--- alias: - AdFin Solutions - AdFin Solutions, Inc. - AdFin - Adfin - AD/FIN - Ad/Fin category: Private Organization created: 2026-10-04 location: New York, New York relations: - fn: 4 reverse: true role: Series A preferred purchaser (1,142,857 shares for $499,999.94 on April 10, 2013; 285,714 shares for $124,999.87 on July 23, 2013) start: 2013-04-10 type: funded with: '[[Southern Trust Company]]' - fn: 5 reverse: true role: Series A preferred purchaser (800,000 shares for $350,000); purchaser of a $2,000,000 unsecured convertible note dated December 26, 2013 start: 2013-07-23 type: funded with: '[[CVAFH I LLC]]' - fn: 5 reverse: true role: ultimate holding company of CVAFH I LLC according to the July 2013 letter agreement; largest shareholder at 60.32 percent on January 4, 2018 start: 2013-07-23 type: funded with: '[[Cantor Fitzgerald]]' - fn: 7 reverse: true role: president and chief executive officer start: 2012-11-05 type: head_of with: '[[Jeanne Houweling]]' - fn: 16 reverse: true role: chief executive officer start: 2014 type: head_of with: '[[Andrew Altersohn]]' - fn: 3 reverse: true role: board member and Series A purchaser start: 2012-12-28 type: director_of with: '[[David Mitchell]]' - fn: 3 reverse: true role: board member, Series A purchaser and lender start: 2012-12-28 type: director_of with: '[[Jonathan Leitersdorf]]' - fn: 15 role: Form D (accession 0001595302-13-000001, file number 021-208986) filed December 31, 2013 under item 06b; first sale 2012-12-28; total amount sold $4,149,157; signed by Jeanne Houweling, CEO, December 30, 2013 start: 2013-12-31 type: subject_of with: '[[Securities and Exchange Commission]]' summary: AdFin Solutions was a Delaware advertising-analytics company whose Series A investors included Jeffrey Epstein's Southern Trust Company and CVAFH I LLC, described in a July 2013 letter agreement as held ultimately by Cantor Fitzgerald. tags: - Organization - AdTech - ProgrammaticAdvertising - JeffreyEpstein - CantorFitzgerald - HowardLutnick - SouthernTrust - EpsteinFiles updated: 2026-10-04 --- AdFin Solutions, Inc., styled AD/FIN, was a Delaware corporation incorporated on April 25, 2011 that ingested and harmonized log-file data on winning bid transactions in programmatic advertising and sold pricing and media-audit analytics built on it.[^1][^2] Its Series A preferred stock was bought in 2012 and 2013 by Jonathan Leitersdorf, David Mitchell, Tom Glocer, [Southern Trust Company](/organizations/southern-trust-company/), Inc. (whose signature blocks name [Jeffrey Epstein](/people/jeffrey-epstein/) as president) and CVAFH I LLC, a vehicle whose ultimate holding company, according to a July 2013 letter agreement, was [Cantor Fitzgerald](/organizations/cantor-fitzgerald/), L.P. The company ceased operations in October 2019.[^3][^4][^5][^6] ### Incorporation and the Series A The Series A Preferred Stock Purchase Agreement is dated December 28, 2012 and provides for an initial closing that day at the offices of company counsel DLA Piper in East Palo Alto, at a price of $0.4375 per share, with each subsequent closing deemed a Closing under the agreement. The initial closing on that date involved two purchasers: Mitchell, for 685,714 shares ($299,999.88), and Leitersdorf, for 3,428,571 shares ($1,499,999.81), a total of $1,799,999.69. The agreement fixes a five-member board of Leitersdorf, Gil Mandelzis, Roy Lowrance, Jeanne Houweling and Mitchell.[^3] The company's schedule of exceptions records that Houweling had been hired as president and chief executive officer under an employment agreement dated November 9, 2012, effective November 5, 2012, and that the company "has received loans totaling approximately $1,500,000 from Jonathan Leitersdorf, a director and sole stockholder of the Company."[^7] In a February 2016 letter to his co-investors Mitchell called Leitersdorf the company's "founder."[^8] On March 21, 2013 Mitchell wrote to Epstein about the voting rights attached to the investment: "I was invited into this transaction by Jonathan as part of the negotiations I asked for and got the 90 percent majority voting on certain major decisions. I suggest going forward that you and I split this, meaning it would take both of us to agree on major changes, or you and Jonathan would have to agree, or in the last case Jonathan and I would have to agree." Epstein answered "Ok" on March 22, 2013.[^9] ### The 2013 closings and the counterpart signature pages The Schedule of Purchasers (Exhibit A) lists two later closings. For the subsequent closing of April 10, 2013 it lists Southern Trust Company, Inc. for 1,142,857 Series A shares at $499,999.94 and Tom Glocer for 228,571 shares at $99,999.81, alongside other individual purchasers. For the subsequent closing of July 23, 2013 it lists CVAFH I LLC for 800,000 shares at $350,000 and Southern Trust Company for a further 285,714 shares at $124,999.87, alongside Mitchell, Leitersdorf, Mandelzis and one other individual; the total line reads 7,940,935 shares and $3,474,158.50.[^4] The same closing set contains counterpart signature pages to the purchase agreement, the Investors' Rights Agreement, the Right of Refusal and Co-Sale Agreement and the Voting Agreement. For Southern Trust Company, Inc. the signature block reads "Name: Jeffrey Epstein," "Title: President." For CVAFH I LLC each block reads "Name: [Howard W. Lutnick](/people/howard-lutnick/)," "Title: President." The CVAFH page of the purchase agreement carries a handwritten line in the margin, "[Signature Page to $350,000 Series A Preferred Stock Investment in AdFin Solutions, Inc.]." The Voting Agreement's Exhibit A, the Schedule of Investors, lists "Southern Trust Company, Inc." with 1,428,571 shares and "CVAFH I LLC" with 800,000 shares.[^10] A letter agreement dated July 2013 on the letterhead of "Cantor Ventures, L.P.," 110 East 59th Street, refers to "the closing of the investment in the Company by CVAFH I LLC ('Cantor') on the date hereof" and states: "Cantor has been formed for the specific purpose of acquiring the Shares and the ultimate holding company of Cantor is Cantor Fitzgerald, L.P., a Delaware limited partnership." The signature block for CVAFH I LLC on that letter reads "Title: President." Stock certificate PA-7, dated July 23, 2013, certifies that "CVAFH I LLC is the record holder of Eight Hundred Thousand shares of Series A Preferred Stock of AdFin Solutions, Inc."[^5] ### The $2 million convertible note A Note Purchase Agreement dated December 26, 2013 provided for the sale of "an unsecured convertible promissory note in the principal amount of $2,000,000" to a single investor, CVAFH I, LLC, whose Schedule I address is 499 Park Avenue. The signature page for CVAFH I, LLC bears the handwritten name "Douglas Barnard" and the title "Chief Financial Officer." A stockholder consent of the same date, required under the certificate of incorporation for debt above $250,000 and for the written consent of holders of at least 66 percent of the Series A, has signature pages for Leitersdorf, Mitchell, Southern Trust Company, Inc. and CVAFH I, LLC, the last two dated December 26, 2013.[^11] On January 7, 2014 Mitchell wrote to Epstein: "We completed a $2 million convertible placement with Cantor Ventures at the end of the year." He listed the terms (conversion at the lower of 50 percent above the investors' price or the valuation of the next round, an 8 percent coupon, a one-year maturity, and "If and when they convert they get a board seat (we will have to increase board to 7 people as we have 5 now)") and added that "Cantor is doing another $4 million in April targeting a $16-18 million valuation," that Mitchell was separately trying to raise at a higher valuation ("Cantor can match this as they have ROFR"), and that under an existing arrangement "either two of the three of us (JEE, JL or DJM) could block certain actions of the Company."[^12] On January 13, 2014 Epstein's lawyer [Darren Indyke](/people/darren-indyke/) sent [Lesley Groff](/people/lesley-groff/) the executed bridge-loan consents and note purchase agreement with the instruction to file them "in AdFin redweld in a folder called $2MM Bridge Note Financing December 2013."[^13] An August 11, 2014 term sheet for a follow-on financing, which describes itself as "an expression of intent only" and "not meant to be binding," described the proposed notes as "on substantially the same terms" as "the existing $2,000,000 of unsecured convertible debt issued to Cantor Ventures in December 2013 (the 'Cantor Debt')," except that the lenders "will not be entitled to elect a member to the Board upon conversion of the Notes as Cantor Ventures is entitled to upon conversion of the Cantor Debt."[^14] ### The Form D of December 31, 2013 AdFin Solutions, Inc. filed a Form D (Notice of Exempt Offering of Securities) with the [Securities and Exchange Commission](/organizations/securities-and-exchange-commission/) on December 31, 2013 under accession number 0001595302-13-000001 and SEC file number 021-208986. The submission header gives the filing date as December 31, 2013, the acceptance time as 17:49:05 on December 30, 2013, and the issuer's central index key as 0001595302. The filing records the issuer as "AdFin Solutions, Inc.," a corporation, jurisdiction of incorporation "DELAWARE," year of incorporation 2011, with a previous name "AdFin Services, Inc."[^15] The offering fields read: federal exemption item "06b"; "isAmendment" false; "dateOfFirstSale" 2012-12-28; duration of offering "moreThanOneYear" false; type of securities "isEquityType" true; "isBusinessCombinationTransaction" false; revenue range "Decline to Disclose"; industry group "Other"; minimum investment accepted 0. The amounts read: "totalOfferingAmount" 4,484,375; "totalAmountSold" 4,149,157; "totalRemaining" 335,218; "totalNumberAlreadyInvested" 11; "hasNonAccreditedInvestors" false. Sales commissions, finders' fees and gross proceeds used are each recorded as 0.[^15] The related persons listed are Jeanne Houweling ("Executive Officer" and "Director"), Jonathan Leitersdorf ("Director"), Gil Mandelzis ("Director"), David J. Mitchell ("Director") and Tom Glocer ("Director"). The signature block reads "/s/ JEANNE HOUWELING," name of signer "Jeanne Houweling," title "CEO," date 2013-12-30.[^15] ### Management changes, 2014 and 2015 Andrew Altersohn was chief executive by September 2014. On September 12, 2014 Mitchell asked Groff to arrange time with Epstein for the new chief executive: "Andrew Jeffery is the principal behind AdFin's investor Southern Trust. Andrew is the new CEO of AdFin and I mentioned to JE this morning I would like him to meet."[^16] On December 15, 2014 Mitchell sent Epstein a presentation and wrote that the company was "6-9 months behind where it thought it would be," that it had received a buyout offer of "$12-15 milion" which "the board did not think much of," and that "the new CEO is much better than the old one."[^17] On March 16, 2015 Leitersdorf confirmed to Mitchell, in a message Mitchell forwarded to Epstein on March 23: "True up to 7% when cantor exercises their option to convert to equity and we all get diluted."[^18] ### The February 2016 proposed terms A letter of February 16, 2016 from Mitchell to his co-investors reported: "On Friday, the Board of Adfin voted to accept an offer from its largest shareholder, Cantor Venture, to fund $1,750,000. Alongside its founder, Jonathan Leitersdorf, Cantor has been funding the Company for the past two years on a bridge loan basis." Its Exhibit A, a summary of the proposed terms, lists "Conversion of approximately $7.3M in outstanding debt from Cantor, Julserra, David Mitchell and Southern Trust" and a board "increased to 7 directors. All chosen by Cantor, but each 10% or greater stockholder will have the right to appoint 1 director ... for now only Julserra and the Board must include the CEO," adding that "Howard Lutnick, Jed Kleckner and Henrique de Castro will join the Board." It continues: "Cantor will effectively control decision-making power at the Board and stockholder level subject to very limited minority rights protection set out in a new Shareholders Agreement and to fiduciary duties under Delaware law," and "AdFin will be majority owned by Cantor."[^8] A company investor presentation in the same file, dated February 2016, carries a slide headed "Backed By Leaders" stating "AD/FIN is backed by Cantor Fitzgerald, one of the world's leading financial services firms, and prominent angel investors." Beneath photographs, the captions read "Howard Lutnick, Chairman and CEO, Cantor Fitzgerald," Tom Glocer, "Former CEO, Thomson Reuters," Leitersdorf, "Founder, Julserra Capital," David Mitchell, "President, Mitchell Holdings LLC," and Gil Mandelzis, "Executive Chairman, Traiana, Inc." (page EFTA01084707).[^8] ### Southern Trust's 2018 request to sell A cap table "as of 1.4.18" in a company presentation lists Cantor with 85,959,207 shares (60.32 percent) and $11,742,954 invested, Julserra with 26,234,837 shares (18.41 percent) and $3,655,758 invested, and Southern with 6,409,679 shares including 110,619 options (4.50 percent) and $889,000 invested, out of 142,495,899 shares.[^19] In an email thread of January 2018 with Mitchell and [Richard Kahn](/people/richard-kahn/), Epstein's accountant, Altersohn wrote on January 26 that "we are trying to get a meeting with Howard next week." On February 13, 2018 he wrote to Kahn: "yes, finally met with Howard. All went well, but as always a few followup items I need to work on this week, most importantly finalizing the exact amount of the raise and per share valuation." On February 26 he sent details of an A-4 round ("Cantor and Julserra are taking their relative pro rata of $1.5M in a firm commitment over 3 tranches February to June 2018") and wrote that "Southern is already a party" to the shareholders agreement and that, to maintain its pro rata share, "Southern would have to invest in $85,695." Kahn forwarded this to Epstein, who answered: "you can tell them we are a seller at cost. 875 and we are out." Kahn then wrote to Altersohn that "we would be interested in selling for our cost of $875,000 which is approx 68% of FMV" and asked him to "communicate to existing investors and any other prospects you speak with during this Series A-4 round." On March 13 Altersohn answered a request for an update with "No, but let me check in and get back to you"; on March 14 Kahn forwarded this to Epstein with the note "still waiting on response to purchase our interest.." On April 13, 2018 Altersohn wrote: "We were trying to get a response from Howard and Jonathan on your ask, but there is apparently no interest at this time on the sale of your interest. We are however in discussions with other potential investors so if there is interest I will let you know." The emails give no surname for "Howard."[^20] On April 3, 2018 Mitchell wrote to Kahn, copying Epstein, "meeting Jonathan next week on potential buy of AdFin Holdings." On September 18, 2018 he wrote to Epstein, "Jonathan seeing him this week and trying to get to buy Adfin position." On October 18, 2018 he sent slides with the note that the company needed "to get to a few million dollars until they are a real candidate to be sold" and that "in the fall next year, a capital event could happen which would return money."[^21] ### The May 28, 2018 email On May 28, 2018 at 1:12 p.m. Epstein wrote to an address labeled "HWL" with a Cantor Fitzgerald disclaimer footer: "on another note what do you think the prospects for adfin are?" The reply at 1:19 p.m. read: "Producing revenue finally. This is their year. Next 12 months they need to become economically self sufficient." Epstein wrote at 1:23 p.m., "thx. how long until sherry is ready , and i can buy my guest house?" and HWL answered at 6:07 p.m. UTC, "Probably 4 years (pierre). We'd need to actually do something for it to ever finish. Haven't even picked an architect/designer yet. Too much construction. Just finishing this house."[^22] ### Statements before the House Oversight Committee In a transcribed interview with the [House Committee on Oversight and Government Reform](/organizations/house-committee-on-oversight-and-government-reform/) on May 6, 2026, Lutnick gave these answers. Asked "During your visit to the island, did you discuss the company AdFin Solutions with Mr. Epstein?" he answered "No." (p. 26). Asked what AdFin Solutions was: "It was a company that attempted to create an exchange for online ads. They went out of business." "Were you personally an investor in AdFin Solutions?" "No." "Was Cantor Fitzgerald an investor in AdFin Solutions?" "Yes." Asked which part of Cantor Fitzgerald: "It was called Cantor Ventures ... it was a venture capital arm of Cantor Fitzgerald, so sort of multiple layers down the subsidiary chain" (pp. 26 to 27). A questioner stated that a stock purchase agreement released under the [Epstein Files Transparency Act](/concepts/epstein-files-transparency-act/) was one "that you signed on behalf of CVAFH and Mr. Epstein signed" and asked "Did you know that Mr. Epstein was an investor in this company AdFin?" Lutnick answered "No," and that he learned it "when these documents were released" (p. 27). On the signature page appearing in Epstein's files: "I found it inexplicable and unsettling that he had ... that it was released, that my company's signature page would be in someone else's files" (p. 27). On the 2018 email: "This was ... this was me, because it says 'HWL'" (p. 29); asked whether he knew during that exchange that Epstein was an investor: "I do not remember that I knew that, no" (p. 88). On timing: "I don't think I heard about this investment till 2013, May. I think the pitch was made to me in May of 2013, from the document. So it wasn't in December" (p. 88). His counsel at the interview, Zachary Terwilliger of Vinson & Elkins, stated that the documents show that "when Cantor Fitzgerald Venture Capital signed these documents, it was ... much later ... in 2013 in the spring" and that "I do not consider this a business dealing with Mr. Epstein" (pp. 87, 89).[^23] ### Reporting in 2026 The [BBC](/organizations/bbc/) reported on July 14, 2026 that [Simon Andriesz](/people/simon-andriesz/), a former employee of Lutnick's firm, searched the released [Epstein files](/concepts/epstein-files/) for "HWL" and found the May 28, 2018 exchange, which he gave to members of the House committee before Lutnick's interview. The BBC wrote that Epstein "had talked directly to Lutnick about a digital advertising company called Adfin, in which he and Lutnick's firm, Cantor Fitzgerald, had both invested," and that Lutnick "repeated his claim to the committee, that he did not know until this year that Epstein had been a co-investor in Adfin." The Commerce Department told the BBC there was "no evidence of wrongdoing or legitimate cause for concern."[^24] ### Closure An AdExchanger article of July 29, 2019 described a 2016 study the company undertook with the Association of National Advertisers and Ebiquity that strained its relations with agency holding companies, and reported that in January 2019, after Altersohn's departure, Ravi Patel and Matt DeLoca became co-chief executives, with the investors holding them "on a tighter leash."[^25] On October 17, 2019 AdExchanger reported that "Ad/Fin ceased business operations on Friday," that the company "let go of all 16 of its employees" and was "considering selling its technology," and that "its investors, who were extremely patient with the company during the ANA saga, eventually pulled out." Patel was quoted: "The burn rate caught up to us."[^6] [^1]: U.S. Department of Justice, Epstein Library, EFTA00289540, DataSet 9, Delaware Secretary of State certificate for AdFin Solutions, Inc. ("was incorporated on the twenty-fifth day of April, A.D. 2011"), in the closing set beginning EFTA00289477. https://www.justice.gov/epstein/files/DataSet%209/EFTA00289540.pdf [^2]: Alison Weissbrot, "How Ad/Fin Got Caught In The Crossfire Of The Industry's Transparency Crusade," *AdExchanger,* July 29, 2019. https://www.adexchanger.com/agencies/how-ad-fin-got-caught-in-the-crossfire-of-the-industrys-transparency-crusade/ ; Alison Weissbrot, "After A Rocky Road, Ad/Fin Shuts Its Doors," *AdExchanger,* October 17, 2019 ("Launched in 2012 as a tool to benchmark pricing data in programmatic media"). https://www.adexchanger.com/agencies/after-a-rocky-road-ad-fin-shuts-its-doors/ [^3]: U.S. Department of Justice, Epstein Library, EFTA00289560, DataSet 9, AdFin Solutions, Inc. Series A Preferred Stock Purchase Agreement dated December 28, 2012, sections 1.2, 2.1 and 5.7 and Exhibit A (initial closing). https://www.justice.gov/epstein/files/DataSet%209/EFTA00289560.pdf [^4]: U.S. Department of Justice, Epstein Library, EFTA00289560, DataSet 9, Exhibit A, Schedule of Purchasers (pages EFTA00289583 to EFTA00289585). https://www.justice.gov/epstein/files/DataSet%209/EFTA00289560.pdf [^5]: U.S. Department of Justice, Epstein Library, EFTA00289560, DataSet 9, letter agreement of July 2013 between AdFin Solutions, Inc. and CVAFH I LLC (pages EFTA00289678 to EFTA00289680); EFTA00289722, DataSet 9, stock certificate PA-7, July 23, 2013. https://www.justice.gov/epstein/files/DataSet%209/EFTA00289560.pdf ; https://www.justice.gov/epstein/files/DataSet%209/EFTA00289722.pdf [^6]: Weissbrot, "After A Rocky Road, Ad/Fin Shuts Its Doors," *AdExchanger,* October 17, 2019. https://www.adexchanger.com/agencies/after-a-rocky-road-ad-fin-shuts-its-doors/ [^7]: U.S. Department of Justice, Epstein Library, EFTA00289560, DataSet 9, Schedule of Exceptions, Schedules 3.12 and 3.15 (pages EFTA00289676 and EFTA00289677). https://www.justice.gov/epstein/files/DataSet%209/EFTA00289560.pdf [^8]: U.S. Department of Justice, Epstein Library, EFTA01084694, DataSet 9, letter from David J. Mitchell, "RE: ADFIN SOLUTIONS INC.," February 16, 2016, with Exhibit A (page EFTA01084696) and company investor presentation, "Backed By Leaders" slide (page EFTA01084707). https://www.justice.gov/epstein/files/DataSet%209/EFTA01084694.pdf [^9]: U.S. Department of Justice, Epstein Library, EFTA00652698, DataSet 9, email from David Mitchell to Jeffrey Epstein, "Re: AdFin," March 21 and 22, 2013. https://www.justice.gov/epstein/files/DataSet%209/EFTA00652698.pdf [^10]: U.S. Department of Justice, Epstein Library, EFTA00289560, DataSet 9, counterpart signature pages: purchase agreement (EFTA00289580 and EFTA00289581), Investors' Rights Agreement (EFTA00289633 and EFTA00289634), Right of Refusal and Co-Sale Agreement (EFTA00289651 and EFTA00289652), Voting Agreement (EFTA00289668 and EFTA00289669) and Voting Agreement Exhibit A (EFTA00289670). https://www.justice.gov/epstein/files/DataSet%209/EFTA00289560.pdf [^11]: U.S. Department of Justice, Epstein Library, EFTA00289541, DataSet 9, Note Purchase Agreement dated December 26, 2013, Schedule I and signature page (EFTA00289550); EFTA00289527, DataSet 9, Action by Written Consent of the Stockholders, signature pages EFTA00289531 and EFTA00289532. https://www.justice.gov/epstein/files/DataSet%209/EFTA00289541.pdf ; https://www.justice.gov/epstein/files/DataSet%209/EFTA00289527.pdf [^12]: U.S. Department of Justice, Epstein Library, EFTA01942504, DataSet 10, email from David Mitchell to Jeffrey Epstein, January 7, 2014. https://www.justice.gov/epstein/files/DataSet%2010/EFTA01942504.pdf [^13]: U.S. Department of Justice, Epstein Library, EFTA00376028, DataSet 9, email from Darren Indyke to Lesley Groff, "Fwd: AdFin - Bridge Loan Documents," January 13, 2014. https://www.justice.gov/epstein/files/DataSet%209/EFTA00376028.pdf [^14]: U.S. Department of Justice, Epstein Library, EFTA01202791, DataSet 9, AdFin Solutions, Inc. Convertible Promissory Note Financing Term Sheet, August 11, 2014. https://www.justice.gov/epstein/files/DataSet%209/EFTA01202791.pdf [^15]: U.S. Securities and Exchange Commission, EDGAR, AdFin Solutions, Inc. (CIK 0001595302), Form D, accession number 0001595302-13-000001, filed December 31, 2013 (primary document and submission header). https://www.sec.gov/Archives/edgar/data/1595302/000159530213000001/primary_doc.xml ; https://www.sec.gov/Archives/edgar/data/1595302/000159530213000001/0001595302-13-000001.txt [^16]: U.S. Department of Justice, Epstein Library, EFTA00362758, DataSet 9, email from Lesley Groff to David Mitchell, September 12, 2014 (Groff's reply quoting Mitchell's message, copied to Andrew Altersohn). https://www.justice.gov/epstein/files/DataSet%209/EFTA00362758.pdf [^17]: U.S. Department of Justice, Epstein Library, EFTA00868060, DataSet 9, email from David Mitchell to Jeffrey Epstein, December 15, 2014. https://www.justice.gov/epstein/files/DataSet%209/EFTA00868060.pdf [^18]: U.S. Department of Justice, Epstein Library, EFTA01746876, DataSet 10, email from David Mitchell to Jeffrey Epstein forwarding message from Jonathan Leitersdorf, March 16 and 23, 2015. https://www.justice.gov/epstein/files/DataSet%2010/EFTA01746876.pdf [^19]: U.S. Department of Justice, Epstein Library, EFTA00796718, DataSet 9, AD/FIN company presentation, slide 21, "Cap Table as of 1.4.18" (page EFTA00796738). https://www.justice.gov/epstein/files/DataSet%209/EFTA00796718.pdf [^20]: U.S. Department of Justice, Epstein Library, EFTA00877345, DataSet 9, email chain "AD/FIN Update & Financing," January 26 to February 26, 2018, with Epstein's reply of February 26, 2018; EFTA00861028, DataSet 9, Richard Kahn to Epstein, March 14, 2018; EFTA00836715, DataSet 9, Richard Kahn to Epstein, April 13, 2018. https://www.justice.gov/epstein/files/DataSet%209/EFTA00877345.pdf ; https://www.justice.gov/epstein/files/DataSet%209/EFTA00861028.pdf ; https://www.justice.gov/epstein/files/DataSet%209/EFTA00836715.pdf [^21]: U.S. Department of Justice, Epstein Library, EFTA00843811, DataSet 9, David Mitchell to Richard Kahn, April 3, 2018; EFTA01022753, DataSet 9, David Mitchell to Jeffrey Epstein, September 18, 2018; EFTA01019335, DataSet 9, David Mitchell to Jeffrey Epstein, "slides for David.pptx," October 18, 2018. https://www.justice.gov/epstein/files/DataSet%209/EFTA00843811.pdf ; https://www.justice.gov/epstein/files/DataSet%209/EFTA01022753.pdf ; https://www.justice.gov/epstein/files/DataSet%209/EFTA01019335.pdf [^22]: U.S. Department of Justice, Epstein Library, EFTA01050772, DataSet 9, email chain "Re: thanks for letting me know," May 28, 2018. https://www.justice.gov/epstein/files/DataSet%209/EFTA01050772.pdf [^23]: U.S. House Committee on Oversight and Government Reform, transcribed interview of Howard Lutnick, May 6, 2026, pp. 26 to 29, 87 to 89. https://oversight.house.gov/wp-content/uploads/2026/05/Lutnick-Transcript.pdf [^24]: Andy Verity, Rob Byrne and Ben Milne, "How US commerce secretary's Epstein links were uncovered by British whistleblower," *BBC News,* July 14, 2026. https://www.bbc.co.uk/news/articles/c9q28dlyxrzo [^25]: Weissbrot, "How Ad/Fin Got Caught In The Crossfire," *AdExchanger,* July 29, 2019. https://www.adexchanger.com/agencies/how-ad-fin-got-caught-in-the-crossfire-of-the-industrys-transparency-crusade/