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CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 and Plaintiffs October Notice of Dropping State Attorney Dave Aronberg from the above-captioned lawsuit See Exhibits A and attached hereto The total time Affiants law firm has expended services rendered to date is hours however from the date of Defendant Aron bergs demand Affiant law firm has expended a total of hours Of the hours expended since Defendant Aronbergs demand was served the Affiant Of the hours expended since Defendant Aronbergs demand was served the total time Affiant has expended services rendered to date is hours at the rate of per hour Likewise the total time Affiants law partner Arthur I Jacobs has expended services rendered to date is hours at the rate of per hour Accordingly since Defendant Aronbergs demand was served Defendant Aronbergs counsel JACOBS SCHOLZ WYLER LLC has rendered services in the amount of in conjunction with the defense of the instant action pursuant to Florida Statutes See Exhibit attached hereto Affiant expects to incur an additional hours at an hour in preparing for and attending the hearing on attorneys fees Thus the total amount of hourly attorneys fees the State Attorney is seeking is hours for a total of Additionally the State Attorney seeks a multiplier of which when applied makes the grand total attorneys fees sought herein Dated this 9th day of November FURTHER AFFIANT SA STATE OF FLORIDA COUNTY OF NASSAU The foregoing instrument was acknowledged before me this 9th day of November by Dou A Wyler Esquire who is personally known to me and who did take an oath Name typed printed or stamped TARA JACKSON Notary Pubhc State of Floridi i Commission GG me My Comm Expires Aug Bonded through National Notary Assn CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of November a copy of the foregoing has been electronically filed with the Florida E-File Portal fore-service on all parties of record herein JACOBS SCHOLZ WYLER LLC Is Douglas A Wyler Arthur I Jacobs Esq Fla Bar No Richard Scholz Esq Fla Bar No Douglas A Wyler Esq Fla Bar No Gateway Blvd Suite Fernandina Beach Florida Fax Primary jacobsscholzlaw comcast.net Attorneys/or Defendant Dave Aronberg EXHIBIT A EXHIBIT A Friday September at Eastern Daylight Time Subject SERVICE OF COURT DOCUMENT CASE NO CA FLORIDA HOLDINGS LLC DAVE ARON BERG JACOBS SCHOLZ WYLER LLC A LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW GATEWAY TO AMELIA THE LAW OFFICES OF JACOBS ASSOCIATES P.A ARTHUR JACOBS GATEWAY BLVD SUITE FERNA.."IDINA BEACH F:LORIDA June VIA ELECTRONIC U.S MAIL Stephen A Mendelsohn Esq_ Greenburg Traurig P_A Town Center Circle Suite Boca Raton FL TELEPHONE FAX NO RE CA Florida Holdings LLC Dave Aronberg et al Palm Beach County Case No Dear Mr Mendelsohn RICHARD SCHOLZ P.A RICHARD SCHOLZ DOUGLAS A WYLER P.A DOUGLAS A WYLER As you are aware our finn represents the interests of Dave Aronberg as State Attorney of Palm Beach County Florida in the above referenced matter The purpose of this letter is to demand the voluntary dismissal of your First Amended Complaint the Complaint dated January This demand is made pursuant to section Florida Statutes As you know Section provides Upon the courts initiative or motion of any party the court shall award a reasonable attorneys fee including prejudgment interest to be paid to the prevailing party in equal amounts by the losing party and the losing partys attorney on any claim or defense at any time during a civil proceeding or action in which the court finds that the losing party or the losing partys attorney knew or should have known that a claim or defense when initially presented to the court or at any time before trial a Was not supported by the material facts necessary to establish the claim or defense or Would not be supported by the application of then-existing law to those material facts Today Judge Marx granted with prejudice Defendant Aronbergs Motion to Dismiss Count II of the Plaintiffs Complaint Pursuant to the Courts ruling the Plaintiffs only remaining cause of action consists of Count I for Declaratory Relief Accordingly we believe that the Complaint filed herein and its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to establish the claims asserted and that your claims are not supported by the application of current law to said material facts First and foremost the Complaint is not supported by the material facts necessary to establish the claims asserted because neither Defendant Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit is in custody or control of the grand jury materials sought therein Simply put the declaratory relief sought by the Plaintiff seeks records from my client that are impossible for him or his office to produce Accordingly Defendant Aronberg is not a proper party to this action because no matter what he and his office do not have possession custody or control of the requested materials In addition to the foregoing material facts that negate the claims asserted in the Complaint your claims are also not supported by the application of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection I for use in a civil case it may be disclosed to all parties to the case and to their attorneys and by the latter to their legal associates and employees However the grand iury testimony afforded such persons by the court can only be used in the defense or prosecution ofthe civil or criminal case and for no other purpose whatsoever Moreover even if the Plaintiff were to prevail in the declaratory action Mr Aronberg would be unable to comply with any court order granting disclosure of the requested documents because neither Mr Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession custody or control of the Epstein grand jury records Based on the foregoing if the Complaint is not dismissed within days of the service of this letter the enclosed Motion for Attorneys Fees will be filed and we will seek as sanctions from your client and your firm recovery of the legal expenses incurred in defending this frivolous action Plea Douglas A Wyler Esq For the Firm Encl Defendants Motion for Attorneys Fees IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CA FLORIDA HOLDINGS LLC Publisher of the PALM BEACH POST Plaintiff DA VE ARONBERG as State Attorney of Palm Beach County Florida SHARON BOCK as Clerk and Comptroller of Palm Beach County Florida Defendants I CASE NO DEFENDANT DAVE ARONBERGS MOTION FOR ATTORNEYS FEES Defendant DA VE ARONBERG as State Attorney of Palm Beach County Florida by and through the undersigned attorneys moves the Court pursuant to Florida Statutes Section to award him reasonable attorneys fees for the defense of Plaintiffs First Amended Complaint the Complaint and as grounds therefor would show that on June Plaintiff was served a copy of this Motion together with a letter from the undersigned attorney in accordance with subsection of the above Statute demanding dismissal of the Complaint at least days prior to the filing of this Motion In said letter Defendants attorney advised Plaintiff of the facts which establish that the Complaint is without support of the facts or the law WHEREFORE Defendant DA VE ARONBERG as State Attorney of Palm Beach County Florida respectfully requests the Court enter an Order requiring Plaintiff and Plaintiffs attorneys to pay said Defendants attorneys fees incurred herein after service of this Motion CERTIFICATE OF SERVICE I hereby certify that on this __ day the foregoing was electronically filed via the Florida E-File Portal for electronic service on the parties of record herein JACOBS SCHOLZ WYLER LLC Isl Douglas A Wyler Arthur I Jacobs Esquire Fla Bar No Richard Scholz Esquire Fla Bar No Douglas A Wyler Esquire Fla Bar No Gateway Blvd Suite Fernandina Beach Florida jacobsscholzlaw comcast.net Attorneys for Defendant EXHIBIT EXHIBIT Filing E-Filed PM CA FLORIDA HOLDINGS LLC Publisher of THE PALM BEACH POST Plaintiff DA VE ARONBERG as State Attorney of Palm Beach County Florida SHARON BOCK as Clerk and Comptroller of Palm Beach County Florida Defendants IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO DIVISION AG PLAINTIFF CA HOLDINGS LLCS NOTICE OF DROPPING STATE ATTORNEY DA VE ARONBERG Plaintiff CA HOLDINGS LLC pursuant to Fla Civ I hereby notifies the parties that it has dropped State Attorney Dave Aronberg from the above case Respectfully submitted GREENBERG TRAURIG P.A Attorneys for CA Florida Holdings LLC Publisher of The Palm Beach Post Stephen A Mendelsohn Esq I East Las Olas Boulevard Suite Boca Raton Florida Telephone Facsimile By Isl Stephen A Mendelsohn STEPHEN A MENDELSOHN Florida Bar No mendelsohns algtlaw com smith Viz gtl,nv com FLService gtlaw.com By Isl Michael Grygiel MICHAEL GRYGIEL Admitted Pro Hae Vice State St 6th Floor Albany New York Telephone Facsimile grvgielm gtlaw.com By Isl Nina Boyaiian NINA BOY AJIAN Admitted Pro Hae Vice Century Park East Suite Los Angeles California Telephone Facsimile bovaj iann ivgtlaw com riveraal tvgtlaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this day of October a true and correct copy of the foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system which will send a notice of electronic service for all parties of record herein ACTIVE Isl Stephen A Mendelsohn STEPHEN A MENDELSOHN EXHIBIT EXHIBIT Jacobs Scholz Wyler LLC Gateway Blvd Suite Fernandina Beach FL United States Dave Aronberg Jacobs Scholz Wyler LLC Balance Invoice Invoice Date November Payment Terms Due Date Aronberg adv CA Florida Holdings LLC Time Entries Date EE Activity Description Rate Hours Line Total ow Review Initial review of summons and complaint ow Review Reviewed motion for pro hac vice and Judge Hafele order granting ow Teleconference Teleconference Client re response to lawsuit ow Draft Drafted engagement letter and sent to client ow Review Reviewed 15th circuit local rules AIJ Review Initial review of complaint AIJ Meeting Meeting DAW to discuss lawsuit and strategy ow Meeting Meeting AIJ to discuss lawsuit and strategy AIJ Teleconference Teleconference Client re response to lawsuit ow Research Preparation Research and prep for Motion to dismiss ow Draft 1st Draft motion to dismiss ow Teleconference Teleconference Client re draft motion to dismiss AIJ Review Reviewed 1st Draft MTDismiss AIJ Teleconference Teleconference client re draft motion to dismiss AIJ Meeting Meeting DAW re motion to dismiss ow Meeting Meeting AIJ re MTDismiss ow Draft Completed final draft of motion to dismiss filed with Court ow Teleconference Spoke client re fin_al draft of motion to dismiss ow Teleconference Spoke with Clerks attorney re response AIJ Review Reviewed final draft MTDismiss AIJ Review Reviewed Clerks MTDismiss ow Review Reviewed Clerks Motion to Dismiss ow Review Reviewed Order Setting Hearing on Defendants MTDismiss ow Review Reviewed motion for pro hac vice ow Review Reviewed Pls Amended Complaint ow Teleconference Spoke with client re Amended Complaint ow Review Reviewed Pls notice of filing AIJ Review Reviewed Pls Am Campi ow Review Reviewed Judge Marxs Order Cancelling MTDismiss Hearing ow Review Reviewed Pls Objection to Defendants MTDismiss ow Teleconference Spoke with client re Amended complaint AIJ Meeting Meeting DAW re response to Am Campi ow Meeting Meeting AIJ re response to Am Campi ow Review Reviewed Order granting pro hac vice admission ow Research Draft Researched and drafted response to Amended Complaint ow Teleconference Spoke with Clerks attorney re response to amended complaint ow Various Completed Answer/MTDismiss Amended Complaint filed with Court sent copy to Client ow Draft Drafted and filed Notice of Unavailability AIJ Review Reviewed final Answer/MTDismiss ow Review Reviewed Clerks Answer/MTDismiss ow Review Reviewed Order setting hearing on Defs MTDismiss ow Teleconference Spoke client re order setting MTDismiss hearing for March ow Review Reviewed Pls Opposition to Aronberg MTDismiss Clerks MTDismiss AIJ Review Reviewed Pls Opposition to Aronberg MTDismiss Clerks MTDismiss ow Teleconference Reviewed email from Pls counsel re motion to continue hearing ow Review Reviewed Pls unopposed motion for continuance ow E-mail Emails Clerks counsel re Pls request to continue hearing ow E-mail Reviewed email from Pl re agreed order responded ow Review Reviewed Courts agreed order continuing hearing Reviewed order rescheduling hearing on Defs ow Review MTDismiss ow Teleconference Spoke client re order rescheduling MTDismiss hearing for June AIJ Review Reviewed Order rescheduling MTDismiss hearing ow Review Reviewed order setting Zoom hearing re MTDismiss ow Teleconference Spoke client re hearing will be via Zoom ow Review Reviewed Clerks filing change of atty of record ow Teleconference Spoke with Clerks new counsel Nicole Fingerhut ow E-mail Reviewed Pls email re cases and authorities for MTDismiss hearing responded ow Preparation Began oral argument prep for MTDismiss hearing ow E-mail Reviewed email from Judge Marxs JA and responded ow Various Reviewed Pls page binder re MTDismiss prepped for hearing ow E-mail Drafted and sent email to client re MTD hearing tomorrow ow Attend Hearing Prepped for and attended MTDismiss hearing via Zoom ow Teleconference Spoke Client re debrief MTDismiss hearing ow E-mail Emailed courtesy copies of Aronbergs Answer and MTDismiss to Judge Marx ow E-mail Reviewed response from Client and replied AIJ Attend Hearing Attended MTDismiss hearing via Zoom AIJ Review Reviewed order granting MTDismiss prejudice ow Review Reviewed Courts Order Granting Defendants MTDismiss Count II Prejudice ow Various Shared order Client and spoke re result and plan going forward re Researched Fla Stat drafted ow Various demand letter and proposed motion for attorneys fees/sanctions Served Pls counsel with demand letter and proposed motion AIJ Meeting Meeting DAW re Order ow Meeting Meeting AIJ re Order AIJ Review Reviewed demand and proposed motion for sanction ow Various Reviewed notice of change of attorney re Clerk called and spoke new counsel Cynthia Guerra Reviewed Pls letter refusing to voluntarily dismiss ow Various amended complaint despite demand called and spoke client re Pls refusal next steps DW E-mail Sent client copy of Pls letter refusing to dismiss complaint AIJ Review Reviewed Pls letter refusing to dismiss Count I/Am Campi Spoke client re filing of motion for DW Various fees/sanctions filed motion for attorneys fees based on Pls failure to voluntarily dismiss amended complaint count DW E-mail Email to client re affidavit and summary judgment DW Teleconference Discussed Client drafting and filing Motion for Summary Judgment and MSJ evidence AIJ Teleconference Discussed Client drafting and filing Motion for Summary Judgment and MSJ evidence DW Draft Created 1st draft of Aronberg Affidavit shared client AIJ Various Reviewed draft affidavit and discussed DAW DW Meeting Discussed draft affidavit AIJ DW Review Reviewed Pls Request to Produce re Clerk DW Teleconference Spoke Clerks counsel re Request to Produce DW Review Reviewed Pls Amended Request to Produce re Clerk DW Teleconference Spoke Clerks counsel re Amended Request to Produce DW Draft Revised Aronberg affidavit DW Draft Finalized Aronberg Affidavit and sent to client DW Research Preparation Research and prep for Motion for Summary Judgment DW Various Received executed Aronberg Affidavit DW Draft Began drafting Motion for Summary Judgment DW Draft Continued drafting Motion for Summary Judgment DW Review Reviewed email from Plaintiff attempting to set hearing on motion for fees/sanctions DW E-mail Sent responsive email to Pls counsel DW Meeting Discussed draft MSJ AIJ AIJ Various Reviewed draft MSJ and met DAW to discuss DW Draft Finalized Motion for Summary Judgment filed court along with Aronberg affidavit DW Teleconference Spoke Clerks counsel re request to produce DW Various Reviewed Pls email and accepted conference call invite for DW Review Reviewed Clerks response to request for production Spoke Pls counsel re dispute as to whether DW Teleconference MSJ should be heard before fee motion or vis versa call was unsuccessful AIJ Meeting Discussed DAW phone call Pls counsel ow Meeting Discussed AIJ phone call Pls counsel Reviewed email from Pls counsel requested ow E-mail Aronberg to withdraw sanctions motion w/o prejudice ow Meeting Discussed AIJ filing motion for CMG AIJ Meeting Discussed DAW filing motion for CMC ow Various Drafted and filed motion to set case management conference re MSJ 1st or Fee hearing 1st Responded to Pls email and refused to ow E-mail withdraw motion provided copy of motion to set CMC and available dates for hearing ow E-mail Reviewed Pls email insisting that motion be withdrawn Replied to Pls counsel that the motion for ow E-mail sanctions will not be withdrawn and asking for response re CMG ow E-mail Sent client copy of email exchange Pls counsel called and spoke Client ow Various Drafted and filed Notice of Hearing on set up Court Call spoke client re hearing date ow Review Reviewed Pls Memo of Law opposing Aronbergs motion for fees/sanctions ow Review Reviewed Pls Response to Aronbergs request to schedule motion for fees after MSJ AIJ Review Reviewed Pls Memo of Law opposing motion AIJ Review Reviewed Pls Response to Aronbergs request to schedule motion after MSJ ow Research Research caselaw statutes re response to Pls Memo of Law ow Research Continued researching caselaw re response to Analyze Pls memo of law ow Draft Created 1st draft of Response to Pls Memo of Law and shared Client ow Meeting Discussed AIJ caselaw and draft response to memo AIJ Various Reviewed draft MSJ discussed draft DAW and caselaw ow Draft Finalized and filed Response to Pls Memo of Law ow Telephone Spoke client re memo of law ow Telephone Spoke client again re response to memo of law ow Attend Hearing Attended hearing re Motion to Set CMC called client to discuss ow Various Reviewed email and letter from Pl re settlement Sent copy to Client and called to discuss ow Telephone Spoke PJs counsel re settlement ow Telephone Spoke client re Pls settlement proposal AIJ Various Attended hearing re motion to set CMG discussed client AIJ Various Discussed Pls settlement proposal DAW and then Client ow Meeting Discussed Pls settlement proposal AIJ ow Various Drafted and shared proposed order PJs counsel ow Telephone Spoke PJs counsel re settlement ow Telephone Spoke client re PJs settlement proposal ow Meeting Discussed PJs settlement proposal AIJ AIJ Meeting Discussed PJs settlement proposal DAW ow Various Uploaded proposed order re CMG for Judge Hafele ow Telephone Spoke client re Pls settlement proposal ow Telephone Spoke PJs counsel re settlement AIJ Meeting Discussed PJs settlement proposal DAW ow Meeting Discussed PJs settlement proposal AIJ ow Various Reviewed email from Pl re settlement sent copy to Client and called to discuss ow Telephone Spoke client re settlement ow Telephone Spoke Pls counsel re settlement ow Telephone Spoke client re settlement ow Meeting Discussed PJs settlement proposal AIJ AIJ Meeting Discussed PJs settlement proposal DAW Drafted and filed Motion to Set Hearing on ow Various Aronberg MSJ drafted proposed order granting motion to set checked court availability emailed PJs counsel re choose date for hearing ow Review Reviewed Order re CMG unnecessary ow Telephone Spoke client re media response ow Telephone Spoke client re media response ow Telephone Spoke client re media response ow Telephone Spoke client re media response ow Telephone Spoke client re media response ow E-mail Sent email Aronberg statement to media AIJ Meeting Discussed media response DAW ow Meeting Discussed media response AIJ Reviewed PJs Notice of Dropping Aronberg as ow Various party spoke Client and AIJ re notice and next steps Reviewed Pls Notice of Dropping Aronberg as AIJ Various party spoke Client and DAW re notice and next steps Totals Time Entry Sub-Total Sub-Total Total Amount Paid Balance Due
