Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
On today's episode, we're going to continue exploring the Jeffrey
Epstein core documents, and this time we're taking a look
at the lawsuit that Epstein survivor Tila Davies filed against
Jeffrey Epstein and the estate case Number st Dash nineteen
Dash pb Dash eighty Action for Probate in the matter
of the Estate of Jeffrey E. Epstein. Claim the undersigned
Marianne Meier Wang Esquire of Cutty Hecker Wang LLP, Richard P.
Bourne Vanik Esquire and Dolred Morocco and Goldberg hereby present
and file this claim on behalf of Tila Davies, the
claimant for unliquidated and unsecured damages from the estate of
Jeffrey e. Epstein, the estate in the above captioned batter
now pending before court and in support thereof State. As follows. One,
Jeffrey Edward Epstein was arrested in New York City, New
York on July six, twenty nineteen, and held in custody
on sex trafficking charges following a series of investigations into
his activities prior there too. Number two. Claimant is one
of a number of underage victims of decedent's criminal actions. Three. Decedent,
upon information and belief, conspired with multiple individuals, including attorneys
and advisors, to fraudently convey and hide assets from his victims,
including claimant, by transferring assets into a newly titled trust
through the provisions of a contemporaneously drafted last will and
testament honor about August eighth, twenty nineteen four. On November
twenty one, twenty nineteen, claimant filed a civil action in
the United States District Court for the Southern District of
New York seeking damage is against the estate. A true
and correct copy of the complaint soul filed and indexed
as case number one nineteen CV DASH one zero seven
eight eight, is attached Heer two as Exhibit A five.
Pursuant to New York Child's Victims Act, among other bases,
claimants civil action in New York was commenced timely. Six
Descedent committed sexual abuse, included repeated sexual assault and forcible
rape upon claimant on multiple occasions. Seven. The petition for
probate of the dessendents a state lists personal and real
property valued at five hundred and seventy seven million, six
hundred and seventy two thousand and six hundred and fifty
four dollars eight. Claimant's claim, as determined in a final
judgment in the matter attached heer two as Exhibit A,
including compensentory damages, punitive damages, costs, interests in fees, is
rightfully entitled to payment whether or not the claim has
been reduced to judgment, liquidated, fixed, or matured, and as
an equitable lean on all encumbered assets and property of
the estate. This was signed by Mary Anne Meyer Wang.
The next document we have is the complaint and the
jury demand Case number nineteen SIV DOT one zero seven
eight eight Tila Davies plaintiff vers Darren k Endyke and
Richard D. Kahn as executors of the estate of Jeffrey
e Epstein. Plaintiff Tila Davies buy and, through her attorneys
Cutty Hecker, Wang LLP and Allred, Morocco and Goldberg, for
her complaint alleges as follows nature of action one. When
plaintiff Tila Davies was just seventeen years old, living on
her own and working full time to support herself, Jeffrey
Epstein prayed upon her, manipulated her to be completely dependent
on him, and sexually abused her. Two. Epstein was presented
to Tela as someone who had learned about her challenging
circumstances and had the resources and interest to his sister,
including by helping her to attend college and study abroad
to see the world. Telo was introduced to Ebstein by
her sister, but Tila was unaware that Epstein had been
manipulating and sexually abusing her sister, as Epstein's total power
in control over Tila's sister made it impossible for her
to say anything about it. Three. During their early interactions,
Epstein led Tila to believe that he would help her
achieve her dream of becoming a translator, and he arranged
for Tila to study abroad in Spain. Tila gave up
her job and her apartment in anticipation of this life
changing opportunity, leaving her completely dependent on Epstein and his
continuing generosity. Four. Epstein exploited this power over seventeen Tila
to sexually abuse her repeatedly. Ultimately, he raped her and
sexually assaulted her frequently in a variety of places and settings,
including by trafficking Tila to his homes in New York,
New Mexico, Florida, the Virgin Islands, and France. He treated
her like an object for his sexual gratification. Five. These
assaults caused Tila to feel completely intimidated and fearful. She
froze up and began to cry, able to think only
about trying to survive. Six. Epstein continued to exert total
control over Tila's life for two more years, trafficking her
around the country and the world, and sexually abusing her
on frequent basis. During this time, Tila felt deep despair
and isolation and developed a severe and self destructive eating disorder.
Still within his power and control, Tila confided in Epstein
about her disorder, mistakingly believing that she could trust him
rather than help her. Epstein cast her out out within
hours of her admission, sending her back to a place
where she no longer had a home, a job, or
any resources of support. Seven. Epstein's abuse destroyed Miss Davies's life.
She sank into alcoholism and other self harm, unable to
trust others but not understanding why. Eight At the same time,
like so many childhood sex abuse victims, she did not
comprehend how it had undone her or her life, or
how it had impacted her. Nine. Now a working mother
of three, Miss Davies is still just beginning to understand
the depth of those injuries from the sexual assaults that
Epstein inflicted on her, beginning when she was seventeen. She
still feels the toll of Epstein's abuse every day. She
feels dysfunctional, on edge, overwhelmed, and like she is on
the verge of a psychological breakdown. She has difficulty sleeping
and often has flashbacks to Epstein's abuse. Ten Epstein died
August of twenty nineteen before Miss Davies or the countless
other girls he prayed upon could obtain a modicum of justice.
Number eleven. Miss Davies brings this action, seeking at last
some remedy for the egregious abuse that Epstein inflicted when
she was still a child. Parties twelve. Plaintiff Tila Davies
is an individual who resides in Arizona. Thirteen Defendants Darren
k Endyke and Richard D. Con are the executors of
the estate of Jeffrey E. Epstein. The estate as executors
of the estate. Defendants are liable for the acts and
omissions of Epstein and his agents for purposes of US CO.
Twenty eight, Section thirteen thirty two. Defendants in Dyke and
Khan are deemed to be citizens of the United States
Virgin Islands, where Epstein was domiciled at the time of
his death. Jurisdiction and venue fourteen. This court has subject
matter jurisdiction pursuant to US Code twenty eight, Section thirteen
thirty two because the case is between citizens of different
states and the amountain controversy exceeds seventy five thousand dollars. Fifteen,
Venue is proper in this district pursuant to US Code
twenty eight Section thirteen ninety one b in two because
the substantial part of the events or omissions giving rise
to the claim occurred in this district. Sixteen, This Court
has personal jurisdiction over defendants as executors of the estate.
Defendants Indike and Khan are subject to personal jurisdiction in
this court because Epstein was subject to personal jurisdiction at
the time of his death. Seventeen, this court had both
specific and general personal jurisdiction over Epstein at the time
of his death eighteen. Epstein resided in New York State
a substantial portion of the time during the time period
at issue in this lawsuit and through the time of
his death nineteen. Epstein resided in the Metropolitan Correctional Center
in New York County. At the time of his death
twenty Epstein conducted substantial business operations in New York. Twenty one.
Epstein owned and or controlled numerous companies with principal places
of business in New York. Twenty two. Epstein owned substantial
real property assets in New York, including townhouse located at
ninth East seventy first Street in Manhattan, which is valued
at fifty five million or more. Twenty three. New York
was the epicenter of Epstein's criminal sex trafficking enterprise. For years,
Abstein and his agents took action in New York in
order to arrange for minor girls to be trafficked to
his homes throughout the country in order to perform sexual
lax forum. Epstein's trafficking and abuse of Miss Davies was
part of that New York based criminal enterprise. Twenty four.
From his Manhattan townhouse, Epstein directed a vast network of
agents in recruiting minor girls to be brought to him
for his sexual use. Twenty five. Epstein sexually abused many
minor girls, including Miss Davies, in his Manhattan town house.
Twenty six. On many occasions, Epstein and his agents made
phone calls from New York to schedule appointments for minor
girls to come to Epstein's residences outside of New York
in order to perform commercial sex acts for Epstein. Twenty seven.
Upon information and belief, Epstein and or his agents were
present in New York when they took various actions to
facilitate the trafficking of Miss Davies for the purpose of
performing sexual acts for Epstein. Jury Demand twenty eight. Plaintiff
hereby demands a trial by jury on oli her claims
in this action. Factual Allegations twenty nine. When Plaintiff Tila
Davies was seventeen years old, Jeffrey eppste Dean preyed upon her,
manipulating her to be completely dependent on him, and then
sexually assaulting and raping her on numerous occasions. Epstein continued
this pattern of manipulation and frequent sexual assault for years,
leaving Miss Davies with deep emotional wounds that she is
still just beginning to grapple with thirty. By age seventeen,
Tila had already lived through tremendously challenging circumstances. At eleven
years old, she was homeless for a year, staying with
various friends and seeing her mother only about once a week.
At fifteen, Tela began working in order to support herself.
At sixteen, Tila's living situation was again unstable, and she
moved to La to live with her older sister. Thirty one,
Tila initially tried to go to school in Los Angeles,
but was unable to continue due to the need to
work full time to support herself. Tela lived with her
sister and worked out a hair salon, eventually getting her ged.
By the time Tela met Epstein, she had already been
living on her own and working full time for a
year and a half. Thirty two, Teala's sister, who was
five years older than her, had previously met Epstein and
traveled with him. Teala's sister described Epstein as her generous,
wealthy person, and reported that he often helped her make
it possible for people to attend college. Teala's sister reported
that Epstein had heard Telas story and had wanted to help.
Thirty three. Unbeknownst to Tela, Ebstein had been manipulating and
sexually abusing her sister. Tela had no idea that her
sister had been involved in any type of sexual interactions
with Epstein. Epstein's power and control of Tela's sister made
it impossible for her to say anything. Thirty four. Tela
met Epstein for the first time in two thousand and two.
She was seventeen years old. Epstein was visiting Los Angeles,
and Tela drove with her sister to meet him at
the Hotel Bell thirty five. During that first meeting, Epstein
lay on a bed in his spacious hotel suite. Fully clothed.
He asked Tila's sister to massage his feet, then encouraged
Tila to join her. Afterwards, Epstein took them shopping and
insisted on buying several items for Tila. Thirty six. After
that meeting, Epstein kept in touch with Tila through frequent
phone calls. Epstein veered the conversation toward Tila's career goals.
How Epstein could help her achieve them. He purported to
want to help her and guide her to a better life.
Thirty seven, Epstein offered to send Tila to school to
learn hairdressing, but Tila made clear this was not what
she wanted to do in the long term. Tela explained
that she had a passion for languages and for people,
and that her dream was to be a translator. Thirty eight,
Epstein claimed that he wanted to help Tela study to
become a translator. He suggested that he would pay for
Tila to study in Spain for a semester. Soon after,
Epstein helped her to obtain a letter of recommendation from
high school and helped her get accepted to study at
the University of Madrid. Thirty nine. Tila was over the moon,
feeling her dreams were coming true. Epstein made sure she
felt that it was all his doing. Forty Tela prepared
for this exciting opportunity to study abroad and pursue her
dream career. She gave notice at her hair dressing job
and gave up her apartment in Los Angeles, preparing to
move to Spain. Forty one before Tila left for her
school program, However, Epstein began what would become a long
pattern of using her as his sexual object. Forty two
and approximately the summer of two thousand and two, Epstein
flew Tila and her sister to his ranch in New Mexico.
Tila felt no reason to be wary of Epstein. He
had been kind in their first meeting and had acted
with generosity towards her. Forty three. When Tila got to
Ebstein's ranch, Epstein's close associate Glen Maxwell and Sarah Kellen
were there. Maxwell asked Tila questions about herself and took
her horse back riding. Kellen invited Tela to go swimming.
Forty four, After Tela swam, Epstein asked her to go
into the massage room along with Kellen. Kellen began massaging Epstein,
and Tila innocently joined in, as she had when her
sister massaged Epstein's feet for the first time forty five.
At that point, Epstein began fondling Kellen and took off
Kellen's shirt. Tila became very uncomfortable as the massage had
quickly and unexpectedly turned into a sexual encounter. Epstein reached
inside Tela's bathing suit and fondled her genitals. Tila began crying,
but Epstein continued to grope her as he masturbated to
completion forty six. Tila felt extremely vulnerable. Epstein had arranged
the circumstances to ensure that Tela was completely at his mercy.
Tela had given up her job and her apartment in
order to travel to Spain at Epstein's expense. If Epstein
decided to rethink his generosity at any point, Tila would
have had nothing and would have been left homeless and
jobless once again. After being brought so close to her dream,
Even though Epstein had preyed upon her and sexually assaulted her,
Tila understood she had no choice but to submit to him.
His power over her was all encompassing forty seven. Epstein
viciously exploited this power dynamic. In the summer and fall
of two thousand and two. He flew seventeen year old
Tila to his home in New York, Florida, and then
the US Virgin Islands, sexually assaulting her in each of
those locations. Forty eight. In or around December two thousand
and two, Epstein flew Tila to stay at his townhouse
located at nineties seventy first Street in Manhattan. While they
were in the dining room of the townhouse, Epstein, without warning,
stuck his hand down to Tila's pants and fondled her genitals.
It was as if she were his toy. Forty nine.
In Or around the same month, at Epstein's home in Florida,
Epstein crept into Tila's bedroom while she was sleeping and
raped her fifty Also around that same month, at the
private island Epstein owned in the Virgin Islands, Epstein ordered
Tila to massage them, then proceeded to sexually assault her
in the massage room. Fifty one. Tila finally traveled to
Spain to study in Or around the end of two
thousand and two. Fifty two. In early two thousand and three,
when Tila was still seventeen years old, Epstein flew her
from Madrid to Paris. At his home in Paris, Epstein
again crept into Tila's bedroom while she slept and raped
her fifty three. When Epstein inflicted these sexual assaults on Tila,
she felt completely intimidated and fearful. All she could think
about was trying to survive her body froze up and
she began crying. Four after Tela's semester in Madrid, she
had no home and no job. Instead, Epstein brought her
to live a nomadic lifestyle in his close orbit. Tila
traveled around the country with Epstein and his entourage, which
generally included Maxwell, Kellen and others. Virtually every few days,
Epstein would bring Tila to a different home of his,
including the Manhattan townhouse and throughout the country, where he
continued to sexually assault her on a frequent basis. Epstein
regularly used his private planes to traffic Tela into various
locations for his sexual abuse of her. Fifty five. Epstein
had power over every aspect of Tila's life, and he
had groom Tela to be completely dependent on him and
completely submissive to him. Epstein treated Tila as a sexual object,
using her body for his sexual gratification frequently and at
his whim fifty six. Eventually, by approximately two thousand and four,
Epstein arranged for Tila to live at an apartment at
three oh one East sixty sixth Street in Manhattan, just
blocks from his townhouse. When she was in New York
fifty seven. This pattern of Epstein, exercising total control over
Tila's life and using her as a sexual object whenever
he desired. Continued throughout two thousand and three and two
thousand and four. Epstein arranged for Tila to study abroad
two more times, apparently when he grew bored with having
her around each time. Tela lived in this nomadic orbit
with Epstein both before and after traveling to attend school.
Fifty eight. Epstein also tried to introduce Tela to his
friends and essentially offer her as a sexual object to them.
In one instance, Epstein had Tela spend time with a
well known Hollywood producer, who then demanded and attempted to
engage in abusive sexual behavior. Tila barely escaped fifty nine.
By two thousand and four, Tila fell 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. Sixty Tila developed a severe eating
disorder for the first time in or around two thousand
and four. After she had struggled with the disorder for
six months or a year, it became too much to bear.
She confided in Epstein about her eating disorder, still manipulated
into thinking he was someone she could trust sixty one. Instead,
from the moment Epstein learned of Tila's self destructive behavior,
he immediately cast her out. Literally within hours of Tila
anxiously confessing to Ebstein 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 arrange for her to be flown to Arizona
sixty two, but there was nothing left in Arizona. Still
had no idea what had happened to her and felt
it was all her fault. Sixty three. Epstein's abuse destroyed
Tila'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. Sixty four. Miss Davies is now a
working mother raising three children. She's still struggling to put
her life back together. Sixty five. Miss Davies is still
in the nascent stages of understanding the deep and lasting
injuries at 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's on
the verge of a psychological breakdown. Sixty six. This action
is timely under the law of each jurisdiction whose law
might be determined to govern Miss Davies's claims or aspects thereof,
including without limitation, New York, New Mexico, Florida, and the
Virgin Islands. Sixty seven. Miss Davies still has not disclosed
her abuse to a licensed medical or mental health care
provider in the context of receiving healthcare from the provider.
Sixty eight. Miss Davies is still just beginning to process
and understand the full extent of the injuries that Epstein's
abuse has caused her, and the connection between Epstein's abuse
and the emotional and psychological injuries she had experienced. Sixty nine.
This action is timely under New York law because it
falls within New York cp LR two fourteen G and
is brought during the one year time period set forth
in that action. The claims brought herein allege intentional and
negligent acts and or emissions for physical, psychological, and other
injuries suffered as a result of conduct that would constitute
sexual offenses as defined an Article one point thirty of
the New York Penal Law, and such acts and or
emissions were committed against Miss Davies when she was less
than eighteen years of age seventy Epstein's conduct constitutes childhood
sexual abuse within the meaning of New Mexico Statute thirty
seven Dash one, Dash thirty and abuse with the meaning
of Florida Statute Section ninety five Dot eleven seven. First
cause of action battery seventy one. Plaintiff hereby incorporates each
of the foregoing paragraphs as if fully set forth here
in seventy two. In committing the acts described above, Epstein
intentionally subjected plaintiff to bodily contact that was offensive in nature.
Seventy three. Epstein intentionally touched plaintiff in a rude, insolent,
or angry manner. Seventy four. As a result of Epstein's actions,
plaintiff suffered damages in an amount to be determined at trial.
Second cause of action assault seventy five Plaintiff hereby incorporates
each of the fore going paragraphs as if fully set
forth herein seventy six. In committing the acts described above,
Epstein engaged in physical conduct that plays plaintiff in eminent
apprehension that he would harmur seventy seven. As a result
of Epstein's actions, Plaintiff suffered damages in an amount to
be determined at trial. Third cause of action intentional infliction
of emotional distress seventy eight. Plaintiff hereby incorporates each of
the fore going paragraphs as if fully set forth here
in seventy nine. In committing the acts described above, Epstein
engaged in extreme and outrageous conduct eighty 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 eighty one. As a direct result of Epstein's actions,
Plaintiff suffered severe emotional distress. Eighty two. 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 the amount to be determined at trial.
B Awarding punitive damages in an amount to be determined
at trial. C Awarding attorney's fees and cost pursue it
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 Defendant's real property and other assets
located in the State of New York pursu into New
York CPLR. Sixty two oh one and Federal Rule of
Civil Procedures sixty four, and def Awarding such other and
further relief as this Court may deem just and proper.
This document was signed by Mary Ann Mera Wang. So
instead of the BS, right, So, instead of all of
the nonsense and the innuendo, we're gonna go right to
the source and we're gonna continue going through these core
documents so that all of you out there are able
to wade through the bullshit and get to what's really real.
All right, folks, that's gonna do it for this one.
All of the information that goes with this episode can
be found in the description box.