Epstein Data Wiki

The Virgin Islands Financial Services Improvement Act (2016–2017)

Properties2
tagstopic, usvi, legislation, trusts, tax, offshore-financial-structures, epstein-correspondence, 2016, 2017
aliasesVirgin Islands Financial Services Improvement and Corporate Modernization Act, Virgin Islands Financial Services Improvement Act of 2017, Financial Services Improvement Act of 2017, FSIA, the 284-page USVI bill, the USVI financial services bill

45 min read

The instrumentA draft bill for the Legislature of the U.S. Virgin Islands, intended to go to the Legislature over the Governor’s name. It carried two titles in succession: the subject line of the drafting correspondence in September 2016 reads “Virgin Islands Financial Services Improvement and Corporate Modernization Act”, and on 3 November 2016 its drafter wrote that he was proposing to call it the “Virgin Islands Financial Services Improvement Act of 2017.”12
Who drafted itWilliam Blum, a partner at Solomon Blum Heymann LLP of 40 Wall Street, New York, whose name and partnership appear in the signature block of every letter cited here3
Who it was forGovernor Kenneth E. Mapp of the U.S. Virgin Islands was to send it to the Legislature, and the drafter wrote the Governor’s covering letter for him. The drafter’s own account of who had engaged him is different: “since you are the client and you engaged us for this work, we have no choice but to look to you for payment” — written to Jeffrey Epstein45
Who received every draftJeffrey Epstein. On 8 September 2016 the drafter told him a preliminary draft would go to him and to Peter Hiebert, “but please don’t send it to anyone, including the Governor.”6
What it would have doneCreated Virgin Islands statutory trusts with tax exemptions that applied automatically rather than by agency approval; imported asset-protection features from South Dakota, Alaska, New Hampshire, Nevada and the Cayman Islands; enacted a Uniform Principal and Income Act; eliminated the Net Investment Income Tax on Virgin Islands source interest and dividends, a provision deleted again by version 10; and, in a section reserved but at first unwritten, created tax benefits for corporate “repatriation”789
The 284 pagesNo document read for this page says the bill was 284 pages long. Two do fix its length at about that: on 8 October 2016 the drafter wrote “I am reserving space at the end (p. 284) to add the repatriation stuf= — once we decide what we are doing on that”, and on 3 November 2016 he placed the repatriation provisions “at section 15(b) of the bill (starting at page 283)“92
How far it gotBy 17 November 2016 the drafter wrote that “The bill should now be ready for transmittal to the Legislature.” In May 2017 he was still expecting to testify on it “once the hearings are set.” Nothing read for this page shows it being introduced, numbered, sponsored or heard101112
Versions on the recordNamed or numbered in the correspondence: a preliminary draft promised for 9 September 2016, the “First Draft” (13 September), version 7 (8 October, identified as version 7 by the letter of 18 October), version 9 and version 10 (17 November). The bill text itself is not in the files read for this page13941014
Who else worked on itPeter N. Hiebert, who wrote the first statutory trust draft; Barry Hart, on exit tax and the Irish corporate model; Geoffrey P. Eaton, whose written comments were incorporated into version 10; and Erika Kellerhals of the firm through which the fees were billed. Copies went to further lawyers at both firms715105
What is in the files instead of the billThree undated draft bills set out in the Legislature’s own form, with the bill number and the sponsor’s name left blank, each enacting a component the correspondence describes: series limited liability companies, trust and fiduciary protections, and a Uniform Principal and Income Act. Nothing read for this page names their drafter161718

Page limits. Nothing on this page is a finding of wrongdoing. Drafting legislation for a territorial government is ordinary legal work, and no person named here is alleged to have committed an offence by appearing in these documents. Telephone, fax and e-mail values printed or labelled on the documents cited here are not reproduced. No page image of any document cited here was available to this page, so every quotation is taken from the released text of the sheet named in its footnote and nothing here rests on reading a mark on paper; where the released text is damaged, the damage is reproduced inside the quotation marks rather than repaired. This page asserts no printed Bates stamp for any sheet, because none was read. It supplies no sender and no recipient from context, and makes no statement about how any producing party treated any field. It does not cover any document whose subject is a complainant or a survivor.

Between August and November 2016 a lawyer in New York wrote a bill for the U.S. Virgin Islands Legislature, down to the covering letter the Governor was to send with it. No document read for this page shows him sending a draft to the Governor. Every draft in the record goes to Jeffrey Epstein, and it is Epstein who forwards them on; when the bill was finished and the fees were not paid he wrote to Epstein to say why he was asking him and not the territory: “since you are the client and you engaged us for this work, we have no choice but to look to you for payment.”65

What the bill was for

The project began as a memorandum, not a bill. On 23 August 2016 William Blum wrote to Epstein about the possibility of making the Virgin Islands a place where large United States corporations could move asset-holding subsidiaries then located, in the letter’s list, in Ireland, Bermuda, the British Virgin Islands, the Cayman Islands and the Channel Islands. Epstein’s reply the following day went to Blum and to Erika Kellerhals. Of the memorandum he wrote: “The focus of the memo is on IRC sections 367 and 1248.” Those are sections of the United States Internal Revenue Code; the letter names them and does not explain them.7

In the same letter he described the three things that would become the bill. The first was a trust statute he had inherited: “lifted directly from Delaware (which is good)” was his description of the draft prepared for the Governor by Peter Hiebert, and his own changes were to put it into Virgin Islands legislative form and to substitute provisions from jurisdictions more favourable than Delaware. The released text of that passage is damaged across the first of the names it then lists: South Dakota, Alaska, New Hampshire, Nevada and the Cayman Islands. Asset protection, he wrote, was the main focus.7

The second was the tax treatment, and the letter’s own point of comparison is the Economic Development Commission, whose approval the new exemption would not require. The released text of his letter is damaged at four points in this passage; what it reads is that they were trying to work out a method by which the tax exemption for these entities would be automatic for some purposes and owners, with no approval of an agency such as the EDC required, the exemption instead being statutory if requirements were met, as with Virgin Islands exempt companies.7

The third was the one he had not yet solved: how a corporation moving a subsidiary to the Virgin Islands would be taxed. On 13 September Epstein pressed him on it: “does it deal with inbound and outbound to the u.s. ? 367 etc„ or exit tax ?” The answer named the model directly:

Not yet. I am waiting on input from Peter and Barry on both of those issues, especially the exit tax. We need to understand, fairly precisely, how Apple/Microsoft, et al. are being taxed in Ireland in order to try to replicate that, if we can, in the VI. They have promised some input from contacts who may know those types of details.15

Epstein’s own answer to the memorandum had been one sentence, sent after midnight: “when will you have the draft. we need a fully =xamined bill ready by third week of sept?"7

"please don’t send it to anyone, including the Governor”

On 8 September 2016 Epstein wrote a one-word message: “draft?” Blum’s reply sets out the distribution rule the correspondence then follows:

Preliminary by end of day tomorrow. Which I will send to you and Peter Hiebert so you can start to read it, but please don’t send it to anyone, including the Governor.6

He went on: “I expect a fully proofread and more perfected version by middle of next week and that one could be circulated more widely for review in advance of a “final” version, to incorporate changes and comments, which presumably would be ready for the Governor before then end of the month.” The slip in the last clause is in the released text.6

On 13 September he circulated what he called the First Draft: “Here is what I am going to call the “First Draft” of the legislation.” It ran with its own explanatory apparatus: “It also has a four-page explanation section at the end that reviews the bill and goes into detail on some of the important elements”. The circulation widened by one step, to the other lawyers rather than to the client’s government: “I am also going to share this now with Peter Hiebert and Barry Hart as well as with others in our firm who have worked on the bill.” The Governor remained at the far end of a queue: “I expect that Peter and Barry, as well as other attorneys in both firms will have some further suggestions which we will need to incorporate in future drafts before we send it on to the Governor.”13

What Epstein asked for, and what he got

On 15 September 2016 Epstein sent Blum a numbered list of trust features. As it stands in the released text it is printed as items 1, 2 and then 4 to 8, with no item 3 shown at all; this page does not supply the missing item and does not infer what it was. What is printed reads: Quiet Trusts against trusts with an obligation on the trustee to disclose to beneficiaries; divided or directed trusts; decanting; reformation and modification; dynasty trusts; self-settled asset protection trusts; and income and principal division.19

Blum’s reply of 20 September treats the list as a client instruction and reports back against it. He opened: “When do you want to discuss your list of trust—related points below or any other aspects of the bill? Most of these points are already covered except principal and income and decanting.” He added that he had already drafted and added decanting provisions for the next draft, and that he was “also thinking of adding the Uni form Principal and Income Act”, a statute, he noted, that the Virgin Islands had never had and nearly every other United States jurisdiction did.8

The same letter added a tax provision that appears on no item of the list as printed:

I have also drafted a provision to eliminate the “Obama care tax” (formally known as the Net Investment Income Tax) with respect to USVI source interest and dividends in the future as well as some provisions to assist in enforcement of the tax with respect to past years (the tax started in 2013).8

And then, to the client, in the next sentence: “I don’t know if you have been paying this tax but in our view it is clearly applicable.”8

He also raised a further possibility, and it is the one that reaches personal rather than corporate income: “But this also brings up again the issue of an equivalent of PR Act 22 to eliminate all taxes on VI source capital gains (at least on personal property) and other passive income to the extent allowed by the IRC. In PR this only applies to newcomers. We need to talk about this.”8

Where the 284 pages come from

The figure that has attached itself to this bill is not a figure the bill’s drafter ever wrote down. What he wrote, on 8 October 2016, was a note about empty space:

I am reserving space at the end (p. 284) to add the repatriation stuf= — once we decide what we are doing on that.9

The damaged word is in the released text. The same letter gives the internal geography of the draft: a revised title 15, section 1423 on tax exemptions for statutory trusts, and the uniform principal and income act starting at page 100. It then gives the drafter’s own assessment, which stands clean in the released text: “Other changes were just clean up.”9 Epstein’s reply to it was a single word: “Ok”.9

A second document fixes the length independently. On 3 November 2016 Blum described the new repatriation provisions as sitting “at section 15(b) of the bill (starting at page 283)”.2 A bill whose repatriation section starts at page 283 and whose last reserved page is 284 is a bill of about 284 pages. That is an inference from two letters, not a count of a document, and the document itself is not in the files read for this page.14

The three routes to the Governor

The correspondence shows the bill reaching Governor Mapp three times between 12 October and 18 November 2016, and the sequence is the point.

12 October 2016. Epstein wrote directly to the Governor. The message carries no subject line, and the attachment is named for version 7 of the financial services improvement act. The whole of what he said about it was: “attached you will find latest . im working on one more provision.”20 The draft was Blum’s work. The provision Blum had reported outstanding on 8 October was the repatriation section; whether that is the one Epstein meant, the message does not say.

23 October 2016. Epstein forwarded Blum’s letter of 18 October to the Governor, adding two words and a question mark: “see you tues?”4 The Governor replied on 24 October: “Got it, thanks”.4

18 November 2016. Epstein forwarded Blum’s letter of the previous day to the Governor. The forward carries five attachments by name: version 10 of the bill in both Word and PDF, a third version of the Governor’s covering letter, and redlines of the bill against version 9 and of the letter against its first circulated version.10

In none of the three is the bill’s drafter the sender.

The letter the Governor was to send

Blum’s letter of 18 October 2016 is the one in which he writes the Governor’s words for him and then asks Epstein to approve them.

Attached is the proposed transmittal letter to the Legislature from the Governor. I tried to draft it as a mostly “political” document, as opposed to the Explanation section of the bill itself which is more technical and “explanatory.” Please give me any comments.4

The next paragraph asks Epstein to predict the Governor’s politics:

Please note that I have not yet included the repatriation provisions in the letter because (1) I have not drafted them yet, and (2) I am unsure of how you think the Governor will want to handle that issue politically.4

The same letter does two further things. It identifies the 8 October draft: “There are no substantive differences from version 7 which I sent you last week.” And it records a change of name that explains an apparent discrepancy in the record: “The changes are in the Explanation section regarding section 1423 (taxation of statutory trusts — pp. 45-47) and in the name of bill (I changed 2016 to 2017 in the title).”4

That is the moment the title acquires the year 2017. By 3 November the name Blum was proposing had also dropped the words “and Corporate Modernization”: “Virgin Islands Financial Services Improvement Act of 2017.” A reader meeting that later name in the May 2017 correspondence, or on the page for Kenneth Mapp, is meeting the same instrument under its second title.25

The letter closes on the repatriation idea, and on a conversation that is not in the files: “my thought about how to draft the repatriation provisions is to establish a special type of statutory trust that requires a very large capital investment, the 25 employees we talked about, and the requirement that the trust and its assets remain in the USVI for a minimum period of time, etc.”4 Who agreed the figure of twenty-five, and when, is not recorded in anything read for this page.

The last drafts: what went in and what came out

By 3 November 2016 Blum was circulating what he called a further draft of the entire bill to Hiebert and Hart, and proposing the new title. The letter sets out what was new: the revised section 1423 at page 45, the repatriation provisions at section 15(b) from page 283, and general changes to the explanation section. It then flags the parts still unsettled: “There are a few provisions identified in this draft (mostly in section 1423 and the repatriation provisions), which are bracketed and highlighted in yellow, which will require some further attention and decisions.”2

The same letter sets out the order of business, and the client’s place in it:

I believe that bill is now ready for review by Governor Mapp, after which it can be finalized and sent to the Legislature. In that regard, at Jeff’s suggestion, I have also prepared a draft transmittal letter for the Governor to consider using when sending the bill to the Legislature.2

Version 10 followed on 17 November, after incorporating what the letter calls the Winston & Strawn comments, discussed by telephone and then supplied in writing. Two substantive changes are recorded, and one of them undoes the provision of 20 September:

The only major substantive deletion from the prior draft is the section on Net Investment Income Tax (which has been deleted in its entirety as unneeded) and the only major substantive addition is the provision on Series LLCs (which is based on the Delaware law on this subject).10

Blum’s assessment was that the drafting was finished: “In my view, there should be no need for any further changes in the legislation itself prior to passing it along to the Governor for any comments he or his counsel may have. The bill should now be ready for transmittal to the Legislature.”10

And then, in the last paragraph, he offered to appear on it in a character the correspondence does not otherwise give him:

As I have indicated previously, if there is a need or desire to discuss this legislation directly with the Governor, or for my testimony to the Legislature (not so much as the draftsperson, but as an “expert” on USVI financial services and financial services legislation), I shall of course make myself available.10

Then nothing, and then an invoice

The drafting stops in November 2016 and the chasing begins. On 22 November Blum wrote to Epstein: “Do you know what the status of the legislation is with the Governor?”21 On 7 December: “Hi, Jeff. Can you give me any update on this?” Epstein answered “ill see the governor tomorw”, and Blum replied “OK. Please let me know his plans/timing for this. I can be available, of course, for questions, etc.”21

Nothing read for this page records a reply from the Governor or his office on the bill’s substance between the forward of 18 November 2016 and 18 May 2017, when Blum wrote to Epstein about money.

As you know we completed most of our work on the legislative project for you (now the “Financial Services Improvement Act of 2017”) over six months ago. However, the bulk of our fees for this project (billed through Erika’s firm) have not yet been paid and we have been patiently waiting for that to happen.5

The next paragraph is the one that settles who the client was, and it does so in the course of saying that the question of who pays is a different question:

Erika tells me that this may have to do with the fact that the Governor preferred to have the fees paid by his office or by Peter Hiebert’s firm. Exactly who cuts the check to us is not that important to us, but since you are the client and you engaged us for this work, we have no choice but to look to you for payment.5

Epstein replied the same day, and the reply adds the Governor’s reason: “understood , i am meeting with the govemore this week, he thought it imporant that the govt pay, for pr purposes at a minimum , not nice,” followed on its own line by “ill report back aft3r the meeting”. The spellings are the released text’s.5

Blum then added a message for the Governor:

BTW, when you meet with the Governor, please let him know that I am planning to testify on the bill at the Legislature once the hearings are set.11

On the same day, 18 May 2017, Blum wrote to the Governor himself. The letter is addressed to Governor Mapp under the subject “Financial Services Improvement Act of 2017 (FSIA)” and copies Epstein and Peter Hiebert. Its occasion was not the bill: Blum had received an e-mail from an attorney in the Lieutenant Governor’s office which, he wrote, suggested that the office was about to impose a number of administrative requirements on Virgin Islands exempt companies, and the letter argues against them. The bill appears in it as something the Governor was proposing: “these types of changes go directly contrary to what you are trying to achieve by proposing the Financial Services Improvement Act of 2017 (FSIA)”.22 It appears, too, as something he and the Governor had discussed before:

As we have previously discussed, the FISA itself makes almost no amendments to the exempt company law as none are needed; rather it would enact many other modern provisions of corporate and trust law that will make exempt companies and many other entities to be formed in the USVI more attractive to the world market.22

The misspelling of the Act’s initials is in the released text. The Governor answered in a reply dated 19 May 2017: “Thank Bill. I will stop those efforts and bring them in line with my new policies. I’ll get back to you.” The efforts the reply undertakes to stop are the proposals the letter complains of, not the bill, and what came of either is not recorded in anything read for this page. Those proposals, and this exchange, are set out on the page for Kenneth Mapp.22

On 25 May: “Hi, Jeff. Any report after you spoke with the Governor.”23 On 5 June 2017 Blum wrote “Any update?” and Epstein answered: “i know i have to do something , he did not meet with me yet. many texts dealying it. odd including one today”.24

Nine months later the bill is no longer the subject of the correspondence; only the bill for drafting it is. On 19 February 2018 Blum wrote:

I have never heard back from you regarding the exchange below from nine months ago. I don’t believe that Erika has either. Can you please let me know when we can expect payment?25

Epstein’s answer was “pleae ping me friday and you should get payment by a=d of month. sorry”.26 Whether the fees were ever paid is not shown by anything read for this page.

Three bills in the Legislature’s own form

The 284-page instrument is not in the files read for this page. Three shorter draft bills are, and each enacts a component the correspondence names.

One, of eleven sheets, is headed “BILL NO. 32-”, then “THIRTY-SECOND LEGISLATURE OF THE VIRGIN ISLANDS” and “OF THE UNITED STATES” on the two lines beneath it, and proposes “To amend Title 13 Virgin Islands Code to provide for the establishment of series limited liability companies; and for other purposes”. Its explanation section begins “The bill amends the Virgin Islands Uniform Limited Liability Company (“LLC”) Act in three respects”, and the three are series LLCs on the Delaware model, co-ownership of a single LLC interest, and allowing corporations and LLCs to serve as officers or directors of a Virgin Islands corporation, a change the explanation presents as “This change in the law will be unique in the United States although it is often permitted in many other countries around the world.” and recommends as “helpful in attracting new companies to the Virgin Islands and making the Virgin Islands financial services industry more competitive and dynamic.”16

The second, of forty-four sheets, carries the same two headings and proposes “To amend Titles 15, 28, and 5, Virgin Islands Code to allow additional protections for trust settlers. beneficiaries, and trustees and other fiduciaries; and for other purposes”. The spelling and the stray full stop are in the released text. It adds a new Chapter 69 on fiduciaries and trusts, opening on purpose trusts and protection from creditors.17

The third, of twenty-three sheets, proposes “To enact the Virgin Islands Uniform Principal and Income Act”, the statute Blum said on 20 September he was thinking of adding and on 8 October said began at page 100.1889

All three leave the bill number incomplete after “32-” and all three leave the line “PROPOSED BY:” empty. For comparison, two other bills of the same Legislature in the same files are complete on both counts: one is “BILL NO.” “32-0175”, dated 7 March 2018, proposed by Senator Kurt A. Vialet, to strengthen the Economic Development Commission.27

What these three documents are cannot be settled from them. Nothing read for this page names their drafter, gives them a date, or ties them to the 284-page bill; the correspondence’s section 1423 appears in none of them, and a search of the released files finds that section number only in the letters.28 What can be said is that three bills in the Legislature’s own drafting form, with the sponsor’s name left blank, enacting three of the components the correspondence describes, were in Jeffrey Epstein’s files.

The drafter

William Blum appears in the released files as a partner of Solomon Blum Heymann LLP, of 40 Wall Street in New York, and that is how the signature block of every letter cited on this page reads.3 The phrase “William Blum” occurs in 117 documents of the released files, across 156 sheets, as counted on 22 October 2026 against 1,425,556 documents and 2,925,025 sheets in all.29

His own firm’s website, read on 22 October 2026, states that he is a partner, that he served as counsel to the Governor of the U.S. Virgin Islands, naming Governor Juan Luis and the years 1981 to 1984, that he drafted that territory’s foreign sales corporation and exempt company laws, and that he is the leading expert on the territory’s status as a tax haven for non-U.S. persons. The same page lists him as Of Counsel at Kellerhals Ferguson Kroblin, PLLC of St Thomas from 2011 onwards, and describes him as having advocated reforms that resulted in an expansion of the territory’s Economic Development Commission tax exemption programme.30

Those two facts sit together and the page states them without drawing a conclusion from them: the lawyer drafting an automatic statutory tax exemption for the Virgin Islands in 2016 is the lawyer whose website says he drafted the territory’s exempt company law, and he was working, on his own account, for the client who was the bill’s recipient. The fees for the drafting were, in the drafter’s words, “billed through Erika’s firm”; the role of Erika Kellerhals and her St Thomas firm in Epstein’s Virgin Islands affairs is set out on her own page.5

What these documents do not show

Whether the bill was ever introduced. Nothing read for this page shows it. No bill number, no sponsor, no referral to a committee and no hearing date appears in any document cited here, and the last reference to the legislative process is Blum’s expectation in May 2017 of testifying “once the hearings are set.”1112

Whether any of it became law. Not shown by these records. The bill text is not in the files read for this page, so no provision-by-provision comparison against enacted Virgin Islands law can be made from them.14

Whether the Governor knew who had commissioned it. The documents establish that Blum had his own line to the Governor: on 23 August 2016 he told Epstein he had spoken with Governor Mapp about ten days earlier and might see him on island the following week. On 18 May 2017 he wrote to Governor Mapp directly about the Act, copying Epstein, and the Governor replied to him by name.22 Blum also wrote that Erika had told him that the non-payment of the fees might have to do with the Governor preferring them to be paid by his office or by Peter Hiebert’s firm.75 They do not establish what the Governor understood about the engagement, and this page does not infer it.

Who the bill would have benefited. The provisions are general on their face: an automatic statutory tax exemption, asset protection trusts and repatriation incentives would be available to whoever met their conditions. Epstein’s own Virgin Islands entities, Financial Trust Company and Southern Trust Company, have their own pages. Nothing read for this page names either of them in the bill or in the drafting correspondence, and nothing here asserts that either would have used it.

What the missing item 3 of the September list said. The released text of that sheet prints no item 3. Nothing is supplied for it here.19

Where the record disagrees with itself

The page range of section 1423. The letter of 8 October gives it, in the released text, as “(pp 45-36)”, a range that runs backwards. The letter of 18 October gives the same section as “pp. 45-47”, and the letter of 3 November puts the revised section 1423 at page 45. All three are printed here and none is corrected by the others.942

Times in the December thread. The December 2016 exchange carries both a produced header time and a quoted preamble time for messages of the same day, and they do not reconcile with each other on their face. This page gives dates only for that thread and performs no arithmetic on its times.21

Who is named here, and who is not

Named: the bill’s drafter, the Governor it was written for, the lawyer whose files these are, the lawyers the correspondence records as working on or commenting on the bill, and the senator who sponsored an unrelated bill of the same Legislature. Each is named for an act a cited document records, each was an adult at the date of the document, and none is a complainant or a survivor in any matter.

Not reproduced: any telephone, fax or e-mail value appearing on any sheet cited here; and the names of further recipients on the copy lines of the November 2016 letters whose role no document read for this page states. Documents touching private individuals who have no part in this subject were left out of it.

The report this page is drawn from, and three things it gets wrong

This page was commissioned from an internal research report on the same subject, and corrects it in three places. The report’s quotations are repaired: it states in its own notes that where the released text carries obvious damage, “corrections are made silently when the intended text is unambiguous from context.” Every quotation on this page is instead reproduced as the released text has it. The report attributes to the 8 October letter the description “version 7”, which that letter does not contain; the identification comes from the letter of 18 October.94 And the report quotes a law-firm biography describing the drafter as “the foremost expert on the utilization of the U.S. Virgin Islands as a tax haven for non-U.S. persons” and attributing to him the drafting of the Economic Development Commission regulations; the page it cites for that carried no biography when it was read on 22 October 2026, and the other firm’s page, read the same day, uses different words and claims advocacy rather than drafting for the Commission programme.30

Footnotes

  1. William Blum to Jeffrey Epstein, 13 September 2016, whose subject line reads “RE: Virgin Islands Financial Services Improvement and Corporate Modernization Act”, quoting Epstein’s message of the same date under the subject “Re: Virgin Islands Financial Services Improvement and Corporate Modernization Act”. The same subject line stands on two further documents in the released files, Epstein’s messages of 13 and 14 September 2016. Quoted from the released text; no page image of this document was available to check it, and no printed Bates stamp is asserted for any sheet of it. https://epstein-data.com/EFTA01782906 p. 1; the further copies at https://epstein-data.com/EFTA02450817 p. 1 and https://epstein-data.com/EFTA02451505 p. 1. ↩

  2. William Blum to Peter N. Hiebert and Barry Hart, 3 November 2016, subject “VI Fnancial Services Legislation” — the misspelling is in the released text, and the subject line itself stands on the first served sheet. The letter’s own text, and every span quoted from it, stand on the second served sheet of the document cited at 10, below the later letter that quotes it. All quoted spans stand undamaged in the released text of that sheet. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA01061029 p. 2. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  3. The signature block reading “William Blum I Partner”, “SOLOMON BLUM HEYMANN LLP”, “40 Wall Street, 35th floor”, “New York, NY 10005” stands on the sheets cited in this page’s footnotes for 8 September, 13 September, 20 September, 7 December and 22 November 2016 and 18 May 2017 and 19 February 2018. The capital I between name and title is the released text’s rendering of a vertical bar. Telephone and fax labels stand beneath it; no value is reproduced anywhere on this page. Quoted from the released text; no page image was available to check it. https://epstein-data.com/EFTA01782654 p. 1. ↩ ↩2

  4. William Blum to Jeffrey Epstein, 18 October 2016, subject “Legislation”, forwarded by Epstein to “Governor Kenneth E. Mapp” on 23 October 2016 with the message “see you tues?”, and the Governor’s reply of 24 October 2016, “Got it, thanks”, which heads the same served sheet. The letter stands in the released files in two separate documents. The words of the quoted passages are the same in both; a single numeral inside the second quoted paragraph is rendered differently between them, and this page does not say which rendering belongs to which document. The blockquote in the body reproduces the rendering that stands on the sheet cited first below. Both documents are cited and both are linked. Quoted from the released text; no page image of either document was available to check it, and no printed Bates stamp is asserted for any sheet. https://epstein-data.com/EFTA00813687 p. 1 and https://epstein-data.com/EFTA01738723 p. 1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  5. William Blum to Jeffrey Epstein, 18 May 2017, subject “Fees”, and Epstein’s reply of the same day, both on the first served sheet. All quoted spans stand undamaged in the released text of this document, including “govemore”, “imporant” and “aft3r” in Epstein’s reply, which is reproduced as the released text has it. Epstein’s reply stands as two lines on the sheet, a wrapped sentence and then a separate short line; they are quoted here as two spans and are not joined. The same exchange stands in at least three further documents in the released files whose text of the quoted passages agrees word for word apart from single-character rendering differences, which this page does not attribute to any particular document. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA01045539 p. 1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  6. William Blum to Jeffrey Epstein, 8 September 2016, subject “Legislation”, answering Epstein’s message of the same day, whose one-word body “draft?” stands on the document’s second served sheet. The quoted passage stands as reproduced, including “before then end of the month” in the second paragraph. Quoted from the released text; no page image of this document was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA01782654 p. 1, and p. 2 for “draft?”. ↩ ↩2 ↩3 ↩4

  7. William Blum to Jeffrey Epstein, copying Erika Kellerhals, 23 August 2016, and Epstein’s reply of 24 August 2016, subject “Re: Trust Project, etc.”. The released text of Blum’s long paragraph carries substitution damage at approximately a dozen points, which is why this page quotes only the undamaged spans “The focus of the memo is on IRC sections 367 and 1248.” and “lifted directly from Delaware (which is good)” and states the rest of the passage without quotation marks. Epstein’s reply is quoted with its damage reproduced: “when will you have the draft. we need a fully =xamined bill ready by third week of sept?”. The sentence about Governor Mapp reads, with damage, that Blum spoke with Governor Mapp about ten days earlier and might see him when on island early the following week. Quoted from the released text; no page image of this document was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA02454259 p. 1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  8. William Blum to Jeffrey Epstein, 20 September 2016, forwarded by Epstein the same evening under the subject “Fwd: legislation”, which stands on the document’s first served sheet. The letter itself, and all five quoted spans, stand on the second served sheet, undamaged in the released text, including “trust—related” with an em dash where a hyphen would be expected and “Uni form” as two words. Quoted from the released text; no page image of this document was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA02042877 p. 2. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  9. William Blum to Jeffrey Epstein, 8 October 2016, subject “Legislation”, and Epstein’s one-word reply “Ok” of the same day, which stands above it on the same served sheet. The released text of Blum’s first paragraph carries substitution damage at six points, including the page range printed “(pp 45-36)” and a quoted-printable sequence where an em dash belongs; this page quotes “Other changes were just clean up.” which stands undamaged, and quotes the reserved-space sentence with its single damaged word reproduced: “I am reserving space at the end (p. 284) to add the repatriation stuf= — once we decide what we are doing on that.” Epstein’s request of the previous evening, “ple=se send me latest draft . of bill . task over the weekend if good for you re repatriation”, stands damaged on the second served sheet and is not quoted in the body. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA02448555 p. 1, and p. 2 for the 7 October request. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  10. William Blum to Jeffrey Epstein, Barry Hart and Peter N. Hiebert, 17 November 2016, subject “RE: VI Fnancial Services Legislation”, forwarded by Epstein to “Governor Kenneth E. Mapp” on 18 November 2016. The forward’s attachments field names five files; their names are stated in this page’s body rather than transcribed. The copy line of the 17 November letter extends to further lawyers at both firms, including Erika Kellerhals and Geoffrey P. Eaton, whose written comments the letter says were incorporated; recipients whose role the letter does not state are not named on this page. The letter of 5 October 2016 enclosing a revised section 1423, which reads “Attached is a revised version of section 1423 of the proposed legislation which sets forth the proposed tax exemption scheme for VI statutory trusts. It is designed to reflect our discussion of yesterday.”, stands on the document’s third served sheet. All quoted spans stand undamaged in the released text. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA01061029 p. 1, with the 3 November letter at p. 2 and the 5 October letter at p. 3. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  11. William Blum to Jeffrey Epstein, 18 May 2017 at 10.54 pm by the produced header, subject “RE: Fees”, the message immediately following the exchange at 5. The quoted span stands undamaged in the released text. No telephone or fax value from any copy of this message is reproduced on this page. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA02366332 p. 1. ↩ ↩2 ↩3

  12. No document cited on this page records the bill being introduced, numbered, assigned to a committee, sponsored or heard. Searched on 22 October 2026 across the released files for the bill’s two titles and for the phrases “transmittal to the Legislature”, “ready for transmittal” and “legislative hearing”: the first two return one sheet each, both of them letters quoted here, and the third returns 41 sheets across 33 documents, which were not read for this page and are not relied on here. This is an account of what this page found and when, not an assertion about the Legislature’s records, which were not consulted. ↩ ↩2

  13. William Blum to Jeffrey Epstein, 13 September 2016 at 6.55 pm by the preamble quoted in the later message, the covering letter for the “First Draft”, standing on the second served sheet of the document cited at 15. All four quoted spans stand undamaged in the released text of this sheet. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA01782906 p. 2. ↩ ↩2

  14. The bill’s own text is not among the documents read for this page. The correspondence describes it as an attachment throughout, and the attachment contents are not in the released text of any document cited here. This is a statement about what this page found, not about what any producing party released. ↩ ↩2 ↩3

  15. William Blum to Jeffrey Epstein, 13 September 2016, under the subject line quoted at 1, answering Epstein’s question of the same date, which is quoted here as the released text has it, with the double comma after “etc”: “does it deal with inbound and outbound to the u.s. ? 367 etc„ or exit tax ?”. The passage beginning “Not yet.” stands undamaged in the released text of the sheet cited here, which is the sheet this page quotes. The same message stands in at least one further document in the released files, which this page does not quote and about which it states nothing. Quoted from the released text; no page image was available to check it. https://epstein-data.com/EFTA01782906 p. 1. ↩ ↩2 ↩3

  16. An eleven-sheet draft bill, undated, headed “BILL NO. 32-” and “THIRTY-SECOND LEGISLATURE OF THE VIRGIN ISLANDS” and “OF THE UNITED STATES”, proposing “To amend Title 13 Virgin Islands Code to provide for the establishment of series limited liability companies; and for other purposes”, with the line “PROPOSED BY:” standing empty beneath it. Its explanation section occupies the tenth and eleventh served sheets. All quoted spans stand undamaged in the released text. The sheet identifiers within the run are not named here: this project’s index holds no rows for them, and no printed Bates stamp is asserted for any sheet, no page image having been available. Quoted from the released text. https://epstein-data.com/EFTA00812580 p. 1, with the explanation at pp. 10–11. ↩ ↩2

  17. A forty-four-sheet draft bill, undated, carrying the same two headings and the same empty “PROPOSED BY:” line, proposing “To amend Titles 15, 28, and 5, Virgin Islands Code to allow additional protections for trust settlers. beneficiaries, and trustees and other fiduciaries; and for other purposes”, and adding a new Chapter 69, “Fiduciaries and Trusts”, whose first subchapter is headed “Purpose Trusts, Protection from Creditors, and Other Rules”. The spelling “settlers.” with a full stop is in the released text. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA00812591 p. 1. ↩ ↩2

  18. A twenty-three-sheet draft bill, undated, carrying the same two headings and the same empty “PROPOSED BY:” line, proposing “To enact the Virgin Islands Uniform Principal and Income Act”, adding a new Chapter 64 to Title 15 and reciting at its own section 1301 that the chapter may be cited as the “Virgin Islands Uniform Principal and Income Act”. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA00812635 p. 1. ↩ ↩2

  19. Jeffrey Epstein to William Blum, 15 September 2016. The numbered list stands on the document’s third served sheet and is printed there as items 1, 2, 4, 5, 6, 7 and 8, with no item 3 shown; the item texts are “Quiet Trusts vs. Trusts with obligation of Trustee to disclose to beneficiaries.”, “Divided or Directed Trusts.”, “Decanting.”, “Reformation and modification.”, “Dynasty Trusts.”, “Self-settled asset protection trusts.” and “Income and principal division.” Whether an item 3 stood on the paper cannot be determined without the page image, which was not available; nothing is supplied for it here. That the list is Epstein’s is established by Blum’s own reply, which calls it “your list of trust—related points below”. Quoted from the released text; no printed Bates stamp is asserted. https://epstein-data.com/EFTA02042877 p. 3; the covering header on p. 2. ↩ ↩2

  20. Jeffrey Epstein to “Governor Kenneth E. Mapp”, 12 October 2016, a single served sheet. The subject field is printed empty. The attachments field names one file, whose name is that of the financial services improvement act at version 7; its content is stated here rather than transcribed. The quoted sentence stands undamaged in the released text. The remainder of the message concerns a permit application unrelated to the bill and is not reproduced here. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA00815225 p. 1. ↩

  21. William Blum to Jeffrey Epstein, 22 November 2016, subject “Financial Services/trust/repatriation legislation”, standing on the second served sheet; and the exchange of 7 December 2016 on the first, comprising Blum’s “Hi, Jeff. Can you give me any update on this?”, Epstein’s “ill see the governor tomorw” and Blum’s “OK. Please let me know his plans/timing for this. I can be available, of course, for questions, etc.” The sheet carries both a produced header time and a quoted preamble time for the 7 December messages which do not reconcile on their face; this page gives dates only and derives no interval. All quoted spans stand undamaged in the released text. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA01787145 p. 1, and p. 2 for 22 November. ↩ ↩2 ↩3

  22. William Blum to Governor Kenneth E. Mapp, 18 May 2017, subject “Financial Services Improvement Act of 2017 (FSIA)”, copying Jeffrey Epstein and Peter N. Hiebert, with the Governor’s reply standing above it on the same served sheet under a produced header dated 19 May 2017. Blum’s letter runs from the first served sheet onto the second. Every span quoted from this document stands on the first served sheet and stands undamaged in the released text, except that the blockquote carries “FISA” where the same letter has “FSIA” elsewhere; it is reproduced as the released text has it. The e-mail the letter complains of is described in it as attached and is not in the released text of this document. No telephone, fax or e-mail value from this document is reproduced on this page. Blum’s own send time stands in the released text only as a clock reading inside a quoted preamble, carrying no time zone; the send time of the fee letter at 5 stands the same way, in a preamble printed in a different form. This page therefore gives dates for the two letters and derives no interval between them. Quoted from the released text; no page image of this document was available to check it, and no printed Bates stamp is asserted for any sheet. https://epstein-data.com/EFTA01045547 p. 1. ↩ ↩2 ↩3 ↩4

  23. William Blum to Jeffrey Epstein, copying Erika Kellerhals, 25 May 2017, subject “RE: Fees”. The quoted span stands undamaged in the released text and ends with a full stop rather than a question mark, as reproduced. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA02354235 p. 1. ↩

  24. William Blum to Jeffrey Epstein, 5 June 2017, subject “Re: Fees”, and Epstein’s reply of the same day. Both quoted spans stand undamaged in the released text of the sheet cited here, Epstein’s including “dealying”. The same exchange stands in at least one further document in the released files, which this page does not quote and about which it states nothing. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA01044454 p. 1. ↩

  25. William Blum to Jeffrey Epstein, 19 February 2018, subject “RE: Fees”, quoting the exchange of 18 May 2017 beneath it. The quoted span stands undamaged in the released text of the first served sheet. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA02524930 p. 1. ↩

  26. Jeffrey Epstein to William Blum and Erika Kellerhals, 19 February 2018, subject “Re: Fees”. The quoted span is reproduced with its damage: “pleae ping me friday and you should get payment by a=d of month. sorry”. Quoted from the released text; no page image was available to check it, and no printed Bates stamp is asserted. https://epstein-data.com/EFTA02525212 p. 1. ↩

  27. A nine-sheet bill of the same Legislature, carried in the same released files, headed “COMMITTEE ON ECONOMIC DEVELOPMENT” with “AND AGRICULTUE” on the line beneath it — the misspelling is in the released text — over “04/04/2018-SPECIAL ORDERED”, “BILL NO.”, “32-0175”, “Thirty-Second Legislature of the Virgin Islands”, “March 7, 2018”, “An Act amending Title 29 V.I.C. Chapter 12 to strengthen the Economic Development Commission”, “PROPOSED BY:” and “Senator Kurt A. Vialet”. It is cited only as a specimen of the completed form, and has no connection to the subject of this page. A second such bill, numbered 32-0236 and dated 17 July 2018, is in the same files and is complete in the same way: nine sheets, a committee heading, the full bill number, the date, a subject unconnected with this page’s, and a named senator standing on its “PROPOSED BY:” line. Quoted from the released text; no page image of either document was available to check it, and no printed Bates stamp is asserted for any sheet. https://epstein-data.com/EFTA00794849 p. 1 and https://epstein-data.com/EFTA00520997 p. 1. ↩

  28. A search of the released files for the phrase “section 1423”, column-scoped to the text of the sheets and run on 22 October 2026, returns five sheets across four documents, all of them letters in the drafting correspondence quoted on this page. A search for the phrase “Virgin Islands Statutory Trust” returns none. Searches of the three draft bills at 16, 17 and 18 for the string 1423 return nothing on any of their seventy-eight sheets. A control phrase known to be present returns a non-zero count in the same run and an invented control phrase returns zero. ↩

  29. Counted on 22 October 2026 by a phrase search over the text of the released files, column-scoped, against the measured denominators of 1,425,556 documents and 2,925,025 sheets, which are the sum across five production routes and not a figure for any one of them. The phrase “William Blum” returns 117 documents and 156 sheets; the surname alone returns 396 documents and is inflated by the firm name in signature blocks; “William L. Blum” returns 35 documents. An invented control phrase returns zero documents in the same run. ↩

  30. Solomon Blum Heymann LLP, attorney page for William Blum, at https://www.solblum.com/attorney/william-blum/ , read 22 October 2026, HTTP 200. The page carries no date. It gives his title as Partner; lists under past employment “Government of the U.S. Virgin Islands, Counsel to the Governor of the U.S. Virgin Islands (the Honorable Juan Luis), 1981 – 1984”; states that he drafted the territory’s foreign sales corporation and exempt company laws; describes him as the leading expert on the territory’s status as a tax haven for non-U.S. persons; lists “Kellerhals Ferguson Kroblin, PLLC, St. Thomas, Virgin Islands, 2011 – present, Of Counsel” under professional associations; and says of the Economic Development Commission only that reforms he advocated resulted in an expansion of that programme. Because this page was read through a text conversion rather than byte for byte, its wording is reported here rather than quoted, except for the two employment entries, which are plain text. The second biography cited by the report this page corrects, at https://www.kellfer.com/attorneys/william-l-blum/ , returned HTTP 200 on the same date with the page title “Page Not Found – Kellerhals Ferguson LLP” and a body reading that the website is coming soon; it carried no biography, and nothing is taken from it here. ↩ ↩2

Backlinks