# GT Greenberg Traurig

Stephen A. Mendelsohn
Tel 561.955.7629
Fax 561.659.9119
mendelsohns@gtlaw.com

October 15, 2020

## FOR SETTLEMENT PURPOSES ONLY NOT ADMISSIBLE IN EVIDENCE

Douglas A. Wyler
Jacob Scholz & Wyler, LLC
961687 Gateway Blvd.
Suite 201-I
Fernandina Beach, Fl. 32034
[Jacobsscholzlaw@comcast.net](mailto:Jacobsscholzlaw@comcast.net)

Re: *CA Holdings, Inc. as Publisher of The Palm Beach Post v. Dave Aronberg, as State Attorney et al.*
Case No. 2019-CA-014681

Dear Mr. Wyler:

In candor, I was disappointed to receive your telephone call today, and write to advise that my client will not accept the counter-offer proposed by the State's Attorney.

Nevertheless, as we discussed previously this morning, and as I mentioned to the Court during the case management conference, *The Palm Beach Post* ("The Post") was pleased to read the State Attorney's clear and unequivocal statement in its Response filed yesterday that his office will not oppose *The Post*'s request for access to the Jeffrey Epstein grand jury materials.

I therefore hereby reiterate my client's initial settlement offer: in exchange for *The Post* dropping the State Attorney from the above case, pursuant to Fla. R. Civ. P. Rules 1.250 and 1.420(1)(B), the State Attorney will withdraw all of his pending motions. The dismissal of the case will be with prejudice. The parties will file a brief stipulation with the Court stating that they have settled their litigation based on these terms as well as the State Attorney's representation that it will not take a position against *The Post*'s constitutional and statutory claims for public access to the Jeffrey Epstein grand jury materials.

**Greenberg Traurig, P.A. | Attorneys at Law**

5100 Town Center Circle | Suite 400 | Boca Raton, Florida 33486 | T +1 561.955.7600 | F +1 561.338.7099

Albany, Amsterdam, Atlanta, Austin, Berlin, Boca Raton, Boston, Chicago, Dallas, Delaware, Denver, Fort Lauderdale, Houston, Las Vegas, London, Los Angeles, Mexico City, Miami, Milan, Minneapolis, Nashville, New Jersey, New York, Northern Virginia, Orange County, Orlando, Philadelphia, Phoenix, Sacramento, San Francisco, Seoul, Shanghai, Silicon Valley, Tallahassee, Tampa, Tel: Party JOINT C. West Palm Beach, Westchester County.

**Joint Exhibit**
J22

Correspondence to Douglas A. Wyler October 15, 2020 Page 2

Resolving the case makes sense for both parties. We urge the State Attorney to consent and for the parties to enter into the stipulation as set forth herein.

Thank you for your cooperation.

Very truly yours,

is/Stephen Mendelsohn

Stephen Mendelsohn Nina Boyajian, Esq. ?s, ACTIVE 53206738v2

SAM:Is

cc: Michael Grygiel, Esq.