[0:08]We'll go on the record. It is 9.58 a.m. This is a deposition of Mr. Richard Kahn conducted by the House Committee on Oversight and Government Reform under the authority granted to it pursuant to House Rule 10.
[0:25]Accordingly, House Rule 10 grants the committee broad jurisdiction for the committee to conduct investigations of any matter at any time.
[0:33]On January 7, 2026, the committee voted to approve a motion directing the chairman to authorize and issue a subpoena to you for a deposition.
[0:41]On January 23, 2026, Chairman Comer issued a subpoena for Mr. Kahn to appear today for a deposition and furtherance of the committee's investigation into the actions and investigations of Mr. Jeffrey Epstein and Ms. Ghislaine Maxwell.
[0:56]I will enter the subpoena and corresponding cover letter as Exhibit 1.
[1:01]The committee noticed the deposition for Mr. Kahn on March 4, 2026.
[1:06]I will enter the notice for this deposition as Exhibit 2.
[1:10]Can the witness please state his name and spell his last name for the record?
[1:14]Richard Kahn, K-A-H-N.
[1:18]Thank you. My name is Billy Grant and I am the Deputy Chief Counsel for Investigations for Chairman James Comer.
[1:25]Under the Committee on Oversight and Government Reforms rules, you are allowed to have counsel present to advise you during this deposition.
[1:32]Do you have counsel representing you at a personal capacity present with you today?
[1:36]Yes.
[1:37]Will counsel please identify themselves for the record?
[1:40]Daniel Rezumna, R-U-Z-U-M-N-A, on behalf of Richard Kahn.
[1:46]Joshua Berman, B-E-R-M-A-N, on behalf of Mr. Kahn.
[1:51]For the record, starting with the majority staff, can the additional staff members please introduce themselves with their name, title, and affiliation?
[1:58]Jack Emmer, Chief Counsel for Investigations for Chairman Comer.
[2:03]Peter Spector, Deputy Director of Oversight for Chairman Comer.
[2:06]Daniel Ashworth, General Counsel for Chairman Comer.
[2:09]Ryan Giacchetti, Chief Counsel for Chairman Comer.
[2:12]Will Harness, Professional Staff Member for Chairman Comer.
[2:15]Anna Cathy, Revention Staff Member for Chairman Comer.
[2:18]Emily Feierabend, Counsel for Chairman Comer.
[2:21]Ellison Tolan, Counsel for Chairman Comer.
[2:24]Brittany Berdian, Senior Counsel for Chairman Comer.
[2:27]Jack Furlough, Counsel for Chairman Comer.
[2:29]Ashley Benyard, Deputy Staff Director for Chairman Comer.
[2:39]And would the members of Congress please introduce themselves?
[2:41]James Kober, Tupetucket.
[2:44]James Walkinshaw, Virginia.
[2:46]Thank you all.
[2:47]Mr. Kahn, before we begin, I would like to go over the ground rules for this deposition.
[2:52]The questioning will proceed in rounds.
[2:54]The majority will ask questions for an hour,
[2:56]and then the minority will have an opportunity to ask questions for an hour if they choose.
[3:00]To the extent members have questions for the witness,
[3:03]they will be propounded during their size respective rounds.
[3:06]The clock will stop if you need to confer with counsel,
[3:09]your counsel is speaking,
[3:10]and when members or staff are speaking during the opposing side's round of questions.
[3:14]We will alternate back and forth until there are no more questions.
[3:17]Do you understand?
[3:18]Yes.
[3:19]There is a court reporter taking down everything I say and everything you say
[3:23]to make a written record of the deposition.
[3:25]For the record to be clear,
[3:27]please wait until the staffer questioning you
[3:29]finishes each question before you begin your answer,
[3:32]and the staffer will wait until you finish your response
[3:34]before proceeding to the next question.
[3:36]Further, to ensure the court reporter can properly record this deposition,
[3:40]please speak clearly, concisely, and slowly.
[3:43]Also, the court reporter cannot record non-verbal answers,
[3:46]such as nodding or shaking your head,
[3:48]so it is important that you answer each question with an audible verbal answer.
[3:52]Do you understand?
[3:53]Yes.
[3:55]Exhibits may be entered into the record.
[3:57]Majority exhibits will be identified numerically.
[3:59]Minority exhibits will be identified alphabetically.
[4:02]Do you understand?
[4:03]Yes.
[4:05]We want you to answer our questions in the most complete and truthful manner possible,
[4:09]so we will take our time.
[4:11]If you have any questions or do not fully understand the question,
[4:14]please let us know.
[4:15]We will attempt to clarify, add context to, or rephrase our questions.
[4:20]If we ask about specific conversations or events in the past,
[4:23]and you are unable to recall the exact words or details,
[4:26]you should testify to the substance of those conversations or events,
[4:29]to the best of your recollection.
[4:31]If you recall only a part of a conversation or event,
[4:34]you should give us your best recollection of those events
[4:36]or parts of conversations that you do recall.
[4:39]Do you understand?
[4:40]Yes.
[4:42]You are required by law to answer questions from Congress truthfully.
[4:45]This also applies to questions posed by congressional staff in this deposition.
[4:49]Do you understand?
[4:50]Yes.
[4:52]If at any time you knowingly make false statements,
[4:54]you could be subject to criminal prosecution,
[4:56]including but not limited to perjury.
[4:58]Do you understand?
[4:59]Yes.
[5:01]This includes both knowingly providing false testimony,
[5:03]but also stating that you do not recall or remember something
[5:06]when in fact you do.
[5:07]Do you understand?
[5:08]Yes.
[5:10]Furthermore, you cannot tell half-truths
[5:12]or exclude information necessary to make statements accurate.
[5:15]You are required to provide all information
[5:18]that would make your response truthful.
[5:20]A deliberate failure to disclose information
[5:22]can constitute a false statement.
[5:24]Do you understand?
[5:25]Yes.
[5:26]Is there any reason you are unable to provide
[5:28]truthful testimony in today's deposition?
[5:30]No.
[5:32]Please note that if you wish to assert a privilege
[5:34]over any statement today,
[5:36]the assertion must comply with the rules of the Committee
[5:38]on Oversight and Government Reform.
[5:40]Pursuant to that, Committee Rule 16C1 states,
[5:57]For the purposes of the deposition,
[5:59]objections must be stated concisely
[6:01]and in a non-argumentative and non-suggestive manner.
[6:04]If the witness refuses to answer a question
[6:06]to preserve a privilege,
[6:07]the Committee may seek a ruling from the Chair.
[6:09]If the Chair overrules any such objection,
[6:12]the witness shall be ordered to answer.
[6:14]If the witness continues to refuse to answer a question,
[6:16]despite being ordered to do so,
[6:18]the witness may be subject to sanction.
[6:20]Do you understand?
[6:21]Yes.
[6:23]Ordinarily, we take a five-minute break
[6:25]at the end of each hour of questioning,
[6:27]but if you need a longer break or a break before that,
[6:29]please let us know and we'll be happy to accommodate.
[6:32]However, to the extent that there is a pending question,
[6:35]we would ask that you finish answering the question
[6:37]before we take the break.
[6:38]Do you understand?
[6:39]Yes.
[6:42]Finally, I will note for everyone here today
[6:44]that the content of what we discuss in the deposition today
[6:47]is confidential under the House deposition regulation.
[6:50]Under the rules,
[6:51]the Chairman and Ranking Minority Member shall consult
[6:53]before any release of testimony or transcripts,
[6:56]including portions thereof.
[6:58]This means it is a violation of House and Committee rules
[7:01]to disclose content of the deposition
[7:03]prior to its official release.
[7:05]For this reason,
[7:06]the marked exhibits that we will use today
[7:08]will remain with the court reporter
[7:10]so that they can go into the official transcript,
[7:12]and any copies of those exhibits will be kept at the table
[7:15]or returned to us when we wrap up.
[7:17]Can the reporter please swear in the witness?
[7:19]Yes, sir.
[7:20]Sir, will you please raise your right hand?
[7:22]Can you solemnly declare and affirm,
[7:24]under the ability of perjury,
[7:26]that the testimony you will give today will be the truth,
[7:28]the whole truth and nothing but the truth?
[7:30]Yes, I do.
[7:31]Thank you.
[7:32]Thank you.
[7:33]Do you have any other questions before we begin?
[7:35]No.
[7:37]Mr. Cahn would like to make a statement before we begin.
[7:39]It's an opening statement.
[7:40]I'll give a copy to the court reporter as well.
[7:45]We'll mark this statement as Exhibit 3.
[7:50]I would like to thank the Committee
[7:52]for the opportunity to testify
[7:54]and thereby try to set the record straight
[7:56]on a number of important points.
[7:59]Because I expect the Committee has many questions,
[8:02]I will keep this statement brief.
[8:05]First, in the years that I provided outside accounting
[8:09]and bookkeeping services for Jeffrey Epstein,
[8:12]I was not aware of the terrible and unforgivable things
[8:16]that he did to women and girls.
[8:19]My relationship with Epstein
[8:21]was strictly on a professional level.
[8:24]We did not interact socially,
[8:26]and I never attended any of his parties
[8:28]or his social functions.
[8:31]While Epstein was alive,
[8:33]I never observed any sexual abuse or trafficking of women
[8:37]and never received a complaint,
[8:39]either by one of Epstein's victims
[8:42]or anyone else, of such abuse or trafficking.
[8:46]Epstein told me that his 2006 arrest was a mistake,
[8:51]that he did not know the woman was underage,
[8:54]and that nothing like that would happen again.
[8:57]I believed him at the time
[8:59]and never saw what appeared to be a minor in his presence.
[9:03]Had I learned of any of his horrific behavior,
[9:06]I would have quit work immediately.
[9:09]Second, in the work that I performed
[9:12]on behalf of Epstein or his companies,
[9:15]I did not see anything that suggested to me
[9:18]that Epstein was abusing or trafficking women
[9:21]or otherwise acting unlawfully.
[9:24]I worked with other accountants and bookkeepers
[9:27]to track spending on Epstein's properties and other assets,
[9:32]and in the few years before Epstein's death,
[9:34]I also tracked his investments.
[9:37]With homes in the Virgin Islands, New York,
[9:39]Palm Beach, Paris, and New Mexico,
[9:42]and with several planes and a helicopter,
[9:44]Epstein had substantial yearly expenditures
[9:47]and a large staff.
[9:50]We tracked the expenditures as meticulously as possible,
[9:53]including gifts by Epstein to women and men.
[9:58]The gifts represent a very small fraction of Epstein's spending.
[10:02]I did not see them as red flags for abuse or trafficking.
[10:06]Third, some media sources have reported
[10:10]that Epstein used corporate structures and cash
[10:13]to conceal his identity
[10:15]and hide his sexual abuse and trafficking.
[10:18]Based on my experience and conversations
[10:21]with financial officers for family offices,
[10:24]the use of limited liability companies
[10:27]by wealthy individuals to hold assets
[10:30]such as real estate or major assets
[10:33]like airplanes and helicopters
[10:36]is completely standard practice.
[10:39]I had no role in setting up any of Epstein's companies,
[10:43]but did not view them as improper or suspicious.
[10:47]Like all expenditures,
[10:49]we tried to closely track the use of cash
[10:52]at Epstein's properties,
[10:54]and where backup was missing,
[10:56]we treated cash and other expenditures
[10:59]as gifts by Epstein and reported them,
[11:02]when appropriate, on Epstein's gift tax returns.
[11:06]Finally, I agreed to serve as co-executor
[11:09]of Epstein's estate.
[11:11]By the time of Epstein's death,
[11:13]I had learned of the harm
[11:15]that he had caused to so many women
[11:19]and thought that my knowledge of Epstein's holdings
[11:22]would make me better prepared
[11:24]to alleviate some of their suffering.
[11:27]One of the first things my co-executor and I did
[11:30]was set up the Epstein Victims Compensation Fund,
[11:34]which resolved claims by over 130 women
[11:37]in a confidential manner
[11:39]without limits as to their recovery
[11:41]and without any decision-making by the estate.
[11:44]We also settled nearly 60 claims by Epstein's victims.
[11:49]I have done my best to balance my obligations
[11:52]as a fiduciary of the estate
[11:54]with the interest in providing legitimate compensation
[11:57]to Epstein's victims.
[11:59]For this work, I have been the subject of attacks
[12:02]by plaintiff's lawyers
[12:04]and have had my reputation dragged through the mud.
[12:07]It has taken a tremendous toll on me and my family,
[12:11]but I continue to serve as co-executor
[12:13]because I believe it is the right thing to do.
[12:16]I was not aware of the nature
[12:18]or extent of Epstein's abuse of so many women
[12:21]until after Epstein's death.
[12:23]However, it pains me to think,
[12:25]and I deeply regret,
[12:27]that I may have unknowingly assisted Epstein in any way.
[12:31]Thank you.
[12:32]Thank you.
[12:33]Before we begin,
[12:34]will the additional members of Congress who joined us
[12:36]please identify themselves for the record?
[12:38]I'm Representative C. Ross DeBorogh of the Bridges.
[12:42]We're all TANF from California 17.
[12:45]And for the additional person that just walked in,
[12:48]will you please identify yourself for the record?
[12:50]Thank you.
[12:54]The clock reads 10, 11 a.m.
[12:57]and the majority's time will begin now.
[12:59]Mr. Kahn, thank you for appearing here today.
[13:02]I'm going to get started
[13:04]with just some brief background information on you.
[13:07]Can you tell us where you went to college?
[13:10]I went to Syracuse University.
[13:12]And what degree did you graduate with?
[13:14]An accounting degree.
[13:15]Did you, after graduating from Syracuse,
[13:19]did you obtain any other professional degrees
[13:23]or licensures or anything like that?
[13:25]I later obtained a master's degree in taxation
[13:29]from Pace University.
[13:30]And what year was that?
[13:32]I don't recall the exact year.
[13:34]Maybe late 90s, 99.
[13:36]And after these degrees,
[13:40]can we briefly go through your professional career
[13:43]prior to you joining,
[13:45]prior to you starting employment with Mr. Epstein?
[13:48]Yes.
[13:49]Can you just walk through that for us, please?
[13:51]Certainly.
[13:53]After college, I worked for three public accounting firms.
[13:57]The first firm was Cooper's and Liebrand,
[14:01]which at the time, I believe, was a big four accounting firm.
[14:05]The next firm I worked for was Richard Eisner & Company,
[14:08]a mid-sized firm.
[14:10]And then I worked for a small firm called KNHN.
[14:19]And when did you join,
[14:21]or when did you first become employed with Mr. Epstein?
[14:25]I interviewed for a job with Epstein in October of 2005.
[14:30]And when did you first meet Mr. Epstein?
[14:37]I met him in October of 2005.
[14:40]I don't recall the date,
[14:42]and I believe I started employment about two weeks later.
[14:46]And when you first met him,
[14:48]can you explain where that was and what you were doing?
[14:53]Yes.
[14:54]I was at the time,
[14:57]I had reached out to recruiting firms
[14:59]looking for an accounting or a CFO job.
[15:02]And I believe I was looking at the Times
[15:05]and came across a recruiter
[15:07]who advertised for a job as an accountant bookkeeper.
[15:12]And I did not know when he said to me
[15:16]that I was going to have an interview, who it was.
[15:19]And I found out about 30 minutes before the interview
[15:22]that I was going to be interviewing with Jeffrey Epstein.
[15:25]And my first interview with Epstein was at his townhouse.
[15:32]I don't recall the date or the time,
[15:34]but it's sometime in October 2005.
[15:37]And what did you discuss during that interview?
[15:41]I don't recall the exact conversation.
[15:43]I believe the interview lasted about 10 minutes
[15:47]with Epstein asking me questions about my previous employment.
[15:52]Did you know anything about Mr. Epstein
[15:57]prior to that interview with him?
[16:00]I believe in the 30 minutes before the interview,
[16:06]I saw that there was one article about him.
[16:09]I think it was the International Man of Mystery article.
[16:14]Was anyone else present during your interview with Mr. Epstein?
[16:21]Not that I recall.
[16:22]Did anyone greet you at the door
[16:25]when you walked in for your interview with Mr. Epstein?
[16:28]It certainly wasn't him, so someone must have,
[16:30]but I don't recall who that was.
[16:32]What were your first impressions of Mr. Epstein?
[16:47]It was a very quick interview.
[16:49]I didn't really have much impressions.
[16:52]I was used to longer interviews, so it was very brief,
[16:58]and I had a tough time knowing after the interview
[17:01]if it was someone that was interested in hiring me or not,
[17:06]so it was unknown of what was going to take place going forward.
[17:12]And who informed you that you were officially hired for the job?
[17:16]I believe the recruiter reached out to me.
[17:22]What did you understand Mr. Epstein's job to be
[17:25]at the time that you started working with him?
[17:29]I understood that he was providing financial,
[17:33]tax and estate planning to clients.
[17:36]Did you know anything about Mr. Epstein's background
[17:48]when you first started working with him,
[17:50]as in his past of where he had previously worked,
[17:55]where he went to school, things like that?
[17:58]I believe I knew that, and I don't know,
[18:05]maybe it was from the coworkers that told me
[18:07]that he worked at Bear Stearns previously.
[18:11]I also understand that he did not finish his college education.
[18:19]And at the time of your first beginning employment with Mr. Epstein,
[18:27]did you already understand him,
[18:29]Mr. Epstein, to be a wealthy individual?
[18:33]I knew he was a wealthy individual from at least some of the assets
[18:37]he had, homes, planes.
[18:40]But at the time I began working for Epstein,
[18:43]I was pretty much focused on bookkeeping and dealing with his
[18:47]insurance and investments outside of stocks and bonds.
[18:52]So at that point in time I was not preparing asset summaries for him
[18:57]and was unaware of his net worth or the value of his brokerage accounts.
[19:03]And you mentioned handling his investments outside of stocks and bonds.
[19:07]What sort of investments would those be?
[19:09]If Epstein wanted to invest in a newspaper or a magazine,
[19:15]if he wanted to invest in a private company,
[19:17]I would usually be the point person to maybe look at the financial
[19:22]statements before he made the investment
[19:24]or while he was holding the investment to monitor the investment on his behalf.
[19:30]And did Mr. Epstein ever invest in any newspapers or publications?
[19:38]I believe that Epstein invested with Mort Zuckerman in Radar magazine.
[19:48]Any other publications?
[19:54]There was another investment, which I don't recall if it was Epstein
[20:00]or one of his clients, but a company by the name of Seed Media Group.
[20:07]And what did Seed Media Group do to your understanding?
[20:12]I believe it originally was doing scientific analytics
[20:18]and then maybe pivoted into a magazine.
[20:22]I don't recall the specifics, but that is my general understanding.
[20:31]During your time working with Mr. Epstein,
[20:35]did you develop a personal relationship with him outside of work?
[20:39]Mr. Epstein and I never socialized.
[20:42]I did not have a personal relationship with Epstein.
[20:46]And my dealings with Epstein were quite infrequent.
[20:50]I would typically meet with him about every three weeks
[20:54]or anywhere from 30 to 90 minutes.
[20:58]And our conversations were 90% regarding the questions I brought in
[21:05]and was looking to get answered regarding his accounting and financial situation.
[21:11]Did you ever at any point consider Mr. Epstein to be a friend of yours?
[21:21]No.
[21:32]And you mentioned that you would meet on approximately three weeks or so
[21:38]cadence in person outside of those physical face-to-face meetings.
[21:44]How often would you otherwise communicate with Mr. Epstein?
[21:48]I would say that 80% of my communication with Epstein was on email.
[21:54]And the remaining was phone calls.
[22:01]I could probably count on one hand the amount of times I called Epstein.
[22:04]It was always him calling me.
[22:08]And that was the extent when he would call me on the phone, email, and then in-person meetings.
[22:15]And the in-person meetings, where would those most frequently occur?
[22:25]After 2010. I began in 2005.
[22:29]The in-person meetings were always at his townhouse in New York.
[22:39]And you specifically broke out a portion of time after 2010,
[22:43]prior to 2010, where would a majority of those meetings take place?
[22:48]Well, I began work in 2005.
[22:51]And I believe that Epstein was incarcerated in, I believe, June of 2008.
[22:58]So for the period of time, 2005 to 2008, those meetings were at our office at 457 Madison Avenue.
[23:17]Did the nature of your relationship with Mr. Epstein ever change over the course of your years of employment with him?
[23:24]My relationship with him was always strictly professional.
[23:27]We never had a personal relationship or socialized.
[23:32]So I don't believe it changed at all.
[23:36]And how long did you work for Mr. Epstein?
[23:38]I worked from October 2005 through the date that Epstein was incarcerated.
[23:47]And then I continued to serve as co-executive.
[23:53]And when did you officially become co-executive of Mr. Epstein's estate?
[23:57]I believe that occurred in August 2019.
[24:03]So sometime shortly after his death?
[24:07]Yes.
[24:11]When was the last time you communicated with Mr. Epstein prior to his death?
[24:15]I believe that Epstein was in Paris prior to him flying back and being arrested in New Jersey on July 6.
[24:27]I believe I spoke with him probably or communicated via email or phone in the three or four days prior to his arrest.
[24:48]Do you know why Mr. Epstein was in Paris at that time?
[24:50]No.
[24:51]And at the time of that last discussion, what were the two of you discussing?
[24:59]I recall this from seeing recent media reports, but we were discussing his pursuit of a property in Morocco.
[25:13]And what about that pursuit of the property in Morocco?
[25:19]Epstein was looking to purchase a property in Morocco and was giving me instructions on what amount of money to wire to his real estate representative based on what I believe was a purchase of a home in Morocco.
[25:37]And did you ever visit Mr. Epstein while he was incarcerated after his arrest in July of 2019?
[25:46]I never visited Epstein in 2019 or 2008.
[25:51]When was the last time you saw Mr. Epstein in person?
[26:00]I don't recall a specific date. My presumption would be within two or three weeks of his arrest, but I can't specify a date.
[26:12]And understanding you can't specify a date, do you know why you met with Mr. Epstein in person at that time?
[26:32]My meetings with Epstein were, as I said earlier, usually every three weeks.
[26:39]And I was handling a lot of things on behalf of Epstein at the time.
[26:46]So I typically would come into a meeting with a list of 30 to 50 questions looking to get answers.
[26:54]So the purpose of almost every one of my meetings was to try to work down my list and get answers to things that I was working on.
[27:03]And those 30 to 50 questions you would often ask, what types of questions would you be asking at that time?
[27:14]If an employee was looking for a raise and they came to me, I was going to ask if he was interested in giving a raise, if he was doing construction at a property,
[27:25]and the contractor was looking for payments for the agreements, I wanted to make sure he was comfortable with the work in place.
[27:33]If I was renewing his aviation insurance policy, I wanted to let him know what the premiums were for the next period of time.
[27:41]Those were some examples.
[27:46]Would some of these questions involve disbursements of payments to or from entities of Mr. Epstein's to various employees as well?
[27:59]I'm not sure I understand what your question is.
[28:02]As part of these 30 to 50 questions that you would ask Mr. Epstein, you mentioned that you would talk about raises or construction projects and their payments, insurance policies, and renewing them.
[28:12]Would you also discuss any type of payments that you would okay to go from one of the entities of Mr. Epstein to individuals on the payroll?
[28:23]Well, if the individual was on a payroll, the payment would be the same every week unless that person was asking for a raise.
[28:33]If you're asking if Epstein wanted to wire money to an individual that maybe wasn't on the payroll, those were never questions that I initiated or asked.
[28:44]Those were usually directives I received from Epstein.
[28:47]Understood. Did you have any knowledge or suspicion that prior to August of 2019 you would become co-executor of Mr. Epstein's statement?
[29:03]Not that I recall. There were earlier documents I believe that I was in, but I don't recall that I would be the name co-executor when he changed his documents a few days before his death.
[29:22]And did you subsequently review any documents that would have indicated when this decision would have been made to name you as co-executor?
[29:30]I believe that after Epstein's death, I was asked if I would take on the role as co-executor and co-trustee, and I thought about it for a little period of time, and I believe I signed the documents maybe 10 to 15 days after his death.
[29:52]And were you surprised that you were named to be a co-executor of his estate?
[29:57]No, I wasn't surprised.
[29:59]And why were you not surprised?
[30:01]I wasn't surprised because I thought performing accounting and bookkeeping services on behalf of Epstein, I would be best suited to know his assets.
[30:13]And, sorry to jump around in the timeline here, but in 2005 Mr. Epstein was, the investigation into Mr. Epstein in Florida began. I know you started your employment with Mr. Epstein in 2005. Prior to his arrest in 2006, were you aware of any investigations into Mr. Epstein?
[30:40]I was not aware of any investigations, nor was I aware of the fact that Epstein was arrested. I found out about Epstein's legal problems when we had a discussion in 2008.
[30:53]And who was part of that discussion in 2008?
[30:58]The discussion was Epstein and myself.
[31:01]And what did you discuss?
[31:09]Epstein said he wanted to talk with me and mentioned that he was having legal problems in Florida.
[31:16]And he mentioned that he was with a woman that turned out to be a minor and that he was going to be charged with soliciting a minor for prostitution.
[31:27]Epstein then told me that it was a mistake that he was with this minor and that it would never happen again.
[31:34]Where did this conversation occur?
[31:37]I don't recall where it occurred. That's the conversation that I recall.
[31:42]Do you recall if it was in person or over a phone or anything like that?
[31:46]I don't recall.
[31:49]And when Mr. Epstein informed you of his legal problems and that he had been with a minor, were you surprised by that fact?
[31:59]Yeah, I was surprised. I'd just been working for this man for a few years.
[32:06]So it was shocking to me and it was quite upsetting.
[32:11]I know at the time that the crime was very serious.
[32:16]However, his sentence was rather light.
[32:18]I believe he served 13 months, which he was allowed to leave the county jail six days a week for 12 hours a day.
[32:27]So I didn't fully grasp at the time, nor was I aware of the depth of what actually took place that I later learned as co-executor.
[32:38]But at the time, I unfortunately and regrettably trusted Epstein that this would never happen again.
[32:44]And I decided to stay working for him.
[32:47]And did Mr. Epstein inform you of the interaction he had with this minor woman at that time?
[32:56]The only thing he told me was he was mistakenly with a minor and that he would never be with a minor again.
[33:04]That was a mistake on his part.
[33:09]But no specifics about what he was doing with this minor?
[33:14]No.
[33:19]Did you discuss Mr. Epstein's legal problems with anyone else at that time?
[33:31]I don't recall having any other substantive conversations with anyone else.
[33:35]And I don't believe I knew much more than what Epstein told me.
[33:55]You didn't discuss his legal issues with anyone else that you worked with?
[33:59]I think everyone was alarmed and scared that their employer was arrested.
[34:05]But there may have been some office chatter, but I can't recall the specific conversation.
[34:10]And did you discuss how his legal problems and subsequent incarceration would affect his financial accounting?
[34:20]Well, at the time, Epstein wanted to continue to employ everyone.
[34:26]He didn't want to fire people.
[34:30]And I know at the time everyone that continued working for him received a pay cut of, I believe, 10 percent.
[34:38]And that was what I recall from the time period.
[34:46]And additionally, that because Epstein was incarcerated, the amount of work that we all had had diminished probably by about 30 or 40 percent.
[34:56]And so outside of the 10 percent pay cut that employees faced, what other financial operations were changed during this time period of his incarceration in 2008?
[35:11]Well, I would say a lot of the transactions and work that would occur was when Epstein moved from property to property.
[35:23]So, for example, if Epstein was in New York and heading down to the U.S. Virgin Islands to his islands, the property managers would want to make sure that the house was meticulous and that the landscaping was perfect.
[35:36]And there was food in the refrigerator and they were able to accommodate Epstein and whoever he was traveling with.
[35:46]There was a lot of work done in anticipation of Epstein moving from home to home, which would lead to more expenses and me having more interactions with the household staff if they needed an increase on their credit line or they needed cash to pay for bills or get things ready or purchase flowers.
[36:04]So in that regard, because he wasn't moving around from property to property, you know, the amount and volume of transactions and work was diminished.
[36:14]And did you receive a pay cut during this time?
[36:19]Yes.
[36:20]10 percent?
[36:21]Yes. Every employee did.
[36:23]And what was your pay at this time?
[36:25]I believe my salary was $180,000 or somewhere in the $180,000 range. It could have been $185,000 or $190,000. I believe my starting salary was $180,000.
[36:38]And I think you briefly touched on this, but after learning of Mr. Epstein's legal troubles, you of course ultimately decided to continue your employment with Mr. Epstein.
[36:59]Did you ever consider leaving or discuss leaving your employment?
[37:03]Yes, 100 percent. I apologize for not alluding to that earlier.
[37:08]I without a doubt questioned leaving him.
[37:11]And in hindsight, I regret that I relied on Epstein's word that this would never happen again.
[37:18]And I believe at the time we were in the middle of a financial crisis and I had a family to support.
[37:24]So I made the wrong decision in staying for him, staying working for him because I later learned as co-executor that Epstein continued to abuse hundreds of minors and adults.
[37:36]So I made an improper decision.
[37:39]And you briefly, I think, touched on this.
[37:49]Before obviously knowing that you started in 2005 and before Mr. Epstein formally came to you with his legal troubles in 2008, did you suspect that he was ever trafficking women, sex trafficking women or abusing women or girls in any way?
[38:06]No, I never suspected any of that.
[38:08]Did anyone in Mr. Epstein's orbit ever express concern to you about Mr. Epstein and his dealings with women before his 2008 conviction?
[38:28]Before his 2008 conviction, I never saw minors in the presence of Epstein.
[38:34]I saw him on my visits every three weeks when Epstein was in town.
[38:38]Occasionally I saw assistants, but I never saw anything that looked improper.
[38:44]In addition, no woman has ever come to me and said that she was in danger, that she was being sexually abused or sexually trafficked.
[38:53]And just so that the record is clear, saw no minors, no women outside of, or I'm sorry, no minors or girls present with Mr. Epstein at any time?
[39:21]No, I'm not saying that I never saw minors.
[39:25]I'm saying, I never saw minors in Epstein's presence.
[39:30]Period, correct, yes, that's what I'm saying.
[39:33]What I'm saying is that occasionally when Epstein was in the office, I did see his assistants and no one ever approached me, communicated with me, and said that they were in danger or that they were being sexually abused or trafficked by Epstein.
[39:49]Is it fair to say the assistants were adult females?
[39:52]Correct, yes.
[39:54]When did you become aware that Mr. Epstein had to register as a sex offender following his arrest and incarceration in 2008?
[40:07]I believe I became aware, I assume, after, I guess after he was to be released from jail.
[40:19]And who did you learn that from?
[40:26]I learned that from his attorney Darren Endyke.
[40:30]And the context of how I learned that was that as a registered sex offender, he was required to make a list of all of his phone numbers, I believe all of his transportation, his planes, his cars, and I believe a list of his properties as well.
[40:56]So at times Darren Endyke would ask me questions about his properties or phone numbers or his aviation or cars.
[41:09]What sorts of questions regarding the phone numbers, cars, properties, and aviation vehicles would you be answering or providing?
[41:25]I believe there was a base list that Mr. Endyke had.
[41:29]And if Epstein had purchased a new car, I assume it would have to be added to the list.
[41:34]So he might say to me, you know, has Epstein sold or purchased any cars in the last, you know, I don't know the period that he was reporting.
[41:43]So those were the questions I would be asked.
[41:45]When did you first meet Ghislaine Maxwell?
[41:55]I met Maxwell probably within the first, I'd say, two months of working for Epstein.
[42:03]And what was the context of that first meeting?
[42:08]I don't recall the context of the first meeting.
[42:12]I believe I was probably introduced to her and that was the extent of my first meeting with her.
[42:20]Introduced to Ms. Maxwell by whom?
[42:23]I don't recall.
[42:27]Do you know where this meeting with Ms. Maxwell took place?
[42:30]It would have had to take place at the office because that's where I was every day.
[42:34]And what did you discuss with Ms. Maxwell in your first meeting?
[42:48]As I said before, I don't recall the conversation.
[42:51]But my dealings with Maxwell when she was working in Epstein's office were predominantly regarding she was a signatory on Epstein's accounts.
[43:04]And I would receive from Epstein's properties stacks of invoices of which I would review.
[43:14]And after I reviewed them, I would either bring them to her if she was at her desk or leave them on her desk for her to sign the checks and review them as well.
[43:25]Were you surprised that Ms. Maxwell was a signatory on accounts?
[43:32]I knew Maxwell to be the equivalent of Epstein's chief of staff.
[43:41]I was explained that she was number two to Epstein, so no, I wasn't surprised.
[43:47]And at the time of your first interactions with Ms. Maxwell, what was your understanding of what she did for a living outside of performing a chief of staff-like duty as you just explained?
[44:07]My understanding was that she had signatory authority, so she reviewed bills.
[44:13]And when I used the word chief of staff, I mean that she would travel with Epstein.
[44:19]She would interact with the property managers and the staff to make sure that the properties were the way Epstein wanted the properties to be.
[44:29]And that she on occasion traveled with Epstein as well.
[44:35]And throughout your relationship or employment with Mr. Epstein and working with Ms. Maxwell, did her role as sort of a chief of staff or a number two to Mr. Epstein, did that ever change?
[44:54]Yeah, I believe that she was no longer involved in Epstein's day-to-day operations sometime in, I want to say, the 2009 to 2010 range.
[45:08]Do you know why her role changed in that 2009 to 2010 range?
[45:19]I was never informed why her role changed, no.
[45:23]Were you surprised that Ms. Maxwell was no longer handling day-to-day things for Mr. Epstein anymore?
[45:32]It's not something that I really thought about.
[45:34]A person you would review invoices for and provide them to for final sign-off, you didn't think about why she was leaving her role or her involvement in the day-to-day of Mr. Epstein?
[45:54]I don't know why she left her role in the day-to-day.
[45:57]What I can tell you though is when Epstein was incarcerated, Maxwell had asked if I could help her with some of her finances.
[46:05]And I helped her organize her finances, sometimes during my working day and sometimes after work.
[46:15]I helped her organize her assets, her investments, her brokerage accounts, her cash, her insurances, her payroll.
[46:25]And I did that for a period of time.
[46:28]And after a period of time of doing that work, I was not paid by her and I felt like my work was not appreciated.
[46:37]So I told Epstein that I no longer want to do work for Maxwell.
[46:42]And he said, great, don't do work for Maxwell.
[46:44]I mean, that was the end of my dealing with Maxwell.
[46:53]Did you ever have the impression that Ms. Maxwell and Mr. Epstein had a romantic relationship with each other?
[47:01]I was never aware of Epstein's romantic relationships.
[47:04]But there was, let's say, office chatter or people said that at one point in time they did have a romantic relationship.
[47:10]But I can't say I know that with confidence.
[47:13]Do you recall who would have been engaging in this office chatter talking about their relationship?
[47:18]Could have been any of the six to ten employees that were in the office. I don't know.
[47:22]And how would you characterize your relationship with Ms. Maxwell?
[47:27]Our relationship was cordial.
[47:32]But as I said just previously, at the period of time where Epstein was incarcerated and I was doing work for Maxwell,
[47:41]working very hard and not being paid, I felt my work was underappreciated.
[47:45]So I had no desire to deal with her at that point in time anymore.
[47:51]Would you consider Ms. Maxwell a friend?
[47:53]No.
[47:55]Would you consider yourselves close?
[47:57]No.
[48:00]How often would you, knowing that after you provided services to Ms. Maxwell and then no longer wanted to provide those services, prior to that, how often would you see Ms. Maxwell?
[48:13]Prior to that?
[48:14]Yeah.
[48:15]I'd see probably Maxwell at the same cadence I saw Epstein.
[48:23]You know, I might see her every two or three weeks.
[48:26]I don't recall specifically, but it was not often.
[48:29]And outside of face-to-face interactions, how frequent would you communicate with Ms. Maxwell?
[48:40]Not frequently at all.
[48:42]If you did communicate with her, what would you use to communicate with her? Phone, email, text message, etc.?
[48:49]Similar to Epstein, I rarely ever called Maxwell. It would either be email or in-person meeting.
[48:57]Did Ghislaine Maxwell ever try to introduce you to any woman or girls during her time in Ms. Epstein's orbit?
[49:12]No.
[49:16]Did Ms. Maxwell ever ask you to introduce her to any women or girls in your orbit?
[49:21]No.
[49:22]When – let me go back. So you provided some financial services to Ms. Maxwell in the 2009-2010 timeframe, you said.
[49:40]And after you felt that your work wasn't valued, you no longer wanted to work with her.
[49:46]Is that when your relationship, professional or otherwise, ended with Ms. Maxwell?
[49:54]I believe that is correct. After that, there may have been an email here or there, but I was no longer providing services, nor did I feel the need to communicate with her at all.
[50:07]And when was the last time you communicated with Ms. Maxwell?
[50:16]I don't recall. Probably sometime in the 2010 range. I don't recall any substantive emails or conversations thereafter.
[50:26]Prior to Ms. Maxwell leaving Ms. Epstein's orbit in the 2009-2010 timeframe, was Ms. Maxwell heavily involved in Ms. Epstein's business dealings?
[50:44]When you say the word business, do you mean financial stocks and bonds, or do you mean his properties and caretakers?
[50:53]Let's start with the first one. Stocks, bonds, investments, et cetera.
[50:59]I don't recall Maxwell being involved with his investments at all.
[51:02]And then with his properties, assets, airplanes, vehicles?
[51:07]That was the majority of what I understood her role to be. Yes.
[51:11]And she was primarily performing functions of a signatory on invoices and payments?
[51:16]Well, she was more than just a signatory. She was someone that had signatory authority at the banks, but she was also interacting with the pilots, with the property managers,
[51:26]making sure that the properties were to Epstein's liking, and if they needed to purchase something, she would be generating or initiating that process.
[51:42]You mentioned there were six to ten people in your office in this, I guess, pre-2009-2010 timeframe. Is that correct?
[51:54]Yes. Yes, that is correct.
[51:59]And with those six to ten people in your office, would they have routinely communicated with Jeffrey Epstein?
[52:08]Could you explain what you mean by routinely?
[52:11]Were they on their own accord, having conversations, meetings, phone calls, emails with Mr. Epstein?
[52:18]I can't speak on behalf of others. I will say that for the time that I worked in Epstein was my client.
[52:29]Everyone had their own relationship with Epstein, so my involvement with Epstein would be regarding whatever I was working on at the time, his properties, his construction projects, his planes, later in my employment, his investments.
[52:44]But another individual or an accountant might be talking about his investments.
[52:50]The meetings when we were working at 457 were more one-on-one with Epstein. Later thereafter, we would have group meetings at his townhouse.
[53:01]And who would be at those group meetings at his townhouse?
[53:12]The group meetings were typically myself, Darren Endyke, Bella Klein, Harry Beller, Emad Hanner, I believe it's H-A-N-N-A, our IT person, I believe at the time it was William Murphy, Leslie Groff.
[53:40]There may have been one or two more names, but that's what I remember.
[53:49]And Mr. Endyke was Mr. Epstein's primary attorney, is that correct?
[53:55]That's my understanding.
[53:57]And what role did Ms. Klein provide?
[54:02]She was a bookkeeper for Epstein.
[54:04]She worked with you primarily?
[54:10]Well, we all worked for two companies over the years, but she, you know, as I was saying earlier, everyone had their own relationship with Epstein, so we all kind of had our own roles.
[54:24]We would work together because we were both accountants and bookkeepers, but I didn't view her as my assistant. We kind of each had our areas that we worked on.
[54:34]And by saying that she was a bookkeeper, what does that mean?
[54:38]She kept the QuickBooks file for Epstein. She handled his checks. She handled his credit cards. She handled his petty cash.
[54:49]She paid bills on behalf of Epstein personally, as well as many other entities.
[54:55]How did her role differ from your role?
[55:04]So that was her role. So I didn't do any of that stuff.
[55:12]My role would be reviewing checks from properties, bills that came in, dealing with property managers, as I said earlier, reviewing his investments, dealing with Epstein's insurance, for himself and for his employees, his health insurance, his dental insurance, his property insurance, his aviation insurance, his life insurance.
[55:36]I dealt with construction projects. When Epstein was decorating a property, somehow I inevitably always was involved with the architect, engineer, or designer.
[55:49]I was involved with Epstein. If he was hiring employees and hiring a recruiter, I would be the point person.
[55:55]So I did many functions, but none of the functions that Bella Klein did.
[56:01]And Mr. Beller, what was his role?
[56:04]Mr. Beller's role was specific to Epstein's investments in stocks and bonds and derivatives.
[56:13]Mr. Beller provided the accounting for Epstein, for his personal investments, as well as his clients.
[56:25]And Ahmad Hannah, what was his role?
[56:29]Ahmad Hannah was like a project controller. So, you know, he would focus on big projects and really interface with the employees.
[56:42]And some of the stuff that I mentioned that I did, Ahmad Hannah used to do previously, but when he left employment, I started doing that.
[56:51]So if Epstein wanted to purchase a car for himself or for an individual, Ahmad Hannah would handle that.
[56:59]But I later assumed those responsibilities when he was no longer employed.
[57:04]And as a project controller, I presume that includes things like purchasing vehicles. What else would that include?
[57:13]Purchasing vehicles. At one point in time, Epstein was doing a lot of construction on his island, Little St. James.
[57:23]And they set up, I guess, what you call a thatch plant where they were making cement live on the property.
[57:30]I guess it was more cost effective. So Epstein must have hired 30, 40-year people at the time.
[57:37]And he was involved dealing with the construction manager and making sure that the costs were in line and setting up budgets and timelines for the start to the finish of that project.
[57:47]And when you first started with Mr. Epstein in 2005, were you part of the New York Strategy Group?
[58:07]Yes. The first entity that I worked for was New York Strategy Group.
[58:12]And generally what did the New York Strategy Group do as a whole?
[58:18]New York Strategy Group was an entity that provided accounting, bookkeeping, and legal services for Epstein.
[58:25]And does New York Strategy Group still exist?
[58:30]No.
[58:31]And why does it not still exist?
[58:34]I believe it was dissolved around 2012.
[58:40]I don't know why it no longer exists, but I do know that the two entities that followed after New York Strategy Group were HBRK Associates, which I was part of.
[58:55]And that was the accounting of bookkeeping services.
[58:59]And the next entity was, I believe, DKIPLLC, which was the legal entity that was run by Darren Endyke.
[59:11]What does HBRK stand for?
[59:16]HB is Harry Beller. RK is Richard Cunn.
[59:21]And you mentioned when you first started you worked at the 457 Madison Avenue location, is that correct?
[59:30]Yes.
[59:31]And did Mr. Epstein have an office there during that time?
[59:35]Epstein had an office at 457 Madison from the time I started up until the time he was incarcerated.
[59:44]How often would he come to the office?
[59:46]About every three weeks.
[59:52]And did the rest of the staff, including you, Mr. Beller, Mr. Endyke, and Ms. Klein, all have an office at 457 Madison?
[1:00:03]At 457 Madison, I believe it was four rooms.
[1:00:08]There was one room that was the accounting room, and that was myself.
[1:00:14]It was Bella Klein, Harry Beller, and Eman Hannah.
[1:00:19]There were four desks.
[1:00:22]Another office was Darren Endyke with his own office.
[1:00:26]And then there was another office with, I believe, three desks, whereby it was the IT person that had a desk there, Maxwell had a desk there, and there was one more desk.
[1:00:41]I believe the woman's name was Helen Kim, who sat at that desk.
[1:00:46]Then there was a, I guess I said four before, there's actually five offices.
[1:00:53]Leslie Groff, who was Epstein's executive assistant, had her own office, and that was right outside of Epstein's office.
[1:01:00]What was Ms. Helen Kim's role?
[1:01:07]She might have been an assistant to Maxwell.
[1:01:09]I don't recall her specific role, but we didn't really overlap, so I'm not sure.
[1:01:16]And you said the New York Strategy Group was closed down in 2012, and subsequently HBRK came into existence.
[1:01:28]Why did New York Strategy Group close, and why was HBRK set up thereafter?
[1:01:37]I don't recall the reason why New York Strategy Group closed.
[1:01:42]New York Strategy Group, just to clarify the record, New York Strategy Group was dissolved, I believe, in 2012, but it stopped operations, whereby it employed staff, I believe, the last year was 2008.
[1:01:56]2009 was the first year that both HBRK and DKIP LLC began to employ staff.
[1:02:08]I don't recall, or I don't know, why the entities switched, but I was asked if I would be okay, along with Harry Beller and setting up an entity that we owned,
[1:02:21]and I didn't have an issue, so that was where we operated out of HBRK Associates.
[1:02:27]And who asked you to make that decision?
[1:02:30]I believe it was either Epstein or Endyke, I don't recall.
[1:02:33]And whose idea was it to name the company after yourself and Harry Beller?
[1:02:43]I believe Epstein said, you know, you guys are going to form a company, why don't you pick a name, so I believe we decided, not Epstein or Endyke.
[1:02:54]And where, as in, let me backtrack, what office space did you operate out of when HBRK started?
[1:03:09]So when HBRK started, we were still working at 457 Madison.
[1:03:15]At the time, 2009, Epstein was incarcerated and the rent was very high.
[1:03:22]So we had a lease that was very expensive and we were trying to break the lease.
[1:03:28]As Epstein was incarcerated and we were in a recession, we were trying to be more cost efficient.
[1:03:34]So I believe we continued working at 157 Madison until around May or June of 2010.
[1:03:45]And where did you locate to after that?
[1:03:49]For two years thereafter, both HBRK and DKI, the LLC, worked out of an apartment building at 301 East 66th Street.
[1:04:02]And which apartment were you based out of inside of that building?
[1:04:06]There were two apartments. I don't recall which one I was out of, but I know the two apartments were 10B and 10F.
[1:04:13]And what was the layout of the apartments in which HBRK operated in?
[1:04:22]HBRK's apartment was a one-bedroom apartment, which had a living room, dining room, and three desks were set up.
[1:04:31]The three desks in the living room, dining room, were Harry Beller, Iman Hanna, and at the time William Murphy, but then we had a subsequent new IT person.
[1:04:45]And in the bedroom were Bella Klein and myself.
[1:04:51]Did anyone live in this space or is it primarily just an office space?
[1:04:55]It was a residential space that was converted into an office, so at the time we were working there, there was no one living there.
[1:05:02]And who suggested that you move to this space?
[1:05:07]I presume Epstein, but I don't recall.
[1:05:12]Do you know why you were asked to move to this space?
[1:05:15]I think as I mentioned earlier, the 457 Madison rent, I think it was $40,000 or $50,000 a month.
[1:05:24]It was a very fancy, elegant space that Epstein probably wanted for when he was there and dealing with clients,
[1:05:30]but he was not looking to spend that type of money when he was incarcerated and we were just performing work on his behalf.
[1:05:38]Were you aware that Mr. Epstein was affiliated with the 301 East 66th Street building?
[1:05:47]I recall that Epstein was affiliated with 301.
[1:05:55]I know he had access to about 10 to 12 apartments.
[1:05:59]My understanding was that 301 East 66th Street was a co-op that tried to convert to a condo and I call it a failed conversion.
[1:06:13]And I don't know if Epstein put the deal together or knew the players involved, but I knew.
[1:06:20]But my understanding was that that was how he had access to some apartments.
[1:06:24]Did Mr. Epstein pay the salaries for HBRK?
[1:06:35]HBRK was an outside accounting and bookkeeping service.
[1:06:43]And on an annual basis, we would prepare a budget for the salaries, for the operating expenses, the rent, the office supplies,
[1:06:52]whatever cost we thought we would incur for the year.
[1:06:55]And we would bill Epstein and he would usually pay our services for one year in advance.
[1:07:02]And which entity of Mr. Epstein's would pay for these services one year in advance?
[1:07:06]I don't recall. It could have been either one or two of his entities.
[1:07:15]It could have been his personal, which I believe it was, or maybe one of his businesses, but I don't recall exactly.
[1:07:23]We'll get more into various entities later, but what was his personal entity?
[1:07:27]It was just Jeffrey Epstein.
[1:07:31]How did Mr. Epstein act around women in your presence?
[1:07:41]I didn't see anything out of the ordinary.
[1:07:46]When you refer to women, are you referring to employees or assistants?
[1:07:52]Employees, assistants, other women you would have around him at any given time.
[1:07:56]I didn't see anything out of the ordinary, but again, the cadence that I saw him was not very frequent.
[1:08:04]I saw him every three weeks and never saw anything that seemed unusual or that anyone was ever under distress.
[1:08:12]Did you ever witness Mr. Epstein receive a massage from any woman or girl?
[1:08:16]No.
[1:08:18]Did you ever witness Mr. Epstein have sexual contact of any kind with a young woman or girl?
[1:08:22]No.
[1:08:24]Did Mr. Epstein ever discuss sexual acts of any kind with you?
[1:08:28]No.
[1:08:29]Did he ever discuss getting any massages with you?
[1:08:32]No.
[1:08:35]Was it common for Mr. Epstein or Ms. Maxwell to bring young women or girls to any other places where the two of you would meet?
[1:08:42]The only place I ever met Epstein was at the office, 457 Madison or his townhouse.
[1:08:50]So I'm not sure I understand the context of your question.
[1:08:54]There was no other places that I met Epstein or Maxwell.
[1:08:57]Did he bring young women to those meetings?
[1:09:00]Thank you, Ted.
[1:09:02]Occasionally there might be someone.
[1:09:06]When we met at Epstein's townhouse, we met in a dining room similar to a long table like this, and I would be in a meeting with Epstein on occasion.
[1:09:17]An assistant might walk in for 30 seconds, say something to Epstein, and then leave.
[1:09:22]There was never any women present in my meetings with Epstein.
[1:09:26]Did anyone check the date of birth of any employees on the payroll?
[1:09:34]When we received, I usually would hand out an employment package to new employees, and I would receive their information with date of birth.
[1:09:50]And if they were on the insurance plan, I would receive their personal information as well.
[1:09:55]In addition, when we prepared gift tax returns, if Epstein was reporting a taxable gift, we were required to know that individual's date of birth.
[1:10:06]Would you verify those individuals' date of births?
[1:10:12]In New York State, I believe that you're required to have working papers from either your school or from your parents if you're a minor.
[1:10:24]I never saw any working papers in New York, so I knew there were no minors that were working for Epstein on his payroll.
[1:10:31]And for the dates of birth, when we saw the gifts, there was nothing that was alarming that stood out.
[1:10:42]So when you say, did I ever verify them, I wasn't in tune saying was every date, making sure it was a minor, but I never saw a date of birth that was a minor,
[1:10:53]with the exception of potentially one gift that was to what I believe was a family friend of Epstein's.
[1:11:02]And who was that family friend of Epstein's?
[1:11:14]Epstein made gifts to when she was reported on his gift tax returns.
[1:11:21]Do you recall what that gift was at the time?
[1:11:25]She was a minor.
[1:11:27]Yeah, I believe he purchased for her gift cards, American Express gift cards.
[1:11:36]Do you know how much value was for those gift cards?
[1:11:44]Probably somewhere in the $10,000 to $15,000 range.
[1:11:47]Do you ever have any sexual contact with any young woman or girl introduced to you by Epstein or Maxwell?
[1:12:01]No.
[1:12:02]Do you ever receive any massages from any young woman or girl brought to you or introduced to you by Epstein or Maxwell?
[1:12:08]No.
[1:12:26]We will conclude our first hour there and go off the record.
[1:12:30]We are on the record.
[1:12:43]Mr. Conn, good morning.
[1:12:44]Good morning.
[1:12:47]I understand from your testimony in the previous round that you first became aware of Jeffrey Epstein's arrest in Florida through a conversation you had with him in 2008.
[1:12:57]Is that correct?
[1:12:58]Yes.
[1:13:00]Do you recall the date of Mr. Epstein's arrest?
[1:13:04]His arrest, I do not know the date.
[1:13:08]I know when he was incarcerated.
[1:13:10]I believe it was June 30, 2000.
[1:13:12]I'm going to ask the court reporter to mark as Exhibit A an email.
[1:13:19]It's a thread initiated by you to Mr. Epstein.
[1:13:28]I'll give you a moment to review it.
[1:13:42]Could I ask you to read the first email into the record?
[1:13:51]When you say the first email from the bottom.
[1:13:53]The one dated July 28, 2006.
[1:13:57]Bottom up?
[1:13:58]Yes.
[1:14:00]It says, I know it has been a challenging week.
[1:14:02]I support you 100%.
[1:14:03]If there's anything I can do for you, please let me know.
[1:14:07]An email is sent by you to Mr. Epstein, correct?
[1:14:10]Yes.
[1:14:11]And what were you referring to there when you talked about a challenging week?
[1:14:17]I don't recall.
[1:14:19]I'll represent to you that Mr. Epstein was arrested on July 23, 2006.
[1:14:24]Is there anything you could have been referring to in that email other than his arrest?
[1:14:29]I don't recall this email, so it's hard for me to make comments on what I knew.
[1:14:33]It appears from this communication that you've actually learned of Mr. Epstein's arrest in July of 2006 rather than 2008 as you testified in the previous round.
[1:14:42]That's not correct.
[1:14:43]I testified to what I recall, to a conversation I had in 2008.
[1:14:48]This email does not say, I know that you were arrested and it's been a challenging week.
[1:14:53]It says, I know it's been a challenging week and I support you.
[1:14:57]It does not say in this email, I know you were arrested, so I'm not going to testify to that.
[1:15:02]Is there any other challenge you could have been referring to in this email apart from his arrest?
[1:15:07]As I said when I testified a few minutes ago, I don't recall this email, so I don't know what I was referring to.
[1:15:14]I would like to return to the subject of the point in time when you started working for Mr. Epstein.
[1:15:23]Did you have a title?
[1:15:27]No, I think Epstein referred to me and others from HBR Care.
[1:15:34]Actually, it was at the time New York Strategy Group as accountants and bookkeepers.
[1:15:39]You were asked during the previous round about Mr. Epstein's net worth and I wanted to return to that topic as well.
[1:15:48]If I understood correctly, you said you didn't have complete visibility into that question at the onset of your employment,
[1:15:56]but I understood from your testimony in the last round that there came a point in time when you did.
[1:16:00]Is that fair?
[1:16:02]I believe the question earlier was Epstein was a wealthy man.
[1:16:09]I testified that I understood he was a wealthy man because he had many homes and he had planes and other assets.
[1:16:17]I said at the time I was not handling his individual stocks and bonds or asset summaries, so I didn't know what his net worth was.
[1:16:27]I just knew he was a wealthy man.
[1:16:29]When Harry Beller left working for Epstein in I believe May of 2014, at that point in time, I began making asset summaries for Epstein.
[1:16:45]Okay, so let's start at that point in time.
[1:16:48]What was Mr. Epstein's approximate net worth?
[1:16:55]One additional clarification.
[1:16:57]The asset summaries that I was preparing only included Epstein's liquid assets, his investments in stocks, bonds.
[1:17:07]It might have been loans receivable.
[1:17:09]It might have been maybe an investment in a private company that was valued on a frequent basis, but it never included his homes.
[1:17:18]He never wanted to see his homes on there, so I can't accurately say it was a net worth statement.
[1:17:24]It was a good portion of his assets, but not a total financial picture.
[1:17:29]Okay, so we can break those apart.
[1:17:31]Liquid assets.
[1:17:33]What was the value, as you understood?
[1:17:35]Again, I don't recall what at any given point in time his liquid assets were worth.
[1:17:42]I do know he had hundreds of millions of dollars in stocks and bonds and investments.
[1:17:48]And I do know, as serving as co-executor, that when we filed his Form 706, a state tax return, it had somewhere between five and six hundred million in assets.
[1:18:01]And I'm sorry, just to clarify, I understood your testimony in the previous round with respect to your appointment as co-executor.
[1:18:09]You were not surprised at that appointment because you did have visibility into the value of his assets.
[1:18:14]Is that correct?
[1:18:15]I thought Epstein would want me to serve as his co-executor, and I chose to serve as co-executive because I thought I knew his assets best.
[1:18:23]However, it appears at the moment that you did not have complete command of his assets, if I'm understanding your answers correctly.
[1:18:37]I don't think he said that at all.
[1:18:39]I think he said he doesn't recall in 2014 what the assets are worth.
[1:18:44]He told you what they were worth at the time of the estate becoming formed.
[1:18:49]So I'm not sure your question.
[1:18:51]I'm sorry.
[1:18:52]I just want to make sure we're clear on what your understanding was at these various shifting points in time.
[1:18:57]You did have complete visibility into the totality of Mr. Epstein's assets at the time his estate was formed, but not prior to that.
[1:19:07]And I want to put words in your mouth.
[1:19:08]Please, not what I testified.
[1:19:09]Please clarify.
[1:19:10]What I testified was you had asked me what was his net worth?
[1:19:13]What was he worth?
[1:19:14]What was the value of his stocks and bonds?
[1:19:16]And I said I don't recall any specific value from 2014 to 2019.
[1:19:21]I knew it was in the hundreds of millions of dollars.
[1:19:24]I then testified I know at his day to death when the estate tax return was filed, it was somewhere between, I think, five hundred and fifty and six hundred million dollars.
[1:19:32]So I knew the totality of his assets, but I did not know, number one, his net worth at any given point in time because we never included the homes, nor do I recall to a particular period.
[1:19:45]These reports were produced monthly, nor do I recall from 2014 to 19 what any monthly valuation would be.
[1:19:53]Was part of your job duties the preparation of Mr. Epstein's tax returns?
[1:19:58]I never prepared any tax returns for Epstein.
[1:20:01]He used outside accountants.
[1:20:03]During the period of time that Mr. Epstein employed you, what were the sources of his wealth?
[1:20:10]Epstein earned fees from his clients for financial tax and estate planning.
[1:20:18]Epstein made investments.
[1:20:21]So he had interest, dividends, made real estate investments.
[1:20:28]So he had passive income.
[1:20:30]That's what I understand the sources of his income.
[1:20:35]If we could talk about the clients for a few minutes, how many clients did Mr. Epstein have?
[1:20:41]Again, this is during the period of your employment.
[1:20:44]So I know clients to be individuals that paid income to Epstein's entities.
[1:20:55]And I believe during my period of time, somewhere between five and ten clients Epstein had.
[1:21:02]However, there were many times that Epstein spent time talking to someone, trying to cultivate business, but that never occurred.
[1:21:12]So he might spend a year or two with what he would think would be a prospective client.
[1:21:17]And that person, maybe he gave them advice that was useful or not, but that client never paid fees.
[1:21:23]So I don't know if you would consider that to be a client.
[1:21:26]But, you know, in getting to the number ten, I think probably there were about five that he spoke to that never paid fees.
[1:21:34]And I'm aware of approximately five clients that paid fees over the years.
[1:21:38]And I appreciate that distinction.
[1:21:40]If we could focus on the clients who did pay fees, who were they?
[1:21:44]Dan, am I allowed to say?
[1:21:51]So there are certain confidentiality agreements that Mr. Kahn has signed on to.
[1:22:00]So we have, you know, just that issue with respect to that.
[1:22:13]I mean, I think these names are probably well-known, but nonetheless, Mr. Kahn is bound by confidentiality agreements.
[1:22:19]And do those confidentiality agreements set forth a complete bar to disclosure?
[1:22:26]Are there not exceptions for responses to questions duly posed by a congressional committee?
[1:22:36]I don't recall exactly the language, but I don't believe there's any exception for a congressional committee.
[1:22:43]I think it's by law. I'm not sure if this qualifies by law.
[1:22:46]If you would, I think you could ask if, do you mind if we take a two minute break?
[1:22:59]I'll just talk to Mr. Kahn about this.
[1:23:01]Sure. I'll just note for the record that from the minority's perspective, I won't speak for our majority colleagues.
[1:23:07]Your client is under an obligation pursuant to subpoena to respond to all of our questions today.
[1:23:13]We'd love to do it.
[1:23:14]We'd love to do it.
[1:23:15]I'll leave it there. And yes, we can go off the record.
[1:23:27]And John, you can ask that question again.
[1:23:30]Again, my question, Mr. Kahn, you referred to five clients of Jeffrey Epstein who paid fees to him during the period of your employment.
[1:23:38]And so I would ask you to identify those five clients.
[1:23:43]The first clients that paid fees that I'm aware of is Les Wexner.
[1:23:51]The next client that paid fees was either Glenn Dubin individually or his entity, Highbridge Capital.
[1:24:00]The next client was an individual named Stephen Sanofsky.
[1:24:05]I believe Rothschild paid fees.
[1:24:11]Rothschild, is that an individual or an entity?
[1:24:16]I don't recall. I don't recall how the income was received, but I believe it was from I believe maybe Ariana Rothschild or one of her affiliated entities.
[1:24:27]And Leon Black, I believe, was the fifth.
[1:24:31]Thank you.
[1:24:34]If we could break those down, I'd just like to ask you about the services that Mr. Epstein provided to each of those five, starting with Les Wexner.
[1:24:46]I am not aware of the services that Epstein provided to Les Wexner because I was not involved
[1:24:56]in working with Epstein or anyone from New York Strategy Group on that account.
[1:25:02]I had no interface with Les Wexner and Epstein's fee income.
[1:25:07]And again, this is cabin to the period of your employment.
[1:25:11]How much did Mr. Wexner pay Jeffrey Epstein?
[1:25:14]I don't know.
[1:25:16]And then Glenn Dubin, same questions.
[1:25:18]Glenn Dubin, I remember seeing income come in for the sale of Highbridge.
[1:25:30]I don't recall a specific amount. I think it was somewhere between $15 and $25 million, but I don't recall the specific number.
[1:25:38]And the income may have come in before I began working there, but I do recall at one point seeing an invoice and a fee.
[1:25:48]And that was in connection with the sale of Highbridge Capital?
[1:25:51]That is my understanding.
[1:25:56]And the services that Mr. Epstein provided to Mr. Dubin in connection with that sale were what?
[1:26:04]My understanding, again, I was not involved in that work, but my understanding was that he advised on the sale of Highbridge Capital to JPMorgan.
[1:26:14]And then Leon Black?
[1:26:19]Leon Black, I was involved in the work on that account.
[1:26:23]And Epstein provided tax estate planning and financial consulting work to Leon Black.
[1:26:37]And that is what he received the income for.
[1:26:40]And how much did Mr. Black pay him?
[1:26:44]I don't recall the exact amount. I believe it was somewhere in the range of $150 million.
[1:26:51]And with respect to the tax and estate planning consulting work, what specific issues was Jeffrey Epstein advising him about?
[1:27:03]There were many things that Epstein was working on for Leon Black.
[1:27:08]I think the first thing that Epstein did, at least that I was aware of, so I'm only speaking from what I'm aware of, what I was involved in.
[1:27:18]I don't know about Mr. Black and Epstein's conversations that they had regarding the work, so I can't speak to what Epstein provided consulting on.
[1:27:28]But I know that I believe when Epstein first started working with Black, Leon Black had a family office that was very understaffed.
[1:27:38]So one of the first things that Epstein helped Black with was staff up a proper sized family office.
[1:27:44]So we were involved in the hiring of individuals to support Black's assets and his needs.
[1:27:52]We were involved in reviewing his trusts, his holdings, how he held art, how he held investments.
[1:28:02]I know Epstein did a lot of talk with Leon Black regarding his TRA, which I believe is a tax receivable asset.
[1:28:13]We reviewed the structure of how Leon Black held his planes. His planes were managed by an outside entity.
[1:28:21]So we reviewed the expenses for his planes and I believe his boat.
[1:28:27]We dealt with one of the hires that Leon Black made was he hired an estate attorney and an art consultant.
[1:28:36]So the majority of our meetings revolved around estate planning, whereby they would produce a book that would include all of Mr. Black's assets.
[1:28:49]And they would run through different scenarios based on where Apollo stock was and how that would impact his estate.
[1:28:56]Don't go into what the attorney says. Don't tell what Black's attorney says.
[1:29:01]So we went, we did estate planning.
[1:29:03]It appears that you are rather closely familiar with the scope of the work that Mr. Epstein did for Leon Black, but not for Les Wexner.
[1:29:14]Why is that?
[1:29:16]Because I began working for Epstein in October of 2005 and I was never involved on that account.
[1:29:26]Harry Beller was working there at the time. So Harry Beller was handling all of the trusts.
[1:29:32]He was handling all the investments.
[1:29:37]I guess it was well-staffed and I wasn't needed.
[1:29:41]And I believe shortly thereafter that relationship between Epstein and Mr. Wexner ended.
[1:29:48]What was your understanding as to why that relationship ended?
[1:29:52]I don't know why it ended, but I do know it ended around the time of his incarceration.
[1:29:59]Of Mr. Epstein's incarceration in 2008?
[1:30:02]Correct.
[1:30:03]And then just to round out the list, Mr. Kahn, Stephen Sinovsky, do I have that right?
[1:30:38]That was one of the names I mentioned that Epstein received fees from.
[1:30:42]Who is Mr. Sinovsky?
[1:30:45]I don't know. Let me rephrase that. At the time I didn't know who he was.
[1:30:50]I've seen subsequent press reports in the last six months to a year.
[1:30:55]I understand that Mr. Sinovsky used to work at Microsoft.
[1:30:58]However, I have no knowledge of what work Epstein did for Mr. Sinovsky to receive those fees.
[1:31:04]And then lastly, Arianna Rothschild.
[1:31:08]My understanding for that was that Epstein was doing estate planning on their behalf.
[1:31:15]And I did attend a few meetings with Ms. Rothschild's team along with some of Epstein's staff.
[1:31:26]Do you know how much money Mr. Sinovsky paid Jeffrey Epstein?
[1:31:30]I believe it was $5 million.
[1:31:32]And what about Ms. Rothschild?
[1:31:34]I think it was $20 or $25 million.
[1:31:38]Just a few follow-up questions related to Mr. Epstein's incarceration in Florida.
[1:31:57]Did you or anyone else ever make any payments in connection with Epstein's incarceration or work release?
[1:32:09]I can be more specific.
[1:32:11]Payments with the goal of securing for Mr. Epstein better treatment either in prison or on his work release.
[1:32:21]I'm not aware of any payments that relate to what you just mentioned.
[1:32:25]And to your knowledge, did you or anyone else ever make any payment on behalf of Jeffrey Epstein to any law enforcement officer?
[1:32:33]Not that I'm aware of.
[1:32:35]Although I do believe when Epstein had office hours in Florida, he was required to have, I don't know what the right term is,
[1:32:45]a guard or someone that was present either in his office or outside his office.
[1:32:51]I believe that might have been, I don't know if that answers your question or relates to your question,
[1:32:56]but that might have been something that he was responsible to pay for.
[1:33:00]Were you involved in making that payment?
[1:33:02]I don't recall.
[1:33:03]Was any payment ever made by you or anyone else on behalf of Jeffrey Epstein to Alex Acosta?
[1:33:10]Not that I'm aware of.
[1:33:12]And did you ever become aware of Jeffrey Epstein paying the fees for attorneys for victims in the Florida case?
[1:33:24]Could you repeat that, I'm sorry?
[1:33:26]Sure.
[1:33:27]Did you ever become aware of Jeffrey Epstein paying for the attorneys who represented victims in the Florida case?
[1:33:33]I don't recall.
[1:33:38]I wasn't that familiar with that at the time.
[1:33:43]I'd like to shift gears and talk a little bit more about 301 East 66th Street,
[1:33:50]the building where I understand you had an office for a period of time.
[1:33:56]We've talked about the office arrangement.
[1:33:59]I'd like to ask you whether there were women connected to Jeffrey Epstein who were also living at 301 East 66th.
[1:34:07]Only women or the men too?
[1:34:09]Start with the women.
[1:34:11]At the time, Epstein had, I believe, 10 to 12 apartments at 301 East 66th Street.
[1:34:23]So let's just say for this example, there were 10 apartments.
[1:34:27]The offices 10B and 10F were two out of the 10 apartments.
[1:34:32]I believe there was a period of time and I'm not speaking to a specific year.
[1:34:40]I'm going to just speak, generally speaking, because I don't recall the dates where people occupied apartments.
[1:34:45]But I know of the apartments that Epstein had, some of his assistants did have apartments.
[1:34:55]I believe Sarah Kellan had an apartment.
[1:34:59]I believe Nadia Marcinkova had an apartment.
[1:35:05]I believe at one point in time Svetlana had an apartment.
[1:35:10]I believe at one point in time an employee of Eva Dubin's, maybe a housekeeper, had an apartment.
[1:35:18]I believe two of the pilots had apartments.
[1:35:22]I believe that Lin, his housekeeper, from 90 71st Street had an apartment.
[1:35:30]And I think there was always a couple of guest apartments that he kept open for guests or friends that would come in town that he would be able to use those apartments for.
[1:35:42]If I could back up for a second, you said that Mr. Epstein had 10 to 12 apartments in the building.
[1:35:48]Did he own those units?
[1:35:51]Good question. I don't believe he owned those apartments.
[1:35:55]And I was not familiar with the arrangement.
[1:35:59]What I understood was that on a few of the apartments, Epstein paid rent, let's say, for example, $2,000 a month.
[1:36:09]And on the remainder of the apartments, Epstein was billed annually and he would pay for the operating expenses of those apartments.
[1:36:17]For example, the equivalent as if it was a condo, he would pay the common charges and the real estate taxes.
[1:36:25]And I believe the utilities may be included in that payment as well.
[1:36:31]So we were billed annually for the majority of the apartments.
[1:36:35]So it's fair to say that he covered the cost of housing for the people who occupied those units?
[1:36:43]Yes, with a few exceptions.
[1:36:48]There were a few individuals over time that did pay rent.
[1:36:52]Did any of the women you just identified pay rent?
[1:36:56]I believe over a period of time there were some women that paid rent.
[1:37:00]Who?
[1:37:02]I believe Jen Kalin and Karina Szuljak paid rent at one point in time.
[1:37:11]I think at one point in time, John Luke had an apartment he paid rent.
[1:37:23]I think there are others.
[1:37:26]Maybe it was one other apartment, but I don't recall who that was.
[1:37:32]As to the individuals for whom Mr. Epstein did pay rent, was it your job to make those rent payments on his behalf?
[1:37:44]The individuals that paid rent, paid rent directly to the management company.
[1:37:48]The rent didn't come to Epstein.
[1:37:51]But when Epstein was billed, as I mentioned earlier, at the end of the year,
[1:37:56]I believe Epstein's New York entity, NES LLC, paid the costs of the apartments at 301 East 66th Street.
[1:38:08]Was it you or Bella who did that?
[1:38:11]Bella, the bill would come to me by OSSA properties.
[1:38:17]I would review the bill.
[1:38:19]Epstein would approve it, and Bella Klein would make the payments.
[1:38:25]I am going to ask the court reporter to mark as Exhibit B an email from an email thread between yourself and Leslie Groff dated November 7th, 2014.
[1:39:25]Mr. Kahn, I'm going to ask you about some of the individuals referenced in this email.
[1:39:30]Before I do that, I just want to make a request for the record to the majority
[1:39:39]to ensure that to the extent any of my questions today elicit the identity of any actual or potential Epstein survivors,
[1:39:47]that those names and any information from which they could be identified are fully redacted prior to any public release of the transcript.
[1:39:56]Now, as to this email, Mr. Kahn, starting at the bottom, you are emailing Ms. Groff for a breakdown of, well, why don't you read that sentence into the record?
[1:40:15]OK, November 7th, 2014, I wrote to Leslie Groff, can you please send me the latest breakdown of the apartments, I wrote alts, but it means apartments for 301. Thanks.
[1:40:34]And why were you asking Ms. Groff for that?
[1:40:37]The reason that I was inquiring about the status of the apartments was that the individuals that stayed at Epstein's apartments were receiving a benefit from Epstein because he was paying the expenses.
[1:40:53]So it was my job to assemble the information for Epstein's gift tax returns.
[1:40:58]And I needed to make sure that I knew who was living in the apartment and for what period of time so that that could be properly reported on Epstein's gift tax returns.
[1:41:09]If we could focus on the second email, and I'll start from the top of the list, there's a reference to 2G, and I take that to be the apartment unit.
[1:41:22]Is that correct?
[1:41:24]2G, yes.
[1:41:26]Do you know, looking at this email, who the individual whose name is redacted here is?
[1:41:39]No, I was going to say, I'm assuming everyone she is redacted.
[1:41:44]I don't know who was ever in any apartment other than what I said earlier, we were in 10B and 10F.
[1:41:51]Well, Ms. Groff sent you a list identifying the occupants of these units, right?
[1:41:56]Right, but I guess what I'm trying to say, and forgive me for not being clear, I don't recall the specifics of this email at the time.
[1:42:05]I know why I asked for the apartments, but I don't remember from 2014 who was in any apartment now looking at it today.
[1:42:13]And unfortunately, the names that you're asking me for are redacted.
[1:42:18]So I'll just go down the list. 3M also redacted.
[1:42:23]Yes.
[1:42:25]Do you know who that individual is?
[1:42:26]No.
[1:42:28]Do you know whether the individuals referenced with respect to 2G and 3M were female?
[1:42:35]I don't know who the names are of 2G and 3M as they're redacted, so I can't answer that question.
[1:42:42]5P is Lynn and Jojo?
[1:42:45]Yes.
[1:42:46]Who are they?
[1:42:47]Lynn and Jojo were Epstein's housekeeper and liber for 90 71st Street.
[1:42:54]And 7J is Jean-Luc?
[1:42:56]Yes.
[1:42:57]And who is that individual?
[1:42:59]I believe Jean-Luc was a friend of Epstein's.
[1:43:03]Okay, and I will return to him at a later point today. 8A guest apartment, 8C JE brother kids. Who is that referring to?
[1:43:16]I think when I was pondering before, I thought maybe there was another apartment that paid.
[1:43:21]I believe that Epstein was paying for his brother's apartment.
[1:43:29]Joyce might be a reference to Mark Epstein's first wife.
[1:43:35]And Epstein was providing apartments for his kids possibly.
[1:43:39]That's what I assume from this.
[1:43:44]Moving further down the list, 8H name redacted. Do you know who that individual is?
[1:43:50]No.
[1:43:51]Do you know whether that person was female?
[1:43:53]No.
[1:43:54]10F also redacted. Do you know who that individual is?
[1:43:58]No.
[1:44:00]Do you know if that person was female?
[1:44:02]No.
[1:44:03]And 10N, again, name redacted. Do you know who that individual is?
[1:44:08]I do not.
[1:44:09]Was that individual female?
[1:44:11]I do not know.
[1:44:12]11E, once again, redacted.
[1:44:16]I do not know who that individual was.
[1:44:21]And 11J also redacted.
[1:44:25]In the parentheses redacted, I do not know what the redaction relates to.
[1:44:44]Going back to the roster of individuals who connected to Mr. Epstein who had units in the building, how many of those were female?
[1:44:55]And I'm going to exclude Lynn and Jojo from that list.
[1:45:01]Are you including the kids?
[1:45:03]Not including the kids.
[1:45:05]And do you want them to speculate based on their redactions?
[1:45:11]No.
[1:45:15]So if I understand your question, you're asking me this list of apartments from November 4th?
[1:45:21]I'm asking, independent of this email, what women do you recall having been in the building, women who were connected to Jeffrey Epstein?
[1:45:29]What women do I recall living in the building at any point in time?
[1:45:32]At any point in time.
[1:45:33]Okay. Thank you for clarifying.
[1:45:37]Sarah Kelly.
[1:45:40]Nadia Marcinkova.
[1:45:42]Svetlana, I don't recall her last name, it's with a P.
[1:45:51]I believe Sue Hamlin had an apartment at one point in time.
[1:46:01]There may be a few more names, but I don't recall.
[1:46:11]That's what comes to mind.
[1:46:13]And of that list, what was the age range?
[1:46:24]I don't know the age range, but I could tell you I know that none of those women were minors.
[1:46:31]Were any of them, to your understanding, above the age of 30?
[1:46:35]As I said before, I do not know their age range, but I do know that none of those women were minors.
[1:46:42]How do you know that?
[1:46:44]Because, as I said and testified earlier,
[1:46:47]I was required to obtain their date of birth for either employment records or for gift tax returns.
[1:46:57]And what was your understanding after the nature of their relationship to Jeffrey Epstein?
[1:47:04]Some of the women that were mentioned were assistants that worked for Epstein.
[1:47:13]Were these women, from your perspective, women who would generally be perceived as attractive?
[1:47:22]I can't make that judgment. You're asking me if I thought these women were attractive?
[1:47:25]Sure.
[1:47:27]It's not a fair question.
[1:47:29]He can't answer that question. I mean, everyone has their own view of it.
[1:47:32]And if you're getting at something, if you want to say, did you think they were being abused, just ask him that question.
[1:47:38]No, I'm interested in his perception of their attractiveness.
[1:47:41]I never looked and viewed at Epstein's assistants and made judgment on their looks.
[1:47:49]Sitting here now and knowing these women, would you classify any of them as unattractive?
[1:47:55]Yes.
[1:47:57]Which ones?
[1:47:58]I'm not answering that question.
[1:48:00]And to your understanding, did Mr. Epstein view these women as attractive?
[1:48:04]I don't know if Epstein viewed any women.
[1:48:07]Were any of those women foreign?
[1:48:10]I believe Nadia Marcinkova was foreign. Svetlana, I believe, was foreign.
[1:48:17]What were their nationalities?
[1:48:21]Eastern European. I don't recall the countries.
[1:48:26]Russian?
[1:48:27]Potentially. I don't recall the countries.
[1:48:30]And what was your understanding as to how they came to know Jeffrey Epstein?
[1:48:34]I didn't know how these women came to me, Mr. Epstein.
[1:48:38]Did you ever ask him about that?
[1:48:41]Did I ask Epstein how he met his assistants?
[1:48:44]These women, yes.
[1:48:46]The women that we're speaking about now?
[1:48:48]Yes.
[1:48:49]No.
[1:48:50]Did you ever talk to anyone else about that?
[1:48:52]No.
[1:48:54]Did you ever understand that Jeffrey Epstein was engaging in sexual activity with any of those women?
[1:49:00]Can you repeat your question, please?
[1:49:05]Did you ever understand that Jeffrey Epstein was engaging in sexual activity with any of those women?
[1:49:10]I was not aware of Epstein's personal and sexual relationships.
[1:49:14]Did you think it was possible?
[1:49:16]It's not something that I thought about.
[1:49:19]Did you think it was possible that he was sexually abusing any of them?
[1:49:23]I never thought it was possible that Epstein was sexually abusing them because if I thought that, I would have never continued to work for Epstein.
[1:49:31]Did you believe that the relationship between these women and Jeffrey Epstein was platonic?
[1:49:37]I knew that these women worked for Epstein as assistants.
[1:49:44]I made no judgment if these women were girlfriends.
[1:49:47]What I knew is that none of these women were minors.
[1:49:50]And I also knew that none of these women ever came to me and said that they were in danger or that they were being sexually abused or trafficked by Epstein.
[1:49:59]So we've talked about women at 301 East 66th.
[1:50:10]You've also mentioned being in Epstein's home.
[1:50:14]And specifically, if I understand correctly, his mansion on East 71st Street. Is that correct?
[1:50:20]I visited Epstein's home at 90 71st Street approximately every three weeks for my meetings with Epstein.
[1:50:28]And when you were present for those meetings, you observed women present in his residence. Is that also correct?
[1:50:39]On my visits to Epstein's home, I saw women.
[1:50:44]The first woman I would see is usually when I would come into the building would be Leslie Groff, who had an office right off the stairway.
[1:50:53]I often would see Epstein's housekeeper, Lynn, sometimes another housekeeper by the name of Tess.
[1:51:03]And on occasion, either waiting for a meeting in Leslie's office for Epstein, I would see some of Epstein's assistants.
[1:51:13]And when you say some of Epstein's assistants, are you referring to the women who resided at 301 East 66th that we were just discussing or are these different women?
[1:51:23]I'm referring to assistants of Epstein. I don't know where all of Epstein's assistants resided.
[1:51:29]So I just want to be clear, because again, we're talking about the roster of women that you encountered.
[1:51:36]The ones that we're talking about you seeing in his residence are distinct from the list living at 301 East 66th that we talked about.
[1:51:45]What I'm saying is you're saying you asked me the question, is every woman you saw at 90 71st Street, who was an assistant of Epstein's, did they all live at 301 East 66th Street?
[1:51:58]And what I'm saying to you is I named three or four assistants of Epstein.
[1:52:03]And over my 14 years of working for Epstein, he had more than three or four assistants.
[1:52:08]So I don't know where some of these other women lived.
[1:52:12]And you're trying to reference to me, you know, where did some of these other women live?
[1:52:15]I don't know. Maybe they lived at one point in time at 301.
[1:52:19]Maybe they live somewhere else, but I can't answer that question.
[1:52:23]Irrespective of their residence, the women that you observed in Epstein's mansion, what was the age range of those women?
[1:52:34]I don't know the age range of the women that worked for Epstein as assistants, but I do know that none of them were minors.
[1:52:44]Did any of them, to your observation, appear to be above the age of 30?
[1:52:51]There probably were some, but I don't, you know, as I keep testifying, I don't know the exact age of these women.
[1:52:59]But I believe that there were some assistants that were in their 30s, yes.
[1:53:04]And how many of those women were also foreign?
[1:53:08]I don't know.
[1:53:09]Did you ever travel on Mr. Epstein's plane?
[1:53:20]Yes, on two occasions I traveled on Epstein's plane.
[1:53:25]This was at a time when I was visiting his office in St. Thomas, the U.S. Virgin Islands.
[1:53:34]I purchased a round-trip ticket to go meet with his office employees in St. Thomas,
[1:53:40]and usually my trips to see his islands were revolving around a construction project.
[1:53:47]So as I alluded to before, just as an example, if he was running a batch plant and there was a big project going on,
[1:53:54]I may go down and look at the project because I was told many times that I was very tough in approving bills.
[1:54:02]So many times Epstein wanted me to see a project so I could better understand what was going on and pay those invoices quicker.
[1:54:09]So I typically went to visit his local office in St. Thomas,
[1:54:15]and on occasion would take a trip to his islands during that visit to see a project or deal with staffing or employment issues.
[1:54:23]But on two of the visits whereby I purchased a round-trip ticket, Epstein was also in residence
[1:54:29]and asked if I would like a ride back to New York, whereby I said yes.
[1:54:34]And those were the two occasions I traveled on Epstein's plane.
[1:54:39]And on those two trips, who else was on the plane with you?
[1:54:46]On the first plane ride, and I don't recall the dates, it was Darren Endyke, myself, Epstein, and I believe Sarah Kellan, plus the two pilots.
[1:55:00]And that's both trips.
[1:55:07]Oh, I'm sorry. Sorry about that.
[1:55:09]The second trip, it was myself, Epstein, an assistant, and the two pilots.
[1:55:16]And who was the assistant?
[1:55:18]I don't recall the assistant, but what I do recall specifically about that flight
[1:55:24]is that the pilots asked me if I wanted to sit in the cockpit and watch the whole plane process,
[1:55:30]which I said yes and regretted that because it was pretty scary with the speed and watching it through the front window.
[1:55:38]We do have some questions for him.
[1:55:49]Yes.
[1:55:50]Thank you for your cooperation. I'm Representative Suhas Subramanian from Virginia.
[1:55:53]Some of this may be a little redundant, but I appreciate you bearing with me.
[1:55:57]Did Jeffrey Epstein or anyone associated with him ever ask you to assist with anything illegal
[1:56:03]or you may have construed to potentially be illegal during the time working for him?
[1:56:07]Not that I'm aware of, no.
[1:56:09]Were you ever asked to do anything illegal yourself at any point?
[1:56:15]Not that I'm aware of.
[1:56:17]Were you ever asked, did you ever ask or inquire about the legality of any of these transactions or any of his actions?
[1:56:25]Could you be more specific with your question, please?
[1:56:28]In your capacity while working for him, were you ever, did you ever inquire with,
[1:56:33]did you, Jeffrey Epstein or any of his associates, including Darren and Dyke,
[1:56:36]about the legality of anything going on with Jeffrey Epstein at any point?
[1:56:43]Are you asking if I ever saw a transaction that was alarming that I asked him a question about?
[1:56:47]Yes.
[1:56:48]Not that I'm aware of.
[1:56:50]Did you ever see any transactions that you found alarming or found suspicious in any way?
[1:56:56]I never saw a transaction in Epstein's books and records that said payment for sex
[1:57:02]or I don't recall ever seeing any payments that said, you know, for massages.
[1:57:06]So there was never anything in his ledger that alluded to that, if that's what you're asking.
[1:57:12]Just to follow up to that, I'm not referring just to sex trafficking, but anything illegal, not just sex trafficking.
[1:57:18]Not that I'm aware of.
[1:57:20]And did you ever provide any financial advice or assistance to any women associated with Jeffrey Epstein,
[1:57:26]such as tax advice or just any informal financial advice?
[1:57:31]About four or five of Epstein's assistants had asked if I would do a favor and prepare their tax returns.
[1:57:38]Do you remember who they were?
[1:57:40]I believe it was Karina Szuliak.
[1:57:54]Maybe her name's LaLassa, I'm not sure.
[1:57:59]There might have been one other, two others, for those are the names that I recall.
[1:58:02]So you'd mentioned in 2008 you'd heard about the arrest, but by 2019,
[1:58:07]is that when you started to learn about the extent of his crimes?
[1:58:12]When the Miami Herald article came out, it was alarming because
[1:58:17]there was a lot more depth to what took place in 2008.
[1:58:22]And at the time, this was the time when we had just gotten dropped by Deutsche Bank.
[1:58:30]So after he was dropped by banks, did you help him try to find new firms that would open accounts for him?
[1:58:36]When Epstein was dropped by Deutsche Bank, I tried to help Epstein open up cash and brokerage accounts.
[1:58:46]Did you ever help him withdraw cash amounts that wouldn't trigger federal reporting,
[1:58:51]specifically because that amount wouldn't trigger federal reporting?
[1:58:54]I never had signatory on any of Epstein's accounts with the exception of HBRK, which was my company.
[1:59:01]There was a company, a design company, that I had signatory authority for the sole purpose of processing payroll.
[1:59:08]I never signed any cash withdrawals from that.
[1:59:13]And at one point in time, one of his trusts, I had signatory authority, but all of his other accounts,
[1:59:18]I never had signatory authority until the last six months when Epstein was alive.
[1:59:23]Did you ever withdraw cash for Jeffrey Epstein to pay for services or pay Jeffery Epstein?
[1:59:30]Not that I recall.
[1:59:32]How were Jeffrey Epstein's employees generally paid? Were they paid through wire transfer or cash?
[1:59:39]Do you have any knowledge of that?
[1:59:41]Epstein had assistants that were on payroll, and it was with the employees.
[1:59:48]My assumption was those are the employees that were working full-time.
[1:59:53]But Epstein may have had other assistants that were not full-time that he may have paid via cash or wire transfer,
[2:00:01]but I'm not aware of that because I didn't travel with these individuals.
[2:00:07]Were you aware of any financial transactions involving public figures, such as politicians, political leaders, or heads of state?
[2:00:14]Could you please repeat that?
[2:00:15]Were you aware of or involved in any financial transactions involving Jeffrey Epstein
[2:00:21]or any public figures, political leaders, or heads of state?
[2:00:26]Public figures? Financial transactions?
[2:00:30]Such as wire transfers, such as business dealings.
[2:00:34]Would Leon Black be considered a public figure?
[2:00:40]I would think anyone in a government or anyone who's a public figure.
[2:00:45]An American politician?
[2:00:48]Any politician around the world.
[2:00:52]The only thing that comes to mind is that I believe Epstein invested in an entity.
[2:01:03]I don't even know if it was his partner or what the original origins of, but with Ehud Barak.
[2:01:10]And then were you aware of any financial transactions while you were employed there involving Jeffrey Epstein and the Trump family?
[2:01:19]Either before you'd been employed or after?
[2:01:21]Never aware of any transactions between Epstein and the Trump family.
[2:01:26]Thank you.
[2:01:28]Ms. Wolfe, Trump.
[2:01:29]Thank you, Mr. Cahn. I'm James Wolfe from Virginia, and I'm going to start by introducing Exhibit C,
[2:01:35]which is an email chain between Jeffrey Epstein and a redacted individual from September 13, 2017 with the subject line Visa Switzerland.
[2:01:46]We have a copy of it there.
[2:01:51]As I said, it's an email between Epstein and a person whose identity is redacted.
[2:01:56]The redacted sender emails Epstein asking what she should put down.
[2:02:01]Excuse me one second. Could you mind if I read it for a second?
[2:02:03]Sure, go ahead.
[2:02:04]Okay.
[2:02:56]Okay, so as you saw in this email, the redacted sender emails Epstein asking what she should put down for her university application to explain,
[2:03:05]quote, who is the sponsor to me and on what grounds she provides me with financial support.
[2:03:12]Epstein then explains that the redacted person will have a sponsor paying for the full tuition.
[2:03:18]And she replied, quote, a full scholarship from Richard Cahn.
[2:03:22]I'm sorry, sir, but I don't see the connection.
[2:03:25]And then as you saw on page three, Epstein replied, Richard has decided to pay for your school.
[2:03:31]That's all you need to know. He gives out scholarships.
[2:03:35]Smiley face. Mr. Cahn, have you seen this email before today?
[2:03:40]Have you all seen this email?
[2:03:42]No, I've never seen this email.
[2:03:44]Okay, so you're not familiar with this?
[2:03:50]I believe I'm familiar with the transaction, but I'm not familiar with the email.
[2:03:56]Okay, and do you know who the sender is? Who is Epstein corresponding with?
[2:04:03]It might have been a woman by the name of...
[2:04:07]Do you remember her surname?
[2:04:10]I believe it is with... I don't recall her last name.
[2:04:15]What was your relationship to her? What is your relationship to her?
[2:04:20]I did not have a relationship with her.
[2:04:23]My understanding of this transaction was that Epstein had asked me if HBRK,
[2:04:32]which was the entity that I operated out of, would sponsor this individual for her school.
[2:04:41]This woman was attending school in Switzerland, or I believe it was a finishing and hospitality school,
[2:04:49]and that Epstein was going to potentially hire her after the school,
[2:04:54]but he asked if my entity would pay the invoice for her school.
[2:04:58]And you had ever met her?
[2:05:00]I don't recall ever meeting this woman.
[2:05:03]Okay, and beyond what you described, what did you understand Epstein's relationship to be with her?
[2:05:12]I did not know Epstein's relationship with her.
[2:05:15]And you didn't ask?
[2:05:17]I didn't ask. What I was explained to understand was that Epstein was paying for tuition for this woman to attend a hospitality school,
[2:05:27]and I knew that from previously employing, through HBRK, individuals that provided hospitality services,
[2:05:35]where we called them property managers.
[2:05:39]It kind of overviewed all of the properties.
[2:05:42]Our entity, HBRK, has hired those individuals before.
[2:05:46]I thought that that's what this transaction related to.
[2:05:51]In the email, Epstein says that you will give out scholarships.
[2:05:58]What did you understand him to mean by that?
[2:06:01]I don't think that's an accurate statement that I personally give out scholarships.
[2:06:08]Your business, HBRK?
[2:06:11]HBRK, I don't recall, other than this, ever giving out a scholarship.
[2:06:18]So saying that HBRK or Richard Kahn gives out scholarships is not accurate.
[2:06:24]What I understood was that HBRK was funded, as I testified earlier, usually we were funded for one year in advance.
[2:06:35]So, for example, if the annual budget for HBRK was $900,000, we would earn $75,000 a month times $12,000 was $900,000.
[2:06:47]So Epstein, at times, thought that HBRK was sitting with unearned revenue.
[2:06:53]At times, Epstein would ask HBRK to pay an expense out of the unearned revenue.
[2:06:59]On occasion, HBRK paid an expense.
[2:07:02]This, to me, was one example of him looking to pay for education for a woman attending finishing school in Switzerland.
[2:07:10]Okay, I want to introduce Exhibit D, which is emails between Mr. Kahn and another redacted individual from September 14, 2017 with the subject Lyon or Guion Forms.
[2:07:25]As you can see, Mr. Kahn, this email exchange takes place the day after the one we previously discussed, presumably from the same center, the same redacted individual, discusses scholarships, tuition, and visas.
[2:08:24]And Lyon is a university in Switzerland. Have you seen this email before today?
[2:08:29]I believe so.
[2:08:30]And you know who the sender is?
[2:08:33]I believe it's the same woman. Thank you.
[2:08:38]Perhaps, okay.
[2:08:39]And again, did you have any knowledge or understanding about Epstein's relationship with her? Does this jog your memory in terms of their relationship?
[2:08:51]I did not know Epstein's relationship with this woman.
[2:08:54]What I understood at the time was that Epstein wanted to pay for this woman's education.
[2:09:02]And from my perspective, at the time, this woman was attending a finishing and hospitality school.
[2:09:08]And it was something that HBRK had hired previously, a property manager to oversee his entities.
[2:09:18]And nothing with this transaction stood out to me or was alarming or implied sex trafficking.
[2:09:25]I'm going to hand it over to Mr. Kahn.
[2:09:28]I'll give you more time if I don't take it.
[2:09:31]Thank you, Mr. Kahn. Thank you for coming.
[2:09:35]Is it true that Jane Doe IV, the citation is Doe versus Jeffrey Epstein, 1, colon 19, CB 07675, Southern District of New York, received a financial settlement directly from the estate as her attorney as clerk?
[2:09:53]I'm sorry. I don't know who Jane Doe IV is.
[2:09:55]She's the person who has been widely described as alleging that President Trump raped or abused her when she was 13 in the 1980s.
[2:10:06]And her attorney is out there has said that she received a settlement from the estate.
[2:10:14]Congressman, may I just tell him who Jane Doe IV is?
[2:10:16]Yes.
[2:10:17]Refreshes it.
[2:10:21]Okay. I believe I understand who you're referring to. If you don't mind, may you please repeat the question?
[2:10:27]Is it true that she received a financial settlement directly from the estate? Her attorney said that she has.
[2:10:32]I believe that Jane Doe IV received a settlement via mediation with the estate, I believe in 2025.
[2:10:42]And her attorney saying she received that settlement because she was a victim of Epstein and President Trump. Is that accurate?
[2:10:48]I don't recall the mediation statement or the lawsuit in particular, but I don't have recollection of President Trump.
[2:11:00]I know that she alleges that Epstein abused her, but I don't recall President Trump.
[2:11:09]Then I guess it would only be the mediation statement that would be.
[2:11:12]I believe she filed a lawsuit. So there was a complaint, which I believe is public.
[2:11:16]So if I'm not speaking correctly, we can look at the complaint and see if she makes that allegation.
[2:11:23]But I don't recall from the mediation statement that I don't even actually now I'm thinking about it.
[2:11:30]I don't know if she made a mediation statement, so I don't have any recollection of her making allegations against President Trump.
[2:11:37]And do we know why she was ineligible to receive the compensation from the Epstein Victims Compensation Program?
[2:11:45]The Epstein Victims Compensation Program, in my view, was a great success.
[2:11:52]And I'm very happy that that was the first thing I did as co-executor to set up that program.
[2:11:58]There were 136 claimants that were paid over 121 million dollars.
[2:12:04]But there were also many individuals that were deemed ineligible for compensation.
[2:12:11]I believe what you're implying is she was deemed ineligible for compensation.
[2:12:16]With the Epstein Victims Compensation Program as co-executors, we wanted to have no involvement.
[2:12:22]We said that the program could pay out unlimited funds from the estate. There was no limit to any award.
[2:12:29]Jordi Feldman, who ran the Victims Compensation Program, did not share with us the individual's packets that they submitted with their allegations against Epstein and or the estate.
[2:12:40]So I don't know. I never saw the packet.
[2:12:43]The only information we received as co-executors were the individual's names and the award that they received or a list of individuals that were deemed ineligible.
[2:12:55]The last point, and so I just to get on the record, Jane Doe did get a settlement.
[2:13:01]You don't know anything beyond it, but she was given a settlement.
[2:13:05]There are some people who have said, oh, this is all a hoax.
[2:13:08]The survivors obviously say they're over a thousand survivors.
[2:13:12]Given your situation, would you say it's fair to say that there are hundreds of women who were abused or raped or trafficked?
[2:13:21]And would you say that there are more than Epstein and Maxwell that were involved?
[2:13:27]I don't agree with the statement that there are a thousand plus survivors.
[2:13:32]My understanding is that the Epstein Victims Compensation Program gave out awards to 136 women.
[2:13:39]The estate then settled mediation or individually with another 59 individuals, which I believe is 195.
[2:13:52]I believe and there's allegations that maybe there's another 50 women out there in my belief.
[2:14:00]So I'd say the number is probably somewhere in the 250 range, not 1,000.
[2:14:04]Would you say it's fair to say that there were other men involved either in trafficking, raping, abusing or participating in the abuse of these girls other than Maxwell and Epstein?
[2:14:14]I can't speak for what other men did.
[2:14:17]I could only speak as co-executor.
[2:14:19]I don't see any lawsuits against the estate that I'm now tasked with reading and trying to understand.
[2:14:26]But I can say to you that in some of the settlements that were made, as well as the Epstein Victims Compensation Program,
[2:14:35]women were allowed to have carve outs from their release.
[2:14:39]And there were a number of carve outs from both the Epstein Victims Compensation Program and the mediation.
[2:14:47]What does that mean?
[2:14:48]What the carve out means when we set up the Epstein Victims Compensation Program, we set up a very broad release.
[2:14:57]And the thought process as fiduciaries and co-executors was that we did not want to settle with a woman for her to then turn around and sue another employee or someone who was a contractor or affiliated with the estate.
[2:15:11]So at the time when we were negotiating the release, David Boyce was involved in that conversation.
[2:15:18]And we at first he was against a broad release.
[2:15:21]And when the estate and Geordi Feldman and Ken Feinberg all decided that the estate was going to give out larger rewards because the release was a little broader, he agreed to the release.
[2:15:32]But what I'm saying is that the carve out would be if this plaintiff's attorney or if this victim was unsure of whether or not this person was covered by the release.
[2:15:45]They wanted that name to specifically say this release does not cover this individual.
[2:15:50]There were other men involved based on that.
[2:15:52]I'm not making allegations.
[2:15:54]Women wanted to have other names carved out.
[2:15:58]I'm not making any statements that other men were involved.
[2:16:02]I'm not aware of what went on.
[2:16:04]Thank you.
[2:16:05]We'll end the minority round here.
[2:16:06]We'll go off.
[2:16:07]We'll go back on the record.
[2:16:24]Mr. Khan and 102 PM.
[2:16:29]Mr. Khan, towards the end of the last hour, there were discussions about the estate settlement fund for victims and survivors of the crimes of misdemean and it was mentioned that there were carve outs for other individuals.
[2:16:48]Could you please inform us of who those individuals are that were carved out?
[2:16:54]Yes, my recollection is that from the Epstein Victims Compensation Program.
[2:17:02]I'm aware of two carve outs.
[2:17:04]There may have been a few more, but these are the two that I'm aware of.
[2:17:07]One was Alan Dershowitz and the other carve out was Prince Andrew.
[2:17:16]Regarding the mediation, there were two additional carve outs.
[2:17:22]One was Leon Black and the other was Jess Staley.
[2:17:32]And just for clarity, could you briefly explain what these individuals, what it means that these individuals were carved out?
[2:17:43]Yes.
[2:17:44]So when I was alluding to the release from the estate's perspective as fiduciaries, us wanting as broad a release as possible because we did not want an individual that worked for Epstein or someone that may have been indemnified to later come back to us for legal fees.
[2:18:02]We wanted as much coverage as possible so that we could have finality.
[2:18:08]The victims that chose to carve out these individuals, I don't believe were meant to be covered, but maybe they were.
[2:18:17]I think that the individuals wanted there just to be 100% clarity that these individual names that were carved out were not part of the release.
[2:18:27]Understood.
[2:18:29]Switching gears a little bit now.
[2:18:32]At HBRK, Harry Beller was a part of that entity, is that correct?
[2:18:37]Yes.
[2:18:38]And Mr. Beller, I believe you testified earlier, his role was that he handled a lot of the derivatives and investment accounts for Mr. Epstein, is that correct?
[2:18:48]Yes.
[2:18:49]And when did Mr. Beller leave HBRK?
[2:18:55]I believe Mr. Harry Beller left employment in May of 2014.
[2:19:04]And do you know why Mr. Beller left in May of 2014?
[2:19:09]As I testified earlier, I believe to the minority, Mr. Beller was predominantly involved in working on investments for Les Wexner and in addition to Epstein.
[2:19:26]But at the time, from 2000, I don't recall the exact date when Mr. Wexner and Epstein terminated their relationship, but let's just say approximately 2008, the amount of transactions and volume that Mr. Beller was working on had slowed down.
[2:19:43]So at that point in time, Epstein was just working predominantly on, I'm sorry, at that point in time, Mr. Beller was working just on Epstein stuff and there was not a lot of work.
[2:19:54]And Epstein did not think that he was getting good value for paying Mr. Beller's compensation package and decided that he was going to no longer pay for his services.
[2:20:07]And you mentioned that the business relationship between Mr. Wexner and Mr. Epstein ended in the 2000s. You didn't say you didn't know exactly when that was.
[2:20:28]Do you know why that relationship ended?
[2:20:31]I do not know why it ended.
[2:20:33]And whose decision was it for Mr. Beller to no longer be employed with HBRK?
[2:20:42]It was Epstein's decision.
[2:20:46]And was that decision to terminate Mr. Beller, was that decision made with you?
[2:20:54]I was not part of the decision. I would have liked Harry Beller to stay employed and continue to work together. It was Epstein's sole decision.
[2:21:04]And at that point, how did your role change after the departure of Mr. Beller?
[2:21:09]Well, as I testified earlier, Mr. Beller was working on clients investments and stocks and options derivatives and doing the accounting for it, as well as tracking Epstein's assets and investments.
[2:21:23]The accounting work that continued thereafter was not work that I took on. Another accountant for Epstein did that work.
[2:21:31]What I picked up from Mr. Harry Beller's work was I was involved with tracking Epstein's stocks and bonds and reporting to him on a monthly basis the value of those assets.
[2:21:44]And who was the other accountant that picked up the lion's share of the other work?
[2:21:52]A woman by the name of Jeannie Brennan, who worked out of the St. Thomas office.
[2:22:03]Are you aware of how long Ms. Brennan worked for Mr. Epstein?
[2:22:06]I don't recall how long she worked. I know that in 2005, when I began working for New York Strategy Group, she was already working for Epstein.
[2:22:20]And was there any type of agreement when Mr. Beller left HBRK that governed his departure from the entity?
[2:22:36]I believe he received a severance payment. Maybe he was on salary for a period of time. I don't recall the amounts or the details of that severance.
[2:22:48]Was the entity, did you take sole ownership or management of the entity at that point?
[2:22:55]At that point in time, I believe the year was 2014. When we filed our tax return for the 2014 tax year, I was the 100% owner of HBRK.
[2:23:09]How did HBRK's business change with the departure of Mr. Beller?
[2:23:17]I don't think it changed much because the majority of the work that Beller was focused on had already diminished over the years with Mr. Wexner no longer being a client of Epstein's.
[2:23:34]So, as I said before, I picked up a portion of it and Jeanne Brennan picked up a portion, but HBRK still continued to do accounting and bookkeeping services on behalf of Epstein and a number of his other entities.
[2:23:49]And how well would you say that you know Mr. Beller?
[2:23:57]At the time that we worked together, we had both a personal and work relationship.
[2:24:05]By personal relationship, what does that mean?
[2:24:08]That we might see each other outside of work.
[2:24:12]Social events, things of that nature?
[2:24:15]I only recall one or two circumstances, but we were friendly and we are both Jewish.
[2:24:22]So during certain Jewish holidays, we wish each other a Happy New Year or, you know, speak along those lines.
[2:24:28]So I only remember one or two events outside of work, but we had a friendly relationship more than just coworkers.
[2:24:35]Do you still have a relationship with Mr. Beller?
[2:24:37]Unfortunately not.
[2:24:39]You say unfortunately not. Why do you still not have a relationship with Mr. Beller?
[2:24:45]Because when I took on the role of co-executor, there were many lawsuits that occurred and I believe that Harry Beller was subpoenaed and part of it just made it a little challenging for us to continue to communicate.
[2:25:07]Reporting indicates that Mr. Beller made some large cash transactions over a series of months towards the end of his employment with Mr. Epstein. Are you aware of Mr. Beller's large cash transactions?
[2:25:28]I'm aware that Mr. Beller had signatory authority for Epstein's accounts at JP Morgan and then Deutsche Bank.
[2:25:37]And I'm aware that Mr. Beller withdrew cash at times. I'm not familiar with any particular transactions.
[2:25:47]Reporting indicates, based off legal documents in the 2022 U.S. Virgin Islands lawsuit against JP Morgan, that under the span of 18 months, there were checks cashed for approximately $800,000. Are you familiar with that figure or that occurring?
[2:26:07]I'm not familiar with the figure, but could you repeat the time frame that it was reported? $800,000, please?
[2:26:14]It was around the time of Mr. Beller's departure from HBRK, so I believe that would be 2014. These figures were found out as part of the 2022 U.S. Virgin Islands lawsuit against JP Morgan.
[2:26:28]And the SARs that were unsealed as part of that case showed that in under 18 months, Mr. Beller had cash checks for approximately $800,000.
[2:26:40]I'm not aware of any particular amounts, but I could testify that that amount seems abnormal to me. I don't recall ever having $800,000 of cash over an 18-month period.
[2:26:56]Between the years of 2013 and 2014, so towards the end of Mr. Beller's working arrangement at HBRK, he sent checks in the value of tens of thousands of dollars, signed by himself to members of his family.
[2:27:32]Are you aware of who is? I don't know who is. Are you aware of who is? It might be one of his children. I'm not sure. Are you aware of who is? I believe that's Harry Beller's son.
[2:27:55]Are you aware of who is? I'm not aware. Are you aware of who is? I'm not aware. Are you aware of who is? I'm not aware. Are you aware of any of the transactions made by Mr. Harry Beller to his family members between the years of 2013 and 2014?
[2:28:26]I believe these transactions were made. I'm not familiar with the specifics. The only way I would have seen these transactions would have been on the gift tax reporting. But sitting here today, I don't recall what we reported. You said 2013?
[2:28:45]2013 to 2014. I don't recall the specifics of those gift tax reports, but if I would have seen those checks, they would have been quoted to gifts, and we would have recorded them if they were over the annual gift tax amount.
[2:29:02]Would you have approved these checks? No, I was not in position to approve any checks.
[2:29:09]Do you have any understanding of why Mr. Beller may have sent checks to individuals within his family from Epstein-related entity accounts?
[2:29:27]I don't have any understanding of why Mr. Beller would have sent those checks. However, I can say that in all my dealings with Harry Beller, he was an honest and straight forward person, so my presumption would be that he had Epstein's approval to send those checks and did not do it in a fraudulent or improper fashion.
[2:29:50]As the personal accountant to Mr. Epstein, were you aware of the frequent cash withdrawals made by Epstein-related entities?
[2:30:15]I'm aware that when Harry Beller was a signatory, he withdrew cash. I don't recall the frequency. And when Harry Beller was no longer working, that Darren Endype withdrew cash.
[2:30:37]Sorry, just to be clear, you said Darren Endype would withdraw cash?
[2:30:41]When Harry Beller was no longer working for Epstein. Darren Endype, I believe other than Epstein, was the only signatory on his accounts, so Darren Endype would withdraw cash from Epstein's accounts.
[2:30:56]Were these cash withdrawals reflected in your accounting records?
[2:31:02]Yes, every withdrawal would be recorded in Epstein's books and records.
[2:31:06]And how would those be categorized?
[2:31:10]When the money would come out of cash, it would go from cash to petty cash. That would be the journal entry for the books and records.
[2:31:22]Who would instruct, whether it be yourself or another member of HBRK, who would instruct someone to facilitate providing cash to another individual?
[2:31:45]From the accountant's perspective, we track the cash. So when the cash came, it was put in a safe, and we were recorded on Epstein's books and records.
[2:32:01]As far as dispersing cash, the approvals would come from Epstein. For example, if a property manager wanted or needed $2,000 or $3,000 cash to pay tips to buy groceries, to pay for dry cleaning, they would come to the office and they would sign out a slip that said $2,000 petty cash.
[2:32:28]We would then set up a sub-account for that individual. Let's just say in this example it was Richard Barnett, $2,000 petty cash. He now is accountable for that $2,000 petty cash.
[2:32:40]And if he ever wanted to receive another dollar of petty cash, he needed to bring back receipts for how he spent that money.
[2:32:47]Now, he might come back to us after spending $1,600 with a $400 balance and say, can I have another $1,000 or $2,000 in petty cash? And provided that he had receipts, he would then receive more petty cash.
[2:33:02]And at any given time, how much cash was kept in the safe at HBRK?
[2:33:07]I did not handle the petty cash, so I don't recall the amounts, but I'd say somewhere in the range of $20,000 or $30,000.
[2:33:15]Would you also provide cash for Mr. Epstein to keep in his New York townhome?
[2:33:27]Epstein would request cash. And for a period of time, when I met with Epstein, I believe I testified earlier that we used to have meetings at Epstein's townhouse, and it was usually a group of us that would attend.
[2:33:43]And then as individuals were no longer working for Epstein, for example, Emad Hanna or Harry Beller, the group got smaller.
[2:33:50]So for a period of time, I was asked when we would come from HBRK office to bring Epstein cash.
[2:33:57]And he was given the cash, but I don't know if Epstein used the money and spent it.
[2:34:07]I would see him every three weeks, so I don't know if that was spending money for three weeks or if he put it in his safe. I don't know what he did with the cash.
[2:34:15]Is there a certain increment of cash that you would often supply Mr. Epstein with when you would meet with him at these three-week intervals?
[2:34:25]The amounts that I recall from the last few years of working for Epstein was typically $6,000 that I would bring him approximately every three weeks.
[2:34:38]Is there a reason or rationale for the $6,000 figure?
[2:34:42]That was what was either requested and communicated to me from Epstein directly or from Leslie Groff.
[2:34:48]Would you personally provide that cash over to Mr. Epstein?
[2:34:55]If I were visiting him, I would bring it.
[2:35:01]If Epstein were in town and I were not seeing him because I didn't have a need to see him or I was on vacation,
[2:35:08]maybe his driver Jojo or his house manager would pick it up or one of his assistants.
[2:35:14]But I saw Epstein on a fairly regular basis, so the cash would be withdrawn from the safe from Bella Klein.
[2:35:24]She would then give it to me, and when I met with Epstein, I would give it to him.
[2:35:28]Did you ever provide any cash to any woman or girl during your time working for Mr. Epstein?
[2:35:39]I was not involved in petty cash, and I could probably count on the number of times on one hand that I would open the safe.
[2:35:50]I didn't know the combination by heart, so I had it written down.
[2:35:56]I didn't want to be bothered with opening the safe.
[2:35:58]But probably in my 14 or 15 years, one or two handfuls of times, I needed to go into the safe for one reason or another.
[2:36:07]I don't recall if I was giving the cash to property managers or to women or to pilots or to Epstein,
[2:36:15]but I can tell you that I did go in the safe about five or 10 times over my 14 years.
[2:36:21]Did you ever witness Ms. Klein providing cash to young women or girls?
[2:36:30]Many individuals would come, as I said, property managers, pilots, assistants.
[2:36:38]On occasion, I did see Ms. Klein provide cash to these individuals I just mentioned, but I never saw Ms. Klein give cash to a minor.
[2:36:50]Did any of the women or girls Ms. Klein provided cash to surprise you at all?
[2:37:00]Well, most of the women that came for cash were typically Epstein's assistants,
[2:37:08]so I was somewhat familiar with them from sending them payroll records to fill out W-4
[2:37:15]and their documentation for health insurance if their entity provided.
[2:37:19]So I knew most of the assistants that came into the room that requested petty cash.
[2:37:26]And which assistants? Can you provide their names for us, please?
[2:37:31]I can provide names of assistants, but I can't, for my recollection, recall a particular instance where I saw a woman come in.
[2:37:39]I have no specific memory of an instance where someone came in, but I can recite assistants' names,
[2:37:44]but I can't tie that to them coming and withdrawing petty cash.
[2:37:49]I also would like to say that there was, when I was talking about when we worked together,
[2:37:59]Bella Klein and I, the first four and a half years we were in a large office together,
[2:38:04]the four of us had individual desks, and I was at one end and she was at the other,
[2:38:08]so I might not always see if someone came in.
[2:38:11]For the two years that we were together at 301 East 66th Street, we did not, I'm sorry, we did share an office,
[2:38:19]so it was likely I could see people coming in there.
[2:38:23]But thereafter, from I believe May 2012 until Epstein's incarceration, we did not share an office.
[2:38:30]Do you know why Mr. Epstein needed access to so much petty cash?
[2:38:44]Well, Epstein used petty cash for many reasons.
[2:38:50]First, as I alluded to earlier, the property managers requested petty cash for expenses relating to the home,
[2:39:00]but the petty cash needs that I recall were magnified after J.P. Morgan dropped Epstein as a client
[2:39:12]because J.P. Morgan supplied credit cards, I believe master and visa cards for Epstein,
[2:39:20]and the only other card that Epstein had at the time was American Express.
[2:39:25]For a lot of vendors back in 2013 and 14, they didn't always accept American Express,
[2:39:32]so it was difficult for us to obtain new credit cards,
[2:39:38]more than when we had credit cards from my understanding.
[2:39:42]But the property managers used it for expenses relating to the house,
[2:39:47]whether it was groceries at one point in time, I know we had a chef that withdrew a lot of cash to buy food that was prepared.
[2:39:55]The assistants used it for shopping errands as well as for buying stuff on behalf of Epstein.
[2:40:03]Our office used petty cash for if someone was going out and buying office supplies or meals,
[2:40:10]and the pilots used it predominantly for travel and for tipping.
[2:40:15]And you mentioned that it was difficult for Mr. Epstein to obtain new credit cards. Why was that?
[2:40:23]It was after J.P. Morgan dropped him.
[2:40:28]I believe he had a difficult time obtaining credit cards due to his prior conviction or pleading, I'm sorry, of soliciting a minor for prostitution.
[2:40:42]Are you aware that there is a pattern of withdrawals of cash for exactly $9,800?
[2:40:54]I was not aware of the amounts or the cadence of withdrawals. I was not involved in the process.
[2:41:01]You didn't review any type of statements that would show withdrawals and withdrawal amounts?
[2:41:08]The QuickBooks file had every transaction recorded, so it was in the QuickBooks file, but it was just not an area that I worked on.
[2:41:17]With Epstein's personal QuickBooks file, the two or three things that I was focused on was picking up any income or deductions that would relate to his personal tax return
[2:41:29]and picking up his gifts that would need to be reported on separate gift tax returns.
[2:41:35]Isn't it possible that some of the cash used by Mr. Epstein was for some sort of deductible reason?
[2:41:56]Deductible? No. The petty cash, again, the assistance, if they went to a store and bought him a sweater, that's not deductible.
[2:42:10]If they bought groceries for his home, that's not deductible. If the pilots were traveling, none of his aviation was ever, we never took business expenses on any of his aircraft, so that was not deductible.
[2:42:24]HBRK's office expense, that could be a potentially deductible expense at our level, but not for Epstein.
[2:42:32]It was all related to personal items, so I don't believe that anything relating to petty cash was deductible or relatable to his personal tax return.
[2:42:43]Would he not use petty cash as a way of providing a gift to someone?
[2:42:48]Well, thank you. That's a good point. Yes, if he gave cash to someone, thank you for the clarification.
[2:42:56]If he gave cash to someone and we didn't know what it was for, he may give cash to someone and say rent.
[2:43:03]If he was paying that individual's rent, it would go in the gift tax reporting.
[2:43:07]If he gave petty cash to an individual and said reimbursement for a sweater you bought for Epstein, that would go on Epstein's personal stuff.
[2:43:14]But thank you for the correction. Yes, if a gift was given in cash, it would go on his gift tax reporting.
[2:43:21]So because any gifts provided by Mr. Epstein in the form of cash or cash compensation, you would need to know what the use for that cash was ultimately, correct?
[2:43:41]No. If we had proper coding, again, if it was for a woman's rent, if it was for buying a sweater for a woman, if it was meals, if he was paying for taxis or for transportation,
[2:44:00]we had an explanation and if it didn't relate to Epstein, it got reported in the gifts.
[2:44:06]But if Epstein gave a woman or a man a gift and it says said $3,000 cash and we did not receive an explanation,
[2:44:16]we took the conservative approach and put it in his gift tax reporting because we did not get back up for what it was for.
[2:44:24]And going back to the $9,800 number, are you aware of who would have made the decision to withdraw that amount of cash from an account?
[2:44:47]I was not, as I said before, I was not a signatory and I was not involved in the withdrawal of cash from the banks.
[2:44:58]Right, but that doesn't mean that you wouldn't have any idea of who was making that decision.
[2:45:03]I didn't make that decision, no.
[2:45:04]Did you know anyone who did or do you know who did?
[2:45:07]I don't know who made the decision.
[2:45:08]You never asked?
[2:45:09]No. I wasn't involved in the cash withdrawal process so it didn't cross my realm of work.
[2:45:18]I wasn't involved and I didn't know why an amount was taken out of $9,800.
[2:45:24]I mean it's not an amount that sounds familiar to me.
[2:45:28]I remember there were $7,500 withdrawals but I don't recall $9,800 withdrawals.
[2:45:34]And no, I was not involved in the process.
[2:45:38]Could you list out for us the individuals that were signatories or could decide on withdrawing cash from accounts?
[2:45:45]The signatories, do you want to refer to a specific time period or just generally speaking?
[2:45:52]I think generally speaking across all of your years of employment with Mr. Epstein.
[2:45:56]So the signatories were as follows.
[2:46:00]Epstein, Maxwell, Harry Beller, Darren Endyke.
[2:46:13]And I believe that that was it.
[2:46:15]What are the signatories?
[2:46:17]For example, I believe on some of the aviation checking accounts.
[2:46:22]Some of the pilots had signatories already and I believe on some of the households.
[2:46:27]For example, in New Mexico, I believe we had what we would call local accounts.
[2:46:33]And in Florida as well where some of the property managers would be able to write checks up to a certain amount so they did have check writing authority.
[2:46:43]Could Bella Klein withdraw cash?
[2:46:45]No.
[2:46:47]Are you aware of what the reporting threshold is for cash withdrawals?
[2:46:52]No, the only thing I do know is when a large amount is taken out, you need to sign paperwork, but I don't know what that amount is.
[2:47:01]You're not aware of a $10,000 figure being an amount that sends flags and reports to the Department of the Treasury?
[2:47:08]No, I'm not aware.
[2:47:10]You think it's suspicious that $9,800 was consistently withdrawn out of accounts related to Mr. Epstein?
[2:47:17]I can't make judgment. I wasn't involved in the process, you know, nor do I work for the Treasury Department, so that's something for them to decide, but I don't have judgment on that.
[2:47:27]I understand, but I mean, you're an accountant. You've been an accountant for, you know, some 20-odd years now.
[2:47:37]I think it would be strange to not know what the reporting limit was and if consistent figures pulled under that reporting limit didn't raise any flags for you personally.
[2:47:49]I think he said that he wasn't aware of that because that wasn't, excuse me, his realm of responsibility.
[2:47:55]So if you want to ask him, were you aware that $9,800 was taken out once, twice, or however many times, that may be a useful question because I think he can answer that.
[2:48:08]Were you aware of any banks raising suspicions to you about the amount of cash withdrawals that Mr. Epstein's accounts were faced with?
[2:48:15]No, I do recall that there were transactions that both JP Morgan and Deutsche Bank asked about certain transactions, but I never recall hearing anything from the banks regarding cash withdrawals.
[2:48:33]And what transactions would those be?
[2:48:39]I believe that Deutsche Bank, I don't recall the specific transactions, but I know one or two times they would send an email and say, you know, could you please give us a description for what the following wires or payments relate to?
[2:48:58]And would you always provide a description?
[2:49:00]Yes, when I would receive an email like that, the first thing I would do is look to the general ledger and see if I knew what it related to.
[2:49:10]I know one of the times, I believe Deutsche Bank asked, it was a Spanish name, and they said, what does this transaction relate to?
[2:49:19]And when I looked at the books and records, I found out that related to a payment for work on Epstein's barge down in the U.S. Virgin Islands.
[2:49:30]So if I found out that information, I would note it and then send it along to Epstein and say, here's four transactions.
[2:49:38]I know the first one relates to a barge.
[2:49:40]Could you please explain what these other transactions relate to?
[2:49:43]And he would provide me with backup for what those transactions related to.
[2:49:48]Did you ever think any of the explanations for those transactions were suspicious in any way?
[2:49:55]No. Typically, he would say, I know a couple that come to mind, he said it was for school or it was a loan or to a friend, but nothing deemed or seems suspicious to me, no.
[2:50:18]Looking back with your knowledge as you sit here today, do any of these payments or withdrawals concern or raise flags for you now?
[2:50:29]Yes, 100 percent. Looking back with what I know today as co-executor, I should never have trusted Epstein on anything, he said.
[2:50:39]So I regret many decisions I made and having trust in his explanations to me, knowing what I know now and all the terrible things he did to so many innocent women.
[2:50:54]Switching gears a little bit here.
[2:50:58]What was your compensation for your role with Mr. Epstein in 2010?
[2:51:04]I don't recall a particular year of compensation.
[2:51:09]I was paid by New York Strategy Group and then I was paid by HBRK and my W-2 was approximately $180,000 to $250,000 during the years I worked for Epstein.
[2:51:27]Years you worked for Epstein. So your base salary was the same from 2010 until 2019?
[2:51:35]No, my base salary maybe went up $10,000 or $15,000 a year along with the bonus potentially, yes.
[2:51:42]And how much typically would your bonus be?
[2:51:44]It might be somewhere from $10,000 to $20,000.
[2:51:48]I was going to say, as I mentioned to you, I started in 2005 and I might have started at $180,000 I think I testified and I believe that was the right amount, but within two years my salary went down 10%.
[2:52:06]So then it started going up from that amount that it went down to.
[2:52:09]Understood.
[2:52:11]And outside of your base salary and your bonuses, did you receive any other forms of compensation or remuneration from Mr. Epstein?
[2:52:22]My entity HBRK paid health insurance and I believe Epstein one time paid a medical bill for me on my behalf as well as at times I received tuition assistance.
[2:52:42]For your children?
[2:52:43]For my children, thank you.
[2:52:44]That was my next question.
[2:52:45]Thank you.
[2:52:49]In 2019, what was your total compensation?
[2:52:53]2019 was the one year that my W-2 was not in that range of $180,000 to $250,000.
[2:53:07]In 2019, Epstein had prepaid for services for the entire year and HBRK was a C corporation.
[2:53:22]So with a C corporation any income at the end of the year is taxed at 35%.
[2:53:29]So at the end of that year we had a large amount of income and based on advice from my accountant I said, you know, what's the best way to handle this?
[2:53:38]Should we have the corporation pay the tax?
[2:53:41]And then if we want to take it out we'll be taxed again as a W-2 and he said the best and most tax efficient way is for you to take that additional earned money in your W-2.
[2:53:52]So in 2019 I think my W-2 was approximately $600,000 in change.
[2:53:58]And in 2019 were there any other forms of compensation?
[2:54:08]Not that I'm aware of.
[2:54:11]Did you receive any gifts from Mr. Epstein on a yearly basis?
[2:54:18]I never received a gift from Epstein.
[2:54:21]Did you receive any loans from Mr. Epstein?
[2:54:24]Yes, I received loans from Epstein over the years that I worked for him.
[2:54:30]Just one loan, multiple loans?
[2:54:32]Probably three or four.
[2:54:35]What was the purpose for those loans?
[2:54:38]Epstein treated these loans for me and probably 10 other employees as retention bonuses.
[2:54:47]He was giving loans to us similar to the way that a brokerage firm would sign on and bring an individual in.
[2:54:58]They would give a loan to a new employee.
[2:55:01]But these loans were typically nine-year loans and each year annual interest was paid on the loans.
[2:55:15]And the loans had two outcomes.
[2:55:18]The two outcomes were one, either Epstein would forgive the loan and we would have to pick up forgiveness of debt income.
[2:55:29]Or two, Epstein would ask for the loan to be repaid.
[2:55:35]And what was the interest rate you received on these loans from Mr. Epstein?
[2:55:42]The loans I believe at the time were the midterm AFR rates.
[2:55:49]And you mentioned there were three or four of them.
[2:55:53]Yes.
[2:55:54]What years primarily were these loans in?
[2:55:56]Somewhere in the 2014-15 range to maybe 2019.
[2:56:05]And what was the total amount of those three to four loans, grand total?
[2:56:11]Approximately three million dollars.
[2:56:13]And how many of those loans were forgiven by Mr. Epstein?
[2:56:18]While Epstein was alive, none of the loans were forgiven.
[2:56:22]The loans were being, the loans had interest being paid each year.
[2:56:27]And none of the loans had ballooned or matured while Epstein was alive.
[2:56:33]When Epstein died and the estate attorneys reviewed his trusts and his will, his estate, I'm sorry, his trust.
[2:56:45]Don't say what the attorney said.
[2:56:47]You can say, if they have questions about it, you can explain things, but you don't explain.
[2:56:52]The trust had forgiveness of debt provisions in it.
[2:56:57]So how much total debt was forgiven for you?
[2:57:04]I don't know technically when the debt is forgiven.
[2:57:10]I believe we still carry the loans on the books and records.
[2:57:14]I believe that it will be forgiven from a technical perspective when the estate is finally at a probate.
[2:57:23]And at that point in time, the estate's closed and then the trust is the operative document.
[2:57:28]So I don't believe anything at this point has been forgiven.
[2:57:34]But I believe that if a loan was forgiven while someone was alive, there would be forgiveness of debt income.
[2:57:42]And if it's part of a trust document, there is not forgiveness of debt income.
[2:57:47]And so to be clear, you are still paying off those loans.
[2:57:53]When Epstein died, I was continuing to pay interest on those loans.
[2:57:58]And that's when advice of counsel said...
[2:58:01]Don't say what it said. It stopped.
[2:58:03]It stopped, thank you. Payments stopped based on what the trust provisions had in them.
[2:58:09]So when the estate is finalized and through probate and the trust is final, how much do you stand to gain from those loans?
[2:58:26]I don't think I'm going to gain anything. I think the loans just will not be repaid.
[2:58:30]And I believe I said that the loans were approximately $3 million.
[2:58:37]So how much debt do you currently have to the estate?
[2:58:43]I think it's approximately $3 million, yes.
[2:58:49]Did you receive any compensation from any financial investments from Mr. Epstein?
[2:58:57]Financial investments?
[2:59:02]When you say financial investments, I'm not sure what you mean, but I don't... did I receive... I don't know how I received...
[2:59:13]Did you invest with Epstein?
[2:59:16]I never invested with Epstein. There was... I never invested with him.
[2:59:21]There was one deal that he invested in that I also invested in, which was a debt deal where an entity was buying debt, I want to say, for two or three cents on the dollar.
[2:59:36]And they were trying to sell it for 15 to 17 cents over a five to seven year period.
[2:59:46]But I personally wrote out an investment. I personally used my own money to invest in that. He didn't make that investment on my behalf.
[3:00:00]Did you ever receive any ownership stake in any Epstein-related company or entity?
[3:00:05]Not that I'm aware of, no.
[3:00:20]Notwithstanding the final trust of Mr. Epstein, I believe it's called the 1953 trust,
[3:00:30]Mr. Epstein had a number of other trusts, is that correct?
[3:00:34]Yes.
[3:00:35]And do you... did you receive any disbursements of money from any of those trusts?
[3:00:44]Yes.
[3:00:45]And how much?
[3:00:47]I believe it was a few million dollars.
[3:00:50]A few million as in three million, five million?
[3:00:55]I don't recall the exact amount.
[3:01:01]And how many different trusts did you receive disbursements from?
[3:01:06]Just one trust.
[3:01:08]What trust is that?
[3:01:10]It's the 2013 Butterfly Trust.
[3:01:19]This was in addition to your salary?
[3:01:27]That was a distribution that was, yes, in addition to my salary.
[3:01:32]Do you want to give the time? That was after Epstein's death, was it not?
[3:01:36]It may have been. I don't recall.
[3:01:44]Are you aware of the other beneficiaries to the 2013 Butterfly Trust?
[3:01:48]No, I am not.
[3:01:51]And what was the money for as part of that trust or what was the rationale for that trust?
[3:02:09]Just so I understand your question, you're asking what was the purpose of why I received this distribution
[3:02:13]or what was the purpose of why the trust had money?
[3:02:15]I guess it's two questions.
[3:02:17]First one being why did the trust have money?
[3:02:21]And then the second question would be why did you receive the disbursement?
[3:02:25]I believe that the 2013 Butterfly Trust was a pour-over trust
[3:02:29]that Epstein made an investment maybe through a grant or through another trust,
[3:02:37]and this was some of the proceeds from the sale of that investment.
[3:02:41]And the second part of your question is I was a beneficiary of that trust.
[3:02:48]I was never told why I was a beneficiary, but I was one of many beneficiaries of that trust.
[3:02:58]Did you ever use the funds provided to you from the 2013 Butterfly Trust
[3:03:04]to pay off any victims or survivors of Mr. Epstein's crimes?
[3:03:08]No.
[3:03:21]Were you a trustee or administrator on any other trust,
[3:03:25]not including the 2013 Butterfly Trust or the 1953 trust?
[3:03:31]I just want to clarify.
[3:03:32]I received a distribution from the 2013 Butterfly Trust,
[3:03:36]but at one point in time I believe when that trust was created I was a trustee.
[3:03:41]So my role changed from being a trustee to later being one of the beneficiaries.
[3:03:48]When were you a trustee of the Butterfly Trust?
[3:03:50]I believe when it was originated, which based on the name of the trust was probably 2013.
[3:03:58]When did you officially become a beneficiary?
[3:04:00]I don't know.
[3:04:04]I believe the second part of your question was I a trustee on any other trust.
[3:04:09]I was a trustee for a period of years for the Butterfly Trust.
[3:04:21]What year was that?
[3:04:22]I believe that I was a trustee for that trust from 2011 to either 2014 or 2015.
[3:04:35]I don't recall the specific dates.
[3:04:37]What was the purpose of that Butterfly Trust?
[3:04:40]I believe that too was a pour-over trust from an investment that Epstein made
[3:04:47]and it had proceeds from the profits of that original investment.
[3:04:53]Did you become a beneficiary of that trust?
[3:04:56]I don't recall, but I do know that I never received a distribution from that trust,
[3:05:05]but I don't recall if I was a beneficiary of that trust as well.
[3:05:08]I do know when I was a trustee you can't be a beneficiary,
[3:05:11]so maybe I was a beneficiary, but I don't recall.
[3:05:17]Are you aware of any other beneficiaries of that Butterfly Trust?
[3:05:21]Currently speaking, or previously.
[3:05:24]We'll say pre-2019 at this point.
[3:05:30]Yes, I do believe I know some names of individuals.
[3:05:37]Who are those individuals?
[3:05:39]I think I was a beneficiary.
[3:05:46]I think Sarah Kellan was a beneficiary.
[3:05:53]I think Karina Shulak was a beneficiary.
[3:05:56]I think Sue Hamlin was a beneficiary.
[3:06:01]I think a woman by the name of, I don't recall her last name, was a beneficiary.
[3:06:12]Epstein's pilots may have been, but I can't say with certainty.
[3:06:20]That's all I recall.
[3:06:24]Are you aware of how much money these individuals received in disbursements from this trust?
[3:06:32]I don't know any particular amount.
[3:06:38]I don't recall any particular amount,
[3:06:40]but I believe that over the course of the lifetime of that trust,
[3:06:45]I believe there was about a million dollars in disbursements.
[3:06:50]And just to be clear, were you a trustee or administrator of any other trusts already mentioned previously?
[3:07:08]Not that I recall. Epstein had other trusts.
[3:07:17]Many of them were unfunded.
[3:07:20]Some of his trusts owned title to some of his properties.
[3:07:25]But those are the two trusts that come to mind.
[3:07:28]And you mentioned that approximately a million dollars in disbursements were made from the Butterfly Trust.
[3:07:44]Are you aware of the total amount of funds that were held by that trust?
[3:07:52]Was it greater than the a million dollars that was dispersed?
[3:07:56]No, I believe that that trust has dispersed 100% of the assets and has since been dissolved.
[3:08:05]Just a minor point, but I think it's distribution as opposed to disbursement.
[3:08:09]Thank you.
[3:08:11]I'm not a trust and estate attorney, unfortunately.
[3:08:14]What is the COUQ Foundation?
[3:08:18]The COUQ Foundation was one of the foundations that Epstein formed.
[3:08:27]I don't know what the letters stand for.
[3:08:32]And that foundation was in existence prior to my beginning employment.
[3:08:39]And what did you understand the role of that foundation to be?
[3:08:44]I don't believe I was an officer or director.
[3:08:48]Maybe I was at the end. I don't recall.
[3:08:52]But I don't know what its administrative purpose was.
[3:08:55]But I know that it gave away disbursements to 501C3 charities.
[3:09:03]Which 501C3 charities?
[3:09:09]Many charities. I don't recall.
[3:09:14]Can you approximate the amount of money it dispersed to those charities?
[3:09:20]I don't know.
[3:09:23]I do recall seeing a tax return in the earlier years.
[3:09:27]The trust had over $10 million, but it was before my time, so I can't speak to specifics.
[3:09:33]But at one point in time, I believe it had $10 million in assets.
[3:09:38]Did you replace Ghislaine Maxwell as treasurer of the COUQ Foundation in 2007?
[3:09:46]It's possible. I don't recall.
[3:09:51]Understanding you can't recall the specifics, as we said here right now.
[3:10:00]Do you know why you would have replaced Ms. Maxwell?
[3:10:04]I don't know.
[3:10:36]You mentioned previously during this hour that
[3:10:44]knowing what you know now as co-executor of the estate
[3:10:51]with reviewing documents that you should have never trusted, Mr. Epstein,
[3:11:03]what exactly have you learned to make you feel that way or believe that?
[3:11:08]Well, as I mentioned earlier, I took the role as co-executor for three main reasons.
[3:11:15]One, I thought I was best suited to know Epstein's assets.
[3:11:19]Second, as we were going to be forced to liquidate his properties and terminate employees,
[3:11:28]I thought that I could do that in a proper and kind fashion.
[3:11:32]Many employees that I had friendships with over the years.
[3:11:36]And third, and most important, why I took the role is I thought that I would be able to,
[3:11:43]as co-executor, create a program that would compensate women for all the harms they endured by Mr. Epstein.
[3:11:51]With that in mind, the first thing I did even before I was co-executor
[3:11:58]was listen to a podcast by Ken Feinberg regarding alternative dispute resolution programs.
[3:12:05]And after listening to that podcast, I was convinced that setting up a compensation program
[3:12:11]for all the women that had been harmed would be the best way for them to receive compensation
[3:12:16]in a discreet, kind, and non-confrontational manner.
[3:12:20]So with that in mind, I took on the role.
[3:12:24]But as part of the role as co-executor, I was forced for the first time to read all of the lawsuits
[3:12:30]and allegations of what Epstein did to so many women.
[3:12:34]So I learned of all the harms that he caused.
[3:12:37]And at that point in time, I thought I was able to act and help compensate these women.
[3:12:42]Notwithstanding reading lawsuits or complaints or any other variations thereof,
[3:13:01]is there anything else that you have learned that informed your decision
[3:13:11]that you should have never trusted Jeffrey Epstein?
[3:13:14]Well, going back to when I originally spoke to Epstein when he first was being charged
[3:13:21]with soliciting a minor for prostitution, he told me that this was a mistake
[3:13:26]and it would never happen again that he would be with a minor.
[3:13:29]I never saw minors around Epstein, so I was never suspicious that Epstein was with minors.
[3:13:35]But in reading these lawsuits, I realized that Epstein abused hundreds of women.
[3:13:43]And at that point in time, if he was abusing hundreds of women,
[3:13:47]I couldn't trust anything he said to me because he told me at that point in time
[3:13:51]that he was never going to do this again.
[3:13:53]So if I knew back then that Epstein was not keeping his word and not honest and abusing women,
[3:14:07]I would have left work and reported them to the authorities.
[3:14:10]And sitting here today, is it your belief that Jeffrey Epstein's financial
[3:14:19]and estate planning strategy was a purposeful design to obfuscate his crimes?
[3:14:27]Do I believe that the work that Epstein provided for clients obfuscated his crimes?
[3:14:36]Not just the work he provided for clients, but how he designed his entire enterprise,
[3:14:42]for lack of a better word, with dozens and dozens of companies and accounts.
[3:14:46]Do you think that was a design to obfuscate his crimes?
[3:14:49]No. I think there's a general misconception about Epstein's operating financial entities
[3:14:57]and setting up LLCs and bank accounts.
[3:15:01]I believe that setting up LLCs and bank accounts are the ABCs of financial planning
[3:15:07]for wealthy individuals like Epstein and others.
[3:15:10]If I was, for example, a real estate developer and I purchased five buildings,
[3:15:16]I would never put five buildings in one LLC for the sole reason that
[3:15:21]if someone was walking down the street and they tripped and fell in front of one building,
[3:15:26]they would sue the building.
[3:15:28]As an owner of a property, I would never want to put at risk those four other buildings I owned
[3:15:32]for that one lawsuit.
[3:15:34]So segregating significant assets, to me, is common practice for individuals like Epstein
[3:15:40]and any other wealthy individuals.
[3:15:46]And one last question or so before we finish our hour up.
[3:15:52]Did your co-executor, Mr. Endyke, was he part of the decision of planning the victim fund
[3:16:02]of the Epstein estate?
[3:16:03]Yes. We worked together on that.
[3:16:05]And I brought the idea to Endyke after listening to that podcast.
[3:16:14]And then I knew a friend who knew Ken Feinberg's son, so I got his number
[3:16:21]and we reached out to Mr. Feinberg together.
[3:16:24]So, yes, Mr. Endyke was part of putting together the Epstein Victim Compensation Program.
[3:16:29]Was he supportive of this idea?
[3:16:31]100 percent.
[3:16:33]That will end our hour there and go off the record.
[3:16:37]Go back on the record.
[3:16:53]Good afternoon, Mr. Khan.
[3:16:55]Good afternoon.
[3:16:56]There was a discussion in the previous round about loans that Mr. Epstein extended to you
[3:17:01]at various points in time.
[3:17:03]Were any of those loans documented?
[3:17:05]Yes.
[3:17:06]So loan agreements exist for each of them?
[3:17:08]Yes.
[3:17:09]Have those been produced to the committee?
[3:17:12]I don't know.
[3:17:13]If requested, everything was provided.
[3:17:18]So it's just a function of what the committee has asked for.
[3:17:21]Thank you, counsel.
[3:17:25]I would like to refer you back, if I could, to what was marked previously as Exhibit D,
[3:17:31]that is the email thread you were discussing with Congressman Walkinshaw.
[3:17:36]And if I could refer you to the second email down on the first page,
[3:17:52]that's the page ending in the Bates Numbers 1286,
[3:17:57]sent by an unidentified individual on the subject of Gleon at 606EDT.
[3:18:06]Do you see that?
[3:18:07]Yes.
[3:18:08]I'm just going to read it into the record.
[3:18:11]Dear Mr. Khan, thank you for your help with the university application.
[3:18:15]The next step will be the student visa application in which I'll also need your help.
[3:18:20]There are certain details that I'll need to present to the council.
[3:18:25]And then itemizing those details, the third sentence down reads,
[3:18:31]a sponsorship letter that says you're willing to pay for my tuition
[3:18:35]on the terms that I'll be working for you in the future.
[3:18:38]A full scholarship, parentheses, a fake one, obviously.
[3:18:44]Mr. Khan, what is your understanding as to why the sender of this email
[3:18:48]was describing the scholarship she references as fake, obviously?
[3:18:53]I don't know what she's referencing to.
[3:18:56]I believe she's asking for some sort of letter that she says is a fake letter,
[3:19:01]and I never wrote such a letter that she requested.
[3:19:05]And then I'm looking up above at your email to Mr. Epstein forwarding her email,
[3:19:13]and the text reads, please advise.
[3:19:15]If okay, then it appears I should be using HBRK as sponsor, question mark.
[3:19:21]Is that correct?
[3:19:23]That's what the email says, yes.
[3:19:25]And in that email you don't raise any concerns about the reference
[3:19:29]to a fake scholarship in the prior email, right?
[3:19:35]Yes, it's correct that I don't make a reference to a fake scholarship
[3:19:40]because I would never write such a letter.
[3:19:42]So I don't need to tell Epstein that I'm not writing a fake letter.
[3:19:46]I would never write a fake letter for this individual.
[3:19:49]Well, that's not what you said in your email to him concerning this email,
[3:19:53]though, is it?
[3:19:54]You're asking him to advise on what you should do.
[3:19:57]No, my understanding of what I wrote is if okay to sponsor, should it be HBRK?
[3:20:07]My understanding is that Epstein had asked for HBRK to pay for this woman's education,
[3:20:16]and I believe she required documentation.
[3:20:19]I believe that HBRK was going to be the entity that was paying,
[3:20:24]and that's what she's asking for us.
[3:20:26]But you're not drawing his attention in this email to her use of the words
[3:20:30]a fake one obviously or raising any concerns with him regarding those words.
[3:20:35]Yes, that's correct that I did not need to raise the concerns
[3:20:38]regarding what she deemed to be a fake letter
[3:20:41]because I would never write such letter and I never did write such letter.
[3:20:45]I'm also going to ask the court reporter to mark as Exhibit E an email from you
[3:20:56]attaching an invoice from the law firm Kirkland and Ellis dated December 18, 2007.
[3:21:10]The email is directed to the email address jeeprojectatyahoo.com.
[3:21:29]Do you see that? Yes.
[3:21:31]And was that an email address that Jeffrey Epstein used?
[3:21:35]In 2008, that was the proper address for Epstein's email.
[3:21:40]Okay. And as I understand, it's your testimony that you didn't learn
[3:21:46]about Mr. Epstein's legal case in Florida until you had a conversation
[3:21:50]with him regarding it in 2008. Is that right? Correct.
[3:21:54]Could I draw your attention to the invoice attached to this email
[3:21:59]that you attached to this email and in particular the entry on the last page
[3:22:05]referring to the matter of DOJ investigation. Do you see that?
[3:22:12]Yes. Did you read the invoice before you send it along to Mr. Epstein?
[3:22:17]When I received the invoices from Epstein and he gave me the authority
[3:22:23]to pay it, I was not reviewing Epstein's legal invoices.
[3:22:28]The majority of the time, I never received the details other than a summary statement.
[3:22:33]But did you look at this invoice?
[3:22:36]The invoice that he sent 18 years ago? You're asking if he remembers?
[3:22:41]Yes. The invoice referring to a DOJ investigation.
[3:22:47]I don't recall what this invoice relates to that he sent for October 31, 2007.
[3:22:54]I'm sorry. I just want to make sure the record is clear.
[3:22:57]Did you read this invoice when you received it?
[3:23:00]When you say did I read the invoice, what I'm looking at appears to be
[3:23:04]a summary page with an amount due.
[3:23:07]Yes.
[3:23:08]What I would receive...
[3:23:09]Let him finish.
[3:23:10]Sure.
[3:23:11]We just keep interrupting. Let him just finish.
[3:23:12]Easy, easy.
[3:23:13]Sure, sure. No, it's fine.
[3:23:14]When I receive this invoice, what I would do is take the amount that was due
[3:23:18]and if there were multiple invoices outstanding, send it to Epstein,
[3:23:22]which looks like I sent him previous payments and say,
[3:23:27]here's an invoice. Here's what you previously paid.
[3:23:30]Shall I pay this invoice?
[3:23:32]That's usually how I would handle a situation like this.
[3:23:35]So again, I don't want to be pedantic.
[3:23:36]I just want to make sure we have a clear record.
[3:23:38]I understand how you're describing your regular practice,
[3:23:41]this specific invoice that I'm showing you in Exhibit E.
[3:23:45]I'm aware of what you're asking.
[3:23:46]You keep asking, did I read the invoice?
[3:23:48]And I keep telling you when I receive an invoice on behalf of Epstein
[3:23:53]or a legal bill, usually I only receive a summary statement
[3:23:57]and at the times when I do receive detailed invoices,
[3:24:02]my focus is on getting the amount at the end of the invoice to be correct
[3:24:06]and making payment for that invoice.
[3:24:08]I have Epstein's approval.
[3:24:10]I don't need to read the invoice.
[3:24:12]So no, I would not be reading the details of his invoices.
[3:24:15]So it's your testimony that you did not read this invoice?
[3:24:18]It's my testimony that what you're showing me, okay?
[3:24:22]And again, I don't know if this was the whole email chain.
[3:24:26]It's my testimony that I received this invoice and I'm asking Epstein,
[3:24:31]please advise on attached invoices.
[3:24:36]So the first question I would pose to you is this a complete set of documents
[3:24:41]because I'm referring to multiple invoices and here we only see one invoice.
[3:24:45]So I don't know what else was in this email.
[3:24:47]That's number one.
[3:24:48]The second thing is I'm saying to Epstein,
[3:24:51]here's all the invoices that are owed from Epstein
[3:24:54]and here's what you've paid him so far.
[3:24:56]Please give me some guidance.
[3:24:58]That's what I'm doing here in this email.
[3:25:01]And the entry that we're discussing does refer to a DOJ investigation
[3:25:08]in which Kirkland and Ellis was serving as outside counsel, right?
[3:25:13]I don't know what Kirkland and Ellis was representing Epstein on.
[3:25:22]Turning back, if I could, Mr. Kahn, to the issue of Mr. Epstein's bank accounts.
[3:25:30]I'm just getting a little bit more specific.
[3:25:33]Did Jeffrey Epstein ever have any accounts at HSBC?
[3:25:39]I don't recall. He may have, but it would have been before my time.
[3:25:46]Did you become aware of HSBC dropping Mr. Epstein as a client?
[3:25:54]As I said, I'm not aware if he had that account,
[3:25:57]so I wouldn't be aware of them dropping him.
[3:26:00]Well, you were his accountant.
[3:26:03]Was it not part of your role to track his bank accounts?
[3:26:07]What I just testified is that I don't recall Epstein ever having an account,
[3:26:12]and I said it's possible he may have had an account,
[3:26:16]but that account was open and closed before my time.
[3:26:20]So I'm not aware from 2005 when I started that Epstein had an HSBC banking account.
[3:26:27]I will represent to you that according to the Wall Street Journal,
[3:26:34]an HSBC account that Mr. Epstein held in France was terminated.
[3:26:39]Do you have any recollection of that?
[3:26:41]I don't have recollection of Epstein's Paris bank accounts.
[3:26:46]Epstein's Paris banking and bill paying was handled by a legal firm in Paris,
[3:26:53]so I'm not aware of the accounts that he had,
[3:26:56]but it's possible he may have had an account. I just don't know.
[3:27:00]Did you ever become aware at any point in time that HSBC had dropped him?
[3:27:04]No.
[3:27:05]It's also my understanding that JPMorgan Chase dropped Mr. Epstein as a client in 2013.
[3:27:11]Is that right?
[3:27:13]Yes, JPMorgan dropped Epstein as a client,
[3:27:16]and I believe 2013 was the year, but I don't know 100% the time frame.
[3:27:21]It could have been 2013 or 2014.
[3:27:23]What is your understanding as to why JPMorgan dropped him?
[3:27:27]I don't believe that I ever received an explanation.
[3:27:32]Let me rephrase that.
[3:27:33]I know I never received an explanation,
[3:27:35]and I don't believe that Epstein or others received an explanation.
[3:27:39]Weren't you curious?
[3:27:41]I didn't receive an explanation.
[3:27:43]I don't believe that banks give explanations when they drop clients.
[3:27:47]Did you ask them any questions?
[3:27:49]Did I ask Epstein questions?
[3:27:51]JPMorgan.
[3:27:53]When they dropped us? No.
[3:27:55]Did it cause you any concern that the individual who employed you had been cut off by a major financial institution?
[3:28:08]The transition from JPMorgan to Deutsche Bank happened quite seamlessly.
[3:28:19]It was the same account rep that went from JPMorgan, his name was Paul Morris,
[3:28:26]and then went from JPMorgan to Deutsche Bank.
[3:28:31]Paul Morris switched firms and then brought Epstein's accounts over.
[3:28:36]I wasn't concerned.
[3:28:40]He had a new banking relationship, and there was no red flags to me that JPMorgan dropped him.
[3:28:46]I didn't know why, but I knew that a new bank was taking his business.
[3:28:50]If he said to me in 2013, was it concerning?
[3:28:55]If he never opened up another account, I would say yes,
[3:28:58]but he quickly had another banking relationship with the same individual that was representing him.
[3:29:04]Let me be a little bit more specific.
[3:29:06]I understand that you didn't have concerns as you just testified about the transition from JPMorgan to Deutsche,
[3:29:13]but did you have concerns about JPMorgan's decision to drop him as a longtime client?
[3:29:18]I did not know Epstein's relationship with JPMorgan and the individuals that he dealt with at the bank,
[3:29:24]nor was I a signatory, nor was I ever told.
[3:29:28]I don't know the details of why they dropped him, so I can't testify to that.
[3:29:33]It's hard to testify that I was concerned when I don't know the details of what actually took place.
[3:29:38]In November of 2018, the Miami Herald published a series of articles about Jeffrey Epstein
[3:29:46]and his crimes and allegations by additional Epstein survivors.
[3:29:51]Were you aware of that Miami Herald series?
[3:29:54]I did see the article and I did read parts of it, yes.
[3:29:58]Did that series cause you concern?
[3:30:01]Yes, it did cause me concern.
[3:30:03]Why?
[3:30:04]Because the Miami Herald article, from what I recall reading,
[3:30:09]provided more details regarding Epstein and his earlier pleading to soliciting a minor for prostitution.
[3:30:20]It's been reported that in the wake of the Miami Herald series,
[3:30:24]additional banks, including Deutsche, dropped Mr. Epstein as a client. Is that right?
[3:30:30]Yes, I believe that Deutsche Bank dropped Epstein shortly after that article.
[3:30:36]What other banks?
[3:30:42]Deutsche Bank is the only one that I recall.
[3:30:44]Just quickly returning to the issue of your compensation and things of value that Mr. Epstein paid,
[3:31:04]as I understand, Mr. Kahn, you were married?
[3:31:07]Yes.
[3:31:08]You were married during the time that you were employed by Jeffrey Epstein?
[3:31:11]Yes.
[3:31:12]Did Mr. Epstein ever make any payments directly to your wife?
[3:31:17]He never made any payments directly to my wife.
[3:31:20]However, the entity that received loans was owned by me and my wife.
[3:31:28]I'm sorry, what was the name of that entity?
[3:31:30]I believe it was called CO2 Enterprises.
[3:31:33]C-O-A-T-U-E.
[3:31:37]C-O-A-T-U-E.
[3:31:55]Again, sticking with the topic of bank accounts, and I don't want to make you repeat yourself.
[3:32:01]I think this will touch upon some questions that have been asked previously,
[3:32:04]but just in the interest of a clear record, I had some follow-up questions.
[3:32:11]Most generally, am I correct in understanding that you were an authorized person on Epstein's bank accounts?
[3:32:22]I don't know what the technical term authorized person was.
[3:32:25]I was never a signatory on Epstein's account, so I could never sign a check.
[3:32:30]I could never sign a wire, and I could never withdraw cash.
[3:32:35]But what I was able to do was speak to the bank and ask them if I needed a bank statement.
[3:32:42]Can you please email me a bank statement?
[3:32:44]So I believe I had what I would envision as inquiry status,
[3:32:49]and that was the extent of the authority that I had with JP Morgan and with Deutsche Bank.
[3:32:57]What about other banks?
[3:32:59]Those are the two main banks that I recall Epstein having relationships with during my time.
[3:33:04]Did you have the ability to effectuate payments from those accounts on Mr. Epstein's behalf?
[3:33:09]No.
[3:33:14]Did you ever open bank accounts for women connected to Jeffrey Epstein?
[3:33:18]No, I never opened bank accounts for women.
[3:33:21]However, a few women I do recall once asked if they could open up a bank account,
[3:33:31]and I don't recall if it was for women, or Epstein asked if we could use our private bank,
[3:33:39]either at Deutsche Bank or Deutsche Bank or JP Morgan.
[3:33:45]So I may have requested, or Bella Klein may have requested,
[3:33:49]an application that was then passed off to these women for them to fill out and complete.
[3:33:55]So it was basically these women were getting a benefit of his private banking service as opposed to having to go to a branch.
[3:34:42]I'm going to ask the reporter to mark his exhibits F, G, and H three checks that I'd like you to take a look at, please.
[3:35:04]Thank you.
[3:35:43]Mr. Khan, first of all, is that your signature on each of these three checks?
[3:35:50]I don't believe it's a live signature. I believe it's an electronic signature.
[3:35:56]These checks are all made out from the entity JSC Interiors LLC,
[3:36:02]and I believe in an earlier round you referred to JSC as a design company?
[3:36:08]I don't recall if I testified to JSC being a design company, but that is accurate what you said.
[3:36:16]JSC Interiors was a design company that was used by assistance of Epstein in order to have access to the design district in New York,
[3:36:32]as well as obtain a sales tax certificate for that purpose,
[3:36:38]so that if Epstein wanted his assistants to pick up samples or do any decorating to assist him, they would have access.
[3:36:46]So JSC Interiors was a design company.
[3:36:49]I believe what I testified to earlier was that there were only three accounts where I had signatory authority.
[3:36:55]And what I said is the three accounts up until Epstein's last six months where I did have signatory authority on a few accounts.
[3:37:03]And what I said and I believe I testified to was that it was HBRK, it was JSC Interiors,
[3:37:10]and for the time that I was a trustee on Butterfly Trust,
[3:37:14]were the only three times that I had signatory at Epstein's Deutsche Bank or JP Morgan accounts.
[3:37:23]And when was JSC formed?
[3:37:30]I don't recall the date of when JSC Interiors was formed.
[3:37:35]However, I do recall that the previous design company was a company called SLK Designs that was owned by Sarah Kellan.
[3:37:48]And when Sarah Kellan was no longer working with Epstein,
[3:37:54]Epstein wanted to have another design company that would allow him access to the design store room and stores.
[3:38:01]And JSC was the company that followed SLK Designs.
[3:38:06]And did JSC provide services to anyone other than Jeffrey Epstein?
[3:38:10]I believe that JSC Interiors was solely set up similar to HBRK,
[3:38:21]where it was employees of Epstein's assistants that design was one component, but they also were assistants.
[3:38:28]So if Epstein asked his assistant to go to the grocery store, they weren't saying,
[3:38:33]I'm a designer, I can't go to the grocery store.
[3:38:35]So design was one component of what his assistants performed as a task.
[3:38:41]And do you know what these payments were for?
[3:38:44]Yes, these payments, if you look at the checks, it actually says payroll check on all of these checks, payroll check date.
[3:38:55]These were checks that were cut from an outside payroll company,
[3:39:00]and they represented checks to look like two individuals that were on JSC Interiors payroll.
[3:39:10]Thank you.
[3:39:11]Thank you.
[3:39:15]It is my understanding that Jeffrey Epstein also bought gifts for women on various occasions.
[3:39:24]Were you aware of that?
[3:39:26]I was aware that Jeffrey Epstein bought gifts for women, men, and scientists and all sorts of individuals, not just women.
[3:39:35]Were you involved with effectuating those purchases?
[3:39:40]On rare occasion. There are certain instances he might ask me to get involved.
[3:39:45]It's not one of the things that I quite frankly enjoy doing, but on occasion I did make a purchase of a gift for individuals.
[3:39:55]Were you ever aware of Jeffrey Epstein buying lingerie or sex toys for women?
[3:40:02]No.
[3:40:05]I would like to ask the court reporter to mark as Exhibit I a November 18th, 2018 email thread of which you are a part.
[3:40:45]For the record, it's a thread between yourself and Leslie Roth.
[3:40:53]Can you just give us an entry of this?
[3:40:54]Of course.
[3:41:57]Okay, I'm ready.
[3:41:58]Okay. I'm going to start from the bottom up just to go in chronological order.
[3:42:04]So that's the email that Leslie writes to you at 7 or 6 p.m. on November 18th.
[3:42:09]Do you see that?
[3:42:10]Yes.
[3:42:11]And it starts, Hi Rich, I would like to send this out tomorrow morning to the recipients.
[3:42:18]What is your understanding as to why Ms. Roth was sending you this email?
[3:42:22]My understanding of this email chain, all three pages, is that Epstein wanted to buy gifts for I think it was over 40 individuals, men, women, assistants, employees, scientists, attorneys.
[3:42:41]He wanted to buy everyone the Apple Series 4 watch.
[3:42:45]So at the end of her email, she writes, All good for me to send question mark.
[3:42:52]Was she asking for your sign off?
[3:42:55]No, I never approved this purchase.
[3:42:58]I was never, I never initiated this purpose.
[3:43:02]I think I was involved for two reasons.
[3:43:05]One, I believe that Bella Klein was going to be responsible for payment of these watches so that if we saw making the assumption these watches were $1,000 each and I saw a $40,000 bill come in watches, I would be aware of what that purchase was.
[3:43:27]But Epstein was the one that decided to make these gifts to these individuals, along with who the list consisted of.
[3:43:38]If I could refer you to two emails up.
[3:43:42]So this is the email that Ms. Roth sends to you at 730 p.m.
[3:43:48]This is on the second page of this exhibit.
[3:43:51]See that?
[3:43:52]Yes.
[3:43:53]And she writes a second sentence.
[3:43:55]Also, are you positive that who is to get the watches?
[3:44:00]Do you see that?
[3:44:03]Yes.
[3:44:04]Who is?
[3:44:06]I don't know.
[3:44:08]It appears that Ms. Groff understands that you know.
[3:44:13]She says, are you positive that Epstein may have known two women that were named, I don't know, she says, are you positive?
[3:44:29]And maybe, you know, when I was with Epstein, he gave me a list of the names that he wanted, but I don't know the context of why she's asking.
[3:44:38]But my inference from this is that Epstein knew two women that were named, and she's asking which one.
[3:44:45]She's asking you.
[3:44:46]Yeah, she's asking me because I believe, and I can't say with certainty, that I had a meeting with Epstein and he had told me that he wanted to buy gifts of Apple Watch Series 4 for 40 individuals
[3:45:00]and started to dictate a list or gave me a list.
[3:45:04]And his name must have been on the list, and she's, I must have just written the word, and she's asking which it is, and I believe I'm saying I don't know.
[3:45:13]And then looking at your reply to Ms. Groff at 732 p.m.
[3:45:30]I looked Friday and do not have who is.
[3:45:35]Is referenced on the previous page.
[3:45:41]As you have an email from Scott links assistant, but I don't know who is.
[3:45:47]That's the only reference I have from this email, but I don't know who is.
[3:45:51]Why you explain who Scott link is.
[3:45:53]Thank you.
[3:45:54]Scott link was one of Epstein's attorneys.
[3:45:57]Thank you.
[3:45:58]And then the second sentence in that email, I believe maybe Bella can verify.
[3:46:06]What was the source of your belief that was?
[3:46:11]I believe that I had seen her name in the gift report under where we file the gift tax return with her name.
[3:46:18]So that was the name that I was most familiar with.
[3:46:21]And I assumed that he had given her gifts in the past.
[3:46:24]And this was another gift that Epstein was giving to that woman.
[3:46:28]All right.
[3:46:34]Nothing else on this exhibit.
[3:46:35]Thank you.
[3:46:36]Thank you.
[3:46:49]I will ask the reporter to mark as exhibit J.
[3:46:54]A June 8th, 2018 email thread between yourself and Mr. Epstein.
[3:47:58]Right.
[3:47:59]So looking at the first email, the one from Mr. Epstein to you at five thirty a.m.
[3:48:09]It reads send redacted.
[3:48:13]I'm assuming that word is dash three K euros by PayPal and the same.
[3:48:20]Do you recall Mr. Epstein giving you that instruction?
[3:48:23]I think I think about on the first one that low one is.
[3:48:28]Right.
[3:48:29]Please confirm this.
[3:48:30]It may be both.
[3:48:31]We use the subjects as I don't know.
[3:48:35]I don't recall this email from eight years ago, but.
[3:48:39]You know, I see it today and I see that Epstein's asking to send money to
[3:48:44]appears to be two individuals.
[3:48:47]What was he instructing you to pay 3000 euros to these individuals for?
[3:48:54]From what I see from this exhibit, I don't believe I have an explanation.
[3:49:01]So this would be a perfect example of Epstein asking to send money to an
[3:49:07]individual and we do not know what it relates to.
[3:49:10]So we put it in the gifts account and it goes on Epstein's gift tax report.
[3:49:16]And then looking up above at the second email, you write, please confirm that,
[3:49:23]which I take to be a surname.
[3:49:30]Do you know who that individual is?
[3:49:33]I don't.
[3:49:34]I would have received that information from Bella Klein, who makes payments
[3:49:39]and records the ledger and just communicating information I have for Bella.
[3:49:46]But no, I do not know who that individual is.
[3:49:48]And the second sentence per Bella redacted name is traveling to Russia and
[3:49:53]she was unable to reach her.
[3:49:55]Why is that something that Bella would have known this individual's
[3:49:59]whereabouts and travel to Russia?
[3:50:01]I don't know.
[3:50:02]No more questions on this one.
[3:50:08]Thank you.
[3:50:09]Thank you.
[3:50:17]I will ask the reporter to mark an additional document as Exhibit K.
[3:50:23]This is an email thread dated May 15th, 2018.
[3:50:30]Thank you.
[3:50:37]And I'm looking specifically at the first page.
[3:50:56]My only question on this one pertains to the email at the top.
[3:51:00]Just give me one second.
[3:51:01]Sure.
[3:51:39]Bless you.
[3:52:12]I'm ready.
[3:52:14]Actually, I'll start on the second page.
[3:52:19]This is information provided seemingly in connection with an inquiry
[3:52:24]regarding an LSJ account at Deutsche.
[3:52:28]And I'm looking at the line entry for a March 29th, 2018 payment of $25,000
[3:52:36]to an MR Sead.
[3:52:38]Do you see that?
[3:52:40]Yes.
[3:52:41]Who is Mr. Sead?
[3:52:43]I do not know who Mr. Sead is.
[3:52:48]And then I'm looking at the first email on the first page,
[3:52:53]which addresses that question, the response from Stuart Oldfield.
[3:52:58]Amar Sead is a professional photographer.
[3:53:01]Does that refresh your recollection as to who Mr. Sead is?
[3:53:06]Yeah, I do recall this inquiry in particular,
[3:53:12]and I believe I referred to it in the previous session when I was asked
[3:53:17]if the banks ever made inquiries.
[3:53:19]And I think I referred to this specific transaction,
[3:53:24]which was the wire on 3-7, 2018, for $25,000.
[3:53:30]The individual's name is redacted,
[3:53:32]and I said it was a Spanish name and it was for work on his barge.
[3:53:35]So yes, I do vaguely remember this email exchange and the inquiries.
[3:53:41]So in this example, just to provide some context,
[3:53:44]I was able to look up through the books and records
[3:53:47]the first payment of $25,000.
[3:53:50]So I did not know what the other three payments were for.
[3:53:54]I then told Epstein the first ones were the barge.
[3:53:58]Could you please let me know what the other three payments were for?
[3:54:01]I appreciate that.
[3:54:02]I'm focused specifically on the payment to Mr. Sead.
[3:54:07]I'm just referring you back to the explanation at the top of page one,
[3:54:15]noting that Mr. Sead is a professional photographer.
[3:54:18]My question was, did that refresh your recollection as to who Mr. Sead is?
[3:54:23]I do not know.
[3:54:24]I've never met Mr. Sead, and I only know his name from this
[3:54:29]or let me rephrase that.
[3:54:31]I'm familiar with his name from this transaction,
[3:54:39]and when I was asked who he is and what is this for,
[3:54:43]and he was a photographer and he received a loan.
[3:54:46]So yes, I do recall these transactions.
[3:54:48]Were you aware of Mr. Epstein using the services of a professional photographer?
[3:54:54]Was I aware of that he was using?
[3:54:58]As I testified earlier, I was not in Epstein's personal world,
[3:55:04]so I don't know what Epstein did with photographers
[3:55:07]or what he did with his personal time.
[3:55:09]I sat in my office and accounted for his books and records,
[3:55:12]so I have no knowledge of what he did in his personal life.
[3:55:24]I'm going to shift gears to a different topic now.
[3:55:28]It's been reported in the Wall Street Journal,
[3:55:32]and I believe elsewhere,
[3:55:33]that you had a role with respect to marriages that took place
[3:55:37]between certain women connected to Jeffrey Epstein.
[3:55:40]Is that right?
[3:55:42]Did I have a role?
[3:55:45]The reporting on the marriages in the Wall Street Journal,
[3:55:49]I believe, is inaccurate,
[3:55:51]but I did write a letter on behalf of two women at their requests,
[3:55:57]so I could talk about that,
[3:55:58]but I don't believe the reporting in the Wall Street Journal is accurate.
[3:56:03]Which women did you write that letter for?
[3:56:06]At the request of Jennifer Kalin and Karina Szuliak,
[3:56:11]I wrote that letter.
[3:56:13]Who was that letter addressed to?
[3:56:19]I don't recall.
[3:56:22]It might have,
[3:56:23]and I don't know if my recollection is from seeing articles
[3:56:28]like the Wall Street Journal.
[3:56:31]It might have been to immigration services,
[3:56:33]but I don't recall.
[3:56:36]It was not.
[3:56:37]They can show it to you.
[3:56:38]Okay.
[3:56:39]I don't know.
[3:56:40]I don't know.
[3:56:42]Had you known those two women prior to writing the letter?
[3:56:46]Yes.
[3:56:47]For how long?
[3:56:50]Since my employment.
[3:56:53]Now,
[3:56:54]Jen Kalin, I believe, was working with Epstein when I began,
[3:56:58]and Karina maybe came,
[3:57:01]I don't know, four to five years after I began.
[3:57:06]Did you play any other role in connection with any other couple,
[3:57:12]female couples that were married?
[3:57:15]Well, I'd like to just rephrase your question.
[3:57:18]I never played a role in any couples and their marriage.
[3:57:22]I never committed immigration fraud.
[3:57:24]Let me finish, please.
[3:57:26]Not my question, though.
[3:57:29]You insinuated something that was not true,
[3:57:31]and he's just correcting it.
[3:57:33]Yes or no question.
[3:57:34]You're referring to an article where I believe the reporting was inaccurate.
[3:57:37]Okay.
[3:57:38]So what I'd like to set the record straight with is,
[3:57:40]these two women made a request and asked if I would do a favor
[3:57:45]and write them a letter of recommendation.
[3:57:48]These two women provided me with a form letter
[3:57:51]and later came to my office and advised me on sample lines
[3:57:55]that I should include in the letter.
[3:57:57]I agree that the letter was embellished.
[3:58:00]I saw the letter as no different than me writing a co-op recommendation letter
[3:58:05]for a friend who I had not seen in 10 years,
[3:58:09]and I write in the letter how great his kids are,
[3:58:12]and these are kids that I never met.
[3:58:14]So the letter was embellished.
[3:58:16]I did it as a favor and as a request of these two women.
[3:58:20]These two women never told me that this marriage was a sham.
[3:58:24]These two women never told me that this marriage was forced.
[3:58:28]I will tell you, in hindsight, I regret writing this letter
[3:58:32]because I now know that I unknowingly contributed to these women's pain and suffering,
[3:58:37]but this was not me participating in immigration fraud,
[3:58:41]and it's been misreported on,
[3:58:43]and I'm happy that you allowed me to set the record straight.
[3:58:47]Just to make sure I understand what you mean when you say that the letter was embellished,
[3:58:51]are you saying that the characterizations of their relationship that the letter contains
[3:58:56]were the women's rather than yours?
[3:58:59]Yes, the letter.
[3:59:01]When I clearly look at the writing today,
[3:59:04]10 years or whatever it is after the fact the letter was written,
[3:59:08]anyone, Dan and Joshua, could attest that is not my writing
[3:59:12]and those are not my words.
[3:59:17]Shifting to yet another topic,
[3:59:22]Conor, you're familiar with the entity Enhanced Education.
[3:59:25]Yes.
[3:59:26]What is Enhanced Education?
[3:59:28]Enhanced Education is a foundation that Epstein created.
[3:59:32]I believe it's a U.S. Virgin Islands foundation,
[3:59:35]and Enhanced Education, I believe, is the DBA
[3:59:41]for maybe the proper corporate name.
[3:59:44]That was the J. Epstein Virgin Islands Foundation.
[3:59:48]I'm not sure which is the DBA.
[3:59:50]But it's the same entity.
[3:59:52]Did you have a position either in Enhanced Education or the DBA?
[3:59:57]I don't recall if I was ever an officer of that entity.
[4:00:02]I may have for a period of time,
[4:00:04]but my position would have been just making sure,
[4:00:09]like I did whether I was an officer or not,
[4:00:12]that if a foundation was making out checks,
[4:00:15]that it was a proper 501c3,
[4:00:18]or if it was a proper expense, how we reported.
[4:00:22]And if it was something that was not a 501c3,
[4:00:28]I would report that to Epstein
[4:00:29]and say that this is not a proper deduction.
[4:00:33]Did Epstein ever recruit any women to work for Enhanced Education?
[4:00:38]I believe Epstein had a communications director
[4:00:43]for a period of time that was paid as a consultant, yes.
[4:00:46]Who was that person?
[4:00:48]I believe her name was Svetlana.
[4:00:51]Her last name is with a P. I don't recall her last name.
[4:00:54]And was Svetlana Russian?
[4:00:57]I don't know where Svetlana was from.
[4:01:02]I will ask the court reporter to mark as Exhibit L
[4:01:07]a letter apparently signed by you
[4:01:10]on Enhanced Education letterhead dated July 25, 2014.
[4:01:15]Thank you.
[4:01:26]I'm ready.
[4:02:01]Mr. Khan, did you write this letter?
[4:02:03]Yes.
[4:02:05]And who was it written for?
[4:02:08]I don't recall the woman's name,
[4:02:11]but I recall it was written on behalf of a woman
[4:02:20]who had previously traveled with Epstein
[4:02:26]to visit Mr. Bill Gates in Seattle
[4:02:31]three or four months prior to this letter being written.
[4:02:35]Who was the intended recipient?
[4:02:38]Of this letter?
[4:02:39]Yes.
[4:02:41]I don't recall, but if I look at the letter,
[4:02:45]the third or fourth line, it says,
[4:02:48]please help accelerate the visa.
[4:02:50]So I don't know the legal authority that deals with visas,
[4:02:54]but I assume that's what it relates to.
[4:02:57]Did you ever meet the individual
[4:02:59]who the letter was written for,
[4:03:00]meaning the person whose name was redacted at the beginning?
[4:03:03]I don't recall.
[4:03:05]And were you asked to write this letter?
[4:03:08]Yes, I was asked to write this letter
[4:03:10]after it was explained to me that Epstein
[4:03:15]and this woman had went to visit Bill Gates
[4:03:18]in I believe it was March of that year in Seattle,
[4:03:24]and this woman was desiring to do some charity work in Africa.
[4:03:30]And that Epstein reached out to a medical doctor
[4:03:36]that was once affiliated or worked for Gates' Foundation
[4:03:41]and had asked if this individual could help source some work in Africa
[4:03:48]as this woman was desiring to do some charity work in Africa.
[4:03:53]And I believe that the woman and the medical doctor had a conversation
[4:03:59]and that they decided that this was the program
[4:04:03]that this woman was going to go do some work for in Africa.
[4:04:07]And who explained that to you?
[4:04:10]I believe it was Epstein.
[4:04:12]The letter states, and I'm looking at the second sentence,
[4:04:19]this work is critical to our continued operations in Africa.
[4:04:24]Did enhanced education have operations in Africa?
[4:04:28]Enhanced education did not have an office in Africa,
[4:04:31]but I don't know what work or charitable donations it was making
[4:04:36]related to charities in Africa,
[4:04:38]so I can't answer what it was doing in Africa,
[4:04:43]but the only thing I know is it did not have an office.
[4:04:46]Did you do anything to verify the representations in this letter
[4:04:50]beyond receiving information from Mr. Epstein?
[4:04:55]Epstein telling me that this woman and him visited Gates in Seattle
[4:05:01]and Gates' medical doctor speaking with this woman and mapping out a plan.
[4:05:08]There was nothing that was suspicious,
[4:05:10]nothing about this letter that spoke of sexual abuse or sex trafficking.
[4:05:15]There was nothing for me to question.
[4:05:16]Everything seemed proper to me.
[4:05:20]Nothing else on this exhibit. Thank you.
[4:05:21]Thank you.
[4:05:29]A few follow-up questions.
[4:05:30]I know you covered this in the prior round with the majority concerning Mr.
[4:05:35]Epstein's use of various business entities.
[4:05:39]Again, just want to make sure that we have a complete record here.
[4:05:43]How many entities did Jeffrey Epstein own in whole or in part?
[4:05:48]I think this is another area where the media has misreported.
[4:05:56]I think Jeffrey Epstein, at any given time,
[4:05:59]owned somewhere in the neighborhood of 20 to 30 entities.
[4:06:04]I don't recall even what the media reported,
[4:06:06]but I think they talk about 50 or 100 entities,
[4:06:09]and they talk about other terms if you're free to ask about,
[4:06:13]which is incorrect as well, financial maneuvers, financial scaffolding.
[4:06:17]I'm happy to talk about that if you'd like.
[4:06:19]Sure.
[4:06:20]I'll start with just the number that he utilized.
[4:06:28]To some observers, 20 to 30 seems like a lot.
[4:06:32]What was the reason that he had that number?
[4:06:35]I'm happy to walk you through almost all that I can recall.
[4:06:39]He had five homes.
[4:06:41]What's the... I'm sorry.
[4:06:44]Epstein had five homes.
[4:06:47]Each of the homes were owned in an S corporation,
[4:06:51]that tax reported to the IRS.
[4:06:54]Each of the homes then had an entity that paid the bills and expenses
[4:06:58]of that entity in addition to the payroll of the employees.
[4:07:02]That right there is 10 entities.
[4:07:04]Epstein had, I believe, three or four aircraft at any given time
[4:07:10]between planes and helicopters, so now we're at 14.
[4:07:15]Epstein made investments,
[4:07:18]and each investment would go in a separate entity.
[4:07:21]Epstein had two trusts that we spoke about earlier.
[4:07:25]Now we're at 16.
[4:07:28]I could go on and on.
[4:07:30]I don't recall all of his entities,
[4:07:32]but every one of his entities was set up.
[4:07:35]There was no financial scaffolding.
[4:07:37]I don't even know what that term means.
[4:07:39]There was no reason to hide anything.
[4:07:41]Everything was reported on the books and records,
[4:07:43]and all of his entities were tax-paying entities.
[4:07:46]Therefore, every income, most of his households,
[4:07:49]there was no income, it was only expenses,
[4:07:51]but all of the expenses were reported to the IRS.
[4:07:54]There was nothing we were trying to hide.
[4:07:57]Correct me if I'm wrong.
[4:07:59]If I'm understanding correctly,
[4:08:01]specific entities were set up to serve specific purposes
[4:08:05]related to Mr. Epstein's expenditures.
[4:08:08]Is that fair?
[4:08:10]Each of Epstein's households had an entity that paid the bills
[4:08:14]and payroll for those households.
[4:08:17]Each of Epstein's planes also had expenses.
[4:08:22]I don't believe that planes had payroll.
[4:08:26]So yes, every entity that Epstein set up had a purpose.
[4:08:30]Some of them were not a business purpose
[4:08:32]because they were for personal use,
[4:08:34]but they were all, in my mind,
[4:08:37]every one of his entities was a legitimate entity.
[4:08:40]I'd just like to quickly walk through
[4:08:43]some of those specific entities that we had an interest in,
[4:08:47]the first being Southern Trust Company.
[4:08:50]What was Southern Trust?
[4:08:52]Southern Trust was the entity that Epstein used
[4:08:56]for his financial tax and estate planning.
[4:08:59]It was a U.S. Virgin Islands entity.
[4:09:02]And did Southern Trust ever make payments to women?
[4:09:12]Not that I'm aware of.
[4:09:14]The Butterfly Trust we spoke about earlier.
[4:09:18]I know you've answered questions regarding that entity.
[4:09:22]What was its purpose?
[4:09:24]I don't know what its purpose was,
[4:09:26]but the Butterfly Trust, as I testified to earlier,
[4:09:29]was a pour over trust from an investment that Epstein made
[4:09:32]and the proceeds from that investment went to the Butterfly Trusts
[4:09:36]whereby I was a trustee for a period of time
[4:09:39]and then I was not a trustee for many years.
[4:09:43]Did the Butterfly Trust make payments to women?
[4:09:47]Yes.
[4:09:48]And did you handle those payments?
[4:09:51]Again, I think this is another area that was misreported on.
[4:09:55]I believe that it was reported that I
[4:09:59]were responsible for millions of dollars for payments
[4:10:03]to women from the Butterfly Trust.
[4:10:06]I think the Butterfly Trust only had approximately a million dollars
[4:10:11]of distributions, number one,
[4:10:14]and I was a trustee for a portion of time,
[4:10:18]probably for less than half of those distributions.
[4:10:21]So yes, at times as trustee,
[4:10:25]I made distributions based on the beneficiaries in that trust, yes.
[4:10:30]And then LSJELLC?
[4:10:34]LSJELLC was the entity that paid the bills for Epstein's two islands,
[4:10:44]LSJ and GSJ.
[4:10:50]And did LSJE ever make payments to women?
[4:10:53]Yes.
[4:10:54]I believe that improper payments were made to women from that entity.
[4:11:00]And what I mean by that is, for whatever reason,
[4:11:04]I don't know, Epstein asked to make a payment from that entity.
[4:11:08]It was incorrect.
[4:11:10]And because it was on an entity, LSJELLC,
[4:11:13]that was not a tax reporting entity,
[4:11:16]we were forced to make journal entries and take those personal expenses
[4:11:20]and put it on his personal books and records
[4:11:22]so that it could be properly reflected on his gift tax return.
[4:11:26]And then, as I understand it again, please correct me if I'm wrong,
[4:11:30]Mr. Epstein also had a personal account at Deutsche Bank in his own name.
[4:11:35]Is that right?
[4:11:36]Yes, Epstein had a personal account.
[4:11:38]And did he make payments to women out of that account?
[4:11:41]Yes.
[4:11:43]I think that's all helpful.
[4:11:46]I think the question arises if, as you've told us,
[4:11:51]each of these entities was set up to serve a specific purpose.
[4:11:56]And I understand the goal of efficiency.
[4:12:00]Why were payments being made to women from several different entities,
[4:12:05]which, as I understand, were designed to serve different purposes?
[4:12:09]Well, I'll speak first to the trust.
[4:12:11]The Butterfly Trust had no specific purpose.
[4:12:14]It was a trust that Epstein set up for the benefit of whoever the beneficiaries are.
[4:12:18]So I take Butterfly Trust out of that.
[4:12:21]In the three entities we went through,
[4:12:23]I don't believe that Southern Trusts ever paid women.
[4:12:26]And in the example of LSJ,
[4:12:28]I am telling you that I believe Epstein made handfuls of payments improperly to women from that entity.
[4:12:35]Why he chose to do that, I don't know.
[4:12:38]But I do know, as his accountant, and my goal and desire of keeping meticulous books and records,
[4:12:43]we quickly journal-entried those entries into Epstein's personal QuickBooks account
[4:12:49]so we could properly record for his gift taxes.
[4:12:51]So from what you asked, it appears that there was one entity
[4:12:55]that he improperly paid women from other than his personal account.
[4:12:59]When you say improperly, can you explain what you mean?
[4:13:01]I mean by improperly meaning that it was a personal expense.
[4:13:04]It had nothing to do – I don't want to misspeak.
[4:13:08]It possibly could have been.
[4:13:10]Again, I never traveled with Epstein,
[4:13:13]so I don't know if he was paying a woman for work she did at that property.
[4:13:19]And this woman was a server.
[4:13:21]But if that was one or two times, maybe that's okay.
[4:13:25]But if it was 20 or 30 transactions, that doesn't seem to be the case.
[4:13:29]So we took all those – I'm not saying the payments weren't proper.
[4:13:33]I'm just saying the payment should have been from his personal books and records
[4:13:36]because that's where he made his personal payments.
[4:13:39]And that is where we – that's the entity we used to report his gift tax reporting.
[4:13:47]We can go off the record.
[4:14:03]Okay, we will go back on the record.
[4:14:05]Mr. Conn, in the previous hour,
[4:14:13]I believe you touched a little bit on Mr. Epstein's banking relationships.
[4:14:19]And I just want to go back through some of that just so that the record is clear.
[4:14:25]JP Morgan Chase was the primary bank until they dropped Mr. Epstein in approximately 2013.
[4:14:33]Is that accurate?
[4:14:35]Yes.
[4:14:36]And can you just restate the reasons for JP Morgan dropping Mr. Epstein as a client?
[4:14:45]I believe what I testified to earlier was I did not know the reasons why JP Morgan dropped Epstein as a client.
[4:14:52]Have you subsequently learned any reasons for why JP Morgan dropped Mr. Epstein?
[4:14:57]Possibly as co-executor, I learned that they were concerned about him being charged with soliciting a minor
[4:15:13]and they were concerned about cash withdrawals.
[4:15:17]But a lot of the reporting – I'm not sure what to believe and what not to believe.
[4:15:21]I don't know what's accurate, but I did hear they dropped him because of suspicious cash withdrawals.
[4:15:27]And I believe they were concerned.
[4:15:29]I think I'm saying this in context of just clearly that maybe I read reports
[4:15:35]that he was the only reason that banks stayed on with Epstein,
[4:15:38]but I don't know what's accurate and what's not accurate.
[4:15:42]And following JP Morgan dropping Mr. Epstein, which banks did Mr. Epstein primarily move over to?
[4:15:50]Epstein moved pretty seamlessly from JP Morgan to Deutsche Bank for his main banking relationship.
[4:16:01]Did most of his entities also move to Deutsche Bank for their banking relationships?
[4:16:05]Yes.
[4:16:12]Did you play any role in finding a new bank for Mr. Epstein at this time?
[4:16:19]In 2014, I was not involved with Epstein's move from JP Morgan to Deutsche Bank.
[4:16:26]Who would have been involved in that?
[4:16:29]I don't know if anyone other than Epstein was involved.
[4:16:34]As I testified earlier, Paul Morris, who was Epstein's account rep at JP Morgan,
[4:16:41]had moved over to Deutsche Bank, I believe prior to him being dropped.
[4:16:45]I don't know how much before.
[4:16:47]And then when Epstein was leaving JP Morgan, he took in Epstein's accounts at Deutsche Bank.
[4:16:57]And how long did Mr. Epstein bank with Deutsche Bank?
[4:17:00]I believe he banked in 2014.
[4:17:03]And Deutsche Bank, I believe sometime in November or December of 2008,
[4:17:12]decided to terminate their relationship with Epstein.
[4:17:17]2018.
[4:17:18]Thank you.
[4:17:19]In November or December 2018, decided to terminate their relationship.
[4:17:24]However, for a handful or so accounts, they allowed us some time to find a new banking.
[4:17:30]So what I'm testifying to say is that the last bank account at Deutsche Bank might not have been closed until March or April of 2019.
[4:17:41]And at which point did you take on a more prominent role in the banking activities of Mr. Epstein?
[4:17:51]Well, after Deutsche Bank had dropped Epstein, he had asked if I could assist in trying to find him a bank account.
[4:18:03]At the time, as I testified to earlier, we had 20 or so entities with probably 10 or so payrolls.
[4:18:09]And I was concerned about making sure that staff was paid and bills were paid.
[4:18:16]At that point in time, I live on the Upper East Side of Manhattan.
[4:18:20]And I went to two local branches, two brokerage accounts that are a block away from each other, Fidelity Brokerage and Charles Schwab.
[4:18:32]And I believe we opened up account brokerage accounts at each of those institutions.
[4:18:40]And this was, I don't recall the time frame, sometime probably in March or April or maybe April or sometime in the first or second quarter of 2019.
[4:18:56]At this point in time, did you move any of Mr. Epstein's money into your own personal accounts?
[4:19:07]My own personal account? No.
[4:19:10]Are you aware of Mr. Indyk moving any of Mr. Epstein's money into his own personal accounts?
[4:19:15]I'm not aware, but I can't say that with certainty. I don't know.
[4:19:20]And you testified, actually let me go back for a second.
[4:19:28]Over the course of your time working for Mr. Epstein, can you provide a total number of bank accounts in which you would have had?
[4:19:38]Rich economy personally? No, no, no. That Mr. Epstein had.
[4:19:42]A total number of accounts at all institutions? Correct.
[4:19:46]I would say that his main banking relationship would have somewhere between what I was describing before.
[4:19:56]It was entities, planes, personal investment, somewhere between 25 to 30.
[4:20:01]And I know he had one account in the U.S. Virgin Islands. That was the first bank.
[4:20:08]I believe he had a local account in Palm Beach for a period of time.
[4:20:12]Most of these local accounts were for the purposes of the house managers so they could access checks.
[4:20:18]And I believe he had a local account in New Mexico.
[4:20:24]So I would say the most accounts he ever had at any given time was about 30, approximately.
[4:20:32]How many accounts did Mr. Epstein maintain, bank accounts did Mr. Epstein maintain overseas?
[4:20:40]The only accounts that I'm aware that Epstein had overseas were his Paris accounts,
[4:20:48]which I am not 100 percent certain whether they were in the name of Epstein or the local attorney.
[4:20:57]I think some of them were in Epstein's name because I do recall his FBARs,
[4:21:04]which is financial reporting we're required to do with his personal return that he had a state the highest value.
[4:21:10]So he must have had a few accounts in his name.
[4:21:12]But my understanding is his accounts were all from Paris and they were related to the support of his home there.
[4:21:21]Mr. Epstein maintained any bank accounts in Switzerland?
[4:21:26]Not that I'm aware of.
[4:21:28]Grand Cayman Islands?
[4:21:30]Not that I'm aware of.
[4:21:32]Did Mr. Epstein ever hold any Bitcoin or other digital assets?
[4:21:41]Not that I'm aware of.
[4:21:50]Going back to the Paris bank, do you know the name of that bank?
[4:21:56]I believe there were a few banks.
[4:22:00]I think it was maybe BNP Paribas.
[4:22:06]The minority was talking about an HSBC account.
[4:22:09]I don't know if that's accurate, but they were talking about that earlier.
[4:22:13]And there may have been one other, I don't recall.
[4:22:19]You mentioned earlier, I believe, around the earlier time frame of you coming into employment with Mr. Epstein
[4:22:31]and moving towards his problems with JP Morgan, he had problems getting credit cards.
[4:22:38]Is that accurate?
[4:22:40]When JP Morgan dropped Epstein, we struggled to get credit cards.
[4:22:51]And I don't know the particular reason, but I believe it's one of two things.
[4:22:59]One, Epstein spent a lot of money on an annual basis and typically wanted credit lines of $300,000, $400,000,
[4:23:10]because he wanted to give out 10 or 15 credit cards to employees.
[4:23:14]And I believe that banks wanted full-time—they didn't want to provide just credit card services for that amount of credit
[4:23:23]without a full-time banking relationship.
[4:23:25]And Epstein was already settled at Deutsche Bank, so he wasn't looking to move over his banking relationship.
[4:23:30]And the other reason, and maybe I'm making an inference, is that maybe he had trouble with his credit cards because of his 2008 incident.
[4:23:46]And outside of just the plain property management staff, approximately how many other individuals would have access to Mr. Epstein's credit cards,
[4:24:01]whether that be direct access to his own account or an account in their name that maybe he paid for?
[4:24:07]I'm not sure I'm understanding you. Are you asking how many credit cards were outstanding or how many people would—
[4:24:15]How many people would have a credit card?
[4:24:17]Other than property managers?
[4:24:19]Other than the property managers.
[4:24:20]What about the pilots?
[4:24:21]Pilots.
[4:24:22]Included pilots? Are you just asking for assistance?
[4:24:25]Including pilots, assistants, other women, women associated with other businesses, et cetera.
[4:24:31]I believe, and again, I don't recall that much about the J.P. Morgan credit cards,
[4:24:39]I believe back then we probably had between American Express, and I don't know if J.P. Morgan was master of visa,
[4:24:47]but between J.P. Morgan and American Express there were probably 15 or so credit cards outstanding.
[4:24:53]And who were they besides the property managers?
[4:24:56]They were the pilots. When you use the word property managers, are you referring to also staff of the properties?
[4:25:04]Yes, outside of staff.
[4:25:06]Outside of property staff. It was the pilots. I think at one point in time Maxwell had a credit card.
[4:25:13]And his assistants, I would assume, that would be what gets me to 15 in my head.
[4:25:27]Did any other women associated with other entities have credit cards paid for by Mr. Epstein?
[4:25:36]I apologize. I'm not sure I'm understanding your question. You say other credit cards. Are you inferring that he's paying their personal credit cards?
[4:25:43]Correct.
[4:25:44]Not that I'm aware of. I believe that Epstein, for assistants that made purchases on behalf of Epstein and also made personal purchases,
[4:25:55]I believe that all the credit cards were originated from Epstein.
[4:26:02]Did you track all of Mr. Epstein's credit card payments?
[4:26:05]No, that was an area that I was not involved in. That was Bella Klein that handled credit cards,
[4:26:11]which is, you know, each month when a credit card statement came,
[4:26:18]Bella Klein would communicate with the individual property manager, assistant, or pilot and request backup for each one of the charges.
[4:26:27]And then she would take that backup with the explanation and input that into QuickBooks.
[4:26:35]Did you have access to any of the expense reports generated by the use of those credit cards or was that also Ms. Klein?
[4:26:46]I was not restricted if I wanted to see the report, but I never looked at the reports. It was not something that I worked on.
[4:26:52]So to answer your question, yes, I had access. There were no restrictions, but it was not something that I worked on.
[4:27:02]And just to be clear, the property managers at the Palm Beach residence, Little St. James residence, the New York residence,
[4:27:16]and the Zorro Ranch residence all had credit cards that they could use on behalf of Ms. Epstein.
[4:27:22]I believe Paris as well.
[4:27:23]And Paris.
[4:27:24]Yes. Now, depending on the property managers, yes.
[4:27:31]And then depending on how much work some of the other individuals did, there might be additional credit cards given to others at that property.
[4:27:58]We discussed, I believe, much earlier in the day that Mr. Epstein was at one point in either late 2018 or 2019 looking to buy a property in Morocco.
[4:28:13]Is that accurate?
[4:28:14]Yes, that's accurate.
[4:28:16]And is it fair to say that Mr. Epstein had already set aside the funds to pay for it?
[4:28:27]I know he didn't ultimately end up paying for that house, but he had the funds set up to pay for that purchase?
[4:28:33]Just to clarify a little bit, the property that Epstein was pursuing in Morocco, I don't know if the ultimate property that he was pursuing...
[4:28:46]Sorry to go back. Epstein, in a previous meeting with me sometime in 2018 or 2019, showed Endyke and I a picture of a home and said, I'd like to buy this home one day.
[4:28:57]So I knew he was pursuing a property.
[4:29:01]I don't know if the property that he made an initial payment to the broker for was that same property, but I knew Epstein had an interest in Morocco and I knew he had visited there previous times.
[4:29:15]The Charles Schwab account where the wire came out of had plenty of funds in the account, I believe the account.
[4:29:30]I don't know which count in particular came out of. I know he had three accounts there at the time and probably had, I don't know, 50 to 70 million dollars among the three accounts.
[4:29:40]But I will say I did see an article that alluded to the fact that Epstein made a wire and then we asked for the wire to be returned, which is correct.
[4:29:54]I believe that wire was maybe two days before his arrest, somewhere in that range.
[4:30:04]Maybe it was a week before. He then asked, he retracted that wire. He then asked for a second wire to be made and I believe it was reported on that he didn't have the funds in the account, which I don't believe is correct.
[4:30:14]The bank would have never allowed money to go to Switzerland without funds in the account. Maybe it didn't come back and clear, but Epstein held stocks and securities in cash.
[4:30:24]He had plenty of funds in the account, so I don't believe that reporting was accurate.
[4:30:28]But then after Epstein was incarcerated, let me rephrase that, one wire was made, it was retracted, and then two or three days before Epstein's arrest, he made a second wire.
[4:30:39]And after his incarceration, he requested that that wire be returned back to Charles Schwab or maybe I personally made the request. He didn't want to purchase that home anymore.
[4:30:51]And the money was returned and there's no money in Switzerland and all the money went back to Charles Schwab.
[4:30:56]Are you aware of if Morocco has any extradition treaty with the United States?
[4:31:05]I'm not aware of which countries have extradition.
[4:31:08]Did Mr. Epstein ever mention countries with extradition treaties?
[4:31:12]That's not something we ever spoke about.
[4:31:18]I'm going to introduce as majority exhibit four an email. We'll wait a second until it is passed out.
[4:31:53]Thank you.
[4:31:56]This is an email with the Bates number of EFTA 02125060.
[4:32:11]The two line is redacted.
[4:32:14]It is from a Janine Brennan sent on Wednesday, October 30th, 2013.
[4:32:21]The subject line reads heads up to expect a call from Mike Marvel.
[4:32:29]In the original message there at the bottom of the page, this is an email that appears to be from Miss Groff.
[4:32:40]As the signature line says, thanks so much.
[4:32:42]Leslie, is that accurate?
[4:32:44]Yes.
[4:32:46]And just above that, the email states, and I quote, Mike Marvel from Bank of America will be calling to speak with Jeffrey.
[4:32:54]But you need to connect the call to Rich Khan.
[4:32:57]Rich has been speaking with Mike as, in quotation marks, Jeffrey.
[4:33:00]Please do not bother Jeffrey with this.
[4:33:04]Did you impersonate Mr. Epstein in speaking with Bank of America?
[4:33:09]I don't recall this email, nor do I recall conversations with Mike Marvel from Bank of America.
[4:33:17]Did you ever have discussions with Bank of America?
[4:33:23]I believe, I thought I dealt with a woman by the name of Karen Weiss.
[4:33:29]I believe that Bank of America was the relationship where Leon Black had his accounts.
[4:33:39]And maybe there was conversations between Epstein and Black in regards to Epstein setting up accounts.
[4:33:47]But that's my only recollection of dealing with Bank of America.
[4:33:51]I will introduce as Majority Exhibit 5 another email.
[4:34:07]I'll give it a moment for that to get passed around.
[4:34:10]This is an email based stamped EFTA 02120271.
[4:34:29]The to line is Leslie Groff.
[4:34:33]The from line is Richard Khan.
[4:34:35]It was sent on Wednesday, November 27, 2013.
[4:34:39]Subject line reads Mike Marvel, Bank of America.
[4:34:42]It appears that the signature line has your name, Richard Khan.
[4:34:49]Is that correct?
[4:34:50]Yes.
[4:34:51]The email says, and I quote, I left him a message as if I was JEE.
[4:34:56]A redacted number for him to call.
[4:34:59]If he does, please forward to me.
[4:35:01]Thanks.
[4:35:02]JEE, is that often referred to as Mr. Epstein?
[4:35:06]Yes, JEE is Epstein.
[4:35:09]And did you call Bank of America impersonating Mr. Epstein?
[4:35:15]I don't recall the particular conversation as we sit here today,
[4:35:18]but it looks like from this email that's what it says.
[4:35:22]Would you often impersonate Mr. Epstein when dealing with entities or banking institutions?
[4:35:27]No.
[4:35:29]Do you recall any other times in which you would have impersonated Mr. Epstein?
[4:35:33]No.
[4:35:34]In dealing with his matters?
[4:35:35]No.
[4:35:36]Do you recall impersonating Mr. Epstein in this?
[4:35:39]I don't recall impersonating Epstein ever, but the email says I left him a message as if I was JEE.
[4:35:44]So those are my words, but I don't recall a conversation.
[4:35:49]It's possible it happened.
[4:35:51]I wrote something, but I don't recall the conversation.
[4:36:02]Would you have ever done that without Mr. Epstein's permission?
[4:36:05]I would never.
[4:36:07]My inference from this email is that Epstein had asked me to speak to the bank on his behalf.
[4:36:12]I would have never impersonated anyone without their permission.
[4:36:17]But I don't recall this fact pattern, but I could tell you that I never impersonated anyone
[4:36:23]unless Epstein asked me to call the bank and say you're JEE, but I don't recall the conversation.
[4:36:31]Are there any other times when Mr. Epstein explicitly told you to call and discuss matters as if you were Mr. Epstein himself?
[4:36:39]Not that I recall.
[4:36:40]Switching gears a little bit.
[4:36:48]You know, in the previous hour, some of the entities owned by Mr. Epstein were discussed.
[4:37:11]I believe you testified last hour that you believed every single entity was a legitimate entity.
[4:37:16]Is that a correct characterization of your testimony?
[4:37:19]Yes.
[4:37:20]And you had no concern over any of these entities whatsoever?
[4:37:25]Yes, I had no concern over any entities.
[4:37:28]Looking back with the subsequent knowledge you have since learned, do any of these entities present any red flags to you sitting here today?
[4:37:41]Looking back as co-executor and knowing what I know now, I still don't see any red flags with Epstein's entities.
[4:37:50]A lot of Epstein's companies held pretty high cash balances.
[4:37:58]Was there a reason why they held such high balances?
[4:38:03]If you don't mind, could you give me context to when you say his companies held cash balances?
[4:38:08]Epstein spent a lot of money from a lot of his entities, especially properties where he was doing construction.
[4:38:15]So if I'm understanding you correctly, if it was an entity that was a household
[4:38:26]and he was going to have bills and construction projects over the next two or three months, instead of sending wires every two weeks,
[4:38:33]we'd send a wire one time, possibly for $500,000 to pay for the next three or four months expenses.
[4:38:39]But if you're referring to his brokerage accounts, Epstein made all of his stock and bond investments on his own.
[4:38:47]I never offered him advice, so I don't know what his thoughts were on investing in the market or other entities.
[4:38:54]Were there any conversations or discussions about a maximum amount of money to hold in any entity?
[4:39:04]Not that I recall. You're asking the question, did XYZ entity have to hold a million dollars in cash at a certain point in time?
[4:39:16]Yes.
[4:39:17]Not that I'm aware of, but I do know that sometimes banks require companies to hold a certain amount of money in cash
[4:39:27]so that the banks could have the use of that money and pay very low interest rate, but I'm not aware of any arrangements like that.
[4:39:33]Were there any discussions or conversations about a minimum balance to hold in any of these entities' accounts
[4:39:41]with the understanding that, of course, banks often have thresholds, but outside of that?
[4:39:47]I believe whatever the bank would require, we would keep in order not to pay fees, but I'm not aware of minimum balances at all, no.
[4:39:55]You recall the entity named Nautilus and Poplar?
[4:40:02]Nautilus and Poplar, I believe they were title-holding entities.
[4:40:10]I believe Poplar was for the Virgin Islands residents, Little St. James, and Nautilus, I think, might have been New York title.
[4:40:23]And were you the treasurer or otherwise affiliated with any of these entities?
[4:40:28]I believe I was an officer for his entities, yes, for that entity, for the tree company entities, yes.
[4:40:35]Do you recall the entity named Cyprus?
[4:40:42]Yes, I believe Cyprus held title for his New Mexico property.
[4:40:46]And were you an officer of Cyprus Inc.?
[4:40:51]I believe at a certain point in time I was the treasurer. I don't recall the dates.
[4:40:57]And do you recall an entity named Maple Inc.?
[4:41:02]Maple Inc., maybe Maple owned New York, maybe Nautilus owned Florida.
[4:41:07]I'm not sure, but Maple Inc. was another entity that was set up for the sole purpose of holding title to one of Epstein's residences, yes.
[4:41:14]And were you an officer of Maple Inc.?
[4:41:17]I believe so, at a certain point in time.
[4:41:22]Are you familiar with a company named Laurel Inc.?
[4:41:27]I believe Laurel Inc. was the title holding company for his Florida residence.
[4:41:35]Were you an officer of Laurel Inc.?
[4:41:37]I believe so.
[4:41:39]And speaking about these title holding entities we just discussed, you indicated you were an officer at one point or another with all of them.
[4:41:51]What was your role in being an officer for these title holding companies?
[4:41:55]My role as an officer would be to make sure that the bills were paid, and these title holding companies, that the property tax bills were paid and that they filed timely tax returns.
[4:42:07]Did these entities have any other obligations outside of the ones you just mentioned?
[4:42:13]My understanding of these entities is that they were set up, they were USVI corporations, and they strictly held title to Epstein's residences.
[4:42:26]And the only bills that they paid on an annual basis were property taxes or maybe some filing fees, but that's all I understood that these entities did.
[4:42:39]Are you familiar with Gratitude America?
[4:42:42]Yes.
[4:42:43]And what is Gratitude America?
[4:42:45]It is a US Virgin Islands foundation that Epstein set up with the goal of giving money to scientific purposes as well as to the ideals of America.
[4:42:58]Were you an officer or any otherwise way affiliated with Gratitude America?
[4:43:04]Yes.
[4:43:05]What was your role?
[4:43:06]I believe I was treasurer and at one point I was president as well.
[4:43:10]And given those roles, what were your responsibilities with Gratitude America?
[4:43:17]With Gratitude America, similar to the tree entities we spoke about, my goal would be to make sure that Epstein was giving donations to 501c3 entities, make sure that he was properly filing his tax returns, and making sure that the books and records were accurate.
[4:43:37]Are you aware of any funds being paid by Gratitude America to any women for unrelated purposes than the stated purpose of the entity?
[4:43:49]Not that I'm aware of, no.
[4:43:53]Are you familiar with MC2 Model Management?
[4:43:57]Yes.
[4:43:58]And what is MC2 Model Management?
[4:44:00]It is not an Epstein-owned entity.
[4:44:03]However, it is an entity that was owned by Jean-Luc and I believe a few other partners.
[4:44:10]That was a modeling agency that Epstein gave a credit line to.
[4:44:17]Let me rephrase that.
[4:44:19]That Epstein backed a credit line.
[4:44:21]I believe they obtained a credit line from the bank and Epstein guaranteed it.
[4:44:24]And how much was that guaranteed?
[4:44:26]I believe at one point it was up to a million dollars.
[4:44:29]And why did Mr. Epstein provide a guarantee to the modeling agency?
[4:44:37]I don't know.
[4:44:38]And who is Jean-Luc Brunel?
[4:44:42]I believe he was one of the owners of MC2 modeling agencies.
[4:44:48]Are you aware of what Mr. Brunel's relationship was with Mr. Epstein?
[4:44:57]At the time, I assumed they were friends.
[4:45:03]I didn't know their relationship, but subsequently I read articles that said that they were friends.
[4:45:08]And I saw recent articles that said Jean-Luc and him had a falling out.
[4:45:13]Did you ever meet Mr. Brunel?
[4:45:15]I've probably met him a handful of times coming or going from a meeting, but we've never had any substantive conversations.
[4:45:23]Did you ever process any payments from Mr. Epstein or his entities to Mr. Brunel or MC2 model management?
[4:45:38]Process payments meaning?
[4:45:40]Did you send any money in any form?
[4:45:43]I believe at one point in time Epstein asked if money could be sent on behalf of, it may have been Svetlana.
[4:45:52]That's all I recall.
[4:45:55]Do you know what the purpose of the money for Svetlana was that was provided to MC2 model management?
[4:46:04]No, I do not.
[4:46:13]Do you have any concerns about Mr. Epstein's relationship with MC2 model management and the young women that were associated with it as well?
[4:46:24]I never met the women from MC2 model agency.
[4:46:29]The extent of my relationship with MC2 was as Epstein's accountant when the credit line was extended to the agency.
[4:46:41]I was making sure that it was paid down and paid off over time.
[4:46:45]So my dealings were predominantly with a gentleman by the name of Jeff Fuller,
[4:46:51]who I believe was John Luke's partner.
[4:46:56]And I would ask him the status of payments and make sure that they would be able to pay down the credit line so that Epstein didn't have to pay on that guarantee.
[4:47:27]Are you familiar with Roadruck Investigations?
[4:47:32]Yes.
[4:47:33]And what is Roadruck Investigations?
[4:47:35]I believe it's an entity that we used when we hired new individuals, employees rather, I'm sorry, to run background checks.
[4:47:50]Did you hire Roadruck Investigations to perform background checks on every new employer or new hire?
[4:47:57]I believe so.
[4:47:59]Was this PI firm used for any other purpose other than background checks on new hires?
[4:48:06]I got the name of Roadruck from either Epstein or Endyke, so I don't know what their previous relationship was with this organization.
[4:48:18]Are you familiar with the entity JEGE Inc.?
[4:48:25]Yes.
[4:48:26]And what is JEGE Inc.?
[4:48:28]JEGE Inc. was an S corporation that was set up to hold Epstein's Boeing 727 aircraft.
[4:48:38]Did it have any other purposes other than holding the Boeing 727 aircraft?
[4:48:42]It held title to the aircraft and also paid the expenses on operating that aircraft.
[4:48:49]Were you involved with JEGE Inc.?
[4:48:52]I was involved in a bookkeeping capacity.
[4:48:57]I was involved if the pilots were doing renovations and they needed to pay for the work that was being put in place, making sure that the work was proper.
[4:49:08]So I would communicate with them on projects relating to the plane, but that was the extent of my involvement.
[4:49:15]Is Mr. Epstein the owner of that entity?
[4:49:20]Epstein owned 100% of that entity, yes.
[4:49:23]Are you familiar with JEGE Inc. owned the 727, is that correct?
[4:49:45]Yes.
[4:49:46]Mr. Epstein also had another aircraft, is that correct?
[4:49:49]I believe he had two planes at most times. He also had a Gulfstream 2B originally and then sold that and bought another Gulfstream, yes.
[4:50:01]And which entity of Mr. Epstein's held the Gulfstream?
[4:50:06]I believe originally the Gulfstream 2B was owned by Hyperion Air Inc., another S Corp.
[4:50:15]And when Epstein sold the Boeing and sold the Gulfstream 2B, he bought maybe a Gulfstream 4 or 5, I don't recall.
[4:50:26]I believe that was owned by JEGE LLC.
[4:50:30]Mr. Epstein also owned a helicopter, is that correct?
[4:50:38]Yes.
[4:50:39]And which entity held the helicopter?
[4:50:42]Epstein owned many helicopters over the years.
[4:50:47]One of the first helicopters he owned, I believe, was owned by an entity by the name of Air Gillan Inc.
[4:50:58]When that helicopter was sold, I think he owned three or four helicopters over the years.
[4:51:03]And I believe some of the later helicopters were owned by Hyperion Air LLC.
[4:51:10]A lot of these entities, they have similar names.
[4:51:25]You have JEGE Inc., JEGE LLC, Hyperion Air Inc., Hyperion LLC.
[4:51:33]What is the purpose for having entities that are named similarly but not being the exact same entity?
[4:51:43]I don't know the process of how Epstein named his entities.
[4:51:49]Quite frankly, from my perspective, a lot of them were weird names, including the tree companies,
[4:51:53]but that's irrelevant for today.
[4:51:57]What I do know is that Epstein held one asset in each entity.
[4:52:01]So for the time that Epstein owned two planes, they would never be held in the same entity.
[4:52:06]When Epstein owned two helicopters at the same time, they were always in separate entities.
[4:52:10]But I don't know the significance for why or how he named the entities.
[4:52:15]Given your years of experience and expertise as an accountant,
[4:52:20]do you find that strategy to have similarly named entities as strange?
[4:52:28]I find nothing suspicious about having the same name of an entity.
[4:52:32]I mean, from working as an accountant with real estate,
[4:52:37]developers and property owners, many times they'll call it ABC1, ABC2, ABC3,
[4:52:44]and they'll just keep continuing the name they like and adding a number for each property they buy.
[4:52:48]So I find nothing suspicious about that, no red flags.
[4:52:52]Did Mr. Epstein own any boats or sea bearing craft?
[4:52:57]Yes, he owned a number of boats and jet skis at his U.S. Virgin Islands location, LSJ.
[4:53:07]And which entities would hold those boats and jet skis?
[4:53:16]The barge was held by an entity by the name of Shells Transportation, LLC.
[4:53:24]And he never owned a yacht.
[4:53:29]I think most of his boats were just to transport workers back and forth.
[4:53:37]They might have been owned.
[4:53:39]This might be the one circumstance where he did not put boats or aircraft in a separate LLC.
[4:53:48]From my perspective, it wasn't significant in the fact that these boats,
[4:53:54]I don't think any boat that Epstein owned was more than $50,000 or $100,000.
[4:54:01]And understanding that Mr. Epstein likely owned many cars over the time that you worked for him,
[4:54:09]which entities would have held the various vehicles that Mr. Epstein owned?
[4:54:15]Epstein typically held his cars by the entity where the car was located.
[4:54:22]So, for example, in New Mexico, for a period of time,
[4:54:26]there was Zorro Development that operated the ranch that then became Zorro Management.
[4:54:32]So those two entities owned his cars over time.
[4:54:36]In Florida, I think very early on when I first started working,
[4:54:41]Epstein owned cars in his individual name, one of two cars.
[4:54:45]But thereafter, he owned it in the entity Neptune LLC.
[4:54:51]Little St. James, the cars were owned, I believe.
[4:54:58]I don't think there was, I mean, it was an island.
[4:55:02]I think there was only one car and it was owned by his business, maybe Southern Trust or Financial Trust.
[4:55:10]New York would be the same.
[4:55:11]NES LLC would own, I think it was one or two vehicles in New York.
[4:55:18]And I believe the same goes for Paris.
[4:55:21]And which entity in Paris?
[4:55:25]I think the entity that Epstein held title to his property in Paris was an entity by the name of SCI.
[4:55:34]It was the name of the corporation that he held shares.
[4:55:36]I believe he was in a co-op there, owning multiple apartments.
[4:55:41]But I don't know if that entity held the cars or if he held them individually there.
[4:55:46]I don't recall.
[4:55:47]Understood. Are you familiar with Zorro Trust?
[4:55:51]Yes.
[4:55:52]And what was the Zorro Trust?
[4:55:54]Zorro Trust was the original entity that held title to the ranch.
[4:55:59]So before Epstein used the tree companies to hold title, he held title differently for all of his properties.
[4:56:08]And prior to, I believe Cyprus held title at Epstein's death.
[4:56:13]But prior to that, Zorro Trust held title to the ranch and Zorro Development paid the bills, owned the cars and did the operations.
[4:56:23]After that, title was held by Cyprus Inc. and Zorro Management paid the bills.
[4:56:28]Are you familiar with 116 East 65th Street LLC?
[4:56:34]I believe that was the entity that Maxwell owned her townhouse in.
[4:56:39]Do you have any role with that entity?
[4:56:41]I had no role with the entity other than the fact that I testified earlier that I helped her organize her finances.
[4:56:49]So potentially that entity had some of her staff that were on payroll and I may have helped her organize her finances with and understand her payroll.
[4:56:59]But I had no involvement with that entity in setting it up.
[4:57:03]And so that entity was owned by Ms. Maxwell?
[4:57:06]I believe so.
[4:57:08]Are you familiar with EGC Capital LLC?
[4:57:11]I don't know that entity.
[4:57:17]Are you familiar with Forums LLC?
[4:57:20]Yes.
[4:57:21]And what is Forums LLC?
[4:57:24]Forums LLC was an entity that was set up by Maxwell and funded by Epstein.
[4:57:36]And Forums LLC was involved in the 2005 Clinton Global Initiative.
[4:57:46]I believe that Forums had some sort of profit sharing with the entity that was putting that event together, which was called Publicis.
[4:57:57]I believe Publicis was producing the event, whatever that event was, I don't know.
[4:58:06]But Forums invested money and was in some sort of profit sharing agreement with Publicis.
[4:58:14]And I don't know anything more other than the fact that when I first began working with Epstein in late 2005 and later in 2006, I remember reviewing the financial statements from that event for the profit and loss of the Clinton Global Initiative.
[4:58:36]Were there any other entities that were involved with the Clinton Global Initiative or Clinton Foundation?
[4:58:43]I believe that Epstein made a $25,000 donation to one of Clinton's foundations in 2006.
[4:58:52]Do you know which entity that came from?
[4:58:56]I believe it was COUQ.
[4:58:59]Are you familiar with J. Epstein and Company Inc.?
[4:59:06]I'm not that familiar with that entity.
[4:59:12]I believe that was in existence prior to me starting, and I feel like it might have ended either right when I got there or before, but I think it was an entity.
[4:59:24]I don't know. I'm sorry.
[4:59:27]Are you familiar with Lin and Jojo LLC?
[4:59:31]Yes.
[4:59:32]And what was Lin and Jojo LLC?
[4:59:35]Lin and Jojo LLC was an entity that held real estate.
[4:59:42]And what real estate did it hold?
[4:59:45]It was a home in Valley Stream, New York.
[4:59:48]And whose home is that?
[4:59:51]I believe Epstein owns the home, but it was occupied by Lin and Jojo, his housekeepers.
[5:00:01]And driver.
[5:00:02]And driver. Thank you.
[5:00:10]Are you familiar with Enhanced Education?
[5:00:13]Yes.
[5:00:14]And what is the role of Enhanced Education?
[5:00:19]Enhanced Education was also known as the J. Epstein Virgin Islands Foundation, and it was a U.S. Virgin Islands Foundation that made donations.
[5:00:30]I don't know its proper business purpose of what it registered.
[5:00:34]I wasn't involved or around when it was originally set up.
[5:00:37]Are you aware of any payments from Enhanced Education to the Stockholm School of Economics?
[5:00:51]Yes, I most recently learned about that as co-executor.
[5:00:56]And what did you learn about that payment?
[5:00:59]I learned through a litigation that Epstein made donations to that entity.
[5:01:08]And did you have a role in processing or wiring that payment?
[5:01:17]I don't believe.
[5:01:20]I may have been on an email, but I couldn't have.
[5:01:23]I would have never initiated the payment because I don't approve payments to charities.
[5:01:30]And I would have never been able to sign the wire or check.
[5:01:32]But I may have been on an email where Epstein was asking for money to be sent, or maybe he asked me.
[5:01:39]And it was handed off to Bella and whoever the signatory was at the time.
[5:01:43]Understood.
[5:01:44]Are you familiar with the Florida Science Foundation?
[5:01:47]Yes.
[5:01:48]And what is the purpose of the Florida Science Foundation?
[5:01:51]I believe the Florida Science Foundation was a subsidiary of Kuk Foundation.
[5:01:59]And I believe that was a foundation he set up that was in place for when Epstein was incarcerated and going to his office six days a week.
[5:02:12]You said Kuk Foundation, is that C-O-U-Q?
[5:02:15]Yes, C-O-U-Q.
[5:02:17]Do you know when the Florida Science Foundation was established?
[5:02:22]I do not know.
[5:02:26]And you mentioned that it was established during his time being incarcerated in Florida.
[5:02:31]I believe so.
[5:02:33]Do you know why it was established?
[5:02:36]I don't know the purpose of why it was established, no.
[5:02:39]Did you have a role with the Florida Science Foundation?
[5:02:50]I don't recall specifically a role.
[5:02:53]I may have been an officer of the foundation, but I don't recall.
[5:02:59]I know the Florida Science Foundation had employees that were on payroll.
[5:03:05]So possibly I had a role with payroll, or Bella had a role, but I don't recall specifics.
[5:03:12]But I know it had a payroll for the people that worked in that office.
[5:03:18]Is it possible that you were the treasurer of the Florida Science Foundation?
[5:03:23]It's possible, but I don't recall.
[5:03:27]Did you process any payments to any women or girls while Mr. Epstein was incarcerated in 2008?
[5:03:36]Again, just to clarify, I never processed any payments.
[5:03:40]I may have been on an email chain where Epstein was asking if someone was going to be paid,
[5:03:45]I was never a signatory, nor was I ever had ability to send a wire transfer,
[5:03:53]other than, as I testified earlier, the two entities, JSC Interiors and Butterfly Trust.
[5:04:02]Switching gears a little bit, are you aware of Mr. Epstein assisting with visa applications for many young women during your times of employment with Mr. Epstein?
[5:04:15]I was not aware during employment, but I've seen many articles subsequently as co-executor that he was involved with visas for individuals.
[5:04:26]Did you review or process any payments in relation to applying for visas for young women?
[5:04:35]I don't recall specifics.
[5:04:39]I may have been asked to pay an immigration attorney.
[5:04:44]That would be the extent of my knowledge and involvement.
[5:04:47]Do you recall reviewing or initiating any payments to embassies or consulates regarding immigration paperwork for yourself?
[5:04:59]I'm not personally familiar with that.
[5:05:01]We will conclude our hour right there and go off the record.
[5:05:36]Back on the record.
[5:05:38]Mr. Conn, I don't have too much more for you.
[5:05:42]I wanted to return briefly to the subject of Mr. Epstein's estate.
[5:05:50]You spoke this morning about your appointment as co-executor.
[5:05:54]I wanted to turn your attention, if I could, to the 1953 trust.
[5:06:00]Yes.
[5:06:01]And it's my understanding that contemporaneous with the execution of the will, Mr. Epstein's assets were transferred into that trust.
[5:06:10]Is that correct?
[5:06:11]No, that's not correct.
[5:06:12]Please.
[5:06:13]Mr. Epstein's estate is being probated in the U.S. Virgin Islands probate court.
[5:06:18]And not until all of the remaining debts, credits, and outstanding obligations of the estate are satisfied will anything move to the trust.
[5:06:29]So currently, the trust does not have a bank account.
[5:06:32]The trust is not 100 percent operative and may never be operative if the estate ends with zero assets.
[5:06:40]So the trust document is his provisions when the estate is finally and fully probated.
[5:06:45]But at this point in time.
[5:06:47]Hasn't been effectuated.
[5:06:48]Correct.
[5:06:49]It's also my understanding that the trust agreement names yourself and Mr. Endyke as beneficiaries.
[5:06:58]Is that right?
[5:06:59]Yes, I am a beneficiary of the 1953 trust.
[5:07:02]And you are among the top three beneficiaries in terms of dollar amounts.
[5:07:09]Is that correct?
[5:07:11]I believe I am the in the top three of beneficiaries.
[5:07:15]Yes.
[5:07:16]And specifically, it's my understanding that the trust bequeaths $50 million to Mr. Endyke and $25 million to you.
[5:07:26]Is that correct?
[5:07:28]Yes, I believe that the trust has a bequest to me for $25 million.
[5:07:39]I think the question that arises then, given that you described your relationship to Mr. Epstein this morning as strictly professional.
[5:07:49]Why he would leave you at the quest of that size through his trust.
[5:07:56]So I was not involved in Epstein's drafting of his will documents.
[5:08:02]But what I can say is that Epstein asked me to be wasn't alive, but I was requested to be his co-executor and co-trustee.
[5:08:12]I believe that it's likely that I will receive zero from Epstein's 1953 trust based on the value of its assets and its remaining obligations.
[5:08:24]As of the last publicly filed quarterly accounting, the estate had approximately $120 million of assets.
[5:08:33]Most recently, the estate settled a lawsuit, a class action lawsuit for $35 million, which leaves approximately $85 million.
[5:08:45]The estate still has unfortunately four to five remaining lawsuits.
[5:08:50]In addition to the fact that it is burning approximately $10 to $15 million a year in legal fees and other expenses.
[5:09:01]As far as taking the role as co-executor, that's not a role that anyone would want.
[5:09:07]I decided to take the role as I testified earlier, as I thought I'd be best suited to know Epstein's assets and to be able to terminate employees in a respectful and kind fashion.
[5:09:20]Lastly, being able to compensate victims for all of their harms that they endured by Epstein was my top priority in taking this role after learning about all the terrible things Epstein did.
[5:09:33]To go back to your original question, actually let me just add one more point.
[5:09:40]Being co-executor has caused tremendous strife for me and my family.
[5:09:45]The anguish, anxiety, distress is unfathomable.
[5:09:51]My reputation has suffered what I believe to be irreputable damage that I don't know if I'll ever recover from taking this role.
[5:10:01]But you asked me the question, why do you think Epstein awarded $25 million to me?
[5:10:08]I was not involved in the drafting of his documents.
[5:10:11]But what I can say is that Epstein's estate of approximately $600 million,
[5:10:18]if his estate was being probated in New York or Florida and there was no designation of a co-executor fee.
[5:10:27]Currently Epstein's will calls for me to receive $250,000 for what will probably amount to 10 years of work.
[5:10:36]As I just said, I don't believe I will receive anything from Epstein's trust based on the assets and liabilities.
[5:10:42]I believe that Epstein envisioned me taking this role as co-executor and co-agent trustee would be many, many years of work.
[5:10:50]And at the same time, he didn't provide for what would be an executor fee in New York or Florida,
[5:10:56]which I believe the statutory rate is approximately 2%.
[5:11:00]So if I was not in Epstein's trust and I was a corporate trustee,
[5:11:04]I probably would have received an executor fee of $12 million for serving as co-executor and serving as co-trustee.
[5:11:13]So that could be the only reason why he left me such a large request.
[5:11:19]Because if you take away the $12 million, my request is not different than many other individuals that are in that trust for $10 million.
[5:11:27]And lastly, I would just say, other than compensating victims, I would never take on this role again as co-executor.
[5:11:36]Thank you. Switching topics again.
[5:11:41]The BBC yesterday reported that you told, I'm quoting directly,
[5:11:47]the mansion staff to pack two suitcases with the contents of the safe and deliver them to Epstein's home, according to FBI agents.
[5:11:55]Epstein's home? What does it say? Did it say Epstein's home?
[5:12:00]I'm sorry. Thank you, Dan. To his home. That'd be referring to your home, Mr. Khan. I apologize.
[5:12:07]Did you do that?
[5:12:08]No, I did not read the article, but I do know what you're referring to because the BBC had made inquiries myself.
[5:12:18]What happens when the FBI raided Epstein's home in, I believe it was on the 6th, the same day he was arrested.
[5:12:26]I think it was the 6th or the 7th. When they raided his home, they broke open his safe.
[5:12:32]And for whatever reason, the FBI did not take some of the contents from Epstein's safe.
[5:12:38]When the FBI broke into Epstein's home, they broke down his door so his door could not lock and the alarm could not set properly,
[5:12:45]in addition to the fact that they took all the electronic equipment.
[5:12:49]When Murdo and the house manager was at the house, they realized that these items were not safe to be left alone in the house.
[5:12:58]I was on Long Island at the time. I was not in New York City.
[5:13:02]And I received a call from Merwin, who's the property manager for 90 71st Street, telling me that I packed up two bags of Epstein's belongings or things that were safe.
[5:13:14]And I left them with your doorman in New York City. I just want to let you know.
[5:13:19]I said to him, I'm not home. I'll be home in three or four days. And, you know, at that time, I'll bring it up to my apartment.
[5:13:26]When I arrived home three or four days later, I arrived in my apartment. I brought the two bags up.
[5:13:32]I never touched them. I never opened them. I left them in my dining room.
[5:13:36]I believe a day or two later, I got a call from Merwin that the FBI was at the house again, looking to collect things that they didn't take from their first visit.
[5:13:50]I believe the request of me was, can you please bring the two bags to the home?
[5:13:55]I was at my office in Midtown at the time. I left. I went home.
[5:14:00]I grabbed the two bags. I brought them to the residence.
[5:14:04]And I believe at that point in time, the FBI gave me a receipt for the two bags.
[5:14:10]And that is what took place. What the BBC reported is inaccurate.
[5:14:15]And, you know, the story, as I understand it, is exactly what I told you.
[5:14:19]And then another topic. During your employment by Mr. Epstein, did you ever become aware of the relationship between him and Donald Trump?
[5:14:33]Did I ever become aware of the relationship?
[5:14:39]Donald Trump is someone that Epstein liked to talk about a lot.
[5:14:44]Did I become aware of a relationship?
[5:14:49]I assumed at one point they were friends and they had a falling out, but I don't know what is true and what is not true.
[5:14:58]He never spoke to me about his relationship with Donald Trump.
[5:15:02]And I've just seen a lot of stories in the news that I don't know whether they're true or not.
[5:15:07]You mentioned that he spoke about Donald Trump a lot. Did he ever do that in your presence?
[5:15:13]Yes.
[5:15:14]What did he say?
[5:15:16]Most of, I don't recall specific conversations,
[5:15:20]but most of the conversations relating to Donald Trump or relating to,
[5:15:26]sorry, I'm sorry, respectfully.
[5:15:28]Most of the conversations relating to President Trump were at the time where
[5:15:32]President Trump was in the news quite frequently from 2016 to 2020.
[5:15:38]And if President Trump was doing something that day and it made news,
[5:15:42]and I was in a meeting at his office, he might say, could you believe that President Trump did X, Y or Z?
[5:15:47]And it might be a 30 second conversation.
[5:15:50]But that was the context of how Epstein spoke in my presence about President Trump.
[5:15:55]And were any of his comments about having had a relationship with Trump?
[5:16:05]Just to try to be a little clearer, what you described was observations that in your telling sounded political in nature.
[5:16:14]I'm asking whether he made comments that were more social in nature.
[5:16:18]Not that I recall.
[5:16:24]Again, during the period of your employment by Mr. Epstein, did you ever become aware of the relationship between Mr. Epstein and Howard Lutnick?
[5:16:37]I was never aware of the relationship between Mr. Lutnick and Epstein.
[5:16:44]However, most recently I did see a lot of reporting on the matter.
[5:16:49]And I am aware of a few instances of communication that involve Mr. Lutnick and Epstein, either directly or indirectly.
[5:17:01]The first that I could speak of is in 2016, Mr. Lutnick was doing renovations on his townhouse.
[5:17:11]And I believe Mr. Lutnick's property or construction manager rather sent a note to the residents that I might have received.
[5:17:20]Or maybe it went to the property manager that said, you know, we apologize in advance.
[5:17:24]We're going to be making some noise. You know, please bear with us and let us know if there's any issues.
[5:17:27]That was the first.
[5:17:30]The second was that Epstein, through his friend David Mitchell, invested in a company called AdFin,
[5:17:38]which was trying to, I think they were trying to become like a Bloomberg terminal for purposes of advertising.
[5:17:46]And I believe at the time, Mr. Lutnick, either individually or through his entities, was one of the largest or the largest shareholder.
[5:17:57]The third thing that I became aware of most recently is that in 2017, John Paulson, hedge fund manager, made a request to Epstein.
[5:18:15]I don't know if it was a request. He sent him a note mentioning that the UJA was honoring Mr. Lutnick in December.
[5:18:23]Would you be interested in donating? And Epstein donated $50,000 from one of his foundations.
[5:18:31]And the last incident or correspondence that did not involve Epstein or Mr. Lutnick directly was involved Epstein seeking to seeking employment.
[5:18:49]Epstein was looking for a new personal assistant, along with some other positions he wanted to hire.
[5:18:56]And Epstein engaged a recruiting firm out of Milwaukee, which sent some resumes over, and I believe maybe they came to me first.
[5:19:05]And when I reviewed the resumes, one of the positions on one of the women's resumes said that she was a personal assistant for a private residence in Manhattan.
[5:19:18]And the recruiter then told me that this was Mr. Lutnick's residence.
[5:19:23]I sent the resumes to Epstein and informed him that this personal assistant used to work for your neighbor, Mr. Lutnick.
[5:19:33]Epstein said, OK, great. I'd like to interview this woman.
[5:19:37]I reached back out to the recruiter and the woman had already taken a job at that time.
[5:19:42]I never interviewed with Epstein.
[5:19:45]That's what I recall from most recent news reporting and understanding.
[5:19:54]Apart from this instance, were you ever involved in hiring any other personal assistants?
[5:20:00]I wasn't involved in hiring. I was simply the intermediary between the recruiter, me and Epstein.
[5:20:06]I never made decisions on hiring anyone.
[5:20:10]I got the resumes because I was dealing with the recruiter and his engagement letter, and they went first to me maybe to scream.
[5:20:17]But I never made a decision. I forwarded everything on to Epstein.
[5:20:23]I'm going to ask the reporter to mark what will be Exhibit M,
[5:20:28]which is an email dated October 3rd, 2013 between yourself and Mr. Epstein's subject line, Emily Johnson resume.
[5:20:47]Mr. Khan, do you recall this email?
[5:21:08]I don't. Most recently, when there was some news reporting and we received inquiries,
[5:21:14]I revisited this email, and I do recollect this email.
[5:21:20]And additionally, this is exactly what we just discussed.
[5:21:24]This is the individual you described?
[5:21:26]Yes.
[5:21:27]And who is Peter?
[5:21:29]Peter, I believe, is Peter Moller, was the gentleman that owns the recruiting or hiring agency from Milwaukee.
[5:21:42]He was the principal.
[5:21:45]And did you ever discuss this potential hire with Howard Lutnick?
[5:21:51]I don't ever recall meeting Mr. Lutnick.
[5:21:55]And then I will ask the reporter to mark as Exhibit N an email thread dated November 8th and 9th of 2017.
[5:22:15]Thank you.
[5:22:16]Subject UJA Wall Street Dinner honoring Howard Lutnick.
[5:22:24]Mr. Khan, is this the UJA solicitation that you described a few minutes ago?
[5:23:11]Yes.
[5:23:12]If I could point you to the second page, and this is the email from Mr. Paulson,
[5:23:23]containing the solicitation, and I'm looking at the second paragraph on the page.
[5:23:30]It starts with the words, as chairman.
[5:23:35]You see that?
[5:23:36]And for the record, the full sentence reads, as chairman of the Wall Street Division,
[5:23:39]I want to make sure that as a close friend of the Lutnicks,
[5:23:42]you are aware of the event and have the opportunity to support them.
[5:23:47]And my question is simply, do you, to your understanding,
[5:23:53]is Mr. Paulson's characterization of Mr. Epstein as a close friend of the Lutnicks accurate?
[5:24:05]Number one, I do not know what Epstein's relationship was with Mr. Lutnick,
[5:24:10]but I would say to you that this was what appears to me a standard email
[5:24:16]that was written and sent and forwarded to many individuals on behalf of Mr. Lutnick
[5:24:22]as Paulson was trying to raise money on his behalf.
[5:24:25]I do not believe that this email, as I read it today,
[5:24:28]was written directly and solely for Epstein.
[5:24:32]And did Mr. Epstein attend this event?
[5:24:35]I don't know.
[5:24:37]And just to confirm my understanding, he did contribute $50,000 in response to this solicitation.
[5:24:43]Yes, Epstein contributed $50,000.
[5:25:02]I asked you a few minutes ago, Mr. Kahn, about the relationship between Jeffrey Epstein and Donald Trump.
[5:25:10]I'm just going to ask you the same question with respect to Melania Trump.
[5:25:14]And specifically, during your employment by Mr. Epstein,
[5:25:17]did you ever become aware of a relationship between Jeffrey Epstein and Melania Trump?
[5:25:22]No.
[5:25:25]Did you ever provide payments to Melania Trump?
[5:25:27]No.
[5:25:39]Earlier today, I believe you testified that Mr. Epstein invested in a business with Ehud Barak.
[5:25:46]Is that correct?
[5:25:49]I do not know if they invested together or if Ehud Barak made an introduction to Epstein,
[5:25:56]for Epstein to invest in a business.
[5:25:58]And what was the nature of that business?
[5:26:01]It was a 911 software company that is today known as Carbine.
[5:26:07]And did Mr. Epstein proceed with that investment?
[5:26:10]Yes.
[5:26:11]What was the amount?
[5:26:13]I believe he made a few investments over time, something in the amount of $3 or $3.5 million.
[5:26:21]We can go off the record.
[5:26:27]All right. We will go back on the record. It is 4.37 p.m.
[5:26:46]Mr. Khan, I have a few more questions for you before we wrap up today.
[5:26:52]First, starting with Mr. Epstein wanting to open his own bank account,
[5:27:00]when did Mr. Epstein first receive his license to be able to open his own bank in the U.S. Virgin Islands?
[5:27:11]So I believe what you are referring to is Epstein's desire to use his IBE,
[5:27:18]his International Banking Entity, to provide banking for himself.
[5:27:27]My understanding is that Epstein received this license maybe in 2012 or 2013,
[5:27:37]and it sat dormant for five or so years, whereby Epstein was just paying annual fees to have this license.
[5:27:47]There were not that many IBE entity banks in the U.S. Virgin Islands, but there were a few.
[5:27:56]And Epstein's desire to activate this license and try to form his own bank
[5:28:03]after he was dropped by Deutsche Bank and was unable to find banking elsewhere.
[5:28:11]And did you discuss the idea of starting this IBE bank with him back in 2012, 2013, when he first received his licensure?
[5:28:22]I don't believe I was involved in him obtaining the license at all.
[5:28:27]I don't recall discussions. He may have said in passing,
[5:28:33]I have this entity, or maybe when the annual fees were paid, I knew what it was for, but we never had discussions about it.
[5:28:40]And at what point did Mr. Epstein express to you that he wanted to more thoroughly pursue this idea?
[5:28:49]I believe the timing was after the Miami Herald article, Deutsche Bank dropping him and him struggling to open up other banking relationships.
[5:28:59]And did you advise or otherwise help Mr. Epstein during this time of officially trying to pursue opening up his bank?
[5:29:09]Yes.
[5:29:10]And how did you advise Mr. Epstein in this?
[5:29:13]At the time, I had a friend who previously served, I don't recall his exact positions, but as an officer or owner of a bank.
[5:29:25]And Epstein engaged him, or Epstein's entity, which I believe at the time was Southern Country International,
[5:29:34]engaged this individual as a consultant to help the process of trying to figure out how to open a bank and how to run a bank.
[5:29:44]And did Mr. Epstein ever take concrete steps towards opening this bank?
[5:29:52]Yes, we began to, at the advice of the consultant, we were advised that in order to operate a bank efficiently,
[5:30:03]and I believe the consultant had bigger plans than just banking for Epstein, he wanted to be able to bank for the public as well.
[5:30:09]But the advice that he gave was that the entity, Southern Country International, needed to have a lot of capital.
[5:30:17]So some of the steps that Epstein was taking is two of the other entities where Epstein held his brokerage assets in cash were Southern Trust,
[5:30:27]Company Inc., and Southern Financial.
[5:30:30]I believe he started to transfer assets from those entities to Southern Country to start to build up a capital in that entity as part of the process to begin to activate this bank.
[5:30:44]And as part of the meetings with this consultant to initiate this bank, these meetings were in the U.S. Virgin Islands, is that correct?
[5:30:56]We did take one trip to the U.S. Virgin Islands, but most of the meetings were based in New York, either telephone conversations or emails.
[5:31:07]I believe Epstein met with the consultant maybe once, I don't recall specifically, but a plan was being formulated.
[5:31:15]And then we took a trip down to the U.S. Virgin Islands, the consultant and myself, whereby we met with another IBE entity that was already operating.
[5:31:25]And we met with some of the local officials in order to figure out how to activate the bank and making sure we adhered with the rules and regulations.
[5:31:37]Which local officials did you meet with?
[5:31:40]I don't recall. Maybe it had to do with someone in the banking division, but I don't recall.
[5:31:46]Did you ever meet with the then current governor of the U.S. Virgin Islands?
[5:31:52]I don't believe I ever met with Governor Mapp.
[5:31:55]Did you meet with any of the prior serving governors of the U.S. Virgin Islands?
[5:32:00]During that visit, we had dinner one evening with Cecile DeYoung, who was the office manager.
[5:32:12]She ran Epstein's St. Thomas office and her husband, who was the former governor, John DeYoung.
[5:32:20]Sorry.
[5:32:21]I want to add one thing. It was the consultant, myself, the two of them, and I believe it was two or three other individuals.
[5:32:27]And who are those other?
[5:32:28]I don't recall.
[5:32:30]Did you meet with any other elected officials of the U.S. Virgin Islands?
[5:32:35]Other than meeting with Governor DeYoung, I don't recall ever meeting with any other elected officials.
[5:32:42]Did anyone express any concerns about Mr. Epstein opening up this bank, giving his criminal and financial histories?
[5:32:58]I didn't hear any concerns in my visit.
[5:33:01]Was the bank ever officially started?
[5:33:09]No. We were in the process, as I said, of capitalizing the entity.
[5:33:14]And then shortly thereafter, Epstein was incarcerated.
[5:33:18]And then the entity ended up sending all the money back to where it came from, Southern Trusts and Southern Financial.
[5:33:25]And the entity was later dissolved.
[5:33:35]Mr. Kahn, in your years of accounting work for Mr. Epstein, did you ever record or review payments to individuals described as providing massage services?
[5:33:45]Did I ever record payments or see them? No, I don't recall ever seeing massage payments.
[5:33:50]Do you recall seeing any categories for payments following under the term massage?
[5:33:58]I don't recall seeing payments for massage.
[5:34:11]Are you aware of any purchases of massage tables or other massage goods for Mr. Epstein?
[5:34:18]I'm not familiar with those types of purchases.
[5:34:33]In April of 2019, did you receive a $1 million payment to your personal account from an Epstein-owned trust?
[5:34:40]Yes.
[5:34:41]And which trust sent you this money?
[5:34:44]That was the trust we spoke about earlier, the 2013 Butterfly Trust.
[5:34:48]Understood.
[5:34:49]Have you previously given a deposition, sworn statement, or formal interview about your role with Mr. Epstein prior to today?
[5:35:10]Yes.
[5:35:12]Which of those three have you provided?
[5:35:16]This is my third. So the first one was, I believe, Jane Doe versus JPMorgan Chase.
[5:35:23]And that was a deposition?
[5:35:25]A deposition, I believe, in May of 2023.
[5:35:30]And I gave another deposition in, I believe it was Jane Doe versus Epstein Estate and like at all.
[5:35:41]And that was in October 2024.
[5:35:47]Have you ever been formally questioned by any government authority in connection with Mr. Epstein?
[5:35:53]I've never been questioned by any government authority.
[5:35:56]Although I did receive, I believe, a grand jury subpoena request from the Southern District of New York,
[5:36:07]and I believe from the U.S. Virgin Islands Department of Justice.
[5:36:14]I'm not sure what division, but both of the requests were for the same thing.
[5:36:19]They were asking for Epstein's estate documents.
[5:36:24]They wanted to see his will and his 1953 trust.
[5:36:27]And I believe they also asked for prior versions of some of the trusts, which we complied with and provided.
[5:36:35]Have you ever been subject to any regulatory action?
[5:36:40]No.
[5:36:41]Any financial regulatory action?
[5:36:43]No.
[5:36:59]In, I believe it was September of last year, the committee issued a subpoena to the estate.
[5:37:13]And just for the record, the estate has complied with the committee subpoena.
[5:37:20]Based off of your testimony today, I just wanted to ask a follow-up question.
[5:37:25]And I can provide this as an exhibit if you all would like, but I'm just going to read a provision from the subpoena.
[5:37:31]It's item 13.
[5:37:33]All documents and communications, including but not limited to manuals or instruction booklets regarding or referring to the maintenance,
[5:37:40]management of properties or services performed at properties owned, rented, operated or used by Mr. Jeffrey Epstein from January 1, 1990 through August 10, 2019, including but not limited to.
[5:37:52]And we listed out several addresses as to our knowledge that we had two addresses for Mr. Epstein in New Albany, Ohio.
[5:38:06]Testimony from Mr. Wexner also indicated that Mr. Epstein had potentially purchased a home near Mr. Wexner in New Albany, Ohio.
[5:38:15]So my question to you is, are you aware of any properties owned by Mr. Epstein or any of his entities in New Albany, Ohio?
[5:38:23]As of Epstein's date of incarceration and as of today, Epstein does not own property in Ohio.
[5:38:30]I believe at one point he did own a home, but I believe from the time I began employment in 2005, he no longer owned property in Ohio.
[5:38:41]And is there any reason in which the estate would no longer have those documents to show the properties in Ohio?
[5:38:50]I never had those documents. They were never in my possession.
[5:38:55]So unless Epstein had the documents and they were in his emails, I don't know where the documents would be.
[5:39:03]And in the same vein you mentioned earlier today about an entity of Mr. Epstein that owned a home in Valley Springs, New York, I think.
[5:39:16]Valley Stream, New York.
[5:39:17]Valley Stream, New York. Does the estate have any documentation as to the ownership of the property in Valley Stream, New York?
[5:39:28]I believe, but I'm not 100% certain that the estate still owns that property.
[5:39:33]The property, I believe, was purchased with Epstein or Endyke as nominee owner for the benefit and use of Lynn and Jojo.
[5:39:48]Fortunately, Lynn is no longer alive and I believe Jojo lives there, but I believe it is property of the estate.
[5:39:58]And I believe it's property of the estate and I'm 100% certain it's property of the estate and reported on our publicly filed quarterly accounting.
[5:40:08]And then I have a broader question. I can explain it further if you need further explanation.
[5:40:22]If you indicate yes or no, if you indicate yes to one of these names, I will ask some follow-ups.
[5:40:29]If you indicate no, I will not have any additional follow-ups.
[5:40:32]But the question is, have you ever had a conversation with any of the following people about Jeffrey Epstein's crimes, his criminal investigations, or in regard to sexual activity of any kind of Mr. Epstein?
[5:40:44]The first name is Doug Band.
[5:40:47]No.
[5:40:48]Leslie Groff.
[5:40:51]No.
[5:40:53]Nadia Marsynkova.
[5:40:55]No.
[5:40:56]Sarah Kellan.
[5:40:58]No.
[5:41:01]Leslie Wexner.
[5:41:02]No.
[5:41:05]Ted Waite.
[5:41:06]No.
[5:41:09]Kathy Rummler.
[5:41:10]No.
[5:41:11]Bill Gates.
[5:41:13]No.
[5:41:14]Leon Black.
[5:41:16]No.
[5:41:17]Steven Sanofsky.
[5:41:21]No.
[5:41:22]Glenn Dubin.
[5:41:25]No.
[5:41:28]Eva Anderson Dubin.
[5:41:29]No.
[5:41:30]Any member of the Rothschild family?
[5:41:34]No.
[5:41:35]And then a couple more follow-up questions, I promise.
[5:41:44]Approximately how much money was the monthly payroll for all of Epstein's employees or contractors?
[5:41:57]I don't recall specifically, but I do have vague memories.
[5:42:01]I used to prepare for Epstein a budget on one sheet of paper that included all of his entities.
[5:42:08]And I believe his annual upkeep for everything, not just his employees, for his homes, employees, planes, cars, gifts, personal expenditures, was somewhere in the 25 to 30 million dollar range.
[5:42:24]And understanding that there can be some fluctuation, but in a similar vein, what were Mr. Epstein's total monthly expenses across everything under his entities or control or ownership?
[5:42:51]I'm sorry if I answered the previous question incorrectly.
[5:42:54]That was the number that I said relates to his total everything.
[5:42:59]Okay.
[5:43:00]Annually.
[5:43:01]Yes, annually.
[5:43:02]Yes.
[5:43:03]25 to 30 million dollars annually.
[5:43:04]That includes the fuel for his planes, repairs and maintenance for his planes, if he does a capital improvements on one of his properties, if he buys a car, if he gives a gift, if he hires a decorator, everything.
[5:43:21]Was Mr. Epstein at any point ever losing money?
[5:43:27]I guess it's a difficult question for me to ask because I just told you what his operations ran him.
[5:43:38]So in this example, we'll say 30 million dollars.
[5:43:41]Again, this is purely hypothetical.
[5:43:44]If Epstein had a stock, Apple stock he liked, he had a lot of Apple stock, if he had, you know, 100,000 shares of Apple stock and it went up 100 points, he would make, if my math is right, I think 10 million dollars.
[5:44:01]And then if he made other investments, he might make more than the 30 he was spending, but that was from passive and that was unrealized gains.
[5:44:09]But Epstein, as I explained earlier, earned fees from clients, from five clients over the years that I worked for Epstein.
[5:44:17]So in some years, if you're asking the question, in some years was his income from clients less than his expenses?
[5:44:24]Yes.
[5:44:25]But if you factor in his investments and many years he lost money in investments, you know, I can't say with certainty whether he was ever losing money, but sometimes his investments were making more money than he spent.
[5:44:38]And sometimes his income was more than his expenses, but I don't think there was a particular pattern or anything.
[5:44:45]And I believe you testified earlier that you had some concerns after Mr. Epstein's legal troubles in 2008 and 2009 when he was imprisoned.
[5:45:08]You decided to stay employed because you were a new bother.
[5:45:13]There was a financial crisis.
[5:45:15]Is that accurate to what you testified to today?
[5:45:18]In 2008, I trusted Epstein when he told me that it was a mistake that he was with a minor and that it would never happen again.
[5:45:27]But I still had concerns and I then evaluated along with the fact that we were in a financial crisis and I had a young family and I decided to stay.
[5:45:36]Yes, that was my testimony.
[5:45:38]And after 2009, did your concerns about Jeffrey Epstein end or wane?
[5:45:45]Are you referring to a particular time after he was released from prison?
[5:45:52]Just after he was released from prison.
[5:45:54]After Epstein was released, I could say affirmatively that I never saw a minor.
[5:46:01]I never saw a woman that was being abused.
[5:46:05]No woman had ever come to me and saying that she was under distress, that she was being sexually abused or sexually trafficked.
[5:46:12]I never saw any payments that he made that said they were for sex.
[5:46:16]I never saw payments that said cash massages.
[5:46:19]So although Epstein was still doing terrible things that I later learned as co-executor, at that point in time,
[5:46:29]I did not, during the later years, during 2009-19, I did not see any signs until the Miami Herald article that alerted me to me re-evaluating potentially leaving employment.
[5:46:43]There were times during the period of time that I wanted to leave on my own because I wanted to do something else,
[5:46:50]but I never saw signs from Epstein and later learning about the terrible things he did that made me want to leave in the interim.
[5:46:59]And after the Miami Herald article came out in November of 2018, why did you not decide to leave then?
[5:47:08]At that point, everything was happening quite fast.
[5:47:14]We got dropped by the bank and I was being asked to do things.
[5:47:17]I still was thinking about leaving, but I was quite busy at that time putting out fires.
[5:47:24]I would have liked to think with a clear head and me not dealing with trying to set up an IBE or open up accounts on Epstein's behalf.
[5:47:32]I would have certainly left working for him.
[5:47:37]And as a representative of the estate of Mr. Epstein, as a co-executor, is your responsibility in part to respond to subpoenas, is that correct?
[5:47:49]Yes.
[5:47:50]And have you ever withheld information that was requested by a subpoena or any civil discovery?
[5:47:56]I never personally withheld any information.
[5:48:00]However, our attorneys typically handle the subpoenas.
[5:48:07]And, you know, I could say that they do everything with 100 percent diligence.
[5:48:12]And I believe our attorneys have been praised by plaintiff's attorneys that said how cooperative our attorneys have been.
[5:48:20]So I don't have any knowledge that we've ever withheld any information.
[5:48:24]To the totality of your knowledge, both as your time working for Mr. Epstein and subsequently becoming a co-executor of his estate, was Jeffrey Epstein paid by individuals to traffic women to them?
[5:48:39]Was he paid by individuals? Not that I don't know.
[5:48:43]You have a deep awareness of Mr. Epstein's finances and financial situation.
[5:48:49]Did any of his funds come from the trafficking of women?
[5:48:54]No, not that I'm aware of.
[5:48:56]And does Mr. Epstein have any unexplainable income in your time as his personal accountant?
[5:49:04]No, I walked through today all of his income and I know where it was sourced from.
[5:49:11]As I testified earlier, with certain clients I was involved, especially Leon Black.
[5:49:18]But other clients I was not involved, so I can't speak to the services he provided for those individuals.
[5:49:24]But I have no reason to believe that any of his income was earned in an improper fashion.
[5:49:30]And apologies if I missed this earlier.
[5:49:44]What was the total amount of compensation that was paid by Leon Black to Mr. Epstein for his financial arrangement?
[5:49:51]I believe that I said he paid in fees approximately $150 million.
[5:49:57]It would be up or down 5%.
[5:50:01]And Mr. Black also contributed $10 million to one of Epstein's foundations.
[5:50:06]And with that we will go off the record.
[5:50:24]Back on the record.
[5:50:40]Mr. Connachs, I have one last question for you.
[5:50:44]You spoke in our first hour of testimony this morning about the Jane Doe IV case.
[5:50:51]Yes, and I believe is when we...
[5:50:54]Okay, yes I did.
[5:50:56]My question is simply, is there anything additional beyond what you've already discussed that you can share with the committee about the status of the settlement in that case?
[5:51:09]I may have made a mistake as to which plaintiff that is, because we've had quite a few.
[5:51:16]We have just a lot, so I can't quite remember Jane Doe IV with 100% certainty.
[5:51:26]So I think we said the right...
[5:51:29]I think we know, but I'm not 100% certain.
[5:51:33]And I apologize because I generally know these, but I just don't know...
[5:51:40]Do you know who it is?
[5:51:43]We do, and we're willing to have a discussion off the record.
[5:51:46]Yeah, off the record.
[5:51:48]But if you don't mind, to the extent that you believe it is this person, you've been informed by your counsel that it is this person, we'd like to answer the question right here today.
[5:51:56]If it is not that person, we figure out that Jane Doe IV is someone else.
[5:52:00]We're happy to have that conversation after.
[5:52:03]I'd rather find out who it is so I can answer.
[5:52:06]Can we just go off the record for two seconds?
[5:52:09]Sure.
[5:52:10]Well, no.
[5:52:11]Off the record.
[5:52:22]Yes.
[5:52:23]When we were off the record, we had a discussion about an individual previously described as Jane Doe IV.
[5:52:31]The name that was provided to us in confidence or off the record as to Jane Doe IV's last name is not a name that neither I nor Mr.
[5:52:44]Khan is familiar with.
[5:52:46]We do not recognize that individual to be someone who has brought claims against the estate or that we have mediated with and resolved a case.
[5:53:03]We can go off the record.