State motion to unseal Epstein grand jury testimony, with executive order

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

STATE OF FLORIDA¶

-VS-¶

Jeffrey Epstein¶

Defendant(s)¶

Case No. 50-2006-CF-009454-A¶

MOTION FOR AN ORDER UNSEALING GRAND JURY TESTIMtl14/¶

COMES NOW the State of Florida, by and through its undersigned Ass’ pursuant to Florida Statute 905.27 (1), moves this court to en unsealing of grand jury testimony. The State further requests authorizing FDLE Agent Troy K. Cope, Members of Investigations Public Corruption Unit, State Attorney Bruc to obtain recordings of the entire grand jury in the above Clerk of Court and authorize the transcription of Palm Beach County Grand Jury proceedings invo Jeffrey Epstein for Felony Solicitation of Prostitu S t vAttomey, and authorizing the to enter an order Office of Executive and his assigned assistants matter from the Palm Beach otion refers specifically to the dictment dated July 19, 2006 of¶

As grounds in support of this motion, the S the following:¶

• 905.27(1) Florida Statutes (201 its the disclosure of the testimony of a witness examined before the grandlypr er evidence received by it.
• 2. An exception to the rul on-disclosure exists when disclosure is required for the furthering of justice. 9 )(c) Florida Statutes (2019). DeSantis, Governor of the State of Florida, authorized the ent • f Law Enforcement to initiate a preliminary inquiry beyond the Jeffrey Epstein and into other irregularities surrounding the prior State d the ultimate plea agreement. See Exhibit A, Executive Order Number ctor Troy K. Cope and the Office of Executive Investigations Public Corruption Uni has been assigned to spearhead the investigation on behalf of the Florida Department of Law Enforcement.
• 5. The aforementioned executive order assigned Bruce H. Colton, State Attorney for the Nineteenth Judicial Circuit of Florida, to assist in the investigation, prosecution and all allegations related to Jeffrey Epstein and his assigned work release program and other irregularities.

1. 6. Bruce H. Colton assigned Assistant State Attorneys Lev [REDACTED] and Anastasia Norman to assist the Florida Department of Law Enforcement in the execution to this executive assignment.
2. 7. A review of the Palm Beach County Clerk of Court’s file in Case No. 2006CF9454AXX and 2008CF009381AXX indicate that Jeffrey Epstein was charged, in part, via grand jury indictment. See Attached Indictment, Exhibit B.
3. 8. A review of the grand jury testimony is necessary to fulfill Governor DeSantis’ assignment and required in the furtherance of justice.

WHEREFORE, the State respectfully requests this Honorable Court enter an order granting the State’s Motion as requested above.¶

I HEREBY CERTIFY that a true copy of the foregoing has been furnished to, Jack A. Goldberger, by eservice/email at the designated email address of jgoldberger@agwpa.com, smahoney@agwpa.com; Attorney Robert D. Critton, by email at the designated email address of rcrit@lawclc.com; Sharon R. Bock, Clerk and Comptroller of Palm Beach County by mail at 205 N Dixie Hwy, West Palm Beach, FL 33401; Attorney Spencer T. Kuvin by email at the designated email address of skuvin@800goldlaw.com; Attorney [REDACTED] J. [REDACTED], by email at the designated email address of brad@epllc.com; Attorney Jeffrey M. Herman by email at the designated email address of jherman@hermanlaw.com; Theodore J. Leopold, by email at the designated email address of tleopold@cohenmilstein.com; A.H. by US mail at confidential address; A.D. by US mail at confidential address; S.G. by US mail at confidential address; Gregory Parkinson by US mail at 7022 Venetian Way, West Palm Beach, FL 33406, on December 10, 2019.¶

RESPECTFULLY SUBMITTED BRUCE H. COLTON, State Attorney¶

By: /s/ M. Levering [REDACTED] M. Levering [REDACTED] Assistant State Attorney FL Bar#: 708828 411 S. 2nd Street Fort Pierce, FL 34950 (772) 465-3000 Designated eService address: SA19eService@sao19.org¶

STATE OF FLORIDA¶

OFFICE OF THE GOVERNOR EXECUTIVE ORDER NUMBER 19-183¶

WHEREAS, in 2008, Jaw ailed guilty to procuring a person under 18 for prostitution and felony solicitation of prostitution in Palm Beach County, folio to and federal investigations, and was later placed on work release; and¶

WHEREAS, the State Attorney Office for Palm Beach related to the state investiption concerning Jeffrey Epstein; and¶

WHEREAS, the Sheriff for Palm Beach County e work release of Jeffrey Epstein; and¶

• WHEREAS, the Sheriff* Palm ittidated a criminal investigation concerning Jeffrey Epstein and hai that the Florida Department of Itiw • Enforcement now assume that’¶

WHEREAS, the De f Law Enforcement may initiate apreliminnor iriquirt beyond the work release ofleffrey Epstein and into other irregularities sititianding the prior •.: state investigation and theul6mate plea agreement; and¶

• Y. the Honorable BRUCE IL COLTON, State Attorney for the Nineteenth Judicial Qirc l of Florida, has agreed to accept an executive assignment for any proceedings thatetrom the Department of Law Enforcement investigation and inquiry in this Mutts¶

WHEREAS, for good and sufficient reason, the Governor has determined it is in the best interests of the State of Floriclaand of the ends of justice that the Honorable BRUCE H.¶

COLTON discharge the duties of the Honorable DAVID ARONBERG, pursuant to section 27.14, Florida Statutes.¶

NOW, THEREFORE, I, RON DESANTIS, Governor of Florida, in obedience to my solemn constitutional duty to “take care that the laws be faithfully executed,” and pursuant to the Constitution and laws of the State of Florida, issue the following Executive Order, effective immediately:¶

Section 1.¶

The Honorable BRUCE H. COLTON, State Attorney for the Nineteenth Judicial Circuit of Florida, referred to as the “Assigned State Attorney,” is assigned to discharge the duties of the Honorable DAVID ARONBERG, State Attorney for the Fifteenth Judicial Circuit of Florida, as they relate to the investigation, prosecution, and all matters related to allegations related to Jeffrey Epstein and his assigned work release program and other irregularities.¶

Section 2.¶

The Assigned State Attorney or one or more Assistant State Attorneys and Investigators, who have been designated by the Assigned State Attorney, shall proceed immediately to the Fifteenth Judicial Circuit of Florida, and are vested with the authority to perform the duties prescribed herein.¶

Section 3.¶

All residents of the Fifteenth Judicial Circuit are requested, and all public officials are directed, to cooperate and render whatever assistance is necessary to the Assigned State Attorney, so that justice may be served.¶

Section 4.¶

The period of this Executive Assignment shall be for one (1) year, to and including August 6, 2020.¶

Section 5.¶

The Assigned State Attorney shall notify the Governor on or before July 6, 2020, if additional time is required.¶

IN TESTIMONY WHEREOF, I have hereunto set my hand and have caused the Great Seal of the State of Florida to be affixed at Tallahassee, this 6th day of August, 2019.¶

ATTEST:¶

Lawrence SECRETARY OF STATE¶

U.S. ATTORNEY OF STATE TALLAHASSEE, FLORIDA¶

2019 AUG - 6 PM 1:20¶

FILED¶

INDICTMENT¶

A TRUE BILL¶

06-9454 CF A2¶

05 JUL 19 PM 2:4¶

FILED¶

SHARON R. BOCK, CLERK FALM BEACH COUNTY CIRCUIT OF FLORIDA¶

IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA¶

For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State aforesaid,¶

COUNT ONE FELONY SOLICITATION OF PROSTITUTION¶

on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31, 2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005, contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)¶

against the form of the statute, to the evil example of all others, and against the peace and dignity of the State of Florida.¶

I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.¶

GRAND JURY FOREPERSON¶

July 19, 2005 DATE¶

Jeffrey E. Epstein, Race: [REDACTED], Sex: Male, DOB: January 20, 1953, SS#: [REDACTED]; Issue Warrant¶

CAA RUL 25 [unclear]¶