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House Oversight — Estate records

HOUSE_OVERSIGHT_029405

Radar Online v FBI (Epstein)

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Case 1:17-cv-03956-PGG Document 1 Filed 05/25/17 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
------------------------------------------------------------------------X
RADAR ONLINE LLC :
Plaintiff, :
- v. - :
FEDERAL BUREAU OF INVESTIGATION, :
Defendant. :
------------------------------------------------------------------------X
COMPLAINT
1. This is an action under the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), to order
the production of Federal Bureau of Investigation (“FBI”) records concerning the agency’s
investigation and prosecution of financier Jeffrey Edward Epstein (“Epstein”) for sexually
trafficking underage women. Defendant FBI has withheld these records despite a properly
filed FOIA request.
PARTIES
2. Plaintiff Radar Online LLC (“Radar”) is an online investigative news outlet read by millions.
3. The FBI, a component of the Department of Justice, is an agency of the United States with
possession and control of the records sought by Plaintiff.
JURISDICTION AND VENUE
4. This court has jurisdiction over this action pursuant to 28 U.S.C. § 1331 and 5 U.S.C. §
552(a)(4)(B).
5. Radar’s principal place of business is New York City and therefore venue is appropriate
1
Case 1:17-cv-03956-PGG Document 1 Filed 05/25/17 Page 2 of 3
under 5 U.S.C. § 552(a)(4)(B).
FACTS
Background of Request
6. Jeffrey Epstein is a billionaire financier, philanthropist, and sex offender. In 2005, Epstein
became the subject of an undercover sex trafficking investigation by Palm Beach, Florida
police and the FBI. Dozens of underage women were trafficked by Epstein to perform sexual
acts on him as well as his friends.
7. Despite the gravity of his offenses, the Department of Justice allowed Epstein to plead guilty
to a single count of soliciting prostitution from a minor under Florida state law, and serve
only 13 months in prison. In addition, prosecutors agreed not to bring charges against
Epstein’s alleged co-conspirators.
8. Mr. Epstein en

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