By Paul Serran 

Following a decision by the US Court of Appeals for the Second Circuit, the first documents from the 2015 defamation case brought against Ghislaine Maxwell by Virginia Giuffre (née Roberts) have been unsealed on Friday morning.

The first immediate development is that Ghislaine Maxwell’s reputation has been splintered seemingly beyond repair.

Ghislaine Maxwell

Since we know from the US Attorney for the Southern District of NY, Geoffrey Berman, that the present charges against [the officially deceased] Jeffrey Epstein were “placeholders” and that had he lived, we were to expect many more charges to be unsealed at a later date, if the case continues in any fashion, Ghislaine Maxwell is now looking like a pretty safe bet to be named in a future indictment.
Let’s look at what we have learned about Maxwell.

In 2015, Giuffre sued Maxwell, the daughter of UK newspaper tycoon Robert Maxwell. Giuffre claims  Maxwell defamed her by denying her claims of having been sexually abused and sex trafficked by both Epstein and Maxwell, and by stating that Giuffre was lying.

Among the first batch of documents released, I’d like to bring this one to your attention. It’s a PLAINTIFFS’ RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT. It was written by Giuffre’s attorney Sigrid McCawley Boies, from SCHILLER & FLEXNER LLP.

The Plaintiffs’ Response states that Maxwell “undertook a ‘concerted and malicious campaign to discredit Giuffre’ so that her claims to have been abused and trafficked would not be believed. Maxwell instructed her spokesman to “attack Giuffre’s honesty and truthfulness, and to accuse Giuffre of lying”.

It says Maxwell made 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 made her statements knowing full well they were false.”

The documents reveal in great detail the three-year period in which Roberts claims she was Jeffrey Epstein and Maxwell’s sex slave.

Virginia Giuffre

Giuffre’s lawyers showed that a former Epstein victim, Joanna Sjoberg, testified that Maxwell lured her from her school to have sex with Epstein, under the guise of hiring her for a job “answering phones”.

Epstein’s former bodyguard, Tony Figueroa testified that Maxwell “would call him to bring over underage girls and that Defendant (Maxwell) and Epstein would have threesomes with Ms. Giuffre.”

Rinaldo Rizzo was the house manager for one of Maxwell’s close friends, Eva Dubin. He testified that Maxwell “took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein.”

Palm Beach PD Detective Joseph Recarey testified that he sought to investigate Maxwell in relation to his original investigation of Epstein. An investigation that was thwarted by the “sweetheart deal” brokered by Florida’s State Attorney Barry Krischer, and later by the less bad, but still unacceptable plea deal worked by US Attorney Alex Acosta.


Epstein’s pilot David Rodgers testified that “he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the ‘Lolita Express’ and that ‘GM’ on the flight logs Stands for Ghislaine Maxwell.”

The Plaintiffs’ Response reminds the judge that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein all invoked the Fifth Amendment when asked about Maxwell trafficking girls for Epstein.

Epstein’s house manager, Juan Alessi, testified that Maxwell “was one of the people who procured some of the over 100 girls he witnessed visit Epstein and that he had to clean Defendant’s sex toys.”

Maxwell “has never offered a legal explanation for what she was doing with, and why she was traveling with, a minor child on 21 flights while she was a child, including 6 international flights, aboard a convicted pedophile’s private jet all over the world.”

(Like this is something explainable.)

Sigrid McCawley Boies continues: Maxwell “never offered a legal explanation for why Prince Andrew was photographed with his hand around Ms. Giuffre’s bare waist while she was a minor child, while posing with Defendant, inside Defendant’s house in London.”

One of the documents included in this Response states that “In 2008, the United States Attorney’s office for the Southern District of Florida identified Ms. Giuffre as a protected ‘victim’ of Jeffrey Epstein’s sex abuse. The U.S. Attorney mailed Ms. Giuffre a notice of her rights as a crime victim under the CVRA.”

Years before this cause of action arose, Ms. Giuffre “sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein.”

A 2011 psychological treatment record, written by her psychologist, unambiguously describes Maxwell as Ms. Giuffre’s abuser:

“. . . [Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help her get a job as a massage therapist . . . seemed respectable . . . was shown how to massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on person. Miss Maxwell promised her $200 a job.”

This demonstrates that years before Maxwell defamed her, Ms. Giuffre had confided to her treating psychologist that Maxwell was the one who recruited her for sex with Epstein.

The police recovered numerous “note pads” both from Epstein trash, and in his house during a police search. These messages “are relevant to refute Maxwell’s denial of any involvement with Epstein during relevant time periods, and, accordingly her denial of knowledge of certain events.”

She took messages at the residence, including from underage girls who were calling to schedule a time to come over to see Epstein.

The message pads show Maxwell was regularly at the Palm Beach home during the time period she claimed she was not.

In fact, it demonstrates she “is at the Palm Beach mansion so frequently that people, including Epstein’s main pilot Larry Visoski, are leaving messages for Maxwell at the Palm Beach house.”

“Law enforcement was able to confirm identities of underage victims through the use of the names and telephone numbers in these message pads.”

Detective Recarey authenticated an receipt that the Palm Beach Police collected from Jeffrey Epstein’s trash.

The books he ordered are titled:

(1) SM 101: A Realistic Introduction, Wiseman, Jay;

(2) SlaveCraft: Roadmaps for Erotic Servitude – Principles, Skills and Tools by Guy Baldwin; and

(3) Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy.

Boies writes: “And yet, when Ms. Giuffre had the courage to come forward and expose what Defendant had done to world – in a Court pleading trying to hold Epstein accountable – Defendant responded by calling her a liar in a press release intended for worldwide publication. Such heinous conduct is not a mere ‘opinion,’ but rather is defamation executed deliberately and with actual malice. The jury should hear all of the evidence and then render its verdict on Ms. Giuffre’s complaint.”

There was, however, never a chance for that, since the defamation suit that Giuffre brought against Maxwell was settled out of court, and the documents were filed under seal.

Now, with this decision from the United States District Court Southern District of New York, the world is about to know more details about the sex trafficking racket that Epstein and his accomplices had been running for decades.

A small preview of the horrors ahead can be seen in this note pad message: Jean-Luc Brunnel, a shady modeling agent, accused of molesting and drugging underage girls, is seen leaving a very open message, offering Epstein a 16-year-old non-blond Russian girl “for free”.

It is not inappropriate to remind readers that these allegations were not “proven in court”. But the fact that Maxwell settled the suit, while not proof of the veracity of every single allegation, does give immense credence to the ever growing body of evidence.

Paul Serran is a journalist, writer, and musician. He lives in Rio de Janeiro, Brazil.