074.pdf

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Filing# 132529617 E-Filed 08/12/2021 10:20:22 AM 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
CASE NO.: 
2019-CA-014681 
DIVISION: 
AG 
AMENDED MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT DAVE 
ARONBERG'S AMENDED MOTION FOR ATTORNEYS' FEES 
Defendant, DA VE ARONBERG, as State Attorney of Palm Beach County, Florida, (the 
"State Attorney"), by and through counsel below, hereby submits the following Amended 
Memorandum of Law in Support of his Amended Motion for Attorneys' Fees, as follows: 
TIMELINE & BACKGROUND 
1. 
On November 14, 2019, Plaintiff filed a Complaint against the State Attorney and 
Clerk seeking to create a private right of action under Fla. Stat. § 905 .27, in the interest of 
"furthering justice", to compel disclosure of the testimony, minutes, and other evidence presented 
in 2006 to the Palm Beach County grand jury, as to Jeffrey Epstein, (the "Requested Materials"). 
[Def.Ex.A-I]. 
2. 
On November 26, 2019, the State Attorney and his office received an engagement 
letter and attorney-client contract from the undersigned, which was later executed. [Def.Ex.A-2]. 
~** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 08/12/2021 10:20:22 AM*** 

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3. 
On December 6, 2019, the State Attorney filed his Motion to Dismiss, which put 
Plaintiff on notice that "Defendant Aronberg is not in custody or control of the [Requested 
Materials} and is therefore not a proper party to this action." [Def.Ex.A-3]. 
4. 
On January 17, 2020, Plaintiff filed its First Amended Complaint, which in addition 
to its original claim under§ 905.27 Fla. Stat., ("Count II"), added a claim for Declaratory Relief, 
("Count I"), that sought an order declaring that the State Attorney and the Clerk disclose and 
release the Requested Materials. [Def.Ex.A-4]. 
5. 
On January 24, 2020, the State Attorney filed an Answer to Count I of the First 
Amended Complaint and a Motion to Dismiss Count II, which again notified Plaintiff that: 
Defendant Aronberg and the Office of the State Attorney for the Fifieenth Judicial 
Circuit are not in custody or control of the records sought herein, and therefore 
Defendant Aron berg is not a proper party to this action. In fact, Defendant, Sharon 
R. Bock, as Clerk and Comptroller of Palm Beach County, Florida, admits that it 
is the custodian in possession of the documents that are the subject of this action. 
[Def.Ex.A-5, p. 12]. 
6. 
On June 3, 2020, Chief Judge Marx held a hearing on the State Attorney's and 
Clerk's Motions to Dismiss Count II. [Def.Ex.A-6]. 
7. 
On June 8, 2020, the Court entered its Order Granting Defendants' Motions to 
Dismiss Count II of Plaintiff's First Amended Complaint with Prejudice, leaving only Plaintiff's 
Count I seeking declaratory relief. [Def.Ex.A-?]. 
8. 
Immediately thereafter, Plaintiff was served with a demand, pursuant to § 57 .105 
Fla. Stat., to voluntarily dismiss/withdraw the First Amended Complaint and the claims against 
the State Attorney, along with a Motion for Attorneys' Fees("§ 57.105 Demand"). [Def.Ex.A-8]. 
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9. 
In serving his§ 57 .105 Demand, the State Attorney properly put Plaintiff on notice 
that he would seek sanctions by filing the § 57 .105 Motion for Attorneys' Fees if Plaintiff failed 
to dismiss the remainder of the First Amended Complaint within 21 days. 
10. 
On June 23, 2020, Plaintiff's counsel sent a response to the § 57 .105 Demand 
refusing to withdraw the remainder of the First Amended Complaint. [Def.Ex.A-9]. 
11. 
After receiving Plaintiff's response and waiting the requisite "21 days after service 
of the motion," the State Attorney's§ 57.105 Motion for Attorneys' Fees was filed with the Court 
on July 1, 2020, ("First Motion for Attorneys' Fees"). [Def.Ex.A-IO]. 
12. 
On August 18, 2020, the State Attorney filed his Motion for Summary Judgment, 
[Def.Ex.A-I I], which includes an Affidavit made by the State Attorney. [Def.Ex.A-12]. 
13. 
On October 21, 2020, Plaintiff filed its Notice of Dropping the State Attorney, 
pursuantto Rule 1.250(b), Fla.R.Civ.P. [Def.Ex.A-13]. 
14. 
On November 9, 2020, the State Attorney filed his Amended Motion for Attorneys' 
Fees, ("Amended Motion"), pursuantto § 57.105, Fla. Stat., seeking attorneys' fees in the amount 
of$19,975.00, plus a multiplier of 2. [Def.Ex.A-14]. 
I. 
LEGAL STANDARD 
As follows, Florida Statutes § 57 .105( 1) authorizes awards of attorneys' fees as sanctions: 
(1) 
Upon the court's initiative or motion of any party, the court shall award a 
reasonable attorney's fee, including prejudgment interest, to be paid to the 
prevailing party in equal amounts by the losing party and the losing party's attorney 
on any claim or defense at any time during a civil proceeding or action in which 
the court finds that the losing party or the losing party's attorney knew or should 
have known that a claim or defense when initially presented to the court or at any 
time before trial: 
(a) Was not supported by the material facts necessary to establish the 
claim or defense; or 
(b) 
Would ...

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"Section 57 .105 does not require a finding of frivolousness to justify sanctions, but only a 
finding that the claim lacked a basis in fact or law" and "does not require a party to show complete 
absence of a justiciable issue of fact or law." Martin County Conservation Alliance v. Martin 
County, 73 So. 3d 856, 865 (Fla. 1st DCA 2011) (finding that "Courts are not at liberty to disregard 
the legislative mandate that courts shall impose sanctions in cases without foundation in material 
fact or law. The word "shall" in § 57.105, Fla. Stat., evidences the legislative intent to impose a 
mandatory penalty to discourage baseless claims, by placing a price tag on losing parties who 
engage in these activities. Section 57 .105 expressly states courts "shall" assess attorney's fees for 
bringing, or failing to dismiss, baseless claims or defenses."). 
In determining an award of sanctions under § 57 .105, the trial court's findings "must be 
based on substantial competent evidence" and the trial court "must make an inquiry into what the 
losing party knew or should have known during the fact-establishment process, both before and 
after the suit was filed." See Trust Mortg., LLC c. Fer/anti, 193 So. 3d 997 (Fla. 4th DCA 2016). 
II. 
THE STATE ATTORNEY'S AMENDED MOTION IS NEITHER IN VIOLATION 
OF THE 21-DAY SAFE HARBOR PROVISION IN FLA. STAT.§ 57.105(4), NOR 
WAS THE AMENDED MOTION MOOT UPON FILING. 
"Section 57.105(4), Florida Statutes creates an opportunity to avoid the sanction of 
attorney's fees by creating a safe period for withdrawal or amendment of meritless allegations and 
claims." Davis v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th DCA 2019). Specifically, the relevant 
portion of the Statute states: 
A motion by a party seeking sanctions under this section must be served but may 
not be filed with or presented to the court unless, within 21 days after service of the 
motion, the challenged paper, claim, defense, contention, allegation, or de...

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fees with notice and the opportunity to withdraw or abandon a frivolous claim before sanctions are 
sought." MC Liberty Express, Inc. v. All Points Servs., 252 So. 3d 397,404 (Fla. 3d DCA 2018). 
Here, Plaintiff contends that the State Attorney "did not serve his Amended Motion at any 
time before filing it, and thus failed to comply with the 21-day notice provision .... " [See, Plaintiff's 
Memorandum of Law in Response to Amended Motion for Attorneys' Fees, p.6.]. Plaintiff claims 
that for this reason the Amended Motion should be denied and cites in support, Lago v. Kame By 
Design, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013) (holding that "if a party files a subsequent 
or amended motion for sanctions under section 57 .105 and raises an argument that was not raised 
in the original motion for section 57 .105 sanctions, the subsequent motion must independently 
comply with the twenty-one-day 'safe harbor' provision of Section 57.105(4)."). 
The instant case is distinguishable from Lago1. In Lago, because the case was still active 
when the plaintiff's amended motion for attorneys' fees was filed and was not served on the 
defendant in compliance with the 21-day safe harbor provision before it was filed with the court, 
pursuant to § 57 .105, the defendant was entitled to notice and an opportunity to change its position 
and withdraw its offending motion before being subject to sanctions. 
Here, despite Plaintiff's decision to drop the State Attorney as a party, the Florida Rules of 
Civil Procedure and the courts of Florida are clear: Because Rule 1.250 specifies that a party is 
dropped "in the manner provided for voluntary dismissal in Rule 1.420(a)(l)," dropping a party 
therefore "operates as an adjudication on the merits." See, Siboni v. Allen, 52 So. 3d 779, 781 
(Fla. 5th DCA 2010); Rule 1.420(a)(l) Fla. R. Civ. P. Notably, Plaintiff admits that "the entire 
1 Notably, the court in Lago v. Kame By Design, LLC, 120 So. 3d 73, 75 (Fla. 4t...

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action, which necessarily included Count I [of the First Amended Complaint], was dismissed as to 
[the State Attorney] on October 21, 2020. [See, Plaintiff's Memorandum of Law in Response to 
Amended Motion for Attorneys' Fees, p.7 .]. Nonetheless, as a result of dropping the State Attorney 
from the case, Plaintiff not only effectively made an admission that its allegations against the State 
Attorney have no basis in fact or law, but also concluded the case as to the State Attorney and 
thereby became the losing party in this action. 
Consequently, unlike the fact scenario and timeline in Lago, because Plaintiff concluded 
the instant litigation by dropping the State Attorney from the action before the filing of the 
Amended Motion, it was impossible to give Plaintiff an opportunity to respond and withdraw its 
Count I of the First Amended Complaint since Plaintiff had already done so, thus there can be no 
violation of the 21-day safe harbor provision set forth in Fla. Stat. § 57 .105( 4 ). Based on the 
foregoing, the State Attorney's Amended Motion does not violate the 21-day safe harbor provision 
because Plaintiff dropped him from the action prior to the filing of the Amended Motion, and 
therefore Plaintiff was not prejudiced by the filing of the Amended Motion. Accordingly, as further 
set forth below, Plaintiff has exposed itself to § 57 .105 attorneys' fees as sanctions for failing to 
drop the State Attorney as a party within the 21-da y safe harbor period. 
Additionally, there is nothing improper about the First Motion for Attorneys' Fees or the 
Amended Motion and no argument or authority has been offered by Plaintiff that would make the 
Amended Motion moot. In fact, amended motions for attorneys' fees are filed consistently as a 
matter of course to include the entirety of fees in a lawsuit. Here, the State Attorney's total legal 
fees were able to be calculated and submitted at the time of filing the Amended Motion. 
Finally, de...

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it fails under the [S]tatute", Plaintiff has failed to provide any supporting authority and there is no 
statutory requirement or language in § 57 .105 that supporting record evidence must exist to 
properly serve a§ 57 .105 demand and motion for attorneys' fees. [See, Plaintiff's Memorandum 
of Law in Response to Amended Motion for Attorneys' Fees, p.8.]. "The central purpose of§ 
57 .105, Fla. Stat., is, and always has been, to deter meritless filings and thus streamline the 
administration and procedure of the courts." Davi'> v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th 
DCA 2019). In this vein, a § 57 .105 demand and accompanying motion for attorneys' fees can be 
filed at any time after a lawsuit is initiated, even directly in response to the filing of a complaint, 
regardless of whether any record evidence exists in support of the§ 57.105 demand. 
Consequently, the foregoing indicates that the State Attorney's First Motion for Attorney's 
Fees, as served and filed, is sufficient under§ 57.105 to seek sanctions from Plaintiff for its failure 
to drop the State Attorney from the instant lawsuit within the 21-day safe harbor provision after 
being notified why its First Amended Complaint had no basis in fact or law. Furthermore, as set 
forth at length above, the State Attorney had no obligation to serve his Amended Motion prior to 
filing it with the Court as Plaintiff had already dropped him from the case when it was filed. 
III. 
THE COMPETENT SUBSTANTIAL EVIDENCE ON THE RECORD SHOWS 
THAT THERE IS NO ARGUABLE BASIS IN LAW OR FACT FOR THE ISSUES 
RAISED IN PLAINTIFF'S COUNT I, WHICH NOT ONLY LACK A GOOD 
FAITH ARGUMENT FOR THE INTERPRETATION OF EXISTING LAW OR 
ESTABLISHMENT OF A NEW LAW WITH A REASONABLE EXPECTATION 
OF SUCCESS, BUT ALSO ARE NEITHER NOVEL OR COMPLEX. 
Here, Plaintiff relies on § 57.105(3)(a), which sets forth a scenario where sanctions are 
improper under the Statute: 
3) Notwithstanding subsections (1) and (2), monetary s...

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new law, as it applied to the material facts, with a reasonable expectation 
o(success. 
Notably, the§ 57.105(3)(a) defense only applies to demands made under§ 57.105(1)(b). 
Accordingly, Plaintiff's attempt to prevent an award of sanctions here only applies to whether 
Plaintiff or Plaintiff's attorney "knew or should have known" that the First Amended Complaint 
"when initially presented to the court or at any time before trial ... (b) would not be supported by 
the application of then-existing law to those material facts necessary to establish their claim." § 
57. JOS(l)(b), Fla. Stat. 
Regarding the disclosure of grand jury materials, Florida Statutes § 905.17( 1) makes clear 
that there is no arguable basis in law that the State Attorney provide the Requested Materials: 
The notes, records, and transcriptions are confidential and exempt from the 
provisions of s. 119.07(1) ands. 24(a), Art. I of the State Constitution and shall be 
released by the clerk only on request by a grand jury for use by the grand jury or 
on order o(the court pursuant to s. 905.27. 
Florida Statutes § 90 5.1 7 (1). Based on the clear language of § 90 5 .1 7 ( 1), Fla. Stat. there can be 
no good faith reasonable expectation of success for the State Attorney to produce and disclose the 
Requested Materials as he lacks the legal authority to obtain and deliver the Requested Materials 
demanded by Plaintiff in Count I of the First Amended Complaint. 
Even if Plaintiff is shielded from § 57.105(1)(b) sanctions based on the§ 57.105(3)(a) 
defense, Plaintiff is nonetheless subject to sanctions under§ 57.105(1)(a), because Plaintiff or 
Plaintiff's attorneys "knew or should have known" that Count I "when initially presented to the 
court or at any time before trial ... (a) was not supported by the material facts necessary to establish 
the claim." Fla. Stat. § 57.JOS(l)(a). Specifically, based on Plaintiff's own research, statutory 
constructive notice, the State Attorney...

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Chief Judge Marx's statements during the June 3, 2020 hearing, Plaintiff and Plaintiff's attorneys 
knew or should have known that Count I of the Amended Complaint was not supported by the 
material facts necessary to establish the claim." See, Fla. Stat. § 57.105(1)(a). 
The material facts showing that Plaintiff has no reasonable expectation of success and is 
unable to establish its claim for declaratory relief have been open, obvious, and apparent to 
everyone involved in this matter from the start. The State Attorney's position has been consistent: 
neither he nor his office has possession, custody, or control of the Requested Materials and 
therefore the declaratory relief sought by Plaintiff seeks materials that are impossible for him or 
his office to produce and he is not a proper party to this action. [See, Def.Ex.A-12 ~~ 3-4]. Again, 
these material facts negating Plaintiff's declaratory relief claim against the State Attorney were 
not only set forth in the June 8, 2020, § 57 .105 Demand Letter, but have been the basis for the 
State Attorney's defense in every pleading, filing, and/or correspondence in this matter. 
Accordingly, Plaintiff knew or should have known that the First Amended Complaint was 
not supported by the material facts necessary to establish the claim for declaratory relief. At the 
very least, Plaintiff should have known that its First Amended Complaint was not supported by 
the material facts after Judge Marx's statements during the June 3, 2020 hearing on Defendant's 
Motion to Dismiss Plaintiff's Count II. During that hearing, Chief Judge Marx drew a bright line 
as to when Plaintiff knew or should have known that Count I of the Amended Complaint had no 
basis in fact or law since the relief sought thereby is impossible for the State Attorney to perform. 
Specifically, Chief Judge Marx made several unequivocal statements on the record putting Plaintiff 
on notice, if they weren't already, that the State Attorney...

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Additionally, Plaintiff's argument for novelty and complexity fails as to Count I, regardless 
of Plaintiff's reliance on "Constitutional provisions and interpretive case law, along with Fla. Stat. 
§ 905.27" ... "to propose a good faith interpretation of existing law in support of its declaratory 
relief claim in Count I." [See, Plaintiff's Memorandum of Law in Response to Amended Motion 
for Attorneys' Fees, p.10.]. The simple fact of the matter is that Count I is neither novel or complex 
because Count I merely seeks declaratory relief and the State Attorney's lack of possession, 
custody, or control in conjunction with § 905.17( 1) creates an impossibility of performance as to 
Count I. Here,§ 905.17(1) is abundantly clear that only the Clerk can release grand jury materials 
pursuant to a court order. The record is likewise clear that not only has the State Attorney never 
had possession, custody, or control of the Requested Materials, but he also lacks any legal authority 
to obtain and deliver the Requested Materials. 
Thus, there is no arguable "good faith" basis in law and/or fact as to Plaintiff's Count I. 
Likewise, under no set of facts does Plaintiff have a reasonable expectation of success against the 
State Attorney in obtaining the Requested Materials because he does not have possession, custody, 
or control over them. 
In fact, Plaintiff acknowledged, admitted, and acquiesced to the 
impossibility of the State Attorney providing the Requested Materials when he was dropped from 
the action. Consequently, sanctions against Plaintiff are appropriate under§ 57.105, Fla. Stat. 
CONCLUSION 
Based on the foregoing, Defendant, Dave Aronberg, as State Attorney of Palm Beach 
County, Florida, respectfully requests the Court enter an order granting his Amended Motion for 
Attorneys' Fees as well as such other and further relief as the Court deems just or proper. 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 

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Arthur I. Jacobs, Esq. 
Fla. Bar No.: 10249 
Richard J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 Fax 
Primary: j aco bsscho lzla w@comcast.net 
Attorneys for Defendant, Dave Aronberg 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 12th day of August, 2021, a copy of the foregoing has 
been electronically filed with the Florida E-File Portal fore-service on all parties ofrecord herein. 
Isl Douglas A. Wyler 
11 

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Def.Ex.A-I 

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••- CASE NUMBER: 502019CA014681XXXXMB Div: AG**** 
Filing# 98869063 E-Filed 11/14/2019 11 :06:37 AM 
IN THE CIRCUIT COURT, 15th 
JUDICIAL CIRCUIT, IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST 
PlaintifC 
v. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida, SHARON R. 
BOCK. as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
I 
------
CASE NO.: 
SUMMONS 
DEFENDANT: 
Dave Aronberg. as State Attorney of 
Palm Beach County, Florida 
401 N. Dixie Highway 
West Palm Beach, Florida 33401 
---
A lawsuit has been filed against you. You have 20 calendar days after this summons is 
served on you to file a written response to the attached Complaint with the Clerk of this 
Court. A phone call will not protect you. Your written response, including the case 
number given above and the names of the parties, must be filed if you want the Court to 
hear your s(de of the case. If you do not file your response on time, you may lose the 
case, and your wages, money, and property may thereafter be taken without further 
warning from the Court. There are other legal requirements. You may want to call an 
attorney right away. If you do not know an attorney, you may call an attorney referral 
service or a legal aid office (listed in the phone book). If you choose to file a written 
response yourself, at the same time you file your written response to the Court you must 
also mail or take a copy of your written response to the: Stephen A Mendelsohn, 
Esquire, Greenberg Traurig, P.A., 5100 Town Center Circle, Suite 400, Boca Raton, 
Florida 33486, Telephone: (561) 955-7600. 
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11 :06:37 AM 

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THE STATE OF FLORIDA 
TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and 
a copy of the Complaint in this lawsuit on the above named Defendant. 
DATED on November , 2019 
Novt5 2019 
Sharon R. Bock 
As Clerk & Comptroller of the Court 
By:_•-~--=--~--,-,----
Deputy Clerk 
IMPORTANTE 
BOUY GMM:IA 
Usted ha sido demandado legalmente. Tiene 20 Dias, contados a partir del recibo de esta 
notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una Hamada 
telefonica no lo protegera. Si usted desea que el tribunal considere su defensa, debe presentar su respuesta 
por escrito, incluyendo el numero del caso y los nombres de las partes interesadas. Si usted no contesta la 
demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado 
de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legales. Si lo desea, puede usted 
consultar a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de 
asistencia legal que aparecen en la guia tclefonica. 
Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante 
el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a la persona denominada 
abajo como "Plaintiff/Plaintiff's Attorney" (Demandante o Abogado del Demandante). 
IMPORTANT 
Des poursuites judiciares ont ete entreprises contre vous. Yous avez 20 jours consecutifs a partir 
de la date de )'assignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce 
tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Yous etes oblige de deposer 
votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nommees ici, si 
vous souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre reponse ecrite dans le 
relai requis, vous risquez de perdre la ca...

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Filing# 98869063 E-Filed l l/14/201911:06:37 AM 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 
COMPLAINT 
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Complaint against 
Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his official capacity ("State 
Attorney"), and Sharon R. Bock, the Clerk of the Court for Palm Beach County, Florida, in her 
official capacity ("Court Clerk"), alleges as follows: 
JURISDICTION 
l . 
This is an action within the exclusive jurisdiction of the Circuit Court pursuant to 
Fla. Stat. Section 26.012(2)(a). 
PARTIES 
2. 
The Palm Beach Post is a daily community newspaper published by Plaintiff CA 
Florida Holdings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. 
3. 
Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth 
Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27 .0 I and 

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has authority in grand jury proceedings pursuant to Fla. Stat. section 27.03. He is sued herein in 
his official capacity as his office is in possession of documents that are the subject of this action. 
4. 
Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach 
County, Florida. She is sued herein in her official capacity as her office is in possession of 
documents that are the subject of this action. 
INTRODUCTION 
5. 
In what is now widely if belatedly recognized as a colossal miscarriage of justice -
which led to the further needless victimization of countless young girls and women- a wealthy, 
politically connected, and powerful financier was not held accountable for, nor even forced to 
confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein's 2008 
deal with the State of Florida was not consistent with the evidence gathered against him, what 
remains shrouded in mystery is how that evidence was presented - and the extent to which it was 
presented - to the grand jury that returned an indictment far more limited in scope than expected 
and deserved. 
6. 
Through this action, The Palm Beach Post seeks public access to the testimony, 
minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled 
during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for 
example, in order to prevent the flight of those whose indictment may be contemplated and their 
ability to conceal or destroy evidence; to ensure jurors' candor in deliberations_: and to protect an 
accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law 
expressly authorizes the disclosure of grand jury proceedings under certain circumstances, 
including, as here, in the furtherance of justice. Fla. Stat. § 905. 2 7 ( 1 )( c ). 
7. 
It can no longer credibly be maintained that continued blanket secrecy over the...

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To the contrary, transparency is required to promote public understanding of the criminal justice 
system and public confidence in the fair administration of justice. As detailed below, Epstein was 
accused of sexually abusing and trafficking dozens of women and girls in south Florida (among 
other locations) over a period of several years while exploiting his wealth and political connections 
to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury 
proceedings will shed light on the extent to which those in our government entrusted with the 
solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties 
in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated 
like others accused of similar heinous crimes. or (2) as appears more likely to be the case, those 
who chose to give Epstein favorable- "wtusual," in the words of the Town of Palm Beach Police 
Chief - treatment, are exposed and held accountable. From what limited information is now in the 
public domain, the State Attorney's referral to the grand jury - which would be out of the ordinary 
for this type of case - gives rise to a strong inference of favoritism and corresponding disregard 
for the rights of the minor victims of Epstein's sex trafficking. Access to the grand jury materials 
will allow the public to determine whether the grand jury process, and the secrecy that comes with 
it, was used to further justice or, instead, operated to shield Epstein and his co-conspirators from 
the consequences of their criminal activities. Accordingly, Fla. Stat. Section 905.27 authorizes the 
disclosure of Epstein's 2006 grand jury proceedings. 
8. 
Even in the absence of such a statutory basis, this Court is empowered to order 
public disclosure pursuant to its inherent authority and supervisory powers over the grand jury. 
Indeed, courts throughout the country ...

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as here, many of the details of Epstein's criminal misdeeds have already been made available in 
the public domain through extensive news reporting by, among others, The Palm Beach Post; by 
the many civil suits brought against Epstein and his co•conspirators; and by the victims themselves. 
9. 
In recognition of the sensitivity of the materials being sought, and in the interest of 
protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to 
copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County 
grand jury first being submitted to this Court for in camera review, where they may be redacted, 
as appropriate, to protect those who deserve such protection. 
FACTUAL BACKGROUND 
10. 
The following facts were gathered, in large part, from documents obtained by 
The Palm Beach Post through various Florida Public Records Law requests, documents unsealed 
or publicly available in other related judicial proceedings, and information and documents in the 
public record. 
A. 
First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 
2005-2008. 
1 I. 
The investigation into Epstein's sex crimes began more than fourteen years ago, 
when a 14•year•old girl's stepmother reported to police in the Town of Palm Beach, Florida, that 
Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein 
required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid 
$300. Epstein was 52 years old at the time. 
12. 
Following this initial report in 2005, the Town of Palm Beach Police, and later. in 
2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and 
seventeen witnesses revealed that the events described by the 14•year•old girl occurred, with 
disturbingly similar details, with each of the other victims. 
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13. 
Both the victim/witness interviews, as well as evidence retrieved following a search 
of Epstein's home, showed that some of the girls involved were under the age of 18. The police 
search of Epstein's residence also found two hidden cameras and, throughout the house, large 
numbers of nude photos of girls, including victims whom the police had not interviewed in the 
course of their investigation. 
14. 
In March 2006, a State grand jury was scheduled at which all of the victims were 
expected to testify. The proceeding was postponed, however, due to meetings between the State 
Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan 
Dershowitz. 
15. 
Another grand jury was convened in April 2006, but canceled the day before it was 
to begin receiving evidence. 
(l) 
Police Chief Reiter's Letter to the State Attorney. 
16. 
On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a 
"personal and confidential" letter to then Palm Beach County State Attorney, Barry Krischer, 
stating: 
I must renew my prior observation to you that I continue to find your office's 
treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to 
communicate in this manner, but my most recent telephone calls to you and those 
of the lead detective to your assigned attorneys have been unanswered and 
messages remain unreturned. After giving this much thought and consideration. 
I must urge you to examine the unusual course that your office's handling of this 
matter has taken and consider if good and sufficient reason exists to require your 
disqualif,cationfrom the prosecution of these cases. (Emphasis supplied) 
17. 
Chief Reiter' s letter to State Attorney Krischer enclosed the Town of Palm Beach 
Police Department's probable cause affidavits charging Epstein and two of his assistants with 
multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested 
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that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges 
against him, which would be public. 
(2) 
The Juh' 2006 State Grand Jurv Presentation. 
18. 
Instead. State Attorney Krischer elected to refer the case to a grand jury, which is 
mandatory for capital cases but rarely used for all other crimes. According to an official 
spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm 
Beach County. 
19. 
In July 2006, after State Attorney Krischer presented testimony and evidence from 
one victim. the grand jury returned an indictment on a sole count of solicitation of prostitution. 
There is no mention in the indictment of the victim being a minor. 
20. 
On infom1ation and belief, a second of Epstein's victims was supposed to testify 
before the grand jury, but was unable to attend because of a school exam. 
21. 
No reasonable explanation has been provided as to why the numerous other known 
victims were not presented as witnesses and crime victims to the grand jury convened in July 2006. 
Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was 
initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do 
so. 
22. 
On information and belief, during the grand jury appearance of the single victim 
who testified, the State Attorney presented evidence that vilified the victim and attacked her 
credibility, including soliciting testimony regarding underage drinking and questionable personal 
behavior that was unrelated to tile charges against Epstein. Further upon information and belief, 
tllis information was initially brought to the attention of the State Attorney's office by Epstein's 
defense counsel. 
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(3) 
The FBI's Investigation and Epstein's Non-Prosecution 
Agreement With Federal Authorities. 
23. 
On information and belief, following the deficient July 2006 indictment, and with 
Chief Reiter's encouragement, the FBI began its own investigation of Epstein. 
24. 
Records unsealed in 2015 revealed that the FBJ compiled reports on "34 confirmed 
minors" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI, 
a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. However, at the 
request of Epstein's lawyers, the indictment was never presented to a federal grand jury. 
25. 
Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta, 
negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with 
four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal 
charges. 
26. 
Throughout the remainder of 2007 and through the first half of 2008, Epstein's 
lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon infonnation and 
belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept 
confidential and under seal, and (3) all grand jury subpoenas (including one that had already been 
issued for Epstein's computers) be withdrawn. 
27. 
On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of 
prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was 
sentenced to 18 months in jail, followed by a year of community control or house arrest, and was 
adjudicated as a convicted sex offender required to register twice a year in Florida. 
28. 
The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to 
receive immunity from federal sex-trafficking charges that could have sent him to prison for life. 
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On infonnation and belie(. based on public records, former State Attorney Krischer communicated 
with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers. 
29. 
Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for 
which he was convicted. Instead, he was placed in a private wing of the Palm Beach County 
Stockade, where, after 3 I,,2 months, he was allowed to leave the jail on "work release" for up to 
12 hours a day, 6 days a week. His private driver provided his transportation to and from "work." 
30. 
Epstein was released five months early. 
31. 
Upon infonnation and belief, Epstein violated the terms of his probation, but was 
not prosecuted. 
(4) 
The Crime Victims' Rights Act Litigation. 
32. 
Epstein's victims only learned after the fact about his plea in State court and filed 
an emergency petition to force federal prosecutors to comply with the Crime Victims' Rights Act 
(18 U.S.C. § 3771, '"CVRA"), which mandates certain rights for crime victims, including the right 
to be infonned about plea agreements and the right to appear at sentencing. U.S. District Judge 
Kenneth A Marra recently ruled that federal prosecutors violated the CVRA by failing to notify 
Epstein's victims before allowing him to plead guilty to only the two State offenses. 
33. 
The prosecution's failure to keep the victims apprised, among other things, also 
contravenes the Florida Constitution. Article L § 16(b) and Fla. Stat.§ 960.001. 
34. 
Following publicity exposing the extraordinary leniency of the plea deal, dozens of 
civil suits were brought against Epstein, most of which Epstein's lawyers settled out•of•court. 
35. 
In 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense) 
sex offender in New York, a lifelong designation. In 2011, the New York County District 
Attorney's office unsuccessfully sought to lower his registration to low.risk "level one." 
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36. 
Upon information and belief, during the course of the Town of Palm Beach and FBI 
investigations, Epstein retained private investigators to follow, harass, and photograph his victims 
and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated 
the case against Epstein. 
37. 
Upon information and belief, Epstein's victims were threatened against cooperating 
with law enforcement and told that they would be compensated only if they did not cooperate with 
law enforcement. 
B. 
Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019. 
38. 
On July 6, 2019, Epstein was arrested on federal sex trafficking charges. 
39. 
Upon information and belief, the United States government's investigation of new 
allegations and charges stemmed, in part, from continued press investigations into and reporting 
on the mishandling of the 2006 charges and the civil suits that followed. 
40. 
In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the 
Southern District of New York, Epstein was described as "a serial sexual predator who preyed on 
dozens of minor girls over a period of years." The letter emphasized that "the Government has real 
concerns - grounded in past experience with this defendant - that if allowed to remain out on bail, 
the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this 
case. including victims and their families_. and otherwise attempt to obstruct justice." It also 
described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex 
trafficking in the fonn of "hundreds - and perhaps thousands - of sexually suggestive photographs 
of fully- or partially-nude females," including underage females. In a locked safe, compact discs 
were found with handwritten labels including the descriptions: "Young [Name]+ [Name]," "Misc 
nudes 1," and "Girl pies nude." 
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41. 
On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's 
office for the Southern District of New York charged Epstein with sex trafficking and conspiracy 
to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were 
brought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry 
over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida, 
Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump 
administration, resigned from office. 
42. 
Epstein was denied bail and was placed into pretrial detention at the federal 
Metropolitan Correction Center in lower Manhattan. 
43. 
On August 10, 2019, Epstein was found dead in his cell at the Metropolitan 
Correctional Center. His cause of death was determined to be suicide. 
C. 
The August 27. 2019, SDNY Hearing: Epstein's Victims Speak. 
44. 
On account of his death, prosecutors sought to dismiss the indictment against 
Epstein, while maintaining that they would continue to investigate his co-conspirators. 
45. 
United States Senior District Judge Richard M. Berman ordered a hearing on 
August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to 
speak at the hearing. 
46. 
In the course of the hearing, more than two dozen victims delivered their personal 
stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of 
violent rape by Epstein. Many more victims were present in the courtroom but did not testify. 
47. 
While some questioned the reasoning behind the court's decision to give the victims 
voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred 
vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings 
promote transparency and they provide the court with insights and information wh...

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may not otherwise be aware of." lndeed, even Epstein's defense lawyer noted at the hearing that 
the court "is the institution that most people have confidence in, in these very troubled times." 
48. 
At the August 27th hearing, the girls, now women, spoke about their ''exploitation 
and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme 
poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their] 
behalf.. .. " One victim lamented that "as a victim, [she] never got to see what the agreement was 
or why the special treatment got approved" in the Florida case years earlier. Another noted how 
"completely different" the investigators leading to the 2019 federal indictment were from the 
prosecutors in the Florida case, both in their treatment of her and their investigation of her 
victimization by Epstein. 
49, 
A former federal judge in attendance at the August 27th hearing emphasized that 
"transparency is one of the overriding objectives in our criminal justice system." 
50. 
Nearly all of the victims expressed the conviction that the secrecy that shielded 
Epstein has caused them "irreparable harm" and that an opportunity to address his criminal 
wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for 
at least some measure of justice to be served after his death. Indeed, one victim stated: "'Any efforts 
made to protect Epstein's name and legacy send a message to the victims that he wins and that he 
is untouchable." Another victim expressed fear that this is a world "where there are predators in 
power, a world where people can avoid justice if their pockets run deep enough." In short, the 
''unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and 
connections severely eroded the public's faith in the integrity and impartiality of the criminal 
justice system. 
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D. 
The Palm Beach Post's Standing and the Public Interest. 
51. 
Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm 
Beach County and the Treasure Coast vicinity. 
52. 
The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist 
three other times. 
53. 
Beginning in 2004, The Palm Beach Post has extensively investigated and reported 
on the allegations against, the law enforcement investigation of, and the crimes committed by, 
Epstein and his co-conspirators. The Newspaper's reportage has included publication of the 
following articles: 
• 
"The Man Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends 
and, Investigators Say, Underage Girls.," published on August 14, 2006, reporting that: 
Haley Robson, a local community college student, admitted in a sworn statement to 
police that "she had taken at least six girls to visit Epstein, all between the ages of 14 
and 16;" Palm Beach Police "interviewed five alleged victims and I 7 witnesses;" 
"Dershowitz, the Harvard law professor, traveled to West Palm Beach with information 
about the girls," including social media discussions about "their use of alcohol and 
marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their 
decision to take the case to a grand jury;" Palm Beach Police subsequently "received 
complaints that two of the victims or their families had been harassed or threatened;" 
'"relations between police and prosecutors were fraying" as the investigation continued; 
and "one girl who was subpoenaed - the one who said she had sexual intercourse with 
Epstein - never showed up" to testify before the grand jury. 
• 
"Trump Snags Gosman Estate for $41 Million" published on November 16, 2004, 
reporting on the bidding war between Donald Trump and Jeffrey Epstein for the 
purchase of a "'43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along 
the storied 'Raider's Row'" in Palm Beach. ...

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• 
"After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006, 
reporting that "Palm Beach police thought there was probable cause to charge Epstein 
with unlawful sex acts with a minor and lewd and lascivious molestation." The article 
further reported that "Police Chief Michael Reiter was so angry with State Attorney 
Barry Krischer's handling of the case that he wrote a memo suggesting the county's 
top prosecutor disqualify himself," and identified a 20-year-old on-the-record female 
source who said '"she gave Epstein a massage in the nude, then brought him six girls, 
ages 14 to 16, for massage and sex-tinged sessions at his home." 
• 
"Police Say Lawyer Tried to Discredit Teenage Girls" published on July 29, 2006, 
reporting that "[f]amed Harvard law professor Alan Dershowitz met with the Palm 
Beach County State Attorney's Office and provided damaging information about 
teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein, 
sexually charged massages" and that "[t]he state attorney's office said it presented the 
Epstein case to a county grand jury this month rather than directly charging Epstein 
because of concerns about the girls' credibility." 
• 
"Expert: Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006, 
reporting that "[r]ather than file charges, the state attorney's office presented the case 
to a county grand jury" which "indicted Epstein last week on a single, less serious 
charge of felony solicitation of prostitution," and that "'[t]he case raised eyebrows 
because the state attorney's office rarely, if ever, kicks such charges to a grand jury." 
• 
"Epstein Camp Calls Female Accusers Liars" published on August 8, 2006, reporting 
that "[a] state attorney's spokesman would say only that the office refers cases to the 
grand jury when there are issues with the viability of the evidence or witnesses' 
credibility." 
• 
"Palm Beach Chief Focus of Fire ...

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offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their 
investigation of Epstein, which they had taken to a grand jury." 
• 
"Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on 
August 13, 2008, reporting that ''[d]uring his first month of confinement" Epstein was 
visited by Sarah Kellen, who allegedly escorted victims "upon their arrival at his Pahn 
Beach waterfront home to an upstairs room, where she prepared the massage table and 
provided the oils for their encounters" with Epstein, and by Nadia Marcinkova, "a 
young woman whom Epstein purportedly described as his Yugoslavian sex slave." 
• 
"Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published on July 
I, 2008, reporting that Epstein "is allowed to leave the Palm Beach County Stockade 
six days a week on a work-release program." 
• 
"Women Want Epstein Sex Plea Deal Unsealed" published on June 10, 2009, reporting 
that attorneys for women suing Epstein in various courts "want his [non-prosecution] 
agreement [NP A] with federal prosecutors unsealed" and were moving to unseal the 
agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces 
at least a dozen civil lawsuits in federal and state courts filed by young women who 
said they had sex with him and now are seeking damages." On that date, The Palm 
Beach Post moved to intervene in the matter for the purpose of obtaining public access 
to the NPA, which was ordered disclosed by this Court on June 25, 2009. 
• 
"Epstein's Secret Pact With Feds Reveals 'Highly Unusual' Terms" published on 
September 19, 2009, reporting that, owing to Epstein's non-prosecution agreement, 
"federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein 
pleaded guilty to prostitution-related felonies in state court" and "also agreed not to 
charge any of Epstein's possible co-conspirators: Sarah Kellen, Adriana Ross...

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• 
"'Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims' 
Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge 
Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's 
teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had 
dropped plans to prosecute the billionaire on dozens of federal charges in connection 
with the girls' claims that he paid them for sex at his Palm Beach mansion." 
• 
"Epstein Indicted On Sex Charges/Part•Time Palm Beacher Pleads Not Guilty to Sex 
Trafficking, Conspiracy Charges In Federal Court In Manhattan" published on July 9, 
2019, reporting on Epstein's appearance in U.S. District Court for the Southern District 
of New York in which he "pleaded not guilty to charges accusing him of creating a vast 
network of girls as young as 14 that he exploited for his sexual pleasure at his homes 
in Palm Beach and Manhattan." 
A true and correct copy of the above news articles, in either the computerized format in which they 
are maintained in The Palm Beach Post's electronic archives or the news print edition in which 
originally published, is annexed hereto as Exhibit 1. 
54. 
The press has a constitutional right of access to criminal proceedings, see, e.g., 
Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal 
proceedings. Newman v. Grad.dick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the 
judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in 
proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Pub!. 
Co. v. Lewis, 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in 
matters concerning the closure of judicial proceedings). Tue press also has a First Amendment 
interest in receiving information from willing speakers. See Va. Pharmacy Bd v. Va. Con...

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has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing 
to convey the infonnation to her"), 
55. 
Because of the unique role performed by the press as a "public surrogate" (Lewis, 
426 So. 2d at 6--7) in protecting the right of access and its interest in reporting information about 
criminal proceedings, news organizations "presumptively have a right to access judicial records," 
Comm 'r, Ala. Dep'tofCorr. v. Advance Local ]1,fedia, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), 
and "standing to question the validity of an order restricting publicity because its ability to gather 
news is directly impaired or curtailed." Lewis, 426 So. 2d at 4; see also Carlson v. United States, 
837 F.3d 753, 757-58 (7th Cir. 2016) c·[a]s a member of the public, [the Reporters Committee] 
has standing to assert [its] claim" to grand jury materials because such materials are "public records 
to which the public may seek access, even if that effort is ultimately unsuccessful"). 
56. 
Here, the continued denial of access to information The Palm Beach Post seeks on 
behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury." 
Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also 
Zerilli v. Smith, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press' function as a vital 
source of information is weakened whenever the ability of journalists to gather information is 
impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand 
jury materials). 
E. 
The Court's Supervision of the Grand Jurv Process and Its Authoritv to Order 
Public Disclosure of the Epstein Evidence. 
5 7. 
The Florida Supreme Court has noted that "in states such as Florida, where the 
grand jury is preserved, it is an important appendage of the court which impanels it. At the same 
time it should not be forgotten that the judge of th...

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maintain the dignity and the integrity of both the grand jury and the presiding judge.'' State v. 
Clemons, l 50 So. 2d 231, 233-34 (Fla. 1963 ). 
58. 
Chapter 905 of the Florida Statutes governs the empanelment and conduct of 
Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury 
about its legal duties. Fla. Stat. § 905.18. 
59. 
Florida Stat. Section 905.27(1) provides that ''the testimony of a witness examined 
before the grand jury ... or other evidence received by it" may be disclosed "when required by a 
court ... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by 
the witness before the court; (b) Determining whether the witness is guilty of perjury~ or (c) 
Furthering justice." Fla. Stat. § 905.27(l)(a)-(c). 
60. 
Further, disclosure is appropriate pursuant to this Court's inherent authority over 
grand jury proceedings because of the exceptional public interest in this case and the compelling 
circumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 ("'a district court 
has the inherent power to disclose [grand jury] materials in exceptional circumstances and ... 
historic importance can be a sufficient reason when there is little countervailing need for secrecy"). 
COUNTI 
(Florida Stat. Section 905.27) 
61. 
Based on information learned by The Palm Beach Post through its Florida Public 
Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence 
and proceedings, judicial documents obtained from independent but related court proceedings, and 
documents otherwise available in the public record, the State Attorney for Palm Beach County 
presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner 
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that precluded his indictment for the serious crimes he committed, including sex trafficking and 
sexual assault. 
62. 
Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's 
victims and the public, and to provide public disclosure to illuminate whether Epstein received 
unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests 
immediate public access to the testimony, minutes, and other evidence presented in 2006 to the 
Palm Beach County grand jury. In a case of this magnitude and importance, where the accused is 
dead and so many of his crimes, as well as the identities and crimes of his co-conspirators, and the 
identities of the victims have already been exposed, the need for grand jury secrecy is no more. 
See United States v. Socony-Vacuum Oil Co., 310 U.S. 150,234 (1940) ("[A]fter the grand jury's 
functions are ended, disclosure is wholly proper where the ends of justice require it."). 
WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla. 
Stat. Section 905.27(1) and the Court's inherent authority, order the State Attorney and the Clerk 
of the Court to file with this Court copies of the testimony, minutes, and other evidence presented 
in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so 
that, following an in camera inspection, it can be made available to The Palm Beach Post and the 
public on an expedited basis, and grant any other and further equitable or legal relief the Court 
deems just and proper. 
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Dated: November 14, 2019 
ACTIVE 45678709v3 
Respectfully submitted, 
GREENBERG TRAURIG, P.A. 
Attorneys for CA Florida Holdings, LLC, 
Publisher of The Palm Beach Post 
Stephen A. Mendelsohn, Esq. 
5100 Town Center Circle, Suite 400 
Boca Raton, Florida 33486 
Telephone: (561) 955-7629 
Facsimile: (561) 338-7099 
By: Isl Stephen A. 1\Jendelsohn 
STEPHEN A MENDELSOHN 
Florida Bar No. 849324 
mcndds:ihns:a)'..'tlaw.com 
hasenh@gtlaw.com 
FLService@gtlaw.com 
By: Isl Michael J Gngiel 
MICHAEL J GRYGIEL 
(Pro Hae Vice application forthcoming) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile: (518) 689-1499 
grvgi~Jm,:d.Q"tlm.v.com 
By: Isl Vincent H Chieffo 
VINCENT H. CHIEFFO 
(Pro Hae Vice application forthcoming) 
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Telephone: (310) 586 7700 
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NINA D. BOY AJIAN 
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19 

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EXHIBIT 1 
The Newspaper's Reportage on Jeffrey Epstein 

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The Palm Beach Post 
REAL NEWS STARTS IDE 
The Man Who Had Everything: Jeffrey Epstein craved big 
homes, elite friends and underage girls 
By Andrew.Marra 
Posted Jul 17, 2019 at 6:02 AM 
From the archives: When Palm Beach detectives started asking 
questions and teenage girls started talking, a wave of legal resistance 
followed. 
Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after 
Jeffrey Epstein's arrest in Palm Beach County on a charge of felony solicitation of prostitution. 
WINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach mansion. Inside, 
hidden cameras trolled two rooms, while the girls came and went. 
For the police detectives who sifted through the garbage outside and kept records of visitors, it 
was the lair of a troubling target. 
Epstein, one of the most mysterious of the country's mega-rich, was known as much for his 
secrecy as for his love of fine things: magnificent homes, private jets, beautiful women, 
friendships with the world's elite. 
But at Palm Beach police headquarters, he was becoming known for something else: the 
regular arrival of teenage girls he hired to give him massages and, police say, perform sexual 
favors. 
Epstein was different from most sexual abuse suspects; he was far more powerful. He counted 
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along 
with some of the most prominent legal, scientific and business minds in the country. 
When detectives started asking questions and teenage girls started talking, a wave oflegal 
resistance followed. 

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>> NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work-
...... - •• ------········-----·•-T••- ... ···--··········---····· ................ a_ ................................................................................................................................... ~···················• ... , •••• _. __ ++•-• .. ••• ....................... + 
release 
If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough. 
Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends 
quietly, always in the background as he navigated New York high society. 
When he first attracted notice in the early 1990s, it was on account of the woman he was 
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. 
In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the British 
Mail on Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a 
math teacher, a concert pianist or a corporate headhunter. 
"But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both 
flamboyant and intensely private." 
The media frenzy did not begin in full until a decade later. In September 2002, Epstein was 
flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to 
Africa on his private jet. 
Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair 
published lengthy profiles. The New York Post listed him as one of the city's most eligible 
•••u••••••••-•••••••••••••••••• ••••••••--••••••••T 
•••••••••n•o••••••••n•ooOOOOOOO 
bachelors and began describing him in its gossip columns with adjectives such as "mysterious" 
and "reclusive." 
Although Epstein gave no interviews, the broad strokes of his past started to come into focus. 
Building a life of extravagance 
He was born blue-collar in 1953, the son of a New York City pa...

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• In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J. 
Epstein and Co. That is when he began making his millions in earnest. 
Little is known or said about Epstein's business except this: He manages money for the 
extremely wealthy. He is said to handle accounts only of $1 billion or greater. 
It has been estimated he has roughly 15 clients, but their identities are the subject of only 
speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a 
former Palm Beacher who is said to have been a mentor to Epstein. 
Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a 
block on Manhattan's Upper East Side. It is reported to have, among its finer features, closed-
circuit television and a heated sidewalk to melt away fallen snow. 
That townhouse, thought to be the largest private residence in Manhattan, is only a piece of 
the extravagant world Epstein built over time. 
In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch 
outside Santa Fe. Many believed it to be the largest home in the state. 
In Palm Beach, he bought a waterfront home on El Brillo Way, And he owns a 100-acre 
private island in the Virgin Islands. 
>> PHOTOS: The players in the Jeffrey Epstein saga 
Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at 
the highest echelons of power. This includes not only socialites but also business tycoons, 
media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often 
funds. 
"Just like other people collect art, he collects scientists," said Martin Nowak, who directs the 
Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of 
a $30 million research donation from Epstein. 
Epstein is said to have befriended former Harvard President Larry Summers, prominent law 
Professor Alan Dershowitz, Do...

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And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely 
photographed. 
"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials 
and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article. 
Epstein's friendship with Clinton has attracted the most attention. 
Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at 
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become 
close friends until after Clinton left the Oval Office and moved to New York. 
Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John 
Kerry's presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the 
Senate bids of Joe Lieberman, Hillary Rodham Clinton, Christopher Dodd and Charles 
Schumer. 
Powerful friends and enemies 
A Vanity Fair profile found cracks in the veneer of Epstein's life story. The 2003 article said he 
.,,, ••••••••••• ,,,,.,,,, •••• ,,,, •••••••••••••••••....••.• + •• -- •• 
left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange 
Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20 
million loan. 
The article suggested that one of his business mentors and previous employers was Steven 
Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million 
in one of the largest Ponzi schemes in American history." 
As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the 
man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less 
than $16,000 in furnishings. 
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of 
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein 
owed him not...

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"It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the 
retired former president of Williams Electronics and Sega Corp. "Suffice it to say I have 
nothing good to say about him." 
Among the characteristics most attributed to Epstein is a penchant for women. 
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York 
and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian 
model. 
"He's a lot of fun to be with,'' Donald Trump told New York magazine in 2002. "It is even said 
that he likes beautiful women as much as I do, and many of them are on the younger side. No 
doubt about it, Jeffrey enjoys his social life." 
Investigation leads to Epstein 
Although he was not a frequenter of the Palm Beach social scene, he made his presence felt. 
Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and 
$100,000 to Ballet Florida. 
In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green 
Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a 
private chef and a small staff stood at the ready. From a window in his mansion, he could look 
out on the lntracoastal Waterway and the West Palm Beach skyline. He seemed to be a man 
who had everything. 
But extraordinary wealth can fuel extraordinary desires. 
>> Epstein wants to leave jail for mansion in sex-trafficking case 
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·-
In March 2005, a worried mother contacted Palm Beach police. She said another parent had 
overheard a conversation between their children. 
Now the mother was afraid her 14-year-old daughter had been molested by a man on the 
island. 
The phone call triggered an extensive investigation, one that would lead detectives to Epstein 
but leave them frustrated. 

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Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm 
Beach police report detailing the criminal probe offers a window into what detectives faced as 
they sought to dose in on Epstein. 
Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to 
perform a massage. She said the friend told her to say she was 18 if asked. At the house, she 
said she was paid $300 after stripping to her panties and massaging the man while he 
masturbated. 
Police interview 5 alleged victims 
The investigation began in full after the girl identified Epstein in a photo as the man who had 
paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift 
through it. They set up a video camera to record the comings and goings at his home. They 
monitored an airport hangar for signs of his private jet's arrivals and departures. 
They quickly learned that the woman who took the 14-year-old girl to Epstein's house was 
Haley Robson, a Palm Beach Community College student from Loxahatchee. In a sworn 
statement at police headquarters, Robson, then 18, admitted she had taken at least six girls to 
visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said. 
During the drive back to her house, Robson told detectives, 'Tm like a Heidi Pleiss." 
Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls 
said they had been instructed to have sex with another woman in front of Epstein, and one said 
she had direct intercourse with him. 
In October, police searched the Palm Beach mansion. They discovered photos of naked, young-
looking females, just as several of the girls had described in interviews. Hidden cameras were 
found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school 
transcript. 
Two of Epstein's former employees told investigators that young-looking gir...

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One employee told detectives he was told to send a dozen roses to one teenage girl after a high 
school drama performance. Others were given rental cars. One, according to police, received a 
$200 Christmas bonus. 
The cops moved to cement their case. But as they tried to tighten the noose, they encountered 
other forces at work. 
In Orlando they interviewed a possible victim who told them nothing inappropriate had 
happened between her and Epstein. They asked her whether she had spoken to anyone else. 
She said yes, a private investigator had asked her the same questions. 
>> Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal 
When they subpoenaed one of Epstein's former employees, he told them the same thing. He 
and a private eye had met at a restaurant days earlier to go over what the man would tell 
investigators. 
Detectives received complaints that private eyes were posing as police officers. When they told 
Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the 
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William 
Kennedy Smith. 
While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law 
professor, traveled to West Palm Beach with information about the girls. From their own 
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about 
their use of alcohol and marijuana. 
He took his research to a meeting with prosecutors in early 2006, where he sought to cast 
doubt on the teens' reliability. 
The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only 
did some of the girls have issues with drugs or alcohol but also some had criminal records and 
other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she 
told police she was younger than 18 when she started performing massages for Epstein. 
After the meeting, prosecutor...

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In the following weeks, police received complaints that two of the victims or their families had 
been harassed or threatened. Epstein's legal team maintains that its private investigators did 
nothing illegal or unethical during their research. 
By then, relations between police and prosecutors were fraying. At a key meeting with 
prosecutors and the defense, Detective Joseph Recarey, the lead investigator, was a no-show, 
according to Epstein's attorney. 
"The embarrassment on the prosecutor's face was evident when the police officer never 
showed up for the meeting," attorney Jack Goldberger said. 
Later in April, Recarey walked into a prosecutor's office at the state attorney's office and 
learned the case was taking an unexpected turn. 
The prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein 
a plea deal that would not require him to serve jail time or receive a felony conviction. 
Recarey told her he disapproved of the plea offer. 
The deal never came to pass, however. 
Future unclear after charge 
On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four 
counts of unlawful sexual activity with a minor and to charge his personal assistant, Sarah 
Kellen, now 271 for her alleged role in arranging the visits. Police officials also wanted to 
charge Robson, the self-described Heidi Pleiss, with lewd and lascivious acts. 
By then, the department was frustrated with the way the state attorney's office had handled the 
case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter 
wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if 
he would not act. 
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to 
the grand jury. 

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It is not known how many of the girls testified before the grand jury. But Epstein's defense 
team said one girl who was subpoenaed - the one who said she had sexual intercourse with 
Epstein - never showed up. 
The grand jury's indictment was handed down in July. It was not the one the police 
department had wanted. 
Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was 
charged with one count of felony solicitation of prostitution, which carries a maximum penalty 
of five years in prison. He was booked into the Palm Beach County Jail early July 23 and 
released hours later. 
Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But 
he said their claims that they had sexual encounters with him lack credibility. 
"They are incapable of being believed," he said. "They had criminal records. They had 
accusations of theft made against them by their employers. There was evidence of drug use by 
some of them." 
What remains for Epstein is yet to be seen. 
The Palm Beach Police Department has asked the FBI to investigate the case. It also has 
returned the $90,000 Epstein donated in 2004. 
In New York, candidates for governor and state attorney general have vowed to return a total 
of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful 
friends have remained silent as tabloids and Internet biogs feast on the public details of the 
police investigation. 
Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future 
plea deal. He insists Epstein will emerge in the end with his reputation untarnished. 
"He will recover from this," he said. 
Staff writer Larry Keller and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and 
Melanie Mena contributed to this story. 
amarra@pbpost.com 

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@AMarraPBPost 

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273 / 278 - Tuesday, November 16, 2004 
Edition: FINAL 
Section: A SECTION 
Page: lA 
Source: By PAUL OWERS Pahn Beach Post Staff Writer 
Illustration: PHOTO (C & 2 B&W) & MAP (B&W) 
Memo: Ran all editions. 
Dateline: WEST PALM BEACH 
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION 
When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The 
Donald was not about to be trumped. 
''Nobody was going to outbid me," the brash developer-turned-TV-personality said from his 
New York office. 
Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot, 
seven-bedroom estate on 6 oceanfront acres along the storied "Raider1s Row." 
But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at 
513 N. County Road. He wants to - what else? - sell it and make more money. 
The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super 
luxury house" that would be the "finest anywhere in the United States." He might build 
another house before flipping the entire package. 
"I've known about this house for quite some time," Trump said. 
11lt's probably the best piece 
ofland in Florida - and probably the country - for luxury real estate." 
Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor 
Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith 
said she's not worried about Trump's plans. 
"He's been a very good property owner in the town of Palm Beach," she said. "He does his 
projects very well. He's a perfectionist." 
Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of 
Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual 
distribution to creditors. 
The auction began at exactly noon after Judge Steven Friedman dismissed an objection from 
an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfu...

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But Friedman allowed the offer to stand, and Pulte and Trump went back and fo1th until 
Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at 
$38.6 million. 
Friedman closed the bidding IO minutes after it started, leaving Trump with the right to buy 
the 29,000-square-foot home (a typical Palm Beach County single-family house is about 
2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service 
quarters. 
The closing could take place within a week but probably won't happen until next month. 
Trustee Joe Luzinski and creditors said they were pleased with the outcome. 
"We knew we were dealing with some substantial people ... who were going to bid it up a 
bit," Luzinski said. 
"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank. 
"In bankruptcy court, the idea is to get the most for creditors, and that's what happened." 
The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer 
former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't 
receive a commission, he said. 
Pulte, 42, of Boca Raton, said he figured Trump wouldn't back do~n Monday. 
"I got the feeling he was willing to go a lot higher, and I didn't want to chase it1" Pulte said. 
Pulte said Gosman asked him before the auction whether he would be willing to let him stay 
in the mansion after the closing W1til he decides where he wants to move. Trump and 
Luzinski said they have had no such discussions with Gosman. 
Gosman, 75, had the house built after paying $12.1 million for the land in 1986. 
The former health-care magnate declined interview requests before and after the auction 
Monday. He was at the courthouse but left before the auction took place. 
The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm 
Beach home and guest house but falls short of the $45 million th...

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The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife 
an ownership interest in his home and other belongings only to avoid losing them in 
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in 
1999, well before he filed for bankruptcy. 
Lessen is expected to rule in the next two months whether Gosman made improper transfers, 
a decision that will affect how much money will be available to creditors. 
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were 
willing to move forward, in part because the upkeep of the estate now exceeds their means. 
11This is not a happy occasion for them, but at least we're moving to the next level," Cimo 
said. "That's not a house you want to live in unless you
1re making large amounts of money 
like Donald Trump." 
paul_ owers@pbpost.com 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Indictment: Billionaire Solicited 3 Times 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 2, 2019 at 2:30 PM 
(EDITORS NOTE: Th is story originally published in The Palm Beadt Post on July 25, 
2006) 
Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein 
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 
oflast year, according to an indictment charging him with felony solicitation of 
prostitution. 
Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He 
was released on $3,000 bond. 
Epstein's case is unusual in that suspected prostitution johns are usually charged 
with a misdemeanor, and even a felony charge is typically made in a criminal 
information - an alternative to an indictment charging a person with the 
commission of a crime. 
His attorney,Jack Goldberger, declined to discuss the charge. 
State attorney's office spokesman Mike Edmondson also had little to say. 
"Generally speaking, there is a case that has a number of different aspects to it," 
Edmondson said of a prostitution-related charge being submitted to a grand jury. 
"We first became aware of the case months ago by Palm Beach police.~ 
Prosecutors and police worked together to bring the case to the grand jury, he 
said. 
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Palm Beach police confirmed that and said the department will release a report 
today regarding its investigation. 
Epstein has owned a five-bedroom, 7 112-bath, 7,234-square-foot home with a 
pool and a boat dock on the lntracoastal Waterway since 1990, according to 
property records. A man answering the door there Monday said that Epstein 
wasn't home. A Cadillac Escalade registered to him was parked in the driveway, 
which is :flanked by two massive gargoyles. 
Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the 
assessment of his home exceeded its fair market value. He dismissed his lawsuit 
in December 2002. 
A profile of Epstein in Vanity Fair magazine said he owns what are believed to 
be the largest private homes in Manhattan - 51,000 square feet - and in New 
Mexico - a 7 ,500-acre ranch. Those are in addition to his 70-acre island in the 
U.S. Virgin Islands and fleet of aircraft. 
Epstein's friends and admirers, according to the magazine, include prominent 
businessmen, academics and scientists and famed Harvard law professor Alan 
Dershowitz. 
larry_keller@p_~_£OSt.com 
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The Palm Beach Post 
REAL NEWS STARTS HERE 
After long probe, billionaire faces solicitation 
charge 
Posted Jul 27, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 3:11 PM 
(EDITOR'S NOTE: This story originally published in The Palm Beadt Post on July 26, 
2006) 
Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young 
women brought to his home, where he received massages and sometimes sex, 
according to an investigation by the Palm Beach Police Department. 
Palm Beach police spent months sifting through Epstein's trash and watching his 
waterfront home and Palm Beach International Airport to keep tabs on his 
private jet. An indictment charging Epstein, 53, was unsealed Monday, charging 
him with one count of felony solicitation of prostitution. 
Palm Beach police thought there was probable cause to charge Epstein with 
unlawful sex acts with a minor and lewd and lascivious molestation. 
Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's 
handling of the case that he wrote a memo suggesting the county's top 
prosecutor disqualify himself. 
"I must urge you to examine the unusual course that your office's handling of this 
matter has taken and consider if good and sufficient reason exists to require your 
disqualification from the prosecution of these cases," Reiter wrote in a May 1 
memo to Krischer. 
While not commenting specifically on the Epstein case, Mike Edmondson, 
spokesman for the state attorney, said his office presents cases other than 
murders to a grand jury when there are questions about witnesses' credibility and 
their ability to testify. 
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By the nature of their jobs, police officers look at evidence from a "one-sided 
perspective," Edmondson said. "A prosecutor has to look at it in a much broader 
fashion," weighing the veracity of witnesses and how they may fare under 
defense attorneys' questioning, he said. 
Epstein's attorney,Jack Goldberger, said his client committed no crimes. 
"The reports and statements in question refer to false accusations that were not 
charged because the Palm Beach County state attorney questioned the credibility 
of the witnesses," Goldberger said. A county grand jury "found the allegations 
wholly unsubstantiated and not credible," and that's why his client was not 
charged with sexual activity with minors, he said. 
Goldberger said Epstein passed a lie detector test administered by a reputable 
polygraph examiner in which he said he did not know the girls were minors. 
Also, a search warrant served on Epstein's home found no evidence to 
corroborate the girls' allegations, Goldberger said. 
According to police documents: 
- A Palm Beach Community College student said she gave Epstein a massage in 
the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged 
sessions at his home. 
- A 27-year-old woman who worked as Epstein's personal assistant also 
facilitated the liaisons, phoning the PBCC student to arrange for girls when 
Epstein was coming to town. And she escorted the girls upstairs when they 
arrived, putting fresh sheets on a massage table and placing massage oils nearby. 
- Police took sworn statements from five alleged victims and 17 witnesses. They 
contend that on three occasions, Epstein had sex with the girls. 
A money manager for the ultra-rich, Epstein was named one of New York's most 
eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with 
the likes of form...

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He has contributed tens of thousands of dollars to Democratic Party candidates 
and organizations, including Sen. John Kerry's presidential bid, and the Senate 
campaigns of Joe Lieberman, Hillary Clinton, Christopher Dodd and Charles 
Schumer. 
Goldberger is one of five attorneys Epstein has retained since he became the 
subject of an investigation, Edmondson said. Among the others: Alan 
Dershowitz, the well-known Harvard law professor and author, who is a friend 
of Epstein. Dershowitz could not be reached for comment. 
Police said the woman who enlisted young girls for Epstein was Haley Robson, 
20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in 
Wellington and said she was a journalism major at Palm Beach Community 
College when she was questioned by police last October. She has an unlisted 
phone number and could not be reached for comment. 
Robson said she met Epstein when, at age 17, a friend asked her if she would like 
to make money giving him a massage, She said she was driven to his five-
bedroom, 7 t/2-bath home on the lntracoastal Waterway, then escorted upstairs 
to a bedroom with a massage table and oils. Epstein and Robson were both naked 
during the massage, she said, but when he grabbed her buttocks, she said she 
didn't want to be touched. 
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Epstein said he'd pay her to bring him more girls - the younger the better, 
Robson told police. When she tried once to bring a 23-year-old woman to him, 
Epstein said she was too old, Robson said. 
Robson, who has not been charged in the case, said she eventually brought six 
girls to Epstein who were paid $200 each time, Robson said. "I'm like a Heidi 
Fleiss," police quoted her as saying. The girls knew what to expect when they 
were taken to Epstein's home, Robson said. Give a massage - maybe naked- and 
allow some touching. 
One 14-year-old girl Robson took to meet Epstein led police to start the 
investigation of him in March 2005. A relative of the girl called to say she 
thought the child had recently engaged in sex with a Palm Beach man. The girl 
then got into a fight with a classmate who accused her of being a prostitute, and 
she couldn't explain why she had $300 in her purse. 
The girl gave police this account of her meeting with Epstein: 
She accompanied Robson and a second girl to Epstein's house on a Sunday in 
February 2005. Once there, a woman she thought was Epstein's assistant told the 
girl to follow her upstairs to a room featuring a mural of a naked woman, several 
photographs of naked women on a shelf, a hot pink and green sofa and a massage 
table. 
She stripped to her bra and panties and gave him a massage. 
Epstein gave the 14-year-old $300 and she and the other girls left, she said. She 
said Robson told her that Epstein paid her $200 that day. 
Other girls told similar stories. In most accounts, Epstein's personal assistant at 
the time, Sarah Kellen, now 27, escorted the girls to Epstein's bedroom. 
Kellen, whose most recent known address is in North Carolina, has not been 
charged in the case. 
Palm Beach police often conducted surveillance of Epstein's home, and at Palm 
Beach International Airpor...

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from Palm Beach sanitation workers, collecting papers with names and phone 
numbers, sex toys and female hygiene products. 
One note stated that a female could not come over at 7 p.m. because of soccer. 
Another said a girl had to work Sunday - "Monday after school?" And still 
another note contained the work hours of a girl, saying she leaves school at 11:30 
a.m. and would come over the next day at 10:30 a.m. 
Only three months before the police department probe began, Epstein donated 
$90,000 to the department for the purchase of a firearms simulator, said Jane 
Struder, town finance director. The purchase was never made. The money was 
returned to Epstein on Monday, she said. 
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Palm Beach Daily News 
Police say lawyer tried to discredit teenage 
girls 
Posted Jul 29, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 2:00 PM 
(EDITOR'S NOTE: This story originally was published in The Palm Beadt Post on July 
29, 2006) 
Famed Harvard law professor Alan Dershowitz met with the Palm Beach County 
State Attorney's Office and provided damaging information about teenage girls 
who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually 
charged massages, according to police reports. 
The reports also state that another Epstein attorney agreed to a plea bargain that 
would have allowed Epstein to have no criminal record. His current attorney 
denies this happened. 
And the documents also reveal that the father of at least one girl complained that 
private investigators aggressively followed his car, photographed his home and 
chased off visitors. 
Police also talked to somebody who said she was offered money if she refused to 
cooperate with the Palm Beach Police Department probe of Epstein. 
The state attorney's office said it presented the Epstein case to a county grand 
jury this month rather than directly charging Epstein because of concerns about 
the girls' credibility. The grand jury indicted Epsteini 53, on a single count of 
felony solicitation of prostitution, which carries a maximum penalty of five years 
in prison. 
Police believed there was probable cause to charge Epstein with the more serious 
crimes of unlawful sex acts with a minor and lewd and lascivious molestation. 
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry 
Krischer a memo in May suggesting he disqualify himself from the case. 
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1/.4 

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t'Ollce say rawyer meo 10 0Iscreo11 teenage gins - NeWS - t'aIm 1:1eacn ua11y News• t'a1m 0eacn, t-L 
The case originally was going to be presented to the grand jury in February, but 
was postponed after Dershowitz produced information gleaned from the Web 
site myspace.com showing some of the alleged victims commenting on alcohol 
and marijuana use, according to the police report prepared by Detective Joseph 
Recarey. 
Haley Robson, a 20-year-old Royal Palm Beach woman who told police she 
recruited girls for Epstein, also is profiled on myspace.com. Her page includes 
photos of her and her friends, including one using the name "Pimpin' Made EZ." 
Robson, who was not charged in the case, is a potential prosecution witness. 
According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys 
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with 
Epstein, accepted the deal, in which Epstein would plead guilty to one count of 
aggravated assault with intent to commit a felony, be placed on five years' 
probation and have no criminal record. The deal also called for Epstein to submit 
to a psychiatric and sexual evaluation and have no unsupervised visits with 
minors, according to Recarey's report. The plea bargain was made in connection 
with only one of the five alleged victims, the report states. 
Fronstin - who declined to comment on the case - was subsequently fired and 
veteran defense attorney Jack Goldberger was hired. He denies there was any 
agreement by any of Epstein's attorneys to a plea deal. 
"We absolutely did not agree to a plea in this case," he said. Neither Belohlavek 
nor a state attorney's spokesman could be reached for comment. 
The parent or parents of alleged victims who complained of being harassed by 
private investigators provided license tag numbers of two of the men. Police 
found the vehicles were registered to a private eye in West Palm Beach and 
another in Jupiter, according to Re...

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t-'011ce say Iawyer ureo to 01screon teenage gms - News - t-'&lm ljeacn uauy News - t-'a1m ~aa,, r- L 
who did talk ''will be dealt with," the woman said she was told. Phone records 
show the woman talked with the person who allegedly intimidated her around 
the time she said, Recarey reported. 
Phone records also show that the person said to have made the threat then 
placed a call to Epstein's personal assistant, who in turn called a New York 
corporation affiliated with Epstein, the report states. 
The issue in the Epstein case is not whether females came to his waterfront 
home, but whether he knew their ages. 
"He's never denied girls came to the house," Goldberger said. But when Epstein 
was given a polygraph test, "he passed on knowledge of age," the attorney said. 
After the indictment against Epstein was unsealed this week, Police Chief Reiter 
referred the matter to the FBI. "We've received the referral, and we're reviewing 
it," said FBI spokeswoman Judy Orihuela in Miami. 
The chief himself has come under attack from Epstein's lawyers and friends in 
New York, where he has a home. The New York Post quoted Epstein's 
prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted 
only "because of the craziness of the police chief." 
Reiter has declined to comment on the case. 
Prosecutors have not presented a sex-related case like Epstein's to a grand jury 
before, said Mike Edmondson, spokesman for the state attorney's office. "That's 
what you do with a case that falls into a gray area," he said. 
The state attorney's office did not recommend a particular criminal charge on 
which to indict Epstein, Edmondson said. The grand jury was presented with a 
list of charges from highest to lowest, then deliberated with the prosecutor out of 
the room, he said. 
"People are surprised at the grand jury proceeding," West Palm Beach defense 
attorney Richard Tendler said. "It's a way for the prosecutor's office to not take 
the ...

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ll/"II/LU"ll1 
t-'once say Iawyer meo 10 mscrean 1eenage gms • News - t-'a1m oeacn va1iy News - t-'aJm i::ieacn, r-L 
Defense attorney Robert Gershman was a prosecutor for six years. "Those girls 
must have been incredible or untrustworthy, I don't know," he said. 
Other attorneys said Epstein's case raises the issue of whether wealthy, connected 
defendants like Epstein - whose friends include former President Clinton and 
Donald Trump - are treated differently from others. Once he knew he was the 
subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as 
Dershowitz and Lefcourt, who is a past president of the National Association of 
Criminal Defense Lawyers. 
Miami lawyer Roy Black - who became nationally known when he successfully 
defended William Kennedy Smith on a rape charge in Palm Beach - also was 
involved at one point. 
Said defense attorney Michelle Suskauer: "I think it's unfortunate the public may 
get the perception that with power, you may be treated differently than the 
average Joe." 
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4/4 

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The Palm Beach Post 
Rf.AL NEWS STARTS HOE 
Expert: Ignorance of age isn't 
defense in sex cases 
Posted Aug 5, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 1 :38 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Aug. 5, 2006) 
Even if Palm Beach money manager Jeffrey Epstein didn't 
know that girls who police say gave him sexual massages at 
his lntracoastal home were under the legal age1 that alone 
wouldn't have exempted him from criminal charges of 
sexual activity with minors. 
"Ignorance is not a valid defense," said Bob Dekle, a legal 
skills professor who was a Lake City prosecutor for nearly 
30 years, half of that time specializing in sex crimes against 
children. 
"There is no knowledge element as far as the age is 
concerned," Dekle said. 
After an 11-month investigation, Palm Beach police said 
there was probable cause to charge Epstein, 53, with 
unlawful sex acts with a minor and lewd and lascivious 
molestation. They contend that Epstein - friend of the rich 
and famous and financial patron of Democratic Party 
organizations and candidates - committed those acts with 
five underage girls. 
In the past week, New York Attorney General and 
gubernatorial candidate Eliot Spitzer has returned about 
$50,000 in campaign contributions he received from 
Epstein, and Mark Green, a candidate to replace Spitzer in 

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his current job, has returned $10,000 to him because of the 
Palm Beach scandali the New York Daily News has 
reported. 
Rather than file chargesi the state attorney's office 
presented the case to a county grand jury. The panel 
indicted Epstein last week on a single, less serious charge of 
felony solicitation of prostitution. 
The case raised eyebrows because the state attorney's office 
rarely, if ever, kicks such charges to a grand jury. And it 
increases the difficulty of prosecuting child sex abuse cases, 
especially when the defendant is enormously wealthy and 
can hire high-priced, top-tier lawyers. 
At least one of Epstein's alleged victims told police he knew 
she was underage when the two of them got naked for 
massages and sexual activity. She was 16 years old at the 
time and said Epstein asked her questions about her high 
school, according to police reports. 
A girl who said she met Epstein when she was 1 S said he 
told her if she told anybody what happened at his house, 
bad things could happen, the police reports state. 
Epstein's youngest alleged victim was 14 when she says she 
gave him a massage that included some sexual activity. She 
is now 16. The girl's father says he doesn't know whether 
she told Epstein her age. 
"My daughter has kept a lot of what happened from me 
because of sheer embarrassment," he said. aBut she very 
much looked 14. Any prudent man would have had second 
thoughts about that." 
Defense attorney Jack Goldberger maintains that not only 
did Epstein pass a polygraph test showing he did not know 
the girls were minors, but their stories weren't credible. 
The state attorney's office also implied that their credibility 
was an issue when it decided not to charge Epstein directly, 
but instead give the case to the grand jury. 

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"A prosecutor has to look at it in a much broader fashion," a 
state attorney's spokesman said last week. 
#t ; e;c . 
.IP& 
Epstein hired Harvard law Professor Alan Dershowitz 
when he became aware he was under investigation, and 
Dershowitz gave prosecutors information that some of the 
alleged victims had spoke of using alcohol and marijuana on 
a popular W eh site, according to a Palm Beach police 
report. 
Prosecutors typically consider two things in deciding 
whether to charge somebody with sex-related offenses 
against minors - whether there is sufficient evidence and 
whether there is a public interest in doing so, Dekle said. 
If two teens are in a sexual relationship and the boy turns 
18 before the girl, he could be charged with a sex crime if 
the sex continues. There would be no public interest in 
pursuing that, Dekle said. 
But where there is a large gap in ages - and especially in 
cases of teachers with students - there is a public interest in 
prosecuting, he said. Likewise if the accused has a track 
record of sex with minors. 

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Still there is a "universal constant" in prosecuting these 
cases, Dekle said. Men who exploit underage children for 
sex often carefully choose their victims in ways that will 
minimize the risk to themi he said. 
Victims usually are from a lower social status, and they may 
suffer from psychological problems, Dekle said. 
"Lots of child sexual abuse victims have been victimized by 
multiple people over a period of time. Then the act of abuse 
produces behavior in the victims that further damages their 
credibility." Examples include promiscuous behavior and 
drug abuse. 
Some of the alleged victims in the Epstein case returned to 
his home multiple times for the massage sessions and the 
$200 to $300 he typically paid them per visit. "That would 
be a definite problem for the prosecutor," said Betty Resch, 
who prosecuted crimes against children in Palm Beach 
County for five years and now is in private practice in Lake 
Worth. 
"The victim becomes less sympathetic" to a jury, Resch said. 
aBut she's a victim nevertheless. She's a kid." 
Most men charged with sex crimes against minors look 
normal, Dekle said. A jury expecting to see a monster 
seldom will. And the victims' ages work against them and in 
favor of the defendant in a trial, Dekle said, 
If a child and an adult tell different stories and both swear 
they're telling the truth, adult jurors are more likely to 
believe the adult, Dekle said. 
"You have all these things working against you in a child 
sex abuse case. Prosecutors normally try to be very careful 
in filing those cases because they know what they're getting 
into. There is no such thing as an iron-dad child sexual 
abuse case." 

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The Palm Beach Post 
REAL NEWS STARTS & 
Epstein camp calls female accusers 
liars 
Posted Aug 8, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 3:35 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Aug. 8, 2006) 
Attorneys and publicists for Palm Beach financier Jeffrey 
Epstein went on the offensive Monday, contending that 
teenage girls who have accused Epstein of sexual 
shenanigans at his waterfront home are liars and saying 
that the Palm Beach Police Department is "childish." 
"There never was any sex between Jeffrey Epstein and any 
underage women," his lead attomey,Jack Goldberger, said 
from Idaho where he was vacationing with his family. 
Epstein did have young women come to his house to give 
him massages, Goldberger said. "Mr. Epstein absolutely 
insisted anybody who came to his house be over the age of 
18. How he verified that, I don't know. The question is, did 
anything illegal occur. The law was not violated here." 
He had no explanation as to why Epstein would pay girls or 
women with no massage training - as the alleged victims 
said was the case - $200 to $300 for their visits. "The 
credibility of these witnesses has been seriously 
questioned," Goldberger said. 
Epstein, 53, was indicted by a county grand jury last month 
on a charge of felony solicitation of prostitution. After an 
11-month investigation that included sifting through 
Epstein's trash and surveilling his home, Palm Beach police 
concluded there was enough evidence to charge him with 
sexual activity with minors. When the grand jury indicted 

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Epstein on the less serious charge, Police Chief Michael 
Reiter referred the case to the FBI to determine whether 
there were federal law violations. 
After a spate of stories about the case last week, New York 
publicist Dan Klores - whose client list has included Paris 
Hilton and Jennifer Lopez - said on Saturday that Epstein's 
camp was ready "to get their story out. n 
They did that Monday via Goldberger and a Los Angeles 
publicist for Miami criminal defense attorney Roy Black, 
who also has represented Epstein in the case. 
"We just think there has been a distorted view of this case 
in the media presented by the Palm Beach police," 
Goldberger said. 
Reiter has consistently declined to comment on the case 
and did not respond to a request for comment Monday. 
The implication that State Attorney Barry Krischer was 
easy on Epstein by presenting the case to a grand jury 
rather than filing charges directly against him is wrong, 
Goldberger said. 

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The Palm Beach Police Department was "happy and 
ecstatic" that the panel was going to review the evidence. "I 
think what happened is they weren't happy with the result. 
They decided to use the press to embarrass Mr. Epstein." 
But records show that Reiter wrote Krischer on May 1 -
well before the case went to the grand jury - suggesting that 
Krischer "consider if good and sufficient reason exists to 
require your disqualification from the prosecution of these 
cases." 
Rather than flat-out decline to charge Epstein, Krischer 
referred the case to the grand jury to "appease" the chief, 
Goldberger said. 
A state attorney's spokesman would say only that the office 
refers cases to the grand jury when there are issues with the 
viability of the evidence or witnesses' credibility. 
Both the state attorney and the grand jury concluded there 
was not sufficient evidence that Epstein had sex with 
minors, according to Goldberger. "It was just a childish 
performance by the Palm Beach Police Department," 
Goldberger said. 
The defense attorney said one of the alleged victims who 
claimed she was a minor was in fact over the age of 18. 
Another alleged victim who was subpoenaed to testify to 
the grand jury failed to do so. Epstein's accusers, he added, 
have histories of drug abuse and thefts. "These women are 
liars. We've established that." 
But why would they all invent their stories about meeting 
Epstein for sexual massages? 
"I don't have an answer as to what was the motivation for 
these women to come forward and make these allegations," 
Goldberger said. 

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The Palm Beach Post 
REAL NEWS STAIR'S HBIE 
Delays in Epstein case unusual, 
lawyers say 
Posted Mar 13, 2007 at 12:01 AM 
Updated Oct 3, 2019 at 3:48 PM 
(EDITORS NOTE: This story originally published in The Palm 
Beach Post March 13, 2007) 
A federal probe or a plea deal could explain the wait in the 
Palm Beacher's solicitation case. 
Nearly eight months after Palm Beach tycoon Jeffrey 
Epstein was charged. with felony solicitation of prostitution, 
there has been no discernible progress in his case. No 
witnesses deposed. No trial date set. Nothing, save for 
routine court hearings reset without explanation. 
"Usually that would be unusual," said criminal defense 
attorney Glenn Mitchell, who has no involvement in the 
case. 
"As a general rule, it would be unusual for nothing to have 
happened,» agreed Michael Dutko, a criminal defense 
attorney in Fort Lauderdale. He represents Haley Robson, 
20, of Royal Palm Beach, potentially a key witness in the 
case. 
A routine hearing for Epstein was pulled from the court 
docket last week and reset for May 16. The delays and 
inaction could be due to a potential federal probe of Epstein 
or because a plea deal is in the works, attorneys say. 
Unusual is the word that best describes everything about 
the case against Epstein, 54, an enigmatic money manager 
in New York City who counts Bill Clinton and Donald 
Trump among his friends. 

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"Highly unusual" is how Palm Beach Police Chief Michael 
Reiter described State Attorney Barry Krischer's handling 
of the case in a bluntly critical letter to Krischer last year 
before Epstein was indicted. 
Reiter referred the matter to the FBI to determine whether 
any federal laws had been violated. Epstein's allies 
countered by attacking the chief personally and 
professionally. 
Reiter's department investigated Epstein for 11 months. 
Police sifted repeatedly through his trash and conducted 
surveillance on his five-bedroom, 7 1/2-bath, 7,234-square-
foot home on the lntracoastal Waterway. 
Police said Epstein paid women and girls as young as 14 to 
give him erotic massages at his home. Police thought there 
was probable cause to charge him with unlawful sex acts 
with a minor and lewd and lascivious molestation. 
Epstein responded by hiring a phalanx oflawyers. One of 
them, Harvard law professor and author Alan Dershowitz, 
provided the state attorney's office with information about 
alcohol and marijuana use by some of the girls who said 
they were with Epstein. 
Prosecutors then referred the case to the grand jury rather 
than file charges directly against Epstein. 
Epstein's attorneys deny he had sex with underage girls. 
The lawyers say the girls' stories are not credible. But if the 
court file is any indicator, they've made no effort to depose 
the girls. 
Neither prosecutors nor defense attorneys have sought to 
question Robson, said Dutko, her attorney. She recruited 
teenage girls to visit Epstein for massages and sexual 
activity, Palm Beach police said, and presumably would be a 
key witness. 

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Epstein's attorney Jack Goldberger did not return phone 
messages. 
A source close to the case suggested it is languishing 
pending a decision by the FBI on whether to refer it to 
federal prosecutors. 
"We still have a pending case," FBI spokeswoman Judy 
Orihuela said Monday. 
State Attorney Krischer did not return a call for comment. 
His spokesman1 Mike Edmondson, declined to say whether 
federal investigators are delaying the Epstein case. But1 he 
added, "if another agency is looking at something, we 
wouldn't want to step on their toes." 
Attorneys say inertia in a criminal case often points to a 
pending plea deal. 
"It would not surprise me if something has happened that's 
not reflected in the court file," said Dutko, such as an 
agreement that will be formalized later. 
Defense attorney Marc Shiner said defense attorneys 
sometimes put off overtly conducting discovery-- deposing 
witnesses, requesting documents and the like -- because 
doing so creates more work for harried prosecutors who 
may become angry and not offer a plea deal. 
"Sometimes defense lawyers, knowing that, will try and do 
discovery without taking depositions," said Shiner, a former 
prosecutor for 13 years. 
Instead, they may conduct a below-the-radar probe such as 
having a private investigator check out leads, he said. 
Shiner and others say a plea deal for Epstein probably 
would result in pretrial intervention, in which a defendant 
may be ordered to undergo a psychological evaluation, 
counseling or other conditions in return for dropping the 
charge. 

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Edmondson, spokesman for State Attorney Krischer, said 
there is no plea offer and no request for the prosecution to 
show its cards. 
"To my knowledge, it's never happened before on a filed 
case," he said. 

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252 / 278 - Thursday, October 18, 2007 
Edition: FINAL 
Section: LOCAL 
Page: 5B 
Source: The Associated Press 
Illustration: PHOTO (B&W) 
Memo: Ran all editions. 
Dateline: NEW YORK 
WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16 
A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage 
prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had 
sought his help becoming a model. 
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had 
the teen perform a sex act when she brought photographs of herself for him to review in his Upper 
East Side mansion sometime in 2000. 
Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get 
you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice" 
included massages and other favors. 
When the girl told Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I 
won't tell anybody," court papers say. 
Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been 
indicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending. 
The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural 
sex acts" while she was a minor, the lawsuit says. 
Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends, 
stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her 
40s). I love girls your age.'" 
The young woman, now 23, kept returning to Epstein because she has "mental issues," said her 
lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result 
of severe mental disease and defect." 
Epstein's lawyer in New York, Gerald Lefcourt, said, ''The ...

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The Palm Beach Post 
REAL flEWS STARTS IDE 
Palm Beacher pleads in sex case 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 3, 2019 at 1 :47 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on July 1, 2008) 
Jeffrey Epstein will serve 1 t/2 years on teen solicitation 
charges. 
He lives in a Palm Beach waterfront mansion and has kept 
company with the likes of President Clinton, Prince 
Andrew and Donald Trump, but investment banker Jeffrey 
Epstein will call the Palm Beach County Jail home for the 
next 18 months. 
Epstein, 55, pleaded guilty Monday to felony solicitation of 
prostitution and procuring a person under the age of 18 for 
prostitution. After serving 18 months in jail, he will be 
under house arrest for a year. And he will have a lifelong 
obligation to register as a sex offender. He must submit to 
an HIV test within 48 hours, with the results being 
provided to his victims or their parents. 
As part of the plea deal, federal investigators agreed to drop 
their investigation of Epstein, which they had taken to a 
grand jury, two law enforcement sources said. 
Epstein was indicted two years ago after an 11-month 
investigation by Palm Beach police. They received a 
complaint from a relative of a 14-year-old girl who had 
given Epstein a naked massage at his five-bedroom, 7,234-
square-foot, $8.5 million Intracoastal home. 
Police concluded that there were several other girls brought 
in 2004 and 2005 to an upstairs room at the home for 
similar massages and sexual touching. 

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The indictment charged Epstein only with felony 
solicitation of prostitution. The state attorney's office later 
added the charge of procuring underage girls for that 
purpose. 
Prosecutor Lanna Belohlavek said of the plea: "I took into 
consideration the length the trial would have been and 
witnesses having to testify'' about sometimes embarrassing 
incidents. 
Epstein may have made a serious mistake soon after he was 
charged. He rejected an offer to plead guilty to one count of 
aggravated assault with intent to commit a felony, 
according to police documents. He would have gotten five 
years' probation, had no criminal record and not been a 
registered sex offender, the documents indicate. 
Epstein arrived in court Monday with at least three 
attorneys. He wore a blue blazer, blue shirt, blue jeans and 
white and gray sneakers. After Circuit Judge Deborah Dale 
Pucillo accepted the plea, he was fingerprinted. Epstein 
then removed his blazer and was handcuffed for the trip to 
jail while his attorneys tried to shield him from 
photographers' lenses. 
When he eventually is released to house arrest, Epstein will 
have to observe a 10 p.m. to 6 a.m. curfew, have no 
unsupervised contact with anyone younger than 18 and 
neither own nor possess pornographic or sexual materials 
"that are relevant to your deviant behavior," the judge said. 
Epstein will be allowed to leave home for work. The New 
York-based money manager told the judge he has formed 
the not-for-profit Florida Science Foundation to finance 
scientific research. ''I'm there every day," Epstein said. 
The foundation was incorporated in November. Epstein 
said he already has awarded money to Harvard and MIT. 

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When he is released from jail, there is a chance that Epstein 
will be forced to move. Sex offenders are not allowed to live 
within 1,000 feet of a school, park or other areas where 
children may gather. No determination has been made as to 
whether Epstein's home complies, but attorneys said it 
likely does. 
Sex offenders also typically must attend counseling sessions. 
Belohlavek said that was waived for Epstein because his 
private psychiatrist is working with him. The judge was 
skeptical but agreed to it. 
Epstein's legal woes don't end with Monday's plea. There 
arc four pending federal civil lawsuits and one in state court 
related to his behavior. At least one woman has sued him in 
New York, where he owns a 51,000-square-foot Manhattan 
mans10n. 
"It's validation of what we're saying in the civil cases," said 
Miami attorney Jeffrey Herman, who represents the alleged 
victims in the federal lawsuits. West Palm Beach attorney 
T cd Leopold represents one alleged victim in a civil suit in 
state court. He said he anticipates amending that lawsuit to 
add "a few other clients" as well. 
In the criminal case, police went so far as to scour Epstein's 
trash and conduct surveillance at Palm Beach f nternational 
Airport, where they watched for his private jet so they 
would know when he was in town. They concluded that 
Epstein paid girls $200 to $300 each after the massage 
sessions. 
'Tm like a Heidi Pleiss," Haley Robson, now 22, told police 
about her efforts in recruiting girls for Epstein. 
There was probable cause to charge Epstein with unlawful 
sex acts with a minor and lewd and lascivious molestation, 
police concluded. 

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The state attorney's office said questions about the girls' 
credibility led it to take the unprecedented step of 
presenting the evidence against Epstein to a grand jury, 
rather than directly charging him. 
Palm Beach Police Chief Michael Reiter was furious with 
State Attorney Barry Krischer, saying in a May 2006 letter 
that the prosecutor should disqualify himself. "I continue to 
find your office's treatment of these cases highly unusual," 
he wrote. He then asked for and got a federal investigation. 
Epstein hired a phalanx of high-priced lawyers - including 
Harvard law professor and author Alan Dershowitz - and 
public relations people who questioned Reiter's competence 
and the victims' truthfulness. 
In addition to mansions in Palm Beach and Manhattan, 
Epstein owns homes in New Mexico and the Virgin Islands. 
He's a frequent contributor to Democratic Party candidates. 
He also donated $30 million to Harvard in 2003. 
Former New York Gov. Eliot Spitzer returned a $50,000 
campaign contribution from Epstein after his indictment, 
then resigned this year during his own sex scandal. And the 
same Palm Beach Police Department that vigorously 
investigated Epstein returned his $90,000 donation for the 
purchase of a firearms simulator. 
Staff writer Eliot Kleinberg and former staff researcher 
Michelle Quigley contributed to this story. 

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The Palm Beach Post 
REAL NEWS STARTS HRE 
Jeffrey Epstein: Scientist, 
stuntman, 'sex slave' visit jailed 
tycoon 
By LARRY KELLER / Palm Beach Post Staff Writer 
Posted Aug 13, 2008 at 12:01 AM 
Updated Jul 16, 2019 at 4:54 PM 
Tycoon Jeffrey Epstein mingled with an eclectic mix of 
people, including beautiful young women, before he got 
into trouble for paying teenage girls to give him sexual 
massages at his Palm Beach mansion. 
Not much has changed, even though he now resides in a 
dorm at the Palm Beach County Sheriffs Office's 17-acre, 
967-bed stockade near the fairgrounds. 
During his first month of confinement, Epstein was visited 
by the female assistant who, girls told police, had escorted 
them to the room at his mansion where they gave him 
naked massages. 
Also trekking to the jail was a young woman whom Epstein 
purportedly described as his Yugoslavian sex slave. 
The wealthy financier and science wonk also has been 
visited by an expert on artificial intelligence, as well as a 
man who is a mixed martial arts aficionado and sometime 
movie stuntman. 
The only other people to visit him at the jail, according to 
records, are a Singer Island man and an individual who 
listed Epstein's Palm Beach address as his own. 
Epstein, 55, pleaded guilty on June 30 to two prostitution-
related charges and was sentenced to 18 months in jail, 
followed by a year of house arrest. Epstein paid teenage 

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girls $200 to $300 in 2004 and 2005 for massages in his 
home that sometimes included sexual touching, Palm Beach 
police said. 
His jail visitors in July included: 
- Sarah Kellen, 29, who some of the teen masseuses said 
phoned them when Epstein was in town and escorted them 
upon their arrival at his Palm Beach waterfront home to an 
upstairs room, where she prepared the massage table and 
provided the oils for their encounters with him. Kellen 
visited Epstein three times in July, according to a jail 
visitor's log. Kellen lists a Manhattan home address. 
Reached by telephone, she declined to discuss Epstein. 
- Nadia Marcinkova, 23, whose family in Yugoslavia 
Epstein paid money to so that he could bring her to the 
United States to be his "sex slave," two teenage girls told 
police. One girl told police that Epstein instructed 
Marcinkova and her to kiss and have sex while he watched 
and masturbated. Another said she engaged in sex with 
Marcinkova at Epstein's urging. Marcinkova visited Epstein 
in jail four times in 13 days. She lists her address as on the 
Upper East side of Manhattan, not far from Epstein's 
enormous apartment. 
- Roger Schank, 62, founder of the Institute for Learning 
Sciences at Northwestern University and an expert on 
artificial intelligence, paid one visit to Epstein. Schank has 
written numerous books on that subject and has a doctorate 
degree from Yale University in linguistics. He was one of 19 
people who applied to be president of Florida Atlantic 
University in 2003. He became "chieflearning officer" at the 
online Trump University in 2005. Schank listed his address 
as being in Stuart, and records show he also owns a home 
in Lake Worth. 

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Epstein has financed a number of scientists over the years, 
including Nobel Prize winners. He gave $30 million to 
Harvard University in 2003. In November, he formed the 
not-for-profit Florida Science Foundation, which he said 
finances scientific research. 
- Igor Zinoviev, a Russian mixed martial arts fighter, who 
coaches a Chicago team in the International Fight League. 
He also has worked as a personal trainer, celebrity 
bodyguard and movie stuntman, according to the league's 
Web site. The New Jersey resident visited Epstein seven 
times in July. 
Zinoviev, Schank and Marcinkova could not be reached for 
comment. 
Staff researcher Niels Heimeriks contributed to this story. 

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Palm Beach Daily News 
Billionaire sex offender leaves jail 
six days a week for work 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 4, 2019 at 9:27 AM 
Palm Beach billionaire Jeffrey Epstein, who's serving 18 
months in jail for soliciting an underage girl for 
prostitution, is allowed to leave the Palm Beach County 
Stockade six days a week on a work-release program. 
Teri Barbera, spokeswoman for the Palm Beach County 
Sheriffs Office, confirmed that Epstein, 55, has been in the 
work-release program since Oct. 10. 
"He works six days a week: Friday through Wednesday 10 
a.m. to 10 p.m.," Barbera said via e-mail. "(He) works at his 
local West Palm Beach office, monitored on an active GPS 
system (he wears an ankle bracelet). Mr. Epstein hires a 
permit deputy, at his expense, for his own security at his 
workplace during the time he is out." 
Miami attorney Jeffrey Herman represents six young 
women who've sued Epstein, claiming he sexually abused 
them at his Palm Beach home when they were minors. 
Herman said he received a letter about the work-release 
program from the U.S. Attorney's Office within the past 
few days. But Herman says Epstein had been out on work-
release for several weeks before the notification. 
"My clients expressed shock and disappointment," Herman 
said. "I find it incredible that he's on work-release in the 
community and my clients aren't notified of this and we get 
this letter weeks after the fact." 
Jack Goldberger, Epstein's criminal attorney, said the 

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arrangement is not unusual. 
"He goes to work every single day and goes back to jail at 
night, just like everybody else (in the program)," 
Goldberger said. 
Epstein pleaded guilty June 30 to two felony counts: 
soliciting prostitution and procuring a person under 18 for 
prostitution. As part of the plea agreement, Epstein must 
serve one year of house arrest and register as a lifelong sex 
offender. 

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The Palm Beach Post 
REAL NEWS STARTS HEIE 
Women want Epstein sex plea deal 
unsealed 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 2, 2019 at 2:23 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post June 10, 2009) 
Their attorneys will ask a judge to open Jeffrey Epstein's 
records. 
When wealthy money manager Jeffrey Epstein of Palm 
Beach pleaded guilty last year to procuring teens for 
prostitution, his case detoured around local and state rules 
regarding the sealing of court documents. 
At a plea conference on the state charges, a judge, a defense 
lawyer and a prosecutor huddled at the bench and decided 
that a deal Epstein had struck with federal prosecutors to 
avoid charges should be sealed, according to a transcript of 
the hearing. 
And so it was. 
But Florida rules of judicial administration, as well as rules 
of the Palm Beach County court system, require public 
notification that a court document has been or will be 
sealed, meaning kept from public view. The rules also 
require a judge to find a significant reason to seal, such as 
protecting a trade secret or a compelling government 
interest. 
Yet no notification or reason occurred in Epstein's case, 
according to court records. 

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Epstein's own attorneys, in federal filings, have ref erred to 
his confidential deferred prosecution agreement with the 
U.S. attorney's office, struck in September 2007i as 
"unprecedented" and "highly unusual." And it was "a 
significant inducement" for Epstein to accept the state's 
deal, observed the state judge who accepted his plea, 
County Judge Deborah Dale Pucillo. 
Epstein now faces at least a dozen civil lawsuits in federal 
and state courts filed by young women who said they had 
sex with him and now are seeking damages. 
Attorneys for some of those women want his agreement 
with federal prosecutors unsealed and will ask Circuit Judge 
Jeffrey Colbath to do so today. 
"It is against public policy for these documents to be have 
been sealed and hidden from public scrutiny. As a member 
of the public, E.W. has a right to have these documents 
unsealed/' wrote former Circuit Judge Bill Berger, now in 
private practice and representing one of the women. 
The Palm Beach Post also will ask Colbath to unseal the 
agreement. Post attorney Deanna Shullman will argue that 
the public has a right to know the specifics of Epstein's deal. 
According to various media accounts, Epstein moved in 
circles that included President Clinton, Donald Trump and 
Prince Andrew. "International Moneyman of Mystery," 
declared a 2002 New York magazine profile of Epstein. 
Epstein, 56, is in the Palm Beach County Stockade, serving 
an 18-month sentence after pleading guilty nearly a year 
ago to felony solicitation of prostitution and procuring 
teenagers for prostitution. 
He is allowed out from 7 a.m. to 11 p.m., escorted by a 
deputy, said Palm Beach County Sheriffs Office 
spokeswoman Teri Barbera. 

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During a Palm Beach Police Department investigation, five 
victims and 17 witnesses gave statements. They told of 
young women brought by his assistants to Epstein's 
mansion on El Brillo Way for massages and sexual activity, 
and then being paid afterward. 
At Epstein's plea conference last year, his attorney,Jack 
Goldberger, and then-Assistant State Attorney Lanna 
Belohlavek approached Pucillo in a sidebar conference. 
Pucillo, who had left the bench nine years earlier, was 
filling in temporarily as a senior judge. 
According to a transcript, Goldberger told Pucillo that 
Epstein had entered a confidential agreement with the U.S. 
attorney's office in which federal prosecutors brokered not 
pursuing charges against him ifhe pleaded guilty in state 
court. Pucillo then said she wanted a sealed copy of the 
agreement filed in his case, and Goldberger concurred that 
he wanted it sealed. Belohlavek later signed off on it. 
The Florida Supreme Court has expressed "serious concern" 
and launched an all-out inquiry into sealing procedures 
across the state following media reports in 2006 of entire 
cases being sealed and disappearing from court records, 
"The public's constitutional right of access to court records 
must remain inviolate, and this court is fully committed to 
safeguarding this right," justices wrote in their final report. 
Epstein's office on Tuesday referred any questions to 
Goldberger, who declined to comment. Pucillo also has 
declined to comment. 

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The Palm Beach Post 
REAL OS STARl'S HERE 
Epstein secret pact with Feds 
reveals "highly unusual" terms 
Posted Jun 10, 2009 at 12:01 AM 
Updated Oct 4, 2019 at 9 :23 AM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on September 19, 2009) 
A secret non-prosecution agreement multimillionaire 
financier Jeffrey Epstein struck with federal prosecutors is 
being called "highly unusual" by former federal prosecutors 
and downright outrageous by attorneys now representing 
young women who serviced him. 
The deal reveals that the FBI and the U.S. Attorney's Office 
investigated him for several federal crimes, including 
engaging minors in commercial sex. The crimes are 
punishable by anywhere from 10 years to life in prison. 
But federal prosecutors backed down and agreed to recall 
grand jury subpoenas if Epstein pleaded guilty to 
prostitution-related felonies in state court, which he 
ultimately did. He received an 18-month jail sentencei of 
which he served 13 months. 
The U.S. Attorney's Office also agreed not to charge any of 
Epstein's possible co-conspirators: Sarah Kellen, Adriana 
Ross, Lesley Groff and Nadia Marcinkova. 
The deal was negotiated in part by heavyweight New York 
criminal defense attorney Gerald Lefcourt. 
Unsealed on Friday after attorneys for some of Epstein's 
victims and The Palm Beach Post sought its release, it offers 
the first public look at the deal Epstein's high-powered legal 
counsel brokered on his behalf. 

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Mark Johnson of Stuart, a former federal prosecutor, 
described the disparity in potential sentences as unusual, 
but even more so a provision on attorney payment. 
The first draft of the agreement in September 2007 
required that Epstein pay an attorney-- tapped by the U.S. 
Attorney's Office and approved by Epstein -- to represent 
some of the victims. That attorney is prominent Miami 
lawyer Bob Josefsberg. 
But an addendum to the agreement signed the following 
month struck Epstein's duty to pay Josefsberg ifhe and the 
victims did not accept settlements -- capped at $150,000 --
and instead pursued lawsuits. 
Johnson said it appears the government was trying to 
balance the lesser sentence for Epstein with recovering 
$150,000 for each victim. "I've never, ever seen anything 
like that in my life," he said. "It's highly unusual." 
The deal does not say whether any victims were contacted 
or consulted before the deal was made. 
Attorney Brad Edwards of Port Lauderdale, who represents 
three of the young women, believes that none of the 30 to 
40 woman identified as victims in the federal investigation 
were told ahead of time. Edwards said his clients received 
letters from the U.S. Attorney's Office months after the deal 
was signed, assuring them Epstein would be prosecuted. 
"Never consulting the victims is probably the most 
outrageous aspect of it," Edwards said. "It taught them that 
someone with money can buy his way out of anything. It's 
outrageous and embarrassing for United States Attorney's 
Office and the State Attorney's Office.'' 
Epstein now faces many civil lawsuits filed by the women, 
who are represented by a variety of attorneys. In many, the 
allegations are the same: that Epstein had a predilection for 
teenage girls, identified poor, vulnerable ones and used 

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other young women to lure them to his Palm Beach 
mansion. They walked away with between $200 and 
$1,000. 
Former Circuit Judge Bill Berger, also representing victims, 
called the agreement a "sweetheart deal" 
"Why was it so important for the government to make this 
deal?'' Berger asked rhetorically. "We have not yet had an 
honest explanation by any public official as to why it was 
made ... and why the victims were sold down the river." 
Former federal prosecutor Ryon McCabe described the 
agreement as "very unorthodox." Such agreements, he said, 
are usually reserved for corporations, not individuals. 
''It's very, very rare. I've never seen or heard of the 
procedure that was set up here," said McCabe, who has no 
involvement in any Epstein litigation. 
"He's essentially avoiding federal prosecution because he 
can afford to pay that many lawyers to help those victims 
review their cases .... If a person has no money, he couldn't 
be able to strike a deal like this and avoid federal 
prosecution." 
The backroom deal with federal prosecutors is all the more 
interesting in light of the legal powerhouses who have 
worked for Epstein, including Harvard professor Alan 
Dershowitz and Bill Clinton investigator Kenneth Starr. 
Lefcourt is a past president of the National Association of 
Criminal Defense Lawyers. 
Epstein's local defense attorney,Jack Goldberger, issued a 
statement Friday saying he had fought the release of the 
sealed agreement to protect the third parties named there. 
"Mr. Epstein has fully abided by all of its terms and 
conditions. He is looking forward to putting this difficult 
period in his life behind him. He is continuing his long-
standing history of science philanthropy." 

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The investigation triggered tensions between police and 
prosecutors, with then-Palm Beach Chief Michael Reiter 
saying in a May 2006 letter to then-State Attorney Barry 
Krischer that the chief prosecutor should disqualify himself. 
"I continue to find your office's treatment of these cases 
highly unusual," Reiter wrote. He then asked for and got 
the federal investigation that ended in the sealed deal. 
"The Jeffrey Epstein matter was an experience of what a 
many-million-dollar defense can accomplish," Reiter told 
the Palm Beach Daily News upon his retirement. 

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187 / 278 - Wednesday, January 27, 2010 
Edition: FINAL 
Section: LOCAL & BUSINESS 
Page:3B 
Source: By JANE MUSGRAVE Palm Beach Post Staff Writer 
Dateline: WEST PALM BEACH 
JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS 
In a decision that could spark a constitutional showdown over privacy rights, a judge 
Tuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to 
subpoena abortion records from women who are seeking millions in damages from the part-
time Palm Beach resident. 
Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut 
the women's claims that they suffered psychological ills after being paid to give him 
sexually-charged massages at his Palm Beach mansion when they were as young as 14. 
Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records, 
he said, can't be sought until the women are asked whether they have ever had an abortion, 
how many and where. Further, he said, the records would not be made public and might not 
be admissible during trial. 
But, he said, since the women claim Epstein, now 57, is responsible for their emotional 
distress, his attorneys can explore the impact of other events. Medical records, Hafele said, 
are a better source of information than a person's memory. 
Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm 
Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky 
constitutional grounds. 
"These records are protected by our constitutional right of privacy," he said, referring to the 
Florida Constitution. 
After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the 
records. 
In another ruling Wednesday, Hafele also said that videos from depositions in the state cases 
can't be released without a court order. The ruling came after Epstein attorney Robert Critton 
complained that ...

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The Palm Beach Post 
REAL NEWS STARTS HEIE 
Epstein Journal's Findings Could 
Resurrect Case 
By Jane.Musgrave 
Posted Sep 17, 2019 at 12:01 AM 
Updated Oct 1, 2019 at 1 0:51 AM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on March 20, 2010) 
A purloined journal that is said to contain the names of 
''hundreds" of victims of convicted sex offender Jeffrey 
Epstein could be used to reopen the investigation into the 
multi-millionaire's appetite for teenage girls, an attorney 
representing seven of the victims said Friday. 
New details about the contents of the journal were released 
this week when Alfredo Rodriguez, who worked as a 
property manager for the Palm Beach resident, pleaded 
guilty to obstruction of justice for lying to federal agents 
when asked if he had any information about his former 
boss' criminal activity. He later tried to sell the journal he 
stole from Epstein for $50,000 to an unidentified person, 
who alerted authorities, according to court records. 
As part of the plea agreement, federal prosecutors said the 
journal "contains information material to the Epstein 
investigation, including the names of material witnesses 
and additional victims." 
"Had the items been produced in response to the inquiries 
of state or federal authorities ... the materials would have 
been presented to the federal grand jury," federal 
prosecutors wrote. 

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Instead, prosecutors short-circuited the grand jury 
investigation and cut a deal with Epstein. They agreed not 
to pursue federal charges ifhe didn't contest prostitution-
related felonies in state court. The money manager pleaded 
guilty in July 2008 to procuring a minor for prostitution 
and soliciting prostitution. He served 13 months of an 18-
month sentence. 
Attorney Adam Horowitz, who represents seven of the 
roughly 18 women who have filed civil suits against 
Epstein, said the new information could trump the so-
called non-prosecution agreement. 
The multifaceted agreement, he said, deals only with a 
specific list of victims that the U.S. Attorney's Office knew 
about when it penned the deal in 2007. If additional victims 
are listed in the journal Rodriguez stole, Horowitz said 
federal prosecutors could reopen the investigation. 
"It opens the door for further prosecution," he said. 
In addition to turning over the journal to federal agents, 
Rodriguez told them he knew his former boss was having 
sex with underage girls when he worked for him in 2004 
and 2005. He had seen naked girlsi who looked like minors, 
in the pool of Epstein's $8.6 million mansion. He had seen 
pornographic images of young girls on Epstein's computer, 
according to court records. 
Neither Epstein's criminal defense attorney,Jack 
Goldberger, nor attorney Robert Critton, who represents 
Epstein in the civil lawsuits, could be reached. Federal 
prosecutors have consistently declined comment. 
The wording of the controversial agreement is unclear. It 
says federal prosecutors would provide Epstein's attorneys 
"with a list of individuals whom it has identified as victims." 
Miami attorney Robert Josefsberg was appointed to 

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represent any of the victims on the list who wanted to 
pursue Epstein in civil court. As part of the agreement, 
Epstein is to pay for Josefsberg to represent the women. 
Some of the women, most identified as Jane Doe in 
lawsuits, had already hired attorneys to represent them. 
Some have since settled their suits with Epstein, although 
terms were not disclosed. 
Horowitz said he has filed court papers to get the journal 
that Rodriguez stole. "It's another piece of evidence that 
shows our clients were at Epstein's mansion," he said. 
Rodriguez told prosecutors he didn't turn over the journal 
when both FBI and Palm Beach police asked for it because 
he wanted money for it. He also said he was afraid Epstein 
would make him "disappear." The information, he told 
investigators, was his "insurance policy." 
He faces a maximum 20 years in prison when he is 
sentenced on June 18. 
jane....musgrave@pbpost.com 
@pbpcourts 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Epstein paid three women $5.5 million to end underage-
sex lawsuits 
By Jane.Musgrave 
Posted Oct 3, 2017 at 12:01 AM 
Updated Oct 4, 2017 at 12:46 AM 
Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young 
,,,,,, •••.• , •••••••••• ,, •. -.---·•·· .. ··••1•-··· 
women who claimed he used them as sex toys, court documents filed last week show he shelled 
out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him. 
Responding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the 
sex scandal, attorney Bradley Edwards said the politically-connected 64-year-old convicted sex 
offender paid more than $1 million to each of the three women Edwards represented. 
Identified in court papers only by their initials or pseudonyms because of the nature of the 
allegations and their youthful ages, L.M. was paid $1 million, E.W. $2 million and Jane Doe 
$2.5 million, Edwards said of the settlements he negotiated with Epstein to end the lawsuits. 
Jack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on 
the revelations, citing confidentiality agreements that were part of the settlements. For the 
same reason, he declined to say whether Epstein paid similar amounts to settle roughly two 
dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex 
when some were as young as 14 years old. 
Attorney Jack Scarola, who is representing Edwards, said his client was compelled to divulge 
the confidential settlements to answer questions posed by Epstein's attorneys. "Brilliant move 
on their part," he said. 
Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have 
likely come out. He says the information will help him undermine Epstein's claims that 
Edwards "ginned up" the allegations to help his former law partner, imprisoned and...

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The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute 
between Epstein and Rothstein, both billionaires. 
A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a 
minor for prostitution, he sued Rothstein and Edwards, claiming they trumped up the 
allegations of sexual molestation to perpetuate the Ponzi scheme. 
Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly 
successful law firm by forging the names of federal judges and others to persuade investors he 
had negotiated settlements in lawsuits against high-profile people. Investors were told they 
could get a cut of the cash. 
One of the high-profile people Rothstein used to lure investors was Epstein, according to a 
lawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the 
lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the lawsuits 
with the teens for $200 million - a claim Critton described as "a complete fabrication." 
After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him. Edwards accused 
Epstein of filing the lawsuit maliciously to punish him for representing the young women. 
Although Edwards was a partner in Rothstein's now defunct firm, Scarola claims Epstein had 
no evidence Edwards was involved in the Ponzi scheme. Federal prosecutors successfully 
charged other attorneys and members of the firm, but Edwards was never implicated, Scarola 
said in the malicious prosecution lawsuit. 
The revelations about the money Epstein paid to three of the young woman came last week in 
documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit. 
Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the 
trial, in part, because she claimed she has been unable to talk to her client since his estate on his 
private island in the U....

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Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge 
Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those 
victimized by the storm that hammered the Caribbean and roared through South Florida, he 
said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims. 
Stilt Hafele gave Coleman extra time to respond to various motions that he will have to decide 
before the case goes to trial. 
Despite Scarola's insistence that Edwards had nothing to do with Rothstein's Ponzi scheme, 
Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's 
well-known friends, such as now President Donald Trump, former President Bill Clinton and 
illusionist David Copperfield, she asked. He used the celebrities as a draw, she said. 
"The Epstein cases were used to fleece money and defraud investors," she said. 
Edward's malicious prosecution case has been difficult for both sides because both Epstein and 
Edwards have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked 
his Fifth Amendment right against self-incrimination when questioned by Scarola. Edwards 
has claimed that much of the information Epstein is seeking is protected by attorney-client 
privilege. 
The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit 
Edwards against Epstein. Edwards also is suing the U.S. attorney's office, claiming it violated 
the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with 
Epstein. 
Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to 
plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court 
records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's 
agreement to settle lawsuits filed against him by dozens of his underage vi...

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Palm Beach Daily News 
Judge rules feds' agreement with 
Jeffrey Epstein pact violated teen 
victims' rights 
By Jane.Musgrave 
Posted Sep 17, 2019 at 4:02 PM 
Updated Oct 8, 2019 at 12:31 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on February 22, 2019) 
Federal prosecutors violated the rights of Jeffrey Epstein's 
teenage victims by failing to reveal they had dropped plans 
to prosecute the billionaire on dozens of federal charges in 
connection with the girls' claims that he paid them for sex 
at his Palm Beach mansion, U.S. District Judge Kenneth 
Marra ruled on Thursday. 
In a blistering 33-page ruling, Marra meticulously and 
methodically detailed the numerous steps federal 
prosecutors took to hide the agreement from more than 40 
young women who claim Epstein paid them for sex when 
they were as young as 14. 
"While the government spent untold hours negotiating the 
terms and implications of the NPA with Epstein's attorneys, 
scant information was shared with the victims," Marra 
wrote. "Instead, the victims were told to be 'patient' while 
the investigation proceeded." 
By then, it was too late. A deal had already been cut with 
then-South Florida U.S. Attorney Alex Acosta and Epstein's 
attorneys to shelve a 52-page federal indictment against 
Epstein, a former math teacher turned money manager 
who counts Presidents Donald Trump and Bill Clinton 
among his friends. 

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Prosecutors' failure to alert the young women about the 
deal violated the Crime Victims' Rights Act, Marra ruled. 
"At a bare minimum the (act) required the government to 
inform (the young women) that it intended to enter into an 
agreement not to prosecute Epstein," he wrote. 
Still, Marra said he wasn't second-guessing prosecutors' 
decision not to pursue Epstein on federal charges ifhe 
pleaded guilty to minor state prostitution charges and 
agreed to compensate his victims for the trauma he caused. 
"The court is not ruling that the decision not to prosecute 
was improper," Marra wrote. "The court is simply ruling 
that, under the facts of this case, there was a violation under 
the CVRA." 
Further, he made no decision about what the remedy 
should be. He gave prosecutors and attorneys representing 
the young women 15 days to meet to decide how to unravel 
the complex legal web that has been hanging over Epstein 
and his young victims for more than a decade. 
The chances an accord will be reached are slim, said 
attorney Jack Scarola, who is representing the two Jane 
Does who challenged the prosecutors' actions. 
Further, he said, there is no road map to follow. The 
lawsuit attorney Bradley Edwards filed on behalf of the two 
unidentified young women, claiming prosecutors violated 
the federal act, is unique, he said. 
"We are treading on virgin ground, to use what is probably 
an inappropriate phrase in this situation," he said. 
Scarola said he and Edwards will ask that the non-
prosecution agreement be thrown out. That would open 
the possibility that the long-shelved federal indictment 
could be dusted off and filed against the 66-year-old 
Epstein, who spends most of his time on a private island he 
owns in the U.S. Virgin Islands. 

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"I don't see the government conceding to that remedy," 
Scarola admitted. Further, he said, it is likely Epstein will be 
allowed to weigh in. Miami attorney Roy Black years ago 
filed papers asking to intervene on Epstein's behalf. 
The U.S. Attorney's Office said it wouldn't comment on 
Marra's ruling. Neither Black nor New York City attorney 
Jay Lefkowitz, who led efforts to bury the federal 
indictment, responded to emails or phone calls for 
comment. West Palm Beach attorney Jack Goldberger, who 
represents Epstein, also didn't respond. 
Scarola said it is likely Epstein's star-studded legal team will 
argue that Epstein fully complied with the terms of the 
agreement he made in 2007 with federal prosecutors and 
therefore the agreement can't be undone. 
As he promised, Epstein pleaded guilty in June 2008 to state 
charges of soliciting a minor for prostitution and soliciting 
prostitution. He served 13 months of an 18-month jail term 
in a vacant wing of the county stockade that he was allowed 
to leave 12 hours a day, six days week. 
Further, as agreed, he paid settlements to the young women 
who sued him. While the settlements were confidential, 
court records show he paid three women a total of $5.5 
million. 
In return, federal prosecutors held up their end of the 
bargain. Their investigation ceased. 
Having done all that prosecutors asked of him, Scarola said 
Epstein will make a simple argument: "You can't turn 
around and deprive me of the benefits I bargained for." 
However, Scarola said, using Marra's ruling, he will counter 
that the contract Epstein signed was illegal and therefore 
unenforceable. 

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Even if Marra agrees to toss out the non-prosecution 
agreement, Scarola conceded that doesn't mean Epstein will 
face federal charges. 
"The contract can be set aside and the federal government 
can attempt to enter into the same agreement," he said. 
"Except the spotlight of public attention will be on them 
and the 40 victims will be able to explain to the court why 
this sweetheart deal should not be approved." 
Scarola said that prosecutors may have had good reason not 
to pursue Epstein. ''There may be a reasonable explanation 
but we don't know what that reason may have been," he 
said. 
In court papers, federal prosecutors have said that many of 
the young women were afraid to cross the powerful, 
politically connected money manager and simply refused to 
testify against him. 
In other cases, they said, the women changed their stories. 
Jane Doe 2, who is trying to have the non-prosecution 
agreement thrown out, initially described Epstein as "an 
awesome man" and told prosecutors she hoped "nothing 
happens" to him. While she later agreed to testify against 
Epstein, prosecutors said they feared Epstein's attorneys 
would use her words to destroy her if she ever took the 
witness stand. 
Marra, however, said the young woman's comments didn't 
mean she wasn't entitled to know about the prosecutors' 
plans to drop the charges. "There is no dispute that Epstein 
sexually abused Jane Doe 2 while she was a minor," he 
wrote. "Therefore, regardless of her comments to the 
prosecutor, she was a victim." 
Before the case is finally resolved, Scarola predicted that "a 
lot of people are going to have to answer a lot of questions." 

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In his ruling, Marra detailed what appeared to be a cozy 
relationship between Acosta, his line prosecutors and 
Epstein's team of lawyers. His phalanx of lawyers included 
noted Harvard law professor Alan Dershowitz and Kenneth 
Starr, the former U.S. solicitor general whose investigation 
led to the impeachment of President Clinton. 
Marra describes an October 2007 breakfast meeting 
between Acosta, who is now U.S. labor secretary, and 
Lefkowitz shortly after the non-prosecution agreement was 
inked. 
After the meeting, Lefkowitz sent Acosta a note thanking 
him for "the commitment you made to me during our 
October 12 meeting in which you assured me that your 
Office would not ... contact any of the identified 
individuals, potential witnesses, or potential civil claimants 
and their respective counsel in this matter.'' 
Marra qu9ted an equally pleasant note then-Palm Beach 
County State Attorney Barry Krischer sent to Assistant U.S. 
Attorney Marie Villafana, who was the lead prosecutor in 
Epstein's case. "Glad we could get this worked out for 
reasons I won't put in writing," Krischer wrote, shortly 
after the non-prosecution agreement was signed. "After this 
is resolved I would love to buy you a cup at Starbucks and 
have a conversation." 
Many of the notes that were exchanged dealt with 
prosecutors' and Epstein's lawyers' shared desire to keep the 
deal secret from Epstein's accusers. In a September email, 
Villafana asked Lefkowitz for guidance about what she 
should reveal. "And can we have a conference call to discuss 
what I may disclose to ... the girls regarding the 
Agreement," she asked. 

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Such cooperation between prosecutors and defense 
attorneys is unusual, Marra said. "It was a deviation from 
the government's standard practice to negotiate with 
defense counsel about the extent of crime victim 
notifications," he wrote, 
Further, he noted, that when Edwards and his two young 
clients asked for information, they were repeatedly misled. 
"The CRV A was designed to protect victims' right and 
ensure their involvement in the criminal justice process," 
Marra wrote. "When the government gives information to 
victims it cannot be misleading." 
Ultimately, the terms of the non-prosecution agreement 
were revealed only after Edwards and attorneys for the 
press successfully sued to make them public. 
jmusgrave@pbpost.com 
........... ,o••••••T•••••••••noo•OOOOOOO••••••••••••••••••••~•••••••••<+..•••T•••• 
@pbpcourts 
,,,,,,,, ...... ,, ••••••• + .. ··--•··"···»•• 

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.. 
• 
761278 - Tuesday, July 9, 2019 
Edition: Final 
Section: A Section 
Page: 1A 
Source: By Jane Musgrave, The Palm Beach Post 
Epstein indicted on sex charges 
Part-time Palm Beacher pleads not guilty to sex 
trafficking, conspiracy charges in federal court in 
Manhattan 
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty 
to charges accusing him of creating a vast network of girls as young as 14 that he exploited 
for his sexual pleasure at his homes in Palm Beach and Manhattan. 
The 66-year-old money manager's appearance in U.S. District Court in New York City 
capped more than a decade of recriminations by young women and their attorneys who 
claimed Epstein used his money and political influence to avoid federal prosecution. 
Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking 
charges as "essentially a do-over
11 of allegations that landed Epstein in the Palm Beach 
County Jail for 13 months more than a decade ago. 
However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to 
shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state 
prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is 
now U.S. labor secretruy. 
"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey 
Bennan said at a 
morning news conference. "And while the charged conduct is from a number of years ago, it 
is still profoundly important to many of the alleged victims, now young women. They 
deserve their day in court." 
At a detention hearing scheduled for Monday, Bennan said he will ask a federal judge to 
keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to 
commit sex trafficking. Epstein paid dozens of young women to give him nude massages 
that, for most, led to sex, he said. 
If convicted of exploiting dozens of young women, inc...

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I 
"We think he's a significant flight risk,
11 Berman said of the man who ferried Britain's Prince 
Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former 
President Bill Clinton on his jet, dubbed the Lolita Express. 
Berman
1s hard-line stance was welcomed by young women who for years have been told that 
Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement, 
promising not to charge Epstein in federal court. 
Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning 
her into his sex slave and forcing her to have sex with others, including Dershowitz and 
Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she 
told the Associated Press. Dershowitz has vehemently denied Guiffre's claims. 
New York prosecutors were able to ignore the controversial nonprosecution agreement 
because it contained some significant fine print, said former federal Judge Paul Cassell, who 
for years has fought to get the agreement thrown out. It says only that no charges could be 
filed against Epstein in South Florida, he said. 
Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of 
Florida," he said. "The Southern District of New York is not bound by that agreement and 
wasn't a signatory of it." 
That means the sordid allegations that have been leveled at Epstein for years are now part of 
a federal indictment. 
Contrary to Epstein's claims, he knew the women who came to his homes in New York and 
Palm Beach were minors because they told him their ages, according to the indictment. 
Epstein preyed on young girls because he knew they were "vulnerable to exploitation,
11 
prosecutors added. 
As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while 
he was in New York so they would be available for sex once he returned to Palm Beach, the 
indictment says. The employees w...

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.. 
• 
U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime 
Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked. 
Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight 
Monday, explaining what action Marra should take to redress that 'Nfong. 
Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida 
victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's 
victims with attorneys Bradley Edwards and Jack Scarola. 
Since it's likely Florida women will get to testify against Epstein in New York, Scarola said 
he's not focused on whether Epstein will face charges here. Instead, he said he wants to know 
how and why the agreement was reached. 
"There's been no explanation as to how a deal like this could have been cut and how the 
federal government could have been involved in a conspiracy to violate federal law, 
11 Scarola 
said of his interest in continuing the legal battle over the nonprosecution agreement. 
When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two 
prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the 
Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He 
was also forced to register as a sex offender and settle civil lawsuits more than 30 young 
women filed against him. 
U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out 
how the agreement came to be. "I am especially more interested in why Epstein got the deal 
he got/ Frankel said. "We need to know why he was given such an easy sentence. 
While she has asked the House Oversight Committee to investigate Acosta, Frankel said she 
is not sure that will happen. 
11It just seems to me it was a travesty that this guy got off the 
way he did and, without pre-ju...

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"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you," 
Bennan said. A special number, 1-800-CALLFBI, will link victims of authorities. 
Bill Sweeney, assistant director of the FBI's New York office, said after years of being 
ignored by federal agents, the victims' voices will be heard. 
"The Jeffrey Epstein matter is No. 1 on the major case list in the count.J.y," Sweeney said. 
Turning to address Epstein's victims directly, he said: 
11Y our bravery may empower others to 
speak out against crimes against them." 
jmusgrave@pbpost.com 

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Def.Ex.A-2 

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JACOBS SCHOLZ & WYLER, LLC. 
THE I.AW Of'Tlci;S Of' 
JAC:0155 ,_ ASSOC:11' Tf;s. P.A. 
--,HUR I . .JACO!llS 
November 26, 2019 
Office of the State Attorney 
I 5th Judicial Circuit 
Attn: 
Jeanne Howard 
A LIMITEQ Ll-"JiliUTY C:OMPANY OF P~FESSIO•V,L ASS0C:'AT10N$ 
ATTORNO'S AT I.AW 
GATEWAY TO ""'411:LlA 
$1$168? GATEWAY BLVD., SUITE: 11!:0l•I 
FERNANDINA BEA.c:n, F'LoRmA 32004 
TELE:PHONE C904) 1i!:6l-3693 
FAX NO. {9()4) 281.?879 
401 North Dixie Highway 
West Palm Beach, FL 33401 
Re: 
CA Florid.a Holdings, LLC v. Dave Aronberg et al. 
Case No.: 2019-CA-014681 
Dear Mrs. Howard: 
RIC:H1'RO J. SCHOL%, P.A. 
Ille ..,._RO .J. $C!-f01..l 
OOUGI..A$ A. W'l'Llt!t, P.A. 
DOUGt..AS "· WV~EA 
The purpose of this letter is to confirm that Jacobs Scholz & Wyler, LLC will represent you regarding the 
above-referenced matter. 
Our fees will be contingent upon our success in this matter. You will not be liable or required to pay any 
monies to our office unless we are successful in our representation of you regarding the above-referenced 
litigation and receive a court order awarding attorneys' fees. 
Accordingly, should we be successful in this matter, you agree to be billed for the time incurred in defending 
this action at our current hourly rates. At this time, our current hourly rates are: $475.00/hour for senior 
partners, $425.00/hour for other partners, $37S.00/hour for associate attorneys, and $125.00/hour for 
paralegal time. 
Furthcnnore, the attorneys' fees paid to our firm shall be calculated by the above listed hourly rates 
multiplied by the number of hours expended in defending this action or the total fee mandated and awarded 
by the court order herein, whichever is greater. 
By signing below; you agree to the terms as set forth above. Please return a signed and dated copy of this 
letter to our office. If you have any questions or concerns, please contact our office. On behalf of the 
finn, we are proud to represent you in this matter. 
...

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Def.Ex.A-3 

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida: SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Flotida. 
Defendants. 
I 
----------------
MOTION TO DISMISS 
CASE NO.: 19-CA-014681 
Defendant, DA VE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned counsel, hereby files this Motion to Dismiss Plaintiff's Complaint for failure to 
state a cause of action, and in supp011 thereof states: 
MOITON TO DISMISS STANDARD 
When confronted with a motion to dismiss, the Com1 must determine whether the Complaint as 
phrased within its four comers sufficiently states a cause of action, whereby relief can be granted. Fox v. 
Professional Wrecker Operations, 801 So. 2d 175, 178 (Fla. 5th DCA 2001). A motion to dismiss tests 
whether the plaintiff has stated a cause of action. The test for a motion to dismiss under Flotida Rule of 
Civil Procedure 1. l 40(b) is whether the pleader could prove any set of facts as alleged in the Complaint to 
support his or her claim. See, Connolly v. Sebeco, Inc., 89 So. 2d 482,484 (Fla. 1956): Wasua Ins. Co. v. 
Haynes, 683 So. 2d 1123 (Fla. 4th DCA 1996). 
In order to meet this test, "a complaint must allege sufficient ultimate facts to show that a pleader 
is entitled to relief." W.R. Townsend Contr., Inc. v. Jensen Civ. Consn-., Inc., 728 So. 2d 297, 300 (Fla. 
1st DCA 1999) (quoting Peny v. Cosgrove, 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. R. Civ. P. 
1.ll0(b)). The court need not accept internally inconsistent factual claims, conclusory allegations, 
unwmnnted deductions, or mere legal conclusions made by a party. Id. (citing Response Oncology, Inc. 

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v. Metrahealth Insurance Co., 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Asset Mgmt. v. Jaharis, 
297 F.3d 1182, 1188 (11th Cir. 2002) ("[On a motion to dismiss,] the plaintiff's fachlal allegations are 
accepted as trne .... However, legal conclusions masquerading as facts will not prevent dismissal."). To 
avoid dismissal, a pleading "must allege a cause of action recognized under law" against the defending 
pmty. Kislak v. Kreedian, 95 So. 2d 510, 514 (Fla. 1957). 
COUNTI 
(Florida Stahltes Section 905.27) 
Plaintiff attempts to assert a cause of action, in the interest of "fiuthering justice", under Flotida 
Statute § 905.27; however, a review of the stahlte in question reveals that no cause of action is provided 
for therein and consequently Plaintiff's Complaint must be dismissed as a matter of law. 
Despite 
Plaintiff's extensive recitation of the fachlal background regm-ding Jeffery Epstein and the testimony and 
evidence presented to the 2006 grand jury in Palm Beach County, Florida, Fla. Stat. § 905.27, merely 
explains the exceptions to the disclosure of grand jrny testimony and does not set forth in any way a cause 
of action upon which to initiate a valid law suit. 
Moreover, a review of the stahlte at issue clem-Iy indicates that even if § 905.27, Fla. Stat. 
provided a basis for a cause of action, Plaintiff is bmred from access to the records it seeks. To wit, in 
pertinent part, Fla. Stat. § 905.27(2) states: 
When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil 
case, it may be disclosed to all parties to the case and to their attorneys and by the latter 
to their legal associates and employees. However, the grand iwy testimony afforded such 
persons by the court can only be used in the defense or prosecution of the civil or 
criminal case and for no other purpose whatsoever. 
Here, despite the elem- stahlt01y guidelines for disclosure of grand jury materials in a civil case, 
Plaintiff...

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Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla. Stat. § 905.27(2). 
Finally, it is significant to note that despite Plaintiff's allegations to the contrary, Defendant Aronberg is 
not in custody or control of the records sought and is therefore not a proper party to this action. 
WHEREFORE, based on the foregoing argument and supporting authority, Defendant, DA VE 
ARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this Honorable 
Court grant the instant Motion and dismiss Plaintiff's Complaint with prejudice, and grant Defendant 
Aronberg all other and further relief deemed just and proper, including attorney's fees and costs for 
def ending this frivolous action. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 6th day of December, 2019, a copy of the foregoing has been 
electronically filed with the Florida E-File Portal for e-service on all parties of record herein. 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Althur I. Jacobs, Esq. 
Fla. Bar No.: 10249 
Richm-d J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
96168 7 Gateway Blvd., Suite 201-I 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 Fax 
Primmy: j acobsscholzlaw@comcast.net 
General Counsel for the Florida Prosecuting 
Attorney's Association 

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Def.Ex.A-4 

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Filing# 101840557 E-Filed 01/17/2020 12:23:06 PM 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEA CH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
IN 
THE 
CIRCUIT 
COURT OF 
THE 
FIFTEENTH mDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 50-2019-CA-014681-XXXX-MB 
Div.:AG 
F1RST AMENDED COMPLAINT 
CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its First Amended 
Complaint against Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his 
official capacity ("State Attorney"), and Sharon R. Bock, the Clerk of the Court for Palm Beach 
County, Florida, in her official capacity ("Comi Clerk"), alleges as follows: 
JURISDICTION 
1. 
This is an action within the exclusive jurisdiction of the Circuit Comi pursuant to 
Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq. 
PARTIES 
2. 
The Palm Beach Post is a daily community newspaper published by Plaintiff CA 
Florida Holdings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. 
3. 
Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth 
Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and 
has authority in grand jury proceedings pursuant to Fla. Stat. Section 27.03. He is sued herein in 

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his official capacity as his office is in possession and/or control of documents that are the subject 
of this action. 
4. 
Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach 
County, Florida. She is sued herein in her official capacity as her office is in possession and/or 
control of documents that are the subject of this action. 
INTRODUCTION 
5. 
fu what is now widely if belatedly recognized as a colossal miscaITiage of justice -
which led to the fmiher needless victimization of countless young girls and women - a wealthy, 
politically connected, and powerful financier was not held accountable for, nor even forced to 
confront, allegations of serious sex trafficking crimes. \Vhile it is clear that Jeffrey Epstein's 2008 
deal with the State of Florida was not consistent with the evidence gathered against him, what 
remains shrouded in myste1y is how that evidence was presented - and the extent to which it was 
presented - to the grand jury that returned an indictment far more limited in scope than expected 
and dese1ved. 
6. 
Through this action, The Palm Beach Post seeks public access to the testimony, 
minutes, and other evidence presented in 2006 to the Palm Beach County grand jmy empaneled 
during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for 
example, in order to prevent the flight of those whose indictment may be contemplated and their 
ability to conceal or destroy evidence; to ensure jurors' candor in deliberations; and to protect an 
accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law 
expressly authorizes the disclosure of grand jury proceedings under certain circumstances, 
including, as here, in the furtherance of justice. Fla. Stat.§ 905.27(1)(c). 
7. 
It can no longer credibly be maintained that continued blanket secrecy over the 
proceedings that led to the egregiously flawed 2006 Epstein indictment is wa...

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To the contrary, transparency is required to promote public understanding of the criminal justice 
system and public confidence in the fair administration of justice. As detailed below, Epstein was 
accused of sexually abusing and trafficking dozens of women and girls in south Florida (among 
other locations) over a period of several years while exploiting his wealth and political connections 
to obstmct the administration of justice at every tum. Public disclosure of the Epstein grand jury 
proceedings will shed light on the extent to which those in our government entrusted with the 
solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties 
in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated 
like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those 
who chose to give Epstein favorable- "unusual," in the words of the Town of Palm Beach Police 
Chief - treatment, are exposed and held accountable. From what limited information is now in the 
public domain, the State Attorney's refe1rnl of Epstein's case to the grand jury-which would be 
out of the ordina1y for this type of case - gives rise to a strong inference of favoritism and 
conesponding disregard for the rights of the minor victims of Epstein's sex trafficking. Access to 
the grand jmy materials will allow the public to determine whether the grand jury process, and the 
secrecy that comes with it, was used to further justice or, instead, operated to shield Epstein and 
his co-conspirators from the consequences of their criminal activities. Accordingly, Fla. Stat. 
Section 905.27 authorizes the disclosure of Epstein's 2006 grand jury proceedings. 
8. 
Even in the absence of such a statutmy basis, this Court is empowered to order 
public disclosure pursuant to its inherent authority and supervisory powers over the grand jury. 
fudeed, courts throughout t...

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as here, many of the details of Epstein's criminal misdeeds have already been made available in 
the public domain through extensive news repo11ing by, among others, The Palm Beach Post; by 
the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves. 
9. 
fu recognition of the sensitivity of the materials being sought, and in the interest of 
protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to 
copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County 
grand jmy first being submitted to this Court for in camera review, where they may be redacted, 
as appropriate, to protect those who dese1ve such protection. 
FACTUAL BACKGROUND 
10. 
The following facts were gathered, in large part, from documents obtained by The 
Palm Beach Post through various Florida Public Records Law requests, documents unsealed or 
publicly available in other related judicial proceedings, and information and documents in the 
public record. 
A. 
First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 
2005---2008. 
11. 
The investigation into Epstein's sex crimes began more than fomieen years ago, 
when a 14-year-old girl's stepmother repo1ied to police in the Town of Pahn Beach, Florida, that 
Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein 
required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid 
$300. Epstein was 52 years old at the time. 
12. 
Following this initial report in 2005, the Town of Palm Beach Police, and later, in 
2006, the FBI, investigated Epstein. futerviews under oath with five additional alleged victims and 
seventeen witnesses revealed that the events described by the 14-year-old girl occuned, with 
disturbingly similar details, with each of the other victims. 
4 

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13. 
Both the victim/witness inte1views, as well as evidence retrieved following a search 
of Epstein's home, showed that some of the girls involved were under the age of 18. The police 
search of Epstein's residence also found two hidden cameras and, throughout the house, large 
numbers of nude photos of girls, including victims whom the police had not inte1viewed in the 
course of their investigation. 
14. 
fu March 2006, a State grand jury was scheduled at which all of the victims were 
expected to testify. The proceeding was postponed, however, due to meetings between the State 
Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan 
Dershowitz. 
15. 
Another grand jmy was convened in April 2006, but canceled the day before it was 
to begin receiving evidence. 
(1) 
Police Chief Reiter's Letter to the State Attorney. 
16. 
On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a 
"personal and confidential" letter to then Palm Beach County State Attorney, Bany Krischer, 
stating: 
I must renew my prior observation to you that I continue to find your office's 
treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to 
communicate in this manner, but my most recent telephone calls to you and those 
of the lead detective to your assigned attorneys have been unanswered and 
messages remain unreturned. After giving this much thought and consideration, J 
must urge you to examine the unusual course tflatyour office's handling oftflis 
matter has taken and consider if good and sufficient reason exists to require your 
disqualification from the prosecution of these cases. (Emphasis supplied) 
17. 
Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach 
Police Department's probable cause affidavits charging Epstein and two of his assistants with 
multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested 
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that either an atTest waITant be issued for Epstein or the State Attorney directly initiate the charges 
against him, which would be public. 
(2) 
The July 2006 State Grand Jury Presentation. 
18. 
fustead, State Attorney Krischer elected to refer the case to a grand jury, which is 
mandatory for capital cases but rarely used for all other crimes. According to an official 
spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm 
Beach County. 
19. 
fu July 2006, after State Attorney Krischer presented testimony and evidence from 
one victim, the grand jmy returned an indictment on a sole count of solicitation of prostitution. 
There is no mention in the indictment of the victim being a minor. 
20. 
On information and belief, a second of Epstein's victims was supposed to testify 
before the grand jmy, but was unable to attend because of a school exam. 
21. 
No reasonable explanation has been provided as to why the numerous other known 
victims were not presented as witnesses and crime victims to the grand jury convened in July 2006. 
Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was 
initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do 
SO. 
22. 
On information and belief, during the grand jmy appearance of the single victim 
who testified, the State Attorney presented evidence that vilified the victim and attacked her 
credibility, including soliciting testimony regarding underage drinking and questionable personal 
behavior that was unrelated to the charges against Epstein. Fmiher upon information and belief, 
this information was initially brought to the attention of the State Attorney's office by Epstein's 
defense counsel. 
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(3) 
The FBl's Investigation and Epstein's Non-Prosecution 
Agreement With Federal Authorities. 
23. 
On information and belief, following the deficient July 2006 indictment, and with 
ChiefReiter's encouragement, the FBI began its own investigation of Epstein. 
24. 
Records unsealed in 2015 revealed that the FBI compiled repmis on "34 confirmed 
minors" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI, 
a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. However, at the 
request of Epstein's lawyers, the indictment was never presented to a federal grandjmy. 
25. 
Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta, 
negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with 
four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal 
charges. 
26. 
Throughout the remainder of 2007 and through the first half of 2008, Epstein's 
lawyers and the U.S. Attorney continued negotiating the plea anangement. Upon information and 
belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept 
confidential and under seal, and (3) all grandjmy subpoenas (including one that had already been 
issued for Epstein's computers) be withdrawn. 
27. 
On June 30, 2008, Epstein pied guilty to State charges: one count of solicitation of 
prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was 
sentenced to 18 months in jail, followed by a year of community control or house anest, and was 
adjudicated as a convicted sex offender required to register twice a year in Florida. 
28. 
The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to 
receive immunity from federal sex-trafficking charges that could have sent him to prison for life. 
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On information and belief, based on public records, former State Attorney Krischer communicated 
with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers. 
29. 
fudeed, Epstein was not incarcerated in a Florida prison for the State crimes for 
which he was convicted. fustead, he was placed in a private wing of the Palm Beach County 
Stockade, where, after 3 J;2 months, he was allowed to leave the jail on "work release" for up to 
12 hours a day, 6 days a week. His private driver provided his transportation to and from "work." 
30. 
Epstein was released five months early. 
31. 
Upon information and belief, Epstein violated the terms of his probation, but was 
not prosecuted. 
(4) 
The Crime Victims' Rights Act Litigation. 
32. 
Epstein's victims only learned after the fact about his plea in State court and filed 
an emergency petition to force federal prosecutors to comply with the Crime V i.ctims' Rights Act 
(18 U.S.C. § 3771, "CVRA"), which mandates ce1iain rights for crime victims, including the right 
to be infonned about plea agreements and the right to appear at sentencing. U.S. Di.strict Judge 
Kenneth A. Mana recently mled that federal prosecutors violated the CVRA by failing to notify 
Epstein's victims before allowing him to plead guilty to only the two State offenses. 
33. 
The prosecution's failure to keep the victims apprised, among other things, also 
contravenes the Florida Constitution, Atiicle 1, § 16(b) and Fla. Stat. § 960.001. 
34. 
Following publicity exposing the extraordinary leniency of the plea deal, dozens of 
civil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court. 
35. 
fu 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense) 
sex offender in New York, a lifelong designation. fu 2011, the New York County District 
Attorney's office unsuccessfully sought to lower his registration to low-risk "level one." 
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36. 
Upon information and belief, during the course of the Town of Palm Beach and FBI 
investigations, Epstein retained private investigators to follow, harass, and photograph his victims 
and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated 
the case against Epstein. 
37. 
Upon information and belief, Epstein's victims were threatened against cooperating 
with law enforcement and told that they would be compensated only if they did not cooperate with 
law enforcement. 
B. 
Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019. 
38. 
On July 6, 2019, Epstein was anested on federal sex trafficking charges. 
39. 
Upon infonnation and belief, the United States government's investigation of new 
allegations and charges stemmed, in pa1i, from continued press investigations into and reporting 
on the mishandling of the 2006 charges and the civil suits that followed. 
40. 
fu a July 8, 2019, letter to the federal district court by the U.S. Attorney for the 
Southern District of New York, Epstein was described as "a serial sexual predator who preyed on 
dozens of minor girls over a period of years." The letter emphasized that "the Government has real 
concerns - grounded in past experience with this defendant - that if allowed to remain out on bail, 
the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this 
case, including victims and their families, and othe1wise attempt to obstrnct justice." It also 
described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex 
trafficking in the fonn of "hundreds - and perhaps thousands - of sexually suggestive photographs 
of fully- or partially-nude females," including underage females. In a locked safe, compact discs 
were found with handwritten labels including the descriptions: "Young [N arne] + [N arne]," "Misc 
nudes l," and "Girl pies nude." 
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41. 
On July 8, 2019, prosecutors with the Public Conuption Unit of the U.S. Attorney's 
office for the Southern District of New York charged Epstein with sex trafficking and conspiracy 
to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were 
brought into Epstein's mansions for sexual encounters. A few days later, owing to public outc1y 
over the NP A with Epstein entered into by the U.S. Attorney for the Southern District of Florida, 
Alexander Acosta, who by then was serving as U.S. Secreta1y of Labor in the Trump 
administration, resigned from office. 
42. 
Epstein was denied bail and was placed into pretrial detention at the federal 
Metropolitan Conection Center in lower Manhattan. 
43. 
On or about August 6, 2019, Florida Gov. Ron Desantis ordered a state criminal 
probe into the actions of the Palm Beach Sheriff and fonner State Attorney Krischer for their 
handling of the Epstein underage sex trafficking case. 
44. 
On August 10, 2019, Epstein was found dead in his cell at the Metropolitan 
C01Tectional Center. His cause of death was determined to be suicide. 
C. 
The August 27, 2019, SDNY Hearing: Epstein's Victims Speak. 
45. 
On account of his death, prosecutors sought to dismiss the indictment against 
Epstein, while maintaining that they would continue to investigate his co-conspirators. 
46. 
United States Senior District Judge Richard M. Berman ordered a hearing on 
August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to 
speak at the hearing. 
47. 
fu the course of the hearing, more than two dozen victims delivered their personal 
stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of 
violent rape by Epstein. Many more victims were present in the comiroom but did not testify. 

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48. 
\Vhile some questioned the reasoning behind the court's decision to give the victims 
voice after Epstein's death, District Judge Bennan noted that "a public hearing is [the] prefened 
vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings 
promote transparency and they provide the comi with insights and infonnation which the court 
may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that 
the court "is the institution that most people have confidence in, in these ve1y troubled times." 
49. 
At the August 27th hearing, the girls, now women, spoke about their "exploitation 
and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme 
pove1iy, circumstances where [they] didn't have anyone on [their] side, to speak on [their] 
behalf. ... " One victim lamented that "as a victim, [she] never got to see what the agreement was 
or why the special treatment got approved" in the Florida case years earlier. Another noted how 
"completely different" the investigators leading to the 2019 federal indictment were from the 
prosecutors in the Florida case, both in their treatment of her and their investigation of her 
victimization by Epstein. 
50. 
A fonner federal judge in attendance at the August 27th hearing emphasized that 
"transparency is one of the oveni.ding objectives in our c1i.minal justice system." 
51. 
Nearly all of the victims expressed the conviction that the secrecy that shielded 
Epstein has caused them "itTeparable hann" and that an oppmiunity to address his criminal 
wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for 
at least some measure of justice to be se1ved after his death. Indeed, one victim stated: "Any efforts 
made to protect Epstein's name and legacy send a message to the victims that he wins and that he 
is untouchable." Another victim expressed fear that this i...

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"unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and 
connections severely eroded the public's faith in the integrity and impartiality of the criminal 
justice system. 
D. 
The Palm Beach Post's Standing and the Public Interest. 
(1) 
The Palm Beach Post Has Reported Extensively On Epstein's 
Crimes For Nearly 15 Years. 
52. 
Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm 
Beach County and the Treasure Coast vicinity. 
53. 
The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist 
three other times. 
54. 
Beginning in 2004, The Palm Beach Post has extensively investigated and repmied 
on the allegations against, the law enforcement investigation of, and the crimes committed by, 
Epstein and his co-conspirators. The Newspaper's repo11age has included publication of the 
following a1iicles: 
• 
"The Man \Vho Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends 
and, Investigators Say, Underage Girls.," published on August 14, 2006, reporting that 
Haley Robson, a local community college student, admitted in a sworn statement to 
police that "she had taken at least six girls to visit Epstein, all between the ages of 14 
and 16;" Palm Beach Police "inte1viewed five alleged victims and 17 witnesses;" 
"Dershowitz, the Ha1vard law professor, traveled to West Palm Beach with infonnation 
about the girls," including social media discussions about "their use of alcohol and 
marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their 
decision to take the case to a grand jmy;" Palm Beach Police subsequently "received 
complaints that two of the victims or their families had been harassed or threatened;" 
"relations between police and prosecutors were fraying" as the investigation continued; 
and "one girl who was subpoenaed - the one who said she had sexual intercourse with 
Epstein - never showed up" to testify before the ...

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• 
"Indictment Billionaire Solicited 3 Times" published on July 25, 2006, reporting that 
"Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein 
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last 
year, according to an indictment charging him with felony solicitation of prostitution." 
The a1iicle further repmied that "Epstein's case is unusual in that suspected prostitution 
johns are usually charged with a misdemeanor, and even a felony charge is typically 
made in a criminal infonnation - an alternative to an indictment charging a person with 
the commission of a crime." 
• 
"After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006, 
reporting that "Palm Beach police thought there was probable cause to charge Epstein 
with unlawful sex acts with a minor and lewd and lascivious molestation." The article 
fmiher repo1ied that "Police Chief Michael Reiter was so angry with State Attorney 
Bany Krischer's handling of the case that he wrote a memo suggesting the county's 
top prosecutor disqualify himself," and identified a 20-year-old on-the-record female 
source who said "she gave Epstein a massage in the nude, then brought him six girls, 
ages 14 to 16, for massage and sex-tinged sessions at his home." 
• 
"Police Say Lawyer Tried to Discredit Teenage Girls" published on July 29, 2006, 
reporting that "[f]amed Ha1vard law professor Alan Dershowitz met with the Palm 
Beach County State Attorney's Office and provided damaging infonnation about 
teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein, 
sexually charged massages" and that "[t]he state attorney's office said it presented the 
Epstein case to a county grand jmy this month rather than directly charging Epstein 
because of concerns about the girls' credibility." 
• 
"Expert: Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006, 
reporting that "[r]ather...

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• 
"Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published 
on October 18, 2007, reporting on a lawsuit brought in New York State court against 
Epstein "by a young woman who says he had sex with her when she was 16 and had 
sought his help becoming a model." 
• 
"Palm Beacher Pleads In Sex Case" published on July 1, 2008, repmiing that "Epstein, 
55, pleaded guilty ... to felony solicitation of prostitution and procuring a person under 
the age of 18 for prostitution," resulting in "a lifelong obligation to register as a sex 
offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their 
investigation of Epstein, which they had taken to a grandjmy." 
• 
"Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on 
August 13, 2008, reporting that"[ d]uring his first month of confinement" Epstein was 
visited by Sarah Kellen, who allegedly escmied victims "upon their ani.val at his Palm 
Beach waterfront home to an upstairs room, where she prepared the massage table and 
provided the oils for their encounters" with Epstein, and by Nadia Marcinkova, "a 
young woman whom Epstein purpmiedly desc1i.bed as his Yugoslavian sex slave." 
• 
"Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published on July 
1, 2008, repmiing that Epstein "is allowed to leave the Palm Beach County Stockade 
six days a week on a work-release program." 
• 
"Women Want Epstein Sex Plea Deal Unsealed" published on June 10, 2009, repo1iing 
that attorneys for women suing Epstein in various comis "want his [non-prosecution] 
agreement [NP A] with federal prosecutors unsealed" and were moving to unseal the 
agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces 
at least a dozen civil lawsuits in federal and state courts filed by young women who 
said they had sex with him and now are seeking damages." On that date, The Palm 
Beach Post moved to inte1ven...

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• 
"Epstein Journal's Findings Could Resunect Abuse Case" published on March 20, 
2010, reporting that "[a] purloined journal that is said to contain the names of 
'hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reopen 
the investigation into the multi-millionaire's appetite for teenage girls." 
• 
"Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits" published 
on October 4, 2017, reporting that, according to court documents, Epstein "shelled out 
$5.5 million to settle lawsuits with three of more than two dozen teens who sued him." 
• 
"Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims' 
Rights" published on Februa1y 22, 2019, repo1iing on a ruling by U.S. District Judge 
Kenneth Mana that "Federal prosecutors violated the rights of Jeffrey Epstein's 
teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had 
dropped plans to prosecute the billionaire on dozens of federal charges in connection 
with the girls' claims that he paid them for sex at his Palm Beach mansion." 
• 
"Epstein fudicted On Sex Charges/Pait-Time Palm Beacher Pleads Not Guilty to Sex 
Trafficking, Conspiracy Charges In Federal Court rn Manhattan" published on July 9, 
2019, repmiing on Epstein's appearance in U.S. District Court for the Southern District 
of New York in which he "pleaded not guilty to charges accusing him of creating a vast 
network of girls as young as 14 that he exploited for his sexual pleasure at his homes 
in Palm Beach and Manhattan." 
A ttue and conect copy of the above news articles, in either the computerized fonnat in which they 
are maintained in The Palm Beach Post's electronic archives or the news print edition in which 
originally published, is annexed hereto as Exhibit 1. 
55. 
Since the filing of the initial Complaint in this matter, The Palm Beach Post-along 
with media worldwide - has continued to repmi on Epstein's crimes and the ongoing of...

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Co. v. Lewis, 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a ''public sunogate" in 
matters concerning the closure of judicial proceedings). The press also has a First Amendment 
interest in receiving infonnation from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer 
Council, 425 U.S. 748, 756-57 (1976) ("Where a speaker exists ... the protection afforded [by 
the First Amendment] is to the collllllunication, to its source and to its recipients both."); Pittman 
v. Cole, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Court has recognized that the 
First Amendment offers protection to both speakers and those wishing to receive speech."); see 
also Stephensv. Cty. of Albemarle, Va., 524 F.3d485, 492 (4th Cir. 2008) (providing that a plaintiff 
has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing 
to convey the information to her"). 
57. 
Because of the unique role perfonned by the press as a ''public surrogate" (Lewis, 
426 So. 2d at 6-7) in protecting the right of access and its interest in repo1ting infonnation about 
criminal proceedings, news organizations "presumptively have a right to access judicial records," 
Comm 'r, Ala. Dep 't of Corr. v. Advance Local Media, LLC, 918 F .3d 1161, 1166 (11th Cir. 2019), 
and "standing to question the validity of an order restricting publicity because its ability to gather 
news is directly impaired or curtailed." Lewis, 426 So. 2d at 4; see also Carlson v. United States, 
837 F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Collllllittee] 
has standing to asse1t [its] claim" to grand jury materials because such materials are "public records 
to which the public may seek access, even if that effort is ultimately unsuccessful"). 
58. 
Here, the continued denial of access to information The Palm Beach Post seeks on 
behalf of its journalists and the public it serves "unquestionably constitutes i.tTep...

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source of information is weakened whenever the ability of journalists to gather infonnation is 
impaired," as it is by Attorney General's refusal to disclose umedacted report and underlying grand 
jmy materials). 
59. 
The Palm Beach Post has the right to maintain this private right of action because 
the furtherance of justice, an express legislative exception to grand jmy secrecy, is intended for 
the public benefit, and The Palm Beach Post seeks access on behalf of the public. Fla. Stat. 
§ 905.27(1)(c). It is further express in Fla. Stat. § 905.27 that the legislature intended for a comi 
to be the pa1iy to make the detennination of disclosure. Fla. Stat. § 905.27(1). In other words, the 
legislature intended for recourse to the courts in considering and detennining the propriety and 
scope of grand jmy secrecy. 
E. 
The Court's Jurisdiction And Authority. 
(1) 
The Court's Supervision of the Grand Jury Process and Its 
Authority to Order Public Disclosure of the Epstein Evidence. 
60. 
The Florida Supreme Court has noted that "in states such as Florida, where the 
grand jmy is prese1ved, it is an important appendage of the comi which impanels it. At the same 
time it should not be forgotten that the judge of that court is equally important and he is generally 
charged with the supe1vision of the grandjmy's activities .. .It is, therefore, of vital importance to 
maintain the dignity and the integrity of both the grand jmy and the presiding judge." State v. 
Clemons, 150 So. 2d 231, 233-34 (Fla. 1963). 
61. 
Chapter 905 of the Florida Statutes governs the empanelment and conduct of 
Florida grand juries. The court gives the grand jmy its initial charge and advises the grand jmy 
about its legal duties. Fla. Stat.§ 905.18. 
62. 
Florida Stat. Section 905.27(1) provides that "the testimony of a witness examined 
before the grand jmy ... or other evidence received by it" may be disclosed "when required by a 
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court ... for the purpose of: (a) Asce11aining whether it is consistent with the testimony given by 
the witness before the court; (b) Determining whether the witness is guilty of perjmy; or ( c) 
Fmihering justice." Fla. Stat. § 905. 27 ( 1 )(a)-( c). 
63. 
Fmiher, disclosure is appropriate pursuant to this Comi's inherent authority over 
grand jmy proceedings because of the exceptional public interest in this case and the compelling 
circmnstances suppmiing transparency. Carlson v. United States, 837 F.3d at 766 ("a district court 
has the inherent power to disclose [grand jmy] materials in exceptional circumstances and . . . 
historic irnpo11ance can be a sufficient reason when there is little countervailing need for secrecy"). 
64. 
The Florida Supreme Comi has confinned that grand jmy secrecy is not absolute 
and that any ''potential harm to public officeholders" from disclosure "will be the product of their 
own conduct, and not the consequence of an unrestrained body of misguided citizens." Miami 
Herald Pub. Co. v. Marko, 352 So. 2d 518 (1977) ("The benefits to be derived from this 
extraordinary exercise in citizen pa11icipation [in the grand jmy] would be severely limited if the 
:fi.uits of that activity were not available to the public on whose behalf it is undertaken. Implicit in 
the power of the grand jmy to investigate and expose official misconduct is the right of the people 
to be informed of its findings. \Vhile public disclosure of grand jury findings inevitably entails the 
risk of reputational damage, the legislature has ensured that any potential hann to public 
officeholders will be the product of their own conduct, and not the consequence of an unrestrained 
body of mis guided citizens."). 
(2) 
The Court's Jurisdiction To Declare Rights And Construe 
Statutes. 
65. 
This Comi has jurisdiction to declare rights, status, and other equitable or legal 
relations whether or not fmiher relief is or could be claimed. Florida S...

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66. 
Florida law specifically provides that a declaration may be sought from the Court 
concerning a petitioner's rights under a statute. Florida Stat. Section 86.021 ("Any person ... whose 
rights, status, or other equitable or legal relations are affected by a statute, or any regulation made 
under statuto1y authority, ... may have detennined any question of constmction or validity arising 
under such statute, ... or any part thereof, and obtain a declaration ofrights, status, or other equitable 
or legal relations thereunder."). 
67. 
The Comi's exercise of its power to declare rights "is to be liberally administered 
and construed." Florida Stat. Section 86.101. 
COUNTI 
(Declarato1y Relief - Florida Stat. Sections 86.011 et seq.) 
68. 
The allegations set fo1ih in paragraphs 1 through 67 are incorporated by reference 
as if fully set forth herein. 
69. 
This is an action for Declarato1y Relief pursuant to Chapter 86, Florida Statutes, 
and other supplemental relief 
70. 
The Palm Beach Post respectfully requests that the Comi declare that pursuant to 
Fla. Stat. Section 905.27(1), it is entitled access to the testintony, minutes, and other evidence 
presented in 2006 to the Palm Beach County grand jury because such disclosure and access would 
be in the fmiherance of justice. Fla. Stat. § 905.27(l)(c). Because The Palm Beach Post is not 
seeking these materials in connection with either a civil or criminal case, it seeks a declaration that 
the scope of its use of the disclosed materials is not lintited. See Fla. Stat.§ 905.27(2). 
71. 
The Palm Beach Post fmiher seeks a declaration that disclosure of the testimony, 
minutes, and other evidence presented in 2006 to the Palm Beach County grand jmy is appropriate 
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pursuant to this Comi's inherent authority over grand jury proceedings because of the exceptional 
public interest in this case and the compelling circmnstances suppmiing transparency. 
72. 
The Palm Beach Post has sought from Defendants, but Defendants have refused to 
provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach 
County grand jmy. Indeed, Defendants have each filed motions to dismiss the Complaint and the 
relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute exists between 
the patties. 
73. 
Through this Complaint, The Palm Beach Post presently has a justiciable question 
concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat. Section 905. 2 7 ( 1) 
and the Court's inherent authority. 
74. 
A bona fide, actual, present, and practical need for the declaration exists in that 
Defendants have denied to The Palm Beach Post - and to the public at large - the grand jury 
materials sought to be disclosed. The relief sought from the Court is therefore not merely the giving 
of legal advice or to answer hypothetical questions. 
\VHEREFORE, The Palm Beach Post respectfully requests that the Court determine the 
rights and obligations of the patties by declaring that pursuant to Fla. Stat. Section 905.27(l)(c) 
and the Court's inherent authority, The Palm Beach Post may gain access to the testimony, 
minutes, and other evidence presented in 2006 to the Palm Beach County grand jury and use those 
materials for the purpose of informing the public. 
COUNT II 
(Florida Stat. Section 905.27) 
75. 
The allegations set fotih in paragraphs 1 through 74 are incorporated by reference 
as if fully set forth herein. 
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76. 
Based on information learned by The Palm Beach Post through its Florida Public 
Records Law requests, law enforcement sources with direct knowledge of the grandjmy evidence 
and proceedings, judicial documents obtained from independent but related comi proceedings, and 
documents otherwise available in the public record, the State Attorney for Palm Beach County 
presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jmy in a manner 
that precluded his indictment for the serious crimes he committed, including sex trafficking and 
sexual assault. 
77. 
Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's 
victims and the public, and to provide public disclosure to illuminate whether Epstein received 
umeasonably lenient treatment based on the available evidence, The Palm Beach Post requests 
immediate access to the testimony, minutes, and other evidence presented in 2006 to the Palm 
Beach County grand jury. 
78. 
fu a case ofthis magnitude and impmiance, where the accused is dead and so many 
of his crimes, as well as the identities and crimes of his co-conspirators, and the identities of the 
victims have already been exposed, the need for grand jmy secrecy is no more. See United States 
v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) ("[A]fter the grand jmy's functions are 
ended, disclosure is wholly proper where the ends of justice require it."). 
\VHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla. 
Stat. Section 905.27(1) and the Comi's inherent authority, order the State Attorney and the Clerk 
of the Comi to file with this Court copies of the testimony, minutes, and other evidence presented 
in 2006 to the Palm Beach County grand jmy during the first Epstein sex abuse investigation so 
that, following an in camera inspection, it can be made available to The Palm Beach Post and the 
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public on an expedited basis, and grant any other and further equitable or legal relief the Court 
deems just and proper. 
Dated: January 1 7, 2020 
Respectfully submitted, 
GREENBERG TRA.URIG, P.A. 
Attorneys for CA Florida Holdings, LLC, 
Publisher of The Palm Beach Post 
Stephen A. Mendelsohn, Esq. 
5100 Town Center Circle, Suite 400 
Boca Raton, Florida 33486 
Telephone: (561) 955-7629 
Facsimile: (561) 338-7099 
By: Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 
mendelsohns@gtlaw.com 
hasenh@gtlaw.com 
FLService@gtlaw.com 
By: Isl Michael J Grygiel 
MICHAEL J GRYGIEL 
(Admitted Pro Hae Vice) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile: (518) 689-1499 
grygielm@gtlaw.com 
By: Isl Nina D. Bovaiian 
NINA D. BOY AJIAN 
(Pro Hae Vice application pending) 
1840 Century Park East, Suite 1900 
Los Angeles CA 90067 
Telephone: (310) 586 -7700 
Facsimile: (310) 586 -7800 
boyajiann@gtlaw.com 
riveraal@gtlaw.com 
22 

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CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has 
been electronically filed with the Florida E-File Portal fore-service on all parties of record herein. 
Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
23 

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EXHIBIT 1 
The Newspaper's Reportage on Jeffrey Epstein 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
The Man Who Had Everything: Jeffrey Epstein craved big 
homes, elite friends and underage girls 
By Andrew_Marra 
Posted Jul 17, 2019 at 6:02 AM 
From the archives: When Palm Beach detectives started asking 
questions and teenage girls started talking, a wave of legal resistance 
followed. 
Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after 
Jeffrey Epstein's arrest in Palm Beach County on a charge of felony solicitation of prostitution. 
WINGED GARGOYLES guarded the gate atJeffreyEpstein's Palm Beach mansion. Inside, 
hidden cameras trolled two rooms, while the girls came and went. 
For the police detectives who sifted through the garbage outside and kept records of visitors, it 
was the lair of a troubling target. 
Epstein, one of the most mysterious of the country's mega-rich, was known as much for his 
secrecy as for his love of fine things: magnificent homes, private jets, beautiful women, 
friendships with the world's elite. 
But at Palm Beach police headquarters, he was becoming known for something else: the 
regular arrival of teenage girls he hired to give him massages and, police say, perform sexual 
favors. 
Epstein was different from most sexual abuse suspects; he was far more powerful. He counted 
among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along 
with some of the most prominent legal, scientific and business minds in the country. 
When detectives started asking questions and teenage girls started talking, a wave oflegal 
resistance followed. 

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>> NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work-
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release 
If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough. 
Epstein, now 53 1 was a quintessential man of mystery. He amassed his fortune and friends 
quietly1 always in the background as he navigated New York high society. 
When he first attracted notice in the early 1990s, it was on account of the woman he was 
dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. 
In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the British 
Mail on Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a 
math teacher1 a concert pianist or a corporate headhunter. 
"But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both 
flamboyant and intensely private." 
The media frenzy did not begin in full until a decade later. In September 2002, Epstein was 
flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to 
Africa on his private jet. 
Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair 
published lengthy profiles. The New York Post listed him as one of the city's most eligible 
bachelors and began describing him in its gossip columns with adjectives such as "mysterious" 
and "reclusive." 
Although Epstein gave no interviews, the broad strokes of his past started to come into focus. 
Building a life of extravagance 
He was born blue-collar in 1953, the son of a New York City parks department employee, and 
raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree 
but became a math teacher at the prestigious Dalton School in Manhattan. 
The stor...

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In 197 6, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J. 
Epstein and Co. That is when he began making his millions in earnest. 
Little is known or said about Epstein's business except this: He manages money for the 
extremely wealthy. He is said to handle accounts only of $1 billion or greater. 
It has been estimated he has roughly 15 clients, but their identities are the subject of only 
speculation. All except for one: Leslie W exner, founder of The Limited retail chain and a 
former Palm Beacher who is said to have been a mentor to Epstein. 
Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a 
block on Manhattan's Upper East Side. It is reported to have, among its finer features, closed-
circuit television and a heated sidewalk to melt away fallen snow. 
That townhouse, thought to be the largest private residence in Manhattan, is only a piece of 
the extravagant world Epstein built over time. 
In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch 
outside Santa Fe. Many believed it to be the largest home in the state. 
In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre 
private island in the Virgin Islands. 
>> PHOTOS: The players in the Jeffrey Epstein saga 
Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at 
the highest echelons of power. This includes not only socialites but also business tycoons, 
media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often 
funds. 
'Just like other people collect art, he collects scientists," said Martin Nowak, who directs the 
Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of 
a $30 million research donation from Epstein. 
Epstein is said to have befriended former Harvard President Larry Summers, prominent law 
Professor Alan Dershowitz, Do...

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And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely 
photographed. 
"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials 
and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article. 
Epstein's friendship with Clinton has attracted the most attention. 
Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at 
an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become 
close friends until after Clinton left the Oval Office and moved to New York. 
Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John 
Kerry's presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the 
Senate bids of Joe Lieberman, Hillary Rod.ham Clinton, Christopher Dodd and Charles 
Schumer. 
Powerful friends and enemies 
A Vanity Fair profile found cracks in the veneer of Epstein's life story. The 2003 article said he 
left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange 
Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20 
million loan. 
The article suggested that one of his business mentors and previous employers was Steven 
Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million 
in one of the largest Ponzi schemes in American history." 
As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the 
man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less 
than $16,000 in furnishings. 
A former friend claimed Epstein backed out of a promise to reimburse him hundreds of 
thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein 
owed him nothing. 
>> Jeffrey Epstein: Model prisoner who swept, mopped floors, offici...

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"It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the 
retired former president of Williams Electronics and Sega Corp. "Suffice it to say I have 
nothing good to say about him." 
Among the characteristics most attributed to Epstein is a penchant for women. 
He has been linked to Maxwell, a fixture on the high-society party circuits in both New York 
and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian 
model. 
"He's a lot of fun to be with," Donald Trump told New York magazine in 2002. "It is even said 
that he likes beautiful women as much as I do, and many of them are on the younger side. No 
doubt about it,Jeffrey enjoys his social life." 
Investigation leads to Epstein 
Although he was not a frequenter of the Palm Beach social scene, he made his presence felt. 
Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and 
$100,000 to Ballet Florida. 
In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green 
Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a 
private chef and a small staff stood at the ready. From a window in his mansion, he could look 
out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man 
who had everything. 
But extraordinary wealth can fuel extraordinary desires. 
>> Epstein wants to leave jail for mansion in sex-trafficking case 
In March 2005, a worried mother contacted Palm Beach police. She said another parent had 
overheard a conversation between their children. 
Now the mother was afraid her 14-year-old daughter had been molested by a man on the 
island. 
The phone call triggered an extensive investigation, one that would lead detectives to Epstein 
but leave them frustrated. 

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Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm 
Beach police report detailing the criminal probe offers a window into what detectives faced as 
they sought to close in on Epstein. 
Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to 
perform a massage. She said the friend told her to say she was 18 if asked. At the house, she 
said she was paid $300 after stripping to her panties and massaging the man while he 
masturbated. 
Police interview 5 alleged victims 
The investigation began in full after the girl identified Epstein in a photo as the man who had 
paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift 
through it. They set up a video camera to record the comings and goings at his home. They 
monitored an airport hangar for signs of his private jet's arrivals and departures. 
They quickly learned that the woman who took the 14-year-old girl to Epstein's house was 
Haley Robson1 a Palm Beach Community College student from Loxahatchee. In a sworn 
statement at police headquarters, Robson, then 18, admitted she had taken at least six girls to 
visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said. 
During the drive back to her house, Robson told detectives, 'Tm like a Heidi Pleiss." 
Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls 
said they had been instructed to have sex with another woman in front ofEpstein1 and one said 
she had direct intercourse with him. 
In October, police searched the Palm Beach mansion. They discovered photos of naked, young-
looking females, just as several of the girls had described in interviews. Hidden cameras were 
found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school 
transcript. 
Two of Epstein's former employees told investigators that young-looking gir...

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One employee told detectives he was told to send a dozen roses to one teenage girl after a high 
school drama performance. Others were given rental cars. One, according to police, received a 
$200 Christmas bonus. 
The cops moved to cement their case. But as they tried to tighten the noose, they encountered 
other forces at work. 
In Orlando they interviewed a possible victim who told them nothing inappropriate had 
happened between her and Epstein. They asked her whether she had spoken to anyone else. 
She said yes, a private investigator had asked her the same questions. 
>> Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal 
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When they subpoenaed one of Epstein's former employees, he told them the same thing. He 
and a private eye had met at a restaurant days earlier to go over what the man would tell 
investigators. 
Detectives received complaints that private eyes were posing as police officers. When they told 
Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the 
high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William 
Kennedy Smith. 
While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law 
professor, traveled to West Palm Beach with information about the girls. From their own 
profiles on the popular Web site MySpace.com, he obtained copies of their discussions about 
their use of alcohol and marijuana. 
He took his research to a meeting with prosecutors in early 2006, where he sought to cast 
doubt on the teens' reliability. 
The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only 
did some of the girls have issues with drugs or alcohol but also some had criminal records and 
other troubles1 Epstei...

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In the following weeks, police received complaints that two of the victims or their families had 
been harassed or threatened. Epstein's legal team maintains that its private investigators did 
nothing illegal or unethical during their research. 
By then, relations between police and prosecutors were fraying. At a key meeting with 
prosecutors and the defense, Detective Joseph Recarey, the lead investigator, was a no-show, 
according to Epstein's attorney. 
"The embarrassment on the prosecutor's face was evident when the police officer never 
showed up for the meeting," attorney Jack Goldberger said. 
Later in April, Recarey walked into a prosecutor's office at the state attorney's office and 
learned the case was taking an unexpected turn. 
The prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein 
a plea deal that would not require him to serve jail time or receive a felony conviction. 
Recarey told her he disapproved of the plea offer. 
The deal never came to pass, however. 
Future unclear after charge 
On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four 
counts of unlawful sexual activity with a minor and to charge his personal assistant, Sarah 
Kellen, now 27, for her alleged role in arranging the visits. Police officials also wanted to 
charge Robson, the self-described Heidi Pleiss, with lewd and lascivious acts. 
By then, the department was frustrated with the way the state attorney's office had handled the 
case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter 
wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if 
he would not act. 
Two weeks later, Recarey was told that prosecutors had decided once again to take the case to 
the grand jury. 

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It is not known how many of the girls testified before the grand jury. But Epstein's defense 
team said one girl who was subpoenaed - the one who said she had sexual intercourse with 
Epstein - never showed up. 
The grand jury's indictment was handed down in July. It was not the one the police 
department had wanted. 
Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was 
charged with one count of felony solicitation of prostitution, which carries a maximum penalty 
of five years in prison. He was booked into the Palm Beach County Jail early July 23 and 
released hours later. 
Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But 
he said their claims that they had sexual encounters with him lack credibility. 
"They are incapable of being believed," he said. "They had criminal records. They had 
accusations of theft made against them by their employers. There was evidence of drug use by 
some of them." 
What remains for Epstein is yet to be seen. 
The Palm Beach Police Department has asked the FBI to investigate the case. It also has 
returned the $90,000 Epstein donated in 2004. 
In New York, candidates for governor and state attorney general have vowed to return a total 
of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful 
friends have remained silent as tabloids and Internet biogs feast on tl}e public details of the 
police investigation. 
Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future 
plea deal. He insists Epstein will emerge in the end with his reputation untarnished. 
"He will recover from this," he said. 
Staff writer Larry Keller and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and 
Melanie Mena contributed to this story. 
amarra@pbpost.com 

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273 / 278 -Tuesday, November 16, 2004 
Edition: FINAL 
Section: A SECTION 
Page: lA 
Source: By PAUL OWERS Palm Beach Post Staff Writer 
Illustration: PHOTO (C & 2 B&W) & MAP (B&W) 
Memo: Ran all editions. 
Dateline: WEST PALM BEACH 
TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION 
When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The 
Donald was not about to be trumped. 
"Nobody was going to outbid me," the brash developer-turned-TV-personality said from his 
New York office. 
Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot, 
seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row." 
But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at 
513 N. County Road. He wants to - what else? - sell it and make more money. 
The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super 
luxury house" that would be the "finest anywhere in the United States." He might build 
another house before flipping the entire package. 
"I've known about this house for quite some time," Trump said. "It's probably the best piece 
of land in Florida - and probably the country - for luxury real estate." 
Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor 
Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith 
said she's not worried about Trump's plans. 
"He's been a very good property owner in the town of Palm Beach," she said. "He does his 
projects very well. He's a perfectionist." 
Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of 
Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual 
distribution to creditors. 
The auction began at exactly noon after Judge Steven Friedman dismissed an objection from 
an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully...

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But Friedman allowed the offer to stand, and Pulte and Trump went back and forth until 
Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at 
$38.6 million. 
Friedman closed the bidding 10 minutes after it started, leaving Trump with the right to buy 
the 29,000-square-foot home (a typical Palm Beach County single-family house is about 
2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service 
quarters. 
The closing could take place within a week but probably won't happen until next month. 
Trustee Joe Luzinski and creditors said they were pleased with the outcome. 
"We knew we were dealing with some substantial people ... who were going to bid it up a 
bit," Luzinski said. 
"The system worked,
11 said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank. 
11In bankruptcy court, the idea is to get the most for creditors, and that's what happened." 
The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer 
former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't 
receive a commission, he said. 
Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday. 
11I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said. 
Pulte said Gosman asked him before the auction whether he would be willing to let him stay 
in the mansion after the closing until he decides where he wants to move. Trump and 
Luzinski said they have had no such discussions with Gosman. 
Gosman, 7 5, had the house built after paying $12 .1 million for the land in 1986. 
The former health-care magnate declined interview requests before and after the auction 
Monday. He was at the courthouse but left before the auction took place. 
The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm 
Beach home and guest house but falls short of the $45 mill...

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The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife 
an ownership interest in his home and other belongings only to avoid losing them in 
bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in 
1999, well before he filed for bankruptcy. 
Lessen is expected to rule in the next two months whether Gosman made improper transfers, 
a decision that will affect how much money will be available to creditors. 
Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were 
willing to move forward, in part because the upkeep of the estate now exceeds their means. 
"This is not a happy occasion for them, but at least we're moving to the next level," Cimo 
said. "That's not a house you want to live in unless you're making large amounts of money 
like Donald Trump." 
paul _ owers@pbpost.com 

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11/11/2019 
Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post-West Palm Beach, FL 
The Palm Beach Post 
REAL NEWS STARTS HERE 
Indictment: Billionaire Solicited 3 Times 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 2, 2019 at 2:30 PM 
(EDITORS NOTE: This story originally published in The Palm Beach Post on July 25, 
2006) 
Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein 
solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 
of last year, according to an indictment charging him with felony solicitation of 
prostitution. 
Epstein, 53, was booked at the Palm Beach County jail at 1 :45 a.m. Sunday. He 
was released on $3,000 bond. 
Epstein's case is unusual in that suspected prostitution johns are usually charged 
with a misdemeanor, and even a felony charge is typically made in a criminal 
information - an alternative to an indictment charging a person with the 
commission of a crime. 
His attorney,Jack Goldberger, declined to discuss the charge. 
State attorney's office spokesman Mike Edmondson also had little to say. 
"Generally speaking, there is a case that has a number of different aspects to it," 
Edmondson said of a prostitution-related charge being submitted to a grand jury. 
"We first became aware of the case months ago by Palm Beach police." 
Prosecutors and police worked together to bring the case to the grand jury, he 
said. 
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11/11/2019 
lndlctmenl: Billionaire Solicited 3 Times• News -The Palm Beach Post• West Palm Beach, FL 
Palm Beach police confirmed that and said the department will release a report 
today regarding its investigation. 
Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a 
pool and a boat dock on the Intracoastal Waterway since 1990, according to 
property records. A man answering the door there Monday said that Epstein 
wasn't home. A Cadillac Escalade registered to him was parked in the driveway, 
which is flanked by two massive gargoyles. 
Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the 
assessment of his home exceeded its fair market value. He dismissed his lawsuit 
in December 2002. 
A profile of Epstein in Vanity Fair magazine said he owns what are believed to 
be the largest private homes in Manhattan - 51,000 square feet - and in New 
Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the 
U.S. Virgin Islands and fleet of aircraft. 
Epstein's friends and admirers, according to the magazine, include prominent 
businessmen, academics and scientists and famed Harvard law professor Alan 
Dershowitz. 
larry _keller@pbpost.com 
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After long probe, billionaire faces solicitation charge - News -The Palm Beach Post-West Palm Beach, FL 
The Palm Beach Post 
REAL NEWS STARTS HERE 
After long probe, billionaire faces solicitation 
charge 
Posted Jul 27, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 3:11 PM 
(EDITOR'S NOTE: This story originally published in The Palm Beadt Post on July 26, 
2006) 
Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young 
women brought to his home, where he received massages and sometimes sex, 
according to an investigation by the Palm Beach Police Department. 
Palm Beach police spent months sifting through Epstein's trash and watching his 
waterfront home and Palm Beach International Airport to keep tabs on his 
private jet. An indictment charging Epstein, 53, was unsealed Monday, charging 
him with one count of felony solicitation of prostitution. 
Palm Beach police thought there was probable cause to charge Epstein with 
unlawful sex acts with a minor and lewd and lascivious molestation. 
Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's 
handling of the case that he wrote a memo suggesting the county's top 
prosecutor disqualify himself. 
"I must urge you to examine the unusual course that your office's handling of this 
matter has taken and consider if good and sufficient reason exists to require your 
disqualification from the prosecution of these cases," Reiter wrote in a May 1 
memo to Krischer. 
While not commenting specifically on the Epstein case, Mike Edmondson, 
spokesman for the state attorney, said his office presents cases other than 
murders to a grand jury when there are questions about witnesses' credibility and 
their ability to testify. 
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After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL 
By the nature of their jobs1 police officers look at evidence from a "one-sided 
perspective," Edmondson said. "A prosecutor has to look at it in a much broader 
fashion," weighing the veracity of witnesses and how they may fare under 
defense attorneys' questioning, he said. 
Epstein's attorney, Jack Goldberger, said his client committed no crimes. 
"The reports and statements in question refer to false accusations that were not 
charged because the Palm Beach County state attorney questioned the credibility 
of the witnesses," Goldberger said. A county grand jury "found the allegations 
wholly unsubstantiated and not credible," and that's why his client was not 
charged with sexual activity with minors, he said. 
Goldberger said Epstein passed a lie detector test administered by a reputable 
polygraph examiner in which he said he did not know the girls were minors. 
Also, a search warrant served on Epstein's home found no evidence to 
corroborate the girls' allegations, Goldberger said. 
According to police documents: 
- A Palm Beach Community College student said she gave Epstein a massage in 
the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged 
sessions at his home. 
- A 27-year-old woman who worked as Epstein's personal assistant also 
facilitated the liaisons, phoning the PBCC student to arrange for girls when 
Epstein was coming to town. And she escorted the girls upstairs when they 
arrived, putting fresh sheets on a massage table and placing massage oils nearby. 
- Police took sworn statements from five alleged victims and 17 witnesses. They 
contend that on three occasions, Epstein had sex with the girls. 
A money manager for the ultra-rich, Epstein was named one of New York's most 
eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with 
the likes of former President Cl...

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11/11/2019 
After long probe, billionaire faces solicitation charge• News• The Palm Beach Post• West Palm Beach, FL 
He has contributed tens of thousands of dollars to Democratic Party candidates 
and organizations, including Sen. John Kerry's presidential bid, and the Senate 
campaigns of Joe Lieberman, Hillary Clinton, Christopher Dodd and Charles 
Schumer. 
Goldberger is one of five attorneys Epstein has retained since he became the 
subject of an investigation, Edmondson said. Among the others: Alan 
Dershowitz, the well-known Harvard law professor and author, who is a friend 
of Epstein. Dershowitz could not be reached for comment. 
Police said the woman who enlisted young girls for Epstein was Haley Robson, 
20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in 
Wellington and said she was a journalism major at Palm Beach Community 
College when she was questioned by police last October. She has an unlisted 
phone number and could not be reached for comment. 
Robson said she met Epstein when, at age 17, a friend asked her if she would like 
to make money giving him a massage. She said she was driven to his five-
bedroom, 7 t /2-bath home on the Intracoastal Waterway, then escorted upstairs 
to a bedroom with a massage table and oils. Epstein and Robson were both naked 
during the massage, she said, but when he grabbed her buttocks, she said she 
didn't want to be touched. 
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After long probe, billionaire faces solicitation charge - News -The Palm Beach Post - West Palm Beach, FL 
Epstein said he'd pay her to bring him more girls - the younger the better, 
Robson told police. When she tried once to bring a 23-year-old woman to him, 
Epstein said she was too old, Robson said. 
Robson, who has not been charged in the case, said she eventually brought six 
girls to Epstein who were paid $200 each time, Robson said. ''I'm like a Heidi 
Pleiss," police quoted her as saying. The girls knew what to expect when they 
were taken to Epstein's home, Robson said. Give a massage - maybe naked - and 
allow some touching. 
One 14-year-old girl Robson took to meet Epstein led police to start the 
investigation of him in March 2005. A relative of the girl called to say she 
thought the child had recently engaged in sex with a Palm Beach man. The girl 
then got into a fight with a classmate who accused her of being a prostitute, and 
she couldn't explain why she had $300 in her purse. 
The girl gave police this account of her meeting with Epstein: 
She accompanied Robson and a second girl to Epstein's house on a Sunday in 
February 2005. Once there1 a woman she thought was Epstein's assistant told the 
girl to follow her upstairs to a room featuring a mural of a naked woman, several 
photographs of naked women on a shelf, a hot pink and green sofa and a massage 
table. 
She stripped to her bra and panties and gave him a massage. 
Epstein gave the 14-year-old $300 and she and the other girls left, she said. She 
said Robson told her that Epstein paid her $200 that day. 
Other girls told similar stories. In most accounts, Epstein's personal assistant at 
the time, Sarah Kellen, now 27, escorted the girls to Epstein's bedroom. 
Kellen1 whose most recent known address is in North Carolina, has not been 
charged in the case. 
Palm Beach police often conducted surveillance of Epstein's home, and at Palm 
Beach International Airp...

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11/11/2019 
After long probe, billionaire faces solicitation charge - News• The Palm Beach Post-West Palm Beach, FL 
from Palm Beach sanitation workers, collecting papers with names and phone 
numbers, sex toys and female hygiene products. 
One note stated that a female could not come over at 7 p.m. because of soccer. 
Another said a girl had to work Sunday - "Monday after school?" And still 
another note contained the work hours of a girl, saying she leaves school at 11 :30 
a.m. and would come over the next day at 10:30 a.m. 
Only three months before the police department probe began, Epstein donated 
$90,000 to the department for the purchase of a firearms simulator, said Jane 
Struder, town finance director. The purchase was never made. The money was 
returned to Epstein on Monday, she said. 
https:/Jwww,palmbeachpost.com/news/20060727 /after-long-probe-billionaire-faces-solicitation-charge 
5/5 

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11/11/2019 
Police say lawyer tried to discredit teenage girls • News • Palm Beach Daily News - Palm Beach, FL 
Palm Beach Daily News 
Po lice say lawyer tried to disc red it teenage 
girls 
Posted Jul 29, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 2:00 PM 
(EDITOR'S NOTE: This story originally was published in The Palm Beadt Post on July 
29, 2006) 
Famed Harvard law professor Alan Dershowitz met with the Palm Beach County 
State Attorney's Office and provided damaging information about teenage girls 
who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually 
charged massages, according to police reports. 
The reports also state that another Epstein attorney agreed to a plea bargain that 
would have allowed Epstein to have no criminal record. His current attorney 
denies this happened. 
And the documents also reveal that the father of at least one girl complained that 
private investigators aggressively followed his car, photographed his home and 
chased off visitors. 
Police also talked to somebody who said she was offered money if she refused to 
cooperate with the Palm Beach Police Department probe of Epstein. 
The state attorney's office said it presented the Epstein case to a county grand 
jury this month rather than directly charging Epstein because of concerns about 
the girls' credibility. The grand jury indicted Epstein, 53, on a single count of 
felony solicitation of prostitution, which carries a maximum penalty of five years 
in prison. 
Police believed there was probable cause to charge Epstein with the more serious 
crimes of unlawful sex acts with a minor and lewd and lascivious molestation. 
Police Chief Michael Reiter was so angry that he wrote State Attorney Barry 
Krischer a memo in May suggesting he disqualify himself from the case. 
https://www.palml,eachdallynews.com/article/20060729/NEWS/190917573 
1/4 

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11/11/2019 
Police say lawyer tried to discredit teenage girls• News• Palm Beach Daily News• Palm Beach, Fl 
The case originally was going to be presented to the grand jury in February, but 
was postponed after Dershowitz produced information gleaned from the Web 
site myspace.com showing some of the alleged victims commenting on alcohol 
and marijuana usei according to the police report prepared by Detective Joseph 
Recarey. 
Haley Robsoni a 20-year-old Royal Palm Beach woman who told police she 
recruited girls for Epstein, also is profiled on myspace.com. Her page includes 
photos of her and her friends, including one using the name "Pimpin' Made EZ." 
Robson, who was not charged in the case, is a potential prosecution witness. 
According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys 
Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with 
Epstein 1 accepted the deal, in which Epstein would plead guilty to one count of 
aggravated assault with intent to commit a felony, be placed on five years' 
probation and have no criminal record. The deal also called for Epstein to submit 
to a psychiatric and sexual evaluation and have no unsupervised visits with 
minors, according to Recareys report. The plea bargain was made in connection 
with only one of the five alleged victims, the report states. 
Fronstin - who declined to comment on the case - was subsequently fired and 
veteran defense attorney Jack Goldberger was hired. He denies there was any 
agreement by any of Epstein's attorneys to a plea deal. 
"We absolutely did not agree to a plea in this case," he said. Neither Belohlavek 
nor a state attorney's spokesman could be reached for comment. 
The parent or parents of alleged victims who complained of being harassed by 
private investigators provided license tag numbers of two of the men. Police 
found the vehicles were registered to a private eye in West Palm Beach and 
another inJupiteri according...

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11/11/2019 
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL 
who did talk "will be dealt with," the woman said she was told. Phone records 
show the woman talked with the person who allegedly intimidated her around 
the time she said, Recarey reported. 
Phone records also show that the person said to have made the threat then 
placed a call to Epstein's personal assistant, who in turn called a New York 
corporation affiliated with Epstein, the report states. 
The issue in the Epstein case is not whether females came to his waterfront 
home, but whether he knew their ages. 
"He's never denied girls came to the house," Goldberger said. But when Epstein 
was given a polygraph test, "he passed on knowledge of age," the attorney said. 
After the indictment against Epstein was unsealed this week, Police Chief Reiter 
referred the matter to the FBI. "We've received the referral, and we're reviewing 
it," said FBI spokeswoman Judy Orihuela in Miami. 
The chief himself has come under attack from Epstein's lawyers and friends in 
New York, where he has a home. The New York Post quoted Epstein's 
prominent New York lawyeri Gerald Lefcourt, as saying his client was indicted 
only ''because of the craziness of the police chief." 
Reiter has declined to comment on the case. 
Prosecutors have not presented a sex-related case like Epstein's to a grand jury 
before, said Mike Edmondson, spokesman for the state attorney's office. "That's 
what you do with a case that falls into a gray area," he said. 
The state attorney's office did not recommend a particular criminal charge on 
which to indict Epstein, Edmondson said. The grand jury was presented with a 
list of charges from highest to lowest, then deliberated with the prosecutor out of 
the room, he said. 
"People are surprised at the grand jury proceeding," West Palm Beach defense 
attorney Richard Tendler said. "It's a way for the prosecutor's office to not t...

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11/11/2019 
Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL 
Defense attorney Robert Gershman was a prosecutor for six years. "Those girls 
must have been incredible or untrustworthy, [ don't know," he said. 
Other attorneys said Epstein's case raises the issue of whether wealthy, connected 
defendants like Epstein - whose friends include former President Clinton and 
Donald Trump - are treated differently from others. Once he knew he was the 
subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as 
Dershowitz and Lefcourt, who is a past president of the National Association of 
Criminal Defense Lawyers. 
Miami lawyer Roy Black - who became nationally known when he successfully 
defended William Kennedy Smith on a rape charge in Palm Beach - also was 
involved at one point. 
Said defense attorney Michelle Suskauer: "I think it's unfortunate the public may 
get the perception that with power, you may be treated differently than the 
average Joe." 
https://www.palmbeachdailynews.com/articJe/20060729/NEWS/190917573 
4/4 

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The Palm Beach Post 
REAL NEWS STARTS H 
Expert: Ignorance of age isn't 
defense in sex cases 
Posted Aug 5, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 1 :38 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Aug. 5, 2006) 
Even if Palm Beach money manager Jeffrey Epstein didn't 
know that girls who police say gave him sexual massages at 
his Intracoastal home were under the legal age, that alone 
wouldn't have exempted him from criminal charges of 
sexual activity with minors. 
"Ignorance is not a valid defense," said Bob Dekle, a legal 
skills professor who was a Lake City prosecutor for nearly 
30 years, half of that time specializing in sex crimes against 
children. 
"There is no knowledge element as far as the age is 
concerned," Dekle said. 
After an 11-month investigation, Palm Beach police said 
there was probable cause to charge Epstein, 53, with 
unlawful sex acts with a minor and lewd and lascivious 
molestation. They contend that Epstein - friend of the rich 
and famous and financial patron of Democratic Party 
organizations and candidates - committed those acts with 
five underage girls. 
In the past week, New York Attorney General and 
gubernatorial candidate Eliot Spitzer has returned about 
$50,000 in campaign contributions he received from 
Epstein, and Mark Green, a candidate to replace Spitzer in 

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his current job, has returned $10,000 to him because of the 
Palm Beach scandal, the New York Daily News has 
reported. 
Rather than file charges, the state attorney's office 
presented the case to a county grand jury. The panel 
indicted Epstein last week on a single, less serious charge of 
felony solicitation of prostitution. 
The case raised eyebrows because the state attorney's office 
rarely, if ever, kicks such charges to a grand jury. And it 
increases the difficulty of prosecuting child sex abuse cases, 
especially when the defendant is enormously wealthy and 
can hire high-priced, top-tier lawyers. 
At least one of Epstein's alleged victims told police he knew 
she was underage when the two of them got naked for 
massages and sexual activity. She was 16 years old at the 
time and said Epstein asked her questions about her high 
school, according to police reports. 
A girl who said she met Epstein when she was 15 said he 
told her if she told anybody what happened at his house, 
bad things could happen, the police reports state. 
Epstein's youngest alleged victim was 14 when she says she 
gave him a massage that included some sexual activity. She 
is now 16. The girl's father says he doesn't know whether 
she told Epstein her age. 
"My daughter has kept a lot of what happened from me 
because of sheer embarrassment," he said. ''But she very 
much looked 14. Any prudent man would have had second 
thoughts about that." 
Defense attorney Jack Goldberger maintains that not only 
did Epstein pass a polygraph test showing he did not know 
the girls were minors, but their stories weren't credible. 
The state attorney's office also implied that their credibility 
was an issue when it decided not to charge Epstein directly, 
but instead give the case to the grand jury. 

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"A prosecutor has to look at it in a much broader fashion/' a 
state attorney's spokesman said last week. 
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Epstein hired Harvard law Professor Alan Dershowitz 
when he became aware he was under investigation, and 
Dershowitz gave prosecutors information that some of the 
alleged victims had spoke of using alcohol and marijuana on 
a popular Web site, according to a Palm Beach police 
report. 
Prosecutors typically consider two things in deciding 
whether to charge somebody with sex-related offenses 
against minors - whether there is sufficient evidence and 
whether there is a public interest in doing so, Dekle said. 
If two teens are in a sexual relationship and the boy turns 
18 before the girl, he could be charged with a sex crime if 
the sex continues. There would be no public interest in 
pursuing that, Dekle said. 
But where there is a large gap in ages - and especially in 
cases of teachers with students - there is a public interest in 
prosecuting, he said. Likewise if the accused has a track 
record of sex with minors. 

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Still there is a "universal constant" in prosecuting these 
cases, Dekle said. Men who exploit underage children for 
sex often carefully choose their victims in ways that will 
minimize the risk to them, he said. 
Victims usually are from a lower social status, and they may 
suffer from psychological problems, Dekle said. 
"Lots of child sexual abuse victims have been victimized by 
multiple people over a period of time. Then the act of abuse 
produces behavior in the victims that further damages their 
credibility." Examples include promiscuous behavior and 
drug abuse. 
Some of the alleged victims in the Epstein case returned to 
his home multiple times for the massage sessions and the 
$200 to $300 he typically paid them per visit. "That would 
be a definite problem for the prosecutor," said Betty Resch, 
who prosecuted crimes against children in Palm Beach 
County for five years and now is in private practice in Lake 
Worth. 
'The victim becomes less sympathetic" to a jury, Resch said. 
"But she's a victim nevertheless. She's a kid." 
Most men charged with sex crimes against minors look 
normal, Dekle said. A jury expecting to see a monster 
seldom will. And the victims' ages work against them and in 
favor of the defendant in a trial, Dekle said. 
If a child and an adult tell different stories and both swear 
they're telling the truth, adult jurors are more likely to 
believe the adult, Dekle said. 
"You have all these things working against you in a child 
sex abuse case. Prosecutors normally try to be very careful 
in filing those cases because they know what they're getting 
into. There is no such thing as an iron-clad child sexual 
abuse case." 

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The Palm Beach Post 
REAL NEWS STARTS IIRE 
Epstein camp calls female accusers 
liars 
Posted Aug 8, 2006 at 12:01 AM 
Updated Oct 3, 2019 at 3:35 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on Aug. 8, 2006) 
Attorneys and publicists for Palm Beach financier Jeffrey 
Epstein went on the offensive Monday, contending that 
teenage girls who have accused Epstein of sexual 
shenanigans at his waterfront home are liars and saying 
that the Palm Beach Police Department is "childish." 
"There never was any sex between Jeffrey Epstein and any 
underage women," his lead attorney,Jack Goldberger, said 
from Idaho where he was vacationing with his family. 
Epstein did have young women come to his house to give 
him massages, Goldberger said. "Mr. Epstein absolutely 
insisted anybody who came to his house be over the age of 
18. How he verified that, I don't know. The question is, did 
anything illegal occur. The law was not violated here." 
He had no explanation as to why Epstein would pay girls or 
women with no massage training - as the alleged victims 
said was the case - $200 to $300 for their visits. "The 
credibility of these witnesses has been seriously 
questioned," Goldberger said. 
Epstein, 53, was indicted by a county grand jury last month 
on a charge of felony solicitation of prostitution. After an 
11-month investigation that included sifting through 
Epstein's trash and surveilling his home, Palm Beach police 
concluded there was enough evidence to charge him with 
sexual activity with minors. When the grand jury indicted 

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Epstein on the less serious charge1 Police Chief Michael 
Reiter referred the case to the FBI to determine whether 
there were federal law violations. 
After a spate of stories about the case last week1 New York 
publicist Dan Klores - whose client list has included Paris 
Hilton and Jennifer Lopez - said on Saturday that Epstein's 
camp was ready "to get their story out." 
They did that Monday via Goldberger and a Los Angeles 
publicist for Miami criminal defense attorney Roy Blacki 
who also has represented Epstein in the case. 
'We just think there has been a distorted view of this case 
in the media presented by the Palm Beach police," 
Goldberger said. 
Reiter has consistently declined to comment on the case 
and did not respond to a request for comment Monday. 
The implication that State Attorney Barry Krischer was 
easy on Epstein by presenting the case to a grand jury 
rather than filing charges directly against him is wrong1 
Goldberger said. 

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The Palm Beach Police Department was "happy and 
ecstatic" that the panel was going to review the evidence. "l 
think what happened is they weren't happy with the result. 
They decided to use the press to embarrass Mr. Epstein." 
But records show that Reiter wrote Krischer on May 1 -
well before the case went to the grand jury - suggesting that 
Krischer "consider if good and sufficient reason exists to 
require your disqualification from the prosecution of these 
" 
cases. 
Rather than flat-out decline to charge Epstein, Krischer 
referred the case to the grand jury to "appease" the chief, 
Goldberger said. 
A state attorney's spokesman would say only that the office 
refers cases to the grand jury when there are issues with the 
viability of the evidence or witnesses' credibility. 
Both the state attorney and the grand jury concluded there 
was not sufficient evidence that Epstein had sex with 
minors, according to Goldberger. "It was just a childish 
performance by the Palm Beach Police Department," 
Goldberger said. 
The defense attorney said one of the alleged victims who 
claimed she was a minor was in fact over the age of 18. 
Another alleged victim who was subpoenaed to testify to 
the grand jury failed to do so. Epstein's accusers, he added, 
have histories of drug abuse and thefts. "These women are 
liars. We've established that." 
But why would they all invent their stories about meeting 
Epstein for sexual massages? 
"I don't have an answer as to what was the motivation for 
these women to come forward and make these allegations," 
Goldberger said. 

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News1 ,.Jr. ,er1.'.;-
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The Palm Beach Post (Wes1 Palm Beach, Florida)· 14 Aug 2006, Mon• Page 7 
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Reiter focus of fire 1n Epstein case 
Clipped By: 
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Sat, Apr 22, 2017 
Copyright© 2019 Newspapers.com. All Rights Reserved. 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Delays in Epstein case unusual, 
lawyers say 
Posted Mar 13, 2007 at 12:01 AM 
Updated Oct 3, 2019 at 3:48 PM 
(EDITOR'S NOTE: This story originally published in The Palm 
Beach Post March 13, 2007) 
A federal probe or a plea deal could explain the wait in the 
Palm Beacher's solicitation case. 
Nearly eight months after Palm Beach tycoon Jeffrey 
Epstein was charged with felony solicitation of prostitution, 
there has been no discernible progress in his case. No 
witnesses deposed. No trial date set. Nothing, save for 
routine court hearings reset without explanation. 
"Usually that would be unusual," said criminal defense 
attorney Glenn Mitchell, who has no involvement in the 
case. 
"As a general rule, it would be unusual for nothing to have 
happened," agreed Michael Dutko, a criminal defense 
attorney in Fort Lauderdale. He represents Haley Robson, 
20, of Royal Palm Beach, potentially a key witness in the 
case. 
A routine hearing for Epstein was pulled from the court 
docket last week and reset for May 16. The delays and 
inaction could be due to a potential federal probe of Epstein 
or because a plea deal is in the workst attorneys say. 
Unusual is the word that best describes everything about 
the case against Epstein, 54, an enigmatic money manager 
in New York City who counts Bill Clinton and Donald 
Trump among his friends. 

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"Highly unusual" is how Palm Beach Police Chief Michael 
Reiter described State Attorney Barry Krischer's handling 
of the case in a bluntly critical letter to Krischer last year 
before Epstein was indicted. 
Reiter referred the matter to the FBI to determine whether 
any federal laws had been violated. Epstein's allies 
countered by attacking the chief personally and 
professionally. 
Reiter's department investigated Epstein for 11 months. 
Police sifted repeatedly through his trash and conducted 
surveillance on his five-bedroom, 7 1/2-bath, 7,234-square-
foot home on the Intracoastal Waterway. 
Police said Epstein paid women and girls as young as 14 to 
give him erotic massages at his home. Police thought there 
was probable cause to charge him with unlawful sex acts 
with a minor and lewd and lascivious molestation. 
Epstein responded by hiring a phalanx oflawyers. One of 
them, Harvard law professor and author Alan Dershowitz, 
provided the state attorney's office with information about 
alcohol and marijuana use by some of the girls who said 
they were with Epstein. 
Prosecutors then referred the case to the grand jury rather 
than file charges directly against Epstein. 
Epstein's attorneys deny he had sex with underage girls. 
The lawyers say the girls' stories are not credible. But if the 
court file is any indicator, they've made no effort to depose 
the girls. 
Neither prosecutors nor defense attorneys have sought to 
question Robsoni said Dutko, her attorney. She recruited 
teenage girls to visit Epstein for massages and sexual 
activity, Palm Beach police saidi and presumably would be a 
key witness. 

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Epstein's attorney Jack Goldberger did not return phone 
messages. 
A source close to the case suggested it is languishing 
pending a decision by the FBI on whether to refer it to 
federal prosecutors. 
"We still have a pending case," FBI spokeswoman Judy 
Orihuela said Monday. 
State Attorney Krischer did not return a call for comment. 
His spokesman, Mike Edmondson 1 declined to say whether 
federal investigators are delaying the Epstein case. But, he 
added, "if another agency is looking at something, we 
wouldn't want to step on their toes." 
Attorneys say inertia in a criminal case often points to a 
pending plea deal. 
"It would not surprise me if something has happened that's 
not reflected in the court file," said Dutko1 such as an 
agreement that will be formalized later. 
Defense attorney Marc Shiner said defense attorneys 
sometimes put off overtly conducting discovery -- deposing 
witnesses1 requesting documents and the like -- because 
doing so creates more work for harried prosecutors who 
may become angry and not offer a plea deal. 
"Sometimes defense lawyers, knowing that1 will try and do 
discovery without taking depositions," said Shiner, a former 
prosecutor for 13 years. 
Instead, they may conduct a below-the-radar probe such as 
having a private investigator check out leads, he said. 
Shiner and others say a plea deal for Epstein probably 
would result in pretrial intervention, in which a defendant 
may be ordered to undergo a psychological evaluation, 
counseling or other conditions in return for dropping the 
charge. 

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Edmondson, spokesman for State Attorney Krischer, said 
there is no plea offer and no request for the prosecution to 
show its cards. 
"To my knowledge, it's never happened before on a filed 
"h 
'd 
case, 
e sa1 . 

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252 I 278 - Thursday, October 18, 2007 
Edition: FINAL 
Section: LOCAL 
Page: 5B 
Source: The Associated Press 
Illustration: PHOTO (B& W) 
Memo: Ran all editions. 
Dateline: NEW YORK 
WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16 
A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage 
prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had 
sought his help becoming a model. 
The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had 
the teen perform a sex act when she brought photographs of herself for him to review in his Upper 
East Side mansion sometime in 2000. 
Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get 
you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice" 
included massages and other favors. 
When the girl told Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I 
won't tell anybody," court papers say. 
Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been 
indicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending. 
The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural 
sex acts" while she was a minor, the lawsuit says. 
Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends, 
stating, 'Corne by with your friends your age next time. Don't bring Sherrie (a mutual friend in her 
40s). I love girls your age.' " 
The young woman, now 23, kept returning to Epstein because she has "mental issues," said her 
lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result 
of severe mental disease and defect." 
Epstein's lawyer in New York, Gerald Lefcourt, said, "Th...

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The Palm Beach Post 
REAL NEWS STARTS & 
Palm Beacher pleads in sex case 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 3, 2019 at 1:47 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on July 1, 2008) 
Jeffrey Epstein will serve 1 1/2 years on teen solicitation 
charges. 
He lives in a Palm Beach waterfront mansion and has kept 
company with the likes of President Clinton, Prince 
Andrew and Donald Trump, but investment banker Jeffrey 
Epstein will call the Palm Beach County Jail home for the 
next 18 months. 
Epstein, 55, pleaded guilty Monday to felony solicitation of 
prostitution and procuring a person under the age of 18 for 
prostitution. After serving 18 months in jail, he will be 
under house arrest for a year. And he will have a lifelong 
obligation to register as a sex offender. He must submit to 
an HIV test within 48 hours, with the results being 
provided to his victims or their parents. 
As part of the plea deal, federal investigators agreed to drop 
their investigation of Epstein, which they had taken to a 
grand jury, two law enforcement sources said. 
Epstein was indicted two years ago after an 11-month 
investigation by Palm Beach police. They received a 
complaint from a relative of a 14-year-old girl who had 
given Epstein a naked massage at his five-bedroom, 7,234-
square-foot, $8.5 million Intracoastal home. 
Police concluded that there were several other girls brought 
in 2004 and 2005 to an upstairs room at the home for 
similar massages and sexual touching. 

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The indictment charged Epstein only with felony 
solicitation of prostitution. The state attorney's office later 
added the charge of procuring underage girls for that 
purpose. 
Prosecutor Lanna Belohlavek said of the plea: "I took into 
consideration the length the trial would have been and 
witnesses having to testify" about sometimes embarrassing 
incidents. 
Epstein may have made a serious mistake soon after he was 
charged. He rejected an offer to plead guilty to one count of 
aggravated assault with intent to commit a felony, 
according to police documents. He would have gotten five 
years' probation, had no criminal record and not been a 
registered sex offender, the documents indicate. 
Epstein arrived in court Monday with at least three 
attorneys. He wore a blue blazer, blue shirt, blue jeans and 
white and gray sneakers. After Circuit Judge Deborah Dale 
Pucillo accepted the plea, he was fingerprinted. Epstein 
then removed his blazer and was handcuffed for the trip to 
jail while his attorneys tried to shield him from 
photographers' lenses. 
When he eventually is released to house arrest, Epstein will 
have to observe a 10 p.m. to 6 a.m. curfew, have no 
unsupervised contact with anyone younger than 18 and 
neither own nor possess pornographic or sexual materials 
"that are relevant to your deviant behavior," the judge said. 
Epstein will be allowed to leave home for work. The New 
York-based money manager told the judge he has formed 
the not-for-profit Florida Science Foundation to finance 
scientific research. 'Tm there every day," Epstein said. 
The foundation was incorporated in November. Epstein 
said he already has awarded money to Harvard and MIT. 

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When he is released from jail, there is a chance that Epstein 
will be forced to move. Sex offenders are not allowed to live 
within 1,000 feet of a school, park or other areas where 
children may gather. No determination has been made as to 
whether Epstein's home complies, but attorneys said it 
likely does. 
Sex offenders also typically must attend counseling sessions. 
Belohlavek said that was waived for Epstein because his 
private psychiatrist is working with him. The judge was 
skeptical but agreed to it. 
Epstein's legal woes don't end with Monday's plea. There 
are four pending federal civil lawsuits and one in state court 
related to his behavior. At least one woman has sued him in 
New York1 where he owns a 51,000-square-foot Manhattan 
mans10n. 
"It's validation of what we're saying in the civil cases," said 
Miami attorney Jeffrey Herman, who represents the alleged 
victims in the federal lawsuits. West Palm Beach attorney 
Ted Leopold represents one alleged victim in a civil suit in 
state court. He said he anticipates amending that lawsuit to 
add "a few other clients" as well. 
In the criminal case1 police went so far as to scour Epstein's 
trash and conduct surveillance at Palm Beach International 
Airport, where they watched for his private jet so they 
would know when he was in town. They concluded that 
Epstein paid girls $200 to $300 each after the massage 
sessions. 
'Tm like a Heidi Pleiss," Haley Robsoni now 22, told police 
about her efforts in recruiting girls for Epstein. 
There was probable cause to charge Epstein with unlawful 
sex acts with a minor and lewd and lascivious molestation, 
police concluded. 

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The state attorney's office said questions about the girls' 
credibility led it to take the unprecedented step of 
presenting the evidence against Epstein to a grand jury, 
rather than directly charging him. 
Palm Beach Police Chief Michael Reiter was furious with 
State Attorney Barry Krischer, saying in a May 2006 letter 
that the prosecutor should disqualify himself. "I continue to 
find your office's treatment of these cases highly unusual," 
he wrote. He then asked for and got a federal investigation. 
Epstein hired a phalanx of high-priced lawyers - including 
Harvard law professor and author Alan Dershowitz - and 
public relations people who questioned Reiter's competence 
and the victims' truthfulness. 
In addition to mansions in Palm Beach and Manhattan, 
Epstein owns homes in New Mexico and the Virgin Islands. 
He's a frequent contributor to Democratic Party candidates. 
He also donated $30 million to Harvard in 2003. 
Former New York Gov. Eliot Spitzer returned a $50,000 
campaign contribution from Epstein after his indictment, 
then resigned this year during his own sex scandal. And the 
same Palm Beach Police Department that vigorously 
investigated Epstein returned his $90,000 donation for the 
purchase of a firearms simulator. 
Staff writer Eliot Kleinberg and former staff researcher 
Michelle Quigley contributed to this story. 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Jeffrey Epstein: Scientist, 
stuntman, 'sex slave' visit jailed 
tycoon 
By LARRY KELLER / Palm Beach Post Staff Writer 
Posted Aug 13, 2008 at 12:01 AM 
Updated Jul 16, 2019 at 4:54 PM 
Tycoon Jeffrey Epstein mingled with an eclectic mix of 
people, including beautiful young women, before he got 
into trouble for paying teenage girls to give him sexual 
massages at his Palm Beach mansion. 
Not much has changed, even though he now resides in a 
dorm at the Palm Beach County Sheriffs Office's 17-acre, 
967-bed stockade near the fairgrounds. 
During his first month of confinement, Epstein was visited 
by the female assistant who, girls told police, had escorted 
them to the room at his mansion where they gave him 
naked massages. 
Also trekking to the jail was a young woman whom Epstein 
purportedly described as his Yugoslavian sex slave. 
The wealthy financier and science wonk also has been 
visited by an expert on artificial intelligence, as well as a 
man who is a mixed martial arts aficionado and sometime 
movie stuntman. 
The only other people to visit him at the jail, according to 
records, are a Singer Island man and an individual who 
listed Epstein's Palm Beach address as his own. 
Epstein, 55, pleaded guilty on June 30 to two prostitution-
related charges and was sentenced to 18 months in jail, 
followed by a year of house arrest. Epstein paid teenage 

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girls $200 to $300 in 2004 and 2005 for massages in his 
home that sometimes included sexual touching, Palm Beach 
police said. 
His jail visitors in July included: 
- Sarah Kellen, 29, who some of the teen masseuses said 
phoned them when Epstein was in town and escorted them 
upon their arrival at his Palm Beach waterfront home to an 
upstairs room, where she prepared the massage table and 
provided the oils for their encounters with him. Kellen 
visited Epstein three times in July, according to a jail 
visitor's log. Kellen lists a Manhattan home address. 
Reached by telephone, she declined to discuss Epstein. 
- Nadia Marcinkova, 23, whose family in Yugoslavia 
Epstein paid money to so that he could bring her to the 
United States to be his "sex slave," two teenage girls told 
police. One girl told police that Epstein instructed 
Marcinkova and her to kiss and have sex while he watched 
and masturbated. Another said she engaged in sex with 
Marcinkova at Epstein's urging. Marcinkova visited Epstein 
in jail four times in 13 days. She lists her address as on the 
Upper East side of Manhattan, not far from Epstein's 
enormous apartment. 
- Roger Schank, 62, founder of the Institute for Learning 
Sciences at Northwestern University and an expert on 
artificial intelligence, paid one visit to Epstein. Schank has 
written numerous books on that subject and has a doctorate 
degree from Yale University in linguistics. He was one of 19 
people who applied to be president of Florida Atlantic 
University in 2003. He became "chieflearning officer" at the 
online Trump University in 2005. Schank listed his address 
as being in Stuart, and records show he also owns a home 
in Lake Worth. 

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Epstein has financed a number of scientists over the years, 
including Nobel Prize winners. He gave $30 million to 
Harvard University in 2003. In November, he formed the 
not-for-profit Florida Science Foundation, which he said 
finances scientific research. 
- Igor Zinoviev, a Russian mixed martial arts fighter, who 
coaches a Chicago team in the International Fight League. 
He also has worked as a personal trainer, celebrity 
bodyguard and movie stuntman, according to the league's 
Web site. The New Jersey resident visited Epstein seven 
times in July. 
Zinoviev, Schank and Marcinkova could not be reached for 
comment. 
Staff researcher Niels Heimeriks contributed to this story. 

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Palm Beach Daily News 
Billionaire sex offender leaves jail 
six days a week for work 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 4, 2019 at 9:27 AM 
Palm Beach billionaire Jeffrey Epstein, who's serving 18 
months in jail for soliciting an underage girl for 
prostitution, is allowed to leave the Palm Beach County 
Stockade six days a week on a work-release program. 
Teri Barbera, spokeswoman for the Palm Beach County 
Sheriffs Office, confirmed that Epstein, 55, has been in the 
work-release program since Oct. 10. 
"He works six days a week: Friday through Wednesday 10 
a.m. to 10 p.m.," Barbera said via e-mail. "(He) works at his 
local West Palm Beach office, monitored on an active GPS 
system (he wears an ankle bracelet). Mr. Epstein hires a 
permit deputy, at his expense, for his own security at his 
workplace during the time he is out." 
Miami attorney Jeffrey Herman represents six young 
women who've sued Epstein, claiming he sexually abused 
them at his Palm Beach home when they were minors. 
Herman said he received a letter about the work-release 
program from the U.S. Attorney's Office within the past 
few days. But Herman says Epstein had been out on work-
release for several weeks before the notification. 
"My clients expressed shock and disappointment," Herman 
said. "I find it incredible that he's on work-release in the 
community and my clients aren't notified of this and we get 
this letter weeks after the fact." 
Jack Goldberger, Epstein's criminal attorney, said the 

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arrangement is not unusual. 
"He goes to work every single day and goes back to jail at 
night, just like everybody else (in the program)," 
Goldberger said. 
Epstein pleaded guilty June 30 to two felony counts: 
soliciting prostitution and procuring a person under 18 for 
prostitution. As part of the plea agreement, Epstein must 
serve one year of house arrest and register as a lifelong sex 
offender. 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Women want Epstein sex plea deal 
unsealed 
Posted Jul 1, 2008 at 12:01 AM 
Updated Oct 2, 2019 at 2:23 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post June 10, 2009) 
Their attorneys will ask a judge to open Jeffrey Epstein's 
records. 
When wealthy money manager Jeffrey Epstein of Palm 
Beach pleaded guilty last year to procuring teens for 
prostitution, his case detoured around local and state rules 
regarding the sealing of court documents. 
At a plea conference on the state charges, a judge, a defense 
lawyer and a prosecutor huddled at the bench and decided 
that a deal Epstein had struck with federal prosecutors to 
avoid charges should be sealed, according to a transcript of 
the hearing. 
And so it was. 
But Florida rules of judicial administration, as well as rules 
of the Palm Beach County court system, require public 
notification that a court document has been or will be 
sealed, meaning kept from public view. The rules also 
require a judge to find a significant reason to seal, such as 
protecting a trade secret or a compelling government 
interest. 
Yet no notification or reason occurred in Epstein's case, 
according to court records. 

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Epstein's own attorneys, in federal filings, have referred to 
his confidential deferred prosecution agreement with the 
U.S. attorney's office, struck in September 2007, as 
"unprecedented" and "highly unusual." And it was "a 
significant inducement" for Epstein to accept the state's 
deal, observed the state judge who accepted his plea, 
County Judge Deborah Dale Pucillo. 
Epstein now faces at least a dozen civil lawsuits in federal 
and state courts filed by young women who said they had 
sex with him and now are seeking damages. 
Attorneys for some of those women want his agreement 
with federal prosecutors unsealed and will ask Circuit Judge 
Jeffrey Colbath to do so today. 
"It is against public policy for these documents to be have 
been sealed and hidden from public scrutiny. As a member 
of the public, E.W. has a right to have these documents 
unsealed," wrote former Circuit Judge Bill Berger, now in 
private practice and representing one of the women. 
The Palm Beach Post also will ask Colbath to unseal the 
agreement. Post attorney Deanna Shullman will argue that 
the public has a right to know the specifics of Epstein's deal. 
According to various media accounts, Epstein moved in 
circles that included President Clinton, Donald Trump and 
Prince Andrew. "International Moneyman of Mystery/' 
declared a 2002 New York magazine profile of Epstein. 
Epstein, 56, is in the Palm Beach County Stockade, serving 
an 18-month sentence after pleading guilty nearly a year 
ago to felony solicitation of prostitution and procuring 
teenagers for prostitution. 
He is allowed out from 7 a.m. to 11 p.m., escorted by a 
deputy, said Palm Beach County Sheriffs Office 
spokeswoman Teri Barbera. 

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During a Palm Beach Police Department investigation, five 
victims and 17 witnesses gave statements. They told of 
young women brought by his assistants to Epstein's 
mansion on El Brillo Way for massages and sexual activity, 
and then being paid afterward. 
At Epstein's plea conference last year, his attorney,Jack 
Goldberger, and then-Assistant State Attorney Lanna 
Belohlavek approached Pucillo in a sidebar conference. 
Pucillo, who had left the bench nine years earlier, was 
filling in temporarily as a senior judge. 
According to a transcript, Goldberger told Pucillo that 
Epstein had entered a confidential agreement with the U.S. 
attorney's office in which federal prosecutors brokered not 
pursuing charges against him ifhe pleaded guilty in state 
court. Pucillo then said she wanted a sealed copy of the 
agreement filed in his case, and Goldberger concurred that 
he wanted it sealed. Belohlavek later signed off on it. 
The Florida Supreme Court has expressed "serious concern" 
and launched an all-out inquiry into sealing procedures 
across the state following media reports in 2006 of entire 
cases being sealed and disappearing from court records. 
"The public's constitutional right of access to court records 
must remain inviolate, and this court is fully committed to 
safeguarding this right," justices wrote in their final report. 
Epstein's office on Tuesday referred any questions to 
Goldberger, who declined to comment. Pucillo also has 
declined to comment. 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Epstein secret pact with Feds 
reveals "highly unusual" terms 
Posted Jun 10, 2009 at 12:01 AM 
Updated Oct 4, 2019 at 9:23 AM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on September 19, 2009) 
A secret non-prosecution agreement multimillionaire 
financier Jeffrey Epstein struck with federal prosecutors is 
being called "highly unusual" by former federal prosecutors 
and downright outrageous by attorneys now representing 
young women who serviced him. 
The deal reveals that the FBI and the U.S. Attorney's Office 
investigated him for several federal crimes, including 
engaging minors in commercial sex. The crimes are 
punishable by anywhere from 10 years to life in prison. 
But federal prosecutors backed down and agreed to recall 
grand jury subpoenas if Epstein pleaded guilty to 
prostitution-related felonies in state court, which he 
ultimately did. He received an 18-month jail sentence, of 
which he served 13 months. 
The U.S. Attorney's Office also agreed not to charge any of 
Epstein's possible co-conspirators: Sarah Kellen, Adriana 
Ross, Lesley Groff and Nadia Marcinkova. 
The deal was negotiated in part by heavyweight New York 
criminal defense attorney Gerald Lefcourt. 
Unsealed on Friday after attorneys for some of Epstein's 
victims and The Palm Beach Post sought its release, it offers 
the first public look at the deal Epstein's high-powered legal 
counsel brokered on his behalf. 

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Mark Johnson of Stuart, a former federal prosecutor, 
described the disparity in potential sentences as unusual1 
but even more so a provision on attorney payment. 
The first draft of the agreement in September 2007 
required that Epstein pay an attorney -- tapped by the U.S. 
Attorney's Office and approved by Epstein -- to represent 
some of the victims. That attorney is prominent Miami 
lawyer Bob J osefsberg. 
But an addendum to the agreement signed the following 
month struck Epstein's duty to pay Josefsberg ifhe and the 
victims did not accept settlements -- capped at $150,000 --
and instead pursued lawsuits. 
Johnson said it appears the government was trying to 
balance the lesser sentence for Epstein with recovering 
$150,000 for each victim. ''I've never, ever seen anything 
like that in my life," he said. "It's highly unusual." 
The deal does not say whether any victims were contacted 
or consulted before the deal was made. 
Attorney Brad Edwards of Fort Lauderdale, who represents 
three of the young women, believes that none of the 30 to 
40 woman identified as victims in the federal investigation 
were told ahead of time. Edwards said his clients received 
letters from the U.S. Attorney's Office months after the deal 
was signed, assuring them Epstein would be prosecuted. 
"Never consulting the victims is probably the most 
outrageous aspect of it," Edwards said. "It taught them that 
someone with money can buy his way out of anything. It's 
outrageous and embarrassing for United States Attorney's 
Office and the State Attorney's Office." 
Epstein now faces many civil lawsuits filed by the women1 
who are represented by a variety of attorneys. In many, the 
allegations are the same: that Epstein had a predilection for 
teenage girls, identified poor1 vulnerable ones and used 

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other young women to lure them to his Palm Beach 
mansion. They walked away with between $200 and 
$1,000. 
Former Circuit Judge Bill Berger, also representing victims, 
called the agreement a "sweetheart deal." 
"Why was it so important for the government to make this 
deal?'' Berger asked rhetorically. "We have not yet had an 
honest explanation by any public official as to why it was 
made ... and why the victims were sold down the river." 
Former federal prosecutor Ryon McCabe described the 
agreement as "very unorthodox." Such agreements, he said, 
are usually reserved for corporations, not individuals. 
"It's very, very rare. I've never seen or heard of the 
procedure that was set up here," said McCabe, who has no 
involvement in any Epstein litigation. 
"He's essentially avoiding federal prosecution because he 
can afford to pay that many lawyers to help those victims 
review their cases .... If a person has no money, he couldn't 
be able to strike a deal like this and avoid federal 
prosecution." 
The backroom deal with federal prosecutors is all the more 
interesting in light of the legal powerhouses who have 
worked for Epstein, including Harvard professor Alan 
Dershowitz and Bill Clinton investigator Kenneth Starr. 
Lefcourt is a past president of the National Association of 
Criminal Defense Lawyers. 
Epstein's local defense attorney,Jack Goldberger, issued a 
statement Friday saying he had fought the release of the 
sealed agreement to protect the third parties named there. 
"Mr. Epstein has fully abided by all of its terms and 
conditions. He is looking forward to putting this difficult 
period in his life behind him. He is continuing his long-
standing history of science philanthropy." 

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The investigation triggered tensions between police and 
prosecutors, with then-Palm Beach Chief Michael Reiter 
saying in a May 2006 letter to then-State Attorney Barry 
Krischer that the chief prosecutor should disqualify himself. 
"I continue to find your office's treatment of these cases 
highly unusual," Reiter wrote. He then asked for and got 
the federal investigation that ended in the sealed deal. 
"The Jeffrey Epstein matter was an experience of what a 
many-million-dollar defense can accomplish," Reiter told 
the Palm Beach Daily News upon his retirement. 

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187 / 278 - Wednesday, January 27, 2010 
Edition: FINAL 
Section: LOCAL & BUSINESS 
Page: 3B 
Source: By JANE MUSGRAVE Palm Beach Post Staff Writer 
Dateline: WEST PALM BEACH 
JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS 
In a decision that could spark a constitutional showdown over privacy rights, a judge 
Tuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to 
subpoena abortion records from women who are seeking millions in damages from the part-
time Palm Beach resident. 
Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut 
the women's claims that they suffered psychological ills after being paid to give him 
sexually-charged massages at his Palm Beach mansion when they were as young as 14. 
Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records, 
he said, can't be sought until the women are asked whether they have ever had an abortion, 
how many and where. Further, he said, the records would not be made public and might not 
be admissible during trial. 
But, he said, since the women claim Epstein, now 57, is responsible for their emotional 
distress, his attorneys can explore the impact of other events. Medical records, Hafele said, 
are a better source of information than a person's memory. 
Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm 
Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky 
constitutional grounds. 
"These records are protected by our constitutional right of privacy," he said, referring to the 
Florida Constitution. 
After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the 
records. 
In another ruling Wednesday, Hafele also said that videos from depositions in the state cases 
can't be released without a court order. The ruling came after Epstein attorney Robert Critton 
complained that...

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The Palm Beach Post 
REAL NEWS STARTS IIRE 
Epstein Journal's Findings Could 
Resurrect Case 
By Jane. Musgrave 
Posted Sep 17, 2019 at 12:01 AM 
Updated Oct 1, 2019 at 10:51 AM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on March 20, 2010) 
A purloined journal that is said to contain the names of 
"hundreds" of victims of convicted sex offender Jeffrey 
Epstein could be used to reopen the investigation into the 
multi-millionaire's appetite for teenage girls, an attorney 
representing seven of the victims said Friday. 
New details about the contents of the journal were released 
this week when Alfredo Rodriguez, who worked as a 
property manager for the Palm Beach resident, pleaded 
guilty to obstruction of justice for lying to federal agents 
when asked ifhe had any information about his former 
boss' criminal activity. He later tried to sell the journal he 
stole from Epstein for $50,000 to an unidentified person, 
who alerted authorities, according to court records. 
As part of the plea agreement, federal prosecutors said the 
journal "contains information material to the Epstein 
investigation, including the names of material witnesses 
and additional victims." 
"Had the items been produced in response to the inquiries 
of state or federal authorities ... the materials would have 
been presented to the federal grand jury," federal 
prosecutors wrote. 

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Instead, prosecutors short-circuited the grand jury 
investigation and cut a deal with Epstein. They agreed not 
to pursue federal charges if he didn't contest prostitution-
related felonies in state court. The money manager pleaded 
guilty in July 2008 to procuring a minor for prostitution 
and soliciting prostitution. He served 13 months of an 18-
month sentence. 
Attorney Adam Horowitz, who represents seven of the 
roughly 18 women who have filed civil suits against 
Epstein, said the new information could trump the so-
called non-prosecution agreement. 
The multifaceted agreement, he said, deals only with a 
specific list of victims that the U.S. Attorney's Office knew 
about when it penned the deal in 2007. If additional victims 
are listed in the journal Rodriguez stole, Horowitz said 
federal prosecutors could reopen the investigation. 
"It opens the door for further prosecution," he said. 
In addition to turning over the journal to federal agents, 
Rodriguez told them he knew his former boss was having 
sex with underage girls when he worked for him in 2004 
and 2005. He had seen naked girls, who looked like minors, 
in the pool of Epstein's $8.6 million mansion. He had seen 
pornographic images of young girls on Epstein's computer, 
according to court records. 
Neither Epstein's criminal defense attorney,Jack 
Goldberger, nor attorney Robert Critton, who represents 
Epstein in the civil lawsuits, could be reached. Federal 
prosecutors have consistently declined comment. 
The wording of the controversial agreement is unclear. It 
says federal prosecutors would provide Epstein's attorneys 
"with a list of individuals whom it has identified as victims." 
Miami attorney Robert Josefsberg was appointed to 

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represent any of the victims on the list who wanted to 
pursue Epstein in civil court. As part of the agreement, 
Epstein is to pay for Josefsberg to represent the women. 
Some of the women, most identified as Jane Doe in 
lawsuits, had already hired attorneys to represent them. 
Some have since settled their suits with Epstein, although 
terms were not disclosed. 
Horowitz said he has filed court papers to get the journal 
that Rodriguez stole. "It's another piece of evidence that 
shows our clients were at Epstein's mansion," he said. 
Rodriguez told prosecutors he didn't turn over the journal 
when both FBI and Palm Beach police asked for it because 
he wanted money for it. He also said he was afraid Epstein 
would make him "disappear." The information, he told 
investigators, was his "insurance policy." 
He faces a maximum 20 years in prison when he is 
sentenced on June 18. 
jane_musgrave@pbpost.com 
,,,,.,,. __ ,,, ... ,,, ... ,,, ...... --·--······-····-··--
@pbpcourts 

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The Palm Beach Post 
REAL NEWS STARTS HERE 
Epstein paid three women $5.5 million to end underage-
sex lawsuits 
By Jane. Musgrave 
Posted Oct 3, 2017 at 12:01 AM 
Updated Oct 4, 2017 at 12:46 AM 
Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young 
women who claimed he used them as sex toys1 court documents filed last week show he shelled 
out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him. 
Responding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the 
sex scandal, attorney Bradley Edwards said the politically-connected 64-year-old convicted sex 
offender paid more than $1 million to each of the three women Edwards represented. 
Identified in court papers only by their initials or pseudonyms because of the nature of the 
allegations and their youthful ages1 L.M. was paid $1 million1 E.W. $2 million and Jane Doe 
$2.5 million, Edwards said of the settlements he negotiated with Epstein to end the lawsuits. 
Jack Goldberger1 one of Epstein's criminal defense attorneys, on Tuesday declined comment on 
the revelations, citing confidentiality agreements that were part of the settlements. For the 
same reason, he declined to say whether Epstein paid similar amounts to settle roughly two 
dozen lawsuits filed by other young women against Epstein1 claiming he paid them for sex 
when some were as young as 14 years old. 
Attorney Jack Scarola1 who is representing Edwards, said his client was compelled to divulge 
the confidential settlements to answer questions posed by Epstein's attorneys. "Brilliant move 
on their part," he said. 
Even if Epstein's attorneys hadn't opened the door1 Scarola said the information would have 
likely come out. He says the information will help him undermine Epstein's claims that 
Edwards "ginned up" the allegations to help his former law partner, imprisoned and disbarred 
Fort Lauderdale lawyer Scott Rothstein, perp...

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The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute 
between Epstein and Rothstein, both billionaires. 
A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a 
minor for prostitution1 he sued Rothstein and Edwards, claiming they trumped up the 
allegations of sexual molestation to perpetuate the Ponzi scheme. 
Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly 
successful law firm by forging the names of federal judges and others to persuade investors he 
had negotiated settlements in lawsuits against high-profile people. Investors were told they 
could get a cut of the cash. 
One of the high-profile people Rothstein used to lure investors was Epstein1 according to a 
lawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the 
lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the lawsuits 
with the teens for $200 million - a claim Critton described as "a complete fabrication." 
After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him. Edwards accused 
Epstein of filing the lawsuit maliciously to punish him for representing the young women. 
Although Edwards was a partner in Rothstein's now defunct firm, Scarola claims Epstein had 
no evidence Edwards was involved in the Ponzi scheme. Federal prosecutors successfully 
charged other attorneys and members of the firm, but Edwards was never implicated, Scarola 
said in the malicious prosecution lawsuit. 
The revelations about the money Epstein paid to three of the young woman came last week in 
documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit. 
Attorney Tonja Haddad Coleman1 who represents Epstein, on Tuesday sought a delay of the 
trial, in part, because she claimed she has been unable to talk to her client since his estate on his 
private island in the U....

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Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge 
Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those 
victimized by the storm that hammered the Caribbean and roared through South Florida, he 
said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims. 
Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide 
before the case goes to trial. 
Despite Scarola's insistence that Edwards had nothing to do with Rothstein's Ponzi scheme, 
Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's 
well-known friends, such as now President Donald Trump, former President Bill Clinton and 
illusionist David Copperfield, she asked. He used the celebrities as a draw, she said. 
"The Epstein cases were used to fleece money and defraud investors," she said. 
Edward's malicious prosecution case has been difficult for both sides because both Epstein and 
Edwards have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked 
his Fifth Amendment right against self-incrimination when questioned by Scarola. Edwards 
has claimed that much of the information Epstein is seeking is protected by attorney-client 
privilege. 
The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit 
Edwards against Epstein. Edwards also is suing the U.S. attorney's office, claiming it violated 
the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with 
Epstein. 
Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to 
plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court 
records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's 
agreement to settle lawsuits filed against him by dozens of his underage v...

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Palm Beach Daily News 
Judge rules feds' agreement with 
Jeffrey Epstein pact violated teen 
victims' rights 
By Jane. Musgrave 
Posted Sep 17, 2019 at 4:02 PM 
Updated Oct 8, 2019 at 12:31 PM 
(EDITOR'S NOTE: This story originally published in The 
Palm Beach Post on February 22, 2019) 
Federal prosecutors violated the rights of Jeffrey Epstein's 
teenage victims by failing to reveal they had dropped plans 
to prosecute the billionaire on dozens of federal charges in 
connection with the girls' claims that he paid them for sex 
at his Palm Beach mansion, U.S. District Judge Kenneth 
Marra ruled on Thursday. 
In a blistering 33-page ruling, Marra meticulously and 
methodically detailed the numerous steps federal 
prosecutors took to hide the agreement from more than 40 
young women who claim Epstein paid them for sex when 
they were as young as 14. 
"While the government spent untold hours negotiating the 
terms and implications of the NPA with Epstein's attorneys, 
scant information was shared with the victims/' Marra 
wrote. "Instead, the victims were told to be 'patient' while 
the investigation proceeded." 
By then, it was too late. A deal had already been cut with 
then-South Florida U.S. Attorney Alex Acosta and Epstein's 
attorneys to shelve a 52-page federal indictment against 
Epstein, a former math teacher turned money manager 
who counts Presidents Donald Trump and Bill Clinton 
among his friends. 

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Prosecutors' failure to alert the young women about the 
deal violated the Crime Victims' Rights Act, Marra ruled. 
"At a bare minimum the (act) required the government to 
inform (the young women) that it intended to enter into an 
agreement not to prosecute Epstein," he wrote. 
Still, Marra said he wasn't second-guessing prosecutors' 
decision not to pursue Epstein on federal charges if he 
pleaded guilty to minor state prostitution charges and 
agreed to compensate his victims for the trauma he caused. 
"The court is not ruling that the decision not to prosecute 
was improper/' Marra wrote. "The court is simply ruling 
that, under the facts of this case, there was a violation under 
the CVRA." 
Further I he made no decision about what the remedy 
should be. He gave prosecutors and attorneys representing 
the young women 15 days to meet to decide how to unravel 
the complex legal web that has been hanging over Epstein 
and his young victims for more than a decade. 
The chances an accord will be reached are slim, said 
attorney Jack Scarola, who is representing the two Jane 
Does who challenged the prosecutors' actions. 
Further, he said, there is no road map to follow. The 
lawsuit attorney Bradley Edwards filed on behalf of the two 
unidentified young women, claiming prosecutors violated 
the federal act, is unique, he said. 
"We are treading on virgin ground, to use what is probably 
an inappropriate phrase in this situation," he said. 
Scarola said he and Edwards will ask that the non-
prosecution agreement be thrown out. That would open 
the possibility that the long-shelved federal indictment 
could be dusted off and filed against the 66-year-old 
Epstein, who spends most of his time on a private island he 
owns in the U.S. Virgin Islands. 

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"I don't see the government conceding to that remedy," 
Scarola admitted. Further, he said, it is likely Epstein will be 
allowed to weigh in. Miami attorney Roy Black years ago 
filed papers asking to intervene on Epstein's behalf. 
The U.S. Attorney's Office said it wouldn't comment on 
Marra's ruling. Neither Black nor New York City attorney 
Jay Lefkowitz, who led efforts to bury the federal 
indictment, responded to emails or phone calls for 
comment. West Palm Beach attorney Jack Goldberger, who 
represents Epstein, also didn't respond. 
Scarola said it is likely Epstein's star-studded legal team will 
argue that Epstein fully complied with the terms of the 
agreement he made in 2007 with federal prosecutors and 
therefore the agreement can't be undone. 
As he promised, Epstein pleaded guilty in June 2008 to state 
charges of soliciting a minor for prostitution and soliciting 
prostitution. He served 13 months of an 18-month jail term 
in a vacant wing of the county stockade that he was allowed 
to leave 12 hours a day, six days week. 
Further, as agreed, he paid settlements to the young women 
who sued him. While the settlements were confidential, 
court records show he paid three women a total of $5.5 
million. 
In return, federal prosecutors held up their end of the 
bargain. Their investigation ceased. 
Having done all that prosecutors asked of him, Scarola said 
Epstein will make a simple argument: "You can't turn 
around and deprive me of the benefits I bargained for." 
However, Scarola said, using Marra's ruling, he will counter 
that the contract Epstein signed was illegal and therefore 
unenforceable. 

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Even if Marra agrees to toss out the non-prosecution 
agreement, Scarola conceded that doesn't mean Epstein will 
face federal charges. 
"The contract can be set aside and the federal government 
can attempt to enter into the same agreement," he said. 
"Except the spotlight of public attention will be on them 
and the 40 victims will be able to explain to the court why 
this sweetheart deal should not be approved." 
Scarola said that prosecutors may have had good reason not 
to pursue Epstein. "There may be a reasonable explanation 
but we don't know what that reason may have been," he 
said. 
In court papers, federal prosecutors have said that many of 
the young women were afraid to cross the powerful, 
politically connected money manager and simply refused to 
testify against him. 
In other cases, they said, the women changed their stories. 
Jane Doe 2, who is trying to have the non-prosecution 
agreement thrown out, initially described Epstein as "an 
awesome man" and told prosecutors she hoped "nothing 
happens" to him. While she later agreed to testify against 
Epstein, prosecutors said they feared Epstein's attorneys 
would use her words to destroy her if she ever took the 
witness stand. 
Marra, however, said the young woman's comments didn't 
mean she wasn't entitled to know about the prosecutors' 
plans to drop the charges. "There is no dispute that Epstein 
sexually abused Jane Doe 2 while she was a minor," he 
wrote. "Therefore, regardless of her comments to the 
prosecutor, she was a victim." 
Before the case is finally resolved, Scarola predicted that "a 
lot of people are going to have to answer a lot of questions." 

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In his ruling, Marra detailed what appeared to be a cozy 
relationship between Acosta, his line prosecutors and 
Epstein's team of lawyers. His phalanx of lawyers included 
noted Harvard law professor Alan Dershowitz and Kenneth 
Starr, the former U.S. solicitor general whose investigation 
led to the impeachment of President Clinton. 
Marra describes an October 2007 breakfast meeting 
between Acosta, who is now U.S. labor secretary, and 
Lefkowitz shortly after the non-prosecution agreement was 
inked. 
After the meeting, Lefkowitz sent Acosta a note thanking 
him for "the commitment you made to me during our 
October 12 meeting in which you assured me that your 
Office would not ... contact any of the identified 
individuals, potential witnesses, or potential civil claimants 
and their respective counsel in this matter." 
Marra quoted an equally pleasant note then-Palm Beach 
County State Attorney Barry Krischer sent to Assistant U.S. 
Attorney Marie Villafana, who was the lead prosecutor in 
Epstein's case. "Glad we could get this worked out for 
reasons I won't put in writing," Krischer wrote, shortly 
after the non-prosecution agreement was signed. "After this 
is resolved I would love to buy you a cup at Starbucks and 
have a conversation." 
Many of the notes that were exchanged dealt with 
prosecutors' and Epstein's lawyers' shared desire to keep the 
deal secret from Epstein's accusers. In a September email, 
Villafana asked Lefkowitz for guidance about what she 
should reveal. "And can we have a conference call to discuss 
what I may disclose to ... the girls regarding the 
Agreement," she asked. 

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Such cooperation between prosecutors and defense 
attorneys is unusual, Marra said. "It was a deviation from 
the government's standard practice to negotiate with 
defense counsel about the extent of crime victim 
notifications," he wrote. 
Further, he noted, that when Edwards and his two young 
clients asked for information, they were repeatedly misled. 
"The CRV A was designed to protect victims' right and 
ensure their involvement in the criminal justice process," 
Marra wrote. "When the government gives information to 
victims it cannot be misleading." 
Ultimately, the terms of the non-prosecution agreement 
were revealed only after Edwards and attorneys for the 
press successfully sued to make them public. 
jmusgrave@pbpost.com 
@pbpcourts 

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761278 - Tuesday, July 9, 2019 
Edition: Final 
Section: A Section 
Page: 1A 
Source: By Jane Musgrave, The Palm Beach Post 
Epstein indicted on sex charges 
Part-time Palm Beacher pleads not guilty to sex 
trafficking, conspiracy charges in federal court in 
Manhattan 
Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty 
to charges accusing him of creating a vast network of girls as young as 14 that he exploited 
for his sexual pleasure at his homes in Palm Beach and Manhattan. 
The 66-year-old money manager's appearance in U.S. District Court in New York City 
capped more than a decade of recriminations by young women and their attorneys who 
claimed Epstein used his money and political influence to avoid federal prosecution. 
Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking 
charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach 
County Jail for 13 months more than a decade ago. 
However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to 
shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state 
prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is 
now U.S. labor secretary. 
"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey 
Bennan said at a 
morning news conference. "And while the charged conduct is from a number of years ago, it 
is still profoundly important to many of the alleged victims, now young women. They 
deserve their day in court." 
At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to 
keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to 
commit sex trafficking. Epstein paid dozens of young women to give him nude massages 
that, for most, led to sex, he said. 
If convicted of exploiting dozens of young women, including ma...

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"We think he's a significant flight risk," Bennan said of the man who ferried Britain's Prince 
Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and fonner 
President Bill Clinton on his jet, dubbed the Lolita Express. 
Bennan's hard-line stance was welcomed by young women who for years have been told that 
Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement, 
promising not to charge Epstein in federal court. 
Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning 
her into his sex slave and forcing her to have sex with others, including Dershowitz and 
Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she 
told the Associated Press. Dershowitz has vehemently denied Guiffre's claims. 
New York prosecutors were able to ignore the controversial nonprosecution agreement 
because it contained some significant fine print, said former federal Judge Paul Cassell, who 
for years has fought to get the agreement thrown out. It says only that no charges could be 
filed against Epstein in South Florida, he said. 
Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of 
Florida," he said. "The Southern District of New York is not bound by that agreement and 
wasn't a signatory of it." 
That means the sordid allegations that have been leveled at Epstein for years are now part of 
a federal indictment. 
Contrary to Epstein's claims, he knew the women who came to his homes in New York and 
Palm Beach were minors because they told him their ages, according to the indictment. 
Epstein preyed on young girls because he knew they were "vulnerable to exploitation," 
prosecutors added. 
As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while 
he was in New York so they would be available for sex once he returned to Palm Beach, the 
indictment says. The employees weren't n...

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U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime 
Victims
1 Rights Act by not telling Epstein
1s victims about the agreement before it was inked. 
Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight 
Monday, explaining what action Marra should take to redress that wrong. 
Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida 
victims deserve justice in Florida, 
11 said Cassell, who is working on behalf of Epstein's 
victims with attorneys Bradley Edwards and Jack Scarola. 
Since it's likely Florida women will get to testify against Epstein in New York, Scarola said 
he's not focused on whether Epstein will face charges here. Instead, he said he wants to know 
how and why the agreement was reached. 
"There's been no explanation as to how a deal like this could have been cut and how the 
federal government could have been involved in a conspiracy to violate federal law," Scarola 
said of his interest in continuing the legal battle over the nonprosecution agreement. 
When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two 
prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the 
Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He 
was also forced to register as a sex offender and settle civil lawsuits more than 30 young 
women filed against him. 
U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out 
how the agreement came to be. "I am especially more interested in why Epstein got the deal 
he got," Frankel said. "We need to know why he was given such an easy sentence. 
While she has asked the House Oversight Committee to investigate Acosta, Frankel said she 
is not sure that will happen. 
11Itjust seems to me it was a travesty that this guy got off the 
way he did and, without pre-judging ...

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"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you," 
Berman said. A special number, 1-800-CALLFBI, will link victims of authorities. 
Bill Sweeney, assistant director of the FBl's New York office, said after years of being 
ignored by federal agents, the victims' voices will be heard. 
"The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said. 
Turning to address Epstein's victims directly, he said: "Your bravery may empower others to 
speak out against crimes against them." 
jmusgrave@pbpost.com 

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Def.Ex.A-5 

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Pahn Beach County, Florida, SHARON R. BOCK, 
as Clerk & Comptroller, Pahn Beach County, 
Florida, 
Defendants. 
I 
CASE NO: 2019-CA-014681 
DEFENDANT, DAVE ARONBERG, AS STATE ATTORNEY OF PALM BEACH COUNTY, 
FLORIDA'S ANSWER TO FIRST AMENDED COMPLAINT 
AND MOTION TO DISMISS COUNT II 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, ("SAO"), 
by and through the undersigned attorney, hereby answers Count I of the First Amended Complaint of 
Plaintiff, CA Florida Holdings, LLC, Publisher of The Pahn Beach Post ("Post"), and files a Motion 
to Dismiss Count II, as follows: 
JURISDICTION 
1. 
Admitted for jurisdictional purposes. 
PARTIES 
2. 
Admitted. 
3. 
Denied that Defendant Aronbcrg or the Office of the State Attorney for the F iftccnth 
Judicial Circuit is in possession and/or control of documents that arc the subject of this action. 
Otherwise admitted. 
4. 
Admitted. 
INTRODUCTION 
5. 
Paragraph 5 contains the Post's statement of the case and legal arguments to which no 

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response is required. To the extent that a response is required, the SAO is without knowledge or 
infonnation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph 
5, and therefore denies the allegations and demands strict proof thereof. 
6. 
Paragraph 6 contains the Post's statement of the case and legal arguments to which no 
response is required. To the extent that a response is required, the SAO admits only that section 
905.27(1)(c), Florida Statute authorizes the disclosure of grand jury proceedings under certain 
circumstances. 
7. 
Paragraph 7 contains the Palm Beach Post's statement of the case and legal arguments 
to which no response is required. To the extent that a response is required, the SAO is without 
knowledge or infonnation sufficient to fonn a belief as to the truth of any factual allegations contained 
in paragraph 7, and therefore denies the allegations and demands strict proof thereof. 
8. 
Paragraph 8 sets forth the Post's statement of the case and legal arguments to which 
no response is required. To the extent that a response is required, the SAO is without knowledge or 
infonnation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph 
8, and therefore denies the allegations and demands strict proof thereof. 
9. 
Paragraph 8 sets forth the Post's statement of the case and le gal arguments to which 
no response is required. To the extent that a response is required, the SAO is without knowledge or 
infonnation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph 
9, and therefore denies the allegations and demands strict proof thereof. 
FACTUAL BACKGROUND 
10. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 10, and therefore denies the allc gations and demands 
strict proof thereof. 
A. 
First Epstein Sex Cr...

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of any factual allegations contained in paragraph 11, and therefore denies the allegations and demands 
strict proof thereof. 
12. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 12, and therefore denies the allc gations and demands 
strict proof thereof. 
13. 
The SAO is without knowledge or infonnation s ufficicnt to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 13, and therefore denies the allc gations and demands 
strict proof thereof. 
14. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 14, and therefore denies the allegations and demands 
strict proof thereof. 
15. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 15, and therefore denies the allegations and demands 
strict proof thereof. 
(1) 
Police Chief Reiter's Letter to the State Attorney 
16. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 16, and therefore denies the allegations and demands 
strict proof thereof. 
17. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 17, and therefore denies the allegations and demands 
strict proof thereof. 
(2) 
The July 2006 State Grand Jury Presentation 
18. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 18, and therefore denies the allegations and demands 
strict proof thereof. 
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1 9. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 19, and therefore denies the allegations and demands 
strict proof thereof. 
20. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 20, and therefore denies the allegations and demands 
strict proof thereof. 
21. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 21, and therefore denies the allegations and demands 
strict proof thereof. 
22. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 22, and therefore denies the allegations and demands 
strict proof thereof. 
(3) 
The FBI's Investigation and Epstein's Non-Prosecution Agreement with Federal 
Authorities. 
23. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 23, and therefore denies the allegations and demands 
strict proof thereof. 
24. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 24, and therefore denies the allegations and demands 
strict proof thereof. 
25. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 25, and therefore denies the allegations and demands 
strict proof thereof. 
26. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 26, and therefore denies the allegations and demands 
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strict proof thereof. 
2 7. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 2 7, and therefore denies the allegations and demands 
strict proof thereof. 
28. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 28, and therefore denies the allegations and demands 
strict proof thereof. 
2 9. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 29, and therefore denies the allegations and demands 
strict proof thereof. 
30. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 30, and therefore denies the allegations and demands 
strict proof thereof. 
31. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 31, and therefore denies the allegations and demands 
strict proof thereof. 
(4) 
32. 
The Crime Victims' Rights Act Litigation. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 32, and therefore denies the allegations and demands 
strict proof thereof. 
3 3. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 33, and therefore denies the allegations and demands 
strict proof thereof. 
34. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 34, and therefore denies the allegations and demands 
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strict proof thereof. 
3 5. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 35, and therefore denies the allegations and demands 
strict proof thereof. 
36. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 36, and therefore denies the allegations and demands 
strict proof thereof. 
3 7. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 3 7, and therefore denies the allegations and demands 
strict proof thereof. 
B. 
Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019. 
38. 
Admitted. 
3 9. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 39, and therefore denies the allegations and demands 
strict proof thereof. 
40. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 40, and therefore denies the allegations and demands 
strict proof thereof. 
41. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 41, and therefore denies the allegations and demands 
strict proof thereof. 
42. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 42, and therefore denies the allegations and demands 
strict proof thereof. 
43. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
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of any factual allegations contained in paragraph 43, and therefore denies the allegations and demands 
strict proof thereof. 
44. 
Admitted. 
C. 
The August 27. 2019. SDNY Hearing: Epstein's Victims Speak. 
45. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the 
truth of any factual allegations contained in paragraph 44, and therefore denies the allegations and 
demands strict proof thereof. 
46. 
Admitted that United States Senior Judge Richard M. Bcnnan ordered a hearing on 
August 27, 2019, but the SAO is without knowledge or infonnation sufficient to fonn a belief as to the 
truth of any remaining factual allegations contained in paragraph 43, and therefore denies the 
allegations and demands strict proof thereof. 
4 7. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 4 7, and therefore denies the allegations and demands 
strict proof thereof. 
48. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 48, and therefore denies the allegations and demands 
strict proof thereof. 
49. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations contained in paragraph 49, and therefore denies the allegations and demands 
strict proof thereof. 
50. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allegations paragraph 50, and therefore denies the allegations and demands strict proof 
thereof. 
51. 
The SAO is without knowledge or infonnation sufficient to fonn a belief as to the truth 
of any factual allc gations contained in paragraph 51, and therefore denies the allegations and demands 
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strict proof thereof. 
D. 
The Palm Beach Post's Standing and the Public Interest. 
(1) 
52. 
53. 
54. 
The Palm Beach Post Has Reported Extensively On Epstein's Crimes For Nearly 
15 Years. 
Admitted. 
Admitted. 
Admitted that the Post has extensively investigated and reported on the allegations 
against, the law enforcement investigation of, and the crimes committed by Epstein, but lacks sufficient 
knowledge to admit or deny any factual allegations remaining in paragraph 54, and therefore denies 
the allegations and demands strict proof thereof. 
5 5. 
The SAO is without knowledge or infonnation s ufficicnt to fonn a belief as to the 
truth of any factual allegations contained in paragraph 55, and therefore denies the allegations and 
demands strict proof thereof. 
(2) 
56. 
The Palm Beach Post's Standing and the Public Interest. 
Paragraph 56 of the First Amended Complaint contains the Palm Beach Post's 
statement of the case and legal arguments to which no response is required. To the extent that a 
response is required, the SAO admits the press has a constitutional right of access to criminal 
proceedings, but is without knowledge or infonnation sufficient to fonn a belief as to the truth of any 
remaining factual allegations contained in paragraph 56, and therefore denies the allegations and 
demands strict proof thereof. 
57. 
Paragraph 57 sets forth the Post's statement of the case and legal arguments to which 
no response is required. To the extent that a response is required, the SAO is without knowledge or 
infonnation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph 
5 7, and therefore denies the allc gations and demands strict proof thereof. 
58. 
Paragraph 58 sets forth the Post's statement of the case and legal arguments to which 
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no response is required. To the extent that a response is required, the SAO is without knowledge or 
infonnation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph 
57, and therefore denies the allegations and demands strict proof thereof. 
59. 
Paragraph 59 of the First Amended Complaint contains the Palm Beach Post's 
statement of the case and legal arguments to which no response is required. To the extent that a 
response is required, the SAO admits that Fla. Stat. 905.27 allows a court to make the dctcnnination 
of disclosure but is without knowledge or infonnation sufficient to fonn a belief as to the truth of any 
remaining factual allegations contained in paragraph 59, and therefore denies the allegations and 
demands strict proof thereof. 
E. 
The Court's Jurisdiction and Authority. 
(1) 
The Court's Supervision of the Grand Jury Process and Its Authority to Order 
Public Disclosure of the E µstein Evidence. 
60. 
Paragraph 60 of the First Amended Complaint contains the Palm Beach Post's 
statement of the case and legal arguments to which no response is required. To the extent that a 
response is required, the SAO admits the press has a constitutional right of access to criminal 
proceedings, but is without knowledge or infonnation sufficient to fonn a belief as to the truth of any 
remaining factual allegations contained in paragraph 60, and therefore denies the allegations and 
demands strict proof thereof. 
61. 
Admitted. 
62. 
Admitted. 
63. 
Paragraph 63 sets forth the Post's statement of the case and legal arguments to which 
no response is required. To the extent that a response is required, the SAO is without knowledge or 
infonnation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph 
63, and therefore denies the allegations and demands strict proof thereof. 
64. 
Paragraph 64 of the First Amended Complaint contains the Palm Beach Post's 
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statement of the case and legal arguments to which no response is required. To the extent that a 
response is required, the SAO is without knowledge or infonnation sufficient to fonn a belief as to the 
truth of any remaining factual allegations contained in paragraph 64, and therefore denies the 
allegations and demands strict proof thereof. 
(2) 
65. 
66. 
67. 
The Court's Jurisdiction To Declare Rights And Construe Statutes. 
Admitted. 
Admitted. 
Admitted. 
COUNT I 
(Declaratory Relief - Florida Stat. Sections 86.011 et seq.) 
68. 
The SAO reincorporates and re-alleges its prior answers to paragraphs 1 through 
67 above. 
69. 
Admitted. 
70. 
Paragraph 70 contains the Post's statement of the case and legal arguments to which 
no response is required. To the extent that a response is required, the SAO is without knowledge or 
infonnation sufficient to fonn a belief as to the truth of any factual allegations contained in paragraph 
70, and therefore denies the allegations and demands strict proof thereof. 
71. 
Admitted that The Palm Beach Post is seeking a declaration from this Court but 
denies the remainder of Paragraph 71. 
72. 
Admitted. 
73. 
Denied. 
74. 
Paragraph 74 contains the Post's legal arguments to which no response is required. 
To the extent that a response is required, the SAO is without knowledge or infonnation sufficient to 
fonn a belief as to the truth of any factual allegations contained in paragraph 74, and therefore denies 
the allegations and demands strict proof thereof. 

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MOTION TO DISMISS COUNT II 
(Florida Stat. Section 905.27) 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, pursuant 
to the Florida Rules of Civil Procedure 1.420, hereby files this Motion to Dismiss Count II of Plaintiff's 
First Amended Complaint for failure to state a cause of action, and in support thereof states: 
I. 
Standard of Review 
When confronted with a motion to dismiss, the Court must dctenninc whether the Complaint 
as phrased within its four comers sufficiently states a cause of action, whereby relief can be granted. 
Fox v. Professional Wrecker Operations, 801 So. 2d 175, 178 (Fla. 5th DCA 2001). A motion to 
dismiss tests whether the plaintiff has stated a cause of action. The test for a motion to dismiss under 
Florida Rule of Ci vii Procedure 1.140(b) is whether the pleader could prove any set of facts as alleged 
in the Complaint to support his or her claim. Sec, Connolly v. Scbcco, Inc., 89 So. 2d 482,484 (Fla. 
1956); Wasua Ins. Co. v. Haynes, 683 So. 2d 1123 (Fla. 4th DCA 1996). 
In order to meet this test, "a complaint must allege sufficient ultimate facts to show that a 
pleader is entitled to relief." W.R. Townsend Contr., Inc. v. Jensen Civ. Constr., Inc., 728 So. 2d 297, 
300 (Fla. 1st DCA 1999) (quoting Perry v. Cosgrove, 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. 
R. Civ. P. 1.11 0(b)). The court need not accept internally inconsistent factual claims, conclusory 
allegations, unwarranted deductions, or mere legal conclusions made by a party. hL (citing Response 
Oncology, Inc. v. Mctrahcalth Insurance Co., 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Asset 
Mgmt. v. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002) ("[On a motion to dismiss,] the plaintiff's 
factual allegations arc accepted as true .... However, legal conclusions masquerading as facts will not 
prevent dismissal."). To a void dismissal, a pleading "must allc gc a cause of action rcco gnizcd under 
law" against the de...

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are the subiect of this action. 
It is significant to emphasize that despite Plaintiff's allegations to the contrary, Defendant 
Aron berg and the Office of the S tatc Attorney for the F iftcenth Judicial Circuit arc not in custody or 
control of the records sought herein, and therefore Defendant Aronbcrg is not a proper party to this 
action. In fact, Defendant, Sharon R. Bock, as Clerk and Comptroller of Pahn Beach County, Florida, 
admits that it is the custodian in possession of the documents that arc the subject of this action. 
b. 
Plaintiff Fails to State a Cause of Action 
Plaintiff attempts to assert a cause of action, in the interest of "furthcringj usticc", under Florida 
Statute§ 905.27; however, a review of the statute in question reveals that no cause of action is provided 
for therein and consequently Count II of Plaintiff's First Amended Complaint must be dismissed as a 
matter of law. Despite Plaintiff's extensive recitation of the factual background regarding Jeffery 
Epstein and the testimony and evidence presented to the 2006 grand jury in Palm Beach County, 
Florida, Fla. Stat. § 905.27, merely explains the exceptions to the disclosure of grand jury testimony 
and docs not set forth in any way a cause of action upon which to initiate a valid law suit. 
Moreover, a review of the statute at issue clearly indicates that even if§ 905.27, Fla. Stat. 
provided a basis for a cause of action, Plaintiff is barred from access to the records it seeks. To wit, in 
pertinent part, Fla. Stat. § 905.27(2) states: 
When such disclos urc is ordered by a court pursuant to s u bscction ( 1) for use in a civil 
case, it may be disclosed to all parties to the case and to their attorneys and by the latter 
to their legal associates and employees. However, the grand ;ury testimony afforded 
such persons by the court can only he used in the defense or prosecution o{the civil or 
criminal case and for no other purpose whatsoever. 
Herc, dcspi tc the...

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prosecution of the civil or criminal case and for no other purpose whatsoever", which is distinctly 
diff crent from Plaintiff's intended purpose for public disclos urc of the grand jury evidence. Fla. Stat. 
§ 905.27(2). 
WHEREFORE, based on the foregoing argument and supporting authority, Defendant, DAVE 
ARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this 
Honorable Court grant the instant Motion and dismiss Count II of Plaintiff's First Amended Complaint 
with prejudice, and grant Defendant Aronbcrg all other and further relief deemed just and proper, 
including attorney's fees and costs for defending this frivolous action. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 24th day of January, 2020, a copy of the fore going has been 
electronically filed with the Florida E-Filc Portal for c-scrvicc on all parties of record herein. 
13 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esq. 
Fla. Bar No.: 10249 
Richard J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 Fax 
Primary: j aco bsscholzlaw@comcast.net 
General Counsel for the Florida Prosecuting 
Attorney's Association 

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In the Matter Of: 
CA FLORIDA HOLDINGS vs DA VE ARONBERG 
50-2019-CA-014681 
HEARING 
June 03, 2020 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
IN THE CIRCUIT COURT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 
50-2019-CA-014681 
CIRCUIT CIVIL DIVISION: "AG" 
CA FLORIDA HOLDINGS LLC PUBLISHER 
OF THE PALM BEACH POST, 
Plaintiff/Petitioner 
-vs-
DAVE ARONBERG, 
SHARON R. BOCK, 
Defendant/Respondents. 
_______________ ! 
HEARING BEFORE THE HONORABLE KRISTA MARX 
(ZOOM CONFERENCE) 
Wednesday, June 3, 2020 
10:08 a.m. -
10:28 a.m. 
REMOTE ZOOM CONFERENCE 
Port Saint Lucie, Florida 
Stenographically Reported By: 
SONJA M. REED 
Court Reporter 
June 03, 2020 
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APPEARANCES: 
On behalf of the Plaintiff/Petitioner: 
GREENBERG TRAURIG, P.A. 
1840 Century Park East 
Suite 1900 
Los Angeles, California 90067 
310.586.7700 
boyajian@gtlaw.com 
BY: NINA D. BOYAJIAN, ESQUIRE 
On behalf of the Defendant/Respondent: 
JACOB, SCHOLZ & WYLER, LLC 
961687 Gateway Boulevard 
Suite 2011 
Fernandina Beach, Florida 32034 
904.261.3693 
doug.wyler@comcast.net 
BY: DOUGLAS A. WYLER, ESQUIRE 
On behalf of the Defendant/Respondent: 
June 03, 2020 
2 
CLERK & COMPTROLLER, PALM BEACH COUNTY 
P.O. Box 229 
West Palm Beach, Florida 33401 
561.355.2983 
nfingerhut@mypalmbeachclerk.com 
BY: NICOLE R. FINGERHUT, ESQUIRE 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
PROCEEDINGS 
***** 
June 03, 2020 
3 
THE COURT: 
We are here today for a very 
limited purpose. 
I'm sure the attorneys are aware of 
that, but I just don't want there to be any 
confusion. 
We are here on Defendant Dave Aronberg 
and Defendant Sharon Bock for the Comptroller and the 
State Attorney's motion to dismiss Count II. 
You're all acutely aware as the lawyers that 
this is a question of law. 
So we 1 re not going to be 
diving into facts and the Court will not be deciding 
the merits of this motion this morning. 
We are 
simply here for the sole purpose of that motion to 
dismiss. 
So I just wanted to make sure that we all 
stay on track and we're all on that same page. 
So, Ms. Boyagian, I
1 ll send it to you first, 
Ma'am. 
I -- of course, we all know that the Law 101, 
I must look at the four corners of the motion, which 
alleges that the State Attorney, David Aronberg, and 
the clerk and comptroller, Sharon Bock, actually have 
custody and control of these grand jury proceeding. 
Whether that is true or not is not for this 
court to determine because I'm looking simply at the 
four corners of the complaint. 
But, not for nothing, 
I think we all know that they don 1 t have control and 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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custody of the records. 
But I'm going to assume that 
it 1 s correct because that 1 s what has been alleged. 
So what I first want to hear from is the 
attorney for Florida Holdings with regard to, 
assuming arguendo, that Florida Statute 905.27 does 
create a cause of action, what relief is it that 
you 1 re seeking from -- in Count II, specifically. 
Not the dee action. 
We 1 re not here on that today 
what is it you hope to get, a judgment? 
MS. BOYAGIAN: 
Thank you, your Honor. 
Good 
morning, and thank you for the privilege of appearing 
before this court. 
The relief we are seeking is disclosure of the 
grand jury records, pursuant to the Furtherance of 
Justice Exception to 905.27. 
And under the First 
Amendment. 
The press, as your Honor is aware, has a right 
of access under the First Amendment as a surrogate of 
the public --
THE COURT: 
Let me just stop you for a minute. 
I
1 d like you to answer my specific question. 
So I am not particularly convinced -- and I'd 
like for you to address that. 
So we 1 re not going to 
dive into facts or the press 1 s standing because 
that 1 s not something we 1 re here to discuss today. 
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HEARING 
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And I have read the voluminous paperwork --
I 1ve received paperwork as -- and -- five-minute ago 
from some of the other parties. 
But I deeply 
appreciate the fact that you sent this to me so much 
in advance and I have been able to spend some time 
with, as I said, the voluminous paperwork that was 
provided. 
But as you know, Ma'am, we are here for such an 
extremely limited issue today, and that their motion 
to dismiss where they state "you're suing the wrong 
people 11 ; that the court has these records. 
And so, more importantly, I want you to address 
whether Section 905.27 gives you a private cause of 
action against the state attorney and the clerk. 
Again, I
1m going to assume the facts are true 
that are asserted in the motion. 
Whether they are or 
not -- because I think we can all agree we're not for 
sure if they ever -- that the state attorney doesn 1 t 
have these records. 
So what is it you're seeking in 
Count II -- not the dee action. 
I know you want the 
records. 
I've got that. 
But in Count II, 
specifically, what do you -- what's the relief you 1 re 
seeking and, more importantly, how under this statute 
do you get to assert a private action -- a private 
cause of action against the state attorney and the 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
clerk? 
June 03, 2020 
6 
MS. BOYAGIAN: 
Your Honor, we are aware, of 
course, that there is no expressed private right of 
action, 905.27. 
But that does not end the inquiry. 
As the Florida Supreme Court stated: 
"Where a statute like 905.27 
forbids an act which is to Plaintiff's 
injury, the party injured should have 
an action.
11 
And that 1 s the Smith Piezo case in the volume 
of materials that we sent you. 
There's no question here that the denial of the 
FIRST AMENDMENT right to the press is an injury which 
gives rise to a right of action. 
Stated another way, looking at the analysis 
that the Fischer Metcalf Court looked at, there are 
three factors in determining whether there is a 
private right of action where a statute does not 
expressly provide for one. 
One is whether the Plaintiff is part of the 
class for which the statute is intended to protect; 
second is a legislative history; and the third is the 
underlying purposes of the statutory scheme. 
The first factor I already addressed, that the 
press is part of the class that the statute is 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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intended to benefit, being the surrogate of the 
public and exercising its first amendment right. 
The second issue of legislative history and the 
purpose -- statutory purpose are somewhat related. 
We were unable to find much legislative history on 
this issue of a private right of action under the 
statute. 
There is nothing that says we intend to create 
a private action, but there's certainly nothing that 
says we do not want to create a private right of 
action. 
What we do have is that in 1994, the same time 
that 905.27 was reenacted, a statute that pertains to 
the secrecy of State Grand Jury -- statewide grand 
juries was also enacted. 
That provision, which is 
905.395, has no exceptions for -- for revealing these 
records. 
By contrast, the legislature intentionally 
enacted 905.27 with the Furtherance of Justice 
Exception. 
If the public through the press can't bring a 
private right of action to enforce that exception or 
to seek relief under that exception, that 
intentionally placed exception of furthering justice 
1s essentially rendered hollow 
(Speaking simultaneously.) 
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THE COURT: 
Okay. 
Pause for a minute. 
I don't think anybody is saying that there 
isn 1 t a cause of action or that the press doesn 1 t 
have standing. 
That's not what I
1m asking you. 
I 1m 
asking you, how are the clerk and the state attorney 
the proper defendants? 
So, you know, nowhere have I said there isn't a 
cause of action. 
Clearly there is. 
I
1m puzzled by 
the procedural posturing of this case naming the 
state attorney. 
And, you know, I'm further stymied by the fact 
that you allege in your complaint that they have --
particularly David Aronberg the State Attorney --
that he has these records. 
But I
1m going to assume that 1 s true. 
So I'm 
not telling you, you don't have a cause of action. 
I'm just saying, okay, let's run this all the way 
out. 
Let's say you win and you get a judgment 
against the State Attorney Dave Aronberg. 
What's he supposed to do with it? 
He can't 
release the grand jury testimony. 
He has no 
authority whatsoever to do that. 
MS. BOYAGIAN: 
Well, your Honor, as you stated, 
this is a motion to dismiss stage, and we are 
entitled to discovery on the issue of possession, 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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custody, and control. 
My understanding is that the 
state attorney has asserted that he does not have 
possession. 
It's not my understanding that the clerk 
has taken that position. 
So the clerk may indeed be 
the -- someone who does have possession, custody, and 
control. 
In any event, we would submit that the state 
attorney, even it does not have actual possession at 
this time, it might be able to have the power to 
control or direct the entity or persons who do have 
control and possession to release those -- to effect 
the judgment. 
THE COURT: 
So let me ask you this: 
So the 
clerk is the keeper of the record. 
But even if you 
got a judgment against her -- let's say you asserted 
this cause of action and let's say you win and you 
get a judgment against the clerk. 
The clerk cannot 
release grand jury testimony to you. 
Only the court 
can. 
So really -- all I'm saying to you is I do not 
understand the way this case was filed or why these 
are the defendants because it's impossible for them 
to perform. 
I mean, I'm going to assume, based on your 
motion, again, that they do have the records. 
But we 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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all know -- everyone in the room knows they do not 
that only the court -- they're -- they 1 re with a 
court interpreting. 
And only the court can release 
the records. 
So if you get a judgment against either the 
state attorney or the clerk, they cannot 
I mean, I 
guess what you 1 re saying to me is, well, we want to 
do discovery and we want them to say unequivocally "I 
have these records" or 
11 I don't have them." 
And --
I mean, the law is abundantly clear. 
You cannot do it without a court determining whether, 
in the furtherance of justice, the release is 
appropriate. 
C) 
MS. BOYAGIAN: 
And that is a determination 
we 1 re asking your Honor to make, and we 1 re asking for 
an order from your court. 
THE COURT: 
When we get to the merits of the 
case, sure it is. 
But, again, you 1 re asking me to 
make that determination and for me to make a 
determination of whether the grand jury records 
should be released. 
And the only thing we 1 re here 
today about is why should the clerk and the state 
attorney have to defend a civil action when it's a 
possibility of performance? 
They -- even if you were 
to win and get a judgment against them, they cannot 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
give you what they don 1 t have. 
June 03, 2020 
11 
So --
I mean, it's as simply as this: 
Are 
you -- you just want to engage in some discovery for 
them to absolutely assert, particularly, the state 
attorney, 
11 I don't have these records"; look to the 
rules that say the moment the grand jury 1 s over, 
they 1 re sealed and they're turned over and they 
cannot be released without court order? 
So I'm not addressing the merits or whether you 
have an exception or you're able to argue that 
there's an exception in the furtherance of justice. 
We 1 re not getting there today. 
I'm simply saying why 
should these two entities have to defend this lawsuit 
when even down the road if they win they can't give 
you what they don't have? 
MS. BOYAGIAN: 
As your Honor stated, I 1 m not 
sure that's the case with the clerk. 
That was not in 
their -- that issue was not stated in their papers. 
THE COURT: 
Let me ask you this, then: 
Do you 
think, if you got a judgment and I or the court 
doesn 1 t make the determination that the grand jury 
records should be released, that the clerk would be 
able to perform? 
Would they be able to say "here you go 11 ? 
I 
mean, could the clerk just make that unilateral 
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decision "I
1 m going to release the records, sealed 
confidential records 11 ? 
Does she have any authority to do that? 
MS. BOYAGIAN: 
My understanding, your Honor, is 
that 905.27 requires a court order before the records 
are unsealed. 
THE COURT: 
Exactly. 
Exactly. 
All right. 
Let me hear from Mr. Aronberg 1 s 
attorney, Mr. Wyler. 
MR. WYLER: 
Thank you, your Honor. 
May it 
please the Court 
THE COURT: 
Good morning, Sir. 
MR. WYLER: 
Good morning. 
Your Honor, I just wanted to let you know that 
I spoke with counsel for the clerk, Ms. Fingerhut, a 
couple of days before this hearing, and we decided 
that I would just make the presentation for both of 
of us, being that our arguments overlap except for 
the fact of who this claim -- whether they have the 
records or not, which, of course, we've said we don 1 t 
have custody of the records. 
But, nonetheless, our arguments overlap. 
The 
Plaintiff is attempting to assert a cause of action 
under Section 905.27. 
That statute settled testimony 
not to be disclosed exceptions. 
So it
1 s just 
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CA FLORIDA HOLDINGS vs DAVE ARONBERG 
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explaining exceptions to the disclosure of the grand 
jury testimony. 
Our position is that it doesn't set forth a 
cause of action and that it's impossible for us to 
perform what they're asking. 
I know you said you didn 1 t really want to get 
into the Furthering Justice Exception, but I know 
that 1 s what they're using as their basis to get to 
these. 
But it 1 s our position that the clear 
unambiguous statutory language, it shows that this 
disclosure only applies to a civil or criminal case, 
and that within that civil or criminal 
(Speaking simultaneously.} 
THE COURT: 
Again, sir -- I'm sorry. 
As I told 
Plaintiff 1 s counsel 
MR. WYLER: 
can only be used in the defense 
for 
THE COURT: 
Okay. 
We're not there. 
We 1re not 
discussing the merits of the case, and -- I'm not 
ready to cross that bridge. 
I'm here for a very, 
very limited hearing today. 
So just as I stopped Plaintiff's counsel from 
arguing the merits of the case and whether or not the 
Furtherance of Justice Exception will apply in this 
instance, we're not even there yet. 
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I'm only here for the purpose of determining 
whether or not the clerk and state attorney should be 
dismissed. 
And I am bound by the four corners of the 
document, which assert that you do have control and 
custody over it. 
So if you'll fashion your argument with regard 
to that limited purpose, I would appreciate it. 
MR. WYLER: 
No problem, your Honor. 
I 
apologize. 
Within the four corners of their complaint, our 
position is that they failed to state a cause of 
action under 905.27. 
It does not provide for 
it 
doesn
1 t list that there's no element that they have 
adequately pled to assert a cause of action under 
that. 
There's -- and the only thing they 1 re asking 
for is records that we don 1 t have. 
There
1 s really not much more to it, your Honor. 
And we would ask that you would grant our motion to 
dismiss for failure to state a cause of action. 
THE COURT: 
Okay. 
Ms. Fingerhut, are you still 
on the phone? 
MS. FINGERHUT: 
Yes, your Honor. 
THE COURT: 
Is there anything you wish to add? 
MS. FINGERHUT: 
We agree with the state 
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attorney 1 s position, and we also agree with what the 
Court has said, that the plain language of the 
statute, a cause of action doesn 1 t exist. 
And we 
really cannot -- we 1ll be defending something without 
the four corners. 
We 1 re simply involved in this 
action because the clerk is the custodian of the 
records. 
THE COURT: 
Okay. 
Thank you, Ma'am. 
Ms. Boyagian, back to you. 
MS. BOYAGIAN: 
Your Honor, I 1 d like to note 
that in the Butterworth case in which the Supreme 
Court limited the application 905.27 by saying that a 
witness can reveal her own testimony and prohibiting 
that they violate the First Amendment --
THE COURT: 
Say that again, please. 
MS. BOYAGIAN: 
In the Supreme Court case, the 
Butterworth case, in which the Supreme Court ruled 
that 905.27 can't restrict a Grand Jury witness from 
revealing her own testimony, that would be a 
violation of First Amendment, in that case, the state 
attorney was, in fact, a party. 
THE COURT: 
Well, I assume the state attorney 
that was present 
I mean, I don't find that that's 
close to what we're talking about here, and that 1 s 
whether or not --
I mean, as we know, this was in 
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2006. 
Certainly Dave Aronberg wasn 1 t even the state 
attorney then. 
But this is about the release of 
records. 
I want to give you ample opportunity -- and 
again, I sincerely appreciate that all of the case 
law and the way that it was presented to the Court in 
such a timely fashion. 
I really do. 
And I did spend 
some time with it. 
But I want to give you whatever 
opportunity you want to take to convince me that it 
is in -- as to Count 2, again. 
Not the dee action 
whether these would be the appropriate defendants. 
And, you know, really, I want you to boil it 
down for me as to this -- let's take it all the way 
down the road. 
You win. 
You get a judgment against 
the clerk and the state attorney. 
I know there's other reasons why you might have 
filed it this way. 
But I'm just simply puzzled 
because I do hear what the clerk and the state 
attorney are saying, and that is, performance is 
impossible. 
They don 1 t have the records and 
cannot -- absolutely. 
There's not even an inch of 
wiggle room -- that they could release the records 
even if you got a judgment. 
It is solely a 
determination for the court. 
I, frankly, think, you know, there's ways to 
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u 

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
17 
get to your records. 
There's ways to get 
confidential records. 
But it isn 1 t by suing the 
state attorney and the clerk. 
So I just want to hear your last final argument 
on how Count II, the appropriate defendants are the 
clerk and the state attorney. 
Even assuming arguendo 
they have the records -- we know they don't -- you 
were to get a judgment against them, how would you 
expect them to perform? 
MS. BOYAGIAN: 
Two points, your Honor: 
One is 
that, again, the clerk did not assert in her papers 
that she does not have control. 
That is a position 
that the State Attorney's Office has asserted. 
It is 
our allegation, and as your Honor noted, allegations 
must be accepted as true -- as true at this stage of 
the proceedings. 
Second, it is also our understanding that the 
state attorney and the clerk intend to block access 
to these records. 
So our allegation is that they do 
have possession, custody, or control, which the clerk 
has not denied; and second, that they are trying to 
block access to the records 
THE COURT: 
What do you mean? 
What do you 
mean? 
They 1 re not trying to block it. 
They 1 re 
saying that despite the fact -- let 1 s just talk about 
800.211.DEPO (3376) 
EsquireSolutions.com 

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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
June 03, 2020 
18 
the clerk, because we all know the state attorney 
doesn 1 t have it. 
So the clerk is the custodian of records. 
That's her main job. 
There's no doubt about it. 
We 
all know that. 
But we also know, unequivocally 
unequivocally, only the court can make the 
determination of whether the moving party has 
satisfied that there is an exception that these 
should be released. 
So, again, I ask you -- she is, in fact, the 
custodian of the records -- is it your opinion that 
if you got a judgment saying clerk and comptroller 
gets a judgment against them, that she can release 
the records without the court -- without the court 
weighing in, without the court making that 
determination as required by law? 
MS. BOYAGIAN: 
No, your Honor. 
We are asking 
your Honor to order the clerk to do that under your 
discretion. 
THE COURT: 
All right. 
Mr. -- Ms. Fingerhut, you wish to be heard on 
that? 
MS. FINGERHUT: 
Your Honor, our position is 
that we're not trying to block access to the 
records --
800.211.DEPO (3376) 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
(Speaking simultaneously.) 
June 03, 2020 
19 
THE COURT: 
Can you hear? 
Can the attorneys 
hear? 
MS. FINGERHUT: 
-- custodian the records and 
that he cannot release the records without court --
THE COURT: 
Exactly. 
Okay. 
All right. 
Anything further, Mr. Wyler? 
MR. WYLER: 
No, your Honor. 
I concur with the 
attorneys for the clerk 1 s office that it's impossible 
for us to release these records. 
There 1 s no intent 
to hide them or block anything from the Plaintiff. 
THE COURT: 
Okay. 
Anything further, 
Ms. Fingerhut? 
MS. FINGERHUT: 
No, your Honor. 
THE COURT: 
And, Ms. Boyagian, anything 
further, Ma'am? 
MS. BOYAGIAN: 
Nothing further, your Honor. 
THE COURT: 
Okay. 
I will get an order out 
quickly. 
Thank you, folks so much. 
And I 1 ll see you 
on the next round. 
Thanks a lot. 
MS. BOYAGIAN: 
Thank you, your Honor. 
MR. WYLER: 
Thank you, your Honor. 
(The proceedings concluded at 10:28 a.m.) 
800.211.DEPO (3376) 
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HEARING 
CA FLORIDA HOLDINGS vs DAVE ARONBERG 
CERTIFICATE OF REPORTER 
June 03, 2020 
20 
I, Sonja M. Reed, Court Reporter, certify that 
I was authorized to and did stenographically report the 
foregoing proceedings and that the transcript, pages 1 
through 19, is a true and complete record of my 
stenographic notes. 
Dated this 3rd day of June, 2020. 
Sonja M. Reed 
Court Reporter 
800.211.DEPO (3376) 
EsquireSolutions. com 

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Def.Ex.A-7 

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CIRCUIT CIVIL DIVISION AG 
CASE NO. 50-2019-CA-014681-XXXX-MB 
CA FLORIDA HOLDINGS LLC PUBLISHER OF THE PALM BEACH POST, 
Plaintiff/Petitioner 
vs. 
DA VE ARONBERG, 
SHARON R BOCK, 
Defendant'Respondents. 
I 
ORDER GRANTING DEFENDANTS MOTIONS TO DISMISS COUNT II OF 
PLAINTIFF'S FIRST AMENDED COMPLAINT WITH PREJUDICE 
THIS CAUSE came before the Court on Dave Aronberg, as State Attorney of Palm 
Beach Cm.mty's ("St.ate Attorney") and Sharon R. Bock, as Clerk & Comptroller of Palm Beach 
County's, ("Clerk") respective Motion.-; to Dismiss Col.Illt II of CA Florida Holdings, LLC, 
Publisher of the P aim Beach Post's ("The Po st") First AmeIKled Complaint (DE## 22, 24 ). This 
case is assigned to Division AG, which is currently presided over by the Honorable Donald 
Hafele. However, the undersigned, as Chief Judge of the Fifteenth Judicial Circuit, presided 
over the June 3, 2020 hearing on the State Attorney and Clerk's Motion.-; as the Motions 
implicate records of the P aim Beach Col.Illty grand jury, over which the Chief Judge pre sides. 
See § 905.01, Fla. Stat. (2019). After careful con.-,ideration of the pleadings and the arguments 
presented at the hearing, the Court grants the Motions for the following reasons. 
Background 
The Post is a media outlet which has heavily reported on the 2006 Palm Beach County criminal 
prosecution of Jeffrey Epstein. Through the instant civil lawsuit, The Post seeks "irrnnediate 
access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach 
County grand jury" in Mr. Epstein's case and alleges that both the State Attorney and Clerk are 
"in possession and/or control of [those] documents." (DE# 17, First AmeIKled Complaint at ,i,i 
3,4, and 77). Specifically, The Post seeks declaratory judgment as to its rights to obtain the 
graIKl jury testimony in Mr. Epstein's case from the State Attorney...

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Case No.50-2019-CA-014681-XXXX-MH 
judgment against the State Attorney and the Clerk ptrrsuant to section 90527, Florida Statutes, 
w hie h sets forth the parameters of grand jtrry secrecy in Flo rid a. (Count II). Bo th the State 
Attorney and the Clerk move to dismiss Col.Illt II of The Post's First Amended Complaint, 
arguing that that section 905.27 does not create a private cau.-;e of action. (DE## 22, 24 ). The 
Court agrees. 
Analysis 
"In reviewing a motion to dismiss for failtrre to state a cau.-;e of action, the court must accept the 
allegations of the complaint as true and construe them in the light most favorable to the plaintiff." 
Almarante v. Art Institute (?/Fort Lauderdale, Inc., 921 So. 2d 703, 704-05 (Fla.4th DCA 
20 06 ). The motion should only be granted if the moving party demonstrates that the plaintiff 
cannot provide any facts that would support a cau.-;e of action. Id. It follows that if the cau.-;e of 
action alleged is nonexistent under Florida law, dismissal is warranted. Cummings v. Dawson, 
444 So . 2d 5 6 5, 56 6 (Fla. 1st D CA 19 84) ( af firrning dismissal of c au.-; e of action not recognized 
by Florida law). 
Section 90527, Florida Statutes (2019), is titled "Testimony not to be disclosed, exceptions," 
and states: 
(1) A grand juror, state attorney, assistant state attorney, reporter, stenographer, 
interpreter, or any other person appearing before the grand jtrry shall not disclose the 
testimony of a witness examined before the grand jtrry or other evidence received by it 
except when required by a court to disclose the testimony for the purpose of: 
a. Ascertaining whether it is consistent with the testimony given by the witness before 
the court; 
b. Determining whether the witness is guilty of perjury; or 
c. Furthering ju.-;tice. 
(2) It is unlawful for any person knowingly to publish, broadcast, disclose, divulge, or 
commlfilicate to any other person, or knowingly to cause or permit to be published,...

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Case No.50-2019-CA-014681-XXXX-MH 
attorney, and by the latter to his or her legal associates and employees. When such 
disclosure is ordered by a court pursuant to subsection (1) for u.-;e in a civil case, it may be 
disclosed to all parties to the case and to their attorneys and by the latter to their legal 
associates and employees. However, the grand jury testimony afforded such persons by 
the court can only be used in the defense or prosecution of the civil or criminal case and 
for no other purpose what-;oever. 
(3) Nothing in this section shall affect the attorney-client relationship. A client shall have 
the right to corrnnunicate to his or her attorney any testimony given by the client to the 
grand jury, any matters involving the client discussed in the client's presence before the 
grand jury, and any evidence involving the client received by or proffered to the grand jury 
in the client's presence. 
( 4) Persons convicted of violating this section shall be guilty of a misdemeanor of the first 
degree, punishable as provided ins. 775.083, or by fine not exceeding $5,000, or both. 
(5) A violation of this section shall constitute criminal contempt of court. 
§ 905.27, Fla. Stat.(2019). 
As the State Attorney and Clerk argue and The Post concedes, section 905.27 
makes no express provision for a civil suit or civil liability. Nonetheless, The Post maintains that 
it is entitled to seek the grand jury records via a private cause of action pursuant to the "furthering 
justice" exception to grand jury secrecy contained in subsection 905.27(l)(c ). Therefore, the 
limited question for this Court's consideration is whether a cause of action under section 905.27 
should be judicially implied. See Murthy v. N. Sinha Corp., 644 So. 2d 983, 985 (Fla. 1994 ). 
In advocating that it may rnaintain a cau.-;e of action against the State Attorney and Clerk 
under section 905.27, The Post urges the Court to examine three factors "(l) whether the 
plai...

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Case No.50-2019-CA-014681-XXXX-MH 
grand jury secrecy outlined in section 90 5 .27( 1 )( c) was ire ant to benefit the public at large, for 
which the press acts as a surrogate. The Post's argurrents are unpersuasive as to the discrete 
issue of whether a private cause of action lies in section 90527. 
To begin with, The Post's reliance on the benefit factor is misplaced. Per the Florida 
Suprerre Court's 1994 opinion in Murthy, "the question of whether a statute establishes a duty to 
take precautions to protect or benefit a particular class of persons is no longer determinative on 
the question of whether a cause of action should be recognized." Sorenson v. Prof'/ 
Compounding Pharmacist~ of W Pa., Inc., 191 So. 3d 929 (Fla. 2d DCA 2016) (citing Murthy, 
644 So. 2d at 985). ln.-;tead, "whether a statute ry cause of action should be judicially implied is a 
question of legislative intent." Horowitz v. Plantation Gen. Hosp. Ltd. P 'ship, 959 So. 2d 176, 
182 (Fla. 2007). See also QBE Ins. Corp. v. Cha!fonte Condo. Apartment Ass 'n, Inc., 94 So. 3d 
541, 551 (Fla. 2012) (" Since Murthy, we have reaffinned the principle that whether a statutory 
cau.-;e of action should be judicially in1)lied is a question of legislative intent."); Universal Prop. 
& Cas. Ins. Co. v. Loftus, 276 So. 3d 84 9, 851 (Fla. 4th DCA 2019). 
As is always the case when a court undertakes a legislative intent analysis, the plain 
language of the statute is the starting, and often ending, point. See Horowitz, 959 So. 2d at 182. 
"When the statute is clear and unambiguous, courts will not look behind the statute's plain 
language for legislative intent or resort to rules of statutory construction to ascertain intent." 
LC?fius, 276 So. 3d at 851 (Fla. 4th DCA 2019))(quoting Daniels v. Fla. Dep't ofHealth, 898 So. 
2d 61, 64 (Fla. 2005)). "However, a single part of a statute should not be read in isolation." Id. 
"ln.-;tead, 'all part-; of a statute must be read together in or...

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Case No.50-2019-CA-014681-XXXX-MH 
history indicating an intent to create a private right of action is telling, it is not dis positive as the 
plain language of the section 905.27 is clear an unambiguous and, therefore, controls. Horowitz, 
959 So, 2d at 182. 
Examining the plain language of section 905.27 in its entirety. which requires the Court to 
look at more than just the "furthering ju.-;tice" provision of section 905.27(l)(c) relied on by The 
Post, it is clear that the intent of the Legislature in passing section 905.27 was to limit, not 
facilitate, disclosure of grand jury records. In no uncertain terms, the Legislature provided that 
no "person appearing before the grand jury" may "disclose" testirmny or evidence presented 
except when "required by a court" under certain limited circwnstances. § 905.27(1), Fla. Stat. In 
solidifying that its intent was to prohibit disclosure without court pemlission, the Legislature 
provided that disclosure without a court order is a criminal offense. § 90 5 .27( 4 ), Fla. Stat. 
Therefore, to the extent section 905.27 could be read as imposing a duty on the State Attorney 
and Clerk, the duty imposed is one of secrecy, not disclosure. 
In sum, there is nothing in the text of section 905.27 from which one can deduce that the 
Legislature contemplated a member of the media, or anyone else for that matter, having a private 
cau.-;e of action to compel the State Attorney and Clerk to disclose grand jury records. Indeed, 
to the contrary, section 905.27 prohibits the State Attorney and the Clerk (assuming that, as 
pleaded by The Post, they have the documents) from disclosing the documents without first 
being ordered to do so by the court.ill Reading section 905.27 as creating a private cause of 
action against the State Attorney and Clerk is, therefore, not only unsupported by the language of 
section 90 5 .27, but is actually paradoxical to its plain language of the statute. As such, this Court 
lack...

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Case No.50-2019-CA-014681-XXXX-MH 
90527. In aniving at this conclusion, the Court does not suggest The Post has no available 
mechanism to obtain a court order granting it access to the grand jrny proceedings. The Court 
also does not render any opinion as to whether releasing these records is appropriate for the 
purpose of "furthering ju.-;tice" within the meaning of section 90 5 .27. Rather, the Court's 
dismissal of Count II is necessitated by precedent and the sin1)le fact that a civil lawsuit against 
the State Attorney and Clerk under section 90 5 .27 is not the proper mechanism for The Po st to 
pursue its goal. 
Therefore, it is hereby 
ORDERED AND ADJUDGED that Dave Aronberg, as State Attorney of Palm Beach 
County's and Sharon R. Bock, as Clerk & Comptroller of Palm Beach County's, respective 
Motions to Dismiss Count II of CA Florida Holdings, LLC, Publisher of the Palm Beach Post's 
First Amended Complaint are GRANTED and Count II of Plaintiff's first Amended Cofll)laint is 
hereby DISMISSED with prejudice. 
DONE AND ORDERED, in West Palm Beach, Palm Beach County, Florida this 8th day 
of Jtme, 2020. 
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06/08/2020 
Krista Marx 
Chief Judge 
ill The Court notes that, if there was a court order directing the State Attorney or the Clerk to 
disclose records and the State Attorney or the Clerk refused, the remedy for disobeying a court order 
i<; contempt or, in some instances, a mandamus proceedings -- not a civil lawsuit. 
COPIES TO: 
DOUGLAS A. WYLER 
No Address Available 
961687 GATEWAY BLVD 
SUITE 201-1 
FERNANDINA BEACH, FL 
Page 6 of 7 
No E-miil Address Available 
doug.wyler@corocast.net 

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Case No.50-2019-CA-014681-XXXX-MH 
MICHAEL GRYGIEL 
MICHAEL J. GRYGIEL 
NICOLE R. FINGERHUT 
NINA D. BOY AJIAN 
NINA D. BOY AJIAN 
STEPHEN A 
MENDELSOHN, ESQ 
32034 
54 STATE STREET 
6THFLOOR 
ALBANY, NY 12207 
No Address Available 
POST OFFICE BOX 229 
GRYGIELM@GTLAW .COM 
grygielrr(l!}gtlaw .com 
CLERK E-
WEST PALM BEACH, FL 
SERVICE@MYP ALMBEACH 
33401 
CLERK.COM 
No Address Available 
1840 CENTURY PARK 
EAST 
SUITE 1900 
LOS ANGELES, CA 90067 
nfing e rhut@mypalmbe ache lerk. 
com 
boyajiarm@gtlaw.com 
riveraal@gtlaw.com 
No E-miil Address Available 
5100 TOWN CENTER CIR 
rreIKlelsolms@gtlaw.com 
SUITE 400 
smithl@gtlaw.com 
BOCA RATON, FL 33486 
flservice@gtlaw.com 
Page 7 of 7 

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Def.Ex.A-8 

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JACOBS SCHOLZ & WYLER, LLC. 
A LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS 
ATTORNEYS AT l.AW 
GATEWAY TO AMELIA 
THE LAW OFFICES OF 
JACOBS & ASSOCIATES, P.A. 
ARTHUR I. JACOBS 
961687 GATEWAY BLVD .. SUITE 201-1 
FERNANDINA BEACH, FLORIDA 32034 
June 8, 2020 
VIA ELECTRONIC & U.S. MAIL 
Stephen A. Mendelsohn, Esq. 
Greenburg Traurig, P.A. 
5100 Town Center Circle, Suite 400 
Boca Raton, FL 33486 
TELEPHONE (904) 261-3693 
FAX NO. (904) 261-7879 
RE: 
CA Florida Holdings, LLC v. Dave Aronberg et al. 
Palm Beach County, Case No.: 2019-CA-014681 
Dear Mr. Mendelsohn: 
RICHARD J, SCHOLZ. P.A. 
RICHARD J. SCHOLZ 
DOUGLAS A. WYLER, P.A. 
DOUGLAS A. WYLER 
As you are aware our finn represents the interests of Dave Aron berg, as State Attorney of Palm Beach 
County, Florida, in the above referenced matter. The purpose of this letter is to demand the voluntary 
dismissal of your First Amended Complaint, (the "Complaint"), dated January 17, 2020. This demand 
is made pursuant to section 57.105, Florida Statutes. 
As you know, Section 57 .105 provides: 
(1) Upon the court's initiative or motion of any party, the court shall award a 
reasonable attorney's fee, including prejudgment interest, to be paid to the 
prevailing party in equal amounts by the losing party and the losing party's attorney 
on any claim or defense at any time during a civil proceeding or action in which 
the court finds that the losing party or the losing party's attorney knew or should 
have known that a claim or defense when initially presented to the court or at any 
time before trial: 
a. 
Was not supported by the material facts necessary to establish the claim or 
defense; or 
b. Would not be supported by the application of then-existing law to those 
material facts. 
Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count II of the 
Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiffs only remaining cause of action 
co...

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First and foremost, the Complaint is not supported by the material facts necessary to establish the 
claims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the 
Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein. 
Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are 
impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to 
this action because no matter what, he and his office do not have possession, custody, or control of the 
requested materials. 
In addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims 
are also not supported by the application of current law. Specifically, your action for declaratory relief 
fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes, 
which states: 
When such disclosure is ordered by a court pursuant to subsection ( 1) for use in a civil 
case, it may be disclosed to all parties to the case and to their attorneys and by the latter 
to their legal associates and employees. However, the grand iury testimony afforded 
such persons by the court can only be used in the defense or prosecution o(the civil or 
criminal case and for no other purpose whatsoever. 
Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable 
to comply with any court order granting disclosure of the requested documents because neither Mr. 
Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession, 
custody, or control of the 2006 Epstein grand jury records. 
Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter, 
the enclosed Motion for Attorney's Fees will be filed and we will seek as sanctions, from your client 
and your firm, recovery of the...

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
I 
-----.,....------------
CASE NO.: 19-CA-014681 
DEFENDANT, DA VE ARONBERG'S MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57. I 05, 
to award him reasonable attorneys' fees for the defense of Plaintiffs First Amended Complaint, 
(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, together with a letter from the undersigned attorney, in accordance with 
subsection ( 4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior 
to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish that the Complaint is without support of the facts or the law. 
WHEREFORE, Defendant, DA VE ARONBERG, as State Attorney of Palm Beach 
County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiffs 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 

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CERTIFICATE OF SERVICE 
I hereby certify that on this __ day ___ , 2020, the foregoing was electronically filed 
via the Florida E-File Portal for electronic service on the parties of record herein. 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esquire 
Fla. Bar No.: 108249 
Richard J. Scholz, Esquire 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esquire 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 
j acobsscho lzlaw@comcast.net 
Attorneys for Defendant 

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Def.Ex.A-9 

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IJ GreenbergTraurig 
Stephen A. Mendelsohn 
Tel 561.955.7629 
Fax 561.659.9119 
mendelsohns@gtlaw.com 
June 23, 2020 
Douglas A. Wyler 
Jacob Scholz & Wyler, LLC 
961687 Gateway Blvd. 
Suite 201-I 
Fernandina Beach, FL 32034 
Re: 
CA Florida Holdings, LLC v. Dave Aron berg et al. 
Case No. 2019-CA-014681 
Dear Mr. Wyler: 
We are in receipt of your letter of June 8, 2020withyourproposedFla. Stat. section 57.105 motion. 
fu your letter and your proposed motion, you asse1i that CA Florida Holdings, LLC and the law 
furn of Greenberg Traurig, P.A. should be liable for the attorneys' fees to be incurred by State 
Attorney Aronberg after the date of your letter. Your letter cites to Fla. Stat. sections 57.105(1) 
(a) and (b) for suppo1i. As shown below, there is no basis for a Fla. Stat. section 57.105 motion, 
and we expect that if the State Attorney were to make such a motion, the court should deny it. 
Your letter omits a citation to section 57.105(3). Subsection 57.105(3)(a) provides that sanctions 
may not be awarded where there is a "good faith argument for the extension, modification or 
reversal of existing law or the establishment of new law, as it is applied to the material facts, with 
a reasonable expectation of success." We have such a good faith argument. 
Contrary to your analysis of Fla. Stat. section 905.27, there are actually three instances where a 
court may order the release of grand jury materials. As we argue, the court may order release "in 
furtherance of justice." There are few cases in Florida reviewing this provision and its scope. It is 
an open and valid question as to whether the comi may order release of grand jury transcripts to 
the media, under both the statute and the First Amendment to the US Constitution in fmiherance 
of justice. The statutory language you cite refers to instances where a person is seeking grand jury 
materials for use in a civil or in a criminal case. fu these limited situations, the statute all...

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C01Tespondence to Douglas A Wyler 
June 23, 2020 
Page2 
use limitation you cite applies. No reported Florida case has addressed this issue and there is a 
good faith basis for our view of Fla. Stat. section 905.27 
Your letter also argues that sanctions are applicable because the State Attorney has alleged that it 
does not possess the Jeffrey Epstein grand jury transcripts. This allegation is also contained in the 
State Attorney's Answer. Assuming that the State Attorney does not cunently have physical 
possession of the Epstein grand jury materials, which has yet to be demonstrated, this does not end 
the matter. The State Attorney was named as a party not simply as a custodian of grand jury 
records. The State Attorney was named in his official capacity as his office has "as its primary 
interest the protection of its grand jury system." [Italics in original.] In re Grand Jury Proceedings, 
832 F. 3d 554, 559 (11 th Circuit 1987). In that case, the US petitioned a state judge to order the 
State Attorney to turn over grand jury transcripts. The State Attorney argued against their release 
citing to Fla. Stat. section 905.27. Later, a federal grand jmy subpoenaed the Broward County 
State Attorney for delivery of state grand jury testimony. The Broward State Attorney advised the 
federal court that it would produce the transcripts, thereby demonstrating that while it may not 
have physical possession of the materials, he had legal authority to obtain and deliver them. It 
should also be noted that the State Attorney moved to quash the subpoena arguing that it was 
unlawful under Florida law and Fla. Stat. section 905. 2 7. This case indicates that where one seeks 
grand jury materials, the relevant State Attorney is a necessa1y patty in order to protect the grand 
jmy that the Office of State Attorney supervised and to make arguments, if need be, against release 
of the grand jury materials. These are some of the same reasons why the State A...

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C01Tespondence to Douglas A Wyler 
June 23, 2020 
Page3 
For these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed 
against the Office of the State Attorney. We expect that your demand will be withdrawn. 
Thank you, 
Very truly yours, 
ls/Stephen Mendelsohn 
Stephen Mendelsohn 
SAM:ls 
ACTIVE 51081659v1 
Greenberg Tramig, P.A. I Attm-nevs at Law 
www.gllaw.com 

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Def.Ex.A-I 0 

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
CASE NO.: 19-CA-014681 
DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57 .105, 
to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint, 
( the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, together with a letter from the undersigned attorney, in accordance with 
subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior 
to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish that the Complaint is without support of the facts or the law. 
WHEREFORE, Defendant, DA VE ARONBERG, as State Attorney of Palm Beach 
County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 

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CERTIFICATE OF SERVICE 
I hereby certify that on this 1st day July, 2020, the foregoing was electronically filed via 
the Florida E-File Portal for electronic service on the parties of record herein. 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esquire 
Fla. Bar No.: 108249 
Richard J. Scholz, Esquire 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esquire 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 
j ac obsscholzla w@comcast.net 
Attorneys for Defendant, Dave Aronberg 

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Def.Ex.A-11 

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DAVE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Pahn 
Beach County, Florida. 
Defendants. 
I 
----------------
CASE NO.: 19-CA-014681 
DEFENDANT DAVE ARONBERG'S MOTION FOR SUMMARY FINAL JUDGMENT 
AND MEMORANDUM OF LAW IN SUPPORT THEREOF 
Defendant 
DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, 
(hereinafter "Aronbcrg"), by and through counsel below and pursuant to Rule 1. 510 Florida Rules of 
Civil Procedure, moves for entry of summary final judgment in his favor as to the remaining claim for 
Declaratory Relief in Plaintiff's First Amended Complaint 1 , and in support thereof states as follows: 
STATEMENT OF THE UNDISPUTED FACTS 
The following is a statement of facts material to this motion for summary judgment as to which 
there is no genuine issue: 
1. 
Count I of Plaintiff's First Amended Complaint, (hereinafter "Complaint"), filed 
January 17, 2020, seeks Declaratory Relief pursuant to Section 86.011, Florida Statutes. 
2. 
Specifically, Plaintiff's Count I seeks a court order "declaring that pursuant to Fla. Stat. 
Section 905.27(1)(c) and the Court's inherent authority, The Palm Beach Post may gain access to the 
testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury" that 
1 On June 8, 2020, this Court entered its Order Granting Defendants Motion to Dismiss Count II of the Plaintifrs First 
Amended Complaint with Prejudice. 

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was empaneled during the first Jeffrey Epstein, (hereinafter "Epstein"), sex abuse investigation, 
(hereinafter "Requested Materials"). Complaint pg. 20 
3. 
Plaintiff seeks to use the Requested Materials "for the purpose ofinfonning the public." 
Id. 
4. 
Plaintiff seeks the above-referenced declaratory relief, including copies of the 
Requested Materials, from both Aronbcrg, as State Attorney of Palm Beach County, Florida, and 
Defendant, Sharon R. Bock, as Clerk and Comptroller of Palm Beach County, Florida, (hereinafter the 
"Clerk"). 
5. 
N ci thcr Aronbcrg nor the Office of the S tatc A ttomcy for the Fifteenth Judicial Circuit, 
("SAO"), is in control, custody, or possession of the Requested Materials. Aronbcrg Aff. ,i 3, attached 
as Exhibit "A". 
6. 
The declaratory relief sought by the Plaintiff seeks materials that arc impossible for 
Aronbcrg or the SAO to produce. Exhibit "A" ,i 4. 
7. 
Neither Aronbcrg nor the SAO has the legal authority to obtain and/or deliver the 
Requested Materials. Exhibit "A" ,i 5. 
8. 
The undisputed facts set forth above in paragraphs 6-7 have been repeatedly made 
evident by Aronbcrg to the Plaintiff and the public through not only the pleadings and correspondence 
in this matter, but also through an office press release and Aronbcrg's public social media accounts. 
Exhibit "A" ,i 6. 
9. 
Neither Aronbcrg nor the SAO has the authority to demand that the Clerk grant the 
SAO access to grand jury materials after a criminal case has concluded. Exhibit "A" ,i 7. 
10. 
During Aronbcrg's administration, neither he nor his office has accessed grand jury 
materials from the Clerk's office in this or any other instance. Exhibit "A" ,i 8. 
2 

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11. 
As provided in section 905 .17( 1 ), Florida Statutes (2020), the Clerk has sole custody 
and possession of the Requested Materials, which can only be released by the Clerk pursuant to an 
order of the Court. Exhibit "A" ,i 9. 
MEMORANDUM OF LAW 
I. 
Legal Standard Governing Motions For Summary Judgment 
"The judgment sought shall be rendered forthwith if the pleadings, depositions, answers to 
interrogatories, and admissions on file together with the affidavits, if any, show that there is no genuine 
issue of material fact and that the moving party is entitled to a judgment as a matter of law." Rule 
1. 510, Fla. R. Ci v. P. It is appropriate to resolve a declaratory action on summary judgment when, as 
here, the decree seeks a legal interpretation of a statute. Rahimi v. Global Discoveries, Ltd., LLC, 252 
So. 3d 804 (Fla. 5th DCA 2018). 
II. 
The Requested Materials Can Only Be Released By The Clerk Pursuant To A Court 
Order 
Notably, neither Aronbcrg nor the SAO is in control, custody, or possession of the Requested 
Materials. Exhibit "A" ,i 3. Nonetheless, pursuant to Section 905.27(1)(c), Florida Statutes and the 
Court's inherent authority, Plaintiff seeks a court order declaring that Aronbcrg provide copies of the 
Requested Materials to The Palm Beach Post for the purpose of infonning the public. Complaint pg. 
20-21. 
Plaintiff is seeking declaratory relief allc ging its cnti tlcmcnt to the Rcqucs ted Materials 
pursuant to the "furthering justice" exception to grand jury secrecy. § 905 .27, Fla. Stat. (2020). 
Despite bringing its declaratory relief claim pursuant to Section 905.27, Florida Statutes, "a 
single part of a statute should not be read in isolation." Universal Prop. & Cas. Ins. Co. v. Loftus, 276 
So. 3d 849, 851 (Fla. 4th DCA 2019). "Instead, 'all parts of a statute must be read together in order to 
achieve a consistent whole."' Id. (quoting Forsythe v. Longboat Key Beach Erosion Control Dist., 
604 So. 2d 452, 45...

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S cction 905 .1 7 ( 1 ), Florida Statutes makes clear that grand jury records, like the Requested 
Materials in this matter, arc to be maintained with the Clerk, and can only be released by the Clerk 
pursuant to a court order. To wit: 
The stenographic records, notes, and transcriptions made by the court reporter or 
stenographer shall be filed with the clerk who shall keep them in a scaled container not 
subject to public inspection. The notes, records, and transcriptions are confidential 
and exempt from the provisions of s. 119.07(1) and s. 24(a), Art. 1 of the State 
Constitution and shall he released by the clerk only on request by a grand jury for use 
by the grand jury or on order of the court pursuant to s. 905.27. 
Section 905 .17( 1 ), Florida S tatutcs (2020). (Emphasis added.) 
Text, context, and purpose arc the ordinary tools used for discerning statutory meaning, with 
the overarching principle being "that judges lack the power to construe an unambiguous statute in a 
way which would extend, modify, or limit its express tenns or its reasonable and obvious implications. 
To do so would be an abrogation of lcgislati vc power." Id. Herc, the plain language of section 905 .1 7 
is clear and unambiguous and, therefore, controls. See Horowitz v. Plantation Gen. Ho.sp. Ltd. P'ship, 
959 So. 2d 176, 182 (Fla. 2007). 
Accordingly, based on the clear, unambiguous statutory language set forth in section 905 .1 7 ( 1 ), 
only the Clerk, not the State Attorney, may release grand jury materials pursuant to an order of the 
court. Thus, it is apparent that Aronbcrg and the SAO lack the legal authority to obtain and deliver the 
Requested Materials. Exhibit "A" ,i 5. Likewise, the declaratory relief sought by the Plaintiff seeks 
materials that arc impossible for Aronbcrg or the SAO to produce. Exhibit "A" ,i 4. Again, the Clerk 
has sole custody and possession of the Requested Materials. These facts have been repeatedly made 
evident by Aronbcrg...

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Aronbcrg nor the SAO has the authority to demand that the Clerk grant the SAO access to grand jury 
materials after a criminal case has concluded. 
Exhibit "A" ,i 7. 
Hence, during Aronbcrg's 
administration, neither he nor his office has accessed grand jury materials from the Clerk's office in 
this or any other instance. Exhibit "A" ,i 8. 
III. 
Conclusion 
The ultimate facts underlying the lawsuit arc not in dispute. The Court is fully empowered to 
dispose of this matter based on application of the undisputed facts to the plain language of Section 
905.17, Florida Statutes, which renders the Plaintiff's action for declaratory relief an impossibility for 
Aronbcrg to pcrfonn and that must be denied as a matter oflaw. 
WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, 
Florida, respectfully requests that this motion be granted and that summary final judgment be entered 
in his favor consistent with this motion, and hereby respectfully requests that this Court dismiss the 
Complaint with prejudice and grant such other relief, including attorney's fees and costs, as this Court 
deems fit and proper under the circumstances. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 18th day of August, 2020, a copy of the foregoing has been 
electronically filed with the Florida E-Filc Portal for c-scrvicc on all parties of record herein. 
5 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esq. 
Fla. Bar No.: 10249 
Richard J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 Fax 
Primary: j aco bsscholzlaw@comcast.net 

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6 
General Counsel for the Florida Prosecuting 
Attorney's Association 

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EXHIBIT ''A'' 
EXHIBIT ''A'' 

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TN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
v. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Cleric and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
----------------'/ 
CASE NO.: 19..CA-014681 
AFFIDAVIT OF DAVID ARONBERG 
ST ATE OF FLORIDA 
COUNTY OF PALM BEACH 
Before me, the undersigned authority personally appeared DAVID ARONBERG, being first duly sworn, 
states: 
I. 
My name is David (Dave) Aronberg, and I am the State Attorney for the Fifteenth Judicial 
Circuit/Palm Beach County, Florida, since 2013, and a Defendant in the above-captioned matter. 
2. 
Plaintiff is seeking dee laratory relief, pursuant to Fla. Stat. 90 S .21 (I)( c) and the Court's 
inherent authority, allowing Plaintiff access to the testimony, minutes, and other evidence presented in 2006 
to the Palm Beach County grand jury, (the "Requested Materials"), and to use those materials for the 
purpose of informing the public. 
3. 
Despite Plaintiffs above-described action for declaratory relief, neither myself nor the 
Office of the State Attorney for the Fifteenth Judicial Circuit, ("SAO"), is in control, custody, or possession 
of the Requested Materials. 
4. 
As such, the declaratory relief sought by the Plaintiff seeks materials that are impossible 
for me or my office to produce. 
5. 
To be clear, neither myself nor the SAO has the legal authority to obtain and deliver the 
Requested Materials. 
6. 
I have repeatedly made these facts evident to the Plaintiff and the public through not only 
the pleadings and correspondence in this matter, but also through an office press release and my public 
social media accounts. 

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7. 
Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to 
demand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded. 
8. 
Moreover, during my administration, neither myself nor my office has accessed grand jury 
materials from the Clerk's office in this or any other instance. 
9. 
As provided in section 905.17( 1 ), Florida Statutes (2020), the Clerk has sole custody and 
possession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the 
Court. 
FURTHER AFFIANT SA YETH NAUGHT. 
ST A TE OF FLORIDA 
COUNTY OF PALM BEACH 
.. 
Sw_gm tQ_ and subscribed before me this 36iay of July, 2020, by DAVID ARON BERG, who is 
(·personally known)to me or has shown __________ as personal identification. 
•-.. ____ ' -
. 
--· --- _ _________,,, 
LAT~LOWE-GODDE 
~I 
GG 111111 
e...,.11ay21,,a, 
.... n.,,_,..,._, .... 

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Def.Ex.A-12 

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TN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
v. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Cleric and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
----------------'/ 
CASE NO.: 19..CA-014681 
AFFIDAVIT OF DAVID ARONBERG 
ST ATE OF FLORIDA 
COUNTY OF PALM BEACH 
Before me, the undersigned authority personally appeared DAVID ARONBERG, being first duly sworn, 
states: 
I. 
My name is David (Dave) Aronberg, and I am the State Attorney for the Fifteenth Judicial 
Circuit/Palm Beach County, Florida, since 2013, and a Defendant in the above-captioned matter. 
2. 
Plaintiff is seeking dee laratory relief, pursuant to Fla. Stat. 90 S .21 (I)( c) and the Court's 
inherent authority, allowing Plaintiff access to the testimony, minutes, and other evidence presented in 2006 
to the Palm Beach County grand jury, (the "Requested Materials"), and to use those materials for the 
purpose of informing the public. 
3. 
Despite Plaintiffs above-described action for declaratory relief, neither myself nor the 
Office of the State Attorney for the Fifteenth Judicial Circuit, ("SAO"), is in control, custody, or possession 
of the Requested Materials. 
4. 
As such, the declaratory relief sought by the Plaintiff seeks materials that are impossible 
for me or my office to produce. 
5. 
To be clear, neither myself nor the SAO has the legal authority to obtain and deliver the 
Requested Materials. 
6. 
I have repeatedly made these facts evident to the Plaintiff and the public through not only 
the pleadings and correspondence in this matter, but also through an office press release and my public 
social media accounts. 

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7. 
Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to 
demand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded. 
8. 
Moreover, during my administration, neither myself nor my office has accessed grand jury 
materials from the Clerk's office in this or any other instance. 
9. 
As provided in section 905.17( 1 ), Florida Statutes (2020), the Clerk has sole custody and 
possession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the 
Court. 
FURTHER AFFIANT SA YETH NAUGHT. 
ST A TE OF FLORIDA 
COUNTY OF PALM BEACH 
.. 
Sw_gm tQ_ and subscribed before me this 36iay of July, 2020, by DAVID ARON BERG, who is 
(·personally known)to me or has shown __________ as personal identification. 
•-.. ____ ' -
. 
--· --- _ _________,,, 
LAT~LOWE-GODDE 
~I 
GG 111111 
e...,.11ay21,,a, 
.... n.,,_,..,._, .... 

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Def.Ex.A-13 

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Filing# 115383434 E-Fil_ed 10/21/2020 04: 13:35 PM 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, ·as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 50-2019-CA-014681-XXXX-MB 
DIVISION; AG 
PLAINTIFF CA HOLDINGS, LLC'S 
NOTICE OF DROPPING ST A TE ATTORNEY, DA VE ARONBERG 
Plaintiff, CA HOLDINGS, LLC, pursuant to Fla. R. Civ. P. 1250(b), hereby notifies the parties that 
it has dropped State Attorney, Dave Aronberg from the above case. 
Respectfu I ly submitted, 
GREENBERG TRAURIG, P.A. 
Attorneys for CA Florida Holdings, LLC, Publisher 
of The Palm Beach Post 
Stephen A. Mendelsohn, Esq. 
40 I East Las Olas Boulevard Suite 2000 
Boca Raton, Florida 33486 
Telephone: (561) 955-7629 
Facsimile: (561) 338-7099 
By: !.,I Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 
mende I soh ns@gt law .com 
smith I( i"vbrtl aw .corn 
FLServ icc(dl gt law .com 

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By: Isl Michael J Grygiel 
MICHAEL J GRYGIEL 
(Admitted Pro Hae Vice) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile: (518) 689-1499 
grvgielm@gtlaw.com 
By: Isl Nina D. Boyaiian 
NINA D. BOY AJIAN 
(Admitted Pro Hae Vice) 
1840 Century Park East, Suite 1900 
Los Angeles California 90067 
Telephone: (310) 586-7700 
Facsimile: (310) 586-7800 
bovaj iann@gtlaw.com 
ri veraali'it)gt law .com 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 2151 day of October, 2020, a true and correct copy of the 
foregoing has been filed with the Clerk of the Court usihg the State of Florida e-filing system, which 
wi 11 send a notice of electronic service for al I parties of record herein 
ACTIVE 53317341v1 
Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
2 

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Def.Ex.A-14 

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
CASE NO.: 19-CA-014681 
DEFENDANT DAVE ARONBERG'S AMENDED MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned counsel, hereby moves this Honorable Court, pursuant to Rule 1.525, Fla. 
R. Civ. P. to enter an award of attorneys' fees in his favor against Plaintiff, CA FLORIDA 
HOLDINGS, LLC, publisher of the PALM BEACH POST, and in support thereof states the 
following: 
BASIS FOR AWARDING ATTORNEYS' FEES 
1. 
On November 14, 2019, CA FLORIDA HOLDINGS, LLC, publisher of the PALM 
BEACH POST ("Plaintiff') filed a complaint against DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida (the "State Attorney" or "Defendant Aronberg") and SHARON R. 
BOCK, as Clerk and Comptroller of Palm Beach County, Florida (the "Clerk"). The basis of the 
action was asking the Court to order the State Attorney and the Clerk to disclose the 2006 Jeffrey 
Epstein grand jury materials, (the "Requested Materials"), pursuantto § 905.27(1) Fla. Stat. 

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2. 
On December 6, 2019, the State Attorney filed his Motion to Dismiss, then on 
December 13, 2019, the Clerk also filed a Motion to Dismiss. In response, Plaintiff filed its First 
Amended Complaint on January 17, 2020, which in addition to its original claim under§ 905.27 
Fla. Stat. (Count II) added a claim for Declaratory Relief (Count I) that sought an order declaring 
that the State Attorney and the Clerk disclose the Requested Materials to Plaintiff for the purpose 
of informing the public. 
3. 
On January 24, 2019, both the State Attorney and the Clerk filed their Answer to 
the First Amended Complaint and Motion to Dismiss Count II ("Answer/Motion to Dismiss). 
Notably, the State Attorney's Answer/Motion to Dismiss asserted its right to attorneys' fees for 
defending the action and requested such relief from the Court. 
4. 
On June 8, 2020, the Court entered its Order Granting Defendants Motions to 
Dismiss Count II of Plaintiff's First Amended Complaint with Prejudice ("Order"). 
5. 
Immediately following the Court's Order, on June 8, 2020, the State Attorney, 
through the undersigned counsel, served Plaintiff with a demand pursuant to § 57 .105 Fla. Stat., 
to voluntary dismiss/withdraw the First Amended Complaint and the claims against the State 
Attorney, along with a Motion for Attorneys' Fees ("57 .105 Demand"). See, Exhibit "A"-
Specifically, because of the Court's Order only Count I of Plaintiffs Amended Complaint 
remained, which sought Declaratory Relief under§ 86.011, Fla. Stat. 
6. 
Here, in properly serving his 57 .105 Demand on Plaintiff, the State Attorney also 
properly put Plaintiff on notice that he would seek sanctions by filing the 57 .105 Motion for 
Attorneys' Fees if Plaintiff failed to dismiss the remainder of its First Amended Complaint within 
21 days of service of the 57.105 Demand and Motion for Attorneys' Fees. 
2 

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7. 
On June 23, 2020, Plaintiff's counsel sent a response to the 5 7 .105 Demand 
refusing to withdraw the remainder of the First Amended Complaint. See, Exhibit "B". 
8. 
§ 57.105, Florida Statutes states the following: 
A motion by a party seeking sanctions under this section must be served but may 
not be filed with or presented to the court unless, within 21 days after service of the 
motion, the challenged paper, claim, defense, contention, allegation, or denial is not 
withdrawn or appropriately corrected. 
9. 
Accordingly, after receiving Plaintiff's June 23, 2020, response refusing to 
withdraw the remainder of the First Amended Complaint and waiting the prerequisite "21 days 
after service of the motion" the State Attorney's Motion for Attorneys' Fees was filed with this 
Court on July 1, 2020. See, Exhibit "C". 
10. 
Thereafter, on August 18, 2020, the State Attorney filed his Motion for Summary 
Judgment ("Motion") and proceeded, on October 21, 2020, to file a Motion to Set Hearing on the 
State Attorney's Motion ("Motion to Set") after it became clear that there would be no resolution 
of this matter without the Court's intervention. 
11. 
Nonetheless, later the same day, rather than setting and participating in a hearing 
on the merits as to State Attorney's Motion, Plaintiff filed its Notice of Dropping the State Attorney 
("Notice") from the instant case. See, Exhibit "D". As a consequence of filing its Notice, Plaintiff 
has effectively made an admission that its allegations against the State Attorney have no basis in 
fact or law. 
12. 
"An essential distinction between a notice of dropping a party and a voluntary 
dismissal is that the former concludes the action as to the dropped party while the latter is generally 
utilized to conclude the action in its entirety." Carter v. Lake County, 840 So. 2d 1153, 1155 (Fla. 
5th DCA 2003). 
3 

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13. 
Specifically, Plaintiff's Notice states: "Plaintiff, [sic], pursuant to Fla. R. Ci v. P. 
1.250(b), hereby notifies the parties that it has dropped State Attorney, Dave Aronberg from the 
above case." 
14. 
Rule 1.250(b), Fla. R. Civ. P. states: 
(b) Dropping Parties. Parties may be dropped by an adverse party in the manner 
provided for voluntary dismissal in rule 1. 420(a)(l) subject to the exception stated 
in that rule. If notice of lis pendens has been filed in the action against a party so 
dropped, the notice of dismissal shall be recorded and cancels the notice of lis 
pendens without the necessity of a court order. Parties may be dropped by order of 
court on its own initiative or the motion of any party at any stage of the action on 
such terms as are just. 
15. 
Rule 1.420(a)(l), Fla. R. Civ. P., Voluntary Dismissal states: 
( 1) By Parties. Except in actions in which property has been seized or is in the 
custody of the court, an action, a claim, or any part of an action or claim may be 
dismissed by plaintiff without order of court (A) before trial by serving, or during 
trial by stating on the record, a notice of dismissal at any time before a hearing on 
motion for summary judgment, or if none is served or if the motion is denied, before 
retirement of the jury in a case tried before a jury or before submission of a nonjury 
case to the court for decision, or (B) by filing a stipulation of dismissal signed by 
all current parties to the action. Unless otherwise stated in the notice or stipulation, 
the dismissal is without prejudice, except that a notice of dismissal operates as an 
adjudication on the merits when served by a plaintiff who has once dismissed in 
any court an action based on or including the same claim. 
16. 
Notably, "[R ]ule 1.250(b) expressly incorporates the procedural aspects of Florida 
Rule of Civil Procedure 1.420(a)( 1) governing voluntary dismissal by providing that parties may 
be dropped 'in the ma...

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18. 
Accordingly, the Siboni court held that a "party dropped from litigation under rule 
1.250(b) is subject to the time limitation contained in rule 1.525 governing service of a motion 
seeking a judgment for costs and attorney's fees." Id. 
19. 
Although Plaintiff filed its Notice the claims asserted by Plaintiff have been, since 
the filing of its initial complaint, completely without support of the facts or the law. Attheir very 
core, all of Plaintiff's claims are based on the presumption that the State Attorney has the authority 
to disclose the Requested Materials. Nonetheless, Section 905.17( 1 ), Florida Statutes makes clear 
that Plaintiffs Requested Materials can only be released by the Clerk pursuant to a court order. 
The stenographic records, notes, and transcriptions made by the court reporter or 
stenographer shall be filed with the clerk who shall keep them in a sealed container 
not subject to public inspection. The notes, records, and transcriptions are 
confidential and exempt from the provisions ofs. 119.07(1) ands. 24(a), Art. I of 
the State Constitution and shall be released by the clerk only on request by a grand 
jury for use by the grand jury or on order o(the court pursuant to s. 905.27. 
Section 905.17( 1 ), Florida Statutes (2020). 
20. 
The State Attorney has no objection to the Clerk producing and disclosing the 
Requested Materials should the Court grant an order to that effect, however, it is impossible for 
the State Attorney to comply with the relief sought by Plaintiff in its remaining claim for 
declaratory relief as he does not possess or control the Requested Materials and is statutorily barred 
from any disclosure. 
21. 
Although the State Attorney was prepared to make his argument to the Court, 
Plaintiff decided instead to drop him as a party. Despite Plaintiff's decision, the Florida Rules of 
Civil Procedure and the above authorities make clear that because Rule 1.250 specifies that a party 
is dropp...

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22. 
Consequently, the filing of Plaintiff's Notice triggered Rule 1.525, Fla. R. Civ. P. 
and therefore: 
Under[§ 57 .105], the legislature has expressed its unequivocal intent that where a 
party files a meritless claim, suit or appeal, the party who is wrongfully required to 
expend funds for attorneys' fees is entitled to recoup those fees. 
Martin County Conservation Alliance v. Martin County, 73 So. 3d 856, 857 (Fla. 1st DCA 2011) 
( finding that "Courts are not at liberty to disregard the legislative mandate that courts shall impose 
sanctions in cases without foundation in material fact or law. The word "shall" in § 57 .105, Fla. 
Stat., evidences the legislative intent to impose a mandatory penalty to discourage baseless claims, 
by placing a price tag on losing parties who engage in these activities. Section 57 .105 expressly 
states courts "shall'' assess attorney's fees for bringing, or failing to dismiss, baseless claims or 
defenses."). 
23. 
In fact, "Section 57 .105( 1) clearly and explicitly confers upon the trial court the 
authority to award attorney's fees to the prevailing party upon the court's initiative, if 'the court 
finds that the losing party ... knew or should have known that a claim or defense when initially 
presented to the court or at any time before trial ... [ w ]as not supported by the material facts 
necessary to establish the claim or defense." Koch v. Koch, 47 So. 3d 320, 324 (Fla. 2d DCA 
2010). 
24. 
The simple fact of the matter is that Plaintiff failed to withdraw its Amended 
Complaint against the State Attorney within the 21-day period provided for in section 57.105(4), 
and therefore the State Attorney was permitted to file his 57.105 Motion for Attorneys' Fees as 
sanctions. 
25. 
Furthermore, based on the impossible nature of Plaintiff's demand of the State 
Attorney, it was proper to demand withdrawal of Plaintiff's remaining claim for declaratory relief 
6 

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and serve the 57.105 Motion for Attorneys' Fees due to Plaintiff's claim lacking any basis in fact 
or law. Again, neither the State Attorney nor his office has possession, custody or control of the 
Requested Materials. Likewise, the State Attorney has no objection, and never has had any 
objection, to the Clerk releasing the records sought by Plaintiff, as disclosure of the Requested 
Materials sought by Plaintiff lies solely within the providence of the Clerk pursuant to an order of 
the Court. 
26. 
Consequently, the State Attorney is entitled to recover all of his reasonable 
attorneys' fees in defending this suit by virtue of 57 .105, Florida Statutes. 
REASONABLENESS AND AMOUNT OF ATTORNEYS' FEES 
27. 
From the service of the 57 .105 Demand to the date of this motion, the attorneys for 
the State Attorney have rendered 42 .2 hours of legal services for a total amount of $18,275.00 in 
defending this action. See time sheets detailing: the amount of hours by each timekeeper, the 
timekeeper's hourly rate, and a description of the tasks done during those times, on attached 
Exhibit "E". Of that amount, the undersigned has been paid $0.00 as the engagement with the 
State Attorney is on a pure contingency fee basis. The undersigned expects to incur an additional 
4.0 hours at $425.00 an hour in preparing for and attending the hearing on attorneys' fees. Thus, 
the total amount of hourly attorneys' fees the State Attorney is seeking is 46.2 hours for a total of 
$19,975.00. As further set forth below, the State Attorney also seeks a multiplier of 2.0, which 
when applied makes the grand total attorneys' fees as sanctions sought herein $39,950.00. 
28. 
An Affidavit of Attorneys' Fees is attached hereto as Exhibit "F", which details 
and breaks down the attorneys' fees sought herein. 
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29. 
The State Attorney would offer the following facts and arguments as they relate to 
the factors promulgated in Rule 4-1.5 of the Rules Regulating the Florida Bar and Florida Patient's 
Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla. 1985): 
Factor 
(A) the time and labor 
required, the novelty, 
complexity, and difficulty 
of the questions involved, 
and the skill requisite to 
perform the legal service 
properly 
(B) the likelihood that the 
acceptance of the 
particular employment 
will preclude other 
employment by the lawyer 
( C) the fee, or rate of fee, 
customarily charged in the 
locality for legal services 
of a comparable or similar 
nature 
(D) the significance of, or 
amount involved in, the 
subject matter of the 
representation, and the 
results obtained 
(E) the time limitations 
imposed by the client or 
by the circumstances and, 
as between attorney and 
client, any additional or 
special time demands or 
requests of the attorney by 
the client 
(F) the nature and length 
of the professional 
relationship with the client 
Facts and Arguments 
The time involved by counsel was substantial, consuming nearly 
75 hours of legal work. Moreover, the issues in controversy were 
novel and complex in that Plaintiff sought to create a new private 
statutory cause of action under Florida Statute§ 905.27, implicated 
several 1st Amendment issues, and further sought declaratory 
relief pursuant to said Statute. Finally, this litigation has been 
ongoing for nearly a year and required skill and knowledge in these 
areas of the law. 
Because of the amount of time involved in this litigation and 
considering the relative small size of the firm representing the State 
Attorney, the undersigned attorneys were forced to tum away or 
delay representing other clients especially during critical stages of 
the litigation, due to time required in the instant matter. 
The base fees consisting of $425.00/hour for Mr. Wyler's services 
and $475.00/ho...

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(G) the experience, 
This representation required experience in a field available to few 
reputation, diligence, and 
lawyers, which included defending the State Attorney from claims 
ability of the lawyer or 
of a media entity and lawyers from multiple states regarding the 
lawyers performing the 
release of information with a nationwide interest. Accordingly, the 
service and the skill, 
undersigned counsel conducted the representation with skill and 
expertise, or efficiency of 
efficiency wherein Defendant Aronberg was dismissed from the 
effort reflected in the 
action prior to any hearing on the merits before the court. 
actual providing of such 
services 
(H) whether the fee is 
The fee arrangement herein was entirely contingent, wherein 
fixed or contingent, and, if obtaining a fee was conditioned upon prevailing and obtaining an 
fixed as to the amount or 
order awarding fees. 
rate, then whether the 
client's ability to pay 
rested to any significant 
degree on the outcome of 
the representation. 
JUSTIFICATION FOR MULTIPLIER 
30. 
Defendant Aronberg was able to proceed with this litigation only if counsel would 
receive a court order a warding contingency based attorneys' fees upon achievement of a successful 
outcome in this case. See, Exhibit "G". Given this and the fact that counsel risked a total of 74.8 
hours of work for no pay, of which 39.4 hours is subject to the 57 .105 Demand, Defendant 
Aron berg submits that multiplier of 2.0 would be appropriate in this case. Based upon the hours 
expended, the hourly rates and a 2.0 multiplier, Defendant Aronberg respectfully requests an award 
of attorneys' fees as sanctions as stated herein. 
31. 
With regard to the application of a multiplier, the court must analyze the three 
factors set forth in Standard Guaranty Insurance Co. v. Quanstrom, 555 So. 2d 828 (Fla. 1990): 
( 1) whether the relevant market requires a contingency fee multiplier to obtain 
competent counsel; (2) whether t...

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32. 
Here, as to the first factor there was no other counsel in the relevant market who 
would agree to represent Defendant Aronberg under the contingency fee agreement needed due to 
the financial situation of the Office of the State Attorney as a public entity funded entirely by the 
taxpayers of the State of Florida. Although "Risk Mitigation" within the Florida Department of 
Financial Services and the Office of the Attorney General indeed represent the State Attorney in 
some instances, this case was not picked up by either and Defendant Aronberg was left needing 
representation by other, private counsel. Although the undersigned counsel and his law firm are 
General Counsel for the Florida Prosecuting Attorneys' Association, Inc., ("FPAA") the instant 
matter did not fall within the scope of representation for the FP AA and required a separate 
engagement between Defendant Aronberg and the undersigned counsel. 
Accordingly, the 
undersigned counsel and his law firm agreed to represent Defendant Aronberg on a contingency 
fee basis and to try the case to final judgment considering that there was no other counsel willing 
to represent Defendant Aron berg on such terms. 
33. 
With respect to the other factors to be considered in applying a multiplier as set 
forth in Quanstrom, here Defendant Aronberg was unable to mitigate against non-payment of fees 
because as a purely taxpayer funded entity, the Office of State Attorney had no other means by 
which to pay the undersigned counsel. Additionally, Defendant Aronberg meets each of the 
individual Rowe factors as set forth in the table located above on pages 8-9. Accordingly, based 
on the foregoing the application of a multiplier herein is proper. In this vein, the Rowe court set 
guidelines for the size of a multiplier, as follows: 
Based on our review of the decisions of other jurisdictions and commentaries on 
the subject, we conclude that in contingent fee cases, the lodestar figure calcul...

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be 2; and, when success was unlikely at the time the case was initiated, the 
multiplier should be in the range of 2.5 to 3. 
Florida Patient's Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla. 1985). 
34. 
Additionally, the Quanstrom court confirmed and modified the Rowe approach, as 
follows: 
However, we find that the multiplier in Rowe should be modified as follows: If the 
trial court determines that success was more likely than not at the outset, it may 
apply a multiplier of 1 to 1.5; if the trial court determines that the likelihood of 
success was approximately even at the outset, the trial judge may apply a multiplier 
of 1.5 to 2.0; and if the trial court determines that success was unlikely at the outset 
of the case, it may apply a multiplier of 2.0 to 2.5. Accordingly, our Rowe decision 
is modified to allow a multiplier from 1 to 2.5. 
Standard Guaranty Insurance Co. v. Quanstrom, 555 So. 2d 828, 834 (Fla. 1990). Thus, based 
upon all of the foregoing factors, Defendant Aron berg respectfully submits that a multiplier of 2.0 
is appropriate for this representation. 
CERTIFICATION OF GOOD FAITH EFFORT TO RESOLVE 
The undersigned certifies that a good faith effort was made to resolve the issues raised in 
this motion by agreement of the parties. The parties were unable to resolve by agreement the 
issues of entitlement to fees or the amount of fees. 
WHEREFORE, Defendant, DA VE ARONBERG, as State Attorney of Palm Beach 
County, Florida, prays that this Honorable Court will enter an Order awarding Defendant Aronberg 
his reasonable attorneys' fees with a multiplier of 2.0 against the Plaintiff, CA FLORIDA 
HOLDINGS, LLC, publisher of the PALM BEACH POST, in the amount of $39,950.00. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 9th day of November, 2020, a copy of the foregoing 
Defendant, Dave Aronberg's Amended Motion for Attorneys' Fees has been electronically filed 
with the Florida E-File Portal for e-service on all part...

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12 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esq. 
Fla. Bar No.: 10249 
Richard J. Scholz, Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 Fax 
Primary: j aco bsscho lzla w@comcast.net 
Attorneys for Defendant, Dave Aronberg 

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EXHIBIT ''A'' 
EXHIBIT ''A'' 

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Friday, September 18, 2020 at 11:09:24 Eastern Daylight Time 
Subject: 
Date: 
From: 
SERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, LLC V. 
DAVE ARON BERG ET AL. 
Monday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time 
Douglas Wyler 
To: 
'mendelsohns@gtlaw.com', sm ithl@gtlaw.com, flservice@gtlaw.com, Boyaj ian N@gtlaw.com, 
rive ra a l@gt law. com, G RYG IE LM@gtl aw. com 
Attachments: 2020-06-08 Aron berg 57.105 Demand and Motion for Attorneys' Fees.pdf 
Please see attached and below in this matter. 
Court: 
Circuit Court of the Fifteenth Judicial Circuit, in and for Palm Beach County, 
Florida 
Case No: 
Case No. 2020-CA-014681 
Plaintiff: 
CA Florida Holdings, LLC 
Defendant: 
Dave Aron berg 
Title of Documents 
• Fla. Stat.§ 57.105 Demand Letter 
Served: 
• Defendant, Dave Aronberg's Motion for Attorneys' Fees 
Sender's Name and 
Douglas Wyler 
Telephone Number: 
{904) 261-3693 
Sincerely, 
Doug Wyler, Esq. 
Jacobs, Scholz & Wyler, LLC 
961687 Gateway Blvd., STE 201-1 
Fernandina Beach, FL 32034 
904-261-3693 
904-261-7879 {fax) 
do ug. wylfil@co m cast.net 
Please be advised that this e-mail and any files transmitted with it are confidential attorney-client 
communication or may ot he rw is e be privileged or co nfid entia I and a re intended so le ly for the ind ivi d ua I or 
entity to whom they are addressed. If you are not the intended recipient, please do not read, copy or 
retransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or 
copying of this communication is strictly prohibited. 
Page 1 of 1 

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JACOBS SCHOLZ & WYLER, LLC. 
A LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS 
ATTORNEYS AT l.AW 
GATEWAY TO AMELIA 
THE LAW OFFICES OF 
JACOBS & ASSOCIATES, P.A. 
ARTHUR I. JACOBS 
961687 GATEWAY BLVD .. SUITE 201-1 
FERNANDINA BEACH, FLORIDA 32034 
June 8, 2020 
VIA ELECTRONIC & U.S. MAIL 
Stephen A. Mendelsohn, Esq. 
Greenburg Traurig, P.A. 
5100 Town Center Circle, Suite 400 
Boca Raton, FL 33486 
TELEPHONE (904) 261-3693 
FAX NO. (904) 261-7879 
RE: 
CA Florida Holdings, LLC v. Dave Aronberg et al. 
Palm Beach County, Case No.: 2019-CA-014681 
Dear Mr. Mendelsohn: 
RICHARD J, SCHOLZ. P.A. 
RICHARD J. SCHOLZ 
DOUGLAS A. WYLER, P.A. 
DOUGLAS A. WYLER 
As you are aware our finn represents the interests of Dave Aron berg, as State Attorney of Palm Beach 
County, Florida, in the above referenced matter. The purpose of this letter is to demand the voluntary 
dismissal of your First Amended Complaint, (the "Complaint"), dated January 17, 2020. This demand 
is made pursuant to section 57.105, Florida Statutes. 
As you know, Section 57 .105 provides: 
(1) Upon the court's initiative or motion of any party, the court shall award a 
reasonable attorney's fee, including prejudgment interest, to be paid to the 
prevailing party in equal amounts by the losing party and the losing party's attorney 
on any claim or defense at any time during a civil proceeding or action in which 
the court finds that the losing party or the losing party's attorney knew or should 
have known that a claim or defense when initially presented to the court or at any 
time before trial: 
a. 
Was not supported by the material facts necessary to establish the claim or 
defense; or 
b. Would not be supported by the application of then-existing law to those 
material facts. 
Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count II of the 
Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiffs only remaining cause of action 
co...

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First and foremost, the Complaint is not supported by the material facts necessary to establish the 
claims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the 
Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein. 
Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are 
impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to 
this action because no matter what, he and his office do not have possession, custody, or control of the 
requested materials. 
In addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims 
are also not supported by the application of current law. Specifically, your action for declaratory relief 
fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes, 
which states: 
When such disclosure is ordered by a court pursuant to subsection ( 1) for use in a civil 
case, it may be disclosed to all parties to the case and to their attorneys and by the latter 
to their legal associates and employees. However, the grand iury testimony afforded 
such persons by the court can only be used in the defense or prosecution o(the civil or 
criminal case and for no other purpose whatsoever. 
Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable 
to comply with any court order granting disclosure of the requested documents because neither Mr. 
Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession, 
custody, or control of the 2006 Epstein grand jury records. 
Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter, 
the enclosed Motion for Attorney's Fees will be filed and we will seek as sanctions, from your client 
and your firm, recovery of the...

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
I 
-----.,....------------
CASE NO.: 19-CA-014681 
DEFENDANT, DA VE ARONBERG'S MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57. I 05, 
to award him reasonable attorneys' fees for the defense of Plaintiffs First Amended Complaint, 
(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, together with a letter from the undersigned attorney, in accordance with 
subsection ( 4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior 
to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish that the Complaint is without support of the facts or the law. 
WHEREFORE, Defendant, DA VE ARONBERG, as State Attorney of Palm Beach 
County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiffs 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 

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CERTIFICATE OF SERVICE 
I hereby certify that on this __ day ___ , 2020, the foregoing was electronically filed 
via the Florida E-File Portal for electronic service on the parties of record herein. 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esquire 
Fla. Bar No.: 108249 
Richard J. Scholz, Esquire 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esquire 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 
j acobsscho lzlaw@comcast.net 
Attorneys for Defendant 

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EXHIBIT ''B'' 
EXHIBIT ''B'' 

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IJ GreenbergTraurig 
Stephen A. Mendelsohn 
Tel 561.955.7629 
Fax 561.659.9119 
mendelsohns@gtlaw.com 
June 23, 2020 
Douglas A. Wyler 
Jacob Scholz & Wyler, LLC 
961687 Gateway Blvd. 
Suite 201-I 
Fernandina Beach, FL 32034 
Re: 
CA Florida Holdings, LLC v. Dave Aron berg et al. 
Case No. 2019-CA-014681 
Dear Mr. Wyler: 
We are in receipt of your letter of June 8, 2020withyourproposedFla. Stat. section 57.105 motion. 
fu your letter and your proposed motion, you asse1i that CA Florida Holdings, LLC and the law 
furn of Greenberg Traurig, P.A. should be liable for the attorneys' fees to be incurred by State 
Attorney Aronberg after the date of your letter. Your letter cites to Fla. Stat. sections 57.105(1) 
(a) and (b) for suppo1i. As shown below, there is no basis for a Fla. Stat. section 57.105 motion, 
and we expect that if the State Attorney were to make such a motion, the court should deny it. 
Your letter omits a citation to section 57.105(3). Subsection 57.105(3)(a) provides that sanctions 
may not be awarded where there is a "good faith argument for the extension, modification or 
reversal of existing law or the establishment of new law, as it is applied to the material facts, with 
a reasonable expectation of success." We have such a good faith argument. 
Contrary to your analysis of Fla. Stat. section 905.27, there are actually three instances where a 
court may order the release of grand jury materials. As we argue, the court may order release "in 
furtherance of justice." There are few cases in Florida reviewing this provision and its scope. It is 
an open and valid question as to whether the comi may order release of grand jury transcripts to 
the media, under both the statute and the First Amendment to the US Constitution in fmiherance 
of justice. The statutory language you cite refers to instances where a person is seeking grand jury 
materials for use in a civil or in a criminal case. fu these limited situations, the statute all...

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C01Tespondence to Douglas A Wyler 
June 23, 2020 
Page2 
use limitation you cite applies. No reported Florida case has addressed this issue and there is a 
good faith basis for our view of Fla. Stat. section 905.27 
Your letter also argues that sanctions are applicable because the State Attorney has alleged that it 
does not possess the Jeffrey Epstein grand jury transcripts. This allegation is also contained in the 
State Attorney's Answer. Assuming that the State Attorney does not cunently have physical 
possession of the Epstein grand jury materials, which has yet to be demonstrated, this does not end 
the matter. The State Attorney was named as a party not simply as a custodian of grand jury 
records. The State Attorney was named in his official capacity as his office has "as its primary 
interest the protection of its grand jury system." [Italics in original.] In re Grand Jury Proceedings, 
832 F. 3d 554, 559 (11 th Circuit 1987). In that case, the US petitioned a state judge to order the 
State Attorney to turn over grand jury transcripts. The State Attorney argued against their release 
citing to Fla. Stat. section 905.27. Later, a federal grand jmy subpoenaed the Broward County 
State Attorney for delivery of state grand jury testimony. The Broward State Attorney advised the 
federal court that it would produce the transcripts, thereby demonstrating that while it may not 
have physical possession of the materials, he had legal authority to obtain and deliver them. It 
should also be noted that the State Attorney moved to quash the subpoena arguing that it was 
unlawful under Florida law and Fla. Stat. section 905. 2 7. This case indicates that where one seeks 
grand jury materials, the relevant State Attorney is a necessa1y patty in order to protect the grand 
jmy that the Office of State Attorney supervised and to make arguments, if need be, against release 
of the grand jury materials. These are some of the same reasons why the State A...

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C01Tespondence to Douglas A Wyler 
June 23, 2020 
Page3 
For these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed 
against the Office of the State Attorney. We expect that your demand will be withdrawn. 
Thank you, 
Very truly yours, 
ls/Stephen Mendelsohn 
Stephen Mendelsohn 
SAM:ls 
ACTIVE 51081659v1 
Greenberg Tramig, P.A. I Attm-nevs at Law 
www.gllaw.com 

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EXHIBIT ''C'' 
EXHIBIT ''C'' 

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
CASE NO.: 19-CA-014681 
DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57 .105, 
to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint, 
( the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, together with a letter from the undersigned attorney, in accordance with 
subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior 
to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish that the Complaint is without support of the facts or the law. 
WHEREFORE, Defendant, DA VE ARONBERG, as State Attorney of Palm Beach 
County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 

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CERTIFICATE OF SERVICE 
I hereby certify that on this 1st day July, 2020, the foregoing was electronically filed via 
the Florida E-File Portal for electronic service on the parties of record herein. 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esquire 
Fla. Bar No.: 108249 
Richard J. Scholz, Esquire 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esquire 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 
j ac obsscholzla w@comcast.net 
Attorneys for Defendant, Dave Aronberg 

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EXHIBIT ''D'' 
EXHIBIT ''D'' 

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Filing# 115383434 E-Fil_ed 10/21/2020 04: 13:35 PM 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, ·as Clerk and Comptroller of Palm 
Beach County, Florida, 
Defendants. 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 50-2019-CA-014681-XXXX-MB 
DIVISION; AG 
PLAINTIFF CA HOLDINGS, LLC'S 
NOTICE OF DROPPING ST A TE ATTORNEY, DA VE ARONBERG 
Plaintiff, CA HOLDINGS, LLC, pursuant to Fla. R. Civ. P. 1250(b), hereby notifies the parties that 
it has dropped State Attorney, Dave Aronberg from the above case. 
Respectfu I ly submitted, 
GREENBERG TRAURIG, P.A. 
Attorneys for CA Florida Holdings, LLC, Publisher 
of The Palm Beach Post 
Stephen A. Mendelsohn, Esq. 
40 I East Las Olas Boulevard Suite 2000 
Boca Raton, Florida 33486 
Telephone: (561) 955-7629 
Facsimile: (561) 338-7099 
By: !.,I Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 
mende I soh ns@gt law .com 
smith I( i"vbrtl aw .corn 
FLServ icc(dl gt law .com 

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By: Isl Michael J Grygiel 
MICHAEL J GRYGIEL 
(Admitted Pro Hae Vice) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400 
Facsimile: (518) 689-1499 
grvgielm@gtlaw.com 
By: Isl Nina D. Boyaiian 
NINA D. BOY AJIAN 
(Admitted Pro Hae Vice) 
1840 Century Park East, Suite 1900 
Los Angeles California 90067 
Telephone: (310) 586-7700 
Facsimile: (310) 586-7800 
bovaj iann@gtlaw.com 
ri veraali'it)gt law .com 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 2151 day of October, 2020, a true and correct copy of the 
foregoing has been filed with the Clerk of the Court usihg the State of Florida e-filing system, which 
wi 11 send a notice of electronic service for al I parties of record herein 
ACTIVE 53317341v1 
Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
2 

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EXHIBIT ''E'' 
EXHIBIT ''E'' 

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Jacobs Scholz & Wyler, LLC 
961687 Gateway Blvd., Suite 2011 
Fernandina Beach, FL 32034 
United States 
904-261 -3693 
Dave Aronberg 
Jacobs Scholz & Wyler, LLC 
Balance 
Invoice# 
$32,440.00 
00307 
Invoice Date 
November 6, 2020 
Payment Terms 
Due Date 
Aronberg (SA015) adv. CA Florida Holdings, LLC 
Time Entries 
Date 
EE 
Activity 
Description 
Rate 
Hours 
Line Total 
11/26/2019 
DW 
Review 
Initial review of summons and complaint. 
$425.00 
1.5 
$637.50 
11/26/2019 
DW 
Review 
Reviewed motion for pro hac vice and Judge 
Hafele' order granting 
$425.00 
0.2 
$85.00 
11/26/2019 
DW 
Teleconference 
Teleconference w/ Client, re: response to lawsuit 
$425.00 
0.5 
$212.50 
11/26/2019 
DW 
Draft 
Drafted engagement letter and sent to client 
$425.00 
0.3 
$127.50 
11/26/2019 
DW 
Review 
Reviewed 15th circuit local rules 
$425.00 
1.0 
$425.00 
11/26/2019 
AIJ 
Review 
Initial review of complaint 
$475.00 
1.0 
$475.00 
11/26/2019 
AIJ 
Meeting 
Meeting w/ DAW to discuss lawsuit and strategy 
$475.00 
0.5 
$237.50 
11/26/2019 
DW 
Meeting 
Meeting w/ AIJ to discuss lawsuit and strategy 
$425.00 
0.5 
$212.50 
11/26/2019 
AIJ 
Teleconference 
Teleconference w/ Client, re: response to lawsuit 
$475.00 
0.5 
$237.50 
12/02/2019 
DW 
Research & 
Preparation 
Research and prep tor Motion to dismiss 
$425.00 
2.0 
$850.00 
12/02/2019 
DW 
Draft 
1st Draft motion to dismiss 
$425.00 
1.0 
$425.00 
12/02/2019 
DW 
Teleconference 
Teleconference w/ Client, re: draft motion to 
$425.00 
0.5 
$212.50 
dismiss 
12/02/2019 
AIJ 
Review 
Reviewed 1st Draft MTDismiss 
$475.00 
0.3 
$142.50 
12/02/2019 
AIJ 
Teleconference 
Teleconference w/ client, re: draft motion to 
$475.00 
0.5 
$237.50 
dismiss 
12/03/2019 
AIJ 
Meeting 
Meeting w/ DAW, re: motion to dismiss 
$475.00 
0.2 
$95.00 
12/03/2019 
DW 
Meeting 
Meeting w/ AIJ, re: MTDismiss 
$425.00 
0.2 
$85.00 
12/06/2019 
DW 
Draft 
Completed final draft of motion to dismiss; filed with 
Court 
$425.00 
...

NOT A CERTIFIED COPY
12/06/2019 
DW 
Teleconference 
Spoke with Clerk's attorney, re: response 
$425.00 
0.5 
$212.50 
12/06/2019 
AIJ 
Review 
Reviewed final draft MTDisrniss 
$475.00 
0.2 
$95.00 
12/06/2019 
AIJ 
Review 
Reviewed Clerk's MTDisrniss 
$475.00 
0.2 
$95.00 
12/13/2019 
DW 
Review 
Reviewed Clerk's Motion to Dismiss 
$425.00 
0.5 
$212.50 
01/16/2020 
DW 
Review 
Reviewed Order Setting Hearing on Defendants' 
MTDisrniss 
$425.00 
0.1 
$42.50 
01/16/2020 
DW 
Review 
Reviewed motion for pro hac vice 
$425.00 
0.1 
$42.50 
01/17/2020 
DW 
Review 
Reviewed Pl's Amended Complaint 
$425.00 
1.0 
$425.00 
01/17/2020 
DW 
Teleconference 
Spoke with client, re: Amended Complaint 
$425.00 
0.5 
$212.50 
01/17/2020 
DW 
Review 
Reviewed Pl's notice of filing 
$425.00 
0.1 
$42.50 
01/20/2020 
AIJ 
Review 
Reviewed Pl's Am. Compl 
$475.00 
0.3 
$142.50 
01/21/2020 
DW 
Review 
Reviewed Judge Marx's Order Cancelling 
MTDisrniss Hearing 
$425.00 
0.1 
$42.50 
01/21/2020 
DW 
Review 
Reviewed Pl's Objection to Defendants' MTDisrniss 
$425.00 
0.2 
$85.00 
01/21/2020 
DW 
Teleconference 
Spoke with client, re: Amended complaint 
$425.00 
0.5 
$212.50 
01/21/2020 
AIJ 
Meeting 
Meeting w/ DAW, re: response to Am. Cornpl. 
$475.00 
0.2 
$95.00 
01/21/2020 
DW 
Meeting 
Meeting w/ AIJ, re: response to Am. Compl. 
$425.00 
0.2 
$85.00 
01/22/2020 
DW 
Review 
Reviewed Order granting pro hac vice admission 
$425.00 
0.1 
$42.50 
01/22/2020 
DW 
Research & Draft 
Researched and drafted response to Amended 
Complaint 
$425.00 
1.0 
$425.00 
01/23/2020 
DW 
Teleconference 
Spoke with Clerk's attorney, re: response to 
amended complaint 
$425.00 
0.2 
$85.00 
01/24/2020 
DW 
Various 
Completed Answer/MTDismiss Amended 
$425.00 
1.0 
$425.00 
Complaint; filed with Court; sent copy to Client 
01/24/2020 
DW 
Draft 
Drafted and filed Notice of Unavailability 
$425.00 
0.4 
$170.00 
01/24/2020 
AIJ 
Review 
Reviewed final Answer/MTDismiss 
$475.00 
0.2 
$95.00 
01/27/2020 
DW 
...

NOT A CERTIFIED COPY
04/21/2020 
DW 
Review 
Reviewed order rescheduling hearing on Defs' 
MTDismiss 
$425.00 
0.1 
$42.50 
04/21/2020 
DW 
Teleconference 
Spoke w/ client, re: order rescheduling MTDismiss 
hearing for June 3, 2020 
$425.00 
0.3 
$127.50 
04/21/2020 
AIJ 
Review 
Reviewed Order rescheduling MTDismiss hearing 
$475.00 
0.1 
$47.50 
05/22/2020 
DW 
Review 
Reviewed order setting Zoom hearing, re: 
MTDismiss 
$425.00 
0.1 
$42.50 
05/22/2020 
DW 
Teleconference 
Spoke w/ client, re: hearing will be via Zoom 
$425.00 
0.2 
$85.00 
05/27/2020 
DW 
Review 
Reviewed Clerk's filing: change of atty of record 
$425.00 
0.1 
$42.50 
05/27/2020 
DW 
Teleconference 
Spoke with Clerk's new counsel, Nicole Fingerhut 
$425.00 
0.2 
$85.00 
05/28/2020 
DW 
E-mail 
Reviewed Pl's email, re: cases and authorities for 
MTDismiss hearing; responded 
$425.00 
0.1 
$42.50 
05/29/2020 
DW 
Preparation 
Began oral argument prep for 6/8 MTDismiss 
hearing 
$425.00 
1.0 
$425.00 
06/01/2020 
DW 
E-mail 
Reviewed email from Judge Marx's JA and 
responded 
$425.00 
0.1 
$42.50 
06/02/2020 
DW 
Various 
Reviewed Pl's 500+ page binder, re: MTDismiss & 
prepped for hearing 
$425.00 
3.0 
$1,275.00 
06/02/2020 
DW 
E-mail 
Drafted and sent email to client, re: MTD hearing 
tomorrow 
$425.00 
0.1 
$42.50 
06/03/2020 
DW 
Attend Hearing 
Prepped for and attended MTDismiss hearing via 
Zoom 
$425.00 
1.5 
$637.50 
06/03/2020 
DW 
Teleconference 
Spoke w/ Client, re: debrief MTDismiss hearing 
$425.00 
0.5 
$212.50 
06/03/2020 
DW 
E-mail 
Emailed courtesy copies of Aronberg's Answer and 
MTDismiss to Judge Marx 
$425.00 
0.1 
$42.50 
06/03/2020 
DW 
E-mail 
Reviewed response from Client and replied 
$425.00 
0.1 
$42.50 
06/03/2020 
AIJ 
Attend Hearing 
Attended MTDismiss hearing via Zoom 
$475.00 
1.0 
$475.00 
06/03/2020 
AIJ 
Review 
Reviewed order granting MTDismiss w/ prejudice 
$475.00 
0.3 
$142.50 
06/08/2020 
DW 
Review 
Reviewed Court's Order Granting Defendants 
MTDismiss Co...

NOT A CERTIFIED COPY
06/23/2020 
DW 
E-mail 
Sent client copy of Pl's letter refusing to dismiss 
$425.00 
0.1 
$42.50 
complaint 
06/23/2020 
AIJ 
Review 
Reviewed Pl's letter refusing 10 dismiss Count I/Am. 
$475.00 
0.1 
$47.50 
Compl. 
Spoke w/ client, re: filing of 57.105 motion for 
07/01/2020 
DW 
Various 
fees/sanctions; filed motion for attorneys' fees 
based on Pl's failure to volun1arily dismiss 
$425.00 
0.5 
$212.50 
amended complaint count 1 
07/02/2020 
DW 
E-mail 
Email 10 client, re: affidavit and summary judgment 
$425.00 
0.1 
$42.50 
07/08/2020 
DW 
Teleconference 
Discussed w/ Client drafting and filing Mo1ion for 
$425.00 
0.7 
$297.50 
Summary Judgment and MSJ evidence 
07/08/2020 
AIJ 
Teleconference 
Discussed w/ Client drafting and filing Mo1ion for 
$475.00 
0.7 
$332.50 
Summary Judgment and MSJ evidence 
07/10/2020 
DW 
Draft 
Created 1st draft of Aronberg Affidavi1; shared w/ 
client 
$425.00 
1.0 
$425.00 
07/10/2020 
AIJ 
Various 
Reviewed draft affidavit and discussed w/ DAW 
$475.00 
0.3 
$142.50 
07/10/2020 
DW 
Meeting 
Discussed draft affidavit w/ AIJ 
$425.00 
0.2 
$85.00 
07/13/2020 
DW 
Review 
Reviewed Pl's Request 10 Produce, re: Clerk 
$425.00 
0.1 
$42.50 
07/13/2020 
DW 
Teleconference 
Spoke w/ Clerk's counsel, re: Request 10 Produce 
$425.00 
0.2 
$85.00 
07/27/2020 
DW 
Review 
Reviewed Pl's Amended Request 10 Produce, re: 
Clerk 
$425.00 
0.1 
$42.50 
07/27/2020 
DW 
Teleconference 
Spoke w/ Clerk's counsel, re: Amended Request 10 
Produce 
$425.00 
0.1 
$42.50 
07/28/2020 
DW 
Draft 
Revised Aronberg affidavit 
$425.00 
0.5 
$212.50 
07/29/2020 
DW 
Draft 
Finalized Aronberg Affidavi1 and sent 10 client 
$425.00 
0.5 
$212.50 
07/29/2020 
DW 
Research & 
Research and prep for Mo1ion for Summary 
$425.00 
1.0 
$425.00 
Prepara1ion 
Judgment 
07/30/2020 
DW 
Various 
Received executed Aronberg Affidavi1 
$425.00 
0.1 
$42.50 
07/30/2020 
DW 
Draft 
Began drafting Motion for Summary Judgment 
$425.00 
2.0 
$850.00 
08/0...

NOT A CERTIFIED COPY
09/02/2020 
AIJ 
Meeting 
Discussed w/ DAW phone call w/ Pl's counsel 
$475.00 
0.2 
$95.00 
09/02/2020 
DW 
Meeting 
Discussed w/ AIJ phone call w/ Pl's counsel 
$425.00 
0.2 
$85.00 
Reviewed email from Pl's counsel requested 
09/16/2020 
DW 
E-mail 
Aronberg to withdraw sanctions motion w/o 
$425.00 
0.1 
$42.50 
prejudice 
09/17/2020 
DW 
Meeting 
Discussed w/ AIJ filing motion tor CMG 
$425.00 
0.1 
$42.50 
09/17/2020 
AIJ 
Meeting 
Discussed w/ DAW tiling motion for CMG 
$475.00 
0.1 
$47.50 
09/18/2020 
DW 
Various 
Drafted and filed motion to set case management 
conference; re: MSJ 1st or Fee hearing 1st 
$425.00 
0.5 
$212.50 
Responded to Pl's 9/16/20 email and refused to 
09/18/2020 
DW 
E-mail 
withdraw 57.105 motion; provided copy of motion to 
$425.00 
0.1 
$42.50 
set CMG and available dates tor hearing 
09/18/2020 
DW 
E-mail 
Reviewed Pl's email insisting that 57.105 motion be 
withdrawn 
$425.00 
0.1 
$42.50 
Replied to Pl's counsel that the 57 .105 motion for 
09/18/2020 
DW 
E-mail 
sanctions will not be withdrawn and asking for 
$425.00 
0.1 
$42.50 
response, re: CMG 
09/18/2020 
DW 
E-mail 
Sent client copy of email exchange w/ Pl's counsel; 
called and spoke w/ Client 
$425.00 
0.5 
$212.50 
09/22/2020 
DW 
Various 
Drafted and filed Notice of Hearing on 10/15/20; set 
$425.00 
0.7 
$297.50 
up Court Call; spoke w/ client, re: hearing date 
10/02/2020 
DW 
Review 
Reviewed Pl's Memo of Law opposing Aronberg's 
57.105 motion tor fees/sanctions 
$425.00 
0.7 
$297.50 
10/02/2020 
DW 
Review 
Reviewed Pl's Response to Aronberg's request to 
schedule 57 .1 05 motion tor fees after MSJ 
$425.00 
0.5 
$212.50 
10/02/2020 
AIJ 
Review 
Reviewed Pl's Memo of Law opposing 57.105 
$475.00 
0.5 
$237.50 
motion 
10/02/2020 
AIJ 
Review 
Reviewed Pl's Response to Aronberg's request to 
$475.00 
0.4 
$190.00 
schedule 57.105 motion after MSJ 
10/12/2020 
DW 
Research 
Research caselaw & statutes, re: response to Pl's 
Memo of Law 
$4...

NOT A CERTIFIED COPY
10/15/2020 
DW 
Telephone 
Spoke w/ Pl's counsel, re: settlement 
$425.00 
0.1 
$42.50 
10/15/2020 
DW 
Telephone 
Spoke w/ client, re: Pl's settlement proposal 
$425.00 
0.2 
$85.00 
10/15/2020 
AIJ 
Various 
Attended hearing, re: motion to set CMG; 
$475.00 
1.0 
$475.00 
discussed w/ client 
10/15/2020 
AIJ 
Various 
Discussed Pl's settlement proposal w/ DAW and 
$475.00 
0.4 
$190.00 
then w/ Client 
10/15/2020 
DW 
Meeting 
Discussed Pl's settlement proposal w/ AIJ 
$425.00 
0.2 
$85.00 
10/16/2020 
DW 
Various 
Drafted and shared proposed order w/ Pl's counsel 
$425.00 
0.5 
$212.50 
10/16/2020 
DW 
Telephone 
Spoke w/ Pl's counsel, re: settlement 
$425.00 
0.2 
$85.00 
10/16/2020 
DW 
Telephone 
Spoke w/ client, re: Pl's settlement proposal 
$425.00 
0.5 
$212.50 
10/16/2020 
DW 
Meeting 
Discussed Pl's settlement proposal w/ AIJ 
$425.00 
0.2 
$85.00 
10/16/2020 
AIJ 
Meeting 
Discussed Pl's settlement proposal w/ DAW 
$475.00 
0.2 
$95.00 
10/19/2020 
DW 
Various 
Uploaded proposed order, re: CMG tor Judge 
Hafele 
$425.00 
0.1 
$42.50 
10/19/2020 
DW 
Telephone 
Spoke w/ client, re: Pl's settlement proposal 
$425.00 
0.2 
$85.00 
10/19/2020 
DW 
Telephone 
Spoke w/ Pl's counsel, re: settlement 
$425.00 
0.1 
$42.50 
10/19/2020 
AIJ 
Meeting 
Discussed Pl's settlement proposal w/ DAW 
$475.00 
0.2 
$95.00 
10/19/2020 
DW 
Meeting 
Discussed Pl's settlement proposal w/ AIJ 
$425.00 
0.2 
$85.00 
10/20/2020 
DW 
Various 
Reviewed email from Pl, re: settlement; sent copy 
to Client and called to discuss 
$425.00 
0.5 
$212.50 
10/20/2020 
DW 
Telephone 
Spoke w/ client, re: settlement 
$425.00 
0.4 
$170.00 
10/20/2020 
DW 
Telephone 
Spoke w/ Pl's counsel, re: settlement 
$425.00 
0.1 
$42.50 
10/20/2020 
DW 
Telephone 
Spoke w/ client, re: settlement 
$425.00 
0.1 
$42.50 
10/20/2020 
DW 
Meeting 
Discussed Pl's settlement proposal w/ AIJ 
$425.00 
0.2 
$85.00 
10/20/2020 
AIJ 
Meeting 
Discussed Pl's settlement proposal w/ DAW 
$475.00 ...

NOT A CERTIFIED COPY
Reviewed Pl's Notice of Dropping Aronberg as 
10/22/2020 
AIJ 
Various 
party; spoke w/ Client and DAW, re: notice and next 
steps 
$475.00 
0.5 
$237.50 
Totals: 
74.8 
$32,440.00 
Time Entry Sub-Total: 
Sub-Total: 
Total: 
Amount Paid: 
Balance Due: 
$32,440.00 
$32,440.00 
$32,440.00 
$0.00 
$32,440.00 

NOT A CERTIFIED COPY
EXHIBIT ''F'' 
EXHIBIT ''F'' 

NOT A CERTIFIED COPY
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
V. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
I 
---------------
CASE NO.: 19-CA-014681 
AFFIDAVIT OF ATTORNEYS' FEES 
ST A TE OF FLORIDA 
COUNTY OF NASSAU 
BEFORE ME, the undersigned authority appeared Douglas A. Wyler, Esq., who, after 
being first duly sworn, deposes and says: 
I. 
Affiant is a partner of JACOBS, SCHOLZ & WYLER, LLC, counsel for 
Defendant, DAVE ARON BERG, as State Attorney of Palm Beach County, Florida, C'Aronberg"), 
as well as general counsel to the Florida Prosecuting Attorneys Association, ("FPAA"), and makes 
this Affidavit of his own personal knowledge. 
2. 
Affiant is licensed to practice law in the State of Florida, is an active member of 
the Florida Bar in good standing and has engaged in the practice oflaw in the State of Florida since 
2015. 
3. 
As detailed herein, the services rendered by Affiant and his firm pertain to Affiant' s 
demand letter and motion for attorneys' fees sent to Plaintiff's counsel pursuant to § 57.105, 
Florida Statutes, on June 8, 2020, in defending against Count I of Plaintiffs Amended Complaint 

NOT A CERTIFIED COPY
and Plaintiffs October 21, 2020 Notice of Dropping State Attorney, Dave Aronberg from the 
above-captioned lawsuit. See, Exhibits "A" and "B" attached hereto. 
4. 
The total time Affiant's law firm has expended services rendered to date is 74.8 
hours, however, from the date of Defendant Aronberg's 57.105 demand, Affiant's law firm has 
expended a total of 42.2 hours. Of the 42.2 hours expended since Defendant Aron berg's 57.105 
demand was served, the Affiant 
5. 
Of the 42.2 hours expended since Defendant Aronberg's 57.105 demand was 
served, the total time Affiant has expended services rendered to date is 35.4 hours at the rate of 
$425.00 per hour. Likewise, the total time Affiant's law partner, Arthur I. Jacobs, has expended 
services rendered to date is 6.8 hours at the rate of $475.00 per hour. 
6. 
Accordingly, since Defendant Aronberg·s 57.105 demand was served, Defendant 
Aronberg's counsel, JACOBS, SCHOLZ & WYLER, LLC, has rendered services in the amount 
of$ I 8,275.00, in conjunction with the defense of the instant action pursuant to§ 57.105, Florida 
Statutes. See, Exhibit "C" attached hereto. 
7. 
A ffiant expects to incur an additional 4.0 hours at $425.00 an hour in preparing for 
and attending the hearing on attorneys' fees. Thus, the total amount of hourly attorneys' fees the 
State Attorney is seeking is 46.2 hours for a total of $19,975.00. Additionally, the State Attorney 
seeks a multiplier of 2.0, which when applied makes the grand total attorneys· fees sought herein 
$39,950.00. 
Dated this 9th day of November, 2020. 
FURTHER AFFIANT SA YETH NOT. 
Douglas 

NOT A CERTIFIED COPY
STATE OF FLORIDA 
COUNTY OF NASSAU 
The foregoing instrument was acknowledged before me this 9th day of November, 2020, 
s A.. Wyler, Esquire, who is personally known to me and who did take an oath. 
Name typed, printed or stamped 
_....;,:;;i,:v•~ 
TAIUN R JACKSON 
tl~ .\ NotJry Public· StJte of Florid, 
\ \Wj.'i 
Com mi51iion # GG 3 5,. ! .. 1 
......... ~-~--/ My Comm. Expires Aus 17. 2023 
Bond~ thr OIJSh N ationa I i'lotary A.1.1n. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on this 9th day of November, 2020, a copy of the foregoing has 
been electronically filed with the Florida E-File Portal fore-service on all parties of record herein. 
JACOBS SCHOLZ & WYLER, LLC 
Is/ Douglas A. Wyler 
Arthur I. Jacobs, Esq. 
Fla. Bar No.: I 0249 
Richard J. Scholz. Esq. 
Fla. Bar No.: 0021261 
Douglas A. Wyler, Esq. 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-1 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 Fax 
Primary: jacobsscho lzla w@comcast.net 
Attorneys/or Defendant, Dave Aronberg 

NOT A CERTIFIED COPY
EXHIBIT "A" 
EXHIBIT "A" 

NOT A CERTIFIED COPY
Friday, September 18, 2020 at 11:09:24 Eastern Daylight Time 
Subject: 
SERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLOR I DA HOLDINGS, LLC V. 
DAVE ARON BERG ET AL 
Date: 
From: 
Monday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time 
Douglas Wyler 
To: 
'm ende lsoh ns@gtlaw.com ', sm ithl@gtlaw.co m, flservice@gtlaw.co m, Boyajia n N@gtlaw.com, 
rive raa l@gtlaw.com, G RYG IE LM@gtlaw.com 
Attachments: 2020-06-08 Aronberg 57.105 Demand and Motion for Attorneys' Fees.pdf 
Court: 
Case No: 
Plaintiff: 
Defendant: 
Title of Documents 
Served: 
Sender's Name and 
Telephone Number: 
Sincerely, 
Doug Wyler, Esq. 
Circuit Court of the Fifteenth Judicia I Circuit, in and for Pa Im Beach County, 
Flori~a 
Case.No. 2020-CA-014681 
CA Florida Holdings, LLC 
Dave Aron berg 
• 
Fla. Stat.§ 57.105 Demand Letter 
• Defendant, Dave Aronberg's Motion for Attorneys' Fees 
Douglas Wyler 
{904) 261-3693 
Jacobs, Scholz & Wyler, LLC 
961687 Gateway Blvd., STE 201-l 
Fernandina Beach, FL 32034 
904-261-3693 
904-261-7879 (fax) 
-------
Please be advised that this e-mail and any files transmitted with it are confidential attorney-client 
communication or may otherwise be privileged or confidential and are intended solely for the individual or 
entity to whom they are addressed. If you are not the intended recipient, please do not read, copy or 
retransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or 
copying of thls communication is strictly prohibited. 
Page loft 

NOT A CERTIFIED COPY
JACOBS SCHOLZ & WYLER, LLC. 
A LIMITED t..lABlllTY COMPANY OF PROFESS!ONAl ASSOCIATIONS 
ATTORNEYS AT LAW 
THE: LAW OFF1CES OF 
GATEWAY TO AMELIA 
A~THIJ~ J_ JACOE:IS 
961687 GATEWAY SI.VD., SUITE 201·1 
FERNA..-..DIN.A BEA.CB, FLORIDA 32034 
June 8, 2020 
VIA ELECTRONIC & U.S. MAIL 
Stephen A. Mendelsohn, Esq. 
Greenburg Traurig, P.A. 
5100 Town Center Circle, Suite 400 
Boca Raton, FL 33486 
TELEPHONE (904) 261-3693 
,AX NO. (904) 261-7879 
RE: 
CA Florida Holdings, LLC ,,_ Dave Aronberg et al. 
Palm Beach County, Case No.: 2019-CA-014681 
Dear Mr. Mendelsohn: 
RICHAROJ, SCHOlZ, P.A. 
'"CHARD J. SCHDlZ 
DDUGL,'\S A. WYlER, P.A. 
DOW GLAS A. WVL.E~ 
As you are aware our finn represents the interests of Dave Aron berg, as State Attorney of Palm Beach 
County, Florida, in the above referenced matter. The purpose of this letter is to demand the voluntary 
dismissal of your First Amended Complaint, (the "Complaint"), dated January 17, 2020. This demand 
is made pursuant to section 57.105, Florida Statutes. 
As you know, Section 57 .105 provides: 
( I ) Upon the court's initiative or motion of any party, the court shal I award a 
reasonable attorney's fee, including prejudgment interest, to be paid to the 
prevailing party in equal amounts by the losing party and the losing party"s attorney 
on any claim or defense at any time during a civil proceeding or action in which 
the court finds that the losing party or the losing party"s attorney knew or should 
have known that a claim or defense when initially presented to the court or at any 
time before trial; 
a. ' Was not supported by the material facts necessary to establish the claim or 
defense; or 
b. Would not be supported by the application of then-existing law to those 
material facts. 
Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count II of the 
Plaintiffs Complaint. Pursuant to the Court's ruling, the Plaintiffs only remaining cause of action 
consists of...

NOT A CERTIFIED COPY
First and foremost, the Complaint is not supported by the material facts necessary to establish the 
claims asserted because neither Defendant Aron berg, nor The Office of the State Attorney for the 
Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein. 
Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are 
impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to 
this action because no matter what, he and his office do not have possession, custody, or control of the 
requested materials. 
In ·addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims 
are also not supported by the application of current law. Specifically, your action for declaratory relief 
fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes, 
which states: 
• 
When such disclosure is ordered by a court pursuant to subsection (I} for use in a civil 
case, it may be disclosed to all parties to the case and to their attorneys and by the latter 
to their legal associates and employees. However, the grand fury testimony afforded 
such persons by the court can only be used in the defense or prosecution o(the civil or 
criminal case and for no other purpose whatsoever. 
Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable 
to comply with any court order granting disclosure of the requested documents because neither Mr. 
Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession, 
custody, or control of the 2006 Epstein grand jury records. 
Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter, 
the enclosed Motion for Attorney's Fees will be filed and we will seek as sanctions, from your client 
and your firm, recovery of...

NOT A CERTIFIED COPY
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CA FLORIDA HOLDINGS, LLC, 
Publisher of the PALM BEACH POST, 
Plaintiff, 
v. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptroller of Palm 
Beach County, Florida. 
Defendants. 
I 
------,--..-----------
CASE NO.: 19-CA-014681 
DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES 
Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and 
through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105, 
to award him reasonable attorneys' fees for the defense of Plaintiffs First Amended Complaint, 
(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served 
a copy of this Motion, together with a letter from the undersigned attorney, in accordance with 
subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior 
to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which 
establish that the Complaint is without support of the facts or the law. 
WHEREFORE, Defendant, DA VE ARONBERG, as State Attorney of Palm Beach 
County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's 
attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion. 

NOT A CERTIFIED COPY
CERTIFICATE OF SERVICE 
I hereby certify that on this __ day __ 
__, 2020, the foregoing was electronically filed 
via the Florida E-File Portal for electronic service on the parties of record herein. 
JACOBS SCHOLZ & WYLER, LLC 
Isl Douglas A. Wyler 
Arthur I. Jacobs, Esquire 
Fla. Bar No.: 108249 
Richard J. Scholz, Esquire 
Fla. Bar No.: 0021261 
Douglas A Wyler, Esquire 
Fla. Bar No.: 119979 
961687 Gateway Blvd., Suite 201-I 
Fernandina Beach, Florida 32034 
(904) 261-3693 
(904) 261-7879 
j acobsscholzlaw@comcast.net 
Attorneys for Defendant 

NOT A CERTIFIED COPY
EXHIBIT "B" 
EXHIBIT "B'' 

NOT A CERTIFIED COPY
Filing If 115383434 E-Filed 10/_21/2020 04: 13:35 PM 
CA FLORIDA HOLDINGS, LLC, 
Publisher of THE PALM BEACH POST, 
Plaintiff, 
v. 
DA VE ARONBERG, as State Attorney of 
Palm Beach County, Florida; SHARON R. 
BOCK, as Clerk and Comptro I [er of Palm 
Beach County, Florida, 
Defendants. 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE N 0.: 50-20 I 9-CA-0 14681-XXXX-MB 
DIVISION: AG 
PLAINTIFF CA HOLDINGS, LLC'S 
NOTICE OF DROPPING ST ATE ATTORNEY, DA VE ARONBERG 
Plaintiff, CA HOLDINGS, LLC, pursuant to Fla. R. Civ. P. 1250(b), hereby notifies the part'ies that 
it has dropped State Attorney, Dave Aron berg from the above case. 
Respectfully submitted, 
GREENBERG TRAURIG, P.A. 
Allorneysfor CA Florida Holdings, LLC. Publisher 
of The Palm Beach Po.\'t 
Stephen A. Mendelsohn. Esq. 
40 I East Las Olas Boulevard Suite 2000 
Boca Raton, Florida 33486 
Telephone: (561) 955-7629 
Facsimile: (561) 338-7099 
By: Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
Florida Bar No. 849324 
men de I sohns'iil gtlaw. com 
smith 11,,~agtla ,,., .com 
F LServ icer,i'1 gt la,..,· .com 

NOT A CERTIFIED COPY
By: /s/ Michael J Grygiel 
MICHAEL J GRYGIEL 
(Admitted Pro Hae Vice) 
54 State St., 6th Floor 
Albany, New York 12207 
Telephone: (518) 689-1400-
Facsimile: (518) 689-1499 
grvgielmirugtlaw .com 
By: /s/ Nina D. Boyaiian 
NINA D. BOYAJIAN 
(Admitted Pro Hae Vice) 
1840 Century Park East, Suite 1900 
Los Angeles California 90067 
Telephone: (310) 586-7700 
Facsimile: (3 IO) 586-7800 
bovai ian nui)gtla w .com 
ri veraa!@.gt law .com 
CERTIFICATE OF SERVICE 
l HEREBY CERTIFY that on this 21 st day of October, 2020, a true and correct copy of the 
foregoing has been filed with the Clerk of the Court using the State of Florida e-fi I ing system, which 
will send a notice of electronic service for a 11 parties of record herein 
ACTIVE 53317341v1 
Isl Stephen A. Mendelsohn 
STEPHEN A. MENDELSOHN 
2 

NOT A CERTIFIED COPY
EXHIBIT "C" 
EXHIBIT ''C" 

NOT A CERTIFIED COPY
Jacobs Scholz & Wyler, LLC 
961687 Gateway Blvd., Suite 2011 
·Fernandina Beach, FL 32034 
United States 
Jacobs Scholz & Wyler, LLC 
904-261-3693 
Dave Aronberg 
Balance 
Invoice# 
Invoice Date 
Payment Terms 
Due Date 
Aronberg (SA015) adv. CA Florida Holdings, LLC 
Time Entries 
Date 
EE 
Activity 
Description 
Rate 
11126/2019 
DW 
Review 
Initial review of summons and complaint. 
$425.00 
1112612019 
DW 
Review 
Reviewed motion for pro hac vice and Judge 
$425.00 
Hafele' order granting 
11/26/2019 
ow 
Teleconference 
Teleconference w/ Client, re: response to lawsuit 
$425.00 
11/26/2019 
ow 
Draft 
Drafted engagement letter and sent to client 
$425.00 
11/26/2019 
ow 
Review 
Reviewed 15th circuit local rules 
$425.00 
11/2612019 
AIJ 
Review 
Initial review of complaint 
$475.00 
11/26/2019 
AIJ 
Meeting 
Meeting w/ DAW to discuss lawsuit and strategy 
$475.00 
11/2612019 
DW 
Meeting 
Meeting w/ AIJ to discuss lawsuit and strategy 
$425.00 
11/2612019 
AIJ 
Teleconference 
Teleconference wl Client, re: response to lawsuit 
$475.00 
12/02/2019 
ow 
Research & 
Preparation 
Research and prep for Motion to dismiss 
$425.00 
12/0212019 
ow 
Draft 
1st Draft motion to dismiss 
$425.00 
12/02/2019 
ow 
Teleconference 
Teleconference w/ Client, re: draft motion to 
$425.00 
dismiss 
12/0212019 
AIJ 
Review 
Reviewed 1st Draft MTOismiss 
$475.00 
12/0212019 
AIJ 
Teleconference 
Teleconference w/ client, re: draft motion to 
$475.00 
dismiss 
1210312019 
AIJ 
Meeting 
Meeting wl DAW, re: motion to dismiss 
$475.00 
12103/2019 
DW 
Meeting 
Meeting w/ AlJ, re: MTOismiss 
$425.00 
12/06/2019 
ow 
Draft 
Completed final draft of motion to dismiss: filed with 
$425.00 
Court 
12/06/2019 
ow 
Teleconference 
Spoke w/ client, re: fin_al draft of motion to dismiss 
$425.00 
$32,440.00 
00307 
November 6, 2020 
Hours 
Line Total 
1.5 
$637.50 
0.2 
$85.00 
0.5 
$212.50 
0.3 
$127.50 
1.0 
$425.00 
1.0 
$475.00 
0.5 
$237.50 
0.5 
$212.50 
0.5 
$237.50 ...

NOT A CERTIFIED COPY
12/06/2019 
ow 
Teleconference 
Spoke with Clerk's attorney, re: response 
$425.00 
0.5 
$212.50 
12/06/2019 
AIJ 
Review 
Reviewed final draft MTDismiss 
$475.00 
0.2 
$95.00 
12/0612019 
AIJ 
Review 
Reviewed Clerk's MTDismiss 
$475.00 
0.2 
$95.00 
12/13/2019 
ow 
Review 
Reviewed Clerk's Motion to Dismiss 
$425.00 
0.5 
$212.50 
01116/2020 
ow 
Review 
Reviewed Order Setting Hearing on Defendants' 
MTDismiss 
$425.00 
0.1 
$42.50 
01/16/2020 
ow 
Review 
Reviewed motion for pro hac vice 
$425.00 
0.1 
$42.50 
01/17/2020 
ow 
Review 
Reviewed Pl's Amended Complaint 
$425.00 
1.0 
$425.00 
01/17/2020 
ow 
Teleconference 
Spoke with client, re: Amended Complaint 
$425.00 
0.5 
$212.50 
01/17/2020 
ow 
Review 
Reviewed Pl's notice of filing 
$425.00 
0.1 
$42.50 
01/20/2020 
AIJ 
Review 
Reviewed Pl's Am. Campi 
$475.00 
0.3 
$142.50 
01/21/2020 
ow 
Review 
Reviewed Judge Marx's Order Cancelling 
$425.00 
0.1 
$42.50 
MTDismiss Hearing 
01/21/2020 
ow 
Review 
Reviewed Pl's Objection lo Defendants' MTDismiss 
$425.00 
0.2 
$85.00 
01/2112020 
ow 
Teleconference 
Spoke with client, re: Amended complaint 
$425_,00 
0.5 
$212.50 
01/21/2020 
AIJ 
Meeting 
Meeting w/ DAW, re: response to Am. Campi. 
$475.00 
0.2 
$95.00 
01/21/2020 
ow 
Meeting 
Meeting wl AIJ, re: response to Am. Campi. 
$425.00 
0.2 
$85.00 
01122/2020 
ow 
Review 
Reviewed Order granting pro hac vice admission 
$425.00 
0.1 
$42.50 
01/22/2020 
ow 
Research & Draft 
Researched and drafted response to Amended 
$425.00 
1.0 
$425.00 
Complaint 
01/23/2020 
ow 
Teleconference 
Spoke with Clerk's attorney, re: response to 
amended complaint 
$425.00 
0.2 
$85,00 
01/2412020 
ow 
Various 
Completed Answer/MTDismiss Amended 
$425.00 
1.0 
$425.00 
Complaint; filed with Court: sent copy to Client 
01/2412020 
ow 
Draft 
Drafted and filed Notice of Unavailability 
$425.00 
0.4 
$170.00 
01/24/2020 
AIJ 
Review 
Reviewed final Answer/MTDismiss 
$475.00 
0.2 
$95.00 
01/27/2020 
ow 
Revie...

NOT A CERTIFIED COPY
04/2112020 
ow 
Review 
Reviewed order rescheduling hearing on Defs' 
$425.00 
MTOismiss 
0.1 
$42.50 
04/21/2020 
ow 
Teleconference 
Spoke w/ client, re: order rescheduling MT□ismiss 
$425.00 
0.3 
$127.50 
hearing for June 3, 2020 
04/21/2020 
AIJ 
Review 
Reviewed Order rescheduling MT□ismiss hearing 
$475.00 
0.1 
$47.50 
05122/2020 
ow 
Review 
Reviewed order setting Zoom hearing, re: 
$425.00 
0.1 
$42.50 
MTDismiss 
05/22/2020 
ow 
Teleconference 
Spoke wl client, re: hearing will be via Zoom 
$425.00 
0.2 
$85.00 
• 05/27/2020 
ow 
Review 
Reviewed Clerk's filing: change of atty of record 
$425.00 
0.1 
$42.50 
05/2712020 
ow 
Teleconference 
Spoke with Clerk's new counsel, Nicole Fingerhut 
$425.00 
0.2 
$85.00 
05/2812020 
ow 
E-mail 
Reviewed Pi's email, re: cases and authorities tor 
$425.00 
0.1 
$42.50 
MTDismiss hearing; responded 
05129/2020 
ow 
Preparation 
Began oral argument prep for 6/8 MTOismiss 
$425.00 
1.0 
$425.00 
hearing 
06101/2020 
OW 
E-mail 
Reviewed email from Judge Marx"s JA and 
responded 
$425.00 
0.1 
$42.50 
06102/2020 
ow 
Various 
Reviewed Pl"s 500+ page binder, re: MTDismiss & 
$425.00 
3.0 
$1,275.00 
prepped for hearing 
0610212020 
ow 
E-mail 
Drafted and sent email to client, re: MT□ hearing 
tomorrow 
$425.00 
0.1 
$42.50 
06/0312020 
ow 
Attend Hearing 
Prepped tor and attended MTDismiss hearing via 
Zoom 
$425.00 
1.5 
$637.50 
06103/2020 
ow 
Teleconference 
Spoke wl Client, re: debrief MT□ismiss hearing 
$425.00 
0.5 
$212.50 
06103/2020 
ow 
E-mail 
Emailed courtesy copies of Aronberg"s Answer and 
$425.00 
0.1 
$42.50 
MT□ismiss to Judge Marx 
06103/2020 
DW 
E-mail 
Reviewed response from Client and replied 
$425.00 
0.1 
$42.50 
06103/2020 
AIJ 
Attend Hearing 
Attended MTDismiss hearing via Zoom 
$475.00 
1.0 
$475.00 
06103/2020 
AIJ 
Review 
Reviewed order granting MT □ismiss wl prejudice 
$475.00 
0.3 
$142.50 
0610812020 
ow 
Review 
Reviewed Court's Order Granting Defendants 
$425.00 
...

NOT A CERTIFIED COPY
06/23/2020 
DW 
E-mail 
Sent client copy of Pl's letter refusing to dismiss 
$425.00 
complaint 
0.1 
$42.50 
06/23/2020 
AIJ 
Review 
Reviewed Pl's letter refusing to dismiss Count I/Am. 
$475.00 
0.1 
$47.50 
Campi. 
Spoke w/ client, re: filing of 57.105 motion for 
07/01/2020 
ow 
Various 
fees/sanctions; filed motion for attorneys' fees 
based on Pl's failure to voluntarily dismiss 
$425.00 
0.5 
$212.50 
amended complaint count 1 
07102/2020 
ow 
E-mail 
Email to client, re: affidavit and summary judgment 
$425.00 
0.1 
$42.50 
07/08/2020 
ow 
Teleconference 
Discussed w/ Client drafting and filing Motion for 
$425.00 
0.7 
$297.50 
Summary Judgment and MSJ evidence 
07/08/2020 
AJJ 
Teleconference 
Discussed w/ Client drafting and filing Motion for 
$475.00 
0.7 
$332.50 
Summary Judgment and MSJ evidence 
07/10/2020 
ow 
Draft 
Created 1st draft of Aronberg Affidavit; shared wl 
client 
$425.00 
1.0 
$425.00 
07/10/2020 
AIJ 
Various 
Reviewed draft affidavit and discussed w/ DAW 
$475.00 
0.3 
$142.50 
07110/2020 
ow 
Meeting 
Discussed draft affidavit wl AIJ 
$425.00 
0.2 
$85.00 
0711312020 
ow 
Review 
Reviewed PJ's Request to Produce, re: Clerk 
$425.00 
0.1 
$42.50 
07/13/2020 
ow 
Teleconference 
Spoke w/ Clerk's counsel, re: Request to Produce 
$425.00 
0.2 
$85.00 
0712712020 
ow 
Review 
Reviewed Pl's Amended Request to Produce, re: 
Clerk 
$425,00 
0.1 
$42.50 
07/27/2020 
ow 
Teleconference 
Spoke wt Clerk's counsel, re: Amended Request to 
Produce 
$425.00 
0.1 
$42.50 
07128/2020 
ow 
Draft 
Revised Aronberg affidavit 
$425.00 
0.5 
$212.50 
07/29/2020 
ow 
Draft 
Finalized Aronberg Affidavit and sent to client 
$425.00 
0.5 
$212.50 
07/29/2020 
ow 
Research & 
Research and prep for Motion for Summary 
$425.00 
1.0 
$425.00 
Preparation 
Judgment 
07/30/2020 
ow 
Various 
Received executed Aronberg Affidavit 
$425.00 
0.1 
$42.50 
07/3012020 
ow 
Draft 
Began drafting Motion for Summary Judgment 
$425.00 
2.0 
$850.00 
08/0...

NOT A CERTIFIED COPY
09/02/2020 
AIJ 
Meeting 
Discussed wl DAW phone call w/ Pl's counsel 
$475.00 
0.2 
$95.00 
09/02/2020 
ow 
Meeting 
Discussed w/ AIJ phone call wl Pl's counsel 
$425.00 
0.2 
$85.00 
Reviewed email from Pl's counsel requested 
09/16/2020 
ow 
E-mail 
Aronberg to withdraw sanctions motion w/o 
$425.00 
0.1 
$42.50 
prejudice 
09/17/2020 
ow 
Meeting 
Discussed wl AIJ filing motion for CMC 
$425.00 
0.1 
$42.50 
09/17/2020 
AIJ 
Meeting 
Discussed w/ DAW filing motion for CMG 
$475.00 
0.1 
$47.50 
09/18/2020 
ow 
Various 
Drafted and filed motion to set case management 
$425.00 
0.5 
$212.50 
conference; re: MSJ 1st or Fee hearing 1st 
Responded to PJ's 9/16/20 email and refused to 
09/1812020 
ow 
E-mail 
withdraw 57.105 motion; provided copy of motion to 
$425.00 
0.1 
$42.50 
set CMG and available dates for hearing 
09/1812020 
ow 
E-mail 
Reviewed Pl's emai! insisting that 57.105 motion be 
withdrawn 
$425.00 
0.1 
$42.50 
Replied to P!"s counsel that the 57 .105 motion for 
09/18/2020 
ow 
E-mail 
sanctions will not be withdrawn and asking for 
$425.00 
0.1 
$42.50 
response, re: CMG 
09/18/2020 
ow 
E-mail 
Sent client copy of email exchange w/ Pl's counsel; 
called and spoke wl Client 
$425.00 
0.5 
$212.50 
09/22/2020 
ow 
Various 
Drafted and filed Notice of Hearing on 10115/20; set 
$425.00 
0.7 
$297.50 
up Court Call; spoke w/ client, re: hearing dale 
10/02/2020 
ow 
Review 
Reviewed Pl's Memo of Law opposing Aronberg's 
57.105 motion for fees/sanctions 
$425.00 
0.7 
$297.50 
10/02/2020 
ow 
Review 
Reviewed Pl's Response to Aronberg's request to 
$425.00 
0.5 
$212.50 
schedule 57 .105 motion for fees after MSJ 
10/02/2020 
AIJ 
Review 
Reviewed Pl's Memo of Law opposing 57 .1 05 
motion 
$475.00 
0.5 
$237.50 
10/02/2020 
AIJ 
Review 
Reviewed Pl's Response to Aronberg's request to 
schedule 57.105 motion after MSJ 
$475.00 
0.4 
$190.00 
10/12/2020 
ow 
Research 
Research caselaw & statutes, re: response to Pl's 
Memo of Law 
$...

NOT A CERTIFIED COPY
10/15/2020 
ow 
Telephone 
Spoke wf Pl's counsel, re: settlement 
$425.00 
0.1 
$42.50 
10/1512020 
ow 
Telephone 
Spoke wl client, re: Pl's settlement proposal 
$425.00 
0.2 
$85.00 
10115/2020 
AIJ 
Various 
Attended hearing, re: motion to set CMC; 
$475.00 
1.0 
$475.00 
discussed wl client 
1011512020 
AIJ 
Various 
Discussed Pl's settlement proposal wl DAW and 
$475.00 
0.4 
$190.00 
then wl Client 
10/15/2020 
ow 
Meeting 
Discussed Pl's settlement proposal w/ AIJ 
$425.00 
0.2 
$85.00 
10116/2020 
ow 
Various 
Draftee and shared proposed order w/ Pl's cour1se/ 
$425.00 
0.5 
$212.50 
10/16/2020 
ow 
Telephone 
Spoke w/ Pl's counsel, re: settlement 
$425.00 
0.2 
$85.00 
10/16/2020 
ow 
Telephone 
Spoke w/ clier1t, re: Pl's settlement proposal 
$425.00 
0.5 
$212.50 
10/16/2020 
ow 
Meeting 
Discussed Pi's settlement proposal w/ AIJ 
$425.00 
0.2 
$85.00 
10/16/2020 
AIJ 
Meeting 
Discussed Pl's settlement proposal w/ DAW 
$475.00 
0.2 
$95.00 
10/19/2020 
ow 
Various 
Uploaded proposed order, re: CMG for Judge 
$425.00 
0.1 
$42.50 
Hafele 
10/1912020 
ow 
Telephone 
Spoke w/ client, re: Pl's settlement proposal 
$425.00 
0.2 
$85.00 
10/19/2020 
ow 
Telephone 
Spoke wl Pl's counsel, re: settlement 
$425.00 
0.1 
$42.50 
10f1912020 
AIJ 
Meeting 
Discussed Pl's settlement proposal w/ DAW 
$475.00 
0.2 
$95.00 
10/19/2020 
ow 
Meeting 
Discussed Pl's settlement proposal w/ AIJ 
$425.00 
0.2 
$85.00 
10/20/2020 
ow 
Various 
Reviewed email from Pl, re: settlement; sent copy 
$425.00 
0.5 
$2t2.50 
to Client and called to discuss 
10120/2020 
ow 
Telephone 
Spoke w/ client, re: settlement 
$425.00 
0.4 
$170.00 
10/20/2020 
ow 
Telephone 
Spoke w/ Pl's counsel, re: settlement 
$425.00 
0.1 
$42.50 
10120/2020 
ow 
Telephone 
Spoke w/ client, re: settlement 
$425.00 
0.1 
$42.50 
10/20/2020 
ow 
Meeting 
Discussed Pl's settlement proposal wl AIJ 
$425.00 
0.2 
$85.00 
10/20/2020 
AIJ 
Meeting 
Discussec Pl's settlement proposal w/ DAW 
$475.0...

NOT A CERTIFIED COPY
Reviewed Pl's Notice of Dropping Aronberg as 
10/22/2020 
AlJ 
Various 
party; spoke wl Client and DAW, re: notice and next 
steps 
$475.00 
0.5 
Totals: 
74.8 
Time Entry Sub-Total: 
Sub-Total: 
Total: 
Amount Paid: 
Balance Due: 
$237.50 
$32,440.00 
$32,440.00 
$32,440.00 
$32,440.00 
$0.00 
$32,440.00 

NOT A CERTIFIED COPY
EXHIBIT ''G'' 
EXHIBIT ''G'' 

NOT A CERTIFIED COPY
JACOBS SCHOLZ & WYLER, LLC. 
THE I.AW Of'Tlci;S Of' 
JAC:0155 ,_ ASSOC:11' Tf;s. P.A. 
--,HUR I . .JACO!llS 
November 26, 2019 
Office of the State Attorney 
I 5th Judicial Circuit 
Attn: 
Jeanne Howard 
A LIMITEQ Ll-"JiliUTY C:OMPANY OF P~FESSIO•V,L ASS0C:'AT10N$ 
ATTORNO'S AT I.AW 
GATEWAY TO ""'411:LlA 
$1$168? GATEWAY BLVD., SUITE: 11!:0l•I 
FERNANDINA BEA.c:n, F'LoRmA 32004 
TELE:PHONE C904) 1i!:6l-3693 
FAX NO. {9()4) 281.?879 
401 North Dixie Highway 
West Palm Beach, FL 33401 
Re: 
CA Florid.a Holdings, LLC v. Dave Aronberg et al. 
Case No.: 2019-CA-014681 
Dear Mrs. Howard: 
RIC:H1'RO J. SCHOL%, P.A. 
Ille ..,._RO .J. $C!-f01..l 
OOUGI..A$ A. W'l'Llt!t, P.A. 
DOUGt..AS "· WV~EA 
The purpose of this letter is to confirm that Jacobs Scholz & Wyler, LLC will represent you regarding the 
above-referenced matter. 
Our fees will be contingent upon our success in this matter. You will not be liable or required to pay any 
monies to our office unless we are successful in our representation of you regarding the above-referenced 
litigation and receive a court order awarding attorneys' fees. 
Accordingly, should we be successful in this matter, you agree to be billed for the time incurred in defending 
this action at our current hourly rates. At this time, our current hourly rates are: $475.00/hour for senior 
partners, $425.00/hour for other partners, $37S.00/hour for associate attorneys, and $125.00/hour for 
paralegal time. 
Furthcnnore, the attorneys' fees paid to our firm shall be calculated by the above listed hourly rates 
multiplied by the number of hours expended in defending this action or the total fee mandated and awarded 
by the court order herein, whichever is greater. 
By signing below; you agree to the terms as set forth above. Please return a signed and dated copy of this 
letter to our office. If you have any questions or concerns, please contact our office. On behalf of the 
finn, we are proud to represent you in this matter. 
...

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