Epstein Secrets

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

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

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

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

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,

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