Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 10 of 12 13. | 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. 14. | Maxwell specifically directed her false statements at Guiuffre’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. 15. | 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. 16. 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. 17. | 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 10 HOUSE_OVERSIGHT_015540