COMPLAINT

  1. Jeffrey Epstein and his co-conspirators engaged in widespread trafficking and sexual abuse of young girls, some as young as fourteen when the abuse occurred. Throughout his lifetime, per the federal government’s own accounting, Epstein and his criminal network subjected over 1,000 survivors to egregious and predatory conduct, including vulnerable young girls in New Mexico. By 2021, the United States Court of Appeals for the Eleventh Circuit already had recognized that the relevant facts were “beyond scandalous—they tell a tale of national disgrace.”

  2. Current Acting United States Attorney General Todd Blanche and members of United States Department of Justice (“USDOJ”) leadership in Washington, D.C., the Southern District of New York, and the District of New Mexico perpetuate that disgrace. Their conduct now actively harms victims and undermines the public interest, by stonewalling New Mexico Attorney General Raúl Torrez’s ongoing criminal investigation into conduct by Epstein and his co-conspirators at “Zorro Ranch” located outside Santa Fe.

  3. Acting Attorney General Blanche and USDOJ’s conduct violates promises USDOJ made to New Mexico to secure an agreement for state law enforcement to stand down Epstein-related investigations in 2019. USDOJ wanted federal investigators to complete their work before the state investigated related crimes and assured New Mexico that federal law enforcement would cooperate in subsequent state investigations and prosecutions. In reliance on those assurances, New Mexico gave up timely access to witnesses, victims, and other evidence. The state’s reliance was reasonable given decades of successful state-federal cooperation that has included the sharing of confidential investigative files, evidence, and reports in similar criminal investigations. New Mexico had no reason in 2019 to believe federal law enforcement officials would breach their express assurances and deviate from historical practice just to block their state counterparts from successfully investigating child sexual abuse under state law