Court filing, 2019-07

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CA FLORIDA HOLDINGS, LLC, CASE NO.: 50-2019-CA-014681-XXXX-MB¶

Publisher of THE PALM BEACH POST,¶

DIVISION: AG¶

Plaintiff,¶

v.¶

DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida,¶

Defendants.¶

REOUEST FOR PRODU ‘Sic ‘t CUMENTS¶

Plaintiff, CA FLORIDA HOLDINGS fisher of THE PALM BEACH POST, by and through their undersigned counsel, by r uests that Defendant, SHARON R. BOCK, as Clerk and Comptroller of Palm B , Florida, produce all materials requested herein at the offices of the undersigned e ‘thin thirty (30) days from the date hereof, or such shorter time as may be ordered b urt, pursuant to Rule 1.350, Fla. R. Civ. P.¶

EFINITIONS AND INSTRUCTIONS¶

• 1. ” d Jury Materials” shall refer to all evidence, testimony, documents, transc , bills and other items used in or presented to the grand jury in and for Palm Beach County, Florida in the prosecution of Jeffrey E. Epstein, date of birth January 20, 1953, Palm Beach Circuit Court Case No. 50-2008-CF-AXXX-MB.
• 2. “Clerk” shall refer to the Office of the Clerk and Comptroller of Palm Beach County, Florida established by the Fla. Constitution, Article V, Section 16.

Cos¶

• e Federal Bureau of Investigation. The specific materials referenced need duced. not be disclosed or produced.

• 1. Copies of all logs, notations, registers, lists and entries that show the deliv of Epstein Grand Jury Materials from the Clerk to the State Attorney. The specific mate s’gt eli red need 0
• 2. Copies of all logs, notations, registers, lists and entries that ow the return of Epstein Grand Jury Materials by the State Attorney to the Clerk. The materials returned need not be disclosed or produced.
• 3. Copies of all communications between d the State Attorney concerning the storage, possession, delivery, receipt and c stein Grand Jury Materials. The specific materials referenced need not be disc duced.
• 4. Copies of all logs, no ‘stern, lists and entries that show the general types of Epstein Grand Jury Materials in ssession of the Clerk, without revealing their contents.
• 5. Copies of alJ4ogs, o Lions, registers, lists and entries that show the delivery of Epstein Grand Jury not be disc
• 6. Co s of all logs, notations, registers, lists and entries that show the delivery of Epstein Grand Jury Materials to the United States Department of Justice and/or any Office of the United States Attorney. The specific materials referenced need not be disclosed or produced.
• 3. “State Attorney” shall refer to the Office of State Attorney for Palm Beach County, Florida established by Fla. Constitution, Article V, Section 17.

DOCUMENTS REOUESTED¶

• 7. Copies of all subpoenas and any judicial process served upon the Clerk for production of Epstein Grand Jury Materials.
• 8. Copies of all communications between the Clerk and the United States Department of Justice, or the Federal Bureau of Investigation or any Offices of the United at Attorney concerning Epstein Grand Jury Materials. The specific materials referenced neao t be disclosed or produced. CO

CERTIFICATE OF SERVICE¶

I HEREBY CERTIFY that on this nth day of July opy of the foregoing has been electronically filed with the Florida E-File Portal for e-set \ *c I parties of record herein.¶

AS tfully submitted,

¶

GREENBERG TRAURIG, P.A. Attorneys for CA Florida Holdings, LLC, Publisher of The Palm Beach Post Stephen A. Mendelsohn, Esq. 5100 Town Center Circle, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099¶

By: is/Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 mendelsohnslautlaw.com smithl©gtlawcom FLService@gtlaw.com¶

By: /s/ Michael J Grygiel MICHAEL J GRYGIEL (Admitted Pro Hac Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 grygielm@gtlaw.com¶

By: /s/ Nina D. Boyajian NINA D. BOYAJIAN (Admitted Pro Hac Vice) 1840 Century Park East, Suite 1900 Los Angeles California 90067 Telephone: (310) 586-7700 Facsimile: (310) 586-7800 boyajiann@gtlaw.com riveraal@gtlaw.com¶

ACTIVE 51334994w1¶