Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 3 of 12 PARTIES 6. Plaintiff Giuffre is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8. Virginia Giuffre became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Giuffre was under the age of eighteen. 9, Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexually abused Giuffre at numerous locations including his mansions in West Palm Beach, Florida, and in this District. Between 2001 and 2007, with the assistance of numerous co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by state and federal law enforcement. 10.‘ As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre into remaining silent about what had happened to her. 11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”) that barred his prosecution for numerous federal sex crimes in the Southern District of Florida. 12. In the NPA, the United States additionally agreed that it would not institute any federal criminal charges against any potential co-conspirators of Epstein. 13. As a co-conspirator of Epstein, Maxwell was consequently granted immunity in the Southern District of Florida through the NPA. 14. Epstein ultimately pled guilty to procuring a minor for prostitution, and is now a registered sex offender. 3 HOUSE_OVERSIGHT_015533