TypeUnited States Virgin Islands limited liability company. Its operating agreement recites that Jeffrey E. Epstein “hereby forms ZORRO MANAGEMENT, LLC, a U.S. Virgin Islands limited liability company”1
Formed14 December 2016, by the filing of Articles of Organization with the Office of the Lieutenant Governor; the Lieutenant Governor certified the same date in September 201812
MemberJeffrey E. Epstein, sole member, 100 membership units, 100 per cent, capital contributed $1,000.003
OrganizerBrett Geary, who swore the articles before a Virgin Islands notary on 14 December 20164
Resident agentBusiness Basics VI, LLC, Royal Palms Professional Building, Suite 101, St. Thomas5
Addresses of recordThe articles give the Royal Palms Professional Building as the company’s physical and mailing address; the operating agreement of the same date gives the principal place of business as 6100 Red Hook Quarter, B3, St. Thomas, which is also the address printed on its cheques and entered on its bank applications; its 2019 registry filing gives 9053 Estate Thomas, Suite 1015167
BanksDeutsche Bank Trust Company Americas, two checking accounts, the second styled “(House Account)”; American Express, a Plum Card account in the company’s and Epstein’s names8910
ComplianceCarried under Deutsche Bank’s internal relationship label “Southern Financial Relationship”; a know-your-customer case in the company’s name was rejected in July 2017, and the company was one of three accounts in the bank’s 2018 periodic review of high-risk accounts111213
Date-opened discrepancyThe bank’s September 2019 exhibit to prosecutors gives a date opened of 4/25/2014 for the company’s checking account, two years and eight months before the company was formed. This page reports the difference and does not resolve it14115
After Epstein’s deathBoth accounts stood at $0 and were still open on a bank closure instruction of 8 July 2019; the estate’s Schedule B gives the company $205,186 as at 10 August 2019 and a dash as at 31 December 2019; the Verified Inventory values it at nil161718
Route into the releaseDeutsche Bank’s account-opening file and its compliance correspondence; the bank’s 12 September 2019 presentation to the Southern District of New York; cheque and statement runs produced by the bank; filings in the Epstein estate probate in the Superior Court of the Virgin Islands

Zorro Management, LLC is a Virgin Islands company that Jeffrey Epstein formed on 14 December 2016 and that, from March 2017, paid the running costs of his New Mexico ranch: it wrote the cheques to ranch hands and Albuquerque contractors, and the ranch office signed its electronic mail in the company’s name.1619 It held two Deutsche Bank checking accounts and an American Express card account, and in 2018 the bank reviewed it as one of three high-risk accounts under a single relationship label.891020

The New Mexico property itself, its buildings and its management are the subject of Zorro Ranch; title to the land and the state leases stood in the Zorro Trust until December 2011 and thereafter in Cypress, Inc. Neither is repeated here.

Four Zorro names, and this page is about the fourth

The release uses four similar names for four different things, and a document that says one of them does not support a statement about another.

The Zorro Trust held title to the Santa Fe County land, the state leases and the water rights from 1993 to December 2011. Zorro Ranch, LLC is entered on Epstein’s office schedule of entities as a single-member New Mexico limited liability company “formed 12-27-2002 to hold title yet never used”.21 Zorro Development Corp. is entered on the same schedule as the entity that “[p]ays all operating expenses and cap improve” for the property.21 Zorro Management, LLC, the subject of this page, is none of those: it is a Virgin Islands limited liability company formed twenty-three years after the trust took title, whose own instruments recite its formation on 14 December 2016.15

The two Zorro companies were live at the same time and the bank kept them apart. Deutsche Bank’s daily deposit report for 29 December 2016, read at the image, carries “ZORRO DEVELOPMENT CORP.” and “ZORRO MANAGEMENT, LLC” as separate rows two apart, at .00 and 200,000.00 respectively, with LSJE, LLC between them; the account-number column is covered by a black bar down the whole list.22 The bank’s 2019 exhibit likewise gives them separate rows.14

Formation, December 2016

The Articles of Organization are in the release under a printed “FILE COPY” stamp. Their opening recites: “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 … do hereby adopt the following Articles of Organization.” Article One names the company, gives its physical address as “Royal Palms Professional Building, 62-3A & 62-3B Estate Thomas, Suite 101, St. Thomas, Virgin Islands 00802” and its mailing address as the same building at 9053 Estate Thomas, and names “its initial resident agent at such address” as “Business Basics VI, LLC.”5 The execution page reads: “IN WITNESS WHEREOF, the undersigned person has hereunto set her hand as Organizer of the Company this 14th day of December, 2016,” and the notarial paragraph beneath it recites that on the same day “personally appeared Brett Geary, who, being by me first duly sworn, declared that she is the person who signed the foregoing document as the Organizer of the Company.”4

The operating agreement is dated the same day and made by Epstein alone. It is “made and entered into as of December 14, 2016 by Jeffrey E. Epstein (hereinafter referred to as ‘Sole Member’), with an address at 6100 Red Hook Quarter, B3, St. Thomas, USVI 00802, who hereby forms ZORRO MANAGEMENT, LLC, a U.S. Virgin Islands limited liability company.” Section I records that the company “has been organized … by the filing of Articles of Organization (‘Articles’) with the Office of the Lieutenant Governor, on December 14, 2016, as required by the Act”; that its purpose “is to engage in any lawful activity, operate any lawful enterprise or to have any other lawful purpose permitted by the law of the territory”; that it “shall continue in existence perpetually, beginning on the date of filing of the Articles, unless terminated by law or dissolved and terminated”; and that “[t]he Company’s principal place of business shall be 6100 Red Hook Quarter, B3, St. Thomas U.S. Virgin Islands 00802 or such other place or places as the Sole Member may hereafter determine.”1 The two instruments of that one day therefore give two different principal offices, and this page reports that without resolving it.51

Exhibit A to the operating agreement is a one-line member listing: Jeffrey E. Epstein, capital contributed $1000.00, 100 membership units, 100 per cent membership interest, over the words “ACCEPTED AND AGREED” and the date December 14, 2016; a large looping pen stroke crosses the rule captioned with his printed name, and this page reports the stroke and does not characterise it.3

The operating agreement, the certificate of existence quoted below, two messages in the 2018 chain and the estate’s Verified Inventory are each in the release in more than one copy.23

Twenty-one months later the territory certified the company’s existence. On 13 September 2018 the Lieutenant Governor of the Virgin Islands, Osbert E. Potter, certified “[t]hat ZORRO MANAGEMENT, LLC filed Articles of Organization with the Office of the Lieutenant Governor on December 14, 2016 and the Company is duly organized under the laws of the United States Virgin Islands”; “[t]hat the duration of this Limited Liability Company shall be perpetual”; “[t]hat the company has paid all applicable fees to date”; and “[t]hat Articles of Termination have not been filed by the company.”2

The two bank accounts, and a date that precedes the company

Deutsche Bank’s account-opening file for the company is in the release. It holds two Business Deposit Account Applications on the bank’s Wealth Management form, each carrying a rubber-stamped “ORIGINAL” at the head, each with the “Limited Liability Company (LLC)” box ticked under the printed heading Client Relationship and the “Checking Account” box ticked under DBTCA Accounts.89

The first is in the name “Zorro Management, LLC.” Beside the account title a hand entry reads 12/14/2016, the day the articles were filed; the field beneath it, and the second line of the mailing address, are covered by black bars. On its last sheet the authorised-signer block carries a pen stroke, the printed-name rule is completed by hand with the name Jeffrey Epstein and the date rule beneath it with the date December 14, 2016; in the block headed “For Bank Use Only” the reviewer’s date reads 12/20/16 and the date under “Accepted by DBTCA:” reads 12/20/16.815

The second is in the name “Zorro Management, LLC (House Account),” with the entity name given as Zorro Management, LLC. The date beside the account title is machine-typed 12/14/2016; the taxpayer-identification field and the business-telephone field are covered by black bars. On its last sheet the printed-name rule is again completed by hand with the name Jeffrey Epstein and the date rule with 3/6/17, and in the bank-use block both the reviewer’s date and the date under “Accepted by DBTCA:” read 3/13/17. On that second application the reviewer’s and accepter’s name rules are covered by black bars where on the first application they are not.92415

Deutsche Bank’s own exhibit to prosecutors dates one of those accounts to 2014. On 12 September 2019 the bank gave the Office of the United States Attorney for the Southern District of New York a spiral-bound presentation whose Exhibit B is headed “Nature and Purpose of Active / Capitalized Southern Financial Relationship Accounts.” Under a group label printed in the left-hand column as “Property Management,” the sheet carrying the company’s rows gives:

  • “Zorro Management, LLC”, account type Checking, date opened 4/25/2014, KYC purpose “The purpose of this account is to manage the daily expenses of the company.”
  • “Zorro Management, LLC (House Account)”, Checking, date opened 3/13/2017, “The purpose of the account is to manage the monthly expenses of the company.”
  • “Zorro Development Corp.”, Checking, date opened 4/25/2014, “Checking account for the day-to-day expenses associated with running the ranch in New Mexico that Zorro owns.”

The account-number column is covered by a black bar down the whole length of the table and no account number is reproduced here.14 Exhibit D of the same presentation, on the parties to those accounts, gives Jeffrey Epstein as ultimate beneficial owner of each of the three; for the Zorro Management, LLC account it gives Jeffrey Epstein and Darren Indyke as signatories, and for the House Account four signatory entries, of which one is covered by a black bar and is not identified here and the last is Brice Gordon.25

The date given for the second account, 3/13/2017, is the date entered in the bank-use block of that account’s own application.2414 The date given for the first, 4/25/2014, is two years and eight months before the day the company’s articles were filed, before the day its application was signed, and before the day the bank accepted it; it is also the date the same sheet gives for Zorro Development Corp.’s checking account, on the row two below the company’s own, with the House Account row standing between them.181514

The bank’s own automated reporting does not carry the company before that December. Deutsche Bank sent a “Daily Deposit Report” to relationship-manager distribution lists listing accounts under a code with large, zero or negative balances; 2,385 sheets of it in the release carry a report date in their subject line, running from 28 August 2013 to 9 July 2019. On the 1,324 of those whose subject-line date falls before 21 December 2016, the only string beginning “Zorro” that the extraction carries is “ZORRO DEVELOPMENT CORP.” The earliest report naming the company is the one reporting balances as of 20 December 2016, the day the bank accepted the application, where “ZORRO MANAGEMENT, LLC” appears with a balance of .00 against “ZORRO DEVELOPMENT CORP.” at 229,424.00. That is a statement about the extracted text of those sheets rather than about their images; two of them were read at the image and are pinned here: the report for 25 April 2014, which names Zorro Development Corp. twice and Zorro Management not at all, and the report for 20 December 2016.2627

This page reports the difference between the exhibit and those documents and does not resolve it. No document cited here explains it.

The bank had already told itself to check. On 5 July 2017 a Deutsche Bank message headed “Your KYC has been rejected”, giving the relationship as “SOUTHERN FINANCIAL RELATIONSHIP” and the customer name as “Zorro Management, LLC” with the case number and customer number covered by black bars, set out nine reasons. The fifth reads: “Please provide Certificate of Good Standing for all entities dated within 6 months.” The sixth reads: “Please ensure the account opening date for all account holders is accurate.”11 Nothing cited here records what was done about that point. The notice’s fourth point concerns the legal name of a signatory on the file and is set out on Jeanne Brennan-Wiebracht.11

The 2018 periodic review

In July 2018 Deutsche Bank’s know-your-customer unit in Mumbai opened its annual review of three high-risk accounts under the Southern Financial Relationship label: Southern Trust Company, Inc., Jeffrey E. Epstein personally, and this company. The opening message of the chain, sent on 30 July 2018 by a KYC case representative to the New York relationship team, states: “This review relates to above high risked three accounts due for remediation 08/31/2018,” and “Upon review of the docs available in the repositories, I have completed the attached checklist, main RP’s also listed below for reference.”20

Its block for the company opens “Acct Holder — Zorro Management. LLC” and “Sole Member & Authorized Signature — Jeffrey Epstein”, and its authorised-signatories line names Darren D. Indyke and Brice M Gordon with a third name between them covered by a black bar, which is not identified here.13 The same block sets the bank’s requirement: “We require SoS extracted from US Virgin Islands website for the account holding entity. We are unable to extract the same as there is a cost involved with the request, so kindly provide the same. Note we already have the COE (Certificate of Existence) for this entity. The SoS is required so we can evidence that this entity is still registered with the authorities and is active.”13

The same message goes on to a second inaccuracy the bank found in the account’s file. Of the customer due diligence form already provided for the account, it reads: “please note that under section c, Jeffrey Epstein’s legal address is incorrect. It seems they have provided the entity address”13; the sentence completes on the next sheet, which says the entity’s address had been provided there instead of the member’s personal address, and asks the relationship team to “have that amended by the client & re-send revised form accordingly.”28 The 22 August 2018 message quoted below records “revised CDD Forms provided (in separate emails)”.29

A week earlier the same unit had put the company on a list of the accounts under the relationship “due for remediation this year,” in a message about the customer due diligence forms required under the FinCEN rule; the sheet says the form “is missing for entity highlighted in yellow below,” and the copy in the release is monochrome, so which of the nine entities was highlighted cannot be read from it.30

The chain then runs three months. On 22 August 2018 the case representative wrote that “we have launched KYC Case#01977695 for these accounts” and confirmed that the outstanding item was a “SoS or COGS (dtd within last 6 months) from US Virgin Islands registry for Zorro Management LLC.”2912 On 24 September 2018 he sent a reminder listing the same item as still pending.31 The same day, a vice-president in Deutsche Bank Wealth Management in New York replied: “See attached COGS for Zorro.”32 The certificate of existence signed by the Lieutenant Governor eleven days earlier, on 13 September 2018, is in the same account-opening file.2 On 26 September the case representative wrote “Many thanks for the docs & clarification, we are assigning this case (01977695) to Stewart for review,” and asked him to “forward to the AML team for final approval”; the reply the same morning reads in full: “Submitted. Thanks”.33

The release also contains a recall notice for the message that opened the review. It carries the same subject line prefixed “Recall:”, an RFC date header of “Mon, 30 Jul 2018 05:07:58 -0400”, and the single line: “Vijay-A Sawant would like to recall the message, ‘2018 Periodic Review of High Risked Accounts Southern Trust Company, Inc …, Epstein, Jeffrey E. … and Zorro Management, LLC … under the SOUTHERN FINANCIAL RELATIONSHIP’.”34 The chain quoted above nevertheless carries a message of that subject as sent on 30 July 2018. This page reports both and does not reconcile them.

“SOUTHERN FINANCIAL RELATIONSHIP” is the bank’s own label for the group of accounts, not the name of an entity, and it is printed as such on the subject line of the review, on the July 2017 rejection notice and in the heading of the 2019 exhibit.121114

What the company paid for

Cheque number 1001, drawn by “ZORRO MANAGEMENT, LLC” of 6100 Red Hook Quarter, B3, St. Thomas, on Deutsche Bank Trust Company Americas, New York, is dated 3/24/2017 and pays Stone Gate Turf & Ranch $1,386.00, “One Thousand Three Hundred Eighty-Six Only”; a pen signature crosses the rule captioned AUTHORIZED SIGNATURE, and the memo area and the magnetic-ink line at the foot are each covered by a black bar.6 The extraction of later cheques in the same two runs shows payees who are Albuquerque and Moriarty suppliers, among them Molzen-Corbin and Western Systems, and individuals under memo lines recording a number of hours at an hourly rate for ranch work; those sheets were not opened at the image and no individual paid on them is identified here.635

The ranch office wrote in the company’s name. A message sent from a “Zorro Ranch” mailbox on 20 January 2017 about household supplies for Paris closes with a signature block giving “Zorro Management LLC”, then a line covered by a black bar, then the line “Ranch Manager”, then a further covered line; the recipient line and part of the signature block are covered by black bars, and no person is identified here.19 A search of the release for both “Zorro Management” and “Ranch Manager” returns 148 pages; of these, 47 carry a date this page could parse, the earliest 20 January 2017 and the latest 25 May 2019. The 20 January 2017 sheet was read at the image; the other 147 were not.19

The company also held an American Express card account. Its first statement, a Plum Card statement in the names “ZORRO MANAGEMENT LLC” and “JEFFREY E EPSTEIN” at the Red Hook Quarter address, has a closing date of 02/08/17, a previous balance of $0.00, new charges of $2,549.44, a new balance of $2,549.44 and a billing period of sixteen days, and carries the line “Welcome to American Express! Thank you for choosing OPEN to service your small business needs.”10 Statements in the same series in the release carry closing dates from 8 February 2017 to 10 November 2019. Account numbers on those pages are not reproduced here.1036

The name in the bank listings

Searching the released text for “Zorro Management” returns 2,874 pages across 2,219 documents. Classifying all 2,874 pages by the words their extraction carries: 1,063 carry the header or column line of a Deutsche Bank daily deposit report; a further 198 carry the same repeated entity-listing shape without those words; 390 are cheque images; 181 are American Express statement sheets; 54 are bank statements with a “Beginning Balance” line; and the remaining 988 were not classified by that test. On that classification 1,261 of the 2,874 pages, or 44 per cent, are one row in a repeated listing rather than a document about the company, and 988 are unclassified.37

The daily deposit report is an automated overnight message. The one for 29 December 2016 is addressed to a bank distribution list, carries a relationship-manager code and the printed line “LARGE, ZERO AND NEGATIVE BALANCES” over the column headings ACCT #, NAME, CAT, BALANCE and OD AMOUNT, and lists fourteen names with their balances; the account-number column is covered by a black bar down the whole list, and the sender and recipient lines are covered by black bars.22

In the estate

Both Deutsche Bank accounts were still open, at nil, in July 2019. At 7:33 on the morning of Monday 8 July 2019, Eastern Daylight Time, a Deutsche Bank officer sent the relationship team a message headed “URGENT!!! Need to close accounts ASAP - please prioritize today,” whose first item is “$0 balance deposit accounts that are still open. Please coordinate with Daphne Cales to get these closed out on the system.”38 The signature block that closes that message gives the sender’s title as Managing Director and Divisional Control Officer, the division as Wealth Management Americas and the bank as Deutsche Bank Trust Company Americas.39 The list beneath it ends with “ZORRO MANAGEMENT, LLC” and “ZORRO MANAGEMENT, LLC (HOUSE ACCOUNT)”; a black bar runs down the left of the list, and one entry within it is covered and is not identified here.3816 The bank’s handling of the wider closure is on Deutsche Bank and is not repeated here.

Three weeks later the company made its own filing. On 31 July 2019 “Ms. Erika KELLERHALS,” entered as “Attorney in Fact” on behalf of the member Jeffrey EPSTEIN, signed the company’s 2019 annual report to the Lieutenant Governor under a declaration made under penalty of perjury; the registry filed it on 1 August 2019. The form gives the principal office as 9053 Estate Thomas, Suite 101, Charlotte Amalie, an amount of capital of 1,000.00 with nothing withdrawn, and the company as member managed with Jeffrey EPSTEIN as its member; the tax identifier field and the member’s e-mail address are covered by black bars.740

The estate then valued the company twice. Schedule B to the First Quarterly Accounting in the Epstein estate probate gives “Zorro Management LLC,” beneficial ownership 100 per cent, a total value of 205,186 as at 10 August 2019 and, in the column for 31 December 2019, a dash; seven other entities on the same schedule carry a dash in that column, and the columns were read across at the image.17 The Verified Inventory then lists “Zorro Management, LLC” among the limited liability companies wholly owned by the decedent at a value of “-0-,” at voucher 12, and its footnote 9 states that the values of those companies “are solely based upon available cash on hand, unless otherwise noted” and names Zorro Management, LLC first among eight entities that “hold other assets which must be appraised.”18 Voucher 12 itself is the company’s 2019 annual report, lodged in the inventory’s exhibits under an exhibit sticker numbered 12.7

What the record here does not show

These documents establish when and where the company was formed, on whose application and in whose sole ownership, what its stated purposes and addresses were, when its two bank accounts were applied for and accepted, what those accounts were said to be for, who could sign on them, what compliance work a bank did on it in 2017 and 2018, what it paid for in New Mexico, and how it was valued in the estate after Epstein’s death.

They do not show why the bank’s 2019 exhibit dates the company’s checking account to a day two years and eight months before the company existed. They do not show what answer, if any, was given to the July 2017 instruction to ensure that account opening dates were accurate.

They do not show that the company was dissolved. These are the searches this page ran, in the words it ran them, over the documents that also name the company. The company’s name together with the word dissolution, and together with the word dissolve, each return nothing.41 Together with the word dissolved, and together with the word terminated, it returns the same two pages, each the duration clause of the company’s own operating agreement in one of its two copies in the release.42 Together with the phrase Articles of Termination it returns three pages, each a copy of the certificate of existence, which states that articles of termination had not been filed as at 13 September 2018.43 The runs immediately on either side of the operating agreement in the Deutsche Bank account-opening file are two bank forms, and the runs immediately on either side of the articles of organization are the certificate of existence quoted above and the first of the two business deposit applications; on its extracted first page none of them is a termination instrument.44 Whether an instrument recording the company’s termination is somewhere in the release under wording none of those searches or those adjacent runs reaches is not settled by this page.

They do not show the company’s tax filings: searched together with the company’s name, the phrases tax return, tax returns, Form 1065, Schedule K-1, franchise tax and franchise taxes each return nothing.45 Searched together with the phrase annual report, it returns two pages, both copies of the 2019 registry filing described above; searched with the plural, annual reports, it returns nothing.46 They do not name any manager or officer: the registry filing records the company as member managed, and no document cited here names a manager. Appearing in these documents is not evidence of wrongdoing by any person named on this page.

Zorro Trust; Zorro Development Corp.; Zorro Ranch; Cypress, Inc.; Deutsche Bank; Southern Trust Company; Darren Indyke; Jeanne Brennan-Wiebracht; Jeffrey Epstein estate; Bank records of the entity network.

Notes

Footnotes

  1. “OPERATING AGREEMENT OF ZORRO MANAGEMENT, LLC / A U.S. Virgin Islands Limited Liability Company”, made as of December 14, 2016, Jeffrey E. Epstein as Sole Member, first page, carrying the recitals and Section I paragraphs A to E. Read at the image at 400 dpi: the sheet is a photograph of a printed instrument under a red “CONFIDENTIAL” overlay and a grand-jury legend, with no manuscript entry on it. https://epstein-data.com/EFTA01298488 p.1. 2 3 4 5 6 7 8 9

  2. Government of the Virgin Islands of the United States, Office of the Lieutenant Governor, “CERTIFICATE OF EXISTENCE” for ZORRO MANAGEMENT, LLC, dated the 13th day of September A.D. 2018 over the printed name of Lieutenant Governor Osbert E. Potter. Read at the image at 400 dpi, which is a photograph of the certificate: a pen signature crosses the rule above the printed name, an embossed territorial seal is impressed at the foot left, a small inked seal stands beside it, and the sheet carries scan skew and paper grain. https://epstein-data.com/EFTA01298500 p.1. 2 3

  3. Same instrument, last page, “EXHIBIT A / MEMBER LISTING; CAPITAL CONTRIBUTIONS”. Read at the image at 400 dpi: the four printed column headings are Members, Capital Contributed, Number of Membership Units and Percentage Membership Interest, and the single row gives $1000.00, 100 and 100%; the words “ACCEPTED AND AGREED:” and “DATE: December 14, 2016” are machine print, and a large looping pen stroke crosses the “By:” rule captioned with the printed name beneath it. The stroke is not attributed here. https://epstein-data.com/EFTA01298488 p.8. 2

  4. Same instrument, execution page, carrying the witness clause and the notarial paragraph. Read at the image at 400 dpi: a pen signature crosses the rule above the organizer’s printed name; a second pen signature crosses the notary’s rule; the commission-expiry blank beside it is completed by hand, and a rubber-stamped notarial block stands beneath. The two signatures are described rather than quoted. https://epstein-data.com/EFTA01298501 p.4. 2

  5. “ARTICLES OF ORGANIZATION OF ZORRO MANAGEMENT, LLC”, first page, Article One. Read at the image at 400 dpi: a grey “FILE COPY” stamp stands at the head of the sheet and the whole page is machine print with no manuscript entry. https://epstein-data.com/EFTA01298501 p.1. 2 3 4 5

  6. Cheque image, drawer “ZORRO MANAGEMENT, LLC”, 6100 Red Hook Quarter, B3, St. Thomas, USVI 00802, on Deutsche Bank Trust Company Americas, New York, cheque number 1001, dated 3/24/2017, in a run of cheque images produced by the bank. Read at the image at 400 dpi: the drawer’s printed address is not covered on this sheet; a pen signature crosses the rule captioned AUTHORIZED SIGNATURE and is not attributed here; the memo area and the magnetic-ink line at the foot are each covered by a black bar and neither is reproduced here. https://epstein-data.com/EFTA01294274 p.39. 2 3 4

  7. “THE UNITED STATES VIRGIN ISLANDS / Annual Report Filing 2019 / ZORRO MANAGEMENT, LLC”, USVI Lieutenant Governor, filed 1 August 2019, first of three sheets, lodged as an exhibit to the Verified Inventory in the Epstein estate probate. Read at the image at 400 dpi: the sheet is a photocopy of a blue-tinted web filing record under the territorial seal; the filing line at the head gives the filing date and a clock time, and carries no time zone, so no time from it is given anywhere on this page; the Tax Identifier Number field is covered by a black bar and is not reproduced here; the capital block gives 1,000.00 for the amount of capital, 0.00 additional and 0.00 withdrawn; an exhibit sticker numbered 12 is affixed across the foot of the sheet and is described rather than quoted. https://epstein-data.com/EFTA00076491 p.37. 2 3

  8. Deutsche Bank Wealth Management “Business Deposit Account Application”, account title “Zorro Management, LLC”, first sheet of three. Read at the image at 400 dpi and again at 600 dpi on the date field: a rubber-stamped “ORIGINAL” stands at the head; the ticked boxes are “Limited Liability Company (LLC)” under Client Relationship and “Checking Account” under DBTCA Accounts; the entry beside the account title is manuscript and reads 12/14/2016; the printed label beneath that entry does not render legibly at 600 dpi on this copy and is not quoted; the field below it and the second line of the mailing address are covered by black bars, and nothing in either is reproduced here. https://epstein-data.com/EFTA01298509 p.1. 2 3 4 5

  9. Deutsche Bank Wealth Management “Business Deposit Account Application”, account title “Zorro Management, LLC (House Acount)” as printed, entity/company name “Zorro Management, LLC”, first sheet of three. Read at the image at 400 dpi and again at 600 dpi on the date field: a rubber-stamped “ORIGINAL” and a pen stroke stand at the head; the ticked boxes are “Limited Liability Company (LLC)” and “Checking Account”; the entry beside the account title is machine type and reads 12/14/2016; the printed label beneath it does not render legibly at 600 dpi and is not quoted; the taxpayer-identification field and the business-telephone field are covered by black bars and neither is reproduced here. https://epstein-data.com/EFTA01298506 p.1. 2 3 4

  10. American Express “Plum Card” statement in the names “ZORRO MANAGEMENT LLC” and “JEFFREY E EPSTEIN”, closing date 02/08/17, next closing date 03/10/17, marked DUPLICATE COPY. Read at the image at 300 dpi. Account numbers on that page are not reproduced here. The sheet’s own printed production stamp differs from the identifier of the run that contains it; the citation below is to the run. https://epstein-data.com/EFTA01671962 p.9460. 2 3 4

  11. Deutsche Bank system message, subject “Your KYC has been rejected”, RFC date header “Wed, 05 Jul 2017 16:23:08 -0400”, relationship “SOUTHERN FINANCIAL RELATIONSHIP”, customer name “Zorro Management, LLC”, listing nine numbered reasons for rejection. Read at the image at 400 dpi: the sender’s and recipient’s addresses, the case number, the customer number, a phrase within reason 1 and the link at the foot are each covered by black bars, and none is reproduced here. https://epstein-data.com/EFTA01416621 p.1. 2 3 4

  12. Same chain, the sheet carrying the close of the 22 August 2018 message and the header block of the 30 July 2018 message it quotes, whose subject line names the three accounts and the relationship label. Read at the image at 300 dpi: the recipients’ e-mail addresses, an embedded image reference and two lines of the sender’s signature block are covered by black bars; customer reference numbers printed on this sheet are not reproduced here. https://epstein-data.com/EFTA01417850 p.5. 2 3

  13. Same quoted message, next sheet, carrying the blocks for the Epstein personal account and for this company. Read at the image at 300 dpi: in the Authorized Signatories line a black bar stands between the first and last names given, and the name it covers is not identified here. https://epstein-data.com/EFTA01417850 p.7. 2 3 4

  14. Deutsche Bank presentation to the Office of the United States Attorney for the Southern District of New York, September 12, 2019, Exhibit B, “Nature and Purpose of Active / Capitalized Southern Financial Relationship Accounts”, the sheet carrying the three Zorro rows. Read at the image at 400 dpi, which is a photograph of a spiral-bound copy: the six printed column headings are Nature of Account Holder, Account Name, Account Type, Account Number, Date Opened and KYC Purpose; the group label “Property Management” is printed in the first column against the block containing these rows; the account-number column is covered by a black bar down the whole length of the table and no account number is reproduced here. The exhibit titles are printed on the contents page of the same presentation at p.1 and the exhibit begins at p.3. https://epstein-data.com/EFTA01681865 p.5. 2 3 4 5 6

  15. Same application, last sheet, carrying the authorised-signer block and the block headed “For Bank Use Only”. Read at the image at 400 dpi: a pen stroke crosses the Authorized Signer rule; the Print Name rule is completed by hand and reads Jeffrey Epstein; the Date rule beneath it is completed by hand and reads December 14, 2016; in the bank-use block a pen signature, a hand-written name and the title AVP stand above a hand-written date reading 12/20/16, and under “Accepted by DBTCA:” a pen signature, a hand-written name and the title Director stand above a hand-written date reading 12/20/16. The two hand-written bank names are described rather than reproduced. The Account numbers block beneath is not reproduced here. https://epstein-data.com/EFTA01298509 p.3. 2 3 4

  16. Same sheet’s continuation, carrying the last six names of that list, of which the fifth is “ZORRO MANAGEMENT, LLC” and the sixth “ZORRO MANAGEMENT, LLC (HOUSE ACCOUNT)”, and the opening of the second item. Read at the image at 300 dpi: a black bar runs down the left of each of the two lists on this sheet. https://epstein-data.com/EFTA01418488 p.15. 2

  17. First Quarterly Accounting, Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80, Superior Court of the Virgin Islands, Division of St. Thomas & St. John, covering August 10 to December 31, 2019, Schedule B, “STATEMENT OF ENTITIES OWNED BY DECEDENT”. Read at the image at 400 dpi and the columns read across: the row “Zorro Management LLC” gives 100%, 205,186 under “As of August 10, 2019” and a dash under “As of December 31, 2019”; the column is totalled under a double rule. https://epstein-data.com/EFTA00082467 p.7. 2

  18. Verified Inventory, Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80, Superior Court of the Virgin Islands, page 2 of the inventory, “Limited Liability Companies Wholly Owned by Decedent”. Read at the image at 400 dpi: the row “Zorro Management, LLC” gives a value of “-0-” against voucher 12, and footnote 9 at the foot of the same sheet names Zorro Management, LLC first among the entities that “hold other assets which must be appraised.” https://epstein-data.com/EFTA00076491 p.2. 2

  19. Message sent from a “Zorro Ranch” mailbox, 20 January 2017, subject “PARIS_BATHMATS_012017”, whose closing block gives “Zorro Management LLC” above a covered line, then the line “Ranch Manager”, then a further covered line. Read at the image at 300 dpi: the recipient line, a word of the salutation, and the two lines of the signature block are covered by black bars and none is reproduced here; the “Sent” line carries a clock time with no zone and no time from it is given on this page. https://epstein-data.com/EFTA02203219 p.1. The counts of returns given in the text are counts of the corpus text and not of images; no other sheet of that set was opened. 2 3

  20. Deutsche Bank KYC case representative to the New York relationship team, “2018 Periodic Review of High Risked Accounts … under the SOUTHERN FINANCIAL RELATIONSHIP”, quoted within a later message of the same chain; this sheet carries the opening paragraphs and the block for Southern Trust Company, Inc. Read at the image at 300 dpi: the sheet is machine print throughout with no manuscript entry and no redaction. https://epstein-data.com/EFTA01417850 p.6. 2

  21. Schedule of entities kept in Epstein’s office, an undated spreadsheet printout whose columns are Entity Name, Type, State, Tax ID #, Year End, Extension Due, Due with Ext, Ownership and Notes; the sheet cited carries the blocks headed PROPERTIES / USVI, NEW MEXICO and FLORIDA. Read at the image at 400 dpi: the sheet is machine print throughout, with no manuscript entry and no redaction; under NEW MEXICO the Notes cell against Zorro Development Corp. reads “Pays all operating expenses and cap improve” and the Notes cell against Zorro Ranch, LLC reads “formed 12-27-2002 to hold title yet never used”. Both quotations in the text above are taken from this sheet. The sheet’s own printed production stamp differs from the identifier of the run that contains it; the citation below is to the run. Tax identifiers printed on this sheet are not reproduced here. https://epstein-data.com/EFTA01118648 p.4. 2

  22. Deutsche Bank automated “Daily Deposit Report”, subject line “RM0082289 Daily Deposit Report 20161230”, RFC date header “Fri, 30 Dec 2016 01:41:45 -0500”, reporting balances as of 12/29/16. Read at the image at 400 dpi: the sender and recipient lines are covered by black bars; the account-number column is covered by a black bar down the whole list; the row “ZORRO DEVELOPMENT CORP.” reads D and .00 and the row “ZORRO MANAGEMENT, LLC” reads D and 200,000.00, two rows apart, with “LSJE, LLC” between them. https://epstein-data.com/EFTA01424157 p.1. 2

  23. The duplicate copies, none of which was opened at the image and none of which anything on this page rests on: a second copy of the operating agreement at https://epstein-data.com/EFTA01255145 p.1; two further copies of the certificate of existence at https://epstein-data.com/EFTA01387542 p.1 and https://epstein-data.com/EFTA01435482 p.1; a second copy of the 24 September 2018 reminder at https://epstein-data.com/EFTA01438356 p.1 and of the reply to it at https://epstein-data.com/EFTA01435475 p.1; and a second copy of the Verified Inventory, carrying the same annual-report exhibit sheet, at https://epstein-data.com/EFTA00076892 p.37.

  24. Same application, last sheet, carrying the authorised-signer block and the block headed “For Bank Use Only”. Read at the image at 400 dpi: a pen stroke crosses the Authorized Signer rule; the Print Name rule is completed by hand and reads Jeffrey Epstein; the Date rule beneath reads 3/6/17; in the bank-use block a pen signature stands above a Name rule covered by a black bar, with the title AVP and a hand-written date reading 3/13/17 beneath; under “Accepted by DBTCA:” the signature and Name rules are covered by a single black bar, with the title VP and a hand-written date reading 3/13/17 beneath. The Account numbers block is not reproduced here. https://epstein-data.com/EFTA01298506 p.3. 2

  25. Same presentation, Exhibit D, “Parties to Active / Capitalized Southern Financial Relationship Accounts”, the sheet carrying the three Zorro rows. Read at the image at 400 dpi: the table continues from the preceding sheet and a partial row stands above the first full row; for the Zorro Management, LLC row the Grantor/UBO cell carries “Jeffrey Epstein (UBO)” and the Signatory cell carries “Jeffrey Epstein (S)” and “Darren Indyke (S)”; for the House Account row the Signatory cell carries four bullets, of which the second is “Darren Indyke (S)”, the third is covered by a black bar and is not identified here, and the fourth is “Brice Gordon (S)”. The account-number column is covered by a black bar. The extraction of this page runs the columns together and nothing above is taken from it. https://epstein-data.com/EFTA01681865 p.13.

  26. Deutsche Bank automated “Daily Deposit Report”, subject line “RM0081851 Daily Deposit Report 20140426”, sent 4/26/2014, reporting balances as of 04/25/14. Read at the image at 300 dpi: the recipient line and a contact line at the foot are covered by black bars and the account-number column is covered by a black bar down the whole list; the sixteen names listed include “ZORRO DEVELOPMENT CORP.” twice, at D .00 and M .00, and include no name beginning “Zorro Management”. https://epstein-data.com/EFTA01453942 p.1.

  27. Deutsche Bank automated “Daily Deposit Report”, subject line ending “Daily Deposit Report 20161221”, sent 12/21/2016, reporting balances as of 12/20/16. Read at the image at 300 dpi: the sender, recipient and relationship-manager code are covered by black bars and the account-number column is covered by a black bar down the whole list; the row “ZORRO MANAGEMENT, LLC” reads D and .00 and the row “ZORRO DEVELOPMENT CORP.” reads D and 229,424.00. https://epstein-data.com/EFTA01380034 p.1.

  28. Same quoted message, next and last sheet of the run, carrying the completion of the sentence quoted above, the request that the form be amended and re-sent, and the close of the message. Read at the image at 400 dpi: beneath the closing lines an embedded image reference is covered by a black bar, and below the sender’s printed business address two further lines are covered by black bars; nothing covered is reproduced here, and no address of any individual is printed on the sheet. https://epstein-data.com/EFTA01417850 p.8.

  29. Same chain, the sheet carrying the opening of the 22 August 2018 message: “As per your attached no material confirmation for the above accounts and revised CDD Forms provided (in separate emails), we have launched KYC Case#01977695 for these accounts.” Read at the image at 300 dpi: an embedded image reference, two lines of the signature block above it and the quoted header’s e-mail addresses are covered by black bars; customer reference numbers printed on this sheet are not reproduced here. https://epstein-data.com/EFTA01417850 p.4. 2

  30. Deutsche Bank KYC case representative to the relationship team, subject “RE: FinCEN CDD Form - Epstein/SOUTHERN FINANCIAL RELATIONSHIP”, RFC date header “Mon, 23 Jul 2018 02:25:28 -0400”, listing nine account holders under the relationship “due for remediation this year”, of which the third is “Zorro Management, LLC”. Read at the image at 300 dpi: the sheet is reproduced in monochrome and carries no visible highlighting, so the entity the message says is “highlighted in yellow” cannot be identified from this copy; the recipients’ e-mail addresses are covered by black bars. https://epstein-data.com/EFTA01415665 p.1.

  31. Same chain, the sheet carrying the 24 September 2018 reminder listing the two outstanding items, over the signature block of the message above it. Read at the image at 300 dpi: two lines of that signature block and the quoted header’s e-mail addresses are covered by black bars, and a customer reference number printed on the sheet is not reproduced here. https://epstein-data.com/EFTA01417850 p.3.

  32. Same chain, the sheet carrying the reply of 24 September 2018: “See attached COGS for Zorro.” Read at the image at 300 dpi: the recipients’ e-mail addresses in the quoted header block are covered by black bars, as is one line beneath a signature block higher on the sheet; business telephone numbers printed on this sheet are not reproduced here. https://epstein-data.com/EFTA01417850 p.2.

  33. Same chain, first sheet: the reply of 26 September 2018 reading “Submitted. Thanks”, over the quoted message of the same morning assigning the case for review. Read at the image at 300 dpi: the sender’s and recipients’ e-mail addresses are covered by black bars; customer reference numbers printed on this sheet are not reproduced here. https://epstein-data.com/EFTA01417850 p.1.

  34. Message-recall notice, subject “Recall: 2018 Periodic Review of High Risked Accounts …”, RFC date header “Mon, 30 Jul 2018 05:07:58 -0400”, whose body is the single sentence quoted. Read at the image at 300 dpi: the sender’s and the three recipients’ e-mail addresses are covered by black bars; customer reference numbers printed on this sheet are not reproduced here. The document is a recall notice and not the review message itself. https://epstein-data.com/EFTA01421805 p.1.

  35. Further cheque images drawn by the company on the same bank, in two runs of cheque images produced by Deutsche Bank: https://epstein-data.com/EFTA01294274 and https://epstein-data.com/EFTA01254891. Cited here only for the classes of payee described in the text; no individual payee is identified here and no figure from those sheets is reproduced. Only p.39 of the first run was opened at the image.

  36. Statements of the same series in the same run. Their closing dates, taken from the extracted text of 123 such sheets, run from 8 February 2017 to 10 November 2019; only the sheet cited above was opened at the image. Account numbers on those pages are not reproduced here. https://epstein-data.com/EFTA01671962.

  37. Counts taken over the corpus text of every page returned by a column-scoped phrase search for “Zorro Management”: 2,874 pages across 2,219 documents. The classification given in the text was applied to all 2,874 pages by the words their extraction carries, in the order stated, and is a classification of the extraction rather than of the images. The daily-deposit-report figures given elsewhere on this page were taken over all 2,385 sheets in the release whose subject line carries a report date of the form “Daily Deposit Report yyyymmdd”.

  38. Deutsche Bank internal message to the relationship team, “URGENT!!! Need to close accounts ASAP - please prioritize today”, within a forward of the same chain; the sheet carries the header block, the instruction and the first nine entries of the list, one of them covered. Read at the image at 300 dpi: the header reads “Date: July 8, 2019 at 7:33:19 AM EDT” and the zone is printed on the sheet; the correspondents’ e-mail addresses are covered by black bars; a black bar runs down the left of the list and one entity name within the list is covered and is not identified here. https://epstein-data.com/EFTA01418488 p.14. 2

  39. The signature block closing the same message, which begins at the foot of the sheet before it and continues onto the last sheet of the run. Read at the image at 300 dpi: the sheet before it ends with the sender’s sign-off, a rule, an embedded image reference and the sender’s printed name; the last sheet carries the title line giving Managing Director and Divisional Control Officer, the division line giving Wealth Management Americas, the bank’s name and its New York street address, and a closing securities line, with the telephone, fax, mobile and e-mail lines covered by a single black bar. The block is described rather than quoted and nothing covered is reproduced here. https://epstein-data.com/EFTA01418488 p.16 and https://epstein-data.com/EFTA01418488 p.17.

  40. Same filing, second sheet, carrying the Managers/Members and Signature(s) blocks. Read at the image at 400 dpi: the entity is entered as “Member Managed”, the member as “Jeffrey EPSTEIN”, status Active, physical address 6100 Red Hook Qtr B3; the member’s e-mail address is covered by a black bar and is not reproduced here; the signature block enters “Ms. Erika KELLERHALS” as Name, “Attorney in Fact” as Position, “Member” and “Jeffrey EPSTEIN” under On Behalf Of, and 07/31/2019 as Date, above a printed declaration made under penalty of perjury. The block carries no image of a handwritten signature. https://epstein-data.com/EFTA00076491 p.38.

  41. Column-scoped phrase searches of the released text, each run as the two phrases together in one query: “Zorro Management” with “dissolution”, and “Zorro Management” with “dissolve”. Each returns no page. The plural “dissolutions” was run as well and returns no page.

  42. The two pages returned by a column-scoped search for “Zorro Management” together with “dissolved”, and by the same search with “terminated”: https://epstein-data.com/EFTA01298488 p.1 and https://epstein-data.com/EFTA01255145 p.1. The first was read at the image at 400 dpi; the second was not.

  43. The three pages returned by a column-scoped search for “Zorro Management” together with “Articles of Termination”: https://epstein-data.com/EFTA01298500 p.1, https://epstein-data.com/EFTA01387542 p.1 and https://epstein-data.com/EFTA01435482 p.1. The first was read at the image at 400 dpi; the other two were not.

  44. The Bates runs adjacent to the two formation instruments in the Deutsche Bank account-opening file, walked rather than searched. Immediately before https://epstein-data.com/EFTA01298488 stands https://epstein-data.com/EFTA01298485, a Deutsche Bank business deposit account application in another company’s name, and before that https://epstein-data.com/EFTA01298484, a bank form whose extracted first page carries the House Account title; immediately after it stands https://epstein-data.com/EFTA01298496, whose extraction is illegible, and then https://epstein-data.com/EFTA01298498, a bank certificate of a limited liability company’s resolutions naming this company. Immediately before https://epstein-data.com/EFTA01298501 stands https://epstein-data.com/EFTA01298500, the certificate of existence pinned above; immediately after it stands https://epstein-data.com/EFTA01298506, the House Account application pinned above. Of the pages pinned in this footnote, only the certificate of existence and the House Account application were read at the image, and each of the others was identified from its extracted first page alone; no statement on this page rests on those others beyond the fact that none of them is a termination instrument on that first page.

  45. Column-scoped phrase searches of the released text, each run as “Zorro Management” together with the second phrase in one query: “tax return”, “tax returns”, “Form 1065”, “Schedule K-1”, “franchise tax”, “franchise taxes” and “annual reports”. Each returns no page. Both the singular and the plural were run in every case where the two differ.

  46. The two pages returned by a column-scoped search for “Zorro Management” together with “annual report”: https://epstein-data.com/EFTA00076491 p.37 and https://epstein-data.com/EFTA00076892 p.37, the two copies of the 2019 registry filing. The first was read at the image at 400 dpi; the second was not.