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s 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 EFTA00791941
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
is 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 19 EFTA00791923
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
is 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
Entities connected to both Justin Y.K. Chu and First Defense

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Justin Trudeau
PERSONJane Doe
PERSON
Michael C. Miller
PERSON
Lesley Groff
PERSON
United States
LOCATION
Virginia Giuffre
PERSONSouthern District
LOCATIONEleventh Defense
ORGANIZATIONFifth Defense
ORGANIZATION