Marc Rowan

Liquid Funding Ltd was a $6.7B Bermuda-registered Structured Investment Vehicle (SIV) incorporated Oct 19, 2000 (EC 29378), where Epstein served as Chairman and Director from Nov 2001 to at least Mar 2007. Bear Stearns owned ~40% and provided investment management through its Dublin subsidiary. The vehicle held mortgage-backed securities and CLOs. By 2004, FTC's investment summary listed 'Liquid Funding Holding' with $1.5M in holdings (EFTA01308282). By 2009, the K-1 showed only $969 income -- the entity was dormant post-Bear Stearns collapse. In 2016, Rowan's 'Re-Introduction after Liquid Funding' email subject line confirms Liquid Funding was the shared business context connecting Rowan, Epstein, and Shwachman.

Marc and Carolyn Rowan wrote a check for $838,675 to Leon Black on April 9, 2014 (check #000013326, US Trust/Bank of America), tagged '2013HERITAGE'. The accompanying TRA breakdown shows Rowan received $103.37M total in TRA payments from Apollo (2007-2013 exchanges combined), with the July 2007 exchange alone generating $95.4M in distributable share. This document was in Epstein's possession, demonstrating Epstein had access to confidential financial details of inter-founder payments within Apollo.

ROWAN $838,675 TRA CHECK TO BLACK -- INTER-FOUNDER PAYMENT IN EPSTEIN'S POSSESSION: Previously recorded (finding #1183) but now contextualized within the BRH architecture: Marc and Carolyn Rowan wrote check #000013326 (US Trust/Bank of America) for $838,675 to Leon Black on April 9, 2014, tagged '2013HERITAGE'. The accompanying TRA breakdown shows Rowan received $103.37M total in TRA payments from Apollo (2007-2013 exchanges combined), with the July 2007 exchange alone generating $95.4M in distributable share. This document was in Epstein's possession. The TRA (Tax Receivable Agreement) is the mechanism by which BRH Holdings LP distributes tax benefits to the three founders individually -- specifically, Apollo pays the founders 85% of the tax savings from the step-up in basis of Apollo's assets when the founders exchange their partnership interests for stock. Epstein asked Rowan directly: 'the tra liability amount is on apollos balance sheet. can you find how they calculate?' (Feb 22, 2016) and Rowan forwarded confidential TRA calculations from Apollo CFO Chris Weidler. The TRA is now worth billions following the Athene merger and Apollo stock appreciation. Epstein's access to inter-founder TRA payments means he understood the precise economic relationship between all three founders.

Black Family Partners (BFP) cash flow projection (Dec 23 2014, prepared by Richard Joslin) shows Athene capital call of .6M as the single largest disbursement, dwarfing all other items. Apollo distributions were the primary inflow: .5M (Dec 2014), .9M (Feb 2015), .8M (Apr), .9M recurring. TRA payment of .5M. Advisory fee line item present but amount unclear. Family office expense ,667/month (.4M/year). Loan to LDB of .5M repaid. Phaidon Global loan repayment .35M. Cash balance projected to go negative by May 2015 at -.9M, requiring borrowing from LDB 2014 LLC to fund residual Athene commitment. This demonstrates that the Athene investment was so large it strained even Black Family Partners' cash flows, explaining why Epstein's proposed 25% advisory fee on Athene tax optimization was worth engaging all three founders.

Complete timeline of Rowan-Epstein documented interactions: Sept 2013: Epstein set Google Alert on 'rowan'. May/Jun 2014: Richard Kahn forwarded Rowan's Apollo share sales articles to Epstein. Dec 16 2015: Melanie Spinella arranges Rowan-Epstein first meeting. Dec 29 2015: Epstein's hand-deliver memo references 'Rowen request re Athene.' Jan 6 2016: 8am breakfast at Epstein residence. Jan 9: Black directs Rowan+Cohen to call Epstein re DAFs. Jan 18: Epstein proposes 25% Athene fee naming marc and josh. Jan 21: Epstein engages Paul Weiss on Apollo/Athene restructuring. Feb 1-22: Multiple calls/meetings, TRA/inversion/valuation discussions. Mar 4-14: TRA calculations forwarded, inversion progress. Aug 12 2016: Rowan introduces Shwachman for USVI insurance. Aug 15: Leon agenda includes Athene and josh/mark. Aug 26: Epstein offers to explain Form 8865. Apr 3 2018: Ruemmler asks Epstein if she has met Rowan.

In Epstein's explosive 'DO NOT SEND, hand deliver' memo to Leon Black (Dec 29, 2015, EFTA02451672), Epstein combined a scathing critique of Black's financial operations with the first reference to 'Rowen request re Athene, 2 billion in taxes on transaction.' This same memo discusses: (1) the Phaidon payout dispute (Epstein expected 50% of $20M), (2) 'Halperin has a conflict that should be addressed', (3) 'inversion rules', (4) 'insurance regs, out and inbound issues', (5) Rothschild bank $150B distribution network. The Rowan/Athene item appears as one element of Epstein's comprehensive advisory role across all Apollo/Black affairs. The memo proves Epstein was functioning as shadow chief financial adviser to Black/Apollo.

Leon Black directed Barry Cohen and Marc Rowan to call Epstein regarding Donor Advised Funds. Melanie Spinella (Black's executive assistant at Apollo Management) wrote: 'Leon has asked Barry Cohen and Marc Rowan to call you re Donor Advised Funds - Barry wanted me to give you a heads up' (EFTA02405147, undated but Jan 2016 context). DAFs are charitable giving vehicles with significant tax benefits. This confirms Black was actively delegating Apollo financial matters to Epstein with Rowan's direct involvement.

Epstein proposed a 25% fee on the Athene transaction to Melanie Spinella (Leon Black's assistant), explicitly naming 'marc and josh' (Rowan and Harris) as parties who would need to sign on. Epstein wrote: 'I propose a 25% fee based on benefit to all founders... if there is a 300 overall benefit, then each founder would pay 25 m... marc and josh would have to sign on' (Jan 18, 2016). This proves Epstein expected ALL three Apollo co-founders to be involved in his fee arrangement, not just Black.

Epstein engaged Brad Karp (Chairman of Paul, Weiss) on the Apollo/Athene restructuring on Jan 21, 2016, describing the work as covering 'apollo/athene - rothschild (possible) USVI less likely', requiring review of 'BRH agreement, agreement amongst principals, TRA, consequences on death, insurance reg and restrictions, on-shore and off-shore, personal income tax, PFIC or CFC, SEC disclosures, inversion' rules. Karp responded: 'we're all very excited.' Epstein also mentioned getting Kathy Ruemmler to recommend a hire at Paul Weiss. This was just 3 days after Epstein's Athene fee proposal — the firm work was to implement the restructuring.

Epstein negotiated with Rowan regarding a 'Fenn' matter and fee structure, writing: 'spoke to fenn, I am waiting on you to decide whether you want me to move forward, and if, and only if successful, what you three propose as a fee.' (Feb 12, 2016). Rowan responded: 'WPPI...care of MR'. The reference to 'you three' (i.e., the three Apollo co-founders: Black, Rowan, Harris) and fee negotiation confirms Epstein was providing compensated advisory services to all three Apollo founders jointly. WPPI likely refers to Wharton Public Policy Institute — Epstein also noted 'summers gave a lecture at wharton public policy school, is that your deal?'

Rowan emailed Epstein about 'Empire' wanting to chat (Feb 19, 2016). Richard Kahn forwarded Epstein a NY Post article 'Rowan finds more luck in personal investments' (Jun 7, 2014) and a Bloomberg article 'Apollo Billionaire Rowan Sells 72.8 Million in Shares' (May 27, 2014). The Kahn forwards show Epstein's inner circle actively monitoring Rowan's financial activities and Apollo share transactions. The 'Empire' subject line likely refers to a deal or entity Rowan was discussing with Epstein.

Rowan discussed Epstein's valuation critique of Apollo unit transfers. Rowan wrote: 'I found the same long valuation report when I transferred units to the various estate planning vehicles' (Feb 21, 2016). Epstein responded with pointed critique: 'did you see the goofy description, ie puts, for example not realizing that there is a traded market in them, they also added 144 restrictions. were sec filings made on your transfers? did not take into account termination clause. or current year knowledge of projections.' This shows Epstein critiquing the valuation methodology used for Rowan's personal Apollo unit transfers to estate planning vehicles.

Rowan served as Epstein's financial adviser on Apollo TRA (Tax Receivable Agreement) valuation. Epstein directly asked Rowan 'the tra libility amount is on apollos balance sheet. can you find how they calculate?' (Feb 22, 2016). Rowan forwarded confidential Apollo internal TRA calculations from CFO Chris Weidler to Epstein (Mar 4, 2016), including DTA discount rates, management fee cash flows, and carried interest projections. This reveals Epstein had direct access to Apollo's most sensitive financial modeling through Rowan.

Epstein asked Rowan about 'the inversion' in the context of Apollo TRA valuations: 'have you made any progress on the inversion?' (Mar 14, 2016). An 'inversion' in this context means restructuring Apollo from a US partnership into a foreign corporation to reduce the tax burden on TRA payments and founder distributions. Rowan responded 'minimal'. Epstein also asked about the 'worksheet calculation for the tra number on the balance sheet' and whether they were 'undiscounted' — demonstrating deep working knowledge of Apollo's tax structure.

Epstein advised Reid Hoffman on tax-free stock donation via CRT (Charitable Remainder Trust) in the context of a corporate inversion: 'trust (CRT), where the stock can be sold on a tax-free basis... To avoid this result, it is best to make the donation of stock before shareholder approval of the inversion occurs' (Jul 26, 2016, EFTA02456896). This confirms Epstein was simultaneously advising multiple billionaires on inversion-related tax strategies during the same period he was advising Rowan on Apollo's inversion. The expertise was not hypothetical -- it was an active advisory practice.

Marc Rowan (Apollo Global co-founder) personally introduced Epstein to Perry Shwachman (Partner, Sidley Austin LLP) in the context of 'Liquid Funding' (EFTA02454291, Aug 2016). Rowan wrote: 'I will leave it to the two of you to discuss directly.' Shwachman then contacted Epstein about 'potential new USVI insurance regulations' (EFTA02361689, Aug 2016). This reveals Rowan was actively brokering connections for Epstein well after Epstein's 2008 conviction. The 'Liquid Funding' context appears on FTC's 2009 K-1, suggesting a shared investment history. Separately, the Dechert LLP memo (EFTA02730996) commissioned by Apollo Conflicts Committee investigated the Epstein/Black relationship and confirmed AP SHL and AP Technology were formed by 'certain Apollo executives' — Rowan, as co-founder, would have known about these side vehicles. Rowan's introduction of Shwachman to Epstein for USVI regulatory influence echoes the broader pattern of Apollo executives facilitating Epstein's access to institutional power.

Epstein's 'leon agenda' memo (Aug 15, 2016) lists 14 action items including '10 apollo insurance AThene' and '14. sit with josh and mark re amendments' (EFTA02455405). 'Mark' is likely Marc Rowan, 'josh' is Joshua Harris. This memo shows Epstein managing all three Apollo co-founders' business simultaneously. The mention of Athene alongside the Rowan-Shwachman USVI insurance introduction (same month) demonstrates that Epstein was coordinating multiple Apollo/Athene workstreams: the insurance vehicle, the corporate restructuring, and the TRA optimization.

Epstein was advising Rowan on IRS Form 8865 (Return of US Persons With Respect to Certain Foreign Partnerships). Epstein wrote: 'Happy to explain my thinking on the 8865 issue' (Aug 26, 2016). Form 8865 is required when US persons hold interests in foreign partnerships — this directly relates to the offshore structuring of Apollo entities and the proposed inversion. This establishes Epstein as providing specific international tax advisory services to Rowan on Apollo's cross-border tax obligations.

Epstein referenced 'Rowen request re Athene, complex 2 billion in taxes on transaction' in a comprehensive advisory memo to Leon Black (Aug 25, 2017). This email demonstrates Rowan was directly requesting Epstein's tax advisory expertise on the Athene transaction, which involved approximately 2 billion dollars in tax implications. The memo covers Apollo/Athene restructuring, Rothschild bank partnership, USVI considerations, corporate inversions, TRA, shareholder agreements, SEC disclosures, and estate planning — showing Epstein functioning as a shadow adviser to all Apollo founders.

ROWAN FEC ANALYSIS: Marc Rowan is a heavily Republican donor via Apollo Management. Key contributions 2019-2025: (1) AIPAC (LittleSis, amount not specified) - significant given Rowan's prominence in pro-Israel advocacy. (2) Mitch McConnell ,600 (May 2019). (3) John Barrasso ,900 (Dec 2021). (4) Marco Rubio ,800 (Dec 2021). (5) NY Republican Federal Campaign Committee ,000 (Dec 2025). (6) Multiple Congressional candidates at ,500 each (2025). Rowan lists employer as 'Apollo Management' or 'Apollo Global Management' on all filings. His donation pattern is heavily Republican with no Democratic contributions visible, contrasting with Harris's bipartisan giving and PTJ's bipartisan pattern. Rowan's political giving aligns with his post-Black role as Apollo CEO -- managing the firm's political relationships.

ROWAN-HARRIS LATERAL CONNECTIONS via LittleSis: Both Rowan (entity 66624) and Harris (entity 6143) hold positions at Apollo Global Management (LittleSis org 50090). Both serve on the Wharton School advisory board. Both donated to John Barrasso (R-WY) and Marco Rubio (R-FL). Rowan is also on the New York Police Foundation board (rel 1960178). Harris owns Harris Blitzer Sports & Entertainment (rel 1960206, NBA 76ers/NHL Devils) and founded 26North (rel 1960205) and HRS Management (rel 1960204) post-Apollo. The lateral network shows Rowan stayed within Apollo while Harris diversified into sports ownership and a new investment platform -- but their shared Wharton connection, political donation patterns, and documented joint engagement with Epstein at the Oct 22 2013 meeting demonstrate they operated as a coordinated unit throughout the Epstein advisory period.

Rowan had at least 3 confirmed in-person meetings with Epstein. (1) Jan 6, 2016 breakfast at 8am at Epstein residence, arranged via Melanie Spinella in Dec 2015 -- 'Marc said if Jeffrey wants early breakfast that works for him, he will bring coffee' (EFTA02477895). (2) A second schedule entry same week (EFTA02347894/EFTA02475448). (3) Rowan scheduled to meet Epstein on Aug 21 per EFTA02375781. Leon Black separately asked Rowan to attend a meeting at Epstein's house 'with a woman representing a wealthy family, where two blonde women who appeared to be in their 20s greeted guests at the door' (WSJ article, EFTA01365973). Epstein had a Google Alert monitoring 'rowan' (EFTA02573689, Sept 2013). Kathy Ruemmler asked Epstein 'Have I met Marc Rowan?' (Apr 3, 2018, EFTA02485265), showing Epstein as connective tissue.

Epstein demonstrated expert-level knowledge of Rowan's personal liability in Caesars litigation. Corrected Richard Kahn: 'not leon -rowen, ie board members' — knowing Rowan faced liability as board member while Black did not. Also wrote self-memo: 'caesars case re mark. open tax years could be a neg' — tracking Rowan's tax exposure. During same period, advising Rowan on Apollo TRA valuations and receiving confidential Apollo CFO calculations.

Rowan named defendant in Case 15-01145 as CEC director who orchestrated asset-stripping as 'de facto CEO' of CEOC. Court ordered Rowan to disclose personal wealth. Rowan/Sambur offered 250M personal settlement, received fraud releases. Rowan later became Apollo CEO in 2021.