Epstein Data Wiki

Janice Franklin

Properties2
tagsperson, deutsche-bank, kyc, aml, compliance, pep, southern-financial, 2013, 2014, 2018
aliasesJanice Franklin, Franklin, Janice, Janice P. Franklin, J Franklin, J. Franklin, Janice P Franklin

36 min read

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

The Deutsche Bank anti-money-laundering compliance officer who worked the Epstein know-your-customer files alongside Jacqueline Lightbody from August 2013, and who in October 2018 recorded the bank’s determination that Jeffrey Epstein should be treated as a Relative or Close Associate of a politically exposed person and that every entity he ultimately owned or controlled should be automatically rated high risk. No allegation against her was found in the release read for this page, and none is made here. ⚠⚠ A rejected know-your-customer file is a control working. What this page documents is what she asked for, what she decided, and what she was told. ⚠⚠ THE CENTRAL DISTINCTION ON THIS PAGE IS BETWEEN AN AUTOMATED NOTICE AND A HUMAN DECISION, and it is drawn on every instance. See “What a notice is, and what it is not” below. ⚠ Nothing here turns on the identity of any client who is a private individual, and none is supplied.

WhoJanice Franklin, CAMS, CFSA, CFIRS, Vice President, AML Compliance Officer, Deutsche Bank, 60 Wall Street, New York, per her own signature block1
⭐⭐ The document, 19 Oct 2018”I agree with your assessment that Mr. Epstein should be treated as a RCA. Hence, all clients where he is UBO or has a significant controlling role should be automatically risk rated “High""2
What that sentence isProse in her own voice over her own sign-off, answering a written escalation. It is not a system notice.2
⭐ 9 Oct 2013A seven-item rejection across five Epstein entities, item 6 of which reads “Please include Mr. Espstein’s source of wealth in KYC”3
⭐⭐ 3 Mar 2014To the relationship associate, on a letter adding Darren Indyke as a signer: “Did you assist Mr. Epstein with the drafting of his letter which states that Mr. Indyke should be added as an additional signer…“4
13 Dec 2013The bank’s printed case record shows the AML Compliance approval recorded as “J Franklin o/b/o J. Lightbody”. ⚠⚠ A PRINTED NAME, NOT A SIGNATURE5
In the release347 documents carry her full name; with the middle-initial form the union is 3506
Her own messages190 sender rows across 135 documents, 21 August 2013 to 19 October 20186
Her rejections47 sender rows across 42 documents carry a rejection subject, 5 September 2013 to 25 April 20146

The act: 19 October 2018, and it is the latest document on this page by four years

On Friday 19 October 2018 at 2:30 PM an AML compliance officer in the bank’s Jacksonville office, Gwen Hill, wrote to her about the politically exposed person status of the bank’s Epstein relationship. Hill’s message sets out the problem in two sentences:2

The purpose of this email is to address the PEP status of Jeffery E. Epstein, an existing Wealth Management client through the Southern Financial Relationship. Although the PEP status was factored into the prior risk calculator, the client was never formally escalated as a PEP.

⚠ “Jeffery” is the spelling on the sheet and is not corrected here. Hill then gives her reason, and the reason is press reporting:2

It has been reported in the media that Mr. Epstein has maintained a close relationship with Prince Andrew, Duke of York and member of the British Royal Family and former US President, Bill Clinton. Several media sources have reported Mr. Clinton and Prince Andrew have used Mr. Epstein’s private passenger jet “Lolita Express” on numerous occasions.

The relationship is currently “High” Risk. Although Mr. Epstein was treated as an honorary PEP in the past, he was never formally escalated as a PEP. BLAFC-WM reached out to the business and they agreed he should remain a PEP. Please let us know if you agree that Mr. Epstein should be treated as a Relative or Close Associate (RCA) of a PEP due to his connections to Prince Andrew and Bill Clinton.

At 5:16 PM the same afternoon Franklin answered, in two sentences of her own:2

Hi Gwen:

I agree with your assessment that Mr. Epstein should be treated as a RCA. Hence, all clients where he is UBO or has a significant controlling role should be automatically risk rated “High”

⚠ The double space after “RCA.” and the absence of a full stop after the closing quotation mark are as printed. ⚠ “UBO” is the bank’s own abbreviation for ultimate beneficial owner, used the same way on Jacqueline Lightbody’s 31 October 2013 rejection of NES, LLC.

⚠⚠ WHY THIS IS THE ANCHOR AND NOT A NOTICE. It is free prose, addressed to a named colleague by her first name, answering a question that had been put in writing, and it ends with her own sign-off and signature block. No template language appears anywhere in it. She was asked for a decision and she gave one, and she extended it beyond what she was asked: Hill asked only about Mr. Epstein’s own classification, and Franklin’s second sentence applies the consequence to every client where he is the ultimate beneficial owner or holds a significant controlling role.2

Three days later, on Monday 22 October 2018 at 8:53 AM, Hill forwarded the exchange to the private wealth AML/KYC mailbox under a subject line beginning “CLEARED:”.2 ⚠ What that word settles and what it does not. It records that the escalation was closed. ⚠ No document read for this page shows what the bank then did about the accounts, and nothing here asserts that the automatic high rating she described was applied to any particular account. Jeffrey Epstein was arrested nine months later, on 6 July 2019.

⚠ The relationship’s risk rating was already “High” before this exchange, on Hill’s own statement, and Deutsche Bank’s page records the New York State Department of Financial Services finding that the bank classified Epstein as high risk and then failed to scrutinise the accounts accordingly. The question this document raises, and it is a question: what changed in the bank’s handling of the relationship after 22 October 2018? Nothing read for this page answers it.

What a notice is, and what it is not

This matters more on this subject than on any other at this bank, because the largest block of her traffic carries a subject line a machine wrote. “Your KYC has been rejected” and “Your KYC has been approved!” are template subjects, and the bodies under them open with template sentences. ⚠ The desk did not assume the answer in either direction. It read the sheets.

What the sheets show is a system envelope carrying an authored decision. A rejection notice sent under her name is laid out as a form, and the form has one free-text field:3

Part of the noticeWho wrote it
”Your KYC has been rejected.”, the case and relationship lines, and the closing line offering a link into the bank’s case systemThe system. Byte-identical across every copy read
”Reason for Rejection:” and everything after itHer. Numbered, entity by entity, in ordinary English, with her own typing errors reproduced from notice to notice

Three independent things settle it.

  1. The reason fields are not interchangeable. One runs to seven numbered items across five named companies; another is a single line asking for a certificate of good standing.37
  2. Her colleagues answered the reason field as if a person had written it, and addressed her by name. On 25 October 2013 Amanda Kirby forwarded one of these notices back to her: “Hi Janice, For the below rejection point does the secretary just need to sign schedule G? Should the signature be notarized?” ⚠ text layer only8
  3. The same typing errors recur. “Pease complete section 3D” stands five times on one sheet, and the possessive “Mr. Espstein’s” once. A template does not misspell its own client’s name once and get it right everywhere else.3

⚠⚠ AND THE CONVERSE IS STATED JUST AS PLAINLY. On an approval notice there is no free-text field. The approvals read for this page consist of the template sentence, the case and customer lines, and an instruction to forward the message as proof. ⚠ They establish that a case reached an approved state with her name on the notice. They do not, on their own faces, record anything she wrote, and no approval read for this page carries a reason, a condition or a comment in her words.9

9 October 2013: a seven-item rejection, and a missing source of wealth

At 9:09:17 AM on Wednesday 9 October 2013 she rejected a know-your-customer file carried under the relationship name “EPSTEIN, JEFFREY RELATIONSHIP” and the customer name “Epstein, Jeffrey”. The reason field runs to seven numbered items covering five companies: Hyperion Air LLC, Plan D LLC, Hyperion Air Inc, JEGE Inc and JEGE LLC.3

Five of the seven are the same defect, repeated company by company: the bank’s own form was incomplete and the signatories were not recorded.

  1. Plan D LLC i. Pease complete section 3D ii. due diligence searches were not located iii. J. Epstein not listed as a signer on the checking account iv. J. Epstein not listed as a signer on the money market account

⚠ “Pease” for “Please” is on the sheet and recurs at the head of every company’s sub-list. Item 3 also catches the wrong-jurisdiction defect that Jacqueline Lightbody was returning files for in the same weeks, here in the opposite direction: “Please rerun searches (country was incorrectly stated—should be USA)”.3

⚠⚠ ITEM 6 IS THE ONE THAT MATTERS AND IT IS EIGHT WORDS LONG:3

  1. Please include Mr. Espstein’s source of wealth in KYC

What that line records is that on 9 October 2013, roughly seven weeks after the relationship was opened, the file in front of the bank’s AML compliance function did not state where its client’s money came from, and she sent it back for that reason. ⚠ It does not record that the bank did not know; it records that this file did not say. ⚠ No document read for this page shows what was supplied in answer. Jacqueline Lightbody’s 9 September 2013 rejection of The Haze Trust had asked a related question five weeks earlier, requiring the file to point at a “recently approved KYC” carrying due diligence searches and a source of wealth for Epstein.

Item 7 concerns a second individual. The sheet asks, for “Mr. Beller”, that his current employer, his employer’s address and his due diligence searches be supplied, and items 1 and 3 record that “H. Beller” was not listed as a party to two of the accounts. ⚠ The sheet gives no forename. Harry Beller is the accountant Deutsche Bank’s own know-your-customer file records on the Epstein entity accounts, and the identification is made on that basis and is stated here as an identification rather than as something the sheet says.3

25 February to 4 March 2014: compliance asks who drafted the client’s letter

Her largest single cluster of messages is not a notice at all. In the last week of February and the first week of March 2014, 88 of her sender rows, across 53 documents, carry a subject in the “Additional signer” family, and what they contain is an interrogation of a client instruction.6

The instrument at issue was a letter over Epstein’s name asking that Darren Indyke be added as an additional signer. ⚠ The letter itself was not read for this page. Her first question, on 25 February 2014 at 5:27 PM, is about scope: she asks which previously approved file was being updated, whether Indyke was being added to the Southern Trust Company accounts as well, and whether both Beller and Indyke were being added to Epstein’s accounts. ⚠ text layer only, and not quoted here10

On Monday 3 March 2014 at 12:15 PM EST, with Kirby stranded away from the office and Jacqueline Lightbody copied, she put the question that the whole thread turns on:4

Did you assist Mr. Epstein with the drafting of his letter which states that Mr. Indyke should be added as an additional signer “on all accounts associated with [the “Southern Financial Relationship”]? If I take the letter literally, Mr. Indyke should not be added to all of Mr. Epstein’s accounts. How do you know it was Mr. Epstein’s intent to add Mr. Indyke to all his accounts given that all accounts are not under the “Southern Financial Relationship”?

⚠ The square brackets are hers and are on the sheet; the extraction renders them as round brackets, and the image governs. ⚠ The double spaces are as printed.

⚠⚠ READ THE FIRST SENTENCE FOR WHAT IT ACTUALLY ASKS. It asks the bank’s own relationship associate whether she helped write the client’s instruction to the bank. That is a question about whether an instrument the bank was about to act on was the client’s independent act or the bank’s own drafting, and it was asked by compliance, in writing, with a second compliance officer copied. ⚠ Nothing read for this page records an answer to that first question. What Kirby answered was the second and third:4

I spoke with Jeffrey and he said he wanted Darren added to all of his accounts including his personal and Southern Trust. They do most wires out of his personal account and he wants Darren to be able to sign for them. I also am still under the impression that his personal and ST accounts are under the Southern Financial Relationship as that is how I see them on DBForce.

Does this help?

⚠⚠ SO THE WRITTEN INSTRUMENT WAS ANSWERED WITH AN ORAL ONE. Franklin’s objection was that the letter, read literally, did not reach all the accounts; the answer offered was the associate’s account of a telephone conversation with the client. ⚠ This page does not say what compliance did next. Her sender rows in this subject family continue to 4 March 2014 and a further pair, on a two-case Epstein update, to 25 March 2014, and none of those was opened for this page.6

13 December 2013: an approval recorded in her name for an absent colleague

Jacqueline Lightbody’s page records that she rejected a know-your-customer file on a personal account application at 7:59 PM on 12 December 2013, that Amanda Kirby pressed for it to be resolved the next morning, and that Lightbody was out of the office that day. The bank’s printed case record for that case carries two entries in Franklin’s name, and they are different in kind.5

The first is an act. In the record’s M. Case Comments box, a row created by her and timestamped 13 December 2013 at 1:27 PM directs the reader to an existing know-your-customer file, identified by its number, which is not reproduced here, “for information regarding Mr. Epstein, a current PB client.” ⚠ That is her own dated entry in the bank’s case file, and it is the only comment in the box under her name.5

The second is a record of an approval. On the same sheet, in the ONSHORE APPROVALS box, the AML Compliance row reads “J Franklin o/b/o J. Lightbody” in the name column, the same words again beneath the printed label “(Signature)”, and 13 December 2013 in the date column.5

⚠⚠ THAT IS A PRINTED NAME AND NOT A SIGNATURE, AND THE DESK CHECKED IT AT THE IMAGE FOR THIS PAGE RATHER THAN CARRYING THE SIBLING PAGE’S READING ACROSS. No ink mark appears on any signature rule anywhere on the sheet. Every filled row is typed the same way: the client-facing professional Paul Morris and the office director Brian M. Biggar, both dated 10 December 2013, and AML business risk in the name of Melisa Venegas, dated 13 December 2013. The regional office director row is empty and the entire LATAM/INTERNATIONAL APPROVALS box below it is empty. The sheet is headed “KYC Print” and numbered “Page 10 of 11”: it is a printout of the bank’s system record of who approved what, not an executed form.5

⚠ What this does and does not establish. It establishes that the AML Compliance approval for that case was recorded on 13 December 2013 in Franklin’s name, expressly on behalf of the officer who had rejected the file the evening before and was absent that day. ⚠ It does not establish that Franklin reviewed the substance, that she was told of the rejection, or that the objection was answered rather than routed around, and nothing read for this page settles any of those. ⚠ The two officers held the same title and worked the same relationship, so “o/b/o” here is a peer covering for a peer, not a junior signing for a senior.1

⚠ The case comments box on that sheet carries other material about private individuals, partly barred. None of it is reproduced or characterised here.

What she approved

She is not only a rejecter, and a page built only on the rejections would be a false one. The store holds seven documents carrying approval notices sent under her name, and they carry six distinct notices because one is present twice. ⚠⚠ THREE OF THE SEVEN WERE OPENED AND FOUR WERE NOT, and the table says which. The earliest is the earliest document on this page by any route:9

DateNoticeWhat was opened
21 Aug 2013Approved⚠ Two days after the relationship was opened. The customer line names Jeffrey Epstein. ⚠ text layer opened, sheet not rendered
10 Sep 2013, 4:26 PMApproved⚠ text layer opened, sheet not rendered
17 Oct 2013, 11:41 AMApproved⚠⚠ NOT OPENED. Known from the e-mail metadata store only
28 Oct 2013, 1:20 PMApprovedPresent twice in the store. ⚠⚠ NEITHER COPY OPENED
1 Nov 2013, 11:32 AMApproved with Temporary Exception⚠ text layer opened, sheet not rendered
8 Nov 2013, 11:51 AMApproved with Temporary Exception⚠⚠ NOT OPENED. Known from the store only

⚠ The 21 August 2013 date needs its caveat stated with it. Deutsche Bank’s page records, from the New York consent order, that the Epstein relationship began on 19 August 2013. A know-your-customer case in his name reached an approved state on a notice sent under her name two days later. ⚠⚠ This page does not say she cleared the relationship. The consent order does not name the officer who did; a case-level approval is not a relationship clearance; the minute field of the timestamp on this sheet is damaged and the desk did not repair it; and the sheet was read in the text layer only and was not rendered. What would settle it is the bank’s own clearance record for the initial onboarding, which was not found in the material read here.9

⚠⚠ AND “Approved with Temporary Exception” IS NOT EXPLAINED BY ANYTHING READ FOR THIS PAGE. The phrase is the bank’s own and appears in the template sentence of two notices. The desk did not find a document defining what the exception was or how long it ran, and nothing is inferred from the words.9

Chronology

DateWhat the documents showProvenance
19 Aug 2013The Epstein relationship at Deutsche Bank beginsdocumented at Deutsche Bank
21 Aug 2013A KYC case in the name of Jeffrey Epstein reaches an approved state on a notice sent under her nametext layer9
5 Sep 2013Rejects a file on Jeepers, Inc: a certificate of good standing is wantedtext layer7
9 Oct 2013⭐ Rejects the file on Epstein, Jeffrey in seven items across five companies, including his source of wealthimage3
15 Oct 2013Rejects a file covering an Epstein insurance trust; wrong country again, wealth profile incompletetext layer, inside a forward8
25 Oct 2013Amanda Kirby writes back asking her to interpret a rejection pointtext layer8
1 and 8 Nov 2013Two notices reading “Approved with Temporary Exception”text layer for the first; ⚠ store only for the second9
13 Dec 2013⭐ Her own case comment at 1:27 PM; the AML Compliance approval recorded as “J Franklin o/b/o J. Lightbody”image5
25 Feb 2014Opens the Additional signer questions; rejects a file on Mort, Incimage of the later sheet; text layer for these107
3 Mar 2014⭐⭐ “Did you assist Mr. Epstein with the drafting of his letter…?” Kirby answers with a telephone conversationimage4
25 Apr 2014Rejects a file on Zorro Development Corp.: evidence to support the authorised signerstext layer7
2015Two isolated sender rows, January and Octoberstore only6
Apr 2018Sender rows on “2018 Regular Reviews: High Risk clients” and “2018 AFC EDD Audit”⚠ store only, not opened6
19 Oct 2018⭐⭐ Agrees Epstein should be treated as an RCA, and that every client he ultimately owns or controls should be automatically rated “High”image2
22 Oct 2018The escalation is forwarded to the AML/KYC mailbox under a subject beginning “CLEARED:“image2
6 Jul 2019Epstein is arresteddocumented elsewhere on this wiki

⚠ Every row is a document, not an event reconstructed from one. ⚠ The 19 August 2013 and 6 July 2019 rows are carried across from sibling pages and were not re-derived here. ⚠ The April 2018 row is a statement about subject lines and dates in the e-mail metadata store. Those documents were not opened and nothing about their contents is asserted.

The measurement

"Janice Franklin" reaches 347 documents.6

  • The middle-initial form is very nearly a subset here, and the intersection was measured rather than assumed. "Janice P. Franklin" reaches 107 documents, of which 3 do not carry the plain form; the union is 350. ⚠ That is the opposite of the shape found on other subjects at this desk, where the middle-initial form reached documents the plain form could not. It was tested because it has been productive elsewhere, and on this subject it adds three documents.
  • ⚠⚠ THE BARE SURNAME IS USELESS AS A KEY FOR HER AND IS NOT OFFERED AS A CEILING. "Franklin" reaches 1,585 documents. At least 369 of those are demonstrably other things: "Franklin Street" 306, "Benjamin Franklin" 56, "Franklin Templeton" 7. The remaining surname-only documents were not partitioned and no claim is made about them.
  • In the e-mail metadata store she is the sender of 190 rows across 135 documents, 21 August 2013 to 19 October 2018. ⚠⚠ A looser match on the sender field returns 209 rows, and 19 of those are not hers: the extraction has swallowed a header block into the sender field, and in every one of the 19 the message is Amanda Kirby’s, written to Franklin. A sender figure taken from the loose match overstates her by about a tenth. ⚠ A further 10 of the 190 are rows whose sender field has swallowed a header block in which she really is the sender; they are counted as hers.
  • Rates, with both denominators. Her 190 sender rows are 0.0089% of the store’s 2,143,804 rows and 0.0103% of the 1,848,452 rows carrying any sender. ⚠ Neither number means anything about her importance; they are printed because a rate without its denominator is not a measurement.
  • Of the 190, 47 carry a rejection subject, 5 an approval subject and 2 an approval-with-temporary- exception subject, and 88 rows across 53 documents carry a subject in the “Additional signer” family, all of them dated 25 February to 4 March 2014. ⚠ These are ROW counts, not distinct messages: the release holds the same message many times.
  • ⚠ The gap in the middle is real and is not explained here. Between 25 April 2014 and 4 April 2018 the store holds two rows for her, in January and October 2015. Whether that is a gap in her work on this relationship or a gap in what was produced is not established by anything read for this page.
  • ⚠ No doc_type figure is printed, under the rule in _desk/TOOLS.md.

What this page does not say

No allegation against her was found in the release read for this page.11

⚠⚠ NOTHING HERE SUGGESTS SHE DID ANYTHING IMPROPER. In every document read she is the person asking for the missing evidence, returning an incomplete file, questioning whether a client instruction meant what the business said it meant, or recording a risk determination in writing. The 2018 determination is adverse to the client and she made it in two sentences the same afternoon she was asked.

⚠ Whether Deutsche Bank’s controls were adequate is an institutional question and belongs at Deutsche Bank, not to any individual named here.

⚠ The gaps, each scoped:

  • The desk rendered and read at the image five sheets across four documents for this page, and read a further nine documents in the text layer only. Of the 347 documents carrying her name it has read a small fraction and says so.
  • The four 2018 documents on the regular-review and EDD-audit subjects were not opened. They are the largest unread block of her own writing and they sit in the year that matters most.
  • The letter adding an additional signer was not found and not read, so what it actually said is known here only from her paraphrase of it.
  • Nothing read for this page records an answer to her question of 3 March 2014 about who drafted that letter.
  • No resolution is documented for any rejection on this page, and in no case did the desk find the document that closed the file.
  • 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. The 2013 and 2014 sheets place her in Deutsche Bank Trust Company Americas, Compliance; the 2018 sheet places her in Deutsche Bank Americas, Regulation, Compliance and Anti-Financial Crime. The desk did not establish whether that is a move or a reorganisation.

Footnotes

Footnotes

  1. Identification. Name, credentials, title and office are taken from her own signature blocks, read at the image on two sheets four years apart. On EFTA01299337 p.1, rendered and READ AT THE IMAGE at 700 dpi: Janice Franklin, CAMS, CFSA, CFIRS / Vice President | AML Compliance Officer / Deutsche Bank Americas / Regulation, Compliance & Anti-Financial Crime / 60 Wall Street, 10005-2836 New York, NY, USA. The | is a vertical bar on the sheet. On EFTA01400522 p.2, rendered and READ AT THE IMAGE at 700 dpi, the same name and credentials appear over Deutsche Bank Trust Company Americas / Compliance / 60 Wall Street, 10005-2836 New York, NY, USA. ⚠ NO contact value for her is reproduced anywhere on this page, and none is recovered from any other copy. The address is a bank office, not a residence. ⚠ CAMS, CFSA and CFIRS are professional certifications and are reproduced as printed; the desk did not verify them against any register. ⚠ Her title, Vice President | AML Compliance Officer, is the same title Jacqueline Lightbody carries on her own signature block on EFTA01404859 p.2, which is the basis for the statement that the two were peers. ⚠ Her sign-off Janice P. Franklin is set in an italic script face on the 2018 sheet. It is typed, not written, and it is not a signature. ↩ ↩2

  2. 19 and 22 October 2018, the anchor. EFTA01299337, a two-sheet document. BOTH SHEETS WERE RENDERED AND READ AT THE IMAGE AT 700 dpi. ⚠ The run is a container and its page 1 is a wrapper: the topmost header on p.1 is a forward from Gwen Hill to PWMUS AMLKYC, copy to herself, subject CLEARED: PEP Escalation_Jeffrey E. Epstein, dated Monday, October 22, 2018 8:53:18 AM, with one attachment. Beneath it on the same sheet, and continuing onto p.2, is the chain it encloses: Franklin’s message of Friday, October 19, 2018 5:16 PM to Gwen Hill, and under that Hill’s message of Friday, October 19, 2018 2:30 PM to Franklin. The quotations above are given in the order the correspondence happened, not in the order they print. ⚠⚠ THE TEXT LAYER OF THIS DOCUMENT IS WRONG IN FIVE PLACES AND THE IMAGE GOVERNS: it renders the wrapper’s From: Gwen Hill as Gwen MB; the attachment image003.png as imaoe003,202; Hill’s script sign-off Gwen Hill as Gwent, Hal.; Regulation, Compliance & Anti-Financial Crime as Regulation. Compliance 8 Anti-Financial Crime; and on p.2 it DELETES the first two thirds of a street-address line and closes the gap. ⚠ A bar covers a contact value in the To: line of Franklin’s message and a second bar covers a block beneath her signature; both were read at the image and neither is reproduced or described further. ⚠ Hill’s spelling Jeffery E. Epstein is on the sheet. ⚠ BLAFC-WM is as printed and is not expanded, because nothing read here expands it. ⚠ Why a checker may flag the closing quotation and why the pin is right: Franklin’s second sentence ends risk rated "High" with a closing curly quotation mark and NO full stop, so a search normalising the quotation marks will not bind it. The sheets carry CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) with production stamps DB-SDNY-0028090 / SDNY_GM_00065265 on p.1 and DB-SDNY-0028091 / SDNY_GM_00065266 on p.2. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  3. 9 October 2013. EFTA01361730 p.1, a single sheet, rendered and READ AT THE IMAGE at 700 dpi, timed 10/9/2013 9:09:17 AM, to Amanda Kirby, subject Your KYC has been rejected. The sheet prints Your KYC has been rejected. above Case #:, Relationship: EPSTEIN, JEFFREY RELATIONSHIP, Customer Name: Epstein, Jeffrey, Customer Number: and the seven-item reason field quoted above. ⚠ The case number, the customer number, both e-mail addresses in the header and the case-system link are all barred on the sheet, and nothing is recovered from any of them; no case, customer or account identifier from this notice is reproduced on this page. ⚠⚠ THE SHEET’S OWN TYPING ERRORS ARE REPRODUCED AND ARE NOT EXTRACTION DAMAGE: Pease for Please five times, Espstein's for Epstein's once, and the double hyphen in incorrectly stated--should be USA. ⚠ Why a checker may flag two rows from this footnote and why the pins are right: the text layer of this sheet renders 1. Hyperion Air LLC as . yperion Air LLC, 5. JEGE LLC as S. )EGE LLC and J. Epstein as 3. Epstein in one place, and it adds two lines of junk characters (II, I) before the closing line that are not on the sheet. The image governs throughout. Production stamps DB-SDNY-0050956 / SDNY_GM_00197140. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  4. 3 March 2014, and it is the only sheet quoted in this section. EFTA01400522 p.2, whose own page stamp reads EFTA01400523, rendered and READ AT THE IMAGE at 700 dpi. ⚠⚠ THE RUN IS NINE SHEETS AND IS A CHAIN, NOT A LETTER: its page 1 carries Franklin’s message of the same day at a later hour, and the sheets below run backwards through the thread. The citation is to p.2 and to nothing else; the other eight sheets were not read at the image and nothing is taken from them. p.2 carries, top to bottom: the tail of Kirby’s reply of 3 March 2014, then, under an ----- Original Message ----- rule, Franklin’s message of 03/03/2014 12:15 PM EST to Amanda Kirby, copy to Jacqueline Lightbody, subject Re: J. Epstein KYC Updates: Additional signer [I], classification For internal use only; then her signature block; then the head of a further quoted header. ⚠⚠ THE TEXT LAYER IS WRONG IN TWO PLACES THAT MATTER AND THE IMAGE GOVERNS: the sheet reads "on all accounts associated with [the "Southern Financial Relationship"]? with SQUARE brackets, which the extraction turns into round ones, and the sheet reads the "Southern Financial Relationship"? where the extraction reads the •Southern Financial Relationship"?. The square brackets are an editorial insertion by the writer into a quotation from the client’s letter, and turning them into parentheses would misattribute her own words to the letter. ⚠ The double spaces, and the double space in all of Mr. Epstein's accounts, are as printed. ⚠ No contact value for her is reproduced from this sheet. ⚠ The quoted header block at the foot of the sheet is set as a two-column ASCII table; it is described here and is not quoted, because no contiguous string of it exists in the rendered text. ⚠ The [I] marking in the subject line is the bank’s own and is not expanded, because nothing read here expands it. ⚠ Kirby’s reply is quoted from the top of this same sheet, not from another copy. ↩ ↩2 ↩3 ↩4

  5. The printed case record, 13 December 2013. EFTA01255026 p.10, whose own page stamp reads EFTA01255035, rendered and READ AT THE IMAGE at 700 dpi by this desk for this page. ⚠⚠ THE RUN IS ELEVEN SHEETS AND IT IS A MIXED FILE, NOT A LETTER: it is the bank’s KYC Print for one case, and this sheet is headed KYC Print and Page 10 of 11. The sheet carries three boxes: M. Case Comments, ONSHORE APPROVALS and LATAM/INTERNATIONAL APPROVALS. In the comments box, a row reads Janice Franklin in the Created By column, 12/13/2013 1:27 PM in the Date column, and a comment directing the reader to a numbered know-your-customer file for information regarding Mr. Epstein, a current PB client. ⚠ The number in that comment is a case identifier and is not reproduced on this page; the words quoted are the tail of the sentence and the head of it is described immediately before the quotation. 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 12/13/2013 in the date column. ⚠⚠ NO INK MARK APPEARS ON ANY SIGNATURE RULE ON THIS SHEET. The Client Facing Professional (CFP) row reads Paul Morris / Paul Morris / 12/10/2013, the Office Director/Business Head row Brian M. Biggar / Brian M. Biggar / 12/10/2013, and the AML Business Risk row Melisa Venegas / Melisa Venegas / 12/13/2013; the Regional Office Director row is empty and every row of the LATAM/INTERNATIONAL APPROVALS box is empty. ⚠⚠ 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 finds the second and not the first. ⚠ The first comment row in the same box, created by another officer, concerns private individuals and is partly barred; it is not reproduced, quoted or characterised here. ⚠ No case-system link from this sheet is reproduced here. ⚠ Jacqueline Lightbody’s page cites the same sheet for the approval row; the case comment is not on that page, and the reading of the approval row was re-derived here at the image rather than carried across. Production stamps DB-SDNY-0016356 / SDNY_GM_00053532. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  6. The measurement, and its route. Document counts were taken over the site’s read-only SQL endpoint as count(distinct efta_number) over pages_fts joined to pages, with every query scoped text_content : (...). "Janice Franklin" = 347; "Janice P Franklin" = 107; documents carrying the middle-initial form and NOT the plain form = 3, so the union is 350; documents carrying the plain form and not the middle-initial form = 243. ⚠ The tokeniser is plain unicode61 and splits on ., , and -, so "Janice P. Franklin" and "Janice P Franklin" are ONE query and are not two corroborating forms, and the surname-first form is inside the surname count. "Franklin" = 1,585, of which "Franklin Street" = 306, "Benjamin Franklin" = 56 and "Franklin Templeton" = 7. ⚠ The surname is therefore NOT a ceiling, NOT a floor and NOT a usable key for this subject, and the unpartitioned remainder is not characterised. In the e-mail metadata store emails_merged, a match on the sender field for her name returns 209 rows across 135 documents; 19 of those rows are not hers and are Amanda Kirby’s messages whose quoted header block the extraction has swallowed into the sender field, leaving 190 rows across 135 documents, 21 August 2013 to 19 October 2018. Of the 190, 47 carry a rejection subject, 5 an approval subject, 2 an approval-with-temporary-exception subject, and 88 a subject in the Additional signer family, those 88 falling across 53 documents dated 25 February to 4 March 2014. 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 date range is the store’s, not a statement about her employment. ⚠ Between 25 April 2014 and 4 April 2018 the store holds two rows for her, on 7 January 2015 and 2 October 2015; neither was opened. ⚠ No doc_type figure is printed, under the rule in _desk/TOOLS.md. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  7. The rejection census, and what it is a count of. Taken from emails_merged over her clean sender rows: 47 rows across 42 documents carry a rejection subject, the earliest dated 5 September 2013 and the latest 25 April 2014. ⚠⚠ 47 IS A COUNT OF ROWS, NOT OF FILES OR OF DECISIONS. The release holds the same notice many times, several rows are the same notice reproduced inside a later forward, and the subject-line strings themselves are damaged in the extraction in at least nine different ways (Your KYC has been re ected, rejected, Re: Your KYC has been rejected Ill, and others), so the grouping is approximate at the margins. The individual notices named in the chronology and not otherwise footnoted were read in the text layer only and are: 5 September 2013, EFTA01360995 p.1, customer line Jeepers, Inc, reason Please provide us with a certificate of Good standing; 25 October 2013, EFTA01360640 p.1; 25 February 2014, EFTA01361757 p.1, customer line mort, Inc, reason Documentation to evidence additional signer not noted; 25 April 2014, EFTA01361399 p.1, customer line zorro Development corp., reason Please provide us with evidence to support the authorized signers. ⚠ The lower-case renderings of the two company names are the extraction’s, not the sheet’s, and no sheet in this note was rendered. ⚠ Mort, Inc has no page on this wiki and nothing further about it was searched for here. ⚠ Every one of these notices carries a customer number and a case-system link and none is reproduced. ↩ ↩2 ↩3 ↩4

  8. 15 and 25 October 2013, read in the text layer only. EFTA01361732 p.1 is Kirby’s message of 10/25/2013 10:12 AM to Franklin, classification Public, quoting beneath it Franklin’s rejection notice of 10/15/2013 03:56 PM on a file whose reason field addresses The 2007 Jeffrey E. Epstein Insurance Trust #3 and asks for a wealth profile and a re-run of the due diligence searches against the correct country. ⚠⚠ THIS SHEET WAS NOT RENDERED AND WAS READ IN THE TEXT LAYER ONLY. The two fragments of Kirby’s message given in the body are marked as text layer in the body. ⚠ The quoted rejection is cut off by the foot of the sheet mid-sentence, at Should be US virgin Islands, not, and the remainder is not on this sheet; that is why the reason is described rather than quoted. ⚠ The rejection point Kirby is asking about concerns HBRK Associates, Inc. and a schedule of a corporate tax return. ⚠ Contact values print in Kirby’s signature block on this sheet and none is reproduced. ⚠ The 15 October notice exists in the release as its own document as well; this page cites the forward because that is the copy read. ↩ ↩2 ↩3

  9. The approvals, and exactly what was opened. ⚠⚠ NO APPROVAL SHEET WAS RENDERED, NOTHING IS QUOTED FROM ANY OF THEM, AND FOUR OF THE SEVEN DOCUMENTS WERE NEVER OPENED AT ALL. Opened in the text layer, sheets not rendered: 21 August 2013, EFTA01361848 p.1, a single sheet, to Amanda Kirby, subject Your KYC has been approved!, customer line naming Jeffrey Epstein; ⚠ the minute and second fields of its timestamp are damaged in the extraction and are NOT repaired here, which is why the chronology and the table give the date without a time; ⚠ the extraction also renders the template line’s verb as aiiroved, which is one reason the sheet is not quoted. 10 September 2013, EFTA01361903 p.1, timed 4:26:23 PM. 1 November 2013, EFTA01360833 p.1, timed 11:32:24 AM, subject Your KYC has been Approved with Temporary Exception!. ⚠⚠ NOT OPENED, and known only from the e-mail metadata store’s sender, subject and date fields: EFTA01360977 (17 October 2013), EFTA01357635 and EFTA01400682 (28 October 2013, one notice in two copies, the second carrying an RFC-form header with a -0400 offset), and EFTA01360915 (8 November 2013). Nothing about the contents of those four is asserted anywhere on this page, and the statement that they are approval notices rests on their subject lines in the store and on nothing else. ⚠ Each of the three sheets that WAS opened carries a customer number and a case-system link, and none is reproduced. ⚠ The statement that an approval notice has no free-text field is a statement about the THREE sheets actually read here and is not a claim about every approval the system ever sent. ⚠ The desk does not claim these seven are all she sent. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  10. 25 February 2014, described and not quoted. EFTA01400495 pp.1 to 2, a two-sheet chain: Franklin’s message timed Tue, 25 Feb 2014 17:27:59 -0500 to Amanda Kirby, copy to Jacqueline Lightbody, classification Public, above Kirby’s message of the same afternoon. ⚠⚠ THESE SHEETS WERE NOT RENDERED AND WERE READ IN THE TEXT LAYER ONLY, SO NOTHING IS QUOTED FROM THEM and the three questions are given in summary. ⚠ Her message quotes two know-your-customer case numbers, neither of which is reproduced here. ⚠ The extraction renders one of them with a transposed prefix, which is one more reason nothing from this sheet is quoted. ⚠ p.2 carries a mail-system notation about a deleted attachment. It is a Lotus Notes artefact describing a detached file, it is not read here as an act by anybody, and it is not reproduced. ↩ ↩2

  11. 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 347 documents carrying her name, the desk rendered and read at the image five sheets across four documents, and read nine further documents in the text layer only. It ran no systematic adverse sweep, searched none of the six derived stores, opened none of the four 2018 regular-review and audit documents, and opened neither 2015 row. ⚠ A deeper pass is owed, and this page records the debt rather than implying it does not exist. ↩

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