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GIUFFRE V PRINCE His Answer To Her Complaint
GIUFFRE V PRINCE His Answer To Her Complaint
Defendant.
Defendant Prince Andrew, Duke of York (“Prince Andrew”), by and through his
attorneys at Lavely & Singer, P.C., answers the complaint filed by plaintiff Virginia L. Giuffre
Complaint.
6. Prince Andrew denies the allegations contained in paragraph six of the Complaint.
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7. Prince Andrew denies the first clause in paragraph seven of the Complaint. He
lacks sufficient information to admit or deny the remaining allegations contained in that
paragraph.
8. Prince Andrew admits that he met Jeffrey Epstein (“Epstein”) in or around 1999.
Complaint.
10. Prince Andrew denies the allegations contained in the first sentence of paragraph
ten of the Complaint. The remainder of that paragraph amounts to a legal conclusion to which
no response is required. To the extent a response is required, Prince Andrew denies the
11. The contentions in paragraph eleven of the Complaint are legal conclusions to
which no response is required. To the extent a response is required, Prince Andrew denies the
PARTIES
12. Prince Andrew disputes that Giuffre is domiciled in the State of Colorado and on
response is required. To the extent a response is required, Prince Andrew disputes and denies
that the Court has subject matter jurisdiction over this dispute on the grounds that Giuffre is not
domiciled in Colorado.
response is required. To the extent a response is required, Prince Andrew denies the allegations
in this paragraph.
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response is required. To the extent a response is required, Prince Andrew denies the allegations
in this paragraph.
FACTUAL ALLEGATIONS
17. Prince Andrew lacks sufficient information to admit or deny the allegations
18. Prince Andrew lacks sufficient information to admit or deny the allegations
19. Prince Andrew lacks sufficient information to admit or deny the allegations
20. Prince Andrew lacks sufficient information to admit or deny the allegations
21. Prince Andrew lacks sufficient information to admit or deny the allegations
22. Prince Andrew lacks sufficient information to admit or deny the allegations
23. Prince Andrew lacks sufficient information to admit or deny the allegations
25. Prince Andrew lacks sufficient information to admit or deny the allegations
26. Prince Andrew lacks sufficient information to admit or deny the allegations
contained in paragraph twenty-six of the Complaint, including those pertaining to the graphic
embedded therein.
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27. Prince Andrew lacks sufficient information to admit or deny the allegations in
paragraph twenty-seven of the Complaint pertaining to the alleged abuse of Giuffre at the hands
28. Prince Andrew lacks sufficient information to admit or deny the allegations
contained in paragraph twenty-eight of the Complaint. To the extent the allegations in this
paragraph are predicated on any alleged abuse at the hands of Prince Andrew, he denies the
29. Prince Andrew lacks sufficient information to admit or deny the allegations
30. Prince Andrew admits that he met Epstein in or around 1999. He denies the
remaining allegations in the first sentence of paragraph thirty of the Complaint, and lacks
sufficient information to admit or deny the allegations contained in the second sentence of that
paragraph.
31. Prince Andrew lacks sufficient information to admit or deny the allegations
32. Prince Andrew admits the first sentence of paragraph thirty-two of the Complaint.
33. Prince Andrew lacks sufficient information to admit or deny the allegations
contained in paragraph thirty-three of the Complaint.
34. Prince Andrew admits the first sentence of paragraph thirty-four of the Complaint.
He lacks sufficient information to admit or deny any allegation pertaining to the authenticity the
35. Prince Andrew lacks sufficient information to admit or deny the allegations
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36. Prince Andrew denies the allegations contained in paragraph thirty-six of the
Complaint.
37. Prince Andrew denies the allegations contained in paragraph thirty-seven of the
Complaint.
38. Prince Andrew lacks sufficient information to admit or deny the allegations
39. Prince Andrew denies the allegations contained in paragraph thirty-nine of the
Complaint.
40. Prince Andrew denies the allegations contained in paragraph forty of the
Complaint.
41. Prince Andrew denies the allegations contained in paragraph forty-one of the
Complaint.
42. Prince Andrew denies the allegations contained in paragraph forty-two of the
Complaint.
43. Prince Andrew denies the allegations contained in paragraph forty-three of the
Complaint.
44. Prince Andrew denies the allegations contained in paragraph forty-four of the
Complaint and denies that he ever engaged in sexual acts with Giuffre.
45. Prince Andrew denies the allegations contained in paragraph forty-five of the
Complaint.
46. Prince Andrew denies the allegations contained in paragraph forty-six of the
Complaint.
47. Prince Andrew denies the allegations contained in paragraph forty-seven of the
Complaint and denies that he ever engaged in sexual acts with Giuffre.
48. Prince Andrew denies the allegations contained in paragraph forty-eight of the
Complaint.
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D. The Arrest, Prosecution, and Death of Epstein, and Prince Andrew’s Alleged
49. Prince Andrew lacks sufficient information to admit or deny the allegations
50. Prince Andrew admits the second clause of paragraph fifty of the Complaint. He
lacks sufficient information to admit or deny the remaining allegations contained in that
paragraph.
51. Prince Andrew lacks sufficient information to admit or deny the allegations
52. Prince Andrew lacks sufficient information to admit or deny the allegations
53. Prince Andrew lacks sufficient information to admit or deny the allegations
54. Prince Andrew lacks sufficient information to admit or deny the allegations
55. Prince Andrew lacks sufficient information to admit or deny the allegations
56. Prince Andrew lacks sufficient information to admit or deny the allegations
58. Prince Andrew denies that he was a co-conspirator of Epstein or that Epstein
trafficked girls to him. Prince Andrew lacks sufficient information to admit or deny the
59. Prince Andrew lacks sufficient information to admit or deny the allegation that
there exists photographic evidence of his alleged meeting with Giuffre. Prince Andrew admits
the remainder of paragraph fifty-nine of the Complaint.
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61. Prince Andrew denies the allegations contained in the first sentence of paragraph
sixty-one of the Complaint. Prince Andrew lacks sufficient information to admit or deny the
62. Prince Andrew denies the allegations contained in paragraph sixty-two of the
Complaint.
legal conclusions and impermissible legal argument to which no response is required. To the
extent a response is required, Prince Andrew denies the allegations contained in this paragraph
legal conclusions and impermissible legal argument to which no response is required. To the
extent a response is required, Prince Andrew denies the allegations contained in this paragraph.
(Battery)
65. Prince Andrew repeats and re-asserts his responses stated above, as if fully set
forth herein.
66. Prince Andrew denies the allegations contained in paragraph sixty-six of the
Complaint.
67. The allegations contained in paragraph sixty-seven of the Complaint consist of
legal conclusions to which no response is required. To the extent a response is required, Prince
legal conclusions to which no response is required. To the extent a response is required, Prince
Andrew lacks sufficient information to admit or deny the allegations contained in this paragraph.
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69. Prince Andrew repeats and re-asserts his responses stated above, as if fully set
forth herein.
70. The allegations contained in paragraph seventy of the Complaint consist of legal
legal conclusions to which no response is required. To the extent a response is required, Prince
legal conclusions and impermissible argument to which no response is required. To the extent a
response is required, and to the extent the allegations in this paragraph are predicated on any
alleged abuse at the hands of Prince Andrew, he denies the allegations in this paragraph.
legal conclusions to which no response is required. To the extent a response is required, and to
the extent the allegations in this paragraph are predicated on any alleged abuse at the hands of
AFFIRMATIVE DEFENSES
Prince Andrew hereby asserts the following affirmative defenses without assuming the
1. Giuffre’s Complaint should be dismissed because this Court lacks subject matter
jurisdiction over the action, due to Giuffre’s improper assertion of diversity jurisdiction
notwithstanding that she is a permanent resident of Australia and not a domiciliary of Colorado.
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2. Giuffre, through her own actions, inactions, and other conduct – including,
without limitation, entering into the 2009 Release Agreement with Epstein containing a broad
third-party release of her claims against Prince Andrew and others – waived the claims now
(Laches)
3. Giuffre is barred, in whole or in part, from obtaining the requested relief based on
4. Assuming, without admitting, that Giuffre has suffered any injury or damage,
Giuffre and/or others, who are not Prince Andrew, contributed in whole or in part to the alleged
damage.
(Consent)
damage alleged in the Complaint, Giuffre’s claims are barred by the doctrine of consent.
SIXTH AFFIRMATIVE DEFENSE
(Unclean Hands)
6. Giuffre’s alleged causes of action are barred in whole or in part by her own
(Estoppel)
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(Statute of Limitations)
limitations.
(Speculative Damages)
9. Giuffre cannot recover the damages alleged in the Complaint because such
10. Giuffre’s prayer for exemplary or punitive damages is barred because the
Complaint fails to allege facts sufficient to entitle Giuffre to recover exemplary or punitive
damages from Prince Andrew. Moreover, any award of punitive damages is unconstitutional if it
11. Giuffre’s causes of action fail to state facts sufficient to constitute viable causes of
as to whether he may have additional, as yet unstated, affirmative defenses available. Prince
Andrew therefore expressly and specifically reserves the right to amend this Answer to add,
delete and/or modify affirmative defenses based on legal theories, facts, and circumstances that
may be or will be divulged through discovery and/or through legal analysis of Prince Andrew in
this action.
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(a) That Giuffre’s Complaint and the first and second causes of action pleaded therein
(b) That Giuffre take nothing by her Complaint and that judgment be entered against
(c) That Prince Andrew be granted such other and further relief as this Court may
JURY DEMAND
Prince Andrew hereby demands a trial by jury on all causes of action asserted in the
Complaint.
Respectfully submitted,
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