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Teala Davies And The Lawsuit Filed Against Jeffrey Epstein · The Vault: The Epstein Files

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  Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
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  Speaker 1: On today's episode, we're gonna continue exploring the Jeffrey Epstein
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  Speaker 1: court documents, and this time, we're taking a look at
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  Speaker 1: the lawsuit that Epstein survivor, Teela Davies, filed against Jeffrey
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  Speaker 1: Epstein and the estate. Case number, ST-19-PB-80. Action for probate.
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  Speaker 1: In the matter of the estate, of Jeffrey E. Epstein. Claim.
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  Speaker 1: The undersigned Marianne Meyer Wang, Esquire, of Cuddehecker Wang LLP,
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  Speaker 1: Richard P. Bourne Vanek, Esquire, and Allred, Morocco and Goldberg,
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  Speaker 1: hereby present and file this claim on behalf of Tila Davies,
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  Speaker 1: the claimant, for unliquidated and unsecured damages from the estate
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  Speaker 1: of Jeffrey E. Epstein, the estate, in the above captioned matter,
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  Speaker 1: now pending before court and in support thereof, state as follows. 1.
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  Speaker 1: Jeffrey Edward Epstein was arrested in New York City, New York,
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  Speaker 1: on July 6, 2019, and held in custody on sex
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  Speaker 1: trafficking charges following a series of investigations into his activities
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  Speaker 1: prior thereto. 2. Klayman is one of a number of
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  Speaker 1: underage victims of decedent's criminal actions. 3. Decedent, upon information
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  Speaker 1: and belief, conspired with multiple individuals, including attorneys and advisors,
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  Speaker 1: to fraudulently convey and hide assets from his victims, including claimant,
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  Speaker 1: by transferring assets into a newly titled trust through the
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  Speaker 1: provisions of a contemporaneously drafted last will and testament on
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  Speaker 1: or about August 8, 2019. 4. On November 21, 2019,
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  Speaker 1: Claimant filed a civil action in the United States District
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  Speaker 1: Court for the Southern District of New York, seeking damages
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  Speaker 1: against the estate. A true and correct copy of the complaint,
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  Speaker 1: so filed and indexed as case number 1-19-CV-10788 is attached
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  Speaker 1: here too as Exhibit A. 5. Pursuant to New York
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  Speaker 1: Child's Victims Act, among other bases, claimant's civil action in
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  Speaker 1: New York was commenced timely. 6. Descendant committed sexual abuse
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  Speaker 1: included repeated sexual assault and forcible rape upon claimant on
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  Speaker 1: multiple occasions. 7. The petition for probate of the decedent's
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  Speaker 1: estate lives personal and real property valued at $ 577, 672, 654. 8.
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  Speaker 1: Claimant's claim, as determined in a final judgment in the
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  Speaker 1: matter attached here to, as Exhibit A, including compensatory damages,
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  Speaker 1: punitive damages, costs, interest and fees, is rightfully entitled to payment,
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  Speaker 1: whether or not the claim has been reduced to judgment, liquidated, fixed,
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  Speaker 1: or matured, and has an equitable lien on all encumbered
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  Speaker 1: assets and property of the estate. This was signed by
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  Speaker 1: Mary Ann Meyer Wang. The next document we have is
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  Speaker 1: the complaint and the jury demand. Case number 19. civ. 10788,
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  Speaker 1: Teela Davies, Plaintiff, vs. Darren K. Indyke and Richard D.
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  Speaker 1: Kahn as executors of the estate of Jeffrey E. Epstein.
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  Speaker 1: Plaintiff Teela Davies, by and through her attorneys, Cuddy Hecker Wang, LLP,
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  Speaker 1: and Allred, Morocco, and Goldberg, for her complaint alleges as follows.
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  Speaker 1: Nature of action. 1. When plaintiff Teela Davies was just
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  Speaker 1: 17 years old, living on her own, and working full-time
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  Speaker 1: to support herself, Jeffrey Epstein preyed upon her, manipulated her
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  Speaker 1: to be completely dependent on him, and sexually abused her. 2.
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  Speaker 1: Epstein was presented to Teela as someone who had learned
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  Speaker 1: about her challenging circumstances and had the resources and interest
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  Speaker 1: to assist her, including by helping her to attend college
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  Speaker 1: and study abroad to see the world. Tila was introduced
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  Speaker 1: to Epstein by her sister, but Tila was unaware that
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  Speaker 1: Epstein had been manipulating and sexually abusing her sister as
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  Speaker 1: Epstein's total power and control over Tila's sister made it
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  Speaker 1: impossible for her to say anything about it. 3. During
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  Speaker 1: their early interactions, Epstein led Tila to believe that he
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  Speaker 1: would help her achieve her dream of becoming a translator,
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  Speaker 1: and he arranged for Tila to study abroad in Spain.
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  Speaker 1: Tila gave up her job, and her apartment in anticipation
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  Speaker 1: of this life-changing opportunity, leaving her completely dependent on Epstein
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  Speaker 1: and his continuing generosity. 4. Epstein exploited this power over
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  Speaker 1: 17-year-old Tila to sexually abuse her repeatedly. Ultimately, he raped
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  Speaker 1: her and sexually assaulted her frequently in a variety of
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  Speaker 1: places and settings, including by trafficking Tila to his homes
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  Speaker 1: in New York, New Mexico, Florida, the Virgin Islands, and France.
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  Speaker 1: He treated her like an object for his sexual gratification. 5.
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  Speaker 1: These assaults caused Tila to feel completely intimidated and fearful.
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  Speaker 1: She froze up and began to cry, able to think
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  Speaker 1: only about trying to survive. 6. Epstein continued to exert
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  Speaker 1: total control over Tila's life for two more years, trafficking
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  Speaker 1: her around the country and the world and sexually abusing
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  Speaker 1: her on frequent basis. During this time, Tila felt deep
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  Speaker 1: despair and isolation, and developed a severe and self-destructive eating disorder.
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  Speaker 1: Still within his power and control, Tila confided in Epstein
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  Speaker 1: about her disorder, mistakenly believing that she could trust him.
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  Speaker 1: Rather than help her, Epstein cast her out within hours
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  Speaker 1: of her admission, sending her back to a place where
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  Speaker 1: she no longer had a home, a job, or any
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  Speaker 1: resources of support. 7. Epstein's abuse destroyed Ms. Davies' life.
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  Speaker 1: She sank into alcoholism and other self-harm, unable to trust
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  Speaker 1: others but not understanding why. 8. At the same time,
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  Speaker 1: like so many childhood sex abuse victims, she did not
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  Speaker 1: comprehend how it had undone her or her life or
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  Speaker 1: how it had impacted her. 9. Now a working mother
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  Speaker 1: of three, Ms. Davies, is still just beginning to understand
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  Speaker 1: the depth of those injuries from the sexual assaults that
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  Speaker 1: Epstein inflicted on her beginning when she was 17. she
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  Speaker 1: still feels the toll of Epstein's abuse every day. She
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  Speaker 1: feels dysfunctional, on edge, overwhelmed, and like she is on
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  Speaker 1: the verge of a psychological breakdown. She has difficulty sleeping
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  Speaker 1: and often has flashbacks to Epstein's abuse. 10. Epstein died
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  Speaker 1: in August of 2019 before Ms. Davies or the countless
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  Speaker 1: other girls he preyed upon could obtain a modicum of justice. 11. Ms.
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  Speaker 1: Davies brings this action seeking, at last, some remedy for
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  Speaker 1: the egregious abuse that Epstein inflicted when she was still
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  Speaker 1: a child. Parties. 12. Plaintiff Teela Davies is an individual
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  Speaker 1: who resides in Arizona. 13. Defendants Darren K. Endyke and
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  Speaker 1: Richard D. Kahn are the executors of the estate of
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  Speaker 1: Jeffrey E. Epstein, the estate. As executors of the estate,
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  Speaker 1: defendants are liable for the acts and omissions of Epstein
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  Speaker 1: and his agents. For purposes of U.S. Code 28, Section 1332,
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  Speaker 1: defendants Indyk and Kahn are deemed to be citizens of
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  Speaker 1: the United States Virgin Islands, where Epstein was domiciled at
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  Speaker 1: the time of his death. Jurisdiction and Venue 14. This
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  Speaker 1: court has subject matter jurisdiction pursuant to U.S. Code 28,
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  Speaker 1: Section 1332, because the case is between citizens of different states,
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  Speaker 1: and the amount in controversy exceeds $ 75, 000. 15. Venue is
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  Speaker 1: proper in this district, pursuant to U.S. Code 28, Section 1391,
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  Speaker 1: being 2, because a substantial part of the events or
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  Speaker 1: omissions giving rise to the claim occurred in this district. 16.
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  Speaker 1: This court has personal jurisdiction over defendants, As executors of
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  Speaker 1: the estate, defendants Indyk and Kahn are subject to personal
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  Speaker 1: jurisdiction in this court because Epstein was subject to personal
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  Speaker 1: jurisdiction at the time of his death. Seventeen. This court
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  Speaker 1: had both specific and general personal jurisdiction over Epstein at
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  Speaker 1: the time of his death. Eighteen. Epstein resided in New
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  Speaker 1: York State a substantial portion of the time during the
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  Speaker 1: time period at issue in this lawsuit and through the
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  Speaker 1: time of his death. Nineteen. Epstein resided in the Metropolitan
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  Speaker 1: Correctional Center in New York County at the time of
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  Speaker 1: his death. 20. Epstein conducted substantial business operations in New York. 21.
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  Speaker 1: Epstein owned and or controlled numerous companies with principal places
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  Speaker 1: of business in New York. 22. Epstein owned substantial real
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  Speaker 1: property assets in New York, including townhouse located at 9th
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  Speaker 1: East 71st Street in Manhattan, which is valued at $ 55
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  Speaker 1: million or more. 23. New York was the epicenter of
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  Speaker 1: Epstein's criminal sex trafficking enterprise. For years, Epstein and his
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  Speaker 1: agents took action in New York in order to arrange
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  Speaker 1: for minor girls to be trafficked to his homes throughout
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  Speaker 1: the country, in order to perform sexual acts for him.
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  Speaker 1: Epstein's trafficking and abuse of Ms. Davies was part of
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  Speaker 1: that New York-based criminal enterprise. 24. From his Manhattan townhouse,
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  Speaker 1: Epstein directed a vast network of agents in recruiting minor
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  Speaker 1: girls to be brought to him for his sexual use. 25.
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  Speaker 1: Epstein sexually abused many minor girls, including Ms. Davies, in
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  Speaker 1: his Manhattan townhouse. 26. On many occasions, Epstein and his
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  Speaker 1: agents made phone calls from New York to schedule appointments
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  Speaker 1: for minor girls to come to Epstein's residences outside of
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  Speaker 1: New York in order to perform commercial sex acts for Epstein. 27.
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  Speaker 1: Upon information and belief, Epstein and or his agents were
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  Speaker 1: present in New York when they took various actions to
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  Speaker 1: facilitate the trafficking of Ms. Davies for the purpose of
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  Speaker 1: performing sexual acts for Epstein. Jury Demand 28. Plaintiff hereby
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  Speaker 1: demands a trial by jury on all of her claims
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  Speaker 1: in this action. Factual allegations. 29. When plaintiff Tila Davies
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  Speaker 1: was 17 years old, Jeffrey Epstein preyed upon her, manipulating
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  Speaker 1: her to be completely dependent on him and then sexually
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  Speaker 1: assaulting and raping her on numerous occasions. Epstein continued this
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  Speaker 1: pattern of manipulation and frequent sexual assault for years, leaving Ms.
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  Speaker 1: Davies with deep emotional wounds that she is still just
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  Speaker 1: beginning to grapple with. 30. By age 17, Tila had
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  Speaker 1: already lived through tremendously challenging circumstances. At 11 years old,
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  Speaker 1: she was homeless for a year, staying with various friends,
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  Speaker 1: and seeing her mother only about once a week. At 15,
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  Speaker 1: Tila began working in order to support herself. At 16,
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  Speaker 1: Tila's living situation was again unstable, and she moved to L.A.
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  Speaker 1: to live with her older sister. 31. Tila initially tried
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  Speaker 1: to go to school in Los Angeles, but was unable
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  Speaker 1: to continue due to the need to work full-time to
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  Speaker 1: support herself. Tila lived with her sister and worked at
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  Speaker 1: a hair salon, eventually getting her GED. By the time
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  Speaker 1: Tila met Epstein, she had already been living on her
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  Speaker 1: own and working full-time for a year and a half. 32.
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  Speaker 1: Tila's sister, who was five years older than her, had
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  Speaker 1: previously met Epstein and traveled with him. Tila's sister described Epstein,
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  Speaker 1: as her generous, wealthy person, and reported that he often
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  Speaker 1: helped her make it possible for people to attend college.
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  Speaker 1: Tila's sister reported that Epstein had heard Tila's story and
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  Speaker 1: had wanted to help. 33. Unbeknownst to Tila, Epstein had
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  Speaker 1: been manipulating and sexually abusing her sister. Tila had no
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  Speaker 1: idea that her sister had been involved in any type
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  Speaker 1: of sexual interactions with Epstein. Epstein's power and control of
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  Speaker 1: Tila's sister made it impossible for her to say anything. 34.
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  Speaker 1: Tila met Epstein for the first time in 2002. She
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  Speaker 1: was 17 years old. Epstein was visiting Los Angeles, and
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  Speaker 1: Tila drove with her sister to meet him at the
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  Speaker 1: Hotel Bel Air. 35. During that first meeting, Epstein lay
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  Speaker 1: on a bed in his spacious hotel suite, fully clothed.
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  Speaker 1: He asked Tila's sister to massage his feet, then encouraged
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  Speaker 1: Tila to join her. Afterwards, Epstein took them shopping and
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  Speaker 1: insisted on buying several items for Tila. 36. After that meeting,
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  Speaker 1: Epstein kept in touch with Tila through frequent phone calls.
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  Speaker 1: Epstein veered the conversation toward Tila's career goals, how Epstein
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  Speaker 1: could help her achieve them. He purported to want to
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  Speaker 1: help her and guide her to a better life. 37.
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  Speaker 1: Epstein offered to send Tila to school to learn hairdressing,
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  Speaker 1: but Tila made clear this was not what she wanted
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  Speaker 1: to do in the long term. Tila explained that she
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  Speaker 1: had a passion for languages and for people and that
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  Speaker 1: her dream was to be a translator. 38. Epstein claimed
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  Speaker 1: that he wanted to help Tila study to become a translator.
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  Speaker 1: He suggested that he would pay for Tila to study
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  Speaker 1: in Spain for a semester. Soon after, Epstein helped her
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  Speaker 1: to obtain a letter of recommendation from high school and
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  Speaker 1: helped her get accepted to study at the University of Madrid. 39.
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  Speaker 1: Tila was over the moon. feeling her dreams were coming true.
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  Speaker 1: Epstein made sure she felt that it was all his doing. 40.
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  Speaker 1: Tila prepared for this exciting opportunity to study abroad and
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  Speaker 1: pursue her dream career. She gave notice at her hairdressing
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  Speaker 1: job and gave up her apartment in Los Angeles, preparing
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  Speaker 1: to move to Spain. 41. Before Tila left for her
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  Speaker 1: school program, however, Epstein began what would become a long
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  Speaker 1: pattern of using her as a sexual object. 42. In
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  Speaker 1: approximately the summer of 2002, Epstein flew Tila and her
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  Speaker 1: sister to his ranch in New Mexico. Tila felt no
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  Speaker 1: reason to be wary of Epstein. He had been kind
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  Speaker 1: in their first meeting and had acted with generosity towards her. 43.
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  Speaker 1: When Tila got to Epstein's ranch, Epstein's close associate Ghislaine
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  Speaker 1: Maxwell and Sarah Kellen were there. Maxwell asked Tila questions
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  Speaker 1: about herself and took her horseback riding. Kellen invited Tila
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  Speaker 1: to go swimming. 44. After Tila swam, Epstein asked her
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  Speaker 1: to go into the massage room along with Kellen. Kellen
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  Speaker 1: began massaging Epstein and Tila innocently joined in as she
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  Speaker 1: had when her sister massaged Epstein's feet for the first time. 45.
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  Speaker 1: At that point, Epstein began fondling Kellen and took off
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  Speaker 1: Kellen's shirt. Tila became very uncomfortable as the massage had
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  Speaker 1: quickly and unexpectedly turned into a sexual encounter. Epstein reached
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  Speaker 1: inside Tila's bathing suit and fondled her genitals. Tila began crying,
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  Speaker 1: but Epstein continued to grope her as he masturbated to completion. 46.
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  Speaker 1: Tila felt extremely vulnerable. Epstein had arranged the circumstances to
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  Speaker 1: ensure that Tila was completely at his mercy. Tila had
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  Speaker 1: given up her job and her apartment in order to
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  Speaker 1: travel to Spain at Epstein's expense. If Epstein decided to
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  Speaker 1: rethink his generosity at any point, Tila would have had nothing,
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  Speaker 1: and would have been left homeless and jobless once again
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  Speaker 1: after being brought so close to her dream. Even though
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  Speaker 1: Epstein had preyed upon her and sexually assaulted her, Tila
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  Speaker 1: understood she had no choice but to submit to him.
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  Speaker 1: His power over her was all-encompassing. 47. Epstein viciously exploited
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  Speaker 1: this power dynamic. In the summer and fall of 2002,
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  Speaker 1: he flew 17-year-old Tila to his home in New York, Florida,
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  Speaker 1: and then the U.S. Virgin Islands, sexually assaulting her in
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  Speaker 1: each of those locations. 48. In or around December 2002,
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  Speaker 1: Epstein flew Tila to stay at his townhouse located at
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  Speaker 1: 9 East 71st Street in Manhattan. While they were in
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  Speaker 1: the dining room of the townhouse, Epstein, without warning, stuck
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  Speaker 1: his hand down Tila's pants and fondled her genitals. It
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  Speaker 1: was as if she were his toy. 49. In or
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  Speaker 1: around the same month, at Epstein's home in Florida, Epstein
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  Speaker 1: crept into Tila's bedroom while she was sleeping and raped her. 50.
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  Speaker 1: Also around that same month, at the private island Epstein
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  Speaker 1: owned in the Virgin Islands, Epstein ordered Tila to massage him,
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  Speaker 1: then proceeded to sexually assault her in the massage room. 51.
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  Speaker 1: Tila finally traveled to Spain to study in or around
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  Speaker 1: the end of 2002. 52. In early 2003, when Tila
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  Speaker 1: was still 17 years old, Epstein flew her from Madrid
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  Speaker 1: to Paris. At his home in Paris, Epstein again crept
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  Speaker 1: into Tila's bedroom while she slept and raped her. 53.
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  Speaker 1: When Epstein inflicted these sexual assaults on Tila, she felt
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  Speaker 1: completely intimidated and fearful. All she could think about was
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  Speaker 1: trying to survive. Her body froze up and she began crying. 54.
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  Speaker 1: After Tila's semester in Madrid, she had no home and
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  Speaker 1: no job. Instead, Epstein brought her to live a nomadic
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  Speaker 1: lifestyle in his close orbit. Tila traveled around the country
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  Speaker 1: with Epstein and his entourage, which generally included Maxwell, Kellen,
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  Speaker 1: and others. Virtually every few days, Epstein would bring Tila
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  Speaker 1: to a different home of his, including the Manhattan townhouse,
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  Speaker 1: and throughout the country, where he continued to sexually assault
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  Speaker 1: her on a frequent basis. Epstein regularly used his private
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  Speaker 1: planes to traffic Tila into various locations for his sexual
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  Speaker 1: abuse of her. 55. Epstein had power over every aspect
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  Speaker 1: of Tila's life, and he had groomed Tila to be
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  Speaker 1: completely dependent on him and completely submissive to him. Epstein
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  Speaker 1: treated Tila as a sexual object, using her body for
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  Speaker 1: his sexual gratification, frequently and at his whim. 56. Eventually,
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  Speaker 1: by approximately 2004, Epstein arranged for Tila to live at
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  Speaker 1: an apartment at 301 East 66th Street in Manhattan, just
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  Speaker 1: blocks from his townhouse when she was in New York. 57.
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  Speaker 1: This pattern of Epstein exercising total control over Tila's life
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  Speaker 1: and using her as a sexual object whenever he desired
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  Speaker 1: continued throughout 2003 and 2004. Epstein arranged for Tila to
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  Speaker 1: study abroad two more times, apparently when he grew bored
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  Speaker 1: with having her around. Each time, Tila lived in this
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  Speaker 1: nomadic orbit with Epstein, both before and after traveling to
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  Speaker 1: attend school. 58. Epstein also tried to introduce Tila to
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  Speaker 1: his friends and essentially offer her as a sexual object
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  Speaker 1: to them. In one instance, Epstein had Tila spend time
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  Speaker 1: with a well-known Hollywood producer, who then demanded and attempted
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  Speaker 1: to engage in abusive sexual behavior. Tila barely escaped. 59.
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  Speaker 1: By 2004, Tila felt deep despair and isolation. There was
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  Speaker 1: no one she could talk to about what Epstein was
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  Speaker 1: doing to her. Instead, Epstein had ensured that she thought
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  Speaker 1: He was the only person in her life whom she
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  Speaker 1: could trust. 60. Tila developed a severe eating disorder for
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  Speaker 1: the first time in or around 2004. After she had
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  Speaker 1: struggled with the disorder for six months or a year,
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  Speaker 1: it became too much to bear. She confided in Epstein
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  Speaker 1: about her eating disorder, still manipulated into thinking he was
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  Speaker 1: someone she could trust. 61. Instead, from the moment Epstein
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  Speaker 1: learned of Tila's self-destructive behavior, he immediately cast her out.
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  Speaker 1: Literally within hours of Tila anxiously confessing to Epstein that
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  Speaker 1: she did not know why, but had a compulsive need
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  Speaker 1: to binge and purge, he threw her out. He instructed
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  Speaker 1: her to pack up her belongings and arrange for her
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  Speaker 1: to be flown to Arizona. 62. But there was nothing
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  Speaker 1: left in Arizona. She still had no idea what had
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  Speaker 1: happened to her and felt it was all her fault. 63.
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  Speaker 1: Epstein's abuse destroyed Tila's life. After being cast out by him,
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  Speaker 1: after two years of a lavish, if abusive, lifestyle, she
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  Speaker 1: sank into alcoholism and other self-harm, unable to trust others
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  Speaker 1: but not understanding why. 64. Ms. Davies is now a
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  Speaker 1: working mother raising three children. She's still struggling to put
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  Speaker 1: her life back together. 65. Ms. Davies is still in
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  Speaker 1: the nascent stages of understanding the deep and lasting injuries
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  Speaker 1: that Epstein's pattern of abuse has caused her, but she
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  Speaker 1: feels the effects every day. She feels dysfunctional, on edge,
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  Speaker 1: and constantly overwhelmed. She has difficulty sleeping. She often has
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  Speaker 1: flashbacks to Epstein's sexual assaults. She feels like she's on
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  Speaker 1: the verge of a psychological breakdown. 66. This action is
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  Speaker 1: timely under the law of each jurisdiction whose law might
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  Speaker 1: be determined to govern Ms. Davies' claims or aspects thereof,
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  Speaker 1: including without limitation New York, New Mexico, Florida, and the
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  Speaker 1: Virgin Islands. 67. Ms. Davies still has not disclosed her
• 22:12
  Speaker 1: abuse to a licensed medical or mental health care provider
• 22:16
  Speaker 1: in the context of receiving health care from the provider. 68. Ms.
• 22:21
  Speaker 1: Davies is still just beginning to process and understand the
• 22:24
  Speaker 1: full extent of the injuries that Epstein's abuse has caused
• 22:28
  Speaker 1: her and and the connection between Epstein's abuse and the
• 22:31
  Speaker 1: emotional and psychological injuries she had experienced. 69. This action
• 22:38
  Speaker 1: is timely under New York law because it falls within
• 22:41
  Speaker 1: New York CPLR 214-G and is brought during the one-year
• 22:47
  Speaker 1: time period set forth in that action. The claims brought
• 22:52
  Speaker 1: herein allege intentional and negligent acts and or omissions for physical, psychological,
• 22:58
  Speaker 1: and other injuries suffered as a result of conduct that
• 23:01
  Speaker 1: would constitute sexual offenses as defined in Article 130 of
• 23:06
  Speaker 1: the New York Penal Law, and such acts and or
• 23:09
  Speaker 1: omissions were committed against Ms. Davies when she was less
• 23:12
  Speaker 1: than 18 years of age. 70. Epstein's conduct constitutes childhood
• 23:18
  Speaker 1: sexual abuse within the meaning of New Mexico Statute 37-1-30,
• 23:22
  Speaker 1: an abuse with the meaning of A Florida Statute, Section 95.11.7.
• 23:31
  Speaker 1: First Cause of Action, Battery. 71. Plaintiff hereby incorporates each
• 23:36
  Speaker 1: of the foregoing paragraphs as if fully set forth herein. 72.
• 23:41
  Speaker 1: In committing the acts described above, Epstein intentionally subjected plaintiff
• 23:46
  Speaker 1: to bodily contact that was offensive in nature. 73. Epstein
• 23:52
  Speaker 1: intentionally touched plaintiff in a rude, insolent, or angry manner. 74.
• 23:57
  Speaker 1: As a result of Epstein's actions, plaintiff suffered damages in
• 24:01
  Speaker 1: an amount to be determined at trial. Second cause of action. Assault. 75.
• 24:09
  Speaker 1: Plaintiff hereby incorporates each of the foregoing paragraphs as if
• 24:12
  Speaker 1: fully set forth herein. 76. In committing the acts described above,
• 24:18
  Speaker 1: Epstein engaged in physical conduct that placed plaintiff in eminent
• 24:23
  Speaker 1: apprehension that he would harm her. 77. As a result
• 24:27
  Speaker 1: of Epstein's actions, plaintiff suffered damages in an amount to
• 24:30
  Speaker 1: be determined at trial. Third cause of action, intentional infliction
• 24:35
  Speaker 1: of emotional distress. 78. Plaintiff hereby incorporates each of the
• 24:41
  Speaker 1: foregoing paragraphs as it fully set forth herein. 79. In
• 24:45
  Speaker 1: committing the acts described above, Epstein engaged in extreme and
• 24:49
  Speaker 1: outrageous conduct. 80. In doing so, Epstein acted with the
• 24:53
  Speaker 1: intent to cause and or disregard of a substantial likelihood
• 24:58
  Speaker 1: of causing plaintiff to suffer severe emotional distress. 81. As
• 25:03
  Speaker 1: a direct result of Epstein's actions, plaintiff suffered severe emotional distress. 82.
• 25:09
  Speaker 1: As a result of Epstein's actions, plaintiff suffered damages in
• 25:13
  Speaker 1: an amount to be determined at trial. Wherefore, plaintiff respectfully
• 25:17
  Speaker 1: requests that judgment be entered against defendants as follows. A.
• 25:22
  Speaker 1: Awarding compensatory damages for all physical injuries, emotional distress, psychological harm, anxiety, humiliation,
• 25:29
  Speaker 1: physical and emotional pain and suffering, family and social disruption,
• 25:34
  Speaker 1: and other harm in the amount to be determined at trial. B.
• 25:38
  Speaker 1: Awarding punitive damages in an amount to be determined at trial. C.
• 25:43
  Speaker 1: Awarding attorney's fees and costs pursuant to any applicable statute
• 25:48
  Speaker 1: or law. D. Awarding pre- and post-judgment interest on all
• 25:52
  Speaker 1: such damages, fees, and or costs. E. Attaching all of
• 25:56
  Speaker 1: defendant's real property and other assets located in the state
• 26:00
  Speaker 1: of New York pursuant to New York CPLR 6201 and
• 26:04
  Speaker 1: Federal Rule of Civil Procedure 64 and F. Awarding such
• 26:09
  Speaker 1: other and further relief as this court may deem just
• 26:13
  Speaker 1: and proper. This document was signed by Marianne Meyer-Wang. So
• 26:19
  Speaker 1: instead of the BS, right? So instead of all of
• 26:22
  Speaker 1: the nonsense and the innuendo, we're going to go right
• 26:25
  Speaker 1: to the source. And we're going to continue going through
• 26:28
  Speaker 1: these court documents so that all of you out there
• 26:31
  Speaker 1: are able to wade through the bullshit and get to
• 26:34
  Speaker 1: what's really real. All right, folks, that's going to do
• 26:36
  Speaker 1: it for this one. All of the information that goes
• 26:38
  Speaker 1: with this episode can be found in the description box.