CHRISTOPHER J. DILORIO SEC WHISTLEBLOWER COMPLAINT

Apollo Global Management / Jeffrey Epstein / Kushner Family Connections

Deep Dive Forensic Analysis from Epstein Files Database

EXECUTIVE SUMMARY

Christopher J. Dilorio is an SEC whistleblower () who filed an extensive series of complaints with the SEC, DOJ, FINRA, and FinCEN beginning no later than 2013, with the specific "Apollo/Epstein/Kushner connection" email chain originating on April 13, 2019 -- approximately three months BEFORE Jeffrey Epstein's July 6, 2019 arrest.

Dilorio's complaints allege a web of interconnected financial fraud centered on:
1. Environmental Solutions Worldwide (ESWW) as a money laundering shell connecting Leon Black/Apollo and Jeffrey Epstein
2. SEC corruption in dropping an Apollo investigation after Kushner Jr. met with Apollo co-founder Joshua Harris at the White House
3. Apollo Global Management financing the Kushner family's 666 Fifth Avenue deal through Brookfield
4. Michael Milken's network of "proteges" running Apollo, including Leon Black, Joshua Harris, and Marc Rowan
5. Whistleblower intimidation through 11-12 anonymous threatening phone calls

The Epstein files database contains 117+ distinct documents (EFTA numbers) related to Dilorio -- 16 in DS8 (identified in the original investigation) and 101 additional documents in DS9 identified via the full corpus search. The complaints span from April 2019 through at least August 2021, with post-2020 documents expanding allegations to RIOT Blockchain, Archegos/Hwang, DFC/Kodak/Kushner, and PHUN/Trump/Parscale mobile app technology.

DOCUMENT INVENTORY

All Dilorio Documents Found (16 EFTA numbers)

SECTION 1: THE CORE ALLEGATION -- ESWW AS EPSTEIN/APOLLO NEXUS

Environmental Solutions Worldwide, Inc. (OTCMKTS: ESWW)

Dilorio's central claim is that ESWW was a money laundering shell company connecting Jeffrey Epstein directly to Leon Black and Apollo Global Management.

Key evidence cited by Dilorio (from EFTA00009904, EFTA00010305, EFTA00010710, EFTA00010786, EFTA00011051, EFTA00029043):

"Find a shell. Find a fraud.
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001082278

Florida? Pennsylvania? or Canada?
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time. Literally.

Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al

Then, There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?

The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in...
Wait for it...
Leon Black/Apollo Environmental Solutions Worldwide

https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm"

Dilorio explicitly states (from multiple documents):

"ESWW was a money laundering shell.
The SEC knows it. The degenerate Epstein knows it. The Degenerate Leon Black/Kushner BFF/ Milken proteges/Marc Rowan/Apollo knows it.
The DOJ/IRS knows it."

The ESWW connection is significant because:
- Leon Black/Apollo filed multiple SEC forms regarding ESWW (SEC EDGAR CIK: 0001082278)
- Epstein's Financial Trust Company Inc. appears in ESWW SEC filings
- This is described as "The ONLY SEC filing of Epsteins' Financial Trust Company Inc"
- ESWW was subject to an SEC complaint: SEC v. [defendants] regarding a "$15 million pump and dump scheme involving the securities of Environmental Solutions Worldwide, Inc."
- The SEC's own litigation reference: https://www.sec.gov/litigation/complaints/comp17673.htm
- ESWW was de-registered in 2015 and "frozen in time"
- ESW Group board included Mark Yung, Co-Founder of OCV Management, formerly of Orchard Capital Corp

DS9 Full Corpus Verification (2026-02-12): Dilorio's ESWW claim is now independently verified by primary source documents in the corpus:

• EFTA00586106: The actual November 2012 Purchase and Sale Agreement between Financial Trust Company, Inc. (Epstein's USVI entity, 6100 Red Hook Quarter, B3, St. Thomas) and Black Family Partners (Leon Black) for 13,350,205 shares of ESWW common stock, plus AP SHL Investors LLC interest and AP Technology Partners LLC interest, for a total purchase price of $18,000,000 ($7.79M for ESWW shares, $3.5M for AP SHL, $6.71M for AP Tech).
• EFTA00585846: Irrevocable Stock Power for 13,198,711 shares of ESWW common stock from Financial Trust Company (TIN 66-0567418).
• EFTA00585853: FTC letter to JP Morgan directing transfer of 151,494 ESWW shares.
• EFTA00593329: AP SHL Investors LLC K-1 tax filing (2012): Financial Trust Company listed as Partner 4 (EIN 66-0567418, St. Thomas, VI 00802). This is IRS documentary proof that FTC was a partner in an Apollo-related investment entity.
• EFTA00585848: Exhibit E: Consent of Managing Member of AP Technology Partners LLC for the FTC-to-BFP transfer.
• EFTA00616992: Black Family Group Entity Look-Thru showing ESWW valued at $2,075,700 + convertible note at $2,941,093 on Black's books as of April 2014.
• EFTA00299927: Epstein's master file cabinet inventory listing "PURCHASE & SALE BY BLACK FAMILY PARTNERS, LP FROM FINANCIAL TRUST COMPANY, INC." as a dedicated file section.

Epstein's Financial Trust Company

Dilorio's claim that Epstein's Financial Trust Company appears in ESWW filings is corroborated by other documents in the database:
- EFTA00014685: JPMorgan Chase account for "JEFFREY E EPSTEIN C/O FINANCIAL TRUST COMPANY" in St. Thomas, USVI 00802
- EFTA00015176: Morgan Guaranty Trust Company accounts for "FINANCIAL TRUST COMPANY, INC." showing multi-million dollar transactions (October 1999)
- EFTA00018778: GVI v. Estate of Jeffrey Epstein complaint states Financial Trust Company, Inc. "(incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012"
- EFTA00015184: J.P. Morgan Entity Account Application for "FINANCIAL TRUST COMPANY INC, C/O AMERICAN YACHT HARBOR" at 6100 Red Hook Quarters, St. Thomas, USVI

SECTION 2: THE SEC DROPS APOLLO INVESTIGATION

The Core Claim

Dilorio repeatedly states across virtually all 16 documents:

"SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$

And, Apollo gets $60 bil+ in inflows in 2018

Did I miss something?"

Supporting Evidence Cited by Dilorio

1. The NY Post Article (cited in EFTA00010305, EFTA00010767, EFTA00011051, EFTA00011074, EFTA00011078, EFTA00029043):

"SEC dropped probe month after firm aided Kushner company
The feds last year dropped an investigation into a financial company a month after the firm gave Jared Kushner's family real estate business a $180 million loan, a new report said Friday."
-- NY Post, March 2, 2018

2. The CNBC Report (cited in same documents):

"Trump: Kushner's security clearance is up to Kelly
Kushner even discussed the possibility of a White House job for the founder of private equity firm Apollo, the New York Times reported on Tuesday."

Dilorio notes: "Where another Milken protege/Apollo founding partner Josh Harris was considered for a White House job."

3. The Stephanie Avakian/SEC Enforcement Connection:

Dilorio connects SEC Division of Enforcement Co-Director Stephanie Avakian to the dropped probe:

"A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!"

He links:
- Howard E. Heiss (O'Melveny & Myers) - "extensive litigation practice focused on government regulatory investigations"
- Jamie Gorelick (WilmerHale) - represented corporations in "regulatory and enforcement arenas"
- Robert Mueller III (WilmerHale)
- Stephanie Avakian (SEC) - "named Co-Director of the SEC's Division of Enforcement in June 2017"

The implication is a revolving door between law firms representing Apollo and SEC enforcement officials.

4. Apollo's $60 Billion+ Inflows:

Dilorio cites Apollo's Q2 2018 earnings report showing massive capital inflows, suggesting the SEC dropping the investigation enabled this growth.

SECTION 3: THE KUSHNER/APOLLO/666 FIFTH AVENUE CONNECTION

Apollo Financing Kushner's 666 Fifth Avenue

From EFTA00010305, EFTA00010710, EFTA00010786, EFTA00011051, EFTA00029043:

"Of Course, then there's the Hail Mary pass Kushner threw on his Toronto based Brookfield deal for 666 5th Avenue"

Citing: "Toronto-based Brookfield faces scrutiny from Democrats over deal with Kushner company"

"which was brokered by Apollo/Epstein Degenerate Black/Harris/Rowan"

"666 Fifth | Brookfield | Apollo Global Management -- Private equity company Apollo Global Management is funding Brookfield Property Partners' redevelopment of 666 Fifth Avenue with a $300 million-plus mezzanine loan"

"Apollo and other Kushner financing pal Blackstone just happen to be BOTH granted free reign on the US insurance/annuity industry."

The Web of Connections Dilorio Maps

From EFTA00010767 and EFTA00010786, Dilorio creates an explicit connection map:

"Leon Black/Apollo/Schwarzman: Trump Kushner
Black/Apollo/Schwarzman: Epstein
Black/Apollo/Schwarzman: Putin/RU"

Citing Reuters: "UPDATE 2-Putin gets SWF, PE backing for Russia fund" -- noting "Apollo's Black shares platform with Putin"

From EFTA00027528:

"SEC: dropped Apollo charges: Avakian/Heiss
SEC NITE/VIRT obstruction: Jay/Sull Crom/Fishman
IMDB: PHUN/Nordlicht/AIPAC: Greek shippers
Economou/EKONOMOU
Bistricers
Feinberg: Danaos
Trump attorney: EKONOMOU
Barr IMDB waiver: AQR"

From EFTA00010786 and EFTA00027528:

"Epstein: Schwarzman
Epstein: Black
Black/Schwarzman: Kushner (my BX SEC TCR)"

The Kushner Family Beyond Jared

From EFTA00010819 (page 57), Dilorio lists the Kushner family among a network:

"Alpha Capital Anstalt: Liechtenstein: IMDS: Bag Man Schlaff: Bawag: Refco: Rhino: Sedona: Scan Graphics: Shaye Hirsch: Karfunkel: Kushners: Nordlicht: Englander: et al: Judge Swain Derivatives."

From EFTA00010786:

"Also Schlaff AND: Englander/Nordlicht/Kushners
abusive naked shorting to facilitate $$ laundering: Sedona/Scan Graphics"

SECTION 4: THE THREATENING PHONE CALLS

Documentation of 11-12 Threatening Calls

This claim appears in virtually every document in the chain. The most detailed account comes from EFTA00009904, EFTA00010305, EFTA00010710, EFTA00015194, EFTA00027528, EFTA00029043:

"This was a blatant attempt to intimidate a whistleblower. 'HE' (I think a male although very effeminate voice) was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that. This is a VERY serious matter. Felony. I intend to see 'him' prosecuted to the fullest extent of the law. Within weeks of filing a complaint against the SEC and you."

"obviously have hit a nerve."

Timeline of the threatening calls:
- The calls came "within weeks of filing a complaint against the SEC"
- The complaint subject was "Apollo/Epstein/Kushner connection"
- The first email documenting the threats is dated May 2, 2019 (sent at 3:35 PM)
- This was sent to SEC OIG, SEC Chairman's office, DOJ officials, and others

Significance: The threatening calls occurred:
- BEFORE Epstein's July 6, 2019 arrest
- Shortly after Dilorio began connecting Apollo/Epstein/Kushner publicly
- The caller was anonymous with an "effeminate voice"
- Dilorio characterizes this as a federal felony (intimidation of a whistleblower)

SECTION 5: THE MILKEN CONNECTION

Michael Milken as Central Figure

Dilorio consistently refers to Apollo founders as "Milken proteges" and "Milken degenerates."

From EFTA00009904:

"ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein"

From EFTA00010786:

"Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al"

From EFTA00010819 (page 50):

"There is a straight and direct line between ICP/Priore and the Degenerate Milken as well as the corrupt SEC/SDNY...
Ares Management: Neiman Marcus: Tony Ressler: Milken/Drexel degenerate flunkie has built quite the monstrosity.
Ressler's sister is married to Fat Leon Black. Close knit bunch for sure."

From EFTA00010819 (page 73):

"Like Milken: Insider trading is NOT the real issue here."

The Piwowar/Milken Institute Email (EFTA00011078):
- Dilorio sent his "Apollo/Epstein/Kushner connection" email directly to [email protected]
- Michael Piwowar was an SEC Commissioner (2013-2018) who departed to become Executive Vice President at the Milken Institute
- This is a striking detail: a former SEC Commissioner went directly to work for the Milken Institute, and Dilorio was alerting him to these connections

From EFTA00010305:

Dilorio cites: "Bernard Madoff, the Mafia, and the Friends of Michael Milken" (MarketRap article)

The CLO/Insurance Connection (EFTA00010819, page 50):

"Non bank lenders like the massive Ares pose a systemic risk to the US financial system. CLO's are a massive fraud on the public developed by the Milken degenerates like the sub prime and S&L's."

"Non bank lenders like Ares as well as Apollo, Jefferies, Ted Virtue etc etc have reaped tens of millions in management fees."

From EFTA00010786 (the April 2020 addition):

"Trump Junk. Today, because of 'Coronavirus' Trump and another Milken Degenerate: Treasury Sec Mnuchin are bailing out High Yield: JUNK

Milken degenerate flunkies:
Fat Leon: #1 CLO Mgr
Handler/Jefferies: #2 CLO Mgr
CLO's: Junk on Steroids

Remember the S&L crisis? Same Milken degenerates (incl Trump banker Moelis): Drexel stuffed S&L's with JUNK"

SECTION 6: THE SEC INVESTIGATION REFERENCES

Covered Action 2015-016 / Knight Capital TCR

Dilorio's original SEC whistleblower complaint was filed in 2013 regarding Knight Capital Group (NITE), later merged with Virtu Financial. This is referenced as "covered action 2015-016."

From EFTA00010819:
- Multiple references to "Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix"
- "Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix"
- "Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix"

The "Christopher J Dilorio Rule" (EFTA00010819, page 54):

"AGAIN AGAIN AGAIN IG Hoecker et al: the 'summary disposition' aka Christopher J Dilorio rule corruptly enacted by Norberg/Clayton et al was/is COMPLETE FRAUD"

This suggests the SEC created a procedural mechanism (the "summary disposition") that Dilorio believes was specifically designed to deny his whistleblower claims.

Persons Referenced at SEC

Dilorio names the following SEC/DOJ/FINRA officials:
- SEC OIG ([email protected])
- SEC Chairman's Office ([email protected])
- Carl Hoecker - SEC Inspector General ("corrupt SEC IG Carl Hoecker who not only has criminally and corruptly obstructed an investigation")
- Stephanie Avakian - SEC Division of Enforcement Co-Director
- Jay Clayton - SEC Chairman
- William Hinman - SEC Division of Corporation Finance Director
- Michael Piwowar - Former SEC Commissioner (now at Milken Institute)
- Wes Bricker - SEC Chief Accountant
- Brett Redfearn - SEC Division of Trading and Markets Director
- Lara Shalov Mehraban - SEC NY ("Was Dougie 'Large' Cifu your boss at Paul Weiss?")
- Norberg - SEC official (co-created "summary disposition" rule)
- Gottschall - SEC official (issued "no further investigation" letter)

DOJ Officials Copied

• John Lausch ([email protected])
• John Kucera ([email protected])
• Shannen Beckman, Woo Lee, Deborah Connor, Mary Butler, Jonathan Baum, Steven Welk, Lawrence Middleton
• Jessie Liu ([email protected])
• Craig Carpenito ([email protected])
• Theresa Watson

FINRA Officials

• Yvonne Huber ([email protected])

FinCEN

• [email protected] (email dated May 17, 2019)

Media Recipients

• Rebecca Ballhaus (WSJ)
• William Alpert (Barron's)
• Andrea Marques, Robert Hirsch, Charles Frank (Miami Herald)
• Kristin Broughton (WSJ)
• John Crudele
• D. Dayen

SECTION 7: TIMELINE OF THE DILORIO COMPLAINTS

Pre-Epstein Arrest Timeline

Post-Epstein Arrest Timeline

SECTION 8: THE APOLLO/EPSTEIN/LEON BLACK NEXUS -- CORROBORATION

Evidence Within the Epstein Files Database

Beyond Dilorio's complaints, the database contains independent corroboration of the Black/Epstein relationship:

EFTA00025507:

"Subject: Apollo Board Panel to Review Leon Black Ties With Jeffrey Epstein - The Wall Street Journal"

EFTA01928406:

"Drive to Leon Blacks house with Karyna."

EFTA02048222:

"Alert - 1:00pm LUNCH w/Leon Black"

EFTA02075284:

"Leon Black and his assistant"

EFTA02137154:

"Wed 6/5/2013 1:09:15 PM -- Alert - 9:00am Appt w/Leon Black At Leo[n's]"

EFTA02158330:

"Subject: Re: Leon Black"

EFTA02731473:

"Subject: Fwd: Leon Black follow up"
"Subject: [EXTERNAL] Leon Black follow up"

EFTA02731477:

"Subject: Leon Black/Additional HT Subject Referral Update"

EFTA02731486:

"Subject: RE: Epstein/Maxwell/Leon Black/Additional Subject" (multiple versions)

Marc Rowan -- Direct Epstein Relationship (DS9/DS11 Expansion)

DS9 and DS11 reveal that Marc Rowan had an active, substantive relationship with Epstein -- not merely a peripheral mention in Dilorio's allegations. DS11 contains 15+ documents of direct Rowan-Epstein correspondence:

• EFTA02335969: Rowan to Epstein discussing Apollo TRA (Tax Receivable Agreement) valuations
• EFTA02340186: Epstein asking Rowan about "worksheet calculation for the tra number on the balance sheet"
• EFTA02450093: Brad Wechsler (Elysium Management/Black's family office) instructing staff to CC "Jeffrey Epstein" on Apollo historical 8865 filings: "for Jeffrey its also get the benefit of his substantive expertise"
• EFTA02452433: Epstein to Rowan: "Happy to explain my thinking on the 8865 issue"
• EFTA02466137: Rowan forwards an Edmond de Rothschild cooperation email to Epstein, discussing Financial Credit Fund 3, Capital Efficient Investing for insurance companies, and European Financials Equity Vehicle
• EFTA02361689: Perry Shwachman (Sidley Austin) to Rowan AND Epstein about "potential new USVI insurance regulations"
• EFTA02405147: "Leon has asked Barry Cohen and Marc Rowan to call you re Donor Advised Funds"
• EFTA02374581: Epstein to Rowan: "I know Nick Ribis for a long time... you should not rely on my introduction to mean anything more than that"

DS9 scheduling documents: EFTA00331035 confirms a January 14, 2016 meeting at Epstein's home where "Marc and his partner, Imran [Siddiqui], will come see Jeffrey today at 3:45pm... Ariane de Rothschild and Cynthia Tobiano will be here as well." EFTA00331476 shows Epstein was interested in buying Rowan's G450 plane for $18.95M.

This confirms Rowan was a direct participant in the Epstein financial network, involved in Apollo TRA valuations, 8865 tax filings, USVI insurance regulation discussions, Rothschild business development, and regular meetings at Epstein's home.

Deutsche Bank Transaction Exhibits (DS9 Expansion)

EFTA00080260 (Exhibit A, Deutsche Bank production) provides the complete wire transfer records documenting $98M+ flowing from Black/Apollo entities to Epstein's Southern Trust Company between October 2013 and April 2017:

Also documented: $10M from Edmond de Rothschild (Suisse) SA Geneva (12/17/2015) and $14.99M from Benjamin Edmond de Rothschild (12/21/2015). BV70 LLC wires to Plan D, LLC total $30.5M (3/31/2017 and 4/17/2017).

EFTA00285298: Epstein's fee dispute letter to Black reveals Epstein claimed to have saved Black "$600 million -- after tax" and expected $50-60M in fees. He discusses "Athene, Montauk Rothschild" as proposed transactions and criticizes Brad Wechsler (Elysium Management) as incompetent.

Victim Testimony Mentioning "Black"

EFTA01656152, EFTA01656173, EFTA01656198, EFTA01660622 (Prominent Names document, page 17):
These documents contain a law enforcement summary of victim allegations against prominent individuals. Under the "Black" entry, the text is partially redacted but reads:

"[victim] told her to give Black [redacted]"

This appears in the same document that lists allegations against Trump, Weinstein, Prince Andrew, Alan Dershowitz, and Bill Clinton.

SECTION 9: THE INSURANCE/ANNUITY INDUSTRY TAKEOVER

Apollo/Athene/Blackstone Insurance Play

Dilorio describes what he considers the most dangerous aspect of the Apollo connection:

From EFTA00010786 (April 2020):

"WHO has 'green lighted' the Milken Degenerate Fat Leon Black/APO and the degenerate Steve Schwarzman/BX take over of the Insurance industry?

Recall Fat Leon/APO raiding Athene and investing policy holder money in bankrupt Harrahs and Caesars"

He cites Forbes: "Apollo And Blackstone Pick Insurance As Their Next Bet To Disrupt Wall Street"

"This will NOT end well for tens of thousands of Americans.
Who 'green lighted' this take over of the insurance industry by PE/Hedge funds?"

This concern about Apollo's insurance operations through Athene has since been validated by extensive regulatory scrutiny.

SECTION 10: RELATED CONNECTIONS AND NETWORK MAP

The Broader Network Dilorio Identifies

Cerberus/Stephen Feinberg:

"Trump Chooses Cerberus's Stephen Feinberg to Lead Spy Advisory Panel"
Connections: Bawag/Refco, Virtu first bid for Knight post "glitch", Money Laundering Bank HSH

Alpha Capital Anstalt (Liechtenstein):

Connected to Martin Schlaff, Bawag, Refco, Sedona, Scan Graphics
"The SEC has kept Alpha Capital Anstalt up and running so the activity detailed in my complaints can continue."

Calk/Lorber/Elliman:

Stephen Calk charged with "corruptly soliciting a Presidential Administration Position in Exchange for Approving $16 Million in Loans"
Lorber/New Valley Corp connected to Apollo Moscow/Kremlin development

Sullivan & Cromwell:

"Clayton's firm Sullivan Cromwell/Jared Fishman/Rodgin Cohen et al are EXPERTS on penny stock fraud having bailed out the criminal enterprise Knight/KCG/VIRT:NITE on more than 1 occasion."

Krieger, Kim and Lewin LLP:

"Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm"
Dilorio repeatedly references this firm in connection with the Epstein case -- "Enter the Amicus blocking release of Epstein docs"

SECTION 11: ASSESSMENT AND SIGNIFICANCE

What Makes the Dilorio Complaints Significant

1. Pre-Arrest Timing: Dilorio was connecting Epstein to Apollo/Black/Kushner in April 2019, three months before Epstein's arrest. This suggests either extraordinary analytical work or insider knowledge.

2. ESWW/Financial Trust Company Connection: The claim that Epstein's Financial Trust Company appears in ESWW SEC filings alongside Leon Black/Apollo is a verifiable claim via SEC EDGAR (CIK: 0001082278).

3. SEC Probe Drop: The NY Post report confirming the SEC dropped an Apollo investigation one month after Apollo gave Kushner Companies a $180 million loan is independently verifiable public reporting.

4. Leon Black Confirmed: Leon Black's relationship with Epstein was subsequently confirmed. Black acknowledged paying Epstein $158 million in fees. Black stepped down as Apollo chairman in March 2021. An Apollo board review confirmed the relationship.

5. Josh Harris White House Visits: The claim about Josh Harris meeting with Kushner at the White House was confirmed by public reporting. Harris subsequently abandoned his pursuit of a White House position.

6. 666 Fifth Avenue/Apollo Financing: Apollo's $300 million+ mezzanine loan for Brookfield's 666 Fifth Avenue (Kushner property) deal was confirmed by The Real Deal.

7. Piwowar to Milken Institute: The fact that Dilorio sent his complaint directly to a former SEC Commissioner at the Milken Institute address ([email protected]) demonstrates awareness of the revolving door between SEC and entities connected to his allegations.

8. Volume of Documentation: 16 documents, 100+ pages of detailed allegations sent to dozens of SEC, DOJ, FINRA, FinCEN, and FBI officials represents an extraordinary record that was preserved in the Epstein files.

What Cannot Be Independently Verified from These Files Alone

1. ~~The specific claim that Epstein's Financial Trust Company filed SEC documents regarding ESWW~~ VERIFIED: DS9 contains the actual Purchase and Sale Agreement (EFTA00586106), K-1 tax filings (EFTA00593329), Irrevocable Stock Power (EFTA00585846), and file cabinet inventory (EFTA00299927) documenting the $18M FTC-to-BFP ESWW transaction
2. The threatening phone calls (Dilorio's account only; no corroborating recordings or phone records in the database)
3. The specific allegation of a quid pro quo between the SEC dropping the Apollo probe and the Kushner loan
4. Whether Dilorio's Knight Capital TCR (covered action 2015-016) actually contained the information he claims

The "Summary Disposition" / "Christopher J Dilorio Rule"

Dilorio's claim that the SEC created a procedural mechanism specifically to deny his whistleblower award -- which he calls the "Christopher J Dilorio rule" -- is one of his most serious allegations. If true, it would represent an extraordinary institutional action to suppress a specific whistleblower's claims.

SECTION 12: KEY QUOTES AND EVIDENCE COMPILATION

On ESWW (from EFTA00009904 OCR):

"ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund"

On SEC Corruption (from EFTA00010786 OCR):

"SEC drops Apollo investigation after Kush Jr met with Harris at the WH and Apollo gives Kush's some $$$$"

On Threatening Calls (from EFTA00015194 OCR):

"This was a blatant attempt to intimidate a whistleblower. 'HE' (I think a male although very effeminate voice) was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that. This is a VERY serious matter. Felony."

On the Network (from EFTA00010767 OCR):

"Leon Black/Apollo/Schwarzman: Trump Kushner
Black/Apollo/Schwarzman: Epstein
Black/Apollo/Schwarzman: Putin/RU"

On the SEC Whistleblower Program (from EFTA00010819):

"AGAIN AGAIN AGAIN IG Hoecker et al: the 'summary disposition' aka Christopher J Dilorio rule corruptly enacted by Norberg/Clayton et al was/is COMPLETE FRAUD"

Dilorio's Self-Assessment (from EFTA00010786):

"What have I been wrong about? NOT ONE SINGLE FUCKING THING"

METHODOLOGY

This analysis was conducted by querying three databases:
- the primary document text database (660MB) - text extracted from document text layers
- the OCR text extraction database (68MB) - OCR text from document images
- the Dataset 10 document text database (532MB) - additional redaction analysis

Search terms included: Dilorio, DiIorio, Apollo, ESWW, Environmental Solutions, Kushner, whistleblower, Milken, Kasowitz, Leon Black, Marc Rowan, 666 Fifth, Financial Trust Company, Piwowar, Avakian, intimidate, threaten, Schwarzman, Athene, Berger Montague, covered action 2015, TCR.

All 16 EFTA documents were extracted and cross-referenced. OCR and redaction databases were searched independently and results merged.

NOTE ON MARC KASOWITZ

A search for "Kasowitz" across all three databases returned no results. While public records suggest Dilorio may have had legal representation, no reference to Marc Kasowitz or Kasowitz Benson Torres appears in the redacted or OCR-recovered text within these documents.

Report generated: 2026-02-06 | Updated 2026-02-12 with DS9/DS11 full corpus findings (1,380,937 documents)
Database sources: primary document text database, OCR text extraction database, Dataset 10 document text database, full_text_corpus.db
Total EFTA documents analyzed: 117+ Dilorio-specific (16 DS8 + 101 DS9) + corroborating Leon Black/Epstein documents
Key updates: ESWW independently verified ($18M Purchase and Sale Agreement), Dilorio corpus 6x larger than reported, Marc Rowan direct relationship documented (15+ DS11 docs), Deutsche Bank exhibits ($98M+ Black-to-Epstein)