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Case 1:17-mc-00025-RWS Document1 1-2
Case 1:15-cv-07433 Document Filed Filed 06/13/16
09/21/15 Page 1Page
of 121 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 1:17-mc-00025-RWS Document1 1-2
Case 1:15-cv-07433 Document Filed Filed 06/13/16
09/21/15 Page 2Page
of 122 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 world
[…]