Amended Complaint Against Leon Black Filed
Amended Complaint Against Leon Black Filed
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Plaintiff Guzel Ganieva (“Plaintiff”) brings this Amended Complaint against Defendant
PRELIMINARY STATEMENT
2. Everything that Black said in the above statement about Ms. Ganieva is false. First,
1
Gillian Tan, Black Says He Paid to Hide Affair, Denies It Led to Apollo Exit, Bloomberg,
(April 8, 2021, 10:04 PM), https://www.bloomberg.com/news/articles/2021-04-09/black-says-he-
paid-to-hide-affair-denies-it-led-to-apollo-exit, (emphasis added).
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Black did not have “a consensual affair” with Ms. Ganieva. Second, any telling of “harassment”
or “inappropriate behavior” by Black towards Ms. Ganieva is not fabricated. As described below,
such words do not come close to the appalling forced sexual misconduct that Black inflicted on
her. Third, Black has never been “extorted by Ms. Ganieva,” much less for “many years.”
Disgustingly, he used his extreme power and wealth to coerce her into signing a non-disclosure
agreement (“NDA”) in October 2015 precisely because he knew what he had done to her was
3. The only repeated threats for many years came from Black to Ms. Ganieva that if
she did not sign the NDA, take his hush money and retreat into silence forever, she would feel the
“If you do not take the money, I will put you in prison.”
“If you do not take the money, I will destroy your life.”
anything. As the people within Black’s inner circle know, the suggestion that Black attempted to
5. For years, Black ate countless meals with Ms. Ganieva in 5-star restaurants, took
her to Broadway shows, numerous art shows, museum exhibitions, private parties, the movies,
including the premier of The King’s Speech and even sat beside her while he cheered for the New
York Knicks at MSG. In the midst of all these very public outings, Black never once worried about
sparing his family from public embarrassment. 2 In fact, he never worried about people associating
2
Nor did he care about being seen out with other young women, often of Russian descent, in
addition to Ms. Ganieva.
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him with Ms. Ganieva because he enjoyed being seen with her in public. What Black has worried
6. On October 29, 2020 during an earnings call, in connection with his announcements
about his future role at Apollo Global Management (“Apollo”), Black publicly stated:
7. This and similar subsequent false claims by Black, including his January 25, 2021
statement in connection with his “retirement” as CEO of Apollo in which he stated, “I did not
engage in any wrongdoing or inappropriate conduct” in relation to Jeffrey Epstein, served as the
tipping point for Ms. Ganieva. Having recently educated herself in law school and knowing that
many of Black’s sexual acts were against her will and without her consent, she no longer was
8. Knowing that her public outing of his disgusting conduct would surely end any
further monetary payments from Black, i.e., his “hush money,” she did so regardless.
9. On March 17, 2021, Ms. Ganieva bravely posted on Twitter that Black was a
“predator” that had “sexually harassed and abused” her for years. The next morning, Black texted
10. Knowing that he could no longer control her into silence, Black resorted to a tact
that has been used by wealthy and powerful men like him who had committed sexual misconduct
3
Too many examples exist to include here of wealthy male sexual harassers re-victimizing
their victims by accusing these women of extortion after they came forward. A number of high
profile examples, some of whom also have close ties to Black as described below, are detailed infra
at ¶ 232. Threats of extortion are potentially far more damaging and frightening to a female accuser
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victimized one more time in a public way, often including threats of criminal charges. As
demonstrated by Black, this is accomplished by his going to the “criminal authorities” to accuse
Ms. Ganieva of extortion and placing her on the legal defensive before she can take any legal action
12. Although heinous and disgusting, Ms. Ganieva had been threatened by Black for
years that if she disobeyed him, he would “put her in prison,” and to speak out would be
“suicide.”
13. For too long, wealthy and powerful men like Black have enjoyed an unequal and
grossly imbalanced access to justice unavailable to the average man or woman and non-
millionaires. Knowing the right lawyers and politicians provided Black with the ability to do
exactly as he said:
14. Threatening that a criminal charge will be brought against Ms. Ganieva first will
not save Black from the truth about what he has done. Nor will she be deterred by any baseless,
retaliatory and unlawful counterclaims that have been asserted against her in this action, despite
the immense potential liability and risks these claims could mean. As chronicled below, the truth
will reveal a violent, abusive, predatory, vindictive and brutal side to Black that he has shielded
than threats of a civil lawsuit for defamation, an option that numerous men accused of sexual
misconduct use for similar reasons.
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16. The Court has personal jurisdiction pursuant to Civil Practice Law and Rules
(“CPLR”) § 301, inter alia, because Plaintiff and Defendant reside in New York.
17. Venue is proper in this County pursuant to CPLR § 503 because a substantial part
of the events giving rise to Plaintiff’s claims took place in New York County.
PARTIES
18. Plaintiff Guzel Ganieva resides in the state of New York, New York County.
19. Defendant Leon Black resides in the state of New York, New York County.
FACTUAL ALLEGATIONS
20. Like a master chess player, Black was many moves ahead of Ms. Ganieva from the
moment he met her. Black picked Ms. Ganieva out of a crowd on March 8, 2008, while attending
an International Women’s Day event held at Donald Engel’s UES home.4 Ms. Ganieva was invited
by a woman who she knew through modeling. This woman also knew Black. The event included
Russian musicians and a number of other Russian-speaking guests, including other models.
21. A single mother in her early twenties (she was 25), having moved from Russia to
the United States by herself, it was easy work for Black to convince Ms. Ganieva to dine with him
at La Grenouille where he planned to tell her how he could help her with her “future.”
23. It was a choreographed plan that allowed him to quickly gain Ms. Ganieva’s trust.
4
Donald Engel knew Black from Drexel Burnham. It has been alleged that it was Donald
Engel who arranged for the beautiful “girls” to be present at the infamous annual Drexel Burnham
conferences that came to be known as the “the predators’ ball.” Linette Lopez, Here's What
Happened When I Went To Vegas With 1,800 Hedge Fund Managers, (May 22, 2014),
https://www.businessinsider.com/what-hedge-fund-managers-do-in-vegas-2014-5.
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Common sense suggests that he had used this tactic before, and in fact, Ms. Ganieva later met at
least two other women that were similarly involved with Black. Over the course of several dinners,
Black repeatedly praised Ms. Ganieva on her innate talent and intellect, “arranged” a few
appointments for her, for example, one with the Creative Artists Agency, LLC (“CAA”) in Los
Angeles. These efforts helped him quickly gain her gratitude and admiration.
24. Ms. Ganieva was pleased that a successful businessman that she admired found her
conversation and company enjoyable. As the person in charge of thousands of employees, Ms.
Ganieva believed Black understood the value and importance of reliable, secure employment, and
intended to help her move beyond simply modeling. Naïvely, Ms. Ganieva believed that Black
was not interested in her sexually, particularly because she told him that their relationship would
not be sexual.
25. It was her intention and hope that Black would serve as a mentor to her
professionally.
26. Black, however, is a ruthless planner and a man that gets what he wants. It was not
long before he managed to secure his ability to get Ms. Ganieva alone with him, out of sight from
27. Once he did, Black forced sadistic sexual acts on her, some of which are described
28. The first time it happened, in 2008, Black took Ms. Ganieva to a studio apartment
with a mattress on the floor and no other furniture. Black said that a young woman lived there.
Humiliated and in shock, Ms. Ganieva never uttered a word about what he had done to her.
29. In a sad but predictable pattern, for the next several years Ms. Ganieva endured a
cycle of intimidation, abuse and humiliation by Black that on numerous occasions included forced
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sexual conduct against her will. As described below, many of these instances were perpetrated by
Black in order for him to indulge in sadistic sexual acts that were physically painful to Ms. Ganieva
and to which she never consented. In addition to causing intentional physical pain, Black engaged
in these acts because he derived pleasure from humiliating and debasing Ms. Ganieva.
30. After these acts of violence, Ms. Ganieva would tell Black to never speak to her or
contact her again. Inevitably, after waiting weeks and sometimes several months, being a master
manipulator, Black would engage in remorseful and conciliatory behavior, relentlessly – until he
31. Black’s persuasion tactics included endless promises in line with the mentor that
she wanted him to be for her, such as: to help with Ms. Ganieva’s child’s educational opportunities;
to finance a movie for her that she could produce or direct, after convincing her that acting was too
difficult a business; to purchase a townhouse and turn it into an art museum that Ms. Ganieva could
manage or be a director of; and to help her with an application to Harvard Business School because
of his strong relationships there. She believed his promises, and in fact, she was aware that Black
had purchased an art gallery and hired another woman that he had been sexually involved with to
32. Even during these periods of overt remorseful and conciliatory behavior, Black
nevertheless engaged in textbook harasser conduct. Specific details about each instance of Black’s
derogatory and controlling conduct towards Ms. Ganieva are too much to include in this Amended
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33. Black, the powerful and ruthless Wall Street titan, was also ruthless and
34. Unfortunately for Ms. Ganieva, during many, but not all, of her sexual experiences
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35. Ms. Ganieva made it known to Black that she did not consent to his abnormal and
36. REDACTED
37. REDACTED
38. REDACTED
39. The first time Black did this, Ms. Ganieva had no idea what was happening –
REDACTED
40. On some occasions, the pain was so extreme that Ms. Ganieva believes she lost
consciousness or fainted.
something from which Black derived pleasure and arousal, and knew caused Ms. Ganieva pain and
distress.
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42. REDACTED
43. REDACTED
44. REDACTED
45. Black, because of his abnormal and atypical sexual needs, was extremely concerned
about keeping this information secret. At the same time, Black’s violent sexual behavior was a
powerful way for him to exert complete physical, mental and emotional control over Ms. Ganieva
46. At all times, Ms. Ganieva constantly feared Black. When they were alone, she
feared him physically and was unable to reject his sexual advances, too afraid to anger him or cause
his temper to flare. There were times when Ms. Ganieva physically submitted to his physical force
47. She experienced fear mentally and emotionally even when not in his physical
presence. She was always worried that she was not doing things exactly the way Black wanted her
to do them. By way of example only, Black had strong opinions about everything she did – from
the way she spoke to him, to her tone of voice and what she said, to where she went on vacation,
and what jobs she applied for. In her experience, upsetting him was dangerous and she did her best
to avoid it.
48. REDACTED
10
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REDACTED
49. The fear was exhausting but Ms. Ganieva felt she could not disobey Black for fear
III. Leon Black’s Public Statements About His Relationship with Jeffrey Epstein
50. There has been, and remains, much mystery surrounding the infamous Jeffrey
Epstein (“Epstein”), and just how he became an ultra-wealthy and powerfully connected person.
51. Indeed, Epstein had a modest upbringing in Coney Island, New York, did not
complete college, and first worked as a high school math teacher in Manhattan. Nonetheless, he
somehow rose to become an extremely wealthy person, with properties all over the world, including
a seven-story townhouse in the Upper East Side, a private island in the United States Virgin Islands,
a massive home in ritzy Palm Beach, Florida, and his own compound in New Mexico that he was
52. Not only was he wealthy, but Epstein is believed to have had close personal ties to
some of the world’s most powerful politicians, businessmen, and celebrity figures, including, but
not limited to, former Presidents Bill Clinton and Donald Trump, Prince Andrew, Duke of York,
53. Mystery has also surrounded how Epstein received only a mild “slap on the wrist”
despite operating an alleged sophisticated sex trafficking ring in Palm Beach, Florida. Numerous
young women had come forward and accused him of engaging in sex acts with them while they
were minors. Epstein ultimately pled guilty in 2008 to just one count of soliciting an underage
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prostitute, and ultimately spent 13 months out of an 18-month sentence in the Palm Beach County
Stockade.
54. After renewed public outcry concerning Epstein’s heinous conduct and the
sweetheart prosecution deal he received in 2008, Epstein was arrested again on July 6, 2019, when
his private jet landed in New Jersey’s Teterboro airport. Manhattan federal prosecutors charged
55. Following Epstein’s arrest, Leon Black told Apollo investors (Apollo is the publicly
traded hedge fund with over $400 billion in assets under management founded by Black where he
served as then-Chairman and Chief Executive Officer (“CEO”)), during a July 31, 2019 earnings
call that he “was completely unaware of and [was] deeply troubled by the conduct that is now
the subject of the federal criminal charges brought against [Epstein].” (emphasis added).
56. On August 10, 2019, after he was denied bail, Epstein was found dead in his jail cell
in the Manhattan Correctional Center. New York’s Chief Medical Examiner determined that
57. Then, on October 12, 2020, the New York Times published an article5 revealing that
Black, one of the world’s wealthiest persons with a net worth estimated at close to $10 billion, had
58. In response, Black, in an October 12, 2020, letter to Apollo’s Limited Partners,
5
Matthew Goldstein, Steve Eder and David Enrich, The Billionaire Who Stood by Jeffrey
Epstein, (Oct. 12, 2020), https://www.nytimes.com/2020/10/12/business/leon-black-jeffrey-
epstein.html.
12
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59. Later that month, during an October 29, 2020, earnings call (“October 2020
61. Following the October 12, 2020 New York Times article, Apollo hired the law firm
62. Dechert was also tasked with creating a report to submit to the Securities and
63. On or around January 22, 2021, Dechert released its Report7 which recounted
Black’s claim that, while he was aware of Epstein’s 2008 guilty plea, he “understood from Epstein
that these offenses arose from a single instance in which Epstein had received a massage from a
6
A full transcript of the call and Black’s prepared remarks is available here:
https://www.fool.com/earnings/call-transcripts/2020/10/30/apollo-global-management-llc-apo-
q3-2020-earnings/.
7
https://www.sec.gov/Archives/edgar/data/1411494/000119312521016405/d118102dex99
1.htm (“Exhibit 99.1”).
13
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17-year-old prostitute.” (Report at 6, emphasis added). Of course, it was widely reported that
Epstein had had sex with countless underaged girls, and not merely a massage on one occasion
from a prostitute.
64. Black claimed to Dechert that, as a result of what Epstein supposedly told him about
the nature of his conviction, he thought it would “not be inappropriate to maintain a personal and
professional relationship with Epstein” because: (i) Black believed Epstein had made a single
“mistak[e]”; (ii) “numerous prominent figures” “continued to maintain social and business
relationships with Epstein”; and (iii) because Black “believes in rehabilitation, and in giving people
second chances,” while “name-dropping” his relationships with Michael Milken and Martha
Stewart. Id.
65. Black admitted to Dechert that, up until the fall of 2018, he maintained a relationship
with Epstein, whom he viewed “as a friend worthy of trust” that he confided on personal matters,
66. While Black admitted that he knew Epstein had “eclectic tastes” and “often
employed attractive women,” he claimed he did not believe that any of the women in Epstein’s
employ were underage,” and was “repulsed” by the details of Epstein’s crimes. Id. at 8 (emphasis
added).
67. Throughout Dechert’s Alice in Wonderland narrative, the Report repeatedly (and
conveniently) emphasizes that between the years 2008-2010, “Black had no client relationship
68. The Report further revealed that Black paid Epstein, between 2012 and 2017, a total
of $158 million (id. at 4), which Black claimed were payments made to compensate Epstein —
who possessed neither a college degree, nor any advanced degrees related to tax advisement or
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estate planning — “for the overall value he believed Epstein was providing to him through
Epstein’s advice on trust and estate planning, tax issues, philanthropic issues, and the operation of
Dechert must admit, any “conclusions” contained in the Report were based on nothing more than
voluntary statements provided by willing participants, who likely prepared heavily with counsel
about what they said and produced to Dechert, and may have even had counsel present when they
spoke to Dechert. Nobody testified under oath or provided sworn statements under the penalty of
perjury, and it is unclear what access, if any, Dechert had to all relevant documents and evidence.
70. Further, these “Good Samaritans” who volunteered to speak to Dechert were none
other than Black’s posse, consisting of Paul Weiss lawyers (supposedly the best and brightest legal
minds in the world, but who were consistently outshined by Epstein, who could only come up with
a $2 billion tax solution for Black), Apollo Global Management partners and associates, and other
people with personal, professional and/or financial interests aligned with Black’s.
71. Following the Report, in a January 25, 2021, statement, Black maintained that, “I
was completely unaware of Mr. Epstein’s abhorrent misconduct that came to light in late
2018,” and repeated, “I did not engage in any wrongdoing or inappropriate conduct.”
72. In what can only be described as the epitome of irony, disingenuousness and
“trolling” based on how Black horrifically abused Ms. Ganieva and, upon information and belief,
other women with whom he has had been involved, Black also stated that:
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73. Though Black has, conveniently, tried to distance himself from Epstein in the wake
of Epstein’s death and the revelation of more sordid details about Epstein’s criminal affairs, and
though Black has tried his best, with the help of a well-crafted public relations and legal team, to
make it appear that his and Epstein’s relationship was only “professional,” in reality, the two had
an extremely close personal friendship, and Epstein was Black’s “best friend.”
74. As detailed below, this relationship regularly delved into nefarious waters, and
directly contradicts Black’s statements to the public, to investors on the October 2020 earnings call,
IV. Black Flies Ms. Ganieva From New York City to Jeffrey Epstein’s Home in Palm
Beach, Florida While Epstein Was Serving His Prison Sentence in the Palm Beach
County Stockade
75. One morning, in or about mid-to-late October 2008,9 Black picked up Ms. Ganieva
purportedly to take her to lunch. After she got in the car, however, Black told her that they were
not going to lunch in Manhattan. Rather, he was taking her on a “trip” to Florida to see a “friend”
of Black’s.
76. He refused to tell her where they were going, who they were visiting, or the reason
8
A subpoena has been served on Dechert to obtain statements made by Black and by the
voluntary witnesses specific to certain allegations set forth infra.
9
To identify the precise date, which Ms. Ganieva cannot specifically recall, subpoenas have
been served on Teterboro Airport (TEB) for records of Black’s flights to Palm Beach International
Airport (“PBI”) in this period, as well as on PBI for any records about Black’s air travel. Additional
subpoenas have been served on Fixed Base Operators (“FBO”) at PBI for aircraft hangar storage,
maintenance, or refueling of the aircraft used for Black’s turnaround flight.
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77. Black and Ms. Ganieva were driven to Teterboro Airport (“TEB”), located in New
78. Once on the plane, Black finally told Ms. Ganieva where they were going and who
they were going to see. Black told her that they were flying down to Palm Beach to visit his
79. As referenced to above, earlier that year, on or about June 30, 2008, Epstein pleaded
guilty to a felony charge of solicitation of prostitution involving a minor. After being jailed full-
time at Palm Beach County Stockade, at some point approximately three months in, Epstein was
permitted to leave the jail on “work release” for up to 12 hours a day, six days a week.
80. In addition to allegedly going to a work office, Epstein was permitted to spend hours
81. Although Epstein pled guilty to one count of soliciting an underage prostitute, by
the time he began his jail sentence, news about his sex trafficking ring had been widely reported
on for several years. Additionally, several civil lawsuits had been filed against him.
82. Evidence strongly suggested that Epstein operated a sophisticated sex trafficking
ring which involved minors, including girls as young as 12 and 14, in which he and his associates
would recruit and groom underaged and/or economically disadvantaged girls and young women
from the West Palm Beach, Florida and other surrounding areas to come over to Epstein’s Palm
83. Repeatedly during their relationship, Black would confide in Ms. Ganieva,
unsolicited, that Epstein was his “best friend,” as if it was a badge of honor for him.
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84. Notably, based on the timing of Black’s trip to Palm Beach, Epstein would have
only recently been allowed to leave the jail house on “work release.” 10 Of course, whereas Epstein
was known to have multiple sexual partners a day, during the three months he could not leave jail,
Epstein, conceivably, had less ability to engage in sexual conduct with women.
85. During the flight to Palm Beach, after Black disclosed where he was taking her,
Black sternly warned Ms. Ganieva not to tell anyone that he was flying her down to meet with
Epstein.
86. Disgustingly, Black threatened that he would plant drugs on Ms. Ganieva and frame
87. When Ms. Ganieva said that such threats would not work on her, Black doubled
down on his threats, acknowledged that planting “minor” drugs on her would probably not be
problematic, but said he would frame her with possessing “very serious” drugs that would make
her family and son ashamed of her. Black specifically used heroin as an example of an illicit drug
that would be problematic for her if he planted it on her. Afraid to make him angrier, Ms. Ganieva
88. It is deeply concerning that Black’s scheme to bring Ms. Ganieva to Epstein’s home
was something he planned, and did do, without her knowledge. It was wholly without her consent
and even worse, by the time he told her, Ms. Ganieva was powerless to do anything about it.
Black’s threats to frame her for a “crime,” i.e., by planting drugs, such as heroin, on her, is behavior
10
Epstein’s work release began on October 10, 2008. See DOJ, Office of Professional
Responsibility (OPR) Report, November 2020, at 114-115 (investigation into whether prosecutors
in the U.S. Attorney’s Office for the Southern District of Florida improperly resolved a federal
investigation into the criminal conduct of Jeffrey Epstein) (“DOJ Report”). The Palm Beach
County Sheriff’s office permitted this arrangement, allowing Epstein to work out of an office for a
newly formed nonprofit called The Florida Science Foundation. Id. at 116-117.
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that falls squarely within the definition of New York Penal Law Section §230.34 “Sex Trafficking”
(“a person is guilty of sex trafficking if he or she […] engag[es] in a scheme … by means of
instilling fear in the person [of one of eight consequences, including] “accus[ing] some person of
a crime or cause criminal charges to be instituted against some person.”) N.Y. Pen. L. §230.4(3)(d).
89. After arriving at PBI, a driver affiliated with a car service picked up Ms. Ganieva
and Black in a dark car, possibly a Mercedes-Benz manufactured vehicle, and drove them to
90. When Black and Ms. Ganieva arrived at Epstein’s home, Ms. Ganieva saw that there
was a sheriff’s deputy standing outside the door. Under the terms of the “work release” program,
a prisoner like Epstein was required to pay for the services of a sheriff’s deputy or similar law
enforcement officer who would escort and monitor the prisoner while they were on “work release.”
Black even confirmed to Ms. Ganieva that the man was “a prison guard” hired to escort Epstein to
and from his “work release.” The deputy smiled sheepishly at Black and Ms. Ganieva as they
91. Black and Ms. Ganieva were greeted by Sarah Kellen (“Kellen”). Ms. Ganieva had
never met Kellen before and had no idea who she was.
92. Media reports have described Kellen as a close associate and “lieutenant” of
Epstein’s. Some reports have described her as one of Epstein’s victims, who also happened to
11
It was later disclosed that Epstein paid the Sheriff’s office more than $128,000 for off-duty
deputies wearing business suits to “guard” Epstein while he was on work release. Additionally,
the “office” for the nonprofit at which Epstein allegedly worked turned out to be the office of Jack
Goldberger, one of Epstein’s defense lawyers. The “supervisor” responsible for monitoring
Epstein’s work previously had submitted sworn filings with the IRS that Epstein worked one hour
per week for no pay. That same supervisor, as part of Epstein’s application for work release,
represented that Epstein would work six days a week, twelve hours per day. DOJ Report, at 116-
117.
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work for him. Kellen is thought to be one of the unindicted co-conspirators in Epstein’s sex
trafficking ring, shielded from prosecution under Epstein’s 2007 “Non-Prosecution Agreement”
93. Kellen has also been described as Epstein’s “personal assistant,” who scheduled and
managed the teenage girls and young women who came in and out of Epstein’s houses, including
collecting contact information, taking messages, arranging travel, and escorting the girls and
women to Epstein’s room. Prison records also show that Kellen repeatedly visited Epstein while
he was in prison. Kellen has not been criminally prosecuted for her role in Epstein’s sex trafficking
ring.12
94. Ms. Ganieva soon found herself alone with Black and Epstein in a room that
appeared to be an office. Black and Epstein were situated close to one another, each facing Ms.
Ganieva while in almost supine positions, as if they were waiting for her to get on top of them.
Indeed, Black indicated with his eyes that he wanted Ms. Ganieva to come and lay in between him
and Epstein. Alarmed and shocked, Ms. Ganieva remembers standing in front of them unable to
12
Kellen, however, has been identified, and her alleged conduct described in detail, in
numerous civil lawsuits filed against Epstein. For example, one civil complaint states that,
“Epstein’s plan and scheme reflected a particular pattern and method. The underage victim would
be brought to Epstein’s (Palm Beach) mansion, where she would be introduced to Sarah Kellen,
Epstein’s assistant. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that
contained a massage table… [t]he girl would then find herself alone in the room with Epstein, who
would be wearing only a towel…Epstein would then perform one or more lewd, lascivious and
sexual acts…” Jane Doe 7 v. Jeffrey Epstein, Index No. 08-cv-80993 (S. Dist. FL 2008), Dkt. No.
1 (Complaint) at p. 3; see also Jane Doe No. 1 v. Jeffrey Epstein, et. al, Index No. 9:08-cv-80804-
KAM (S. Dist. FL 2008), Dkt. No. 26 (Opinion and Order Remanding Case to State Court), at p. 3
(“Plaintiff was introduced to Kellen, who led her up the stairs to the room with the massage
table…Kellen set up the massage table, laid out the massage oils, told Plaintiff that Epstein would
be in shortly, and then left the room.”)
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say anything while they just stared up at her, saying nothing, but clearly expecting her to do
something.
95. As she continued to stand there in silence, Black became visibly annoyed. He
96. After Black said this, Kellen suddenly appeared and took Ms. Ganieva into what
appeared to be a living room. Kellen first tried to make small talk, and asked Ms. Ganieva for her
email address because she wanted to send Ms. Ganieva a good website to shop for clothes.
97. Kellen then sat Ms. Ganieva down and said, in a serious but soft, feminine tone:
“You have to let them do whatever they want with you, and you
have to let them be with multiple sexual partners if that’s what
they want.”
“They are very powerful, and if you don’t do what they want
you to do, there will be consequences that I do not want for you.”
98. Kellen again said to her, “you know….[pausing] …. something may happen to you,”
99. Although Epstein was on work release, the heightened scrutiny of his behavior and
whereabouts made his earlier pattern of cycling in underaged girls from economically
disadvantaged homes in West Palm Beach on a daily basis — sometimes three or four girls a day
— no longer an option. Since he was being monitored by law enforcement, he needed to be more
discreet, and could not merely enlist his associates to procure for and bring him the same young,
100. Although Black knew better than to ever actually say aloud why he brought Ms.
Ganieva down there, all the way from New York City to Epstein (without her consent), at the time,
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Ms. Ganieva was caught off-guard and too bewildered to appreciate exactly what was happening
to her.
101. Ms. Ganieva was disgusted, and she let Kellen know this. Ms. Ganieva knew that
by not submitting to Epstein, she would cause Epstein and Black to be very upset, and that there
102. Soon thereafter, Black and Epstein came into the room where Ms. Ganieva sat with
Kellen. The four of them sat around a table, with Black on Ms. Ganieva’s left, Kellen on her right,
and Epstein across from her where he could look directly at her and size her up. An attempt at
awkward conversation was made. Ms. Ganieva recalls saying something about the financial crisis
and remarking about the federal government’s bailout of large financial institutions and the impact
on jobs. Black made a comment about a couch he had bought for Ms. Ganieva’s apartment. Epstein
103. Kellen then, in front of the men this time, brought up again her earlier comment
about how Black and Epstein are addicted to sex. This time, in response to the comment, Ms.
Ganieva said that sex addiction was like any addiction in that you want to have it more often and
with more frequency, but at some point, it will catch up and affect your life.
104. Ms. Ganieva noticed that her voice was getting louder and she became very self-
aware that she was in a precarious situation. It is no wonder that Black refused to tell her about
this planned trip until they were on his aircraft. Black was bringing her down to Florida without
her consent, to satisfy the sex needs of Epstein, his “best friend.”
105. When it became clear that Ms. Ganieva would not be engaging in sex with Epstein,
Epstein and Black became angry and upset with Ms. Ganieva. Not long after, Black and Ms.
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Ganieva left Epstein’s home and went back to PBI. Black was so furious he refused to speak to
her.
107. Back on the private plane, Ms. Ganieva was silent, still shaken from her encounter
with Epstein. Black, visibly angry with Ms. Ganieva and her refusal to submit to Epstein, did not
speak to her, but forcibly shoved food into Ms. Ganieva’s mouth.
108. While this was the first time Black brought Ms. Ganieva to meet with Epstein, it
was not the only time Epstein crept into their relationship.
V. Black’s Relationship with Epstein was Used as a Tool to Control Ms. Ganieva
109. Despite Black’s public statements to the contrary, Black would regularly boast
about how “great” a friend Epstein was. He would regularly regale Ms. Ganieva with stories about
Epstein’s New Mexico compound with wonderment and reveal how Epstein flew around “pretty
and very young girls” in his private jet, which Black described as “just jaw dropping.”
110. In particular, Black appeared most impressed by how Epstein was allegedly creating
his own town in New Mexico, which he said meant that Epstein would have “his own schools,” be
in “control of his own hospitals,” and have “his own police force.” Black seemed enthralled by the
power and authority Epstein was amassing in this town that Epstein envisioned and captivated by
111. On one occasion, when Ms. Ganieva asked Black how Epstein makes his money,
Black bizarrely told her: “he takes care of the little girls.” When Ms. Ganieva gave Black a puzzled
look, Black stared into her eyes and repeated that Epstein does take care of “little girls” (using a
condescending and suggestive tone), and said he was “doing a great job with it.”
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112. Ms. Ganieva understood this to mean that Epstein, widely regarded as a master
manipulator and “fixer,” or someone who makes arrangements for other people, especially of an
illicit or devious kind, was providing Black with advice and resources to help manage the women
Black was involved in outside of his marriage. Of course, this included Ms. Ganieva.
113. Included in the idea of “managing” such affairs, was the implied reference to
114. Indeed, on many other occasions, often while Black was texting with Epstein, he
would reiterate to Ms. Ganieva how his “best friends” were Epstein and Harvey Weinstein, the
115. Worse, Black would mention that these men were helping him to “do” Ms. Ganieva.
116. When asked what he meant by this, Black said that Epstein and Weinstein gave
117. Black also would tell Ms. Ganieva that Epstein and Weinstein were “recording her”
and even making a movie about her. In an effort to veil his threats, Black would chide her and say,
“what kind of director do you prefer?” As always, Ms. Ganieva took his threats seriously. She
believed that if she obeyed Black, he would not make good on his threats. If she did not, however,
118. Such comments were yet another reference to how Epstein, and apparently also
Weinstein, provided Black with advice about how to manipulate and control Ms. Ganieva and he
other women with whom Black was involved, some of whom are discussed below.
119. Black also made multiple comments to Ms. Ganieva about Epstein’s sexual
proclivities, dispelling any notion that Black did not know the true extent of Epstein’s depravity.
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120. By way of example only, in early 2014, while at a café in New York, Ms. Ganieva
criticized Black’s friendship with Epstein. Black rebuked Ms. Ganieva. Superfluously, he said,
“you are too old for [Epstein], he likes them young.” He then added, “he wouldn’t be interested in
you.”
121. Black once similarly made a comment about a woman with whom he allegedly had
been having a sexual relationship. This woman, Jane Doe 1, was an attractive, Russian-speaking
woman, and only a few years older than Ms. Ganieva. Black referred to Ms. Doe 1 as now being
122. Black also told Ms. Ganieva that Epstein had an attraction to ballerinas.
Disgustingly, Black boasted to her that he introduced Epstein to dancers at a ballet company that
Black had connections to, and to which Epstein had apparently donated money. Appalled, Ms.
123. Black constantly made it a point to remind Ms. Ganieva about how close he was
with Epstein, and how well-connected Epstein was to rich and powerful people. Black wanted her
to believe that he was behind her introductions to other powerful men who had ties to Epstein,
124. Based on Black’s best friend status with Epstein, it is certain that he knew Ghislaine
Maxwell (“Maxwell”). Maxwell has been dubbed as Epstein’s “madam,” and has been charged by
the federal government with the crimes of enticement of minors and sex trafficking of underage
girls, stemming from her connection to Epstein’s sex trafficking ring. Among other criminal acts,
13
Years later, it was reported that Epstein preyed on young dancers using the promise of
advancing their careers. Claire Lampen, Report: Jeffrey Epstein Used NYC Dance Studios As
Recruiting Grounds, (Sept. 3, 2019), https://gothamist.com/news/report-jeffrey-epstein-used-nyc-
dance-studios-recruiting-grounds
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Maxwell has been accused of personally recruiting and grooming underaged girls and young
125. In the fall of 2013, Ms. Ganieva was approached by Maxwell at a restaurant/lounge.
On the day in question, Maxwell aggressively tried to speak with Ms. Ganieva, and told her that
126. Maxwell told Ms. Ganieva that she wanted to “help [her] get a passport” and that
she “must call her.” Maxwell then handed Ms. Ganieva her business card. Ms. Ganieva had no
idea who Maxwell was, or that she was connected to Epstein, and thought her behavior was
127. Upon information and belief, Black had pushed Maxwell on Ms. Ganieva, likely
through Epstein, after Ms. Ganieva repeatedly rebuked Black’s attempts to “help” Ms. Ganieva
with her immigration status, which would have only pulled Ms. Ganieva further within Black’s
128. Notably, on multiple occasions, including during the 2015 discussions in which
Black pressured Ms. Ganieva into agreeing to a non-disclosure agreement described below, Black
threatened Ms. Ganieva against talking about Epstein and Epstein’s relationship with Black.
129. Black would warn that Ms. Ganieva would “die” if she ever spoke about Epstein
and Epstein’s relationship with Black, and that he would pay people to destroy Ms. Ganieva’s life
VI. Black’s “Conveyor Belt of Women” and the Absurdity of His Extortion Defense
130. For many reasons, Black’s claim that Ms. Ganieva attempted to extort him by
threatening to make their relationship publicly known, which allegedly induced him to pay her
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131. Perhaps the biggest flaw in Black’s manufactured narrative is that, like Ms. Ganieva,
Black made no attempt to keep secret the many women with whom he was involved throughout
the years. As he often bragged to Ms. Ganieva, Black had a “conveyor belt of women” available
to him.
132. Black did not attempt to keep these women hidden from anyone, much less his
family. Black openly traveled in social circles, including with Epstein, where men with excessive
wealth like him had access to an endless supply of available, single young attractive women. It
was no secret among those that know Black that he had a preference for Russian-speaking women,
including many like Ms. Ganieva, who were young, had modeling experience, and may have newly
arrived in the U.S. and thus did not have an extensive family or support system here.
133. Quite simply, if Black was trying to hide the fact that he was involved with women
other than his wife, including young, Russian-speaking models, he did an extremely poor job,
particularly for someone who founded and ruthlessly ran a publicly traded global hedge fund with
134. Worse, there were occasions where Ms. Ganieva found herself attending the same
social functions as Black and his wife. Black made absolutely no effort to keep his wife and Ms.
Ganieva away from one another. Black openly pursued Ms. Ganieva at these events in front of his
wife. By way of example only, this included an event in the Hamptons that took place in the
summer of 2011.
135. In that same summer, Black brought Ms. Ganieva over to his home in the Hamptons
and tried to convince her to sleep with him in the house. When Ms. Ganieva asked Black where
his wife was, he told her that she was in the “main house.” In other words, Black had brought Ms.
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Ganieva to his home in order to sleep with her in what was apparently a guest house, all while his
136. On another occasion, as Black and Ms. Ganieva were either entering or exiting
Black’s studio apartment located in a building on the southwest corner of 72nd and Park Avenue
where they would usually meet, they encountered Black’s wife on the street as she was walking
towards her car. Black did not act surprised or worried in any way. In fact, there would have been
no reason to be surprised given that the apartment in which Black lived with his family was located
in a building on the northwest corner of 72nd and Park Avenue, i.e., directly across from his studio.
Black even brought Ms. Ganieva to the apartment where Black and his family lived.
137. Surely if Black was worried about his wife or family knowing about his relationship
with Ms. Ganieva, he would have chosen an apartment slightly farther away from where they all
138. Black even brought Ms. Ganieva to his family’s home in Bedford, New York,
demonstrating that his relationship with Ms. Ganieva was anything but secretive.
139. Black also openly told Ms. Ganieva about the other women with whom he was
involved. Ms. Ganieva even met several of the other women in Black’s life.
140. For instance, a Russian woman that Ms. Ganieva knew, Jane Doe 2, had confided in
her about problems with a man with whom she was involved. At the time, Ms. Ganieva had yet to
meet Black. Ms. Doe 2 confided in Ms. Ganieva that she was “exhausted” by a man with whom
she was in a relationship with and could not wait to move on her with life because she could no
longer endure him any longer. Ms. Doe 2 kept repeating the words, “I just cannot.” Ms. Ganieva
had no idea that Ms. Doe 2 was referring to Black. Ms. Ganieva thought that Ms. Doe 2 looked
fragile, frightened and very jumpy, as if she had suffered from post-traumatic stress disorder.
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141. It was only a few months later that Black told Ms. Ganieva that he had been sexually
142. Ms. Doe 2 told Ms. Ganieva that she was introduced to Black by Epstein. Ms. Doe
2 further told her that Epstein gave her advice about how to handle her relationship with Black.
143. Upon information, Ms. Doe 2 was another victim of abuse and misconduct at the
hands of Black.
144. It defies credibility for Black to message to the public that he merely had a
“professional” relationship with Epstein when Epstein was introducing Black to single young
145. Moreover, at the previously mentioned summer 2011 social event at the Hamptons
in which Ms. Ganieva encountered Black and his wife, Black was also seen hugging and being
affectionate with a Russian woman named Jane Doe 3. It was obvious that Black was involved
146. Another Russian woman that knew Ms. Ganieva and Ms. Doe 3, told Ms. Ganieva
that she should behave more like Ms. Doe 3 when it came to Black, implying that Ms. Doe 3 knew
147. Black was clearly not afraid to show affection for another woman in his wife’s
presence, nor to boast to Ms. Ganieva about his other relationships to make it clear to her that he
148. Further, in or about late 2011, early 2012, while Black continued to pursue Ms.
Ganieva no matter how many times she tried to end the intimacy and abuse cycle, Black also
became sexually involved with another Russian-speaking model, Jane Doe 4, who was even
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149. Black in no way attempted to hide his sexual relationship with Ms. Doe 4 from Ms.
Ganieva, or anyone else. In fact, one day in the fall of 2012, while Ms. Ganieva was walking on a
Manhattan street, she encountered Black walking along with Ms. Doe 4. No effort to avoid her
was made.
150. Perhaps not shockingly, like Ms. Ganieva, Black paid for Ms. Doe 4 to attend
Columbia University.14
151. Ms. Doe 4 would come up to Ms. Ganieva at Columbia and at social events and try
to speak with her. Ms. Ganieva thought it was strange and inappropriate that Ms. Doe 4 did this
152. Bizarrely, Black moved Ms. Doe 4 into an apartment near where Ms. Ganieva lived,
and even bought her a Steinway piano, just as he had for Ms. Ganieva.
153. Again, Black made no effort to hide his relationship with Ms. Doe 4, but rather
14
Significantly, Black also financed the college tuition for Ms. Doe 2 – at the same time he
was doing so for Ms. Doe 4 and Ms. Ganieva. Black’s claim that it was Ms. Ganieva who asked
him for money to help with school is false. Presumably, Black will claim that Ms. Doe 2 and Ms.
Doe 4 also were the ones to ask Black for thousands of dollars to fund their education in the U.S.
– which provided them the ability to remain in the U.S., despite their lack of citizenship. Epstein
similarly offered to and did in fact foot education costs for numerous young women that he sexually
assaulted. Tara Palmieri, The Women Who Enabled Jeffrey Epstein, POLITICO, (May 14, 2021),
https://www.politico.com/news/magazine/2021/05/14/jeffrey-epstein-investigation-women-
487157, (“In an email to POLITICO, Oh characterized Epstein’s offers of tuition and the SoHo
studio as tools of his ‘prolonged and repeated’ sexual abuse.”); New Jeffrey Epstein Accuser Calls
on Prince Andrew to Talk, BBC, (Nov. 19, 2019), https://www.bbc.com/news/world-us-canada-
50469409, (“Many of the women's accounts allege they were recruited to give massages to Epstein,
with the massages leading to sexual abuse. Many also include promises made by Epstein to help
them with things like college tuition, medical expenses or advancing their careers.”)
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154. Disgustingly, he would chastise and try to guilt Ms. Ganieva for not having
threesomes with him. Black would compare Ms. Ganieva to Ms. Doe 4, who according to Black,
156. Like his relationship with Ms. Ganieva, Black took these women to high end
restaurants, and attended social events and art exhibits together. He took them shopping and spent
thousands of dollars on them. There is simply no way that Black was afraid of people seeing him
157. Importantly, Black financially supported some of these women. Black would do
this in order to hold financial control over these women. He would offer them a small glimpse at
a better life, but only under his terms, and for so long as he could continue to manipulate and control
them. Black purposely made it so that these women became indebted to him, which enabled him
to do whatever he wanted to do with or asked of them without fear of them speaking out about his
conduct.
158. In short, Black had no legitimate concern if a woman said publicly that she and
Black were involved or otherwise had sexual relations – because he did not try to keep this a secret.
159. This of course begs the question of what Black was actually concerned about
160. In 2011, Ms. Ganieva enrolled in school to finish her undergraduate degree in math.
She hoped that a degree would allow her to find a job outside of modeling.
161. Ms. Ganieva believed that going to school would occupy more of her time and make
her less available to Black. Other efforts to distance from him included cutting off most of her hair,
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believing that Black would find her unattractive. Unfortunately, these efforts had thus far been
mostly futile.
162. As it turned out, Black said that he was in favor of her returning to college, and used
163. One day in 2011, Black told Ms. Ganieva that he had arranged a loan for her.
Despite being a financial titan with teams of lawyers at his disposal, Black presented a one-page
164. As stated, the “loan” included a 5% interest rate and was payable on June 1, 2016.
165. Of course, such an amount of money was unfathomable to Ms. Ganieva and she
protested that she would never be able to pay it back. Financial control – a tried-and true tactic to
achieve dominance over another, was a method Black knew intimately and understood would place
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166. Critically, it would ensure that his criminal and deviant behavior would remain
silenced.
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167. Unsurprisingly, Black followed this initial loan with another one just like it in 2013:
168. The two “loans,” and his ability to force repayment of such an amount, allowed Black
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to exert even greater control over Ms. Ganieva. Black knew the magnitude of the harm that he had
inflicted on Ms. Ganieva over the years. This money, at least in his twisted mind, was a way of
excusing himself.
169. After Ms. Ganieva finished her math degree, Black reignited his charade of promises
to help her find a job. He convinced her that with all of his powerful Wall Street connections, he
170. Pathetically, Ms. Ganieva believed all of his promises and pursued leads for jobs
arranged by Black for over a year. In hindsight Ms. Ganieva knows that none of these arranged
interviews were meant to be legitimate. Rather, it was all part of Black’s sick plan to make her feel
grateful to him on the one hand, but also allow him to belittle and humiliate her after each job
rejection.
171. Too many examples exist of these sham interviews to detail herein, but Black used
his connections at Goldman Sachs and other financial powerhouses to arrange appointments for
her. On the surface, such interviews appeared well-meaning, such as this example:
Hello Guzel,
Just following up to the voicemail I recently left. Curious if you are
available to come onsite this
Friday May 9th from 11am to 1:30pm?
Please let me know. Thank you, Jenna
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172. As Black knew would happen, Ms. Ganieva never received an offer from any
financial company in New York. Desperate for work and falling for Black’s claims that he was
the only person that could help her, Ms. Ganieva even interviewed for jobs in London and Moscow
173. Predictably, Ms. Ganieva was rejected. By way of example only, one such rejection
email is as follows:
174. After yet another failed job interview, in desperation, Ms. Ganieva even asked Black
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if she could work as a receptionist at one of these companies. This idea was rejected by Black.
Clearly, Black preferred her instability and dependence. In fact, after yet another failed Goldman
Sachs interview, Black said, in a perversely happy manner, that he knew her “world is shitty.”
Black then used the opportunity to remind her that he is the “only one” who can help her escape
VIII. Black Rapes Ms. Ganieva, and Concocts a Scheme to Insulate Himself from Liability
and Frame Ms. Ganieva as an Extortionist
175. Ms. Ganieva always made her objection to sex with Black known. This did not
deter Black. He continued to force sex upon Ms. Ganieva even though he knew that it was against
her will. As detailed above, that was part of how Black became sexually aroused and derived
pleasure.
176. Black, understandably, was concerned about this specific information becoming
177. In the days leading up to the July 4, 2014 weekend, Ms. Ganieva became sick and
was home for a number of days, unable to go to the store or cook for herself. At the time, her child
was away at summer camp. On Sunday, July 6, 2014, Black came from the Hamptons to her
apartment on East 77th Street. Although Ms. Ganieva did not buzz him through the building
entrance, one of her neighbors must have done so, because suddenly he was knocking at her
apartment door. When Ms. Ganieva opened the door, Black barged in, pushing her off to the side.
178. Ms. Ganieva was weak and could barely walk. Disturbingly, when Black realized
179. Aware that Black wanted to have sex with her, Ms. Ganieva quickly began
protesting that she could not and would not have sex with him. She tried to tell him that she was
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180. Never a match for his physical size and strength, on this day in particular Ms.
181. At over 6’5” and more than 300 pounds, Black had no difficulty dragging Ms.
Ganieva into the bedroom and throwing her on her back on the bed. She was limp and unable to
move.
182. Despite her begging him to leave, he took off her clothes and his own. Inexplicably,
he spared Ms. Ganieva the pain of his usual sadistic rituals described in detail above, quickly got
on top of her and forced his penis into her vagina against her will. Disgustingly, when Black was
done, as he stood up and put his clothes back on, he angrily said:
183. Black then walked out – leaving Ms. Ganieva naked and unable to move on her bed.
184. Ms. Ganieva was no match for the cunning and masterful manipulation of Black or
185. Perhaps after coming to the realization that he had “gone too far” this time when he
raped Ms. Ganieva on July 6, 2014, Black “huddled up” again with his legal team – some of whom,
upon information and belief, also served as Epstein’s lawyers – to come up with a scheme to
insulate Black from criminal liability for his actions towards Ms. Ganieva.
186. The plan was to manufacture evidence that would counter the narrative that Black
forced himself onto Ms. Ganieva, and to paint Ms. Ganieva as an extortionist if she ever gained the
187. Soon after the rape, knowing that Ms. Ganieva wanted to leave New York City,
Black told her he was going to give her extra money to make this happen, suggesting it would be a
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substantial amount. As anyone would be, and as Black knew she would be, Ms. Ganieva was
extremely grateful and appreciative, as she had been wanting to leave with her son. As part of this
substantial gift of money, he commanded her to send him text messages saying that she loved him.
When Ms. Ganieva spoke to a close family member about Black’s promise of money, she
mentioned his order that she had to send texts like this. At the time, not knowing his nefarious
plans, it seemed odd but not worrisome, as Black had always insisted that Ms. Ganieva be
188. Of course, beneath this facade was the reality that Black had, in fact, been
physically, sexually and emotionally abusive towards Ms. Ganieva for years.
189. Bank records confirm that Black deposited a payment of $500,000 into Ms.
Ganieva’s bank account on July 30, 2014. Not long after, another deposit in excess of $150,000
190. Then, in 2015, after Ms. Ganieva returned to the U.S. from Russia, the second leg
191. Following the July 2014 rape, Ms. Ganieva took her son and left New York to
physically distance herself from Black. Unfortunately, she was unable to fully escape his influence
as it seemed that no matter where she traveled, inevitably, she happened to meet someone that knew
Black, including people that worked with Black at Apollo, and Black managed to always know
192. In this regard, Black often called Ms. Ganieva to tell her than he knew that she had
been at a certain event the night before, knew with whom she had been, even what she wore.
193. No matter the physical distance between them, Ms. Ganieva never stopped feeling
threatened by Black and his power and control over her. Of course, this was precisely what he
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wanted.
194. It was no surprise to Black that when Ms. Ganieva was back in New York City in
2015, she asked to meet him. Ms. Ganieva wanted to know what she could do to be able to live
her life without his continued involvement. Having planned for years about how to silence Ms.
Ganieva from revealing what he had done, Black was prepared to speak with her, especially
knowing that her two “loans” were coming due, and that she of course did not have one million
195. Black claims that he surreptitiously recorded select conversations with Ms. Ganieva.
It remains to be seen which specific conversations (and which parts thereof) were and were not
recorded.
196. Black knew that he had violently and viciously raped Ms. Ganieva in July 2014, and
that he had physically, mentally and emotionally abused her for years.
197. During their conversations, Black would speak about how she, Ms. Ganieva, could
“harm him” if she “spoke about our relationship.” Black would also say, “I want to provide for
you for the rest of your life. What is your number? How much do you need to be taken care of?”
198. Feeling pressured to respond, Ms. Ganieva blurted out a number. This made Black
happy. Clearly, the “fix” was in, and Black was giddy about Ms. Ganieva having “taken the bait.”
199. Black and Ms. Ganieva met a few additional times in 2015. During some meetings,
Black would scream, “I want to give you money… Say that you are blackmailing me.” Black
offered to make regular payments to Ms. Ganieva over a period of years so long as she agreed to
200. Ms. Ganieva told Black that she did not want to receive regular payments from him
and would not meet with his lawyers or sign any documents. Ms. Ganieva did not want to be bound
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to Black, and simply wanted to move on with her life and try to forget what Black had done to her.
Ms. Ganieva made it clear that all she wanted was for Black’s harassment of and control over her
to stop, and for her remaining loan obligations to be forgiven since, as Black was well aware, she
201. Black was relentless. Black urged Ms. Ganieva to take money he was offering her
202. Simply put, it was never an actual offer because refusing Black was not an option.
He reminded Ms. Ganieva that if she did not take the “deal,” i.e., his hush money, he would make
203. Black also attempted to goad Ms. Ganieva into speaking about who and when people
connected with Black had harassed her. Ms. Ganieva repeated stories about people she had
encountered who claimed to or appeared to know Black, and how some of them had mistreated her.
Black sought to extract more and more details about some of these incidents. This was all of course
a ploy on Black’s part to make Ms. Ganieva seem paranoid (and he would become elated and giggle
when Ms. Ganieva said something that he thought made her seem so), in support of his quest to
204. Black eventually told Ms. Ganieva that he would pay her $100,000 every month and
a certain sum of money to help with her immigration status, but only if she agreed to make it seem
like it was her idea that Black pay her substantial sums of money in exchange for her silence.
205. Black told Ms. Ganieva that she would receive continuing payments for as long as
she kept her mouth shut about all the things Black had done and said to her, as well as what she
knew about Black’s relationship to Epstein. Black threatened Ms. Ganieva’s safety if she did not
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206. Eventually, after friends of Ms. Ganieva pressured her into agreeing to Black’s
proposal for fear of what he would do to her if she refused, Ms. Ganieva reached out to Black, told
him she did not want to fight with him any further, and would accept his money.
207. Black then set up one last meeting at the Four Seasons restaurant on October 18,
208. Ms. Ganieva was nervous and had difficulty understanding what it said. She
understood that it involved confidentiality -- what she later learned is referred to as a nondisclosure
agreement (“NDA”).
210. As to the other terms, she only read them once, quickly, and is unsure what other
211. There was no space on the document for Black to sign; only Ms. Ganieva.
212. After she signed, he handed her another piece of paper which looked to be a copy
“[I will be paying you] as long as you keep your mouth shut.”
214. Black refused to give her a copy. He left with the documents. 15
215. While Ms. Ganieva desperately wanted to get out of there, Black forced her to wait
15
There is no way for Ms. Ganieva to be sure that the language in the second piece of paper
matches the language in the first document. Although it appeared to be the same, to this day she
cannot be sure what either document contains.
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216. While Black apparently made recordings of their conversations that he claims
support his version of what happened, in reality, it was Black who was heavy-handedly trying to
force Ms. Ganieva to keep silent about his years-long sexual, mental and emotional abuse in
217. From that time until April 2021, Ms. Ganieva received regular payments from
218. Prior to November 2015, whenever Black transferred money into her account, her
bank statement recorded the funds as from “Leon D. Black,” or “J. Black Trust Account.” Ms.
Ganieva has no knowledge as to why payments began from the “E Trust,” where the money from
219. Over the years, Ms. Ganieva asked Black numerous times to obtain a copy of what
she signed that day. He refused to respond. By way of example only, in 2019 she wrote to him:
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mentioned January 25, 2021 “retirement” announcement, of Black’s character and representation
of his clean hands deeply upset Ms. Ganieva. Black knew what he had done to her, and that Ms.
Ganieva considered many of his sexual acts to have been against her will and consent.
224. Having enrolled in law school, Ms. Ganieva had a greater understanding of what
Black had done to her physically and what he had coerced her into signing in connection with the
225. Knowing that Black was the one who had committed unlawful acts on her and
likely other vulnerable women, and despite the threats he made to her to coerce her into signing,
or knowing that whatever money she received from the mysterious E Trust may cease, Ms.
Ganieva finally had the courage to say what her experience with Black had been.
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226. On March 17, 2021, Ms. Ganieva posted on Twitter the following:
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229. For all of the reasons detailed above, everything Black said in the above statement
230. Black’s statement published on April 8, 2021 was made with malice.
231. Black knew that he issued a false statement of facts to Bloomberg or made the
16
Gillian Tan, Black Says He Paid to Hide Affair, Denies It Led to Apollo Exit, Bloomberg,
(April 8, 2021, 10:04 PM), https://www.bloomberg.com/news/articles/2021-04-09/black-says-he-
paid-to-hide-affair-denies-it-led-to-apollo-exit.
17
Josh Kosman, Robert Kraft resigns from Apollo board amid Epstein controversy, the New
York Post, (April 12, 2021, 2:09 PM), https://nypost.com/2021/04/12/robert-kraft-resigns-from-
apollo-board-amid-epstein-controversy/.
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232. Black’s decision to falsely state that Ms. Ganieva extorted him “for years” is right
from the playbook of scores of wealthy and powerful men, a number of whom have ties to Black,
who have faced similar accusations. Just a fraction of such examples are below:
19
Kyle Munzenrieder, How Tabloids Dragged Ambra Gutierrez Through the Mud After She
Accused Harvey Weinstein of Groping Her, W Magazine, (October 10, 2017),
https://www.wmagazine.com/story/harvey-weinstein-ambra-gutierrez-page-six-daily-mail-smear-
campaign.
20
Anna North, Men like Bill O’Reilly get to make a comeback. Women who speak up about
harassment lose their jobs, Vox, (May 16, 2018, 12:30 PM),
https://www.vox.com/identities/2018/5/16/17360334/bill-oreilly-returning-sexual-harassment-
fox-news-back-accusers-metoo-me-too-movement.
21
Post-Weinstein, These Are the Powerful Men Facing Sexual Harassment Allegations,
Glamour, (May 18, 2019), https://www.glamour.com/gallery/post-weinstein-these-are-the-
powerful-men-facing-sexual-harassment-allegations.
22
Tom Jackman and Deanna Paul, Alan Dershowitz countersues accuser in Jeffrey Epstein
case, then is sued by David Boies, The Washington Post, (November 8, 2019, 3:39 PM),
https://www.washingtonpost.com/crime-law/2019/11/08/alan-dershowitz-countersues-accuser-
jeffrey-epstein-case-then-is-sued-by-david-boies/.
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233. The false and defamatory statements exposed Ms. Ganieva to hostility, contempt,
234. In order to be admitted to the New York State bar, Ms. Ganieva must pass an ethics
and moral character test. Such accusations against her will negatively impact this process and
235. The false and defamatory statements imputed sexual immorality and involved
criminal activity in connection with Ms. Ganieva. Such statements will inevitably cause her harm
and damage in her ability to secure employment going forward, and in all of her relationships,
236. On June 1, 2021, Ms. Ganieva filed the instant lawsuit alleging defamation and
gender-motivated violence.
237. On July 19, 2021, Black, in a blatant act of retaliation, filed baseless counterclaims
against Ms. Ganieva for defamation, defamation per se, and breach of contract (the
“Counterclaims”) because she protested the years of abuse she suffered at Black’s hands and his
238. Black commenced the Counterclaims only after Ms. Ganieva brought this action
against him. At the time the tweets were made, on March 17, 2021, this case had not been filed
23
Ashley Cullins, Russell Simmons Says Jane Doe’s Rape Lawsuit is a “Vile” Extortion
Attempt, The Hollywood Reporter, (April 18, 2018, 6:31 PM).
https://www.hollywoodreporter.com/business/business-news/russell-simmons-says-jane-does-
rape-lawsuit-is-a-vile-extortion-attempt-1103734/.
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and nowhere were the allegations about Black’s conduct involving violations of the GMVA
239. Black’s intentions are clear, he is attempting to make good on his promise, that if
Ms. Ganieva did not comply with his whims, he would “destroy [her] life.”
240. Black has chosen to bully, threaten and intimidate by causing Ms. Ganieva to fear
that she may owe him substantial life-altering money as a result of the Counterclaims.
241. To make matters worse, Black audaciously seeks to hold Ms. Ganieva legally liable
for breach of contract under an alleged contract that Ms. Ganieva is not even in possession of and
has been requesting a copy of for years. Incredulously, despite repeated requests by counsel for
Ms. Ganieva, Black has continued to fail to produce the NDA to Ms. Ganieva to this very day.
242. The GMVA protects victims of violence that are specifically “motivated by
gender,” which occurs when the act is “committed because of gender or on the basis of gender,
243. While the GMVA does not expressly contain an anti-retaliation provision, the lack
of express “anti-retaliation” language has not prevented courts from reading robust anti-retaliation
244. Clearly, based on the purpose of the GMVA and how courts have interpreted
24
For example, 20 USC § 1681 ("Title IX"), the federal law prohibiting sex discrimination in
education, contains no anti-retaliation language. Nevertheless, in Jackson v. Birmingham Board of
Education, the United States Supreme Court held that the law prohibited retaliation against a third-
party teacher because, “if retaliation were not prohibited, Title IX's enforcement scheme would
unravel.” (544 US 167, 180 (2004)).
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245. Ms. Ganieva hereby repeats, reiterates and re-alleges each and every allegation in
246. As described above, Defendant Black has stated false information regarding, inter
alia, the circumstances surrounding his relationship with Ms. Ganieva and payments made to Ms.
Ganieva.
247. These statements were untrue and defamatory in that they falsely reported, inter
alia, that Ms. Ganieva and Defendant Black engaged in a wholly consensual relationship and that
248. Defendant Black knew or should have known that such defamatory statements were
false.
249. Defendant Black made such defamatory statements with knowledge of their falsity
250. Defendant Black’s statements constitute defamation because they impugn Ms.
Ganieva’s honesty, trustworthiness, dependability, and professional fitness and abilities by falsely
claiming, inter alia, that Ms. Ganieva engaged in a wholly consensual affair with Defendant Black
251. Defendant Black’s statements constitute defamation because they accuse Ms.
252. Defendant Black’s defamatory statements have harmed Ms. Ganieva’s professional
reputation and standing in her industry, have caused her economic harm, have caused her to incur
special damages in the form of actual pecuniary loss, including lost income, benefits, job security
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and opportunities for career advancement and have caused her embarrassment, humiliation and
emotional injury.
253. As a direct and proximate result of Defendant Black’s defamation, Ms. Ganieva
has suffered, and continues to suffer, from humiliation, loss of standing in the community, loss of
254. As a direct and proximate result of Defendant Black’s conduct, Ms. Ganieva has
suffered, and continues to suffer, harm for which she is entitled to an award of monetary damages
255. Defendant Black’s defamatory statements were malicious, willful, wanton, and
done with reckless disregard for Ms. Ganieva’s rights. As such, Ms. Ganieva is entitled to an
256. Ms. Ganieva hereby repeats, reiterates and re-alleges each and every allegation in
257. As described above, Defendant Black has stated false information regarding, inter
alia, the circumstances surrounding his relationship with Ms. Ganieva and payments made to Ms.
Ganieva.
258. These statements were untrue and defamatory in that they falsely reported, inter
alia, that Ms. Ganieva and Defendant Black engaged in a wholly consensual relationship and that
259. Defendant Black knew or should have known that such defamatory statements were
false.
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260. Defendant Black made such defamatory statements with knowledge of their falsity
261. Defendant Black’s statements constitute defamation per se because they impugn
Ms. Ganieva’s honesty, trustworthiness, dependability, and professional fitness and abilities by
falsely claiming, inter alia, that Ms. Ganieva engaged in a wholly consensual affair with Defendant
Black and that Ms. Ganieva committed a crime by extorting Defendant Black.
262. Defendant Black’s statements constitute defamation because they accuse Ms.
263. Defendant Black’s defamatory statements have harmed Ms. Ganieva’s professional
reputation and standing in her industry, have caused her economic harm, have caused her to incur
special damages in the form of actual pecuniary loss, including lost income, benefits, job security
and opportunities for career advancement and have caused her embarrassment, humiliation and
emotional injury.
264. As a direct and proximate result of Defendant Black’s defamation, Ms. Ganieva
has suffered, and continues to suffer, from humiliation, loss of standing in the community, loss of
265. As a direct and proximate result of Defendant Black’s conduct, Ms. Ganieva has
suffered, and continues to suffer, harm for which she is entitled to an award of monetary damages
266. Defendant Black’s defamatory statements were malicious, willful, wanton, and
done with reckless disregard for Ms. Ganieva’s rights. As such, Ms. Ganieva is entitled to an
267. Ms. Ganieva hereby repeats and re-alleges each and every allegation in all of the
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268. Defendant Black made defamatory statements with malice and with knowledge of
their falsity and/or with a reckless disregard for their truth or falsity.
269. Defendant Black’s statements constitute defamation per se because they impugn
270. Defendant Black’s defamatory statements have harmed Ms. Ganieva’s professional
reputation and standing in her industry, have harmed her personal reputation, have caused her
economic harm, have caused her to incur special damages in the form of actual pecuniary loss,
including lost income, benefits, job security and/or opportunities for career advancement, and have
271. As a direct and proximate result of Defendant Black’s defamation, Ms. Ganieva
has suffered, and continues to suffer, from humiliation, loss of standing in the community, loss of
self-esteem and public esteem, public disgrace and physical and emotional distress.
272. As a direct and proximate result of Defendant Black’s conduct, Ms. Ganieva has
suffered, and continues to suffer, harm for which she is entitled to an award of monetary damages
273. Defendant Black’s defamatory statements were malicious, willful, wanton, and
done with reckless disregard for Ms. Ganieva’s rights. Therefore, Ms. Ganieva is entitled to an
274. Ms. Ganieva hereby repeats, reiterates and re-alleges each and every allegation in
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275. Defendant Black engaged in conduct toward Ms. Ganieva that is extreme and
outrageous so as to exceed the bounds of decency in a civilized society; namely by, inter alia,
subjecting her to defamatory statements and publicly accusing her of the crime of extortion.
276. These actions were taken with intent to cause, or disregard for, the substantial
277. As a direct and proximate result of Defendant Black’s extreme and outrageous
278. Defendant Black’s conduct was wanton, malicious, willful and/or cruel, entitling
279. Ms. Ganieva hereby repeats, reiterates and realleges each and every allegation in
280. The above-described conduct of Defendant Black, including, but not limited to,
Defendant Black’s sexual assaults and rapes of Ms. Ganieva constitutes a “crime of violence” and
a “crime of violence motivated by gender” against Ms. Ganieva as defined by the New York City
Gender Motivated Violence Act, N.Y.C. Admin. Code § 8-901 et seq. (2017).
281. The above-described conduct of Defendant Black, including, but not limited to,
Defendant Black’s sexual assaults and rapes of Ms. Ganieva, constitutes a “crime of violence”
against Ms. Ganieva motivated: (i) by her gender; (ii) on the basis of her gender; and/or (iii) due,
282. Defendant Black committed a “crime of violence” against Ms. Ganieva because she
is a woman and, at least in part, because he has an unlawful animus towards women. Defendant
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Black’s gender-motivated animus towards women is demonstrated by, among other things, his
Ms. Ganieva 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
284. Defendant Black’s gender-motivated violence against Ms. Ganieva entitles her to
285. Ms. Ganieva hereby repeats, reiterates and realleges each and every allegation in
286. The above-described conduct of Defendant Black, including, but not limited to,
Defendant Black’s filing of counterclaims against Ms. Ganieva, constitutes retaliation under the
GMVA.
counterclaims against Ms. Ganieva as a result of her protected action of filing GMVA claims
against Black .
288. A cause of action for retaliation furthers the remedial purpose of the GMVA.
289. As a direct and proximate result of the aforementioned retaliation in violation of the
GMVA, Ms. Ganieva 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
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290. Defendant Black’s retaliation against Ms. Ganieva entitles her to punitive damages,
WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against
complained of herein violate the laws of the State of New York and the City of New York;
officers, owners, agents, successors, employees and/or representatives, and any and all persons
acting in concert with them, from engaging in any such further unlawful conduct, including the
for all non-monetary and/or compensatory damages, including, but not limited to, compensation
E. An award of damages for any and all other monetary and/or non-monetary losses
suffered by Plaintiff, including, but not limited to, loss of income, reputational harm and harm to
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H. Dismissal of the Defendant’s retaliatory counterclaims, and costs and fees incurred
in defense thereof;
I. 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 attorneys’ fees and costs to the fullest
J. Such other and further relief as the Court may deem just and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein.
WIGDOR LLP
By: _____________________________
Jeanne M. Christensen
Tanvir H. Rahman
Lindsay M. Goldbrum
85 Fifth Avenue
New York, NY 10003
Telephone: (212) 257-6800
Facsimile: (212) 257-6845
[email protected]
[email protected]
[email protected]
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