the State Attorneys prosecution of those crimes in secrecy should be unsealed The resounding answer to this question which is not contested by either the Defendant Clerk or the former Defendant the Palm Beach County Office of State Attomey is yes The Palm Beach Post seeks summary judgment on its claim for public access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury empaneled during the first Epstein sex abuse prosecution Typically access to such materials is limited for example in order to prevent the flight of those whose indictment may be contemplated and their ability to conceal or destroy evidence to ensure jurors candor in deliberations and to protect an accused who is later exonerated However these factors are inapplicable here Moreover Florida law expressly authorizes the disclosure of grand jury proceedings under certain circumstances including as here in the furtherance of justice Fla Stat It can no longer credibly be maintained that continued blanket secrecy over the proceedings that led to the egregiously flawed Epstein indictment is warranted under the law To the contrary transparency is required to promote public understanding of the criminal justice system and public confidence in the fair administration of justice As detailed below Epstein was accused of sexually abusing and trafficking dozens of women and girls in south Florida among other locations over a period of several years while exploiting his wealth and political connections to derail his prosecution and obstruct the administration of justice at every tum Public disclosure of the Epstein grand jury proceedings will shed light on the extent to which those in our government entrusted with the solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties in this instance Justice will be furthered where it is demonstrated either that As set forth infra at based upon his statement that he no longer contests the relief sought by The Palm Beach Post the State Attorney has been dropped from the case pursuant to Fla Civ GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE Epstein was treated like others accused of similar heinous crimes or as appears more likely those who chose to give Epstein favorable unusual in the words of the Town of Palm Beach Police Chief treatment are exposed and held accountable From the incomplete information now in the public domain the State Attorneys choice to refer Epsteins case to the grandjury which was extraordinary for this type of case gives rise to a strong inference of favoritism and corresponding disregard for the rights of the minor victims of Epsteins habitual sex trafficking Access to the grand jury materials will allow the public to determine whether the grand jury process and the secrecy that comes with it was used to further justice or instead operated to shield Epstein and his co-conspirators from the consequences of their criminal activities Accordingly Fla Stat Section authorizes the disclosure of Epsteins grand jury proceedings Even in the absence of such a statutory basis this Court is empowered to order public disclosure pursuant to its inherent authority and supervisory powers over the grand jury Indeed courts throughout the country in the past several decades including in the case of the controversial Breonna Taylor shooting in have done exactly that where the publics interest in high-profile grand jury proceedings has outweighed the general need for secrecy This is particularly so where as here many of the details of Epsteins criminal misdeeds have already been made available in the public domain through extensive news reporting by among others The Palm Beach Post by the many civil suits brought against Epstein and his co-conspirators and by the victims themselves II FACTS NOT IN DISPUTE As reflected in the respective Answers of the Defendants as well as filings by the parties the material facts underlying this action are uncontested See Answer of State Attorney Answer of Clerk GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE A The First Epstein Sex Crimes Investigation Indictment and Plea Agreement The Police Investigation and Search of Epsteins Residence The investigation into Epsteins sex crimes began more than fifteen years ago when a 14-year-old girls stepmother reported to police in the Town of Palm Beach that Epstein and others who worked for him arranged for her to give Epstein a massage Epstein required the girl to strip exposed himself and masturbated while touching her The girl was paid Epstein was years old at the time Appendix at Recarey Depo Following this initial report in the Palm Beach Police Department PBPD and later in the FBI investigated Epstein Interviews under oath with additional victims and witnesses revealed that the events described by the 14-year-old girl occurred with disturbingly similar details including sexual contact with each of the other victims In addition one of the girls admitted to having intercourse with Epstein while others stated that they were instructed by Epstein to have sexual relations with an adult female in front of Epstein Appendix at Recarey Depo One of the victims stated that she was afraid to speak to the police because Epstein was very wealthy that he could pay someone to hurt her or her family Appendix at Recarey Depo Epstein told at least one victim that bad things could happen if she spoke of the massages to anyone Appendix at Recarey Depo Both the victim/witness interviews as well as evidence retrieved following a search of Epsteins home showed that many of the girls involved were under the age of According to Detective Recarey the lead detective on the case one of the photos removed from the master GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE bedroom was of a naked girl who was ounger than ten Appendix at Recarey Depo The police search of Epsteins residence also found two hidden cameras and throughout the house large numbers of nude photos of girls including victims whom the police had not interviewed in the course of their investigation It appeared however that some evidence was removed and the house had been sanitized Appendix at Recarey Depo The PBPD believe that Epstein was tipped off about the search likely through a leak in the State Attorneys office Appendix at Department of Justice Office of Professional Responsibility Report OPR Report Then-Palm Beach County State Attorney Barry Krischer among other influential members of Palm Beach society told the PBPD to back off the investigation of Epsteins crimes Appendix at Reiter Depo at Another member of the State Attorneys Office further gave Detective Recarey the feeling that she was trying to brush this case under the carpet Appendix at Recarey Depo In March a State grand jury was scheduled at which all of Epsteins victims identified during the investigation by law enforcement authorities were expected to testify The proceeding was postponed however due to meetings between the State Attorneys Office and Epsteins prominent criminal defense lawyer and personal friend Alan Dershowitz Appendix at OPR Report Recarey Depo Police Chief Reiter Chastises the State Attorney Another grand jury was convened in April but canceled the day before it was to begin receiving evidence Appendix at Recarey Depo GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE On May Town of Palm Beach Police Chief Michael Reiter wrote a personal and confidential letter to former State Attorney Krischer stating I must renew my prior observation to you that I continue to find your offices treatment of the Epstein cases highly unusual It is regrettable that I am forced to communicate in this manner but my most recent telephone calls to you and those of the lead detective to your assigned attorneys have been unanswered and messages remain unreturned After giving this much thought and consideration I must urge you to examine the unusual course that your offices handling of this matter has taken and consider if good and sufficient reason exists to require your disqualification from the prosecution of these cases Emphasis supplied Appendix at Reiter Letter Chief Reiter wrote the letter because he knew that Mr Krischer was making decisions about this case and felt his objectivity was lacking Appendix at Reiter Depo Chief Reiter believed Krischers objectivity was compromised because when the Chief first told him about the case Krischer said lets go for it this is an adult male in his fifties whos had sexual contact with children of the ages of the victims He said this is somebody who we have to stop However once Epstein became aware of the investigation and his attorneys contacted the State Attorneys Office the tone and tenor of the discussions of this case with Mr Krischer changed completely One point he suggested that we write Epstein a notice to appear which would be for a misdemeanor He just completely changed from not only our first conversation about this and he didnt know the name Jeffrey Epstein till when he had been informed of Mr Epsteins reputation and his wealth and I just thought that very unusual I feel like I know him or knew him very well the State Attorney and I just felt like he could not objectively make decisions about this case Appendix at Reiter Depo Chief Reiter was further motivated to write his letter because it was pretty clear to me that Mr Krischer did not want to prosecute this case the suggestion that multiple victims GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE and some of the crimes felonies that he should write a notice to appear for a misdemeanor and the scheduling of a grand jury on an issue like this is extremely rare And he fact that he and I had an excellent relationship and yet he wouldnt return my phone calls I mean it was clear to me by his actions that he could not objectively look at this case Appendix at Reiter Depo The State Attorneys Referral to the Grand Jury A Single Victim Testifies Chief Reiters letter to State Attorney Krischer enclosed the Town of Palm Beach Police Departments probable cause affidavits charging Epstein and two of his assistants with multiple counts of unlawful sex acts with a minor and one count of sexual abuse and requested that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges against him which charges would be public Appendix at Reiter Letter Instead State Attorney Krischer elected to refer the case to a grand jury which is mandatory for capital cases but rarely used for all other crimes This was the first time that a sex crimes case was presented to a grand jury in Palm Beach County Appendix at Reiter Depo In April the Palm Beach Police Department learned that Assistant State Attorney Lanna Belohlavek who was in charge of prosecuting sex crimes had offered a plea deal to Epsteins attorneys Alan Dershowitz and Guy Fronstin without first discussing the matter with the police The plea deal allowed Epstein to plead to a single count of aggravated assault with intent to commit a felony and receive no more than five years probation upon the completion of which he would not have a criminal record Epstein rejected the deal Appendix at OPR Report At the July grand jury proceedings the State Attorneys Office presented testimony and evidence from just one victim even though the State Attorney was aware of the GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE true number of victims because they had the probable cause affidavit which indicated all the facts Appendix at Recarey Depo at After hearing from the single victim the grand jury returned an indictment on a sole count of solicitation of prostitution There is no mention in the indictment of the victim being a minor See Appendix at Indictment at Chief Reiter did not consider fifteen-year-olds sixteen-year-olds who are paid money to engage in sexual contact as prostitution Appendix at Reiter Depo Detective Recarey had the same opinion because there was no negotiation between the parties Appendix at Recarey Depo at A second of Epsteins victims was supposed to testify before the grand jury but was unable to attend because of a school exam Appendix at Recarey Depo With respect to why the numerous other young girls known to have been abused by Epstein were not presented as witnesses and crime victims to the grand jury convened in July or why State Attorney Krischer who was initially eager to investigate and prosecute Epstein for his crimes over time lost the desire to do so Krischer recently explained to the U.S Department of Justice that under state law as it existed until changed in his office prosecuted minors as young as for prostitution The possibility that Epsteins victims themselves could have been prosecuted caused great consternation within the office and according to Krischer resulted in the decision to put the case before the grand jury But the State Attorneys Office some years earlier even suggested that the police no longer do sting operations for prostitution because they didnt want to prosecute them Appendix at Reiter Depo When Chief Reiter asked him about the unusual decisions to proceed with a grand jury and call only one witness Krischer explained that the victims werent credible in his mind and it was the policy of the GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE State Attorneys Office not to charge molestation type cases when it was consensual Appendix at Reiter Depo Krischer also told Chief Reiter that he chose a grand jury because it was a noteworthy investigation a noteworthy prosecution Appendix at Reiter Depo During the grand jury appearance of the single victim who testified the State Attorney presented evidence that vilified the victim and attacked her credibility including soliciting testimony regarding underage drinking and questionable personal behavior that was umelated to the charges against Epstein This information was initially brought to the attention of the State Attorneys Office by Epsteins defense counsel Appendix at OPR Report pp Recarey Depo The State Attorney who presented the case to the grand jury did not believe that some of the victims were victims based on the social media materials that were supplied by Epsteins defense team Appendix at Recarey Depo The Federal Investigation the State Attorney Intentionally Torpedoed the Case Before the Grand Jury Following the deficient July indictment and with Chief Reiters encouragement the FBI began its own investigation of Epstein because Chief Reiter did not feel as though justice had been sufficiently served by the State Appendix at Reiter Depo Detective Recarey shared the same view that it wasnt any justice served Appendix at Recarey Depo Deputy Chief of the Criminal Division of the U.S Attorneys Office Andrew Lourie in a transmittal letter with the prosecution memo of Assistant U.S Attorney Ann Marie Villafana told Criminal Chief Matthew Menchel The state intentionally torpedoed the case in the grand jury so it was brought to us Appendix at OPR Report emphasis supplied GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE When the FBI commenced its own investigation then-U.S Attorney for the Southern District of Florida Alexander Acosta asked First Assistant U.S Attorney Jeffrey Sloman whether it was appropriate to approach State Attorney Krischer and give him a heads up re where we might go Sloman replied No for fear that it will be leaked straight to Epstein Appendix at OPR Report The Infamous Non-Prosecution Agreement Please Tell Me You Are Joking Acosta was well aware that the PBPD brought the case to the FBIs attention because of a concern that the State Attorneys Office had succumbed to pressure from defense counsel Villafana informed both Acosta and Sloman of this when she met with them at the start of the federal investigation Acosta confirmed that he was aware that the PBPD was dissatisfied with the State Attorneys Offices handling of the case Appendix at OPR Report Records unsealed in revealed that the FBI compiled reports on confirmed minors that were victims of Epsteins sexual predations Based on evidence gathered by the FBI a 53-page indictment was prepared by the U.S Attorneys Office in June However at the request of Epsteins lawyers the indictment was never presented to a federal grand jury Appendix at OPR Report pp Instead Acosta negotiated a plea deal in the form of a Non-Prosecution Agreement NPA with Epsteins team oflawyers that granted immunity to Epstein along with four named co-conspirators and any unnamed potential co-conspirators from all federal criminal charges Appendix at NPA Shortly before the NP A was signed additional information came to light that suggested the State Attorneys Office was predisposed to manipulating the process in Epsteins favor Specifically during a September meeting at the State prosecutors suggestion the GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE USAO team agreed with Acostas subsequent approval to permit Epstein to plead guilty to one state charge of solicitation of minors to engage in prostitution rather than the three charges the USAO had originally specified The State prosecutor assured Lourie that the selected charge would require Epstein to register as a sexual offender Shortly thereafter the USAO was told by defense counsel that despite the assurances made to Lourie the State prosecutor had advised Epstein incorrectly it turned out that a plea to that particular offense would not require him to register as a sexual offender Yet despite this evidence which at least suggested that the State Attorney should not have been considered to be a reliable partner in enforcing the NP A Acosta did not alter his decision about proceeding with a process that depended completely on State authorities for its successful execution Appendix at OPR Report Throughout the remainder of and through the first half of Epsteins lawyers and the U.S Attorney continued negotiating the plea arrangement Epsteins lawyers insisted that the victims not be notified the deal be kept confidential and under seal and all grand jury subpoenas including one that had already been issued for Epsteins computers be withdrawn Appendix at OPR Report pp Reiter Depo Upon learning of a plea deal offered by State Attorney Krischer that would result in a mere 90-day jail term for Epstein Villafana wrote to her immediate supervisor Please tell me that you are joking Maybe we should throw him Epstein a party and tell him we are sorry to have bothered him Villafana and her immediate supervisor later had phone and email exchanges with Krischer and with Epsteins local counsel to insist that the State plea comply with the terms of the NPA or we will consider it a breach of the agreement and proceed accordingly Villafana further advised her superior Someone really needs to talk to Barry Krischer Appendix at OPR Report GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE In a September email from State Attorney Krischer to Villafana regarding the NP A Krischer stated Glad we could get this worked out for reasons I wont put in writing Appendix at OPR Report According to Chief Reiter the NPA was unsatisfactory as the U.S Attorneys Office had advised him that typically these kinds of cases with just one victim would end up in a ten-year sentence Appendix at Reiter Depo On June Epstein pled guilty to two State charges one count of solicitation of prostitution and one count of solicitation of prostitution with a minor under the age of He was sentenced to months in jail followed by a year of community control or house arrest and was adjudicated as a convicted sex offender required to register twice a year in Florida Appendix at Plea Deal The NP A allowed Epstein to receive immunity from federal sex-trafficking charges that could have sent him to prison for life Former State Attorney Krischer communicated with Acosta concerning the NPAs negotiation with Epsteins lawyers Appendix at NPA OPR Report Epstein was not incarcerated in a Florida prison for the State crimes for which he was convicted Instead he was placed in a private wing of the Palm Beach County Stockade where after months he was allowed to leave the jail on work release for up to hours a day days a week His private driver provided his transportation to and from work Appendix at OPR Report pp Epstein was released five months early Appendix at OPR Report Epstein violated the terms of his probation but was not prosecuted Appendix at Recarey Depo OPR Report GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE Epsteins victims only learned after the fact about his plea in State court and filed an emergency petition to force federal prosecutors to comply with the Crime Victims Rights Act U.S.C CVRA which mandates certain rights for crime victims including the right to be informed about plea agreements and the right to appear at sentencing U.S District Judge for the Southern District of Florida Kenneth A Marra ruled in that federal prosecutors violated the CVRA by failing to notify Epsteins victims before allowing him to plead guilty to only the two State offenses Appendix at OPR Report Following publicity exposing the extraordinary leniency of Epsteins plea deal public records reveal that dozens of civil suits were brought against Epstein most of which Epsteins lawyers settled out-of-court In Epstein was registered as a level three i.e high risk ofrepeat offense sex offender in New York a lifelong designation In the New York County District Attorneys office unsuccessfully sought to lower his registration to low-risk level one During the course of the Town of Palm Beach and FBI investigations Epstein retained private investigators to follow harass and photograph his victims and their families as well as Chief Reiter and the Town of Palm Beach detective who investigated the case against Epstein Appendix at Reiter Depo Recarey Depo Epsteins victims were threatened against cooperating with law enforcement and told that they would be compensated only if they did not cooperate with law enforcement Appendix at Recarey Depo Detective Recarey died on May The Second Epstein Sex Crimes Investigation Indictment Suicide On July Epstein was arrested on federal sex trafficking charges Appendix at OPR Report iv GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE The United States governments investigation of new allegations and charges stemmed in part from continued press investigations into and reporting on the mishandling of the charges and the civil suits that followed Appendix at OPR Report pp i xii In a July letter to the federal district court by the U.S Attorney for the Southern District of New York Epstein was described as a serial sexual predator who preyed on dozens of minor girls over a period of years The letter emphasized that the Government has real concerns grounded in past experience with this defendant that if allowed to remain out on bail the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case including victims and their families and otherwise attempt to obstruct justice It also described the results of the FBIs search of Epsteins Manhattan townhouse evidence of sex trafficking in the form of hundreds and perhaps thousands of sexually suggestive photographs of fully or partially-nude females including underage females In a locked safe compact discs were found with handwritten labels including the descriptions Young Name Name Misc nudes and Girl pies nude Appendix at Berman Letter at pp On July prosecutors with the Public Corruption Unit of the U.S Attorneys office for the Southern District of New York charged Epstein with sex trafficking and conspiracy to traffic minors for sex The grand jury indictment alleges that dozens of underage girls were brought into Epsteins mansions for sexual encounters A few days later owing to public outcry over the NPA with Epstein entered into by Acosta who by then was serving as U.S Secretary of Labor in the Trump administration Acosta resigned from office Appendix at DOJ U.S Attorneys Office S.D.N.Y Press Release OPR Report iv Epstein was denied bail and was placed into pretrial detention at the federal Metropolitan Correction Center in lower Manhattan Appendix at OPR Report iv GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE On or about August Florida Gov Ron DeSantis ordered a State criminal probe into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their handling of the Epstein underage sex trafficking case Appendix at OPR Report vii On August Epstein was found dead in his cell at the Metropolitan Correctional Center His cause of death was determined to be suicide Appendix at OPR Report The August SDNY Hearing Epsteins Victims Speak On account of his death prosecutors sought to dismiss the indictment against Epstein while maintaining that they would continue to investigate his co-conspirators United States Senior District Judge Richard Berman ordered a hearing on August on the prosecutors decision to dismiss the indictment and allowed victims to speak at the hearing Appendix at August Hearing Transcript before the Honorable Richard Berman Hearing Transcript In the course of the hearing more than two dozen victims delivered their personal stories of pain frustration and sexual abuse at the hands of Epstein Several victims spoke of violent rape by Epstein Many more victims were present in the courtroom but did not testify Appendix at Hearing Transcript While some questioned the reasoning behind the courts decision to give the victims voice after Epsteins death District Judge Berman noted that a public hearing is the preferred vehicle for its resolution emphasizing that public hearings are exactly what judges do Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of Indeed even Epsteins defense lawyer noted at the hearing that the court is the institution that most people have confidence in in these very troubled times Appendix at Hearing Transcript GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE At the August 27th hearing Epsteins victims now mature women spoke about their exploitation and coercion and to the fact that many of them were in very vulnerable situations and in extreme poverty circumstances where they didnt have anyone on their side to speak on their behalf One victim lamented that as a victim she never got to see what the agreement was or why the special treatment got approved in the Florida case years earlier Another noted how completely different the investigators who secured the federal indictment were from the prosecutors in the Florida case both in their treatment of her and their investigation of her victimization by Epstein Appendix at Hearing Transcript A former federal judge in attendance at the August 27th hearing emphasized that transparency is one of the overriding objectives in our criminal justice system Appendix at Hearing Transcript Nearly all of the victims expressed the conviction that the secrecy that shielded Epstein has caused them irreparable harm and that an opportunity to address his criminal wrongdoings and those of the individuals who enabled his sexual racketeering would allow for at least some measure of justice to be served after his death Indeed one victim stated Any efforts made to protect Epsteins name and legacy send a message to the victims that he wins and that he is untouchable Another victim expressed fear that this is a world where there are predators in power a world where people can avoid justice if their pockets run deep enough In short the unusual treatment Epstein received in Florida in based on his wealth social status and connections severely eroded the publics faith in the integrity and impartiality of the criminal justice system Appendix at Hearing Transcript GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE The Palm Beach Posts Extensive 15-Year Reporting On Epsteins Crimes Plaintiff The Palm Beach Post is a community newspaper serving readers in Palm Beach County and the Treasure Coast vicinity The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist three other times Beginning in The Palm Beach Post has extensively investigated and reported on the allegations against the law enforcement investigation of and the crimes committed by Epstein and his co-conspirators A true and correct copy of a compilation of the The Palm Beach Posts reportage in either the computerized format in which the articles are maintained in The Palm Beach Posts electronic archives or the news print edition in which originally published is included in the Appendix at Since the filing of the initial Complaint in this matter The Palm Beach Post along with media worldwide has continued to report on Epsteins crimes and the ongoing official proceedings resulting from those crimes Procedural History The initial Complaint in this action was filed on November It alleged one count under Florida Statutes Section Both Defendants named in the Complaint the Clerk of Palm Beach County and Dave Aronberg as the State Attorney moved to dismiss the Complaint In response to the Defendants motions The Palm Beach Post filed an Amended Complaint on January adding an additional count for declaratory relief On January both Defendants the Clerk and the State Attorneys Office answered Count I of the Amended Complaint declaratory relief and moved to dismiss Count II of the Amended Complaint Section GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE In its Answer the State Attorneys Office denied that it is in possession and/or control of documents that are the subject of this action State Attorney Answer By contrast in its Answer the Clerk admitted that she is in possession and/or control of documents that are the subject of this action Clerk Answer The Defendants Motions to Dismiss were heard on June While this case is assigned to Division AG which is currently presided over by the Honorable Donald Hafele Chief Judge of the Fifteenth Judicial Circuit Hon Krista Marx presided over the June hearing on the State Attorney and Clerks Motions as the Motions implicate records of the Palm Beach County grand jury over which the Chief Judge presides June Order granting motions to dismiss Order At the June hearing Chief Judge Marx stated I dont think anybody is saying that there isnt a cause of action under Section or that the press doesnt have standing Appendix at June Hearing Transcript before the Honorable Krista Marx June Hearing Transcript at see also nowhere have I said there isnt a cause of action So Im not telling you you dont have a cause of action Attorneys for both the Clerk and the State Attorneys Office unequivocally stated that they did not seek to block access to the records sought by The Palm Beach Post Appendix at June Hearing Transcript at On June Chief Judge Marx issued an order granting Defendants motions to dismiss Count II of the Amended Complaint leaving Count I against which neither Defendant had filed a motion in the action The Court held that there was no private cause of action embodied in Section Specifically the Order stated that the Court does not suggest The Post has no available mechanism to obtain a court order granting it access to the grand jury GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE proceedings The Court also does not render any opinion as to whether releasing these records is appropriate for the purpose of furthering justice within the meaning of section Rather the Courts dismissal of Count II is necessitated by precedent and the simple fact that a civil lawsuit against the State Attorney and Clerk under section is not the proper mechanism for The Post to pursue its goal Order at In its Amended Motion for Attorneys Fees filed on November the State Attorneys Office stated that the State Attorney has no objection to the Clerk producing and disclosing the Requested Materials should the Court grant an order to that effect Amended Motion for Attorneys Fees tl see also i the State Attorney has no objection and never has had any objection to the Clerk releasing the records sought by Plaintiff In November the Office of Professional Responsibility at the Department of Justice released the results of its investigation into allegations that in prosecutors in the U.S Attorneys Office for the Southern District of Florida improperly resolved a federal investigation into the criminal conduct of Jeffrey Epstein by negotiating and executing the NP A referenced above Appendix at OPR Report i The OPR collected and reviewed materials relating to the state investigation and prosecution of Epstein including sealed pleadings grand jury transcripts and grand jury audio recordings Appendix at OPR Report I ARGUMENT A Legal Standard A party moving for summary judgment must show the absence of any genuine issue of material fact Donnell WF Taylor Co So.3d Fla Dist Ct App citing Moore Morris So.2d Fla Inferences must be drawn in favor of the non-moving party however the judgment sought must be rendered immediately if the GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE pleadings and summary judgment evidence on file show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law Id quoting Fla Civ This is such a case there are no issues as to any material fact underlying The Palm Beach Posts request for summary judgment on its declaratory relief claim Relevant Legal Framework Fla Stat Grand Jury Secrecy Is Not Absolute Typically grand jury proceedings are conducted and maintained in secret Fla Stat But this secrecy has never been and was never intended to be absolute First grand jury proceedings are subject to public disclosure to the extent mandated by constitutional free speech principles as a testifying grand jury witness is free to disclose her grand jury testimony In Buttenvorth Smith the United States Supreme Court weighing the competing interests of grand jury secrecy and the First Amendment held unconstitutional Section prohibition on a witness revealing her own testimony U.S The secrecy of grand juries in Florida is thus qualified not absolute based on principles embodied in the First Amendment Second Section specifically provides exceptions to grand jury secrecy the testimony of a witness examined before the grand jury or other evidence received by it may be disclosed when required by a court for the purpose of a Ascertaining whether it is consistent with the testimony given by the witness before the court Determining whether the witness is guilty of perjury or Furthering justice Fla Stat a The Florida The Florida Supreme Court has similarly confirmed that grand jury secrecy is not absolute and that any harm to public officeholders from disclosure will be the product of their own conduct and not the consequence of an umestrained body of misguided citizens Miami Herald Pub Co Marko So.2d Fla The decision in Marko emphasized that a grand jurys important role in exposing official misconduct precludes restricting access to its activities for the purpose of protecting public officeholders Id The benefits to be derived from this extraordinary exercise in citizen participation in the grand jury would be severely limited if the fruits of that activity were not available to the public on whose behalf it is undertaken Implicit in the power of the grand jury to investigate and expose official misconduct is the right of the people to be informed of its findings GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE legislature therefore clearly intended to empower a court to order the disclosure of grand jury proceedings for among other reasons to further justice as this Court should do here Subsequent to such disclosure The Palm Beach Post is not as the State Attorney has previously argued State Attorney Motion to Dismiss at pp constrained by the statute from using the materials for public disclosure-nor could it be under the First Amendment The Palm Beach Post Has Standing Under Section The Palm Beach Post has the right to maintain this private right of action because the furtherance of justice an express legislative exception to grand jury secrecy is intended for the public benefit and The Palm Beach Post seeks access on behalf of the public it serves Fla Stat It is further mandated in Fla Stat that the legislature intended for a court to be the party to make the determination of disclosure Fla Stat In other words the legislature granted the judiciary the power to consider and determine the propriety and scope of grand jury secrecy The United States Supreme Court has recognized that the invocation of grand jury interests is not some talisman that dissolves all constitutional protections Buttenvorth U.S at quoting US Dionisio U.S see also Landmark Communications Inc Virginia U.S balancing states interest in preserving confidentiality of judicial misconduct proceedings against rights of newspaper reporting on such proceedings The Supreme Court has further recognized that the press has a constitutional right of access to criminal proceedings see e.g Richmond Newspapers Inc Virginia U.S Indeed such a limitation would render the statute a prior restraint the most serious and the least tolerable infringement on First Amendment rights Nebraska Press Ass Stuart U.S noting a deeply-seated American hostility to prior restraints To the extent redactions to the grand jury materials may be required to protect the privacy of unnamed victims or third parties the Court of course may require such redactions prior to ordering disclosure of the records GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE including pre-trial criminal proceedings Newman Graddick F.2d 11th Cir Indeed the integrity of the judicial process which public scrutiny is supposed to safeguard is just as much at issue in proceedings of this kind pre and post-trial as at trial Id at see also Miami Herald Puhl Co Lewis So.2d Fla identifying the news media as a public surrogate in matters concerning the closure of judicial proceedings The press also has a First Amendment interest in receiving information from willing speakers See Va State Bd of Pharmacy Va Citizens Consumer Council Inc U.S Where a speaker exists the protection afforded by the First Amendment is to the communication to its source and to its recipients both Pittman Cole F.3d 11th Cir The Supreme Court has recognized that the First Amendment offers protection to both speakers and those wishing to receive speech see also Stephens Cnty of Albemarle VA F.3d 4th Cir providing that a plaintiff has standing to assert a right to receive speech by showing that there exists a speaker willing to convey the information to her Because of the unique role performed by the press as a public surrogate Lewis So.2d at in protecting the right of access and its interest in reporting information about criminal proceedings news organizations presumptively have a right to access judicial records Comm Ala Dep of Corr Advance Local Media LLC F.3d 11th Cir and standing to question the validity of an order restricting publicity because its ability to gather news is directly impaired or curtailed Lewis So.2d at see also Carlson United States F.3d 7th Cir as a member of the public the Reporters Committee has standing to assert its claim to grand jury materials because such materials are public records to which the public may seek access even if that effort is ultimately unsuccessful GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE Here the continued denial of access to the information sought by The Palm Beach Post on behalf of its journalists and the public unquestionably constitutes irreparable injury Gainesville Woman Care LLC State of Florida So.3d Fla see also Zerilli Smith F.2d D.C Cir noting that the pres function as a vital source of information is weakened whenever the ability of journalists to gather news is impaired as it is by Attorney Generals refusal to disclose unredacted report and underlying grand jury materials The Palm Beach Post does not disagree that Section makes no express provision for a civil suit or civil liability but that is just the start of the inquiry Where a statute like forbids the doing of an act which may be to the plaintiffs injury though no action be given in express terms by the statute for the omission or commission the general rule of law is that the party injured should have an action for where a statute gives a right there although in express terms it has not given a remedy the remedy which by law is properly applicable to that right follows as an incident Smith Piezo Tech and Prof Adm rs So.2d Fla Supreme Court of Florida implied a statutory cause of action for the wrongful discharge of employees who sought workers compensation benefits Here the forbidding of disclosure of grand jury proceedings injures The Palm Beach Post The statute in tum gives a right to disclosure of those proceedings and The Palm Beach Post should have a cause of action to enforce that right In determining whether a private right of action lies in a statute courts in Florida consider whether the plaintiff is one of the class for whose special benefit the statute was enacted whether there is any indication either explicit or implicit of a legislative intent to create or deny such a remedy and whether judicial implication is consistent with the underlying GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE purposes of the legislative scheme Fischer Metcalf So.2d Fla 3d DCA adding the second and third factors previously courts considered solely the class benefited factor Courts must strike a balance neither fashioning a per se rule of construction that implicit in every penal statute is a concomitant civil remedy nor relinquishing the task of judicial implication in the face oflegislative faltering or uncertainty Fischer So.2d at quoting Roger Rankin Enters Inc Green So.2d Fla 3d DCA Consideration of these three factors establishes a private right of action in Section First the statutory exception to grand jury secrecy embodied in Section furthering justice is intended to benefit the public at large not just those previously party to the grand jury proceeding at issue Because as set forth above members of the press are public surrogate Lewis So.2d at and play a vital role in gathering information and reporting on the criminal justice system The Palm Beach Post is one of the class for whose especial benefit the statute was enacted namely the public itself See Moyant Beattie So.2d Fla 4th DCA finding plaintiffs had the right to maintain a private cause of action as the persons the legislature intended to protect by the enactment of the relevant statute Second there is a dearth oflegislative history surrounding Section and The Palm Beach Post has been unable to identify any documents capturing the Legislatures intent regarding the existence of a private right of action There is no explicit statement in favor of such a right but to be clear there is also no intent express or otherwise to prohibit a private right of action in the absence of which disclosure of grand jury materials to further justice under the statute would be rendered a hollow vessel See Moyant So.2d at The absence of express provision for civil liability in the case of violation of a statute does not negative the GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE existence of a legislative intent that the statute shall effect private rights quoting Florida Statutes Section In such circumstances consideration of the third factor whether judicial implication is consistent with the underlying purposes of the legislative scheme is particularly instructive When scrutinizing the history of legislation to determine legislative intent it is appropriate to consider acts passed at subsequent sessions Fischer So.2d at In at the same time Section was reenacted to expressly provide the three exceptions to grand jury secrecy including furthering justice the Florida legislature also reenacted Fla Stat which concerns the secrecy of statewide grand juries Fla ALS Fla Laws ch Fla SB Fla Stat Like Section Section has a general prohibition on disclosure of grand jury proceedings absent a court order Fla Stat Tellingly however Section does not provide any specific exceptions to nondisclosure Through the intentional omission of these exceptions including the fundamental furthering justice exception it can be understood that the legislature did not intend for court-ordered disclosure of statewide grand jury records to further justice and did not anticipate such disclosures would benefit the public By contrast the legislatures decision to include the catchall furthering justice exception in Section reflects an intent to protect and inform the public the ultimate benefactors of the criminal justice system by providing a means of access in those rare situations where the integrity and legitimacy of the grand jury process have been called into serious question Accordingly implying a private right of action is consistent with the purposes underlying the legislative scheme in Chapter of the Florida Statutes GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE This Court Has Inherent Power to Release Grand Jury Records in Order to Further Justice and Promote Public Confidence in the Judicial Process Even in the absence of Section statutory framework disclosure is appropriate pursuant to this Courts inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency rather than continued secrecy The Grand Jury is Under the Courts Supervision and Jurisdiction It is well-settled that the grand jury is a judicial proceeding in a court of justice an appendage or adjunct to the circuit court In re Grand Jury Investigation So.2d Fla quoting Craft State Fla So Indeed it is the court that gives the grand jury its initial charge and advises the grand jury about its legal duties Fla Stat It has long been understood that ertain implied powers must necessarily result to our Courts of justice from the nature of their institution powers which cannot be dispensed with in a Court because they are necessary to the exercise of all others Chambers NASCO Inc U.S There can be no question of the inherent power of a court to protect itself and hence society as an instrument of justice In re Osborn F.2d 6th Cir Thus in a variety of contexts it has been held that courts have the inherent power to protect the integrity of the judicial process from perversion and abuse Vitakis-Valchine Va/chine So.2d Fla 4th DCA Attwood Singletary So.2d Fla invoking courts inherent authority to prevent interference with orderly process of judicial administration Tramel Bass So.2d Fla 1st DCA invoking courts inherent authority to strike pleadings to sanction fraud perpetrated on the court GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE The Florida Supreme Court has noted that it is of vital importance to maintain the dignity and the integrity of both the grand jury and the presiding judge State Clemmons So.2d Fla In states such as Florida where the grand jury is preserved it is an important appendage of the court which impanels it and it should not be forgotten that the judge of that court is equally important and he is generally charged with the supervision of the grand jurys activities Id The importance of public confidence in the integrity of judges stems from the place of the judiciary in the government Williams-Yulee Fla Bar U.S Courts do not command armies and have no influence over either the sword or the purse Id citing The Federalist No Rossiter ed A Hamilton The judiciarys authority therefore depends in large measure on the publics willingness to respect and follow its decisions Id see also Carlson United States F.3d at recognizing the courts wide discretion to use its inherent power to fashion exceptions pertaining to the release of grand jury records The perception of a viable healthy judiciary is of critical importance to our system of justice U.S.C.C.A.N This perception is of equal importance with respect to state courts which are invested with primary responsibility for overseeing the investigation and prosecution of crimes The Supreme Court of the United States while acknowledging the value in grand Jury secrecy has long authorized the disclosure of grand jury records where the need for transparency outweighs any remaining interest in secrecy Douglas Oil Co of California Petrol Stops Northwest U.S Courts around the country have followed suit See e.g In re Petition of Nat Sec Archive No CIV WL S.D.N.Y Aug release of grand jury records concerning the indictment of Julius and Ethel Rosenberg State Clemons was superseded by statute See Kelly Sturgis So.2d Fla 5th DCA GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE In re Petition of Nat Sec Archive Supp 3d S.D.N.Y same In re Petition of Kut/er Supp 2d D.D.C release of President Nixons grand jury deposition testimony in connection with third Watergate grand jury In re Unseal Dockets Related to the Indep Counsels Investigation of President Clinton Supp 3d D.D.C release of records related to independent counsels investigation of President Clinton In Re Application of the Committee on the Judiciary US House of Representatives For an Order Authorizing the Release of Certain Grand Jury Materials Committee on the Judiciary United States House of Representatives US Department of Justice No D.C Cir March ordering the Trump administration to provide the House Judiciary Committee redacted portions of grand jury materials from former special counsel Robert Muellers probe into Russian election interference More recently Kentuckys Jefferson County Circuit Court released audio of the grand jury proceedings in the Breonna Taylor case in which a young woman was tragically shot by police who were executing a search warrant The grand jury returned only one wanton endangerment charge which did not involve Ms Taylors death against a single police officer Like Florida Kentucky has a rule punishable by contempt of court maintaining the secrecy of grand jury proceedings Kentucky Rules of Criminal Procedure RCr Rule A court has authority to direct disclosure of those proceedings though unlike Section RCr does not enumerate specific reasons allowing the Court to exercise its discretion in ordering disclosure After community outrage over the indictment a member of the grand jury requested the court to release the grand jury transcripts The Jefferson County Circuit Court released redacted audio recordings of the grand jury proceeding and in the interest of public trust and GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE transparency permitted grand jurors who desired to speak out to do so Estate of Jones City of Martinsburg Nos Va LEXIS at Oct citing Commonwealth Hankison No Order of Arraignment and Discovery Ky Jefferson Cir Ct Div entered September Following the courts order authorizing disclosure in the Taylor case grand jurors informed the public that the prosecutor did not present the jury with any options other than first degree wanton endangerment charges One grand juror said the prosecutors did not walk the jury through Kentuckys homicide laws or explain why they decided that two other officers who shot at Breonna Taylor were justified When the panel asked about additional charges prosecutors told them there would not be any because they didnt feel they could make them stick the juror said Estate of Jones Va LEXIS at citing riticizes leb-a258614acf2b906dstory.html In all probability the grand jury transcripts in the Epstein proceedings will similarly reveal what charges were presented how they were presented how questions from grand jurors were handled by the State Attorney the testimony of witnesses and whether the post hoc explanations provided by the State Attorneys Office align with what actually transpired There is no evidence that the disclosures resulting from the above cases have adversely affected the grand jury process On the other hand there is no doubt that the release of these materials has contributed greatly to the historical record and public understanding of significant events in our countrys history as well as exposing failures in our justice system And in the case ofBreonna Taylor as a result of the transparency surrounding the events that led to her GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE death the practice of no knock warrants has largely been condemned and banned throughout the country This Court Has Inherent Power to Release Grand Jury Records in Order to Further Justice and Vindicate Public Confidence in the Judicial Process Courts have identified nine non-exhaustive factors that may be considered in determining whether their inherent authority should be exercised to order the release of grand jury documents These factors include i the identity of the party seeking disclosure ii whether the defendant to the grand jury proceeding or the government opposes the disclosure i why disclosure is being sought in the particular case iv what specific information is being sought for disclosure how long ago the grand jury proceedings took place vi the current status of the principals of the grand jury proceedings and that of their families vii the extent to which the desired material-either permissibly or impermissibly-has been previously made public vi whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive and ix the additional need for maintaining secrecy in the particular case in question Kutler Supp 2d at quoting In re Petition of Craig F.3d The vast majority of these factors support disclosure in this case First the party seeking disclosure does so in furtherance of its First Amendment right to report information informing the public about the operation of the criminal justice system See Va Pharmacy Bd U.S at Pittman F.3d at Richmond Newspapers U.S at the No-knock warrants have been banned in Florida since See State Bamber So.2d Fla While it is largely federal courts that have applied these nine factors there can be no dispute that Florida courts are endowed with inherent authority like their federal counterparts see supra at and federal courts consider these factors when the enumerated exceptions to grand jury secrecy set forth in Federal Rule of Criminal Procedure do not appear to apply See e.g Carlson United States F.3d at 7th Cir As the Supreme Court put it Rule is but declaratory of the long-standing principle that disclosure of grand jury materials is committed to the discretion of the trial court United States John Doe Inc I U.S the Court stressed that wide discretion must be afforded to district court judges in evaluating whether disclosure is appropriate Douglas Oil Co Petrol Stops Northwest U.S We emphasize that a court called upon to determine whether grand jury transcripts should be released necessarily is infused with substantial discretion Thus to the extent the Court does not find that it is authorized by Fla Stat to order disclosure of the Epstein grand jury materials its inherent authority provides substantial id grounds for such disclosure GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE conduct of the criminal trial is pre-eminently a matter of public interest More importantly public access to trials acts as an important check akin in purpose to the other checks and balances that infuse our system of government Globe Newspaper Co Superior Court for Norfolk County U.S the right of access to criminal trials plays a particularly significant role in the functioning of the judicial process and the government as a whole Second the defendant to the grand jury proceeding is deceased and the government has unequivocally stated that is not opposed to the disclosure requested by The Palm Beach Post Third disclosure is being sought-based on information learned by The Palm Beach Post from a series of Florida Public Records Law requests law enforcement sources with direct knowledge of the grand jury evidence and proceedings judicial documents obtained from independent but related court proceedings and documents otherwise available in the public record-to inform the public as to whether the then State Attorney for Palm Beach County presented truncated evidence of Epsteins criminal wrongdoing to the grand jury in a manner that precluded Epsteins indictment for the serious crimes he committed including sex trafficking and sexual assault Fourth the records being sought are the testimony minutes and other evidence presented in to the Palm Beach County grand jury The evidence known to date strongly supports the conclusion that the State Attorney willfully skewed and downplayed his case before the grand jury through a seriously under-charged indictment that ignored the true extent of Epsteins crimes and denigrated his victims as prostitutes unworthy of legal protection Indeed the State Attorney appears to have ignored the evidence of how Epstein had groomed the girls and how he had manipulated them into doing his bidding Plainly Epsteins payments to them were part of his scheme to attack the girls should he be charged with crimes and to convince the State GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE Attorney that he had merely solicited prostitutes who were not true victims The machination of buying their services was also intended to counter the fact that the girls were minors Fifth the grand jury proceedings took place fifteen years ago Sixth the current status of the principals of the grand jury proceedings are unknown Seventh because much of the requested information has now entered the public domain through victims protesting their mistreatment by and misgivings concerning prosecutors both state and federal other lawsuits surrounding Epstein and his co-conspirators and public records requests and extensive news reporting this factor weighs in favor of full disclosure Eighth the status of the witnesses who appeared is unknown indeed The Palm Beach Posts request is made in part to learn who the witnesses were that the State Attorney did decide to call as well as those he decided not to call Finally The Palm Beach Post submits that with the death of the defendant the publicly-known and litigated acts of his co-conspirators the length of time that has passed and the widely reported nature of this miscarriage of justice there is no additional need for maintaining secrecy See US Socony-Vacuum Oil Co U.S After the grand jurys functions are ended disclosure is wholly proper where the ends of justice require it Courts have long realized that a transparent criminal justice system affords significant community therapeutic value Richmond Newspapers U.S at The open processes of justice serve an important prophylactic purpose providing an outlet for community concern hostility and emotion Id at The crucial prophylactic aspects of the With respect to the sixth and eighth factors an in camera review by this Court followed by appropriate redactions would remedy any potential harm to innocent parties GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE administration of justice cannot function in the dark no community catharsis can occur if justice is done in a comer or in any covert manner Id The Palm Beach Post is accordingly entitled to disclosure of the Epstein grand jury materials maintained by the Clerk of Palm Beach County pursuant to this Courts inherent authority and supervisory powers which allow the Court to take appropriate and necessary action to preserve promote and protect the integrity of the justice system The citizens of Palm Beach County and throughout the State of Florida are entitled to nothing less in this case of paramount importance and public interest As a surrogate for the public it serves The Palm Beach Post respectfully requests that the Court declare pursuant to Fla Stat Section that it is entitled to access the testimony minutes and other evidence presented in to the Palm Beach County grand jury because such disclosure would be in the furtherance of justice Fla Stat Because The Palm Beach Post is not seeking these materials in connection with either a civil or criminal case it also seeks a declaration that the scope of its use of the disclosed materials is not so limited See Fla Stat The Palm Beach Post further seeks a declaration that disclosure of the testimony minutes and other evidence presented in to the Palm Beach County grand jury is appropriate pursuant to this Courts inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency IV CONCLUSION The Palm Beach Post respectfully requests that this Court pursuant to Fla Stat Section and the Courts inherent authority order the Clerk of the Court to file with this Court copies of the testimony minutes and other evidence presented in to the Palm Beach GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE County grand jury during the first Epstein sex abuse investigation so that following an in camera inspection it can be made available to The Palm Beach Post and the public on an expedited basis Dated April Respectfully submitted GREENBERG TRAURIG P.A Attorneys for CA Florida Holdings LLC Publisher of The Palm Beach Post Stephen A Mendelsohn Esq East Las Olas Blvd Ste Fort Lauderdale Florida Telephone Facsimile By Isl Stephen A Mendelsohn STEPHEN A MENDELSOHN Florida Bar No mendelsohns gtlaw.com smithl gtlaw.com FLService gtlaw.com By Michael Grygiel MICHAEL GRYGIEL Admitted Pro Hae Vice State St 6th Floor Albany New York Telephone Facsimile grygielm gtlaw.com By Nina Boyaiian NINA BOY AilAN Admitted Pro Hae Vice Century Park East Ste Los Angeles California Telephone Facsimile boyajiann gtlaw.com riveraal gtlaw.com GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this nd day of April 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 Isl Stephen A Mendelsohn STEPHEN A MENDELSOHN GreenbergTraurig P.A East Las Olas Boulevard Suite Ft Lauderdale Florida Tel Fax w.gtlaw.com ACTIVE
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