Leon Black And The Motion To ID His Accuser (Part 2) (9/6/26)

0:00What's up everyone and welcome back to the Epstein Chronicles. In this episode we're picking up where we left off with Leon Black and his attempt to pierce the shield of his accusers anonymity. More fundamentally, plaintiff offers nothing in support of her bar 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 are retaliation and harassment. She falsely cites involved defendant or his agents, all of whom already know plaintiffs identity. Plaintiff gives no explanation other than anecdotes 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 which was brought against the very same lawyers who filed this case was sustained over plaintiff counsel's motion to dismiss. See, Black vs. Gonevia. Plaintiff's concerns

1:06about the well-being of her family members are shocking. Given that redacted, see ECF document number 92 through 2, 1 in 2, 26, 34, 37, 57 and 98. 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 52, 8, 10, 11 and 13 redacted. These are not the actions of one who was genuinely concerned about the shielding of her or her own family members identities in a highly publicized case to assert that defendant cannot utilize the same information and 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. Plaintiff's supposed concern about bringing non-parties into the litigation is similarly disingenuous given that plaintiff has issued subpoenas to numerous individuals and institutions with no ties to the allegations

2:10in the complaint, many of which do not even mention either party to this action. Plaintiff next contends that she has not required to submit evidence to substantiate and corroborate her alleged harm in doing so. Plaintiff ignores decisions from this court and numerous others looking for corroboration from medical professionals that detailed the risk to plaintiff. Combs, 2024, WL 863 705 at 3, moreover even if supporting affidavits are not required, something more than mirror speculation and broad conclusion plainly is. CEG Dover Skyline Autos Incorporated 375 F.SUPP 3D 401 406 SDNY 2019 Combs 2024 WL 463509 at 2 and 3. Plaintiff fails to clear even that bar. Instead, plaintiff asserts that as an alleged rape victim, she will obviously be retraumatized and suffer untold psychological harm

3:12if her identity is disclosed. But all she offers in support are statistics regarding a Saul victims reluctant to speak publicly about their experiences and examples of victims and families who have been harassed by their alleged attackers. While those reports are certainly upsetting, they are insufficient to establish any harm or threat of harm, particular to plaintiff, that justifies continued anonymity. CE Dover's Intel Corporation 24 CIV 6117 2024 WL 455 3985 at 3 and 4 SDNY October 22, 2024 Combs 2024 WL 463 5309 at 2 and 3. Plaintiff's alleged membership in a particular 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.

4:13Intel Corp 2024 WL 455 3985 at 3 and 4 SITATION and Quotation omitted. Part 4, 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 counsel's prior certification that plaintiff has not spoken publicly about the incidents that underlie the causes of action in her complaint. CE CF Docket Number 7 and 18 In fact, as documented in defendants opening brief, frequently posted on Twitter that she survived alleged trafficking by Epstein, including, for example, tweeting 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 her opposition

5:14in her opposition, flatly declaring that none of her social media posts discussing her alleged trafficking by Epstein concern the allegations made in this case. The post never mentioned the incident's detailed in the complaint and plaintiff is never publicly disclosed the allegations that she has made in this case, opposition at 17, emphasis and original. These representations are categorically and knowingly false and do not tip the seven-sealed plaintiff factor whether the plaintiff's identity has thus far been kept confidential to favor an inimit. 537 f.3d at 190 See motion at 1112 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 the center of her complaint. The complaint contains more references to Epstein than to defendant and redacted despite the fact that Mr. Black is the sole

6:14defendant 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 defendant. CECF document number 1 16 44 and 45 56 60 through 66 and 83. 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. 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 her public statements about those allegations should not weigh against her continued anonymity. As detailed in the defendant's opening brief, plaintiff also discusses specific allegations against

7:19defendant by name with at least two individuals she knew only through social media. They should also not be used as a basis to foist a host of irrelevant harassing and burdensome discovery on defendant and third parties. Mr. Black is mentioned in less than 17% of the requests 71 of 419 including the subpoenas Duke is techam that the plaintiff has noticed to date. Gwynne declaration at five on the other hand the subpoenas are rife with references to Epstein as cohorts and various businesses and political leaders including former president Clinton, two United States senators, two former cabinet officers, several owners of professional sports franchises in Washington DC 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 Mr. Black. Although she shared these details and direct messages rather than public posts, there is no evidence that plaintiff received assurances of confidentiality from either individuals

8:23both of whom were virtual strangers to her and in fact readily shared this information with investigators. See, rap 537 f dot supp 3d at 529. Accordingly plaintiff's public statements weigh strongly in favor of disclosing her identity. Part 5. 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. See, plaintiff 537 f dot 3d at 190 because even if the conduct alleged in the complaint occurred when plaintiff was a minor plaintiff is now an adult motion at 16. 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 14 citing rap 537 f dot supp 3d at 530 calms at 2024 wl 863 705 at 4 but plaintiff wrongly asserts that this factor

9:29weighs in favor of anonymity in this case because she alleges that she is developmentally about 12 years old and currently has the emotional characteristics of a 12 year old. Put differently, plaintiff contends that her legal age is irrelevant here because her alleged disabilities make her vulnerable. An exactly the way a 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 adopting her reasoning. Moreover, if as plaintiff alleges she is so developmentally and neurologically disabled that she should be considered the 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 are civ p 17c. 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 have never sought to go this route which

10:33speaks volumes. Conclusion for the four going reasons and as said fourth in the opening brief defendant respectfully requests at the court grant this motion and amend the caption to disclose plaintiff's name. This document was dated November 4th 2024 and it was signed by Daniel Perry. All of the information that goes with this episode can be found in the description box.