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Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 6 of 12 27. Giuffre’s motion described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme. 28. In January, 2015, Maxwell undertook a concerted and malicious campaign to discredit Giuffre and to so damage her reputation that Giuffre’s factual reporting of what had happened to her would not be credited. 29. As part of Maxwell’s campaign she directed her agent, Ross Gow, to attack Giuffre’s honesty and truthfulness and to accuse Giuffre of lying. 30. On or about January 3, 2015, speaking through her authorized agent, Maxwell issued an additional false statement to the media and public designed to maliciously discredit Giuffre. That statement contained the following deliberate falsehoods: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” Bis Maxwell’s January 3, 2015, statement incorporated by reference “Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same,” an earlier statement that had falsely described Giuffre’s factual assertions as “entirely false” and “entirely untrue.” 32. Maxwell made the same false and defamatory statements as set forth above, in the Southern District of New York and elsewhere in a deliberate effort to maliciously discredit Giuffre and silence her efforts to expose sex crimes committed around the world by Maxwell, Epstein, and other powerful persons. Maxwell did so with the purpose and effect of having HOUSE_OVERSIGHT_015536