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Page 1 Filing # 201184781 E-Filed 06/24/2024 01:09:07 PM
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,
vs.
Case No. 50-2019-CA-014681-AG
PY
SHARON BOCK, as Clerk and Comptroller
of Palm Beach County, Florida,
CO
Defendant.
_________________________________/
D
UNOPPOSED MOTION FOR LIMITED INTERVENTION
IE
American Broadcasting Companies, Inc.; Bloomberg L.P., the publisher of
IF
Bloomberg News; Cable News Network, Inc.; CMG Media Corporation stations
RT
WFTV/WRDQ (Orlando) and WJAX/WFOX (Jacksonville); Court TV Media, LLC;
Dow Jones & Company, Inc.; Gray Media Group, Inc. stations WCJB (Gainesville),
CE
WCTV (Tallahassee-Thomasville), WFLX (West Pam Beach-Ft. Pierce), WJHG-TV
(Panama City) and WWSB (Tampa-St. Petersburg (Sarasota)); NBCUniversal Media,
A
LLC; The New York Times Company; Orlando Sentinel Media Group; Scripps Media,
T
Inc. and its stations WPTV-TV (West Palm Beach), WFTS-TV (Tampa), WFTX-TV (Ft.
O
Myers-Naples), WSFL-TV (Miami), and WTXL-TV (Tallahassee); Sun Sentinel Media
N
Group; Telemundo Network Group LLC; and Univision Networks & Studios, Inc.
(collectively, the “Media Intervenors”) move to intervene in this action for the limited
purpose of asserting their right of access, pursuant to Section 905.27, Florida Statutes, to
any released grand jury materials involving Jeffrey Epstein, and state as follows:
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 06/24/2024 01:09:07 PMPage 2 1.
The Media Intervenors are national, regional and local news and media
organizations that publish and broadcast information throughout the United States,
including Florida. Each of the Media Intervenors has reported on the controversies
surrounding Mr. Epstein and employ public and court records as important newsgathering
sources.
The Plaintiff in this case, The Palm Beach Post, has sought to obtain grand
PY
2.
CO
jury materials relating to Mr. Epstein. The controversy surrounding Mr. Epstein, the
criminal investigation into his alleged sex trafficking of minors, and the resulting plea
D
deal, are well known to the Court.
On February 29, 2024, the Court entered an order ruling that under the
IE
3.
IF
current iteration of Section 905.27, Florida Statutes, releasing the grand jury materials
RT
would not further the interests of justice. [DIN 184] Yet the court explained that, pursuant
to an amendment of Section 905.27 slated to take effect on July 1, 2024, the Court would
CE
entertain a motion for reconsideration once the statute changes.
4.
On June 12, 2024, The Palm Beach Post (“Post”) filed a Motion for
A
Reconsideration of the Trial Court’s February 29, 2024 Order. [DIN 208] The motion
T
explained that the amendments to Section 905.27 were intended to remove all prior
O
statutory hurdles to disclosure of the Epstein grand jury materials and that access to the
N
grand jury materials serves the public interest.
5.
Like the Post, Media Intervenors fulfill the requirements of Section
905.27(2)(c), as amended. They are requesting disclosure of grand jury materials as
members of the media and, as explained in the Post’s motion, all statutory conditions for
release have been met: Mr. Epstein was the target of grand jury testimony relating to
2Page 3 criminal sexual activities between and adult and a minor, Mr. Epstein is deceased, the
Fourth District Court of Appeals ordered release of the grand jury materials for an in
camera review (which has been completed), and the current State Attorney was a party to
this litigation and ultimately adopted a neutral position concerning disclosure.
6.
As such, Media Intervenors seek to intervene in this matter for the limited
PY
purpose of procuring access to any materials that, upon reconsideration, the Court orders
CO
to be disclosed.
7.
The Media Intervenors possess standing to intervene in this matter, see
D
Miami Herald Publ’g Co. v. McIntosh, 340 So. 2d 904, 908 (Fla. 1976), for the purpose
IE
of “imparting a more complete understanding to the public of the judicial system.” Miami
IF
Herald Publishing Co. v. Lewis, 426 So.2d 1, 6 (Fla. 1983). See also WESH Television,
RT
Inc. v. Freeman, 691 So. 2d 532, 535 (Fla. 5th DCA 1997) (media must be permitted to
intervene and be heard on motion seeking access to public records); News-Press Publ’g
CE
Co. v. State, 345 so. 2d 865, 866 (Fla. 2d DCA 1977) (media permitted to intervene with
respect to order that had the “practical effect of making it more difficult for the press to
A
obtain information about the case which it may wish to publish”). 1
The Media Intervenors communicated with counsel for both Plaintiff and
T
8.
N
O
Defendant, neither of whom oppose the relief sought in this motion.
1
By an agreed order dated February 28, 2024, the Court permitted the Associated Press
to intervene in this action. [DIN 183] The Court similarly entered an agreed order on
March 5, 2024, granting the McClatchy Company, LLC’s motion to intervene. [DIN 187]
3Page 4 WHEREFORE, the Media Intervenors seek intervention in this case for the
limited purpose of obtaining access to the grand jury materials related to Mr. Epstein.
Respectfully submitted,
SHULLMAN FUGATE PLLC
IE
D
CO
PY
/s/ Rachel E. Fugate
Rachel E. Fugate
Florida Bar No. 0144029
rfugate@shullmanfugate.com
Deanna K. Shullman
Florida Bar No. 514462
dshullman@shullmanfugate.com
Minch Minchin
Florida Bar No. 1015950
mminchin@shullmanfugate.com
2101 Vista Parkway Suite 4006
West Palm Beach, Florida 33411
Tel: (813) 935-5098
IF
Attorneys for the Media Intervenors
RT
CERTIFICATE OF SERVICE
CE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via the Florida Courts E-Filing Portal this 24th day of June 2024, which will
A
provide service to all counsel of record.
N
O
T
/s/ Rachel E. Fugate
Attorney for the Media Intervenors
4
PDF Page 1
PlainSite Cover Page
PDF Page 2
Filing # 201184781 E-Filed 06/24/2024 01:09:07 PM
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,
vs.
Case No. 50-2019-CA-014681-AG
PY
SHARON BOCK, as Clerk and Comptroller
of Palm Beach County, Florida,
CO
Defendant.
_________________________________/
D
UNOPPOSED MOTION FOR LIMITED INTERVENTION
IE
American Broadcasting Companies, Inc.; Bloomberg L.P., the publisher of
IF
Bloomberg News; Cable News Network, Inc.; CMG Media Corporation stations
RT
WFTV/WRDQ (Orlando) and WJAX/WFOX (Jacksonville); Court TV Media, LLC;
Dow Jones & Company, Inc.; Gray Media Group, Inc. stations WCJB (Gainesville),
CE
WCTV (Tallahassee-Thomasville), WFLX (West Pam Beach-Ft. Pierce), WJHG-TV
(Panama City) and WWSB (Tampa-St. Petersburg (Sarasota)); NBCUniversal Media,
A
LLC; The New York Times Company; Orlando Sentinel Media Group; Scripps Media,
T
Inc. and its stations WPTV-TV (West Palm Beach), WFTS-TV (Tampa), WFTX-TV (Ft.
O
Myers-Naples), WSFL-TV (Miami), and WTXL-TV (Tallahassee); Sun Sentinel Media
N
Group; Telemundo Network Group LLC; and Univision Networks & Studios, Inc.
(collectively, the “Media Intervenors”) move to intervene in this action for the limited
purpose of asserting their right of access, pursuant to Section 905.27, Florida Statutes, to
any released grand jury materials involving Jeffrey Epstein, and state as follows:
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 06/24/2024 01:09:07 PM
PDF Page 3
1.
The Media Intervenors are national, regional and local news and media
organizations that publish and broadcast information throughout the United States,
including Florida. Each of the Media Intervenors has reported on the controversies
surrounding Mr. Epstein and employ public and court records as important newsgathering
sources.
The Plaintiff in this case, The Palm Beach Post, has sought to obtain grand
PY
2.
CO
jury materials relating to Mr. Epstein. The controversy surrounding Mr. Epstein, the
criminal investigation into his alleged sex trafficking of minors, and the resulting plea
D
deal, are well known to the Court.
On February 29, 2024, the Court entered an order ruling that under the
IE
3.
IF
current iteration of Section 905.27, Florida Statutes, releasing the grand jury materials
RT
would not further the interests of justice. [DIN 184] Yet the court explained that, pursuant
to an amendment of Section 905.27 slated to take effect on July 1, 2024, the Court would
CE
entertain a motion for reconsideration once the statute changes.
4.
On June 12, 2024, The Palm Beach Post (“Post”) filed a Motion for
A
Reconsideration of the Trial Court’s February 29, 2024 Order. [DIN 208] The motion
T
explained that the amendments to Section 905.27 were intended to remove all prior
O
statutory hurdles to disclosure of the Epstein grand jury materials and that access to the
N
grand jury materials serves the public interest.
5.
Like the Post, Media Intervenors fulfill the requirements of Section
905.27(2)(c), as amended. They are requesting disclosure of grand jury materials as
members of the media and, as explained in the Post’s motion, all statutory conditions for
release have been met: Mr. Epstein was the target of grand jury testimony relating to
2
PDF Page 4
criminal sexual activities between and adult and a minor, Mr. Epstein is deceased, the
Fourth District Court of Appeals ordered release of the grand jury materials for an in
camera review (which has been completed), and the current State Attorney was a party to
this litigation and ultimately adopted a neutral position concerning disclosure.
6.
As such, Media Intervenors seek to intervene in this matter for the limited
PY
purpose of procuring access to any materials that, upon reconsideration, the Court orders
CO
to be disclosed.
7.
The Media Intervenors possess standing to intervene in this matter, see
D
Miami Herald Publ’g Co. v. McIntosh, 340 So. 2d 904, 908 (Fla. 1976), for the purpose
IE
of “imparting a more complete understanding to the public of the judicial system.” Miami
IF
Herald Publishing Co. v. Lewis, 426 So.2d 1, 6 (Fla. 1983). See also WESH Television,
RT
Inc. v. Freeman, 691 So. 2d 532, 535 (Fla. 5th DCA 1997) (media must be permitted to
intervene and be heard on motion seeking access to public records); News-Press Publ’g
CE
Co. v. State, 345 so. 2d 865, 866 (Fla. 2d DCA 1977) (media permitted to intervene with
respect to order that had the “practical effect of making it more difficult for the press to
A
obtain information about the case which it may wish to publish”). 1
The Media Intervenors communicated with counsel for both Plaintiff and
T
8.
N
O
Defendant, neither of whom oppose the relief sought in this motion.
1
By an agreed order dated February 28, 2024, the Court permitted the Associated Press
to intervene in this action. [DIN 183] The Court similarly entered an agreed order on
March 5, 2024, granting the McClatchy Company, LLC’s motion to intervene. [DIN 187]
3
PDF Page 5
WHEREFORE, the Media Intervenors seek intervention in this case for the
limited purpose of obtaining access to the grand jury materials related to Mr. Epstein.
Respectfully submitted,
SHULLMAN FUGATE PLLC
IE
D
CO
PY
/s/ Rachel E. Fugate
Rachel E. Fugate
Florida Bar No. 0144029
rfugate@shullmanfugate.com
Deanna K. Shullman
Florida Bar No. 514462
dshullman@shullmanfugate.com
Minch Minchin
Florida Bar No. 1015950
mminchin@shullmanfugate.com
2101 Vista Parkway Suite 4006
West Palm Beach, Florida 33411
Tel: (813) 935-5098
IF
Attorneys for the Media Intervenors
RT
CERTIFICATE OF SERVICE
CE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via the Florida Courts E-Filing Portal this 24th day of June 2024, which will
A
provide service to all counsel of record.
N
O
T
/s/ Rachel E. Fugate
Attorney for the Media Intervenors
4
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