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Case 1:19-cv-10476 Document 1 Filed 11/12/19 Page 1 of 14
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
TERESA HELM,
Plaintiff, CASE NO:
v.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
_____________________________________
COMPLAINT
BOIES SCHILLER FLEXNER LLP
1
Case 1:19-cv-10476 Document 1 Filed 11/12/19 Page 2 of 14
Plaintiff Teresa Helm, by her attorneys Boies Schiller Flexner LLP, for her Complaint
against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of
the Estate of Jeffrey Edward Epstein (“Epstein”), avers upon personal knowledge as to her own
acts and status and upon information and belief and to all other matters as follows:
NATURE OF THE ACTION
1. This suit arises out of Jeffrey Epstein’s sexual abuse of Plaintiff.
2. Teresa was sexually trafficked by Epstein, Sarah Kellen, and Ghislaine Maxwell as part
of Epstein’s organized ring of procuring young women for sex. She was recruited by a woman
who worked for Epstein and who offered Teresa the opportunity to become a traveling masseuse.
As Teresa was studying massage at the California Healing Arts College, this seemed like a
dream opportunity, but her hopes were dashed when it quickly turned into sexual assault.
3. Epstein’s trafficking scheme involved recruiting young females by making false promises
and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young women.
4. As United States District Judge Kenneth Marra found, “From between ab
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