Epstein Secrets

nd B. such other and further relief as this Court may deem just and proper. Dated: August 31, 2018 New York, New York STEPTOE & JOHNSON LLP /s/ Michael C. Miller By: Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York, NY 10036 Telephone Facsimile: Attorneys for Defendant 18 EFTA0

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

. such other and further relief as this Court may deem just and proper. Dated: August 31, 2018 New York, New York STEPTOE & JOHNSON LLP By: Is/ Michael C. Miller Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York, NY 10036 Telephone Facsimile: Attorneys for Defendant Jeffrey Epstein

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

urther relief as this Court may deem just and proper. Dated: August 31, 2018 New York, New York STEPTOE & JOHNSON LLP /s/ Michael C Miller By: Michael C. Miller Justin Y.K. Chu 1114 Avenue of the Americas New York, NY 10036 Attorneys for Defendant Jeffrey Epstein 19 Doc. # DC-12059066 v.1 EFTA00798031

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

nd B. such other and further relief as this Court may deem just and proper. Dated: August 31, 2018 New York, New York STEPTOE & JOHNSON LLP /s/ Michael C. Miller By: Michael C. Miller Justin Y.K. Chu e ep one: Facsimile: Attorneys for Defendant 18 EFTA00283710

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,