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Case 1:19-cv-03377 Document 1 Filed 04/16/19 Page 7 of 28

19. Dershowitz has repeatedly, publically claimed that he wanted to have a trial that would determine the facts concerning his conduct. He said on national television that he would waive the statute of limitations so that Roberts could sue him for sex abuse. However, when Robert’s counsel asked Dershowitz to do so, Dershowitz refused -- and continues to refuse.

20. Similarly, when Dershowitz was faced with an actual case brought by Edwards and Cassell which would have determined the veracity of Roberts’ claims, Dershowitz settled to avoid that determination.

21. More recently, Dershowitz, perhaps believing that Roberts who is now living with her husband and children in Australia would not be prepared to engage in litigation, has again taken to claiming publically that he demands a trial on the question of whether Roberts committed perjury and made up her statements about him for money. For example on March 2, 2019: My “accusers are Virginia Roberts and Sarah Ransome…I hereby accuse my false accusers of committing the felony of perjury and challenge them to sue me for defamation.” (Exhibit 6).

22. Mr. Dershowitz now has what he claims to have been looking for.

JURISDICTION AND VENUE

23. This is an action for damages in an amount in excess of the minimum jurisdictional limits of this Court.

24. This Court has jurisdiction over this dispute pursuant to 28 U.S.C. §1332 (diversity jurisdiction) in that Roberts and Dershowitz are citizens of different states and the amount in controversy exceeds seventy-five thousand ($75,000), exclusive of interest and costs.

25. This Court has personal jurisdiction over Defendant. Defendant resides in New York City; Defendant conducts regular business in New York City; and this action arose,

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