Epstein Data Wiki

LSJE, LLC and L.S.J., LLC

Properties2
tagsentity, virgin-islands, epstein-company, little-saint-james
aliasesLSJE, LSJE LLC, LSJ Employees, LSJ EMPLOYEES, L.S.J. LLC, LSJ LLC

42 min read

L.S.J., LLCLimited liability company organised under the laws of Delaware; owner of record of Little St. James Island from 1998 until 2011123
LSJE, LLCLimited liability company organised under the laws of the U.S. Virgin Islands, formerly LSJ Employees, LLC; articles of organization filed October 27, 201145
Name changeCertificate of Amendment filed March 13, 20135
Sole member of eachJeffrey E. Epstein1256
Address6100 Red Hook Quarter B3, St. Thomas, VI 0080215
Registered agent, LSJEBusiness Basics VI, LLC, 9100 Port of Sale Mall, Suite 15, St. Thomas5
BanksFirstBank, Puerto Rico; Deutsche Bank Trust Company Americas78
Island title transferredTo Nautilus, Inc. by quitclaim deed executed December 23, 2011, recorded December 30, 201119

L.S.J., LLC was a Delaware limited liability company that held title to Little St. James Island in the U.S. Virgin Islands from April 1998 until December 2011, when Jeffrey Epstein, as its sole member, quitclaimed the island to Nautilus, Inc.19 LSJE, LLC, a separate Virgin Islands company organised in October 2011 under the name LSJ Employees, LLC, held the island’s operating and payroll accounts.45710 Epstein is named as sole member of both.25 The two names are close and the documents run them together, so this page treats them separately and says which company each instrument names.

L.S.J., LLC

Title to the island

The quitclaim deed of December 2011 recites the earlier conveyance: the premises were conveyed to L.S.J., LLC “by Warranty Deed dated April 27, 1998 and recorded May 15, 1998 in Book 49-T, Page 494 Doc. No. 1988 and entered in Aux 52, Page 141 in the Office of the Recorder of Deeds for St. Thomas and St. John.”1 The property is described as Parcel Nos. A, B and C, Little St. James Island, No. 6B Red Hook Quarter, of approximately 36.7, 23 and 11.8 acres.1 Those three figures total 71.5 acres, or about 3,114,500 square feet, which is the “3.1 million square feet” the Government of the Virgin Islands pleaded for the same parcel nine years later from the Recorder’s records; the two descriptions agree to the precision each states.11 The 1998 warranty deed itself is not among the documents cited here, and these pages do not state what was paid for the island.

An FBI senior financial investigator on Squad C-40 (FAST) traced the same chain in August 2019, writing that “The Last Deed of Record, dated 12/23/2011, indicates Nautilus Inc as holding the title. L.S.J. LLC was the previous owner. Epstein is/was the sole beneficial owner of both entities.”12 A separate FBI email exchange the week before, in a different thread on the last deed of record specifically, records that the 1998 deed could not be pulled online.13

A draft complaint in the Superior Court of the Virgin Islands, brought in the names of Jeffrey Epstein and L.S.J., LLC against Fancelli Paneling, Inc. and Atelier Fancelli, describes the company in the same terms: “The Plaintiff, L.S.J., LLC (‘LSJ’), is a limited liability company organized under the laws of Delaware, is the owner of Little St. James Island located off the coast of St. Thomas, United States Virgin Islands and maintains its principal address in the United States Virgin Islands.”3 The pleading concerns library cabinetry for the island’s Office Pavilion, designed by Juan Pablo Molyneux and fabricated by Fancelli, and pleads damages “that include but are not limited to $780,000, plus additional” sums14. The same figure appears on that page as “the $780,000 price of the Library Cabinetry”, so the sum pleaded as damages is the price of the work14. The copy of this complaint in the release is an unsigned redline: its caption reads “CASE NO. ST-10-CV-”, its date line prints “Dated: July” above ”, 2010” with the day left unfilled, and no row of underscore characters appears on the sheet, the signature line above counsel’s name is blank, and change bars in the margin mark tracked insertions adding Atelier Fancelli as a co-defendant and a jury demand.15 A blank signature block shows only that this copy was not signed; it is not evidence that the action was never filed or that no settlement followed.

The action was in fact commenced. An affidavit of Denise Francois, a partner at Hodge & Francois, describes herself as “legal counsel of record for the Plaintiffs Jeffrey Epstein and L.S.J., LLC … in the above-captioned action.”16 It carries a Superior Court received stamp of June 21, 2011, captioned Jeffrey Epstein and L.S.J., LLC, Plaintiffs, against Fancelli Paneling, Inc., Defendant, Case No. ST-10-CV-443, an action for damages with a jury trial demanded.16 The affidavit recites that on December 30, 2010 the Plaintiffs and Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. had entered a confidential Settlement Agreement and Release, and that counsel held “a true and correct copy of the Confidential Agreement duly executed by the Plaintiffs and Molyneux.”16

That settlement recites that disputes had arisen between Molyneux and Studio, on one side, and LSJ and Epstein on the other, over “payments and deliverables in connection with design and related services by Molyneux for LSJ and/or Epstein with respect to Little St. James Island and other properties beneficially owned by Epstein” (the ‘Disputes’), and that the Parties were also parties to “a lawsuit now pending before the District Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. 3:10-cv-00034” (the ‘Lawsuit’).17 That lawsuit is a different case from the Fancelli action. The signature page of the December copy carries the blocks for Molyneux, individually and as President of J.P. Molyneux Studio, Ltd., and for Epstein personally and for L.S.J., LLC as Member; the same two-page block is scanned twice at the end of the file1819. The extraction captures script above Molyneux’s printed name and nothing above Epstein’s, which does not distinguish a line left blank from one the scan did not resolve, and this page has not read the signatures at the image; what attests execution is counsel’s affidavit, which states she held a copy “duly executed by the Plaintiffs and Molyneux”16. Under its terms Molyneux was to pay Epstein $500,000, in four installments of $125,000 due within five business days and thirty-five, sixty-five and ninety-five days of the Effective Date, four payments that sum exactly to the stated Settlement Sum, releasing claims connected with the Disputes and the Lawsuit.20 Billing records from Hodge & Francois, counsel for Epstein and LSJ in both matters, describe their work that August as “Molyneux v Epstein, et al.” and show the firm drafting a memorandum in support of the defendants’ motion to dismiss and researching rescission of a settlement agreement, in the months before the December agreement was signed.21 An earlier agreement among the same parties, dated in May 2009, had settled a first dispute over the same design relationship by having Molyneux pay Epstein $1,200,000.22 The 2009 agreement did more than that. Besides the cash it required Molyneux to “credit Epstein’s account with Studio in the amount of Two Hundred Fifty Thousand Dollars ($250,000)” against future services, billed “at a rate equal to Five Hundred Dollars ($500) per hour” for Molyneux himself and at “the lower of Eighty Dollars ($80) per hour or the standard billing rates” for his staff.23 Its own payment clause falls due “On or before May 15, 2009”,22 and the first written Design Services Agreement between the same parties is dated May 15, 2009, so the first dispute was settled and the design relationship put in writing on the same day.24

What the December settlement was drafted around

The executed settlement is built around the Fancelli action, which it never joins. Section 3(a) releases Molyneux but provides that “nothing provided herein shall release Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any such Fancelli entity (collectively, the ‘Fancelli Group’), from any Claims whatsoever”25. Section 4(a) has Epstein and LSJ covenant not to sue Molyneux while expressly preserving any claim “against any one or more persons or entities of the Fancelli Group”, and records that “this covenant not to sue is a material inducement for Molyneux to enter into this Agreement”26. Section 4(c) then promises that Epstein and LSJ “shall not seek to enforce against the Molyneux Releasees” any judgment obtained against a Fancelli entity, and that Fancelli’s claims against Molyneux for “contribution, indemnification, or apportionment of liability” shall require no payment from Molyneux “regardless of any finding or apportionment of liability”; a closing sentence states that nothing in the agreement limits “the liability to Epstein and/or LSJ of any such Fancelli entity”.2627 The effect of those three provisions together is that Epstein kept his claim against the fabricator and gave up any route by which the fabricator’s losses could travel back to the designer.

⚠ None of that language is in the earlier drafts. Two further renderings of the same instrument are in the release, each dated in November 2010 on its own face, with the day left blank, each thirteen pages against the executed copy’s seventeen, and the word Fancelli does not appear in either of them at all: no carve-out, no preserved claim, no Section 4(c).28 The Fancelli architecture was therefore added between November and the execution date of December 30, 2010. Paragraph 8 of the executed agreement provides that “the prior drafting and negotiating history of this Agreement shall not be used to construe any term of this Agreement”29; the release contains that history.

Paragraph 7 provides that “the existence, terms, and consideration paid pursuant to this Agreement are strictly confidential” and that it will not be filed in any court except to enforce it or the Office Design Agreement.30 Paragraph 20 sends any dispute under it to a named private decision-maker, “retired District Judge Hon. Thomas Moore”, with Molyneux permitted to testify by videoconference from New York County and not required to appear in any other forum.31

The Office Design Agreement

The instrument Paragraph 7 names is also in the release. “THIS AGREEMENT FOR OFFICE DESIGN SERVICES (‘Office Design Agreement’)” is made as of a day in November 2010, the day left blank, among the same four parties, in exchange for “One Dollar ($1.00) and other valuable consideration”, and requires Molyneux to ship the items on a Schedule 1 to Epstein in St. Thomas at Molyneux’s expense within ninety days.32 A modification of May 2011 recites that the parties entered it “on or about December 30, 2010”, which is the settlement’s date, and describes the Schedule as a one-page document dated November 15, 2010 bearing the designation “01901 - LSJ - Sarah’s Office”, whose requirements concern “a lamp, a rug, two chairs, and a desk”; the lamp had been delivered and accepted and the rug and chairs approved, while “certain disputes have arisen regarding the desk”.33 So the agreement paired with a $500,000 settlement of a multi-million-dollar design dispute has four items of furniture for one room as its entire subject matter.

Its second paragraph is a disclaimer: “Epstein acknowledges and agrees that neither J.P. Molyneux nor Studio is an architect, that neither has been held out as an architect to Epstein, and that this Office Design Agreement does not involve the rendering of any architectural services.”32 The recital of the May 2009 agreement had described the same relationship as “architectural and design and related services”;22 the December 2010 settlement’s recital drops the first word and reads “design and related services”.17 The documents cited here do not state why the characterisation changed.

The two instruments of the same date also differ in how each is to be enforced. Epstein’s sole remedy for non-payment under the settlement is the unpaid balance of the Settlement Sum;34 his sole remedy for a material breach of the Office Design Agreement is “liquidated damages of Fifty Thousand Dollars ($50,000)”, and disputes under it go not to Judge Moore but to “arbitration before the American Arbitration Association (‘AAA’) by a single arbitrator”.35

The course of the Fancelli action

The release does show what became of the Fancelli action, at least into the summer of 2011. By Memorandum Opinion and Order of May 16, 2011 the Superior Court held, as quoted in a later filing, that “Plaintiffs must join Molyneux as a necessary party. The Court will deny the Motion to Dismiss, but will direct Plaintiffs to join the necessary party”, reasoning that “Without Molyneux Studio in the case, the Court would be hard-pressed to accord complete relief among Plaintiffs and Fanelli [sic]” and that it “lacks jurisdiction to compel the production of documents or depositions outside the Territory”.36 The Court required a Second Amended Complaint adding Molyneux Studio to the caption within fourteen days.37

Epstein and LSJ sought reconsideration on the ground of manifest injustice, relying on the confidential settlement. The time to file was extended to June 21, 2011,37 and the affidavit of Denise Francois quoted above, which sets out Paragraphs 5, 6 and 7 of the confidential agreement and nothing else of it, bears the Superior Court’s received stamp of that same day.1638 An agreement whose own Paragraph 7 said it would not be filed in any court was thus put before a court, in part, by the party it protected.

Fancelli’s opposition of July 5, 2011 is also in the release, and the characterisations in it are its own. It argues that the confidential agreement “arises out of the same transaction or series of transactions as the captioned action, including Molyneux’s Purchase Order with Defendant, as to which the Court has found Plaintiffs to be third party beneficiaries”, and that it “is dated December 30, 2010, a scant two days after the sworn Affidavit of Juan Pablo Molyneux was submitted in opposition to Defendant’s Motion to Dismiss”.39 It reads the agreement as “relieving Molyneux of $1,200,000 of potential liability to Plaintiffs and an additional $250,000 of liability under the Design Services Agreement”, which are the two sums the 2009 agreement had imposed, which together are $1,450,000 against the $500,000 Molyneux agreed to pay.40 It dates the two actions against each other: “Molyneux’s filing of the federal action against Epstein April 10, 2010 and Epstein filing the instant action against Fancelli July 30, 2010”, and says of the settlement that “The resulting machinations of private interests could not contractually circumvent the rules”.41 Those are a litigant’s submissions on a contested motion, not findings.

The same filing sets out the contractual chain the claim ran along. Fancelli was retained not by Epstein but by Molyneux, “By Purchase Order #2680 dated June 15, 2006 … to fabricate and install cabinetry for the OFFICE & SITTING AREA of this project”, replaced by “Purchase Order #7106 dated October 14, 2008”; Epstein and LSJ sued on it as third-party beneficiaries.2439 Fancelli describes that purchase order as “the sole ‘contract’ between Molyneux and Defendant, consisting of 41 words with reference to ‘JPM design,’ which was based on Escorial in Spain”, a plan it says was rejected and replaced by an “Exotic” design for which no drawing was produced to it.42 The documents cited here do not show how the action ended.

Authority to act for the company

An undated Grant of Authorization signed by Epstein, over the printed line “Jeffrey E. Epstein, Sole Member of L.S.J., LLC,” recites that “The Undersigned, Jeffrey E. Epstein, being the sole member of L.S.J., LLC, a limited liability company organized under the laws of the State of Delaware (the ‘Company’) which is the owner of record title to the real property located in the United States Virgin Islands and known as Little St. James Island” authorises named attorneys and an agent to execute applications, affidavits and permits for the company before the Department of Planning and Natural Resources and other agencies.2 It supersedes all prior grants and is stated to remain in force until March 1, 2010.2

Earlier, Paul Hoffman certified on a Virgin Islands coastal zone permit that he was “Attorney for L.S.J., LLC., LITTLE ST. JAMES, LLC” and “duly authorized and empowered to sign this Permit on behalf of” the company; the certification is signed and notarised on December 15, 1999.43 The notices clause of that permit directs correspondence, if addressed to the Permittee, to “L.S.J.,LLC, Little St. James Islands Inc. c/o Paul Hoffman, 41-42 Kongens Gade, P.O. Box 870, St. Thomas, Virgin Islands, 00804,” or to such other place as later designated by certified mail.44 These alternative forms appear in permit instruments and the documents cited here do not show separate companies behind them.

The 2011 restructuring discussion

On November 21, 2011 the attorney Erika Kellerhals of Kellerhals Ferguson LLP wrote to Epstein and others about several matters then open, among them an application to the Virgin Islands Economic Development Commission and the ownership structure to be used for it.45 Under the heading “Transfer of LSJ/Permits” she wrote: “In an effort to transfer the LSJ property from the existing Delaware LLC into CDE, Inc. a USVI S corporation – I had suggested that we merely redeed the parcel as there is a specific exemption from stamp tax in the VI Code for a corporate reorganization. So we could do it with minimal expense.”45 The memorandum then sets out the transfer procedure for each class of permit the island held, coastal zone, building, territorial discharge and environmental protection, noting that coastal zone permits can be transferred without reapplication under 12 V.I.R. Reg. § 910-15 and that discharge permits transfer automatically on thirty days’ notice.46 On the coastal zone permits specifically, she wrote that “In this circumstance – where the same person owns a beneficial interest in the transferor and transferee entity – I suspect we can streamline the process.”46 She added that she had “asked for confirmation in writing that where the beneficial owner of the entity remains the same, the process can be completed by affidavit.”46 The conveyance made a month later was to Nautilus, Inc., a Virgin Islands corporation, and not to the S corporation named in the memorandum; the affidavit asserting the stamp-tax exemption is the one discussed below.1

Transfer to Nautilus, Inc.

The quitclaim deed is made “the 23rd day of December, 2011, between L.S.J., LLC, a Delaware limited liability company with an address of 6100 Red Hook Quarter, Suite B-3, St. Thomas, VI 00802 (‘Grantor’), and Nautilus, Inc., a U.S. Virgin Islands corporation with an address of 9100 Havensight, Port of Sale, Ste 15-16, St. Thomas, VI 00802 (‘Grantee’).”1 It recites that Grantor conveys the property to Grantee in consideration of ten dollars and other good and valuable consideration.1 It is signed over the line “BY: JEFFREY E. EPSTEIN, Sole Member,” witnessed, and acknowledged the same day before the notary Erika A. Kellerhals, the same attorney whose November 2011 memorandum on the island’s restructuring is discussed above.9 The recording stamp reads Doc# 2011009441, five pages, December 30, 2011 at 11:23 a.m., Office of the Recorder of Deeds for St. Thomas and St. John.1 The copy in the release also carries a fax transmission header from Kellerhals Ferguson LLP dated December 28, 2011, two days before recording.1

An affidavit filed with the deed, sworn two days earlier on December 21, 2011, is made by Epstein “as the President and the sole beneficial owner of Nautilus, Inc. … and the sole member of L.S.J., LLC” and asserts an exemption from stamp taxes under 33 V.I.C. §128(a)(6) on the footing that the conveyance is “for no consideration, between subsidiary entities, all beneficially owned by Jeffrey E. Epstein.”47 The affidavit describes the instrument it accompanies as a warranty deed of even date; the recorded instrument is a quitclaim deed dated the 23rd.147 The same page carries a manuscript notation giving a value for recording purposes of $6,442,100.00; the caption is handwritten and this page has not read it at the image, but the figure itself is corroborated in print elsewhere in the release, as set out below.4748

A Real Property Tax Clearance Letter from the Virgin Islands Office of the Tax Collector, dated December 27, 2011, certifies that there are no outstanding real property tax obligations for parcel number 1-09803-0101-00, Little St James Island, Red Hook, owner’s name L.S.J., LLC, and records that taxes had been researched “up to and [i]ncluding 2008”49, the bracketed character marking a capital the form prints and this page does not.

LSJE, LLC

Formation and name

A Certificate of Existence issued by the Office of the Lieutenant Governor of the Virgin Islands on July 9, 2018 certifies “That LSJE, LLC formerly: LSJ EMPLOYEES, LLC filed Articles of Organization with the Office of the Lieutenant Governor on October 27, 2011 and the Company is duly organized under the laws of the United States Virgin Islands,” that its duration is unlimited, that all fees have been paid and that articles of termination have not been filed.4

The company’s Amended and Restated Operating Agreement, made as of March 13, 2013 by Epstein “(hereinafter referred to as ‘Sole Member’), with an address at 6100 Red Hook Quarter, B3, St. Thomas, USVI 00802, who formed LSJE, LLC, a United States Virgin Islands limited liability company” records the same filing date and states that a Certificate of Amendment was filed with the Office of the Lieutenant Governor on March 13, 2013 “in order to change the name of the Company” to “LSJE, LLC”5. The extraction of the former name in that clause reads “IX Employees, LLC”; Section B of the same sheet prints it as “LSJ EMPLOYEES, LLC”, and adds that the company “was formerly named ‘LSJ EMPLOYEES, LLC’, but the Company’s name was changed to ‘LSJE, LLC’ by the filing of the Amendment”550. The registered office and resident agent are Business Basics VI, LLC at 9100 Port of Sale Mall, Suite 15, St. Thomas, and the principal place of business is the Red Hook address.5

Administration

An undated internal organisation chart puts the company’s back office at Southern Trust Company, Inc.: “STC is the Administration office for LSJE which controls Purchasing, Vendor payments, Expense tracking, Staff payroll and Contractor(s) payments.”1051 Under the Southern Trust heading the chart lists Cecile de Jongh as office manager and Jeanne Brennan as head accountant, together with an accountant for LSJE, an accountant for Southern Trust and an information technology manager, who are not named here.10 Under a second heading for HBRK Associates it lists Darren Indyke as attorney and Richard Kahn as project manager, with an estate manager and an executive assistant, of whom the estate manager is not named here and the executive assistant line is blank on the chart.10 The telephone and fax lines for both offices are blacked out.10

Banking

FirstBank, Puerto Rico

Answering a grand jury subpoena from the U.S. Attorney’s Office for the Southern District of New York on March 9, 2020, FirstBank listed the Epstein-related accounts it held, with the account numbers blacked out.52 Three are in the island company’s name and two in LSJE’s:7

Account holderTypeAuthorized signatureOpenedClosed or status
Little St James LLC c/o Financial Trust Co IncCommercial checkingInformation not available7/16/19988/3/2012
Little St James LLC c/o Financial Trust Co IncCommercial checkingJeffrey Epstein, Harry Beller, Ghislaine N. Maxwell10/22/98Credits only allowed
Little St James LLCCommercial checkingInformation not available1/22/20048/3/2012
LSJE LLCCommercial checkingDarren K. Indyke, Jeffrey Epstein, Harry Beller, Jeanne Brennan-Wiebracht12/29/11Normal
LSJE LLC, operating acctCommercial checkingDarren K. Indyke, Jeffrey Epstein, Harry Beller, Jeanne Brennan-Wiebracht01/23/1203/04/20

The documents cited here do not record what authority Maxwell’s signature on the 1998 account carried, or for how long she held it.

Money into the island accounts

Epstein’s private bank at JPMorgan Chase sent money to these accounts by wire. A statement page for April 2006 records two Fedwire debits from Epstein’s Premier Checking account to LSJ, LLC at FirstBank, Puerto Rico: $50,000 on April 20 and $10,000 on April 24.53 A memorandum on Epstein’s letterhead of January 5, 2010, signed by Harry Beller and addressed to a banker at JP Morgan, instructs the bank to “wire One Hundred Fifty Thousand Dollars ($150,000)” to LSJ, LLC at FirstBank.54 A second memorandum of May 25, 2010, in the same form, instructs a wire of “Fifty Thousand Dollars ($50,000)” to the same company and bank.55 A third, of January 24, 2012, instructs “Two Hundred Fifty Thousand Dollars & 00/100 ($250,000)” to LSJ Employees LLC at FirstBank.56 No account or routing number printed on any of these instruments is reproduced here.

Deutsche Bank Trust Company Americas

LSJE, LLC held an account at Deutsche Bank Trust Company Americas that the bank administered alongside Southern Financial, LLC under an internal relationship label that the correspondence prints in capitals in its subject line as SOUTHERN FINANCIAL RELATIONSHIP8. Beginning a periodic review in August 2018, a know-your-customer case representative in the bank’s wealth management unit wrote that the review related to “above high risked accounts due for remediation Aug 2018”57 and set out the position for each account holder.6 For LSJE the entry is set out on three lines, joined here with a solidus: “Acct Holder — LSJE, LLC / Sole Member, shareholder & Authorized Signatory — Jeffrey Epstein / Authorized Signatory — Darren Indyke”6. The sheet prints no mark at the end of the third line. The outstanding item for the company was documentary: “During review, I have found the Certificate of Existence for this entity, but couldn’t extract SoS from the USVI website and the COGS is missing.”6 Whether either was supplied is not established by the documents cited here.

Permits and construction

Building permits

The Virgin Islands Department of Planning and Natural Resources, Division of Permits, issued building permits for the island to the company in successive forms of its name:58

Permit no.DatePermittee as printedWorkApproximate costPerson(s) in charge
133-08Dec. 20, 2007LSJ, LLCConstruct Mechanical Building$2,000,000Lafayette Contractors, LLC
375-08May 16, 2008L.S.J., LLCInstallation of Mechanical Equipment$1,200,000Lafayette Contractors
CN# 1049Feb. 7, 2011* L.S.J., LLCConstruct Pool w/ Cabana, Deck & Equipment Room$383,300.00redacted

Permits 133-08 and 375-08 carry a handwritten cross-reference to coastal zone permit CZT-53-04L and are signed by the territorial director for the Commissioner; CN# 1049 carries a handwritten cross-reference to CZT-25-10L and is signed by the Commissioner.58

A Certificate of Occupancy on Form CZM-22, under the heading CZM PERMIT NO. CZT-61-06, was issued in the name of the company for a structure entered on the form as an office building and covered pool patio, located at Parcel No. C, Estate Little St. James, Red Hook Quarter, St. Thomas, and is signed by Commissioner Alicia Barnes and dated July 13, 2011.59 The field values are reported here rather than quoted: the extraction of this form renders the permit’s bracketed suffix, the company name and two words of the structure description differently from the readings above, and nothing on it has been read at the image.59

The submerged-lands permit, and where the recording value came from

A Basis for Negotiations sheet attached to Major Coastal Zone Management Permit No. CZT-5-99(W), the submerged-lands permit the company held for its dock, sets out in print how the Virgin Islands fixed the annual occupancy fee. It reconciles to the cent in both directions:48

StepAs the sheet prints itChecks
Fair market value$6,442,100 = $2,778,400 land + $3,663,700 improvements, for 68.7 acresthe two components sum exactly to the total
Unit value$93,771.47 per acre$6,442,100 ÷ 68.7 acres, exact
Structures on submerged land2,550 ft² = .0585 acres × $93,771.47 = $5,489.38 × 12% = $658.722,550 ÷ 43,560 acres, then the product, each exact
Water area26,130 ft² = .60 acres × $93,771.47 = $56,249.96 × 12% = $6,750.00exact on the unrounded acreage, not the rounded .60
Fee on that basis$658.72 + $6,750.00 = $7,408.72exact
Fee actually charged”Total Fee Negotiated = $9,500.00 per year”$2,091.28, or 28.2 per cent, above the computed figure

Two things follow that the page could not otherwise state. The $6,442,100 is the figure written by hand on the 2011 deed as the value for recording purposes, and here it appears in print as a fair market value computed for a coastal zone permit of 1999, itemised into land and improvements. The value at which the island was conveyed to Nautilus in December 2011 was therefore not a 2011 appraisal; it is a figure the territory’s own permit file already carried. ⚠ And the acreage differs: this sheet values 68.7 acres, while the quitclaim deed describes three parcels totalling 71.5. The documents cited here do not reconcile the two, and neither figure is treated as correcting the other.481

The permit itself names the St. Thomas Committee of the Virgin Islands Coastal Zone Management Commission as permittor and LSJ, LLC as permittee, and authorises two mooring buoys, two covered structures on the dock, and the continued use and occupancy of a 1,586 ft² dock, a 144 ft² trampoline, a 204 ft² bulkhead, “one 100’ eight-inch (8”) diameter intake line and one 100’ six-inch (6”) intake hose to supply the reverse osmosis plant”, and 250 feet of riprap revetment, all seaward of Parcel C.60 ⭐ Those intake lines are the supply side of the plant whose brine discharge the territorial discharge permit described above regulates; the two permits are two halves of one water system.

Its term is twenty years, expiring March 30, 2020, and it “shall not constitute a property right”. The modification takes effect only on signature by the Committee’s chairman, “approval by the Governor of the Virgin Islands, and approval by the Legislature of the Virgin Islands”.60 The exhibits incorporated by reference record a chain of earlier modifications approved on June 12, 2002, June 9, 2004 and August 20, 2008, each with its own environmental assessment report, on a modification request of April 4, 2011.60

Coastal zone permits

Minor Coastal Zone Management Permit No. CZT-61-06L names the Government of the Virgin Islands as permittor and “LSJ, LLC” as permittee, and allows “the site preparation and construction of a 2,500 square feet of office space, patio and pool to an existing residence located at Parcel C Little St. James, St. Thomas, Virgin Islands.”61 It incorporates by reference a coastal zone permit application dated July 10, 2006.61 The issuing page is a printed form reciting that on a stated day the Department of Planning and Natural Resources issues the minor CZM permit, with the day and the month written in by hand as the 3rd of November, 2006; it carries the signature of Dean C. Plaskett, Esq., Commissioner, and the permittee’s acceptance below it is signed for the company and dated November 16, 2006.62 The line is not quoted because the extraction of it is heavily damaged and the two values that matter are manuscript; this page has not read the sheet at the image.62

A Request for Amendment/Modification to Minor Coastal Zone Permit No. CZT-53-04L names L.S.J., LLC as both applicant and owner of the property, and is signed on September 25, 2007 for each of them by a signature the scan does not resolve, beside a manuscript note reading “SEE ATTACHED POWER OF ATTORNEY”63. An inspector endorsed it on October 4 and the Commissioner marked the application approved on November 2, 2007.63

Environmental permits

Air Pollution Control Authority to Construct No. STT-8-020-L-10 was issued on December 16, 2010 to L.S.J., LLC at 6100 Red Hook Quarters B-3 for the construction of “one (1) 500 kW Caterpillar diesel generator … for standby use only” at Little St. James Island, in accordance with an application dated October 29, 2010, effective for one year to December 16, 2011.64

A Territorial Pollutant Discharge Elimination System permit in the same file, permit no. VI0040525, names “LITTLE ST. JAMES” as permittee at Little St. James Island and authorises a discharge of reverse osmosis brine to a drainage system at a daily maximum and monthly average of 0.3 million gallons a day. It is signed by Commissioner Alicia V. Barnes, becomes effective on November 1, 2011 and expires on October 31, 2016.65

Contractors

Gensler’s letter agreement for architectural services for the “Little St. James Pool Area and Screening Room” is dated September 28, 2009 on its face and addressed to “Mr. Jeffrey Epstein, LSJ, LLC, 6100 Red Hook Quarters, Suite B-3.” Its opening sentence makes the agreement one between Epstein as client and the firm, not between the firm and the company; the running head on its later pages prints September 18, 2009.66

A change order from Virgin Island Gunite Pools dated February 15, 2012 is addressed to “LSJ, LLC” at the Red Hook address for chipping out and re-plastering the main pool at Little St. James for $28,000. It refers to a contract of January 19, 2012 “signed by Rex Wolterman of Virgin Island Gunite Pools and Brice Gordon of LSJ, LLC.”67 The acceptance block on the copy in the release is blank on both lines, and the contractor’s own submission line, above “Per: Bart Wolterman,” is unsigned as well.67

Investigation and litigation

SDNY forfeiture evaluation, 2019

In August 2019 the FBI’s Squad C-40 (FAST) was preparing to order a certified title report and a certified appraisal for Little St. James and asked whether the U.S. Attorney’s Office for the Southern District of New York was inclined to pursue the island.68 The reply on August 14, 2019 said: “As I’m sure you can imagine, there’s a lot going on in the case and we’re still sorting out next steps. We are not sure yet how we will decide to address the question of forfeiture, and that’s an ongoing and complicated conversation we’re having with our supervisors, including the chiefs of the forfeiture unit.”68 The senior financial investigator replied the same day: “I will proceed in anticipation of going forward with real property forfeiture (where appropriate) , until advised to stop.” An earlier message in the thread had said it “would be advisable to determine if the island will be forfeited in a civil action” before ordering the report and appraisal.6869 The names of everyone in the thread are blacked out. What was decided is not established by the documents cited here.

An FBI serial report headed “Serial Report for Case: 50D-NY-3027571-FF” lists, in the title column of that same report, “(U) Request for a Title report and an Appraisal for Little St James Island, U.S.V.I.” among the items in the file, on the page following the header, alongside two blacked-out rows.70

On August 12, 2019 an agent assisting New York Squad C20 in the financial investigation set a priority lead to the Baltimore office “to serve a grand jury subpoena to obtain records for a Delaware corporation,” attaching a courtesy copy whose filename names the subpoena for August 9, 2019 and identifies it as addressed to Delaware Corporations for LSJ LLC.71 The body of the message does not name the company. Whether records were produced is not established by the documents cited here.

Government of the Virgin Islands action

The Government of the Virgin Islands sued Epstein’s estate, its co-executors Darren Indyke and Richard Kahn, the 1953 Trust and a group of Virgin Islands entities including Nautilus, Inc. The copy of its First Amended Complaint in the release is filed as an exhibit in a Southern District of New York docket on September 1, 2020.72

The complaint pleads that a deed recorded on December 30, 2011 “reflects that the property was transferred from a Delaware entity, L.S.J., LLC, to Nautilus, Inc.” for “TEN DOLLARS ($10.00) and other good and valuable consideration,” and that the quitclaim deed lists Epstein as sole member of L.S.J., LLC, which acquired the island by the warranty deed of April 27, 1998.73 It pleads that the Recorder of Deeds records Nautilus, Inc. as owner of “Little St. James, a/k/a Parcel Number 109803010100, a parcel of 3.1 million square feet valued at $3.2 million, with buildings and improvements valued at $4 million.”74 It also pleads that Epstein was president and director of Nautilus with Indyke and Kahn as secretary and treasurer, and that “The Estate values Epstein’s holdings of Nautilus, Inc., which holds title to Little St. James at $63.9 million.”75 The estate’s Petition for Probate is pleaded as valuing Great St. James and Little St. James together at $86 million.76

The Government alleges that Epstein “maintained a deliberately complex web of Virgin Islands corporations, limited liability companies, foundations, and other entities … through which he carried out and concealed his criminal conduct,” that those entities held properties at which he trafficked and sexually abused women and underage girls, and that “Nautilus, Inc. participated in carrying out, facilitating and concealing Epstein’s crimes, hence Little St. James became an instrumentality of those crimes.”7778 It claims the right to obtain “through divestiture, forfeiture, or other equitable relief all properties and instrumentalities used by the Epstein Enterprise in the criminal pattern of trafficking and sexual abuse in the Virgin Islands, including but not limited to Great St. James and Little St. James, and all other remedies and penalties permitted by law”79. Those are the Government’s allegations. The action is against Epstein’s estate, and no answer from him to them exists; the documents cited here record no response from Indyke or Kahn to them.

Little Saint James; Nautilus, Inc.; Southern Trust Company; HBRK Associates; Deutsche Bank; JPMorgan Chase; Financial Trust Company; Great St. James; Darren Indyke; Richard Kahn; Harry Beller; Jeanne Brennan-Wiebracht; Cecile de Jongh; Paul Hoffman; Ghislaine Maxwell.

Footnotes

  1. Quitclaim Deed, L.S.J., LLC to Nautilus, Inc., made December 23, 2011 and recorded December 30, 2011, Office of the Recorder of Deeds for St. Thomas and St. John. https://epstein-data.com/EFTA01305148 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14

  2. Grant of Authorization signed by Jeffrey E. Epstein as sole member of L.S.J., LLC, undated, in the Department of Planning and Natural Resources permit file. https://epstein-data.com/EFTA01222235 p.15. ↩ ↩2 ↩3 ↩4 ↩5

  3. Draft complaint, Jeffrey Epstein and L.S.J., LLC v. Fancelli Paneling, Inc. and Atelier Fancelli, Superior Court of the Virgin Islands, ¶¶1-2. https://epstein-data.com/EFTA00731209 p.1. ↩ ↩2

  4. Certificate of Existence for LSJE, LLC, Office of the Lieutenant Governor of the Virgin Islands, July 9, 2018. https://epstein-data.com/EFTA01387523 p.1. ↩ ↩2 ↩3

  5. Amended and Restated Operating Agreement of LSJE, LLC, made as of March 13, 2013, Section I. Marked confidential under Federal Rule of Criminal Procedure 6(e). https://epstein-data.com/EFTA01456712 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  6. The same correspondence, the underlying message of August 2018 setting out the position and pending items for each account holder. https://epstein-data.com/EFTA01421281 p.3. ↩ ↩2 ↩3 ↩4

  7. The same response, schedule of accounts. https://epstein-data.com/EFTA00065864 p.3. Other rows on this page concern Cypress, Inc., Laurel, Inc., Southern Trust Company, Inc. and FSF LLC and are not reproduced here. ↩ ↩2 ↩3

  8. Deutsche Bank wealth management know-your-customer correspondence, August 24, 2018, on the 2018 periodic review of the Southern Financial and LSJE accounts. https://epstein-data.com/EFTA01421281 p.1. ↩ ↩2

  9. The same deed, signature and acknowledgment page. https://epstein-data.com/EFTA01305148 p.2. ↩ ↩2 ↩3

  10. Internal organisation chart of the Southern Trust Company administration office and HBRK Associates, undated, photographed in the release. https://epstein-data.com/EFTA00003149 p.1. No number printed on the chart is reproduced here. ↩ ↩2 ↩3 ↩4 ↩5

  11. The acreages are the deed’s own; the square footage is the Government’s pleading at https://epstein-data.com/EFTA00018778 p.5. 71.5 acres is 3,114,540 square feet at 43,560 square feet to the acre. The reconciliation is this page’s arithmetic on two figures each document states; neither document performs it. ↩

  12. FBI internal email chain, August 14, 2019, “Certified Title Search and Certified Appraisal - Little St James Island,” second page. https://epstein-data.com/EFTA00089152 p.2. ↩

  13. FBI internal email chain, August 7 and 8, 2019, “Little St James Island - Last Deed of Record”. The correspondents are redacted. https://epstein-data.com/EFTA00037750 pp.1-2. ↩

  14. The same draft, allegations on the design, fabrication and price of the library cabinetry. https://epstein-data.com/EFTA00731209 pp.2-3, 6. ↩ ↩2

  15. The same draft, a redline with change bars and tracked insertions in the margin; caption and signature page. https://epstein-data.com/EFTA00731209 pp.1, 8. ↩

  16. Affidavit of Denise Francois, sworn and filed June 21, 2011, in Epstein and L.S.J., LLC v. Fancelli Paneling, Inc., Case No. ST-10-CV-443, Superior Court of the Virgin Islands, Division of St. Thomas and St. John. https://epstein-data.com/EFTA00307575 p.1. ↩ ↩2 ↩3 ↩4 ↩5

  17. Settlement Agreement and Release among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein, made as of December 30, 2010, recitals. https://epstein-data.com/EFTA00312659 p.1. ↩ ↩2

  18. The same agreement, signature page for Molyneux, individually and as President of J.P. Molyneux Studio, Ltd. https://epstein-data.com/EFTA00312659 p.15. ↩

  19. The same agreement, signature page for Epstein, personally and for L.S.J., LLC. https://epstein-data.com/EFTA00312659 p.17. ↩

  20. The same agreement, ¶¶1-2, payment terms. https://epstein-data.com/EFTA00312659 p.2. ↩

  21. Hodge & Francois invoices to Jeffrey Epstein c/o Darren Indyke, “In Reference To: Molyneux v Epstein, et al.”, August 2010 time entries. https://epstein-data.com/EFTA01222222 pp.2-3. ↩

  22. Agreement among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein, made as of a day in May 2009, settling an earlier dispute over design and related services for Little St. James Island. https://epstein-data.com/EFTA00725445 p.1. ↩ ↩2 ↩3

  23. The same agreement, paragraph 2(b), the credit against future services and the hourly rates it is to be billed at. https://epstein-data.com/EFTA00725445 p.1. ↩

  24. The same filing, part III.A, relevant facts, including the date it gives for the first written Design Services Agreement and for Purchase Order #2680. https://epstein-data.com/EFTA00308324 p.8. ↩ ↩2

  25. The same settlement agreement, section 3(a), the release of Molyneux and the Fancelli Group carve-out. https://epstein-data.com/EFTA00312659 p.4. ↩

  26. The same agreement, section 4(a) and the opening of section 4(c). https://epstein-data.com/EFTA00312659 p.5. ↩ ↩2

  27. The same agreement, the remainder of section 4(c). https://epstein-data.com/EFTA00312659 p.6. ↩

  28. Two further renderings of the Settlement Agreement and Release, each entered into as of a day in November 2010, the day left blank, and each of thirteen pages against the executed copy’s seventeen. Neither contains the word Fancelli at any point. https://epstein-data.com/EFTA00585546 pp.1-13 and https://epstein-data.com/EFTA00586553 pp.1-13. Which of the two is the earlier is not established by the documents cited here, and the comparison made in the text is between the November drafts and the December executed copy, not between these two. ↩

  29. The same agreement, paragraph 8. https://epstein-data.com/EFTA00312659 p.8. ↩

  30. The same agreement, paragraph 7, confidentiality. The extraction prints “riled” where the sense is “filed”; the word is not quoted here. https://epstein-data.com/EFTA00312659 p.7. ↩

  31. The same agreement, paragraph 20, submission of disputes and the terms on which Molyneux is to appear. A telephone number and an electronic address printed in this paragraph are not reproduced here. ⚠ The retired judge named in it and the attorney who signed the Fancelli opposition cited below share a surname and are different people; only the forenames distinguish them. https://epstein-data.com/EFTA00312659 p.13. ↩

  32. Agreement for Office Design Services among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein, made as of a day in November 2010, paragraphs 1 and 2 and the consideration clause. https://epstein-data.com/EFTA00585559 p.1. ↩ ↩2

  33. Modification of the Office Design Agreement and its Schedule, made in May 2011 among the same parties, recitals. https://epstein-data.com/EFTA00589731 p.1. The forename in the schedule designation is left as the document leaves it. ↩

  34. The same agreement, paragraph 17, notice, cure and Epstein’s sole remedy for non-payment. https://epstein-data.com/EFTA00312659 p.12. ↩

  35. The same agreement, paragraph 13, liquidated damages, and paragraph 15, arbitration. https://epstein-data.com/EFTA00585559 p.6. ↩

  36. Opposition to Motion to Reconsider, Fancelli Paneling, Inc., in Jeffrey Epstein et al. v. Fancelli Paneling, Inc., No. ST-10-CV-443 (Carroll, J.), Superior Court of the Virgin Islands, July 5, 2011, quoting the Court’s Memorandum Opinion and Order of May 16, 2011. “Fanelli” with one l is as the filing prints it. https://epstein-data.com/EFTA00308324 p.2. ↩

  37. The same filing, part III.B, procedural status, items 7 and 10. https://epstein-data.com/EFTA00308324 pp.10-11. ↩ ↩2

  38. The same filing, part II, on Rule 19(a)(1) and the joinder of Juan Pablo Molyneux individually. https://epstein-data.com/EFTA00308324 p.3. ↩

  39. The same filing, on the confidential agreement, the purchase order and the third-party-beneficiary finding. https://epstein-data.com/EFTA00308324 p.4. ↩ ↩2

  40. The same filing, on the effect it ascribes to the confidential agreement and on the first amended complaint in the District Court action. https://epstein-data.com/EFTA00308324 p.5. ↩

  41. The same filing, conclusion. https://epstein-data.com/EFTA00308324 p.14. A street line printed in the certificate of service on the following page is not reproduced here. ↩

  42. The same filing, on the revised purchase order. https://epstein-data.com/EFTA00308324 p.9. ↩

  43. Certification of Paul Hoffman as attorney for L.S.J., LLC, sworn and notarised December 15, 1999, in Major Coastal Zone Management Permit No. CZT-5-99W. https://epstein-data.com/EFTA01222235 p.69. ↩

  44. The same permit, general conditions, notices clause. https://epstein-data.com/EFTA01222235 p.65. ↩

  45. Erika Kellerhals to Jeffrey Epstein and others, November 21, 2011, items 1 to 5. https://epstein-data.com/EFTA02026396 p.1. ↩ ↩2

  46. The same message, on the transfer of coastal zone, discharge and other permits. https://epstein-data.com/EFTA02026396 p.2. ↩ ↩2 ↩3

  47. Affidavit of Jeffrey E. Epstein sworn December 21, 2011, recorded with the deed. https://epstein-data.com/EFTA01305148 p.4. ↩ ↩2 ↩3

  48. “BASIS FOR NEGOTIATIONS”, attached to Major Coastal Zone Management Permit No. CZT-5-99(W) modified, LSJ, LLC, Parcel C Little St. James Island: general information, activity, fees and the fee calculation. https://epstein-data.com/EFTA00310784 p.8. The arithmetic checks in the table are this page’s, performed on figures the sheet itself prints; the sheet states each product and total and does not describe them as reconciling. ↩ ↩2 ↩3

  49. Real Property Tax Clearance Letter, Office of the Tax Collector, Division of Real Property Tax, December 27, 2011, recorded with the deed. https://epstein-data.com/EFTA01305148 p.5. ↩

  50. Where a quotation reproduced on this page contains quotation marks that the sheet prints, they are rendered as single marks so as not to close the surrounding quotation. No other character inside any quotation on this page is altered except where a bracket marks it. ↩

  51. The sheet breaks this word across a line as “pay-” and “ments”. The hyphen is a line-break hyphen and is closed here; no other character is changed. ↩

  52. FirstBank, San Juan, Records and Legal Requirements Department, to an Assistant U.S. Attorney, Southern District of New York, March 9, 2020, answering a grand jury subpoena, reference FB Num. SUB-19353. https://epstein-data.com/EFTA00065864 p.1. ↩

  53. JPMorgan Private Bank Premier Checking statement for Jeffrey E Epstein, April 1 to April 28, 2006, activity page, recording two Fedwire debits to LSJ, LLC. Other entries on the page (a Wells Fargo debit, an incoming credit, and a book transfer to J.P. Molyneux Studio Ltd.) are not cited here. https://epstein-data.com/EFTA01482717 p.1. ↩

  54. Memorandum on Jeffrey E. Epstein letterhead from Harry Beller to JP Morgan, January 5, 2010. https://epstein-data.com/EFTA01578772 p.1. ↩

  55. Memorandum on Jeffrey E. Epstein letterhead from Harry Beller to JP Morgan, May 25, 2010, the fourth of five scanned pages; the fax’s own transmission header reads “Page 3 of 4”. https://epstein-data.com/EFTA01587188 p.4. ↩

  56. Memorandum on Jeffrey E. Epstein letterhead from Harry Beller to JP Morgan, January 24, 2012. https://epstein-data.com/EFTA01578612 p.1. ↩

  57. The same correspondence, the periodic-review message of August 14, 2018 that opens the review. https://epstein-data.com/EFTA01421281 p.2. ↩

  58. Building permits CN# 1049 of February 7, 2011, 375-08 of May 16, 2008 and 133-08 of December 20, 2007, Department of Planning and Natural Resources, Division of Permits. https://epstein-data.com/EFTA01222235 pp.1-3. ↩ ↩2

  59. Certificate of Occupancy, CZM Permit No. CZT-61-06 (L), Form CZM-22, signed by the Commissioner. https://epstein-data.com/EFTA01222235 p.4. ↩ ↩2

  60. Major Coastal Zone Management Permit No. CZT-5-99(W) modified, sections 1 to 4: authority, scope, term and documents incorporated by reference. https://epstein-data.com/EFTA00310784 p.9. The exhibit list gives a date for the underlying permit that does not sit with the twenty-year term expiring in March 2020; neither is relied on here beyond the term the permit states. ↩ ↩2 ↩3

  61. Minor Coastal Zone Management Permit No. CZT-61-06L, authority, scope and documents incorporated by reference. https://epstein-data.com/EFTA01222235 p.6. ↩ ↩2

  62. The same permit, issuing and acceptance page. https://epstein-data.com/EFTA01222235 p.10. ↩ ↩2

  63. Request for Amendment / Modification to Minor Coastal Zone Permit No. CZT-53-04L, September 25, 2007, with the inspector’s and Commissioner’s endorsements. https://epstein-data.com/EFTA01222235 p.12. No telephone number printed on the form is reproduced here. ↩ ↩2

  64. Air Pollution Control Authority to Construct Permit No. STT-8-020-L-10, Division of Environmental Protection, December 16, 2010. https://epstein-data.com/EFTA01222361 p.1. No telephone number printed on the permit is reproduced here. ↩

  65. Territorial Pollutant Discharge Elimination System permit VI0040525, Division of Environmental Protection, effective November 1, 2011. https://epstein-data.com/EFTA01222361 p.2. ↩

  66. Gensler to Jeffrey Epstein at LSJ, LLC, “Agreement for Architectural Services … Little St. James Pool Area and Screening Room,” September 28, 2009, and the running head of its tenth page. https://epstein-data.com/EFTA00727145 pp.1, 10. ↩

  67. Virgin Island Gunite Pools change order, main pool re-plaster, February 15, 2012, with its acceptance block. https://epstein-data.com/EFTA01842634 p.1. ↩ ↩2

  68. The same chain, first page, carrying the reply of August 14, 2019 and the message it answers. The header time is in coordinated universal time; the quoted messages beneath it are stamped in local time. https://epstein-data.com/EFTA00089152 p.1. ↩ ↩2 ↩3

  69. The same chain, second page. https://epstein-data.com/EFTA00089152 p.2. ↩

  70. FBI Sentinel serial report for case 50D-NY-3027571-FF, in a Bates range of exported case records. The page cited is the title column of that report. https://epstein-data.com/EFTA01684602 pp.145-146. This range is a continuous run of page stamps rather than a single document, and no other part of it is cited here. ↩

  71. FBI email setting a priority lead, August 12, 2019, “State of Delaware - Division of Corporations - Grand Jury Subpoena”. The correspondents are redacted. https://epstein-data.com/EFTA01659285 p.1. ↩

  72. Government of the Virgin Islands v. Estate of Jeffrey E. Epstein, First Amended Complaint, filed as an exhibit on September 1, 2020 in Case 1:15-cv-07433-LAP, caption and parties. https://epstein-data.com/EFTA00018778 pp.2, 5. ↩

  73. The same complaint, ¶24. https://epstein-data.com/EFTA00018778 p.6. ↩

  74. The same complaint, ¶¶21-22. https://epstein-data.com/EFTA00018778 p.5. ↩

  75. The same complaint, ¶23. https://epstein-data.com/EFTA00018778 p.6. ↩

  76. The same complaint, ¶¶11-13. https://epstein-data.com/EFTA00018778 p.4. ↩

  77. The same complaint, ¶¶17-19. https://epstein-data.com/EFTA00018778 p.5. ↩

  78. The same complaint, ¶26. https://epstein-data.com/EFTA00018778 p.6. ↩

  79. The same complaint, ¶103, which begins on the preceding page. https://epstein-data.com/EFTA00018778 pp.21-22. ↩

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