Giuffre v. Maxwell: Summary Judgment Motion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. 15-cv-7433 (RWS) VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Plaintiff Virginia L. Giuffre, by and through her attorneys at Boies Schiller Flexner LLP, respectfully moves this Court for summary judgment on all claims pursuant to Federal Rule of Civil Procedure 56. STATEMENT OF UNDISPUTED MATERIAL FACTS 1. From approximately 1999 through 2002, Plaintiff Virginia Giuffre was sexually abused by Jeffrey Epstein on a repeated basis. 2. Defendant Ghislaine Maxwell personally recruited Giuffre into Epstein's circle when Giuffre was approximately 16 years old, while Giuffre was working at Mar-a-Lago. 3. Maxwell trained Giuffre in how to provide sexual services to Epstein and others, and directed Giuffre to travel for the purpose of engaging in sexual acts. 4. After Giuffre made public statements about her experiences, Maxwell, through her authorized agent Ross Gow, issued a public statement calling Giuffre's claims "obvious lies." SUPPORTING EXHIBITS (Filed Under Seal — Later Unsealed January 2024) - Exhibit A: Deposition excerpts - Exhibit B: Travel and scheduling records - Exhibit C: Communications and correspondence - Exhibit D: Photographs and documentation - Exhibit E: Third-party witness declarations The supporting exhibits filed with this motion formed the core of the documents unsealed by Judge Loretta Preska in the January 2024 release of 943 pages. Source: U.S. District Court, S.D.N.Y., Case No. 15-cv-7433 Available at: https://www.courtlistener.com/docket/4355835/giuffre-v-maxwell/