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e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA00163123 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA01654941 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
CGLacs e. 22-1kod.-CIfia91143BRDOnntuantataa PDS EIC1O12/23 Page 11B aff ain accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
EFTA00161851 Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 17 of 34 accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
Entities connected to both the Epstein Estate and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Richard Kahn
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATIONJane Doe
PERSON
Les Wexner
PERSON
United States
LOCATIONV.I.C.
ORGANIZATIONGratitude America
ORGANIZATION
Deutsche Bank
ORGANIZATION
Bradley Edwards
PERSON
JPMorgan Chase
ORGANIZATIONSouthern District
LOCATIONHyperion Air
ORGANIZATION
Glenn Dubin
PERSON
Condoleezza Rice
PERSONJEGE, Inc.
ORGANIZATIONVirgin Islands Department of Justice
ORGANIZATION