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Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 3 of 28 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 out by Epstein to others for sexual purposes. 6. Defendant Dershowitz was Epstein’s attorney, close friend, and co-conspirator. Dershowitz was also a participant in sex trafficking, including as one of the men to whom Epstein lent out Plaintiff for sex. 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), liars and prostitutes. 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” (including himself) from prosecution. 9. On July 7, 2008, a challenge to the NPA was brought on behalf of two of 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. HOUSE_OVERSIGHT_017937