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NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 12/28/2022
Exhibit A
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------------------------------------------- x SUMMONS
GUZEL GANIEVA, :
: Plaintiff designates
Plaintiff, : NEW YORK COUNTY
v. : as the place of trial
:
LEON BLACK; : The basis of the venue is: Residence of
: Plaintiff and a substantial part of the
Defendant. : events giving rise to Plaintiff’s claims took
: place in New York County
----------------------------------------------------------------------- x
To the above-named Defendant:
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.
Dated: June 1, 2021
New York, New York Respectfully submitted,
WIGDOR LLP
By: _____________________________
Jeanne M. Christensen
Lindsay M. Goldbrum
85 Fifth Avenue
New York, NY 10003
Telephone: (212) 257-6800
Facsimile: (212) 257-6845
jchristensen@wigdorlaw.com
lgoldbrum@wigdorlaw.com
Counsel for Plaintiff
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------------X
GUZEL GANIEVA, :
:
Plaintiff, : Civil Action No.:
:
v. :
: COMPLAINT
LEON BLACK, :
:
Defendant. : Jury Trial Demanded
-------------------------------------------------------------------------X
Plaintiff Guzel Ganieva (“Plaintiff”) brings this Complaint against Leon Black (“Black”
or “Defendant”), and hereby alleges as follows:
PRELIMINARY STATEMENT
1. On April 8, 2021, Bloomberg published an article that contained the following
statements by Defendant Leon Black about Plaintiff Guzel Ganieva:
“I foolishly had a consensual affair with Ms. Ganieva that ended
more than seven years ago,” Black said in the statement Thursday.
“Any allegation of harassment or any other inappropriate behavior
towards her is completely fabricated. The truth is that I have
been extorted by Ms. Ganieva for many years and I made
substantial monetary payments to her, based on her threats to
go public concerning our relationship, in an attempt to spare my
family from public embarrassment.”
Black had previously planned to step down by the end of July as
CEO of the firm he co-founded. He said that, on advice from his
counsel, he asked criminal authorities several weeks ago to
investigate Ganieva. 1
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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2. Everything that Black said in the above statement about Ms. Ganieva is false.
First, 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 shocking, evil and exposed him to potential criminal charges.
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 brunt of his true wrath. He said many times to her:
“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.”
4. Fourth, Ms. Ganieva never “threatened to go public” about Black regarding
anything. As the people within Black’s inner circle know, the suggestion that Black attempted to
spare his family public embarrassment about a purported extramarital relationship is ridiculous.
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
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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associating him with Ms. Ganieva because he enjoyed being seen with her in public. What Black
has worried about, however, is being exposed for the sadist that he is.
6. On October 29, 2020 during an earnings call, in connection with his
announcements about his future role at Apollo Management, Black publically stated:
“There has never been an allegation by anyone that I engaged in any
wrongdoing, because I did not.”
7. This false claim of Black’s was the tipping point for Ms. Ganieva. Having
recently educated herself in law school and knowing that many of his sexual acts were against her
will and without her consent, she no longer was willing to stand by and allow him to escape
accountability.
8. Knowing that her public outing of his disgusting conduct would end any further
monetary payments from Black, 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
Ms. Ganieva to call him immediately. She refused.
10. Knowing that he could no longer control her into silence, Black resorted to the
age-old playbook used by wealthy and powerful men – he made a preemptive claim of extortion. 3
11. This textbook strategy involves overpowering the female accuser by victimizing
her one more time in a public way with threats of criminal charges. As demonstrated by Black,
this is accomplished by going to the “criminal authorities” to accuse Ms. Ganieva of extortion
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 are detailed infra at ¶ 87. Threats of extortion are potentially far more
damaging and frightening to a female accuser 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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and placing her on the legal defensive before she can take any legal action against him – just in
case she planned on doing so.
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 men like Black have enjoyed an unequal access to justice
unavailable to the average citizen and non-millionaires. Knowing the right lawyers and
politicians provided Black with the ability to do exactly as he said:
“Ask criminal authorities to investigate Ganieva.”
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. The truth will reveal a violent, sadistic
side to Black that he has shielded from public view for decades.
15. Black defamed Ms. Ganieva by making the above statements.
JURISDICTION AND VENUE
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, Westchester County.
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FACTUAL ALLEGATIONS
I. Leon Black’s Orchestrated Secrecy of His Sexual Violence and Deviance
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 in March 2008, while
attending an International Women’s Day event in NYC.
21. A single mother in her early twenties, 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.
22. This is exactly what Black did.
23. It was a choreographed plan that allowed him to quickly gain Ms. Ganieva’s trust.
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 repeated proclamations about her innate talent and intellect, and combined with a
few “arranged” appointments, for example with the Creative Artists Agency, LLC in Los
Angeles, he quickly gained her gratitude and admiration.
24. Ms. Ganieva was flattered that a successful businessman would find 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 modeling. Naïvely, Ms. Ganieva believed that Black was not
interested in her sexually, simply because she told him that their relationship would not be sexual.
25. 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
the public or his own employees.
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26. Once he did, Black forced sadistic sexual acts on her without her consent and
despite her saying no.
27. 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. Humiliated and in shock, Ms. Ganieva never
uttered a word about he had done to her.
28. 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 sexual conduct against her will. 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.
29. 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
could induce her to meet him again.
30. Black’s persuasion tactics included endless promises 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 involved with to run the gallery.
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31. Despite Black’s periods of remorseful and conciliatory behavior, he nevertheless
also 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
Complaint. By way of example only, it included such things as:
Ubiquitous belittling;
Falsely accusing her of being jealous to deflect from his
own hideous conduct;
Pretending not to listen to or understand Ms. Ganieva when
she said something he did not like, especially when it
involved her attempts at cutting off communication;
Forcing her to walk behind him;
Forcing her to wait for his permission to speak;
Punishing her by yelling and screaming if she did not speak
to him “nicely”;
Insisting that she speak to him in a pleasing, pleasant or
otherwise “happy” and “nice” manner and yelling at her if
she failed to do so;
Insisting that her text messages also be sufficiently
pleasant;
Criticizing her appearance by saying she needed to lose
weight or improve certain parts of her body;
Criticizing her clothing and make-up;
Berating her for refusing to agree to threesomes with other
women and Black;
Intentionally making her feel stupid and inferior to him;
and
Physically intimidating her by such acts as clenching his
fists, pounding nearby pieces of furniture, repetitive
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cracking of his knuckles and otherwise using his
formidable 6’5” and 300+ pound body to intimidate her.
II. Ms. Ganieva Returns to College
32. 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.
33. 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, believing that Black would find her unattractive. Unfortunately, these efforts had thus
far been mostly futile.
34. As it turned out, Black said that he was in favor of her returning to college, and
used the situation to convince Ms. Ganieva to sign a “loan” with Black.
A. The First $480,000 Loan
35. 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 to her a one-
page document, set forth below.
36. As stated, the “loan” included a 5% interest rate and was payable on June 1, 2016.
37. 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 Ms. Ganieva in his debt forever.
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38. Critically, it would ensure that his criminal behavior would remain silenced.
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B. The Second $480,000 Loan
39. Unsurprisingly, Black followed this initial loan with another one just like it in
2013:
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40. The two “loans” and his ability to force repayment of such an amount allowed
Black 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.
41. After Ms. Ganieva finished her math degree, Black reignited his charade of
promises to help her find a “real job” outside of modeling. He convinced her that with all of his
powerful Wall Street connections, he would find her a job.
42. 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.
43. 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:
From: REDA , Jenna L. [HCM]
CTED
Sent: Wednesday, May 07, 2014 11:33 AM
To: 'Guzel Ganieva'
Subject: RE: Goldman Sachs Interview Opportunity
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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On Wednesday, May 7, 2014, REDA , Jenna L.
REDA CTED
wrote:
CTED
Hello Guzel,
Please see your interview details below:
Friday, May 9th, 2014
Interviewer Time Details:
Dana Bunting 11:00am EST 32/201
HCM TBD 11:30am EST 32/201
Pete Lyon & Alison Mass 12:00pm EST 32/201
Julie Silverman 1:00pm EST 32/301
Please keep in mind that all schedules are subject to change. When
you arrive to our building at 200 West Street in New York, our
security team will direct you.
44. 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 that Black arranged, including at Goldman Sachs in London and Moscow.
45. Predictably, Ms. Ganieva was rejected. By way of example only, one such
rejection email is as follows:
On Saturday, November 29, 2014, RED , Pete
RED ACT
wrote:
ThanksACT Guzel…in short, I think we just have to be patient for
now…we have explored many options internally and, given the
macro environment, there are no open jobs at Goldman Sachs right
now that work for/are a fit for you…I also saw Paolo a few weeks
ago in NYC and he told me he would keep his eyes open for you in
Moscow with clients of his ifthey have roles/openings that make
sense but that there were no immediate openings he was aware
of…I wish we had better news but I think we just need to hang
tight for now and if something opens that makes sense then Paolo
and/or I will be in touch…thanks a lot.”
46. After yet another failed job interview, in desperation Ms. Ganieva even asked
Black 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
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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 her “miserable life.”
III. The Rape in July 2014
47. 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.
48. Ms. Ganieva was weak and could barely walk. Disturbingly, when Black realized
what a debilitated state she was in, he became happy.
49. 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
in a weakened state, having been sick for almost a week.
50. Never a match for his physical size and strength, on this day in particular Ms.
Ganieva knew what fate was in store.
51. At over 6’5” and 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.
52. 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 and quickly got on top
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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:
“Now I have fucked you.”
53. Black then walked out – leaving Ms. Ganieva naked and unable to move on her
bed.
54. Ms. Ganieva was no match for the cunning and masterful manipulation of Black
or his repeated and unwanted sexual conduct.
55. After this 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
Preview
FILED: NEW YORK COUNTY CLERK 12/28/2022 09:14 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 12/28/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------------------------------------------------------------- x SUMMONS GUZEL GANIEVA, : : Plaintiff designates Plaintiff, : NEW YORK COUNTY v. : as the place of trial : LEON BLACK; : The basis of the venue is: Residence of : Plaintiff and a substantial part of the Defendant. : events giving rise to Plaintiff’s claims took : place in New York County ----------------------------------------------------------------------- x To the above-named Defendant: 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. Dated: June 1, 2021 New York, New York Respectfully submitted, WIGDOR LLP By: _____________________________ Jeanne M. Christensen Lindsay M. Goldbrum 85 Fifth Avenue New York, NY 10003 Telephone: (212) 257-6800 Facsimile: (212) 257-6845 jchristensen@wigdorlaw.com lgoldbrum@wigdorlaw.com Counsel for Plaintiff 1 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------------------------------------------------X GUZEL GANIEVA, : : Plaintiff, : Civil Action No.: : v. : : COMPLAINT LEON BLACK, : : Defendant. : Jury Trial Demanded -------------------------------------------------------------------------X Plaintiff Guzel Ganieva (“Plaintiff”) brings this Complaint against Leon Black (“Black” or “Defendant”), and hereby alleges as follows: PRELIMINARY STATEMENT 1. On April 8, 2021, Bloomberg published an article that contained the following statements by Defendant Leon Black about Plaintiff Guzel Ganieva: “I foolishly had a consensual affair with Ms. Ganieva that ended more than seven years ago,” Black said in the statement Thursday. “Any allegation of harassment or any other inappropriate behavior towards her is completely fabricated. The truth is that I have been extorted by Ms. Ganieva for many years and I made substantial monetary payments to her, based on her threats to go public concerning our relationship, in an attempt to spare my family from public embarrassment.” Black had previously planned to step down by the end of July as CEO of the firm he co-founded. He said that, on advice from his counsel, he asked criminal authorities several weeks ago to investigate Ganieva. 1 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). 1 2 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 2. Everything that Black said in the above statement about Ms. Ganieva is false. First, 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 shocking, evil and exposed him to potential criminal charges. 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 brunt of his true wrath. He said many times to her: “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.” 4. Fourth, Ms. Ganieva never “threatened to go public” about Black regarding anything. As the people within Black’s inner circle know, the suggestion that Black attempted to spare his family public embarrassment about a purported extramarital relationship is ridiculous. 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 2 Nor did he care about being seen out with other young women, often of Russian descent, in addition to Ms. Ganieva. 2 3 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 associating him with Ms. Ganieva because he enjoyed being seen with her in public. What Black has worried about, however, is being exposed for the sadist that he is. 6. On October 29, 2020 during an earnings call, in connection with his announcements about his future role at Apollo Management, Black publically stated: “There has never been an allegation by anyone that I engaged in any wrongdoing, because I did not.” 7. This false claim of Black’s was the tipping point for Ms. Ganieva. Having recently educated herself in law school and knowing that many of his sexual acts were against her will and without her consent, she no longer was willing to stand by and allow him to escape accountability. 8. Knowing that her public outing of his disgusting conduct would end any further monetary payments from Black, 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 Ms. Ganieva to call him immediately. She refused. 10. Knowing that he could no longer control her into silence, Black resorted to the age-old playbook used by wealthy and powerful men – he made a preemptive claim of extortion. 3 11. This textbook strategy involves overpowering the female accuser by victimizing her one more time in a public way with threats of criminal charges. As demonstrated by Black, this is accomplished by going to the “criminal authorities” to accuse Ms. Ganieva of extortion 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 are detailed infra at ¶ 87. Threats of extortion are potentially far more damaging and frightening to a female accuser than threats of a civil lawsuit for defamation, an option that numerous men accused of sexual misconduct use for similar reasons. 3 4 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 and placing her on the legal defensive before she can take any legal action against him – just in case she planned on doing so. 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 men like Black have enjoyed an unequal access to justice unavailable to the average citizen and non-millionaires. Knowing the right lawyers and politicians provided Black with the ability to do exactly as he said: “Ask criminal authorities to investigate Ganieva.” 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. The truth will reveal a violent, sadistic side to Black that he has shielded from public view for decades. 15. Black defamed Ms. Ganieva by making the above statements. JURISDICTION AND VENUE 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, Westchester County. 4 5 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 FACTUAL ALLEGATIONS I. Leon Black’s Orchestrated Secrecy of His Sexual Violence and Deviance 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 in March 2008, while attending an International Women’s Day event in NYC. 21. A single mother in her early twenties, 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. 22. This is exactly what Black did. 23. It was a choreographed plan that allowed him to quickly gain Ms. Ganieva’s trust. 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 repeated proclamations about her innate talent and intellect, and combined with a few “arranged” appointments, for example with the Creative Artists Agency, LLC in Los Angeles, he quickly gained her gratitude and admiration. 24. Ms. Ganieva was flattered that a successful businessman would find 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 modeling. Naïvely, Ms. Ganieva believed that Black was not interested in her sexually, simply because she told him that their relationship would not be sexual. 25. 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 the public or his own employees. 5 6 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 26. Once he did, Black forced sadistic sexual acts on her without her consent and despite her saying no. 27. 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. Humiliated and in shock, Ms. Ganieva never uttered a word about he had done to her. 28. 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 sexual conduct against her will. 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. 29. 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 could induce her to meet him again. 30. Black’s persuasion tactics included endless promises 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 involved with to run the gallery. 6 7 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 31. Despite Black’s periods of remorseful and conciliatory behavior, he nevertheless also 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 Complaint. By way of example only, it included such things as: Ubiquitous belittling; Falsely accusing her of being jealous to deflect from his own hideous conduct; Pretending not to listen to or understand Ms. Ganieva when she said something he did not like, especially when it involved her attempts at cutting off communication; Forcing her to walk behind him; Forcing her to wait for his permission to speak; Punishing her by yelling and screaming if she did not speak to him “nicely”; Insisting that she speak to him in a pleasing, pleasant or otherwise “happy” and “nice” manner and yelling at her if she failed to do so; Insisting that her text messages also be sufficiently pleasant; Criticizing her appearance by saying she needed to lose weight or improve certain parts of her body; Criticizing her clothing and make-up; Berating her for refusing to agree to threesomes with other women and Black; Intentionally making her feel stupid and inferior to him; and Physically intimidating her by such acts as clenching his fists, pounding nearby pieces of furniture, repetitive 7 8 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 cracking of his knuckles and otherwise using his formidable 6’5” and 300+ pound body to intimidate her. II. Ms. Ganieva Returns to College 32. 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. 33. 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, believing that Black would find her unattractive. Unfortunately, these efforts had thus far been mostly futile. 34. As it turned out, Black said that he was in favor of her returning to college, and used the situation to convince Ms. Ganieva to sign a “loan” with Black. A. The First $480,000 Loan 35. 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 to her a one- page document, set forth below. 36. As stated, the “loan” included a 5% interest rate and was payable on June 1, 2016. 37. 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 Ms. Ganieva in his debt forever. 8 9 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 38. Critically, it would ensure that his criminal behavior would remain silenced. 9 10 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 B. The Second $480,000 Loan 39. Unsurprisingly, Black followed this initial loan with another one just like it in 2013: 10 11 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 40. The two “loans” and his ability to force repayment of such an amount allowed Black 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. 41. After Ms. Ganieva finished her math degree, Black reignited his charade of promises to help her find a “real job” outside of modeling. He convinced her that with all of his powerful Wall Street connections, he would find her a job. 42. 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. 43. 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: From: REDA , Jenna L. [HCM] CTED Sent: Wednesday, May 07, 2014 11:33 AM To: 'Guzel Ganieva' Subject: RE: Goldman Sachs Interview Opportunity 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 11 12 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 On Wednesday, May 7, 2014, REDA , Jenna L. REDA CTED wrote: CTED Hello Guzel, Please see your interview details below: Friday, May 9th, 2014 Interviewer Time Details: Dana Bunting 11:00am EST 32/201 HCM TBD 11:30am EST 32/201 Pete Lyon & Alison Mass 12:00pm EST 32/201 Julie Silverman 1:00pm EST 32/301 Please keep in mind that all schedules are subject to change. When you arrive to our building at 200 West Street in New York, our security team will direct you. 44. 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 that Black arranged, including at Goldman Sachs in London and Moscow. 45. Predictably, Ms. Ganieva was rejected. By way of example only, one such rejection email is as follows: On Saturday, November 29, 2014, RED , Pete RED ACT wrote: ThanksACT Guzel…in short, I think we just have to be patient for now…we have explored many options internally and, given the macro environment, there are no open jobs at Goldman Sachs right now that work for/are a fit for you…I also saw Paolo a few weeks ago in NYC and he told me he would keep his eyes open for you in Moscow with clients of his ifthey have roles/openings that make sense but that there were no immediate openings he was aware of…I wish we had better news but I think we just need to hang tight for now and if something opens that makes sense then Paolo and/or I will be in touch…thanks a lot.” 46. After yet another failed job interview, in desperation Ms. Ganieva even asked Black 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 12 13 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 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 her “miserable life.” III. The Rape in July 2014 47. 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. 48. Ms. Ganieva was weak and could barely walk. Disturbingly, when Black realized what a debilitated state she was in, he became happy. 49. 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 in a weakened state, having been sick for almost a week. 50. Never a match for his physical size and strength, on this day in particular Ms. Ganieva knew what fate was in store. 51. At over 6’5” and 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. 52. 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 and quickly got on top 13 14 of 30 FILED: NEW YORK COUNTY CLERK 06/01/2021 12/28/2022 09:55 09:14 AM PM INDEX NO. 155262/2021 952002/2022 NYSCEF DOC. NO. 1 41 RECEIVED NYSCEF: 06/01/2021 12/28/2022 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: “Now I have fucked you.” 53. Black then walked out – leaving Ms. Ganieva naked and unable to move on her bed. 54. Ms. Ganieva was no match for the cunning and masterful manipulation of Black or his repeated and unwanted sexual conduct. 55. After this 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