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Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 1 of 17

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

ANASTASIA DOE,

Plaintiff, CASE NO.: 1:19-cv-11869 (MKV) (DCF)

DARREN K. INDYKE AND RICHARD D.
KAHN AS CO-EXECUTORS OF THE
ESTATE OF JEFFREY E. EPSTEIN,

Defendants.

DEFENDANTS’ ANSWER AND AFFIRMATIVE DEFENSES TO
PLAINTIFF’S COMPLAINT

Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of

Jeffrey E. Epstein (the “Co-Executors”), through their undersigned counsel, hereby respond to the

numbered paragraphs of Plaintiff’s Complaint (ECF Doc. 1) as follows:

1. The Co-Executors lack knowledge or information sufficient to form a belief about

the truth of the allegations in the first sentence of paragraph 1 of the Complaint. The second

sentence of paragraph 1 of the Complaint states a legal conclusion to which no response is required.

2. The Co-Executors lack knowledge or information sufficient to form a belief about

the truth of the allegations in paragraph 2 of the Complaint, except admit that Plaintiff filed the

Complaint using a pseudonym.

3. The Co-Executors lack knowledge or information sufficient to form a belief about

the truth of the allegations in paragraph 3 of the Complaint.

4. The Co-Executors lack knowledge or information sufficient to form a belief about

the truth of the allegations in paragraph 4 of the Complaint, except admit that, at the time of his

death, decedent Jeffrey E. Epstein (“Decedent”) was a U.S. citizen.
Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 2 of 17

5. The Co-Executors lack knowledge or information sufficient to form a belief about

the truth of the allegations in paragraph 5 of t

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