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10/5/2015 Jeffrey Epstein 'sex slave' Virginia Roberts was a 'moneyhungry sex kitten', ex friends claim | Daily Mail Online
'millionaire's house' for a day or two, before returning with cash.
He did say that she tried to get out of the sex business, but was dragged back in.
Last month it was revealed Roberts accused two male acquaintances she was raped, bringing her
credibility into question.
Roberts' lawyers says the latest allegations do not contend the fact she was used for underage sex.
Attorney Sigrid McCawleysaid : 'To say that our client acquiesced in this abuse, or that the abuse
was OK because she was paid for it — leaves out the fact that this is why we have laws in the United
States to protect minor children who are groomed and sexually trafficked by adults.'
Epstein served 13 months in a Florida prison after pleading guilty in 2008 to soliciting a minor for
prostitution.
and booted as she
heads out to work in
elegant pinstriped
ensemble
George's better half
'He can go f***
himself': Kris Jenner's
rant over Caitlyn's
negative portrayal of her
in Vanity Fair article....
on Keeping Up With The
Kardashians
Her sun and stars!
Emilia Clarke reunites
with former Game of
Thrones love interest
Jason Momoa during
Paris Fashion Week
Two looked very close
It's in the genes! Meg
Ryan's son Jack Quaid
cracks up his famous
mom as they enjoy a
Sunday stroll in New
York City
Had his mom in stitches
From matching tattoos
and annual weddings to
gifts of $40 million
private jets, the craziest
things celebrities have
done for love
Sponsored
Attached at the hip!
Christie Brinkley, 61,
radiates as she and new
boyfriend John
Mellencamp leave hotel
in NYC... following date
the night before
Allegations: The 31yearold is currently in the midst of a lawsuit claiming she was recruited to join Epstein's
harem of underage women in 1999, naming Prince Andrew and attorney Alan Dershowitz as two of the men
she was made to 'service'
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The scandal resurfaced in January when Roberts named Prince Andrew in a lawsuit, accusing him
of using her for underage sex.
According to court records connected with Roberts' current lawsuit, she maintains that she was
recruited to join Epstein's harem in 1999 by his friend, the socialite Ghislaine Maxwell.
She says during the three years she worked for Epstein, she was made to entertain his friends and
named Prince Andrew and Dershowitz as two men she had sex with.
Both men have denied having sex with Roberts, and Dershowitz is trying to get his name removed
from the suit, claiming Roberts made the entire story up.
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SEE WHAT`S IN STORE AT
WASHINGTON DC
http://www.dailymail.co.uk/news/article2974613/JeffreyEpsteinsexslavemoneyhungrysexkittenenjoyedroletravellingmasseuseformerfriendsclai… 2/21
EXHIBIT G
Case 1:15-cv-07433 Document 1 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
1
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 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 out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently, wrongfully subjected Giuffre to public ridicule, contempt and disgrace by, among other
things, calling Giuffre a liar in published statements with the malicious intent of discrediting and
further damaging Giuffre worldwide.
JURISDICTION AND VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional limits of this Court.
3. This Court has jurisdiction over this dispute pursuant to 28 U.S.C. §1332
(diversity jurisdiction) as Giuffre and Maxwell are citizens of different states and the amount in
controversy exceeds seventy-five thousand ($75,000), exclusive of interest and costs.
4. This Court has personal jurisdiction over Maxwell. Maxwell resides in New York
City, and this action arose, and defamatory statements were made, within the Southern District of
New York.
5. Venue is proper in this Court as the cause of action arose within the jurisdiction of
this Court.
2
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 3 of 12
PARTIES
6. Plaintiff Giuffre is an individual who is a citizen of the State of Colorado.
7. Defendant Maxwell, who is domiciled in the Southern District of New York, is
not a citizen of the state of Colorado.
FACTUAL ALLEGATIONS
8. Virginia Giuffre became a victim of sex trafficking and repeated sexual abuse
after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Giuffre was under the age
of eighteen.
9. Between 1999 and 2002, with the assistance and participation of Maxwell,
Epstein sexually abused Giuffre at numerous locations including his mansions in West Palm
Beach, Florida, and in this District. Between 2001 and 2007, with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre
into remaining silent about what had happened to her.
11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”)
that barred his prosecution for numerous federal sex crimes in the Southern District of Florida.
12. In the NPA, the United States additionally agreed that it would not institute any
federal criminal charges against any potential co-conspirators of Epstein.
13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in
the Southern District of Florida through the NPA.
14. Epstein ultimately pled guilty to procuring a minor for prostitution, and is now a
registered sex offender.
3
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 4 of 12
15. Rather than confer with the victims about the NPA, the U.S. Attorney’s Office
and Epstein agreed to a “confidentiality” provision in the Agreement barring its disclosure to
anyone—including Epstein’s victims. As a consequence, the victims were not told about the
NPA.
16. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey
Epstein’s victims (other than Giuffre), filed a petition to enforce her rights under the Crime
Victims’ Rights Act (“CVRA”), 18 U.S.C. ¶ 3771, alleging that the Government failed to
provide her the rights promised in the CVRA with regard to the plea arrangement with Epstein.
The litigation remains ongoing.
17. On or about May 4, 2009, Virginia Giuffre—identified then as Jane Doe No.
102—filed a complaint against Jeffrey Epstein in the United States District Court for the
Southern District of Florida. The complaint included allegations made by Giuffre that pertained
to Maxwell.
18. In pertinent part, the Jane Doe No. 102 complaint described in detail how
Maxwell recruited Giuffre (who was then a minor girl) to become a victim of sex trafficking by
introducing Giuffre to Jeffrey Epstein. With the assistance of Maxwell, Epstein was able to
sexually abuse Giuffre for years until Giuffre eventually escaped.
19. The Jane Doe No. 102 complaint contained the first public allegations made on
behalf of Giuffre regarding Maxwell.
20. As civil litigation against Epstein moved forward on behalf of Giuffre and many
other similarly-situated victims, Maxwell was served with a subpoena for deposition. Her
testimony was sought concerning her personal knowledge and role in Epstein’s abuse of Giuffre
and others.
4
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 5 of 12
21. To avoid her deposition, Maxwell claimed that her mother fell deathly ill and that
consequently she was leaving the United States for London with no plans of ever returning. In
fact, however, within weeks of using that excuse to avoid testifying, Maxwell had returned to
New York.
22. In 2011, two FBI agents located Giuffre 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. Giuffre 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 many victims, Giuffre believed that
she should speak out about her sexual abuse experiences in hopes of helping others who had also
suffered from sexual trafficking and abuse.
24. On December 23, 2014, Giuffre incorporated an organization called Victims
Refuse Silence, Inc., a Florida not-for-profit corporation.
25. Giuffre intended Victims Refuse Silence to change and improve the fight against
sexual abuse and human trafficking. The goal of her organization was, and continues to be, to
help survivors surmount the shame, silence, and intimidation typically experienced by victims of
sexual abuse. Giuffre has now dedicated her professional life to helping victims of sex
trafficking.
26. On December 30, 2014, Giuffre moved to join the on-going litigation previously
filed by Jane Doe 1 in the Southern District of Florida challenging Epstein’s non-prosecution
agreement by filing her own joinder motion.
5
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 6 of 12
27. Giuffre’s motion described Maxwell’s role as one of the main women who
Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator and
participant in his sexual abuse and sex trafficking scheme.
28. In January, 2015, Maxwell undertook a concerted and malicious campaign to
discredit Giuffre and to so damage her reputation 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, Maxwell
issued an additional false statement to the media and public designed to maliciously discredit
Giuffre. That statement contained the following deliberate falsehoods:
(a)
(b)
(c)
That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.”
That the allegations have been “shown to be untrue.”
That Giuffre’s “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 Giuffre’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 Maxwell,
Epstein, and other powerful persons. Maxwell did so with the purpose and effect of having
6
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 7 of 12
others repeat such false and defamatory statements and thereby further damaged Giuffre’s
reputation.
33. Maxwell made her statements to discredit Giuffre in close consultation with
Epstein. Maxwell made her statements knowing full well they were false.
34. Maxwell made her statements maliciously as part of an effort to conceal sex
trafficking crimes committed around the world by Maxwell, Epstein and other powerful persons.
35. Maxwell intended her false and defamatory statements set out above to be
broadcast around the world and to intimidate and silence Giuffre from making further efforts to
expose sex crimes committed by Maxwell, Epstein, and other powerful persons.
36. Maxwell intended her false statements to be specific statements of fact, including
a statement that she had not recruited an underage Giuffre for Epstein’s abuse. Maxwell’s false
statements were broadcast around the world and were reasonably understood by those who heard
them to be specific factual claims by Maxwell that she had not helped Epstein recruit or sexually
abuse Giuffre and that Giuffre was a liar.
37. On or about January 4, 2015, Maxwell continued her campaign to falsely and
maliciously discredit Giuffre. When a reporter on a Manhattan street asked Maxwell about
Giuffre’s allegations against Maxwell, she responded by saying: “I am referring to the statement
that we made.” The New York Daily News published a video of this response by Maxwell
indicating that she made her false statements on East 65 th Street in Manhattan, New York, within
the Southern District of New York.
7
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 8 of 12
COUNT I
DEFAMATION
1. Plaintiff Giuffre re-alleges paragraphs 1 - 37 as if the same were fully set forth
herein. Maxwell made her false and defamatory statements deliberately and maliciously with the
intent to intimidate, discredit and defame Giuffre.
2. In January 2015, and thereafter, Maxwell intentionally and maliciously released to
the press her false statements about Giuffre in an attempt to destroy Giuffre’s reputation and
cause her to lose all credibility in her efforts to help victims of sex trafficking.
3. Maxwell additionally released to the press her false statements with knowledge
that her words would dilute, discredit and neutralize Giuffre’s public and private messages to
sexual abuse victims and ultimately prevent Giuffre from effectively providing assistance and
advocacy on behalf of other victims of sex trafficking, or to expose her abusers.
4. Using her role as a powerful figure with powerful friends, Maxwell’s statements
were published internationally for the malicious purpose of further damaging a sexual abuse and
sexual trafficking victim; to destroy Giuffre’s reputation and credibility; to cause the world to
disbelieve Giuffre; and to destroy Giuffre’s efforts to use her experience to help others suffering
as sex trafficking victims.
5. Maxwell, personally and through her authorized agent, Ross Gow, intentionally
and maliciously made false and damaging statements of fact concerning Giuffre, as detailed
above, in the Southern District of New York and elsewhere.
6. The false statements made by Gow were all made by him as Maxwell’s
authorized agent and were made with direct and actual authority from Maxwell as the principal.
8
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 9 of 12
7. 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.
8. 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.
9. 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.
10. 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.
11. 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.
12. 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.
9
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 10 of 12
13. 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.
14. 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.
15. 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.
16. 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.
17. 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
10
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 11 of 12
non-profit foundation, or share her life story, and thereby help others who have suffered from
sexual abuse.
18. 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.
19. 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.
20. 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.
21. 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.
11
Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 12 of 12
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
(954) 356-0011
/s/ Ellen Brockman
Ellen Brockman
Boies Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
(212) 446-2300
12
EXHIBIT H
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and PAUL G.
CASSELL,
vs.
Plaintiff(s),
ALAN M. DERSHOWITZ,
Defendant(s).
NOTICE OF SERVING ANSWERS TO INTERROGATORIES
Plaintiffs, Bradley J. Edwards and Paul G. Cassell, by and through their undersigned
counsel, hereby file this Notice of Serving Answers to Interrogatories with the Court propounded
by the Defendant, ALAN M. DERSHOWITZ, on February 11, 2015, and that a copy has been
furnished to the attorney for the Defendant.
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
to all Counsel on the attached list, this day of , 2015.
A CA OLA
Florida Bar No.: 169440
Attorney E-Mail(s): jsx@searcylaw.com and
mep@searcylaw.com
Primary E-Mail: _scarolateam@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorneys for Plaintiffs
13. Describe in detail Each instance in which Jane Doe #3 has provided information
referencing Dershowitz by name that Concern the allegations set forth in Paragraphs 24-31
of the 2015 Jane Doe #3 Declaration.
ANSWER: Edwards and Cassell lack sufficient information to determine all circumstances in
which Jane Doe No. 3 has mentioned to others Dershowitz's name as someone who abused her
or had information relevant to abuse.
With regard to when she has provided information related to this subject to them, Jane Doe No. 3
provided such information in telephone calls with Brad Edwards beginning in 2011.
Jane Doe No. 3 has also provided this information in a public affidavit, filed on January 21,
2015, in the CVRA case. Jane Doe No. 3 has also provided similar information on other
occasions, but the specifics of those communications are protected by the attorney-client
privilege and the work product doctrine.
14. If You have ever seen a photograph or video of Jane Doe #3 with Dershowitz, then state
when You saw the photograph or video, identify who took the original photograph
or video, identify Each person who possesses a copy of the photograph or video, and state
the location of Each such original and copy.
ANSWER: Edwards and Cassell have not personally seen such a photograph or
video. Discovery efforts to obtain photographic materials regarding Jane Doe No. 3 held by the
U.S. Attorney's Office for the Southern District of Florida and/or other federal law enforcement
and prosecuting agencies are on-going.
15. For Each communication between You or anyone acting on Your behalf, and anyone
from, or acting on behalf of, any media outlet Concerning this action, the Joinder Motion,
or Dershowitz, and regardless of whether such communication was "on the record" or "off
the record," (a) state the date of the communication; (b) state the participants in the
communication; and (c) describe the contents of the communication.
ANSWER: Objection, not reasonably calculated to lead to the discovery of admissible evidence;
vague, harassing, work-product.
16. Describe in detail All facts Concerning any assertion that Dershowitz was
a "coconspirator" with Epstein.
ANSWER: See answers to interrogatory number 5 above, as well as answers to interrogatories
numbers 1, 6, 8, 9, 10 above. In addition, factual information is found in the documents and
other materials and references provided in answer to Request for Production Number 2
15
PAUL G. CASSELL
STATE OF )
COUNTY OF (A-cr )
The foregoing instrument was acknowledged before me this
day of
or who has produced
, 20 ,•5 by
who is personally known to me
(type of identification) as
identification and whClidtdid not take an oath.
„ LtS crki -)C( CQ1 „
Notary Public
Statc of
My Commission expires:
Commission No:
vsc L'kkq.it,
SaNitcrAr4 BP Au bCi jAc
P4r) itlifte il19ys c 7 hIsr
State
STATE OF FLORIDA
COUNTY OF 3r-await d )
Bradley J. Edwards
BEFORE ME, the undersigned authority, personally appeared this day Bradley J.
Edwards, who [ is
personally known to me or [ produced
, as identification, and who, after being duly sworn, did state
that he/she executed the foregoing Answers to First Set of Interrogatories and that the same are
true and correct to the best of his knowledge
Subscribed and sworn to before me this IS'day of , 2015.
W1R1A W. KELLJCHINI
MY COMMISSION iPEE840478
EXPIRES: OCT 03, 2016
Son* We* 1M SOW imam
Signature ofNotaryPublik, St .cSfFlorida
Print / Typed Name, Notary Public
My commission expires:
10
EXHIBIT I
·1· · · · · ·IN THE CIRCUIT COURT OF THE SEVENTEENTH
· · · · · · · · · ·JUDICIAL CIRCUIT IN AND FOR
·2· · · · · · · · · · BROWARD COUNTY, FLORIDA
·3· · · · · · · · · CASE NO.· CACE 15-000072
·4