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1.43 MB

Extraction Summary

3
People
2
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal filing (civil complaint)
File Size: 1.43 MB
Summary

This document is page 11 of a legal complaint (Case 1:15-cv-07433) filed on September 21, 2015, by Virginia Giuffre against Ghislaine Maxwell. The text outlines allegations that Maxwell sexually abused Giuffre, facilitated Epstein's abuse of her, and subsequently launched a defamation campaign to discredit Giuffre and cover up the crimes. The page concludes with a 'Prayer for Relief' requesting judgment against Maxwell for damages in excess of $75,000.

People (3)

Name Role Context
Virginia Giuffre Plaintiff
Victim of sexual abuse and defamation seeking damages.
Ghislaine Maxwell Defendant
Accused of sexually abusing Giuffre, facilitating Epstein's abuse, and defaming Giuffre.
Jeffrey Epstein Alleged Abuser
Mentioned as having sexually abused Giuffre with Maxwell's help.

Organizations (2)

Name Type Context
Court
Entity requested to grant relief.
House Oversight Committee
Indicated by the Bates stamp 'HOUSE_OVERSIGHT'.

Timeline (2 events)

2015-09-21
Filing of Complaint
Court
Variable (Past)

Relationships (2)

Ghislaine Maxwell Abuser/Victim Virginia Giuffre
Maxwell sexually abused Giuffre
Ghislaine Maxwell Co-conspirators/Accomplices Jeffrey Epstein
Maxwell... helped Epstein to sexually abuse Giuffre

Key Quotes (4)

"Maxwell sexually abused Giuffre and helped Epstein to sexually abuse Giuffre"
Source
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Quote #1
"Maxwell wantonly and maliciously set out to falsely accuse, defame, and discredit Giuffre."
Source
HOUSE_OVERSIGHT_015541.jpg
Quote #2
"Punitive and exemplary damages are necessary in this case to deter Maxwell and others from wantonly and maliciously using a campaign of lies"
Source
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Quote #3
"awarding compensatory, consequential, exemplary, and punitive damages in an amount to be determined at trial, but in excess of the $75,000 jurisdictional requirement"
Source
HOUSE_OVERSIGHT_015541.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,770 characters)

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
HOUSE_OVERSIGHT_015541

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