Document EFTA 02735595¶
GT GreenbergTraurig¶
Michael I.Grygiel Tel: 518.689.1406 Fax: 518.689.1499 grygielml0gtlaw.com¶
October 9, 2019¶
VIA ELECTRONIC MAIL AND UPS OVERNIGHT DELIVERY¶
State Attorney David Aronberg 401 North Dixie Highway West Palm Beach, Florida 33401 Email: Oarcinbera(u sa15.state.fLus¶
Re: The Palm Beach Post’s Public Records Law Re {sup}O {sup}S Cf14 y Epstein¶
Dear State Attorney Aronberg:¶
As you know from my colleague Steve August 27, 2019, and September 17, 2019, our fi the “Newspaper”) in connection with its Flop concerning your office’s investigation of previous correspondence dated is The Palm Beach Post (“PBP” or lic Records Law requests for documents sex abuser Jeffrey Epstein.¶
The Newspaper has carefully Attorney’s October 1, 2019, respon these materials, significant info attention to the following, wh the ordinary course: supplemental disclosures provided in the State r Jane Musgrave. Based on. PBP’s examination of rently remains undisclosed. We specifically call your it would be maintained by the State Attorney’s office in¶
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- Case Jo — we understand that, as a matter of policy and practice, Florida S rosecutors routinely compile and maintain this document, fu ions as a comprehensive ledger that keeps track of all ative activities in a given criminal prosecution, on .a step-by step, logical basis. AC System — the Newspaper advises that documents from this system, which is also routinely utilized by Florida State Attorneys and provides a repository for any and all investigative notes, including those of any witness interviews, have not been provided.
These omissions are conspicuous given the high profile and public importance of the investigation and prosecution of Jeffrey Epstein. Indeed, and with all due respect, the absence of any investigative notes — including those of witness interviews — from your office’s previous disclosures raises a serious question as to its good faith compliance with its disclosure obligations under the Florida Public Records Law. We respectfully request expedited production of the above information, and in any event no later than COB (5:00 p.m. Eastern) on October 16, 2019. If the¶
State Attorney David Aronberg October 9, 2019 Page 2¶
State Attorney’s position is that the foregoing categories of documents do not exist, we respectfully request certification to that effect from appropriate personnel in your office.¶
In making this request, we are mindful of and thank your office for producing responsive documents to date. Nevertheless, I am compelled to emphasize the extreme public interest in the information requested herein, as well as the extreme importance of the public issues it ‘mplicates, in requesting that it be produced by the above date in order to avoid litigation.¶
Thank you for your continuing consideration in this matter.¶
Very truly yours,¶
GREENBERG TRAURIG, LLP¶
Michael J.¶
MJG/Imd ACTIVE 46491241v1¶
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State Attorney David Aronberg October 9, 2019 Page 3¶
bcc: Ms. Holly Baltz Senior Editor, Investigations The Palm Beach Post¶
Mr. Joel Engelhardt¶
Investigative Team Editor The Palm Beach Post Chief Litigation Counsel GateHouse Media, LLC¶
Edwin M.. Esq.¶