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Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 25 of 28 world to disbelieve Roberts; and to destroy Roberts’s efforts to use her experience to help others suffering as sex trafficking victims. 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 Roberts to public hatred, contempt, ridicule, and disgrace. 91. At the time Dershowitz made his false statements, he and Epstein, knew full well that they were completely false. 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. 25 HOUSE_OVERSIGHT_017959