Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 5 of 28 exposing how Epstein and his lawyers had corrupted the legal system to obtain the NPA and referring to Dershowitz’s sexual abuse of Roberts. Dershowitz’s response on behalf of himself and his client and co-conspirator Epstein has been a desperate barrage of false and increasingly defamatory attacks on Roberts. The purpose and effect of these attacks has been to damage Robert’s reputation and credibility and to try to intimidate her into silence. 14. Defendant’s central assertion is that Roberts has committed perjury, and that in December 2014, Roberts and her attorneys hatched a scheme to falsely accuse Dershowitz of sex trafficking as part of a criminal attempt to extort a settlement from another party. 15. | As Defendant and Epstein well knew, Dershowitz’s assertion was false. Dershowitz and Epstein knew that Dershowitz had in fact had sex with Plaintiff. Dershowitz and Epstein also knew that Roberts’s assertions about Dershowitz were not part of any criminal extortion plot. Indeed, Dershowitz and Epstein knew that Roberts had identified Dershowitz as a sexual predator years before December 2014. 16. Defendant’s knowledge of the falsity of his attacks on Roberts have not, however, limited the scope or scale of those attacks. 17. | Examples of Dershowitz’s knowingly false and malicious defamatory statements made on behalf of himself and Epstein are: (a) November 28, 2018: “the story was 100% flatly categorically made up” and “Roberts and her attorneys fabricated the assertion in order to get money from other powerful, wealthy people”. (Exhibit 1, p. 8). (b) December 1, 2018: “I never met Roberts; I never had sex with her; she simply made up the entire story for money”. (Exhibit 2). 5 HOUSE_OVERSIGHT_017939