Mega Edition: Leon Black Looks To Expose The Identity Of His Accuser (8/9/25)

In response to the civil lawsuit filed against him under New York’s Adult Survivors Act, Leon Black sought to unmask the identity of his accuser, known in court filings as Jane Doe. Black’s legal team argued that anonymity undermined his ability to defend himself and conduct a fair investigation into the allegations. They filed motions urging the court to compel the woman to publicly reveal her name, claiming that her accusations were damaging his reputation and that shielding her identity placed him at an unfair legal disadvantage. This move was widely criticized by victim advocates, who saw it as a tactic meant to intimidate and discourage other survivors from coming forward, especially in cases involving powerful, well-connected defendants.

Jane Doe’s legal team pushed back forcefully, emphasizing that her anonymity was legally protected under the Adult Survivors Act and critical to her safety and well-being. They argued that forcing her to go public would expose her to harassment, retraumatization, and potential danger. The court initially ruled in her favor, allowing her to proceed under a pseudonym. The broader implications of Black’s attempt to identify his accuser reflect a familiar dynamic in high-profile sexual assault cases—where wealthy defendants use aggressive legal maneuvers to shift the focus away from the allegations and onto the accuser. In the context of Epstein’s network, this tactic is seen as part of a pattern of silencing, discrediting, and outlasting survivors through sheer financial and institutional power.


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Episode Transcript

Speaker 1 (00:00):
What's up everyone, and welcome back to the Epstein Chronicles.
Leon Black is in a battle with his accuser over
her identity and her emotion to remain anonymous as they
battle it out inside of the courtroom. Well, today we're
going to take a look at Leon Black's reply memorandum
of law and further support of his motion to amend

(00:22):
the caption to disclose the plaintiff's name. In other words,
Leon Black wants to put this plaintiff on blast. So
let's see what he has to say for himself. Case
number one twenty three h CV DASH zero six four
one eight Jane Doe, Plaintiff verse Leon Black, the defendant.

(00:44):
Defendant Leon Black's reply memorandum of law and further support
of his motion to amend the caption to disclose the
plaintiff's name preliminary statement. As defendant showed in his opening brief,
the enumerated sealed plaintiff factors overwhelmingly against permitting plaintiff to
continue to proceed anonymously. Most notably, defendant will be significantly

(01:06):
prejudiced if plaintiff is permitted to remain anonymous. Now that
discovery has commenced and plaintiff fails to articulate any counter
availing harm that would warrant her continued anonymity. Moreover, Plaintiff's
own actions indicate that she is more than willing to
be publicly identified in connection with her allegations, and indeed,
she employed various means to amplify her public statements and

(01:29):
attract significant attention without any apparent concern for keeping her
identity confidential. In her opposition brief, plaintiff fails entirely to
show otherwise. She contends that the sealed plaintiff factors are
non exhaustive and should not be applied as a mechanical test,
but nowhere identifies any additional factors the court should consider,

(01:49):
or why it should ignore the factors identified by the
Second Circuit and applied in countless cases in this district
and by this very court. She baselessly cites retaliation as
a reason to maintain her anonymity, but hides the fact
that the defendant already knows Plaintiff's identity, and fails to
identify any retaliation that he has taken or any nonspeculative

(02:11):
risk of retaliation if the public were to learn her name.
She fails to even identify any particularized, nonspeculative harm that
you will suffer if she were to proceed using her
true name, let alone to substantiate or corroborate any such harm.
She unsuccessfully attempts to minimize the prejudice to defend its
ability to conduct discovery and disprove her false allegations, and

(02:35):
she fails to acknowledge and honestly confront her long and
well documented history of making public statements about her supposed
trafficking by Jeffrey Epstein, a subject to which Plaintiff devotes
a substantial portion of her complaint. In short, Plaintiff asks
the court to bless her efforts to her heinous reputation,
destroying fabricated allegations against defendant and innocent third parties from

(02:58):
behind a protective cloes of anonymity, while frustrating Defendant's right
and ability to defend himself. Plaintiff simply is not carried
her burden of showing any privacy interest that outweighs the
clear prejudice to defendant and the strong presumption that litigants
must proceed under their true names. For all of these reasons,
and as discussed in more detail below, and in Defendants

(03:21):
Opening Brief, the Court should grant Defendant's motion to compel
plaintiff to proceed using her true name. The argument, as
explained in Defendants Opening Brief, anonymity is the exception and
not the rule, and the party seeking to proceed anonymously
bears the burden of establishing a privacy interest that outweighs
the strong presumption against anonymity. The Second Circuit has identified

(03:44):
ten factors that should guide this analysis see Seal Plaintiff
for Seal Defendant five point thirty seven, which countless courts
in this district have applied in similar cases. Nine of
the ten factors weigh against anonymity, and Plaintiff has not
shown otherwise. The plaintiff mischaracterizes the governing law. Plaintiff begins
her opposition by asserting that Defendant's entire argument is invalid

(04:07):
because he supposedly treats the non exhaustive list in Seal
Plaintiff as if it is mechanical test. She makes much
of the Second Circuit statements that courts should take into
account other factors relevant to the particular case under consideration,
but never identifies any other factors the court should consider
here at the same time, she declares that the Court

(04:29):
need not consider certain of the enumerated seal plaintiff factors
because they are non relevant. In doing so, Plaintiff wrongly
conflates the question of how to weigh the factors with
whether to consider the factors at all. Moreover, Plaintiff never
explains why the factors she seeks to exclude are not relevant,
other than that they all weigh against anonymity. Here, effectively

(04:52):
conceding the points. Ultimately, Plaintiff concedes, as she must, that
the ten seal plaintiff factors are the established guidelines in
this circuit for assessing all party's request for anonymity, and
offers no reason why this Court should depart from those guidelines.
Defendant will be prejudiced in discovery if Plaintiff's anonymity continues.

(05:13):
Plaintiff places great weight on the timing of Defendant's motion, implying,
but stopping short of seriously contending, that defendant was required
to make his motion as soon as he became aware
of evidence inconsistent with his previous position on Plaintiff's request
for anonymity. Of course, the governing law imposes no such requirement,
and indeed plaintiff herself acknowledges that the right to proceed

(05:36):
anonymously can be challenged at any time in the litigation.
She further contends that defendant faces no greater prejudice now
than he did a year ago, and only filed the
instant motion at this stage to retaliate against plaintiff, as
there is no reason for defendant to be raising this
motion at this time. But of course there is a
well established good reason, as this court is recognized the

(05:59):
prejudice to a defendant in fact at its greatest now
that this case is proceeding to discovery. See Doe versus
Colms Number twenty three Sieve ordering that plaintiff, represented by
Wigdor could not proceed anonymously, but staying the effect of
the order until the case proceeded to discovery, because the
prejudice to defendants and is at its greatest if this

(06:22):
matter were to proceed to discovery. Contrary to Plaintiff's assertions,
the timing of defendant's motion is not indicative of malicious intent,
but rather of the particular and heighten need for disclosure
of plaintiff's identity at the current stage of litigation. Defendant
became aware of plaintiff's prior public statements as early as
December of twenty twenty three, and indeed Defendant discussed these

(06:44):
statements at length in his motion seeking his stay of discovery. However,
Defendant did not object the plaintiff's anonymous status at the
time because he believed that there was a strong possibility
that his motion to dismiss would be granted, rendering the
issue moot see Calms twenty twenty four w L. Eight
six three seven five at six. If the court were

(07:06):
to dismiss this action, it would do so for a
purely legal reason, where plaintiff's identity is irrelevant to that decision. Furthermore,
because discovery did not proceed while defendant's motion to dismiss
and motion to stay discovery were pending, the prejudice to
defendant flowing from plaintiff's anonymous status was lessened. Plaintiff wrongly
contends that it is only now that discovery must proceed

(07:29):
that defendant believes this evidence justifies challenging plaintiff's anonymity in
this lawsuit. To the contrary, defendant has long known that
plaintiff is not entitled to proceed anonymously, not least because
of her prior public statements about the allegations in her complaint,
but commencement of discovery brought the issue to a head
and made immediate defendants concerns that he would be prejudiced

(07:51):
in discovery by the asymmetry in fact gathering resulting from
plaintiff's anonymity. That prejudice is hardly hypothetical. Cannot conduct effective
third party discovery without running a foul of the court's
order allowing plaintiff to proceed anonymously. For example, plaintiff alleges
that she miss countless Fridays and Mondays from her junior

(08:13):
year of high school, almost causing her to fail. In
order to properly test these allegations, which plaintiff's family members
have denied, Defendant must require attendance and academic records from
the school's plaintiff attended, which necessarily requires disclosing plaintiff's name
so that the school can search for and locate those records. Similarly,
defendant cannot effectively obtain information from individuals who new plaintiff

(08:38):
during the time period in which he alleges to have
been trafficked, or medical records or information concerning the damages
plaintiff seeks in this lawsuit. Without identifying plaintiff, defendants simply
would be unable to defend himself against these life ruining accusations.
If plaintiff is permitted to remain anonymous see Doe versus

(08:58):
Combs Number twenty four or Sieve eight zero five to
four two zero two four WOL four to six three
five three zero nine at five SDN Y, October thirtieth,
twenty twenty four. If damaging information about one side is
aired through the litigation, defendants cannot mitigate the damage to
their reputations. This concrete and undeniable prejudice to defendant weighs

(09:21):
strongly against plaintiffs continued anonymity. And you can already see
how this Calm's case is bleeding into Leon Black's case.
And that's how it works with these kinds of issues
in the court. There's going to be a lot of
reference one way or the other. And that's because the
courts love precedent. Part three, Plaintiff alleges nothing more than
speculative and generalized harm to herself for third parties if

(09:43):
she discloses her real name in her opposition. Plaintiff asserts
that she must remain anonymous in order to prevent further
harm to herself and innocent third parties, namely members of
her family redacted. But plaintiff fails to even identify, let
alone substanti when she ate any specific or particularize mental

(10:03):
or physical harm she will suffer if she is identified publicly. Instead,
plaintiff offers only speculative, generalized claims of harm, mischaracterizes both
defendants arguments and the governing law, and basically misconstrues defendants
ordinary and absolutely necessary given the allegations investigative efforts as

(10:23):
evidence that he will use her identity to harass or
retaliate against her or her family. Again, these claims are
entirely unfounded, especially considering defendant already knows Plaintiff's identity and
has not inflicted any such harm to date. Plaintiff first
contends that defendant has used his wealth and influence to
her harasser and her family, and asserts that disclosing her

(10:46):
identity will only enable him to amplify those efforts. Specifically,
she complains that defendant has employed private investigators to contact
members of her biological family and her former classmates, but
what she describes as prior threats or nothing more than
ordinary investigative tactics intended to gather facts about Plaintiff's credibility

(11:06):
and the validity of her claims. Defendants trained and certified
investigator contacted these individuals not to intimidate them, but to
gather information, and was able to do so because the
individuals willingly cooperated and answered his questions, confirming on the
record and in consensually recorded interviews that they were speaking

(11:27):
with the investigator voluntarily and with no coercion or inducement. Indeed,
plaintiff accuses defendant of going so far as to imply
that she has somehow made up the fact that she
has autism, but that is based in part on defendants
accurate recitation of what defendant's investigator was told by plaintiffs

(11:47):
biological family. All right, we're going to wrap up right here,
and then the next episode we're going to pick up
with more fundamentally. All of the information that goes with
this episode can be found in the description box. What's
the everyone, and welcome back to the Epstein Chronicles. In
this episode, we're picking up where we left off with
Leon Black in his attempt to pierce the shield of

(12:10):
his accusers anonymity. More fundamentally, plaintiff offers nothing in support
of her bear assertion that disclosure of her identity would
allow defendant to instigate third parties to cause plaintiff and
her family harm Opposition at eight. All of these supposed
examples of retaliation and harassment she falsely cites involved defendant

(12:32):
or his agents, all of whom already no plaintiff's identity.
Plaintiff gives no explanation other than anidotes about other individuals,
of why she is at risk of retaliation or a
backlash from the general public. As for her assertion that
defendant has a history of retaliation and intimidation, plaintiff relies
primarily on a case in which defendants malicious prosecution claim,

(12:55):
which was brought against the very same lawyers who filed
this case, was the state over plaintiff Council's motion to
dismiss see Black Verseknavilla. Plaintiff's concerns about the well being
of her family members are shocking given that redacted see
ECF document number ninety two through two one in two
twenty six, thirty four, thirty seven, fifty seven, and ninety

(13:18):
eight no doubt In response to the fact that these
family members gave truthful information to defendant that destroys Plaintiff's
claims see ECF Document number fifty two, eight, ten, eleven,
and thirteen redacted. These are not the actions of one
who is genuinely concerned about the shielding of her or
her own family member's identities in a highly publicized case.

(13:40):
To assert that defendant cannot utilize the same information in
his own discovery efforts is not only hypocritical but deeply prejudicial.
If plaintiff insists on involving her family in this litigation,
defendant must be allowed to identify her and them. Plaintiffs suppose.
Concern about bringing non parties into theation is similarly disingenuous,

(14:02):
given that plaintiff is issued subpoenas to numerous individuals and
institutions with no ties to the allegations in the complaint,
many of which do not even mention either party to
this action. Plaintiff next contends that she is not required
to submit evidence to substantiate and corroborate her alleged arm.
In doing so, plaintiff ignores decisions from this court and

(14:24):
numerous others looking for corroboration from medical professionals that detail
the risk to plaintiff Combs twenty twenty four WL eight
six three seven five at three. Moreover, even if supporting
affidavits are not required, something more than mirrors, speculation and
broad conclusion plainly is ceg Dover Skyline Autos Incorporated. Three

(14:47):
seventy five f Dot supp three D four oh one
four oh six SDNY twenty nineteen, Combs two zero two
four WL four six three five zero nine at two
and three. Plaintiff fails to clear even that bar. Instead,
plaintiff asserts that as an alleged rate victim, she will

(15:07):
obviously be re traumatized and suffer untold psychological harm if
her identity is disclosed. But all she offers in support
are statistics regarding assault victims reluctant to speak publicly about
their experiences, and examples of victims and families who have
been arrassed by their alleged attackers. While those reports are
certainly upsetting, they are insufficient to establish any harm or

(15:32):
a threat of harm particular to plaintiff that justifies continued anonymity.
See Dovevers Intel Corporation Number twenty four CIV sixty one,
seventeen twenty twenty four, WL four fifty five three nine
eighty five at three and four. SDNY October twenty second,
twenty twenty four, Combs twenty twenty four w L four

(15:53):
sixty three five three zero nine at two and three.
Plaintiff's alleged membership in a particular the group is not enough.
She must show a real risk of harm that is
more than speculative in nature, based on direct evidence linking
disclosure of her name to a specific physical or mental
injury or threat thereof Intel Corp. Twenty twenty four, WL

(16:16):
four five five three nine eight five at three and four.
Citation and quotation omitted, Part four. Plaintiff mischaracterizes her prior
public statements on this matter. Plaintiff has, on multiple occasions
falsely represented to defendant and this Court that she has
kept her identity confidential, including her council's prior certification that

(16:37):
Plaintiff has not spoken publicly about the incidents that underlie
the causes of action in her complaint see ECF Doc
at number seven and eighteen. In fact, is documented in
defendants opening brief. Plaintiff frequently posted on Twitter that she
survived a ledge trafficking by Epstein, including for example, tweeting

(16:58):
that she was redacted. Plaintiff also introduced herself as a
survivor or victim of Epstein dozens of times during Twitter
spaces events attended by thousands of viewers. Despite being confronted
with her own public statements, Plaintiff doubles down on our
opposition in her opposition, flatly declaring that none of her
social media posts discussing her alleged trafficking by Epstein concerned

(17:21):
the allegations made in this case. The post never mentioned
the incidents detailed in the complaint, and plaintiff has never
publicly disclosed the allegations that she has made in this case.
Opposition at seventeen, emphasis and original. These representations are categorically
and knowingly false and do not tip the seven sealed

(17:42):
plaintiff factor whether the plaintiff's identity has thus far been
kept confidential to favor anonymity five point thirty seven ft
three d at one ninety See motion at eleven and twelve.
While it's true that plaintiff alleged trafficking by Epstein, who
is deceased, does not form the basis for any causes
of action in the complaint, Plaintiff intentionally places Epstein at

(18:05):
the center of her complaint. The complaint contains more references
to Epstein than to defendant and redacted, despite the fact
that mister Black is the sole defendant in this action.
Plaintiff repeatedly and in great detail alleges in her complaint
that she was trafficked to and by Epstein, and that
such trafficking is what led to her alleged assault by

(18:26):
defendant CEECF Document number one sixteen, forty four and forty five,
fifty six, sixty through sixty six, and eighty three. Plaintiff's
numerous public declarations that she was trafficked by Epstein undeniably
relate to these allegations for purposes of this motion. Here again,
plaintiff seeks to have her cake and eat it too.

(18:49):
She filled the complaint with irrelevant Epstein references to garner
attention and sensationalize her claims. Yet now she argues that
these same allegations are not relevant to her claims in
this lawsuit. But plaintiff made these irrelevant allegations and put
them in the complaint and cannot now protest that are
public statements about those allegations should not weigh against her

(19:11):
continued anonymity, as detailed in the defendants opening brief. Plaintiff
also discussed the specific allegations against defendant by name with
at least two individuals she knew only through social media.
They should also not be used as a basis to
voice a host of irrelevant, harassing, and burdensome discovery on
defendant and third parties. Mister Black is mentioned in less

(19:34):
than seventeen percent of their requests seventy one of four
hundred and nineteen, including the subpoenas ducas Teckham that the
plaintiff has noticed to date Quinn Declaration at five. On
the other hand, the subpoenas or rife with references to Epstein,
his cohorts, and various businesses and political leaders, including former
President Clinton, two United States senators, two former cabinet officers,

(19:58):
several owners of professional sports franchises in Washington, d C.
And the Hall of Fame football coach that appear to
be pulled from the conspiracy theory, laced recesses of the
dark web, and are completely irrelevant to the allegations against
mister Black. Although she shared these details and direct messages
rather than public posts, there is no evidence that plaintiff

(20:20):
received assurances of confidentiality from either individuals, both of whom
were virtual strangers to her, and in fact readily shared
this information with investigators. See Rap. Five thirty seven f.
Dot supp three d at five twenty nine. Accordingly, plaintiff's
public statements weigh strongly in favor of disclosing her identity.

(20:41):
Part five Plaintiff is not particularly vulnerable to the harms
of disclosure. Defendant previously showed that plaintiff is not particularly
vulnerable to the possible harms of disclosure Seal Plaintiff five
thirty seven Ft three d at one ninety, because even
if the conduct alleged in the complaint occurred when plaintiff
was a minor, plaintiff is now an adult Motion at sixteen.

(21:03):
In her opposition, Plaintiff acknowledges that courts in this district
have only treated this factor as favoring anonymity when plaintiff
is a minor at the time the lawsuit is brought.
See Opposition at fourteen, citing Wrap five thirty seven Ft.
Supp three d at five point thirty, Combs at twenty
twenty four Wl eight sixty three seven five at four

(21:26):
but plaintiff wrongly asserts that this factor weighs in favor
of anonymity in this case because she alleges that she
is developmentally about twelve years old and currently has the
emotional characteristics of a twelve year old. Put differently, plaintiff
contends that her legal age is irrelevant here because her
alleged disabilities make her vulnerable and exactly the way a

(21:48):
child would be, and therefore her disabilities place her squarely
into the class of persons the fourth factor aims to protect,
but that simply is not the law, and plaintiff does
not point to even a single case a dot opting
her reasoning. Moreover, if, as plaintiff alleges, she is so
developmentally and neurologically disabled that she should be considered the

(22:09):
legal equivalent of a child, then her allegations raise serious
questions about whether plaintiff is even competent to bring this
action on her own see if that r CIVP. Seventeen
C A minor or an incompetent person may bring suit
only through a general guardian, committee, conservator, fiduciary, next friend,
or guardian ad litum. Of course, plaintiff and her counsel

(22:31):
have never sought to go this route, which speaks volumes
conclusion for the foregoing reasons, and is set forth in
the opening brief. Defendant respectfully requests that the Court grant
this motion and amend the caption to disclose Plaintiff's name.
This document was dated November fourth, twenty twenty four, and
it was signed by Daniel Perry. All of the information

(22:53):
that goes with this episode can be found in the
description box.