Epstein Data Wiki

Darren Indyke

Properties2
tagsperson, lawyer, new-york, virgin-islands, epstein-estate
aliasesDarren K. Indyke, Darren K. Indyke PLLC, Darrin Indyke, Indyke, Darren

24 min read

PracticeDarren K. Indyke, PLLC, New York12
EducationColgate, 1986; Cornell Law School, 1991 (as reported)3
Role for EpsteinPersonal and corporate attorney, from the 1990s until Epstein’s death in 201945
Estate rolesCo-executor, Estate of Jeffrey E. Epstein (Probate No. ST-19-PB-80); co-trustee of The 1953 Trust67

Darren K. Indyke is a New York lawyer who acted as Jeffrey Epstein’s personal and corporate attorney and who, with the accountant Richard D. Kahn, was appointed co-executor of Epstein’s estate and co-trustee of The 1953 Trust under the will Epstein signed two days before his death.68 A memorandum written after the February 2016 enactment of International Megan’s Law, recommending that Epstein’s compliance with sex-offender travel-reporting requirements be investigated, told its readers that “One single attorney, Darren Indyke, represents all of these companies.”5 Indyke held signature authority on bank accounts of more than a dozen Epstein companies and appears in bank compliance records as an officer of several of them.910 He is a defendant, in his capacity as executor and trustee, in the U.S. Virgin Islands government’s civil racketeering action and in numerous civil suits brought against the estate by women alleging abuse by Epstein.111213 In a December 2008 email an Assistant U.S. Attorney in the Southern District of Florida wrote that Indyke “was a subject of our investigation and refused to comply with a grand jury subpoena.”14 He has retained criminal defence counsel; he and his lawyers have declined or not responded to press requests for comment on the matters described here.15416

Practice and role for Epstein

The Daily Beast reported in August 2020 that Indyke grew up on Long Island, graduated from Colgate in 1986 and from Cornell Law School five years later, and spent about four years at the New York firm Gold & Wachtel, which had represented Epstein at least as far back as 1988.17318 The same account drew on the memoir of the lawyer Brad Edwards, who litigated against Epstein for years and who characterised Indyke as a fixer rather than a litigator with a single client; The Daily Beast reported that Indyke and his criminal defence lawyer did not return its messages.194

A Palm Beach Police Department incident report of September 2006 recorded that a telephone number that had called a witness in the department’s Epstein investigation was registered to a corporation at 457 Madison Avenue in New York, and that “Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent”; the detective listed El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group at that address.20 The same memorandum, which sets out the travel-notification duties created by International Megan’s Law and recommends steps to test Epstein’s compliance, states that each of his companies should be subpoenaed because they have no Fifth Amendment protection, and that “One single attorney, Darren Indyke, represents all of these companies. He is located in New York.”5 It listed The C.O.U.Q. Foundation, East Broadway Partners LLC, E Management New York, LLC, 116 East 65th Street, LLC, New York Strategy Group, LLC and the New York Strategy Group, LLC 401K Plan.5

A one-page organisation chart for Epstein’s Virgin Islands operation lists an administration section under Southern Trust Company and a second section headed “HBRK is…” under which “Darren Indyke, Esq.” is named as Attorney, Richard Kahn as Project Manager and Mark Tollison as Estate Manager.21 FedEx invoices billed to Epstein accounts in late 2002 show “DARREN INDYKE, NYSG LLC, 457 Madison Ave” as the sender of overnight shipments to law firms and other recipients in the United States and Europe.22 JPMorgan Chase private-banking statements for Epstein’s personal checking account in 2010 were addressed to “Jeffrey E Epstein, Attn Darren K Indyke” at Indyke’s office at 301 East 66th Street, Suite 10B.23 A Washington law firm’s June 2016 engagement letter retaining counsel for Epstein’s deposition in Giuffre v. Maxwell was addressed to Epstein care of Darren K. Indyke, PLLC, 575 Lexington Avenue, and recorded that the scope of work had been discussed with Indyke.1

Corporate offices and bank authority

Indyke was the incorporator of The C.O.U.Q. Foundation, Inc., whose Delaware certificate of incorporation was filed on 16 March 1998 and names him and Epstein and Ghislaine Maxwell as the initial board of directors.24 A unanimous written consent dated 1 March 2012 records that Indyke, Cecile de Jongh and Jeanne Brennan had resigned on 29 February 2012 from all offices of The J. Epstein Virgin Islands Foundation, Inc., also known as Enhanced Education, and that Epstein was appointed president and Indyke vice-president.25 A background report compiled on Epstein in December 2018 lists Indyke as secretary of Zorro Development, and gives the corporate and principal office address of Nine East 71st Street Corporation as care of Darren K. Indyke, Esq., 575 Lexington Avenue.2627 Deutsche Bank’s 2018 periodic review of the Southern Financial relationship recorded Indyke as an authorised signatory of Southern Financial, LLC and as vice-president and secretary of Southern Trust Company, Inc.10 In February 2015 Indyke wrote to Deutsche Bank that the trustees of the Butterfly Trust had changed; a bank officer read the attachment as showing that “both Rich and Darren have officially resigned as trustees.”28

First Bank’s response of 9 March 2020 to a grand jury subpoena lists Indyke as an authorised signature on commercial accounts of Financial Trust Company, Inc., Jeepers Inc., Lafayette Contractors LLC, F T Real Estate Inc., Michelle’s Transportation Co LLC, Southern Country International Ltd, Gratitude America, Ltd, Great St Jim LLC, Nautilus, Inc., Maple, Inc., Cypress, Inc., Laurel, Inc., Southern Trust Company, Inc., LSJE LLC, Freedom Air Petroleum LLC, Island Grounds Inc. and Poplar, Inc.9 In March 2007 Indyke wrote to a Bear Stearns executive, Ira Zicherman, certifying that Financial Trust Company, Inc. was the sole stockholder of Jeepers, Inc. and that Epstein was the sole stockholder of Financial Trust Company and so the beneficial owner of Jeepers.29

An appendix to a WilmerHale letter of 2 September 2020, produced with JPMorgan Chase’s response to grand jury subpoenas, indexes accounts by their associated individual; “Darren K Indyke PLLC” and two “Darren K Indyke PLLC ATTY TR Acct-Client Funds” accounts appear under the heading “JE DM” accounts, which the letter describes as associated with Epstein’s overall relationship with the firm while noting that Epstein “did not necessarily have control of or access to those accounts.”30 A JPMorgan suspicious activity report covering 4,725 wire transactions totalling $1,081,819,653 between 1 October 2003 and 22 July 2019 names, among the individuals and entities involved, Darren K. Indyke, “DARREN K INDYKE ATORNEY AT LAW” and “DARREN K INDYKE PLLC”; the narrative states that the filing was made to report wire activity consistent with negative media involving alleged sex trafficking of minors and allegations that Epstein misappropriated funds, the use of multiple accounts, a high-risk jurisdiction and Epstein’s status as a politically exposed person.31

The 2008 Florida case and work release

A memorandum dated 25 September 2008, marked privileged and attorney work product, headed “WRONGDOING BY ATTORNEYS IN THE EPSTEIN CRIMINAL MATTER” and addressed to file from Darren K. Indyke, sets out numbered complaints against members of Epstein’s defence team and records assessments of the prosecutors handling the case.32 It is a mixed-voice draft: it carries Indyke’s name as author and refers to Epstein in the third person as “JEE,” but several passages are written in Epstein’s own first person, as in “Alan never told JEE about the probation option, but told me that Recarey would try to violate me,” so it cannot be read as a record of Indyke’s words throughout.32 Indyke did not respond to requests for comment when the New York Times reported in 2019 on his work for Epstein’s trusts and entities, and did not return messages left by The Daily Beast in 2020.154

On 3 December 2008 an Assistant U.S. Attorney in the Southern District of Florida wrote to colleagues about Epstein’s work-release placement, noting that Epstein had listed himself as president of the Florida Science Foundation and Indyke, its vice-president, as his supervisor, and that Indyke was in New York rather than Florida; of Indyke the prosecutor added, parenthetically, that he “was a subject of our investigation and refused to comply with a grand jury subpoena.”14 Indyke did not respond to requests for comment when the New York Times reported on his role in Epstein’s entities in August 2019, and his lawyers declined to comment when the Wall Street Journal reported on claims against the estate that month.1516 On 9 December 2008 the same office wrote to the Palm Beach Sheriff’s Office Corrections Division setting out what it called inaccuracies and omissions in Epstein’s work-release file; the letter was re-sent by hand on 11 December 2008.3334 It states that Indyke was listed in the file as Epstein’s supervisor, signed the Alternative Custody Unit Program Agreement as Epstein’s employer, and supplied a two-sentence work schedule stating that Epstein’s “duties will require him to work six days a week, Monday through Saturday, at the Foundation’s office located at 250 S. Australian Avenue, Suite 1404, West Palm Beach, Florida from the hours of 8:00 A.M. to 8:00 P.M.”34 The letter says that the C.O.U.Q. Foundation’s returns for 1999 through 2006, each signed under penalty of perjury by Epstein or by Indyke, showed Epstein working one hour a week for the foundation without compensation, that Indyke did not disclose this, and that as vice-president of the Florida Science Foundation and Epstein’s subordinate at Financial Trust Company he could neither supervise Epstein nor be relied on to report violations.34 In an entry dated 28 July 2009 Epstein’s Florida probation file records: “DEFT SUBMITTED PROOF OF EMPLOYMENT - CERTIFICATE OF INCORPORATION FOR THE C.O.U.Q. FOUNDATION AND FINANCIAL TRUST COMPANY, INC.”35

Sex-offender registration and travel

On 21 May 2012 Indyke wrote from Darren K. Indyke, PLLC to Detective Deborah Anaya of the Santa Fe County Sheriff’s Office, recalling that the New Mexico Department of Public Safety had determined that Epstein was not required to register in New Mexico, and stating that Epstein’s permanent residence was in the U.S. Virgin Islands but that he maintained a home in Santa Fe County “that he visits (albeit very infrequently)” and had registered with the sheriff in an effort to comply with federal SORNA requirements.2 Seven emails filed as an exhibit in Epstein’s 2019 federal bail litigation, dated between 25 July 2012 and 31 July 2015, show Epstein notifying Detective Anaya of his arrivals in and departures from New Mexico with Indyke copied on each; the emails carry a footer stating that the communication “is confidential, may be attorney-client privileged.”36

On November 7, 2014 Indyke filed a Freedom of Information Act request with U.S. Customs and Border Protection on Epstein’s behalf, seeking records created between November 1, 2013 and November 6, 2014 relating to inspections or examinations on Epstein’s arrival at or departure from a U.S. port of entry, and to his entry and exit.37 CBP logged it as CBP-2015-005069 and closed it as a partial grant.37 On January 13, 2015 the agency wrote that “[a] search of CBP databases produced records responsive to your Freedom of Information Act (FOIA) request CBP-2015-005069” and that the responsive records were “partially releasable”.38 One was closed as a duplicate, one as an improper request, and one was granted in part on 13 January 2015.37 Indyke also carried Epstein’s Freedom of Information Act appeal against the National Security Agency, which the Agency refused on 30 July 2014; that correspondence, and the Customs and Border Protection requests, are set out on Epstein’s own requests for records about himself.

Charities and the New York Attorney General

Reuters reported in March 2015 that the New York Attorney General’s Charities Bureau had written to Epstein’s foundation asking why it should be considered exempt from state registration requirements, after noting that the site jeffreyepstein.org described the foundation as based in both New York City and the U.S. Virgin Islands.39 According to that report Indyke replied on 10 February that the foundation did not engage in charitable activity in New York and that a contractor who had not been closely monitored had mistaken his Manhattan law office for a foundation office and put the information online: “I have addressed this with the contractor, who has removed any erroneous statements about the foundation being based in New York.”39 Reuters reported that Indyke did not respond to its requests for comment.39

Work for Maxwell and her entities

Asked in an April 2019 deposition in an unrelated New York slip-and-fall case who Darren Indyke was, Ghislaine Maxwell answered “He is a lawyer”; asked what his connection was with the limited liability company under discussion, Ellmax, she said “He helped create it” and “he was the lawyer”; and asked whether he had been referred to her, she said “He worked for a friend of mine,” identifying the friend as “A gentlemen called Mr. Epstein.”40 In January 2015 a Daily Mail correspondent put to Maxwell’s public-relations representative that records showed a property associated with her had been bought in 2000 by “Darren Indyke, a lawyer with long standing links to Jeffrey Epstein,” and asked who owned it; Maxwell forwarded the enquiry to Epstein under the subject “PROBLEM,” adding “PLSE TAKE A LOOK ASAP / this is unhelpful….”41 JPMorgan’s account index groups Ellmax, 116 East 65th St LLC, the Max Foundation and the Terra Mar Project under accounts associated with both “JE DM” and Maxwell.30 The Daily Beast reported that Indyke served as a trustee of Maxwell’s Max Foundation from 2001 to 2010, that he was listed as secretary of The Wexner Foundation in filings from 1998 to 2001 and in its tax forms through 2006, and that in about 2008 Abigail Wexner gave him power of attorney over a Manhattan condominium.17

Executor of the Epstein estate

Epstein’s will, dated 8 August 2019, appoints Indyke and Richard D. Kahn as executors, names Boris Nikolic as successor executor if either fails to qualify or ceases to act, directs that each executor be paid $250,000 on completion of probate and no other compensation, and leaves the residue of the estate to the trustees of The 1953 Trust, created under a trust agreement of the same date.6 Indyke and Kahn’s petition for probate is dated 15 August 2019 in counsel’s signature block, and they swore oaths of willingness to serve; the Superior Court of the Virgin Islands’ own received stamp on the first page of the petition reads 19 August 2019, and the court issued letters testamentary appointing them co-executors on 6 September 2019.642 The first quarterly accounting, dated 31 January 2020 and sworn by Indyke as co-executor, values the estate’s total assets at $628,330,500 as of 10 August 2019 and $634,797,047 as of 31 December 2019, both figures marked as pre-appraisal estimates.4344

On 14 November 2019 the co-executors moved the probate court for approval to retain Jordana Feldman, Kenneth Feinberg and Camille Biros to design and implement an Epstein Victims’ Compensation Program, and in a further filing said that seventeen suits involving twenty-six plaintiffs were then pending against the estate.42 A federal prosecutor’s summary of the probate docket in February 2020 records that the Virgin Islands Attorney General had written to the executors setting out demands for a compensation programme, among them that the estate cooperate with her investigations and that “The executors cannot play any role in establishing the victim compensation program or selecting its administrators.”45 The Guardian reported on 12 February 2020 that Attorney General Denise George had said in court documents that she planned to name Epstein’s lawyers as co-defendants and to contest the estate’s involvement in creating the compensation fund.46 The same report quoted the lawyer acting for the estate, Bennet Moskowitz, telling a hearing that “The attorney general for the Virgin Islands has decided for whatever reason to impede the program,” and the prosecutor’s summary recorded that he had not seen evidence of the executors’ response to the attorney general’s letter.4645

On 23 July 2020 the U.S. Attorney for the Southern District of New York wrote to counsel for Indyke and Kahn about the estate.7 The letter asks the trustees to confirm that the employment-continuity provision at section 2.5(B) of the 1953 Trust Agreement will not be used to suggest that any current or former employee who provides information to law enforcement will be retaliated against, asks whether any distribution has been made to Ghislaine Maxwell and for advance notice of any such distribution during her criminal case, and asks whether the co-executors take a position on privilege over materials seized in the Epstein investigation.7

Maxwell sued the estate, Indyke and Kahn as executors, and NES, LLC in the Superior Court of the Virgin Islands, seeking indemnification and advancement of expenses she said she had incurred in litigation and investigations by reason of her former employment by Epstein and his companies.47 The complaint alleges that Indyke, as executor, assured her that her legal fees would be paid, that she submitted a claim to the estate addressed to Indyke and Kahn by letter of 22 November 2019, and that “The Estate has not honored or even formally responded to Maxwell’s claim.”47 Those are the allegations of Maxwell’s own pleading and are unadjudicated; lawyers for Indyke and Kahn declined to comment when the Wall Street Journal reported on claims against the estate.4716

Litigation and investigations

The Government of the Virgin Islands filed a civil action under the territory’s Criminally Influenced and Corrupt Organizations Act on 15 January 2020, captioned Government of the U.S. Virgin Islands v. Indyke et al., Case No. ST-20-CV-14.11 Its first amended complaint names Indyke and Kahn in their capacities as executors of the estate and administrators of The 1953 Trust, together with the estate, the trust and several Epstein companies.12 In a filing of 1 September 2020 the government stated that Indyke and Kahn served respectively as secretary and treasurer of Great St. Jim, LLC and Nautilus, Inc., which it alleged had knowingly participated in the Epstein enterprise by providing the secluded properties used in it.48 Indyke is named in that action in his representative capacities rather than personally, and the estate’s lawyer said publicly that the attorney general was impeding the compensation programme.1246

A schedule attached to the first quarterly accounting lists the suits then pending against the estate; Indyke is named in each as executor, and in one as trustee of Epstein Interests and as a representative of the J. Epstein VI Foundation and the J. Epstein Virgin Islands Foundation, Inc.13 Cases in the schedule include Annie Farmer v. Darren K. Indyke, Richard D. Kahn, and Ghislaine Maxwell, 19-cv-10475 (LGS-DCF) (S.D.N.Y.); Katlyn Doe v. Darren K. Indyke and Richard D. Kahn, 1:19-cv-07771 (S.D.N.Y.); Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, 1:19-cv-10577; Jane Doe 15 v. Darren K. Indyke and Richard D. Kahn, 1:19-cv-10653; and Jane Doe v. Darren K. Indyke, Richard D. Kahn and Ghislaine Maxwell, 1:20-cv-00484 (S.D.N.Y.), filed on 22 January 2020.1349 The suits were filed in the Southern District of New York, New York state court, the Superior Court of the Virgin Islands, a Florida circuit court and Minnesota.13

In the 20-cv-00484 case the plaintiff’s responses to interrogatories propounded by Indyke and Kahn allege that Indyke telephoned her, and identify phone records from Indyke showing calls made by him to her; the allegations are unadjudicated, and Indyke did not return messages left by The Daily Beast, which reported on the case.504 On 20 August 2020 her counsel, Robert Glassman, wrote to Magistrate Judge Debra Freeman opposing the estate’s attempt to cancel Indyke’s deposition, then set for 26 August, and said that Indyke was being deposed “in both his personal capacity and as a co-executor of the Epstein Estate.”51 The Daily Beast reported that the court put the depositions of Indyke and Kahn on hold pending resolution of a stay sought by Maxwell, and that Indyke and his criminal defence lawyer did not return its messages.524

Statements and responses

The New York Times reported on 11 August 2019 that Indyke and Jeffrey Schantz, both described as longtime Epstein attorneys involved with his trusts and entities, had recently hired criminal defence lawyers, and that neither had responded to requests for comment.15 The Daily Beast reported in August 2020 that Indyke’s criminal defence lawyer was Marc Agnifilo and that neither returned its messages.4 The Wall Street Journal reported on 23 August 2019, in an article on claims against the estate, that “Lawyers for Mr. Indyke and Mr. Kahn declined to comment.”16

In a sworn statement to the Justice Department’s Office of the Inspector General on 22 September 2021, Epstein’s brother Mark Epstein questioned the executors’ decision not to bring a wrongful-death action, saying that if such a suit had succeeded “there could have been more money in the pot for the victims” and that “the executives chose not to do it.”53 He described Indyke as his brother’s “private attorney” who “worked for Jeff for a long time.”53 Indyke did not return messages left by The Daily Beast, which reported on his role as executor, and his lawyers declined to comment to the Wall Street Journal on claims against the estate.416

Indyke prepared a biographical statement about Epstein for Florida prosecutors around the time of the 2008 plea, describing financial support Epstein had given him; The Daily Beast quoted from it in 2020.1854

Coverage

  • Reuters, David Ingram, March 5, 2015.
  • New York Times, August 11, 2019; Wall Street Journal, August 23, 2019; The Guardian, February 12, 2020; The Daily Beast, August 30, 2020.

Footnotes

  1. Law Offices of Gregory L. Poe PLLC, engagement letter, June 1, 2016. https://epstein-data.com/EFTA01102153 ↩ ↩2

  2. Darren K. Indyke, PLLC to Detective Deborah Anaya, Santa Fe County Sheriff’s Office, May 21, 2012. https://epstein-data.com/EFTA01147516 ↩ ↩2

  3. The Daily Beast, August 30, 2020. https://epstein-data.com/EFTA00163119 p.10. ↩ ↩2

  4. The Daily Beast, August 30, 2020. https://epstein-data.com/EFTA00163119 p.7. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  5. Memorandum re Jeffrey Epstein, 2016. https://epstein-data.com/EFTA00098755 pp.1–2. ↩ ↩2 ↩3 ↩4

  6. Petition for probate, oath of willingness to serve and Last Will and Testament of Jeffrey E. Epstein dated August 8, 2019, Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I.). https://epstein-data.com/EFTA00027979 pp.1–4, 7, 11–12. ↩ ↩2 ↩3 ↩4

  7. U.S. Attorney, Southern District of New York, to counsel for Darren K. Indyke and Richard D. Kahn, July 23, 2020. https://epstein-data.com/EFTA00015838 pp.1–2. ↩ ↩2 ↩3

  8. Kate Briquelet and William Bredderman, The Daily Beast, “Jeffrey Epstein’s Right-Hand Mystery Men,” August 30, 2020. https://epstein-data.com/EFTA00163119 p.3. ↩

  9. First Bank response to grand jury subpoena, March 9, 2020. https://epstein-data.com/EFTA00065864 pp.1–4. ↩ ↩2

  10. Deutsche Bank 2018 periodic review of the Southern Financial relationship, August 2018. https://epstein-data.com/EFTA01421281 p.2. ↩ ↩2

  11. Complaint, Government of the U.S. Virgin Islands v. JPMorgan Chase Bank, 22-cv-10904 (JSR), April 12, 2023, citing Government of the U.S. Virgin Islands v. Indyke et al., Case No. ST-20-CV-14 (Super. Ct. V.I. Jan. 15, 2020). https://epstein-data.com/EFTA00145666 p.2. ↩ ↩2

  12. Government of the United States Virgin Islands, first amended complaint. https://epstein-data.com/EFTA00018778 pp.2–3. ↩ ↩2 ↩3

  13. Schedule G, civil claims and lawsuits, first quarterly accounting. https://epstein-data.com/EFTA00082467 pp.14–16. ↩ ↩2 ↩3 ↩4

  14. Assistant U.S. Attorney, Southern District of Florida, email of December 3, 2008. https://epstein-data.com/EFTA01657851 p.2. ↩ ↩2

  15. Emily Steel, Matthew Goldstein, Steve Eder and David Enrich, New York Times, “Jeffrey Epstein’s Opaque Finances Could Become Focal Point for Investigators,” August 11, 2019. https://epstein-data.com/EFTA00172288 p.4. ↩ ↩2 ↩3 ↩4

  16. Nicole Hong, Wall Street Journal, “Jeffrey Epstein’s Death Creates Legal Morass for His Accusers,” August 23, 2019, reproduced in SDNY news clips. https://epstein-data.com/EFTA00069870 pp.10–12. ↩ ↩2 ↩3 ↩4 ↩5

  17. The Daily Beast, August 30, 2020. https://epstein-data.com/EFTA00163119 p.9. ↩ ↩2

  18. The Daily Beast, August 30, 2020. https://epstein-data.com/EFTA00163119 p.11. ↩ ↩2

  19. The Daily Beast, August 30, 2020. https://epstein-data.com/EFTA00163119 p.13. ↩

  20. Palm Beach Police Department incident report 1-05-000368, narrative of September 6, 2006. https://epstein-data.com/EFTA01333248 p.27, cited for the corporate-registration passage only. ↩

  21. Organisation chart, Epstein Virgin Islands operation. https://epstein-data.com/EFTA00003149 ↩

  22. FedEx invoices to Epstein accounts, November–December 2002. https://epstein-data.com/DOJ-OGR-00015310 pp.11, 82, 97. ↩

  23. JPMorgan Private Checking statement for Jeffrey E. Epstein, period February 27 – March 31, 2010. https://epstein-data.com/EFTA01483144 ↩

  24. Certificate of incorporation of The C.O.U.Q. Foundation, Inc., filed in Delaware March 16, 1998, in Epstein’s Florida probation file. https://epstein-data.com/EFTA00181807 pp.403–404. ↩

  25. Unanimous consent in lieu of meeting of the board of trustees of The J. Epstein Virgin Islands Foundation, Inc. (a/k/a Enhanced Education), dated as of March 1, 2012. https://epstein-data.com/EFTA01424496 pp.3–4. ↩

  26. Individual background report on Jeffrey Epstein, December 6, 2018. https://epstein-data.com/EFTA00101560 p.15. ↩

  27. Individual background report on Jeffrey Epstein, December 6, 2018. https://epstein-data.com/EFTA00101560 p.67. ↩

  28. Deutsche Bank internal email chain re Butterfly Trust, February 3–10, 2015. https://epstein-data.com/EFTA01456686 ↩

  29. Darren K. Indyke to Ira Zicherman, Bear Stearns, March 30, 2007. https://epstein-data.com/EFTA00038693 ↩

  30. WilmerHale to the U.S. Attorney’s Office, September 2, 2020, and Appendix A. https://epstein-data.com/EFTA00096342 pp.1, 4–5. ↩ ↩2

  31. JPMorgan Chase suspicious activity report narrative. https://epstein-data.com/EFTA01648787 p.1. ↩

  32. Memorandum to file from Darren K. Indyke, “Wrongdoing by Attorneys in the Epstein Criminal Matter,” September 25, 2008. https://epstein-data.com/EFTA00727491 pp.1–4. ↩ ↩2

  33. U.S. Attorney’s Office, Southern District of Florida, to Palm Beach Sheriff’s Office Corrections Division, December 9, 2008, the version sent by mail. https://epstein-data.com/EFTA01660001 pp.2–3. ↩

  34. U.S. Attorney’s Office, Southern District of Florida, to Captain David Sleeth, Palm Beach Sheriff’s Office Corrections Division, December 11, 2008, the hand-delivered version, which softens some of the December 9 wording. https://epstein-data.com/EFTA00208423 pp.2–3. ↩ ↩2 ↩3

  35. Florida Department of Corrections offender contact/comment summary, entry of July 28, 2009. https://epstein-data.com/EFTA00181807 p.109. ↩

  36. Exhibit B, United States v. Epstein, 19-cr-00490 (RMB), filed July 17, 2019. https://epstein-data.com/DOJ-OGR-00000458 pp.2–8. ↩

  37. U.S. Customs and Border Protection Freedom of Information Act log row and the text of the request as filed. https://epstein-data.com/DOJ-OGR-00027690 p.2. ↩ ↩2 ↩3

  38. U.S. Customs and Border Protection to Darren K. Indyke, January 13, 2015. https://epstein-data.com/DOJ-OGR-00027690 p.4. ↩

  39. David Ingram, Reuters, “Exclusive: New York attorney general seeks information on financier Epstein’s philanthropy,” March 2015. https://epstein-data.com/EFTA01363905 . The printout runs to four pages and each page is filed as its own single-page run; everything cited here is on this one. The “Page 2 of 4” printed in its header is the newspaper’s pagination and is not a page of this document. ↩ ↩2 ↩3

  40. Deposition of Ghislaine Maxwell, April 9, 2019, excerpted at page 25 of the transcript. https://epstein-data.com/EFTA00011365 p.8. ↩

  41. Ghislaine Maxwell to Jeffrey Epstein, January 9, 2015, forwarding an enquiry from a Daily Mail correspondent to her public-relations representative. https://epstein-data.com/EFTA00699032 ↩

  42. Co-executors’ request for immediate hearing regarding expedited motion for establishment of a voluntary claims resolution program, Probate No. ST-19-PB-80. https://epstein-data.com/EFTA00100674 pp.1–2. ↩ ↩2

  43. First quarterly accounting, Estate of Jeffrey E. Epstein, covering August 10 to December 31, 2019, dated January 31, 2020. https://epstein-data.com/EFTA00082467 pp.1–2. ↩

  44. Sworn statement of Darren K. Indyke, co-executor, first quarterly accounting. https://epstein-data.com/EFTA00082467 p.3. ↩

  45. Assistant U.S. Attorney’s summary of Epstein probate developments, February 20, 2020, in an email chain of May 28, 2020. https://epstein-data.com/EFTA00087321 pp.2–3. ↩ ↩2

  46. Edward Helmore, The Guardian, “Epstein’s lawyers in dispute with Virgin Islands over settlements with victims,” February 12, 2020, reproduced in SDNY news clips. https://epstein-data.com/EFTA00087321 p.3. ↩ ↩2 ↩3

  47. Ghislaine Maxwell v. Estate of Jeffrey E. Epstein, Darren K. Indyke, Richard D. Kahn and NES, LLC, complaint, Superior Court of the Virgin Islands. https://epstein-data.com/EFTA00076593 pp.1–6. ↩ ↩2 ↩3

  48. Government of the United States Virgin Islands, motion filed September 1, 2020 in Giuffre v. Maxwell, 15-cv-07433 (LAP). https://epstein-data.com/EFTA00073260 p.3. ↩

  49. David Boies to Hon. Debra C. Freeman, May 18, 2020, Annie Farmer v. Darren K. Indyke, Richard D. Kahn, & Ghislaine Maxwell, 19-10475-LGS-DCF (S.D.N.Y.). https://epstein-data.com/DOJ-OGR-00019237 p.81. ↩

  50. Plaintiff’s response to first set of interrogatories, Jane Doe v. Indyke, Kahn and Maxwell, 1:20-cv-00484 (S.D.N.Y.). https://epstein-data.com/DOJ-OGR-00015259 pp.2–3. ↩

  51. Robert Glassman, Panish Shea & Boyle, to Hon. Debra C. Freeman, August 20, 2020, Doe v. Indyke, 1:20-cv-00484-JGK-DCF, Doc. 71. https://epstein-data.com/EFTA02752289 pp.1–2. ↩

  52. The Daily Beast, August 30, 2020. https://epstein-data.com/EFTA00163119 p.6. ↩

  53. Sworn statement of Mark Epstein, U.S. Department of Justice Office of the Inspector General, September 22, 2021, OIG case 2019-010614. https://epstein-data.com/EFTA00113460 pp.15, 20–21. ↩ ↩2

  54. The Daily Beast, August 30, 2020. https://epstein-data.com/EFTA00163119 p.12. ↩

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