MEMY-1805 marker2-fixhub court-ca-florida-holdings (pepper 16-core): 422/422

marker2-fixhub/court-ca-florida-holdings/EFTA02732399/EFTA02732399.md

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+## FORM 1.997. CIVIL COVER SHEET
+
+The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner for the use of the Clerk of Court for the purpose of reporting judicial workload data pursuant to section 25.075, Florida Statutes. (See instructions for completion.)
+
+#### I. CASE STYLE
+
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+Case No.:
+
+Judge:
+
+CA Florida Holdings LLC Publisher of PB Post
+
+Plaintiff
+
+vs.
+
+Dave Arenberg as State Attorney of Palm Beach Flo. Sharon R Bock as Cler Defendant mptroller of PB Ctv
+
+#### II. TYPE OF CASE
+
+- O Condominium O Contracts and Indebtedness .L1 Eminent domain Q Auto negligence O Negligence —other O Business governance ❑ Business torts ❑ Environmental/Toxic tort Q Third party indemnification 12 Construction defect O Mass tort ❑ Neg3gent security z O Nursing home negligence ❑ Premises liability — commercial
+  - **Premises liability -residential residential**
+- **0. Products liability El Real Property/Morigage foreclosure O Commercial foreclosure \$0 - \$50,000**  ❑ "Canmercial foreclosure 550,001 - \$249,999 O C14/ .•imerciai foreclosure \$250,000 or more O Homestead residential foreclosure \$0 - 50,000 O Homestead residential foreclosure \$50,001 - \$249,999 ❑ Homestead residential foreclosure \$250,000 or more ❑ Non-homestead residential foreclosure \$0 - \$50,000 ❑ Non-homestead residential foreclosure \$50,001 - \$249,999
+
+O U U U Non-homestead residential foreclosure \$250,00 or more Other real property actions SO - \$50,000 Other real property actions \$50,001 - \$249,999 Other real property actions \$250,000 or more Professional malpractice . Other U ❑ OOI0OIDIDOOlo Malpractice — business Malpractice — medical Malpractice — other professional Antitrust/Trade Regulation Business Transaction Circuit Civil - Not Applicable Constitutional challenge-statute or ordinance Constitutional challenge-proposed amendment Corporate Trusts Discrimination-employment or Other Insurance claims Intellectual property Ubel/Slander Shareholder derivative action Securities litigation Trade secrets Trust litigation
+
+## COMPLEX BUSINESS COURT
+
+This action is appropriate for assignment to Complex Business Court as delineated and mandated by the Administrative Order. Yes ❑ No
+
+## III. REMEDIES SOUGHT (check all that apply):
+
+O Monetary; Non-monetary declaratory or injunctive relief; O Punitive
+
+# IV. NUMBER OF CAUSES OF ACTION: ( )
+
+(Specify)
+
+I - Fla. Section 905.27(1)(c)
+
+## V. IS THIS CASE A CLASS ACTION LAWSUIT?
+
+- Cl Yes
+- No
+
+#### VI. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?
+
+E No O Yes — If "yes" list all related cases by name, case number and court:
+
+## VII. IS JURY TRIAL DEMANDED IN COMPLAINT?
+
+O Yes O No
+
+I CERTIFY that the information I have provii O4fi this cover sheet is accurate to the best of my knowledge and belief, and that I have read and will comply withpth requirements of Florida Rule of Judicial Administration 2.425.
+
+Signature s/ Stephen A. M elsoh FL Bar No.: 849324 Attorney or pa (Bar number, if attorney)
+
+Ste hen A ohn 11/14/2019 &win name) Date

marker2-fixhub/court-ca-florida-holdings/EFTA02732399/EFTA02732399.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732401/EFTA02732401.md

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+IN THE CIRCUIT COURT, 15th JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.:
+
+CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST
+
+Plaintig
+
+v .
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, SHARON IL BOCK, as Clerk and Comptroller of Palm Beach County, Florida,
+
+Defendants.
+
+Dave Aronber Attorney of Palm Beach • rida 401 N. D. West P , Florida 33401
+
+A Cos
+
+A lawsuit has been led againt you. You have 20 calendar days after this summons is served on you to file n response to the attached Complaint with the Clerk of this Court. A pho• call not protect you. Your written response, including the case number giv d the names of the parties, must be filed if you want the Court to hear yo o e case. If you do not file your response on time, you may lose the case, wages, money, and property may thereafter be taken without further wa the Court. There are other legal requirements. You may want to call an a ght away. If you do not know an attorney, you may call an attorney referral serve 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.
+
+## 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 Nov 15 2019
+
+## IMPORTANTE
+
+Sharon R. Bock As Clerk & Comptroller of the Court
+
+![](_page_1_Picture_4.jpeg)
+
+By:
+
+Deputy e NUI' GARCIA
+
+listed ha sido demandado legalmente. Tiene 20 Dias, contados fgarbbedi recibo de esta notification, para contester la demanda adjunta, por escrito, y presentarla an\* este qibunal. Una Hamada tcicfonica no lo protegera. Si usted desca que cl tribunal considere su defensa, debipresentar su respuesta por escrito, incluyendo el numero del caso y los nombres de las part ntcresadas. Si usted no contesta la demanda a tiempo, pudiese perder cl caso y podria set despojado e S9c ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existcn otros tar os\ égales. Si lo dama, pucdc tasted consulter a un abogado inmediatamente. Si no conte a un 91M pjledc !lamer a una de las officines de asistencia legal que aparecen en la guis telefonies.
+
+Si desca responder a la demanda por su cue a s tiempo en que prescnta su respuesta ante cl tribunal, dcbcra ustcd envier por corrco o entr ar c is dc su respuesta a la persona denominada abajo como "Plaintiff/Plaintiffs Attorney" (Dc te o bogado del Demandante).
+
+Des poursuites judiciarcs de la date de l'assignation de tribunal. Un simple coup de te votre rcponsc ecrite, avec mention numcro de dossier ci-dessus et du nom des parties nommccs ici, si vous souhaitez que le tri entende votre cause. Si vous ne deposez pas votre reponse ecrite dans le relai requis, vous risquez re la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre saisis par la suite s suc prcavis ultcricur du tribunal. Il y a d'autres obligations juridiques et vous pouvez roque rvices immediats d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez telephoner q.4n Jvie e reference d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de telephones rases contre vous. Vous avez 20 jours consccutifs a partir ur deposer une reponse ecrite a la plainte ci-jointe aupres de ce est insuffisant pour vous proteger. Vous des oblige de deposer
+
+us choisissez de deposer vous-meme une reponse ecrite, il vous faudra egalement, en meme temps tac cette formalite, faire parvenir ou cxpcdier une copie de votre reponse ecrite au "Plainti laintiffs Attorney" (Plaignant ou a son avocat) nomme ci-dessous.

marker2-fixhub/court-ca-florida-holdings/EFTA02732401/EFTA02732401.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732403/EFTA02732403.md

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+IN THE CIRCUIT COURT, 15th JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.:
+
+CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST
+
+Plaintig
+
+v .
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, SHARON It BOCK, as Clerk and Comptroller of Palm Beach County, Florida,
+
+Defendants.
+
+DEFENDANT: Sharon R. Boc As Clerk an Of Palm 205 N Wes er ty, Florida way h, Florida 33401 A Cos
+
+## <94
+
+A lawsuit has been mst you. You have 20 calendar days after this summons is served on you file wntten response to the attached Complaint with the Clerk of this Court. A p call .11 not protect you. Your written response, including the case number ' e and the names of the parties, must be filed if you want the Court to hear yo o the case. If you do not file your response on time, you may lose the case, wages, money, and property may thereafter be taken without further m the Court. There are other legal requirements. You may want to call an attoit,y 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.
+
+## 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 aboye named Defendant.
+
+DATED on November , 2019 NO, 15 2019 9
+
+![](_page_1_Picture_3.jpeg)
+
+I NI PO ETA NT
+
+Sharon R. Bock As Clerk & Comptroller of the Court
+
+By:
+
+BOU"
+
+![](_page_1_Picture_9.jpeg)
+
+Usted ha sido demandado legalmente. Ticnc 20 Dias, contados t recibo de esta notificacion, para contestar la demanda adjunta, por escrito, y presentarla an e este tfibunal. Una llamada tclefonica no lo protegera. Si usted desea que cl tribunal considere su defensa, debe/presentar su respuesta por escrito, incluyendo el numero del caso y los nombres de las part nteresadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado e ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen otros ui os legales. Si lo desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un de llamar a una de las oficinas de asistencia legal que aparecen en la guia telefonica.
+
+Si desea responder a la demanda por su cue a smo tiempo en que presenta su respuesta ante cl tribunal, dcbcra ustcd enviar por correo o entr ia de su respuesta a la persona denominada abajo como "Plaintiff/Plaintiffis Attorney" (De te o bogado del Demandante).
+
+Des poursuitcs judiciares de la date de l'assignation de tribunal. Un simple coup de te votrc repone ecrite, aves mcntion W numero de dossier ci-dcssus ct du nom des partics nommccs ici, si vous souhaitcz que le tri entende votre cause. Si vous nc deposez pas votre reponse ecrite dans le relai requis, vous risquez re la cause ainsi que votrc salairc, votre argcnt, et vos bien peuvent etrc saisis par la suite s auc prcavis ultcricur du tribunal. II y a d'autrcs obligations juridiques ct vous pouvez reqUe rvices immediats d'un avocat. Si vous ne connaissez pu d'avocat, vous pourriez telephoner e reference d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de tclephones mes contre vous. Vous avez 20 jours consccutifs a partir ur deponer une repone ecrite a la plaintc ci-jointe aupres de ce est insuffisant pour vous proteger. Vous eles obligo de dcposer
+
+us choisissez de deponer vous-meme une reponse ecrite, il vous faudra egalement, en meme temps uc cette formalite, fairc parvenir ou expedia une copie de votrc reponse ecrite au "Plainti laintiff's Attomey" (Plaignant ou a son avocat) nomme ci-dessous.

marker2-fixhub/court-ca-florida-holdings/EFTA02732403/EFTA02732403.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732405/EFTA02732405.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732495/EFTA02732495.md

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+![](_page_0_Picture_0.jpeg)
+
+## SHARON R. BOCK
+
+CLERK & COMPTROLLER PALM BEACH COUNTY, FLORIDA
+
+## RECEIPT
+
+
+
+Printed On: 11/15/2019 09:38 Page 1 of 1
+
+| **Receipt Number: 3417823 - Date 11/15/2019 Time 9:38AM** |  |  |  |
+| ----------------------------------------------------------------------------------------- | ---------------- | --------------------------------------------------------------------------------- | ---------------------- |
+| **Received of:** | | Greenberg Traurig
+Greenberg Traurig
+333 S.E. 2d Avenue
+Miami, FL 33131 | |
+| **Cashier Name:** |  | ADMIN |  |
+| **Cashier Location:** |  | E-Filing |  |
+| **Receipt ID:** |  | 9712663 |  |
+| **Division:** |  | AG: Circuit Civil Central - AG(Civil) |  |
+| **Case# 50-2019-CA-014681-XXXX-MB -- PLAINTIFF/PETITIONER: CA FLORIDA HOLDINGS LLC** |  |  |  |
+| **PUBLISHER OF PB POST** |  |  |  |
+| **Item** | **Balance** | **Paid** | **Bal Remaining** |
+| Fees | 421.00 | 421.00 | 0.00 |
+| **Case Total** | **421.00** | **421.00** | **0.00** |
+| **Payments** |  |  |  |
+| **Type** | **Ref#** | **Amount** |  |
+| EFiling_CREDITCARD | 26405260 |  | 421.00 |
+| **Total Received** |  |  | **421.00** |
+| **Total Paid** |  |  | **421.00** |
+
+How was your service today? Please visit www.mypalmbeachclerk.com/survey or send your feedback to clerkweb@mypalmbeachclerk.com.
+
+For office locations and information about Clerk & Comptroller services: Visit www.mypalmbeachclerk.com or call (561) 355-2996.

marker2-fixhub/court-ca-florida-holdings/EFTA02732495/EFTA02732495.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732496/EFTA02732496.md

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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 Palm Beach County, Florida,
+
+Defendants.
+
+CASE NO.: 50-2019-CA-014681-XXXX-MB AG
+
+C~
+
+#### VERIFIED MOTION FOR ADMISSION TO APPEAR PRO MC VICE PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510
+
+COMES NOW Michael Grygiel, Mo t herein, and respectfully represents the following:
+
+- 1. Movant resides in Sara , State of New York.
+- 2. Movant is an attorney and a Shareholder of the law firm of Greenberg Traurig, LLP, with offices at 54 State Street, 6th Floor, Albany, New York 12207, telephone number (518) 689- 1406.
+- 3. vant has been retained personally or as a member of the above-named law firm on or abo t , 2019, by plaintiff CA Florida Holdings, LLC, publisher of the Palm Beach P s egal representation in connection with matters related to the above-styled action now pen ing before the above-named court of the State of Florida.
+- 4. Movant is an active member in good standing and currently eligible to practice law in the following jurisdiction(s):
+
+| Court | Bar Number | Admitted |
+| ----------------------------- | ------------ | ----------- |
+| State of New York | 2291821 | 8/28/1989 |
+| District of Columbia | 423070 | 3/7/1990 |
+| State of Vermont | 3154 | 4/8/1996 |
+| United States Supreme Court | 309705 | 5/13/2019 |
+
+5. There have been no disciplinary, suspension, disbarment, or contempt proceedings initiated against Movant in the preceding 5 years.
+
+6. Movant, either by resignation, withdrawal, or otherwise, nev attempted to terminate Movant's office as an attorney in order to avoid alit disbarment, or suspension proceedings. errainated or e, disciplinary,
+
+7. Movant is not an active member of The Florida
+
+8. Movant is not now {sup}`a`member of The F
+
+9. Movant is not a suspended mem o {sup}`e`Florida Bar.
+
+10. Movant is not adisbarred mt o {sup}`e`Florida Bar nor has Movant received {sup}`a` disciplinary resignation from The Fl
+
+11. Movant has ny been disciplined or held in contempt by reason of misconduct committed while ed in representation pursuant to Florida Rule of Judicial Administration 2.5 0.
+
+12. fo S has not filed amotion to appear as counsel in Florida state courts during the p
+
+Local counsel of record associated with Movant in this matter is Stephen A. Mendelsohn who is an active member in good standing of The Florida Bar and has offices at Greenberg Traurig, P.A., 51 Town Center Circle, Suite 400, Boca Raton, Florida 33486, telephone number (561) 955-7600.
+
+4
+
+•
+
+14. Movant has read the applicable provisions of Florida Rule of Judicial Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and certifies that this verified motion complies with those rules.
+
+15. Movant agrees to comply with the provisions of the Florida Rules of Professional Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida.
+
+WHEREFORE, Movant respectfully requests permission to appear in this court for this cause only.
+
+DATED this 12{sup}`th` day of November, 2019.
+
+STATE OF NEW YORK )  
+) ss: )  
+COUNTY OF ALBANY )
+
+I, Michael J. Grygiel, do hereby swear or affirm under penalty of perjury that I am the Movant in the above-styled matter; that I have read the foregoing Motion and know the contents thereof, and the contents are true of my own knowledge and belief.
+
+Sworn to before me  
+This 12 day of November, 2019.
+
+AUTUMN [REDACTED]  
+Notary Public, State of New York  
+Qualified in Santa Cruz County  
+No. 01WH6006258  
+Commission Expires Nov. 13, 2019
+
+### CERTIFICATE OF. LOCAL COUNSEL
+
+{sup}`I`hereby consent to be associated as local counsel of record in this cause pursuant to Florida Rule of Judicial Administration 2.510.
+
+DATED November 12, 2019.
+
+Stephen 11. Afendelvalm Stephen A. Mendelsohn Florida Bar Number: 849324 Greenberg Traurig, PA. 5100 Town Center Circle, Suite 400 Boca Raton, FL 33486 Telephone: (561) 955-7600 Facsimile: (561-338-7099 o@gtlaw.com
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on November 12, 2019, a true and correct copy of the foregoing motion was served by mail to PHV Admissions, The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2333 accompanied by payment of the \$250.00 filing fee made payable to The Florida Bar. I also certify that the foregoing was electronically filed with the Clerk of the Court using the Florida Courts E-Filing Portal and is being served by e-mail generated by the EPortal system upon:
+
+/s/ Sionhisit A. /Vandals() MS
+
+Stephen A. Mende °o
+
+ACTIVE 47104867v1
+
+1% /C)
+
+,
+
+S
+
+P
+
+1
+
+I
+
+# SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION, FOURTH DEPARTMENT ROCHESTER, NEW YORK
+
+I, ALAN L. , Deputy Clerk of the Appellate Division of the Supreme Court in the Fourth Judicial Department, State of New York, do hereby certify that
+
+Michael J. Grygiel
+
+was duly admitted to practice a§,a attorney and counselor at law in all courts of this state by this Court on August 28, 1989, and appears in good standing upon the roll of attorneys and counselors, and other records, in this office and has registered with the administrative office of the Courts as required by Judiciary Law §468-a.
+
+![](_page_5_Picture_4.jpeg)
+
+IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of this Court, at the City of Rochester, November 12, 2019
+
+Deputy Clerk of the Court

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marker2-fixhub/court-ca-florida-holdings/EFTA02732502/EFTA02732502.md

@@ -0,0 +1,36 @@
+![](_page_0_Picture_0.jpeg)
+
+## SHARON R. BOCK
+
+CLERK & COMPTROLLER PALM BEACH COUNTY, FLORIDA
+
+## RECEIPT
+
+
+
+Printed On: 11/15/2019 02:15 Page 1 of 1
+
+|  |  | Receipt Number: 3418924 - Date 11/15/2019 Time 2:14PM |  |
+| ------------------- | ------------------------------------------------------ | ------------------------------------------------------- | -------- |
+| Received of: | Greenberg Traurig 333 S.E.2nd Avenue Miami, FL 33131 |  |  |
+| Cashier Name: | ADMIN | Balance Owed: | 100.00 |
+| Cashier Location: | E-Filing | Total Amount Paid: | 100.00 |
+| Receipt ID: | 9713811 | Remaining Balance: | 0.00 |
+| Division: | AG: Circuit Civil Central - AG(Civil) |  |  |
+
+Case# 50-2019-CA-014681-XXXX-MB -- PLAINTIFF/PETITIONER: CA FLORIDA HOLDINGS LLC PUBLISHER OF PB POST
+
+|  | Item | Balance | Paid | Bal Remaining |
+| ------------------- | ------ | --------------- | --------------- | --------------- |
+| Fees |  | 100.00 | 100.00 | 0.00 |
+| **Case Total** |  | **100.00** | **100.00** | **0.00** |
+
+|  |  | Payments |  |  |
+| ----------------------------------- | ---------- | ---------- | -------- | -------- |
+| Type |  | Ref# | Amount |  |
+| EFiling_CREDITCARD Total Received | 26418315 |  |  |  |
+| Total Paid |  |  |  | 100.00 |
+
+How was your service today? Please visit www.mypalmbeachclerk.com/survey or send your feedback to clerkwebmypalmbeachclerk.com.
+
+For office locations and information about Clerk & Comptroller services: Visit www.mypalmbeachclerk.com or call (561) 355-2996.

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marker2-fixhub/court-ca-florida-holdings/EFTA02732503/EFTA02732503.md

@@ -0,0 +1,35 @@
+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
+
+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 Palm  
+Beach County, Florida,
+
+Defendants.
+
+**ORDER GRANTING MOTION TO APPEAR PRO HAC VICE**
+
+**THIS CAUSE** having come before the Court upon the foregoing Verified Motion for Admission to Appear Pro Hac Vice, and the Court being fully advised in the premises,
+
+**IT IS HEREBY ORDERED AND ADJUDGED** that said Motion be and is hereby GRANTED. Michael Grygiel, Esq. is admitted Pro Hac Vice and may represent Plaintiff, CA Florida Holdings, LLC, Publisher of The Palm Beach Post in proceedings before this Court.
+
+**DONE AND ORDERED** in [REDACTED] in Palm Beach County, Florida this 19 day of November, 2019.
+
+Copies furnished to:
+
+Stephen Mendelsohn, Esq., Greenberg Traurig, 5100 Town Center Circle, Suite 400, Boca Raton, Florida  
+33486; [mendelsohns@gtlaw.com](mailto:mendelsohns@gtlaw.com)
+
+NOT A CERTIFIED COPY

marker2-fixhub/court-ca-florida-holdings/EFTA02732503/EFTA02732503.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732505/EFTA02732505.md

@@ -0,0 +1,88 @@
+## 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 IL ) BOCK, as Clerk and Comptroller of Palm ) Beach County, Florida, ) ) Defendants.
+
+CASE NO. 50-2019-CA-014681-XXXX-MB Division: AG
+
+## \*NOTICE OF FILING RETURN OF SERVICE
+
+Plaintiff, CA FLORIDA HOLDINGS, l i isher of The Palm Beach Post ("Plaintiff"), by and through undersigned co ciSt c e attached Return of Service of Summons and Complaint served on Sharon R. Vi t.., as erk and Comptroller of Palm Beach County, Florida on November 18, 2019.
+
+Dated: November 25, 2019
+
+O
+
+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: ft/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 :mendelsoluisOgtlaw.com basenh@gtlaw.cem
+
+-and-
+
+By: *[s/Michael J Grygiel]*  
+MICHAEL J GRYGIEL  
+*(Pro Hac Vice)*  
+54 State St., 6th Floor  
+Albany, New York 12207  
+Telephone: (518) 689-1400  
+Facsimile: (518) 689-1499  
+[grygielm@gtlaw.com](mailto:grygielm@gtlaw.com)
+
+NOTA CERTIFIED COPY
+
+## RETURN OF SERVICE
+
+State of Florida
+
+Case Number: 502019CA014681X)0VMSAG
+
+Plaintiff:
+
+CA FLORIDA HOLDINGS, LLC,
+
+Publisher of THE PALM BEACH POST
+
+vs.
+
+Defendant:
+
+DAVE ARONBERG, as State Attorney of
+
+Palm Beach County, Florida; SHARON R.
+
+BOCK, as Clerk and Comptroller of Palm
+
+Beach County, Florida
+
+For.
+
+Stephen Mendelsohn
+
+Greenberg Traurig, PA.
+
+5100 Town Center Circle
+
+Suite 400
+
+Boca Raton, FL 33486
+
+• Received by Nixon Fleur!mond on the 18th day of November, 2019 at 9:62 am to be served on Sharon R. Bock, As Clerk and Comptroller of Palm Beach County, Florida, 205 N. Dixie Highway, West Palm Beach, FL 33401.
+
+I, Nixon Fleurimond, do hereby affirm that on the 18th da4f November, 2019 at 10:55 am, I:
+
+GOVERNMENT AGENCY: served by delivering a true copy of the Summons, Complaint and Exhibit 1 with the date and hour of service endorsed thereon by me, to: Tara Ramos as Paralegal for Sharon R. Bock, As Clerk and Comptroller of Palm Beach County, Florida, at the address of 205 N. Dixie Highway, West Palm Beach, FL 33401 and Informed said person of the contents therein, in compliance with State Statutes.
+
+M Description of Person Served: Age: 45, Sex: F, Race/Skin Color: = Height: 5.4", Weight: 190, Hair Light . Glasses: Y
+
+Under penalties of perjury, I declare that I have read the foregoing and that the facts stated in it are true. I am over the age of 18, have no Interest in the above action, and am a Certified Process Server, In good standing, in the county In which service was effected in accordance with State Statutes.
+
+County of Palm Beach 15th Circuit Court
+
+04 G
+
+on-Fleurimond rocess Server 1316
+
+Rock Legal Se 8 Investigations Inc 2048 Ponce De Avenue West Palm Beach, FL 33407 (581) 296-7574
+
+Our Job Serial Number: ROC-2019019696 Ref: 127136.025100.
+
+![](_page_2_Picture_28.jpeg)

marker2-fixhub/court-ca-florida-holdings/EFTA02732505/EFTA02732505.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732508/EFTA02732508.md

@@ -0,0 +1,112 @@
+## 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
+
+•
+
+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 Palm ) Beach County, Florida, )
+
+) Defendants. ) A
+
+Cos
+
+## NOTICE OF FILING RETURN CE
+
+Plaintiff, CA FLORIDA HOLDINGS, <t /Sph ("Plaintiff'), by and through undersigned co S143 , s ., e attached Return of Service of Summons and Complaint served on Dave Aron 7 c S Attorney of Palm Beach County, Florida on November 18, 2019. isher of The Palm Beach Post
+
+Dated: Novembei 25, 2019 C
+
+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: is/ Stephen A. Mendelsohn
+
+STEPHEN A. MENDELSOHN Florida Bar No. 849324 mendelsohniagilaw:com Il Snh@gt1P4om ;FtServiceeatlaW.cbm
+
+-and-
+
+By: 18/ Michael J Grvgiel
+
+MICHAEL J GRYGML
+
+(Pro Hac Vice)
+
+54 State St., 6th Floor
+
+Albany, New York 12207
+
+Telephone: (518) 689-1400
+
+Facsimile: (518) 689-1499
+
+grvaiehn@atlaw.com
+
+{sup}`O`C iS 4/) 9 4
+
+**RETURN OF SERVICE**
+
+State of Florida
+
+County of Palm Beach
+
+15th Circuit Court
+
+Case Number: 502019CA014681XXXXMBAG
+
+Plaintiff:
+
+**CA FLORIDA HOLDINGS, LLC,  
+Publisher of THE PALM BEACH POST**
+
+vs.
+
+Defendant:
+
+**DAVE ARONBERG, as State Attorney of  
+Palm Beach County, Florida; SHARON R.  
+BOCK, as Clerk and Comptroller of Palm  
+Beach County, Florida**
+
+For:
+
+Stephen Mendelsohn  
+Greenberg Traurig, P.A.  
+5100 Town Center Circle  
+Suite 400  
+Boca Raton, FL 33486
+
+Received by Rock Legal Services & Investigations Inc on the 18th day of November, 2019 at 9:19 am to be served on Dave Aronberg, as State Attorney of Palm Beach County, Florida, 401 N. Dixie Highway, West Palm Beach, FL 33401.
+
+I, Nixon Fleurimond, do hereby affirm that on the 18th day of November, 2019 at 10:45 am, I:
+
+**GOVERNMENT AGENCY:** served by delivering a true copy of the Summons, Complaint and Exhibit 1 with the date and hour of service endorsed thereon by me, to: Leigh [REDACTED] as Assistant State Attorney for Dave Aronberg, as State Attorney of Palm Beach County, Florida, at the address of 401 N. Dixie Highway, West Palm Beach, FL 33401 and informed said person of the contents therein, in compliance with State Statutes.
+
+**Description of Person Served:** Age: 60, Sex: F, Race/Skin Color: [REDACTED], Height: 5'5", Weight: 140, Hair: Light [REDACTED], Glasses: N
+
+Under penalties of perjury, I declare that I have read the foregoing and that the facts stated in it are true. I am over the age of 18, have no interest in the above action, and am a Certified Process Server, in good standing, in the county in which service was effected in accordance with State Statutes.
+
+Nixon Fleurimond  
+Process Server 1316
+
+**Rock Legal Services & Investigations Inc**  
+2048 Ponce De [REDACTED] Avenue  
+West Palm Beach, FL 33407  
+(561) 296-7574
+
+Our Job Serial Number: ROC-2019019697  
+Ref: 127136.025100.
+
+![](_page_2_Picture_193.jpeg)

marker2-fixhub/court-ca-florida-holdings/EFTA02732508/EFTA02732508.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732511/EFTA02732511.md

@@ -0,0 +1,49 @@
+#### 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. CASE NO.: 19-CA-014681
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON It BOCK, as Clerk and Comptroller of Palm 4164' Beach County, Florida.
+
+Defendants.
+
+# C.) MOTION TO DISMISS
+
+Defendant, DAVE ARONBERG, as State Attorney (4 c a , each County, Florida, by and through the undersigned counsel, hereby files this Motio lit.Nlic i i e Plaintiffs Complaint for failure to state a cause of action, and in support thereof states:
+
+### MOITON T . It t. , i STANDARD
+
+When confronted with a motion,to dismiss; the Court must determine whether the Complaint as phrased within its four corners suffidiently 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 sta a cause of action. The test for a motion to dismiss under Florida Rule of Civil Procedure 1 is ether the pleader could prove any set of facts as alleged in the Complaint to support his o m. \$..tv., Connolly v. Sebeco. Inc 89 So. 2d 482, 484 (Fla. 1956).Wasua Ins. Co. v Ha 2d 1123 (Fla. 4th DCA 1996).
+
+In rder 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 IM v. Cosgrove, 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. R. Civ. P. 1.110(b)). The court need not accept internally inconsistent factual claims, conclusory allegations, unwanuited deductions, or mere legal conclusions made by a party. 14. (citing Response Oncology. Inc.
+
+of action upon which to initiate a valid law suit. Plaintiff attempts to assert a cause of action, in the interest of "furtherin Statute § 905.27; however, a review of the statute in question reveals that for therein and consequently Plaintiff's Complaint must be dismissed A ", under Florida action is provided ter of law. Despite Plaintiff's extensive recitation of the factual background regardi a Epstein and the testimony and evidence presented to the 2006 grand jury in Palm Beach ' o lorida, Fla. Stat. § 905.27, merely explains the exceptions to the disclosure of grand j u \to and does not set forth in any way a cause
+
+Moreover, a review of the statu provided a basis for a cause of act' pertinent part, Fla. Stat. § 905.27( clearly indicates that even if § 905.27, Fla. Stat. is barred from access to the records it seeks. To wit, in
+
+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 factual allegations are accepted as true.... 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 parry. ICislak v. Kreedian, 95 So. 2d 510, 514 (Fla. 1957).
+
+#### COUNT I (Florida Statutes Section 905.27)
+
+When such disclos ered by a court pursuant to subsection (I) for use in a civil case, it may be disci to all parties to the case and to their attorneys and by the latter to their legal associat and employees. However the grand jury testimony afforded such persons th curt can only be used in the defense or prosecution of the civil or crimi Ito and for no other purpose whatsoever.
+
+k spite the clear statutory guidelines for disclosure of grand jury materials in a civil case, Plaintiff is Improperly seeking the requested 2006 grand jury materials for the purposes of public disclosure pursuant to the court's inherent authority and supervisory powers over the grand jury. [See, Complaint ¶' 8, 62]. Again, even if Plaintiff properly asserted a cause of action under Fla. Stat. 905.27, the statute unambiguously states that grand jury testimony "can only be used in the defense or prosecution of the civil or criminal case and for no other purpose whatsoever", which is distinctly different from electronically filed with the Florida E-File Portal for e-service I HEREBY CERTIFY that on this 6th day of December, 2 cl i) copy of the foregoing has been es of record herein.
+
+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, DAVE 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 Defendant Aronberg all other and further relief deemed just and proper, including attorney' an costs for defending this frivolous action.
+
+## CERTIFICATE OF SERVICE
+
+HOLZ & WYLER, LLC
+
+k
+
+% ic Douglas A. Wyler
+
+Arthur I. =, 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-I Fernandina Beach, Florida 32034 (904) 261-3693 (904) 261-7879 Fax Primary: jacobsscholzlaw@comcast.net
+
+General Counsel for the Florida Prosecuting Attorney's Association

marker2-fixhub/court-ca-florida-holdings/EFTA02732511/EFTA02732511.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732514/EFTA02732514.md

@@ -0,0 +1,61 @@
+#### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO: 20I 9CA014681XVOC MB AG
+
+CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST,
+
+Plaintiff,
+
+vs.
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, SHARON R. BOCK, as Clerk & Comptroller, Palm Beach County, Florida,
+
+# Defendants. cis DEFENDANT, SHARON R. BOCK, AS CLERK & COMPTROLLER, PALM BEACH COUNTY'S MOTION TO DISMISS
+
+cos
+
+DEFENDANT, Sharon it Bock, as ''&SOMptroller, Palm Beach County, pursuant to the Florida Rules of Civil Procedure by files this Motion to Dismiss the Complaint of Plaintiff; CA Florida Holdings, isher of The Palm Beach Post, and as grounds states as follows:
+
+## f. AreumenItcZir Standard of Review
+
+#### a. plaintiff Fails to State a Cause of Action
+
+To state a cause of action, a complaint must allege sufficient ultimate facts to show that the pleader is entitled to relief. Florida Rules of Civil Procedure 1.110(b) requires "a short and plain statement of the ultimate facts showing that the pleader is entitled to relief." In reviewing an order granting a motion to dismiss for failure to state a cause of action, the Court must accept as true all well-pled allegations in a complaint, and it must draw all reasonable inferences in favor of the
+
+pleader.
+
+Whether a complaint is sufficient to state a cause of action is an issue of law. W.R. Townsend Contracting, Inc. v. Jensen Civil Construction, Inc., 728 So. 2d 297, 299, (Fla. 1st DCA 1999). When a trial court rules on a motion to dismiss, the trial court is confined to the allegations within the four comers of the Complaint, must accept these allegations as true, and may not speculate as to what the true facts ma nI e or what facts may ultimately be proved in the trial of the cause. See Al-Mv. Holder, 787 So. 2d 939, 941 (Fla. 2d A 2001); Infinite v. Union Cent. Life Ins. Co., 809 So. 2d 13 3d DCA 2002).
+
+The purpose of a motion to dismiss is to determine whether the pla leged a viable cause of action. Hammon v. Buckeye Cellulose Corp., 285 So. 7, 1 a. 1973). In fact, "[d]espite the elemental proposition that on a motion to dismi lure to state a cause of action all allegations are taken as true, [a] court will not `by inf ference or speculations supply essential averments that are lacking.'" v. E ce Corp., 708 So. 2d 997, 1000 (Fla. 3d DCA 1998); see also Conley v. Shuns Stecwe .A., 616 So. 2d 523, 524-25 (Fla. 3d DCA 1993).
+
+Taking the facts alleged state a cause of action against t , and therefore, the Complaint against the Clerk should be dismissed because u der n rc?` e r of facts can the Plaintiff state a cause of action for which relief can be granted. exhibits attached to the Complaint, Plaintiff failed to
+
+0
+
+## COUNT I
+
+(Florida Statutes Section 905.27)
+
+Admittedly, Fla. Stat. § 905.27, sets forth possible exceptions to the disclosure of grand jury testimony. Plaintiff here brings an attempted cause of action under the same statute; however, a review of the statute in question reveals that no cause of action is provided for therein, and therefore, Plaintiff's Complaint must be dismissed as a matter of law.
+
+Moreover, a review of the statute at issue clearly indicates that even if § 905.27, Fla. Stat. provided a basis for an independent cause of action, Plaintiff is barred from access to the records it seeks for the purposes it has set forth as 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 jury testi ny afforded such persons by the court can only be used in the defense or vrosec of the civil or criminal case and for no other purpose whatsoever.
+
+Here, despite the clear statutory guidelines for disclosure of grand ' 'als in a civil case, Plaintiff is improperly seeking the requested 2006 grand jury ateri or the purposes of public disclosure and publication pursuant to the court's inhereic, ority and supervisory powers over the grand jury. Again, even if Plaintiff properlyassertM 905.27, the statute unambiguously states that gran or prosecution of the civil or criminal case an different from Plaintiff's intended pu Stat. & 905.27(2). use of action under Fla. Stat. ony "can only be used in the defense er purpose whatsoever", which is distinctly lic disclosure of the grand jury evidence. Fla. CCONCLUSION
+
+Here, the Cle olvement in this action is as the custodian of the record as set forth in section 28. Fl Statute. This duty includes keeping grand jury records confidential pursuant 905.27, Florida Statute. The Clerk must follow strict statutory guidelines to maintain t e record's confidentiality. Further emphasizing the statutory intent of confidentiality, section 905.395 Florida Statute even imposes a penalty for improper disclosure of grand jury proceedings or identity of persons, at the level of a felony of the third degree.
+
+Plaintiff's Complaint is an 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. However, that recitation fails to state a cause of action for which relief can be granted.
+
+WHEREFORE, based on the foregoing argument and supporting authority, Defendant, Sharon R. Bock, as Clerk & Comptroller, Palm Beach County respectfully prays for the Court to grant this Motion to Dismiss with prejudice, provide direction to the Clerk as needed, and grant such other and further relief as the court deems proper.
+
+#### CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true copy of the foregoing has beermai led in compliance with the Florida Rules of Judicial Administration 2.516, on this 13 day of December, 2019, to: Stephen A. Mendelsohn, Esq., Greenberg Traurig, P.A., 5100 T,d6RltGenter Circle, Suite 400, Boca Raton, FL 33486, email: mendelsohnsagtlaw.com and . Wyler, Esq., 961687 Gateway Blvd., Suite 201-1, Fernandina Beach, FL 32034, e h zl w
+
+Hamp •n, General Counsel For ro ock, Clerk & Comptroller P x 229 d e) one: Beach, FL 33402 el e: (561) 355-2983 ervice: Clerk\_E-service@mypalmbeachclerk.com
+
++6s
+
+'I liair, BY: s/Hampton C. Peterson Florida Bar No. 331384

marker2-fixhub/court-ca-florida-holdings/EFTA02732514/EFTA02732514.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732518/EFTA02732518.md

@@ -0,0 +1,51 @@
+TN THE CIRCUIT COURT 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.
+
+DAVE ARONBERG, SHARON R BOCK, Defendant/Respondents.
+
+## ORDER SETTING HEARING ON DEFENDANT'S MOTION TO DISMISS
+
+THIS CAUSE having come before the Court on Defendant Dave Aronberg's Motion to Dismiss and Defendant Sharon 12 Bock's Motion to Dismiss, and the Court having reviewed the file in the entirety and being otherwise fully advised in the premises, it is
+
+ORDERED that BOTH Defendant's Motion to Dismiss are hereby scheduled for hearing onJanuary 24, 2020 at 10:00 ant in Courtroom 11B of the Main Courthouse, 205 N Dixie Highway, West Palm Beach, Florida 33401. Failure to appear will result in sanctions.
+
+DONE AND ORDERED in West Pa ( {sup}`S` arc- {sup}`e` h Palm Beach County, Florida. Thursday, January 16, 2020
+
+## COPIES TO
+
+ARTHUR JACOBS
+
+DOUGLAS A. WYLER
+
+No Address Available
+
+HAMPTON C. PETERSON
+
+--)W1 9-C .01 e5 2\_000(.113:\_14111./2420 , KrIsta filaue2Chlot4ydge
+
+50.2019•CA-014681-XXXX-Atli 01116/2020 Krista Marx Chief Judge
+
+961687 GATEWAY BLVD SUITE 201-I FERNANDINA BEACH, FL 32034
+
+POST OFFICE BOX 229 WEST PALM BEACH, FL 33402
+
+jacobsscholzlaw@comeastnet aijacobs@comeast.net
+
+doug.wyler@comcast.net
+
+CLERK E-SERVICE@MYPALMBEACH CLERICCOM hpeterson@mypalmbeachcletic. corn
+
+MICHAEL GRYGIEL 54 STATE STREET GRYGIELM®GTLAW.COM
+
+6TH FLOOR ALBANY, NY 12207
+
+STEPHEN A. 5100 TOWN CENTER CIR rrendelsohns@gtlaw.com MENDELSOHN, ESQ SUITE 400 hasenh@gtlaw.com BOCA RATON, FL 33486
+
+A, g

marker2-fixhub/court-ca-florida-holdings/EFTA02732518/EFTA02732518.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732520/EFTA02732520.md

@@ -0,0 +1,95 @@
+## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CA FLORIDA HOLDINGS, LLC, CASE NO.: 50-2019-CA-014681-XXXX-MB
+
+Publisher of THE PALM BEACH POST, Div.: AG
+
+Plaintiff,
+
+v.
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida,
+
+## Defendants. is VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.51Q
+
+04
+
+COMES NOW Nina D. Boyajian, Movant herein, and respectfully represents the following:
+
+- 1. Movant is an attorney and a member of the law firm of Greenberg Traurig, LLP, with offices at 1840 Century Park East, Suite 1900, Los Angeles, California 90067, telephone number (310) 586-7700. / -
+- 2. M6 it has been retained personally or as a member of the above-named law firm on or ..76.4 abo \ t e 28, 2019, by plaintiff CA Florida I loldings, LLC, publisher of the Palm Beach Post to legal representation in connection with matters related to the above-styled action now pending before the above-named court of the State of Florida.
+- 3. Movant is an active member in good standing and currently eligible to practice law in the following jurisdiction(s):
+
+| Court | Bar Number Admitted |
+| --------------------------------- | --------------------- |
+| Superior Courts of California | 246415 12/04/2006 |
+| Central District of California | 12/15/2006 |
+| Northern District of California | 11/14/2016 |
+| Southern District of California | 01/30/2009 |
+| Eastern District of California | 07/29/2010 |
+| District of Colorado | 03/07/2019 |
+
+4. There have been no disciplinary, suspension, disbarment o cons pt proceedings initiated against Movant in the preceding 5 years.
+
+5. Movant, either by resignation, withdrawal, or se, never has terminated or attempted to terminate Movant's office as an attorney in orderlopoid adm nistrative, disciplinary, disbarment, or suspension proceedings.
+
+6. Movant is not an inactive member of The Florida Bar.
+
+7. Movant is not now a merriber of The Florida Bar.
+
+8. Movant is not a suspended member of The Florida Bar.
+
+9. Movant is not a disbarred member of The Florida Bar nor has Movant received a disciplinary resignation frOM The Florida Bar.
+
+10. Movartt has not previously been disciplined or held in contempt by reason of miscondu dommitted while engaged in representation pursuant to Florida Rule of Judicial Administ ion 2.510.
+
+11. Movant has not filed a motion to appear as counsel in Florida state courts during the past five years.
+
+12. Local counsel of record associated with Movant in this matter is Stephen A. Mendelsohn who is an active member in good standing of The Florida Bar and has offices at cause only. WHEREFORE, Movant respectfully requests permission to appear in-this court for this
+
+DATED this 16th day of January, 2020.
+
+Greenberg Traurig, P.A., 51 Town Center Circle, Suite 400, Boca Raton, Florida 33486, telephone number (561) 955-7600.
+
+13. Movant has read the applicable provisions of Florida Rule of Judicial Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and certifies that this verified motion complies with those rules.
+
+14. Movant agrees to comply with the provisions of the Florida Rules of Professional Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida.
+
+"S CA)
+
+{sup}`y` Nina D. Boyajian Greenberg Traurig, LLP 1840 Century Park East, Suite 1900 Los Angeles, CA 90067-2121 Telephone: (310) 586-7700 Facsimile: (310) 586-7800 Email: boyajiaffn@gtlaw.com
+
+C .)
+
+STATE OF CAL ) ss: COUNTY OF LOS ANGELES
+
+1, Nina D. Boyajian, do hereby swear or affirm under penalty of perjury that I am the Movant in the above-styled matter; that I have read the foregoing Motion and know the contents thereof, and the contents are true of my own knowledge and belief.
+
+Nina D. Boyajian
+
+CERTIFICATE OF LOCAL COUNSEL
+
+I hereby consent to be associated as local counsel of record in this cause pursuant to Florida Rule of Judicial Administration 2.510.
+
+DATED January 16, 2020.
+
+/s/ Stephen A. Mendelsohn  
+Stephen A. Mendelsohn  
+Florida Bar Number: 849324  
+Greenberg Traurig, P.A.  
+5100 Town Center Circle, Suite 400  
+Boca Raton, FL 33486  
+Telephone: (561) 955-7600  
+Facsimile: (561) 338-7099  
+Email: sanchezfo@gtlaw.com
+
+NOTA CERTIFIED
+
+CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on January 16, 2020, a true and correct copy of the foregoing motion was served by mail to PHV Admissions, The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2333 accompanied by payment of the \$250.00 filing fee made payable to The Florida Bar. I also certify that the foregoing was electronically filed with the Clerk of the Court using the Florida Courts E-Filing Portal and is being served by e-mail generated by the EPortal system upon: Douglas A. Wyler, Esq., [REDACTED] Scholz & Wyler, LLC, 961687 Gateway Blvd., Suite 201-I, Fernandina Beach, FL 32304, jacobsscholzlaw@comcast.net; and Hampton C. Peterson, General Counsel, Post Office Box 33402, West Palm Beach, FL: 33402, clerk\_e-service@mypalmbeachclerk.com.
+
+/s/ Stephen A. Mendelsohn  
+Stephen A. Mendelsohn
+
+NOT A CERTIFIED COPY

marker2-fixhub/court-ca-florida-holdings/EFTA02732520/EFTA02732520.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732525/EFTA02732525.md

@@ -0,0 +1,36 @@
+![](_page_0_Picture_0.jpeg)
+
+## SHARON R. BOCK
+
+CLERK & COMPTROLLER PALM BEACH COUNTY, FLORIDA
+
+## RECEIPT
+
+
+
+Printed On: 01/17/2020 10:30 Page 1 of 1
+
+| **Receipt Number: 3499457 - Date 01/17/2020 Time 10:29AM** |  |  |  |  |
+| ------------------------------------------------------------------------------------------------------------------------------ | ------------- | ------------------------------------------------------------------------------- | --------------- | ---------------------- |
+| **Received of:** | | Greenberg Traurig, P.A.
+333 SE 2nd Avenue
+Suite 4400
+Miami, FL 33131 | | |
+| **Cashier Name:** |  | ADMIN |  |  |
+| **Cashier Location:** |  | E-Filing |  |  |
+| **Receipt ID:** |  | 9798748 |  |  |
+| **Division:** |  | AG: Circuit Civil Central - AG(Civil) |  |  |
+| **Case# 50-2019-CA-014681-XXXX-MB -- PLAINTIFF/PETITIONER: CA FLORIDA HOLDINGS LLC
+PUBLISHER OF THE PALM BEACH POST** | | | | |
+| **Item** |  | **Balance** | **Paid** | **Bal Remaining** |
+| Fees |  | 100.00 | 100.00 | 0.00 |
+| **Case Total** |  | **100.00** | **100.00** | **0.00** |
+| **Payments** |  |  |  |  |
+| **Type** | **Ref#** | **Amount** |  |  |
+| EFiling_CREDITCARD | 26957046 | 100.00 |  |  |
+| **Total Received** |  | **100.00** |  |  |
+| **Total Paid** |  | **100.00** |  |  |
+
+How was your service today? Please visit www.mypalmbeachclerk.com/survey or send your feedback to clerkweb@mypalmbeachclerk.com.
+
+For office locations and information about Clerk & Comptroller services: Visit www.mypalmbeachclerk.com or call (561) 355-2996.

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marker2-fixhub/court-ca-florida-holdings/EFTA02732526/EFTA02732526.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732620/EFTA02732620.receipt.json

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marker2-fixhub/court-ca-florida-holdings/EFTA02732716/EFTA02732716.md

@@ -0,0 +1,31 @@
+## 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. DAVE ARONBERG, SHARON R BOCK, Defendant/Respondents.
+
+## ORDER CANCELLING HEARING
+
+THIS CAUSE having come before the Court on Plaintiff Complaint on January 17, 2020, and the Court having reviewed the full advised in the premises, it is of First Amended its entirety and being
+
+ORDERED that the hearing scheduled on Ja at 1090 am on Defendant's Motion to Dismiss the Complaint is cancelled as the ot.
+
+DONE AND ORDERED, in West P Palm Beach County, Florida this 21st day of January, 2020.
+
+## COPIES TO
+
+C.)
+
+No Address Available DOUGLAS A. WYLER 961687 GATEWAY BLVD SUITE 201-I FERNANDINA BEACH, FL 32034 HAMPTON C. PETERSON POST OFFICE BOX 229 WEST PALM BEACH, FL 33402 No E-mail Address Available doug.wylet®comcastnet CLERK E-SERVICE©MYPALMBEACH CLERK.COM hpetersongmypalmbeachclerk. com
+
+XGOGIA: (Oldtallauc=Chlonly go
+
+so-201§;c4i-ovisel:XXXX-Mii Krista Marx Chief Judge
+
+MICHAEL GRYGIEL 54 STATE STREET GRYGIELM@GTLAW.COM
+
+6TH FLOOR ALBANY, NY 12207
+
+NINA D. BOYAJIAN 1840 CENTURY PARK No E-mail Address Available EAST SUITE 1900 LOS ANGELES, CA 90067
+
+STEPHEN A. 5100 TOWN CENTER CIR irendelsolms@gdaw.com MENDELSOHN, ESQ SUITE 400 basenh@gtlaw.com
+
+BOCA RATON, FL 33486 6)\*

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marker2-fixhub/court-ca-florida-holdings/EFTA02732718/EFTA02732718.md

@@ -0,0 +1,42 @@
+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
+
+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 Palm ) Beach County, Florida, )
+
+CO 'S
+
+
+Defendants. )
+
+## ORDER GRANTING MOTION TO&AITA AR PRO HAC VICE
+
+THIS CAUSE having come befoc t i upon the foregoing Verified Motion for Admission to Appear Pro Hac Vice, an urt being fully advised in the premises,
+
+IT IS HEREBY ORDERED AND ADJUDGED that said Motion be and is hereby GRANTED. Nina D. Boyajian, Esq. is admitted Pro Hac Vice and may represent Plaintiff, CA Florida Holdings, LLC, Publisher of The Palm Beach Post in proceedings before this Court.
+
+DONE AND ORDERED in January, 2020. in Palm Beac lorida this? "day of
+
+ACTIVE 48303997v1
+
+CIRC JUDGE
+
+Copies furnished to:
+
+Stephen Mendelsohn, Esq., Greenberg Traurig, 5100 Town Center Circle, Suite 400, Boca Raton, Florida 33486; mendelsohnsentlaw.com
+
+Michael J. Grygiel, Esq., Greenberg Traurig, 54 State Street, 6" Floor, Albany, New York 12207, grygielmQgtlaw.com;
+
+Nina D. Boyajian, Esq., Greenberg Traurig, 1840 Century Park East, Suite 1900, Los Angeles, CA 90067; bovajiarmagtlaw.com riveraal@ntlaw.com;
+
+Arthur I. =, Esq., Scholz & Wyler, LLC, 961687 Gateway B te 201-1, Fernandina Beach, FL 32034; iacobsscholzlaw@comcast.net
+
+Hampton C. Peterson, Esq., General Counsel for Sharon R. Bock, a omptroller, P.O. Box 229, West Palm Beach, FL 33402; Clerk E-service@mvpahn om

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marker2-fixhub/court-ca-florida-holdings/EFTA02732720/EFTA02732720.md

@@ -0,0 +1,90 @@
+## 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 Palm ) Beach County, Florida, ) ) Defendants. )
+
+CASE NO. 50-2019-CA-014681-XXXX-MB
+
+Division: AG
+
+## PLAINTIFF'S OWE DEFENDANTS' MOTI ISMISS
+
+A Cos
+
+Plaintiff, CA FLORIDA HOLDIN Palm Beach Post') for its Objection moot states: \*dim ts' Motions to Dismiss on the ground they are "S ePublisher of The Palm Beach Post, ("The
+
+- The Palm Beach C. is a daily community newspaper published by plaintiff CA Florida Holdings, of the Attorney,
+- 3. Beach Post commenced this action seeking to obtain the public release roceedings conducted by the office of the former Palm Beach County State Krischer, from its prior criminal prosecution of Jeffrey Epstein. The Palm Beach Post sued the current Palm Beach County State Attorney, Dave Aronberg, and the current Palm Beach County Clerk, Sharon R. Bock, solely in their official capacities who may have custody, control and possession of the Jeffrey Epstein grand jury records.
+  - 4. The Palm Beach Post filed its original Complaint on November 14, 2019.
+
+January 24, 2020 on defendants' Mio • ii the Court grant other just and p WHEREFORE, The Palm Beach P Ily requests that the hearing scheduled for iss the original Complaint be cancelled, and that
+
+Dated: January 21, 20201
+
+rcS"
+
+- 5. The State Attorney and Clerk separately moved to dismiss the original Complaint.
+- 6. The Court has scheduled a hearing on defendants' Motions to Dismiss for January 24, 2020.
+
+7. On January 17, 2020, The Palm Beach Post filed and served its First Amended Complaint, pursuant to Fla. R. Civ. P. 1.190, which states in pertinent part:
+
+> A party may amend a pleading once as a matter of course at any time before a responsive pleading is served ....
+
+8. In light of the filing of the First Amended Complaint Motions to Dismiss the original Complaint are now moot.
+
+9. The Palm Beach Post requests that the hearth de ndants' Motions to Dismiss, scheduled for January 24, 2020, be cancelled as the Mo .0 smiss are directed to the original Complaint, which is no longer the operative plea 14
+
+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: is/Stephen A. Mendelsohn
+
+STEPHEN A. MENDELSOHN
+
+Florida Bar No. 849324
+
+mendelsohns®gtlaw.com
+
+hasenh®gtlaw.com
+
+FLService®Htlaw.cotn
+
+-and-
+
+By: /s/ Michael J Grvgiel
+
+MICHAEL J GRYGIEL
+
+(Pro Hac Vice)
+
+54 State St., 6th Floor
+
+Albany, New York 12207
+
+Telephone: (518) 689-1400
+
+Facsimile: (518) 689-1499
+
+grygielm@stlaw.com
+
+By: /s/ Nina D. Boyajian
+
+NINA D. BOYAJIAN
+
+(Pro Hac Vice applica 8)
+
+1840 Century Park E Suije 1900
+
+Los Angeles CA 6
+
+Telephone: (3 7700
+
+Facsimile: \_7800
+
+I HEREBY CER that on this 21' day of January, 2020, a copy of the foregoing has been electronicall r ed will the Florida E-File Portal for e-service on all parties of record herein. +0 /s/ Stephen A. Mendelsohn
+
+STEPHEN A. MENDELSOHN

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marker2-fixhub/court-ca-florida-holdings/EFTA02732723/EFTA02732723.md

@@ -0,0 +1,250 @@
+#### 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. CASE NO: 2019-CA-014681
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, SHARON R. BOCK, as Clerk & Comptroller, Palm Beach County, Florida,
+
+Defendants. GO
+
+#### DEFENDANT, DAVE ARONBERG, AS STATE ATTORNIIIMPALM REACH COUNTY, FLORIDA'S ANSWER TO FIRST AMENDED COMPLAINT AND MOTION TO DISMISS COUNT 11
+
+Defendant, DAVE ARONBERG, as State A olgalm Beach County, Florida, ("SAO"), by and through the undersigned attorney, he Plaintiff, CA Florida Holdings, LLC, Pt( to Dismiss Count II, as follows: Count I of the First Amended Complaint of e Palm Beach Post ("Post"), and files a Motion
+
+- 1. Admitted fir" dietional purposes.
+
+#### JURISDICTION
+
+#### PARTIES
+
+cnicd that Defendant Aronberg or the Office of the State Attorney for the Fifteenth
+
+Judicial Circuit is in possession and/or control of documents that are 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
+
+response is required. To the extent that a response is required, the SAO is without knowledge or information sufficient to form 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 July proccedinoie cr certain circumstances.
+
+7. Paragraph 7 contains the Palm Beach Post's statement of legal arguments to which no response is required. To the extent that a response is r r , the SAO is without knowledge or information sufficient to form a belief as to the factual allegations contained in paragraph 7, and therefore denies the allegations and a t proof thereof.
+
+8. Paragraph 8 sets forth the Post's st e o the case and legal arguments to which no response is required. To the extent that a nse required, the SAO is without knowledge or information sufficient to form a belief of any factual allegations contained in paragraph 8, and therefore denies the allege mends strict proof thereof.
+
+9. Paragraph 8 sets e Post's statement of the case and legal arguments to which no response is required. T i xtent that a response is required, the SAO is without knowledge or information suffre en forma belief as to the truth of any factual allegations contained in paragraph 9, and the the allegations and demands strict proof thereof.
+
+# FACTUAL BACKGROUND
+
+10. The SAO is without knowledge or information sufficient to forma belief as to the truth of any factual allegations contained in paragraph 10, and therefore denies the allegations and demands strict proof thereof.
+
+# A. First Epstein Sex Crimes Investivation, Indictment, and Plea Agreement: 2005-2008.
+
+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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 12, and therefore denies the allegations and demands strict proof thereof.
+
+13. The SAO is without knowledge or information sufficient to form a beli to the truth of any factual allegations contained in paragraph 13, and therefore denies the alle and demands strict proof thereof.
+
+14. The SAO is without knowledge or information suffrcient'oyh a belief as to the truth of any factual allegations contained in paragraph 14, and there the allegations and demands strict proof thereof.
+
+15. The SAO is without knowledge or of any factual allegations contained in pars strict proof thereof. sufficient to form a belief as to the truth therefore denies the allegations and demands
+
+# (1) Police Chief Reit C to the State Attorney
+
+16. The SAO is with o wledge or information sufficient to form a belief as to the truth of any factual allegations c fp a d in paragraph 16, and therefore denies the allegations and demands strict proof there°
+
+17 • AO is without knowledge or information sufficient to form a belief as to the truth of any fa a egations 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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 18, and therefore denies the allegations and demands strict proof thereof.
+
+19. The SAO is without knowledge or information sufficient to form 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 information sufficient to form 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 information sufficient to form f as to the truth of any factual allegations contained in paragraph 21, and therefore denies ons and demands strict proof thereof.
+
+22. The SAO is without knowledge or informationnr to form a belief as to the truth of any factual allegations contained in paragraph 22, and enies the allegations and demands strict proof thereof.
+
+#### (3) The FBI's Investigation an tein Non-Prosecution Agreement with Federal Authorities.
+
+23. The SAO is without owe or information sufficient to form a belief as to the truth of any factual allegations contai in aTagraph 23, and therefore denies the allegations and demands strict proof thereof.
+
+24. The ( 4cOr is 'thout knowledge or information sufficient to form a belief as to the truth of any factual 'o contained in paragraph 24, and therefore denies the allegations and demands strict p .
+
+25. The SAO is without knowledge or information sufficient to form 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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 26, and therefore denies the allegations and demands
+
+strict proof thereof.
+
+27. The SAO is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 27, and therefore denies the allegations and demands strict proof thereof.
+
+28. The SAO is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 28, and therefore denies the allegatio, d demands strict proof thereof.
+
+29. The SAO is without knowledge or information sufficient t as to the truth of any factual allegations contained in paragraph 29, and therefore deni a egations and demands strict proof thereof.
+
+of any factual allegations contained in paragraph 3 \ it ore denies the allegations and demands 40 30. The SAO is without knowledge or info rma(is {40 'o r lent to form a belief as to the truth strict proof thereof.
+
+31. The SAO is without 1m 'nformation sufficient to form a belief as to the truth of any factual allegations contain 'n ph 31, and therefore denies the allegations and demands strict proof thereof.
+
+# (4) The crhne c s' Rights Act Litigation.
+
+32. is without knowledge or information sufficient to form a belief as to the truth of any fac ons contained in paragraph 32, and therefore denies the allegations and demands strict p f.
+
+33. The SAO is without knowledge or information sufficient to form 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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 34, and therefore denies the allegations and demands strict proof thereof.
+
+35. The SAO is without knowledge or information sufficient to form 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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 36, and therefore denies the allegatiq d demands strict proof thereof.
+
+37. The SAO is without knowledge or information sufficient t as to the truth of any factual allegations contained in paragraph 37, and therefore deni a egations and demands strict proof thereof.
+
+#### icicle: 2019. B. Second Epstein Sex Crimes Investigation. Ind
+
+39. The SAO is without knowled 4fo ation sufficient to form a belief as to the truth of any factual allegations contained in g 9, and therefore denies the allegations and demands strict proof thereof.
+
+38. Admitted.
+
+40. The SAO is with° wledge or information sufficient to form a belief as to the truth of any factual allegations d in paragraph 40, and therefore denies the allegations and demands strict proof thereo
+
+41 • AO is without knowledge or information sufficient to form a belief as to the truth of any fa a a egations contained in paragraph 41, and therefore denies the allegations and demands strict proof thereof.
+
+42. The SAO is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 42, and therefore denies the allegations and demands strict proof thereof.
+
+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 I I earina: Enstein's Victims Sneak.
+
+45. The SAO is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 44, and therefore denies the al demands strict proof thereof. ns and
+
+46. Admitted that United States Senior Judge Richard M. B August 27, 2019, but the SAO is without knowledge or information suffi, form a belief as to the truth of any remaining factual allegations contained in p 3, and therefore denies the allegations and demands strict proof thereof. a hearing on
+
+47. The SAO is without knowledge or of any factual allegations contained in pare strict proof thereof. \ io sufficient to form a belief as to the truth therefore denies the allegations and demands
+
+48. The SAO is witho of any factual allegations contain aragraph 48, and therefore denies the allegations and demands strict proof thereof. ge or information sufficient to form a belief as to the truth
+
+49. T11 SIis without knowledge or information sufficient to form a belief as to the truth of any fac ons contained in paragraph 49, and therefore denies the allegations and demands strict p f.
+
+50. The SAO is without knowledge or information sufficient to form 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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 51, and therefore denies the allegations and demands
+
+strict proof thereof.
+
+### 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. Admitted.
+
+53. Admitted.
+
+54. Admitted that the Post has extensively investigated and reported the egations against, the law enforcement investigation of, and the crimes committed by Ep i lacks sufficient knowledge to admit or deny any factual allegations remaining in pare ph 5 , d therefore denies the allegations and demands strict proof thereof.
+
+55. The SAO is without knowledge or informa truth of any factual allegations contained in paragra therefore denies the allegations and demands strict proof thereof. ' i k) t to form a belief as to the
+
+# The Palm Beach Post's StalingrACISr d the Public Interest.
+
+56. Paragraph 56 of th ended Complaint contains the Palm Beach Post's statement of the case and legal to which no response is required. To the extent that a response is required, the \T0 ieradmits the press has a constitutional right of access to criminal proceedings, but is out owledge or information sufficient to form a belief as to the truth of any remaining fa a I Lions contained in paragraph 56, and therefore denies the allegations and deman f 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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 57, and therefore denies the allegations and demands strict proof thereof.
+
+58. Paragraph 58 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 information sufficient to form 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 te rmination of disclosure but is without knowledge or information sufficient to form a belief e truth of any remaining factual allegations contained in paragraph 59, and therefore allegations and demands strict proof thereof.
+
+# E. The Court's Jurisdiction and Authority.
+
+#### A X , (1) The Court's Supervision of the Grand .kuryC 'recess and Its Authority to Order Public Disclosure of the Epstein Evide
+
+60. Paragraph 60 of the First aint contains the Palm Beach Post's statement of the case and legal argume h no response is required. To the extent that a response is required, the SAO a ss has a constitutional right of access to criminal proceedings, but is without kno information sufficient to form a belief as to the truth of any remaining factual allegati ro tz contained ar in paragraph 60, and therefore denies the allegations and demands strict p ereo .
+
+Onitted.
+
+61. itt .
+
+63. Y 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 information sufficient to form 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
+
+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 information sufficient to form 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) The Court's Jurisdiction To Declare Rights And Construe Statutes.
+
+- 65. Admitted.
+- 66. Admitted.
+- 67. Admitted. C)
+
+4 4,
+
+## COUNT I
+
+(Declaratory Relief - Florida Stat. Sections V et seq.)
+
+- 68. The SAO reincorporates and re-alleges its p ' r s to paragraphs 1 through
+- 69. Admittcd. 4 67 above. \
+- 70. Paragraph 70 contains the 's siilement of the case and legal arguments to which no response is required. To the ex t t sponse is required, the SAO is without knowledge or information sufficient to form a the truth of any factual allegations contained in paragraph 70, and therefore denies egations and demands strict proof thereof.
+- 71. Ad de7 tha The Palm Beach Post is seeking a declaration from this Court but tlit ,34v/ denies the re o aragraph 71. itted.
+  - 73. Y 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 information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 74, and therefore denies the allegations and demands strict proof thereof.
+
+#### 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 determine wh athe mplaint as phrased within its four comers sufficiently states a cause of action, where • n be granted. Fox v. Professional Wrecker Operations 801 So. 2d 175, 178 (Fla. 5 DC I). A motion to dismiss tests whether the plaintiff has stated a cause of action. for a motion to dismiss under Florida Rule of Civil Procedure 1.140(b) is whether the pl er u rove any set of facts as alleged in the Complaint to support his or her claim. See, Co 1 ebeco Inc. 89 So. 2d 482, 484 (Fla. 1956); Wasua Ins. Co. v. Haynes, 683 So. 2d 11 DCA 1996).
+
+In order to meet this test, "a co nt allege sufficient ultimate facts to show that a pleader is entitled to relief." W.R. T n ontr.. Inc. v. Jensen Civ. Constr.. Inc.,728 So. 2d 297, 300 (Fla. 1st DCA 1999) (quoti Cos t rove 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. IL Civ. P. 1.110(b)). Th {sup}`t` urt.need not accept internally inconsistent factual claims, conclusory allegations, unwa de ctions, or mere legal conclusions made by a party. a (citing Response Oncolo in tralealth Insurance Co.,978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Asset M 97 F.3d 1182, 1188 (11th Cir. 2002) ("[On a motion to dismiss,] the plaintiffs factual alle :lions are accepted as true.... 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 party. Kislak v. Kreedian, 95 So. 2d 510, 514 (Fla. 1957).
+
+# H. Argument
+
+- a. Neither Defendant Aronbere, nor the Office of the State Attorney for the Fifteenth Judicial Circuit is in possession and/or control of documents that
+
+#### arc the subject of this act ion.
+
+It is significant to emphasize that despite Plaintiff's allegations to the contrary, Defendant Aronberg and the Office of the State Attorney for the Fifteenth Judicial Circuit are not in custody or control of the records sought herein, and therefore Defendant Aronberg 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 arc the subject of thjh,g ion.
+
+# b. Plaintiff Fails to State a Cause of Action
+
+Plaintiff attempts to assert a cause of action, in the interest of "furth ", under Florida Statute § 905.27; however, a review of the statute in question reveals that c se of action is provided for therein and consequently Count IT of Plaintiff's First Am plaint must be dismissed as a matter of law. Despite Plaintiff's extensive recitation background regarding Jeffery Epstein and the testimony and evidence presente t 21f06 grand jury in Palm Beach County, Florida, Fla. Stat § 905.27, merely explains ceplfons to the disclosure of grand jury testimony and does not set forth in any way a ca upon which to initiate a valid law suit.
+
+Moreover, a review of a issue clearly indicates that even if § 905.27, Fla. Stat. provided a basis for a cause of ac laintiff is barred from access to the records it seeks. To wit, in pertinent part, Fla. Stat. § !N 9 . (2) states:
+
+When such osure is ordered by a court pursuant to subsection (1) for use in a civil case, sclosed to all parties to the case and to their attorneys and by the latter to ike associates and employees. However, the grand jury testimony afforded s by the court can only be used in the defense or prosecution of the civil or c'P\*pii case and for no other purpose whatsoever.
+
+Here, despite the clear statutory guidelines for disclosure of grand jury materials in a civil case, Plaintiff is improperly seeking the requested 2006 grand jury materials for the purposes of public disclosure pursuant to the court's inherent authority and supervisory powers over the grand jury. [See, Complaint ¶¶ 8, 63]. Again, even if Plaintiff properly asserted a cause of action under Fla. Stat. 905.27, the statute unambiguously states that grand jury testimony "can only be used in the defense or
+
+prosecution of the civil or criminal case and for no other purpose whatsoever", which is distinctly different from Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla. Stat. § 905.27(21.
+
+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 Amq Complaint with prejudice, and grant Defendant Aronberg all other and further relief de t 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 y of the foregoing has been electronically filed with the Florida E-File Portal for e- • I parties of record herein. so\
+
+4 SCHOLL & WYLER, LLC
+
+Douglas A. Wyler
+
+Artlwrq. 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-I Fernandina Beach, Florida 32034 (904) 261-3693 (904) 261-7879 Fax Primary: jacobsscholzlaw@comcast.net
+
+General Counsel for the Florida Prosecuting Attorney's Association

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marker2-fixhub/court-ca-florida-holdings/EFTA02732736/EFTA02732736.md

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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 & Comptroller, Palm Beach County, Florida,
+
+Defendants.
+
+I
+
+## NOTICE OF UNAVAILABILI
+
+PLEASE TAKE NOTICE that counsel for Plainti SCHOLZ, and DOUGLAS A. WYLER, will be unavailabl 2020, due to obligations in the Florida Legislature, out The undersigned attorney requests that no hearings time, and that an extension of time/continuance which require his approval, attendance, or 'patio to prejudice any party. Go I. RICHARD J. ary 27, 2020 through March 16, mess obligations, and personal leave. ns, mediations, trials, etc. be set during this or those things that arise during the time frame This notice is not intended for purpose of delay, or
+
+I HEREBY CERTIFY electronically filed with th on 's 24th day of January, 2020, a copy of the foregoing has been Ida E-File Portal for e-service on all parties of record.
+
++6s
+
+CASE NO: 2019-CA-014681
+
+## CATE OF SERVICE
+
+SCHOLZ & WYLER, LW
+
+Id Douglas A. Wyler
+
+Arthur I. =, Esq. Fla. Bar No. 108249 Richard J. Scholz, Esq. Fla. Bar No.: 0021261 Douglas A. Wyler, Esq. Fla. Bar No.: 119979 961687 Gateway Blvd, Suite 201-1 Fernandina Beach, FL 32034 Telephone: (904) 261-3693 Facsimile: (904) 261-7879
+
+Primary: [jacobsscholzlaw@comcast.net](mailto:jacobsscholzlaw@comcast.net)
+
+*General Counsel for the Florida  
+Prosecuting Attorney's Association*
+
+NOT A CERTIFIED COPY

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marker2-fixhub/court-ca-florida-holdings/EFTA02732738/EFTA02732738.md

@@ -0,0 +1,250 @@
+#### IN THE CIRCUIT COURT OF THE I Di tENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO: 2019CA0146/31)OOC<MB AG
+
+CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST,
+
+Plaintiff
+
+vs.
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, SHARON R. BOCK, as Clerk & Comptroller, Palm Beach County, Florida,
+
+Defendants.
+
+O S
+
+\-1
+
+#### S TO FIVT IME CIED COMPLAINT DEFENDANT, SHARON R. BOCK, AS CLERK & 0 PTROLLER. PALM BEACH AND MOTIONV VHSS , COUNT H
+
+Defendant, Sharon R. Bock, as C & C ptroller, Palm Beach County ("Clerk"), by and through the undersigned attorney swers Count I of the First Amended Complaint of Plaintiff, CA Florida Holdings, isher of The Palm Beach Post ("Post"), and files a Motion to Dismiss Count II as forq.yonop,"
+
+S" is for jurisdictional purposes.
+
+#### JURISDICTION
+
+#### PARTIES
+
+- Admits.
+- 3. Admits.
+- 4. Admits.
+
+## INTRODUCTION
+
+5. Paragraph 5 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 Clerk is without knowledge or information sufficient to form 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 which no response is required. To the extent that a response is required, the Clerk admits section o(C) 905.27(1)(c), Florida Statute authorizes the disclosure of grand jury pr • under certain circumstances.
+
+7. Paragraph 7 contains the Palm Beach Post' ent of the case and legal arguments to which no response is required. To the exte ponse is required, the Clerk is without knowledge or information sufficient to fo i es to the truth of any factual allegations contained in paragraph 7, and therefore deniy4 a lions and demands strict proof thereof.
+
+8. Paragraph 8 sets forth th tatement of the case and legal arguments to which no response is required. To the e at response is required, the Clerk is without knowledge or information sufficient to form belief as to the truth of any factual allegations contained in paragraph 8, and the fore I en sthe allegations and demands strict proof thereof.
+
+9. 9 sets forth the Post's statement of the case and legal arguments to which no respon To the extent that a response is required, the Clerk is without knowledge or informatio ufficient to form 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 Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 10, and therefore denies the allegations and
+
+## A. First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 2005-2008.
+
+11. The Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 11, and therefore denies the allegations and demands strict proof thereof.
+
+12. The Clerk is without knowledge or information sufficient to font) to the truth of any factual allegations contained in paragraph 12, and therefore deO legations and demands strict proof thereof.
+
+13. The Clerk is without knowledge or informatio c, 'ent to form a belief as to the 4 truth of any factual allegations contained in paragraph 13 h ore denies the allegations and demands strict proof thereof.
+
+14. The Clerk is without know! oration sufficient to form a belief as to the truth of any factual allegations container nL graph 14, and therefore denies the allegations and demands strict proof thereof.
+
+15. The Clerk is witlThtgXnowledge or information sufficient to form a belief as to the truth of any factual a legal s ontained in paragraph 15, and therefore denies the allegations and demands strict f.
+
+# (1 e Chief Reiter's Letter to the State Attorney.
+
+The Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 16, and therefore denies the allegations and demands strict proof thereof.
+
+17. The Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 17, and therefore denies the allegations and
+
+## (2) The July 2006 State Grand Jury Presentation.
+
+18. The Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 18, and therefore denies the allegations and demands strict proof thereof.
+
+19. The Clerk is without knowledge or information sufficient to fo to the truth of any factual allegations contained in paragraph 19, and therefore d allegations legations and demands strict proof thereof. eO
+
+c 20. The Clerk is without knowledge or informatio l, tent to form a belief as to the truth of any factual allegations contained in paragraph 2 fore denies the allegations and demands strict proof thereof.
+
+21. The Clerk is without knowl or i tifp(oration sufficient to form a belief as to the truth of any factual allegations contain graph 21, and therefore denies the allegations and demands strict proof thereof.
+
+22. The Clerk is wit truth of any factual a legat is ontained in paragraph 22, and therefore denies the allegations and demands strict ntsloflltereof. owledge or information sufficient to form a belief as to the
+
+#### (3 I's Investigation and Epstein's Non-Prosecution Agreementwith Federal uthorities.
+
+23. The Clerk is without knowledge or information sufficient to form 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 Clerk is without knowledge or information sufficient to form 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 Clerk is without knowledge or information sufficient to form 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 Clerk is without knowledge or information sufficient to fo to the O truth of any factual allegations contained in paragraph 26, and therefore d i legations and demands strict proof thereof.
+
+27. The Clerk is without knowledge or informatio V tent to form a belief as to the truth of any factual allegations contained in paragraph S2 tf, i fore denies the allegations and demands strict proof thereof.
+
+28. The Clerk is without knowl or /Sr"i Si ation sufficient to form a belief as to the truth of any factual allegations contains ph 28, and therefore denies the allegations and demands strict proof thereof.
+
+29. The Clerk is witlTh.dXnowledge or information sufficient to form a belief as to the truth of any factual a legat ontained in paragraph 29, and therefore denies the allegations and demands strict f.
+
+3 lerk is without knowledge or information sufficient to form a belief as to the truth of an ctual allegations contained in paragraph 30, and therefore denies the allegations and demands strict proof thereof.
+
+31. The Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 31, and therefore denies the allegations and demands strict proof thereof.
+
+## (4) The Crime Victims' Rights Act Litigation.
+
+32. The Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 32, and therefore denies the allegations and demands strict proof thereof.
+
+33. The Clerk is without knowledge or information sufficient to form a be 'ef as to the truth of any factual allegations contained in paragraph 33, and therefore denies t a ions and demands strict proof thereof.
+
+34. The Clerk is without knowledge or information suffic' nt to a belief as to the truth of any factual allegations contained in paragraph 34, and re denies the allegations and demands strict proof thereof.
+
+35. The Clerk is without knowledge or SH<c) n sufficient to form a belief as to the truth of any factual allegations contained in pc gra 5, and therefore denies the allegations and demands strict proof thereof.
+
+36. The Clerk is wit a truth of any factual allegations ct4' ed in paragraph 36, and therefore denies the allegations and demands strict proof them ge or information sufficient to form a belief as to the
+
+37. is without knowledge or information sufficient to form a belief as to the truth of a allegations contained in paragraph 37, and therefore denies the allegations and demands t proof thereof.
+
+# B. Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
+
+38. Admits.
+
+39. The Clerk is without knowledge or information sufficient to form a belief as to the truth of any factual allegations contained in paragraph 39, and therefore denies the allegations and
+
+40. The Clerk is without knowledge or information sufficient to form 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 Clerk is without knowledge or information sufficient to form a bepef as to the truth of any factual allegations contained in paragraph 41, and therefore denies t9te allegations and ' demands strict proof thereof.
+
+42. The Clerk is without knowledge or information suffie. nt to a belief as to the truth of any factual allegations contained in paragraph 42, anddhf pre denies the allegations and demands strict proof thereof.
+
+43. The Clerk is without knowledge or itSinn honsufficient to form a belief as to the truth of any factual allegations contained in paragraph 43, and therefore denies the allegations and demands strict proof thereof.
+
+44. Admits
+
+# C. The August 27, 2019, SDNY Hearing: Enstein's Victims Sneak.
+
+45. The Clerk i Cvi out knowledge or information sufficient to form a belief as to the truth of any fa I a gations contained in paragraph 45, and therefore denies the allegations and dema roof thereof.
+
+Admits that United States Senior Judge Richard M. Berman ordered a hearing on August 27, 2019, but the Clerk is without knowledge or information sufficient to form a belief as to the truth of any remaining factual allegations contained in paragraph 46, and therefore denies the allegations and demands strict proof thereof.
+
+47. The Clerk is without knowledge or information sufficient to form a belief as to the
+
+truth of any factual allegations contained in paragraph 47, and therefore denies the allegations and demands strict proof thereof.
+
+48. The Clerk is without knowledge or information sufficient to form 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 Clerk is without knowledge or information sufficient to form aTT s to the truth of any factual allegations contained in paragraph 49, and therefore de cies h...,th e allegations and demands strict proof thereof. C
+
+V 50. The Clerk is without knowledge or informatio ient to form a belief as to the truth of any factual allegations paragraph 50, and therefo rot t allegations and demands strict proof thereof.
+
+51. The Clerk is without know! or \fpi \ nation sufficient to form a belief as to the truth of any factual allegations contain graph 51, and therefore denies the allegations and demands strict proof thereof.
+
+# D. The Palm Beach Post's dine and the Public Interest.
+
+- (1) The Palm c i' Post Has Reported Extensively On Epstein's Crimes For Nearly 15 rs. ?
+- 52. dmits.
+
+54. Admits 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.
+
+55. The Clerk is without knowledge or information sufficient to form 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) The Palm Beach Post's Standing and the Public interest.
+
+56. Paragraph 56 of the First Amended Complaint contains the Palm Beach Post's that a to criminal statement of the case and legal arguments to which no response is required. T A response is required, the Clerk admits the press has a constitutional ri proceedings, but is without knowledge or information sufficient to fo a f as to the truth of any remaining factual allegations contained in paragraph 56, an ore denies the allegations and demands strict proof thereof.
+
+57. Paragraph 57 sets forth the Post's s e case and legal arguments to which no response is required. To the extent that a r uired, the Clerk is without knowledge or information sufficient to form a bet' e truth of any factual allegations contained in paragraph 57, and therefore deni tions and demands strict proof thereof.
+
+58. Paragraph 58 set the Post's statement of the case and legal arguments to which no response is requ Ti extent that a response is required, the Clerk is without knowledge or information s ie form a belief as to the truth of any factual allegations contained in paragraph erefore 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 Clerk admits that Fla. Stat. 905.27 allows a court to make the determination of disclosure but is without knowledge or information sufficient to form a belief as to the truth of any remaining factual allegations contained in paragraph 59, and therefore denies the allegations and
+
+## 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. 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 t e tent that a response is required, the Clerk admits the press has a constitutional right o ss to criminal proceedings, but is without knowledge or information sufficient to fo 11 i as to the truth of any remaining factual allegations contained in paragraph 56, and theref ies the allegations and demands strict proof thereof.
+
+- 61. Admits.
+
+- 62. Admits.
+
+63. Paragraph 63 sets forth the 's1 Cement of the case and legal arguments to which no response is required. To the exte t ponse is required, the Clerk is without knowledge or information sufficient to form as to the truth of any factual allegations contained in paragraph 63, and theref nies the allegations and demands strict proof thereof.
+
+64. Pa raph of the First Amended Complaint contains the Palm Beach Post's statement of e and legal arguments to which no response is required. To the extent that a respo red, the Clerk is without knowledge or information sufficient to form 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) The Court's Jurisdiction To Declare Rights And Construe Statutes.
+
+- 65. Admits.
+
+- 66. Admits.
+- 67. Admits
+
+## COUNT I
+
+(Declaratory Relief - Florida Stat. Sections 86.011 et seq.)
+
+68. The Clerk & Comptroller reincorporates and re-alleges its prior answer to paragraphs 1 through 67 above.
+
+- 69. Admits.
+
+70. Paragraph 70 contains the Post's statement of the case Ord Ieg Crguments to which no response is required. To the extent that a response is requirr lerk is without knowledge or information sufficient to form a belief as to the truth y ctual allegations contained in paragraph 70, and therefore denies the allegations ds strict proof thereof.
+
+71. Admits that The Palm Beach ng a declaration from this Court but denies the remainder of Paragraph 71.
+
+- 72. Admits.
+- 73. Denies.
+
+74. Para ph tains the Post's legal arguments to which no response is required. To the extent t r nse is required, the Clerk is without knowledge or information sufficient to form a bel e truth of any factual allegations contained in paragraph 74, and therefore denies the allegat s and demands strict proof thereof.
+
+## MOTION TO DISMISS COUNT II
+
+(Florida Stat. Section 905.27)
+
+DEFENDANT, Sharon R. Bock, as Clerk & Comptroller, Palm Beach County, pursuant to the Florida Rules of Civil Procedure 1.420, hereby files this Motion to Dismiss Count II of the First
+
+Amended Complaint of Plaintiff, CA Florida Holdings, LLC, Publisher of The Palm Beach Post, and as grounds states as follows:
+
+## I. Argument and Standard of Review
+
+## a. Plaintiff Fails to State a Cause of Action
+
+To state a cause of action, a complaint must allege sufficient ultimate facts to s ow that the pleader is entitled to relief. Florida Rules of Civil Procedure I.1 10(b) requires " s nd plain statement of the ultimate facts showing that the pleader is entitled to relief.' wing an order granting a motion to dismiss for failure to state a cause of action, the ourt st accept as true all i well-pled allegations in a complaint, and it must draw all rIc le inferences in favor of the pleader.
+
+> Whether a complaint is sufficient to W.R. Townsend Contracting, In 2d 297, 299, (Fla. 1st DCA 1 dismiss, the trial court is co the Complaint, must ac to what the true fac trial of the cause. 2001); DCA 2002). se of action is an issue of law. Civil Construction, Inc., 728 So. n a trial court rules on a motion to he allegations within the four comers of legations as true, and may not speculate as r what facts may ultimately be proved in the m v. Holder, 787 So. 2d 939, 941 (Fla. 2d DCA pion Cent. Life Ins. Co., 809 So. 2d 13 (Fla. 3d
+
+The purpose f a m li to to dismiss is to determine whether the plaintiff has alleged a viable cause of actio ns v. Buckeye Cellulose Corp., 285 So. 2d 7, 10 (Fla. 1973). In fact, "[d]espite ntal proposition that on a motion to dismiss for failure to state a cause of action all allegan are taken as true, [a] court will not `by inference on inference or speculations supply essential averments that are lacking." v. E & A Produce Corp., 708 So. 2d 997, 1000 (Fla. 3d DCA 1998); see also Conley v. Shuns & Bowen, P.A., 616 So. 2d 523, 524-25 (Fla. 3d DCA 1993).
+
+Taking the facts alleged therein and exhibits attached to the Complaint, Plaintiff failed to
+
+state a cause of action against the Clerk, and therefore, Count II should be dismissed because under no set of facts can the Plaintiff state a cause of action for which relief can be granted.
+
+Admittedly, Fla. Stat. § 905.27, sets forth possible exceptions to the disclosure of grand jury testimony, however Plaintiff is barred by the clear language of the statute from access to the records it seeks for the purposes it has set forth as Fla. Stat. § 905.27(2) states:
+
+When such disclosure is ordered by a court pursuant to subsection (I) civil case, it may be disclosed to all parties to the case and to their attortM and by the latter to their legal associates and employees. However, the wan jury testimony afforded such persons by the court can only be used in the defen osecution of the civil or criminal case and for no other purpose whatsoeve
+
+Here, despite the clear statutory guidelines for disclos case, Plaintiff is improperly seeking the requested 2006 outside the statutory limitations pursuant to the co over the grand jury. The statute unambiguo the defense or prosecution of the civil o is distinctly different from Plai evidence. Fla. Stat. § 905.27(2). nd jury materials in a civil materials for purposes clearly nt authority and supervisory powers at grand jury testimony "can only be used in case and for no other purpose whatsoever", which ded purpose for public disclosure of the grand jury
+
+Here, t in sectio pursuant t sole involvement in this action is as the custodian of the record as set forth orida Statute. This duty includes keeping grand jury records confidential tion 905.27, Florida Statute. The Clerk must follow strict statutory guidelines to maintain the record's confidentiality. Further emphasizing the statutory intent of confidentiality, section 905.27, Florida Statute imposes criminal penalties for improper disclosure of grand jury proceedings or identity of persons.
+
+# CONCLUSION
+
+Ultimately, plaintiff's Complaint is an 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. However, that recitation fails to state a cause of action for which the requested relief can be granted.
+
+WHEREFORE, based on the foregoing argument and supporting authority, Defendant, Sharon R. Bock, as Clerk &Comptroller, Palm Beach County respectfully prays for the C urt to grant this Motion to Dismiss Count II of Plaintiff's First Amended Complaint with 444 u provide direction to the Clerk as needed, and grant such other and further relief as thOse ms proper.
+
+# CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true copy of the forego been emailed in compliance with the Florida Rules of Judicial Administration 2.516, 4th day of January, 2020, to: Stephen A. Mendelsohn, Esq., Greenberg Traurig, own Center Circle, Suite 400, Boca Raton, FL 33486, email: mendelsohns@gtla Douglas A. Wyler, Esq., 961687 Gateway Blvd., Suite 201-1, Fernandina Beach, email: jacobsscholzlaw@comcast.net.
+
+> O ton C. Peterson, General Counsel Sharon R. Bock, Clerk & Comptroller ost Office Box 229 West Palm Beach, FL 33402 Telephone: (561) 355-2983 E-service: Clerk E-service@mpalmbeachclerk.com
+
+BY: s/Hampton C. Peterson Florida Bar No. 331384

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marker2-fixhub/court-ca-florida-holdings/EFTA02732752/EFTA02732752.md

@@ -0,0 +1,53 @@
+IN THE CIRCUIT COURT 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.
+
+DAVE ARONBERG, SHARON R BOCK,
+
+Defendant/Respondents.
+
+## ORDER SETTING HEARING ON DEFENDANTS' MOTION 11 SS COUNT
+
+THIS CAUSE having come before the Court onDefe ' Motion to Dismiss Count H, and the Court having reviewed the file in the entirety premises, it is rwise fully advised in the
+
+ORDERED that Defendants' Motion to D s"46unt II is hereby scheduled for hearing before Judge Krista Marx on March 2 0 10:00 am in Courtroom 11B of the Main Courthouse, 205 N Dixie Highway, Wes 161 ach, Florida 33401. Thirty (30) minutes has beenreserved for this hearing.
+
+DONE AND ORDERED in W c aim each, Palm Beach County, Florida. Monday, February 03, 2020
+
+## COP
+
+DOUGLAS A. WYLER
+
+4000C; ": TiotallapC:ChlofJg go
+
+50 Y018 CA-014681-XXXX.MB 0i/03/2020 frOstaMqx Chief Judge
+
+No Address Available No E-mail Address Available 961687 GATEWAY BLVD doug.wyler@conrast.net SUITE 201-I FERNANDINA BEACH, FL 32034
+
+HAMPTON C. PETERSON POST OFFICE BOX 229 CLERK E-33402 CLERK.COM
+
+WEST PALM BEACH, FL SERVICE@MYPALMBEACH hpeterson@rnypalmbeachclerk.
+
+MICHAEL GRYGIEL
+
+NINA D. BOYAJIAN
+
+STEPHEN A. MENDELSOHN, ESQ 54 STATE STREET 6TH FLOOR ALBANY, NY 12207
+
+1840 CENTURY PARK EAST
+
+SUITE 1900 LOS ANGELES, CA 90067 corn
+
+GRYGIELM@GTLAW.COM
+
+No E-mail Address Available
+
+5100 TOWN CENTER CIR rrendelsohns@gtlaw.com
+
+SUITE 400 lasenh@gtlaw.com BOCA RATON, FL 33486 6)\*

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marker2-fixhub/court-ca-florida-holdings/EFTA02732754/EFTA02732754.md

@@ -0,0 +1,265 @@
+#### IN THE CIRCUIT COURT OF THE F1141 EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CA FLORIDA HOLDINGS, LLC, CASE NO.: 50-2019-CA-014681-XXXX-MB
+
+Publisher of THE PALM BEACH POST, Div.: AG
+
+Plaintiff;
+
+v.
+
+DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida,
+
+Defendants.
+
+CO SA
+
+# PLAINTIFF'S OPPOSITION TO DEFENDANT CONBERG, AS STATE ATTORNEY OF PALM BEACH COUNTY, S MOTION TO DISMISS COUNT II OF THE FIRST COMPLAINT
+
+Plaintiff CA Florida Holdings, LLC, The Palm Beach Post ("The Palm Beach Past) files this opposition to Defendan a nberg, State Attorney of Palm Beach County's Motion to Dismiss Count II of The ch Post's First Amended Complaint ("Motion"):
+
+#### I. Y OF ARGUMENT
+
+The State Attorney btieyes this action to be "frivolous." Motion at 13. Far from it. This action is an opportunity institution of the State of Florida to exercise its authority, not to shield the sordid and but instead to further justice and restore the public's confidence in the criminal justices,
+
+The State Attorney pushes the general rule of grand jury secrecy too far. The State Attorney does so by arguing that Florida Statute § 905.27 does not allow The Palm Beach Post to seek relief under that statute, and even if it did, disclosure of the grand jury records in furtherance of justice cannot solely be made for purposes of informing the public. The State Attorney also appears to argue that the Court lacks the inherent authority and supervisory powers over the grand jury to order such disclosure. Motion at 12.1 Both arguments fail.
+
+The Palm Beach Post has sufficiently pled the existence of its right to maintain an action under Section 905.27, as it does so for the benefit of the public and consistent with the general legislative scheme. The Palm Beach Post has the right to use the grand jury materials to inform the ublic, which is consistent with Section 905.27.
+
+The Palm Beach Post has further stated a claim that either together W ependently of, l l Section 905.27, the Court has inherent authority to order the release e jury records. The exercise of such authority is regularly made for purposes as v • oting court efficiency to providing transparency for the judicial system.
+
+The Palm Beach Post has therefore stated a c %Of oth Section 905.27 and pursuant to the Court's inherent powers by which this Courtpia e release of the grand jury records sought in this action.
+
+## II. tt rl, BACKGROUND
+
+The facts underlying th acti are largely uncontested. See Answer of State Attomey; Answer of Clerk. Indeed, t now largely a matter of public record as a result of the extensive legal proceedings g out of the various crimes of Epstein and his co-conspirators over the course of more than e. While the complete factual allegations are set forth in the First Amended Compla. mary of the relevant facts is set forth below.
+
+# A. First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 2005 - 2008
+
+The investigation into Epstein's sex crimes began more than fifteen years ago, when a 14-
+
+I The State Attorney also contends that it is "not in custody or control of the records sought." Motion at 12. Whether the State Attorney possesses custody or control over the records is a disputed issue of fact that cannot be determined at the motion to dismiss stage.
+
+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. First Amended Complaint ("FAC") ¶ 11.
+
+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 victitseventeen witnesses revealed that the events described by the I4-year-old girl occurred, O rbingly similar details, with each of the other victims. Id.1 12.
+
+eviden c5 trie (4following a Epstein's home, showed that some of the girls involved w Ros) e age of 18. The police search of Epstein's residence also found two hidden cam eri \n , h ughout the house, large numbers of nude photos of girls, including victims whom 8,4i had not interviewed in the course of their investigation. Id. 1113. Both the victim/witness interviews, as well as search of
+
+In March 2006, a State gran testify. The proceeding was pos and Epstein's prominent c Another grand jury <vriccony a evidence. Id.1 cheduled at which all of the victims were expected to wever, due to meetings between the State Attorney's office defense lawyer and personal friend, Alan Dershowitz. Id.1 14. ed in April 2006, but canceled the day before it was to begin receiving
+
+14. 1' On May I, 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:
+
+#### Police Chief Reiter's Letter to the State Attorney
+
+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 unretumed. 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 disqualification from the prosecution of these cases. (Emphasis supplied)
+
+Id.¶ 16.
+
+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 requesl6i at either an arrest warrant be issued for Epstein or the State Attorney directly initiate tJ>uges against him, which would be public. Id.1 17.
+
+# 2. The July 2006 State Grand Jury Presentatiq
+
+Instead, State Attorney Krischer elected to refer theme d jury, which is mandatory for capital cases but rarely used for all other crimes. • o an official spokesperson, this was the first time that a sex crimes case was presentyd,'S " rtd jury in Palm Beach County. M.1 18.
+
+In July 2006, after State Attorney victim, the grand jury returned an i no mention in the indictment of sche resented testimony and evidence from just one n a sole count of solicitation of prostitution. There is being a minor. Id.119. Another of Epstein's victims was supposed to testify before l d jury, but did not. M. ¶ 20. No reasonable explanation has been provided as to wh e num rous other known victims were not presented as witnesses and crime victims to the convened in July 2006. M. ¶ 21. Nor has any reasonable explanation been provid hy State Attorney Krischer, who was initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do so. M.
+
+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 the charges against Epstein. Id. ¶ 22. This information was initially brought to the attention of the State Attorney's office by Epstein's defense counsel. Id.
+
+#### 3. The FBI's Investigation and Epstein's Non-Prosecution Agreement With Federal Authorities
+
+Following the deficient July 2006 indictment, and with Chief Reiter's encouragement, the FBI began its own investigation of Epstein. Id. ¶ 23. Records unsealed in 2015 revealed that the FBI compiled reports on "34 confirmed minors" that were victims of Epstein's sexual pred\$tions. Based on evidence gathered by the FBI, a 53-page indictment was prepared by the U ' tto y's Office presented to a federal grand jury. Id. in June 2007. Id. ¶ 24. However, at the request of Epstein's lawyers, t c ent was never
+
+Instead, then U.S. Attorney for the Southern District of Alexander Acosta, negotiated a plea deal with Epstein's team of lawyers to grant imm (along with four named coconspirators and any unnamed potential co-conspigal all federal criminal charges. Id. ¶ 25. Throughout the remainder of 2007 and through the fi half of 2008, Epstein's lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and belief, Epstein's lawyers insisted that (1) the victims not bpt of f(2) the deal be kept confidential and under seal, and (3) all grand jury subpoenas (includald.ahe that had already been issued for Epstein's computers) be withdrawn. Id.1 26.
+
+On June 2 Epstein pled guilty to State charges: one count of solicitation of prostitution and one co months in j 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. Id. ¶ 27. itation of prostitution with a minor under the age of 18. He was sentenced to 18
+
+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. Public records reveal that former State Attorney Krischer communicated with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers. Id.1 28.
+
+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 12 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." Id. ¶ 29. Epstein was also known to have violated the terms of his probation, but was not prosecuted. I g d. released five months early. Id. ¶ 30. was then
+
+Following publicity exposing the extraordinary leniency of the ozens of civil suits were brought against Epstein, most of which Epstein's lawyers f-court. Id.1 34.
+
+## 4. The Crime Victims' Rights Act Litiea
+
+During the course of the Town of Palm Beac I , vestigations, Epstein retained private c investigators to follow, harass, and photograph ' ti and their families, as well as Chief Reiter and the Town of Palm Beach detective w ' Sves ( ta lRr....y ted the case against Epstein. Id. ¶ 36. Epstein's victims were threatened against c t' with law enforcement and told that they would be compensated only if they did no to with law enforcement. Id.1 37.
+
+To add insult to inj tein's victims only learned after the fact about his plea deal in State court and filed an petition to force federal prosecutors to comply with the Crime Victims' Rights Act (1 3771, "CVRA"), which mandates certain rights for crime victims, including the right formed about plea agreements and the right to appear at sentencing. U.S. District Judge Kenneth A. Marra ruled in 2019 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. Id. ¶ 32. The prosecution's failure to keep the victims apprised, among other things, also contravenes the Florida Constitution, Article I, § 16(b) and Fla. Stat. § 960.001.k/1133.
+
+#### B. Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019
+
+On July 6, 2019, Epstein was arrested on federal sex trafficking charges. Id. ¶ 38.
+
+The United States government's prosecution of Epstein based on new allegations and charges stemmed, in part, from continued press investigations and reporting on the mishandling of the 2006 charges and the civil suits that followed. Id. ¶ 39.
+
+In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the 4iikhern District of New York, Epstein was described as "a serial sexual predator who preyed s of minor girls over a period of years." The letter emphasized that "the Government h ems — grounded in past experience with this defendant — that if allowed to remain out bat defendant could attempt to pressure and intimidate witnesses and potential witnes t including victims and their families, and otherwise attempt to obstruct justice." It lls" d the results of the FBI's search of Epstein's Manhattan townhouse: evidence of t g in the form of "hundreds—and perhaps thousands-of sexually suggestive phot phs f fully- or partially-nude females," including underage females. In a locked safe, ac 'scs were found with handwritten labels including the descriptions: "Young [Name] + area, "Misc nudes 1," and "Girl pies nude." Id. ¶ 40.
+
+On July 8, 2019, pri ors with the Public Corruption Unit of the U.S. Attorney's office for the Southern Di of N York charged Epstein with sex trafficking and conspiracy to traffic minors for se Th d jury indictment alleges that "dozens" of underage girls were brought into Epstein' ns 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. Id. ¶41.
+
+On or about August 6, 2019, Florida Governor Ron DeSantis ordered a state criminal probe into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their handling of the Epstein underage sex trafficking case. Id.1 43.
+
+On August 20, 2019, Epstein was found dead, by apparent suicide, at the federal Metropolitan Correction Center in lower Manhattan where he was being held without bail. Id. 11142, 44.
+
+#### C. The August 27. 2019. SDNY Henri ne: Enstein's Victims Sneak
+
+Following Epstein's death, prosecutors sought to dismiss the indictment aga while maintaining that they would continue to investigate his co-conspirators. Id. CI•ted States Senior District Judge Richard M. Berman ordered a hearing on August 27, 201 to dismiss the indictment and allowed victims Id. ¶ 46. at the hearing. secutors' decision
+
+In the course of the hearing, more than two d pain, frustration, and sexual abuse at the hands Sic it4 delivered their personal stories of . Several victims spoke of violent rape by Epstein. Many more victims were present • e m but did not testify. Id. ¶ 47.
+
+While some questioned the hind the court's decision to give the victims voice after Epstein's death, Judge Berman ted "a public hearing is [the] preferred vehicle of resolution," emphasizing that "public Irs• are exactly what judges do. Hearings promote transparency and they provide the co with • ights and information which the court may not otherwise be aware of" Indeed, even 's efense lawyer noted at the hearing that the court "is the institution that most people rdence in, in these very troubled times." Id. ¶ 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. Id. ¶ 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." Id. ¶ 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 wron s and those of the individuals who enabled his sexual racketeering, would allow for me measure of justice to be served after his death. Indeed, one victim stated: "Any e to protect Epstein's name and legacy send a message to the victims that he wins at is untouchable." Another victim expressed fear that this is a world "where there are q at )0 n power, a world where people can avoid justice if their pockets run deep enough." /
+
+In short, the "unusual" treatment Epstei ' Florida in 2006 based on his wealth, social status, and connections severely eroded pub 's faith in the integrity and impartiality of the criminal justice system. Allowing T ach Post's claims to proceed in this action would allow for public examination and and of the operation of the criminal justice system in Florida.
+
+## I pa,,p, III. LEGAL ARGUMENT
+
+#### A. Le al Sta
+
+Fla. R. 1.110(b) provides that a pleading that sets forth a claim for relief shall contain a short statement of the grounds of the ultimate facts showing that the pleader is entitled to relief. Fla. R. Civ. P. 1.110(g) permits a party to "set up in the same action as many claims or causes of action ... as the pleader has, and claims for relief may be stated in the alternative." The Rule further provides "[a] party may also state as many separate claims or defenses as that party has, regardless of consistency and whether based on legal or equitable grounds or both." Fla. R. Civ. P. I .110(g).
+
+Here, The Palm Beach Post brings two claims: one pursuant to Fla. Stat. § 905.27, and one for declaratory relief based on the principles set forth in Section 905.27 as well as constitutional principles of freedom of the press as protected by the Court's inherent authority and supervisory powers. The State Attorney concedes that the declaratory relief claim is adequately plead. For the same reasons requiring that concession—and those set forth below—the Court should, respectfully, find that both claims have been sufficiently plead.
+
+## 1. Grand Jury Secrecy Is Not Absolute CO S
+
+Typically, grand jury proceedings are conducted and ma' c • !' ed secret. Fla. Stat. § 905.24. grand jury proceedings are already subject to public , as a testifying grand jury witness is But this secrecy has never been—and was never intended tute. First, as a practical matter, public s, free to disclose her grand jury testimony. In ic {sup}`B`losr" .M, the United States Supreme Court, weighing the competing interests of grand • sec y and the First Amendment, held unconstitutional Section 905.27's purported prohibit' fitness revealing her own testimony. 494 U.S. 624, 626 (1990).2 The "secrecy" of grand Florida is thus qualified — not absolute — based on principles embodied in the First Ame
+
+## B. Relevant Legal Framework: Fla. Stat. ti 905.27
+
+Second, S testimony of disclo 90 .27(1) specifically provides exceptions to grand jury secrecy: "the s examined before the grand jury or other evidence received by it" may be required by a court ... for the purpose of: (a) Ascertaining whether it is consistent
+
+{sup}`2` The Florida Supreme Court has similarly confirmed that grand jury secrecy is not absolute and that any "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 (Fla. 1977). The decision in Marko emphasized that a grand jury's important role in "expos[ing) official misconduct" precludes restricting access to its activities for the purpose of protecting "public officeholders." Id. ("[t]he benefits to be derived from this extraordinary exercise in citizen participation [in the grand jury] would be severely limited if the fruits of that activity wcrc not available to the public on whose behalf it is undertaken. Implicit in the power of the grand jury to investigate and expose official misconduct is the right of the people to be informed of its findings.").
+
+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(1Xa)-(c). The Florida legislature therefore clearly intended to empower a court to order the disclosure of grand jury proceedings to, among other things, further justice, as this Court should do here.
+
+Subsequent to such disclosure, The Palm Beach Post is not, as the State Attorney argues, constrained by the statute from using the materials for public disclosure—nor coup under the First Amendment.; Motion at 13. The State Attorney argues that "grand j o y `can only be used in the defense or prosecution of the civil or criminal case and for n t se whatsoever'..." Motion at 12-13. But that limitation only applies "[w]hen such disc tI; ) re rdered by a court pursuant to subsection (1)for use in a civil case." Fla. Stat. § 905.27 t e y added). Here, The Palm Beach Post is not asking the Court to order the disclosure i d records "for use in a civil case;" rather, it seeks disclosure for the express r th in Section 905.27(1XO—i.e., to further justice by allowing the public, through th 7S rts IThe Palm Beach Post, access to this information.
+
+## 2. The Pahn Reach Landing Under Section 905.27
+
+The Palm Beach Post ht to maintain this private right of action because the furtherance of justice, an e egislative exception to grand jury secrecy, is intended for the public benefit, and The Be ch Post seeks access on behalf of the public it serves. Fla. Stat. § 905.27(IXc) It is rt er mandated in Fla. Stat. § 905.27 that the legislature intended for a court to be the ake the determination of disclosure. Fla. Stat. § 905.27(1). In other words, the legislature granted the courts the power to consider and determine the propriety and scope of grand
+
+{sup}`3` In this regard, the State Attorney's interpretation of Section 905.27 would render the statute a prior restraint, "the most serious and the least tolerable infringement on First Amendment rights." Nebraska Press Ass'n v. Swan, 427 U.S. 539, 559 (1976) (noting a "deeply-seated American hostility to prior restraints"). To the extent redactions to the grand jury materials may be required to protect the privacy of unnamed victims or third parties, the Court of coursc may require such redactions prior to ordering disclosure of the records.
+
+jury secrecy.
+
+The Supreme Court of the United States has "recognized that the invocation of grand jury interests is not "'some talisman that dissolves all constitutional protections." Butterworth, 494 U.S. at 630-31 (quoting U.S. v. Dionisio, 410 U.S. 1, 11 (1973)); see also Landmark Communications, at 838 (balancing state's interest in preserving confidentiality of judicial review proceedings against rights of newspaper reporting on such proceedings).
+
+As explained in the FAC (¶y 56-59), the Supreme Court has further ( ecocized that the press has a constitutional right of access to criminal proceedings, see, e.g., tc n ncnVewspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial crimina ,4 ;44 eeaRfp. v. Graddick, 696 F.2d 796 (11th Cir. 1983). 'Indeed, "the integrity of th is rocess, which public scrutiny is supposed to safeguard, is just as much at issue in prpCre f this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ. ?S ri. , 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in Att....., ers cerning the closure of judicial proceedings). The press also has a First Amendment ' cpe tt receiving information from willing speakers. See Va. State Bd. of Pharmacy v. Va. Ci ens nsumer Council, Inc., 425 U.S. 748, 756-57 (1976) ("Where a speaker exists . .. the p afforded [by the First Amendment] is to the communication, to its source and to its h."); Pittman v. 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Cou gnized that the First Amendment offers protection to both speakers and those wishing l re speech."); see also Stephens v. Cty. of Albemarle, VA, 524 F.3d 485, 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").
+
+Because of the unique role performed by the press as a "public surrogate" (=, 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'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." M, 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 Committee] has standing to assert [its] claim" to grand jury materials because such materials are "public records to which t c may seek ACt" access, even if that effort is ultimately unsuccessful").
+
+Here, the continued denial of access to information sought by Beach Post on behalf of its journalists and the public "unquestionably constitutes irre V 1 ury." Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla c ) , e also Zerilli v.M, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press' /S ittis '43 v as a vital source of information is weakened whenever the ability of journalists to ( s Ars h , e , is impaired," as it is by Attorney General's refusal to disclose unredacted report 119 and lyin grand jury materials).
+
+The Palm Beach Post does d that Section 905.27 makes no express provision for a civil suit or civil liability, but tha 's jus e start of the inquiry. In determining whether a private right of action lies in a statute, n Florida consider: (1) whether the plaintiff is one of the class for whose special ben the st to was enacted; (2) whether there is any indication, either explicit or implicit, of a I e mtent to create or deny such a remedy; and (3) whether judicial implication is consiste e underlying purposes of the legislative scheme. Fischer v. Metcalf, 543 So. 2d 785 (Fla. 3d DCA 1989) (adding the second and third factors; previously, courts considered solely the "class benefited" factor). "Courts must strike a balance; neither `fashioning a per se rule of construction that implicit in every penal statute is a concomitant civil remedy,' nor relinquishing the task of judicial implication in the face of legislative faltering or uncertainty." Fischer, 543 So. 2d at 789 (quoting
+
+Roger Rankin Enters., Inc. v.M, 433 So. 2d 1248, 1250 (Fla. 3d DCA 1983); v. Piezo Tech. and Prof! Adm'rs, 427 So. 2d 182, 184 (Fla. 1983) (Supreme Court of Florida implied a statutory cause of action for the wrongful discharge of employees who sought workers' compensation benefits).
+
+Consideration of these three factors weighs in favor of finding a private right of action in Section 905.27. First, the statutory exception to grand jury secrecy embodied in Sec 'on 905.27 — "furthering justice" — is intended to benefit the public at large, not just those prey arty to the grand jury proceeding at issue. Because, as set forth above, members s, are "public surrogate[s]" (=, 426 So. 2d at 6-7) and play a vital role in gathe g 1 ation and reporting on the criminal justice system, The Palm Beach Post is "one of clan or whose especial benefit the statute was enacted"—namely, the public itself. See M RQa . aide, 561 So. 2d 1319 (Fla. 4th DCA 1990) (finding plaintiffs "had the right to mai S {sup}`n`:, to cause of action as the persons the legislature intended to protect by the enactment e evant statute).
+
+Second, there is a dearth of legisle tisto surrounding Section 905.27, and The Palm Beach Post was unable to locate any do private right of action. There is also no intent—express or disclosure of gran vessel. See M case of ring any legislative intent regarding the possibility of a lit statement in favor of such a right, but to be clear, there is ise—prohibiting a private right of action, in the absence of which als to "further justice" under the statute would be rendered a hollow 61 So. 2d at 1320 ("The absence of express provision for civil liability in the f a statute does not negative the existence of a legislative intent that the statute shall effect private rights.") (quoting Florida Statutes, Section 475.482 (1989)).
+
+In such circumstances, consideration of the third factor — whether judicial implication is consistent with the underlying purposes of the legislative scheme — is instructive. When scrutinizing the history of legislation to determine legislative intent, it is appropriate to consider acts passed at
+
+subsequent sessions. Fischer, 543 So. 2d at 790. In 1994, at the same time Section 905.27 was reenacted to expressly provide for the three exceptions to grand jury secrecy, including furthering justice, the Florida legislature also reenacted Fla. Stat. § 905.395, which concerns the secrecy of statewide grand juries. 1994 Fla. ALS 285, 1994 Fla. Laws ch. 285, 1994 Fla. SB 114; Fla. Stat. § 905.395. Like Section 905.27, Section 905.395 has a general prohibition on disclosure of grand jury proceedings, absent a court order. Fla. Stat. § 905.395. Tellingly, however, Sectio 95 does not provide any specific exceptions to nondisclosure, including the fiwtheran i e. Through the intentional omission of these exceptions, including the fundamental " tice" exception, it can be understood that the legislature did not intend for court-o d osure of statewide grand jury records to further justice, and did not anticipate suc r lo would benefit the public. By contrast, the legislature's decision to include the ca " ering justice" exception in Section 905.27 reflects an intent to protect and inform e b the ultimate benefactors of the criminal justice system—by providing a means of a m se rare situations where the integrity of the grand jury process has been called into s ion. Accordingly, implying a private right of action is consistent with the purposes and e legislative scheme in Chapter 900 of the Florida Statutes.
+
+#### C. This Court has i t Power to Release Grand Jury Records in Order to Further Justice and %Indica e Confidence in the Judicial Process
+
+As set f inNipFAC (VI 60-64), even in the absence of the statutory framework in Section 905.27, di s appropriate pursuant to this Court's inherent authority over grand jury proceedings cause of the exceptional public interest in this case and the compelling circumstances supporting transparency rather than continued secrecy.
+
+# 1. The Grand Jury is Under the Court's Sunervision and Jurisdiction
+
+It is well-settled that the grand jury is "'a judicial proceeding in a court of justice...an appendage or adjunct to the circuit court."' In re Grand Jut),Investigation, 287 So. 2d 43 (Fla. 1973) (quoting Craft v. State, 42 Fla. 567, 29 So. 418 (1900)). Indeed, it is the court that gives the grand jury its initial charge and advises the grand jury about its legal duties. Fla. Stat. § 905.18.
+
+"It has long been understood that Iciertain implied powers must necessarily result to our Courts of justice from the nature of their institution,' powers `which cannot be dispensed with in a Court, because they are necessary to the exercise of all others." v. NASCa nc., 501 U.S. 32, 43 (1991). "There can be no question of the inherent power of a court `to prot and hence society, as an instrument of justice."' In re Osborn, 376 F.2d 808, 810 (6th •
+
+Thus, in a variety of contexts, it has been held that "courts hav t power to protect the integrity of the judicial process from perversion and abuse." v. . - chine v. Valchine, 793 So. 2d 1094, 1099-1100 (Fla. 4th DCA 2001); Attwood v. t e , 661 So. 2d 1216 (Fla. 1995) (invoking court's inherent authority to prevent "abus' tic ' m filing additional cases to prevent S "S in interference with orderly process of judicial ); Tramel v. Bass, 672 So. 2d 78 (Fla. 1st DCA 1996) (invoking court's inherent a c t trike pleadings to sanction fraud perpetrated on the court).
+
+The Florida Supreme Co has 6ted that it is "of vital importance to maintain the dignity and the integrity of both the and the presiding judge." State v. Clemmons, 150 So. 2d 231, 233- 34 (Fla. 1963).4 states such as Florida, where the grand jury is preserved, it is an important appendage of a co which impanels it...[and] it should not be forgotten that the judge of that court is equal tent and he is generally charged with the supervision of the grand jury's activities..." Id. "The importance of public confidence in the integrity of judges stems from the place of the judiciary in the government." - Yulee v. Fla. Bar, 575 U.S. 433, 445 (2015). Courts do not command armies and have "no influence over either the sword or the purse[.]" Id. (citing The Federalist No. 78,
+
+{sup}`4` State v. Clemons was superseded by statute. See Kelb, v. Sturgis, 453 So. 2d 1179 (Fla. 5th DCA 1984).
+
+p. 465 (C. Rossiter ed. 1961) (A. )). "The judiciary's authority therefore depends in large measure on the public's willingness to respect and follow its decisions." Id.; see also In re Petition to Inspect & Copy Grand Jury Materials, 735 F.2d 1261, 1269-70 (11th Cir. 1984) (upholding the exercise of the court's inherent power to release grand jury records to further "a matter of great societal importance" that affected "the public confidence in the judiciary"). "The perception of a viable healthy judiciary is of critical importance to our system of justice." Id. at 1271. This ' " is of equal importance with respect to state courts, which are invested with primary itsTes ty for overseeing the investigation and prosecution of crimes.
+
+The Supreme Court of the United States, while acknowled • ) the ues in grand jury secrecy, has long authorized the disclosure of grand jury records w ; t eed for transparency outweighs any remaining interest in secrecy. Douglas Oil Co. o i Sdfi(? c a v. Petrol Stops Northwest, 441 U.S. 211, 223 (1979). Courts around the country ha lllic, suit. See, e.g.. In re Petition of Nat? Sec. Archive, No. 08 CIV. 6599, 2008 WL 898 (S. sooN .Y. Aug. 26, 2008) (release of grand jury records concerning the indictment of Julius e osenberg); In re Petition of Nat? Sec. Archive, 104 F. Supp. 3d 625 (S.D.N.Y. 2015) me n re Petition of Kutler, 800 F. Supp. 2d 42 (D.D.C. 2011) (release of President Nixo d jury deposition testimony in connection with the third Watergate grand jury); In re ckets Related to the Indep. Counsel's 1998 Investigation of President Clinton, 308 d 314 (D.D.C. 2018) (release of records related to independent counsel's investig resident Clinton). Most recently, the D.C. Circuit ordered the Trump administration to provide the House Judiciary Committee redacted portions of grand jury materials from former special counsel Robert Mueller's probe into Russian election interference. In Re: Application of the Committee on the Judiciary, U.S. House of Representatives, For an Order Authorizing the Release of Certain Grand Jwy Materials, Committee on the Judiciary, United States House of Representatives
+
+v. U.S. Department ofJustice, No. 19-5288 (D.C. Cir. March 20, 2020). There is no evidence that the disclosures resulting from these cases have adversely affected the grand jury process. On the other hand, there is no doubt that the release of these materials has contributed greatly to the historical record of significant events in our country's history, as well as exposing failures in our justice system.
+
+#### 2. This Court has inherent Power to Release Grand Jury Records in Order to Further Justice and Vindicate Confidence in the Judicial Process
+
+Courts have identified nine "non-exhaustive" factors that a court atimcOStider when determining whether their inherent authority should be exercised to ord e of grand jury documents. These factors include:
+
+(i) the identity of the party seeking disclosure; (ii) w proceeding or the government opposes the disclosu the particular case; (iv) what specific informatio ago the grand jury proceedings took place; (vi jury proceedings and that of their famili either permissibly or impermissibly witnesses to the grand jury proceedin (ix) the additional need for maintayri e defendant to the grand jury y disclosure is being sought in ought for disclosure; (v) how long status of the principals of the grand th extent to which the desired material previously made public; (viii) whether t be affected by disclosure are still alive; and cy in the particular case in question.
+
+Kutler, at 47-48 (quoting In re Petit' g, 131 F.3d 99,106).5
+
+The vast majority of the weigh in favor of disclosure in this case. First, the party seeking disclosure does so uant to its First Amendment right to receive information in order to inform the public.St defendant to disclos P rmacy Bd., 425 U.S. at 756-57; Pittman, 267 F.3d at 1283. Second, the d'jury proceeding is deceased, although the government is opposed to the alm Beach Post respectfully submits that the government's opposition should be
+
+While it is largely federal courts that have applied these nine factors, (1) there can be no dispute that Florida courts arc endowed with inherent authority like their federal counterparts, see supra at 15-16; and (2) notably, federal courts consider these factors when the enumerated exceptions to grand jury secrecy set forth in Federal Rule of Criminal Procedure 6(eX3)(E) do not appear to apply. See, e.g., In re Petition to Inspect & Copy Grand Jury Materials, 735 F.2d 1261, 1268 ( I 1th Cir. 1984) ("it has been authoritatively said that [Rule 6(e)] is not the true source of the district court's power with respect to grand jury records but rather is a codification of standards pertaining to the scope of the power entrusted to the discretion of the district court"). Thus, to the extent the Court does not find that it is authorized by Fla. Stat. § 905.27 to order disclosure of the Epstcin grand jury materials, its inherent authority provides "ample[]" (id.) grounds for such disclosure.
+
+given little weight where, as here, the disclosure of records is sought to uncover the alleged misconduct of a prior State Attorney (as opposed to, for example, witness perjury). Third, disclosure is being sought—based on information learned by The Palm Beach Post from (1) a series of Florida Public Records Law requests, (2) law enforcement sources with direct knowledge of the grand jury evidence and proceedings, (3) judicial documents obtained from independent but related court proceedings, and (4) documents otherwise available in the public record—to inform the public as o tter the then State Attorney for Palm Beach County presented truncated evidence of Epste al wrongdoing to the 2006 grand jury in a manner that precluded Epstein's indic e serious crimes he committed, including sex trafficking and sexual assault. Fourt e rds being sought are the testimony, minutes, and other evidence presented in 2006 t appear to have been whitewashed so that Epstein wo there was ample evidence. Fifth, the grand jury each County grand jury, which charged with serious crimes of which took place nearly fifteen years ago. Sixth, the current status of the principals of the % j " croceedings are unknown. Seventh, because much of the requested information has mistreatment by and misgivin surrounding Epstein and hi this factor weighs unknown—in t the public domain through victims protesting their ing prosecutors (both state and federal), other lawsuits pirators, and public records requests and extensive news reporting, f MI disclosure. Eighth, the status of the witnesses who appeared is e Palm Beach Post's request is made, in part, to learn who the witnesses were that the rney did decide to call. 6 Finally, The Palm Beach Post submits that with the death of the defendant, the widely-known and litigated acts of his co-conspirators, the length of time that has passed, and the widely reported nature of this miscarriage of justice, there is no additional need for maintaining secrecy. See U.S. v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) ("[A]fter the grand
+
+{sup}`6` With rcspcct to the sixth and eighth factors, an in camera review by this Court, followed by appropriate redactions, would remedy any potential harm to innocent parties.
+
+jury's functions are ended, disclosure is wholly proper where the ends of justice require it.").
+
+Courts have long realized that a transparent criminal justice system, affords "significant community therapeutic value." Richmond Newspapers v. Virginia, 448 U.S. at 570-71. "[T]he open processes ofjustice serve an important prophylactic purpose, providing an outlet for community concern, hostility, and emotion." Id. at 571. "The crucial prophylactic aspects of the ad inistration ofjustice cannot function in the dark; no community catharsis can occur if justice i in a corner [or] in any covert manner." Id. eS'
+
+The Palm Beach Post has accordingly stated a claim pursuant to s inherent authority and supervisory powers, which allow the Court to take appropri it cessary action to preserve and promote the integrity of the justice system. The citizens a 7 each County and throughout the State of Florida are entitled to nothing less in this cas onal importance and public interest.
+
+## IV. Cctk , ION
+
+Pursuant to Fla. Stat. § 905.27 • 's rt's inherent supervisory authority, The Palm Beach Post has sufficiently pleaded • .
+
+Dated: March 13, 2020 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: Is/ Stephen A. Mendelsohn
+
+STEPHEN A. MENDELSOHN Florida Bar No. 849324 mendelsohns@gtlaw.com hasenhegtlaw.com FLService@gtlaw.com
+
+By: Is/ Michael J Grvgiel
+
+ACTIVE 492958.871M
+
+MICHAEL J GRYGIEL
+
+(Admitted Pro Hac Vice)
+
+54 State St., 6th Floor
+
+Albany, New York 12207
+
+Telephone: (518) 689-1400
+
+Facsimile: (518) 689-1499
+
+grvnielmQgtlaw.com
+
+By: /s/ Nina D. Bovaiian
+
+NINA D. BOYAJIAN
+
+(Admitted Pro Hac Vice)
+
+1840 Century Park East
+
+Los Angeles California
+
+Telephone: (310) 5
+
+Facsimile: (310
+
+bo \*\*aim
+
+riveraa

marker2-fixhub/court-ca-florida-holdings/EFTA02732754/EFTA02732754.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marker2",
+  "doc_id": "EFTA02732754",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 1,
+  "fix_ids": "[\"swarm.html-myst-whitelist\"]",
+  "idempotent": true,
+  "input_sha256": "db52c1b90345cfb6475fb68c40bd7ca7bf202e8ba5f2f1f74d5a2abcbdd3031d",
+  "output_sha256": "1ba894db50862cc67fb4a2f7fdb135be116d41a8d13a149b0b5430a123152421",
+  "page_markers": false,
+  "source_id": "marker2-court-ca-florida-holdings",
+  "text_format": "markdown"
+}