RE: Ghislaine Maxwell Redacted Documents

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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.
   Case 1:15-cv-07433-RWS Document 1 Filed 09/21/15 Page 9 of 12

Comments

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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
   Case 1:15-cv-07433-RWS Document 1 Filed 09/21/15 Page 10 of 12

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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.
   Case 1:15-cv-07433-RWS Document 1 Filed 09/21/15 Page 11 of 12

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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]
Case 1:15-cv-07433-RWS Document 1 Filed 09/21/15 Page 12 of 12