This document is 'Exhibit 2' filed in the Superior Court of the Virgin Islands on March 4, 2022, in case ST-2021-RV-00005. The content is a Wall Street Journal article from February 9, 2016, titled 'Legal Fees Cross New Mark: $1,500 an Hour'. The article discusses the rising billing rates of top corporate lawyers in the US, citing specific firms like DLA Piper, Proskauer Rose, and Kirkland & Ellis. It serves as evidence of market rates for legal services, likely submitted to support a fee application in the associated court case.
An email chain between redacted USANYS officials from February 11, 2021, discussing media inquiries (specifically from Bloomberg) regarding a Law360 article titled '3 Names To Watch As Biden Mulls Next SDNY Top Prosecutor'. The forwarded article discusses potential successors to U.S. Attorney Audrey Strauss, explicitly mentioning her office's prosecution of Jeffrey Epstein associate Ghislaine Maxwell as a significant recent high-profile case. The article profiles candidates Damian Williams, Katherine Goldstein, and Anjan Sahni.
This document is an email chain between USANYS employees discussing and forwarding a Law360 article dated February 10, 2021. The article discusses the Biden administration's process for selecting the next U.S. Attorney for the Southern District of New York, mentioning current U.S. Attorney Audrey Strauss's high-profile cases against Ghislaine Maxwell and Peter Nygard. The email correspondence also notes that Bloomberg has been making inquiries to the USANYS staff regarding this topic.
This document is a Law360 email newsletter dated March 5, 2019, summarizing various legal news stories, including the trial of a former KPMG partner, a suit involving a Trump associate and Mariah Carey's ex-manager, and various law firm hirings and suits. The document appears to be included in the collection due to a 'JOBS' listing on page 4 for the law firm 'Epstein Drangel, LLP', which is an Intellectual Property firm and likely unrelated to Jeffrey Epstein personally. The document contains no flight logs, direct communications with Jeffrey Epstein, or information regarding his criminal network.
This document is an email chain from August 2020 involving Parvin Moyne of Akin Gump (representing Deutsche Bank) and redacted recipients (likely government investigators). Moyne informs the recipients that Deutsche Bank received a subpoena from the US Virgin Islands Attorney General regarding the Epstein estate and requests permission to disclose previous government subpoenas and productions to the USVI AG. The internal discussion among the redacted recipients suggests the USVI AG is 'trying to copy our investigation.'
This document is an email thread from November 2019 involving Parvin Moyne of Akin Gump. Moyne updates the recipient on an internal review of bank communications regarding Jeffrey Epstein, specifically identifying a 2013 email from Epstein's accountant Harry Beller containing a chart of Epstein's J.P. Morgan accounts. This chart revealed previously unknown accounts (Butterfly Trust) and banker relationships (Ted Serure, Laurie Cameron) prior to Epstein's asset transfer to Deutsche Bank. The email also notes upcoming document production regarding Darren Indyke's cash withdrawals.
This document is an email chain from August 2019 between Parvin Moyne of Akin Gump (representing Deutsche Bank) and redacted officials (likely SDNY prosecutors). The correspondence concerns the scheduling of an 'attorney proffer' regarding Jeffrey Epstein's relationship with the bank. Moyne proposes a presentation by Akin Gump and 'DB Legal' to overview Epstein's accounts, transactions, and findings from their internal investigation to assist the government in reviewing subpoena returns.
This email chain from August 2020 details a request from Deutsche Bank's counsel (Akin Gump) to the US Attorney's Office (USANYS) regarding a subpoena received from the US Virgin Islands Attorney General. The USVI AG sought copies of all government subpoenas and productions Deutsche Bank had previously provided to USANYS regarding Jeffrey Epstein. USANYS prosecutors discussed the request internally, characterizing the USVI AG's efforts as 'trying to copy our investigation' and deciding to push back on sharing the subpoena itself (citing money laundering statutes) while allowing the release of the underlying documents.
This document is an email dated September 6, 2019, from Parvin Moyne of Akin Gump to a redacted recipient. The email transmits an attachment titled 'Timeline of Payments to Potential Co-Conspirators,' containing identified payment information for specific names/entities and their variations. The document relates to the post-death investigation phase, gathering financial evidence regarding potential co-conspirators.
An email chain from August 2019 between Parvin Moyne of Akin Gump (representing Deutsche Bank) and redacted recipients (likely SDNY prosecutors). The correspondence concerns scheduling an 'attorney proffer' where Akin Gump and Deutsche Bank legal teams would present an overview of Jeffrey Epstein's relationship with the bank, including specific accounts and transactions identified during an internal investigation. The emails discuss logistics, timing (aiming for early September), and the format of the presentation.
This document is an email chain between Parvin Moyne of Akin Gump (representing Deutsche Bank) and likely federal prosecutors (SDNY, based on subject line) in August 2019. The correspondence concerns an 'attorney proffer' where Deutsche Bank lawyers propose to present an overview of Jeffrey Epstein's relationship with the bank, his accounts, and suspicious transactions identified during their internal investigation. They discuss scheduling this meeting and the submission of a production index regarding subpoena returns.
An email dated August 15, 2019 (five days after Jeffrey Epstein's death), from attorney Parvin Moyne of Akin Gump to redacted recipients. Moyne provides an index of document productions related to the SDNY (Southern District of New York) investigation and explicitly requests to schedule a 'proffer' session. The email indicates ongoing cooperation or negotiation regarding evidence production.
This document is an email chain between Parvin Moyne of Akin Gump (representing Deutsche Bank) and redacted recipients (likely SDNY prosecutors) from August 15-22, 2019. They coordinate the scheduling of an 'attorney proffer' set for September 12, 2019, where Akin Gump and Deutsche Bank legal teams plan to present an overview of Jeffrey Epstein's relationship with the bank, his accounts, and suspicious transactions identified during internal investigations. The emails also reference the ongoing production of documents and indices related to the investigation.
This is an email dated August 3, 2020, from Parvin Moyne (Akin Gump) representing Deutsche Bank to a redacted recipient (likely a federal prosecutor or regulator). Moyne informs the recipient that the U.S. Virgin Islands Attorney General has subpoenaed Deutsche Bank for copies of all government subpoenas related to Jeffrey Epstein. Moyne is seeking the recipient's permission to disclose their specific previous subpoena and the bank's production to the USVI AG.
This document is an email from Joseph DiPiero of Akin Gump to an undisclosed recipient (likely the SDNY based on attachment names) dated December 13, 2019. It serves as a transmittal for an additional production of documents from Deutsche Bank in response to a July 11, 2019 subpoena. The email references attached files including a submission PDF and an Excel appendix.
This document is a confidential cover letter dated November 19, 2019, from Akin Gump (representing Deutsche Bank) to the SDNY U.S. Attorney's Office, detailing the production of bank records related to Jeffrey Epstein. The production includes records of asset transfers from JP Morgan, cash withdrawals by Epstein's attorney and accountant, and transactions involving entities like Gratitude America, Ltd., LSJE, LLC, and the Butterfly Trust. It also mentions internal bank policies (ARRC) and due diligence regarding the '2017 Caterpillar Trust'.
This document is a biographical list of high-profile individuals from the technology, political, and academic sectors, possibly serving as a guest list for a conference or retreat (such as the Dialog Retreat mentioned in Auren Hoffman's bio). It includes the footer 'HOUSE_OVERSIGHT_017584', indicating it is part of a House Oversight Committee investigation. Notably, the list includes a 'Jeff Epstein,' who is identified as the former CFO of Oracle, distinct from the financier Jeffrey Epstein typically associated with such investigations.
This document contains an email thread and associated notes regarding the management of complex business and personal affairs, likely for a high-net-worth individual. The text outlines significant organizational disarray, including the lack of an accounting system, staffing issues (hiring/firing), and coordination problems with outside counsel (Paul Weiss, etc.). Specific tasks mentioned include plane and boat expenses, art sales (Picasso), tax audits, and a fee dispute between the sender and Melanie Spinella regarding 'after care' work.
This document contains a series of notes and emails discussing the disorganized state of financial, legal, and asset management for an entity or individual, likely Jeffrey Epstein. It details a chaotic review of investments, taxes, and expenses, criticizes current legal strategies and invoicing, and recounts a history of poor oversight by previous staff members. The text lists numerous law firms, accounting tasks, and specific assets like planes, boats, and art requiring attention.
This document is an email draft or memo titled 'Ulysses 2.0' sent to Melanie Spinella on May 29, 2015. It outlines a chaotic state of financial affairs, citing a lack of oversight, antiquated IT systems, and over 100 uncoordinated bank accounts involving major banks like JPM, DB, and GS. The text details staffing issues, the need for new accountants, and strategic planning for assets including art (Picasso, Calder), planes, boats, and the Phaidon publishing house.
This document contains a series of email correspondences from 2016, likely between Jeffrey Epstein and Leon Black (addressed as 'Leon'), mediated partly through Melanie Spinella. The text reveals significant friction regarding financial management, with the sender (Epstein) aggressively defending his 'high fees' by claiming to have generated billions in value while criticizing the 'outrageous incompetence' of Leon's family office staff (including Alan, Joslin, and others) regarding IRS audits, valuation discounts, and tax planning structures like CLATs and 1031 exchanges. The document includes specific references to Empire Valuation, PWC, BDO, and Akin Gump.
The document contains a detailed list of financial, legal, and administrative tasks regarding trusts, investments, and office management, followed by two emails mainly criticizing the management of a family office. The first email to 'Leon' highlights unresolved issues and staff conflicts, while the second email to Jeffrey Epstein complains about an employee named Brad's incompetence during a transaction.
An email from May 2015, likely written by Jeffrey Epstein to Melanie Spinella, outlining the chaotic state of his financial and legal affairs ('family office'). The sender complains about incompetent staff, a lack of accounting systems across 100 bank accounts and various entities, and details the involvement of 'Apollo' (likely Apollo Global Management) in handling his airplane expenses and tax coordination. The document lists numerous law firms, financial assets (including art by Picasso and Calder), and outlines a strategy for restructuring oversight of his estate, trusts, and businesses.
This document is a printout of a highly critical email sent on June 30, 2015, to Melanie Spinella. The sender (likely a financial consultant, trustee, or high-level manager) details extreme disorganization in the financial, legal, and tax affairs of the subject entity (implied to be the Epstein estate/enterprise), citing a lack of accounting systems, uncoordinated outside counsel (listing major firms like Paul Weiss and Withers Bergman), and incompetent staff. The email concludes with a dispute over professional fees, where the sender pushes back against providing free 'after care' services despite having been paid a large sum.
This document contains notes and an email chain dated May 18, 2015, sent to Jeffrey Epstein (using the alias jeevacation@gmail.com) and his associates. The content outlines a massive 'brain dump' of financial and legal tasks, including rationalizing over 100 bank accounts, overseeing brokerage accounts at major banks (JPM, DB, GS), dealing with IRS/SEC oversight, and managing assets like art (Picasso, Calder), planes, and boats. The text highlights significant disorganization, noting a 'convoluted' corporate structure, unreviewed invoices, and the fact that the subject is 'sitting on over 100 m of cash.'
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