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CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL 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 fl i his official capacity as his office is in possession and/or control of documents that are the subject I of this action i Defendant Sharon Bock is the duly elected Clerk and Comptroller of Palm Beach County Florida She is sued herein in her official capacity as her office is in possession and/or control of documents that are the subject of this action INTRODUCTION In what is now widely if belatedly recognized as a colossal miscarriage of justice which led to the further needless victimization of countless young girls and women a wealthy politically connected and powerful financier was not held accountable for nor even forced to confront allegations of serious sex trafficking crimes While it is clear that Jeffrey Epstein 2s deal with the State of Florida was not consistent with the evidence gathered against him what remains shrouded in mystery is how that evidence was presented and the extent to which it was presented to the grand jury that returned an indictment far more limited in scope than expected and deserved Through this action The Palm Beach Post seeks 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 investigation 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 Also 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 i CA/Aronbera-0118 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM his official capacity as his office is in possession and/or control of documents that are the subject I I of this action I i Defendant Sharon Bock is the duly elected Clerk and Comptroller of Palm Beach County Florida She is sued herein in her official capacity as her office is in possession and/or control of documents that are the subject of this action INTRODUCTION In what is now widely if belatedly recognized as a colossal miscarriage of justice which led to the further needless victimization of countless young girls and women a wealthy politically connected and powerful financier was not held accountable for nor even forced to confront allegations of serious sex trafficking crimes While it is clear that Jeffrey Epsteins deal with the State of Florida was not consistent with the evidence gathered against him what remains shrouded in mystery is how that evidence was presented and the extent to which it was presented to the grand jury that returned an indictment far more limited in scope than expected and deserved Through this action The Palm Beach Post seeks 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 investigation 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 Also 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 CA/Aronbern.:-0118 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I 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 obstruct the administration of justice at every turn 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 either demonstrated that Epstein was treated like others accused of similar heinous crimes or as appears more likely to be the case those who chose to give Epstein favorable 223unusual in the words of the Town of Palm Beach Police Chief treatment are exposed and held accountable From what limited information is now in the public domain the State Attorney 2s referral of Epstein 2s case to the grand jury which would be out of the ordinary for this type of case gives rise to a strong inference of favoritism and corresponding disregard for the rights of the minor victims of Epstein 2s 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 Epstein 2s 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 have ordered the disclosure of high-profile grand jury proceedings pursuant to their inherent authority where the public 2s interest in those proceedings has outweighed the general need for secrecy This is particularly so where CA/Aronberg-0119 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I To the contrary transparency is required to promote public understanding 6f the criminal justice I system and public confidence in the fair administration of justice As detail 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 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 either demonstrated that Epstein was treated like others accused of similar heinous crimes or as appears more likely to be the case 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 what limited information is now in the public domain the State Attorneys referral of Epsteins case to the grand jury which would be out of the ordinary 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 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 have ordered the disclosure of high-profile grand jury proceedings pursuant to their inherent authority where the publics interest I in those proceedings has outweighed the general need for secrecy This is particularly so where CA/AronbeLc;t-0119 FILb1J PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM as here many of the details of Epstein 2s criminal misdeeds have already 2een made available in I 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 In recognition of the sensitivity of the materials being sought and in the interest of protecting any victims who wish to remain anonymous The Palm Beach Post has no objection to copies of the testimony minutes and other evidence presented in to the Palm Beach County grand jury first being submitted to this Court for in camera review where they may be redacted as appropriate to protect those who deserve such protection FACTUAL BACKGROUND The following facts were gathered in large part from documents obtained by The Palm Beach Post through various Florida Public Records Law requests documents unsealed or publicly available in other related judicial proceedings and information and documents in the public record A First Epstein Sex Crimes Investigation Indictment and Plea Agreement The investigation into Epstein 2s sex crimes began more than fourteen years ago when a 14-year-old girl 2s stepmother reported to police in the Town of Palm Beach Florida that Epstein and others who worked for him arranged for her to give Epstein a 223massage Epstein required the girl to strip exposed himself and masturbated while touching her The girl was paid Epstein was years old at the time Following this initial report in the Town of Palm Beach Police and later in the FBI investigated Epstein Interviews under oath with five additional alleged victims and seventeen witnesses revealed that the events described by the 14-year-old girl occurred with disturbingly similar details with each of the other victims i I BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I as here many of the details of Epsteins criminal misdeeds have already een made available in I 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 In recognition of the sensitivity of the materials being sought and in the interest of protecting any victims who wish to remain anonymous The Palm Beach Post has no objection to copies of the testimony minutes and other evidence presented in to the Palm Beach County grand jury first being submitted to this Court for in camera review where they may be redacted as appropriate to protect those who deserve such protection FACTUAL BACKGROUND I The following facts were gathered in large part from documents obtained by The Palm Beach Post through various Florida Public Records Law requests documents unsealed or publicly available in other related judicial proceedings and information and documents in the public record A First Epstein Sex Crimes Investigation Indictment and Plea Agreement The investigation into Epsteins sex crimes began more than fourteen years ago when a 14-year-old girls stepmother reported to police in the Town of Palm Beach Florida 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 Following this initial report in the Town of Palm Beach Police and later in the FBI investigated Epstein Interviews under oath with five additional alleged victims and I I seventeen witnesses revealed that the events described by the 14-year-old girl occurred with disturbingly similar details with each of the other victims CA/Aropfi:ms L2Ri BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Both the victim/witness interviews as well as evidence-258.5 retrieved following a search of Epstein 2s home showed that some of the girls involved were under theiage of The police search of Epstein 2s 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 In March a State grand jury was scheduled at which all of the victims were expected to testify The proceeding was postponed however due to meetings between the State Attorney 2s office and Epstein 2s prominent criminal defense lawyer and personal friend Alan Dershowitz Another grand jury was convened in April but canceled the day before it was to begin receiving evidence Police Chief Reiter 2s Letter to the State Attorney On May Town of Palm Beach Police Chief Michael Reiter wrote a 223personal and confidential letter to then Palm Beach County State Attorney Barry Krischer stating I must renew my prior observation to you that I continue to find your office 2s 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 been unanswered and messages remain unreturned After giving this much thought and consideration I must urge you to examine the unusual course that your office 2s handling of this matter has taken and consider ifgood and sufficient reason exists to require your disqualification from the prosecution of these cases Emphasis supplied Chief Reiter 2s letter to State Attorney Krischer enclosed the Town of Palm Beach Police Department 2s probable cause affidavits charging Epstein and two of his assistants with i multiple counts of unlawful sex acts with a minor and one count of sexual abuse and requested CA/Aronberg-0121 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I Both the victim/witness inteIViews as well as evidence retrietd following a search I of Epsteins home showed that some of the girls involved were under thelage of 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 inteIViewed in the course of their investigation In March a State grand jury was scheduled at which all of the victims were expected to testify The proceeding was postponed however due to meetihgs between the State Attorneys office and Epsteins prominent criminal defense lawyer and personal friend Alan Dershowitz Another grand jury was convened in April but canceled the day before it was to begin receiving evidence Police Chief Reiters Letter to the State Attorney On May Town of Palm Beach Police Chief Michael Reiter wrote a personal and confidential letter to then Palm Beach County State Attorney Barry Krischer stating I must renew my prior obseIVation 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 nmst 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 disquali_ficationfrom the prosecution of these cases Emphasis supplied Chief Reiter letter to State Attorney Krischer enclosed the Town of Palm Beach Police Departments probable cause affidavits charging Epstein and two of his assistants with I multiple counts of unlawful sex acts with a minor and one count of sexual abuse and requested CA/AronbeLQ-0121 FILEU PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges I against him which would be public The July State Grand Jury Presentation 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 According to an official spokesperson this was the first time that a sex crimes case was presented to a grand jury in Palm Beach County In July after State Attorney Krischer presented testimony and evidence from one 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 On information and belief a second of Epstein 2s victims was supposed to testify before the grand jury but was unable to attend because of a school exam No reasonable explanation has been provided as to why the numerous other known victims were not presented as witnesses and crime victims to the grand jury convened in July Nor has any reasonable explanation been provided as to why State Attorney Krischer who was initially eager to investigate and prosecute Epstein for his crimes over time lost the desire to do so On information and belief 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 unrelated to the charges against Epstein Further upon information and belief this information was initially brought to the attention of the State Attorney 2s office by Epstein 2s defense counsel I CA/Aronbera-0122 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I I that either an arrest warrant be issued for Epstein or the State Attorney direc ly initiate the charges I I against him which would be public The July State Grand Jury Presentation 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 According to an official spokesperson this was the first time that a sex crimes case was presented to a grand jury in Palm Beach County In July after State Attorney Krischer presented testimony and evidence from one 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 On information and belief a second of Epsteins victims was supposed to testify before the grand jury but was unable to attend because of a school exam No reasonable explanation has been provided as to why the numerous other known victims were not presented as witnesses and crime victims to the grand jury convened in July Nor has any reasonable explanation been provided as to why State Attorney Krischer who was initially eager to investigate and prosecute Epstein for his crimes over time lost the desire to do SO On information and belief 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 unrelated to the charges against Epstein Further upon information and belief this information was initially brought to the attention of the State Attorneys office by Epsteins defense counsel CA/Aronbern __ FILEU PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I The FBI 2s Investigation and Epstein 2s Non-Prosecution Agreement With Federal Authorities On information and belief following the deficient July indictment and with Chief Reiter 2s encouragement the FBI began its own investigation of Epstein Records unsealed in revealed that the FBI compiled reports on confirmed minors that were victims of Epstein 2s sexual predations Based on evidence gathered by the FBI a 53-page indictment was prepared by the U.S Attorney 2s Office in June However at the request of Epstein 2s lawyers the indictment was never presented to a federal grand jury Instead then U.S Attorney for the Southern District of Florida Alexander Acosta negotiated a plea deal with Epstein 2s team of lawyers to grant immunity to Epstein along with four named co-conspirators and any unnamed potential co-conspirators from all federal criminal charges Throughout the remainder of and through the first half of Epstein 2s lawyers and the U.S Attorney continued negotiating the plea arrangement Upon information and belief Epstein 2s 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 Epstein 2s computers be withdrawn On June Epstein pled guilty to 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 The plea deal called a non-prosecution agreement 223NPA allowed Epstein to receive immunity from federal sex-trafficking charges that could have sent him to prison for life CA/Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I The FBls Investigation and Epsteins Non-Prosecution Agreement With Federal Authorities On information and belief following the deficient July indictment and with Chief Reiters encouragement the FBI began its own investigation of Epstein 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 feder grand jury Instead then U.S Attorney for the Southern District of Florida Alexander Acosta negotiated a plea deal with Epsteins team of lawyers to grant immunity to Epstein along with four named co-conspirators and any unnamed potential co-conspirators from all federal criminal charges Throughout the remainder of and through the first half of Epsteins lawyers and the U.S Attorney continued negotiating the plea arrangement Upon information and belief 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 On June Epstein pied guilty to 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 contr or house arrest and was adjudicated as a convicted sex offender required to register twice a year in Florida The plea deal called a non-prosecution agreement NPA allowed Epstein to receive immunity from federal sex-trafficking charges that could have sent him to prison for life CA/AronbeLQ:-0123 FILblJ PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM On information and belief based on public records former State Attorney Krischer communicated with then U.S Attorney Acosta concerning the NPA 2s negotiation with Epstein 2s lawyers Indeed 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 223work release for up to hours a day days a week His private driver provided his transportation to and from 223work Epstein was released five months early Upon information and belief Epstein violated the terms of his probation but was not prosecuted The Crime Victims Rights Act Litigation Epstein 2s 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 223CVRA 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 Kenneth A Marra recently ruled that federal prosecutors violated the CVRA by failing to notify Epstein 2s victims before allowing him to plead guilty to only the two State offenses The prosecution 2s failure to keep the victims apprised among other things also contravenes the Florida Constitution Article and Fla Stat Following publicity exposing the extraordinary leniency of the plea deal dozens of civil suits were brought against Epstein most of which Epstein 2s lawyers settled out-of-court In Epstein was registered as a 223level three i.e high risk of repeat offense sex offender in New York a lifelong designation In the New York County District Attorney 2s office unsuccessfully sought to lower his registration to low-rislt 223level one I I CA/Aronbera-0124 I On infonnation and belief based on public records fonner State Attorney jrischer communicated I with then U.S Attorney Acosta concerning the NPAs negotiation with Epsteins lawyers I I Indeed Epstein was not incarcerated in a Florida prison fdr the State crimes for which he was convicted Instead he was placed in a private wing of the Palm Beach County Stockade where after lJ2 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 Epstein was released five months early Upon information and belief Epstein violated the terms of his probation but was not prosecuted The Crime Victims Rights Act Litigation 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 Kenneth A Marra recently ruled that federal prosecutors violated the CVRA by failing to notify Epsteins victims before allowing him to plead guilty to only the two State offenses The prosecutions failure to keep the victims apprised among other things also contravenes the Florida Constitution Article and Fla Stat Following publicity exposing the extraordinary leniency of the plea deal 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 of repeat offense sex offender in New York a lifelong designation In the New ork County District Attorneys office unsuccessfully sought to lower his registration to low-ris level one CA/AronbeN-0124 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I i i Upon information and belief during the course of the Town of Palm Beach and FBI i 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 Upon information and belief Epstein 2s victims were threatened against cooperating with law enforcement and told that they would be compensated only if they did not cooperate with law enforcement Second Epstein Sex Crimes Investigation Indictment Suicide On July Epstein was arrested on federal sex trafficking charges Upon information and belief the United States government 2s 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 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 serial sexual predator who preyed on dozens of minor girls over a period of years The letter emphasized that 223the 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 FBI 2s search of Epstein 2s Manhattan townhouse evidence of sex trafficking in the form of 223hundreds 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 223Young Name Name 223Mise nudes and 223Girl pics nude CA/Aronberg-0125 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I Upon information and belief during the course of the Town Jf Palm Beach and FBI I I 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 dete tive who investigated the case against Epstein Upon information and belief 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 Second Epstein Sex Crimes Investigation Indictment Suicide On July Epstein was arrested on federal sex trafficking charges Upon information and belief 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 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 CA/Aronbel9.:-0125 FILb1J PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM On July prosecutors with the Public Corruption Unit of the U.S Attorney 2s I I 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 223dozens of underage girls were brought into Epstein 2s mansions for sexual encounters A few days later owing to public outcry over the NPA with Epstein entered into by the U.S Attorney for the Southern District of Florida Alexander Acosta who by then was serving as U.S Secretary of Labor in the Trump administration resigned from office Epstein was denied bail and was placed into pretrial detention at the federal Metropolitan Correction Center in lower Manhattan 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 On August Epstein was found dead in his cell at the Metropolitan Correctional Center His cause of death was determined to be suicide The August SDNY Hearing Epstein 2s 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 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 I I i CA/Aronberg-0126 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM On July prosecutors with the Public Corruption Unit,ofthe U.S Attorneys I I 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 the U.S Attorney for the Southern District of Florida Alexander Acosta who by then was serving as U.S Secretary of Labor in the Trump administration resigned from office Epstein was denied bail and was placed into pretrial detention at the federal Metropolitan Correction Center in lower Manhattan 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 On August Epstein was found dead in his cell at the Metropolitan Correctional Center His cause of death was determined to be suicide 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 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 Sev;eral victims spoke of violent rape by Epstein Many more victims were present in the courtroom but did not testify CA Aronbem-0126 FILEU PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM While some questioned the reasoning behind the court 2s decision to give the victims voice after Epstein 2s death District Judge Berman noted that public hearing is the preferred vehicle of resolution emphasizing that 223public hearings are exactly what judges do Hearings I promote transparency and they provide the court with insights and information which the court may not otherwise be aware of Indeed even Epstein 2s defense lawyer noted at the hearing that the court the institution that most people have confidence in in these very troubled times At the August 27th hearing the girls now women spoke about their 223exploitation and coercion and to the fact that many of them 223were in very vulnerable situations and in extreme poverty circumstances where they didn 2t have anyone on their side to speak on their behalf.One victim lamented that 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 223completely different the investigators leading to 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 A former federal judge in attendance at the August 27th hearing emphasized that 223transparency is one of the overriding objectives in our criminal justice system Nearly all of the victims expressed the conviction that the secrecy that shielded Epstein has caused them 223irreparable 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 223Any efforts made to protect Epstein 2s 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 223where:there are predators in power a world where people can avoid justice if their pockets run deep enough In short the I I I i CA/Aronberg-0127 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM While some questioned the reasoning behind the courts decision to give the victims I I voice after Epsteins death District Judge Berman noted that a public hearing is the preferred I vehicle of resolution emphasizing that public hearings are exactly wh 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 At the August 27th hearing the girls now 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 leading to 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 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 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 I power a world where people can avoid justice if their pockets run deep enough In short the I I CA/Aronberg-0127 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 223unusual treatment Epstein received in Florida in based on his wealth social status and connections severely eroded the public 2s faith in the integrity and impartiality of the criminal justice system The Palm Beach Posts Standing and the Public Interest The Palm Beach Post Has Reported Extensively On Epstein 2s Crimes For Nearly Years 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 The Newspaper 2s reportage has included publication of the following articles 223The Man Who Had Everything Jeffrey Epstein Craved Big Homes Elite Friends and Investigators Say Underage Girls published on August reporting that Haley Robson a local community college student admitted in a sworn statement to police that 223she had taken at least six girls to visit Epstein all between the ages of and Palm Beach Police 223interviewed five alleged victims and witnesses 223Dershowitz the Harvard law professor traveled to West Palm Beach with information about the girls including social media discussions about 223their use of alcohol and marijuana after meeting with Epstein 2s legal team 223prosecutors postponed their decision to take the case to a grand jury Palm Beach Police subsequently 223received complaints that two of the victims or their families had been harassed or threatened 223relations between police and prosecutors were fraying as the investigation continued and 223one girl who was subpoenaed the one who said she had sexual intercourse with Epstein never showed up to testify before the grand jury 223Trump Snags Gosman Estate for Million published on November reporting on the bidding war between Donald Trump and Jeffrey Epstein for the purchase of a seven-bedroom estate on oceanfront acres along the storied 221Raider 2s Row in Palm Beach CA/Aronbera-0128 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I i unusual treatment Epstein received in Florida in based on his weJlth social status and I connections severely eroded the publics faith in the integrity and imparJ:iality of the criminal justice system The Palm Beach Posts Standing and the Public Interest The Palm Beach Post Has Reported Extensively On Epsteins Crimes For Nearly Years 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 The Newspapers reportage has included publication of the following articles The Man Who Had Everything Jeffrey Epstein Craved Big Homes Elite Friends and Investigators Say Underage Girls published on August reporting that Haley Robson a local community college student admitted in a sworn statement to police that she had taken at least six girls to visit Epstein all between the ages of and Palm Beach Police interviewed five alleged victims and witnesses Dershowitz the Harvard law professor traveled to West Palm Beach with information about the girls including social media discussions about their use of alcohol and marijuana after meeting with Epsteins legal team prosecutors postponed their decision to take the case to a grand jury Palm Beach Police subsequently received complaints that two of the victims or their families had been harassed or threatened relations between police and prosecutors were fraying as the investigation continued and one girl who was subpoenaed the one who said she had sexual intercourse with Epstein never showed up to testify before the grand jury Trump Snags Gosman Estate for Million published on November reporting on the bidding war between Donald Trump and Jeffrey Epstein for the purchase of a 43,0-square-foot seven-bedroom estate on oceanfront acres along the storied Raiders Row in Palm Beach CA/Aronbem:-0128 FILEU PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 223Indictment Billionaire Solicited Times published on July reporting that 223Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein solicited or procured prostitutes three or more times between Aug and Oct of last year according to an indictment charging him with felony solicitation of prostitution The article further reported that 223Epstein 2s case is unusual in that suspected prostitution Johns are usually charged with a misdemeanor and even a felony charge is typically made in a criminal information an alternative to an indictment charging a person with the commission of a crime 223After Long Probe Billionaire Faces Solicitation Charge published on July reporting that 223Palm Beach police thought there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation The article further reported that 223Police Chief Michael Reiter was so angry with State Attorney Barry Krischer 2s handling of the case that he wrote a memo suggesting the county 2s top prosecutor disqualify himself and identified a 20-year-old on-the-record female source who said 223she gave Epstein a massage in the nude then brought him six girls ages to for massage and sex-tinged sessions at his home 223Police Say Lawyer Tried to Discredit Teenage Girls published on July reporting that 223fjamed Harvard law professor Alan Dershowitz met with the Palm Beach County State Attorney 2s Office and provided damaging information about teenage girls who say they gave his client Palm Beach billionaire Jeffrey Epstein sexually charged massages and that 223the state attorney 2s office said it presented the Epstein case to a county grand jury this month rather than directly charging Epstein because of concerns about the girls credibility 223Expert Ignorance of Age Isn 2t Defense In Sex Cases published on August reporting that 223rather than file charges the state attorney 2s office presented the case to a county grand jury which 223indicted Epstein last week on a single less serious charge of felony solicitation of prostitution and that 223the case raised eyebrows because the state attorney 2s office rarely if ever kicks such charges to a grand jury 223Epstein Camp Calls Female Accusers Liars published on August reporting that state attorney 2s spokesman would say only that the office refers cases to the grand jury when there are issues with the viability of the evidence or witnesses credibility 223Palm Beach Chief Focus of Fire In Epstein Case published on August reporting that Chief Reiter 223pressed for Epstein to be charged with the more serious crimes of sexual activity with minors and 223slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that office 2s mishandling of the case 223Delays In Epstein Case Unusual Lawyers Say published on March reporting that 223nearly eight months after Palm Beach tycoon Jeffrey Epstein was charged with felony solicitation of prostitution there has been no discernible progress in his case i i CA/Aron Indictment Billionaire Solicited Times published on July 2ji reporting that I Billionaire money manager and Palm Beach part-time res dent Jeffrey Epstein solicited or procured prostitutes three or more times between Aug and Oct oflast year according to an indictment charging him with felony solicitation of prostitution The article further reported that Epsteins case is unusual in that suspected prostitution johns are usually charged with a misdemeanor and even a felony charge is typically made in a criminal information an alternative to an indictment charging a person with the commission of a crime After Long Probe Billionaire Faces Solicitation Charge published on July reporting that Palm Beach police thought there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation The article further reported that Police Chief Michael Reiter was so angry with State Attorney Barry Krischers handling of the case that he wrote a memo suggesting the countys top prosecutor disqualify himself and identified a 20-year-old on-the-record female source who said she gave Epstein a massage in the nude then brought him six girls ages to for massage and sex-tinged sessions at his home Police Say Lawyer Tried to Discredit Teenage Girls published on July reporting that famed Harvard law professor Alan Dershowitz met with the Palm Beach County State Attorneys Office and provided damaging information about teenage girls who say they gave his client Palm Beach billionaire Jeffrey Epstein sexually charged massages and that the state attorneys office said it presented the Epstein case to a county grand jury this month rather than directly charging Epstein because of concerns about the girls credibility Expert Ignorance of Age Isnt Defense In Sex Cases published on August reporting that rather than file charges the state attorneys office presented the case to a county grand jury which indicted Epstein last week on a single less serious charge of felony solicitation of prostitution and that the case raised eyebrows because the state attorneys office rarely if ever kicks such charges to a grand jury Epstein Camp Calls Female Accusers Liars published on August reporting that a state attorneys spokesman would say only that the office refers cases to the grand jury when there are issues with the viability of the evidence or witnesses credibility Palm Beach Chief Focus of Fire 1n Epstein Case published on August reporting that Chief Reiter pressed for Epstein to be charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling of the case Delays In Epstein Case Unusual Lawyers Say published on March reporting that nearly eight months after Palm Beach tycoon Jeffrey Epstein was charged with felony solicitation of prostitution there has been no discernible progress in his case CA/AronbeLQ-0129 FILEU PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 223Woman Sues Billionaire Investor Says They Had Sex When She Was published on October reporting on a lawsuit brought in New York State court against Epstein a young woman who says he had sex with her when she was and had sought his help becoming a model 223Palm Beacher Pleads In Sex Case published on July reporting that 223Epstein pleaded guilty to felony solicitation of prostitution and procuring a person under the age of for prostitution resulting in lifelong obligation to register as a sex offender and that part of the plea deal federal investigators agreed to drop their investigation of Epstein which they had taken to a grand jury 223Jeffrey Epstein Scientist Stuntman 221Sex Slave Visit Jailed Tycoon published on August reporting that 223during his first month of confinement Epstein was visited by Sarah Kellen who allegedly escorted victims 223upon their arrival at his Palm Beach waterfront home to an upstairs room where she prepared the massage table and provided the oils for their encounters with Epstein and by Nadia Marcinkova young woman whom Epstein purportedly described as his Yugoslavian sex slave 223Billionaire Sex Offender Leaves Jail Six Days a Week For Work published on July reporting that Epstein allowed to leave the Palm Beach County Stockade six days a week on a work-release program 223Women Want Epstein Sex Plea Deal Unsealed published on June reporting that attorneys for women suing Epstein in various courts 223want his non-prosecution agreement NPA with federal prosecutors unsealed and were moving to unseal the agreement in Circuit Court of the Fifteenth Judicial Circuit and that 223Epstein now faces at least a dozen civil lawsuits in federal and courts filed by young women who said they had sex with him and now are seeking damages On that date The Palm Beach Post moved to intervene in the matter for the purpose of obtaining public access to the NPA which was ordered disclosed by this Court on June 223Epstein 2s Secret Pact With Feds Reveals 221Highly Unusual Terms published on September reporting that owing to Epstein 2s non-prosecution agreement 223federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein pleaded guilty to felonies in state court and 223also agreed not to charge any of Epstein 2s possible co-conspirators Sarah Kellen Adriana Ross Lesley Groff and Nadia Marcinkova The article further reported that according to an attorney representing three of Epstein 2s victims 223none of the to women identified as victims in the federal investigation were informed ahead of time about the NPA 223Judge Rules Epstein Attorneys Can Subpoena Abortion Records published on January reporting that judge gave lawyers representing multi millionaire sex offender Jeffrey Epstein the right to subpoena abortion records from women who are seeking millions in damages from the part-time Palm Beach resident CA/Aronbera-0130 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Woman Sues Billionaire Investor Says They Had Sex When She Was published I on October reporting on a lawsuit brought in New Y9rk State court against Epstein by a young woman who says he had sex with her when she was and had sought his help becoming a model Palm Beacher Pleads In Sex Case published on July reporting that Epstein pleaded guilty to felony solicitation of prostitution and procuring a person under the age of for prostitution resulting in a lifelong obligation to register as a sex offender and that as part of the plea deal federal investigators agreed to drop their investigation of Epstein which they had taken to a grand jury Jeffrey Epstein Scientist Stuntman Sex Slave Visit Jailed Tycoon published on August reporting that during his first month of confinement Epstein was visited by Sarah Kellen who allegedly escorted victims upon their arrival at his Palm Beach waterfront home to an upstairs room where she prepared the massage table and provided the oils for their encounters with Epstein and by Nadia Marcinkova a young woman whom Epstein purportedly described as his Yugoslavian sex slave Billionaire Sex Offender Leaves Jail Six Days a Week For Work published on July reporting that Epstein is allowed to leave the Palm Beach County Stockade six days a week on a work-release program Women Want Epstein Sex Plea Deal Unsealed published on June reporting that attorneys for women suing Epstein in various courts want his non-prosecution agreement NPA with federal prosecutors unsealed and were moving to unseal the agreement in Circuit Court of the Fifteenth Judicial Circuit and that Epstein now faces at least a dozen civil lawsuits in federal and state courts filed by young women who said they had sex with him and now are seeking damages On that date The Palm Beach Post moved to intervene in the matter for the purpose of obtaining public access to the NPA which was ordered disclosed by this Court on June Epsteins Secret Pact With Feds Reveals Highly Unusual Terms published on September reporting that owing to Epsteins non-prosecution agreement federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein pleaded guilty to prostitution-related felonies in state court and also agreed not to charge any of Epsteins possible co-conspirators Sarah Kellen Adriana Ross Lesley Groff and Nadia Marcinkova The article further reported that according to an attorney representing three of Epsteins victims none of the to women identified as victims in the federal investigation were informed ahead of time about the NPA Judge Rules Epstein Attorneys Can Subpoena Abortion Records published on January reporting that a judge gave lawye;s representing multi millionaire sex offender Jeffrey Epstein the right to subpoena abortion records from women who are seeking millions in damages from the part-time Palm Beach resident CA/AronbeN-0130 223Epstein Journal 2s Findings Could Resurrect Abuse Case published on March reporting that purloined journal that is said to contain the names of 221hundreds of victims of convicted sex offender Jeffrey Epstein could be used to reopen the investigation into the multi-millionaire 2s appetite for teenage girls 223Epstein Paid Three Women Million to End Underage Sex Lawsuits published on October reporting that according to court documents Epstein 223shelled out million to settle lawsuits with three of more than two dozen teens who sued him 223Judge Rules Feds Agreement With Jeffrey Epstein Pact Violated Teen Victims Rights published on February reporting on a ruling by U.S District Judge Kenneth Marra that 223Federal prosecutors violated the rights of Jeffrey Epstein 2s teenage victims under the Crime Victims Rights Act by failing to reveal they had dropped plans to prosecute the billionaire on dozens of federal charges in connection with the girls claims that he paid them for sex at his Palm Beach mansion 223Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex Trafficking Conspiracy Charges In Federal Court In Manhattan published on July reporting on Epstein 2s appearance in U.S District Court for the Southern District of New York in which he 223pleaded not guilty to charges accusing him of creating a vast network of girls as young as that he exploited for his sexual pleasure at his homes in Palm Beach and Manhattan A true and correct copy of the above news articles in either the computerized format in which they are maintained in The Palm Beach Posts electronic archives or the news print edition in which originally published is annexed hereto as Exhibit Since the filing of the initial Complaint in this matter The Palm Beach Post along with media worldwide has continued to report on Epstein 2s crimes and the ongoing official proceedings resulting from those crimes The Palm Beach Posts Standing and the Public Interest The press has a constitutional right of access to criminal proceedings see e.g Richmond Newspapers Inc Virginia U.S including pre-trial criminal proceedings Newman Graddick F.2d 11th Cir Indeed 223the integrity of the I 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 Pnbl I CA/Aronberg-0131 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Epstein Journals Findings Could Resurrect Abuse Case published on March I reporting that a purloined journal that is said to contain the names of I hundreds of victims of convicted sex offender Jeffrey Epstein could be used to reopen I the investigation into the multi-millionaires appetite for teenage girls Epstein Paid Three Women Million to End Underage Sex Lawsuits published on October reporting that according to court documents Epstein shelled out million to settle lawsuits with three of more than two dozen teens who sued him Judge Rules Feds Agreement With Jeffrey Epstein Pact Violated Teen Victims Rights published on February reporting on a ruling by U.S District Judge Kenneth Marra that Federal prosecutors violated the rights of Jeffrey Epsteins teenage victims under the Crime Victims Rights Act by failing to reveal they had dropped plans to prosecute the billionaire on dozens of federal charges in connection with the girls claims that he paid them for sex at his Palm Beach mansion Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex Trafficking Conspiracy Charges In Federal Court In Manhattan published on July reporting on Epsteins appearance in U.S District Court for the Southern District of New York in which he pleaded not guilty to charges accusing him of creating a vast network of girls as young as that he exploited for his sexual pleasure at his homes in Palm Beach and Manhattan A true and correct copy of the above news articles in either the computerized format in which they are maintained in The Palm Beach Posts electronic archives or the news print edition in which originally published is annexed hereto as Exhibit 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 The Palm Beach Posts Standing and the Public Interest The press has a constitutional right of access to criminal proceedings see e.g Richmond Newspapers Inc Virginia U.S including pre-trial criminal proceedings Newman Graddick F.2d 11th Cir Indeeq the integrity of the I I judicial process which public scrutiny is supposed to safeguard is just as much at issue in i proceedings of this kind pre and post-trial as at trial Id at see also Miami Herald Pub CA/Aronbe_r:g__-0131 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Co Lewis So 2d Fla identifying the news media as a 223public 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 Pharmacy Bd Va Consumer Council U.S 223Where 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 223The Supreme Court has recognized that the First Amendment offers protection to both speakers and those wishing to receive speech see also Stephens Cty of Albemarle Va F.3d 4th Cir providing that a plaintiff has 223standing to assert a right to receive speech by 223showing that there exists a speaker willing to convey the information to her Because of the unique role performed by the press as a 223public surrogate Lewis So 2d at in protecting the right of access and its interest in reporting information about criminal proceedings news organizations 223presumptively have a right to access judicial records Comm 2r Ala Dep 2t of Corr Advance Local Media LLC F.3d 11th Cir and 223standing 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 a member of the public the Reporters Committee has standing to assert its claim to grand jury materials because such materials are 223public records to which the public may seek access even if that effort is ultimately unsuccessful Here the continued denial of access to information The Palm Beach Post seeks on behalf of its journalists and the public it serves 223unquestionably constitutes irreparable injury Gainesville Woman Care LLC State of Florida So 3d Fla see also Zerilli Smith F.2d D.C Cir noting that 223the press function as a vital CA/Aronberg-0132 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I Co Lew;s So 2d Fla identifying the news media as public surrogate in I I matters concerning the closure of judicial proceedings The press also a First Amendment interest in receiving information from willing speakers See Va Phmwacy Bd Va Consumer Council U.S I 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 Cty 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 Here the continued denial of access to information The Palm Beach Post seeks on behalf of its journalists and the public it serves 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 pre function as a vital CA/Aronberg-0132 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM source of information is weakened whenever the ability of journalists to gather information is impaired as it is by Attorney General 2s refusal to disclose unredacted report and underlying grand jury materials I 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 Fla Stat It is further express 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 intended for recourse to the courts in considering and determining the propriety and scope of grand jury secrecy The Court 2s Jurisdiction And Authority The Court 2s Supervision of the Grand Jury Process and Its Authority to Order Public Disclosure of the Epstein Evidence The Florida Supreme Court has noted that states such as Florida where the grand jury is preserved it is an important appendage of the court which impanels it At the same time 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 jury 2s activities It is therefore of vital importance to maintain the dignity and the integrity of both the grand jury and the presiding judge State Clemons So 2d Fla Chapter of the Florida Statutes governs the empanelment and conduct of Florida grand juries The court gives the grand jury its initial charge and advises the grand jury about its legal duties Fla Stat Florida Stat Section provides that 223the testimony of a witness examined before the grand jury or other evidence received by it may be disclosed 223when required by a CA/Aronbera-0133 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM source of information is weakened whenever the ability of journalists to gather information is impaired as it is by Attorney Generals refusal to disclose unredacted report and underlying grand jury materials I I 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 Fla Stat It is further express 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 intended for recourse to the courts in considering and determining the propriety and scope of grand jury secrecy The Courts Jurisdiction And Authority The Courts Supervision of the Grand Jury Process and Its Authority to Order Public Disclosure of the Epstein Evidence The Florida Supreme Court has noted that in states such as Florida where the grand jury is preserved it is an important appendage of the court which impanels it At the same time 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 It is therefore of vital importance to maintain the dignity and the integrity of both the grand jury and the presiding judge State Clemons So 2d Fla Chapter of the Florida Statutes governs the empanelment and conduct of Florida grand juries The court gives the grand jury its initial charge and advises the grand jury about its legal duties Fla Stat Florida Stat Section provides that the testimony of a witness examined I I before the grand jury or other evidence received by it may be disclosed when required by a I CA/Aronbern..:-0133 FILE PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I 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 peijury or I Furthering justice Fla Stat a Further disclosure is appropriate pursuant to this Court 2s inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency Carlson United States F.3d at district court has the inherent power to disclose grand jury materials in exceptional circumstances and historic importance can be a sufficient reason when there is little countervailing need for secrecy The Florida Supreme Court has confirmed that grand jury secrecy is not absolute and that any 223potential harm to public officeholders from disclosure 223will be the product of their own conduct and not the consequence of an unrestrained body of misguided citizens Miami Herald Pub Co Marko So 2d 223The 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 While public disclosure of grand jury findings inevitably entails the risk of reputational damage the legislature has ensured that any potential harm to public officeholders will be the product of their own conduct and not the consequence of an unrestrained body of misguided citizens The Court 2s Jurisdiction To Declare Rights And Construe Statutes This Court has jurisdiction to declare rights status and other equitable or legal relations whether or not further relief is or could be claimed Florida Stat Section I CA/Aro BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM court for the purpose of a Ascertaining whether it is consistent with the testimony given by I the witness before the court Determining whether the witness is guilty of perjury or I I Furtheringjustice Fla Stat a Further 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 Carlson United States F.3d at a district court has the inherent power to disclose grand jury materials in exceptional circumstances and historic importance can be a sufficient reason when there is little countervailing need for secrecy The Florida Supreme Court has confirmed that grand jury secrecy is not absolute and that any potential harm to public officeholders from disclosure will be the product of their own conduct and not the consequence of an unrestrained body of misguided citizens Miami Herald Pub Co Marko So 2d 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 While public disclosure of grand jury findings inevitably entails the risk of reputational damage the legislature has ensured that any potential harm to public officeholders will be the product of their own conduct and not the consequence of an unrestrained body of misguided citizens The Courts Jurisdiction To Declare Rights And Construe Statutes This Court has jurisdiction to declare rights status and other equitable or legal relations whether or not further relief is or could be claimed Florida Stat Section I CA Aron FlLhD PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Florida law specifically provides that a declaration may be sought from the Court concerning a petitioner 2s rights under a statute Florida Stat Section 223Any person whose rights status or other equitable or legal relations are affected by a statute dr any regulation made i under statutory authority may have determined any question of construction or validity arising under such statute or any part thereof and obtain a declaration of rights status or other equitable or legal relations thereunder The Court 2s exercise of its power to declare rights to be liberally administered and construed Florida Stat Section COUNT I Declaratory Relief Florida Stat Sections el seq The allegations set forth in paragraphs through are incorporated by reference as if fully set forth herein This is an action for Declaratory Relief pursuant to Chapter Florida Statutes and other supplemental relief The Palm Beach Post respectfully requests that the Court declare that pursuant to Fla Stat Section it is entitled access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury because such disclosure and access 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 seeks a declaration that the scope of its use of the disclosed materials is not 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 i CA/Aronberg-0135 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Florida law specifically provides that a declaration may be sought from the Court concerning a petitioners rights under a statute Florida Stat Section Any person whose I rights status or other equitable or legal relations are affected by a statute or any regulation made i under statutory authority may have determined any question of construction or validity arising under such statute or any part thereof and obtain a declaration of rights status or other equitable or legal relations thereunder The Courts exercise of its power to declare rights is to be liberally administered and construed Florida Stat Section COUNTI Declaratory Relief Florida Stat Sections et seq The allegations set forth in paragraphs through are incorporated by reference as if fully set forth herein This is an action for Declaratory Relief pursuant to Chapter Florida Statutes and other supplemental relief The Palm Beach Post respectfully requests that the Court declare that pursuant to Fla Stat Section it is entitled access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury because such disclosure and access 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 seeks a declaration that the scope of its use of the disclosed materials is not 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 CA Aronbe FILb1J PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM pursuant to this Court 2s inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency I The Palm Beach Post has sought from Defendants but Defendants have refused to i provide access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury Indeed Defendants have each filed motions to dismiss the Complaint and the relief it sought under Fla Stat Section Accordingly a good-faith dispute exists between the parties Through this Complaint The Palm Beach Post presently has a justiciable question concerning its rights to obtain the grand jury materials pursuant to Fla Stat Section and the Court 2s inherent authority A bona fide actual present and practical need for the declaration exists in that Defendants have denied to The Palm Beach Post and to the public at large the grand jury materials sought to be disclosed The relief sought from the Court is therefore not merely the giving of legal advice or to answer hypothetical questions WHEREFORE The Palm Beach Post respectfully requests that the Court determine the rights and obligations of the parties by declaring that pursuant to Fla Stat Section and the Court 2s inherent authority The Palm Beach Post may gain access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury and use those materials for the purpose of informing the public COUNT Florida Stat Section The allegations set forth in paragraphs through are incorporated by reference as if fully set forth herein CA/Aronberg-0136 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM pursuant to this Courts inherent authority over grand jury proceedings because of the exceptional I public interest in this case and the compelling circumstances supporting trahsparency I T71e Palm Beach Post has sought from Defendants but Defe dants have refused to i provide access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury Indeed Defendants have each filed motions to dismiss the Complaint and the relief it sought under Fla Stat Section Accordingly a good-faith dispute exists between the parties Through this Complaint The Palm Beach Post presently has a justiciable question concerning its rights to obtain the grand jury materials pursuant to Fla Stat Section and the Courts inherent authority A bona fide actual present and practical need for the declaration exists in that Defendants have denied to The Palm Beach Post and to the public at large the grand jury materials sought to be disclosed The relief sought from the Court is therefore not merely the giving of legal advice or to answer hypothetical questions WHEREFORE The Palm Beach Post respectfully requests that the Court determine the rights and obligations of the parties by declaring that pursuant to Fla Stat Section and the Courts inherent authority The Palm Beach Post may gain access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury and use those materials for the purpose of informing the public COUNT II Florida Stat Section The allegations set forth in paragraphs through are incorporated by reference as if fully set forth herein CA/Aronbe_rn-0136 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Based on information learned by The Palm Beach Post through its 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 the State Attorney for Palm Beach County presented truncated evidence of Epstein 2s criminal wrongdoing to the grand jury in a manner that precluded his indictment for the serious crimes he committed including sex trafficking and sexual assault Pursuant to Florida Stat Section in order to further justice for Epstein 2s victims and the public and to provide public disclosure to illuminate whether Epstein received unreasonably lenient treatment based on the available evidence The Palm Beach Post requests immediate access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury In a case of this magnitude and importance where the accused is dead and so many of his crimes as well as the identities and crimes of his co-conspirators and the identities of the victims have already been exposed the need for grand jury secrecy is no more See United States Socony-Vacuum Oil Co U.S 223After the grand jury 2s functions are ended disclosure is wholly proper where ends of justice require it WHEREFORE The Palm Beach Post respectfully requests that this Court pursuant to Fla Stat Section and the Court 2s inherent authority order the State Attorney and the Clerk of the Court to file with this Court copies of the testimony minutes and other evidence presented in to the Palm Beach 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 i CA/Aronberg-0137 FILEB PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Based on information learned by The Palm Beach Post through its Florida Public I I Records Law requests law enforcement sources with direct knowledge of grand jury evidence and proceedings judicial documents obtained from independent but related tourt proceedings and documents otherwise available in the public record the State Attorney for Palm Beach County presented truncated evidence of Epsteins criminal wrongdoing to the grand jury in a manner that precluded his indictment for the serious crimes he committed including sex trafficking and sexual assault Pursuant to Florida Stat Section in order to further justice for Epsteins victims and the public and to provide public disclosure to illuminate whether Epstein received unreasonably lenient treatment based on the available evidence The Palm Beach Post requests immediate access to the testimony minutes and other evidence presented in to the Palm Beach County grand jury In a case of this magnitude and importance where the accused is dead and so many of his crimes as well as the identities and crimes of his co-conspirators and the identities of the victims have already been exposed the need for grand jury secrecy is no more See United States Socony-Vacuum Oil Co U.S After the grand jurys functions are ended disclosure is wholly proper where the ends of justice require it WHEREFORE The Palm Beach Post respectfully requests that this Court pursuant to Fla Stat Section and the Courts inherent authority order the State Attorney and the Clerk of the Court to file with this Court copies of the testimony minutes and other evidence presented in to the Palm Beach County grand jury during the first Epstein sex abuse investigation so that following an in camera inspection it can be made available to The Pafm Beach Post and the I CA/AronbeLQ-0137 FILEU PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM public on an expedited basis and grant any other and further equitable or legal relief the Court deems just and proper Dated January Respectfully submitted GREENBERG TRAURIG P.A Attorneys for CA Florida Holdings LLC Publisher of The Palm Beach Post Stephen A Mendelsohn Esq Town Center Circle Suite Boca Raton Florida Telephone Facsimile By s/Stephen A Mendelsohn_ STEPHEN A MENDELSOHN Florida Bar No mendel sohns gtlaw com hasenh gtlaw.com FLService gtlaw.com By Michael Grygiel__ MICHAEL GRYGIEL Admitted Pro Hac Vice State St 6th Floor Albany New York Telephone Facsimile grygielm gtlaw.com By s/Nina Boyajian_ NINA BOYAJIAN Pro Hac Vice application pending Century Park East Suite Los Angeles CA Telephone Facsimile boyajiann gtlaw.com ri veraal gtl aw com CA/Aronbera-0138 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM public on an expedited basis and grant any other and further equitable orl legal relief the Court deems just and proper Dated January Respectfully submitted GREENBERG TRAURIG A Attorneys for CA Florida Holdings LLC Publisher of The Palm Beach Post Stephen A Mendelsohn Esq Town Center Circle Suite Boca Raton Florida Telephone Facsimile By Isl Stephen A Mendelsohn STEPHEN A MENDELSOHN Florida Bar No mendelsohns gtlaw.com hasenh gtlaw.com FLService gtlaw.com By Isl Michael Grygiel MICHAEL GRYGIEL Admitted Pro Hae Vice State St 6th Floor Albany New York Telephone Facsimile grygielm gtlaw.com By Isl Nina Boyaiian NINA BOY AJIAN Pro Hae Vice application pending Century Park East Suite Los Angeles CA Telephone Facsimile boyajiann gtlaw.com riveraal gtlaw.com CA/AronbeLQ:0138 FILblJ PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of January a copy of the foregoing has been electronically filed with the Florida E-File Portal for e-service on all parties of record herein A Stephen A Mendelsohn i_ STEPHEN A MENDELSOHN BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of January a copy of the foregoing has been electronically filed with the Florida E-File Portal fore-service on all parties of record herein Isl Stephen A Mendelsohn STEPHEN A MENDELSOHN I CA/Aroppffil:5?Wl BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT I The Newspaper 2s Reportage on Jeffrey Epstein CA/Aron FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM IJXDIBIT I I I The Newspapers Reportage on Jeffrey Epstein CA/AronbeLQ-0140 FILEU PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM The Mm Beach Post REALNEWSSTARTS HERE i Ths Mani Who i Had Everything Joffrey Epstein craved big homes elite friends and underageIs By Andrew Marra Posted Jul at AM From the archives When Palm Beach detectives started asking questions and teenage girls started talking a wave of legal resistance followed Editors Note This article appeared in The Palm Beach Post on August three weeks after Jeffrey Epsteins arrest in Palm Beach County oh a charge of felony solicitation of prostitution WINGED GARGOYLES guarded the gate at Jeffrey Epstein 2s Palm Beach mansion Inside hidden cameras trolled two rooms while the girls came and went For the police detectives who sifted through the garbage outside and kept records of visitors it was the lair of a troubling target Epstein one of the most mysterious of the country 2s mega-rich was known as much for his secrecy as for his foye of fine things magnificent homes private jets beautiful women friendships with the world 2s elite But at Palm Beach police headquarters he was becoming known for something else the regular arrival of teenage girls he hired to give him massages and police say perform sexual favors Epstein was different from most sexual abuse suspects he Was far more powerful He counted among his friends former President Bill Clinton Donald Trump and Prince Andrew along with some of the most prominent legal scientific and business minds in the country When detectives started asking questions and teenage girls started talking a wave of legal resistance followed CA/Aronberg-0141 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I.he M.an W,b.o i.e:ad Evet;ythlng Jeffrey Epsle Cta:1ed big 267omes elite Jri:ends and un.deragat:girls B,y Andrew Marra Pgst ufi AM From the archives When Palm Beach detectives started asking que.stions and teenage girls started talking a wave of legal resistance followed Editor sNo.te This-arti_ck appeared in The Palm Beach Pos,t on August three eks after Jrffrey Epstein.:S arrest in.Palm Beach County on a charge of felony solicitation of prostitution WINGED GARGOYLES guarded the gate at Jeffrey Epsteins Palro Beach man_siqn Insicie hidcien cameras trolled two rooms whik the girls caille and nt For the police detectives who sifted through the garhageoutsideand kept re:cords of visitors it was the lair of a trcmbliri target Epstein one of the most mysterious of the totmtrysmega-rich was known as much for his ecrecy a for his lpye of fine tJ:iings:_IIJ.:3.gnificent h_omes prjvate jets beat.tif women friendships with the worlds elite But at Palm Beach police headquarters he was becoming known for something else the regular arrival ofteenag_e girls he hired tQ give him ma_ssages and polic:e perform sexual fayors Epstein was diff rentfrom m:ostsexual abuse suspects he was.far more powerfoL He cotuited among his friends former President Bill Clinton Donald Trump and Prince,.Andrew along with some of the most 267proipinen leg cientific aJld bus 265i,ess minds in i,he q:rnnJry When tec.tives sta,rted asking questions and teenage gtrls sta,:rted talking a wave oflegaf I resistance foilow:ed i CA/Aronbe_rn_-0141 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM NEW Jeffrey-Epstein Lawyer said financier had sex with woman during work release I If Palm Beach police didn 2t know quite who Jeffrey Epstein was they found out soon enough Epstein now was a quintessential man of mystery He amassed his fortune and friends quietly always in the background as he navigated New York high society When he first attracted notice in the early it was on account of the woman he was dating Ghislaine Maxwell daughter of the late British media tycoon Robert Maxwell In a lengthy article headlined The Mystery of Ghislaine Maxwell 2s Secret Love the British Mail on Sunday tabloid laid out speculative stories that the socialite 2s beau was a CIA spook a math teacher a concert pianist or a corporate headhunter But what is the truth about him the newspaper wondered Like Maxwell Epstein is both flamboyant and intensely private The media.frenzy did not begin iri full until a decade later In September Epstein was flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to Africa on his private et I Suddenly everyone wanted to know who Epstein was New York magazine and Vanity Fair published lengthy profiles The New York Post listed him as one of the city 2s most eligible bachelors and began describing him in its gossip columns with adjectives such as 223mysterious and reclusive Although Epstein gave no interviews the broad strokes of his past started to come into focus Building a life of extra vagance He was born blue-collar in the son of a New York City parks department employee and raised in Brooklyn 2s Coney Island neighborhood He left college without a bachelor 2s degree but became a iriath teacher at the prestigious Dalton School iri Manhattan The story goes that the father of brie of Epstein 2s students was so impressed with the man that he put in touch with a senior partner at Bear Stearns the global investment bank and securities firm CA/Aronberg-0142 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I I I I i NEW Jeffrey.Epstein Lawyer said financier fiadsex with woipan dutin:g work release CC I I If Palm Beac;h,police didnt know quite who Jeffrey Epstein was they found out soon enougp Epstein now was a quintessential man of mystery He amassed his fortune and friends quietly always in the background as he navigated New York high society Whep h,e first a,ttra ted nqdce fo the early it was on account ofthe woman he:wa dating Ghislaine Maxwell daughter of the late Br:.itish m.edfa tycoon Robert Maxwell In a len thyarticle headlined The Mystery of Ghislaine Maxwells Secret Love the British Mail ort Sunday tabloid laid out speculative stories that the socialites beau was a CIA spook a math_ te cher a co n_ist or a c_orpornte l;i adht1nter Bu_t what is the truth bo:u h1 the newsp;i,per wondered Like Jvtaxwelt Epstein 1s both flarn:boya.nt and intenseiy private The media.frenzy did hot begin in full until a decade lateE Ih September Epstein was flung into the limeught when he flew Cllnton and actors Kevm Spacey and Chris Tucker to Africa on his private jet Suddenly everyone wanteo to know who Epstein New York1I1a:gazine and Van:ityFair blishedJengthypr9file The New Yark Post listed him as one 6f the citys most eligible b;:i._ci elqrs c1n:d begap desqibing hiq1 in its g_ossip columns y.,ith adjecthres suc_h my tedou rn-d reclusive Although Epstein gave no interviews the broadstrokesofhis past started fo come into focus Buildili a life,ofextra:vagance He was bor_nblue-collar in i the son of a New York City-parks department employee and raised in Brooklyns Coney Island neighborhood He left college witho:ut.;a bachelors degr_e.e but b"ecame a math teacher at the prestigio:us Dalton Schooi in Manhattap The story goes that the father of ohe of Epsteins students:was so impressed with the.man that he put him fn to:uc_h with a seniorpartner at Bear Stea,rns the glob investment and securities firm CA/Aronberg-0142 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i
