Jane Doe And Her Lawsuit Against Leon Black (Part 1) (3/29/26)

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What's up, everyone?

And welcome back to the Epstein Chronicles.

One of the people that was in Epstein 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 23-cv-06418.

Jane Doe, verse Leon Black.

The first amended complaint.

Plaintiff Jane Doe, by and through council, WigDoor, LLP,

alleges against defendant Leon Black or defendant as follows.

One plaintiff Jane Doe, from ages 16 to 19,

had almost no ability to speak out about the horror

she experienced 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 entries

that documented a particularly brutal instance of abuse

by defendant Leon Black.

In the first, she wrote,

walk down Madison Avenue to 71st Street,

my redacted, has lost her fucking mind.

Even though Galaine said it was best to take me home

because Mr. Black is so important for some reason

over my health.

There is going to be hell 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 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 Jeffrey Epstein's Manhattan townhouse located

at 9th East 71st Street, Epstein traffic Jane Doe

to his close friend Leon Black.

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 given 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 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, 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

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 25th, 2023, seeking justice and accountability

for Black's assault over jurisdiction,

venue, and limitations period.

The court has jurisdiction over this matter,

pursuant to US code 28, section 1332.

As this action involves citizens of different states

and the amount and controversy in this matter, exceed 75,000.

The venue is proper in the Southern District of New York,

pursuant to US code 28, section 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, pursuant

to the New York City Victims of Gender-Motivated Violence

Protection Act, VGM VPL, as amended NYC Admin Code,

section 10-1105A, this case is timely.

Parties, plaintiff Jane Doe is over the age of 18

and is a citizen of the US.

Defendantly on black is over the age of 18,

is a citizen of the US and resides in New York.

Factual allegations, plaintiff is autistic.

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 is born with an extra chromosome

in every cell of 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.

Although Miss Doe has an above average IQ,

her developmental age is around 12 years old.

Because Miss Doe is autistic, it's difficult for her

to understand social 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 one factor which places girls with autism

at a substantially increased risk of being sexually assaulted.

Plaintiff was a perfect target for Jeffrey Epstein

and is a complex gland Maxwell.

Epstein and Maxwell sees the Palm plaintiff's developmental abilities

coupled with her outwardly physical appearance, specifically

fair skin, blue eyes, and blonde hair for their own deviant

sexual predation.

Disgustingly, Epstein and Maxwell trafficked Miss Doe to other men

in their circle, including Defendant Black.

Two, plaintiff is trafficked to multiple powerful people,

including Jeffrey Epstein and Galen Maxwell.

During the summer of 2001, Miss Doe signed up for a county

recreational cheerleading program geared towards girls ages 8 to 12.

The program was run by an adult volunteer named Elizabeth

about age 40, who upon information and belief

had no background in cheerleading instruction.

Elizabeth told plaintiff that even though she was 15,

she could participate in a recreational cheerleading

if 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 8 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 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 at never questioned Elizabeth or her parents.

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Plaintiff traveled back and forth between Elizabeth's home

and her parents' home 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 for what Elizabeth had planned.

By a way of example only, Elizabeth violently physically abused plaintiff

by punching and kicking her and even dragging plaintiff

of multiple flights of stairs in her townhouse by plaintiff's ponytail.

Elizabeth's psychologically abused plaintiff by depriving her food and water

and punishing plaintiff any time Elizabeth was dissatisfied with plaintiff's behavior,

which was often, including 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 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 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.

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 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 kept a gun in the house. She told Miss Doe that if she ever told anyone about the

thing 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 violentive conduct 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 going to wrap up part one right here,

and in the next episode, we're going to pick up with three plaintiff is traffic to Epstein and Max

Will. All of the information that goes with this episode can be found in the description box.

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