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Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 24 of 28 Dershowitz’s knowledge that revealing how much he had paid to avoid a trial of the allegations against him would reveal his guilt. 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 asked to do so and, equally promptly refused. 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 the intent to intimidate, discredit and defame Roberts. 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 in her efforts to help victims of sex trafficking. 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 sex trafficking, or expose her abusers. 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 24 HOUSE_OVERSIGHT_017958