RE: Ghislaine Maxwell Redacted Documents

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  1. Maxwell’s false statements were reasonably understood by many persons who
    read those statements as making specific factual claims that Giuffre was lying about specific
    facts.
  2. Maxwell specifically directed her false statements at Giuffre’s true public
    description of factual events, and many persons who read Maxwell’s statements reasonably
    understood that those statements referred directly to Giuffre’s account of her life as a young
    teenager with Maxwell and Epstein.
  3. Maxwell intended her false statements to be widely published and disseminated
    on television, through newspapers, by word of mouth and on the internet. As intended by
    Maxwell, her statements were published and disseminated around the world.
  4. Maxwell coordinated her false statements with other media efforts made by
    Epstein and other powerful persons acting as Epstein’s representatives and surrogates. Maxwell
    made and coordinated her statements in the Southern District of New York and elsewhere with
    the specific intent to amplify the defamatory effect those statements would have on Giuffre’s
    reputation and credibility.
  5. Maxwell made her false statements both directly and through agents who, with
    her general and specific authorization, adopted, distributed, and published the false statements on
    Maxwell’s behalf. In addition, Maxwell and her authorized agents made false statements in
    reckless disregard of their truth or falsity and with malicious intent to destroy Giuffre’s
    reputation and credibility; to prevent her from further disseminating her life story; and to cause
    persons hearing or reading Giuffre’s descriptions of truthful facts to disbelieve her entirely.
    Maxwell made her false statements wantonly and with the specific intent to maliciously damage
    Giuffre’s good name and reputation in a way that would destroy her efforts to administer her
    Case 1:15-cv-07433-RWS Document 1 Filed 09/21/15 Page 10 of 12
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2 Comments
Ecency