Cox_v_Houston

CASE NO. _

_

IN THE CIRCUIT COURT FOR JACKSON COUNTY
STATE OF TENNESSEE

KELLY LYNN COX,
by and through her natural mother and next friend,
CATHLEEN ANN O’BRIEN,

Plaintiff,

v.

WALTER “ALEX” HOUSTON,
RAYMOND “RAY” MYERS,
REGINA “JOY” MYERS,
and JOHN DOES 1–5 (co-conspirators and additional participants whose identities will be ascertained through discovery),

Defendants.

COMPLAINT

Plaintiff Kelly Lynn Cox, by and through her natural mother and next friend, Cathleen Ann O’Brien, complains of Defendants and respectfully shows the Court as follows:

I. JURISDICTION AND VENUE

1. This Court has subject-matter jurisdiction over this action pursuant to Tennessee Code Annotated §§ 16-10-101 et seq. and the general civil jurisdiction of the Circuit Court, as the claims arise from tortious acts of child sexual abuse occurring within the State of Tennessee.

2. Venue is proper in Jackson County pursuant to Tennessee Code Annotated § 20-4-101 because a substantial part of the events or omissions giving rise to the claims—including the repeated sexual assaults of Plaintiff—occurred in Jackson County, Tennessee, specifically in the Cummins Mill area and at related venues where Defendants had access through country music performances and private residences.

3. Defendants are subject to the long-arm jurisdiction of this Court because they purposefully availed themselves of the privilege of conducting activities within Tennessee by residing, operating businesses, and participating in entertainment events in the state, where they engaged in the unlawful conduct described below.

II. PARTIES

4. Plaintiff Kelly Lynn Cox is an individual who, at all times relevant herein (1985), was a minor child approximately eight years of age and was subjected to repeated sexual assault and pedophilic abuse while under the control of Defendants.

5. Defendant Walter “Alex” Houston was a well-known country music ventriloquist and performer who, during the relevant period, toured extensively across Tennessee, including state fairs and Pigeon Forge venues. Houston had a documented career that included appearances on *The Jimmy Dean Show* (1957–1959), hosting *The Alex and Elmer Show*, performances on *Hee Haw* and the Grand Ole Opry, and opening acts for artists such as Charley Pride, Barbara Mandrell, Johnny and June Carter Cash, Conway Twitty, Alabama, and Ronnie Milsap. He also performed on USO tours with Bob Hope. Houston resided in Tennessee and used his entertainment access to facilitate abuse of minors, including Plaintiff.

6. Defendant Raymond “Ray” Myers resided in the Cummins Mill area of Jackson County, Tennessee, and operated Myers Supply (a small shop in the region circa 2000). Myers identified with the Baptist faith and was a close associate of Houston through Houston’s company UniPhayse.

7. Defendant Regina “Joy” Myers is the wife of Raymond “Ray” Myers and resided with him in the Cummins Mill area of Jackson County, Tennessee. She participated jointly with her husband in the sexual abuse of Plaintiff and is alleged to have abused other unnamed children.

8. John Does 1–5 are additional co-conspirators and participants in the pedophilic acts whose identities will be ascertained through discovery.

III. FACTUAL ALLEGATIONS

9. In 1985, while Plaintiff was a minor child approximately four years of age, she was repeatedly subjected to sexual assault and pedophilia by all three named Defendants in Jackson County, Tennessee.

10. Defendant Walter “Alex” Houston sexually assaulted Plaintiff on multiple occasions. These acts occurred in connection with Houston’s country music performances at Tennessee state fairs and Pigeon Forge venues, where Houston had ready access to minors through his public entertainment career and private associations. Houston’s use of his ventriloquist puppet “Elmer” (referred to as “his little buddy”) provided a facade of normalcy that masked his predatory behavior.

11. Defendant Raymond “Ray” Myers sexually assaulted Plaintiff on at least two separate occasions in Jackson County. Defendant Regina “Joy” Myers participated with her husband in at least one of these assaults. The Myers couple are further alleged to have sexually abused other unnamed children, establishing a pattern of pedophilic conduct.

12. All acts were committed without consent and involved harmful and offensive sexual touching and penetration. No protection was used, consistent with the pattern of exploitation described in related accounts.

13. Corroborating testimony is provided by Cathleen Ann O’Brien (Plaintiff’s mother), who has direct personal knowledge of the events, and by Marquart “Mark” Ewing Phillips. Phillips personally knew both Houston and Raymond “Ray” Myers through Houston’s company UniPhayse and has explicitly identified Myers as Houston’s “pervert friend.” Phillips is willing and prepared to testify regarding the relationship between Houston and the Myers couple, their access to Plaintiff, and the pedophilic nature of their activities. Phillips’ testimony establishes that the Myers couple were known to have molested Plaintiff and their own children.

14. At the time of the assaults, Plaintiff was too young to retain or recall all details due to her age, trauma-induced memory blocking, and the overwhelming number of abuses inflicted by multiple perpetrators. The claims are therefore supported by the direct observations and knowledge of Cathleen Ann O’Brien and Marquart “Mark” Ewing Phillips.

15. These acts were part of a larger pattern of trauma-based coercion and exploitation of minors for the sexual gratification of Defendants. Defendants acted in concert to conceal the crimes through threats, compartmentalization of memory, and exploitation of their positions in entertainment and local communities. The conduct has caused Plaintiff severe, permanent physical and emotional harm, including dissociative identity disorder, chronic pain, and profound psychological trauma.

IV. CAUSES OF ACTION

COUNT I – CHILD SEXUAL ABUSE / SEXUAL BATTERY
(Against All Defendants)
16. Defendants intentionally and unlawfully subjected Plaintiff, a minor child, to sexual touching, penetration, and other harmful and offensive acts without consent.

COUNT II – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against All Defendants)
17. Defendants’ conduct was extreme and outrageous, exceeding all bounds of decency, and was undertaken with the intent to cause, or with reckless disregard of the probability of causing, severe emotional distress to a minor child. Plaintiff has in fact suffered severe emotional distress, including dissociative disorders and permanent psychological damage.

COUNT III – CIVIL CONSPIRACY TO COMMIT CHILD SEXUAL ABUSE
(Against All Defendants)
18. Defendants conspired with one another to sexually exploit Plaintiff and other unnamed children, furthering their pedophilic objectives through coordinated access via entertainment venues and private residences.

V. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays for judgment against Defendants, jointly and severally, as follows:

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.

Plaintiff demands a trial by jury on all issues so triable.