Alessandro Benedetti
Geneva-based Italian financier and cross-border dealmaker whose corporate footprint spans UK, Swiss, French, Italian, BVI, Maltese, and Cypriot jurisdictions. Documented in Epstein scheduling records as a Paris contact from 2011 to 2019, and separately identified in a February 2020 Wall Street Journal investigation as the coordinator of a covert campaign against SoftBank executives on behalf of Rajeev Misra.
According to UK Companies House filings and SEC proxy disclosures, Alessandro Benedetti (born July 1961, Italian national, Swiss resident in Lugano) is a Geneva-based financier, founding partner of Schwarzfield, and CEO of SAE Capital Ltd 12. The same records reveal directorships across at least seven jurisdictions, including Attali Investment Partners Ltd, Asherco LLP, SPQR Capital Holdings S.A., and the NYSE-listed Equus Total Return Inc., where he served as Executive Chairman from June 2011 to June 2014 34. He is referenced as Jeffrey Epstein’s Paris neighbor in a December 2011 email from Reid Weingarten, who describes him as “your Italian jewish neighbor on ave. foch” 56.
Benedetti’s career centers on cross-border dealmaking. According to press and UK court records, he brokered the 2005 acquisition of Wind Telecomunicazioni SpA for Naguib Sawiris, reported at approximately €12 billion, and subsequently sued Sawiris for a one-third stake in the proceeds before losing at the UK Supreme Court in 2013 1. Epstein’s scheduling records place Benedetti first on a September 2013 “Paris List” of fourteen contacts 78, and a January 28, 2019 email shows Epstein inquiring about him through Eduardo Teodorani at CNH Industrial with the one-line query “Allesandro benedetti?” 910.
According to a February 2020 Wall Street Journal investigation, Rajeev Misra of SoftBank paid Benedetti $500,000 in April 2015, routed via Standard Chartered Bank to Barkmere Group Ltd (BVI), to coordinate a covert campaign against internal rivals Nikesh Arora and Alok Sama 1112. According to the same reporting, the operation involved Nicolas Giannakopoulos, a Swiss intermediary identified by WSJ as having SCL Group ties, and included a shareholder pressure campaign and negative press placements 13. According to WSJ, Benedetti disclosed the arrangement to the paper after a compensation dispute with Misra 14. Epstein’s emails show him querying both Brad Karp about representing Misra and Teodorani about Benedetti within a 72-hour window in late January 2019 1516.
The Avenue Foch Connection
The documentary trail places Benedetti within Epstein’s Paris network across an eight-year span from 2011 to 2019 17. The earliest record is Weingarten’s December 9, 2011 email to Epstein asking “did we ever talk about allesandro Benedetti, your Italian jewish neighbor on ave. foch?” 56. The possessive “your” indicates Weingarten treated Benedetti as already known to Epstein through the Avenue Foch property — the same street as Epstein’s 22 Avenue Foch Paris residence 6. Cross-reference of the email thread shows Epstein engaged on other topics but did not respond in writing to the Benedetti question, which analysts of the thread characterize as either a prior phone discussion or a preference to avoid a written response 6.
By September 2013, Benedetti appeared in Epstein’s Paris scheduling records. Groff’s “Paris List” 7 places “Alesandro de benedetti” first among fourteen contacts, a roster that included Ariane de Rothschild, Wojtek Fibak of Fine Arts Investments, Margherita Campella Della Spina, a “Sultan,” and conductor Frederic Chaslin 8. Records show the same day’s schedule 18 lists the Benedetti reminder alongside an 8:30am breakfast with Ian Osborne (a Peter Thiel intermediary), an 11:30am lunch with Larry Summers, and a 1:00pm meeting with Richard Kahn and Darren Indyke, before a 9:55pm Air France departure for Paris 1920. Duplicate reminders on September 26 and October 7 2122 record repeated scheduling around Benedetti during the trip cycle 23.
The final documented reference is Epstein’s January 28, 2019 email to Eduardo Teodorani at CNH Industrial containing the single-line inquiry “Allesandro benedetti?” 910. The query arrived two days after Epstein asked Brad Karp about representing Rajeev Misra, and within the same week Weingarten discussed the “Softbank caper” with Epstein 1516. Analysis of the 72-hour window indicates Epstein was tracking the SoftBank matter through Italian corporate channels rather than contacting Benedetti directly 24.
Corporate Architecture Across Jurisdictions
Cross-reference of UK Companies House, SEC proxy filings, and ICIJ records indicates Benedetti’s corporate footprint spans at least seven jurisdictions — UK, Switzerland, France, Italy, BVI, Cyprus, and Malta — with public-facing advisory vehicles on one tier and offshore holding entities on another 31. According to UK filings and MarketScreener listings, Benedetti founded SAE Capital Ltd in January 2007, chairs Schwarzfield SA from February 2013, and serves as director of SPQR Capital Holdings SA from August 2010 252. SEC proxy filings for Equus Total Return Inc. (NYSE: EQS, CIK 878932), where he served as Executive Chairman from June 2011 to June 2014, itemize eight concurrent directorships and record personal ownership of over 100,000 shares plus 400,000 held through EB Finance S.A., an entity of which Benedetti disclaimed beneficial ownership in the DEF 14A disclosures 4.
The UK tier contains four Companies House appointments 3. Asherco LLP (OC379532), active since October 2012, shows a sequential rotation through two BVI corporate members: Youngstown Investments Group Ltd (BVI 1688567, November 2014–November 2021) and Satsu Finance Ltd (BVI 1583501, November 2021–March 2023), both registered at the same PO Box 3483, R.G. Hodge Plaza, Wickhams Cay 1, Road Town, Tortola 26. After the BVI members departed, Israeli national Dotan Moshe (March 2023–July 2024) served briefly before being replaced by Mathieu Villaume of Luxembourg 26. Analysis of the rotation pattern indicates a structure that maintains a UK regulatory presence while cycling corporate members through a shared BVI registered-agent address 26.
According to UK Companies House records, Attali Investment Partners Ltd (UK 07138407, January 2010–December 2015) links Benedetti to Franco-Italian political networks 2725. Records show the entity is named for Jacques Attali, former senior adviser to President Mitterrand and founding president of the EBRD, and was co-directed by Bertrand Gauquelin des Pallieres (born November 1966, French, resident in Rome) until both resigned in the same month in December 2015 and were replaced by Methorios Capital LLP as corporate director 27. Cross-reference with Wall Street Journal reporting on the SoftBank matter indicates that des Pallieres, a former Deutsche Bank trader who had worked under Misra, later introduced Misra to Benedetti for the operation described in that reporting 12.
According to WSJ reporting, the offshore tier includes Barkmere Group Ltd (BVI), the vehicle through which Misra’s $500,000 payment was routed, together with Barkmere Limited (Cyprus) 11. According to the ICIJ Paradise Papers, Benedetti is identified as shareholder of Tree of Life Limited (Malta, C67345, incorporated October 2014), registered at Via delle Serre N. 9/A, Florence, with cross-reference of UK Companies House filings confirming this entity is distinct from the Northzone VC associate of a similar name 1128. According to OCCRP Aleph, a separate Cyprus entity of the same name (HE 279303, incorporated December 2010, dissolved January 2016) sits sixteen months before the Malta entity’s incorporation, a chronology the Aleph record characterizes as a possible jurisdictional migration from Cyprus to Malta 29.
Wind Hellas Creditor Ring and the SPQR Capital Holding Board (2016)
According to Luxembourg RCS records (B150334), SPQR Capital Holding SA was domiciled at 12 rue Guillaume Schneider L-2522 — the same NeoTrust Fiduciary domicile as Compagnie Du Saleve SA — and was liquidated 16 March 2023 under liquidator Christian Steinmetz 3031. Records show three directors of SPQR Capital Holding were appointed on the same day, 1 March 2016: Alessandro Benedetti as Chair, Bertrand G. des Pallieres, and Mathieu Villaume (the latter serving until 7 February 2018) 30. The Swiss arm, SPQR Capital Services Sagl in Lugano (CHE-496.390.425, capital CHF 20,000), was registered 17 March 2011 with Benedetti as chair 30.
According to RelationshipScience and MarketScreener disclosures, des Pallieres — the founder and CEO of SPQR Capital, ex-JPMorgan MD Global Head of Structured Credit (1992–2005) and ex-Deutsche Bank MD Global Head of Principal Finance (2005–2007) — called on the ICAEW to investigate Ernst & Young over the Wind Hellas administration after SPQR Capital and other junior bondholders lost millions when Naguib Sawiris’s Weather Investments wiped GBP 1.3 billion of debt acquiring the group out of administration 32. Records show his board portfolio extended to Equus Total Return Inc., Cadogan Petroleum Plc, Lansdowne Capital SA, InfraVia Capital Partners SAS, Attali Investment Partners Ltd, Euromax Finance Ltd, Methorios Capital Services Ltd, SPQR Capital (Cayman) Ltd, and Bitfury Group Ltd 32. The earlier dossier record naming “Stephane des Pallieres” is corrected by these registry filings to Bertrand G. des Pallieres 32.
Analysis of the 1 March 2016 simultaneous installation indicates a three-handed Luxembourg fund-vehicle governance shape coincident with the active phase of SPQR’s Wind Hellas / TIM Hellas creditor dispute against Sawiris’s Weather Investments 33. Cross-reference of finding #11127 with the SPQR registry record places Benedetti at both ends of the Wind chain: he had brokered the 2005 Sawiris acquisition of Wind Telecomunicazioni for an €67 million fee, sued Sawiris and lost at the UK Supreme Court in 2013, and then chaired the Luxembourg SPQR vehicle that pursued Sawiris’s Wind Hellas administration as a junior bondholder 13433. According to the same registry record, the SPQR domicile at 12 rue Guillaume Schneider co-located with Compagnie Du Saleve SA (B223232, registered 23 March 2018, capital EUR 6,854,000), wholly owned since 8 March 2023 by Five Arrows AutoBench Holding Sarl (B209234), with current directors Pierre Mouliere and Mathieu Villaume 31. Examination of the shared domicile pattern and Villaume’s presence on both the Saleve and SPQR boards indicates a NeoTrust Fiduciary cluster spanning at least two of Benedetti’s Luxembourg vehicles 3130.
The SoftBank Campaign, as Reported by WSJ
According to the February 2020 Wall Street Journal investigation, in January 2015 Rajeev Misra — then a senior SoftBank executive positioning for leadership of what became the Vision Fund — met Benedetti in London to commission an operation against his internal rivals SoftBank president Nikesh Arora and chief strategy officer Alok Sama 1213. According to the same reporting, Bertrand des Pallieres, a former Deutsche Bank trader who had worked under Misra before relocating to Rome, made the introduction 12. According to WSJ, by April 2015 Misra had paid $500,000 via Standard Chartered Bank to Barkmere Group Ltd, the BVI entity controlled by Benedetti 11. According to the same report, Misra’s spokesman characterized the transfer as an “oil investment,” a characterization the WSJ report treats as disputed 11.
According to WSJ, the alleged campaign ran on multiple tracks 13. According to the same reporting, an attempt in Tokyo to compromise Arora using women and hidden cameras did not succeed 13. According to WSJ, Benedetti subcontracted Nicolas Giannakopoulos, a Swiss operative the paper identifies as having ties to Cambridge Analytica’s parent SCL Group, to distribute leaked banking records and organize a nominal shareholder campaign 12. According to the report, K2 Intelligence was engaged to investigate Arora and Sama and in turn retained London PR firm Powerscourt Group to place the resulting material 13. According to WSJ, by September 2015 Giannakopoulos had engaged freelance journalist Mark Hollingsworth, and in October 2015 The Independent published an article on Arora 13. According to the same reporting, the shareholder pressure campaign launched in November 2015, with the first formal letter arriving in January 2016 13. According to WSJ, Arora resigned in June 2016 and Sama departed in April 2019 13. According to the report, the alleged operation used the code name “Mr. West” for Arora, Misra provided a dedicated cellphone for operational communications, and meetings were conducted at London’s Bulgari Hotel and Zurich’s Hotel Baur au Lac in November 2017 12.
According to WSJ, the arrangement collapsed over compensation 14. According to the reporting, Benedetti expected substantially more than the initial $500,000 — a share of Misra’s SoftBank earnings and appointment to lead the Vision Fund’s London office — and when neither materialized he recorded conversations with Misra detailing the alleged plans against Arora and Sama 14. According to WSJ, Benedetti provided the recordings and documentation to the paper, which published its investigation in February 2020 14. According to the same reporting, a Shearman & Sterling probe commissioned in 2018 was inconclusive 13. Cross-reference of the WSJ account with UK Companies House and Paradise Papers records indicates a pattern of multi-layered subcontracting, BVI payment channels, PR firm placements, and shareholder letter campaigns consistent with the corporate architecture documented for Benedetti’s entities 1226.
Epstein and the SoftBank Convergence
A cluster of documentary evidence from late January 2019 links Epstein’s prior Paris relationship with Benedetti to the emerging SoftBank matter. Around January 25, 2019, Weingarten discussed the “Softbank caper” with Epstein 15. On January 26, Epstein asked Brad Karp of Paul, Weiss about representing Misra 1516. On January 28, Epstein emailed Eduardo Teodorani at CNH Industrial with the one-line inquiry “Allesandro benedetti?” 910. Records show three separate contacts — Weingarten, Karp, and Teodorani — queried within a 72-hour window on related facets of the same matter 16.
According to the available documentary record, Epstein is not a party to the original campaign against Arora and Sama 24. By January 2019, however, he was inquiring about the individual WSJ later identified as the coordinator (Benedetti), exploring legal representation for the reported beneficiary (Misra), and discussing the broader matter with his own counsel 15. Analysis of the 72-hour inquiry pattern indicates Epstein was tracking the SoftBank situation in real time through multiple intermediaries, with the Teodorani routing indicating an indirect rather than direct approach to Benedetti 2417. Analysis of the correspondence indicates Epstein’s choice of Teodorani as channel, rather than contacting Benedetti directly, is consistent with a relationship that had changed character by early 2019, although the record does not specify when or why 24.
Position in the Paris Network
Benedetti’s placement within Epstein’s Paris correspondence ecosystem illuminates the structure of that network. The September 2013 “Paris List” 7 is one of the few documents that maps Epstein’s Parisian social circle in a single snapshot 8. Records show Benedetti appears first, followed by names that include “Ariane” (likely Ariane de Rothschild), Wojtek Fibak of Fine Arts Investments, Margherita Campella Della Spina (arriving by train September 27), a “Sultan in Paris Sun Sept 29,” and conductor Frederic Chaslin 823. Examination of the list indicates it combines the social registers Epstein cultivated — finance, art, European aristocracy, and Gulf wealth — with Benedetti positioned among the financial contacts 8.
According to UK Companies House, the Attali Investment Partners directorship anchors Benedetti in Franco-Italian political networks 27. Records reveal Jacques Attali as a former senior adviser to President Mitterrand and founding president of the EBRD 25. Cross-reference of Benedetti’s directorships indicates his position on Attali’s investment vehicle placed him at the intersection of French political access and Italian financial networks, a profile consistent with the cross-border intermediaries documented elsewhere in the Epstein Paris records 2519. According to UK Companies House and DOJ Vol 11 records, Benedetti’s earlier role as president of M Finances SAS (Paris, 2000–2001) and director of Vendome Investments Ltd (UK, 2005–2011) establishes a Paris-London axis predating the Epstein correspondence by roughly a decade 2. According to UK Supreme Court and press records, his 2005 brokerage of Naguib Sawiris’s Wind Telecomunicazioni acquisition, for which he was separately investigated by Roman prosecutors in 2008 and which produced the UK Supreme Court case Benedetti v Sawiris (2013), illustrates the scale of dealmaking that preceded the Paris contacts period 1.
All Connections
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All Connections
22 totalMisra paid Benedetti 500K via Barkmere Group BVI Apr 2015 for smear campaign. Benedetti expected exec position plus profit share. Falling out led to WSJ leak Feb 2020
Giannakopoulos was Benedetti's subcontractor in the SoftBank sabotage operation (2015-2016). Benedetti recruited Giannakopoulos to distribute leaked banking records and act as nominal shareholder.
Co-directors at Attali Investment Partners Ltd (UK 07138407, Jan 2010-Dec 2015), SPQR Capital Holdings SA (Lux, since 2010), Equus Total Return Inc (NYSE EQS), Cadogan Petroleum plc, Bitfury Group. Joint defendants in Kruppa v Benedetti [2014] EWHC 1887 (Comm). Methorios Capital LLP replaced both as corporate director on simultaneous Dec 2015 resignation from Attali.
Benedetti worked for Sicilian developer Ligresti through Magnetofoni Castelli (Milan) 1989-1993. ~100 companies offshore (Caribbean/Panama/Monaco/UK/Switzerland/Lux/Netherlands), 21,000 accounting entries, ~65B lire exported. Per Il Sole 24 Ore reconstruction (Claudio Gatti, Mar 11 2008). This is Benedetti's pre-Wind operational training in money-laundering/influence-buying machine architecture.
Benedetti brokered the 2005 Wind Telecom acquisition for Sawiris (then-largest European LBO). Brokerage fee ~67M EUR + 3.4M EUR support = ~97M EUR. Met in Cairo Dec 25-26 2002. Benedetti sued for additional one-third stake (~3.7B EUR claim); lost UK High Court 2009, Court of Appeal 2010, UK Supreme Court 17 July 2013 — Benedetti v Sawiris [2013] UKSC 50 (leading UK quantum meruit precedent).
Bigazzi was K2 London EMD who ran the Arora desk-research / TIM Hellas dossier for Benedetti during the SoftBank caper. Italian K2 partner. Also ran 'Project Spring' covert anti-asbestos infiltration (2012-2016, settled Nov 2018 substantial damages) — same operator network, identical BVI-paymaster pattern (Wetherby Select / Barkmere Group).
Co-Designated Members of Asherco LLP (UK OC379532) since Jul 1 2024. Villaume sole UK natural-person fiduciary signatory after BVI-nominee era + Dotan Moshe bridge. Took role post-WSJ + post-UK Economic Crime Act 2022/2023 — full information.
Chair from 1 Mar 2016; also chair of SPQR Capital Services Sagl (Lugano CH)
Co-directors SPQR Capital Holding SA (Lux) - simultaneous installation 1 Mar 2016 during Wind Hellas creditor litigation
Paris contacts list, calendar entries Sept-Oct 2013, Epstein inquired about Benedetti via Teodorani Jan 28 2019
Epstein queried Teodorani about Benedetti Jan 28 2019 via one-line email. Teodorani was Epstein Italian connection who would know Benedetti from Italian business circles.
Both on Epstein Paris list Sept 2013. Epstein asked Teodorani about Benedetti Jan 2019. Italian high society connection
Weingarten knew of Benedetti through Epstein by Dec 2011, later considered deploying someone on SoftBank caper Benedetti orchestrated
Epstein queried Teodorani about Benedetti on Jan 28 2019 (EFTA02628256). Both Italian. Teodorani is SVP CNH Industrial.
Teodorani bridge to Benedetti SoftBank op [Wave 7]
Misra introduced Klein to Benedetti June 2017. Trio met at Hotel Baur au Lac Zurich Nov 2017. Misra urged Klein to hire Benedetti for M Klein & Co Europe; Klein declined. M Klein & Co denies any business relationship with Benedetti.
Both named in Rome prosecutors' February 28, 2008 corruption probe of the Wind/Enel deal. Conti was Enel CEO; Benedetti was the alleged mediator. Outcome likely time-barred (prescrizione). Per Il Sole 24 Ore and Tgcom coverage.
Benedetti brokered the 2005 Wind Telecomunicazioni acquisition for Sawiris (Europe's largest LBO ~EUR 12bn) — Sawiris's Wind/Weather then bought TIM Hellas in 2007. Benedetti v Sawiris [2013] UKSC 50 dispute over the Wind brokerage fee. The TIM Hellas litigation Misra paid Benedetti USD 500K to weaponize against Arora arose from Benedetti's own brokered deal.
Both on same Sep 26 2013 Epstein schedule (EFTA02297224). Osborne breakfast 8:30am, Benedetti Paris reminder. Circumstantial connection.
All Findings
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All Findings
38 totalfinancial (5)
UK Companies House reveals Benedetti's full corporate network. Born July 1961, Italian, resident in Switzerland (Lugano, 7 Riva Paradiso). FOUR UK appointments: (1) ASHERCO LLP (OC379532, active since Oct 2012, 4 Moorgate London) - current co-member with Mathieu Villaume (Luxembourg). Former members include Dotan Moshe (Israeli), SATSU FINANCE LTD (BVI 1583501), and YOUNGSTOWN INVESTMENTS GROUP LTD (BVI 1688567, PO Box 3483 Road Town Tortola). (2) SCHWARZFIELD LLP (OC379789, Oct 2012, dissolved). (3) ATTALI INVESTMENT PARTNERS LTD (07138407, Jan 2010-Dec 2015, dissolved) - co-directors included Bertrand Gauquelin des Pallieres (French, resident Rome) and corporate successor METHORIOS CAPITAL LLP. (4) SILVERARROW CAPITAL ADVISORS LLP (OC379903, Nov 2012-Mar 2013, dissolved).
FULL BIOGRAPHY SYNTHESIS: Benedetti (born Jul 1961, Italian, resident Switzerland/Geneva/Lugano) is a Geneva-based financier and founding partner of Schwarzfield. His career-defining deal: brokering the 2005 acquisition of Wind Telecomunicazioni SpA for Naguib Sawiris (Egyptian billionaire, Orascom Telecom), Europe's then-largest LBO at approx 12 billion euros. Benedetti received 67M+ euros but sued Sawiris for a 1/3 stake -- lost at UK Supreme Court Jul 2013 (Benedetti v Sawiris). Also investigated by Roman prosecutors for corruption in the Wind deal (2008). He has 30+ years experience in telecoms, energy, mining, real estate across W/E Europe, Scandinavia, CIS, Africa, North America, Middle East. Former non-exec director of Cadogan Petroleum (Ukraine oil/gas, Aug 2010-Jun 2012). Chairman of SPQR Capital SA. CEO of SAE Capital. Executive Chairman of NYSE-listed Equus Total Return (2011-2014).
SEC EDGAR reveals Benedetti was EXECUTIVE CHAIRMAN of Equus Total Return Inc (NYSE: EQS, CIK 878932), a publicly traded closed-end fund, from June 2011 to June 2014. He was also a director (board member nominee). He owned over 100K in shares personally plus 400K shares through EB FINANCE S.A. (of which he disclaims beneficial ownership). The DEF 14A filing lists his roles: CEO of SAE Capital Ltd (founded Jan 2007), Director of Attali Investment Partners Ltd (since Oct 2010), Director of SPQR Capital Holdings S.A. (since Aug 2010), Non-exec director of Cadogan Petroleum plc (Aug 2010-Jun 2012), director of Versatile Systems Inc (since Dec 2008), Director of Schwarzfield S.A. (since Feb 2013), Schwarzfield Services SAGL (since Oct 2013), and Director of Asherco LLP (since Oct 2012). 8 hits across 2011-2016 proxy statements.
ASHERCO LLP (OC379532) reveals Benedetti's BVI connections. Two former BVI corporate members: YOUNGSTOWN INVESTMENTS GROUP LTD (BVI 1688567, Nov 2014-Nov 2021, PO Box 3483 Road Town Tortola) and SATSU FINANCE LTD (BVI 1583501, Nov 2021-Mar 2023, same PO Box 3483 address). Both BVI entities at SAME address: PO Box 3483, R.G. Hodge Plaza, Wickhams Cay 1, Road Town, Tortola, BVI. This is a registered agent address. Former member Dotan Moshe (Israeli, Feb 1972, 116 Ballards Lane London N3 2DN, Mar 2023-Jul 2024) replaced after BVI entities departed. Current co-member Mathieu Villaume (Luxembourg, Aug 1976) from Jul 2024. Pattern: BVI corporate members rotate through Asherco to obscure beneficial ownership.
Misra paid Benedetti $500K in April 2015 via Standard Chartered Bank to Barkmere Group Ltd, a BVI company controlled by Benedetti. Misra's spokesman claimed this was for 'oil investment.' Benedetti appears in ICIJ Paradise Papers as shareholder of Tree of Life Limited (Malta, C67345, incorporated Oct 2014), registered to Via delle Serre N. 9/A, Firenze, Italy.
relationship (9)
Benedetti has been a director at Attali Investment Partners Ltd since 2010, placing him on the board of Jacques Attali's investment firm. Attali is former senior advisor to President Mitterrand and first president of EBRD. This directorship is the link between Benedetti's SoftBank/intelligence operative activities and French political elite. Benedetti's broader corporate portfolio: Chairman of Schwarzfield SA (2012+), Director of SPQR Capital Holdings SA (2010+), Asherco LLP (2012+), Schwarzfield Services SAGL (2013+). Previously President of M Finances SAS (Paris 2000-2001), Chairman of Equus Total Return Inc (until 2015).
Alessandro Benedetti appears in Epstein's documents as a Paris contact from at least 2013-2019. EFTA02297224 (Sep 25, 2013) lists 'allesandro de benedetti-paris' alongside schedule items for Ian Osborne breakfast, Larry Summers lunch, and Rich/Darren (Kahn/Indyke) meeting, plus Paris departure via Air France. EFTA02575400 shows Benedetti on an explicit Paris contact list. EFTA02628256 (Jan 28, 2019) references 'Allesandro benedetti?' alongside 'TEODORANI Eduardo (CNH Industrial)' -- both are Italian businessmen Epstein was tracking in his final months.
EFTA02297224 (Sep 25, 2013) schedule places Benedetti-Paris on the same day as breakfast with Ian Osborne (Thiel intermediary), lunch with Larry Summers, and meeting with Richard Kahn and Darren Indyke, before Epstein departs for Paris via Air France. This places Benedetti in the context of Epstein's tech/intelligence inner circle -- Osborne is the key Thiel intermediary, Summers the economics/policy advisor, Kahn/Indyke the legal/financial controllers. Benedetti appears to be Epstein's Paris contact in the European intelligence/finance world, consistent with his SAE Capital M&A role and later SoftBank operation.
Benedetti appears on Epstein's Paris contact list from Sept 26, 2013, listed as '-Alesandro de benedetti' alongside Lang, Victo, Ariane, Fred, Fabrice, Emily, Jean Luc, Fabrizio, Shahar, Wojtek Fibak (Fine Arts Investments), and Margherita Campella Della Spina. A separate reminder from the same day confirmed the meeting. A second reminder on Oct 7, 2013 shows another planned Paris meeting. This places Benedetti in Epstein's Paris social circle at least 2 years BEFORE the SoftBank smear campaign began in early 2015. The same day's schedule included breakfast with Ian Osborne and lunch with Larry Summers.
Benedetti ('Alesandro de benedetti') appears on Epstein's Paris contact list Sept 26, 2013, alongside Teodorani, Shahar, Wojtek Fibak (Fine Arts Investments), Margherita Campella Della Spina, Sultan, and others. Multiple Groff reminders about Benedetti-Paris meetings Sept 26 and Oct 7, 2013. The same Sept 26 schedule shows: 8:30am breakfast with Ian Osborne, 11:30am lunch with Larry Summers, 1:00pm with Rich and Darren, then departing for Paris via Air France.
Benedetti was on Epstein's Paris social circle since at least Sept 2013. Groff scheduled reminders for 'Allesandro de Benedetti-Paris' on Sept 26, 2013 and Oct 7, 2013. Benedetti also appears on Epstein's Paris contacts list alongside Ariane de Rothschild, Shahar, and others.
Benedetti was a long-standing Epstein Paris associate, appearing in multiple scheduling and contact documents: (1) EFTA02575276: 'Allesandro de Benedetti-Paris' reminder (Sep 2013). (2) EFTA02576024: duplicate reminder. (3) EFTA02297224: Benedetti on same Sep 26 2013 schedule as Ian Osborne breakfast and Larry Summers lunch, before Epstein departs for Paris. (4) EFTA02575400: Lesley Groff sends Epstein 'Paris List' with Benedetti as first name, followed by 13 other names including Shahar, Sultan, Wojtek Fibak (art), Margherita Campella della Spina (Sep 26 2013). (5) EFTA02628256: Jan 28 2019 -- Epstein emails Teodorani (CNH Industrial/Agnelli): 'Allesandro benedetti?' -- a one-line inquiry 72 hours after the Weingarten 'Softbank caper' message (Jan 25). This Jan 28 inquiry to Teodorani about Benedetti, cross-referenced with the Wave 7 SoftBank timeline, confirms Epstein was actively investigating the Benedetti SoftBank operation in real-time.
Epstein emailed Eduardo Teodorani (CNH Industrial) on Jan 28, 2019 with one-word inquiry: 'Allesandro benedetti?' — asking about Benedetti 10 months after WSJ March 2018 expose of SoftBank dirty tricks campaign. This is intelligence-gathering about Benedetti, not an introduction.
Three directors of SPQR Capital Holding (B150334) appointed simultaneously 1 Mar 2016: Alessandro Benedetti (Chair), Bertrand G. des Pallieres, Mathieu Villaume - simultaneous board installation pattern coincident with Wind Hellas creditor litigation phase
Synthesis: The 1 Mar 2016 simultaneous appointment of Benedetti+des Pallieres+Villaume to SPQR Capital Holding's board is operationally significant - it was during the active phase of SPQR's Wind Hellas / TIM Hellas creditor dispute against Naguib Sawiris's Weather Investments. The three-handed board (PE principal Benedetti + hedge-fund founder des Pallieres + director-for-hire Villaume) is a typical Lux fund-vehicle governance shape: principal + co-investor representative + independent.
legal (1)
Benedetti's pre-SoftBank legal exposure: June 2003 Turin conviction (1 year 7 months reclusione, suspended) for Commertec bankruptcy; UK Supreme Court loss to Sawiris (2013); Sept 1996 Nice police raid
Alessandro Benedetti (Italian, born July 13, 1961, Sassuolo Modena; resident Lugano 7 Riva Paradiso) had substantial pre-SoftBank legal exposure: (1) June 12, 2003: Turin conviction for Commertec bankruptcy — 1 year 7 months reclusione (suspended). First documented Italian criminal conviction. (2) July 17, 2013: UK Supreme Court loss to Naguib Sawiris (Wind Telecom brokerage fee dispute, ~€67M plus €3.4M support = ~€97M total). Benedetti v Sawiris [2013] UKSC 50 became the leading UK precedent on unjust enrichment / quantum meruit. Lower courts: UK High Court 2009, Court of Appeal 2010. (3) September 1996: Nice judicial police raided his Beaulieu-sur-Mer residence (Villa Roc Fleuri); subsequent French imprisonment and house arrest (per Il Sole 24 Ore reconstruction by Claudio Gatti, Mar 11 2008). (4) February 28, 2008: Rome prosecutors opened bribery investigation into the Wind deal naming Naguib Sawiris, Fulvio Conti (Enel CEO), and Benedetti as mediator. Outcome likely time-barred (prescrizione). (5) 2014 UK Commercial Court: Kruppa v Benedetti [2014] EWHC 1887 (Comm) — joint defendant with Bertrand des Pallieres. By 2015 when Misra hired him, Benedetti had 30+ years of cross-jurisdictional financial-intelligence tradecraft and a documented Italian criminal record.
intelligence (12)
ATTALI INVESTMENT PARTNERS LTD (UK 07138407): Benedetti was co-director with Bertrand Gauquelin des Pallieres (French, born Nov 1966, resident in Rome at 9 Via G A Rayneri). Company name references Jacques Attali -- former adviser to French President Mitterrand, founder of EBRD, head of Attali and Associates advisory firm. Benedetti and Gauquelin co-founded in Jan 2010, both resigned Dec 2015 (same month), replaced by METHORIOS CAPITAL LLP as corporate director. SIC code 64999 (financial intermediation). Registered at 43-45 Dorset Street London W1U. The Attali connection places Benedetti in elite Franco-Italian political and financial circles -- the same milieu as Epstein's Paris network.
10-YEAR PREQUEL TO THE SOFTBANK CAPER — Benedetti himself brokered the underlying deal. The 'Egyptian investor' to whom Apax/TPG sold TIM Hellas for EUR 3.4bn in Feb 2007 is Naguib Sawiris/Weather Investments (later renamed Wind Telecom S.p.A.). Per existing finding #861, Benedetti's career-defining deal was brokering Sawiris's 2005 acquisition of Wind Telecomunicazioni SpA — Europe's largest LBO at ~EUR 12bn — for which Benedetti received EUR 67M+ but sued Sawiris for a 1/3 stake and lost at UK Supreme Court [2013] UKSC 50 (Benedetti v Sawiris). The TIM Hellas litigation (Hosking/Bonney NY claim and Luxembourg suit) used in Oct 2015 to smear Arora arose directly from a deal that BENEDETTI BROKERED to Sawiris in 2007. The 2015 Independent piece is therefore not just a planted smear — it is Benedetti weaponizing the unwind of his own brokered deal to attack the man he was paid USD 500K to destroy. The structural grievance loop: (1) 2005 Benedetti brokers Wind for Sawiris, gets EUR 67M; (2) 2007 Sawiris/Wind acquires TIM Hellas from Apax/TPG; (3) 2009 TIM Hellas collapses; (4) 2013 UKSC rules against Benedetti; (5) 2015 Misra pays Benedetti USD 500K to use the TIM Hellas litigation as ammunition against Arora. Benedetti has personal grievance against Sawiris AND structural knowledge of every transaction in the chain. He is the only operative who could have curated this exact attack vector.
EFTA00925685 (Dec 9, 2011): Weingarten to Epstein: 'did we ever talk about allesandro Benedetti, your Italian jewish neighbor on ave. foch?' This establishes: (1) Benedetti was Epstein's NEIGHBOR on Avenue Foch in Paris — the same street as Epstein's 22 Avenue Foch property; (2) The Epstein-Benedetti relationship predates the SoftBank honey trap campaign (2015) by at least 4 years; (3) Weingarten knew of Benedetti through Epstein; (4) Epstein IGNORES the Benedetti question in the email chain, deflecting to scheduling — suggesting the topic was discussed by phone or Epstein preferred not to respond in writing. Also notable: Weingarten says 'have some interesting jeffrey-reid projects in mind' — confirming active joint ventures between Epstein and Weingarten beyond legal representation.
Benedetti appears in Epstein's calendar/reminder system as 'Allesandro de Benedetti - Paris' on Sept 26, 2013 (EFTA02575276) and Oct 7, 2013 (EFTA02576024). On the Sept 26 schedule (EFTA02297224), Benedetti appears alongside: '8:30am Breakfast w/Ian Osborne, 11:30am Lunch w/Larry Summers, 1:00pm Appt w/Rich and Darren' followed by departure to Paris. On a separate Paris contacts list (EFTA02575400), 'Alesandro de benedetti' appears first, alongside Wojtek Fibak (Fine Arts Investments), 'Sultan in Paris Sun. Sept 29th', Frederic Chaslin, and multiple women. This places Benedetti firmly in Epstein's Paris social-intelligence network as early as 2013.
Alessandro 'de Benedetti' appears in Epstein's Paris calendar and contact lists for Sep-Oct 2013. On Sep 26 2013, Lesley Groff sent reminders for 'Allesandro de Benedetti-Paris' alongside Epstein's schedule: breakfast with Ian Osborne, lunch with Larry Summers, then 9:55pm Air France to Paris. A Paris List (EFTA02575400) includes Benedetti alongside Lang, Victo, Ariane, Fabrice, Shahar, Wojtek Fibak, Margehrita Campella Della Spina, Sultan, Giselle, and Frederic Chaslin. A second reminder for 'allesandro de benedetti paris' was sent Oct 7 2013. Benedetti later hired by SoftBank's Rajeev Misra to run honey trap against Nikesh Arora (WSJ Feb 2020). Axios reported Benedetti had Cambridge Analytica/SCL Group ties.
SoftBank honey trap operation timeline: Jan 2015 Misra-Benedetti meet London. Apr 2015 $500K payment to Barkmere Group BVI. 2015 honey trap attempt in Tokyo (women + hidden cameras, Arora didn't fall for it). 2015 K2 Intelligence hired to investigate Arora/Sama. K2 hired Powerscourt Group (London PR) to place findings. Sept 2015 Nicolas Giannakopoulos (Swiss operative, Cambridge Analytica/SCL ties) hires Mark Hollingsworth (freelancer). Oct 2015 Independent publishes Arora story. Nov 2015 shareholder campaign begins. Jan 2016 first shareholder letter. Jun 2016 Arora resigns. Apr 2019 Sama leaves. 2018 Shearman Sterling probe: inconclusive. Feb 2020 WSJ breaks full story.
WSJ identified Benedetti as the central operative in the SoftBank smear campaign. Giannakopoulos (Swiss intelligence, Cambridge Analytica/SCL Group agent) was his subcontractor. The operation used code name 'Mr. West' for Arora. Benedetti expected compensation beyond the $500K: a cut of Misra's SoftBank earnings and to be named head of Vision Fund in London. Bertrand des Pallieres (French banker, former Deutsche Bank trader under Misra) introduced Misra and Benedetti. Meetings at London's Bulgari Hotel and Zurich's Hotel Baur au Lac (Nov 2017). Special cellphone provided for operational communications.
Benedetti leaked SoftBank honey trap operation to WSJ because Misra failed to pay promised compensation. Benedetti expected: (1) share of Misra's SoftBank earnings, (2) senior executive position at Vision Fund London. Neither materialized after K initial payment. Associates say Benedetti recorded conversations with Misra detailing plans to sabotage rivals.
Epstein emailed Eduardo Teodorani (CNH Industrial/Fiat executive) on Jan 28, 2019 -- just TWO DAYS after asking Brad Karp about Misra's representation -- with a single question: 'Allesandro benedetti?' This indicates Epstein was actively seeking to contact or learn about Benedetti through Italian corporate networks at the exact moment the SoftBank honey trap operation was under legal scrutiny.
On Jan 28, 2019 — exactly 2 days after the Karp/Misra and Weingarten/SoftBank exchanges — Epstein emailed Eduardo Teodorani (SVP, CNH Industrial) with a single line: 'Allesandro benedetti?' This shows Epstein was actively gathering intelligence about Benedetti, the very person WSJ later identified as the operative paid $500K by Misra to run smear campaigns and honey traps against SoftBank rivals. The 48-hour Karp→Misra→Benedetti inquiry sequence is too precise to be coincidental.
Epstein asked Teodorani (CNH Industrial/Agnelli heir) about 'Allesandro benedetti?' on Jan 28, 2019 — two days after asking Karp about representing Misra and the same week Weingarten discussed the 'Softbank caper.' This places Epstein actively networking around the SoftBank scandal, potentially seeking Benedetti as an operative or source through his Italian contacts.
TEMPORAL PATTERN: Oct 2013 activity burst — 16 findings in 14-day window (Sep 22-Oct 6 2013), the largest single-period cluster for any target. Benedetti dominates with 10 findings. This coincides with peak STC transfer year (Black M), Leon Black thread activity (5 findings same week in T5), and Ariane de Rothschild cross-thread presence. Suggests Benedetti was central to a coordinated operational period.
The Oct 2013 burst is the densest non-2019 activity cluster in the entire investigation. It spans 3 threads simultaneously (T1, T3, T5). Benedetti findings cluster around his role as intermediary, while Leon Black and Joshua Harris activity in T5 suggests parallel Apollo financial flows. The temporal co-occurrence of Benedetti intelligence activity with peak Black-Epstein financial transfers is the strongest cross-thread temporal correlation in the pre-2018 period.
identity (7)
DISAMBIGUATION: Alessandro De Benedetti at Northzone VC (grandson of Carlo De Benedetti/Olivetti/CIR dynasty, son of Marco De Benedetti/Carlyle) is a DIFFERENT person from Epstein's contact. Northzone De Benedetti is too young (joined as associate in 2024) and based in Stockholm. Epstein's Benedetti is the SAE Capital CEO born July 1961, confirmed via UK Companies House directorships and ICIJ Paradise Papers (Florence address).
Benedetti's claimed Jewish identity from ~1986 is self-presented, NOT ancestral — born/raised Catholic to Franzoni family ('cattolicissima'); reframes Weingarten's 'Italian jewish neighbor' description
Per Il Sole 24 Ore reconstruction by investigative journalist Claudio Gatti (Mar 11, 2008), Alessandro Benedetti was born and raised Catholic. Mother from the Franzoni family, described as 'cattolicissima' (extremely devout Catholic). However, from circa 1986 he allegedly began claiming Jewish identity, reportedly stating that 'great business deals require being Jewish.' This is what Reid Weingarten was relaying when he described Benedetti to Epstein on Dec 9, 2011 (EFTA00925685) as Epstein's 'Italian jewish neighbor on ave. foch.' NEGATIVE on documentary evidence that Benedetti is halakhically or ancestrally Jewish. NEGATIVE on connection to historic Italian Jewish patriciate families (Sereni, De Benedetti, Della Pergola, Foa, Modigliani). His Florence address (Via delle Serre 9/A) is non-historic-ghetto residential. Likely a claimed identity used as elite-network lubricant, particularly relevant given Benedetti's Sawiris (Egyptian Coptic), Saudi PIF/MBS-adjacent (via Misra/SoftBank), and Russian-language operational portfolio. Important disambiguation: Alessandro Benedetti is NOT related to the De Benedetti industrial dynasty (Carlo De Benedetti / Olivetti / CIR / GEDI) — his family was a failed crane-manufacturing concern from Sassuolo.
Identity CONFIRMED: 'Allesandro de Benedetti - Paris' in Epstein contacts = Alessandro Benedetti, CEO of SAE Capital Ltd (founded 2007), born July 1961, Italian national, Swiss resident. UK Companies House confirms his directorships at Attali Investment Partners Ltd (since 2010), M Finances SAS (President 2000-2001, Paris), and Vendome Investments Ltd (2005-2011) — all Paris-connected entities that explain his designation as a Paris contact. The 'de' particle is a French-style name rendering not used in formal UK/Italian filings.
Benedetti's full corporate constellation across 10 jurisdictions (~22 confirmed entities) — textbook financial-intelligence operational architecture
Active/current entities: Schwarzfield SA (Lux/Geneva, Chairman), Schwarzfield Services SAGL (Lugano), SAE Capital Ltd (UK, CEO/Founder Jan 2007-present), SPQR Capital Holdings SA (Lux, Director 2010-present), SPQR Capital Services Sagl (Switzerland, Chair), Asherco LLP (UK OC379532, Designated Member since Oct 2012), Tree of Life Limited (Malta C67345, shareholder, ICIJ Paradise Papers), Barkmere Group Ltd (BVI, beneficial controller — received Misra's 500K). Resigned/dissolved: Schwarzfield LLP (UK), SilverArrow Capital Advisors LLP (UK), Attali Investment Partners Ltd (UK 07138407, Jan 2010-Dec 2015, co-director with des Pallieres, name references Jacques Attali), Equus Total Return Inc (NYSE: EQS, Executive Chairman June 2011-June 2014), Cadogan Petroleum plc (UK/Ukraine NED Aug 2010-June 2012), M Finances SAS (Paris CEO 2000-2001), Vendome Investments Ltd (UK Director 2005-2011), Methorios Capital (acquired 14% in 2011 for 10M EUR), International Technologies Management Ltd (ITM — vehicle that received 67M EUR from Sawiris for Wind brokerage), Managest Media SA (Switzerland), Weather Investments Sarl (Lux), Swissital SpA (Italy ~1980), Mineraria Italiana SpA (Italy 1983 asbestos), Francescato SpA (Italy 1983 chemical), Magnetofoni Castelli (Milan 1989-93 Ligresti era — 100 companies offshore, 65B lire exported), Commertec (Turin, June 2003 bankruptcy conviction). Roughly 22 entities across Italy, UK, Lux, Switzerland, BVI, Malta, USA, France, Netherlands, Panama. Pattern is operational architecture for cross-border financial-intelligence work, not normal investment activity.
ICIJ Paradise Papers confirms Benedetti's registered address as Via delle Serre 9/A, Florence (Firenze) 50100, Italy. This is his personal/residential address used for the Tree of Life Limited Malta shareholder filing. Benedetti is confirmed Italian national. His name appears in Epstein documents as 'Allesandro de Benedetti' (with French-style 'de' particle), suggesting he may use both Italian and French-style name forms.
7+ UK directorships: Vendome Investments, SAE Capital, Attali, Schwarzfield, Asherco
Vendome Investments (05296529, 2005-2011), SAE Capital (05640558, sole director 2005), Attali Investment Partners (07138407, 2010-2015, Lugano), Schwarzfield LLP (OC379789, 2012), Asherco LLP (OC379532), Silverarrow Capital Advisors LLP. Shared agent: C&P Company Secretaries. Addresses: 26 Eaton Place, 59 Chester Square, 3 More London Riverside.
Bertrand G. des Pallieres = Wind Hellas / TIM Hellas figure (NOT Stephane); founder/CEO SPQR Capital; ex-JPMorgan MD Global Head Structured Credit (1992-2005), ex-Deutsche Bank MD Global Head Principal Finance (2005-2007); director SPQR Capital Holdings SA (Lux), Equus Total Return Inc, Cadogan Petroleum Plc, Lansdowne Capital SA, InfraVia Capital Partners SAS, Attali Investment Partners Ltd, Euromax Finance Ltd, Methorios Capital Services Ltd, SPQR Capital (Cayman) Ltd, Bitfury Group Ltd
CORRECTION: Round 5 record shows 'Stephane des Pallieres' - actual name is Bertrand G. des Pallieres. He called on ICAEW to investigate Ernst & Young over Wind Hellas administration after SPQR Capital and other junior bondholders lost millions when Naguib Sawiris (Weather Investments) wiped GBP 1.3bn debt acquiring the group out of administration. Bitfury board seat = blockchain crypto exposure.
document (4)
DOJ Vol 11 contains a SEPARATE Cyprus entity TREE OF LIFE LIMITED (HE 279303) incorporated 2010-12-27, dissolved 2016-01-11, at Agias Elenis 36, Galaxias Commercial Center, Floor 4, Flat 401, 1061, Nicosia, Cyprus. This is distinct from the Malta entity (C67345, incorporated 2014-10-28). The Cyprus Tree of Life has 3 directorship relationships per Aleph. Possible predecessor entity to the Malta Tree of Life -- note the Malta entity was incorporated Oct 2014 and the Cyprus entity dissolved Jan 2016, suggesting a migration from Cyprus to Malta jurisdiction.
DOJ Vol 11 Paris contact list (EFTA02575400, Sept 26 2013) places Benedetti first on Epstein's 'Paris List' alongside: Lang, Victo, Ariane, Fred, Fabrice, Emily, Jean Luc, Fabrizio, Shahar, Wojtek Fibak (Fine Arts Investments), Margherita Campella Della Spina (arriving by train Sept 27), 'Sultan in Paris Sun Sept 29', Giselle, and Frederic Chaslin. This list was sent by Lesley Groff to Epstein. The same day's schedule (EFTA02297224) shows Benedetti as a Reminder item alongside breakfast with Ian Osborne, lunch with Larry Summers, and appointment with Rich and Darren, before Epstein departed for Paris via Air France from JFK at 9:55pm. Benedetti is explicitly in the same social orbit as Summers and Osborne.
SPQR Capital Holding SA (Lux RCS B150334) - liquidated 16 Mar 2023; office 12 rue Guillaume Schneider L-2522 (SAME as Saleve); directors Alessandro Benedetti (Chair from 1 Mar 2016) + Bertrand G. des Pallieres (1 Mar 2016) + Mathieu Villaume (1 Mar 2016 to 7 Feb 2018) + Michel Thill (Oct 2021 to Aug 2022); liquidator Christian Steinmetz
Bertrand des Pallieres = the Wind Hellas / TIM Hellas figure (NOT 'Stephane' - corrects Round 5 record). SPQR Capital Services Sagl in Lugano CH (CHE-496.390.425, CHF 20k, registered 17 Mar 2011, chair Alessandro Benedetti) is the Swiss arm. Three directors of SPQR Holding (Benedetti, des Pallieres, Villaume) all appointed same day 1 Mar 2016 - simultaneous board installation pattern.
Compagnie Du Saleve SA (Lux RCS B223232) wholly owned by Five Arrows AutoBench Holding Sarl (B209234) since 8 Mar 2023; current directors Pierre Mouliere + Mathieu Villaume; office 12 rue Guillaume Schneider L-2522 (NeoTrust Fiduciary domicile)
Reg 23 Mar 2018, capital EUR 6,854,000, LEI 254900TWD935XLM3HD91. Past directors: Othman Baraka (apt 25 Jan 2023), Lucie Delamontagne (term 25 Jan 2023), Pierre-Yves Mouliere (apt Sept 2019). Previous shareholder Luxfactory Group (2020-2021); 27 Jul 2018 record showed Five Arrows White C Holding Sarl (renamed AutoBench 2 Dec 2020 - same entity B209234).
Full Timeline
41 events
Full Timeline
41 events- 1.Finding #861
- 2.Finding #1632
- 3.Finding #842
- 4.Finding #847
- 5.EFTA00925685
- 6.Finding #814
- 7.EFTA02575400
- 8.Finding #835
- 9.EFTA02628256
- 10.Finding #518
- 11.Finding #776
- 12.Finding #740
- 13.Finding #785
- 14.Finding #774
- 15.Finding #733
- 16.Finding #988
- 17.Finding #1244
- 18.EFTA02297224
- 19.Finding #849
- 20.Finding #734
- 21.EFTA02575276
- 22.EFTA02576024
- 23.Finding #519
- 24.Finding #778
- 25.Finding #1633
- 26.Finding #843
- 27.Finding #844
- 28.Finding #1644
- 29.Finding #833
- 30.Finding #11215
- 31.Finding #11211
- 32.Finding #11221
- 33.Finding #11226
- 34.Finding #11102