Case 1:17-cv-03956-PGG Document1 Filed 05/25/17 Page1lof3
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Case 1:17-cv-03956-PGG Document1 Filed 05/25/17 Page1lof3
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
ween enn eee eee X
RADAR ONLINE LLC
Plaintiff,
-vV.-
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
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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
HOUSE_OVERSIGHT_029405
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