1 00:00:00,240 --> 00:00:04,120 Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles. 2 00:00:04,280 --> 00:00:08,000 On today's episode, we're going to continue exploring the Jeffrey 3 00:00:08,039 --> 00:00:12,000 Epstein core documents, and this time we're taking a look 4 00:00:12,320 --> 00:00:16,960 at the lawsuit that Epstein survivor Tila Davies filed against 5 00:00:17,120 --> 00:00:23,280 Jeffrey Epstein and the estate case Number st Dash nineteen 6 00:00:23,760 --> 00:00:28,559 Dash pb Dash eighty Action for Probate in the matter 7 00:00:28,640 --> 00:00:34,600 of the Estate of Jeffrey E. Epstein. Claim the undersigned 8 00:00:34,759 --> 00:00:40,399 Marianne Meier Wang Esquire of Cutty Hecker Wang LLP, Richard P. 9 00:00:40,560 --> 00:00:45,840 Bourne Vanik Esquire and Dolred Morocco and Goldberg hereby present 10 00:00:46,000 --> 00:00:49,159 and file this claim on behalf of Tila Davies, the 11 00:00:49,240 --> 00:00:53,960 claimant for unliquidated and unsecured damages from the estate of 12 00:00:54,039 --> 00:00:57,799 Jeffrey e. Epstein, the estate in the above captioned batter 13 00:00:58,359 --> 00:01:04,359 now pending before court and in support thereof State. As follows. One, 14 00:01:04,799 --> 00:01:08,159 Jeffrey Edward Epstein was arrested in New York City, New 15 00:01:08,280 --> 00:01:12,280 York on July six, twenty nineteen, and held in custody 16 00:01:12,319 --> 00:01:16,560 on sex trafficking charges following a series of investigations into 17 00:01:16,560 --> 00:01:21,200 his activities prior there too. Number two. Claimant is one 18 00:01:21,200 --> 00:01:26,920 of a number of underage victims of decedent's criminal actions. Three. Decedent, 19 00:01:27,159 --> 00:01:32,319 upon information and belief, conspired with multiple individuals, including attorneys 20 00:01:32,359 --> 00:01:36,840 and advisors, to fraudently convey and hide assets from his victims, 21 00:01:37,000 --> 00:01:41,040 including claimant, by transferring assets into a newly titled trust 22 00:01:41,319 --> 00:01:45,120 through the provisions of a contemporaneously drafted last will and 23 00:01:45,159 --> 00:01:51,159 testament honor about August eighth, twenty nineteen four. On November 24 00:01:51,200 --> 00:01:55,079 twenty one, twenty nineteen, claimant filed a civil action in 25 00:01:55,120 --> 00:01:58,480 the United States District Court for the Southern District of 26 00:01:58,560 --> 00:02:02,200 New York seeking damage is against the estate. A true 27 00:02:02,239 --> 00:02:05,599 and correct copy of the complaint soul filed and indexed 28 00:02:05,640 --> 00:02:10,479 as case number one nineteen CV DASH one zero seven 29 00:02:10,560 --> 00:02:14,280 eight eight, is attached Heer two as Exhibit A five. 30 00:02:14,840 --> 00:02:18,400 Pursuant to New York Child's Victims Act, among other bases, 31 00:02:18,680 --> 00:02:22,639 claimants civil action in New York was commenced timely. Six 32 00:02:23,400 --> 00:02:28,639 Descedent committed sexual abuse, included repeated sexual assault and forcible 33 00:02:28,759 --> 00:02:33,919 rape upon claimant on multiple occasions. Seven. The petition for 34 00:02:34,000 --> 00:02:38,080 probate of the dessendents a state lists personal and real 35 00:02:38,120 --> 00:02:42,039 property valued at five hundred and seventy seven million, six 36 00:02:42,120 --> 00:02:45,159 hundred and seventy two thousand and six hundred and fifty 37 00:02:45,199 --> 00:02:49,759 four dollars eight. Claimant's claim, as determined in a final 38 00:02:49,840 --> 00:02:53,240 judgment in the matter attached heer two as Exhibit A, 39 00:02:53,680 --> 00:02:59,319 including compensentory damages, punitive damages, costs, interests in fees, is 40 00:02:59,439 --> 00:03:02,719 rightfully entitled to payment whether or not the claim has 41 00:03:02,759 --> 00:03:07,439 been reduced to judgment, liquidated, fixed, or matured, and as 42 00:03:07,479 --> 00:03:11,960 an equitable lean on all encumbered assets and property of 43 00:03:12,000 --> 00:03:16,159 the estate. This was signed by Mary Anne Meyer Wang. 44 00:03:17,360 --> 00:03:19,599 The next document we have is the complaint and the 45 00:03:19,680 --> 00:03:24,919 jury demand Case number nineteen SIV DOT one zero seven 46 00:03:25,000 --> 00:03:29,439 eight eight Tila Davies plaintiff vers Darren k Endyke and 47 00:03:29,560 --> 00:03:33,840 Richard D. Kahn as executors of the estate of Jeffrey 48 00:03:34,039 --> 00:03:39,599 e Epstein. Plaintiff Tila Davies buy and, through her attorneys 49 00:03:39,840 --> 00:03:44,879 Cutty Hecker, Wang LLP and Allred, Morocco and Goldberg, for 50 00:03:45,000 --> 00:03:49,919 her complaint alleges as follows nature of action one. When 51 00:03:49,919 --> 00:03:53,479 plaintiff Tila Davies was just seventeen years old, living on 52 00:03:53,520 --> 00:03:57,560 her own and working full time to support herself, Jeffrey 53 00:03:57,560 --> 00:04:01,240 Epstein prayed upon her, manipulated her to be completely dependent 54 00:04:01,319 --> 00:04:05,319 on him, and sexually abused her. Two. Epstein was presented 55 00:04:05,360 --> 00:04:08,960 to Tela as someone who had learned about her challenging 56 00:04:09,000 --> 00:04:12,400 circumstances and had the resources and interest to his sister, 57 00:04:13,039 --> 00:04:16,399 including by helping her to attend college and study abroad 58 00:04:16,600 --> 00:04:20,439 to see the world. Telo was introduced to Ebstein by 59 00:04:20,480 --> 00:04:23,839 her sister, but Tila was unaware that Epstein had been 60 00:04:23,879 --> 00:04:28,360 manipulating and sexually abusing her sister, as Epstein's total power 61 00:04:28,360 --> 00:04:31,800 in control over Tila's sister made it impossible for her 62 00:04:31,839 --> 00:04:36,279 to say anything about it. Three. During their early interactions, 63 00:04:36,279 --> 00:04:39,399 Epstein led Tila to believe that he would help her 64 00:04:39,399 --> 00:04:42,920 achieve her dream of becoming a translator, and he arranged 65 00:04:42,920 --> 00:04:46,920 for Tila to study abroad in Spain. Tila gave up 66 00:04:46,959 --> 00:04:50,240 her job and her apartment in anticipation of this life 67 00:04:50,360 --> 00:04:54,199 changing opportunity, leaving her completely dependent on Epstein and his 68 00:04:54,360 --> 00:05:00,959 continuing generosity. Four. Epstein exploited this power over seventeen Tila 69 00:05:01,000 --> 00:05:05,199 to sexually abuse her repeatedly. Ultimately, he raped her and 70 00:05:05,319 --> 00:05:09,160 sexually assaulted her frequently in a variety of places and settings, 71 00:05:09,399 --> 00:05:12,480 including by trafficking Tila to his homes in New York, 72 00:05:12,720 --> 00:05:17,399 New Mexico, Florida, the Virgin Islands, and France. He treated 73 00:05:17,399 --> 00:05:21,360 her like an object for his sexual gratification. Five. These 74 00:05:21,399 --> 00:05:25,199 assaults caused Tila to feel completely intimidated and fearful. She 75 00:05:25,279 --> 00:05:28,240 froze up and began to cry, able to think only 76 00:05:28,240 --> 00:05:33,319 about trying to survive. Six. Epstein continued to exert total 77 00:05:33,360 --> 00:05:37,319 control over Tila's life for two more years, trafficking her 78 00:05:37,480 --> 00:05:40,560 around the country and the world, and sexually abusing her 79 00:05:40,720 --> 00:05:44,720 on frequent basis. During this time, Tila felt deep despair 80 00:05:44,800 --> 00:05:48,920 and isolation and developed a severe and self destructive eating disorder. 81 00:05:49,480 --> 00:05:53,600 Still within his power and control, Tila confided in Epstein 82 00:05:53,879 --> 00:05:57,560 about her disorder, mistakingly believing that she could trust him 83 00:05:57,839 --> 00:06:00,560 rather than help her. Epstein cast her out out within 84 00:06:00,639 --> 00:06:03,279 hours of her admission, sending her back to a place 85 00:06:03,319 --> 00:06:06,279 where she no longer had a home, a job, or 86 00:06:06,319 --> 00:06:12,120 any resources of support. Seven. Epstein's abuse destroyed Miss Davies's life. 87 00:06:12,240 --> 00:06:15,759 She sank into alcoholism and other self harm, unable to 88 00:06:15,800 --> 00:06:20,000 trust others but not understanding why. Eight At the same time, 89 00:06:20,360 --> 00:06:23,519 like so many childhood sex abuse victims, she did not 90 00:06:23,680 --> 00:06:27,959 comprehend how it had undone her or her life, or 91 00:06:28,120 --> 00:06:32,040 how it had impacted her. Nine. Now a working mother 92 00:06:32,120 --> 00:06:35,879 of three, Miss Davies is still just beginning to understand 93 00:06:35,920 --> 00:06:38,920 the depth of those injuries from the sexual assaults that 94 00:06:39,040 --> 00:06:43,360 Epstein inflicted on her, beginning when she was seventeen. She 95 00:06:43,439 --> 00:06:46,920 still feels the toll of Epstein's abuse every day. She 96 00:06:46,959 --> 00:06:50,839 feels dysfunctional, on edge, overwhelmed, and like she is on 97 00:06:50,879 --> 00:06:54,839 the verge of a psychological breakdown. She has difficulty sleeping 98 00:06:55,120 --> 00:06:59,920 and often has flashbacks to Epstein's abuse. Ten Epstein died 99 00:07:00,000 --> 00:07:03,800 August of twenty nineteen before Miss Davies or the countless 100 00:07:03,800 --> 00:07:07,399 other girls he prayed upon could obtain a modicum of justice. 101 00:07:07,600 --> 00:07:11,839 Number eleven. Miss Davies brings this action, seeking at last 102 00:07:11,879 --> 00:07:15,839 some remedy for the egregious abuse that Epstein inflicted when 103 00:07:15,879 --> 00:07:20,439 she was still a child. Parties twelve. Plaintiff Tila Davies 104 00:07:20,720 --> 00:07:25,439 is an individual who resides in Arizona. Thirteen Defendants Darren 105 00:07:25,519 --> 00:07:28,959 k Endyke and Richard D. Con are the executors of 106 00:07:29,000 --> 00:07:33,759 the estate of Jeffrey E. Epstein. The estate as executors 107 00:07:33,759 --> 00:07:36,439 of the estate. Defendants are liable for the acts and 108 00:07:36,480 --> 00:07:41,480 omissions of Epstein and his agents for purposes of US CO. 109 00:07:41,680 --> 00:07:45,399 Twenty eight, Section thirteen thirty two. Defendants in Dyke and 110 00:07:45,480 --> 00:07:48,439 Khan are deemed to be citizens of the United States 111 00:07:48,519 --> 00:07:52,319 Virgin Islands, where Epstein was domiciled at the time of 112 00:07:52,399 --> 00:07:57,879 his death. Jurisdiction and venue fourteen. This court has subject 113 00:07:57,959 --> 00:08:02,079 matter jurisdiction pursuant to US Code twenty eight, Section thirteen 114 00:08:02,160 --> 00:08:05,839 thirty two because the case is between citizens of different 115 00:08:05,839 --> 00:08:11,600 states and the amountain controversy exceeds seventy five thousand dollars. Fifteen, 116 00:08:12,319 --> 00:08:16,040 Venue is proper in this district pursuant to US Code 117 00:08:16,040 --> 00:08:20,240 twenty eight Section thirteen ninety one b in two because 118 00:08:20,240 --> 00:08:23,680 the substantial part of the events or omissions giving rise 119 00:08:23,759 --> 00:08:28,160 to the claim occurred in this district. Sixteen, This Court 120 00:08:28,439 --> 00:08:32,879 has personal jurisdiction over defendants as executors of the estate. 121 00:08:33,240 --> 00:08:37,519 Defendants Indike and Khan are subject to personal jurisdiction in 122 00:08:37,559 --> 00:08:41,559 this court because Epstein was subject to personal jurisdiction at 123 00:08:41,559 --> 00:08:45,000 the time of his death. Seventeen, this court had both 124 00:08:45,039 --> 00:08:49,320 specific and general personal jurisdiction over Epstein at the time 125 00:08:49,320 --> 00:08:53,080 of his death eighteen. Epstein resided in New York State 126 00:08:53,320 --> 00:08:56,440 a substantial portion of the time during the time period 127 00:08:56,600 --> 00:08:59,320 at issue in this lawsuit and through the time of 128 00:08:59,360 --> 00:09:04,440 his death nineteen. Epstein resided in the Metropolitan Correctional Center 129 00:09:04,480 --> 00:09:06,679 in New York County. At the time of his death 130 00:09:07,200 --> 00:09:12,799 twenty Epstein conducted substantial business operations in New York. Twenty one. 131 00:09:13,279 --> 00:09:18,279 Epstein owned and or controlled numerous companies with principal places 132 00:09:18,279 --> 00:09:22,559 of business in New York. Twenty two. Epstein owned substantial 133 00:09:22,600 --> 00:09:26,919 real property assets in New York, including townhouse located at 134 00:09:27,080 --> 00:09:30,639 ninth East seventy first Street in Manhattan, which is valued 135 00:09:30,639 --> 00:09:34,639 at fifty five million or more. Twenty three. New York 136 00:09:34,720 --> 00:09:39,320 was the epicenter of Epstein's criminal sex trafficking enterprise. For years, 137 00:09:39,360 --> 00:09:42,679 Abstein and his agents took action in New York in 138 00:09:42,759 --> 00:09:45,600 order to arrange for minor girls to be trafficked to 139 00:09:45,679 --> 00:09:49,240 his homes throughout the country in order to perform sexual 140 00:09:49,320 --> 00:09:53,399 lax forum. Epstein's trafficking and abuse of Miss Davies was 141 00:09:53,480 --> 00:09:57,120 part of that New York based criminal enterprise. Twenty four. 142 00:09:57,639 --> 00:10:01,080 From his Manhattan townhouse, Epstein directed a vast network of 143 00:10:01,120 --> 00:10:04,559 agents in recruiting minor girls to be brought to him 144 00:10:04,919 --> 00:10:09,919 for his sexual use. Twenty five. Epstein sexually abused many 145 00:10:09,919 --> 00:10:13,399 minor girls, including Miss Davies, in his Manhattan town house. 146 00:10:14,480 --> 00:10:18,320 Twenty six. On many occasions, Epstein and his agents made 147 00:10:18,320 --> 00:10:21,919 phone calls from New York to schedule appointments for minor 148 00:10:21,960 --> 00:10:25,759 girls to come to Epstein's residences outside of New York 149 00:10:26,120 --> 00:10:30,639 in order to perform commercial sex acts for Epstein. Twenty seven. 150 00:10:30,960 --> 00:10:35,039 Upon information and belief, Epstein and or his agents were 151 00:10:35,080 --> 00:10:38,200 present in New York when they took various actions to 152 00:10:38,279 --> 00:10:41,799 facilitate the trafficking of Miss Davies for the purpose of 153 00:10:41,840 --> 00:10:47,879 performing sexual acts for Epstein. Jury Demand twenty eight. Plaintiff 154 00:10:47,919 --> 00:10:51,279 hereby demands a trial by jury on oli her claims 155 00:10:51,399 --> 00:10:57,039 in this action. Factual Allegations twenty nine. When Plaintiff Tila 156 00:10:57,120 --> 00:11:01,000 Davies was seventeen years old, Jeffrey eppste Dean preyed upon her, 157 00:11:01,240 --> 00:11:04,240 manipulating her to be completely dependent on him, and then 158 00:11:04,320 --> 00:11:09,440 sexually assaulting and raping her on numerous occasions. Epstein continued 159 00:11:09,440 --> 00:11:13,320 this pattern of manipulation and frequent sexual assault for years, 160 00:11:13,600 --> 00:11:17,200 leaving Miss Davies with deep emotional wounds that she is 161 00:11:17,279 --> 00:11:21,879 still just beginning to grapple with thirty. By age seventeen, 162 00:11:22,240 --> 00:11:27,080 Tila had already lived through tremendously challenging circumstances. At eleven 163 00:11:27,200 --> 00:11:29,960 years old, she was homeless for a year, staying with 164 00:11:30,039 --> 00:11:33,440 various friends and seeing her mother only about once a week. 165 00:11:33,960 --> 00:11:37,600 At fifteen, Tela began working in order to support herself. 166 00:11:38,120 --> 00:11:42,399 At sixteen, Tila's living situation was again unstable, and she 167 00:11:42,519 --> 00:11:45,960 moved to La to live with her older sister. Thirty one, 168 00:11:46,519 --> 00:11:49,320 Tila initially tried to go to school in Los Angeles, 169 00:11:49,559 --> 00:11:52,360 but was unable to continue due to the need to 170 00:11:52,440 --> 00:11:55,919 work full time to support herself. Tela lived with her 171 00:11:55,960 --> 00:11:59,799 sister and worked out a hair salon, eventually getting her ged. 172 00:12:00,639 --> 00:12:03,360 By the time Tela met Epstein, she had already been 173 00:12:03,399 --> 00:12:06,039 living on her own and working full time for a 174 00:12:06,120 --> 00:12:09,919 year and a half. Thirty two, Teala's sister, who was 175 00:12:09,960 --> 00:12:13,240 five years older than her, had previously met Epstein and 176 00:12:13,360 --> 00:12:17,679 traveled with him. Teala's sister described Epstein as her generous, 177 00:12:18,000 --> 00:12:20,960 wealthy person, and reported that he often helped her make 178 00:12:21,000 --> 00:12:25,559 it possible for people to attend college. Teala's sister reported 179 00:12:25,600 --> 00:12:28,799 that Epstein had heard Telas story and had wanted to help. 180 00:12:29,360 --> 00:12:33,960 Thirty three. Unbeknownst to Tela, Ebstein had been manipulating and 181 00:12:34,039 --> 00:12:37,759 sexually abusing her sister. Tela had no idea that her 182 00:12:37,799 --> 00:12:41,279 sister had been involved in any type of sexual interactions 183 00:12:41,360 --> 00:12:45,480 with Epstein. Epstein's power and control of Tela's sister made 184 00:12:45,480 --> 00:12:49,799 it impossible for her to say anything. Thirty four. Tela 185 00:12:49,840 --> 00:12:52,639 met Epstein for the first time in two thousand and two. 186 00:12:53,039 --> 00:12:56,639 She was seventeen years old. Epstein was visiting Los Angeles, 187 00:12:56,840 --> 00:12:59,320 and Tela drove with her sister to meet him at 188 00:12:59,320 --> 00:13:03,559 the Hotel Bell thirty five. During that first meeting, Epstein 189 00:13:03,639 --> 00:13:07,080 lay on a bed in his spacious hotel suite. Fully clothed. 190 00:13:07,480 --> 00:13:10,879 He asked Tila's sister to massage his feet, then encouraged 191 00:13:10,919 --> 00:13:14,600 Tila to join her. Afterwards, Epstein took them shopping and 192 00:13:14,679 --> 00:13:19,279 insisted on buying several items for Tila. Thirty six. After 193 00:13:19,320 --> 00:13:22,600 that meeting, Epstein kept in touch with Tila through frequent 194 00:13:22,639 --> 00:13:26,960 phone calls. Epstein veered the conversation toward Tila's career goals. 195 00:13:27,080 --> 00:13:30,159 How Epstein could help her achieve them. He purported to 196 00:13:30,240 --> 00:13:32,720 want to help her and guide her to a better life. 197 00:13:33,279 --> 00:13:36,720 Thirty seven, Epstein offered to send Tila to school to 198 00:13:36,799 --> 00:13:40,000 learn hairdressing, but Tila made clear this was not what 199 00:13:40,080 --> 00:13:43,840 she wanted to do in the long term. Tela explained 200 00:13:43,879 --> 00:13:46,320 that she had a passion for languages and for people, 201 00:13:46,639 --> 00:13:50,039 and that her dream was to be a translator. Thirty eight, 202 00:13:50,639 --> 00:13:53,679 Epstein claimed that he wanted to help Tela study to 203 00:13:53,759 --> 00:13:56,720 become a translator. He suggested that he would pay for 204 00:13:56,759 --> 00:14:00,480 Tila to study in Spain for a semester. Soon after, 205 00:14:00,519 --> 00:14:03,639 Epstein helped her to obtain a letter of recommendation from 206 00:14:03,720 --> 00:14:07,200 high school and helped her get accepted to study at 207 00:14:07,240 --> 00:14:12,039 the University of Madrid. Thirty nine. Tila was over the moon, 208 00:14:12,360 --> 00:14:16,360 feeling her dreams were coming true. Epstein made sure she 209 00:14:16,440 --> 00:14:20,519 felt that it was all his doing. Forty Tela prepared 210 00:14:20,519 --> 00:14:24,159 for this exciting opportunity to study abroad and pursue her 211 00:14:24,240 --> 00:14:27,279 dream career. She gave notice at her hair dressing job 212 00:14:27,559 --> 00:14:30,879 and gave up her apartment in Los Angeles, preparing to 213 00:14:30,879 --> 00:14:34,960 move to Spain. Forty one before Tila left for her 214 00:14:34,960 --> 00:14:38,799 school program, However, Epstein began what would become a long 215 00:14:38,879 --> 00:14:42,480 pattern of using her as his sexual object. Forty two 216 00:14:43,039 --> 00:14:46,159 and approximately the summer of two thousand and two, Epstein 217 00:14:46,240 --> 00:14:49,600 flew Tila and her sister to his ranch in New Mexico. 218 00:14:49,919 --> 00:14:52,600 Tila felt no reason to be wary of Epstein. He 219 00:14:52,639 --> 00:14:55,080 had been kind in their first meeting and had acted 220 00:14:55,120 --> 00:14:59,080 with generosity towards her. Forty three. When Tila got to 221 00:14:59,120 --> 00:15:03,720 Ebstein's ranch, Epstein's close associate Glen Maxwell and Sarah Kellen 222 00:15:03,759 --> 00:15:08,360 were there. Maxwell asked Tila questions about herself and took 223 00:15:08,360 --> 00:15:11,879 her horse back riding. Kellen invited Tela to go swimming. 224 00:15:13,159 --> 00:15:16,639 Forty four, After Tela swam, Epstein asked her to go 225 00:15:16,679 --> 00:15:20,919 into the massage room along with Kellen. Kellen began massaging Epstein, 226 00:15:21,279 --> 00:15:24,519 and Tila innocently joined in, as she had when her 227 00:15:24,559 --> 00:15:28,840 sister massaged Epstein's feet for the first time forty five. 228 00:15:29,440 --> 00:15:32,559 At that point, Epstein began fondling Kellen and took off 229 00:15:32,600 --> 00:15:36,840 Kellen's shirt. Tila became very uncomfortable as the massage had 230 00:15:36,919 --> 00:15:42,000 quickly and unexpectedly turned into a sexual encounter. Epstein reached 231 00:15:42,000 --> 00:15:47,200 inside Tela's bathing suit and fondled her genitals. Tila began crying, 232 00:15:47,480 --> 00:15:50,759 but Epstein continued to grope her as he masturbated to 233 00:15:50,840 --> 00:15:56,559 completion forty six. Tila felt extremely vulnerable. Epstein had arranged 234 00:15:56,600 --> 00:16:01,120 the circumstances to ensure that Tela was completely at his mercy. 235 00:16:01,720 --> 00:16:04,559 Tela had given up her job and her apartment in 236 00:16:04,679 --> 00:16:08,240 order to travel to Spain at Epstein's expense. If Epstein 237 00:16:08,320 --> 00:16:12,000 decided to rethink his generosity at any point, Tila would 238 00:16:12,000 --> 00:16:14,679 have had nothing and would have been left homeless and 239 00:16:14,799 --> 00:16:18,519 jobless once again. After being brought so close to her dream, 240 00:16:19,240 --> 00:16:22,440 Even though Epstein had preyed upon her and sexually assaulted her, 241 00:16:22,720 --> 00:16:25,840 Tila understood she had no choice but to submit to him. 242 00:16:26,159 --> 00:16:31,320 His power over her was all encompassing forty seven. Epstein 243 00:16:31,440 --> 00:16:34,799 viciously exploited this power dynamic. In the summer and fall 244 00:16:34,840 --> 00:16:37,320 of two thousand and two. He flew seventeen year old 245 00:16:37,399 --> 00:16:40,399 Tila to his home in New York, Florida, and then 246 00:16:40,440 --> 00:16:43,759 the US Virgin Islands, sexually assaulting her in each of 247 00:16:43,799 --> 00:16:48,320 those locations. Forty eight. In or around December two thousand 248 00:16:48,360 --> 00:16:51,440 and two, Epstein flew Tila to stay at his townhouse 249 00:16:51,519 --> 00:16:55,559 located at nineties seventy first Street in Manhattan. While they 250 00:16:55,559 --> 00:16:58,840 were in the dining room of the townhouse, Epstein, without warning, 251 00:16:59,080 --> 00:17:03,039 stuck his hand down to Tila's pants and fondled her genitals. 252 00:17:03,679 --> 00:17:06,960 It was as if she were his toy. Forty nine. 253 00:17:07,279 --> 00:17:10,160 In Or around the same month, at Epstein's home in Florida, 254 00:17:10,519 --> 00:17:13,599 Epstein crept into Tila's bedroom while she was sleeping and 255 00:17:13,759 --> 00:17:17,599 raped her fifty Also around that same month, at the 256 00:17:17,599 --> 00:17:21,519 private island Epstein owned in the Virgin Islands, Epstein ordered 257 00:17:21,519 --> 00:17:24,880 Tila to massage them, then proceeded to sexually assault her 258 00:17:25,039 --> 00:17:29,160 in the massage room. Fifty one. Tila finally traveled to 259 00:17:29,200 --> 00:17:32,079 Spain to study in Or around the end of two 260 00:17:32,119 --> 00:17:35,400 thousand and two. Fifty two. In early two thousand and three, 261 00:17:35,640 --> 00:17:40,000 when Tila was still seventeen years old, Epstein flew her 262 00:17:40,039 --> 00:17:43,279 from Madrid to Paris. At his home in Paris, Epstein 263 00:17:43,359 --> 00:17:46,559 again crept into Tila's bedroom while she slept and raped 264 00:17:46,559 --> 00:17:51,039 her fifty three. When Epstein inflicted these sexual assaults on Tila, 265 00:17:51,240 --> 00:17:55,079 she felt completely intimidated and fearful. All she could think 266 00:17:55,079 --> 00:17:58,400 about was trying to survive her body froze up and 267 00:17:58,559 --> 00:18:03,079 she began crying. Four after Tela's semester in Madrid, she 268 00:18:03,200 --> 00:18:06,640 had no home and no job. Instead, Epstein brought her 269 00:18:06,640 --> 00:18:10,680 to live a nomadic lifestyle in his close orbit. Tila 270 00:18:10,759 --> 00:18:14,720 traveled around the country with Epstein and his entourage, which 271 00:18:14,839 --> 00:18:20,000 generally included Maxwell, Kellen and others. Virtually every few days, 272 00:18:20,240 --> 00:18:22,839 Epstein would bring Tila to a different home of his, 273 00:18:23,319 --> 00:18:26,759 including the Manhattan townhouse and throughout the country, where he 274 00:18:26,799 --> 00:18:30,880 continued to sexually assault her on a frequent basis. Epstein 275 00:18:30,960 --> 00:18:34,839 regularly used his private planes to traffic Tela into various 276 00:18:34,880 --> 00:18:39,440 locations for his sexual abuse of her. Fifty five. Epstein 277 00:18:39,480 --> 00:18:43,160 had power over every aspect of Tila's life, and he 278 00:18:43,200 --> 00:18:46,119 had groom Tela to be completely dependent on him and 279 00:18:46,160 --> 00:18:50,880 completely submissive to him. Epstein treated Tila as a sexual object, 280 00:18:51,119 --> 00:18:55,160 using her body for his sexual gratification frequently and at 281 00:18:55,200 --> 00:18:59,880 his whim fifty six. Eventually, by approximately two thousand and four, 282 00:19:00,319 --> 00:19:03,960 Epstein arranged for Tila to live at an apartment at 283 00:19:04,000 --> 00:19:07,079 three oh one East sixty sixth Street in Manhattan, just 284 00:19:07,119 --> 00:19:09,559 blocks from his townhouse. When she was in New York 285 00:19:10,240 --> 00:19:14,839 fifty seven. This pattern of Epstein, exercising total control over 286 00:19:14,880 --> 00:19:18,559 Tila's life and using her as a sexual object whenever 287 00:19:18,599 --> 00:19:22,039 he desired. Continued throughout two thousand and three and two 288 00:19:22,039 --> 00:19:25,839 thousand and four. Epstein arranged for Tila to study abroad 289 00:19:25,880 --> 00:19:29,119 two more times, apparently when he grew bored with having 290 00:19:29,119 --> 00:19:32,839 her around each time. Tela lived in this nomadic orbit 291 00:19:32,880 --> 00:19:36,599 with Epstein both before and after traveling to attend school. 292 00:19:37,440 --> 00:19:40,720 Fifty eight. Epstein also tried to introduce Tela to his 293 00:19:40,799 --> 00:19:44,599 friends and essentially offer her as a sexual object to them. 294 00:19:44,960 --> 00:19:48,359 In one instance, Epstein had Tela spend time with a 295 00:19:48,400 --> 00:19:52,240 well known Hollywood producer, who then demanded and attempted to 296 00:19:52,400 --> 00:19:58,279 engage in abusive sexual behavior. Tila barely escaped fifty nine. 297 00:19:58,559 --> 00:20:02,519 By two thousand and four, Tila fell deep despair and isolation. 298 00:20:03,440 --> 00:20:05,319 There was no one she could talk to about what 299 00:20:05,359 --> 00:20:08,519 Epstein was doing to her. Instead, Epstein had ensured that 300 00:20:08,599 --> 00:20:11,160 she thought he was the only person in her life 301 00:20:11,319 --> 00:20:16,640 whom she could trust. Sixty Tila developed a severe eating 302 00:20:16,640 --> 00:20:19,519 disorder for the first time in or around two thousand 303 00:20:19,519 --> 00:20:22,359 and four. After she had struggled with the disorder for 304 00:20:22,400 --> 00:20:25,119 six months or a year, it became too much to bear. 305 00:20:25,720 --> 00:20:29,599 She confided in Epstein about her eating disorder, still manipulated 306 00:20:29,640 --> 00:20:34,559 into thinking he was someone she could trust sixty one. Instead, 307 00:20:34,640 --> 00:20:38,359 from the moment Epstein learned of Tila's self destructive behavior, 308 00:20:38,599 --> 00:20:42,480 he immediately cast her out. Literally within hours of Tila 309 00:20:42,519 --> 00:20:46,039 anxiously confessing to Ebstein that she did not know why, 310 00:20:46,079 --> 00:20:49,640 but had a compulsive need to binge and purge, he 311 00:20:49,720 --> 00:20:52,240 threw her out. He instructed her to pack up her 312 00:20:52,240 --> 00:20:55,480 belongings and arrange for her to be flown to Arizona 313 00:20:56,039 --> 00:21:00,200 sixty two, but there was nothing left in Arizona. Still 314 00:21:00,279 --> 00:21:02,880 had no idea what had happened to her and felt 315 00:21:02,880 --> 00:21:06,799 it was all her fault. Sixty three. Epstein's abuse destroyed 316 00:21:06,799 --> 00:21:10,319 Tila's life. After being cast out by him after two 317 00:21:10,400 --> 00:21:14,200 years of a lavish if abusive lifestyle, she sank into 318 00:21:14,200 --> 00:21:17,759 alcoholism and other self harm, unable to trust others but 319 00:21:18,000 --> 00:21:22,240 not understanding why. Sixty four. Miss Davies is now a 320 00:21:22,279 --> 00:21:25,599 working mother raising three children. She's still struggling to put 321 00:21:25,599 --> 00:21:29,839 her life back together. Sixty five. Miss Davies is still 322 00:21:29,839 --> 00:21:33,240 in the nascent stages of understanding the deep and lasting 323 00:21:33,279 --> 00:21:36,880 injuries at Epstein's pattern of abuse has caused her, but 324 00:21:37,039 --> 00:21:41,319 she feels the effects every day. She feels dysfunctional, on edge, 325 00:21:41,559 --> 00:21:45,759 and constantly overwhelmed. She has difficulty sleeping. She often has 326 00:21:45,799 --> 00:21:49,359 flashbacks to Epstein's sexual assaults. She feels like she's on 327 00:21:49,400 --> 00:21:54,240 the verge of a psychological breakdown. Sixty six. This action 328 00:21:54,400 --> 00:21:58,160 is timely under the law of each jurisdiction whose law 329 00:21:58,240 --> 00:22:02,880 might be determined to govern Miss Davies's claims or aspects thereof, 330 00:22:03,160 --> 00:22:07,640 including without limitation, New York, New Mexico, Florida, and the 331 00:22:07,720 --> 00:22:12,680 Virgin Islands. Sixty seven. Miss Davies still has not disclosed 332 00:22:12,680 --> 00:22:15,440 her abuse to a licensed medical or mental health care 333 00:22:15,480 --> 00:22:19,119 provider in the context of receiving healthcare from the provider. 334 00:22:19,599 --> 00:22:23,599 Sixty eight. Miss Davies is still just beginning to process 335 00:22:23,599 --> 00:22:27,279 and understand the full extent of the injuries that Epstein's 336 00:22:27,319 --> 00:22:31,240 abuse has caused her, and the connection between Epstein's abuse 337 00:22:31,599 --> 00:22:37,799 and the emotional and psychological injuries she had experienced. Sixty nine. 338 00:22:37,839 --> 00:22:40,839 This action is timely under New York law because it 339 00:22:40,880 --> 00:22:45,680 falls within New York cp LR two fourteen G and 340 00:22:45,880 --> 00:22:48,799 is brought during the one year time period set forth 341 00:22:48,960 --> 00:22:54,000 in that action. The claims brought herein allege intentional and 342 00:22:54,160 --> 00:22:58,759 negligent acts and or emissions for physical, psychological, and other 343 00:22:58,799 --> 00:23:02,480 injuries suffered as a result of conduct that would constitute 344 00:23:02,759 --> 00:23:06,400 sexual offenses as defined an Article one point thirty of 345 00:23:06,440 --> 00:23:09,039 the New York Penal Law, and such acts and or 346 00:23:09,079 --> 00:23:12,680 emissions were committed against Miss Davies when she was less 347 00:23:12,680 --> 00:23:18,240 than eighteen years of age seventy Epstein's conduct constitutes childhood 348 00:23:18,240 --> 00:23:22,400 sexual abuse within the meaning of New Mexico Statute thirty 349 00:23:22,480 --> 00:23:25,920 seven Dash one, Dash thirty and abuse with the meaning 350 00:23:26,240 --> 00:23:32,119 of Florida Statute Section ninety five Dot eleven seven. First 351 00:23:32,119 --> 00:23:36,920 cause of action battery seventy one. Plaintiff hereby incorporates each 352 00:23:36,960 --> 00:23:40,160 of the foregoing paragraphs as if fully set forth here 353 00:23:40,200 --> 00:23:44,440 in seventy two. In committing the acts described above, Epstein 354 00:23:44,759 --> 00:23:49,480 intentionally subjected plaintiff to bodily contact that was offensive in nature. 355 00:23:50,440 --> 00:23:54,839 Seventy three. Epstein intentionally touched plaintiff in a rude, insolent, 356 00:23:55,039 --> 00:23:59,440 or angry manner. Seventy four. As a result of Epstein's actions, 357 00:23:59,519 --> 00:24:03,759 plaintiff suffered damages in an amount to be determined at trial. 358 00:24:04,519 --> 00:24:10,559 Second cause of action assault seventy five Plaintiff hereby incorporates 359 00:24:10,720 --> 00:24:13,400 each of the fore going paragraphs as if fully set 360 00:24:13,400 --> 00:24:17,960 forth herein seventy six. In committing the acts described above, 361 00:24:18,200 --> 00:24:22,920 Epstein engaged in physical conduct that plays plaintiff in eminent 362 00:24:23,039 --> 00:24:27,039 apprehension that he would harmur seventy seven. As a result 363 00:24:27,039 --> 00:24:30,640 of Epstein's actions, Plaintiff suffered damages in an amount to 364 00:24:30,680 --> 00:24:35,240 be determined at trial. Third cause of action intentional infliction 365 00:24:35,559 --> 00:24:40,960 of emotional distress seventy eight. Plaintiff hereby incorporates each of 366 00:24:41,000 --> 00:24:43,799 the fore going paragraphs as if fully set forth here 367 00:24:43,839 --> 00:24:48,000 in seventy nine. In committing the acts described above, Epstein 368 00:24:48,079 --> 00:24:52,240 engaged in extreme and outrageous conduct eighty In doing so, 369 00:24:52,440 --> 00:24:56,039 Epstein acted with the intent to cause and or disregard 370 00:24:56,519 --> 00:25:00,440 of a substantial likelihood of causing plaintiff to suffer severe 371 00:25:00,720 --> 00:25:05,759 emotional distress eighty one. As a direct result of Epstein's actions, 372 00:25:05,880 --> 00:25:10,359 Plaintiff suffered severe emotional distress. Eighty two. As a result 373 00:25:10,400 --> 00:25:13,799 of Epstein's actions, Plaintiff suffered damages in an amount to 374 00:25:13,839 --> 00:25:18,720 be determined at trial. Wherefore, Plaintiff respectfully requests that judgment 375 00:25:18,960 --> 00:25:23,759 be entered against defendants as follows. A Awarding compensatory damages 376 00:25:23,960 --> 00:25:29,359 for all physical injuries, emotional distress, psychological harm, anxiety, humiliation, 377 00:25:29,839 --> 00:25:34,119 physical and emotional pain and suffering, family and social disruption, 378 00:25:34,400 --> 00:25:37,559 and other harm in the amount to be determined at trial. 379 00:25:38,000 --> 00:25:41,839 B Awarding punitive damages in an amount to be determined 380 00:25:41,960 --> 00:25:46,240 at trial. C Awarding attorney's fees and cost pursue it 381 00:25:46,519 --> 00:25:50,640 to any applicable statute or law. D Awarding pre and 382 00:25:50,680 --> 00:25:54,720 post judgment interest on all such damages, fees, and or costs. 383 00:25:55,000 --> 00:25:59,039 E Attaching all of Defendant's real property and other assets 384 00:25:59,079 --> 00:26:01,839 located in the State of New York pursu into New 385 00:26:01,920 --> 00:26:05,559 York CPLR. Sixty two oh one and Federal Rule of 386 00:26:05,599 --> 00:26:10,079 Civil Procedures sixty four, and def Awarding such other and 387 00:26:10,240 --> 00:26:14,160 further relief as this Court may deem just and proper. 388 00:26:14,799 --> 00:26:19,400 This document was signed by Mary Ann Mera Wang. So 389 00:26:19,519 --> 00:26:22,039 instead of the BS, right, So, instead of all of 390 00:26:22,079 --> 00:26:25,359 the nonsense and the innuendo, we're gonna go right to 391 00:26:25,400 --> 00:26:28,599 the source and we're gonna continue going through these core 392 00:26:28,720 --> 00:26:31,839 documents so that all of you out there are able 393 00:26:31,920 --> 00:26:34,880 to wade through the bullshit and get to what's really real. 394 00:26:35,200 --> 00:26:37,200 All right, folks, that's gonna do it for this one. 395 00:26:37,279 --> 00:26:39,880 All of the information that goes with this episode can 396 00:26:39,960 --> 00:26:41,880 be found in the description box.