Case 1:17-cv-03956-PGG Document1 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 enjoyed close ties to numerous prominent political figures, including former President Bill Clinton and Prince Andrew of the British Royal Family, leading many to speculate whether he received preferential treatment from authorities. See Goodnough, Abby, “Questions of Preferential Treatment Are Raised in Florida Sex Case,” The New York Times, Sep. 3, 2006. (Exhibit A) FOIA Request and Constructive Denial 9. On April 20, 2017 James Robertson, a Senior Editor for The National Enquirer and sister- publication Radar Online, submitted a FOIA request to the FBI for all documents relating to the investigation and prosecution of Epstein (the “Request”). (Exhibit B) 10. Robertson requested expedited processing because Epstein’s crimes are the subject of widespread and exceptional media interest, and raise questions about the government's integrity, which affects public confidence; specifically, whether Mr. Epstein received 2 HOUSE_OVERSIGHT_029406