Epstein Secrets

lorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Col

tation that Giuffre’s factual reporting of what had happened to her would not be credited. 29. 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. 30. On or about January 3, 2015, speaking through her authorized agent

fre’s factual assertions as “entirely false” and “entirely untrue.” 32. 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 Maxw

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

ilure to carry out the most elementary investigation or any real due diligence. Iam now taking action to clear my name," she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: [email protected] Media contact: Ross Gow, Acuity Reputation, Tel:

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

er reputation that factual reporting of what had happened to her would not be credited. 29. As part of Maxwell's campaign she directed her agent, Ross Gow, to attack honesty and truthfulness and to accuse of lying. 30. On or about January 3, 2015, speaking through her authorized agent, Maxwell issu

forts 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 reputation and credibility. 17. Maxwell ma