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/s/ Michael C. Miller By: Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York,
ntiff's claim is barred, in whole or in part, by the doctrines of assumption of risk, estoppel, unclean hands, waiver, consent and/or ratification. Fifth Defense Plaintiff's damages, if any, resulted from the acts or omissions of Plaintiff or third parties other than Sixth Defense The damages, if any, alle
P /s/ Michael C Miller By: Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York,
t, by the doctrines of assumption of risk, estoppel, unclean hands, waiver, consent and/or ratification. 17 Doc. # DC-12059066 v.1 EFTA00798029 Fifth Defense Plaintiff's damages, if any, resulted from the acts or omissions of Plaintiff or third parties other than Epstein. Sixth Defense The damages, if
/s/ Michael C. Miller By: Michael C. Miller Justin Y.K. Chu e ep one: Facsimile: Attorneys for De
ntiff's claim is barred, in whole or in part, by the doctrines of assumption of risk, estoppel, unclean hands, waiver, consent and/or ratification. Fifth Defense Plaintiff's damages, if any, resulted from the acts or omissions of Plaintiff or third parties other than M . Sixth Defense The damages, if any
Entities connected to both Justin Trudeau and Fifth Defense

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