Jane Doe And Her Lawsuit Against Leon Black (Part 1)

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 23-cv-06418. Jane Doe,

verse Leon Black, the first amended complaint.

Plaintiff Jane Doe, by and through Council Wig Door, LLP, alleges against defendant Leon Black,

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,

walked 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

to his close friend Leon Black. Jane though 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 though 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 Blacks' all-dover jurisdiction venue and limitations period. The court has jurisdiction

over this matter pursuant to U.S. Code 28, Section 1332. As this action involves citizens of

different states and the amount in controversy in this matter exceeds 75,000.

The venue's proper in the Southern District of New York pursuant to U.S. Code 28,

Section 1391.B because a substantial part of the events or omissions giving rise to this action

including the unlawful sexual assault 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 the citizen of the U.S.

Defendantly on Black is over the age of 18 is the citizen of the U.S. 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 seized upon 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 Golan 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 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,

and never questioned Elizabeth or her parents.

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 the

private or 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 dressed 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 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.

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 Maxwell. All of the information that goes with

this episode can be found in the description box.