{"database": "deposition_transcripts", "table": "segments", "is_view": false, "human_description_en": "where deposition_id = 17", "rows": [[10080, 17, 0, "Page 1", null, null, "COMMITTEE 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."], [10081, 17, 1, "Page 2", null, null, "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"], [10082, 17, 2, "Page 3", null, null, ", 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"], [10083, 17, 3, "Page 4", null, null, ", 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"], [10084, 17, 4, "Page 5", null, null, "Ms. 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? Mr. Staley. James Edward Staley, S-t-a-l-e-y. Ms. 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? Mr. Staley. I do. Ms. Brignac. Will all counsels please identify themselves for the record? Mr. Sullivan. Brendan Sullivan, Williams & Connolly, Washington, D.C. Ms. Harris. Kathleen Harris, Arnold & Porter. Ms. Brignac. Thank you."], [10085, 17, 5, "Page 6", null, null, "For the record, starting with the majority staff, can the additional staff members please introduce themselves with their name, title, and affiliation? Mr. Grant. Billy Grant, deputy chief counsel for investigations for Chairman Comer. Mr. Emmer. Jack Emmer, chief counsel for investigations for Chairman Comer. Mr. Ashworth. Daniel Ashworth, general counsel for Chairman James Comer. Ms. Tolan. Ellison Tolan, senior counsel for Chairman Comer. Ms. Cathey. Hannah Cathey, professional staff member for Chairman Comer. Mr. Harnice. Will Harnice, professional staff member, Chairman Comer. Ms. Feyerabend. Emily Feyerabend, counsel for Chairman Comer. Ms. Collins. Jessica Collins, comms director. Ms. Cogar. Mallory Cogar, director of operations and chief clerk, Chairman Comer. Ms. Vinyard. Ashlee Vinyard, deputy staff director, Chairman Comer. Mr. 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. Ms. Brignac. Mr. Staley, before we begin, I would like to go over the ground rules for this"], [10086, 17, 6, "Page 7", null, null, "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? Mr. Staley. Yes, I do. Ms. 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? Mr. Staley. Yes, I do. Ms. Brignac. Exhibits may be entered into the record. Majority exhibits will be identified numerically. Minority exhibits will be identified alphabetically. Do you understand? Mr. Staley. Yes, I do. Ms. Brignac. We want you to answer all questions in the most complete and truthful"], [10087, 17, 7, "Page 8", null, null, "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? Mr. Staley. I do. Ms. 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? Mr. Staley. Yes, I do. Ms. Brignac. If at any time you knowingly make false statements, you could be subject to criminal prosecution. Do you understand? Mr. Staley. Yes, I do. Ms. 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? Mr. Staley. Yes, I do. Ms. 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."], [10088, 17, 8, "Page 9", null, null, "Do you understand? Mr. Staley. Yes, I do. Ms. Brignac. Is there any reason you are unable to provide truthful testimony in today's interview? Mr. Staley. No. Ms. 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? Mr. Staley. Yes, I do. Ms. 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? Mr. Staley. Yes, I do. Ms. Brignac. Do you have any questions before we begin? Mr. Staley. No. Ms. 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"], [10089, 17, 9, "Page 10", null, null, "BY MS. BRIGNAC: Q Mr. Staley, let's begin by discussing your background. Where were you born? A Born in Cambridge, Massachusetts. Q What year were you born? A In 1956. Q What is your marital status? A I am married, but separated. Q What is your educational background? A I have a bachelor's degree in economics from Bowdoin College. Q We'll go into more detail later, but can you briefly describe your professional career? A I 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. Q Over those years in J.P. Morgan, what are the dates that you held each position? A I don't recall the dates. Q When did you start working at J.P. Morgan? A In 1979. Q What was your role at that time? A I went into the training program, and then in 1980 was when I first went to Latin America. I was in Latin America till 1989. Q What were you doing in Latin America?"], [10090, 17, 10, "Page 11", null, null, "A A 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. Q What was your next position? A Then I moved to New York and was part of a small team asked to build a public equities business at J.P. Morgan. Q Who asked you to do that? A I believe at the time it was Bill Harrison. Q What year was that? A That would have been 1989. Q What was your next position? A Then I was asked to go run the Private Bank. Q In 1999? A About 2000. Q 2000? Okay. And what was your next position? A Then, added to running the Private Bank, I was asked to run Asset Management as well. Q Was that the next year, 2001? A Thereabouts, yes. Q What was your next position? A I did that until I think about 2009, and then was asked to run the Investment Bank of J.P. Morgan. Q When did you leave J.P. Morgan? A In 2013. Q Why did you leave J.P. Morgan? A I stepped down as head of the Investment Bank and took a much smaller role. And it"], [10091, 17, 11, "Page 12", null, null, "seemed like it was time to move on from J.P. Morgan. Q Why is that? A I 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. Q Did they communicate the reason why they thought you were not an appropriate successor? A No. Q Did you ever hear from anyone else why they thought you would not be an appropriate successor? A No. Q Do you believe it was because of your affiliation with Mr. Epstein? A No. Q Do you still hold a role at J.P. Morgan? A No. Q When did you leave J.P. Morgan's orbit entirely? A 2013. Q What was the smaller role you held? A I think I was made chairman of the Investment Bank, which is a much less role than the CEO. Q Did anyone ask you to leave J.P. Morgan? A No, but the implication of the lesser role was it was probably time to move on. Q Did you reach any agreement with J.P. Morgan on your departure about rules you would"], [10092, 17, 12, "Page 13", null, null, "abide by regarding your knowledge of J.P. Morgan's dealings? A Aside from the sort of standard confidentiality agreements, that was it. Q Was there any additional confidentiality they asked you to abide by given the very senior roles you held? A No. Q Would those confidentiality agreements have prohibited you from discussing J.P. Morgan's dealings with friends of yours? A I 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. Q You were able to use your discretion to discuss confidential matters of J.P. Morgan's? Is that accurate? A I believe so, yes. Q Are you currently employed? A No, I'm not. Q Thank you. Tell me about the first time you interacted with Mr. Epstein? A The 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. Q Who introduced you to him? A That would have been Sandy Warner. Q What year was this? A I believe 2001."], [10093, 17, 13, "Page 14", null, null, "Q And where were you at this time? A In New York. Q Where specifically in New York? A On Park Avenue right above Grand Central. Q What was the reason for this interaction? A Again, 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. Q Why was he considered of a high net worth? A He 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. Q Did Sandy Warner tell you anything about Mr. Epstein before you met him? A Just that he seemed to be connected to the high net worth community in New York. Q Did you hear anything about Mr. Epstein during your time at the bank? A The entire time at the bank? Q Prior to your meeting Mr. Epstein. A No. Q What did you know about him prior to this meeting? A I 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. Q Did that alone make him a high-value client, or were there other things you knew about him that led you to that belief?"], [10094, 17, 14, "Page 15", null, null, "A No. Again, in the beginning it was simply I was asked to meet him by the then-CEO of J.P. Morgan. Q What were your impressions of him upon meeting him? A Again, 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. Q What was his demeanor? What was he like? A He seemed relaxed, intelligent, curious. Q Who else was present at the meeting? A Just myself. Q What did you understand his job to be? A Again, save for providing some advice to Les Wexner, I didn't know what his job was. Q Did you ever become involved in his business with Les Wexner? A In his business with Les Wexner? No. Q Did you ever become involved in his financial dealings with Les Wexner? A No. Q Did anyone raise concerns about Mr. Epstein prior to this meeting? A No. Q After you met Mr. Epstein, what happened next? A Nothing significant happened next. I think we probably met a few more times. But for a while nothing happened. Q So 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? A I 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"], [10095, 17, 15, "Page 16", null, null, "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. Q Who was assigned to his accounts? A At that time, I didn't know who was managing his accounts. Q What part of the bank was he assigned to and why? A He was a high net worth client, so he was a client of the Private Bank. Q What are the requirements to be assigned to the Private Bank? What factors go into that decision? A I 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. Q How many accounts did Mr. Epstein have at J.P. Morgan over the years? A I don't know. Q Over a hundred, would you say? A I don't know. Q The 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? A In those early years? Q Overall, generally, over the years. A Again, it changed over time. I think probably the most significant event in the 2000s"], [10096, 17, 16, "Page 17", null, null, "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. Q Why is that significant to you? A So 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. Q So did Mr. Epstein's introduction to Glenn Dubin change the nature of your relationship? A Yes, 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. Q And he earned a $15 million fee from that transaction, correct? A So 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"], [10097, 17, 17, "Page 18", null, null, "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. Q And that -- A An 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. Q Did this acquisition benefit your career? A Yes. Q How? A As 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 -- Q I'm sorry, do you understand my question? How did that benefit your career? A Because 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. Q So Mr. Epstein benefited from the transaction and you benefited from the transaction. What year did this transaction take place? A I believe it was closed in 2004. Q Okay. So by this point you've referenced a significant transaction between you and Mr. Epstein. We've covered years -- A Excuse me. Say that again? It was not a transaction between me and Jeffrey Epstein. Q Okay. 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? A Again, it was always a business relationship, but he gave advice and had good insights"], [10098, 17, 18, "Page 19", null, null, "into the industry and into broader finances, and I would seek his thoughts. Q Did you ever discuss personal matters? A Only later on did I discuss career issues with Jeffrey Epstein, yes, but always around my career and business, not personal. Q So you never discussed personal matters with Mr. Epstein? A No, 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. Q Did you ever discuss your families? A Only 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. Q Returning to your dealings with Mr. Epstein, you referenced earlier that you believed it was in your discretion to divulge confidential information. Is that accurate? A Yes. Q Doesn't the nature of confidentiality mean that there are barriers around what you can divulge? A But 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. Q Were there any barriers to your sharing of information with Mr. Epstein specifically by J.P. Morgan? A No. Q How often did you interact with Mr. Epstein in a personal capacity? A Again, my interactions were predominantly around business and my career, so I don't know how to characterize just personal. Q Well, Mr. Staley, documents released by the DOJ illustrate that you referenced Mr."], [10099, 17, 19, "Page 20", null, null, "Epstein as family to you. What did that mean? A I 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. Q You reference to everyone you have a business relationship with as family? A I didn't say I reference everyone I had business with as family. Q No, I asked if you referenced. A So the answer to that question would be no. Q So why Mr. Epstein? A Again, 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. Q You've already referenced Mr. Epstein did communicate with your daughter. Did he have a relationship with all of your family members? A No, just principally me and my eldest daughter. Q Did you get the impression that your family liked him? A Again, my second daughter had no interaction with him really, and my wife had very limited interaction with him. Q What was the nature of your daughter's relationship with Mr. Epstein? A She 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. Q Did they frequently communicate without your knowledge? A No, I don't think so. [Staley Majority Exhibit No. 1."], [10100, 17, 20, "Page 21", null, null, "was marked for identification.] BY MS. BRIGNAC: Q I'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? A I'm ready. Q Do you recognize this document, Mr. Staley? A I recognize it's an email from me to Mr. Epstein, yes. Q Can you please read it into the record? A From 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.\" Q And, Mr. Staley, is Deby referring to your legally married wife who you're separated from? A Yes. Q And refers to your daughter? A Yes. Q Why did you send this email? A It 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"], [10101, 17, 21, "Page 22", null, null, "daughter to pursue a doctorate in physics and connected her to some people in the physics community. Mr. 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. Mr. Krishnamoorthi. Raja Krishnamoorthi. Mr. Grant. Thank you all. BY MS. BRIGNAC: Q Mr. 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? A Again, 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. Q Can you tell me about your first interaction with Ghislaine Maxwell? A I don't believe I had interaction with Ghislaine Maxwell. Q You recommended J.P. Morgan open an account for her; correct? A I don't remember that. Q Would it help if we refreshed your recollection? A Sure. Q We'll go off the record."], [10102, 17, 22, "Page 23", null, null, "[Discussion off the record.] Ms. 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.] BY MS. BRIGNAC: Q I 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? A I don't. Q Did J.P. Morgan end up opening an account for Ms. Maxwell? A I have learned that they did, yes. Q And we can agree your recommendation for a referred client in opening account probably carries quite a bit of weight with your senior roles, correct? A I 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. Q Did Mr. Epstein ask you to meet with Ms. Maxwell? A I don't recall that. Q Have you ever met with Ms. Maxwell on any other occasion? A Again, I don't know what occasion this refers to. If you have what occasion, that would"], [10103, 17, 23, "Page 24", null, null, "be helpful for my memory. Q No, 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? A No. Q How often would you have casual or private conversations with Mr. Epstein? A Again, 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. Q Can you estimate daily, weekly, monthly? A I would say weekly. Q Weekly. Did Mr. Epstein ever discuss young women or girls with you? A No, he did not. Q Did Mr. Epstein ever introduce you to young women or girls? A No, he did not. Q Did Mr. Epstein ever discuss massages with you? A No, he did not. Q Did Mr. Epstein -- strike that. Did you ever witness Mr. Epstein receive a massage of any kind from a young woman or girl? A No, I did not. Q Did you ever witness Mr. Epstein pay women for massages? A No, I did not. Q Did you ever witness Mr. Epstein giving cash to other young women or girls? A No, I did not. Q Did you ever witness Ms. Maxwell giving cash to young women or girls? A No, I did not."], [10104, 17, 24, "Page 25", null, null, "Q Did Mr. Epstein ever discuss sexual acts with you? A No. Q Did you ever witness Mr. Epstein sexually abuse or assault young women or girls? A No. Q Did you ever witness Ms. Maxwell sexually abuse or assault young women or girls? A No. Q Did you ever witness Mr. Epstein engage in sexual conduct? A No, I did not. Q Did you ever witness Ms. Maxwell engage in sexual conduct? A No, I did not. Q Did you ever witness Mr. Epstein exploit young women or girls? A No, I did not. Q Ms. Maxwell? A No, I did not. Q Did they ever threaten anyone? A I never saw that. Q Did Mr. Epstein or Ms. Maxwell ever ask if you wanted them to bring women or girls to you? A No. Q Did you ever have sexual contact with any young woman or girl introduced to you by Mr. Epstein? A What do you mean by introduced? Q However you interpret introduction. A So ask the question again? Q Did you ever have sexual contact with any young woman or girl introduced to you by"], [10105, 17, 25, "Page 26", null, null, "Mr. Epstein? A Young women and girls, no. Q Why the confusion on that question? Is there someone you think we should be aware of? A As I have testified before, I had an encounter once with someone who was on Epstein's staff but was a mature woman. Q Okay. We'll return to that. Did you ever have any sexual contact with young women or girls in the presence of Epstein? A No. Q Were you ever aware that Mr. Epstein regularly entertained young women at his residences? A No. Q How did Mr. Epstein act towards the young women or girls that were around him? A As I said, I did not see him with young women or girls around him. Q How did he act with his assistants? A He treated them professionally. Q We can agree his assistants were mostly young women, correct? A Again, it would be helpful if you define young women. There were women of late 20s, 30s. Q Were you aware of the nature of any of Mr. Epstein's activities involving minors? A No. Q When did you become aware of these activities? A I 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. Q Do you know of any individuals that knowingly facilitated Mr. Epstein in his criminal"], [10106, 17, 26, "Page 27", null, null, "activities? A No. Q And for the record, have you ever been contacted by any law enforcement agency concerning Jeffrey Epstein or Ghislaine Maxwell? A No, I have not. Q Have you ever been interviewed by any law enforcement agency concerning Jeffrey Epstein or Ghislaine Maxwell? A No, I have not. Q Have you ever provided any information to any law enforcement agency concerning Jeffrey Epstein or Ghislaine Maxwell? A No, I have not. Q Did Jeffrey Epstein ever inform or represent to you he was working with any intelligence service of any nation, including the United States? A No, he did not. Q Did Ghislaine Maxwell? A No, she did not. Q During your relationship, did you ever suspect Jeffrey Epstein or Ghislaine Maxwell of being affiliated with any intelligence agency? A Jeffrey Epstein had a network of contacts internationally, but I never associated it with an intelligence agency. Q At any time, have you had an affiliation with any intelligence agency? A When I was with the Private Bank, I had some interaction with parts of the U.S. intelligence system. Q Have you or any of your representatives or agents asked anyone to sign a nondisclosure agreement or other agreement in connection with Jeffrey Epstein?"], [10107, 17, 27, "Page 28", null, null, "A No, I have not. Q Have you or any of your representatives or agents asked anyone to sign a nondisclosure agreement in connection with Ghislaine Maxwell? A No, I have not. Q Have 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? A No, I have not. Q I'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? A Yes. Q How many times? A I believe three times, although one occasion was literally to get on his island into the helicopter and left. Q Have you ever visited Mr. Epstein's Palm Beach house? A No. Q Have you ever visited Mr. Epstein's Manhattan townhouse? A Yes. Q Have you ever visited his apartment buildings or offices at 301 East 66th Street in New York? A Yes. Q Have you ever visited Mr. Epstein's New Mexico ranch Zorro? A Once. Q Have you ever visited Mr. Epstein's Paris apartment? A No."], [10108, 17, 28, "Page 29", null, null, "Q Have you ever visited Mr. Epstein's Great Saint James Island? A That's the island in the Virgin Islands. Yes. Q Have you ever visited Mr. Epstein's property in New Albany, Ohio? A I didn't know that he had a property in New Albany, Ohio. Q Have you ever visited any of his other properties that are owned or leased by him that I didn't state? A No. Q How many times did you visit his Manhattan townhome? A Dozens of times. Q And his offices at 301 East 66th Street in New York how many times? A Once. Q Did you see any young women or girls while you were at the Manhattan townhome? A No. Q While at any properties, did you witness any sexual conduct by Jeffrey Epstein with any women or girls? A No. Q While at any of his priorities, did you witness any sexual conduct by anyone else with young women or girls? A No. Q Mr. 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? A . Q How did you meet her? A She was an assistant to Jeffrey Epstein, and I met her at his townhouse. Q Who else was there?"], [10109, 17, 29, "Page 30", null, null, "A Again, most often it would be his assistant Lesley Groff. That would be really the only other person that was often there that I saw. Q How many times did you interact with her before you had sex? A A handful. Q Can you give me a number estimate? A I would be guessing, but 6 to 12. Q What were the circumstances that led you to have sex with her on that first occasion? A On the only occasion. We met and began to have a dialogue and it turned flirtatious. And we met and had one intimate encounter. Q Did Mr. Epstein set it up? A No. Q Are you aware if she's had sex with anyone else associated with Mr. Epstein? A No. Q Where did the sex take place? A At her apartment. Q Where did she live? A 66th Street, to my recollection. Q Did you discuss the fact that you had sex with her with Mr. Epstein? A No, I did not. Q Do you know if she shared that with Mr. Epstein? A No, I don't. Q Have you had sex with anyone else associated with Mr. Epstein? A No, I have not. [Staley Majority Exhibits Nos. 3, 4, and 5"], [10110, 17, 30, "Page 31", null, null, "were marked for identification.] Ms. 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.] Ms. Brignac. We'll go back on the record. BY MS. BRIGNAC: Q Majority 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? A No, I have not. Q Did you see this photo in preparation for your examination today? A This photo, no. Q Acknowledging the face in this photograph is redacted, can you otherwise describe what you see in the photo? A That looks like Epstein's apartment in New York, and obviously it's someone dressed in a costume. Q Yes, it appears to be a young woman in a Snow White costume. Who is in this photograph? A I don't know. Q The Committee has been able to identify this photograph as . Have you met ? A I don't believe so."], [10111, 17, 31, "Page 32", null, null, "Q You stated you have been to Mr. Epstein's New York townhome. Were you there on or around July 9th through 10th, 2010? A I don't know. Q You don't know because you can't recall? A Yes. Q I 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? A Say it again? Sorry. This email is from who? Q This is from in the Committee's review of the documents. My question is, what do you interpret \"f..ed\" to mean? A Intercourse. Q Were you ever around this woman in the Snow White costume at Mr. Epstein's residence? A No. Q Okay. 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? A I don't recall. So I don't know. Q Who were you asking Mr. Epstein to say hi to? A I'm saying: \"Say hi to Snow White.\" Q Yes, who is Snow White?"], [10112, 17, 32, "Page 33", null, null, "A Yeah, I'm saying I don't know who Snow White is. Q We 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? A Yes. Q Why do you think that is? A Again, I don't know. Q Do you maintain you've never met ? A I don't recall ever meeting her, no. I don't know who she is. Q Now that I've refreshed your recollection, do you recall being at Mr. Epstein's New York townhome on July 9th or 10th, 2010? A Again, 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."], [10113, 17, 33, "Page 34", null, null, "[11:08 a.m.] BY MS. BRIGNAC: Q Have you seen any woman in a costume around Mr. Epstein? A No. Q Later in the email exchange, Mr. Epstein asks, \"What character would you like next?\" What do you think Mr. Epstein's asking you here? A Um. You know -- Q I didn't get that. Can you speak up? A Yeah, 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. Q Who were you referring to as \"Beauty and the Beast\"? A I don't know. I was referring to the movie \"Beauty and the Beast.\" Q Have you had sexual relations with any woman dressed as a Snow White? A No, I have not. Q Mr. 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. A Oh, it seems like he's talking about a beauty. But I don't know who that is. Q Have you ever had sex with Mr. Epstein? A No. Q Has Mr. Epstein ever asked you to have sex with him? A No. Q Does it appear that the characters Mr. Epstein is offering to you can say no? Mr. Sullivan. That's a pretty far-out -- I'm doing my best to remain silent, but -- Mr. Ashworth. I'm sorry?"], [10114, 17, 34, "Page 35", null, null, "Mr. Sullivan. That's a pretty far-out question. Ms. Brignac. I would like for you to answer it. Mr. Sullivan. Could you read it back for us? BY MS. BRIGNAC: Q Does 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? A I don't think he's offering characters to me. Q Did you and Mr. Epstein use Disney princesses as code names for selecting women for sexual encounters? A No. Q The Committee has also reviewed documents where Philip Levine uses the exact same code name \"Beauty and the Beast.\" Why would that be? A Who is Philip Levine? Q The 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? A I don't know who he is. Q Okay. 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? A No. Q The Little Mermaid? A No. Q Cinderellas?"], [10115, 17, 35, "Page 36", null, null, "A No. Q Sleeping Beauty? A No. Q Have you ever met Frederic Fekkai? A No, I have not. I may have met him once, but I don't re- -- yeah -- but nothing to do with Epstein. Q Did you ever hear rumors that Frederic Fekkai was involved with Mr. Epstein's assistants? A No. Q Same question for Mr. Levine. Did you ever hear anything about Mr. Levine's involvement with Epstein's assistants? A I don't know who Mr. Levine is, so no. Ms. 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 :"], [10116, 17, 36, "Page 37", null, null, "Q Mr. 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? A Not exactly, no. Q So you said it was sometime in 2009 or 2010. Can you be more specific? A No. I mean, 2009, 2010. Q Mr. Epstein was incarcerated through July 2009 and on house arrest through July 2010. Does that help you narrow down the period? A I guess -- I guess it would've been after July 2009 then. Q And you said previously that you met this young woman at Mr. Epstein's New York home, correct? A Yeah. And, again, I don't know whether she was in her twenties or thirties, but -- Q I asked if you met her at Mr. New York -- excuse me. I asked if you met her at Mr. Epstein's New York home. A Yes, I did. Q And you're also saying you don't remember her age?"], [10117, 17, 37, "Page 38", null, null, "A Again, I think it was twenties or thirties. Q And you said previously that you'd talked to this woman a few times. Do you remember exactly how you first met her? A Yeah. 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. Q And do you remember how many times you spoke with her? A I'm sure it would've been half a dozen to a dozen times. Q Did you talk to other assistants for Mr. Epstein too? A Yes. Q Did you have any sense of what she did as one of Mr. Epstein's assistants? A You 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. Q When did you have the conversation with her where you claim she invited you to her apartment? A I don't exactly recall, but I think it was 2010. Q Do you remember when it was relative to when you first met her? A I'm sure it was months after I first met her. Q Months. Okay. What exactly did she say to you? A I don't recall the exact conversation. Q Did she tell you why she wanted you to come to her apartment? A I don't believe so, no. Q So she just invited you to her apartment, but she didn't tell you why she wanted you to come? A I think it was suggested, but I don't think she said explicitly, no."], [10118, 17, 38, "Page 39", null, null, "Q How would she have suggested that? A \"You want to come by my apartment,\" you know, \"tomorrow morning?\" I think that's suggestive. Q So did she tell you when she wanted you to come by her apartment? A Just in the morning is my recollection. Q Did she tell you where her apartment was? A Yes. Q And 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? A That seems right, yes. Q How did you get into her apartment? A It 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. Q You testified that you had sex at her apartment. Please walk us through what happened. A I 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. Q Was the sex consensual? A Yes. Q How did you know it was consensual? A My recollection is, she invited me into her bedroom. Q Do you remember what she said to you? A Precise words, no. Q Are you aware that Mr. Epstein would instruct women in his orbit to have sex with men"], [10119, 17, 39, "Page 40", null, null, "that he was connected to? A No, I was not. Q You've since become aware of that, correct? A I am not aware of him instructing his assistants to have sex with men, no. I'm not. Q As you sit here today, that is something that you are totally unaware of? A Yes. Q You previously testified that you never spoke to Mr. Epstein about this encounter, correct? A That's correct. Q So how do you know that Mr. Epstein did not instruct this woman to have sex with you? A That's my assumption. It didn't seem -- that's what I assumed. Q Is it possible that, instead of her inviting you to her apartment, you just showed up? A No. Q Were you violent with her? A No. Q Had you ever been to this young woman's apartment or her building before? A No, I had not. Q Did you visit this young woman's apartment or her building after? A No, I did not. Q You said previously you remembered the building was on 66th Street. Is it correct that the building was 301 East 66th Street? A I don't recall the exact number. Q Were you aware at the time that Mr. Epstein housed women he trafficked in this building? A No, I was not."], [10120, 17, 40, "Page 41", null, null, "Q Are you aware of that now? A No, I am not. Q Did you see this young woman following this encounter? A Yes, I did. Q How often? A A few times, I think. Q Was this at Mr. Epstein's New York home? A Yes. Q Did you speak with her? A I believe so, yes. Q What did you talk about? A Just casual conversation. Q Did you engage in any sexual activity with this young woman at any point after your visit to her apartment? A No, I did not. Q And, to be clear, that encounter that you claim was consensual was the first time that you engaged in any sexual activity with this woman? A That's correct. Q This 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? A No, I was not. Q This 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? A No, I was not. Q You were not aware of this at any point up until today?"], [10121, 17, 41, "Page 42", null, null, "Mr. Sullivan. His answer to that would require revealing attorney-client communication. BY Q If 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? A I don't know. Q You previously testified in a sworn deposition that this was your only Epstein-connected sexual encounter. A That's correct. Q Do you stand by that testimony? A I do. Q Did you ever meet any minor girls through Mr. Epstein? A No, I did not. Q But you did meet young women through Mr. Epstein, correct? A Again, I met some of his assistants, who were in their twenties or thirties. Q And you met the woman that you claim you had consensual sex with through Mr. Epstein, correct? A Correct. Q How many young women would you say you met through Mr. Epstein? A A half a dozen. Q Other than the encounter that we just discussed, did you engage in sexual activity with any of those women? A No, I did not. Q Did Mr. Epstein ever pay women to engage in sexual activity with you? A No, he did not. Q I'd like to introduce as minority exhibit A an email chain between you and Mr. Epstein"], [10122, 17, 42, "Page 43", null, null, "starting on August 27th, 2009. The Bates number is EFTA02436302. [Staley Minority Exhibit A. was marked for identification.] BY : Q In 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.\" Mr. Sullivan. This is one document, right? One page? . Correct, it's one page. BY : Q What did you understand Mr. Epstein to mean by, quote, \"Do you need anything there?\" A I 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. Q It does appear that he's offering you something, though, correct? A I think he's just asking if I needed anything there. Q So offering you something. In replying, quote, \"Yep,\" you were affirming that you did need whatever Mr. Epstein was offering, correct? A I don't know what he was offering. Q Sure. 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. A Yeah. He used to set up business with people from the Treasury, people from the royal family -- lots of things he used to set up. Q But you are indicating that you, in fact, need that thing. You are responding, quote,"], [10123, 17, 43, "Page 44", null, null, "\"Yep.\" A Yes. Q I 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 : Q In 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? A Where do you know that's a young woman from? Q Excuse me? I didn't catch that. A Where do you know that it's a young woman from? Q Based on in camera review of the unredacted version of this document. A Ask the question again. Q Did you ask Mr. Epstein to email this young woman your hotel information? A No. Q Did Mr. Epstein tell you that he was emailing this young woman your hotel information? A No. Q Is that something that he had done previously? A No. Q Why do you think that Mr. Epstein shared your hotel information with this young"], [10124, 17, 44, "Page 45", null, null, "woman? A I don't know. Q Was it because Mr. Epstein was instructing this young woman to go to your hotel and have sex with you? A No. I don't know. Q You don't know, or no? A No. I mean, I did not have an encounter with the young woman in a hotel when the -- Q But 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\" -- A No. Q -- or \"I don't know\"? A No. Q How would you know -- A Oh, sorry. No. Q -- that Mr. Epstein hadn't -- A Can you ask the question again? Sorry. Q I 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? A I don't know. Q Did Mr. Epstein otherwise introduce you to young women from Eastern Europe when you were in London? A No. Q Never?"], [10125, 17, 45, "Page 46", null, null, "A Never. Q Did Mr. Epstein ever send women or girls to your hotel or wherever you were staying on any other occasion? A No. Q I'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 : Q In 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? A No."], [10126, 17, 46, "Page 47", null, null, "Q Did Mr. Mountbatten-Windsor show you around London? This was in June of 2010. A Around London? No. Q Did Mr. Mountbatten-Windsor give you a tour of his home? A I visited the palace. I thought it was just by myself. I didn't recall him joining or being there. Q Do you remember when you visited the palace? A Not -- not exactly, no. Q Do you have a year? A No, but I know I went once. Q And that's Buckingham Palace, correct? A Yes. Q And your recollection is that you visited but you weren't with Mr. Mountbatten-Windsor? A That'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. Q So 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. A That's correct. Q And 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. A That's correct. Q I'd like to introduce as minority exhibit D an email -- A Can I make one clarification? Q Sure. A Years later, when I was working in London, I went to the palace on a couple of"], [10127, 17, 47, "Page 48", null, null, "occasions. Q And that is separate from the tour that you also recollect? A Yes. Q Because those were visits and not a tour? A Those were professional visits to the palace in my role with Barclays. Q And when you say \"years later,\" when was that? A That would've been from 2015 to 2021. Q So the tour that you remember would've been some point before 2015? A Yes. Q I'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 Q In 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\"? A I don't know. Q Could it be the same woman from Eastern Europe who Mr. Epstein and Mr. Mountbatten-Windsor were emailing about earlier? A I don't know. Q Why would you be asking Mr. Epstein if a woman was free? A Again, I don't recall this email. Q I understand you don't recall the email, but why would you ask Mr. Epstein if a woman was free?"], [10128, 17, 48, "Page 49", null, null, "A I'm not going to speculate. Q Did you call Mr. Epstein in response to his email? A I don't recall. Q Would you have typically called Mr. Epstein when he asked you to call him? A Yes. Q So you might have. A I might have. But this is 16 years ago. Q A few hours later, you respond, \"I'm with A.\" Is \"A\" Andrew Mountbatten-Windsor? A It seems like it. Q What did that have to do with the previous conversation that you were having with Mr. Epstein? A I don't know. Q Because 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? A Don't know. Q Were the two of you having dinner, as Mr. Mountbatten-Windsor had noted for Mr. Epstein the day prior? A It seems like it. Q Do you remember that dinner? A No. Q Do you remember having dinners with Mr. Mountbatten-Windsor generally? A No. Q You don't have any recollection of any dinner with Mr. Mountbatten-Windsor? A I don't think I had dinners with Mount- -- with Prince Andrew. Q So, when Mr. Mountbatten-Windsor tells Mr. Epstein the two of you are having dinner"], [10129, 17, 49, "Page 50", null, null, "together, he's -- A It's possible. Q -- wrong? A No. Q You just don't remember. 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