ms. Fingerhut, a\n\n16\n\ncouple of days\n\n17\n\nthat I wouldjst make the presentation for both of\n\n18\n\nof us,\n\n19\n\nthe\n\n20\n21\n\nQ\n\ning\n\nThank you, your\n\nof\n\na\n\nr.\n\nrg's\n\nMay it\n\ne this hearing, and we decided\n\nhat our arguments overlap except for\nwho this claim -- whether they have the\n\nor not, which, of course, we've said we don't\nhaVb' custody of the records.\n\n22\n\nBut, nonetheless, our arguments overlap.\n\n23\n\nPlaintiff is attempting to assert a cause of action\n\n24\n\nunder Section 905.27.\n\n25\n\nnot to be disclosed exceptions.\n\nESQUIRE\n\nDCP0t1 Os 3CRUT101.1\n\nThe\n\nThat statute settled testimony\nSo it's just\n\n800.211.OEPO (3376)\nEsquireSolutions.corn\n\nEFTA02734260\n\n\f", "char_count": 1253}, {"efta_number": "EFTA02734027", "page_number": 234, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONSERG\n\n•\n\n1\n\nexplaining exceptions to the disclosure of the grand\n\n2\n\njury testimony.\n\n3\n\nOur position is that it doesn't set forth a\n\n4\n\ncause of action and that it's impossible for us to\n\n5\n\nperform what they're asking.\nI know you said you didn't really want\n\n6\n\ninto the Furthering Justice Exception, bu\n\nknow\n\n8\n\nthat's what they're using as their basi\n\nget to\n\nBut it's our position that tngs piear\n\n10\n\nunambiguous statutory language,\n\n11\n\ndisclosure only applies to a\n\n12\n\nand that within that civi\n\n13\n\n(Speaking simulta\n\nou\n\n14\n\nTHE COURT:\n\ns r\n\n15\n\nPlaintiff's cou\n\n16\n\nMR. WYLER\nwv\n\n17\n\n19\n\nAgo\n\nows that this\nor criminal case,\n\n4iminal\n\n--\n\ny.)\nI'm sorry.\n\nAs I told\n\ncan only be used in the defense\n\nfor\n\n18\n\n•\n\nget\n\n7\n\nthese.\n\n0\n\nJune 03, 2020\n13\n\nCOURT:\ndisc\n\n%\n\nOkay.\n\nWe're not there.\n\nWe're not\n\nthe merits of the case, and -- I'm not\n\n20\n\no cross that bridge.\n\n21\n\nvery limited hearing today.\n\nI'm here for a very,\n\n22\n\nSo just as I stopped Plaintiff's counsel from\n\n23\n\narguing the merits of the case and whether or not the\n\n24\n\nFurtherance of Justice Exception will apply in this\n\n25\n\ninstance, we're not even there yet.\n\nESQUIRE\n.\"..\".\"0\n\n800.211.DEPO (3376)\nEsquireSolutions. corn\n\nEFTA02734261\n\n\f", "char_count": 1259}, {"efta_number": "EFTA02734027", "page_number": 235, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\nJune 03, 2020\n14\n\n1\n\nI'm only here for the purpose of determining\n\n2\n\nwhether or not the clerk and state attorney should be\n\n3\n\ndismissed.\n\n4\n\ndocument, which assert that you do have control and\n\n5\n\ncustody over it.\n\n6\n7\n\nSo if you'll fashion your argument with\n\nMR. WYLER:\n\nNo problem, your Hono .\n\napologize.\nWithin the four corners of\n\n10\n11\n\nposition is that they failed\n\n12\n\naction under 905.27.\n\n13\n\ndoesn't list that there\n\n14\n\nadequately pled to\n\n15\n\nthat.\n\n16\n\nfor is records\n\nThere's -\n\nIt d\n\ncomplaint, our\ne a cause of\n\n4\n\nt provide for -- it\n\nlement that they have\n\ncause of action under\nrt\n17e\nhe only thing they're asking\ne don't have.\n\nThere's really not much more to it, your Honor.\n\n17\n18\n\nAnd we\n\n19\n\ndism'\n\nuld ask that you would grant our motion to\nI‘ 4\nfailure to state a cause of action.\n\nE COURT:\ng:Nf\n\n20\n21\n\nALk\n\ne and\n\nto that limited purpose, I would appreciatORlt\ne.\n\n8\n9\n\nAnd I am bound by the four corners of the\n\non\n\nOkay.\n\nMs. Fingerhut, are you still\n\nhe phone?\n\n22\n\nMS. FINGERHUT:\n\n23\n\nTHE COURT:\n\n24\n\nMS. FINGERHUT:\n\nYes, your Honor.\n\nIs there anything you wish to add?\nWe agree with the state\n\n25\n\nESQUIRE\nOIPOSI\n\nON SOLUTIONS\n\n800.211.DEPO (3376)\nEsquireSolutions.coln\n\nEFTA02734262\n\n\f", "char_count": 1269}, {"efta_number": "EFTA02734027", "page_number": 236, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\n0\n\n1\n\nattorney's position, and we also agree with what the\n\n2\n\nCourt has said, that the plain language of the\n\n3\n\nstatute, a cause of action doesn't exist.\n\n4\n\nreally cannot -- we'll be defending something without\n\n5\n\nthe four corners.\n\n6\n\naction because the clerk is the custodian 06.44;\n\n7\n\nrecords.\n\nAnd we\n\nWe're simply involved in this\n\n8\n\nTHE COURT:\n\n9\n\nII. Boyagian, back to you.\n\n10\n\nMS. BOYAGIAN:\n\nOkay.\n\nThank you, ItO\n\nYour Honor,\n\nlii Ir\n\nlike to note\n\n11\n\nthat in the Butterworth casedw\n\n12\n\nCourt limited the application\n\\\n\n13\n\nwitness can reveal her own testimony and prohibiting\n\n14\n\nthat they violate tre First Amendment --\n\nich the Supreme\n\n05.27 by saying that a\n\n15\n\nTHE COURT:( 1\n4/\n\n16\n\nMS. BOYAGAtiN) In the Supreme Court case, the\n\nat again, please.\n\n17\n\nButterworth-\n\n18\n\nthat 905'.27 can't restrict a Grand Jury witness from\n\n19\n\nrevear7,g\n\n20\n\ni\n\n21\n22\n\n•\n\nJune 03, 2020\n15\n\ne, in which the Supreme Court ruled\n\ner own testimony, that would be a\n\non of First Amendment, in that case, the state\n\natt rney was, in fact, a party.\nTHE COURT:\n\nWell, I assume the state attorney\n\n23\n\nthat was present -- I mean, I don't find that that's\n\n24\n\nclose to what we're talking about here, and that's\n\n25\n\nwhether or not -- I mean, as we know, this was in\n\nESQUIRE\n\n800.211.DEPO (3376)\nEsquireSolutions.corn\n\nEFTA02734263\n\n\f", "char_count": 1383}, {"efta_number": "EFTA02734027", "page_number": 237, "text_content": "June 03, 2020\n16\n\nHEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n1\n\n2006.\n\n2\n\nattorney then.\n\n3\n\nrecords.\n\n4\n\nCertainly Dave Aronberg wasn't even the state\nBut this is about the release of\n\nI want to give you ample opportunity -- and\n\n5\n\nagain, I sincerely appreciate that all of the case\n\n6\n\ncourt\nt in\nSo\nlaw and the way that it was presented to the ..„,,\n\n7\n\nsuch a timely fashion.\n\n8\n\nsome time with it.\n\nBut I want to give\n\nhatever\n\n9\n\nopportunity you want to take to convl\n\ne that it\n\nI really do.\n\n10\n\nis in -- as to Count 2, again\n\n11\n\nwhether these would be the ap\n\n12\n\nAnd, you know, really\n\n•\n\nAnd Qid\n\nspend\n\nhe dec action -te defendants.\n\nnt you to boil it\n\n13\n\ndown for me as to this --/Set s take it all the way\n\n14\n\ndown the road.\n\n15\n\nthe clerk and the state attorney.\n\n16\n\nYou win.\n\nYou get a judgment against\n\nI know there's other reasons why you might have\nBut I'm just simply puzzled\n\n17\n\nfiled it this way.\n\n18\n\nbecause/I- do hear what the clerk and the state\nI\n\n\\\n\n19\n\nattorney are saying, and that is, performance is\n\n20\n\nimpossible.\n\n21\n\ncannot -- absolutely.\n\n22\n\nwiggle room -- that they could release the records\n\n23\n\neven if you got a judgment.\n\n24\n\ndetermination for the court.\n\n25\n\nThey don't have the records and\nThere's not even an inch of\n\nIt is solely a\n\nI, frankly, think, you know, there's ways to\n\nESQUIRE\nDIIOSR'\nwtubOMS\nOH\n\n800.211.DEPO (3376)\nEsquireSolutions.corn\n\nEFTA02734264\n\n\f", "char_count": 1420}, {"efta_number": "EFTA02734027", "page_number": 238, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n\n•\n\n1\n\nget to your records.\n\nThere's ways to get\n\n2\n\nconfidential records.\n\nBut it isn't by suing the\n\n3\n\nstate attorney and the clerk.\n\n4\n\n0\n\nSo I just want to hear your last final argument\n\n5\n\non how Count II, the appropriate defendants are the\n\n6\n\nclerk and the state attorney.\n\n7\n\nthey have the records -- we know they don't -- you\n\n8\n\nwere to get a judgment against them, how would you\n\n9\n\nexpect them to perform?\n\n10\n\nMS. BOYAGIAN:\n\nEven assuming arguendo\n\nTwo points, your Honor:\n\nOne is\n\n11\n\nthat, again, the clerk did not assert in her papers\n\n12\n\nthat she does not have control.\n\n13\n\nthat the State Attorne\n\ns Office has asserted.\n\n14\n\nour allegation, and\n\nour Honor noted, allegations\n\n15\n\nmust be accepted\n\n16\n\nthe proceeding\n\n17\n\nSecond\n\nThat is a position\nIt is\n\nas true at this stage of\n\nis also our understanding that the\n\n18\n\nstate attorney and the clerk intend to block access\n\n19\n20\n\nto these records. So our allegation is that they do\n%. )1\n'bssession, custody, or control, which the clerk\n\n21\n\nhas not denied; and second, that they are trying to\n\n22\n\nblock access to the records\n\n23\n\n•\n\nJune 03, 2020\n17\n\nTHE COURT:\n\nWhat do you mean?\n\nWhat do you\n\n24\n\nmean?\n\nThey're not trying to block it.\n\n25\n\nsaying that despite the fact -- let's just talk about\n\nESQUIRE\n\"mw\".\".w\n\nThey're\n\n800.211.DEPO (3376)\nEsquireSolutions.com\n\nEFTA02734265\n\n\f", "char_count": 1402}, {"efta_number": "EFTA02734027", "page_number": 239, "text_content": "June 03, 2020\n18\n\nHEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n1\n\nthe clerk, because we all know the state attorney\n\n2\n\ndoesn't have it.\n\n3\n\nSo the clerk is the custodian of records.\n\n4\n\nThat's her main job.\n\nThere's no doubt about it.\n\n5\n\nall know that.\n\n6\n\nunequivocally, only the court can make the\n\n7\n\ndetermination of whether the moving party\n\n8\n\nsatisfied that there is an exception\n\n9\n\nshould be released.\n\nWe\n\nBut we also know, unequivocally\n\n%in\n\nh\n\n4\nese\n\n10\n\nSo, again, I ask you --\n\n11\n\ncustodian of the records --\n\n12\n\nif you got a judgment say\n\n13\n\ngets a judgment against\n\nm, that she can release\n\n14\n\nthe records without\n\nurt -- without the court\n\n15\n\nweighing in, with\n\n16\n\ndetermination\n\n17\n18\n\nfact, the\n\nour opinion that\nrk and comptroller\n\ne court making that\nired by law?\n\nMS. BOYAGIAN:\n\nNo, your Honor.\n\nWe are asking\n\nyour Ho or t\\‘rorder the clerk to do that under your\n\n19\n20\n21\n22\n23\n\n% blE COURT:\n\nAll right.\n\nMr. -- Ms. Fingerhut, you wish to be heard on\nthat?\nMS. FINGERHUT:\n\nYour Honor, our position is\n\n24\n\nthat we're not trying to block access to the\n\n25\n\nrecords --\n\nESQUIRE\nDI POSITION SOLUTIONS\n\n800.211.DEPO (3376)\nEsquireSofutions.com\n\nEFTA02734266\n\n\f", "char_count": 1189}, {"efta_number": "EFTA02734027", "page_number": 240, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n1\n\n(Speaking simultaneously.)\n\n2\n\nTHE COURT:\n\n3\n\nCan the attorneys\n\nhear?\n\n4\n5\n\nCan you hear?\n\nJune 03, 2020\n19\n\nMS. FINGERHUT:\n\n-- custodian the records and\n\nthat he cannot release the records without court\n\n6\n\nTHE COURT:\n\n7\n\nOkay.\n\n8\n\nMR. WYLER:\n\nExactly.\n\nAll right.\n\nAllAr\n\nAnything further\n\nNo, your Honor.\n\nWyler?\n.\nith the\n\nI\n\n9\n\nattorneys for the clerk's office that's\n\n10\n\nfor us to release these records\n\n11\n\nto hide them or block anything f)4r6m the Plaintiff.\n\n12\n13\n\nTHE COURT:\n\nOkay.\n\n-re's no intent\n\nAnything further,\n\nMs. Fingerhut?\n\n0\n14\n\nMS. FINGERHUT:\n\n15\n\nTHE COURT:\n\n16\n\nimpossible\n\n\\\nyour Honor.\ns. Boyagian, anything\n\nfurther\n\n17\n\nII. BOYAGIAN:\n\n18\n\nCOURT:\n\nNothing further, your Honor.\n\nOkay.\n\nI will get an order out\n\n19\n\nquic\n\nhank you, folks so much.\n\nAnd I'll see you\n\n20\n\ne next round.\n910i.\n\n21\n\nMS. BOYAGIAN:\n\n22\n\nMR. WYLER:\n\n23\n\n(The proceedings concluded at 10:28 a.m.)\n\nThanks a lot.\nThank you, your Honor.\n\nThank you, your Honor.\n\n24\n\n•\n\n25\n\nESQUIRE\nOIPOSiTIO\n\nSOLUTIONS\n\n800.211.DEPO (3376)\nEsquireSolutions.com\n\nEFTA02734267\n\n\f", "char_count": 1110}, {"efta_number": "EFTA02734027", "page_number": 241, "text_content": "HEARING\nCA FLORIDA HOLDINGS vs DAVE ARONBERG\n1.\n\nJune 03, 2020\n20\n\n•\n\nCERTIFICATE OF REPORTER\n\n2\n3\n4\n\nI, Sonja M. a\n\nCourt Reporter, certify that\n\n5\n\nI was authorized to and did stenographically report the\n\n6\n\nforegoing proceedings and that the transcript,\n\n7\n\nthrough 19, is a true and complete record of\n\n8\n\nstenographic notes.\n\ns 1\n\n5:)\n\n9\n(:/\n1\n4\n10\n11\n\nDated this 3rd day of\n\n0020.\n\n12\n\n(s4\n\n13\n14\n15\n16\n17\n\nSonja M.\nCourt RepR\n\n18\n\nIL\n\n19\n20\n21\n22\n23\n24\n25\n\nESQUIRE\nIMPOSITION SOLUTIONS\n\n800.211.DEPO (3376)\nEsquireSolutions. corn\n\nEFTA02734268\n\n\f", "char_count": 553}, {"efta_number": "EFTA02734027", "page_number": 242, "text_content": "Def.Ex.A-7\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734269\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 243, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCIRCUIT CIVIL DIVISION AG\nCASE NO. 50-2019-CA-014681-XXXX-MB\nCA FLORIDA HOLDINGS LLC PUBLISHER OF THE PALM BEACH POST,\nPlaintiff/Petitioner\nvs.\nDAVE ARONBERG,\nSHARON R BOCK,\nDefendant/Respondents.\n\nORDER GRANTING DEFENDANTS MOTIONS TO DISMISS COUNT II OF\nPLAINTIFF'S FIRST AMENDED COMPLAINT WIT)! PREJUDICE\nTHIS CAUSE cant before the Court on Dave Aronbe\nBeach County's (\"State Attorney\") and Sharon R. Bock,\nCounty's, (\"Clerk\") respective Motions to Dismiss\nPublisher of the Palm Beach Post's (\"The Post\"\n\nle\n\nStan. Attorney of Palm\nComptroller of Palm Beach\nCA Florida Holdings, LW,\n\n>MtAmierded Complaint (DE## 22, 24). This\n\ncase is assigned to Division AG, which is\n\ny\n\nsided over by the Honorable Donald\n\nHafele. However, the undersigned, a\n\nge of the Fifteenth Judicial Circuit, presided\n\nover the June 3, 2020 hearing o\n\nttorney and Clerk's Motions as the Motions\n\nimplicate records of the Palm\n\nh ounty grand jury, over which the Chief Judge presides.\n\nSee § 905.01, Fla. Stat (\n\ner careful consideration of the pleadings and the arguments\n\npresented at the\n\nThe Post is\nprosecuiio\n\n0\n\nourt grants the Motions for the following reasons.\nBackground\noutlet which has heavily reported on the 2006 Palm Beach County criminal\n\nf Jeffrey Epstein. Through the instant civil lawsuit, The Post seeks \"in mediate\n\naccess to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach\nCounty grand jury\" in Mr. Epstein's case and alleges that both the State Attorney and Clerk are\n\"in possession and/or control of [those] documents.\" (DE # 17, First Amended Complaint at 11\n3,4, and 77). Specifically, The Post seeks declaratory judgment as to its rights to obtain the\ngrand jury testimony in Mr. Epstein's case from the State Attorney and Clerk (Count I) as well as\n\nPage 1 of 7\n\nEFTA02734270\n\n\f", "char_count": 1906}, {"efta_number": "EFTA02734027", "page_number": 244, "text_content": "Case No. 50-2019-CA-014681-XXXX-MB\njudgment against the State Attorney and the Clerk pursuant to section 905.27, Florida Statutes,\nwhich sets forth the parameters of grand jury secrecy in Florida. (Count 11). Both the State\nAttorney and the Clerk move to dismiss Count II of The Post's First Amended Complaint,\narguing that that section 905.27 does not create a private cause of action. (DE## 22, 24). The\nCourt agrees.\nAnalysis\n\"In reviewing a motion to dismiss for failure to state a cause of action, the court\n\nt ccept the\n\nallegations of the complaint as true and construe them in the light most favora\n\nthe\n\nAlmarante v. Art Institute ofFort Lauderdale, Inc., 921 So. 2d 703, 704-0.4\n\nDCA\n\n2006). The motion should only be granted if the moving party demo\ncannot provide any facts that would support a cause of action. Jd.\naction alleged is nonexistent under Florida law, dismissal'\n444 So. 2d 565, 566 (Fla. 1st DCA 1984) (affirming itsic\n\nintiff.\"\n\nthe plaintiff\nfo\n\nws that if the cause of\nCummings v. Dawson,\n\nf cause of action not recognized\n\nby Florida law).\nSection 90527, Florida Statutes (2019), is tic \"T timony not to be disclosed, exceptions,\"\nand states:\ns r Cant state attorney, reporter, stenographer,\n(1) A grand juror, state atto\ninterpreter, or any other rson\naring before the grand jury shall not disclose the\ntestimony of a witness e\nbefore the grand jury or other evidence received by it\nexcept when requirjby a court to disclose the testimony for the purpose of:\n\na. Asc\n\nwhether it is consistent with the testimony given by the witness before\nning whether the witness is guilty of perjury; or\nring justice.\n\n(2) It is unlawful for any person knowingly to publish, broadcast, disclose, divulge, or\ncotritunicate to any other person, or knowingly to cause or permit to be published,\nbroadcast, disclosed, divulged, or comrrunicated to any other person, in any manner\nwhatsoever, any testimony of a witness examined before the grand jury, or the content,\ngist, or import ther\n... [truncated, 2449 chars — for the full page use /api/corpus/document/EFTA02734027/244 or ?id=EFTA02734027&page=244]", "char_count": 2449}, {"efta_number": "EFTA02734027", "page_number": 245, "text_content": "Case N o. 50-2019-CA-014681-XXXX-MB\nattorney, and by the latter to his or her legal associates and employees. When such\ndisclosure is ordered by a court pursuant to subsection (I) for use in a civil case, it may be\ndisclosed to all patties to the case and to their attorneys and by the latter to their legal\nassociates and employees. However, the grand pry testimony afforded such persons by\nthe court can only be used in the defense or prosecution of the civil or criminal case and\nfor no other purpose whatsoever.\n(3) Nothing in this section shall affect the attorney-client relationship. A client shall have\nthe right to cormunicate to his or her attorney any testimony given by the client to the\ngrand jury, any nutters involving the client discussed in the client's presence before the\ngrand jury, and any evidence involving the client received by or proffered tootlr1 grand jury\nin the client's presence.\n(4) Persons convicted of violating this section shall be guilty of a\ndegree, punishable as provided ins. 775.083, or by fine not exce\n\nr of the first\n,000, or both.\n\n(5) A violation of this section shall constitute criminal collie\n§ 90527, Fla. Stat. (2019).\nAs the State Attorney and Clerk argue\nmakes no express provision for a civil suit or c\n\nNonetheless, The Post maintains that\n\nit is entitled to seek the grand jury records\njustice\" exception to grand jury secre\nlimited question for this Court's\n\nt concedes, section 90527\n\ncause of action pursuant to the \"furthering\ndin subsection 90527(IXc). Therefore, the\non is whether a cause of action under section 90527\n\nshould be judicially implied. Se\n\nv y v. N. Sinha Corp., 644 So. 2d 983, 985 (Fla. 1994).\n\nIn advocating that it\n\nintain a cause of action against the State Attorney and Clerk\n\nunder section 90\nplaintiff is ot o\n\nThe ost urges the Court to examine three factors \"(1) whether the\ns for whose special benefit the statute was enacted; (2) whether there\n\nis any\n\nther explicit or implicit, of a legislative intent to creat\n... [truncated, 2615 chars — for the full page use /api/corpus/document/EFTA02734027/245 or ?id=EFTA02734027&page=245]", "char_count": 2615}, {"efta_number": "EFTA02734027", "page_number": 246, "text_content": "Case No. 50-2019-CA-014681-XXXX-MB\ngrand jury secrecy outlined in section 905.27(1)(c) was meant to benefit the public at large, for\nwhich the press acts as a surrogate. The Post's arguments are unpersuasive as to the discrete\nissue of whether a private cause of action lies in section 905.27.\nTo begin with, The Post's reliance on the benefit factor is misplaced. Per the Florida\nSupreme Court's 1994 opinion in Murthy, \"the question of whether a statute establishes a duty to\ntake precautions to protect or benefit a particular class of persons is no longer determinative on\nthe question of whether a cause of action should be recognized.\" Sorenson v. Pro\nCompounding Pharmacists of W. Pa., Inc., 191 So. 3d 929 (Fla. 2d DCA 201\n644 So. 2d at 985). Instead, \"whether a statutory cause of action should\nquestion of legislative intent.\" Horowitz v. Plantation Gen. Hosp. L\n\nurthy,\ni. i y implied is a\n\nzp, 959 So. 2d 176,\n\n182 (Fla. 2007). See also QBE Ins. Corp. v. Chalfonte Condo.\n\nent Ass it, Inc., 94 So. 3d\n\n541, 551 (Fla. 2012) (\"Since Murthy, we have reaffmredite sa\n\ne that whether a statutory\n\ncause of action should be judicially implied is a qtes\n& Cas. Ins. Co. v. Loftus, 276 So. 3d 849, 851\nAs is always the case when a court\nlanguage of the statute is the starting,\n\"When the statute is clear and\nlanguage for legislative intent\nLoftus, 276 So. 3d at 851\n\ne\n\nf\n\nlative intent.\"); Universal Prop.\n\nD A 2019).\ns\n\nlegislative intent analysis, the plain\n\nnding, point. See Horowitz, 959 So. 2d at 182.\ncourts will not look behind the statute's plain\n\ns\n\nto rules of statutory construction to ascertain intent\"\n\nhy th DCA 2019)Xquoting Daniels v. Fla. Dept ofHealth, 898 So.\n\n2d 61, 64 (Fla. 20\n\n). \"Htwever, a single pad of a statute should not be read in isolation.\" Id.\n\n\"Instead, `all\n\nf statute must be read together in order to achieve a consistent whole.\"' Id.\n\n(quo\n\nLongboat Key Beach Erosion Control Dist., 604 So. 2d 452, 455 (Fla.\n\nF\n\n1992)).\nAs The Post acknowledges, \"there i\n... [truncated, 2450 chars — for the full page use /api/corpus/document/EFTA02734027/246 or ?id=EFTA02734027&page=246]", "char_count": 2450}, {"efta_number": "EFTA02734027", "page_number": 247, "text_content": "Case No. 50-2019-CA-014681-XXXX-MB\nhistory indicating an intent to create a private right of action is telling, it is not dispositive as the\nplain language of the section 90527 is clear an unambiguous and, therefore, controls. Horowitz,\n959 So, 2d at 182.\nExamining the plain language of section 90527 jja its entirety which requires the Court to\nlook at more than just the \"furthering justice\" provision of section 90527(1Xc) relied on by The\nPost, it is clear that the intent of the Legislature in passing section 90527 was to limit, not\nfacilitate, disclosure of grand jury records. In no uncertain tents, the Legislature\nno \"person appearing before the grand jury\" may \"disclose\" testimony or ev\n\np\n\nexcept when \"required by a court\" under certain limited circunstances.\nsolidifying that its intent was to prohibit disclosure without court pe\n\ned that\nented\n\n( , Fla. Stat. In\n\nssio\n\nt\n\nLegislature\n\nprovided that disclosure without a court order is a criminal offc)\n\n§9\n\nTherefore, to the extent section 90527 could be read as\n\nduty on the State Attorney\n\ns\n\n27(4), Fla. Stat.\n\nand Clerk, the duty imposed is one of secrecy, not d'\nln sum, there is nothing in the text of sectre\\\n' 9\n\n7 from which one can deduce tint the\n\nLegislature contemplated a member of the\n\nor wone else for that matter, having a private\n\ncause of action to compel the State\n\nClerk to disclose grand jury records. Indeed,\n\nto the contrary, section 90527 p\npleaded by The Post, they hay\nbeing ordered to do so b\n\nState Attorney and the Clerk (assuming that, as\ncunrnts) from disclosing the documents without first\nurtin Reading section 90527 as creating a private cause of\n\naction against the\n\nteAtt\n\ny and Clerk is, therefore, not only unsupported by the language of\n\nsection 905\n\nis ctually paradoxical to its plain language of the statute. As such, this Court\n\nlacks the\n\nconstrue the unambiguous language of section 90527 in a way that would\n\nextend its\n\npress terms and create a cause of action where none exists. \"To\n... [truncated, 2356 chars — for the full page use /api/corpus/document/EFTA02734027/247 or ?id=EFTA02734027&page=247]", "char_count": 2356}, {"efta_number": "EFTA02734027", "page_number": 248, "text_content": "Case No. 50-2019-CA-01468 I-XXXX-MB\n90527. In arriving at this conclusion, the Court does not suggest The Post has no available\nmechanism to obtain a court order granting it access to the grand jury proceedings. The Court\nalso does not render any opinion as to whether releasing these records is appropriate for the\npurpose of \"furthering justice\" within the meaning of section 90527. Rather, the Court's\ndismissal of Count II is necessitated by precedent and the simple fact that a civil lawsuit against\nthe State Attorney and Clerk under section 90527 is not the proper mechanism for The Post to\npursue its goal.\nTherefore, it is hereby\nORDERED AND ADJUDGED that Dave Ainnberg, as State Att\nCounty's and Sharon R. Bock, as Clerk & Comptroller of PalmBeac\n\nalm Beach\ns, respective\n\nMotions to Dismiss Count Hof CA Florida Holdings, LLC, P\n\nr o the Palm Beach Post's\n\nFirst Amended Complaint are GRANTED and Count II o\n\nfirst Attended Complaint is\n\nhereby DISMISSED with prejudice.\nDONE AND ORDERED, in West Pa\n\nalm Beach County, Florida this 8th day\n\nof June, 2020.\n\n)14f\n01\n\nMOOS\n\neittii\n\nj\n\nkrIstal Maim Chief 39 gip50-2019-CA-014681-XXXX-MB\nKrtsta Marx\nChief Judge\n\n0608,2020\n\nIn The\n\nn•tes that, if there was a court order dkecting the State Attorney or the Clerk to\ndisclose re rds and the State Attorney or the Clerk refined, the remedy for disobeying a court order\nis contempt or, in some instances, a mandamus proceedings — not a civil lawsuk.\n\nCOPES TO:\nNo Address Available\nDOUGLAS A. WYLER\n\nNo E-mail Address Available\n\n961687 GATEWAY BLVD\ndoug.wyler@comcastnet\nSUITE 201-I\nFERNANDINA BEACH, FL\n\nPage 6 of 7\n\nEFTA02734275\n\n\f", "char_count": 1636}, {"efta_number": "EFTA02734027", "page_number": 249, "text_content": "Case No. 50-2019-CA-014681-XXXX-MB\n\nMICHAEL GRYGIEL\n\nMICHAEL J. GRYGIEL\nNICOLE R. FINGERHUT\n\n32034\n54 STATE STREET\n6TH FLOOR\nALBANY, NY 12207\nNo Address Available\nPOST OFFICE BOX 229\nWEST PALM BEACH, FL\n33401\n\nNINA D. BOYAJIAN\n\nNo Address Available\n\nNINA D. BOYAJIAN\n\n1840 CENTURY PARK\nEAST\nSUITE 1900\nLOS ANGELES, CA 90067\n5100 TOWN CENTER CIR\nSUITE 400\nBOCA BATON, FL 3\n\nSTEPHEN A.\nMENDELSOHN, ESQ\n\nGRYGIELM@GTIAW.COM\n\ngrygielm@gtlaw.com\nCLERK ESERVICE@MYPALMBEACH\nCLERK.COM\nnfingerhia@mypalmbeachclerk\ncorn\nboyajiann(a)gtla\nriveraal@gt\nm\nNo E-ma'\nAvailable\n\nelsohns@gtlaw.com\na)gtlaw.com\nservice@gtlaw.com\n\ntiff\n\nPage 7 of 7\n\nEFTA02734276\n\n\f", "char_count": 644}, {"efta_number": "EFTA02734027", "page_number": 250, "text_content": "Def.Ex.A-8\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734277\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 251, "text_content": "A LIMITED L\nTilt LAW orricts Or\n\na ASSOCIATES. PA.\nARTHUR I.\n\nSCHOLZ & WYLER, LLC.\n\nMU TY COMPANY OF PROFESSIONAL ASSOCIATIONS\n\nATTORNEYS AT LAW\nGATEWAY TO AMELIA\n961007 GATEWAY BLVD.. SUITE aO1-1\nFERNANDINA BRACK FLORIDA 32034\n\nRICHARD J. SCHOLZ. P.A.\nRICHARD J. SCHOLZ\nDOUGLASA. WYLER, P.A.\nDOUGLAS A. WYLER\n\nTELEPHONE (904) 261.3693\nFAX NO. (904) 261.7679\n\nJune 8, 2020\n\nVIA ELECTRONIC & U.S. MAIL\nStephen A. Mendelsohn, Esq.\nGreenburg Traurig, PA.\n5100 Town Center Circle, Suite 400\nBoca Raton, FL 33486\nRE:\n\nCos\n\nCA Florida Holdings, LLC v. Dave Aronbe\nPalm Beach County, Case No.: 2019-CA,.d\n\nDear Mr. Mendelsohn:\nAs you are aware our firm represents the intere\nCounty, Florida, in the above referenced\ndismissal of your First Amended Complai\nis made pursuant to section 57.105, Fl\n\nAronberg, as State Attorney ofPalm Beach\ntirpose of this letter is to demand the voluntary\nomplaint\"), dated January 17, 2020. This demand\n\nAs you know, Section 57\n(1) Upon the court's\ne or motion of any party, the court shall award a\nreasonable a mey's ee, including prejudgment interest, to be paid to the\nprevailing p\nual amounts by the losing party and the losing party's attorney\non any im o efense at any time during a civil proceeding or action in which\nthe\nInds that the losing party or the losing party's attorney knew or should\nthat a claim or defense when initially presented to the court or at any\nore trial:\nWas not supported by the material facts necessary to establish the claim or\ndefense; or\nb. Would not be supported by the application of then-existing law to those\nmaterial facts.\nToday, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count II of the\nPlaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action\nconsists of Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein\nand its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to\nestabl\n... [truncated, 2138 chars — for the full page use /api/corpus/document/EFTA02734027/251 or ?id=EFTA02734027&page=251]", "char_count": 2138}, {"efta_number": "EFTA02734027", "page_number": 252, "text_content": "First and foremost, the Complaint is not supported by the material facts necessary to establish the\nclaims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the\nFifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein.\nSimply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are\nimpossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to\nthis action because no matter what, he and his office do not have possession, custody, or control of the\nrequested materials.\nIn addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims\nare also not supported by the application of current law. Specifically, your action ford laratory relief\nfails based on the clear, unambiguous statutory language found in Section 905.27(2 Fl rids Statutes,\nwhich states:\nuse in a civil\nWhen such disclosure is ordered by a court pursuant to subsection (\nby the latter\ncase, it may be disclosed to all parties to the case and to their atto\nto their legal associates and employees. However the rand\nonv afforded\nsuch persons by the court can only be used in the defense or p\non ofthe civil or\ncriminal case and for no other purpose whatsoever.\nMoreover, even if the Plaintiff were to prevail in the decla\nto comply with any court order granting disclosure of\nAronberg nor The Office of the State Attorney fo\ncustody, or control of the 2006 Epstein grand ju\nBased on the foregoing, if the Complaint is\nthe enclosed Motion for Attorney's Fees '\nand your firm, recovery of the legal ex\n\nMr. Aronberg would be unable\ndocuments because neither Mr.\nnth Judicial Circuit have possession,\n\nsed within 21 days of the service of this letter,\ned and we will seek as sanctions, from your client\nerred in defending this frivolous action.\n\nPlease govern yourself accordin\n\nDouglas A. Wyler, Esq.\nFor the Finn\nEnd.: Defe\n\nion for Attorney\n... [truncated, 2024 chars — for the full page use /api/corpus/document/EFTA02734027/252 or ?id=EFTA02734027&page=252]", "char_count": 2024}, {"efta_number": "EFTA02734027", "page_number": 253, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-CA-O14681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\ng\nDefendants.\n\nAtIC\n\nDEFENDANT, DAVE ARONBERG'S M\n\nR ATTORNEYS' FEES\n\nDefendant, DAVE ARONBERG, as Staff\n\nof Palm Beach County, Florida, by and\n\nthrough the undersigned attorneys, move\nto award him reasonable attorneys'\n\n, pursuant to Florida Statutes, Section 57.105,\ne defense of Plaintiff's First Amended Complaint,\n\n(the \"Complaint\"), and as gro\n\nr, would show that on June 8, 2020, Plaintiff was served\n\na copy of this Motion, togeth\n\na letter from the undersigned attorney, in accordance with\n\nsubsection (4) of the abo\nto the filing o\nestabli\n\nis\n\ntute, demanding dismissal of the Complaint, at least 21 days prior\n\non. In said letter, Defendant's attorney advised Plaintiff of the facts which\nmplaint is without support of the facts or the law.\n\nREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach\nCounty, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's\nattorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.\n\nEFTA02734280\n\n\f", "char_count": 1360}, {"efta_number": "EFTA02734027", "page_number": 254, "text_content": "CERTIFICATE OF SERVICE\nI hereby certify that on this\n\nday\n\n, 2020, the foregoing was electronically filed\n\nvia the Florida E-File Portal for electronic service on the parties of record herein.\nSCHOLZ & WYLER, LLC\nA/ Douglas A. Wyler\nArthur I.W\nEsquire\nHa. Bar No.: 108249 tic\n,\nRichard J. Scholz, E\nFla. Bar No.: 0021\nDouglas A. Wyl\nFla. Bar No.: 1\n961687 Gate\nd., Suite 201-I\nFernan4jflach,Florida 32034\n9\nzlaw@comcast.net\nttorneysfor Defendant\n\nGs'\n\nEFTA02734281\n\n\f", "char_count": 467}, {"efta_number": "EFTA02734027", "page_number": 255, "text_content": "Def.Ex.A-9\nA\nCO\nAS\n\n(S ,\n6 -S\n)-I.'\"\n\nEFTA02734282\n\n\f", "char_count": 53}, {"efta_number": "EFTA02734027", "page_number": 256, "text_content": "GT GreenbergTraurig\nStephen A. Mendelsohn\nTel 561.955.7629\nFOX 561.659.9119\n\nmendelsohns@gtlaw.com\n\nJune 23, 2020\nDouglas A. Wyler\nJacob Scholz & Wyler, LLC\n961687 Gateway Blvd.\nSuite 201-I\nFernandina Beach, Fl. 32034\nRe:\n\nCA Florida Holdings, LLC v. Dave Arenberg el at.\nCase No. 2019-CA-014681\n\nA\nCos\n\nDear Mr. Wyler:\nWe are in receipt of your letter of June 8, 2020 with yeti\ned Fla. Stat. section 57.105 motion.\nIn your letter and your proposed motion, you assert that\nFlorida Holdings, LLC and the law\nfirm of Greenberg Tinting, P.A. should be li ble (the attorneys' fees to be incurred by State\nAttorney Aronberg after the date of your I\nYo letter cites to Fla. Stat. sections 57.105(1)\n(a) and (b) for support. As shown below\nre t o basis for a Fla. Stat. section 57.105 motion,\nand we expect that if the State Attom\nmake such a motion, the court should deny it.\nYour letter omits a citation to s\nmay not be awarded where\nreversal of existing law or the es\na reasonable expectation\n\n5(3). Subsection 57.105(3)(a) provides that sanctions\ngood faith argument for the extension, modification or\nhtnent of new law, as it is applied to the material facts, with\n\" We have such a good faith argument.\n\nContrary to your\nlysis df Fla. Stat. section 905.27, there are actually three instances where a\ncourt may ord t e\nse of grand jury materials. As we argue, the court may order release \"in\na\nfurtherance jus\n' There are few cases in Florida reviewing this provision and its scope. It is\nan open and v\nestion as to whether the court may order release of grand jury transcripts to\nthe med1under both the statute and the First Amendment to the US Constitution in furtherance\nof justice. the statutory language you cite refers to instances where a person is seeking grand jury\nmaterials for use in a civil or in a criminal case. In these limited situations, the statute allows for\nsuch uses and for no other reason. However, the statute does not state, as you assert, that where\nthe media seeks grand jury\n... [truncated, 2882 chars — for the full page use /api/corpus/document/EFTA02734027/256 or ?id=EFTA02734027&page=256]", "char_count": 2882}, {"efta_number": "EFTA02734027", "page_number": 257, "text_content": "Correspondence to Douglas A. Wyler\nJune 23, 2020\nPage 2\nuse limitation you cite applies. No reported Florida case has addressed this issue and there is a\ngood faith basis for our view of Fla. Stat. section 905.27\nYour letter also argues that sanctions are applicable because the State Attorney has alleged that it\ndoes not possess the Jeffrey Epstein grand jury transcripts. This allegation is also contained in the\nState Attorney's Answer. Assuming that the State Attorney does not currently\ne physical\npossession of the Epstein grand jury materials, which has yet to be demonstrated, s\ns not end\nthe matter. The State Attorney was named as a party not simply as a custo\nnd jury\nrecords. The State Attorney was named in his official capacity as his office\nas its primary\ninterest the protection of its grand jury system.\" [Italics in original.] In re rand Jury Proceedings,\n832 F. 3d 554, 559 (11th Circuit 1987). In that case, the US petitioned\nate judge to order the\nState Attorney to turn over grand jury transcripts. The State Attome argtt\ninst their release\nciting to Fla. Stat. section 905.27. Later, a federal grand jury subp a the Broward County\nState Attorney for delivery of state grand jury testimony. The\nd tate Attorney advised the\nfederal court that it would produce the transcripts, thereby\nrating that while it may not\nhave physical possession of the materials, he had legal autl\no obtain and deliver them. It\nshould also be noted that the State Attorney moved t\ne subpoena arguing that it was\nunlawful under Florida law and Fla. Stat. section 9\ncase indicates that where one seeks\ngrand jury materials, the relevant State Attorney,\nsary patty in order to protect the grand\njury that the Office of State Attorney supervis\nn o ake arguments, if need be, against release\nof the grand jury materials. These are some f same reasons why the State Attorney was named\nin this case.\nAlso, assuming the State Attome\nve physical possession of the grand jury materials,\nthere is nothing in Flor\n... [truncated, 2729 chars — for the full page use /api/corpus/document/EFTA02734027/257 or ?id=EFTA02734027&page=257]", "char_count": 2729}, {"efta_number": "EFTA02734027", "page_number": 258, "text_content": "Correspondence to Douglas A. Wyler\nJune 23, 2020\nPage 3\n\nFor these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed\nagainst the Office of the State Attorney. We expect that your demand will be withdrawn.\nThank you,\nVery truly yours,\nIs/Stephen Mendelsohn\nStephen Mendelsohn\n\nSAM:Is\n\nACTIVE 51081659v1\n\nGreenberg Tranrig, P.A. I Attorneys at raw\nvnyvtlaw.corn\n\nEFTA02734285\n\n\f", "char_count": 411}, {"efta_number": "EFTA02734027", "page_number": 259, "text_content": "Def.Ex.A-10\n\nEFTA02734286\n\n\f", "char_count": 28}, {"efta_number": "EFTA02734027", "page_number": 260, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-CA-014681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\nCO\n\nSA\n\nDefendants.\n\nDEFENDANT. DAVE ARONBERG'S MO\nDefendant, DAVE ARONBERG, as State\n\n\\\n\nATTORNEYS' FEES\n\ney f Palm Beach County, Florida, by and\n\nthrough the undersigned attorneys, moves t\n\nurt, ursuant to Florida Statutes, Section 57.105,\n\nto award him reasonable attorneys'\n\ndefense of Plaintiff's First Amended Complaint,\n\n(the \"Complaint\"), and as grotire\n\n, would show that on June 8, 2020, Plaintiff was served\n\na copy of this Motion, together • a letter from the undersigned attorney, in accordance with\nrr\nsubsection (4) of th b v\ntute, demanding dismissal of the Complaint, at least 21 days prior\nto the filing of 'i\nestablish\nWW\n\non. In said letter, Defendant's attorney advised Plaintiff of the facts which\nmplaint is without support of the facts or the law.\n\nREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach\n\nCounty, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's\nattorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.\n\nEFTA02734287\n\n\f", "char_count": 1380}, {"efta_number": "EFTA02734027", "page_number": 261, "text_content": "CERTIFICATE OF SERVICE\nI hereby certify that on this 1st day July, 2020, the foregoing was electronically filed via\nthe Florida E-File Portal for electronic service on the parties of record herein.\nSCHOLZ & WYLER, LLC\nIs/ Douglas A. Wyler\nArthur I. =\nEsquire\nFM. Bar No.: 108249\nRichard J. Scholz, Esqui\nFla. Bar No.: 002126\nDouglas A. Wyle\nFla. Bar No.: 11\n961687 Gateway\n•., Suite 201-1\nFernandi\nh, Florida 32034\n(904)\n61-7\nholZlaw@comcast.net\nneysfor Defendant, Dave Aronberg\n\nEFTA02734288\n\n\f", "char_count": 495}, {"efta_number": "EFTA02734027", "page_number": 262, "text_content": "Def.Ex.A-11\n\nEFTA02734289\n\n\f", "char_count": 28}, {"efta_number": "EFTA02734027", "page_number": 263, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-CA-014681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller ofPalm\nBeach County, Florida.\nO ISA\n\nDefendants.\nC\n\nDEFENDANT DAVE ARONBERG'S MOTION F01(9)1M RY FINAL JUDGMENT\nAND MEMORANDUM OF LAW IN, 1 jyRT THEREOF\nDefendant\n\nDAVE ARONBERG, as SJ\\tc\nAStictto\\>ey of Palm Beach County, Florida,\n\n(hereinafter \"Aronberg\"), by and through cou\n\nwand\n\nCivil Procedure, moves for entry ofsu\n\njudgment in his favor as to the remaining claim for\n\nDeclaratory Relief in Plaintiff's F\"\nC\nSTATE\nThe following is a s\n\npursuant to Rule 1.510 Florida Rules of\n\ncd Complaint', and in support thereof states as follows:\n4 OF THE UNDISPUTED FACTS\n\nnt of facts material to this motion for summary judgment as to which\n\nthere is no germ\nt I of Plaintiff's First Amended Complaint, (hereinafter \"Complaint\"), filed\nJanuary\n2.\n\nseeks Declaratory Reliefpursuant to Section 86.011, Florida Statutes.\nSpecifically, Plaintiff's Count I socks a court order\"declaring that pursuant to Fla. Stat.\n\nSection 905.27(1Xe) and the Court's inherent authority, The Palm Beach Pas, may gain access to the\ntestimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury\" that\n\nOn June 8, 2020, this Court entered its Order Granting Defendants Motion to Dismiss Count II of the Plaintiffs First\nAmended Complaint with Prejudice.\n\nEFTA02734290\n\n\f", "char_count": 1571}, {"efta_number": "EFTA02734027", "page_number": 264, "text_content": "was empancled during the first Jeffrey Epstein, (hereinafter \"Epstein\"), sex abuse investigation,\n(hereinafter \"Requested Materials\"). Complaint pg. 20\n3.\n\nPlaintiff secics to use the Requested Materials \"for the purpose of informing the public.\"\n\n4.\n\nPlaintiff seeks the above-referenced declaratory relief, including copies of the\n\nId.\n\nRequested Materials, from both Arenberg, as State Attorney of Palm Beach Cou\n\nlorida, and\n\nDefendant, Sharon R. Bock, as Clerk and Comptroller of Palm Beach County, FleAd\n\n(hereinafter\n,\nthe\n\n\"Clerk\").\n5.\n\n0\nNeither Arenberg nor the Office of the State Attorney for\n\n(\"SAO\"), is in control, custody, or possession of the Request\n\nFjkccnth Judicial Circuit,\nArenberg Aff. 13, attached\n\nas Exhibit \"A\".\n6.\n\nThe declaratory relief sought by t 'ICtAS'\n\nArenberg or the SAO to produce. Exhibit \"A\n7.\n\nNeither Arenberg nor\n\nseeks\nmaterials that arc impossible for\n\n\\\nas the legal authority to obtain and/or deliver the\n\nRequested Materials. Exhibit \"A\"\nC se)\n.\n8.\n\nThe undisputed f\n\nevident by Arenberg to the\nin this matter, but\n\nt forth above in paragraphs 6-7 have been repeatedly made\ntff and the public through not only the pleadings and correspondence\n\nugh an office press release and Arenberg's public social media accounts.\n\nExhibit\"\neither Arenberg nor the SAO has the authority to demand that the Clerk grant the\nSAO access to grand jury materials after a criminal ease has concluded. Exhibit \"A\" 1 7.\n10.\n\nDuring Aronbcrg's administration, neither he nor his office has accessed grand jury\n\nmaterials from the Clerk's office in this or any other instance. Exhibit \"A\" 1 8.\n\n2\n\nEFTA02734291\n\n\f", "char_count": 1636}, {"efta_number": "EFTA02734027", "page_number": 265, "text_content": "11.\n\nAs provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody\n\nand possession of the Requested Materials, which can only be released by the Clerk pursuant to an\norder of the Court. Exhibit \"A\" 1 9.\nMEMORANDUM OF LAW\nI.\n\nLegal Standard Governing Motions For Summary Judgment\n\"The judgment sought shall be rendered forthwith if the pleadings, dcposi\n\ninterrogatories, and admissions on file together with the affidavits, if any, show\nissue of material fact and that the moving party is entitled to a judgmen\n1.510, Fla. R. Civ. P. It is appropriate to resolve a declaratory action on\nhere, the decree seeks a legal interpretation of a statute. Rahi\n\nanswers to\nis no genuine\n\nma\n\nr of law.- Rule\n\na ary judgment when, as\nI Discoveries, Ltd., LLC, 252\n\nSo. 3d 804 (Fla. 5th DCA 2018).\nIL\n\nThe Requested Materials Can Only Be\nOrder\nNotably, neither Aronbcrg nor the\n,\n\nMaterials. Exhibit \"A\" 1 3. None\nCourt's inherent authority, Plain\n\n\\sed\n\ny The Clerk Pursuant To A Court\n\ne ty\nisivcontrol, custody, or possession of the Requested\nuant to Section 905.27(1)(c), Florida Statutes and the\na court order declaring that Aronbcrg provide copies of the\n\nRequested Materials to Thvic lm\norBeach Post for the purpose of informing the public. Complaint pg.\n20-21. Plaintiff i\npursuant to dr¢\n\nkingtelaratory relief alleging its entitlement to the Requested Materials\nrc\n\ng justice\" exception to grand jury secrecy. § 905.27, Fla. Stat. (2020).\n\nnging its declaratory relief claim pursuant to Section 905.27, Florida Statutes, \"a\nsingle part df a statute should not be read in isolation.\" Universal Prop. & Cat Ins. Co. v. Loftus, 276\nSo. 3d 849, 851 (Fla. 4th DCA 2019). \"Instead, `all parts of a statute must be read together in order to\nachieve a consistent whole.'\" Id. (quoting Forsythe v. Longboat Key Beach Erosion Control Dist,\n604 So. 2d 452, 455 (Fla. 1992).\n\n3\n\nEFTA02734292\n\n\f", "char_count": 1905}, {"efta_number": "EFTA02734027", "page_number": 266, "text_content": "Section 905.17(1), Florida Statutes makes clear that grand jury records, like the Requested\nMaterials in this matter, arc to be maintained with the Clerk, and can only be released by the Clerk\npursuant to a court order. To wit\nThe stenographic records, notes, and transcriptions made by the court reporter or\nstenographer shall be filed with the clerk who shall keep them in a sealed container not\nsubject to public inspection. The notes, records, and transcriptions are confidential\nand exempt from the provisions of s. 119.07(1) and s. 24(a), Art. 1 of the late\nConstitution and shall be released by the clerk only on request by a grandju\nby the grandjuty or on order ofthe court pursuant to s. 905.27.\nSection 905.17(1), Florida Statutes (2020). (Emphasis added.)\nText, context, and purpose arc the ordinary tools used for disco\n\ntory meaning, with\n\nthe overarching principle being \"that judges lack the power to\n\ne an unambiguous statute in a\n\nway which would extend, modify, or limit its express terms\n\nble and obvious implications.\n\nTo do so would be an abrogation of legislative powcr.\n\nit\n\n, the plain language of section 905.17\nwitz v. Plantation Gen. Hosp. Ltd. P'ship,\n\nis clear and unambiguous and, therefore, contro\n959 So. 2d 176, 182 (Fla. 2007).\nAccordingly, based on the cl\nonly the Clerk, not the State At rncy,\n\nat\n\n*guous statutory language set forth in section 905.17(1),\n\nay release grand jury materials pursuant to an order of the\n\ncourt. Thus, it is apparent tit iiir\nAronberg and the SAO lack the legal authority to obtain and deliver the\nRequested Matcria\nmaterials that\n\nhib t \"A\" 1 5. Likewise, the declaratory relief sought by the Plaintiff socks\no\n\nhas sol\n\nble for Aronberg or the SAO to produce. Exhibit \"A\"14. Again, the Clerk\n\nd possession of the Requested Materials. These facts have been repeatedly made\n\nevident by\n\nonbcrg to the Plaintiff and the public through not only the pleadings and correspondence\n\nin this matter, but also through an office press release \n... [truncated, 2284 chars — for the full page use /api/corpus/document/EFTA02734027/266 or ?id=EFTA02734027&page=266]", "char_count": 2284}, {"efta_number": "EFTA02734027", "page_number": 267, "text_content": "Aronbcrg nor the SAO has the authority to demand that the Clerk grant the SAO access to grand jury\nmaterials after a criminal case has concluded.\n\nExhibit \"A\" 1 7.\n\nHence, during Aronbcrg's\n\nadministration, neither he nor his office has accessed grand jury materials from the Clerk's office in\nthis or any other instance. Exhibit \"A\"1 8.\nIII.\n\nConclusion\nThe ultimate facts underlying the lawsuit arc not in dispute. The Court is fully\n\nowered to\n\ndispose of this matter based on application of the undisputed facts to the plain 1 g iagc of Section\n905.17, Florida Statutes, which renders the Plaintiff's action for declarato\n\nimpossibility for\n\nAronbcrg to perfonn and that must be denied as a matter of law.\nWHEREFORE, Defendant, DAVE ARONBERG. as State Attorney of Palm Beach County,\nFlorida, respectfully requests that this motion be granted and that summary final judgment be entered\nin his favor consistent with this motion, and here\n\ncctftlly requests that this Court dismiss the\n\nComplaint with prejudice and grant such othc4f,\n\nuding attorney's fees and costs, as this Court\n\ndeems fit and proper under the circums\nIl CATE OF SERVICE\nI HEREBY CERTIFY this\n\n18th day of August, 2020, a copy of the foregoing has been\n\nelectronically filed with the p o rda E-File Portal for c-service on all parties of record herein.\nSCHOLZ & WYLER, LLC\nAS\nIs/ Douglas A. Wyler\n\n‘.....)\n\nArthur I.\nEsq.\nFla. Bar No.: 10249\nRichard J. Scholz, Esq.\nFla. Bar No.: 0021261\nDouglas A. Wylcr, Esq.\nFla. Bar No.: 119979\n961687 Gateway Blvd., Suite 201-I\nFernandina Beach, Florida 32034\n(904) 261-3693\n(904) 261-7879 Fax\nPrimary: jacobsscholzbw@comcast.nct\n5\n\nEFTA02734294\n\n\f", "char_count": 1658}, {"efta_number": "EFTA02734027", "page_number": 268, "text_content": "General Counselfor the Florida Prosecuting\nAttorney's Antsciatimt\n\nCog\n\n6\n\nEFTA02734295\n\n\f", "char_count": 90}, {"efta_number": "EFTA02734027", "page_number": 269, "text_content": "EXHIBIT \"A\"\n\nEXHIBIT \"A\"\n\nEFTA02734296\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 270, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nCASE NO.: 19-CA-014681\n\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\nDefendants.\nVIT OFD YID AR\nSTATE OF FLORIDA\nCOUNTY OF PALM BEACH\nBefore rnc, the undersigned authority personally appal\n\nDA ID ARONBERG, being first duly sworn,\nASV\n\nstates:\nI.\n\nMy name is David (Dave) Atbn\n\nCircuit/Palm Beach County, Florida, si\n\n13,\n\nadd I am the State Attorney for the Fifteenth Judicial\na Defendant in the above-captioned matter.\n\nrelief, pursuant to Fla. Stat. 905.21(1)(c) and the Court's\ninherent authority, allowing Plaintiff access to the testimony, minutes, and other evidence presented in 2006\n2.\n\nPlaintiff is seeking decla\n\nto the Palm Beach County grand jury, (the \"Requested Materials\"), and to use those materials for the\npurpose of informing the public.\nDespite Plaintiff's above-described action for declaratory relief, neither myself nor the\nOffice of the State Attorney for the Fifteenth Judicial Circuit, (\"SAO\"), is in control, custody, or possession\n3.\n\nof the Rapes Materials.\nAs such, the declaratory relief sought by the Plaintiff seeks materials that are impossible\ny office to produce.\nTo be clear, neither myself nor the SAO has the legal authority to obtain and deliver the\nRequested Materials.\nI have repeatedly made these facts evident to the Plaintiff and the public through not only\nthe pleadings and correspondence in this matter, but also through an office press release and my public\n6.\n\nsocial media accounts.\n\nEFTA02734297\n\n\f", "char_count": 1708}, {"efta_number": "EFTA02734027", "page_number": 271, "text_content": "Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to\ndemand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded.\n7.\n\n8.\n\nMoreover, during my administration, neither myself nor my office has accessed grand jury\n\nmaterials from the Clerk's office in this or any other instance.\nAs provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody and\n9.\npossession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the\nCourt.\nFURTHER AFFIANT SAYETH NAUGHT.\n\nBy:\n\nSTATE OF FLORIDA\nCOUNTY OF PALM BEACH\nSworn to and subscribed before me this 36\nC personally known'to me or has shown\n\nGs'\n\n020, by DAVID ARONBERG, who is\nas personal identification.\n\niss-deoe , st\ntt\nPublic\nt\nNotary's Stamp or Seal,.,, LATOSIMLOWE4OCCE\nCaledoil 414 ICUS\nElan My a at\niris miliestent•\n\nEFTA02734298\n\n\f", "char_count": 915}, {"efta_number": "EFTA02734027", "page_number": 272, "text_content": "Def.Ex.A-12\n\nEFTA02734299\n\n\f", "char_count": 28}, {"efta_number": "EFTA02734027", "page_number": 273, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nCASE NO.: 19-CA-014681\n\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\nDefendants.\nVIT OFD YID AR\nSTATE OF FLORIDA\nCOUNTY OF PALM BEACH\nBefore rnc, the undersigned authority personally appal\n\nDA ID ARONBERG, being first duly sworn,\nASV\n\nstates:\nI.\n\nMy name is David (Dave) Atbn\n\nCircuit/Palm Beach County, Florida, si\n\n13,\n\nadd I am the State Attorney for the Fifteenth Judicial\na Defendant in the above-captioned matter.\n\nrelief, pursuant to Fla. Stat. 905.21(1)(c) and the Court's\ninherent authority, allowing Plaintiff access to the testimony, minutes, and other evidence presented in 2006\n2.\n\nPlaintiff is seeking decla\n\nto the Palm Beach County grand jury, (the \"Requested Materials\"), and to use those materials for the\npurpose of informing the public.\nDespite Plaintiff's above-described action for declaratory relief, neither myself nor the\nOffice of the State Attorney for the Fifteenth Judicial Circuit, (\"SAO\"), is in control, custody, or possession\n3.\n\nof the Rapes Materials.\nAs such, the declaratory relief sought by the Plaintiff seeks materials that are impossible\ny office to produce.\nTo be clear, neither myself nor the SAO has the legal authority to obtain and deliver the\nRequested Materials.\nI have repeatedly made these facts evident to the Plaintiff and the public through not only\nthe pleadings and correspondence in this matter, but also through an office press release and my public\n6.\n\nsocial media accounts.\n\nEFTA02734300\n\n\f", "char_count": 1708}, {"efta_number": "EFTA02734027", "page_number": 274, "text_content": "Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to\ndemand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded.\n7.\n\n8.\n\nMoreover, during my administration, neither myself nor my office has accessed grand jury\n\nmaterials from the Clerk's office in this or any other instance.\nAs provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody and\n9.\npossession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the\nCourt.\nFURTHER AFFIANT SAYETH NAUGHT.\n\nBy:\n\nSTATE OF FLORIDA\nCOUNTY OF PALM BEACH\nSworn to and subscribed before me this 36\nC personally known'to me or has shown\n\nGs'\n\n020, by DAVID ARONBERG, who is\nas personal identification.\n\niss-deoe , st\ntt\nPublic\nt\nNotary's Stamp or Seal,.,, LATOSIMLOWE4OCCE\nCaledoil 414 ICUS\nElan My a at\niris miliestent•\n\nEFTA02734301\n\n\f", "char_count": 915}, {"efta_number": "EFTA02734027", "page_number": 275, "text_content": "Def.Ex.A-13\n\nEFTA02734302\n\n\f", "char_count": 28}, {"efta_number": "EFTA02734027", "page_number": 276, "text_content": "Filing # 115383434 E-Fited 10(21/2020 04:13:35 PM\n\nIN THE CIRCUIT COURT OF THE\nFIFTEENTH JUDICIAL CIRCUIT IN AND\nFOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of THEPALMBEACHPOST,\n\nCASE NO.: 50-2019-CA-0144581-XXXX-MB\nDIVISION: AG\n\nPlaintiff,\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida,\nDefendants.\nPLAINTIFF CA HOLDIN\nNOTICE OF DROPPING STATE ATT\nPlaintiff, CA I IOLDINGS, LLC, pursuant to Fla.\nit has dropped State Attorney, Dave Aronber\n( ic ro\n\n*\n\nAVE ARONBERG\n50(6), hereby notifies the parties that\n\nabove case.\n\nRespectfully submitted,\nGREENBERG TRAURIG, P.A.\nAttorneysfor CA Florida Holdings, LLC. Publisher\nofThe Palm Beach Post\nStephen A. Mendelsohn, Esq.\n401 East Las Olas Boulevard Suite 2000\nBoca Raton, Florida 33486\nTelephone: (561) 955-7629\nFacsimile: (561) 338-7099\nBy: ZilSteMen A. Mendelsohn\nSTEPHEN A. MENDELSOHN\nFlorida Bar No. 849324\nmendelsohnsOgthmcom\nsmithkrivtlaw.com\nFLServicera)gtlaw.com\n\nEFTA02734303\n\n\f", "char_count": 1048}, {"efta_number": "EFTA02734027", "page_number": 277, "text_content": "By: /s/ Michael JGrygiel\nMICHAEL .1 GRYGIEL\n(Admitted Pro Hac Vice)\n54 State St., 6th Floor\nAlbany, New York 12207\nTelephone: (518) 689-1400\nFacsimile: (518) 689-1499\ngrygielm@gtlaw.com\nBy: /s/ Nina D. Boyajian\nNINA D. BOYAJIAN\n(Admitted Pro Hoc Vice)\n1840 Century Park East, Sui\nLos Angeles California\nTelephone: (310) 586-7\nFacsimile: (310) 586-7\n\no\n\nCERTIFICATE 0\nI HEREBY CERTIFY that on this 21\"\n\nOctober, 2020, a true and correct copy of the\n\nforegoing has been filed with the Clerk of\n\nurt Jsing the State ofFlorida e-filing system, which\n\nwill send a notice of electronic servi\n\nriles of record herein\n\n/s/ Stephen A. Mendelsohn\nSTEPHEN A. MENDELSOHN\n\nACTIVE 533173414\n\n2\n\nEFTA02734304\n\n\f", "char_count": 696}, {"efta_number": "EFTA02734027", "page_number": 278, "text_content": "EFTA02734305\n\n\f", "char_count": 15}, {"efta_number": "EFTA02734027", "page_number": 279, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-CA-014681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\n\n444'\n(Y\nC\n\n1\n\nDefendants.\n/\nDEFENDANT DAVE ARONBERG'S AMENDED It i( v\n\nOR ATTORNEYS' FEES\n\nDefendant, DAVE ARONBERG, as State AAt AS4,\nn\n(Palm Beach County, Florida, by and\nthrough the undersigned counsel, hereby mov\n( s 11%i\nhioi g„\nR. Civ. P. to enter an award of attom\nHOLDINGS, LLC, publisher of\n\n' f\n\ncable Court, pursuant to Rule 1.525, Fla.\n\n'n his favor against Plaintiff, CA FLORIDA\n\nBEACH POST, and in support thereof states the\n\nC\n\nfollowing:\n\nBATOR AWARDING ATTORNEYS' FEES\n1.\nBEACH PO\nPalm\n\nO\n\nvem r 14, 2019, CA FLORIDA HOLDINGS, LLC, publisher of the PALM\naintiff') filed a complaint against DAVE ARONBERG, as State Attorney of\n\nunty, Florida (the \"State Attorney\" or \"Defendant Aronberg\") and SHARON R.\n\nBOCK, as Clerk and Comptroller of Palm Beach County, Florida (the \"Clerk\"). The basis of the\naction was asking the Court to order the State Attorney and the Clerk to disclose the 2006 Jeffrey\nEpstein grand jury materials, (the \"Requested Materials\"), pursuant to § 905.27(1) Fla. Stat.\n\nEFTA02734306\n\n\f", "char_count": 1351}, {"efta_number": "EFTA02734027", "page_number": 280, "text_content": "2.\n\nOn December 6, 2019, the State Attorney filed his Motion to Dismiss, then on\n\nDecember 13, 2019, the Clerk also filed a Motion to Dismiss. In response, Plaintiff filed its First\nAmended Complaint on January 17, 2020, which in addition to its original claim under § 905.27\nFla. Stat. (Count II) added a claim for Declaratory Relief (Count I) that sought an order declaring\nthat the State Attorney and the Clerk disclose the Requested Materials to Plaintiff for the purpose\nof informing the public.\n3.\n\nAsic\n's\nir Answer to\n\nOn January 24, 2019, both the State Attorney and the Cle\n\nthe First Amended Complaint and Motion to Dismiss Count 11 (\"\n\nO\n\nNotably, the State Attorney's Answer/Motion to Dismiss asse\nAV\n\nt to attorneys' fees for\n\n'ts\n\ntion to Dismiss).\n\ndefending the action and requested such relief from the Cc)\n4.\n\nOn June 8, 2020, the Court ente reSSs t d\n\nDismiss Count II of Plaintiff's First Amended\n5.\n\nla\n\nImmediately following t\n\nthrough the undersigned counsel,\nto voluntary dismiss/withdraw\nAttorney, along with a\n\n'\n\nGranting Defendants Motions to\n\nwith Prejudice (\"Order\").\n\nOrder, on June 8, 2020, the State Attorney,\nmiff with a demand pursuant to § 57.105 Fla. Stat.,\nAmended Complaint and the claims against the State\n\nfor Attorneys' Fees (\"57.105 Demand\"). See, Exhibit \"A\".\n\nSpecifically, ber\n\nof te Court's Order only Count I of Plaintiff's Amended Complaint\n\nremained, w\n\nht Declaratory Relief under § 86.011, Fla. Stat.\nere, in properly serving his 57.105 Demand on Plaintiff, the State Attorney also\n\nproperly put Plaintiff on notice that he would seek sanctions by filing the 57.105 Motion for\nAttorneys' Fees if Plaintiff failed to dismiss the remainder of its First Amended Complaint within\n21 days of service of the 57.105 Demand and Motion for Attorneys' Fees.\n\n2\n\nEFTA02734307\n\n\f", "char_count": 1820}, {"efta_number": "EFTA02734027", "page_number": 281, "text_content": "7.\n\nOn June 23, 2020, Plaintiff's counsel sent a response to the 57.105 Demand\n\nrefusing to withdraw the remainder of the First Amended Complaint. See, Exhibit \"B\".\n8.\n\n§ 57.105, Florida Statutes states the following:\n\nA motion by a party seeking sanctions under this section must be served but may\nnot be filed with or presented to the court unless, within 21 days after service of the\nmotion, the challenged paper, claim, defense, contention, allegation, or denial is not\nwithdrawn or appropriately corrected.\n9.\n\nAccordingly, after receiving Plaintiff's June 23, 2020, re\n\nwithdraw the remainder of the First Amended Complaint and waiting th\nafter service of the motion\" the State Attorney's Motion for Attom\nCourt on July 1, 2020. See, Exhibit \"C\".\n10.\n\na,\\\nict\n\nThereafter, on August 18, 2020, the St\n\nJudgment (\"Motion\") and proceeded, on October\nState Attorney's Motion (\"Motion to Set\") a\n\nt\n\nrefusing to\n'site \"21 days\nwas filed with this\n\ny filed his Motion for Summary\n\n0, to file a Motion to Set Hearing on the\n\name clear that there would be no resolution\n\nof this matter without the Court's int\n11.\n\nNonetheless, latC\n\non the merits as to State Attorney\n\neI)\n\nday, rather than setting and participating in a hearing\n\notion, Plaintiff filed its Notice of Dropping the State Attorney\n\n(\"Notice\") from the' start as See, Exhibit \"13\". As a consequence of filing its Notice, Plaintiff\nhas effectivelyiygrde\nfact or la\n1\n12.\n\ndmission that its allegations against the State Attorney have no basis in\n\n\"An essential distinction between a notice of dropping a party and a voluntary\n\ndismissal is that the former concludes the action as to the dropped party while the latter is generally\nutilized to conclude the action in its entirety.\" Carter v. Lake County, 840 So. 2d 1153, 1155 (Fla.\n5th DCA 2003).\n\n3\n\nEFTA02734308\n\n\f", "char_count": 1828}, {"efta_number": "EFTA02734027", "page_number": 282, "text_content": "13.\n\nSpecifically, Plaintiff's Notice states: \"Plaintiff, [sic], pursuant to Fla. IL Civ. P.\n\n1.250(b), hereby notifies the parties that it has dropped State Attorney, Dave Aronberg from the\nabove case.\"\n14.\n\nRule 1.250(b), Fla. R. Civ. P. states:\n\n(b) Dropping Parties. Parties may be dropped by an adverse party in the manner\nprovidedfor voluntary dismissal in rule 1.420(a)(1) subject to the exception ted\nin that rule. If notice of lis pendens has been filed in the action against a •\no\ndropped, the notice of dismissal shall be recorded and cancels the\nof s\npendens without the necessity of a court order. Parties may be drop\nder of\ncourt on its own initiative or the motion of any party at any sta\n( ke\non on\nsuch terms as are just.\n15.\n\nRule 1.420(aX1), Fla. R. Civ. P., Voluntary Distyissal states:\n\n(1) By Parties. Except in actions in which prope\nn seized or is in the\ncustody of the court, an action, a claim, or an\naction or claim may be\ndismissed by plaintiff without order of co\n) f trial by serving, or during\ntrial by stating on the record, a notice of\n• al any time before a hearing on\nmotion for summary judgment, or if no t\nor if the motion is denied, before\nretirement of the jury in a case tried\nea j y or before submission of a nonjury\ncase to the court for decision, or (A) by ng a stipulation of dismissal signed by\nall current parties to the actio9J1nlessetherwise stated in the notice or stipulation,\nthe dismissal is without prejdice. except that a notice of dismissal operates as an\nadjudication on the mer wheiksetved by a plaintiff who has once dismissed in\nany court an action bas on 4Pincluding the same claim.\n16.\n\nNotably, \"\n\n1.250(b) expressly incorporates the procedural aspects of Florida\n\nRule of Civil Pro~4I.\n\n0(aX1) governing voluntary dismissal by providing that parties may\n\nbe dropped\n\nmanner provided for voluntary dismissal in rule 1.420(aX1) subject to the\nin that rule.\" Siboni v.\n\nexcep\n17.\n\n52 So. 3d 779, 780 (Fla. 5th DCA 2010).\n\nLikewise, because \n... [truncated, 2343 chars — for the full page use /api/corpus/document/EFTA02734027/282 or ?id=EFTA02734027&page=282]", "char_count": 2343}, {"efta_number": "EFTA02734027", "page_number": 283, "text_content": "18.\n\nAccordingly, the Siboni court held that a \"party dropped from litigation under rule\n\n1.250(b) is subject to the time limitation contained in rule 1.525 governing service of a motion\nseeking a judgment for costs and attorney's fees.\" Id.\n19.\n\nAlthough Plaintiff filed its Notice the claims asserted by Plaintiff have been, since\n\nthe filing of its initial complaint, completely without support of the facts or the law. At their very\ncore, all of Plaintiff's claims are based on the presumption that the State Attorney\n\nauthority\n\nto disclose the Requested Materials. Nonetheless, Section 905.17(1), FloriCi\n\nmakes clear\n\nthat Plaintiffs Requested Materials can only be released by the Clerk\n\na court order.\n\nThe stenographic records, notes, and transcriptions ma\nourt reporter or\nstenographer shall be filed with the clerk who shall k\nin a sealed container\nnot subject to public inspection. The notes, r\nd transcriptions are\nconfidential and exempt from the provisions ofA14/.\n) and s. 24(a), Art. I of\nthe State Constitution and shall be released\nh e only on request by a grand\njuryfor use by the grand jury or on order\nco t pursuant to s. 905.27.\nSection 905.17(1), Florida Statutes (2020).\n20.\n\nThe State Attorney h\n\ntion to the Clerk producing and disclosing the\n\nRequested Materials should the\n\nt an order to that effect, however, it is impossible for\n\nthe State Attorney to comply\n\nthe relief sought by Plaintiff in its remaining claim for\n\ndeclaratory relief as e do\n\nno possess or control the Requested Materials and is statutorily barred\nYYY\n\nfrom any disc\n21.\n\nough the State Attorney was prepared to make his argument to the Court,\n\nPlaintiff &Sided instead to drop him as a party. Despite Plaintiff's decision, the Florida Rules of\nCivil Procedure and the above authorities make clear that because Rule 1.250 specifies that a party\nis dropped \"in the manner provided for voluntary dismissal in Rule 1A20(a)(1),\" it therefore\n\"operates as an adjudication on the merits.\" See, Siboni v.\n... [truncated, 2095 chars — for the full page use /api/corpus/document/EFTA02734027/283 or ?id=EFTA02734027&page=283]", "char_count": 2095}, {"efta_number": "EFTA02734027", "page_number": 284, "text_content": "22.\n\nConsequently, the filing of Plaintiff's Notice triggered Rule 1.525, Fla. IL Civ. P.\n\nand therefore:\nUnder [§ 57.105], the legislature has expressed its unequivocal intent that where a\nparty files a meritless claim, suit or appeal, the party who is wrongfully required to\nexpend funds for attorneys' fees is entitled to recoup those fees.\nCounty Conservation Alliance v.\n\nCounty, 73 So. 3d 856, 857 (Fla. 1st DCA 2011)\n\n(finding that \"Courts are not at liberty to disregard the legislative mandate that coutebfigll impose\nsanctions in cases without foundation in material fact or law. The word \"\nStat., evidences the legislative intent to impose a mandatory penalty t\nby placing a price tag on losing parties who engage in these a\nstates courts \"shall\" assess attorney's fees for bringing,\n\ns\n\n'\n\n57.105, Fla.\nbaseless claims,\n\n'on 57.105 expressly\n\nit\n\ndismiss, baseless claims or\n\nIn fact, \"Section 57.105(1) clepr y eplicitly\n\nconfers upon the trial court the\n\ndefenses.\").\n23.\n\nauthority to award attorney's fees to the\n\nnth g party upon the court's initiative, if `the court\n\nfinds that the losing party . .. kne\n\nd have known that a claim or defense when initially\n\npresented to the court or at a\nnecessary to establish thLir.-\n\nr\n\nefore trial .\nor defense.\"\n\n[w]as not supported by the material facts\nv. MI 47 So. 3d 320, 324 (Fla. 2d DCA\n\n2010).\n24.\nComp\n\nTh\n\nmple fact of the matter is that Plaintiff failed to withdraw its Amended\n\nst the State Attorney within the 21-day period provided for in section 57.105(4),\n\nand therefore the State Attorney was pen-flitted to file his 57.105 Motion for Attorneys' Fees as\nsanctions.\n25.\n\nFurthermore, based on the impossible nature of Plaintiff's demand of the State\n\nAttorney, it was proper to demand withdrawal of Plaintiff's remaining claim for declaratory relief\n\n6\n\nEFTA02734311\n\n\f", "char_count": 1842}, {"efta_number": "EFTA02734027", "page_number": 285, "text_content": "and serve the 57.105 Motion for Attorneys' Fees due to Plaintiff's claim lacking any basis in fact\nor law. Again, neither the State Attorney nor his office has possession, custody or control of the\nRequested Materials. Likewise, the State Attorney has no objection, and never has had any\nobjection, to the Clerk releasing the records sought by Plaintiff, as disclosure of the Requested\nMaterials sought by Plaintiff lies solely within the providence of the Clerk pursuant to an order of\nthe Court.\n26.\n\nConsequently, the State Attorney is entitled to recover\n\nA\n\nAS's ) reasonable\n\nattorneys' fees in defending this suit by virtue of 57.105, Florida Sta\nREASONABLENESS AND AMOUNT OF AT\n27.\n\nFrom the service of the 57.105 Demand tot\n\nthe State Attorney have rendered 42.2 hours of legS\n\nFEES\nthis motion, the attorneys for\n\nSis\nin er or a total amount of $18,275.00 in\n\ndefending this action. See time sheets detail\ne\n:t e\n\nount of hours by each timekeeper, the\n\ntimekeeper's hourly rate, and a descri '\n\nof\ns\n\nExhibit \"E\". Of that amount, the\n\ned has been paid $0.00 as the engagement with the\n\nState Attorney is on a pure con\n4.0 hours at $425.00 an hr\nthe total amount\n$19,975.00.\nwhen\n\ne\n\nurly\n\nen\n\ntasks done during those times, on attached\n\nfee basis. The undersigned expects to incur an additional\n\npreparing for and attending the hearing on attorneys' fees. Thus,\nomeys' fees the State Attorney is seeking is 46.2 hours for a total of\n\nther set forth below, the State Attorney also seeks a multiplier of 2.0, which\n\nakes the grand total attorneys' fees as sanctions sought herein $39,950.00.\n\n28.\n\nAn Affidavit of Attorneys' Fees is attached hereto as Exhibit \"F\", which details\n\nand breaks down the attorneys' fees sought herein.\n\nEFTA02734312\n\n\f", "char_count": 1755}, {"efta_number": "EFTA02734027", "page_number": 286, "text_content": "29.\n\nThe State Attorney would offer the following facts and arguments as they relate to\n\nthe factors promulgated in Rule 4-1.5 of the Rules Regulating the Florida Bar and Florida Patient's\nCompensation Fund v.IM, 472 So. 2d 1145 (Fla. 1985):\n\nFactor\n\nFacts and Arguments\n\n(A) the time and labor\nrequired, the novelty,\ncomplexity, and difficulty\nof the questions involved,\nand the skill requisite to\nperform the legal service\nproperly\n\nThe time involved by counsel was substantial, consu ng nearly\ny were\n75 hours of legal work. Moreover, the issues in c\nnovel and complex in that Plaintiff sought to c to ne private\nstatutory cause of action under Florida Statu • • I\n, implicated\nseveral 1st Amendment issues, and f\ni i ght declaratory\nrelief pursuant to said Statute. Finall\n. gation has been\nongoing for nearly a year and required ' 1\nknowledge in these\nareas of the law.\n(B) the likelihood that the Because of the amount of ti inv lved in this litigation and\nacceptance of the\nconsidering the relative smarsize • lefirtn representing the State\nparticular employment\nAttorney, the undersigned attorneys were forced to turn away or\nwill preclude other\ndelay representing 44 - clients especially during critical stages of\nem lo ent b the law er the liti ation due time required in the instant matter.\n(C) the fee, or rate of fee, The base fees c • .1. isting of $425.00/hour for Mr. Wyler's services\ncustomarily charged in the and $475.00 ,os for Mr.\nservices are reasonable for\nlocality for legal services lawyers '\nheir respective communities possessing equal\nof a comparable or similar expert e\nill.\nnature\n(D) the significance of, or T e out\ne of this case is of great public significance to the State\namount involved in, the\no lo 'kia as it pertains to the disclosure of grand jury records and\nsubject matter of the\nthe e of the State Attorney concerning such disclosure. Here.\nrepresentation, and the\nresults obtained were the maximum sought by Defendant\nresults obtained? s\n,\nAronberg as he w\n... [truncated, 2845 chars — for the full page use /api/corpus/document/EFTA02734027/286 or ?id=EFTA02734027&page=286]", "char_count": 2845}, {"efta_number": "EFTA02734027", "page_number": 287, "text_content": "(G) the experience,\nreputation, diligence, and\nability of the lawyer or\nlawyers performing the\nservice and the skill,\nexpertise, or efficiency of\neffort reflected in the\nactual providing of such\nservices\n(H) whether the fee is\nfixed or contingent, and, if\nfixed as to the amount or\nrate, then whether the\nclient's ability to pay\nrested to any significant\ndegree on the outcome of\nthe representation.\n\nThis representation required experience in a field available to few\nlawyers, which included defending the State Attorney from claims\nof a media entity and lawyers from multiple states regarding the\nrelease of information with a nationwide interest. Accordingly, the\nundersigned counsel conducted the representation with skill and\nefficiency wherein Defendant Aronberg was dismissed from the\naction prior to any hearing on the merits before the court.\n\nThe fee arrangement herein was entirely contin en\nobtaining a fee was conditioned upon prevailing a\norder awarding fees.\nCO\n\nwherein\nfining an\n\nAS\n\n\"ask\n\nJUSTIFICATION FOR MU\n30.\n\nDefendant Aronberg was able to pro\n\n's litigation only if counsel would\n\nreceive a court order awarding contingency\n\nAs , s' fees upon achievement of a successful\n\noutcome in this case. See, Exhibit \"C\".\n\nen t s and the fact that counsel risked a total of 74.8\n\nhours of work for no pay, of w\n\nours is subject to the 57.105 Demand, Defendant\n\nAronberg submits that multipf\nexpended, the hourly rates\nof attorneys' fee\n31.,\n\nof\n\nwould be appropriate in this case. Based upon the hours\n\n2.0 multiplier, Defendant Aronberg respectfully requests an award\n\nanew s as stated herein.\nregard to the application of a multiplier, the court must analyze the three\nin Standard Guaranty Insurance Co. v. Quanstrom, 555 So. 2d 828 (Fla. 1990):\n\n(1) whether the relevant market requires a contingency fee multiplier to obtain\ncompetent counsel; (2) whether the attorney was able to mitigate the risk of\nnonpayment in any way; and (3) whether any of the factors set forth in\nare\nappl\n... [truncated, 2232 chars — for the full page use /api/corpus/document/EFTA02734027/287 or ?id=EFTA02734027&page=287]", "char_count": 2232}, {"efta_number": "EFTA02734027", "page_number": 288, "text_content": "32.\n\nHere, as to the first factor there was no other counsel in the relevant market who\n\nwould agree to represent Defendant Aronberg under the contingency fee agreement needed due to\nthe financial situation of the Office of the State Attorney as a public entity funded entirely by the\ntaxpayers of the State of Florida. Although \"Risk Mitigation\" within the Florida Department of\nFinancial Services and the Office of the Attorney General indeed represent the State Attorney in\nsome instances, this case was not picked up by either and Defendant Aronberg\n\nneeding\n\nrepresentation by other, private counsel. Although the undersigned couns0\n\nlaw firm are\n\nGeneral Counsel for the Florida Prosecuting Attorneys' Association n .,\n\nAA\") the instant\n\nmatter did not fall within the scope of representation for th\nengagement between Defendant Aronberg and the u(7, ig\n\nnd required a separate\ncounsel.\n\nAccordingly, the\n\nundersigned counsel and his law firm agreed to rep\ni it*\ne,i, efendant Aronberg on a contingency\nfee basis and to try the case to final judgments,\nto represent Defendant Aronberg on suc\n33.\n\nWith respect to the\n\nforth in Quanstrom, here Defe\nbecause as a purely taxp\nwhich to pay th\nindividual R\non the\n\ns.\n\nic\n\ng that there was no other counsel willing\n\nors to be considered in applying a multiplier as set\nnberg was unable to mitigate against non-payment of fees\n\nded entity, the Office of State Attorney had no other means by\ned counsel. Additionally, Defendant Aronberg meets each of the\n\nors as set forth in the table located above on pages 8-9. Accordingly, based\nthe application of a multiplier herein is proper. In this vein, the\n\ncourt set\n\nguidelines for the size of a multiplier, as follows:\nBased on our review of the decisions of other jurisdictions and commentaries on\nthe subject, we conclude that in contingent fee cases, the lodestar figure calculated\nby the court is entitled to enhancement by an appropriate contingency risk\nmultiplier in the range from 1.5 to 3. When \n... [truncated, 2221 chars — for the full page use /api/corpus/document/EFTA02734027/288 or ?id=EFTA02734027&page=288]", "char_count": 2221}, {"efta_number": "EFTA02734027", "page_number": 289, "text_content": "be 2; and, when success was unlikely at the time the case was initiated, the\nmultiplier should be in the range of 2.5 to 3.\nFlorida Patient's Compensation Fund v.\n34.\n\n472 So. 2d 1145 (Fla. 1985).\n\nAdditionally, the Quanstrom court confirmed and modified the\n\napproach, as\n\nfollows:\nHowever, we find that the multiplier in\nshould be modified as follows: the\ntrial court determines that success was more likely than not at the outse\ny\napply a multiplier of 1 to 1.5; if the trial court determines that the lilthlihood f\nsuccess was approximately even at the outset, the trial judge may apply a multiplier\nof 1.5 to 2.0; and if the trial court determines that success was unli*ly at the outset\nof the case, it may apply a multiplier of 2.0 to 2.5. According! , o ?Rowe decision\nis modified to allow a multiplier from 1 to 2.5.\nStandard Guaranty Insurance Co. v. Quanstrom, 555 So. 2\n\n(Fla. 1990). Thus, based\n\nupon all of the foregoing factors, Defendant Aronberg \\ p\n\ny submits that a multiplier of 2.0\n\nis appropriate for this representation.\nCERTIFICATION OF GO\nThe undersigned certifies that\nthis motion by agreement oft\nissues of entitlement to fees or t\nWHEREFO\nCounty, Flori\nhis reaso\nHOLDIN\n\nD\n\nAL\n\nI EFFORT TO RESOLVE\n\nth effort was made to resolve the issues raised in\nThe parties were unable to resolve by agreement the\nount of fees.\n\nant, DAVE ARONBERG, as State Attorney of Palm Beach\n\nat this Honorable Court will enter an Order awarding Defendant Aronberg\nmeys' fees with a multiplier of 2.0 against the Plaintiff, CA FLORIDA\nLW, publisher of the PALM BEACH POST, in the amount of $39,950.00.\nCERTIFICATE OF SERVICE\n\nI HEREBY CERTIFY that on this 9th day of November, 2020, a copy of the foregoing\nDefendant, Dave Aronberg's Amended Motion for Attorneys' Fees has been electronically filed\nwith the Florida E-File Portal for e-service on all parties of record herein.\n\n11\n\nEFTA02734316\n\n\f", "char_count": 1901}, {"efta_number": "EFTA02734027", "page_number": 290, "text_content": "SCHOLZ & WYLER, LLC\n/s/ Douglas A. Wyler\nArthur\nFla. Bar No.: 10249\nRichard J. Scholz, Esq.\nFla. Bar No.: 0021261\nDouglas A. Wyler, Esq.\nFla. Bar No.: 119979\n961687 Gateway Blvd., Suit\nFernandina Beach, Flori • < 4,4134\n(904) 261-3693\n(904) 261-7879 Fax\nPrimary: jacobss\n,comcast.net\nAttorneys\n\nnt, Dave Aron berg\n\n12\n\nEFTA02734317\n\n\f", "char_count": 334}, {"efta_number": "EFTA02734027", "page_number": 291, "text_content": "EXHIBIT \"A\"\n\nEXHIBIT \"A\"\n\nEFTA02734318\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 292, "text_content": "Friday, September 18, 2020 at 11:09:24 Eastern Daylight Time\nSubject:\n\nSERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, LLC V.\nDAVE ARONBERG ET AL.\n\nDate:\n\nMonday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time\n\nFrom:\n\nDouglas Wyler\n\nTo:\n\n'mendelsohns@gtlaw.com', smith' ®gtlaw.com, flservice@gtlaw.com, BoyajianN®gtlaw.com,\nriveraal@gtlaw.com, GRYGIELM @gtlaw.com\n\nAttachments: 2020.06.08 Aron berg 57.105 Demand and Motion for Attorneys' Fees.pdf\nPlease see attached and below in this matter.\nCourt:\nCase No:\nPlaintiff:\nDefendant:\nTitle of Documents\nServed:\nSender's Name and\nTelephone Number:\n\nCircuit Court of the Fifteenth Judicial Circuit, in and for Palm Beachtounty,\n\\\nFlorida\ns - ''s\nCase No. 2020-CA-014681\nON\nCA Florida Holdings, LLC\nDave Aronberg\n• Fla. Stat. § 57.105 Demand Letter\n( 1)\n• Defendant, Dave Aronberg's Motionfor attorneys' Fees\nDouglas Wyler\n(904) 261-3693\n\nAc-N\n\nSincerely,\nDoug Wyler, Esq.\nScholz & Wyler, LLC\n961687 Gateway Blvd., STE 201-I\nFernandina Beach, FL 32034\n904-261-3693\n904-261-7879 (fax)\ndoug.wyleracomcast.net\nPlease be advised that this e-mail and any files transmitted with it are confidential attorney-client\ncommunication or may otherwise be privileged or confidential and are intended solely for the individual or\nentity to whom they are addressed. If you are not the intended recipient, please do not read, copy or\nretransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or\ncopying of this communication is strictly prohibited.\n\nPage 1 of 1\n\nEFTA02734319\n\n\f", "char_count": 1579}, {"efta_number": "EFTA02734027", "page_number": 293, "text_content": "A LIMITED L\nTilt LAW orricts Or\n\na ASSOCIATES. PA.\nARTHUR I.\n\nSCHOLZ & WYLER, LLC.\n\nMU TY COMPANY OF PROFESSIONAL ASSOCIATIONS\n\nATTORNEYS AT LAW\nGATEWAY TO AMELIA\n961007 GATEWAY BLVD.. SUITE aO1-1\nFERNANDINA BRACK FLORIDA 32034\n\nRICHARD J. SCHOLZ. P.A.\nRICHARD J. SCHOLZ\nDOUGLASA. WYLER, P.A.\nDOUGLAS A. WYLER\n\nTELEPHONE (904) 261.3693\nFAX NO. (904) 261.7679\n\nJune 8, 2020\n\nVIA ELECTRONIC & U.S. MAIL\nStephen A. Mendelsohn, Esq.\nGreenburg Traurig, PA.\n5100 Town Center Circle, Suite 400\nBoca Raton, FL 33486\nRE:\n\nCos\n\nCA Florida Holdings, LLC v. Dave Aronbe\nPalm Beach County, Case No.: 2019-CA,.d\n\nDear Mr. Mendelsohn:\nAs you are aware our firm represents the intere\nCounty, Florida, in the above referenced\ndismissal of your First Amended Complai\nis made pursuant to section 57.105, Fl\n\nAronberg, as State Attorney ofPalm Beach\ntirpose of this letter is to demand the voluntary\nomplaint\"), dated January 17, 2020. This demand\n\nAs you know, Section 57\n(1) Upon the court's\ne or motion of any party, the court shall award a\nreasonable a mey's ee, including prejudgment interest, to be paid to the\nprevailing p\nual amounts by the losing party and the losing party's attorney\non any im o efense at any time during a civil proceeding or action in which\nthe\nInds that the losing party or the losing party's attorney knew or should\nthat a claim or defense when initially presented to the court or at any\nore trial:\nWas not supported by the material facts necessary to establish the claim or\ndefense; or\nb. Would not be supported by the application of then-existing law to those\nmaterial facts.\nToday, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count II of the\nPlaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action\nconsists of Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein\nand its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to\nestabl\n... [truncated, 2138 chars — for the full page use /api/corpus/document/EFTA02734027/293 or ?id=EFTA02734027&page=293]", "char_count": 2138}, {"efta_number": "EFTA02734027", "page_number": 294, "text_content": "First and foremost, the Complaint is not supported by the material facts necessary to establish the\nclaims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the\nFifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein.\nSimply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are\nimpossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to\nthis action because no matter what, he and his office do not have possession, custody, or control of the\nrequested materials.\nIn addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims\nare also not supported by the application of current law. Specifically, your action ford laratory relief\nfails based on the clear, unambiguous statutory language found in Section 905.27(2 Fl rids Statutes,\nwhich states:\nuse in a civil\nWhen such disclosure is ordered by a court pursuant to subsection (\nby the latter\ncase, it may be disclosed to all parties to the case and to their atto\nto their legal associates and employees. However the rand\nonv afforded\nsuch persons by the court can only be used in the defense or p\non ofthe civil or\ncriminal case and for no other purpose whatsoever.\nMoreover, even if the Plaintiff were to prevail in the decla\nto comply with any court order granting disclosure of\nAronberg nor The Office of the State Attorney fo\ncustody, or control of the 2006 Epstein grand ju\nBased on the foregoing, if the Complaint is\nthe enclosed Motion for Attorney's Fees '\nand your firm, recovery of the legal ex\n\nMr. Aronberg would be unable\ndocuments because neither Mr.\nnth Judicial Circuit have possession,\n\nsed within 21 days of the service of this letter,\ned and we will seek as sanctions, from your client\nerred in defending this frivolous action.\n\nPlease govern yourself accordin\n\nDouglas A. Wyler, Esq.\nFor the Finn\nEnd.: Defe\n\nion for Attorney\n... [truncated, 2024 chars — for the full page use /api/corpus/document/EFTA02734027/294 or ?id=EFTA02734027&page=294]", "char_count": 2024}, {"efta_number": "EFTA02734027", "page_number": 295, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-CA-O14681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\ng\nDefendants.\n\nAtIC\n\nDEFENDANT, DAVE ARONBERG'S M\n\nR ATTORNEYS' FEES\n\nDefendant, DAVE ARONBERG, as Staff\n\nof Palm Beach County, Florida, by and\n\nthrough the undersigned attorneys, move\nto award him reasonable attorneys'\n\n, pursuant to Florida Statutes, Section 57.105,\ne defense of Plaintiff's First Amended Complaint,\n\n(the \"Complaint\"), and as gro\n\nr, would show that on June 8, 2020, Plaintiff was served\n\na copy of this Motion, togeth\n\na letter from the undersigned attorney, in accordance with\n\nsubsection (4) of the abo\nto the filing o\nestabli\n\nis\n\ntute, demanding dismissal of the Complaint, at least 21 days prior\n\non. In said letter, Defendant's attorney advised Plaintiff of the facts which\nmplaint is without support of the facts or the law.\n\nREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach\nCounty, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's\nattorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.\n\nEFTA02734322\n\n\f", "char_count": 1360}, {"efta_number": "EFTA02734027", "page_number": 296, "text_content": "CERTIFICATE OF SERVICE\nI hereby certify that on this\n\nday\n\n, 2020, the foregoing was electronically filed\n\nvia the Florida E-File Portal for electronic service on the parties of record herein.\nSCHOLZ & WYLER, LLC\nA/ Douglas A. Wyler\nArthur I.W\nEsquire\nHa. Bar No.: 108249 tic\n,\nRichard J. Scholz, E\nFla. Bar No.: 0021\nDouglas A. Wyl\nFla. Bar No.: 1\n961687 Gate\nd., Suite 201-I\nFernan4jflach,Florida 32034\n9\nzlaw@comcast.net\nttorneysfor Defendant\n\nGs'\n\nEFTA02734323\n\n\f", "char_count": 467}, {"efta_number": "EFTA02734027", "page_number": 297, "text_content": "EXHIBIT \"B\"\n\nEXHIBIT \"B\"\n\nEFTA02734324\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 298, "text_content": "GT GreenbergTraurig\nStephen A. Mendelsohn\nTel 561.955.7629\nFOX 561.659.9119\n\nmendelsohns@gtlaw.com\n\nJune 23, 2020\nDouglas A. Wyler\nJacob Scholz & Wyler, LLC\n961687 Gateway Blvd.\nSuite 201-I\nFernandina Beach, Fl. 32034\nRe:\n\nCA Florida Holdings, LLC v. Dave Arenberg el at.\nCase No. 2019-CA-014681\n\nA\nCos\n\nDear Mr. Wyler:\nWe are in receipt of your letter of June 8, 2020 with yeti\ned Fla. Stat. section 57.105 motion.\nIn your letter and your proposed motion, you assert that\nFlorida Holdings, LLC and the law\nfirm of Greenberg Tinting, P.A. should be li ble (the attorneys' fees to be incurred by State\nAttorney Aronberg after the date of your I\nYo letter cites to Fla. Stat. sections 57.105(1)\n(a) and (b) for support. As shown below\nre t o basis for a Fla. Stat. section 57.105 motion,\nand we expect that if the State Attom\nmake such a motion, the court should deny it.\nYour letter omits a citation to s\nmay not be awarded where\nreversal of existing law or the es\na reasonable expectation\n\n5(3). Subsection 57.105(3)(a) provides that sanctions\ngood faith argument for the extension, modification or\nhtnent of new law, as it is applied to the material facts, with\n\" We have such a good faith argument.\n\nContrary to your\nlysis df Fla. Stat. section 905.27, there are actually three instances where a\ncourt may ord t e\nse of grand jury materials. As we argue, the court may order release \"in\na\nfurtherance jus\n' There are few cases in Florida reviewing this provision and its scope. It is\nan open and v\nestion as to whether the court may order release of grand jury transcripts to\nthe med1under both the statute and the First Amendment to the US Constitution in furtherance\nof justice. the statutory language you cite refers to instances where a person is seeking grand jury\nmaterials for use in a civil or in a criminal case. In these limited situations, the statute allows for\nsuch uses and for no other reason. However, the statute does not state, as you assert, that where\nthe media seeks grand jury\n... [truncated, 2882 chars — for the full page use /api/corpus/document/EFTA02734027/298 or ?id=EFTA02734027&page=298]", "char_count": 2882}, {"efta_number": "EFTA02734027", "page_number": 299, "text_content": "Correspondence to Douglas A. Wyler\nJune 23, 2020\nPage 2\nuse limitation you cite applies. No reported Florida case has addressed this issue and there is a\ngood faith basis for our view of Fla. Stat. section 905.27\nYour letter also argues that sanctions are applicable because the State Attorney has alleged that it\ndoes not possess the Jeffrey Epstein grand jury transcripts. This allegation is also contained in the\nState Attorney's Answer. Assuming that the State Attorney does not currently\ne physical\npossession of the Epstein grand jury materials, which has yet to be demonstrated, s\ns not end\nthe matter. The State Attorney was named as a party not simply as a custo\nnd jury\nrecords. The State Attorney was named in his official capacity as his office\nas its primary\ninterest the protection of its grand jury system.\" [Italics in original.] In re rand Jury Proceedings,\n832 F. 3d 554, 559 (11th Circuit 1987). In that case, the US petitioned\nate judge to order the\nState Attorney to turn over grand jury transcripts. The State Attome argtt\ninst their release\nciting to Fla. Stat. section 905.27. Later, a federal grand jury subp a the Broward County\nState Attorney for delivery of state grand jury testimony. The\nd tate Attorney advised the\nfederal court that it would produce the transcripts, thereby\nrating that while it may not\nhave physical possession of the materials, he had legal autl\no obtain and deliver them. It\nshould also be noted that the State Attorney moved t\ne subpoena arguing that it was\nunlawful under Florida law and Fla. Stat. section 9\ncase indicates that where one seeks\ngrand jury materials, the relevant State Attorney,\nsary patty in order to protect the grand\njury that the Office of State Attorney supervis\nn o ake arguments, if need be, against release\nof the grand jury materials. These are some f same reasons why the State Attorney was named\nin this case.\nAlso, assuming the State Attome\nve physical possession of the grand jury materials,\nthere is nothing in Flor\n... [truncated, 2732 chars — for the full page use /api/corpus/document/EFTA02734027/299 or ?id=EFTA02734027&page=299]", "char_count": 2732}, {"efta_number": "EFTA02734027", "page_number": 300, "text_content": "Correspondence to Douglas A. Wyler\nJune 23, 2020\nPage 3\n\nFor these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed\nagainst the Office of the State Attorney. We expect that your demand will be withdrawn.\nThank you,\nVery truly yours,\nIs/Stephen Mendelsohn\nStephen Mendelsohn\n\nSAM:Is\n\nACTIVE 51081659v1\n\nGreenberg Tranrig, P.A. I Attorneys at raw\nvnyvtlaw.corn\n\nEFTA02734327\n\n\f", "char_count": 411}, {"efta_number": "EFTA02734027", "page_number": 301, "text_content": "EXHIBIT \"C\"\n\nEXHIBIT \"C\"\n\nEFTA02734328\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 302, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-CA-014681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\nCO\n\nSA\n\nDefendants.\n\nDEFENDANT. DAVE ARONBERG'S MO\nDefendant, DAVE ARONBERG, as State\n\n\\\n\nATTORNEYS' FEES\n\ney f Palm Beach County, Florida, by and\n\nthrough the undersigned attorneys, moves t\n\nurt, ursuant to Florida Statutes, Section 57.105,\n\nto award him reasonable attorneys'\n\ndefense of Plaintiff's First Amended Complaint,\n\n(the \"Complaint\"), and as grotire\n\n, would show that on June 8, 2020, Plaintiff was served\n\na copy of this Motion, together • a letter from the undersigned attorney, in accordance with\nrr\nsubsection (4) of th b v\ntute, demanding dismissal of the Complaint, at least 21 days prior\nto the filing of 'i\nestablish\nWW\n\non. In said letter, Defendant's attorney advised Plaintiff of the facts which\nmplaint is without support of the facts or the law.\n\nREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach\n\nCounty, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's\nattorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.\n\nEFTA02734329\n\n\f", "char_count": 1380}, {"efta_number": "EFTA02734027", "page_number": 303, "text_content": "CERTIFICATE OF SERVICE\nI hereby certify that on this 1st day July, 2020, the foregoing was electronically filed via\nthe Florida E-File Portal for electronic service on the parties of record herein.\nSCHOLZ & WYLER, LLC\nIs/ Douglas A. Wyler\nArthur I. =\nEsquire\nFM. Bar No.: 108249\nRichard J. Scholz, Esqui\nFla. Bar No.: 002126\nDouglas A. Wyle\nFla. Bar No.: 11\n961687 Gateway\n•., Suite 201-1\nFernandi\nh, Florida 32034\n(904)\n61-7\nholZlaw@comcast.net\nneysfor Defendant, Dave Aronberg\n\nEFTA02734330\n\n\f", "char_count": 495}, {"efta_number": "EFTA02734027", "page_number": 304, "text_content": "EXHIBIT \"D\"\n\nEXHIBIT \"D\"\n\nEFTA02734331\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 305, "text_content": "Filing # 115383434 E-Fited 10(21/2020 04:13:35 PM\n\nIN THE CIRCUIT COURT OF THE\nFIFTEENTH JUDICIAL CIRCUIT IN AND\nFOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of THEPALMBEACHPOST,\n\nCASE NO.: 50-2019-CA-0144581-XXXX-MB\nDIVISION: AG\n\nPlaintiff,\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida,\nDefendants.\nPLAINTIFF CA HOLDIN\nNOTICE OF DROPPING STATE ATT\nPlaintiff, CA I IOLDINGS, LLC, pursuant to Fla.\nit has dropped State Attorney, Dave Aronber\n( ic ro\n\n*\n\nAVE ARONBERG\n50(6), hereby notifies the parties that\n\nabove case.\n\nRespectfully submitted,\nGREENBERG TRAURIG, P.A.\nAttorneysfor CA Florida Holdings, LLC. Publisher\nofThe Palm Beach Post\nStephen A. Mendelsohn, Esq.\n401 East Las Olas Boulevard Suite 2000\nBoca Raton, Florida 33486\nTelephone: (561) 955-7629\nFacsimile: (561) 338-7099\nBy: ZilSteMen A. Mendelsohn\nSTEPHEN A. MENDELSOHN\nFlorida Bar No. 849324\nmendelsohnsOgthmcom\nsmithkrivtlaw.com\nFLServicera)gtlaw.com\n\nEFTA02734332\n\n\f", "char_count": 1048}, {"efta_number": "EFTA02734027", "page_number": 306, "text_content": "By: /s/ Michael JGrygiel\nMICHAEL .1 GRYGIEL\n(Admitted Pro Hac Vice)\n54 State St., 6th Floor\nAlbany, New York 12207\nTelephone: (518) 689-1400\nFacsimile: (518) 689-1499\ngrygielm@gtlaw.com\nBy: /s/ Nina D. Boyajian\nNINA D. BOYAJIAN\n(Admitted Pro Hoc Vice)\n1840 Century Park East, Sui\nLos Angeles California\nTelephone: (310) 586-7\nFacsimile: (310) 586-7\n\no\n\nCERTIFICATE 0\nI HEREBY CERTIFY that on this 21\"\n\nOctober, 2020, a true and correct copy of the\n\nforegoing has been filed with the Clerk of\n\nurt Jsing the State ofFlorida e-filing system, which\n\nwill send a notice of electronic servi\n\nriles of record herein\n\n/s/ Stephen A. Mendelsohn\nSTEPHEN A. MENDELSOHN\n\nACTIVE 533173414\n\n2\n\nEFTA02734333\n\n\f", "char_count": 696}, {"efta_number": "EFTA02734027", "page_number": 307, "text_content": "EXHIBIT \"E\"\n\nEXHIBIT \"E\"\n\nEFTA02734334\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 308, "text_content": "Fp\n\nScholz & Wyler, LLC\nGateway Blvd., Suite 2011\nFernandina Beach, FL 32034\nUnited States\n904-261-3693\n\nScholz & Wyler, LLC\n\nDave Aronberg\n\nBalance\n$32,440.00\n00307\nInvoice it\nInvoice Date\nNovember 6, 2020\nPayment Terms\nDue Date\nCO\n\nAronberg (SAO15) adv. CA Florida Holdings, LLC\nTime Entries\n09\nDate\n\nEE\n\nActivity\n\nDescription\n\nV\n\nRate\n\nHours\n\nLine Total\n\n11/26/2019\n\nDW\n\nReview\n\nInitial review of summons and COmplaint\n\n$425.00\n\n1.5\n\n$637.50\n\n11/26/2019\n\nOW\n\nReview\n\nReviewed motion for pro Mc vice and Judge\nHafele order granting\n\n$425.00\n\n0.2\n\n$85.00\n\n11/26/2019\n\nDW\n\nTeleconference\n\nTeleconference w/ Cient, re: response to lawsuit\n\n$425.00\n\n0.5\n\n$212.50\n\n11/26/2019\n\nDW\n\nDraft\n\nDrafted engagement letter and sent to client\n\n$425.00\n\n0.3\n\n$127.50\n\n11/26/2019\n\nDW\n\nReview\n\nReviewed 15th circuit local rules\n\n$425.00\n\n1.0\n\n$425.00\n\n11/26/2019\n\nAU\n\nReview\n\nInitial review of complaint\n\n$475.00\n\n1.0\n\n$475.00\n\n11/26/2019\n\nAIJ\n\nMeeting\n\nMeeting w/ DAW to discuss lawsuit and strategy\n\n$475.00\n\n0.5\n\n$237.50\n\n11/26/2019\n\nDW\n\nMeeting\n\nMeeting w/ AU to discuss lawsuit and strategy\n\n3425.00\n\n0.5\n\n$212.50\n\n11/26/2019\n\nAU\n\nTeleconference\n\nTeleconference w/ Cient, re: response to lawsuit\n\n$475.00\n\n0.5\n\n$237.50\n\n12/02/2019\n\nDW\n\nResearch &\nPreparation\n\nResearch and prep for Motion to dismiss\n\n$425.00\n\n2.0\n\n$850.00\n\n12/02/2019\n\nDW\n\nDraft\n\n1st Draft motion to dismiss\n\n$425.00\n\n1.0\n\n$425.00\n\n12/02/2019\n\nDW\n\nTeleconference\n\nTeleconference w/ Cient, re: draft motion to\ndismiss\n\n$425.00\n\n0.5\n\n$212.50\n\n12/02/2019\n\nAU\n\nReview\n\nReviewed 1st Draft MTDismiss\n\n$475.00\n\n0.3\n\n$142.50\n\n12/02/2019\n\nAU\n\nTeleconference\n\nTeleconference w/ client, re: draft motion to\ndismiss\n\n$475.00\n\n0.5\n\n$237.50\n\n12/03/2019\n\nAU\n\nMeeting\n\nMeeting w/ DAW, re: motion to dismiss\n\n$475.00\n\n0.2\n\n$95.00\n\n12/03/2019\n\nDW\n\nMeeting\n\nMeeting w/ AU, re: MTDismiss\n\n$425.00\n\n0.2\n\n$85.00\n\n12/06/2019\n\nDW\n\nDraft\n\nCompleted final draft of motion to dismiss: filed with\nourt\n\n$425.00\n\n0.7\n\n$297.50\n\n12/06/2019\n\nDW\n\nTeleconference\n\nSpoke w/ clien\n... [truncated, 2079 chars — for the full page use /api/corpus/document/EFTA02734027/308 or ?id=EFTA02734027&page=308]", "char_count": 2079}, {"efta_number": "EFTA02734027", "page_number": 309, "text_content": "12/06/2019\n\nDW\n\nTeleconference\n\nSpoke with Clerk's attorney, re: response\n\n$425.00\n\n0.5\n\n3212.50\n\n12/06/2019\n\nAU\n\nReview\n\nReviewed final draft MTDismiss\n\n3475.00\n\n0.2\n\n$95.00\n\n12/06/2019\n\nAU\n\nReview\n\nReviewed Clerk's MTDismiss\n\n$475.00\n\n0.2\n\n$95.00\n\n12/13/2019\n\nDW\n\nReview\n\nReviewed Clerk's Motion to Dismiss\n\n$425.00\n\n0.5\n\n3212.50\n\n01/16/2020\n\nDW\n\nReview\n\nReviewed Order Settng Hearing on Defendants'\nMTDismiss\n\n$425.00\n\n0.1\n\n342.50\n\n01/16/2020\n\nDW\n\nReview\n\nReviewed motion for pro hac vice\n\n3425.00\n\n0.1\n\n$42.50\n\n01/17/2020\n\nDW\n\nReview\n\nReviewed Pi's Amended Complaint\n\n$425.00\n\n1.0\n\n3425.00\n\n01/17/2020\n\nDW\n\nTeleconference\n\nSpoke with diem, re: Amended Complaint\n\n$425.00\n\n0.5\n\n$212.50\n\n01/17/2020\n\nDW\n\nReview\n\nReviewed Pl's notice of filing\n\n$425.00\n\n0.1\n\n$42.50\n\n01/20/2020\n\nAU\n\nReview\n\nReviewed Pi's Am. Compl\n\n3475.00\n\n0.3\n\n3142.50\n\n01/21/2020\n\nDW\n\nReview\n\nReviewed Judge Man's Order Cancelling\nMTDismiss Hearing\n\n$425.00\n\n0.1\n\n$4230\n\n01/21/2020\n\nDW\n\nReview\n\nReviewed Pl's Objection to Defendants' MTDismiss\n\n$425.00\n\n0.2\n\n$85.00\n\n01/21/2020\n\nDW\n\nTeleconference\n\nSpoke with client, re: Amended complaint\n\n$425.00\n\n0.5\n\n$212.50\n\n01/21/2020\n\nAU\n\nMeeting\n\nMeeting w/ DAW, re: response to Am. Compl.\n\n3475.00\n\n0.2\n\n$95.00\n\n01/21/2020\n\nDW\n\nMeeting\n\nMeeting w/ AIJ, re: response to Am. Compl.\n\n$425.00\n\n0.2\n\n$85.00\n\n01/22/2020\n\nDW\n\nReview\n\nReviewed Order granting pro hac vice admission\n\n$425.00\n\n0.1\n\n$42.50\n\n01/22/2020\n\nDW\n\nResearch & Draft\n\nResearched and drafted response to Amended\nComplaint\n\n$425.00\n\n1.0\n\n3425.00\n\n01/23/2020\n\nDW\n\nTeleconference\n\nSpoke with Clerk's attorney, re: response to\namended complaint\n\n$425.00\n\n0.2\n\n$85.00\n\n01/24/2020\n\nDW\n\nVarious\n\nCompleted Answer/MTDismiss Amended\nComplaint; filed with Court: sent copy to Client\n\n$425.00\n\n1.0\n\n3425.00\n\n01/24/2020\n\nDW\n\nDraft\n\nDrafted and tiled Notice of Unavailability\n\n$425.00\n\n0.4\n\n3170.00\n\n01/24/2020\n\nAU\n\nReview\n\nReviewed final Answer/MTDismiss\n\n$475.00\n\n0.2\n\n$95.00\n\n01/27/2020\n\nDW\n\nReview\n\nReviewed Clerk's Answer/MTDismiss\n\n... [truncated, 3014 chars — for the full page use /api/corpus/document/EFTA02734027/309 or ?id=EFTA02734027&page=309]", "char_count": 3014}, {"efta_number": "EFTA02734027", "page_number": 310, "text_content": "04/21/2020\n\nDW\n\nReview\n\nReviewed order reschedufing hearing on Defs'\nMTDismiss\n\n$425.00\n\n0.1\n\n$42.50\n\n04/21/2020\n\nDW\n\nTeleconference\n\nSpoke w/ client, re: order rescheduling MTDismiss\nhearing for June 3,2020\n\n$425.00\n\n0.3\n\n$127.50\n\n04/21/2020\n\nAU\n\nReview\n\nReviewed Order rescheduling MTDismiss hearing\n\n$475.00\n\n0.1\n\n$47.50\n\n05/2212020\n\nDW\n\nReview\n\nReviewed order setting Zoom hearing, re:\nMTDismiss\n\n$425.00\n\n0.1\n\n$42.50\n\n05/22/2020\n\nDW\n\nTeleconference\n\nSpoke w/ client, re: hearing will be via Zoom\n\n$425.00\n\n0.2\n\n$85.00\n\n05/27/2020\n\nDW\n\nReview\n\nReviewed Clerk's filing: change of atty of record\n\n$425.00\n\n0.1\n\n$42.50\n\n05/27/2020\n\nDW\n\nTeleconference\n\nSpoke with Clerk's new counsel. Nicole Fingerhut\n\n$425.00\n\n0.2\n\n$85.00\n\n05/28/2020\n\nDW\n\nE-mail\n\nReviewed Prs email, re: cases and authorities for\nMTDismiss hearing; responded\n\n$425.00\n\n0.1\n\n$42.50\n\n05/29/2020\n\nDW\n\nPreparation\n\nBegan oral argument prep for 6/8 MTDismiss\nhearing\n\n$425.00\n\n1.0\n\n3425.00\n\n06/01/2020\n\nDW\n\nE-mail\n\nReviewed email from Judge Marx's JA and\nresponded\n\n$425.00\n\n0.1\n\n$42.50\n\n06/02/2020\n\nDW\n\nVarious\n\nReviewed Prs 500+ page binder, re: MTDiemieS &\nprepped for hearing\n\n$425.00\n\n3.0\n\n$1,275.00\n\n06/02/2020\n\nDW\n\nE-mail\n\nand sent email to client, re: MTD hearing\ntnenew\nDraftedrro\n\n$425.00\n\n0.1\n\n$42.50\n\n06/03/2020\n\nDW\n\nAttend Hearing\n\nPrepped for and attended MTDismiss hearing via\nZoom\n\n$425.00\n\n1.5\n\n3637.50\n\n06/03/2020\n\nDW\n\nTeleconference\n\nSpoke w/ Client, re: debrief MTDismiss hearing\n\n$425.00\n\n0.5\n\n3212.50\n\n06/03/2020\n\nDW\n\nE-mail\n\nEntailed courtesy copies of Aronbergs Answer and\nMThismisS to Judge Man(\n\n5425.00\n\n0.1\n\n$42.50\n\n06/03/2020\n\nDW\n\nE-mail\n\nReviewed response from Client and replied\n\n$425.00\n\n0.1\n\n$42.50\n\n06/03/2020\n\nAU\n\nAttend Hearing\n\nAttended MTDismiss hearing via Zoom\n\n$475.00\n\n1.0\n\n3475.00\n\n06/03/2020\n\nAU\n\nReview\n\nReviewed order granting MTDismiss w/ prejudice\n\n$475.00\n\n0.3\n\n3142.50\n\n06/08/2020\n\nDW\n\nReview\n\nReviewed Court's Order Granting Defendants\nMTDismiss Count II w/ Prejudice\n\n$425.00\n\n0.5\n\n$2\n... [truncated, 2990 chars — for the full page use /api/corpus/document/EFTA02734027/310 or ?id=EFTA02734027&page=310]", "char_count": 2990}, {"efta_number": "EFTA02734027", "page_number": 311, "text_content": "06/23/2020\n\nDW\n\nE-mail\n\nSent client copy of Pfs letter refusing lO dismiss\ncomplaint\n\n$425.00\n\n0.1\n\n$42.50\n\n06/23/2020\n\nAU\n\nReview\n\nC\nReviewed Ks letter refusing to dismiss Count liAm.\nompl.\n\n$475.00\n\n0.1\n\n$47.50\n\n$425.00\n\n0.5\n\n$212.50\n\n07/01/2020\n\nDW\n\nVarious\n\nSpoke w/ client, re: fling of 57.105 motion for\nfees/sanctions; filed motion for attorneys' fees\nbased on PI'S faikre to voluntarily dismiss\namended complaint count 1\n\n07/02/2020\n\nDW\n\nE-mail\n\nEmail to client, re: affidavit and summary judgment\n\n$425.00\n\n0.1\n\n$42.50\n\n07/68/2020\n\nDW\n\nTeleconference\n\nDiscussed w/ Cleat drafting and filing Motion for\nSummary Judgment and MSJ evidence\n\n$425.00\n\n0.7\n\n$297.50\n\n07/08/2020\n\nAU\n\nTeleconference\n\nDiscussed w/ Cleat drafting and filing Motion for\nSummary Judgment and MSJ evidence\n\n$475.00\n\n0.7\n\n$332.50\n\n07/10/2020\n\nDW\n\nDraft\n\nCreated 1st draft of Arenberg Affidavit; shared w/\nclient\n\nvia®\n\n1.0\n\n$425.00\n\n07/10/2020\n\nAIJ\n\nVarious\n\nReviewed draft affidavit and discussed w/ DAW\n\n$475.00\n\n0.3\n\n$142.50\n\n07/10/2020\n\nDW\n\nMeeting\n\nDiscussed draft affidavit w/ AU\n\n$425.00\n\n0.2\n\n$85.00\n\n07/13/2020\n\nDW\n\nReview\n\nReviewed Pi's Request to Produce, re: Cleric\n\n$425.00\n\n0.1\n\n$42.50\n\n07/13/2020\n\nDW\n\nTeleconference\n\nSpoke w/ Clerk's counsel, re: Request to Produce\n\n$425.00\n\n0.2\n\n$85.00\n\n07/27/2020\n\nDW\n\nReview\n\nReviewed Pi's Amended Request to Produce, re:\nClerk\n\n$425.00\n\n0.1\n\n$42.50\n\n07/27/2020\n\nDW\n\nTeleconference\n\nSpoke w/ Clerk's counsel, re: Amended Request to\nProduce\n\n$425.00\n\n0.1\n\n$42.50\n\n07/28/2020\n\nDW\n\nDraft\n\nRevised Arenberg affidavit\n\n$425.00\n\n0.5\n\n$212.50\n\n07/29/2020\n\nOW\n\nDraft\n\nFinalized Arenberg Affidavit and sent to client\n\n$425.00\n\n0.5\n\n$212.50\n\n07/29/2020\n\nDW\n\nResearch &\nPreparation\n\nResearch and prep tor Motion for Summary\nJudgment\n\n$425.00\n\n1.0\n\n$425.00\n\n07/30/2020\n\nOW\n\nVarious\n\nReceived executed Arenberg Affidavit\n\n$425.00\n\n0.1\n\n$42.50\n\n07/30/2020\n\nDW\n\nDraft\n\nBegan drafting Motion for Summary Judgment\n\n$425.00\n\n2.0\n\n$850.00\n\n08/05/2020\n\nDW\n\nDraft\n\nContinued drafting Motion\n... [truncated, 3100 chars — for the full page use /api/corpus/document/EFTA02734027/311 or ?id=EFTA02734027&page=311]", "char_count": 3100}, {"efta_number": "EFTA02734027", "page_number": 312, "text_content": "09/02/2020\n\nAU\n\nMeeting\n\nDiscussed w/ DAW phone call w/ Prs counsel\n\n$475.00\n\n0.2\n\n$95.00\n\n09/02/2020\n\nDW\n\nMeeting\n\nDiscussed w/ AU phone call w/ Prs counsel\n\n$425.00\n\n0.2\n\n$85.00\n\n09/16/2020\n\nDW\n\nE-mail\n\nReviewed email from Ks counsel requested\nAronberg to withdraw sanctions motion w/o\nPrejudice\n\n$425.00\n\n0.1\n\n$42.50\n\n09/17/2020\n\nDW\n\nMeeting\n\nDiscussed wl AU filing motion for CMC\n\n$425.00\n\n0.1\n\n$42.50\n\n09/17/2020\n\nAU\n\nMeeting\n\nDiscussed wl DAW filing motion for CMC\n\n$475.00\n\n0.1\n\n$47.50\n\n09/18/2020\n\nDW\n\nVarious\n\nDrafted and filed motion to set case management\nconference; re: MSJ 1st or Fee hearing 1st\n\n$425.00\n\n0.5\n\n$212.50\n\n09/18/2020\n\nDW\n\nE-mail\n\nResponded to PI% 9/16/20 email and refused to\nwithdraw 57.105 motion; provided copy of motion to\nset CMC and available dates for hearing\n\n$425.00\n\n0.1\n\n$42.50\n\n09/18/2020\n\nDW\n\nE-mail\n\nReviewed Prs email insisting that 57.105 motion be\nwithdrawn\n\n$425.00\n\n0.1\n\n$42.50\n\n09/18/2020\n\nDW\n\nE-mail\n\nReplied to PI'S counsel that the 57.105 motion for\nsanctions will not be withdrawn and asking for\nresponse, re: CMC\n\n$425.00\n\n0.1\n\n$42.50\n\n09/18/2020\n\nDW\n\nE-mail\n\nSent client copy of email exchange w/ Prs counsel;\ncalled and spoke w/ Client\n\n$425.00\n\n0.5\n\n3212.50\n\n09/22/2020\n\nDW\n\nVarious\n\nDrafted and filed Notice of Hearing on 10/15/20: set\nup Court Call; spoke w/ client, re: hearing date\n\n$425.00\n\n0.7\n\n$297.50\n\n10/02/2020\n\nDW\n\nReview\n\nReviewed Prs Memo of Law opposing Aronberg's\n57.105 motion for fees/sanctions\n\n$425.00\n\n0.7\n\n3297.50\n\n10/02/2020\n\nDW\n\nReview\n\nReviewed Prs Response to Aronberg's request to\nschedule 57.105 motion for fees after MSJ\n\n$425.00\n\n0.5\n\n$212.50\n\n10/02/2020\n\nAU\n\nReview\n\nReviewed P1% Memo of Law opposing 57.105\nmotion\n\n$475.00\n\n0.5\n\n3237.50\n\n10/02/2020\n\nAU\n\nReview\n\nReviewed Prs Response to Aronberg's request to\nschedule 57.105 motion after MSJ\n\n$475.00\n\n0.4\n\n$190.00\n\n10/12/2020\n\nDW\n\nResearch\n\nResearch caselaw & statutes, re: response to Prs\nMemo of Law\n\n$425.00\n\n1.0\n\n$425.00\n\n10/13/2020\n\nDW\n\nResearch &\nAnalyze\n\n\n... [truncated, 2971 chars — for the full page use /api/corpus/document/EFTA02734027/312 or ?id=EFTA02734027&page=312]", "char_count": 2971}, {"efta_number": "EFTA02734027", "page_number": 313, "text_content": "10/15/2020\n\nDW\n\nTelephone\n\nSpoke w/ PPS counsel, re: settlement\n\n$425.00\n\n0.1\n\n$42.50\n\n10/15/2020\n\nDW\n\nTelephone\n\nSpoke w/ client, re: Prs settlement proposal\n\n$425.00\n\n0.2\n\n$85.00\n\n10/15/2020\n\nAL)\n\nVarious\n\nAttended hearing, re: motion to set CMC;\ndiscussed wl client\n\n$475.00\n\n1.0\n\n$475.00\n\n10/15/2020\n\nAU\n\nVarious\n\nDiscussed Ks settlement proposal w/ DAW and\nthen w/ Client\n\n$475.00\n\n0.4\n\n3190.00\n\n10/15/2020\n\nDW\n\nMeeting\n\nDiscussed Prs settlement proposal w/ AU\n\n$425.00\n\n0.2\n\n$85.00\n\n10/16/2020\n\nDW\n\nVarious\n\nDrafted and shared proposed order w/ PPS counsel\n\n$425.00\n\n0.5\n\n$212.50\n\n10/16/2020\n\nDW\n\nTelephone\n\nSpoke w/ Prs counsel, re: settlement\n\n$425.00\n\n0.2\n\n$85.00\n\n10/16/2020\n\nDW\n\nTelephone\n\nSpoke wl client, re: Pt's settlement proposal\n\n$425.00\n\n0.5\n\n$212.50\n\n10/16/2020\n\nDW\n\nMeeting\n\nDiscussed Pt's settlement proposal w/ AU\n\n$425.00\n\n0.2\n\n$85.00\n\n10/16/2020\n\nAU\n\nMeeting\n\nDiscussed Prs settlement proposal w/ DAW\n\n$475.00\n\n0.2\n\n$95.00\n\n10/19/2020\n\nDW\n\nVarious\n\nUploaded proposed order. re: CMC for Judge\nHafele\n\n$425.00\n\n0.1\n\n$42.50\n\n10/19/2020\n\nDW\n\nTelephone\n\nSpoke w/ client. re: Pt's settlement proposal\n\n$425.00\n\n0.2\n\n$85.00\n\n10/19/2020\n\nDW\n\nTelephone\n\nSpoke w/ Prs counsel, re: settlement\n\n$425.00\n\n0.1\n\n$42.50\n\n10/19/2020\n\nAU\n\nMeeting\n\nDiscussed Prs settlement proposal w/ DAW\n\n$475.00\n\n0.2\n\n$95.00\n\n10/19/2020\n\nDW\n\nMeeting\n\nDiscussed Prs settlement proposal w/ AU\n\n$425.00\n\n0.2\n\n$85.00\n\n10/20/2020\n\nDW\n\nVarious\n\nReviewed email from PI, re: settlement; sent copy\nto Client and caled to discuss\n\n$425.00\n\n0.5\n\n$212.50\n\n10/20/2020\n\nDW\n\nTelephone\n\nSpoke w/ client, re: settlement\n\n$425.00\n\n0.4\n\n3170.00\n\n10/20/2020\n\nDW\n\nTelephone\n\nSpoke w/ PI'S counsel, re: settlement\n\n$425.00\n\n0.1\n\n$42.50\n\n10/20/2020\n\nDW\n\nTelephone\n\nSpoke w/ client, re: settlement\n\n$425.00\n\n0.1\n\n$42.50\n\n10/20/2020\n\nOW\n\nMeeting\n\nDiscussed Prs settlement proposal w/ AU\n\n$425.00\n\n0.2\n\n$85.00\n\n10/20/2020\n\nAU\n\nMeeting\n\nDiscussed PPS settlement proposal w/ DAW\n\n$475.00\n\n0.2\n\n$95.00\n\n$425.00\n\n1.0\n\n$425.00\n\n10/21/2020\n... [truncated, 3126 chars — for the full page use /api/corpus/document/EFTA02734027/313 or ?id=EFTA02734027&page=313]", "char_count": 3126}, {"efta_number": "EFTA02734027", "page_number": 314, "text_content": "10/22/2020\n\nAIJ\n\nVarious\n\nReviewed Ks Notice of Dropping Aronberg as\nparty; SPOke w/ Client and DAW, re: notice and next\nsteps\n\n$475.00\n\n0.5\n\n$237.50\n\nTotals:\n\n74.8\n\n$32,440.00\n\nTime Entry Sub-Total:\n\n$32,440.00\n\nSub-Total:\n\n$32,440.00\n\nTotal:\n\n$32,440.00\n\nAmount Paid:\n\n$0.00\n\nBalance Due:\n\n$32,440.00\n\nEFTA02734341\n\n\f", "char_count": 319}, {"efta_number": "EFTA02734027", "page_number": 315, "text_content": "EXHIBIT \"F\"\n\nEXHIBIT \"F\"\n\nEFTA02734342\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 316, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff,\nv.\n\nCASE NO.: 19-C\n\nI4681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\n\nCC A\n\n1\n\nDefendants.\n\nAFFIDAVIT OF ATTORNUS' En.>\nSTATE OF FLORIDA\nCOUNTY OF NASSAU\nBEFORE ME, the undersigned aut\n\nS9\nDouglas A. Wyler, Esq., who, after\n\nbeing first duly sworn, deposes and sa\nI.\n\nAffiant is a partner of ACOBS, SCHOLZ & WYLER, LLC, counsel for\n\nDefendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, (\"Aronberg\"),\nas well as general counsel to the Florida Prosecuting Attorneys Association, (\"FPAA\"), and makes\nthis AffidavitS cs own'personal knowledge.\n2.\nffiant is licensed to practice law in the State of Florida, is an active member of\nc \".14\nthe Flo a r in good standing and has engaged in the practice of law in the State of Florida since\n2015.\n3.\n\nAs detailed herein, the services rendered by Affiant and his firm pertain to Affiant's\n\ndemand letter and motion for attorneys' fees sent to Plaintiffs counsel pursuant to § 57.105,\nFlorida Statutes, on June 8, 2020, in defending against Count I of Plaintiff's Amended Complaint\n\nEFTA02734343\n\n\f", "char_count": 1316}, {"efta_number": "EFTA02734027", "page_number": 317, "text_content": "and Plaintiffs October 21, 2020 Notice of Dropping State Attorney, Dave Aronberg from the\nabove-captioned lawsuit. See, Exhibits \"A\" and \"B\" attached hereto.\n4.\n\nThe total time Affiant's law firm has expended services rendered to date is 74.8\n\nhours, however, from the date of Defendant Aronberg's 57.105 demand, Affiant's law firm has\nexpended a total of 42.2 hours. Of the 42.2 hours expended since Defendant Aronberg's 57.105\ndemand was served, the Affiant\n5.\n\nOf the 42.2 hours expended since Defendant Aronberg'\n\nserved, the total time Affiant has expended services rendered to date\n\nemand was\nA boars at the rate of\n\n$425.00 per hour. Likewise, the total time Affiant's law partner, Arthur CM,\n\nhas expended\n\nservices rendered to date is 6.8 hours at the rate of S475.00 per hour.\n6.\n\nAccordingly, since Defendant Aronberg's 57.105 demand was served, Defendant\n\nAronberg's counsel,\n\nSCHOLZ & WYLER, LLC, has rendered services in the amount\n\nof $18,275.00. in conjunction with the defense of the instant action pursuant to § 57.105, Florida\nStatutes. See. Exhibit \"C\" attached hereto.\n7.\n\nAffiant expects to incur an additional 4.0 hours at $425.00 an hour in preparing for\n\nand attending the hearing on attorneys' fees. Thus, the total amount of hourly attorneys' fees the\nState Attorney is seeking is 46.2 hours for a total of $19,975.00. Additionally, the State Attorney\nseeks a multipliN12.0, which when applied makes the grand total attorneys' fees sought herein\n$39,1.9\nDat\n\nh day of November, 2020.\nFURTHER AFFEANT SAYETH NOT.\n\nDouglas\n\nWyler, Esq., Fla. 8.2 No. 119979\n\nEFTA02734344\n\n\f", "char_count": 1598}, {"efta_number": "EFTA02734027", "page_number": 318, "text_content": "STATE OF FLORIDA\nCOUNTY OF NASSAU\nby Do\n\nSign\n\nThe foregoing instrument was acknowledged before me this 9th day of November, 2020,\nWyler, Esquire, who is personally known to me and who did take an oath.\n\nTAAAN\nMotley Pobik • State of P:of\nCommission a GG 354141\nMy Comm. Expires Aug 17. 2023\n!abed throws, h edam: Mowry Aur.\n\nf otary Public — State ofFlorida\n\n4-årark. R. 1 -CtC1(.50111\nName typed, printed or stamped\nCERTIFICATE OF SERVICE\nI HEREBY CERTIFY that on this 9th day ofNovem\nbeen electronically filed with the Florida E-File Portal\n\n, a copy of the foregoing has\non all parties of record herein.\nSCHOLZ & WYLER, LLC\n\nDouglas A. fyyler\nArtlu\nrq.\nFla. Bar No.: 10249\nRichard .1. Scholz. Esq.\nFla. Bar No.: 0021261\nDouglas A. Wyler, Esq.\nFla. Bar No.: 119979\n961687 Gateway Blvd., Suite 201-I\nFernandina Beach, Florida 32034\n(904) 261-3693\n(904) 261-7879 Fax\nPrimary: jacobsscholzlaw@comcast.net\nAttorneysfor Defendant, Dave Aronberg\n\nEFTA02734345\n\n\f", "char_count": 959}, {"efta_number": "EFTA02734027", "page_number": 319, "text_content": "EXHIBIT \"A\"\n\nEXHIBIT \"A\"\n\nEFTA02734346\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 320, "text_content": "Friday, September 18, 2020 at 11:09:24 Eastern Daylight Time\nSubject:\n\nSERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, LLC V.\nDAVE ARONBERG ET AL.\n\nDate:\n\nMonday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time\n\nFrom:\n\nDouglas Wyler\n\nTo:\n\n'mendelsohns@gtlaw.com', smithl@gtlaw.com, flservice@gtlaw.com, BoyajianN@gtlaw.com,\nriveraal@gtlaw.com, GRVGIELM@gtlaw.com\n\nAttachments: 2020-05.08 Aronberg 57.105 Demand and Motion for Attorneys' Fees.pdf\n\nCourt:\nCase No:\nPlaintiff:\nDefendant:\nTitle of Documents\nServed:\nSender's Name and\nTelephone Number:\n\nCircuit Court of the Fifteenth Judicial Circuit, in and for Palm Eteat*ty,\nFlorida\nCase Na. 2020-CA-014681\nCA Florida Holdings, LLC\nDave Aronberg\n(..)\n• Fla. Stat. 4 57.105 Demand Letter\n• Defendant, Dave Aronberg's Motion j\nDouglas Wyler\n(904) 261-3693\n\nSincerely,\n\ntt\n\n' Fees\n\n4/\n\nDoug Wyler, Esq.\n_Scholi a& Wyle r, LLC\nT\n961687 Gateway Blvd., SE 201-I\nFernandina Beach, FL 32034\n904-261-3693\n904-261.7879 (fax)\n\n?S.\n\n< C0\n*)\nPlease be advised that this e-mail ny files transmitted with it are confidential attorney-client\ncommunication or may otherwise be privileged or confidential and are intended solely for the individual or\nentity to whom they are addressed. If you are not the intended recipient, please do not read, copy or\nretransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or\ncopying of this commtvccation is strictly prohibited.\n\nPage 1 of 1\n\nEFTA02734347\n\n\f", "char_count": 1499}, {"efta_number": "EFTA02734027", "page_number": 321, "text_content": "SCHOLZ & WYLER, LLC.\nA LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS\nATTORNEYS AT LAW\nTHE LAW (H, ICES Of\n\nGATEWAY TO AMELIA\n\nJACOBS IL ASSOCIATES. P.A.\nAlitTtiLl9\n\nBoles,\n\nGATEWAY BLVD.. SUITE EL31.1\n\nFtlItHA-VDDIA BEACH. FLORIDA 02034\n\nRICHARDJ. SCHOL2. P.A.\nRCHARDJ SCHOLZ\nDOUGLAS A. WYLER. P.A.\nDOUGLAS A WYLER\n\nTELEPHONE 19041\nmom NO. 1904)\n\n261.3693\n\n261-7879\n\nJune 8, 2020\n\nVIA ELECTRONIC & U.S. MAIL\nStephen A. Mendelsohn, Fsq.\nGrccnburg Traurig, P.A.\n5100 Town Center Circle, Suite 400\nBoca Raton, FL 33486\nRE:\n\nCA Florida Holdings, LLC v. Dave Aronberg et\nPalm Beach County. Case No.: 2019-C4\n\nDear Mr. Mendelsohn:\nzfr,\nAs you are aware our firm represents the interests of Dave Aronberg, as State Attorney of Palm Beach\nCounty, Florida, in the above referenced matter. The purpose of this letter is to demand the voluntary\ndismissal of your First Amended Complaint, (the \"Complaint\"), dated January 17, 2020. This demand\nis made pursuant to section 57.105, Florida Statutes.\nAs you know, Section 57.105 provides.\n(I) Upon the court's initiative or motion of any party, the court shall award a\nreasonable attorney's fee. including prejudgment interest, to be paid to the\nprevailing party in equal amounts by the losing party and the losing party's attorney\non any claim or defense at any time during a civil proceeding or action in which\nthe court finds that the losing party or the losing partys attorney knew or should\nhave known that a claim or defense when initially presented to the court or at any\ntine before trial:\na. ' Was not supported by the material facts necessary to establish the claim or\ndefense; or\nb. Would not be supported by the application of then-existing law to those\nmaterial facts.\n\nO\n\nToday, Judge Marx granted, with prejudice. Defendant Aronberg's Motion to Dismiss Count II of the\nPlaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action\nconsists of Count t, for Declaratory Relief. Accordingly, we believe t\n... [truncated, 2279 chars — for the full page use /api/corpus/document/EFTA02734027/321 or ?id=EFTA02734027&page=321]", "char_count": 2279}, {"efta_number": "EFTA02734027", "page_number": 322, "text_content": "First and foremost, the Complaint is not supported by the material facts necessary to establish the\nclaims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the\nFifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein.\nSimply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are\nimpossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to\nthis action because no matter what, he and his office do not have possession, custody, or control of the\nrequested materials.\nIn'addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims\nare also not supported by the application of current law. Specifically, your action for declaratory relief\nfails based on the clear, unambiguous statutory language found in Section 905.27(2)414cca Statutes,\nwhich states:\nWhen such disclosure is ordered by a court pursuant to subsection ( ) fotusein a civil\ncase, it may be disclosed to all parties to the case and to their attorneys and by the latter\nto their legal associates and employees. However, the grand kttry testimony afforded\nsuch persons by the court can only be used in the defense ocp •ecution of the civil or\ncriminal case and for no other ramose whatsoever.\nMoreover, even if the Plaintiff were to prevail in the declaratory ion, Mr. Aronberg would be unable\nto comply with any court order granting disclosure of the. requested documents because neither Mr.\nAronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession,\ncustody, or control of the 2006 Epstein grand jury‘ E\nBased on the foregoing, if the Complaint is neitittmt d within 21 days of the service of this letter,\nthe enclosed Motion for Attorney's Fccs will be filed and we will seek as sanctions, from your client\nand your firm, recovery of the legal expenses incurred in defending this frivolous action.\n... [truncated, 2135 chars — for the full page use /api/corpus/document/EFTA02734027/322 or ?id=EFTA02734027&page=322]", "char_count": 2135}, {"efta_number": "EFTA02734027", "page_number": 323, "text_content": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT\nIN AND FOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of the PALM BEACH POST,\nPlaintiff;\nv.\n\nCASE NO.: 194\n\n.0„\n-014681\n\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida.\nO 'S\n\nDefendants.\n\nDEFENDANT. DAVE ARONBF.RG'S MOTION FOR ATTORNEYS' FEES\nDefendant, DAVE ARONBERG, as Stats Ait orney\nof Palm Beach County, Florida, by and\no\nthrough the undersigned attorneys, moves\n<\nto award him reasonable attorneys'\n(the \"Complaint\"), and as grounds the\n\nte, i\n\nfoSr\n\n, unuant to Florida Statutes, Section 57.105,\n\ndefense of Plaintiffs First Amended Complaint,\n\nwould show that on June 8. 2020, Plaintiff was served\n\na copy of this Motion, together with/ a letter from the undersigned attorney, in accordance with\nJ\n\nsubsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior\nto the filing of this Motion. In said letter. Defendant's attorney advised Plaintiff of the facts which\nestablish that the Complaint is without support of the facts or the law.\nWHEREFORE. Defendant. DAVE ARONBERG, as State Attorney of Palm Beach\nCounty, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's\nattorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.\n\nEFTA02734350\n\n\f", "char_count": 1427}, {"efta_number": "EFTA02734027", "page_number": 324, "text_content": "CERTIFICATE OF SERVICE\nhereby certify that on this\n\nday\n\n, 2020, the foregoing was electronically filed\n\nvia the Florida E-File Portal for electronic service on the parties of record herein.\n\n-SCHOLZ & WYLER, LLC\n4/ Douglas A. Wyler\nArthur I.\nEsquire\nHa. Bar .1\n8249\nRichard J. Scholz, Esquire\nFla. Bar No.: 0021261\nDouglas A. Wyler, Esquire\nFla. Bar No.: 119979\n961687 Gateway Blvd., Suite 201-1\nFernandina Beach, Florida 32034\n(904) 261-3693\n(9,7879\nA sh\nIzlaw@corncast.net\nfro eysfor Defendam\n\nEFTA02734351\n\n\f", "char_count": 512}, {"efta_number": "EFTA02734027", "page_number": 325, "text_content": "EXHIBIT \"B\"\n\nEXHIBIT \"B\"\n\nEFTA02734352\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 326, "text_content": "Filing if 115383434 E-Filed 10/21/2O20 04:13:35 PM\n\nIN THE CIRCUIT COURT OF THE\nFIFTEENTH JUDICIAL CIRCUIT IN AND\nFOR PALM BEACH COUNTY, FLORIDA\nCA FLORIDA HOLDINGS, LLC,\nPublisher of THEPALMBEAC I POST\n\nCASE NO.: 50-2019-CA-014681-XXXK-MB\nDIVISION: AG\n\nPlaintiff;\nv.\nDAVE ARONBERG, as State Attorney of\nPalm Beach County, Florida; SHARON R.\nBOCK, as Clerk and Comptroller of Palm\nBeach County, Florida,\n\nA\n\nDefendants.\nPLAINTIFF CA HOLDING', ,\nNOTICE OF DROPPING STATE ATTORN\n< V.IsAVE\n5,),\nARONBERG\nPlaintiff; CA HOLDINGS, LLC, pursuant to Fla.\n\n.\n\n0(b), hereby notifies the panics that\n\nit has dropped State Attorney, Dave Aronber\nc Arse\n,\nabove cue.\n\nRespectfully submitted,\nGREENBERG I RAURIG, P.A.\nAnorneysjor CA Florida Holdings, LLC Publisher\nof The Palm Beach Post\n\n+6s\n\nStephen A. Mendelsohn, Esq.\n401 East Las Olas Boulevard Suite 2000\nBoca Raton, Florida 33486\nTelephone: (561) 955-7629\nFacsimile: (561) 338-7099\nBy: is/ Stephen A. Mendelsohn\nSTEPHEN A. MENDELSOHN\nFlorida Bar No. 849324\nmendelsohnscvolaw.com\nsmithkittplaw.com\naServiceOutlaw.com\n\nEFTA02734353\n\n\f", "char_count": 1075}, {"efta_number": "EFTA02734027", "page_number": 327, "text_content": "By: is/Michael Grygiel\nMICHAEL J GRYGIEL\n(Admitted Pro Hac Vice)\n54 State St., 6th Floor\nAlbany, New York 12207\nTelephone: (518) 689-1400\nFacsimile: (518) 689-1499\ngrvgielnentlaw.com\nBy: /s/ Nina D Bovolian\nNINA D. BOYAJIAN\n(Admitted Pro Hoc Vice)\n1840 Century Park East, Sui\nLos Angeles California 9006\nTelephone: (310) 586-7\nFacsimile: (310) 586-7\nbovaiiannegtlaw.eom\nriserazI41).\nCERTI\n\nAT O\n\nI HEREBY CERTIFY that on this 2Ia\n\nI\n' r, 2020, a true and correct copy of the\n\nforegoing has been tiled with the Clerk of\n\nng the State of Florida e-filing system, which\n\nwill send a notice of electronic service for all parties of record herein\nis< pir\n\nC\n\n/s/Steohen A. Mendelsohn\nSTEPHEN A. MENDELSOHN\n\nx\n\nO\nACTIVE 53317341v1\n\n2\n\nEFTA02734354\n\n\f", "char_count": 744}, {"efta_number": "EFTA02734027", "page_number": 328, "text_content": "EXHIBIT \"C\"\n\nEXHIBIT \"C\"\n\nEFTA02734355\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 329, "text_content": "IV\n\nScholz & Wyler, LLC\n\nScholz & Wyler, LLC\n\nGateway Blvd., Suite 2011\nFemandina Beach, FL 32034\nUnited States\n904-261-3693\n\nDave Aronberg\n\nBalance\nInvoice #\nInvoice Date\nPayment Term\nDue Date\n\n$32,440.00\n00307\nNovember 6, 2020\n\nAronberg (SA015) adv. CA Florida Holdings, LLC\nTime Entries\nDate\n\nEE\n\nActivity\n\nDescription\ni\n\nRate\n\nHours\n\nLine Total\n\n$425.03\n\n1.5\n\n$637.50\n\n11/26/2019\n\nOW\n\nReview\n\nwer \\si N\nInitial review of summons _4 corn\n\n11/2612019\n\nOW\n\nReview\n\nReviewed motion for pro hoc vice and Judge\nlialele' order granting\n\n$425.00\n\n02\n\n$85.00\n\n11/26/2019\n\nOW\n\nTeleconference\n\nTeleconference wL Client, ro: response to lawsuit\n\n$425.00\n\n0.5\n\n$212.50\n\n11/26/2019\n\nOW\n\nDraft\n\nDrafted engagement letter and sent to client\n\n$425.00\n\n0.3\n\n$127.50\n\n11/26(2019\n\nDW\n\nReview\n\nReviewed 15th cIrcuil local rules\n\n$425.00\n\n1.0\n\n$42500\n\n11/26/2019\n\nAU\n\nReview\n\nInitial review of complaint\n\n$475.00\n\n1.0\n\n$475.00\n\n11/26/2019\n\nAU\n\nMeeting\n\nMeeting w/ OAW to discuss lawsuit and strategy\n\n$475.00\n\n0.5\n\n$237.50\n\n11/26/2019\n\nDW\n\nMeetng\n\nMeeting w/ AU to discuss lawsuit and strategy\n\n$425.00\n\n0.5\n\n$212.50\n\n11;26/2019\n\nAU\n\nTeleconference\n\nTeleconference w! Client. re: response to lawsuit\n\n$475.00\n\n0.5\n\n$237.50\n\n12/022019\n\nOW\n\nResearch 3\nPreparation\n\nResearch and prep for Maori to dismiss\n\n$42500\n\n2.0\n\n$650.00\n\n12/02/2019\n\nOW\n\nDraft\n\n1st Draft motion to dismiss\n\n$425.00\n\n1.0\n\n$42500\n\n12/022019\n\nDW\n\nTeleconference\n\nTeleconference w/ Ckent, re: draft nation to\ndismiss\n\n$425.00\n\n0.5\n\n$212.50\n\n12/02/2019\n\nAU\n\nReview\n\nReviewed 1st Draft MIDismiss\n\n$475.00\n\n0.3\n\n$142.50\n\n12102/20 19\n\nAU\n\nTeleconference\n\nTeleconfererce w/ client, re: draft motion to\ndismiss\n\n$475.00\n\n0.5\n\n$237.50\n\n12/03/2019\n\nAU\n\nMeeting\n\nMeeting wr DAW, re: motion to dismiss\n\n$475.00\n\n0.2\n\n$95.00\n\n12/03/2019\n\nDW\n\nMeeting\n\nMeeting we AU, re: MTDisrniss\n\n$425.00\n\n0.2\n\n$85.00\n\n12/06/2019\n\nOW\n\nDraft\n\nCompleted final draft of motion to dismiss; filed with\nCourt\n\n5425.00\n\n0.7\n\n$297 50\n\n12/06/2019\n\nDW\n\nTeleconference\n\nSpoke w/ client. re\n... [truncated, 2074 chars — for the full page use /api/corpus/document/EFTA02734027/329 or ?id=EFTA02734027&page=329]", "char_count": 2074}, {"efta_number": "EFTA02734027", "page_number": 330, "text_content": "12/062019\n\nDW\n\nTeleconference\n\nSpoke with Clerk's attorney, re: response\n\n$425.00\n\n0.5\n\n$212.50\n\n12/06/2019\n\nAIJ\n\nReview\n\nReviewed final draft MTDismiss\n\n$475.00\n\n0.2\n\n$95.00\n\n12/06/2019\n\nAU\n\nReview\n\nReviewed Clerk's MTDismiss\n\n$475.00\n\n0.2\n\n$95.00\n\n12/13/2019\n\nOW\n\nReview\n\nReviewed Clerk's Motion to Dismiss\n\n$425.00\n\n0.5\n\n$212.50\n\n01/16/2020\n\nOW\n\nReview\n\nReviewed Order Setting Hearing on Delendants'\nMTDismiss\n\n$42500\n\n0.1\n\n$42.50\n\n01/16/2020\n\nDW\n\nReview\n\nReviewed motion fOr pro hac vice\n\n$425.00\n\n0.1\n\n$42.50\n\n01/17/2020\n\nDW\n\nReview\n\nReviewed Prs Amended Complalm\n\n$425.00\n\n1.0\n\n$425.00\n\n01/17/2020\n\nDW\n\nTeleconference\n\nSpoke with client, re: Amended Complaint\n\n$425.00\n\n0.5\n\n$21250\n\n01/17/2020\n\nOW\n\nReview\n\nReviewed Prs notice of filing\n\n$425.00\n\n., 0.1\n\n$42.50\n\n01/20/2020\n\nAU\n\nReview\n\nReviewed Pt's Am. Comps\n\n$475.00\n\n03\n\n$142.50\n\n01/21/2029\n\nOW\n\nReview\n\nReviewed Judge Manes Order Canceling\nMTOismiss Hearing\n\n542500\n\n0.1\n\n$42.50\n\n01/21/2020\n\nDW\n\nReview\n\nReviewed Prs Objection to Defendants' MTDismiss --- $425.00\n\n0.2\n\n$85.00\n\n01/21/2020\n\nDW\n\nTeleconference\n\nSpoke with then!, re: Amended complaint\n\n$425.00\n\n0.5\n\n$212.50\n\n01/21/2020\n\nAIJ\n\nMeeting\n\nMeeting w/ DAW, re: response to Am. Cornet:\n\n$475.00\n\n0.2\n\n$95.00\n\n01/212020\n\nOW\n\nMeeting\n\nMeeting w/ AU, re: response to Am. Cornpl.\n\n$425.00\n\n0.2\n\n$85.00\n\n01/22/2020\n\nOW\n\nReview\n\nReviewed Order granting pro hat vice admission\n\n$425.00\n\n0.1\n\n$42.50\n\n01/22/2020\n\nDW\n\nResearch 8 Draft\n\nResearched and dratted response to Amended\n.\nComplaint\n\n$42500\n\n1.0\n\n$425.00\n\n01/23/2020\n\nOW\n\nTeleconference\n\nSpoke with Clerk's attorney, re: response to\namended complaint\n\n$425.00\n\n0.2\n\n$85.00\n\n01/24/2020\n\nDW\n\nVarious\n\nCompleted Answer/MTClismiss Amended\nComplaint: tiled with Court: sent copy lo Client\n\n5425.00\n\n1.0\n\n$425.00\n\n01/24/2020\n\nDW\n\nDraft\n\nDratted and Ned Notice of Unavailability\n\n$42500\n\n0.4\n\n$170.00\n\n0124/2020\n\nAU\n\nReview\n\nReviewed foal Answer/MTDismiss\n\n$475.00\n\n0.2\n\n$95.00\n\n01/27/2020\n\nOW\n\nReview\n\nReviewed Clerk's Answer/MTDismiss\n\n$\n... [truncated, 3006 chars — for the full page use /api/corpus/document/EFTA02734027/330 or ?id=EFTA02734027&page=330]", "char_count": 3006}, {"efta_number": "EFTA02734027", "page_number": 331, "text_content": "04/21/2020\n\nDW\n\nReview\n\nReviewed order rescheduling hearing on Deis'\nMTDismiss\n\n$425.00\n\n0.1\n\n$42.50\n\n04/21/2020\n\nDW\n\nTeleconference\n\nSpoke w/ client. re: order rescheduling MTDIsrmiss\nhearing for June 3, 2020\n\n$425.00\n\n0.3\n\n$127.50\n\n0421/2020\n\nAU\n\nReview\n\nReviewed Order resehoduing MTOismiss hearing\n\n$475.00\n\n0.1\n\n$47.50\n\n05/222020\n\nDW\n\nReview\n\nReviewed order setting Zoom hearing. re:\nMTOismiss\n\n$425.00\n\n0.1\n\n$42.50\n\n05/22/2020\n\nDW\n\nTeleconference\n\nSpoke kW client. re: hearing will be via Zoom\n\n$425.00\n\n0.2\n\n$85.00\n\n05/27/2020\n\nDW\n\nReview\n\nReviewed Clerk's fling: change of atty of record\n\n$425.00\n\n0.1\n\n$42.50\n\n05/27/2020\n\nDW\n\nTeleconference\n\nSpoke with Clerk's new counsel, Nicole Flngerhut\n\n$425.00\n\n- il 0.2\n\n$85.00\n\n05/28/2020\n\nOW\n\nE.mall\n\nReviewed Pi's email. re: cases and authorities for\nMTDismiss hearing, responded\n\n$425.00\n\n0.1\n\n$42.50\n\n05/29/2020\n\nDW\n\nPreparation\n\nBegan oral argument prep for 6/8 MTOismiss\nhearing\n\n$425.00\n\n1.0\n\n$425.00\n\n06/01/2020\n\nOW\n\nEmail\n\nReviewed email from Judge Marx's JA and\nresponded\n\n$425.00\n\n0.1\n\n$42.50\n\n06/02/2020\n\nOW\n\nVarious\n\nReviewed Ks 500+ page binder. re: MTOisneelk$\nprepped for hearing\n\n$425 00\n\n3.0\n\n$1,275.00\n\n06/02/2020\n\nOW\n\nE-mail\n\nDrafted and sent email to client, re: MID hearing\ntomorrow\n\n$425.00\n\n0.1\n\n$42.50\n\n06/03/2020\n\nOW\n\nAttend Hearing\n\nPrepped for and attended MT0Lcrnl% hearing via\nZoom\n\n5425.00\n\n1.5\n\n$637.50\n\n06/03/2020\n\nDW\n\nTeleconference\n\nSpoke w/ Client, re; debrief MTDIsmiss hearing\n\n$425.00\n\n0.5\n\n$212.50\n\n06/032020\n\nOW\n\nE-mail\n\nEmailed courtesy copies of Aronberg's Answer and\nMTOismiss to Judge Mani\n\n5425.00\n\n0.1\n\n$42.50\n\n06/03/2020\n\nDW\n\nE-mag\n\nReviewed response from Client and replied\n\n$425.00\n\n0.1\n\n542.50\n\n06/032020\n\nAU\n\nAttend Hearing\n\nAttended MTOismiss hearing via Zoom\n\n$475.00\n\n1.0\n\n$475.00\n\n06103/2020\n\nAU\n\nReview\n\nReviewed order granting MTDism ss ve prejudice\n\n$475.03\n\n0.3\n\n$142.50\n\n06/08/2020\n\nOW\n\nReview\n\nReviewed Courts Order Granting Defendants\nMTDismiss Counl II w/ Prejudice\n\n$425.00\n\n0.5\n\n$212.\n... [truncated, 2982 chars — for the full page use /api/corpus/document/EFTA02734027/331 or ?id=EFTA02734027&page=331]", "char_count": 2982}, {"efta_number": "EFTA02734027", "page_number": 332, "text_content": "01323/2020\n\nDW\n\nEmail\n\nSent client copy of Pis letter refusing to dismiss\ncomplaint\n\n$425.00\n\n0.1\n\n54250\n\n06'23/2020\n\nAIJ\n\nReview\n\nReviewed R's lobar refusing to dismiss Count I/Am.\nComet.\n\n$475.00\n\n0.1\n\n$47.50\n\n$425.00\n\n0.5\n\n$212.50\n\n07/01/2020\n\nDW\n\nVarious\n\nSpoke iv/ client. re: filing of 57.105 motion for\nfees/sanctions: tiled motion for attorneys' fees\nbased on Pre faiure to voluntarily dismiss\namended complaint count 1\n\n07/02/2020\n\nDW\n\nE-mail\n\nEmail to client, re: affidavit and summary judgment\n\n$425.00\n\n0.1\n\n$42.50\n\n07/08/2020\n\nDW\n\nTeleconference\n\nDiscussed w/ Client drafting and Wing Motion for\nSummary Judgment and MSJ evidence\n\n$425.00\n\n0.7\n\n$297.50\n\n07/08/2020\n\nAU\n\nTeleconference\n\nDiscussed w/ Client drafting and filing Motion for\nSummary Judgment and MSJ evidence\n\n$475.00\n\n' 0.7\n\n$332.50\n\n07/10/2020\n\nDW\n\nDraft\n\nCreated 1st draft of Arenberg Affida 1; shared w!\ndent\n\n$425.00\n\n1.0\n\n$425.00\n\n07/10/2020\n\nAU\n\nVarious\n\nReviewed draft affidavit and discussed vi/ DAW\n\n$475.00\n\n0.3\n\n$142.50\n\n07/10/2020\n\nOW\n\nMeeting\n\nDiscussed drab affidavit w/ ALI\n\n5425.00\n\n0.2\n\n$85.00\n\n07/13/2020\n\nOW\n\nReview\n\nReviewed Pt's Request to Produce, re: Clerk\n\n$425.00\n\n0.1\n\n$42.50\n\n07/13/2020\n\nOW\n\nTeleconference\n\nSpoke vt/ Clerk's counsel, re: Request to Produce\n\n$425.00\n\n0.2\n\n$85.00\n\n07/27/2020\n\nOW\n\nReview\n\nReviewed Prs Amended Request to Produce. re:\nClerk\n\n5425.00\n\n0.1\n\n$42.50\n\n07/27/2020\n\nDW\n\nTeleconference\n\nSpoke w/ Oldies counsel. re: Amended Request to\nProduce\n\n$425.00\n\n0.1\n\n$42.50\n\n07/28/2020\n\nDW\n\nDraft\n\nRevised Arenberg affidavit\n\n$425.00\n\n0.5\n\n5212.50\n\n07/29/2020\n\nOW\n\nDraft\n\nFinalized Arenberg Affidavit and sent to dent\n\n$425.00\n\n0.5\n\n$212.50\n\n07/29/2020\n\nDW\n\nResearch &\nPreparation\n\nResearch and prep for Motion for Summary\nJudgment\n\n$42500\n\n1.0\n\n$425.00\n\n07/30/2020\n\nDW\n\nVarious\n\nReceived executed Azonberg Affidavit\n\n$425.00\n\n0.1\n\n$42.50\n\n07/30/2020\n\nOW\n\nDraft\n\nBegan drafting Motion for Summary Judgment\n\n$425.00\n\n2.0\n\n$850.00\n\n08/0512020\n\nDW\n\nDraft\n\nContinued drafting Motion for\n... [truncated, 3081 chars — for the full page use /api/corpus/document/EFTA02734027/332 or ?id=EFTA02734027&page=332]", "char_count": 3081}, {"efta_number": "EFTA02734027", "page_number": 333, "text_content": "09(0212020\n\nAU\n\nMeeting\n\nDiscussed w/ DAW phone caN w/ Pt's counsel\n\n$475.00\n\n0.2\n\n$95.00\n\n09/02/2020\n\nDW\n\nMeeting\n\nDiscussed w/ AU phone cal w/ PIS counsel\n\n$425.00\n\n0.2\n\n$85.00\n\n09/16/2020\n\nDW\n\nEmail\n\nReviewed email from Prs counsel requested\nArenberg to withdraw sanctions motion w/o\nprejudice\n\n$425.00\n\n0.1\n\n$42.50\n\n09/17/2020\n\nDW\n\nMeeting\n\nDiscussed *1AIJ filing motion for CMC\n\n$425.00\n\n0.1\n\n$42.50\n\nOW17/2020\n\nAU\n\nMeeting\n\nDiscussed w/ DAW filing motion for CMC\n\n$475.00\n\n0.1\n\n$47.50\n\n$42500\n\n0.5\n\n$212.50\n\n0.1\n\n$42.50\n\n0.1\n\n$42.50\n\n0.1\n\n$42.50\n\n0.5\n\n$212.50\n\n$425.00\n\n0.7\n\n$297.50\n\n09/18/2020\n\nDW\n\nVarious\n\nDrafted and filed motion to sot case management\nconference; re: MSJ 1st cr Fee hearing 1st\n\n09/18/2020\n\nDW\n\nE-mai\n\nResponded to Prs 9/16/20 email and refuSed to\nwithdraw 57.105 motion: provided copy of motion to\nset CMC and available dates for hearing\n\n$425.00\n\n09/18/2020\n\nDW\n\nEmail\n\nReviewed Prs email insisting mat 57.105 motion be\nwithdrawn\n\n$425c\n\n09/18/2020\n\nDW\n\nE-mail\n\n09/18/2020\n\nDW\n\nE-mail\n\n0922/2020\n\nDW\n\nVarious\n\nDrafted and filed Notice of 'Joann° orri0/1\nup Court Cal; spoke w/ client. re: hearinhate\n\n1002/2020\n\nDW\n\nReview\n\nReviewed Pt's Memo of Law-Opposing Arenberg's\n57.105 motion for feestsancOons\n.\n\n$425.00\n\n0.7\n\n$297.50\n\n10/02/2020\n\nOW\n\nReview\n\nReviewed Prs\nPr\nto, Aroeberg's request to\nschedule 57.105 motion for Noes after MSJ\n\n$42500\n\n0.5\n\n$212.50\n\n10/02/2020\n\nAU\n\nReview\n\nReviewed PraMemo Of Law opposing 571D5\nmotion\n\n$475.00\n\n0.5\n\n$237.50\n\n10.02/2020\n\nAU\n\nReview\n\nReviewed Pi's Response to Aroriberg's request to\nsoiled* 57.105 motion after MSJ\n\n$475.00\n\n0.4\n\n$190.00\n\n10/12/2020\n\nOW\n\nResearch\n\nResearch caselaw 8 statutes, re: response to Prs\nMemo el Law\n\n$425.00\n\n1.0\n\n$425.00\n\n10/13/2020\n\nDW\n\nResearch 8\nAnalyze\n\nContinued researching Caselaw, re: response to\nPt's memo of law\n\n$425.00\n\n1.0\n\n5425.00\n\n10/13/2020\n\nDW\n\nDraft\n\nCreated 1st draft of Response to Firs Memo of Law\nand shared WI Client\n\n$425.00\n\n4.0\n\n$1,700.00\n\n10/13/2020\n\nOW\n\nMeeting\n\nDiscusse\n... [truncated, 2953 chars — for the full page use /api/corpus/document/EFTA02734027/333 or ?id=EFTA02734027&page=333]", "char_count": 2953}, {"efta_number": "EFTA02734027", "page_number": 334, "text_content": "10/15/2020\n\nDW\n\nTelephone\n\nSpoke wi Prs counsel, re: settlement\n\n$425.00\n\n0.1\n\n$42.50\n\n10/15/2020\n\nOW\n\nTelephone\n\nSpoke w/ client, re: Prs settlement proposal\n\n$425.00\n\n0.2\n\n585.00\n\n10/15/2020\n\nAU\n\nVarious\n\nAttended hearing, re: motion to set CMC:\ndiscussed &client\n\n$475.00\n\n1.0\n\n$475.00\n\n10/15/2020\n\nAU\n\nVarious\n\nDiscussed Pie settlement proposal w/ DAW and\nthen w/ Client\n\n$475.00\n\n0.4\n\n$190.00\n\n10/15/2020\n\nOW\n\nMeeting\n\nDiscussed Prs settlement proposal WI AIJ\n\n$425.00\n\n0.2\n\n$8500\n\n10/16/2020\n\nDW\n\nVarious\n\nDrafted and shared proposed order w/ Prs counsel\n\n$425.00\n\n0.5\n\n$212.50\n\n10/16/2020\n\nOW\n\nTelephone\n\nSpoke w/ Pt's counsel, re: settlement\n\n$425.00\n\n0.2\n\n$85.00\n\n10/16'2020\n\nDW\n\nTelephone\n\nSpoke w/ client. re: Prs settlement proposal\n\n$425.00\n\n-!y 0.5\n\n$212.50\n\n10/16/2020\n\nOW\n\nMeeting\n\nDiscussed Pi's settlement proposal tiv/ AU\n\n$425.00 1-4\"•%9.2\n\n$8500\n\n10/16/2020\n\nAU\n\nMeeting\n\nDiscussed Prs settlement proposal tiv1 DAW\n\n$475001\n\n02\n\n$95.00\n\n1a/9,2020\n\nDW\n\nVarious\n\nUploaded proposed order, re: CMC for Judge\nHafele\n\n',\n$425.00\n\n0.1\n\n$42.50\n\n10/19/2020\n\nDW\n\nTelephone\n\nSpoke iv/ client. re: Prs settlement proposal\n\n$425.00\n\n02\n\n$85 00\n\n10/19,2020\n\nDW\n\nTelephone\n\nSpoke wr Pt's counsel. re: settlement\n\n$425.00\n\n0.1\n\n$42.50\n\n10/19'2020\n\nAU\n\n//atilt;\n\nDiscussed PIS settlement proposal w/ DAW\n\n$475.00\n\n0.2\n\n$95.00\n\n10/19/2020\n\nDW\n\nMeeting\n\nDiscussed Prs settlement proposal w/ AU\n\n$425.00\n\n0.2\n\n$85.00\n\n10/20/2020\n\nOW\n\nVarious\n\nReviewed erne from Pl. re: settlement, sent copy\nto Client and cared to discuss\n\n$425.00\n\n0.5\n\n$212.50\n\n10/20/2020\n\nOW\n\nTelephone\n\nSpoke w/ client. re: settlement\n\n$425.00\n\n0.4\n\n$170.00\n\n10/20/2020\n\nOW\n\nTelephone\n\nSpoke w/ Prs counsel, re: setttement\n\n$425.00\n\n0.1\n\n$42.50\n\n1020/2020\n\nOW\n\nTelephone\n\nSpoke w/ client, re: sentment\n\n$425.00\n\n0.1\n\n$42.50\n\n1020V2020\n\nOW\n\nMeeting\n\nDiscussed Pre settlement proposal w/ AU\n\n$425.00\n\n0.2\n\n$85.00\n\n10262020\n\nAIJ\n\nMeeting\n\nDiscussed P1's settlement proposal w/ DAW\n\n$475.00\n\n0.2\n\n$95.00\n\n$425.00\n\n1.0\n\n$425.00\n\n10/2\n... [truncated, 3127 chars — for the full page use /api/corpus/document/EFTA02734027/334 or ?id=EFTA02734027&page=334]", "char_count": 3127}, {"efta_number": "EFTA02734027", "page_number": 335, "text_content": "10/22/2020\n\nAU\n\nVarious\n\nReviewed Pi's Notice of Dropping Aronberg as\nparty; spoke w/ Client and DAW, re: notice and next\nsteps\n\n$475.00\n\n0.5\n\n$237.50\n\nTotals:\n\n74.8\n\n$32,440.00\n\nTime Entry Sub•Total:\n\n$32,440.00\n\nSub•Total:\n\n$32,440.00\n\nTotal:\n\n$32,440.00\n\nAmount Paid:\n\n$0.00\n\nBalance Due:\n\n$32,440.00\n\nEFTA02734362\n\n\f", "char_count": 320}, {"efta_number": "EFTA02734027", "page_number": 336, "text_content": "EXHIBIT \"G\"\n\nEXHIBIT \"G\"\n\nEFTA02734363\n\n\f", "char_count": 41}, {"efta_number": "EFTA02734027", "page_number": 337, "text_content": "Mill. SCHOLZ 8c WYLER, LW.\n\nINC LAW OFFICES OF\n. P.A.\n\nARTHUR I.\n\nAl!LITT COMPANY Or PROFESSIONAL ASSOC.AVORS\nATTORNEYS AT LAW\nGATEWAY TO AMELIA\nSHIMS? GATEWAY BLVD.. SUITE SCUT\nFERNANDINA Basra. FLORIDA 00034\n\nRICHAND a SCHOLZ. PA.\nArcnanc. J. SCHOLZ\nA. WV'S& P.A.\nDOUGLAS A VMS\n\n00U04Als\n\nTELEPHONE (904) EGI-31193\nFAX NO (004) to.7679\nNovember 26, 2019\n\nOffice of the State Attorney\n15th Judicial Circuit\nAnn: Jeanne Howard\n401 North Dixie Highway\nWest Palm Beach, FL 33401\nRe:\n\nC\n\nO SA\n\nCA Florida Holdings, LLC v. Dave Arenberg et al.\nCase No.: 2019-CA-014681\n\nDear Mrs. Howard:\nThe purpose of this letter is to confirm that\nabove-referenced matter.\n\nSchott & Wyler, LLC will represent you regarding the\n\nOur fees will be contingent upon our success in this matter. You will not be liable or required to pay any\nmonies to our office unless we are sores-Wu( in ow representation of you regarding the above-referenced\nlitigation and receive a court order awarding attorneys' fees.\nAccordingly, should we be successful in this matter, you agree to be billed for the time incurred in defending\nthis action at our current hourly rates. At this time, our current hourly rates are: $475.00/hour for senior\npartners, $425.00/hour for other partners. $375.00/hour for associate attorneys, and $125.00/hour for\nparalegal time.\nFurthermore, the attorneys' fees paid to our firm shall be calculated by the above listed hourly rates\nmultiplied by the number of hours expended in defending this action or the total fee mandated and awarded\nby the court order herein, whichever is greater.\nBy signing below, you agree to the terms as set forth above. Please return a signed and dated copy of this\nletter to our office. If you have any questions or concerns, please contact our office. On behalf of the\nfirm, we are proud to represent you in this matter.\nSincerely,\niji h\nk t —\nDouglas A. Wyler, Esq.\nFor the Firm\n\nLA/1,,ta-D\nDate\n\nEFTA02734364\n\n\f", "char_count": 1936}]}