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Meanwhile, Indyke was listed as secretary of The Wexner Foundation—a nonprofit founded by Epstein's only known clients, ex-Victoria's Secret mogul Leslie Wexner and his wife Abigail—in SEC filings from 1998 to 2001. The nonprofit's tax forms also listed Indyke as secretary through 2006. Two years later, Abi
e 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 Charitable Fund in 2008, just before Epstein started his Palm Beach jail sentence. According to one CNBC report, Epstein's nonprofit gave $14
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
Meanwhile, Indyke was listed as secretary of The Wexner Foundation—a nonprofit founded by Epstein's only known clients, ex-Victoria's Secret mogul Leslie Wexner and his wife Abigail—in SEC filings from 1998 to 2001. The nonprofit's tax forms also listed Indyke as secretary through 2006. Two years later, Abi
e 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 Charitable Fund in 2008, just before Epstein started his Palm Beach jail sentence. According to one CNBC report, Epstein's nonprofit gave $14
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
ter." 127. Before Staley, Epstein relied heavily on the massive wealth bestowed upon him primarily by one individual, Leslie (Les) Herbert Wexner ("Wexner"), to give him the appearance of grand importance while relying on his then-madame, Maxwell, to find and groom young women to be abused. 128. It h
Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 36 of 130 Epstein's international sex trafficking operation, most notably Ghislaine Maxwell, Les Wexner, Jean Luc Brunel, and Jes Staley, acting through and on behalf of JP Morgan. 139. In later years, Deutsche Bank swapped in for JP Morgan and provid
19-JSR Document 36 Filed 01/13/23 Page 72 of 130 and the identities of the individual Class members are ascertainable through records maintained by the Epstein Estate and JP Morgan, including but not limited to JP Morgan's records for Epstein-related accounts (e.g., account ledgers reflecting payments from Epstei
20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's reportedly prior girlfriend. 69. Each of these red flags was serious; together, they suggest a p
Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's
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
20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's reportedly prior girlfriend. 69. Each of these red flags was serious; together, they suggest a p
Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's
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
Entities connected to both Les Wexner and the Epstein Estate

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
Financial Trust Company
ORGANIZATIONLeon Black
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Marc Rich
PERSONJane Doe
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
United States
LOCATION
Harvey Weinstein
PERSON
Jean-Luc Brunel
PERSON
Abigail Wexner
PERSON
Palm Beach
LOCATION