Epstein Data Wiki

Cypress Inc

Properties2
tagsentity, virgin-islands, new-mexico, epstein-company, banking
aliasesCypress, Inc., CYPRESS, INC.

43 min read

TypeVirgin Islands corporation, formed under the General Corporation Law of the Virgin Islands (Chapter 1, Title 13, Virgin Islands Code); articles subscribed 21 November 201112
Date of incorporation11/22/2011, as entered on its 2013 franchise tax report and on FirstBank’s due-diligence sheet34
Registered office9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, per the articles; resident agent Kellerhals Ferguson LLP15
Business address6100 Red Hook Quarter B3, St. Thomas463
OfficersJeffrey Epstein, president and director; Darren Indyke, vice-president, secretary and director; Richard Kahn, treasurer and director, on its Virgin Islands filings from 2012 through 2019678
Capital10,000 authorised shares of $.01 par value; paid-in capital $1,000, unchanged on the 2011, 2012 and 2019 filings1639
Shareholder”Jeffrey Epstein, Trustee of Cypress I Trust”, entered as holding 100 per cent acquired 11/22/11, on the corporation’s IRS Form 2553 S-corporation election10
BankFirstBank Puerto Rico; account opened in May 2012 on an initial deposit of $1,000411
HeldThe Santa Fe County, New Mexico ranch, conveyed to it in December 2011 — for the conveyance see Zorro Trust, and for the property see Zorro Ranch
Stated purpose”formed solely for the purpose of holding certain real estate,” in a sworn statement given to its bank in April 2012; “Holding Property for Personal Use,” on the franchise tax report filed in June 2013123
Route into the releaseFirstBank Puerto Rico’s account file, produced under grand-jury process in the Southern District of New York; New Mexico Office of the State Engineer permit files; Deutsche Bank compliance records; Virgin Islands corporate filings; exhibits in the Virgin Islands’ litigation

Cypress, Inc. was the Virgin Islands corporation that held Jeffrey Epstein’s Santa Fe County, New Mexico ranch from December 2011.13 It was incorporated in St. Thomas three weeks before the conveyance, its officers were Epstein, Darren Indyke and Richard Kahn, and its bank account was opened at FirstBank Puerto Rico in the spring of 2012.164 The instruments by which the Zorro Trust conveyed the land, the state leases and the water rights to it are the subject of that page and are not repeated here; what follows is what the corporation did once it held them: what it told its bank, what it commissioned in New Mexico, how it was funded, and what it reported to the Virgin Islands.

Incorporation

The Articles of Incorporation of Cypress, Inc. recite that the incorporators associate “under the provisions and subject to the requirements of the laws of the Virgin Islands of the United States … and particularly the General Corporation Law of the Virgin Islands (Chapter 1, Title 13, Virgin Islands Code).”1 Article II locates the principal office at 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, and names Kellerhals Ferguson LLP as resident agent at the same address.1 Article III gives the corporation’s first stated purpose as “[t]o engage in any lawful business in the United States Virgin Islands,” and Article IV authorises 10,000 shares of common stock at $.01 par value with no preferred stock, the minimum capital with which the corporation will commence business being one thousand dollars.114

The signature page is subscribed “this 21st day of November, 2011” by three incorporators, Erika A. Kellerhals, Gregory J. Ferguson and Brett Geary, each rule carrying a pen signature; the acknowledgment beneath, of the same date, is taken before a St. Thomas notary.2 A separate Consent of Agent for Service of Process, signed the same day, records Kellerhals Ferguson LLP consenting to accept service for the company under Title 13 of the Virgin Islands Code.5 The Virgin Islands franchise tax report the corporation filed in June 2013 enters its date of incorporation as 11/22/2011.3

The Internal Revenue Service issued the corporation an employer identification number by a notice dated 12-15-2011, a Form CP 575 A addressed to CYPRESS INC at the Havensight address, which directs it to file Form 1120 by 03/15/2012.15 The corporation elected to be taxed as a small business corporation. Its IRS Form 2553, “Election by a Small Business Corporation (Under section 1362 of the Internal Revenue Code)”, enters the name as Cypress, Inc., the date incorporated as 11/22/2011, the state of incorporation as VI, and the election as effective for the tax year beginning 11/22/2011; at item F the Calendar year box carries a tick and the three alternatives beneath it are empty; and at item H the officer or legal representative the IRS may call is entered as Erika A. Kellerhals.16 On its second page, under the column headed “Name and address of each shareholder or former shareholder required to consent to the election,” a single row is completed. It reads “Jeffrey Epstein, Trustee of Cypress I Trust, 6100 Red Hook Qtr, B-3, St. Thomas, VI 00802”, with 100% entered against the number of shares or percentage of ownership, 11/22/11 against the dates acquired and 12/31 against the shareholder’s tax year end; the Signature and Date columns of the shareholders’ consent statement on that row are blank, and the rows beneath it are empty.10 An estate-office index of file contents carries a heading “CYPRESS INC Organizational” over a list of folder tabs: Articles of Incorporation, Incorporators Consents, Bylaws, Subscription Agreement, Stock Certificate, Initial Consent of Directors, Initial Stockholder’s Consent, Tax Identification Number (ID #), Virgin Islands S Election, Cypress I Trust, Cypress II Trust, Annual Report June 30, 2012.17 That is a list of tab titles and is evidence that files bore those names; the instruments behind the two trust tabs are not among the documents this page found, and no page cited here states any term of either.17

The bank account, and the affidavit that opened it

FirstBank’s Customer Due Diligence sheet for business accounts, Virgin Islands, gives the account title as CYPRESS, INC, the physical and mailing addresses as Red Hook Quarter B3, St. Thomas, the line of business as “Office Administrative Se”, the NAICS code as 561110, the date established as 11/22/2011, annual sales as $0.00, the number of offices or branches as 1 and the number of employees as 1.4 The authorised signer is entered as Jeffrey Epstein, occupation “FINANCIAL CONSULTANT”; the initial deposit is $1,000.00, type CHECKS.4 The bank’s automated screen, run on the file, returned a results summary of OFAC CHECK: PASSED and IDV RESPONSE: OVERRIDE; beneath it three result boxes reading EIN: FAILED, NAME MATCH: PASSED and ADDRESS MATCH: FAILED, the last against three St. Thomas addresses it held; an Alternative Verifications box in which PHONE MATCH carries no result and the input phone reads “No verification data given”; and an “Additional Actions taken” box reading ”* Note - Please confirm the EIN.” The override comment records “On 05/07/12 at 03:12:22 Madelin Colon Added: Cleared - Other … Client has provided the SS4 dated 12/15/2011 and the Articles of Incorporation. Client previosu address was verified and the address previously used was the location before relocating to Red Hook,” and the account status on that screen reads OPENED.11

Among the papers the bank took was a sworn statement headed “AFFIDAVIT RE NOT DOING BUSINESS,” in which Indyke states that he is “from the date of the filing of the Articles of Incorporation … the Secretary of Cypress, Inc.” and confirms:

I hereby confirm that the Company never did any business of any kind from the date of the filing of the Articles of Incorporation through the date of this statement and further state that the Company has no intention of doing any business in the foreseeable future.

I hereby further confirm that the Company was formed solely for the purpose of holding certain real estate, and it is not intended to be used for any type of business.12

The affidavit goes on to confirm “that the Company will not do any business of any kind prior to applying for and obtaining a United States Virgin Islands Business License, a copy of which will be delivered to the Bank,” and that “[t]he Company requires a bank account for the purpose of corporate expenses.”12 It is dated 18 April 2012, carries a pen signature over the rule captioned “Darren Indyke”, and is subscribed and sworn before a New York notary whose stamp reads Harry I. Beller.12

A FirstBank corporate resolution certified by Indyke as secretary and attested by Kahn as treasurer, dated 19 April 2012, records resolutions of the board authorising the officers to open accounts and to sign instruments.18 Its officer table lists Jeffrey Epstein against President, Darren Indyke against Secretary and Richard Kahn against Treasurer, each with a pen signature opposite; the rule opposite Vice President carries no name and no signature.18 A companion resolution for telephone, telex, facsimile and written instructions records a board meeting held at American Yacht Harbor on the 5th day of April 2012 and names, as the persons the bank is to call back to verify instructions, “Jeffrey Epstein, President”, “Richard Kahn, Treasurer” and “Jeanne Brennan, Accountant”.1920

The well

Within weeks of the account opening, Cypress, Inc. was the named owner in a New Mexico contracting exercise. A bid schedule headed “REQUEST FOR BIDS / CYPRESS, INC. / PRODUCTION WELL (6-INCH CASING)” was completed and returned by HydroGeologic Services, Inc. of Albuquerque under New Mexico driller’s licence WD-1472, itemising thirteen lines from mobilisation to a permanent pump and controls and totalling $110,996.00; a second schedule in the same set prices an optional alternative 8-inch casing.2122

The bids travelled to Epstein’s office under the subject line “Request for Bids - Santa Fe County, NM - Cypress, Inc.”, a line originating with the drilling firm on 3 May 2012.23 The consulting engineer Casey W. Cook, P.E., of Balleau Groundwater, Inc., forwarded them the next day to Brice Gordon, whose own signature block on that chain gives his place as Little Saint James, USVI: “Hydrogeologic Services sent the attached bid for the new well at Zorro Ranch. HGS estimates the 6-inch well would cost $110,996, and the 8-inch well would cost $123,816; both bids including a permanent pump. I expect to get a bid from Yellow Jacket Drilling later this afternoon, which I will forward to you. Stewart Brothers opted out of the project due to committed workload…”23 Gordon sent the chain onward on 9 May 2012, writing: “requesting approval to move forward with HGS as driller for new well / they are around 15k lower than Yellow Jacket Drillers / i,m proposing 6 inch casing with 100 gpm pump, $110,996.00 … Can you please get approval ASAP, would like to meet with Bill on sight before i leave”.23

Epstein answered on 19 May 2012: “why not go 8 inches? benefits, burdens? time frame , we need additional equiptment to and from new site don’t we?”24 The reply he received, from the sender the export renders as BMG, was that “Single phase power already at sight therefore 100 gpm pump 6 inch casing / Anything bigger will require 3 phase power / 3 phase only at existing Dakota well / 3 week lead time / Would use existing infrastructure Controls, power etc to keep cost down / Will need to lay electric and pipe 800 ft / To connect to existing infrastructure”.24 Epstein forwarded that exchange to Craig Martin and Richard Kahn on 20 May 2012.24

The larger well was what went ahead. On 17 July 2012 Cook wrote to Kahn that the drilling firm “sent the attached revised draft contract with a price adjustment on the 8-inch screen,” that “the drilled and constructed depth may be less than the planned 800 feet depending on determination in the field of the final depth,” that “I understand HGS will invoice Cypress, Inc for the actual footage drilled and cased on the basis of the proposed unit prices,” and closed: “I recommend Cypress, Inc. award the contract to Hydrogeologic Services for drilling the 8-inch well at Zorro Ranch because of their lower bid price and earlier availability than the other responsive bidder (Yellow Jacket Drilling), and for their previous experience drilling a similar well into the target formation at the Ranch.”25 Kahn forwarded that recommendation to Epstein the same day with a covering note: “I just spoke with the owner Bill Whaley who was reluctant to discount his pricing any further than the $1,600 offered in this email. I was able to persuade him to agree to a total discount of $6,000 which represents a 4.85% discount from original quote. Accordingly their price to drill would be $117,221 / They will be ready to start next week around July 25th + or - a day.”26 It goes on: “Please note that this quote is priced for the full 800 feet of drilling / If we only drill 700 feet then the cost will be reduced by approximately $6,300”.26 The note sets out other costs beyond the driller’s, being a consultant to oversee the job and file reports at about $12,500, of which $9,000 had already been incurred and paid in 2012, and an electrical contractor at about $17,500, and gives an “Estimated total drilling costs with gross receipts tax: $165,974”, adding “darren is looking into why gross receipts is applicable.”26 Epstein’s reply, the same day, was “ok”.26

Weeks later a hole was plugged. A Well Plugging Plan of Operations filed with the New Mexico Office of the State Engineer names Cypress, Inc. as the owner of well E-7871-S, gives the mailing address as care of HydroGeologic Services, Inc., names that firm as the driller contracted to provide plugging services, and enters the depth of the well as 800 feet.2728 Two copies of the form are in the same run, and their “Reason(s) for plugging well” fields differ. The copy received-stamped by the State Engineer’s Albuquerque office in August 2012 reads “Drilling a new and encountered a dry hole”; the copy marked REVISED and received-stamped in September 2012 reads “Drilled 12” borehole to 800 feet using mud rotary method / consultant declared borehole did not produce enough water therefore well casing was never set.”2827

No document cited here states that the plugged well is the well the July contract covered, and this page does not treat them as the same hole.

A further well is on the record as productive. On 2 October 2012 Cypress, Inc. filed an Application for Permit to Change an Existing Water Right, signed for the applicant by Frank M. Bond, Attorney at Law; the supplemental page states that “[t]his application is being filed to effect the Settlement Agreement between Applicant and Water Rights Division of the New Mexico State Engineer executed on November 1, 2010” and that “[t]he applicant under exploratory well permit number E-7871-POD4 has encountered a groundwater supply sufficient to address the requirements of the Settlement Agreement.”29 The State Engineer approved it. On 7 January 2013 the office wrote to “ATTN: Mr. Brice Gordon, Cypress, Inc., 49 Zorro Rancho Road, Stanley, NM 87056” enclosing “the enclosed Permit to Change Location of Well, which has been approved subject to the attached Conditions of Approval,” over the name of a water resource specialist.30 The Conditions of Approval name the permittee as Cypress, Inc. under permit E-7871, with an application file date of October 2, 2012, notice for publication of October 3, 2012, affidavits of publication in the Mountain View Telegraph on October 26, 2012 and the Santa Fe New Mexican on December 3, 2012, and a priority of November 20, 2000; the purpose of use is “Domestic, livestock, irrigation, and ranch-related purposes, which include wash down of facilities and equipment, dust suppression, and other ranch property maintenance activities,” and the amount of water is “68 acre-feet per annum from all sources under file no. E-7871 combined.”3132

Money in, taxes out

Cypress, Inc. was funded by wires from Epstein. A memorandum on Jeffrey E. Epstein’s letterhead dated November 12, 2012, from Harry Beller to “Janet, JP Morgan”, reads “Please wire Sixty Two Thousand Five Hundred Dollars (S62,500) from the above account to:”, gives the receiving institution as “FirstBank, Puerto Rico, 1518 Ponce Deleon Ave, PO 9146 San Juan 00908”, enters “For further credit to: Cypress, Inc.”, and gives the reference as “1st Half – New Mexico Real Estate Taxes.”33

Later payments went by Fedwire from Epstein’s Deutsche Bank account. Six Fedwire Receive Credit Advices in the release, each certified by FirstBank as a true and exact copy of the original, show credits to Cypress, Inc. at FirstBank Puerto Rico from an originator entered as “JEFFREY EPSTEIN, C/O HBRK ASSOCIATES, INC, 575 LEXINGTON AVENUE, 4TH FLOOR, NEW YORK, NY 10022” at Deutsche Bank Trust Company Americas: $100,000.00 on 17 March 2016, $100,000.00 on 4 April 2017, $100,000.00 on 24 October 2017, $100,000.00 on 7 November 2018, $175,000.00 on 22 February 2019 and $100,000.00 on 29 March 2019.34

The October 2017 wire drew a compliance inquiry. On 1 November 2017 Deutsche Bank’s private wealth management AML compliance unit wrote to the relationship officers on the account, marked High importance and “For internal use only”, identifying the activity as “10/24/2017, $100,000.00, from account [redacted] - JEFFREY EPSTEIN to CYPRESS, INC at FIRSTBANK PUERTO RICO (PUERTO RICO)” under “Alert No. 80825 - DUE November 8”, and asking three questions: “Please explain the purpose of this Outgoing Wire. Please explain the relationship between the Client and Counterparty. Please explain the business activities of the Counterparty.”35 It set a deadline: “Your complete response must be received within 5 business days.”35

The answer came on Friday, 3 November 2017 at 11:41 Eastern Daylight Time, the zone being taken from the reply’s own date header, which reads “-0400”, from an assistant vice-president in Deutsche Bank Wealth Management, who wrote “The client has provided the following responses to your below inquiries”:

  1. The purpose of this outgoing wire is to fund Mr. Epstein’s Cypress Inc account at FirstBank Puerto Rico which he solely owns

  2. This corporation currently holds the title to one of Mr. Epstein’s properties in Puerto Rico

  3. This wire was used to pay the real estate taxes for his Puerto Rico properties36

Those answers place the corporation’s property, and the taxes the wire paid, in Puerto Rico. The documents cited above place the property in Santa Fe County, New Mexico, and the 2012 wire memorandum for the same corporation at the same bank gives its reference as New Mexico real estate taxes.1333 This page reports the difference and does not resolve it; nothing cited here explains it, and no document cited here records the bank asking a further question.

What the corporation reported to the Virgin Islands

Cypress, Inc. filed annual reports with the Office of the Lieutenant Governor, Division of Corporations and Trademarks. The first, dated June 30, 2012 and covering the fiscal year ended December 31, 2011, enters “First Report” against the field for the fiscal year covered by the last report filed; gives the resident agent as Erika Kellerhals at the Havensight address; and lists Epstein as President/Director, Kahn as Treasurer/Director and Indyke as Vice President and Secretary/Director. On that copy the verification rules beneath the word VERIFIED, captioned President or Vice President and Treasurer or Asst. Treasurer, carry no signature.6

The following year’s filing is in the release with its financial statements attached. The annual report is dated 6/30/2013 for a tax closing date of 12/31/2012; its printed DATE OF INCORPORATION reads 4/12/2011, and that entry is circled in blue ink with “11/22/11” written beside it in the same ink.7 The franchise tax report filed with it gives the date of incorporation as 11/22/2011 and the nature of business as “Holding Property for Personal Use”, computes the tax at $150.00, and carries printed names but no signature on either the Treasurer or the President rule.3 The balance sheet submitted with them reads:

Cypress, Inc. / BALANCE SHEET / As of December 31, 2012 / PROPERTY $ 1,000 / TOTAL ASSETS $ 1,000 / STOCKHOLDER’S EQUITY / Paid in capital stock $ 1,000 / TOTAL LIABILITIES AND STOCKHOLDER’S EQUITY $ 1,000

and beneath it, under the heading “STATEMENT OF INCOME AND RETAINED EARNINGS / For the year ended December 31, 2012”, the words “NO ACTIVITY for the Year Ended December 31, 2012.”37

The same run holds the corporation’s internal accounts for that year, printed on 06/07/13 on an accrual basis. Its balance sheet as of December 31, 2012 gives a First Bank balance of 3,221.37 against 0.00 a year earlier, total assets of 3,221.37, and under equity: Capital Stock 1,000.00, Stockholder distributions 62,500.00 and Net Income -60,278.63.38 Its profit and loss statement for January through December 2012 gives income of 0.00 and expenses of Banking Fees 80.50, Office Supplies 179.98 and Property Tax 60,018.15, for a total expense of 60,278.63 and a net income of -60,278.63.39

The corporation’s last such filing was made after Epstein’s arrest. The Virgin Islands Franchise Tax and Annual Report Filing 2019 for CYPRESS, INC. (581974) is stamped by the Lieutenant Governor’s office “Filed: July 31, 2019 10:05 AM”; it gives the amount of capital as 1,000.00 and the highest capital amount during the reporting period as 1,000.00; lists Epstein as President, Indyke as Secretary and Kahn as Treasurer, each Active and each with a term expiration of “Perpetual”; and against the question “Did the entity have Economic Activity during the reporting period?” enters “No.”98 The signature block names Erika Kellerhals as “Attorney in Fact” signing on behalf of the President, Jeffrey Epstein, dated 07/31/2019, and Richard Kahn as Treasurer, dated 07/31/2019. A declaration reading “I DECLARE, UNDER PENALTY OR PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH” stands on the same sheet under a separate block and not over those two signatures; the field ends at that word and the continuation is not in the run.40 The printout was generated from the Lieutenant Governor’s system on February 21, 2020 and bears a handwritten exhibit sticker numbered 26; the page does not say who marked it.9 A 2019 Santa Fe County property tax bill, over the name of the county treasurer, sits on the page immediately after that filing in the same run.41

The Government of the Virgin Islands afterwards pleaded that these filings were false. Its second amended complaint against the estate alleges that “[t]he financial statements submitted by each of these three Defendant corporations to the Office of Lieutenant Governor of the Virgin Islands were false and misleading due to their failure to include the above properties owned by each company or the related expenses incurred by each company, such as property taxes,” and, as to this corporation, that “Cypress’s Balance Sheet as of December 31, 2018 did not reflect any assets other than cash of $18,824” and that “Cypress reported only $301 in expenses for the year ended December 31, 2018”; that “in 2017, Cypress reported as its only asset cash in the amount of $29,736 and expenses of $150”; and that “for the tax years 2011 through 2016, Cypress did not include the value of the New Mexico property in the total assets it reported and did not include any expenses related to the New Mexico property in the total expenses it reported to the Government.”42 In each of the two paragraphs alleging what the corporation was paying while it reported those figures, the sum is covered by a black bar on the filed copy.42 Those are the Government’s pleaded allegations in a civil action and were not adjudicated; the settlement of that action, and the estate’s denial of wrongdoing, are set out on Laurel, Inc.

One of a set

The corporation was formed alongside others. The Government’s second amended complaint pleads that Cypress, Inc. “is a Virgin Islands corporation that was formed and first licensed in or about November 2011” and “owns the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or about December 2011, shortly after it was incorporated”; the two paragraphs that follow plead the same formation month, the same three officers and a December 2011 transfer for Maple, Inc. as to 9 East 71st Street and for Laurel, Inc. as to the Palm Beach property.1343

The corporate filings bear that out on their face. The run holding Cypress’s 2013 filing holds the same set of papers, being an annual report, a franchise tax report, a balance sheet and a franchise tax cheque, for six further companies. The balance sheet filed for the year ended December 31, 2012 by Nautilus, Inc, the company that held Little St. James, is set out in the same words and the same figures as Cypress’s, down to the line “NO ACTIVITY for the Year Ended December 31, 2012”; the balance sheets in the same run for Laurel, Inc., Maple, Inc., Poplar, Inc and Mort, Inc. read the same in their asset lines, and the one for CDE, Inc. gives its single asset line as “STOCK SUBSCRIPTION RECEIVABLE $ 1,000” above the same total and the same closing line.44

The banking arrangement was shared too. A Deutsche Bank Elite Checking statement for Jeffrey Epstein covering March 1 to March 31, 2019 carries a run of seven consecutive entries headed “Outgoing Money Trnsf / TO FIRSTBANK PUERTO RICO A/C” naming, in this order, LSJE LLC, MAPLE, INC., GREAT ST JIM LLC, LAUREL, INC., MICHELLE’S TRANSPORT CO. LLC, NAUTILUS, INC and CYPRESS, INC., standing beneath a run of seven bare “03-29” lines.45 The copy of that page in the release is a reconstruction rather than a photograph, and it carries no amount column; the figures for that day are not taken from it. On that copy the dates stand in a stack of their own, separated from the description blocks, and no row-to-date alignment is printed on the sheet, so reading those seven entries as entries of 29 March is an inference from the order of the two stacks and not something the sheet states.45 The Fedwire advice for 29 March 2019 gives the credit to Cypress, Inc. on that date as $100,000.00.34

What the record here does not show

The documents cited here establish when the corporation was formed and by whom, who its officers were, what it told its bank at the account opening, what it commissioned and was permitted to do in New Mexico, how money reached it and what it reported to the Virgin Islands. They name the holder of its shares as a trust and go no further: the Form 2553 enters “Jeffrey Epstein, Trustee of Cypress I Trust” as the consenting shareholder, and no instrument creating or governing either the Cypress I Trust or the Cypress II Trust is among the documents this page found. The phrase “Cypress I Trust” returns two pages, that form and the estate-office index; “Cypress II Trust” returns one, the index alone; “Cypress” together with “stock certificate” returns one page, again the index; “Cypress” together with “subscription agreement” returns two; and “Cypress” together with “shareholder” returns five, of which two are the pages of that form and one is the corporation’s own bylaws, the remaining two using the word of a Florida street and of a consulting firm named in an unrelated private placement memorandum.46 They do not show whether the United States Virgin Islands business licence referred to in the April 2012 affidavit was ever applied for or obtained, or whether a copy was delivered to the bank; the affidavit is the last word on the subject in the documents cited here.12 They do not show what the corporation’s later balance sheets said in their own words: the figures for 2017 and 2018 are given here as the Government’s pleading gives them, the corporation’s own statements for those years are not among the documents this page found, and the sums the pleading says the corporation was paying in those years are covered on the filed copy.42 They do not show whether the corporation was ever dissolved, or what became of its shares after 2019; searching “Cypress” together with “dissolved” returns one page, and it is that same private placement memorandum. Appearing in these documents is not evidence of wrongdoing by any person named on this page.

Zorro Trust; Zorro Ranch; Laurel, Inc.; Nautilus, Inc.; Darren Indyke; Richard Kahn; HBRK Associates; Jeffrey Epstein estate.

Notes

No account number or routing number is reproduced on this page.

Footnotes

  1. “ARTICLES OF INCORPORATION OF CYPRESS, INC.,” Articles I to III. Read at the image. https://epstein-data.com/EFTA01269354 p.17. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  2. Same instrument, signature page and Virgin Islands acknowledgment. Read at the image at 400 dpi: the printed date reads “this 21st day of November, 2011”; each of the three rules captioned “Erika A. Kellerhals, Incorporator”, “Gregory J. Ferguson, Incorporator” and “Brett Geary, Incorporator” is crossed by a pen stroke; the notarial stamp beneath reads Gina Marie Bryan, St. Thomas/St. John, USVI. https://epstein-data.com/EFTA01269354 p.23. The three names on this page were read at the image before being printed here. ↩ ↩2

  3. Same office, “FRANCHISE TAX REPORT – DOMESTIC CORPORATION,” Cypress, Inc., today’s date 6/30/2013, tax closing date 12/31/2012. Read at the image at 400 dpi: DATE OF INCORPORATION reads 11/22/2011 and NATURE OF BUSINESS reads “Holding Property for Personal Use”; section 6 gives $150.00; the rules captioned SIGNATURE under TREASURER and under PRESIDENT are blank, with “Richard Kahn” and “Jeffrey E. Epstein” appearing on the PRINTED FIRST NAME AND LAST NAME lines beneath them. The tax identification number on that page is not reproduced here. https://epstein-data.com/EFTA00313152 p.2. The company’s $150.00 franchise tax cheque, drawn on FirstBank St. Thomas and dated 6/11/2013 to the Government of the Virgin Islands, is at p.4. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  4. FirstBank, “Customer Due Diligence / Business Accounts / Virgin Islands,” client information sheet for CYPRESS, INC. Read at the image: the fields quoted are printed entries on the form. The account number, tax identification number, social security number and date of birth fields on that page are covered by black bars. Residential address information on that page is not reproduced here. https://epstein-data.com/EFTA01269354 p.6. Signature cards for the same corporation are at p.4 of the same run. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  5. “Consent of Agent for Service of Process,” Kellerhals Ferguson LLP as designated agent of Cypress, Inc., signed the 21st day of November 2011. https://epstein-data.com/EFTA01269354 p.24. The bylaws of the corporation follow at p.25. ↩ ↩2

  6. United States Virgin Islands, Office of the Lieutenant Governor, “ANNUAL REPORT ON DOMESTIC OR FOREIGN CORPORATIONS,” Cypress, Inc., fiscal year covered December 31, 2011, dated June 30, 2012. Read at the image at 300 dpi: the entries are typed on the printed rules, and the rules captioned “(PRESIDENT OR VICE PRESIDENT)” and “(TREASURER OR ASST. TREASURER)” beneath the word VERIFIED carry no signature. Address information on that page is not reproduced here. https://epstein-data.com/EFTA00284691 p.25; the accompanying franchise tax report is at p.26. ↩ ↩2 ↩3 ↩4 ↩5

  7. Same office, “ANNUAL REPORT – DOMESTIC AND FOREIGN CORPORATION,” Cypress, Inc., today’s date 6/30/2013, tax closing date 12/31/2012. Read at the image at 400 dpi: the printed DATE OF INCORPORATION entry reads 4/12/2011 and is circled in blue ink, with “11/22/11” written beside it in ink of the same colour, in strokes of varying weight sitting off the printed baseline. The addresses entered for two of the three officers, and the Lieutenant Governor’s own telephone and fax numbers, are covered by black bars on this copy. The tax identification number on that page is not reproduced here. https://epstein-data.com/EFTA00313152 p.1. ↩ ↩2

  8. Same filing, page 2 of 4, “Directors/Officers” and “Documents.” Read at the image at 300 dpi: the entry against “Did the entity have Economic Activity during the reporting period?” reads No. The physical addresses given for two of the three officers, and all three e-mail addresses, are covered by black bars. https://epstein-data.com/EFTA00076491 p.83. ↩ ↩2

  9. The United States Virgin Islands, “Franchise Tax and Annual Report Filing 2019, CYPRESS, INC. (581974),” USVI Lieutenant Governor, “Filed: July 31, 2019 10:05 AM”, printout generated February 21, 2020, page 1 of 4. Read at the image at 300 dpi: an exhibit sticker at the foot carries a handwritten 26, and the page does not name the proceeding or the party that marked it. The tax identifier number is covered by a black bar. https://epstein-data.com/EFTA00076491 p.82. Page 1 of that run is the estate’s Verified Inventory in the Virgin Islands probate, Probate No. ST-19-PB-80. ↩ ↩2 ↩3

  10. Same form, page 2, “Part I Election Information (continued),” columns J to N. Read at the image at 400 dpi: one row of the table is completed and the rows beneath it are blank; within the completed row the Signature and Date cells under column K carry no entry. Identity and tax numbers on that page are not reproduced here. https://epstein-data.com/EFTA00316603 p.2. Part II of the form is at p.3. ↩ ↩2

  11. “Business Verification Results,” a screening print run against the account file. Read at the image at 400 dpi: the sheet is headed “Page 1 of 2” and carries, in order, the results summary, three result boxes with their input entries, an Alternative Verifications box, an “Additional Actions taken” box, the override comment and the account status; the boxes enumerated in the text are all of them. The input entry against EIN: FAILED is covered by a black bar. Page 2 of 2 of the same print, at p.11 of the run, carries only the consumer-report notice and no further result. The employer identification number on that page is not reproduced here. https://epstein-data.com/EFTA01269354 p.10. A second copy of the same screen stands in another run of the same FirstBank production, at https://epstein-data.com/EFTA01269393 p.7, and reads the same in the passages quoted. ↩ ↩2

  12. “AFFIDAVIT RE NOT DOING BUSINESS” of Darren Indyke as Secretary of Cypress, Inc. Read at the image at 400 dpi: the witness clause is printed “this 18th day of April, 2012”; on the “SUBSCRIBED AND SWORN” line the day and the month are entered in ink, in strokes of varying weight sitting off the printed rule; a pen signature crosses the rule captioned “Darren Indyke” and a second crosses the rule captioned “Notary Public”, above a stamp reading HARRY I. BELLER, Notary Public, State of New York. https://epstein-data.com/EFTA01269354 p.16. ↩ ↩2 ↩3 ↩4 ↩5

  13. Government of the United States Virgin Islands v. Estate of Jeffrey E. Epstein et al., Superior Court of the Virgin Islands, Case No. ST-20-CV-14, Second Amended Complaint, exhibited in the territory’s federal case against JPMorgan Chase — Cypress, Inc. at ¶38. https://epstein-data.com/EFTA00161836 pp.43–44. ↩ ↩2 ↩3

  14. Same instrument, Articles IV to VII, giving the authorised stock, the minimum capital, the incorporators and perpetual existence. https://epstein-data.com/EFTA01269354 p.18. ↩

  15. Internal Revenue Service notice, Cincinnati, “WE ASSIGNED YOU AN EMPLOYER IDENTIFICATION NUMBER,” addressed to CYPRESS INC, 9100 Havensight 15 16, St. Thomas. Read at the image at 400 dpi: “Date of this notice: 12-15-2011”, “Form: SS-4”, “Number of this notice: CP 575 A”, and under the forms to be filed, “Form 1120 / 03/15/2012”. The text layer of this page renders that date as 12-15-2021 and that due date as 01/15/2012; both were read at the image. The employer identification number is covered by black bars in two places on the page and is not reproduced here. https://epstein-data.com/EFTA01269354 p.9. ↩

  16. Internal Revenue Service Form 2553 (Rev. December 2007), “Election by a Small Business Corporation,” for Cypress, Inc., page 1. Read at the image at 400 dpi: the entries are machine-set form-fill in blue, the tick at item F(1) is a check glyph and items F(2) to F(4) are empty squares, and the “Sign Here” block at the foot carries no signature, title or date. This copy is a rendering rather than a photograph, and this page found no photographed sibling of it. Identity and tax numbers and telephone numbers on that page are not reproduced here. https://epstein-data.com/EFTA00316603 p.1. ↩

  17. Estate-office index of file contents, listing folder tabs by title under a heading for each file. Read at the image under the heading “CYPRESS INC Organizational”. https://epstein-data.com/EFTA00299927 p.23. ↩ ↩2

  18. FirstBank “Virgin Islands / Corporate Resolution” for Cypress, Inc., certified by the Secretary. Read at the image at 400 dpi: in the table headed Name / Office / Signature, “Jeffrey Epstein” stands against President, “Darren Indyke” against Secretary and “Richard Kahn” against Treasurer, each with a pen signature on the corresponding rule in the Signature column; the name rule and the signature rule opposite Vice President are both blank. The witness clause is dated with the day entered in ink as 19 and the month and year printed as April, 2012; it is signed as Secretary and attested “Attest (Second Officer)” over the printed title Treasurer. https://epstein-data.com/EFTA01269354 p.37; the resolutions themselves begin at p.36. ↩ ↩2

  19. FirstBank “Corporate Resolutions For Telephone/Telex/Facsimile/Written Instructions,” Cypress, Inc., recording a meeting of the board of directors held at American Yacht Harbor on the 5th day of April 2012. https://epstein-data.com/EFTA01269354 p.38. ↩

  20. FirstBank “Corporate Authorization and Indemnity Agreement For Telephone/Telex/Facsimile/Written Instructions,” Cypress, Inc., naming the call-back individuals as “Jeffrey Epstein, President”, “Richard Kahn, Treasurer” and “Jeanne Brennan, Accountant”, and executed for the account holder by “Darren Indyke, Secretary”. Telephone numbers on that page are not reproduced here. https://epstein-data.com/EFTA01269354 p.39. ↩

  21. “REQUEST FOR BIDS / CYPRESS, INC. / PRODUCTION WELL (6-INCH CASING),” bid schedule completed by HydroGeologic Services, Inc., NM License No. WD-1472. Read at the image at 300 dpi; the unit and total prices quoted, and the total of 110,996.00, are printed entries in the Unit Price and Total Price columns. The pump note reads “20 HP/100 GPM pump set @ 504’ on 2.5” galv. drop pipe w/control panel”; the text layer of this page renders that figure as 120 HP. https://epstein-data.com/EFTA01147503 p.1; the supplemental information sheet is at p.2. A second copy of the same schedule is at https://epstein-data.com/EFTA01147487 p.1, and the figures given here are read from the first. ↩

  22. “REQUEST FOR BIDS / CYPRESS, INC. / PRODUCTION WELL (OPTIONAL ALTERNATIVE 8-INCH CASING),” in the same set. https://epstein-data.com/EFTA01147503 pp.3–4. ↩

  23. Forwarded chain under the subject line “Request for Bids - Santa Fe County, NM - Cypress, Inc.” Read at the image: the Casey Cook message is dated Fri, May 4, 2012 to brice gordon; the message beginning “requesting approval to move forward with HGS” is the body of brice gordon’s message of Wed, May 9, 2012 to Craig Martin, copied to Zorro Ranch, whose header stands at the foot of the preceding page; the chain originates with a message from Esperanza Cordova of HydroGeologic Services dated Thu, May 3, 2012 to “Casey W. Cook”. Correspondents’ e-mail addresses on this page are covered by black bars. https://epstein-data.com/EFTA01884360 p.2, headers at p.1. The transmittal from the firm is at p.3, read at the image at 400 dpi: its body states that the attached proposal was prepared by Bill W. Whaley, C.P.G., Hydrogeologist, and the subscription line beneath is entered as Esperanza Meis for Bill W. Whaley — a surname differing from the one the 3 May header on p.2 gives, and neither page gives that sender a job title. Brice Gordon’s own signature block stands lower on p.3 and gives his place as Little Saint James, USVI, with the telephone line covered by a black bar. ↩ ↩2 ↩3

  24. Same chain, top sheet. Read at the image: the export’s top-of-message “Sent” field carries no time zone and reads earlier in the day than the forwarded message beneath it, so this page gives dates from this document and no clock times. Epstein’s quoted message of May 19, 2012 and brice gordon’s of the same date are quoted in the body; the reply beginning “Single phase power” is from the sender the export renders as BMG, dated May 20, 2012, to Epstein; Epstein forwarded the chain to Craig Martin and Richard Kahn on May 20, 2012. https://epstein-data.com/EFTA01884360 p.1. Further copies of parts of the same chain are at https://epstein-data.com/EFTA01881347 p.1, https://epstein-data.com/EFTA02025731 p.1 and https://epstein-data.com/EFTA00686268 p.1; the last carries an RFC date header reading “Sat, 19 May 2012 14:18:06 +0000” for gordon’s message, which the other copies render as 4:18 PM, and that disagreement is the reason no clock time is printed here. ↩ ↩2 ↩3

  25. Casey W. Cook, P.E., Balleau Groundwater, Inc., to Richard Kahn, copied to brice gordon, “Fwd: Zorro Ranch Revised,” dated July 17, 2012 10:17:42 AM EDT on the message’s own header. Read at the image: correspondents’ e-mail addresses and the block beneath Cook’s firm name are covered by black bars. The drilling firm’s revised draft contract is an attachment referred to in this message and is not itself in this document. https://epstein-data.com/EFTA01875410 p.2. ↩

  26. Richard Kahn to Jeffrey Epstein, forwarding the message above, with Epstein’s reply “ok” at the head of the sheet, July 17, 2012. Read at the image. The top-of-message “Sent” field on this export carries no zone; dates only are given here. https://epstein-data.com/EFTA01875410 p.1. ↩ ↩2 ↩3 ↩4

  27. New Mexico Office of the State Engineer, “WELL PLUGGING / PLAN OF OPERATIONS,” marked REVISED, for well E-7871-S, owner Cypress, Inc. Read at the image at 400 dpi: the entries in sections II to IV are machine-printed on the rules, of uniform stroke weight; a rotated received stamp of the State Engineer Office, Albuquerque, sits in the right margin and reads 2012 SEP. The owner’s telephone number and e-mail address, and the driller’s licence number, are covered by black bars on this copy. https://epstein-data.com/EFTA00309241 p.1. ↩ ↩2

  28. The earlier copy of the same form in the same run, without the REVISED marking, whose rotated received stamp reads 2012 AUG 27. Read at the image at 400 dpi. The owner’s telephone number and e-mail address are covered by black bars on this copy as on the other. https://epstein-data.com/EFTA00309241 p.2. ↩ ↩2

  29. New Mexico Office of the State Engineer, “APPLICATION FOR PERMIT TO CHANGE AN EXISTING WATER RIGHT (Non 72-12-1),” Cypress, Inc., acknowledgment naming Frank M. Bond, Attorney at Law, as the applicant signing; supplemental page headed “Cypress, Inc.’s Application for Permit to Change an Existing Water Right, OSE File: E-7871-S-2 under E-7871 et al.” https://epstein-data.com/EFTA00309073 pp.7–8. Further copies of the application form appear at https://epstein-data.com/EFTA01083169 p.1 and https://epstein-data.com/EFTA00589044 p.1; the quotations here are taken from the copy in the permit file. ↩

  30. State of New Mexico, Office of the State Engineer, District I, Albuquerque, to Mr. Brice Gordon, Cypress, Inc., 49 Zorro Rancho Road, Stanley, NM, January 7, 2013, “OSE Permit No. E-7871,” over the name of David B. Anderson, Water Resource Specialist Senior. https://epstein-data.com/EFTA00309073 p.1. ↩

  31. Same file, “Permit No. E-7871 / Page 1 of 2 / CONDITIONS OF APPROVAL.” Read at the image at 300 dpi. https://epstein-data.com/EFTA00309073 p.9. ↩

  32. Same permit, page 2 of 2, giving the purpose of use, place of use and amount of water. https://epstein-data.com/EFTA00309073 p.10. ↩

  33. Memorandum on Jeffrey E. Epstein letterhead, from Harry Beller to “Janet, JP Morgan”, dated November 12, 2012, produced by JPMorgan Chase under a request for confidential treatment. Read at the image on the copy that is a photograph of the sheet, which carries paper grain, skew and a pen signature beside Beller’s printed name. Account numbers on this page are not reproduced here. https://epstein-data.com/EFTA01580483 p.1. A second copy of the same memorandum, at https://epstein-data.com/EFTA01590184 p.4, is not a photograph but uniform machine type on a clean white field with the redactions applied as rectangles; it renders the addressee as “JP Morgai” and the subject line as “Jefftey Epstein”. The transmittal covering the group of wires, from Richard Kahn to a JPMorgan service desk copied to Beller and headed “re: wires (4) 11-13-2012”, is at p.1 of that second run. ↩ ↩2

  34. Six “FEDWIRE RECEIVE CREDIT ADVICE (ADVICE WITHOUT SIGNATURE)” forms addressed to CYPRESS, INC at Red Hook Qtr B3, St. Thomas, each carrying a blue FirstBank stamp reading “RECORDS & LEGAL REQUIREMENTS / CERTIFIED TO BE A TRUE AND EXACT COPY OF THE ORIGINAL” over a signature. Dates and credit amounts as given in the text. Read at the image on p.3, the advice for 24 October 2017; the remaining five were read in the text layer of the same run and agree with it in form. Account numbers and bank routing numbers on these pages are not reproduced here. https://epstein-data.com/EFTA01273143 pp.1–6. ↩ ↩2

  35. Deutsche Bank PWM AML Compliance, “Inquiry Regarding Account [redacted], Client: JEFFREY EPSTEIN; Alert No. 80825 - DUE November 8”, sent on behalf of Amlcompliance Inquiries to the two officers on the account, November 1, 2017, marked Importance: High. Read at the image; the account number, correspondents’ e-mail addresses and a fax number are covered by black bars, and the sheet carries the Bates stamps DB-SDNY and SDNY_GM. The top-of-message “Sent” field carries no zone, and no clock time from it is printed here. https://epstein-data.com/EFTA01368675 p.1. The same inquiry is quoted below the reply at https://epstein-data.com/EFTA01415326 p.2. ↩ ↩2

  36. Reply of the relationship officer, an assistant vice-president at Deutsche Bank Trust Company Americas, Deutsche Bank Wealth Management, 345 Park Avenue, New York, “RE: Inquiry Regarding Account [redacted],” whose date header reads “Fri, 03 Nov 2017 11:41:04 -0400”. Read at the image: this copy is a rendering rather than a photograph — uniform monospaced type on a clean white field with the redactions applied as rectangles — and the three correspondents’ names it prints are corroborated by the separately produced copy of the inquiry cited above, which prints the same three names. Account numbers and e-mail addresses on that page are covered by black bars. https://epstein-data.com/EFTA01415326 p.1. ↩

  37. Balance sheet and statement of income and retained earnings for Cypress, Inc. as of and for the year ended December 31, 2012, filed with the annual report. Read at the image at 400 dpi. The quotation in the body is not the whole of the sheet: besides the tax identification line, an unlabelled subtotal of 1,000, ruled above and below and carrying no dollar sign, stands between the paid-in capital stock line and the total, and is not reproduced. An employer identification number on that page is not reproduced here. https://epstein-data.com/EFTA00313152 p.3. ↩

  38. “Cypress, Inc. / Balance Sheet / As of December 31, 2012,” printed 06/07/13, accrual basis, in the same run. Read at the image at 400 dpi: the Net Income line reads -60,278.63, with the minus sign present. https://epstein-data.com/EFTA00313152 p.5. The text layer of the second copy of this run, at https://epstein-data.com/EFTA00284828 p.5, drops that minus sign; the figures here are read from the image of the first. ↩

  39. “Cypress, Inc. / Profit & Loss / January through December 2012,” printed 06/07/13, accrual basis. Read at the image at 400 dpi. https://epstein-data.com/EFTA00313152 p.6. ↩

  40. Same filing, page 3 of 4, “Signature(s)” and “Daytime Contact.” Read at the image at 300 dpi. A telephone number and an e-mail address on that page are covered by black bars. https://epstein-data.com/EFTA00076491 p.84. ↩

  41. A 2019 property tax bill for Santa Fe County, New Mexico, over the names of the county treasurer and the chief deputy treasurer, standing in the same run on the page immediately after the three pages of the 2019 Virgin Islands filing cited above, which occupy pp.82–84 and are numbered on their own faces page 1 of 4, 2 of 4 and 3 of 4. Read at the image at 400 dpi: p.85 is that bill and carries a printed 2 at its foot, so it is not the filing’s fourth sheet; no sheet numbered page 4 of 4 stands between p.84 and p.86, where the next company’s filing begins in the text layer of the run. The text layer of that page is heavily degraded and no figure from it is quoted here. https://epstein-data.com/EFTA00076491 p.85. ↩

  42. Same complaint, ¶¶182–186 and ¶193. Read at the image at 300 dpi: in ¶184 and ¶185 the text following “despite it paying” is covered by black bars running to the end of the sentence. https://epstein-data.com/EFTA00161836 p.72; ¶193 and ¶194 at p.73. A further copy of the same complaint is at https://epstein-data.com/EFTA02805472 pp.9–10, 37–39. ↩ ↩2 ↩3

  43. Same complaint, ¶¶39–40, on Maple, Inc. and Laurel, Inc. https://epstein-data.com/EFTA00161836 p.44. ↩

  44. Same run, the balance sheets filed for the year ended December 31, 2012 with the annual reports of the other companies whose filings it holds: Nautilus, Inc at p.9, Laurel, Inc. at p.15, Maple, Inc. at p.21, Poplar, Inc at p.27, CDE, Inc. at p.31 and Mort, Inc. at p.35; the annual reports and franchise tax reports stand at pp.7–8, 13–14, 19–20, 25–26, 29–30 and 33–34, and a franchise tax cheque at pp.10, 16, 22, 28, 32 and 36. The same run also carries a second, differently headed pair of statements for four of the seven companies: an accrual-basis balance sheet and a profit and loss statement for the same year, for this company at pp.5-6 and for Nautilus, Laurel and Maple at pp.11-12, 17-18 and 23-24. A search of the extracted text of all thirty-six pages for the words that head them returns those eight pages and no others, so the three remaining companies have no such pair in this run. The Nautilus and CDE balance sheets were read at the image at 300 dpi; the rest of this list, including the eight pages just named, was read in the text layer of the run. Employer identification numbers printed on those pages are not reproduced here. https://epstein-data.com/EFTA00313152. ↩

  45. Deutsche Bank Trust Co. Americas statement, Elite Checking With Interest, Jeffrey Epstein, March 1, 2019 to March 31, 2019. Read at the image at 400 dpi: this copy is a rendering rather than a photograph — uniform monospaced type on a clean white field with black bars as applied rectangles — and the transaction rows on this page carry no amount column, the amounts and running balances standing on a separate page of the same run. The dates likewise fall into a stack of their own, with description blocks in another, so the assignment of a date to any row on this sheet is order inference and not something the sheet prints; that is the recorded behaviour of this class of reconstruction. Between the earlier date stack and the seven “03-29” lines the sheet carries intervening rows, among them a transfer to another bank and a cash withdrawal. Partial account numbers on that page are not reproduced here. https://epstein-data.com/EFTA01428610 p.8; the run’s first page, carrying the account holder and period, is at p.1. ↩ ↩2

  46. Searches run against the full-text index of the release, column-scoped and by phrase, on 8 September 2026: "Cypress I Trust" 2 pages; "Cypress II Trust" 1 page; "Cypress" with "stock certificate" 1 page; "Cypress" with "subscription agreement" 2 pages; "Cypress" with "shareholder" 5 pages; "Cypress" with "stockholder" 6 pages; "Cypress" with "sole stockholder" 1 page; "Cypress" with "certificate of dissolution" 0 pages. Whether an instrument of either trust is somewhere in the release under wording none of these reaches is not settled by this page. ↩

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