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Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 1 of 13

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-GH

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