Epstein Data Wiki

Plan D, LLC

Properties2
tagsentity, virgin-islands, epstein-company, aircraft, banking, promissory-notes
aliasesPlan D, LLC, PLAN D LLC, Plan D LLC, PLAN D, LLC

30 min read

ConstitutionLimited liability company organized under the Uniform Limited Liability Company Act, Chapter 15, Title 13, Virgin Islands Code1
Articles of organization filedOctober 19, 2012, with the Office of the Lieutenant Governor of the Virgin Islands2
OrganizerErika A. Kellerhals3
Initial manager, under the articlesLawrence Visoski; the articles make the company manager-managed3
Opening capital, under the articlesOne thousand United States dollars3
Resident agent and initial designated officeBusiness Basics VI, LLC, 9100 Port of Sale Mall, Suite 15, St. Thomas1
Business address given to its bank6100 Red Hook Quarter, B3, St. Thomas, given on the account application as the company’s business address and on the bank’s account record as the account legal address45
Business stated to its bankTo own and operate aircraft4
BankJPMorgan Chase, N.A., Private Bank: a business checking account opened March 2013456
Authorized signers on the bank resolutionJeffrey E. Epstein and Harry Beller, each able to sign singly7
Borrowing recorded in the released filesMaker of a $28,500,000 note of March 27, 2017 payable to Leon Black, and of an $8,000,000 demand note of April 17, 2017 payable to BV70 LLC; a $22,500,000 note of March 30, 2017 payable to BV70 LLC is recited in an amendment of March 31, 20178910
Named as defendantGovernment of the Virgin Islands v. Estate of Jeffrey E. Epstein, Superior Court of the Virgin Islands, Case No. ST-2020-CV-1411
Not the same company asPlan D, Inc., a Delaware corporation for which the same bank opened an account in 2007; see JPMorgan Chase12

Plan D, LLC is a United States Virgin Islands limited liability company whose articles of organization were filed with the Office of the Lieutenant Governor on October 19, 2012, the same day as those of Hyperion Air, LLC and JEGE, LLC.213 Four months later it told JPMorgan Chase that its business was to own and operate aircraft, and opened a checking account.4 The Government of the Virgin Islands later alleged that it owned the Gulfstream that flew as N212JE; the registration history of that airframe is on Epstein’s flight department.14 In 2017 it was the maker of three promissory notes running to Leon Black and to a company of his.8109

Its operating agreement of the same date, which names Epstein as sole member and states the company’s purpose, is quoted on JPMorgan Chase and is not retold here. This page takes the other instruments in the same bank file (the articles as filed, the account application and resolution, and the papers by which the account was opened) together with the company’s borrowing and the government’s pleading about it. The registration history of the airframes is on Epstein’s flight department and the Boeing Business Jet negotiation is on Thomas World Air; neither is repeated here. Nothing on this page is a finding of wrongdoing.

There is a second company of almost the same name. “Plan D, Inc.” is a Delaware corporation for which the same bank opened an account in April 2007; the 2007 account-opening correspondence, and the Delaware incorporation papers filed behind it, sit further on in the same JPMorgan client file as the Virgin Islands company’s 2013 papers, and the Delaware Secretary of State certifies its certificate of incorporation as filed on April 12, 2007.12 Every document cited on this page names the limited liability company, and where a document was ambiguous it was read at the page image before it was used.

And a file index in the release names a third. A typed inventory of a tall file cabinet in the office of Darren K. Indyke carries a heading “DISSOLUTIONS” under which, among twelve lines, stand both “-PLAN D, LLC (DE)”, the second line under that heading, and “-PLAN D, INC (DE)”, the ninth: two entities of the name, both marked as Delaware.15 That sheet is a list of folder tabs and not of instruments; it establishes what a drawer was labelled and nothing else. This page makes no claim about a Delaware limited liability company of this name, and no document cited here is drawn from that entry.

What the territory’s register showed, and what the bank’s file showed

The articles of organization open in the voice of an organizer: “I, the undersigned natural person of the age of eighteen years or more, acting as Organizer of a limited liability company under the Uniform Limited Liability Company Act, Chapter 15, Title 13, Virgin Islands Code.”1 Article One gives the initial designated office and the resident agent for service of process as Business Basics VI, LLC at 9100 Port of Sale Mall, Suite 15, St. Thomas. Article Two states the purpose in the territory’s general form, “to engage in any and all lawful purposes for which a limited liability company may be organized.” Article Three makes the duration perpetual.1 Article Four names the organizer as Erika A. Kellerhals. Article Five provides that “[t]he Company shall be manager managed. The initial manager of the company shall be Lawrence Visoski,” at the same Port of Sale Mall address. Article Six provides that the company “shall begin business with capital in the amount of One Thousand United States Dollars (US $1,000.00).”3 The execution page carries a pen signature above the printed name of the organizer, the day of the month entered by hand in both the attestation and the jurat below it, and a notary’s acknowledgment over a printed notary block.16

The articles name no member. They name an organizer and a manager, and nothing on the four pages says who owns the company.131716 The operating agreement executed the same day, which was in the bank’s file and not the register, does: its Exhibit A lists one member, Jeffrey E. Epstein, one hundred membership units, one hundred per cent membership interest and one thousand dollars contributed, beside the printed date October 19, 2012 and above a printed name across which a single ink stroke runs.18

The Government of the Virgin Islands drew the same contrast when it sued the estate. Paragraph 33 of its First Amended Complaint alleges: “In its original Articles of Organization, filed October 19, 2012, and Annual Report filings, Epstein’s pilot, Larry Visoski. was listed as Plan D, LLC’s sole manager/member. However, the July 31, 2019 Annual Report revealed Epstein as the principal behind Plan D, LLC.”11 Paragraph 34 alleges, on information and belief, that the company owned one or more of the aircraft Epstein used, “[a]mong the airplanes owned by Plan D, LLC is a Gulfstream with N-number N212JE,” and that “[f]light logs and travel notices indicate that Epstein used this plane to traffic and transport and young women and underage girls to the Virgin Islands” (the doubled “and” stands in the pleading).14 Those are allegations in a pleading. The documents cited on this page do not contain the annual report filings the paragraph describes; searches of the released files are set out below.

On September 13, 2018 the Lieutenant Governor, Osbert E. Potter, certified that the company “filed Articles of Organization with the Office of the Lieutenant Governor on October 19, 2012 and the Company is duly organized under the laws of the United States Virgin Islands,” that its duration “shall be perpetual,” that it “has paid all applicable fees to date,” and that “Articles of Termination have not been filed by the company.”2

JPMorgan Chase: an account for a company that owns and operates aircraft

The bank’s decision to open the account is on Hyperion Air: on February 21, 2013 a JPMorgan officer asked Private Bank Risk Management whether the bank could proceed with opening checking accounts for three named Virgin Islands entities, of which this company was one, and the answer that day was one word.19 The papers that followed are here.

On the J.P. Morgan Entity Account Application the entry for type of business is machine-printed as “OPERATE AIRCRAFT,” and above it, in a hand whose stroke weight varies and which sits off the print baseline, two further words are inserted, so that the entry as amended reads: own and operate aircraft. That insertion is not in the extraction of the page and is visible only at the image.4 The date of organization is given as October 19, 2012 and the state as USVI; the primary authorized contact person is Richard Kahn; the business address is 6100 Red Hook Quarter, B3, St. Thomas, and the box for “Mailing Address same as Business Address?” is marked at “Yes.”4 Under Account Information the title of the account is PLAN D LLC and, of the seven printed entity types, the box beside “Limited Liability Company” is marked. Five account types are offered: checking; money market deposit account or savings; investment management, third-party manager or the J.P. Morgan Advisory Program (discretionary); asset/brokerage; and asset/custody. Only the checking box is marked, and the other four are empty. Neither the “Yes” nor the “No” box on the line applying for a linked line of credit carries a mark. Under Ownership Information the question whether any one person or entity holds twenty-five per cent or more is marked “Yes,” and the controlling owner is given as Jeffrey E. Epstein at one hundred per cent.4 A date of birth and identity and tax reference numbers are printed on that page and are not reproduced here.

The second sheet of the application is its agreement and signature page. Of its three signature rules, one is used: it carries a pen signature, a date entered by hand as 03/07/2013, and, in machine print, the name Lawrence Visoski. The other two rules are blank.20 The extraction of that page renders the manuscript date as “03/01 /20/3”; the date given here is read from the image.20

The J.P. Morgan Entity Resolution Form carries a certifying officer’s name entered in ink. Its opening line is printed with blanks for the certifying officer, the entity and the jurisdiction, and offers the officer a choice of description: “the Secretary (or duly authorized officer)”. The certifying officer’s name is entered in ink, in hand-lettered capitals reading Lawrence Visoski, and the printed word “Secretary” is struck through by a heavy ink stroke, so that the certification stands on the alternative.7 The entity is given as PLAN D LLC and the law as USVI; those two entries, and the day and the month of the meeting, are machine-printed in a single face distinct from the form’s own body print and are not entered by hand.7 The resolutions are certified as adopted on the eleventh day of February; the year, which follows a printed “20”, is a single heavily overwritten ink mark that could not be resolved into digits at the image.7 Section A lists two authorized signers, each with a specimen signature in ink beside a machine-printed name: Jeffrey E. Epstein and Harry Beller. For each, of the two boxes offered, “Singly” is marked and “Jointly” is not; the two further signer blocks on the sheet are empty.7 Of the resolutions on that sheet, the banking and custody resolution carries a mark and the investment management resolution does not.7 Dates of birth, identity numbers and telephone numbers appear on that page in part and are not reproduced here.

The account the bank then opened is recorded as a “JPM Classic Business Checking (Low-Fee)” account, booked to New York & Northeast, with the account legal address given as 6100 Red Hook Quarter B3, St. Thomas.5 The same record carries the instructions for the chequebook: type of checks “Newport Desk Book”; “Omit My Address from Check Imprint”; “Order Deposit Slips : No”; billing “First Order, no charge”; and, under special instructions, “ATTN: RICHARD KAHN.”5

On March 18, 2013 a request went from the bank’s account-opening side to its service groups under the subject “The following newly opened account includes Checkbook Request,” naming the folder “PLAN D LLC- DDA,” the product “DDA/MMIA” and the account title “PLAN D LLC.”6 The request was worked in the Private Bank’s Mumbai office and returned marked “Request Completed.”6 The order was placed on March 19, 2013: one box, quantity three hundred, cheque numbering beginning at 101, style NPT, format 05, personalized “PLAN D LLC,” with one signature line.2122 The order-detail screen states the shipping in code only; the shipping address stands on a second screen captured behind it, which gives the business name J.P. Morgan Special Services NY at 270 Park Avenue in New York and leaves the first, middle and last name fields blank, so the cheques went to the bank and not to the customer.2324 Below the screen area the second copy carries three lines of manuscript annotation recording receipt on 3-21-13, the range 101-400, and shipment by courier on 3-26-13, a further manuscript figure above and to the right of them, and an inked verification stamp bearing a bank employee’s name and initials.22

The release holds two copies of that order, produced under different Bates numbers, and each copy is a two-sheet screen capture: an order-detail screen headed “Page: 1” and a shipping screen headed “Page: 2”, four order sheets in all. Both copies carry pen tick-strokes across the printed fields; what the later copy adds is the written lines, the figure and the stamp described above. The two copies carry different applied redactions.21222324 Account and telephone numbers on these pages are not reproduced here.

Borrowing: the manager could not do it, and the sole member signed

Section V of the operating agreement gives the manager “full and complete authority, power and discretion to do all things necessary or convenient to manage, control and carry out the business, affairs and properties of the Company,” and then takes eleven things back. Under the heading “Limitation of Manager’s Authority” it provides that the written consent of the sole member is required for the manager to “[s]ell, transfer, assign, convey, or otherwise dispose of any part of the Company’s assets”; to “[c]ause the Company to incur any debt in excess of $5,000, whether or not in the ordinary course of business”; to encumber any assets in connection with such a debt; to adopt, amend or repeal the operating agreement; to appoint or fill a vacancy in the office of manager; to approve a plan of merger; or to “[i]ncur any single expense or combination of related expenses in excess of $5,000.”25

Each of the three notes described below is far above that five-thousand-dollar threshold, and each was given by the sole member and not by the manager. A promissory note of March 27, 2017 in the principal amount of $28,500,000 records that “the undersigned, Plan D LLC, a U.S. Virgin Islands limited liability company (the ‘Maker’), hereby unconditionally promises to pay to the order of Leon Black, with an address at c/o Elysium Management LLC, 445 Park Avenue, Suite 1401, New York, NY 10022 (the ‘Holder’)” that sum “together with interest on the unpaid principal balance at the rate of One and one hundredths percent (1.01%) per annum,” the balance to be “due and payable by no later than 5:00 PM Eastern Standard Time on March 26, 2018.”8 Its execution page carries a signature in blue ink over the rule printed “Jeffrey Epstein, Sole Member,” and beneath it a New York notary’s acknowledgment that on March 27, 2017 Epstein personally appeared and “acknowledged to me that he executed the same in his capacity as Sole Member of Plan D, LLC.”26 The note is in the release in two runs whose page images are, so far as they were compared, the same.26

Three days later the company gave a second note. An instrument headed “AMENDMENT NUMBER 1 TO PROMISSORY NOTE OF PLAN D, LLC, DATED MARCH 30, 2017, PAYABLE TO THE ORDER OF BV70 LLC,” made effective March 31, 2017, recites that the company is “the Maker under that certain promissory noted dated March 30, 2017 payable to the order of the Holder in the principal amount of Twenty Two Million Five Hundred Thousand Dollars ($22,500,000.00),” and amends it to add the holder’s consent to sale, assignment or transfer.10 On April 17, 2017 the company gave a third: a demand note for $8,000,000 payable to BV70 LLC, a New York limited liability company at the same Elysium Management address, at the federal short-term rate compounded semiannually, payable “within two (2) business days of written demand.”9

This wiki records elsewhere, from Deutsche Bank’s transaction chart and the Dechert report commissioned by Apollo Global Management, that $22,500,000 reached a Plan D account from BV70 LLC on March 31, 2017 and $8,000,000 on April 17, 2017, that Epstein guaranteed the company’s obligations under a demand note of April 17, 2017 in the principal amount of $30,500,000, and that $10,000,000 went back from Plan D to a BV70 entity on October 2, 2018; that material is on Leon Black and Southern Trust Company and is not repeated here.27 The $28,500,000 note of March 27, 2017 payable to Leon Black personally does not correspond to any of the figures in that account, and the documents cited here do not say what became of it. The discrepancy is recorded, not resolved.

What the released files actually hold

A search of the released files for the company’s name returns 4,443 pages across 2,862 documents. Most of those pages are not about the company as a company. The bulk of them are single pages of bank deposit reports on which the company is one account line among many, passenger manifest forms and aircraft log sheets carrying “PLAN D, LLC” as a printed heading above flight data, and pages of aircraft maintenance and support invoices. No count by category is given here: the sheets were classified by no rule this page can state, and a breakdown a reader cannot reproduce is a claim about method rather than about the release. A hit on the company’s name in this release is, more often than not, a hit on letterhead. The documents cited on this page were chosen because the company acts in them.

The company’s own papers in the JPMorgan client file begin at Bates JPM-SDNY-00063117 and are produced one page to an EFTA number. Read in Bates order they run: the four pages of the articles; the two sheets of the account application; the two sheets of the entity resolution form; the checkbook request and the account-opening record; the first copy of the cheque order, in two sheets; the operating agreement with its Exhibit A; the second copy of the cheque order, in two sheets; and a set of funds transfer request forms dated November 2013.28 The instruments are not consecutively numbered because other sheets of the bank’s file stand between them; the sheets on either side of the articles were opened and are index sheets generated by the bank’s own document system, and the other gaps were not identified sheet by sheet.28

On whether the articles were amended. The four pages of the articles are bounded in the bank’s file by index sheets on either side, and the pages immediately before and after them carry no amendment.28 A search of the released files for the company’s name together with the words Articles of Amendment returns nothing, and together with the words Amended Articles returns nothing. A search for the company’s name together with the words Annual Report returns thirty pages, and a search together with the words 2019 Annual Report returns twenty-two. Of the thirty, twenty-nine are pages of the Government of the Virgin Islands complaint or further copies of it; the thirtieth is the file-cabinet index described above.15 None of the thirty is a report to the Lieutenant Governor. A search for the phrase ANNUAL REPORT OF A DOMESTIC LIMITED LIABILITY COMPANY, in those words, returns nothing. The searches this page ran did not reach an amendment to the articles or any annual report of this company; that is a statement about these searches and not about the release.

What the documents cited here do not establish

They do not establish when the company acquired or disposed of any aircraft, which is dealt with on Epstein’s flight department. They do not establish whether the $28,500,000 note of March 27, 2017 was drawn on, replaced, or repaid. They do not establish whether Lawrence Visoski acted as manager beyond the two forms he completed for the bank. They do not establish what the bank knew about the company beyond what its own forms record. They do not establish the outcome of the Government of the Virgin Islands action.

JPMorgan Chase; Hyperion Air; JEGE LLC; Thomas World Air; Southern Trust Company; Nautilus, Inc.; Leon Black; Richard Kahn; Harry Beller; Darren Indyke; Epstein’s flight department; Bank records of the entity network; The Epstein estate.

Footnotes

  1. Articles of Organization of PLAN D, LLC, page 1 of 4, in the JPMorgan Chase client file produced to the Southern District of New York under a request for confidential treatment; Bates JPM-SDNY-00063117. https://epstein-data.com/EFTA01583446 p.1. Rendered at 400 dpi and read against the image: a photographed sheet with paper skew and scan speckle, carrying an angled inked stamp at the upper right and a vertical inked date-stamp block at the right margin, neither of which is quoted here. The page carries no applied redaction. ↩ ↩2 ↩3 ↩4 ↩5

  2. Certificate of Existence for PLAN D, LLC, Office of the Lieutenant Governor of the Virgin Islands, issued at Charlotte Amalie on the thirteenth day of September 2018 over the printed name of Osbert E. Potter. https://epstein-data.com/EFTA01298637 p.1. Rendered at 300 dpi and read against the image: the sheet carries an inked circular seal impression at the left margin, an embossed territorial seal at the foot, a pen signature above the printed name, an orange “CONFIDENTIAL” overlay and a Rule 6(e) legend, and three production stamps. A second copy of this certificate in the release, at https://epstein-data.com/EFTA01425210 p.1, is a RECONSTRUCTION and not a photograph — uniform monospaced type on a clean white field, with no seal, no signature, no paper grain and no skew. It is not cited here; the photograph is. ↩ ↩2 ↩3

  3. The same articles, page 2 of 4, Articles Four to Seven; Bates JPM-SDNY-00063118. https://epstein-data.com/EFTA01583447 p.1. Rendered at 400 dpi and read against the image. The extraction of this page gives the organizer’s address as “Suite 25” and the statutory reference as “Subsections VII and 15)”; the image reads “Suite 15” and “Subsections (4) and (5)”, and the image is followed here. The page carries no applied redaction. ↩ ↩2 ↩3 ↩4 ↩5

  4. J.P. Morgan Entity Account Application for PLAN D LLC, sheet 1 of 2; Bates JPM-SDNY-00063123. https://epstein-data.com/EFTA01583451 p.1. Rendered at 400 dpi and read against the image. The tick-box states above are measured from the image: at the entity-type row the mark falls on “Limited Liability Company”; at the accounts-applied-for block the mark falls on “Checking Account” and the four other boxes are empty; on the line-of-credit line neither box is marked; at the ownership question the mark falls on “Yes”. The words inserted above the type-of-business entry are in ink — varying stroke weight, sitting above and off the print baseline — and are absent from the extraction of the page. Applied black rectangles cover four fields on this sheet. A date of birth and identity and tax reference numbers printed on this page are not reproduced here. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  5. JPMorgan account-opening record for PLAN D LLC, sheet 2, giving the client service group, initiator, booking bank, banker, account type and account legal address, and the contents of the checks and check-details panels; Bates JPM-SDNY-00063130. https://epstein-data.com/EFTA01583458 p.1. Rendered at 400 dpi and read against the image: the sheet is a printed export of a screen record, carrying no ink and no applied redaction. ↩ ↩2 ↩3 ↩4

  6. JPMorgan internal email chain, “IMPORT REQUEST” returned marked “Request Completed”, enclosing the checkbook request of Monday, March 18, 2013 under the subject “The following newly opened account includes Checkbook Request”, worked in the Private Bank’s Goregaon (West), Mumbai office; Bates JPM-SDNY-00063129. https://epstein-data.com/EFTA01583457 p.1. Rendered at 400 dpi and read against the image; nine applied black rectangles cover fields on this sheet. Account and telephone numbers on this page are not reproduced here. The enclosed message carries a clock time with no zone printed and the outer message carries no time field at all, so no time of day and no interval is stated above. The “Related Customers” table on this sheet is overlaid by a second panel and its rows cannot be read. ↩ ↩2 ↩3

  7. J.P. Morgan Entity Resolution Form for PLAN D LLC, page 1 of 2; Bates JPM-SDNY-00063126. https://epstein-data.com/EFTA01583454 p.1. Rendered at 600 dpi and each entered field magnified and measured against the two specimen signatures on the same sheet, which are known ink. The certifying officer’s name is ink: irregular letterforms of varying stroke weight sitting off the baseline grid, darkest grey value 5 on a 0-255 scale. So is the year glyph following the printed “20”, a solid overwritten mark of darkest value 0 which could not be resolved into digits at that resolution. The entity name, the jurisdiction, the day of the month and the month are uniform in stroke weight, sit on the baseline and are set in one face distinct from the form’s own body print: they are machine-printed and not entered by hand. The printed word “Secretary” in the opening line is struck through by a heavy ink stroke. Both authorized-signer names are machine-printed and each carries a pen signature in the specimen box beside it; on both rows the mark falls on “Singly” and the “Jointly” box is empty; the third and fourth signer blocks are empty. In the resolutions below, a manuscript mark stands on the rule to the left of resolution 1, banking and custody, and the rule to the left of resolution 2, investment management, is blank. Applied black rectangles cover five fields on this sheet. Dates of birth, identity numbers and telephone numbers printed on this page are not reproduced here. This page is also cited, for the two signers, on Harry Beller. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  8. Promissory Note, $28,500,000.00, March 27, 2017, Plan D LLC as Maker and Leon Black as Holder. https://epstein-data.com/EFTA00592523 p.1. Rendered at 400 dpi and read against the image: a photographed sheet with skew and paper tone, carrying no applied redaction and no production stamp. ↩ ↩2 ↩3

  9. Demand Promissory Note, $8,000,000.00, April 17, 2017, Plan D, LLC as Maker and BV70 LLC as Holder. https://epstein-data.com/EFTA00622816 p.1. ↩ ↩2 ↩3

  10. “AMENDMENT NUMBER 1 TO PROMISSORY NOTE OF PLAN D, LLC, DATED MARCH 30, 2017, PAYABLE TO THE ORDER OF BV70 LLC”, made effective the thirty-first day of March 2017. https://epstein-data.com/EFTA00583036 p.1. ↩ ↩2 ↩3

  11. Government of the Virgin Islands v. Estate of Jeffrey E. Epstein, GVI’s First Amended Complaint, paragraph 33, filed as an exhibit in Giuffre v. Maxwell, Case 1:15-cv-07433-LAP, Document 1111-1, September 1, 2020. https://epstein-data.com/EFTA00018778 p.8. The sentence is quoted as the extraction gives it, including its stop after the pilot’s surname. The complaint is the government’s pleading; its allegations are not findings. ↩ ↩2

  12. Certification of the Secretary of State of Delaware, Harriet Smith Windsor, “DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT COPY OF THE CERTIFICATE OF INCORPORATION OF “PLAN D, INC.”, FILED IN THIS OFFICE ON THE TWELFTH DAY OF APRIL, A.D. 2007, AT 2:34 O’CLOCK P.M.”; Bates JPM-SDNY-00063208. https://epstein-data.com/EFTA01583525 p.1. Rendered at 300 dpi, and the filing-time line re-rendered at 600 dpi and magnified: a photographed sheet carrying the Secretary’s inked office seal, a pen signature above the printed name, and an authentication number, with no applied redaction. The image reads “2:34”; the extraction of the page reads “2:54”, and the image is followed here. The 2007 material for the Delaware corporation begins in the same file at Bates JPM-SDNY-00063166, after the Virgin Islands company’s papers. The 2007 account-opening correspondence itself is described and cited on JPMorgan Chase and is not restated here. ↩ ↩2

  13. For HYPERION AIR, LLC: Certificate of Existence, Office of the Lieutenant Governor of the Virgin Islands, issued at Charlotte Amalie on the thirteenth day of September 2018 over the printed name of Osbert E. Potter, certifying that the company “filed Articles of Organization with the Office of the Lieutenant Governor on October 19, 2012”. https://epstein-data.com/EFTA01387522 p.1. For JEGE, LLC: a certificate in the same form and of the same date, certifying the same filing date. https://epstein-data.com/EFTA01298588 p.1. Both rendered at 300 dpi and read against the image: each is a photographed sheet carrying an inked circular seal at the left margin, an embossed territorial seal, a pen signature above the printed name and a Rule 6(e) legend. Neither certificate names this company, and the Certificate of Existence for this company names neither of them. ↩

  14. The same complaint, paragraph 34, pleaded “[u]pon information and belief.” https://epstein-data.com/EFTA00018778 p.8. ↩ ↩2

  15. “DKI TALL FILE CABINET”, a typed inventory of drawers and folder tabs, the heading “DISSOLUTIONS” and the twelve lines under it. https://epstein-data.com/EFTA00298018 p.14; the inventory opens at p.1. Rendered at 400 dpi and read against the image: a typed sheet with no signature, no manuscript mark and no applied redaction, listing folder tabs. The twelve lines under the heading were counted at the image: the two lines quoted are the second and the ninth of them, with six lines between them. This is a list of what folders were labelled; nothing on the sheet is an instrument, and the desk’s standing caution against reading a folder-tab list as the instruments it names applies. The same inventory is cited on Thomas World Air for a different drawer. ↩ ↩2

  16. The same articles, page 4 of 4, execution and jurat; Bates JPM-SDNY-00063120. https://epstein-data.com/EFTA01583449 p.1. Rendered at 600 dpi and the two date fields magnified: in both the attestation and the jurat the day of the month is left blank in the print and entered by hand on the printed rule, in strokes of varying weight sitting off the baseline grid; the day is not transcribed here and the filing date given on this page is taken from the Certificate of Existence instead. A pen signature crosses the rule above the printed name of the organizer, and a second pen signature sits above the notary rule; the printed notary block below it names Brett A. Geary, notary public for the district of St. Thomas/St. John. The stamp at the right margin is not quoted. ↩ ↩2

  17. The same articles, page 3 of 4, Articles Eight and Nine; Bates JPM-SDNY-00063119. https://epstein-data.com/EFTA01583448 p.1. ↩

  18. Operating Agreement of PLAN D, LLC, Exhibit A, “MEMBER LISTING: CAPITAL CONTRIBUTIONS”; Bates JPM-SDNY-00063147. https://epstein-data.com/EFTA01583472 p.1. Rendered at 400 dpi and read against the image: the printed date beside the acceptance block reads October 19, 2012, and a single ink stroke crosses the “By:” rule above the machine-printed name. The body of this agreement, which names the sole member and states the company’s purpose, is quoted on JPMorgan Chase and is not requoted here. ↩

  19. JPMorgan internal email, February 21, 2013, subject “Please approve 3 KYCs”, naming three U.S. Virgin Islands entities of which PLAN D LLC is one, and the reply of the same date; described in full and cited on Hyperion Air. https://epstein-data.com/EFTA01583436 p.1. ↩

  20. The same application, sheet 2 of 2, agreement and signature; Bates JPM-SDNY-00063124. https://epstein-data.com/EFTA01583452 p.1. Rendered at 600 dpi and the signature band magnified: the first of three signature rules carries a pen signature and a manuscript date, both in ink of varying stroke weight; the name to their right is machine-printed; the second and third rules carry no mark. The manuscript date reads 03/07/2013 at the image; the extraction of the page renders it “03/01 /20/3”. ↩ ↩2

  21. JPMorgan cheque order screen for PLAN D LLC, sheet 1 of a two-sheet capture, headed “Page: 1”, screen MEC010A-03, status CONFIRMED, ordered 03/19/2013; Bates JPM-SDNY-00063131. https://epstein-data.com/EFTA01583459 p.1. Rendered at 400 dpi and read against the image: a photographed sheet carrying pen tick-strokes over several printed fields, and one applied black rectangle. Clock times are printed at three places on the sheet, none of them carrying a zone, so no time of day is given here. Account and telephone numbers on this page are not reproduced here. ↩ ↩2

  22. The second copy of the same 03/19/2013 order, sheet 1 of two, headed “Page: 1”; Bates JPM-SDNY-00063149. https://epstein-data.com/EFTA01583474 p.1. Rendered at 400 dpi and read against the image: two applied black rectangles; pen tick-strokes across the printed fields, as on the first copy, and a pen tick at the head of the sheet; and below the screen area three lines of manuscript annotation in ink, with a further manuscript figure above and to the right of them, together with an inked rubber stamp carrying a name and initials, which is described and not quoted. Account and telephone numbers on this page are not reproduced here. ↩ ↩2 ↩3

  23. The shipping screen captured behind the first copy of the order, headed “Page: 2”, screen MEC040A-01; Bates JPM-SDNY-00063132. https://epstein-data.com/EFTA01583460 p.1. Rendered at 400 dpi and read against the image: the shipping address block gives a business name, a Park Avenue street line, a city and a state, and the first, middle and last name fields are left blank; pen tick-strokes cross several printed fields. Account, telephone and internal reference values on this page are not reproduced here. ↩ ↩2

  24. The shipping screen captured behind the second copy, headed “Page: 2”, screen MEC040A-01; Bates JPM-SDNY-00063150. https://epstein-data.com/EFTA01583475 p.1. Rendered at 400 dpi and read against the image: the same shipping address block, with the same fields blank, and a mirror-image impression of the verification stamp standing in the lower half of the sheet. Account, telephone and internal reference values on this page are not reproduced here. ↩ ↩2

  25. The same agreement, Section V, management; Bates JPM-SDNY-00063144. https://epstein-data.com/EFTA01583469 p.1. Rendered at 400 dpi and the section magnified; the quotations above are read from the image, and the extraction of this page is damaged at several of the quoted words. ↩

  26. The same note, page 4, governing law, jury-trial waiver, execution and notarial acknowledgment. https://epstein-data.com/EFTA00592523 p.4. Rendered at 400 dpi and read against the image: a large blue-ink signature crosses the printed rule above “Jeffrey Epstein, Sole Member”, a second blue-ink signature sits above the notary rule, and the printed notary block below names a New York notary public. A second copy of the whole note is at https://epstein-data.com/EFTA00624912 pp.1 and 4; page 4 of that copy was rendered at 400 dpi and compared with page 4 of this one, and the two images agree in the printed text and in the ink. No claim is made here about copies elsewhere in the release. ↩ ↩2

  27. The Deutsche Bank transaction chart, the Dechert report’s account of the 2017 loans, and the two guaranty letters are cited and quoted on Leon Black and Southern Trust Company; the compliance inquiry captioned to the Plan D account is at https://epstein-data.com/EFTA01423373 p.1. ↩

  28. The Bates order of the JPMorgan client file was read by listing the page stamps from EFTA01583425 to EFTA01583529 and reading the first page of each, one page to an identifier. The instruments named above appear in the order given, and the gaps between them are occupied by further sheets of the bank’s file, which is why consecutive instruments are not consecutively numbered. The sheets on either side of the articles were opened and are the bank’s own document-system index sheets; the other gaps were not identified sheet by sheet, and nothing here says what fills them. The articles occupy https://epstein-data.com/EFTA01583446 to https://epstein-data.com/EFTA01583449 and are bounded by index sheets at https://epstein-data.com/EFTA01583445 p.1 and https://epstein-data.com/EFTA01583450 p.1. The second of those was rendered at 300 dpi and read: it is a blank-bodied indexing sheet headed “Form Type = “CITADEL"" with a date field of 02262013 and a document code, and it carries no instrument. Neither the sheets before nor those after the articles, up to the account application, carry an amendment. ↩ ↩2 ↩3

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