Denise George


Named on the documents as	`Denise George`, `Denise N. George`, `DENISE N. GEORGE, ESQ.`, `Attorney General Denise George`, and — in Epstein’s own Virgin Islands counsel’s hand, nine weeks before she took office — `Denise George-Counts`¹²
⚠ 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 be³
⛔ The bare surname is not her	`george` alone stands in 10,236 documents of this release, overwhelmingly as a given name. ⛔ No figure on this page comes from a bare-surname search. The initial form `"d. george"` is worse than useless: 31 sheets, and the desk’s triage attributed none of them to her. ⛔ Neither figure is ever cited here as a figure about her¹
⚠ The obvious search misses a third of her	`"denise george"` reaches 48 documents. `"general denise"` reaches 69. Essentially all of the uplift is primary court material from the JPMorgan action — her deposition index and the summary-judgment record. A desk that screened her on her full name alone would have lost her entire litigation footprint¹
⭐ Epstein’s side welcomed her appointment	28 March 2019. Epstein’s Virgin Islands counsel, Erika Kellerhals, to Epstein and Darren Indyke: `I'm still at the EDC but I am hearing we got a new AG = Denise George-Counts. I believe this is good news for us with respect to =he registration issues. I'll reach out to Governor again.` ⚠ `=he` is the extraction’s rendering and is not mended here. ➡ She was not installed as an adversary²
⭐⭐ She refused the waiver in her own hand, as a nominee	2 June 2019. Over her own signature as `Attorney General Nominee`: `In this particular case, I have not been presented with any documentation of such proof, nor does the V1D0J have any record of such documentation ever having been submitted to the VIDOJ.` And: `Until this review is completed, the Department is requiring that the current terms of Mr. Epstein's travel—both internationally and nationally—be strictly adhered to.` Primary. In her hand. Not her later account of herself⁴
⭐ What Epstein’s lawyers told her the Virgin Islands already knew	30 April 2019. Epstein’s counsel, pressing her to restore the old reporting terms: `the USVIDOJ has been aware of Mr. Epstein's location every single day of his lift without exception for the past ten (1(I) years.` ⚠ `lift` and `(1(I)` are the extraction’s renderings and are not mended. ➡ That is Epstein’s own lawyers’ written characterisation of the Department she had just inherited⁵
⛔ The obvious story is wrong about 2019	12 July 2019. Three days before she is quoted saying anything else about him, she explained to the Virgin Islands Daily News why her office had not investigated Epstein: `"Something has to trigger an investigation," said V.I. Attorney General Denise George.` … `"It's not based on that type of hearsay, or news reports from another jurisdiction," George said.` She is not a crusading prosecutor in 2019. She is a public sceptic of investigating him⁶
⭐ And the bank used exactly that against her government	24 July 2023. JPMorgan’s statement of undisputed facts: `Former Attorney General Denise ⟦—⟧ similarly testified that she couldn't rely on "news reports," "rumor" or "innuendo" to initiate an investigation into Epstein. Ex. 282 at 167:3-170:3.` ➡ Her own sworn deposition became the bank’s defence against the territory she had served⁷
⭐ Both sides cited the same lines of her deposition and read them opposite ways	JPMorgan cites `Ex. 282 at 167:3-170:3` for her inability to act on news reports. The Virgin Islands cites the identical page-and-line range, under its own exhibit numbering, for something else entirely: `The Government did not initiate an investigation following his arrest out of deference to the federal government. Ackerman Decl., Ex. 9 at 167:3-170:3, 172:6-174:3.`⁷⁸
⭐ 1 December 2022 — she thanked the Governor in writing	Her office’s settlement release: she `expressed gratitude to Governor Albert Bryan, who appointed her in 2019, for his commitment to ensure that justice was done.` Twenty-six days before she sued JPMorgan. Thirty days before she was told she was finished⁹
⭐⭐ The sequence	~27 December 2022 the JPMorgan action is filed · 31 December 2022 she is informed she is terminated (her account to the FBI) · 1 January 2023 the removal is reported, Government House on the record. ⛔ NO DOCUMENT IN THIS RELEASE STATES THAT ONE CAUSED THE OTHER. The newspaper drew the link; the Governor’s office refused to give reasons. Causation is a question on this page and stays one¹⁰¹¹
⛔⛔ A reason was refused four times on one page of newsprint	1 January 2023. (1) `Motta did not respond to a request for comment about Bryan's reasons for the decision` · (2) `Bryan, in a brief statement released late Sunday night, also gave no reason for termination.` · (3) `Motta could not immediately be reached for comment on reports circulating that the governor was unaware of ⟦—⟧ lawsuit against JPMorgan Chase and was displeased with her previous court actions against the Epstein estate.` · (4) `and Justice Department spokeswoman Sandra Goomansingh did not respond to requests for comment from The Daily News.` ➡ Four distinct refusals, three of them attributable to a named official. A refusal to give a reason is not a reason¹¹
⭐⭐ What the Governor said when he appointed her	2019, quoted in the article announcing her removal. `"In the Virgin Islands, due to the inherent structure of our government, the balance of power is sometimes tipped towards the executive branch. Over the years, this bias has allowed individuals to use the power of the executive branch to intimidate, suppress and to exact political retribution on individuals and on other branches of government..."` — and independence for the attorney general `"would help to restore the balance of power to the executive branch."` ⚠ The last clause is the extraction’s rendering and is not mended. ➡ The page sets his 2019 words beside his 2023 act and draws no conclusion from the juxtaposition¹¹
⚠ The only rationale that reaches the record arrives at two removes	2 October 2023, in her own complaint to the FBI: `Several reasons were provided to the press but a listed reason was that no attorney general was going to file anything without notifying the Governor.` ⚠ Measured: the phrase `notifying the governor` stands on exactly ONE sheet in the whole of this release — that one. No named official asserts it. Credible allegation, double-hearsay. Not a finding¹⁰¹²
⚠ The spine of the allegations is allegation-tier by the FBI’s own words	The FD-302 recording her account carries the Bureau’s standard legend: `This document contains neither recommendations nor conclusions of the FBI.` Everything she told the agent is written here as what she said, never as what happened¹⁰
⛔ Retaliation vocabulary is absent, and that was measured	*`retaliat` stands on 1,625 sheets of this release and on ZERO of the 127 sheets that name her. Invented control `zzqdenise` returns 0. ➡ Nobody in this release — not her, not the newspaper, not either party to the bank litigation — frames her removal as retaliation. The page does not supply the word**¹²
⚠ Not verified at the image	⛔ Every quotation on this page is read from the TEXT LAYER of the extracted corpus. No page image was opened. The local image store holds no file for any document cited here, and this pass did not go to the site server. ⚠ CORRECTION TO THE DESK’S TRIAGE: a public PDF address IS recorded for 28 of the 88 documents in the union set, including most of the strongest ones. Image verification is therefore REACHABLE and merely OUTSTANDING — it is not impossible³
What the record does not contain	Any document stating a cause for her removal · any letter, notice or order of termination · any statement by her about the removal in her own words at the time · any transcript of her deposition itself, only excerpts and index lines · any document from the ten months between the February 2020 lien correspondence and the February 2021 amended complaint¹³
Covered elsewhere on this wiki	Epstein’s USVI sex-offender registration · The Epstein estate · JPMorgan Chase · JPMorgan’s due diligence on Epstein · Southern Trust Company · Erika Kellerhals · Darren Indyke · Richard Kahn · Cecile de Jongh · Brad Edwards · Jes Staley · Jeffrey Epstein

Denise George was Attorney General of the United States Virgin Islands. Her own office’s press release says she took office in May 2019; the article reporting her removal says the Governor appointed her in 2019; she was still signing as Attorney General Nominee as late as 17 June 2019. She brought the territory’s civil enforcement action against the Estate of Jeffrey Epstein, settled it on 1 December 2022 for $105 million in cash plus one half of the proceeds from the sale of Little St. James, filed suit against JPMorgan Chase in the Southern District of New York at the end of that December, and was told she was terminated days later.⁹¹¹⁴

⛔ This page does not establish why she was fired, and it does not try. A prosecutor removed days after suing a bank is the exact place a desk invents a finding. What this release carries is a sequence, a newspaper’s own juxtaposition of two of its elements, four separate refusals to give a reason, and one rationale reaching the record at two removes through the press. It does not carry a statement of cause from anybody with the authority to give one. That is written below as a question and is left as a question.

⛔⛔ And the familiar story about her is wrong about 2019. The shape most readers will expect — a prosecutor who went after Epstein and was destroyed for it — is contradicted by her own documented conduct in the first summer of her tenure. In July 2019 she publicly explained why her office had not investigated him. In February 2020 she publicly damped speculation that Virgin Islands officials bore broader responsibility. Four years later JPMorgan Chase put her sworn testimony to that effect at the centre of its defence against her own government, and the Virgin Islands did not dispute it. The documents that most complicate the story are the ones in her own hand.⁶¹⁴⁷⁸

⚠ The genuinely independent act in this file is earlier, smaller, and better evidenced than the lawsuits. Nine weeks before she took office, Epstein’s Virgin Islands counsel told Epstein that the incoming Attorney General was good news for us with respect to =he registration issues. Two months into the job she refused him the travel-reporting waiver, in writing, over her own signature. That refusal ran against the expectation held of her by the people who wanted it granted, and unlike almost everything else on this page it is documented from the opposing side’s own litigation file.²⁴⁵

The name, and the two search traps

Measured for this page against the full-text index of this release, with invented controls. Counts in sheets and in documents. Every figure below was re-run here and every one reproduced the desk’s triage exactly.

form of the name	sheets	documents
`"general denise"`	71	69 — ⭐ the highest-reach form, and it is not her full name
`"denise george"`	69	48
`"attorney general denise"`	62	60
`"denise n. george"`	23	14
`"george counts"`	1	1
⛔ `"d. george"`	31	27 — ⛔ A PURE TRAP. The desk’s triage opened all 31 and attributed NONE of them to her. Never cited as a figure about her
⛔ bare token `george`	14,444	10,236 — ⛔ NOT A FIGURE ABOUT HER. Reported only to size the trap
invented controls `zzqdenise`, `zzqgeorge`	0	0
union of the attributable forms, as re-run here	127	88

➡ The uplift from "denise george" (48 documents) to "general denise" (69) is almost entirely primary court material — the JPMorgan summary-judgment record, the exhibit declarations, and the index line naming her deposition. ⚠ The reason is a property of the extraction and nothing more: across the EFTA028… litigation family the text layer available on this desk carries the honorific construction and stops. ⛔ This page makes no claim whatever about why, states no position, field, class or adjacent content, and reconstructs nothing. It is reporting the behaviour of its own instrument.

⚠ "george-counts" hides no population. The index tokenizer splits on the hyphen, so the base phrase already matches the hyphenated rendering, and the inverted phrase "george counts" reaches one sheet. ✓

⚠ The union is a floor, not a count. It is a floor because the honorific constructions are productive and cannot have been exhaustively enumerated; because a third party rendered her surname differently at least once, so other renderings may exist unfound; and because in one large document family the text layer does not carry her surname at all, making surname-only sheets in that family unreachable by any query run here. ⚠ The desk’s triage put the floor at 86 documents / 125 sheets after subtracting eight sheets it positively established as other people; this pass measures 88 / 127 before any such subtraction, and inherits the triage’s attribution rather than re-deriving it.¹

⛔⛔ And the 88 is inflated roughly threefold. The desk’s triage clustered the set by the actual passage that carries her name and found that 59 of 86 documents reach her only through one of eight replicated passages — two press clips at 18 documents each, a JPMorgan exhibit index line at ten, and five smaller families. The real working set is 27 documents. ⚠ That clustering is inherited from the triage and was not re-derived here. Any count of “86 documents about her” would overstate by about 3×.¹

Block S, measured on her own sheets

Denominator: the 127 sheets that name her — not documents, and not a doc_type subset. Prefix forms throughout, because a truncated stem returns a confident zero as a bare token.

term	sheets of 127
`"attorney general"`	117 (92.1%)
`victim*`	64
bare token `victim`	47 — ⚠ the prefix finds 36% more; the bare token is not safe
`traffick*`	49
`minor*`	2
`underage*`	2
`"jane doe"`	2
`massage*`	0
`complainant`	0
invented control `zzqvict*`	0

➡ She occupies the prosecuting position on 92.1% of the sheets that name her, and the vocabulary of abuse on those sheets refers to other people. ⚠ In exactly one document of the set — the FD-302 — she is herself the complainant, and the complaint concerns alleged official interference with her own Epstein prosecution, not abuse of herself. ⛔ She is not a survivor-subject anywhere in this release and is not written as one here.¹⁰¹²

28 March 2019: Epstein’s lawyer hears there is a new Attorney General

Tier: documented fact, and it is the most valuable single sheet in the set because it is contemporaneous, documentary, and from the side that wanted something from her. On the evening of Thursday 28 March 2019 Epstein’s Virgin Islands counsel wrote to Epstein and to his New York counsel under the one-word subject line AG:

I’m still at the EDC but I am hearing we got a new AG = Denise George-Counts. I believe this is good news for us with respect to =he registration issues. I’ll reach out to Governor again.

⚠ =he is the extraction’s rendering and is NOT mended inside the quotation marks. ⛔ The sender line of this message carries a mail address which is not reproduced, described or located here, and the signature block carries a street line which is likewise not reproduced. ⚠ The document’s email_date metadata reads 2019-03-29 against an in-text send time of Thursday 28 March 2019; the in-text date is used and the metadata is not relied on anywhere on this page.²

➡ Read the whole sentence, not the first clause. The expectation was specific — the registration issues — and the plan was specific: I'll reach out to Governor again. ⚠ again is the word doing the work. Tier: question — what had already been reached out to the Governor about, and when? This release does not answer it.

14 March to 17 June 2019: the waiver, and who actually revoked what

Tier: documented fact, from Epstein’s counsel’s own file, produced in the bank litigation. The chronology here matters because the FD-302’s later account of it is approximate and this correspondence is not.

The revocation was not hers. Epstein’s counsel’s letter of 30 April 2019, addressed to Denise N. ⟦—⟧, Esq., Attorney General Nominee, states:

By letter to Mr. Epstein dated March 14. 2019, then Acting Assistant Attome? General Carol ⟦—⟧ acknowledged Mt Epstein’s well documented history of frequent and extensive travel, but advised that the USVIDOJ would no longer permit Mr. Epstein to follow these procedures, despite the fact that they have worked thwkssly for the pair ten (10) years.

⚠ Attorne?, Mt, thwkssly and pair are the extraction’s renderings and are NOT mended. ⚠ The addressee’s surname and the acting official’s surname are absent from the extraction at those points. This page does not supply either from context and makes no claim about what the paper carries. ⛔ The letterhead of this sheet carries telephone, fax, web and street lines. None is reproduced, described or located.⁵

The letter’s central factual assertion is extraordinary and should be read twice. Arguing that the old email-notice regime had worked, Epstein’s lawyers wrote:

As a result of this system of email travel notification, the USVIDOJ has been aware of Mr. Epstein’s location every single day of his lift without exception for the past ten (1(I) years. This is confirmed by the USVIDOJ’s own tiles which contain hundreds of Mr. Epstein’s email travel notices

⚠ lift, tiles and (1(I) are the extraction’s renderings and are NOT mended. ➡ Tier: documented fact that Epstein’s counsel asserted this in writing to the incoming Attorney General. ⚠ It is not a finding that the Department was in fact so informed — it is an advocate’s characterisation of the Department’s own files, offered to persuade her. ⭐ But it is the characterisation the opposing side chose to put in writing, and the Department it describes is the one she had just inherited.⁵

Her answer, on 2 June 2019, is the best document on this page. Replying to that letter over her own signature as Attorney General Nominee:

I will need additional information from Mr. Epstein prior to making that determination.

As you are well aware, my role as the Attorney General is to ensure that the laws of the territory are faithfully executed without passion or prejudice. … The primary purpose behind these sections of law is to protect the safety of communities from the dangers posed by sexual offenders like Mr. Epstein, through ensuring that such criminal sex offenders are registered and that their whereabouts are accounted for and verified at all times within the United States, its territories and abroad.

While my predecessors have apparently had differing interpretations of Title 14, Section 1724(b)(4) of the Virgin Islands Code, it is my understanding that the 21 -day in-person notification for international travel can only be waived upon a showing of “reasonable and reliable proof satisfactory to the Department of Justice” that your client frequently travels internationally for business or some other legitimate purpose.

In this particular case, I have not been presented with any documentation of such proof, nor does the V1D0J have any record of such documentation ever having been submitted to the VIDOJ.

⚠ V1D0J and 21 -day are the extraction’s renderings and are NOT mended. She closed by requiring production of whatever had originally justified the earlier waiver, and then:

Until this review is completed, the Department is requiring that the current terms of Mr. Epstein’s travel—both internationally and nationally—be strictly adhered to.

⛔ Her signature block on that sheet continues into a street line, a telephone number and a mail address. The quotation stops at Attorney General Nominee / Virgin Islands Department of Justice / Office of the Attorney General and nothing beyond it is reproduced, described or located.⁴

Pressed, two weeks later, to say what proof she wanted, she declined to narrow it. On 17 June 2019:

There is no specific information that I am seeking at this time. Please submit reasonable and reliable proof as required by statute. If the travel notifications are helpful in your submission of the required proof, you may submit.

➡ Documented fact: the waiver was not granted, and the reason it was not granted is in her own words, in the file of the lawyers who sought it. ⚠ The FD-302 records her telling an FBI agent in 2023 that GEORGE did not grant EPSTEIN the waiver, that the Governor had texted her you need to make a decision on the Epstein matter, and that she informed Epstein’s counsel by letter and the Governor by email the same day. ⭐ The refusal itself does not depend on that account at all — the primary correspondence carries it. The gubernatorial text message does depend on it entirely, and stays at the allegation tier.⁴¹⁰

⚠ A date the record does not settle. Her office’s press release says she took office in May 2019 — the single carrier for that date in this release. Yet she is addressed as Attorney General Nominee on 30 April 2019 and still signs as nominee on 17 June 2019, and Epstein’s counsel reports hearing of a new AG on 28 March 2019. Tier: question. The documents are consistent with appointment in March, assumption of office in May and legislative confirmation later, but this release does not state that, and this page does not assert it.⁹⁵⁴¹³

12 July 2019: she explains why she has not investigated him

Tier: documented fact — a direct quotation, contemporaneous, six days after Epstein’s federal arrest. Under the headline Local authorities not currently investigating Epstein, the Virgin Islands Daily News reported:

The V.I. Justice Department has been monitoring Jeffrey Epstein since 2008 when he became a registered sex offender, but local authorities have never received a criminal complaint that would prompt an investigation in the territory.

“Something has to trigger an investigation,” said V.I. Attorney General Denise George.

The article continues that she said an investigation can only be launched on a criminal complaint or a peace officer’s observation, and that "an investigation is not triggered because criminal activity was occurring in another jurisdiction, or another state." Put to her that an individual had alleged in a New York civil suit that she was abused at Epstein’s island home, the article reports her answer:

“It’s not based on that type of hearsay, or news reports from another jurisdiction,” George said.

If the individual in the case filed a complaint “then an investigation can be opened,” George said.

⛔ No detail identifying any survivor is reproduced from this sheet or from any other sheet on this page.⁶

➡ This is the hinge of the page. Three days before the end of that week she was the official explaining the absence of an investigation. Six months later she filed one of the largest civil enforcement actions in the territory’s history. Both are documented. The page does not smooth the first into the second.

On 14 February 2020, with the estate action already filed, she damped the wider question too. The Miami Herald, reporting that the amendment naming Southern Trust seemed to be painting a target on some of the island's most prominent figures, including Gov. Albert Bryan Jr., and a former first lady, Cecile de Jongh:

But in an interview with the Miami Herald, USVI Attorney General Denise ⟦—⟧ squelched those rumors, saying there was no evidence yet that might suggest broader responsibility.

“People can only be liable for evidence that leads to them,” she said. “Just because a person may be there and working, it does not mean that they committed a crime.”

⚠ squelched is the newspaper’s characterisation, not hers, and is attributed here to the newspaper. ⚠ The surname is absent from the extraction at those points and nothing is supplied. ➡ Tier: question — she publicly declined to implicate the Governor who had appointed her, two years before he is alleged to have told her to end the case quickly. The release does not connect those two things and neither does this page.¹⁴¹⁰

15 January 2020 to 1 December 2022: the estate action

Tier: documented fact, from the filings and from her own office. The initial complaint against the Estate of Jeffrey E. Epstein was filed on 15 January 2020 in the Superior Court of the Virgin Islands. The Second Amended Complaint is dated February 10.2021 — ⚠ the extraction’s rendering — and her office’s later release gives the amended filing date as 12 February 2021. Her name stands on the complaint as Attorney General of record:

RESPECTFULLY SUBMITTED, DENISE N. GEORGE, ESQ. ATTORNEY GENERAL Dated: February 10.2021 /s/ Carol Thomas-Jacobs CAROL THOMAS-JACOBS, ESQ. Assistant Attorney General

⛔ The signature block on that sheet continues into a street line, a mail address and a telephone number with extension. None of them is reproduced, described or located here.¹⁵⁹

In February 2020 she was operating the action in real time, and the correspondence survives. The densest file on her in this release is a NOTICE TO THE COURT in the probate matter with twenty-three sheets of attached correspondence. It records that the Government placed a Criminal Activity Lien on estate accounts on 31 January 2020, that the Estate’s counsel objected by email on 5 February 2020, and that On February 6, 2020, the Attorney General responded by email, and offered to schedule a meeting with the Estate the following day. Her outgoing filing is dated 11 February 2020.¹⁶

And her own reply to victims’ counsel, on 10 February 2020, is in the file:

We are indeed very interested in meeting with the victims and I thank you for the productive and encouraging conversation in our February 4rn meeting. … To that end, I have attached a letter that I want to share with you which I sent to Epstein’s Estate to establish the kind of specific commitments that would be required of the Estate to address the Government’s concerns regarding their program as proposed.

⚠ 4rn is the extraction’s rendering and is not mended. ⛔ The message she was replying to describes individual clients of victims’ counsel. NOTHING from it is reproduced, paraphrased or characterised here beyond the bare fact that counsel proposed a meeting, and no survivor is identified, counted or described. ⛔ The mail and telephone fields on these sheets are not reproduced.¹⁶

The settlement was announced on 1 December 2022. Her office’s release states the terms as $105 million in cash plus one half of the proceeds from the sale of Little St. James, a further $450,000 to remediate environmental damage around Great St. James, and the return of more than $80 million in economic development tax benefits. In the same release she said:

This settlement restores the faith of the People of the Virgin Islands that its laws will be enforced, without fear or favor, against those who break them. We are sending a clear message that the Virgin Islands will not serve as a haven for human trafficking.

⭐⭐ And in the same release — twenty-six days before she sued JPMorgan Chase and thirty days before she was told she was terminated — she expressed gratitude to Governor Albert Bryan, who appointed her in 2019, for his commitment to ensure that justice was done. ➡ Tier: documented fact. The inference a reader will draw from putting that sentence beside the FD-302’s account of the same Governor is not a finding of this page, and the page does not make it.⁹¹⁰

⚠ A gap in this release, reported as a gap in reach and not as a gap in the record. Nothing in the attributable set is dated between the February 2020 lien correspondence and the February 2021 amended complaint. ⛔ This pass did not establish whether that ten-month interval is empty in this release or merely unreached by her name forms. It is not called a gap in the record.¹³

27 December 2022 to 1 January 2023: the filing, the firing, and four refusals

Tier: documented fact as to the sequence. ⛔ Nothing below is a finding of cause.

The filing. Her own account to the FBI, nine months later: Approximately December 27, 2022, GEORGE filed action against JP MORGAN. ⚠ Approximately is her word, recorded by the agent.¹⁰

The termination, as she dated it. From the same sheet: On December 31, 2022 GEORGE was informed that she was terminated. ⚠ 31 December 2022 was a Saturday.¹⁰

The removal as reported. The Virgin Islands Daily News of 1 January 2023 — a Sunday — carried the article Bryan terminates Attorney General Denise ⟦—⟧ by a named staff reporter:

Gov. Albert Bryan Jr. has fired V.I. Attorney General Denise ⟦—⟧ , and appointed Carol ⟦—⟧ to the role in an acting capacity, Government House Communications Director Richard Motta Jr. said Sunday.

⛔⛔ The extraction does NOT carry the surname of either woman at that point. This page quotes only what the extraction returns, supplies nothing from context, and makes NO claim about whether the printed paper carries them — that is an image question and no image was opened. ⛔ Nothing is said about any mark, and this page does not identify the person appointed in an acting capacity.¹¹

The Governor’s own statement, quoted in the same article:

“I relieved Denise ⟦—⟧ of her duties as attorney general this weekend. I thank her for her service to the people of the Territory during the past four years as Attorney General and wish her the best in her future endeavors. Assistant Attorney General Carol ⟦—⟧ will serve as Acting Attorney General,” the governor said in the prepared statement with the customary paragraph touting transparency.

⚠ with the customary paragraph touting transparency is the newspaper’s editorial aside, not the Governor’s, and is attributed here to the newspaper. ➡ this weekend is the Governor’s own dating, and it spans both candidate dates.¹¹

The date: three documents, three framings, and they are reconcilable

what it says	when it says it was	whose words
`On December 31, 2022 GEORGE was informed that she was terminated`	Sat 31 Dec 2022 — notification	hers, to an FBI agent, Oct 2023¹⁰
`has fired V.I. Attorney General Denise ⟦—⟧ … Motta said Sunday`; `a brief statement released late Sunday night`	Sun 1 Jan 2023 — announcement	Government House, via the press¹¹
`I relieved Denise ⟦—⟧ of her duties as attorney general this weekend`	the weekend of 31 Dec – 1 Jan	the Governor¹¹
`an article titled "Bryan terminates Attorney General Denise ⟦—⟧," dated January 1, 2023`	1 Jan 2023 — publication	a sworn exhibit declaration for JPMorgan¹⁷
`In an article published following her termination in January 2023`	January 2023	JPMorgan’s statement of undisputed facts⁷

➡ These are not in conflict about an event; they are dating different events. Notification falls on Saturday 31 December 2022 on her account; the announcement falls on Sunday 1 January 2023 on Government House’s. This weekend covers both. ⚠ The only genuine divergence is JPMorgan’s her termination in January 2023, which dates the termination by the announcement rather than by the notification, and which rests on an article dated 1 January 2023. ⛔ The desk’s own commission for this page asserted 31 December 2022 and not January 2023 on its authority. That is too firm: 31 December 2022 is her recollection of being informed, recorded ten months later, and no contemporaneous document carries it. The page states which source gives which date and asserts no single one.

The juxtaposition is in the record, attributed, and it is a newspaper’s

Motta did not respond to a request for comment about Bryan’s reasons for the decision, which comes days after The Daily News reported that ⟦—⟧ filed a lawsuit in federal court in Manhattan, accusing JPMorgan Chase of helping Jeffrey Epstein exploit women and girls.

⚠ The subject of filed is absent from the extraction, and nothing is supplied. ⚠ Measured for this page: the phrase comes days after stands on 10 sheets in the whole of this release, and exactly ONE of them is this one. The temporal link is drawn once, by a named newspaper, in its own voice. ⛔ A newspaper’s which comes days after is a juxtaposition, not a causal finding, and is not converted into one here.¹¹¹²

Four refusals on one page of newsprint

Tier: documented fact. Each is a separate, attributable non-answer, and the desk’s own correction — that there were two — undercounts.

Motta did not respond to a request for comment about Bryan's reasons for the decision — the Communications Director, on the Governor’s reasons.
Bryan, in a brief statement released late Sunday night, also gave no reason for termination. — the Governor himself, in a prepared statement.
Following that statement. Motta could not immediately be reached for comment on reports circulating that the governor was unaware of ⟦—⟧ lawsuit against JPMorgan Chase and was displeased with her previous court actions against the Epstein estate. — the Communications Director again, on a specific allegation.
and Justice Department spokeswoman Sandra Goomansingh did not respond to requests for comment from The Daily News. — the Department she had led.

➡ Item 3 is the most informative of the four, and not because of the refusal. It records that on 1 January 2023 there were reports circulating of two specific things: that the Governor was unaware of the JPMorgan filing, and that he was displeased with her previous court actions against the Epstein estate. ⚠ That is the newspaper reporting the existence of circulating reports — the weakest evidentiary form on this page, and nothing more than that is claimed for it. ⛔⛔ A refusal to give reasons is not a reason. The page records the refusals as findings in their own right and does not convert them.¹¹

⭐⭐ And the sharpest thing in the record is in the same article, four sheets later, in the Governor’s own voice from 2019. Explaining at her appointment why the Attorney General’s Office needed more autonomy:

“In the Virgin Islands, due to the inherent structure of our government, the balance of power is sometimes tipped towards the executive branch. Over the years, this bias has allowed individuals to use the power of the executive branch to intimidate, suppress and to exact political retribution on individuals and on other branches of government. It has also made way to grant favors for politicians and family affiliations, while persecuting perceived enemies and political opponents,” Bryan said at the time.

And:

Independence for the attorney general, “would help to restore the balance of power to the executive branch. My team and I have given considerable thought to how we could help to ensure that this office, the Office of the Governor, is never used in this way, and every Virgin Islander is afforded the protection of the United States Constitution and the Organic Act,” Bryan added.

⚠ restore the balance of power to the executive branch is the extraction’s rendering and is NOT mended inside the quotation marks; the sense of the surrounding passage runs the other way and this page does not repair it. ➡ Tier: documented fact that he said it. The page sets his 2019 words beside his 2023 act, attributes both, and draws no conclusion. ⛔ The irony is the reader’s to have.¹¹

The one rationale that reaches the record

Tier: credible allegation, double-hearsay, and the weakest evidentiary form used anywhere on this page. From her complaint to the FBI:

Several reasons were provided to the press but a listed reason was that no attorney general was going to file anything without notifying the Governor.

⚠ Measured for this page: the phrase notifying the governor stands on exactly ONE sheet in the whole of this release — that one. ➡ So the only stated rationale in this release is her account of what the press reported, it is attributed to no named official, and it exists in exactly one place. ⛔ It is not an official statement of cause and is not written as one.¹⁰¹²

The question, left as a question

➡ ⛔⛔ NO DOCUMENT IN THIS RELEASE STATES THAT THE JPMORGAN FILING CAUSED THE REMOVAL. The absence was tested here with her name removed from the query, because an absence claim cannot be drawn from a name-scoped set: retaliat* stands on 1,625 sheets of this release and on ZERO of the 127 that name her. ⚠ What the record carries instead is a sequence of four days, a single newspaper’s own which comes days after, four separate refusals of a reason, and one rationale at two removes.

Tier: question. What would explain a termination notified four days after the filing, announced without a stated reason, where the Governor’s own office declined comment twice, the Department declined comment once, and the only rationale reaching the record arrives through the press on a single sheet? ⛔ This page does not answer that and no document in this release does.¹²

What she alleged, ten months later, and at what tier

⛔ EVERYTHING IN THIS SECTION IS CREDIBLE ALLEGATION, NOT DOCUMENTED FACT. On 2 October 2023 she requested to file a complaint with the FBI in St Thomas. The resulting FD-302 carries the Bureau’s standard legend on its first sheet: This document contains neither recommendations nor conclusions of the FBI. ➡ The document establishes what she said. It does not establish that it happened, and the form itself says so. ⛔ The interviewee’s personal identifiers on that sheet are not reproduced, described or located.¹⁰

As recorded by the agent, she alleged a reversal of gubernatorial support as the estate case widened:

BRYAN told GEORGE “He’s dead go for it”.

BRYAN original tone of “Go for it” changed to “End it quickly”. BRYAN would message GEORGE with questions on why she was interviewing certain people, requesting documents, or filing certain items. BRYAN told GEORGE that `originally when I said go ahead I didn’t think it was going to go this far. I can’t get you to let this go?’.

⚠ The mixed quotation marks are the extraction’s and are not mended. And a specific direction on how to end it:

BRYAN informed GEORGE to settle with the EPSTEIN estate for 80 million dollars and to pursue mediation and select Henry Smock (SMOCK) as the mediator. BRYAN told GEORGE that the EPSTEIN estate just wanted to clear people. BRYAN later told GEORGE that he was sick of her not doing what she was told to do.

➡ Credible allegation. ⚠ Note what is checkable about it and what is not: the settlement figure she says she was told to accept is 80 million dollars, and the case settled at $105 million plus property — a figure her own press release carries. ⛔ That the two numbers differ is a documented fact; what it means is not, and the page does not interpret it.¹⁰⁹

She also alleged an obstruction mechanism inside the estate, recorded as: All EPSTEIN employees had nondisclosure agreements and were informed if questioned by law enforcement to say nothing and alert KELLERHALS. ⚠ Credible allegation, her account, named in an FBI form. This page records no finding about any named lawyer’s conduct.¹⁰

⚠ The 302 further records her belief, as the agent wrote it, that during the estate investigation it was discovered that the estate’s co-executors were participants in the human trafficking operation. ⛔ That is an allegation at the lowest tier used on this page — her characterisation, of an investigative conclusion, recorded in a form carrying the FBI’s disclaimer — and it is reported here only because the public record of the same matter carries the answer to it: the newspaper reporting her removal states that The estate and its co-executors, Darren Indyke and Richard Kahn, denied all allegations of wrongdoing, and her own settlement release states that The estate denied all wrong doing. ⛔ No survivor detail from that passage is reproduced.¹⁰¹¹⁹

⚠ The 302 also records alleged gubernatorial interference in matters having nothing to do with Epstein — a police-misconduct suit, and a gaming contract — including an allegation that the Governor telephoned her extremely angry saying "I am hearing you are going after people who are members of our team." ⛔ Those passages name several private individuals against whom this page makes and reports NO allegation whatever; they are not named here, their alleged conduct is not reproduced, and this page records only the pattern she described and the single quotation above. ⚠ One structural element of it is worth stating without a name, because it goes to access rather than to conduct: the 302 records her description of the Governor’s then Chief of Legal as a former employee of Epstein’s Virgin Islands counsel’s firm. Credible allegation; unverified; no name supplied.¹⁰

Resistance log

event	tier	source
The Communications Director `did not respond to a request for comment about Bryan's reasons for the decision`	documented fact	the article, 1 Jan 2023¹¹
The Governor’s `brief statement released late Sunday night, also gave no reason for termination`	documented fact	the article¹¹
The Communications Director `could not immediately be reached for comment on reports circulating that the governor was unaware of` the JPMorgan filing	documented fact	the article¹¹
`Justice Department spokeswoman Sandra Goomansingh did not respond to requests for comment from The Daily News`	documented fact	the article¹¹
Estate employees under nondisclosure agreements, instructed to say nothing to law enforcement and alert counsel	credible allegation	FD-302¹⁰
A cease-and-desist letter emailed to her, and `an unknown man arriving at her home`, after she gave press interviews about her tenure. `GEORGE took the use of an unknown man to convey a message that we can reach you at your home.`	credible allegation	FD-302¹⁰
Her office’s `Supplemental Written Responses and Objections` to the bank’s deposition notice `filed under seal`, and two further exhibits in the same declaration `[Sealed]`	documented fact that material was withheld from the public file	exhibit index¹⁸

➡ The fourth row is the one a reader should sit with. The reasons for removing the Attorney General who had just sued JPMorgan Chase were declined to the press contemporaneously, by three different offices, within hours. ⛔ The pattern of refusal is a finding in its own right. It is not evidence of what the reasons were.

How JPMorgan Chase used her against her own government

Tier: documented fact, from the filings. Her deposition in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. was taken on 17 July 2023; the exhibit index describes it as Transcript excerpts of the Deposition of former Attorney General Denise ⟦—⟧ taken on July 17, 2023, in this Action. ⚠ Only excerpts are in this release. The transcript itself is not, and no quotation on this page comes from it — every characterisation of her testimony below is a party’s characterisation, cited as such.¹⁸

The bank’s use of her is explicit. In its statement of undisputed facts, under the heading Facts Concerning Epstein's Registration as a Sex Offender in the Virgin Islands:

Former Attorney General Denise ⟦—⟧ similarly testified that she couldn’t rely on “news reports,” “rumor” or “innuendo” to initiate an investigation into Epstein. Ex. 282 at 167:3-170:3.

As witnesses testified, absent an actual complaint from a victim or eyewitness evidence brought to the Department of Justice’s attention, the Department could not initiate investigations.

⚠ The same filing also records something that cuts the other way and is reported here for that reason: Upon assuming her role as Attorney General, Attorney ⟦—⟧ inquired of various agencies to confirm whether they had received any complaints regarding Epstein. She found no evidence that any complaints had been received. ➡ The bank’s own 56.1 statement has her actively checking.⁷

And in a separate attachment the bank put a second former Attorney General against the first. The former Acting Attorney General testified that she is "sure the Virgin Islands would be aware of any national press accounts.", and further that if the USVI knew of allegations in civil lawsuits they had a "responsibility to follow up" on the allegations. ⚠ Immediately above that, the same attachment records: Former Attorney General Denise ⟦—⟧ testified that she reviewed civil complaints against Epstein when she became the Attorney General. ⛔⛔ That sheet also carries a named survivor pseudonym and detailed allegations of abuse. NOTHING else on it is reproduced, paraphrased or characterised here, and no survivor detail is taken from it.¹⁹

➡ Her testimony is in tension with itself, and the page reports the tension rather than resolving it. She reviewed the civil complaints when she took office; she inquired of the agencies; she found no complaints had been received; and she did not open an investigation, on the stated ground that civil-suit allegations from another jurisdiction were not sufficient. Three of those four are JPMorgan’s own characterisations of her sworn testimony. All four can be true at once. Whether they amount to a defensible exercise of prosecutorial discretion is a question this release does not answer and this page does not decide.

⭐⭐ The most telling thing in the summary-judgment record is that both sides cited the same lines of her deposition. JPMorgan cites Ex. 282 at 167:3-170:3 for her inability to act on news reports. The Virgin Islands, responding, offers an additional fact citing the identical page-and-line range under its own exhibit numbering:

23-a. The Government did not initiate an investigation following his arrest out of deference to the federal government. Ackerman Decl., Ex. 9 at 167:3-170:3, 172:6-174:3.

⚠ The exhibit numbers differ because the two parties filed under different declarations; the page-and-line range is the same. This page states that the ranges match and asserts nothing further about the underlying transcript, which is not in this release.⁷⁸¹⁸

And her own government did not dispute the point

⚠⚠ This is the single most important thing the bank litigation establishes about her, and it has nothing to do with her firing. JPMorgan’s paragraph 24 asserted:

In July 2019, then-Attorney General Denise ⟦—⟧ reportedly told the Virgin Islands Daily News that “there was no reason for her to investigate Epstein,” because the allegations in a civil lawsuit filed in another state “[were] not sufficient to launch a local investigation.” Ex. 22. In an article published following her termination in January 2023, she was quoted as saying at the time, “an investigation is not triggered because criminal activity was occurring in another jurisdiction, or another state.” Id.

⚠ The Ex. 22 on which that paragraph rests is the 1 January 2023 article reporting her removal — authenticated into the record by a sworn declaration for JPMorgan as a true and correct copy of an article titled "Bryan terminates Attorney General Denise ⟦—⟧," dated January 1, 2023. ➡ The bank built the paragraph out of the newspaper story about her firing.⁷¹⁷

The Government of the Virgin Islands answered it on 7 August 2023, in its own filing:

RESPONSE: The Government disputes that the allegations in this paragraph are material to Defendant’s Motion for Summary Judgment. … To the extent the allegations are material, the Government does not dispute the allegations set forth in this paragraph.

➡ ⭐⭐ Documented fact, at the highest tier available: a party admission in a federal filing. The Virgin Islands did not dispute that its own then-Attorney General said there was no reason for her to investigate Epstein. It argued only that the point was immaterial, and that the Government's investigative decisions cannot, as a matter of law, form a basis for JPMorgan's affirmative defenses.⁸

⚠ A note on attribution, because the desk’s commission raised it and the answer is not the obvious one. The sheet carrying her termination in January 2023 is not the bank’s filing. It is the Government of the Virgin Islands’ RESPONSE TO DEFENDANT'S LOCAL 56.1 STATEMENT OF UNDISPUTED MATERIAL FACTS, which reproduces each of the bank’s numbered paragraphs and answers it. The quoted paragraph is JPMorgan’s; the response under it is the Virgin Islands’. ⛔ Citing that sheet as “the bank’s filing” would misattribute it, and citing it as “the Government’s filing” would misattribute the paragraph. Both appear on the same sheet and this page separates them.⁸⁷

What this release does not contain about her

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

NEGATIVE, measured. No document states a cause for her removal. retaliat* stands on zero of the 127 sheets that name her, against 1,625 sheets of this release. The phrase notifying the governor stands on one sheet. The phrase comes days after stands on 10 sheets of which one is hers. No letter, notice, order or memorandum of termination appears anywhere in the set. No statement by her in her own words about the removal appears anywhere in the set — her account of it reaches this release only through an FBI form, ten months later. [VISION] sheets across all fifteen documents cited on this page: ZERO, measured per document.¹²³

UNMEASURED, and therefore NOT a finding of absence. Whether she appears in this release under a role phrase that never spells her name; whether renderings of her surname beyond those enumerated exist; whether the ten-month interval between February 2020 and February 2021 is genuinely empty in the corpus; what her deposition actually says, as opposed to what each party says it says; what the reasons for her removal were; and whether any page image matches any text layer quoted here. ⚠ Each of those is unmeasured. None is a negative.¹³

Name forms and attribution. Measured for this page over pages_fts, phrase-matched, counts in sheets and in documents: "general denise" 71 / 69; "denise george" 69 / 48; "attorney general denise" 62 / 60; "denise n. george" 23 / 14; "george counts" 1 / 1; "d. george" 31 / 27; bare token george 14,444 / 10,236. Invented controls zzqdenise and zzqgeorge return 0 / 0. Union of the attributable forms as run here: 127 sheets / 88 documents. Every one of these figures independently reproduces the desk’s triage exactly. ⛔ The bare-surname and "d. george" figures are reported ONLY to size two traps and are never used as figures about her; the triage opened all 31 "d. george" sheets and attributed none of them to her. ⚠ The triage’s floor of 86 documents / 125 sheets subtracts eight sheets it positively established as other people; that attribution is INHERITED here and was not re-derived sheet by sheet, and the difference is not load-bearing for anything on this page. ⚠ The triage’s clustering finding — that 59 of 86 documents reach her only through one of eight replicated passages, leaving a working set of 27 — is likewise INHERITED and was not re-derived. ⚠ unicode61 splits on the hyphen, so the base phrase already matches George-Counts; the inverted phrase reaches one sheet and no population is hidden there. ⚠⚠ A TRUNCATED STEM RETURNS A CONFIDENT ZERO AS A BARE FTS TOKEN. Every stem query run for this page was an UNQUOTED prefix: measured here, bare victim returns 47 sheets where victim* returns 64, and a quoted MATCH '"retaliat*"' returns 0 because inside double quotes the asterisk is a literal character. ↩ ↩² ↩³ ↩⁴ ↩⁵
E-mail from Epstein’s Virgin Islands counsel to Jeffrey Epstein and Darren Indyke, sent Thursday, March 28, 2019 6:11 PM, subject AG. ONE row in pages. https://epstein-data.com/EFTA02636006 . page_number 0, 0-based as found, located by string. The sheet bears its own stamp EFTA02636006 and a second production stamp. No served page number is asserted and no mapping between the numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; documents.pdf_url is NULL for this identifier and the recorded file_path points into an image store that does not exist on this desk (checked). From this sheet this page takes the body sentence in full, exactly as the extraction returns it, including the damaged span =he. ⛔⛔ THE SENDER LINE CARRIES A MAIL ADDRESS AND IS NOT REPRODUCED, DESCRIBED OR LOCATED. The signature block carries a street line and is not reproduced. Nothing on this sheet beyond the one body sentence is quoted. ⚠ documents.email_date records 2019-03-29 against the in-text Thursday, March 28, 2019; the in-text date is used and the metadata field is not relied on anywhere on this page. Block S over the single row: victim 0, massage 0, minor 0, underage 0, traffick 0. [VISION] 0. ↩ ↩² ↩³ ↩⁴
Statement about this release’s own records, offered because it changes how every quotation above must be read. ⚠⚠ (1) NO IMAGE VERIFICATION WAS PERFORMED AND EVERY QUOTATION ON THIS PAGE IS A TEXT-LAYER READING. The recorded file_path for these identifiers points into /atb-data/…, which does not exist on this desk (checked); the local image directory holds no file for any document cited here; and this pass did not go to the site server. 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. ⚠⚠ CORRECTION TO THE DESK’S TRIAGE, WHICH MATTERS BECAUSE IT CHANGES WHAT IS POSSIBLE NEXT: the triage reported that pdf_url is null for all but one document in the set. Measured here over the 88 documents of the union form, 28 carry a non-null pdf_url — including the article reporting her removal, the exhibit declaration authenticating it, the registration correspondence, both 56.1 filings and the deposition index. Image verification for the strongest documents on this page is REACHABLE and merely OUTSTANDING. It is not impossible, and the desk should do it before this page is reviewed. The documents where it is NOT reachable by that route, because pdf_url is null, include the two most load-bearing single sheets: the FD-302 and the March 2019 e-mail. ⚠⚠ (2) doc_type IS NOT USABLE AS A FILTER AND WAS NOT USED. On this set alone: the article reporting her removal is typed court.filing; the 71-sheet exhibit of registration correspondence is typed email.header; the Miami Herald article is typed court.filing_state; and the desk’s triage records six further misses in the same set, among them two roughly thousand-sheet containers typed blank.redacted, two probate accountings typed travel.itinerary and financial.bank_statement, and a newspaper article typed image.photo. ➡ A search scoped by document type would have lost the best evidence on this page. ⚠⚠ (3) documents.total_pages WAS NOT RELIED ON. Every run length stated on this page is a 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 here — the extraction row, the court’s ECF header, the document’s own internal pagination, the producer’s stamp, and a second production stamp — and on one sheet cited above two of those numbers differ by more than two hundred. The footnotes print every number they have and relate none of them by arithmetic. Every sheet was located by STRING and each footnote says which number it is giving. ⚠⚠ (5) documents.sender AND documents.email_date WERE READ AND NOT RELIED ON FOR ANY CLAIM. One ±1-day drift is demonstrated above on the March 2019 e-mail, and one sender field in the set is a mangled personal name. Every date on this page comes from DOCUMENT TEXT. ⚠⚠ (6) [VISION] SHEETS: ZERO across every document cited, measured per document with instr() after a GLOB test produced 99 false positives. ⚠⚠ (7) A SYNTHETIC ANNOTATION LAYER EXISTS IN THIS CORPUS AND IS NOT A PRODUCING PARTY’S MARK. One document cited here carries an appended block headed [═══ TRANSCRIPT ═══]; quotation is taken only from above that line. ⚠⚠ (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, and the two are never mixed. ↩ ↩² ↩³
Her own e-mail replies to Epstein’s counsel of Jun 2, 2019, at 8:24 PM and Jun 17, 2019, at 6:20 PM, in the same 71-row exhibit. https://epstein-data.com/EFTA02808954 . **This page cites page_number 55, 56 and 57 (0-based, as found, located by string); stamps EFTA02809009 and EFTA02809010, and stamp EFTA02809011; the sheets also carry the court’s Page 56 of 71 / Page 57 of 71 / Page 58 of 71 headers, their own internal pagination 2/3/4, and production bates of their own. NO MAPPING between those numbers is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From page_number 57 this page takes: I will need additional information from Mr. Epstein prior to making that determination.; the paragraph beginning As you are well aware, my role as the Attorney General, elided at one point and marked; the paragraph beginning While my predecessors have apparently had differing interpretations; the sentence beginning In this particular case, I have not been presented; the sentence beginning Until this review is completed; and the three signature lines Attorney General Nominee / Virgin islands Department of Justice / Office of the Attorney General. From page_number 55 this page takes the three sentences beginning There is no specific information that I am seeking at this time. From page_number 56 this page takes nothing quoted; it is the counterparty asking what reasonable and reliable proof means, and it is cited only as establishing that the demand was pressed. ⛔⛔ THESE SHEETS CARRY MAIL ADDRESSES, A TELEPHONE NUMBER AND A STREET LINE, INCLUDING IN HER OWN SIGNATURE BLOCK. NONE IS REPRODUCED, DESCRIBED OR LOCATED, AND EVERY QUOTATION OF THE SIGNATURE BLOCK STOPS SHORT OF THEM. ⚠ The addressee surnames on these sheets are rendered by the extraction as damaged fragments and are not reproduced or repaired. ⚠ V1D0J and 21 -day are the extraction’s renderings and are NOT mended. ⚠ CORRECTION OF RECORD: the desk’s triage characterised page_number 56 as the sheet on which her office imposed the evidentiary demand. It is not — 56 is Epstein’s counsel asking what the demand means. The demand itself is on 57 and 55, in her own words, and the triage did not record that she signed as Attorney General Nominee or that the 14 March 2019 revocation was the acting official’s and not hers. Both are material and both are corrected here. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶
Letter from Epstein’s Virgin Islands counsel to the Attorney General Nominee, dated April 30, 2019, subject Changein Notification Procedures, produced in the JPMorgan action as Exhibit 83 and stamped CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER. The containing document EFTA02808954 has 71 rows in pages. https://epstein-data.com/EFTA02808954 . This page cites page_number 1, 4, 5 and 6 (0-based, as found, located by string); those sheets bear their own stamps EFTA02808955 and EFTA02808958, and the stamps EFTA02808959 and EFTA02808960, print their own internal letter pagination, carry the court’s own Page 2 of 71 / Page 5 of 71 header, and carry a production bates of their own. ⚠⚠ Five or more numbers name each of these sheets and NO MAPPING between them is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. ⚠ A public PDF address IS recorded in documents.pdf_url for this identifier, so image verification is reachable and simply outstanding. From page_number 1 this page takes: the addressee block as far as Attorney General Nominee; the sentence beginning By letter to Mr. Epstein dated March 14. 2019, in full as quoted; and the two sentences beginning As a result of this system of email travel notification, in full as quoted. From page_number 5 this page takes the clause Although Attorney Jacobs cited section I 724(b)(1) as the reasoning for revocation of the established travel procedures only insofar as it corroborates that the revocation preceded her; it is not quoted in the body. From page_number 6 this page takes the fact of the February 2019 Dominican Republic detention and nothing quoted. ⛔⛔ THE LETTERHEAD AND SIGNATURE BLOCKS ON THESE SHEETS CARRY TELEPHONE, FAX, WEB AND STREET LINES. NONE IS REPRODUCED, DESCRIBED OR LOCATED. ⚠ The surnames of the addressee and of the acting official are ABSENT FROM THE EXTRACTION at those points. This page supplies neither from context, says nothing about any mark, and makes no claim about what the printed sheet carries — that is an image question and no image was opened. ⚠ Attome?, Mt, thwkssly, pair, lift, tiles and (1(I) are the extraction’s renderings and are NOT mended inside quotation marks. [VISION] sheets across all 71 rows: 0. ↩ ↩² ↩³ ↩⁴ ↩⁵
A Virgin Islands Daily News article, Local authorities not currently investigating Epstein, by a named staff reporter, circulated inside a government e-mail forwarded Frid*, July 12, 2019 8:08 AM. FOUR rows in pages. https://epstein-data.com/EFTA00148228 . This page cites page_number 1 (0-based, as found, located by string); the sheet bears its own stamp EFTA00148229. No served page number is asserted. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; documents.pdf_url is NULL for this identifier. From this sheet this page takes: the two-sentence opening beginning The V.I. Justice Department has been monitoring Jeffrey Epstein since 2008; the quotation "Something has to trigger an investigation," said V.I. Attorney General Denise George.; the clause "an investigation is not triggered because criminal activity was occurring in another jurisdiction, or another state."; the quotation "It's not based on that type of hearsay, or news reports from another jurisdiction," George said.; and the sentence If the individual in the case filed a complaint "then an investigation can be opened," George said. ⛔⛔ THE SHEET DESCRIBES AN INDIVIDUAL’S ALLEGATIONS IN A CIVIL SUIT. NO IDENTIFYING DETAIL ABOUT HER IS REPRODUCED, PARAPHRASED OR CHARACTERISED, AND SHE IS NOT NAMED, COUNTED OR DESCRIBED BEYOND THE WORDS OF THE QUOTATIONS ABOVE. ⛔ The producer withheld the party fields of both covering messages and this page does not supply them, states no class or position for any withheld value, and says nothing about what is covered. ⚠ Frid* and Pl ay are the extraction’s renderings of the send dates and are not mended; the in-text article date is not printed on the sheet and is not asserted. [VISION] 0. ↩ ↩² ↩³
JPMorgan Chase Bank, N.A.’s Local Rule 56.1 statement of undisputed material facts, Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904-JSR (S.D.N.Y.), filed 24 July 2023. Cited here in two documents of the set: EFTA02809616, 12 rows (https://epstein-data.com/EFTA02809616), page_number 4, stamp EFTA02809620, court header Page 5 of 12, internal pagination -5-; and EFTA02809437, 148 rows (https://epstein-data.com/EFTA02809437), page_number 141, stamp EFTA02809578, court header Page 142 of 148, internal pagination 142. 0-based, as found, located by string. NO MAPPING derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; public PDF addresses ARE recorded for both. From EFTA02809616 page_number 4 this page takes paragraph 24 in full as quoted. From EFTA02809437 page_number 141 this page takes paragraph 428 in full, the first sentence of paragraph 429, and paragraph 431 in full, together with the section heading Facts Concerning Epstein's Registration as a Sex Offender in the Virgin Islands. ⚠ Her surname is ABSENT FROM THE EXTRACTION at every occurrence in both and is never supplied; ⟦—⟧ in the body marks that absence and nothing else. ⛔⛔ Several paragraphs adjacent to those quoted have values withheld in the extraction. THIS PAGE QUOTES ONLY COMPLETE, INTACT PARAGRAPHS, states nothing about any withheld value, its class or its position, and reconstructs nothing. ⚠ The desk’s triage records that this paragraph 428 stands identically in four copies within the set and that the family is clean. ⛔ This page nonetheless cites ONE copy per quotation, sets no copy beside another, and characterises no difference between any two. ⚠ The triage also records TWO SHEETS IN A SEPARATE COPY FAMILY as barred under the copy-divergence rule, with no clean second carrier in the attributable set. ⛔ NEITHER IS CITED, QUOTED, PINNED OR SOUGHT HERE BY ANY ROUTE, and the evidence line they alone carried is built on the FD-302 and the March 2019 e-mail or it is absent from this page. It is absent. [VISION] 0 across all rows of both. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' RESPONSE TO DEFENDANT'S LOCAL 56.1 STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF DEFENDANT'S MOTION FOR ⟦—⟧RTIAL SUMMARY JUDGMENT, filed 7 August 2023. 43 rows in pages. https://epstein-data.com/EFTA02814426 . This page cites page_number 15 (0-based, as found, located by string); the sheet bears its own stamp EFTA02814441, the court’s Page 16 of 43 header, and its own internal pagination 16. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; a public PDF address IS recorded for this identifier. From this sheet this page takes: the Government’s additional fact numbered 23-a in full; and from the RESPONSE under paragraph 24, the sentences beginning The Government disputes that the allegations in this paragraph are material and ending the Government does not dispute the allegations set forth in this paragraph, together with the clause the Government's investigative decisions cannot, as a matter of law, form a basis for JPMorgan's affirmative defenses. ⚠⚠ ATTRIBUTION, CORRECTING THE COMMISSION FOR THIS PAGE. The desk asked whether the filing carrying her termination in January 2023 is the bank’s. IT IS NOT. It is the Government of the Virgin Islands’ response, which reproduces each of the bank’s numbered paragraphs above its own answer. THE QUOTED PARAGRAPH 24 IS JPMORGAN’S; THE RESPONSE BENEATH IT IS THE VIRGIN ISLANDS’. Both stand on this one sheet, and this page separates them explicitly rather than attributing the sheet to one party. ⚠ ⟦—⟧RTIAL in the caption is the extraction’s damage and is not mended. [VISION] 0 across all 43 rows. ↩ ↩² ↩³ ↩⁴ ↩⁵
Press release of the U.S. Virgin Islands Department of Justice, dated December 1, 2022, U.S. Virgin Islands Attorney General Settles Sex Trafficking Case Against Estate Of Jeffrey Epstein And Co-Defendants For Over $105 Million, filed in the JPMorgan action as Exhibit 5. EIGHT rows in pages. https://epstein-data.com/EFTA02806313 . This page cites page_number 1, 2, 3 and 4 (0-based, as found, located by string); stamps EFTA02806314 through EFTA02806317; the sheets also carry the court’s Page 2 of 8 through Page 5 of 8 headers. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From these sheets this page takes: the settlement terms $105 million in cash plus one half of the proceeds from the sale of Little St. James, $450,000 to remediate environmental damage around Great St. James and more than $80 million in economic development tax benefits; her quotation beginning This settlement restores the faith of the People of the Virgin Islands; the clause expressed gratitude to Governor Albert Bryan, who appointed her in 2019, for his commitment to ensure that justice was done; the sentence Attorney General ⟦—⟧ took office in May 2019; the clause The estate denied all wrong doing as it appears in the related press account; and the amended-complaint date Feb. 12, 2021. ⚠ Her surname is ABSENT FROM THE EXTRACTION at every occurrence on these sheets and is never supplied. ⚠ took office in May 2019 has exactly ONE carrier in this release — this sheet. The only other sheet in this release matching "took office in may" concerns an unrelated head of government and was checked and excluded. ⛔⛔ These sheets describe the trafficking of dozens of young women and children and give aggregate compensation-fund figures. NO INDIVIDUAL SURVIVOR IS NAMED, COUNTED INDIVIDUALLY, QUOTED OR DESCRIBED HERE, and no detail about any identifiable person is reproduced from them. [VISION] 0 across all 8 rows. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷
FBI form FD-302 and continuation sheets, (U//FOUO) Interview of Denise George, interview conducted 10/02/2023 in St Thomas, U.S. Virgin Islands, in person, drafted the same day, date of entry 10/06/2023. FOUR rows in pages, recorded as fbi.302a. https://epstein-data.com/EFTA00129035 . This page cites page_number 0, 1, 2 and 3 (0-based, as found, located by string). ⚠⚠ WORKED DEMONSTRATION OF THE FIVE-NUMBERS PROBLEM: page_number 0 is also producer stamp EFTA00129035, also the form’s own internal pagination -1 of 4-, also a 1-indexed wiki pin of 1, also PDF page 1. FIVE NUMBERS, ONE SHEET, and NO MAPPING IS DERIVED. Every sheet was located by STRING. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; documents.pdf_url is NULL for this identifier and the recorded file_path points into an image store that does not exist on this desk (checked). ⛔⛔⛔ THE FORM CARRIES THE FEDERAL BUREAU OF INVESTIGATION’S STANDARD LEGEND ON page_number 0: This document contains neither recommendations nor conclusions of the FBI. THAT LEGEND IS BINDING ON EVERY USE OF THIS DOCUMENT ON THIS PAGE. IT ESTABLISHES WHAT SHE SAID TO AN AGENT AND NOTHING ELSE. EVERY STATEMENT DRAWN FROM IT IS WRITTEN AS A CREDIBLE ALLEGATION, NEVER AS A DOCUMENTED FACT ABOUT THE UNDERLYING EVENTS. From page_number 0 this page takes: the clause requested to file a complaint; GEORGE did not grant EPSTEIN the waiver. The same day she informed KELLERHALS via a letter and BRYAN via an email.; and the text-message quotation you need to make a decision on the Epstein matter. From page_number 1 this page takes: BRYAN told GEORGE "He's dead go for it".; the paragraph beginning BRYAN original tone of "Go for it" changed to "End it quickly".; and the characterisation of the co-executors, which is quoted only to the three words were participants in and the following phrase, and only alongside the public denials. From page_number 2 this page takes: All EPSTEIN employees had nondisclosure agreements and were informed if questioned by law enforcement to say nothing and alert KELLERHALS.; and the single quotation "I am hearing you are going after people who are members of our team." From page_number 3 this page takes: the paragraph beginning BRYAN informed GEORGE to settle with the EPSTEIN estate for 80 million dollars; Approximately December 27, 2022, GEORGE filed action against JP MORGAN. On December 31, 2022 GEORGE was informed that she was terminated.; Several reasons were provided to the press but a listed reason was that no attorney general was going to file anything without notifying the Governor.; and the account of the cease-and-desist letter and the unknown man at her home, as quoted in the resistance log. ⛔⛔ THE FIRST SHEET CARRIES THE INTERVIEWEE’S OWN PERSONAL IDENTIFIERS. NONE IS REPRODUCED, DESCRIBED OR LOCATED. A THIRD PARTY’S TELEPHONE NUMBER ON page_number 1 IS NOT REPRODUCED. THE BUREAU’S INTERNAL FILE NUMBER IS NOT REPRODUCED. ⛔⛔ page_number 2 AND 3 NAME SEVERAL PRIVATE INDIVIDUALS IN CONNECTION WITH UNPROVEN ALLEGATIONS IN MATTERS UNRELATED TO EPSTEIN. NONE OF THEM IS NAMED ON THIS PAGE, their alleged conduct is not reproduced, and no allegation is made or repeated against any of them. The single structural element carried forward — a personnel link between the Governor’s legal office and the firm of Epstein’s Virgin Islands counsel — is stated WITHOUT A NAME and at the allegation tier. ⚠ The drafting agent is not named here. The form distinguishes the agent’s own interpolations by bracketing them as [Agent Note: …]; no Agent Note is quoted on this page. ⚠ The mixed and inconsistent quotation marks in the passages above are the extraction’s and are NOT mended. ⚠ The dates and sequences in this document are her recollection of events up to four years earlier and differ in detail from the contemporaneous correspondence cited above — in particular as to when and by whom a meeting was sought in June and July 2019. ⛔ Where the two differ, this page prefers the contemporaneous correspondence and says so. Block S over all four rows: victim 1 — read in context, Epstein’s accusers collectively; complainant 0; massage 0; underage 0; minor 0; "jane doe" 0. [VISION] 0. ⚠⚠ THIS IS THE ONE DOCUMENT IN THE SET IN WHICH THE SUBJECT IS HERSELF A COMPLAINANT. The complaint concerns alleged official interference with her own prosecution, NOT abuse of herself, and it is one document of 88. She is not written as a survivor-subject anywhere on this page. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³ ↩¹⁴ ↩¹⁵ ↩¹⁶ ↩¹⁷ ↩¹⁸
A Virgin Islands Daily News article, Bryan terminates Attorney General Denise ⟦—⟧, by a named staff reporter, Jan 1, 2023, filed in the JPMorgan action as EXHIBIT 22. NINE rows in pages, recorded as court.filing. https://epstein-data.com/EFTA02810140 . This page cites page_number 2, 3, 4, 6 and 7 (0-based, as found, located by string). The sheets bear their own stamps EFTA02810142, EFTA02810143 and EFTA02810144, and the stamps EFTA02810146 and EFTA02810147; they also carry the court’s own ECF page header — badly damaged by the extraction — and the web print’s own 2/8 through 7/8 pagination. ⚠⚠ FIVE numbers name each of these sheets and NO MAPPING between them is derived. Every sheet was located by STRING. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. ⚠ A public PDF address IS recorded in documents.pdf_url for this identifier, so image verification is reachable and simply outstanding. ⚠⚠ NO NAME-SCOPED SEARCH REACHES THIS DOCUMENT: the extraction carries the forename and not the surname. The desk located it outside the name-form set and this page inherits that; a writer screening on her name alone would not have found the single best contemporaneous record of her removal. From page_number 2 this page takes: the sentence beginning Gov. Albert Bryan Jr. has fired V.I. Attorney General Denise, in full as quoted; the sentence beginning Motta did not respond to a request for comment, in full as quoted; and the sentence Bryan, in a brief statement released late Sunday night, also gave no reason for termination. From page_number 3 this page takes: the Governor’s prepared statement as quoted, together with the newspaper’s own aside with the customary paragraph touting transparency; the sentence beginning Following that statement. Motta could not immediately be reached for comment; the clause and Justice Department spokeswoman Sandra Goomansingh did not respond to requests for comment from The Daily News; and the clause The estate and its co-executors, Darren Indyke and Richard Kahn, denied all allegations of wrongdoing. From page_number 7 this page takes the Governor’s two 2019 quotations in full as quoted. From page_number 4 and 6 this page takes nothing quoted. ⛔⛔ THIS DOCUMENT CARRIES AT LEAST FOUR TELEPHONE NUMBERS AND A MAIL ADDRESS, IN ADVERTISING AND IN A REPORTER’S SIGN-OFF. NONE IS REPRODUCED, DESCRIBED OR LOCATED. NO TELEPHONE, FAX, MAIL, HANDLE, STREET LINE OR WEB ADDRESS FROM ANY SHEET OF IT APPEARS ANYWHERE ON THIS PAGE. ⛔⛔ THE EXTRACTION RENDERS Attorney General Denise AND appointed Carol WITH THE SURNAMES ABSENT, AND LIKEWISE OMITS THE SUBJECT OF filed a lawsuit in federal court in Manhattan. WHETHER THE PRINTED PAPER CARRIES THOSE VALUES IS AN IMAGE QUESTION AND NO IMAGE IS OPENABLE ON THIS DESK. THIS PAGE THEREFORE: quotes only what the extraction returns; SUPPLIES NOTHING from context; says NOTHING about any mark, its class, its position or what it would conceal; and does NOT identify the person appointed in an acting capacity. THE MATTER IS RECORDED AS UNVERIFIED AND NOTHING FURTHER IS CLAIMED. ⚠ restore the balance of power to the executive branch is the extraction’s rendering and is NOT mended inside the quotation marks, although the sense of the surrounding passage runs the other way. ⛔ Three further matters on these sheets are deliberately NOT carried: the Governor’s spouse’s employment; a government contract held by an adult relative of the subject, together with the subject’s on-the-record answer about it; and two non-Epstein matters from her tenure, one of which concerns the death of an infant. None bears on this page’s subject, and the deceased child is not named, described or discussed here. Block S over all nine rows: victim* present on two sheets and referring in both to Epstein’s accusers collectively; massage* 0; "jane doe" 0. [VISION] 0. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³ ↩¹⁴ ↩¹⁵ ↩¹⁶
Measurements run for this page, so that every figure is reproducible and every denominator is stated. ON HER NAME-SHEETS (denominator: the 127 sheets of the union form, stated as sheets): "attorney general" 117 (92.1%); victim* 64; bare victim 47; traffick* 49; minor* 2; underage* 2; "jane doe" 2; massage* 0; complainant 0; retaliat* 0; invented control zzqvict* 0. CORPUS-WIDE (denominator: all 2,925,025 rows of pages, stated as sheets): retaliat* 1,625; "comes days after" 10 sheets in 10 documents, of which exactly ONE is hers; "notifying the governor" 1 sheet — the FD-302, and nowhere else; "bryan terminates" 2 sheets — the article and the declaration authenticating it; "gave no reason" 10 sheets, one of them hers and the others checked and unrelated. ⚠⚠ THE ABSENCE CLAIM WAS TESTED WITH HER NAME REMOVED FROM THE QUERY, because an absence claim cannot be drawn from a name-scoped set. retaliat* is abundant in this release and entirely absent from her sheets; the causal framing is absent from the record and is NOT supplied by this page. ⚠⚠ A CONTROL THAT FAILED, DISCLOSED. A first [VISION] test written as GLOB '*[VISION]*' returned 99 sheets — every one of them a FALSE POSITIVE, because GLOB reads the square brackets as a character class. Re-run with instr(), the true count on the name-form set is ZERO, and it is zero on each of the fifteen documents cited here, measured per document. ⛔ No [VISION] page is quoted anywhere on this page, and none exists in this subject’s set to quote. ⚠ Negative controls zzqdenise, zzqgeorge and zzqvict* return 0 on every screen run for this page. ⚠ COUNT(DISTINCT …) was never placed over an unbounded full-text match; every intersection above was computed as a bounded join of two rowid sets. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷
What was searched for and not found, labelled as measured-negative or as unmeasured. NEGATIVE, measured: no document in this release states a cause for her removal; retaliat* returns 0 of 127 name-sheets against 1,625 corpus-wide; "notifying the governor" returns 1 sheet corpus-wide; no letter, notice, order or memorandum of termination stands anywhere in the set; no statement by her about the removal in her own contemporaneous words stands anywhere in the set; no transcript of her deposition stands in the set, only party characterisations and an index entry; the two identifiers this desk bars outright were checked against the union set and are NOT IN IT, and are not named here because naming them would point at them. UNMEASURED, and therefore NOT negative: whether she appears in this release under a role phrase that never spells her name; whether surname renderings beyond those enumerated exist; whether the interval between the February 2020 lien correspondence and the February 2021 amended complaint is genuinely empty in this release or merely unreached by her name forms; whether the appointment, assumption of office and legislative confirmation dates of her tenure can be separated from this release; what her deposition says as opposed to what each party says it says; what the reasons for her removal were; and whether any page image matches any text layer quoted here. ⚠ Each of those is unmeasured and none is a finding of absence. ⛔ A standing desk HOLD on one individual was observed absolutely: that person was not named, searched for, researched or looked up at any point in this pass. A standing bar on one topic page was observed and the page was not approached. Two barred identifiers were checked for presence only and neither was opened. ↩ ↩² ↩³ ↩⁴
A Miami Herald article, Jeffrey Epstein case threatens to drag Virgin Islands elite into the muck. Will it matter?, dated February 14, 2020 Friday, filed in the JPMorgan action. FIVE rows in pages. https://epstein-data.com/EFTA02807748 . This page cites page_number 1 (0-based, as found, located by string); the sheet bears its own stamp EFTA02807749 and the court’s Page 2 of 5 header. No mapping between them is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the clause seemed to be painting a target on some of the island's most prominent figures, including Gov. Albert Bryan Jr., and a former first lady, Cecile de Jongh; the sentence beginning But in an interview with the Miami Herald; and the two sentences "People can only be liable for evidence that leads to them," she said. "Just because a person may be there and working, it does not mean that they committed a crime." ⚠ squelched is the newspaper’s characterisation and is attributed to the newspaper in the body, not adopted. ⚠ Her surname is ABSENT FROM THE EXTRACTION on this sheet and nothing is supplied from context. ⛔ Nothing else on the sheet is reproduced or characterised. [VISION] 0. ↩ ↩²
GVI's Second Amended Complaint in Government of the Virgin Islands v. Estate of Jeffrey E. Epstein, Superior Court of the Virgin Islands, Division of St. Thomas & St. John, its final sheet dated February 10.2021. The containing document has 253 rows in pages. https://epstein-data.com/EFTA00162121 . This page cites page_number 241 (0-based, as found, located by string); the sheet bears its own stamp EFTA00162362, prints its own internal pagination Page 76 of 76, and carries a heavily damaged header line. ⚠⚠ Four or more numbers name this sheet and NO MAPPING between them is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; documents.pdf_url is NULL for this identifier. From this sheet this page takes exactly the signature lines RESPECTFULLY SUBMITTED, DENISE N. GEORGE, ESQ. ATTORNEY GENERAL Dated: February 10.2021 /s/ Carol Thomas-Jacobs CAROL THOMAS-JACOBS, ESQ. Assistant Attorney General. ⛔⛔ THE BLOCK CONTINUES INTO A STREET LINE, A MAIL ADDRESS AND A TELEPHONE NUMBER WITH EXTENSION. NONE IS REPRODUCED, DESCRIBED OR LOCATED, AND THE QUOTATION STOPS BEFORE THEM. ⚠ February 10.2021 is the extraction’s rendering and is not mended; the office’s own later release gives the filing date as 12 February 2021 and both are reported. ⚠ The co-signatory is named because this is a public court filing and she signed it. [VISION] 0 across all 253 rows. ↩
NOTICE TO THE COURT of the Government of the Virgin Islands in the Epstein probate matter, Superior Court of the Virgin Islands, its filing dated February 11, 2020, with twenty-three further sheets of attached correspondence. 28 rows in pages. https://epstein-data.com/EFTA00087286 . This page cites page_number 0, 3 and 26 (0-based, as found, located by string); stamps EFTA00087286, EFTA00087289 and EFTA00087312. No served page numbers are asserted and no mapping is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; documents.pdf_url is NULL for this identifier. From page_number 0 this page takes the dated sequence of the lien and the Estate’s objection, and the clause On February 6, 2020, the Attorney General responded by email, and offered to schedule a meeting with the Estate the following day. From page_number 3 this page takes nothing quoted; it establishes the filing date and her signature of record. From page_number 26 this page takes her reply of Monday, February 10, 2020 12:46 PM, from We are indeed very interested in meeting with the victims as far as regarding their program as proposed. ⛔⛔ THE MESSAGE SHE WAS REPLYING TO, ON AN ADJACENT SHEET, DESCRIBES INDIVIDUAL CLIENTS OF VICTIMS’ COUNSEL AND THEIR WISHES. NOTHING FROM IT IS REPRODUCED, PARAPHRASED, COUNTED OR CHARACTERISED HERE BEYOND THE BARE FACT THAT COUNSEL PROPOSED A MEETING. NO SURVIVOR IS IDENTIFIED OR DESCRIBED. ⛔ The mail fields throughout this document are withheld or damaged and are not reproduced or supplied; a street line in her signature block is not reproduced; the probate docket number is not reproduced; and the names of administrative staff with no investigative bearing are not reproduced. ⚠ 4rn is the extraction’s rendering and is not mended. ⚠ The desk’s triage notes a second copy of this document in the set and did not compare them. ⛔ Under the copy-divergence rule this page cites THIS copy only, sets no copy beside another, characterises no difference between any two copies, and builds nothing on the fact that a second exists. [VISION] 0 across all 28 rows. ↩ ↩²
DECLARATION OF FELICIA H. ELLSWORTH IN SUPPORT OF JPMORGAN CHASE BANK, N.A.'s MOTION FOR PARTIAL SUMMARY JUDGMENT, sworn under 28 U.S.C. § 1746, filed 24 July 2023. NINE rows in pages. https://epstein-data.com/EFTA02810307 . This page cites page_number 4 (0-based, as found, located by string); the sheet bears its own stamp EFTA02810311, the court’s Page 5 of 9 header, and its own internal pagination 5. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; a public PDF address IS recorded for this identifier. From this sheet this page takes the single clause Attached as Exhibit 22 is a true and correct copy of an article titled "Bryan terminates Attorney General Denise ⟦—⟧," dated January 1, 2023. ⛔ The web address printed in the same paragraph is NOT reproduced. No street line from this document is reproduced. The surname is ABSENT FROM THE EXTRACTION in the article title as printed here and is not supplied. ⚠ The declarant is named because she is the sworn author of record of this document and an attorney of record in the action. [VISION] 0. ↩ ↩²
Declaration and exhibit index in support of the United States Virgin Islands’ memorandum in opposition to JPMorgan’s motion for partial summary judgment, filed 7 August 2023. FOUR rows in pages. https://epstein-data.com/EFTA02814623 . This page cites page_number 1 (0-based, as found, located by string); the sheet bears its own stamp EFTA02814624, the court’s Page 2 of 4 header, and its own internal pagination 2. NO MAPPING is derived. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE. From this sheet this page takes: the Exhibit 9 description Transcript excerpts of the Deposition of former Attorney General Denise ⟦—⟧ taken on July 17, 2023, in this Action.; the fact that Exhibit 8 is the deposition of the former Acting Attorney General taken 13 July 2023; and the fact that Exhibits 5, 6 and 26 are marked [Sealed] or filed under seal. ⚠⚠ A SYNTHETIC ANNOTATION LAYER EXISTS ON THIS DOCUMENT AND IS NOT A PRODUCING PARTY’S MARK. The row for page_number 1 carries, appended BELOW its text layer, a block headed [═══ TRANSCRIPT ═══]. ⛔ EVERY QUOTATION ABOVE IS TAKEN FROM ABOVE THAT LINE, and the appended block is treated exactly as a [VISION] description is treated — as evidence of nothing about any sheet. ⚠ Measured for this page, that marker stands on three sheets of the name-form set, across this document and two others; the desk’s triage did not flag this document for it. ⚠ Her surname and the Acting Attorney General’s are ABSENT FROM THE EXTRACTION in the entries quoted and neither is supplied. [VISION] 0 across all 4 rows. ↩ ↩² ↩³
ATTACHMENT B PART 4 to the summary-judgment record in the JPMorgan action, filed 14 August 2023. 86 rows in pages. https://epstein-data.com/EFTA02815448 . This page cites page_number 56 (0-based, as found, located by string); the sheet bears its own stamp EFTA02815504, the court’s Page 57 of 86 header, AND its own internal pagination 274. ⚠⚠ Four numbers name this one sheet and they disagree by more than two hundred. NO MAPPING IS DERIVED and the sheet was located by STRING. TEXT LAYER ONLY — UNVERIFIED AT THE IMAGE; a public PDF address IS recorded. From this sheet this page takes EXACTLY THREE numbered paragraphs: 253, 254 and 255, in full as quoted. ⛔⛔ THE SAME SHEET CARRIES A SURVIVOR PSEUDONYM AND A DETAILED ACCOUNT OF ALLEGED ABUSE AND AN ATTEMPTED ESCAPE. NOTHING FROM IT IS REPRODUCED, PARAPHRASED, SUMMARISED OR CHARACTERISED ON THIS PAGE, THE PSEUDONYM IS NOT REPRODUCED, AND NO DETAIL ABOUT ANY SURVIVOR IS TAKEN FROM THIS DOCUMENT AT ALL. ⚠ Both Attorneys General’s surnames are ABSENT FROM THE EXTRACTION in the paragraphs quoted and neither is supplied. [VISION] 0 across all 86 rows. ↩

tags	person, usvi, attorney-general, usvi-department-of-justice, sex-offender-registration, epstein-estate, cico, jpmorgan-chase, fbi-302, termination, 2019, 2022, 2023
aliases	Denise George, Denise N. George, Denise N. George, Esq., Denise George-Counts, Attorney General Denise George

Epstein Data Wiki

Denise George

The name, and the two search traps

Block S, measured on her own sheets

28 March 2019: Epstein’s lawyer hears there is a new Attorney General

14 March to 17 June 2019: the waiver, and who actually revoked what

12 July 2019: she explains why she has not investigated him

15 January 2020 to 1 December 2022: the estate action

27 December 2022 to 1 January 2023: the filing, the firing, and four refusals

The date: three documents, three framings, and they are reconcilable

The juxtaposition is in the record, attributed, and it is a newspaper’s

Four refusals on one page of newsprint

The one rationale that reaches the record

The question, left as a question

What she alleged, ten months later, and at what tier

Resistance log

How JPMorgan Chase used her against her own government

And her own government did not dispute the point

What this release does not contain about her

Table of Contents

Backlinks

Epstein Data Wiki

Denise George

The name, and the two search traps

Block S, measured on her own sheets

28 March 2019: Epstein’s lawyer hears there is a new Attorney General

14 March to 17 June 2019: the waiver, and who actually revoked what

12 July 2019: she explains why she has not investigated him

15 January 2020 to 1 December 2022: the estate action

27 December 2022 to 1 January 2023: the filing, the firing, and four refusals

The date: three documents, three framings, and they are reconcilable

The juxtaposition is in the record, attributed, and it is a newspaper’s

Four refusals on one page of newsprint

The one rationale that reaches the record

The question, left as a question

What she alleged, ten months later, and at what tier

Resistance log

How JPMorgan Chase used her against her own government

And her own government did not dispute the point

What this release does not contain about her

Footnotes

Table of Contents

Backlinks