Latest / The Epstein Chronicles / Leon Black's Legal Team Ask The Judge To Reconsider The Anonymity Of His Accuser (9/24/26)

Transcript

Leon Black's Legal Team Ask The Judge To Reconsider The Anonymity Of His Accuser (9/24/26) · The Epstein Chronicles

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  Speaker 1: What's up everyone and welcome to another episode of the
• 0:02
  Speaker 1: Epstein Chronicles. In this episode, we're going to jump right
• 0:06
  Speaker 1: back into that court paperwork between Jane Doe and Leon Black.
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  Speaker 1: And this time, we're going to take a look at
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  Speaker 1: a letter that Leon Black's team wrote to the judge
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  Speaker 1: in regards to his accuser and her anonymity. Reply to
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  Speaker 1: Jane Doe vs. Leon Black 123-CV-06418JGLC additional information regarding plaintiff's
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  Speaker 1: failure to keep her identity confidential in support of defendant's
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  Speaker 1: motion to amend the caption. Dear Judge Clark, we write
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  Speaker 1: to provide additional information regarding plaintiff's failure to keep her
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  Speaker 1: identity confidential as ordered by the court following the initial
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  Speaker 1: pretrial conference. During the IPTC, plaintiff's counsel challenged defendant's assertion
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  Speaker 1: that plaintiff discussed the specific allegations against defendant in private
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  Speaker 1: messages with at least two individuals she befriended on Twitter
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  Speaker 1: stating that plaintiff had never brought up defendant in any
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  Speaker 1: of her communications and that plaintiff's counsel was not aware
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  Speaker 1: of any instance in which plaintiff spoke specifically about defendant.
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  Speaker 1: Plaintiff's counsel also specifically referenced direct messages between plaintiff and
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  Speaker 1: other users on Twitter. Your Honor stated that it would
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  Speaker 1: be helpful to see those messages and subsequently ordered plaintiff
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  Speaker 1: and her counsel to submit all Twitter messages referenced at
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  Speaker 1: the IPTC. This court's order also permitted defendant to submit
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  Speaker 1: any additional information regarding plaintiff's alleged failure to keep her
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  Speaker 1: identity confidential. After the parties made ex parte submissions, the
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  Speaker 1: court directed plaintiff to file her submission on the public
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  Speaker 1: docket with appropriate redactions and permitted defendant to supplement his
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  Speaker 1: initial submission to respond to plaintiff's submission. Plaintiff specifically disclosed
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  Speaker 1: defendant's name and allegations against him to at least two
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  Speaker 1: individuals whom she knew. only through social media. Pursuant to
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  Speaker 1: the court's order, defendant submits the relevant portions of the
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  Speaker 1: messages referenced in support of his motion to amend the
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  Speaker 1: caption to disclose plaintiff's name, which are attached as exhibits
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  Speaker 1: A and B to this letter. Defendant's investigator received copies
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  Speaker 1: of these messages from the individuals to whom plaintiff disclosed
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  Speaker 1: her allegations against defendant and whom plaintiff knew only from
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  Speaker 1: interactions on Twitter. CECF number 118. Although plaintiff's counsel specifically
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  Speaker 1: referenced Twitter direct messages during the IPTC and in her submission,
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  Speaker 1: the relevant exchanges occurred over text message in early 2023.
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  Speaker 1: According to a recorded interview of one of the individuals,
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  Speaker 1: individual number one, plaintiff met these individuals through Twitter and
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  Speaker 1: subsequently exchanged phone numbers with them so she could communicate
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  Speaker 1: with them off the platform. As reflected in the attached screenshots,
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  Speaker 1: plaintiff did disclose defendant's name to both individuals. According to
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  Speaker 1: Individual 1, shortly before filing the complaint in this action,
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  Speaker 1: plaintiff relayed that she was assaulted by a billionaire and
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  Speaker 1: shared graphic details of the alleged assault. Plaintiff then offered, unprompted,
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  Speaker 1: to share the name of her alleged attacker and asked
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  Speaker 1: that Individual 1 delete the messages with his name after
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  Speaker 1: reading it. After plaintiff provided defendant's name, Individual 1 did
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  Speaker 1: subsequently delete the message disclosing defendant's name. As Individual 1
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  Speaker 1: told the investigator, Individual 1, she always, always talked about
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  Speaker 1: being an Epstein survivor. She never ever, but she brought up, yeah,
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  Speaker 1: I mean, she's always talked about Epstein and how she
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  Speaker 1: was his special girl. And that's why she was always mentioned. Investigator,
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  Speaker 1: when did she ever mention any other abuse or rape
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  Speaker 1: or anything by any other people? Or she only referred
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  Speaker 1: always to Epstein? Individual 1, not in the well, not
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  Speaker 1: in the Twitter spaces directly, no. But she texted me unsolicited,
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  Speaker 1: you know, here's the, you know, I have, you know,
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  Speaker 1: the story of, you know, who did it. And in
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  Speaker 1: my text, I'm like, I don't want to hear it. Investigator.
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  Speaker 1: And did she actually tell you the name? Individual one.
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  Speaker 1: And then she said, here's the name of the person
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  Speaker 1: who did it. I said, please don't tell me. And
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  Speaker 1: then she said, just delete it after. And I was like,
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  Speaker 1: I don't want it. But I did. And I did.
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  Speaker 1: So in my text messages, she gave me Leon Black's
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  Speaker 1: name and I deleted it right after. And I was like,
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  Speaker 1: I don't even know who the hell he is. Like,
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  Speaker 1: you know, so like she was this and this was
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  Speaker 1: her case getting her together. Individual one. I originally, I
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  Speaker 1: was like, no, I don't want to hear her story.
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  Speaker 1: I didn't know she was going to blast her story,
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  Speaker 1: but she gave me her full, you know, exact like
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  Speaker 1: what she put out in the complaint in the text
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  Speaker 1: she sent me. And then she says, I'll tell you
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  Speaker 1: once you read it who the redacted name is. And
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  Speaker 1: I said, you know, after reading it, I was, you know,
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  Speaker 1: May I tell you his name? And if I do,
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  Speaker 1: can you delete it? I said, I'm going to delete everything,
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  Speaker 1: which I didn't. And I said, I don't know who
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  Speaker 1: that is. Investigator. And so she said, that's also March 7th.
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  Speaker 1: So it's all the same part of the same conversation.
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  Speaker 1: And she said, I'm going to come out and file
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  Speaker 1: and I'll tell you the name of the person and
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  Speaker 1: so forth. Okay. Individual one. Yeah. And it was all
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  Speaker 1: like unprovoked. Like I didn't ask, you know. I like
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  Speaker 1: my things where, you know, like to help, to keep positive. Like,
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  Speaker 1: I'm here to help you just for positivity. You know,
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  Speaker 1: I said that your mental health and your future are
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  Speaker 1: most important. The text messages that Individual 1 provided in
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  Speaker 1: Exhibit A show that this is exactly what happened. Plaintiff
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  Speaker 1: texted Individual 1, I will tell you, once you've read it,
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  Speaker 1: who the redacted name is. And may I tell you
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  Speaker 1: his name? And if I do, can you delete it
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  Speaker 1: right after? After Individual 1 agreed, Plaintiff, said, okay, his
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  Speaker 1: name was, and then provided Mr. Black's name, which Individual
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  Speaker 1: 1 told investigators that she deleted. After her interview, Individual
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  Speaker 1: 1 contacted Individual 2, another person who had interacted with
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  Speaker 1: Plaintiff on Twitter, and then via text message, Individual 2
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  Speaker 1: provided her with text messages, Plaintiff to investigators through Individual 1.
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  Speaker 1: Those messages provided in the Exhibit B are remarkably similar
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  Speaker 1: to Individual 1's. Plaintiff Asked Individual 2, Okay, so I'm
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  Speaker 1: going to type a name, and then you can delete
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  Speaker 1: it as soon as I type it. Plaintiff did so,
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  Speaker 1: and Individual 2 acknowledged that she had deleted Mr. Black's name.
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  Speaker 1: As discussed at the IPTC, these messages demonstrate that Plaintiff
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  Speaker 1: has not in fact kept her identity confidential in connection
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  Speaker 1: with the allegations concerning defendant in the first amended complaint. Indeed,
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  Speaker 1: she freely and insistently denied. offered up the details of
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  Speaker 1: her alleged assault and defendant's identity to at least two individuals,
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  Speaker 1: both of whom were virtual strangers she knew only through
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  Speaker 1: social media, without even being asked and even though one
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  Speaker 1: of them expressly said she did not want to hear
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  Speaker 1: about it. Moreover, these two individuals are merely the people
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  Speaker 1: that defendant is aware of so far, without having the
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  Speaker 1: ability to learn more due to plaintiff's anonymity, and only
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  Speaker 1: because one of them made the connection to this case
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  Speaker 1: based on the similarity between what plaintiff told her and
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  Speaker 1: the allegations in the complaint. Plaintiff had thousands of contacts
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  Speaker 1: on social media, regularly described her supposed connection to Epstein
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  Speaker 1: in Twitter Spaces events attended by thousands of participants, and
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  Speaker 1: posted frequently about her alleged connection to Epstein, employing hashtags
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  Speaker 1: and other methods to maximize the reach of her posts,
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  Speaker 1: all of which relate to plaintiff's allegations in the FAC
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  Speaker 1: and are sufficient, standing alone, to weigh against plaintiff's continued anonymity.
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  Speaker 1: These two individuals are, in likelihood, just the tip of
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  Speaker 1: the proverbial iceberg, and we expect that more witnesses will
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  Speaker 1: come forward if plaintiff's name is disclosed. Those witnesses possess
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  Speaker 1: critical information that defendant has a right to use in
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  Speaker 1: his defense. Plaintiff's submission is non-responsive and raises serious concerns
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  Speaker 1: about spoliation. Plaintiff's submission is entirely non-responsive to the court's instruction,
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  Speaker 1: provides no evidence that plaintiff kept her identity confidential in
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  Speaker 1: connection with her allegations concerning defendant, and fails to rebut
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  Speaker 1: defendant's evidence that she did not. First and foremost, contrary
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  Speaker 1: to plaintiff's counsel's assertion at the ITPC, none of the
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  Speaker 1: Twitter users referenced in plaintiff's letter are individuals that defendant's
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  Speaker 1: investigators have even spoken with, and are not the two
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  Speaker 1: individuals referenced in defendant's motion. Second, other than a single
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  Speaker 1: direct message exchange, plaintiff's submissions, consist entirely of cherry-picked communications
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  Speaker 1: to plaintiff and provide no evidence of what plaintiff communicated
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  Speaker 1: to others. Third, none of the communications included with her
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  Speaker 1: submission are even related to the two topics at issue,
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  Speaker 1: namely Epstein and the defendant. In short, plaintiff's submission is bewildering.
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  Speaker 1: Her apparent non-response to direct messages that do not even
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  Speaker 1: so much as mention Epstein or defendant says nothing about
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  Speaker 1: what plaintiff affirmatively said about Epstein and defendant to other individuals.
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  Speaker 1: It's entirely unclear how or why plaintiff selected these particular
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  Speaker 1: communications to prove that she has not spoken with anyone
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  Speaker 1: about her allegations against defendant. Plaintiff noticeably omits from her
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  Speaker 1: submission one of the few specific communications her counsel mentioned
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  Speaker 1: during the IPTC, a direct message in which an individual
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  Speaker 1: supposedly asked plaintiff to send them inappropriate pictures of herself.
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  Speaker 1: These messages appear to have been selected without rhyme or
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  Speaker 1: reason and have no bearing on the issue of whether
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  Speaker 1: a plaintiff should be required to proceed under a real name.
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  Speaker 1: Beyond its non-responsiveness, plaintiff's submission raises serious concerns about her spoliation.
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  Speaker 1: In her submission, plaintiff represents that she deleted her Twitter
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  Speaker 1: account in approximately May of 2023, only two months before
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  Speaker 1: she commenced this lawsuit. As a result, plaintiff's counsel report
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  Speaker 1: they only have access to what Ms. Doe has saved
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  Speaker 1: on her phone. Plaintiff was a prolific user of Twitter,
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  Speaker 1: and her now-lost Twitter account, both her public posts about
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  Speaker 1: Epstein and her communications with other users about Epstein and defendant,
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  Speaker 1: contained highly relevant and material information about her allegations in
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  Speaker 1: this lawsuit. the identities of potential witnesses, and information relevant
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  Speaker 1: to plaintiff's credibility. Defendant will undoubtedly be highly prejudiced by
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  Speaker 1: the deletion of this information and the preservation of only
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  Speaker 1: a subset of materials plaintiff believes is helpful to her cause. Moreover,
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  Speaker 1: by her own admission, plaintiff appears to have been represented
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  Speaker 1: by counsel and was either contemplating or actively engaged in
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  Speaker 1: litigation concerning Epstein and or defendant at the time she
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  Speaker 1: deleted her Twitter account. In February of 2023, Plaintiff told
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  Speaker 1: Individual 2, whom she knew only through social media, that
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  Speaker 1: in March my case starts against the estate of Jeffrey Epstein.
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  Speaker 1: Shortly thereafter, she told Individual 2 about another case involving
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  Speaker 1: a man that Jeffrey literally gave me to as a gift,
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  Speaker 1: using language nearly identical to what would later appear in
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  Speaker 1: the pleadings in this action, before disclosing defendant's name on
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  Speaker 1: the condition that Individual 2 would immediately delete it. and
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  Speaker 1: in March of 2023, she told Individual 1, whom she
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  Speaker 1: also knew only from social media, that she was literally
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  Speaker 1: currently in a court battle with two of the most
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  Speaker 1: powerful billionaires on the planet, and went on to recount
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  Speaker 1: allegations that appeared nearly verbatim a few months later in
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  Speaker 1: the complaint in this action, indicating that plaintiffs planned to
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  Speaker 1: sue Mr. Black was already underway by then. Conclusion As
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  Speaker 1: the foregoings make clear, plaintiff has not only kept her
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  Speaker 1: identity confidential, with respect to her allegations in this case,
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  Speaker 1: neither with respect to her allegations about Epstein, nor with
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  Speaker 1: respect to her allegations about defendant. But ultimately, whether or
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  Speaker 1: not plaintiff has kept her identity confidential is just one
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  Speaker 1: of the relevant factors, and eight of the nine other
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  Speaker 1: factors plainly weigh against plaintiff's continued anonymity. For all of
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  Speaker 1: these reasons, and for the reasons set forth in the
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  Speaker 1: defendant's motion papers, we respectfully request that the court grant
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  Speaker 1: defendant's motion to amend the caption to disclose plaintiff's name.
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  Speaker 1: We thank the court for its attention to this matter
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  Speaker 1: and are available to discuss at the court's convenience if necessary.
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  Speaker 1: Respectfully submitted by Dania Perry and this was filed on
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  Speaker 1: November 22, 2024. All of the information that goes with
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  Speaker 1: this episode can be found in the description box.