Original Complaint - Battery Allegations Against Prince Andrew

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. 21-cv-10926 (LAK) VIRGINIA GIUFFRE, Plaintiff, v. PRINCE ANDREW, DUKE OF YORK, Defendant. COMPLAINT Plaintiff Virginia Giuffre, by and through her attorneys, Boies Schiller Flexner LLP, brings this Complaint against Defendant Prince Andrew, Duke of York, and alleges as follows: NATURE OF THE ACTION 1. This is an action for battery and intentional infliction of emotional distress. Prince Andrew committed sexual assault and battery upon Plaintiff Virginia Giuffre when she was under the age of eighteen and a victim of sex trafficking by Jeffrey Epstein and Ghislaine Maxwell. PARTIES 2. Plaintiff Virginia Giuffre is a citizen of the State of Colorado and the Commonwealth of Australia. 3. Defendant Prince Andrew Albert Christian Edward, Duke of York, is a citizen and domiciliary of the United Kingdom. Prince Andrew is a son of Queen Elizabeth II and is eighth in line to the British throne. JURISDICTION AND VENUE 4. This Court has subject-matter jurisdiction under 28 U.S.C. § 1332 because this is a civil action between a citizen of a State and a citizen of a foreign state, and the amount in controversy exceeds $75,000. 5. Venue is proper in this district under the New York Child Victims Act, N.Y. C.P.L.R. § 214-g, which provides a window for victims of childhood sexual abuse to bring claims regardless of the statute of limitations. FACTUAL ALLEGATIONS 6. In or about 2000, when Plaintiff was sixteen years old, she was recruited by Ghislaine Maxwell to provide so-called "massages" to Jeffrey Epstein. 7. Maxwell and Epstein trafficked Plaintiff to Prince Andrew and forced her to engage in sexual acts with him at the London home of Maxwell, at Epstein's mansion in New York, and on Epstein's private island in the U.S. Virgin Islands. 8. On each occasion, Plaintiff was compelled by express or implied threats by Epstein, Maxwell, and Prince Andrew to engage in sexual acts with Prince Andrew. 9. Prince Andrew knew Plaintiff's age at the time, and he knew that she was a sex trafficking victim being forced to engage in sexual acts with him. FIRST CAUSE OF ACTION — BATTERY 10. Prince Andrew's sexual assault and battery upon Plaintiff was intentional, harmful, offensive, and without Plaintiff's consent. Prince Andrew is liable for compensatory and punitive damages. PRAYER FOR RELIEF Plaintiff demands judgment against Prince Andrew for compensatory damages, punitive damages, attorneys' fees, and costs. Filed: August 9, 2021 Source: U.S. District Court, S.D.N.Y. — PACER Available at: https://www.courtlistener.com/docket/60543025/giuffre-v-prince-andrew/