001.pdf
6.48 MB
Extraction Summary
9
People
7
Organizations
9
Locations
6
Events
7
Relationships
3
Quotes
Document Information
Type:
Legal complaint
File Size:
6.48 MB
Summary
This document is a legal complaint filed by Teresa Helm against the executors of Jeffrey Epstein's estate, Darren K. Indyke and Richard D. Kahn, alleging sexual abuse and trafficking by Epstein and his co-conspirators. The complaint details Epstein's extensive sex trafficking network, previous legal proceedings, and his personal statements regarding his actions, seeking damages for battery and intentional infliction of emotional distress.
People (9)
| Name | Role | Context |
|---|---|---|
| Teresa Helm | Plaintiff |
Sexually abused and trafficked by Jeffrey Epstein and others, citizen and resident of Ohio.
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| Darren K. Indyke | Defendant, Executor |
Executor of the Estate of Jeffrey Edward Epstein.
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| Richard D. Kahn | Defendant, Executor |
Executor of the Estate of Jeffrey Edward Epstein.
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| Jeffrey Edward Epstein | Deceased Perpetrator |
Alleged sexual abuser and trafficker, subject of the lawsuit.
|
| Sarah Kellen | Co-conspirator |
Alleged participant in Epstein's sex trafficking ring.
|
| Ghislaine Maxwell | Co-conspirator |
Alleged participant in Epstein's sex trafficking ring.
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| Kenneth Marra | United States District Judge |
Judge who made findings about Epstein's sexual abuse.
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| Amber Sutherland | Reporter |
Author of the New York Post article 'Billionaire Jeffrey Epstein: I’m a Sex Offender Not a Predator'.
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| James B. Stewart | Reporter |
Author of The New York Times article 'The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People'.
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| United States District Court for the Southern District of New York |
Court where the complaint was filed.
|
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| Boies Schiller Flexner LLP |
Attorneys for Plaintiff Teresa Helm.
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| California Healing Arts College |
Where Teresa Helm was studying massage.
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| Estate of Jeffrey Edward Epstein |
Defendant in the lawsuit, represented by executors Darren K. Indyke and Richard D. Kahn.
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| U.S. Attorney for the Southern District of Florida |
Involved in the 2008 non-prosecution agreement with Epstein.
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| New York Post |
Published an interview with Epstein in 2011.
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| The New York Times |
Published an interview with Epstein in 2018.
|
Timeline (6 events)
1999-2007
Jeffrey Epstein sexually abused more than 30 minor girls at his mansion in Palm Beach, Florida, and elsewhere. He directed others to abuse girls and used paid employees to recruit minors.
Palm Beach, Florida; United States; overseas
Jeffrey Epstein
minor girls
2008
Epstein received a minimal charge, pleading guilty to a Florida state law charge of procuring a minor for prostitution, and a non-prosecution agreement (NPA) with the U.S. Attorney for the Southern District of Florida. Served one year in jail with work release privileges.
Florida
Jeffrey Epstein
U.S. Attorney for the Southern District of Florida
2011
Epstein interview with New York Post where he referred to his sexual abuse of minors.
New York City
Jeffrey Epstein
2018-08
Epstein interview with New York Times reporter where he stated his views on sex with teenage girls.
Jeffrey Epstein
2019-08-29
Termination of a criminal action against Epstein related to the sex trafficking enterprise, which starts the one-year window for civil action.
Jeffrey Epstein
Teresa Helm was sexually trafficked by Epstein, Sarah Kellen, and Ghislaine Maxwell. She was recruited under the guise of a traveling masseuse opportunity while studying at California Healing Arts College, which led to sexual assault.
Locations (9)
| Location | Context |
|---|---|
|
Location of the court and a residence of Epstein.
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Teresa Helm's residence.
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Location of one of Epstein's mansions where abuse occurred.
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Location of Epstein's residences and where abuse occurred.
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Location of Epstein's residences.
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Location of Epstein's residences and his domicile at death.
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Location of Epstein's residences.
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Where Epstein recruited Teresa Helm and where sexual abuse occurred.
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General location of Epstein's activities.
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Relationships (7)
Teresa was sexually trafficked by Epstein; Epstein committed sexual assault and battery against her.
Teresa was sexually trafficked by Sarah Kellen as part of Epstein’s organized ring.
Teresa was sexually trafficked by Ghislaine Maxwell as part of Epstein’s organized ring.
Indyke is an appointed executor of the Estate of Jeffrey E. Epstein.
Kahn is an appointed executor of the Estate of Jeffrey E. Epstein.
Sarah Kellen trafficked Teresa Helm as part of Epstein's ring.
Ghislaine Maxwell trafficked Teresa Helm as part of Epstein's ring.
Key Quotes (3)
"From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach Florida, and elsewhere in the United States and overseas. . . . In addition to his own sexual abuse of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid employees to find and bring minor girls to him. Epstein worked in concert with others to obtain minors not only for his own sexual gratification, but also for the sexual gratification of others."Source
001.pdf
Quote #1
"Billionaire pervert Jeffrey Epstein is back in New York City – and making wisecracks about his just-ended jail stint for having sex with an underage girl. ‘I am not a sexual predator, I’m an offender,’ the financier told The Post yesterday. ‘It’s the difference between a murderer and a person who steals a bagel,’ said Epstein."Source
001.pdf
Quote #2
"that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable."Source
001.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (8,083 characters)
Case 1:19-cv-10476 Document 1 Filed 11/12/19 Page 1 of 14
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
FOR THE SOUTHERN DISTRICT OF NEW YORK
TERESA HELM,
Plaintiff,
CASE NO:
v.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
COMPLAINT
BOIES SCHILLER FLEXNER LLP
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Case 1:19-cv-10476 Document 1 Filed 11/12/19 Page 2 of 14
Plaintiff Teresa Helm, by her attorneys Boies Schiller Flexner LLP, for her Complaint
against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of
the Estate of Jeffrey Edward Epstein (“Epstein”), avers upon personal knowledge as to her own
acts and status and upon information and belief and to all other matters as follows:
NATURE OF THE ACTION
1. This suit arises out of Jeffrey Epstein’s sexual abuse of Plaintiff.
2. Teresa was sexually trafficked by Epstein, Sarah Kellen, and Ghislaine Maxwell as part
of Epstein’s organized ring of procuring young women for sex. She was recruited by a woman
who worked for Epstein and who offered Teresa the opportunity to become a traveling masseuse.
As Teresa was studying massage at the California Healing Arts College, this seemed like a
dream opportunity, but her hopes were dashed when it quickly turned into sexual assault.
3. Epstein’s trafficking scheme involved recruiting young females by making false promises
and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young women.
4. As United States District Judge Kenneth Marra found, “From between about 1999 and
2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach
Florida, and elsewhere in the United States and overseas. . . . In addition to his own sexual abuse
of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid
employees to find and bring minor girls to him. Epstein worked in concert with others to obtain
minors not only for his own sexual gratification, but also for the sexual gratification of others.”
Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted).
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Case 1:19-cv-10476 Document 1 Filed 11/12/19 Page 3 of 14
5. Epstein organized this sex trafficking network to obtain hundreds of young females for
himself for sex, and also lent these females out to other powerful and wealthy individuals to be
sexually abused.
6. Epstein conspired with others and hired staff to maintain and keep secret this network of
sexual abuse for years, which sprawled throughout Epstein’s residences in New York, Florida,
New Mexico, the United States Virgin Islands, and Paris. Epstein’s preference was to have three
different young females a day for his sexual pleasure.
7. Despite his significant criminal activity, in 2008 Epstein received a shockingly minimal
charge, pleading guilty to a single Florida state law charge of procuring a minor for prostitution
and a non-prosecution agreement (a “NPA”) with the U.S. Attorney for the Southern District of
Florida. Unknown to the public and the victims at the time, Epstein’s lawyers were pressuring
the Government to commit to the NPA without informing the victims. Epstein’s multiple
victims were kept in the dark and told to be “patient” while Epstein’s lawyers worked to protect
him and other potential co-conspirators from prosecution. Epstein served one year in jail, but
was afforded the privilege of being able to leave the jail to go to work for twelve hours per day,
six days per week.
8. The NPA allowed Epstein to escape proportionate punishment for his actions and to
continue operating his sex trafficking enterprise with liberty.
9. A few years later, Epstein flippantly referred to his sexual abuse of multiple minors, and
the slap on the wrist he had received for it, in a 2011 interview with the New York Post:
“Billionaire pervert Jeffrey Epstein is back in New York City – and making wisecracks about his
just-ended jail stint for having sex with an underage girl. ‘I am not a sexual predator, I’m an
offender,’ the financier told The Post yesterday. ‘It’s the difference between a murderer and a
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Case 1:19-cv-10476 Document 1 Filed 11/12/19 Page 4 of 14
person who steals a bagel,’ said Epstein.” Amber Sutherland, Billionaire Jeffrey Epstein: I’m a
Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011),
https://nypost.com/2011/02/25/billionaire-jeffrey-epstein-in-a-sex-offender-not-a-predator/.
10. In August 2018, just one year before his death, Epstein told a New York Times reporter
“that criminalizing sex with teenage girls was a cultural aberration and that at times in history it
was perfectly acceptable.” James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on
Powerful People, N.Y. Times (Aug. 12, 2019),
https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html.
11. When Plaintiff was 22 years old, Epstein added her to his long list of victims by
committing sexual assault and battery against her. As such, Epstein is responsible for battery
and intentional infliction of emotional distress pursuant to New York common law. The damage
to Plaintiff has been severe and lasting.
12. This action has been timely filed pursuant to N.Y. C.P.L.R. § 215(8)(a), which provides
that a plaintiff shall have at least one year from the termination of a criminal action against the
same defendant to commence an action with respect to the event or occurrence from which the
criminal action arose. A criminal action against Epstein with respect to the same sex trafficking
enterprise from which Plaintiff’s claims arise was terminated on August 29, 2019.
13. Any statute of limitations applicable to Plaintiff’s claims, if any, is tolled due to the
continuous and active deception, duress, threats of retaliation, and other forms of misconduct that
Epstein and his co-conspirators used to silence his many victims, including Plaintiff. Epstein’s
actions deprived Plaintiff of the opportunity to commence this lawsuit before his death. Until his
death, Plaintiff feared that Epstein and his co-conspirators would harm her or her family, or ruin
her life, if she came forward.
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Case 1:19-cv-10476 Document 1 Filed 11/12/19 Page 5 of 14
14. Defendants are equitably estopped from asserting a statute of limitations defense.
Allowing Defendants to do so would be unjust. Epstein and his co-conspirators intimidated each
of his victims into silence by threatening their lives and their livelihoods. They therefore
prevented Plaintiff from commencing this lawsuit before his death. By using threats, along with
his wealth and power, Epstein was able to escape punishment for his intolerable and brutal
crimes against countless young women and underage girls for the duration of his life.
PARTIES
15. Plaintiff Teresa Helm is a citizen and resident of Ohio.
16. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
17. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
JURISDICTION AND VENUE
18. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at
the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New
York. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and
Richard D. Kahn are deemed citizens of the U.S. Virgin Islands.
19. The amount in controversy in this action exceeds the sum or value of $75,000.00
excluding interests and costs and is between citizens of different states. Accordingly, jurisdiction
is proper under 28 U.S.C. § 1332.
20. Venue is proper in this Court as Epstein’s sexual abuse of Plaintiff occurred in New
York, New York, where he recruited her at the age of 22, physically molested her, and began
grooming her for sex in his organized sex trafficking ring.
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