# 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.

A Cos

# PLAINTIFF CA FLORIDA HOLDINGS, LLC M SCHEDULE A ONE HOUR HEARING FOR ITS MOTION F K ch ARY JUDGMENT
Plaintiff, CA Florida Holdings, LLC, pub S ' ills r e Palm Beach Post, moves for an order scheduling its Motion for Summary Jud t an states:

- I. Plaintiff CA Holdings, LL t publisher of The Palm Beach Post newspaper (the "PBP"), the largest daily circu wspaper in Palm Beach County, Florida. PBP brings this action seeking the release effrey Epstein grand jury materials in the possession of the Clerk of the Court, Pal h rr. unty.
- 2. As co is well aware, Jeffrey Epstein ("Epstein") was convicted of a sexual felony as part of rgain between Epstein, the Palm Beach State Attorney and the U.S. Attorney for the Southern District of Florida.
- 3. Investigations by PBP and other media exposed the favorable plea deal which allowed Epstein to avoid prosecution for serious sexual felonies involving minors. Epstein also received lenient treatment through a work-release program which he used to continue his sexual abuse of

minors. Epstein, following these revelations, was eventually charged by the U.S. Attorney for the Southern District of New York with additional multiple counts of sexual abuse of minors. While in pre-trial detention, Epstein committed suicide.

4. In order to inform the public as to why the Palm Beach State Attorney treated Epstein so favorably, PBP filed this lawsuit for the release and access to Palm Beach County's Epstein grand jury materials.

5. This case involves novel issues of first impression relating to the op lorida grand o juries, grand jury secrecy and the media's First Amendment right to final prosecution materials to inform the public

6. Because of these important public issues, PBP r A motion for summary judgment for at least a (1) one- n videntiary hearing. is Court specially set PBP's

7. The exhibits supporting PBP's motion r judgment are voluminous and require time to review. Ample time is necessary the urt to address the possible remedies to balance the competing interests.

8. PBP also requests that mo i n for summary judgment be heard at the Court's earliest convenience given the im 74pe of the issues presented.

9. PBP has ised unsel for the Clerk of the Court about this motion and the relief requested he in. I ough PBP has repeatedly asked whether the Clerk opposes or consents to the relief r the Clerk has not stated his position.

10. Therefore, PBP has shown good cause for the Court to schedule at least a one hour hearing.

WHEREFORE, PBP respectfully requests that the Court specially set PBP's motion for summary for at least one hour, and schedule a hearing at the Court's earlies convenience, as well as grant such other and further relief that the Court may deem just and proper.

Respectfully submitted,

+6s

GREENBERG TRAURIG, P.A.

Attorneys for CA Florida Holt LL , Publisher of The Palm Bea

Stephen A. Mendelso 401 East Las Olas B1 Fort Lauderdale, Florit. .01 Telephone: (95 Facsimile:

By: //Sle ST ENDELSOHN o. 849324 law.com

y: Is/ Michael J Gimlet MICHAEL J. GRYGIEL (Admitted Pro Hac Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 grvgielmegtlaw.com

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

**CERTIFICATE OF SERVICE**

**I HEREBY CERTIFY** that on this 24{sup}`th` day of May, 2021, a true and correct copy of the foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system, which will send a notice of electronic service for all parties of record herein

*/s/ Stephen A. Mendelsohn*

**STEPHEN A. MENDELSOHN**

ACTIVE 57206934v2

NOTA CERTIFIED COPY