Cox_v_Byrd

CASE NO. _

_

IN THE CIRCUIT COURT FOR SUMNER COUNTY
STATE OF TENNESSEE

KELLY L. COX, a minor, by and through her Mother and Next Friend,
CATHERINE A. O’BRIEN,

Plaintiff,

v.

ROBERT C. BYRD, a/k/a CORNELIUS CALVIN SALE JR.;
WALTER A. HOUSTON, a/k/a ALEX HOUSTON;
EDWARD W. COX, a/k/a WAYNE COX;
MARY COX (nee FARMAR);
JOHN DOES 1-10 (co-conspirators and additional participants whose identities will be ascertained through discovery),

Defendants.

COMPLAINT

Plaintiff Kelly Cox, by and through her mother and next friend Catherine A. O’Brien, brings this action against the above-named Defendants for damages arising from a pattern of sexual exploitation, trafficking, and physical sexual abuse occurring within the State of Tennessee.

I. PARTIES AND JURISDICTION

1. Plaintiff Kelly L. Cox is a minor child at the time of the underlying events, appearing through her mother, Catherine A. O’Brien.
2. Defendant Robert C. Byrd (a/k/a Cornelius Calvin Sale Jr.) was a high-ranking public official who allegedly exploited his position to direct the trafficking of the Plaintiff.
3. Defendant Walter A. Houston (a/k/a Alex Houston) was a resident of Tennessee and acted as a primary handler and abuser of the Plaintiff under the guise of his career as a professional ventriloquist.
4. Defendant Edward W. Cox (a/k/a Wayne Cox) is the biological father of the Plaintiff and acted as a handler and abuser, frequently coordinating with other Defendants to facilitate the Plaintiff’s exploitation.
5. Defendant Mary Cox (nee Farmar) is the mother of Edward Cox and is alleged to have acted as an accomplice in the concealment and facilitation of the abuse.
6. Defendants John Does 1-10 are individuals whose identities are currently unknown but who participated in or facilitated the illegal acts described herein and will be named upon discovery.
7. Jurisdiction and venue are proper in Sumner County, Tennessee, as a substantial portion of the acts giving rise to this claim occurred within this county and the surrounding Middle Tennessee area.

II. FACTUAL ALLEGATIONS

8. Beginning in the early 1980s, Defendant Robert Byrd exerted unlawful control over Catherine O’Brien and her daughter, Kelly Cox, treating them as personal property to be moved and exploited at his direction.
9. Defendant Byrd utilized Defendants Alex Houston and Wayne Cox as "handlers" to ensure Kelly Cox was transported to various locations for the purpose of sexual exploitation.
10. Defendant Alex Houston, a ventriloquist, used his professional travels to state and county fairs and nightclubs in Tennessee as a cover for trafficking the Plaintiff.
11. While in Tennessee, the Plaintiff was subjected to repeated sexual abuse and prostituted at various venues, including nightclubs and private residences in the Nashville and Sumner County areas.
12. Defendant Wayne Cox, a musician and performer, collaborated with Houston to maintain control over the Plaintiff through physical trauma and psychological intimidation.
13. The Defendants worked in concert to ensure the Plaintiff remained in a state of dependency and fear, often depriving her of adequate sleep and basic necessities to prevent her or her mother from seeking help.
14. Defendant Mary Cox provided logistical support and a base of operations for Wayne Cox, knowingly facilitating the environment in which the Plaintiff was abused.
15. This trafficking network operated under the direct influence of Defendant Byrd, who used his political power to ensure the operation remained shielded from local law enforcement and to intimidate those who attempted to report the abuse.

III. CAUSES OF ACTION

16. Assault and Battery: The Defendants subjected the Plaintiff to unwanted, harmful, and offensive sexual and physical contact.
17. False Imprisonment: The Defendants restricted the Plaintiff’s movement through force, threats, and psychological coercion, preventing her from escaping the cycle of abuse.
18. Intentional Infliction of Emotional Distress: The Defendants’ conduct was outrageous and extreme, intended to cause—and resulting in—severe emotional and psychological trauma to the Plaintiff.
19. Civil Conspiracy: The Defendants entered into an agreement to engage in the illegal trafficking and sexual exploitation of the Plaintiff for their personal benefit and gratification.

IV. PRAYER FOR RELIEF WHEREFORE, Plaintiff Kelly Cox respectfully requests that this Court:

A. Compensatory damages in an amount to be proven at trial, but not less than $50,000,000.00;
B. Punitive and exemplary damages in an amount sufficient to punish Defendants and deter future misconduct;
C. Pre- and post-judgment interest at the maximum legal rate;
D. Costs, attorneys’ fees, and expenses as allowed by law;
E. Such other and further relief as this Court deems just and proper.