HOUSE_OVERSIGHT_015539.jpg
1.54 MB
Extraction Summary
4
People
3
Organizations
1
Locations
1
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal filing (civil complaint)
File Size:
1.54 MB
Summary
This page is from a legal complaint (Case 1:15-cv-07433) filed on September 21, 2015. It outlines allegations of libel against Ghislaine Maxwell, stating she and her agent Gow made false statements with 'actual and deliberate malice' to discredit the plaintiff, Giuffre. The document asserts that these statements damaged Giuffre's professional reputation as the president of a sex trafficking non-profit and falsely accused her of lying about being recruited by Maxwell and abused by Epstein.
People (4)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Accused of making false statements and libel against Giuffre personally and through an agent.
|
| Giuffre | Plaintiff/Victim |
Subject of Maxwell's alleged libel; described as president of a non-profit for sex trafficking victims.
|
| Gow | Authorized Agent |
Agent through whom Maxwell allegedly made false statements.
|
| Epstein | Alleged Abuser |
Mentioned in the context of the allegations Giuffre made, which Maxwell called lies (specifically regarding sexual ab...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Southern District of New York | Jurisdiction/Court |
Location where statements were published.
|
| Unnamed Non-profit Corporation | Non-profit |
Organization designed to help victims of sex trafficking, of which Giuffre is president.
|
| House Oversight | Government Body |
Referenced in Bates stamp (HOUSE_OVERSIGHT_015539).
|
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction where the false statements were published.
|
Relationships (3)
Giuffre is suing Maxwell for libel regarding statements made about recruitment and abuse.
Key Quotes (3)
"Maxwell made her false statements knowing full well that they were completely false."Source
HOUSE_OVERSIGHT_015539.jpg
Quote #1
"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."Source
HOUSE_OVERSIGHT_015539.jpg
Quote #2
"Maxwell’s false statements directly and indirectly indicate that Giuffre lied about being recruited by Maxwell and sexually abused by Epstein and Maxwell."Source
HOUSE_OVERSIGHT_015539.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,950 characters)
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.
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HOUSE_OVERSIGHT_015539
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