Epstein Data Wiki

C.O.U.Q. Foundation, Inc.

Properties2
tagsentity, delaware, epstein-company, foundation, philanthropy
aliasesThe C.O.U.Q. Foundation, Inc., The C.O.U.Q. Foundation, C.O.U.Q. Foundation, COUQ Foundation, The Florida Science Foundation

22 min read

TypeDelaware non-profit, non-stock corporation; filed as a section 501(c)(3) exempt private foundation12
IncorporatedCertificate of incorporation filed in Delaware March 16, 1998 at 2 p.m.3
IncorporatorDarren K. Indyke, 457 Madison Avenue, New York1
Delaware registered agentThe Corporation Trust Company, 1209 Orange Street, Wilmington1
EIN13-39964714
Initial directorsJeffrey E. Epstein, Darren K. Indyke, Ghislaine Maxwell1
Officers, year ending Feb. 28, 2007Epstein president and director; Indyke vice-president and director; Maxwell treasurer; each one hour a week, none compensated5
Officers, 2012Epstein president; Indyke vice-president; Richard Kahn treasurer67
Other registrationsNew York foreign not-for-profit, filed March 26, 1999; qualified in Florida July 9, 2008; Florida fictitious name “The Florida Science Foundation” registered July 10, 20088910
Assets$22,832,814 fair market value at February 28, 20072
BankJPMorgan Chase, account statements September 2006 to January 2013117
DissolvedNovember 19, 2012; counsel told the New York Charities Bureau that “[a]t the time of dissolution, the corporation had no assets”412

The C.O.U.Q. Foundation, Inc. was a Delaware charitable corporation through which Jeffrey Epstein made grants to universities, research institutes, arts organisations and other charities between 1998 and 2012. It was incorporated in March 1998 by his attorney Darren K. Indyke, who with Epstein and Ghislaine Maxwell formed its initial board; Epstein was its president, Maxwell its treasurer until 2007, and Richard Kahn succeeded her.1513 It reported fair market value assets of $22,832,814 and grants of $1,186,000 for the year ending February 28, 2007.2 In July 2008, after Epstein had begun his Florida sentence, it qualified to conduct affairs in Florida and registered the fictitious name “The Florida Science Foundation,” which he then gave as his employer on a work-release application; the United States Attorney’s Office for the Southern District of Florida wrote to the Palm Beach Sheriff’s Office that the Florida Science Foundation, its offices and Epstein’s purported job schedule “were all created on the eve of Mr. Epstein’s incarceration in order to provide him with a basis for seeking work release.”9101415 It was dissolved on November 19, 2012 with no assets.412 The Government of the United States Virgin Islands later alleged in its suit against JPMorgan Chase that the Foundation’s account there had been used for payments unrelated to any charitable purpose; the bank denied liability and the case was recorded by the court as settled.161718

The certificate of incorporation of “The C.O.U.Q. Foundation, Inc. (A Non-Profit, Non-Stock Corporation)” was faxed to Delaware on March 13, 1998 and filed on March 16 at 2 p.m.; the Secretary of State’s certification, signed by Edward J. Freel, records the filing.31 Article Third states that the Foundation “shall have no capital stock” and is “a nonprofit organization, organized and operated exclusively for one or more charitable, religious, literary, scientific and educational purposes within the meaning of Section 501(c)(3) of the Internal Revenue Code of 1986.”1 Article Fourth names the incorporator as “Darren K. Indyke, Esq., 457 Madison Avenue, Fourth Floor, New York, NY 10022”; Article Fifth gives the Foundation perpetual existence and Article Sixth provides that it “shall have no members.”1 The registered office was the Corporation Trust Center at 1209 Orange Street, Wilmington, with The Corporation Trust Company as agent.1 Article Ninth bars distribution of assets or income to any private individual and provides that on liquidation the remaining property is to go to organisations qualifying under section 501(c)(3).19

Its returns were prepared under employer identification number 13-3996471 and filed from the New York office of the accountants George V. Delson Associates, which the Form 990-PF gives as the Foundation’s own mailing address.24 A commercial business report compiled in 2008 records a New York registration as a foreign not-for-profit corporation filed on March 26, 1999, and a Florida registration as a foreign non-profit with a foreign incorporation date of July 9, 2008.820 The New York Charities Bureau registration number was 06-34-76.6

The Florida Department of State wrote on July 10, 2008 that qualification documents had been filed on July 9 and that the corporation was “now qualified and authorized to transact business in Florida as of the file date”; the application gives its principal office as 250 S. Australian Avenue, Suite 1404, West Palm Beach, and names C T Corporation System as Florida registered agent.921 A full-text search of the release for “C.O.U.Q.” and for “COUQ,” and for those terms in combination with “stands for,” “acronym,” “named for” and “named after,” returned no document that expands them.

Officers and directors

The certificate of incorporation names three initial directors: Jeffrey E. Epstein, at 358 El Brillo Way, Palm Beach; Darren K. Indyke, in New York; and Ghislaine Maxwell, care of George V. Delson Associates, New York.1 Part VIII of the Form 990-PF for the year ending February 28, 2007 lists the same three, with titles and hours: Epstein as “Pres./Director,” Indyke as “VP/Director” and Maxwell as “Treasurer,” each recorded as devoting one hour a week and each receiving no compensation, no benefits and no expense allowance.5 The Daily Beast reported in 2020 that Kahn replaced Maxwell as treasurer in 2007 and held the post until the charity dissolved.13 Kahn signed the Florida fictitious-name application as treasurer on July 8, 2008.10 The final New York annual filing was certified in January 2013 by Indyke as vice-president and Kahn as treasurer, and a forensic accountant’s expert report in the JPMorgan litigation records that the Foundation’s 2012 return identified Epstein as president, Kahn as treasurer and Indyke as vice-president.67

The United States Attorney’s Office wrote in December 2008 that it had located the Foundation’s returns for fiscal years 1999 through 2006 and that “[t]hese sworn filings show that Mr. Epstein worked for the Foundation for only one hour per week and earned no compensation,” and that all of them “were signed under penalty of perjury by either Mr. Epstein or Darren Indyke.”15

Contributions received

Year endingRecorded contributions received
Feb. 29, 2000Jeffrey E. Epstein $75,000; John J. Hannan $166,667; William Mack $166,666; Leon Black $166,667, the last three care of Apollo Management, LP — total $575,00022
Feb. 28, 2002From Leslie H. Wexner, as grantor of The Wexner Children’s Trust, “600,000 shares of Too, Inc common stock having a market value of $11,205,000 at date of gift recorded on the Foundation’s books at the donor’s basis”23

The New York Times reported in August 2019 that “Wexner-backed entities financed a charity called C.O.U.Q., which Mr. Epstein controlled,” and that the Foundation “accepted an $11.2 million donation from the Wexner Children’s Trust in 2002 and $10 million from the Leslie H. Wexner Charitable Fund in 2004.”24 The profit and loss statement of Enhanced Education, Epstein’s Virgin Islands foundation, records grants to the C.O.U.Q. Foundation of $200,000 in 2009 and $100,000 in 2010.25

Grantmaking

Grants recorded in the returns held in the released files:

Year endingTotal contributions paid
Feb. 28, 2001$100,000 (World Economic Forum $50,000; Ionia, Inc. $50,000)26
Feb. 28, 2002$845,00027
Feb. 28, 2003$1,245,00028
Feb. 28, 2006$1,125,13329
Feb. 28, 2007$1,186,00030

Recipients in the year to February 28, 2002 included the Institute for Advanced Study ($400,000), Harvard University ($125,000), the UNM Foundation ($100,000), the University of Maryland ($50,000) and the Nelson Mandela Children’s Fund ($50,000).27 In the year to February 28, 2003 they included Harvard University ($200,000 and $110,000), the Neurosciences Research Foundation ($250,000), the Santa Fe Institute ($50,000 and $100,000), the Massachusetts Institute of Technology ($100,000), Engines for Education ($62,500 twice), The Dalton School ($75,000) and the Edge Foundation ($50,000).28

Statement 6 to the return for the year ending February 28, 2007 lists every contribution paid in that year:30

DateRecipientAmountPurpose
3/7/2006Stockholm School of Economics25,000Unrestricted
5/3/2006The Continium Center for Health & Hearing25,000Unrestricted
5/30/2006Hunter College3,000Scholarship
6/1/2006Martha Graham Dance Company10,000Scholarship
6/14/2006Little Flower Children’s Services10,000Unrestricted
6/28/2006Robin Hood50,000Unrestricted
7/12/2006Ballet Florida20,000Unrestricted
7/18/2006Georgia Southern University10,000Scholarship
7/18/2006William J. Clinton Foundation25,000Unrestricted
8/10/2006Freestate Shooters25,000Unrestricted
8/11/2006Zvi Tzedakah Fund100,000Unrestricted
9/1/2006Institute of International Education100,000Unrestricted
9/6/2006Alliance for Lupus Research5,000Unrestricted
9/8/2006Happy Hearts Fund100,000Unrestricted
9/27/2006Ovarian Cancer Research Fund50,000Unrestricted
10/3/2006The Trilateral Commission50,000Unrestricted
10/5/2006Faith in The Future, Inc.5,000Unrestricted
10/5/2006National Council of Jewish Women5,000Unrestricted
11/10/2006The Institute for Music & Brain Science25,000Unrestricted
11/16/2006President and Fellows of Harvard College100,000Unrestricted
11/27/2006Santa Fe Institute75,000Unrestricted
1/17/2007Ballet Florida15,000Unrestricted
1/18/2007Save Darfur Coalition150,000Unrestricted
2/7/2007Stockholm School of Economics50,000Unrestricted
2/21/2007Saint Peter’s Prep3,000Unrestricted
2/22/2007Scholar Rescue Fund150,000Unrestricted

CNBC reported in July 2019 that Epstein “through his C.O.U.Q. nonprofit in 2006 reportedly sent $25,000” to the Clinton Foundation, and that a spokesman for Bill Clinton had said the former president had not spoken to Epstein for over a decade; the article records that the foundation did not return a request for comment.31

Interlochen Center for the Arts

A letter of April 25, 2003 from Interlochen’s vice-president for development to Epstein reads: “On behalf of all of us at Interlochen Center for the Arts, I want to write and express our deep appreciation for the recent gift of $17,000 from C.O.U.Q. Foundation. This gift provides us with the needed funds for the Interlochen Jazz Ensemble to compete in the Essentially Ellington Jazz Festival at Lincoln Center on May 17 – 20, 2003.”32 Interlochen’s donor database records the gift as a single donation of $17,000 by cheque, dated April 9, 2003, from “The C.O.U.Q. Foundation, Inc” and designated to music tours.33 A solicitation letter of March 25, 2003 had asked Epstein to help underwrite the $17,000 the trip was expected to cost.34

A wire instruction for Marvin Minsky

A memorandum of December 21, 2007 from “Jeffrey Epstein/ COUQ Foundation” to a JPMorgan banker directs: “Please wire Fifty Thousand Dollars ($50,000) from the above account to: Bank name: Brookline Bank … Account Name: Marvin Minsky.”35 The document is an instruction to the bank and not a record of a completed transfer. See Marvin Minsky.

Investments and the Bear Stearns litigation

Statement 4 to the return for the year ending February 28, 2007 lists the Foundation’s other investments as an interest in Bear Stearns Asset Backed Securities Partners LP, carried at $7,289,911 book value and $11,870,413 fair market value, and an interest in Second City Capital Partners I, LP at $6,136,808 book and $6,144,653 fair market.36 The same return reports total revenue of $646,781 against total expenses and disbursements of $1,972,636, an excess of expenses over revenue of $1,325,855.2

A schedule to a draft of the settlement records that the Foundation put $10,000,000 into the Bear Stearns asset-backed securities funds in January 2004, and that “[p]ursuant to an instrument dated January 1, 2008, COUQ assigned to YLK Charitable Trust 100 percent of the shares COUQ owned in Bear Stearns Asset Backed Securities Overseas, Ltd.”37 The Foundation and Financial Trust Company, Inc. brought an arbitration before FINRA Dispute Resolution against The Bear Stearns Companies Inc., Bear, Stearns & Co. Inc., Bear Stearns Asset Management Inc. and Warren Spector, case number 09-00979; a draft settlement agreement circulated in September 2010 recites that the claimants alleged “among other things, fraudulent inducement, breach of fiduciary duty, constructive fraud, negligent misrepresentation and breach of contract in connection with the Investments.”38 Financial Trust brought a parallel federal action that was consolidated in the Southern District of New York.39 An execution copy of a settlement agreement dated as of August 2011 among Financial Trust, the Foundation and Epstein on one side and the Bear Stearns respondents on the other provides that the respondents “shall pay the sum of $9,200,000” to the claimants collectively, by wire to an attorney trust account established by Darren K. Indyke PLLC, and records that the settlement is made “without any admission of liability, and Respondents specifically deny any liability whatsoever.”3940 The copy in the released files is unexecuted: the day of the month is left blank and every signature line is empty.41 Claimants’ counsel wrote to the respondents’ lawyers on August 29, 2011 referring to “the Settlement Agreement” and enclosing a stipulation of dismissal with prejudice of the arbitration.42

Transfers to the YLK Charitable Fund, 2007–2008

CNBC reported in July 2019, citing tax filings, that the Foundation gave $14 million to the YLK Charitable Fund in 2007 and that “[j]ust before Epstein began a 13-month jail term, his firm, the Financial Trust Co., based in the U.S. Virgin Islands, and his own nonprofit, The C.O.U.Q. Foundation, contributed a combined $46 million plus to YLK, according to a 2008 990 disclosure form.”43 It reported that the initial financing consisted of “$33 million worth of Apple stock and $5.4 million in shares of Bear Stearns Asset Backed-Securities Overseas Ltd.,” that Abigail Wexner was YLK’s president in 2008 and Leslie Wexner became its director in 2010, and that YLK received no other contribution that year and none in 2009 or 2010.43

The New York Times reported the same $46 million transfer in August 2019 and recorded Wexner’s own account of it. In a letter to the Wexner Foundation community, Wexner wrote that on separating from Epstein “[i]t was agreed that he should step back from the management of our personal finances. In that process, we discovered that he had misappropriated vast sums of money from me and my family.”24 He said he had been “able to recover some of the funds,” and the Times reported that this “included a transfer of about $46 million worth of securities from C.O.U.Q. and a Virgin Island business controlled by Mr. Epstein to a foundation run by Mr. Wexner’s wife, Abigail Wexner, according to tax documents,” which Wexner described as a “portion of the returned monies.”24 The Times reported separately that Wexner’s lawyers “worked out a private arrangement in which Mr. Epstein’s foundation and business would repay some of the misappropriated money.”44 A lawyer for Epstein did not respond to the accusation, and a spokeswoman for Wexner told CNBC only that he had “severed ties” with Epstein over a decade earlier.2445 See Les Wexner.

Work release and “The Florida Science Foundation”

On July 8, 2008 Richard Kahn signed, as treasurer, a Florida application to register the fictitious name “The Florida Science Foundation,” giving the owner as “The C.O.U.Q. Foundation, Inc.” at 250 S. Australian Avenue, Suite 1404, West Palm Beach; the registration took effect on July 10, 2008.1046

On December 11, 2008 the United States Attorney’s Office for the Southern District of Florida wrote to a captain of the Palm Beach Sheriff’s Office corrections division about Epstein’s work-release application, over the name of United States Attorney R. Alexander Acosta and by Assistant United States Attorney A. Marie Villafaña.1447 The letter states that Epstein was “alternatively referred to as working for ‘The Florida Science Foundation’ or ‘self-employed,’” that he listed a salary of $250,000, and that “the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000.”1415 It continues: “Mr. Epstein provided to you no documentation regarding his pre-incarceration employment with ‘The Florida Science Foundation’ or its corporate alter-ego, ‘The C.O.U.Q. Foundation, Inc.’ As you will see, the Foundation, its offices, and Mr. Epstein’s purported job schedule were all created on the eve of Mr. Epstein’s incarceration in order to provide him with a basis for seeking work release.”15 The letter adds that The Florida Science Foundation “was not registered with the State of Florida and had no office space or telephone number until after Mr. Epstein was already incarcerated,” and that the Florida application was signed under penalty of perjury by Kahn and gave as the Foundation’s telephone number that of one of the law firms then representing Epstein.15 Indyke, described in the file as Epstein’s supervisor, had supplied a work schedule stating that Epstein “will be responsible for the general oversight and management of the Foundation” six days a week from 8 a.m. to 8 p.m. at the West Palm Beach address; the letter observes that this was not reconciled with the one hour a week the returns recorded.15 No response by Epstein or his counsel to the letter appears in the documents cited here; Epstein died in 2019 and none can now be given.

A Florida community-control contact log for Epstein records, at 07:50 on July 28, 2009: “WRITTEN MONTHLY REPORT RECEIVED FOR CURRENT MONTH. DEFT SUBMITTED PROOF OF EMPLOYMENT - CERTIFICATE OF INCORPORATION FOR THE C.O.U.Q. FOUNDATION AND FINANCIAL TRUST COMPANY, INC. SUBMITTED OLD CC SCHEDULE AND NEW SCHEDULE APPROVED.”48

The JPMorgan account and the Virgin Islands litigation

In September 2020 JPMorgan’s counsel produced to the Southern District of New York an index of accounts for which the bank held wire data in response to grand jury subpoenas; “THE C O U Q FDN INC” appears in it under the heading of Epstein and “JE DM” accounts.11 A Suspicious Activity Report filed by JPMorgan Chase Bank NA and JP Morgan Securities LLC reporting “4,725 wire transactions, totaling $1,081,819,653, that occurred from 10/01/2003 to 07/22/2019” names “THE C.O.U.Q. FOUNDATION INC” among the current, former and non-customers involved.49

The Government of the United States Virgin Islands, in its Second Amended Complaint against JPMorgan, listed the C.O.U.Q. Foundation among the companies and non-profit organisations it said were “[s]pecifically included in the Epstein Enterprise,” a term the complaint uses for what it alleged was an illicit association of Epstein, his businesses and his associates.50 The complaint alleged that “Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein’s purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education,” that “Epstein made payments from these accounts with no clear nexus to the organization’s charitable purpose,” and, as an example, that “Epstein and/or his representative used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc.”51 A forensic accountant’s expert report served for the Virgin Islands in June 2023 sets out two wires from the Foundation’s JPMorgan account to Phoenix Realty Home Inc., of $14,557.49 on July 24, 2007 and $5,550.00 on December 19, 2008, which its author says “appear to be unrelated to C.O.U.Q. Foundation’s charitable purpose,” and, under the heading “Payments Unrelated to Charitable Organization’s Purpose,” four payments to women totalling $30,362.14, whose payees are redacted.52 The complaint further noted that the bank’s 2013 compliance report described “nothing unusual” in Epstein’s account transactions and stated that “Compliance reviews activity regularly.”51

These are allegations in a pleading and an opinion in an expert report served by one party. JPMorgan denied liability and wrongdoing and did not admit the complaint’s allegations; the court recorded that the case “was settled for $75 million” and that the case was closed on October 18, 2023.18 Epstein died in August 2019, and no answer from him to these allegations exists. See JPMorgan Chase.

Dissolution

The Foundation’s final Form 990-PF covers the tax year from March 1, 2012 to November 19, 2012 and reports total assets of nil at the end of the year, against $3,045 in cash at the beginning.453 The final Form CHAR500 for 2012, marked “Final filing,” was certified for the same period by Kahn on January 7, 2013 and by Indyke on January 8, 2013.6 On January 8, Indyke wrote to the New York State Department of Law: “We hereby request that the Charities Bureau close the registration for The C.O.U.Q Foundation, Inc., a Delaware corporation, now dissolved. At the time of dissolution, the corporation had no assets.”12

The Daily Beast reported in 2020: “Before C.O.U.Q. shut down in November 2012, Epstein created another murky entity called Gratitude America Ltd. The charity’s tax filings didn’t show revenues until 2015, when Kahn replaced Epstein as president of the group and investor Leon Black donated $10 million through an anonymous LLC.”54 See Gratitude America, Ltd..

After Epstein’s death, Schedule G to the first quarterly accounting of his estate in the Superior Court of the Virgin Islands lists the C.O.U.Q. Foundation, Inc. among the defendants to a civil action filed in the New York Supreme Court in August 2019, index number 950010/2019, alongside the estate, its executors and many other Epstein entities.55

Darren Indyke; Richard Kahn; Ghislaine Maxwell; Les Wexner; Leon Black; Marvin Minsky; Financial Trust Company, Inc.; Enhanced Education; Gratitude America, Ltd.; Southern Trust Company; HBRK Associates; JPMorgan Chase; Harvard University and Jeffrey Epstein.

Footnotes

  1. Certificate of incorporation of The C.O.U.Q. Foundation, Inc., faxed March 13, 1998, within Epstein’s Florida supervision file. https://epstein-data.com/EFTA00181807 p.404. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  2. The C.O.U.Q. Foundation, Form 990-PF for the tax year March 1, 2006 to February 28, 2007, page 1. https://epstein-data.com/EFTA00190062 p.1. ↩ ↩2 ↩3 ↩4 ↩5

  3. Certification of the Delaware Secretary of State, signed Edward J. Freel, attached to the certificate of incorporation. https://epstein-data.com/EFTA00181807 p.403. ↩ ↩2

  4. The C.O.U.Q. Foundation, Inc., Form 990-PF for the tax year March 1, 2012 to November 19, 2012. https://epstein-data.com/EFTA00312858 p.4. ↩ ↩2 ↩3 ↩4 ↩5

  5. Form 990-PF, year ending February 28, 2007, Part VIII. https://epstein-data.com/EFTA00190062 p.6. ↩ ↩2 ↩3

  6. Form CHAR500, Annual Filing for Charitable Organizations, 2012, marked “Final filing,” certified January 8, 2013. https://epstein-data.com/EFTA00312858 p.3. ↩ ↩2 ↩3 ↩4

  7. Expert report of Jorge Amador, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 238-31, June 16, 2023, report p.54. https://epstein-data.com/EFTA02810827 p.57. ↩ ↩2 ↩3

  8. Commercial business report on the Foundation’s New York registration, October 2008, within a production of nonprofit filings. https://epstein-data.com/EFTA00192298 p.10. ↩ ↩2

  9. Florida Department of State, Division of Corporations to The C.O.U.Q. Foundation, Inc., July 10, 2008. https://epstein-data.com/EFTA00181807 p.409. ↩ ↩2 ↩3

  10. Application for registration of fictitious name, “The Florida Science Foundation,” owner The C.O.U.Q. Foundation, Inc., signed by Richard Kahn as treasurer, July 8, 2008. https://epstein-data.com/EFTA00181807 p.408. ↩ ↩2 ↩3 ↩4

  11. WilmerHale to the United States Attorney’s Office for the Southern District of New York, September 2, 2020, Appendix A. https://epstein-data.com/EFTA00096342 pp.1, 4. ↩ ↩2

  12. Letter, Darren K. Indyke PLLC to the New York State Department of Law, Office of the Attorney General, January 8, 2013. https://epstein-data.com/EFTA00312858 p.2. ↩ ↩2 ↩3

  13. Kate Briquelet and William Bredderman, “Jeffrey Epstein’s Right-Hand Mystery Men,” The Daily Beast, August 30, 2020, preserved in a DOJ production. https://epstein-data.com/EFTA00163119 pp.3, 16. ↩ ↩2

  14. R. Alexander Acosta, United States Attorney, by A. Marie Villafaña, Assistant United States Attorney, to Captain David Sleeth, Palm Beach Sheriff’s Office, December 11, 2008. https://epstein-data.com/EFTA00189918 p.1. ↩ ↩2 ↩3

  15. Same letter, p.2. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  16. Government of the United States Virgin Islands, Second Amended Complaint, USVI v. JPMorgan Chase Bank, N.A., 22-cv-10904 (JSR), Doc. 119, April 12, 2023. https://epstein-data.com/EFTA00145666 pp.8, 17. ↩

  17. JPMorgan Chase Bank, N.A.’s Third-Party Complaint against James Edward Staley, 22-cv-10904 (JSR), Doc. 70, March 8, 2023, ¶¶1–5. https://epstein-data.com/EFTA02806526 pp.1–4. ↩

  18. Memorandum Order, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 366, June 28, 2024. https://epstein-data.com/EFTA02819006 p.1. ↩ ↩2

  19. Certificate of incorporation, articles Eighth to Ninth. https://epstein-data.com/EFTA00181807 p.405. ↩

  20. Commercial business report on the Foundation’s Florida registration, October 2008. https://epstein-data.com/EFTA00192298 p.7. ↩

  21. Application by foreign not-for-profit corporation for authorization to conduct its affairs in Florida. https://epstein-data.com/EFTA00181807 p.410. ↩

  22. The C.O.U.Q. Foundation, Form 990-PF for the year ending February 29, 2000, Statement 1, within a production of nonprofit filings. https://epstein-data.com/EFTA00192298 p.48. ↩

  23. The C.O.U.Q. Foundation, Inc., Form 990-PF for the year ending February 28, 2002, Statement 1. https://epstein-data.com/EFTA00192298 p.104. ↩

  24. Steve Eder and Emily Steel, “Leslie Wexner Accuses Jeffrey Epstein of Misappropriating ‘Vast Sums of Money,’” New York Times, August 7, 2019, preserved in a DOJ production. https://epstein-data.com/EFTA00172284 pp.1–3. ↩ ↩2 ↩3 ↩4

  25. Enhanced Education, profit and loss, January through December 2010 with 2009 comparatives. https://epstein-data.com/EFTA00310685 p.31. ↩

  26. The C.O.U.Q. Foundation, Form 990-PF for the year ending February 28, 2001, Statement 3. https://epstein-data.com/EFTA00192298 p.78. ↩

  27. Form 990-PF, year ending February 28, 2002, Statement 4, contributions paid. https://epstein-data.com/EFTA00192298 p.110. ↩ ↩2

  28. Form 990-PF, year ending February 28, 2003, Statement 2, contributions paid. https://epstein-data.com/EFTA00192298 p.140. ↩ ↩2

  29. The C.O.U.Q. Foundation Inc., Form 990-PF for the year ending February 28, 2006, Part XV and Statement 5. https://epstein-data.com/EFTA01714002 pp.7, 10. ↩

  30. Form 990-PF, year ending February 28, 2007, Statement 6, contributions paid. https://epstein-data.com/EFTA00190062 p.17. ↩ ↩2

  31. Same article, p.4. ↩

  32. Interlochen Center for the Arts to Jeffrey Epstein, April 25, 2003. https://epstein-data.com/EFTA00102702 p.243. ↩

  33. Interlochen donor database record, “C.O.U.Q. Foundation, Inc $17000.00 Single Donation 04/09/2003.” https://epstein-data.com/EFTA00102702 pp.11, 14. ↩

  34. Interlochen Center for the Arts to Jeffrey Epstein, March 25, 2003. https://epstein-data.com/EFTA00102702 p.293. ↩

  35. Memorandum, Jeffrey Epstein / COUQ Foundation to JPMorgan, December 21, 2007. https://epstein-data.com/EFTA01578922 ↩

  36. Form 990-PF, year ending February 28, 2007, Statement 4. https://epstein-data.com/EFTA00190062 p.16. ↩

  37. Draft settlement agreement and release, August 2011, among Financial Trust Company, Inc., The C.O.U.Q. Foundation, Inc. and Jeffrey Epstein and the Bear Stearns respondents, schedule of contributions and note. https://epstein-data.com/EFTA00611330 p.27. ↩

  38. Draft settlement agreement and release, September 17, 2010, recitals. https://epstein-data.com/EFTA01300739 pp.1–2. ↩

  39. Settlement agreement and release, execution copy, dated as of August 2011, recitals and paragraph 2.1. https://epstein-data.com/EFTA00615375 pp.1–2, 6. ↩ ↩2

  40. Settlement agreement and release, execution copy, recital preceding paragraph 1. https://epstein-data.com/EFTA00615375 p.2. ↩

  41. Settlement agreement and release, execution copy, signature page. https://epstein-data.com/EFTA00615375 p.16. ↩

  42. Susman Godfrey LLP to counsel for the Bear Stearns respondents, August 29, 2011, enclosing a stipulation of dismissal with prejudice. https://epstein-data.com/EFTA00283089 pp.1, 22. ↩

  43. Brian Schwartz, “Jeffrey Epstein used $46 million charitable donation to keep alive his ties with billionaire Les Wexner,” CNBC, July 11, 2019, circulated the same day in a U.S. Attorney’s Office email. https://epstein-data.com/EFTA00026723 p.2. ↩ ↩2

  44. Emily Steel, Matthew Goldstein, Steve Eder and David Enrich, “Jeffrey Epstein’s Opaque Finances Could Become Focal Point for Investigators,” New York Times, August 11, 2019, preserved in a DOJ production. https://epstein-data.com/EFTA00172288 p.2. ↩

  45. Same article, p.3. ↩

  46. Florida Department of State, Division of Corporations, acknowledgment of the fictitious name registration, July 10, 2008. https://epstein-data.com/EFTA00181807 p.407. ↩

  47. Same letter, closing block. https://epstein-data.com/EFTA00189918 p.3. ↩

  48. Florida offender contact and comment summary for Jeffrey Epstein, entry of July 28, 2009, within his supervision file. https://epstein-data.com/EFTA00181807 p.109. ↩

  49. Suspicious Activity Report narrative filed by JP Morgan Chase Bank NA and JP Morgan Securities LLC. https://epstein-data.com/EFTA01648787 p.1. ↩

  50. Same complaint, ¶27. https://epstein-data.com/EFTA00145666 p.8. ↩

  51. Same complaint, ¶¶68–69. https://epstein-data.com/EFTA00145666 p.17. ↩ ↩2

  52. Same report, pp.54–55. https://epstein-data.com/EFTA02810827 pp.57–58. ↩

  53. Final Form 990-PF, Part II balance sheet. https://epstein-data.com/EFTA00312858 p.5. ↩

  54. Same article, p.17. ↩

  55. Estate of Jeffrey E. Epstein, first quarterly accounting, Probate No. ST-19-PB-80, Superior Court of the Virgin Islands, Schedule G. https://epstein-data.com/EFTA00082467 pp.1, 14. ↩

Backlinks