EFTA00015726.pdf

"became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when was under the age of "

"Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexually abused at numerous locations including his mansions"

"Epstein entered into a Non-Prosecution Agreement (NPA) that barred his prosecution for numerous federal sex crimes"

"On or about May 4, 2009, identified then as Jane Doe No. 102—filed a complaint against Jeffrey Epstein"

"In 2011, two FBI agents located in Australia... and arranged to meet with her at the U.S. Consulate in Sidney"

"incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation"

"Maxwell sexually abused and helped Epstein to"

"lied about being recruited by Maxwell and sexually abused by Epstein and Maxwell"

"Plaintiff re-alleges paragraphs 1 - 37 as if the same were fully set forth herein. Maxwell made her false and defamatory statements deliberately and m"

"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"

"Maxwell's false statements also constitute libel per se inasmuch as they tended to injure in her professional capacity as the president of a non-profi"

"Maxwell sexually abused and helped Epstein to sexually abuse and then, in order to avoid having these crimes discovered, Maxwell wantonly and maliciou"

"Maxwell sexually abused and helped Epstein to sexually abuse"

"Plaintiff respectfully requests judgment against Defendant Maxwell, awarding compensatory, consequential, exemplary, and punitive damages in an amount"

"Plaintiff respectfully requests judgment against Defendant Maxwell"

"Plaintiff respectfully requests judgment against Defendant Maxwell"

"David Boies Boies Schiller & Flexner LLP"

"Sigrid McCawley Boies chiller & Flexner LLP"

"Ellen Brockman Boies chiller Flexner LLP"

"Defendant Maxwell not only facilitated that sexual abuse but, most recently, wrongfully subjected to public ridicule"

"As a co-conspirator of Epstein, Maxwell was consequently granted immunity in the Southern District of Florida through the NPA"

"she directed her agent, Ross Gow, to attack honesty and truthfulness"

"Maxwell made her statements to discredit in close consultation with Epstein."

"issued an additional false statement to the media and public designed to maliciously discredit . That statement contained the following deliberate fal"

"a statement that she had not recruited an underage for Epstein's abuse. Maxwell's false statements... were reasonably understood... that she had not h"

"indicating that she made her false statements on East 65'h Street in Manhattan, New York"