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.. From the time the FBI 
began 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 under consideration." Id. at 8. 
E. 
Victims Refuse Silence 
48. 
Ultimately, as a mother and one of Epstein's many victims, Plaintiff 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. 
49. 
On December 23, 2014, Plaintiff incorporated an organization called Victims 
Refuse Silence, Inc., a Florida not-for-profit corporation. 
50. 
Plaintiff 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. 
F. 
Defendant Acted Maliciously to Defame, Discredit, and Intimidate Plaintiff 
51. 
Defendant made his false and defamatory statements as set forth above in the 
Southern District of New York and elsewhere, in a deliberate effort to maliciously discredit 
Plaintiff and silence her efforts to expose the sexual abuse she suffered. Defendant did so with 
the purpose and effect of having others repeat such false and defamatory statements and thereby 
further damaged Plaintiff's reputation. Defendant knew his statements were false. 
52. 
Defendant made his statements to discredit Plaintiff in concert with Epstein and 
others, including Ghislaine Maxwell, one of Epstein's long-time procurers, as part of a 
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conspiracy to discredit and try to silence Plaintiff. Epstein was particularly interested in 
discrediting and silencing Plaintiff because he feared a reopening of a federal criminal 
investigation of him. 
53. 
Defendant 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 
world by Epstein and other powerful persons. 
54. 
Defendant intended his false and defamatory statements set out above to be 
broadcast around the world and to intimidate and silence Plaintiff from making further efforts to 
expose sex crimes committed by Epstein and other powerful persons, including Defendant. 
55. 
Defendant intended his false statements to be specific statements of fact. 
Defendant's false statements were, as he intended, broadcast around the world and were 
reasonably understood by those who heard them to be specific factual claims by Defendant that 
he had not had sex with Plaintiff, that Plaintiff was intentionally lying about having sex with 
Defendant, that Plaintiff committed the crime of perjury, that Plaintiff had committed the crime 
of extortion, and that Plaintiff had intentionally fabricated her assertions about Defendant to 
extort money from others. 
56. 
Epstein also worked with other of his lawyers to attack Plaintiffs 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 
was no `international sex-trafficking operation' and there was never evidence that Mr. Epstein 
'hosted sex parties' at his home." Kenneth W. Starr, Martin G. Weinberg, Jack Goldberger, and 
Lilly Ann Sanchez, Jeffrey Epstein 's Attorneys: A Fair Plea Deal, NY TIMES (Mar. 4, 2019), 
https://nyti.ms/2EGHpnf. 
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G. 
Defendant's Lies 
57. 
From the beginning, Defendant has sought to hide his crimes behind a curtain of 
lies. In response to Plaintiff's description of Defendant's participation in Epstein's sex 
trafficking, Defendant began a series of intentional, outright lies designed to distance himself 
from Epstein, to cover up his own wrongdoing, and to discredit Plaintiff and intimidate her into 
silence. 
58. 
Defendant'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 Defendant's statements since his sex trafficking was 
revealed. 
59. 
In an attempt to conceal his relationship with Epstein, Defendant 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." That was a lie, as Defendant knew (see, e.g., paragraphs 34-35). 
60. 
Both to conceal Defendant's relationship with Epstein and to discredit Plaintiff, 
Defendant has repeatedly asserted that he was not at Epstein's residence in Palm Beach at all 
during the period when Plaintiff was trafficked. However, Juan Alessi, a long time Epstein 
household employee whose tenure with Epstein included the period of Plaintiffs trafficking, has 
confirmed that Defendant 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 in Palm Beach approximately only six months several years later, confirmed 
that during that six-month period, Defendant visited Epstein twice. 
61. 
Again, both to conceal his relationship with Epstein and to discredit Plaintiff, 
Defendant has repeatedly asserted that he was never in Epstein's residence in the presence of 
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young women. As Defendant knows, that assertion was also false. As Mr. Rodriguez has 
confirmed, there were "also young ladies in the house at the time he [Defendant] 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" whom he was "told to call masseuses," although he did 
not himself know whether Dershowitz personally received a massage. 
62. 
vas 
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. 
(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 and would be 
escorted upstairs. 
(b) 
Ms. Farmer was told these young girls were interviewing for modeling 
positions even though it did not seem credible to her that these young girls were 
interviewing for modeling positions. 
63. 
Ms. Farmer asserts that she witnessed Defendant visit Epstein at his New York 
mansion a number of times when she was working for Epstein. Defendant was very comfortable 
at the home and would come in and walk upstairs. On a number of occasions, she witnessed 
Defendant going upstairs at the same time there were young girls under the age of 18 who were 
present upstairs in the house. 
64. 
Ms. Farmer, like other victims of, and witnesses to, Epstein's and Defendant's sex 
trafficking and abuse, has been subjected to attacks and intimidations. Her courageous testimony, 
together with the sworn testimony of victims such as 
land witnesses such as Mr. 
Alessi and Mr. Rodriguez, show that Defendant's claims that he was never present where 
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Plaintiff was trafficked and never in the presence of young girls are lies intended to cover up his 
culpability. 
65. 
Again, both to conceal his relationship with Epstein and to discredit Plaintiff, 
Defendant has repeatedly asserted that he has records that prove that it would have been 
"impossible" for him to be with Plaintiff because he was never in the same place and time as 
Plaintiff. As Defendant knew, that too was a lie. The testimony of Epstein's household staff 
establishes that Defendant was repeatedly present at Epstein's residence. Even Defendant's own 
selected, incomplete, and apparently revised, records demonstrate that Defendant was present at 
locations where Plaintiff was with Epstein. 
66. 
Defendant's assertion that Plaintiff accused him of having sex with her only after 
her lawyers convinced her to do so in late 2014 is not only false, as Defendant knows, but 
thoroughly disproved by the record. 
67. 
Plaintiff had identified Defendant 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 
about Defendant. For example: 
(a) 
fused to answer on Fifth Amendment grounds whether 
"Alan Dershowitz stays at Jeffrey Epstein's house . . . when underage minor 
females have been in the bedroom with Jeffrey Epstein". • 
(b) 
refused to answer on Fifth Amendment grounds: "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?" 
68. 
In 2011, lawyers for Edwards wrote Defendant: 
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(a) 
On August 23, 2011: "We...have reason to believe that you have 
personally observed Jeffrey Epstein in the presence of underage females." 
(b) 
On September 7, 2011: "Multiple individuals have placed you in the 
presence of Jeffrey Epstein on multiple occasions and in various locations when 
Jeffrey Epstein was in the company of underage females subsequently identified 
as victims of Mr. Epstein's criminal molestations." 
69. 
Defendant lied and stated that he had never flown on Epstein's plane with a young 
woman and always flew with his wife. See Hala Gorani, Alan Dershowitz: Lawsuit claims 
'utterly untrue', CNN (Jan. 5, 2015), https://cnn.it/2SbaAXU. However, even the limited 
publicly available flight logs of Epstein's private plane demonstrate that Defendant flew often on 
Epstein's planes without his wife; with young women, including a Victoria's Secret model; with 
Epstein's co-conspirator and procurer Ghislaine Maxwell; and 
who was identified 
by the Government as Epstein's co-conspirator in his sex-trafficking. 
70. 
Defendant 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." Dareh Gregorian, Alleged 
'sex slave' 
says she didn't have sex with former President Bill Clinton, but in 
explosive court filing, details I I-person orgy with Prince Andrew and others, NY DAILY NEWS 
(Jan. 21, 2015), https://bit.ly/2Z3gX0K. However, after it was revealed that Epstein's household 
staff identified Defendant as one of the recipients of "massages" at Epstein's Palm Beach 
mansion, Defendant changed his story and admitted he got a massage at Epstein's Palm Beach 
home but claimed: "I kept my underwear on during the massage." Bob Norman, Alan 
Dershowitz: Sex slave' accuser is serial liar, prostitute, LOCAL 10 NEWS (Jan. 22, 2015), 
https://bit.ly/36YraOR. 
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71. 
Defendant 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, 
including in the common areas. 
72. 
Defendant also lied to attempt to deflect 
revelations about him. 
Ms. Ransome revealed that during the time she was a victim of Epstein's sex trafficking, Epstein 
arranged for his lawyer, Defendant, to also represent Ms. Ransome. Ms. Ransome also described 
how, during the time Defendant was her lawyer, Epstein lent her out to Defendant for sex. 
73. 
Defendant 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 Plaintiff's lawyer in retaliation for a bar complaint that 
Defendant had filed against that lawyer. However, as Defendant knew: 
(a) 
He did have sex with Ms. Ransome. 
(b) 
He was Ms. Ransome's lawyer. 
74. 
Ms. Ransome's statements about her involvement with Defendant preceded any 
contact with Plaintiff's lawyers. For example, Ransome's first contact with any of Plaintiff's 
lawyers was in November 2016, and at least as early as October 2016, Ransome had identified 
Defendant in writing to a reporter as someone who had had sex with one or more of the girls 
provided by Epstein and that Epstein had arranged for Defendant to be Ransome's lawyer. 
H. 
Defendant's Conspiracy Theory 
75. 
In a desperate attempt to deflect attention from his own misconduct, Defendant 
fabricated an extortion plot by Plaintiff and her lawyers. Defendant falsely told the media that he 
was being used by Plaintiff and her lawyers as a pawn to extort money from a billionaire 
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business mogul and colleague of Epstein. Defendant claims 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 
not pay Plaintiff and her lawyers. As Defendant knew: 
(a) 
(b) 
(c) 
No complaint was ever made against the billionaire. 
No money was either paid by or demanded from the billionaire. 
There was no such extortion plot. 
76. 
Defendant also falsely claimed that Plaintiff's lawyer had told him that he had 
concluded that Plaintiff was "wrong" and "simply wrong" in accusing Defendant. Defendant, in 
violation of the canons of ethics and in at least one case in violation of federal and state law, 
surreptitiously tape-recorded confidential settlement negotiations in which he had engaged with 
Plaintiff's lawyer, David Boies. 
77. 
During these conversations, Boies was acting as Plaintiff's lawyer and agent, and 
neither he nor she consented to the recording. 
78. 
Defendant then played and/or described excerpts from those tapes out of context 
to reporters and in court filings to make it appear that Plaintiff's lawyer's hypothetical comments 
and characterizations of Defendant's assertions represented that lawyer's conclusions. As the 
sworn testimony of Defendant's own lawyer and the facts set forth below demonstrate, 
Defendant's assertions about what Plaintiff's lawyer said are, again, false. 
79. 
In May 2015, Defendant requested confidential settlement negotiations with 
Plaintiff's lawyers in which Defendant sought to convince Plaintiff's lawyers that Plaintiff was 
mistaken, and that the person to whom Epstein had lent Plaintiff was Nathan Myhrvold, not 
Defendant. Defendant claimed that from 1999-2002, he had not visited Epstein's Palm Beach 
home, that he had never been in the vicinity of Epstein's island, and that he had been at Epstein's 
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New Mexico ranch only once for a few hours (with his family). Defendant provided a summary 
of his whereabouts during the period from 1999-2002 that purported to prove that his assertions 
were true. 
80. 
Defendant was told that, based on what was shown in his travel summary, it 
would have been impossible for Plaintiff's assertions about him to be true, and that if his 
assertions proved out, Plaintiff's lawyers would undertake to convince her that she must have 
made a mistake. 
(a) 
Defendant was also told, however, (i) that his assertions would have to be 
proven, (ii) that Plaintiff had always been very clear that she recalled having had 
sex with Defendant multiple times, and (iii) that everyone was convinced that 
Plaintiff was telling the truth as she recalled it. 
(b) 
Defendant responded that he did not doubt that Plaintiff 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 Plaintiff had made an honest mistake in confusing 
him with Nathan Myhrvold. 
81. 
Following Defendant's presentations, Defendant's representations were 
investigated and repeatedly proven false. 
(a) 
Defendant's alleged backup for his travel summary proved to be 
incomplete, inconsistent, and in some instances, apparently altered. 
(b) 
Defendant's key claims about the frequency with which he visited 
Epstein's houses were proven false, including by the testimony of Epstein's 
household employees Mr. Alessi (see paragraph 60 above) and Mr. Rodriguez 
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(see paragraphs 60-61 above), as well as the testimony of Ms. Ransome and Ms. 
Farmer. 
(c) 
Defendant's claim that Plaintiff confused him with Nathan Myhrvold was 
tested by showing Plaintiff pictures of both. She confirmed that it was Defendant, 
not Myhrvold, with whom she had sex. 
(d) 
Defendant's claim he had never been on Epstein's plane without his wife 
was proven false by plane logs. 
(e) 
Defendant'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. 
(0 
Defendant's claim that he had never been in the presence of young 
females was proven false by the testimony of Epstein's household employee (see 
paragraphs 60-61) and of young women themselves. 
82. 
After Defendant's claimed proof of exonerating evidence collapsed, and the 
evidence of his guilt grew, Plaintiff's lawyers told Defendant in writing that they "had 
discovered evidence inconsistent with some of [your] representations," and that his travel 
"records were incomplete." 
83. 
Plaintiff's lawyer explicitly told Defendant that neither Plaintiff nor her lawyer 
would make any statement saying or implying that Plaintiff was mistaken in her charge that 
Defendant participated in her sexual trafficking and abuse. 
84. 
Faced with the mounting evidence of his guilt, Defendant abandoned his attempt 
to get Plaintiff or her lawyer to concede a mistake or that Plaintiff had been wrong, and 
desperately sought even a suggestion that an error was "possible." 
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85. 
In December 2015, Plaintiff's lawyers again told Defendant that "Virginia is 
adamant about her current recollection" and that neither Plaintiff nor her lawyers believed she 
was mistaken in identifying Defendant as one of the men to whom Epstein had lent her out for 
sex. In response, Defendant did not claim that Plaintiff's lawyers had told him that they did not 
believe her. 
86. 
Instead, the morning of December 9, 2015, Defendant 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." When Plaintiff's lawyer did not immediately respond, Defendant wrote later the same 
day: 
We should be aiming at a short simple statement such as: "The 
events at issue occurred approximately 15 years ago when I was a 
teenager. Although I believed then and continued to believe that AD 
was the person with whom I had sex, recent developments raise the 
possibility that this may be a case of mistaken identification." 
Defendant went on to write: "It would be acceptable if the statement came from you rather than 
her, if she prefers." 
87. 
Wholly absent at this point was any assertion by Defendant that Plaintiff was 
lying, or that she made up her charge as part of an extortion claim, or that after investigating his 
alleged evidence Plaintiff's lawyer did not believe her. On the contrary, Defendant expressly 
recognized that Plaintiff's belief was an honest one. All Defendant was pleading for was an 
acknowledgement that there was a "possibility" that there "may be" a case of mistaken 
identification. 
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88. 
Defendant has played selective portions of his recordings to members of the press 
in an effort to persuade the public that Plaintiff's lawyers disbelieve her. He has also made sworn 
representations concerning the contents of the tape to the Court. In his statements, Defendant 
conspicuously omits any reference to the statements by Plaintiffs lawyers after they had 
investigated his representations and concluded that they were false. 
89. 
Defendant's present PR claim that Plaintiff's lawyers disbelieved their client, and 
that Plaintiff intentionally committed perjury as part of an extortion scheme, is just another 
Defendant lie. His reliance on statements from settlement negotiations that have been taken out 
of context, his failure to include the statements of Plaintiff's lawyer after Defendant's supposed 
evidence had been investigated, and the damning admissions of his own lawyer, reveal 
Defendant's total lack of support for his allegation that Plaintiff and her lawyers concocted 
knowingly false allegations against him as part of a supposed extortion plot. 
90. 
Further belying his conspiracy theory, Defendant settled the case against him 
brought by Plaintiff's then-lawyers Edwards and Cassell accusing him of defamation for 
publishing false accusations that they conspired with Plaintiff to fabricate her claims. 
91. 
After the settlement, Defendant told the media he had been vindicated, while at 
the same time insisting that the terms 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 Mr. Dershowitz's statements that Bradley Edwards and Paul 
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Cassell had determined that the allegations against Alan Dershowitz made by 
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 conclusions, and it is false to state or 
suggest otherwise." Dershowitz Settles Sex Case, But Is He Vindicated?, THE AMERICAN 
LAWYER (Apr. 10,2016), https://bit.ly/2tAuSQd. 
92. 
Defendant continues to this day to insist that the terms of his settlement with 
Edwards and Cassell remain confidential—a position that can be explained only by Defendant's 
knowledge that revealing how much he had paid to avoid a trial of the allegations against him 
would confirm his guilt. 
93. 
As described above, Dershowitz has also repeatedly asserted that he wanted to 
have a trial to establish his innocence. By contrast, he settled the case that would have provided 
that trial (and refuses to disclose the amount paid to the plaintiffs). He even lied about his being 
willing to waive the statute of limitations so that Plaintiff could sue him for sex abuse—a lie 
almost immediately exposed when he was promptly asked to do so and refused. 
COUNT I DEFAMATION 
94. 
Plaintiff re-alleges paragraphs 1-93 as if the same were fully set forth herein. 
Defendant made his false and defamatory statements deliberately and maliciously with the intent 
to intimidate, discredit and defame Plaintiff. 
95. 
In November 2018, and thereafter, Defendant intentionally and maliciously 
released to the press his false statements about Plaintiff in an attempt to destroy Plaintiff's 
reputation and brand her as a liar and extortionist and also to cause her to lose all credibility in 
her efforts to help victims of sex trafficking. 
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96. 
Defendant knew that his assertions would dilute, discredit, and neutralize 
Plaintiff's public and private messages to sexual abuse victims and ultimately prevent Plaintiff 
from effectively providing assistance and advocacy on behalf of other victims of sex trafficking, 
or exposing her abusers. 
97. 
Using his role as a powerful lawyer with powerful friends, Defendant's statements 
were published nationally and internationally for the malicious purpose of further damaging 
Plaintiff, a sexual abuse and sex trafficking victim; to destroy Plaintiff's reputation and 
credibility; to cause the world to disbelieve Plaintiff; and to destroy Plaintiff's efforts to use her 
experience to help others suffering as sex trafficking victims. 
98. 
Defendant, personally, intentionally, and maliciously made false and damaging 
statements of fact concerning Plaintiff, as detailed above, in the Southern District of New York 
and elsewhere. 
99. 
The false statements that Defendant made not only called Plaintiff's truthfulness 
and integrity into question, but also exposed Plaintiff to public hatred, contempt, ridicule, and 
disgrace. 
100. 
At the time Defendant made his false statements, he knew full well that they were 
completely false and defamatory. 
101. 
Defendant's false statements constitute libel and/or slander, as he knew that they 
were going to be transmitted in writing, widely disseminated on the intemet and in print. 
Defendant intended his false statements to be published by newspaper, television, radio, and 
other media outlets nationally and internationally, and they were, in fact, published globally, 
including within the Southern District of New York. 
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102. 
Defendant's false statements constitute libel per se and/or slander per se because 
they accuse her of crimes including perjury and extortion, and because they expose Plaintiff to 
public contempt, ridicule, aversion, and disgrace, and induced an evil opinion of her in the minds 
of right-thinking persons. 
103. 
Defendant's false statements also constitute libel per se and/or slander per se, 
inasmuch, among other reasons, as they tended to injure Plaintiff 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. 
104. 
Defendant's false statements directly stated and also implied that in speaking out 
against sex trafficking Plaintiff acted with fraud, dishonesty, and unfitness for the task. 
Defendant's false statements directly and indirectly assert that Plaintiff lied about being sexually 
trafficked and abused by Epstein and having sex with Defendant, all for the purpose of extorting 
money from wealthy third parties, and that Plaintiff committed and conspired with her lawyers to 
commit the crimes of perjury and extortion. Defendant's false statements were reasonably 
understood by many persons who read, and/or heard, and/or witnessed his statements as 
conveying that specific intention and meaning. 
105. 
Defendant's false statements were reasonably understood by many persons who 
read, and/or heard, and/or witnessed those statements as making specific factual claims that 
Plaintiff was lying about specific facts and that she committed the crimes of perjury and 
extortion and conspired with her lawyers to commit those crimes. 
106. 
Defendant specifically directed his false statements at Plaintiff's true public 
description of factual events, and many persons who read Defendant's statements reasonably 
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understood that those statements referred directly to Plaintiff's account of the abuse she suffered 
at the hands of Epstein and Defendant. 
107. 
Defendant intended Defendant's false statements to be widely published and 
disseminated in his book, on television and radio, through newspapers and other print media, by 
word of mouth, and on the intemet and other electronic media. As intended by Defendant, 
Defendant's false statements were published and disseminated around the world. 
108. 
Defendant made his false statements in reckless disregard of their truth or falsity 
and with malicious intent to destroy Plaintiff's reputation and credibility; to prevent her from 
further disseminating her life story; and to cause persons hearing or reading Plaintiff's 
descriptions of truthful facts to disbelieve her entirely. Defendant knew that his defamatory 
statements were false and/or entertained serious doubts as to their truth when he made them. 
Defendant made his false statements wantonly and with the specific intent to maliciously damage 
Plaintiff's good name and reputation in a way that would destroy her efforts to administer her 
non-profit foundation, or share her life story, and thereby help others who have suffered from 
sexual abuse. 
109. 
As a result of Defendant's campaign to spread false, discrediting, and defamatory 
statements about Plaintiff, Plaintiff suffered substantial damages in an amount to be proven at 
trial. 
110. 
Defendant's false statements have caused, and continue to cause, Plaintiff 
economic damage, psychological pain and suffering, mental anguish and emotional distress, and 
other direct and consequential damages and losses. 
III. 
Defendant's campaign to spread his false statements nationally and internationally 
was unusual and particularly egregious conduct. Defendant and Epstein sexually abused and 
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trafficked Plaintiff, conspired to avoid having these crimes properly prosecuted and discovered, 
and Defendant wantonly and maliciously set out to falsely accuse, defame, and discredit Plaintiff 
to deny and conceal the scope and scale of his crimes and wrongdoing. In so doing, Defendant's 
efforts constituted a public wrong by deterring, damaging, and setting back Plaintiff's efforts to 
help victims of sex trafficking. Accordingly, this is a case in which exemplary and punitive 
damages are appropriate. 
112. 
Punitive and exemplary damages are necessary in this case to deter Defendant and 
others from wantonly and maliciously using a campaign of lies to discredit Plaintiff and other 
victims of sex trafficking. 
COUNT II BATTERY 
113. 
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-93 as 
if filly set forth herein. 
114. 
Defendant intentionally committed battery by engaging in offensive and wrongful 
sexual intercourse with and abuse of Plaintiff without her consent. 
115. 
Plaintiff's action is timely under N.Y.C.P.L.R. § 214-g, which provides that 
"[n]otwithstanding any provision of law which imposes a period of limitation to the 
contrary ... every civil claim or cause of action brought against any party alleging intentional or 
negligent acts or omissions by a person for physical, psychological, or other injury or condition 
suffered as a result of conduct which would constitute a sexual offense as defined in article one 
hundred thirty of the penal law committed against a child less than eighteen years of 
age, ... which conduct was committed against a child less than eighteen years of age, which is 
barred as of the effective date of this section because the applicable period of limitation has 
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expired ... is hereby revived ...." Defendant's actions constitute sexual offenses as defined in 
New York Penal Law Article 130, including but not limited to: 
(a) 
Sexual abuse as defined in Article 130.55, because during the battery, 
Defendant subjected Plaintiff to sexual contact under circumstances in which 
Plaintiff did not expressly or impliedly acquiesce in his conduct; and 
(b) 
Forcible touching as defined in Article 130.52, because during the battery, 
Defendant forcibly touched Plaintiff's sexual parts for the purpose of 
gratifying his sexual desire, under circumstances in which Plaintiff did not 
expressly or impliedly acquiesce in his conduct. 
116. 
As a direct and proximate result of Defendant's acts, Plaintiff has in the past and 
will in the future continue to suffer extreme emotional distress, humiliation, fear, psychological 
trauma, loss of dignity and self-esteem, and other direct and consequential damages. 
117. 
Because Defendant's conduct was wanton and malicious and violated criminal 
statutes, Plaintiff is entitled to punitive damages. 
COUNT III WIRETAP ACT 
118. 
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-112 as 
if fully set forth herein. 
119. 
In 2015, Defendant surreptitiously taped one or more telephone calls and/or in-
person meetings between himself and Boies. At the time, Boies was acting as Plaintiff's lawyer 
and agent. He engaged in the conversation on Plaintiff's behalf to discuss the merits of her 
claims and a potential settlement. Neither he nor Plaintiff consented to Defendant recording the 
conversation. 
120. 
Defendant is a "person" within the meaning of 18 U.S.C. §§ 2510(6), 2511(d). 
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121. 
In violation of 18 U.S.C. § 2511(I)(a), Defendant intentionally intercepted or 
endeavored to intercept Plaintiff's wire, oral, or electronic communications by recording 
telephone calls between himself and Plaintiff's agent, Boies. 
122. 
In violation of 18 U.S.C. § 2511(1)(b), Defendant intentionally used an electronic, 
mechanical, or other device to intercept an oral communication by Plaintiff's agent, Boies, when 
Defendant knew or had reason to know that such device or a component thereof was sent through 
the mail or transmitted in interstate or foreign commerce. 
123. 
In violation of 18 U.S.C. § 2511(I)(c) and (d), Defendant intentionally disclosed 
to another person and used, or endeavored to use, the contents of Plaintiff's wire, oral, or 
electronic communication, knowing or having reason to know that the information was obtained 
through an interception in violation of § 2511(1). 
124. 
Plaintiff's communications were intercepted for the purpose of committing the 
criminal act of perjury or a tortious act of defamation in violation of the laws of the United States 
and of New York. 
125. 
Plaintiff and her agent had a reasonable expectation that the communications 
would remain confidential and would not be intercepted. 
126. 
Plaintiff and her agent did not discover that the communications had been 
intercepted until the interception was reported in the press in November 2018. 
127. 
Neither Plaintiff nor her agent expressly or impliedly consented to the 
interception. 
128. 
Plaintiff had a justifiable expectation that her wire, oral, or electronic 
communications were not subject to interception. 
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Case 1:19-cv-03377-LAP Document 101-1 Filed 12/20/19 Page 40 of 41 
129. 
Plaintiff is a "person" whose wire, oral, or electronic communications were 
intercepted within the meaning of 18 U.S.C. § 2520. 
130. 
As a direct and proximate result of Defendant's actions, Plaintiff suffered injury 
to her reputation and her ability to vindicate her rights through the zealous representation by her 
counsel of choice, economic damage, psychological pain and suffering, mental anguish and 
emotional distress, and other direct and consequential damages and losses, and she is entitled to 
an award of the greater of the actual damages suffered or statutory damages pursuant to 18 
U.S.C. § 2520(c). 
131. 
In light of the egregious nature of Defendant's violations, Plaintiff is entitled to 
punitive damages and reasonable attorneys' fees and costs pursuant to 18 U.S.C. § 2520(b)(2) & 
(3). 
PIZ AVER FOR RELIEF 
WHEREFORE, Plaintiff respectfully requests judgment against Defendant, awarding 
compensatory, consequential, exemplary, and punitive damages in an 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. 
Dated: December 20, 2019 
/s/ Charles J. Cooper 
Charles J. Cooper* 
Michael W. Kirk* 
Nicole J. Moss* 
Haley N. Proctor* 
COOPER & KIRK PLLC 
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