Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 27 of 28

Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 27 of 28 to administer her non-profit foundation, or share her life story, and thereby help others who have suffered from sexual abuse. 100. Asaresult of Dershowitz’s and Epstein’s campaign to spread false, discrediting, and defamatory statements about Roberts, Roberts suffered substantial damages in an amount to be proven at trial. 101. Dershowitz’s false statements have caused, and continue to cause, Roberts economic damage, psychological pain and suffering, mental anguish and emotional distress, and other direct and consequential damages and losses. 102. Dershowitz’s and Epstein’s campaign to spread his false statements nationally and internationally was unusual and particularly egregious conduct. Dershowitz and Epstein sexually abused and trafficked Roberts, conspired to avoid having these crimes properly prosecuted and discovered, and wantonly and maliciously set out to falsely accuse, defame, and discredit Roberts to deny and conceal the scope and scale of their crimes. In so doing, Dershowitz’s efforts constituted a public wrong by deterring, damaging, and setting back Roberts’ efforts to help victims of sex trafficking. Accordingly, this is a case in which exemplary and punitive damages are appropriate. 103. Punitive and exemplary damages are necessary in this case to deter Dershowitz, Epstein and others from wantonly and maliciously using a campaign of lies to discredit Roberts and other victims of sex trafficking. PRAYER FOR RELIEF WHEREFORE, Plaintiff Roberts respectfully requests judgment against Defendant Dershowitz, awarding compensatory, consequential, exemplary, and punitive damages in an 27 HOUSE_OVERSIGHT_017961