20 MAR 20-First Amended Complaint for Mandamus Relief, Injunctive Relief, and Disclosure of Grand Jury Records

20 MAR 2020

1. This is an action: A) To petition the District Court pursuant to the First Amendment of the United States Constitution to release certain grand jury records, and to request that the District Court release certain grand jury records pursuant to the federal common law and Fed. R. Cr. P. 6; B) To request injunctive relief to stop an apparent continuing violation by the United States Attorney’s Office of Plaintiffs’ Right to Petition for Redress under the First Amendment of the United States Constitution; and C) In the alternative, to compel officers of the United States to perform a non-discretionary duty under 18 U.S.C. § 3332(a), brought pursuant to the federal mandamus statute, 28 U.S.C. § 1361, and D) In the alternative, to compel officers of the United States to perform a non-discretionary duty under 18 U.S.C. § 3332(a)

First Amended Complaint Mandamus NY GJ Petit case 032020 MH JOK final