A federal judge found that the attorney representing a woman who accused billionaire Leon Black of sexual assault “lied repeatedly” to the court and to opposing counsel, sanctioning both the lawyer and her firm in a blistering 76-page opinion that stopped just short of killing the case entirely.
U.S. District Judge Jessica Clarke imposed sanctions on attorney Jeanne Christensen and her firm, Wigdor LLP, after concluding they engaged in what she called “serious, sanctionable misconduct” throughout the litigation. The misconduct included directing the plaintiff to delete a potentially relevant social media account and presenting falsified evidence, sonogram images tucked inside personal journals that the judge determined could not be trusted.
The ruling does not end the lawsuit. But it guts the plaintiff’s evidentiary foundation at a moment when the broader Epstein scandal continues to draw congressional scrutiny, and it raises hard questions about whether litigation tied to Jeffrey Epstein’s crimes is being weaponized by attorneys willing to cut corners in court.
Clarke’s opinion, reported by Fox News Digital, laid out a pattern of dishonesty by Christensen during the case. The judge wrote that Christensen lied to both the court and Black’s legal team about a related case and ordered her client to destroy a social media account that could have contained relevant material.
Among the most damaging findings: some of the plaintiff’s key supporting materials, sonogram images she claimed documented pregnancies resulting from sexual abuse, had been falsified. The plaintiff, identified in court filings as “Jane Doe,” testified that all of the sonograms in the journals were hers “from several abuse-related pregnancies, including some pregnancies that came to term and others that were terminated.” Clarke found that testimony unreliable.
The judge wrote that the plaintiff claimed she “was forced to carry out pregnancies that resulted from the men who sexually abused her, and Maxwell took photographs of Plaintiff’s body as it changed during her pregnancies.” Those allegations are central to the case. Barring the journals from evidence strips the plaintiff of a key pillar of her story.
Clarke acknowledged the severity of the misconduct openly. She wrote that she “strongly considered granting the case-terminating sanctions Defendant requests in this matter.” But she ultimately concluded that “lesser sanctions can address the misconduct.”
Instead of dismissing the case, Clarke ordered a set of penalties designed to follow Christensen through her career. The attorney must file the misconduct ruling in every one of her federal cases in the Second Circuit for the next year. For the next five years, she must file it in any case where sanctions are sought against her, her firm, or her client.
Wigdor LLP was ordered to pay Leon Black’s legal fees connected to the sanctions motion, a direct financial consequence for the firm’s conduct. The plaintiff herself is now barred from relying on the journals containing the falsified sonograms.
The firm no longer represents the plaintiff. The New York Post reported that Wigdor LLP had sought to withdraw from the case days before a key hearing on whether the firm should be sanctioned. The Post also noted that Black’s legal team said they discovered the accuser’s identity and that her family told them she was lying, including about being autistic.
Douglas Wigdor, the firm’s founder, issued a statement saying, “We are pleased that our former client will get her day in court.” The firm told Politico it was “upset” by the sanctions but noted the case remains active.
Susan Estrich, the attorney representing Leon Black, did not mince words. She said the plaintiff’s credibility had been “destroyed” and called for the complaint to be withdrawn entirely.
“Her credibility having been destroyed, Doe should withdraw her Complaint and apologize to Mr. Black for manufacturing false and defamatory claims. We urge the federal authorities to investigate this fraud on the Court.”
Black has denied wrongdoing. He co-founded Apollo Global Management and served as its chairman and CEO before leaving the firm in 2021. The lawsuit alleged he raped the plaintiff in New York City in 2002 when she was 16 years old, claiming she had been groomed and trafficked by Epstein and Ghislaine Maxwell.
Epstein died in jail in 2019 while awaiting trial on federal sex-trafficking charges. Maxwell was convicted in 2021 on sex-trafficking charges and is serving a 20-year prison sentence. The fallout from their crimes has reached institutions and individuals far beyond the courtroom, from finance to philanthropy to the church.
The sanctions ruling lands as Congress prepares to press deeper into Epstein’s network. The House Oversight Committee is expected to hear testimony next month from Black and other high-profile figures about their connections to Epstein and Maxwell.
That congressional push has already generated friction. The House Oversight Committee recently subpoenaed Attorney General Pam Bondi over the DOJ’s handling of Epstein-related files, a sign that lawmakers on both sides want answers about how the government has managed, or mismanaged, the broader investigation.
The Epstein scandal has also prompted internal reviews at major institutions. The Gates Foundation ordered an outside review of Bill Gates’ Epstein connections while simultaneously slashing hundreds of jobs, a reminder that the late financier’s web of relationships continues to generate consequences years after his death.
Clarke’s ruling did not address the underlying allegations of sexual assault. She made no determination about whether Black did or did not commit the acts described in the complaint. What she determined is that the plaintiff’s own legal team engaged in conduct so dishonest that it compromised the integrity of the proceedings.
That distinction matters. Real victims of trafficking deserve a legal system that takes their claims seriously. But the system also depends on attorneys who tell the truth. When lawyers fabricate, conceal, and destroy evidence, they don’t just undermine one case. They erode the credibility of every plaintiff who comes after.
The plaintiff’s claim that she was subjected to an “impregnation game” by Epstein and others, and that Maxwell photographed her body during resulting pregnancies, is the kind of allegation that demands rigorous, honest presentation. Instead, the court found falsified sonograms and a lawyer who lied about related proceedings.
Courts have shown a willingness to hold attorneys accountable for misconduct in high-profile cases. The question is whether the accountability is proportional. Clarke chose lesser sanctions over dismissal, reasoning they could “address the misconduct.” Estrich and Black’s legal team clearly disagree, arguing the fraud warrants not just sanctions but a federal investigation.
The case will proceed. But it will proceed without the law firm that brought it, without the journals that were supposed to corroborate it, and under the shadow of a 76-page judicial finding that the plaintiff’s own attorney could not be trusted to tell the truth.
Legal accountability, the kind that applies equally to attorneys who abuse the system regardless of the political valence of their case, is supposed to be a bedrock principle. Clarke’s ruling enforces that principle. Whether it enforces it enough is another matter.
The plaintiff must now find new counsel willing to take the case forward under extraordinary constraints. The falsified evidence is excluded. The prior legal team’s misconduct is on the record. And Leon Black’s attorneys are pressing for more, not just vindication in court, but a criminal referral for what they describe as fraud.
Meanwhile, the House Oversight Committee hearings loom. Black is expected to testify about his connections to Epstein and Maxwell. Whatever the outcome of the civil case, the congressional inquiry will put additional facts on the public record, facts that voters and taxpayers deserve to see.
The Epstein case has always been about whether powerful people can escape accountability. That question cuts in every direction, against the men who exploited Epstein’s network, and against the lawyers who exploit the legal system in the name of pursuing them.
Justice demands honest courts. When officers of the court lie repeatedly, the first casualty is the truth, and the second is every real victim still waiting for their day before a judge they can trust.
By signing up, you agree to receive newsletters and promotional content from American Frontline News and selected publications in the American Digest Media Network, operated with Patriot Mom Digest LLC, and you accept our Terms of Use and Privacy Policy. You may unsubscribe at any time.
By signing up, you agree to receive newsletters and promotional content from American Frontline News and selected publications in the American Digest Media Network, operated with Patriot Mom Digest LLC, and you accept our Terms of Use and Privacy Policy. You may unsubscribe at any time.