p. 1COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. INTERVIEW OF: JAMES EDWARD "JES" STALEY Thursday, July 24, 2026 Washington, D.C. The interview in the above matter was held in room 2154, Rayburn House Office Building, commencing at 10:06 a.m. Present: Representatives Comer, Luna, Garcia, Ansari, Walkinshaw, Subramanyam, Krishnamoorthi, Stansbury, and Randall. Appearances: For the COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM: DANIEL ASHWORTH, GENERAL COUNSEL ALEX BOYD, STAFF ASSISTANT BRITTANY BRIGNAC, SENIOR COUNSEL EMMANUEL CARACHEO, UNDERGRADUATE FELLOW HANNAH CATHEY, PROFESSIONAL STAFF MEMBER MALLORY COGAR, CHIEF CLERK AND DEPUTY DIRECTOR OF OPERATIONS JESSICA COLLINS, COMMUNICATIONS DIRECTOR JACK EMMER, CHIEF COUNSEL FOR INVESTIGATIONS EMILY FEYERABEND, COUNSEL , INTERN BILLY GRANT, DEPUTY CHIEF COUNSEL FOR INVESTIGATIONS WILL HARNICE, PROFESSIONAL STAFF MEMBER , INTERN KYLIE HINOJOSA, PROFESSIONAL STAFF MEMBER AND ADMINISTRATIVE CLERK MARK MARIN, STAFF DIRECTOR , INTERN , INTERN LISA MORTIER, SENIOR ADVISOR , INTERN PETER SPECTRE, DEPUTY DIRECTOR FOR OVERSIGHT ELLISON TOLAN, COUNSEL ASHLEE VINYARD, DEPUTY STAFF DIRECTOR , INTERN LAUREN WILLIAMS, LEGISLATIVE AIDE , INTERN COLEMAN WRIGHT, STAFF ASSISTANT , MINORITY DEPUTY PRESS SECRETARY , MINORITY STAFF DIRECTOR , MINORITY DEPUTY COMMUNICATIONS DIRECTOR , MINORITY FELLOW , MINORITY COMMUNICATIONS DIRECTOR , MINORITY RESEARCH ASSISTANT , MINORITY RESEARCH ANALYST , MINORITY INTERN , MINORITY PRESS SECRETARY , MINORITY SENIOR COUNSEL , MINORITY INTERN , MINORITY INTERN , MINORITY SENIOR COUNSEL , MINORITY OPERATIONS SPECIALIST , MINORITY RAPID RESPONSE STRATEGIST , MINORITY DEPUTY CHIEF COUNSEL , MINORITY INTERN , MINORITY FELLOW , MINORITY SENIOR ADVISOR , MINORITY CHIEF COUNSEL For JAMES EDWARD STALEY: BRENDAN V. SULLIVAN, JR., WILLIAMS & CONNOLY LLP KATHLEEN HARRIS, ARNOLD & PALMER
p. 5Ms. Brignac.We will go on the record. This is a transcribed interview of Mr. James Edward Staley conducted by the House Committee on Oversight and Government Reform under the authority granted to it pursuant to House Rule X. Accordingly, House Rule X grants the Committee broad jurisdiction for the Committee to conduct investigations of any matter at any time. This interview was requested by Chairman James Comer as part of the Committee's investigation into the circumstances and subsequent investigations into the crimes of Jeffrey Epstein and Ghislaine Maxwell; the operation of sex trafficking rings and ways for the Federal Government to effectively combat them; the ways in which Mr. Epstein and Ms. Maxwell sought to curry favor and exercise influence to protect their illegal activities; and potential violations of ethics rules related to elected officials. Can the witness please state his name and spell his last name for the record?
p. 5Mr. Staley.James Edward Staley, S-t-a-l-e-y.
p. 5Ms. Brignac.Thank you. I want to thank Mr. Staley for appearing here today. My name is Brittany Brignac. I am senior counsel for Chairman James Comer. Under the Committee on Oversight and Government Reform's rules, you are allowed to have counsel present to advise you during this interview. Do you have counsel representing you in a personal capacity present with you today?
p. 5Mr. Staley.I do.
p. 5Ms. Brignac.Will all counsels please identify themselves for the record?
p. 5Mr. Sullivan.Brendan Sullivan, Williams & Connolly, Washington, D.C.
p. 5Ms. Harris.Kathleen Harris, Arnold & Porter.
p. 5Ms. Brignac.Thank you. For the record, starting with the majority staff, can the additional staff members please introduce themselves with their name, title, and affiliation?
p. 6Mr. Grant.Billy Grant, deputy chief counsel for investigations for Chairman Comer.
p. 6Mr. Emmer.Jack Emmer, chief counsel for investigations for Chairman Comer.
p. 6Mr. Ashworth.Daniel Ashworth, general counsel for Chairman James Comer.
p. 6Ms. Tolan.Ellison Tolan, senior counsel for Chairman Comer.
p. 6Ms. Cathey.Hannah Cathey, professional staff member for Chairman Comer.
p. 6Mr. Harnice.Will Harnice, professional staff member, Chairman Comer.
p. 6Ms. Feyerabend.Emily Feyerabend, counsel for Chairman Comer.
p. 6Ms. Collins.Jessica Collins, comms director.
p. 6Ms. Cogar.Mallory Cogar, director of operations and chief clerk, Chairman Comer.
p. 6Ms. Vinyard.Ashlee Vinyard, deputy staff director, Chairman Comer.
p. 6Mr. Spectre.Peter Spectre, director of oversight, Chairman Comer. . , senior counsel, Ranking Member Garcia. . , research analyst, Ranking Member Garcia. . , chief counsel, Ranking Member Garcia. . , chief counsel, Ranking Member Garcia. . , Ranking Member Garcia. , senior counsel, Ranking Member Garcia. . , deputy comms director, Ranking Member Garcia. . , rapid response strategist, Ranking Member Garcia. . , press secretary, Ranking Member Garcia. . , deputy press secretary, Ranking Member Garcia. . , fellow, Ranking Member Garcia.
p. 6Ms. Brignac.Mr. Staley, before we begin, I would like to go over the ground rules for this interview. The questioning will proceed in rounds. The majority will ask questions for up to an hour, and then the minority will have an opportunity to ask questions for up to an hour if they choose. To the extent members have questions for the witness, they will be propounded during their side's respective round. The clock will stop if you need to confer with counsel, your counsel is speaking, and when members or staff are present during the opposing side's round of questions. We will alternate back and forth until there are no more questions. Do you understand?
p. 7Mr. Staley.Yes, I do.
p. 7Ms. Brignac.There is a court reporter taking down everything I say and everything you say to make a written record of the interview. For the record to be clear, please wait until the staffer questioning you finishes each question before you begin your answer, and the staffer will wait until you finish your response before proceeding to the next question. Further, to ensure the court reporter can properly record this interview, please speak clearly, concisely, and slowly. Also, the court reporter cannot record nonverbal answers, such as nodding or shaking your head. So it is important that you answer each question with an audible, verbal answer. Do you understand?
p. 7Mr. Staley.Yes, I do.
p. 7Ms. Brignac.Exhibits may be entered into the record. Majority exhibits will be identified numerically. Minority exhibits will be identified alphabetically. Do you understand?
p. 7Mr. Staley.Yes, I do.
p. 7Ms. Brignac.We want you to answer all questions in the most complete and truthful manner possible, so we will take our time. If you have any questions or do not fully understand the questions, please let us know. We will attempt to clarify, add context, or rephrase our questions. If we ask about specific conversations or events in the past and you are unable to recall the exact words or details, you should testify to the substance of those conversations or events to the best of your recollection. If you recall only a part of a conversation or event, you should give us your best recollection of those events or parts of conversations that you do recall. Do you understand?
p. 8Mr. Staley.I do.
p. 8Ms. Brignac.Although you are here voluntarily, you are required by law, pursuant to Title 18 of United States Code Section 1001 to answer questions from Congress truthfully. This also applies to questions posed by congressional staff in this interview. Do you understand?
p. 8Mr. Staley.Yes, I do.
p. 8Ms. Brignac.If at any time you knowingly make false statements, you could be subject to criminal prosecution. Do you understand?
p. 8Mr. Staley.Yes, I do.
p. 8Ms. Brignac.This includes both knowingly providing false testimony, but also stating that you do not recall or remember something when, in fact, you do. Do you understand?
p. 8Mr. Staley.Yes, I do.
p. 8Ms. Brignac.Furthermore, you cannot tell half-truths or exclude information necessary to make statements accurate. You are required to provide all information that would make your response truthful. A deliberate failure to disclose information can constitute a false statement. Do you understand?
p. 9Mr. Staley.Yes, I do.
p. 9Ms. Brignac.Is there any reason you are unable to provide truthful testimony in today's interview?
p. 9Mr. Staley.No.
p. 9Ms. Brignac.Please note that if you wish to assert a privilege over any statement today, that assertion must comply with the rules of the Committee on Oversight and Government Reform. Pursuant to that, Committee Rule 16(c)(1) states: "For the Chair to consider assertions of privilege over testimony or statements, witnesses or entities must clearly state the specific privilege being asserted and the reason for the assertion on or before the scheduled date of testimony or appearance." Do you understand?
p. 9Mr. Staley.Yes, I do.
p. 9Ms. Brignac.Ordinarily, we take a five-minute break at the end of each hour of questioning, but if you need a longer break or a break before that, please let us know and we will be happy to accommodate. However, to the extent there is a pending question, we would ask that you finish answering the question before we take a break. Do you understand?
p. 9Mr. Staley.Yes, I do.
p. 9Ms. Brignac.Do you have any questions before we begin?
p. 9Mr. Staley.No.
p. 9Ms. Brignac.I understand you have an opening statement you would like to enter into the record? No? Okay. The time reads 10:13 a.m., and the majority's time will begin now. EXAMINATION
p. 10QMr. Staley, let's begin by discussing your background. Where were you born?
p. 10ABorn in Cambridge, Massachusetts.
p. 10QWhat year were you born?
p. 10AIn 1956.
p. 10QWhat is your marital status?
p. 10AI am married, but separated.
p. 10QWhat is your educational background?
p. 10AI have a bachelor's degree in economics from Bowdoin College.
p. 10QWe'll go into more detail later, but can you briefly describe your professional career?
p. 10AI spent 30 years at J.P. Morgan or so; 10 years in Brazil; 10 years building J.P. Morgan's Investment Bank -- excuse me, Asset Management and Private Bank; and then 10 years running the investment bank or thereabouts. Ten years in Latin America. It was 10 years building the equity business. It was like five or six years running Asset Management and three or four years running the Investment Bank. So I stand corrected.
p. 10QOver those years in J.P. Morgan, what are the dates that you held each position?
p. 10AI don't recall the dates.
p. 10QWhen did you start working at J.P. Morgan?
p. 10AIn 1979.
p. 10QWhat was your role at that time?
p. 10AI went into the training program, and then in 1980 was when I first went to Latin America. I was in Latin America till 1989.
p. 10QWhat were you doing in Latin America?
p. 11AA number of jobs. At one point, I was running the rep office. And then we got a license to open a bank in Brazil and ultimately ended up running the bank of J.P. Morgan in Brazil.
p. 11QWhat was your next position?
p. 11AThen I moved to New York and was part of a small team asked to build a public equities business at J.P. Morgan.
p. 11QWho asked you to do that?
p. 11AI believe at the time it was Bill Harrison.
p. 11QWhat year was that?
p. 11AThat would have been 1989.
p. 11QWhat was your next position?
p. 11AThen I was asked to go run the Private Bank.
p. 11QIn 1999?
p. 11AAbout 2000.
p. 11Q2000? Okay. And what was your next position?
p. 11AThen, added to running the Private Bank, I was asked to run Asset Management as well.
p. 11QWas that the next year, 2001?
p. 11AThereabouts, yes.
p. 11QWhat was your next position?
p. 11AI did that until I think about 2009, and then was asked to run the Investment Bank of J.P. Morgan.
p. 11QWhen did you leave J.P. Morgan?
p. 11AIn 2013.
p. 11QWhy did you leave J.P. Morgan?
p. 11AI stepped down as head of the Investment Bank and took a much smaller role. And it seemed like it was time to move on from J.P. Morgan.
p. 12QWhy is that?
p. 12AI don't know the actual reason. I think there was a period of time where the general thought at Morgan was that the successor to the CEO probably needed to come from the Investment Bank, given its uniqueness and size. And so I think who occupied that role generally was considered a potential successor to the CEO. And I think the bank made the decision that I would not be the successor to the then-CEO, and therefore it was time to step down from the Investment Bank.
p. 12QDid they communicate the reason why they thought you were not an appropriate successor?
p. 12ANo.
p. 12QDid you ever hear from anyone else why they thought you would not be an appropriate successor?
p. 12ANo.
p. 12QDo you believe it was because of your affiliation with Mr. Epstein?
p. 12ANo.
p. 12QDo you still hold a role at J.P. Morgan?
p. 12ANo.
p. 12QWhen did you leave J.P. Morgan's orbit entirely?
p. 12A2013.
p. 12QWhat was the smaller role you held?
p. 12AI think I was made chairman of the Investment Bank, which is a much less role than the CEO.
p. 12QDid anyone ask you to leave J.P. Morgan?
p. 12ANo, but the implication of the lesser role was it was probably time to move on.
p. 12QDid you reach any agreement with J.P. Morgan on your departure about rules you would abide by regarding your knowledge of J.P. Morgan's dealings?
p. 13AAside from the sort of standard confidentiality agreements, that was it.
p. 13QWas there any additional confidentiality they asked you to abide by given the very senior roles you held?
p. 13ANo.
p. 13QWould those confidentiality agreements have prohibited you from discussing J.P. Morgan's dealings with friends of yours?
p. 13AI think you respect confidentiality, but it was at my discretion if I wanted to talk to friends of mine about issues at J.P. Morgan.
p. 13QYou were able to use your discretion to discuss confidential matters of J.P. Morgan's? Is that accurate?
p. 13AI believe so, yes.
p. 13QAre you currently employed?
p. 13ANo, I'm not.
p. 13QThank you. Tell me about the first time you interacted with Mr. Epstein?
p. 13AThe first time I interacted with Mr. Epstein would have been I had a passing -- I met him in passing in about 2000. And then in 2001, the then-CEO of J.P. Morgan, Sandy Warner, called me and said that he had met Jeffrey Epstein. It seemed like he was quite connected to a high net worth network in New York and that given my new role as running the Private Bank I should probably meet him. So I did.
p. 13QWho introduced you to him?
p. 13AThat would have been Sandy Warner.
p. 13QWhat year was this?
p. 13AI believe 2001.
p. 14QAnd where were you at this time?
p. 14AIn New York.
p. 14QWhere specifically in New York?
p. 14AOn Park Avenue right above Grand Central.
p. 14QWhat was the reason for this interaction?
p. 14AAgain, I think I was running the Private Bank, which meant trying to develop high net worth clients for J.P. Morgan. And Sandy Warner mentioned that Jeffrey Epstein seemed to be connected to the high net worth community of J.P. Morgan, and therefore I went to pay a visit to Jeffrey Epstein.
p. 14QWhy was he considered of a high net worth?
p. 14AHe was an existing client at the Private Bank, so I wasn't the one who brought him in and determined his net worth. That was before I was made head of the Private Bank.
p. 14QDid Sandy Warner tell you anything about Mr. Epstein before you met him?
p. 14AJust that he seemed to be connected to the high net worth community in New York.
p. 14QDid you hear anything about Mr. Epstein during your time at the bank?
p. 14AThe entire time at the bank?
p. 14QPrior to your meeting Mr. Epstein.
p. 14ANo.
p. 14QWhat did you know about him prior to this meeting?
p. 14AI guess all I knew was that he had a connection to Les Wexner. Back when I first crossed him in 1999, I was running equity capital markets, and we took The Limited public, which was owned by Les Wexner. And that's where I had the one passing encounter. So all I knew was that he had a connection to Les Wexner.
p. 14QDid that alone make him a high-value client, or were there other things you knew about him that led you to that belief?
p. 15ANo. Again, in the beginning it was simply I was asked to meet him by the then-CEO of J.P. Morgan.
p. 15QWhat were your impressions of him upon meeting him?
p. 15AAgain, I knew very little about him, so I think it was a reasonably brief meeting. He had an office next to St. Patrick's Cathedral, which was an interesting place to have an office. But it was a brief conversation, and that was it.
p. 15QWhat was his demeanor? What was he like?
p. 15AHe seemed relaxed, intelligent, curious.
p. 15QWho else was present at the meeting?
p. 15AJust myself.
p. 15QWhat did you understand his job to be?
p. 15AAgain, save for providing some advice to Les Wexner, I didn't know what his job was.
p. 15QDid you ever become involved in his business with Les Wexner?
p. 15AIn his business with Les Wexner? No.
p. 15QDid you ever become involved in his financial dealings with Les Wexner?
p. 15ANo.
p. 15QDid anyone raise concerns about Mr. Epstein prior to this meeting?
p. 15ANo.
p. 15QAfter you met Mr. Epstein, what happened next?
p. 15ANothing significant happened next. I think we probably met a few more times. But for a while nothing happened.
p. 15QSo what was your relationship with him at this time? Were you assigned to any of his accounts? Did you begin dealing with him in his business? What happened next?
p. 15AI was not -- I had no dealings with his business. I wasn't really sure what his business was aside from his connection to Les Wexner. I had not managed his accounts. I did not know what accounts he had with Morgan. It wasn't a close -- I wasn't close to what he was doing with the bank. And, again, I was very active doing a lot of other things at Morgan. So it was -- we would meet occasionally, not that often, and that was the early years of my interaction with him.
p. 16QWho was assigned to his accounts?
p. 16AAt that time, I didn't know who was managing his accounts.
p. 16QWhat part of the bank was he assigned to and why?
p. 16AHe was a high net worth client, so he was a client of the Private Bank.
p. 16QWhat are the requirements to be assigned to the Private Bank? What factors go into that decision?
p. 16AI think back then it was probably somewhat of a wealth test. Did someone have sufficient net worth to be part of the Private Bank. My recollection, it was roughly a minimum of $5 million. And that was about it.
p. 16QHow many accounts did Mr. Epstein have at J.P. Morgan over the years?
p. 16AI don't know.
p. 16QOver a hundred, would you say?
p. 16AI don't know.
p. 16QThe Committee has reviewed documents that made us believe he had about 134 accounts. Moving into your relationship with Mr. Epstein, we'll go into more specifics later, but for now can you describe the nature and extent of your relationship with Mr. Epstein?
p. 16AIn those early years?
p. 16QOverall, generally, over the years.
p. 16AAgain, it changed over time. I think probably the most significant event in the 2000s was his introduction to me of a man named Glenn Dubin. And Glenn Dubin was the founder of a hedge fund called Highbridge Capital Corporation.
p. 17QWhy is that significant to you?
p. 17ASo in the 2000s, I started out running a Private Bank. And as I said, the then-CEO asked me to add asset management. And the asset management business at that time, the traditional asset management business, was called a long-only business. Asset managers like Fidelity, Capital, and J.P. Morgan and Vanguard would manage portfolios of stocks and portfolios of bonds from a long-only position. That was the principal asset management business. What was developing in the early 2000s were two alternative ways to manage money. One was called private equity. So rather than buying public securities, you would invest in nonpublic companies. The other was the hedge fund industry. And what narrowly defined the hedge fund industry was not only would you go long stocks and bonds, but you could also go short stocks and bonds. And one of the early hedge funds was Highbridge Capital Corporation.
p. 17QSo did Mr. Epstein's introduction to Glenn Dubin change the nature of your relationship?
p. 17AYes, to the extent that over a period of time, over a year or so, I got to know Glenn Dubin. I got to understand somewhat the hedge fund industry. And it began to become an idea with Glenn and myself that perhaps J.P. Morgan as a long-only asset manager make an investment in Highbridge Capital. And Epstein was aware of that.
p. 17QAnd he earned a $15 million fee from that transaction, correct?
p. 17ASo he encouraged the conversation between Glenn and myself. It took a fair period of time for Glenn and I to reach the conclusion that it might work. It was an internal process of getting Morgan comfortable with the possibility that we might invest in a hedge fund. So it took a period of time, but ultimately Glenn and I found a way to make it work. Epstein was a supporter of the transaction. And when the transaction was consummated, J.P. Morgan, we paid an advisory fee for the acquisition to Goldman Sachs, and Glenn paid an -- or Highbridge, I should say, not Glenn -- Highbridge paid an advisory fee to Jeffrey Epstein.
p. 18QAnd that --
p. 18AAn important note, Highbridge was owned half by Glenn Dubin and half by a gentleman by the name of Henry Swieca. Again, who paid the fee to Jeffrey was Highbridge, neither Glenn nor Henry Swieca.
p. 18QDid this acquisition benefit your career?
p. 18AYes.
p. 18QHow?
p. 18AAs I said, you had the traditional asset management industry, and you had the alternative asset management industry. And really up until the Highbridge acquisition by J.P. Morgan, the two industries had never really partnered or --
p. 18QI'm sorry, do you understand my question? How did that benefit your career?
p. 18ABecause it was a very successful transaction for J.P. Morgan, it was very novel, and I was seen as the leader of that transaction inside of J.P. Morgan.
p. 18QSo Mr. Epstein benefited from the transaction and you benefited from the transaction. What year did this transaction take place?
p. 18AI believe it was closed in 2004.
p. 18QOkay. So by this point you've referenced a significant transaction between you and Mr. Epstein. We've covered years --
p. 18AExcuse me. Say that again? It was not a transaction between me and Jeffrey Epstein.
p. 18QOkay. So by this point in 2004 you've referenced a significant event. We've covered years of your relationship with Mr. Epstein. Did you develop a friendship over these years?
p. 18AAgain, it was always a business relationship, but he gave advice and had good insights into the industry and into broader finances, and I would seek his thoughts.
p. 19QDid you ever discuss personal matters?
p. 19AOnly later on did I discuss career issues with Jeffrey Epstein, yes, but always around my career and business, not personal.
p. 19QSo you never discussed personal matters with Mr. Epstein?
p. 19ANo, I think it was always centered around business and my career. If you consider a career personal. But it was around business and my career.
p. 19QDid you ever discuss your families?
p. 19AOnly very later on. I discussed the interest of my daughter getting a graduate degree in physics. And so that was probably the first time we talked about personal issues.
p. 19QReturning to your dealings with Mr. Epstein, you referenced earlier that you believed it was in your discretion to divulge confidential information. Is that accurate?
p. 19AYes.
p. 19QDoesn't the nature of confidentiality mean that there are barriers around what you can divulge?
p. 19ABut I think senior officers of the bank, whether it's to a lawyer or to a consultant or someone that they consider knowledgeable in an industry, can ask questions and can talk about confidential issues, issues that, obviously, a person cannot act on it.
p. 19QWere there any barriers to your sharing of information with Mr. Epstein specifically by J.P. Morgan?
p. 19ANo.
p. 19QHow often did you interact with Mr. Epstein in a personal capacity?
p. 19AAgain, my interactions were predominantly around business and my career, so I don't know how to characterize just personal.
p. 19QWell, Mr. Staley, documents released by the DOJ illustrate that you referenced Mr. Epstein as family to you. What did that mean?
p. 20AI use warm language both in a personal capacity as well as a professional capacity. I referred to many colleagues and people I worked with as friends. So I don't -- I didn't find that particularly unique.
p. 20QYou reference to everyone you have a business relationship with as family?
p. 20AI didn't say I reference everyone I had business with as family.
p. 20QNo, I asked if you referenced.
p. 20ASo the answer to that question would be no.
p. 20QSo why Mr. Epstein?
p. 20AAgain, he was one of the people I dealt with in business that was particularly helpful on a number of levels and transactions. And so I believe the first person to reference a family issue was him referencing to me. I think I was just being accommodating to what he was doing.
p. 20QYou've already referenced Mr. Epstein did communicate with your daughter. Did he have a relationship with all of your family members?
p. 20ANo, just principally me and my eldest daughter.
p. 20QDid you get the impression that your family liked him?
p. 20AAgain, my second daughter had no interaction with him really, and my wife had very limited interaction with him.
p. 20QWhat was the nature of your daughter's relationship with Mr. Epstein?
p. 20AShe was getting -- she was in the process of getting a Ph.D. in physics. Epstein was very engaged, it seemed or it appeared, in the scientific community, internationally, and in the academic community, particularly with Columbia and Harvard.
p. 20QDid they frequently communicate without your knowledge?
p. 20ANo, I don't think so. [Staley Majority Exhibit No. 1. was marked for identification.]
p. 21QI'm entering majority exhibit 1 into the record which is Bates stamped with EFTA00905750 and dated March 5th, 2011. This is an email between you, Mr. Staley, and Mr. Epstein. We'll get that passed out and give you a moment to review. Whenever you're ready?
p. 21AI'm ready.
p. 21QDo you recognize this document, Mr. Staley?
p. 21AI recognize it's an email from me to Mr. Epstein, yes.
p. 21QCan you please read it into the record?
p. 21AFrom Jes Staley to jeevacation@gmail.com. No subject. The date is Saturday, 5th of March, 2011. I think it's 5:11:41 seconds. And it reads: "Deby and I were talking tonight about what you have meant to me and to You have paid a price for what has been accused. But we know what you have done for us and we count you as one of our deepest friends and most honest of people. Thanks, Jes."
p. 21QAnd, Mr. Staley, is Deby referring to your legally married wife who you're separated from?
p. 21AYes.
p. 21QAnd refers to your daughter?
p. 21AYes.
p. 21QWhy did you send this email?
p. 21AIt was quite unique at that time that a young woman from -- a young woman would pursue a Ph.D. in physics. And at one point made the decision to pursue a career as a physicist. Epstein was, as I said, very connected to the scientific community, and he encouraged my daughter to pursue a doctorate in physics and connected her to some people in the physics community.
p. 22Mr. Grant.We've had some Members of Congress join us. Could they please announce themselves for the record? Chairman Comer. James Comer, Chairman, House Oversight Committee.
p. 22Mr. Krishnamoorthi.Raja Krishnamoorthi.
p. 22Mr. Grant.Thank you all.
p. 22QMr. Staley, I understand in sworn testimony to the Financial Conduct Authority you admitted by 2010 you knew Mr. Epstein lied to you in 2006 about the ages of victims who had brought allegations against him. This email you said is in 2011. Can you help reconcile our confusion about why you would call him the most honest of people when you knew he lied to you?
p. 22AAgain, I think it was a reflection of the pride we had in what our daughter was doing, the uniqueness of someone of her age accomplishing what she accomplished in physics. It was, I think, reflective more of what was doing than anything else. But he was helpful. And I use warm language on many occasions. And he was constructive in what our daughter accomplished.
p. 22QCan you tell me about your first interaction with Ghislaine Maxwell?
p. 22AI don't believe I had interaction with Ghislaine Maxwell.
p. 22QYou recommended J.P. Morgan open an account for her; correct?
p. 22AI don't remember that.
p. 22QWould it help if we refreshed your recollection?
p. 22ASure.
p. 22QWe'll go off the record. [Discussion off the record.]
p. 23Ms. Brignac.We'll go back on the record. I am entering majority exhibit 2 into on the record, which is an internal report generated by J.P. Morgan and Bates stamped EFTA01582859. [Staley Majority Exhibit No. 2. was marked for identification.]
p. 23QI would draw your, attention Mr. Staley, to the bottom right of the page under the "Banker Response" column where it states: "Ghislaine Maxwell is a very close friend of Jeffrey Epstein who is an existing client and who has recommended us to her. Jes Staley has also met with her and has recommended we open an account for her." So do you recall meeting Ms. Maxwell now?
p. 23AI don't.
p. 23QDid J.P. Morgan end up opening an account for Ms. Maxwell?
p. 23AI have learned that they did, yes.
p. 23QAnd we can agree your recommendation for a referred client in opening account probably carries quite a bit of weight with your senior roles, correct?
p. 23AI think there's a whole process to go to open an account of the Private Bank. That involves compliance departments, legal departments, et cetera. So I think there's a process that the bank follows. The recommendation would be accounted in that process. But it's a separate process for opening an account.
p. 23QDid Mr. Epstein ask you to meet with Ms. Maxwell?
p. 23AI don't recall that.
p. 23QHave you ever met with Ms. Maxwell on any other occasion?
p. 23AAgain, I don't know what occasion this refers to. If you have what occasion, that would be helpful for my memory.
p. 24QNo, just based on your personal knowledge, do you have any recollection of other meetings with Ms. Maxwell besides the one I've just showed you?
p. 24ANo.
p. 24QHow often would you have casual or private conversations with Mr. Epstein?
p. 24AAgain, I think we met with a fair degree of frequency and had a fair degree of telephone calls and that sort of thing. So fairly often.
p. 24QCan you estimate daily, weekly, monthly?
p. 24AI would say weekly.
p. 24QWeekly. Did Mr. Epstein ever discuss young women or girls with you?
p. 24ANo, he did not.
p. 24QDid Mr. Epstein ever introduce you to young women or girls?
p. 24ANo, he did not.
p. 24QDid Mr. Epstein ever discuss massages with you?
p. 24ANo, he did not.
p. 24QDid Mr. Epstein -- strike that. Did you ever witness Mr. Epstein receive a massage of any kind from a young woman or girl?
p. 24ANo, I did not.
p. 24QDid you ever witness Mr. Epstein pay women for massages?
p. 24ANo, I did not.
p. 24QDid you ever witness Mr. Epstein giving cash to other young women or girls?
p. 24ANo, I did not.
p. 24QDid you ever witness Ms. Maxwell giving cash to young women or girls?
p. 24ANo, I did not.
p. 25QDid Mr. Epstein ever discuss sexual acts with you?
p. 25ANo.
p. 25QDid you ever witness Mr. Epstein sexually abuse or assault young women or girls?
p. 25ANo.
p. 25QDid you ever witness Ms. Maxwell sexually abuse or assault young women or girls?
p. 25ANo.
p. 25QDid you ever witness Mr. Epstein engage in sexual conduct?
p. 25ANo, I did not.
p. 25QDid you ever witness Ms. Maxwell engage in sexual conduct?
p. 25ANo, I did not.
p. 25QDid you ever witness Mr. Epstein exploit young women or girls?
p. 25ANo, I did not.
p. 25QMs. Maxwell?
p. 25ANo, I did not.
p. 25QDid they ever threaten anyone?
p. 25AI never saw that.
p. 25QDid Mr. Epstein or Ms. Maxwell ever ask if you wanted them to bring women or girls to you?
p. 25ANo.
p. 25QDid you ever have sexual contact with any young woman or girl introduced to you by Mr. Epstein?
p. 25AWhat do you mean by introduced?
p. 25QHowever you interpret introduction.
p. 25ASo ask the question again?
p. 25QDid you ever have sexual contact with any young woman or girl introduced to you by Mr. Epstein?
p. 26AYoung women and girls, no.
p. 26QWhy the confusion on that question? Is there someone you think we should be aware of?
p. 26AAs I have testified before, I had an encounter once with someone who was on Epstein's staff but was a mature woman.
p. 26QOkay. We'll return to that. Did you ever have any sexual contact with young women or girls in the presence of Epstein?
p. 26ANo.
p. 26QWere you ever aware that Mr. Epstein regularly entertained young women at his residences?
p. 26ANo.
p. 26QHow did Mr. Epstein act towards the young women or girls that were around him?
p. 26AAs I said, I did not see him with young women or girls around him.
p. 26QHow did he act with his assistants?
p. 26AHe treated them professionally.
p. 26QWe can agree his assistants were mostly young women, correct?
p. 26AAgain, it would be helpful if you define young women. There were women of late 20s, 30s.
p. 26QWere you aware of the nature of any of Mr. Epstein's activities involving minors?
p. 26ANo.
p. 26QWhen did you become aware of these activities?
p. 26AI knew in 2006 that he was indicted and obviously was aware in 2008 of his plea. And that's when I think those -- when I became aware of the allegation that he was involved with minors.
p. 26QDo you know of any individuals that knowingly facilitated Mr. Epstein in his criminal activities?
p. 27ANo.
p. 27QAnd for the record, have you ever been contacted by any law enforcement agency concerning Jeffrey Epstein or Ghislaine Maxwell?
p. 27ANo, I have not.
p. 27QHave you ever been interviewed by any law enforcement agency concerning Jeffrey Epstein or Ghislaine Maxwell?
p. 27ANo, I have not.
p. 27QHave you ever provided any information to any law enforcement agency concerning Jeffrey Epstein or Ghislaine Maxwell?
p. 27ANo, I have not.
p. 27QDid Jeffrey Epstein ever inform or represent to you he was working with any intelligence service of any nation, including the United States?
p. 27ANo, he did not.
p. 27QDid Ghislaine Maxwell?
p. 27ANo, she did not.
p. 27QDuring your relationship, did you ever suspect Jeffrey Epstein or Ghislaine Maxwell of being affiliated with any intelligence agency?
p. 27AJeffrey Epstein had a network of contacts internationally, but I never associated it with an intelligence agency.
p. 27QAt any time, have you had an affiliation with any intelligence agency?
p. 27AWhen I was with the Private Bank, I had some interaction with parts of the U.S. intelligence system.
p. 27QHave you or any of your representatives or agents asked anyone to sign a nondisclosure agreement or other agreement in connection with Jeffrey Epstein?
p. 28ANo, I have not.
p. 28QHave you or any of your representatives or agents asked anyone to sign a nondisclosure agreement in connection with Ghislaine Maxwell?
p. 28ANo, I have not.
p. 28QHave you or any of your representatives or agents asked anyone to sign a nondisclosure agreement affiliated with any of Jeffrey Epstein and Ghislaine Maxwell's victims?
p. 28ANo, I have not.
p. 28QI'm going to follow up with more questions, but for now please answer yes or no to the following. Have you ever visited Mr. Epstein's private island Little Saint James?
p. 28AYes.
p. 28QHow many times?
p. 28AI believe three times, although one occasion was literally to get on his island into the helicopter and left.
p. 28QHave you ever visited Mr. Epstein's Palm Beach house?
p. 28ANo.
p. 28QHave you ever visited Mr. Epstein's Manhattan townhouse?
p. 28AYes.
p. 28QHave you ever visited his apartment buildings or offices at 301 East 66th Street in New York?
p. 28AYes.
p. 28QHave you ever visited Mr. Epstein's New Mexico ranch Zorro?
p. 28AOnce.
p. 28QHave you ever visited Mr. Epstein's Paris apartment?
p. 28ANo.
p. 29QHave you ever visited Mr. Epstein's Great Saint James Island?
p. 29AThat's the island in the Virgin Islands. Yes.
p. 29QHave you ever visited Mr. Epstein's property in New Albany, Ohio?
p. 29AI didn't know that he had a property in New Albany, Ohio.
p. 29QHave you ever visited any of his other properties that are owned or leased by him that I didn't state?
p. 29ANo.
p. 29QHow many times did you visit his Manhattan townhome?
p. 29ADozens of times.
p. 29QAnd his offices at 301 East 66th Street in New York how many times?
p. 29AOnce.
p. 29QDid you see any young women or girls while you were at the Manhattan townhome?
p. 29ANo.
p. 29QWhile at any properties, did you witness any sexual conduct by Jeffrey Epstein with any women or girls?
p. 29ANo.
p. 29QWhile at any of his priorities, did you witness any sexual conduct by anyone else with young women or girls?
p. 29ANo.
p. 29QMr. Staley, you've testified that you did give prior testimony that you had a sexual relationship with one of Mr. Epstein's assistants. Who was that?
p. 29QHow did you meet her?
p. 29AShe was an assistant to Jeffrey Epstein, and I met her at his townhouse.
p. 29QWho else was there?
p. 30AAgain, most often it would be his assistant Lesley Groff. That would be really the only other person that was often there that I saw.
p. 30QHow many times did you interact with her before you had sex?
p. 30AA handful.
p. 30QCan you give me a number estimate?
p. 30AI would be guessing, but 6 to 12.
p. 30QWhat were the circumstances that led you to have sex with her on that first occasion?
p. 30AOn the only occasion. We met and began to have a dialogue and it turned flirtatious. And we met and had one intimate encounter.
p. 30QDid Mr. Epstein set it up?
p. 30ANo.
p. 30QAre you aware if she's had sex with anyone else associated with Mr. Epstein?
p. 30ANo.
p. 30QWhere did the sex take place?
p. 30AAt her apartment.
p. 30QWhere did she live?
p. 30A66th Street, to my recollection.
p. 30QDid you discuss the fact that you had sex with her with Mr. Epstein?
p. 30ANo, I did not.
p. 30QDo you know if she shared that with Mr. Epstein?
p. 30ANo, I don't.
p. 30QHave you had sex with anyone else associated with Mr. Epstein?
p. 30ANo, I have not. [Staley Majority Exhibits Nos. 3, 4, and 5 were marked for identification.]
p. 31Ms. Brignac.I am now entering into the record three exhibits, which will be marked majority exhibits 3, 4, and 5. We're going to go off the record to pass these out. [Discussion off the record.]
p. 31Ms. Brignac.We'll go back on the record.
p. 31QMajority exhibit 3 is Bates stamped EFTA00779451. Majority exhibit 4 is Bates stamped EFTA00741531. Majority exhibit 5 is Bates stamped EFTA01300651. All three exhibits are parts of email exchanges that took place from July 10th through July 11th of 2010. I'm going to begin, Mr. Staley, by asking questions about majority exhibit 3. This is a photograph sent by Mr. Epstein to a redacted name on July 11th, 2010. Have you seen this photo before?
p. 31ANo, I have not.
p. 31QDid you see this photo in preparation for your examination today?
p. 31AThis photo, no.
p. 31QAcknowledging the face in this photograph is redacted, can you otherwise describe what you see in the photo?
p. 31AThat looks like Epstein's apartment in New York, and obviously it's someone dressed in a costume.
p. 31QYes, it appears to be a young woman in a Snow White costume. Who is in this photograph?
p. 31AI don't know.
p. 31QThe Committee has been able to identify this photograph as . Have you met ?
p. 31AI don't believe so.
p. 32QYou stated you have been to Mr. Epstein's New York townhome. Were you there on or around July 9th through 10th, 2010?
p. 32AI don't know.
p. 32QYou don't know because you can't recall?
p. 32AYes.
p. 32QI will now turn to majority exhibit 4. This email was sent from a who the Committee understands to be , to Mr. Epstein on July 10th, 2010, at 12:36 a.m. And it states that "Snow White was f..ed twice as soon as she put on her costume." Mr. Staley, what do you interpret "f..ed" to mean?
p. 32ASay it again? Sorry. This email is from who?
p. 32QThis is from in the Committee's review of the documents. My question is, what do you interpret "f..ed" to mean?
p. 32AIntercourse.
p. 32QWere you ever around this woman in the Snow White costume at Mr. Epstein's residence?
p. 32ANo.
p. 32QOkay. We will now turn to majority exhibit 5. This is an email exchange between you, Mr. Staley, and Mr. Epstein on July 10th, 2010, sent around the same time that was reporting to Mr. Epstein that Snow White had been f..ed twice. In your email exchange with Mr. Epstein you state: "That was fun. Say hi to Snow White." Why did you send this email?
p. 32AI don't recall. So I don't know.
p. 32QWho were you asking Mr. Epstein to say hi to?
p. 32AI'm saying: "Say hi to Snow White."
p. 32QYes, who is Snow White?
p. 33AYeah, I'm saying I don't know who Snow White is.
p. 33QWe can agree it's coincidental that at the same time you send this email is sending to Mr. Epstein that she was in a Snow White costume, correct?
p. 33AYes.
p. 33QWhy do you think that is?
p. 33AAgain, I don't know.
p. 33QDo you maintain you've never met ?
p. 33AI don't recall ever meeting her, no. I don't know who she is.
p. 33QNow that I've refreshed your recollection, do you recall being at Mr. Epstein's New York townhome on July 9th or 10th, 2010?
p. 33AAgain, we're talking 16 years ago. I don't know exactly what dates I was at his townhouse. I don't recall seeing someone in the Snow White outfit. [11:08 a.m.]
p. 34QHave you seen any woman in a costume around Mr. Epstein?
p. 34ANo.
p. 34QLater in the email exchange, Mr. Epstein asks, "What character would you like next?" What do you think Mr. Epstein's asking you here?
p. 34AUm. You know --
p. 34QI didn't get that. Can you speak up?
p. 34AYeah, I'm trying to -- I'm reading the emails. This seems to imply that I saw a Snow White. And Epstein says, you know, "What character would you like next?" And I referred to "Beauty and the Beast," which was a movie at that time.
p. 34QWho were you referring to as "Beauty and the Beast"?
p. 34AI don't know. I was referring to the movie "Beauty and the Beast."
p. 34QHave you had sexual relations with any woman dressed as a Snow White?
p. 34ANo, I have not.
p. 34QMr. Epstein later responds in the email, "Well, one side is available." Who is Mr. Epstein referring to? It doesn't appear to be the movie.
p. 34AOh, it seems like he's talking about a beauty. But I don't know who that is.
p. 34QHave you ever had sex with Mr. Epstein?
p. 34ANo.
p. 34QHas Mr. Epstein ever asked you to have sex with him?
p. 34ANo.
p. 34QDoes it appear that the characters Mr. Epstein is offering to you can say no?
p. 34Mr. Sullivan.That's a pretty far-out -- I'm doing my best to remain silent, but --
p. 34Mr. Ashworth.I'm sorry?
p. 35Mr. Sullivan.That's a pretty far-out question.
p. 35Ms. Brignac.I would like for you to answer it.
p. 35Mr. Sullivan.Could you read it back for us?
p. 35QDoes it appear that the characters Mr. Epstein is offering to you can say no? Or does it appear to be your choice whether to have the characters?
p. 35AI don't think he's offering characters to me.
p. 35QDid you and Mr. Epstein use Disney princesses as code names for selecting women for sexual encounters?
p. 35ANo.
p. 35QThe Committee has also reviewed documents where Philip Levine uses the exact same code name "Beauty and the Beast." Why would that be?
p. 35AWho is Philip Levine?
p. 35QThe Committee has received credible accusations that Mr. Levine is a man in Mr. Epstein's orbit that committed assault against one of the assistants. Have you ever been around Mr. Levine?
p. 35AI don't know who he is.
p. 35QOkay. The Committee has also reviewed documents that reference other Disney princesses. We would appreciate any information you have on helping us to decode who these women are. Tinker Bell?
p. 35ANo.
p. 35QThe Little Mermaid?
p. 35ANo.
p. 35QCinderellas?
p. 36ANo.
p. 36QSleeping Beauty?
p. 36ANo.
p. 36QHave you ever met Frederic Fekkai?
p. 36ANo, I have not. I may have met him once, but I don't re- -- yeah -- but nothing to do with Epstein.
p. 36QDid you ever hear rumors that Frederic Fekkai was involved with Mr. Epstein's assistants?
p. 36ANo.
p. 36QSame question for Mr. Levine. Did you ever hear anything about Mr. Levine's involvement with Epstein's assistants?
p. 36AI don't know who Mr. Levine is, so no.
p. 36Ms. Brignac.We'll go off the record. [Recess.] . We're back on the record. Good morning, Mr. Staley. My name is , and I'm going to be asking most of the questions for the minority today. I'm going to cover some of the same topics that the majority covered with you in the previous round. That is not to make you repeat yourself but, rather, to make sure we have as clear a record as possible. I appreciate your patience while I do that. In addition, to the extent that any of my questions or any of your answers involve survivor names or any other survivor identifying information, I ask on behalf of the minority that the majority redact that information prior to releasing the transcript publicly. EXAMINATION BY :
p. 37QMr. Staley, I'd like to start with something that you talked about briefly in the previous round. You testified that you had sex with a young woman on Mr. Epstein's staff both in a deposition in a class action against J.P. Morgan and also before the U.K.'s Financial Conduct Authority. As reported by The New York Times, you said that, in 2009 or 2010, while visiting Mr. Epstein's New York residence, you had a conversation with a young woman in her twenties who worked for Mr. Epstein. You further said that the young woman suggested that you come by the building she lived in on the Upper East Side. According to you, when you visited her apartment, you went to her bedroom, had consensual sex, took a shower, and then left and went back to work. I have some questions for you about that encounter. Do you remember when you first met this woman?
p. 37ANot exactly, no.
p. 37QSo you said it was sometime in 2009 or 2010. Can you be more specific?
p. 37ANo. I mean, 2009, 2010.
p. 37QMr. Epstein was incarcerated through July 2009 and on house arrest through July 2010. Does that help you narrow down the period?
p. 37AI guess -- I guess it would've been after July 2009 then.
p. 37QAnd you said previously that you met this young woman at Mr. Epstein's New York home, correct?
p. 37AYeah. And, again, I don't know whether she was in her twenties or thirties, but --
p. 37QI asked if you met her at Mr. New York -- excuse me. I asked if you met her at Mr. Epstein's New York home.
p. 37AYes, I did.
p. 37QAnd you're also saying you don't remember her age?
p. 38AAgain, I think it was twenties or thirties.
p. 38QAnd you said previously that you'd talked to this woman a few times. Do you remember exactly how you first met her?
p. 38AYeah. She was an assistant for Epstein. Oftentimes when I went to his house, he would not, you know, be available, and so she and I would engage in a discussion about, you know, just banter.
p. 38QAnd do you remember how many times you spoke with her?
p. 38AI'm sure it would've been half a dozen to a dozen times.
p. 38QDid you talk to other assistants for Mr. Epstein too?
p. 38AYes.
p. 38QDid you have any sense of what she did as one of Mr. Epstein's assistants?
p. 38AYou know, he had -- he traveled a lot. He had a lot of properties. She seemed to have an administrative role in helping travel and management of his properties, is what I thought.
p. 38QWhen did you have the conversation with her where you claim she invited you to her apartment?
p. 38AI don't exactly recall, but I think it was 2010.
p. 38QDo you remember when it was relative to when you first met her?
p. 38AI'm sure it was months after I first met her.
p. 38QMonths. Okay. What exactly did she say to you?
p. 38AI don't recall the exact conversation.
p. 38QDid she tell you why she wanted you to come to her apartment?
p. 38AI don't believe so, no.
p. 38QSo she just invited you to her apartment, but she didn't tell you why she wanted you to come?
p. 38AI think it was suggested, but I don't think she said explicitly, no.
p. 39QHow would she have suggested that?
p. 39A"You want to come by my apartment," you know, "tomorrow morning?" I think that's suggestive.
p. 39QSo did she tell you when she wanted you to come by her apartment?
p. 39AJust in the morning is my recollection.
p. 39QDid she tell you where her apartment was?
p. 39AYes.
p. 39QAnd your recollection is, you had this conversation one day at some point in 2010 and then the next day, specifically the next morning, you went to her apartment?
p. 39AThat seems right, yes.
p. 39QHow did you get into her apartment?
p. 39AIt was a concierge building, and I went to the concierge and said I was there to meet (ph). He called up; she said, "Please let him in." He gave me her apartment number, and I went up to the apartment.
p. 39QYou testified that you had sex at her apartment. Please walk us through what happened.
p. 39AI think we talked. I believe we were sitting on her couch together while we talked. And one thing led to another and we had an intimate engagement.
p. 39QWas the sex consensual?
p. 39AYes.
p. 39QHow did you know it was consensual?
p. 39AMy recollection is, she invited me into her bedroom.
p. 39QDo you remember what she said to you?
p. 39APrecise words, no.
p. 39QAre you aware that Mr. Epstein would instruct women in his orbit to have sex with men that he was connected to?
p. 40ANo, I was not.
p. 40QYou've since become aware of that, correct?
p. 40AI am not aware of him instructing his assistants to have sex with men, no. I'm not.
p. 40QAs you sit here today, that is something that you are totally unaware of?
p. 40AYes.
p. 40QYou previously testified that you never spoke to Mr. Epstein about this encounter, correct?
p. 40AThat's correct.
p. 40QSo how do you know that Mr. Epstein did not instruct this woman to have sex with you?
p. 40AThat's my assumption. It didn't seem -- that's what I assumed.
p. 40QIs it possible that, instead of her inviting you to her apartment, you just showed up?
p. 40ANo.
p. 40QWere you violent with her?
p. 40ANo.
p. 40QHad you ever been to this young woman's apartment or her building before?
p. 40ANo, I had not.
p. 40QDid you visit this young woman's apartment or her building after?
p. 40ANo, I did not.
p. 40QYou said previously you remembered the building was on 66th Street. Is it correct that the building was 301 East 66th Street?
p. 40AI don't recall the exact number.
p. 40QWere you aware at the time that Mr. Epstein housed women he trafficked in this building?
p. 40ANo, I was not.
p. 41QAre you aware of that now?
p. 41ANo, I am not.
p. 41QDid you see this young woman following this encounter?
p. 41AYes, I did.
p. 41QHow often?
p. 41AA few times, I think.
p. 41QWas this at Mr. Epstein's New York home?
p. 41AYes.
p. 41QDid you speak with her?
p. 41AI believe so, yes.
p. 41QWhat did you talk about?
p. 41AJust casual conversation.
p. 41QDid you engage in any sexual activity with this young woman at any point after your visit to her apartment?
p. 41ANo, I did not.
p. 41QAnd, to be clear, that encounter that you claim was consensual was the first time that you engaged in any sexual activity with this woman?
p. 41AThat's correct.
p. 41QThis woman sued Mr. Epstein for sexual abuse and settled with his estate. Were you aware at the time that Mr. Epstein was sexually abusing her?
p. 41ANo, I was not.
p. 41QThis woman carved you out of her settlement with Mr. Epstein's estate, meaning that she reserved the right to pursue legal action against you. Were you aware of this?
p. 41ANo, I was not.
p. 41QYou were not aware of this at any point up until today?
p. 42Mr. Sullivan.His answer to that would require revealing attorney-client communication. BY
p. 42QIf the sex that you had with this woman was consensual, as you claim it was, why would she have wanted to reserve her right to bring claims against you?
p. 42AI don't know.
p. 42QYou previously testified in a sworn deposition that this was your only Epstein-connected sexual encounter.
p. 42AThat's correct.
p. 42QDo you stand by that testimony?
p. 42AI do.
p. 42QDid you ever meet any minor girls through Mr. Epstein?
p. 42ANo, I did not.
p. 42QBut you did meet young women through Mr. Epstein, correct?
p. 42AAgain, I met some of his assistants, who were in their twenties or thirties.
p. 42QAnd you met the woman that you claim you had consensual sex with through Mr. Epstein, correct?
p. 42ACorrect.
p. 42QHow many young women would you say you met through Mr. Epstein?
p. 42AA half a dozen.
p. 42QOther than the encounter that we just discussed, did you engage in sexual activity with any of those women?
p. 42ANo, I did not.
p. 42QDid Mr. Epstein ever pay women to engage in sexual activity with you?
p. 42ANo, he did not.
p. 42QI'd like to introduce as minority exhibit A an email chain between you and Mr. Epstein starting on August 27th, 2009. The Bates number is EFTA02436302. [Staley Minority Exhibit A. was marked for identification.] BY :
p. 43QIn the second email of the chain, you tell Mr. Epstein that you will be in London that week. Mr. Epstein responds, quote, "Do you need anything there?" And you reply, quote, "Yep."
p. 43Mr. Sullivan.This is one document, right? One page? . Correct, it's one page. BY :
p. 43QWhat did you understand Mr. Epstein to mean by, quote, "Do you need anything there?"
p. 43AI don't recall. I mean, I go to London on business a lot. He was very connected in London. But I don't know specifically -- I don't recall specifically what it was in 2009.
p. 43QIt does appear that he's offering you something, though, correct?
p. 43AI think he's just asking if I needed anything there.
p. 43QSo offering you something. In replying, quote, "Yep," you were affirming that you did need whatever Mr. Epstein was offering, correct?
p. 43AI don't know what he was offering.
p. 43QSure. But he's sending you an email asking you a question, quote, "Do you need anything there?" And you respond, quote, "Yep." So, regardless of what he was offering, you are indicating that you do, in fact, need that thing.
p. 43AYeah. He used to set up business with people from the Treasury, people from the royal family -- lots of things he used to set up.
p. 43QBut you are indicating that you, in fact, need that thing. You are responding, quote, "Yep."
p. 44AYes.
p. 44QI would like to introduce as minority exhibit B an email from Mr. Epstein to a redacted individual dated September 2nd, 2009, just 3 days after you responded to Mr. Epstein's email with, quote, "Yep." The Bates number is EFTA00883896. [Staley Minority Exhibit B. was marked for identification.] BY :
p. 44QIn the email, Mr. Epstein says, quote, "Jes Staley is staying at the Berkeley Hotel in London tonight." I can represent to you based on in camera review of the unredacted version of this document that this individual is a young woman from Eastern Europe. Did you ask Mr. Epstein to email this young woman your hotel information?
p. 44AWhere do you know that's a young woman from?
p. 44QExcuse me? I didn't catch that.
p. 44AWhere do you know that it's a young woman from?
p. 44QBased on in camera review of the unredacted version of this document.
p. 44AAsk the question again.
p. 44QDid you ask Mr. Epstein to email this young woman your hotel information?
p. 44ANo.
p. 44QDid Mr. Epstein tell you that he was emailing this young woman your hotel information?
p. 44ANo.
p. 44QIs that something that he had done previously?
p. 44ANo.
p. 44QWhy do you think that Mr. Epstein shared your hotel information with this young woman?
p. 45AI don't know.
p. 45QWas it because Mr. Epstein was instructing this young woman to go to your hotel and have sex with you?
p. 45ANo. I don't know.
p. 45QYou don't know, or no?
p. 45ANo. I mean, I did not have an encounter with the young woman in a hotel when the --
p. 45QBut your answer to my question, was it because Mr. Epstein was instructing this young woman to go to your hotel and have sex with you -- is your answer "no" --
p. 45ANo.
p. 45Q-- or "I don't know"?
p. 45ANo.
p. 45QHow would you know --
p. 45AOh, sorry. No.
p. 45Q-- that Mr. Epstein hadn't --
p. 45ACan you ask the question again? Sorry.
p. 45QI asked you why you thought Mr. Epstein shared your hotel information with this young woman. I believe you said you did not know. I then asked you, was it because Mr. Epstein was instructing this young woman to go to your hotel and have sex with you?
p. 45AI don't know.
p. 45QDid Mr. Epstein otherwise introduce you to young women from Eastern Europe when you were in London?
p. 45ANo.
p. 45QNever?
p. 46ANever.
p. 46QDid Mr. Epstein ever send women or girls to your hotel or wherever you were staying on any other occasion?
p. 46ANo.
p. 46QI'd like to introduce as minority exhibit C an email exchange between Mr. Epstein and Andrew Mountbatten-Windsor from June 14th, 2010. The Bates number is EFTA01812700. [Staley Minority Exhibit C. was marked for identification.] BY :
p. 46QIn the first email of the chain, Mr. Epstein says, quote -- this is at the very bottom -- he says, quote, "If you can find time to show Jes around with [redacted], that would be fun. He told me he ran into you tonight." Mr. Mountbatten-Windsor confirms that the two of you saw each other and then asks Mr. Epstein who "redacted" is. Mr. Epstein responds, quote, "A great friend of mine, very pretty. She is my future ex-wife. I know Jes and she would love to see home." The next day, June 15th, Mr. Mountbatten-Windsor complains to Mr. Epstein that the woman did not respond to his email and notes that he is having dinner with you the following evening. Mr. Epstein replies by giving Mr. Mountbatten-Windsor the woman's phone number and telling him that she is expecting his call. I can represent to you based on in camera review of the unredacted version of this document that the person Mr. Epstein calls his "future ex-wife" is another young woman from Eastern Europe, a different young woman than the one we just discussed. Did you meet this woman?
p. 46ANo.
p. 47QDid Mr. Mountbatten-Windsor show you around London? This was in June of 2010.
p. 47AAround London? No.
p. 47QDid Mr. Mountbatten-Windsor give you a tour of his home?
p. 47AI visited the palace. I thought it was just by myself. I didn't recall him joining or being there.
p. 47QDo you remember when you visited the palace?
p. 47ANot -- not exactly, no.
p. 47QDo you have a year?
p. 47ANo, but I know I went once.
p. 47QAnd that's Buckingham Palace, correct?
p. 47AYes.
p. 47QAnd your recollection is that you visited but you weren't with Mr. Mountbatten-Windsor?
p. 47AThat's my recollection. Because my recollection is, I went by taxi, and I just -- I just recall it because the taxi driver was quite taken aback that he was going into Buckingham Palace.
p. 47QSo your recollection is that you weren't with Mr. Mountbatten-Windsor when you toured Buckingham Palace and he did not otherwise show you around London.
p. 47AThat's correct.
p. 47QAnd the two of you for -- or you, rather, for either one of those activities, you were not joined by a young woman from Eastern Europe.
p. 47AThat's correct.
p. 47QI'd like to introduce as minority exhibit D an email --
p. 47ACan I make one clarification?
p. 47QSure.
p. 47AYears later, when I was working in London, I went to the palace on a couple of occasions.
p. 48QAnd that is separate from the tour that you also recollect?
p. 48AYes.
p. 48QBecause those were visits and not a tour?
p. 48AThose were professional visits to the palace in my role with Barclays.
p. 48QAnd when you say "years later," when was that?
p. 48AThat would've been from 2015 to 2021.
p. 48QSo the tour that you remember would've been some point before 2015?
p. 48AYes.
p. 48QI'd like to introduce as minority exhibit D an email chain between you and Mr. Epstein from the following day, June 16th, 2010. The Bates number is EFTA01300635. [Staley Minority Exhibit D. was marked for identification.] BY
p. 48QIn the first email, you write, quote, "Is she free tonight?", to which Mr. Epstein responds just 2 minutes later, quote, "Call me." Who is "she"?
p. 48AI don't know.
p. 48QCould it be the same woman from Eastern Europe who Mr. Epstein and Mr. Mountbatten-Windsor were emailing about earlier?
p. 48AI don't know.
p. 48QWhy would you be asking Mr. Epstein if a woman was free?
p. 48AAgain, I don't recall this email.
p. 48QI understand you don't recall the email, but why would you ask Mr. Epstein if a woman was free?
p. 49AI'm not going to speculate.
p. 49QDid you call Mr. Epstein in response to his email?
p. 49AI don't recall.
p. 49QWould you have typically called Mr. Epstein when he asked you to call him?
p. 49AYes.
p. 49QSo you might have.
p. 49AI might have. But this is 16 years ago.
p. 49QA few hours later, you respond, "I'm with A." Is "A" Andrew Mountbatten-Windsor?
p. 49AIt seems like it.
p. 49QWhat did that have to do with the previous conversation that you were having with Mr. Epstein?
p. 49AI don't know.
p. 49QBecause you asked Mr. Epstein if a woman was free. He says, "Call me." And then later you say, "I'm with A." So it would seem like those two things are connected, right?
p. 49ADon't know.
p. 49QWere the two of you having dinner, as Mr. Mountbatten-Windsor had noted for Mr. Epstein the day prior?
p. 49AIt seems like it.
p. 49QDo you remember that dinner?
p. 49ANo.
p. 49QDo you remember having dinners with Mr. Mountbatten-Windsor generally?
p. 49ANo.
p. 49QYou don't have any recollection of any dinner with Mr. Mountbatten-Windsor?
p. 49AI don't think I had dinners with Mount- -- with Prince Andrew.
p. 49QSo, when Mr. Mountbatten-Windsor tells Mr. Epstein the two of you are having dinner together, he's --
p. 50AIt's possible.
p. 50Q-- wrong?
p. 50ANo.
p. 50QYou just don't remember.
p. 50AThat's correct. BY
p. 51QDo you remember if you were ever joined by any young women from Eastern Europe?
p. 51ANo.
p. 51QBased on these documents, it looks like Mr. Epstein introduced a young woman from Eastern Europe to you and Mr. Mountbatten-Windsor. Your testimony today is that you don't remember if that happened, correct?
p. 51AThat's correct.
p. 51QBut it could have?
p. 51AI don't remember.
p. 51QI'd like to discuss a series of emails that you were asked about in the prior round. I know you've answered some questions about these, but I have some followup questions for you. I'd like to introduce as minority exhibit E an email chain between you and Mr. Epstein from July 9th, 2010. The Bates number is EFTAOO894090. [Staley Minority Exhibit E. was marked for identification.] BY :
p. 51QIn the first email, you write to Mr. Epstein, quote, "That was fun. Say hi to Snow White." Mr. Epstein responds, quote, "What character would you like next?", to which you reply, quote, "Beauty and the Beast." Mr. Epstein then says, quote, "Well, one side is available." You said in the prior round that you have no idea who this person is -- specifically, who "Snow White" is. Is that correct?
p. 51AThat's correct.
p. 51QI'd like to introduce as minority exhibit F an email from the next day, July 10th, 2010. The Bates number is EFTA00741531. [Staley Minority Exhibit F. was marked for identification.] BY :
p. 52QThe email is from a redacted individual to Mr. Epstein, saying, quote, "The Snow White was f..ed twice as soon as she put her costume." To be clear, that word is spelled f-dot-dot-e-d, but we understand it to mean "fucked." Mr. Staley, was the Snow White who you referred to in your email the day before a young woman in a Snow White costume that Mr. Epstein arranged for you to have sex with?
p. 52AAgain, I don't recall a Snow White individual. So the answer would be no.
p. 52QDid you ever have sex with a young woman in a Snow White costume?
p. 52ANo, I did not.
p. 52QNever?
p. 52ANever.
p. 52QWhy would this young woman have sent this email to Mr. Epstein if the two of you had not had sex while she was wearing a Snow White costume and if Mr. Epstein had not instructed her to do so?
p. 52AI have no idea who else she was with. I -- it has nothing to do with me, though.
p. 52QBut you sent an email to Mr. Epstein on July 9th.
p. 52AAs I said, I may have -- this is in his apartment. I may have seen her in apartment and prompted that email. But I was not with a person dressed as Snow White outside of potentially crossing at his apartment.
p. 52QSo you may have seen her in his apartment, later emailed Mr. Epstein and said, "That was fun," but it was not because you had sex with her?
p. 52AThat's correct.
p. 52QWhy would you have asked Mr. Epstein to say hi to her then?
p. 53AMaybe I -- you know, again, I probably crossed her in his apartment and -- I don't know. Just, say hi.
p. 53QAnd then she emails him the next day, saying, quote, "The Snow White was [fucked] twice as soon as she put [on] her costume." Would you agree that's a pretty incredible coincidence, that you email him on July 9th, saying, "That was fun, say hi to Snow White," and then she emails him the next day, reporting back on something that just didn't have anything to do with you?
p. 53ASure. Why not?
p. 53QThat's pretty hard to believe.
p. 53Mr. Sullivan.That's not a question. BY :
p. 53QI'd like to introduce as minority exhibit G an email chain between Mr. Epstein and a redacted person dated June 20th, 2010, about 2-1/2 weeks before you sent the email to Mr. Epstein telling him to say hi to Snow White. The Bates number is EFTA00735698. [Staley Minority Exhibit G. was marked for identification.] BY :
p. 53QIn the email chain, Mr. Epstein says, quote, "I would love to take photos of you in a Snow White costume. You can get it from the costume store." I can represent to you based on in camera review of the unredacted version of this document that this individual is the same individual who sent the email to Mr. Epstein about Snow White.
p. 53Mr. Sullivan.Excuse me. Forgive me. I'm confused. . Sure.
p. 53Mr. Sullivan.I think you -- I've lost track, but I think you said something that does not appear on the document. Am I right? Could you start again? It's only my confusion. I just didn't follow the question. . If you look at the first line of the email --
p. 54Mr. Sullivan."Brett Ratner" -- . -- Mr. Epstein is referring to "a big movie, Snow White." And then he says, quote, "I would love to take photos of you in a Snow White costume. You can get it from the costume store." Do you see it?
p. 54Mr. Sullivan.I do. BY :
p. 54QAnd I can represent to you that Mr. Epstein is sending that email to the same woman who sent the email to him saying that the Snow White was fucked. It appears, looking at all of these emails together, that Mr. Epstein told this young woman to buy a Snow White costume and then instructed her to have sex with you while wearing it. Your testimony today is that that did not happen, correct?
p. 54AWhere is he -- where is he instructing her to have sex with me?
p. 54QI said it appears, taking these emails together, that that is what is happening here. He sends this woman an email on June 20th, which is about 2-1/2 weeks before you send the email to him saying "say hi to Snow White," which is 1 day before she sends the email to him saying that the Snow White was fucked twice.
p. 54Mr. Sullivan.What is the question? BY :
p. 54QTaken together, based on these emails, it appears that Mr. Epstein told this young woman to buy a Snow White costume and then instructed her to have sex with you while wearing it.
p. 54AI think that is speculation on your part.
p. 54QYour testimony is that that is not what happened?
p. 55AThat's my testimony.
p. 55QMr. Staley, you've previously said that you only had sex with one woman connected to Mr. Epstein.
p. 55AThat's correct.
p. 55QWould you like to correct that statement?
p. 55ANo.
p. 55QYou previously testified that, between July 2009 and the end of 2012, you went to Mr. Epstein's New York home approximately 40 times or about once a month. Is that correct?
p. 55AYes.
p. 55QWhen you visited Mr. Epstein's New York home, did you see girls or young women in the home?
p. 55ANo.
p. 55QWere there ever girls or young women in the room when you would meet with Mr. Epstein?
p. 55ANo.
p. 55QWere there ever girls or young women sitting on his lap when you would talk to Mr. Epstein?
p. 55ANo.
p. 55QWhen you visited Mr. Epstein's New York home, did you ever go to the massage room?
p. 55ANo.
p. 55QYou testified previously that you did see the room, though, correct?
p. 55AYes.
p. 55QAnd you said that was part of a tour that you took of the home?
p. 55AYes.
p. 55QSo you saw the room but you did not walk in it?
p. 56AYes.
p. 56QWhat did you see in the massage room?
p. 56AAgain, I just saw -- like, it was a dark wall, but I don't -- I didn't really see anything in the room.
p. 56QWas there a massage table?
p. 56AI don't recall.
p. 56QWas there a basket of vibrators?
p. 56AI didn't see that.
p. 56QYou previously said that you did not receive a massage in the massage room. Is that correct?
p. 56AThat's correct.
p. 56QDid Mr. Epstein ever arrange massages for you anywhere else?
p. 56ANo, he did not.
p. 56QHow many allegations of sexual abuse have been made against you?
p. 56AI think in the lawsuit against J.P. Morgan there was one allegation, but I ne- -- it was never -- it was never filed with me.
p. 56QSo that allegation is the only one that you're aware of?
p. 56AYes.
p. 56QHow many women have you settled sexual abuse claims with or otherwise entered into NDAs with?
p. 56ANone.
p. 56QDid you ever make payments to women that you had sexual relationships with?
p. 56ANo.
p. 56QHave you ever paid or attempted to pay a minor girl for sex?
p. 56ANo.
p. 57QI'd like to introduce as minority exhibit H a memorandum to the U.S. attorney for the Southern District of New York from assistant U.S. attorneys dated December 19th, 2019. The Bates number is EFTA02731082. [Staley Minority Exhibit H. was marked for identification.] BY :
p. 57QThe document that we are handing you is an excerpt of a larger document. We have marked the relevant paragraph for you. . On the last page. BY :
p. 57QThe memorandum describes law enforcement's October 24th, 2019, interview with a survivor who Mr. Epstein started sexually abusing when she was about 20 years old. As detailed in the memorandum, the survivor told law enforcement that Mr. Epstein instructed her to, quote, "provide a massage to Jes Staley in Epstein's New York residence." The memorandum says that, quote, "[Redacted] attempted to give him an ordinary massage, but he forced [redacted] to touch his genitals and then raped [redacted]. Afterwards, [redacted] complained to Epstein, who said he left it to [redacted] and Staley to decide whether to engage in sex." These were the allegations that you were referring to previously, correct? Or these are different allegations?
p. 57Mr. Sullivan.He can't answer that because it would require knowledge from counsel (ph), but it's the same woman that testified in the J.P. Morgan case that made a complaint to the New York U.S. attorney which was not found credible. BY :
p. 57QDid you ever force the woman to touch your genitals in the context of a massage?
p. 58ANo.
p. 58QDid you ever sexually abuse, assault, or rape a woman in the context of a massage?
p. 58ANo.
p. 58QWere you ever violent with a woman in the context of a massage?
p. 58ANo.
p. 58QI'd like to introduce as minority exhibit I an opinion in the class action that survivors of Mr. Epstein's abuse brought against J.P. Morgan. [Staley Minority Exhibit I. was marked for identification.] BY :
p. 58QThe document we are handing you is an excerpt of a larger document. On page 7, the second full paragraph reads, quote, "Plaintiffs allege that Mr. Staley had first-hand knowledge of Jeffrey Epstein's sex-trafficking operation. Mr. Staley is alleged to have visited Epstein's residences several times while that operation was ongoing and, during these visits, observed JPM Jane Doe 'as a sexual trafficking and abuse victim.'" On page 8, the first full paragraph reads, quote, "Plaintiffs further allege that Mr. Staley himself abused some of Epstein's victims, including JPM Jane Doe herself. JPM Jane Doe claims that 'one of Mr. Epstein's friends' -- whom she later identified as Mr. Staley -- 'used aggressive force in his sexual assault of her and informed [JPM Jane Doe] that he had Epstein's permission to do what he wanted to her.'" Did you sexually abuse and assault girls or women that you met through Mr. Epstein?
p. 58ANo.
p. 58QDid you ever tell a girl or a woman who Mr. Epstein abused or trafficked that you had Mr. Epstein's permission to, quote, "do what you wanted with her"?
p. 58ANo.
p. 59QMr. Staley, we have credible information that you have aggressively, even violently, sexually assaulted multiple women connected to Mr. Epstein. We are concerned that you are not being truthful in your answers. Are there any statements that you have made today that you would like to correct for the record?
p. 59ANo. With that, we'll pause and go to Members for questions.
p. 59Ms. Ansari.As you know, while he was in jail at the Palm Beach stockade, Mr. Epstein was allowed to leave the stockade for 12 hours a day, 6 days a week, ostensibly to work for his organization, the Florida Science Foundation, as part of the work release that he secured. Were you aware at the time that Mr. Epstein established the Florida Science Foundation in November of 2007 just months before he pleaded guilty and that he dissolved it soon after his sentence was completed?
p. 59Mr. Staley.No. I knew he used an office building on work release when he was in jail in Florida, but I didn't know how he constructed it and whatnot.
p. 59Ms. Ansari.So you weren't aware of the details of the foundation that was created. When did you become aware of the timeline in terms of the office that he used?
p. 59Mr. Staley.I think he told me that he was on work release and -- so -- I was -- I traveled a lot, and one time we found a date where he was on work release and I could visit him in his office building.
p. 59Ms. Ansari.So, to be clear, were you aware that there was a Florida Science Foundation?
p. 59Mr. Staley.No, I was not.
p. 59Ms. Ansari.You were never aware of that?
p. 59Mr. Staley.There was a Florida Science Foundation? No.
p. 59Ms. Ansari.Yes. That is the organization that he created. So --
p. 60Mr. Staley.No, I wasn't.
p. 60Ms. Ansari.-- you were not aware? Okay. Regardless of that, did you have any concerns about the fact that he was able to get work release and go to an office for that many hours per day?
p. 60Mr. Staley.No.
p. 60Ms. Ansari.Are you aware now that some survivors have stated that Mr. Epstein abused them at the Florida Science Foundation offices?
p. 60Mr. Staley.No.
p. 60Ms. Ansari.Are you aware that some of the women were hired as Florida Science Foundation staff?
p. 60Mr. Staley.No.
p. 60Ms. Ansari.So, to this day, you have never heard that, even though there's been public testimony?
p. 60Mr. Staley.No.
p. 60Ms. Ansari.Okay. One of those women told this Committee that, quote, "Jeffrey offered me a position at the Florida Science Foundation to handle phone calls to help with my financial troubles. One day, his masseuse called me into a room, where I was molested by Epstein. For the following 3 years, I was subject to ongoing rape and stripped of my dignity. Jeffrey Epstein was under house arrest for the molestation of underage girls at the exact same time that he was abusing me." Mr. Staley, you visited Mr. Epstein while he was on work release in Florida. Is that correct?
p. 60Mr. Staley.Once.
p. 60Ms. Ansari.Once. Why did you visit him there?
p. 60Mr. Staley.He was in jail and serving time for his offense that he pleaded to.
p. 60Ms. Ansari.Uh-huh.
p. 61Mr. Staley.I had known him for a number of years and -- and decided that I should go visit him and did.
p. 61Ms. Ansari.So it was a friendly visit?
p. 61Mr. Staley.Yeah, I mean, it was -- yeah.
p. 61Ms. Ansari.Do you recall how long you were there?
p. 61Mr. Staley.There was a sheriff there, and it lasted -- I think I was there for --
p. 61Ms. Ansari.At the office or at the jail?
p. 61Mr. Staley.At the office.
p. 61Ms. Ansari.Okay.
p. 61Mr. Staley.And I was there for less than an hour.
p. 61Ms. Ansari.Did you participate in sexual abuse of any women at the Florida Science Foundation offices?
p. 61Mr. Staley.No. And, again, there was a police officer there while I was there.
p. 61Ms. Ansari.And were you aware that Mr. Epstein was sexually abusing women at those offices?
p. 61Mr. Staley.No. It seemed incredible to me that if he is in jail for offenses that he would do something like that.
p. 61Ms. Ansari.Okay. That's my questions. Thank you.
p. 61Ms. Stansbury.One quick followup on Representative Ansari's questions. You visited the office of the Florida Science Foundation, correct?
p. 61Mr. Staley.I didn't realize what the Florida Science Foundation -- but I visited Epstein in an office building, correct.
p. 61Ms. Stansbury.Okay. So your testimony is that you visited him in an office building for some organization that you had no knowledge of and were generally unaware of.
p. 62Mr. Staley.That's correct.
p. 62Ms. Stansbury.Okay. Can I ask a quick followup? Sorry. So I guess what I'm struggling with is generally to understand your testimony. So the incident that was just described by Rep. Ansari happened in 2007, and the --
p. 62The Reporter.The microphone.
p. 62Ms. Stansbury.Okay. Oh, I'm sorry. Okay. This is just a quick followup question. So, in terms of the incident that was just described by Representative Ansari of your visit to the Florida Science Center, happened in 2007. And your testimony that you just gave is that you remember it was less than an hour, you remember who was present, including a sheriff, correct?
p. 62Mr. Staley.That's why I don't -- whether we're talking about the same visit. Because he was incarce- --
p. 62Mr. Sullivan.Excuse me. Excuse me. He could not have been in jail in 2007. He had not pled guilty until July of 2008.
p. 62Ms. Stansbury.Oh, okay, 2008. So 20- -- what -- but the date is 2007 or 2008.
p. 62Mr. Staley.No --
p. 62Ms. Stansbury.But yet the incidents --
p. 62Mr. Sullivan.Listen -- I'm sorry. I'm --
p. 62Ms. Stansbury.But the followup question that I'm asking is actually not about that incident. It's more to establish the relevance that you recall the location, you recall the setting, you recall the persons who were present. But when you were asked extensively by our counsel about these incidents involving young women, including the so-called Snow White person, which happened years later in 2010, you're claiming you have no knowledge and no memory of these exchanges that you had with Mr. Epstein and engagement with these women?
p. 63Mr. Staley.Again, that's a long question. So I met in an office building in Florida, I believe it was 2009. But I have -- I do not have any recollection of Snow White.
p. 63Ms. Stansbury.But your testimony here today is that you --
p. 63Mr. Staley.No. So --
p. 63Ms. Stansbury.-- clearly remember an incident in which --
p. 63Mr. Staley.And, again, when I was at the office building with Epstein in 2009, there was a sheriff --
p. 63Ms. Stansbury.Yes.
p. 63Mr. Staley.-- in the same office the whole time.
p. 63Ms. Stansbury.But the question is about your memory. You're claiming that you can remember this interaction you had with Mr. Epstein when you went and made a friendly visit while he was doing his sentence, but you have no recollection of these emails and exchanges you had over a woman that was referenced as "Snow White" years later? That's your testimony here today?
p. 63Mr. Staley.Yes, it is.
p. 63Ms. Stansbury.Okay. That's ridiculous. But thank you.
p. 63Mr. Subramanyam.Thank you for coming in today. Were you personally involved in conversations related to whether Jeffrey Epstein was a bank of -- a client of the bank?
p. 63Mr. Staley.Yes.
p. 63Mr. Subramanyam.Did you actively defend him when he was trying to get accounts?
p. 63Mr. Staley.No. I left it to the bank's compliance department, legal department, and Private Bank to determine whether he maintained an account.
p. 64Mr. Subramanyam.So at no point did you ever tell your colleagues that you vouched for him in any way or that you support him opening different accounts at the bank?
p. 64Mr. Staley.I went to visit him when allegations came out in 2006, and I said he was -- appeared shocked and he denied the ages. But I let the bank and its compliance department, legal department, and the Private Bank determine what and what type of business Epstein would continue to do with the bank or not.
p. 64Mr. Subramanyam.But at no point did you ever say, we should bank this guy, we should let him open accounts, and, you know, what he did in the past shouldn't play into that?
p. 64Mr. Staley.The bank dramatically restricted what it would do with -- and what it would allow Epstein to do with the bank, and I, you know, supported what the bank's decision was.
p. 64Mr. Subramanyam.And the bank restricted it based on what criteria? Why would the bank restrict him?
p. 64Mr. Staley.I think, given his -- given what he was charged with, the bank, you know, made the decision to no longer, basically, allow him to engage with the Private Bank in investment activities, which is principally what they do. And I supported that decision.
p. 64Mr. Subramanyam.But what was he allowed to do with the bank?
p. 64Mr. Staley.I think, basically, what he was left with was simply a checking account.
p. 64Mr. Subramanyam.A checking account. And did you ever speak to Mr. Jamie Dimon about Mr. Epstein?
p. 64Mr. Staley.Yes.
p. 64Mr. Subramanyam.When was that?
p. 64Mr. Staley.I believe once in 2006 when Epstein was indicted, and I believe once in 2008 when Epstein went to jail.
p. 64Mr. Subramanyam.And did you speak to him about Mr. Epstein's charges?
p. 64Mr. Staley.Mr. Epstein's --
p. 65Mr. Subramanyam.Did you speak to Mr. Dimon about Mr. Epstein's charges?
p. 65Mr. Staley.Again, I think I -- in 2006, I think I just mentioned that a client of the bank, Jeffrey Epstein, had been indicted.
p. 65Mr. Subramanyam.So you did not speak to Mr. Dimon -- because I believe you've said under oath that you've spoken to him about the fact that Mr. Epstein pleaded guilty to one count of soliciting prostitution and one count of soliciting prostitution from a minor. Do you --
p. 65Mr. Staley.That was -- the was the second conversation.
p. 65Mr. Subramanyam.That was the second conversation? So you did talk to him. So -- because Mr. Dimon had said under oath that he does not recall knowing anything about Mr. Epstein until Federal prosecutors charged Mr. Epstein with sex trafficking in 2019. So I'm just trying to understand why there's two recollections here.
p. 65Mr. Staley.I don't know.
p. 65Mr. Subramanyam.Okay. That's all of my questions.
p. 65Mr. Walkinshaw.Thank you, Mr. Staley. I'm James Walkinshaw from Virginia's 11th District. The New York Times reported last year that, in 2011, you informed Mr. Epstein that there were concerns inside J.P. Morgan about his large and regular cash withdrawals. Did you talk to Mr. Epstein about those concerns that existed within J.P. Morgan about his large cash withdrawals?
p. 65Mr. Staley.Do you have -- can I see a transcript of that? Or --
p. 65Mr. Walkinshaw.Yeah. I don't know -- what is the exhibit number? I think we have the -- exhibit J, a September 8, 2025, New York Times article, "How JPMorgan Enabled the Crimes of Jeffrey Epstein." [Staley Minority Exhibit J. was marked for identification.]
p. 66Mr. Walkinshaw.And my pages aren't numbered, but it's page -- page 23. See the paragraph on page 23 at the -- it's the first full paragraph, "At the request of Langford and other executives"? Oh, I'm sorry. Is that the wrong one? Yeah, I'm sorry. The paragraph starts, "Staley and at least one other executive alerted Epstein."
p. 66Mr. Sullivan.I think he wants you to read this.
p. 66Mr. Staley.Yeah. Let me read the -- yeah. . If you need a few minutes to read it, we can go off the record.
p. 66Mr. Staley.Okay. Thank you. . We'll go off the record now. [Discussion off the record.] [12:17 p.m.] . We are back on the record.
p. 67Mr. Walkinshaw.Okay. Mr. Staley, in or around 2011, did you alert Mr. Epstein about J.P. Morgan's heightened sensitivity about his constant cash withdrawals?
p. 67Mr. Staley.That's what this article says, yes.
p. 67Mr. Walkinshaw.Do you recall alerting him to that heightened sensitivity?
p. 67Mr. Staley.Again, I don't recall the actual engagement, but quite possibly, yes.
p. 67Mr. Walkinshaw.Okay. So --
p. 67Mr. Staley.But I think I did, and I think Mary Erdoes did as well.
p. 67Mr. Walkinshaw.I'm sorry, can you say the name again?
p. 67Mr. Staley.I think I may have and Mary Erdoes.
p. 67Mr. Walkinshaw.Okay. So your testimony is you may have alerted Mr. Epstein to the bank's concern about the --
p. 67Mr. Staley.Yes, yes.
p. 67Mr. Walkinshaw.Okay. When you, perhaps, informed Mr. Epstein that the bank was concerned about these cash withdrawals, were you trying to help him alter his behavior to avoid additional scrutiny?
p. 67Mr. Staley.No.
p. 67Mr. Walkinshaw.What would have been your purpose of alerting him to this sensitivity within the bank about his cash withdrawals? Why would you have done it?
p. 67Mr. Staley.I was more sort of asking him, is that true?
p. 67Mr. Walkinshaw.Is -- well --
p. 67Mr. Staley.Was he taking, you know, large cash withdrawals.
p. 67Mr. Walkinshaw.So, presumably, though, your colleagues at the bank would have told you that he was making large cash withdrawals, so why would you need to ask him?
p. 68Mr. Staley.Just, I guess, rhetorically, saying that the bank is asking about large cash withdrawals.
p. 68Mr. Walkinshaw.Okay. But it wasn't for the purpose of helping him to change his behavior so there wouldn't be additional uncomfortable questions asked within the bank?
p. 68Mr. Staley.Again, I always let the private bank and -- you know, and its staff to -- if they had issues with Epstein, to take it with Epstein. If they had issues with his accounts, to do what they deemed to be appropriate. I never stood in the way of that.
p. 68Mr. Walkinshaw.But in this instance, you, perhaps, interfered?
p. 68Mr. Staley.I wouldn't call that interference. I was saying that the bank --
p. 68Mr. Walkinshaw.You made a decision to tell -- perhaps to tell him that there were concerns within the bank. You weren't allowing others within the bank to handle it.
p. 68Mr. Staley.No. I think other people -- as I said, I think Mary Erdoes talked to him as well.
p. 68Mr. Walkinshaw.Okay. By this time in 2011, there had been media reports that Mr. Epstein paid his victims in cash. Did you ever have conversations either with Mr. Epstein or with your colleagues at J.P. Morgan as to the fact that perhaps Mr. Epstein was paying sexual abuse victims with these cash withdrawals that you discussed with him?
p. 68Mr. Staley.No.
p. 68Mr. Walkinshaw.Did it ever cross your mind that perhaps these large cash withdrawals that you were aware of were related to either sexual abuse or him having sex with girls or young women?
p. 68Mr. Staley.You know, you can go to jail for, you know, a year and you've been convicted of abusing minors, it's just incredible to me that he would continue to do it after he got out of jail.
p. 68Mr. Walkinshaw.At this point, you're a senior executive at J.P. Morgan. I presume over the course of your career, you attended trainings, briefings, with respect to the role of banks and large cash withdrawals in human trafficking and sex trafficking. Is that correct?
p. 69Mr. Staley.I was sensitive to large cash withdrawals, yes.
p. 69Mr. Walkinshaw.Okay. So you have Jeffrey Epstein, who is a convicted sex offender, you then have knowledge he's making large cash withdrawals, you see him regularly in the presence of young women --
p. 69Mr. Staley.No.
p. 69Mr. Walkinshaw.-- and it never once crossed your mind that these large cash withdrawals might have been connected to any of the women that you saw in his presence?
p. 69Mr. Staley.Again, I did not see young women in his presence, so that part of your question, I think, is unfair.
p. 69Mr. Walkinshaw.How would you define young women?
p. 69Mr. Staley.Again, what I -- I saw him with his assistants, and I would say they were in their late 20s, early 30s.
p. 69Mr. Walkinshaw.Okay. That's my time. Thank you. . We'll go off the record. [Recess.] [12:57 p.m.]
p. 70Mr. Ashworth.I just want to correct the record real quick for something that a Member of the minority said outside to the press. There has not been any limitation on the scope of today's interview.
p. 70QMr. Staley, during the previous hour, you were asked if you had visited Little Saint James. Is that right?
p. 70AYes.
p. 70QYou were also asked if you had visited Great Saint James, correct?
p. 70ACorrect.
p. 70QAnd when you were asked about Great Saint James, you answered in the affirmative. Was that the correct testimony?
p. 70ANo. I misspoke. Great Saint -- I've never visited Great Saint James.
p. 70Mr. Emmer.Thank you.
p. 70QMr. Staley, you mentioned that you frequently visited Mr. Epstein's Manhattan town house at least dozens of times. For what purpose did you attend these meetings?
p. 70AGenerally, it would be on my way home. It would be to sit and talk with Epstein about what was going on both economically, politically, financial world, talked about what I was doing at the bank, talked about people that he introduced me to as part of his network. So general conversations around business and around the network that he had, and it was of interest to me.
p. 70QDid your meetings always take place at his Manhattan town home?
p. 70AYes.
p. 71QWhy?
p. 71AHe used his dining room there as his office. So oftentimes when I would go there, there would be other people there meeting with him. So that was generally where he met people.
p. 71QCan you list who else would have attended these meetings with you?
p. 71AWell, not with me, but that we would have crossed.
p. 71QYes.
p. 71APeople like Larry Summers, people like Sergey Brin, people like Ehud Barak. That type of people.
p. 71QTo clarify, were these people at the meeting or you would discuss them at the meetings?
p. 71AWe would cross. So I would come and Ehud Barak would be talking with Epstein. I would show up. We would sort of overlap for a bit of time and then Ehud Barak would leave. That -- it would be more of that type of engagement.
p. 71QDid anyone else attend the meetings with you and Mr. Epstein?
p. 71ANo.
p. 71QDid you ever see any young women around the Manhattan town house?
p. 71ANo, I did not.
p. 71QDid you ever see his assistants around the Manhattan town house?
p. 71AYes.
p. 71QWho?
p. 71ALesley Groff mostly, Sarah Kellen, Yeah, those would be the principal ones.
p. 71QDid you ever attend a party at his Manhattan town house?
p. 71AA party, no. I don't believe -- no, I never attended a party there.
p. 71QDid you ever have a drink at his Manhattan town house?
p. 71AYes. Sometimes he would serve me a glass of wine.
p. 72QDid you ever become intoxicated to the point where you would likely not remember things that happened today?
p. 72ANo.
p. 72QBefore, during, or after a meeting with Mr. Epstein, were you ever introduced to young women or girls?
p. 72ANo.
p. 72QI'm entering majority exhibit 6 into the record. This is an email from Lesley Groff to Mr. Epstein on September 23rd, 2014, with the Bates stamp EFTA00362214.
p. 72Ms. Brignac.And we'll go off the record so you can review. [Staley Exhibit No. 6. was marked for identification.]
p. 72QWe'll go back on the record. What were you meeting with Mr. Epstein about on September 23rd, 2014?
p. 72AI don't recall what the meeting was about. Seemed like I was just stopping by to say hi.
p. 72QDid any girls join you during a conversation with Mr. Epstein?
p. 72ANo.
p. 72QDid you see any girls before or after saying hello to Mr. Epstein?
p. 72ANo, I did not.
p. 72QDo you know who the BBB girls are?
p. 72ANo, I don't.
p. 72QWho is Barbro Ehnbom (ph)?
p. 72AI don't know.
p. 72QHas ever attended a meeting with you and Mr. Epstein?
p. 72AI don't know who that is.
p. 73QWe do have DOJ documents that reflect did attend a meeting with you and Mr. Epstein. Do you -- there was ever a meeting, do you recall where a young woman attended with you and Mr. Epstein?
p. 73AI don't know so I don't recall that, no.
p. 73QI'll now ask names that have been recorded in the press as attending Mr. Epstein's town house meetings. Can you confirm whether you were present for another individual's meeting with a yes or no?
p. 73AWhat individual?
p. 73QI'm going to give you a list of names and just give me a yes or no if you ever attended a meeting with this individual --
p. 73AOkay.
p. 73Q-- at Mr. Epstein's town house. Bill Gates?
p. 73AYes.
p. 73QSteve Bannon?
p. 73ANo.
p. 73QWoody Allen?
p. 73AWe crossed.
p. 73QPresident Bill Clinton?
p. 73ANo.
p. 73QNoam Chomsky?
p. 73AI don't know.
p. 73QTom Pritzker?
p. 73AYes.
p. 73QReid Hoffman?
p. 74ANo.
p. 74QMort Zuckerman?
p. 74AYes.
p. 74QDick Cavett?
p. 74ANo.
p. 74QEhud Barak?
p. 74AYes.
p. 74QLeon Black?
p. 74AYes.
p. 74QDid any of the individuals you just listed engage in sexual misconduct during these visits that you said yes to?
p. 74ANo.
p. 74QCan you describe the circumstances under which you met Bill Gates?
p. 74AI met Bill Gates a couple of times in Seattle when I was there on business trips. I met him at a conference I believe was hosted by Microsoft. That's my recollection of when I met him.
p. 74QWho introduced you to Mr. Gates?
p. 74AJeffrey Epstein.
p. 74QWas he a client of Mr. Epstein's?
p. 74AI don't know. I don't think so.
p. 74QDid he ever refer -- strike that. Did Mr. Epstein ever refer Bill Gates as a client to J.P. Morgan?
p. 74AI think Bill Gates was already a client of J.P. Morgan, my recollection, but -- but I'm not sure.
p. 74QWere you involved in Mr. Epstein's pitch to J.P. Morgan regarding the donor-advised fund for the Bill and Melinda Gates Foundation?
p. 75AYes.
p. 75QWhat was your role?
p. 75AI just was aware of it. I think it was being handled by Mary Erdoes.
p. 75QWhat was this fund?
p. 75AI think the idea was to create a fund for charity that where the Private Bank would approach high-net-worth individuals to participate in the fund, and Bill Gates would be a major sponsor of it.
p. 75QWas Mr. Epstein compensated by his work on this deal?
p. 75ANot by J.P. Morgan.
p. 75QWho would he -- was he compensated by anyone?
p. 75AI don't know. The deal never happened, so --
p. 75QWhy did the deal never happen?
p. 75AI just think it just never came together as a concept.
p. 75QHow did you meet Tom Pritzker?
p. 75AI think I just met Tom Pritzker. He's a client of the bank.
p. 75QDo you recall what you met with him about with Mr. Epstein?
p. 75AAgain, I'm not sure I met with Tom with Mr. Epstein. My recollection is I met with Tom Pritzker at their headquarters.
p. 75QDid you work with Mr. Epstein on any deal for Mr. Pritzker?
p. 75AI don't think so, no.
p. 75QThe Wall Street Journal has reported in March of 2026 that you divulged confidential information to Mr. Epstein regarding financial dealings that JPMorgan Chase was working on. What information did you divulge?
p. 75AWhat year?
p. 75QThis was reported in 2026, but the deal that they found was in 2008.
p. 76ADo you know which deal they're talking about?
p. 76QA deal for the Pritzker family.
p. 76AI don't -- no, I don't recall what the deal was.
p. 76QWould it be accurate to say that you divulged bank communications with the Federal Reserve on how to stabilize the financial system?
p. 76AYes.
p. 76QDid you divulge any other market-moving information to Mr. Epstein?
p. 76AAsk the question again. Sorry.
p. 76QDid you divulge any other market-moving information to Mr. Epstein?
p. 76AI don't think so, no.
p. 76QWould it be accurate to say you also divulged that J.P. Morgan was inundated by $44 billion in new assets within 2 weeks?
p. 76AThat's possible, yes.
p. 76QSo is there any other information that you divulged to Mr. Epstein?
p. 76AIt was a long time ago you're talking, so I apologize, I can't answer it.
p. 76QI would still like an answer to the question, though. Is there any other information that you divulged?
p. 76AThat I recall, no.
p. 76QDid you discuss J.P. Morgan salaries with Mr. Epstein?
p. 76AI discussed my salary with Mr. Epstein, yes.
p. 76QDid you understand at the time that sharing this information was in violation of your fiduciary duties to the bank?
p. 76ANo.
p. 76QWhy did you share this information to Mr. Epstein?
p. 76ATo get his thoughts and ideas about it.
p. 77QDid Mr. Epstein benefit from any of the information you divulged?
p. 77ANo. That I'm aware of, no.
p. 77QHow did you meet Mort Zuckerman?
p. 77AI think I met him through Jeffrey Epstein.
p. 77QWhy did he introduce you to Mort Zuckerman?
p. 77AI think he was thinking of doing -- of starting a publication with Mort Zuckerman. I think we just crossed.
p. 77QHow did you meet Ehud Barak?
p. 77AI met Ehud Barak at Jeffrey Epstein's town house, and then we met in Israel. We also may have met in Davos.
p. 77QDid you form a relationship with Mr. Barak after this introduction?
p. 77AMore when he and I met in Israel, we developed a relationship, but no. Yeah. But not -- I didn't stay in regular contact with him or something like that.
p. 77QHave you ever flown on any of Mr. Epstein's private aircraft?
p. 77AYes.
p. 77QHow many times?
p. 77AI think I flew on his 727 once. I think I flew on his Gulfstream plane once or twice.
p. 77QWhat were the occasions for this travel?
p. 77AI think once when we were going to his island with my family, I believe once was going to Miami. I think I flew by myself on that flight. That's what I recall.
p. 77QWho was present on the other flights?
p. 77AThe 727 flight?
p. 77QYes. You said on one occasion I flew alone. So who else was present on the other flights?
p. 77AMy family.
p. 78QOn how many trips was your family present with you on the travel?
p. 78AThe whole family, just one. Yeah, just one.
p. 78QWere members of your family present on other travels?
p. 78ANo. I think it was just the one travel to the Virgin Islands.
p. 78QWhy did they attend this trip?
p. 78AIt was just -- I think my family went, I think the Dubins went. It was just -- we were invited by Epstein to go to his island, so my family and I went for a couple days.
p. 78QThis was in February 2005, correct?
p. 78AI think that's right.
p. 78QDid you ever witness young women or girls while traveling on Mr. Epstein's plane?
p. 78ANo, I did not.
p. 78QDid you ever witness sexual activity on his plane?
p. 78ANo.
p. 78QHas Mr. Epstein ever flown on a private plane of yours?
p. 78AI've never owned a private plane.
p. 78QHave you ever heard of sexual activity taking place on Mr. Epstein's plane?
p. 78ANo.
p. 78QIn 2005, police in Palm Beach, Florida, began investigating Mr. Epstein for soliciting prostitution from minors. When did you first become aware of the investigation in 2005, 2006?
p. 78AI think when -- when it was printed in the Palm Beach Press.
p. 78QWhen would this have been?
p. 78AI'm not exactly sure. 2005, 2006.
p. 78QHave you -- strike that. Was JE ever on a plane leased or operated by you?
p. 79ANo.
p. 79QWas Jeffrey Epstein ever on a plane leased or operated by you?
p. 79AI've never leased or operated an airplane.
p. 79QSo you became aware of the investigation, you believe, sometime in 2005, 2006 when it was published in the press. What did you do next?
p. 79AI think -- I believe I went to his office and asked him. And I reported back to the bank that I went and asked him and reported that he was shocked, or he seemed shocked, that he denied the ages. And I reported that back in an email to the bank.
p. 79QWhat did you say that led you to find him credible in that moment?
p. 79AI've known Epstein for a number of years, and his reaction seemed to be genuine. But again, I just reported what I heard from him and saw to the bank so the bank had that.
p. 79QWho did you report it to at the bank?
p. 79AWell, I put it in an email. So I know it went to Mary Erdoes, but -- I may have also -- I may have also reported it to Langford, who I believe was a lawyer for the Private Bank at the time.
p. 79QWhat were their responses?
p. 79AI think my recollection is the bank had a group called the rapid response team at compliance, and they were responsible for, I think, reviewing things like this, and I believe the bank did review Epstein.
p. 79QAnd it published a report on this, correct, a rapid response report?
p. 79AI believe so.
p. 79QThere were internal discussions at this time. Who all participated in these discussions?
p. 79AI think it was members of the rapid response team. I think it's members from legal, from compliance, the people who ran his banking group, but I was not part of those meetings.
p. 79QWere you a part of any of the meetings?
p. 80AOf the rapid response team? Not that I recall, no.
p. 80QWhen you reported it to Mary Erdoes and --
p. 80ALangford.
p. 80Q-- Langford, what did you say?
p. 80AI said, this is -- this is something that -- I think both Mary and I said this is something very concerning, and let's let the bank look into it and decide what to do.
p. 80QWhy did they not part ways with Mr. Epstein at that time?
p. 80AMy understanding is the bank restricted his activities significantly within the bank. And while looking back, it may not seem as such, but back then that was a major move by the bank. And I think for that moment in time, that deemed sufficient withdrawal of the bank from Epstein's business activities.
p. 80QHow many meetings took place on this?
p. 80AI don't know how often the rapid response team met.
p. 80QFor the record, the committee has reviewed documents that reflect at least five to six meetings on this topic. In July 2006, Mr. --
p. 80AAlso, those rapid response meetings would also -- I think were filed with the Federal Government.
p. 80QThank you. In July 2006, Mr. Epstein was arrested for the first time for soliciting prostitution from minors. Did you discuss the allegations with Mr. Epstein?
p. 80AYes.
p. 80QCan you describe what happened in that conversation?
p. 80AAgain, he said he was shocked by the allegation, he denied it, and he denied the ages.
p. 80QPalm Beach Detective Joseph Recarey spoke out about his belief that Epstein was tipped off about the raid since multiple computers expected to be at the house were missing when the search warrant was executed. Did anyone tip off Mr. Epstein to this raid?
p. 81AI have no idea.
p. 81QDid you ever hear of anyone informing Mr. Epstein about the impending search warrant?
p. 81ANo.
p. 81QWere you surprised by his arrest?
p. 81ASure.
p. 81QWhy?
p. 81ABecause I had known Epstein for a number of years. Again, he was involved with things like the Highbridge Capital transaction, and someone who you know gets arrested for sex with a minor, that's shocking.
p. 81QWhat exactly did Mr. Epstein tell you had occurred that led to his arrest?
p. 81AI think there was press about victims reporting to authorities that they were victimized. I think that's what prompted it.
p. 81QBut did he tell you his side of the story --
p. 81ANo.
p. 81Q-- or did he tell you something different?
p. 81ANo.
p. 81QSo on his arrest, it's published in the press more people are becoming aware, did you begin to hear any rumors about his conduct with minors or young women?
p. 81AJust what I read in the press.
p. 82QBut did you discuss it with anyone else in your financial circles? Did any more information become available as you began to discuss it with others?
p. 82ASeparate from the press, I don't believe so.
p. 82QThe FCA says that they doubted you were surprised at the arrest given all of the reports and allegations that you were aware of by then.
p. 82AIn 2006?
p. 82QCorrect. The FCA found that the bank at large was well aware, and that by 2006, the reports and allegations he was facing caused them doubt to believe that you would have been surprised.
p. 82AAre you sure that's 2006? I think the bank was as surprised as I was.
p. 82QThe FCA said that by 2006, but definitely by 2010 --
p. 82AThat's --
p. 82Q-- J.P. Morgan was aware given Mary Erdoes' testimony.
p. 82AThat's 4 years. So let's ask the question in the context of 2010.
p. 82QSo my question to you is, why do you think the FCA stated that they doubt you were surprised by the allegations?
p. 82AI think in 2010, I would not have been surprised by the allegations.
p. 82QWhy?
p. 82AHe had gone to jail for it.
p. 82QSo at that time you did understand that he was soliciting prostitution from minors?
p. 82AHe had pleaded guilty, and he had gone jail.
p. 82QThank you.
p. 82Ms. Tolan.And just one quick follow-up on the rapid response meetings that we were discussing a moment ago. Why were you not part of that team or those meetings?
p. 82Mr. Staley.Because I was not part of the rapid response team. [Staley Majority Exhibit No. 7. was marked for identification.]
p. 83QI would like to enter into the record majority exhibit 7. This is an email exchange between you, Mr. Staley, and Mr. Epstein on November 1st, 2009. It is Bates stamped EFTA00768032.
p. 83Ms. Brignac.We'll go off the record to pass this out and give you a moment to review. We'll go back on the record.
p. 83QSo on November 1st, 2009, you emailed Mr. Epstein, "So when all hell breaks loose and the world is crumbling, I will come here and be at peace. Presently, I'm in the hot tub with a glass of white wine. This is an amazing place. Truly amazing. Next time we're here together. I owe you so much, and I deeply appreciate our friendship. I have few so profound." Mr. Staley, what prompted you to send this email?
p. 83AI believe this is when I visited his ranch. I was in Albuquerque on business, and my understanding was he had the largest ranch in the State of New Mexico. He was not there, but as I was going to travel home that day, I asked if I could stop by and see his ranch. There was a couple taking care of the ranch. I was there. They happened to have saddled a horse for me. I ride horses. So I went for a quick ride on a horse, got off, and I remember in the basement of the house was, like, a spa area with a big swimming pool. And I went there and -- to take a shower and change, and I believe there was a -- I took a shower and jumped into his hot tub. I think there was a mini bar, and I grabbed a glass of white wine, and I later sent him this email.
p. 83QWhat did you mean by, "I owe you so much"?
p. 84AYou know, he had been helpful in my career, he had done -- he was instrumental in the Highbridge transaction. He had given me, you know, advice along the way. And I was visiting this extraordinary ranch, and as I said, I use effusive language. And that's what I was doing.
p. 84QYou testified earlier that you understood that he did solicit prostitution from minors when he pled guilty. He pled guilty in 2008, and you sent this email in 2009. So why did you maintain your friendship with Mr. Epstein who had solicited prostitution from minors?
p. 84AAgain, it's inconceivable to me that he would have continued, and I thought he had paid his fine. He had gone to jail. My expectation was he would have reformed himself. And so I maintained the relationship because he had done a number of viable things to me in my career.
p. 84QSo you maintained your relationship with a sex offender because he did valuable things to your career --
p. 84AI thought it was a one-off event. And so, I did not think that he was a -- I'll leave it at that.
p. 84QWhy did you believe he would reform himself?
p. 84ABecause I would think if you would go -- if you spent time in jail, the last thing you would do is repeat the behavior that put you into jail.
p. 84QMr. Staley, you seem to have great recollection about this ranch and all of the events that took place there in 2009, but you cannot remember the Snow White events of July 2010 based on your memory. Can you help reconcile my confusion on this?
p. 84AOne thing, getting in the car, driving an hour, going to a ranch, riding on a horse, seeing a whole new environment, you know, using the spa, the whole thing surrounding it, that was -- as opposed to someone who apparently I crossed, you know, for a few minutes, I think, is quite a difference.
p. 85QDo you normally see young women in Halloween costumes at your friends' houses?
p. 85AAgain, I don't recall that I met someone in a Halloween costume.
p. 85QBut you said you may have?
p. 85AI don't --
p. 85QThat's not an event you recall?
p. 85AI don't remember seeing a Snow White.
p. 85Ms. Tolan.And when you visited his ranch, did you see anyone else there besides the couple who worked there?
p. 85Mr. Staley.No. Just the couple and the horse.
p. 85QOn your visits to any of Mr. Epstein's properties, did you see anything unusual?
p. 85ANo.
p. 85QIt's been reported that Mr. Epstein kept nude photographs in his home. Did you ever see nude photographs?
p. 85ANo.
p. 85QDid you ever see unusual artwork?
p. 85AYes.
p. 85QWhat did you see?
p. 85AThe one that stands out is he had a painting of someone reclining in a chair with, like, sort of a dress on with the head of President Clinton.
p. 85QDo you know why he had this photograph?
p. 85ANo.
p. 85QDid you ever ask about it?
p. 85AI think he saw it as sort of a joke.
p. 85QIn prior sworn testimony you've stated that over 25 individuals and entities were referred to the bank by Mr. Epstein, to include Sergey Brin, Google, Sultan Ahmed bin Sulayem, Ehud Barak, Peter Mandelson, Mort Zuckerman, LeFrak family (ph), Highbridge Capital Management, Glenn Dubin, Eva Dubin, Andrew Farkas, Kathryn Ruemmler, Bill Gates, Leon Black, Boris Nikolic, David Gergen, Larry Summers, Nathan Myhrvold, Kimbal Musk, Elon Musk, Les Wexner, Bill Richardson, and George Mitchell. Is that correct?
p. 86AYes.
p. 86QDid Mr. Epstein also facilitate meetings between individuals at J.P. Morgan with Andrew Mountbatten-Windsor, formerly known as Prince Andrew?
p. 86AI don't believe so.
p. 86QI believe you previously testified that he did.
p. 86AThat he did.
p. 86QIs your testimony --
p. 86ASo ask the question again. Sorry.
p. 86Q-- different today? Has Mr. Epstein facilitated meetings between individuals at J.P. Morgan with Andrew Mountbatten-Windsor, formerly known as Prince Andrew?
p. 86AYes. Sorry. Apologize.
p. 86QThank you. Why did Mr. Epstein refer these clients to J.P. Morgan?
p. 86AI think it was part of him building out his network, and I think -- in hindsight, I think what he was doing was -- you know, we thought that he was introducing us to these people as -- to help J.P. Morgan. And I think he was showing to these individuals that he was connected to J.P. Morgan to build his credibility.
p. 86QDid all of these referrals eventually become clients of J.P. Morgan?
p. 86AI think many of them were already clients, actually, and some of them became clients, yes. Like Larry and Sergey Brin of Google became clients on the back of that.
p. 87QDid you benefit from any of these client referrals?
p. 87AI mean, if you're running the Private Bank and you get introduced to three of the five wealthiest men potentially in the world, yeah, that's a valuable thing.
p. 87QBut did it actually benefit you in your career? Did you realize any benefit in your career?
p. 87ABeyond what it reflected in the Private Bank. I didn't personally get something individually because -- like, there's no finder's fee or something like that, if that's what you're referring to.
p. 87QThere's no monetary benefit?
p. 87ANo, no.
p. 87QDid you manage the clients' accounts?
p. 87ANo.
p. 87QDid Epstein ever ask that you take a role in someone's account?
p. 87ANo.
p. 87QWas Mr. Epstein involved in any of the accounts?
p. 87ANo.
p. 87QHow much revenue did J.P. Morgan generate from Mr. Epstein's new client referrals?
p. 87AI wasn't aware then, but I have read subsequent it would be, you know, well over $100 million.
p. 87QAnd that would have made him an incredibly valuable client, correct?
p. 87AYeah. I think the introduction of the people that -- of the level of people that he brought to us was very valuable, yes.
p. 87QDo you think his value caused J.P. Morgan to turn their heads at the suspicious things that Mr. Epstein was engaged in, even following 2008?
p. 87AAgain, I was not part of the bank that reviewed his account. I was not part of the rapid response teams, I was not part of compliance, so I'd be speculating as to what their motivations were.
p. 88QI am asking you to speculate. Do you believe that J.P. Morgan kept Mr. Epstein's on as a high-risk client because he generated so much revenue for the bank?
p. 88ANo, I don't. I think J.P. Morgan felt that the principal activity of the Private Bank is to invest money, and I think Morgan took the decision to no longer deal with Epstein in the management of his assets. That was a major move by the bank against him in the bank's mind.
p. 88QWho had visibility into Mr. Epstein's accounts?
p. 88AI think the bankers that managed his accounts; I think compliance did; I think legal did; I think risk did; and people in operations did.
p. 88QDid you?
p. 88ANo.
p. 88QDid you review any of his transactions?
p. 88ANo.
p. 88QWere his transactions ever discussed with you?
p. 88AAt some point I learned that he was making cash withdrawals, and I asked him about that because cash withdrawals were a red light for the bank and a red light for regulators.
p. 88QWhen did you become aware of that?
p. 88AI'm not exactly sure what year it was, but I want to say 2010, 2011.
p. 88QWho would have been responsible for reviewing these transactions?
p. 88AAgain, members of the rapid response team, heads of compliance, people involved in legal, and I think ultimately my recollection is it did go all the way up to the general counsel of the bank.
p. 88QWho was that?
p. 89AAt that -- beginning of 2009, 2010, I think it was Steve Cutler.
p. 89QDid you ever ask Mr. Epstein about the cash withdrawals?
p. 89AI know someone -- either I did or Mary did. And he said that they -- he told her or he told me that they were to -- or he told his banker that they were for fuel for his airplane.
p. 89QDid you ask why he would need cash for airplane fuel?
p. 89AI don't think I did. I think the question -- I think the question was discussed, and I think the view was, particularly if you're flying overseas or whatnot, that oftentimes you would pay cash for fuel as opposed to another source.
p. 89QWhat steps were taken to investigate that defense?
p. 89AI don't know. Again, I was not part of the team that was -- that was looking into that.
p. 89QYou mentioned this made it up to the general counsel, Stephen Cutler. Did you discuss the matter with Stephen Cutler?
p. 89AAt one point in time, yes. I think as Epstein's problems built, he hired some very recognized lawyers, and I recall that I suggested Steve meet with them.
p. 89QWhy did you suggest that?
p. 89ASo the bank would make an informed decision as to whether to keep Epstein or not as a client.
p. 89QIn October 2011, Stephen Cutler complained to you and others that Epstein was not an honorable person in any way, and should not be a client. How did you respond?
p. 89AAgain, I let the bank do what the bank felt was proper.
p. 89QDid you say anything at that moment in response to him, though?
p. 89AI think that's when he had people like Ken Starr represent him and just suggested that Steve meet with Ken Starr. But it was Steve Cutler's decision to close him as a client or not.
p. 89QThere's --
p. 89AIf Steve Cutler wanted to do it, he could have done it.
p. 90QThere is reporting that you asked Mr. Cutler to sit down with Mr. Epstein and hear him out. Is that correct?
p. 90AYes. Or hear his lawyers out. I forget what it was. It was either meet with Epstein -- I think I did meet with Epstein, and I don't know whether Steve met with him or was with his lawyers.
p. 90QWhy did you advocate for Mr. Cutler to take his time to meet with Mr. Epstein?
p. 90ASteve was running legal and compliance in the bank, and these were serious allegations, and the bank was going to exit Epstein more than it already had, seemed like Steve -- seemed like the thing to do was have Steve meet with Epstein himself.
p. 90QDid you not feel as though Mr. Epstein, as a registered sex offender and someone who pleaded guilty to soliciting prostitution from minors, was a great risk to the bank and should be removed as a client?
p. 90AWell, again, the bank cut off the principal activities that it had with Epstein. The question is whether you would close his checking account or not. And my --
p. 90QDid anyone else at the bank take steps to defend Mr. Epstein?
p. 90AI don't think I took steps to defend Mr. Epstein, but I think his banking team defended him. And I think what's telling is when Epstein moved his accounts ultimately out of Morgan, he followed his banking team to Deutsche Bank.
p. 90QWas Mr. Cutler going to remove Mr. Epstein as a client before you asked him to sit down with Mr. Epstein?
p. 90AI don't know.
p. 90QReporting indicates that Justin Nelson wrote a memo trumpeting Epstein's large volume of business with J.P. Morgan and noting that, despite his status as a sex offender, he was still clearly well-respected and trusted by some of the richest people in the world. Did you ever see this memo?
p. 91AI know Justin Nelson. I don't know if I saw that specific memo.
p. 91QDid you ever speak with Mr. Nelson about Mr. Epstein's status as a client?
p. 91AI recommended that Justin Nelson be the banker for Jeffrey Epstein at one point, but I think that was it.
p. 91QWas Justin Nelson also your banker?
p. 91AHe became the banker to my wife's family, not to me.
p. 91QAre you aware of whether Mr. Epstein asked Mr. Nelson to write this memo?
p. 91ANo.
p. 91Mr. Emmer.We've had another Member join. Can she please announce herself for the record.
p. 91Mrs. Luna.Congresswoman Luna.
p. 91Mr. Emmer.Mrs. Luna, we understand you have some questions?
p. 91Mrs. Luna.I do. Thank you. Thank you for being here today. I wanted to see, have you ever made a settlement payment to ?
p. 91Mr. Staley.No.
p. 91Mrs. Luna.Okay. At your position at J.P. Morgan, you had referenced U.S. intelligence agencies. Can you elaborate further on your interactions with various agencies, and if so, which agencies were those?
p. 91Mr. Staley.Can you say that again? Sorry.
p. 91Mrs. Luna.You had made a reference to having contact with U.S. intelligence agencies for your work at J.P. Morgan.
p. 91Mr. Staley.Yes.
p. 92Mrs. Luna.Can you specify as to the agencies, as well as what that nature of work may have been?
p. 92Mr. Staley.I believe it was the State Department and the CIA.
p. 92Mrs. Luna.Okay. Can you elaborate further on what they were having you do?
p. 92Mr. Staley.Yes. This was after 9/11, and the Bin Laden family had its international banking accounts with J.P. Morgan --
p. 92Mrs. Luna.Uh-huh.
p. 92Mr. Staley.-- and the State Department and Morgan and I agreed that I should fly to Saudi Arabia to meet with the Bin Laden family and to tell them that the State Department and Morgan recognized that Osama bin Laden was rogue and had been expelled by the family, then the family's business with Morgan would be preserved.
p. 92Mrs. Luna.Where does the CIA fit into those conversations?
p. 92Mr. Staley.Hmm?
p. 92Mrs. Luna.Where does the CIA fit into those conversations?
p. 92Mr. Staley.My recollection is the CIA came to meet me in my office.
p. 92Mrs. Luna.With the State Department?
p. 92Mr. Staley.I'm not sure whether it was the same time or together.
p. 92Mrs. Luna.Do you remember who at the State Department or who at the CIA came to meet you?
p. 92Mr. Staley.No.
p. 92Mrs. Luna.Okay. Following up on that, were you aware that Jeffrey Epstein had an alias?
p. 92Mr. Staley.Had a what?
p. 92Mrs. Luna.An alias.
p. 92Mr. Staley.No, I was not.
p. 92Mrs. Luna.Okay. He had an alias that was listed with a Saudi Arabian address. Following that interaction that you had with the Bin Laden family, did Jeffrey Epstein ask to meet with you again?
p. 93Mr. Staley.With respect to the Bin Laden family?
p. 93Mrs. Luna.Or closely thereafter.
p. 93Mr. Staley.I don't know about the timing, but I don't think he met with me with respect to the Bin Laden family.
p. 93Mrs. Luna.Did he ever ask you about your travels to that area or interactions with the family?
p. 93Mr. Staley.He was close to a member -- a member of the royal family in Dubai.
p. 93Mrs. Luna.Who was?
p. 93Mr. Staley.He ran Dubai ports.
p. 93Mrs. Luna.Who was close to a member of --
p. 93Mr. Staley.Epstein.
p. 93Mrs. Luna.Okay.
p. 93Mr. Staley.And I met with the sheik who ran the ports for Dubai. That was the only really -- and then he had connections in Israel, and I met senior officials in Israel that Epstein knew.
p. 93Mrs. Luna.Who did you meet?
p. 93Mr. Staley.I met Ehud Barak, and I met the Prime Minister Netanyahu.
p. 93Mrs. Luna.Those are my questions.
p. 93QAnd then I just have a quick follow-up from something we were discussing earlier. You mentioned you were not part of the rapid response teams or any of the teams overseeing Mr. Epstein's accounts. We were talking about you being informed of him making the suspicious cash withdrawals. Why were you informed of that?
p. 94AAgain, I think it was very suspicious, and generally the bank would report cash withdrawals like that to the Federal Government. And, you know, it's just something that generally the bank would not allow.
p. 94QBut you said you were informed about it and then had a discussion with Mr. Epstein. Is that correct?
p. 94AAs I said, I said I think I or Mary Erdoes said that the bank raised this issue about cash and there was a problem.
p. 94QSo who would have informed you about the withdrawals?
p. 94AI don't recall who exactly was informing.
p. 94QWhen did you begin working at Barclays?
p. 94AIn December 2015.
p. 94QWhat was your position?
p. 94ACEO.
p. 94QWhat is Barclays?
p. 94AIt is a major international bank headquartered in London.
p. 94QDid you ever ask Mr. Epstein to assist you in getting the position at Barclays?
p. 94ANever.
p. 94QIt's been reported that Mr. Epstein enlisted a London power broker to plant seeds about you with senior bank officials back in 2012. But you interviewed for the job in 2012, and it ultimately went to another Barclays executive. Did you interview for the position in 2012?
p. 94AYes.
p. 94QAnd it did go to someone else?
p. 94AYes.
p. 95QSo the rest of the reporting is correct. Did Mr. Epstein enlist a London power broker to plant seeds about you?
p. 95AI don't know, and I would not have wanted someone to lobby on my behalf.
p. 95QYou never asked him to speak with --
p. 95ANever.
p. 95Q-- anyone?
p. 95ANo.
p. 95QIn 2015, did Barclays ask that you change anything about your relationship with Mr. Epstein?
p. 95ANo. I took the decision when I became CEO of Barclays that I would cut all contact with Jeffrey Epstein.
p. 95QDid you, in fact, cut all contact with Mr. Epstein in 2015.
p. 95AI had no contact post-2015 with Jeffrey Epstein, direct contact.
p. 95Ms. Brignac.I'll now enter majority exhibit 8 into the record. This document is Bates stamped with EFTA01055036. It is an email exchange between your daughter and Mr. Epstein from February 6th, 2017. [Staley Majority Exhibit No. 8. was marked for identification.]
p. 95Ms. Brignac.We'll go off the record. We're back on the record.
p. 95QDo you recognize these emails, Mr. Staley?
p. 95AYes.
p. 95QCan you describe what's happening in the thread?
p. 95AAgain, I think it is Jeffrey Epstein, unfortunately, trying to contact me through my daughter.
p. 96QWere you aware that Mr. Epstein was contacting your daughter in 2017?
p. 96AMy understanding is it happened twice. I was not aware -- I don't believe there was contact before this exchange.
p. 96QWhy would Mr. Epstein reach out to regarding a former J.P. Morgan employee, Veronique Weill?
p. 96AAgain, many years before he was helpful in her pursuit of physics. So they knew each other. And it seems like he approached her with respect to Veronique Weill.
p. 96QDid your daughter come to you and ask you this question?
p. 96AThat's what this email says.
p. 96QDid you know it was coming from Mr. Epstein?
p. 96AI believe so.
p. 96QSo, Mr. Staley, we can agree your communications through your daughter to Mr. Epstein were in violation of the agreement you made to Barclays to cut off communication with Mr. Epstein after 2015, correct?
p. 96AThere was not an agreement. What I told Barclays was that I had not had physical contact with Epstein for a while, which was true, and I cut off contact directly with Epstein upon taking the CEO role at Barclays, which is also true.
p. 96QAnd then you began communicating to Mr. Epstein through your daughter,
p. 96ANo, I did not start communicating with Epstein through my daughter.
p. 96QYou testified you were aware that your -- the message from your daughter --
p. 96ANo.
p. 96QYou testified earlier that you were aware that your daughter's message came from Mr. Epstein, and it reflects in the document that you gave that information. So you did not cut off contact with Mr. Epstein following 2015, correct?
p. 97AYour first thing is that I was trying to contact Epstein through my daughter. I was not trying to contact Epstein through my daughter. [1:53 p.m.]
p. 98Mrs. Luna.I'm back for more questions. Do you know who is? Have you heard of that name?
p. 98Mr. Staley.Now I have.
p. 98Mrs. Luna.Okay. She read the email, "The Snow White was [fucked] twice as soon as she put [on] her costume." Would you say that that would be a predatory statement to make about this image?
p. 98Mr. Staley.What -- what's your question?
p. 98Mrs. Luna.Would you say that that statement is a predatory statement to make about this image?
p. 98Mr. Staley.I don't think it's a predatory statement made about --
p. 98Mrs. Luna.You don't think that's predatory?
p. 98Mr. Staley.No, I think -- I think someone assaulting a women is predatory, yes.
p. 98Mrs. Luna.The question was, do you think that that's a predatory statement to make about this image?
p. 98Mr. Staley.I don't know who that person is.
p. 98Mrs. Luna.I'm not asking if you know who that person is. I'm asking if you think that that statement is a predatory statement to make about this image.
p. 98Mr. Staley.If that's what the -- if that's the image that the person is referring to --
p. 98Mrs. Luna.Referring to, yes.
p. 98Mr. Staley.-- then, yes, that would be a predatory statement.
p. 98Mrs. Luna.Okay. Going back to this email correspondence, it appears that Jeffrey Epstein is asking you, which character would you like next? Do you know what he's referencing?
p. 99Mr. Staley.I don't.
p. 99Mrs. Luna.Okay. It says that you're responding to him, "Beauty and the Beast." What can you refer in "Beauty and the Beast"? Are you talking about Belle?
p. 99Mr. Staley.I'm just mentioning "Beauty and the Beast."
p. 99Mrs. Luna.Sir, I wouldn't laugh at this at all. It's very --
p. 99Mr. Staley.I'm not.
p. 99Mrs. Luna.-- disturbing to read --
p. 99Mr. Staley.I'm not.
p. 99Mrs. Luna.-- these emails. So I just -- the reason I'm asking you is because, to me, reading this, it looks like there's trafficking happening. And what I would also say is, this girl looks she's about maybe 13, 14 years old. So, if this was written about someone like your child, I don't think that you would be laughing right now. And so the point is that we have you here. Can you give us information and/or names for people that you may know who have harmed these kids?
p. 99Mr. Staley.No. I do not know anyone --
p. 99Mr. Sullivan.Congressperson, I have an objection --
p. 99Mrs. Luna.It's "Congresswoman."
p. 99Mr. Sullivan.Congresswoman. Thank you. But to say, from the picture, to guess the age as 13 years old strikes me as --
p. 99Mrs. Luna.I've seen some of the unredacted photos of these --
p. 99Mr. Sullivan.Well --
p. 99Mrs. Luna.-- and they are children.
p. 99Mr. Sullivan.-- that's your view, but I'd like to see them.
p. 100Mrs. Luna.Well, you can -- I'm sure you'll get the opportunity if this becomes criminal.
p. 100Mr. Sullivan.Thank you.
p. 100Ms. Brignac.We have some pressing followups. We'll go off the record, and we'll come back on later to ask those followups. [Recess.] . We're back on the record. BY :
p. 100QMr. Staley, I'd like to ask you a few clarifying questions based on what you said during the minority's first round. You referred to Mr. Epstein's assistants as "mature" and also as in their late twenties or early thirties. We have a different understanding of his assistants, but given the distinction that you are drawing, I would like to repeat some of the questions I asked you but in the context of his assistants. When you visited Mr. Epstein's New York home, were there ever assistants in the room when you met with Mr. Epstein?
p. 100AOnly that they would occasionally come in and offer coffee or something like that. They weren't sitting in the room during the meetings, no.
p. 100QWere there ever assistants sitting on Mr. Epstein's lap when you talked to him?
p. 100ANo.
p. 100QWe previously talked about your interactions, sexual or otherwise, with women connected to Mr. Epstein. To be clear, when I say "women connected to Mr. Epstein," I am including his assistants. Did you ever introduce any of the women connected to Mr. Epstein to anyone in your family?
p. 100ANo.
p. 100QSo you never introduced any of the women connected to Mr. Epstein to your daughters?
p. 101ANo.
p. 101QHave you ever had a conversation with Leon Black about your relationship with Mr. Epstein?
p. 101AI think we -- we both knew that we knew Epstein. I don't know if I had a specific conversation with him.
p. 101QDid you have a conversation with Mr. Black about Mr. Epstein's crimes?
p. 101AI think we were both aware of Mr. Epstein's crimes.
p. 101QSure. And did you talk about them?
p. 101AWe may have, but I don't recall a specific conversation.
p. 101QWhen would that have been?
p. 101AI don't know.
p. 101QDo you have a sense for whether that would have been post-arrest, post-incarceration, or later?
p. 101AI think it would've been post-indictment and probably post-arrest.
p. 101QAnd do you have any memory of specifically what you would have talked about?
p. 101ANo.
p. 101QDid you ever have a conversation with Mr. Black about any woman connected to Mr. Epstein?
p. 101ANo.
p. 101QDid you ever meet with Mr. Black in Central Park to discuss any of these issues -- your relationship with Mr. Epstein, Mr. Epstein's crimes, or any woman connected to Mr. Epstein?
p. 101ANot that I remember, no.
p. 101QThank you. BY :
p. 101QMr. Staley, you've previously made contradictory statements about your friendship with Mr. Epstein. For example, you have said, quote, your relationship with Mr. Epstein was "never a personal one, nor one that could be described as close." But you have also said that you and Mr. Epstein had a, quote, "fairly close relationship." At one point, you said Mr. Epstein was, quote, "a friend." I would like to clear up some of this confusion and get a better sense of your friendship with Mr. Epstein. I'll begin by introducing what will be marked as minority exhibit K. [Staley Minority Exhibit K. was marked for identification.] BY :
p. 102QThis is six separate email exchanges between you and Mr. Epstein from the first few weeks of his sentence at the Palm Beach stockade. It's from July 10th, 2008, until September 11th, 2008. The first email, which begins on the bottom of the first page and goes into the top of the second page, is from you to Mr. Epstein, dated July 10, 2008, which is just 10 days into his sentence. In the email, you write, quote, "I miss you. The world is in a tough place. Hang in there." It appears at this point that Mr. Epstein was a friend. Is that correct?
p. 102AAgain, my relationship with Epstein was based on a close professional relationship anchored in business, but I would use language like "friend" and "close friend."
p. 102QSo you were friends.
p. 102AI would use language that way, yes, but it was grounded in the business relationship that we had.
p. 102QCould you elaborate on what you mean by you "would use language that way"?
p. 102AI often talked to people that I worked with and called them friends and close friends.
p. 102QSo the business -- the relationship was grounded in business, but you transitioned into being friends as well.
p. 103AI use the word "friend" to describe the relationship, but, for instance, you know, he never came to my house, he never came to social occasions with my family. I would call that a personal friend. [Inaudible] were tied to business.
p. 103QSo a business friend.
p. 103AYes.
p. 103QUnderstood. And this is one of the first emails we have between you and Mr. Epstein. Your message suggests that you were in contact often, if you missed him after just 10 days of him being in the Palm Beach stockade. How frequently were you in touch with Mr. Epstein before he was incarcerated?
p. 103AAgain, I think we would talk, you know, once or twice a week. I'd visit him, you know, once every other week, that sort of frequency.
p. 103QOkay. I would like to move to the fourth page of this exhibit. This is an email from you to Mr. Epstein dated July 16th, 2008, just 1 week later. In this email, you say, quote --
p. 103Mr. Sullivan.Just give us 1 minute to locate it. The fourth page. Is it marked "4". . Yes, towards the bottom of that page.
p. 103Mr. Sullivan.Okay. Got it. BY :
p. 103QYou say, quote, "I hope you're managing. I miss our calls. It's boring without you around." I will now move to the fifth page. It's an email from you to Mr. Epstein dated July 31st, 2008. This is the third email that you sent to Mr. Epstein in just 3 weeks. In this email, you say, quote, "I hope you are hangin there. Just think of the island and my boat anchored in front. I do." On page 6, this is another email from you to Mr. Epstein, on August 3rd, 2008. You say, quote, "Just thinking about you." On the next page, page 7, you email Mr. Epstein on August 4th, 2008, and say, quote, "Hang in there. Keep thinking of the Island." Finally, on page 8, you write to Mr. Epstein on September 11, 2008, saying, quote, "A very tough day today. Thinking of you there. With what I see, it is so unfair. Hang in there, please." Based on these emails, I think it's fair to say that you and Mr. Epstein were very close. Would you agree?
p. 104AI would repeat what I've said before. I think we had a close professional relationship. I use language like this. Like many people you deal with in business -- at this point, I was building a boat. He encouraged me to build the boat. But that's what a lot of this refers to.
p. 104QWas it common for you to email other business friends saying things like "I miss you" and "Just thinking about the island and my boat anchored in front"?
p. 104AWell, there was not that many friends had islands that I anchored my boat in front of it.
p. 104QSo the first part of the question. Was it common for you to email other business friends saying "I miss you"?
p. 104AI think it would be common that I would mention to people that I worked with that I -- you know, that I missed them, but --
p. 104QSo the people that you worked at J.P. Morgan with, not clients of the bank.
p. 104AI'm sure there were some clients that I did this as well, but I don't know. I couldn't name them for you.
p. 104QOkay. I will now introduce what will be marked as minority exhibit L. [Staley Minority Exhibit L. was marked for identification.] BY :
p. 105QThis is an email from you to Mr. Epstein on December 30th, 2010. The Bates number is EFTA02533765. In this email, you write, quote, "Happy new year. It [is] nice to have u free. Much to come. Please know that I am [a] friend forever. You are very special," to which Mr. Epstein replied, quote, "Ditto." What did you mean by "much to come"?
p. 105AI don't recall.
p. 105QYou don't recall what you meant?
p. 105ANo.
p. 105QWhy did you tell Mr. Epstein that you were a friend forever?
p. 105AI think I was showing sympathy to him.
p. 105QSympathy for what?
p. 105AI believe this is when he was getting out of prison.
p. 105QSo you felt sympathy for him at the time, even with the charges that he was serving time for?
p. 105AYeah. I thought he had served his time, he had -- he had -- he had -- he had paid his price, and never -- I never imagined that he would continue to act criminally.
p. 105QAnd what made Mr. Epstein, quote, "very special" to you?
p. 105AAgain, he had given me very valuable business advice. He was instrumental in one of the biggest transactions of my career, the acquisition of Highbridge Capital. He gave me counsel in my discussions with the bank about my career. He gave me counsel -- so those are the things.
p. 105QSo he was just very special because of what he provided for you in your career?
p. 105AOh, I think that's what drove it. I mean, again, he was instrumental in the most important transaction of my career up to that point. He gave me a lot of business. He connected me with -- you read the list -- an incredible group of people that helped my career. So, yeah, he was very helpful to me.
p. 106QBut this was 6 years after the Highbridge Capital deal. So there was nothing else that had happened in between that you felt made him very special to you?
p. 106ANo. He introduced me to names that we've talked about. He introduced me to that. He would facilitate when I traveled overseas to meet with business and country leaders. He did a lot of things like that.
p. 106QOkay. BY :
p. 106QOne quick followup for you, Mr. Staley. When you said these things to Mr. Epstein about how you missed him and you were thinking about him and he was special to you, that you were a friend forever, were those disingenuous? Because it seems like what you're saying now is that you didn't mean them, and if that's the case --
p. 106AI mean, you know --
p. 106Q-- why?
p. 106A-- you know, a point of fact is, when I became CEO of Barclays, I completely cut off all relationship with him and stopped being his friend.
p. 106QSo he was a friend before you became the CEO of Barclays?
p. 106AWell, again, I was responding to the question, was I being disingenuous? And I was responding to the "disingenuous" part by saying, no, actually, I cut him off as a -- as a friend.
p. 106QBut that doesn't answer my question. When you said these things to him, did you mean them at the time?
p. 106AAgain, I used effusive language. The relationship was based on business, as these emails attest to. But I used the word "friendship" with a lot of people. BY :
p. 107QMr. Staley, in a question my colleague asked you -- what did you mean by, quote, "much to come"? -- correct me if I'm wrong, but you testified that you were expressing sympathy. Is that right?
p. 107AI don't know what I was referring to when I said "much to come." That could have been much to come in my career, much to come in our discussion about business and the world. I don't know.
p. 107QBut you told us that this was around the time that Mr. Epstein was being released from jail. Is that right?
p. 107ACan you remind -- can you show me the --
p. 107QSure. This was exhibit L, Bates number 3765, bottom right.
p. 107AAnd ask your question again, sir?
p. 107QWhat you testified to earlier was, around December 30th, 2010, when you wrote to Mr. Epstein, "Much to come," you told us that you were expressing sympathy for him because he was being released from incarceration. Is that right?
p. 107AMy belief is, he was released from incarceration more than a year before this email.
p. 107QGreat. So that would've been the prior exhibit. Why were you expressing sympathy to Mr. Epstein when he was being released from jail?
p. 107AWhere's the sympathy?
p. 107QSir, I'm just repeating the words that you told us.
p. 107AOh, okay. Yeah, you know, this is a year after incarceration. I'm just saying that, you know, we maintained a relationship, and, again, I -- and I'm just saying the relationship will continue. Although, a few years later I terminated the relationship.
p. 108QYou've testified to that multiple times. I think what we are asking about --
p. 108AYou ask the same question multiple times, so I'm just giving you the same answer.
p. 108QUnderstood. And I think we have been very clear that we're asking about your mindset at the time that you wrote this, and you keep jumping to you've cut off relationship in the future. What we're asking about is your mindset at this time. So, sir, again, you told us that you were expressing sympathy to Mr. Epstein because he had just been released from incarceration. Why were you sympathetic that Mr. Epstein was incarcerated?
p. 108AI think, you know, he obviously pled guilty, he deserved his incarceration, but that doesn't mean I can't show sympathy for -- for what he went through.
p. 108QWhat did he go through?
p. 108ABut he deserved it. He went to jail.
p. 108QTo be clear, your testimony is that you felt sympathy that he went to jail.
p. 108ANo, I just felt that -- no, I mean, he rightfully went to jail. And, you know, I'm just expressing sympathy for someone who went through that, even though he deserved it.
p. 108QThank you. BY :
p. 108QCould I just follow up really quickly? You said "he deserved it," but then in a previous email we had looked at, you also said, "From what I see, it is so unfair." Do you know what you were referring to there?
p. 108AUh --
p. 108Mr. Sullivan.Look at the email, please. BY :
p. 108QPage 8 of the first exhibit I introduced, the packet, the last page.
p. 109ASo this is not 2011; we're talking about 2008 now?
p. 109QYes.
p. 109ASo 3 years before?
p. 109QTwo years before, I believe. We were talking 2010.
p. 109AOkay, sorry. Two years before. This is when I guess he was going to jail, right?
p. 109QHe had already been there for about 3 months, I believe, at the time.
p. 109AThanks. Yeah, I don't know what happened on that day, why that day was particularly tough.
p. 109QDo you believe you were saying it's unfair that he was serving time?
p. 109AI don't recall if that was referring to that. BY MR.
p. 109QMr. Staley, do you believe Mr. Epstein's guilty plea is supported by the merits, by the facts?
p. 109AHe pleaded guilty.
p. 109QThat's not my question, sir. Do you believe it's supported by the facts?
p. 109AI have no reason to say it wouldn't be.
p. 109QOkay. BY :
p. 109QMr. Staley, I'd like to ask you some questions about your time at J.P. Morgan. Before I do, a quick point of clarification. You gestured at me when you said that I read a list of names of referrals. That was not me. That was my colleague on the majority, who is also a woman with brown hair.
p. 109ASorry.
p. 109QYou were head of J.P. Morgan's Private Bank from 1999 to 2001, correct?
p. 110ACorrect.
p. 110QAnd then you were promoted to CEO of J.P. Morgan's asset management division in 2001, correct?
p. 110ACorrect.
p. 110QAnd you ran J.P. Morgan's asset management division until 2009, at which point you were appointed as CEO of the investment banking division, correct?
p. 110ACorrect.
p. 110QAnd you left J.P. Morgan in early 2013, correct?
p. 110ACorrect.
p. 110QIs it accurate to say, during the time that you were at the company, that, in addition to banking services, J.P. Morgan's Private Bank offered clients customized lending services, investment advice, portfolio management, and wealth planning?
p. 110AYes.
p. 110QAre there other services that the Private Bank offered that I have left out?
p. 110ACan you read the list again?
p. 110QOther than banking services, customized lending services, investment advice, portfolio management, and wealth planning.
p. 110AThat, and I would add things like custody. Was brokerage in there?
p. 110QBrokerage was not in there.
p. 110ASo I would include brokerage. So those are two that I would add.
p. 110QThank you. Is it also accurate to say that J.P. Morgan's Private Bank would have worked in conjunction with the asset management division in offering some of those services?
p. 110AYes.
p. 110QWhen you were head of the Private Bank, who did you report to?
p. 111AI think it changed over time, but ultimately I reported to Jamie Dimon.
p. 111QSo, when you were the head of the Private Bank, you reported to the CEO directly? There wasn't someone in between you?
p. 111AYeah, I think it was initially Sandy Warner, then I believe it was Bill Harrison, and then I believe it was Jamie Dimon.
p. 111QAnd when you became CEO of asset management, did the head of the Private Bank then report to you?
p. 111AYes.
p. 111QAnd when you were CEO of asset management, you continued to report to the CEO?
p. 111AYes.
p. 111QAnd when you were CEO of investment banking, the same was true? You reported directly to the CEO?
p. 111AYes.
p. 111QI'd like to ask you a few high-level questions about J.P. Morgan's due diligence reports. First, what is a due diligence report?
p. 111AIt's a report that the bank has studied a certain topic and it has done its due diligence, whether it's know-your-client, whether it's AML, anti-money-laundering. There are activities like that that a due diligence report might be part of.
p. 111QWhat action would trigger the creation of a due diligence report?
p. 111AI don't know specifically.
p. 111QDo you know what action would trigger an --
p. 111AI mean, opening --
p. 111Q-- update?
p. 111A-- opening an account, extending a loan, I think those activities would trigger a due diligence report.
p. 112QOkay. So opening an account triggers a due diligence report. In the context of accounts -- excuse me. In the context of an account, what would trigger an update to a due diligence report?
p. 112AChange in assets. Change in direction of the account. Any concern that the bank might have about the account or the holder of the account. That sort of thing.
p. 112QWho would typically create or update a due diligence report?
p. 112AAgain, I would think someone in risk, someone in compliance, someone in legal, that type of thing.
p. 112QWould due diligence reports be shared with individuals in the Private Bank or the asset management division?
p. 112ASure.
p. 112QWould anyone at J.P. Morgan need to sign off on a due diligence report?
p. 112AI imagine someone in risk or credit or compliance, yeah, would need to sign off on a due diligence report.
p. 112QCould it also be someone in the Private Bank or the asset management division?
p. 112AWell, there were people in asset management and the Private Bank that were part of compliance, part of legal, part of risk, so, in that sense, yes.
p. 112QGot it. Okay. I'd like to get a better sense of Mr. Epstein's relationship with J.P. Morgan. Mr. Epstein became a J.P. Morgan client in 1998, correct?
p. 112AThat's my understanding.
p. 112QAnd he was a J.P. Morgan client until 2013, correct?
p. 112AThat's my understanding, yes.
p. 112QWe understand that Mr. Epstein had personal accounts and business accounts at J.P. Morgan. Is that correct?
p. 113AI believe so.
p. 113QWe also understand that Mr. Epstein set up J.P. Morgan accounts for his staff. Is that correct?
p. 113AI was not aware of that, but very possible. I was not involved in his accounts, so --
p. 113QWe also understand that Mr. Epstein set up J.P. Morgan accounts for women that he was connected to. Are you aware of that?
p. 113ANo.
p. 113QWho at J.P. Morgan was responsible for servicing Mr. Epstein's accounts?
p. 113AHe had a banking team that I think was led by a gentleman by the name of Paul Morris.
p. 113QDo you remember who else was on that team?
p. 113ANo.
p. 113QWhat about Justin Nelson, who you referred to earlier?
p. 113AYeah, I think he was earlier; then I think it was Paul Morris. That's my recollection.
p. 113QAnyone else?
p. 113AThat I recall? No.
p. 113QWhat would Paul Barrett's role have been in servicing Mr. Epstein's accounts?
p. 113AI don't know who Paul Barrett is.
p. 113Mr. Sullivan.Do you mean Morris? Are you thinking Morris. BY :
p. 113QThat's my mistake. Thank you.
p. 113AThat's okay.
p. 113QWhat was Paul Morris's role in servicing Mr. Epstein's accounts?
p. 113AI think he was a lead banker for Jeffrey Epstein's accounts.
p. 113QAnd you said Justin Nelson came before Paul Morris? Is that right?
p. 113AYeah, again, I am -- I'm not sure.
p. 114QWas he also a lead banker in servicing Mr. Epstein's accounts?
p. 114AI believe at one point he was, yes.
p. 114QAnd you said you don't know who Paul Barrett is. Is --
p. 114ANo.
p. 114Q-- that correct?
p. 114AThat's correct.
p. 114QWhat about Marcus Sheridan?
p. 114AMarc Sheridan? I recognize the name.
p. 114QBut you don't know what his role would've been?
p. 114AIt was a long time ago.
p. 114QWhat about Mary Casey?
p. 114AI think Mary Casey ran one of the banking groups of which Paul Morris was one of the bankers. We were divided by geography, so I wonder -- I think Mary Casey ran one of the geographic groups that included the Epstein account.
p. 114QWhat about Lisa Waters?
p. 114AMy recollection is that Lisa Waters was in compliance, but I'm not sure.
p. 114QWhen did you first learn that J.P. Morgan had concerns with Mr. Epstein's accounts?
p. 114AI think there were concerns in 2008 -- 2006, 2008.
p. 114Q2006 or 2008 is when you first learned that J.P. Morgan had concerns with Mr. Epstein's accounts?
p. 114AWell, there was a rapid response meeting, and I -- and there was -- you can line it up with that date. And I think it was 2006.
p. 114QDo you remember what those concerns were?
p. 114AHe was -- he was indicted.
p. 114QIn 2003, Vanity Fair published an article on Mr. Epstein titled, "The Talented Mr. Epstein." It included the following lines: Quote, "One young woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein's town house, where the women seemed to outnumber the men by far. 'These were not women you'd see at Upper East Side dinners,' the woman recalls. 'Many seemed foreign and dressed a little bizarrely.' This same guest also attended a cocktail party thrown by Maxwell that Prince Andrew attended, which was filled, she says, with young Russian models. 'Some of the guests were horrified,' the woman says." Do you remember this article being published?
p. 115ANo.
p. 115QI would think that a Vanity Fair piece on a client and friend would be memorable, no?
p. 115AI mean, you're asking whether I remember the article now. I may have recognized the article then.
p. 115QDo you know if anyone at J.P. Morgan was aware of this article?
p. 115AI don't know.
p. 115Mr. Sullivan.Excuse me. Is this '03, did you say. . I'm sorry, Mr. Sullivan.
p. 115Mr. Sullivan.2003? . Correct. BY :
p. 115QI would like on introduce as minority exhibit M an email between two J.P. Morgan employees -- Mary Rieth, who's later Mary Casey, and Paul Lahiff -- dated May 21st, 2003. The Bates number is EFTA02810792. [Staley Minority Exhibit M. was marked for identification.] BY :
p. 116QIn the email, Ms. Rieth tells Mr. Lahiff that she just got the due diligence report on one of Mr. Epstein's companies and notes that she, quote, "was waiting to pull everything together before sending down the Vanity Fair article." Why do you think these J.P. Morgan employees were tracking the Vanity Fair article in the context of a due diligence report.
p. 116AWell, I'd like to read the Vanity Fair article. This is 23 years -- no -- this is 24 years ago or 23 years ago. If there was something negative in that article, then, you know, the bank would want to review it and review the account to make sure they were comfortable with -- with the client.
p. 116QDid J.P. Morgan suspect Mr. Epstein was engaging in sex trafficking as early as 2003?
p. 116AI don't know. I would -- I would doubt it, but I don't know.
p. 116QYou would doubt it?
p. 116AI'm not going to speculate.
p. 116QI would like to introduce as minority exhibit N a due diligence report for a checking account that Mr. Epstein asked J.P. Morgan to set up for an unknown woman in 2004. [Staley Minority Exhibit N. was marked for identification.] BY
p. 116QThe due diligence report does not list a date of birth for this woman, and it notes that no government documentation has been provided. The report also states that the Social Security given could not be confirmed as belonging to the woman. The report acknowledges that no one at J.P. Morgan actually met with this woman and that all of the information about her was provided by one of Mr. Epstein's advisors, a man named Eric Ganey. Finally, the report notes that the woman is in the U.S. for modeling work and states, quote, "Jeffrey Epstein knows the model personally. Epstein is a longstanding client of JPMPB." The report also states, quote, "Jeffrey Epstein often provides support to emerging models. In this case, [redacted] has arrived from the Slovak Republic, and Epstein has asked us the favor of opening a checking account for her." Would you agree that there are a number of indicators of sex trafficking here?
p. 117AI think the bank should not be opening an account without doing proper due diligence.
p. 117QWhat would proper due diligence have looked like here?
p. 117AKnowing who the client is, KYC; AML, anti-money-laundering; knowing where the client's origination of wealth comes from -- all sorts of issues. But if you have an invalid Social Security number, that would be a red flag, et cetera.
p. 117QWould you agree -- would you agree that opening this account -- strike that. Did you ever see this due diligence report?
p. 117ANo.
p. 117QWere its contents communicated to you?
p. 117ANo.
p. 117QWould you agree that opening this account without the information we discussed was a significant failure on J.P. Morgan's part?
p. 117AIt seems noncompliant, yes.
p. 117QThat same year, 2004, J.P. Morgan noted $840,000 in cash transactions in Mr. Epstein's J.P. Morgan account. The next year, 2005, J.P. Morgan identified over $900,000 in cash transactions from Mr. Epstein's personal J.P. Morgan account. Earlier today, you said that significant cash withdrawals are a red light. You have also previously testified in the class action against J.P. Morgan that significant cash withdrawals are a smoking gun. Would you agree that J.P. Morgan sat on a red light or a smoking gun for 9 years?
p. 118ASeems like it.
p. 118QAs you know, Mr. Epstein was arrested on July 23rd, 2006, on a single count of soliciting prostitution from a minor. I would like to introduce as minority exhibit O an email exchange between you and Mary Erdoes on July 26, 2006, 3 days after Mr. Epstein was arrested. The Bates number is EFTA02818597. [Staley Minority Exhibit O. was marked for identification.] BY :
p. 118QIn the exchange, Ms. Erdoes, who was head of J.P. Morgan's Private Bank at the time, forwards you an email from another J.P. Morgan employee, Philip Schlakman. In that email, Mr. Schlakman links to an article in the Palm Beach Post and writes, quote, "It gets worse." In her email to you, Ms. Erdoes comments, quote, "So painful to read," to which you reply, quote, "I went and saw him last night. I've never seen him so shaken. He also adamantly denies the ages." First, do you remember if you read that article in the Palm Beach Post?
p. 118AI don't get the Palm Beach Post, but I imagine at some point I read the article.
p. 118QI'll share two statements from it with you. Quote, "A Palm Beach Community College student said she gave Epstein a massage in the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged sessions at his home." And, quote, "Epstein said he'd pay her to bring him more girls -- the younger, the better." Do you remember learning about these allegations?
p. 118AI don't remember that quote, which is horrendous, that -- what's implied. So -- but I knew that he had been -- you know, the article suggested that he was involved with inappropriate young women, and it was a terrible, terrible accusation.
p. 118QWhat did you understand Mr. Schlakman to mean by, quote, "It gets worse"?
p. 119AJust that the article is commenting on his -- his activities that were terrible.
p. 119QWere there statements in the article that were new information to J.P. Morgan?
p. 119AAgain, I didn't read the article, and so was not aware of what was new or not new to J.P. Morgan. But this implies that, yeah, because as "it gets worse," the implication is that Phil Schlakman is learning something more.
p. 119QThe article makes repeated mention of Mr. Epstein's sexual abuse and molestation of girls as young as 14. Could that have been what Mr. Schlakman was referring to?
p. 119AThat just -- it's a horrible, horrible thing, and I imagine that that's what he was referring to.
p. 119QYou visited Mr. Epstein the night of July 25th, 2006, correct?
p. 119AYes.
p. 119QWhy did you visit him?
p. 119ABecause this article had come out making these horrible accusations, and the bank was trying to decide what to do with his accounts, so I thought that I would hear what he had to say.
p. 119QDid someone ask you to do this, or did you do it on your own accord?
p. 119AI believe I did it on my own accord.
p. 119QWhere did this visit take place?
p. 119AIn his office, I believe.
p. 119QAnd what did you ask Mr. Epstein?
p. 119AWhat's going on?
p. 119QAnd what did he say?
p. 119AI think he denied the ages, which, you know, looking back, is an admission of guilt.
p. 119QWhat do you mean, "looking back, is an admission of guilt"?
p. 119AI mean, I said I'd never seen him so shaken, he denied the ages, but I think he was accepting that he was soliciting prostitutes.
p. 120QRight. He admitted the conduct but denied the ages.
p. 120ARight.
p. 120QDid you believe Mr. Epstein when he denied the ages?
p. 120AI think I gave him the benefit of the doubt.
p. 120QDid you really think that Mr. Epstein could mistake a 14-year-old for an adult?
p. 120AAgain, I don't think a -- you know, no, he shouldn't have.
p. 120QBut you did?
p. 120ANo. I'm just reporting what he said.
p. 120QWell, I'm asking you if you believed him at the time. You said you shouldn't have, and then I said, but you did, correct? You did believe him at the time?
p. 120AThat he was unaware of the ages? I think I gave him the benefit of the doubt.
p. 120QIs it fair to say that you were taking these allegations seriously?
p. 120AYes.
p. 120QI'd like to introduce as minority exhibit P an email exchange between you and Mary Erdoes on August 27th, 2007, about a month after Mr. Epstein was arrested. The Bates number is EFTA02811410. [Staley Minority Exhibit P. was marked for identification.] BY :
p. 120QIn the email, you write, quote, "Last night went to the Huggy Bear concert. The age difference between husbands and wifes would have fit in well with Jeffrey. What a joke." What did you mean when you said, quote, "The age difference between husbands and wifes would have fit in well with Jeffrey"?
p. 120AI think I was, you know, referring that, at that party in the Hamptons, the age difference between the men and the women was -- was significant.
p. 121QAnd when you say "party in the Hamptons," you're referring to the Huggy Bear concert?
p. 121AIt looks like that, yes.
p. 121QWhat did you mean when you said, quote, "What a joke"?
p. 121AI find it awkward to see such an age difference between men and women.
p. 121QBut that's not what you say. You don't say the age difference was significant and it was uncomfortable or awkward. You say, "What a joke."
p. 121AYeah, I think that's similar.
p. 121QSo you're not commenting on Mr. Epstein's conduct?
p. 121AIn this email?
p. 121QWhen you say, "What a joke"?
p. 121A[Nonverbal response.]
p. 121QWhen Ms. Erdoes responds to you, she says, quote, "What I meant to tell you about last night was they were a few people laughing about Jeffrey." She goes on to talk about someone in particular and then says, quote, "Anyway, lots of comparisons to JE." It would appear that the two of you both thought that this was funny.
p. 121ANo. I don't think, when I'm saying, "What a joke," do I -- am I saying it in the context of, is it funny? I think, again, I think I'm saying it, the irony that I think we correctly believed that the age difference between Jeffrey and what he was doing was wrong but you go to a party like this in the Hamptons and you see similar age differences.
p. 121QAnd so that was the joke?
p. 121AI think that's the -- that's the irony. Again, I don't think it's joking in a sense of humor. I think it's sad.
p. 121QI would like to introduce as minority exhibit Q an internal J.P. Morgan document with the heading, "Rapid Response Team, October 17, 2006, Existing Client -- Jeffrey Epstein." The Bates number is EFTA02812987. [Staley Minority Exhibit Q. was marked for identification.] BY :
p. 122QThe document states that Mr. Epstein has banking, asset, and credit accounts with J.P. Morgan with balances totaling approximately $32 million. It further states that, quote, "cash withdrawals are routinely made in amounts for $40,000 to $80,000 several times a month." Finally, under "Derogatory Information Reported by Security Services," it states, quote, "Several newspaper articles were found that details the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes." Had J.P. Morgan connected Mr. Epstein's frequent cash withdrawals with his sexual abuse of minors at this point?
p. 122AAgain, cash withdrawals of this size are very unusual and, as I said before, is a red light. It should've been reported to the Federal authorities, and the Federal authorities should've looked at it as well. And given Epstein's -- given -- well, again, this is 2006. I just think this should've been a red light for the bank.
p. 122QBut had J.P. Morgan connected those two things? Because this is a, as you can see, fairly short document. It clearly addresses --
p. 122AI think the bank -- I think the bank was concerned and, as such, decided to move the nature of its relationship with Jeffrey Epstein and cut off the most significant parts of the general -- of a normal private banking client, which is managing assets, and reduce the relationship to simply his checking account.
p. 122QUnder "Banker Recommendations," the document states, quote, "After internal discussions with Jes Staley, Mary Erdoes, Catherine Keating, John Duffy, and Mary [redacted], it was decided that we will keep Mr. Epstein solely as a banking client and on a 'reactive,' client service basis. We will not proactively solicit new investment business from him." First, you said earlier today that you were not a part of rapid response meetings.
p. 123AThat's correct.
p. 123QBut this is a memorandum entitled "Rapid Response Team" that explicitly refers to internal discussions with Jes Staley.
p. 123ABut I was not a member of the Rapid Response Team.
p. 123QSo what were these internal discussions?
p. 123ANo, I think they -- it looks like they talked with myself, Mary, Catherine, John Duffy, and I imagine this is Mary Casey, came back, had a meeting of the Rapid Response Team as a group, and made the decision to pull back the bank's activities with Mr. Epstein.
p. 123QSo that was not your decision, but it was based on discussions with you. Is that correct?
p. 123AIt was based on discussions with myself, Mary Erdoes, Catherine Keating, John Duffy, and I believe it's Mary Casey.
p. 123QCan you explain how this banking-only relationship was different from the one that Mr. Epstein previously had with J.P. Morgan?
p. 123AAgain, the principal activity of the bank was to manage assets, provide brokerage, all sorts -- you know, "investing" in the broadest sense. And I think that's what was withdrawn as a banking service for Epstein, and was only left with essentially his checking account. So the bank would've seen that as a major move against a client.
p. 123QBut he still had that account, correct?
p. 123AHe still had a checking account.
p. 123QAnd he could still open up other accounts, correct?
p. 123AAgain, I don't know. That would surprise me, but --
p. 123QIt would surprise you if he could open up checking accounts?
p. 124AI think you'd be allowed -- well -- allowed to have checking accounts. I don't know exact- -- you know, I'm not sure. I think it depended.
p. 124QThe document is dated October 17th, 2006. Is that when this decision was made?
p. 124AThat's what it seems like, yes.
p. 124QWhy did it take so long to make this decision?
p. 124AI don't know. I mean -- yeah.
p. 124QAs you know, in 2008, Mr. Epstein pleaded guilty to one count of soliciting prostitution and one count of soliciting prostitution from a minor and was sentenced to 18 months in the Palm Beach stockade. When did you learn that Mr. Epstein had pleaded guilty to these counts?
p. 124AWhen he pled guilty.
p. 124QAnd how did you learn it? Did he tell you?
p. 124ANo. I think I just -- in the -- in the press.
p. 124QDid you talk to anyone at J.P. Morgan about the fact that he had pleaded guilty to these counts?
p. 124AI'm sure I did, yes.
p. 124QDo you remember who?
p. 124AAgain, I think I talked with Jamie Dimon about it. I imagine I talked with Mary Erdoes about it.
p. 124QI'd like to introduce as minority exhibit R an email exchange between two J.P. Morgan employees -- Kevin McCleerey and Anne Verdon -- from July 15th, 2008. [Staley Minority Exhibit R. was marked for identification.] BY :
p. 124QIt appears to be in reference to a meeting regarding Mr. Epstein. In the first exchange, Mr. McCleerey writes to Ms. Verdon, quote, "FYI Jes spoke to Lisa Waters and told her he wants to keep his accounts." This was shortly after Mr. Epstein started his sentence at the Palm Beach stockade. Why did you want J.P. Morgan to keep Mr. Epstein's accounts?
p. 125AAgain, I think, at that time, the only activity he had with the bank was his checking account, and the move against his relationship with the bank had already occurred. And it seemed to me, closing a checking account is a tough move, and --
p. 125QBut weren't those checking accounts facilitating his sex trafficking?
p. 125AI was completely unaware of that.
p. 125QYou weren't aware of cash withdrawals at this point?
p. 125AI was unaware that his checking account was involved in his illegal activity.
p. 125QBut you were part of internal discussions that informed the decision to make him a banking-only client, correct?
p. 125AYes, but I wasn't on the Rapid Response Team, but I was part of that decision.
p. 125QI understand you weren't on the Rapid Response Team --
p. 125AI was informed about it, yes.
p. 125Q-- but you were part of discussions that informed that decision. And in the document we looked at earlier, it says, "Cash withdrawals are routinely made in amounts for $40,000 to $80,000 several times a month."
p. 125AThat was --
p. 125QSo --
p. 125AThat was in the report in the Rapid Response Team. That was not -- that was not communicated to me.
p. 125QYou did not know about the significant cash withdrawals in 2006?
p. 125AI don't believe I did, no.
p. 126QAnd you did not know about them in 2008?
p. 126AI learned at some point, but I need to think about what year I learned. But it was -- again, cash withdrawals of that are a huge red flag and should be going -- in fact, you need to -- technically, you should be informing the Federal authorities, I think on a quarterly basis. [3:00 p.m.] BY :
p. 127QSure. But here you are saying -- or rather here two employees are talking about how you want J.P. Morgan to keep Mr. Epstein's accounts in July of 2008. So shortly after he started serving his sentence. And those cash accounts are the things that are allowing him to facilitate this sex trafficking.
p. 127AYeah, I was saying allowed to keep -- well, because you're making the implication that I knew that continuum. All I was suggesting was to keep his checking account. I was not aware of the cash payments and what he was doing with that amount of cash.
p. 127QSo to be clear, your testimony is that you had no awareness of the cash payments --
p. 127AAt some point, I --
p. 127Q-- in July of 2008.
p. 127AAgain, I don't know the exact timing when I learned about his cash.
p. 127QRight, but the timing is relevant because you were advocating for J.P. Morgan to keep his cash accounts?
p. 127ATo keep his checking account.
p. 127QCorrect. Thank you. So were you aware of the significant cash withdrawals in July of 2008?
p. 127AAnd I am saying I don't know exactly what date I became aware of it.
p. 127QSo you may have been aware of them then and still have been advocating for J.P. Morgan to keep his accounts.
p. 127AI may or I may not have.
p. 127Ms. Stansbury.Hello.
p. 127Mr. Staley.Hello.
p. 127Ms. Stansbury.It's been a long day. My questions are a little more narrative and broad in scope than the specificity of interactions trying to really piece together some of the stories and timeline. But my opening question is really I am curious about your relationship with Epstein's trusts. Are you --
p. 128Mr. Staley.His trusts?
p. 128Ms. Stansbury.His trusts. Are you affiliated with any trusts currently or have you been over the last 10 years?
p. 128Mr. Staley.Currently, no. And at the time of --
p. 128Ms. Stansbury.Or, I'm sorry, since 2019, since he's died.
p. 128Ms. Staley.I believe that there was a time when I was a signator where I signed as either executor or trustee to his trust.
p. 128Ms. Stansbury.And is that his personal estate trust?
p. 128Mr. Staley.I believe it was.
p. 128Ms. Stansbury.Okay. And so you were one of the three executors of that trust?
p. 128Mr. Staley.At a point in time.
p. 128Ms. Stansbury.Okay.
p. 128Mr. Staley.But then I declined it.
p. 128Ms. Stansbury.Did -- oh, go ahead.
p. 128Mr. Staley.So I declined it, and ultimately was not and am not an executor or trustee, nor have I ever received compensation as such.
p. 128Ms. Stansbury.So that is my next question. Have you received any compensation from his estate --
p. 128Mr. Staley.No.
p. 128Ms. Stansbury.-- since 2019?
p. 128Mr. Staley.No.
p. 129Ms. Stansbury.Okay. Going back to the questions about J.P. Morgan. And just to reiterate, so J.P. Morgan began its relationship with Mr. Epstein several years before you took over that account, correct?
p. 129Mr. Staley.Yes.
p. 129Ms. Stansbury.Okay. And just trying to understand your management of Mr. Epstein's account. I understand you were an executive as opposed to kind of a day-to-day account manager. So what was the nature of your management of that relationship? Or what did it entail?
p. 129Mr. Staley.I was introduced to J.P. Morgan by -- or to Jeffrey Epstein by the then-CEO of J.P. Morgan with the idea that Jeffrey had a network of ultra high net worth individuals, particularly in New York, that might benefit the Private Bank. So it was around those contacts, and we went through a list of wealthy, influential people that he introduced to us.
p. 129Ms. Stansbury.Did you not oversee or manage in any way the transactions of Epstein's --
p. 129Mr. Staley.No.
p. 129Ms. Stansbury.-- personal or business accounts?
p. 129Mr. Staley.No.
p. 129Ms. Stansbury.Did you ever --
p. 129Mr. Staley.I had no involvement in his individual accounts.
p. 129Ms. Stansbury.Did you have any knowledge of how those accounts were being financially managed, the source of wealth --
p. 129Mr. Staley.No.
p. 129Ms. Stansbury.-- how wealth was being moved?
p. 129Mr. Staley.No. I always had a question about how he -- how -- where his wealth came from. The only thing I was aware of was he had a close relationship with Les Wexner.
p. 129Ms. Stansbury.And so your management of the relationship with Mr. Epstein was more of a kind of glad-handling, business management, client management kind of relationship? Is that what you would say? Or how would you describe it?
p. 130Mr. Staley.Just knowing or having a relationship with a client of the Private Bank who had an incredible network and was willing to share that network with the bank. And then, as I said earlier, he was instrumental in a very important transaction for J.P. Morgan and for my career in about 2004.
p. 130Ms. Stansbury.What transaction was that?
p. 130Mr. Staley.Which is the acquisition of Highbridge Capital Corporation.
p. 130Ms. Stansbury.Okay.
p. 130Mr. Staley.So Morgan was a traditional asset management firm. Back then, tradition asset managers like Fidelity and Capital would not mix with alternative asset managers. And this really was the first time in the industry that that happened, and it changed dramatically the trajectory of Morgan's asset management business.
p. 130Ms. Stansbury.Okay. And in terms of your relationship, I mean, whether it was personal or not personal, whether it was business, you did travel to Mr. Epstein's island on several occasions, correct?
p. 130Mr. Staley.I went there once with my family. I stopped there once for a couple hours for a lunch. And then I transited from -- I used his island as a transit to St. Thomas on a helicopter. But in terms of the visit per se --
p. 130Ms. Stansbury.And was Mr. Epstein present during any of those visits?
p. 130Mr. Staley.So in terms of the visit per se, I would say only once.
p. 130Ms. Stansbury.Okay. Sorry. Was Mr. Epstein present during any of those visits?
p. 130Mr. Staley.During the visit with my family, yes, he was there. And when we stopped by for lunch, he was there.
p. 130Ms. Stansbury.And you visited Mr. Epstein's townhouse a number of times, correct?
p. 131Mr. Staley.Correct.
p. 131Ms. Stansbury.Did you ever attend any social functions at his house that might be characterized as parties or dinners or anything like that?
p. 131Mr. Staley.Lunches or dinners, yes. Parties? I wouldn't characterize them as parties.
p. 131Ms. Stansbury.Did you ever witness any women there in a social capacity during your time at the island or at the townhouse in New York?
p. 131Mr. Staley.No. Some of his guests, like at a lunch, would be women from academia or the media. I can give you names.
p. 131Ms. Stansbury.And then I just want to go back to the peculiar exchange via email in 2010. Why were you emailing Jeffrey Epstein about women and referring to these women by Disney characters?
p. 131Mr. Staley.By what?
p. 131Ms. Stansbury.By Disney character names, like Snow White. Just why? I mean, just to help us understand why.
p. 131Mr. Staley.Yeah, again, I don't recall Snow White. It's over a 15-year period and thousands of emails. There's one email I don't recall.
p. 131Ms. Stansbury.Just give us a little insight. Why would you have been emailing Mr. Epstein about women and calling them these kind of nicknames?
p. 131Mr. Staley.Again, I don't -- it may have happened on one or two occasions. I don't think I made a practice of doing that.
p. 131Ms. Stansbury.I'm sorry, say that again.
p. 131Mr. Staley.I don't think I did that as a practice.
p. 131Ms. Stansbury.Well, we have -- the emails were just presented to you.
p. 131Mr. Staley.Yes, but --
p. 131Ms. Stansbury.You're not going to answer the question?
p. 133QDo you know if Jeffrey Epstein was involved in securing her apartment lease at East 301 66th Street?
p. 133AI was aware that the apartment was owned by his --- or the apartment building was owned by his brother and so there was that connection.
p. 133QBut do you know if Mr. Epstein was directly involved in lease at the building?
p. 133AI don't know.
p. 133QDo you know if he paid her rent?
p. 133AI do not know.
p. 133QDid he direct her to live there?
p. 133AI don't know.
p. 133QThat's all.
p. 133QMr. Staley, bear with me if I ask you any repetitive questions to make sure the record is clear. You mentioned that Mr. Epstein explained he would use cash withdrawals for flight fuel. Did you ever alert him that his cash withdrawals were flagged by the bank as suspicious?
p. 133AI think Paul Morris did.
p. 133QDid you?
p. 133AI don't know if I had a conversation with Jeffrey about the cash withdrawals. I think they were a red flag and the bank should notice it. So I probably did.
p. 133QDid you ever alert Mr. Epstein that he was categorized as a high-risk client?
p. 133AI believe so, yes.
p. 133QWhen would this have been?
p. 133AAfter 2006, I think.
p. 133QWhat was his response?
p. 134AI don't recall.
p. 134QDid he ask you to give any input with the bank in their consideration of his categorization?
p. 134ANo.
p. 134QDid you ever advise Mr. Epstein on how to structure cash withdrawals?
p. 134ANever.
p. 134QDid you ever advise Mr. Epstein on how to avoid flags by J.P. Morgan?
p. 134ANever.
p. 134QDid you ever advise Mr. Epstein on how to change his categorization as a high-risk client?
p. 134ANever.
p. 134QIs there any appeal process at J.P. Morgan for a client who is flagged as high risk?
p. 134AAn appeal process?
p. 134QUh-huh.
p. 134AI imagine someone could go to the compliance department or legal department and ask for it to be reviewed, but I don't know that there is a formal appeal process.
p. 134QHave you ever asked Mr. Cutler to hear out any other client who is at risk of losing their membership at J.P. Morgan?
p. 134ANot that I recall.
p. 134QWhy did you do this for Mr. Epstein?
p. 134AI knew him. You know, again, he made important referrals to the bank. And so I asked Steve Cutler to get involved. And also Epstein I think had hired some very high-profile lawyers and I thought that they could connect with Steve Cutler to get to the right conclusion.
p. 134QDo you think the fact that Mr. Cutler met with Mr. Epstein on this swayed the bank's decision to retain Mr. Epstein as a client?
p. 135AI think Steve Cutler would have had the authority to change the bank's position if he felt that that was necessary.
p. 135QDid you ever hear about what the conversation between Mr. Epstein and Mr. Cutler was?
p. 135ANo. Not that I recall.
p. 135QDid you hear that they did have a meeting?
p. 135AI believe that they met, yes.
p. 135QWas Mr. Epstein always with the Private Bank of J.P. Morgan?
p. 135AAs opposed to?
p. 135QAny other division at J.P. Morgan.
p. 135AYes, it was always the Private Bank.
p. 135QHave you ever interacted with Mr. Indyke, Richard Indyke?
p. 135AI think I met him, but I wouldn't say I interacted with him.
p. 135QI apologize. Have you ever interacted with Darren Indyke?
p. 135AOh. I wouldn't say interact with him. I crossed him in Mr. Epstein's office once or twice, but didn't interact with him.
p. 135QHave you ever interacted with Richard Kahn?
p. 135ANo.
p. 135QDid you ever work with Darren Indyke on a transaction for Mr. Epstein?
p. 135ANo.
p. 135QWere you ever trained on suspicious activity report requirements?
p. 135AYou know, I had to pass things like Series 7 exams and other exams and whatnot. But I don't know if I had a specific course.
p. 135QDid you ever discuss requirements with Mr. Epstein?
p. 136ANo.
p. 136QDo you still bank with J.P. Morgan?
p. 136ANo.
p. 136QWhy did you change banks?
p. 136AI was asked to withdraw my accounts.
p. 136QBy who?
p. 136ABy J.P. Morgan.
p. 136QBy who at J.P. Morgan?
p. 136AI don't recall.
p. 136QWhy did they ask you to withdraw your accounts?
p. 136AI think because of the issues around Epstein.
p. 136QDoes J.P. Morgan blame you for their reputational damage caused by Mr. Epstein?
p. 136AI believe they have, yes.
p. 136QDo you agree with them on that?
p. 136ANo.
p. 136QWhat do you think J.P. Morgan could have done differently?
p. 136AI think, as I said, everything from rapid response teams to compliance, to legal, to credit, you have this enormous infrastructure in the bank. The banking team itself, they were responsible for his accounts, knowing what's going on in accounts, monitoring his accounts. I was the senior executive for most of the time running the Investment Bank. And yet, the bank places responsibility on my shoulders as opposed to what clearly was the responsibility of the bank.
p. 136QDid you ever tell anyone at the bank that they should react differently?
p. 136AAgain, I was running the Investment Bank, but clearly encouraged the bank to do its investigations, to manage the account properly, to file the proper reports with the authorities, and to do the right thing.
p. 137QWho did you make these requests to?
p. 137AI think it would have been in the conversations with people like Steve Cutler, like Langford, like Mary, and others.
p. 137QWhy then ask Steve Cutler to hear Mr. Epstein out if you think they should have acted differently in retaining him as a client?
p. 137AI think one doesn't have to do with the other. Just having the chief counsel of the bank listen to Jeffrey Epstein before the bank makes -- or as the bank makes its decision what to do with his accounts made sense. The bank would be most informed, the most senior officer responsible for it would be informed, and they would hopefully make the right decision.
p. 137QDid you ever loan Mr. Epstein money?
p. 137ANo.
p. 137QAre you aware of Mr. Epstein exerting influence on J.P. Morgan to convince them to grant loans?
p. 137ANo.
p. 137QDid Mr. Epstein ever procure loans for Leon Black from J.P. Morgan?
p. 137ADid he ever procure loans? Leon Black borrowed in his own right.
p. 137QDid Mr. Epstein say anything to J.P. Morgan to influence their granting of a loan to Leon Black?
p. 137ANot that I'm aware of.
p. 137QWere you involved in any loans for Leon Black?
p. 137ADirectly, no.
p. 137QHow were you involved indirectly?
p. 137AIndirectly? No, I was not involved with loans to Leon Black.
p. 137QWho would have been responsible for handling loans for Mr. Black?
p. 138AHis bankers in the credit department.
p. 138QWho was his banker?
p. 138AI don't know.
p. 138QWas it Justin Nelson?
p. 138AIt could have been at one point, yes.
p. 138QDid you ever speak to Mr. Nelson about loans for Leon Black?
p. 138ANot that I recall, no.
p. 138QDid Mr. Epstein speak with Mr. Nelson about loans for Leon Black?
p. 138ANot that I know of.
p. 138QDid you ever ask J.P. Morgan to grant Mr. Epstein a loan?
p. 138ANo. I know he asked for a loan, but I believe it was -- no. But, no, I did not ask the bank to grant Epstein a loan.
p. 138QWhat did he ask for a loan for?
p. 138AAgain, I'm not sure. I think at one point he asked whether the bank would extend credit to a modeling agency.
p. 138QHow did you become aware of that?
p. 138AI don't know. My recollection is through the press.
p. 138QWere you ever made aware of his request for a line of credit during your time at J.P. Morgan?
p. 138AI believe so, yes.
p. 138QWho would have told you?
p. 138AI don't know.
p. 138QDid you work on granting this line of credit?
p. 138ANo.
p. 138QThe New York Times has reported that J.P. Morgan provided financial backing for Mr. Epstein to help Jean-Luc Brunel start a modeling agency called MC2. Some of Mr. Epstein's underage victims said MC2 lured them to the United States with the prospect of paid modeling work. And Brunel was arrested in France in 2022 for charges of raping teenage girls. Who authorized the line of credit?
p. 139AI don't know.
p. 139QHave you ever met anyone who worked for MC2?
p. 139ANo.
p. 139QHave you ever met Jean-Luc Brunel?
p. 139ANo.
p. 139QWere you aware of the DOJ's investigation into whether Mr. Brunel's MC2 modeling agency was feeding girls and women into Mr. Epsteins' suspected sex trafficking network?
p. 139ANo.
p. 139QWas anyone aware of this investigation at J.P. Morgan?
p. 139AI don't know.
p. 139QDid Mr. Epstein ever try to secure banking ties at Barclays in any way once you became CEO?
p. 139ANo.
p. 139QDid you ever discuss Barclays with Mr. Epstein?
p. 139AYes.
p. 139QWhat did you discuss?
p. 139AWe discussed the discussions I had with Barclays in 2012. And then I told Epstein, when I was offered the job in 2015, that I would cease all contact and relationships with him.
p. 139QDid Mr. Epstein ask why?
p. 139ANo. I think it was obvious why.
p. 139QHow did he respond?
p. 140AHe understood.
p. 140QWhere were you when you told him this?
p. 140AI believe I was in New York. It was by phone.
p. 140QOkay. A crucial part of the committee's investigation is to better understand how Jeffrey Epstein and Ghislaine Maxwell used their connections to prominent individuals to curry favor and shield themselves from scrutiny. I am going to read you a list of names. Please say yes or no to the following question and then I will ask you to elaborate. The question is, have you ever met with or communicated with any of the following people regarding any crimes committed by Jeffrey Epstein or Ghislaine Maxwell? Frederic Fekkai?
p. 140ANo.
p. 140QPhilip Levine?
p. 140ACan you ask the question again?
p. 140QYes. The question is, have you ever met with or communicated with any of the following people regarding any crimes committed by Jeffrey Epstein or Ghislaine Maxwell. Frederic Fekkai?
p. 140ANo.
p. 140QPhilip Levine?
p. 140ANo.
p. 140QAndrew Mountbatten-Windsor, formerly known as Prince Andrew?
p. 140ALet's come back to his name.
p. 140QSultan Ahmed bin Sulayem?
p. 140ANo.
p. 140QJean-Luc Brunel? A No. Q Leon Black? A No. Q Terje Rod-Larsen? A Go back to his name again, please. Q Okay. Terje Rod-Larsen? A No. Q George Mitchell? A No. Q Glenn Dubin? A Let's go back to him as well. Q Eva Andersson-Dubin? A Back to her as well. Q Sergey Brin? A No. Q Mort Zuckerman? A No. Q Peter Mandelson? A No. Q Andrew Farkas? A No. Q Boris Nikolic? A No. Q David Gergen? A No. Q Larry Summers? A No. Q Les Wexner? A No. Q Jack Kessler? A No. Q Steve Sinofsky? A No. Q Kathryn Ruemmler? A No. Q Harvey Weinstein? A No. Q Woody Allen? A No. Q Bill Gates? A No. Q Elon Musk? A No. Q Bill Richardson? A No. Q Ariane de Rothschild? A No. Q Any other member of the Rothschild family? A No. Q President Bill Clinton?
p. 143ANo.
p. 143QSecretary Hillary Clinton?
p. 143ANo.
p. 143QDoug Band?
p. 143ANo.
p. 143QTed Waitt?
p. 143ANo.
p. 143QEhud Barak?
p. 143ANo.
p. 143QBenjamin Netanyahu?
p. 143ANo.
p. 143QOkay. Returning to --
p. 143AIf you can ask the question again.
p. 143QSure. Have you ever met with or communicated with any of the following people regarding any crimes committed by Jeffrey Epstein or Ghislaine Maxwell?
p. 143AOkay.
p. 143QAndrew Mountbatten-Windsor, formerly known as Prince Andrew?
p. 143ANo.
p. 143QLeon Black?
p. 143ASkip it. We'll go back to that.
p. 143QGlenn Dubin?
p. 143ANo.
p. 143QEva Andersson-Dubin? You could also tell us what you do know and that would be helpful for the committee's investigation.
p. 144ADo I know?
p. 144QIf you recall speaking to them at a different time period about the crimes. Anything you recall.
p. 144ANo, I think I would have talked with Glenn and Eva. I think I had -- I think I talked to Leon Black. So those three, yes. Let's keep going.
p. 144QThose are all of the ones you asked me to return to. So Prince Andrew?
p. 144ANo.
p. 144QSo regarding Leon Black, what did you discuss?
p. 144AI just think we discussed -- again, I don't -- the crimes that Epstein was brought down with, that's what I think we discussed.
p. 144QAnd when was this?
p. 144AI don't know exactly when it was.
p. 144QWas it after his 2008 conviction?
p. 144AYes, yes.
p. 144QWhere were you?
p. 144AI don't recall.
p. 144QWho else was present?
p. 144AI don't think anybody was.
p. 144QWhat did Leon Black say?
p. 144AI don't recall.
p. 144QWhat was his attitude towards Mr. Epstein's conviction?
p. 144AOh, I think -- I don't -- I'm not going to characterize -- I don't know.
p. 144QHow did you perceive his reaction to be?
p. 145AI think we were all: It was terrible what he was convicted of and it was a horrible thing what Epstein did. I think we both responded to how -- we both knew him and both responded to how terrible his actions were or what he did. Are you talking about 2019?
p. 145QIt could also be 2019. Any of the crimes of Mr. Epstein, Ghislaine Maxwell, have you discussed them with Leon Black?
p. 145A2019? No.
p. 145QGlenn Dubin?
p. 145AI don't -- again, 2019, I'm sorry. It possibly was 2019.
p. 145QAnd when would this have been?
p. 145AWith Glenn Dubin?
p. 145QWhen would you have discussed the 2019 --
p. 145AI don't --
p. 145Q-- crimes with Leon Black?
p. 145AI don't recall.
p. 145QBut you recall you did discuss them with Mr. Black?
p. 145A2019 crimes? Yeah, I don't recall if I did. So I would scratch Leon Black. I would say with Glenn and Eva Dubin.
p. 145QBut you did meet with Mr. Black about the 2008 conviction?
p. 145AI met with Leon Black about business and other things and we may have talked about it, but I didn't meet him for the purpose of talking about 2008 or 2019.
p. 145QWhat did you discuss with Glenn Dubin?
p. 145AGlenn and Eva and I are good friends. I think we just talked about Epstein overall. We didn't talk any specifics about the crimes committed and whatnot, but just -- it impacted both of our lives dramatically. I think we talked about that.
p. 146QHow did it impact their lives dramatically?
p. 146AI think both the Dubins and I have been ostracized by part of society, have been excluded from institutions that we were a part of before. So investments that we've made we've had to turn away from.
p. 146QHow did you -- have you met Benjamin Netanyahu?
p. 146AOnce.
p. 146QWhere was this?
p. 146AIn the Prime Minister's office in Israel.
p. 146QWho else was present?
p. 146AJust me.
p. 146QDid Mr. --
p. 146AI think he had, like, a secretary there as well.
p. 146QDid Mr. Epstein facilitate this meeting?
p. 146AYes, he did.
p. 146QWhy?
p. 146AI asked him to.
p. 146QWhy?
p. 146AI asked him to. He knew that I was trying to meet with the Prime Minister and I was having difficulty getting on his calendar. And I mentioned that to Epstein, and then I met with the Prime Minister.
p. 146QWhat was Mr. Epstein's relationship to Benjamin Netanyahu?
p. 146AI just think he knew him, that's all.
p. 146QHow would you characterize their relationship?
p. 146AI didn't know -- I wouldn't characterize it.
p. 146QWhy would you ask Mr. Epstein to help you get on his calendar?
p. 147AI think he had relationships with individuals in Israel. He knew Ehud Barak well. And I think he may have mentioned that he knew Benjamin Netanyahu. So I asked if he could help get me a meeting.
p. 147QWhen did you meet with Mr. Netanyahu?
p. 147AI don't recall.
p. 147QWhy were you attempting to get onto his calendar?
p. 147AI was visiting Israel on business and thought it would be of interest to meet with the Prime Minister.
p. 147QWould you say this was around March 2011?
p. 147AIt could have been.
p. 147QWhat did you discuss at the meeting?
p. 147AI just think we talked about the Middle East and geopolitics, nothing specific.
p. 147QWhy would Benjamin Netanyahu agree to meet with you when there was no set topic? What did he believe the reason was for the meeting?
p. 147AIt's possible -- I don't want to speculate. It was a long time ago.
p. 147QWhy was he also interested in meeting with you?
p. 147AThis is 2011?
p. 147QUh-huh.
p. 147AI was a senior executive of J.P. Morgan. J.P. Morgan had a lot of business in the Middle East.
p. 147Ms. Tolan.So you were meeting with him on behalf of J.P. Morgan?
p. 147Mr. Staley.Yes.
p. 147QHave you ever met with Benjamin Netanyahu with Mr. Epstein?
p. 147ANo.
p. 148QWhat was Mr. Epstein's relationship with Ehud Barak?
p. 148AI think they knew each other and Ehud Barak would visit Epstein when he came to New York occasionally.
p. 148QHave you taken a meeting with Ehud Barak and Mr. Epstein?
p. 148AI don't recall. I may have.
p. 148QWhat would you have met with Ehud Barak and Mr. Epstein about?
p. 148AJust talked about geopolitics.
p. 148QYou testified in a previous hour that you have had interactions with foreign intelligence agents. Did you have any reason to --
p. 148ANo, I didn't say foreign intelligence agents. I said the CIA and the State Department, not foreign agents.
p. 148QOkay.
p. 148Mr. Emmer.During your interactions with Ehud Barak and Jeffrey Epstein, did you ever discuss anything that related to foreign intelligence?
p. 148Mr. Staley.No.
p. 148QOn July 6th, 2019, Mr. Epstein was arrested at Teterboro Airport on Federal sex trafficking charges. When did you first become aware of the charges?
p. 148AI believe when he got arrested.
p. 148QHow?
p. 148AThe press.
p. 148QDid anyone tell you directly? Did anyone verify what was in the press?
p. 148ANo.
p. 148QWhen you learned of the gravity of what he was being charged with, what did you do next?
p. 149AI had no contact with Epstein at that time. I was running the bank in London, so I did nothing specifically related to the fact that he got arrested.
p. 149QDid you reach out to anyone in Epstein's orbit to test the veracity of the allegations he was faced with?
p. 149ANo.
p. 149QDid you ever visit Mr. Epstein at the Metropolitan Correctional Center?
p. 149ANo.
p. 149QCan you describe your communications with Mr. Epstein in the days between his arrest in July 2019 until his death?
p. 149ANone.
p. 149QDid any alleged victim of Mr. Epstein contact you after his arrest?
p. 149ANo.
p. 149QI believe you testified to this in a previous hour, but have you ever been appointed as a trustee by Mr. Epstein?
p. 149AI was appointed as an executor of his estate at a point in time. And then I resigned and at the end was not an executor or trustee to his estate.
p. 149QWould it be accurate to say you signed as a trustee in November 2014 for the Epstein 2014 Trust and you also signed an amendment to this trust in September 2015?
p. 149AYes.
p. 149QWhat were your duties and responsibilities?
p. 149ANone.
p. 149QWho asked you to be trustee?
p. 149AI believe Epstein did.
p. 149QWhy?
p. 150AI was a senior person in finance. So I think he trusted my judgment. But ultimately I declined.
p. 150QWhy?
p. 150ABecause I didn't want to be associated with the Epstein estate.
p. 150QWas it related to your agreement with Barclays in 2015?
p. 150ANo, I think it was just I didn't want to be part of his estate.
p. 150QWhat was the Epstein 2014 Trust for?
p. 150AI don't recall.
p. 150QWhy would you not want to be associated with the estate?
p. 150ABecause of his convictions and what he was -- because of his convictions.
p. 150QWhat changed in 2014 to result in your belief that you'd prefer to be separated from the estate?
p. 150AThe passage of time and wanting to be -- and realizing that I need to separate myself from Epstein.
p. 150QDid you hear any rumors of other allegations at that time?
p. 150ANo.
p. 150QWere you ever compensated for serving as trustee?
p. 150ANo.
p. 150QWho first told you of your appointment to his estate?
p. 150AI don't recall.
p. 150QWere you aware of civil litigation against Mr. Epstein at the time you asked to cease communications with him?
p. 150ANo.
p. 150QMr. Epstein also appointed Lawrence Summers as an executor of his estate in 2014, though he was also not named in the will from 2019. Were you ever aware of Mr. Summers' designation in 2014?
p. 151AI may have been, but I don't recall.
p. 151QWho would have told you?
p. 151ALarry Summers.
p. 151QWhat was your relationship with Larry Summers?
p. 151AWe knew each other. I think I met him in his capacity at Harvard. And I believe we met when he was Secretary of Treasury as well.
p. 151QWho introduced you to Mr. Summers?
p. 151AI think we just met because we are in the same -- I think our paths just crossed. Nobody made the introduction per se.
p. 151QWhat was Mr. Summers' relationship with Mr. Epstein?
p. 151AI don't know.
p. 151QWould you agree that his designation as executor of Mr. Epstein's estate means he was someone trusted by Mr. Epstein?
p. 151ASure.
p. 151QAnd same question for yourself. Would you agree that you were highly trusted by Mr. Epstein to be appointed executor of his estate?
p. 151ASure.
p. 151QWhy do you think that is?
p. 151ABecause I think when you appoint someone as an executor of your estate, you trust them.
p. 151QNow, why did Mr. Epstein trust you to that degree?
p. 151AThe same answer.
p. 151QWhat answer is that?
p. 151AOh, I think he saw me as someone who's trustworthy. [Discussion off the record.]
p. 152Ms. Brignac.We will go back on the record.
p. 152QHave you had any conversations with Mr. Summers about the estate?
p. 152AOne thing I want to clarify is I did not see the documents with respect to his estate and so I don't recall the documents, just to be clear on that.
p. 152QDid you ever discuss the estate with Mr. Summers?
p. 152ANo.
p. 152QWhen did you learn of Mr. Epstein's death?
p. 152AI believe the day he died.
p. 152QHow did you learn?
p. 152AMy wife told me that she heard it.
p. 152QWho did she hear it from?
p. 152AI don't know.
p. 152QWhat did you do after you hearing about his death?
p. 152ANothing.
p. 152QWho did you speak to next?
p. 152AI don't recall.
p. 152QDid Mr. Epstein demonstrate suicidal tendencies in all the years you've known him?
p. 152ANo.
p. 152QDo you believe Mr. Epstein committed suicide?
p. 152AYes.
p. 152QWhy?
p. 152AThat's what the police say.
p. 152QHow many lawsuits have you ever appeared as the defendant in?
p. 153AI think the lawsuit of the U.S. Virgin Islands against J.P. Morgan, I believe I was a named defendant.
p. 153QIs that the only one?
p. 153ANo, I think there is a current lawsuit against Barclays where I am a named defendant. Those would be the two.
p. 153Mr. Sullivan.We can clarify that for you on the record. He was not a defendant. He was a third-party defendant in the J.P. Morgan lawsuit. And there is one other class action that relates to stock, which we can provide.
p. 153QHow many lawsuits are you named as the defendant and related to your work with Mr. Epstein?
p. 153AI don't believe any.
p. 153QHow many lawsuits are you listed as the defendant in that reference sexual abuse?
p. 153AI believe one.
p. 153QAt any point, have you or any of your representatives or agents secured a settlement in connection with Mr. Epstein, Ghislaine Maxwell, or any of their victims?
p. 153ANo.
p. 153QReporting in documents reviewed by this committee reflect that a victim of Mr. Epstein settled with his estate and received 6 million as part of the victims' compensation fund. However, Mr. Staley, you and Leon Black are explicitly carved out of this settlement, and the effect of this carve-out allows the victim to sue you and Mr. Black in the future. Why were you carved out of this settlement?
p. 153AI don't know.
p. 153QWhen did you become aware you were carved out of the settlement?
p. 153Mr. Sullivan.That is probably privileged.
p. 154QDid anyone besides your attorney tell you you were carved out of the settlement?
p. 154ANo.
p. 154QWho is the victim in that settlement?
p. 154AI don't know.
p. 154QWhich case are you listed in that relates to sexual abuse?
p. 154Mr. Sullivan.It's a little confusing. Maybe we can help, if you'd care to hear from me quickly on that. The J.P. Morgan lawsuit is dismissed. He was a third-party defendant. J.P. Morgan settled. There was no claim against him by a victim in the sense of he would pay anything. So it was a third-party complaint. The case is settled. Mr. Staley paid nothing. Secondly, there is a class action, the essence of which is -- and that is on the West Coast -- and that is a claim that Barclays and Staley combined failed to provide accurate information about the relationship. And there is one other one we are just finding out about that seems to be -- I'm not even sure what it is. But I can find it.
p. 154Ms. Brignac.Mr. Staley, which case were you referring to when you said you're listed in one case related to sexual abuse?
p. 154Mr. Staley.The one filed against J.P. Morgan. [Staley Majority Exhibit No. 9. was marked for identification.]
p. 154Ms. Brignac.I am entering majority exhibit 9 from The Wall Street Journal. We'll go off the record. [Discussion off the record.]
p. 155QMr. Staley, who is the woman in this photograph?
p. 155AI believe it's . Is that right?
p. 155QHave you ever met this woman before?
p. 155AI just recognize another photo that I have been shown by my lawyers that she is in, but I don't recognize her per se, no.
p. 155QHave you ever had sex with this woman?
p. 155ANo.
p. 155QThe committee has identified this woman to be , the same woman who is dressed in the Snow White costume. Have you ever seen this woman dressed in a Snow White costume?
p. 155ANo.
p. 155Ms. Brignac.That will conclude the majority's questions. We'll go off the record. [Recess.] . We're back on the record. [Staley Minority Exhibit S. was marked for identification.] BY :
p. 155QMr. Staley, I would like to pick up where we left off, which is around 2008. I would like to introduce as minority exhibit S an internal J.P. Morgan document logging comments from rapid response meetings about Mr. Epstein. The document we are handing you is an excerpt of a larger document. On page 15, there is an entry from July 15th, 2008. In one column it states, quote, "Follow up meeting after news that Epstein was sentenced to 12 months in jail for solicitation of a prostitute and six months for procuring a person under the age of 18 for prostitution." In a corresponding column it states, quote, "Catherine will go back to JES to tell him we are uncomfortable with Epstein and do not want to go to Cutler for approval." Catherine refers to Catherine Keating, correct?
p. 156ACould be.
p. 156QDo you know of another Catherine who was involved in Mr. Epstein's accounts at this time?
p. 156ANo.
p. 156QMs. Keating was head of J.P. Morgan's Private Bank starting in 2009, correct?
p. 156ACorrect.
p. 156QWho does the "we" in "we are uncomfortable with Epstein" refer to?
p. 156AI don't know.
p. 156QCould it refer to the employees at the Private Bank?
p. 156AYes.
p. 156QDo you remember Ms. Keating coming to you about Mr. Epstein during this period?
p. 156AI believe we talked about Epstein, yes.
p. 156QWhen was that?
p. 156AAgain, this is dated July 2008.
p. 156QJuly 15th, 2008, correct, but it says, "Catherine will go back to JES."
p. 156AI would say it is around that date.
p. 156QDo you remember what she said?
p. 156ANo.
p. 156QPresumably it was about Mr. Epstein, correct, and concerns that the Private Bank had with him?
p. 156AAnd whether they kept accounts with him, yes.
p. 156QAnd do you remember how you responded to those concerns?
p. 156AI think I was leaving it up to Cutler at that time.
p. 157QIf you were leaving it up to Mr. Cutler, then why does it say, "Catherine will go back to JES"? Clearly you are the person that she thinks she needs to go to here.
p. 157AI don't understand why it says -- this implies that she's not comfortable or they're not comfortable going to Cutler. I don't understand. He is the general counsel for the bank.
p. 157QDo you think it could also mean that they are contemplating going around you to Mr. Cutler if you did not agree to end J.P. Morgan's relationship with Mr. Epstein?
p. 157AI was all for them going to Cutler. I would not consider that going around me.
p. 157QYou previously testified that Mr. Cutler decided that J.P. Morgan should keep Mr. Epstein as a client following his guilty plea.
p. 157AAs a banking-only client, yes.
p. 157QCan you tell us what you remember about that decision or any conversation you had with Mr. Cutler at the time?
p. 157ANo. Again, it was Cutler's decision and I left it to Steve Cutler to make the decision. [4:16 p.m. ] BY :
p. 158QI'd like to introduce as minority exhibit T an internal due diligence report with an embedded article on Mr. Epstein titled, "The Sex Trafficking Model Scout," dated August 4th, 2010. The Bates number is EFTA02811303. [Staley Minority Exhibit T. was marked for identification.] BY :
p. 158QThis article describes the modeling agency MC2, which it notes that Mr. Epstein funded, and allegations that Mr. Epstein and Jean-Luc Brunel, quote, "deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money." The article further states that, quote, "civil complaints allege that young girls from South America, Europe, and the former Soviet Republic, few of whom spoke English, were recruited for Mr. Epstein's sexual pleasure." Do you recall having internal discussions about this article or the allegations it describes?
p. 158ANo.
p. 158QDo you recall having internal discussions about the modeling agency MC2?
p. 158ANo.
p. 158QIn a deposition in a class action against J.P. Morgan, you were asked whether you remembered hearing in 2010 about civil complaints that had been brought against Mr. Epstein. You testified that you did remember hearing about those lawsuits and that you discussed them with others at J.P. Morgan. So would you like to correct your answer?
p. 158ABut you were asking whether I was aware of this article about MC2, right?
p. 159QI asked if you recalled having any internal discussions about this article or the allegations that it describes.
p. 159AOr the allegations. Yeah, I may have had conversations about the allegations.
p. 159QIn your testimony in that class action, again, you said you remembered hearing about these lawsuits, that you discussed them with others at J.P. Morgan. You also testified that, quote, "It was terrible news and it was shocking. Obviously, he lied to me. That's what I recall." When you testified that Mr. Epstein lied to you, what exactly did you believe he lied to you about?
p. 159AIn 2006 he lied that he solicited underage prostitutes.
p. 159QIf you knew in 2010 that Mr. Epstein had lied to you about his victims' ages and you thought that it was terrible and shocking, as you said in your testimony, why did you continue to push for J.P. Morgan to keep Mr. Epstein as a client?
p. 159AI don't believe I pushed J.P. Morgan to keep Epstein as a client. And, again, I was running a completely different part of the bank. Was not involved in his accounts or his business at all with the bank.
p. 159QTo be clear, you are saying that you do not believe that you pushed J.P. Morgan to keep Mr. Epstein as a client?
p. 159AThat's correct. [Staley Exhibit U. was marked for identification.] BY :
p. 159QI would like to introduce as minority exhibit U an email chain between J.P. Morgan employees, including William Langford, Phillip DeLuca, Nina Nichols, Maryanne Ryan, and Arthur Middlemiss from January 7, 2011. . I believe the email chain starts on the last page. . We'll go off the record briefly to give you a minute to review it. [Discussion off the record.] . We're back on the record. BY :
p. 160QIn the first email of the chain, Ms. Ryan sends Mr. DeLuca a summary of a rapid response meeting on Mr. Epstein. In the third paragraph, she says, quote, "Jeffrey is a friend of Jes S. and Catherine feels that PB, along with William, should meet with him to explain the HT project and explain the bank's recognition on the project and whether Epstein, if further exposed, could have a potential serious impact." First, we understand that Catherine refers to Ms. Keating, that William refers to William Langford, J.P. Morgan's director of anti-money laundering, that PB refers to Private Bank, and that HT project refers to human trafficking project. So according to Ms. Ryan, Ms. Keating believed that she, along with Mr. Langford, needed to meet with you to explain J.P. Morgan's human trafficking project and the impact that Mr. Epstein's crimes, if further exposed, could have on the project, correct?
p. 160AYes.
p. 160QWould you agree that this statement makes clear that at this point in early 2011, J.P. Morgan already suspected that Mr. Epstein was engaging in sex trafficking?
p. 160AYes.
p. 160QIn the next paragraph, Ms. Ryan says, quote, "Epstein was released in July from house arrest, and the Palm Beach Post carried two articles saying DOJ may be investigating for child trafficking via a modeling agency he is part owner in. I think Catherine believes that after the briefing on HT that Jes would need to, point-blank, ask Jeffrey the status of any criminal investigations." Did you ask Mr. Epstein about the status of any criminal investigations into him?
p. 161AI don't recall.
p. 161QYou have no memory of asking Mr. Epstein in early 2011 about investigations into him, specifically criminal investigations for sex trafficking?
p. 161AObviously, I was aware of it. He was being investigated. I don't recall if I had specific conversation with him.
p. 161QMs. Ryan continues, quote, "Catherine made sure we knew that no one on today's call was in favor of having retained him as a client. Seems it all is due to Jes's personal relationship. Note, he has about 212 mil in the bank." Would you agree that at this point J.P. Morgan's retention of Mr. Epstein as a client was due to your personal relationship with him?
p. 161ANo. No, I would not.
p. 161QWhat was it due to?
p. 161AI think the bank had full authority to close his accounts and close his business. It was not up to me to make a decision. I was not involved in the decision. I wasn't in the rapid response team. I wasn't involved in any of this process. I knew Epstein, but I think the bank and the people, from Catherine Keating on down, had the authority to close the accounts and chose not to. But I think they significantly restricted his activities with the bank.
p. 161QYou're mentioned throughout this email, though, multiple times --
p. 161AAgain --
p. 161Q-- by multiple people. Clearly, you are central --
p. 161A-- people --
p. 161Q-- to this entire decision.
p. 161ANo.
p. 162Mr. Sullivan.Question, answer.
p. 162Mr. Staley.No. BY :
p. 162QHow can you say you were not involved in it? And if you weren't involved in it, why are so many people talking about how they have to talk to you about Mr. Epstein?
p. 162AIn the meetings discussing -- discussing Epstein's accounts, was I in the meetings with all these people listed?
p. 162QWere you?
p. 162ANo.
p. 162QIn the last full paragraph of the email, Ms. Ryan says, quote, "The one new concerning thing is the one article about the DOJ investigation is saying they brought underage girls to the U.S. via a modeling agency, M2, that is owned by a guy named Brunel. Turns out the banker said today we extended Epstein a loan in relation to this modeling agency." We believe she means MC2. Would you agree that at this point in early 2011, J.P. Morgan had reason to believe that the bank had directly funded Mr. Epstein's sex trafficking operation?
p. 162AAgain, I was not part of this -- I was not part of this area of the bank any longer, so I -- you know, to ask me to tell you what the bank was thinking, it's more important you ask the bank.
p. 162QAt the bottom of the email, Ms. Ryan says, quote, "Bottom line, we need W to meet with Jes to explain HT and then Jes could decide the next steps." We understand this to mean that Mr. Langford needs to meet with you and explain human trafficking, and then you can decide next steps. As you have pointed out multiple times, you were the CEO of the investment banking division at this time, correct?
p. 162AYeah, not the Private Bank.
p. 162QSo you did not have authority over asset management or the Private Bank, correct?
p. 163AThat's correct.
p. 163QSo then why did J.P. Morgan's director of anti-money laundering, or anyone else for that matter, need to talk to you about Mr. Epstein?
p. 163AI think you should ask him.
p. 163QWhy would all of these people from different divisions at J.P. Morgan repeatedly talk about how they need to go to you to talk about Mr. Epstein, to explain human trafficking, if you do not have a significant role in the decision to keep Mr. Epstein as a client?
p. 163AAnd I think you need to ask them. But I did not have a significant role in the decision to keep Epstein as a client.
p. 163QIn the next --
p. 163AIt's a completely different -- completely different part of the bank.
p. 163QI'm sorry?
p. 163AIt was a completely different part of the bank than what I was responsible for.
p. 163QI understand that. In the next email on the chain, Mr. DeLuca forwards Ms. Ryan's email to Ms. Nichols, who is new on the team. He provides Ms. Nichols with some background information, including that Mr. Epstein, quote "is alleged to be involved in the human trafficking of young girls," and that Mr. Epstein, quote, "is also an alleged personal associate of the CEO of the investment bank (Jes Staley)." Do you agree that Mr. Epstein was a, quote, "personal associate" of yours?
p. 163AAgain, as I've said, we had a professional relationship. We obviously knew each other. I would not call it a personal friendship.
p. 163QI asked if you would agree that Mr. Epstein was a, quote, "personal associate" of yours?
p. 163AWhat does associate mean?
p. 163QHowever you understand that word.
p. 163AAgain, I think it was a relationship based on the business relationship that we had. I did not view him as a personal friend.
p. 164QMr. Langford then asks the individuals on the chain to pull prior emails and relevant press reports, quote, "so we can get all the facts ASAP in advance of any meeting with Jes." The team then exchanges emails about compiling information. Did Mr. Langford and management for the Private Bank meet with you at this point?
p. 164AI don't recall.
p. 164QYou have no recollection if they met with you and shared all of the facts relevant to Mr. Epstein's sex trafficking operation that they are discussing compiling in advance of a meeting with you?
p. 164AI don't.
p. 164QFinally, in the last email of the chain, Ms. Ryan explains that the renewed interest in Mr. Epstein was due to alerts for cash activity and that, in talking to J.P. Morgan employees, she learned that, quote, "PB was not so thrilled with retaining him. It was all due to Jes."
p. 164AThat's not fair.
p. 164QSo you dispute her characterization?
p. 164AYes.
p. 164QI'd like to introduce as minority exhibit V, a due diligence report for one of Mr. Epstein's accounts. The Bates number is EFTA02810567. [Staley Minority Exhibit V. was marked for identification.] BY :
p. 164QIf you're looking at the bottom of each page, on page 6 there, is an update dated January 27th, 2011, that says quote, "A few news stories during 2010 connects Jeffrey Epstein to human" --
p. 164Mr. Sullivan.I want to make sure we know what you're reading. Sorry. . If you look at the numbers at the bottom of the page --
p. 165Mr. Sullivan.Page 6. . Flip to page 6. A little further down than halfway down the page.
p. 165Mr. Sullivan.Okay. Thank you. Summary of findings? BY :
p. 165QIt says, quote, "A few news stories during 2010 connects Jeffrey Epstein to human trafficking. The coverage team, along with Catherine Keating and William Langford, all met to discuss the situation and agreed to enhance monitoring and document a discussion with the client. Jes Staley discussed the topic with Jeffrey Epstein, who replied there was no truth to the allegations, no evidence, and was not expecting any problems. We will continue to monitor the accounts and usage closely going forward?"
p. 165Mr. Staley.Is that the same date where I said he was shaken?
p. 165Mr. Sullivan.No. This is 11. BY :
p. 165QSo the outcome of the meeting with Ms. Keating and Ms. Langford, which I understand that you do not recall, but that they are clearly, at least Mr. Langford is emailing about, the outcome of this meeting appears to be that you would simply talk to Mr. Epstein. Do you remember whose idea that was?
p. 165ANo.
p. 165QDo you remember why the idea was for you to talk to Mr. Epstein and not someone in risk or compliance or legal or even someone at the Private Bank?
p. 165AAgain, by this time I think the decision was ultimately in the hands of Steve Cutler and, you know, the bank is -- you know, Langford and Catherine and whatnot are doing their reviews, and I was in another part of the bank, so --
p. 165QIf the decision was in the hands of --
p. 166Mr. Sullivan.Please let him finish. I'm sorry. . Excuse me, Mr. Sullivan?
p. 166Mr. Sullivan.Please let him finish.
p. 166Mr. Staley.So confusing the issue of me talking with Epstein about the accusations against him, it's not the same thing as the decision by the bank to keep him as a banking client only. I think you're pushing the two together. BY :
p. 166QI don't think I am.
p. 166ASorry.
p. 166QThe document says, "Jes Staley discussed the topic with Jeffrey Epstein." So whatever role you say Mr. Cutler had isn't relevant to what I am asking right now. I am asking why the idea was for you to talk to Mr. Epstein, as it says you did, instead of someone -- even put Mr. Cutler aside -- but instead of someone in risk or compliance or at the Private Bank, because, as you've pointed out multiple times --
p. 166AThey may have.
p. 166QPlease don't interrupt me. As you have pointed out multiple times, you were CEO of the investment banking division. So why are you asking Mr. Epstein about these allegations?
p. 166ABecause I knew Epstein, and I was asking about the allegations. But that is a separate issue from the activities of the Private Bank and what they should do with Epstein.
p. 166QSo as they are reviewing his accounts, they're pulling you in because of your friendship with Mr. Epstein and asking you to talk to Mr. Epstein about the allegations against him?
p. 166AAgain, and also in this document, we've talked about Steve Cutler, basically, controlling the decision of whether we keep Mr. Epstein as a client. We also had talked -- also talked about that Epstein had, you know, relations with other employees of J.P. Morgan, not just me.
p. 167QI understand that. I'm not sure it answers my question. Setting aside who has the authority to terminate a client relationship with Mr. Epstein --
p. 167ARight.
p. 167Q-- is it your testimony today that the reason that you are talking to Mr. Epstein about the allegations against him in this context is because he was your friend, and so your colleagues at J.P. Morgan who are tracking the issues with his accounts are going to you and saying, please talk to him about these allegations against him. I'm trying to understand why it's you who is talking to him instead of people in other more relevant divisions at J.P. Morgan.
p. 167AWe don't know -- I think he was talking to other people at J.P. Morgan.
p. 167QMaybe. But that's not what the document says. The document says, "Jes Staley discussed the topic with Jeffrey Epstein."
p. 167AYou were saying, why is it you as opposed to other people at Morgan. And I'm saying, I don't think it's as opposed to other people at Morgan. I think other people at Morgan had direct contact with him as well.
p. 167QDo you remember that, other people at J.P. Morgan going to Mr. Epstein and asking him about these allegations?
p. 167AYes.
p. 167QWho?
p. 167AMary Erdoes.
p. 167QAnyone else?
p. 167AI believe Justin Nelson. And then Steve Cutler, I think, had conversations with Epstein's lawyers. I'm not sure whether other lawyers were involved.
p. 167QIf these other people were talking to Mr. Epstein about the allegations against him, why do you think they are not mentioned in documents with the frequency that you are?
p. 168AAgain, I didn't write the documents.
p. 168QDo you remember talking to Mr. Epstein about the allegations against him, the conversation that's referenced here?
p. 168AI remember the one conversation I had with him when I said he was very shaken, and I think that was before this. But I don't know how the dates line up.
p. 168QWell, this update is from January of 2011. So, presumably, it would have been in that month or close to it.
p. 168AAnd the date on my saying he was shaken was what?
p. 168QI believe that was 2006.
p. 168ASo long before. Okay.
p. 168QSo you have no recollection of the conversation that this document indicates you had with Mr. Epstein in 2011 about the allegations against him?
p. 168ANo, I don't.
p. 168QAnd you have no recollection of whose idea it was to have you have this conversation with Mr. Epstein?
p. 168AAgain, I was in a completely different part of the bank. I don't.
p. 168QDo you think that it made sense to ask a potential sex trafficker if he was engaging in sex trafficking?
p. 168AAsk the question again.
p. 168QDo you think it made sense to ask a potential sex trafficker if he was engaging in sex trafficking as a form of due diligence?
p. 168AMakes sense.
p. 168QYou testified that by 2010 you knew Mr. Epstein had lied to you.
p. 168AYes.
p. 169QSo if you knew he had lied to you in 2010, why would it make sense to go to him in 2011 and ask him if he was engaging in sex trafficking?
p. 169AAgain, the issue was 2006, we learned what he did. He pled guilty. He went to jail. He served his time. It was inconceivable to me that he would continue in his sex trafficking after spending a year in jail, year on work release. It just -- you know, it didn't make sense to me.
p. 169QSo even though you knew he lied to you, you --
p. 169AIn 2006.
p. 169QIn 2006, yeah, right. You learned in 2010 that he lied to you in 2006. Even then you thought that it was inconceivable that he might lie to you again, and so having you go to him and ask him if he is engaging in sex trafficking is an adequate form of due diligence?
p. 169AAn adequate form of due diligence would be the Private Bank engaging with him and doing its due diligence. That's the proper form of due diligence. [Staley Minority Exhibit W. was marked for identification.] BY :
p. 169QI would like to introduce as minority exhibit W an email exchange between you and Mr. Epstein dated March 20th, 2011. The Bates number is EFTA00906898. In the first email, Mr. Epstein writes, quote, "I'm working on getting Steve Cutler the comfort he needs," to which you respond, quote, "Agree?" Was Mr. Cutler concerned about something related to Mr. Epstein?
p. 169AI think Steve Cutler had the ultimate decision as to whether we keep Epstein as a client. Also, I think around this time Epstein had hired a legal team, and I think that legal team was being set up to meet with Steve Cutler.
p. 169QIs that what Mr. Epstein was doing to get Mr. Cutler the, quote, "comfort that he needs"?
p. 170AI think so. [Staley Minority Exhibit X. was marked for identification.] BY :
p. 170QI would like to introduce as minority exhibit X an email chain with you, Mr. Cutler, Ms. Erdoes, James Condren, and Nina Shenker dated July 19th, 2011, a few months after Mr. Epstein told you that he was working to get Mr. Cutler the comfort he needed. BY :
p. 170QIn the most recent email, so at the top of the page, Mr. Cutler writes of Mr. Epstein, quote, "This is not an honorable person in any way. He should not be a client." So you have said multiple times today that Mr. Cutler had the authority to terminate a client relationship, correct?
p. 170AYes.
p. 170QIf Mr. Cutler had that authority, why didn't he use it?
p. 170AI don't know.
p. 170QDid you exert influence over Mr. Cutler to keep Mr. Epstein as a client?
p. 170ANo.
p. 170QYou left J.P. Morgan in early 2013, correct?
p. 170ACorrect.
p. 170QAnd then J.P. Morgan terminated its relationship with Mr. Epstein in the summer and fall of that year, correct?
p. 170AYes.
p. 170QWhy do you think that J.P. Morgan only removed Mr. Epstein as a client once you left the bank?
p. 171AI don't know.
p. 171QYou don't think those two things are connected?
p. 171ANo.
p. 171QWould you agree that Mr. Epstein had a vast network of people he was connected to in industries, including finance, politics, entertainment, and academia?
p. 171AYes.
p. 171QWould you agree that Mr. Epstein frequently leveraged those connections to broker meetings, share business intelligence, and trade favors?
p. 171AI'm not sure I'd say trade favors.
p. 171QSure. Would you agree that Mr. Epstein frequently leveraged these connections to broker meetings and share business -- excuse me -- share business intelligence?
p. 171AI think he brokered meetings with his network because of what he knew and his influence.
p. 171QAnd he shared business intelligence; would you agree with that?
p. 171AI'm not quite sure what you mean by business intelligence. But, you know, views about business or whatnot, yes. But if the implication is that he was using it to pass on nonpublic information, no.
p. 171QYou don't think he passed on nonpublic information?
p. 171ANot that I'm aware of.
p. 171QWould you agree that Mr. Epstein used his vast network of people and the connections that he had to stay not just relevant but powerful despite being a -- excuse me -- despite being a convicted sex offender?
p. 171AI think he kept a network that gave him a certain aura. I'm not sure I'd characterize it as power. I don't think he had power over anybody.
p. 171QYour attorney argued before the financial conduct authority that, quote, "Mr. Epstein traded and influenced and relied on his network for his legitimacy." Would you agree with that statement?
p. 172AYes.
p. 172QDid you ever share confidential information about J.P. Morgan with Mr. Epstein?
p. 172AYes.
p. 172QDid you ever share other confidential information with Mr. Epstein, so not necessarily related to J.P. Morgan?
p. 172ANo.
p. 172QAnd you said previously you are not aware of Mr. Epstein sharing or trading on information generally?
p. 172AThat's correct.
p. 172QSo, presumably, you're not aware of Mr. Epstein sharing or trading on information that you gave him?
p. 172ACorrect. [Staley Minority Exhibit Y. was marked for identification.] BY :
p. 172QI would like to introduce as minority exhibit Y an email exchange between you and Mr. Epstein dated August 21st, 2008, and an email that you sent Mr. Epstein dated June 20th, 2009. The Bates number for the 2008 email exchange is EFTA01299999, and the Bates number for the 2009 email is EFTA01256074. In the email exchange from 2008, you write to Mr. Epstein, quote, "I'm trying to do two deals at the same time. Buy Dimensional and sell American Century." Does this refer to Dimensional Fund Advisors and American Century Companies?
p. 172AYes.
p. 173QWhat were these deals?
p. 173AWe were talking with the owner of Dimensional about potentially buying the firm and merging it, and potentially, I think I was selling American Century to fund it or to merge with American Century.
p. 173QAnd J.P. Morgan was involved in a mediation with American Century Companies, correct?
p. 173AWe owned -- at one point we owned American Century Company.
p. 173QAnd there was a mediation later, correct?
p. 173AThere may have been, yes.
p. 173QDid you typically tell Mr. Epstein about ongoing negotiations and mediations before they were public?
p. 173AThis was a transaction that involved me and the business that I was overseeing. As I've said, I went to him for advice and his views, but completely trusted that he would not use this information for personal gain.
p. 173QIn the email from 2009, you write to Mr. Epstein, quote, "We settled with Am Century. Details tomorrow." And then you say, quote, "Thanks for your counsel."
p. 173AYes.
p. 173QSo what was that counsel?
p. 173AI'm not specifically -- I don't specifically recall what his counsel was, but there was -- this implies that it was involved, should we separate from American Century, how should we do it, et cetera. And like you would a consultant or an investment banker, I was looking for counsel from Jeffrey Epstein.
p. 173QBut he wasn't a consultant, was he?
p. 173AI think he advised a lot of people in business in different -- in different spheres.
p. 174QDid you pay him as a consultant?
p. 174ANo, I did not.
p. 174QDid J.P. Morgan pay him as a consultant?
p. 174ANo, they did not.
p. 174QI would like to introduce as minority exhibit Z an email between you and Mr. Epstein dated September 26th, 2008. The Bates number is EFTA01300035. [Staley Minority Exhibit Z. was marked for identification.] BY :
p. 174QIn this email, you write, quote, "I'm spending a lot of time with Treasury. The Private Bank has brought in $44 billion in the last 2 weeks. Unreal." Why did you tell Mr. Epstein that you were spending a lot of time with Treasury?
p. 174AThis was during the financial crisis of 2008. Obviously, a lot was going on financially, globally, and around the world. I was working with the U.S. Treasury in my capacity at J.P. Morgan. And again, I would use Epstein as -- to get his advice and thoughts on issues like this that I was facing.
p. 174QWould you agree the information about how much money J.P. Morgan's Private Bank brought in over the course of 2 weeks is confidential?
p. 174AI don't believe -- I think I could share it with someone that I was seeking advice from.
p. 174QEven if that person was not retained by J.P. Morgan in any capacity?
p. 174AAgain, I think I did -- was using him as a source of advice and views on the markets and -- but not -- this was a very stressful time. So I was not paying him, but I was using him as an adviser at that time.
p. 174QIn the next paragraph, you write, quote, "Also, do you know Sheldon Adelson. I am throwing him out of the bank on Monday." You spelled it t-h-r-o-u-g-h-i-n-g. Did you mean t-h-r-o-w-i-n-g?
p. 175AWe exited Sheldon Adelson as a client.
p. 175QYou're not asking Mr. Epstein for advice here, though; you're just sharing information?
p. 175ANo. I'm asking him whether he knows Sheldon Adelson, and I don't know whether there were follow-up questions or not.
p. 175QSo your testimony here is not that you are just sharing an extremely confidential piece of information with Mr. Epstein, but even though you don't ask him for any -- you don't ask him for any advice or counsel --
p. 175AI asked him whether he knows Sheldon Adelson.
p. 175QAnd you read that as looking for Mr. Epstein's advice or counsel on a decision that you've already made?
p. 175APotentially.
p. 175QWhy would you need his advice or counsel on a decision you had already made?
p. 175AI don't need it, but I might want it.
p. 175QOn a decision you had already made?
p. 175AYeah.
p. 175QWould you agree that information about a client's status at a bank is confidential?
p. 175AYeah, confidential. But I believe, as a senior officer of the bank, I've got the right to use confidential information where I think it's appropriate.
p. 175QI would like to introduce as minority exhibit AA an email chain between you and Mr. Epstein dated October 8th, 2008. [Staley Minority Exhibit AA. was marked for identification.] BY :
p. 175QIn the first email of the chain, you write, quote, "I just gave an idea to the Fed and Jamie that might help the financial markets in a big way. Both thought is brilliant." You're referring to the Federal Reserve here, correct?
p. 176AYes, I am.
p. 176QWhy did you share information about your conversations with the Federal Reserve and J.P. Morgan's CEO with Mr. Epstein?
p. 176AAgain, this was a very, very stressful time in the market. I was using Epstein's knowledge and judgment, and so I was sharing information with him as we were trying to navigate these very difficult times.
p. 176QMr. Epstein responds with some thoughts about financial markets. And then you reply, quote, "I am dealing with the Fed on an idea to solve things. I need a smart friend to help me think through this stuff. Can I get you out for a weekend to help me? (Are they listening?)" Was this the same brilliant idea that you referred to earlier?
p. 176AI believe it was the same idea that I referred to earlier.
p. 176QMr. Epstein was incarcerated at this point, correct?
p. 176AYes.
p. 176QWhen you wrote, quote, "get you out for a weekend," you meant out of the Palm Beach County Stockade, correct?
p. 176AYes.
p. 176QAnd when you wrote, quote, "Are they listening," you were asking whether Mr. Epstein's emails were being monitored, correct?
p. 176AIt seems that way, yes.
p. 176QDid it strike you as problematic to be asking a convicted sex offender if you could get him out for a weekend so that you could share an idea you gave to the Federal Reserve and J.P. Morgan's CEO?
p. 176AAgain, I -- Epstein had very interesting insights into the financial markets. It was a very difficult time in those markets, and I thought that I could benefit from getting his thoughts with respect to what I was thinking of doing with the Fed.
p. 177QI would like to introduce as minority Exhibit AB, an email from Brian Sankey to you, copying Hani Deaibes, dated November 28th, 2009. You forward this email to Mr. Epstein the next day saying, quote, "Please use with discretion. The Bates number is EFTA02410534. [Staley Minority Exhibit AB. was marked for identification.] BY :
p. 177QMr. Sankey and Mr. Deaibes were executives at J.P. Morgan, correct?
p. 177ALet me read the email.
p. 177QIf you need more time to review, we can pause and go off the record.
p. 177AYes, please. . We'll go off the record. [Discussion off the record.] . We're back on the record. BY :
p. 177QI'll repeat my earlier question. Mr. Sankey and Mr. Deaibes were executives at J.P. Morgan, correct?
p. 177AYes.
p. 177QWhat was Mr. Sankey's role in 2009?
p. 177AI don't know.
p. 177QWhat was Mr. Deaibes' role in 2009?
p. 177AI don't remember.
p. 177QIn the email, Mr. Sankey notes he is responding to, quote, "your question," and then shares information about discussions with government officials in the United Arab Emirates, including one who, quote, "reports directly to the Crown Prince." Do you remember what this email was about?
p. 178ANo.
p. 178QDid you ask Mr. Sankey for this information so that you could share it with Mr. Epstein?
p. 178ANo.
p. 178QYou don't remember this email, but you do remember that you didn't ask Mr. Sankey for this information so that you could share it with Mr. Epstein?
p. 178AI don't think I would ask for information so that I could share that information with Epstein.
p. 178QIt does appear, though, that you expected Mr. Epstein to use this information given that you said, quote, "Please use with discretion."
p. 178AAs I said, I used Epstein as an adviser. It's possible that I shared this to get Epstein's thoughts as to what I should do.
p. 178QDo you have any recollection of why Mr. Epstein would have been interested in this information?
p. 178AHe was very involved with the Middle East and very involved with Dubai.
p. 178QDo you have any recollection of how you expected Mr. Epstein to use this information?
p. 178AAgain, I expected him to give me his counsel as to how I might deal with Dubai with respect to this information. [Staley Minority Exhibit AC. was marked for identification.] BY :
p. 178QI'd like to introduce as minority exhibit AC, an email from you to Mr. Epstein on July 20th, 2015. The Bates number is EFTA00850787. In the email you say, quote, "The CEO wants to meet." And Mr. Epstein responds, quote, "I'm home." You were pursuing the role of CEO at Barclays at this point, correct, in July of 2015?
p. 179AYes.
p. 179QAnd you kept Mr. Epstein up to date on all the steps of that process, correct?
p. 179ACorrect.
p. 179QBy October 2015, there were discussions underway about the need for your employer at the time, Blue Mountain Capital, to refrain from trading in Barclays shares, correct?
p. 179ACorrect.
p. 179QAnd this was because the information about you going to Barclays was, as you admitted before the Financial Conduct Authority, quote, "reasonably market sensitive," correct?
p. 179ACorrect.
p. 179QSo why did you share this market sensitive information with Mr. Epstein?
p. 179AObviously, it was a major step in my personal career, and I use him as an adviser in that capacity. So I was sharing my discussions with Barclays with him to get his counsel.
p. 179QDo you regret sharing all of this information with Mr. Epstein?
p. 179ANo.
p. 179QWould you agree that you played a significant role in helping Mr. Epstein maintain legitimacy after his conviction?
p. 179AI think he had a very broad network with dozens and dozens of people that he used to try to maintain his legitimacy.
p. 179QBut you were a part of that network, weren't you?
p. 179ABut I was a part of that network.
p. 179QSo you dispute that you played a significant role in helping him maintain that legitimacy after his conviction?
p. 179AAgain, I was a part of that network. I'm not sure I would characterize it as significant. There were a lot of very influential people involved in his network.
p. 180QUnderstood. BY :
p. 180QMr. Staley, we spoke earlier about you visiting Mr. Epstein in his office at the Florida Science Foundation when he was on work release.
p. 180ARight.
p. 180QYes. Did you ever visit Mr. Epstein at the Palm Beach Stockade?
p. 180ANo, I did not.
p. 180QAnd as you know, Mr. Epstein was on house arrest for a year following his incarceration. This was from roughly July 2009 through July 2010. And this required him to stay in Palm Beach. Did you ever visit Mr. Epstein --
p. 180AWasn't the house arrest -- it was out of Palm Beach, but then he moved that house arrest to New York?
p. 180QSo that was going to be part of our question for you.
p. 180ASorry.
p. 180QDid you ever visit Mr. Epstein in Palm Beach while he was on house arrest?
p. 180ANo.
p. 180QDid you ever visit him anywhere else while he was on house arrest?
p. 180AIn New York and in the -- that one facility where the sheriff was there, and then New York.
p. 180QIn the Florida Science Foundation office?
p. 180AYes.
p. 180QAnd then in New York. Where in New York?
p. 180AHis town house.
p. 180QOkay. I would like to introduce as minority Exhibit AD -- this is an email that you sent to Mr. Epstein on October 4th, 2009. The Bates number is EFTA1300356. [Staley Minority Exhibit AD. was marked for identification.] BY :
p. 181QIn the email you write, quote, "I realize the danger in sending this email, but it was great to be able today to give you in New York City a long heartfelt hug. To my friend. Thanks, Jes." When you wrote, quote, "I realize the danger in sending this email, what did you mean by that?
p. 181AAgain, maintaining a relationship with a convicted felon was a dangerous thing to do. And, in hindsight, I regret it.
p. 181QSo you weren't referring at all to him violating his house arrest --
p. 181ANo.
p. 181Q-- by being in New York?
p. 181ANo. I think his -- he was in New York under house arrest.
p. 181QWere you ever aware of him violating the terms of his house arrest?
p. 181ANo, I was not.
p. 181QOkay. Thank you. BY :
p. 181QI have a few questions for you about visits to Mr. Epstein's properties and a few clarifications. You said earlier that you never went to Mr. Epstein's Palm Beach home, correct?
p. 181ACorrect.
p. 181QYou also said earlier that you went to Mr. Epstein's ranch in New Mexico once, correct?
p. 181ACorrect.
p. 181QDid you spend the night?
p. 182ANo.
p. 182QSo you were in Albuquerque for, I think you said, a business meeting, correct?
p. 182AYes.
p. 182QAnd then did you drive to the ranch?
p. 182AI had a driver drive me there.
p. 182QAnd I think you said it was about an hour?
p. 182AI think so.
p. 182QSo you had someone drive you to the ranch. That's about an hour. And then you said you went horseback riding, took a shower, and then went in the hot tub. And then you had someone drive you back somewhere else that evening?
p. 182AThe same driver drove me to the airport, and I flew home.
p. 182QHow many hours would you say you spent at Zorro Ranch?
p. 182AAn hour. Maybe an hour, hour and a half.
p. 182QSo it was an hour of travel time each way and an hour to an hour and a half at the ranch?
p. 182ARight.
p. 182QThat's a lot of travel time for very little time spent at the ranch.
p. 182AFor a whole day? No. An hour -- again, it was described to me as the largest ranch in New Mexico. I had the time. Didn't seem that special.
p. 182QI would like to introduce as minority exhibit AE an email between Lesley Groff and Mr. Epstein from October 30th, 2009. The Bates number is EFTA02434380. [Staley Minority Exhibit AE. was marked for identification.] BY :
p. 182QIn the email Ms. Groff writes, quote, "Jeffrey just wanted you to know that Jes is all set and organized to stay at the ranch tomorrow night." Is your testimony still that you did not spend the night at Zorro Ranch?
p. 183AYes.
p. 183QWhy do you think Ms. Groff was under the impression that you were going to spend the night?
p. 183AI don't know.
p. 183QI would like to introduce as minority exhibit AF an email chain between you and Mr. Epstein from October 18th and 19th, 2009. The Bates number is EFTA01300295. [Staley Minority Exhibit AF. was marked for identification.] BY :
p. 183QIn the first email, Mr. Epstein writes, quote, "London when?" And you respond, quote, "Could I swing by your house in London on the afternoon of the 27th?"
p. 183AYes.
p. 183QDid Mr. Epstein have a house in London?
p. 183AYes.
p. 183QWhere was it?
p. 183AI don't remember.
p. 183QYou have no recollection -- you spend a lot of time in London, correct?
p. 183AYes.
p. 183QBut you have no recollection where his house in London was?
p. 183AI never went to his house, but I think it may have been on Mayfair, but I don't really know.
p. 183QDo you remember if it was a stand-alone house or a town house or an apartment?
p. 184ANo. This says it's a house, but I don't know.
p. 184QAre you aware that Mr. Epstein had at least four flats in Kensington and Chelsea that he used to house women that he trafficked?
p. 184ANo.
p. 184QCould you have been referring to those flats here?
p. 184AI was referring to his house in London, so --
p. 184QWhy would you have wanted to swing by?
p. 184ABecause, again, I thought it -- it was one of the larger houses in London, and it would be interesting to see.
p. 184QIn all the years that you were friends with Mr. Epstein and all the time that you spent in London, you never went to this house?
p. 184ANo. Because when I was -- no. . We're going to go off the record. [Discussion off the record.]
p. 184Mr. Ashworth.We'll go back on the record. The majority does not have any further questions at this time. I understand the minority has a handful more questions that they're going to go through, and then we'll be finished up -- thank you. We'll go off the record. [Discussion off the record.] . We're back on the record. BY :
p. 184QI'd like to ask you some questions about Mr. Epstein's island, Little Saint James. You've said today that you went twice, once in 2005 and once in 2015, correct?
p. 184AAnd that I transited through it a third time.
p. 184QAnd what year was that?
p. 185AI don't recall. [Staley Minority Exhibit AG. was marked for identification.] BY :
p. 185QOkay. I would like to introduce as minority exhibit AG four flight manifests from February 2005. These manifests indicate that you, your wife, and your two daughters flew from JFK to the Virgin Islands on Mr. Epstein's private plane on February 18th, 2005. You were joined by Mr. Epstein, Ghislaine Maxwell, and three young women who worked for Mr. Epstein, among others. These manifests also indicate that you, your wife, and your two daughters flew from the Virgin Islands to Palm Beach on Mr. Epstein's private plane on February 21st, 2005, and that the same three young women who worked for Mr. Epstein accompanied you. Finally, there is a manifest showing you, your wife, and your two daughters flying from Palm Beach to Teterboro, New Jersey, on Mr. Epstein's private plane on February 22nd, 2005. We'll go off the record briefly to give you time to review these manifests. . We're back on the record. BY :
p. 185QIf you, your wife, and your daughters flew to the Virgin Islands on February 18th and then did not fly back until February 21st, did you stay on Mr. Epstein's island between the 18th and the 21st?
p. 185AApologize. I don't see the name of my family, nor myself on the passenger manifest.
p. 185QSure. The manifests are confusing. If you look at the first page, you'll see the date of the flight is February 18th, the trip number is 322.
p. 185ARight.
p. 185QYou can see Mr. Epstein is the first passenger. He's listed as number one.
p. 185AYes.
p. 186QIf you go down to --
p. 186Mr. Sullivan.Where? Okay. BY :
p. 186QNumber 12, it says Jeff.
p. 186AYep.
p. 186QIt then says female guest, female, female.
p. 186AYep.
p. 186QIf you flip to the next page, about halfway down the page, not quite, it says February 18th, 2005, Flight 322, James Staley, Mrs. Staley, , .
p. 186AOkay. [5:16 p.m.] BY :
p. 187QSo what we believe, because these are the same flights on the same date, is that Jeff is a typo, that it shouldn't say Jeff.
p. 187ARight.
p. 187QAnd that the three female guests are your family members.
p. 187AOkay.
p. 187QSo did you and your family stay on Mr. Epstein's island between February 18th and February 21st?
p. 187AAs I said, my wife and my family visited Epstein, and this sort of confirms that.
p. 187QSo you stayed on his island --
p. 187AOn his island, yes, along with --
p. 187Q-- from the night of the 18th through the 21st?
p. 187A-- along with the Dubins, yes.
p. 187QThat's different from what you had testified to previously, correct?
p. 187ANo. Why? How so?
p. 187QI believe you told the Financial Conduct Authority that you spent a single night on Mr. Epstein's island with your wife.
p. 187AI thought it was a single night. But this implies it was two nights or three nights.
p. 187QYou did testify before the Financial Conduct Authority that you recall -- this is according to their decision -- that you recall visiting Mr. Epstein's island with your wife and spending the night there in 2005 or 2006. So it appears it was your whole family, and it was more than one night, correct?
p. 187AIt appears that way, yes.
p. 187QIt also appears that the three young women who worked for Mr. Epstein also stayed on the island with you because they are on the flight there on the 18th and then they're on the flight back on February 21st?
p. 188AYeah, I wouldn't characterize Sarah Kellen as a young woman. I recognize I don't know who is.
p. 188QDid you and your family socialize with these women?
p. 188ANo.
p. 188QDid you engage in sexual activity with these women?
p. 188ANo.
p. 188QOther than the people listed on the manifest in the first page of this exhibit, was anyone else on the island?
p. 188AI don't even know whether all these people were on the island. I just remember my wife, my family, and the Dubins were on the island.
p. 188QAnd do you remember anyone else on the island who wasn't necessarily on the flight to the island?
p. 188ANo. Except for people that worked on the island.
p. 188QThe manifests show that you fly from the Virgin Islands to Palm Beach on February 21st, and then from Palm Beach to Teterboro, New Jersey, on February 22nd. So it appears that you also spent a night in Palm Beach. Is that correct?
p. 188AThat's what this appears to show. I don't recall that, but that's what this appears to show.
p. 188QDo you remember where you stayed when you spent the night in Palm Beach?
p. 188ANo.
p. 188QWould you have stayed at Mr. Epstein's home in Palm Beach?
p. 188ANo.
p. 188QYou're confident that you would not have stayed at his home?
p. 189AVery confident.
p. 189QWhy is that?
p. 189AIf I was traveling with my whole family, I wouldn't stay at someone's house like that. [Staley Minority Exhibit AH. was marked for identification.] BY :
p. 189QI'd like to introduce as minority exhibit AH two emails from you to Mr. Epstein on January 15th, 2010. The Bates numbers are EFTA01300416 and EFTA01821546. In the first email you say, quote: "Arrived at your harbor. Someday, we have to do this together." In the second email you say, quote: "That was cool." And Mr. Epstein responds: "Yup. Great seeing you." And, again, both of these are from the same day. Was this another trip to Mr. Epstein's island?
p. 189ANo. I believe this was me arriving on my boat to -- he owned a marina in St. Thomas, and I believe I was talking about me sailing -- I believe when I say his harbor, I believe it was to the marina.
p. 189QIn the second email, which, again, is from January 15th, you say: "That was cool."
p. 189AUh-huh.
p. 189QDo you know what you're referring to?
p. 189ANo.
p. 189QIf you were just arriving at Mr. Epstein's marina, would you have seen him?
p. 189APossibly. He may have come over and looked at my boat.
p. 189QSo when he said, "Yup. Great seeing you," it's possible that he was at the marina?
p. 189AIt's possible, yes.
p. 189QIs it also possible that this was an instance in which you visited Little Saint James?
p. 189AI don't think so, because it says: "Arrived at your harbor." And, again, I think the harbor refers to the harbor in St. Thomas where he owns a marina, but I'm not sure. [Staley Minority Exhibits AI and AJ. were marked for identification.] BY :
p. 190QI'd like to introduce as minority exhibit AI an email exchange between you and Mr. Epstein dated December 27th, 2010. The Bates number is EFTA00648887. I would also like to introduce as minority exhibit AJ an email exchange between you and Mr. Epstein dated January 22nd, 2011. The Bates number is EFTA01300907. In the first exchange, you tell Mr. Epstein that you, quote: "Scheduled a dinner on Little Saint Jeff's on Jan 21st." In the second exchange you tell Mr. Epstein that his island is a "paradise."
p. 190AI've lost you.
p. 190QIn the first exchange, which is from December 22nd, 2010 --
p. 190ANo, this is December 27th.
p. 190Mr. Sullivan.What did she say. BY :
p. 190QOh, my apologies. I misspoke. December 27th, 2010. In the first exchange, from December 27th, 2010, you tell Mr. Epstein that you, quote: "Scheduled a dinner on Little Saint Jeff's on Jan 21st." It's the second line of your email.
p. 190AYep.
p. 190QIn the second exchange --
p. 190AWait, wait, wait, wait. Okay.
p. 190QIn the second exchange you tell Mr. Epstein that his island is a "paradise."
p. 190AYep.
p. 190QDid you go back to Mr. Epstein's island in January of 2011?
p. 191AAgain, I think I said that I was in transit on my boat.
p. 191QWell, in your first email you say, quote: "Scheduled a dinner on Little Saint Jeff's on January 21st." So it looks like at the very least you had dinner on Little Saint Jeff's.
p. 191AI don't know. This is an email from December, so a full month before.
p. 191QRight. And then the second --
p. 191ASo I don't know whether I had dinner. And on this next email, just talks about visiting his island, not about having dinner on his island. So I don't think --
p. 191QIt's from the day after you had apparently scheduled a dinner.
p. 191AI scheduled a dinner a month before. I was on my boat. I have no idea whether I had dinner on my boat or off my boat.
p. 191QI will represent to you that Mr. Epstein's birthday is January 20th. [Inaudible.] . That's because one is from December and one is from January.
p. 191The Reporter.I'm sorry, I didn't hear you.
p. 191Ms. Harris.That's okay. I was just querying the date. BY :
p. 191QI'll represent to you that Mr. Epstein's birthday was January 20th. So it looks like you are sending him an email on December 27th, 2010, saying that you scheduled a dinner on Little Saint Jeff's on January 21st, which would be the day after his birthday. And then, about a month later, on January 22nd of 2011, you refer to his island being a "paradise."
p. 191AYes.
p. 191QSo taken together, these look like you scheduled the dinner on his island for his birthday, had that dinner, and then sent an email the day after saying: "What a paradise."
p. 191ABut there's nothing in the second email that talks about a dinner for his birthday the previous night. And you would think, if that had happened, that I would have mentioned that, "Great to see you" or something like that, and there's nothing there.
p. 192QSo you don't think that you visited his island again in January of 2011?
p. 192AAgain, my recollection is there were three times that I was on his island. But I was staying on my boat. So it's possible.
p. 192QIn the second exchange you say: "I think Larry is sad." Is it possible that you were referring to Larry Summers here who was also part of the birthday dinner?
p. 192AWhich birthday dinner again are you talking about?
p. 192QWho was also part of the dinner that you scheduled on Little Saint Jeff's on January 21st?
p. 192ABut Epstein is emailing me on the 22nd saying, "Do you like the kitchen?" as if I wasn't with him on the 21st. The way you're trying to tie it together doesn't make sense in I how read it.
p. 192QSo you do not believe that you visited Mr. Epstein's island in January of 2011?
p. 192AAgain, I believe that I was on my boat, and I may have stopped by his island on the 11th. But I don't remember it.
p. 192QYou may have stopped by his island in January of 2011 and potentially had dinner?
p. 192AI think if I had had dinner on his island I would have mentioned this, and I don't. [Staley Minority Exhibit AK. was marked for identification.] BY :
p. 192QI would like to introduce as minority exhibit AK a manifest for a flight from New Jersey Teterboro Airport to St. Thomas on April 11th, 2015. The manifest lists you, your wife, Jeffrey Epstein, and two additional women, and another woman whose name we will not read because it is not public, as passengers. I'll give you a minute to look it over.
p. 193AOkay.
p. 193QIt appears this manifest is referring to your visit to Mr. Epstein's island in April of 2015, correct?
p. 193AI'm not sure -- no. I don't think I visited his island. I think we were on the boat. So we may have caught a ride with him at St. Thomas but went to our boat.
p. 193QOther than the people listed as passengers on the plane, was there anyone else with you?
p. 193AThe crew.
p. 193QYou previously said earlier today that you didn't believe that you had ever met
p. 193AThat's correct.
p. 193QAnd this shows that you were on a plane with her, correct?
p. 193ACorrect.
p. 193QDo you remember being on a plane with her?
p. 193ANo, I don't.
p. 193QAnd so your recollection is that you were on a boat, but you didn't actually visit his island. Is that correct?
p. 193AThat's correct. [Staley Minority Exhibit AL. was marked for identification.] BY :
p. 193QI would like to introduce as minority exhibit AL an email from you to Mr. Epstein dated April 12th, 2015, which is the following day. The Bates number is EFTA01746275. In the email you say, quote: "Thanks for the flight and thanks for lunch. Your place is crazy and special. It has a warmth and silliness that makes it yours. I count you as a deep friend. The girls seemed to enjoy the sail." So you flew on his private plane, you had lunch, but then you say: "Your place is crazy and special. It has a warmth and silliness that makes it yours." That suggests that you did also visit the island. Agree?
p. 194AI said thanks for lunch, yes.
p. 194QSure. But then you say, quote: "Your place is crazy and special. It has a warmth and silliness that makes it yours."
p. 194AThat's the same to me as "thanks for lunch."
p. 194QWhere would you have had lunch?
p. 194AOn his island it seems like.
p. 194QOkay. So to clarify, you flew on his plane on April 11th, 2015, and then you had lunch on the island that day?
p. 194AIt seems like.
p. 194QWhen you say, quote, "The girls seemed to enjoy the sail," who are the girls?
p. 194AI don't know. I don't recall.
p. 194QYour daughters were not with you at this point, correct?
p. 194AI believe this flight was just my wife and myself, correct.
p. 194QSo were "the girls" either girls or young women that worked for Mr. Epstein?
p. 194AI don't recall.
p. 194QYou have no recollection of going sailing with girls?
p. 194ANo.
p. 194QSo to summarize, you visited Mr. Epstein's island in February of 2005. And in April of 2015 -- in 2005 it was with your family, and in 2015 it was with your wife, correct?
p. 194AIn 2005 we stayed on the island. In 2015 I think we were staying on our boat.
p. 194QAnd in January of 2010 you may have seen him at the marina in the Virgin Islands in St. Thomas?
p. 195AI think he may have come by and seen my boat.
p. 195QAnd your recollection is that you did not also visit in January of 2011?
p. 195AThat's my recollection.
p. 195QYou also flew on Mr. Epstein's plane multiple times. The times that we have discussed are three instances in February of 2005 and then once in April of 2015, correct?
p. 195AI don't recall.
p. 195QDo you remember any other times that you flew on Mr. Epstein's plane?
p. 195AI remember flying on a 727, and I remember flying on his Gulfstream. But I don't -- no. It either would have been between here and Florida or here and St. Thomas -- or New York, sorry.
p. 195QMr. Staley, I am concerned that you have not been entirely honest with us today, in large part because you have a history of saying what you think you need to to get what you want. I want to ask you about that history and see if you have explanations for us. Back in the fall of 2019, the president and trustees of Bowdoin College, your alma mater, became concerned about your association with Mr. Epstein, correct?
p. 195ACorrect.
p. 195QAnd you were a trustee at Bowdoin College, correct?
p. 195ACorrect.
p. 195QAnd you wanted to remain a trustee of Bowdoin College, correct?
p. 195ACorrect.
p. 195QIn response, you gave a presentation to the Bowdoin College trustees about your relationship with Mr. Epstein, correct?
p. 195ACorrect.
p. 195QAnd as part of that presentation, you made a number of statements to the Bowdoin College trustees, correct?
p. 196ACorrect.
p. 196QAnd this was before the Department of Justice released some of its files on Mr. Epstein, correct?
p. 196ACorrect.
p. 196QOne of those statements was: "I had limited contact with him post his conviction." We know that between 2008 and 2012 you exchanged over 1,200 emails with Mr. Epstein. That is nearly 300 emails a year or almost an email a day. How is that "limited contact"?
p. 196AAgain, I have used the word "contact" as being with him, having contact with somebody, not necessarily an email.
p. 196QDo you think that that's how the word was understood when you said it to the Bowdoin College trustees, that "contact" meant physical contact?
p. 196AI can't speak for the Bowdoin trustees, but I think that's what I was referring to.
p. 196QAnother statement was, quote --
p. 196AI'm sorry, I don't know -- when you say that number of emails, is it like separate emails, or is it like a chain where you say, "Hi," I say, "Hi." You say, "What are you doing?" I say, "Nothing. What are you doing?" Like is it --
p. 196QIt's a finding from the Financial Conduct Authority.
p. 196ABut we don't know whether it's -- okay.
p. 196QIndividual emails or emails chains? No. I think it's still a pretty high number. Another statement was, quote: "At no time after his conviction in 2008 did I allow J.E. any connection with any respect of my professional life. Indeed, I have never had any professional relationship with J.E. except for his relationship with J.P. Morgan's Private Bank which began long before I ever met him." There is overwhelming evidence that this is false. You asked Mr. Epstein for advice on your salary. You shared confidential information about how your business was doing and what deals you were working on. You told Mr. Epstein about meetings you had with government officials and meetings that others had with government officials. And you gave Mr. Epstein multiple updates on the hiring process at Barclays. Why would you lie about this to the Bowdoin College trustees?
p. 197ACan you repeat what I said to the Bowdoin College trustees?
p. 197Q"At no time after his conviction in 2008 did I allow J.E. any connection with any aspects of my professional life. Indeed, I have never had any professional relationship with J.E. except for his relationship with J.P. Morgan's Private Bank which began long before I ever met him."
p. 197AAnd I think that was referring to like him being a client, him advising on a transaction like Highbridge. I don't believe that -- I think it was actually doing business with him as opposed to using him to give me counsel with respect to my career. I think those are separate things.
p. 197QI don't follow that distinction. You say you didn't allow him any connection with any aspects of your professional life after his conviction. When he is in jail you email him asking what your salary should be. That very much seems like after his conviction you are allowing him a connection to an aspect of your professional life?
p. 197AI think it was talking about connections of actually business being conducted in my professional life, not about me.
p. 197QI'm not sure what you mean by that. Connections about business?
p. 197ASo the selling of American Century or thinking of buying -- about buying Dimensional or having him involved in the acquisition of Highbridge as separate from, "I'm thinking of going to Barclays, what do you think?" One is sort of advice about my professional life. The other is about transactions and business.
p. 197QI'm still not following you because you did both. You asked him for advice on your professional life and you shared --
p. 197ARight, right, I think after his conviction, I wouldn't know. If I was doing a transaction, I wouldn't bring him to get involved in that transaction. That's different than my personal professional life.
p. 198QRight. But after his conviction you did both. You shared information about deals that you were working on. You --
p. 198AVery little.
p. 198QWe have talked about that, though. You shared information with him about deals that you were working on. You told him about meetings you were having with government officials.
p. 198AAnd that's different.
p. 198QSure. And then in the other category, you asked him for advice about what you should say to Jamie Dimon in a salary negotiation.
p. 198ARight, again, but that's different than bringing to him actual business transactions like American Century or Dimensional or Highbridge.
p. 198QSo you think that the natural reading of this statement that you made to the Bowdoin College trustees is that you were saying that you didn't do some sort of formal business with him?
p. 198AYes.
p. 198QWhen you say, "At no time after his conviction in 2008 did I allow J.E. any connection with any aspect of my professional life"?
p. 198AThat would have been public and involved in a transaction, that's correct. Whereas before, he was paid $15 million to advise on a transaction with Highbridge. That's the sort of thing I was referring to.
p. 198QI don't see that distinction, Mr. Staley, and, instead, it looks like you are giving information to the Bowdoin trustees -- excuse me, the Bowdoin College trustees -- that is not entirely accurate, because at the time all of the emails and documents that we have were not public. And if you were comfortable lying before, how do we know you're not lying to us now?
p. 199AI'm not lying to you.
p. 199QThat's all we have. That concludes our hour. Thank you. [Whereupon, at 5:46 p.m., the interview was concluded.] Certificate of Deponent/Interviewee I have read the foregoing _ _ pages, which contain the correct transcript of the answers made by me to the questions therein recorded. _ _ Witness Name _ _ Date