TypeSection 501(c)(3) exempt organisation, classified by the Internal Revenue Service as a private foundation under section 509(a) and required to file Form 990-PF annually1
Tax exemptionEffective April 25, 2012; determination letter dated September 27, 20121
Address on the returns9053 Estate Thomas, Suite 101, St Thomas, VI 00802, c/o Royal Palms Professional Building2
Officers, tax year 2015Richard Kahn president; Darren K. Indyke treasurer; Erika A. Kellerhals secretary (each one hour a week, none compensated)3
BanksDeutsche Bank Trust Company Americas, a money market deposit account and a checking account, intended opening date February 18, 2015; FirstBank Puerto Rico commercial checking, opened February 26, 201545
Funding$10,000,000 from BV70 LLC, October 14, 201567
Assets$10,006,564 fair market value at December 31, 2015; $9,385,495 at December 31, 201628
Grants reportedNone for tax year 2015; $580,000 to nine organisations for tax year 201691011

Gratitude America, Ltd. was a Virgin Islands charitable organisation of Jeffrey Epstein’s, exempt under section 501(c)(3) from April 25, 2012 and classified by the Internal Revenue Service as a private foundation.1 It was capitalised in October 2015 by a single $10,000,000 contribution from BV70 LLC, an entity Bloomberg reported to be controlled by Leon Black, and it made grants and payments to universities, arts and medical charities and to a number of named individuals between 2016 and 2018.671211 Its accounts at Deutsche Bank became the subject of a compliance escalation in January 2016, when an accountant acting for Epstein asked the bank to open a brokerage account for the charity, and then withdrew the request after the bank ordered an external due diligence report on Epstein; the New York State Department of Financial Services recorded that sequence in its 2020 consent order with the bank.13 The charity was one of many entities named as a defendant in a New York action against Epstein’s estate, and its bank records were reviewed by the Internal Revenue Service and traced by the French financial intelligence unit through the Egmont Group.141516

Formation and tax status

On February 9, 2012 Erika Kellerhals of the St Thomas law firm Kellerhals Ferguson LLP wrote to Epstein: “Can you provide me with the names of 3 directors for Gratitude America please?”17 A week later, on February 16, Epstein’s assistant Lesley Groff sent him a reminder that “ERika Kellerhals needs directors for Gratitude America.”18

The Internal Revenue Service wrote to Gratitude America Ltd at the law firm’s address, 9100 Havensight Port of Sale Ste 15, St Thomas, on September 27, 2012, that the organisation was exempt from federal income tax under section 501(c)(3), that its effective date of exemption was April 25, 2012, that it was “a private foundation within the meaning of section 509(a) of the Code,” and that it was “required to file Form 990-PF annually.”1 The returns give the foundation’s own address as 9053 Estate Thomas, Suite 101, St Thomas, care of the Royal Palms Professional Building, and its accounting period as the calendar year.21

The foundation was registered with the New York State Attorney General’s Charities Bureau: a Gratitude America cheque of May 11, 2017 for $250 is payable to the “Department of Law” at the Charities Bureau Registration Section, 120 Broadway, New York, with the memo “NY registration 452559 2016 Form CHAR500.”19

Officers

Part VIII of the Form 990-PF for calendar year 2015 lists three officers, each recorded as devoting one hour a week and each receiving no compensation, and nothing entered under benefit plans or expense allowance: Richard Kahn as president, Darren K. Indyke as treasurer, and Erika A. Kellerhals as secretary. Epstein is not listed.3 The Daily Beast reported in 2020, from the charity’s tax filings, that Kahn replaced Epstein as president in 2015.20

Deutsche Bank’s own account records give a different set of roles. A periodic review of the account dated August 1, 2018 sets out the account holder as Gratitude America Ltd and lists “President & Authorized Signatory — Jeffrey Epstein,” “Director & Authorized Signatory — Richard Kahn” and “Director, Treasurer & Authorized Signatory — Darren Indyke,” and the reviewer noted that Kahn appeared in a self-certification form and a Form 990 from 2016 but not in the bank’s 2015 non-profit resolution or in its last approved know-your-customer file of August 2017.21 The FirstBank Puerto Rico account opened in February 2015 carries Jeffrey E. Epstein and Darren K. Indyke as authorised signatures.5

Bank accounts

Deutsche Bank’s know-your-customer file for the relationship, opened under relationship manager Paul Morris, records the foundation as introduced by client referral, with the detail line naming Epstein as the current client, “Jeffrey Epstein (President of Gratitude America) is a current client of the bank”, and lists two Gratitude America accounts with an intended opening date of February 18, 2015. The first is described as a “Money market account to hold funds and earn interest”; the second as a “Checking account to deal with the day-to-day running of the foundation.” Darren Indyke is given as the primary contact for the relationship.42223

FirstBank Puerto Rico, answering a grand jury subpoena from the Southern District of New York in March 2020, listed a Gratitude America, Ltd commercial checking account opened February 26, 2015 with a status of “NORMAL.”5

Capitalisation: the BV70 LLC transfer, October 14, 2015

Schedule B to the 2015 Form 990-PF lists a single contributor: BV70 LLC, of 445 Park Avenue, New York, total contributions $10,000,000.6 The return reports total contributions, gifts and grants received of $10,003,000, interest on savings and temporary cash investments of $4,332, total revenue of $10,007,332, legal fees of $543, and fair market value of all assets at year end of $10,006,564. No grants were paid in that year.29

A chart of transactions headed “Exhibit A: Leon Black / Rothschild Group Transactions,” sent to the government by Deutsche Bank’s associate general counsel in August 2019, records a wire of $10,000,000 from BV70 LLC to Gratitude America, Ltd. on October 14, 2015 at Bates DB-SDNY-0004999. The same chart records two transfers the previous day, October 13, 2015, of $5,000,000 each from “Leon and Debra Black c/o Apollo Management” and from “Black Family Partners, LP c/o Apollo Management” to Southern Trust Company, Inc., at Bates DB-SDNY-0004990.724 A footnote to the bank’s chart of the Gratitude America account states: “The Gratitude America MMDA was primarily capitalized via a $10 million deposit from BV70 LLC. Bloomberg has reported that Leon Black controls BV70 LLC,” citing Tom Metcalf’s Bloomberg article of August 6, 2019.25

The report prepared by Dechert LLP for the conflicts committee of Apollo Global Management, dated January 22, 2021, records that Black “made a $10 million donation to Gratitude America in October 2015, which was a charitable organization affiliated with Epstein,” and that Black “felt comfortable making this donation because he understood that Epstein was a strong proponent of scientific innovation.” A footnote adds that the investigation found a letter from Gratitude America to Black of August 21, 2015 thanking him for a $5 million donation, confirmed in an email from Epstein to Black, but that Dechert “did not find any document prepared by Black or the Family Office confirming this donation or any bank record reflecting such payment.”26 See Leon Black.

The money market account, 2015–2019

Deutsche Bank’s counsel sent the government a chart headed “Exhibit E: Transactions Involving Gratitude America Money Market Deposit Account (‘MMDA’),” which traces that one account from the BV70 deposit to January 2019. It is not a record of everything the charity paid out: most of the money left the money market account for the charity’s own checking account, for accounts it held at other institutions, or for a Gratitude America account at Morgan Stanley, and payments made from the checking account do not appear on it.12

DatePayerRecipientAmountBates
10/14/2015BV70 LLCGratitude America, Ltd.$10,000,000DB-SDNY-0004999
1/7/2016Gratitude America MMDABruce and Marsha Moskowitz Foundation$50,000DB-SDNY-0005198
1/21/2016Gratitude America MMDAGratitude America Ltd (First Bank of Puerto Rico)$50,000DB-SDNY-0005198
1/29/2016Gratitude America MMDAMelanoma Research Alliance Foundation$225,000DB-SDNY-0005198
2/3/2016Gratitude America MMDAGratitude America Checking$150,000DB-SDNY-0005264
3/2/2016Gratitude America MMDAGratitude America Ltd. (Morgan Stanley / Citibank)$5,000,000DB-SDNY-0005334
3/8/2016Gratitude America MMDAGratitude America Checking$250,000DB-SDNY-0005334
3/8/2016Gratitude America MMDAGratitude America Checking$250,000DB-SDNY-0005334
4/6/2016Gratitude America MMDAGratitude America Ltd (First Bank of Puerto Rico)$250,000DB-SDNY-0005401
7/12/2016Gratitude America MMDABruce and Marsha Moskowitz Foundation$50,000DB-SDNY-0005605
7/14/2016Gratitude America MMDAGratitude America Ltd. (Morgan Stanley / Citibank)$2,000,000DB-SDNY-0005605
7/19/2016Gratitude America MMDAGratitude America Ltd. (Morgan Stanley / Citibank)$500,000DB-SDNY-0005605
1/20/2017Gratitude America MMDAGratitude America Checking$200,000DB-SDNY-0006006
3/6/2017Gratitude America MMDAGratitude America Checking$250,000DB-SDNY-0006165
6/1/2017Gratitude America MMDAGratitude America Checking$250,000DB-SDNY-0006333
6/7/2017Gratitude America MMDAGratitude America Checking$200,000DB-SDNY-0006333
10/2/2017Gratitude America MMDACancer Research Wellness Institute$25,000DB-SDNY-0006658
11/1/2017Gratitude America MMDAGratitude America Checking$50,000DB-SDNY-0006739
11/1/2017Gratitude America MMDAGratitude America Checking$100,000DB-SDNY-0006739
11/13/2017Gratitude America MMDAGratitude America Checking$100,000DB-SDNY-0006739
12/6/2017Gratitude America MMDABruce and Marsha Moskowitz Foundation$50,000DB-SDNY-0006822
12/11/2017Gratitude America MMDAGratitude America Ltd (First Bank of Puerto Rico)$150,000DB-SDNY-0006822
12/11/2017Gratitude America CheckingGratitude America MMDA$2,500,000DB-SDNY-0006822
1/30/2018Gratitude America MMDAGratitude America Checking$2,000,000DB-SDNY-0006907
2/28/2018Gratitude America MMDACancer Reasearch Wellness Institute [sic]$25,000DB-SDNY-0006991
4/2/2018Gratitude America MMDANPO Baleto Teatras$18,493DB-SDNY-0007170
9/17/2018Gratitude America MMDAVSJ Baleto Teatras$10,000DB-SDNY-0007629
1/10/2019Gratitude America MMDAGratitude America Checking$314,876DB-SDNY-0007994

Two of the bank’s own footnotes qualify the table: the $50,000 of January 7, 2016 appears on the account statements as a payment to “First Clearing LLC,” and the $5,000,000 of March 2, 2016 appears as a payment to “Morgan Stanley,” but in each case the bank says the wire records show the intended recipient to have been the Moskowitz foundation and a Gratitude America account respectively.27

Tax returns

Two years of the foundation’s Form 990-PF are in the released files, for calendar years 2015 and 2016. Both are held inside the Deutsche Bank production as attachments to bank correspondence, and each survives in several partial copies rather than as one complete filing; searches of the release for “Gratitude America” together with “990-PF,” “Return of Private Foundation” and the schedule headings used on those returns (“TY 2013,” “TY 2014,” “TY 2017,” “TY 2018”) returned no return for any other year.

The 2015 return reports no grants paid.9 The 2016 return reports fair market value of assets at year end of $9,385,495 and grants paid of $580,000, itemised in an additional data table as follows.81011

RecipientPurpose statedAmount
Bruce Marsha Moskowitz FoundationGeneral charitable purposes$100,000
Melanoma Research Alliance FoundatiGeneral charitable purposes$225,000
The Hasty Pudding InstituteGeneral charitable purposes$50,000
Crohn’s Colitis Foundation of AmeriGeneral charitable purposes$10,000
Verse Video EducationGeneral charitable purposes$110,000
Women Global Cancer Initiative IncGeneral charitable purposes$10,000
New York Concert Artists Assoc IncGeneral charitable purposes$50,000
Icahn School of Medicine Mt SinaiGeneral charitable purposes$10,000
The Hewitt SchoolGeneral charitable purposes$15,000

Two recipient names are cut off at the width of the form’s field and are printed here exactly as the form prints them, without completion. Of these nine recipients, two also appear on the bank’s money market chart: the Moskowitz foundation, in two payments totalling $100,000, and the Melanoma Research Alliance Foundation at $225,000. The remaining $255,000 does not appear on that chart, which covers one account only.1211

Cheques in the Deutsche Bank production

The bank’s production includes images of Gratitude America cheques drawn on Deutsche Bank Trust Company Americas. The following are read from the page images. They are not a complete cheque series.

DateChequePayeeAmount
3/4/2016302The Hasty Pudding Institude [sic]$50,00028
3/18/2016303Crohn’s and Colitis Foundation of America$10,00029
4/19/2016362Jeremy Rubin$25,00030
8/1/2016364Leon Botstein$37,50031
8/1/2016365Jeremy Rubin$25,00032
1/17/2017305Dr. Robert Trivers$30,00033
2/1/2017308Charlie Albright$50,00034
2/6/2017307The Institute for Music & Brain Science$100,00035
3/2/2017309Noam Chomsky$20,00036
3/6/2017310Paul Krassner$5,00037
3/24/2017316The Film Society of Lincoln Center$25,00038
3/30/2017311Walk MS$5,00039
4/18/2017313University of Arizona Foundation$50,00040
5/8/2017320Met Orchestra Musicians$50,00041
5/8/2017321International Peace Institute, Inc$150,00042
5/11/2017322The Department of Treasury, VI Bureau of Internal Revenue (memo: “Form 990-PF”)$2,57143
5/11/2017323Department of Law, NYS Office of the Attorney General, Charities Bureau (memo: “NY registration 452559 2016 Form CHAR500”)$25019
8/2/2017314The O’Gorman Garden$30,00044
8/23/2017331JTCC$25,00045
10/18/2017332Chopra Foundation$50,00046
11/1/2017315International Peace Institute, Inc, “Attn: Terje Rod Larsen”$100,00047
11/8/2017328UJA-Federation of New York$50,00048
11/13/2017329Paul Krassner$5,00049
1/19/2018330Paul Krassner$5,00050
3/15/2018336The Shakespeare Theatre of New Jersey$25,00051
4/6/2018333The Hasty Pudding Institute of 1770$50,00052
4/27/2018337Crohn’s and Colitis Foundation$10,00053

These entries record that the cheques were paid; none of the documents cited here shows what any recipient knew about the source of the funds or was told about them.

The cheques to Jeremy Rubin and to Leon Botstein of August 1, 2016 carry the memo “3rd Quarterly Payment of 4,” and the Rubin cheque of April 19, 2016 the memo “2nd quarterly payment.”323130 The $20,000 payment to Noam Chomsky of March 2, 2017 followed an email from Darren Indyke of February 28 setting out “the proposed description of services for Noam Chomsky’s service as a consultant to GA in exchange for $20K,” on the assumption that he would serve on the foundation’s advisory board and would “formulate and administer the linguistic challenges”; forwarding it on March 2, Richard Kahn asked Epstein to “please advise if ok to send check or wait until agreement is finalized.” The documents cited here do not show whether the agreement was signed. Chomsky’s own recorded statements are set out on his page.54 The 2017 payments to the International Peace Institute are set out on Terje Rød-Larsen’s page.55

The brokerage account request, January 2016

The consent order entered between the New York State Department of Financial Services and Deutsche Bank in July 2020 records at paragraph 44:

On January 4, 2016, an accountant representing Mr. Epstein (herein, “ACCOUNTANT-1”) requested that the Bank open a brokerage account for Gratitude America, Mr. Epstein’s private charity. COVERAGE TEAM MEMBER-1 escalated the request to AML OFFICER-2, who directed the inquiry to the Secretary for the ARRC. The Secretary of the ARRC conferred with a member of the ARRC and ordered that an external due diligence report be prepared on Mr. Epstein. In response to the request for additional information, ACCOUNTANT-1 informed the Bank of Mr. Epstein’s resignation from Gratitude America and withdrew the request to open the account. As a result, no due diligence report was run on Mr. Epstein.13

The ARRC is the bank’s Americas Reputational Risk Committee, defined earlier in the same order.56 The order does not name ACCOUNTANT-1, and this page does not identify that person with anyone named on it. A separate Deutsche Bank email thread running from February 6, 2015 to January 20, 2016 shows Richard Kahn requesting a Gratitude America account and the request being referred up through the bank; the Deutsche Bank page sets that sequence out.

A class-action complaint filed against Deutsche Bank in the Southern District of New York in January 2023 reproduces the same paragraph and adds an allegation: “Deutsche Bank was aware that the reason that Epstein was withdrawing his request to open the new account was to avoid a due diligence report. Deutsche Bank was aware that a due diligence report on Epstein would have documented that Epstein was using Deutsche Bank accounts to facilitate his sex abuse and sex-trafficking venture.”57 That is an allegation in a pleading, not a finding; the consent order itself records only that the accountant reported a resignation, withdrew the request, and that no report was run.13 The complaint lists Gratitude America as the fifth of five Deutsche Bank accounts it says the bank maintained for Epstein.58

Epstein remained recorded by the bank as president and an authorised signatory of the account in its own periodic review of August 2018.21

The Virgin Islands coastal zone proceeding

The Department of Planning and Natural Resources of the Government of the Virgin Islands opened an administrative enforcement proceeding, NOVA-04-16-STT, by serving Great St. Jim, LLC, the entity holding Great St. James, with a notice of violation dated April 22, 2016, followed by a settlement agreement of August 2016, a notice to cure of November 4, 2016 and a notice of failure to cure of December 15, 2016.5960

A redlined draft of a supplemental consent agreement in that proceeding strikes out a clause under which “The Respondent agrees to fund the following Supplemental Environmental Project (‘SEP’) in Lieu of Stipulated Penalties of not less than One Hundred Sixty Thousand Dollars,” and replaces it with a recital that the respondent’s commitment to coastal resources “is evidenced, among other ways, by a grant to the St. Thomas Historical Trust … which Gratitude America, Ltd., an affiliate of Respondent, is making in the amount of One Hundred Sixty Thousand Dollars ($160,000) … for the purpose of paying fees, costs and expenses in connection with the construction of a raveling wall at Fort Christian.”61 Under the same draft, further action against the respondent under the notice and the failure to cure, “including, without limitation, the assessment of any penalty,” would be “permanently discontinued.”62

On the signature page of the redlined draft every line is blank and the words “SO ORDERED THIS ___ DAY OF _______ 2017” are unfilled.63 A clean seven-page version of the same agreement carries a signature over the line for “JEFFREY EPSTEIN, President of Poplar, Inc., the Sole Member of GREAT ST. JIM, LLC”; the lines for the Director of Coastal Zone Management and for the Commissioner of the department are blank on that copy and the “so ordered” date is unfilled.64

Two letters on the letterhead of Enhanced Education, dated June 30 and July 3, 2017 and typed over the name of Jeffrey E. Epstein as president, transmit a cheque of $160,000 to the St. Thomas Historical Trust; the first carries the heading “Re: Construction of Fort Christian Raveling Wall” and reads “Enclosed please find a check in the amount of $160,000 for the construction of a raveling wall at Fort Christian.”6566 Neither letter states which entity’s cheque was enclosed, and on both copies the space above the signature block is blank. The documents do not establish which entity’s account the cheque was drawn on, and this page does not attribute it.

Federal and foreign interest in the accounts

A Federal Bureau of Investigation import form of April 26, 2021, under case number 272B-SJ-3262541 captioned “SOUTHERN TRUST; SOUTHERN COUNTRY INTERNATIONAL; Wire Fraud,” is titled “IRS FoA analysis of GRATITUDE AMERICA LTD accounts” and carries the synopsis: “IRS had a contract forensic accountant conduct a review of bank accounts for Jeffrey EPSTEIN company GRATITUDE AMERICA LTD.” The form’s single enclosure is listed as “Account” followed by a redaction, and the enclosure itself is not part of the document.15

The FinCEN officer’s covering email of January 17, 2020, transmitting for review a draft response to an Egmont Group information request that FinCEN had received from the French financial intelligence unit Tracfin (undated in the document) about the relationship between the Association pour la Promotion de la Politique Culturelle and Gratitude America, records that “the French account of POLITIQUE CULTURELLE received 50,000 Euros from the Deutsche Bank account of GRATITUDE,” that the transaction “was flagged because it lacked a clear purpose and suspicions are it may be funds from illicit activities,” and that the request indicated the association between the two entities “may be linked to ‘a former French Ministry’.” It records that research identified “the high profile Jeffrey Epstein (now deceased)” as the beneficial owner, that suspicious activity reports had identified him as a politically exposed person because of his ties to senior United States government officials, and that “three SARs and commercial records” had been found.1667 On March 6, 2020 a FinCEN detailee circulated the response for deconfliction, summarising that “It turns out that Gratitude America is owned by Eptstein” and that “FinCEN found three SARs related to Gratitude America”; a special agent of the FBI’s New York Field Office, Violent Crimes Task Force, replied the same day: “I have no objection…”1668

Press inquiry and the government’s response, September 2019

On September 8, 2019 Rebecca Davis O’Brien69 of the Wall Street Journal wrote to the Southern District of New York that she was working on a story about “one of Jeffrey Epstein’s recent Virgin Islands-based charities, Gratitude America,” which she said (1) “got most of its funding from a $10 million grant from a foundation controlled by Leon Black (of Apollo) in 2015”; (2) that “[s]ome of Gratitude’s donations between 2016 and 2017, listed in its tax forms, were never received by the named charities”; (3) that “Epstein attempted to use the charity to pay fines in the Virgin Islands”; and (4) that “Gratitude America had a Deutsche Bank account,” which she described as “the new news here.”70

Counsel for Deutsche Bank at Akin Gump wrote to the government on September 10, 2019 to flag that a Wall Street Journal article would appear the next day reporting “that Epstein controlled a charity called Gratitude America and that the charity held accounts at the Bank.”71

An internal Southern District email sent at 8:32 pm Eastern on September 14, 2019 (00:32 UTC on September 15 by the message header), forwarding the reporter’s questions, gave prosecutors’ superiors an update on the financial side of the investigation. It says that “[e]ssentially all of what the WSJ article covered had been previously reported, with the exception of the information that Gratitude America had an account at Deutsche Bank, which we also knew,” describes “the Gratitude America entity described below” as one example among “many, many financial holdings, transactions, and relationships” the office was aware of, and states, of a list of payments to named individuals set out earlier in the same email, that “[n]one of the payments to the individuals described above appear to have any connection to criminal activity, and I don’t think any of the financial information we’ve seen so far would lead us to initiate a separate financial investigation.”72 That last sentence is directed at those individual payments rather than at Gratitude America specifically.

The reporter’s third point, that Epstein “attempted to use the charity to pay fines in the Virgin Islands,” is not attributed in her email to any document. What the released files show about the charity and Virgin Islands government bodies is set out above: the draft supplemental consent agreement in NOVA-04-16-STT, and a $2,571 cheque of May 11, 2017 to the Department of Treasury at the Virgin Islands Bureau of Internal Revenue whose memo line reads “Form 990-PF.”6143 None of the documents cited on this page describes a payment by the charity as a fine.

An FBI financial investigator circulated a Daily Beast article about the charity within the bureau in August 2020 under the subject line “Epstein’s Secret Charity.”73

Litigation and the estate

Schedule G to the first quarterly accounting filed in the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 in the Superior Court of the Virgin Islands, covering August 10 to December 31, 2019, is headed “Civil Claims – Lawsuits.” Its first entry, an action filed in the Supreme Court of the State of New York on August 14, 2019 under index 950010/2019 and amended on October 10, 2019, names “Gratitude America LTD” among some three dozen defendants alongside the estate, Ghislaine Maxwell, Darren K. Indyke and Richard D. Kahn as executors, the J. Epstein Virgin Islands Foundation, the C.O.U.Q. Foundation, Southern Trust Company and other Epstein entities. The plaintiff’s name is redacted.14

Leon Black; Richard Kahn; Darren Indyke; Noam Chomsky; Terje Rød-Larsen; Lesley Groff; Deutsche Bank; Southern Trust Company; C.O.U.Q. Foundation; Enhanced Education; International Peace Institute; Great St. James.

Footnotes

  1. Internal Revenue Service determination letter to Gratitude America Ltd, Sept 27, 2012. https://epstein-data.com/EFTA01365895 p.1. 2 3 4 5

  2. Gratitude America Ltd, Form 990-PF for calendar year 2015, page 1. https://epstein-data.com/EFTA01372512 p.1. 2 3 4

  3. Form 990-PF, 2015, Part VIII, page 6. https://epstein-data.com/EFTA01378849 p.1. 2

  4. Deutsche Bank private wealth management know-your-customer file, “Southern Financial Relationship,” Part A, relationship details and account list. https://epstein-data.com/EFTA01284048 p.1. 2

  5. FirstBank Puerto Rico to the Southern District of New York, Mar 9, 2020, in response to a grand jury subpoena, covering letter and account table. https://epstein-data.com/EFTA00065864 pp.1–2. 2 3

  6. Schedule B (Form 990, 990-EZ, or 990-PF), 2015, Part I, contributors. https://epstein-data.com/EFTA01379599 p.1. 2 3

  7. “Exhibit A: Leon Black / Rothschild Group Transactions,” Deutsche Bank transaction charts. https://epstein-data.com/EFTA00027019 p.1. 2 3

  8. Form 990-PF for calendar year 2016, page 1. https://epstein-data.com/EFTA01345259 p.1. 2

  9. Form 990-PF, 2015, Part XV, page 11, grants and contributions paid during the year. https://epstein-data.com/EFTA01372336 p.1. 2 3

  10. Form 990-PF, 2016, Part XV, page 11. https://epstein-data.com/EFTA01362366 p.1. 2

  11. Form 990-PF, 2016, Part XV line 3 additional data table, grants and contributions paid during the year. https://epstein-data.com/EFTA01362369 p.1. 2 3 4

  12. “Exhibit E: Transactions Involving Gratitude America Money Market Deposit Account (‘MMDA’).” https://epstein-data.com/EFTA00027019 pp.8–9. 2 3

  13. New York State Department of Financial Services, consent order with Deutsche Bank, ¶ 44. https://epstein-data.com/EFTA00151495 p.15. 2 3

  14. Estate of Jeffrey E. Epstein, First Quarterly Accounting, Probate No. ST-19-PB-80, Superior Court of the Virgin Islands, Division of St. Thomas and St. John, covering Aug 10 to Dec 31, 2019, Schedule G. https://epstein-data.com/EFTA00075562 p.14. 2

  15. Federal Bureau of Investigation, FD-1036 import form, Apr 26, 2021. https://epstein-data.com/EFTA00128841 p.1. 2

  16. FinCEN and FBI deconfliction chain, “France FIU Egmont Response – 290581 ASSOCIATION POUR LA PROMOTION DE LA POLITIQUE CULTURELLE and GRATITUDE AMERICA LTD,” Mar 5–6, 2020. https://epstein-data.com/EFTA00153569 pp.1–3. 2 3

  17. Erika Kellerhals’s message of Feb 9, 2012, “Re: Gratitude America,” quoted in Epstein’s reply of the same day. https://epstein-data.com/EFTA01841427 p.1.

  18. Lesley Groff to Jeffrey Epstein, Feb 16, 2012, “Reminder.” https://epstein-data.com/EFTA01842873 p.1.

  19. Cheque no. 323, May 11, 2017. https://epstein-data.com/EFTA01348687 2

  20. Kate Briquelet and William Bredderman, “Jeffrey Epstein’s Right-Hand Mystery Men,” The Daily Beast, Aug 30, 2020, preserved in a Justice Department production. https://epstein-data.com/EFTA00163119 p.17.

  21. Deutsche Bank periodic review of the Mort, Inc. and Gratitude America Ltd accounts, Aug 1, 2018. https://epstein-data.com/EFTA01422395 p.6. 2

  22. Same file, account ownership summary, money market account. https://epstein-data.com/EFTA01284048 p.2.

  23. Same file, account ownership summary, checking account. https://epstein-data.com/EFTA01284048 p.3.

  24. Covering email transmitting the transaction charts, from Justin Alfano, Director and Associate General Counsel, Deutsche Bank AG New York Branch, Litigation & Regulatory Enforcement, timed 13 Aug 2019 01:13 UTC and quoted in the reply as sent 21:14 on Aug 12, 2019. https://epstein-data.com/EFTA00080250 pp.1, 9; https://epstein-data.com/EFTA00104945 p.1.

  25. Same exhibit, footnote 8. https://epstein-data.com/EFTA00027019 p.8.

  26. Dechert LLP, report to the Apollo Conflicts Committee, Jan 22, 2021, printed p.18 and n.4. https://epstein-data.com/EFTA02730996 p.18.

  27. Same exhibit, footnotes 9 and 10. https://epstein-data.com/EFTA00027019 pp.8–9; https://epstein-data.com/EFTA00080250 p.10.

  28. Gratitude America, Ltd cheque no. 302, Mar 4, 2016. https://epstein-data.com/EFTA01348721

  29. Cheque no. 303, Mar 18, 2016. https://epstein-data.com/EFTA01348719

  30. Cheque no. 362, Apr 19, 2016. https://epstein-data.com/EFTA01348717 2

  31. Cheque no. 364, Aug 1, 2016. https://epstein-data.com/EFTA01348714 2

  32. Cheque no. 365, Aug 1, 2016. https://epstein-data.com/EFTA01348712 2

  33. Cheque no. 305, Jan 17, 2017. https://epstein-data.com/EFTA01348710

  34. Cheque no. 308, Feb 1, 2017. https://epstein-data.com/EFTA01348708

  35. Cheque no. 307, Feb 6, 2017. https://epstein-data.com/EFTA01348706

  36. Cheque no. 309, Mar 2, 2017. https://epstein-data.com/EFTA01348702

  37. Cheque no. 310, Mar 6, 2017. https://epstein-data.com/EFTA01348704

  38. Cheque no. 316, Mar 24, 2017. https://epstein-data.com/EFTA01348700

  39. Cheque no. 311, Mar 30, 2017. https://epstein-data.com/EFTA01348696

  40. Cheque no. 313, Apr 18, 2017. https://epstein-data.com/EFTA01348698

  41. Cheque no. 320, May 8, 2017. https://epstein-data.com/EFTA01348690

  42. Cheque no. 321, May 8, 2017. https://epstein-data.com/EFTA01348694

  43. Cheque no. 322, May 11, 2017. https://epstein-data.com/EFTA01348692 2

  44. Cheque no. 314, Aug 2, 2017. https://epstein-data.com/EFTA01348685

  45. Cheque no. 331, Aug 23, 2017. https://epstein-data.com/EFTA01348683

  46. Cheque no. 332, Oct 18, 2017. https://epstein-data.com/EFTA01348681

  47. Cheque no. 315, Nov 1, 2017. https://epstein-data.com/EFTA01348679

  48. Cheque no. 328, Nov 8, 2017. https://epstein-data.com/EFTA01348675

  49. Cheque no. 329, Nov 13, 2017. https://epstein-data.com/EFTA01348677

  50. Cheque no. 330, Jan 19, 2018. https://epstein-data.com/EFTA01348673

  51. Cheque no. 336, Mar 15, 2018. https://epstein-data.com/EFTA01348671

  52. Cheque no. 333, Apr 6, 2018. https://epstein-data.com/EFTA01348669

  53. Cheque no. 337, Apr 27, 2018. https://epstein-data.com/EFTA01348667

  54. Richard Kahn to Jeffrey Epstein, Mar 2, 2017, forwarding Darren Indyke’s proposed description of services of Feb 28, 2017. https://epstein-data.com/EFTA00711754 pp.1–2.

  55. Epstein to Richard Kahn and Kahn’s reply, Nov 1, 2017, recording that the two earlier cheques to the institute had also been drawn on Gratitude America. https://epstein-data.com/EFTA00675377 p.1.

  56. Same order, ¶ 22. https://epstein-data.com/EFTA00151495 p.7.

  57. Class-action complaint, S.D.N.Y. No. 1:22-cv-10018, filed Jan 13, 2023, ¶ 253. https://epstein-data.com/EFTA00161958 p.69.

  58. Same complaint, ¶ 171. https://epstein-data.com/EFTA00161958 p.44.

  59. Government of the Virgin Islands, Department of Planning and Natural Resources, Division of Coastal Zone Management, NOVA-04-16-STT, supplemental consent agreement (redlined draft), recitals. https://epstein-data.com/EFTA00583721 pp.1–2.

  60. Same draft, recitals continued. https://epstein-data.com/EFTA00583721 p.2.

  61. Same draft, recital and struck clause, beginning at the foot of p.2 and completing on p.3. https://epstein-data.com/EFTA00583721 pp.2–3. 2

  62. Same draft, “Further Action Discontinued.” https://epstein-data.com/EFTA00583721 p.5.

  63. Same draft, signature page. https://epstein-data.com/EFTA00583721 p.10.

  64. Supplemental consent agreement, seven-page version, signature page. https://epstein-data.com/EFTA00299482 p.7.

  65. Letter to the St. Thomas Historical Trust, June 30, 2017, on Enhanced Education letterhead, over the name of Jeffrey E. Epstein as president. https://epstein-data.com/EFTA00583474 p.1.

  66. Letter to the St. Thomas Historical Trust, July 3, 2017, on Enhanced Education letterhead, over the name of Jeffrey E. Epstein as president. https://epstein-data.com/EFTA00584695 p.1.

  67. Same chain, FinCEN officer’s covering email of Jan 17, 2020 transmitting the draft response for review. https://epstein-data.com/EFTA00153569 pp.2–3.

  68. FBI New York Field Office, Violent Crimes Task Force, reply of Mar 6, 2020. https://epstein-data.com/EFTA00153572 p.1.

  69. The produced header of the reporter’s email prints only “O’Brien” (her given name is a black box); her full byline is confirmed from her own published article: Rebecca Davis O’Brien and Jenny Strasburg, “Jeffrey Epstein Used Opaque Charity Account at Deutsche Bank for Own Benefit,” Wall Street Journal, Sept. 12, 2019. https://www.wsj.com/articles/jeffrey-epstein-used-opaque-charity-account-at-deutsche-bank-for-own-benefit-11568286004

  70. Rebecca Davis O’Brien, Wall Street Journal, to the United States Attorney’s Office for the Southern District of New York, Sept 8, 2019, forwarded internally. https://epstein-data.com/EFTA00009962 p.1; https://epstein-data.com/EFTA00105304 p.3.

  71. Parvin Daphne Moyne, Akin Gump Strauss Hauer & Feld LLP, Sept 10, 2019. https://epstein-data.com/EFTA00075273 p.1.

  72. Internal Southern District of New York email, Sept 14, 2019, 8:32 pm Eastern (00:32 UTC on Sept 15 by the message header). https://epstein-data.com/EFTA00105304 pp.1–2.

  73. FBI senior financial investigator forwarding the Daily Beast article, Aug 31, 2020. https://epstein-data.com/EFTA00163118 p.1.