Case 1:17-cv-00616-JGK Document 146 Filed 08/31/18 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 17 Civ 616 (JGK) JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN GHISLAINE MAXWELL, KELLEN LESLEY GROFF, AND Defendants. ANSWER OF JEFFREY EPSTEIN Defendant Jeffrey Epstein ("Epstein"), by and through his counsel, answers and responds to Plaintiff "Complaint"). ("Plaintiff" or 'e) First Amended Complaint (the PRELIMINARY STATEMENT' Epstein 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 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 any doubt or ambiguity, his response be construed as an assertion rather than a waiver of such privilege. Epstein also reserves his right to amend his responses without compromising his rights under the Fifth Amendment. Epstein is not required to respond to the headings set forth in the Complaint since they are not factual allegations. EFTA00791905