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Judge Finds Epstein-Related Plaintiff Lies, Spoliation, and Lawyer Misconduct in Rape Lawsuit Against Investor Leon Black

The judge sanctions the plaintiff and the lawyer, but allows the case to go forward.

Eugene Volokh | 4.25.2026 6:17 PM

A short excerpt from Thursday's 76-page decision by Judge Jessica Clarke (S.D.N.Y.) in Doe v. Black (see also this article yesterday by Politico [Erica Orden]):

This case is an action under the New York City Victims of Gender-Motivated Violence Protection Law. Plaintiff Jane Doe alleges that Defendant Leon Black brutally raped and assaulted her in New York City in 2002, when she was only sixteen years old. She claims that prior to this assault, she was abused and groomed by Jeffrey Epstein ("Epstein") and Ghislane Maxwell ("Maxwell")—who then trafficked her to other men, including Defendant.

Although the parties have exchanged almost no discovery, Defendant brings a Motion for Case-Terminating Sanctions based on lies, fraud, and spoliated evidence that he contends render this case rotten to the core. Ultimately, the Court finds that both Plaintiff's former attorney Jeanne Christensen ("Ms. Christensen"), on behalf of Wigdor LLP ("Wigdor"), and Plaintiff Jane Doe have engaged in serious, sanctionable misconduct in this case. However, taking seriously its obligation to remedy prejudice with lesser sanctions where........

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