RE: Ghislaine Maxwell Redacted Documents

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1. To avoid her deposition, Maxwell claimed that her mother fell deathly ill and that
   consequently she was leaving the United States for London with no plans of ever returning. In
   fact, however, within weeks of using that excuse to avoid testifying, Maxwell had returned to
   New York.
2. In 2011, two FBI agents located Giuffre in Australia—where she had been hiding
   from Epstein and Maxwell for several years—and arranged to meet with her at the U.S.
   Consulate in Sidney. Giuffre provided truthful and accurate information to the FBI about
   Epstein and Maxwell’s sexual abuse.
3. Ultimately, as a mother and one of Epstein’s many victims, Giuffre believed that
   she should speak out about her sexual abuse experiences in hopes of helping others who had also
   suffered from sexual trafficking and abuse.
4. On December 23, 2014, Giuffre incorporated an organization called Victims
   Refuse Silence, Inc., a Florida not-for-profit corporation.
5. Giuffre intended Victims Refuse Silence to change and improve the fight against
   sexual abuse and human trafficking. The goal of her organization was, and continues to be, to
   help survivors surmount the shame, silence, and intimidation typically experienced by victims of
   sexual abuse. Giuffre has now dedicated her professional life to helping victims of sex
   trafficking.
6. On December 30, 2014, Giuffre moved to join the on-going litigation previously
   filed by Jane Doe 1 in the Southern District of Florida challenging Epstein’s non-prosecution
   agreement by filing her own joinder motion.
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Comments

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1. Giuffre’s motion described Maxwell’s role as one of the main women who
   Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator and
   participant in his sexual abuse and sex trafficking scheme.
2. In January, 2015, Maxwell undertook a concerted and malicious campaign to
   discredit Giuffre and to so damage her reputation that Giuffre’s factual reporting of what had
   happened to her would not be credited.
3. As part of Maxwell’s campaign she directed her agent, Ross Gow, to attack
   Giuffre’s honesty and truthfulness and to accuse Giuffre of lying.
4. On or about January 3, 2015, speaking through her authorized agent, Maxwell
   issued an additional false statement to the media and public designed to maliciously discredit
   Giuffre. That statement contained the following deliberate falsehoods:
   (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.”
   (b) That the allegations have been “shown to be untrue.”
   (c) That Giuffre’s “claims are obvious lies.”
5. Maxwell’s January 3, 2015, statement incorporated by reference “Ghislaine
   Maxwell’s original response to the lies and defamatory claims remains the same,” an earlier
   statement that had falsely described Giuffre’s factual assertions as “entirely false” and “entirely
   untrue.”
6. Maxwell made the same false and defamatory statements as set forth above, in the
   Southern District of New York and elsewhere in a deliberate effort to maliciously discredit
   Giuffre and silence her efforts to expose sex crimes committed around the world by Maxwell,
   Epstein, and other powerful persons. Maxwell did so with the purpose and effect of having
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others repeat such false and defamatory statements and thereby further damaged Giuffre’s
reputation.

1. Maxwell made her statements to discredit Giuffre in close consultation with
   Epstein. Maxwell made her statements knowing full well they were false.
2. Maxwell made her statements maliciously as part of an effort to conceal sex
   trafficking crimes committed around the world by Maxwell, Epstein and other powerful persons.
3. Maxwell intended her false and defamatory statements set out above to be
   broadcast around the world and to intimidate and silence Giuffre from making further efforts to
   expose sex crimes committed by Maxwell, Epstein, and other powerful persons.
4. Maxwell intended her false statements to be specific statements of fact, including
   a statement that she had not recruited an underage Giuffre for Epstein’s abuse. Maxwell’s false
   statements were broadcast around the world and were reasonably understood by those who heard
   them to be specific factual claims by Maxwell that she had not helped Epstein recruit or sexually
   abuse Giuffre and that Giuffre was a liar.
5. On or about January 4, 2015, Maxwell continued her campaign to falsely and
   maliciously discredit Giuffre. When a reporter on a Manhattan street asked Maxwell about
   Giuffre’s allegations against Maxwell, she responded by saying: “I am referring to the statement
   that we made.” The New York Daily News published a video of this response by Maxwell
   indicating that she made her false statements on East 65th Street in Manhattan, New York, within
   the Southern District of New York.

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COUNT I
DEFAMATION

1. Plaintiff Giuffre re-alleges paragraphs 1 - 37 as if the same were fully set forth
   herein. Maxwell made her false and defamatory statements deliberately and maliciously with the
   intent to intimidate, discredit and defame Giuffre.
2. In January 2015, and thereafter, Maxwell intentionally and maliciously released to
   the press her false statements about Giuffre in an attempt to destroy Giuffre’s reputation and
   cause her to lose all credibility in her efforts to help victims of sex trafficking.
3. Maxwell additionally released to the press her false statements with knowledge
   that her words would dilute, discredit and neutralize Giuffre’s public and private messages to
   sexual abuse victims and ultimately prevent Giuffre from effectively providing assistance and
   advocacy on behalf of other victims of sex trafficking, or to expose her abusers.
4. Using her role as a powerful figure with powerful friends, Maxwell’s statements
   were published internationally for the malicious purpose of further damaging a sexual abuse and
   sexual trafficking victim; to destroy Giuffre’s reputation and credibility; to cause the world to
   disbelieve Giuffre; and to destroy Giuffre’s efforts to use her experience to help others suffering
   as sex trafficking victims.
5. Maxwell, personally and through her authorized agent, Ross Gow, intentionally
   and maliciously made false and damaging statements of fact concerning Giuffre, as detailed
   above, in the Southern District of New York and elsewhere.
6. The false statements made by Gow were all made by him as Maxwell’s
   authorized agent and were made with direct and actual authority from Maxwell as the principal.
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1. The false statements that Maxwell made personally, and through her authorized
   agent Gow, not only called Giuffre’s truthfulness and integrity into question, but also exposed
   Giuffre to public hatred, contempt, ridicule, and disgrace.
2. Maxwell made her false statements knowing full well that they were completely
   false. Accordingly, she made her statements with actual and deliberate malice, the highest
   degree of awareness of falsity.
3. Maxwell’s false statements constitute libel, as she knew that they were going to
   be transmitted in writing, widely disseminated on the internet and in print. Maxwell intended her
   false statements to be published by newspaper and other media outlets internationally, and they
   were, in fact, published globally, including within the Southern District of New York.
4. Maxwell’s false statements constitute libel per se inasmuch as they exposed
   Giuffre to public contempt, ridicule, aversion, and disgrace, and induced an evil opinion of her in
   the minds of right-thinking persons.
5. Maxwell’s false statements also constitute libel per se inasmuch as they tended to
   injure Giuffre in her professional capacity as the president of a non-profit corporation designed
   to help victims of sex trafficking, and inasmuch as they destroyed her credibility and reputation
   among members of the community that seeks her help and that she seeks to serve.
6. Maxwell’s false statements directly stated and also implied that in speaking out
   against sex trafficking Giuffre acted with fraud, dishonesty, and unfitness for the task.
   Maxwell’s false statements directly and indirectly indicate that Giuffre lied about being recruited
   by Maxwell and sexually abused by Epstein and Maxwell. Maxwell’s false statements were
   reasonably understood by many persons who read her statements as conveying that specific
   intention and meaning.
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1. Maxwell’s false statements were reasonably understood by many persons who
   read those statements as making specific factual claims that Giuffre was lying about specific
   facts.
2. Maxwell specifically directed her false statements at Giuffre’s true public
   description of factual events, and many persons who read Maxwell’s statements reasonably
   understood that those statements referred directly to Giuffre’s account of her life as a young
   teenager with Maxwell and Epstein.
3. Maxwell intended her false statements to be widely published and disseminated
   on television, through newspapers, by word of mouth and on the internet. As intended by
   Maxwell, her statements were published and disseminated around the world.
4. Maxwell coordinated her false statements with other media efforts made by
   Epstein and other powerful persons acting as Epstein’s representatives and surrogates. Maxwell
   made and coordinated her statements in the Southern District of New York and elsewhere with
   the specific intent to amplify the defamatory effect those statements would have on Giuffre’s
   reputation and credibility.
5. Maxwell made her false statements both directly and through agents who, with
   her general and specific authorization, adopted, distributed, and published the false statements on
   Maxwell’s behalf. In addition, Maxwell and her authorized agents made false statements in
   reckless disregard of their truth or falsity and with malicious intent to destroy Giuffre’s
   reputation and credibility; to prevent her from further disseminating her life story; and to cause
   persons hearing or reading Giuffre’s descriptions of truthful facts to disbelieve her entirely.
   Maxwell made her false statements wantonly and with the specific intent to maliciously damage
   Giuffre’s good name and reputation in a way that would destroy her efforts to administer her
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non-profit foundation, or share her life story, and thereby help others who have suffered from
sexual abuse.

1. As a result of Maxwell’s campaign to spread false, discrediting and defamatory
   statements about Giuffre, Giuffre suffered substantial damages in an amount to be proven at trial.
2. Maxwell’s false statements have caused, and continue to cause, Giuffre economic
   damage, psychological pain and suffering, mental anguish and emotional distress, and other
   direct and consequential damages and losses.
3. Maxwell’s campaign to spread her false statements internationally was unusual
   and particularly egregious conduct. Maxwell sexually abused Giuffre and helped Epstein to
   sexually abuse Giuffre, and then, in order to avoid having these crimes discovered, Maxwell
   wantonly and maliciously set out to falsely accuse, defame, and discredit Giuffre. In so doing,
   Maxwell’s efforts constituted a public wrong by deterring, damaging, and setting back Giuffre’s
   efforts to help victims of sex trafficking. Accordingly, this is a case in which exemplary and
   punitive damages are appropriate.
4. Punitive and exemplary damages are necessary in this case to deter Maxwell and
   others from wantonly and maliciously using a campaign of lies to discredit Giuffre and other
   victims of sex trafficking.
   PRAYER FOR RELIEF
   WHEREFORE, Plaintiff Giuffre respectfully requests judgment against Defendant
   Maxwell, awarding compensatory, consequential, exemplary, and punitive damages in an
   amount to be determined at trial, but in excess of the $75,000 jurisdictional requirement; costs of
   suit; attorneys’ fees; and such other and further relief as the Court may deem just and proper.
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JURY DEMAND
Plaintiff hereby demands a trial by jury on all causes of action asserted within this
pleading.
Dated September 21, 2015.
/s/ David Boies
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
/s/ Sigrid McCawley
Sigrid McCawley
(Pro Hac Vice Pending)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
[phone]
/s/ Ellen Brockman
Ellen Brockman
Boies Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
[phone]
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