Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 12 of 28 investigating Epstein until September 24, 2007 — when the NPA was concluded — the Office never conferred with the victims about a NPA or told the victims that such an agreement was under consideration.” Order at 2, 8. E. Victims Refuse Silence 44. _ Ultimately, as a mother and one of Epstein’s many victims, Roberts concluded that she should speak out about her sexual abuse experiences in hopes of helping others who had also suffered from sexual trafficking and abuse, and of possibly protecting future potential victims. 45. On December 23, 2014, Roberts incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. 46. — Roberts intended Victims Refuse Silence to change and improve the fight against sexual abuse and human trafficking. The goal of her organization was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse, and to help others to escape becoming victims of sex trafficking. F. Defendant Acted Maliciously to Defame, Discredit, and Intimidate Roberts 47. Dershowitz made his false and defamatory statements as set forth above on behalf of himself and on behalf of his co-conspirator and client Epstein, in the Southern District of New York and elsewhere, in a deliberate effort to maliciously discredit Roberts and silence her efforts to expose the sexual abuse she suffered. Dershowitz and Epstein did so with the purpose and effect of having others repeat such false and defamatory statements and thereby further damaged Roberts’s reputation. Dershowitz and Epstein knew Dershowitz’s statements were false. 12 HOUSE_OVERSIGHT_017946