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Case 18-2868, Document 281, 08/09/2019, 2628234, Page1 of 66 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. SOUTHERN DISTRICT OF NEW YORK LOCAL RULE 56.1 PLAINTIFF’S STATEMENT OF CONTESTED FACTS AND PLAINTIFF’S UNDISPUTED FACTS DEFENDANT’S PURPORTED FACTS 1. Ms. Maxwell’s response to publications of Ms. Giuffre’s false allegations: the March 2011 statement. In early 2011 Ms. Giuffre in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, Ms. Giuffre made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, Ms. Giuffre suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that the allegations she made against Ms. Maxwell are false. Furthermore, Ms. Giuffre did give an interview to journalist, Sharon Churcher, in which Ms. Giuffre accurately and truthfully described Defendant Maxwell's role as someone who recruited or facilitated the recruitment of young females for Jeffrey Epstein. See McCawley Dec. at Exhibit 34, GIUFFRE003678. Ms. Giuffre was also interviewed by the FBI in 2011 and she discussed Defendant’s involvement in the sexual abuse. See McCawley Dec. at Exhibit 31, FBI Redacted 302, FIUFFRE001235-1246. Those statements were not "false and defamatory," but instead truthful and accurate.