Wigdor Lawyer in Leon Black Case Sanctioned for ‘Repeated’ Lies

April 24, 2026, 3:04 PM UTC

A former attorney for a woman who claimed she was raped by financier Leon Black must face a range of sanctions for her conduct in the case.

Jeanne M. Christensen of Wigdor LLP “lied repeatedly” to Southern District of New York Judge Jessica G.L. Clarke and opposing counsel about what was happening in a related action, and directed the Jane Doe plaintiff, who is proceeding pro se, to destroy the Twitter account Doe used to communicate about her experiences as a purported victim of Jeffrey Epstein, Clarke said Friday.

While Clarke said while she “seriously” considered terminating Doe’s case because of her and Christensen’s “serious, sanctionable misconduct,” she declined to do so because it “need not doom Plaintiff’s claim.”

Christensen has been ordered to share Clarke’s opinion with any federal court within the Second Circuit in which she’s counsel of record for the next year. For the next five years she must share the opinion in any Second Circuit court where a sanctions motion has been filed against her, Wigdor LLP, or her client, and where she’s counsel of record.

Christensen and Wigdor also must pay Black’s “reasonable” attorneys’ fees and costs in bringing the sanctions motion.

Christensen told “several lies” to this Court and opposing counsel about what occurred in a related proceeding brought by Epstein survivors, called Doe 1 v. JP Morgan Chase & Co., Clarke said.

Doe also falsified sonogram images in her personal journals, which her first amended complaint “relies on” to support her allegations, the judge said.

In December 2024, Christensen filed a letter opposing the Black’s attempts to seek documents from the Doe 1action, which described the proceedings that had taken place in front of Southern District Judge Jed Rakoff. That letter “directly mischaracterized” the proceedings and Rakoff’s approach, Clarke said.

Clarke’s ruling “is a thorough repudiation of Doe’s and Wigdor’s claims—and their credibility,” said one Black’s lawyers, Susan Estrich of Estrich Goldin LLP in a written statement. “Wigdor and Doe should never have filed this case against Mr. Black.”

“Black’s objective was for the court to dismiss this case and while we are upset about the sanction, we are pleased that our former client will get her day in court,” Wigdor name partner Douglas Wigdor said in a written statement.

Quinn Emanuel Urquhart & Sullivan LLP and Perry Law also represent Black.

The case is Doe v. Black, 2026 BL 146788, S.D.N.Y., No. 1:23-cv-06418, 4/23/26.

To contact the reporter on this story: Sam Skolnik in Washington at sskolnik@bloomberglaw.com

To contact the editor responsible for this story: Alex Clearfield at aclearfield@bloombergindustry.com

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