Court filing, 2020-09-02

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

CASE NO: 2019CA014681XXXXMB AG¶

CA FLORIDA HOLDINGS, LW, Publisher of THE PALM BEACH POST, Plaintiff,¶

vs.¶

DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, SHARON It BOCK, as Clerk & Comptroller, Palm Beach County, Florida,¶

Defendants.¶

O SA¶

DEFENDANT, SHARON R. BOCK, AS CLERK & C PI)ROLLERI PALM BEACH COUNTY’S RESPONSE TO PLAINTIFF’S Af11ENDED REOUEST FOR PRODUCTION¶

Defendant, Sharon It Bock, as Clerk & Com Beach County, by and through undersigned counsel, hereby files this Respo nse \ o intiff’s Amended Request for Production dated July 10, 2020, and states as follows:¶

OBJECTIONS¶

• 1. The Clerk will P16duce uments in its possession or control, if any, subject to the limitations set forth belo
• 2. The c erk c es the right to supplement, amend or correct all or any part of the responses pro Cey, h in. producing documents pursuant to the Amended Request, the Clerk does not (a) admit that uch documents (or related documents) are properly discoverable; (b) waive any objection which might otherwise be made to such documents; or (c) admit that any such documents are admissible at trial.

4. The Clerk will make reasonable efforts to respond to each item of the Request, as the Clerk understands and interprets the Request. If the Plaintiff subsequently asserts an interpretation of any item in the Request that differs from the Clerk’s interpretation, the Clerk reserves the right to supplement the objections and responses.

5. The Clerk objects to the Request to the extent that it seeks “all” documents, and is thus so broad, vague and indefinite as to make it impossible for the Clerk to ascertain the specific information requested. As previously stated, (i) such broad, vague, and inde InSuests are unduly burdensome and oppressive, and it would be practically impossible erk to produce the documents; and (ii) such broad, vague, and indefinite requests m cal documents which are neither relevant to the subject matter of this action nor ryattlbly calculated to lead to the discovery of admissible evidence.

6. The Clerk objects to the extent any Request seeks documents that are privileged under federal and/or state privacy

DOCUM¶

I. Copies of all logs , registers, lists and entries that show the delivery of Epstein Grand Jury Materials Clerk to the State Attorney. The specific materials delivered need not be disclosed or p¶

RESPONSE: fhb 01Rrk is not in possession of any logs, notations, registers, lists and entries that show the Epstein Grand Jury Materials from the Clerk to the State Attorney.¶

opies of all logs, notations, registers, lists and entries that show the return of Epstein Grand Jury Materials by the State Attorney to the Clerk. The specific materials returned need not be disclosed or produced.¶

RESPONSE: The Clerk is not in possession of any logs, notations, registers, lists and entries that show the return of Epstein Grand Jury Materials by the State Attorney to the Clerk.¶

3. Copies of all communications between the Clerk and the State Attorney concerning the storage, possession, delivery, receipt and control of Epstein Grand Jury Materials. The specific materials referenced need not be disclosed or produced.

RESPONSE: A search of the Clerk’s records from June 2009 to present revealed that there were no responsive records between the Clerk and the State Attorney concerning the storage, possession, delivery, receipt and control of Epstein Grand Jury Materials. Electronic communicajion prior to June 2009 is not reasonably accessible and is duly burdensome to research.¶

4. Copies of all logs, notations, registers, lists and entries that4dfi 11lygeneral types of Epstein Grand Jury Materials in the possession of the Clerk, witho g their contents.

RESPONSE: Our research found no logs, notations, regist ts and entries that show the general types of “Epstein Grand Jury Materials.”¶

5. Copies of all logs, notations, regist d entries that show the delivery of Epstein Grand Jury Materials to the Fed of Investigation. The specific materials referenced need not be disclosed or p

RESPONSE: The Clerk is not in of any logs, notations, registers, lists and entries that show the delivery of Epstein d J Materials to the Federal Bureau of Investigation.¶

6. Copies of~llgs, notations, registers, lists and entries that show the delivery of Epstein Grand J United S aterials to the United States Department of Justice and/or any Office of the ey. The specific materials referenced need not be disclosed or produced

RES e Clerk is not in possession of any 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.¶

7. Copies of all subpoenas and any judicial process served upon the Clerk for production of Epstein Grand Jury Materials.

RESPONSE: No responsive records have been located at this time. Any subpoena or judicial process served upon the Clerk for production of Epstein Grand Jury Materials would likely be included in the Epstein Grand Jury Material, which cannot be released without a Court order.¶

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 States Attorney concerning Epstein Grand Jury Materials. The specific materials referenced need notJle disclosed or produced.

RESPONSE: A search of the Clerk’s records from June 2009 to presen a I rthat there were no responsive records between the Clerk and the United States t of Justice, or the Federal Bureau of Investigation or any Offices of the Unit :ies Attorney Attorney concerning the Epstein Grand Jury Materials. Electronic communicatio accessible and is duly burdensome to research. tme 2009 is not reasonably¶

CERTIFIC RVICE¶

I HEREBY CERTIFY that a ti t y o the foregoing has been emailed in compliance 2ity with the Florida Rules of Judicia t ’ lion 2.516, on this 2nd day of September, 2020, to: Stephen A. Mendelsohn, Esq., rg Traurig, P.A., 5100 Town Center Circle, Suite 400, Boca Raton, FL 33486, email: r lsohns@gtlaw.com and Douglas A. Wyler, Esq., 961687 Gateway Blvd., Suite 201 ndina Beach, FL 32034, email: jacobsscholzlaw@comcast.net.¶

+O¶

Cynthia M. Guerra, Esq. For Sharon R. Bock, Clerk & Comptroller Post Office Box 229 West Palm Beach, FL 33401 Telephone: (561) 355-2983 E-service: Clerk_E-service®mypalmbeachclerk.com¶

BY: s/Cvnthia M. Guerra Florida Bar No. 886610¶