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