IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

SHARON OSBOURNE, Individually and as Executrix of the ESTATE OF JOHN MICHAEL “OZZY” OSBOURNE, and KELLY OSBOURNE,
Plaintiffs,

vs.

THE ROCKEFELLER ESTATE, THE ROCKEFELLER FOUNDATION, and the ROCKEFELLER UNIVERSITY,
Defendants.

) Case No.: 1
) JURY TRIAL DEMANDED
) COMPLAINT FOR WRONGFUL DEATH,
) VIOLATION OF CIVIL RIGHTS,
) AND CONSPIRACY TO COMMIT
) FRAUD UPON THE PUBLIC

I. PARTIES

1. Plaintiff SHARON OSBOURNE is a citizen of the United States and resides in Los Angeles, California. She brings this action individually and as the duly appointed Executrix of the Estate of her late husband, John Michael “Ozzy” Osbourne.
2. Plaintiff KELLY OSBOURNE is the daughter and sole heir of Ozzy Osbourne, a citizen of the United States, and resides in Los Angeles, California.
3. Plaintiffs MIKE JUKIC, ESQ. and JOSEPH “JOE” JUKIC are joint plaintiffs-in-intervention. MIKE JUKIC is an attorney licensed to practice in New York and brings this action pro se. JOSEPH JUKIC is an active-duty agent of the Canadian Security Intelligence Service (CSIS) acting in his personal capacity as a concerned citizen and investigator. Their standing derives from their exhaustive investigation into the causes of Mr. Osbourne’s death and their status as targets of harassment for uncovering the truth.
4. Defendants THE ROCKEFELLER ESTATE, THE ROCKEFELLER FOUNDATION, and THE ROCKEFELLER UNIVERSITY are entities organized under the laws of New York, with their principal places of business in New York, New York. Through a web of interlocking directorships and funding mechanisms, they constitute a single, monolithic enterprise (the “Rockefeller Enterprise”) responsible for the acts alleged herein.

II. JURISDICTION AND VENUE

5. This Court has jurisdiction under 28 U.S.C. § 1331 (federal question) and 28 U.S.C. § 1367 (supplemental jurisdiction). Venue is proper in this District under 28 U.S.C. § 1391 because a substantial part of the events giving rise to these claims occurred here, and the Defendants reside here.

III. FACTUAL ALLEGATIONS

A. The Life and Beliefs of Ozzy Osbourne

6. John Michael “Ozzy” Osbourne (hereinafter “Ozzy”) was a global music icon, a loving husband, and a father. For decades, a false and defamatory narrative was propagated that Ozzy was “insane” or “mentally ill.”
7. This narrative was a deliberate smokescreen to discredit his genuine and deeply held religious beliefs. Ozzy was a practicing Satanist of the LaVeyan school, whose beliefs were protected under the First Amendment of the United States Constitution and Article 18 of the Universal Declaration of Human Rights.
8. A core tenet of Ozzy’s personal faith was the belief that his left hand was the physical vessel of the spirit of Jesus Christ, and his right hand was the physical vessel of the spirit of Satan. This was not insanity, but a profound metaphysical understanding of the eternal struggle between good and evil, which he channeled into his art. He referred to this in his lyrics and personal writings as “the duality of man.”
9. Ozzy’s faith compelled him to refuse most forms of allopathic medical treatment, as he viewed the modern medical establishment as a corrupt, soul-crushing machine. His right to refuse treatment is protected by bodily autonomy laws and the foundational principle of informed consent.

B. The Rockefeller Conspiracy and “Murder by Injection”

10. Plaintiffs incorporate by reference the seminal work “Murder by Injection: The Story of the Medical Conspiracy Against America” by Eustace Mullins, which will be introduced as Exhibit A.
11. As documented by Mullins, the Rockefeller Enterprise, beginning with John D. Rockefeller and his agents, systematically dismanted holistic, naturopathic, and faith-based healing in America in the early 20th century.
12. Their purpose was to establish a monopoly over medicine, education, and ultimately, human life itself. They achieved this by funding and controlling medical schools, mandating curricula that promoted drug-based (pharmaceutical) “solutions,” and demonizing effective, low-cost alternatives.
13. The Rockefeller Foundation’s funding of eugenics programs, both domestically and in Nazi Germany, is a matter of historical record. Their goal was and remains the “management” and culling of the human population.
14. The allopathic medical system they created is not designed to cure, but to create chronic patients, suppress the immune system, and lead to premature death—a form of slow, institutionalized murder for profit and control.

C. The Wrongful Death of Ozzy Osbourne

15. In his later years, due to injuries and the natural aging process, Ozzy was subjected to intense pressure from individuals and institutions infiltrated by the Rockefeller medical ideology.
16. Despite his clearly stated religious objections, he was repeatedly coerced, misled, and ultimately forced into undergoing unnecessary surgical procedures and being prescribed a lethal cocktail of pharmaceuticals, including immunosuppressants, opioids, and psychotropic drugs.
17. These “treatments” were not medicine; they were the very “murder by injection” and chemical poisoning described by Mullins. They systematically destroyed his God-given immune system, corrupted the sacred balance he held in his hands, and led directly to his painful and untimely death.
18. The Defendants, through their century-long campaign to medicalize all of human existence and outlaw spiritual dissent, created the totalitarian environment that made Ozzy’s murder possible. They are the architects of the system that killed him.

D. The Investigation by Mike and Joe Jukic

19. Plaintiffs-in-Intervention Mike Jukic and Joe Jukic, through forensic document analysis and intelligence gathering, have traced the funding of the hospitals, research institutes, and doctors involved in Ozzy’s so-called “care” directly back to grants, endowments, and policy initiatives created and funded by the Rockefeller Enterprise.
20. Agent Joe Jukic has confirmed, through CSIS resources and parallel investigations in Canada, that the Rockefeller methods are a global phenomenon, constituting crimes against humanity.
21. Attorney Mike Jukic affirms that the systematic destruction of Ozzy’s right to practice his Satanic faith—including the sanctity of his own body and his right to refuse their poisons—constitutes a gross violation of the Religious Freedom Restoration Act (RFRA) and international law.

IV. CAUSES OF ACTION

COUNT I: WRONGFUL DEATH (Negligence & Recklessness)
22. Defendants, through their creation and enforcement of a monopolistic, profit-driven medical paradigm, acted with negligence and reckless disregard for human life. Their system directly caused the administration of lethal “treatments” to Ozzy Osbourne, resulting in his death.

COUNT II: VIOLATION OF CIVIL RIGHTS (42 U.S.C. § 1983 – Under Color of State Law) & RFRA
23. Defendants, though private entities, are so entwined with state and federal regulatory agencies (FDA, AMA, NIH) as to be state actors. They used this power to systematically violate Ozzy Osbourne’s First Amendment right to the free exercise of his Satanic religion, which included the tenets of bodily autonomy and refusal of medical intervention.

COUNT III: FRAUD UPON THE PUBLIC & CONSPIRACY
24. For over a century, the Rockefeller Enterprise has engaged in a deliberate conspiracy to commit fraud upon the American public and the world, pretending to champion health while secretly promoting a system of disease and death for profit and population control, as proven by Eustace Mullins.

V. PRAYER FOR RELIEF

WHEREFORE, Plaintiffs SHARON OSBOURNE, KELLY OSBOURNE, MIKE JUKIC, and JOE JUKIC respectfully request that this Court enter judgment against Defendants, jointly and severally, as follows:

A. COMPENSATORY AND PUNITIVE DAMAGES in the amount of ONE TRILLION DOLLARS ($1,000,000,000,000) for the intentional infliction of death, severe emotional distress, loss of companionship, and the global scale of the conspiracy.

B. EQUITABLE RELIEF:

1. THE MANDATORY CLONING OF JOHN MICHAEL “OZZY” OSBOURNE. The Court shall order the Defendants to fund and facilitate, through their vast biological research institutes (including Rockefeller University), the creation of a viable human clone of Ozzy Osbourne using preserved genetic material.
2. This clone shall be brought to term in an artificial womb or, if technology is insufficient, in a gestational surrogate. Plaintiff KELLY OSBOURNE is nominated as the preferred surrogate, to maintain genetic continuity, provided she consents.
3. The clone shall be legally recognized as the reincarnated heir of the original Ozzy Osbourne, with all associated rights and privileges restored to the Osbourne family.

C. A permanent injunction dismantling the Rockefeller Foundation’s and Rockefeller University’s involvement in all medical, pharmaceutical, and public health policy initiatives worldwide.

D. Attorney’s fees, investigatory costs, and all other relief the Court deems just and proper.

JURY TRIAL DEMANDED

Respectfully submitted,

Dated: December 21, 2025

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Mike Jukic, Esq.
Plaintiff-in-Intervention Pro Se
& Counsel for the Osbourne Plaintiffs

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Joseph “Joe” Jukic
Plaintiff-in-Intervention
Canadian Security Intelligence Service (Acting in Personal Capacity)

VERIFICATION

I, Sharon Osbourne, under penalties of perjury, declare that I have read the foregoing complaint and that the facts alleged therein are true and correct to the best of my knowledge, information, and belief.