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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
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
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
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
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
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 Michael C. Miller and Fifth Defense

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSON
Ghislaine Maxwell
PERSON
Justin Trudeau
PERSON
Lesley Groff
PERSON
Virginia Giuffre
PERSONJustin Y.K. Chu
PERSONFirst Defense
ORGANIZATIONEleventh Defense
ORGANIZATION