Carol Thomas-Jacobs


Named on the documents as	`Carol Thomas-Jacobs`, `CAROL THOMAS-JACOBS, ESQ.`, `Carol Thomas-Jacobs, Esq.`, the unhyphenated `Carol Thomas Jacobs` in Epstein’s counsel’s hand, and — on every sheet of her own deposition transcript — the running header `CAROL T.`¹
⚠ A notation used throughout	`⟦—⟧` inside a quotation marks a point at which THE EXTRACTION ON THIS DESK DOES NOT CARRY A VALUE — most often her own surname. ⛔ It is not a producer’s mark and this page does not claim it is one. Whether the printed sheet carries the value is an IMAGE question and no image is openable here. Nothing is ever supplied from context into a quotation, nothing is said about any mark, its class or its position, and nothing is said about what any withheld value would be²
⛔ The bare surnames are not her	The token `thomas` stands on 67,230 sheets of this release — it is `St. Thomas`, which is ubiquitous in every Virgin Islands document. The token `jacobs` stands on 906 sheets, and of thirty sampled by the desk’s triage outside her own name forms, NONE was her. ⛔ No figure on this page comes from either search, and neither is ever cited here as a figure about her¹
⛔ A title-level trap, not a name trap	`"chief deputy attorney general"` reaches 17 sheets and eight of them are a New Mexico official of another name entirely. Eight carry the given name `Carol` inside Virgin Islands filings. The seventeenth is the news clipping this page does not attribute to anybody¹³
⭐⭐ She held the acting office twice, four years apart	14 March 2019: she signed the letter withdrawing Epstein’s travel-notification accommodation `Carol Thomas-Jacobs,` / `Acting Attorney General`. 10 January 2023: the Government’s First Amended Complaint against JPMorgan Chase is dated and signed `CAROL THOMAS-JACOBS, ESQ.` / `ACTING ATTORNEY GENERAL`. ⛔ Both halves are primary and in her own signature. This page asserts NO continuity between them and states nothing about how or when either began or ended beyond what a document says⁴⁵
⭐ Her own sworn account of 2019	13 July 2023, under oath: `when I was sitting Attorney General, I exercised my discretion in a different manner.` And of her predecessor’s waivers: `Was I surprised? Yes.`⁶⁷
⭐⭐ The $62.5 million settlement, and the quarter of it routed onward	The Leon Black Settlement Agreement and Release, which she executed as `Acting Attorney General of ttie U.S. Virgin Islands`: `Black will pay to the U.S. Virgin Islands $62,500,000 in cash (the "Total Cash Payment").` And: `$15,000,000 of the Total Cash Payment shall be provided by the GVI to a trust fund to be established by the Government of the U.S. Virgin Islands`. ⚠ `ttie` is the extraction’s rendering and is NOT mended here⁸
⛔ The date beside her signature on that agreement is NOT readable	The agreement’s own first sheet prints `is entered into this 20th day of January, 2023`. The signature sheet’s date line reads `Dated: fiteiga-;` — illegible — on a sheet that also renders “Office of” as `OW5e, of` and “the” as `ttie`. ➡ So the agreement’s stated date of entry is documented and the date of her signature is not. Nothing is mended inside the quotation marks⁸
⭐⭐ What cuts hardest against the obvious story	She was already on the JPMorgan complaint dated 26 December 2022, and she moved for admission to the Southern District of New York on 30 December 2022 — both before her predecessor’s removal was reported. In office she filed three amended complaints, two sets of letters rogatory, service motions, a motion to make Mr. Dimon a document custodian, verified the Government’s interrogatory responses under penalty of perjury, and on 15 February 2023 filed a `NOTICE OF FILING LESS REDACTED VERSION` of the complaint. ⛔ This page asserts NO motive, in either direction⁹¹⁰¹¹¹²¹³
⭐⭐⭐ When her service ended IS in the record — and no name form reaches it	1 May 2023. A motion in the JPMorgan docket: `Plaintiff now moves for leave to withdraw ⟦—⟧ appearance in this action because ⟦—⟧ will no longer be with the Department of Justice, Office of the Attorney General, effective May 15. 2023.` ⚠ `May 15. 2023` is the extraction’s rendering and is not mended. ⛔ This document matches NONE of the seven query strings the desk’s triage and gate used. It was found only by removing her name from the question¹⁴¹⁵
⛔ Why she left, and when she joined the bench, are NOT in the record	The motion gives no reason beyond her leaving the Department, and names no destination. A 24–25 July 2023 exhibit index carries the words `Judge and former Acting Attorney General Carol` beside `Transcript excerpts of Deposition of U.S. Virgin Islands`, with the word `Court` printed out of position on the same sheet; a 7 August 2023 index calls her only `former Acting Attorney General`. ⚠ Searched name-blind — `"judge thomas-jacobs"`, `"honorable carol"`, judicial-nomination and swearing-in phrases across the whole release — and NOT FOUND BY THE ROUTES STATED¹⁶¹⁷¹⁵
⭐ Resistance, logged	24 July 2023: `Attached as Exhibit 16 is a true and correct copy of excerpts of the transcript from the July 13, 2023 Deposition of Carol T.` ⟦—⟧ `designated confidential pursuant to the Protective Order in this matter and filed under seal.` ⚠ Measured on that same sheet: three other Government-produced items in the same list carry the identical designation, and a 7 August index lists her excerpts without a sealing mark. ⛔ So nothing on these sheets makes the treatment of her transcript singular, and this page asserts nothing about why it was sealed¹⁸¹⁷
⚠ Not verified at the image	⛔ Every quotation on this page is read from the TEXT LAYER of the extracted corpus and every footnote says so. No page image was opened; this pass did not go to the site server, which is under load. ⚠ A recorded public PDF address exists for 21 of the 30 documents cited here and is NULL for 9 — and a populated address does NOT mean the image is fetchable: one such address has returned HTTP 200 with an `Access Denied` body. Image verification is OUTSTANDING, not impossible²
What the record does not contain	Any document giving a reason for her leaving the Department · any appointment, nomination, confirmation or swearing-in record for any judicial office · any statement by her about either acting appointment in her own words at the time · the transcript of her deposition itself, only excerpts · any document dated between 3 April and 13 July 2023 bearing her name¹⁵
Covered elsewhere on this wiki	Denise George · Epstein’s USVI sex-offender registration · The Epstein estate · JPMorgan Chase · Leon Black · Southern Trust Company · Erika Kellerhals · Cecile de Jongh · Darren Indyke · Richard Kahn · Ghislaine Maxwell · Jeffrey Epstein

Carol Thomas-Jacobs is a Virgin Islands government lawyer. On 14 March 2019 she signed, as Acting Attorney General, the letter telling Jeffrey Epstein that the previous provisions for your travel notifications are no longer accepted by USVIDOJ. She then appears across the territory’s litigation against the Epstein estate as Assistant Attorney General, Chief Deputy Attorney General and Deputy Attorney General. On 10 January 2023 she signed the Government’s First Amended Complaint against JPMorgan Chase as ACTING ATTORNEY GENERAL, and she held that office through at least 3 April 2023. A motion filed on 1 May 2023 records that she will no longer be with the Department of Justice, Office of the Attorney General, effective May 15. 2023. By 24 July 2023 an exhibit index in the bank litigation describes her as a Virgin Islands court judge and former Acting Attorney General.⁴⁵¹¹¹⁴¹⁶

⛔ This page asserts no motive for anything she did, and it does not try to settle why she was appointed. She succeeded an Attorney General who was removed days after suing a bank, and the cheap reading — that she was installed to bury the case — is the exact place a desk invents a finding. The filing record contradicts that reading, and the page says so by setting out what she filed and when. ⛔ It does not supply the opposite reading either. No document in this release states why she was appointed, why she left, or what anybody intended.

⛔⛔ The single most important constraint on reading this page: the newspaper report of the January 2023 acting appointment does not name her. It reads appointed Carol with the surname absent from the extraction, and that document carries zero occurrences of her surname on any of its nine sheets — measured. ➡ This page therefore takes nothing from it, quotes nothing from it, and makes no claim that the person it describes is the subject of this page. ✅ It does not need to: her own dated signature blocks as ACTING ATTORNEY GENERAL are primary, and there are at least three of them. That clipping is cited on Denise George and is left there.³⁵

⚠ And the most consequential thing in this file is the earliest. Four months before Epstein’s federal arrest, the officer who tightened his sex-offender travel regime was her, acting in an office she held for a matter of weeks or months that this release does not bound. She explained why, under oath, four years later. That testimony is reachable only through the transcript header form CAROL T., which no search on her name would find.⁴⁷¹

The name, and the routes — three of which do not reach her at all

The full-name phrase is clean. The surnames are useless. And the single most substantive body of evidence about her sits outside every form of her name. Measured for this page against the full-text index of this release (pages_fts), with invented controls, counts in sheets (rows in pages) and documents (distinct identifiers):

form of the name	query actually run	sheets	documents
`thomas-jacobs`	FTS `'"thomas-jacobs"'`	21	19
`carol thomas-jacobs`	FTS `'"carol thomas-jacobs"'`	17	15
`carol thomas jacobs`	FTS `'"carol thomas jacobs"'`	17	15 — ⚠ identical to the row above, not additive: the tokenizer splits on the hyphen, so these are the same query
`carol thomas`	FTS `'"carol thomas"'`	18	16
`c. thomas-jacobs`	FTS `'"c. thomas-jacobs"'`	0	0
`jacobs, carol`	FTS `'"jacobs carol"'`	2	2 — ⚠ and neither is a surname-first rendering; both are artefacts of a doubled signature block
⭐ `carol t`	FTS `'"carol t"'`	32	8
bare `thomas`	FTS `'thomas'`	67,230	—
bare `jacobs`	FTS `'jacobs'`	906	—
invented controls `zzqcarol`, `zzqthomasjacob`	FTS prefix	0	0

➡ 21 sheets across 19 documents carry her surname, and the desk’s triage read all 21 and attributed all 21 to her. That classification is inherited on this page and was not re-derived sheet by sheet; the sheets this page actually quotes were each located by string and read.¹

⭐ "carol t" is the only route to her sworn testimony, and it was not in the desk’s own list. Of its 32 sheets, 29 stand in five documents that are all hers; the other three are an unrelated vehicle record and two mail headers. The running header on every sheet of her deposition transcript prints CAROL T. and the surname is absent from the extraction. ➡ A page built from the eight name forms the desk enumerated would have contained no testimony of hers at all.¹

The role-phrase route, and why no absence claim here comes from a name-scoped set

⛔ Every absence statement on this page was re-run with her name removed from the query, because on this subject a name-scoped set is demonstrably blind. The reason is measurable: "acting attorney general" reaches 120 sheets of which the desk’s triage attributed 74 — 61.7% — to her, and most of the Government’s filings in the JPMorgan docket carry an acting-Attorney-General signature block in which the extraction prints CAROL and not the surname.¹

⭐⭐ And the re-run paid for itself. The document that records the end of her service at the Department — the Government’s own motion to withdraw her as counsel of record — matches none of the seven query strings the desk used: not "thomas-jacobs", not "carol t", not "acting attorney general", not "assistant attorney general", not "deputy attorney general", not "chief deputy attorney general", not "acting ag". Measured: 0 hits on each. It carries the token carol on two sheets and no surname anywhere. It was reached only by asking, without her name, who signed the Government’s filings in that docket after April 2023. ➡ That is the fourth time on this subject that the material which mattered sat outside the forms the desk thought to enumerate, and it is the reason this page states its negative findings as not found by the routes stated rather than as absences.¹⁴¹⁵

⚠ The desk’s union floor of 132 sheets across 91 documents is inherited here and is called a floor. It was not re-derived for this page, and this pass found at least two documents outside it, including the withdrawal motion above. A further sheet of the FBI’s record of her predecessor’s complaint refers to her office as the outgoing acting AG with no name at all — which is precisely the shape of sheet no enumerated query family can reach.¹¹⁹¹⁵

Block S, measured on her own sheets

The denominator is the 21 sheets that carry her surname, measured for this page over the whitespace-normalised text of each sheet. It is not a document count and not a doc_type subset.

term	hits / 21	%
`attorney general`	21	100.0%
`complainant`	0	0.0%
`victim*`	4	19.0%
`underage*`	2	9.5%
`traffick*`	2	9.5%
`csam`	2	9.5%
`jane doe`	2	9.5%
`minor*`	0	0.0%
`massage*`	0	0.0%
invented control `zzqcarol*`	0	0.0% ✅

➡ Every one of the 21 sheets carries the words attorney general. None carries complainant. She appears in this release only as a government lawyer and an officeholder. ⚠ A government lawyer appears beside claimant material because that is the job, and the four sheets carrying victim vocabulary are a 2020 press report of what she wrote in court papers, two statutory prayers-for-relief reciting the CICO Act’s purpose, and one agreed motion on which she was counsel of record. ⛔ No survivor is named, described, counted, quoted or characterised anywhere on this page, and the subject matter of that agreed motion is not reproduced, paraphrased or characterised here.²⁰²¹

14 March 2019: the letter, in her own signature

Tier: documented fact, from the letter itself. Over the letterhead of the Virgin Islands Department of Justice, Office of the Attorney General, dated March 14, 2019 and addressed to Epstein:

The United States Virgin Islands Department of Justice (“USVIDOJ”) understands that your business activities require you to make frequent trips outside of the Territory to the United States destinations and international destinations. While provisions were granted in the past, upon our careful review and consideration these are the conditions to which you must now comply:

The four conditions, as the sheet prints them:

Notification of any travel outside of the U.S. Virgin Islands must be provided in person at USVIDOJ when you are in the Territory;

Notification by email can only serve as notification if you are already outside the jurisdiction and planning on traveling to another destination or to notify of a change in the length of your travels while you are outside the Territory;

You are required to appear in person at USVIDOJ at least twenty one calendar days prior to any intended travel outside of the United States; and

If a reduction in the 21 day notification is requested, you must submit information in support of the request for approval at the discretion of USVIDOJ.

and the authority relied on: These requirements are pursuant to Chapter 86, Section 1724 (b) of the Virgin Islands Code and H.R.515 - International Megan's Law. The second sheet closes:

Mr. Epstein, please understand that the previous provisions for your travel notifications are no longer accepted by USVIDOJ and you must comply immediately with the conditions noted above. We thank you for you cooperation and trust that you will adhere to these conditions.

Sincerely,

Carol Thomas-Jacobs,

Acting Attorney General

⛔ The first of those sheets carries a street line for the addressee and a letterhead with telephone and fax fields. None is reproduced, described or located here. ⚠ Five further copies of this letter stand in this release. This page cites one, sets no copy beside another, characterises no difference between any two, and builds nothing on the fact that others exist.⁴²²

Three documents give that one letter three different titles, and this page reconciles none of them

what the sheet says	the sheet
`Carol Thomas-Jacobs,` / `Acting Attorney General` — her own signature, 14 March 2019	the letter⁴
`then Acting Assistant Attorney General Carol Thomas Jacobs` — Epstein’s counsel, 30 April 2019	counsel’s letter to the incoming Attorney General²³
`former Acting Attorney General Carol` ⟦—⟧ — the Attorney General Nominee, 2 June 2019	the reply refusing the waiver²⁴

➡ Tier: documented fact as to what each sheet says, and nothing more. ⛔ The page does not decide which title was correct, does not reconcile Acting Attorney General against Acting Assistant Attorney General, and does not infer any date of appointment or departure from the word former. ⚠ The 30 April letter is one of several copies in this release and the one cited here spells her surname unhyphenated. This page cites that one copy, compares none, and says nothing about what any other copy carries.²³²²

March to June 2019: Epstein’s lawyers wrote back, and a draft comment survived

Tier: documented fact, from the file of Epstein’s own Virgin Islands counsel, produced in the bank litigation. The letter opens Dear Attorney General Thomas-Jacobs: and continues:

We represent Mr. Jeffrey Epstein, who is registered on the U.S. Virgin Islands sex offender registry. We have received a copy of your March 14, 2019 letter regarding substantial additional requirements that you now seek to impose on Mr. Epstein in connection with his future travel notifications to your office, and I have several questions regarding those requirements that I would like to discuss with you in person.

➡ Documented fact: Epstein’s Virgin Islands counsel addressed her as Attorney General and objected to her letter in writing. The letter then sets out, from counsel’s side, the sequence that preceded it:

In accordance with the procedures authorized by Attorney General Frazer in August 2012, Mr. Epstein gave proper email notice on February 16, 2019 to Ms. Shani Pinney, the Territorial Sexual Offender Registry Program Manager, of his intended to travel for a day trip to the Dominican Republic on February 19, 2019.

and:

Despite Mr. Epstein’s timely and proper notice to the Department of Justice of his travel to the Dominican Republic, the Dominican Republic did not receive advance notice of Mr. Epstein’s travel. As result, upon Mr. Epstein’s arrival at the Dominican Republic on February 19, 2019, he was detained for several hours and ultimately denied entry.

⚠ Tier: credible allegation, and it is an advocate’s account offered to persuade her. It is not a finding that notice was given or that the Department failed to pass it on. It is the account the opposing side chose to put in writing to her, three weeks before she acted.²⁵

⭐ And the copy in this release is a draft. Standing on the same sheet is an editorial comment, which the extraction renders:

Committed lell: Do we have proof of prior notifications S email that were received by Pinney? It might be helpful to show al that we had successfully notified her previously S email.

⚠ Committed lell, S email and al are the extraction’s renderings and are NOT mended here; the commenter is not identified on this sheet and this page supplies no identification. ➡ Layer four, read plainly: at the moment of drafting, Epstein’s own lawyers were asking one another whether they could prove the prior notices they were about to assert. ⛔ The page states that and stops. It does not conclude that the proof did not exist. ⚠ Several versions of this letter stand in this release; this page cites one, compares none, and builds nothing on the existence of the others.²⁵²²

The FBI’s account of the same act uses a different verb, and a different trigger

⚠ Tier: credible allegation recorded by a federal agent — the account of a named person with direct knowledge, not an established fact. An FD-302 recording her predecessor’s complaint of 2 October 2023 states:

A previous AG, Vincent Franklin Frazer (FRAZER) granted EPSTEIN the waiver but it was later rescinded by acting AG Carol Thomas-Jacobs (JACOBS) after EPSTEIN was detained in the Dominican Republic.

⚠ That document carries the Bureau’s standard legend: This document contains neither recommendations nor conclusions of the FBI.

➡ Read against her own letter and her own testimony, the three records do not agree, and this page does not reconcile them. The 302 says the waiver was rescinded and places the trigger in a detention. Her letter says the previous provisions for your travel notifications are no longer accepted and gives the reason as our careful review and consideration. Her sworn testimony says she modified the waiver, and gives the reason as a file review in which I did not see anything in the file to support the waiver. ⛔ Each is reported here as what its own document says. Nothing is harmonised and nothing is chosen. ⚠ This page is consistent with Denise George, which records that the revocation of the waiver was not hers.¹⁹⁴⁷

2020 to 2022: three more titles, and a motion that was struck

Tier: documented fact, from her own filings and from the court’s own orders.

date on the sheet	the title as the sheet carries it
press papers reported 4 March 2020	`Assistant AG Carol Thomas-Jacobs`²⁶
22 September 2020	`CAROL` ⟦—⟧ `ESQ.` / `Chief Deputy Attorney General`²⁷
10 February 2021	`/s/ Carol Thomas-Jacobs` / `CAROL THOMAS-JACOBS, ESQ.` / `Assistant Attorney General`²⁸
17 March 2021	`/s/ Carol` ⟦—⟧ / `CAROL` ⟦—⟧ `, ESQUIRE` / `Chief Deputy Attorney General`²⁹
February 2022, as a court order’s addressee	`Chief Deputy Attorney General, Carol` ⟦—⟧ `Esq.`³⁰
1 December 2022, in her own department’s press release	`Deputy Attorney General Carol` ⟦—⟧³¹

➡ Tier: documented fact as to which sheet gives which title. ⛔ The reconciliation is NOT a finding. A signature reading Assistant Attorney General in February 2021 stands five weeks before one reading Chief Deputy Attorney General in March 2021, and this page does not explain that and does not pick one.

In 2020 her written position on the compensation of Epstein’s victims reached the press through her own court papers. A Southern District of New York press digest headed SDNY News Clips, Thursday, March 5, 2020 reproduces an article of the previous day:

“The Attorney General intends to permit the release of Estate assets to allow for just compensation of victims of Mr. Epstein through the administration of the Fund assuming that certain enhancements to the claims program are implemented,” Assistant AG Carol Thomas-Jacobs wrote in papers filed Tuesday in Virgin Islands Superior Court.

⛔ Nothing else from that article is reproduced, paraphrased, counted or characterised here. The sentence above is quoted because it is her own written position, attributed, and names nobody else.²⁶

4 February 2021: she moved to freeze the Estate’s assets, and the court struck the motion

⭐ Tier: documented fact, from the court’s own order. The order recites:

Emergency Motion to Immediately Freeze All Estate Assets and Cash on Hand filed by the Government of the United States Virgin Islands, by and through Carol ⟦—⟧ Esq., Chief Deputy Attorney General, on February 4, 2021

and disposes of it:

For these reasons, the Court will use its inherent authority to strike the Emergency Motion and all responses thereto from the record.

She then appealed, over her own signature, and framed the question herself. Her Notice of Appeal and Petition for Review, Dated: March 17, 2021, puts the issue as:

Whether the Magistrate Judge properly denied the Government’s Emergency Motion to Freeze All Estate Assets and Cash on Hand based on lack of standing because the Government is not a party to and was denied intervention in the Probate action, even though it has a claim against the Estate.

The appeal failed. An order of February 2022 affirms the magistrate orders and directs that Petitioner's Appeal is DISMISSED WITH PREJUDICE, and directs a copy to Chief Deputy Attorney General, Carol ⟦—⟧ Esq. ⚠ That order’s own date line reads DATED: February P9 , 2022 and the day is not readable; it is not mended and no day is supplied.

➡ Documented fact: in her own name she sought the most aggressive available remedy against the Estate, and lost it twice on standing. ⛔ The order recites joinders by other claimants and their counsel. None of that is reproduced here and no claimant is named, counted or described.²⁹³⁰

26 December 2022 to 10 January 2023: she was on the case before the office changed hands

⭐⭐ Tier: documented fact, from the docket. The Government’s original complaint against JPMorgan Chase carries Dated: December 26, 2022, was filed on 27 December 2022, and her name stands in its signature block under the title Assistant Attorney General, with the notation Pro Hac Vice to be submitted.⁹

Four days later she moved for admission to the Southern District of New York in her own name:

Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts ofNew York. I, Carol ⟦—⟧ hereby move this Court for an Order for admission to practice Pro I lac Vice to appear as counsel for Plaintiff, the Government of the United States Virgin Islands. in the above-captioned action.

I am in good standing of the bars of the state of New York and the United States Virgin Islands and there are no pending disciplinary proceedings against me in any state or federal court.

Dated: December 30, 2022, over the title Assistant Attorney General. ⚠ ofNew and Pro I lac Vice are the extraction’s renderings and are NOT mended. The signature line on that sheet is damaged in the extraction and is not quoted, reconstructed or described. ⛔ A bar-register number, a street line, a telephone field with an extension and a mail field stand on that sheet and NONE is reproduced, described or located here.¹⁰

The court granted it on 6 January 2023 — a date that reaches this release only through the Government’s own later motion to withdraw her: On January 6, 2023, the Court entered an Order [Docket #13] granting admission pro hac vice to Carol ⟦—⟧ as counsel for Plaintiff in the above-captioned litigation.¹⁴

➡ Documented fact, and it is the fact that most complicates the obvious story: she was counsel on the bank complaint before the office changed hands, and she sought her own federal admission before the removal of her predecessor was reported. ⛔ This page draws no inference from that about why she was appointed. It states the sequence.⁹¹⁰³

10 January to 3 April 2023: what she actually did in the office

Tier: documented fact, from dated filings over her name as ACTING ATTORNEY GENERAL. The First Amended Complaint is Dated: January 10, 2023 and signed CAROL THOMAS-JACOBS, ESQ. / ACTING ATTORNEY GENERAL — the name as that signature block gives it, the acting title and a printed date, all three on one sheet.⁵

What follows, in the docket, over the same title:¹¹

20 and 26 January 2023 — motions for Letters of Request (Letters Rogatory).
13 February 2023 — a brief resisting the scope of a discovery demand, and her own sworn verification (below).
15 February 2023 — the NOTICE OF FILING LESS REDACTED VERSION (below).
17 February and 3 March 2023 — motions for alternative service of subpoenas on named third parties.
23 February 2023 — a motion that the court order JPMorgan to designate Mr. Dimon as a document custodian and provide documents for the relevant time period through and including 2019.
2 March 2023 — an agreed amendment to the protective order.
23 March 2023 — a motion to withdraw another lawyer from the Government’s team.
27 March 2023 — an agreed motion in a related matter on which she was counsel of record. ⛔ Nothing of that motion’s subject, parties or content is reproduced, paraphrased or characterised anywhere on this page.
3 April 2023 — the last filing in this set over her name as Acting Attorney General: Dated: April 3, 2023 / CAROL THOMAS-JACOBS, ESQ. / ACTING ATTORNEY GENERAL.

13 February 2023: she verified the Government’s answers herself, under penalty of perjury

⭐⭐ Tier: documented fact, and it is sworn.

VERIFICATION

I. (‘arol ⟦—⟧ declare:

I am the Acting Attorney General for the United States Virgin Islands Department of Justice. I am authorized to make this verification on behalf of Plaintiff Government of the United States Virgin Islands (“Government”).

She qualified it in the same breath:

Because the matters stated in the document identified above constitute a collective response, they arc not all necessarily within my personal knowledge, or within the personal knowledge of any single individual.

and closed:

I declare under penalty of perjury that the foregoing is true and correct.

Executed at St. ⟦—⟧ United States Virgin Islands on this 13th day of February, 2023.

⚠ ('arol and arc are the extraction’s renderings and are NOT mended.¹²

15 February 2023: under her name the Government put more on the record, not less

⭐⭐ Tier: documented fact. The caption reads GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' NOTICE OF FILING LESS REDACTED VERSION OF ITS FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL, and the body:

PLEASE TAKE NOTICE that Plaintiff, Government of the United States Virgin Islands, (“Government”) hereby files a less redacted version of its First Amended Complaint and Demand for a Jury Trial (attached as Exhibit A). This version of the Complaint is identical to the First Amended Complaint filed on January 10, 2023 except that the Government has removed certain redactions from the previously-filed version.

Dated: February 15, 2023, over CAROL ⟦—⟧ ESQ. / ACTING ATTORNEY GENERAL. ⛔ This page says nothing whatever about what any withheld value in either version was, where any is printed, or what class of value either version concerned. It reports only what the notice says of itself.

➡ Five weeks into the acting tenure, the Government under her name moved in the direction of disclosure. ⛔ No motive is asserted. The point is recorded because the opposite is what an “installed to bury it” reading would predict.¹³

20 January 2023: the Leon Black settlement

⭐⭐ Tier: documented fact, from the agreement itself — five rows in pages, filed in this release under the recorded type court.plea_agreement, which it is not. It opens:

This Settlement Agreement and Release (“Agreement”) is entered into this 20th day of January, 2023, between the Government of the United States Virgin Islands (“the U.S. Virgin Islands” or “GVI”) and Leon Black (“Black”).

Its recitals state the premise:

WHEREAS, according to public reports, Black paid $158 million over approximately live years to Jeffrey Epstein’s Virgin Islands company, Southern Trust, for what Black contends was for services rendered and value received.

WHEREAS, Jeffrey Epstein used the money Black paid him to partially fund his operations in the Virgin Islands.

⚠ live is the extraction’s rendering of what reads as five and is NOT mended.

The money, and both figures matter:

In consideration for the agreement and for the full and complete mutual Release, inclusive of all attorneys’ fees and costs, as further specified herein, Black will pay to the U.S. Virgin Islands $62,500,000 in cash (the “Total Cash Payment”).

$15,000,000 of the Total Cash Payment shall be provided by the GVI to a trust fund to be established by the Government of the U.S. Virgin Islands to fund projects, services, counseling programs and activities, or mental health services and facilities for Virgin Islands residents or inhabitants.

➡ Documented fact: slightly under a quarter of the headline figure is routed onward by the Government into a trust fund, and the agreement names the beneficiaries of that fund as Virgin Islands residents or inhabitants. ⛔ A page that printed only $62,500,000 would give a reader less than the document does.

What the release does and does not cover. The Government released Black and his agents and entities from

any and all claims and rights of any nature whatsoever which the United States Virgin Islands now has or in the future may have against them related to Jeffrey Epstein, whether known or unknown, suspected or unsuspected, for any act, omission, or event occurring up to and including the date this agreement is executed. For avoidance of doubt, this release does not apply to JP Morgan Chase or any other financial

— the sentence continuing onto the next sheet —

institution used by Black or Jeffrey Epstein or any current or former employees of JP Morgan Chase or other financial institution. Nor does it apply to Jeffrey Epstein or his estate.

⚠ That sentence runs across two sheets and both are pinned in the footnote; nothing is bridged except the line break. ➡ Documented fact: the bank claim and the Estate claim were expressly preserved. The agreement also records that nothing contained herein may be taken as or construed to he an admission by Black of any liability, and, in the Government’s favour:

‘Ibis Agreement shall not limit the rights of any private party to pursue any remedies allowed by law and does not satisfy or release any claims or remedies of any private party not otherwise identified in any other Settlement Agreement. Black will not assert in any other action that his monetary payments to the U.S. Virgin Islands resolve, satisfy, or release the claims of any individual.

⚠ he and 'Ibis are the extraction’s renderings and are NOT mended.

The clause about documents, and a question this page does not answer

⭐ Tier: documented fact as to the clause; question as to why it is there.

The Virgin Islands will disclose documents related to this matter to non-parties only as permitted or required by the laws of the Virgin Islands or any Court order. The Parties will provide 14-days’ notice of any request for documents.

➡ The agreement does not say why a disclosure constraint and a notice period were needed, and neither does this page. ⚠ Set beside it, without a conclusion drawn, is what the Government’s own press release had said seven weeks earlier about the Estate settlement: that the Estate has also agreed to wind down its business operations in the U.S. Virgin Islands and to provide documents to assist the Government's ongoing investigations. ⛔ Those are two different agreements with two different counterparties and this page does not treat one as a measure of the other.⁸³¹

A difference in the two trust-fund clauses, stated and left as a question

⚠ Tier: documented fact as to the words; question as to everything else. The Government’s own press release of 1 December 2022 described the Estate settlement’s trust as follows:

The settlement terms require that the Government dedicate the proceeds from the sale of Little St. James exclusively to a trust created by the Government of the U.S. Virgin Islands to fund projects, services, counseling programs, organizations and activities that help Virgin Islands residents or inhabitants who are victims of sexual assault, human trafficking, sexual misconduct, and child sexual abuse.

The Black agreement’s own text, seven weeks later, uses closely parallel language and stops earlier: to fund projects, services, counseling programs and activities, or mental health services and facilities for Virgin Islands residents or inhabitants. ➡ The qualifying clause is not there.

⛔⛔ What this page does and does not say about that. It is a documented fact that the two passages differ in those words. ⚠ They are not comparable instruments: one is a department’s press description of a settlement, the other is a settlement’s own operative text, and no copy of either is being set against another copy of itself. ⛔ This page does not assert that the beneficiaries were narrowed or broadened, does not assert that anybody intended the difference, and does not assert what either fund in fact did. The question — why does the second clause stop where the first one continues? — is left open.⁸³¹

Her signature, and the date that is not readable

Tier: documented fact, with a flagged limit. The execution sheet reads:

IN WITNESS WHEREOF, the Parties hereto, through their fully authorized representative, have executed this Agreement as of the date first written below.

Dated: fiteiga-;

Government of the U.S. Virgin Islands Department of Justice OW5e, of the Attorney General

Carol Thomas-Jacobs, Esq. Acting Attorney General of ttie U.S. Virgin Islands

⚠⚠ fiteiga-;, OW5e, of and ttie are the extraction’s renderings and are NOT mended here under any circumstances. The following sheet carries a second date line which the extraction renders Dated: 11AD /A 3, equally unreadable.

➡ ⛔ So this page does NOT say the agreement was executed on 20 January 2023. What it says is what the document says: the agreement states it is entered into this 20th day of January, 2023, that date is printed on its own first sheet and is established; the dates beside both signature blocks are illegible in this extraction and no date of signature is established. ⚠ The witness clause itself refers to the date first written below, and what stands below is not readable.⁸

21 February 2023: the Government withdrew from Maxwell’s suit against the Estate

Tier: documented fact, and both ends of it are in her own filings. On 22 September 2020 she signed, as Chief Deputy Attorney General, the Government’s REPLY BRIEF IN SUPPORT OF MOTION TO INTERVENE in Ghislaine Maxwell v. Estate of Jeffrey E. Epstein in the Superior Court of the Virgin Islands — a brief pressing that the Government be allowed in as of right or by permission.²⁷

Twenty-nine months later, over her name as Acting Attorney General:

The Government of the United States Virgin Islands (“Government”), by and through its undersigned counsel, hereby withdraws it Motion to Intervene, which was filed in the abovecaptioned action on July 10, 2020, in light of the Government’s recent settlement of its separatelyfiled action against Defendant the Estate of Jeffrey E. Epstein.

Dated: February 21, 2023, under CAROL ⟦—⟧ ESQUIRE / ACTING ATTORNEY GENERAL / VIRGIN ISLANDS DEPARTMENT OF JUSTICE. ⚠ withdraws it, abovecaptioned and separatelyfiled are the extraction’s renderings and are NOT mended. ⚠ The signature line itself is another lawyer’s, under the title Assistant Attorney General; the Acting Attorney General’s name heads the block. ⛔ This sheet carries an appended [═══ TRANSCRIPT ═══] block; the quotation above is taken from ABOVE that line and nothing below it is quoted, counted or treated as evidence of anything.

➡ Question, not finding: what did the Government give up on 21 February 2023, and who decided? The sheet gives one reason — the separate settlement with the Estate — and says nothing else. ⛔ No document in this release connects that withdrawal to the Black agreement, to the bank action, or to anybody’s intention, and this page does not.³²

1 May 2023: the end of her service, in the Government’s own filing

⭐⭐⭐ Tier: documented fact — and this is the finding the desk’s own brief said the record did not contain. The Government’s motion, Case 1:22-cv-10904-JSR Document 128 Filed 05/01/23:

GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS’ MOTION FOR LEAVE TO WITHDRAW CAROL ⟦—⟧ AS COUNSEL OF RECORD

On January 6, 2023, the Court entered an Order [Docket #13] granting admission pro hac vice to Carol ⟦—⟧ as counsel for Plaintiff in the above-captioned litigation.

Plaintiff now moves for leave to withdraw ⟦—⟧ appearance in this action because ⟦—⟧ will no longer be with the Department of Justice, Office of the Attorney General, effective May 15. 2023.

Withdrawal is sought with notice to and consent from Plaintiff. Plaintiff remains represented in this action by legal counsel from the Office of the Attorney General and Motley Rice LLC, including but not limited to undersigned counsel.

Dated: May 1, 2023, over ARIEL ⟦—⟧ ESQ. / ATTORNEY GENERAL NOMINEE. ⚠ May 15. 2023 is the extraction’s rendering and is NOT mended. ⛔ The extraction does not carry the subject’s surname at any point on these sheets, and it does not carry the signatory’s surname either. This page supplies neither, says nothing about any mark, and names no successor.

How this page identifies the subject of that motion, stated so it can be checked. The motion is titled to withdraw CAROL ⟦—⟧ as counsel of record for the Government in 1:22-cv-10904-JSR, and its first paragraph ties that person to a pro hac vice admission in that same docket. Sheets in the same docket print, in full, Carol Thomas-Jacobs (pro hac vice) / Acting Attorney General of the United States Virgin Islands — on the Government’s filings of 3 April 2023 and 27 March 2023. ➡ The identification rests on those full-name sheets in the same action, not on anything supplied into the quotation above.¹¹²¹

⭐ And the office changed hands in the same four weeks, measured name-blind. The Government’s filings in that docket are signed ACTING ATTORNEY GENERAL over her full name as late as 3 April 2023; from 1 May 2023 they are signed ATTORNEY GENERAL NOMINEE over a different given name, and from 14 July 2023 ATTORNEY GENERAL over that same given name. ➡ Documented fact: her acting tenure in this docket ends between 3 April and 1 May 2023, and her service at the Department ends on the date the motion states. ⛔ The motion gives no reason beyond her leaving the Department, names no destination, and this page supplies neither.¹¹¹⁴

⚠ A year later the office was still being held in an acting capacity by somebody else. A filing Dated: May 13, 2024 reads Respectfully submitted, / IAN S.A. CLEMENT, ESQ. / ACTING ATTORNEY GENERAL.³³

13 July 2023: her own sworn testimony

⭐⭐ Tier: documented fact as to the testimony — this is her, under oath, in a video-recorded deposition in the bank action. The transcript’s title page reads VIDEO RECORDED DEPOSITION OF / CAROL ⟦—⟧ / THURSDAY, JULY 13, 2023, and every sheet’s running header prints CAROL T.

⚠⚠ A DISCLOSURE THAT GOVERNS EVERY PASSAGE BELOW, AND IT IS ALSO A CORRECTION TO THE DESK’S OWN TRIAGE. The transcript prints a line number at the head of every line, and on these sheets the text layer does not preserve reading order: speaker prefixes are separated from the words they label, and words that overflowed the right margin of the printed page are relocated several lines further down. ⛔ So the desk’s triage quoted several of these answers as continuous sentences when they are not continuous in the extraction. Every quotation below has been re-cut to a run that is contiguous in the extraction once the line numbers are lifted out, that lift is the only alteration, and where the extraction breaks a sentence THIS PAGE SAYS SO AND DOES NOT SPLICE IT.⁷

On what she did in 2019, and why:

A. I reviewed the file and I consulted with Shani regarding course of action.

Q. Okay. And what did you decide to do?

A. I decide to modify his — the waiver that was in there — that he had before.

A. — had granted Mr. Epstein a waiver of certain requirements, which — and so I — after I reviewed, I decided to modify that waiver.

Asked Q. And why did you decide to modify the waiver?, the answer begins at the foot of one sheet and finishes at the head of the next, and the extraction prints its opening words out of order. ⛔ This page therefore quotes only the part that is contiguous, from the second sheet:

— I did not see anything in the file to support the waiver.

On whether the statute allowed what she did, the extraction gives the answer with its clauses out of sequence, and it is reproduced here in the order the sheet prints them rather than mended:

THE WITNESS: Well, I think the statutes allows their Attorney General the discretion to make modifications — and so — to the basic requirements. wanted to stick closer to the basic requirements of the statute. And I felt that I

⚠⚠ That is exactly what the extraction carries, in the order it carries it. The words And I felt that I belong before wanted to stick closer, and THIS PAGE DOES NOT MOVE THEM. The exchange that follows is printed with counsel’s question inside her answer, and is likewise given as it stands:

A. Again, because to protect our

And why was that? community.

On her predecessor’s waivers:

Q. Uh-huh. Were you surprised when you saw the waivers that had been granted to Mr. Epstein previously?

THE WITNESS: Was I surprised? Yes.

and, asked to explain, in the only contiguous part of the answer:

that at least for me, the better course would have been to have him comply as strictly as possible to the statute.

⚠ The opening words of that answer are printed lower on the same sheet, out of position. They are not reproduced, reconstructed or spliced here.⁷

On Epstein’s conduct, by the officer then responsible for it:

THE WITNESS: I think Epstein, Mr. Epstein was evasive

A. — and clever in avoiding the verifications, if nothing else.

and, asked Q. And do you think that evasiveness should have triggered some follow-up by the Virgin Islands Department of Justice, which after all was charged with protecting the community?:

THE WITNESS: Again, I — you know, I don’t — they may have been. And if they wasn’t, they should have been.

⚠ they wasn't is the extraction’s rendering and is not mended.⁷

The answers that cut the other way

⚠ Tier: documented fact as to the testimony, and they are the answers a page sympathetic to her would leave out. Asked whether the Virgin Islands had done an adequate job on Epstein’s compliance checks, she first deflected the question to a subordinate’s remit:

A. I don’t have all the facts before me.

and, in the only other contiguous part of that answer:

best person would be the person who is responsible for the sex offender registration.

⚠ The remainder of the answer is printed out of sequence on that sheet and is not reproduced or reconstructed.

Counsel then put a document to her. ⛔ Nothing from that document is reproduced, paraphrased, counted or characterised anywhere on this page. Her answers were:

THE WITNESS:

They should have.

A. I don’t recall this.

Q. Do you know if any follow-up happened?

A. I don’t know.

⚠ On that sheet the words They should have. are printed four lines below the speaker prefix they belong to, and the prefix stands alone. Both are given exactly as they stand and nothing is joined.⁷

On whether the territory watched the public record before 2019:

And do you know if the Attorney General’s Office in the Virgin Islands did anything at anytime prior to 2019 to try to see what kind of allegations were being made in publicly filed lawsuits regarding Jeffrey Epstein?

THE WITNESS: I’m not aware of any.

The Virgin islands can only respond to what they know.

I was not aware, and I don’t know if anyone was aware in 2017.

⚠ islands lower-cased is the extraction’s rendering and is not mended. A connecting clause stands between those last two fragments, printed out of position on the same sheet, and this page does not splice them into one sentence. Asked the same question a third way, she answered:

THE WITNESS: The Virgin Islands can only take action on what they know.

And, asked directly whether law enforcement must watch other courts’ dockets — a question that runs across the join between two sheets, both of which are pinned:

In your opinion, do you believe law enforcement has an

obligation to monitor public dockets of every court in the country for allegations that may reference the Virgin Islands?

Her answer is printed by the extraction in scattered fragments. The only contiguous run of it reads:

unreasonable obligation on the Virgin Islands.

⚠⚠ The words I don't., I think it's and It would be an stand lower on the same sheet, out of position. ⛔ This page does NOT splice them into a sentence, and the desk’s triage quoted them as one. ➡ Question, and this page leaves it as one: the Government she led in 2023 sued a bank over what it should have known and acted on, while her sworn position was that such monitoring would be an unreasonable obligation on the Virgin Islands. ⛔ The documents do not reconcile those two postures, and neither does this page.⁷⁶

On the statute, on her predecessor, and on Cecile de Jongh

The statutory basis, in her words:

A. It gives the Attorney General the discretion to modify the notification requirements.

Asked whether her predecessor had done anything inconsistent with it:

A. Attorney Generals are free to exercise their discretion however they see fit.

discretion one way, and I — when I was sitting Attorney General, I exercised my discretion in a different manner.

⚠ The clause And he exercised his stands below those words on the sheet, out of position, and is not spliced in. ⭐ That is the 2019 acting tenure in her own sworn words.⁶

She was also shown an e-mail exchange and asked about Cecile de Jongh. Counsel described the exhibit as an e-mail

exchange between Jeffrey Epstein and somebody named Cecile de Jongh on March 17th of 2019, which is three

days after the letter that we’ve been looking at.

⚠ The clause And this is the E-mail stands between those two fragments in the extraction and the page does not splice them. The exchange that followed:

Do you know Cecile de Jongh? A. I know of Cecile de Jongh. I don’t personally know Cecile de Jongh.

A. I know she was — she’s the —

she’s Governor De Jongh’s wife. Q. Okay. And were you aware that Ms. De Jongh worked for Mr. Epstein? A. I think everyone in the Virgin Islands knew that.

Asked finally whether she had ever interacted with her about Epstein, the answer on the sheet is the single word No. ⚠ It is printed at the foot of the sheet together with displaced fragments of the question, and this page does not reassemble the question around it.

➡ Documented fact as to the testimony. I think everyone in the Virgin Islands knew that is her characterisation and is attributed to her.³⁴

And she confirmed she had been copied on the 2019 waiver correspondence:

Q. And this is the E-mail chain that counsel showed you involving Clive Rivers and Denise ⟦—⟧ you were copied on several of these E-mails; is that correct? A. Yes.

Counsel identified that e-mail on the next sheet — And there is an E-mail that AG ⟦—⟧ sent to Attorney Kellerhals and Attorney Rivers on June 2nd, 2019. — and read a sentence from it into the record: says, "While my predecessors have apparently had differing interpretations of Title 14, Section 1724B (4) of the Virgin Islands code." ⛔ The extraction does not carry the sending officeholder’s surname at that point and this page does not supply it. That correspondence is set out on Denise George and is not reproduced here.⁶²⁴

A colleague’s testimony five days later

⚠ Tier: a witness’s inference under oath, not a documented fact about the office. The Department’s sex-offender registry manager, deposed on 18 July 2023 and reading an internal distribution list, named two other departmental employees —

Anola Duncan was the AG’s secretary. Quincy McRae was the criminal — the chief over the criminal division.

— and then, in the part of the answer the extraction prints in reading order:

So Carol must have been the acting AG, and Kevin Augustin was the — Kevin Augustin was the investigator for SORNA.

⚠ The words immediately before that, in which the witness reads the subject’s given name off the list and observes that she does not see the Attorney General’s name on it, are printed out of sequence in the extraction and are NOT quoted or reconstructed here. Asked

Q. Do you know what, if any, follow-up they did in response to you passing this information along?

the answer, in its contiguous part, was:

anything was done, followed up. I’m not sure if anything was done. It — I wasn’t aware of it.

⛔ Nothing about the content of that internal distribution is reproduced, paraphrased, counted or characterised here. ⚠ So Carol must have been the acting AG is the witness’s inference from a list in front of her. This page records it as that and builds nothing on it.³⁵

Two governors, from a deposition schedule — and the attribution is an inference

⚠ Tier: inference from a parallel list, flagged as one. A deposition-topic schedule in the bank action sets six Virgin Islands Department of Justice entries against six topic lines. The last of the six topics reads:

Interactions with Epstein or his counsel in individual capacity and as Deputy Attorney General and Acting Attorney General for USVI under Governors Kenneth Mapp and Albert

➡ The line ends there, at the foot of the sheet, and this page supplies nothing after Albert. ⚠ The text layer prints that sheet’s two columns one after the other rather than in register, so the pairing of names to topics is positional, not adjacent. The pairing is corroborated by the titles: the line immediately before it names an Attorney General under Governor Albert Bryan., and the one before that an Attorney General under John de Jongh. beside the name Vincent Frazer. It is the only line in the group whose titles match her and no other person named there. ⛔ It is still an inference, it is labelled one, and no claim about any period of service before 2019 rests on anything else. ⚠ A second copy of this schedule stands in the release; this page cites one and compares none.³⁶²²

24 July to 7 August 2023: sealed, and described as a judge

Tier: documented fact as to what each index says. A declaration filed on 24 July 2023 lists:

Attached as Exhibit 16 is a true and correct copy of excerpts of the transcript from the July 13, 2023 Deposition of Carol T. ⟦—⟧ designated confidential pursuant to the Protective Order in this matter and filed under seal.

⚠ Measured on that same sheet: three other items in the same list — all documents produced by the Government of the Virgin Islands — carry the identical designated confidential ... and filed under seal formula, and one item produced by the bank carries no such formula. ➡ So the designation on her transcript is not singular within the declaration that applies it, and this page asserts nothing about why it was applied. ⛔ The declaration also identifies other exhibits by case captions in survivors’ proceedings. None of those captions is reproduced here.¹⁸

An exhibit index filed the next day describes her as a judge. ⛔ The entry is NOT contiguous in the extraction, so it is given below as three separate runs, each exactly as the sheet prints it, and NOTHING is joined:

Transcript excerpts of Deposition of U.S. Virgin Islands

Judge and former Acting Attorney General Carol

July 13, 2023, in this Action.

⚠⚠ The words Court and taken on stand BELOW that entry on the same sheet, out of position, and the extraction does not carry the name of the court nor her surname after Carol. ⛔ This page does not compose those pieces into a sentence, does not supply the court’s name, and says nothing about what the extraction fails to carry. ➡ What can be stated is this: the words Judge and former Acting Attorney General stand in that index entry beside the words U.S. Virgin Islands, and the word Court stands on the same sheet. ⚠ Eight further copies of that index stand in this release; this page cites one and compares none.¹⁶²²

And an index filed two weeks later does not call her a judge at all. A declaration of 7 August 2023 describes the same deposition as the Deposition of former Acting Attorney General ⟦—⟧ taken on July 13, 2023, in this Action. ⚠ On that sheet the given name Carol is printed out of sequence below the entry; it is not reconstructed into the quotation.¹⁷

➡⛔ What this page concludes, which is very little. It is a documented fact that a filing of 24–25 July 2023 described her as a Virgin Islands court judge and former Acting Attorney General, and a documented fact that a filing of 7 August 2023 described her only as former Acting Attorney General. This release carries no appointment, nomination, confirmation, oath or swearing-in record for any judicial office she may hold, and no record of which court. ⚠ That negative was tested name-blind — "judge thomas-jacobs" (0 sheets), "honorable carol" (0), "carol t" co-occurring with judge (0), judicial-nomination and swearing-in phrases over the whole release, and a sweep of Virgin Islands judicial-appointment language — and it is reported as NOT FOUND BY THE ROUTES STATED, not as an absence. ⚠ "judge carol" returns two sheets and both are other judges of that given name in other jurisdictions.¹⁵¹

The January 2023 clipping, and why nothing on this page comes from it

⛔⛔ This release contains a newspaper report of an acting appointment to the office of Attorney General of the Virgin Islands. It reads appointed Carol and the extraction does not carry the surname. Measured per sheet with instr(): the document carries ZERO occurrences of thomas, jacobs or thomas-jacobs on any of its nine rows.

➡ Therefore: this page quotes nothing from that document, takes no fact from it, and does not assert that the person it describes is the subject of this page. ⛔ Nothing is supplied into it from context. Nothing is said about any mark, its class or its position, and nothing is said about what any withheld value would be. Whether the printed paper carries the surname is an IMAGE question and no image is openable on this desk. ⚠ The sheet is also a browser print whose own header reads 7/21/23, 12:18 PM — a July 2023 capture of an earlier story, filed as a litigation exhibit, not a contemporaneous newspaper. ✅ None of this matters to the page, because the 2023 acting tenure is documented three times over in her own dated signature blocks.

That clipping is cited, in its proper place, on Denise George, and this page does not duplicate it.³⁵

What cuts against the obvious story

The available cheap story is that an Attorney General sued a bank, was removed within days, and an assistant was installed to make the problem go away. ⛔ This page asserts nothing about why she was appointed. But the filing record is what it is, and it runs the other way:

She was already counsel on the JPMorgan complaint dated 26 December 2022, and she moved for her own federal admission on 30 December 2022 — before the removal of her predecessor was reported.⁹¹⁰
Between 10 January and 3 April 2023 she filed three successive amended complaints, two sets of letters rogatory, alternative-service motions against named third parties, and a motion to make the bank’s chief executive a document custodian.¹¹
She personally verified the Government’s interrogatory responses under penalty of perjury rather than delegating the verification.¹²
On 15 February 2023 the Government under her name filed a NOTICE OF FILING LESS REDACTED VERSION of its complaint.¹³
The Black agreement she signed expressly preserved the claims against JPMorgan Chase and against the Estate, and expressly preserved private parties’ remedies.⁸
In 2019 she was the officer who tightened Epstein’s notification regime, and she testified that she was surprised by her predecessor’s waivers and wanted to stick closer to the basic requirements of the statute.⁴⁷

⛔⛔ None of that is evidence of her motives either. It is evidence of what she filed. A desk that inverted the cheap story into a heroic one would be making the same mistake in the opposite direction, and this page does not do it.

What is left as a question

What did the Government give up on 21 February 2023, when it withdrew the intervention she had pressed in September 2020, and who decided? The sheet gives one reason and says nothing else.³²²⁷
Why does the Black agreement carry a document-disclosure constraint and a 14-day notice period? The agreement does not say.⁸
Why does the Black agreement’s trust-fund clause stop where the Estate settlement’s described purpose continued? The documents do not say, and the two are not comparable instruments.⁸³¹
Why was her deposition transcript designated confidential and filed under seal? The declaration gives only the Protective Order as the ground — and applies the same formula to three other Government-produced items on the same sheet.¹⁸
Why did she leave the Department on 15 May 2023, and when and to what court was she appointed? The motion recording her departure gives no reason and names no destination, and the appointment is not found by the routes stated.¹⁴¹⁵
Which title was hers when. Six sheets give five different titles across 2019–2022, including two that overlap in weeks. The record is inconsistent and this page reports the inconsistency.

Two traps in this record, disarmed

⛔ The surname trap. The token thomas stands on 67,230 sheets of this release because St. Thomas appears in nearly every Virgin Islands document, and jacobs stands on 906 because of at least six unrelated bearers. ⚠ A prefix is worse than the bare token here: '"thomas jacob"*' reaches 31 sheets, ten of them one unrelated man on social-event mail distributions. ⛔ No figure on this page comes from any of those searches.¹

⛔ The title trap, which is newer and sharper. "chief deputy attorney general" is a title, not a name, and eight of its seventeen sheets belong to a Chief Deputy Attorney General of New Mexico who wrote to the Southern District of New York about Epstein’s associates and whose office address is on one of the sheets. ➡ A desk that treated a job title as an identifier would have been wrong roughly half the time on this subject.¹

What this release does not contain about her

⛔ Stated as negatives where they were measured, and as unmeasured where they were not.

Measured, name-blind, and not found by the routes stated: any appointment, nomination, confirmation, oath or swearing-in record for any judicial office; any statement of which court; any reason for her leaving the Department beyond the fact of it; any statement by her, in her own words at the time, about either acting appointment.¹⁵

Measured, and negative: no document in the attributable set is dated between 3 April 2023 and 13 July 2023; no document in this set bounds the start or the end of the 2019 acting tenure; and the token retaliat* was not searched for over her sheets and no figure about it is given here.¹⁵

Unmeasured, and therefore not an absence: whether she appears in this release under role phrases that never spell her name beyond the five the desk tested; whether any further spelling variant exists; what the Virgin Islands trust funds in fact did with either sum; and whether any of the questions above is answerable from documents outside this release.¹⁵

Footnotes

Name-form and route measurement run for this page on 2026-10-01 against the full-text index of this release (pages_fts), counts in sheets (rows in pages) and documents (distinct identifiers). Counted: '"thomas-jacobs"' 21 sheets / 19 documents; '"carol thomas-jacobs"' 17/15; '"carol thomas jacobs"' 17/15 — the same query, because the unicode61 tokenizer splits on the hyphen, so these two rows are not additive; '"carol thomas"' 18/16; '"c. thomas-jacobs"' 0/0; '"jacobs carol"' 2/2, and both of those are artefacts of a doubled signature block in which /s/ Carol Thomas-Jacobs is immediately followed by CAROL THOMAS-JACOBS, ESQ., so the tokens fall adjacent across two lines — there is no surname-first rendering of her name in this release; '"carol t"' 32 sheets / 8 documents, of which 29 sheets in 5 documents are hers (EFTA02810307, EFTA02812460, EFTA02814515, EFTA02815106, EFTA02815688) and three are not. Traps, sized and never cited as figures about her: bare 'thomas' 67,230 sheets — it is St. Thomas; bare 'jacobs' 906 sheets, of which the desk’s triage sampled thirty outside her name forms and attributed none to her; '"thomas jacob"*' 31 sheets, ten of them one unrelated Thomas Jacobson; '"chief deputy attorney general"' 17 sheets, of which 8 are Clara Moran, Chief Deputy Attorney General of New Mexico (one of those sheets carries a Santa Fe office address), 8 carry the given name Carol inside Virgin Islands filings (EFTA02821562 ×4, EFTA02821591, EFTA02821851, EFTA02822271 ×2), and the seventeenth is EFTA02810140 pn 6, the clipping this page does not attribute to anybody. ⚠ CORRECTION TO THE DESK’S TRIAGE, which put the split at 9 hers and 8 Moran: the ninth sheet it counted as hers is that clipping, and this page does not attribute it. '"judge carol"' 2 sheets, both other judges of that given name in other jurisdictions; '"judge thomas-jacobs"', '"honorable carol"', '"carol t" AND judge' all 0. Role phrase: '"acting attorney general"' 120 sheets; the attribution of 74 of them to her is the desk triage’s hand classification of 2026-10-01, inherited here and NOT re-derived sheet by sheet, and so is the union floor of 132 sheets across 91 documents, which is stated throughout as a floor and never as a count. Invented controls, both 0/0: 'zzqcarol*', 'zzqthomasjacob*'. ⚠ Two method notes kept because they cost figures. (1) A truncated stem returns a confident zero as a bare FTS token, and quoting a prefix returns zero because inside double quotes the asterisk is a literal character — every stem query run for this page was an unquoted prefix. (2) LIKE fails across a line wrap where FTS does not: a candidate set filtered with LIKE '%virgin island%' silently dropped attributable sheets on which the phrase wraps, and returned them only after replace(replace(text_content,char(13),' '),char(10),' '). Every LIKE filter run for this page normalised whitespace first. ⚠ GLOB '*[VISION]*' is not a usable test — the brackets are a character class — and every synthetic-layer test on this page used instr(). ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹
Statement about this release’s own records, offered because it changes how every sheet above must be read. ⚠⚠ (1) NO IMAGE VERIFICATION WAS PERFORMED FOR THIS PAGE AND EVERY QUOTATION ON IT IS A TEXT-LAYER READING. This pass did not go to the site server at all — it is under load from a scrape and that is an open question for the owner — and no network request of any kind was made. Every footnote above says TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE, and no character-level claim is made anywhere on this page about the ink of any sheet. ⚠ A recorded public PDF address exists for 21 of the 30 documents cited here, all of them in the twelfth dataset, and is NULL for the other 9. A POPULATED ADDRESS DOES NOT MEAN THE IMAGE IS FETCHABLE: the desk has recorded one such address returning HTTP 200 with an Access Denied body. Image verification of this page is therefore OUTSTANDING; it is not established as impossible and it is not established as available. ⚠ Where a quotation is damaged the damage is reproduced and flagged, and NOTHING is mended inside quotation marks — on this page that includes fiteiga-;, OW5e, of, ttie, 11AD /A 3, live, Panics, 'Ibis, he, ('arol, arc, ofNew, Pro I lac Vice, May 15. 2023, February 10.2021, September 22. 2020, February P9 , 2022, ru, ro, lace, Committed lell, S email, al, they wasn't, I decide, Virgin islands, withdraws it, abovecaptioned, separatelyfiled and SHAM A. PINNEY. ⚠⚠ (2) doc_type IS NOT USABLE AND WAS NOT USED AS A FILTER ANYWHERE. Measured on the documents cited here: the Leon Black settlement agreement is typed court.plea_agreement; the Dimon custodian brief is typed travel.itinerary; the press digest carrying her 2020 court papers is typed calendar; a court motion is typed image.scan; two letters produced in the bank litigation are typed email.header; a court order is typed memo; and the same deposition transcript is typed court.filing in one copy and transcript.deposition in another. ➡ A search scoped by document type would have lost the single most consequential instrument on this page. ⚠⚠ (3) documents.total_pages WAS NOT RELIED ON. Every run length stated on this page is a direct count of rows in pages. ⚠⚠ (4) page_number IS 0-BASED AND NO MAPPING TO ANY SERVED PAGE NUMBER IS DERIVED ANYWHERE. Up to five different numbers can name one sheet in this production — the extraction row, the sheet’s own printed marking, its own stamp, a second production stamp or served ECF header, and the document identifier — and the footnotes above print every number they have and relate none of them by arithmetic. Every sheet cited on this page was located by STRING. ⚠⚠ (5) A SYNTHETIC ANNOTATION LAYER EXISTS IN THIS CORPUS AND IS NOT A PRODUCING PARTY’S MARK. Appended below the OCR layer of some sheets is a block headed [═══ TRANSCRIPT ═══]. That is an ADDED LAYER. ⛔ Quotation is taken ONLY from above that line and the block is treated exactly as a [VISION] description would be — as not evidence of anything about any sheet. ⚠⚠ CORRECTION TO THE DESK’S TRIAGE AND GATE, both of which put this at TWO sheets: measured with instr() over the thirty documents cited or considered for this page, the marker stands on FIFTEEN rows across SEVEN documents — EFTA02805549 at page_number 11, 12 and 27; EFTA02806313 at 6; EFTA02807216 at 0; EFTA02808954 at 10, 17 and 33; EFTA02809037 at 77, 84, 100, 128 and 151; EFTA02814623 at 1; and EFTA02822416 at 0. Three of those sheets are sheets this page quotes from, and in each case the offset of the marker and the offset of the last quoted string are given in the footnote so the reader can check that every quotation is from above the line. MEASURED CORPUS-WIDE for this page: the marker stands on 5,672 sheets of this release. It is a systemic layer of the extraction, not an anomaly of a few documents, and it is treated as evidence of nothing. ⚠⚠ ⚠⚠ (5a) THE DEPOSITION TRANSCRIPTS’ TEXT LAYER DOES NOT PRESERVE READING ORDER, AND THAT IS A CORRECTION TO THE DESK’S TRIAGE. On the transcript sheets cited here, speaker prefixes are separated from the words they label and right-margin overflow is relocated several lines below, so a number of answers the triage quoted as continuous sentences are NOT continuous in the extraction. Every transcript quotation on this page was re-cut to a run contiguous after the declared line-number lift and then checked by a whitespace-normalised substring test against the extraction; where the extraction breaks a sentence the page says so at the point of quotation and splices nothing. ⚠⚠ (6) [VISION] SHEETS: ZERO across every document cited on this page, measured per document with instr() and NOT with GLOB, because GLOB '*[VISION]*' is a character class and is broken for this purpose. ⚠⚠ (7) [REDACTED] TOKENS: ZERO across every document cited on this page. ⚠⚠ (8) EVERY DENOMINATOR ON THIS PAGE IS STATED. Where a figure is over sheets it says sheets; where it is over documents it says documents; where a count is inherited from the desk’s triage rather than re-derived here it says so; and where a figure is a floor it is called a floor. ⚠⚠ (9) NO COUNT(DISTINCT) FIGURE IS GIVEN OVER AN UNBOUNDED FULL-TEXT MATCH. The two bare-surname figures on this page are sheet counts only, and no document count is given for either. ↩ ↩²
A news article about an acting appointment to the office of Attorney General of the Virgin Islands, filed as a litigation exhibit; the sheet’s own print header reads 7/21/23, 12:18 PM. 9 rows in pages. https://epstein-data.com/EFTA02810140 . doc_type recorded court.filing; pdf_url populated. ⛔⛔ NOTHING IS QUOTED FROM THIS DOCUMENT ANYWHERE ON THIS PAGE AND NO FACT ON THIS PAGE COMES FROM IT. It is recorded here for one reason: so that its omission is not mistaken for an absence. ⚠ MEASURED FOR THIS PAGE with instr() per row over all 9 rows: thomas-jacobs 0, jacobs 0, thomas 0 — the document carries NO occurrence of her surname on ANY sheet. ⛔⛔ Therefore this page does not use it to attribute the appointment to her, does not supply her surname into anything it says, and does not assert that the person it names with a given name only is the subject of this page. Nothing is supplied from context. Nothing is said about any mark, its class or its position. Nothing is said about what any value the extraction does not carry would be. Whether the printed paper carries the surname is an IMAGE question and no image is openable on this desk. ⛔ The document carries telephone fields and advertising copy, and none of it is reproduced, described or located. ⚠ It is cited, in its proper context and with the same constraints, on Denise George, and this page does not duplicate it. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³ ↩⁴
Letter of the United States Virgin Islands Department of Justice, Office of the Attorney General, to Jeffrey Epstein, March 14, 2019, 6 rows in pages, counted directly; documents.total_pages was not relied on. https://epstein-data.com/EFTA00076028 . doc_type recorded letter; pdf_url NULL. This page cites page_number 2 and 3 (0-BASED, as the local extraction numbers them, located by STRING). ⚠⚠ Four numbers name each of those sheets and NO MAPPING between them is derived anywhere: the extraction rows 2 and 3; the sheets’ own stamps EFTA00076030 and EFTA00076031; the second sheet’s own printed marking Page 2; and the document identifier EFTA00076028. Every number this page has is printed and none is related to another by arithmetic. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 2 this page takes: the date line; the opening paragraph as quoted; the four numbered conditions in full; and the authority sentence. From page_number 3 this page takes the closing paragraph and the signature block as far as Acting Attorney General, and nothing after it. ⛔⛔ The addressee’s street line stands on page_number 2, and so does a letterhead carrying telephone and fax fields. NONE of it is reproduced, described or located here, and the quotation stops before each. ⚠ Five further copies of this letter stand in this release (EFTA00076036, EFTA00172077, EFTA01340980, EFTA01598591, and a further sheet of EFTA00794358’s family). Under the desk’s copy rule this page cites ONE copy, sets no copy beside another, characterises no difference between any two, and builds nothing on the fact that others exist. Block S over all 6 rows: every screened term 0. [VISION] sheets 0 by instr(). [REDACTED] tokens 0. Appended [═══ TRANSCRIPT ═══] blocks 0. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷
Signature sheets of the Government of the Virgin Islands’ First Amended Complaint against JPMorgan Chase, Dated: January 10, 2023, standing inside two large containers. https://epstein-data.com/EFTA00161836 — 122 rows in pages, doc_type court.filing, pdf_url NULL — and https://epstein-data.com/EFTA00162121 — 253 rows, same type, pdf_url NULL. This page cites EFTA00161836 page_number 32 and EFTA00162121 page_number 163 (0-based, as found, located by string). ⚠ These are two separate containers rather than two copies of one document, and the page sets neither beside the other, characterises no difference between them and builds nothing on their both existing; it cites the first and records the second so the citation can be checked. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE for both. From the sheet cited this page takes THREE lines: Dated: January 10, 2023, CAROL THOMAS-JACOBS, ESQ. and ACTING ATTORNEY GENERAL, and nothing after them. ⛔⛔ A bar-register number, a street line, a mail field and a telephone field stand below those lines and NONE is reproduced, described or located. ➡ ⭐ This footnote carries the correction that matters most to this page’s spine: the desk’s gate rested the 2023 acting tenure on the Black settlement’s signature block, whose date line is damaged. It did not need to. THREE sheets in this release carry the signature block CAROL THOMAS-JACOBS, ESQ. / ACTING ATTORNEY GENERAL beside a legible date — these two at January 10, 2023 and EFTA00145666 page_number 41 at April 3, 2023. The 2023 tenure is documented with name and date independently of the settlement. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0 on both documents. ↩ ↩² ↩³ ↩⁴ ↩⁵
Further excerpts of the same video-recorded deposition of THURSDAY, JULY 13, 2023, filed as EXHIBIT 312, Case 1:22-cv-10904-JSR Document 283-9 Filed 08/14/23. 11 rows in pages. https://epstein-data.com/EFTA02815106 . doc_type transcript.deposition; pdf_url populated. This page cites page_number 2, 5, 6, 7, 8, 9 and 10 (0-based, as found, located by string); the transcript’s own internal page numbers on those sheets are 132, 135, 146, 147, 148, 149 and 150, their stamps run EFTA02815108 and following, and their served headers read Page 3 of 11 and following. NO MAPPING between those five families of number is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. ⚠⚠ The line-number lift and the READING-ORDER WARNING set out in full in the previous footnote apply to every passage below, and every one of them was re-cut to a contiguous run and checked by substring test. **From page_number 2 this page takes: the question beginning And do you know if the Attorney General's Office in full, and the answer THE WITNESS: I'm not aware of any. From page_number 5: the run The Virgin islands can only respond to what they know., the separate run I was not aware, and I don't know if anyone was aware in 2017. — ⚠ between those two the sheet prints the clause And like I said, I don't know out of position, and this page does NOT splice them — and the run THE WITNESS: The Virgin Islands can only take action on what they know. From page_number 6: the run In your opinion, do you believe law enforcement has an, which is where that sheet ends. From page_number 7: the continuation obligation to monitor public dockets of every court in the country for allegations that may reference the Virgin Islands?; the ONLY contiguous run of the answer, unreasonable obligation on the Virgin Islands.; and the run Q. And this is the E-mail chain that counsel showed you involving Clive Rivers and Denise ⟦—⟧ you were copied on several of these E-mails; is that correct? A. Yes. ⚠⚠ The words I don't., I think it's and It would be an stand lower on page_number 7, out of position. The desk’s triage quoted the answer as one sentence. THIS PAGE DOES NOT, and says so in the body. From page_number 8: the run And there is an E-mail that AG ⟦—⟧ sent to Attorney Kellerhals and Attorney Rivers on June 2nd, 2019. and the run beginning says, "While my predecessors have apparently had differing interpretations. From page_number 10: the run A. It gives the Attorney General the discretion to modify the notification requirements.; the run A. Attorney Generals are free to exercise their discretion however they see fit.; and the separate run discretion one way, and I -- when I was sitting Attorney General, I exercised my discretion in a different manner. ⚠ The clause And he exercised his stands below that last run on the sheet, out of position, and is NOT spliced in. ⚠ Virgin islands lower-cased is the extraction’s rendering and is NOT mended. ⛔ The extraction does not carry the sending officeholder’s surname at the point where counsel names the e-mail’s author, and does not carry one recipient’s surname. NEITHER is supplied, no class or position is stated for either, and nothing is said about what either would be. ⛔ page_number 3 and 4 carry further questioning that refers to allegations in a specific pleading. The answers on those sheets are NOT quoted and nothing from the pleading is reproduced, paraphrased or characterised. ⛔ A document stamp recited by counsel on page_number 7 and 8 is not reproduced. Block S over all 11 rows: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³ ↩⁴
Excerpts of the video-recorded deposition of the subject of this page, taken THURSDAY, JULY 13, 2023 in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., filed as EXHIBIT 263, Case 1:22-cv-10904-JSR Document 284-40 Filed 08/14/23. 14 rows in pages, counted directly. https://epstein-data.com/EFTA02815688 . doc_type transcript.deposition; pdf_url populated. This page cites page_number 1, 2, 3, 5, 6, 7, 8, 10 and 11 (0-BASED, as found, located by STRING). ⚠⚠ FIVE NUMBERS NAME EACH OF THESE SHEETS AND NO MAPPING BETWEEN THEM IS DERIVED: the extraction row; the sheet’s own stamp (EFTA02815689 and following); the served header (Page 2 of 14 and following); the transcript’s own internal page number printed in the running header (1, 23, 24, 40, 41, 114, 115, 126, 127); and the document identifier. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. ⚠⚠⚠ THE QUOTING DISCLOSURE THAT GOVERNS EVERY TRANSCRIPT PASSAGE ON THIS PAGE, AND IT IS A CORRECTION TO THE DESK’S TRIAGE. (1) The transcript prints a line number at the head of every line and a running header at the top of every sheet; the line numbers and the running-header lines have been LIFTED OUT and that lift is the only alteration anywhere. (2) MEASURED FOR THIS PAGE: on these sheets the text layer DOES NOT PRESERVE READING ORDER. Speaker prefixes (A., Q., THE WITNESS:) are frequently separated from the words they label, and words that overflowed the printed right margin are relocated several lines below. (3) CONSEQUENCE: several answers the desk’s triage quoted as continuous sentences are NOT continuous in the extraction. EVERY passage quoted on this page was re-cut to a run that is contiguous after the line-number lift, and was then checked by a whitespace-normalised substring test against the extraction. (4) Where the extraction breaks a sentence, the page SAYS SO at the point of quotation and DOES NOT SPLICE, REORDER, COMPLETE OR MEND IT — including the answer whose clauses it prints in the wrong order, which is quoted in the extraction’s own order with the disorder flagged. (5) Objection interjections are omitted wherever a quoted run begins or ends after them and are reproduced where they fall inside one. From page_number 1 this page takes the three title-page lines quoted. From page_number 2: the run A. I reviewed the file and I consulted with Shani regarding course of action.; the run beginning Q. Okay. And what did you decide to do? through that he had before.; the run beginning A. -- had granted Mr. Epstein a waiver; and the question Q. And why did you decide to modify the waiver?. From page_number 3: the single contiguous run -- I did not see anything in the file to support the waiver. From page_number 5: the run beginning THE WITNESS: Well, I think the statutes allows through And I felt that I, quoted in the extraction’s own order; the run A. Again, because to protect our with And why was that? community. following it as the sheet prints them; the surprise question in full; and THE WITNESS: Was I surprised? Yes. From page_number 6: the single contiguous run beginning that at least for me, the better course. From page_number 7: A. I don't have all the facts before me. and best person would be the person who is responsible for the sex offender registration. From page_number 8: THE WITNESS: I think Epstein, Mr. Epstein was evasive; A. -- and clever in avoiding the verifications, if nothing else.; the follow-up question in full; and the answer beginning THE WITNESS: Again, I -- you know. From page_number 10: the standalone THE WITNESS:, the run They should have. and A. I don't recall this. From page_number 11: the run Q. Do you know if any follow-up happened? A. I don't know. ⛔⛔ page_number 9, 12 and 13 of this transcript carry material put to her from a third party’s correspondence and from pleadings in survivors’ proceedings. NOTHING from any of those sheets is reproduced, paraphrased, counted or characterised on this page. Her own answers quoted above from page_number 10 and 11 are given WITHOUT the documents or allegations that prompted them, and the page says only that counsel put a document to her. No survivor, claimant or third-party correspondent is named, numbered, located or described. ⚠ they wasn't and I decide are the extraction’s renderings and are NOT mended. Block S over all 14 rows: victim 0, complainant 0, massage 0, underage 0, minor 0, traffick 0, csam 0, jane doe 0 — the screened vocabulary is absent even from the sheets this page declines to use. [VISION] 0 by instr(); [REDACTED] 0; appended-transcript blocks 0. ⛔ Reachable in this corpus ONLY through the form "carol t", which the desk’s own commission did not list. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹
SETTLEMENT AGREEMENT AND RELEASE between the Government of the United States Virgin Islands and Leon Black, filed in this release as EXHIBIT B. FIVE rows in pages, counted directly; documents.total_pages was not relied on. https://epstein-data.com/EFTA00155032 . ⚠⚠ doc_type is recorded court.plea_agreement. It is a civil settlement agreement and there is no plea in it. That is a documented fact about this production’s own metadata, and doc_type was NOT used as a filter anywhere on this page. pdf_url NULL. This page cites page_number 1, 2 and 3 (0-BASED, as found, located by STRING); those sheets’ own stamps are EFTA00155033 and EFTA00155034, and the stamp EFTA00155035, and the second and third print their own markings 2 and 3. A fourth sheet, page_number 4, stamp EFTA00155036, prints Dated: 11AD /A 3 and 4. NO MAPPING between any of those numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 1 this page takes: the opening sentence; the two recitals quoted; the Total Cash Payment clause; the trust clause; and the release clause as far as any other financial. From page_number 2 it takes: the continuation institution used by Black through Nor does it apply to Jeffrey Epstein or his estate.; the no-admission clause as quoted; the private-party clause as quoted; and the document-disclosure clause in full. From page_number 3 it takes: the witness clause; the date line Dated: fiteiga-;; the office line; and the two signature lines as quoted. ⚠⚠ THE FOLLOWING STRINGS ARE THE EXTRACTION’S RENDERINGS AND ARE NOT MENDED ANYWHERE ON THIS PAGE, INSIDE QUOTATION MARKS OR OUT: live for five, Panics for Parties, he for be, 'Ibis for This, fiteiga-;, OW5e, of, ttie, and 11AD /A 3. ⚠⚠ The release sentence runs across the join between page_number 1 and page_number 2; both pins are given above and nothing is bridged except the line break. ⛔⛔ CORRECTION CARRIED FROM THE DESK’S GATE AND SHARPENED: the gate recorded that the words executed 20 January 2023 are not readable from page_number 3, which is correct. The agreement’s own date of entry IS readable, and it is printed on page_number 1 — is entered into this 20th day of January, 2023. This page therefore states the date of ENTRY as documented and states that NO date of SIGNATURE is established, because both date lines beside the signature blocks are illegible in this extraction. ⛔ No signature image, no notarisation and no counter-signature is quoted, described or located, and the page makes no claim about who signed on behalf of the other party. Block S over all 5 rows: victim 0, complainant 0, minor 0, massage 0, jane doe 0, traffick 0, csam 0. [VISION] 0 by instr(); [REDACTED] 0; appended [═══ TRANSCRIPT ═══] blocks 0. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸
The Government of the United States Virgin Islands’ original complaint against JPMorgan Chase Bank, N.A., Case 1:22-cv-10904-JSR Document 1 Filed 12/27/22, dated December 26, 2022. 30 rows in pages. https://epstein-data.com/EFTA02805549 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 28 (0-based, as found, located by string); the sheet’s own stamp is EFTA02805577, it prints its own marking 29, and its served header reads Page 29 of 30. NO MAPPING between those numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes THREE strings: Dated: December 26, 2022; Pro Hac Vice to be submitted; and Assistant Attorney General. ⛔⛔ A bar-register number, a street line, a mail field and a telephone field with an extension stand on this sheet and NONE is reproduced, described or located. The Attorney General’s own name in the block above is damaged beyond reading in this extraction and is NOT quoted, reconstructed or described. ⛔ The prayers for relief on this sheet recite the CICO Act’s statutory purpose. Nothing is taken from them. ⚠ The filing date is taken from the served header on page_number 0 and the signature date from page_number 28; the two differ by one day and both are given. Appended [═══ TRANSCRIPT ═══] blocks stand on 3 rows of this document — page_number 11, 12 and 27 — and NOT on the sheet cited. [VISION] 0; [REDACTED] 0. ↩ ↩² ↩³ ↩⁴
MOTION FOR ADMISSION PRO HAC VICE, Case 1:22-cv-10904-JSR Document 7 Filed 12/30/22 Page 1 of 1. ONE row in pages, counted directly. https://epstein-data.com/EFTA02805596 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 0 (0-based, as found); the sheet’s own stamp is EFTA02805596. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the body paragraph beginning Pursuant to Rule 1.3 in full as quoted; the good-standing sentence as quoted; Dated: December 30, 2022; and the title Assistant Attorney General. ⚠ ofNew and Pro I lac Vice are the extraction’s renderings and are NOT mended. ⛔⛔ The signature line on this sheet is damaged in the extraction and is NOT quoted, reconstructed or described. A street line, a telephone field with an extension and a mail field stand below it and NONE is reproduced, described or located. ⛔ A sentence about criminal and disciplinary history is printed with one word out of position in this text layer and is NOT quoted. Block S: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³ ↩⁴
The Government of the Virgin Islands’ filings in 1:22-cv-10904-JSR between January and April 2023, each located by string over a whitespace-normalised search for an acting-Attorney-General signature block beside a printed Dated: line. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE for every row. Cited for existence and date, with the sheet each date is read from: letters rogatory, Dated: January 20, 2023, https://epstein-data.com/EFTA02805800 page_number 1 (3 rows) and EFTA02805819, EFTA02805822, EFTA02805841, EFTA02805860; a further Letter of Request for Document Production, Dated: January 26, 2023, https://epstein-data.com/EFTA02805942 page_number 1; a discovery brief, Dated: February 13, 2023, https://epstein-data.com/EFTA02806300 page_number 10 (13 rows); alternative-service motions, Dated: February 17, 2023 https://epstein-data.com/EFTA02806223 page_number 3 and Dated: March 3, 2023 https://epstein-data.com/EFTA02806354 page_number 2; the custodian motion, Dated: February 23, 2023, https://epstein-data.com/EFTA02806266 page_number 10 (11 rows), from which this page takes ONE sentence — the Court should order JPMorgan to designate Mr. Dimon as a document custodian and provide documents for the relevant time period through and including 2019. — and ⚠ whose doc_type is recorded travel.itinerary, which it is not; a protective-order amendment, Dated: March 2, 2023, https://epstein-data.com/EFTA02806338 page_number 0; a motion to withdraw another lawyer, Dated: March 23, 2023, https://epstein-data.com/EFTA02806639 page_number 1 (2 rows); and the last filing over her name in this set, Dated: April 3, 2023, https://epstein-data.com/EFTA00145666 page_number 41 of 42 rows, pdf_url NULL, from which this page takes Dated: April 3, 2023, CAROL THOMAS-JACOBS, ESQ., ACTING ATTORNEY GENERAL and the line Carol Thomas-Jacobs (pro hac vice) / Acting Attorney General of the United States Virgin Islands. All page_number values are 0-based as found and located by string; each sheet’s own stamp and served header carry different numbers and NO MAPPING between them is derived. ⛔⛔ Every one of these sheets carries street lines, mail fields, telephone and fax fields and in some cases bar-register numbers for Government and private counsel. NONE is reproduced, described or located anywhere on this page, and every quotation stops before them. ⛔ The letters-rogatory motions recite the Government’s trafficking allegations. NOTHING of that recitation is reproduced, paraphrased, counted or characterised here. ⛔ Several of these filings exist in multiple copies in this release; this page cites one of each, sets no copy beside another, and characterises no difference between any two. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶
VERIFICATION of the Government of the United States Virgin Islands’ Objections and Responses to JPMorgan Chase Bank, N.A.’s First Set of Interrogatories, Case 1:22-cv-10904-JSR Document 61-4 Filed 02/28/23 Page 12 of 13. 13 rows in pages. https://epstein-data.com/EFTA02806300 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 11 (0-based, as found, located by string); the sheet’s own stamp is EFTA02806311. NO MAPPING to the served header is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the heading VERIFICATION; the opening declaration line; the two sentences beginning I am the Acting Attorney General; the qualifying sentence beginning Because the matters stated; the perjury sentence; and the execution line. ⚠ ('arol and arc are the extraction’s renderings and are NOT mended. The extraction does not carry her surname in the declaration line, and does not carry the place of execution; NEITHER is supplied, no class or position is stated for either, and nothing is said about what either would be. ⛔ The signature block on the preceding sheet carries bar-register numbers, street lines, telephone fields and mail fields for Government and private counsel and NONE is reproduced, described or located. Block S on the sheet cited: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' NOTICE OF FILING LESS REDACTED VERSION OF ITS FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL, Case 1:22-cv-10904-JSR Document 47 Filed 02/15/23 Page 1 of 3. 3 rows in pages. https://epstein-data.com/EFTA02806164 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 0 (0-based, as found, located by string); the sheet’s own stamp is EFTA02806164. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the caption in full; the body paragraph in full as quoted; Dated: February 15, 2023; and the two lines CAROL and ESQ. / ACTING ATTORNEY GENERAL, stopping there. ⚠ The extraction does not carry her surname in that block and nothing is supplied. ⛔⛔ A street line and a telephone field with an extension follow and neither is reproduced, described or located. ⛔⛔ THIS PAGE SAYS NOTHING WHATEVER ABOUT ANY WITHHELD VALUE IN EITHER VERSION OF THAT COMPLAINT — not what class of value, not where any stands, not what any covers, not how many there were, and nothing whatever about any sheet’s treatment. It reports only what the notice says about itself. Block S: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MOTION FOR LEAVE TO WITHDRAW CAROL ⟦—⟧ AS COUNSEL OF RECORD, Case 1:22-cv-10904-JSR Document 128 Filed 05/01/23. 3 rows in pages. https://epstein-data.com/EFTA02807216 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 0 and 1 (0-based, as found, located by string); their own stamps are EFTA02807216 and EFTA02807217, and their served headers read Page 1 of 3 and Page 2 of 3. NO MAPPING between those numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 0 this page takes: the caption title; paragraph 1 in full; and paragraph 2 in full. From page_number 1 it takes: paragraph 3 in full; the WHEREFORE paragraph in full; Dated: May 1, 2023; and the two lines ARIEL / ESQ. and ATTORNEY GENERAL NOMINEE. ⚠ May 15. 2023 is the extraction’s rendering and is NOT mended. ⛔⛔ The extraction does not carry the subject’s surname at any point on these sheets and does not carry the signatory’s surname. NEITHER is supplied, no class or position is stated for any value the extraction does not carry, nothing is said about what any such value would be, and NO successor is named anywhere on this page. ⛔⛔ page_number 1 and page_number 2 carry a street line, a telephone field with an extension and a mail field for another lawyer. NONE is reproduced, described or located, and the quotation stops before them. ⛔⛔ THIS SHEET CARRIES AN APPENDED [═══ TRANSCRIPT ═══] BLOCK beginning at character offset 1,128 of 1,352 on page_number 0. Measured for this page: the last string quoted from that sheet ends at offset 1,112, so EVERY quotation is taken from ABOVE that line. Nothing below it is quoted, counted or treated as evidence of anything, and a mail field and a telephone field stand inside it and are not reproduced. ⭐⭐ MEASURED FOR THIS PAGE, AND IT IS THE METHODOLOGICAL FINDING OF THIS PASS: this document matches NONE of the seven query strings the desk’s triage and gate used — '"thomas-jacobs"' 0, '"carol t"' 0, '"acting attorney general"' 0, '"assistant attorney general"' 0, '"deputy attorney general"' 0, '"chief deputy attorney general"' 0, '"acting ag"' 0 — and instr() per row returns 0 for thomas and 0 for jacobs on all three rows, while carol stands on two of them. It was reached only by removing her name from the question and asking who signed the Government’s filings in that docket after April 2023. Block S over all 3 rows: every screened term 0. [VISION] 0; [REDACTED] 0. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶
What was searched for and not found, labelled as unmeasured or as negative, and — where it is a negative — re-run with her name REMOVED from the query, because on this subject a name-scoped set is provably blind. ⚠⚠ THE DESK’S BRIEF RECORDED THAT THIS RELEASE CARRIES NOTHING ON WHEN OR WHY THE ACTING TENURE ENDED. THAT IS WRONG, AND THE NAME-BLIND RE-RUN IS WHAT SHOWED IT. Route that found it: FTS '"attorney general" AND "virgin islands"', filtered on the whitespace-normalised sheet for a printed Dated: line after April 2023 beside an attorney-general title block. Result: the Government’s filings in 1:22-cv-10904-JSR are signed over her full name as ACTING ATTORNEY GENERAL as late as 3 April 2023; from 1 May 2023 over a different given name as ATTORNEY GENERAL NOMINEE; and from 14 July 2023 over that same given name as ATTORNEY GENERAL. And the motion of 1 May 2023 states in terms that she will no longer be with the Department of Justice, Office of the Attorney General, effective May 15. 2023. ⛔ That document matches none of the seven query strings the desk used — measured, 0 on each. No successor is named on this page. NOT FOUND BY THE ROUTES STATED, each route named so the negative can be re-tested: any appointment, nomination, confirmation, oath or swearing-in record for any judicial office she may hold, and any statement of which court — searched with '"judge thomas-jacobs"' (0 sheets), '"honorable carol"' (0), '"thomas-jacobs" AND judge' (2 sheets, both the March 2020 press digest, neither about a judicial office of hers), '"carol t" AND judge' (0), '"superior court judge" AND carol' (1 sheet, her own March 2021 filing, referring to another judge), '"superior court" AND nominat* AND "virgin islands" AND judge' (3 sheets, none about her), '"judicial nominee" OR "judicial nomination"' (19 sheets, none about her), '"sworn in as a judge" OR "sworn in as judge"' (0), '"supreme court of the virgin islands" AND nominat*' (0), and '("sworn in" OR "swearing in") AND judge AND "virgin islands"' (3 sheets, all single-row megacontainers excluded for the reasons in the preceding footnote). ⛔ Also not found by the routes stated: any reason for her leaving the Department beyond the fact of it; any statement by her, in her own words at the time, about either acting appointment; any document bounding the start or the end of the 2019 acting tenure. MEASURED AND NEGATIVE: no document in the desk’s attributable set is dated between 3 April 2023 and 13 July 2023. UNMEASURED, AND THEREFORE NOT A NEGATIVE: whether she appears in this release under role phrases beyond the five the desk tested — the desk’s own union floor exists precisely because at least one sheet refers to her office as the outgoing acting AG with no name at all; whether any further spelling variant of her surname exists; whether retaliat* or any similar vocabulary stands on her sheets, which was NOT searched for and about which this page gives no figure; what either Virgin Islands trust fund in fact did with either sum; why the Government withdrew its intervention on 21 February 2023; why the Black agreement carries a document-disclosure clause; why her transcript was sealed; and whether any of those is answerable from documents outside this release. ⚠ Each of those is unmeasured. NONE of them is a finding of absence, and this page does not patch any of them with anything from outside this release. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰
Exhibit index, Case 1:22-cv-10904-JSR Document 237 Filed 07/25/23 Page 34 of 34, closing with Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct. and Dated: July 24, 2023. 34 rows in pages. https://epstein-data.com/EFTA02810511 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 33 (0-based, as found, located by string); the sheet’s own stamp is EFTA02810544 and it prints its own marking 34. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes THREE contiguous runs of the Exhibit 299 entry and no more — Transcript excerpts of Deposition of U.S. Virgin Islands, Judge and former Acting Attorney General Carol, and July 13, 2023, in this Action. — together with the declaration and date lines. ⚠⚠ THE TEXT LAYER PRINTS THE WORDS Court AND taken on OUT OF SEQUENCE, BELOW THE REST OF THAT ENTRY, so the entry is NOT a contiguous string. ⛔ This page gives the three runs separately, declares the disorder, and does NOT compose them into a sentence, does NOT insert Court or taken on into any of them, and reconstructs NOTHING. The desk’s triage quoted this entry as a single continuous phrase. ⛔ The extraction does not carry the name of the court, and does not carry her surname. NEITHER is supplied, no class or position is stated for either, and nothing is said about what either would be. ⛔⛔ The other entries on this sheet identify sealed exhibits, document stamps and other deponents. NOTHING is taken from them beyond the fact, stated in the body, that this index exists. No document stamp from this sheet is reproduced. ⚠ EIGHT further copies of this index stand in this release at the same internal page — EFTA02811112, EFTA02811257, EFTA02811411, EFTA02811585, EFTA02811727, EFTA02811880, EFTA02812084 and EFTA02812468, each at page_number 33. Under the copy rule this page cites ONE, sets no copy beside another, characterises no difference between any two, says nothing about what any other copy carries, and builds nothing on the fact that there are nine. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³
Declaration listing exhibits, Case 1:22-cv-10904-JSR Document 270 Filed 08/07/23 Page 2 of 4. 4 rows in pages. https://epstein-data.com/EFTA02814623 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 1 (0-based, as found, located by string); the sheet’s own stamp is EFTA02814624 and it prints its own marking 2. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes TWO contiguous runs of the Exhibit 8 entry and no more: the Deposition of former Acting Attorney General and taken on July 13, 2023, in this Action. ⚠⚠ On this sheet the given name Carol is printed OUT OF SEQUENCE, below the rest of that entry. It is NOT reconstructed into either run, and the two runs are not composed into a sentence. ⛔ The extraction does not carry her surname in that entry and nothing is supplied. ⚠ MEASURED FOR THIS PAGE: this index marks two other exhibits [Sealed] and marks the Exhibit 8 transcript excerpts with no sealing notation at all. That is stated in the body as a fact about this sheet and NO conclusion is drawn from it; it is a different declaration about a different exhibit set from the one in the preceding footnote, and this page does not treat the two as copies or compare them as such. ⛔⛔ THIS SHEET CARRIES AN APPENDED [═══ TRANSCRIPT ═══] BLOCK beginning at character offset 2,088 of 2,310. EVERY quotation above is taken from ABOVE that line and nothing below it is quoted, counted, characterised or treated as evidence of anything. ⛔ The other entries on this sheet name other deponents and recite document stamps; nothing is taken from them beyond the fact of the index. [VISION] 0; [REDACTED] 0. ↩ ↩² ↩³
Declaration listing exhibits, Case 1:22-cv-10904-JSR Document 226 Filed 07/24/23 Page 4 of 9. 9 rows in pages. https://epstein-data.com/EFTA02810307 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 3 (0-based, as found, located by string); the sheet’s own stamp is EFTA02810310 and it prints its own marking 4. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes ONE numbered item, paragraph 17, in full as quoted. ⛔ The extraction does not carry her surname after Carol T. and nothing is supplied; no class or position is stated for the value the extraction does not carry and nothing is said about what it would be. ⚠ MEASURED ON THIS SHEET FOR THIS PAGE, and the measurement is the reason the body declines to over-read the sealing: paragraphs 15, 18 and 20 each describe a document produced by the Government of the Virgin Islands and each carries the identical formula designated confidential pursuant to the Protective Order in this matter and filed under seal, while paragraph 16 describes a document produced by the bank and carries no such formula. ⛔⛔ Paragraphs 14 and 19 of this sheet identify pleadings in survivors’ proceedings by case caption. NEITHER caption is reproduced, paraphrased or characterised anywhere on this page, and the document stamps recited in the paragraphs this page does not quote are not reproduced. ⛔ This page makes NO comparison between the treatment of this transcript and the treatment of any other deponent’s transcript anywhere else in this release; the only comparison made is within this one sheet, between items in one list, and it is stated as such. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³
Federal Bureau of Investigation FD-302, Date of entry 10/06/2023, recording an interview of Denise George conducted on 10/02/2023, 4 rows in pages. https://epstein-data.com/EFTA00129035 . doc_type recorded fbi.302a; pdf_url NULL. This page cites page_number 0 and refers to page_number 1 (0-based, as found, located by string); their own stamps are EFTA00129035 and EFTA00129036, and the second prints its own marking 2 of 4. No served page number is asserted and no mapping is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 0 this page takes TWO passages: the sentence beginning A previous AG, Vincent Franklin Frazer in full as quoted, and the Bureau’s standard legend This document contains neither recommendations nor conclusions of the FBI. From page_number 1 it takes FIVE WORDS: After being briefed by the outgoing acting AG, cited only to show that sheets referring to her office without any name form exist. ⛔⛔ A date-of-birth field, a telephone field and a case-management number stand on page_number 0 and NONE is reproduced, described or located here. The quotation begins below them. ⛔ page_number 1 carries extensive allegation material about other people and about victims. NOTHING of it is reproduced, paraphrased, counted or characterised on this page, and no victim is named, numbered or described. ⚠ Tier: everything in this document is what a named person told a federal agent, recorded by the agent. It is written on this page as that and never as what happened. ⚠ The identification of the outgoing acting AG with the subject of this page is an inference and is labelled one; nothing rests on it. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩²
Vocabulary and position screen run for this page on 2026-10-01. Denominator: the 21 sheets reached by '"thomas-jacobs"', each tested as a case-folded substring over the whitespace-normalised text_content of that sheet. Results, reproducing the desk triage’s figures exactly: attorney general 21/21 (100.0%); complainant 0/21; victim* 4/21 (19.0%); underage* 2/21 (9.5%); traffick* 2/21 (9.5%); csam 2/21 (9.5%); jane doe 2/21 (9.5%); minor* 0/21; massage* 0/21; invented control zzqcarol* 0/21. ➡ She is counsel or the officer of record on every one of those sheets. ⛔ The four sheets carrying victim vocabulary were read individually and not one places her as a victim or a complainant: two are copies of a 2020 press digest reporting what she wrote in court papers about a compensation fund, one is a statutory prayer-for-relief reciting the CICO Act’s purpose, and one is the agreed motion of 27 March 2023. Nothing from the last of those is reproduced, paraphrased, counted or characterised on this page beyond the bare fact that she was counsel of record on it. ⚠ No survivor is named, numbered, described, quoted or characterised anywhere on this page. ↩
Agreed motion, Date: March 27, 2023, in a related Virgin Islands matter. 7 rows in pages. https://epstein-data.com/EFTA00156585 . doc_type recorded court.order; pdf_url NULL. This page cites page_number 5 (0-based, as found, located by string); the sheet’s own stamp is EFTA00156590; the served header on that sheet is damaged in the extraction and is not reproduced or reconstructed. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes THREE strings and no more: This Motion has been agreed to by the parties., Date: March 27, 2023, and the two lines Carol Thomas-Jacobs (pro hac vice) / Acting Attorney General of the United States Virgin Islands. ⛔⛔ NOTHING ELSE ON THIS SHEET IS REPRODUCED, PARAPHRASED, COUNTED OR CHARACTERISED ANYWHERE ON THIS PAGE. The motion’s subject matter, the relief it sought, the parties to it other than the Government, and every term of its proposed protocol are outside this page entirely. No survivor or claimant is named, numbered, described or alluded to, and the matter is referred to only as a related matter. ⛔⛔ The sheet carries mail addresses, street lines, telephone fields and fax fields for several private firms and for the Government. NONE is reproduced, described or located. ⚠ A further copy of this motion stands at EFTA00144344 page_number 52. This page cites ONE, compares none, and characterises no difference. ⚠ This sheet is cited for one purpose only: it is one of the full-name sheets in the same docket family that let the body state, and a reader check, on what basis the withdrawal motion of 1 May 2023 is read as concerning her. ↩ ↩²
Documents and routes deliberately NOT used, recorded so that the omissions are not mistaken for absences. ⛔ COPIES. This release holds multiple copies of almost every document on this page: at least six of the 14 March 2019 letter, several of the April 2019 letter from Epstein’s counsel, several versions of the earlier letter from Epstein’s counsel addressed to her, nine of the 24–25 July 2023 exhibit index, two of the deposition-topic schedule, two of the March 2020 press digest, two of the 27 March 2023 agreed motion, two of one deposition excerpt, and at least ten of the amended-complaint signature sheets. ⛔⛔ Under the desk’s copy rule this page cites ONE copy of each, sets NO copy beside another, characterises NO difference between any two copies, says nothing about what any uncited copy carries, and builds nothing whatever on the fact that copies differ. Where a divergence was noticed, it was withheld entirely. ⛔ FOUR SINGLE-ROW MEGACONTAINERS under HOUSE_OVERSIGHT_* identifiers stand in the desk’s candidate set at 518,603, 231,065, 91,484 and 73,905 characters on one row each. With one row no sheet inside them can be identified, so no pin into them is possible; they are excluded from every measurement on this page, nothing cites them, and in any case none of them is her — they are an unrelated Carol Berry, an unrelated Carolyn in an obituary, and two instances of an attorney surnamed Scarola. ⛔ The 27 March 2023 agreed motion is cited for three strings only and its subject matter is excluded entirely; the sheets of her own deposition that carry material from survivors’ proceedings and from a third party’s correspondence are excluded entirely; and the second and third sheets of the FD-302 are excluded apart from six words. ⛔ The January 2023 news clipping is excluded as a source of fact for the reasons set out in its own footnote. ⛔ A second copy of the Attorney General Nominee’s June 2019 letter sheet, and the further copies of the April 2019 letter, are recorded above and not compared. ⛔ Two identifiers under standing desk bars, and one topic page under a standing bar, were not approached, opened, queried or named. One name under a standing hold was not named, researched or looked up. ⛔ No search was run, and no figure is given, for any survivor’s name, pseudonym or identifying detail. ↩ ↩² ↩³ ↩⁴ ↩⁵
Letter of April 30, 2019 from Epstein’s Virgin Islands counsel to the incoming Attorney General, inside a 196-row mail container produced in the bank litigation under the legend CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. 196 rows in pages, counted directly. https://epstein-data.com/EFTA02809037 . doc_type recorded email.header, which this document is not; pdf_url populated. This page cites page_number 119 (0-based, as found, located by string). ⚠⚠ Five numbers name that sheet and NO MAPPING is derived: extraction row 119; the sheet’s own stamp EFTA02809156; a second production stamp VI-JPM-000012446; the served header Document 194-27 Filed 06/20/23 Page 120 of 196; and the document identifier EFTA02809037. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE, and the extraction of this sheet is visibly damaged throughout. From this sheet this page takes ONE sentence, in full as quoted, beginning By letter ru Mr. Epstein dated March 14, 2019. ⚠ ru, ro and lace are the extraction’s renderings and are NOT mended. ⛔⛔ The letterhead of this sheet carries a street line, a telephone field and a web address. None is reproduced, described or located. ⛔ Nothing else on the sheet is reproduced or characterised, including the body of counsel’s argument, which is set out on Denise George from a different copy. ⚠⚠ Further copies of this letter stand in this release. Under the copy rule this page cites ONE, sets no copy beside another, characterises no difference between any two, says nothing about what any other copy carries, and builds nothing on the fact that they differ. Appended [═══ TRANSCRIPT ═══] blocks stand on 5 rows of this document — page_number 77, 84, 100, 128 and 151 — and NOT on the sheet cited. [VISION] 0; [REDACTED] 0. ↩ ↩²
Letter of the Attorney General Nominee to Epstein’s counsel, third sheet, inside a 71-row mail container produced in the bank litigation under the legend CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. 71 rows in pages. https://epstein-data.com/EFTA02808954 . doc_type recorded email.header, which this document is not; pdf_url populated. This page cites page_number 57 (0-based, as found, located by string); the sheet’s own stamp is EFTA02809011, its second production stamp is VI-JPM-000012502, its served header reads Document 194-24 Filed 06/20/23 Page 58 of 71, and its own printed marking is 3. NO MAPPING between those five numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes ONE clause: reconsider the terms of your client's sexual offender travel notification requirements as set forth in the March 14, 2019 letter from former Acting Attorney General Carol, and the quotation STOPS there. ⛔ The extraction ceases to carry the value at that point. This page supplies nothing, says nothing about what stands there, states no class or position for it, and makes no claim about the printed sheet. ⛔ The date of this letter is NOT on this sheet and is not asserted from it. The date June 2nd, 2019 reaches this page only through counsel’s statement on the record in her own deposition, where the same sentence was read to her, and through Denise George. ⛔ The body of the letter, its signature block and the street, telephone and mail lines that follow are not reproduced here; the letter is set out on the Denise George page from the copy that page cites, and this page does not duplicate it or compare copies. ⚠ A second copy of this sheet stands at EFTA02809037 page_number 175 and is NOT compared. Appended [═══ TRANSCRIPT ═══] blocks stand on 3 rows of this document — page_number 10, 17 and 33 — and NOT on the sheet cited. [VISION] 0; [REDACTED] 0. ↩ ↩²
Letter from Epstein’s Virgin Islands counsel to the Attorney General, undated in this extraction and postdating 14 March 2019 by its own text, 3 rows in pages. https://epstein-data.com/EFTA00794358 . doc_type recorded letter; pdf_url NULL. This page cites page_number 0 (0-based, as found, located by string); the sheet’s own stamp is EFTA00794358. No served page number is asserted and no mapping is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the salutation; the opening paragraph as far as in person.; the February 2019 notice paragraph as quoted; the detention paragraph as quoted; and the editorial comment in full as quoted. ⚠ The comment is reproduced exactly as the extraction returns it, including Committed lell, S email and al, and is NOT mended. The commenter is not identified on the sheet and this page supplies no identification, states no class or position for any value the extraction does not carry, and says nothing about what any such value would be. ⛔ Nothing else on this sheet is reproduced or characterised. ⚠ Further versions of this letter stand in this release, including EFTA00794361, EFTA00794364 and EFTA00808897. This page cites ONE, compares none, characterises no difference, and builds nothing on the existence of the others. Block S over all 3 rows: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩²
SDNY News Clips, Thursday, March 5, 2020, a press compilation in a Southern District of New York mailbox, reproducing an article dated 3/4/2020. 21 rows in pages. https://epstein-data.com/EFTA00088057 . ⚠ doc_type recorded calendar, which it is not, and it was not used as a filter. pdf_url NULL. This page cites page_number 1 (0-based, as found, located by string); the sheet’s own stamp is EFTA00088058 and its own printed marking is 2. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes ONE sentence: the quotation beginning "The Attorney General intends to permit the release of Estate assets through in Virgin Islands Superior Court. ⛔⛔ NOTHING else on this sheet is reproduced, paraphrased, counted or characterised. The remainder of the article describes claimants against the Estate and is not touched; no claimant is named, numbered or described anywhere on this page. The sheet also carries an unrelated article about a correctional facility and nothing is taken from it. ⚠ CORRECTION TO THE DESK’S TRIAGE, which dated this 3 Mar 2020: the digest heads itself Thursday, March 5, 2020, the article it reproduces is dated 3/4/2020, and the article says the papers were filed Tuesday. This page gives all three and asserts no filing date of its own. ⚠ A second copy of this digest stands at EFTA00088078 page_number 2 and is NOT compared. Block S on this sheet: victim present — it is the compensation-fund reporting described above; jane doe 0; minor 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩²
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' REPLY BRIEF IN SUPPORT OF MOTION TO INTERVENE, Superior Court of the Virgin Islands, Division of St. ⟦—⟧ and St. John, Ghislaine Maxwell v. Estate of Jeffrey E. Epstein et al., Case No. ST-20-CV-155, court-stamped FILED September 22, 2020. 17 rows in pages. https://epstein-data.com/EFTA02822271 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 0 and 14 (0-based, as found, located by string); their own stamps are EFTA02822271 and EFTA02822285, and the second prints its own marking 15. No mapping between those numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 0 this page takes the caption title and the phrases as of right and by permission. From page_number 14 it takes Dated: September 22. 2020 and the signature block as far as Chief Deputy Attorney General, and nothing after it. ⚠ September 22. 2020 is the extraction’s rendering and is NOT mended. ⛔⛔ A street line, a mail field and a telephone field with an extension follow that signature block and NONE is reproduced, described or located. The sheet at page_number 16 carries mail addresses for opposing counsel and nothing is taken from it. ⛔ The extraction does not carry her surname in that block; nothing is supplied. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩² ↩³
Signature sheet of the Government of the Virgin Islands’ Second Amended Complaint against the Estate of Jeffrey Epstein, inside a 253-row container. 253 rows in pages, counted directly. https://epstein-data.com/EFTA00162121 . doc_type recorded court.filing; pdf_url NULL. This page cites page_number 241 (0-based, as found, located by string); the sheet’s own stamp is EFTA00162362 and it prints its own marking Page 76 of 76. The served header on that sheet is damaged in the extraction and is not reproduced or reconstructed. NO MAPPING between those numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes the signature block from RESPECTFULLY SUBMITTED, as far as Assistant Attorney General, and nothing after it. ⚠ Dated: February 10.2021 is the extraction’s rendering and is NOT mended. ⛔⛔ A street line, a mail field and a telephone field with an extension follow that block and NONE is reproduced, described or located; the mail field does not belong to the subject of this page and nothing whatever is said about it. ⚠ This sheet is also cited on Denise George; it is cited here for her own signature and title, which is new to this page. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩
Probate record, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 / ST-2019-PB-00080, Superior Court of the Virgin Islands — the Government’s Notice of Appeal & Petition for Review of Magistrate Judge's Orders of March 17, 2021 together with the order it appeals. 12 rows in pages. https://epstein-data.com/EFTA02821562 . doc_type recorded court.filing_state; pdf_url populated. This page cites page_number 2 and 6 (0-based, as found, located by string); their own stamps are EFTA02821564 and EFTA02821568, and they print their own markings Page 3 of 4 and Page 2 of 3. NO MAPPING between those numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 2 this page takes: the second ISSUES PRESENTED FOR REVIEW item in full as quoted; Dated: March 17, 2021; and the signature block as far as Chief Deputy Attorney General. From page_number 6 it takes: the ORDERED clause reciting the Emergency Motion to Immediately Freeze All Estate Assets and Cash on Hand as quoted, STOPPING at on February 4, 2021; and the sentence For these reasons, the Court will use its inherent authority to strike the Emergency Motion and all responses thereto from the record. ⛔⛔ The order’s recitation continues into a numbered list of joinders by other claimants and their counsel, including a pseudonymous claimant. NOTHING of that list is reproduced, paraphrased, counted or characterised here and no claimant is named. The quotation stops before it. ⛔ A street line, a mail field and a telephone field with an extension follow the signature block on page_number 2 and none is reproduced. ⛔ The extraction does not carry her surname at any of the points quoted and nothing is supplied. ⚠ The order’s reasoning sentence on page_number 6 is printed with two fragments out of column position in this text layer; this page does NOT quote that sentence and paraphrases the standing ground instead, taking the quoted framing of the issue from her own filing at page_number 2. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩²
ORDER of the Superior Court of the Virgin Islands, Case No. ST-2021-RV-00005, originating case ST-2019-PB-00080, in the matter of the Estate of Jeffrey E. Epstein. 7 rows in pages. https://epstein-data.com/EFTA02821591 . doc_type recorded memo, which it is not; pdf_url populated. This page cites page_number 6 (0-based, as found, located by string); the sheet’s own stamp is EFTA02821597. No served page number is asserted. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the two ORDERED clauses as quoted (affirmance of the two magistrate orders, and Petitioner's Appeal is DISMISSED WITH PREJUDICE); the direction to Chief Deputy Attorney General, Carol and no further; and the date line DATED: February P9 , 2022. ⚠⚠ The day in that date line is NOT readable in this extraction. It is quoted as it stands, no day is supplied, and the string is NOT mended. ⛔ The extraction does not carry her surname at that point and nothing is supplied. Other counsel named in the same direction are not reproduced here. ⛔ The clerk’s and the judge’s attestation lines are damaged in the extraction and are not quoted, reconstructed or described. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩ ↩²
United States Virgin Islands Department of Justice press release, U.S. Virgin Islands Attorney General Settles Sex Trafficking Case Against Estate Of Jeffrey Epstein And Co-Defendants For Over $105 Million, dated on the captured page December 1, 2022, captured from the department’s website and filed in the bank action as Exhibit 5, Case 1:22-cv-10904-JSR Document 61-5 Filed 02/28/23. 8 rows in pages. https://epstein-data.com/EFTA02806313 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 3 and 4 (0-based, as found, located by string); their own stamps are EFTA02806316 and EFTA02806317. ⚠⚠ the stamps EFTA02806314 through EFTA02806317 ARE SHEET STAMPS PRINTED INSIDE THIS DOCUMENT AND ARE NOT DOCUMENTS: SELECT efta_number FROM documents WHERE efta_number BETWEEN 'EFTA02806314' AND 'EFTA02806317' returns ZERO rows, verified for this page. NO MAPPING between stamp, served header and extraction row is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 3 this page takes TWO passages: the trust-fund sentence beginning The settlement terms require in full, and the clause The Estate has also agreed to wind down its business operations in the U.S. Virgin Islands and to provide documents to assist the Government's ongoing investigations. From page_number 4 it takes the passage beginning acknowledged the dedicated work of her extraordinary team as far as the law firm of Motley Rice., in which her title is given as Deputy Attorney General Carol ⟦—⟧, and the clause took office in May 2019. ⛔ The extraction does not carry the Attorney General’s surname at several points on those sheets, nor the surname of the Chief of the Civil Division; NEITHER is supplied, no class or position is stated for any value the extraction does not carry, and nothing is said about what any such value would be. ⛔⛔ page_number 5 of this document carries a media-relations telephone field and a mail field, and a site sidebar. NEITHER field is reproduced, described or located, and no claim is made about the sidebar’s date, the state of the site at capture, or anything the sidebar says — a question the desk’s triage raised and this page does not build on. ⚠ VERIFIED FOR THIS PAGE, and it closes a false constraint the desk recorded against itself: this document carries ZERO occurrences of thomas and ZERO of jacobs on all 8 of its rows, measured per row with instr(). No signature block of hers is in it. Appended [═══ TRANSCRIPT ═══] blocks stand on 1 row of this document — page_number 6 — and NOT on either sheet cited. [VISION] 0; [REDACTED] 0. ↩ ↩² ↩³ ↩⁴
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' WITHDRAWAL OF MOTION TO INTERVENE, Superior Court of the Virgin Islands, Ghislaine Maxwell v. Estate of Jeffrey E. Epstein et al., Case No. ST-20-CV-155, court-stamped FILED February 21, 2023. 3 rows in pages. https://epstein-data.com/EFTA02822416 . doc_type recorded court.filing_state; pdf_url populated. This page cites page_number 0 (0-based, as found, located by string); the sheet’s own stamp is EFTA02822416. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the caption title; the body paragraph in full as quoted; the three lines CAROL / ESQUIRE / ACTING ATTORNEY GENERAL with VIRGIN ISLANDS DEPARTMENT OF JUSTICE; Dated: February 21, 2023; and the title Assistant Attorney General from the signature line, which is another lawyer’s. ⚠ withdraws it, abovecaptioned and separatelyfiled are the extraction’s renderings and are NOT mended. The signing lawyer’s rendered name is damaged in this extraction and is NOT quoted, reconstructed or described, and the extraction does not carry that lawyer’s surname. ⛔⛔ THIS SHEET CARRIES AN APPENDED [═══ TRANSCRIPT ═══] BLOCK beginning at character offset 1,346 of 1,628. That block is an ADDED LAYER and NOT a producing party’s mark. EVERY quotation above is taken from ABOVE that line, and nothing below it is quoted, counted, characterised or treated as evidence of anything. A mail address stands inside that block and is not reproduced. ⛔ A street line, a mail field and a telephone field with an extension stand on this sheet below the signature and none is reproduced, described or located. ⚠ The court’s name in the sheet’s own header is damaged in the extraction and is not reproduced or reconstructed. [VISION] 0; [REDACTED] 0. ↩ ↩²
Government of the Virgin Islands’ opposition to a motion to intervene, Case 1:22-cv-10904-JSR Document 364 Filed 05/13/24 Page 8 of 9. 9 rows in pages. https://epstein-data.com/EFTA02818986 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 7 (0-based, as found, located by string); the sheet’s own stamp is EFTA02818993 and it prints its own marking 5. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes FOUR lines: Dated: May 13, 2024, Respectfully submitted,, IAN S.A. CLEMENT, ESQ. and ACTING ATTORNEY GENERAL. ⛔ Nothing else on the sheet is reproduced or characterised, and this page makes no claim about who held the office at any time between the dates it gives. Block S: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩
Further excerpts of the same deposition, filed at Case 1:22-cv-10904-JSR Document 245-24 Filed 07/25/23. 3 rows in pages. https://epstein-data.com/EFTA02812460 . ⚠ doc_type recorded court.filing for this document and transcript.deposition for a parallel copy — the same transcript content is typed two different ways in this production, which is one of six demonstrations on this page that doc_type is not a filter. pdf_url populated. This page cites page_number 2 (0-based, as found, located by string); its stamp is EFTA02812462, its served header reads Page 3 of 3 and the transcript’s own internal page number is 49. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. ⚠⚠ The line-number lift and the READING-ORDER WARNING in the depo1 footnote apply, and this sheet is one of the worst-ordered in the set. From this sheet this page takes FIVE contiguous runs and no more: exchange between Jeffrey Epstein and somebody named Cecile de Jongh on March 17th of 2019, which is three; days after the letter that we've been looking at.; Do you know Cecile de Jongh? A. I know of Cecile de Jongh. I don't personally know Cecile de Jongh.; A. I know she was -- she's the --; and she's Governor De Jongh's wife. Q. Okay. And were you aware that Ms. De Jongh worked for Mr. Epstein? A. I think everyone in the Virgin Islands knew that. — together with the single word No., which stands at the foot of the sheet among displaced fragments of the question it answers. ⚠ The clause And this is the E-mail stands between the first two runs in the extraction, and fragments of the final question stand around the word No.; NOTHING is spliced, reordered or completed, and the page says so at each point. ⛔ The extraction does not carry her surname in the question prefix on that sheet and nothing is supplied. ⛔ Nothing from the exhibit itself is reproduced, paraphrased or characterised; its contents are not before this page. ⚠ A further copy of this transcript excerpt stands at EFTA02814515, page_number 1 to 3. Under the copy rule this page cites ONE, sets no copy beside another, characterises no difference between them and builds nothing on the fact that both exist. Block S over all 3 rows: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩
Excerpts of the 30(b)(6) deposition of the Virgin Islands Department of Justice’s sex-offender registry manager, taken July 18, 2023, filed as Case 1:22-cv-10904-JSR Document 284-38 Filed 08/14/23. 39 rows in pages. https://epstein-data.com/EFTA02815623 . doc_type transcript.deposition; pdf_url populated. This page cites page_number 32 (0-based, as found, located by string); the sheet’s own stamp is EFTA02815655, its served header reads Page 33 of 39, and the transcript’s own internal page number is 420. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; the witness’s own name is rendered SHAM A. PINNEY in the running header of this sheet, that rendering is NOT mended, and it is not reproduced in the body of this page. ⚠⚠ The line-number lift and the READING-ORDER WARNING in the depo1 footnote apply. From this sheet this page takes THREE contiguous runs: Anola Duncan was the AG's secretary. Quincy McRae was the criminal -- the chief over the criminal division.; So Carol must have been the acting AG, and Kevin Augustin was the -- Kevin Augustin was the investigator for SORNA.; and the question Q. Do you know what, if any, follow-up they did in response to you passing this information along?, together with the contiguous part of the answer, anything was done, followed up. I'm not sure if anything was done. It -- I wasn't aware of it. ⚠⚠ The words between the first two runs — in which the witness reads the subject’s given name off the list and observes that she does not see the Attorney General’s name on it — are printed OUT OF SEQUENCE in the extraction and are NOT quoted, spliced or reconstructed. The opening words of the answer (I am not sure if) stand below it, out of position, and are not joined to it. The desk’s triage quoted both passages as continuous. ⛔⛔ The question those answers respond to concerns an internal departmental distribution. NOTHING about the content, subject, recipients or date of that distribution is reproduced, paraphrased, counted or characterised on this page. ⛔ The extraction does not carry the subject’s surname at either point and nothing is supplied. ⚠ Tier: So Carol must have been the acting AG is the witness’s own inference from a list in front of her. It is recorded as that and nothing on this page rests on it. Block S on the sheet cited: every screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩
Deposition-topic schedule, Case 1:22-cv-10904-JSR Document 311-70 Filed 08/25/23 Page 8 of 18. 18 rows in pages. https://epstein-data.com/EFTA02817422 . doc_type recorded court.filing; pdf_url populated. This page cites page_number 7 (0-based, as found, located by string); the sheet’s own stamp is EFTA02817429 and it prints its own marking -7-. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes THREE topic lines: the final one in full as quoted, ending at Albert, where the sheet ends; and two clauses from the lines above it — as Attorney General for USVI under Governor Albert Bryan and as Attorney General for USVI under John de Jongh — cited only to show how the group is ordered. ⚠⚠ THE SHEET IS A TWO-COLUMN TABLE AND THE TEXT LAYER PRINTS THE TWO COLUMNS ONE AFTER THE OTHER RATHER THAN IN REGISTER. Six Department of Justice entries stand in the left column and six topic lines in the right; the pairing used on this page is POSITIONAL, it is an inference and is labelled one everywhere it appears, and nothing on this page about any period of service before 2019 rests on anything else. The corroboration stated in the body — that the titles in the adjacent lines match people the record names independently — is the whole of the support for it. ⛔ The extraction does not carry the surnames of three of the six people listed, including hers. NONE is supplied, no class or position is stated for any, and nothing is said about what any would be. ⛔ The remaining entries on this sheet concern other officials and are not reproduced beyond what is stated above. ⚠ A second copy of this schedule stands at EFTA02818510 page_number 7. This page cites ONE, compares none, and characterises no difference. Block S on the sheet cited: traffick 0, victim 0, every other screened term 0. [VISION] 0; [REDACTED] 0; appended-transcript blocks 0. ↩

tags	person, usvi, attorney-general, acting-attorney-general, usvi-department-of-justice, sex-offender-registration, epstein-estate, cico, jpmorgan-chase, leon-black, deposition, 2019, 2021, 2023
aliases	Carol Thomas-Jacobs, Carol Thomas-Jacobs, Esq., CAROL THOMAS-JACOBS, ESQ., Carol Thomas Jacobs, Carol T.

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