United States District Court Southern District of York VIRGINIA GIUFFR-3.7E Plaintiff CASE GHISLAINE MAXWE-4.6LL Defendant COMPLAI-6.8N1.2T 2750Lexington 2750Avenue New 2750York Case Document Filed Page of Case Document Filed Page of 2230Plaintiff VIRGINIA GIUFFRE for-7.2m7.6erly known as Virginia Roberts Giuf4f4r-1e f)4o1r her Complain6t again6s5.2t Def4e-.2nda GHISLAINE MAXWELL Maxwell avers upon personal knowledge as to her own acts and status and otherwise upon inform8.4ation and NAT-3.7URE OF THE ACTION This suit arises out of Defendant Ma xwell?s4.6 defam8.2a-.8tory statem8.2ents again5.4s-.4t As described below Giuffre was a victim8.5 of sexual trafficking and abuse while-5.9 she was a child Defendant Maxwell not only facilitated that sexual abuse but recen5.5tly wrongfully subjected Giuffre to public ridicule and di-6.7sgrace by among other things calling Giuffre a liar in published statem8.5ents with the m8.7a-.3licious inte nt of discrediting and further dam8a-1ging Giuffre worldwide JURISDI-6.5C-3.5TION AND VENUE-3.7 This is an action for dam8.2a-.8ges in an am8.2ount in excess of the jurisd6.2ic5tiona5l lim9its th6.2is Court This Court has jurisdic tion over this dispute pursuant to U.S.C diversity jurisdiction as Giuffre and Maxwell ar citizens of different states and the in controversy exceeds sev5.5e-.7nty-five th5.5ousand exclu)5.2s-.6ive of interest and costs This Court has personal jurisdiction over Maxwell Maxwell resides in New York City and5.7 th5.7is action aros4.9e and statem8.5en ts were m9a0de within th Southern District of New York Venue is proper in this Court as the cause of action arose within the jurisdiction of this Court Case Document Filed Page of Case Document Filed Page of Plaintiff Giuffre is an individual who is a citizen of the State of Colorado Defendant Maxwell who is dom8.4i-1.6ciled in the Southern District of New York not a citizen of th state of Colorado FACT-4.1UAL Virginia Giuffre became a victim8.1 of sex trafficking and repeated abuse after being recruited by Ghislaine Maxwell and Jeffrey Epst ein when Giuffre was under the age of eighteen Between and with the assistan ce and participat ion of Maxwell Epstein sexually abused Giuffre at num8.4e-.6rous locations including his m8.4a-.6nsions in Beach Florida and in this District Between and with the a ssistance of co-conspirators Epstein abused re than thirty undera ge girls a fact confirm7.6e-1.4d by state and federal law enforcem8.3ent As part of their sex trafficking efforts Epstein and Maxwell intim8.1idated Giuffre-5.8 into abo5.7u.7t wh at had happened to her In Septem8.2ber Epstein entered into a Non-Prosecution Agreem8.2ent NPA that barred his prosecution for num8e-1rous federal se crim7.9es in the Southern District of Florida In the NPA the United States add5.4i-1.8tionally that it woul not institute any federal criminal ch5.8arges ag ainst any potential co-cons pirators of Epstein As a co-conspirator of Ep stein Maxwell was consequent granted im8.6munity the Southern District of Florida through the NPA Epstein u5.6l-1.6tim8.4ately pled guilty to pro5.6c-.6ur ing a for pros4.7titu5.5tion and5.5 is now a registered sex offender Case Document Filed Page of Case Document Filed Page of Rather than confer with the victim7.3s about the NPA the U.S Attorney?s Office and Epstein5.5 agreed to a confidentiality prov5.5is ion in th6e Agreem8.8ent barring6 its d6i-1.2sclosu6re to anyone?including Epstein?s victims As a conse quence the victim8.1s were not told about the NPA On July a young wom8a-1n identified as Jane Doe No one of Epstein?s victim8.1s other than Giuffr-6.7e filed a petition to enforce her rights under the Victim7.8s Rights Act CVRA U.S.C alleging that the Government failed to provide her the rights prom8.5ised in th5.5e CVRA with rega4.3rd to the plea arrangem8.1e-.9nt with Epstein The litigation rem8.1a-.9ins ongoing On or about May Virginia Giu ffre?identified then as Jane Doe No 102?filed a com8.3p.5laint against Jef8.5f3.5rey Epstein in the United States District Court for the Southern District Flor3.6ida The co5.6mplaint in cluded allegations m8a-1de by Gi-3.7uffre pert-3.7ai-3.7ned to Maxwell In pertinent part the Jane Doe No complaint described in detail how7.7 Maxwell recruited Giuffre who was then a m8i-2nor gi rl to a victim8.2 of sex trafficking by introdu5.8cing to Epste4.6i-1.4n W9.6ith th5.8e ass4.4i-2stan5.2ce of Maxwell Epstein able to sexually Giuffre for years un til Giuffre eventually escap5.4ed The Jane Doe No com8.2p.4laint contained the first public allegations m8a-1de on behalf of Giuffre regarding Maxwell As civil litigation Epste4.4i-1.6n move forward on behalf of Giuffre and other sim8.7ilarly-s5.1itu5.9ated victim8.7s Ma-5.3xwell wa served with5.3 a subpoena for deposition Her testim8ony was sought concerning her personal knowledge and role in Epstein?s abuse of Giuffre-6.3 and others Case Document Filed Page of Case Document Filed Page of To avoid her deposition Maxwell claim8.3e-.7d th at her m8.1o.3ther fe-5.9ll deathly ill and that consequently she was leaving the U7.4n.2ited S6.4t-2ates for London with no plans of ever returning In fact howev5.3er within w7.5eeks of that excu5.3s4.5e to avoid testifying Ma xwell return6.3ed to New York In two FBI agents located Giuffre in Aus-5.8t-2.2ralia?where she had been hiding from8.5 Epstein and Maxwell for several years?and arranged to with her at the U.S Consulate in Sidney Giuffre pr ovided truthf8.3ul and accurate information to the FBI about-7.3 Epstein and Maxwell?s sexual abuse Ultim8.7ately as a m8.7o.9ther and one Epstei many victim8.6s believed she should speak out about her sexual abuse experi ences in hopes of helping others who had also suffered from sexual trafficking and abuse On Giuffre incorporat ed an organizati on called Victim8.2s-5.4 Refuse Silence Inc a F6.6l3.2orid a not-for-profit corporation inte4.3nded Victims Ref3.5u.5se Silence to change and im8prove the fight against sexual abuse and trafficking The goal of her organization was and continues to be to help survivors surm8.3ount the sham8.3e silence and intim8.3idation typically expe rienced by victim8.1s of sexual abuse Giuffre has now dedicated her professional life to helping victim8.3s of sex trafficking Giuffre moved to jo in the on-going litigation previously filed by Jane Doe in the Southern District of Florida challenging Epstein?s non-prosecution agreem8.5ent by filing her own joinder motion Case Document Filed Page of Case Document Filed Page of Giuffre?s motion described Maxwell?s ro le as one of the women who Epstein used to procure under-ag ed girls for sexual activities an a prim7.6ary co-conspirator and participant in his sexual abuse and sex trafficking In January Maxwell undertook a con certed and m8.9a-.1licious cam8.9paign to discredit Giuffre and to so dam7.5a ge her reputation that Giuffre factual reporting of what had happened to her would not be credited As part of Maxwell?s cam8.4paign dire cted6 her agent,6 Ross Gow to attack6 Giuffre?s honesty and truthfulness a nd to accuse Giuffre of On or about January speaking through her authorized agent Maxwell issued an addition5.7a-.5l false statem8.5ent to the dia and public designed to m8.3a-.7licious4.7ly discred5.5it Giuffre That statem8.1ent containe the following deliberate falsehoods a That Giuffre?s sworn allegations aga5.5inst Ghislaine Maxw7.7ell are untrue.5.5 That the allegations have been shown to be untrue That Giuffre?s claims are obvious lies Maxwell?s January statem8.3ent inco rporated by reference Ghislaine Maxwell?s original response to the lies and defa-5.6m8.4a-.6tory claim8.4s-.2 the an earlier statem8.5ent that had falsely describe Giuffre?s fa-6.1ctual assertions as entirely a4.2nd entirely5.4 untrue Maxwell the f4a-.2lse and sta4.8t-1.2em8.8ents as f4o1rth abo6v1e in Southern District of New York and elsewhere in a to m9.1a.1licious5.5ly dis5.5c.1red6.3it Giuffre and silen5.6ce her efforts to expose se crim8es committed around the world by Maxwell,5.2 Epstein and other powerful persons Maxwell di so with the purpose and effect of having Case Document Filed Page of Case Document Filed Page of others repeat such false and defam8.2a-.8tory stat em8.6ents and thereby further dam8.6a-.4ged Giuffre?s reputation Maxwell made her statem8.6ents to discre dit Giuffre in close consultation with Epstein Maxwell her statem8.3ents knowing full well they were false Maxwell her statem8.4ents m8.4a-.6liciously5.6 as part of an effort to co5.6nceal sex5.6 trafficking crim8.3es committed around the world by Maxwell E6.1p.3stein and other powerful persons Maxwell intended her false and ry statem8.5ents set out above to be broadcast around the world and to intim7.7idate and silence Giuffre fr making further efforts to expose sex crim8.2es committed by Maxwell Epstein and other powerful persons Maxwell in5.9tended her sta4.7t-1.3em8.7ents to be specific statem8.1e-5.9n.3ts of fact including a statem8.1ent that she had not recr uited an underage Giuffre for Epst ein?s abuse Maxwell?s false statem8.2ents were broadcast around the world and were reasonably understood by those who heard them8.3 to be s4.7p.5ecific factu5.5a-.7l claim8.3s-.3 by Maxwell th5.5at she had not helped Epst ein recruit or sexually abuse Giuffre and that Giuffre was a liar.5.3 On or about January Maxwell continued her campaign to falsely and m7.9a-1.1liciously discredit Giuffre a repor ter on a Manhattan street asked Maxwell about Giuffre?s allegations against Maxwell she respon ded by saying I referring to the statem8.3ent-6.7 that we The New York Daily News published a video of this response by Maxwell indicating that she her false statem8.4ents on East th Street in Manhattan New York within the Southern District of New York Case Document Filed Page of Case Document Filed Page of COUNT Plaintiff Gi-7.2uffre re-alleges paragraphs as the same were set herein her false and defam9.1a.1tory statem ents delibe5.1r-.7ately a5.1nd m9.1a.1liciou6.3s.5ly with to in5.9tim8.7i-1.3date disc4.7redi and defam8.4e-.6 Giuffre In January and thereafter Maxwell in tentionally and maliciously released to the press her false statem7.6ents about Giuffre in an attem7.6p-.2t to destroy G7i-2.4uffre?s reputation and cause her to lose all credibili ty in her efforts to help victim8.2s of sex trafficking Maxwell ad6.3dition6.3a.1lly6.3 re5.1leased6.3 to th6.3e pres her3.7 statem8.5ents with k5.7nowledge that her words would dilute discredit and neut pub6.1lic4.9 a nd private m8.2e-.8ssages to sexual victim8.7s and ultim8.7ately5.9 prevent Giu ef4.2f4.2ectively pr4.2oviding ass5.4i4stance and advocacy behalf of other victim8.2s of se trafficking or to expose her ab5.5users Using her role as a powerful figure with powerf4u1l f4r-1iends,6 Maxwell?s statem8.8ents were published internationally fo the m8.4a-.6licious purpose of furt her dam7.3a-1.7ging a sexual abuse and sexual trafficking victim8 to dest roy Giuffre?s reputatio a4.6nd cred5.8ibility cause4.6 the world5.8 to disbelieve Giuffre and to destr oy Giuffre?s to use her expe rience to help others suffering as sex trafficking victim8.2s Maxwell personally and through her author ized agent Ross Gow intentionally and m8.4a-.6liciously false and dam8.4a-.6ging statem8.4en ts of fact con5.3cern5.3i3.1ng Giuffre as detailed above in the Southern District of New York and elsewhere The false statem8.4ents by Gow were-6.2 all by him as Maxwell?s authorized agent and were with direct and actua4.8l autho6r-1ity Maxwell as th6e princ4.8i-1.2pal Case Document Filed Page of Case Document Filed Page of The false statem8.3ents that Maxwell personally and through her authorized agent Gow not only called Giuffre?s truthfulness and integrity into que stion but also exposed Giuffre to public hatred cont em8pt ridicule and disgrace Maxwell her false statem8.4ents knowi ng full well that they were completely false Accordingly she her statem8.2ents with actu5.7a-.5l and delib5.7erate the highest degree of awareness of falsity Maxwell?3.8s s5t-1.4atem8.6ents constitu5.8te as s5h.8e knew that they were going be transm8.6itted in writing5.8,.8 widely dissem8.6i-1.4nated on th interne4.6t-1.4 and in print Maxwell intended her sta4.9t-1.1em8.9ents be p6.1ublishe by newspaper and other out lets interna4.3tiona4.3lly and they5.5 were in fact published globally including with in the Southern Dist rict of New York Maxwell?s false statem8.4ents constitute libel per se inasm8.4u-4.4ch as they exposed Giuffre to public con5.6t-1.6empt ridicu5.6le aversion a nd disgrace and induced6 an evil opin6i-1.2on of her in the of right-thinking persons Maxwell?4.2s f4.2a0lse sta5t-1em9ents a5l-1so con6.2s.4titu6.2te5 lib5.7el per ina4.5s-.1much as they tended injure Giuffre in her professional capacity as the president of a non-profit corporation designed to help victim7.9s of sex trafficking and inasm7.9u.1ch as they destroyed her cr edibility and reputation am7.8ong me-6.2mbers of the comm7.8unity that seeks he help and that she seeks to serve Maxwell?s false s4.9t-1.5atem8.5ents di rectly stated and also im plied that in speaking out against sex trafficking Giuffre acted with fra ud dishonesty and unf itness for the task Maxwell?s false statem8.2e-5.8n.4ts directly and indirectly indicate that Gi uffre lied about being recruited by Maxwell and sexually abused by Epstein a nd Maxwell Maxwell?s false statem7.5ents were-6.5 reasonably understood by persons who read he statem8.3ents as conve ying that specific intention and m8.1eaning Case Document Filed Page of Case Document Filed Page of Maxwell?s false statem8.2ents were reas onably understood by persons who read those s5t-1.4atem8.6ents as5 m8.6a-.4king specific factua claim8.7s.1 that Giuffre was lying ab5.9out specific facts Maxwell specifically directed her false statem7.6ents at Giu ffre?s true public description of factual events and persons who read Maxwell?s statem8.2ents reason5.4ably5.4 understood that those statem8.4ents referred tly to Giuffre?s accoun5.2t of her life as a young teenager with Maxwell and Epstein Maxwell intended her false statem8.4ents to be widely published and dissem8.4i-1.6nated on television through newspape rs by word of m7.5outh and on th internet As intended by Maxwell her statem8.2ents were publishe and dissem8inated around the world 252.5Maxwell coordinated her false statem8.1en ts with other efforts by Epstein and other powerful persons acting as Epst rep5.4r-1.6esentatives a nd surrogates Maxwell and c-5.7oordinated her statem8.3ents in the Sout hern District of New York and elsewhere with the spec4.9if4.1ic to am8.9plif4.1y the ef fect statem8.4ents would have Giuffre?s reputation and credibility Maxwell made her false statem8.4ents both directly and through agents who with her general and specific author ization adopted distributed and published the false statem8ents on Maxwell?s behalf In addition Maxwell and her authorized agen ts false statem8.6ents in reckless of their falsity an with m8.7a-.3licious to de4.7stro5.9y reputation and credibility to prev en6.3t her from9.1 further disse5.1m9.1i-.9nati ng her life story and to cause persons hearing or reading Giuffre descriptions of truthful fact to disbelieve entirely5.9.5.9 Maxwell her f4a-.2lse statem8.8ents wantonly an6d with the specif4i-1.2c in6ten6t-1.2 to m8.8a-.2licio6usly dam8.8a-.1ge Giuffre?s good and reputation in a way that would destroy her effort to adm7.7i-2.3nister her Case Document Filed Page of Case Document Filed Page of non-profit foundation or share her life story and thereby help others who have suffered from sexual abuse As a result of Maxwell?s cam8.6paign to spr ead false discrediting and defam8.1a-.9tory statem8.1ents about Giuffre Giuffre suffered substantia dam8.2a-.8ges in an am8.2ount to be proven at trial Maxwell?s false statem8.1e-5.9n.3ts have caused and continue to cause Giuffre econom7.9i-2.1c dam8a-1ge psychological pain and suffering mental anguish and em otional distress and other direct and consequential dam7.9a-1.1ges and losses Maxwell?s cam8.5p.7aign to spread her statem8.3ents internationally was unusual and particularly egregious conduc Maxwell sexually abused Gi uffre and helped Epstein to sexually abuse Giuffre and then in order to avoid having these crim es discovered Maxwell wantonly an5.6d m8.4a-.6liciously set out to falsely accu5.6se defa-6m8e-1 and discred5.2i3t Giuffre so doing Maxwell?s efforts constituted a public wrong by deterri ng dam7.4a-1.6ging and setting back Giuffre?s efforts to help victim7.8s of sex trafficking Accord ingly this is a case in which exem8.3plary and punitiv6e are appropria4.8te Punitive and5.9 exem8.7plary dam8.7a-.3ges are necessary in this case to deter Max5.9w3.1ell and5.9 others from wantonly and m8.2a-.8liciously using a cam paign of lies to discredit Giuffre and other victim8s of se-6x trafficking PRAYER Pl-3ai-3nt-3iff Gi-3u-5.8ffre respect-3f2.2u lly requests judgm8.1e-.9nt against Defendant Maxwell a4.5w2.9arding co5.7mpensatory,5.7 consequential exem8.5plary and punitiv5.7e damages in am8.9ount to be determ8.9ined at trial but in excess of the jurisdictional requirement costs of suit attorne4.8y1s f4ees and6 such other a4.8nd f4u1rther as th5.9e Court deem8.7 just and proper Case Document Filed Page of Case Document Filed Page of JURY DE-4.2MAND Plaintiff hereby dem8.2a-.8nds a trial by jury on al ca4.7uses actio5.9n asser3.9t-1.3ed within this pleading Dated September 2750David Boies Schiller Flexner LLP 2750Main 2750Street M4.9c-.5Cawley Sigrid McC7.6a-.6wley Pro Hac Vice Pending Boies Schiller Flexner LLP Las Olas Blvd Suite Ft Lauderdale FL Ellen Ellen Brockm8an Boies Schiller Flexner LLP Lexington Ave New York New York Case Document Filed Page of Case Document Filed Page of
