Self-Regulation Worked Out Well for Boeing

# Self-Regulation Worked Out Well for Boeing

Boeing self-certified the 737 MAX. The FAA delegated safety oversight to the company it was supposed to oversee through something called the Organization Designation Authorization. Boeing's own employees signed off on Boeing's own safety assessments.

346 people died. Two planes fell out of the sky. Lion Air Flight 610 and Ethiopian Airlines Flight 302.

After the crashes, investigations revealed that Boeing had known about problems with the MCAS flight control system. Internal communications showed employees joking about safety concerns. The company had prioritized production speed over engineering rigor. The self-certification process had failed at every level.

The parallel to Apollo Global Management's Epstein investigation is structural, not rhetorical.

The Dechert Investigation

In October 2020, Apollo's Conflicts Committee retained Dechert LLP to investigate the relationship between Jeffrey Epstein and Apollo. The investigation was announced to shareholders. It was presented as thorough and independent.

The Dechert memo — which is in the DOJ production we've indexed — opens:

> *"In October 2020, the Conflicts Committee of Apollo Global Management, Inc. ('Apollo') retained Dechert LLP ('Dechert') as independent counsel to conduct a thorough investigation into (1) the relationship between Leon Black ('Black') and Jeffrey Epstein ('Epstein'), including any financial, business or personal dealings between Black and any Black affiliate, on the one hand, and Epstein and any Epstein affiliate on the other; (2) any work performed for, or services rendered to, Black or any Black affiliate by Epstein or any Epstein affiliate..."*

Read that scope carefully. The investigation was into:

1. The relationship between **Leon Black** and Epstein

2. Any work performed for **Black or any Black affiliate**

The investigation was not scoped to examine:

- Josh Harris's years-long financial advisory relationship with Epstein

- Harris sharing org charts, trust structures, and beneficiary details with Epstein

- The "financial confessional booth" correspondence

- The Bob Bodian go-between channel

- Brad Karp's meetings at Epstein's residence

- The "whoopsie" email chain about Kushner-Apollo loans

- Kathy Ruemmler's role as named trustee on Epstein's 2018 Trust

The Conflicts Committee investigated one co-founder. Not both. Not the law firm chairman. Not the former White House Counsel who was literally a trustee on Epstein's trust.

Who Chose the Scope?

The Conflicts Committee chose Dechert. The Conflicts Committee defined the scope. The Conflicts Committee was a committee of Apollo's own board.

Boeing's employees certified Boeing's planes. Apollo's board investigated Apollo's relationships.

The FAA had delegated its oversight authority to Boeing through the ODA program. Apollo's shareholders delegated their oversight authority to the Conflicts Committee through corporate governance.

In both cases, the entity with the conflict of interest controlled the investigation of the conflict of interest.

What the Scoped-Out Investigation Missed

Because the Dechert investigation focused on Black, here is what was not in scope — all documented in the 329,473 DOJ documents:

Josh Harris (712 hits)

- Epstein requesting "a full org chart, ownership interests, summary of will trusts, beneficiaries, trustees, names of accounts, pre-nups, pledges" from Harris (January 2014)

- Six weeks of Epstein's assistant chasing Harris's assistant for these documents

- Epstein brokering a Bill Gates introduction to Harris (November 2014)

- Epstein describing himself as Harris's "financial confessional booth for jews" (September 2016)

- Harris maintaining contact through Apollo executive Bob Bodian when traveling (September 2016)

- All correspondence continuing years after Epstein's 2008 conviction

Brad Karp (1,000+ hits)

- Chairman of Paul, Weiss — Apollo's primary outside counsel

- Regular meetings at Epstein's residence (May 2017, July 2017)

- Joint meeting with Kathy Ruemmler at Epstein's home (May 2017)

- The "whoopsie" email chain: Epstein forwarding Karp the NYT article about Apollo's loans to Jared Kushner's family business. Karp's response: "Whoa." Epstein: "this could get interesting. It will spook everyone." Karp: "Same response." (February 2018)

- The chairman of Apollo's law firm discussing Apollo's business with a convicted sex offender

Kathy Ruemmler (1,000+ hits)

- **Named trustee on the Jeffrey E. Epstein 2018 Trust** alongside Darren Indyke and Richard Kahn

- Former White House Counsel under President Obama

- Career coached by Epstein — salary negotiations, law firm offers

- Connected David Boies to Epstein's legal team for Ghislaine Maxwell's representation

- Forwarded her Facebook/Meta interview notes to Epstein (July 2018)

- Had Epstein's IT staff set up computers in her homes and office

- Later became Meta's General Counsel

The Dechert investigation found that Black paid Epstein approximately $158 million. Black stepped down as CEO in March 2021.

Everything else — Harris, Karp, Ruemmler, Bodian, the trust structures, the Kushner jokes, the White House Counsel trustee — remained outside the scope.

The Boeing Lesson

After the 737 MAX crashes, Congress held hearings. The FAA reformed the ODA program. Boeing's CEO was fired. Criminal charges were filed. The self-certification model was recognized as a structural failure.

The lesson was supposed to be: you cannot let the entity with the financial incentive control the oversight of its own conduct.

Apollo's Conflicts Committee investigated one co-founder's $158 million relationship. The other co-founder's trust-document-sharing relationship was not in scope. The law firm chairman's residence meetings were not in scope. The White House Counsel trustee was not in scope.

Boeing's ODA let the manufacturer certify its own safety. Apollo's Conflicts Committee let the board scope its own investigation.

Self-regulation. Same pattern. Different industry. Same result: the investigation finds exactly as much as the investigated party wants it to find.

The Difference

When Boeing self-certified, planes crashed and people died. The consequences were visible, immediate, and undeniable. You cannot hide a plane falling out of the sky.

When Apollo self-investigated, a memo was produced and a CEO stepped down. The documents showing the broader network — Harris, Karp, Ruemmler, Barak, Baron — remained in a DOJ production that nobody had indexed.

Until now.

329,473 documents. Searchable in under 100 milliseconds. Every EFTA reference number verifiable. The scope of our index is not defined by a Conflicts Committee.

The receipts don't have a scope limitation.

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*Boeing ODA and 737 MAX details from public Congressional testimony and NTSB reports. Apollo Dechert investigation details from the memo itself, which is in the DOJ production indexed at epstein.dugganusa.com. All Epstein document references sourced from DOJ-produced files with EFTA reference numbers.*

*DugganUSA LLC. $76/month. No Conflicts Committee. No scope limitations. Just the documents.*

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*Her name was Renee Nicole Good.*

*His name was Alex Jeffery Pretti.*