Epstein Data Wiki

Senate Finance Committee letter to Leon Black, July 2023 (EFTA02731023)

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tagsdocument, letter, 2023, senate-finance-committee, ron-wyden, leon-black, apollo-global-management, elysium-management, tax, trusts

61 min read

What it isA sixteen-sheet letter on the printed masthead of the United States Senate Committee on Finance, seeking answers about the $158 million a report commissioned by Apollo’s own board said Leon D. Black paid Jeffrey Epstein, and about two trust transactions Epstein is said to have devised12
DateJuly 24, 2023, centred above the addressee block1
FromSenator Ron Wyden of Oregon, Chairman of the Committee on Finance. A signature in blue ink reading Ron Wyden is written across the rule on p. 16, above a printed block set on four lines3
ToLeon D. Black, care of the Denver office of Brownstein Hyatt Farber Schreck LLP. The salutation reads “Dear Mr. Black,“1
DemandsFifteen numbered questions and document requests, with ten lettered sub-items, running from p. 13 to p. 164563
Return dateSeptember 1, 2023, thirty-nine days after the letter’s own date4
PredecessorThe Committee’s letter of June 22, 2022 to Apollo’s chief executive, EFTA02731018, which this letter says was the point at which the Committee “initiated an investigation” and a copy of which it says is attached2
Bates runSelf-numbered per sheet, EFTA02731023 on p. 1 rising to EFTA02731038 on p. 16. The run is homogeneous: one letter, no wrapper, no enclosure, no cover filing137
RedactionNo producer redaction appears on any of the sixteen sheets. That is a statement about these sixteen sheets at 700 dpi and about nothing else7
Not established hereWhether anyone answered this letter, whether anything was produced under it, and what became of the Committee’s inquiry after September 1, 20238

EFTA02731023 is a sixteen-sheet letter of the United States Senate Committee on Finance, dated July 24, 2023, addressed to Leon D. Black care of counsel in Denver, and signed in blue ink by Senator Ron Wyden of Oregon over a printed block reading “Ron Wyden / United States Senator / Chairman, Committee on / Finance”, which the sheet sets on four lines.13 It is the sequel to the Committee’s letter of June 22, 2022 to Marc Rowan at Apollo Global Management, and unlike that letter it is addressed to Black personally and written throughout in the second person.129 It recites what answers the Committee says it received and what it says it did not, sets out the Committee’s account of a trust transaction Epstein is said to have designed, and puts fifteen numbered demands with a return date of September 1, 2023.10114 All sixteen sheets were read at the image at 700 dpi for this page, and no producer redaction appears on any of them.7

⚠ This is one senator’s letter, not a finding of fact, a charge, or an allegation of wrongdoing by any court or agency. Its propositions come from three places and the difference matters throughout: from the Dechert LLP report Apollo filed with the Securities and Exchange Commission; from two memoranda submitted on Black’s behalf by Paul, Weiss, Rifkind, Wharton & Garrison LLP, which the letter quotes at length in its own footnotes; and from the Committee’s characterisation of both.21211

The formulas matter. Seven of the fifteen demands open “The Dechert report claims”, and three open “The response provided on January 16, 2023 indicated”: in both cases what follows is somebody else’s document being read back.456 Where the letter instead says that a scheme “essentially served as a workaround to federal tax laws”, that is the Committee’s own language about material it says it had not obtained.13

What the letter says on its face

The first paragraph places this inquiry inside a programme rather than treating it as a single case. “As Chairman of the Senate Finance Committee (“the Committee”), I write regarding the Committee’s investigation into your financial dealings with Jeffrey Epstein. This effort is part of an ongoing set of investigations by the Committee into the means by which ultra-high net worth persons avoid or evade paying federal taxes, including gift and estate taxes.”1 Three other inquiries are named in the same breath: tax shelters “such as Private Placement Life Insurance”; “the possible circumvention of laws related to gift taxes and deductions involving the complementary use of private aircraft/superyachts by public officials”; and “the use of Swiss banks by wealthy taxpayers to expatriate from the United States and evade gift taxes while concealing offshore accounts from the Internal Revenue Service (IRS).”1

The subject is then stated twice, in money. “As you are aware, the Committee is investigating the $158 million in payments you made to Epstein for services related to a variety of tax and estate planning matters.”1 And the object of the inquiry is not the payments alone but what they bought: “the Committee seeks information on Epstein’s participation in structuring trusts and other complex transactions designed to avoid federal gift and estate taxes on as much as $2 billion in wealth transferred to your children.”1

The opening closes on the letter’s operative complaint, which is not about the arrangement but about the answers. “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.”1 The jurisdictional claim, when it comes, is a flat assertion rather than an argument: Black’s counsel had objected that some requests were “outside the scope of the Committee’s purview”, and the letter answers that “[t]his claim is without merit, as the Senate Finance Committee has jurisdiction over all matters related to federal tax laws. Investigations into matters pertaining to the operation and enforcement of internal revenue laws are squarely within the Committee’s legislative purview.”10

The trust transaction, and Black’s own account of it

The letter’s longest section concerns the 2006 grantor retained annuity trusts. The Committee’s premise, taken from the Dechert report, was that they had an estate tax “problem” which, left unresolved, would lead to a potential estate tax liability for Black’s children of $1 billion or more, and which Epstein solved with a “proprietary” solution.12 ⚠ Of those three pieces the sheet puts quotation marks around two, “problem” and “proprietary”, and none around the liability clause, which is the Committee’s own prose; this page set all three as quotations until 2026-09-24. The report’s own words for the liability, in the letter’s own footnote 12, are weaker than the body’s: the report has witnesses who “differed on what the value of the estate tax would have been today or in the future if the issues had not been resolved, but they believed the estate tax liability could have been as much as $1 billion or more.” ⚠ And the “proprietary” sentence carries no footnote marker at all. Footnote 12 is attached to the sentence before it, and the only description of Epstein’s solution that it quotes from the report is “a unique solution to a potential estate planning problem” at the report’s page 9. That is where the body’s “problem” comes from; nothing quoted on this sheet is where “proprietary” comes from. Read at the image at 700 dpi.12 Black’s answer, quoted in the letter’s own footnote, rejects the premise entirely, and the letter prints it: “The memorandum respectfully proceeds on the belief that the premise of the question – that there were ‘issues with the 2006 GRAT’ is based on a misunderstanding. There were no issues or problems associated with the 2006 GRATs themselves. The 2006 GRATs functioned as intended, and were in no way out of the ordinary for such instruments, nor were they problematic. Instead, there was a potential tax-related concern with the trust (‘the remainder trust’) into which the assets held in the 2006 GRATs were to be transferred into upon the expiration of the GRATs.”12 The letter accepts the correction in its own body: “In response to the Committee’s investigation, you indicated that there were no issues or problems with the 2006 GRATs themselves. Instead, you clarified that there was a tax-related concern with the remainder trust”.12

The concern, as both sides describe it, is a provision of the Internal Revenue Code. “Under Internal Revenue Code Section 2036(a)(1), if a taxpayer gives away assets to a third party while retaining the right to income from those assets, those assets are included in the taxpayer’s gross estate at the taxpayer’s death.”12 Because the remainder trust’s trustees were distributing income to Black, the assets risked being pulled back into his estate, and a second provision, Section 2035(a), created a three-year tail. On that second point Black’s memorandum makes a case the Committee’s body text does not restate: that the trustees rather than Black would terminate the income interest, “and therefore Section 2035(a) would not be implicated, out of an abundance of caution, and given Mr. Black’s age, all parties wanted to act promptly to resolve this issue (without a potential three-year tail).”12

The sums are given on p. 5. “At the time the 2006 GRATs were funded, the assets in the remainder trust had an appraised value of approximately $585 million.”11 Those assets were interests in Apollo partnerships held before the firm’s initial public offering, “which your advisors believed could reasonably be expected to increase in value over time to an amount exceeding $2 billion.”11 The letter’s own footnote itemises eleven of those interests with an appraised value for each, and the eleven figures sum to $585.4 million, which is the “approximately $585 million” its body gives.1114 On the tax at stake the letter and its source describe the same number from opposite ends: the body says “the estimated tax liability resulting from these assets being included in your estate at time of death could have exceeded $1 billion”, while the footnote quotes Black’s memorandum saying “the estimated tax liability savings as a result of those assets no longer being included in his estate was estimated to exceed $1 billion.”11

⚠ The letter records, in its own sentence and immediately before the one that introduces Epstein’s contribution, that Black took established professional advice on the same problem. “In order to prevent the Apollo assets in the remainder trust from being subject to gift and estate taxes, you consulted with Epstein and retained established trust and estate lawyers from Weil Gotshal and Paul Weiss to devise a solution.”11 That sentence is the Committee’s own, it names two established firms alongside Epstein, and it sits on the sheet this page reads most closely.

What Epstein is said to have contributed, in the sentence that follows that one, is a piece of procedure. “Epstein proposed that the trustees of the trust prepare an accounting to ascertain the amount of income that was distributable to you under the remainder trust agreement compared to the amounts that were in fact distributed to you.”11 The accounting found an over-distribution, and Black’s memorandum characterises it as inadvertent: “That accounting revealed that the trustees had inadvertently over-distributed income to Mr. Black.”11 That over-distribution gave each side a claim against the other, the trustees to claw back the excess and Black for breach of fiduciary duty if removed as a beneficiary, and the solution was to trade them away. “According to your attorneys, it was at this point that Epstein allegedly proposed a solution, which involved a mutual release of claims by and between you and the trustees of the remainder trust.”15 The letter states that Black “confirmed to the Committee that you and the trustees both formally agreed to a mutual release of claims”, and puts the phrase “receiving consideration” in its own quotation marks.15 The consequence, on his advisers’ position, was that “you no longer had the income rights from the remainder trust that would have caused the trust’s assets to be included in your taxable estate”.15

Four things the Committee says it was refused are then set out as square-bullet paragraphs: the amount of the over-distribution and the period it covered; the value and nature of the consideration in the mutual release; the extent of retained voting control over the Apollo shares and partnership interests; and whether Black or any affiliated entity, “including your family office (Elysium Management LLC)”, had borrowed against the remainder trust’s assets.1513 On the second of those the letter states a tax consequence rather than an accusation: “It is possible that, if your release of a right to income from the remainder trust was for less than full and adequate consideration, such release of claims could constitute an additional taxable gift.”15

⚠ One sentence on p. 7 is the Committee’s own characterisation and reads as a finding if lifted out of the letter: “This arrangement raises serious concerns that, in spite of significant violations of the terms of the remainder trust, you were potentially paid millions of dollars in excess income while keeping enormous amounts of wealth outside of your taxable estate.”13

What that sentence calls violations are the over-distributions of income, which the memorandum quoted on the sheet before it describes as inadvertent, and whose size the letter says on the sheet after it that it has been refused.1115

The section closes on the fact that gives the whole letter its weight and that nothing else in the release read for this page touches: “You have confirmed to the Committee that the IRS has not reviewed the 2006 GRATs, the remainder trust or the mutual release of claims scheme as part of an audit, raising yet more concerns about the IRS’s visibility into such transactions and the agency’s compliance efforts.”13

The step-up-basis transaction, and two accounts that do not agree

On the second transaction the letter does something the 2022 letter could not: it sets the Dechert report against Black’s answer and says in terms that the two are “at odds”. The report, as the letter quotes it, had Epstein providing “significant value” to the transaction; the letter’s own word for that attribution is “allegedly”.13 The report also stated, on the letter’s account, that while the idea for the complex transaction did not originate with Epstein, Epstein “played an instrumental role in completing it.”16 ⚠ That sentence carries two clauses. The first is that the idea did not originate with Epstein; the second is that Epstein “played an instrumental role in completing it.” Only the second of the two is a quotation on the sheet. The letter’s body puts quotation marks around “played an instrumental role in completing it.” and around nothing else in that sentence; the clause about where the idea originated is the letter’s own summary, and this page quoted it as the report’s words until 2026-09-24. ⚠ And the report’s actual words, which the letter sets out in its own footnote 28, carry an attribution the body drops: “Outside counsel stated that this transaction did not originate from Epstein but that Epstein had nevertheless played an instrumental role in completing it.” So the report is recording what OUTSIDE COUNSEL said, not making the finding in its own voice, and it says “from Epstein” where the letter’s body says “with Epstein”. Read at the image at 700 dpi.16 ⚠ The two accounts agree on where the idea came from and differ on what Epstein did with it, and this page said until 2026-09-24 that the memorandum said the opposite, which was wrong on the half they agree about. On origination they say the same thing: footnote 28 has outside counsel saying the transaction “did not originate from Epstein”, and the memorandum quoted in footnote 29 says the idea “was in the public domain and originated with his other legal advisors.” What they differ on is whether Epstein’s part in completing it was substantial: the report gives him “an instrumental role in completing it.”, the memorandum gives him nothing but an attempt to take credit for it afterwards. The letter’s own two words for the relation are “minimized” and “at odds”: its body says the responses “minimized Epstein’s involvement in the transaction” and that they “are at odds with the Dechert report’s claim” about the size of that role.16 ⚠ And the memorandum’s own words are in footnote 29, not in the body that renders them. The body renders them “the idea was in the public domain and originated with Black’s other legal advisors. Nevertheless, Epstein tried to take credit for the idea and secure compensation.”; footnote 29 quotes the memorandum itself, at its page 5, as “Finally, the question assumes that Mr. Epstein formulated this proposal. This idea was in the public domain and originated with his other legal advisors. Nevertheless, Mr. Epstein tried to take credit for the idea and secure compensation.” Four departures sit inside one quotation and none of them is bracketed: the body drops the opening sentence, writes “the idea” for the memorandum’s “This idea”, writes “Black’s” for its “his”, and strips the courtesy title from “Mr. Epstein”. The dropped sentence is the one that says what the memorandum was answering: a question that assumed Epstein had formulated the proposal. Both read at the image at 700 dpi, and this page gave the body’s rendering as the memorandum’s own words until 2026-09-24.16 The same memorandum adds that the resulting dispute, “including over Mr. Epstein’s compensation for his advice on this proposal”, “contributed to Mr. Black’s decision to terminate his professional relationship with Mr. Epstein.”16 ⚠ Those are the memorandum’s own words, taken from footnote 30 of the sheet. The letter’s body puts the same point in the second person and without quotation marks: “Your attorneys further added that the dispute over compensation for the step-up-basis transaction contributed to your decision to terminate your professional relationship with Mr. Epstein.” That second-person wording is the Committee addressing Black, not the memorandum, which addresses Wyden; this page attributed it to the memorandum until 2026-09-24.16

The Committee’s response is to name the inconsistency and leave it standing: “The Committee is concerned that these responses are at odds with the Dechert report’s claim that Epstein’s role in the transaction was “significant” or “instrumental.” In fact, your responses did not provide any information clarifying how Epstein contributed any value to the transaction outside of that provided by other legal advisors.”16 The money at issue is $20 million, against a demand of $60 million. “Despite Epstein’s limited and heavily disputed role in the step-up-basis transaction, Epstein demanded payment of $60 million.”16 The footnote gives the arithmetic behind that demand from the Dechert report: $60 million “would have been 10% of a perceived benefit of $600 million that Epstein asserted the basis transaction provided.”16 The Committee says it cannot explain the settlement: “The Committee still does not know how or why you settled on a payment of $20 million instead of the $60 million Epstein demanded for the transaction.”1617

Refusals, and the record of who said what to whom

The section headed “Refusal to provide information regarding Epstein’s compensation scheme” restates the 2022 letter’s core comparison in slightly different words and then becomes a chronology of asking.17 The comparison: the $158 million “averaged approximately $25 million per year, appears to be well in excess of expected compensation for tax and 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 not viewed as useful, and included instances of substantial misrepresentations of tax laws.”17 And: “Despite not being a certified public accountant or licensed tax attorney, Epstein was paid amounts that far exceeded what you paid other professional advisors, including some of the most high-priced legal counsel in the nation.”17

The chronology on p. 10 is the most useful thing on the sheet, because it is the Committee’s own dated account of a two-year exchange for which this letter is, so far as the searches described below reach, the only document in the release. “At every stage of the Committee’s investigation, you have refused to answer these questions or provide any documents related to how Epstein’s compensation was determined or justified. First, you refused to answer the questions regarding Epstein’s compensation included in the Committee’s letter submitted on June 22, 2022. Following a briefing with Committee staff and your outside counsel on August 1, 2022, Committee staff submitted a second set of questions regarding Epstein’s compensation scheme.”18 Those second questions “also inquired about advice Epstein provided in relation to your private art collection, which your outside counsel confirmed in a briefing has a value of more than $1 billion. Again, you refused to provide answers to those questions.”18 And then a meeting, which the sheet does not date: “Subsequently, Committee staff met with your outside counsel at Paul Weiss and Brownstein at the Finance Committee’s offices, where your counsel again reiterated your unwillingness to cooperate with any requests related to Epstein’s compensation scheme”.18

⚠ Note who the refusal is attributed to. The June 22, 2022 letter was addressed to Marc Rowan, Chief Executive Officer of Apollo Global Management, Inc., and not to Black.9 This letter says of that letter’s questions, in the second person, “you refused to answer”. Nothing on any of these sixteen sheets says whether Apollo itself answered, refused, or produced anything; Apollo appears only as the company whose board commissioned the review and filed the report with the Securities and Exchange Commission.218 What the letter does record is that written answers came from Black through Paul Weiss, on January 16 and February 21, 2023, and that the Committee had by then also written to Black directly on January 13, 2023 and e-mailed his counsel on September 20, 2022 and February 6, 2023.101518 The point that follows for Elysium Management LLC, whose page records that no reply from Apollo was in the material reviewed for it, is set out below.

Gift or fee: the question the letter builds toward but never answers

The fifth and last of the letter’s headings frames the whole inquiry as a characterisation problem: “Arrangement with Epstein raises concerns of whether such amounts represented services income or a gift”.18 The reasoning under it is cumulative rather than accusatory, and it is worth giving in the letter’s own order, because four ordinary facts are stacked to raise one question. “The lack of transparency surrounding payments to Epstein, the extraordinary amount of such payments, the apparent lack of a formal services agreement, and the fact that you apparently did not claim such compensation as a tax-deductible expense raises questions about whether such payments would be properly characterized as a taxable gift, or as payment for services rendered.”18

The letter then lays out the two legal tests it says the answer turns on, taking both from the Internal Revenue Service rather than from any document of Black’s. On compensation: “IRS audit guidance indicates that questions around reasonable compensation typically arise in family businesses and closely-held business arrangements, in which the firm pays compensation in amounts determined to exceed what would reasonably be charged for those services,” and the factors it lists are “possible conflicts of interest and relationships to the company, an individual’s role at the company, internal consistency in the company’s compensation to other individuals, and external comparisons of compensation with that of similar companies for similar services, among others.”19 On gifts, the letter reports that the Service defines a gift, the word in quotation marks on the sheet, as “any transfer to an individual, either directly or indirectly, where full consideration (measured in money or moneys worth) is not received in return”, and that “IRS regulations further provide that transfers made in the ordinary course of business are not considered gifts, provided the transaction is” one the sheet then quotes as “bona fide, at arm’s length, and free from any donative intent.”19 The absence of an apostrophe in “moneys worth” is the sheet’s own.19

The two tests are then joined to the deduction rules, which is where the stack closes: business payments are deductible under Section 162 and certain family-office expenses under Sections 162 or 212, but “the Internal Revenue Code specifically denies deductions for amounts not representing reasonable compensation”, and it “also denies deductions of any amount treated as a gift.”19 A footnote supplies the thresholds: “For 2013 to 2017 the annual gift tax exclusion was $14,000 and the lifetime exclusion amount was approximately $5 million.”20 Against those figures the letter sets the one that matters: “During that same period, you paid Epstein $158 million.”20

⚠ The letter does not say the payments were a gift, and it does not say they were not. What it says is that the Dechert report leaves the point unexplained: the report “does not provide any details on when that determination was made, why you determined those payments were not tax-deductible, or how such payments were characterized for tax purposes”, and that the Committee asked for the documents that would show it and did not get them.20 The section closes on the chairman speaking in his own voice about a class rather than a person, which is the note the letter began on: “As Chairman of the Senate Finance Committee I have long been concerned that ultra-high net worth individuals frequently employ sophisticated tax avoidance schemes to circumvent federal gift and estate tax laws,” and “I am also concerned that the decimation of IRS enforcement resources over the last decade has led to a decline in compliance with federal gift tax filing requirements.”20

The fifteen demands

The demands run from p. 13 to p. 16. Three of the first six quote back “the response provided on January 16, 2023” and ask for what that response left out; demands 7 to 12 and 14 open with “The Dechert report claims” and ask Black to explain or document a passage of it; demands 13 and 15 open with “In a briefing with the Committee on August 1, 2022” and ask him to put in writing what his counsel said orally.

#What it asks forSheet
1The total distributed to Black from the remainder trust, the amount the trust agreement intended, the period, and how the over-distribution was calculatedp. 134
2The value and nature of the consideration in the mutual release of claimsp. 134
3Whether any of the eleven Apollo interests that funded the 2006 GRATs are still held by the remainder trust, with (a) an up-to-date accounting of ownership percentage and value and (b) the most recent appraisal of eachp. 134
4Whether Black or any affiliated entity, “including Elysium Management LLC”, has borrowed against the remainder trust’s assets, with loan values, terms, security, repayments, and who held or exercised powers over the loansp. 145
5How many Apollo Global Management, Inc. shares the remainder trust holds, with number, value and classp. 145
6Whether Black retained voting powers over the trust assets, the percentage for each fund, the percentage over Apollo itself calculated under IRC 2036(b)(2), and whether he was a general partner or a member of any of the management companiesp. 145
7Copies of any compensation agreements he signed with Epstein, and a description of the “unsigned agreements” covering trust and estate planning, tax, artwork, his airplane and his yachtp. 145
8A copy of the “written service agreement” the report says was signed on February 13, 2013, with the payment records and statements of work under itp. 145
9All documents on the $56.5 million paid in five instalments over 2013 and 2014 under an agreement that was never signed and was renegotiated to $50 millionp. 145
10All documents on the $70 million paid in 2014 and the $30 million paid in 2015pp. 14 to 1556
11How Dechert LLP assessed that the compensation far exceeded what Black paid other advisers, with the comparative documentsp. 156
12A detailed description of how the ad hoc compensation amounts were decidedp. 156
13What Epstein initially asked for in 2014, 2015 and 2017, how each amount was negotiated, and why such sums were paid with no written agreementp. 156
14Whether deductions were claimed and when and why they were determined nondeductible (a); whether returns were amended (b); all substantiation documents (c); and whether any payment was characterised as a gift, with the tax returns (d)p. 156
15On the art collection: the purpose of the new art partnership and Epstein’s part in forming it (a); art loans involving Epstein (b); like-kind exchanges he helped execute on pieces over $1 million, with the tax benefits (c); and art sales over $1 million he assisted with (d)p. 163

Three features of the set are worth stating because they mark how far the inquiry had moved in thirteen months. Demand 13 is the only place in either letter that puts a 2017 payment to Epstein in issue, and it gives no figure for it.6 Demand 15 rests on a single oral statement by Black’s counsel, reported on the sheet as a briefing with the Committee on August 1, 2022 at which counsel indicated that Epstein had advised on a private art collection “worth over $1 billion”, and the letter gives its last demand and four sub-items to it.3

⚠ What is new against the 2022 letter is narrower than a flat statement that the 2022 letter did not mention art, which is what this page said until 2026-09-24 and which is false at the image. The 2022 letter names artwork once, in its own demand 4 on its p. 3, as one of the matters Epstein was said to have been compensated for under unsigned agreements: “issues relating to artwork, Black’s airplane, Black’s yacht, and other similar matters”. What it does not do is ask about the collection itself, about its value, or about an art partnership, art loans, like-kind exchanges or art sales, which is what this letter’s demand 15 asks for. That negative is a statement about two things and about nothing else: its p. 3 read at the image at 700 dpi, and a search of the extracted text of all five of its sheets for the words artwork, collection, painting, yacht, airplane, appraisal and valuation. Four of the seven return a hit and all four hits are on p. 3. Artwork, yacht and airplane are the three nouns of the demand 4 clause quoted above; valuation falls in demand 3, where the Committee asks how the report reached its figure for the value of Epstein’s advice, and has nothing to do with art. Collection, painting and appraisal return nothing on any of the five sheets. This page gave the result of this search for artwork alone until 2026-09-24, and a negative is worth only the boundary of the search that produced it.9

And demand 4 asks the family office a question the 2022 letter had only asked about custody of documents: whether Elysium Management LLC had borrowed against assets that the same letter says were moved out of Black’s taxable estate.59

The signature

The letter closes “Thank you for your attention to this important matter.”, then “Sincerely,”, and then a signature in blue ink reading Ron Wyden, written across the rule, with the descender of the y crossing the rule and falling below it. Beneath the rule the printed block is set on four lines: “Ron Wyden”, “United States Senator”, “Chairman, Committee on”, “Finance”.3 The mark was examined at 700 dpi for this page, which matters because a printed name, a printed title and a date are each compatible with nobody having signed. Here the mark is there, and it is ink: on a stated box and threshold, every dark pixel of the mark above its rule measures blue-dominant, against the rule itself and the printed text of the same sheet, which measure neutral.37

Where the letter sits in the production

EFTA02731023 is in Data Set 12, and it is the third of three consecutive documents about Black and Apollo, immediately followed by five consecutive prosecution memoranda of the United States Attorney’s Office for the Southern District of New York. The eight runs are numbered end to end with no gap at any boundary.21

IdentifierSheetsWhat p. 1 is
EFTA0273099622Dechert LLP memorandum to the Apollo Conflicts Committee, January 22, 2021, in the form Apollo filed it with the Securities and Exchange Commission as Exhibit 99.121
EFTA027310185Wyden to Marc Rowan at Apollo, June 22, 2022: the initial letter9
EFTA0273102316This letter: Wyden to Black, July 24, 20231
EFTA0273103930Southern District prosecution memorandum, June 11, 201922
EFTA0273106913Southern District memorandum, December 5, 2019, carrying a grand-jury-secrecy header22
EFTA0273108286Southern District memorandum, December 19, 2019, carrying the same header22
EFTA0273116832Southern District prosecution memorandum, April 10, 2020: EFTA0273116822
EFTA0273120026Southern District prosecution memorandum, April 14, 202022

The block is two chronological sequences laid end to end, and the second is earlier than the first: 2021, 2022, 2023, then 2019, 2019, 2019, 2020, 2020. What assembled them in that order is not stated on any sheet read for this page, and the adjacency is recorded here as a fact about the production rather than as evidence about who held this letter or why. The five Southern District runs were not opened for this page; they are described, with their own image-verified citations, on the SDNY prosecution memoranda, and nothing is taken from them here beyond their dates, their lengths and their own first-sheet headings.22

What this letter answers about the 2022 letter, and what it does not

Elysium Management LLC records that no reply from Apollo to the June 2022 letter was in the material reviewed for that page, and EFTA02731018 records the same absence, each scoped to its own searches. Both statements stand, and this letter answers the question standing next to them. On the Committee’s own account: written answers to the investigation did come, from Black through Paul Weiss, dated January 16 and February 21, 2023; the specific questions about Epstein’s compensation in the June 22, 2022 letter were not answered; a briefing took place on August 1, 2022, three weeks after that letter’s July 9 return date; and a further meeting took place at the Committee’s own offices, which the sheet does not date.1018 What no sheet of this letter says is whether Apollo, the addressee of the June 2022 letter, ever answered it. The Committee attributes the non-answer to Black in the second person and does not mention Apollo in that sentence at all.18

What was searched, and not found

Every item of correspondence this letter cites other than the June 2022 letter appears in this release, so far as the phrase searches described in the footnote reach, only as a citation inside this letter: the Committee’s letter to Black of January 13, 2023, the Paul Weiss memoranda of January 16 and February 21, 2023, and the majority staff e-mails of September 20, 2022 and February 6, 2023.8 No copy of the attachment the letter says accompanied it was found either, and the sixteen-sheet run ends with the signature page, so no copy of the 2022 letter is inside this run; EFTA02731018 sits before it in Bates order, which is the wrong direction for an attachment produced with it.38 Nothing read for this page records a response to this letter, a production under it, or any Committee action after the September 1, 2023 return date.8 Those are statements about the searches named in the footnote and about the documents read for this page, not about the release.

⚠ The extraction of this document fabricates fluent English, including a date and a currency figure

This is recorded so that the next reader is not misled and so that a checker’s rows can be explained. Every quotation, figure, name and date on this page was read on the image at 700 dpi, not taken from the extracted text layer, and a line-by-line comparison of the two found the following.23

The extraction printsThe sheet readsWhere
do Brownstein Hyatt Farber Schreck LLP”c/o Brownstein Hyatt Farber Schreck LLP”p. 1, addressee23
January 1r, 2023 and February 6ih, 2023”January 13th, 2023 and February 6th, 2023”, the ordinals set as superscriptsp. 323
which you responded to on January 16'"”which you responded to on January 16th”p. 323
saved 5600 million in value”saved $600 million in value”p. 2, footnote 623
that them were 'issues with the 2006 GRAT' and Them were no issues”that there were ‘issues with the 2006 GRAT’” and “There were no issues”p. 4, footnote 1323
any donative intent? followed by two closing quotation marksthe words “any donative intent” followed by a full stop, a closing quotation mark and then a superscript 41p. 1123
questions no later than September I, 2023”questions no later than September 1, 2023”p. 1323
Securities and Exchange Commission!the words “Securities and Exchange Commission” followed by a full stop and then a superscript 3p. 223
misrepresentations of tax laws!the words “misrepresentations of tax laws” followed by a full stop and then a superscript 34p. 923

⚠ Two of those matter beyond tidiness. January 1r destroys the date of a Committee letter to Black that exists nowhere else in this release, and a reader working from the extraction would have no date for it at all; the correct reading is corroborated by the letter’s own footnote 9, which gives “Jan. 13, 2023”.1023 And September I makes the return date unsearchable: a phrase search for “no later than September 1, 2023” returns nothing, while the control phrase “no later than September” returns forty-nine documents, so the query fires and the date is genuinely unreachable.8

The masthead is destroyed in the same way the 2022 letter’s is. The chairman’s line extracts as RON WAVY OREGON. (MAIRMAN where the sheet reads “RON WYDEN, OREGON, CHAIRMAN”; the staff directors extract as JOSHUA SENNEMAN. STAFF ORION:RI and GREGG PICNAPO. REPLItuCAN STAIR Oat MA where the sheet reads “JOSHUA SHEINKMAN, STAFF DIRECTOR” and “GREGG RICHARD, REPUBLICAN STAFF DIRECTOR”; and the seal line extracts as lamed *tatcs *mate for “United States Senate”.23 A phrase search of the corpus for either staff director’s real name returns no documents at all, so the masthead cannot be reached by querying it.8

⚠ Separately, and not an extraction artefact, the letter carries several errors of its own, all read at the image. The addressee block gives Brownstein’s street as “410 Seventeeth Street”.1 Footnote 1 dates the predecessor letter “Jun. 2, 2022” while the body of the same sheet gives that date as June 22, 2022, in the sentence in which the Committee says it initiated its investigation, and the predecessor letter is itself dated June 22, 2022.29 Demand 3 asks the recipient to “answer the follow questions”, and demand 13 to “provide copies any relevant documents”.46 Page 11 writes “moneys worth” without an apostrophe and “a taxpayers’ lifetime unified exclusion” with one in the wrong place.19

⚠ And the letter gives two different periods for the figure the whole inquiry turns on. Its p. 2 body has Black paying Epstein $158 million “between 2012 and 2017”; its p. 2 footnote 4 quotes the Dechert report for payments “over the period 2012 through 2017 totaled $158 million”; and its p. 9 repeats “between 2012 and 2017”.217 Its p. 12, which is where the total is set against the gift tax thresholds, instead says the report has Black under the deductibility misconception “from 2013 through 2017” and then that “During that same period, you paid Epstein $158 million”, and demand 14 on p. 15 repeats the 2013 start for the misconception.206 Three places give 2012 and one gives 2013, for the same total and the same source; the letter does not reconcile them, and this page does not pick one. The discrepancy is of the same kind as the “Jun. 2, 2022” footnote above: an error in the letter, not in its extraction.

Timeline

Every date below is taken from this letter’s own recital unless the source column says otherwise. The letter is evidence that the Committee asserted these things in July 2023; for the items marked “on the Committee’s account” it is not evidence that they occurred.

DateEventStatusSource
2006The 2006 grantor retained annuity trusts are funded; the remainder trust’s assets are appraised at about $585 millionoccurred, on the letter’s recital of Black’s own memorandum11
13 Feb 2013The “written service agreement” the Dechert report says Black and Epstein signedoccurred, on the report’s account as quoted5
2013 to 2014$56.5 million paid in five instalments under an agreement never signed, renegotiated to $50 millionoccurred, on the report’s account as quoted56
2014 and 2015$70 million and $30 million paid on an ad hoc basis, of which Black attributed $20 million to the step-up-basis transactionoccurred, on the report’s account as quoted1856
2013 to 2017The period over which the report says Black believed the payments were tax-deductible. ⚠ The letter’s p. 12 puts the $158 million in this period; its p. 2 and its p. 9 put the same total in 2012 to 2017. The discrepancy is the letter’s own and is not resolved hereoccurred, on the report’s account as quoted21720
8 Jul 2019Epstein indicted in federal court, as the letter recitesoccurred2
22 Jan 2021The Dechert LLP memorandum is datedoccurred21
22 Jun 2022The Committee writes to Marc Rowan at Apollo, the letter this one says began its investigationoccurred29
9 Jul 2022The 2022 letter’s return dateset by that letter9
1 Aug 2022Committee staff are briefed by Black’s outside counseloccurred, on the Committee’s account1863
20 Sep 2022Majority staff e-mail counsel a second set of compensation questionsoccurred, on the Committee’s account18
13 Jan 2023Wyden writes to Black directly. No copy found in any document read for this pageoccurred, on the Committee’s account108
16 Jan 2023Paul Weiss submits a memorandum on Black’s behalf. No copy found in any document read for this pageoccurred, on the Committee’s account10128
6 Feb 2023Majority staff e-mail counsel follow-up questions on the trust transactionoccurred, on the Committee’s account1015
21 Feb 2023Paul Weiss submits a second memorandum. No copy found in any document read for this pageoccurred, on the Committee’s account10118
undatedCommittee staff meet Paul Weiss and Brownstein at the Committee’s officesoccurred, on the Committee’s account; the sheet gives no date18
24 Jul 2023Wyden signs and sends this letter, with fifteen demandsoccurred13
1 Sep 2023The return date this letter setsset by the letter4

Cited in

EFTA02731018 (pp. 1, 2 and 16); Southern Trust Company, Inc. (pp. 1 to 2).

Footnotes

  1. Letter of Senator Ron Wyden, Chairman, Committee on Finance, United States Senate, to Leon D. Black, July 24, 2023. EFTA02731023 p. 1 of 16. Read at the image at 700 dpi. The sheet carries the committee masthead, the date “July 24, 2023”, the addressee block, the salutation “Dear Mr. Black,” and the first three paragraphs; the foot of the sheet is stamped EFTA02731023. The addressee block is five lines: “Leon D. Black”, “c/o Brownstein Hyatt Farber Schreck LLP”, “410 Seventeeth Street”, “Suite 2200”, “Denver, Colorado 80202-4432”. The street line’s spelling is the sheet’s own, verified at 700 dpi under a further twofold enlargement. The masthead gives “RON WYDEN, OREGON, CHAIRMAN” above two columns of thirteen senators each, with “JOSHUA SHEINKMAN, STAFF DIRECTOR” and “GREGG RICHARD, REPUBLICAN STAFF DIRECTOR” beneath, and the seal line “United States Senate” over “COMMITTEE ON FINANCE” and “WASHINGTON, DC 20510-6200”. The double space in “COMMITTEE ON FINANCE” is the sheet’s own. The masthead is described rather than quoted as one string, because a two-column block is not reliably contiguous in the rendered text and this desk has fabricated a quotation by stitching one. No producer redaction appears on this sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14

  2. The same letter, EFTA02731023 p. 2 of 16. Read at the image at 700 dpi. The sheet carries the bold centred heading “Background”, the account of the June 22, 2022 letter and the Dechert report, and footnotes 1 to 6; the foot of the sheet is stamped EFTA02731024. ⚠ Footnote 1 reads “Letter from Senator Ron Wyden, Chairman, Senate Finance Committee to Apollo Global Management, Jun. 2, 2022.” with a single digit, the line breaking after the comma so that “2022.” begins the next line. Read at 700 dpi and again under a twofold enlargement of that line’s right-hand end. The body of the same sheet reads “As you know, on June 22, 2022, the Committee initiated an investigation into your business arrangement with Epstein.” The sentence “The Committee’s initial letter, a copy of which is attached, asked detailed questions on the nature of Epstein’s tax and estate planning services as well as details regarding payments to” runs on past the foot of this sheet and is quoted here only as far as its first clause. No producer redaction appears on this sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  3. The same letter, EFTA02731023 p. 16 of 16. Read at the image at 700 dpi. The sheet carries demand 15 with sub-items (a) to (d), the closing line “Thank you for your attention to this important matter.”, the subscription “Sincerely,” and the signature; the foot of the sheet is stamped EFTA02731038, and this is the last sheet of the run. ⚠ A signature in blue ink reading Ron Wyden is written across the rule, the descender of the y crossing it and falling below it; the printed block beneath is set on four lines, “Ron Wyden”, “United States Senator”, “Chairman, Committee on”, “Finance”, and is described here as four successive lines rather than quoted as one string, because a stacked block is not reliably contiguous in the rendered text. The ink was measured on the 700 dpi render of this sheet, 5950 by 7875 pixels, and the box and the thresholds are given so that the measurement can be repeated rather than taken: inside the box x 297 to 4462, y 4148 to 4360, which is the mark above its rule, 42,798 pixels fall below a mean-RGB luminance of 160 and every one of them is blue-dominant, where blue-dominant means the blue channel exceeds the greater of red and green by at least 40; the mean colour of those pixels is R 38, G 38, B 248. The same measurement on the rule alone, y 4360 to 4375, gives 21,154 dark pixels of which 408 are blue-dominant; on the printed closing line, x 297 to 5652, y 3339 to 3448, it gives 54,584 dark pixels of which none is blue-dominant, mean R 69, G 69, B 69. The rule is printed and the mark above it is not. This note previously gave a mean triple of R 73, G 73, B 185 with no box and no threshold, which cannot be reproduced. The signature itself leaves no usable trace in the extracted text layer, which renders it 14Thn, so a reader working from the extraction alone cannot tell whether this letter was signed. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11

  4. The same letter, EFTA02731023 p. 13 of 16. Read at the image at 700 dpi. The sheet carries the return date and demands 1, 2 and 3 complete, including both sub-item 3(a) and sub-item 3(b), and then white space to the foot; the foot of the sheet is stamped EFTA02731035. The return-date sentence ends in a COLON, not a full stop: “In order to better understand your business arrangement with Epstein, please provide answers to the following questions no later than September 1, 2023:” ⚠ Demand 3 reads “Please answer the follow questions related to the interests that funded the 2006 GRATs:” and sub-items 3(a) and 3(b) each read “Apollo Management IV, LP Apollo Management V, LP;” with no semicolon between them. Both are the sheet’s own and are not emended here. There are no footnotes on this sheet or on any later sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  5. The same letter, EFTA02731023 p. 14 of 16. Read at the image at 700 dpi. The sheet opens at demand 4, and carries demands 4 to 10; the foot of the sheet is stamped EFTA02731036. Demand 4 names “Elysium Management LLC” without a comma before “LLC”, where p. 7 writes “Elysium Management LLC” the same way and the 2022 letter wrote “Elysium Management, LLC” with one. Demand 10 runs on past the foot of this sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13

  6. The same letter, EFTA02731023 p. 15 of 16. Read at the image at 700 dpi. The sheet carries the conclusion of demand 10 and demands 11 to 14 with sub-items 14(a) to 14(d); the foot of the sheet is stamped EFTA02731037. ⚠ Demand 13 reads “Please also provide copies any relevant documents related to decisions regarding how much Epstein was paid for his services.” The missing “of” is the sheet’s own. Demand 13 is the only place in this letter that names 2017 as a year in which a large payment was made, and it gives no figure. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13

  7. Provenance of the reading. All sixteen sheets of this letter were fetched once from the served PDF and rasterised locally at 700 dpi, and every one was opened and read as an image for this page, in forty-eight overlapping bands plus targeted enlargements of the addressee block, the footnote 1 date, the January 13 date and the signature. Every quotation, every figure, every name in the masthead, the page count, the per-sheet Bates stamps and the signature come from those images and not from the extracted text layer. The statement that no producer redaction appears is a statement about those sixteen sheets at that resolution and about nothing else, and it was tested two ways: by reading every band, and by a mechanical census in which each sheet was tiled into blocks of 100 by 40 pixels and the most-filled block on any sheet measured 0.503, with no block on any sheet above 0.80. The only long horizontal dark runs on any sheet are the footnote separator rules and the signature rule, each one or two pixels tall. The sheet count was established three independent ways: the served PDF reports sixteen pages, the corpus holds sixteen page rows for this identifier, and the sheets number themselves EFTA02731023 to EFTA02731038 at the image. ↩ ↩2 ↩3 ↩4

  8. Absences, scoped to these searches and to the documents read for this page, run on 2026-09-24. Queries were run against the corpus full text as FTS5 phrase matches, and the strings are given exactly as sent. "I write regarding the Committee's investigation into your financial dealings", "the inadequate responses you have provided the Committee", "initiated an investigation into your business arrangement", "Seventeeth Street" and "Reasonable Compensation Job Aid" each return exactly one document, this letter, so no second copy of it is reachable by those phrases and no comparison between copies arises. "please provide answers to the following questions no later than" returns exactly two documents, this letter and its 2022 predecessor, and nothing else. "step-up-basis transaction" returns three, this letter, its predecessor and the Dechert memorandum. "Memorandum submitted on behalf of Leon Black", "Senate Finance Committee to Leon D. Black" and "outside counsel to Leon Black" each return only this letter, so the January 13, 2023 letter, the two Paul Weiss memoranda and the two majority staff e-mails this letter cites are reachable in this release, by those phrases, only as citations inside it. "JOSHUA SHEINKMAN" and "GREGG RICHARD" each return no documents at all, which is why the masthead cannot be reached by query. "no later than September 1, 2023" returns no documents because the extraction renders the sheet’s “1” as a capital “I”; the control phrase "no later than September" returns forty-nine documents, so the query is capable of firing. "Brownstein Hyatt Farber Schreck" returns two documents, this letter and a 2,265-sheet mixed production of Case No. 08-80736-CV-MARRA papers whose two matching sheets carry a docket attorney list naming a different lawyer at that firm’s Las Vegas office, assigned in 2004; that run was not read further. Nothing returned by these searches and read for this page is a response to this letter, a production under it, a privilege log, a production index, or the attachment the letter says accompanied it. This is a statement about the searches named, not about the release. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  9. The predecessor. Letter of Senator Ron Wyden to Marc Rowan, Chief Executive Officer, Apollo Global Management, Inc., June 22, 2022, five sheets, thirteen numbered demands, return date July 9, 2022. EFTA02731018 pp. 1 and 3. Its p. 1 and its p. 3 were both read at the image at 700 dpi for this page, independently of the page that describes it. Its p. 1 reads “June 22, 2022” centred above an addressee block giving Rowan, his title, the company and its business address. Its p. 3 carries the conclusion of its demand 1 and its demands 2, 3, 4 and the opening of 6, and its demand 4 is the only place in that letter where artwork is named. Its masthead, read at the same resolution, names Wyden as chairman above thirteen Democratic and fourteen Republican senators, where this letter’s names thirteen and thirteen: Richard Burr, Rob Portman, Patrick J. Toomey and Ben Sasse appear on the 2022 sheet and not on the 2023 one, and Ron Johnson, Thom Tillis and Marsha Blackburn on the 2023 sheet and not the 2022 one. The staff directors are the same on both. The 2022 letter is set out in full on its own page and is not otherwise re-derived here. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  10. The same letter, EFTA02731023 p. 3 of 16. Read at the image at 700 dpi. The sheet carries the Fortune 500 comparison, the account of the meetings with Paul Weiss and Brownstein, the dates of the January and February 2023 exchanges, the jurisdiction paragraph, and footnotes 7 to 11; the foot of the sheet is stamped EFTA02731025. The body reads “The Committee subsequently directed follow up requests for information to you on January 13th, 2023 and February 6th, 2023, which you responded to on January 16th and February 21, 2023, respectively.” with the ordinals set as superscripts. Footnote 9 reads “Letter from Senator Ron Wyden, Chairman, Senate Finance Committee to Leon D. Black, Jan. 13, 2023; Email from Majority Staff, Senate Finance Committee to outside Counsel to Leon Black at Paul, Weiss, Rifkind Wharton & Garrison LLP, Feb. 6, 2023.” and footnote 10 names the memorandum of “Feb. 21, 2023”. ⚠ The sentence “Payments to Epstein, at an annualized rate of $23 to $26 million per year, was higher than the median CEO pay for Fortune 500 companies” carries the sheet’s own subject-verb disagreement and is not emended here. No producer redaction appears on this sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  11. The same letter, EFTA02731023 p. 5 of 16. Read at the image at 700 dpi. The sheet carries the $585 million appraisal, the $2 billion projection, the letter’s own statement that Black consulted with Epstein and retained established trust and estate lawyers from Weil Gotshal and Paul Weiss to devise a solution, the accounting Epstein is said to have proposed, the over-distribution, and footnotes 16 to 23; the foot of the sheet is stamped EFTA02731027. Footnote 16 quotes the January 16, 2023 memorandum at its page 4 and itemises the eleven interests that funded the 2006 GRATs with an appraised value for each; footnote 17 quotes the February 21, 2023 memorandum at its page 5 for the $2 billion projection, and footnote 18 the same memorandum at the same page for the tax figure, in the form “the estimated tax liability savings as a result of those assets no longer being included in his estate was estimated to exceed $1 billion.” The double space in “Apollo Alternative Assets, LP” is the sheet’s own. No producer redaction appears on this sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12

  12. The same letter, EFTA02731023 p. 4 of 16. Read at the image at 700 dpi. The sheet carries the bold centred heading “Overpayments of income and other issues arising from trust tax avoidance scheme”, the account of the 2006 GRATs and the remainder trust, and footnotes 12 to 15; the foot of the sheet is stamped EFTA02731026. Footnote 13 quotes the Paul Weiss memorandum of January 16, 2023 at its pages 1 and 2, and footnotes 14 and 15 quote its page 2. The passage beginning “The memorandum respectfully proceeds on the belief” is quoted here from the opening of footnote 13’s quotation to its closing parenthesis. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  13. The same letter, EFTA02731023 p. 7 of 16. Read at the image at 700 dpi. The sheet carries the conclusion of the third square-bullet paragraph, the fourth (“Lastly”, which names Elysium Management LLC), the “workaround to federal tax laws” paragraph, the retained-voting-rights paragraph, the statement about the IRS, and the bold centred heading “Epstein’s role in the step-up-basis transaction lacks substantiation”; the foot of the sheet is stamped EFTA02731029. There are no footnotes on this sheet. The double space in “the possibility that wealthy individuals” is the sheet’s own. ↩ ↩2 ↩3 ↩4 ↩5

  14. The arithmetic, and what it is and is not. Footnote 16 on p. 5 itemises eleven interests with an appraised value as of funding for each, read at the image. The eleven are interests in Apollo Management III, IV, V and VI, LP; Apollo Investment Management, LP; Apollo Value Management, LP; Apollo SVF Management, LP; Apollo Asia Management, LP; Apollo Europe Management, LP; Apollo Alternative Assets, LP; and points in Apollo Advisors VI, LP and Apollo Advisors VI (EH). The letter’s own demand 3 on p. 13 lists the same eleven interests in the same order, with an ownership percentage for each and with no values, and that sheet was read at the image at 700 dpi for this note. The eleven appraised values, taken together, are consistent with the “approximately $585 million” the body of the same sheet gives. ⚠ What this page states and what it does not, given exactly, because the earlier form of this note denied what the body says. The body above does state a total computed from the eleven, in the rounded scale-word form $585.4 million, and that figure stays: it is the rounding of the same sheet’s own “approximately $585 million”, and it was measured before it was written. What is not reproduced anywhere on this page, and what a later pass is not to supply from this or any other source, is the itemisation of the eleven values and any total sharper than that rounded one. The itemisation is on the face of the letter linked below, at footnote 16 of its p. 5, where any reader who needs it can read it. ⚠ That withholding was verified by enumerating every numeric token on this page, not by testing for the shape of the figure that should be absent. The page carries nineteen distinct currency tokens; eighteen of them are figures the letter itself states in its body or inside a quoted footnote, and the nineteenth is the rounded total named above. The only comma-grouped numbers on the page are the gift-tax exclusion, the sheet count of the Marra production and the three signature pixel counts. A checker that tests for a bare run of digits cannot see a total written in words, so a clean run of such checkers is not evidence that anything was withheld. The enumeration is the evidence, and it is set out here so that a later pass can repeat it rather than trust it. ⚠ This is a check of a sum against a total the document itself states, not a reconstruction of a damaged table; it establishes that the itemisation as printed is internally consistent with the body’s figure, and nothing more. It does not establish what the remainder trust held at any later date, which is what demands 3(a) and 3(b) ask. EFTA02731023 pp. 5 and 13. ↩

  15. The same letter, EFTA02731023 p. 6 of 16. Read at the image at 700 dpi. The sheet carries the mutual release of claims, the February 6, 2023 follow-up questions, the first two square-bullet paragraphs (“First” and “Second”), and footnotes 24 to 26; the foot of the sheet is stamped EFTA02731028. The sheet encloses the phrase “receiving consideration” in its own quotation marks inside the sentence beginning “You confirmed to the Committee”; the body of this page describes that rather than nesting one quotation inside another, because a doubled quotation mark makes a spurious span for a quotation checker. Footnote 25 gives the underlying wording from the January 16, 2023 memorandum at its page 3 as “Both sides thus agreed to a formal release of these potential claims, with each side receiving consideration.” ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  16. The same letter, EFTA02731023 p. 8 of 16. Read at the image at 700 dpi. The sheet carries the conflict between the Dechert report and Black’s responses on the step-up-basis transaction, the $60 million demand, and footnotes 27 to 32; the foot of the sheet is stamped EFTA02731030. Footnote 29 quotes the January 16, 2023 memorandum at its page 5 and footnote 30 the same memorandum at the same page. The Dechert report is quoted in four footnotes on this sheet, each read at the image: footnote 27 at its pages 10 and 11, footnote 28 at its page 11, footnote 31 at its page 18, and footnote 32 at its page 18. This note previously gave that mapping as footnotes 27, 31 and 32 at pages 10, 11 and 18, and omitted footnote 28 altogether. The sentence “The Committee still does not know how or why you settled on a payment of $20 million instead of the $60 million Epstein demanded for the” runs on past the foot of this sheet and completes with “transaction.” at the head of p. 9, so a checker searching for that sentence whole will not find it on either sheet alone; it is pinned to both. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  17. The same letter, EFTA02731023 p. 9 of 16. Read at the image at 700 dpi. The sheet carries the conclusion of the preceding sentence, the paragraph on further investigation, the bold centred heading “Refusal to provide information regarding Epstein’s compensation scheme”, the $158 million and $25 million averages, the February 13, 2013 agreement, and footnotes 33 to 35; the foot of the sheet is stamped EFTA02731031. ⚠ The full stop after “substantial misrepresentations of tax laws” is on the sheet, followed by a superscript 34, and the extraction has eaten both, rendering the line misrepresentations of tax laws!. A quotation checker may therefore report that the terminal stop is not on any cited sheet. It is; it was read at 700 dpi. The en dash in “services – particularly” is the sheet’s own. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  18. The same letter, EFTA02731023 p. 10 of 16. Read at the image at 700 dpi. The sheet carries the ad hoc payment requests, the dated chronology of asking, the meeting at the Committee’s offices, the bold centred heading “Arrangement with Epstein raises concerns of whether such amounts represented services income or a gift”, and footnotes 36 and 37; the foot of the sheet is stamped EFTA02731032. Footnote 36 quotes the Dechert report at its page 16 for the 2014 and 2015 payments and Black’s attribution of $20 million to the step-up-basis transaction; footnote 37 reads “Email from Majority Staff, Senate Finance Committee to outside counsel to Leon Black at Paul, Weiss, Rifkind Wharton & Garrison LLP, Sep. 20, 2022.” ⚠ CORRECTED 2026-09-24 at the image: the sentence that begins with the lack of transparency surrounding payments to Epstein COMPLETES ON THIS SHEET, ending “or as payment for services rendered.”, and the body of this page quotes it whole and cites this sheet alone for it, which is correct. This note previously said that the sentence ran on past the foot of this sheet, that it was quoted only as far as the sheet carried it, and that a truncation row on it was a disclosure rather than a defect to be repaired. The sheet refutes all three, and a standing instruction to a later pass not to repair something is worse than the row it was protecting. What does run on past the foot of this sheet is the next sentence, whose first words are The Dechert report states that you retained, and which this page does not quote. No producer redaction appears on this sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13

  19. The same letter, EFTA02731023 p. 11 of 16. Read at the image at 700 dpi. The sheet carries the Dechert report’s description of Epstein’s retainer, the reasonable-compensation analysis, the IRS definition of a gift, the deduction provisions, and footnotes 38 to 43; the foot of the sheet is stamped EFTA02731033. ⚠ CORRECTED 2026-09-24: this sheet is quoted at length on this page, four times, and what is quoted is attributed to the Internal Revenue Service and not to the Dechert report: the reasonable-compensation guidance, the four factors it lists, the definition of a gift, and the ordinary-course-of-business proviso. This note previously said that nothing on the sheet was quoted beyond what the body attributes to the report and that the sheet was cited only for completeness of the run; both statements were wrong. ↩ ↩2 ↩3 ↩4 ↩5

  20. The same letter, EFTA02731023 p. 12 of 16. Read at the image at 700 dpi. The sheet carries the tax-deductibility paragraph, the chairman’s statement of his general concern, the other committee investigations, and footnotes 44 and 45, which are the last footnotes in the letter; the foot of the sheet is stamped EFTA02731034. The sentence beginning “The facts and circumstances surrounding your business arrangement with Epstein present a variety of novel issues” runs on past the foot of this sheet. The straight apostrophe in “the Committee’s investigation into Credit Suisse” is the sheet’s own, where the rest of the sheet uses a curly one. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  21. The Bates block, measured for this page. Grouping the corpus pages table by identifier over a three-hundred-number window centred on this letter returns eight identifiers, with sheet counts of 22, 5, 16, 30, 13, 86, 32 and 26. Adding each run’s length to its first number gives its last, and every one of the seven boundaries is contiguous: each run ends exactly one number before the next begins. The first of the eight is the Dechert LLP memorandum to the Apollo Conflicts Committee of January 22, 2021, produced in the form Apollo filed it with the Securities and Exchange Commission as Exhibit 99.1; its date and its length are taken from its own first sheet at the text layer and this desk has not rendered it. 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. EFTA02730996 p. 1. ↩ ↩2 ↩3

  22. The five Southern District runs numbered immediately after this letter were not opened for this page. Their identifiers, lengths and dates are taken from the corpus pages table and from the SDNY prosecution memoranda, a page of this wiki which describes all six memoranda of that family with its own image-verified citations, and from EFTA02731168, which has a page of its own. Two of the five, EFTA02731069 and EFTA02731082, carry a header on their own first sheets marking them privileged attorney work product and confidential subject to Federal Rule of Criminal Procedure 6(e). Nothing is taken from any of the five here beyond identifier, length, date and first-sheet heading, and this page makes no claim about their contents. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  23. Extraction damage, recorded from a line-by-line comparison of the served text layer against the 700 dpi images of all sixteen sheets. The strings in the left-hand column of the table above are the extraction’s own; the strings in the right-hand column were read at the image. The January 1r reading was checked under a further enlargement of p. 3 at 700 dpi, which shows “January 13” with a superscript “th”, and is corroborated by the letter’s own footnote 9 giving “Jan. 13, 2023”: EFTA02731023 p. 3. The 5600 for $600 reading is on EFTA02731023 p. 2, inside footnote 6 of the letter, and belongs to the same class as a serif dollar sign read as an S. ⚠ CORRECTED 2026-09-24: this row was previously placed at p. 8, footnote 27, and that was wrong. The letter quotes the same Dechert sentence in two places, and the extraction damages only one of them: p. 8, footnote 27 renders it saved $600 million in value, undamaged. Both sheets were rendered at 700 dpi and read beside their own extracted text for this correction, and both print the figure with its dollar sign; the fault is in the extraction of p. 2 alone. That the same sentence survives on one sheet and not on the other, in one document, is the sharper finding, because it shows the damage is not a property of the phrase. The September I reading is on p. 13. The them were reading is on EFTA02731023 p. 4, inside footnote 13 of the letter. ⚠ The any donative intent? reading is a new species of this fault and was verified under a further enlargement of EFTA02731023 p. 11: the sheet carries a full stop, a closing quotation mark and a superscript 41, and the extraction has compressed the stop and the superscript into a question mark, turning a quoted statement of a Treasury regulation into a question. The superscript footnote markers rendered as punctuation are on p. 2 and p. 9. The masthead corruptions are on p. 1. ⚠ Two consequences for checkers, stated so that the next pass does not “fix” them. A quotation checker reports that the full stops after “Securities and Exchange Commission” and after “misrepresentations of tax laws” are not on any cited sheet: they are, and both were read at 700 dpi, but the extraction has eaten each of them along with the superscript that follows it, so the right-hand column of the table above describes those marks instead of reproducing them inside a quotation. The same checker reports the stop after “any donative intent” for the same reason, and separately reports a trailing comma after “charged for those services” where the sheet has a full stop and this page has set a comma inside the closing quotation mark to join the fragment into its own sentence: that is the house convention the checker itself labels as such, and it changes no sense. And a pin checker reports twelve distinct quoted spans, over one hundred and four printed rows, as unresolved, because none of them exists in the extraction in the form the sheet carries, which is the whole point of this section. They are given here in full, because an incomplete list is how a real defect hides among the harmless ones. Four are the masthead strings on p. 1; one is the addressee’s c/o line on p. 1; one is the pair of 2023 dates on p. 3; one is the September 1 return date on p. 13; one is the them were clause inside footnote 13 on p. 4. Four more are whole on their sheet but broken in the extraction across a line or a sheet boundary: the opening clause of the return-date sentence on p. 13, the $20 million settlement sentence that completes on p. 9, the follow-up-requests sentence on p. 3, and the opening of footnote 13’s quotation on p. 4. ⚠ Three further spans were unresolved until 2026-09-24 for a different and worse reason, and they were the ones worth finding: they were pinned to the 2022 letter, which does not contain any of them, while all three are on sheets of this letter. Two have been unquoted and the third repinned to the sheet that carries it, and no quotation on this page is now pinned to the 2022 letter for anything that letter does not hold. An unresolved row is where a wrong document hides, and this page’s own earlier note dismissed the bucket as text-layer damage without counting it. One pin has been moved on this page: the 5600 row, from p. 8 to p. 2, on 2026-09-24, after both sheets were rendered at 700 dpi and each sheet’s own extracted text was read beside it. No other pin was moved, and none was moved to improve a checker count. 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. The derived classification stored for this identifier in the corpus calls this letter a financial invoice; that label is wrong, is not used anywhere on this page, and is recorded here so that nobody relies on it. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12

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