Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 8 of 12 COUNT I DEFAMATION 1. Plaintiff Giuffre re-alleges paragraphs 1 - 37 as if the same were fully set forth herein. Maxwell made her false and defamatory statements deliberately and maliciously with the intent to intimidate, discredit and defame Giuffre. 2. In January 2015, and thereafter, Maxwell intentionally and maliciously released to the press her false statements about Giuffre in an attempt to destroy Giuffre’s reputation and cause her to lose all credibility in her efforts to help victims of sex trafficking. 3. Maxwell additionally released to the press her false statements with knowledge that her words would dilute, discredit and neutralize Giuffre’s public and private messages to sexual abuse victims and ultimately prevent Giuffre from effectively providing assistance and advocacy on behalf of other victims of sex trafficking, or to expose her abusers. 4, Using her role as a powerful figure with powerful friends, Maxwell’s statements were published internationally for the malicious purpose of further damaging a sexual abuse and sexual trafficking victim; to destroy Giuffre’s reputation and credibility; to cause the world to disbelieve Giuffre; and to destroy Giuffre’s efforts to use her experience to help others suffering as sex trafficking victims. 5. Maxwell, personally and through her authorized agent, Ross Gow, intentionally and maliciously made false and damaging statements of fact concerning Giuffre, as detailed above, in the Southern District of New York and elsewhere. 6. 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 principal. 8 HOUSE_OVERSIGHT_015538