EFTA00015726.pdf

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Extraction Summary

8
People
5
Organizations
8
Locations
5
Events
3
Relationships
5
Quotes

Document Information

Type: Civil complaint (legal pleading)
File Size: 619 KB
Summary

This document is a civil complaint filed on September 21, 2015, in the Southern District of New York by a redacted Plaintiff (identifiable by context as Virginia Giuffre) against Ghislaine Maxwell. The complaint alleges defamation arising from Maxwell's public statements in January 2015, where she called the Plaintiff a liar regarding allegations of sex trafficking and sexual abuse involving Jeffrey Epstein. The document details the history of the alleged abuse (1999-2002), the 2007 Non-Prosecution Agreement, and Maxwell's specific efforts to discredit the Plaintiff's reputation.

People (8)

Name Role Context
Plaintiff (Redacted) Plaintiff
Victim of sex trafficking; formerly known as Jane Doe 102; citizen of Colorado; President of Victims Refuse Silence, ...
Ghislaine Maxwell Defendant
Accused of facilitating sexual abuse, recruiting minors, and making defamatory statements calling the Plaintiff a liar.
Jeffrey Epstein Alleged Abuser
Registered sex offender; accused of sexually abusing Plaintiff and other minors; entered into NPA in 2007.
Ross Gow Agent
Maxwell's authorized agent who issued statements accusing Plaintiff of lying.
Jane Doe No. 1 Victim
Another victim of Epstein who filed a petition regarding the CVRA and NPA in 2008.
David Boies Attorney
Counsel for Plaintiff, Boies Schiller & Flexner LLP.
Sigrid McCawley Attorney
Counsel for Plaintiff, Boies Schiller & Flexner LLP.
Ellen Brockman Attorney
Counsel for Plaintiff, Boies Schiller & Flexner LLP.

Organizations (5)

Name Type Context
United States District Court, Southern District of New York
Venue of the current lawsuit.
Boies Schiller & Flexner LLP
Law firm representing the Plaintiff.
Victims Refuse Silence, Inc.
Florida not-for-profit corporation incorporated by Plaintiff in Dec 2014.
U.S. Attorney's Office
Office that entered into the Non-Prosecution Agreement with Epstein.
New York Daily News
Media outlet that published video of Maxwell's response in Jan 2015.

Timeline (5 events)

1999-2002
Period during which Plaintiff was allegedly sexually abused by Epstein and Maxwell.
West Palm Beach, Florida and New York
2007-09
Epstein entered into Non-Prosecution Agreement (NPA).
Southern District of Florida
2011
Two FBI agents met with Plaintiff at U.S. Consulate.
Sidney, Australia
Plaintiff FBI Agents
2014-12-23
Plaintiff incorporated Victims Refuse Silence, Inc.
Florida
Plaintiff
2015-01
Maxwell launched campaign to discredit Plaintiff with false statements.
New York and International

Locations (8)

Location Context
Jurisdiction where the case is filed and where defamatory statements were made.
State of citizenship of the Plaintiff.
Location of Epstein's mansion where abuse occurred.
Residence of Maxwell.
Location Maxwell claimed she was moving to in order to avoid deposition.
Location where Plaintiff was located by FBI agents in 2011.
Location of U.S. Consulate where Plaintiff met with FBI.
Specific location where Maxwell made a statement to a reporter.

Relationships (3)

Ghislaine Maxwell Co-conspirator Jeffrey Epstein
Complaint alleges Maxwell recruited girls for Epstein and participated in abuse; Maxwell granted immunity via Epstein's NPA as a co-conspirator.
Ross Gow Agent/Spokesperson Ghislaine Maxwell
Described as Maxwell's 'authorized agent' who issued statements on her behalf.
Plaintiff Victim/Abuser Jeffrey Epstein
Plaintiff alleges she was sexually abused by Epstein between 1999 and 2002.

Key Quotes (5)

"against Ghislaine Maxwell are untrue."
Source
EFTA00015726.pdf
Quote #1
"shown to be untrue."
Source
EFTA00015726.pdf
Quote #2
"claims are obvious lies."
Source
EFTA00015726.pdf
Quote #3
"I am referring to the statement that we made."
Source
EFTA00015726.pdf
Quote #4
"Maxwell sexually abused [Redacted] and helped Epstein to sexually abuse [Redacted]"
Source
EFTA00015726.pdf
Quote #5

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