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use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of 550 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it
rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio
The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available
rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio
The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available
rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio
The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it will
ll times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, , was an adult female. 9. At all times material to this cause of action, the Defe
The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available
Entities connected to both the State of New York and Douglas Oil Co.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSONDarren Indyke
PERSONLeon Black
PERSONthe Southern District
LOCATION
New York
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Samantha Power
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSON
Eric Holder
PERSON
Michael Douglas
PERSONJack Goldberger
PERSON
New York State
LOCATION
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Jeff Sessions
PERSON