EPSTEIN
page 5 / 93 . OCR, unverified
set forth herein.
76.
In committing the acts described above, Epstein engaged in physical
conduct that placed Plaintiff in imminent apprehension that he would harm her.
77.
As a result of Epstein’s actions, Plaintiff suffered damages in an amount to
be determined at trial.
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 11 of 13
THIRD CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
78.
Plaintiff hereby incorporates each of the foregoing paragraphs as if fully
set forth herein.
79.
In committing the acts described above, Epstein engaged in extreme and
outrageous conduct.
80.
In doing so, Epstein acted with the intent to cause and/or disregard of a
substantial likelihood of causing Plaintiff to suffer severe emotional distress.
81.
As a direct result of Epstein’s actions, Plaintiff suffered severe emotional
distress.
82.
As a result of Epstein’s actions, Plaintiff suffered damages in an amount to
be determined at trial.
WHEREFORE, Plaintiff respectfully requests that judgment be entered against
Defendants as follows:
a. Awarding compensatory damages for all physical injuries, emotional distress,
psychological harm, anxiety, humiliation, physical and emotional pain and
suffering, family and social disruption, and other harm, in an amount to be
determined at trial;
b. Awarding punitive damages in an amount to be determined at trial;
c. Awarding attorneys’ fees and costs pursuant to any applicable statute or law;
d. Awarding pre- and post-judgment interest on all such damages, fees and/or costs;
e. Attaching all of Defendants’ real property and other assets located in the State of
New York pursuant to New York CPLR 6201 et seq. and Federal Rule of Civil
Procedure 64; and
f. Awarding such other and further relief as this Court may deem just and proper.
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 12 of 13
Dated: New York, New York
November 21, 2019
CUTI HECKER WANG LLP
By: /s/ Mariann Meier Wang .
Mariann Meier Wang
Daniel Mullkoff
305 Broadway, Suite 607
New York, New York 10007
(212) 620-2603
mwang@chwllp.com
ALLRED, MAROKO & GOLDBERG
Gloria Allred
305 Broadway, Suite 607
New York, New York 10007
(212) 202-2966
Attorneys for Plaintiff
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 13 of 13
==================== END OF Court Records__Davies v. Indyke, No. 119-cv-10788 (S.D.N.Y. 2019)__001.txt ====================
==================== DOCUMENT: Court Records__Davies v. Indyke, No. 119-cv-10788 (S.D.N.Y. 2019)__002.txt ====================
METADATA_SOURCE: Court RecordsDavies v. Indyke, No. 119-cv-10788 (S.D.N.Y. 2019)
METADATA_FILENAME: 002.pdf
----------------------------------------
Case 1:19-cv-10788-GHW-DCF Document 2 Filed 11/21/19 Page 1 of 2
JS 44C/SDNY
REV. 06/01 /17
CIVIL COVER SHEET
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or
other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the
United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet.
PLAINTIFFS
TEALA DAVIES
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
Cuti Hecker Wang LLP, 305 Broadway, Suite 607, New York, NY 10007
212-620-2606
DEFENDANTS
DARREN K. INDYKE and RICHARD D. KAHN,
as EXECUTORS OF THE ESTATE OF JEFFREY E.
i::D~Ti::111.1·
ATTORNEYS (IF KNOWN)
Bennet J. Moskowitz, Troutman Sanders LLP
875 Third Avenue
New York, NY 10002 (for Defendants lndvke and Kahn)
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSf:)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
USC 1332
Judge Previously Assigned
Has this action, case, or proceeding, or one essentially the same been previously filed in SONY at any time? No[aYesO
If yes, was this case Vol. D lnvol. D Dismissed. No D Yes D
If yes, give date __________ & Case No. _________ _
Is THIS AN INTERNATIONAL ARBITRATION CASE?
No iXJ
Yes D
(PLACE AN [x] IN ONE BOX ONLY)
CONTRACT
[ ] 110
[ ] 120
[] 130
[] 140
[ ] 150
[ ] 151
[ ] 152
[ ] 153
[ ] 160
[ ] 190
[ ] 195
INSURANCE
MARINE
MILLER ACT
NEGOTIABLE
INSTRUMENT
RECOVERY OF
OVERPAYMENT &
ENFORCEMENT
OF JUDGMENT
MEDICARE ACT
RECOVERY OF
DEFAULTED
STUDENT LOANS
(EXCL VETERANS)
RECOVERY OF
OVERPAYMENT
OF VETERAN'S
BENEFITS
STOCKHOLDERS
SUITS
OTHER
CONTRACT
CONTRACT
PRODUCT
LIABILITY
[ ] 196 FRANCHISE
REAL PROPERTY
[ ] 210
LAND
CONDEMNATION
[ ]220
FORECLOSURE
[ ] 230
RENT LEASE &
EJECTMENT
[ ] 240
TORTS TO LAND
[ ] 245
TORT PRODUCT
LIABILITY
[ ] 290
ALL OTHER
REAL PROPERTY
TORTS
PERSONAL INJURY
[ ] 310 AIRPLANE
[ ] 315 AIRPLANE PRODUCT
LIABILITY
[ ] 320 ASSAULT, LIBEL &