Complaint,Petition: Cheri Pierson v. Leon Black, Estate Of Jeffrey E. Epstein, Darren K. Indyke in his capacity as the Executor for the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust, Richard D. Kahn in his capacity as the Executor for the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust, The 1953 Trust

On November 28, 2022 a Complaint,Petition was filed involving a dispute between Cheri Pierson, and Darren K. Indyke In His Capacity As The Executor For The Estate Of Jeffrey E. Epstein And Administrator Of The 1953 Trust, Estate Of Jeffrey E. Epstein, Leon Black, Richard D. Kahn In His Capacity As The Executor For The Estate Of Jeffrey E. Epstein And Administrator Of The 1953 Trust, The 1953 Trust, for Torts - Adult Survivors Act in the District Court of New York County.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------------X
CHERI PIERSON, :
:
Plaintiff, : Civil Action No.:
:
v. :
: SUMMONS
LEON BLACK, ESTATE OF JEFFREY E. EPSTEIN, :
DARREN K. INDYKE, in his capacity as the EXECUTOR :
FOR THE ESTATE OF JEFFREY E. EPSTEIN and :
ADMINISTRATOR OF THE 1953 TRUST; :
RICHARD D. KAHN, in his capacity as the EXECUTOR :
FOR THE ESTATE OF JEFFREY E. EPSTEIN and :
ADMINISTRATOR OF THE 1953 TRUST; and THE 1953 :
TRUST, :
:
Defendants. :
-------------------------------------------------------------------------X

To the above-named Defendants:

YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve

a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of

appearance on the Plaintiff’s attorney within twenty (20) days after service of this summons,

exclusive of the day of service (or within thirty (30) days after the service is complete if this

summons is not personally delivered to you within the State of New York); and in case of your

failure to appear or answer, judgment will be taken against you by default for the relief demanded

in the complaint.

Venue is proper as Defendant Leon Black resides in New York County and a substantial

part of the events giving rise to Plaintiff’s claims took place in New York County. Plaintiff

designates NEW YORK COUNTY as the place of trial.

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Dated: November 28, 2022
New York, New York Respectfully submitted,

WIGDOR LLP

By: _____________________________
Jeanne M. Christensen
Renan F. Varghese

85 Fifth Avenue
New York, NY 10003
Telephone: (212) 257-6800
Facsimile: (212) 257-6845
jchristensen@wigdorlaw.com
rvarghese@wigdorlaw.com

Counsel for Plaintiff

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------------------------------------------- X
CHERI PIERSON, :
:
Plaintiff, : Civil Action No.:
:
v. :
: COMPLAINT
LEON BLACK, ESTATE OF JEFFREY E. EPSTEIN, :
DARREN K. INDYKE, in his capacity as the :
EXECUTOR FOR THE ESTATE OF JEFFREY E. : Jury Trial Demanded
EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; :
RICHARD D. KAHN, in his capacity as the EXECUTOR :
FOR THE ESTATE OF JEFFREY E. EPSTEIN and :
ADMINISTRATOR OF THE 1953 TRUST; and THE :
1953 TRUST, :
:
Defendants. :
----------------------------------------------------------------------- X

Plaintiff Cheri Pierson (“Plaintiff”) through her lawyers Wigdor LLP, brings this Complaint

against Defendants Leon Black (“Black”), the Estate of Jeffrey E. Epstein (“Estate”), the 1953

Trust (“The Trust”), Darren K. Indyke (“Indyke”) and Richard D. Kahn (“Kahn”) in their capacities

as the Executors for the Estate of Jeffrey E. Epstein, and Administrators of the 1953 TRUST

(collectively “the Epstein Defendants”), and hereby alleges as follows:

PRELIMINARY STATEMENT

1. In the spring of 2002, on a weekday in the late afternoon, Ms. Pierson was raped by

Black.

2. Black’s brutal attack took place in a secluded and private area where no one could

see Black or hear Ms. Pierson scream.

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3. Black raped her on the third floor of Jeffrey Epstein’s (“Epstein”) Manhattan

mansion located at 9 East 71st Street, in a private suite that contained a massage table and was

connected to a bathroom.

4. After riding up in the elevator to the third floor with Black, Ms. Pierson entered the

massage suite believing that she would give Black a massage and receive the money that had been

promised her in exchange. Money that she desperately needed to help care for her young daughter.

5. By the time Ms. Pierson exited the massage suite and rode down the elevator with

Black, she could barely walk out of the house onto the sidewalk, as she was in excruciating pain

and still in shock. Black callously announced that his driver was waiting for him, turned his back

and left her standing at the curb.

6. Black had the opportunity and the means to rape Ms. Pierson that day because their

meeting was pre-arranged by his close friend and confidant, Epstein.

7. Several weeks before the rape, Epstein told Ms. Pierson that he was arranging for

her to meet a very powerful and wealthy man – someone who Epstein said “helps people” and

implied that he may be able to financially “help” Ms. Pierson. Epstein made the suggestion in the

context of a skincare product that Ms. Pierson was trying to market and sell. Epstein knew about

the skincare product because the two of them had discussed it many times.

8. One day, she received a call from Epstein, who said that he had arranged for her to

meet a powerful businessman. Unbeknownst to her, the man was Leon Black. Epstein told Ms.

Pierson that she was to come to his townhouse after she finished work, where she would meet

Black and give him a massage. When she asked Epstein who the mystery businessman was,

Epstein said that the man was married, and it would be up to him to tell Ms. Pierson his name or

not.

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9. When Ms. Pierson arrived at Epstein’s on the arranged date, and while she was

standing in a back hallway towards the kitchen, Black joined her in the hallway. Black made it

clear that he was the person she was to give the massage to, although he did not offer his name.

He was dressed in a business suit. Ms. Pierson assumed that they would be going upstairs but

Black made her wait because he heard people out in the main hallway, and he wanted to make

certain they left before he and Ms. Pierson ventured out.

10. Wanting to please the wealthy businessman who Epstein claimed was inclined to

help her with the skincare product, Ms. Pierson engaged him in meaningless chit chat that at one

point included commentary by both of them about the artwork on the wall in the hallway.

Eventually, they heard people who had been in the main hallway exit the house and Black said it

was time to go up.

11. Ms. Pierson knew that Black had done this before as he was the one that led the way

to the elevator and up to the massage suite on the third floor. Black already had cash for her.

12. As set forth in the horrific details below, Black wasted no time before inflicting

violence on Ms. Pierson.

13. Appallingly, there is no question that Black’s criminal conduct was facilitated and

fostered by Epstein and individuals that worked for Epstein. It is unknown how many times before

or after the rape of Ms. Pierson or whether Black had met women at Epstein’s townhouse for pre-

arranged “massages.”

14. Because Black repeatedly has stated publicly that he regularly and often visited

Epstein’s townhome, and did so for more than 20 years, he had countless opportunities to spend

secluded hours in the third-floor massage suite with unknown women, just like he did with Ms.

Pierson in 2002.

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15. For decades, Black managed to shield from public view his predatory and violent

side. Although Black believed that Ms. Pierson was a problem that he had “taken care of” and

would not come back to haunt him, pursuant to the Adult Survivor’s Act (“ASA”) Ms. Pierson

seeks to hold Black, and those that assisted him, accountable for the severe and debilitating pain

that she suffered.

JURISDICTION AND VENUE

16. The Court has personal jurisdiction pursuant to Civil Practice Law and Rules

(“CPLR”) § 301, inter alia, because Defendant Black resides 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, including at Epstein’s

home located at 9 East 71st Street, New York, New York.

PARTIES

18. Plaintiff Cheri Pierson currently resides in Virginia.

19. At all relevant times and presently, Defendant Leon Black resides in New York,

New York.

20. Jeffrey E. Epstein was found dead on August 10, 2019 while in federal custody in

New York, New York for sex crimes. At the time of his death Epstein, who had multiple

residences, continued to reside at his home located at 9 East 71st Street, New York, New York.

21. Defendant the Estate of Jeffrey E. Epstein, which was created upon Epstein’s death,

is domiciled in the U.S. Virgin Islands (“USVI”). 1

1
On August 15, 2019, Defendants Indyke and Kahn filed a Petition for Probate and Letters
Testamentary which included Epstein’s last will and testament with the Probate Division of the
Superior Court of the Virgin Islands.

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22. Defendant The 1953 Trust was created by Epstein, and on August 8, 2019, Epstein

“amended and restated” its terms. That same day, Epstein revised his Last Will and Testament,

transferring all of his “property, real and personal, wherever situated” to The Trust. On August 26,

2019, the executors of the Estate, Indyke and Kahn, filed a Certificate of Trust in the Superior

Court of the Virgin Islands for The Trust.

23. Darren K. Indyke is co-executor of the Estate and Administrator of the Trust.

24. Richard D. Kahn is co-executor of the Estate and Administrator of the Trust.

I. FACTUAL ALLEGATIONS

A. Epstein’s Death, Will, Probate and the Trust

25. On July 6, 2019, Epstein was indicted by the Unites States Attorney’s Office for the

Southern District of New York, for sex crimes involving minors. 2

26. While in custody in the Metropolitan Correctional Center, on August 10, 2019,

Epstein was found dead in his jail cell. A New York City medical examiner concluded that Epstein

died by suicide.

27. On August 15, 2019, Epstein’s last will and testament (the “Will”) was filed in the

Probate Division of the Superior Court of the USVI.

28. The Will was executed by Epstein on August 8, 2019, and it was accompanied by

affidavits from Indyke and Kahn attesting to their “Oath of Willingness to Serve as Executor and

Appointment of Local Counsel.” Indyke and Kahn filed a Petition for Probate and for Letters

Testamentary in the Superior Court of the USVI. The Will’s first article directs Epstein’s executors

“to pay from my estate all expenses of my last illness, my funeral and burial expenses, the

2
https://www.justice.gov/usao-sdny/press-release/file/1181016/download

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administration expenses of my Estate and all of my debts duly proven and allowed against my

estate.”

29. The Will further directs that “after the payments and distributions provided in

Article FIRST,” Epstein “give[s] all of my property, real and personal, wherever situated…to the

then acting Trustees of the 1953 Trust.” On August 15, 2019, Indyke and Kahn petitioned the court

in the USVI for Epstein’s Will to be admitted to probate and to be authorized to administer the

estate. 3 On August 26, 2019, Indyke filed a Certificate of Trust with the Superior Court for the

USVI, affirming that he and Kahn are the two Trustees of the Trust. 4 See 68.

B. Leon Black’s Relationship with Jeffrey Epstein

30. There remains much mystery surrounding Epstein and how he became an ultra-

wealthy and powerfully connected person.

31. Epstein had a modest upbringing in Coney Island, New York, did not earn a college

degree, and first worked as a high school math teacher in Manhattan. Yet from there, Epstein

somehow rose to become an extremely wealthy person, with properties all over the world, who

spent his time with 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, billionaires Les Wexner, Glen Dubin and Defendant Black, Jes Staley,

Alan Dershowitz, Bill Gates and countless others.

3
Petition for Probate and for Letters Testamentary, In the Matter of the Estate of Jeffrey E.
Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 15, 2019),
https://www.vicourts.org/common/pages/DisplayFile.aspx?itemId=15998283.
4
Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-
PB-80 (Super. Ct. V.I. Aug. 26, 2019),
https://www.vicourts.org/common/pages/DisplayFile.aspx?itemId=15998303.

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32. It remains a matter of debate as to why Epstein received only a mild “slap on the

wrist” despite operating an allegedly sophisticated sex trafficking ring in Palm Beach, Florida that

was only exposed when numerous girls came forward and accused Epstein of engaging in sex acts

with them while they were under the age of 18, including some as young as 13. Despite the dearth

of accusers, in 2008, Epstein was allowed to plead guilty to just one count of soliciting an underage

prostitute. He served just 13 months in the Palm Beach County Stockade, during which numerous

news reports claim that Epstein regularly was granted unsupervised visits from women.

33. 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

Epstein with sex trafficking and conspiracy to commit sex trafficking.

34. Following Epstein’s arrest, during a July 31, 2019 earnings call, Black told Apollo

investors (Apollo is the publicly traded private equity firm with over $400 billion in assets under

management founded by Black and where he served as then-Chairman and Chief Executive Officer

(“CEO”)), 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).

35. 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

Epstein committed suicide by hanging.

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36. On October 12, 2020, the New York Times published an article 5 revealing that Black,

one of the world’s wealthiest persons, with a net worth estimated at close to $10 billion, had paid

Epstein tens of millions of dollars after Epstein’s 2008 conviction.

37. In response, Black, in an October 12, 2020 letter to Apollo’s Limited Partners, stated

again that:

“I was completely unaware of, and continue to be appalled by, the
reprehensible conduct that surfaced at the end of 2018 and led to the
federal criminal charges brought against Epstein.”

“There has never been an allegation by anyone, including the New
York Times, that I engaged in any wrongdoing or inappropriate
conduct.”

38. Later that month, during an October 29, 2020, earnings call (“October 2020

earnings call”), Black reiterated that:

“there has never been an allegation by anyone that I engaged in any
wrongdoing, because I did not. And any suggestion of blackmail or
any other connection to Epstein’s reprehensible conduct is
6
categorically untrue.”

39. During this earnings call, Black also said:

“Had I known any of the facts about Epstein’s sickening and
repulsive conduct, which I learned in late 2018, more than a year
after I stopped working with them, I never would have had anything
to do with him.” (emphasis added)

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.
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/.

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C. The Falsity of the Dechert Report

40. Following the October 12, 2020 New York Times article, Apollo hired the law firm

of Dechert LLP (“Dechert”) to “investigate” Epstein’s ties to Black and to Apollo.

41. Dechert was also tasked with creating a report to submit to the Securities and

Exchange Commission (“SEC”) (the “Report”).

42. On or around January 22, 2021, Dechert released its Report 7 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

17-year-old prostitute.” (Report at 6, emphasis added). Of course, itwas widely reported that

Epstein had had sex with countless underaged girls, and not merely a massage on one occasion

from a prostitute.

43. Black claimed to Dechert that, as a result of what Epstein supposedly told him about

the nature of his conviction, he thought it was appropriate 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 also “name-dropping” his relationships with Michael Milken and Martha Stewart, two

individuals that had served prison time. Id.

7
The complete Dechert Report is available here:
https://www.sec.gov/Archives/edgar/data/1411494/000119312521016405/d118102dex99
1.htm (“Exhibit 99.1”).

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44. 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” and who he confided on personal

matters, attended social events with, and introduced to his family. Id. at 7.

45. 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).

46. The complete falsity of this statement, disgustingly, is blatant.

47. As Black knows, from as early as 2008 and continuing through the present, Epstein

purposefully introduced Black to certain women with whom Epstein had had ongoing sexual

relationships with while these women were underage. When they were no longer attractive to

Epstein because his preference was for pubescent girls, Epstein simply passed some of these

women on to Black, and likely to other men. Black, thereafter, became involved sexually with

these women, at least several of whom had been with Epstein for years while underage.

48. There can be no doubt that Black knew about their prior involvements with Epstein,

indeed, that is how they were introduced to Black. Several of these women, whose identities are

known but are being protected for their privacy herein, were sexually involved with Black for more

than a decade, including through the present. 8

8
Several of these women, referred to only as Jane Does, are included in the allegations of
Guzel Ganieva, in her Complaint filed against Black in New York State Court, entitled Ganieva v.
Black, Index No. 155262/2021, filed in New York County, Supreme Court.

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49. Despite this sharing of sexual partners between Epstein and Black, and Black’s

financial support for some of these women for years, the Dechert Report repeatedly represents that

Black had no knowledge that Epstein engaged in sexual relationships with underage girls.

50. Although the Report had the appearance of a legitimate independent investigation,

as Dechert must admit, any “conclusions” contained in the Report were based on nothing more

than voluntary statements provided by (unnamed) voluntary 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.

51. Significantly, in connection with the SEC filed Report, no one 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.

52. 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.

53. The Report repeatedly and conveniently emphasizes that during the time Epstein

served his prison sentence in Florida, “Black had no client relationship with Epstein at the

time.” Id. at 6.

54. 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

estate planning — “for the overall value he believed Epstein was providing to him through

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Epstein’s advice on trust and estate planning, tax issues, philanthropic issues, and the operation of

[Black’s] Family [wealth management] Office.” Id. at 17.

55. In a January 25, 2021 statement, Black once again said that he knew nothing about

Epstein’s sexual deviance:

“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.”

56. Disgustingly, in what can only be described as the epitome of irony and

disingenuousness based on Ms. Pierson’s experiences, Black said:

“Having reflected at great length on my professional relationship
with Mr. Epstein, … I have also decided that one way I can begin to
address the grievous error of having maintained a professional
relationship with Mr. Epstein is to pledge $200 million towards
initiatives that seek to achieve gender equality and protect and
empower women, including … helping survivors of domestic
violence, sexual assault and human trafficking.” (emphasis added)

57. To date, no public information is available about whether any of the “$200 million

pledge” has been gifted to any individuals, groups or organizations, much less those involved in

preventing domestic abuse, sexual assault, rape or human trafficking.

D. By 1998, Black Asks Jeffrey Epstein to Serve as the Only “Director” of His
Private Family Foundation, the “Leon Black Family Foundation”

58. Contrary to Black’s recent revisionist history, beginning in the 1990s, he and

Epstein were extremely close friends and confidants, not mere business acquaintances.

59. By 1998, Black asked Epstein to serve as the only “Director” of his private

investment fund, the Leon Black Family Foundation, Inc. (the “Family Office”). Black was the

President and Treasurer, and Debra Black, his wife, was the Vice President and Secretary.

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According to documents submitted to the IRS, Black, his wife and Epstein devoted about four hours

a week to serving in their respective roles.

60. By 2001, the Family Office was disbursing more than $2.5 million to various

groups, including but not limited to Dartmouth College, Jewish Museum, Lincoln Center for

Performance, American Ballet Theatre, the Robinhood Foundation, Museum of Modern Art,

Beaver Creek Arts Foundation, Metropolitan Museum of Art, the Spence School and Trinity

School.

61. Black, his wife Debra Black and Epstein continued to serve as the only executives

of the Family Office from 1997 through at least 2012. During this time, other groups were

beneficiaries of the distributions, including the Miami City Ballet, Harvard Business School, and

the Tony Blair Faith Foundation, now the Tony Blair Institute for Global Change – which also

received tens of millions from the Bill and Melinda Gates’ foundation.

62. In addition to working together to invest Black’s family foundation money, Black

has been quoted as stating that he “often” went to Epstein’s townhouse on East 71st Street,

sometimes early in the day for breakfast meetings.

63. As detailed in Ms. Ganieva’s State Court Complaint, Black described Jeffrey

Epstein as his “best friend” by 2008. See Second Amended Complaint, Dkt. No. 155, Ganieva v.

Black, Index No. 155262/2021.

64. When Ms. Pierson first met Epstein and Ghislaine Maxwell, it is undisputed that

Black and Epstein were personal friends, and also through the Family Office, had business

connections.

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II. PLAINTIFF IS RECRUITED INTO EPSTEIN’S FOLD

65. In 1999, Ms. Pierson was a single mother living in New Jersey with her young child

and commuting into midtown for a low wage position as a receptionist. She had suffered some

financial setbacks and was in credit card debt.

66. Sometime in 2000, a woman of Ukrainian descent, that Ms. Pierson had met through

work, began to call Ms. Pierson repeatedly, telling her that she needed to meet this rich man who

the acquaintance said she had met. This woman told Ms. Pierson that he was a wealthy man and

that he helped women like Ms. Pierson financially. She wanted to give him Ms. Pierson’s number.

67. At first, Ms. Pierson ignored the calls from the acquaintance. However, Ms. Pierson

soon began receiving calls from a woman named Maxwell, with a British accent, also about

meeting a wealthy businessman. Ms. Pierson assumed that her acquaintance had divulged Ms.

Pierson’s name and number, even though she had never given her permission to do so.

68. The caller named “Maxwell,” told Ms. Pierson that she really should meet Epstein.

Maxwell implied that she knew that Ms. Pierson needed money and suggested that as a powerful

businessman, Epstein was someone that could “help” Ms. Pierson.

69. In addition to raising a child as a single mother, Ms. Pierson had dreams of

launching a skin care product but knew that realistically, she lacked even a fraction of the money

to do so. Passionate about the skin care product, and needing money, Ms. Pierson eventually

agreed to meet Epstein.

70. Maxwell told Ms. Pierson to come to her office after she finished with her

receptionist job. Therefore, one day after work, Ms. Pierson went to 9 East 71 Street, to meet the

woman she knew as Maxwell.

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71. When Ms. Pierson entered the lavish townhouse, she was directed to an office where

she first met Maxwell, whom Ms. Pierson now knows is Ghislaine Maxwell. She met her in an

office that had a large desk and an expensive-looking rug. Maxwell appeared busy and distracted,

but made sure to tell Ms. Pierson that she was going to be introducing her to Epstein, who “picks

models for Victoria's Secret.” Ms. Pierson remembers this comment because it was strange to Ms.

Pierson. Although she looked much younger than her age and continued to do some modeling, she

knew that she was not going to be seriously considered as a Victoria’s Secret model.

72. Eventually, Ms. Pierson was introduced to Epstein. He told her all about how he

“make[s] money for rich guys” and was a philanthropist. Just when Ms. Pierson thought about

telling Epstein about her skincare product, Epstein said, “I am a massage slut…I get 2-3 massages

a day, lots of women do it and they do very well.”

73. Epstein said that he would pay Ms. Pierson $300 to give him a massage in a bikini

for 20 minutes, and she did so.

74. Over the course of months, including until at least late December 2001, Ms. Pierson

gave Epstein massages on approximately four other occasions. Each time Epstein paid Ms. Pierson

$300. Disgustingly, Epstein masturbated and wanted her to perform oral sex on him as part of the

massage, but each time she refused. Epstein was not happy and said she needed “to do more.”

75. Ms. Pierson recalls being asked to go to Epstein’s not long after the events of

September 11, 2001. She was there with a number of other guests. The event stands out in her

mind because Epstein made a vulgar and disgusting remark about the young models stranded in

NYC after September 11, 2001. Specifically, Epstein began talking about how bad itwas for

foreign models who had come for Fashion Week and now could not leave. He said that the

modeling agencies had stranded these women with no help or money. Disgustingly, Epstein

17 of 30
FILED: NEW YORK COUNTY CLERK 11/28/2022 11:29 AM INDEX NO. 952002/2022
NYSCEF DOC. NO. 1 REC

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Suzanne J. Adams Track Judge’s New Case

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Document Filed Date

November 28, 2022

Case Filing Date

November 28, 2022

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Parties

BARRETT, JENNIFER JACKSON Attorney for the Defendant
CARLINSKY, MICHAEL BARRY Attorney for the Defendant
Cheri Pierson Plaintiff
CHRISTENSEN, JEANNE-MARIE BATES Attorney for the Plaintiff
Darren K. Indyke in his capacity as the Executor for the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust Defendant
Estate of Jeffrey E. Epstein Defendant
GWYNNE, PETER ANTHONY Attorney for the Defendant
Leon Black Defendant
MOSKOWITZ, BENNET J Attorney for the Defendant
PARACHINI, ALEXANDER KITSOCK Attorney for the Defendant
PERRY, E DANYA Attorney for the Defendant
Richard D. Kahn in his capacity as the Executor for the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust Defendant
The 1953 Trust Defendant
VARGHESE, RENAN F. Attorney for the Plaintiff
DAVID COLE Attorney
STEVEN MANKET Attorney
HERBERT SUBIN Attorney
GEORGE SURGENT Attorneys for Defendants
WILLIAM UNROCH Attorneys for Plaintiffs
ROBERT BOGLE Attorneys for Plaintiffs

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