Professional Documents
Culture Documents
Complaint
Complaint
VIRGINIA L. GIUFFRE,
v.
ALAN DERSHOWITZ,
Defendant.
________________________ /
COMPLAINT
her Complaint against Defendant, Alan Dershowitz (“Dershowitz”) avers upon personal
knowledge as to her own acts and status and upon information and belief and to all other matters:
Plaintiff.
2. During 2000-2002, beginning when Plaintiff was 16, Plaintiff was the victim of
they would be paid $200 for simply providing a massage to a wealthy billionaire. The young girl
would then be brought up to Epstein’s bedroom where Epstein would be on a massage table;
Epstein would then sexually abuse the girl. This same pattern was repeated numerous times with
numerous children.
4. “From between 1999 – 2007, Jeffrey Epstein sexually abused more than 30 minor
girls…in his mansion in Palm Beach Florida, and elsewhere in the United States and overseas…
In addition to his own sexual abuse of the victims, Epstein directed other persons to abuse the
girls sexually. Epstein used paid employees to find and bring minor girls to him. Epstein
worked in concert with others to obtain minors not only for his sexual gratification, but also for
the sexual gratification of others.” United States District Court Judge Marra February 21, 2016
Summary Judgement Order at 2, Case No.: 9:08-cv-80786 (internal citations omitted). One of
5. Like other minor children who came before and after her, Plaintiff was initially
recruited to provide massages, and thereafter to engage in a variety of sexual acts, for Epstein.
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Plaintiff was required to be on call for Epstein for sexual purposes and frequently traveled with
him both nationally and internationally. Plaintiff was regularly abused by Epstein and was lent
Dershowitz was also a participant in sex trafficking, including as one of the men to whom
7. When Epstein was arrested for sex trafficking in 2006, Dershowitz defended his
friend and client by falsely attacking the veracity of his accusers, including calling the children
whom Epstein had abused (and, in the case of Plaintiff, the Defendant himself had also abused),
8. Despite his significant criminal activity, Epstein’s criminal charges were resolved
by a guilty plea to a single Florida state law charge and a non-prosecution agreement (a “NPA”)
with the U.S. Attorney for the Southern District of Florida. Unknown to the public and the
victims at the time, Epstein’s lawyers, including Dershowitz, were pressuring the Government to
commit to the NPA without informing the victims. Epstein’s multiple victims, including
Roberts, were kept in the dark and told to be “patient” while Dershowitz participated in the
drafting of the NPA and worked to protect Epstein and other “potential co-conspirators”
Epstein’s victims (not including Plaintiff) based on the fact that, contrary to the requirements of
the Criminal Victims’ Rights Act (the “CVRA”), the NPA had been concealed from Epstein’s
victims.
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10. In December 2014, Roberts, who had not initially been part of the CVRA action,
was asked to, and did, provide information to Plaintiffs’ counsel in the CVRA case in which she
discussed her sex trafficking by Epstein. On December 31, 2014, Plaintiff’s counsel in the
CVRA proceeding (Brad Edwards and Paul Cassell) filed a Motion Pursuant to Rule 21 for
Joinder in the Action (“Joinder Motion”) on behalf of Roberts. Ms. Roberts’s joinder motion
described how she had been sexually trafficked by Jeffrey Epstein and was forced to have sex
11. Based on Plaintiff’s December 2014 filing, Dershowitz, as he had previously done
to Epstein’s victims, publically and viciously attacked plaintiff’s counsel in the CVRA actions,
Brad Edwards and Paul Cassell. Dershowitz, in nationally televised news interviews, wrongfully
claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for
filing the Joinder Motion that described Dershowitz’s involvement with Epstein and Roberts.
Edwards, who is a prominent attorney for sexually abused women and children, and Cassell who
is a former United States District Court judge who left the bench to advocate for criminal
victims, sued Dershowitz for defamation. Edwards and Cassell asserted that the factual
allegations that Dershowitz had knowledge of and participated in Epstein’s criminal conduct
were entirely proper and well founded and that Dershowitz’s statements about Edwards and
12. In April 2016 Dershowitz settled the Edwards and Cassell defamation claims
against him. As a condition of the settlement, Dershowitz required that the financial terms of the
interviewing over eighty (80) women, the Miami Herald published the first in a series of articles
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exposing how Epstein and his lawyers had corrupted the legal system to obtain the NPA and
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
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
16. Defendant’s knowledge of the falsity of his attacks on Roberts have not, however,
(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
(b) December 1, 2018: “I never met Roberts; I never had sex with her; she
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Roberts made her claims about Dershowitz “in order to obtain money from a
wealthy businessman and that Roberts had never previously included me among
the people with whom she claimed to have had sex”; “one of Roberts’ own lawyers
has acknowledged in front of witnesses that Roberts claims against me are ‘wrong’
‘simply wrong’”; “I never met Roberts; I never had sex with her; she simply made
(d) December 4, 2018: Plaintiff is a “certified, complete, total liar”; “I can prove
conclusively that she made the whole thing up”. At the same time Dershowitz
claimed “that the FBI recognized the evidence showed he was not where she said
(e) December 5, 2018: “Roberts made up the accusations out of whole cloth in
order to obtain millions of dollars from Leslie Wexner” and “there is evidence that
directly proves I was framed. These include emails between Roberts and a
journalist, a book manuscript by Roberts and a legal brief that are smoking guns
showing that I was deliberately framed for financial reasons.” (Exhibit 5).
(f) March 2, 2019: “My perjuring accusers are Virginia Roberts and Sarah
Ransome [who reported that Epstein lent her out to Dershowitz for sex at the same
18. Dershowitz and Epstein knew Dershowitz’s assertions about Roberts, including
his assertions referenced in paragraph 17 above, were, and would be taken by persons who read
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19. Dershowitz has repeatedly, publically claimed that he wanted to have a trial that
would determine the facts concerning his conduct. He said on national television that he would
waive the statute of limitations so that Roberts could sue him for sex abuse. However, when
Robert’s counsel asked Dershowitz to do so, Dershowitz refused -- and continues to refuse.
20. Similarly, when Dershowitz was faced with an actual case brought by Edwards
and Cassell which would have determined the veracity of Roberts’ claims, Dershowitz settled to
21. More recently, Dershowitz, perhaps believing that Roberts who is now living with
her husband and children in Australia would not be prepared to engage in litigation, has again
taken to claiming publically that he demands a trial on the question of whether Roberts
committed perjury and made up her statements about him for money. For example on March 2,
2019: My “accusers are Virginia Roberts and Sarah Ransome…I hereby accuse my false
accusers of committing the felony of perjury and challenge them to sue me for defamation.”
(Exhibit 6).
22. Mr. Dershowitz now has what he claims to have been looking for.
24. This Court has jurisdiction over this dispute pursuant to 28 U.S.C. §1332
(diversity jurisdiction) in that Roberts and Dershowitz are citizens of different states and the
amount in controversy exceeds seventy-five thousand ($75,000), exclusive of interest and costs.
25. This Court has personal jurisdiction over Defendant. Defendant resides in New
York City; Defendant conducts regular business in New York City; and this action arose,
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defamatory statements were made, and abuse occurred, within the Southern District of New
York.
26. Venue is proper in this Court as (a) the cause of action arose within the
jurisdiction of this Court and (b) Defendant resides within this District.
PARTIES
27. Plaintiff is an individual who is a citizen of the State of Florida and a resident of
Australia.
New York at 2 Tudor City Place Apt. 10EN, New York, New York 10017.
29. Jeffrey Epstein is an individual who resides in the Southern District of New York
FACTUAL ALLEGATIONS
30. Plaintiff became a victim of sex trafficking and repeated sexual abuse after being
recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was under the age of
eighteen.
31. Between 2000 and 2002, Epstein sexually abused Roberts at numerous locations
including his mansions in West Palm Beach, Florida, New Mexico, the Virgin Islands, and this
District. Epstein also flew Roberts on his plane nationally and internationally numerous times
when she was under the age of 18. Only portions of the flight logs of Epstein’s private planes
are yet known, and Epstein also flew Roberts frequently on commercial airlines to meet him and
others. However, the chart below which shows Roberts’ flights on Epstein’s private plane from
the limited logs that are available illustrates the international scope of Epstein’s sex trafficking.
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32. Between 1999 and 2007, with the assistance of numerous co-conspirators, Epstein
abused more than thirty (30) minor underage girls, a fact confirmed by state and federal law
enforcement.
33. After years of abuse, Epstein sent Roberts to Thailand in September 2002. One of
Roberts’ assignments from Epstein was to bring a young girl back to Epstein in the United
States. Fearing for her life, and not wanting to subject another young girl to the abuse she was
forced to endure, Roberts fled from Thailand to Australia to escape from Epstein.
34. Dershowitz has been “a close friend of Mr. Epstein” for many years. (Exhibit 7).
In 2003, Dershowitz said “I’m on my 20th book… The only person outside of my immediate
family that I send drafts to is Jeffrey.” “The Talented Mr. Epstein.” Vanity Fair 2003. (Exhibit
8). Dershowitz also described Epstein as his friend “I would be interested in him [Epstein] as a
friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.”
“Vanity Fair Reminds US When Jeffrey Epstein Wasn’t a Creep.” The Atlantic Wire. June 21,
2011. Dershowitz frequently traveled with Epstein, including on Epstein’s private plane. In
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addition, Epstein’s employees have confirmed that Dershowitz visited Epstein’s Palm Beach and
New York City mansions often, would stay overnight, and was present when the victims of
Epstein’s sex trafficking were there. Dershowitz also visited Epstein’s other homes.
attorney. On or about December 2, 2018, Dershowitz stated that he is still Epstein’s attorney
(Exhibit 9).
36. During the time period that Roberts was being trafficked by Epstein she was
forced to have sex with Alan Dershowitz. Roberts was forced to engage in sexual acts with
Dershowitz in, among other locations, Epstein’s mansion located at 9 East 71st Street, New York,
37. Epstein ultimately pled guilty to procuring a minor for prostitution, and is now a
in which the U.S. Attorney for the Southern District of Florida agreed not to prosecute Epstein
39. In the NPA, the United States Attorney for the Southern District of Florida
additionally agreed that it would not institute any federal criminal charges against any potential
co-conspirators of Epstein.
40. Epstein flippantly referred to his sexual abuse of multiple minors, and the slap on
the wrist he had received for it, in a 2011 interview with the New York Post: “Billionaire pervert
Jeffrey Epstein is back in New York City – and making wisecracks about his just-ended jail stint
for having sex with an underage girl. ‘I am not a sexual predator, I’m an “offender,”’ the
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financier told The Post yesterday. “‘It’s the difference between a murderer and a person who
steals a bagel,’ said Epstein.” February 25, 2011, New York Post “Billionaire Jeffrey Epstein:
41. Rather than confer with the victims about the NPA, the U.S. Attorney’s Office
and Epstein, who was represented by Dershowitz at that time, agreed to a “confidentiality”
42. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey
Epstein’s victims (other than Roberts), filed a petition to enforce her rights under the Crime
Victims’ Rights Act (“CVRA”), 18 U.S.C. ¶ 3771, alleging that the Government failed to
provide her the rights promised in the CVRA with regard to the plea arrangement with Epstein.
43. On February 21, 2019, the Court found that the victims’ rights had been violated
and granted summary judgment in favor of the victims finding: “It was a material omission for
the Government to suggest to the victims that they have patience relative to an investigation
about which it had already bound itself not to prosecute.” Order at 31. In its Order the Court
acknowledged that: “Jeffrey Epstein sexually abused more than 30 minor girls”. The Court also
found: “Among other provisions, the NPA expanded immunity to any ‘potential coconspirator’
compensation in the manner described above, if Epstein successfully fulfills all of the terms and
conditions of this agreement, the United States also agrees that it will not institute any criminal
charges against any potential co-conspirators of Epstein, including but not limited to Sarah
Kellen, Adriana Ross, Lesley Groff or Nadia Marcinkova… From the time the FBI began
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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
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.
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.
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.
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48. Dershowitz made his statements to discredit Roberts in concert with Epstein and
conspiracy to discredit and try to silence Roberts. Epstein was particularly interested in
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
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
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
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was no ‘international sex-trafficking operation’ and there was never evidence that Mr. Epstein
G. Dershowitz’s Lies
53. From the beginning, Dershowitz and Epstein have sought to hide their crimes
Epstein’s sex trafficking, Dershowitz began a series of intentional, outright lies designed to
distance himself from Epstein, to cover up his own wrongdoing, and to discredit Roberts and
54. Dershowitz’s repeated lies are compelling evidence both of his lack of credibility
and his guilt. Only a person seeking to conceal improper conduct would have engaged in the
pattern of lies which has characterized Dershowitz’s statements since his sex trafficking was
revealed.
55. In attempt to conceal his relationship with Epstein, Dershowitz in January 2015
asserted that “my relationship with him was entirely professional. It is a total bum rap to say that
I…was ‘chummy’ with him”. (Exhibit 11). That was a lie, as Dershowitz and Epstein knew (see,
56. Both to conceal Dershowitz’s relationship with Epstein, and to discredit Roberts,
Dershowitz has repeatedly asserted that he was only at Epstein’s residence once in Palm Beach,
and that was with his family. However, Juan Alessi, a long time Epstein household employee,
has confirmed that Dershowitz visited Epstein “pretty often. I would say at least four or five
times a year” and that he would “typically” stay two or three days. Similarly, Alfredo Rodriguez
who worked for Epstein approximately only six months confirmed that during that six months
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57. Again, both to conceal his relationship with Epstein and to discredit Roberts,
Dershowitz has repeatedly asserted that he was never in Epstein’s residence in the presence of
young women. As both Dershowitz and Epstein know, that assertion was also false. As Mr.
Rodriguez has confirmed, there were “also young ladies in the house at the time he [Dershowitz]
was there”. Mr. Rodriguez also confirmed that “Mr. Dershowitz was there” when “women came
to Mr. Epstein’s home to give a massage”. Mr. Rodriguez also confirmed that “Alan Dershowitz
was at the house” with “the local Palm Beach girls” who he was “told to call masseuses”,
although he did not himself know whether or not Dershowitz personally received a massage.
58. Maria Farmer was an employee of Epstein responsible for “manning the front
door at his New York mansion and keeping records of people who came to the home” (Exhibit
12, ¶ 2).
(a) Ms. Farmer “witnessed a number of school age girls coming to the house,
some of the young girls would be wearing their school uniforms”…who “then
(b) Ms. Farmer was told these young girls “were interviewing for modeling
positions” even though “it did not seem credible to me that these young girls were
59. Ms. Farmer asserts that “Alan Dershowitz was an individual who came to visit
Epstein at his New York mansion a number of times when I was working for Epstein.
Dershowitz was very comfortable at the home and would come in and walk upstairs. On a
number of occasions I witnessed Dershowitz at the NY mansion going upstairs at the same time
there were young girls under the age of 18 who were present upstairs in the house” (Exhibit 12, ¶
4).
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60. Ms. Farmer, like other victims of, and witnesses to, Epstein and Dershowitz’s sex
trafficking and abuse has been subjected to attacks and intimidations. (Exhibit 12, ¶¶ 8-9). Her
courageous testimony, together with the sworn testimony of victims such as Sarah Ransome and
witnesses such as Mr. Alessi and Mr. Rodriguez , proves beyond any doubt that Dershowitz’s
claims that he was never present where Ms. Roberts was trafficked, and never in the presence of
61. Again both to conceal his relationship with Epstein and to discredit Roberts,
Dershowitz has repeatedly asserted that he has records that prove that it would have been
“impossible” for him to be with Roberts because he was never in the same place and time as
Roberts. As both Dershowitz and Epstein know, that too was a lie. The testimony of Epstein’s
household staff establishes that Dershowitz was repeatedly at Epstein’s residence. Even
Dershowitz’s own selected, incomplete, and apparently revised, records demonstrate that
Dershowitz was present at locations where Ms. Roberts was with Epstein.
62. Dershowitz’s assertion that Roberts accused him of having sex with her only after
her lawyers convinced her to do so in late 2014 is not only false, as both Dershowitz and Epstein
63. Roberts had identified Dershowitz as a participant in her sexual abuse at the time
it occurred. She did so again in 2009. In 2010 Epstein’s co-conspirators were repeatedly asked
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“Alan Dershowitz is also somebody that you also know to have been at the house
when L.M. was being sexually abused in Jeffrey Epstein’s bedroom, correct?”
(a) On August 23, 2011: “We…have reason to believe that you have
65. Dershowitz lied and stated that he had never flown on Jeffrey Epstein’s plane
with a young woman and always flew with his wife. (Hala Gorani, CNN Live, Jan. 5, 2015).
However, even the limited publically available flight logs of Jeffrey Epstein’s private plane
demonstrate that Dershowitz flew often on Epstein’s planes without his wife; with young
women, including a Victoria’s Secret model; Epstein’s procurer Ghislaine Maxwell; and Sarah
Kellen who was identified by the Government as Epstein’s co-conspirator in his sex trafficking.
66. Dershowitz also lied by saying that he “never” got a massage from anybody: “I
never got a massage from anybody. It’s made up out of whole cloth.” (NY Daily News, January
21, 2015). However, after it was revealed that Epstein’s household staff identified Dershowitz as
one of the recipients of “massages” at Epstein’s Palm Beach mansion, Dershowitz changed his
story and admitted he got a massage at Epstein’s Palm Beach home but claimed: “I kept my
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67. Dershowitz lied and said he never saw any naked pictures of females in Epstein’s
Palm Beach home during his many visits, yet the police footage that was obtained from the
search of Epstein’s home proves that there were naked pictures of females throughout the home
68. In a desperate attempt to deflect attention from his own misconduct, Dershowitz
fabricated an extortion plot by Roberts and her lawyers. Dershowitz falsely told the media that
he was being used as a pawn as part of a fanciful plan to extort money from a billionaire business
mogul and colleague of Epstein. Dershowitz’s claim was that he was framed in order to send a
message to the billionaire that this is what would happen to the billionaire if the billionaire did
(c) Roberts’ assertions about Dershowitz long predated the time of the alleged
extortion plot.
69. Dershowitz also falsely claimed that Roberts’ lawyer had told him that he had
concluded that Roberts was “wrong” and “simply wrong” in accusing Dershowitz. Dershowitz,
in violation of the canons of ethics and in at least one case in violation of state law, had
surreptitiously tape recorded confidential settlement negotiations he had engaged in with Ms.
Roberts’ lawyer. Dershowitz then played and described excerpts from those tapes out of context
to reporters to try to make it appear that Ms. Roberts’ lawyer’s hypothetical comments, and
testimony (Exhibit 13) of Dershowitz’s own lawyer, and the facts set forth below, demonstrate,
Dershowitz’s assertions about what Ms. Roberts’ lawyer said are, again, false.
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70. In May 2015 Dershowitz requested confidential settlement negotiations with Ms.
Roberts’ lawyers in which Dershowitz sought to convince Ms. Roberts lawyer that Ms. Roberts
was mistaken, and that the person to whom Epstein had lent Ms. Roberts was Nathan Myhrvold,
not Dershowitz. Dershowitz claimed that he had been at Epstein’s home only once (and that he
was there with his family); that he had never been in the vicinity of Epstein’s island; that he had
not been at Epstein’s New York mansion; and that he had been at Epstein’s New Mexico ranch
only once for a few hours (again with his family). Dershowitz provided a summary of his
71. Dershowitz was told that, based on what was shown in his summary, it would
have been impossible for Ms. Roberts’ assertions about him to be true, and that if his assertions
proved out, Ms. Roberts counsel would undertake to convince her that she must have made a
mistake.
(a) Dershowitz was also told, however, (i) that his assertions would have to be
proven, (ii) that Ms. Roberts had always been very clear that she recalled having
had sex with Dershowitz multiple times, and (iii) that everyone was convinced
that Ms. Roberts was telling the truth as she recalled it.
(b) Dershowitz responded that he did not doubt that Ms. Roberts was telling
the truth as she recalled it and that she would have no difficulty passing a lie
detector test. He said he simply believed Ms. Roberts had made an honest mistake
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(b) Dershowitz’s key claim that he had not stayed at Epstein’s house was
Alessi (see ¶ 56 above) and Alfredo Rodriguez (see ¶¶ 56-57 above) as well as the
testimony of Sarah Ransome (Exhibit 14) and Maria Farmer (Exhibit 12).
(c) Dershowitz’s claim that Ms. Roberts confused him with Nathan Myhrvold
was tested by showing Ms. Roberts pictures of both. She was, and is, clear that it
(d) Dershowitz’s claim he had never been on Epstein’s plane without his wife
(e) Dershowitz’s claim that he had never seen pictures of young females at
Epstein’s house was proven false by Palm Beach police and FBI reports.
(f) Dershowitz’s claim that he had never been in the presence of young
females was proven false by the testimony of Epstein’s household employer (see
¶¶56-57) and of young women themselves (see Exhibit 14 [Ransome] and Exhibit
12 [Farmer].)
73. After Dershowitz’s claimed proof of exonerating evidence collapsed, and the
evidence of his guilt grew, Roberts’ lawyer’s told Dershowitz in writing that they “had
discovered evidence inconsistent with some of [your] representations”, that his travel “records
were incomplete”, and that he “should have settled the case when he had a chance”.
74. Roberts’ lawyer explicitly told Dershowitz that neither Roberts nor her lawyer
would make any statement saying or implying that Roberts was mistaken in her charge that
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Dershowitz participated in her sexual trafficking and abuse. In his public statements, Dershowitz
conspicuously omits any reference to the statements by Roberts’ lawyers after they had
75. Faced with the mounting evidence of his guilt, Dershowitz abandoned his attempt
to get Roberts or her lawyer to concede a mistake or that Roberts had been wrong, and
76. In December 2015 Ms. Roberts’ counsel again told Mr. Dershowitz that “Virginia
is adamant about her current recollection” and that neither Ms. Roberts nor her counsel believed
she was mistaken in identifying Mr. Dershowitz as one of the men to whom Epstein had lent her
out for sex. In response, Mr. Dershowitz did not claim that Ms. Roberts lawyers had told him
77. Instead, the morning of December 9, 2015, Mr. Dershowitz pleaded: “David,
Have we given up on a mutually acceptable statement from VR or you. Let’s keep trying. We are
not that far apart.” (Exhibit 15). When Ms. Roberts lawyer did not immediately respond, Mr.
was the person with whom I had sex, recent developments raise the
(Exhibit 15).
Mr. Dershowitz went on to write: “It would be acceptable if the statement came from you rather
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78. Wholly absent at this point was any assertion by Mr. Dershowitz that Ms. Roberts
was lying, or that she made up her charge as part of an extortion claim, or that after investigating
his alleged evidence Ms. Roberts’ lawyer did not believe her. On the contrary, Mr. Dershowitz
expressly recognized that Ms. Roberts’ belief was an honest one. All Mr. Dershowitz was
pleading for was an acknowledgement that there was a “possibility” that there “may be” a case of
mistaken identification. Even that plea was rejected by Ms. Roberts and her lawyers as
misleading.
79. Dershowitz’s present PR claim that Roberts’ lawyers disbelieved their client, and
that Roberts intentionally committed perjury as part of an extortion scheme, is just another
Dershowitz lie. His reliance on statements taken out of context, his failure to include the
statements of Roberts’ lawyer after Dershowitz’s supposed evidence had been investigated, and
the damning admissions of his own lawyers, reveal Dershowitz’s total lack of support for his
allegation that Roberts and her lawyers concocted knowingly false allegation against him as part
80. Dershowitz also lied to attempt to deflect Sarah Ransome’s revelations about him.
Ms. Ransome revealed that during the time she was a victim of Epstein’s sex trafficking,
Epstein’s arranged for his lawyer, Dershowitz, to also represent Ms. Ransome. Ms. Ransome
also described how, during the time Dershowitz was her lawyer, Epstein lent her out to
81. Dershowitz asserted that he never had sex with Ms. Ransome, that he never
represented Ms. Ransome, that he did not even know Ms. Ransome, and that Ms. Ransome’s
statements about him were fabricated by Ms. Roberts’ lawyer in retaliation for a bar complaint
that Dershowitz had filed against that lawyer (Exhibit 16). However, as Dershowitz knew:
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preceded any contact with Roberts’ attorneys. For example, Ransome’s first
contact with any of Roberts’ lawyers was in November 2016, and at least as early
someone who had had sex with one or more of the girls provided by Epstein and
82. After settling the case against him brought by Messrs. Edwards and Cassell,
Dershowitz told the media he had been vindicated, while at the same time insisting that the term
of the settlement remains confidential. Edwards and Cassell responded: “Following the
announcement of the settlement of defamation claims against Alan Dershowitz, he has been
making public statements suggesting that he has prevailed in the lawsuit and that the terms of the
settlement exonerate him of any wrongdoing. Those statements are at best misleading. It is a
mistake for anyone to conclude based upon Mr. Dershowitz’s statements that the case against
him was abandoned due to lack of factual support. It is a mistake for anyone to conclude based
upon Dershowitz’s statements that Bradley Edwards and Paul Cassell had determined that the
allegations against Alan Dershowitz made by Virginia Roberts Giuffre were false or unfounded.
Neither the terms of settlement nor the agreed upon joint public statement issued as part of the
settlement support any such conclusion and it is false to state or suggest otherwise.” Dershowitz
Settles Sex Case, But is He Vindicated? The American Lawyer, April 10, 2016.
83. Dershowitz continues to this day to insist that the terms of his settlement with
Edwards and Cassell remain confidential -- a position that can only be explained by
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Dershowitz’s knowledge that revealing how much he had paid to avoid a trial of the allegations
84. As described above, Dershowitz has also repeatedly asserted that he wanted to
have a trial to establish his innocence. By contrast, he paid to settle the case that would have
provided that trial. He even lied about his being willing to waive the statute of limitations so that
Roberts could sue him for sex abuse -- a lie almost immediately exposed when he was promptly
COUNT I DEFAMATION
85. Plaintiff Roberts re-alleges paragraphs 1 – 84 as if the same were fully set forth
herein. Dershowitz made his false and defamatory statements deliberately and maliciously with
86. In December 2018, and thereafter, Dershowitz, on behalf of himself and Epstein,
intentionally and maliciously released to the press his false statements about Roberts in an
attempt to destroy Roberts’ reputation and brand her as a liar and cause her to lose all credibility
87. Dershowitz and Epstein knew that Dershowitz’s assertions would dilute, discredit,
and neutralize Roberts’s public and private messages to sexual abuse victims and ultimately
prevent Roberts from effectively providing assistance and advocacy on behalf of other victims of
88. Using his role as a powerful lawyer with powerful friends, Dershowitz’s
statements were published internationally for the malicious purpose of further damaging a sexual
abuse and sexual trafficking victim; to destroy Roberts’s reputation and credibility; to cause the
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world to disbelieve Roberts; and to destroy Roberts’s efforts to use her experience to help others
89. Dershowitz, personally, intentionally, and maliciously made false and damaging
statements of fact concerning Roberts, as detailed above, in the Southern District of New York
and elsewhere.
90. The false statements that Dershowitz made, personally on behalf of himself and
Epstein not only called Roberts’s truthfulness and integrity into question, but also exposed
91. At the time Dershowitz made his false statements, he and Epstein, knew full well
92. Dershowitz’s false statements constitute libel, as he and Epstein knew that they
were going to be transmitted in writing, widely disseminated on the internet and in print.
Dershowitz intended his false statements to be published by newspaper and other media outlets
internationally, and they were, in fact, published globally, including within the Southern District
of New York.
93. Dershowitz’s false statements constitute libel per se, including that they accused
her of a crime, and including that they exposed Roberts to public contempt, ridicule, aversion,
and disgrace, and induced an evil opinion of her in the minds of right-thinking persons.
94. Dershowitz’s false statements also constitute libel per se, inasmuch, among other
reasons, as they tended to injure Roberts in her professional capacity as the president of a non-
profit corporation designed to help victims of sex trafficking, and inasmuch as they destroyed her
credibility and reputation among members of the community that seeks her help and that she
seeks to serve.
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95. Dershowitz’s false statements directly stated and also implied that in speaking out
against sex trafficking Roberts acted with fraud, dishonesty, and unfitness for the task.
Dershowitz’s false statements directly and indirectly assert that Roberts lied about being sexually
trafficked and abused by Epstein and having sex with Dershowitz, and that Roberts committed
the crimes of perjury and extortion. Dershowitz’s false statements were reasonably understood
by many persons who read his statements as conveying that specific intention and meaning.
96. Dershowitz’s false statements were reasonably understood by many persons who
read those statements as making specific factual claims that Roberts was lying about specific
97. Dershowitz specifically directed his false statements at Roberts’ true public
description of factual events, and many persons who read Dershowitz’s statements reasonably
understood that those statements referred directly to Roberts’ account of the abuse she suffered at
published and disseminated on television, through newspapers, by word of mouth, and on the
internet. As intended by Dershowitz and Epstein, Dershowitz’s statements were published and
99. Dershowitz made his false statements on behalf of himself and Epstein in reckless
disregard of their truth or falsity and with malicious intent to destroy Roberts’s reputation and
credibility; to prevent her from further disseminating her life story; and to cause persons hearing
or reading Roberts’s descriptions of truthful facts to disbelieve her entirely. Dershowitz made his
false statements on behalf of himself and Epstein wantonly and with the specific intent to
maliciously damage Roberts’s good name and reputation in a way that would destroy her efforts
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to administer her non-profit foundation, or share her life story, and thereby help others who have
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
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
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
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amount to be determined at trial, but in excess of the $75,000 jurisdictional requirement; costs of
suit; attorneys’ fees; and such other and further relief as the Court may deem just and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all causes of action asserted within this
pleading.
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