Witness Briefing: RICHARD D. KAHN

Estate Co-Executor, Accountant, HBRK Associates Principal

Deposition date: March 11, 2026 (rescheduled from February 25) (Washington Examiner)
Type: Subpoena deposition before House Committee on Oversight and Government Reform
Congressional counsel: Daniel Ruzumna, Patterson Belknap Webb & Tyler LLP (Bloomberg Law)
Civil litigation counsel: Daniel H. Weiner, Hughes Hubbard & Reed LLP (NBC News)
Cooperating posture: "Intends to testify" — the co-executors have produced "thousands of pages of documents, photographs, and other materials" (Bloomberg Law)
Corpus footprint: 68,246+ pages across multiple entities — one of the largest footprints in the EFTA production

Updated: March 7, 2026
Sources: EFTA corpus, prosecutorial_query_graph.db, existing investigation reports, news sources
Standard: Every factual claim supported by EFTA number with justice.gov URL, OR external source URL

See also: Congressional Subpoena Guide | Witness Brief: Darren Indyke | HBRK Associates Investigation | Shell Entity Map | DB KYC Breach Investigation

1. WHO HE IS

Background

What Makes Him Critical

Richard Kahn controlled the money. Every wire transfer, every entity balance, every construction payment, every trust disbursement flowed through HBRK Associates under his direction. The FBI's own Deutsche Bank 302 states:

"Wire requests would generally come in from Richard Kahn, JE's accountant. Richard Kahn would at least be CC'd on all requests."
— EFTA00128780

He managed 39+ entities across six properties. He tracked Leon Black's $10 million wires. He directed $23 million to Erika Kellerhals's escrow account. He opened TD Bank accounts weeks before Epstein's arrest. He was named co-executor of a $577 million estate in a will signed two days before Epstein's death. And despite all of this, no law enforcement agency ever sat him down for a single interview.

2. ENTITY MANAGEMENT — THE 39+ SHELLS

Banking Relationships

Entity Portfolio Under HBRK Management

HBRK Associates managed accounts and operations for at minimum 39 entities, including:

Core Financial Entities: Southern Trust Company, Southern Financial LLC, HBRK Associates Inc, LSJE LLC, JEGE Inc, Plan D LLC, NES LLC, Zorro Management LLC, Prytanee LLC, Neptune LLC, Hyperion Air LLC, Gratitude America Ltd

Trusts: Haze Trust, Butterfly Trust, Insurance Trust #2, Financial Ballistics Trust, 1953 Trust, KCAC LLC

Island Operations: LSJ Employees LLC (payroll), Island Grounds Inc (predecessor), F T Real Estate Inc

Other: Darren K. Indyke PLLC, JSC Interiors LLC, Jeepers Inc, Aviloop LLC, Birch Tree BR LLC, Ellmax LLC, MAX Foundation, C.O.U.Q. Foundation

Leon Black / Wanek Family: 14 trusts/GRATs/LLCs; The Jockey Club, Blood-Horse LLC, Equibase Company

Net worth declared to banks: $500,000,000 (EFTA01582951)

Corpus footprint: 35,919 documents reference HBRK — among the largest entity footprints in the production. (HBRK Investigation)

3. THE MONEY — AGGREGATE BALANCES

$159 Million Snapshot (October 2015)

An email from Kahn to Epstein on November 9, 2015, shows:

"darren mentioned i should transfer 20,000,000 to erika escrow account. currently the 3 accounts that have over 20,000,000 balances as of 10-31-2015 are as follows:
- southern trust: $82,500,000
- haze trust: $47,375,000
- southern financial llc: $29,250,000"

Total: $159,125,000 across three accounts alone.

He was asking which account to pull $20 million from — on top of a previous $3 million transfer 11 days earlier. The "erika escrow account" belonged to Erika Kellerhals, Epstein's USVI attorney.

Source: EFTA02671293

$84.5 Million Deutsche Bank Snapshot (June 2017)

A Deutsche Bank daily deposit report from June 28, 2017, shows balances under RM0082289:

Source: EFTA01421052

JPMorgan Exit (October 2013)

When Epstein's accounts were transferred from JPMorgan to Deutsche Bank, cash transfers included:

• Southern Financial LLC: $14,454,511
• Southern Financial LLC (second account): $329,921
• Southern Trust Company (checking): $372,922
• Southern Trust Company (savings): $18,755,049
• Haze Trust: $28,370
• Jeepers Inc: $5,000
• Total documented transfer: $33.9 million+

Source: EFTA01578684

4. WIRE TRANSFER OPERATIONS

The HBRK → Southern Trust → LSJ Pipeline

Kahn directed a documented pipeline from HBRK-managed Deutsche Bank accounts through Southern Trust Company to LSJ Employees LLC at FirstBank Puerto Rico:

HBRK → Southern Trust funding (2016-2019):

Source: EFTA01273155

LSJ Employees LLC funding (2016-2019):

• 56 documented Fedwire advices
• Wire amounts: $175,000–$800,000 each
• Aggregate documented inflows: $15+ million
• Originator on all wires: "Jeffrey Epstein C/O HBRK Associates"
• Source accounts: Deutsche Bank (#0035269691), later TD Bank

Source: EFTA01273181, EFTA01273198

Leon Black Payment Tracking

Kahn tracked and chased multi-million dollar payments from Leon Black:

$10 million received (April 28, 2014):

"I apologize for the improper information this morning. Two wires totaling 10,000,000 were received late friday — (1) Black Family Partners LP $5,000,000; (2) Leon & Debra Black $5,000,000"
— EFTA01927911

$10 million overdue follow-up:

"i left you a voicemail earlier as i am not sure if you spoke with jeffrey regarding a 10,000,000 payment that was due yesterday"
— Kahn to Eileen Alexanderson (Black's assistant), EFTA01928263

Other Directed Payments

5. TD BANK SUSPICIOUS ACTIVITY REPORT

A FinCEN SAR filed by TD Bank on October 1, 2019, documents $47,296,860 in suspicious activity involving 25 subjects between May 2015 and August 2019.

Key findings regarding Kahn and HBRK:

HBRK Account #4332216963 — Kahn sole signer:
- Funded by $100,000 check from Deutsche Bank HBRK account + $847,838 in wires
- Two cash withdrawals by Kahn: $4,400 (Feb 1, 2019) and $50,000 (May 7, 2019; Currency Transaction Report filed)
- $20,000 wire to Liechtenstein lawyers (re: purchase of shares/Anstalt)
- Tuition payments for a female student

HBRK/NES Account #4332212771 — Kahn sole signer:
- Funded by $3,736,685 in wires from Deutsche Bank (NES LLC c/o HBRK), Charles Schwab (Southern Trust Company), and Southern Country International
- $8,000 cash withdrawal by Kahn

TD Bank's assessment of HBRK:

HBRK was described to the bank as providing accounting services to "Ultra High Net Worth individuals" but "activity in the accounts since they were opened does not suggest the existence of any clients other than Jeffrey Epstein."

Timing: Kahn opened TD Bank accounts in February-April 2019 — coinciding with Deutsche Bank's exit of Epstein and just months before the July 6, 2019 arrest.

Source: EFTA01656524

6. TRUST STRUCTURES

The 1953 Trust (August 8, 2019 — two days before death)

The Employment Lock-In (Section 2.5)

The 1953 Trust contains a provision that names HBRK Associates, Inc. by name — the only corporate entity singled out in the clause:

"No bequest to any Beneficiary... who, during my lifetime, was employed by or provided services to me or any entity that was owned directly or indirectly by me during my lifetime or HBRK Associates, Inc.... shall be distributed to said Beneficiary prior to the expiration of two years following the date of my death."

Any beneficiary who voluntarily quit or was terminated for misconduct within two years would forfeit their entire bequest. The trust further required continued employment of all HBRK/Indyke employees for two years post-death, with compensation from trust assets.

Effect: Every HBRK employee, every island staff member, every household manager — anyone who worked for HBRK — had financial incentive to remain employed and silent for exactly two years after August 10, 2019.

Notable exception: Section 2.5(D) explicitly exempts the Trustees themselves (Kahn and Indyke) from this lock-in provision. The two-year forfeiture clause applied to the staff beneath them, not to Kahn and Indyke personally.

The lock-in expired approximately August 10, 2021.

Source: EFTA00099303

Butterfly Trust (December 27, 2006)

Kahn and Indyke were named co-trustees. In late 2014, beneficiaries were amended: Ghislaine Maxwell removed, replaced by Karyna Shuliak, Darren K. Indyke, and Richard Kahn.

Deutsche Bank compliance questioned the change in December 2016:

"What is the purpose of this trust, as it is not cleared within the original trust agreement? Based on the supporting documents provided, where in the trust agreement does it support the change of beneficiaries? Why are the beneficiaries changing?"
— Cynthia Rodriguez, Deutsche Bank AVP, EFTA01420392

See also: EFTA01296151, EFTA01282297

The 2018 Trust

Named Kathryn Ruemmler (former White House Counsel) as co-trustee alongside Indyke and Kahn. Source: EFTA00099449

Coatue Enterprises, LLC — The Unanswered Question

Section 2.3(A)(47) of the 1953 Trust specifically forgave all obligations owed by Kahn's personal entity Coatue Enterprises, LLC to Epstein or Southern Financial LLC. What was the nature and amount of these forgiven obligations? Is this entity related to the hedge fund Coatue Management (founded by Philippe Laffont), or entirely separate?

7. GRAND JURY SUBPOENA — ZERO RETURNS

EFTA00088989 — Grand jury subpoena from SDNY (Geoffrey S. Berman), dated October 18, 2019, commanding production by November 1, 2019.

Statutes cited: 18 U.S.C. §§ 1591 (sex trafficking), 1594(c) (conspiracy), 2422(b) (coercion/enticement), 371 (general conspiracy).

Materials demanded:
1. All documents relating to "The 1953 Trust" including the trust agreement itself and all referenced sub-trusts
2. All drafts or notes of the Trust Documents
3. All communications relating to the Trust Documents

Returns documented in PQG: Zero. There is no record in the Prosecutorial Query Graph of any production from Kahn in response to this subpoena.

Source: EFTA00088989

8. POST-DEATH FINANCIAL ACTIONS

Shell Entity Consolidation (December 12, 2019)

Four months after Epstein's death, seven shell entities were consolidated back into Southern Trust Company through HBRK-managed TD Bank accounts:

Eleven days later (December 23, 2019), $13,000,000 was transferred from Southern Trust to Interactive Brokers LLC in Greenwich, CT, for placement in an interest-bearing money market account.

Source: EFTA01273155 (pp. 16-22)

$35 Million Settlement (February 2026)

What plaintiffs alleged: Kahn and Indyke "organized, controlled, and directed almost every aspect of the Epstein sex-trafficking enterprise," structured bank accounts for cash access, and participated in coercing victims into sham marriages for immigration status.

What defendants denied: "Not a single woman has ever accused either Mr. Indyke or Mr. Kahn of committing sexual abuse or witnessing sexual abuse. Indyke and Kahn did not socialize with Mr. Epstein."

Sources: NBC News, ABC News, KSGF

9. FLORIDA SCIENCE FOUNDATION

Epstein created the Florida Science Foundation a few months before his 2008 jail sentence and dissolved it shortly after completing community service requirements.

What EFTA corpus shows:

• Wire transfers from C.O.U.Q. Foundation (JPMorgan) to One Clearlake Centre LLC at Wachovia Bank, referencing "The Florida Science Foundation — Invoice 1404" (rent payments, $1,049-$11,438 per transaction, 2008-2009)
• $50,000 wire from C.O.U.Q. to "The Florida Science Foundation" account directly, signed by Darren Indyke — EFTA01590120
• "Florida Science Foundation" used as an email alias for Epstein ([email protected]) — EFTA01899894

External reporting:

• Foundation paid PBSO $128,136 during incarceration; records show payments to off-duty deputies supervising Epstein during work release — WPTV
• Epstein worked at the foundation 6 days/week, 12 hours/day — PBS
• Lawsuit alleged the foundation's "main purpose was to give Epstein a haven from jail where he could prey on young women" — NBC News

Kahn's role: Vice president of the C.O.U.Q. Foundation, which funded the Florida Science Foundation's rent and operations.

10. HARRY BELLER — THE OTHER HALF OF HBRK

Harry Beller is the "HB" in HBRK. He worked for Epstein approximately 22 years (circa 1992-2014) — predating HBRK's 2008 incorporation.

Key facts:
- Listed as "Signer" with full powers on all HBRK-related accounts at JPMorgan — EFTA01582951
- JPMorgan wire protocol required calling Beller to confirm before execution
- Subject of at least 4 JPMorgan Suspicious Activity Reports for large cash withdrawals
- Authorized signer on FirstBank Puerto Rico accounts (Lafayette Contractors LLC, Freedom Air Petroleum LLC) — EFTA00065864
- Invoked the Fifth Amendment in deposition when questioned about HBRK

Question for Kahn: Why did Beller invoke the Fifth? What activities at HBRK warranted self-incrimination protection?

11. CONSTRUCTION AND OPERATIONS

Kahn managed construction and vendor relationships across all six Epstein properties. He consistently negotiated 3-6% discounts on every contract.

Key documented projects:

Personnel Control

Kahn managed the Island Grounds → LSJ Employees payroll transition:

"Eliminating IG payroll and moving everyone to LSJ Employees"
— EFTA02006925

And enforced Epstein's management philosophy with subordinates:

"emad has not authority zero i want him to take pictures and report period"
— Epstein to Kahn regarding project controller Emad Hanna, EFTA01832061

12. INVESTMENT ADVISORY

Beyond accounting, Kahn served in an investment advisory capacity:

• CC'd on Bank of America/Merrill Lynch trading recommendations
• Forwarded market analysis to Epstein (BNY Mellon stock analysis, EFTA01746531)
• Negotiated FX rates with Deutsche Bank: "that rate is not fair — please see if you can improve pricing" (EFTA01423992)
• Managed Butterfly Trust brokerage account opening at Deutsche Bank
• Oversaw tax returns for: Epstein personal (1040), Zorro Trust, Haze Trust, Butterfly Trust, Financial Ballistics Trust, KCAC LLC — EFTA01873997

13. DEPOSITION QUESTIONS

Block A: Banking & Wire Authority (10 questions)

1. "Walk us through the process by which wire transfer requests were initiated, reviewed, approved, and executed at HBRK."

2. "The FBI's Deutsche Bank interview states wire requests 'would generally come in from Richard Kahn.' Over the period 2013-2019, approximately how many wire transfers did you initiate or authorize?"

3. "On November 9, 2015, you emailed Mr. Epstein saying three accounts held $159 million and asked which to pull $20 million from for the 'erika escrow account.' What was the purpose of the $23 million in aggregate transfers to Erika Kellerhals's escrow?" [EFTA02671293]

4. "TD Bank filed a SAR documenting $47.3 million in suspicious activity involving 25 entities. You were the sole signer on HBRK Account #4332216963, from which you made two cash withdrawals — $4,400 in February 2019 and $50,000 in May 2019. What was the cash for?" [EFTA01656524]

5. "From the same account, you wired $20,000 to lawyers in Liechtenstein for the 'purchase of shares/Anstalt.' What was being purchased and for whose benefit?"

6. "The same account shows tuition payments for a female student. Who was this student and what was her relationship to Mr. Epstein?"

7. "You opened TD Bank accounts in February-April 2019 — after Deutsche Bank exited Epstein. Was this a planned transition, and did anyone at Deutsche Bank advise you that the bank was terminating the relationship?"

8. "On October 1, 2013, $33.9 million was transferred from JPMorgan to Deutsche Bank when Epstein's accounts were moved. Were you involved in the decision to leave JPMorgan, and were you aware of the reasons?"

9. "You tracked and chased $10 million payments from Leon Black. What was the stated purpose of these payments? Between 2013-2017, approximately $158 million flowed from Black's entities to Southern Trust. Were you aware of the specific purposes?" [EFTA01927911, EFTA01928263]

10. "Mr. Epstein instructed you: 'please send jean luc the amount of money owed to be wired in ny in dollars.' What was owed to Jean-Luc Brunel, and for what services?" [EFTA01928143]

Block B: Trust & Estate (6 questions)

11. "The 1953 Trust was executed August 8, 2019 — two days before Mr. Epstein's death. When did you first learn you would be named co-trustee and receive a $25 million bequest?"

12. "Section 2.5 of the 1953 Trust prohibited distribution of bequests to employees of HBRK Associates for two years after death, with forfeiture for voluntary resignation or termination for misconduct. Were you aware that this provision effectively locked all HBRK employees into silence during the most intensive period of federal investigation?"

13. "Section 2.3(A)(47) forgave all financial obligations owed by you or Coatue Enterprises, LLC to Epstein or Southern Financial. What is Coatue Enterprises, what was the nature and total amount of these forgiven obligations?"

14. "In 2014, the Butterfly Trust beneficiaries were changed — Ghislaine Maxwell was removed and replaced by Karyna Shuliak, Darren Indyke, and yourself. Why were beneficiaries changed, and who made the decision?" [EFTA01420392, EFTA01296151]

15. "On December 12, 2019, you consolidated $9.2 million from seven shell entities into Southern Trust, then transferred $13 million to Interactive Brokers eleven days later. Who authorized these transactions and what was the purpose?" [EFTA01273155]

16. "A SDNY grand jury subpoenaed you on October 18, 2019, for all 1953 Trust documents. Did you produce documents in response? Our records show zero returns." [EFTA00088989]

Block C: Operations & Knowledge (4 questions)

17. "TD Bank assessed that HBRK's accounts did not suggest 'the existence of any clients other than Jeffrey Epstein.' Did HBRK have any clients besides Mr. Epstein?"

18. "Harry Beller, your co-principal at HBRK, invoked the Fifth Amendment when questioned about HBRK's activities. Why would the co-founder of an accounting firm need self-incrimination protection?"

19. "The USVI Attorney General called you and Mr. Indyke 'indispensable captains' of Mr. Epstein's criminal enterprise. Senator Wyden confirmed that no law enforcement agency ever questioned you. Why do you believe that was?"

20. "You managed payroll for all island employees through LSJ Employees LLC, funded by $15 million+ in wires you directed. Were you aware of any sexual abuse of minors at any of the six properties you managed?"

14. COUNTER-STRATEGIES

If He Invokes the Fifth

• The Fifth Amendment does NOT protect pre-existing documents — only testimony
• Subpoena HBRK corporate records directly; HBRK Associates Inc. (a corporation) has no Fifth Amendment privilege
• Subpoena TD Bank, Deutsche Bank, JPMorgan records independently of Kahn

If He Claims Attorney-Client Privilege

• Kahn is not a lawyer — he is an accountant. Attorney-client privilege does not apply to his communications.
• The accountant-client privilege does NOT exist under federal law. Only a few states recognize it, and it does not apply in federal proceedings.
• His co-executor Indyke may attempt to assert privilege over joint communications, but the crime-fraud exception applies to communications furthering ongoing criminal activity.

If He Claims Limited Knowledge

• His own emails show he tracked every wire, managed every entity, chased every payment
• He personally withdrew $50,000 in cash (triggering a CTR)
• He managed payroll for all island employees
• He negotiated construction contracts down to the dollar
• FBI documents call him the primary wire authorization contact

If He Blames Indyke

• Their roles were complementary, not hierarchical: Indyke handled legal structure, Kahn handled financial operations
• Both were co-trustees, co-executors, and co-beneficiaries
• The lock-in provision in the 1953 Trust treated them as an integrated unit

15. CROSS-REFERENCES

This briefing draws from evidence documented in:

• HBRK Associates / Emad Hanna Investigation — 35,919 documents, $84.5M managed, 39+ entities
• Shell Entity Map — complete map of 95+ entities under RM Code 82289
• Deutsche Bank KYC Breach — KYC failures enabling suspicious transactions
• Haze Trust AML Investigation — $47.4M trust with compliance gaps
• Leon Black Investigation — $158M+ payments Kahn tracked
• DOJ Document Alteration Forensics — FinCEN SARs gutted in post-release re-processing
• Prosecution Failures Analysis — systematic pattern enabling the enterprise
• Congressional Subpoena Guide — full witness inventory and procedures

Prepared for House Committee on Oversight and Government Reform. All EFTA citations verified against the DOJ production database. Financial figures from source document text layers. External claims sourced with URLs.