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Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 1 of 12 United States District Court Southern District of New York Plaintiff, CASE NO: v. GHISLAINE MAXWELL, Defendant. COMPLAINT Boles Schiller & Flexner LLP 575 Lexington Avenue New York. NY 10022 EFTA00676990 Case 1:15-cv-07433 Document 1
1:15-cv-07433 Document 1 Filed 09/21/15 Page 2 of 12 Plaintiff, , formerly known as In), 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
a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8. became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein whe of eighteen. 9. vas under the age Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexua
s located 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. provided truthful and accurate information to the FBI about Epstein and Maxwell's sexual abuse. 23. Ultimately, as a mother and one of Epstein's
L] [NULL] [NULL] [NULL] [NULL] Brian Convey Active Yes John Mariani 0033000000SLGx1AAH Jr. Primary Residence [NULL] United States Active Yes Maxwell 0036000001M0vDtAAL Maxwell [NULL] [NULL] [NULL] Maxwell, Ghislaine [NULL] Brian Convey Ghislaine Ghislaine [NULL] [NULL] Yes Paul Napoli 00
iani 0033000000SLGx1AAH Jr. Primary Residence [NULL] United States Active Yes Maxwell 0036000001M0vDtAAL Maxwell [NULL] [NULL] [NULL] Maxwell, Ghislaine [NULL] Brian Convey Ghislaine Ghislaine [NULL] [NULL] Yes Paul Napoli 0036000000tLsJDAA0 Client Paul [NULL] [NULL] [NULL] [NULL] [NULL] [NU
s for Approval Yes-same Lead John [NULL] Fitzgibbons, Mary Ann Yes-same Client Gary Fuhrman Floor New York Fuhrman, Gary NY Goodfriend, Sidney [NULL] Salvatore E. Moore Active Yes? Rorrie Gregorio 0033000000ERdc6AAD Prospect Gregorio Business 655 Third Avenue 16th Floor York NY 10
w enforcement. EFTA00210642 Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 3 of 28 7. I also knew what Epstein and Maxwell had been doing the years that I was with them. In addition to constantly finding underage girls to satisfy their personal sexual desires, Epstein an
le being published, two FBI agents also called me in Australia and then came to meet me. In around March 2011, they met me at the U.S. Consulate in Sidney. They seemed to be very professional and hard working. I thought to myself that I had finally gotten the attention of the people that I wanted to an
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
Page: HOUSE_OVERSIGHT_015531 →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
Page: HOUSE_OVERSIGHT_015532 →cated Giuffre in Australia—where she had been hiding from Epstein and Maxwell for several years—and arranged to meet with her at the US. Consulate in Sidney. Guuffre provided truthful and accurate information to the FBI about Epstein and Maxwell’s sexual abuse. 23. | Ultimately, as a mother and one of Ep
Page: HOUSE_OVERSIGHT_015535 →y life took a very different turn when adults began to be interested in having sex with me. 4. In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked that I come with her to Jeffrey Epstein’s mansion
Page: HOUSE_OVERSIGHT_010892 →oximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked that I come with her to Jeffrey Epstein’s mansion for the purposes of teaching me how to perform “massages” and to train me professionally in t
Page: HOUSE_OVERSIGHT_010892 →pproximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is the daughter of Robert Maxwell, w
Page: HOUSE_OVERSIGHT_010892 →federal prosecution before this. 56. In 2011, two FBI agents, called me in Australia and then came to meet me. They met me at the U.S. Consulate in Sidney. They seemed to be very professional and hard working. I thought to myself, “Wow, these people will do the right thing against the bad guys and prote
Page: HOUSE_OVERSIGHT_010904 →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
Page: EFTA00015727 →d repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when was under the a
Page: EFTA00015728 →s located 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. provided truthful and accurate information to the FBI about Epstein and Maxwell's sexual abuse. 23. Ultimately, as a mother and one of Epstein's
Page: EFTA00015730 →Entities connected to both Ghislaine Maxwell and Sidney

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
NEW YORK NY
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONJane Doe
PERSON
Denver
LOCATION
Joe Biden
PERSONLarry Visoski
PERSON