EPSTEIN
page 2 / 93 . OCR, unverified
District.
16.
This Court has personal jurisdiction over Defendants. As Executors of the
Estate, Defendants Indyke and Kahn are subject to personal jurisdiction in this Court because
Epstein was subject to personal jurisdiction at the time of his death.
17.
This Court had both specific and general personal jurisdiction over Epstein
at the time of his death.
18.
Epstein resided in New York State a substantial portion of the time during
the time period at issue in this lawsuit, and through the time of his death.
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 3 of 13
19.
Epstein resided in the Metropolitan Correctional Center in New York
County at the time of his death.
20.
Epstein conducted substantial business operations in New York.
21.
Epstein owned and/or controlled numerous companies with principal
places of business in New York.
22.
Epstein owned substantial real property assets in New York, including the
townhouse located at 9 East 71st Street in Manhattan, which is valued at $55 million or more.
23.
New York was the epicenter of Epstein’s criminal sex-trafficking
enterprise. For years, Epstein and his agents took actions in New York in order to arrange for
minor girls to be trafficked to his homes throughout the country in order to perform sexual acts
for him. Epstein’s trafficking and abuse of Ms. Davies was part of that New York-based
criminal enterprise.
24.
From his Manhattan townhouse, Epstein directed a vast network of agents
in recruiting minor girls to be brought to him for his sexual use.
25.
Epstein sexually abused many minor girls, including Ms. Davies, in his
Manhattan townhouse.
26.
On many occasions, Epstein and his agents made phone calls from New
York to schedule appointments for minor girls to come to Epstein’s residences outside of New
York in order to perform commercial sexual acts for Epstein.
27.
Upon information and belief, Epstein and/or his agents were present in
New York when they took various actions to facilitate the trafficking of Ms. Davies for the
purpose of performing sexual acts for Epstein.
JURY DEMAND
28.
Plaintiff hereby demands a trial by jury on all of her claims in this action.
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 4 of 13
FACTUAL ALLEGATIONS
29.
When Plaintiff Teala Davies was seventeen years old, Jeffrey Epstein
preyed upon her, manipulating her to be completely dependent on him and then sexually
assaulting and raping her on numerous occasions. Epstein continued this pattern of manipulation
and frequent sexual assault for years, leaving Ms. Davies with deep emotional wounds that she is
still just beginning to grapple with.
30.
By age seventeen, Teala had already lived through tremendously
challenging circumstances. At eleven years old, she was homeless for a year, staying with
various friends and seeing her mother only about once a week. At fifteen, Teala began working
in order to support herself. At sixteen, Teala’s living situation was again unstable, and she
moved to Los Angeles to live with her older sister.
31.
Teala initially tried to go to school in Los Angeles, but was unable to
continue due to the need to work full-time to support herself. Teala lived with her sister and
worked at a hair salon, eventually getting her GED. By the time Teala met Epstein, she had
already been living on her own and working full-time for a year-and-a-half.
32.
Teala’s sister – who is five years older than her – had previously met
Epstein and traveled with him. Teala’s sister described Epstein to her as a generous wealthy
person, and reported that he often helped make it possible for people to attend college. Teala’s
sister reported that Epstein had heard Teala’s story and that he wanted to help.
33.
Unbeknownst to Teala, Epstein had been manipulating and sexually
abusing her sister. Teala had no idea that her sister had been involved in any type of sexual
interactions with Epstein. Epstein’s power and control of Teala’s sister made it impossible for
her to say anything.
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 5 of 13
34.
Teala met Epstein for the first time in 2002, when she was seventeen years
old. Epstein was visiting Los Angeles, and Teala drove with her sister to meet him at the Hotel
Bel-Air.
35.
During that first meeting, Epstein lay on a bed in his spacious hotel suite,
fully clothed. He asked Teala’s sister to massage his feet, then encouraged Teala to join her.
Afterwards, Epstein took them shopping, and insisted on buying several items for Teala.
36.
After that meeting, Epstein kept in touch with Teala through frequent
phone calls. Epstein veered the conversation toward Teala’s career goals and how Epstein could
help her achieve them. He purported to want to help her and guide her to a better life.
37.
Epstein offered to send Teala to school to learn hairdressing, but Teala