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

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.

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 Amazon.com 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 body of evidence.
“Jeffrey Epstein’s gal pal Ghislaine Maxwell spotted at In-N-Out Burger in first photos since his death.”
https://nypost.com/2019/08/15/jeffrey-epsteins-gal-pal-ghislaine-maxwell-spotted-at-in-n-out-burger-in-first-photos-since-his-death/
Ghislaine Maxwell’s whereabouts and her “respectable new life.”
https://mol.im/a/7352813
“Borgenson did not respond to DailyMail.com’s request for comment when first contacted, but following publication he claimed: ‘I’m traveling abroad for business. Ghislaine Maxwell is not at my home and I don’t know where she is.'”
My expectation:
She will never be seen or heard of again.
She has probably already been installed on a little island south of the equator, where she will live out the rest of her life in comfort.
Wow! Sarah Ferguson was in Epstein black book. Did she “allegedly “ rape young girls too? This is crazier the more you read about Epstein.
Nah, doubt it. She just hangs around men with money and her ex hubby was buddies with him. I wonder if she knew tho. Bet she did.
Don’t “know”…about Sarah….”BUT”, certainly Hillary did, & certainly “enjoyed it”……Wonder if Chelsea, was involved? Like Mother….Like daughter?….{ Like Father?}/…..What a filthy rat’s nest of sex, debauchery, sin, & detestable activities! So typical of the Clinton Cartel?
F.B.I. Should be arresting these “madams” or male madams today. Epstein is dead there is no more excuses. It’s wonderful that they raided pedo island or orgy island but why haven’t they raided “Zorro Ranch” in New Mexico or the mansion in Paris? C’mon F.B.I. Why are we as taxpayers paying you when all this hanging fruit just hangs there. Geez!!!
Sorry….The FBI, CIA, DNC, & NSA…..are all still so busy investigating, Trump, & trying their best to sink his ship…..To even comment on this “nothing” story…..after all, it’s a black mark on the DNC……& decent Americans?
Any nation that refuses to extradite Ghislane Pimp Maxwell to face child sex trafficking charges should have immediate trade sanctions placed on it.
And that includes nations like the UK and Israel.
Currently administration policy is to do business as usual even with totalitarian regimes that do things like assassinate dissidents in hotels, airports and embassies. Good luck with expectations that they’ll get tough on someone who might reveal embarrassing details about the POTUS.
Well, the other “madams” for Epstein should be arrested. Ghislaine Maxwell may not be in the United States but Lesley Groff, Sarah Kellen (Vickers), Adriana Ross, Haley Robson, and Nadia Marchinko are. I would also arrest the Dubins for what they did to the 15-year-old Swedish girl. Plus, Les Wexner and Jean-Luc Brunel as male madams for Epstein. None of these people should be walking free. Oh, and don’t forget those Ms. Giuffre named who “allegedly “ raped her when she was under 18. Ms. Giuffre is only one “sex slave” who had the courage to name names. Can you imagine all the girls Epstein forced to have sex with him and all the powerful men and women? Could be hundreds of pedophiles that should be arrested worldwide yet walk free. Disgusting. Prosecutors and law enforcement better get their act together fast. The world is riveted by this tragedy.
Sarah Kellen is the person named, along with Maxwell, who threatened a girl, not only with intense pressure to have sex with “grown-up” strangers, but also the young lady said that the 2 of them took and withheld her passport from her so her options for leaving their captivity were even more limited. This was because the young lady didn’t want to meet their sexual exploitation demands. The Swedish girl must have felt such fear and helplessness, out on the water on the way to Epstein’s island. Nowhere to go. Once ashore, how much worse?
Bear in mind, the teen was offered chances to further her work as a model by these tricksters, who used bait to catch these girls and then, obviously, could turn fearsome when a girl wasn’t ready to cooperate. Ghislaine Maxwell, Sarah Kellen (Vickers) – two-bit female abusers and hoodlums, were getting paid to recruit and to savage the young. Too attached to all of the wealthy trappings even to give a damn about hunting, deceiving and damaging kids who were just getting started trying to find their ways into what we call adulthood.
Then that scummy whore Maxwell referred to them as trash.
Sarah Kellen would take pictures of the girls in the nude.
Although the exact details might differ slightly, all sex trafficking operations resemble one another.
Links to pictures of Epstein’s alleged pimps.
From the UK’s Sun Newspaper.
Nadia Marcinko
https://www.thesun.co.uk/wp-content/uploads/2019/08/NINTCHDBPICT000513070297-e1565653867367.jpg?w=620
Lesley Groff
https://www.thesun.co.uk/wp-content/uploads/2019/08/NINTCHDBPICT000513091375-e1565654059335.jpg?w=620
Adriana Ross
https://www.thesun.co.uk/wp-content/uploads/2019/08/NINTCHDBPICT000513091299-e1565654144741.jpg?w=620
Sarah Kellen
https://www.thesun.co.uk/wp-content/uploads/2019/08/NINTCHDBPICT000513070729.jpg?w=620
Ghislane Maxwell
https://www.thesun.co.uk/wp-content/uploads/2019/08/NINTCHDBPICT000513036226-e1565654428202.jpg?w=620
Article from the Sun
https://www.thesun.co.uk/news/9709755/jeffrey-epstein-helpers-probe-andrew-barr/
And from Vanity Fair Gloria Allred vows to track down all of Epstein’s pimps.
GLORIA ALLRED VOWS TO TRACK DOWN EPSTEIN’S CO-CONSPIRATORS
British socialite Ghislaine Maxwell is among the potential targets. “The question is,” says Allred, “Can we find these people?”
Allison Mack taking pictures of women’s genitalia is small game compared to the hardcore racket of Epstein’s women. Amazing.
Allison Mack was just getting started.
Yep, well said.
Epstein had 401 Britons in his little black book
https://mol.im/a/7351365
More from the Daily Mail.
Bill Gates flew with Epstein in 2013.
https://mol.im/a/7350469
One of the guards on duty the night of Epstein’s death was not a Corrections Officer.
https://mol.im/a/7351191
How Epstein was found in his cell.
https://mol.im/a/7350415
Epstein said laws banning sex with teenage girls were “cultural aberration” because “it was once perfectly acceptable.”
https://mol.im/a/7351203
“Epstein said laws banning sex with teenage girls were “cultural aberration” because “it was once perfectly acceptable.”
Sounds like something Pea Onyu (Nicki Clyne) would say
And an interesting piece here about conditions at the jail – where the budget is so strapped, they can’t even afford batteries for the clocks:
The MCC, Where Jeffrey Epstein Died, Is a Place That Time Forgot
“The clocks don’t work, the corrections officers work insane hours, and the place is plagued by water leaks, mold, rodents, and roaches.”
https://www.thedailybeast.com/the-metropolitan-correctional-center-mcc-where-jeffrey-epstein-died-is-a-place-that-time-forgot?source=articles&via=rss
Uh oh! Court documents reveal that Ghislaine Maxwell had a sexual relationship with George Clooney. Think about that: he was hooking up with a woman who procured & sex trafficked children to elites. Now do you understand why Hollywood scumbags like Clooney are so anti-Trump?!?! And we’re still just at the tip of the iceberg folks. Enjoy the show!
It was actually just an accusation, or a boast, of a single sex act.
The whole mess, like many, is actually rather bi-partisan. On the other side, besides Trump’s personal ties to Epstein, Epstein’s major backer Wexner was a major Republican donor, and we haven’t even begun to unravel the nature of their relationship and just why he let Epstein have so much money.
And have you forgotten already that the scandal has already claimed one member of the current administration? Plus several others who helped craft Epstein’s sweetheart deal, are still White House political appointees. And despite Acosta’s resignation, we still don’t really know who the higher-ups in the Bush administration were, who approved – or even pushed for – the deal.
Paul Serran,
Just finished re-reading your article. It’s in par with any article I have read in the New Yorker or Atlantic Monthly.
I am glad your writing for the Frankreport!
Hey, Mr. niceguy! that was actually very nice! I grew up with a good diet of exactly this kind of literary journalism. So it means a big deal to me. Thanks a lot!
From writer James B.Stewart
The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People
James B. Stewart 2 hrs ago
Almost exactly a year ago, on Aug. 16, 2018, I visited Jeffrey Epstein at his cavernous Manhattan mansion.
The overriding impression I took away from our roughly 90-minute conversation was that Mr. Epstein knew an astonishing number of rich, famous and powerful people, and had photos to prove it. He also claimed to know a great deal about these people, some of it potentially damaging or embarrassing, including details about their supposed sexual proclivities and recreational drug use.
https://www.msn.com/en-ca/news/world/the-day-jeffrey-epstein-told-me-he-had-dirt-on-powerful-people/ar-AAFI7k5
The upshot of the story is that Epstein has been advising the Tesla automotive company.
Epstein invited Stewart for a dinner with Epstein and Woody Allen but Stewart declined.
It’s a good article. Stewart, an astute journalist, also points out that it was hard to really tell to what extent Epstein’s claims and implications were true, or just part of his technique of deceptive swagger; and that several things either seemed implausible or did not pan out at all – including whether he was actually advising Tesla, or really had the promised dinner guests coming.
I suggest reading the piece – carefully. If anything it seems to be a story of someone probably trying to peddle more influence than he really, or still, had.
I suspect that we’re ultimately going to find out that much of Epstein’s recipe for success was puffery and misdirection, which is typical of grifters and con artists. Like Raniere, he was good at embellishing a rather thin CV, and convincing people that his obviously high intelligence somehow necessarily made him more successful.
I did read the piece carefully.
In it, Epstein invites Stewart to a dinner with Woody Allen and Epstein.
In light of the persistent rumors about Woody Allen and Epstein, why would Epstein have a dinner with Woody Allen and invite a journalist along to witness it?
Epstein is either arrogant or stupid.
And Epstein claims to be advising both Tesla Automotive and Elon Musk.
With Epstein’s reputation, no corporate executive in his right mind would take advice from the disgraced pedophile.
Although some people might argue that Elon Musk is not quite in his right mind.
Paul Serran
I greatly enjoyed and appreciated your Epstein: A pedophile Tale in Three Acts.
Awesome, engrossing read!
I am looking forward to your future articles!
Thanks!
More interesting developments in the case:
FBI agents swarm Jeffrey Epstein’s private Caribbean island
“The investigation into Epstein’s alleged sex trafficking network is continuing despite his death, multiple top law enforcement officials have said.”
https://www.nbcnews.com/news/us-news/fbi-agents-swarm-jeffrey-epstein-s-private-caribbean-island-n1041596
If Ghislaine Maxwell can’t get arrested in U.S. how about the U. K. Arrest her for us?
She could be extradited if a good enough case can be put to the UK by the US. It’s by no means an automatic process.
UK police are well skilled at covering up scandals that could tarnish the sterling reputation of the Royal Family.
Just look at the pedophilia cases involving BBC personality Jimmy Savile.
She’s been mentioned in relation to her role with Epstein in the Times of London, and the Daily Telegraph, both top-tier UK newspapers.
“The British socialite Ghislaine Maxwell faces a conspiracy investigation in the United States over accusations that she recruited under-age girls for sex with the disgraced financier Jeffrey Epstein.
Ms. Maxwell, who denies the claims, is believed to be facing the inquiry by US prosecutors along with former assistants of Epstein, 66, who is thought to have died from hanging in a Manhattan prison cell on Saturday morning.”
https://www.thetimes.co.uk/article/socialite-ghislaine-maxwell-faces-questions-after-jeffrey-epstein-death-gj930wvqh
“Ghislaine Maxwell told friends she planned to ‘disappear’ as Jeffrey Epstein case ‘raised its ugly head”.
https://www.telegraph.co.uk/news/2019/08/12/ghislaine-maxwell-vowed-disappear-knocked-six-renewed-jeffrey/
She is now officially radioactive in the UK.
From the Telegraph, Aug. 12, 2019 “Ghislaine Maxwell told freinds….”
“The British socialite at the center of the Jeffrey Epstein sex scandal told friends in recent weeks that she planned to ‘totally disappear.’ Ghislaine Maxwell said she was ‘knocked for six’ after lurid allegations resurfaced about her dealings with the paedophile billionaire, as source told the Telegraph. It comes as U.S. prosecutors are struggling to locate Miss Maxwell to question her….” A source close to her said: ‘Ghislaine thought this was all dead and buried when the case was settled in 2017. So she was knocked for six when the Epstein stuff raises its ugly head again.’ “
It sounds from the above Telegraph piece that Maxwell’s whereabouts are unknown at the moment. Since she hasn’t been charged with any crime, probably she isn’t obligated to be forthcoming or available, if the Telegraph story is accurate at all. Wait ten minutes or so, and perhaps a story saying the opposite will appear. “Ghislaine Maxwell Spotted Hiking Solo in Bhutan.”
Or how about “Buckingham Palace has announced the marriage of Prince Andrew and a Miss Maxwell. The Duke of York, while overjoyed, requests privacy and honeymoon plans will not be publicized.”
Nah, he stays ‘married’ to his baby mother Sarah Ferguson, herself massively present in Epstein’s little black book.
If Ghislane worked for the Mossad, she will disappear to Israel.
Great to see you here, Paul! A good read as always.
Thanks!
I Would like to ask the Author of the article to unblock me since I was asking an innocent question regarding the impression I thought was Ghislaine Maxwell’s attorney. I innocently thought it was McCawley. Trying to get more clarification I asked if he could supply his link or direct me to the document with the name on it. If the author cannot at least allow his readers to ask questions and get a polite response clarifying, I am now nervous about retweeting his work or passing it onto others.
I have admired his work in the past and have never in any way disparaged his work. But this response of blocking me from his twitter account is so strange, it’s like I said, I am now made to feel uncomfortable and not eager about his type of journalism.
Jessica Fletcher always pinpoints a time when someone does something wrong in a fanatical sense and in this case it was her DUI in England. That must possibly be when the term “the mask slips” is from. She has no other encounters with the law in her long life so something was giving her a big gripe around that time.
A good report on Epstein and Maxwell.
Politics and pedophilia: a demonic mix
By Wayne Madsen
Posted on August 8, 2019
http://www.intrepidreport.com/archives/27808
Is Ghislaine working with, cooperating with the “authorities” or not? Was she going to agree, or had she agreed already to be a witness for the prosecution against Epstein? Since cooperation would have been a tactical move to protect herself, and the whole situation has changed, what happens now that Epstein won’t be tried, and there are supposedly plans to charge his associates? And how protected might Maxwell already be, behind the scenes?
There has been brief and vague reporting from more than one news outlet, including the New York Post, since Epstein’s death – that Maxwell has been cooperating with the prosecution, although there was, from what I’ve seen, zero news about this cooperation mentioned before he died.
So much scrambling, so many explanations being given for how Epstein died and yet a strange absence of factuality about it. Stories of how the guards weren’t doing their rounds. No cameras used in Special Housing to show the interior of the cells. No info of when exactly Epstein was last seen alive and counted as okay. So many vested interests anxious to control the narratives, from multiple subsections of self-interest, some very powerful. How many people who are involved have one goal in mind – to make this all as muted as possible?
What’s the essential difference between Ghislane Pimp Maxwell and Allison Pimp Mack?
One is a brunette and the other is a blonde.
They are both Pimps and Sex Traffickers.
Wait till the ritual abuse info goes mainstream. Toxic.
Wow actual journalism, been a while thanks
I’m sure Mack is mentioned somewhere in here, Mr. Shadow: https://assets.documentcloud.org/documents/6250471/Epstein-Docs.pdf
No she’s not.
With Google chrome you can search a document for a keyword in about 5 seconds.
Correction: Sigrid’s last name is McCawley, not Boies.
You are right. Thanks. Sigrid McCawley, from BOIES, SCHILLER & FLEXNER LLP.
Boies is the partner who sued Amway in a class action lawsuit, then turned around defended Herbalife against Bill Ackman’s attacks. MLMs obviously pay better and more dependably than the class action groups.
Why are there so many conspiracy theories about what happens in the world?
The Liberal Media never stops complaining about Conspiracy Theories and the people, like Alex Jones, who promote those Conspiracy Theories.
(You’re wearing a tinfoil hat.)
Every time there is an important investigation the government SCREWS IT UP.
Who killed JFK?
A lone nut?
The Cubans?
The Russians?
The Mob?
Rich Texas Oil Men?
Lyndon Johnson?
The CIA?
JFK was publicly executed on the streets of Dallas and the Warren Commission cover up still stinks to high heaven over 55 years later.
Now we have a man with powerful, influential blackmailed friends worth 550 million dollars indicted for pedophilia and under 24/7 custody who is attacked in his cell and claims he is in danger.
Is this man given 24/7 protection?
Is he given 24/7 surveillance?
No!
He is placed by himself in a cell with no working video cameras.
And this man is attacked a second time with fatal results.
Why would anyone be surprised by Epstein’s MURDER?
Alive Epstein is dangerous.
Alive Epstein can name who is controlling him.
Dead Epstein is silenced forever.
A point of personal privilege.
When I quote court testimony claiming that Allison PIMP Mack is a sex trafficker, I get attacked by Nutjobs coming out of the woodwork.
Now Ghislane Maxwell is publicly identified in a deposition as a pimp and sex trafficker.
How come the people accusing Ghislane Maxwell of pimping on the basis of a deposition are not attacked?
Because this website’s comments section is infested with NXIVM Nutjobs dedicated to protecting a perverted sadistic pimp named Allison Mack.
“Was Ghislaine Maxwell Found Unresponsive?”
https://heavy.com/news/2019/08/ghislaine-maxwell-unresponsive-hoax/