Epstein Data Wiki

Financial Trust Company, Inc.

Properties2
tagsentity, virgin-islands, epstein-company, banking
aliasesFinancial Trust Company, Financial Trust Co., Inc., The Financial Trust Company, FTC, TFTC

21 min read

TypeFor-profit corporation, U.S. Virgin Islands1
Articles filedNovember 6, 1998, with the Lieutenant Governor of the Virgin Islands1
Principal office at incorporation41–42 Kongens Gade, St. Thomas; resident agent Paul Hoffman2
Later address of record6100 Red Hook Quarter B-3, St. Thomas34
ShareholderJeffrey E. Epstein, holder of 500 of the 1,000 authorised shares5
Officers from September 2007President Darren K. Indyke; Vice President and Secretary Cecile De Jongh; Vice President and Treasurer Jeanne Brennan6
SubsidiaryJeepers, Inc. (USVI)7
SuccessorSouthern Financial, LLC; a March 2013 board consent resolved to merge Financial Trust into it8
Bank accounts closedJune–July 2013 (FirstBank); JPMorgan investment accounts at nil value from April 30, 2013910

Financial Trust Company, Inc. was a United States Virgin Islands corporation of Jeffrey Epstein’s, whose articles of incorporation were filed on November 6, 1998. It held an investment portfolio at JPMorgan, issued him the only W-2 he produced to the Palm Beach Sheriff’s Office in support of his work release application, and was the address of record on his personal bank statements.1113 Epstein was its sole shareholder and, at the outset, its president; he resigned both directorship and presidency in September 2007, and Darren Indyke, Cecile De Jongh and Jeanne Brennan became its directors and officers.5126 It was a beneficiary of the Virgin Islands Economic Development Commission programme.13 In March 2013 its securities were delivered to Southern Financial, LLC and its board resolved to merge the company into that entity; its bank accounts were closed over the following months.1489

Incorporation and charter

The Lieutenant Governor of the Virgin Islands, Kenneth E. Mapp, certified that Financial Trust Company, Inc. filed articles of incorporation in his office on November 6, 1998; the certificate itself is dated November 30, 1998.1 The articles put the corporation’s principal office at 41–42 Kongens Gade, St. Thomas, with Paul Hoffman as resident agent, and stated its first purpose as being

To provide financial counseling and investment advice to clients both within and without the United States Virgin Islands, including serving as trustee and/or fiduciary for such clients and others.2

The corporation was authorised to issue 1,000 shares of common stock of no par value, with no preferred stock, and the minimum capital with which it was to commence business was $1,000.2 Its by-laws fixed the board at three directors.2 Stock certificate No. 1, dated November 6, 1998, records Jeffrey E. Epstein as the owner of five hundred shares, half the authorised issue, and is signed by Epstein as president and Darren K. Indyke as secretary.5

The name of the company postdates the business, and accounts of when it moved differ. Deutsche Bank’s know-your-customer file records: “In 1982, Epstein founded his own financial management firm, J. Epstein & Co. … In 1996, Epstein changed the name of his firm to the Financial Trust Company and, for tax advantages, based it on the island of St. Thomas in the U.S. Virgin Islands.”15 A business plan prepared for a successor company’s Economic Development Commission application dates both events differently: “He later founded his own financial consulting firm in 1981, which he brought to the Virgin Islands in 1999 when he opened Financial Trust Company, Inc.”16 The corporate filing is of November 6, 1998.1

A separate and unrelated Florida company, Financial Trustees, Inc., was filed with the Florida Department of State on December 14, 1990 with “Epstein, Jeff” as registered agent at 358 El Brillo Way, Palm Beach; a commercial records report in the JPMorgan production lists it as inactive.17 It is not the Virgin Islands corporation and the two should not be conflated.

Officers and directors

Stock certificate No. 1 shows Epstein as president and Indyke as secretary at the corporation’s formation.5 The incorporation packet does not name the directors who served between the corporation’s formation and 2007.18

The reorganisation of September 21, 2007

Three signed instruments, faxed together on October 2, 2007, record a change of control of the company’s officers and board on September 21, 2007.

Epstein signed a one-sentence resignation: “The undersigned, Jeffrey E. Epstein, hereby resigns as a director and the President of Financial Trust Company, Inc., a United States Virgin Islands corporation, effective as of September 21, 2007.”12 A sole-shareholder consent signed by Epstein recites that the resignation left the corporation with two directors where the by-laws required three, and elects Darren K. Indyke, Cecile De Jongh and Jeanne Brennan as directors effective the same day, removing all others.19 A directors’ consent signed by all three then appointed Indyke as president, De Jongh as vice president and secretary, and Brennan as vice president and treasurer, and removed every other officer.6

Later documents nonetheless describe Epstein as the company’s president. A December 2008 letter from the U.S. Attorney’s Office for the Southern District of Florida called him “the founder and President of the Financial Trust Company, his for-profit corporation”,11 and a September 2012 business summary circulated for a successor company’s Economic Development Commission application described him as “the President and sole shareholder of an existing Economic Development Commission (‘EDC’) beneficiary, Financial Trust Company, Inc.”13

On March 8, 2010 the three directors signed a unanimous consent in lieu of meeting resolving that Indyke, “the President of the Corporation, acting singly”, was authorised to open and fully operate banking, custody and brokerage accounts at J.P. Morgan and to delegate that authority to other employees, officers or agents, “such authority to remain in full force and effect until any one of the President, a Vice President, the Treasurer or the Secretary of the Corporation, acting singly, sends J.P. Morgan written notice to the contrary.”20 The following day Indyke sent JPMorgan the signature page bearing De Jongh’s signature, and a bank officer replied asking for a signed W-9 from Epstein to complete the company’s tax documentation.21

Cecile De Jongh was married to John de Jongh, Governor of the U.S. Virgin Islands; a September 2019 Deutsche Bank presentation to the U.S. Attorney’s Office for the Southern District of New York described her as “the former First Lady of the U.S. Virgin Islands” and noted that his term ended in January 2015.22 Writing to a Virgin Islands official in February 2011 to arrange a meeting, she introduced herself: “You are probably aware that I work for Financial Trust Company, Inc. which is run and owned by Jeffrey Epstein.”23

Jeepers, Inc.

On March 30, 2007 an email over Darren K. Indyke’s signature block was sent to Ira Zicherman at Bear Stearns:

This is to certify that Financial Trust Company, Inc.(Bear Stearns Acct No. [redacted]), a USVI corporation, is the sole stockholder of Jeepers, Inc. (Bear Stearns Acct No. [redacted]), which is also a USVI corporation. As you know, Jeffrey E. Epstein (Bear Stearns Acct No. [redacted]) is the sole stockholder of Financial Trust Company, Inc. and, through his holdings of Financial Trust Company, Inc. stock, is the beneficial owner of Jeepers, Inc.7

A consent of the board of Southern Trust Company, Inc. dated March 19, 2013 repeats that Financial Trust was the sole shareholder of Jeepers, which had elected to be taxed as a qualified subchapter S subsidiary, and records that Financial Trust’s board had determined to transfer and distribute all of the Jeepers shares to Epstein, so that he would become its sole shareholder.8

Economic Development Commission benefits

Financial Trust was a beneficiary of the Virgin Islands Economic Development Commission programme. An undated application in its name, held in the Palm Beach corrections file, gives its mailing address as 6100 Red Hook Quarter, B-3, St. Thomas, its facility location as Red Hook Quarter #2 on St. Thomas, its local representative as the firm Hodge & Francois, and describes the business as a “Category IIA designated service business providing economic, scientific or management consulting services as defined in §703(g)(4), Title 29, Chapter 12, Virgin Islands Code.”4 As an extension applicant it sought a “Ten year extension at 100% of benefits.”24

A business summary drafted in September 2012 for the Economic Development Commission application of Southern Trust Company recorded that Financial Trust “was granted an extension of benefits in 2010”, and explained the creation of the new company thus: “The client base of and the product provided by the Applicant differ markedly from those of FTC, hence the desire to create a new entity that will meet all of the requirements of the EDC.”13 Circulating the draft to Epstein, De Jongh asked whether the existing employees of Financial Trust would be transferred to the new company; Epstein replied “me plus five is ok, yes africa , europe, . some employees may go”.13

The Economic Development Commission later audited the company. Forwarding its compliance reports to Epstein on February 4, 2014, De Jongh wrote that she had told an official at the authority “that we were never notified that we were being audited and never received a letter”, that the renewal certificate and its terms had not reached the company until October 14, 2010, and that the reports held it to a full year in 2012 “when we ceased operations in March, 2012.” Epstein replied the next morning: “what does he propose, this is not right”.25

Banking and investment accounts

FirstBank Virgin Islands

Responding on March 9, 2020 to a grand jury subpoena from the U.S. Attorney’s Office for the Southern District of New York, FirstBank in San Juan listed three commercial checking accounts in the company’s own name and two held by Little St James LLC care of it.9

Account holderAuthorised signaturesOpenedClosed
Financial Trust Company IncJeffrey Epstein; Darren K. Indyke2/5/20027/11/2013
Financial Trust Company IncJeffrey Epstein; Cecile R. De-Jongh5/1/20017/2/2013
Financial Trust Company IncDarren K. Indyke; Jeffrey Epstein2/3/20106/4/2013
Little St James LLC c/o Financial Trust Co IncJeffrey Epstein; Harry Beller; Ghislaine N. Maxwell10/22/98credits only
Little St James LLC c/o Financial Trust Co Incinformation not available7/16/19988/3/2012

The response was signed by Noraida Castro González, Senior Business Analyst in the bank’s Records and Legal Requirements Department.9

JPMorgan Chase

Epstein’s personal JPMorgan Private Bank statements were addressed to him care of the company: “JEFFREY E EPSTEIN / C/O FINANCIAL TRUST COMPANY / ATTN: JEANNE BRENNAN / 6100 RED HOOK QUARTER B-3 / ST THOMAS 00802 / VIRGIN ISLANDS”. The three statements cited here run from January 2003 to February 2006.32627 The company also held investment accounts at the bank in its own name; a January 2005 portfolio statement is addressed to it care of American Yacht Harbor at the same Red Hook address.28

Indyke used the company’s JPMorgan account to instruct payments to law firms. Signed memoranda on Financial Trust letterhead, sent to the bank by fax, asked it to “wire Forty Thousand Dollars & 00/100 ($40,000.00) from the above account” to an IOLTA trust account of John K. Dema, P.C. at the Bank of St. Croix on December 8, 2009, and to wire $112,237.40 to an account in the name of Kirkland & Ellis LLP on February 25, 2010.2930 Each document is an instruction to the bank rather than a record of a completed transfer.

A screenshot of JPMorgan’s Morgan Online administration tool, dated November 16, 2007, records the user identifier held by Richard Kahn and lists among its related accounts two in the name of Financial Trust Company Inc, both asset accounts.31

In January 2013 Harry Beller, listing available cash for Epstein, put the company’s balances across three accounts at $19 million, $11 million and $2.6 million.32 Monthly account summaries record the two Financial Trust investment accounts at a combined net market value of $68,761,748.84 at the start of October 2012 and $68,032,997.37 at the start of January 2013.3334

Bear Stearns and the Zwirn arbitration

Financial Trust and Jeepers held accounts at Bear Stearns.7 Both were counter-claimants and third-party claimants in an arbitration before JAMS in New York, Fortress VRF I LLC and Fortress Value Recovery Fund I LLC v. Jeepers, Inc., in which they claimed against Fortress Value Recovery Fund I LLC and against the D.B. Zwirn entities and Daniel Zwirn.35 Asked in May 2011 for the total fees paid, Beller wrote to Epstein: “the total fees paid by FTC/JEEPERS to Zwirn was $24,514,951 ($13,244,319 incentive fees and $11,270,632 management fees)”, adding that the figure excluded about $350,000 paid to Fortress.36

Credit Suisse First Boston

The release holds the first page of two schedules to ISDA master agreements dated as of May 19, 2005, each marked “Execution copy”, one between Credit Suisse First Boston International and the company and one between Credit Suisse First Boston (Europe) Limited and the company. Each identifies Financial Trust Company, Inc. as “An United States Virgin Islands corporation” and sets the cross-default threshold amount at $10,000,000.3738

Subpoena and the work release application

On June 12, 2007 Gerald B. Lefcourt wrote to Assistant U.S. Attorney A. Marie Villafaña responding to subpoenas dated May 31, 2007 served on four Epstein entities, Financial Trust Company, Inc. among them. The letter states that no entity had documents responsive to four of the six requests, and encloses, for Financial Trust, IRS Forms W-2 and W-3 for 2003 through 2006 and Forms 1096 and 1099 for 2004 through 2006, together with a schedule of the corporation’s directors, board members and shareholders.39

On December 11, 2008, while Epstein was serving his Florida sentence, Villafaña wrote to Captain David Sleeth of the Palm Beach Sheriff’s Office about Epstein’s work release application over the name of United States Attorney R. Alexander Acosta, “By:” Assistant U.S. Attorney A. Marie Villafaña; the letter carries no manuscript signature. The letter records that his file is alternatively listed as employed by “The Florida Science Foundation” or “self-employed” at a salary of $250,000, and continues: “Please be advised 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.”11

The letter goes on to say that Indyke had signed the “Alternative Custody Unit Program Agreement” as Epstein’s “employer” and was listed in the work release file as his “supervisor”, and objects that the relationship ran the other way: Epstein was “the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein’s subordinate at that entity as well.” It also notes that Indyke lived and worked in the New York metropolitan area and so was unlikely to know whether Epstein appeared for work.11

Wind-down, 2012–2013

On February 1, 2012 Cecile De Jongh sent Epstein “a rough draft of a termination letter”, saying she wanted to pass it to the attorney Erika Kellerhals “for her review and edits given that she knows what was said to the EDC.” The draft opens: “In response to the realities of a deteriorating economy, we have determined that layoffs at Financial Trust Company, Inc. … are necessary. As a result the Company is reducing its workforce due to the need to reduce operating costs.” It is a template: the addressee’s name and the amount of the severance cheque are left blank, and the effective date is filled in as February 3, 2012, two days after the email.40 De Jongh told Epstein in February 2014 that the company had “ceased operations in March, 2012.”25

Southern Financial, LLC was organised in the Virgin Islands on February 25, 2013 as the sole-member subsidiary of Southern Trust Company, Inc.8 On March 19, 2013 the Southern Trust board recorded that Financial Trust’s own board “has determined that it is in the best interests of FTC and its sole shareholder to merge FTC into SF, upon the completion of which merger SF shall be the surviving entity of said merger”.8

Ten days later, on March 29, 2013, eight securities positions were delivered out of the company’s JPMorgan investment account to Southern Financial’s account by free delivery: Lloyds TSB Bank PLC MTN, Ally Financial preferred, Ariad Pharmaceuticals, Bank of America preferred, Biogen Idec, Cliffs Natural Resources convertible preferred, Dean Foods and a Deutsche Bank exchange-traded note.14 The March account summary shows the two Financial Trust investment accounts falling from $69,562,832.38 to $6,146,880.18 over the month, and the April summary shows both at nil on April 30, 2013.4110

On April 2, 2013 Justin D. Nelson of JPMorgan’s private bank wrote to a colleague, Vice President Kenneth Mallek, about a credit card application: “Financial Trust assets are moving to Southern Financial and they need a credit card for Southern Financial. We told them we are not increasing exposure for the overall Epstein relationship, so they agreed to lower LSJ to accommodate the additional card for Southern Financial. I’m ok with this.”42 The company’s FirstBank accounts were closed between June 4 and July 11, 2013.9 A later Deutsche Bank know-your-customer note on Southern Financial described the company as the firm Epstein had based in St. Thomas, “which merged into Southern Financial LLC.”43

In litigation and regulatory filings

In 2002 Citibank, N.A. sued Epstein and Financial Trust Company, Inc. in the Southern District of New York in a contract action before Judge Sidney H. Stein, according to a commercial docket report in the JPMorgan production.44 In the Virgin Islands, Financial Trust Company, Inc. and Epstein sued Citibank, N.A. and Citigroup, Inc., alleging that the defendants had misrepresented facts and fraudulently induced them to borrow $10 million to invest in a venture managed by AIG Global Investment Corporation; on June 19, 2003 the District Court of the Virgin Islands denied the defendants’ motions to dismiss for want of personal jurisdiction and to transfer, allowed claims of breach of fiduciary duty and negligent misrepresentation to proceed, and dismissed the fraud counts with leave to replead.45

A complaint filed in the Southern District of New York on August 20, 2018 named “The Financial Trust Company” as a defendant and alleged that it was “a hedge fund formed under the laws of St. Thomas in the U.S. Virgin Islands in 1996” and was “created, incorporated, owned, and managed, directly or indirectly, by Epstein, or entities controlled by Epstein”; the pleading advances the allegation on information and belief.46

The Government of the Virgin Islands’ amended complaints against Epstein’s estate state that “Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012”, and allege, on information and belief, that the purpose of Epstein’s array of corporate entities was “to allow Epstein to shelter his assets in order to fund, carry out, and conceal his identity and pattern of criminal conduct.”4748 Those complaints name Financial Trust among the companies said to make up an “Epstein Enterprise”, all of which held accounts with JPMorgan.49

The First Amended Complaint in Jane Doe 1 v. JP Morgan Chase Bank, N.A. alleges that Epstein’s business entities, naming Financial Trust among them, “were created to support and legitimize Epstein’s sexual abuse and sex-trafficking enterprise”, and that employees of those entities were involved in bringing the plaintiff to him while he was on work release.50 Financial Trust was not a defendant in that action, whose sole defendant was the bank.50

A suspicious activity report filed by JPMorgan Chase Bank and J.P. Morgan Securities, reporting 4,725 wire transactions totalling $1,081,819,653 between October 1, 2003 and July 22, 2019, lists Financial Trust Company Inc among the current, former and non-customer subjects of the report.51

Darren Indyke; Cecile de Jongh; Jeanne Brennan-Wiebracht; Harry Beller; Richard Kahn; Paul Hoffman; Ira Zicherman; A. Marie Villafaña; Alex Acosta; J. Epstein & Co.; Southern Trust Company; JEGE LLC; Laurel Inc; LSJE LLC; HBRK Associates; The C.O.U.Q. Foundation; Enhanced Education; JPMorgan Chase; Deutsche Bank; Little Saint James.

Footnotes

  1. Certificate of the Lieutenant Governor of the Virgin Islands, C-111-99, signed by Kenneth E. Mapp. https://epstein-data.com/EFTA00300027 p.2. ↩ ↩2 ↩3 ↩4 ↩5

  2. Articles of Incorporation and by-laws of Financial Trust Company, Inc. https://epstein-data.com/EFTA00300027 pp.4–15. ↩ ↩2 ↩3 ↩4

  3. JPMorgan Private Bank asset account portfolio, January 2003. https://epstein-data.com/EFTA01484358 p.1. ↩ ↩2 ↩3

  4. Virgin Islands Economic Development Commission application in the name of Financial Trust Company, Inc. https://epstein-data.com/EFTA00181807 p.394. Other pages of this production are not cited. ↩ ↩2

  5. Stock certificate No. 1, November 6, 1998. https://epstein-data.com/EFTA00300027 p.1. ↩ ↩2 ↩3 ↩4

  6. Consent of the directors appointing officers, September 21, 2007. https://epstein-data.com/EFTA00300027 p.21. ↩ ↩2 ↩3

  7. Email to Ira Zicherman at Bear Stearns over Darren K. Indyke’s signature, March 30, 2007. https://epstein-data.com/EFTA00038693 p.1. ↩ ↩2 ↩3

  8. Consent of the board of directors of Southern Trust Company, Inc., March 19, 2013. https://epstein-data.com/EFTA01362860 p.1. ↩ ↩2 ↩3 ↩4 ↩5

  9. FirstBank, San Juan, response to grand jury subpoena, March 9, 2020. The signature block gives Noraida Castro González’s name and title; the department name comes from the letter’s page footer. https://epstein-data.com/EFTA00065864 pp.1, 3, 4. ↩ ↩2 ↩3 ↩4 ↩5

  10. JPMorgan account summary for the period 4/1/13 to 4/30/13. https://epstein-data.com/EFTA01494144 ↩ ↩2

  11. U.S. Attorney’s Office, Southern District of Florida, to Captain David Sleeth, December 11, 2008. https://epstein-data.com/EFTA00189918 pp.1–3. ↩ ↩2 ↩3 ↩4

  12. Resignation of Jeffrey E. Epstein as director and president, September 21, 2007, faxed October 2, 2007. https://epstein-data.com/EFTA00300027 p.22. ↩ ↩2

  13. Cecile de Jongh to Jeffrey Epstein, September 18, 2012, with his reply. https://epstein-data.com/EFTA00943031 pp.1–2. ↩ ↩2 ↩3 ↩4

  14. JPMorgan account activity, securities transferred out, March 2013. The instrument line is printed as “LLOYDS TSB BANK PLC MTN 9 7/8% DEC 16 2021,” a medium-term note (MTN). https://epstein-data.com/EFTA01494013 p.1. ↩ ↩2

  15. Deutsche Bank know-your-customer file. https://epstein-data.com/EFTA01356688 p.1; https://epstein-data.com/EFTA01421293 p.18. ↩

  16. Virgin Islands business plan for Financial Informatics, Inc. https://epstein-data.com/EFTA00300168 p.5. ↩

  17. Florida Department of State record for Financial Trustees, Inc., in a commercial records report. https://epstein-data.com/EFTA01582880 p.1. ↩

  18. Incorporation packet, including the waiver of notice, minutes and resignation of incorporators. https://epstein-data.com/EFTA00300027 pp.16–20. ↩

  19. Consent of the sole shareholder, September 21, 2007. https://epstein-data.com/EFTA00300027 p.23. ↩

  20. Unanimous consent of directors in lieu of meeting, March 8, 2010. https://epstein-data.com/EFTA01584827 p.1. ↩

  21. JPMorgan to Darren Indyke, March 9, 2010. https://epstein-data.com/EFTA01584587 ↩

  22. Deutsche Bank presentation to the U.S. Attorney’s Office for the Southern District of New York, September 2019. https://epstein-data.com/EFTA01681865 p.37. ↩

  23. Cecile de Jongh email thread, February 2011. https://epstein-data.com/EFTA02027935 p.4. ↩

  24. Economic Development Commission application, extension applicants section. https://epstein-data.com/EFTA00181807 p.402. Other pages of this production are not cited. ↩

  25. Cecile de Jongh to Jeffrey Epstein, February 4, 2014, and his reply of February 5, 2014. https://epstein-data.com/EFTA01935290 p.1. ↩ ↩2

  26. JPMorgan Private Bank asset account portfolio, August 2003. https://epstein-data.com/EFTA01484431 ↩

  27. JPMorgan Private Bank asset account portfolio, February 2006. https://epstein-data.com/EFTA01484746 ↩

  28. J.P. Morgan Portfolios statement for Financial Trust Company Inc, January 2005. https://epstein-data.com/EFTA01558023 p.1. ↩

  29. Financial Trust Company, Inc. memorandum signed by Darren Indyke, December 8, 2009. https://epstein-data.com/EFTA01578818 ↩

  30. Financial Trust Company, Inc. memorandum signed by Darren Indyke, February 25, 2010. https://epstein-data.com/EFTA01578665 ↩

  31. Morgan Online administration tool screenshot, November 16, 2007. https://epstein-data.com/EFTA01583578 ↩

  32. Harry Beller to Jeffrey Epstein, January 10 and 11, 2013. https://epstein-data.com/EFTA01764170 p.1. ↩

  33. JPMorgan account summary for the period 10/1/12 to 10/31/12. https://epstein-data.com/EFTA01493498 ↩

  34. JPMorgan account summary for the period 1/1/13 to 1/31/13. https://epstein-data.com/EFTA01493794 ↩

  35. Fortress VRF I LLC and Fortress Value Recovery Fund I LLC v. Jeepers, Inc., JAMS Ref. No. 1425006537, caption. https://epstein-data.com/EFTA01581723 ↩

  36. Harry Beller to Jeffrey Epstein, May 24, 2011. https://epstein-data.com/EFTA01866726 ↩

  37. Schedule to the master agreement dated as of May 19, 2005 with Credit Suisse First Boston International. https://epstein-data.com/EFTA01581740 ↩

  38. Schedule to the master agreement dated as of May 19, 2005 with Credit Suisse First Boston (Europe) Limited. https://epstein-data.com/EFTA01581771 ↩

  39. Gerald B. Lefcourt to A. Marie Villafaña, June 12, 2007. https://epstein-data.com/EFTA00175998 pp.2–4. Other pages of this production are not cited. ↩

  40. Cecile de Jongh to Jeffrey Epstein, February 1, 2012. https://epstein-data.com/EFTA01989609 p.1. ↩

  41. JPMorgan account summary for the period 3/1/13 to 3/31/13. https://epstein-data.com/EFTA01494043 ↩

  42. Justin D. Nelson to Kenneth Mallek and others, April 2, 2013. https://epstein-data.com/EFTA01583365 ↩

  43. Deutsche Bank client-confirmation file on Southern Financial. https://epstein-data.com/EFTA01422087 p.3. ↩

  44. CourtLink docket report, Citibank, NA v. Epstein, et al, No. 1:02cv5332 (S.D.N.Y., filed July 11, 2002). https://epstein-data.com/EFTA01582887 ↩

  45. Financial Trust Company, Inc. and Jeffrey E. Epstein v. Citibank, N.A. and Citigroup, Inc., 268 F. Supp. 2d 561 (D.V.I., June 19, 2003), reproduced in a Deutsche Bank internal email of May 27, 2015. https://epstein-data.com/EFTA01386025 ↩

  46. Complaint, No. 1:18-cv-07580 (S.D.N.Y., filed August 20, 2018), ¶12. https://epstein-data.com/EFTA01386752 ↩

  47. Government of the Virgin Islands, First Amended Complaint against the Estate of Jeffrey Epstein, ¶¶88–89. https://epstein-data.com/EFTA00018778 p.19. ↩

  48. Government of the Virgin Islands, Second Amended Complaint against the Estate of Jeffrey Epstein, filed as Exhibit 1 to the amended complaint in Jane Doe 1 v. JP Morgan Chase Bank, N.A. https://epstein-data.com/EFTA00162121 p.195. ↩

  49. Government of the Virgin Islands, Second Amended Complaint, ¶27. https://epstein-data.com/EFTA00162121 p.139. ↩

  50. First Amended Complaint, Jane Doe 1 v. JP Morgan Chase Bank, N.A., No. 22-cv-10019-JSR (S.D.N.Y., filed January 13, 2023), ¶106 and caption. https://epstein-data.com/EFTA00162121 pp.1, 28. ↩ ↩2

  51. Suspicious activity report narrative. https://epstein-data.com/EFTA01648787 p.1. ↩

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