Epstein Data Wiki

Jacqueline Lightbody

Properties2
tagsperson, deutsche-bank, kyc, aml, compliance, butterfly-trust, nes-llc, haze-trust, 2013, 2014
aliasesJacqueline Lightbody, Lightbody, Jacqueline, J. Lightbody, Jackie Lightbody

34 min read

⚠ what this page is about, and what it is not

The Deutsche Bank anti-money-laundering compliance officer who rejected the know-your-customer files on Jeffrey Epstein’s trusts and companies, one after another, through the autumn of 2013, and who also approved them. No allegation against her was found anywhere in the release read for this page, and none is made here. ⚠⚠ A rejected KYC file is a control working. What this page documents is what she asked for, what she was told, and what happened around her decisions. ⚠ Nothing on this page turns on the identity of any client who is a private individual, and none is supplied.

WhoJacqueline Lightbody, Vice President, AML Compliance Officer, Deutsche Bank Trust Company Americas, PWM AML Compliance, 60 Wall Street, New York, per her own signature block1
In the release193 documents carry her full name; the surname alone reaches 233, of which 6 are a bibliographic citation to a different Lightbody2
Her own messages52 sender rows across 49 documents, 5 September 2013 to 14 March 20142
⭐ The document, 7 Oct 2013Her automated notice to the relationship associate: “Your KYC has been rejected.” Relationship “EPSTEIN, JEFFREY RELATIONSHIP”, customer “Butterfly Trust”3
⚠ Why it was rejected”Since this is an Irrevocable Trust, following needs to be done for the beneficiaries: i: Name and address ii: RDC & PCR searches (excluding minors)” and “Please complete Wealth Profile for Butterfly Trust”3
⚠⚠ On “excluding minors”It is a carve-out in a screening instruction. NO DOCUMENT READ FOR THIS PAGE STATES THAT ANY BENEFICIARY OF THIS TRUST WAS A MINOR3
⭐⭐ 31 Oct 2013On NES, LLC: “Unable to locate evidence of ownership that Jeffrey is the ubo/sole member or NES, LLC. Please provide. (The letter is not acceptable)”4
⭐ 4 Dec 2013On an alert escalated to her: “I agree with your assessment . This alert can be cleared. I also recommend that the relationship be marked as “High Risk” to be consistent with the existing relationship with Jeffrey Epstein.”5
What she also didShe approved. Five approval notices were read for this page, the first of them on Jeffrey Epstein himself, 5 September 20136
Rejections foundSeven dated rejection notices, 9 September to 12 December 20137

The act: a rejected know-your-customer file, 7 October 2013

At 1:18 PM on Monday 7 October 2013 she sent the relationship associate Amanda Kirby an automated notice headed “Your KYC has been rejected.” It names the relationship “EPSTEIN, JEFFREY RELATIONSHIP” and the customer Butterfly Trust, and gives two reasons:3

Reason for Rejection:1. Since this is an Irrevocable Trust, following needs to be done for the beneficiaries: i: Name and address ii: RDC & PCR searches (excluding minors)

  1. Please complete Wealth Profile for Butterfly Trust

⚠⚠ ON THE PHRASE “excluding minors”. It appears here as a carve-out inside a screening instruction: it says which beneficiaries must be run through the bank’s database searches. ⚠ NO DOCUMENT READ FOR THIS PAGE STATES THAT ANY BENEFICIARY OF THIS TRUST WAS A MINOR, and this desk draws no inference from a line of standing compliance boilerplate. It is quoted because the reason for rejection is quoted whole. The same caution is carried on Amanda Kirby’s page.3

What she was refusing was an exemption. Ten minutes later Kirby wrote back:3

Hi Jacqueline,

I was told that since this trust is not currently giving out any distributions that we do not need to have names or addresses for the beneficiaries. Is this not the case?

Nine minutes after that, at 1:37 PM, she answered in nine words:3

Hi Amanda,

This only applies to revocable trust. Thanks.

⚠ The whole of her reply is those nine words. Read against the question, it says that the no-distributions exemption is available for a revocable trust and not for this one, so the beneficiaries of the Butterfly Trust had to be named, addressed and screened before the bank would pass the file. At 3:09 PM Kirby came back a third time, telephoning first and then writing:3

Just called to ask you a quick question. Why do we need the addresses for the beneficiaries of an irrevocable trust and not a revocable trust if there are no distributions? I want to make sure I fully understand the answer before I reach out to the client for the beneficiary addresses. I have no doubt he’ll ask!

⚠ No answer to that third message appears in this document, and the desk did not find one.3

The timing is worth stating plainly. The bank opened checking and money market accounts for the Butterfly Trust on 24 January 2014, which is three and a half months after this rejection; that opening date is documented at Butterfly Trust. ⚠ No document read for this page records the file being resolved, and nothing here establishes what changed between the two dates.3

The second act: “Unable to locate evidence of ownership”, 31 October 2013

At 11:19 AM on Thursday 31 October 2013 she rejected the file on NES, LLC, carried under the bank’s internal grouping “SOUTHERN FINANCIAL RELATIONSHIP”. The reason is two lines long and the first of them is the substantive one:4

Reason for Rejection:1. Unable to locate evidence of ownership that Jeffrey is the ubo/sole member or NES, LLC. Please provide. (The letter is not acceptable)

  1. Please re-do seaches for NES. LLC with the US instead of US Virgin Islands. (Resolved - J. Lightbody

⚠ “ubo” is the bank’s own abbreviation for ultimate beneficial owner. ⚠ “or NES, LLC”, “seaches” and the unclosed bracket are as printed on the sheet, and the sheet is not corrected here. What the line records is that the bank’s AML compliance function could not establish, from what the relationship team had given it, that Jeffrey Epstein owned NES, LLC, and that a letter offered as evidence was rejected in terms.4

⚠ This was the second rejection of the same file. She had rejected it once already, at 7:51 PM on 24 October 2013, in nearly the same words and without the parenthesis about the letter. ⚠ That earlier sheet was read in the text layer only and is not quoted here.8

⚠⚠ AND THE FILE WAS APPROVED. On 14 March 2014 she sent an approval notice for a NES, LLC case. ⚠ No document read for this page records what evidence of ownership was eventually produced, and the desk does not assume that the March case and the October case are the same submission.6

”(Resolved - J. Lightbody)”

The parenthesis in the NES rejection is a form this desk can count. The string “(Resolved - J. Lightbody)” stands in 17 documents in the release: it is the annotation the bank’s own KYC system carried beside a deficiency once she had accepted the fix. The items it marks in the documents read here are ordinary onboarding defects, and they recur:9

  • a due-diligence search run against the wrong country of formation, on HBRK Associates, Inc., on Darren K. Indyke PLLC, on an attorney trust account, and on NES, LLC;
  • unticked signatory and power-of-attorney boxes.

⚠ The 17 is a count of documents carrying the string, not of distinct deficiencies: the release holds many copies of the same sheets, and the desk did not deduplicate them.9

The recurring error: the wrong country

Across four separate KYC files she sent back the same defect. The relationship team kept running the bank’s due-diligence database searches against the wrong jurisdiction, and she kept catching it:7

DateCustomerWhat she wrote about the country
9 Sep 2013The Haze Trust”Please re-run due diligence searches for The Haze Trust as the current ones were ran with the wrong country. Should be US Virgin Islands, not “Liechtenstein”.“10
10 Sep 2013J. Epstein Virgin Islands Foundation, IncSearches “were done with the wrong country. Should be US Virgin Islands, not the United States.” ⚠ text layer only11
9 Oct 2013The 2007 Jeffrey E. Epstein Insurance Trust #3”Re-run searches with correct country. Should be US Virgin Islands, not United States.”12
31 Oct 2013NES, LLC”Please re-do seaches for NES. LLC with the US instead of US Virgin Islands.”4

⚠ The direction reverses on the last row, and that is not a transcription error: for the trusts and the foundation she told them to search the US Virgin Islands rather than the United States, and for NES, LLC she told them the opposite. The point is the same in both directions: the searches had been run against a jurisdiction the entity did not belong to.7

⚠ What this does and does not show. It shows a compliance officer repeatedly returning files for a defect in the screening, over roughly seven weeks. ⚠ It does not show that the searches, once re-run, found anything, and no re-run result was read for this page.

”I believe this should say ‘Deutsche Bank’”

Her first rejection in the record is also the one that touches a sentence other pages quote. On 9 September 2013 at 5:03 PM she rejected the file on The Haze Trust in five numbered items. The first is about a single word:10

Reason for Rejection:1. Summary of client introduction (last sentence - “funds over to JPMorgan”. I believe this should say “Deutsche Bank”.

⚠ The second and third items correct the description of who the parties to the trust were:10

  1. Jeffrey Epstein is the Grantor not the Executor. Please correct on the list of parties related to the account, and check the box for “Settlor of Trust”.

  2. Please check box for “Signatory or Full POA” for Darren Indyke, since he is the Trustee.

And the fifth asks the file to point at its own precedent:10

  1. Please add a Case Comment stating what recently approved KYC has due diligence searches for Jeffrey Epstein and his source of wealth.

⚠ The question this raises, and it is a question. The bank’s own know-your-customer record for the Epstein relationship, printed on 28 August 2015, closes its introduction narrative with the words “Paul was able to get Jeffrey to bring some of his funds over to Deutsche Bank”; that record is quoted at Deutsche Bank and is a different case file printed nearly two years after this note.13 What her sheet establishes is that on 9 September 2013 she asked for that sentence to be changed from “JPMorgan” to “Deutsche Bank”. It does not establish that the later wording is the result of her note, and the desk did not find the intervening version.10

4 December 2013: an alert cleared

Deutsche Bank’s page already records, from the New York State Department of Financial Services consent order, that in October 2013 a compliance officer running background checks on the Butterfly Trust beneficiaries flagged that one of them had been alleged to be a co-conspirator, and that “the alert was cleared by citing the Approval Email”. A document behind that sentence is in the release.5

At 1:45 PM on 4 December 2013 she answered the escalation, writing to an AML compliance officer in the bank’s New Jersey service company and copying the private wealth AML/KYC mailbox:5

Hi Andrew,

In reviewing the alert against ▮ and the previous attached approval by senior management for Jeffrey Epstein, I agree with your assessment . This alert can be cleared. I also recommend that the relationship be marked as “High Risk” to be consistent with the existing relationship with Jeffrey Epstein. Thanks.

Kind regards,

Jacqueline Lightbody

Thirteen minutes later the officer forwarded her message to the relationship associate under the line “Please find the below approved clearance for ▮”.5

⚠⚠ WHAT IS AND IS NOT SAID HERE. The name of the person the alert concerned is barred on the sheet cited, and nothing about her is reproduced, characterised or inferred on this page. ⚠ The escalation she was answering is neither quoted nor cited here, and the individual it concerned is not named on this page and is not identifiable from it. ⚠ “the previous attached approval by senior management for Jeffrey Epstein” is her phrase; the approval it refers to is not in this document. The message the consent order calls the Approval Email, and Chip Packard’s part in the onboarding, are documented at Deutsche Bank. ⚠ This page does not assert that her message is the clearance the consent order describes; it records that her message exists, what it says, and that it is dated within the window the order describes.5

⚠ And note the second half of what she wrote. Alongside agreeing the alert could be cleared she recommended the relationship be marked “High Risk”. Both halves are hers and both are given here.

12 to 13 December 2013: a rejection, a push-back, and an approval signed for her

At 7:59 PM on Thursday 12 December 2013 she rejected a KYC file on a personal account application.14

At 9:22 the next morning Kirby answered her directly, copying Paul Morris:14

Hi Jacqueline,

There wasn’t any negative information that came back on ▮ in relation to Jeffrey Epstein. There wasn’t any negative information that came back at all. This is my last day before I leave for my MTA so would like to get this resolved this morning so I can open the account this afternoon.

Eight minutes later, at 9:30, Kirby told two colleagues that Lightbody was out of the office and asked them to clear the rejection so the account could be opened that afternoon. That message is quoted in full at Amanda Kirby and is not repeated here.

The bank’s own KYC file for that case records the approval going through that same day. On the printed record’s approvals sheet, the AML Compliance line carries, in the name column and again in the signature column, the words “J Franklin o/b/o J. Lightbody”, dated 13 December 2013.15

⚠⚠ THAT IS A PRINTED NAME AND NOT A SIGNATURE. No mark appears on any signature rule anywhere on that sheet: every approval row on it, including the two dated three days earlier, carries typed text under a printed “(Signature)” label. The sheet is a printout of the bank’s system record of who approved what, not an executed form, and this page says only what the record says: that the AML Compliance approval for that case was recorded on 13 December 2013 in the name of a colleague acting on behalf of J. Lightbody.15

⚠ What this does and does not close. Amanda Kirby’s page records that no document read there showed whether the 13 December rejection was overridden. This record shows the case reaching an approved state on the AML Compliance line that day, in the name of somebody signing for the absent officer. ⚠ It does not show Lightbody’s own decision, does not show what the colleague reviewed, and does not show that the substantive objection was answered rather than routed around. Whether the AML Compliance line was cleared on its merits is not established by anything read for this page.15

⚠ The client. The account was a personal one, and the file names Karyna Shuliak and a second party whose name is barred on the sheet. Nothing on this page is adverse to either of them, and the rejection’s own list of reasons is not reproduced here. ⚠ Karyna Shuliak’s page does not yet cover this account, and the two pages are owed a reconciliation.15

What she approved

She is not only a rejecter, and a page built only on the rejections would be a false one. Five approval notices sent under her name were read for this page:6

DateCustomerNote
5 Sep 2013, 12:24 PMEpstein, JeffreyOne minute later Kirby forwarded it to Paul Morris: “All is a go for JE! Once we get the account docs back they can be opened right away”
17 Oct 2013, 12:32 PMEpstein, JeffreyA second case in his own name
14 Mar 2014, 3:14 PMNeptune, LLC⚠ text layer only
14 Mar 2014, 3:29 PMNES, LLC⚠ text layer only
14 Mar 2014, 4:17 PMHyperion Air LLC⚠ text layer only; the customer name is damaged in the extraction

⚠⚠ THE FIRST ROW IS THE IMPORTANT ONE AND IT NEEDS CARE. The notice of 5 September 2013 is an approval of a know-your-customer case in Jeffrey Epstein’s own name, sent under hers. Deutsche Bank’s page records, from the consent order, that the relationship began on 19 August 2013 and that “An AML compliance officer cleared the relationship on the strength of the email” of 5 May 2013. ⚠ This page does not say she is that officer. The consent order does not name the officer, the September notice is a case-level approval rather than a relationship clearance, and the desk found no document identifying the two. What would settle it is the bank’s own clearance record for the initial onboarding, which was not found in the material read here.6

⚠ The three notices of 14 March 2014 are her last messages in the e-mail metadata store. That is a statement about the store’s coverage, not about her employment, and nothing read for this page says when she left the role.2

Chronology

DateWhat the documents showProvenance
5 Sep 2013Approves a KYC case in the name Epstein, Jeffrey; the associate tells the relationship manager “All is a go for JE!“image6
9 Sep 2013Rejects The Haze Trust in five items, including the “JPMorgan” / “Deutsche Bank” correction and a wrong-country searchimage10
10 Sep 2013Rejects J. Epstein Virgin Islands Foundation, Inc; wrong country, authorised signer, and a board resolution naming an a/k/atext layer11
7 Oct 2013⭐ Rejects Butterfly Trust: beneficiaries not named, addressed or screened; no wealth profile. Refuses the exemption the same afternoonimage3
9 Oct 2013Rejects the file in the name of Darren Indyke, covering four entities and trustsimage12
24 Oct 2013Rejects NES, LLC: no evidence of ultimate beneficial ownershiptext layer8
31 Oct 2013⭐ Rejects NES, LLC again, adding “(The letter is not acceptable)“image4
7 to 8 Nov 2013Four and three sender rows on the NES, LLC case; ⚠ not read for this pagestore only2
4 Dec 2013⭐ Agrees an escalated alert can be cleared, and recommends the relationship be marked “High Risk”image5
12 Dec 2013Rejects a KYC file on a personal account applicationimage of a forward14
13 Dec 2013Out of the office. The AML Compliance approval for that case is recorded as “J Franklin o/b/o J. Lightbody”image15
24 Jan 2014Deutsche Bank opens the Butterfly Trust’s accountsdocumented at Butterfly Trust
14 Mar 2014Three approval notices; the last of her sender rows in the storeimage of one; text layer for the rest6

⚠ Every row is a document, not an event reconstructed from one. ⚠ The 24 January 2014 row is carried across from a sibling page and was not re-derived here.

The measurement

"Jacqueline Lightbody" reaches 193 documents. The bare surname reaches 233.2

  • ⚠ The surname is the larger set and it is not all her. Six of the 233 are a bibliographic citation, Fernandez, Marshall, Lightbody & O'Sullivan, 1999, inside a clinical literature review that has nothing to do with the bank. That leaves 227 documents attributable to her as a floor, not a total.
  • The other 34 surname-only documents are her, reached by forms the full name misses: “J. Lightbody” in an approval annotation, “Jacqueline Lightbody” inside a copy-line that the extraction has damaged, and lower-case and mangled renderings of the forename.
  • In the e-mail metadata store she is the sender of 52 rows across 49 documents, 5 September 2013 to 14 March 2014. ⚠⚠ A looser match on the sender field returns 65 rows, and 13 of those are extraction damage: a copy-line naming her has been swallowed into the sender field, so the row’s real sender is somebody else. A sender figure taken from the loose match overstates her by a quarter.
  • Rates, with both denominators. Her 52 sender rows are 0.0024% of the store’s 2,143,804 rows and 0.0028% of the 1,848,452 rows that carry any sender at all. ⚠ Neither number means anything about her importance; they are printed because a rate without its denominator is not a measurement.
  • ⚠ She is in the store earlier and later than she sends. Copy-line matches run from 13 August 2013 to 26 October 2014. ⚠ The later date rests on one row whose date field the parser may have derived from a damaged stamp, and it is not relied on here.
  • ⚠ No doc_type figure is printed, under the rule in _desk/TOOLS.md.2

What this page does not say

No allegation against her was found in the release read for this page.16

⚠⚠ NOTHING HERE SUGGESTS SHE DID ANYTHING IMPROPER. In every document read she is the person asking for the missing evidence, refusing an exemption, correcting a description of who owned what, or recording a decision in writing. Where she cleared something she said in the same message why, and recommended a high-risk marking at the same time.

⚠ Whether Deutsche Bank’s controls were adequate is an institutional question and belongs at Deutsche Bank, not to any individual named here. The New York State Department of Financial Services found in its consent order of 6 July 2020 that the bank classified Epstein as high-risk and then failed to scrutinise the accounts for the conduct that classification implied; that finding is about the bank.

⚠ The gaps, each scoped:

  • The desk opened ten sheets across nine documents for this page and read them at the image. Of the 193 documents carrying her name, it has read a fraction and says so.
  • No resolution is documented for the Butterfly Trust rejection, and the gap between 7 October 2013 and the accounts opening on 24 January 2014 is unexplained by anything read here.
  • Her four sender rows of 7 November and three of 8 November 2013 on the NES, LLC case were not opened. They are the largest unread block of her own writing.
  • The escalation of 3 December 2013 was read and is deliberately not cited, for the reason given above.
  • No systematic adverse sweep was run, and none of the six derived stores was searched.
  • Nothing read for this page says when she joined or left the role, and the 14 March 2014 endpoint is a property of the e-mail store.

Footnotes

Footnotes

  1. Identification. Title, employer and office are taken from her own signature block as it prints on EFTA01404859 p.2, read at the image at 700 dpi: Jacqueline Lightbody / Vice President | AML Compliance Officer / Deutsche Bank Trust Company Americas / PWM AML Compliance / 23rd Floor / 60 Wall Street, 10005-2836 New York, NY, USA. The | is a vertical bar on the sheet. ⚠ Telephone, fax and e-mail are barred on that sheet, and no contact value for her is reproduced on this page. The address is a bank office floor, not a residence. ⚠ A colleague addresses her as “Jackie” in one document read for this page; that form is recorded in the aliases and is not used in the prose. ↩

  2. The measurement, and its route. Document counts were taken twice by two routes that agree: locally against full_text_corpus.db and again over the site’s read-only SQL endpoint, in both cases as count(distinct efta_number) over pages_fts joined to pages, with the query scoped text_content : (...). "Jacqueline Lightbody" = 193; "Lightbody" = 233; "Marshall Lightbody", the bibliographic form, = 6; "Resolved J Lightbody" = 17. ⚠ The tokeniser is plain unicode61 and splits on ., , and -, so "Lightbody, Jacqueline" and "Lightbody Jacqueline" are one query, and the middle-initial and surname-first forms were run and are inside the 233. ⚠ The full name is a strict subset of the surname here: 193 of 233, with 0 documents carrying the full phrase and not the surname token. In the e-mail metadata store emails_merged she is the sender of 52 rows across 49 documents, 5 September 2013 to 14 March 2014; the looser match sender LIKE '%Lightbody%' returns 65 rows, of which 13 are rows whose sender field has swallowed a copy-line naming her and whose real sender is another person. Store totals used as denominators: 2,143,804 rows, 1,848,452 rows with any sender, 1,117,562 distinct documents. ⚠ These are ROW counts, not distinct messages: the release holds the same message many times. ⚠ No doc_type figure is printed, under the rule in _desk/TOOLS.md. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  3. 7 October 2013. EFTA01404859, a three-sheet chain of four messages, all four on the same day. All three sheets were rendered and READ AT THE IMAGE at 700 dpi. p.3, whose own page stamp reads EFTA01404861, carries the rejection notice: Your KYC has been rejected. above Case #: 01133113, Relationship: EPSTEIN, JEFFREY RELATIONSHIP, Customer Name: Butterfly Trust, the reason quoted above, and a link into the bank’s case system. ⚠ A customer number prints beside those lines and is NOT reproduced here, under the desk’s standing bar on account and customer identifiers; the case-system link is described and not reproduced. p.2, page stamp EFTA01404860, carries her 1:37 PM reply and, beneath it, Kirby’s 1:28 PM question. p.1, page stamp EFTA01404859, carries Kirby’s third message. ⚠ On the clock: the notice and the two replies carry Lotus Notes stamps with no time zone reading 1:18 PM, 1:28 PM and 1:37 PM on 7 October 2013, while the message on p.1 carries an RFC-form header for the same day timed 15:09:03 and carrying a -0400 offset. The zoned header places the chain in Eastern daylight time and the four messages then run in order; the bare stamps are given as printed and are not converted. ⚠ The double spaces in the quotations are as printed. ⚠ The [I] marking in the subject line is the bank’s own and is not expanded, because nothing read here expands it. The sheets carry CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e). ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11

  4. 31 October 2013, and it is the only sheet quoted in this section. EFTA01361294 p.1, a single sheet, rendered and READ AT THE IMAGE at 700 dpi: Your KYC has been rejected. above Case #: 01141322, Relationship: SOUTHERN FINANCIAL RELATIONSHIP, Customer Name: NES, LLC, and the reason quoted above, timed 11:19:04 AM on 31 October 2013. ⚠ A customer number prints on the sheet and is not reproduced. ⚠ “or NES, LLC” for “of NES, LLC”, “seaches” for “searches”, and the unclosed bracket after “J. Lightbody” are all as printed at the image, not extraction damage; the text layer of this sheet additionally renders US as us twice and the image governs. ⚠ Why a checker will flag this footnote and why the pin is right: the 24 October sibling notice, given its own footnote below, carries a damaged version of the same sentence and NOT the quoted one, so a string search that reaches that copy will fail; the quotations in this section come from the 31 October sheet and from nowhere else, and no identifier for the sibling is written into this note. The sheet carries CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) with production stamps DB-SDNY-0050418 / SDNY_GM_00196602. ↩ ↩2 ↩3 ↩4 ↩5

  5. 4 December 2013. EFTA01360501 p.1, a single sheet, rendered and READ AT THE IMAGE at 700 dpi. The sheet is a forward timed 1:58 PM on 4 December 2013 by an associate AML compliance officer at DB Services New Jersey, Inc. to Amanda Kirby, carrying beneath it her message timed 1:45 PM the same day, subject Re: ESCALATION_▮, to that officer and copied to the private wealth AML/KYC mailbox. ⚠⚠ THE NAME OF THE PERSON THE ALERT CONCERNED IS BARRED ON THIS SHEET IN THREE PLACES, in the forwarding line, in the subject and in the body, and the bars in the quotation are marked ▮ because they are on the image, not because the extraction is damaged. ⚠ The spacing in "your assessment ." is as printed. ⚠ Why a checker will flag two rows from this footnote and why the pins are right: both quotations contain a ▮ standing for a bar on the image, and the extraction closes the gap with a line break instead, so neither quoted span is contiguous in the text layer. The bars were read at the image; they are not drawn from the extraction. ⚠ The escalation message she was replying to is a different document and is neither quoted nor cited here. What the consent order says about this episode is quoted at Deutsche Bank and is not restated here. Production stamps DB-SDNY-0048905 / SDNY_GM_00195089. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  6. The approvals. 5 September 2013: EFTA01387879 p.1, a single sheet, rendered and READ AT THE IMAGE at 700 dpi, a forward by Kirby to Paul Morris timed 12:25:35 PM on 5 September 2013, carrying the notice timed one minute earlier: The KYC you had submitted has been approved. above Case #: 01121718 and Customer Name: Epstein, Jeffrey. ⚠⚠ THE TEXT LAYER RENDERS KIRBY’S LINE AS "All is a go for 7E!"; THE SHEET READS "All is a go for JE!". A single fabricated character turned initials into what looks like an apartment or account label, and the image governs. ⚠ A customer number prints on the sheet and is not reproduced; the case-system link is described and not reproduced. 17 October 2013: EFTA01361174 p.1, timed 12:32:20 PM on 17 October 2013, Customer Name: Epstein, Jeffrey, read in the TEXT LAYER only. 14 March 2014: three notices, EFTA01357464 p.1 timed 3:14:09 PM for Neptune, LLC, EFTA01361244 p.1 timed 3:29:40 PM for NES, LLC, and EFTA01361298 p.1 timed 4:17:49 PM for a customer the extraction renders as H then rion Air LLC, all three read in the TEXT LAYER only and none rendered. ⚠ The Neptune, LLC notice exists in a second copy whose subject line the extraction mangles to Your KYC has been af:; that is extraction damage and not a different message. ⚠ Five approvals were read; the desk does not claim these are all she sent. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  7. The rejection census. Built from emails_merged grouped by date_sent over the 52 clean sender rows, then read against the documents themselves. Seven dated rejection notices: 9 September, 10 September, 7 October, 9 October, 24 October, 31 October and 12 December 2013. ⚠ The store also shows five rows dated 13 December 2013 with her as sender; those are the 12 December notice reproduced inside forwarded chains, as the sheet read at the image for 14 shows, and they are not counted as an eighth rejection. ⚠ Seven is a floor and is a count of NOTICES, not of files: the 24 and 31 October notices concern the same case, and the release holds several copies of most of them. ⚠ Four of the seven were read at the image, two in the text layer only, and one, 12 December, only as a header inside a forward. ↩ ↩2 ↩3

  8. 24 October 2013, the earlier notice on the same case, quoted nowhere on this page. EFTA01360829 p.1, a single sheet, timed 7:51:59 PM on 24 October 2013, same case number and customer as the 31 October notice. ⚠⚠ THIS SHEET WAS NOT RENDERED AND WAS READ IN THE TEXT LAYER ONLY, SO NOTHING IS QUOTED FROM IT. Its extraction reads unable to locate locate evident of ownership, a doubled word and a wrong one, which is the reason no quotation is taken from it and the reason the desk treats the 31 October sheet as the only quotable copy. Production stamps DB-SDNY-0049412 / SDNY_GM_00195596. ↩ ↩2

  9. The annotation count. The phrase query "Resolved J Lightbody" returns 17 documents by the route given at 2. ⚠ It is a count of documents, not of deficiencies or of distinct sheets; several of the 17 are further copies of the 9 October and 31 October chains. One of the 17 was read at the image, EFTA01361294 p.1, where the annotation prints as (Resolved - J. Lightbody with the bracket unclosed. The remaining sixteen were read in the text layer only, and the items summarised above are taken from those extractions; no wording is quoted from them. ↩ ↩2

  10. 9 September 2013. EFTA01361245 p.1, a single sheet, rendered and READ AT THE IMAGE at 700 dpi, timed 5:03:58 PM on 9 September 2013: Case #: 01121946, Relationship: EPSTEIN, JEFFREY RELATIONSHIP, Customer Name: The Haze Trust, five numbered reasons of which items 1, 2, 3 and 5 are quoted above and item 4 in the table. ⚠⚠ THE TEXT LAYER OF THIS SHEET IS WRONG IN THREE PLACES AND THE IMAGE GOVERNS: it renders "funds over to JPMorgan" as "funds over to 3PHorgan", US Virgin Islands as DS virgin Islands, and the whole field Customer Name: The Haze Trust as Customer NUM: followed by Th H Tr St. A desk working from the extraction would have had a garbled bank name in the sentence this item is about. ⚠ The customer number is partly barred on the sheet and is not reproduced. ⚠ Why a checker will flag the "funds over to JPMorgan" row and why the pin is right: that string is on this sheet at the image and is NOT in this sheet’s extraction, which reads funds over to 3PHorgan; the same applies to US Virgin Islands, extracted as DS virgin Islands. The rows are the extraction, not the pin. ⚠ The later KYC record of 28 August 2015 is a separate document with its own footnote and its own citation; nothing from it is pinned to this sheet. Production stamps DB-SDNY-0050308 / SDNY_GM_00196492. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  11. 10 September 2013. EFTA01361960 p.1, timed 1:07 PM on 10 September 2013, Case 8: 01122241 as the extraction renders it, Relationship: EPSTEIN, JEFFREY RELATIONSHIP, Customer Name: J. Epstein Virgin Islands Foundation, Inc. ⚠⚠ THIS SHEET WAS NOT RENDERED AND WAS READ IN THE TEXT LAYER ONLY. The wording in the table is therefore marked as text-layer and the third reason, which asks about a board resolution listing "Enhanced Education" as an a/k/a for the foundation, is described and not quoted. Enhanced Education has its own page and this sheet was not used to add anything to it. ⚠ A customer number prints in the extraction and is not reproduced. ↩ ↩2

  12. 9 October 2013. EFTA01361251 p.1, a single sheet, rendered and READ AT THE IMAGE at 700 dpi, timed 1:04:50 PM on 9 October 2013, Relationship: EPSTEIN, JEFFREY RELATIONSHIP, Customer Name: Indyke, Darren. The notice covers four holdings in one file: The 2007 Jeffrey E. Epstein Insurance Trust #3, HBRK Associates, Inc. (both accounts), Darren K. Indyke PLLC, and New York Strategy Group, LLC (both account);. ⚠ The case number and the customer number are barred on this sheet and nothing is recovered from either; the bar over the case number under-covers and the desk did not read through it. ⚠ The second Indyke item asks whether an attorney trust account is an IOLA account and challenges its stated purpose, "for the daily use of the company's needs", on the ground that "If this is a clients esrow account this purpose would not apply." ⚠ “esrow” is as printed. ⚠ New York Strategy Group, LLC has no page on this wiki and nothing further about it was searched for here. Production stamp SDNY_GM_00196514. ↩ ↩2

  13. The later KYC record, cited for comparison only. EFTA01360427 p.1, the bank’s global know-your-customer case record for the EPSTEIN, JEFFREY RELATIONSHIP printed on 28 August 2015, is the record Deutsche Bank cites for the introduction narrative. ⚠⚠ THIS SHEET WAS NOT RENDERED AND WAS READ IN THE TEXT LAYER ONLY BY THIS DESK; the desk opened it rather than relay the sibling page’s quotation unchecked. ⚠ The sentence prints down a narrow field and the extraction breaks it across seven short lines, so a contiguous phrase search for it fails and a checker will report the row as unresolved; the words are in order and unbroken apart from the line ends. ⚠ The case number on that record is not the case number on the 9 September rejection, and no claim is made here that the two are the same file. ↩

  14. 12 and 13 December 2013. EFTA01360380 p.1, a single sheet, rendered and READ AT THE IMAGE at 700 dpi: a forward by Kirby timed 9:27 AM on 13 December 2013 carrying her own message to Lightbody timed 9:22 AM that morning, copy to Paul Morris, subject Fw: Your KYC has been rejected, classified Public; and beneath that the header of Lightbody’s notice timed 7:59 PM the previous evening, subject Your KYC has been rejected. ⚠⚠ THE BODY OF THE REJECTION IS NOT ON THIS SHEET, which ends at the header, so nothing about the reasons for it is taken from here. ⚠ The client’s name is barred in Kirby’s message and is marked ▮; the bar is on the image. ⚠ The image reads MTA; a copy’s text layer reads MIA, and the image governs. The desk does not expand the abbreviation. ⚠ The rejection’s numbered reasons are not reproduced on this page; they concern a private individual’s finances and nothing here turns on them. ⚠ The double spaces are as printed. Production stamps DB-SDNY-0048692 / SDNY_GM_00194876. ↩ ↩2 ↩3 ↩4

  15. The approvals sheet, 13 December 2013. EFTA01255026 p.10, whose own page stamp reads EFTA01255035, rendered and READ AT THE IMAGE at 700 dpi. ⚠⚠ THE RUN IS ELEVEN SHEETS AND IT IS A MIXED FILE, NOT A LETTER: it is the bank’s DB PWM GLOBAL KYC/NCA print for one case, and its sheets include relationship details, account ownership, expected flows, case comments and the approvals block. Its first sheet gives the case number, the relationship SOUTHERN FINANCIAL RELATIONSHIP and a relationship manager, and names the account holders. ⚠ The case number is not reproduced on this page. p.10 carries two boxes, ONSHORE APPROVALS and LATAM/INTERNATIONAL APPROVALS. In the onshore box the AML Compliance: row reads J Franklin o/b/o J. Lightbody in the name column, J Franklin o/b/o J. Lightbody beneath the printed label (Signature), and 13 December 2013 in the date column. ⚠⚠ NO INK MARK APPEARS ON ANY SIGNATURE RULE ON THE SHEET: the rows for the client-facing professional and the office director, both dated 10 December 2013, and for AML business risk, dated 13 December 2013, are typed in exactly the same way, and the entire LATAM/INTERNATIONAL APPROVALS box is empty. This is a system record of approvals, not an executed document, and it is described here as such. ⚠⚠ Why a checker will flag this footnote and why the pin is right: the extraction of this sheet renders the name column as 3 Franklin o/b/o J. Lightbocty and the signature column as 3 Franklin o/b/o J. Lightbody, so a search for the form printed at the image, J Franklin o/b/o J. Lightbody, finds the second and not the first. The damaged renderings are given here so the row can be read rather than re-litigated. ⚠ The image also corrects a case comment the extraction gives as PEI client to PB client. ⚠ The case-comments box on the same sheet contains material about private individuals, partly barred; none of it is reproduced or characterised here. Production stamps DB-SDNY-0016356 / SDNY_GM_00053532. ↩ ↩2 ↩3 ↩4 ↩5

  16. Absences, each scoped. No allegation against her was found in the release read for this page. ⚠⚠ This is a narrow check and is stated as one: of the 193 documents carrying her name, the desk opened ten sheets across nine documents at the image and a further handful in the text layer. It ran no systematic adverse sweep, searched none of the six derived stores, and opened none of the seven November 2013 rows on the NES, LLC case. ⚠ A deeper pass is owed, and this page records the debt rather than implying it does not exist. ↩

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