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Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 18 of 28

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 including in the common areas.

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 not pay Roberts and her attorneys. As Dershowitz knew:

(a) No complaint was ever made against the billionaire.

(b) No money was either paid or demanded by or from the billionaire.

(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 characterizations of Dershowitz’s assertions, represented that lawyer’s conclusions. As the sworn 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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