Epstein Data Wiki

Marjorie Rawls Roberts

Properties2
tagsperson, us-virgin-islands, saint-thomas, tax-attorney, economic-development-commission, exempt-companies, 2001, 2006, 2010, 2011, 2012, 2017, 2018, 2020
aliasesMarjorie Rawls Roberts, Marjorie R. Roberts, Marjorie Roberts, Roberts, Marjorie Rawls, Jorie Roberts, Attorney Roberts, Marjorie Rawls Roberts, P.C., Marjorie Rawls Roberts, PC

43 min read

What this page does and does not contain

This page is about a working tax lawyer, not about a member of Jeffrey Epstein’s circle. Marjorie Rawls Roberts is a St. Thomas attorney whose practice was the U.S. Virgin Islands tax statutes that Epstein’s territorial companies used. She is not a complainant, not a survivor and not an accused person, and nothing on this page suggests otherwise.

The record is small, and this page says so rather than inflating it. Her name reaches 60 documents of this release. Four of those are a different woman, a Palm Beach condominium owner inside a Florida property tax roll, and they are set aside. Of the 56 that remain, 12 carry an act by her and 13 are her law firm’s filings signed by a different attorney. The rest are other people writing about her, machine-generated mail, and administrative lists. Eight distinct acts by her are what the record supports, and this page is built on those eight and on three transactions directed at her.12

The best-known claim about her is an allegation, not a fact, and it stays an allegation here. A reporter wrote in April 2012 that she was helping a telephone company apply for a total Virgin Islands tax exemption. He attributed part of what he knew to “one of my sources.” This page went looking for the underlying record and did not find it: the release holds 201 documents containing the phrase “economic development commission” and not one of them carries her name.3

One sheet reached by her name is not used here. It carries material unrelated to her that this page will not reproduce or characterise, and nothing from it is quoted, counted or relied on.4

PracticePresident and owner of Marjorie Rawls Roberts, P.C., a tax law firm at Dronningens Gade, St. Thomas, U.S. Virgin Islands56
Admitted”the U.S. Virgin Islands, California, the District of Columbia (inactive), the United Kingdom, and the British Virgin Islands”, in her own signature block5
Her firm, as a reporter listed it in 2011”seven attorneys (Marjorie R. Roberts, Sean E. Foster, Travis L. Wright, Joseph A. DiRuzzo, III, Renée M. André, Johanna Harrington, Michele Hyndman)“7
Named on the documents asMarjorie Rawls Roberts, Marjorie Rawls Roberts, Esq., Marjorie R. Roberts, Marjorie Roberts, Attorney Roberts, Jorie Roberts, and in her own sign-off simply Jorie15
The act this page rests on mostA practitioner article she co-wrote, “The American Paradise: Using a Tax-Free U.S. Virgin Islands Exempt Company for FAA Registration of Foreign-Owned Aircraft”, which sets out the machinery in her own words. Read at the page image8
The hardest financial factA 2006 Form 1099-MISC from Epstein’s Financial Trust Company, Inc. to Marjorie Rawls Roberts, box 7 nonemployee compensation, $22,373.16. Printed on the same sheet as a 2006 Form 1099-MISC from the same company to Hodge & Francois for $796.64. Read at the page image9
Earliest contact in the releaseA FedEx envelope sent from Epstein’s New York office to her in St. Thomas, picked up 15 October 2001, delivered 16 October 2001. Read at the page image10
The government directive she receivedLieutenant Governor’s Legal Counsel Dolace McLean, 19 May 2017: “ALL actions with respect to exempt companies are STAYED INDEFINITELY”, three days after she had asked whether her clients could pay their fees. Read at the page image11
The refusal in her nameAsked in July 2011 for the EDC beneficiary companies her firm represented, the territorial agency’s drafted answer was “Overly burdensome and possibly will not be accurate”. Read at the page image7
Where she is absent201 documents in this release contain “economic development commission”. None names her. No EDC application, filing or signature of hers has been located3
Covered elsewhere on this wikiCecile de Jongh · John de Jongh · Stacey Plaskett · Kenneth Mapp · Albert Bryan · Erika Kellerhals · Andrew Farkas · Michael Wolff · Financial Trust Company · Little St. James

Marjorie Rawls Roberts is a tax lawyer in St. Thomas, U.S. Virgin Islands, and the president and owner of the firm that bears her name. Her practice is the territorial tax statutes: the Economic Development Commission benefit programme, the exempt company, and the question of who counts as a bona fide resident of the Virgin Islands for federal tax purposes. Those are the same instruments Jeffrey Epstein’s territorial companies used, and that overlap is why she appears in this release at all. Epstein’s Financial Trust Company, Inc. reported paying her $22,373.16 in nonemployee compensation for 2006; an index to the legal operating files of Little St. James carries a folder headed “Marjorie Roberts Invoices”; and in 2010 a company in which Epstein held a half interest described her as “our local attorney” while asking him to answer an EDC application’s questions about his criminal record.91213

She is not, on this record, a member of his circle. Of the 56 documents in this release that name her and are hers, 12 carry an act by her. The rest are her firm’s court filings over another lawyer’s signature, reporters and officials writing about her, and machine mail. The useful account of her is narrow and specific: she is a professional inside the tax machinery, and the most informative things in the file are a published article in which she explains that machinery, a government order that stopped her clients’ filings, and a refusal by a territorial agency to say which EDC companies her firm acted for.

What reaches her, and the namesakes who are not her

Her name reaches 60 documents and 75 sheets of this release, measured as the union of seven printed forms. Fifty further forms and probes were tested beyond those seven, and none added a document that survived reading, so 60 is a floor that held against deliberate widening.1

Four of the 60 are a different person. They are reached only by the inverted form Roberts, Marjorie, and at the sheet they read ROBERTS MARJORIE R and GOODSTEIN MARJORIE R TR: the owner of a Biltmore condominium unit inside a Palm Beach County property tax roll of roughly 14,274 rows. Different woman, different territory, different decade. The full form marjorie rawls roberts returns none of them, so the two are cleanly separable, and those four are excluded from everything on this page.1

Two further namesakes were tested and rejected. Roberts, Esq. reaches Emma Roberts, Esq., an immigration lawyer at a New York practice, in six documents. Attorney Marjorie reaches Attorney Marjorie Whalen, one of the lawyers who later represented the Epstein estate’s co-executors, in one. Neither is her, and nothing from any of those seven documents is counted here.1

Her surname and her nickname are both eponyms and neither can be mined. The bare surname Rawls reaches 82 documents, of which 45 lie outside her population, and every one of those 45 is somebody else: Louanne Rawls, a Palm Beach court reporter who certified deposition transcripts; Lou Rawls, the singer; John Rawls, the philosopher, in reading lists and seminar descriptions; a corrections officer of that surname in custodial housing logs; and optical-recognition noise in which “Results” and “Rentals” became “Rawls”. The bare forename Jorie reaches 21 documents and outside her population it is the poet Jorie Graham in an event listing, a Jorie Fleming in a corporate directorship record, a Jorie A. Grassie in a client list, and, in Palm Beach property tables, a fourth woman entered there as KENT JORIE B.1 Only the two-word form Jorie Roberts is hers, and it matters: it reaches two documents that no full-name search finds, because the Lieutenant Governor’s office and her own clients called her that.11311

”The American Paradise”: the machinery in her own words

The single most informative document in this population is not about Epstein at all. It is a practitioner article, reproduced in the release from the website of the New York firm Solomon Blum Heymann LLP, headed:8

THE AMERICAN PARADISE: USING A TAX-FREE U.S. VIRGIN ISLANDS EXEMPT COMPANY FOR FAA REGISTRATION OF FOREIGN-OWNED AIRCRAFT

By William L. Blum and Marjorie Rawls Roberts

The article explains why a foreign owner seeking to register an aircraft in the United States should incorporate in the Virgin Islands rather than Delaware. A corporation formed in any state, it says, “will be subject to federal income tax at the usual corporate rates.” The exception “is not a state at all, except for purposes of the Federal Aviation Act; it is the unincorporated territory of the United States Virgin Islands”. Where the aircraft is used outside the United States, the territorial exempt company “offers two major benefits: FAA registration and 100 percent exemption from Federal, state, and local income taxes.”8

This is her own account of the instrument, written for other lawyers, and it is the clearest statement of the machinery anywhere in her file. It carries no reference to Epstein and makes no claim about him. Its value is that it establishes, from her own byline, what she did for a living, and it names the co-author, William L. Blum, who appears again in the May 2017 sequence below.

October 2001 and 2006: the courier and the payment

The earliest dated contact between Epstein’s office and her in this release is a FedEx envelope. A shipping invoice dated 22 October 2001 records a FedEx International Priority envelope picked up on 15 October 2001 at Epstein’s New York office on Madison Avenue, addressed to “MARJORIE ROBERTS” in St. Thomas, delivered at 15:41 the following day. A second invoice records a further shipment from Epstein to her, picked up on 2 January 2003.10

Five years after the first envelope, Epstein’s territorial company paid her. A 2006 Form 1099-MISC issued by Financial Trust Company, Inc. of St. Thomas names MARJORIE RAWLS ROBERTS as the recipient and reports $22,373.16 in box 7, nonemployee compensation. Printed directly above it on the same sheet is a second 2006 Form 1099-MISC from the same company to HODGE & FRANCOIS for $796.64.9

Those are the two firms a reporter would ask the territorial development agency about five years later, and they are side by side on one page of Epstein’s own tax file.

An undated index to Epstein’s legal operating files lists, under the heading “LSJ Operating File I”, nineteen numbered folders. Item 18 is “Marjorie Roberts Invoices”. LSJ is Little St. James. The index appears in three documents of this release, and no invoice from that folder appears among the documents that name her.12

September 2010: American Yacht Harbor, and the questions about Epstein’s record

On 8 and 21 September 2010, Mark Lande wrote to Andrew Farkas enclosing “the application for the renewal of the EDC Benefits for American Yacht Harbor.” Because Epstein was “a 50% owner in the property,” the renewal required disclosures from him. Lande wrote: “According to local counsel we need the information below from Mr. Epstein which is requested pursuant to Section 8 of the EDC Application.” He added: “I am told by local counsel that Mr. Epstein recently renewed the EDC Benefits for an EDC company that he controls/owns so he or his advisors should be familiar with the questions below, although I have not confirmed the recent renewal independently.”13

The five questions that follow are the EDC application’s character questions, and in September 2010, two years after Epstein’s Florida conviction, they read as follows: whether he or any company of his had ever had a licence “denied, suspended, revoked or subject to any conditions”; “Has Mr. Epstein ever been charged with any crime or offense in any jurisdiction?”; whether he “ever been the subject of an investigation conducted by any governmental/agency, organization, court, commission, committee, grand jury or investigatory body”; and whether he had ever filed for bankruptcy.13

Lande closed: “If you have any questions or you would like me or our local attorney, Jorie Roberts, to speak to Mr. Epstein or to any of Mr. Epstein’s advisors, please let me know.”13

What is documented here is what Lande wrote. That he described her as his side’s local counsel on an EDC renewal is on the face of the letter. That she gave the advice he attributes to “local counsel” is his characterisation and is not independently recorded in this release, and no filing, application or signature of hers in the American Yacht Harbor matter has been located.

December 2010: counsel for the petitioner on bona fide residency

A United States Tax Court opinion filed 22 December 2010, reported at 2010 TNT 246-10 and reproduced in the release from a tax news service, concerns a taxpayer “claiming to be a bona fide resident of the U.S. Virgin Islands” for 2002 to 2004 who “filed territorial income tax returns with, and paid income tax to, the Virgin Islands” and did not file federal returns. The counsel line reads: “William M. Sharp, Lawrence R. Kemm, Joseph A. DiRuzzo, III, and Marjorie Rawls Roberts, for petitioner.”14

Joseph A. DiRuzzo, III is listed as one of the seven attorneys at her firm in the FOIA request of the following July. Bona fide residency is precisely the question a reporter would put to the Governor about Epstein eight months later, and it is what she litigated.

July to September 2011: the reporter, the refusal, and the meeting

19 July 2011. Stacey Plaskett, then general counsel at the Virgin Islands Economic Development Authority, circulated a reporter’s questions to agency staff under the subject line FOIA Request CONFIDENTIAL Attorney-Client Privilege. She wrote: “below please find the email that was sent this past Friday from Wayne Barrett, reporter. I would like to send a written response back by the end of the week and am asking for your assistance in crafting a letter.”7

Barrett’s numbered requests follow, with the agency’s drafted answers typed in beside each one. His third item reads:7

  1. I’d like to request separate lists of EDC beneficiary companies presently represented by two firms:

a) Marjorie Rawls Roberts firm, which includes seven attorneys (Marjorie R. Roberts, Sean E. Foster, Travis L. Wright, Joseph A. DiRuzzo, III, Renée M. André, Johanna Harrington, Michele Hyndman).

The answer typed beside it reads: “Overly burdensome and possibly will not be accurate as beneficiaries may have changed lawyers since our last record.”7

That answer is the most informative sentence about her practice in the entire release. The agency did not say the firm had no EDC beneficiary clients, or few. It said that listing them would be too much work. The same request asked the same question about Hodge and Francois and drew the answer “See above.”7

17 to 19 August 2011. Barrett wrote directly to Governor John de Jongh: “I have been working for a few weeks now on a story about Jeffrey Epstein and using him as a bit of a window in the EDC program in the VI.” His fourth question asked the Governor to describe his relationship with Epstein, his wife’s, and “your ties to other attorneys who have represented him in the VI, including Erika Kellerhals, Marjorie Rawls Roberts, Maria Hodge and any others that come to mind.”15

Epstein forwarded the letter on 19 August to Ian Osborne and Michael Wolff under the subject suggestions?. Wolff replied the same morning: “It would appear that this is mostly focused on VI. I would suggest a response come through the Governor’s press office. It should be kept as brief and as general as possible.”15

Barrett’s question is a reporter’s assertion, not a finding. It places her among attorneys who had represented Epstein in the territory; it does not document a retainer, and no retainer or engagement letter of hers has been located in this release.

7 September 2011. A memorandum of a meeting at the Economic Development Authority office records: “Meeting with Stacey Plaskett and Percy Clouden re: Newsweek article.” The next line reads “Also present: Marjorie Rawls Roberts, Jim Tagliaferri, TAG Virgin Islands, Inc.”16

The memorandum states the meeting’s purpose as “to let them know what EDA is doing and to let beneficiaries know they are supported,” records that the FOIA request had been directed to Plaskett and that she was “Very careful in giving them exactly what was requested and to redact,” and lists eight companies in the context of the reporter’s approaches to former employees, among them “Financial Trust”. It then records: “Specifically asked for info about MRR and Hodge & Francois.” The memorandum closes: “2 responses from EDA to Barrett. Tried to protect beneficiaries. SP will provide copies. Sent letter to reporter and to editor.”16

The abbreviation MRR stands beside the same second firm, Hodge & Francois, that the July request had paired with her own, in the same agency’s file, seven weeks later.

She was therefore in the room when the agency discussed how to answer a reporter who was asking the agency about her. That is what the memorandum records, and it is a documented fact. What was said there by her is not recorded.

April 2012: the ICC/VITELCO allegation, and the record that is not there

On 10 April 2012 the reporter Matthew Boyle sent a message headed URGENT REQUEST FOR COMMENT ON EDC BENEFITS/ICC VITELCO/OTHER COMPANIES to Jean P. Greaux, Jr. at the Governor’s communications office. It opens:17

I’ve learned that ICC/VITELCO is in the process of applying for new EDC tax benefits - a 100 percent exemption of all taxes, including income taxes. Attorney Marjorie Rawls Roberts is helping them with the application, and according to one of my sources, former Sen. Roosevelt David is helping as well.

Boyle went on to write that his source said the Governor “is pushing this application through the EDC,” and that the benefits “would amount to about $3 million per year that ICC/VITELCO would not have to pay in taxes.”17

Cecile de Jongh forwarded the inquiry to Epstein the same afternoon with her own answers inserted, and Epstein replied, “i would simply state that you are an office manager.” That exchange concerns her own employment at Financial Trust Company and is covered on her page; it says nothing about Roberts and is not read here as saying anything about her.17

Boyle’s statement about Roberts is a credible allegation in a press inquiry, and it stays one. He is an identifiable reporter writing to a government press office; he expressly sourced part of the same paragraph to “one of my sources”; and the inquiry asks for comment rather than reporting a verified fact. Whether anyone answered the question about her is not recorded in the documents located.

This page looked for the primary record and did not find it. The release contains 201 documents containing the phrase “economic development commission” and 161 containing “economic development authority”; her 56 documents intersect both sets at zero. “Innovative Communication” returns two documents, neither hers. “Certificate of benefits” returns twelve, none hers. No EDC application, no EDC filing and no signature of hers on any EDC instrument has been located in this release.3

That is the shape of the thing: a territorial agency that would not list her firm’s EDC clients because listing them was too much work, a reporter who was told she was working on a particular application, and a released corpus of EDC paper in which her name does not appear once.

May 2017: three days, four documents, and an indefinite stay

Tuesday 16 May 2017, 10:16. She wrote to Dolace McLean, Legal Counsel to the Lieutenant Governor, under the subject Exempt Company Update:11

Attorney McLean —

Can our clients now pay their initial fees and get the necessary certificate of incorporation and certificate of good standing?

Sincerely, Jorie

The signature block beneath reads Marjorie Rawls Roberts / Marjorie Rawls Roberts, PC, with her street in St. Thomas, her firm’s web address, and the line “Admitted to practice in the U.S. Virgin Islands, California, the District of Columbia (inactive), the United Kingdom, and the British Virgin Islands.”11

Thursday 18 May 2017, 22:38. William L. Blum, her co-author on “The American Paradise,” wrote to Governor Kenneth Mapp, copying Epstein’s address, about the Financial Services Improvement Act of 2017. He described an email he had received from Dolace McLean as “quite troubling,” wrote that “What Attorney McLean appear to be suggesting is substantially higher fees” and that “Attorney McLean is suggesting that reporting forms be changed to require exempt companies to report their beneficial ownership to the government,” and observed that “the Lt. Governor’s office recently has been delaying incorporating exempt companies while they have been considering these changes.”18

These Blum documents do not name Roberts and are not counted among her 56. They are set out here because they are the same office, the same officer and the same week, and because they record that the objection to the exempt-company changes travelled to the Governor with Epstein copied in.

Friday 19 May 2017, 02:33. Governor Mapp answered Blum, with Epstein’s address again in the copy line: “Thank Bill. I will stop those efforts and bring them in line with my new policies. I’ll get back to you.” The “efforts” he was answering are the ones Blum had just described: his own Lieutenant Governor’s office proposing higher fees, a contract requirement and beneficial-ownership reporting for exempt companies. This message does not name Roberts either, and it is not counted among her 56.18

Friday 19 May 2017, 08:00. Denise Johannes of the Office of the Lieutenant Governor wrote to the group, opening “Good day Attorney Roberts” and listing her in the addressees as Jorie Roberts.11

Friday 19 May 2017, 13:52. Dolace McLean answered:11

Good Morning All: Please be advised that pursuant to directives received this morning, ALL actions with respect to exempt companies are STAYED INDEFINITELY until there has been an opportunity to meet and discuss the vital issues related to the formation and maintenance of these companies.

Friday 19 May 2017, 15:29. Blum forwarded McLean’s note to Governor Mapp: “The attached e-mail was received a short while ago from Attorney McLean and I wanted to make sure you were aware of it.”18

Three days: a working request about client fees, an objection carried to the Governor with Epstein copied, the Governor undertaking to stop the effort complained of, and, eleven hours later, a government order stopping everything. The sequence is documented. No causal link between the four is documented, and none is asserted here.

What the record does not settle is who issued the “directives received this morning”. McLean’s notice does not say, and nothing located names the author of the directive, states how long the stay lasted, or records whether the meeting it promised took place. What the record does show is that the Governor had told the complaining lawyer, hours earlier that same morning and with Epstein copied, that he would “stop those efforts”. Whether the two are the same thing is a question this page raises and cannot answer: the “efforts” Mapp named were his Lieutenant Governor’s proposed changes, while the stay McLean announced halted all exempt-company actions, which is a wider thing. Governor Mapp’s side of this exchange is set out on his own page.

The Plaskett host committees, 2016 to 2018

Her name appears on three campaign invitations for Congresswoman Stacey Plaskett, in each case as a member of a “host committee in formation”:19

  • 18 July 2016, a fundraiser cocktail reception at Paradise Point, St. Thomas, listing “David Bornn, Esq. / Greg Ferguson, Esq. / Erika Kellerhals, Esq. / Marjorie Rawls Roberts, Esq.”
  • 29 March 2018, a cocktail reception at Villa Botanica for Plaskett’s re-election campaign, listing “Richard Berry, Greg Ferguson, Erika Kellerhals / Sebastiano Paiewonsky-Cassinelli and Marjorie Roberts”.
  • 18 September 2018, a reception at Amalia Café, St. Thomas, listing her among nine names.

A host committee listing records that a name was lent to an invitation. It is not a record of a contribution, and no contribution by her appears in anything located for this page.

The firm after her: Sean E. Foster and the Epstein estate

Thirteen of the 56 documents are her firm’s work signed by a different lawyer. In the probate and related proceedings concerning Epstein’s estate in the Superior Court of the Virgin Islands, the service lists and certificates of service name “Sean Foster, Esq. / Marjorie Rawls Roberts, P.C.” alongside counsel for the other parties. A certificate of service dated 31 January 2020 records service of a “First Quarterly Accounting” on a list of territorial attorneys. Further filings of 16 March 2020 carry the same firm line.20

The acts in those thirteen documents are Foster’s and the firm’s, not hers. In ten of the thirteen the released text has lost at least one word of the firm’s name, most often rendering it Marjorie Rawls, P.C., which is why a search on her full name does not reach them. The name on a letterhead is not a signature, and nothing in this group is counted as an act by her.201

Sean E. Foster is one of the seven attorneys the July 2011 request named at her firm.7

Timeline

DateEventSource
15–16 Oct 2001FedEx envelope from Epstein’s New York office to “MARJORIE ROBERTS”, St. Thomas; delivered 16 Oct, 15:41EFTA0131521910
2 Jan 2003Second FedEx shipment from Jeffrey E. Epstein to Marjorie Roberts, St. ThomasEFTA0125980810
tax year 2006Financial Trust Company, Inc. Form 1099-MISC to Marjorie Rawls Roberts, $22,373.16 nonemployee compensation; Hodge & Francois, $796.64, on the same sheetEFTA013381759
2008Rwanda Project USVI donor acknowledgement lists her among contributors; “J. Epstein V.I. Foundation Inc.” is listed in a separate block aboveEFTA0122113221
8 and 21 Sep 2010American Yacht Harbor EDC renewal; Mark Lande calls her “our local attorney, Jorie Roberts” and relays the application’s questions about Epstein’s criminal recordEFTA0075594313
22 Dec 2010U.S. Tax Court opinion on Virgin Islands bona fide residency; she is named in the counsel line for the petitionerEFTA0059380614
19 Jul 2011Wayne Barrett’s FOIA request asks for the EDC beneficiaries her firm represents; the agency’s drafted answer is “Overly burdensome”EFTA005980407
17–19 Aug 2011Barrett asks Governor de Jongh about “attorneys who have represented him in the VI, including … Marjorie Rawls Roberts”; Epstein forwards to Wolff and OsborneEFTA0091769415
7 Sep 2011EDA meeting on the Newsweek story; “Also present: Marjorie Rawls Roberts”; “Specifically asked for info about MRR and Hodge & Francois”EFTA0108863616
10 Apr 2012Matthew Boyle: “Attorney Marjorie Rawls Roberts is helping them with the application” (ICC/VITELCO)EFTA0093316617
11 Aug 2013She accepts a LinkedIn invitation from EpsteinEFTA007177966
18 Jul 2016Plaskett fundraiser, Paradise Point; she is on the host committeeEFTA0059168419
16 May 2017She asks Dolace McLean whether her clients can pay their fees; signs “Sincerely, Jorie”EFTA0063988611
18 May 2017William L. Blum writes to Governor Mapp objecting to McLean’s proposals, copying EpsteinEFTA0069763118
19 May 2017, 02:33Governor Mapp to Blum, Epstein copied: “I will stop those efforts and bring them in line with my new policies”EFTA0104554718
19 May 2017, 13:52”ALL actions with respect to exempt companies are STAYED INDEFINITELY”EFTA0063988611
29 Mar 2018Plaskett re-election reception, Villa BotanicaEFTA0079435119
18 Sep 2018Plaskett reception, Amalia CaféEFTA0079625319
31 Jan 2020Certificate of service in the Epstein estate matter, signed by Sean Foster of her firmEFTA0007556220
2020Litigation search-term reports count hits on “Marjorie Roberts” and her firm’s mail domainEFTA0009241022

Two gaps in this sequence are worth naming. Between January 2003 and September 2010 the only dated items in her population are the 2006 information return and the 2008 donor acknowledgement: a seven-year interval in which the courier records show the relationship had already begun and almost nothing else survives in what has been released. And after September 2018 nothing in this release is an act by her; the firm continues, through another lawyer, into the estate proceedings of 2020.

What is not here

Her name was a litigation search term. Three documents in this population are document-review reports from the litigation over Epstein’s affairs. They tabulate hit counts for search terms, and the terms include “Marjorie Roberts”, “Marjorie w/2 Roberts” and her firm’s mail domain, listed beside the names and domains of other lawyers. One of the reports is headed as a privilege-terms search. What these record is that a party running a document review treated her name and her firm’s correspondence as a category worth isolating. They do not record what was found, withheld or produced, and this page draws nothing further from them.22

No statement by her has been located. No response, comment, denial or explanation from Marjorie Rawls Roberts about any document on this page has been found in this release. No request for one was made from here, and her silence is not recorded as a refusal; the finding is only that none has been located.

Specifically not located, each against a search that could have found it: any EDC application, filing, certificate or correspondence bearing her name, against 201 documents in the release carrying the phrase “economic development commission”; any engagement letter, retainer or invoice between her or her firm and Epstein or any Epstein entity, against an operating-file index that names a folder of her invoices; any document recording what was said at the 7 September 2011 meeting beyond the memorandum’s own notes; any document naming the author of the “directives” behind the May 2017 stay or recording when it was lifted, the Governor’s undertaking of that morning being set out above and not the same thing; and any answer to the question Matthew Boyle asked about her in April 2012.31216111718

Not measured, and therefore not stated as a negative: whether she appears in this release under a client’s name, a matter name or an entity she formed that never spells hers; and whether damage to the first four letters of either of her names conceals further documents. The union of 60 is a floor.1

Footnotes

  1. The population, and how it was bounded. Measured 5 November 2026 against this project’s full-text index, its size compared and printed as a match at 10,982,875,136 bytes, with a firing control (richard m berman = 371 documents / 885 sheets) and a freshly invented null token returning zero in the same runs. Union of seven printed forms: 60 documents / 75 sheets at ordinary page numbers, all 60 present in the document table, split 56 EFTA* and 4 HOUSE_OVERSIGHT*. Per form: marjorie rawls roberts 23 · rawls roberts 26 (2 exclusive) · marjorie rawls 35 (9 exclusive against the full union, 12 against the full form alone) · marjorie roberts 18 · roberts marjorie 11 (4 exclusive, and all four are the Palm Beach namesake) · marjorierobertspc 7 (0 exclusive) · jorie roberts 3 (2 exclusive). Fifty further forms and probes were tested beyond those seven and none added a document that survived reading, among them m rawls roberts, marjorie rawls robert, rawles roberts, marjorie r roberts, roberts marjorie rawls, marjorie rawls roberts pc, five damaged renderings of the firm’s mail domain, and marjorie rawis (1 document, already in the union; this form had been reported elsewhere as silent and is not). Three candidate forms produced ten documents that were read and all ten rejected: roberts esq (6, all Emma Roberts, Esq., of a New York immigration practice), attorney mclean (3, none naming her), and attorney marjorie (1, Attorney Marjorie Whalen). Eponym screens: the bare surname rawls reaches 82 documents, 45 outside the union, and all 45 were read and are other people; the bare forename jorie reaches 21 and the 15 sheets outside the union were all read: four other women (Jorie Graham, Jorie Fleming, Jorie A. Grassie, and the KENT JORIE B of the Palm Beach property tables), and optical-recognition noise. The forename is a whole token in every one of those sheets and none of them is reached by letters standing inside MARJORIE: the index tokenises on word boundaries, and the probe arjor, a pure substring of “marjorie” that is not a token, returns zero documents against 637 for marjorie; the bare surname roberts reaches 1,992 documents and was never used, because that set contains a binding exclusion. Namesake screen on marjorie roberts, the form most at risk: all 18 were read individually and all 18 are the Virgin Islands attorney; the Palm Beach markers GOODSTEIN (12 documents in the release), BILTMORE (104) and ROBERTS MARJORIE R (4) intersect those 18 at zero, while the aim control roberts marjorie intersects at one, a search-term list in which the inverted form arises from the query syntax. The four excluded documents are HOUSE_OVERSIGHT_016552, HOUSE_OVERSIGHT_016695, HOUSE_OVERSIGHT_016696 and HOUSE_OVERSIGHT_016698, and nothing from any of them is counted or described here. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  2. The act count and its denominator. Denominator: the 56 documents that are hers, the union of 60 less the four Palm Beach documents. Twelve carry an act by her, and the act in each was identified by reading the signature or byline, not by the sender field: her own email of 16 May 2017 (signed “Sincerely, Jorie”); her co-authored article (byline); two printings of the Tax Court opinion (counsel line); the 7 September 2011 meeting memorandum (attendance); four campaign invitations (three distinct events); the 2008 donor acknowledgement; her acceptance of a LinkedIn invitation; and one inbox listing in which she is named as a sender. Five further documents record transactions directed at or involving her: two printings of one FedEx invoice, one further FedEx invoice, and two printings of one 2006 information return. Thirteen are her firm’s filings signed by Sean E. Foster. Twenty-six are other people’s documents that mention her, comprising six printings of two press inquiries, one FOIA thread, two client-side emails, three document-review reports, three printings of one operating-file index, five commercial public-records reports on another attorney in which her firm appears only as an employer field, one device address-book extraction, and five automated LinkedIn digests. 12 + 5 + 13 + 26 = 56. Deduplicating copies, eight distinct acts by her and three distinct transactions directed at her (two courier shipments and one payment) are what the record supports, which is a deflation of roughly seven to one against the document count. These figures are this page’s own measurement and are offered as an estimate: the classification of an act rests on reading a signature, and a reader weighing a host-committee listing differently would get a different number. A census of the sender field across the 56 returns 35 null and names her not once; that is a fact about a database field and not about her conduct, which is why every attribution above was made at the sheet. ↩

  3. The search for the primary record, and what it returned. Run 5 November 2026 against the same index, size compared and printed as a match, with the firing control returning 371 documents and a freshly invented null token returning zero in the same run. Across the whole release: economic development commission 201 documents, economic development authority 161, certificate of benefits 12, innovative communication 2. The intersection of each of those four sets with her 56 documents is zero. vitelco returns 12 documents across the release, of which 4 are hers and all four are printings of the same April 2012 press inquiry; roosevelt david returns 19, of which the same 4 are hers; edc application returns 38, of which 2 are hers and both are the American Yacht Harbor letter. So every document in this release that connects her to an EDC application is either a reporter’s inquiry or a client-side email, and no instrument is among them. These are statements about this release and about these searches, not about the world: she may have filed a great deal that was never produced, and the territorial agency’s own answer of July 2011 suggests she did. ↩ ↩2 ↩3 ↩4

  4. One sheet reached by her name is refused. It is in the population and is counted in the 60 and the 56, and it is the only document in this population from which nothing at all is taken. Its contents are not described, characterised, summarised or quoted, and the reason for the refusal is not given beyond this: it carries material unrelated to the subject of this page which this page will not reproduce. The refusal costs this page one fact that is independently established elsewhere on it, and no conclusion anywhere above depends on it. ↩

  5. Her signature block, EFTA00639886 printed p. 3. Read at the page image at the served file’s native 96 pixels per inch, fetched with a negative control returning HTTP 403 at 111 bytes in the same call. The paper governs and corrected the released text, which renders her firm’s web address marjonerobertspc.com; the paper reads marjorierobertspc.com. From this sheet this page takes the firm name, the street name, the admissions sentence and the sign-off. No telephone number, fax number or electronic address from this sheet is reproduced, described or located, and this page makes no statement about how any producing party has treated anything on it. ↩ ↩2 ↩3

  6. LinkedIn Connections to Jeffrey Epstein, 11 August 2013, subject See Marjorie's connections, experience, and more...: “Jeffrey, Marjorie has accepted your invitation,” with her description “President at Marjorie Rawls Roberts, P.C. and Owner, Marjorie Rawls Roberts, P.C.” EFTA00717796 p. 1. Released text only; this sheet was not read at the page image. From it this page takes the date, the acceptance, and her self-description as the platform printed it. The connections the message goes on to list are not reproduced here. Five further documents in this population are automated LinkedIn digests of the form “Marjorie Roberts has 3 new connections”, dated between September 2015 and August 2017: EFTA00649574, EFTA00685750, EFTA01138799, EFTA01169918 and EFTA01185509. All five were read and all five are machine mail; they are counted in the population and nothing is built on them. ↩ ↩2

  7. Stacey Plaskett to Economic Development Authority staff, 19 July 2011, subject FOIA Request CONFIDENTIAL Attorney-Client Privilege, circulating Wayne Barrett’s requests with the agency’s drafted answers typed beside them. EFTA00598040 printed pp. 1–2. Printed p. 2 was read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. The paper corrected the released text in two places: the released text prints Renee N. Andre where the paper reads Renée M. André, and 892 St. Thomas Tramway where the paper reads #92 St. Thomas Tramway. From these sheets this page takes Plaskett’s covering sentence, Barrett’s item 3 quoted whole, and the two answers typed beside items 3(a) and 3(b). No staff member other than Plaskett is named on this page from the covering sheet. The answers are typed beside the questions and the sheet does not attribute them to a named person; this page does not supply an author for them. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  8. William L. Blum and Marjorie Rawls Roberts, “The American Paradise: Using a Tax-Free U.S. Virgin Islands Exempt Company for FAA Registration of Foreign-Owned Aircraft,” reproduced from the website of Solomon Blum Heymann LLP. EFTA01204870 p. 1. Read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. The paper corrected the released text, which prints the distance from Puerto Rico as 5o miles; the paper reads 50 miles. The document is undated on the sheet read, and no date for it is asserted here. This project’s own label for the document is travel.itinerary, which it is not; labels in this release are unreliable and none is relied on anywhere on this page. ↩ ↩2 ↩3

  9. Two printings of the same 2006 Form 1099-MISC. EFTA01338175 printed p. 67 and EFTA00175998 printed p. 46. Both read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. From these sheets this page takes four things only: the payer’s name, the recipient’s name, the tax year, and the box 7 figure, for each of the two forms printed on the sheet. The paper corrected this page’s own first reading: the released text placed the figure beside the form’s box 1 “Rents” label, and the paper shows it in box 7, nonemployee compensation. No identification number, account number, street address or post box from either sheet is reproduced, described or located, and this page makes no statement of any kind about how any producing party has treated anything on either sheet. ↩ ↩2 ↩3 ↩4

  10. FedEx shipment detail. EFTA01315219 printed p. 9, invoice dated 22 October 2001, and its second printing EFTA01319379 printed p. 9; and EFTA01259808 printed p. 4, invoice dated 20 January 2003. The 2001 sheet was read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call; the 2003 sheet is released text only and was not read at the page image. From them this page takes the direction of each shipment, the pickup and delivery dates, and the two names. No street address or account number from either sheet is reproduced, described or located. The street number of her office is not given on this page from any source. ↩ ↩2 ↩3 ↩4

  11. The exempt-company thread of 16 to 19 May 2017. EFTA00639886 printed pp. 1 and 3: her message of Tuesday 16 May 2017 at 10:16, Denise Johannes’s message of Friday 19 May at 08:00, and Dolace McLean’s message of Friday 19 May at 13:52. Both sheets read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. From them this page takes her message quoted whole with its sign-off, the opening words of the Johannes message, and McLean’s notice quoted whole. The capitalisation of STAYED INDEFINITELY is the sheet’s own, and the em dash after Attorney McLean is the released text’s own, verified as bytes; it is the only such mark on this page and it stands inside a quotation. No electronic address from either sheet is reproduced, described or located, and this page makes no statement about how any producing party has treated anything on them. McLean’s own signature block gives her title as Legal Counsel and General Counsel to the Lieutenant Governor. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  12. An undated index to legal operating files, heading “LSJ Operating File I”, item 18 “Marjorie Roberts Invoices”. EFTA00299870 printed p. 2. Read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. From this sheet this page takes the file heading and item 18 and nothing else; the other eighteen items in the list name staff and third parties and are not reproduced, summarised or characterised here. The same index appears in EFTA00299879 printed p. 3 and EFTA00300480 printed p. 26. Neither was read at the page image. Item 18 is quoted from the sheet that was read; the other two printings were checked at the released text only and are named so that a reader can verify the index independently. ↩ ↩2 ↩3

  13. Mark Lande to Andrew Farkas, enclosing the American Yacht Harbor EDC benefit renewal application. EFTA00755943 printed p. 2, dated 21 September 2010 in this project’s index, and EFTA00757557 printed p. 2, dated 8 September 2010, carrying the same text. The 2010 sheet at EFTA00755943 was read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. The paper corrected the released text, which prints attomey; the paper reads attorney. From it this page takes the opening paragraph, the five numbered questions in summary with question 3 quoted whole, and the closing sentence. The sender field on both documents carries Andrew Farkas; the letter is signed Mark Lande, and this page attributes the words to Lande on the signature, not to the sender field. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  14. United States Tax Court opinion filed 22 December 2010, reported at 2010 TNT 246-10, reproduced from a tax news service. EFTA00593806 printed p. 4, and a second printing at EFTA01123523 printed p. 4. The first was read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. The paper corrected the released text, which prints Ill for the suffix; the paper reads III. From this sheet this page takes the filing date, the reported citation, the headnote’s description of the residency claim, and the counsel line. The petitioner is not named on this page from any source. ↩ ↩2

  15. Wayne Barrett to Governor John de Jongh, 17 August 2011, subject Request to speak with you, from Wayne Barrett / Questions from Newsweek, forwarded by Jeffrey Epstein to Ian Osborne and Michael Wolff on 19 August 2011 under the subject suggestions?. EFTA00917694 pp. 1–2, and Wolff’s reply of the same morning at EFTA00640384 p. 1. Released text only; neither sheet was read at the page image. From them this page takes Barrett’s opening sentence, his question 4, and Wolff’s reply, each quoted whole. The recipients of Barrett’s original message are withheld on these sheets and are not supplied or named here. ↩ ↩2 ↩3

  16. Memorandum of a meeting at the Economic Development Authority office, 7 September 2011. EFTA01088636 p. 1. Read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call; the paper confirms the released text line for line and changed nothing. From this sheet this page takes the heading, the attendance line, the quoted notes about the FOIA handling, the eight-company list in summary with one company named, the “MRR” line and the closing line. The memorandum is unsigned and its author is not identified on the sheet; this page does not supply one. ↩ ↩2 ↩3 ↩4

  17. Matthew Boyle to Jean P. Greaux, Jr., 10 April 2012, subject URGENT REQUEST FOR COMMENT ON EDC BENEFITS/ICC VITELCO/OTHER COMPANIES, forwarded by Cecile de Jongh to Jeffrey Epstein the same afternoon with her answers inserted, and his reply. EFTA00933166 p. 1. Read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. The paper corrected the released text, which prints the company as ICCNITELCO; the paper reads ICC/VITELCO. The released text prints a plain hyphen at the dash in the quoted passage, verified as bytes; the paper at 96 pixels per inch shows a longer mark that this resolution cannot resolve between an en dash and an em dash. The released text is followed and the mark is not mended. From this sheet this page takes Boyle’s opening paragraph quoted whole, two further clauses, the subject line and the two names. Three further printings of the same inquiry are in the release, at EFTA00702259, EFTA02808236 and EFTA02814259; in the last two the released text has lost the word Roberts, rendering her as Attorney Marjorie Rawls. None of the three was read at the page image and no comparison between printings was made or is reported. Epstein’s reply concerns Cecile de Jongh’s own role and is quoted here only to say that it does so; it is set out in full on her page and is not transferred to Roberts in any way. ↩ ↩2 ↩3 ↩4 ↩5

  18. William L. Blum to Governor Kenneth E. Mapp, 18 May 2017 at 22:38, subject Financial Services Improvement Act of 2017 (FSIA), and his forward of 19 May 2017 at 15:29. EFTA00697631 p. 1 and EFTA00639884 p. 1. Governor Mapp’s reply of 19 May 2017 at 02:33:45, quoted whole above, is at EFTA01045547 p. 1, which carries Blum’s letter beneath it. Released text only; none of the three was read at the page image. None of these documents names Marjorie Rawls Roberts, and none is counted among the 56. They are reached by the phrase attorney mclean, were read, and are set out here as context for the week. From them this page takes five quoted clauses, Mapp’s reply in full, and the fact that Epstein’s address is in the copy line of both the letter and the reply. No electronic address from any of these sheets is reproduced, described or located. Whether Blum was acting for her, with her, or independently of her is not recorded in anything located, and no such link is asserted, and nothing here records that Roberts knew of either message. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  19. Three campaign invitations. EFTA00591684 p. 1 and its second printing EFTA01190102 p. 1 (18 July 2016, Paradise Point); EFTA00794351 p. 1 (29 March 2018, Villa Botanica); EFTA00796253 p. 1 (18 September 2018, Amalia Café). The September 2018 invitation was read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call; the other three are released text only. From them this page takes the dates, the venues and the host-committee lines. No contact detail from any of these sheets is reproduced, described or located. ↩ ↩2 ↩3 ↩4

  20. Her firm’s appearances in the Epstein estate proceedings in the Superior Court of the Virgin Islands, over the signature of Sean Foster, Esq. Certificate of service dated 31 January 2020 at EFTA00075562 printed p. 4; service lists at EFTA00076491, EFTA00076892, EFTA00082467, EFTA02751302, EFTA02751322, EFTA02751802, EFTA02751822, EFTA02751843, EFTA02777998, EFTA02810425, EFTA02821574 and EFTA02846417. Released text only; none of the thirteen was read at the page image. From them this page takes only the firm line, the signing attorney’s name, and the two dates. No electronic address from any of these sheets is reproduced, described or located. Nothing in this group is counted as an act by Marjorie Rawls Roberts. ↩ ↩2 ↩3

  21. “Virgin Island Friends”, a donor acknowledgement in a Rwanda Project USVI report. EFTA01221132 printed p. 2. Read at the page image, 96 pixels per inch, negative control 403 at 111 bytes in the same call. The paper corrected the released text, and materially: the text layer runs two printed columns together, producing the string Anonymous donor from Antilles Marjorie Rawls Roberts School, which is not on the paper. On the page the two are separate entries in separate columns, one reading “Anonymous donor from Antilles School” and the other “Marjorie Rawls Roberts”. The paper also shows a tier distinction the text layer conceals: “J. Epstein V.I. Foundation Inc.” stands in a set-apart block of four names at the top of the acknowledgement, and her name is in the general list below it. Co-listing in a donor roll is not a relationship, and these two names are not even in the same part of this one. The report states that the project “began in the Spring of 2008” and acknowledges contributors who “made the dream a reality in 2008”; the acknowledgement itself carries no date and none is asserted. The word “minor” on this sheet stands inside the phrase “major and minor contributors”. ↩

  22. Document-review reports tabulating search-term hit counts. EFTA00092410 printed pp. 2 and 5, report generated 12 October 2020; EFTA00099346, report generated 14 February 2020; and a term list at EFTA00101080. Released text only; none was read at the page image. From them this page takes only the fact that her name, a proximity form of it, and her firm’s mail domain appear as search terms among other lawyers’ names and domains, and that one report is headed as a privilege-terms search. No hit count from these reports is reproduced on this page, because a hit count is a measure of a search and not of a document set, and nothing is inferred from them about what was produced or withheld. ↩ ↩2

Backlinks