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Virginia Roberts will only accept settlement from Andrew if it ‘holds him to account’, says lawyer

Virginia Roberts will only accept a settlement from Prince Andrew if it ‘holds him to account’, according to her lawyer, as he described the Duke of York’s denial of ever meeting Ms Roberts as ‘incomprehensible’.

David Boies, Ms Roberts’ New York attorney, said Ms Roberts does not want a settlement that would allow Andrew to ‘escape’ responsibility due to his ‘position’ and ‘wealth’, according to reports.

The lawyer also said that Ms Roberts would also be unlikely to settle the lawsuit outside of court if the Duke of York continued to deny meeting her, as he did in his famous BBC Newsnight interview.

Legal experts had predicted Andrew, 61, would seek a settlement, but Andrew has taken the dramatic decision to face his accuser in court and become the first member of the modern royal family to submit to being cross-examined over serious allegations.

The lawsuit has come during the same year as the Queen’s platinum jubilee, and Mr Boies admitted that he did feel pain for Her Majesty that the legal action was being played out so ‘publicly’, describing it as a ‘mother’s worst nightmare’.

But Mr Boies told The Telegraph the Queen, nor Prince Andrew’s daughters Beatrice and Eugenie, will not be deposed if the case goes to court, saying it is likely that Andrew’s conversations with his mother will not be used as he ‘probably’ won’t admit to them. 

Ms Roberts filed over 15 pages of court documents at New York’s southern district court in August 2021 in which she formally accused the Royal of sexual abuse while she was being trafficked by billionaire paedophile Jeffrey Epstein.

Ms Giuffre claims she was trafficked by convicted paedophile Jeffrey Epstein and Ghislaine Maxwell to have sex with Prince Andrew three times when she was a teenager. The Duke of York vehemently denies the allegations.

Papers filed by Prince Andrew’s legal counsel Andrew Brettler this week contained 41 separate denials of claims made by Roberts in August 2021 last year.

Legal experts had predicted Andrew would seek a settlement, but David Boies, Ms Roberts’ New York attorney, has said they would only accept a settlement if it held Andrew ‘to account’.

He told The Telegraph: ‘What’s important for Virginia is to vindicate herself and the other victims. Not to let someone escape responsibility, just because of their wealth and power. To hold Prince Andrew to account.’   

David Boies, Virginia Roberts’ attorney (both pictured), has said Ms Roberts would only accept a settlement if it held Prince Andrew ‘to account’

Mr Boies said they would be ‘unlikely’ to settle if the Duke of York, who is fighting the case as a ‘private citizen’ after he lost his royal titles, continued to deny ever meeting Ms Roberts.

Andrew previously insisted during his BBC Newsnight interview that he has no memory of meeting Miss Roberts, saying: ‘I have no recollection of ever meeting this lady, none whatsoever.’ 

Although Mr Boies said the legal team were looking forward to ‘confronting’ the royal about his ‘denials’, he insisted they tried to avoid bringing the lawsuit and attempted mediation.

But he claimed it was Andrew’s ‘incomprehensible’ denial of meeting Ms Roberts that led to the lawsuit, saying it went against overwhelming testimonies and ‘strong evidence’ that he did meet her.

He added: ‘We tried to avoid litigation; we suggested a mediation. But to say ‘I never met her’ is so contrary to all the other evidence that’s out there.’

If the case does go to court, Mr Boies said while Andrew’s conversations with the Queen ‘could be used’, he said they were unlikely to get at them as they will not depose the Queen and said he was ‘probably not’ going to admit to them.

He said: ‘So while those conversations are fair game, on a practical level we’re probably not going to get at them.’

The lawsuit has come during the same year as the Queen’s platinum jubilee, and Mr Boies admitted it does pain him for the lawsuit to be playing out in such a public way because of Andrew’s position. 

Papers filed by Prince Andrew's legal counsel Andrew Brettler this week contained 41 separate denials of claims made by Roberts in August 2021 last year

Papers filed by Prince Andrew’s legal counsel Andrew Brettler this week contained 41 separate denials of claims made by Roberts in August 2021 last year

‘This has got to be any mother’s nightmare,’ he added.  

Legal experts had predicted Andrew would seek a settlement after the Queen removed his military roles and patronages, widely seen as the monarchy distancing itself from any potentially damaging developments.

But Andrew has taken the dramatic decision to face his accuser in court and become the first member of the modern royal family to submit to being cross-examined over serious allegations.

In the bunker! Prince Andrew gives up honorary life membership of The Royal and Ancient Golf Club… his latest lost patronage in wake of sex abuse lawsuit 

Prince Andrew gave up his honorary membership at the prestigious home of golf as the fallout from his civil sex case continues – meaning he will no longer walk the fairways at the Royal and Ancient Golf Club of St Andrews.

Giving up his membership at one of the world’s oldest golf clubs, located in Fife, will be a humiliation for the embattled Duke of York who is a passionate golf fan and has met many top names in the sport over the years.  

The R&A had faced intense pressure over Andrew’s patronage as the scandal regarding his friendship with Jeffrey Epstein intensified and after the Queen stripped him of his military and other royal patronages earlier this month.

However the Duke – who has been the patron at 24 golf clubs, societies and associations – had kept his links with his favourite sport and holding the honorary life membership at the R&A was his most distinguished position. 

In addition, all of the Duke’s royal patronages have now been wiped from the Royal Family’s official website, with his name no longer appearing on a drop-down menu on the ‘Charities and Patronages’ section of Royal.UK. 

Meanwhile the Queen, 95, was photographed this morning near Wood Farm on her Sandringham estate where she is staying for the next few weeks, just over one month after her Christmas visit to Norfolk was cancelled.

She normally hosts her family at Sandringham over the holidays, and on Christmas Day the royals attend church nearby. But the Queen chose in December to remain at Windsor Castle following rising Covid-19 cases at the time.

On February 6, her reign will pass the milestone of 70 years and herald the start of Platinum Jubilee celebrations. Her winter break normally ends after her Accession Day, February 6 – the day her father George VI died in 1952.

The festive period was the Queen’s first Christmas without her husband Prince Philip who died on April 9 last year. She had spent much of last year at Windsor Castle, where she and Philip had shielded throughout the lockdowns.

There were concerns for the Queen’s health during autumn last year after she pulled out of a number of major engagements, spent a night in hospital and was ordered to rest by royal doctors. The Queen was advised to carrying out light duties but also sprained her back, leading to her missing the Remembrance Sunday service.

A R&A spokesman said: ‘I can confirm that the Royal and Ancient Golf Club of St Andrews has received notification that the Duke of York will relinquish his Honorary Membership. We respect and appreciate his decision.’ 

A source close to Andrew told MailOnline: ‘This is in line with the recent announcement from Buckingham Palace.’

The development – which follows other golf clubs removing pictures of the Duke from their clubhouses – comes after Andrew demanded a trial by jury in the civil sexual assault case brought against him by Virginia Giuffre.

It comes after papers filed by Andrew’s legal counsel Andrew Brettler, contained 41 separate denials of claims made by Roberts in August 2021 last year. 

But the document, which spanned 11 pages, also shows 40 separate instances in which Andrew said that he ‘lacks sufficient information to admit or deny’ parts of Roberts’ claim.

Prince Andrew has always vehemently denied the claims, while Giuffre has requested ‘punitive damages’ be awarded by a judge and demanded a ‘trial by jury’ for the ‘physical, psychological’ injuries she says she suffered. Experts believe this could cost the royal £10million if he settles.

The Duke of York, who is now fighting the case as a ‘private citizen’ after his mother the Queen cut him adrift, told BBC Newsnight that he has ‘no recollection of ever meeting this lady, none whatsoever’. 

He also insisted in his notorious in 2019 he wasn’t a party prince and did not sweat ‘profusely’ when allegedly dancing with Miss Roberts at a celebrity night-spot in London, because he was shot at in the Falklands and had a rare medical condition which meant he could not perspire. 

And his alibi was a dinner at Pizza Express in Woking with his daughter Princess Beatrice. 

Another factor the duke’s legal team asked the court to consider was the issue of consent.

The document reads: ‘Assuming, without admitting, that Giuffre has suffered any injury or damage alleged in the complaint, Giuffre’s claims are barred by the doctrine of consent.’

The duke also claimed the case should be ‘barred in whole or in part by her own wrongful conduct’.

Andrew’s lawyers also asserted that Ms Giuffre should not be able to proceed because her claim for damages is ‘too speculative to be recovered at law’.

This appears to show the duke claiming Ms Giuffre’s allegations cannot be proved with reasonable certainty, which would leave jurors speculating as to the actual damages suffered.

The document also argues that the claims should be dismissed because Ms Giuffre is a permanent resident of Australia.

In the 11-page document, Andrew denied being a close friend of Maxwell or being a frequent guest at Epstein’s homes.

The duke has also denied that he refused to cooperate with US authorities in their investigation and prosecution of Epstein.

Andrew’s lawyers have also stated he did not throw Maxwell a birthday party at Sandringham, and ‘lacked sufficient information to admit or deny’ inviting Epstein to his daughter’s 18th birthday party a month after the financier became a convicted sex offender.

Media lawyer Mark Stephens earlier warned that the bombshell lawsuit could ‘overshadow’ Her Majesty’s Platinum Jubilee – and ultimately risks ‘bringing down the monarchy’.

But he admitted it could be a final piece of ‘classic brinkmanship’ to force down the reputed £10million settlement he may have to offer to Miss Roberts, who now uses her married name Giuffre. He also speculated on whether the duke is ‘bluffing’ and may still settle to avoid damaging the standing of the monarchy.

‘I think he’s buying time for settlement. David Boies wants to get to the Queen’s money, which won’t happen. But we are just 10 days from Ascension Day and the beginning of the Platinum Jubilee,’ Mr Stephens said.

Kate MacNab, a solicitor at Reeds Solicitors, told MailOnline: ‘It may seem like an odd route to take – betting on public opinion – after his performance on Newsnight, but perhaps he is just biding his time?

‘Perhaps by agreeing to her initial wish of having a jury trial, he is wanting to position himself as having nothing to hide? Perhaps this will force an out-of-court settlement? All of this is speculation of course, but nothing would surprise me at this stage.’

Lawyers for the Queen’s second son said that Andrew ‘hereby demands a trial by jury on all causes of action asserted in the complaint’ because he denies ‘any and all wrongdoing’. 

Experts say it further confirms why Her Majesty ‘swiftly and ruthlessly’ forced Andrew to step down from his remaining royal patronages and demanded he fight the case as a ‘private citizen’.

Mr Stephens went on: ‘The reason we think he’s got to settle is because of the timing. Essentially this case is going to take up the rest of this year and if it takes up the rest of this year, that’s the whole of his mother’s Platinum Jubilee. 

Mr Boies (pictured with Ms Roberts) said that they would be 'unlikely' to settle if the Duke of York, who is now fighting the case as a 'private citizen', continued to deny meeting Ms Roberts

Mr Boies (pictured with Ms Roberts) said that they would be ‘unlikely’ to settle if the Duke of York, who is now fighting the case as a ‘private citizen’, continued to deny meeting Ms Roberts

‘The only thing he could have done to stop this getting worse is to have pulled the case and stopped it in some way so there was no alternative news. This is going to be crippling if he really is dead set on running this to a trial.’

He continued: ‘I can’t conceive that the Royal Family will allow him to run this case and overshadow the Platinum Jubilee. It’s going to spark a debate about the relevancy and appropriateness of the Royal Family. The more detail that comes out the more there’s going to be a problem for the wider royal family.’

Commenting on lurid details that may emerge from the trial, Mr Stephens said: ‘For example, questions will be asked of Virginia Giuffre about the prince’s body, any marks, his performance, what positions were adopted – every detail that is conceivable to ask will be put to Andrew.’

Royal expert and former MP Norman Baker said Buckingham Palace ‘won’t like’ what could come out at trial, warning: ‘This is going to be very damaging’.

Prince Andrew’s civil sex case: What is alleged and what happens next?

A court document has been published detailing the reasons why the Duke of York’s lawyers believe the civil sex assault case against him should be dismissed. Here, the PA news agency looks at what is alleged against Andrew and what will happen next:

– Who is Virginia Giuffre?

Virginia Giuffre, also known as Virginia Roberts, alleges she was trafficked by disgraced British socialite Ghislaine Maxwell to be molested by financier Jeffrey Epstein and his friends.

– What case does Andrew face?

Ms Giuffre has brought a case of battery and intentional infliction of emotional distress against the duke. It is claimed she was trafficked by convicted sex offender Epstein and others to Andrew, who is alleged to have sexually abused her when she was under the age of 18.

– How many allegations does the duke face?

Court documents reference three separate occasions in which Ms Giuffre accuses him of sexual misconduct.

– Where is the alleged sexual abuse said to have taken place?

Ms Giuffre claims Andrew had sex with her against her will at Maxwell’s London home. She also alleges the royal forced her to engage in sex acts against her will at Epstein’s mansion on the Upper East Side of Manhattan. The duke is also alleged to have sexually abused Ms Giuffre on another occasion during a visit to Epstein’s private island, Little St James.

– Will Andrew have to face a civil trial?

If the case is not settled before the proposed trial date, the facts of the case will be tried in New York.

– When will this take place?

The trial is scheduled to take place between September and December. The parties will need to confirm by July 28 whether they wish to proceed to trial.

– What form would that trial take?

Andrew is demanding a jury trial. In the court document which communicated his reasons for requesting a dismissal of the case, Andrew’s lawyers stated: ‘Prince Andrew hereby demands a trial by jury on all causes of action asserted in the Complaint.’

– Would Andrew have to give evidence in the case?

It is likely he will be asked to give evidence under oath as part of the discovery process in what is known as a deposition.

– What would need to happen for the case not to go to trial?

Unless there are any other motions to dismiss the case, the duke would have to reach a settlement with Ms Giuffre. This is usually a financial settlement where both sides go back and forth until a figure is reached.

– What are the reasons Andrew has given for the case against him to be dismissed?

The duke submitted 11 reasons why the case should be dismissed, including that Ms Giuffre’s claims are ‘barred by the doctrine of consent’ and by ‘her own wrongful conduct’. Andrew’s lawyers also asserted that Ms Giuffre should not be able to proceed because her claim for damages is ‘too speculative to be recovered at law’. His legal team also stated that Ms Giuffre’s claims ‘fail to state facts sufficient to constitute viable causes of action against Prince Andrew’. The document also argues that the claims should be dismissed because Ms Giuffre is a permanent resident of Australia.

– What has Ms Giuffre’s legal team said?

David Boies, who is representing Ms Giuffre, said his client and legal team were anticipating ‘confronting’ the royal about his ‘denials and attempts to blame Ms Giuffre for her own abuse at his deposition and at trial’.

‘This morning the Palace will be looking on in horror at what Prince Andrew is doing,’ he said, adding: ‘I suspect he won’t give evidence and will allow his lawyers to handle it for him. Clearly if he doesn’t give evidence while pushing for a trial, that will not go down well with any jury.’

In his official response to claims made against him by Miss Roberts five months ago, the duke issued 41 denials, rejecting all allegations of wrongdoing – but said a further 40 times that he ‘lacks sufficient information to admit or deny’ other claims.

He also submitted 11 defences calling for the case to be dismissed, including that Miss Roberts’ claims should be barred by ‘her own wrongful conduct’ and ‘unclean hands’. His decision to go ahead with the case puts him in contravention with the Royal Family.

Legal commentator Joshua Rozenberg has said the Duke of York’s demand for a jury trial is him stating ‘bring it on’.

He told BBC Breakfast: ‘Those (a trial by jury) are certainly the words with which this page 11 defence ends but it was Virginia Giuffre who asked for a jury trial, demanded a jury trial, in her claim.

‘And so what you’ve really got here is Prince Andrew saying, ‘Bring it on. You want a jury trial? I want a jury trial. You want to bring these claims? Well, in that case, you have to prove everything that you’re saying, because I’m not going to admit to anything’.

He added the case could still settle out of court but added that ‘nevertheless the prince is saying that he denies everything’.

Prince Andrew’s official rebuttal of Giuffre’s claims comes just weeks after The Queen stripped him of his honorary titles, meaning he can no longer be referred to as ‘His Royal Highness’ in any capacity.

Andrew, who remains Duke of York, also loses his military titles and royal patronages ‘with the Queen’s approval and agreement’, Buckingham Palace said in a terse statement that brought his 61 years as a senior royal to a shock end. 

The Queen’s decision made on January 13 followed the day after Andrew’s motion to have the case against him dismissed on a legal technicality was unequivocally thrown out by a US judge. 

Judge Lewis Kaplan sensationally dismissed an application from the Duke of York’s lawyers to have the case shut down – freeing Ms Giuffre to pursue her high-profile case in a US court later this year. 

Andrew’s attorneys had unsuccessfully argued that her case should have been thrown out because of a newly-unsealed $500,000 settlement with Jeffrey Epstein.

Brettler argued the settlement protected Andrew because it contained a clause in which Giuffre agreed not to take legal action against ‘potential defendants’. 

But Judge Kaplan said the court was not able to consider the duke’s efforts to cast doubt on Giuffre’s claims or whether he was covered by the settlement agreement, suggesting these were issues for a trial.

He said: ‘The 2009 agreement cannot be said to demonstrate, clearly and unambiguously, the parties intended the instrument ”directly”, ”primarily”, or ”substantially”, to benefit Prince Andrew.

‘The defendant’s motion to dismiss the complaint or for a more definite statement is denied in all respects.’

Earlier this month, sources close to the Duke confirmed that he was selling his luxurious chalet in the exclusive Swiss ski resort of Verbier after a mystery buyer agreed to take it off his hands.

Andrew was only able to sell the residence, called Chalet Helora, after settling a £6.6million debt to French socialite Isabelle de Rouvre, 74, who sold it to him and Sarah Ferguson in 2014 also for £18million. 

The deal led to speculation that he would use the money to pay his rapidly expanding legal bills as he prepares to battle the lawsuit of Giuffre.

But Spencer Kuvin, who represented the victims of Epstein, believes the sale could actually be designed to prevent Giuffre from seizing the Duke’s assets.

The lawyer told the Mirror: ‘If Virginia gets a judgment against Andrew, if this went all the way through to trial and she received a financial judgment in her favour, she could execute on any properties he has, the most likely being his ski chalet.

‘If Andrew had properties in any companion country that would abide by such jurisdiction of the US, she can execute on those properties.’

He added: ‘If the Queen has transferred any property to him, anywhere throughout the entire world, they could try and execute on that property if successful in foreign courts.’

Andrew agreed with Ms de Rouvre that the chalet would be paid for in instalments.

But Ms de Rouvre claimed the Yorks failed to make the final instalment of £5m, resulting in her launching legal action against them in the Swiss courts two years ago for the amount she was owed, plus interest, which came to a combined £6.6 million.

Under Swiss law, he was prevented from selling the chalet until the matter had been resolved.

Now that Andrew has paid the final instalment and attached interest for the chalet, he is now expected to sell the property in a matter of weeks.  

Prince Andrew’s 41-point denial in full: Duke of York’s responses to Virginia Roberts’ catalogue of sex abuse allegations as he files legal papers with US court

By DAVID AVERRE FOR MAILONLINE 

Below are Giuffre’s claims made in August 2021 and Prince Andrew’s official rebuttals as laid out in today’s court documents in full.

NATURE OF THE ACTION

1. This suit arises out of Defendant’s sexual abuse of Plaintiff when she was under the age of 18 years old.

Prince Andrew’s response from today’s court documents: Prince Andrew denies the allegations contained in paragraph one of the Complaint.

2. During 2000–2002, beginning when Plaintiff was 16, Plaintiff was the victim of sex trafficking and abuse by convicted sex offender Jeffrey Epstein.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph two of the Complaint. 

3. Epstein’s trafficking scheme involved recruiting young girls, often by claiming they would be paid $200 for simply providing a massage to a wealthy billionaire. This same pattern was repeated numerous times with countless children and young women.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph three of the Complaint. 

4. As United States District Judge Kenneth Marra found, ‘From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls… at his mansion in Palm Beach, Florida, and elsewhere in the United States and overseas…

    ‘In addition to his own sexual abuse of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid employees to find and bring minor girls to him.

    ‘Epstein worked in concert with others to obtain minors not only for his own sexual gratification, but also 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 sufficient information to admit or deny the allegations contained in paragraph four of the Complaint. 

5. Like other minor children who came before and after her, Plaintiff was initially recruited to provide massages, and thereafter to engage in a variety of sexual acts, for Epstein.

Plaintiff was required to be on call for Epstein for sexual purposes and frequently traveled with him both nationally and internationally. Plaintiff was regularly abused by Epstein and was lent out by Epstein to other powerful men for sexual purposes.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph five of the Complaint.

6. One such powerful man to whom Plaintiff was lent out for sexual purposes was the Defendant, Prince Andrew, the Duke of York.

Prince Andrew denies the allegations contained in paragraph six of the Complaint. 

7. Prince Andrew was a close friend of Ghislaine Maxwell, a British socialite who spent years overseeing and managing Epstein’s sex trafficking network, and actively recruited underage girls, including Plaintiff.

Prince Andrew denies the first clause in paragraph seven of the Complaint. He lacks sufficient information to admit or deny the remaining allegations contained in that paragraph. 

8. According to Prince Andrew, he met Epstein through Maxwell in 1999. Prince Andrew thereafter became a frequent guest in Epstein’s various homes around the world, including New York City where 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 around 1999. He denies the remaining allegations contained in paragraph eight of the Complaint. 

9. After publicly feigning ignorance about the scope of Epstein’s sex-trafficking operation and sympathy for Epstein’s victims, Prince Andrew has refused to cooperate with U.S. authorities in their investigation and prosecution of Epstein and his co-conspirators.

Prince Andrew denies the allegations contained in paragraph nine of the Complaint. 

10. Prince Andrew committed sexual assault and battery upon Plaintiff when she was 17 years old. As such, Prince Andrew is responsible for battery and intentional infliction of emotional distress pursuant to New York common law. The damage to Plaintiff has been severe and lasting.

Prince Andrew denies the allegations contained in the first sentence of paragraph ten of the Complaint. The remainder of that paragraph amounts to a legal conclusion to which no response is required. To the extent a response is required, Prince Andrew denies the remainder of the allegations contained in paragraph ten of the Complaint.

11. This action has been timely filed pursuant to the Child Victims Act, N.Y. C.P.L.R. § 214-g. The actions described herein constitute sexual offenses by Defendant under New York Penal Law Article 130, and were committed against Plaintiff when she was a child less than eighteen years of age, for which she suffered physical, psychological, and other injuries as a result.

The contentions in paragraph eleven of the Complaint are legal conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained in paragraph eleven. 

PARTIES

12. Plaintiff Virginia L. Giuffre is an individual who is a citizen of the State of Colorado.

Prince Andrew disputes that Giuffre is domiciled in the State of Colorado and on that basis denies the allegations in paragraph twelve of the Complaint. 

13. Defendant Prince Andrew is a citizen of the United Kingdom, and is currently residing at the Royal Lodge at Windsor Great Park, Berkshire, United Kingdom, where he is domiciled.

Prince Andrew admits paragraph thirteen of the Complaint 

JURISDICTION AND VENUE

14. This Court has diversity jurisdiction over this dispute pursuant to 28 U.S.C. § 1332(a)(2). Plaintiff is a citizen of a State and Defendant is a citizen of a foreign state, and the amount in controversy exceeds the sum or value of $75,000.00 excluding interests and costs.

Paragraph fourteen of the Complaint consists of legal conclusions to which no response is required. To the extent a response is required, Prince Andrew disputes and denies that the Court has subject matter jurisdiction over this dispute on the grounds that Giuffre is not domiciled in Colorado. 

15. Venue is proper in this Court as a substantial part of the events or omissions giving rise to Plaintiff’s claims occurred within this District. 28 U.S.C. § 1391(b)(2).

Paragraph fifteen of the Complaint consists of legal conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations in this paragraph.

16. This Court has personal jurisdiction over Defendant as Defendant sexually abused Plaintiff in this state, and has thus committed a tortious action within this State pursuant to New York’s long-arm statute, N.Y. C.P.L.R. § 302(a)(2).

Defendant also visited Jeffrey Epstein in this State on numerous occasions. Defendant could reasonably anticipate that a suit based upon his acts and omissions with respect to Plaintiff could result in him being subject to suit in this State, and this suit arises directly out of the Defendant’s acts or omissions with respect to Plaintiff in this state.

Paragraph sixteen of the Complaint consists of legal conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations in this paragraph. 

FACTUAL ALLEGATIONS

A. Epstein’s Sex Trafficking Enterprise

17. Jeffrey Epstein was widely renowned as a billionaire who used his vast connections to powerful individuals, and seemingly unlimited wealth and resources, to create a web of transcontinental sex trafficking that served himself, his coconspirators, and some of the most powerful people in the world.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph seventeen of the Complaint. 

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 currently facing criminal charges in the Southern District of New York stemming from her role in Epstein’s sex-trafficking enterprise, and is set to face trial in the fall.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph eighteen of the Complaint.

19. Epstein had perfected a scheme for manipulation and abuse of young females. As part of the scheme, Maxwell or another female recruiter would approach a young girl and strike up a conversation in an effort to quickly learn about the girl’s background and any vulnerabilities they could expose. Epstein’s recruiters found their targets everywhere and anywhere, including schools, spas, trailer parks, and the street.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph nineteen of the Complaint. 

20. The recruiter would then manipulate the young female into coming back to one of Epstein’s residences by offering the young girl something she needed, depending on her situation. In many cases, the recruiter sought out girls who wanted to be professional masseuses and invited them to one of Epstein’s homes by offering them what appeared to be legitimate masseuse positions.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty of the Complaint. 

21. Once in the residence, Epstein and his co-conspirators would work in concert to impress and intimidate the young female with displays of vast wealth and power. They would brag about their connections to very powerful political and social figures, and display photographs of themselves with those figures around Epstein’s homes. They would normalize the sexual abuse by displaying photographs and art displaying nude females, and a massage table and spa related products in an effort to legitimize the area where the abuse was set to occur.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-one of the Complaint. 

22. Once abused, Epstein and Maxwell continued to manipulate their victims, using their financial power, promises, and threats to ensure that the victim returned as directed and remained compliant with their demands. Epstein and his lawyers would even gather information about the victims to use against them if they ever disobeyed him, and his homes were under constant surveillance.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-two of the Complaint. 

23. Message pads recovered during trash pulls at Epstein’s Palm Beach mansion reflect messages that his staff took to relay to Epstein. They show the constant flow of girls to Epstein, sometimes three per day. Epstein’s employees have also described young girls constantly being present at Epstein’s different homes.

Epstein’s constant access to young girls is also evidenced in his ‘Black Book,’ a book of phone numbers and contact information listing girls to call for ‘massages’ in various cities, flight logs documenting his frequent travel with young girls and powerful individuals on his private plane, and troves of lewd photographs of young girls recovered from his homes. In his Black Book, Epstein had at least 12 different contact numbers listed for Prince Andrew.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-three of the Complaint. 

24. Plaintiff became a victim of sex trafficking and repeated sexual abuse after Maxwell recruited her into Epstein’s sex-trafficking operation when Plaintiff was working at the Mar-A-Lago Club in Palm Beach, Florida.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-four of the Complaint. 

25. Between 2000 and 2002, Epstein sexually abused Plaintiff at numerous locations including his mansion in this District, at 9 East 71st Street, New York, New York 10021.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-five of the Complaint. 

26. Epstein also flew Plaintiff on his plane nationally and internationally numerous times when she was under the age of 18.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-six of the Complaint, including those pertaining to the graphic embedded therein. 

27. In addition to being abused by Epstein himself, Plaintiff was also forced to have sex with Defendant, Prince Andrew, the Duke of York, at Epstein and Maxwell’s direction.

Prince Andrew lacks sufficient information to admit or deny the allegations in paragraph twenty-seven of the Complaint pertaining to the alleged abuse of Giuffre at the hands of Epstein and denies the remining allegations contained in this paragraph. 

28. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Plaintiff into remaining silent about what had happened to her.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-eight of the Complaint. To the extent the allegations in this paragraph are predicated on any alleged abuse at the hands of Prince Andrew, he denies the allegations in this paragraph. 

29. After years of abuse, Epstein sent Plaintiff to Thailand in September 2002. One of Plaintiff’s assignments from Epstein was to bring a young girl back to Epstein in the United States. Fearing for her life, and not wanting to subject another young girl to the abuse she was forced to endure, Plaintiff fled from Thailand to Australia to escape from Epstein. 

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph twenty-nine of the Complaint. 

B. Defendant’s Relationship with Epstein and Maxwell

30. According to Prince Andrew, he first met Epstein in 1999 through Maxwell, Prince Andrew’s close friend. Prince Andrew and Maxwell have been photographed at numerous social events together.

Prince Andrew admits that he met Epstein in or around 1999. He denies the remaining allegations in the first sentence of paragraph thirty of the Complaint, and lacks sufficient information to admit or deny the allegations contained in the second sentence of that paragraph. 

31. According to available flight logs, Prince Andrew began flying with Epstein on his private plane as early as 1999, when he flew with Epstein and Maxwell to Epstein’s private island, Little St. James. Prince Andrew’s name also appears in other available flight log entries from around the same time, showing travel with Epstein and Maxwell to and from other locations, including West Palm Beach, Florida, and Teterboro, New Jersey.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph thirty-one of the Complaint. 

32. In 2000, Epstein and Maxwell attended Prince Andrew’s 40th birthday party. That same year, Prince Andrew threw Maxwell a birthday party in Sandringham, United Kingdom, and Epstein was among the guests.

Prince Andrew admits the first sentence of paragraph thirty-two of the Complaint. He denies the remaining allegations contained in that paragraph. 

33. In 2006, Prince Andrew invited Epstein to his daughter’s 18th birthday party, despite Epstein being charged with procuring a minor for prostitution only one month prior.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph thirty-three of the Complaint. 

34. Prince Andrew has himself confirmed that he has been on Epstein’s private plane, stayed at Epstein’s private island, and stayed at Epstein’s homes in Palm Beach, Florida, and New York, New York. See Prince Andrew’s links to Jeffrey Epstein, BBC News (Nov. 16, 2019), available at https://www.bbc.com/news/uk-49411215.

Prince Andrew admits the first sentence of paragraph thirty-four of the Complaint. He lacks sufficient information to admit or deny any allegation pertaining to the authenticity the BBC article referenced in paragraph thirty-four. 

35. Members of Epstein’s house staff have confirmed witnessing Prince Andrew visit Epstein’s numerous homes, both to the media and in sworn testimony.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph thirty-five of the Complaint. 

C. Defendant’s Sexual Abuse of Plaintiff

36. Prince Andrew abused Plaintiff on separate occasions when she was under the age of 18 years old.

Prince Andrew denies the allegations contained in paragraph thirty-six of the Complaint. 

37. On one occasion, Prince Andrew sexually abused Plaintiff in London at Maxwell’s home. During this encounter, Epstein, Maxwell, and Prince Andrew forced Plaintiff, a child, to have sexual intercourse with Prince Andrew against her will.

Prince Andrew denies the allegations contained in paragraph thirty-seven of the Complaint. 

38. The below photograph depicts Prince Andrew, Plaintiff, and Maxwell at Maxwell’s home prior to Prince Andrew sexually abusing Plaintiff.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph thirty-eight of the Complaint. 

39. On another occasion, Prince Andrew sexually abused Plaintiff in Epstein’s New York mansion in this District. During this encounter, Maxwell forced Plaintiff, a child, and another victim to sit on Prince Andrew’s lap as Prince Andrew touched her. During his visit to New York, Prince Andrew forced Plaintiff to engage in sex acts against her will.

Prince Andrew denies the allegations contained in paragraph thirty-nine of the Complaint. 

40. On another occasion, Prince Andrew sexually abused Plaintiff on Epstein’s private island in the U.S. Virgin Islands, Little St. James.

Prince Andrew denies the allegations contained in paragraph forty of the Complaint. 

41. During each of the aforementioned incidents, Plaintiff was compelled by express or implied threats by Epstein, Maxwell, and/or Prince Andrew to engage in sexual acts with Prince Andrew, and feared death or physical injury to herself or another and other repercussions for disobeying Epstein, Maxwell, and Prince Andrew due to their powerful connections, wealth, and authority.

Prince Andrew denies the allegations contained in paragraph forty-one of the Complaint. 

42. During each 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 Complaint. 

43. Prince Andrew engaged in each of the aforementioned sexual acts with Plaintiff at Epstein and Maxwell’s invitation, knowing that she was a sex-trafficking victim being forced to engage in sexual acts with him.

Prince Andrew denies the allegations contained in paragraph forty-three of the Complaint. 

44. During each of the aforementioned incidents, Plaintiff did not consent to engaging in sexual acts with Prince Andrew.

Prince Andrew denies the allegations contained in paragraph forty-four of the Complaint and denies that he ever engaged in sexual acts with Giuffre. 

45. During each of the aforementioned incidents, Prince Andrew knew Plaintiff’s age based on communications from Epstein and Maxwell.

Prince Andrew denies the allegations contained in paragraph forty-five of the Complaint. 

46. During each of the aforementioned incidents, Prince Andrew sexually abused Plaintiff for the purpose of gratifying his sexual desires.

Prince Andrew denies the allegations contained in paragraph forty-six of the Complaint. 

47. During each of the aforementioned incidents, Prince Andrew was acting in his individual, personal capacity, and was not performing any duty relating to his former role as a trade envoy, any duty relating to his role as a member of the Royal Family of the United Kingdom, or any other official or diplomatic duty or function.

Prince Andrew denies the allegations contained in paragraph forty-seven of the Complaint and denies that he ever engaged in sexual acts with Giuffre. 

48. Defendant’s sexual assault and battery of Plaintiff have caused her, and continue to cause her, significant emotional and psychological distress and harm. 

Prince Andrew denies the allegations contained in paragraph forty-eight of the Complaint. 

D. The Arrest, Prosecution, and Death of Epstein, and Prince Andrew’s Refusal to Cooperate with the Authorities

49. In 2008, Epstein pled guilty in Florida to the charge of procuring a minor for prostitution.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph forty-nine of the Complaint. 

50. In 2010, after Epstein had served his sentence and registered as a sex offender, Prince Andrew was photographed with Epstein in Central Park and stayed at Epstein’s New York City mansion.

Prince Andrew admits the second clause of paragraph fifty of the Complaint. He lacks sufficient information to admit or deny the remaining allegations contained in that paragraph. 

51. Epstein flippantly referred to his sexual abuse of multiple minors, and the slap on the wrist he had received for it, in a 2011 interview with the New York Post: ‘Billionaire pervert Jeffrey Epstein is back in New York City—and making wisecracks about his just-ended jail stint for having sex with an underage girl. ‘I am not a sexual predator, I’m an ‘offender,’ the financier told The Post yesterday. ‘It’s the difference between a murderer and a person who steals a bagel,’ said Epstein.’ 

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph fifty-one of the Complaint. 

52. Around the same time, Prince Andrew began to face criticism over his well- publicized friendship with Epstein.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph fifty-two of the Complaint. 

53. In early 2015, after Plaintiff had publicly accused Prince Andrew of sexually abusing her, Prince Andrew emailed Maxwell stating, ‘Let me know when we can talk. Got some specific questions to ask you about Virginia Roberts.’

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph fifty-three of the Complaint. 

54. On July 2, 2019, the U.S. Attorney’s Office for the Southern District of New York (‘SDNY’) charged Epstein with sex trafficking conspiracy and sex trafficking in violation of 18 U.S.C. § 1591.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph fifty-four of the Complaint. 

55. Epstein was arrested on July 8, 2019, pursuant to a Sealed Two Count Indictment.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph fifty-five of the Complaint. 

56. Epstein was found dead in his cell at the Metropolitan Correctional Center on August 10, 2019.

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph fifty-six of the Complaint. 

57. Just one year before his death, Epstein told a New York Times reporter ‘that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable.’ 

Prince Andrew lacks sufficient information to admit or deny the allegations contained in paragraph fifty-seven of the Complaint. 

58. After Epstein’s second arrest and death, numerous of his co-conspirators and the wealthy individuals to whom he trafficked girls—including Prince Andrew—began to face increased public scrutiny for having close ties to a convicted sex offender.

Prince Andrew denies that he was a co-conspirator of Epstein or that Epstein trafficked girls to him. Prince Andrew lacks sufficient information to admit or deny the remaining allegations contained in paragraph fifty-eight of the Complaint. 

59. In November 2019, in response to this renewed scrutiny, Prince Andrew sat for an interview with BBC Newsnight. Prince Andrew stated that he did not regret his friendship with Epstein and that he had no recollection of meeting Plaintiff, despite photographic evidence to the contrary.

Prince Andrew lacks sufficient information to admit or deny the allegation that there exists photographic evidence of his alleged meeting with Giuffre. Prince Andrew admits the remainder of paragraph fifty-nine of the Complaint 

60. Prince Andrew publicly pledged, including in a statement stepping down from his public duties and in his Newsnight interview, to assist the U.S. authorities with their criminal investigation of Epstein and his co-conspirators.

Prince Andrew admits paragraph sixty of the Complaint. 

61. Despite this public pledge, Prince Andrew has refused to cooperate with U.S. authorities. Former SDNY U.S. Attorney Geoffrey Berman stated that Prince Andrew had provided ‘zero co-operation’ despite U.S. prosecutors and the FBI contacting Prince Andrew’s counsel. 

Prince Andrew denies the allegations contained in the first sentence of paragraph sixty-one of the Complaint. Prince Andrew lacks sufficient information to admit or deny the remaining allegations contained in that paragraph.

62. Prince Andrew and his counsel have also refused to cooperate with counsel for the victims of Epstein’s sex trafficking. Counsel for the victims of Epstein’s sex trafficking, including counsel for Plaintiff, have repeatedly asked for a meeting or telephone call with Prince Andrew and/or his representatives to enable Prince Andrew to provide whatever facts, context, or explanation he might have, and to explore alternative dispute resolution approaches. Prince Andrew and his representatives have rejected all such requests, and responded by escalating their vile and baseless attacks on Plaintiff and others.

Prince Andrew denies the allegations contained in paragraph sixty-two of the Complaint. 

63. On July 19, 2021, counsel for Plaintiff proposed a tolling agreement that would have enabled Plaintiff not to sue Prince Andrew at this time, while avoiding any argument that her failure to do so caused her claims to be time-barred. Again Prince Andrew stonewalled—ignoring Plaintiff’s letter and emails without any reply or response, thereby making this action necessary now. A copy of the July 19, 2021, letter proposing a tolling agreement is attached as Exhibit A to this Complaint.

The allegations contained in paragraph sixty-three of the Complaint consist of legal conclusions and impermissible legal argument to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained in this paragraph and in Exhibit A attached to the Complaint. 

64. In this country no person, whether President or Prince, is above the law, and no person, no matter how powerless or vulnerable, can be deprived of the law’s protection. Twenty years ago Prince Andrew’s wealth, power, position, and connections enabled him to abuse a frightened, vulnerable child with no one there to protect her. It is long past the time for him to be held to account.

The contentions contained in paragraph sixty-four of the Complaint consist of legal conclusions and impermissible legal argument to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained in this paragraph. 

FIRST CAUSE OF ACTION (Battery)

65. Plaintiff repeats and re-alleges the allegations stated above as if fully set forth herein.

Prince Andrew repeats and re-asserts his responses stated above, as if fully set forth herein. 

66. Prince Andrew intentionally committed battery by sexually assaulting Plaintiff when she was a minor. As described above, on multiple occasions Prince Andrew intentionally touched Plaintiff in an offensive and sexual manner without her consent.

Prince Andrew denies the allegations contained in paragraph sixty-six of the Complaint. 

67. Prince Andrew’s actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to sexual misconduct as defined in Article 130.20, rape in the third degree as defined in Article 130.25, rape in the first degree as defined in Article 130.35, forcible touching as defined in Article 130.52, sexual abuse in the third degree as defined in Article 130.55, and sexual abuse in the first degree as defined in Article 130.65. See N.Y. C.P.L.R. § 214-g.

The allegations contained in paragraph sixty-seven of the Complaint consist of legal conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained in this paragraph. 

68. As a direct and proximate result of Prince Andrew’s criminal acts, Plaintiff has in the past and will in the future continue to suffer substantial damages, including extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.

The allegations contained in paragraph sixty-eight of the Complaint consist of legal conclusions to which no response is required. To the extent a response is required, Prince Andrew lacks sufficient information to admit or deny the allegations contained in this paragraph. 

SECOND CAUSE OF ACTION (Intentional Infliction of Emotional Distress)

69. Plaintiff repeats and re-alleges the allegations stated above as if fully set forth herein.

Prince Andrew repeats and re-asserts his responses stated above, as if fully set forth herein. 

70. As a direct result of these allegations as stated, Prince Andrew committed intentional infliction of emotional distress against Plaintiff.

The allegations contained in paragraph seventy of the Complaint consist of legal conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained in this paragraph. 

71. Prince Andrew’s actions, described above, constitute extreme and outrageous conduct that shocks the conscience. Prince Andrew’s sexual abuse of a child who he knew was a sex-trafficking victim, and when he was approximately 40 years old, goes beyond all possible bounds of decency and is intolerable in a civilized community.

The allegations contained in paragraph seventy-one of the Complaint consist of legal conclusions to which no response is required. To the extent a response is required, Prince Andrew denies the allegations contained in this paragraph. 

72. Prince Andrew knew or disregarded the substantial likelihood that these actions would cause Plaintiff severe emotional distress.

The allegations contained in paragraph seventy-two of the Complaint consist of legal conclusions and impermissible argument to which no response is required. To the extent a response is required, and to the extent the allegations in this paragraph are predicated on any alleged abuse at the hands of Prince Andrew, he denies the allegations in this paragraph. 

73. As a direct and proximate result of Prince Andrew’s criminal acts, Plaintiff has in the past and will in the future continue to suffer substantial damages, including extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy. 

The allegations contained in paragraph seventy-three of the Complaint consist of legal conclusions to which no response is required. To the extent a response is required, and to the extent the allegations in this paragraph are predicated on any alleged abuse at the hands of Prince Andrew, he denies the allegations in this paragraph. 

Prior to today, Andrew had not officially responded to the 73-point civil claim as his lawyers almost immediately applied to a New York judge for it to be thrown out.

That was dismissed earlier this month, meaning he now needs to formally answer the accusations against him, including claims that Miss Roberts, suing under her married made of Giuffre, was trafficked to him by his friend, paedophile Jeffrey Epstein, and forced to have sex with the duke on three occasions when she was 17.

Following his long list of denials, the legal document goes on to offer a series of defences on behalf of Prince Andrew.

The document reiterated the position on the 2009 agreement which was that Ms Giuffre ‘waived the claims now asserted in the complaint’.

Another factor the duke’s legal team asked the court to consider was the issue of consent.

The document reads: ‘Assuming, without admitting, that Giuffre has suffered any injury or damage alleged in the complaint, Giuffre’s claims are barred by the doctrine of consent.’

The duke also claimed the case should be ‘barred in whole or in part by her own wrongful conduct’.

Andrew’s lawyers also asserted that Ms Giuffre should not be able to proceed because her claim for damages is ‘too speculative to be recovered at law’.

This appears to show the duke claiming Ms Giuffre’s claims cannot be proved with reasonable certainty, which would leave jurors speculating as to the actual damages suffered.

Andrew’s lawyers also stated that Ms Giuffre’s claims ‘fail to state facts sufficient to constitute viable causes of action against Prince Andrew’.

The document also argues that the claims should be dismissed because Ms Giuffre is a permanent resident of Australia.


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