Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 11 of 12 non-profit foundation, or share her life story, and thereby help others who have suffered from sexual abuse. 18. Asa result of Maxwell’s campaign to spread false, discrediting and defamatory statements about Giuffre, Giuffre suffered substantial damages in an amount to be proven at trial. 19. Maxwell’s false statements have caused, and continue to cause, Giuffre economic damage, psychological pain and suffering, mental anguish and emotional distress, and other direct and consequential damages and losses. 20. | Maxwell’s campaign to spread her false statements internationally was unusual and particularly egregious conduct. Maxwell sexually abused Giuffre and helped Epstein to sexually abuse Giuffre, and then, in order to avoid having these crimes discovered, Maxwell wantonly and maliciously set out to falsely accuse, defame, and discredit Giuffre. In so doing, Maxwell’s efforts constituted a public wrong by deterring, damaging, and setting back Giuffre’s efforts to help victims of sex trafficking. Accordingly, this is a case in which exemplary and punitive damages are appropriate. 21. | Punitive and exemplary damages are necessary in this case to deter Maxwell and others from wantonly and maliciously using a campaign of lies to discredit Giuffre and other victims of sex trafficking. PRAYER FOR RELIEF WHEREFORE, Plaintiff Giuffre respectfully requests judgment against Defendant Maxwell, awarding compensatory, consequential, exemplary, and punitive damages in an amount to be determined at trial, but in excess of the $75,000 jurisdictional requirement; costs of suit; attorneys’ fees; and such other and further relief as the Court may deem just and proper. 11 HOUSE_OVERSIGHT_015541