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Angela Dyborn Filed Complaint
Angela Dyborn Filed Complaint
19 Plaintiff, COMPLAINT
20 v.
21 ANGELA DYBORN,
22 Defendant.
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29 April Telek v. Angela Dyborn, Case No. 2:20-cv-10664
COMPLAINT
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Case 2:20-cv-10664-MWF-RAO Document 1 Filed 11/23/20 Page 2 of 12 Page ID #:2
1 COMPLAINT
2 This is a civil action for damages, under Canadian law, brought by Plaintiff
3 April Telek, arising from Defendant Angela Dyborn’s (“Defendant” or “Dyborn”)
4 joint participation, aiding and abetting, and conspiring to sex traffic Plaintiff April
5 Telek to Peter J. Nygard (“Nygard”). Defendant Angela Dyborn has been a key co-
6 conspirator with Peter Nygard for decades, and has been a key cog in his vast sex
7 trafficking network. Angela Dyborn has been instrumental in knowingly aiding,
8 abetting, facilitating, conspiring, and participating in Nygard, Nygard Inc., Nygard
9 International Partnership (“Nygard International”), Nygard Holdings Limited’s
10 (“Nygard Holdings”), and Tan Jay International’s (collectively, the “Nygard
11 Companies”) sex trafficking conspiracy. Defendant lured, enticed recruited
12 harbored, provided, solicited and transported Plaintiff April Telek to Nygard’s
13 residence and caused and conspired for her to be raped and/or sexually assaulted by
14 Nygard. Defendant has also paid many other victims hush money, as well as
15 transporting them to receive abortions and get medical treatment for sexually
16 transmitted diseases. And since the Nygard Companies have gone into receivership,
17 Defendant Dyborn has actively conspired after the fact with Nygard to steal and hide
18 assets.
19 INTRODUCTION
20 1. As detailed in Jane Does Nos. 1-57 v. Nygard, et al., No. 20-cv-01288
21 (ER) (June 10, 2020) (Ramos, J.), John Does 1 and 2 v. Nygard, et al., No. 20-cv-
22 06501 (ER) (August 16, 2020) (Ramos, J.), and Jane Doe v. Suelyn Medeiros, No.
23 20-cv-24357 (SDFL Oct. 22, 2020) (Martinez, J.), Nygard and the Nygard
24 Companies perpetrated a decades-long, international sex trafficking ring that lured,
25 enticed, and coerced countless girls, women, and boys to be raped.
26 2. For decades, Defendant Angela Dyborn has conspired with Nygard, her
27 uncle, and countless others, by knowingly and actively recruiting young women for
28 him to rape as part of his sweeping international sex trafficking venture.
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April Telek v. Angela Dyborn, Case No. 2:20-cv-10664
COMPLAINT
Case 2:20-cv-10664-MWF-RAO Document 1 Filed 11/23/20 Page 3 of 12 Page ID #:3
1 could travel with Nygard and he could rape and/or sexually assault her.
2 12. Dyborn also serves as an officer of a number of U.S. companies owned
3 and operated by Nygard, including, without limitation, Brause Investments, Inc.,
4 Colorado Wellness Research LLC, Dragyn Industries LLC, Edison’s Investments
5 Inc., Fashion Ventures Inc., Future Med Consulting LLC, Health Wellness Holdings
6 LLC, NBH LLC, and co-conspirator, Nygard Inc. In that capacity, she has actively
7 assisted Nygard and Greg Fenske to defraud other owners and investors by illegally
8 transferring assets and funds.
9 13. For her services of recruiting women for Nygard to rape, Dyborn was
10 paid extensively in cash and benefits by the Nygard Companies, including a full-
11 time salary, travel, lodging and food.
12 14. On information and belief, Dyborn also skimmed funds from Nygard
13 by diverting cash to herself.
14 II. Angela Dyborn Knowingly Lured April Telek to Winnipeg to be Raped
by Peter Nygard.
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16 15. In 1993, April Telek was working as a model and was an acquaintance
17 of Dyborn and her brother, Kris Nichol. April Telek and Angela Dyborn are pictured
18 here together:
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April Telek v. Angela Dyborn, Case No. 2:20-cv-10664
COMPLAINT
Case 2:20-cv-10664-MWF-RAO Document 1 Filed 11/23/20 Page 5 of 12 Page ID #:5
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12 16. Dyborn falsely told April Telek, as a means to lure and entire her to
13 meet with Nygard, that Nygard wanted her to model the Nygard Companies’
14 “Signature Line.”
15 17. Dyborn then arranged for Nygard to call April Telek. During that call,
16 Nygard told April Telek that he wanted her to model for the Nygard Companies.
17 But that was not his real intention.
18 18. For decades before and after his rape of Plaintiff, Nygard and his
19 accomplices lured and enticed his victims to meet with Nygard by falsely telling
20 them that they would be models for the Nygard Companies.
21 19. The real purpose, however, was to deliver the victims to Nygard so that
22 he could rape and/or sex traffic them. April Telek was no exception.
23 20. After Dyborn arranged for a telephone call between Nygard and
24 Plaintiff, Nygard told April Telek that he wanted her to travel to Winnipeg, Canada
25 for a meeting to discuss modeling for the Nygard Companies and that his secretary
26 would contact her with the details.
27 21. The Nygard Companies paid for April Telek to travel to Winnipeg,
28 Canada.
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April Telek v. Angela Dyborn, Case No. 2:20-cv-10664
COMPLAINT
Case 2:20-cv-10664-MWF-RAO Document 1 Filed 11/23/20 Page 6 of 12 Page ID #:6
1 22. April Telek was told that she would be staying at the Nygard
2 Companies’ “Executive Suites.”
3 23. Dyborn picked April Telek up from the airport when she arrived in
4 Winnipeg, knowing that Nygard intended to rape and/or sexually assault her.
5 24. Dyborn drove April Telek to the Nygard Companies’ Notre Dame
6 factory in Winnipeg, Canada to meet Nygard.
7 25. Nygard arrived with his chauffer and told April Telek that she was
8 “better than I remember!”
9 26. Dyborn abandoned April Telek at the warehouse, knowing that Nygard
10 intended to rape and/or sexually assault her.
11 27. April Telek began to panic as she realized that she was not staying at
12 the Nygard Companies “Executive Suites,” as she was promised.
13 28. Once he was alone with April Telek, Nygard locked the apartment and
14 prevented her from leaving.
15 29. Nygard held April Telek against her will at the apartment for
16 approximately two days.
17 30. Nygard drugged, raped, and sexually assaulted April Telek repeatedly
18 during that time.
19 31. Eventually, April Telek managed to escape the apartment when Nygard
20 fell asleep.
21 32. After the attack, April Telek described the assault to Dyborn.
22 33. Dyborn responded, “I watched the tape; you didn’t fight that hard.”
23 III. Dyborn Knowingly Benefitted from Conspiring in the Nygard Sex
Trafficking Venture and Continues to Conspire with Nygard After the
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Fact to Lie about their Sex Trafficking Venture.
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26 34. In exchange for Dyborn’s knowing participation and conspiracy in
27 Nygard’s sex trafficking venture, Nygard pays Dyborn a salary and provides other
28 benefits such as travel and lodging.
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April Telek v. Angela Dyborn, Case No. 2:20-cv-10664
COMPLAINT
Case 2:20-cv-10664-MWF-RAO Document 1 Filed 11/23/20 Page 7 of 12 Page ID #:7
1 located in California.1
2 45. Dyborn also serves as a corporate officer of co-conspirator, Nygard Inc.
3 COUNT I
4 JOINT PARTICIPATION AND/OR AIDING AND ABETTING IN
VIOLATION OF CANADIAN LAW
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6 46. Plaintiff realleges and incorporates by reference the allegations
7 contained in paragraphs 1-45, as if fully set forth in this Count.
8 47. Defendant jointly participated, aided and abetted, facilitated, and
9 enabled Nygard’s rape and/or sexual battery of April Telek, in violation of Canadian
10 Law.
11 48. Defendant knew that Nygard’s conduct constituted a breach of duty
12 and/or tortious conduct.
13 49. Defendant, pursuant to a common design, knowingly participated in the
14 commission of tortious conduct and/or gave substantial assistance or encouragement
15 to Nygard to commit a breach of duty and/or tortious conduct.
16 50. Defendant knowingly participated and gave substantial assistance to
17 Nygard in accomplishing his breach of duty and/or tortious conduct and the
18 Defendant’s conduct, separately considered, constitutes a breach of duty to April
19 Telek.
20 51. Defendant had actual knowledge that she was participating in,
21 facilitating, aiding and abetting, and enabling Nygard’s use of the Nygard
22 Companies’ resources and brand to commit sexual assault and/or sexual battery
23 against April Telek.
24 52. Despite such knowledge, Defendant participated in, facilitated, and
25 aided and abetted Nygard’s sexual assault and/or sexual battery of April Telek.
26 53. Defendant participated in, facilitated, and aided and abetted Nygard’s
27 rape and/or sexual battery of April Telek because she believed that she would be
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Jane Does Nos. 1-57 v. Nygard, et al., No. 20-cv-01288 (ER) (June 10, 2020) (Ramos, J.).
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April Telek v. Angela Dyborn, Case No. 2:20-cv-10664
COMPLAINT
Case 2:20-cv-10664-MWF-RAO Document 1 Filed 11/23/20 Page 9 of 12 Page ID #:9
2 Greg G. Gutzler*
3 DICELLO LEVITT GUTZLER
LLC
4 444 Madison Avenue, Fourth Floor
5 New York, New York 10022
Tel.: 646-933-1000
6 [email protected]
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Mark A. DiCello*
8 Robert F. DiCello*
9 Justin J. Hawal*
DICELLO LEVITT GUTZLER
10 LLC
11 7556 Mentor Avenue
Mentor, Ohio 44060
12 Tel.: 440-953-8888
13 [email protected]
[email protected]
14 [email protected]
15
Lisa D. Haba*
16 THE HABA LAW FIRM, P.A.
17 1220 Commerce Park Dr., Ste. 207
Longwood, Florida 32779
18 Tel.: 844-422-2529
19 [email protected]
Counsel for Plaintiff
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* Pro Hac Vice applications pending
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April Telek v. Angela Dyborn, Case No. 2:20-cv-10664
COMPLAINT