In November 2017, Indyke signed a Foundation check made payable to the
immigration lawyer in New York who was involved in one or more forced marriages arranged
among Epstein’s victims to secure a victim’s immigration status. The check’s memo line
references the former Russian model’s last name.
87. These payments were inconsistent with the charitable purpose of the Foundation
and designed to serve the private benefit and criminal activities of Epstein and the Epstein
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