Prince Andrew's responses to Virginia Roberts' catalogue of sex abuse ...

Prince Andrew's responses to Virginia Roberts' catalogue of sex abuse ...
Prince Andrew's responses to Virginia Roberts' catalogue of sex abuse ...

Prince Andrew's legal team today filed legal papers denying all of Virginia Roberts' sex abuse allegations as he prepares for a bitter court battle in the United States.

The papers, filed today by the Duke of York's legal counsel Andrew Brettler, contained 41 separate denials of claims made by Roberts in August 2021 last year.

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. 

Roberts, who is referred to in case documents by her married name Virginia Giuffre, 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

Prince Andrew has always vehemently denied all charges, 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.  

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.

Prince Andrew, Virginia Roberts, aged 17, and Ghislaine Maxwell at Ghislaine Maxwell's townhouse in London, Britain on March 13, 2001.

Prince Andrew, Virginia Roberts, aged 17, and Ghislaine Maxwell at Ghislaine Maxwell's townhouse in London, Britain on March 13, 2001.

Roberts, who is referred to in case documents by her married name Virginia Giuffre, 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 (Roberts pictured with her lawyer David Boies in 2019)

Roberts, who is referred to in case documents by her married name Virginia Giuffre, 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 (Roberts pictured with her lawyer David Boies in 2019) 

First page of legal documents submitted today by Prince Andrew's legal team denying the claims of sexual abuse made against him by Virginia Giuffre

First page of legal documents submitted today by Prince Andrew's legal team denying the claims of sexual abuse made against him by Virginia Giuffre

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 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. 

Over 15 pages of court documents filed at New York's southern district court, Roberts, also referred to by her married name Giuffre (pictured in 2019 following a hearing in the Epstein case), claimed that the Duke of York 'committed sexual assault and battery' against her while she was aged just 17, requesting that a judge award 'punitive damages' for the 'physical and psychological' injuries she suffered

Over 15 pages of court documents filed at New York's southern district court, Roberts, also referred to by her married name Giuffre (pictured in 2019 following a hearing in the Epstein case), claimed that the Duke of York 'committed sexual assault and battery' against her while she was aged just 17, requesting that a judge award 'punitive damages' for the 'physical and psychological' injuries she suffered

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.

The Duke of York's official rebuttal comes after a motion to dismiss the case on a legal technicality at the beginning of January was denied

The Duke of York's official rebuttal comes after a motion to dismiss the case on a legal technicality at the beginning of January was denied

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

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