Prince Andrew’s authorized crew right now filed authorized papers denying all of Virginia Roberts’ intercourse abuse allegations as he prepares for a bitter courtroom battle in america.
The papers, filed right now by the Duke of York’s authorized counsel Andrew Brettler, contained 41 separate denials of claims made by Roberts in August 2021 final 12 months.
The doc, which spanned 11 pages, additionally reveals 40 separate cases by which Andrew stated that he ‘lacks enough data to confess or deny’ elements of Roberts’ declare.
Roberts, who’s referred to in case paperwork by her married title Virginia Giuffre, filed over 15 pages of courtroom paperwork at New York’s southern district courtroom in August 2021 by which she formally accused the Royal of sexual abuse whereas she was being trafficked by billionaire paedophile Jeffrey Epstein.
Prince Andrew has all the time vehemently denied all fees, whereas Giuffre has requested ‘punitive damages’ be awarded by a choose and demanded a ‘trial by jury’ for the ‘bodily, psychological’ accidents she says she suffered.
Under are Giuffre’s claims made in August 2021 and Prince Andrew’s official rebuttals as specified by right now’s courtroom paperwork in full.
Prince Andrew, Virginia Roberts, aged 17, and Ghislaine Maxwell at Ghislaine Maxwell’s townhouse in London, Britain on March 13, 2001.
Roberts, who’s referred to in case paperwork by her married title Virginia Giuffre, filed over 15 pages of courtroom paperwork at New York’s southern district courtroom in August 2021 by which she formally accused the Royal of sexual abuse whereas she was being trafficked by billionaire paedophile Jeffrey Epstein (Roberts pictured along with her lawyer David Boies in 2019)
First web page of authorized paperwork submitted right now by Prince Andrew’s authorized crew denying the claims of sexual abuse made in opposition to him by Virginia Giuffre
NATURE OF THE ACTION
1. This swimsuit arises out of Defendant’s sexual abuse of Plaintiff when she was beneath the age of 18 years outdated.
Prince Andrew denies the allegations contained in paragraph {one of the} Criticism.
2. Throughout 2000–2002, starting when Plaintiff was 16, Plaintiff was the sufferer of intercourse trafficking and abuse by convicted intercourse offender Jeffrey Epstein.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph two of the Criticism.
3. Epstein’s trafficking scheme concerned recruiting younger ladies, typically by claiming they might be paid $200 for merely offering a therapeutic massage to a rich billionaire. This similar sample was repeated quite a few occasions with numerous youngsters and younger girls.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph three of the Criticism.
4. As United States District Decide Kenneth Marra discovered, ‘From between about 1999 and 2007, Jeffrey Epstein sexually abused greater than 30 minor ladies… at his mansion in Palm Seashore, Florida, and elsewhere in america and abroad…
‘Along with his personal sexual abuse of the victims, Epstein directed different individuals to abuse the ladies sexually. Epstein used paid staff to search out and convey minor ladies to him.
‘Epstein labored in live performance with others to acquire minors not just for his personal sexual gratification, but in addition for the sexual gratification of others.’
Opinion and Order, Doc. No. 435 at 1–2, Jane Doe 1 and Jane Doe 2 v. United States, Case No. 9:08-cv-80736 (S.D. Fla. Feb. 21, 2019).
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph 4 of the Criticism.
5. Like different minor youngsters who got here earlier than and after her, Plaintiff was initially recruited to offer massages, and thereafter to have interaction in quite a lot of sexual acts, for Epstein.
Plaintiff was required to be on name for Epstein for sexual functions and steadily traveled with him each nationally and internationally. Plaintiff was recurrently abused by Epstein and was lent out by Epstein to different highly effective males for sexual functions.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph 5 of the Criticism.
6. One such highly effective man to whom Plaintiff was lent out for sexual functions was the Defendant, Prince Andrew, the Duke of York.
Prince Andrew denies the allegations contained in paragraph six of the Criticism.
7. Prince Andrew was an in depth buddy of Ghislaine Maxwell, a British socialite who spent years overseeing and managing Epstein’s intercourse trafficking community, and actively recruited underage ladies, together with Plaintiff.
Prince Andrew denies the primary clause in paragraph seven of the Criticism. He lacks enough data to confess or deny the remaining allegations contained in that paragraph.
8. In line with Prince Andrew, he met Epstein by Maxwell in 1999. Prince Andrew thereafter turned a frequent visitor in Epstein’s numerous houses around the globe, together with New York Metropolis the place he sexually abused Plaintiff at Epstein and Maxwell’s invitation when she was a minor.
Prince Andrew admits that he met Jeffrey Epstein (“Epstein”) in or round 1999. He denies the remaining allegations contained in paragraph eight of the Criticism.
9. After publicly feigning ignorance in regards to the scope of Epstein’s sex-trafficking operation and sympathy for Epstein’s victims, Prince Andrew has refused to cooperate with U.S. authorities of their investigation and prosecution of Epstein and his co-conspirators.
Prince Andrew denies the allegations contained in paragraph 9 of the Criticism.
10. Prince Andrew dedicated sexual assault and battery upon Plaintiff when she was 17 years outdated. As such, Prince Andrew is chargeable for battery and intentional infliction of emotional misery pursuant to New York widespread regulation. The harm to Plaintiff has been extreme and lasting.
Prince Andrew denies the allegations contained within the first sentence of paragraph ten of the Criticism. The rest of that paragraph quantities to a authorized conclusion to which no response is required. To the extent a response is required, Prince Andrew denies the rest of the allegations contained in paragraph ten of the Criticism.
11. This motion has been well timed filed pursuant to the Youngster Victims Act, N.Y. C.P.L.R. § 214-g. The actions described herein represent sexual offenses by Defendant beneath New York Penal Regulation Article 130, and have been dedicated in opposition to Plaintiff when she was a toddler lower than eighteen years of age, for which she suffered bodily, psychological, and different accidents because of this.
The contentions in paragraph eleven of the Criticism are authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained in paragraph eleven.
Over 15 pages of courtroom paperwork filed at New York’s southern district courtroom, Roberts, additionally referred to by her married title Giuffre (pictured in 2019 following a listening to within the Epstein case), claimed that the Duke of York ‘dedicated sexual assault and battery’ in opposition to her whereas she was aged simply 17, requesting {that a} choose award ‘punitive damages’ for the ‘bodily and psychological’ accidents she suffered
PARTIES
12. Plaintiff Virginia L. Giuffre is a person who’s a citizen of the State of Colorado.
Prince Andrew disputes that Giuffre is domiciled within the State of Colorado and on that foundation denies the allegations in paragraph twelve of the Criticism.
13. Defendant Prince Andrew is a citizen of the UK, and is at present residing on the Royal Lodge at Windsor Nice Park, Berkshire, United Kingdom, the place he’s domiciled.
Prince Andrew admits paragraph 13 of the Criticism
JURISDICTION AND VENUE
14. This Court docket has variety jurisdiction over this dispute pursuant to twenty-eight U.S.C. § 1332(a)(2). Plaintiff is a citizen of a State and Defendant is a citizen of a international state, and the quantity in controversy exceeds the sum or worth of $75,000.00 excluding pursuits and prices.
Paragraph fourteen of the Criticism consists of authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew disputes and denies that the Court docket has subject material jurisdiction over this dispute on the grounds that Giuffre isn’t domiciled in Colorado.
15. Venue is correct on this Court docket as a considerable a part of the occasions or omissions giving rise to Plaintiff’s claims occurred inside this District. 28 U.S.C. § 1391(b)(2).
Paragraph fifteen of the Criticism consists of authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations on this paragraph.
16. This Court docket has private jurisdiction over Defendant as Defendant sexually abused Plaintiff on this state, and has thus dedicated a tortious motion inside this State pursuant to New York’s long-arm statute, N.Y. C.P.L.R. § 302(a)(2).
Defendant additionally visited Jeffrey Epstein on this State on quite a few events. Defendant might moderately anticipate {that a} swimsuit based mostly upon his acts and omissions with respect to Plaintiff might lead to him being topic to swimsuit on this State, and this swimsuit arises straight out of the Defendant’s acts or omissions with respect to Plaintiff on this state.
Paragraph sixteen of the Criticism consists of authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations on this paragraph.
FACTUAL ALLEGATIONS
A. Epstein’s Intercourse Trafficking Enterprise
17. Jeffrey Epstein was extensively famend as a billionaire who used his huge connections to highly effective people, and seemingly limitless wealth and assets, to create an online of transcontinental intercourse trafficking that served himself, his coconspirators, and a number of the strongest folks on this planet.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph seventeen of the Criticism.
18. Ghislaine Maxwell is a British socialite and the daughter of disgraced publishing tycoon Robert Maxwell. Maxwell was the highest-ranking recruiter in Epstein’s sex-trafficking enterprise. Maxwell is at present going through felony fees within the Southern District of New York stemming from her function in Epstein’s sex-trafficking enterprise, and is ready to face trial within the fall.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph eighteen of the Criticism.
19. Epstein had perfected a scheme for manipulation and abuse of younger females. As a part of the scheme, Maxwell or one other feminine recruiter would method a younger woman and strike up a dialog in an effort to rapidly study in regards to the woman’s background and any vulnerabilities they might expose. Epstein’s recruiters discovered their targets in every single place and wherever, together with faculties, spas, trailer parks, and the road.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph nineteen of the Criticism.
20. The recruiter would then manipulate the younger feminine into coming again to one among Epstein’s residences by providing the younger woman one thing she wanted, relying on her state of affairs. In lots of circumstances, the recruiter sought out ladies who needed to be skilled masseuses and invited them to one among Epstein’s houses by providing them what seemed to be professional masseuse positions.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty of the Criticism.
21. As soon as within the residence, Epstein and his co-conspirators would work in live performance to impress and intimidate the younger feminine with shows of huge wealth and energy. They’d brag about their connections to very highly effective political and social figures, and show images of themselves with these figures round Epstein’s houses. They’d normalize the sexual abuse by displaying images and artwork displaying nude females, and a therapeutic massage desk and spa associated merchandise in an effort to legitimize the world the place the abuse was set to happen.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-one of the Criticism.
22. As soon as abused, Epstein and Maxwell continued to control their victims, utilizing their monetary energy, guarantees, and threats to make sure that the sufferer returned as directed and remained compliant with their calls for. Epstein and his legal professionals would even collect details about the victims to make use of in opposition to them in the event that they ever disobeyed him, and his houses have been beneath fixed surveillance.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-two of the Criticism.
23. Message pads recovered throughout trash pulls at Epstein’s Palm Seashore mansion mirror messages that his employees took to relay to Epstein. They present the fixed circulate of ladies to Epstein, generally three per day. Epstein’s staff have additionally described younger ladies consistently being current at Epstein’s completely different houses.
Epstein’s fixed entry to younger ladies can also be evidenced in his ‘Black E-book,’ a ebook of cellphone numbers and get in touch with data itemizing ladies to name for ‘massages’ in numerous cities, flight logs documenting his frequent journey with younger ladies and highly effective people on his non-public aircraft, and troves of lewd images of younger ladies recovered from his houses. In his Black E-book, Epstein had no less than 12 completely different contact numbers listed for Prince Andrew.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-three of the Criticism.
24. Plaintiff turned a sufferer of intercourse trafficking and repeated sexual abuse after Maxwell recruited her into Epstein’s sex-trafficking operation when Plaintiff was working on the Mar-A-Lago Membership in Palm Seashore, Florida.
The Duke of York’s official rebuttal comes after a movement to dismiss the case on a authorized technicality firstly of January was denied
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-four of the Criticism.
25. Between 2000 and 2002, Epstein sexually abused Plaintiff at quite a few places together with his mansion on this District, at 9 East 71st Road, New York, New York 10021.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-five of the Criticism.
26. Epstein additionally flew Plaintiff on his aircraft nationally and internationally quite a few occasions when she was beneath the age of 18.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-six of the Criticism, together with these pertaining to the graphic embedded therein.
27. Along with being abused by Epstein himself, Plaintiff was additionally pressured to have intercourse with Defendant, Prince Andrew, the Duke of York, at Epstein and Maxwell’s course.
Prince Andrew lacks enough data to confess or deny the allegations in paragraph twenty-seven of the Criticism pertaining to the alleged abuse of Giuffre by the hands of Epstein and denies the remining allegations contained on this paragraph.
28. As a part of their intercourse trafficking efforts, Epstein and Maxwell intimidated Plaintiff into remaining silent about what had occurred to her.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-eight of the Criticism. To the extent the allegations on this paragraph are predicated on any alleged abuse by the hands of Prince Andrew, he denies the allegations on this paragraph.
29. After years of abuse, Epstein despatched Plaintiff to Thailand in September 2002. One in all Plaintiff’s assignments from Epstein was to deliver a younger woman again to Epstein in america. Fearing for her life, and never eager to topic one other younger woman to the abuse she was pressured to endure, Plaintiff fled from Thailand to Australia to flee from Epstein.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph twenty-nine of the Criticism.
B. Defendant’s Relationship with Epstein and Maxwell
30. In line with Prince Andrew, he first met Epstein in 1999 by Maxwell, Prince Andrew’s shut buddy. Prince Andrew and Maxwell have been photographed at quite a few social occasions collectively.
Prince Andrew admits that he met Epstein in or round 1999. He denies the remaining allegations within the first sentence of paragraph thirty of the Criticism, and lacks enough data to confess or deny the allegations contained within the second sentence of that paragraph.
31. In line with out there flight logs, Prince Andrew started flying with Epstein on his non-public aircraft as early as 1999, when he flew with Epstein and Maxwell to Epstein’s non-public island, Little St. James. Prince Andrew’s title additionally seems in different out there flight log entries from across the similar time, displaying journey with Epstein and Maxwell to and from different places, together with West Palm Seashore, Florida, and Teterboro, New Jersey.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph thirty-one of the Criticism.
32. In 2000, Epstein and Maxwell attended Prince Andrew’s fortieth party. That very same 12 months, Prince Andrew threw Maxwell a party in Sandringham, United Kingdom, and Epstein was among the many friends.
Prince Andrew admits the primary sentence of paragraph thirty-two of the Criticism. He denies the remaining allegations contained in that paragraph.
33. In 2006, Prince Andrew invited Epstein to his daughter’s 18th party, regardless of Epstein being charged with procuring a minor for prostitution just one month prior.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph thirty-three of the Criticism.
34. Prince Andrew has himself confirmed that he has been on Epstein’s non-public aircraft, stayed at Epstein’s non-public island, and stayed at Epstein’s houses in Palm Seashore, Florida, and New York, New York. See Prince Andrew’s hyperlinks to Jeffrey Epstein, BBC Information (Nov. 16, 2019), out there at https://www.bbc.com/information/uk-49411215.
Prince Andrew admits the primary sentence of paragraph thirty-four of the Criticism. He lacks enough data to confess or deny any allegation pertaining to the authenticity the BBC article referenced in paragraph thirty-four.
The papers, filed right now by Prince Andrew’s authorized counsel Andrew Brettler (pictured), contained a element rebuttal of all of Roberts’ claims and in addition requested that the Royal be granted a trial by jury
35. Members of Epstein’s home employees have confirmed witnessing Prince Andrew go to Epstein’s quite a few houses, each to the media and in sworn testimony.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph thirty-five of the Criticism.
C. Defendant’s Sexual Abuse of Plaintiff
36. Prince Andrew abused Plaintiff on separate events when she was beneath the age of 18 years outdated.
Prince Andrew denies the allegations contained in paragraph thirty-six of the Criticism.
37. On one event, Prince Andrew sexually abused Plaintiff in London at Maxwell’s dwelling. Throughout this encounter, Epstein, Maxwell, and Prince Andrew pressured Plaintiff, a toddler, to have sexual activity with Prince Andrew in opposition to her will.
Prince Andrew denies the allegations contained in paragraph thirty-seven of the Criticism.
38. The under {photograph} depicts Prince Andrew, Plaintiff, and Maxwell at Maxwell’s dwelling previous to Prince Andrew sexually abusing Plaintiff.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph thirty-eight of the Criticism.
39. On one other event, Prince Andrew sexually abused Plaintiff in Epstein’s New York mansion on this District. Throughout this encounter, Maxwell pressured Plaintiff, a toddler, and one other sufferer to sit down on Prince Andrew’s lap as Prince Andrew touched her. Throughout his go to to New York, Prince Andrew pressured Plaintiff to have interaction in intercourse acts in opposition to her will.
Prince Andrew denies the allegations contained in paragraph thirty-nine of the Criticism.
40. On one other event, Prince Andrew sexually abused Plaintiff on Epstein’s non-public island within the U.S. Virgin Islands, Little St. James.
Prince Andrew denies the allegations contained in paragraph forty of the Criticism.
41. Throughout every of the aforementioned incidents, Plaintiff was compelled by categorical or implied threats by Epstein, Maxwell, and/or Prince Andrew to have interaction in sexual acts with Prince Andrew, and feared loss of life or bodily harm to herself or one other and different repercussions for disobeying Epstein, Maxwell, and Prince Andrew attributable to their highly effective connections, wealth, and authority.
Prince Andrew denies the allegations contained in paragraph forty-one of the Criticism.
42. Throughout every of the aforementioned incidents, Prince Andrew acted with intent to compel Plaintiff’s submission.
Prince Andrew denies the allegations contained in paragraph forty-two of the Criticism.
43. Prince Andrew engaged in every of the aforementioned sexual acts with Plaintiff at Epstein and Maxwell’s invitation, realizing that she was a sex-trafficking sufferer being pressured to have interaction in sexual acts with him.
Prince Andrew denies the allegations contained in paragraph forty-three of the Criticism.
44. Throughout every of the aforementioned incidents, Plaintiff didn’t consent to partaking in sexual acts with Prince Andrew.
Prince Andrew denies the allegations contained in paragraph forty-four of the Criticism and denies that he ever engaged in sexual acts with Giuffre.
45. Throughout every of the aforementioned incidents, Prince Andrew knew Plaintiff’s age based mostly on communications from Epstein and Maxwell.
Prince Andrew denies the allegations contained in paragraph forty-five of the Criticism.
46. Throughout every of the aforementioned incidents, Prince Andrew sexually abused Plaintiff for the aim of gratifying his sexual wishes.
Prince Andrew denies the allegations contained in paragraph forty-six of the Criticism.
47. Throughout every of the aforementioned incidents, Prince Andrew was appearing in his particular person, private capability, and was not performing any responsibility referring to his former function as a commerce envoy, any responsibility referring to his function as a member of the Royal Household of the UK, or every other official or diplomatic responsibility or operate.
Prince Andrew denies the allegations contained in paragraph forty-seven of the Criticism and denies that he ever engaged in sexual acts with Giuffre.
48. Defendant’s sexual assault and battery of Plaintiff have brought about her, and proceed to trigger her, vital emotional and psychological misery and hurt.
Prince Andrew denies the allegations contained in paragraph forty-eight of the Criticism.
D. The Arrest, Prosecution, and Demise of Epstein, and Prince Andrew’s Refusal to Cooperate with the Authorities
49. In 2008, Epstein pled responsible in Florida to the cost of procuring a minor for prostitution.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph forty-nine of the Criticism.
50. In 2010, after Epstein had served his sentence and registered as a intercourse offender, Prince Andrew was photographed with Epstein in Central Park and stayed at Epstein’s New York Metropolis mansion.
Prince Andrew admits the second clause of paragraph fifty of the Criticism. He lacks enough data to confess or deny the remaining allegations contained in that paragraph.
51. Epstein flippantly referred to his sexual abuse of a number of minors, and the slap on the wrist he had acquired for it, in a 2011 interview with the New York Put up: ‘Billionaire pervert Jeffrey Epstein is again in New York Metropolis—and making wisecracks about his just-ended jail stint for having intercourse with an underage woman. ‘I’m not a sexual predator, I am an ‘offender,’ the financier instructed The Put up yesterday. ‘It is the distinction between a assassin and an individual who steals a bagel,’ stated Epstein.’
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph fifty-one of the Criticism.
52. Across the similar time, Prince Andrew started to face criticism over his well- publicized friendship with Epstein.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph fifty-two of the Criticism.
Andrew’s attorneys had unsuccessfully argued that Giuffre’s case ought to have been thrown out due to a newly-unsealed $500,000 settlement with Jeffrey Epstein (pictured). Brettler argued the settlement protected Andrew as a result of it contained a clause by which Giuffre agreed to not take authorized motion in opposition to ‘potential defendants’. However Decide Kaplan denied Andrew’s movement to have the case dismissed ‘in all respects’
53. In early 2015, after Plaintiff had publicly accused Prince Andrew of sexually abusing her, Prince Andrew emailed Maxwell stating, ‘Let me know once we can speak. Obtained some particular inquiries to ask you about Virginia Roberts.’
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph fifty-three of the Criticism.
54. On July 2, 2019, the U.S. Legal professional’s Workplace for the Southern District of New York (‘SDNY’) charged Epstein with intercourse trafficking conspiracy and intercourse trafficking in violation of 18 U.S.C. § 1591.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph fifty-four of the Criticism.
55. Epstein was arrested on July 8, 2019, pursuant to a Sealed Two Depend Indictment.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph fifty-five of the Criticism.
56. Epstein was discovered useless in his cell on the Metropolitan Correctional Middle on August 10, 2019.
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph fifty-six of the Criticism.
57. Only one 12 months earlier than his loss of life, Epstein instructed a New York Instances reporter ‘that criminalizing intercourse with teenage ladies was a cultural aberration and that at occasions in historical past it was completely acceptable.’
Prince Andrew lacks enough data to confess or deny the allegations contained in paragraph fifty-seven of the Criticism.
58. After Epstein’s second arrest and loss of life, quite a few of his co-conspirators and the rich people to whom he trafficked ladies—together with Prince Andrew—started to face elevated public scrutiny for having shut ties to a convicted intercourse offender.
Prince Andrew denies that he was a co-conspirator of Epstein or that Epstein trafficked ladies to him. Prince Andrew lacks enough data to confess or deny the remaining allegations contained in paragraph fifty-eight of the Criticism.
59. In November 2019, in response to this renewed scrutiny, Prince Andrew sat for an interview with BBC Newsnight. Prince Andrew said that he didn’t remorse his friendship with Epstein and that he had no recollection of assembly Plaintiff, regardless of photographic proof on the contrary.
Prince Andrew lacks enough data to confess or deny the allegation that there exists photographic proof of his alleged assembly with Giuffre. Prince Andrew admits the rest of paragraph fifty-nine of the Criticism
60. Prince Andrew publicly pledged, together with in a press release stepping down from his public duties and in his Newsnight interview, to help the U.S. authorities with their felony investigation of Epstein and his co-conspirators.
Prince Andrew admits paragraph sixty of the Criticism.
61. Regardless of this public pledge, Prince Andrew has refused to cooperate with U.S. authorities. Former SDNY U.S. Legal professional Geoffrey Berman said that Prince Andrew had supplied ‘zero co-operation’ regardless of U.S. prosecutors and the FBI contacting Prince Andrew’s counsel.
Prince Andrew denies the allegations contained within the first sentence of paragraph sixty-one of the Criticism. Prince Andrew lacks enough data to confess or deny the remaining allegations contained in that paragraph.
62. Prince Andrew and his counsel have additionally refused to cooperate with counsel for the victims of Epstein’s intercourse trafficking. Counsel for the victims of Epstein’s intercourse trafficking, together with counsel for Plaintiff, have repeatedly requested for a gathering or phone name with Prince Andrew and/or his representatives to allow Prince Andrew to offer no matter information, context, or rationalization he may need, and to discover different dispute decision approaches. Prince Andrew and his representatives have rejected all such requests, and responded by escalating their vile and baseless assaults on Plaintiff and others.
Prince Andrew denies the allegations contained in paragraph sixty-two of the Criticism.
63. On July 19, 2021, counsel for Plaintiff proposed a tolling settlement that will have enabled Plaintiff to not sue Prince Andrew right now, whereas avoiding any argument that her failure to take action brought about her claims to be time-barred. Once more Prince Andrew stonewalled—ignoring Plaintiff’s letter and emails with none reply or response, thereby making this motion obligatory now. A replica of the July 19, 2021, letter proposing a tolling settlement is hooked up as Exhibit A to this Criticism.
The allegations contained in paragraph sixty-three of the Criticism include authorized conclusions and impermissible authorized argument to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained on this paragraph and in Exhibit A hooked up to the Criticism.
64. On this nation no individual, whether or not President or Prince, is above the regulation, and no individual, regardless of how powerless or weak, could be disadvantaged of the regulation’s safety. Twenty years in the past Prince Andrew’s wealth, energy, place, and connections enabled him to abuse a frightened, weak youngster with nobody there to guard her. It’s long gone the time for him to be held to account.
The contentions contained in paragraph sixty-four of the Criticism include authorized conclusions and impermissible authorized argument to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained on this paragraph.
FIRST CAUSE OF ACTION (Battery)
65. Plaintiff repeats and re-alleges the allegations said above as if totally set forth herein.
Prince Andrew repeats and re-asserts his responses said above, as if totally set forth herein.
66. Prince Andrew deliberately dedicated battery by sexually assaulting Plaintiff when she was a minor. As described above, on a number of events Prince Andrew deliberately touched Plaintiff in an offensive and sexual method with out her consent.
Prince Andrew denies the allegations contained in paragraph sixty-six of the Criticism.
67. Prince Andrew’s actions represent sexual offenses as outlined in New York Penal Regulation Article 130, together with however not restricted to sexual misconduct as outlined in Article 130.20, rape within the third diploma as outlined in Article 130.25, rape within the first diploma as outlined in Article 130.35, forcible touching as outlined in Article 130.52, sexual abuse within the third diploma as outlined in Article 130.55, and sexual abuse within the first diploma as outlined in Article 130.65. See N.Y. C.P.L.R. § 214-g.
The allegations contained in paragraph sixty-seven of the Criticism include authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained on this paragraph.
68. As a direct and proximate results of Prince Andrew’s felony acts, Plaintiff has previously and can sooner or later proceed to undergo substantial damages, together with excessive emotional misery, humiliation, worry, psychological trauma, lack of dignity and vanity, and invasion of her privateness.
The allegations contained in paragraph sixty-eight of the Criticism include authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew lacks enough data to confess or deny the allegations contained on this paragraph.
SECOND CAUSE OF ACTION (Intentional Infliction of Emotional Misery)
69. Plaintiff repeats and re-alleges the allegations said above as if totally set forth herein.
Prince Andrew repeats and re-asserts his responses said above, as if totally set forth herein.
70. As a direct results of these allegations as said, Prince Andrew dedicated intentional infliction of emotional misery in opposition to Plaintiff.
The allegations contained in paragraph seventy of the Criticism include authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained on this paragraph.
71. Prince Andrew’s actions, described above, represent excessive and outrageous conduct that shocks the conscience. Prince Andrew’s sexual abuse of a kid who he knew was a sex-trafficking sufferer, and when he was roughly 40 years outdated, goes past all potential bounds of decency and is insupportable in a civilized neighborhood.
The allegations contained in paragraph seventy-one of the Criticism include authorized conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained on this paragraph.
72. Prince Andrew knew or disregarded the substantial chance that these actions would trigger Plaintiff extreme emotional misery.
The allegations contained in paragraph seventy-two of the Criticism include authorized conclusions and impermissible argument to which no response is required. To the extent a response is required, and to the extent the allegations on this paragraph are predicated on any alleged abuse by the hands of Prince Andrew, he denies the allegations on this paragraph.
73. As a direct and proximate results of Prince Andrew’s felony acts, Plaintiff has previously and can sooner or later proceed to undergo substantial damages, together with excessive emotional misery, humiliation, worry, psychological trauma, lack of dignity and vanity, and invasion of her privateness.
The allegations contained in paragraph seventy-three of the Criticism include authorized conclusions to which no response is required. To the extent a response is required, and to the extent the allegations on this paragraph are predicated on any alleged abuse by the hands of Prince Andrew, he denies the allegations on this paragraph.
Prince Andrew’s authorized crew has filed authorized papers by which the Royal denied all of Virginia Roberts’ intercourse abuse allegations as he prepares for a bitter courtroom battle in america (Pictured: Andrew and ex spouse Sarah Duchess Of York leaving Royal Lodge on January 22)
Previous to right now, Andrew had not formally responded to the 73-point civil declare as his legal professionals nearly instantly utilized to a New York choose for it to be thrown out.
That was dismissed earlier this month, that means he now must formally reply the accusations in opposition to him, together with claims that Miss Roberts, suing beneath her married product of Giuffre, was trafficked to him by his buddy, paedophile Jeffrey Epstein, and compelled to have intercourse with the duke on three events when she was 17.
Following his lengthy checklist of denials, the authorized doc goes on to supply a collection of defences on behalf of Prince Andrew.
The doc reiterated the place on the 2009 settlement which was that Ms Giuffre ‘waived the claims now asserted within the grievance’.
One other issue the duke’s authorized crew requested the courtroom to contemplate was the difficulty of consent.
The doc reads: ‘Assuming, with out admitting, that Giuffre has suffered any harm or harm alleged within the grievance, Giuffre’s claims are barred by the doctrine of consent.’
The duke additionally claimed the case ought to be ‘barred in entire or partially by her personal wrongful conduct’.
Andrew’s legal professionals additionally asserted that Ms Giuffre shouldn’t be capable of proceed as a result of her declare for damages is ‘too speculative to be recovered at regulation’.
This seems to point out the duke claiming Ms Giuffre’s claims can’t be proved with cheap certainty, which would depart jurors speculating as to the precise damages suffered.
Andrew’s legal professionals additionally said that Ms Giuffre’s claims ‘fail to state information enough to represent viable causes of motion in opposition to Prince Andrew’.
The doc additionally argues that the claims ought to be dismissed as a result of Ms Giuffre is a everlasting resident of Australia.