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August 9, 2025 37 mins
The lawsuit filed by Jane Doe against billionaire Leon Black alleges that he raped her at Jeffrey Epstein’s Manhattan townhouse when she was a vulnerable young woman in her early twenties. Filed in 2023 under New York’s Adult Survivors Act, the civil suit claims Black used Epstein’s residence—a known hub of abuse—as the setting for the assault, and that Epstein facilitated the encounter. Jane Doe alleges that she was trafficked and groomed within Epstein’s network and that Black’s actions were part of the larger pattern of abuse and exploitation that Epstein orchestrated for his powerful associates. The lawsuit accuses Black not only of rape, but also of intentional infliction of emotional distress and other civil claims tied to Epstein’s broader trafficking enterprise.

Black has denied the allegations and filed a countersuit against the accuser and her attorneys, claiming extortion and reputational harm. However, the civil complaint against him highlights a critical and recurring theme in the Epstein saga: the deep connections between Epstein and prominent men who allegedly used his network for their own gratification under the guise of friendship or philanthropy. The suit adds to the growing scrutiny of Black’s long-standing ties to Epstein, including previous revelations that he paid Epstein over $150 million for undisclosed “financial advice” long after Epstein’s 2008 conviction. Jane Doe’s case underscores how Epstein’s reach extended well beyond his own crimes, into the lives—and alleged actions—of the elite men he surrounded himself with.



to contact me:

bobbycapucci@protonmail.com



source:

gov.uscourts.nysd.602764.152.0.pdf

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Transcript

Episode Transcript

Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
What's up everyone, and welcome back to the Epstein Chronicles.
One of the people that was in Epstein's circle that
we've talked a lot about is Leon Black. Well, today
we're going to start diving into the lawsuit that was
filed against him by the Jane Doe who has autism.
Case number twenty three DASH CV DASH zero six four

(00:22):
one eight Jane Doe versus Leon Black the first amended
complaint Plaintiff Jane Doe buy and through Council Whigdor LLP
alleges against defendant Leon Black Black or defendant as follows one.
Plaintiff Jane Doe from ages sixteen to nineteen had almost
no ability to speak out about the horror she experienced

(00:45):
as the victim of sex trafficking, particularly because her redacted
and redacted at the time were directly involved in and
responsible for sending her off to men, including Jeffrey Epstein,
for the purpose of sexual exploitation. She was, however, able
to start a journal to document what she was forced
to endure. Two In these journals, she wrote two specific

(01:08):
entries that documented a particularly brutal instance of abuse by
defendant Lyon Black. In the first, she wrote walked down
Madison Avenue to seventy first Street. My redacted has lost
her fucking mind. Even though Glaine said it was best
to take me home because mister Black is so important
for some reason over my health. There is going to

(01:31):
be held to pay. I ruined their trip and I'm
dramatic when that fat fuck bit me. He threw me
on the floor and blood all over Jeffrey's carpet. And
on the issue, who the fuck bites someone sick? No
one is that important and Leon Black can go fuck himself.
I hate New York. In the next journal entry, plaintiff

(01:51):
wrote Leon Black next to a poem she cut and
pasted into the notebook, having underlying words in the poem
such as fatso and millionaire. The horrific incident these entries
reference was a particular day when at Jeffrey Epstein's Manhattan
townhouse located at ninth East seventy first Street, Epstein traffic
Jane Doe to his close friend Leon Black. Jane Doe

(02:14):
is autistic, and she was sixteen 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 given to Jeffrey Epstein when he ordered her too,
even as Black grabbed her hand so hard that she
thought he broke bones. Jeffrey Epstein knew Jane Doe would

(02:34):
never disobey developmentally, she is about twelve, and when she
was threatened to do as she was told, because bad
girls get in trouble, she did as she was told.
Black took her to the third floor of the townhouse
to a massage room where he had been before with
Jeffrey Epstein there, and using adult sex toys in her
anus and vagina, he raped her. He also bit her vagina,

(02:58):
a heinous act. His physical force was 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 Glenn Maxwell would
take care of it. Sadly, Miss Doe's experience is one
more in a long line of despicable and heinous experiences

(03:18):
inflicted on a minor trapped in a web of sexual exploitation,
a web that extended to a group of powerful and
influential politicians and business moguls, including Black and Epstein. Miss
Doe filed the instant lawsuit on July twenty fifth, twenty
twenty three, seeking justice and accountability for Black's assault over jurisdiction,

(03:40):
venue and limitations period. The Court has jurisdiction over this
matter pursuant to US Code twenty eight, section thirteen thirty two,
as this action involves citizens of different states and the
amount in controversy in this matter exceeds seventy five thousand,
the venues proper in the Southern District of New York
pursuant to US Code twenty eight section thirteen ninety one B,

(04:04):
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.
Pursuant to the New York City Victims of Gender Motivated
Violence Protection Act VGMVPL as amended NYC Admining Code Section

(04:25):
ten DASH eleven OZH five A. This case is timely parties.
Plaintiff Jane Doe is over the age of eighteen and
is a citizen of the US. Defendantly On Black is
over the age of eighteen, is a citizen of the
US and resides in New York factual allegations. Plaintiff is autistic.

(04:46):
Miss Doe is autistic and was born with mosaic Down syndrome,
a rare condition where only some of the body cells
contain an extra chromosome, in contrast to an individual with
typical Down syndrome, who was born with an extra chrome
in every cell of her body. As a result, while
plaintiff does not appear physically or outwardly different from a

(05:07):
neurotypical individual, she suffers from many of the same neurological
disabilities and tell tissues that are tragically common among individuals
with Down syndrome. Although Miss Doe has an above average IQ,
her developmental age is around twelve years old. Because Miss
Doe is autistic, it's difficult for her to understand social

(05:27):
cues based on the behavior of people that she encounters.
To be clear, being able to read the room is
an impossible task. Instead, plaintiff experiences the world in a
childlike way and sees situations in terms of whether something
is right or wrong, or good versus bad. As with
most autistic people, she is extremely trusting. Sadly, this is

(05:50):
one factor which places girls with autism at a substantially
increased risk of being sexually assaulted. Plaintiff was a perfect
target for Jeffrey Appstein and his accomplice, Glenn Maxwell. Epstein
and Maxwell seized upon Plaintiff's developmental abilities, coupled with her
outwardly physical appearance, specifically fair skinned, blue eyes, and blonde hair,

(06:11):
for their own deviant sexual predation. Disgustingly, Epstein and Maxwell
traffic Missdoe to other men in their circle, including defendant
Black two. Plaintiff is traffic to multiple powerful people, including
Jeffrey Epstein and Glen Maxwell. During the summer of two
thousand and one, Miss Doe signed up for a county

(06:32):
recreational cheerleading program geared towards girls ages eight to twelve.
The program was run by an adult volunteer named Elizabeth
about age forty, who, upon information and belief, had no
background in cheerleading instruction. Elizabeth told plaintiff that even though
she was fifteen, she could participate in recreational cheerleading if

(06:53):
she could fit into the uniform, which she did 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 Miss doe. She was
happy to be participating. Elizabeth soon showed plaintiff extra attention.
Not long after she began attending the cheerleading program, Plaintiff

(07:14):
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. As the adults
in her life undoubtedly anticipated, Plaintiff did as she was
told and never questioned Elizabeth or her parents. Plaintiff traveled
back and forth between Elizabeth's home and her parents' home

(07:35):
throughout the school year. Little did plaintiff know what horrors
were ahead of her. 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. By way of example,

(07:55):
only Elizabeth violently physically abused plaintiff by punching and kicking her,
and even dragging plaintiff up multiple flights of stairs in
her townhouse by a 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

(08:17):
by locking her in 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. Although Miss
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

(08:40):
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. Elizabeth had a number of sexual partners
at the time, including a man who lived in the

(09:02):
same house, as well as other male friends who would
visit Elizabeth. One of these men, Charlie, was a white
male in his late forties. Elizabeth began sexually grooming plaintiff
as soon as she started staying overnight with Elizabeth. The
sexual grooming included Elizabeth telling plaintiff that she had to
stay close to Elizabeth's bedroom, while Elizabeth then had sex

(09:24):
with men with a door to her room open so
that plaintiff could hear what was happening and see inside
if she tried to. Miss Doe had never engaged in
sexual conduct herself. Again, Plaintiff did everything that Elizabeth and
Charlie told her to do horribly. Elizabeth threatened Miss Doe
with the fact that she had a gun permit and

(09:44):
kept a gun in the house. She told Miss 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, she would
not be missed. Plaintiff never doubted what Elizabeth told her.
Because her parents told her to live with Elizabeth, Plaintiff
was forced to submit to elizabeth degrading and violative conduct

(10:06):
on a daily basis. She feared being killed and believed
everything that Elizabeth said. Saying no to Elizabeth was not
an option for plaintiff. To this day, plaintiff lives in
fear of Elizabeth. All Right, we're gonna wrap up part
one right here, and in the next episode we're gonna
pick up with three plaintiff is Traffic to Epstein and Maxwell.

(10:28):
All of the information that goes with this episode can
be found in the description box. What's up everyone, and
welcome back to the Epstein Chronicles. In this episode, we're
picking up where we left off with the lawsuit filed
against Leon Black by the Doe with Autism three. Plaintiff

(10:49):
is Traffic to Epstein and Maxwell. In two thousand and one,
when Miss Doe was fifteen years old, her adacted took
her to Clearwater of Florida, where she was introduced to
a woman with dark hair and a British accent. During
the meeting, Miss Doe was asked to undress in front
of the woman. It was only later that plaintiff learned
that this woman was Glenn Maxwell Maxwell, the convicted sex

(11:12):
offender currently serving twenty years in prison. Sometime in late
summer of two thousand and one, Elizabeth told plaintiff that
she was taking her to what she referred to as
an adult party in McLean, Virginia, a suburb outside of Washington.
Elizabeth drove Miss Doe to a large home with a
circular drive, fountain and pillars. Plaintiff was told to go inside,

(11:35):
and she did. The only people inside were adults, mostly men,
who seemed old. A plaintiff at this party, she was
approached by Maxwell, who sat with plaintiff and feigned interest
in her safety and well being. At the time, the
plaintiff did not know the woman's name. Maxwell led plaintiff
over to a large white couch and took pains to

(11:55):
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 he struggled to keep
up with conversations, and instead focused on making her feel comfortable.

(12:17):
As a result, plaintiff mistakenly believed that Maxwell truly cared
about her. 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 and that
made her look like a living doll. Seemingly already aware

(12:38):
of plaintiff's developmental abilities, 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.
What plaintiff did not realize at the time was that
Maxwell was merely taking a page out of what had
been a well rehearsed script, making efforts to bond with

(13:02):
a vulnerable young girl so that she would lower her
guard by the time Maxwell introduce 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. At
some point, Maxwell brought Plaintiff out of the driveway where
Elizabeth was waiting. She told Elizabeth that Plaintiff was a darling,

(13:25):
a good girl, and a beautiful girl. In a contemporaneous
journal plaintiff created in two thousand and one, she wrote,
same exact British lady from Clearwater was there. She talked
to me all night. She wants me to come to
her house in Florida so I can learn new things.
She also wrote that perhaps British lady from Clearwater could
get her away from Elizabeth. The very next week, Elizabeth

(13:46):
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. Maxwell and Epstein
began exposing plaintiff to their sexual deviance. Less than an
hour after she arrived. They placed her in a swivel
chair in a hallway outside of their bedroom and told

(14:07):
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 happened and took her downstairs quickly.

(14:28):
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 collapse for her
brilliant success, the way parents do with five year olds.
They made plaintiff engage in sexual acts that night, Epstein

(14:48):
wrapped his arms around both plaintiff and Maxwell, and Maxwell
was affectionate and made plaintiff believe that she cared about her.
Sarah Kellen, not Maxwell, is the one who taught plaintiff
how to make jeffre rehappy by having sexual intercourse with them.
Epstein made plaintiffs sit on his lap with her feet
draped over Maxwell's legs as Epstein complimented her about how

(15:10):
beautiful she was and how much he was drawn to
her mix of blonde hair and blue eyes and porcelain skin.
Epstein often told plaintiff that she was his very special
girl and commented on her special innocence. Elizabeth traffic plaintiff
to other men in addition to Epstein. Numerous times, Elizabeth
sent plaintiff to have sexual interactions with other powerful and

(15:32):
wealthy men in areas not far from Elizabeth and plaintiff's
parents lived. This happened during the school week, causing plaintiff
to miss partial and full days of school. Elizabeth would
refer to this as shipping you out. Elizabeth was not
the only adult to traffic plaintiff during this time. Horribly.
Plaintiff's own redacted and close friends have redacted also shipped

(15:53):
her out to Epstein and Maxwell and other men. Plaintiff
understood that she was expected to have sexual intercourse with
whomever she was sent to. Epstein required plaintiff to give
him massages, and he would strip completely naked prior to
receiving the massage from plaintiff. Plaintiff, who was fifteen or
had just turned sixteen shortly before meeting Maxwell, sometimes also

(16:16):
would require to remove all of her clothing before giving
Epstein his massage. For the handoff. 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 handoff. The handoff meant the plaintiff had to
go with any other men, usually a white male that

(16:37):
seemed very old to plaintiff, to give him a massage
and to have sexual intercourse. Plaintiff had to do this
in Palm Beach and on Epstein's island in the USVII,
it was important that Epstein or any other men did
not complain about Plaintiff to her handlers. Plaintiff feared nothing
more than Elizabeth saying that she did not get a
good report that plaintiff had been a good girl by

(17:00):
Epstein or whichever man she had been sent to. If
plaintiff had not been a good girl, she would be
subjected to intensified physical and psychological abuse by Elizabeth. On
a few occasions, when plaintiff had been sent out to
Epstein and returned to Elizabeth, an envelope was put in
her bag and she was told not to touch it.

(17:21):
Plaintiff was warned that the amount of money in the
envelope was known, so if plaintiff removed any she would
be caught. Plaintiff was not allowed to unpack her own
bag when she returned to Elizabeth. This task was reserved
for Elizabeth. One time, when an envelope had been placed
in plaintiff's bag after having been with Epstein, but it
was not completely sealed. Even though plaintiff had not touched

(17:42):
the envelope, much less taking cash from it, Elizabeth subjected
plaintiff to a beating simply because Elizabeth decided she was
a fucking idiot. Regularly, plaintiff was threatened by her handlers
that she must remain silent. Elizabeth would reiterate her threats
to kill plaintiff if she ever discuss what had happened
to her. Plaintiff believes Elizabeth's claim that no one in

(18:04):
the world cared enough for her to notice if she disappeared.
She therefore lived in constant fear of what would happen
if she ever spoke up about being trafficked, and kept
silent for years. In two thousand and two, plaintiff wrote
in her journal about the multiple powerful men she had
been trafficked to, including Epstein and Black, and mentioned the
various locations where she was trafficked. It doesn't matter how

(18:28):
far away you are, no matter how good you think
you are, even though redacted, they will get you. He
should have been thinking of redacted gross in a plane
on a yacht and n Y in DC at the
vineyard on the island in Palm Beach. It doesn't matter.
Disgusting pigs like redacted and mister redacted and even mister
redacted will hurt you, especially if Golene is busy or

(18:50):
not with you. Five Plaintiff is traffic by Epstein to
his NYC townhouse for the purpose of being handed off
to Leon Black. Not long after plaintiff had been trained
to give Epstein massages involving sex. With the assistance of Elizabeth,
Charlie and other handlers, Epstein and Maxwell traffic plaintiff across

(19:11):
several state lines to Epstein's townhouse, located at ninth East
seventy first Street. Upon information and belief, in late fall
two thousand and one or early winter two thousand and two,
she was brought there and stayed overnight. Plaintiff never left
any of Epstein's residences alone, and certainly not in NYC,
where she had never been before yet. One time, Epstein

(19:34):
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. During this NYC stay, Maxwell brought plaintiff
to a different, smaller townhouse not far away from Epstein's.

(19:56):
Maxwell told plaintiff that she needed to get a few things.
Upon information and belief, this was Maxwell's townhouse, located at
one sixteen East sixty fifth Street. In or around late
spring of two thousand and two or early summer, Elizabeth
told plaintiff that she was being shipped off to New
York City. She said that Charlie would be driving her

(20:17):
from New York City to meet Epstein's special friend, a
man named Leon Black. It was emphasized that Leon Black
was very important and special person to Jeffrey, and Plaintiff
was told that she better receive a good report and
she needed to be a good girl for Jeffrey and
his important special friend. Charlie drove Plaintiff to New York City.

(20:38):
She went to Ebstein's where she was summoned to Ebstein,
who was standing with a huge older man Black at
six y four and about three hundred pounds. The two
men appeared to be having a conversation. Epstein introduced plaintiff
to Leon Black, using his full name, and told her
that Black was important and special to Ebstein. Plaintiff was
struck by blacks men's size. Plaintiff's initial impression of Black

(21:02):
was that he looked like an ogre, and she felt frightened.
Plaintiff noticed Black's bulbous nose and that his face and
neck had a number of skin tags and moles. Epstein
told plaintiff that because she was a special girl, he
had selected her specifically to give his special friend Black
a massage. Epstein told plaintiff that she was to give
Black the same kind of massage treatment that she gives Epstein,

(21:25):
meaning that it would involve sexual intercourse and that she
would be expected to strip naked. Black took plaintiff by
the 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. In the room, there were a

(21:45):
variety of oils and adult sex toys next to the
massage table. Plaintiff assumed that Black would proceed to dis
row before laying down on the massage table, the way
Epstein usually did. Instead, Black picked plaintiff up and threw
her over his shoulder, and then he threw her violently
down on the massage table on her back, so hard
he knocked the wind out of plaintiff she thought the

(22:07):
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. Plaintiff was crying and terrified. Black
asked her repeatedly what made her Jeffrey's special girl, and
threw out the assault, called her demeaning, shameful, disgusting names.

(22:28):
Plaintiff was in a complete state of shock because this
was nothing like the massages she had been taught to
give Epstein. She tried to move off the table, but
Black had pinned her down. Black laughed at the plaintiff's
futile attempts to escape his grasp and asked her if
she considered herself feisty, and mocked her by claiming that
he wanted plaintiff to show him why Epstein referred to

(22:50):
her as a special girl. Plaintiff cannot see, but rather
heard Black rummaging among the adult toys nearby, and he
roughly forced her legs apart, causing play to feel as
if her pelvic bone had been broken, using what, upon
information and belief, was a large dildo. Black then penetrated
plaintiff simultaneously in her vagina and rectum, using such force

(23:13):
that plaintiff felt tearing in the internal tissue. When plaintiff
screamed out in agony, Black again covered her mouth with
one of his hands. 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

(23:33):
with Black to stop. As she sobbed, 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 him, and he began viciously cursing her.

(23:57):
He then called her a fucking bitch, horror and to slut,
and picked plaintiff up off the massage table and threw
her to the floor. Once on the floor, plaintiff attempted
to scramble towards the door, but Black instead grabbed her legs,
pulling plaintiff back towards him, and she saw blood on
the floor, which likely was from her rectum. In his rage,
Black called her a little cunt. Black got on top

(24:20):
of her. Plaintiff went into shock and began to dissociate,
trying to convince herself that she was somewhere else, but
the unimaginable pain that she experienced prevented her from even
this temporary respite. He continued to violently thrust himself in
her with such force that she felt he was crushing
her pelvic and hip bones. Despite violently thrusting over and

(24:41):
over with his extreme weight, Black kept telling plaintiff to
stay still. She felt like she could not breathe. 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 into a sitting position, still crying
in fear and pain. After what seemed like a long
time to plaintif, Epstein came in and found her still

(25:02):
against the wall and crying. Plaintiff begged Epstein to take
her to a doctor because she was in physical agony
and she was continuing to bleed, but he refused. Instead,
he 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 said
that Maxwell would take care of her. Epstein grew increasingly

(25:24):
frustrated as plaintiff continued to cry. He demanded that she
pulled herself together, as 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 he
gave to Epstein upon information and belief. This woman was
Leslie Groff, Epstein's longtime New York based assistant. All right,

(25:46):
we're going to wrap up right here, and in the
next episode we'll pick up where we left off. All
of the information that goes with this episode can be
found in the description box. What's up everyone, and welcome
back to the Epstein Chronicles. In this episode, we're gonna
pick right up where we left off with the Leon
Black lawsuit that was filed by the girl with autism.

(26:11):
As that fourth above, Black's assault of her is detailed
by plaintiff in her contemporaneously kept notebooks. Walk down Madison
Avenue to seventy first Street. My redacted is lost or
fucking mind. Even though Glaine said it was best to
take me home because mister Black is so important for
some reason over my health, there is going to be

(26:31):
hell to pay I ruin their trip and I am dramatic,
And what the fuck that fat fuck bit me? He
threw me on the floor and blood all over Jeffrey's carpet.
And on the issue, who the fuck bites someone sick?
No one is that important? And Leon can go fuck himself.
I hate New York. In a journal entry after the

(26:52):
above one, Plaintiff wrote Leon Black next to a poem
she cut and pasted into the notebook, having underlined the
words in the poems, such as fatso and millionaire. Plaintiff
was trafficked by Elizabeth and others to many other men
both before and after Black. The violent and stadistic nature
of Black's rape left an indelible mark honor both physically

(27:13):
and psychologically. Plaintiff suffered internal abrasions in a rectum that
continue to cause her pain 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 by Black's hands. Six Black's other victims through Epstein

(27:38):
upon information and belief, Plaintiff is not the only female
who Epstein and Black sexually violated. For example, on March thirteenth,
twenty twenty three, in the matter of Jane doe One
versus Deutsche Bank Index number twenty two CIV one zero
zero one eight JSR Southern District of New York, the
District Court heard oral arguments on the defendant's motion today dismiss.

(28:00):
As part of Jane Doe One's claims, she alleged that
there came a time when Epstein forced Jane do One
to give massages to his powerful friends. During some of
these massages, Jane do One was sexually abused by force
and against her will by Epstein's friends, by whom she
had been required to do massage. Deutsche Bank introduced a

(28:21):
release agreement between Jane do One and Epstein in support
of its motion to dismiss. This release included a carve
out of Jane do One's claims against Black, as well
as other individuals James Jess Staley, a former banker who
Black introduced to Epstein in or around two thousand. At
oral argument, the portion of the release were read into

(28:41):
the record, including in the relevant part that while the
parties do not believe there is any reasonable interpretation that
this general release could be construed to release James, Jess Staley,
Leon Black, or their respective entity affiliations. For clarity, this
General Release and Settlement Agreement specifically does not include James,

(29:03):
Jess Staley, Leon Black, or any other company or entity
which either is or was beneficially owned or controlled by
James Staley or Leon Black as a release or release
party under this General Release and Settlement Agreement. Of course,
if Black had not engaged in sexual misconduct or other
tortious claims against Jane do One, there would have been

(29:25):
no reason to include them in the carve out along
with Jess Staley. Additionally, beginning in August twenty nineteen, the
US Virgin Islands conducted extensive investigations into Epstein's ex trafficking activities,
culminating in a lawsuit against Abstein's estate. That lawsuit was
settled between the Office of the Attorney General for the

(29:46):
USVII and Epstein's estate in December of twenty twenty two
for over one hundred million. As part of the usvii's
investigation into Abstein. In August of twenty twenty, Black was
served with subpoenas from the USVII the subpoenas to Black
sought extensive financial documents and tax information relating to Epstein

(30:07):
and entities controlled by Epstein, including Southern Trust, the entity
Epstein used to operate in Little Saint James. In September
of twenty twenty, the NYT New York Times disclosed that
Black had deposited one hundred and fifty eight million in
Southern Trust account between twenty thirteen and twenty seventeen. Thereafter,

(30:28):
Black came under intense scrutiny from Wall Street contingencies and
other interested parties, and in October of twenty twenty, to
help protect Black's reputation, Deckert LLP was retained to investigate
Epstein's ties to Black and to Apollo. Following Deckert's private investigation,
it wrote a report that it filed with the Securities

(30:49):
and Exchange Commission. The Decker report revealed that Black claimed
he paid Epstein one hundred and fifty eight million to Epstein,
who possessed neither a college degree nor any advanced degree
related to tax advisement or a state planning for the
overall value he believed Epstein was providing to him through
Epstein's advice on trust in estate planning, tax issues, philanthropic issues,

(31:12):
and the operation of Black's family wealth management office. According
to the Decor Report, Epstein offered his most valuable piece
of work to Black in twenty twelve, which was advice
related to Black's grantor retained annuity trust that reportedly saved
Black as much as one billion or more and tax liabilities.
Black has never explained why Epstein performed this grat work

(31:35):
other than Paul Wise when the firm provided legal work
for Apollo and Black for decades, and several Paul Wise
partners are considered our nation's top leading tax and estate
planning lawyers. On July twenty one, twenty twenty three, The
New York Times reported that Black agreed to pay the
US Virgin Island's Office of the Attorney General sixty two

(31:55):
and a half million in order to avoid possible claims
stemming from his relationationship with Epstein. Black entered into the
settlement agreement with the USVII on January twentieth, twenty twenty three.
Following mediation. According to The New York Times, some victims
of mister Epstein who had received settlements directly from his
estate were granted permission by the estate's executors to pursue

(32:19):
claims against a handful of men who had socialized with
mister Epstein. According to a person with knowledge of the matter,
mister Black was one of those men. Based on the above,
it's clear that Miss Doe is not the only victim
of both Epstein and Black. The cause of Action Victims
of Gender Motivated Violence Protection Act VGMVPL plaintiff hereby repeats

(32:43):
and realleges each in every allegation in the preceding paragraphs,
as those set forth fully Herein, the above described conduct
of defendant Black, including but not limited to Defendant Black,
sexual assault and rape of plaintiff constitutes a crime of
violence and a crime of violence motive by gender against
plaintiff as defined by the NYC Victims of Gender Motivated

(33:05):
Violence Protection Act VGMVPL, as amended NYC Admin Code, Section
ten eleven oh one. The above described conduct of Black,
including but not limited to Defendant Black, sexual assault and
rape a plaintiff, constitutes a crime of violence against plaintiff
and is a crime of violence motivated by gender, as

(33:27):
defined in section ten eleven O three. The term crime
of violence means an act or a 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 a felony against property as defined
in state or federal law, if the conduct presents a

(33:48):
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 on the
basis of gender, and do at least in part to
an animus based on the victim's gender as a direct

(34:10):
and approximate 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,

(34:34):
attorney fees and costs, and other remedies as this Court
may deem appropriate damages as set fourth in Section ten
Dash eleven oh four. The above described conduct of Defendant
Black constitutes a sexual offense as defined an Article one
hundred and thirty of the New York Penal Law Article
one thirty pursuant to Section ten Dash eleven O five A,

(34:56):
this cause of action is timely because it's commenced within
the two year, years and six months after September one,
twenty twenty two. The prayer for relief Wherefore, a plaintiff
praise at the court enter judgment in her favor and
against defendant containing the following relief. A A declaratory judgment
that actions, conduct and practices of defendant complained of herein

(35:18):
violate the laws of the State of New York and
the City of New York. An injunction and order permanently
restraining defendant and any and all persons acting in concert
with them from engaging in any such further unlawful conduct,
including the conduct complained of here in. An award of
damages against defendant or any jointly or is severally liable

(35:42):
entity or person in an amount to be determined at trial,
plus pre judgment interests to compensate plaintiff for all monetary
or economic damages. An award of damages against defendant or
any jointly or severally liable entity or a person in
an amount to be determined at trial, plus pre judgment
interest to compensate plaintiff for all non monetary and compensatory damages,

(36:06):
including but not limited to compensation for a physical injuries
and emotional distress. An award for damages of any and
all monetary and non monetary losses suffered by plaintiff, including
but not limited to reputational harm, in an amount to
be determined at trial, plus pre judgment interest. An award
of punitive damages and any applicable penalties and or liquidated

(36:30):
damages in an amount to be determined at trial. Pre
judgment interest on all amounts due, 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
attorney fees and costs to the fullest extent permitted by law,
and such other and further relief as the Court deemed

(36:51):
just and proper. Jerry demand. Plaintiff hereby demands a trial
by jury on all issues of fact in damages stated
you're in. This document was dated November seventh, twenty twenty four,
and it was signed by Jeane M. Christiansen from Wigdor
all right, folks, so we're going to be diving deep

(37:12):
into this lawsuit between Leon Black and this Jane Doe
and there's plenty to get to, but that's going to
do it for this one. All of the information that
goes with this episode can be found in the description box.
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