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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
nd/or reasonably rely upon any misrepresentations or omissions alleged in the Complaint. Tenth Defense This Court lacks personal jurisdiction over Eleventh Defense reserves the right to supplement this Answer and to assert other defenses, when and if they become appropriate in this action. PRAYER FOR RELIEF
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
sonably rely upon any misrepresentations or omissions alleged in the Complaint. Tenth Defense This Court lacks personal jurisdiction over Epstein. Eleventh Defense Epstein reserves the right to supplement this Answer and to assert other defenses, when and if they become appropriate in this action. 18 EFTA007
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
by, or the damages, if any, allegedly sustained by her are reduced by, the contributory and/or comparative fault of Plaintiff and/or third parties. Eleventh Defense Plaintiff's claims are barred by, or the damages, if any, allegedly sustained by her are reduced by, the contributory and/or comparative fault of P
Entities connected to both First Defense and Eleventh Defense

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Justin Trudeau
PERSON
Michael C. Miller
PERSON
United States
LOCATIONJustin Y.K. Chu
PERSON
Lesley Groff
PERSONFifth Defense
ORGANIZATIONJane Doe
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATION