The Leon Black lawsuit alleging retarded child bleeding out of her ass on the floor due to tools, may have been linked to Charlie and Elizabeth and Andrew. That would explain Balmoral or other estates Elizabeth shared with Epstein, and also SCL's Cambridge Analytica 2016, all Epstein-blackmailed.

And so we believe there is a real case that Epstein blackmailed the global elite to keep himself in power, but that included stalking and destroying the lives of non-billionaire victims, including the Editor of Uprights News, is a reasonable inference based on the corpus of public evidence.

https://www.uprightsnews.com/3147841_smoking-gun-for-blackmail-conspiracy-by-epstein-and-maxwell-a-leaked-email-makes-clear-that-leon-black-was-being-blackmailed-as-a-spigot-expected-to-dry-is-literally-a-reference-to-the-blackmail-of-leon-black-editor-s-former-employer

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------------------------------
JANE DOE,
Plaintiff,
v.
LEON BLACK,

Defendant.
X
:
Civil Action No.
COMPLAINT
Jury Trial Demanded
------------------------------------------------------------- X
Plaintiff Jane Doe,1 by and through counsel Wigdor LLP, alleges against Defendant Leon
Black (“Black” or “Defendant”), as follows:
1. In 2002, at his Manhattan townhouse, 9 East 71st, Jeffrey Epstein executed a “hand
off” to his close friend Leon Black. But what passed directly to Black’s hands from the hands of
Jeffrey Epstein was a human being – not a ball.
2. The human being, Jane Doe, is autistic, and she was 16 when Jeffrey Epstein
introduced her to Black and said she was to give his “special friend Leon Black” the same kind of
massage that she had to give to Jeffrey Epstein when he ordered her to. Even as Black grabbed
her hand so hard that she thought he broke bones, Jeffrey Epstein knew Jane Doe would never
disobey. Developmentally she is about 12, and when she was threatened to do as told because
“bad girls” get in “trouble,” she did as she was told.
3. Black took her to the third floor of the townhouse, to a massage room where she
had been before with Jeffrey Epstein. There, using adult sex toys in her anus and vagina, he raped
1
Plaintiff intends to file a motion to proceed under the pseudonym “Jane Doe” in this case
to protect her privacy because her allegations concern sexual abuse that occurred when she was a
minor. The disclosure of her name in connection with the allegations would cause her further harm
and potentially endanger her safety.
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 1 of 19
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her. His physical force such that when he left her on the floor sobbing, she was bleeding. As set
forth below, Jeffrey Epstein refused to take her to a doctor, and instead said that Ghislaine Maxwell
would take care of it.
4. Sadly, Ms. Doe’s experience is one more in a long line of despicable and heinous
experiences inflicted on a minor trapped in Jeffrey Epstein’s web – a web that extended to a group
of powerful and influential men, including Leon Black.
JURISDICTION, VENUE & LIMITATIONS PERIOD
5. The Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1332, as this
action involves citizens of different states and the amount in controversy in this matter exceeds
$75,000.
6. Venue is proper in the Southern District of New York pursuant to 28 U.S.C. §
1391(b) because a substantial part of the events or omissions giving rise to this action, including
the unlawful sexual assaults alleged herein, occurred in this district, and Defendant resides in this
district.
7. Pursuant to the New York City Victims of Gender-Motivated Violence Protection
Act (VGMVPL), as amended, N.Y.C. Admin. Code § 10-1105(a), this case is timely.
PARTIES
8. Plaintiff Jane Doe is over the age of 18, and is a citizen of the U.S.
9. Defendant Leon Black is over the age of 18, is a citizen of the U.S. and resides in
New York, New York.
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FACTUAL ALLEGATIONS
I. PLAINTIFF IS AUTISTIC
10. Ms. Doe is autistic,
2
and was born with Mosaic Down Syndrome, a rare condition
where only some of the body’s cells contain an extra chromosome (in contrast to an individual
with typical Down Syndrome, who is born with an extra chromosome in every cell in her body).
As a result, while Plaintiff does not appear physically or outwardly different from a neurotypical
individual, she suffers from many of the same neurological disabilities and health issues that are
tragically common among individuals with Down Syndrome.
11. Although Ms. Doe has an above average intelligence quotient (IQ), her
developmental age is around 12 years old.
12. Because Ms. Doe is autistic, it is difficult for her to understand social cues based
on the behavior of people she encounters. To be clear, being able to “read the room,” is an
impossible task. Instead, Plaintiff experiences the world in a child-like way and sees situations in
terms of whether something is “right” or “wrong,” or “good” versus “bad.”
2
According to Dr. Daniel Geschwind, professor of human genetics, neurology and
psychiatry at UCLA, “autism refers to a broad range of conditions characterized by challenges
with social skills and social and communication and repetitive behaviors, resistance to changes in
routine, or restricted interests. … it’s not one thing, and no two autistic children or adults are
exactly alike even though they may share basic features.”
https://www.cnn.com/2023/04/12/health/what-is-autism-explainer-wellness/index.html; the
National Institute of Mental Health describes autism as: “a neurological and developmental
disorder that affects how people interact with others, communicate, learn, and behave. Although
autism can be diagnosed at any age, it is described as a “developmental disorder” because
symptoms generally appear in the first 2 years of life.”
https://www.nimh.nih.gov/health/topics/autism-spectrum-disorders-asd; the American
Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (DSM-5),
states that people with autism often have: difficulty with communication and interaction with
other people; restricted interests and repetitive behaviors; and symptoms that affect their ability
to function in school, work, and other areas of life.
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13. As with most autistic people, she is extremely trusting. Sadly, this is one factor
which places girls with autism at a substantially increased risk of being sexually assaulted.3

14. Plaintiff was a perfect target for Jeffery Epstein and his accomplice Ghislaine
Maxwell.
15. Epstein and Maxwell seized upon Plaintiff’s developmental disabilities, coupled
with her outwardly physical appearance, specifically fair skin, blue eyes and blond hair, for their
own deviant sexual predation.
16. Disgustingly, Epstein and Maxwell trafficked Ms. Doe to other men in their circle,
including Defendant Black.
II. PLAINTIFF IS TRAFFICKED TO JEFFREY EPSTEIN AND GHISLAINE
MAXWELL
13. During the summer of 2001, Ms. Doe signed up for a county recreational program
geared towards girls ages 8-12 interested in cheerleading. The program was run by an adult
volunteer named “Elizabeth,” about age 40, who upon information and belief, had no background
in cheerleading instruction.
14. Elizabeth told Plaintiff that even though she was 15, she could participate in the
recreational cheerleading if she could fit into the uniform, the largest size which was meant for 12-
year-olds.
15. Plaintiff fit into the uniform. Because of her developmental disabilities, the fact
that she was in a cheerleading group with girls as young as eight years old was not a problem for
Ms. Doe. She was happy to be participating.
3
Studies show that girls with autism from ages 9 to 18 years are three times as likely to
experience sexual assault when compared to their neurotypical counterparts.
https://www.psychologytoday.com/us/blog/talking-about-trauma/202209/girls-autism-face-threetimes-the-risk-sexual-assault
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 4 of 19
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16. Elizabeth soon showed Plaintiff extra attention. Not long after she began attending
the cheerleading program, Plaintiff was told by Elizabeth that she was going to live at Elizabeth’s
house several days a week. Of course, Plaintiff’s parents were involved in the living arrangements.
17. As the adults in her life undoubtedly anticipated, Plaintiff did as she was told and
never questioned Elizabeth or her parents.
18. Soon, several days a week turned into most days a week. By the time school started
in the fall, Plaintiff was living nearly full-time with Elizabeth. Little did Plaintiff know what
horrors were ahead for her.
19. From the beginning of her time living with Elizabeth, Plaintiff was subjected to
horrific, unimaginable physical abuse as part of the “training” Elizabeth believed necessary to
prepare her for what Elizabeth had planned.
20. By way of example only, Elizabeth violently physically abused Plaintiff, by
punching and kicking her and even dragging Plaintiff up multiple flights of stairs in her townhouse
by Plaintiff’s ponytail. Elizabeth psychologically abused Plaintiff by depriving her food and water
and punishing Plaintiff anytime Elizabeth was dissatisfied with Plaintiff’s behavior (which was
often), including by locking her a room for hours, making her dress in small children’s clothing
and making her work out for hours at a gym until Plaintiff was too exhausted to stand, often after
denying her any food.
21. Although Ms. Doe had moved in with Elizabeth, she did not have her own bed
there, much less a bedroom. Instead, Elizabeth repeatedly told Plaintiff that she did not “deserve”
her own bedroom in her house and that Plaintiff would not receive one until she “worked for it.”
Sadly, Plaintiff did not understand what Elizabeth meant, but she never questioned anything
Elizabeth did or said, especially because physical violence was something she wanted to avoid.
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22. Elizabeth had a number of sexual partners at the time, including a man who lived
in the same house, as well as other male “friends,” who would visit Elizabeth. One of these men,
“Charlie,” was a white male in his late 40s. Together with Charlie, Elizabeth began sexually
grooming Plaintiff as soon as she started staying overnight with Elizabeth.
23. The sexual grooming included forcing Plaintiff to watch them have sex. Ms. Doe
had never engaged in sexual conduct herself. Again, Plaintiff did everything that Elizabeth and
Charlie told her to do.
24. Horribly, Elizabeth threatened Ms. Doe with the fact that she had a gun permit and
kept a gun in the house. She told Ms. Doe that if she ever told anyone about the things she and
Charlie made her do, that Plaintiff would go “missing,” and since no one loved or cared for her,
she would not be missed. Plaintiff never doubted what Elizabeth told her because her parents told
her to live with Elizabeth.
25. Plaintiff was forced to submit to Elizabeth’s degrading and violative conduct on a
daily basis. She feared being killed and believed everything that Elizabeth said.
26. Saying no to Elizabeth was not an option for Plaintiff. To this day, Plaintiff lives
in fear of Elizabeth and what will happen if Elizabeth ever learns that Plaintiff has found the
courage to tell her story.
III. ELIZABETH AND CHARLIE ARRANGE FOR MAXWELL AND EPSTEIN TO
MEET MS. DOE
27. Sometime in late summer of 2001, Elizabeth told Plaintiff that she was taking her
to what she referred to as an adult “party” in a suburb outside of Washington D.C.
28. Elizabeth and Charlie drove Ms. Doe to a large home, with a circular drive, fountain
and pillars. Plaintiff was told to go inside and she did.
29. The only people inside were adults – mostly men – who seemed “old” to Plaintiff.
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30. She was approached by a woman with dark hair and a British accent, who
introduced herself to Plaintiff and sat with her, feigning interest in her safety and well-being.
31. It was only later that Plaintiff learned that this woman was Ghislaine Maxwell
(“Maxwell”), the convicted sex offender currently in prison serving a 20-year sentence.
32. Maxwell led plaintiff over to a large white couch and took pains to give Plaintiff
the impression that she cared about her and was genuinely interested in what she had to say.
Maxwell seemed to ignore Plaintiff’s natural difficulties in conversing in social settings – her
inability to hold eye contact, her difficulties in picking up on social cues, how much she struggled
to keep up with conversations – and instead focused on making her feel comfortable. As a result,
Plaintiff mistakenly believed that Maxwell truly cared about her.
33. Maxwell spent the conversation lavishing Plaintiff with compliments, referring to
her as “a beautiful darling girl” and said that she was “a beautiful girl with the most beautiful bright
blue eyes, blonde hair and perfect hair” that made her look like a living “doll.”
34. Seemingly already aware of Plaintiff’s developmental disabilities, Maxwell treated
her like a child, holding her hand, bringing her to the bathroom and making her stand right outside
the door so Maxwell could keep talking to her the way mothers do with young children.
35. What Plaintiff did not realize at the time was that Maxwell was merely taking a
page out of what had by then become a well-rehearsed script, making efforts to bond with a
vulnerable young girl so that she would lower her guard by the time Maxwell introduced them to
Epstein. Although she did not know who the man was, Plaintiff noticed the constant looks passing
between Maxwell and a man on the other side of the room throughout the evening.
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 7 of 19
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36. At some point Maxwell brought Plaintiff out to the driveway where Elizabeth and
Charlie were waiting. She told Elizabeth that Plaintiff was a “darling,” a “good girl,” and a
“beautiful girl.”
37. The very next week, Elizabeth put Plaintiff on a private plane from Virginia to Palm
Beach. There she was picked up by a man who drove her in a large SUV to Epstein’s home.
38. Maxwell and Epstein began exposing Plaintiff to their sexual deviance less than an
hour after she first arrived. They placed her in a swivel chair in a hallway outside of their bedroom
and told her to “not move.” She did not move from the chair, but instead turned around and around
in the swivel chair while she listened to them having sex in the next room with the door open.
When they were done, they came out into the hallway, and acted happy and told Plaintiff she was
a “good girl” for staying seated. They then acted as if nothing had happened and took her
downstairs.
39. Quickly, Maxwell showed Plaintiff how to “make Jeffrey happy.” Maxwell held
Plaintiff’s hand the first time she showed her the way to massage Jeffrey and make him ejaculate
through oral sex – both Maxwell and Epstein gave Plaintiff “happy claps” for her brilliant success,
the way parents do with five-year-olds.
40. They made Plaintiff share a bed with them at night so that they could “cuddle” and
Epstein could wrap his arms around both Plaintiff and Maxwell.
41. Sarah Kellen (Kellen), not Maxwell, is the one who taught Plaintiff how to make
“Jeffrey happy” by having sexual intercourse with him.
42. On other occasions, Plaintiff was required to sit on Epstein’s lap with her feet
draped over Maxwell’s legs as Epstein also complimented her about how beautiful she was and
how much he was drawn to her mix of blonde hair and blue eyes and porcelain skin.
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 8 of 19
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43. Epstein often told Plaintiff that she was his “very special girl,” and commented on
her “special innocence.”
44. Most weekends, Elizabeth sent Plaintiff to Epstein and Maxwell – what Elizabeth
referred to as “shipping you out.” Plaintiff was “shipped out” to Palm Beach and to the USVI.
Plaintiff missed countless Fridays and Mondays from her junior year of high school, almost
causing her to fail.
45. Epstein often required Plaintiff to give him massages, and he would strip
completely naked prior to receiving the massage from Plaintiff. Plaintiff, who had turned 16
shortly before first meeting Maxwell, sometimes also was required to remove all of her clothing
before giving Epstein this massage.
IV. THE “HAND OFF”
46. Once Epstein was satisfied that Plaintiff knew how to give him a massage involving
sexual intercourse, which happened quickly, he began what Plaintiff knows as the “hand off.”
47. The “hand off” meant that Plaintiff had to go with any other man (usually a white
male that seemed very “old” to Plaintiff) to give him a massage and have sexual intercourse. The
first several times Plaintiff had to do this took place in Palm Beach and on Epstein’s island in the
USVI.
48. When Plaintiff was shipped back to Elizabeth, Charlie often picked her up from the
airport. Plaintiff feared nothing more than Elizabeth saying that she did not get a “good report”
that Plaintiff had been a “good girl” by Epstein and Maxwell.
49. If Plaintiff had not been a “good girl,” she would be subjected to intensified
physical and psychological abuse by Elizabeth.
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 9 of 19
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50. Before Plaintiff was shipped back, Maxwell, or Sarah Kellen, or another girl named
Nadia, would put an envelope in Plaintiff’s bag. She was told not to touch it. They warned Plaintiff
that the amount of money in the envelope was known, so if Plaintiff removed any, she would be
caught.
51. Plaintiff was not allowed to unpack her own bag when she returned to Elizabeth’s.
This was a task reserved for Elizabeth.
52. One time when an envelope had been placed in Plaintiff’s bag but it was not
completely sealed, even though Plaintiff had not touched the envelope, much less taken cash from
it, Elizabeth subjected Plaintiff to a beating simply because Elizabeth decided she was a “fucking
idiot.”
53. Regularly, Elizabeth would reiterate her threats to kill Plaintiff if she ever discussed
what had happened to her.
54. Plaintiff believed Elizabeth’s claim that no one in the world cared enough for her
to notice if she disappeared. She therefore lived in constant fear of what Elizabeth would do to
her. She never dared to tell anyone and kept silent for years.
V. PLAINTIFF IS TRAFFICKED BY EPSTEIN TO HIS NYC TOWNHOUSE FOR
THE PURPOSE OF BEING HANDED OFF TO LEON BLACK
55. On two occasions, Epstein and Maxwell made Plaintiff stay with them in NYC, at
Epstein’s townhouse located at 9 East 71st Street.
56. Not long after Plaintiff had been trained to give Epstein massages involving sex,
with the assistance of Elizabeth and Charlie, Epstein and Maxwell trafficked Plaintiff across
several state lines, to New York City, to sexually service Epstein and Maxwell and those she was
handed off to.
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57. The first time Plaintiff was made to stay at Epstein’s townhouse, which upon
information and belief was late fall 2001 or winter 2002, she slept in his bedroom, in the same bed
as Epstein and Maxwell.
58. Plaintiff was never allowed to leave any of the residences alone, and certainly not
in NYC, where she had never been before. Yet, one time Epstein and Maxwell took Plaintiff to
what she believed was a theater for ballet but not to see a performance. Instead, Epstein and
Maxwell met with some individuals there, in what seemed like offices behind the stage, and
Plaintiff was introduced to a dancer.
59. Another time during this NYC stay, Maxwell brought Plaintiff to a different,
smaller townhouse, not far away from Epstein’s. Maxwell told Plaintiff that she needed to get a
few things. Upon information and belief, this was Maxwell’s townhouse located at 116 East 65th
Street.
60. In or around late spring of 2002 or early summer, Elizabeth told Plaintiff that she
was being “shipped off” to New York City. She said that Charlie would be driving her to meet
Epstein’s “special friend,” a man named Leon Black. Elizabeth emphasized that Leon Black was
a “very important and special person” to “Jeffrey,” and she threatened Plaintiff that she “better”
receive a “good report” that Plaintiff was a “good girl” for Jeffrey and his important, special friend.
61. Charlie drove Plaintiff to Epstein’s New York City townhouse.
62. There, she was summoned to Epstein. She found him standing with a huge older
man -- Black is 6’ 4” and about 300 pounds. The two men appeared to be having a conversation.
63. Epstein introduced Plaintiff to Leon Black, using his full name, and told her that
Black was “important” and “special” to Epstein. Plaintiff was struck by Black’s immense size.
Plaintiff’s initial impression of Black was that he looked like an “ogre,” and she felt frightened.
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 11 of 19
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64. Plaintiff noticed Black’s bulbous nose and that his face and neck had a number of
skin tags and moles.
65. Epstein told Plaintiff that because she was his “special girl,” he had selected her
specifically to give his “special friend,” Black, a massage.
66. Epstein told Plaintiff that she was to give Black the same kind of “massage
treatment” that she gives Epstein – meaning that it would involve sexual intercourse and she was
expected to strip naked.
67. Black took Plaintiff by her hand, squeezing it so hard that she thought he might
have broken bones, and led her upstairs to a massage room on the third floor of the townhouse.
She had been in the room with Epstein on her prior stay at the townhouse.
68. In the room there were a variety of oils and adult sex toys next to the massage table.
69. Plaintiff assumed that Black would proceed to disrobe before laying down on the
massage table, the way Epstein usually did.
70. Instead, Black picked Plaintiff up and threw her over his shoulder and then threw
her violently down on the massage table on her back, so hard he knocked the wind out of Plaintiff.
She thought the massage table might have broken. She tried to scream but Black placed his hand
over her mouth and leaned over her while ripping off her shirt and under her skirt pulling her
underwear off.
71. Plaintiff was crying and terrified. Black asked her repeatedly what made her
“Jeffrey’s special girl” and throughout the assault called her demeaning, shameful, disgusting
names. Plaintiff was in a complete state of shock because this was nothing like the massages she
had been taught to give Epstein.
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72. She tried to move off the table but Black had her pinned down. Black laughed at
Plaintiff’s futile attempts to escape his grasp, and he asked her if she considered herself “feisty”
and mocked her by claiming that that he wanted Plaintiff to show him why Epstein referred to her
as his “special girl.”
73. Plaintiff could not see, but rather heard Black rummaging among the adult toys
nearby and he roughly snapped her legs apart causing Plaintiff to feel as if her pelvic bone had
been broken. Using the adult toys, Black then penetrated Plaintiff simultaneously in both her
vagina and rectum, using such force that Plaintiff felt tearing in her internal tissue. When Plaintiff
screamed out in agony, Black again covered her mouth with one of his hands.
74. Plaintiff was crying still when Black placed his mouth on her vaginal area. At this
point, Plaintiff realized that struggling would be useless given how much stronger and physically
more massive Black was and instead pleaded with Black to stop as she sobbed.
75. She felt a sharp pain in her vagina, like a hard pinch and she let out a loud scream.
At the scream, Black lifted his head out from under her skirt and she saw blood on his mouth and
she panicked and kicked him with her right leg. Her “kick” landed on his chest, and while it likely
did not hurt him, he was enraged that she struck out at him and he began viciously cursing her.
76. He then called her a “whore” and a “slut,” and picked Plaintiff up off the massage
table and threw her to the floor.
77. Once on the floor, Plaintiff attempted to scramble towards the door but Black
instead grabbed her legs, pulled Plaintiff towards him and she saw blood on the floor which likely
was from her rectum.
78. Black got on top of her. Plaintiff went into shock and began to disassociate, trying
to convince herself that she was somewhere else but the unimaginable pain she experienced
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 13 of 19
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prevented her from even this temporary respite. He continued to violently thrust himself on her
with such force, that she felt he was crushing her pelvic and hip bones.
79. Despite violently thrusting over her with his extreme weight, Black kept telling
Plaintiff to “stay still.” She felt like she could not breathe.
80. When Black appeared to be finished, he grabbed Plaintiff up by her wrists and
slammed her into the wall and watched as she slid down to a sitting position – still crying in fear
and pain.
81. After what seemed like a long time to Plaintiff, Epstein came in and found her still
against the wall and crying. Plaintiff begged Epstein to take her to a doctor because she was in
physical agony and was continuing to bleed but he refused, instead telling her that Maxwell would
take care of her.
82. Epstein summarily handed her towels to clean herself up. He then took her down to
the second floor of his townhouse and told her to wait in a chair. Epstein grew increasingly
frustrated as Plaintiff continued to cry. He demanded that she pull herself together as he was
expecting a visitor. Shortly thereafter, a thin, middle-aged blonde woman arrived at the townhouse
and had folders in her hands which she gave to Epstein. Upon information and belief, this woman
was Leslie Groff, Epstein’s long-time New York based assistant.
83. Although Epstein trafficked Plaintiff to other men, both before and after Black, she
was never again taken to NYC. The violent and sadistic nature of Black’s rape left an indelible
mark on her, both physically and psychologically. Plaintiff suffered internal abrasions in her
rectum that continue to cause her pain.
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84. To this day, Plaintiff often is triggered each month at the beginning of her menstrual
cycle as the sight of blood from her body causes Plaintiff to suffer from panic attacks, reliving the
attack that she endured ay Black’s hands.
85. Although Epstein and Maxwell did not take Plaintiff to the doctor that day, she was
taken to the airport where she went back to Elizabeth’s, with a thick envelope that she was not
allowed to open and required to hand over to Elizabeth.
VI. BLACK’S OTHER VICTIMS THROUGH EPSTEIN
86. Appallingly, Plaintiff is not the only female who Epstein and Black sexually
violated.
87. For example, on March 13, 2023, in the matter of Jane Doe 1, et al. v. Deutsche
Bank Aktiengesellschaft et al., Index No. 22 Civ. 10018 (JSR) (Southern District of New York),
the district court heard oral argument on the defendant’s motion to dismiss. As part of Jane Doe
1’s claims, she had alleged that,
“There came a time when Epstein forced Jane Doe 1 to give massages to his
powerful friends. During some of these massages, Jane Doe 1 was sexually abused
by force and against her will by Epstein’s friends, by whom she had been required
to do massage.”
88. Deutsche Bank introduced a release agreement (“Release”) between Jane Doe 1
and Epstein in support of its motion to dismiss. This Release included a carve out of Jane Doe 1’s
claims against Black, as well as another individual, James (Jes) Staley, a former banker who Black
introduced to Epstein in or around 2000.
89. At oral argument, the portions of the Release were read into the record, including,
in relevant part that:
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While the parties do not believe there is any reasonable
interpretation that this general release could be construed to release
James (Jes) Staley, Leon Black or their respective entity
affiliations. For clarity, this general release and settlement
agreement specifically does not include James (Jes) Staley, Leon
Black or any company or entity which either is or was
beneficially owned or controlled by James (Jes) Staley or Leon
Black as a releasee or released party under this general release and
settlement agreement.
90. Of course, if Black had not engaged in sexual misconduct or other tortious claims
against Jane Doe 1, there would have been no reason to include him in the carve out along with
Jes Staley.
91. On July 21, 2023, the New York Times reported that Black agreed to pay the U.S.
Virgin Islands Office of the Attorney General $62.5 million in order to avoid possible claims
stemming from his relationship with Epstein.4
As reported, Black entered into that settlement
agreement with the Office of the Attorney General in January 2023.
92. Over the last several years, the U.S. Virgin Islands has been conducting extensive
investigations into Epstein’s sex trafficking activities, culminating in a lawsuit against Epstein’s
estate. That lawsuit was settled between the Office of the Attorney General for the U.S. Virgin
Islands and Epstein’s estate in December 2022 for over $100 million.
93. Furthermore, according to the New York Times, “Some victims of Mr. Epstein who
had received settlements directly from his estate were granted permission by the estate’s executors
to pursue claims against a handful of men who had socialized with Mr. Epstein, according to a
person with knowledge of the matter. Mr. Black was one of those men.” It is clear that Ms. Doe
is not the only victim of both Epstein and Black.
4
https://www.nytimes.com/2023/07/21/business/leon-black-settlement-jeffrey-epsteinclaims.html (last visited July 24, 2023).
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 16 of 19
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CAUSE OF ACTION
Victims of Gender-Motivated Violence Protection Law (VGMVPL)
94. Plaintiff hereby repeats and realleges each and every allegation in the preceding
paragraphs as though set forth fully herein.
95. The above-described conduct of Defendant Black, including, but not limited to,
Defendant Black’s sexual assault and rape of Plaintiff constitutes a “crime of violence” and a
“crime of violence motivated by gender” against Plaintiff as defined by the New York City Victims
of Gender-Motivated Violence Protection Act (VGMVPL), as amended, N.Y.C. Admin. Code §
10-1101, et seq.
96. The above-described conduct of Defendant Black, including, but not limited to,
Defendant Black’s sexual assault and rape of Plaintiff constitutes a “crime of violence” against
Plaintiff and is a “crime of violence motivated by gender” as defined in § 10-1103 (“The term
‘crime of violence’ means an act or series of acts that would constitute a misdemeanor or felony
against the person as defined in state or federal law or that would constitute a misdemeanor or
felony against property as defined in state or federal law if the conduct presents a serious risk of
physical injury to another, whether or not those acts have actually resulted in criminal charges,
prosecution, or conviction,” and “The term ‘crime of violence motivated by gender’ means a crime
of violence committed because of gender or on the basis of gender, and due, at least in part, to an
animus based on the victim’s gender.”).
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97. As a direct and proximate result of the aforementioned crime of violence and
gender-motivated violence, Plaintiff has sustained in the past and will continue to sustain,
monetary damages, physical injury, pain and suffering, and serious psychological and emotional
distress, entitling her to an award of compensatory and punitive damages, injunctive and
declaratory relief, attorneys fees and costs, and other remedies as this Court may deem appropriate
damages, as set forth in § 10-1104.
98. The above-described conduct of Defendant Black constitutes a sexual offense as
defined in Article One Hundred Thirty of the New York Penal Law (“Article 130”).
99. Pursuant to § 10-1105(a), this cause of action is timely because it is commenced
within “two years and six months after September 1, 2022.”
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against
Defendant, containing the following relief:
A. A declaratory judgment that the actions, conduct and practices of Defendant
complained of herein violate the laws of the State of New York and the City of New York;
B. An injunction and order permanently restraining Defendant and any and all
persons acting in concert with him, from engaging in any such further unlawful conduct, including
the conduct complained of herein;
C. An award of damages against Defendant, or any jointly or severally liable entity
or person, in an amount to be determined at trial, plus prejudgment interest, to compensate
Plaintiff for all monetary and/or economic damages;
D. An award of damages against Defendant, or any jointly or severally liable entity
or person, in an amount to be determined at trial, plus prejudgment interest, to compensate
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 18 of 19
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Plaintiff for all non-monetary and/or compensatory damages, including, but not limited to,
compensation for her physical injuries and emotional distress;
E. An award of damages for any and all other monetary and/or non-monetary losses
suffered by Plaintiff, including, but not limited to, reputational harm in an amount to be
determined at trial, plus prejudgment interest;
F. An award of punitive damages, and any applicable penalties and/or liquidated
damages in an amount to be determined at trial;
G. Prejudgment interest on all amounts due;
H. An award of costs that Plaintiff has incurred in this action, including, but not
limited to, expert witness fees, as well as Plaintiff’s reasonable attorneys’ fees and costs to the
fullest extent permitted by law; and,
I. Such other and further relief as the Court may deem just and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein.
Dated: July 25, 2023
New York, New York Respectfully submitted,
WIGDOR LLP
By: __________________________
Jeanne M. Christensen

85 Fifth Avenue
New York, NY 10003
Telephone: (212) 257-6800
Facsimile: (212) 257-6845
jchristensen@wigdorlaw.com

Counsel for Plaintiff Jane Doe
Case 1:23-cv-06418 Document 1 Filed 07/25/23 Page 19 of 19