Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 17 Civ 616 (JGK) JANE DOE 43, Plaintiff, JEFFREY EPSTEIN, GHISLAINE MAXWELL AND Defendants. ANSWER OF LESLEY ia Defendant Lesley || HH. by and through her counsel, answers and responds to Plaintiff || Pd (“Plaintiff or i) First Amended Complaint (the “Complaint”). PRELIMINARY STATEMENT! | | enjoys the same protections of the self-incrimination clause of the Fifth Amendment to the United States Constitution (the “Fifth Amendment”) as do all other persons who are potentially subject to criminal prosecution in a jurisdiction in which the Fifth Amendment applies. It is iz express intent in this Answer to claim the fullest possible protection of the United States Constitution in responding to the Complaint. im does not intend by any of her responses to waive such protection and requests that, in cases of any doubt or ambiguity, her response be construed as an assertion rather than a waiver of such privilege. BE also reserves her right to amend her responses without compromising her rights under the Fifth Amendment. ' || is not required to respond to the headings set forth in the Complaint since they are not factual allegations. EFTA00283693

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 2 of 18 RESPONSE TO SPECIFIC ALLEGATIONS 1. i admits that the Plaintiff purports to bring this lawsuit pursuant to the statutes described in Paragraph 1. 2. In response to the allegations in Paragraph 2, || admits that the Plaintiff filed this lawsuit under a pseudonym purportedly for the reasons stated therein. 3. It appears that the allegations in Paragraph 3 are directed to an individual other than Zz. to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 4. It appears that the allegations in Paragraph 4 are directed to an individual other than Zz. to which no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 5. It appears that the allegations in Paragraph 5 are directed to an individual other than ZZ to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 6. It appears that the allegations in Paragraph 6 are directed to an individual other than Zz. to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 7. It appears that the allegations in Paragraph 7 are directed to an individual other than Zz to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 8. i admits that she is a citizen of the United States. In response to the other allegations in Paragraph 8, | | asserts her rights under the Fifth Amendment and declines to answer. EFTA00283694

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 3 of 18 9. It appears that the allegations in Paragraph 9 state conclusions of law, to which no responsive pleading is required. To the extent a response is required, | | asserts her rights under the Fifth Amendment and declines to answer. 10. It appears that the allegations in Paragraph 10 state conclusions of law, as to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 11. To the extent the allegations in Paragraph 11 concern , conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than im and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. 12. It appears that the allegations in Paragraph 12 are directed to an individual other than ZZ to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 13. It appears that the allegations in Paragraph 13 are directed to an individual other than Zz to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 14. To the extent the allegations in Paragraph 14 concern f conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. EFTA00283695

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 4 of 18 15. It appears that the allegations in Paragraph 15 are directed to individuals other than | to which no responsive pleading is required. To the extent a response is required, BEE assens her rights under the Fifth Amendment and declines to answer. 16. It appears that the allegations in Paragraph 16 are directed to individuals other than to which no responsive pleading is required. To the extent a response is required, BB sens her rights under the Fifth Amendment and declines to answer. 17. In response to the allegations in Paragraph 17 $B asserts her rights under the Fifth Amendment and declines to answer. 18. To the extent the allegations in Paragraph 18 concer asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other thanfand/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. 19. To the extent the allegations in Paragraph 19 concern f | conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is requiredifasserts her rights under the Fifth Amendment and declines to answer. 20. ‘To the extent the allegations in Paragraph 20 concer conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than onaior state conclusions of law, no responsive pleading is required. To the extent a response is required, BR assexs her rights under the Fifth Amendment and declines to answer. EFTA00283696

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 5 of 18 21. To the extent the allegations in Paragraph 21 concern conduct asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. 22. To the extent the allegations in Paragraph 22 concern conduct asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other ihan and/or state conclusions of law, no responsive pleading is required. To the extent a response is required I asserts her rights under the Fifth Amendment and declines to answer. 23. It appears that the allegations in Paragraph 23 are directed to individuals other than to which no responsive pleading is required. To the extent a response is required, BB esses her rights under the Fifth Amendment and declines to answer. 24. To the extent the allegations in Paragraph 24 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required {psserts her rights under the Fifth Amendment and declines to answer. 25. To the extent the allegations in Paragraph 25 concer fla conduct asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, | her rights under the Fifth Amendment and declines to answer. EFTA00283697

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 6 of 18 26. To the extent the allegations in Paragraph 26 concer conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than andor state conclusions of law, no responsive pleading is required. To the extent a response is required assert her rights under the Fifth Amendment and declines to answer. 27. It appears that the allegations in Paragraph 27 are directed to individuals other haf to which no responsive pleading is required. To the extent a response is required, BB ssers her rights under the Fifth Amendment and declines to answer. 28. To the extent the allegations in Paragraph 28 concern] conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than fl and/or state conclusions of law, no responsive pleading is required. To the extent a response is required ia asserts her rights under the Fifth Amendment and declines to answer. 29. It appears that the allegations in Paragraph 29 are directed to an individual other than to which no responsive pleading is required. To the extent a response is required, BB sens her rights under the Fifth Amendment and declines to answer. 30. To the extent the allegations in Paragraph 30 concern I conduc asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other nal and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, | her rights under the Fifth Amendment and declines to answer. 31. To the extent the allegations in Paragraph 31 concer fl conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations EFTA00283698

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 7 of 18 are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEE asserts her rights under the Fifth Amendment and declines to answer. 32. To the extent the allegations in Paragraph 32 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 33. To the extent the allegations in Paragraph 33 concern iz conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than im and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 34. To the extent the allegations in Paragraph 34 concern mz conduct, ma asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than im and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 35. It appears that the allegations in Paragraph 35 are directed to an individual other than ZZ to which no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. EFTA00283699

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 8 of 18 36. It appears that the allegations in Paragraph 36 are directed to individuals other than ZZ to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 37. To the extent the allegations in Paragraph 37 concern mz conduct, ma asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. 38. To the extent the allegations in Paragraph 38 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. 39. It appears that the allegations in Paragraph 39 are directed to individuals other than Zz. to which no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 40. To the extent the allegations in Paragraph 40 concern f conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than || and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 41. To the extent the allegations in Paragraph 41 concern iz conduct, i asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations EFTA00283700

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 9 of 18 are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. 42. To the extent the allegations in Paragraph 42 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 43. To the extent the allegations in Paragraph 43 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. 44. To the extent the allegations in Paragraph 44 concern f conduct, ma asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 45. To the extent the allegations in Paragraph 45 concern iz conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than im and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. EFTA00283701

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 10 of 18 46. It appears that the allegations in Paragraph 46 are directed to individuals other than ZZ to which no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 47. It appears that the allegations in Paragraph 47 are directed to individuals other than Zz to which no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 48. To the extent the allegations in Paragraph 48 concern f conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than || and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 49. To the extent the allegations in Paragraph 49 concern iz conduct, i asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than || and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BB asserts her rights under the Fifth Amendment and declines to answer. 50. To the extent the allegations in Paragraph 50 concern f conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 51. To the extent the allegations in Paragraph 51 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations 10 EFTA00283702

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 11 of 18 are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 52. To the extent the allegations in Paragraph 52 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 53. To the extent the allegations in Paragraph 53 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 54. To the extent the allegations in Paragraph 54 concern mz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than ma and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEE asserts her rights under the Fifth Amendment and declines to answer. 55. To the extent the allegations in Paragraph 55 concern iz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than im and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. 11 EFTA00283703

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 12 of 18 56. To the extent the allegations in Paragraph 56 concern | | conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 57. To the extent the allegations in Paragraph 57 concern | | conduct, la asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than || and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 58. To the extent the allegations in Paragraph 58 concern | | conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 59. To the extent the allegations in Paragraph 59 concern | | conduct, la asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BER asserts her rights under the Fifth Amendment and declines to answer. 60. To the extent the allegations in paragraph 60 concern || conduct, im asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive EFTA00283704

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 13 of 18 pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 61. To the extent the allegations in Paragraph 61 concern iz conduct, i asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 62. To the extent the allegations in Paragraph 62 concern mz conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 63. To the extent the allegations in Paragraph 63 concern iz conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than || and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 64. To the extent the allegations in Paragraph 64 concern fs conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 13 EFTA00283705

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 14 of 18 65. To the extent the allegations in Paragraph 65 concern | | conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 66. To the extent the allegations in Paragraph 66 concern | | conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 67. In response to Paragraph 67, || repeats and incorporates her responses to Paragraphs | through 66 of the Complaint. 68. To the extent the allegations in Paragraph 68 concern iz conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 69. To the extent the allegations in Paragraph 69 concern f conduct, || asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Zz and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 14 EFTA00283706

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 15 of 18 70. To the extent the allegations in Paragraph 70 concern | | conduct, | | asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than i and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 71. To the extent the allegations in Paragraph 71 concern | | conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BE asserts her rights under the Fifth Amendment and declines to answer. 72. To the extent the allegations in Paragraph 72 concern | | conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 73. To the extent the allegations in Paragraph 73 concern | | conduct, la asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 74. It appears the allegations in Paragraph 74 state conclusion of law, as to which no response is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. EFTA00283707

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 16 of 18 75. To the extent the allegations in Paragraph 75 concern | | conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than | | and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 76. To the extent the allegations in Paragraph 76 concern | | conduct, li asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than || and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. 77. It appears the allegations in Paragraph 77 state conclusion of law, as to which no response is required. To the extent a response is required, BEB asserts her rights under the Fifth Amendment and declines to answer. DEFENSES By alleging the following defenses, BEB does not assume any burden of proof, persuasion, or production not otherwise legally assigned to him. BEB 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 Zz Second Defense Plaintiff's claim is barred, in whole or in part, by the applicable statute of limitations and/or laches. Third Defense Plaintiff failed to mitigate damages in whole or in part. 16 EFTA00283708

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 17 of 18 Fourth Defense Plaintiff'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 Zz. Sixth Defense The damages, if any, alleged in the Complaint were directly and proximately caused, in whole or in part, by superseding or intervening conduct for which BB cannot be held liable. Seventh Defense The conduct alleged does not constitute a violation, and is beyond the scope, of the federal criminal anti-sex trafficking statutes upon which this suit is based, none of which are meant to regulate voluntary private relationships. Eighth Defense Plaintiffs claim is barred because Plaintiff was an educated, experienced and sophisticated individual who was free to associate and form relationships with anyone and free to terminate her association and relationships with anyone. Ninth Defense Plaintiff's claim is barred because Plaintiff did not actually rely and did not detrimentally and/or reasonably rely upon any misrepresentations or omissions alleged in the Complaint. Tenth Defense This Court lacks personal jurisdiction over Zz. EFTA00283709

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Case 1:17-cv-00616-JGK Document 147 Filed 08/31/18 Page 18 of 18 Eleventh Defense | | presently has insufficient knowledge or information upon which to form a belief as to whether he may have other, unstated, defenses. la reserves the right to supplement this Answer and to assert other defenses, when and if they become appropriate in this action. PRAYER FOR RELIEF WHEREFORE, | respectfully requests: A. judgment dismissing the First Amended Complaint with prejudice; and B. such other and further relief as this Court may deem just and proper. Dated: August 31, 2018 New York, New York STEPTOE & JOHNSON LLP By: /s/ Michael C. Miller Michael C. Miller Justin Y.K. Chu elephone: Facsimile: Attorneys for Defendant P| EFTA00283710