Epstein Data Wiki

Kellerhals Ferguson Kroblin

Properties2
tagsentity, law-firm, us-virgin-islands, st-thomas, epstein-entities, epstein-finances, economic-development-commission, probate, 2011, 2012, 2013, 2014, 2015, 2016, 2017, 2019, 2020
aliasesKellerhals Ferguson Kroblin PLLC, Kellerhals Ferguson LLP, Kellerhals Ferguson Fletcher Kroblin LLP, Kellerhals Ferguson Fletcher Kroblin, LLP, Kellerhals Ferguson, KFK

39 min read

What this page is, and what it is not

This page is about a law firm, not about Erika Kellerhals. She is its principal and she has a page of her own, which carries her incorporations and notarisations, her trusteeships, the bank’s screening of her, her brokerage on the second island, her channel to the Governor, her election-night messages and her work on the estate. None of that is restated here. This page is about what the firm did as a firm: who else signed for it, what it was retained to do, what it filed, what moved through its accounts, and which arms of the territory’s government it dealt with.

The firm’s own name reaches a floor of 1,991 documents in this release. Of those, 749 carry a firm hand in the authorship position, read on the sheet rather than taken from the project’s attribution of who sent what. That attribution was tested and it was wrong three different ways. Every one of the documents it marks as sent by the firm itself is a party invitation generated by an invitation service, not something the firm wrote. Six further documents it attributes to this firm are invitations to strangers’ weddings, cocktail parties and birthdays with no connection to it at all. And two documents it attributes to the firm’s principal are messages written to her, the name taken off the addressee line. The method section below states every figure and its denominator.

Nothing on this page is a finding of wrongdoing, and none is alleged. A lawyer acting for a client is not evidence of the lawyer’s knowledge, and this page does not treat it as such.

No complainant or survivor appears here in any form. One settlement agreement set out below concerns a former employee’s wrongful-discharge claim; his name is withheld because he is a private individual in an employment matter and his identity adds nothing to the finding, which is the clause he signed.

What it isA law firm in St. Thomas, United States Virgin Islands, which acted for Jeffrey Epstein, for his Virgin Islands companies and for his estate123
Names it used, in orderKellerhals Ferguson LLP (2011-2012); Kellerhals Ferguson Fletcher Kroblin LLP (2013-2014); Kellerhals Ferguson Kroblin PLLC (2014 onward)124
Offices named on its own letterhead9100 Havensight, Port of Sale, Suite 15-16, and 9100 Port of Sale Mall, Suite 15, St. Thomas; from 2016, 9053 Estate Thomas, Suite 101. Its 2013 letterhead foots with three cities: Tampa, the US Virgin Islands and New York, set between vertical rules and quoted in full in the body125
Web addresses on its letterhead and signature blocksKFFKLAW.COM in 2013; kellfer.com thereafter26
Lawyers and staff who sign in this releaseErika A. Kellerhals; Christopher Allen Kroblin; Gregory J. Ferguson, whom the firm’s own rate schedule calls “Greg J. Ferguson”; Brett Geary; Shari N. D’Andrade; Marjorie Whalen; Will Thomas; Shauna Betz; Nicole Miller; Gina M. Bryan, office manager6735
A lawyer who worked thereStacey Plaskett, the territory’s Delegate to Congress, who testified under oath that she joined the firm in 2013 and that Epstein and his businesses remained a client while she was there8
Earliest engagement letter found12 January 2012, for Epstein and L.S.J., LLC in a contract and fraud action. The firm waived its retainer1
Corpus footprint1,991 documents on the firm’s own name forms and domains, a floor; 749 carry a firm hand in the authorship position6

Kellerhals Ferguson Kroblin is a St. Thomas law firm that was Jeffrey Epstein’s Virgin Islands counsel for most of a decade. It changed its name three times in four years as partners came and went, and under each name it did the same work: it formed and served his territorial companies, it applied on his behalf to the arms of the territory’s government that granted him tax benefits and banking licences, it closed property for him and for the people who worked for him, it held and moved his money through its trust account, it settled claims brought by his former employees, and, when he died, it carried his estate through the Superior Court of the Virgin Islands.

Its principal, Erika A. Kellerhals, writes more of this population than anyone else, by a wide margin, and her own page measures that. But she is not the only person who signed for this firm, and the documents that bear other hands are the ones this page is built from.

The firm, its names and its people

The firm’s own paper dates its names. A 12 January 2012 engagement letter goes out under the letterhead “KELLERHALS | FERGUSON”, set as a logo block with a palm device.1 A 2 December 2013 letter to the Lieutenant Governor’s office goes out as “KELLERHALS FERGUSON FLETCHER KROBLIN LLP”.2 An August 2014 memorandum goes out as “Kellerhals Ferguson Kroblin PLLC”, and that is the form it keeps thereafter.4 Earlier still, on 20 October 2011, a message from the firm carries a signature block reading “Kellerhals Ferguson LLP” and “A Full Service Law Firm” above the Havensight address, under the line “PLEASE NOTE OUR NEW ADDRESS BELOW”.9

The firm also advertised more than the territory. Its 2013 letterhead carries a footer, in small capitals across the foot of the sheet, reading “TAMPA | US VIRGIN ISLANDS | NEW YORK”. The footer does not survive into the released text of that sheet at all and was read at the page image.2 No document read for this page says what the Tampa or New York presence consisted of.

Three lawyers are named with their rates in the 2012 engagement letter: Erika A. Kellerhals, Greg J. Ferguson and Christopher Allen Kroblin.1 A March 2012 filing gives Ferguson’s and Kroblin’s Virgin Islands Bar Association numbers as 1065 and 966.7 By the end of the decade the firm’s probate filings are signed by Kroblin with Shari N. D’Andrade, alongside counsel from another firm.3 Marjorie Whalen, Shauna Betz, Nicole Miller, Will Thomas and Gina M. Bryan, the office manager, all appear over the firm’s own name or at its mail domain.6

One name on that list is a sitting member of Congress. Stacey Plaskett testified under oath in 2023 that she went to work for the firm in 2013, that the work she did there was “Predominantly transactional for companies that were in the Virgin Islands and for a few advice related to the economic development”, and, asked whether Epstein and his businesses remained a client of the firm while she was there, answered “Yes.” Asked whether she had herself done any work for Epstein or any Epstein-related business, she answered “I don’t recall.” Her page carries that deposition in full and this one does not repeat it.8

The engagement: 12 January 2012

The earliest engagement letter from this firm found by the searches run for this page is a two-and-a-half page letter to Epstein, sent care of Darren Indyke at a New York address. Seven engagement-shaped documents stand inside this population and none is earlier; that is a floor, not a first. It is the firm’s own statement of what it was engaged to do.

Kellerhals Ferguson LLP (the “Firm”) appreciates the opportunity to provide legal services to Jeffrey Epstein (the “Client”) in the above entitled action.

The scope is narrow and it is commercial:

You have retained the Firm to represent you and L.S.J., LLC regarding the complaint against Nick Labros and AVLC, LLC d/b/a SOUND X in an action for breach of contract and fraud.

L.S.J., LLC is the company that held Little Saint James before it was moved into a territorial corporation. The earliest engagement this page could find is therefore a commercial dispute about the island company, not the corporate work the firm is better known for.

Then the term that is unusual on its face:

It is customary for the Firm to require the payment of a retainer in undertaking a new representation, but in your case we will waive our retainer requirement and simply ask that you return an executed copy of this engagement letter.

The firm waived its retainer for this client. The paragraph that follows sets out what would happen if a retainer were ever paid, and the sentence fixing the minimum balance to be kept in trust is struck through on the face of the letter, the words and the empty parenthesis both ruled out. The released text of that line renders as damage; the image shows a strikethrough, not a loss, and the page follows the paper.1

The rates are on the second sheet, read at the image:

you agree to pay the Firm and to be responsible for paying Erika A. Kellerhals at the hourly rate of Four Hundred Dollars ($400.00), Greg J. Ferguson at the hourly rate of Three Hundred Twenty Five Dollars ($325.00), Christopher Allen Kroblin at the hourly rate of Three Hundred Twenty Five Dollars ($325.00), any Paralegal billings at the hourly rate of One Hundred Thirty Five Dollars ($135.00), and any billable legal assistant work at the rate of Eighty Dollars ($80.00) per hour.

They were guaranteed through 31 December 2012. And one further clause, in the same letter, speaks to something other than the lawsuit it was written for:

If the Firm is required to give testimony through its attorneys and/or other employees, and/or to produce documents or provide other discovery or testimony concerning our representation of you, you agree to pay the time and expenses incurred by this Firm in responding to said requests for testimony and/or other discovery.

That is boilerplate in many American engagement letters, and the page does not suggest otherwise. What it establishes is that from January 2012 the client was contractually responsible for the cost of the firm’s resistance to any subpoena about the representation.1

A former employee, twelve thousand dollars, and a clause about testimony

In February 2013 the firm’s trust account is named on a “CONFIDENTIAL SETTLEMENT AGREEMENT AND RELEASE”. The releasees are L.S.J., LLC, LSJ Employees, LLC, Islands Grounds, Inc. and Jeffrey Epstein. The releasor is a former employee who had brought a wrongful-discharge action and an unemployment claim. This page names neither him nor the two case numbers: he is a private individual in an employment matter, the numbers are the key that retrieves his name from a public docket, and withholding one while printing the other would be no withholding at all. The document itself is cited in full below, so nothing here is unverifiable. Christopher Allen Kroblin signs the instrument as authorised agent for the companies, and a later sheet of the same document carries the account title “KELLERHALS FERGUSON FLETCHER KROBLIN, LLP TRUST ACCOUNT” at the firm’s Havensight address.10

The settlement terms, read at the image:

Releasee agrees to pay Twelve Thousand Dollars ($12,000.00), simultaneous with the execution of this Agreement, without interest, payable on or by February 22, 2012

The sheet dates the agreement to February 2013 and makes the payment due in February 2012, a year earlier. Both readings are printed clearly at the image on the same sheet. This page records the inconsistency and does not resolve it. The same clause then gives a second date, for the filing of a notice of no objection in the unemployment case, in which a digit has been overwritten by hand and initialled in manuscript beside it; the manuscript is not transcribed here.10

And then, on the same sheet, the clause that is the finding:

Releasor shall never assert or pursue any claim or provide any testimony whatsoever arising from, pertaining to or based on the matters herein described or his employment with any of the Released Parties, unless said testimony is in relation to the pending unemployment case.

That is a documented fact about the instrument, and it says what it says. A former employee of the Little Saint James companies agreed, for twelve thousand dollars, never to give testimony about his employment, with a single carve-out for an unemployment claim already pending. Who drafted the clause is not established by this document; what is established is that the firm’s partner executed it for the companies and the firm’s trust account stands on its face. The agreement’s opening recitals, read from the released text rather than the image, record that the parties wished the terms to “forever remain confidential”.10

The firm before the territory’s agencies

The firm’s work was not only private. It appeared for Epstein before the arms of the Virgin Islands government that granted him things.

On 2 December 2013, by hand delivery, it wrote to Mr. John McDonald, Director, Office of the Lieutenant Governor, Division of Banking & Insurance:

This correspondence shall serve as a supplement to the initial application for benefits under the International Banking Entity Act filed by Financial Strategy Group, Ltd. in January 2013. As requested in your email correspondence with Mrs. Cecile deJongh, we are providing the following:

The four enclosures are listed:

  1. Updated Due Diligence Disclosure Affidavit for Mr. Jeffrey Epstein;
  2. Management Organization Chart
  3. List of Jurisdictions
  4. Check in the amount of $10,000.00.

Three things in that letter are findings rather than correspondence. The first is the subject: the firm was pursuing an International Banking Entity licence for an Epstein company. The second is the routing: the Director’s request had come through Cecile de Jongh, whose own page here sets out her employment by Epstein and her marriage to the territory’s then Governor, and the firm addresses the routing plainly in its own first sentence. The third is the enclosure: a due-diligence affidavit for Epstein, filed in December 2013, and a ten-thousand-dollar cheque. The letter is signed in type, “Very truly yours, Erika Kellerhals”, with no manuscript signature standing in the space above the name; this copy is therefore a file copy or an unexecuted one, and the page says so rather than assuming an execution. Read at the image, where the letterhead and its footer are legible and the released text of this sheet carries neither.2

The other agency relationship is the Economic Development Commission, and the firm’s own privileged paper describes a problem inside it.

”Formed incorrectly”: the memorandum of 29 August 2014

One sheet in this population is not a letter and not correspondence. It is a memorandum on Kellerhals Ferguson Kroblin PLLC letterhead, headed “ATTORNEY CLIENT PRIVILEGED COMMUNICATION”, addressed TO: Jeffrey Epstein, Alan Dlugash, FROM: Erika Kellerhals, dated August 29, 2014, and captioned “Application of EDC Credit to Section 1294 Deferral”.4

Its first paragraph is the firm telling its client that two things had gone wrong:

It has recently been determined that an investment that was to have been made in the name of Financial Trust Company, Inc. (“FTC”), an Economic Development Commission (“EDC”) beneficiary, via The Haze Trust (“THT”), was inadvertently titled in the name of Jeffrey Epstein, individually.

And, in the same memorandum:

It is further noted that THT was formed incorrectly as a grantor trust, of which Mr. Epstein was both the grantor and the beneficiary.

Financial Trust Company and the Haze Trust have pages of their own here. What belongs on this page is what the memorandum does: it is the firm, in writing and under privilege, recording that an EDC beneficiary’s investment sat in the wrong name and that an Epstein trust had been “formed incorrectly”, and then reasoning toward the conclusion that the trust “was, at all times, intended to be the owner of the investment”. The memorandum goes on to set out the mechanics of a qualified electing fund election and a Section 1294 deferral running from 1999, and records that on 15 July 2014 an order to liquidate the trust’s interest in Highbridge Capital Corporation, effective 31 August 2014, had been entered.4

The page states what the memorandum says and draws no conclusion about the tax position. Nor does it say who formed the trust: the memorandum does not, and no document read for this page does. Marjorie Rawls Roberts, the territory’s other Epstein tax counsel, is the subject of a separate page.

Money moving through the firm

Her page records that the firm’s accounts appear throughout the bank records in the release, and that it does not total them. Three dated transactions with the firm at one end are set out here, because each is individually documented.

10 November 2015: twenty million dollars. An associate banker at Deutsche Bank Trust Company Americas wrote to two colleagues, under the classification “For internal use only”:

FYI Southern has wired $20MM out to Kellerhals Ferguson Kroblin PLLC… they had a big deal closing.

The released text of that sheet renders the figure as “520MM”; the paper prints “$20MM”, and this page follows the paper. The ellipsis is the writer’s own and is printed on the sheet. “Southern” is Southern Trust Company.11 This is a bank’s internal note about a transfer, not a transfer record, and what the “big deal closing” was is not established by any document read for this page. It is also two months before the January 2016 instruction set out on her page, which told the recipient to send the funds “from the same account you sent them last time”.

7 April 2016: seventy-eight thousand dollars. A bank transfer application records a wire of $78,000.00 from FT Real Estate, Inc. of St. Thomas, through a correspondent bank in Birmingham, Alabama, to a beneficiary at Merchants Commercial Bank in St. Thomas. The special instructions field reads “Real Estate Transaction”. The beneficiary’s account title is “KFK GLOBAL INVESTMENTS”, and the address given for it is 9053 Estate Thomas, Suite 101, St. Thomas. The same transfer appears again as a line in a bank statement in the release.12

That address is the one the firm’s own signature blocks give from 2016, in a building those blocks name as the Royal Palm, or Royal Palms, Professional Building. What relationship, if any, exists between KFK Global Investments and this law firm is not established by any document read for this page. The initials match, the address matches, and an office building has more than one tenant. The page records the match and stops there. No account-class identifier from that sheet is reproduced anywhere on this page.

January 2017: a closing for the island’s manager. On 13 January 2017 Will Thomas, writing from the firm’s office over its signature block, sent an engagement letter for a property closing at Smith Bay, copying Erika Kellerhals and Darren Indyke:

Please find the attached engagement letter for your execution. A title commitment has been requested.

How would you like your name to appear on the deed? What address would you like to use for purposes of the government sending property tax bills?

The addressee was Ann Rodriquez, the manager of Little Saint James, and she forwarded the message to Epstein the same day. In the same message Thomas also asked Indyke a question of his own: “Do you know the attorney representing the seller?” The attachment is named in the header as the firm’s engagement letter.5 Why the client’s own lawyer and the client himself were in the loop on his estate manager’s deed is not explained by any document read for this page.

The firm’s guest list

The firm had Jeffrey Epstein on the guest list for its office parties for at least four years running, and the invitations went to his personal address rather than to his office. The earliest are for the KFFK Holiday Party of November 2013, one of them sent by the firm’s own Shauna Betz; then a Holiday Party in November 2014; the Annual Holiday Party of December 2015; an OFFICE WARMING in May 2016, which is the month the firm’s signature blocks change address; and three messages in December 2016 about a Christmas Party.13

The December 2015 reminder, read at the image, says where:

This is a reminder that the KFK Holiday Party will take place this Saturday, December 12th at 6:00 PM at Sand Bar @ Morning Star Beach Club, 5 Estate Bakkeroe, St. Thomas.

We will also be providing a complimentary shuttle from our offices in Port of Sale, Havensight (next to the FirstBank) to Sandbar from 6 - 10 pm.

Both quotations are from the same message. The released text of that sheet renders the hour as “6:oo”, with letters where the paper prints digits; the two readings above are taken from the image. The invitation card lower on the same sheet names the venue differently, as “Sand Bar at Havana Blue”, against the body’s “Sand Bar @ Morning Star Beach Club”; both stand on the one sheet and this page reproduces both rather than choosing.14 A year later the venue had changed: the December 2016 messages give Saturday 10 December at SandBar @ Havana Blue, with a shuttle from the guard house at the main entrance of the Havensight Mall.15

Every document in this population that the project attributes to the firm itself is one of these invitations, and not one of them was written by the firm. All were generated by a party-invitation service carrying the firm’s name as its display name. In the correspondence, the partnership never writes; its people write. Where the firm does act in its own name it does so on instruments, not in mail: it was the registered agent of the 2011 companies and signed their consents of agent for service of process, which the Laurel, Inc. page carries. This is why the act figures below are built from signatures and not from that column.

The same column is wrong in a larger way, and it is worth stating plainly. Six further documents in the release carry this firm as their sender and have nothing whatever to do with it. All six were read. They are private social invitations sent to Epstein by other people through the same invitation service, and read on the sheet, their own sender lines name the service or name somebody else entirely. They are excluded from this page’s population, nothing from them is counted anywhere here, and their identifiers are not listed, because they concern private individuals and their families and naming them beside what they are would point.13

12 August 2019: the dock

Epstein died on 10 August 2019. Two days later a federal task force went to his island with a search warrant, and the firm was waiting for them.

An FBI situational report timed at 5:30 p.m. on 12 August 2019 records:

At approximately 0855 on 8/12/2019, the Child Exploitation and Human Trafficking Task Force (CEHTTF) approached Little St. James (LSJ) Island and were met on the dock by attorney Christopher Kroblin, his associate and two security personnel. Kroblin advised he was contacted during the evening of 8/11/2019, informed of the pending FBI search warrant and instructed to be on LSJ to meet the search team upon arrival.

Read at the image.16 A later record shows that a copy of the warrant and the inventory of what was seized was left with Christopher Kroblin.17

The sentence that matters is in the passive voice, and the document does not repair it. Kroblin “was contacted” on the evening of 11 August, “informed” of a pending federal search warrant, and “instructed” to be on the island to meet the agents. By whom, in each case, the report does not say, and no document read for this page supplies the answer. What the record does establish is that someone knew of a pending federal search warrant for Little Saint James the night before it was executed, in the words the report itself uses, and that the knowledge reached this firm in time for a partner to be standing on the dock at five to nine the next morning. The report records the question, not its answer, and so does this page.

The estate

The firm’s last documented work for Epstein was administering what he left. The executors petitioned the Superior Court of the Virgin Islands for probate through the firm in August 2019, as the estate page sets out.

The filings that follow are signed by the firm’s lawyers alongside counsel from another firm. A Verified Inventory in Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80, dated 28 February 2020, is subscribed by CHRISTOPHER ALLEN KROBLIN, ESQ., ANDREW W. HEYMANN, ESQ., WILLIAM L. BLUM, ESQ. and SHARI N. D’ANDRADE, ESQ. Earlier filings in the same probate, in November and December 2019, carry the same four names.3 The firm whose lawyers subscribed the articles of the Virgin Islands companies in 2011, and whose own office was their registered address, was still signing for his estate in 2020.

What this page does not establish

  • What KFK Global Investments is. The wire names it, and names an address the firm also uses. No document read for this page states a relationship between them, and none is asserted.12
  • What the November 2015 “big deal closing” was. The bank’s internal note says a closing; no document read for this page says which one.11
  • Who told the firm about the search warrant. The report’s three verbs have no subject and the document does not supply one.16
  • Whether the December 2013 banking application succeeded. The release carries the supplement and the cheque; no document read for this page records a decision on it.2
  • Whether the twelve-thousand-dollar settlement was paid. The agreement provides for payment; no payment record for it was located by the searches run for this page.10
  • Whether the firm was ever asked to testify or produce documents about its representation, which the 2012 engagement letter priced in advance.1
  • It makes no allegation and records none.

How this page is scoped

Measured against the released files on 5 November 2026. The index’s size on disk was compared against its recorded value and printed before every run; every return code was read; no empty result was turned into a zero. Controls printed in the same runs as the counts: a standing firing control returned 567,984 documents / 752,295 sheets; a second, richard m berman, returned 371 documents / 885 sheets, matching this project’s standing figure; and an invented token returned 0.

The population is a union of firm-name forms, and it is a floor. Kellerhals Ferguson, which every one of the firm’s three partnership names contains, returns 1,642 documents. Adding the partner surname Kroblin takes it to 1,947; the mail and web domains kellfer and kffklaw take it to 1,985; three further forms take it to 1,988; five bearer-verified documents on the acronym KFK take it to 1,989; and the acronym KFFK, which the firm used for its own 2013 party, takes it to 1,991. Kellerhals Ferguson Kroblin (1,084), Kellerhals Ferguson Kroblin PLLC (957), Kellerhals Ferguson LLP (221) and Kellerhals Ferguson Fletcher Kroblin (148) each lie wholly inside the 1,642 and add nothing. Six damage candidates were tested as candidates and not as forms; all six are real renderings of the firm’s name and all six lie wholly inside the union, adding nothing.

Two arms were pruned, and both mattered.

The name in this commission is not in this release. Stoller returns 7 documents and Kroblin Stoller returns 0. All seven were read and not one concerns this firm: two are a 2004 courier label bearing an unrelated person’s surname, four are pages of a biography of Elvis Presley naming the songwriters Leiber and Stoller, and one is a cheque drawn to a Florida law firm whose name contains the word. “Kellerhals Ferguson Kroblin & Stoller” does not appear in this release in any form, and nothing from those seven is counted anywhere on this page.

The acronym catches four other things. KFK returns 13 documents. Five are the firm or carry its address and are counted; eight are pruned and read: three are an airline confirmation code, four are extraction noise in scanned material, and one is a run of airport codes in which an aviation log’s JFK has lost its first letter.

Surname-only arms were checked for their bearer. Every document reached by Kroblin alone was checked: the only bearer in this release is Christopher Allen Kroblin of this firm, with the rest of the hits being the firm’s own name with another word between Ferguson and Kroblin. Bare Ferguson was never searched, because it is a common surname and a different population. Bare Kellerhals was never used as the firm, because it conflates the firm with its principal and with any other bearer; her page scopes that token.

The firm’s solo professional corporation is deliberately excluded. Erika A. Kellerhals PC returns 218 documents, 109 of them outside the firm-name union, and the handle at that corporation’s domain returns four more. Those are her own mail identity and her page counts them; counting them here would make this page a second page about her. The exclusion costs this population at least 113 documents and it is a scoping choice, not a measurement.

Authorship was read on the sheet, not taken from the project’s attribution of who sent what. That attribution marks 681 documents in this population with a firm name. Tested against the top-of- message authorship line on each sheet, 597 agree; 3 were caught by the instrument as a party-invitation service, and the rest of that class by hand, carrying the firm’s display name; 54 carry an authorship label with no value in the released text; 12 have no such label on their first sheet; and 9 disagreed outright and were read by hand. Of those nine, seven are the firm’s after all and the instrument was at fault: this production renders the label From: as Fran: on some sheets, and renders the name itself as damage on others, in both cases with the firm’s signature block standing intact below. Two are genuinely not the firm’s: both are messages written to Erika Kellerhals whose attribution was taken from the addressee line. The attribution was therefore wrong in both directions, as this desk has now found four times, and the error here is small: 5 of 681.

The reverse test returned nothing. Of the 581 documents in this population with no attribution at all, none has a firm person in the authorship position on its first sheet, and no document in the population carries the “on behalf of” form that has hidden authorship elsewhere in this release. That is a negative result on a test that has been positive before, and it is a bound: the test reads the first sheet’s header only.

Every document the project attributes to the firm itself was then read by hand, because the instrument caught only the three whose sender address survived into the released text. All are the same class, a party invitation, and all are excluded from the act count below; four had been counted as acts before they were read, and the figure here is the corrected one.

The act count, with its denominator. Against the full population of 1,991, 607 documents carry a firm hand in a top-of-message authorship line, and 146 non-mail instruments carry a firm signature block, 4 of them in both classes. The union is 749 signed firm acts, which is 37.6 per cent of the floor. On the narrower 1,642 the figure is 620, or 37.8 per cent. A first count of the second arm returned 1,150 and was discarded: it searched whole documents and was therefore counting signature blocks quoted inside other people’s replies, which are mentions and not acts. The figure above is the corrected one, and it is a floor, because an unsigned instrument the firm drafted cannot be told from one it did not.

The project’s own labels for these documents are unreliable and three were caught here. The firm’s 2012 engagement letter and the 2013 settlement agreement are both labelled as plea agreements, which neither is. A hundred-sheet probate inventory is labelled a travel itinerary. The August 2014 memorandum on firm letterhead is labelled as a mail header. Every shape figure on this page is an estimate for that reason, and no claim here rests on a label.

Eight sheets were read at the page image. Each was fetched read-only from the site’s own per-document path; every batch carried a negative control, which returned HTTP 403 at 111 bytes, and a wrong-route control, which returned HTTP 404, while every target returned HTTP 200 and a file beginning %PDF-. Every one is served at a native 96 pixels per inch, every page count matches this project’s sheet count for that document exactly, and every reading is taken from the native raster.

The paper corrected the released text in seven places that matter here, and this page follows the paper in all seven. A bank’s internal note that the released text renders 520MM prints $20MM. A party reminder that renders 6:oo PM prints 6:00 PM, and the shuttle hours it runs together as 6 -10 pm print as 6 - 10 pm. A letter’s enclosure list that renders Disdosure prints Disclosure. The engagement letter’s client name, which the released text renders L.$ J., LLC, prints L.S.J., LLC. That same letter’s trust-balance line, which renders as damage, is a strikethrough on the paper and not a loss. And a letterhead footer naming three cities, “TAMPA | US VIRGIN ISLANDS | NEW YORK”, does not survive into the released text of its sheet at all. Seven is a floor, and no claim is made that the released text of these sheets is accurate anywhere else.

Nothing in this population is a native spreadsheet attachment. The sixteen documents in this release that carry a native-attachment marker were enumerated through that marker family, and the intersection with this population is empty.

  • Erika Kellerhals, the firm’s principal, whose page carries her own acts: the incorporations and notarisations, the trusteeships, the brokerage, the channel to Government House, and the work on the estate
  • Stacey Plaskett, who worked at this firm from 2013 and testified about it under oath in 2023
  • Darren Indyke and Richard Kahn, the New York lawyers the firm’s engagement letter was routed through and who instructed the transfers
  • Cecile de Jongh, through whom the Lieutenant Governor’s office relayed its request on the banking application
  • Southern Trust Company, Financial Trust Company and the Haze Trust, the entities named in the firm’s banking application, its privileged memorandum and the November 2015 transfer
  • L.S.J., LLC, the client named in the firm’s first engagement letter, and Little Saint James, the island its partner was standing on when the search team arrived
  • Ann Rodriquez, the island’s manager, for whom the firm handled a property closing in 2017
  • Hodge & Francois, another Virgin Islands firm in the same cluster
  • The Epstein estate and the territory’s investigations and forfeitures

Footnotes

Footnotes

  1. Engagement letter on Kellerhals Ferguson LLP letterhead, “January 12, 2012,” addressed to Jeffrey Epstein care of Darren Indyke, “Re: Representation / Litigation.” Sheets 1 and 2 read at the page image at the asset’s native 96 ppi. The letterhead is a logo block setting “KELLERHALS” and “FERGUSON” either side of a palm device; the released text of that sheet runs the two words together. The sentence fixing the minimum trust balance is struck through on the paper, words and parenthesis together, which is what the released text renders as damage. The paper prints the client company as “L.S.J., LLC”; the released text of this sheet renders it “L.$ J., LLC,” and the quotation above follows the paper. The sheet is justified, so inter-word spacing varies and is not reproduced. The document is labelled a plea agreement by this project and is not one. https://epstein-data.com/EFTA00298982 pp. 1-2. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  2. Letter on Kellerhals Ferguson Fletcher Kroblin LLP letterhead, “December 2, 2013,” marked “Via Hand Delivery,” to Mr. John McDonald, Director, Office of the Lieutenant Governor, Division of Banking & Insurance, “Re: Financial Strategy Group, Ltd. IBE Application Supplement.” Read at the page image at native 96 ppi. The letterhead gives 9100 Port of Sale Mall, Suite 15, and the web address KFFKLAW.COM, and the sheet foots “TAMPA | US VIRGIN ISLANDS | NEW YORK”; none of the letterhead or the footer survives into the released text of this sheet. The paper prints “Disclosure” where the released text gives “Disdosure,” and prints “deJongh” run together. The enclosure list is quoted as the paper sets it, including the extra space before “Management.” The signature space above the typed name is blank. https://epstein-data.com/EFTA00306116 p. 1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  3. “Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80, Verified Inventory,” dated February 28, 2020, subscribed by CHRISTOPHER ALLEN KROBLIN, ESQ., ANDREW W. HEYMANN, ESQ., WILLIAM L. BLUM, ESQ. and SHARI N. D’ANDRADE, ESQ. These readings are from the released text and were not checked at the image. Filings of 14 November 2019 and 13 December 2019 in the same probate carry the same four names at https://epstein-data.com/EFTA00098133 and https://epstein-data.com/EFTA00100674. https://epstein-data.com/EFTA00076892 p. 5. ↩ ↩2 ↩3 ↩4

  4. Memorandum on Kellerhals Ferguson Kroblin PLLC letterhead, “ATTORNEY CLIENT PRIVILEGED COMMUNICATION,” TO: Jeffrey Epstein and Alan Dlugash, FROM: Erika Kellerhals, DATE: August 29, 2014, RE: “Application of EDC Credit to Section 1294 Deferral.” Read at the page image at native 96 ppi. The sheet sets its quotation marks typographically, as “FTC,” “EDC” and “THT,” and the straight marks used above are this page’s rendering and not the paper’s form. A manuscript initial stands beside the FROM line and is not transcribed. The document is labelled a mail header by this project and is a memorandum. https://epstein-data.com/EFTA01197606 pp. 1-2. ↩ ↩2 ↩3 ↩4

  5. Will Thomas, Kellerhals Ferguson Kroblin PLLC, 13 January 2017, subject “Closing 1-6-17 Smith Bay,” copied to Erika Kellerhals and Darren Indyke, forwarded the same day by Ann Rodriquez to Jeffrey Epstein. These readings are from the released text and were not checked at the image. The header names the attachment as the firm’s engagement letter. Thomas’s signature block gives Royal Palms Professional Building, 9053 Estate Thomas, Suite 101. The three quoted sentences are from the one message. https://epstein-data.com/EFTA01056787 p. 1, and the forwarded copy at https://epstein-data.com/EFTA01056806 p. 3. ↩ ↩2 ↩3

  6. Page pins on this page are 1-indexed and count the sheets of the document as the viewer serves them, so “p. 1” is the first sheet. All counts were taken on this project’s page-level index, resolving row identifiers to document identifiers, and were re-run after the last edit to this page. The index’s size on disk was compared against its recorded value and printed in every run. Counts of documents are distinct document identifiers, never index row counts, which count sheets. The firm’s mail and web domains were harvested by reading the firm’s own signature blocks and court-filing signature pages; the domains are named on this page and no individual address at them is reproduced. The roster of lawyers and staff was built from names standing in the signature position immediately above a line carrying the firm’s name, and every name on it was checked against a document. Two names supplied to this page as the firm’s own were checked and are not: both are Deutsche Bank employees and both have pages of their own here. A third name reached through this population is also a Deutsche Bank banker and is not firm staff. ↩ ↩2 ↩3 ↩4

  7. Filing of March 2012 subscribed by “GREG J. FERGU[SON], ESQ.” and “CHRISTOPHER AL[L]EN KROBLIN, ESQ.,” giving “VI Bar Association Nos. 1065 and 966” under the firm name “KELLERHALS FERGUSON LLP” at 9100 Havensight. This reading is from the released text and was not checked at the image. The extraction drops characters from both surnames on this sheet; only the two bar numbers are taken from it, and the lawyers’ full names on this page come from the engagement letter, which was read at the image. https://epstein-data.com/EFTA00298125 p. 1. ↩ ↩2

  8. Videotaped deposition of Stacey E. Plaskett, 9 May 2023, in the civil action numbered 1:22-cv-10904 in the Southern District of New York, transcript page 86. The passage on the Kellerhals firm, her account of the work she did there, her “I don’t recall” and her “Yes” are quoted and pinned in full on her page, which read the sheets at the image; they are not re-derived here. The grammar of “a few advice” is the transcript’s. The transcript interleaves line numbers and times through every answer, so the quoted answer, which is continuous on the page, is given without them; nothing inside it is cut and no two answers are joined. The quoted words were verified against the released text of this document for this page, fragment by fragment, as well as resting on her page’s image readings. https://epstein-data.com/EFTA02807627 ↩ ↩2

  9. Message of 20 October 2011 whose body carries the firm’s signature block, “ERIKA A. KELLERHALS,” “PLEASE NOTE OUR NEW ADDRESS BELOW,” “Kellerhals Ferguson LLP,” “A Full Service Law Firm,” and the Havensight address. This reading is from the released text and was not checked at the image; the authorship label on this sheet is damaged, and the message is attributed to the firm here on the strength of the signature block, not the header. https://epstein-data.com/EFTA02181467 p. 1. ↩

  10. “CONFIDENTIAL SETTLEMENT AGREEMENT AND RELEASE,” February 2013, between a former employee and L.S.J., LLC, LSJ Employees, LLC, Islands Grounds, Inc. and Jeffrey Epstein. Printed sheet 2, carrying the settlement terms, the waiver of causes of action and the confidentiality clause, was read at the page image at native 96 ppi; the quotations above are from that sheet. The recitals quoted as “forever remain confidential” are on printed sheet 1 and are from the released text, not checked at the image. The signature sheet is subscribed by Christopher Allen Kroblin as authorised agent, and a later sheet carries the account title “KELLERHALS FERGUSON FLETCHER KROBLIN, LLP TRUST ACCOUNT”; both readings are from the released text. A handwritten correction and manuscript initials stand beside the second date in the settlement clause and are not transcribed. The releasor’s name is withheld by this page. The document is labelled a plea agreement by this project and is not one. https://epstein-data.com/EFTA00296349 pp. 1-5. ↩ ↩2 ↩3 ↩4

  11. JJ Litchford, Associate Banker, Deutsche Bank Trust Company Americas, to Paul Morris and Stewart Oldfield, 11/10/2015 12:09:23 PM, subject “STC wires,” classified on its face “For internal use only.” Read at the page image at native 96 ppi, where the figure prints “$20MM”; the released text of this sheet renders it “520MM,” and this page follows the paper. The ellipsis is printed on the sheet. The sheet carries Rule 6(e) confidentiality stamps and a Deutsche Bank production number. A second copy of the same message is at https://epstein-data.com/EFTA01352988. https://epstein-data.com/EFTA01346202 p. 1. ↩ ↩2

  12. Bank transfer application dated 4/7/2016 for US $78,000.00 from FT Real Estate, Inc., St. Thomas, to a beneficiary whose account title is given as “KFK GLOBAL INVESTMENTS” at “9053 ESTATE THOMAS, SUITE 101,” St. Thomas, through a correspondent bank in Birmingham, Alabama, with “Real Estate Transaction” in the special-instructions field. Read at the page image at native 96 ppi. The sheet carries account-class identifiers; none is reproduced here, in whole or in part, and none is located. The same transfer stands as a dated line in a bank statement in the release at https://epstein-data.com/EFTA01273089 p. 3. https://epstein-data.com/EFTA01186608 p. 1. ↩ ↩2

  13. The firm’s party invitations to Jeffrey Epstein’s personal address, all generated by a party-invitation service and all carrying the firm’s name: https://epstein-data.com/EFTA01132566 and https://epstein-data.com/EFTA01753180 (November 2013, “KFFK Holiday Party”), https://epstein-data.com/EFTA01140584 (3 December 2013, “KFFK Holiday Party Invitation,” sent by Shauna Betz of the firm), https://epstein-data.com/EFTA01797890 (25 November 2014, “Holiday Party”), https://epstein-data.com/EFTA01131133 (20 November 2015) and https://epstein-data.com/EFTA00645178 (9 December 2015, “Annual Holiday Party”), https://epstein-data.com/EFTA00654763 (9 May 2016, “OFFICE WARMING”), and https://epstein-data.com/EFTA01793736, https://epstein-data.com/EFTA01787940 and https://epstein-data.com/EFTA01786737 (3 and 8 December 2016, “Christmas Party”), each p. 1. Subjects and dates are from the released text of each sheet; only the 9 December 2015 sheet was read at the image. The six documents attributed to this firm that have nothing to do with it were each opened and read at p. 1, and their identifiers are deliberately not listed here: they are private social invitations concerning private individuals and their families, their own sender lines name the invitation service or a different person, and none of them is counted anywhere on this page. ↩ ↩2

  14. Invitation reminder carrying the firm’s name as its display name, sent by a party-invitation service to Jeffrey Epstein’s personal address, dated Wed, 09 Dec 2015, subject “Update: Annual Holiday Party.” Read at the page image at native 96 ppi, where the hour prints “6:00 PM” and the shuttle hours print “6 - 10 pm”; the released text of this sheet renders them “6:oo PM” and “6 -10 pm.” Both quotations above are from the same message. The invitation card lower on the same sheet names the venue “Sand Bar at Havana Blue 5 Estate Bakkeroe, St. Thomas,” where the body names “Sand Bar @ Morning Star Beach Club, 5 Estate Bakkeroe, St. Thomas”; both stand on the one sheet and neither is preferred here. https://epstein-data.com/EFTA00645178 p. 1. ↩

  15. Invitation carrying the firm’s name as its display name, sent by the same service to the same address, dated Thursday, December 8, 2016, subject “Update: Christmas Party,” for Saturday 10 December at SandBar @ Havana Blue, with a shuttle from the guard house at the main entrance of the Havensight Mall. This reading is from the released text and was not checked at the image. The sheet carries quoted-printable = characters through its body, which are a mail-encoding artefact of the export and not a producer’s treatment; no damaged span is quoted above. Two further copies stand at https://epstein-data.com/EFTA01793736 and https://epstein-data.com/EFTA01797890. https://epstein-data.com/EFTA01786737 p. 1. ↩

  16. Federal Bureau of Investigation situational report, marked UNCLASSIFIED//FOUO, “as of 5:30 p.m. EDT 08/12/2019.” Read at the page image at native 96 ppi. Only the bullet concerning the approach to the island is quoted; the remainder of the sheet concerns matters outside this page’s subject and nothing from it is quoted, summarised or counted. A second copy stands at https://epstein-data.com/EFTA00165454. https://epstein-data.com/EFTA00147294 p. 1. ↩ ↩2

  17. Search-warrant return recording “Copy of warrant and inventory left with: Christopher Kroblin,” August 2019. This reading is from the released text and was not checked at the image. https://epstein-data.com/EFTA00277513 p. 2. ↩

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