Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 13 of 28

Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 13 of 28 48. Dershowitz made his statements to discredit Roberts in concert with Epstein and others, including Ghislaine Maxwell, one of Epstein’s long-time procurers, as part of a conspiracy to discredit and try to silence Roberts. Epstein was particularly interested in discrediting and silencing Roberts because he feared a reopening of a federal criminal investigation of him. 49. Dershowitz made his statements pursuant to his conspiracy with Epstein and Maxwell maliciously as part of an effort to conceal sex trafficking crimes committed around the world by Epstein and other powerful persons. 50. | Dershowitz and Epstein intended Dershowitz’s false and defamatory statements set out above to be broadcast around the world and to intimidate and silence Roberts from making further efforts to expose sex crimes committed by Epstein and other powerful persons, including Dershowitz. 51. | Dershowitz and Epstein intended their false statements to be specific statements of fact. Dershowitz’s false statements were, as he and Epstein intended, broadcast around the world and were reasonably understood by those who heard them to be specific factual claims by Dershowitz that he had not had sex with Roberts, that Roberts was intentionally lying about having sex with Dershowitz, that Roberts committed the crime of perjury, that Roberts had committed the crime of extortion, and that Roberts had intentionally fabricated her assertions about Dershowitz to extort money from others. 52. Epstein also worked with other of his attorneys to attack Roberts’ allegations, including in a false statement they made in a letter to the editor to the New York Times asserting: “The number of young women involved in the investigation has been vastly exaggerated, there 13 HOUSE_OVERSIGHT_017947