# 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. # PLAINTIFF'S MOTION TO DIRECT THE CLE JEFFREY EPSTEIN GRAND JURY FILES INVENT AT C COURT TO UNSEAL THE NVENTORY AND FOR AN Plaintiff, CA HOLDINGS, LLC " ?SWPa Beach Post') moves for an Order Directing the Clerk of the Court to Unseal the Je n Grand Jury Files to create an inventory and provide the Court and The Palm Beach t wi the inventory and states: - 1. The Palm ost is a daily community newspaper published by Plaintiff CA Florida Holdings, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. - 2. t Sharon R. Bock ("Clerk") is the duly elected Clerk and Comptroller of Palm Beach C , orida. She is sued in her official capacity as her office is in possession of Grand Jury documents that are the subject of this action. - 3. On October 21, 2020, The Palm Beach Post dropped State Attorney Dave Aronberg from the case pursuant to Fla. R. Civ. P. 1.250(b). CO SA Epstein Grand Jury materials and c 6. Based upon discovery responses provi b lerk, and conversations between the Clerk's office and The Palm Beach Post, the d Jury files are being held by the Clerk in a sealed container. Further, the Clerk h t pe ed and does not possess an inventory of the 4 hat materials are in its possession. 7. The Palm Beach Jury files, and that the C ests that the Clerk be permitted to unseal the Epstein Grand ted to create a written inventory of the items in its possession. 4. By this action, The Palm Beach Post seeks access to the grand jury materials related to the State of Florida's prosecution of the late Jeffrey Epstein to determine why Epstein received a lenient criminal charge and a minimal work release sentence, where there was significant evidence that Epstein was and remained a serial sexual abuser of underage girls. 5. The Palm Beach Post alleges that the First Amendment to ited States Constitution, when read in conjunction with Fla. Stat section 925.07, and un is of this case, compel the lowering of the cloak of grand jury secrecy to resolve th wered questions surrounding Epstein's under and unprosecuted crimes and to inf thellfiblic whether justice was served. 8. Als m Beach Post seeks an order that permits the Clerk to provide its inventory to T each Post and to the Court. e purpose of this inventory is to understand what is contained in the Clerk's files so that The Palm Beach Post will be able to more precisely advocate for the future release of specific Epstein Grand Jury materials. 10. It is understood that the Clerk does not oppose this Motion. 11. To protect the privacy of victims and witnesses, The Palm Beach Post accepts that their names and other identifying information should be redacted in the inventory. It reserves the right to seek the release of such information at a later date. WHEREFORE, The Palm Beach Post requests that its Motion be granted and that the Clerk be permitted to unseal the Epstein Grand Jury files, the Clerk be directed to create amatory of the Epstein Grant Jury materials, with redactions for identifying information, th wide a copy of the inventory report to The Palm Beach Post and to the Court, and that nt such other and further relief it deems just and proper. +6s Resp i 1 'S u fitted, RG TRAURIG, P.A. s for CA Florida Holdings, LLC, Publisher Palm Beach Post ephen A. Mendelsohn, Esq. 5100 Town Center Circle, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 By: /s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 mendelsohns@gtlaw.com smithl®gtlaw.com FLService@gtlaw.com By: /s/ Michael J Grygiel MICHAEL J GRYGIEL (Admitted Pro Hac Vice) 54 State Si, 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 grvgielm@utlaw.com By: Is/ Nina D. Boyajian NINA D. BOYAJIAN (Admitted Pro Hac Vice) 1840 Century Park East Los Angeles California Telephone: (310) 5 -7 Facsimile: (310 bo riveraa # E I HEREBY CERTIFY that on thi f October, 2020, a true and correct copy of the foregoing has been filed with the Cl ourt using the State of Florida e-filing system, which will send a notice of electronic s C ice ) f all parties of record herein /s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN ACTIVE 53423583v3