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← Back to Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1;22-cv-10904 (S.D.N.Y. 2022)
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Exhi1.30 Case Document Filed Page of Confidential bject to Protective Government of the United States rgin Islands JPMorgan Chase Bank N.A JPMorgan Chase Bank N.A James Edward Staley Expert Report of Carlyn Irwin Carlyn Irwin Senior Advisor Cornerstone Research June Case Document Filed Page of Irwin Exhibit Jennifer Dunn RMR CRR Table of Contents to Protective I Introduction A Summary of Conclusions Relevant Parties to My Work Assignment Summary of Qualifications Information Considered and Relied Upon in Forming My O7.3p.1inions Professional Standards Applicable to My Work in this Matter Compensation II Summary of Financial and S6.6outhern Pa4.1rticip5.3ation in USVI?s EDC Program A EDC?s Mission and Structure Overview of Financial Partic ipation in the4.1 IDC EDC Program Overview of Southern Trust?s Partic ipation in the EDC Program I Summary of Findings and Opinions with Respect to USVI Tax Benefits A USVI Gave Mr Epstein Over Million in Breaks Giving Mr Epstein Million in Be nefits Made No Economic Sense USVI Failed to Ask Questions or Deve lop an Appropriate Basis to Support Extending the Million in Benefits USVI and EDC?s Ongoing Monitoring of Fi nancial Trust and Southern Trust Did Not Support its Continuation of Benefits to Epstein Over a Twenty-Year Period The Lack of An Economic Rationale or ffort to Develop an Appropriate Basis For The Million in Benefits Suggests Ot her Factors Influenced The USVI?s Grants IV Summary of Findings with Respect to Certain Expert Opinions A USVI?s Experts Conclusions Rega rding Revenue Earned by JPMC from Customers P6.5o.3tentially Associated with Mr Epstein Are Contradictory and Not Supported by Appropriate Analysis Mr Amador?s Opinion Regarding Mr Epstein?s Account Structure is Unsupported Case Document Filed Page of to Protective I Introductio5.6n1.8 I have been retained by Wilmer Cutler Pickering Hale and Dorr LLP counsel for JPMorgan Chase Bank N.A JPMC to prov)5.1id expert tes5timony in th5.8e matter Go5.8vernmen5.8t-1.4 of the United States Virgin Is lands JPMorgan Chase Bank N.A and JPMorgan Chase Bank N.A James Edward Staley A Summary of Conclusions From my review of the record ev5.4idence I onclude that the United States Virgin Islands USVI gave Mr Epstein?s companies Financ ial Trust Company Inc Financial and Southern Trust Company Inc Southern Trust over mil lion in tax breaks The cost of those tax breaks to USVI dw arfed any economic bene fits the territory rece4.8ived in r4e-.2turn.6 USVI?s Economic Developmen5.6t Commis4.8sion EDC ignored Financial Trust?s Southern Trust?s consistently unfa vorable cost benefit analyses and failed to ask questions or gather info6r4m-1.2ation to ju6stify the g6r-1a4.8n1ting of thes5.2e benef4its.6 These shortcomings continued through the tw enty5.8-year p5.8e-.4riod that USVI were4.6 supposed to be monitoring Mr Epstein?s compan ies through his partic ipation in their tax incentive program USVI?s current claims th5.5at Southern Trust was not a legi tima4.7te comp5.9any are based on facts were re4.8adily an6d uniquely a4.8v1ailab6l-1.2e to USVI The extending of benefits without any clear economic basis and without USVI asking the appropriate questions to develop a basis for extending them sugge sts there is some other reason why Mr Epstein was million in tax incen tiv5.7es USVI and is consis4.9tent with the possibility that these benefits were granted as part of an imprope quid-pro-quo exchange between Epstein and5.5 USVI officials.5.5 Government the United States Virgi-5n2.3 Isla-4.3nds JPMorg-4.6an Ch-4.6ase N.A Ca se Second Amend-5.1ed Dem-8.3and for a Jury April the JPMorg Chas-7.6e Co N.A James Staley Case March T-3.2hird-P-7arty Complaint Case Document Filed Page of to Protective USVI?s Experts conclusions regarding revenue earned by JP6.6MC from customers potentially associated with Mr Epstein are contradictory and not supported by appropriate analysis Mr Amador?s opinion regarding the complexity of Mr Epst ein?s account structure is unsupported Relevant Parties to My Work The parties that are relevant to my analyses and tes timony include the entities and individuals listed below a JPMC is a national banking association formed under the of the United States with its ma4.2in in Columb5.4us OH USVI are a group of Caribbean islands and an unincorporated and organized terr3.8ito5.8ry of the United States EDC is a subsidia4.2ry of the Virgin lands Economic Development Authority a semi-autonomous governmental instrumental ity created and governed pursuant to VIC It is my understanding that the predecessor was Industrial Development Commiss4.7i-1.7on5.5 IDC Mr Jeffrey Epstein was a resident of USVI In July Mr Epstein was arres5.2t-1.2ed in Florid6a for so6lic4.8ita4.8tion of prostitution In June Mr Epstein pled guilty to one count of so5.5liciting pro5.5s titution and count of soliciting prostitution from a He was sentenced to onths in a Florida jail and after serving months of his sentence he was released from jail on probation JPMorgan Co SEC for the fiscal ye-4.5ar end-5.2ed filed on pp Party Compla-4.3i-5n2.3t Virgin Factbook at United States 6.6Virgin Isl-5.5ands 6.6Econom-8ic Dev-7.7e1.8lo-4.8pment Auth ority pp VIC See at Associated Pr-7.6ess A of the Jeffr ey Epstein Ghisl-5.7a1.6in-5e Maxwe-5ll U.S News R-5.4eport June at https://w.us Associated Pr-7.6ess A of the Jeffr ey Epstein Ghisl-5.7a1.6in-5e Maxwe-5ll U.S News R-5.4eport June at https://w.us Associated Pr-7.6ess A of the Jeffr ey Epstein Ghisl-5.7a1.6in-5e Maxwe-5ll U.S News R-5.4eport June at https://w.us at Case Document Filed Page of to Protective Mr Epstein returned to USVI in July and as a result of his crimes he became a registered sex offender in USVI He died in while incarcerated in New York related to add5.5ition5.5a-.7l sexu5.5al mis4.7conduct allegations Financial Trust was a USVI-based rporation wholly owned by Mr Epstein and a recipient of tax exemptions from through Southern Trust was a USVI-based rporation wholly owned by Mr Epstein and was a recipient of ta exemptions from through Ms Stacey Plaskett serv5.4ed as Gene ral Counsel for the EDC from through and currently serves as a non-voting dele gate to the United States H7.4ouse of Representatives from USVI She participated in the EDC?s analysis and discussions regarding the extension of Financial award and the award to Southern Trust Mr Albert Bryan served as Chairman of the ED7.4C from through and is the current Governor of the United States Virgin Islands He became Governor in January He voted to approve outhern Trust?s award in i Ms Cecile de Jongh was an employee of Financial Trust and Southern Trust and its EDC compliance co5.6ntact p5.6e-.6rson From January through January she also served as First L6a-1dy of USVI?tha is the wife of the then Governor of USVI Depos-7.7ition Inais May Associated Pr-7.6ess A of the Jeffr ey Epstein Ghisl-5.7a1.6in-5e Maxwe-5ll U.S News R-5.4eport June at https://w.us VI-JPM VI-JP VI-JPM VI-JPM VI-JPM-0 VI-JPM Biography Congr-8esswom-8an Stacey Plaskett U.S of Repres-8en-5.1tatives at Bio graphy Stacey Plaskett Campaign Plasket Congr-8.2ess at Depos-7.4ition Governor Bryan Jr une De-5.5positi-6.2o Biogra-4.2phy Govern-4.2or Albert 6.6Bryan Jr U.S Virgin Government at at de Jo-5.1ngh May Jongh You get the tax ex empti-5.6ons with-4.9out govern-4.9o1.7r pers-7.8ona lly signing 6.6off A Correct Depos-8.2ition Margarit-10.3a Benj-6amin May Benj-6am Ceci-5.5le de De-4.8positi-5.5on Benjam-8.2in Case Document Filed Page of to Protective Mr John de Jongh Jr was the Governor of USVI from J4.6a-.8nuary until January In he approved Southern Trust?s award of economic benefits Assignment As part of my work on this matte I was asked to do the following a Analyze and5.2 evaluate the tax incen tives awarded by USVI?s IDC/EDC to Financial Trust and Southern Trust during the period Calculate the dollar amount of tax bene fits provided by the ID7.3C/EDC to Mr Epstein Calculate the dollar amount of taxes and other economic benefits received by USVI associated with th5.5e tax in5.5centives provided to Mr Epstein?s USVI-based companies.5.5 Analyze the IDC/EDC?s projected an5.5d actua cost vs benefit ratios associated with its d5.8ecisions to tax ince ntives to Mr Epstein5.5?-1.5s USVI-based companies.5.5 Assess how the costs/benefits of Mr Epstein5.7?-1.3s awards comp5.7ared to representations made in his companies applicati ons to the IDC/EDC Analyze the economic impact of the ID C/EDC?s awards on Mr Epstein his businesses and USVI Assess the work done by IDC/EDC in onnection with evaluating extending benefits to and monitoring of Mr Epstein5.7?-1.3s co5.7mpanies.5.7 Assess and respond to certain opinions se forth by experts retained by USVI The opinions expressed in this report and por tions of the informat ion presented in the accompany5.7i3.5ng exhibits are my op5.7inio5.7ns as of th5.7e date of this report At th5.8e request of counsel I may amend or supplement this repo rt and the accompanying exhibits as a result of developments Virgin Gov John de Jr National Governors Association at United States 6.6Virgin Isl-5.5ands 6.6Econom-8ic Dev-7.7e1.8lo-4.8pment Auth ority Annua-4.7l R-5.4eport Ye ar October to Septemb-4.9e1.7r Case Document Filed Page of to Protective prior to or at trial including but not limited to the discovery of new eviden ce expert discovery and the testimony of other witnes ses in deposition or trial At trial I an6tic4.8ipate u6s.2in6g demonstra4.8tives that ma4.6y include are no5.8t limited to selected exhibits attached to this report documents reviewed in connection with their preparation enhanced graphic versio ns of selected exhibits include in this report and additional graphics illu6.1stra4.9ting con6.1cepts includ6.1ed in th6.1is Summary of Qualifications I am a adviso5.6r with Cornersto5.6n.6e Research,5.6 an economic and fin5.6a-.5ncial firm where I serve as an expert wi tness and consultant I have been retained as an expert witness and have provided testimony in fe deral and state courts intern ational arbitration and other venues As an expert and as a consultant I have analyzed financial economic and accounting issues prepared valuations and damages claims and conducted financial forensic analysis In doing so I have worked on matter involving intellectual property disputes including patents copyrights trademarks and trade secrets as we ll as cases involving alle gations of breach of contract unfair business competition false advertising and fraud In addition I have been retained by clien5.8t-1.4s to an5.8alyze da ta to reconstruct financial reco rds estimate profitability and assess the co5.9nsisten5.9c-.3y an5.9d reliability of data I ha4.4ve tes4.8tif3.6ied a4.4nd previous4.8ly qualified an expert regarding econo5.5mic dama ges valuation accounting and fo rensic accounting issues Prior to join5.4ing Cornerstone Re search I was employed as a itigation consultant with the accounting firm of PricewaterhouseCoopers fo rmerly Price Water house from to From to I served as the assistant cont roller for a law firm where I was primarily responsible for among other th ings maintaining the general ledger producing the firm?s financial statemen6ts and6 assis5.2ting th6e ex ecutive committee with strateg5.6i3.4c analys4.8es.5.6 I hold a Bachelor of Arts degree from the Univ ers4.6ity of Califo5.4r-1.6nia at Santa Barbara wh5.4ere I graduated with honors I have an MBA from the University of Sout hern California I am also a Certified Public Accountant a nd a Certified Fraud Examiner a nd I am Certified in Financial Forensics C7.4e-.8rtified in E6.2n.4terprise and Inta ngible Valuation and Accredited in Business Valuation by the American Institu te of Certified Public Account ants A current copy of my curricu5.7lum vitae including a list of the matters in wh ich I have provided expert testimony over the last years is attached as Appendix A Case Document Filed Page of to Protective Informatio5.1n Considered and Relied Upon in Forming My Opinions4.3 In conducting my analyses and forming my opinions I have approached my work from an economic and financial persp ective I have relied on info rmation from sources reasonably relied upon by experts in my field as well as my own professional judgmen and expertise In addition I have relied upon my education expe rience and training in accounting finance economics and general business subj ect matters As pa rt of my work in this matter I have considered and relied upon the fo llo5.8wing catego5.8r-1.2ies info5.8r3.8m-1.4ation a Various pleadings in this matter incl u5.9d.9ing interro5.9gatory fro5.9m USVI The applications for tax incentiv5.6es su bmitted by Mr Epstein?s USVI-based companies to the Transcripts of IDC/EDC meetings in whic Mr Epstein?s applications requested awards and expected co5.8st be n5.2e-1fit ratios were discussed Annual submissions by Mr Epstein?s US VI-based companies to the IDC/EDC that detail th5.5e economic benefits he eceived referred to by the EDC as costs and economic benefits USVI receiv5.2e4d associated with his two5.3 awards Income tax returns submitted by Financ ial and Southern Trust to the IDC/EDC part of th eir annual reporting IDC/EDC pr-6.5epared of th5.5e actual co sts/benefits of the awards to Financial Trust Southern Trust and other EDC award recipients Publicly in5.6for3.6m-1.6ation contained on EDC?s website4.4 Deposition testimony of US VI witnesses and i USVI news coverage related to the ID C/EDC a-6w-2.6ards to Mr Epstein and his USVI-based businesses A complete list th6.2e in6.2forma5ti on I considered is attached Appendix Professional Standards Applicable to My Work in this Matter The Americ4.5an Institu5.7te of Certified Public Accountants publishes professional standards applicable to my work on this engagement In general those standards require CPAs engaged in litigation se4.6r3.8v.8ices to main)5.8tain integrity and objectivity ii only und ertake engagements that are expected5.6 to be comp5.6leted ith p5.7r3.7ofession5.7al competen5.7ce i exercise due pr ofessional care Case Document Filed Page of to Protective in perfo6.1rmin6.1g the serv6.1ice4.9s.3 adequ6.1a-.1tely an6.1d supervis5.3e the perfo6.1rma4.9n1.1ce of th6.1e se4.9rvices5.3 and obtain sufficient relevant data to pr ovide a reasonable basis for the conclusions I have complied with thes4.6e professional st andards in this engagement Compensation With respect to this matter Cornerstone Re search shall be compensated at per hour for my time spent in preparation and support of my opinions and Cornerstone Research shall also be compensated for my colleagues who work ed on this matter under my direction Neither my compen6s5.2a-.2tion no6r my6 colle4.8agues compensa4.8tio6n is contingent or based on the content of my opinions or the outcome of this ma5.2tte5.2r II Summary of Financial Trust?s and Southern Trust?s Par3.8t-2icipation in USVI?s EDC Program A EDC?s Mission and Structure The EDC is charged by the Virgin Islands Economic Deve4.6lo5.8pment Auth5.8ority with promoting the growth developm ent and diversification of th economy of the United States Virgin Islands by developing the human and econo mic resou6.1r-.9ces of the rritory preserving job opportunities for residents of the U.S Virgin Is lands and promoting capital formation to support industrial developmen in the Territory In an effort to ach5.8ie ve its econo6mic dev6e-.2lop6m-1.2ent goals the EDC offers approved bus inesses a exemp6.1tio6.1n that can be applied toward U.S federal income taxes an a exemption from US VI gross receipt taxes In return USVI stands to benefit from the jobs these businesses creat on the island tourism they bring to the island contributions they make to local charities and capital expe nditures they entrust with local suppliers USVI?s witness Ms Margarit a Benja4.7min,5.9 the Manag5.9i ng Director of the EDC testified in her deposition that whe an applicant co5.2mes and receives EDC Statement Standards for No AICPA availa-5.4bl-6.1e Early is permissi-5.6bl-5.6e United States 6.6Virgin Isl-5.7ands 6.6Econom-8.2ic pment Auth-4.5ority Tax Incentive-4.1s-.3 How Do Work States Virgin 6.6Islands Devel-5.5opm-8ent Authority at See e.g Case Document Filed Page of to Protective incentives?there would be new indirect and indu ced activities in USVI as a result of their entry into th6e mark6etpla4.8ce Mr Epstein owned two USVI companies that received EDC tax benefits Financial Company and Southern Trust Company Financ ial Trust was wound down in and replaced by Southern Trust a new7.5 USVI-based company In at the time when the EDC was evaluating Mr Epstein?s applicatio n6 for bene4.8fits associa4.8t-1.2ed w8.2ith Southern Trust the EDC was compr3.8i-1.4sed two princ4.6i3.6pal units i the A pplications Division and ii the Compliance Division The Applications Division was tasked with reviewing applic ations for economic development tax exemptions and maki ng recommendations to USVI governor The Compliance Division monitors bene fic5i-1ar4.2ies to e5n1.2sure tha5t-1 th6.2ey comply with the and conditions of their certificates and with other requirements of law According to its Annual Report the EDC Applications Division sta ff were trained to anal yze the amount of tax exemptions offered in relation to economic development benefits brought to USVI The EDC reported that its Application Division is focus ed on enhancing the cost-b enefit analysis tools used in the application evaluation process to that all q5.6u.6alitative an5.6d quantitativ5.6e data are appropriately collected to comprehensively ascertain fiscal and economic implications The EDC discussed in its fiscal year Annual Repor its objective to update software with Cost Benefit Mod6e-.2l in6formation to cre4.8a-.2te transpa4.8r-1en cy in the application and selection process The EDC on an annual basis prepares repor ts detailing new awards and the performance of existing award recipients Info5.7rmation regard5.7ing performa4.5n ce of ex5.5isting recip5.5i-1.7ents is collected from annual submissions submitted by recipient US6.4VI businesses and may be subject to verification by the Compliance Divisi on through for example site visits Benjam-8.2in at United States 6.6Virgin Isl-5.7ands 6.6Econom-8.2ic pment Auth-4.5ority United States 6.6Virgin Isl-5.8ands 6.6Econom-8.3ic ent Auth-4.6ority pp United States 6.6Virgin Isl-5.7ands 6.6Econom-8.2ic pment Auth-4.5ority United States 6.6Virgin Isl-5.7ands 6.6Econom-8.2ic pment Auth-4.5ority United States 6.6Virgin Isl-5.7ands 6.6Econom-8.2ic pment Auth-4.5ority United States 6.6Virgin Isl-5.5ands 6.6Econom-8ic Dev-7.7e1.8lo-4.8pment Auth ority Annua-4.7l R-5.4eport Ye ar October to Septemb-4.9e1.7r Case Document Filed Page of to Protective Overview of Financial Trust?s Partic ipation in the IDC/EDC Progr-6.3am Financial Trust applied for tax exem ptions offered by USVI?s IDC in Financial Trust?s application the fo5.9llo5.9wing a Financial Trust was owned by Mr Epstein Mr Epstein served as a Directo5.8r-1.2 and5.8 Presiden5.8t It planned to employ ten USVI resi dents in addition to Mr Epstein Financial Trust planned to establish a nd conduct a designate service business providing economic and management consulti ng services as described in Section of The Virgin Islands I ndustrial Development Program Financial Trust planned to provide a broad range of financial and economic consulting money management investment advisory and fi duciary services for its clien6.3t-.9s Financial Trust was forecasting revenues of to million per year and Net Profit Before Taxes of to mil lion per year over the next years On September the IDC met in Executi ve Session to discuss Financial T6r-1.8ust?s application among other matters The meeting transcribe by Porter?s Court Reporting The meeting minutes noted the following a Based on the standard formula used by the IDC at the time it was projected that Financial Trust would generate a cost be nefit ratio of to This indicates that for every of tax br eak/benefits that was give Financial and Mr Epstein as he was the sole owner of th is pass-through company USVI expected to receive of economic benefits in the form of increased local employment local tax and lo6cal inv6e-.2stme4.8nt at at at at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective A cost benefit ratio of to wa referred to as an acceptable ratio It was expected that Financial ratio would improve upon making certain future capital expenditures As a condition of the aw7.6ard the com mittee required that Financial contribute the greater of or of Financial Tr ust?s gross receipts to charity scholarships a nd local co-op marketing The committee approved the following benefi ts to be awarded to Mr Epstein and Financial Trust for the next years a Exemption of of local real estate taxes Exemption of of USVI gr oss receipts taxes and Exemption of of income taxes As a participant in the program Financial ust was required to comp lete and submit an annual reporting package to the IDC In November Financial Trust reported a It earned million of Gross Sale Eligible for Tax Benefits in It earned million of Or dinary Income that would otherwise be subject to income taxe4.9s It paid gross wages of only paid to Mr Epstein Financial Trust and Mr Epstein receiv ed million of income tax benefits and million of Gross Receipts tax benefits During discovery USVI produced spreadshee ts d5.9e-.3tailing the costs the benefits the EDC program The EDC?s actual cost benefi analysis for indicated the following5.1 In the Septem-8ber Ex-7.7ecutive Se Mr F-3.5r-1.3ancois Domini-5.5qu-4.8e a Speci-5.5a Assistant in the IDC stated that one to accepted the IDC over years as acceptab-4.6le rati-5.3o See at Govern-4.8or-8 Albert Bryan in his ition that a g-5ood on i-4.3n3vestment that tax ben-4.5efits USVI 6.7was give-4.5n def initely least one 6.6and half two wo-4.9uld go-4.9od See Bryan at at at at at at at VI-JPM VI-JP VI-J VI-JPM VI-JP Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective a The EDC pr-6.7ovided Financial with million of tax benefits in this was a direct benefit to Mr Epstein as Financial was a S6.7ubchapter pass through entity This million of tax breaks wa referred to as the cost to USVI of the Financial award USVI receiv5.2e-1d of economic benefits.5.2 Financial Trust reported no donations to USVI charities As a result the EDC determined that Fina ncial Trust?s cost benefit ratio for was to indicating that for every dol lar of tax breaks that USVI gave to Financial Trust USVI received only of economic benefits Fiscal year ending December was Fi nancial first full year in the IDC/EDC pr-6.9ogram Financial submitted its annual reporting package to the IDC in October Financial Trust reported a It earned million of Gross Sale Eligible for Tax Benefits in It employed people and paid gro ss wages of paid to Mr Epstein and paid to the other employees It received million of tax benefits in due to its ability to avoid paying million of Gross Receipts taxes and million of income taxes to USVI The EDC?s actual cost be nefit analysis for i ndicated the following a The EDC pr-6.7ovided Financial with million of tax benefits in this was a direct benefit to Mr Epstein as Financial was a S6.7ubchapter pass through entity This million of tax breaks wa referred to as the cost to USVI of the Financial award USVI receiv5.4e-.8d million of econo5.4mic b5.4enefits in th5.4e form of tab Be4.6nefi4t-.4s tab Be4.6nefi4t-.4s tab Proc-8ureme-5.1n1.5t tab Cont-10.8ributi-6.5on tab Be4.6nefi4t-.4s at at at at tab at tab Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective i of wages paid to Fina ncial Trust?s employees ii million of income and employment taxes collected i of local purchases and iv A double-count of employment taxes Financial Trust reported charitable gi fts of only well below the of Financial Trust?s receip5.5t-1.7s of million required According to the EDC?s calculations the ac tual cost benefit ratio for Financial Trust was fo5.8r every cost tax b5.8r3.8eaks give away to Financial USVI received only of ben5.2e-1fits taxes received loca emp5.7l-1.5oyment and lo5.7cal purchases In Fin5.5a-.7ncial Trust?s actual resu5.5lts con5.5ti nued to fall well below the acceptab5l-2.2e levels discussed by the IDC when it approved Financia Trust?s application For example the EDC?s cost benefit analysis reported the following a The EDC pr-6.8ovided Financial T6r-1.8ust ith million of tax breaks in EDC?s Associated with this cost USVI onl received million of benefits Financial Trust made charitable cont ributions of only well below the of Financial Trust?s gross receipts of million discusse by the committee According to the EDC?s calculations the co st benefit ratio for F6.8i-1.6nancial Trust was for every of cost tax breaks away to Fin5.2a-1ncial Trust USVI received only of benefits taxes received local employment and local purchases This pattern of costs tax breaks provi ded to Financial Trust and Mr Epstein significan5.6tly5.6 exceeding the benefits received by USVI continued in Over this year period Mr Epstein received ano5.4t-1.8her million tax breaks from the EDC program See Exhibit tabs and Employm-7.9ent tabs and Employm-7.9ent tab Proc-7.3ureme-4.4n2.2t tabs and Employm-7.8ent T-3.3a2xes tabs Con-5.4t-3.8ributio-5.4n Employme-4.4nt tab Be4.6nefi4t-.4s tab tab Proc-8ureme-5.1n1.5t tabs Con-5.6t-4ributio-5.6ns Employm-7.9ent tab Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective In July Mr Epstein was arres4.8t3.4ed for so5.6licitation pros4.8titu5.6tion In June Mr Epstein guilty to on5.8e count of s5o.8liciting o5.5s-.3titu5.5tion and5.5 one count soliciting p5.5r-1.5ostitution from a He ultimately served mont hs of his 18-month jail sentence In during the inception of what is commo nly referred to as the Global Financial Crisis re4.7ported losse4.7s For example Financial Trust reported an Ordinary Bu5.7siness Inco5.7me loss er million in its tax returns This pattern of financial losses incurred by Financial Tr ust continued during through See Exhibit In Financial Trust?s origin al 10-year tax benefits awar was set to expire In January Financial Trust subm itted an app5.8lic4.6ation to the ED for modification/extension of its ben5.9e-.3fits In February while Mr Epstein was incarcerated in F6.5l-1.9orida representatives of Financia4.6l Tr3.8ust me4.6t with5.8 the EDC to request an extension of benefits as the orig6inal award was set to expire Per th February meeting minutes a Ms Maria T5.8a-1.2nkenson Hodge and Mr Da rren Indyke repres ented Financial Trust In September Mr Epstein asked Mr I ndyke to stand in fo him at that time and for any period that he may be requi red to be absent from the territory Financial Trust requested anot her years of benefits Financial Trust requested that the min imum number of local employees be reduced from to On April the Board met to discus Financial T5.8r-2ust?s application amongst other topics The meeting mi nutes in5.5dicate the fo5.7llowing a The cost benefit of Financial Trus t?s request seemed very unfavorable Associated Pr-7.6ess A of the Jeffr ey Epstein Ghisl-5.7a1.6in-5e Maxwe-5ll U.S News R-5.4eport June at https://w.us Associated Pr-7.6ess A of the Jeffr ey Epstein Ghisl-5.7a1.6in-5e Maxwe-5ll U.S News R-5.4eport June at https://w.us at at at at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective Financial Trust?s projected cost benefi ratio was indica ting that for every of cost benefits given away to Fi nancial Trust and Mr Epstein USVI received only in benefits to economy At the time a ratio below was called unfavorable The EDC discussed that it was projected that USVI would give away million of tax breaks to Financia Trust and in return re ceive only million in benefits The EDC raised concerns about how the public would react to Financial Trust?s projected cost benefit ratio The EDC tabled consideration of Financial Trust?s application On May the met again to disc uss Financial Trust request for an extension of benefits meeti ng minutes reflect the following a Financial Trust?s current benefi ts were expiring in August Financial Trust was now request ing only a 5-year extension After discussion the ED7.5C approved a 5-year extension under certain terms/conditions As a result of the continuing losses incu rred by Financial Trus in the value of the tax breaks awarded to Fi nancial Trust in was minimal In to tal from through Financial received only of addi tional tax breaks from the EDC program See Exhibit On April Financial notified the EDC that it w7.2ould exit the program and no longer wished to receive benefits On January the EDC sent a letter to Ms de Jongh who was listed as the Office Manager at Financial Trust The letter ind5.7i-1.5cated that the EDC had recently comp5.4leted a at at at at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective compliance review of Financial Trust fo the period January through March The EDC concluded that Financial was out of comp6lian6ce with its inve4.8stment requirement and Special Conditions and According to the Compliance Report Special Condition was a requirement that Financial Trust would contribute the greater of per year or of the gross rece4.8ipts ta4.8x exemption6 value The Compliance Report also indicated th6at fro6m September to December Mr Epstein relinquished th5.5e title Director/President to Mr Indyke Overview of Southern Trust?s Part icipation in the EDC Program In September Southern Trust an Corporation wholly owned by Mr Epstein applied for tax exemp5.7tio5.7ns from the EDC Southern Trust claimed that its5.1 business ob5.9jective was to build an extensive DNA database and devel op a data-mining platform for the database to be available through the internet The application indicated th at Southern Tr ust?s pla5.2tfor4.3m will be on databas4.8e-.6s and info5.6r3.6m-1.6ation to kept on ser3.6v.6ers loc4.4a-.6ted in the U.S Virgin Islands specifically St T6.2homas The application indicated the Southern Trust planned to hire only employees in total and be funded with in initial capital Mr Epstein was to be th6e Presiden6t a4.8nd Chief Executive O7.4fficer with an annual salary of Southern Trust disclosed that it intended to hire a C7.3hief Scientific fficer with a in Biomedical Info5.8rmatics a medical degree with conceivably another degree in Computer Technolo gy or Engineering In It is unclear wh-4.9en the DC modifi-6.3ed the meetin-4.6g mi-5.3nutes from ind-4.6i1.4cate that the Spec-8.1ial at the time of the awar-8d was perc-7.4ent of gross recei-5.7p1.6ts or thous-7.9an-5d whic-7.9hever is will be to charity sc hol-6arshi-6p1.3s co-op mark-8.2etin-5.3g of the IDC See at As discuss ed of gross recei-5.7p1.6ts woul-5.7d have re-5quir-8.2ed 6.6Financ-7.9ial Trust-10 to contribute 6.6milli-5.7ons of do-5ll-5.7ars to USVI charities of the gro-4.4ss receipts tax exempti-6.1on results in a lo-5wer thres-7.9hol-5.7d as the exe-5m ption va-4.6lue only gross receipts-7.5 was-8 the perio-5.1d of time Mr Epstein-4.8 was incarc-7.7erat-9.8ed in sex crimes See Associate-4.3d2.3 Pres-7.2s A T-3i1.7meline of the Jeffrey Epstein Maxw-5.5ell U.S News World June av-7ailable at https://w.usnews.com eline-of-the at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective addition Southern Trust represented that a large majority of its employees will have advanced degrees in fields such as Com puter S6.7c-.7ience Mathematics Bi omedical In5.7form atics and/or Finance Appendix to the application indicated th at the four other em ployees of Southern Trust would be a Data Base Manager a Tec hnical Assistant an Accountant and an Adminis5.1tra4.7tive Assista4.7n.9t Southern Trust?s EDC application also disc losed that Mr Epstei was a convicted sex offender application and its appendices disclosed the following a Mr Epstein had been arrested or charge with a crime or offense and been the subject of an investigati on conducted by a governmental agency/organization court commission committee gra nd jury or investigatory body Mr Epstein did face some legal difficul ties relating to matters alleged to have taken place seven years ago exclusiv5.4ely ith5.5in Palm Beach County Florida The Palm Beach County Sheriff?s Office and th Palm Beach County State Attorn5.4ey commenced a local investiga tion of Mr Epstein in re lating to such matters An investigation was also conducted by th United States Attorney?s Office for the Southern District of Florida and the Federal Bur eau of Investigation in rela4.9ting to th6.1e same loca4.9l matters inv6.1e-.1stig ated by the Palm Beach autho5.4r-1.6ities The Federal investigation was discontinued in without the issuance of any Federal changes Nothing for which Mr Epstein was investigated had any relation whatsoever to the business or industry of Mr Epstein or the Application Mr Epstein pleaded gu5.5ilty to and onvicted5.3 of one coun5.3t of solicitation of prostitution and one count of procuring prostitution of a person under the age of He serv5.2ed month5.2s-.6 of an 18-month sentence in the Palm Beach County Jail following by enhanced probation which he completed over two years ago There at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective have been no similar allegations or charges of any misconduct by Mr Epstein since that period of time seven years ago Beginning in civil tort claims arisi ng out of the same or similar matters alleg5.6e-.6d in th5.6e Palm Beac4.4h investigations all alleged to have occurred over seven years ago commenced against Mr Epstei All but one of these tort claims were commenced in Fed5.6e-.6ral Dis4.8t-1.6rict Court fo th6.1e Southern Distri ct of Florida or in the Circuit Court of the th Judicial Circuit in and for Palm Beach County All of the cases commenced agains Mr Epstein arising out of the same or similar alleged conduct have been sett led More details can be provided as necessary upon request The application also disclosed that Mr Epstei was the sole owner of Southern Trust and that he had been the sole owner of F6.3i-2.1nancial Trus which had been an EDC beneficiary for the past years Southern Trust?s EDC application stated that the client base of and the product provided by the Applicant differ mark ed5.5ly from those Financial h6e-.2nce the to6 create a new entity that will all of th5.7e re4.5quire4.5ments of the EDC Despite this representation the application does acknowledge that some Finan6c4.8ial Tru6s.2t e4.8mployee4.8s.2 may be tr4ansfe4.8rred to6 Southern Trust According to the app lication Southern Trust wa projecting annual revenues of million ov5.6er th5.6e next years The EDC he-6ld a public hearing on N7.4ovember to consider the tax incentive applic4.8ation s5.2ubmitte by Southern Trust On January the EDC met in executive session to discuss Southern Trust?s applicati on The meeting minutes indicate the following a It was expected Southern Trust would rece4.7ive app5.9r-1.1oximate4.7ly million in tax benefits per year ove the next years at at at at at See Benj-5.7amin tion Mr Jeffrey stein that they were or they had and 6.6that some of the empl-5.8oyees be transferred to the new co-4.6mpany at Exhibit to the at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective The projected cost benef it ratio was to indica ting that for every of tax benefits given to Sou5.3t-1.9hern Trust USVI was expected to receive of economic benefits This projected ratio was described as favorable The EDC Board approved a 10-year award to Southern Trust which included a exemption from income taxes and a exemption from gross receipts taxes excise taxes and withholding taxes in USVI On January the EDC sent a letter to Southern Trust?s atto rney indicating that the EDC was recommen5.6ding to th5.6e Gover nor of USVI a grant of benefits On February the sent a letter to th en Governor de Jongh indicati ng its recommendation to grant Southern Trust?s award Governor de Jongh approved the aw7.4ard on May Fiscal year ending December was outhern Trust?s first year in the EDC program In October Southe rn Trust submitted its annual reporting package to the EDC The reporting package i ndicated the following a Southern Trust reported million of Gr oss Sales Eligible for Tax Benefits Southern Trust reported million of Or dinary Business Income on its tax return Southern Trust paid of wages and benefits to seven employees Southern Trust paid million of income taxes to USVI this was Mr Epstein?s net tax exposu re from his ownership of Southern Trust Southern Trust received million of tax benefits in due to the award at at at Incentiv-7.7es Do T-3.5hey Virgin Econom-8ic Dev-7.7e1.8lo-4.8pment Auth-4.8ority available at https://usvieda ncentives/tax--7.4incentives at at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective The EDC analyzed the actual cost benefit of Southe rn Trust?s EDC award The EDC?s cost benefit analysis produced in discovery indicated a Southern Trust paid to employees USVI receiv5.5e-.7d of emp5.5l-1.7oyment Southern Trust made of local purchases Total Taxes Duties by Southern Trust to USVI were millio5.4n Thus the economic benefits receive by USVI in totaled million In return cost million of ta breaks provided to Southern Trust As a result rather than g5.6e-.6nerating th5.6e forecas ted cost benefit ratio of of cost for every in benefits received Sou5.4t hern Trust?s award resu5.6lted in an actual co5.8st b5.8e4.6nefit ratio of of cost for every of benefits in The fiscal y5.5ear December was outhern Trust?s second5.3 year in the EDC program In October Southe rn Trust submitted its annual reporting package to the EDC The reporting package i ndicated the following a Southern Trust reported million of Gr oss Sales Eligible for Tax Benefits Southern Trust reported million of Ordinary Business Income on its tax re5turn Southern Trust paid of wages and benefits to eight employees Southern Trust paid million of income taxes to USVI this was Mr Epstein?s net tax exposu re from his ownership of Southern Trust Southern Trust received million of tax benefits due to the EDC The EDC analyzed the actual cost benefit of Southe rn Trust?s EDC award The EDC?s cost benefit analysis produced in discovery indicated tab Empl-5.2oyment tab Empl-5.1oyment tab Proc-7.1ureme-4.2n2.4t tab Empl-5.1oyment tab Empl-5.7oy ment and tab tab at at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective a Southern Trust paid to employees USVI receiv5.5e-.7d of emp5.5l-1.7oyment Southern Trust made of local purchases Total Taxes Duties by Southern Trust to USVI were millio5.4n Thus the economic benefits receive by USVI in totaled million In return the EDC?s cost was million of tax brea ks provided to Southern Trust As a result rather than g5.6e-.6nerating th5.6e forecas ted cost benefit ratio of of cost for every in benefits received Sou5.4t hern Trust?s award resu5.6lted in an actual co5.8st b5.8e4.6nefit ratio of of cost for every in benefits in Southern Trust?s annual reporting pack age reflected similar results The reporting package indicated the following a Southern Trust reported million of Gr oss Sales Eligible for Tax Benefits Southern Trust reported million of Ordinary Business Income on its tax re5turn Southern Trust paid of wages and benefits to eight employees including Mr Epstein Southern Trust paid million of income taxes to USVI this was Mr Epstein?s net tax exposu re from his ownership of Southern Trust Southern Trust received million of tax benefits due to the EDC The EDC appears to attempted to analy ze th5.9e actual cost benefit of Southern Trust?s EDC award However the cost benefit spreadsheet produced in discovery is tab Empl-5.2oyment tab Empl-5.2oyment tab Proc-8ureme-5.1n1.5t tab Empl-5.2oyment tabs Employm-7.9ent and Proc-8.7ur-9ement tab tab at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective incomplete and contains information that is contradicted by Southern Trust?s reporting package Fo5.5r examp5.5l-1.7e a The spreadsheet indicates that Southe rn Trust had Gross Sales of only million compared to million of Gr oss Sales reported on the tax return The spreadsheet indicates that Southern Trust paid no taxes or duties in compared to million of reported taxes paid in the reporting package In Southern Trust contin ued to receive benefits from the EDC program but at much lower lev6.1e-.1ls due4.9 to a sign6.1if4.1ic4.9ant dec4.9lin in Southern Trust?s re venues and profitability See Exhibit I Summary of Findings and Opinions wi th Respect to USVI4.6 Tax Benefits4.6 Between and USVI?s EDC awarded Fina ncial and Southern Trust more than million in tax benefits For those years in which Mr Epstein?s companies reported positiv5.9e ord5.9i3.7nary busine4.7s5.1s income th5.9e cost bene4.7f it ratio of ta4.8x benefits to6 Financia4.8l T6.8r-1ust and Southern Trust was far lower than target ratio as discussed further below tab Empl-5.2oyment tab Empl-5.2oyment Cost benefit ratios are for years-7.6 in whic-7.6h or So-4.7uthern re-4.7ported ordi-5.4nary busi-5.7ness inc-7.9o-5me on the com-8.2pan-5ies In contin-5.1ued to rece-4.5ive 6.6ben-4.5efits from the EDC but at much low-5.3e2r leve-4.6ls due to a si-5.3gnifi-5.3c ant in 6.6Souther-8n Trust?s reven-4.4ues profitab-4.4ility In additi-5.4on I noted that the cost ben-4.7efit spreads-7.6he-4.7et is and co-4.7ntai-5.4ns informati-5.4on is contrad-5.1i.9cted by-8 Southern re-5.1porti-5.8ng In the Septem-8b-4.8e1.8r Mr Francois a Speci-5.3a2l Assista-4.6n2t in the I DC stated that one was acc-7.6epted by IDC over the ye-4.7ars as an rati-5.2o See at Governor Al bert Bryan stated in dep-5.2ositio-5.2n that a goo-5.2d return ment from that tax benefits USVI was given definitely at l-5.5east one 6.6and a half two wo-4.7uld go-4.7od See of Governor Al-4.9bert Bryan Jr June De-5.2posit-10.2ion I present the lo-4.2wer of target co st b9.2enefit ratios purpos-7es of this table Actual-4.7 cost benefit ratios for and Sout-10.4hern as listed the Benefits tab of EDC-3s co-4.4st-benefit See VI VI-JPM VI-JP VI-J VI-JPM-0 Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective A USVI Gave Mr Epstein6.5 Over Million in T7.3ax Breaks During the period through USVI?s IDC/EDC gave Mr Epstein over million of tax breaks associated with his ow nership of Financial Trust and Southern Trust to incen5.9tiv5.9iz4.7e him to con5.9duct busin5.9es5.1s in USVI Attached Exhibit is a summary of the taxes and duties paid by Financial Trust and Southern Trust to USVI and ii the reported value of the tax exemptions aw7.5arded to Mr Epstein A7.6ccording to the tax returns submitted by Mr Epstein5.5?-1.5s co5.5mpanies to the IDC/EDC each year,5.5 Mr Epstein5.5 paid only million5.5 of inco5.5me taxes on over million of Ordinary Business In come earned by Financial and Southern Trust during the period This indicates th at as a result of the IDC/EDC Mr Epstein?s net effective income tax rate on million of income earned by his USVI-based companies was only Giving Mr Epstein Million Be nefits Made No Economic Sense As discussed above based on the methodology used by the IDC in it was projected that Financial Trust would generate a cost benefit ratio of to This indicates that for i-5.9ncome taxes divid-6.2ed by busi-6.1nes-8.3s income equ-6.5als See Ex4hibit at B5.8e-.5nefit Ratio Benefit Re Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective every of tax breaks that was to be given to Financial Trust and Mr Epstein as he was the sole owner of this pass-through company USVI expected to receive of economic benefits in the form of increased local emplo6y1ment local tax and local investment However Financial Trust?s actual cost benefit was significantly below the IDC?s projections and its so5.6-called accep5.6table ratio5.6 to As reflected in Financial Trust?s annu5.7al repo5.7rting packages an5.7d the availa EDC cost benef3.7it sp readsheets produced in discovery F6.4i-2nancial Trust?s actual co st benefit ratios in were a ratio to ratio to and ratio to Each of these ratios calculat ed by the EDC were well below i the fo)5.8rec4.6a-.4sted ratio to that was discussed by the committee at th time it was considering Financial Trust?s application and ii acceptable rati of to discussed by the committee.5 Southern Trust?s actual cost benefit was similarly also significantly below the EDC?s projections and its so5.7-called accep5.7table ratio5.7 to For examp5.7l-1.5e per the cost benefit calculations produced in discovery the actual cost benefit in was only to This ra4.7tio well i the pr)3.9ojected that the EDC disc ussed when it decided to approve S6.5outhern Trust?s award ii the to acceptable level discussed by the EDC in and i the to unfavorable level discussed by the EDC in Thus from to neither Financial Trus nor Southern Trust came close to generating sufficient benefits to USVI to offset the tax incentives granted to Mr Epstein and these co5.7mpanies let alon5.7e reach the thresholds th5.4e EDC considered acceptable.5.4?-.8 Based on the record the EDC was of Mr Epstein?s companies multi-year history of poor cost benefit performance yet agreed to extend Financial Trus t?s certificate in and granted Southern Trust a new certificat in regardless at tab Be4.6nefi4t-.4s tab Be4.6nefi4t-.4s tab tab at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective USVI Failed to Ask Questions or Develop an Appropriate Basis to S6.3upport Extending the Million in Benefits USVI?s EDC did not properly evaluate Mr Epst ein?s applications for benefits and failed to ask him even the most basic questions based on infor3.7m-1.5atio5.7n that was u5.7n.7iquely av5.7ailable to it about his companies In awarding hundreds of millions of dollars in benefits to Mr Epstein USVI failed to perform even perfunctory examination of info rmation that uniquely available to it and ignored its own calculations that Mr Epstein?s companies were not conferring the promised economic benefits on USVI In and the awards to Mr Epstein were ultimately approved by Governor de Jongh He approved thes benefits while his wife First Lady Cecile de Jongh was the office manager for Mr Epstei n?s companies and received a salary bonuses and other benefits including tuition for children fro6m Mr Epste4.9i-1.2n Based on my review of the record I have not seen any evidence th at USVI or the employed any procedure to manage or investigate the real and/or perceived conflict of in terest by Governor de Jongh?s approval of tax benefits that directly benefitted his family Governor de Jongh testified that no such measu5.6r3.6es were put in place Moreover based on my review of the record it does not a ppear that the exercised their unique ability to inv5.8e-.4stig5.8ate ques tions of Mr Epstein and his companies during hearings evaluating his businesse In when testifying in front of the EDC on behalf of Financia4.5l Tr3.7ust Compan5.7y Mr Epste4.5i-1.5n made exa4.5ggerated sta4.5t3.5ements inc4.5l3.5uding 4.5until on5.7ly ten years ago you actually had to be in New York City to do financial business He also testified my core business frankly is me but also stated he ould have at least ten employees at a minimum The EDC did not ask for the name of Mr Epstein?s clients nor why his statements were intern ally inconsistent and he need ed ten additional employees to Government the United States Isla-4.4nds JPMorg-4.6an Ch-4.6ase N.A Case JPMorga-4.2n2.4 Bank N.A.?s Oppositio-4.2n USVI?s Moti to Strike Affirmative Defe-4.5ns-7.4es May JPMC Oppositi-5.3on to 6.6Motion to Strik-7.5e2 Exhibit JPMC Oppositio-4.4n to Motion to Exhibit JPMC Oppositio-4.6n to Motion to St Exhibit De-4.9posit-9.9ion of Governor de Jong-5.1h Jo-5.1hn de epos-8ition de Bryan John de at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective operate an investment advising business for whic he would be the only advisor In addition when Financial applied for a renewal of benefits for Financ ia4.8l Trust in Fe4.8bruary Mr In5.4dyke appeared on behalf of the co5.4mp any because Mr Epstein was incarcerated in the United Based on my review of the record the EDC did not ask where Mr Epstein was about his incarceration or how he could co ntinue to provide a broa range of financial economic an5.4d business consulting services4.6 from jail Moreover the ED7.5C did not ask about any of the company?s clients Again based on my review of the record I am not aware if they discussed these topics in privat or in the executive session USVI also did not conduct checks on Fina ncial during the renewal period A January EDC due dilig5.7ence r3.7e4.5port state4.5s-.1 th5.7at Mr was registered as a fin5.7a-.5ncia4.5l servic4.8es f4i-1.2r4m/inv6e-.2stme4.8nt adviso6ry with the Co5.3mmodity Fu5.3tures Tr3.3adin5.3g Commiss4.5i3.1on CFTC the Nation5.3a-.9l Association5.3 of Securities Dealers 4.5NASD and the Nation)5.7a-.5l Futur3.7e-.4s Associa4.5tion NFA Yet I am not aware of anything in the record that indi cates the EDC verified this In July a researcher with the Da ily Beast confirmed that Financ ial Trust was never registered with any of those entities Nor does the record reflect that the did anything to review?or even acknowledge Mr Epstein?s criminal history dur ing their granting of benef4its5.2 to him d6e-.2sp6ite it be4.8ing laid out and included in his application In fact the Chairman of the EDC from to current USVI Governor Albert Jr testified he was not aware of news in that Mr Epstein had settled more than two dozen lawsuits and cl aims against him by teenagers who say they gave him sexually charged massages and/or sex in ex change for money despite the fact that this infor3.8m-1.4ation was public4.6ly5.8 available the time the EDC was voting to renew tax benefits for Financial Trust Mr Bryan tes4.9tif3.7ied5.7 that the EDC was generally less concerned about the ethics and integrity of the owne of a business receiving EDC benefits if the business up for renewal as Financial Trust was after Mr Epstein5.3?-1.7s arrest b5.3e-.9cause the ED7.5C had a track record at Associate-4.9d-4.9 Press A of the Jeffrey Ep stein Ghisla-4.9in-4.9e Maxw-5.6ell U.S News World Re-4.6port June available at https://w.usnews.com/news at at Note that the registrati-5.4on an exam-8.6in-5.4ation of int-10.4e1.2rmedi-6.1aries beh-4.3alf of the See Be 6.7Smart Check Registr-7.9a1.9tion 6.6Backgro-4.7un-4.7ds Before You CFTC https://w.cftc.gov/check.-9.1 Bryan Dep-4.6o2siti-5.3on June Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective how the beneficiary had perform ed in the past to rely upon However based on my review of the record Mr Epstein?s tra ck record on performance was in fact unfavorable As discussed above Financial Trust submitted an application for an extension in January On April the EDC held an Execu tive Session to discuss the application during which Finan5.6c-.6ial histor3.6ica4.4lly low unfavorable cost benefit performance was discussed Moreover it was noted that the applica tion stated that Financ ial Trust planned to make million in expenditures but it was anticipated that USVI would forego nearly million in tax revenues over the same five-year period While this compa4.6r-1.2ison some concerns,5.8 and there was further discussion regardi ng needing support for the position that they were giving up more than they are getting the mo6.1tion6.1 was tabled until the meeting in May During the May Executive Sess ion after agreeing to certain additional from th5.9at did no5.9t mater3.9i-1.3ally cha4.7nge the co5.9mpany?s forec4.5a-.5sted ben5.7e-.5fit performanc4.5e4.5,.7 the EDC a pproved Financial Trust?s application for a five year extension In Mr Epstein submitted an app lication for his new USVI-based company Southern Trust Southern Trust?s applic ation flagged that Mr Epst ein was the sole owner of Financial Trust acknowledged that Mr Epstein had been a rrested and had been the subject of a government investigation and noted that some Financ ial employees may be transferred to Southern Trust Southern Trust?s applicati on claimed that Mr Epstein and Financial Trust made signifi cant contributions to the SVI economy over the past years Southern Trust?s EDC application also included a detailed appendix discussing his arrest criminal conviction and related civil tort claims Bryan e-4.9mphas-7.8is at at at at at at at at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective Mr Epstein testified in front of the in Nove-6.1mber that Southern Trust would organize mathematical algo rith5.8ms5 to create computer ge nerated solutions for medical problems but also that it would search the world?s database for what is the best investments in a nanosecond Mr Epste4.4i-1.6n also testified5.6 that he n5.6eed5.6ed high ma4.4thematician5.6s-.2 to help prog5.8ra4.6m the co5.8mp5.8uters un5.8til the will he4.6lp r3.8e-.4design so5.8me of the computer programs and become almost like a c4.9h1.1emis5.3try lab6.1 in the co6.1mp6.1uter Based on my review of the record the ED did not investigate or quest ion Mr Epstein regarding the reasonab5.6l-1.6en5.6ess or feasib5.6ility of these claims.5.6 Mr Epste4.4i-1.6n furthe4.4r testif3.6ied he would make4.6 money beca4.6use s5 1.2ome will be ou5.8tright purchases probably the simple ones There will be leases for onger runs and most people will be coming back Sometimes if you want to know just like a search en gine in answer to one question you get paid for that piece advice ongoing advice exclusive rights lik5.4e drug companies might want to have for a specific answer He also used an anecdote about French fries to explain how his business would work When you go in your computer it might target you for a specific type of advertisement because it knows th at after you?ve been searching for French fries So they mine all the people in the area who is looking for French fries and said you know Randolph seems to like that So we?ll send him a message Mr Epstein proposed to do genetic sequencing in the Virgin Islands to obtain medical data fo his database because it?s so iso5.7l-1.5ated that are ab5.7le to get much better data than ever before Based on my review of the record the EDC did not press Mr Epstein on any of these assertions or ask Mr Epstein for any detailed information ab out Southern Trust?s mission or plans For example the EDC did not question Mr Epstein about his purportedly established algorithms names and qualifications of the pe ople he intended to employ to develop his proprietary DNA database names of potential clients or how he would obtain and analyze DNA information Furthermore the EDC did not ask how Mr Epstein would conduct genetic sequencing in USVI nor how he pl anned to use that genetic sequenc ing to generate solutions to medical problems The EDC did ask if ther other companies a4.4tte4.4mpting similar3.6 at at at at at Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective endeavors to which Mr Epstein re plied there is a couple doi ng it in California Jobs had a group that was trying to help him and it was a little too short Based on my review of the record the EDC asked no follow up questions on this topic Southern Trust?s EDC applica tion in5.9dicated its bus5.1in ess goal was to build an extensive DNA database and develop a data mining platform accessibl via the Internet Southern Trust further claimed to be involve in biomedical and financial informatics According to USVI?s own forensic accounting xpert Mr Jorge Amador Southern Trust was not in fact performing related to its stated purpose Mr Amador?s opinion is based on a review of Southern Trust?s fi nancial documents th ese do5.8cu5.8ments were fi led with the EDC on a yearly basis The documents Mr Amador relied upon contain the same information that existed at the time of Southern Trust?s application and the issu es in them should have been flagged by the EDC Ne-6.1vertheless did not raise any con5.8cerns and continued to provide benefits to S6.4outhern Trust until af ter Mr Epstein was arrested in Indeed even after Mr Epstein5.7?-1.3s th5.7e EDC still did not take step to te4.6rminate Mr bene4.6f3.8its was only after Mr Epstein?s death that his lawyer came to EDC and themselves requested termination of benefits Despite Financial unfavorable co st benefit performance from to and the expectation of continued poor perform ance the EDC nevertheless decided to grant Financial Trust a five-year extension on its benefi ts in and then went on to grant additional economic benefits to Southern Trust from to at at at Expert Report Jorge Amad-4.6or June R-5.4eport Amador Re-4.8por-8t Associated Pr-7.6ess A of the Jeffr ey Epstein Ghisl-5.7a1.6in-5e Maxwe-5ll U.S News R-5.4eport June available at https e-of-the--7.3jeffrey Benjam-8.3in Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective USVI and EDC?s Ongoing Monitoring of Financial Trust and Southern Trust Did Not Suppor-6.2t-2 its Continuation of Benefits to E7p1.2stein Over a Twenty-Year Period6.5 Based on my review of the record despite be ing a government entity with the ability to conduct audits and investigations the EDC and USVI made only cursory attempts to monitor Financial Trust and Southern Tr ust them EDC tax benef3.5its The EDC Compliance Officer assigned to Mr Epstein5.5?-1.5s en5.5tities Sandra Bess did not prep are th6e first compliance report for th5.8at busin5.8ess u5.8n.8til April nine year after Fin5.7a4.5ncial first b5.7ecame an EDC beneficiary in April even though compliance repor ts were required annually Moreover she did not prepare the second complia nce report for Financ ial Trust until January almost six years after the first report During this process Ms Bess testified that she dealt with Ms De Jongh who served as the office manager of Financia Trust and Southern Trust Ms Bess tes4.9tif3.7ied at the time of these ED7.3C site visits Ms De Jongh was also th wife of the Governor of USVI and therefore was the acting First Lady of the Virgin Islands Ms Bess did not attempt to verify w7.6h.4ether Southern Trust was engaged in the business acti vities they purported to perform during site visits instead she chose to rely on information in th annual report provided by Mr E6.1p.3stein and his staff For instance Ms Bess did not do anything to verify that Southern Trust?s alleged clients or the extensive DNA data base it was developing were real instead she chose to rely on representations of Sout hern Trust?s employees Indeed the inconsistencies in the reports Fina ncial Trust and Southern Trust submitted to the EDC did not prompt the EDC compliance depart ment to review any in formation outside of the information Mr Epstein provid ed to verify that Mr Epstein was in fact a resident of the Virgin Islands as was required to be an EDC be neficiary This was true even while Mr Epstein purported to be a USVI reside at th5.8e same time he wa incarcerated in Florida The EDC and USVI also ignored contradicto5.2r-1.8y rep5.2r-1.8esentations includ5.3ing testimony that Mr Epstein5.3?-1.7s business Depos-7.9ition Sandr-8.2a Bess May Dep-5o1.6siti-5.7on Bess Depos-7.7iti-5.5on Bess Depos-7.4iti-5.2on Exhibit Bess Depos-7.8iti-5.6on Bess Depos-7.8iti-5.6on Bess Depos-7.5iti-5.3on Bess Depos-7.9iti-5.7on Bess Depos-7.6iti-5.4on Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective Southern Trust was a new venture that ould take some time to get up and running juxtaposed with his reported first year sales of million The EDC also ignored the fa ct that Financial Trust di not meet the required contribution5.6s-.2 to charity scholarships4.8,.6 and loca co-op mark5.6eting As a co5.6ndition th5.6e award the IDC required that Financ ial Trust contribute the greate of or of Financial Trust?s rece4.6ipts to charity sc holarships and local co-op marketing According to Financial Trust?s application F6.6i-1.8nancial Tru5.4s forecasted5.6 only averag5.6e total of million per year over years Thus of Financial Trust?s forecasted gross receipts/revenues would be per year As discussed above Financial Trust?s actual revenues during the award period significan5.8tly5.8 exceeded th5.8e forecasted revenues reflect ed in its application In its application Financial Trust projected its revenues would be only million in years Howe-6.5ver Financial Trust?s actual revenues in were signif icantly higher a In Financial Trust reported milli on of Gross Sales Eligible for Tax Benefits In Financial Trust reported milli on of Gross Sales Eligible for Tax Benefits In Financial Trust reported milli on of Gross Sales Eligible for Tax Benefits As a result in order for F6.6i-1.8nancial Trust to eet th6.1e IDC?s req6.1u1.1ired charitable contribution of of gross receipts Financ ial Trust would have needed to make donations to USVI charities of over million in However EDC cost benefit spreadsheets show that Financial Trust failed to meet this requirement For example i in Financial no charitable contributions ii in Financial reported only in charitable Bryan VI at at at at at at at at tab Cont-10.6ributi-6.3ons Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective contributions approximately of Gross Receipts and i in Financial Trust reported only in charitable contributions approximately of Gross Receipts I have seen nothing in the record to explain why th5.7e IDC/EDC failed to req5.7u.7ire Fin5.7a-.5ncial Trus4.9t to comply with5.2 its requirement to donate of Gro5.5ss Receip5.5t-1.7s each year to USVI charities.5.5 The EDC also failed to investig5.6ate th5.6e criminal allegations against Mr Epstein alleg6a-.2tion6s.2 that ma4.8jor ne4.8ws outlets fr4equently covered and which were in cluded in his Southern Trust application After Mr Epstein was arrested in upon determining that the circumstances underlying the arre st were not effectively connect ed to Financial Trust nor in the ju5.3risd5.3iction in the Vir3.3g.3in Islands,?4.1 the EDC failed to generate a report investigate the circumstances of the arrest or perfo rm any other type of investigation Even after Mr Epstein5.6?-1.4s EDC compliance te stif4.1ied they did not pe4.9rf4.1orm any add6.1ition6.1a0l investigatio5.7n into Mr E6.5p.7stein b5.7ecau5.7se the agains4.9t Epstein were 4.6i-1.5rrelevant to th5.7e certificate th5.5at was issu5.5ed In the same vein Southern Trust?s applica tion proposed that certain Financial employees would also wo rk for So5.3uthern Trus4.5t yet it provided no explanation for why the employees of a financial services co5.8mpany Fin5.8a4.6n.8cial which at th5.8e time the Governor?s wife Ms Jongh would be qualified to work for a database company Based on the record the EDC also did not notice that of S7outhern Tru5.8s0t?s million in rev5.8e4.6nue from to million came from a sing le customer?Mr Leon Black There is no explanation for how his large payments were in any way connected to sales based on a DNA database In a Complaint filed against the Epstein Estate USVI government has subsequently disclos4.7e-.7d a number of addition5.5a-.7l warning sign5.5s th at could an5.6d should been and addressed by the EDC during its monitoring of Mr Epstein?s companies including a Individuals supposedly employed by Sout hern Trust allegedl performed other personal services for Mr Epstein T6.2hough he was reported by Southern Trust to tabs Con-5.6t-4ributio-5.6ns Employm-7.9ent tabs Con-5.6t-4ributio-5.6ns Employm-7.9ent Bryan Bess Depos-7.8iti-5.6on at See Amador fn Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective be resident of the Virgin Islands th network ad6minis5.2tr4ator4/I4T manager was issued a Flo5.4r3.4ida driver?s license which lis ted an address in Miami Further the admin5.7istrato5.7r-1.3 allegedly s4.9e-.5rved as Ep stein?s driver and picked up luggage and cargo from Mr Epstein?s priv ate planes on his behalf Another executive assist ant lived at th Street Apartment New York New York Mr Epstein?s address book lists various units in this building as providing Apt for mo dels and she is publicly identified as a model a During several time periods Southern Trust Co5.5mpany to EDC that it had no employees who were non-resi dents even though it employed non residen6t-1.2s USVI?s complain5.6t concludes it is cl ear that Southern Trust Company did not perfor4.5m-.7 th6.5e business represented to th EDC and could not have generated the business inco me attributable to that business Instead upon information and belief S6.6outhern Trust Comp any existed to secure tax benefits for Mr Epstein to employ individuals associat ed with the Eps4.5t-1.9ein and to provide a so5.8urce of inco5.8me to suppo5.8rt hi crimin5.6al activities and properties in th5.6e Virgin Is5.2lan6d1s These issues4.4 identified USVI in its comp laint agains5.2t the Epstein Es5.2ta4.8te ar4e the so6rts of facts that can easily be le arned through basic checks and ques tions and should all have been discoverable by the EDC and USVI earlier The Lack of An Economic Ration6.6ale or Effort to Develop6.3 an Appropriate Basis For The Million in Benefits Suggests Other Factors Influenced The USVI?s Grants4.7 As discussed above the goal of the EDA ta benefit program is to drive growth diversity and employment in USVI and USVI?s economy Consistent with that mission the EDC Applications Division staff we re trained to analyze the amount of tax exemptions offered in at at at at Depos-8.1ition Kenn-5.2eth Ma May Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective relation to economic developmen benefits brought to USVI Again the EDC considered a cost b5.4e-.8nefit ratio of to to be an accep5.4table ratio Based on my review of the record the EDC was aware that the cost-b5.7enefit ratios fo5.7r Financial Trust fell well short of the EDC?s stated goals In for every dollar of tax breaks that USVI gave to Finan5.6c-.6ial VI receiv5.4e4.2d only in economic benefits In for every of cost tax breaks given away to Financial USVI received only of benefits taxes received local employment and local purchases In for every of cost tax breaks given away to Financial Trus USVI received only of benefits The EDC Board recog5.7n.7ized th5.7is po5.7or perfo5.7rmance when it deliberated whether to extend EDC benefits to Financial Trust in noting that the cost benefit of Financia request seemed very unfavorable Moreover granting EDC benefits to Southern Tr4.1ust also fa4.9ile4.9d to mean6.1in6.1gfully investment and growth in USVI For example in Southern Trust?s award resulted in an actual cost benefit ra tio of of cost for every in benefits The EDC?s grant of tax benefits to Mr Epst ein?s USVI-based companies was contrary to its mission and conferred only palt ry benefits to the residents of USVI The lack of economic sense raises the obvious question of why these benefits continued to be granted to Mr Epstein?s companies a twen5.9ty5.9-year I have reviewed the Motion to Strike Oppos ition filed by JPMC in this case and th5.6e supporting exhibits That filing lays out facts suggesting an im proper quid-pro-quo relationship between Mr Epstein and certain high-placed USVI with nce over the benefits For example First Lady de Jongh received a salary bonuses and tuition payments for her children from Financial Tr ust and Southern Trust Her husband the Governor signed off on United States 6.6Virgin Isl-5.7ands 6.6Econom-8.2ic pment Auth-4.5ority at tab Be4.6nefi4t-.4s tab Be4.6nefi4t-.4s tab at tabs Employm-7.8ent Procurem-7.9ent and JPMC Opposit-9.3ion to to Strike Exhibi-5t EST JPMC Oppositi-5.1o-4.4n to Motion to Strike Exhib-4.3i1.7t JPMC Op-4.3positi-5on to Moti on to Strike Exhibit John Jong-5.3h De-5.3positi-6on Ceci-6le Jongh Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective the benefits In addition Mr Epstein gave oney from Southern Trust to fund USVI Department of Planning and Natural Resources DNPR an agency whose support I understand he needed receive per mits for construction6.1 activ6.1ities He also funneled a donation from S6.8outhern Trust to Ms P6.5l-1.9askett and a donation to the Mapp Potter Inaug6u1ral co6mmittee In my experience as a fraud investigator wh ere benefits granted by public entities on a private individual make no economic sense to the public entity priv ate payments and benefits to key decisionmakers involved in di spersing those benefits raise ques tions with respect to conflicts of interest and as to why the transactions occurr ed at all Here such payments from Mr Epstein could provide a plausible explanation as to hy the EDC continually ex tended more than in benefits to Mr Epstein and his USVI-based companies over a twen ty-year period without proper examination and without a strong economic reason to do so IV Summary of Findings with Respect to Certa5.2i3n USVI?s Expert Opin6.4ions A USVI?s Experts Conclusions Regardi ng Revenue Earned by JPMC from Customers Potentia5.7lly Associated with Mr Epstein Are Contradictory and Not Suppor-6.3t-2.1ed by Appropriate Analysis USVI experts Mr Jonath5.2on Rusch and Mr Amad or each different calcu5.5lations4.7 of the revenue they claim was generated by JPMC from accounts associated with Mr E6.1p.3stein which they e4.8ach cla4.8im pa4.8rtially d6e-.2mo6nstra4.8t-1.2es th significan5.8ce of Mr Epst r4e-.2la4.8tion6s.2hip with JPMC Messrs Rusch and Ama dor both appear to base thei calcu5.1lation on JPMorgan Chase Bank Supplemental Responses and Ob jections to Plaintiff?s Second Set of Interrogatories Response to In terrogatory No Interrogatory Response JPMC?s Interrogatory Response includes exhibits th at show revenue from the Bank?s Private Bank segment among others for It appears that their ions are based on aggregating Cecile Jon-5.2gh De-5.2positi-5.9on You get the tax exempti-5.3ons with out the-5 govern-5o1.6r pers-7.9ona-5lly signing off A Correct JPMC Opposit-9.6ion to Motio-4.6n2 to Strike Exhibi-5.3t JPMC Opposit-9.3ion to to Strike Exhibi-5t EST JPMC Oppositi-5.1o-4.4n to Motion to Strike Exhib-4.8i1.2t Jane Individ-5.5u1.1a-5.5lly of all others simil-5a2.3rly-7.2 situated vs JPMorga-4.7n1.9 Chas-7.6e Bank N.A JPMorga-4.8n1.9 Chas-7.9e Bank Supplem-8.2e-5n1.6tal and Objecti-5.7o-5ns to Plaintiff?s Set of Interrogator-7.7ies,-9.5 May Interrog-5a1.6tory Resp-5ons-7.9e Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective the total amount of revenue for certain Private nk clients albeit it ap pears Messrs Rusch and Amador included different accoun ts and differen5.8t timeframes5 However neither Mr Rusch nor Mr Amador provide any addi tional analysis to support thei opinions that the revenue figures they calculate ar relevant to accounts associated ith Mr Epstein a nd/or that these figures demonstrate the signi ficance of the relationship be tween Mr E6p.2stein and JPMC Mr Rusch claims that JPMorgan derived significant revenue from its d6.1e-.1a5lings with6.1 Epstein It appears Mr Rusch base his claim by aggregating the total revenues generated from each customer listed in Interrogat ory Response for yielding a total of million As such Mr R7.2u.2sch?s analysis indicates that each customer listed on Interrogatory Response is directly linked to JPMC?s relationship with Mr Epstein This supposition is improper and unsupported Indeed Interrogatory Response states that it includes customers that P7.3lain6.1tiff cons5.3iders associa4.9t-1.1ed w8.3ith Je4.9ffr ey E6p.2stein an Epstein-Related Entity or an Epstein-Related Individual and that the inclusion of an account in Interrogatory Response is not a concession by JP6.7MC that the account is actually an acc ount of Mr Epstein associated with him that an E6.6p.8stei n-related individu al or entity Mr Rusch did not provide any support or analysis to demons trates the link between Mr Ep stein and the approximately revenue-generating customers includ ed in Interrogatory Response In addition to Mr Epstein at most of those customers had accounts for which Mr E6.3p.5stei had signature authority or owned Mr Amador appears to support his claims base in part on aggregating the total revenues generated from approximately customers listed in Inte rrogatory Response for Mr Amador?s analysis indicates that JP6.8MC earned5.6 over million in revenue from Mr Epstein and the Epstei n-related Entities from The revenue included in Interrogatory Response does not equal the pr ofit earned or loss incurred by JPMC for any Mr Rusch incl-5.3udes customers fro-4.6m his total of Epstein Entities some which I un-4.9de-4.9rstand the contends not Epstein-R-5.4elate-4.7d1.9 Mr Amador reven-4.7ue gen-5.1eratin-5.1g cus-8t-3.5omers from in to tal of Epstein-4.9 and Epstei-5.6n Entities.-9.9 Expert Opinio-4.6n Rep-4.6o2rt of Jonatha-4.6n Ru June Rusc-7.5h2 Re-4.6port at Rusch Re-4.2port Rusch Re-4.2port Interrogatory 6.6Resp-4.8onse pp Interrogatory 6.6Resp-4.8onse pp Amador Interro9gatory Exhib-4.3i1.7t A Amador Case Document Filed Page of 19879.7Confidential?Su-7bject to Protective given customer As a result Mr Amador?s re venue figure does not in clude any cost JPMC incurs in the normal course of busin5.5ess such as compensation5.5 expense an5.5d other associated with custo5.8m3.6er mainten5.8a4.6nce For ex5.8ample Mr Amador does not consider JPMC?s compensation expense which ranged from to of non-intere st revenue from Thus Mr Amador bases his analysis on revenue figures instead of p6r-1ofit or loss5.2 figu)6res Based on the lack of analysis performed by Me ssrs Rusch and Amador it is unclear what basis they have to conclude that the revenue figures they calculate are relevant to accounts associated w8.1ith Mr Eps5.1t3.7ein or that th5.9ose fi gu5.6res indicate Mr Epstein had a sign5.6i-1.6fican5.6t business relationship with the Bank Mr Amador?s Opin6.5ion Regarding Mr Epstein6.5?-1.7s Account Structure Unsupported Mr asserts in Report that the sheer volume th5.9e bank acco5.9unts identified?have no apparent business justificati on Rather they are used as instruments to shuffle funds to af4filia4.8te4.8d entities and individuals He also states Mr 4.6E1.6pstein maintained and overly complex organizati onal structure involvin multiple e4.6n.8tities To support these assertions Mr Amador focuses on Mr Epstein?s eight JPMC acc ounts and ten separate entities rela4.8ted to Epste4.8i-1.2n?s six personal aircraft He also c4.8ites th6e fa was paying aircraft out of his p5.7e-.5rsonal acco5.7unt However Mr Amador has not only failed to consider the legitima te reasons e.g liability reasons why it would be necessary to maintain this account structure re lated to the aircraft but he has failed to conduct analysis regard5.9ing th5.9e shuffling of funds he asserts was taking First Mr Amador?s descripti on of accounts related to Mr Ep stein?s aircraft only relates to ten of the Epstein-Related accounts he identif ies He also fails to compare Mr Epstein?s account at to any co6.1mparab6.1le en6.1tity ind5.9i-1.3vidual to estab5.9lish th5.9at the sheer JPMorgan Co SEC for the fiscal ye ar end-5.2ed filed on JPMorga-4.4n2.2 Chas-7.3e Co SEC fo the fiscal ye-5ar e-5nde-5d on F-3.3ebruary Amador Amador Amador pp Amador Case Document Filed Page of Confidential bject to Protective Ord-7 Page volume of accounts has no apparent business justification Without such a benchmark Mr Amador 2s 223analysis lacks context and hi opinion is unsupported and ecula4.8 tive Second Mr Amador has not presented any anal ysis of any 223shuffling of funds between the aircraft-related accou5.4 nts or any Mr Epstein5.4 othe4.6 acco5.6 unts He merely ints to the ct that Mr Epstein utilized his pe rsonal JPMC account to pay for some aircraft expenses Mr Amador does not explain why this fact supports opinion that Mr Epst ein 2s account structure was unusual rendering his opinion baseless and speculative Third the4.3 are potential legitim ate reasons why it is not unusual to have separa4.9 te tities hold title to different aircraft For x1 ample for liab6 ility purposes it is best practice and financ5 ial ins5.4 titu6.2 tions and6.2 or insu6.2 ranc5 compan6.2 ies5.4 often ecommend that nership of signif3.9 can5.9 assets be owned by separate legal entities Th is is done not only to pr otect the value of one airc4.7 raf3.9 shou5.9 ld liabilities be genera4.7 ted5.9 from an o6 aircra4.8 ft bu6 also to intain rpor3.9 ate forma4.9 itie4.9 Mr Amador has failed to pres ent any analysis to support his opinions has also failed to consider the nature and scope of Mr Epstein 2s businesses and asset holdings Executed on this 23rd day of June Carlyn Irwin Case Document Filed Page of IRW8.9 A or ers5.5 ea-4 rch th th oor1.7 nge4.2 one4.2 om ACADE-1 UND a nge9.2 and nanc-1.7 a a B4 a ra an2 a ar-2 ar-2 n2 a gani6.3 aude RANG-9.6 NCE or-4 en-9 on ng d2 ex2 p2 ess xpe9.2 ng ng n2 al on an2 d2 acco2 n2 es ont6.3 of-4 ag2 bus8.5 o2 n2 nd ng f7 or7 in5 id5 ty5 o5 p5 as ex2 p2 en of-4 n2 u2 d2 n2 g2 ev2 he h2 en oduc-1.7 nd ona9.2 as or-4 ed nd ough10.8 on ng pha9.3 of-4 on p2 of-4 ony nd ude n2 an2 en2 ough or-4 ng nd ng udi6.3 ng co2 en2 cy2 an2 d2 y2 as p2 p2 n2 v2 o2 x5 il n5 d5 li11 io5 in5 v5 lv5 g5 h5 o5 r1 dul6.3 onve9.2 br-4 unde9.2 pyr6.9 nd r7 ud a ve pr-4 ovi6.3 ng f1 n5 te u2 d2 u2 en2 en2 al sf9 er-2 udul-4.6 nd ppr6.9 opr6.9 of-4 C9 o5 n5 tr1 n5 d5 n2 n2 ss au2 o2 an2 d2 d2 es es an2 d2 p2 n2 br-4 ont6.2 nd ng of go unf7 bus8.6 co2 o2 n2 zed2 co2 en2 y2 d2 es as as u2 y2 an2 on In-7 p2 y2 sp2 es ng opyr6.9 nd ar-2 n2 g2 as sap2 o2 p2 o2 n2 sp2 p2 ex2 p2 se ng nd nc9 ng of-4 on nd as ap-9 st av2 o2 cen2 ee u2 V7 u2 o2 v2 es ng nd o5 th5 g5 in5 o5 of-4 g2 o2 n2 eco2 o2 ss an2 y2 se ip Case Document Filed Page of Appendix A April Top BBox Subtype Header Type Pagination BDC TT0 Tf Tc Tw Tm IRW8.9 or NAL-1 ACCRE-1.1 NS C6 er-2 ed2 b2 o2 u2 n2 C6 n2 o2 ar-2 d2 u2 n2 an2 cy C6 er-2 ed2 n2 n2 C6 can2 n2 u2 ount-4.6 on C4 ud ud ccr-2 ed2 n2 B6 u2 n2 u2 o2 n2 can2 C6 ed2 u2 cco2 u2 ugus-2.3 C9 d5 in5 ty nd on11 C9 n5 n5 f1 if12 d5 u5 ount6.3 nua9.2 NAL-1 AND RY r9 esen12.9 o2 o2 sea2 nge9.2 or sen-9 pa11 o2 seC6.6 o2 o2 ers nge9.2 anag10.9 C4 it12 ll g5 nge9.2 ssi8.3 a2 o2 er v2 B2 nge9.2 ro2 sso2 a2 n2 n2 n2 ce ep2 NY NCE ovi6.2 on ony in-6 d2 o2 wo p2 sat8.3 o2 p5 ms f1 in5 upe9.2 or-4 C4 C4 R4 accu13 acy2 o2 cu2 o2 n2 n2 g2 p2 p2 o2 n2 p2 o2 ees be on und anc9.2 ad11 pos8.6 on opr6.9 on nd r1 r1 r1 f1 in5 d5 r1 C9 o5 r1 o5 v5 d5 n2 y2 ed2 an2 u2 ed2 n2 ag2 es n2 d2 o2 n2 o2 y2 an2 y2 o2 h2 al-3 eg2 ed2 r9 ad2 N4 oup oung anada10.9 ovi6.2 pos8.6 on ony nua9.2 opr6.9 nd of-4 put6.2 our6.9 A5 ude9.2 but6.3 of-4 on en2 ban Case Document Filed Page of Appendix A April Top BBox Subtype Header Type Pagination BDC TT0 Tf Tc Tw Tm IRW8.9 or NY NUE-1 ovi6.2 pos8.6 on pr7 nd ony nd mi11 p5 r1 p5 o5 n5 o5 f1 r1 d5 in5 d5 C9 u5 th5 r1 o5 r1 y5 in5 lu5 d5 b5 u5 p5 d5 n5 in5 lo5 p5 r1 f1 to5 o5 u5 la nd ng f7 unj6.3 a2 ce ech2 o2 o2 esea2 ch2 n2 M1 n5 a5 g5 te pos8.6 on nd r7 p5 r1 p5 o5 n5 d5 p5 d5 n5 d5 C9 o5 u5 o5 th5 r1 n5 tr12 o5 C4 ude d2 n2 aso2 ab2 o2 n2 u2 u2 nr-4 nd oya9.2 nd ng or C4 hnol6.2 XP Po-2 w2 ovi6.2 pos8.6 on ony on u2 g2 so2 n2 on phys8.6 on I7 ope9.2 of-4 on ude9.2 ng xpe9.2 nd ng he o2 n2 ess u2 n2 y2 g2 assu12.9 n2 as on on C4 pos8.6 on put6.3 ng on udi6.3 ng ppr6.9 opr7 of-4 nf-4 nge9.2 on o5 io5 n5 d5 in5 n5 d5 r1 C9 u5 r1 f1 r1 th5 o5 h5 n5 o5 C4 ng oye9.2 ndus8.6 r7 opi6.3 on ude d2 n2 g2 h2 o2 n2 en2 o2 f9 p2 p2 er-2 ng nd nd ng ons C4 C4 C4 C4 al ovi6.2 pos8.6 on ony dur6.9 on pha9.2 a f1 d5 R9 C9 d5 y5 p5 u5 iv5 f1 d5 id5 n5 th5 d5 C9 o5 or-4 nd of hodo10.9 ogy or g2 d2 ag2 o2 n2 a ass d2 b2 asi8.2 u2 n2 g2 d2 a o2 d2 ed2 b2 y2 h2 O5 nd on or-4 bor8.6 ah rem6.7 n2 ovi6.2 pos8.6 on ony on ga tio5 n5 f1 in th5 d5 tr12 o5 u5 r1 n5 f1 n5 n5 lv5 n5 o5 assi8.3 g2 u2 ed2 n2 g2 r9 o2 n2 en2 ss n2 ex2 p2 an2 y2 p2 o2 a acco2 u2 n2 g2 u2 o2 p2 o2 b2 u2 o2 ed2 i ng publ6.2 C6 h2 ra2 a2 C4 pos8.6 on of-4 ont6.2 C4 o2 C6 cu2 ed2 o2 o2 o2 d2 ans8.6 por8.6 Case Document Filed Page of Appendix A April Top BBox Subtype Header Type Pagination BDC TT0 Tf Tc Tw Tm IRW8.9 or NY NUE-1 pos8.6 C4 our-4 of-4 he C4 on gr-4 nd ud r7 ount6.3 ng he on unde-1.6 pa-2 ad C4 und LLC2 P2 ovi6.3 pos8.5 on ony ud ng ng nd mmig15.9 r1 n5 n5 v5 o5 r1 g5 r1 d5 n5 r1 C9 o5 r1 n5 r1 r1 of-4 nd ount6.3 f7 nd opr6.9 and hang10.8 C4 a pos8.6 on nd secr8.9 n2 o2 n2 g2 h2 an2 o2 a ed2 u2 an2 an2 n2 se n2 o2 a ed or-4 C4 ag2 es n2 h2 o2 o2 ar9 k2 v2 u2 h2 u2 a se,2 h2 d2 ev2 o2 o2 h2 d2 an2 ona9.2 C4 oas8.6 ery,2 n2 et ovi6.2 pos8.6 on i ony nua9.2 ud ng o2 cu2 ssu2 n2 ce r9 y2 p2 o2 en2 cy2 an2 d2 p2 er9 g2 a p2 y2 r9 d2 sch2 as o2 a u2 i v5 k5 in5 g5 mp5 n5 y5 f1 d5 in5 h5 n5 u5 C9 o5 C8 fo4 i ng of-4 nd and ange-1.7 C4 on pos8.6 on on ng ons8.6 of-4 qua9.2 nd I7 of-4 C4 R4 ght6.3 C4 of-4 C4 C4 unt6.3 ng of ev2 u2 ed2 b2 y2 an2 d2 p2 o2 o2 h2 o2 n2 an2 d2 Wo2 en2 na-2 ona9.2 an on ovi6.2 pos8.6 on ony nua9.2 on in5 n5 d5 C4 our-4 r7 of-4 ng of-4 on of-4 nha9.2 nd n2 er-2 f9 en2 ce p2 sp2 v2 n2 o2 ad2 v2 n2 y2 ed2 es an2 d2 o2 d2 ed2 eb2 u2 ng pos8.6 xpe9.2 l6 of7 nd n2 rg2 ech2 n2 g2 es ovi6.2 on nua9.2 nvol6.2 of-4 of-4 de secr8.9 an2 d2 co2 n2 acy2 ed2 n2 C6 i C4 ook C4 I7 nd oppo10.9 ng pr-4 nd N4 w4 oup on ng C4 anada10.8 Case Document Filed Page of Appendix A April Top BBox Subtype Header Type Pagination BDC TT0 Tf Tc Tw Tm IRW8.9 or NY NUE-1 ovi6.2 on ove9.2 br-4 th5 ig5 to5 ib5 h5 lm an ade nd o2 n2 ess o2 g2 n2 b2 o2 x2 ce en2 u2 u2 u2 o2 y2 in5 d5 p5 ll p5 r1 o5 in5 g5 y5 r1 r1 in5 g5 n5 g5 ei j6 ng ng LLC2 pos8.6 ugus-2.3 nd of-4 duc9.2 f7 ud he co ounde9.3 ce h2 h2 sel8.3 nd or-4 C4 our6.9 of-4 C4 or-4 C4 of-4 nge9.2 ope unds-2.3 nd unpa-2 a2 vri8.3 a2 a2 i ss on of-4 or-4 or-4 C4 ng r7 ud nd vi-5 on B4 nd on oppos9 ng o2 b2 ser8.9 v2 an2 d2 n2 en2 y2 an2 u2 da-2 on on C4 d5 r1 C9 o5 r1 n5 r1 r1 C9 o5 r1 ia on onne-1.7 nd n5 ite3.4 C9 o5 u5 C9 n5 o5 f1 C9 f1 n5 ia ovi6.2 pos8.6 on ony nvol6.2 ount-4.6 of o5 in5 u2 en2 cy2 en2 o2 n2 o2 ab2 a ed2 n2 n2 ed2 r1 C9 o5 r1 o5 u5 r1 o5 r1 n5 ly5 n5 lu5 d5 n5 n5 f1 er9 y2 g2 y2 se as n2 o2 en2 u2 asso12.9 ed ith h2 es v2 ALL ag C4 C4 poi6.2 nd asso2 ed2 co2 u2 pos8.6 on nd on of-4 ub se nvol6.3 f7 hnol-4.6 gy A7 b2 n2 o2 n2 y2 ed2 h2 co2 n2 co2 eq2 u2 en2 es a v2 o2 ed pr-4 on by on C4 ps ro2 N6 o2 h2 ca2 C6 o2 rp2 o2 ovi6.2 pos8.6 on ony ud nd dut6.3 nkr-4 C4 our6.9 C4 C4 R4 de v2 o2 n2 y2 an2 d2 o2 y2 u2 asse11.2 n2 g2 v2 n2 cy2 an de-2 opm6.2 nd ng ng h2 eb2 co2 v2 an2 R6 u2 o2 n2 y2 d2 ssed12.8 so2 n2 en2 ss u2 ee p2 er-2 ng ogy or-4 ons8.6 i nd of-4 ng ul nd K4 ond C4 hapt6.2 p2 re Case Document Filed Page of Appendix A April Top BBox Subtype Header Type Pagination BDC TT0 Tf Tc Tw Tm IRW8.9 or NY NUE-1 est8.3 i pos8.6 on on on of-4 on on nd C4 of-4 C4 nd d5 th5 b5 ty o2 ag2 n2 g2 ch2 o2 co2 o2 u2 er-2 ce,2 an2 d2 o2 v2 d2 oppos8.5 ng ng on C4 pani-4.6 ll I7 nc and a2 rs ovi6.2 on nvol6.3 of-4 nd upe9.2 C4 our6.9 of C4 pr-4 but6.3 ng xpe9.3 pr-4 nd C4 on oung10.8 ada pos8.6 on nd on of-4 nd ud nd nd but6.2 ng pos8.6 xpe9.2 oup a nd est8.3 ed2 n2 or-4 C4 ny ng ud nd on B4 nd on oppo10.9 ud r7 nd of-4 es or-4 on C4 K4 nnon upe9.2 of-4 ount-4.6 on vel8.3 a2 ro2 yo2 C4 pany-1.6 of C4 C4 de FE2 B2 E2 PS Mem8.3 b2 er9 C6 a y2 o2 C6 b2 o2 n2 ng ect8.3 o2 of-4 C4 ubl6.2 ng nd V7 u2 o2 v2 es o2 on ud Case Document Filed Page of Appendix A April Top BBox Subtype Header Type Pagination BDC TT0 Tf Tc Tw Tm IRW8.9 or TS r7 or-4 onom6.2 of-4 ur7 r7 C4 or-4 nge9.2 of-4 ount6.2 nd or-4 ove9.2 r7 C4 or-4 on nd C4 ng now4.6 he now4.6 oup nua9.2 C6 o2 n2 er9 n2 ch2 o2 su2 n2 ce ass an2 d2 Mo2 er-2 o2 U5 r7 or-4 ng G7 u2 eak1.9 nd RM CE C4 or-4 r7 ng C4 or-4 r7 na9 C4 on C4 or-4 r7 AW-5 ARDS-3.3 RE-1 ho n2 est8.3 o2 n2 oba9.2 I7 ons8.6 CO-4 M2 M2 UNI-3 NG-4 M2 NT o2 C6 eag2 C4 p2 o2 C6 eag2 C4 er nt Case Document Filed Page of Appendix A April Documents and Information Considered Legal Pleadings JPMorgan Chase Co N.A James Edward Staley-5.9 Case No Third-Party Complaint March Government of the United States Virgin Islands JPMorgan Chase Bank N.A Case Second Amended Complaint and Demand for a Jury Trial April Government of the United States Virgin Islands JPMorgan Chase Bank N.A Case JPMorgan Chase Bank N.A 2s Opposit ion to USVI 2s Motion to Strike Affirmative Defenses May and Exhibits Jane Doe Individually and on behalf of all others si milarly situated vs JPMorgan Chase Bank N.A JPMorgan Chase Bank N.A 2s Suppl emental Responses and Objections to Plaintiff 2s Second Set of Interrogatories May Expert Reports Expert Opinion Report of Jonathan Rusch June Expert Report of Jorge Amador June Depositions and Related Exhibits Deposition of Sandra Bess May and Exhibits Deposition of Kenneth Mapp May Deposition of Inais Borque May and Exhibits Deposition of Margarita Benjamin May and Exhibits Deposition of Cecile de Jongh May and Exhibits Deposition of Governor John de Jongh May and Exhibits Deposition of Governor Albert Br yan Jr June and Exhibits Annual Reports Submitted Financial Trust and Southern Trust to EDC Case Document Filed Page of Documents and Information Considered EDC Annual Reports United States Virgin Islands Economic De velopment Authority Annual Report United States Virgin Islands Economic De velopment Authority Annual Report United States Virgin Islands Economic De velopment Authority Annual Report United States Virgin Islands Economic De velopment Authority Annual Report United States Virgin Islands Econom ic Development Authority Annual Report Fiscal Year October to September United States Virgin Islands Economic Development Authority Annual Report Fiscal Year October to September United States Virgin Islands Economic Development Authority Annual Report United States Virgin Islands Economic Development Authority Annual Report October to September United States Virgin Islands Economic Development Authority Annual Report Virgin Islands Economic Developm ent Authority Annual Report October September EDC Cost Benefi4.3 Anal4.3 ses Other Produced Documents ESTATE_JPM014824 Case Document Filed Page of Documents and Information Considered ESTATE_JPM018975 ESTATE_JPM020521 JPM-SDNYLIT-00149653 Public Materials Associated Press Timeline of the Jeffr-13 ey Epstein Ghislaine Maxwell Scandal U.S News World Report June available at https w.usnews.com/news/politi meline-of-the-jeffrey JPMorgan Chase Co SEC Form for the fiscal year ended December filed on February JPMorgan Chase Co SEC Form for the fiscal year ended December filed on February JPMorgan Chase Co SEC Form for the fiscal year ended December filed on February VIC Smart Check Registration Backgrounds Before You Trade CFTC gov5 heck 223Biography Congresswoman Stacey Plaskett U.S House of Representatives available at 223Biography Stacey Plaskett Campaign Plasket for Congress available at 223Biography Governor Albert Bryan Jr U.S Virgin Islands Governm6 ent available at gov4.6 gov4.6 ernor-bry4.6 an 223Statement on Standards for Fo rensic Services No AICPA available at https://w.aicpa.org/resour ces/download/statement 223Tax Incentives How Do They Work United States Virgin Islands Econom6.4 ic Developm6.4 ent Authority available at https://usvieda.org/resident s/grow/edc-tax-incentives/tax incentives-how-do-they-work 223Virgin Islands The World Factbook available at https://w.cia.gov islands Case Document Filed Page of Documents and Information Considered 223Virgin Islands Gov John de Jogh Jr National Governors Association available at Note Even if not included in this list I also considered and relied up on an other documents cited in my report or exhibits Case Document Filed Page of Exhibit Analysis of Economic Development Commission Credits Financial Trust Company Inc Taxes and Duties Paid Gross Receipts-13854.6 Real Property Tax Excise Income Customs Duties Other Total Taxes Value of Tax Exemptions Gross Receipts-9934.6 Real Property Tax Excise Taxes Income Customs Duties Total Value of Exemptions-2218 Federal Tax Return Form Net Ordinary Business Income-4483 Confidential?Subject to Protective Order Page Case Document Filed Page of Exhibit Analysis of Economic Development Commission Credits Southern Trust Company Inc Taxes and Duties Paid Gross Receipts-13854.6 Real Property Tax Excise Taxes Income Customs Duties Other Total Taxes Value of Tax Exemptions Gross Receipts-9934.6 Real Property Tax Excise Taxes Income Customs Duties Total Value of Exemptions-2218 Federal Tax Return Form Net Ordinary Business Income-4483 Source 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3OA QC KC2 IBH IDNB MMII HLH JJG JJG AA6 6WG2.K 8C E7B0n a PBU jNh A Confidential 227Subject to Protective Order Appendix
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