EPSTEIN
page 4 / 93 . OCR, unverified
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Teala as a sexual object, using her body for his sexual gratification frequently and at his whim.
56.
Eventually, by approximately 2004, Epstein arranged for Teala to live in
an apartment at 301 East 66th Street in Manhattan, just blocks from his townhouse, when she
was in New York.
57.
This pattern – of Epstein exercising total control over Teala’s life and
using her as a sexual object whenever he desired – continued throughout 2003 and 2004. Epstein
arranged for Teala to study abroad two more times, apparently when he grew bored with having
her around. Each time, Teala lived in this nomadic orbit with Epstein both before and after
traveling to attend school.
58.
Epstein also tried to introduce Teala to his “friends” and essentially offer
her as a sexual object to them. In one instance, Epstein had Teala spend time with a well-known
Hollywood producer, who then demanded and attempted to engage in abusive sexual behavior.
Teala barely escaped.
59.
By 2004, Teala felt deep despair and isolation. There was no one she
could talk to about what Epstein was doing to her. Instead, Epstein had ensured that she thought
he was the only person in her life whom she could trust.
60.
Teala developed a severe eating disorder, for the first time, in or around
2004. After she had struggled with the disorder for six months or a year, it became too much to
bear. She confided in Epstein about the eating disorder, still manipulated into thinking he was
someone she could trust.
61.
Instead, from the moment Epstein learned of Teala’s self-destructive
behavior, he immediately cast her out. Literally within hours of Teala anxiously confessing to
Epstein that she did not know why, but had a compulsive need to binge and purge, he threw her
out. He instructed her to pack up her belongings and arranged for her to be flown to Arizona.
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62.
But there was nothing left for her in Arizona. She still had no idea what
had happened to her and felt it was all her fault.
63.
Epstein’s abuse destroyed Teala’s life. After being cast out by him after
two years of a lavish, if abusive, lifestyle, she sank into alcoholism and other self-harm, unable
to trust others but not understanding why.
64.
Ms. Davies is now a working mother raising three children. She is still
struggling to put her life back together.
65.
Ms. Davies is still in the nascent stages of understanding the deep and
lasting injuries that Epstein’s pattern of abuse has caused her, but she feels the effects every day.
She feels dysfunctional, on-edge, and constantly overwhelmed. She has difficulty sleeping. She
often has flashbacks to Epstein’s sexual assaults. She feels like she is on the verge of a
psychological breakdown.
66.
This action is timely under the law of each jurisdiction whose law might
be determined to govern Ms. Davies’s claims or aspects thereof, including without limitation
New York, New Mexico, Florida, and the Virgin Islands.
67.
Ms. Davies still has not disclosed her abuse to a licensed medical or
mental health care provider in the context of receiving health care from the provider.
68.
Ms. Davies is still just beginning to process and understand the full extent
of the injuries that Epstein’s abuse had caused her and the connection between Epstein’s abuse
and the emotional and psychological injuries she had experienced.
69.
This action is timely under New York law because it falls within New
York CPLR 214-g and is brought during the one-year time period set forth in that section. The
claims brought herein allege intentional and negligent acts and/or omissions for physical,
psychological, and other injury suffered as a result of conduct that would constitute sexual
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offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions
were committed against Ms. Davies when she was less than eighteen years of age.
70.
Epstein’s conduct constitutes “childhood sexual abuse” within the
meaning of New Mexico Stat. § 37-1-30 and “abuse” within the meaning of Florida Stat. §
95.11(7).
FIRST CAUSE OF ACTION
(Battery)
71.
Plaintiff hereby incorporates each of the foregoing paragraphs as if fully
set forth herein.
72.
In committing the acts described above, Epstein intentionally subjected
Plaintiff to bodily contact that was offensive in nature.
73.
Epstein intentionally touched Plaintiff in a rude, insolent, or angry
manner.
74.
As a result of Epstein’s actions, Plaintiff suffered damages in an amount to
be determined at trial.
SECOND CAUSE OF ACTION
(Assault)
75.
Plaintiff hereby incorporates each of the foregoing paragraphs as if fully
set forth herein.
76.
In committing the acts described above, Epstein engaged in physical