Not long after a woman sued Leon Black, claiming he raped her at sex-trafficker Jeffrey Epstein’s New York townhouse when she was just 16 years old, the billionaire targeted her lawyers with a request for sanctions.
The private equity mogul’s attorneys argue that Wigdor LLP, the firm representing Jane Doe, failed to properly vet her claims, and that Doe’s own family has questioned her accusations and said she “has a long history of dreaming up alternate realities.” (Wigdor denies Black’s allegation.)
While Black’s lawyer Susan Estrich submitted a memorandum in support of sanctions in September, a redacted version of the document was filed to the court docket this week—along with declarations from Black’s private investigator and “Elizabeth,” a former cheerleading mentor of the accuser who is a central figure in Doe’s lawsuit.
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As The Daily Beast reported, Doe’s complaint alleges that Elizabeth groomed her before sending her into the clutches of predator Epstein and his accomplice Ghislaine Maxwell, who then handed her off to Black to be abused in 2002.
According to the suit, Doe’s abuse began soon after she signed up for the then fortysomething Elizabeth’s cheerleading program. The filing alleges that while Doe lived with Elizabeth in high school, the coach and her male partner forced her to watch them have sex.
Now, in a newly unsealed declaration, one of Doe’s former mentors says she believes she’s the “Elizabeth” referenced in the complaint and challenged Doe’s claims as untrue.
“I have never physically, sexually, or psychologically abused Plaintiff,” the woman stated in the court filing, before denying some of Doe’s other claims—including that she threatened Doe with a gun and forced Doe to watch her have sex.
“During the entire time I knew her, Plaintiff never mentioned Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, or Leon Black. I have no reason to believe she has ever met any of them, let alone that she was abused by them as alleged in her Complaint.”
The mentor claimed Doe participated in the cheerleading program as a 16-year-old and “could not have fit into a uniform” for 8- to 12-year-olds as Doe claimed in her suit.
She added that Doe briefly lived with her after graduating high school in 2003, since her home was close to Doe’s college. “To be clear, Plaintiff never lived with me or stayed overnight with me while she was in high school,” the mentor continued.
The woman said that if Doe’s allegations are referring to her, they “are completely untrue.”
In her own legal memorandum filed Wednesday night, Doe’s lawyer Jeanne M. Christensen argued that Black’s use of Elizabeth’s declaration “to try to show that Wigdor failed to reasonably investigate is absurd.”
“As evident by Ms. Doe’s Complaint, the conduct that Elizabeth engaged in could potentially subject Elizabeth to criminal charges,” Christensen stated.
“A self-serving declaration from a person who helped sexually exploit Ms. Doe is not ‘proof’ of anything in connection with Wigdor’s prelitigation due diligence. This is material for Black’s public relations and media outlet tour.”
The sanctions motion, Christensen added, was intended to publicly disseminate the message that Doe’s “allegations are ‘false’ while injecting his own counterstatements of fact…”
Christensen said “the glaring omission of an affidavit from a single person referenced as the ‘family’ and ‘friends’ upon whom [Black’s private investigator] relied to create his conclusions of ‘fact,’ speaks volumes.”
Christensen told The Daily Beast that Black’s motion for sanctions “is a blatant attempt to punish and intimidate our client, who was a minor when she alleges Black violently sexually assaulted her at Epstein’s townhouse.”
“Black wants to punish Wigdor for representing her and he hopes his bullying will deter other lawyers and victims,” Christensen added. “Black shamefully acts as if he is a victim—as if a billionaire who paid Epstein $158 million for purported ‘legal and tax advice’—even though Epstein was a human sex trafficker not a lawyer or tax advisor has nothing to hide.”
Christensen repeated her assertion that Black’s attempt at sanctions were meant to “intimidate and retaliate against” Doe in a Sept. 7 letter to Estrich filed as an exhibit.
“Black’s position that declarations and statements from parties directly opposed to Ms. Doe, including her estranged birth parents, the woman she alleges facilitated her trafficking, and close associates of Jeffrey Epstein, conclusively establishes that her claims are untrue for purposes of Rule 11, would be laughable were it not so reprehensible,” Christensen wrote.
Christensen then referred to an Aug. 25 letter from Estrich, who wrote that references to certain individuals like Epstein’s assistants Leslie Groff and Sarah Kellen were “pure fiction.” Estrich said that Groff’s and Kellen’s representatives informed them that they’d never heard of Doe.
“It is confounding that you are suggesting someone such as Sarah Kellen would admit to doing the things she has been accused of,” Christensen wrote, “especially since such acts may subject her to potential criminal charges.”
“We are fully confident in our investigation and inquiry that was more than reasonable of our client’s claims,” Christensen continued. “Your repeated hyperbolic narrative about Wigdor filing the action ‘recklessly’ or without any factual basis is utter nonsense.”
Still, Estrich told The Daily Beast that the cheerleading coach’s declaration is just one that throws cold water on Doe’s accusations.
“We have said all along that Jane Doe’s claims are false and made up,” Estrich said in a statement. “This declaration, like others which include statements made by family members and friends, confirms that this has been made up and totally fabricated all along.”
Estrich said Black is seeking Rule 11 sanctions, penalties district courts can impose for the filing of frivolous lawsuits, “based on the knowing falsity of these claims.” She added, “This has been an abuse of the legal system and a miscarriage of justice from the get-go.”
Doe’s lawsuit alleges that she is autistic and has a rare condition known as mosaic Down Syndrome, resulting in developmental disabilities and health issues.
“Although Ms. Doe has an above average intelligence quotient (IQ), her developmental age is around 12 years old,” the complaint says, adding that she “was a perfect target for Jeffrey Epstein and his accomplice Ghislaine Maxwell.”
Black’s team has previously suggested that Doe, as an adult, has faked having these medical issues.
In a separate declaration filed by Black, his 83-year-old private eye said he taped interviews with the cheerleading coach, Doe’s parents, sister, aunt, and cousin, as well as high school classmates and others who contradicted Doe’s claims in her lawsuit.
The investigator claims that some of the interviewees told him that Doe has a history of using “different names and personas,” never traveled to Florida, New York, or the USVI while in high school, and didn’t miss school or fail a grade.
Doe’s lawsuit, however, says that Elizabeth farmed her out to Epstein and Maxwell so often—sending her to Palm Beach and the U.S. Virgin Islands—that she failed her junior year of high school.
According to the complaint, Doe first met Maxwell in the summer of 2001 after Elizabeth and her male partner transported her to a party in a Washington, D.C., suburb. The following week, Doe claims, Elizabeth put the teenager on a private plane from Virginia to Palm Beach, where Maxwell and Epstein would train her to sexually service the multimillionaire.
In late spring or early summer of 2002, the complaint states, Elizabeth informed Doe that she would be heading to New York City to meet Epstein’s “special friend” Leon Black. The lawsuit goes on to describe Black allegedly throwing the teen down on a massage table and violently attacking her to the point that she began bleeding.
“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,” the lawsuit says.
Doe isn’t the only person to accuse Black of sexual assault in recent years. Cheri Pierson sued the billionaire last November, accusing him of raping her at Epstein’s Manhattan mansion in 2002, and former model Guzel Ganieva claimed in a 2021 defamation lawsuit that he abused her for years and coerced her into signing an NDA.
All three women were represented by Wigdor LLP, though Ganieva parted ways with the litigation firm before her suit was dismissed two months later.
Black denies the women’s accusations and claimed he was in a consensual relationship with Ganieva before she allegedly extorted him for millions of dollars. He has two pending lawsuits, one alleging malicious prosecution, against Ganieva and Wigdor LLP in New York state court. A third federal suit, accusing Ganieva of conspiring with a former business partner (Apollo Global Management co-founder Josh Harris) to destroy his reputation, was dismissed by a judge who called it “glaringly deficient.”
The litigation underscores how Black’s friendship with Epstein continues to haunt him.
In 2021, Black stepped down as chairman of the Museum of Modern Art and as CEO of Apollo after his firm’s internal review of his ties to Epstein. Apollo’s report revealed that Black paid Epstein $158 million from 2012 to 2017 for financial advice.
In January, Black paid the U.S. Virgin Islands $62.5 million to settle claims related to the government’s probe into Epstein’s trafficking scheme. The New York Times, which first reported on the payout, noted that Black agreed to pay in cash.
