EPSTEIN
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Court Records Davies v. Indyke, No. 119-
==================== DOCUMENT: Court Records__Davies v. Indyke, No. 119-cv-10788 (S.D.N.Y. 2019)__001.txt ====================
METADATA_SOURCE: Court RecordsDavies v. Indyke, No. 119-cv-10788 (S.D.N.Y. 2019)
METADATA_FILENAME: 001.pdf
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
___________________________________________x
TEALA DAVIES,
Case No. 19 Civ. 10788
Plaintiff,
COMPLAINT
-against-
AND JURY DEMAND
DARREN K. INDYKE and RICHARD D. KAHN,
as EXECUTORS OF THE ESTATE OF JEFFREY E.
EPSTEIN,
Defendants.
___________________________________________x
Plaintiff Teala Davies, by and through her attorneys, Cuti Hecker Wang LLP and
Allred, Maroko & Goldberg, for her Complaint alleges as follows:
NATURE OF THE ACTION
1.
When Plaintiff Teala Davies was just seventeen years old, living on her
own and working full-time to support herself, Jeffrey Epstein preyed open her, manipulated her
to be completely dependent on him, and sexually abused her.
2.
Epstein was presented to Teala as someone who had learned about her
challenging circumstances and had the resources and interest to assist her – including by helping
her to attend college and study abroad to see the world. Teala was introduced to Epstein by her
sister, but Teala was unaware that Epstein had been manipulating and sexually abusing her sister,
as Epstein’s total power and control over Teala’s sister made it impossible for her to say
anything about it.
3.
During their early interactions, Epstein led Teala to believe that he would
help her achieve her dream of becoming a translator, and he arranged for Teala to study abroad
in Spain. Teala gave up her job and her apartment in anticipation of this life-changing
opportunity, leaving her completely dependent on Epstein and his continuing generosity.
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 1 of 13
4.
Epstein exploited this power over seventeen-year-old Teala to sexually
abuse her repeatedly. Ultimately, he raped and sexually assaulted her frequently and in a variety
of places and settings, including by trafficking Teala to his homes in New York, New Mexico,
Florida, the Virgin Islands, and France. He treated her like an object for his sexual gratification.
5.
These assaults caused Teala to feel completely intimidated and fearful.
She froze up and began to cry, able to think only about trying to survive.
6.
Epstein continued to exert total control over Teala’s life for two more
years, trafficking her around the country and the world and sexually abusing her on a frequent
basis. During this time, Teala felt deep despair and isolation, and developed a severe and self-
destructive eating disorder. Still within his power and control, Teala confided in Epstein about
her disorder, mistakenly believing that she could trust him. Rather than help her, Epstein cast
her out within hours of her admission, sending her back to a place where she no longer had a
home, a job or any resources or support.
7.
Epstein’s abuse destroyed Ms. Davies’s life. She sank into alcoholism and
other self-harm, unable to trust others but not understanding why.
8.
At the same time, like so many childhood sex abuse victims, she did not
comprehend how it had undone her or her life, or how it impacted her.
9.
Now a working mother of three, Ms. Davies is still just beginning to
understand the depth of the injuries from the sexual assaults that Epstein inflicted on her
beginning when she was seventeen. She feels the toll of Epstein’s abuse every day. She feels
dysfunctional, on-edge, overwhelmed, and like she is on the verge of a psychological
breakdown. She has difficulty sleeping and often has flashbacks to Epstein’s abuse.
10.
Epstein died in August 2019, before Ms. Davies or the countless other
girls he preyed upon could obtain a modicum of justice.
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 2 of 13
11.
Ms. Davies brings this action seeking, at last, some remedy for the
egregious abuse that Epstein inflicted when she was a child.
PARTIES
12.
Plaintiff Teala Davies is an individual who resides in Arizona.
13.
Defendants Darren K. Indyke and Richard D. Kahn are the Executors of
the Estate of Jeffrey E. Epstein (the “Estate”). As Executors of the Estate, Defendants are liable
for the acts and omissions of Epstein and his agents. For purposes of 28 U.S.C. § 1332,
Defendants Indyke and Kahn are deemed to be citizens of the United States Virgin Islands,
where Epstein was domiciled at the time of his death.
JURISDICTION AND VENUE
14.
This Court has subject-matter jurisdiction pursuant to 28 U.S.C. § 1332
because this case is between citizens of different states and the amount in controversy exceeds
$75,000.
15.
Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(2)
because a substantial part of the events or omissions giving rise to the claim occurred in this