On November 28, 2022 a
Motion-Secondary
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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FILED: NEW YORK COUNTY CLERK 01/09/2023 08:38 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/09/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------------------------------------------ X
CHERI PIERSON, :
: Index No.: 952002/2022
Plaintiff, :
: Hon. Suzanne Adams
v. :
: Motion Seq. No. 001
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, :
:
Defendant. :
----------------------------------------------------------------------- X
AFFIRMATION OF JEANNE M. CHRISTENSEN IN SUPPORT OF
PLAINTIFF’S REPLY TO THE CROSS-MOTION FOR SANCTIONS
I, Jeanne M. Christensen, a partner at Wigdor LLP (“Wigdor”), represent Plaintiff
Cheri Pierson (“Ms. Pierson” or “Plaintiff”) in this action. As such, I am fully familiar
with the facts and issues in this matter, and I hereby affirm under penalty of perjury
pursuant to CPLR 2106, that the following is true and correct:
1. I submit this affirmation in support of the reply to Ms. Pierson’s and
Wigdor’s cross-motion pursuant to 22 NYCRR 130-1.1 against Defendant Leon Black
(“Black”) and his counsel, Perry Guha LLP (“Perry Guha”), for an award of costs and fees.
2. On June 1, 2021, Guzel Ganieva commenced an action against Leon Black
and our firm represents Ms. Ganieva in that case, entitled Ganieva v. Black, Index No.
155262/2021 (N.Y. Sup. Ct.) (the “Ganieva Action”). The Hon. David J. Cohen is
presiding over the Ganieva Action.
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FILED: NEW YORK COUNTY CLERK 01/09/2023 08:38 PM INDEX NO. 952002/2022
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/09/2023
3. On December 16, 2022, Black and his counsel Perry Guha filed almost
identical motions for sanctions in this case and in the Ganieva Action. On January 6, 2022,
Black and his counsel submitted an opposition to Plaintiff’s cross-motion for sanctions in
the Ganieva Action and a true and correct copy of this memorandum of law (see Dkt. Nos.
60, 61) is attached hereto as Exhibit A.
4. I declare under penalty of perjury that the foregoing is true and correct to
the best of my knowledge.
Dated: January 9, 2023
New York, New York
By: __________________________
Jeanne M. Christensen
2
2 of 2
Document Filed Date
January 09, 2023
Case Filing Date
November 28, 2022
Category
Torts - Adult Survivors Act
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FILED: NEW YORK COUNTY CLERK 01/09/2023 08:38 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/09/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------ X CHERI PIERSON, : : Index No.: 952002/2022 Plaintiff, : : Hon. Suzanne Adams v. : : Motion Seq. No. 001 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, : : Defendant. : ----------------------------------------------------------------------- X AFFIRMATION OF JEANNE M. CHRISTENSEN IN SUPPORT OF PLAINTIFF’S REPLY TO THE CROSS-MOTION FOR SANCTIONS I, Jeanne M. Christensen, a partner at Wigdor LLP (“Wigdor”), represent Plaintiff Cheri Pierson (“Ms. Pierson” or “Plaintiff”) in this action. As such, I am fully familiar with the facts and issues in this matter, and I hereby affirm under penalty of perjury pursuant to CPLR 2106, that the following is true and correct: 1. I submit this affirmation in support of the reply to Ms. Pierson’s and Wigdor’s cross-motion pursuant to 22 NYCRR 130-1.1 against Defendant Leon Black (“Black”) and his counsel, Perry Guha LLP (“Perry Guha”), for an award of costs and fees. 2. On June 1, 2021, Guzel Ganieva commenced an action against Leon Black and our firm represents Ms. Ganieva in that case, entitled Ganieva v. Black, Index No. 155262/2021 (N.Y. Sup. Ct.) (the “Ganieva Action”). The Hon. David J. Cohen is presiding over the Ganieva Action. 1 of 2 FILED: NEW YORK COUNTY CLERK 01/09/2023 08:38 PM INDEX NO. 952002/2022 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 01/09/2023 3. On December 16, 2022, Black and his counsel Perry Guha filed almost identical motions for sanctions in this case and in the Ganieva Action. On January 6, 2022, Black and his counsel submitted an opposition to Plaintiff’s cross-motion for sanctions in the Ganieva Action and a true and correct copy of this memorandum of law (see Dkt. Nos. 60, 61) is attached hereto as Exhibit A. 4. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Dated: January 9, 2023 New York, New York By: __________________________ Jeanne M. Christensen 2 2 of 2