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P By: Is/ Michael C. Miller Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York,
en of proof, persuasion, or production not otherwise legally assigned to him. Epstein reserves all rights to assert other defenses as appropriate. First Defense The Complaint fails to state a claim upon which relief can be granted against Epstein. Second Defense Plaintiff's claim is barred, in whole or in
/s/ Michael C. Miller By: Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York,
ny burden of proof, persuasion, or production not otherwise legally assigned to him. reserves all rights to assert other defenses as appropriate. First Defense The Complaint fails to state a claim upon which relief can be granted against 16 EFTA00791939 Case 1:17-cv-00616-JGK Document 148 Filed 08/31/18
P /s/ Michael C Miller By: Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York,
en of proof, persuasion, or production not otherwise legally assigned to him. Epstein reserves all rights to assert other defenses as appropriate. First Defense The Complaint fails to state a claim upon which relief can be granted against Epstein. Second Defense Plaintiff's claim is barred, in whole or in
/s/ Michael C. Miller By: Michael C. Miller Justin Y.K. Chu e ep one: Facsimile: Attorneys for De
burden of proof, persuasion, or production not otherwise legally assigned to him. reserves all rights to assert other defenses as appropriate. First Defense The Complaint fails to state a claim upon which relief can be granted against MI Second Defense Plaintiff's claim is barred, in whole or in part,
Entities connected to both Justin Trudeau and First Defense

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Virginia Giuffre
PERSONSouthern District
LOCATIONJane Doe
PERSON
Michael C. Miller
PERSONJustin Y.K. Chu
PERSONFifth Defense
ORGANIZATIONEleventh Defense
ORGANIZATION