EFTA02731018

EFTA02731018 is a five-sheet letter on the printed masthead of the United States Senate Committee on Finance, dated June 22, 2022, addressed to Marc Rowan, Chief Executive Officer of Apollo Global Management, Inc., and signed in blue ink by Senator Ron Wyden of Oregon over his printed name, the line “United States Senator” and the line “Chairman, Committee on Finance”, which the sheet sets across two lines.¹² It seeks information about the $158 million that a report commissioned by Apollo’s own conflicts committee said Leon D. Black paid Jeffrey Epstein between 2012 and 2017, puts thirteen numbered demands for answers and documents to Apollo, and sets a return date of July 9, 2022.¹³² The Committee’s own later account calls this letter the point at which it “initiated an investigation” into the arrangement.⁴ The run is homogeneous: one letter across five sheets, with no wrapper, no enclosure and no cover filing, and the foot of each sheet carries its own stamp, EFTA02731018 on p. 1 rising to EFTA02731022 on p. 5.¹² All five sheets were read at the image at 700 dpi for this page, and no producer redaction appears on any of them.⁵

⚠ What this letter contains is a senator’s assertions about somebody else’s report, not findings of fact. Every factual proposition in it is footnoted on the sheet itself to one of two outside sources: the Dechert LLP memorandum that Apollo published with the Securities and Exchange Commission, and a single Fortune article about chief-executive pay.¹³ The Committee is quoting a report; the report is an account given to a board’s conflicts committee by its own outside counsel. Nothing on these sheets records the Committee testing any of it, and nothing on these sheets is a finding by the Committee.

What the letter says on its face

The first paragraph states the purpose: “I write seeking information regarding a business arrangement between Leon Black and Jeffrey Epstein.”¹ It then sets out the Committee’s reason for treating the sum as anomalous, in three steps, each of them attributed on the sheet. The Dechert report “stated Epstein was paid $158 million by Black between 2012 and 2017 for services related to a variety of tax and estate planning matters, an amount that appears to far exceed that paid by Black to his other professional advisors.”¹ The letter then states the annual rate and the comparison it draws from it: “This compensation scheme, which ranged between $23 million and $26 million for a number of years appears to have far exceeded the median CEO pay for Fortune 500 CEOs, which Fortune calculated at $15.9 million for 2021.” The missing comma after “years” is the sheet’s own.¹ And the letter concludes the comparison: “This amount also appears well in excess of the expected compensation for estate planning services—particularly in a case where Epstein’s work was required to be vetted by other legal and accounting professionals, at times was viewed as not useful, and included instances of substantial misrepresentations of applicable tax laws.”¹

The second sheet supplies the background. “As you are aware, Jeffrey Epstein was arrested and indicted in federal court on July 8, 2019 on sex trafficking charges involving the exploitation and abuse of dozens of underage girls.”³ In the aftermath, the letter says, “Apollo hired law firm Dechert LLP to conduct an investigation into Epstein’s ties to Black, Apollo’s Chairman and Chief Executive Officer at the time,” and Black “for decades maintained longstanding personal and professional ties to Epstein and engaged Mr. Epstein for his advice related to tax strategy, estate planning and philanthropy.”³ The same sheet gives the two largest figures the Committee is chasing, both attributed to the report: a trust Black created in 2006 “in order to transfer assets to his beneficiaries while avoiding roughly $1 billion in gift and estate taxes,” and a step-up-basis transaction “designed to save Black’s children approximately $600 million in taxes”, in a sentence that runs on to name other tax planning and compliance issues, including responses to audit inquiries from the Internal Revenue Service.³

The claim of jurisdiction is made in one sentence, and it is a tax claim rather than a trafficking one: Wyden writes as chairman of a committee “which has oversight jurisdiction of matters pertaining to federal taxation”, the clause continuing on the sheet into the request itself.³ The letter then gives the reason it thinks the arrangement deserves scrutiny, and this is the sentence that joins the two subjects: “Despite not being a certified public accountant or licensed tax attorney, it appears that Epstein was paid an amount that far exceeded what Black paid other professional advisors, including some of the most high-priced legal counsel in the nation.”³ It continues: “In light of Epstein’s role in a sprawling human trafficking scheme, it is important to understand why Epstein’s compensation arrangement was substantially different than that typically afforded to professional advisors involved in trust, estate and tax planning.”³ The demands follow immediately, under a deadline: “Accordingly, please provide answers to the following questions no later than July 9, 2022:“³

The thirteen demands

The demands run from the foot of p. 2 to the top of p. 5. Numbers 1 to 7 begin on pp. 2 and 3, 8 to 12 on p. 4, and 13 with its three lettered sub-items on p. 5.³⁶⁷² Twelve of the thirteen, every one but the first, open with the formula “The report claims that,” quote a phrase from the Dechert report, and then ask Apollo to explain it or to produce the documents behind it. The letter’s demands are therefore, almost without exception, demands about somebody else’s document.

#	What it asks for	Sheet
1	Whether Apollo has retained all documents behind the Dechert memorandum, who now has custody of them, and whether control of them was transferred to Black, to his family office or to anyone acting for him	pp. 2 to 336
2	An explanation of the report’s statement that “Many witnesses believed that Epstein had creative ideas that no other advisor had proposed,” and how Epstein’s tax solutions differed from those of licensed professionals	p. 36
3	How the report reached its valuation of Epstein’s advice at more than $1 billion and as much as $2 billion, with the documents supporting it	p. 36
4	Copies of any signed compensation agreements, and a description of the “unsigned agreements,” including those covering artwork, Black’s airplane and Black’s yacht	p. 36
5	A copy of the “written service agreement” the report says was signed on February 13, 2013, with the payment records under it	p. 36
6	All documents on the $56.5 million paid in five instalments over 2013 and 2014 under an agreement that was never signed, renegotiated to a total of $50 million	p. 36
7	All documents on the $70 million paid in 2014 and the $30 million paid in 2015, after Black began paying on an ad hoc basis without written agreements	pp. 3 to 467
8	How Dechert LLP assessed that the compensation far exceeded what Black paid other advisors, with the comparative documents	p. 47
9	How Black decided the amounts, with documentation of the services rendered	p. 47
10	Whether Black claimed income tax deductions for the payments, why they were determined nondeductible, whether he amended his returns, and whether any payment was characterised as a gift	p. 47
11	The solution Epstein proposed to the 2006 grantor retained annuity trust, “the work done by Epstein for the family office to resolve the matter,” and all documents Dechert obtained on it	p. 47
12	Epstein’s role in the transaction said to have saved $600 million, and the documentation behind that estimate	pp. 4 to 572
13	The “tax planning” advice, itemised against an IRS audit letter for 2013, an audit letter for 2012, and statements of reasonable cause for a failure to file IRS Forms 8865	p. 52

Two of the demands are the reason this letter matters to a page about Black’s family office. The first asks whether Apollo “transferred control of these documents to Leon Black, his family office (Elysium Management, LLC) or any other individuals or entities operating on Mr. Black’s behalf?”³⁶ The eleventh asks for a description of “the work done by Epstein for the family office to resolve the matter.”⁷ Both are set out, with the family office’s own record, on Elysium Management LLC.

Three further features of the demands are worth stating because they narrow what the Committee was after. The letter itself does not say that GRATs are unlawful; it says the opposite in terms, that “While GRATs are a tax avoidance technique that raise serious public policy concerns, they are routinely used by estate tax planners and have been upheld by federal courts and IRS guidance,” and asks only about the particular solution Epstein proposed.⁷ Demand 10 is the only one that reaches Black’s own tax returns, and it asks two distinct questions, whether deductions were claimed and whether any payment was instead a reportable gift.⁷ And demand 13’s third sub-item is the only place the letter alleges a filing failure rather than a valuation dispute: it asks about “Planning and coordinating the submission of statements of reasonable cause for a series of tax years to address an apparent failure to file certain tax forms, including IRS Forms 8865, relating to Black’s interests in BRH Holdings L.P., a partnership through which Black and the other Apollo co-founders hold their ownership interests in Apollo and related foreign partnerships.”² That, too, is the Committee’s characterisation, and the word on the sheet is “apparent”.²

The signature, and what the release does not contain

The letter closes “Thank you for your attention to this important matter,” then “Sincerely,” and then a blue-ink signature reading Ron Wyden, written across and above a rule, with the printed block “Ron Wyden / United States Senator / Chairman, Committee on Finance” beneath it.² The mark on the rule was examined at 700 dpi for this page. That is worth stating plainly, because a printed name, a printed title and a date at the foot of a letter are each compatible with nobody having signed it. Here the mark is there.²

No reply from Apollo to this letter, and no enclosure, attachment or transmittal belonging to it, was found in any document read for this page. That is a statement about the searches described in the footnote and not about the release as a whole.⁸ What can be said is narrower and comes from a later letter of the same committee, described below.

Where the letter sits in the production

EFTA02731018 is in Data Set 12, and its immediate Bates neighbourhood is not a congressional file at all. The document ending immediately before it is the Dechert LLP memorandum of January 22, 2021 that this letter is entirely about, produced in the form Apollo filed it with the Securities and Exchange Commission as Exhibit 99.1.⁹ The document beginning immediately after it is the Senate Finance Committee’s follow-up letter of July 24, 2023.¹⁰ And immediately after that sits a thirty-sheet prosecution memorandum of the United States Attorney’s Office for the Southern District of New York, dated June 11, 2019, whose first sheet is headed as privileged attorney work product and marked not for dissemination outside that office.¹¹

So four documents of four different origins, a law firm’s report to a corporate board, two letters from a Senate committee and a federal prosecutor’s charging memorandum, occupy consecutive Bates runs. What assembled them into that order is not stated on any sheet read for this page. The neighbourhood is a fact about the production; what it means about who held this letter, and why, is a question this page does not answer.

The sequel, and the one thing known about the response

Thirteen months later, on July 24, 2023, the same committee wrote again, this time not to Apollo but to Black himself, care of counsel in Denver.¹⁰ That letter is sixteen sheets, carries the same committee masthead and a blue-ink signature in the same form, and states in its own background section: “As you know, on June 22, 2022, the Committee initiated an investigation into your business arrangement with Epstein.”⁴ It describes the June 2022 letter as “The Committee’s initial letter, a copy of which is attached,” in a sentence that runs on past the foot of the sheet.⁴ The attached copy is not part of that sixteen-sheet run, which ends with the signature page.¹²

Two things in the sequel bear on the letter described here, and both are the Committee’s own characterisations rather than established facts. The first is that answers came and the Committee found them wanting: “Unfortunately, the inadequate responses you have provided the Committee only raise more questions than answers, and fail to address a number of tax issues my staff has uncovered over the course of this investigation.”¹⁰ The second is dated and specific, and it is the only record read for this page of anyone meeting the Committee on this subject: demand 15 of the 2023 letter opens, “In a briefing with the Committee on August 1, 2022, your outside counsel indicated that Epstein provided substantial advice related to your private art collection, which is worth over $1 billion.”¹² A briefing six weeks after the return date is evidence that the recipients engaged; it is not evidence of what was produced, and no production list was read for this page.

The same committee’s work on Epstein continued for years afterward, reaching a staff memorandum of November 19, 2025 and a report of August 4, 2026 on the banks; those are described on Harry I. Beller and are not re-derived here.¹³

⚠ The extraction of this document is badly damaged, and the masthead is destroyed

This is recorded so the next reader is not misled and so a checker’s unresolved rows can be explained. The masthead of p. 1, read at the image, gives Wyden as chairman above two columns naming twenty-seven further senators, with two staff directors beneath. The extracted text layer renders that block as nonsense throughout: the chairman’s line as Kt. Wel3f, I. MOON . °AIRMAN, the first name in the left column as CROW STARENOw. MICHIGAN where the sheet reads “DEBBIE STABENOW, MICHIGAN”, the first name in the right column as PARE C WO. 0A10 where the sheet reads “MIKE CRAPO, IDAHO”, and the seal line “United States Senate” as United *tams *coati.¹⁴ ⚠ One of those corruptions is a plausible English surname and belongs on this desk’s fabrication tally: the staff director’s line extracts as JOSHUA SNOWMAN SEAM DIRECTOR where the sheet reads “JOSHUA SHEINKMAN, STAFF DIRECTOR.”¹⁴ A search of the corpus for that real name returns nothing at all, so the masthead is unreachable by any query built on it.¹⁴

The extraction also reorders the head of the sheet, placing the salutation “Dear Mr. Rowan,” above the seal, the date and the city line rather than below them, which is the two-column hazard that lets a reader working from an extraction stitch together a string no sheet carries.¹⁴ Three superscript footnote markers are rendered as punctuation or letters, so the extraction reads advisors.' and applicable tax laws! and (IRS).s. ⚠ The second of those is why a quotation checker will report that the full stop after “applicable tax laws” is not on the sheet: it is, and was read at the image at 700 dpi; the extraction has eaten it along with the superscript. One of the letter’s own source URLs is mangled in a way that changes a domain.¹⁴ Every masthead name given above, the signature, and every sentence quoted on this page were read at the image and not taken from the extraction.

Timeline

Date	Event	Status	Source
8 Jul 2019	Epstein arrested and indicted in the Southern District of New York, as the letter recites	occurred	3
Oct 2020	Apollo’s conflicts committee retains Dechert LLP, as the neighbouring memorandum recites	occurred	9
22 Jan 2021	The Dechert LLP memorandum to the Apollo Conflicts Committee is dated	occurred	9
22 Jun 2022	Wyden signs and sends this letter to Marc Rowan at Apollo, with thirteen demands	occurred	12
9 Jul 2022	The return date the letter sets	set by the letter	3
1 Aug 2022	Black’s outside counsel briefs the Committee, per the Committee’s later account	occurred, on the Committee’s account	12
24 Jul 2023	The Committee writes again, to Black, calling the responses inadequate	occurred	104

Cited in

Elysium Management LLC.

Footnotes

1. Letter of Senator Ron Wyden, Chairman, Committee on Finance, United States Senate, to Marc Rowan, Chief Executive Officer, Apollo Global Management, Inc., June 22, 2022. EFTA02731018 p. 1 of 5. Read at the image at 700 dpi. The sheet carries the committee masthead, the date, the addressee block, the opening paragraph and footnotes 1 to 3; the foot of the sheet is stamped EFTA02731018. The addressee block gives Apollo’s business address at 9 West 57th Street, 43rd Floor, New York, NY 10019. Footnotes 1 and 3 cite the Apollo Global Management filing Investigation Of Epstein/Black Relationship And Any Relationship Between Epstein and Apollo Global Management on the Securities and Exchange Commission’s EDGAR system, and footnote 2 cites The top 10 highest paid CEOs of the Fortune 500, Fortune, May 28, 2022. The em dash in “estate planning services—particularly” is the sheet’s own. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹

2. The same letter, EFTA02731018 p. 5 of 5, carrying the conclusion of demand 12, demand 13 with sub-items a to c, the closing line, the subscription and the signature. Read at the image at 700 dpi. The foot of the sheet is stamped EFTA02731022. ⚠ A blue-ink signature reading Ron Wyden crosses and overhangs the rule above the printed name block; the printed block is given here as three successive lines and is described rather than quoted as one string, because a stacked block is not reliably contiguous in the rendered text. The signature itself leaves no trace in the extracted text layer, which is why a reader working from the extraction alone cannot tell whether this letter was signed. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹

3. The same letter, EFTA02731018 p. 2 of 5. Read at the image at 700 dpi. The sheet carries the background section, the jurisdiction paragraph, the return date, the opening of demand 1 and footnotes 4 to 9; the foot of the sheet is stamped EFTA02731019. Demand 1 begins here and its final clause continues at the top of p. 3, so a checker searching for that quotation whole will not find it on either sheet alone; the quotation is pinned to both. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³ ↩¹⁴

4. The same 2023 letter, EFTA02731023 p. 2. Read at the image at 700 dpi. The sheet carries the heading “Background” and the account of the June 22, 2022 letter. The sentence beginning “The Committee’s initial letter, a copy of which is attached” continues past the foot of this sheet and is quoted here only to its first clause. ↩ ↩² ↩³ ↩⁴

5. Provenance of the reading. All five sheets of this letter were rasterised locally at 700 dpi from the served PDF and read as images for this page. Every quotation, every name in the masthead, the page count, the sheet stamps and the signature come from those images and not from the extracted text layer. The statement in the opening paragraph that no producer redaction appears is a statement about those five sheets at that resolution, and about nothing else. Three sheets of the 2023 sequel letter were read the same way and are cited separately; nothing is asserted here about its other thirteen sheets. ↩

6. The same letter, EFTA02731018 p. 3 of 5, carrying the conclusion of demand 1 and demands 2 to 7. Read at the image at 700 dpi. The foot of the sheet is stamped EFTA02731020. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹

7. The same letter, EFTA02731018 p. 4 of 5, carrying the conclusion of demand 7 and demands 8 to 12. Read at the image at 700 dpi. The foot of the sheet is stamped EFTA02731021. Demand 8 quotes the Dechert report as “it is clear the compensation paid by Black to Epstein far exceeded any amounts Black paid to his other professional advisors,” where the letter’s own footnote 9 on p. 2 gives the same passage as “It is clear that the compensation paid by Black to Epstein far exceeded any amounts Black paid to his other professional advisors”; both readings are the sheets’ own and neither is emended here. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰

8. Absences, scoped to these searches and to the material read for this page. Three sentences unique to this letter were run as phrases against the corpus full text: I write seeking information regarding a business arrangement, median CEO pay for Fortune 500 CEOs and no later than July 9, 2022, each as an exact phrase. Each returns exactly one document, EFTA02731018, so no second copy of this letter is reachable by those phrases and no comparison between copies arises. The phrase “Chairman, Committee on Finance” returns five documents, of which two are this letter and its 2023 sequel. Nothing returned by those searches and read for this page is a reply from Apollo, a production index, a privilege log, or any enclosure belonging to this letter. This is a statement about the searches named, not about the release. ↩

9. Dechert LLP memorandum to the Apollo Conflicts Committee, January 22, 2021, Investigation Of Epstein/Black Relationship And Any Relationship Between Epstein and Apollo Global Management, Inc., twenty-two sheets, produced in the form Apollo filed it with the Securities and Exchange Commission as Exhibit 99.1. EFTA02730996 p. 1. Text layer only; this sheet was not rendered for this page. Its account of the Epstein and Black relationship is set out with its own citations on Leon D. Black and is not re-derived here. ↩ ↩² ↩³

10. Letter of Senator Ron Wyden, Chairman, Committee on Finance, United States Senate, to Leon D. Black care of counsel, July 24, 2023, sixteen sheets. EFTA02731023 p. 1. Read at the image at 700 dpi. The sheet carries the masthead, the date, the addressee block, the statement of the Committee’s wider inquiries and the paragraph on the responses received. This is a different document from the one this page describes and is not otherwise summarised here. ↩ ↩² ↩³ ↩⁴

11. Prosecution memorandum of the United States Attorney’s Office for the Southern District of New York, United States v. Epstein, June 11, 2019, thirty sheets. EFTA02731039 p. 1. Text layer only; this sheet was not rendered for this page, and nothing is taken from it here beyond its heading, its date and its length. The Southern District prosecution memoranda as a family are described on the SDNY prosecution memoranda. ↩

12. The same 2023 letter, EFTA02731023 p. 16, carrying demand 15, the closing line and a blue-ink signature over the same printed block. Read at the image at 700 dpi. ⚠ The extraction renders that signature as 14Thn, which is a reminder that an ink mark is not readable from a text layer in either direction. ↩ ↩² ↩³

13. The Committee’s later work. The staff memorandum to Senator Wyden of November 19, 2025 and the Committee report Looking the Other Way of August 4, 2026 are set out with their citations on Harry I. Beller. Not re-derived for this page, and neither is cited here for anything about the June 2022 letter. ↩

14. Extraction damage on EFTA02731018 p. 1 and p. 2, recorded from a line-by-line comparison of the served text layer against the 700 dpi images. The masthead corruptions quoted above are the extraction’s own strings. The corpus returns zero documents for a phrase search on the staff director’s real name, so the masthead cannot be reached by querying it. The superscript markers rendered as punctuation are on p. 1 and p. 2. The domain mangled in footnote 3 of p. 1 is one character different from the domain the sheet gives in footnotes 1 and 3 alike; the sheet’s own reading was taken from the image. None of these is visible to any checker this desk owns, and all of them were found only by reading the image beside the extraction. ↩ ↩² ↩³ ↩⁴ ↩⁵