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

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

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

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

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

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