Epstein Secrets

on in a jurisdiction in which the Fifth Amendment applies. It is Epstein's express intent in this Answer to claim the fullest possible protection of the United States Constitution in responding to the Complaint. Epstein does not intend by any of his responses to waive such protection and requests that, in cases of

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

ated: 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

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