CA Florida Holdings, LLC, Publisher of The Palm Beach Post v. Aronberg, No. 50-2019-CA-014681-XXXX-MB (Fla. 15th Cir. Ct. 2019)

UpdatedSeptember 9, 2026

ByEpsteinWiki

CA Florida Holdings, LLC, Publisher of The Palm Beach Post v. Aronberg was a Florida public access action filed in the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County on November 14, 2019. The publisher of The Palm Beach Post sought access to the testimony, minutes, and other evidence presented to the 2006 Palm Beach County grand jury that investigated Jeffrey Epstein.

The case did not accuse State Attorney Dave Aronberg or court clerk Sharon R. Bock of participating in Epstein’s crimes. They were sued in their official capacities because their offices were alleged to possess, control, or have legal responsibility for the sealed grand jury materials. Joseph Abruzzo later succeeded Bock as clerk and became the named custodian in the appellate proceedings.

The litigation lasted nearly five years and moved through several distinct outcomes. The trial court dismissed one count in 2020, entered final judgment against the Post in 2021, and denied access to the records. Florida’s Fourth District Court of Appeal reversed in 2023, holding that a circuit court had inherent authority to disclose grand jury material when disclosure would further justice. On remand, the trial court again declined to release the materials under the law then in force. The Florida Legislature then enacted HB 117, which created a narrow statutory route for disclosure in circumstances matching the Epstein investigation. The law took effect on July 1, 2024, and the court released approximately 150 pages of transcripts that day.

This was therefore both a press access case and an accountability case. It tested whether grand jury secrecy could continue to shield the record of a prosecution that had become a symbol of unequal justice. It also exposed an institutional problem: even after an appellate court recognized judicial power to consider disclosure, the records remained sealed until lawmakers changed the statute.

Case Snapshot

Field	Detail
Full case name	CA Florida Holdings, LLC, Publisher of The Palm Beach Post v. Dave Aronberg, as State Attorney of Palm Beach County, Florida, and Sharon R. Bock, as Clerk and Comptroller of Palm Beach County, Florida
Trial court docket	50-2019-CA-014681-XXXX-MB
Court	Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida
Original filing date	November 14, 2019
Plaintiff	CA Florida Holdings, LLC, publisher of The Palm Beach Post
Original defendants	Dave Aronberg in his official capacity and Sharon R. Bock in her official capacity
Later clerk defendant	Joseph Abruzzo, successor to Bock
Trial judges involved	Chief Judge Krista Marx, Judge Donald W. Hafele, and Judge Luis Delgado
Records sought	Testimony, minutes, and other evidence presented to the 2006 Palm Beach County grand jury in the Epstein investigation
Statutory focus	Florida Statutes section 905.27
Amended complaint	Filed January 17, 2020
Initial dismissal ruling	Count II dismissed with prejudice on June 8, 2020
Trial court final judgment	December 20, 2021
Appellate case	CA Florida Holdings, LLC v. Aronberg, No. 4D22-293
Reported appellate citation	360 So. 3d 1149 (Fla. 4th DCA 2023)
Appellate decision	Reversed and remanded on May 10, 2023
Legislative response	Florida HB 117, effective July 1, 2024
Final practical result	State grand jury transcripts released July 1, 2024
Primary EFTA complaint record	EFTA02732526
Primary appellate opinion	Fourth District Court of Appeal opinion

The case number identifies a Florida state civil action. It is not a federal case and should not be described as an action in the Southern District of Florida. The related appeal used Fourth District Court of Appeal number 4D22-293.

Key Takeaways

The Post did not seek ordinary executive branch records. It sought judicial grand jury materials protected by unusually strong secrecy rules.
The lawsuit asked who had authority to permit disclosure after the grand jury had completed its work, Epstein had died, and the reasons for the limited 2006 indictment had become a matter of exceptional public concern.
The 2020 dismissal addressed whether section 905.27 itself created a private cause of action. The court did not decide at that stage whether release would further justice.
The 2021 final judgment denied the Post’s remaining declaratory claim. The trial court concluded that its authority was constrained and treated Florida Rule of General Practice and Judicial Administration 2.420 as the proper procedural route.
The Fourth District reversed in 2023. It held that reliance on Rule 2.420 was misplaced and that section 905.27 recognized a circuit court’s inherent authority to disclose grand jury material when disclosure would further justice.
The appellate court did not itself order every page released. It directed the trial court to inspect the materials, decide what would further justice, and protect survivors, witnesses, and uncharged people.
On remand, Judge Luis Delgado obtained and reviewed the materials but declined disclosure under the law then in force. Florida lawmakers responded by passing HB 117.
The July 2024 release resulted from the new statutory authority. It should not be described as if the Post had won an unconditional release order in the original 2019 proceeding.
The released transcripts revealed how prosecutors and grand jurors questioned teenage witnesses and why survivor protection remains essential even when secrecy is lifted.

Survivor Reading Note

This case concerns sealed testimony about sexual abuse of minors. The public release served an accountability purpose, but access does not erase the privacy interests of the girls and women whose experiences appear in the record. Some survivors spoke publicly. Others did not. This article avoids naming private survivors and does not repeat graphic details that are unnecessary to explain the case.

The Fourth District expressly instructed the trial court to protect the identities of victims, witnesses, and people who had not been criminally charged. That direction is part of the holding, not a side issue. Transparency and survivor protection were treated as obligations that had to operate together.

The released testimony may be used to assess official conduct, the presentation made to the grand jury, and the institutional handling of Epstein. It should not be used to shame teenagers, relitigate their private histories, or publish identifying details that add no public value.

Why the 2006 Grand Jury Mattered

The Palm Beach Police Department began investigating Epstein in 2005 after the family of a fourteen year old reported that she had been taken to his Palm Beach residence and paid after a sexualized massage. Police eventually gathered accounts from additional girls and witnesses. Investigators believed the evidence supported serious charges involving minors.

Palm Beach Police Chief Michael Reiter became openly dissatisfied with State Attorney Barry Krischer’s handling of the matter. In a May 1, 2006 letter, Reiter described the treatment of the case as highly unusual and asked Krischer to consider whether disqualification was appropriate. Police sought charges that were substantially more serious than the single count ultimately returned by the grand jury.

Krischer referred the matter to a Palm Beach County grand jury. The July 2006 indictment charged Epstein with felony solicitation of prostitution. It did not charge the minor related sexual offenses the police had sought. Epstein later entered a broader arrangement involving state and federal authorities. In 2008 he pleaded guilty to solicitation of prostitution and procuring a person under eighteen for prostitution. The federal nonprosecution agreement protected Epstein and identified potential coconspirators from federal prosecution in the Southern District of Florida.

The difference between the evidence police said they collected and the narrow grand jury indictment became a central unanswered question. The secrecy of the proceedings meant the public could not determine what witnesses were called, what evidence was presented, how prosecutors framed the case, or whether the process treated teenage victims as people harmed by an adult offender.

The Post’s lawsuit targeted that gap. It did not ask the civil court to retry Epstein. It asked the court to disclose the record needed to evaluate how the criminal justice system had handled him.

The Palm Beach Post’s Investigative Role

The amended complaint described nearly fifteen years of reporting by The Palm Beach Post on Epstein, the Palm Beach investigation, the state prosecution, the federal nonprosecution agreement, civil litigation, work release, and survivor advocacy. It attached a large collection of the newspaper’s prior reporting as Exhibit 1.

The complaint’s standing theory relied partly on the press acting as a public surrogate. It cited decisions recognizing the news media’s role in protecting access to judicial proceedings and gathering information for the public. The Post argued that continued denial of the grand jury material impaired that function.

The paper also argued that its own reporting had already placed much of the surrounding history in the public record. Grand jury secrecy ordinarily protects investigations, encourages candid testimony, prevents flight or tampering, and protects people who are investigated but not charged. The Post contended that several of those interests had diminished because the proceeding had ended years earlier, Epstein was dead, extensive related evidence was already public, and no future state prosecution of Epstein was possible.

The lawsuit grew directly from the newspaper’s investigative project. It was not merely a request to inspect an old court file. The Post sought the missing record necessary to examine whether official decisions protected Epstein, failed survivors, or resulted from legitimate evidentiary judgments.

The complaint itself contained assertions drawn from news reports, public records, civil cases, and other proceedings. Those assertions were the plaintiff’s allegations and advocacy. They should not all be converted into judicial findings merely because they appeared in a verified court filing.

Parties and Official Capacities

CA Florida Holdings, LLC was the legal entity publishing The Palm Beach Post. It brought the action on behalf of its journalists and the public it served.

Dave Aronberg was sued as the elected State Attorney for Florida’s Fifteenth Judicial Circuit. The complaint alleged that his office possessed or controlled responsive materials and that the state attorney had authority connected to grand jury proceedings. Aronberg denied having possession or control of the documents. The Post later dismissed him from the access claim after that custody issue was developed.

Sharon R. Bock was sued as Palm Beach County Clerk and Comptroller. Her office was alleged to possess the sealed court materials. Joseph Abruzzo succeeded Bock in January 2021 and was substituted in his official capacity. The Fourth District later described the clerk as a nominal defendant whose continued role was solely that of records custodian.

The official capacity distinction matters. The action was not a claim that Aronberg, Bock, or Abruzzo personally participated in the 2006 charging decisions. Krischer was the state attorney when the grand jury met. Aronberg and the clerks were named because the Post needed an official respondent and a custodian in order to seek access.

The Post was represented by Greenberg Traurig lawyers including Stephen A. Mendelsohn, Michael J. Grygiel, Nina D. Boyajian, Brigid F. Cech Samole, Katherine M. Clemente, Mark F. Bideau, and Lauren R. Whetstone at different stages. EFTA02732503 admitted Grygiel pro hac vice in November 2019. EFTA02732718 admitted Boyajian in January 2020.

Original Complaint and Records Request

The Post filed its original complaint on November 14, 2019. Before filing, its attorneys had requested the records from the state attorney and clerk. Service on Bock was documented in EFTA02732505.

The action sought the testimony, minutes, and other evidence presented to the 2006 grand jury. The requested material was broader than a final indictment. It included the evidentiary presentation and witness testimony that could show what the grand jury was told and how the prosecution framed its inquiry.

The Post relied on Florida Statutes section 905.27, particularly the exception permitting court ordered disclosure for the purpose of furthering justice. It also invoked the circuit court’s inherent supervisory authority over a grand jury it had empaneled.

The complaint acknowledged the sensitivity of the record. The Post stated that it did not object to in camera review and appropriate redactions protecting victims who wished to remain anonymous. An in camera review would allow the judge to examine the sealed material privately before determining what, if anything, could be released.

The original defendants moved to dismiss. Aronberg’s December 6 motion, EFTA02732511, argued that section 905.27 did not create a cause of action and that the statute limited the use of disclosed testimony to the prosecution or defense of a civil or criminal case. He also argued that his office did not possess or control the requested records.

Those were litigation positions. The motion did not establish the historical adequacy of the 2006 presentation or prove that continued secrecy was necessary.

First Amended Complaint

The Post filed its first amended complaint on January 17, 2020. The pleading and its attached reporting appear in EFTA02732526. The complaint was twenty three pages before its lengthy exhibit and pleaded two counts.

Count I sought declaratory relief. The Post invoked chapter 86 of the Florida Statutes and asked the court to declare that section 905.27 and the court’s inherent authority permitted access. It also sought a declaration that it could use disclosed materials to inform the public rather than only within another pending civil or criminal case.

Count II sought relief directly under section 905.27. The Post asked the court to order the state attorney and clerk to file copies of the grand jury testimony, minutes, and evidence for in camera inspection and later public release. It alleged that the 2006 presentation had been truncated in a way that prevented indictment for more serious crimes.

The amended complaint argued that disclosure would further justice in two possible ways. It could show that Epstein received treatment comparable to similarly situated defendants, or it could expose official choices that gave him improper leniency. Either result, the Post argued, would allow informed evaluation of the justice system.

The pleading emphasized that the request was not indifferent to survivor privacy. It invited redaction and judicial screening. The Post’s proposed remedy therefore combined disclosure with protection rather than demanding publication of every identifying detail.

Motions to Dismiss the Amended Complaint

Both official defendants moved to dismiss Count II. They argued that section 905.27 governed secrecy and exceptions but did not create a freestanding private right of action allowing the newspaper to sue the state attorney and clerk.

The Post opposed dismissal. Its March 12 filing, EFTA02732754, argued that the state attorney was extending the general secrecy rule too far. It maintained that the court could further justice and restore public confidence by allowing a carefully managed release.

The pandemic delayed the hearing. EFTA02732793 records the Post’s March 2020 request for a continuance during the public health emergency.

Chief Judge Krista Marx heard the motions because the dispute involved records of a Palm Beach County grand jury. On June 8, 2020, she dismissed Count II with prejudice in EFTA02732805.

The ruling was narrow but decisive. The court concluded that the legislature had not created a private cause of action under section 905.27. The statute primarily imposed secrecy and criminalized unauthorized disclosure. Reading it to authorize a direct civil action against custodians would conflict with its text.

The court expressly did not decide whether release would further justice. It also did not say the Post had no possible mechanism to obtain access. It held only that Count II’s direct statutory cause of action was not the proper mechanism. Count I for declaratory relief remained pending.

Discovery and Custody of the Records

After Count II was dismissed, the parties litigated the remaining declaratory claim and the custody issue. The Post served requests for production in July 2020. EFTA02732815 and EFTA02732819 document those requests.

Aronberg maintained that the state attorney’s office did not possess or control the sealed grand jury materials. The clerk admitted custody. That difference eventually changed the party structure. The Post dropped Aronberg as an access defendant, and the clerk remained as the nominal custodian.

This procedural change should not be confused with a concession about the conduct of the 2006 state attorney’s office. The custody question concerned who held the records in 2019 and later. The accountability question concerned how Krischer’s office handled the 2006 investigation.

Aronberg separately sought attorneys’ fees under Florida Statutes section 57.105, contending that the claims against him lacked legal or factual support. The Post disputed that characterization and argued that the case presented legitimate questions of exceptional public importance. The fee dispute continued even after Aronberg left the principal access litigation.

The Post’s Motion for Summary Judgment

On April 22, 2021, the Post moved for summary judgment on Count I. The motion appears at EFTA02733046. It argued that the material historical facts were not genuinely disputed and that the court could decide the disclosure question as a matter of law.

The Post described Epstein as a wealthy and influential offender who received extraordinary leniency. It argued that public access would allow scrutiny of the grand jury presentation and would address damage to confidence in equal enforcement of criminal law.

The clerk opposed summary judgment in EFTA02734365. The clerk emphasized statutory confidentiality, limits on judicial power, and Florida Rule of General Practice and Judicial Administration 2.420. Although the clerk was a nominal custodian, counsel argued that the court lacked the authority or procedural basis for the release sought.

The Post replied in EFTA02734396. It argued that the clerk had shifted from an earlier position that it was not trying to block access. More importantly, the Post maintained that the unusual subject matter was central to the exercise of judicial discretion. A request involving a completed proceeding, a deceased subject, acknowledged public concern, and alleged systemic failure could not be evaluated as if context were irrelevant.

Judge Donald W. Hafele heard nearly two hours of argument on October 22, 2021. The question before him was not whether Epstein had committed every act described in the press record. It was whether the circuit court could and should authorize disclosure of the grand jury materials.

December 2021 Final Judgment

Judge Hafele entered final judgment on December 20, 2021. The ruling appears in EFTA02734407. Because Count II had already been dismissed, disposition of Count I ended the trial court phase.

The court recognized the public importance of Epstein’s conduct, the resolution of the 2006 state and potential federal charges, the 2008 guilty plea, and his incarceration. It acknowledged that disclosure might fit a broad social understanding of furthering justice.

Even so, the court concluded that its inherent authority was constrained by section 905.27. It interpreted the statutory scheme as limiting disclosure to use in a pending civil or criminal action. It also treated Rule 2.420(j) as the proper procedure for obtaining confidential court records.

The judgment therefore denied the Post’s request and dismissed the remaining complaint. It did not find that transparency lacked public value. It found that the court lacked sufficient legal authority through the route the Post had pursued.

The distinction is important. The Post lost because of the trial court’s interpretation of power and procedure, not because a judge found that the 2006 grand jury presentation had been fair or complete.

The clerk briefly moved to amend language in the final judgment and then withdrew that request in EFTA02734469. The Post appealed.

Fourth District Court of Appeal Decision

The Fourth District decided the appeal on May 10, 2023. The reported decision is CA Florida Holdings, LLC v. Aronberg, 360 So. 3d 1149 (Fla. 4th DCA 2023). The official appellate opinion reversed and remanded.

The court first held that reliance on Rule 2.420 was misplaced. The Post had not pleaded a claim under that rule, and the clerk told the appellate court that the rule did not apply because there was no ongoing underlying criminal or civil matter.

The appellate court then rejected the trial court’s restrictive reading of section 905.27. Subsection one prohibited specified people from disclosing grand jury testimony and evidence unless a court required disclosure for one of three purposes, including furthering justice. The Fourth District read that language as recognizing the court’s authority to order disclosure.

Subsection two did not erase that power. The appellate court read it as prohibiting unauthorized disclosure by others and directing who could receive material when disclosure was ordered for use in pending litigation. It did not read the subsection as eliminating every other exercise of authority under the furthering justice exception.

The court held that the circuit judge was required to determine whether disclosure would in fact further justice. It directed an in camera examination and allowed disclosure of material satisfying that standard. It also authorized denial of material that would not further justice.

Crucially, the court required protective steps for victims, witnesses, and uncharged people. Its decision was not a command to publish the record without screening.

The Craig Factors and Protective Review

The Fourth District drew guidance from In re Petition of Craig, a federal appellate decision addressing disclosure in special circumstances. It identified nine considerations for the trial court.

The identity of the party seeking disclosure.
Whether the subject of the grand jury proceeding or the government opposed disclosure.
Why disclosure was sought.
What specific information was requested.
How much time had passed since the proceeding.
The current status of the principals and their families.
The degree to which the material had already become public.
Whether living witnesses might be affected.
The remaining need for secrecy in that particular case.

The list was not rigid. It provided a framework for a fact sensitive exercise of discretion. Applied to Epstein, the factors included the newspaper’s accountability role, the age of the proceeding, Epstein’s death, the extraordinary public record already available, the interests of living survivors, and the risk of unfairly identifying uncharged people.

The factors explain why the appellate victory was significant without being absolute. The Post won the right to a lawful review. It did not receive an automatic entitlement to every unredacted page.

Certified Question and Separate Opinions

Because the issue could affect future requests for Florida grand jury records, the Fourth District certified a question of great public importance asking whether a circuit court has inherent authority to disclose grand jury evidence to further justice under section 905.27.

Judge Cory Ciklin concurred specially. He emphasized the judiciary’s inherent control over grand jury records and the historic relationship between Florida courts and grand juries. He would have treated that inherent judicial authority as independent of the statute and proposed a broader question concerning the policies and procedures courts should use when considering disclosure.

Judge Jeffrey Kuntz also concurred specially. He agreed that Rule 2.420 was not a proper basis for denial and that controlling authority allowed disclosure when justice required. He nonetheless expressed concern that the statutory text appeared narrower than some prior decisions had treated it.

The separate opinions reveal the unresolved legal tension. The judges agreed on reversal, but not entirely on whether the authority came from section 905.27, inherent judicial power, or the interaction between them.

Proceedings on Remand

After remand, the trial court began the review process contemplated by the appellate decision. A Florida Senate staff analysis records that on June 9, 2023, the court ordered the Palm Beach County clerk to deliver the grand jury materials for in camera inspection.

The delivered materials included audio recordings that needed transcription. On June 29, 2023, the court directed that transcripts be prepared at the Post’s expense. This step demonstrates that the sealed record was not already a clean, publication ready court transcript.

Judge Luis Delgado reviewed the materials. On February 29, 2024, he denied release under the existing statute. He concluded that disclosure would not further justice as the law then prescribed. The decision did not erase the Fourth District’s recognition of judicial authority. It was the trial court’s discretionary application of the standard after inspection.

The timing was remarkable. On the same day, Governor Ron DeSantis signed legislation designed to create a clearer statutory route for this category of records. The case had exposed a gap between broad public interest and the legal mechanisms available to satisfy it.

HB 117 and the Change in Florida Law

The Florida Legislature considered companion proposals addressing grand jury disclosure. The enacted measure was CS/HB 117, sponsored by Representative Peggy Gossett Seidman and supported across party lines.

The Florida House passed the bill 119 to 0 on February 15, 2024. The Senate passed it on February 21. Governor DeSantis signed it on February 29. It took effect July 1, 2024.

The law amended section 905.27 to recognize a public interest route for media or interested person requests when specified conditions are present. The conditions included a deceased subject, an inquiry involving sexual activity with a minor, prior disclosure by court order, and notice to the state attorney. The court retained authority to limit disclosure and apply redactions.

The Governor’s signing announcement expressly connected HB 117 to the 2006 Epstein grand jury. The Florida House bill page supplies the official legislative history and final text materials.

The legislation did more than resolve a single records dispute. It altered Florida law in response to a case that had shown how existing secrecy rules could outlive their traditional purposes. It also preserved judicial screening rather than making grand jury material automatically public whenever public curiosity existed.

July 2024 Release

On July 1, 2024, the effective date of HB 117, Judge Delgado released approximately 150 pages of the 2006 grand jury transcripts. The release was the practical result the Post had sought since 2019.

The transcripts showed that the grand jury heard testimony from Palm Beach Police Detective Joseph Recarey and teenage witnesses. They documented allegations of sexual abuse, payments, and recruitment. They also showed questioning that focused on the conduct and credibility of teenage witnesses in ways that drew intense criticism after publication.

Judge Delgado warned that the contents would be disturbing and described the conduct discussed in the testimony as criminal. Contemporary reporting and later commentary focused on the apparent inversion of responsibility, with minors subjected to skeptical or blaming questions while Epstein’s adult conduct received comparatively limited examination.

The release did not prove every allegation ever made about Epstein or identify every person associated with him. It illuminated the evidence and questioning placed before one state grand jury in 2006. It should be interpreted within that defined scope.

The state transcript release is also distinct from later efforts to obtain federal grand jury records. Florida’s state law change did not automatically govern federal grand juries, which operate under federal law and Rule 6(e) of the Federal Rules of Criminal Procedure.

Attorneys’ Fees and Sanctions Dispute

Aronberg sought attorneys’ fees against the Post under Florida Statutes section 57.105. He argued that the action against him lacked support because his office did not possess the grand jury records and because the legal theory was deficient.

The Post opposed sanctions. It argued that its factual and legal investigation was substantial, that it had a good faith basis to name the state attorney initially, and that the novel public access questions were not frivolous. The evidentiary hearing occurred over two days in September 2022. The transcript begins at EFTA02734651, and the Post’s written closing argument appears at EFTA02734959.

On January 31, 2023, Judge Delgado denied the amended fee motion. The order appears at EFTA02735064. Aronberg moved to alter or amend and later filed a notice of appeal, EFTA02735075.

The fee ruling is separate from the merits appeal that produced the reported 2023 disclosure decision. It should not be conflated with appellate case 4D22-293.

What the Case Established

The Fourth District established that Florida circuit courts possess authority to consider disclosure of grand jury materials when disclosure would further justice. A court cannot avoid that inquiry merely by applying Rule 2.420 to a claim not brought under that rule or by reading section 905.27 as categorically limited to other pending litigation.

The decision also established that review must be particularized. The trial court must inspect the material and determine which disclosures further justice. It can withhold material that does not meet that standard.

The decision required attention to privacy and fairness. Victims, witnesses, and uncharged people were entitled to protection. Public importance did not authorize careless publication of identities.

The case did not establish that every historical grand jury record in Florida is publicly accessible. It did not abolish grand jury secrecy. It did not create an automatic press right to unredacted testimony. Its holding concerned judicial authority and a discretionary process.

The later legislation created an additional statutory route tailored to circumstances that included the Epstein inquiry. The records were released under that changed legal environment.

Legal and Historical Significance

This case is one of the clearest examples of investigative journalism producing both legal precedent and legislative change. The Post’s reporting identified the secrecy problem. Its lawsuit forced courts to define their authority. The appellate ruling corrected an unduly restrictive procedural approach. The continued impasse then gave lawmakers a concrete reason to amend the statute.

For survivors, the significance is more than doctrinal. The sealed record contained evidence of how teenage witnesses were presented and questioned. Without disclosure, the public could debate the 2006 outcome while lacking the material needed to examine the process itself.

For courts, the case illustrates the tension between transparency and the durable reasons for grand jury secrecy. Witness candor, protection from retaliation, reputational fairness, and investigative integrity remain legitimate concerns. Yet secrecy can also conceal institutional failure after the original reasons have diminished.

For journalists and researchers, the case supplies a disciplined model. Ask for a defined set of records. Identify the public interest. Accept in camera review. Protect survivors and uncharged people. Distinguish the desire for accountability from indiscriminate disclosure.

Evidence and Filing Index

EFTA record	Date	Document	Relevance
EFTA02732496	November 15, 2019	Grygiel admission motion	Confirms original complaint had been filed and identifies counsel
EFTA02732503	November 19, 2019	Pro hac vice order	Admits Michael J. Grygiel for the Post
EFTA02732505	November 25, 2019	Return of service notice	Documents service on Clerk Sharon R. Bock
EFTA02732511	December 6, 2019	Aronberg motion to dismiss	Argues no statutory cause of action and denies custody
EFTA02732518	January 16, 2020	Hearing order	Sets initial dismissal hearing
EFTA02732526	January 17, 2020	First amended complaint and Exhibit 1	Primary statement of claims, history, standing, and requested relief
EFTA02732718	January 22, 2020	Pro hac vice order	Admits Nina D. Boyajian for the Post
EFTA02732754	March 12, 2020	Post opposition to Aronberg motion	Defends statutory and inherent authority theories
EFTA02732793	March 18, 2020	Continuance motion	Records pandemic related hearing delay
EFTA02732805	June 8, 2020	Order dismissing Count II	Holds section 905.27 does not itself create a private cause of action
EFTA02732815	July 10, 2020	Request for production	Part of discovery regarding custody and responsive records
EFTA02732819	July 24, 2020	Amended request for production	Refines the Post’s document request
EFTA02733046	April 22, 2021	Post motion for summary judgment	Seeks judgment on declaratory access claim
EFTA02734365	October 1, 2021	Clerk opposition	Argues against disclosure and invokes confidentiality rules
EFTA02734396	October 13, 2021	Post reply	Defends inherent authority and the relevance of the extraordinary context
EFTA02734407	December 20, 2021	Final judgment	Denies remaining claim and ends initial trial court phase
EFTA02734469	January 26, 2022	Withdrawal notice	Clerk withdraws motion to amend final judgment
EFTA02734637	September 1, 2022	Joint exhibit list	Identifies evidence for fee hearing
EFTA02734651	September 2022	Fee hearing transcript	Records evidentiary hearing on Aronberg’s sanctions request
EFTA02734959	October 6, 2022	Post closing argument	Opposes fees and describes prefiling investigation
EFTA02735064	January 31, 2023	Order denying fee motion	Rejects Aronberg’s amended request for section 57.105 fees
EFTA02735075	March 1, 2023	Aronberg notice of appeal	Appeals fee ruling, separate from main access appeal

Fact Check

Was this a lawsuit against Epstein? No. Epstein was not a party. The case sought access to records of the 2006 grand jury investigation.

Did the Post sue Dave Aronberg for making the 2006 charging decisions? No. Barry Krischer was state attorney in 2006. Aronberg was sued in his official capacity as the current state attorney and alleged records holder.

Did Aronberg admit possessing the records? No. He denied possession or control. The clerk admitted custody.

Did the 2020 order reject the public interest in disclosure? No. It dismissed Count II because section 905.27 did not create a private cause of action. It expressly left open whether release would further justice.

Did the Post win in the trial court in 2021? No. The court entered final judgment against it.

Did the Post win its appeal? Yes, in part. The Fourth District reversed and required the trial court to conduct the proper furthering justice analysis.

Did the appellate court order every page released? No. It ordered review and authorized tailored disclosure, with protection for victims, witnesses, and uncharged people.

Did the trial judge release the records immediately after remand? No. Judge Delgado obtained and reviewed them, then denied release in February 2024 under the law then in effect.

Why were the transcripts released in July 2024? Florida enacted HB 117, which took effect July 1 and supplied a clearer statutory basis for release under circumstances matching the Epstein proceeding.

Were the state transcripts the same as federal Epstein grand jury records? No. They came from the 2006 Palm Beach County state grand jury. Federal grand juries are governed by different law.

Was the docket checked for this article? Yes. The EFTA court record, the official Fourth District opinion, Florida legislative materials, and release reporting were checked through September 9, 2026.

Questions Still Unanswered

Why did the 2006 state attorney’s office present only a limited selection of the available witnesses and evidence?
Who decided which witnesses would appear and what questioning strategy prosecutors would use?
What communications occurred between Krischer’s office and Epstein’s defense team before the final grand jury presentation?
Were all relevant documents and physical evidence shown to the grand jury?
What institutional safeguards have Palm Beach prosecutors adopted to prevent minor victims from being treated as responsible for an adult offender’s conduct?
What was the final outcome of Aronberg’s separate appeal concerning attorneys’ fees?
Are any state grand jury exhibits still withheld, and what specific legal basis supports each continued withholding?
How will Florida courts apply the amended statute to future historically important cases without exposing survivors or unfairly damaging uncharged people?

Research Limitations

The EFTA collection preserves a substantial portion of the trial court filings, but OCR errors affect names, dates, symbols, and page continuity. Researchers should compare extracted text with the scanned image before quoting exact language.

The amended complaint attached many historical newspaper articles. Their inclusion as an exhibit proves what the Post submitted to support its case. It does not transform every reported statement into a court finding.

The official 2023 appellate opinion is the strongest source for the procedural history through final judgment and appeal. Florida legislative analyses are the strongest source for the remand orders and the development of HB 117. Contemporary reporting documents the February and July 2024 events.

A targeted search did not locate a verified article from the established EpsteinWiki sleuth Substack list devoted specifically to this docket. No unrelated Substack is added simply to satisfy a source category.

Related EpsteinWiki Pages

Sources

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Florida legislative and government sources

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PostedDecember 19, 2025