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f time that has passed, and the widely reported nature ofthis miscarriage ofjustice, 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 juty’s functions are ended, disclosure is wholly proper where the ends ofjustice require it.”). 112. Co
ed bail and was placed into pretrial detention at the federal 4 Metropolitan Correction Center in lower Manhattan. Appendix at 3 (OPR Report, p. iv). Greenberg Traurig, PA ■401 East Las Olas Boulevard, Suite 2000 ■Ft. Lauderdale, Florida 33301 ■Tel 954:765.0500 ■Fax 954.765.1477 ■www.etiaw.com 14 ACTIVE 53842030v7 B
I I inspection, it can be made available to The Palm Beach Post and the.publicjon an expedited basis. Dated; April 22, 2021 Respectfully submitted, ! GREENBERG TRAURIG, P.A. Attorneysfor CA Florida Holdings, LLC, Publisher ofThe Palm Beach Post Stephen A; Mendelsohn, Esq. 401 East Las Olas Blvd., Ste. 2000 Fort Laud
de by this Court is whether, as a matter of law, the grand jury transcripts that allowed Epstein’s crimes to remain put of the public eye and cloaked Greenberg Traurig, PA. ■401 East las Olas Boulevard, Suite 2O0C Party JOINT ACT/VE 53842030v7 1954.765.0500 ■Fax 954.765.1477 ■www.etlaw.cr Joint Exhibit ID#_J28 EV#JZ
of his co-conspirators, and the identities of the victims have already been exposed, the need for grand jury secrecy is no more. See United States v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) (“[A]fter the grand jury’s functions are ended, disclosure is wholly proper where the ends ofjustice require it.”). WHEREFO
basis, and grant any other and further equitable or legal relief the Court deems just and proper. j Dated: January 17, 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 Ra
of his co-conspirators, and the identities of the victims have already been exposed, the need for grand jury secrecy is no more. See United States v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) (“[A]fter the grand jury’s functions are ended, disclosure is wholly proper where the ends ofjustice require it.”). WHEREFO
ted basis, and grant any other and further equitable of legal relief the Court deems just and proper. Dated: January 17, 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 Ra
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