Exhibit,Appendix: 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 Exhibit,Appendix 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.

Preview
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Exhibit A
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

GUZEL GANIEVA, Index No. 155262/2021

Plaintiff, Motion Sequence No.: 14

v. AFFIRMATION OF
MICHAEL B. CARLINSKY IN
LEON BLACK, FURTHER SUPPORT OF
DEFENDANT’S MOTION
Defendant. FOR SANCTIONS

MICHAEL B. CARLINSKY, an attorney duly admitted to practice in the courts of the

State of New York, and not a party in the above-captioned action, hereby affirms under penalty of

perjury, pursuant to CPLR 2106, that the following is true and correct:

1. I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

counsel for Defendant Leon Black. I respectfully submit this Affirmation in further support of

Defendant’s Motion for Sanctions. I am fully familiar with the facts and circumstances recited

herein.

2. A true and correct copy of Black’s July 19, 2021 letter to Wigdor LLP

(“Wigdor”) is attached hereto as Exhibit 1.

3. A true and correct copy of Wigdor’s August 13, 2021 letter to Black is

attached hereto as Exhibit 2.

4. A true and correct copy of Black’s September 8, 2021 letter to Wigdor is

attached hereto as Exhibit 3.

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5. A true and correct copy of Wigdor’s October 25, 2021 letter to Black is

attached hereto as Exhibit 4.

I affirm under penalty of perjury that the foregoing is true and correct.

Dated: New York, New York
January 6, 2023
/s/ Michael B. Carlinsky_______________
Michael B. Carlinsky

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ATTORNEY CERTIFICATION PURSUANT TO 22 NYCRR 202.8

I, Michael B. Carlinsky, an attorney duly admitted to practice law before the courts of the

State of New York, hereby certifies that this affirmation in further support of Defendant’s Motion

for Sanctions complies with the word count limit set forth in 22 NYCRR 202.8 -b because it

contains 183 words, excluding the parts of the affidavit exempted by the rule. In preparing this

certification, I have relied on the word count of the word-processing system used to prepare this

memorandum of law.

Dated: January 6, 2023
New York, New York

/s/ Michael B. Carlinsky
Michael B. Carlinsky

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EXHIBIT 1
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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
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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.
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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
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EXHIBIT 2
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Jeanne M. Christensen
jchristensen@wigdorlaw.com

August 13, 2021

VIA EMAIL

E. Danya Perry, Esq.
Perry Guha LLP
35 E 62nd Street
New York, New York 10065

Re: Ganieva v. Black; Index No. 155262/2021

Dear Danya:

I am confounded by the fact that, after I voluntarily told you that I have not taken one day off since
March 13, 2020 and do not plan to be back at work until next week, I woke up this morning to an
email from you essentially threatening to “contact the Court” if I do not formally respond to your
unilateral ultimatums by the close of business today. While such a threat is unprofessional,
unnecessary, and likely issued merely in order to appease your client, I am responding because your
representations are blatantly wrong and misguided.

First, you falsely accused me of “refusing to call the Court to request a conference.” At 7:35 pm last
night, you wrote an email saying that we needed to get on the phone and call the Court about the
preliminary conference. Your firm made a request for a preliminary conference that has been filed
on the docket. See Dkt. No. 16. There is nothing else to be done as I am certain the Court is
competent at handling the scheduling of preliminary conferences. When I reasonably asked why
there was any need to make a telephone call to the Court on top of the submission for a preliminary
conference, you said it was because I was not “advance[ing]” my client’s case. Incredibly, you made
this claim after we: (1) filed a motion to dismiss all three of your client’s counterclaims on August
5, 2021 (Dkt. No. 19); (2) filed a 58-page Amended Complaint on August 9, 2021; and (3) issued
more than a dozen non-party subpoenas.

Your alleged “urgency” appears to be about obtaining discovery from Ms. Ganieva about such
mundane items as her retainer agreement with Wigdor, LLP, the names of reporters she allegedly
spoke to about Leon Black, a list of gifts that Black gave her worth over $1000 (does he not know
what he gifted her?), as well as an itemization of her apartment leases for ten years and the cost of
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E. Danya Perry, Esq.
August 13, 2021
Page 2

same. None of this is relevant to Ms. Ganieva’s claims against Black for defamation, defamation
per se, intentional infliction of emotional distress and violations of the Gender Motivated Violence
Act. As for discovery related to Black’s counterclaims against Ms. Ganieva for defamation,
defamation per se and breach of contract, as you know, we moved to dismiss these claims pursuant
to CPLR § 3211, and so any discovery as to the counterclaims is stayed “until determination of the
motion [to dismiss] unless the court orders otherwise.” CPLR § 3214(b).

Your accusations about our purported refusal to “meet and confer,” and how we are somehow in the
wrong for refusing to sign a confidentiality agreement in exchange for the alleged enforceable
contract on which Black bases his breach of contract claim, are baseless. Far from signing form
confidentiality orders as a matter of standard protocol (which Wigdor LLP does not do), there is
nothing for us to “meet and confer” on until we receive a copy of the mystery agreement. As I have
said previously, I am starting to believe the document does not even exist, and, if it does, may have
been materially altered by Black. It is unfathomable that he refuses to give Ms. Ganieva a copy
without attaching his own self-serving conditions. We have no interest in meeting and conferring or
discussing a confidentiality order until that document is produced. You and your client’s actions
make clear that Black’s breach of contract claim is frivolous and should be withdrawn immediately.

Notably, as you know, before you requested a Preliminary Conference, we represented that we would
respond to your discovery requests on or by August 9, 2021. Rather than consent, you filed your
request for a Preliminary Conference. The Court will get to this application, made less than two
weeks ago, at the appropriate time.

Lastly, while it is my and Wigdor LLP’s practice to extend reasonable courtesies to our professional
colleagues whenever possible, if and when in the future you may need the courtesy of an extension
to respond (as I did when I told you that I was taking my first days off since March 2020), I hope
that you remember this day and your threats to contact the Court by close of business without a
response from me.

Sincerely,

Jeanne M. Christensen
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EXHIBIT 3
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September 8, 2021

Via Email

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:

By letter dated July 19, 2021, we wrote to inform you that the initial complaint filed
by your client, Guzel Ganieva, contained numerous demonstrably false material
allegations. I need not repeat here the significant sanctionable conduct relating to the initial
complaint in this matter, but that letter served as notice that the false allegations were
sanctionable, pursuant to 22 NYCRR 130-1.1 (providing that the Court may impose
sanctions, including costs and attorneys’ fees, on attorneys and parties who engage in
“frivolous conduct,” which includes making claims that are “undertaken primarily. . . to
harass or maliciously injure another” and “assert[ing] material factual statements that are
false.”).
Rather than correct those false material allegations when you filed the Amended
Complaint, you instead doubled down with even more demonstrably and willfully false
allegations. As with the original complaint, by signing the Amended Complaint, you
certified that the claims were not frivolous and had been filed only after a reasonable
inquiry. Id. This was false and is sanctionable. Despite being fully on notice that Ms.
Ganieva’s allegations were belied by Plaintiff’s own written and spoken words, you have
failed to conduct even the most minimal diligence into the truth of the allegations against
Mr. Black, in violation of your ethical obligations.
Your sanctionable conduct only begins, but does not end, with the manufactured
causes of action in this case. The Amended Complaint largely consists of page after page
of purple prose that is not only scandalous, but utterly irrelevant to the claims. This “wild
speculation” and the “plainly irrelevant, absurd, and/or scurrilous statements” in the
Amended Complaint are sanctionable as well. Charles v. Levitt, No. 15 CIV. 9334 (PAE),
2016 WL 3982514, at *7 (S.D.N.Y. July 21, 2016), aff’d and remanded, 716 F. App’x 18
(2d Cir. 2017). We are aware of the “playbook” (to use a word you favor) that your firm
deploys in various lawsuits in which you serve as counsel (and at times as defendants in
your own right) and with which you attempt to import into your cases wholly irrelevant
allegations and characters—including Harvey Weinstein, Jeffrey Epstein, and so many

1
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others—in a craven attempt to tar the defendant. You were fully on notice of the
impropriety of the allegations in this case by virtue of our previous motion to strike. In
seeking a stipulation to extend the time to respond to that motion, your firm went so far as
to imply that you would be amending the complaint in a way that might “obviate” these
improper allegations. This was false; instead, you leaned in and exponentially increased
the “plainly irrelevant, absurd, and/or scurrilous statements” in the pleadings.

This failure is all the more egregious, given our offer to provide you with the
evidence proving the falsity of many of the allegations in the Amended Complaint—
evidence that you specifically (and through an improper court filing) requested in
discovery. We have long stood ready to produce these documents under the terms of a
standard protective order. You refused to even meet and confer regarding such an order on
multiple occasions. Your written representation to us that your firm does not enter into
such agreements is simply false, as even a quick docket search confirms. In any event, we
even offered to quickly provide evidence to you absent a protective order, provided only
that you agree not to publicize it pending the negotiation of terms; you rejected this as well.
Had you simply agreed to meet and confer with us, you could have easily and swiftly
received the parties’ confidentiality and release agreement, the recordings, and the text
messages. You refused, and instead barreled ahead and filed claims without doing a shred
of diligence.
You not only pressed the same lies in the Amended Complaint, but you added
allegation after allegation as to which you or your client could not possibly have any
information. To take just one—very serious—example, I refer you to the false statements
in the Amended Complaint regarding an alleged criminal conspiracy amongst Mr. Black
and his attorneys. You have not a lick of evidence, or even a reasonable basis to allege on
information and belief, that Mr. Black’s “posse” (strange italics in original) of lawyers
“‘huddled up’” (strange internal quotations in original) to devise a criminal “scheme” to
“manufacture evidence” against your client. Obviously, neither you nor your client were
in the room with Mr. Black’s attorneys. Nor have you, your client, or anyone else
working with you spoken with Mr. Black’s attorneys about their decision-making. This
was all made up out of whole cloth for dramatic effect, and not for legitimate pleading
purposes.

To the extent that you have communicated or published these allegations
elsewhere, including in press statements and on your firm’s website, they are not only
sanctionable but actionable. See Williams v. Williams, 23 N.Y.2d 592, 599 (1969). As
you are aware, the absolute privilege for publishing a report of a judicial proceeding does
not apply to a “plaintiff who commences an underlying lawsuit as a sham action brought
solely to defame a defendant and never diligently prosecutes her claims.” Haynes v.
Bonner and Wigdor LLP, 69 Misc. 3d 1201(A), 130 N.Y.S.3d 899 (N.Y. Sup. Ct. 2020)
(internal citations omitted). While you and your firm have managed to avoid liability for
other “sham litigation” claims in the past, the facts are much more egregious in this case
and ultimately you will have to explain them to a factfinder.

2
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The four corners of the Amended Complaint, standing alone, make clear that its
sole purpose is to harass, embarrass, and defame Mr. Black. In addition, this singular
purpose is made all the clearer from your consistent efforts to block discovery. As noted,
it is plain enough that you do not want to advance this case from the fact alone that you
have refused to meet and confer with us in order to quickly receive the material you had a
responsibility to review before filing your frivolous Amended Complaint. And, as we have
recited in a number of deficiency letters and emails to you and in two filings with the Court,
your efforts to impede fact discovery in the case is also patent from your refusal to so much
as respond or object to numerous discovery requests and your refusal to so much as meet
and confer with us. Your only response to this has been to scoff at the lack of “urgency”
for Mr. Black in conducting discovery. Your client has brought claims of rape and sexual
sadism that have upended my client’s life; while his interest in clearing his name is indeed
most urgent, the CPLR cares nothing about your own opinion as to urgency. Your refusal
to engage in standard, rules-based discovery betrays this litigation for the sham that it is.
(As an aside, no matter how many times you repeat it, filing a motion to dismiss and issuing
and then bizarrely withdrawing “countless” subpoenas does not evidence forward
movement. To the contrary, it simply is more evidence of obstructionism).
I will note that I cannot recall ever having experienced the kind of unprofessional
comments you have directed toward me personally. You were civil enough until the
moment it became clear that Mr. Black would actually act to defend himself rather than
negotiate with an extortionist. At that point, you immediately began using some of the
language against me and my colleague that you so casually toss around in the pleadings
against my client, including that we have misled you, threatened you, and bullied you (and
even that we attempted to bully the Court, an interesting take indeed). In my nearly 25
years of practice, I have never sent a letter like this one to opposing counsel—let alone two
such letters. I do not do so lightly.
Each of the demonstrably false allegations as detailed in the Amended Answer is
clearly “material” for purposes of Rule 130. The volume and willfulness of the false
statements—together with all the other conduct detailed herein, in various
communications to you, and in Mr. Black’s Amended Answer—make clear that the
Complaint was filed solely to harass and maliciously injure Mr. Black, rather than for any
legitimate purpose. Taken as a whole, this constitutes frivolous, wrongful, and
sanctionable conduct by your client, by you, and by your firm.

3
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Although I recognize by now that I am just spitting in the wind, we remain willing
to meet and confer with you, including with respect to this notice. Assuming your
continued refusal to engage, we demand nothing less than withdrawal of the Amended
Complaint.

Very truly yours,

E. Danya Perry

cc: Douglas Wigdor

4
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EXHIBIT 4
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Jeanne M. Christensen
jchristensen@wigdorlaw.com

October 25, 2021

VIA EMAIL

E. Danya Perry, Esq.
Perry Guha LLP
35 E. 62nd Street
New York, New York 10065

Re: Ganieva v. Black; Index No. 155262/2021

Dear Danya:

We write in connection with the dilatory tactics by Black concerning discovery. Clearly this conduct
is intentional. On September 22, 2021, after numerous requests by Black, the Court agreed to a
conference. During that conference, several times, you represented to the Court that you would not
produce critical evidence in this matter absent an order of confidentiality. In response, I represented
to the Court, several times, that we would not agree to a confidentiality order.1 We discussed specific
items, including, inter alia, the audio files Black claims he has, as well as the “agreement.” Based
on this, the Court said in sum and substance that he expects “another motion” on his desk. Rather
than timely filing your motion, as of today, nothing has been filed. Contrary to the multitude of
representations you made to the Court about the “urgency” of discovery, Black is doing nothing.

Because of this, any claim by Black that our client is not in compliance with agreed upon internal
dates for discovery, outside of a Court order, is meritless. We agreed to dates believing that Black
would actually be producing discovery. As your responses on October 18, 2021 make obvious,
the last thing Black intends to do is produce relevant information.

Sincerely,

Jeanne M. Christensen

1
Our objection was detailed to you in correspondence dated September 23, 2021.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

GUZEL GANIEVA, Index No. 155262/2021
Plaintiff,
MEMORANDUM OF LAW IN
V. SUPPORT OF MOTION FOR
SANCTIONS
LEON BLACK,
Motion Sequence No. 14
Defendant.
Hon. David B. Cohen

DEFENDANT LEON BLACK'S REPLY MEMORANDUM OF LAW
IN FURTHER SUPPORT OF HIS MOTION FOR SANCTIONS AND IN
OPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SANCTIONS

QUINNEMANUELURQUHART&
SULLIVAN, LLP
Michael B. Carlinsky
Jennifer J. Barrett
51 Madison Avenue, 22nd Floor
New York, NY 10010
(212) 849-7000

PERRY GUHA LLP
E. Danya Perry
1740 Broadway, 15th Floor
New York, NY 10019
(212) 399-8330

ESTRICH GOLDIN LLP
Susan Estrich (pro hac vice pending)
8605 Santa Monica Blvd, Suite 92780
West Holly w ood, CA 90069
(213) 399-2132

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TABLE OF CONTENTS

PRELIMINARY STATEMENT ..................................................................................................... 1
ARGUMENT ................................................................................................................................... 4
I. THE COURT'S GRANT OF LEAVE

Case Info

Judge

Suzanne J. Adams Track Judge’s New Case

Case No.

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Document Filed Date

January 09, 2023

Case Filing Date

November 28, 2022

County

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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