2
sexual abuse of Ms. Giuffre, her statements attacking Ms. Giuffre were not negligently uttered
but deliberately made.
The evidence begins with the fact that the Federal Bureau of Investigation (FBI) and the
U.S. Attorney’s Office for the Southern District of Florida identified Ms. Giuffre as a sexual
assault victim of Jeffrey Epstein. See Declaration of Sigrid McCawley at Exhibit 1,
Government’s September 9, 2008 Victim Notification Letter. Indeed, Epstein entered into a non-
prosecution agreement with the federal authorities obligating him to pay restitution for his crimes
against Ms. Giuffre. That agreement also protected any “co-conspirators” from prosecution.
The remaining question, then, is whether the Defendant was involved in this sexual
abuse. Again, publicly-available evidence (well known to Defendant) reveals that she was at the
heart of Epstein’s sex trafficking. Defendant cannot dispute that she recruited Ms. Giuffre at the
young age of fifteen (15) to come “massage” Jeffrey Epstein at his Palm Beach mansion.
Publicly available flight logs from convicted pedophile1
Jeffrey Epstein’s private jets show the
Defendant flying close to 360 times and at least 20 of those fights were with Jeffrey Epstein and
Ms. Giuffre, when she was a minor child2
. See Decl. of Sigrid McCawley at Composite Exhibit
2, Flight Logs from Jeffrey Epstein’s Plane.
3
While the Defendant attempts to argue that this victim’s claims are unbelievable because
she is accusing prominent and wealthy people of sexual abuse, the Defendant provides no
explanation for why she had Ms. Giuffre, who was a minor child at the time, in the Defendant’s
1
Jeffrey Epstein’s criminal case numbers were 2006-cf-009454AXXXMB and 2008-cf-
009381AXXXMB.
2 Over 30 underage victims of Jeffrey Epstein gave statements to the Palm Beach police during their
investigations. One female stated she was recruited to come to Jeffrey Epstein’s home by Ghislaine
Maxwell. See Decl. of Sigrid McCawley at Composite Exhibit 5, Palm Beach Police Reports dated
March 14, 2005 and July 28, 2006.
3 Only a fraction of Jeffrey Epstein’s private jet flight logs are publically available making these numbers
simply a snapshot of the actual flights.
Case 1:15-cv-07433-RWS Document 20 Filed 12/10/15 Page 7 of 26
3
London home, late at night with Prince Andrew’s arm wrapped around her bare waist – all
shown with the Defendant smiling in the background. Despite the photographic evidence
corroborating Ms. Giuffre’s account, Defendant is quick to publicly denounce Ms. Giuffre – a
liar. See Decl. of Sigrid McCawley at Exhibit 3 (picture of Prince Andrew, Ghislaine Maxwell
and Virginia Roberts Giuffre 17 years old at the time of the picture); see also Decl. of Sigrid
McCawley at Exhibit 4, Alfredo Rodriguez July 29, 2009 Dep. Tr. at 200 - 202 (testimony
regarding the close connection between Defendant Maxwell, Prince Andrew and Jeffrey
Epstein).
During the investigation of Jeffrey Epstein, certain household staff were deposed.
Alfredo Rodriguez, who was Jeffrey Epstein’s household manager, testified that the Defendant
frequently stayed in Jeffrey Epstein’s home and assisted with bringing in young girls to act as
“masseuses” for Jeffrey Epstein.
Q. “Okay. Going back to where we started here was, does Ghislaine Maxwell have
knowledge of the girls that would come over to Jeffrey Epstein’s house that are in
roughly the same age group as C. and T. (minor children) and to have a good time as
you put it?
A. Yes.
Q. And what was her involvement and/or knowledge about that?
A. She knew what was going on.”
See Decl. of Sigrid McCawley at Exhibit 4, Alfredo Rodriguez July 29, 2009 Dep. Tr. at 176-
RE: Ghislaine Maxwell Redacted Documents