Paolo Zampolli

Zampolli in 2013 sold 14 Trump SoHo units (246 Spring St) to Italian clients Magda Pozzo and Gianpaolo Pozzo for $10,856,547; per plaintiff's complaint this was 'over 50% of all sales at Trump SoHo closed by the Sponsor-Defendants during the first ten (10) months of the entire 2013 year' — foreign bulk-buyer pattern typical of Bayrock-era Trump SoHo concerns

Zampolli sworn (July 2019) that May 7, 2015 Cabrits Kempinski Dominica agreement entitled him to 5% of development profits; project generated 800 CBI passports at $220K each = $195M gross; Asaria and Shehada received $30M distributions each from Bank of Dominica Geneva account while denying Zampolli his share

FEC records show one federal political donation: $250 to Maloney for Congress (Carolyn Maloney, D-NY) on 2021-12-14 via ActBlue. Listed address 119 East 17th Street, NYC 10003 (Zeckendorf Towers). Employer listed as RE, occupation as AMB. Notably small political donation footprint for someone in Trump inner circle.

Zampolli sought 7.5M USD finder fee from Dominica CBI-funded Kempinski hotel project. Court filings reveal government provided 800 passports worth approx 195M USD for the project. Zampolli held 5 pct stake. Affidavit claimed 30M USD plus 81.5M EC dollars paid to Range Developments officials from passport proceeds.

FEC records show Zampolli donated 250 USD to Maloney for Congress (D-NY) via ActBlue on 2021-12-14. Listed occupation as AMB, employer as RE, address 119 East 17th Street New York. Only FEC-recorded federal donation found.

LittleSis records Zampolli as a 'failed bidder' for Elite New York (entity 458780). In 2004, Zampolli and Epstein jointly attempted to acquire Elite Model Management at bankruptcy auction. The bid was unsuccessful.

Douglas Elliman sued Paolo Zampolli for allegedly hiding roughly 4 million dollars in commission from the brokerage. Zampolli was a former broker at the firm via the Paramount Realty Group of America Corp. division.

Douglas Elliman sued Zampolli for hiding approximately 4M in commissions while serving as co-chair of Paramount Realty Group of America Corp. Under dual license, Zampolli owed Elliman 30pct of commissions (~1.2M). Separate from but contextualizing the Bayrock/Trump SoHo commission dispute.

Zampolli contracted for 5% of Cabrits Kempinski profits from Range Developments; sued for non-payment of ~.5M from M CBI-funded hotel

On May 7, 2015, Zampolli signed agreement with Mohammed Asaria and Range Capital Partners (Dominica) Ltd entitling him to 5% of development profits from Cabrits Resort & Spa Kempinski. Project funded entirely by 800 CBI family passports at K each = M gross. Zampolli claims he brought the project to Dominica. Filed lawsuit in NY Supreme Court July 17, 2019 against Asaria, Shehada, Range entities, Kempinski Hotels, and Xavier Destribats. Claims Asaria/Shehada pocketed M from Bank of Dominica account held in Geneva, while he received nothing. Judge Eileen Rakower partially granted discovery order Oct 2019. Parallel London arbitration proceedings ongoing. Range Capital Markets filed counter-arbitration May 5, 2019.

Zampolli dual-licensed with Elliman and Paramount Realty 2011-2014; pattern of commission disputes across multiple lawsuits

Zampolli established a dual-license arrangement with Douglas Elliman in 2011 while maintaining his own Paramount Realty Group brokerage. Three separate commission-related lawsuits document a pattern: (1) Zampolli sued Massey Knakal in 2010 for $200K in commissions (dismissed). (2) Domus Arbiter sued Zampolli and others in 2014 for diverting $10.8M in Trump SoHo sales via 6% commission scheme. (3) Elliman sued Zampolli in 2015 for concealing ~$4M in commissions. The dual-license structure appears to have facilitated the alleged commission concealment — Zampolli could claim deals under either Paramount or Elliman depending on which was advantageous, while allegedly sharing proceeds with neither the original referring broker nor Elliman.

FEC records: Zampolli's only personal political donation was to Maloney for Congress (Dec 2021, via ActBlue)

FEC individual contributions database shows only one donation by Paolo Zampolli: $250 earmarked for Maloney for Congress (C00273169) on Dec 14, 2021 via ActBlue. Listed employer: 'RE', occupation: 'AMB'. This is Carolyn Maloney (D-NY), notably a Democratic congresswoman. No donations to Republican candidates, Trump committees, defense PACs, or Lockheed Martin PAC. Other FEC results for surname 'Zampolli' are Elizabeth Zampolli (Venice/Manhattan Beach, CA) donating small amounts to ActBlue/Warnock/Cortez Masto/Bernie 2016, and Claudio Zampolli (Santa Ana, CA) donating $25 to WinRed. No direct financial link between Zampolli and defense industry via FEC. No lobbying disclosure (LDA) filings found for 'GCAP' or 'Global Combat' as client names.

Zampolli/Paramount sold 14 Trump SoHo units for $10.86M in 2013 — 50% of all property sales that year

Zampolli/Paramount Realty sold 14 units at Trump SoHo for $10,856,547 in first 10 months of 2013, representing 50% of ALL sales at the property during that period. Bayrock/Sapir contracted with Zampolli and Douglas Elliman at 6% commission vs standard 4%. Domus Arbiter Realty (CEO Giampiero Rispo, Italian-born broker specializing in foreign investors) alleged its clients were diverted to Zampolli. The buyers were clients seeking to purchase property in New York for investment purposes, likely Italian/European investors given Domus clientele and Zampolli-Rispo Italian connection. Court dismissed claims against co-defendant Jay McGorty but allowed fraud claims against Zampolli and Bayrock to proceed.

ACRIS record: Zampolli sold 149 E 18th St PH for $3.15M in June 2008 to Donahue/Anderer

ACRIS document 2008061600054001 (RPTT&RET, recorded June 25, 2008): Zampolli sold his penthouse at 149 East 18th Street, Manhattan (Block 874, Lot 33) for $3,150,000 to Donald F. Donahue (29 E 22nd St, Apt 5N) and Jeanmarie Anderer (same address). 100% transfer. This was Zampolli personal residence during his transition from modeling to real estate — sold the same year Trump SoHo opened. The timing suggests capital redeployment as he ramped up Trump-related brokerage activity.

Zampolli Grenada Tourism appointment (Aug 2012) preceded CBI Act by one year: Mitchell returned as PM Feb 2013, passed CBI Act Aug 2013. Zampolli pre-positioned in tourism apparatus BEFORE CBI existed — mirroring Dominica pattern where he held diplomatic role before brokering Range Developments deal.

Critical timeline: Zampolli appointed Grenada Tourism Ambassador Aug 2012. Keith Mitchell's NNP swept all 15 seats Feb 2013. Mitchell sworn in Feb 20, 2013. Grenada Citizenship by Investment Act No. 15 of 2013 passed Aug 2013. Range Developments (founded 2011-12 by Asaria) signed Grenada agreement March 2019 for Six Senses La Sagesse. In Dominica, Zampolli was Minister-Counsellor from 2011, then brokered the Cabrits Kempinski under CBI. Same pattern: diplomatic role first, CBI-funded resort project follows.

Domus Arbiter case reveals Bayrock offered Zampolli 6% commission (vs standard 4%) to divert clients — suggests Zampolli was recruited specifically for Trump SoHo sales push

The Domus Arbiter complaint (651970/2014) alleges the Sponsor Defendants (Bayrock Group LLC, Bayrock/Sapir Organization, Bayrock/Zar Spring LLC) contracted with Paolo Zampolli, Jay T. McGorty, Paramount Realty Group, and Douglas Elliman LLC to offer a 6% commission if Zampolli could sell units to Domus Arbiter's clients — significantly above the standard 4% brokers' commission that Bayrock offered. This inflated commission suggests Zampolli was not merely a passive broker but was actively recruited, possibly because of his connections to high-net-worth international buyers. The complaint characterizes this as a 'scheme' to 'divert and steal clients.' Total sale: 14 units for $10,856,547.

Zampolli offered 6% commission to redirect Rispo's Italian clients at Trump SoHo; Elliman later sued Zampolli for hiding 4M in commissions

Per the Domus Arbiter lawsuit, Bayrock/Sapir contracted with Zampolli and Douglas Elliman LLC offering a 6% commission if Zampolli could sell more units to Domus Arbiter's Italian clients. Zampolli allegedly transferred all proceeds to his employer, The Paramount Realty Group of America Corp. Separately, Douglas Elliman sued Zampolli in 2015 alleging he hid approximately 4M in commissions earned during his time at the firm through a dual-license arrangement (Zampolli was supposed to hand over 30% of commissions done under Elliman name). That case was dismissed in 2018. This pattern shows Zampolli operating as intermediary between Italian HNW buyers and Trump properties - consistent with his role as Trump Org Director of International Development (2004+) and his Italian background.

Epstein associate email (EFTA02670679, Nov 9 2016): sender recalls flying with Donald Trump on Epstein plane 'the first weekend I went to visit you in Florida was the weekend he met Melania' — places Epstein in Trump orbit around time of introduction

Email dated November 9, 2016, from unnamed associate to Jeffrey Epstein: 'I remember flying back with Donald on his plane the first weekend I went to visit you in Florida was the weekend he met Melania and he kept on coming out of the bedroom saying wow what a hot piece of ass.' This email does NOT say Epstein introduced them — it says the sender flew with Trump around the same time as Trump met Melania. It places Epstein and Trump socializing together around the time of the introduction but does not resolve who made it. The sender is congratulating Epstein on Trump's election victory.

TEMPORAL PATTERN: 2004 convergence — Zampolli Group formation (Apr), Epstein joint Elite bid (Jun), Trump Org hire (Dec) within 8-month window, immediately following Elite bankruptcy (Feb)

The 2004 timeline reveals rapid-fire career pivots: (1) Feb 2004: Elite Model Management files bankruptcy (SDNY 04-10845); (2) Apr 6 2004: Zampolli Group Inc filed with NY DOS #3036893 — new corporate vehicle; (3) Jun 2004: Zampolli and Epstein jointly bid to acquire Elite (unsuccessful); (4) Dec 2004: Zampolli joins Trump Organization as Director of International Development. The Zampolli Group incorporation precedes the Epstein bid by just 2 months, suggesting the entity may have been created for the acquisition. The pivot from modeling to Trump Org after the failed bid suggests Zampolli was already in Trumps orbit and the modeling acquisition was a shared interest.

Zampolli joined Trump Organization as Director of International Development Dec 2004, immediately after failed Elite bid

After the failed Elite Model Management acquisition bid (2004), Donald Trump invited Zampolli to join the Trump Organization in December 2004 as Director of International Development, where he sold apartments at Trump Park Avenue. This timeline is significant: the bankruptcy auction of Elite occurred mid-2004, Zampolli's bid with Epstein failed, and within months he pivoted to Trump's real estate operation. He subsequently founded Paramount Group, employing former ID Models models as Manhattan property brokers.

TEMPORAL PATTERN: Caribbean multi-nation diplomatic credentialing in 26-month sprint (Aug 2012 - Oct 2013) with Maxwell TerraMar partnership in same window

Zampolli accumulated diplomatic roles from multiple Caribbean CBI nations at unusual pace: (1) Aug 2012: Grenada Tourism Ambassador (via PM Keith Mitchell); (2) Jan 2013: Partners with Ghislaine Maxwells TerraMar Project; (3) Oct 2013: Dominica UN Ambassador + Ambassador for Oceans and Seas (via PM Skerrit); (4) Jun 2014: Amanda Ungaro appointed Grenada UN Ambassador (via Mitchell). The TerraMar partnership was specifically in 'oceans and seas' — the same portfolio Skerrit gave Zampolli. This suggests the Maxwell partnership may have facilitated or complemented the Dominica appointment. Three Caribbean nations providing diplomatic roles to the same Italian-American businessman in overlapping timeframes (Grenada, Dominica, and later St. Kitts) fits the pattern Al Jazeera documented in their 'Diplomats for Sale' investigation (Nov 2019).

Zampolli dual-listed 2013-2014 as real estate salesperson at both (a) The Paramount Realty Group of America Corp, 110 Greene St Suite 12e, NYC 10012 and (b) Prudential Douglas Elliman per Elliman website — permitting the alleged straw-agent arrangement using Amy Williamson of Elliman to route Trump SoHo commissions to Paramount

Attorney roster in Ungaro v. Zampolli 301822/2018 after 2024 e-file conversion: Plaintiff Ungaro represented by Lauren J. Sakofsky, Merryl Evan Steinberg, Neena Tankha, Nassim Mehr Hosseinzadeh (motion 014 Jun 17 2025), Amy Lynne Twohig; Defendant Zampolli represented by Robert Marc Wallack (Wallack Firm PC, appeared 10/24/2024), Michael Andrew Belmont (appeared 07/01/2025), and Dawn M. Cardi (motion 015 from Jul 2025). Judge Michael L. Katz remains assigned. Cardi appearing for Zampolli alongside Wallack suggests escalation to a criminal-defense firm (Cardi & Edgar LLP is known for white-collar defense)

Zampolli introduced Melania Knauss to Donald Trump at a September 1998 party in NYC. Zampolli had met Melania in Milan in 1995 and sponsored her H-1B visa to the US in 1996 through his modeling agency.

LittleSis documents 19 relationships: Long-time friend of Donald Trump. Social with John Casablancas, Ivanka Trump, Huma Abedin. Professional relationship with Ghislaine Maxwell. Business partner of Jeffrey Epstein (attempted 2004 joint acquisition of Elite Model Management). Modeling agent for Melania Trump (1995). Partner/paramour Amanda Ungaro (from 2008). Father of Giovanni Zampolli. Long-time friend of Claudio Lotito (Italian football owner). Board member of TerraMar Project (Ghislaine Maxwell's charity). Co-Chairman of Prudential Douglas Elliman brokerage.

Zampolli partnered with Ghislaine Maxwell on Sustainable Oceans Alliance (2013), linked to Maxwell's TerraMar Project. In 2004, Epstein and Zampolli jointly attempted to purchase Elite Model Management (failed). In 2011 email from Epstein files, Epstein warned an Emirati businessman that 'zampoli is trouble'. Amanda Ungaro (Zampolli's partner from 2008) had earlier arrived in US on Epstein's plane at age 17 via agent Jean-Luc Brunel.

Zampolli and Jeffrey Epstein jointly bid to acquire Elite Model Management at public auction in 2004, with Epstein providing financial backing. Bid was unsuccessful. Epstein also patronized ID Model Management. In a 2011 email, Epstein warned an Emirati businessman that 'zampoli [sic] is trouble'.

Zampolli was Director of International Development at Trump Organization (2004-2006), overlapping with Felix Sater role as Senior Advisor to Trump Organization via Bayrock Group, which operated from Trump Tower. Both sold Trump-branded properties during the same period.

Zampolli claims he brought the Cabrits Kempinski project to Dominica — dual role as diplomat and deal broker for CBI-funded resort

Zampolli became Minister-Counsellor for Dominica in 2011, then UN Ambassador Oct 2013. Range Developments (founded 2012 by Mohammed Asaria, Cambridge law grad, ex-HSBC/Lovells/Dubai) signed to build the Cabrits Resort & Spa Kempinski as the first CBI-approved real estate project. Zampolli claims credit for bringing the project to Dominica and signed profit participation agreement May 7 2015 for 5% of development profits. His wife Amanda Ungaro simultaneously received parallel appointment as UN Ambassador for Grenada (June 2014) from PM Keith Mitchell — and Range Developments has a second CBI hotel project (Six Senses La Sagesse) in Grenada. This creates a pattern: both Zampolli and his wife held ambassadorships in the same two Caribbean nations where Range Developments operated CBI resort projects.

LittleSis network shows Zampolli and Felix Sater share 3 nodes: Donald Trump, Trump Organization, Ivanka Trump — but no direct relationship recorded

LittleSis relationship analysis: Zampolli (entity 351728) has 19 relationships; Sater (entity 49948) has 31 relationships. Shared nodes: (1) Donald Trump (15108) — Zampolli is long-time friend and special envoy; Sater was senior advisor and business associate. (2) Trump Organization (102190) — Zampolli was Director of International Projects; Sater was Senior Advisor. (3) Ivanka Trump (85815) — Zampolli was co-host; Sater had unspecified relationship. No direct Zampolli-Sater relationship is recorded in LittleSis, but the Domus Arbiter lawsuit establishes a verified commercial link: Bayrock (Sater's company) contracted with Zampolli/Paramount for Trump SoHo unit sales in 2013.

Direct personnel flow between ID Models and Epstein-linked agencies: booker Wilbert Hill moved from ID Models to Brunel's Karin Models; Amanda Ungaro arrived on Epstein plane with Brunel in 2002 then joined Zampolli

Two documented personnel/people flows connect ID Models to Epstein's modeling network: (1) Wilbert Hill was ID Model Management's booker who moved to Jean-Luc Brunel's Karin Models, triggering an FBI investigation and civil suit over alleged computer record tampering costing ID Models ~$100K (EFTA00190081). (2) Amanda Ungaro arrived in the US in 2002 at age 16-17 on Epstein's plane with scout Jean-Luc Brunel, then met Zampolli at a Manhattan nightclub that same year. She became Zampolli's long-term partner, had a son with him, and both received UN ambassadorships (Zampolli for Dominica, Ungaro for Grenada). These are not evidence that Zampolli orchestrated trafficking, but they document overlapping personnel between his agency and Epstein/Brunel's operations.

Zampolli held DUAL Caribbean diplomatic roles: Grenada Tourism Ambassador (Aug 2012) AND Dominica UN Ambassador (Oct 2013) — covering both countries where Range Developments operated CBI-funded resort projects

Critical timeline: Zampolli was appointed Ambassador under Ministry of Tourism of Grenada by PM Keith Mitchell in August 2012, BEFORE his October 2013 appointment as Dominica UN Ambassador under PM Roosevelt Skerrit. His partner Amanda Ungaro was then appointed Grenada UN Ambassador by Mitchell in June 2014. The couple held diplomatic roles across BOTH nations simultaneously — Zampolli in Dominica (and previously Grenada Tourism), Ungaro in Grenada. Range Developments operated CBI projects in both countries: Cabrits Kempinski in Dominica (opened 2019, USD 195M from 800 CBI passports) and Six Senses La Sagesse in Grenada (USD 220K CBI investment per applicant). Zampolli had a 5 percent profit participation deal on the Dominica project (signed May 2015). This is a coordinated commercial structure using diplomatic appointments as access vehicles in both CBI jurisdictions.

Zampolli appointed US Special Envoy for Global Partnerships by Trump (March 2025)

In March 2025, President Trump appointed Paolo Zampolli as US Special Envoy for Global Partnerships. The role was not Senate-confirmed. Zampolli has no diplomatic background — his career centered on modeling (ID Models) and real estate. Trump cited Zampolli's 'extensive experience working with the United Nations, the Kennedy Center, and various International initiatives.' The appointment appears to be an informal presidential designation, likely classifying Zampolli as a Special Government Employee. No SF-278 financial disclosure has been publicly located. US Embassy press releases from Uzbekistan, Romania, and Oman confirm the official title in diplomatic contexts.

Shelton v. Elite Model Management dismissal (2005 NY Slip Op 25492): Zampolli and ID Model Management won dismissal on CPLR 3211(a)(7) failure to state a cause of action and 3211(a)(8) personal jurisdiction grounds via joint motion filed 11/25/2003 — NOT a settlement, NOT a sanction, NOT special treatment. The same motion dismissed numerous co-defendants; only Brunel/Karin/Metropolitan/Zeumer/Levaton continued because they 'had not settled and had not moved to dismiss.' The dismissal is legal/procedural, not favorable treatment indicating cooperator status

Named defendant in Domus Arbiter v. Bayrock Group LLC (Index No. 651970/2014, NY Supreme Court) — fraud in Trump SoHo broker commissions

Domus Arbiter Realty Corp. (CEO Giampiero Rispo) sued Bayrock Group LLC, Bayrock/Sapir Organization LLC, Bayrock/Zar Spring LLC, Paolo Zampolli, Paramount Realty Group of America Corp., Jay T. McGorty, and Douglas Elliman LLC. Plaintiff alleged that in January 2013, its agent registered clients with Trump SoHo (246 Spring St) sales office, showed the property, and made purchase offers. The sponsor defendants (Bayrock entities) then allegedly conspired with Zampolli and Elliman to divert those clients, offering a 6% commission (vs 4% standard) if Zampolli could sell units to plaintiff's clients. Clients ultimately purchased 14 units totaling $10,856,547, representing 50% of all Trump SoHo sales in first 10 months of 2013. Zampolli allegedly transferred all proceeds to his employer, Paramount Realty Group of America Corp. Case decided by J. Eileen Bransten, IAS Part 3, Commercial Division.

Domus Arbiter Realty Corp. v. Bayrock Group LLC (NYSCEF 651970/2014) confirms Zampolli's direct connection to Bayrock Group through litigation. Domus Arbiter is a Zampolli-linked entity; Bayrock is the Trump SoHo development partner co-founded by Felix Sater and Tevfik Arif with documented Russian/Kazakh money laundering connections. This case, represented by Albert Feinstein (Zampolli side) vs Dunnington Bartholow & Miller (Bayrock), was disposed before Justice Joel M. Cohen with last appearance 11/29/2023.

Zampolli named defendant in Domus Arbiter Realty Corp v. Bayrock Group LLC, Bayrock/Sapir Organization LLC, Bayrock/Zar Spring LLC, Paolo Zampolli, and The Paramount Realty Group of America Corp (NY County Sup Ct 651970/2014), filed Jun 27, 2014 — broker-commission fraud alleging conspiracy to divert 14 Trump SoHo units ($10.86M sale) via Amy Williamson of Douglas Elliman as straw agent

Older Zampolli NY civil matter: Douglas Elliman LLC v Paolo Zampolli et al, NY County Sup Ct 153120/2015 (Contract Non-Commercial, Disposed, filed Mar 31 2015) — Elliman sued Zampolli in 2015; combined with 2014 Domus Arbiter alleging straw-agent arrangement via Elliman, suggests significant 2013-2015 broker-fee disputes with Zampolli's primary employer

Douglas Elliman sued Zampolli (2015) for hiding approx $4M in commissions during dual-license arrangement

In April 2015, Douglas Elliman filed suit against Zampolli alleging he concealed approximately $4 million in real estate commissions during his dual-license tenure. Under a 2011 agreement, Zampolli maintained his Paramount Realty Group brokerage while holding an Elliman license, agreeing to transfer 30% of commissions for deals done under Elliman's name. Elliman claimed Zampolli accounted for no commissions whatsoever despite being one of the more successful high-end Manhattan residential agents. Zampolli allegedly directed clients to his personal email. Elliman demanded $1.2M (30% of $4M). Zampolli called it frivolous, arguing word-of-mouth referrals to his personal contacts were legitimately under his Paramount license. Notable transaction during period: brokered $35M Beekman Place townhouse for Qatari PM.

Zampolli acted as intermediary in Weinstein cover-up operation Oct 2017. One week after Weinstein's public downfall, Zampolli called Melissa Thompson (Weinstein victim) urging her to contact attorney Alex Spiro at Brafman & Associates, saying 'All of these girls are getting together and they are going to be represented by Brafman.' Zampolli also sent an email on Oct 13 2017 introducing Thompson to Spiro. Brafman was actually Weinstein's defense lawyer, not a victims' attorney — publicly announced weeks later. Zampolli contacted multiple women. This is documented in Thompson v. Weinstein RICO complaint filed June 2018 in Manhattan federal court.

Oct 2017 Weinstein scope expanded: Per Dulany v Miramax class action complaint (18-CV-4857, para 201), 'Weinstein and/or an attorney from Brafman sought the assistance of Ambassador Paolo Zampolli' — this is new detail that Zampolli was being DIRECTED BY Weinstein's side, not independently. He contacted 'at least three different victims' (plural), not just Thompson. Thompson had not spoken with Zampolli in 5 years before his sudden Oct 12-13 outreach

Ungaro v. Zampolli (350016/2018) had court appearance on 10/04/2018 — exactly 21 days before the Oct 25 2018 emails to Epstein naming Zampolli as 'killer' and accusing him of fabricating depositions. Second case (301822/2018) remains active with next appearance 04/27/2026. Both represented by Aronson Mayefsky & Sloan (Ungaro) vs Chemtob Moss Forman & Beyda / The Wallack Firm (Zampolli). Justice: Hon. Michael L. Katz.

Chemtob Moss Forman & Beyda LLP sued Zampolli Oct 25, 2018 for $89,280.95 unpaid matrimonial legal fees; served as his divorce counsel Mar-Sep 2018 and was relieved Sep 27, 2018 by Judge Katz

Sept-Oct 2018 matrimonial crisis timeline for Zampolli: Sep 7 final bill from counsel, Sep 17 counsel OSC to withdraw, Sep 27 Judge Katz granted withdrawal, Oct 2 order entered, Oct 25 CMFB fee lawsuit filed — same day as Ungaro-Epstein Oct 25 emails

Nov 23 2020: Zampolli (paolo@zampolli.com) is addressee on privileged attorney communication from Katherine Friess (Giuliani/Kerik lawyer), Subject 'Re: ATTORNEY-CLIENT PRIVILEGED COMMUNICATION,' with Rudy Giuliani and Bernie Kerik CC'd. Appears twice in privilege log (Freeman v Giuliani, docs 79-5 and 87-2), claimed as 'ACP: Confidential communication discussing legal strategy.' Places Zampolli inside Giuliani election-fraud/Jan 6 legal team

June 2025: Zampolli ALSO contacted Corey Lewandowski (senior adviser to DHS Secretary Kristi Noem) in parallel to ICE #2 Venturella during Amanda Ungaro detention push. Lewandowski reportedly did not respond; said he had never heard of Zampolli. This establishes Zampolli reached out to MULTIPLE DHS officials simultaneously, not just Venturella

June 2025 coordinated family court intervention: While Amanda Ungaro was in ICE detention, 'the day after her arrest, Paolo and his attorneys began filing motions aggressively to undo the work that Amanda had put in to be given legal custody of their child' — coordinated NY Supreme Court filings parallel to the ICE detention. This is the 8th instance documented and shows synchronization between law-enforcement contact and civil court exploitation

Ungaro v Zampolli 301822/2018 had 3 successive motion rounds after Sep 2024 e-file conversion: Motion 013 (Oct 15 2024 - Feb 14 2025, resolved by DECISION+ORDER entered Feb 14 2025, Notice of Entry Feb 18 2025, Exhibits A-U); Motion 014 (Jun 17 2025, OSC by Hosseinzadeh w/ Exhibits A-J); Motion 015 (Jun 23 2025, OSC by Wallack w/ Exhibits A-G, followed by Cardi's affirmations Jul 9-16 2025, Exhibits 1-5). Cross-filings suggest mutual OSC warfare circa Jun-Jul 2025

NEW NYSCEF case: Tania Soares Felizardo v. Paolo Zampolli AND Amanda Ungaro (Index 161870/2025, NY County Supreme Court). Plenary Action — Custody and Visitation. Third party (Felizardo) sued both Zampolli and Ungaro jointly. Judge Michael L. Katz. Filed Sept 5 2025 via Order to Show Cause with Anita Rojas Carroll as petitioner's attorney. Voluntarily discontinued Oct 16 2025. Decision + Order on Motion Oct 20 2025. Status: Disposed. Filed ~11 weeks after Amanda Ungaro's June 18 2025 Aventura arrest during ICE detention window.

Zampolli denied orchestration: stated 'I asked David what was going on because I did not know the process' — claims contact was informational only. DHS stated: 'Any suggestion that she was arrested and removed for political reasons or favors is FALSE.' But MercoPress/NYT reported Zampolli told Venturella 'her immigration detention would help him gain custody of their child'

CourtListener shows: (1) Zampolli v Metropolitan Interna (SDNY 1:97-cv-07946, filed 1997-10-27, dismissed 1997-11-04) - securities fraud suit against Metropolitan International Management LLC and Metropolitan Model Agency USA Inc, dismissed for lack of subject matter jurisdiction. Attorney Raymond Dowd of Dunnington Bartholow. (2) Vermeer v Dennis Direct Mail (SDNY 1:02-cv-00241, 2002) - ID Model Management Inc named as party in personal injury case. (3) Zampolli named as party in Beatty v Trump (DDC 1:25-cv-04480, filed 2025-12-22) re Kennedy Center board.

Zampolli and ID Model Management were co-defendants in Shelton v. Elite Model Management (2005 NY Slip Op 25492), a class action alleging modeling industry labor exploitation. Zampolli's motion to dismiss was granted. Jean-Luc Brunel and Karin Models LLC were also defendants but did NOT join the dismissal motion — their cases continued.

CourtListener shows 5 cases involving Zampolli: (1) Zampolli v Metropolitan Interna (SDNY 1997, securities fraud/diversity, filed 1997-10-27 terminated 1997-11-04 - very short); (2-4) Three related Dennis Publishing model cases (SDNY 2002, civil rights/personal injury) where Zampolli gave declaration as ID Model Management head; (5) Beatty v Trump (DDC 2025, Kennedy Center board lawsuit) where Zampolli is a named defendant trustee.

Zampolli's personal Hungarian connection predates his diplomatic role by 30 years. He moved to New York circa 1994 with Edit Molnar, a Hungarian model from Buda, and they lived together until at least 1996. Molnar was a close friend of Melania Knauss (later Trump). Both worked for Zampolli's modeling agency. This gives Zampolli longstanding personal ties to Hungary and possibly a personal network there beyond official channels.

Melania Knauss obtained EB-1 extraordinary ability green card in March 2001 — one of only 5 Slovenians that year; basis questioned by immigration attorneys

Melania filed for EB-1A in 2000, approved March 2001. EB-1A is self-petitioned (no employer sponsor required). Her portfolio at time of filing: British GQ cover, Sports Illustrated swimsuit, Camel cigarettes Times Square billboard, European runway work. Immigration attorneys have questioned whether this met the extraordinary ability standard — she was 'a relative unknown in the modelling world' at filing time and 'had not excelled in any niche area.' Only 5 Slovenian nationals received EB-1 that year. Immigration attorney Michael J. Wildes handled her case. The EB-1 path bypassed the normal employer-sponsored green card process, removing dependency on any modeling agency.

Zampolli's own X/Twitter statement confirms sequence: 'Before that [Dominica], I was Special Representative for St. Kitts, and then Ambassador-at-Large of Grenada.' Dominica Minister-Counsellor documented as 2011 (Nov per WantedSA). Grenada Tourism Ministry appointment documented as August 2012. St. Kitts 'Special Representative' title predates both — likely 2010 or earlier. The Park Hyatt/Range Developments agreement was signed July 10, 2012 — AFTER Zampolli's stated St. Kitts appointment but temporally close to it.

IREO/Exemplar-Zero timeline narrows St. Kitts appointment window. Oct 11, 2010: Zampolli titled 'UN Brazil Association Ambassador at Large' at IREO event — NOT yet titled St. Kitts Special Representative. Sequence: IREO Executive Director (2007-2008) -> 'UN Brazil Association Ambassador at Large' (2010) -> St. Kitts Special Representative (between late 2010 and mid-2011) -> Dominica Minister-Counsellor (Nov 2011) -> Grenada Tourism Ministry Ambassador (Aug 2012) -> Dominica UN Ambassador (Oct 2013). St. Kitts appointment likely occurred in late 2010 or early 2011, under PM Denzil Douglas.

TEMPORAL PATTERN: Epstein 'trouble' warning (Feb 2011) coincides exactly with Zampolli's pivot from business to Caribbean diplomacy — ID Models dissolved 2009, Dominica appointment ~2011

Epstein emailed Sultan Ahmed Bin Sulayem in Feb 2011: 'Be careful, zampoli is trouble. Lots.' (DOJ EFTA02536145). This warning coincides precisely with the period when Zampolli was transitioning from defunct ID Models (dissolved 2009) to diplomatic career: (1) 2009: ID Model Management dissolved; (2) ~2011: Appointed Minister-Counsellor to Dominica UN Mission; (3) Aug 2012: Appointed Grenada Tourism Ambassador. The 2-year gap between ID Models dissolution and Dominica appointment is also a significant silence period. Epsteins warning suggests he had intelligence about Zampollis activities or reputation during this transition. The Vanity Fair 'Talented Mr. Epstein' article also published Mar 2011.

WantedSA reports Zampolli allegedly offered USD 250,000 cash to Dominica UN Ambassador Vince Henderson in 2011 for diplomatic appointment and passport. Article dates Dominica Minister-Counsellor appointment to November 2011. Grenada appointment as 'Minister of Tourism' dated August 2012. Grenada UN Ambassador reportedly declined a similar cash offer from Zampolli.

PassBlue (2017): Zampolli 'is responsible for bringing the Cabrits Resort Kempinski to Dominica.' This confirms his self-described role as deal-broker between Caribbean governments and CBI developers. His 5% profit-sharing agreement with Range Developments (signed May 7, 2015) was explicitly a finder's/broker's fee — he claims approximately USD 7.5M to 9.75M. Pattern: diplomatic credentialing preceded deal-brokering in Dominica, and by Zampolli's own account, St. Kitts was his FIRST Caribbean posting.

Hungary's original residency bond program (2013-2017) was run through 8 offshore intermediaries registered in Cayman Islands, BVI, Hong Kong, Singapore, Cyprus, Liechtenstein. OCCRP investigation found they collected at least USD 600M in fees. Program architect was Antal Rogan, later head of Orban's cabinet. One intermediary, Arton Capital Hungary, is also a major authorized agent for Caribbean CBI programs including Dominica -- the same country where Zampolli held UN Ambassador and Oceans Ambassador posts. This creates a structural parallel between Hungarian and Caribbean golden visa ecosystems.

Zampolli alleged under oath (July 2019) that Range Developments principals Asaria and Shehada 'are known to sell passports to Iran, Yemen, and Sudan to circumvent U.S. Treasury sanctions and United Nations Security Council sanctions' — extraordinary admission implicating the Dominica CBI program Zampolli personally marketed

FBI proffer EFTA00159321 shows Zampolli is DISCUSSED by cooperating witness, not the cooperator: 07/12/2019 proffer interview at West Palm Beach with Polish former Epstein assistant (2005-2006) who describes being 'put in contact with an agent named PAOLO ZEMPOLI who worked with ID Models' and 'had an affair with the agent' while ZEMPOLI 'was trying to buy Elite Models with EPSTEIN'

TEMPORAL PATTERN: 4.2-year silence period (Dec 2020 to Feb 2025) — longest gap in Zampolli timeline, coincides with Trump out of office and post-Epstein scrutiny era

Between Dec 22 2020 (Kennedy Center appointment) and Feb 21 2025 (StartMag defense lobbying report), there are 1522 days with ZERO Zampolli events in the timeline. This is the longest documented gap. During this period: (1) Jan 2021: Trump leaves office; (2) Multiple Epstein document unsealing waves (2021-2024); (3) Maxwell trial and conviction (2021-2022); (4) Range Developments ICC arbitration continuing; (5) Congressional scrutiny of modeling industry visa practices. The silence may reflect: (a) genuine inactivity while patron Trump was out of power; (b) deliberate low-profile during Epstein/Maxwell fallout period; (c) undocumented private activities not captured by public records. The abrupt reactivation coinciding with Trumps second inauguration (Jan 20 2025) strongly suggests Zampollis public career trajectory is patron-dependent.

Hungary relaunched its golden visa program in 2024 as the Guest Investor Residence permit (EUR 250K investment fund or EUR 1M university donation for 10-year residence). This happened during the same period Zampolli was making official sports diplomacy visits to Budapest. No direct evidence Zampolli is involved in the relaunched program, but the timing of his Hungary engagement coincides with the program restart.

TEMPORAL PATTERN: Zampolli claimed Special Envoy title and pushed defense contracts in Italian media 7-8 days BEFORE official appointment (Feb 21-22 vs Mar 1, 2025)

Zampolli operated under claimed authority before receiving it: (1) Feb 21 2025: StartMag reports Zampolli pushing Lockheed Martin/GCAP defense dossiers in Italy; (2) Feb 22 2025: Zampolli claims Special Envoy to Italy title in Il Giornale interview; (3) Mar 1 2025: Official appointment as US Special Envoy for Global Partnerships; (4) Mar 3 2025: Defense News reports Zampolli floating transatlantic warplane program; (5) Italian FM Tajani publicly denied knowing Zampolli when asked about claimed Italy role. This pattern of claiming authority before appointment and operating in spaces (defense procurement, Italian diplomacy) beyond the actual role scope suggests Zampolli uses titles as access credentials rather than operating within formal boundaries.

Zampolli contacted ICE official David Venturella around June 15 2025 stating Ungaro was in country illegally and that immigration detention would help him gain custody — Venturella then called ICE Miami field office noting case was 'important to someone close to the White House' and arranged agents to pick up Ungaro before bail release

PATTERN: Zampolli used DHS/immigration contacts against Ungaro in BOTH 2018 and 2025 — in 2018 he admitted having her name flagged through Homeland Security to prevent her from leaving the US with their child; in 2025 he contacted Venturella to have her detained by ICE

ORCHESTRATION ASSESSMENT: Zampolli did NOT initiate the criminal investigation (CrimeStoppers tip April 2024, sting Jan 2025, warrants March 2025 — all predating his contact). But he DID opportunistically weaponize the arrest by contacting Venturella to ensure ICE detained Ungaro before bail release, explicitly linking it to custody. The arrest was independent; the ICE hold was orchestrated.

TEMPORAL PATTERN: Zampolli geopolitical escalation spiral — 8 months from Uzbekistan minerals (Aug 2025) to Iran peace talks (Apr 2026), touching Russia, Oman, and defense industry

Post-appointment as Special Envoy, Zampolli engaged in rapid geographic expansion with security implications: (1) Aug 28 2025: Critical minerals negotiations in Uzbekistan; (2) Jan 15 2026: Meets Russian Sports Minister Degtyarev at OCA in Tashkent; (3) Feb 5 2026: Visits Oman as Special Envoy; (4) Feb 21 2026: NYT reports Zampolli advocating Russia/Belarus Paralympic return; (5) Feb 28 2026: US-Iran military strikes begin (Operation Epic Fury); (6) Apr 11 2026: Present at US-Iran peace talks in Islamabad. Central Asia (minerals) to Gulf (Oman) to Russia (sports diplomacy) to Iran peace table — a former model agent with no known diplomatic training or intelligence community background is operating in spaces traditionally reserved for career diplomats or intelligence officers. The minerals-to-defense pipeline (Uzbekistan -> GCAP fighter program -> Iran talks) suggests Zampollis envoy role may be a vehicle for resource-access diplomacy rather than conventional partnership building.

Zampolli made an advance trip to Budapest March 17-19, 2026 as Special Envoy for Global Partnerships. Per US Embassy Hungary press release, he met Daniel Gyurta, Director of Sports Diplomacy at Hungary MFA, plus the Minister of Culture and Innovation.

AP photo (Reuters/Jonathan Ernst) confirms Zampolli walked the red carpet at Budapest Ferenc Liszt International Airport on April 7, 2026 alongside VP JD Vance and Second Lady Usha Vance. Caption identifies him as 'a friend of President Donald Trump and Trump's envoy for global partnerships.' He was part of the official arrival party, not just peripherally present.

The April 7 2026 Budapest event was the 'Day of Friendship' rally at MTK Sportpark, attended by approx 5,000 people. Vance gave a 40-minute speech calling Orban 'one of the only true statesmen in Europe'; Trump called in live via speakerphone. This was the first time a sitting US VP addressed a campaign-style rally supporting a foreign leader on the eve of that country's election. Orban lost the April 12 election decisively to Peter Magyar's Tisza party (138-55 seats).

Zampolli swore (July 2019) he is 'United Nations Ambassador for the Commonwealth of Dominica... a United States citizen and a New York resident and has resided in the United States for 25 years. His primary business is real estate developments.' — 25 years would date NY residency to ~1994

Director of International Projects at Trump Organization Dec 2004 to approx 2006 (sold apartments at Trump Park Avenue). Founded Paramount Realty Group of America Corp after leaving Trump Org. Also CEO of Fashion Investment Group (FIG). Founded Green Inc in 2009. Owner of ID Model Management, ID Bikini Models, and Metropolitan Models Group.

Zampolli appointed UN Ambassador and Ambassador for Oceans and Seas for the COMMONWEALTH OF DOMINICA (not Dominican Republic) in October 2013 by PM Roosevelt Skerrit. Previously Minister-Counsellor to Dominica UN Mission from 2011. Dominica is a small Caribbean island nation (pop ~72,000), distinct from Dominican Republic.

NY DOS confirms ID Model Management, Inc. (DOS ID 2202863) was incorporated in New York on 1997-11-26. Status: Inactive. This is Zampolli's modeling agency through which he represented Melania Knauss (later Trump).

Zampolli appointed Special Envoy for Global Partnerships by President Trump in March 2025. Previously represented himself as Special Envoy to Italy (unofficial). Named to Kennedy Center board of trustees in 2020. Served as UN Ambassador for Dominica since October 2013 (appointed by PM Roosevelt Skerrit). Founded Green Inc. in 2009. Served as Executive Director of IREO (UN IGO) Sept 2007-Nov 2008.

Zampolli's residential address as of Oct 2018: 119 East 17th Street, New York, NY 10003 (pleaded as his residence)

Range Developments is located at 654 Madison Ave 9th Fl NYC 10065 per Zampolli's petition; Kempinski Hotels operates from 551 Madison Ave 4th Fl NYC 10022; Xavier Destribats oversees Kempinski Americas; Zampolli's attorney Hantman & Associates at 1120 Ave of Americas 4th Fl NYC 10036

Zampolli corporate entities share two address clusters: (1) 137 Varick Street, Ste 401, NY 10013 — ID Model Management CEO address and ID Models.com SOP address; (2) 277 Broadway, Ste 1310, NY 10007 — Dowd & Marotta law firm serving as SOP agent for both ID Model Management and The Zampolli Group Inc. Current Paramount Realty address is 119 East 17th Street, NY 10003. Paramount Group Realty of NY LLC at 315 Madison Avenue Ste 4016 (Ido Shalikar).

May 7, 2015 Range Capital Partners (Dominica) agreement is governed by England & Wales law, with ICC London arbitration; counterparty signatories are Munaf Ali and Mohammed Asaria; Zampolli acknowledged on May 7, 2015 at 119 E 17th St — documents attached as Exhibit A show letter sent to 119 E 17th Street address

FBI proffer confirms Zampolli-Epstein joint bid for Elite Model Management

FBI FD-302 document (EFTA00159321), dated 11/26/2019, records a proffer interview conducted 07/12/2019 with a former Epstein assistant/model. The witness states under penalty of perjury: 'ZEMPOLI was trying to buy Elite Models with EPSTEIN.' The same document states 'EPSTEIN introduced MELANIA TRUMP to DONALD TRUMP.' The witness worked for Epstein ~2005-2006, was formerly a model who was put in contact with 'an agent named PAOLO ZEMPOLI who worked with ID Models.' The witness lived in a model apartment on Varick Street. This is primary source — sworn FBI testimony under a proffer agreement, with false statements carrying up to 5 years imprisonment.

FBI witness statement: former ID Models model described Zampolli as 'sleazy', corroborates Varick St model apartment

FBI FD-302 (EFTA00173834) interviews a model born ~1984 who signed with ID Models at age 18 (approx. 2002). Witness states: she lived in a model apartment on Varick Street with two other girls, ZAMPOLLI was 'sleazy' and dated models, ZAMPOLLI made her get a short haircut and then let her go. Around 2004 she left modeling and was working at a coffee shop in Union Square when recruited by an Epstein associate. This corroborates the EFTA00159321 proffer which also places the proffer witness at a model apartment on Varick Street and at ID Models.

Zampolli blog confirmed by Brunel: Brunel email Aug 18, 2010 (EFTA02407009) explicitly references 'blog done by Zampolli years ago about FBI investigating MC2 for bookers leaving.' This blog (no longer available online) publicized FBI scrutiny of Brunel's MC2 agency over poaching ID Models bookers. Blog cannot be located on Wayback Machine or current web. Brunel was furious about it, calling it 'malicious fabrication' in same email where he also complains about Maritza Vasquez (ex-accountant convicted of grand theft) publishing damaging articles and admits 'Jeffrey Epstein is my friend.'

FBI FD-302 proffer (EFTA00159321): unnamed witness stated 'EPSTEIN introduced MELANIA TRUMP to DONALD TRUMP' — but witness worked for Epstein 2005-2006, seven years after 1998 event, so claim is necessarily hearsay, not firsthand

FD-302 proffer statement (EFTA00159321/EFTA00090773): Unnamed Polish-born former model/Epstein assistant (worked 2005-2006) stated under proffer agreement to FBI on 07/12/2019: 'EPSTEIN introduced MELANIA TRUMP to DONALD TRUMP.' Statement appears in a series about Zampolli: '[redacted] put [redacted] in contact with agent PAOLO ZEMPOLI who worked with ID Models. ZEMPOLI was trying to buy Elite Models with EPSTEIN. EPSTEIN introduced MELANIA TRUMP to DONALD TRUMP. EPSTEIN was visiting ZEMPOLI at the agency when there were casting auditions.' The witness began working for Epstein circa 2005. The Trump-Melania introduction occurred September 1998. Therefore the witness could not have been present and is relaying something she was told — likely by Epstein himself.

Melania Trump White House statement (April 9, 2026): 'Epstein did not introduce me to Donald Trump. I met my husband by chance at a New York City party in 1998. The first time I crossed paths with Epstein was in the year 2000.' Also called for Congressional hearings for Epstein survivors.

First Lady Melania Trump issued a public statement from the White House on April 9, 2026, directly addressing the Epstein introduction claim. She stated: 'Epstein did not introduce me to Donald Trump. I met my husband, by chance, at a New York City party in 1998. This initial encounter with my husband is documented in detail in my book, MELANIA. The first time I crossed paths with Epstein was in the year 2000, at an event Donald and I attended together.' She also stated she never flew on Epstein's plane or visited his island. The statement was reportedly driven by Melania's monthslong frustration with press coverage, made with minimal advance notice to her husband. Trump later admitted he did not 'recommend' the statement.

NYSCEF reveals 11 NY Supreme Court civil cases involving Zampolli (1997-2019). Key cases: two 1997 suits vs Metropolitan International (model agency); 2011 Ruiz v. Zampolli (employment); 2014 Domus Arbiter Realty v. Bayrock Group LLC (Zampolli party); 2015 Douglas Elliman v. Zampolli; two 2018 Ungaro v. Zampolli custody cases (301822/2018 still active, 350016/2018 disposed 10/04/2018); 2019 Zampolli v. Range Developments (Dominica hotel).

Zampolli's co-worker at 'actual place of business' in October 2014 was Adrienne Braun; service of process made via Braun on Oct 6 2014

Born March 5, 1970, in Milan, Italy. Relocated to NYC in 1990s. Founded ID Model Management mid-1990s. Met Melania Knauss on scouting trip to Milan 1995, sponsored her H-1B visa 1996, introduced her to Trump at September 1998 party at Kit Kat Club.

Zampolli served as Director of International Development for the Trump Organization starting Dec 2004, selling apartments at Trump Park Avenue. Left to found Paramount Group using ID Models talent as real estate brokers.

Appointed UN Ambassador and Ambassador for Oceans and Seas for Commonwealth of Dominica by PM Roosevelt Skerrit in Oct 2013 (Minister-Counsellor from 2011). Connected to Dominica via Cabrits Resort Kempinski development under Dominica's Citizenship by Investment program. In Dec 2020, Trump appointed him to JFK Center for Performing Arts board. In March 2025, named US Special Representative for Global Partnerships.

Modeling industry visa abuse was systemic in 1990s-2000s NYC: models entered on tourist visas, worked illegally, agencies avoided H-1B process due to annual cap and 6-month processing delay

Multiple sources document systemic visa abuse in NYC modeling: (1) Models instructed to enter on tourist visas, dress down, ship portfolios separately to avoid customs. (2) H-1B applications open once per year with 6+ month processing, creating structural incentive to bypass. (3) Models without work authorization subject to wage theft — agencies kept earnings since models had no legal recourse. (4) Trump Model Management documented bringing ~30 foreign models via H-1B since 2008, but model Alexia Palmer alleged earning only a few thousand over 3 years vs promised $200K+. (5) Rachel Blais (former Trump Model Management model) stated she never heard of any model being deported or denied entry despite widespread violations. (6) Non-disclosure agreements prevented models from speaking out.

GCAP program overview: B+ sixth-gen fighter jointly developed by UK, Italy, Japan — Edgewing JV formed June 2025

The Global Combat Air Programme (GCAP) is a trilateral initiative by UK, Italy, and Japan to develop a sixth-generation stealth fighter (informally 'Tempest') with target IOC in mid-2030s and service life beyond 2070. Industrial partners: BAE Systems (UK), Leonardo (Italy), and Japan Aircraft Industrial Enhancement Co. formed joint venture Edgewing in June 2025, each holding 33.3%. First international contract: 686M GBP awarded by GIGO (GCAP International Government Organization) to Edgewing in April 2026. Electronics consortium G2E (Mitsubishi Electric, ELT Group, Leonardo/Leonardo UK) formed Sep 2025. Saudi Arabia has expressed interest in joining but Japan opposed, citing export policy and tech security concerns. The US has its own competing sixth-gen program (F-47/NGAD by Boeing). US entry into GCAP as Zampolli proposed would fundamentally restructure the existing 33/33/33 arrangement and could position Lockheed Martin to dominate a program where it currently has zero share.

Zampolli held three Caribbean diplomatic roles in sequence: St. Kitts Special Representative, Grenada Ambassador-at-Large, Dominica UN Ambassador (2013-~2023)

Zampolli disclosed his full Caribbean diplomatic timeline on X/Twitter: (1) Special Representative for St. Kitts (dates unclear, pre-2012), (2) Ambassador-at-Large of Grenada (from Aug 2012 per Wikipedia), (3) Ambassador and Permanent Representative of Dominica to the UN (Oct 2013 to approximately 2023). His partner Amanda Ungaro was separately appointed Grenada UN Ambassador in June 2014 by PM Keith Mitchell. This pattern -- a couple accumulating diplomatic titles from multiple small Caribbean CBI nations -- is unusual and suggests the appointments were related to CBI deal-making rather than traditional diplomatic qualifications.

Zampolli's WordPress bio describes transition: Trump Organization Director of International Development (2004-2006), then Paramount Group Co-Chairman (2006-present), then I.R.E.O. Director/Special Advisor on Climate Change (Sept 2007-Nov 2008). No diplomatic titles claimed on this bio page. The I.R.E.O. (International Renewable Energy Organization) role in 2007-2008 preceded his Caribbean appointments and matches the 2008 UN event hosting pattern. This suggests Zampolli was cultivating UN/diplomatic relationships from ~2007, with St. Kitts Special Representative likely obtained ~2009-2010 during the transition from I.R.E.O. to Caribbean diplomacy.

NEGATIVE RESULT: The three custody/matrimonial cases in NY Supreme Court (Ungaro 301822/2018 and 350016/2018; Felizardo 161870/2025) are classified as Matrimonial-Contested or Plenary Custody and expose NO downloadable document URLs to the public despite showing complete metadata. Case 350016/2018 does not appear in NYSCEF party-search (likely purged post-disposition in 2018). Deposition transcripts, sworn affirmations, child support calculations, and financial disclosures are sealed under DRL §235 and NY CPLR matrimonial privacy rules. Hypotheses 1 (Oct 2018 email authorship) and 2 (Zampolli sworn statements about law enforcement) CANNOT be resolved via NYSCEF public access — would require court-intervention motion, subpoena, or party-to-litigation access

No FARA registrations found for Zampolli despite serving as UN Ambassador for Dominica and current US Special Representative for Global Partnerships. No lobbying disclosure filings found. No OpenSanctions records. Not on any sanctions lists. FARA search returned empty registrants and foreign_principals arrays.

DOL H-1B disclosure data (2013-2025) contains zero LCA filings for ID Model Management or Metropolitan Models — pre-dates electronic disclosure era

Searched h1bdata.info (4.8M+ LCA records Oct 2013-Sept 2025) for ID Model Management, Metropolitan Models, and Metropolitan International — zero results for all three. ID Model Management Inc (NY DOS #2202863) was dissolved in 2009, before the DOL electronic disclosure era. The H-1B that Zampolli obtained for Melania in 1996 predates public LCA databases by nearly two decades. Only 2 NY modeling agencies appear in modern H-1B data: DNA Model Management LLC (7 filings) and The Society Model Management Inc (2 filings, $200K salary). Trump Model Management also returned zero results despite documented H-1B sponsorship of ~30 foreign models.

ID Model Management not in current NY DOL Model Management Company Registry (47 active agencies as of April 2026); The Identity Models Inc is active but appears unrelated

NY DOL Model Management Company Registry (data.ny.gov) shows 47 currently active model management companies in New York. ID Model Management is absent — consistent with NY DOS dissolution of entity #2202863 in 2009. The Identity Models Inc (cert issued 2026-01-26) is the only agency with a similar name but appears to be a separate entity. The Society Management (SCTY Management LLC), one of only two NY agencies that appear in federal H-1B LCA data, is active in the registry.

No public scrutiny found of Zampolli's presence at Iran talks or his CBI-Iran conflict of interest. Congressional attention on Zampolli in April 2026 focused entirely on Epstein/Melania introduction and Amanda Ungaro deportation — not his diplomatic activities. Emptywheel, Unlimited Hangout, and other investigative outlets have profiled Zampolli but none have connected his CBI role to his Iran diplomacy presence.

NEGATIVE RESULT: No FARA registration found for Zampolli related to St. Kitts and Nevis. FARA database shows 7 registrations for St. Kitts entities (tourism boards, government), none involving Zampolli or any Zampolli-linked entity. Consistent with pattern: Zampolli holds Caribbean diplomatic titles without US foreign agent registration, same as his Dominica and Grenada roles.

NEGATIVE RESULTS from dedicated FBI cooperator search: (1) FBI FOIA Vault — no dedicated file on Zampolli, ID Models, or Brunel accessible via FOIA reading room; (2) FINRA whistleblower/advisor database — 0 matches for Paolo Zampolli (only similar-name individuals); (3) SEC enforcement actions — 0 matches; (4) OpenSanctions PEP/sanctions database — 0 matches; (5) FARA registered agents — 0 matches (no foreign agent registration); (6) Lobbying disclosures — 0 matches; (7) SAM.gov exclusions — not accessible (API key issue); (8) CourtListener federal dockets — Zampolli appears as plaintiff in 1997 case Zampolli v. Metropolitan International (1:97-cv-07946 SDNY) and as non-party in 2025 Beatty v. Trump DC case; NO federal criminal case, NO SDNY sealed cooperator docket; (9) DOJ Vol 11 'zampolli cooperator' and 'zampolli informant' — 0 results; (10) Unified Epstein DB — 0 results for Zampolli; (11) FBI files parquet (8,150 FBI docs Textract OCR) — 0 matches for zampolli/zempoli/cooperator/confidential source/ID Model/Wilbert

NEGATIVE RESULT (party-search scope confirmation): NYSCEF party search 'Paolo Zampolli' returns 6 post-~2014 electronic cases (Douglas Elliman v Zampolli 153120/2015, Zampolli v Range Developments 156698/2019, Felizardo v Zampolli/Ungaro 161870/2025, Ungaro v Zampolli 301822/2018, Domus Arbiter v Bayrock 651970/2014, Chemtob Moss v Zampolli 655303/2018) — fewer than the 11 cases CourtListener/prior analysis identified (which includes pre-e-filing 1997-2013 cases not loaded to NYSCEF). NYSCEF guest search is confirmed to have NO mechanism to search non-party mentions (witness, deponent, affiant, correspondent named in exhibits). The operational-fixer pattern expansion — where Zampolli appears as a contact/intermediary WITHIN someone else's case — CANNOT be tested via NYSCEF guest-search alone. Would require either PACER-style full-text indexing (not available on NYSCEF) or individual case-by-case document review. Infrastructure gap to note.