Preview
FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023
EXHIBIT 1
FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023
July 19, 2021
Via Email and FedEx
Jeanne M. Christensen
Wigdor LLP
85 Fifth Avenue, Fl. 5
New York, NY 10003
JChristensen@wigdorlaw.com
Re: Guzel Ganieva v. Leon Black, Index No. 155262/2021
Dear Ms. Christensen:
As you are aware, we represent Leon Black in this matter. We are writing to inform
you that the Complaint filed by your client, Ms. Ganieva, contains numerous demonstrably
false material allegations. You are no doubt aware that 22 NYCRR 130-1.1 permits the
Court to impose sanctions, including costs and attorneys’ fees, on attorneys and parties
who engage in “frivolous conduct,” which includes, among other things, “assert[ing]
material factual statements that are false.” 22 NYCRR 130-1.1(c).
As explained in Mr. Black’s Answer, Affirmative Defenses, and Counterclaims
(the “Answer”), filed today, Plaintiff’s allegations are materially and knowingly false. The
evidence—including numerous recorded conversations and written communications
(spoken and written by Ms. Ganieva herself)—shows that, among other things: (i) the
parties’ relationship was wholly consensual and never involved abuse or harassment; (ii)
the alleged rape described in the Complaint never occurred; and (iii) Mr. Black’s public
statements were entirely true.
While the Answer details the many materially false allegations contained in the
Complaint, the following particularly egregious examples are illustrative of the blatant
factual inaccuracies in the Complaint:
For one, the Complaint contains numerous false statements about the so-called
“NDA,” including that Mr. Black “coerced” Ms. Ganieva into signing it under duress, that
she “she did not want [Mr. Black’s] money,” id. ¶ 61, that Mr. Black threatened that he
would make sure that she would end in “in prison” and that he would “destroy her life,” id.
¶ 63, that he “ordered” her to sign the NDA, id. ¶¶ 64, 69, that she did not understand the
nature of the document she was signing, id. ¶ 65, and that she did not have sufficient time
to review the NDA before signing, id. ¶ 67. Each of these allegations is demonstrably false.
In fact, Ms. Ganieva sought out Mr. Black and demanded $100 million in exchange
for her silence about their affair. Further, Mr. Black never threatened that he would make
FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023
sure Ms. Ganieva ended up “in prison” or that he would “destroy her life.” Finally, Ms.
Ganieva agreed to the terms willingly and with full information and understanding. Ms.
Ganieva took her time reviewing the agreement, and Mr. Black explained each of its
terms—both the elements of the payments Ms. Ganieva would receive and the
confidentiality and release provisions—and Ms. Ganieva indicated her assent and
understanding as to each term.
As another example, the Complaint contains several demonstrably false allegations
concerning the circumstances of the purported sexual assault that Ms. Ganieva claims
occurred on July 6, 2014. Among other things, Ms. Ganieva claims that on the night of the
alleged rape, she had “been sick for almost a week,” was in a “debilitated state,” and was
“weak and could barely walk,” Compl. ¶¶ 48-49, that Mr. Black showed up apparently
unannounced and uninvited, id. ¶ 47, and that she left New York after the alleged sexual
assault, in order to “physically distance herself from [Mr. Black],” id. ¶ 55.
In fact, if Ms. Ganieva had been sick earlier in the week (as she claimed on July 1),
she had recovered by the night in question, texting Mr. Black on July 2, 2014 that she was
already feeling “much better” and that “I think I will be all done by tonight.” Further, Mr.
Black’s visit was anything but a surprise: Ms. Ganieva asked Mr. Black to bring a bottle
of wine when he arrived at her apartment at a mutually agreed upon time to “tuck” her in.
Finally, Ms. Ganieva did not leave New York until July 31, 2014, and she and Mr. Black
saw each other several times between July 6 and her departure, at her request. Moreover,
Ms. Ganieva told Mr. Black on several occasions that she had to leave the United States at
this time due to visa issues.
FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023
Each of the demonstrably false allegations as detailed in the Answer are clearly
“material” for purposes of Rule 130. The sheer number of false statements, together with
the inflammatory nature of the allegations against Mr. Black, suggest that the Complaint
was filed solely to harass and maliciously injure Mr. Black, rather than for any legitimate
purpose. Taken together, this constitutes frivolous and sanctionable conduct by Plaintiff.
This letter serves as formal notice to your client, and to you.
Very truly yours,
E. Danya Perry
cc: Lindsay M. Goldbrum
Peter Gwynne
Preview
FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023 EXHIBIT 1 FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023 July 19, 2021 Via Email and FedEx Jeanne M. Christensen Wigdor LLP 85 Fifth Avenue, Fl. 5 New York, NY 10003 JChristensen@wigdorlaw.com Re: Guzel Ganieva v. Leon Black, Index No. 155262/2021 Dear Ms. Christensen: As you are aware, we represent Leon Black in this matter. We are writing to inform you that the Complaint filed by your client, Ms. Ganieva, contains numerous demonstrably false material allegations. You are no doubt aware that 22 NYCRR 130-1.1 permits the Court to impose sanctions, including costs and attorneys’ fees, on attorneys and parties who engage in “frivolous conduct,” which includes, among other things, “assert[ing] material factual statements that are false.” 22 NYCRR 130-1.1(c). As explained in Mr. Black’s Answer, Affirmative Defenses, and Counterclaims (the “Answer”), filed today, Plaintiff’s allegations are materially and knowingly false. The evidence—including numerous recorded conversations and written communications (spoken and written by Ms. Ganieva herself)—shows that, among other things: (i) the parties’ relationship was wholly consensual and never involved abuse or harassment; (ii) the alleged rape described in the Complaint never occurred; and (iii) Mr. Black’s public statements were entirely true. While the Answer details the many materially false allegations contained in the Complaint, the following particularly egregious examples are illustrative of the blatant factual inaccuracies in the Complaint: For one, the Complaint contains numerous false statements about the so-called “NDA,” including that Mr. Black “coerced” Ms. Ganieva into signing it under duress, that she “she did not want [Mr. Black’s] money,” id. ¶ 61, that Mr. Black threatened that he would make sure that she would end in “in prison” and that he would “destroy her life,” id. ¶ 63, that he “ordered” her to sign the NDA, id. ¶¶ 64, 69, that she did not understand the nature of the document she was signing, id. ¶ 65, and that she did not have sufficient time to review the NDA before signing, id. ¶ 67. Each of these allegations is demonstrably false. In fact, Ms. Ganieva sought out Mr. Black and demanded $100 million in exchange for her silence about their affair. Further, Mr. Black never threatened that he would make FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023 sure Ms. Ganieva ended up “in prison” or that he would “destroy her life.” Finally, Ms. Ganieva agreed to the terms willingly and with full information and understanding. Ms. Ganieva took her time reviewing the agreement, and Mr. Black explained each of its terms—both the elements of the payments Ms. Ganieva would receive and the confidentiality and release provisions—and Ms. Ganieva indicated her assent and understanding as to each term. As another example, the Complaint contains several demonstrably false allegations concerning the circumstances of the purported sexual assault that Ms. Ganieva claims occurred on July 6, 2014. Among other things, Ms. Ganieva claims that on the night of the alleged rape, she had “been sick for almost a week,” was in a “debilitated state,” and was “weak and could barely walk,” Compl. ¶¶ 48-49, that Mr. Black showed up apparently unannounced and uninvited, id. ¶ 47, and that she left New York after the alleged sexual assault, in order to “physically distance herself from [Mr. Black],” id. ¶ 55. In fact, if Ms. Ganieva had been sick earlier in the week (as she claimed on July 1), she had recovered by the night in question, texting Mr. Black on July 2, 2014 that she was already feeling “much better” and that “I think I will be all done by tonight.” Further, Mr. Black’s visit was anything but a surprise: Ms. Ganieva asked Mr. Black to bring a bottle of wine when he arrived at her apartment at a mutually agreed upon time to “tuck” her in. Finally, Ms. Ganieva did not leave New York until July 31, 2014, and she and Mr. Black saw each other several times between July 6 and her departure, at her request. Moreover, Ms. Ganieva told Mr. Black on several occasions that she had to leave the United States at this time due to visa issues. FILED: NEW YORK COUNTY CLERK 01/06/2023 07:10 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 01/06/2023 Each of the demonstrably false allegations as detailed in the Answer are clearly “material” for purposes of Rule 130. The sheer number of false statements, together with the inflammatory nature of the allegations against Mr. Black, suggest that the Complaint was filed solely to harass and maliciously injure Mr. Black, rather than for any legitimate purpose. Taken together, this constitutes frivolous and sanctionable conduct by Plaintiff. This letter serves as formal notice to your client, and to you. Very truly yours, E. Danya Perry cc: Lindsay M. Goldbrum Peter Gwynne