Epstein Secrets

cv-07433 Document1 Filed 09/21/15 Page 1 of 12 United States District Court Southern District of New York VIRGINIA L. GIUFFRE, Plaintiff, CASE NO: V. GHISLAINE MAXWELL, Defendant. / COMPLAINT Boies Schiller & Flexner LLP 575 Lexington Avenue New York, NY 10022 (212) 446-2300 HOUSE_OVERSIGHT_015531 --- PAGE BREA

age 2 of 12 Plaintiff, VIRGINIA L. GIUFFRE, formerly known as Virginia Roberts (“Giuffre”), for her Complaint against Defendant, GHISLAINE MAXWELL (“Maxwell”), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit arises o

o cause the world to disbelieve Giuffre; and to destroy Giuffre’s efforts to use her experience to help others suffering as sex trafficking victims. Se Maxwell, personally and through her authorized agent, Ross Gow, intentionally and maliciously made false and damaging statements of fact concerning Giuffre,

5-cv-07433-LAP Document 1 Filed 09/21/15 Page 2 of 12 Plaintiff, formerly known as (a'), for her Complaint against Defendant, GHISLAINE MAXWELL ("Maxwell"), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit aris

d repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when was under the a

egations have been "shown to be untrue." (c) That "claims are obvious lies." 31. 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 factual assertions as "ent

ondition suffered by such person as a result of conduct which would constitute" certain sex crimes under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint, and that sexual assault constitutes one or more sex c

under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible

ise for years, up until the last time Jane Doe saw Epstein. 46. One day, Epstein had someone call Jane Doe to his mansion. When Jane Doe arrived, Maxwell was waiting for her and led her upstairs to Epstein's master bedroom. When they got to the bedroom, sex toys were laid out on the bed. Epstein and M

onk, NY 10504 (914) 749-8200 Joshua I. Schiller BOIES SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300 Sigrid McCawley (Pro Hac Vice Pending) BOIES $CHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 14 EFTA00023305