Jamie Dimon Deposition in U.S. Virgin Islands v. JP Morgan

Confidential - Pursuant to Protective Order
1 UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK
2
GOVERNMENT OF THE UNITED )
3 STATES VIRGIN ISLANDS )
)
4 Plaintiff, )
)
5 vs. ) 1:22-cv-10904-JSR
)
6 JPMORGAN CHASE BANK, N.A., )
)
7 Defendant/Third- )
Party Plaintiff. )
8 _________________________ )
JPMORGAN CHASE BANK, N.A. )
9 )
Third-Party )
10 Plaintiff, )
)
11 vs. )
)
12 JAMES EDWARD STALEY, )
)
13 Third-Party )
Defendant. )
14
FRIDAY, MAY 26, 2023
15
CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
16
**CONFIDENTIAL BSA PORTIONS UNDER SEPARATE COVER**
17 – – –
18 Videotaped deposition of James
Dimon, held at the offices of JPMorgan Chase,
19 383 Madison Avenue, New York, New York,
commencing at 9:02 a.m. Eastern, on the above
20 date, before Carrie A. Campbell, Registered
Diplomate Reporter and Certified Realtime
21 Reporter.
22
23 – – –
24 GOLKOW LITIGATION SERVICES
877.370.3377 ph | 917.591.5672 fax
25 [email protected]
Golkow Litigation Services Page 1

1 A P P E A R A N C E S :
2
3 MOTLEY RICE LLC
BY: LINDA SINGER
4 [email protected]
MEGHAN S.B. OLIVER
5 [email protected]
MIMI LIU (VIA ZOOM)
6 [email protected]
WILLIAM H. NARWOLD (VIA ZOOM)
7 [email protected]
401 Ninth Street NW, Suite 630
8 Washington, DC 20004
(202) 232-5504
9 Counsel for the Government of the
United States Virgin Islands
10
11
BOIES SCHILLER FLEXNER LLP
12 BY: DAVID BOIES
[email protected]
13 ALEXANDER LAW
[email protected]
14 ANDREW VILLACASTIN (VIA ZOOM)
[email protected]
15 55 Hudson Yards, 20th Floor
New York, New York 10001
16 (212) 446-2300
17
and
18
19 BOIES SCHILLER FLEXNER LLP
BY: DANIEL CRISPINO (VIA ZOOM)
401 East Las Olas Boulevard, Suite 1200
21 Fort Lauderdale, Florida 33301
(954) 356-0011
22
23 and
24
25

1 EDWARDS POTTINGER
BY: BRITTANY HENDERSON
2 [email protected]
BRAD EDWARDS (VIA ZOOM)
3 [email protected]
DEAN KAIRE (VIA ZOOM)
4 [email protected]
425 North Andrews Avenue
5 Fort Lauderdale, Florida 33301
(800) 400-1098
6 Counsel for Jane Doe plaintiffs
7
8 WILMER CUTLER PICKERING HALE AND DORR LLP
BY: JOHN J. BUTTS
9 [email protected]
60 State Street
10 Boston, Massachusetts 02109
(617) 526-6000
11
12 and
13
WILMER CUTLER PICKERING HALE AND DORR LLP
14 BY: CHRISTOPHER J. BOUCHOUX
[email protected]
15 7 World Trade Center
250 Greenwich Street
16 New York, New York 10007
17
and
18
19 MASSEY & GAIL LLP
BY: LEONARD A. GAIL
50 East Washington Street, Suite 400
21 Chicago, Illinois 60602
(312) 283-1590
22 Counsel for JPMorgan Chase Bank, N.A.
23
24
25

1 WILLIAMS & CONNOLLY LLP

BY: BRENDAN V. SULLIVAN, JR.
2 [email protected]
STEPHEN L. WOHLGEMUTH
3 [email protected]
680 Maine Avenue SW
4 Washington, DC 20024
(202) 434-5000
5 Counsel for James Edward Staley
6
7 ALSO PRESENT:
8 STACEY FRIEDMAN, Executive Vice
President and General Counsel,
9 JPMorgan Chase & Co.
10 CYNTHIA MARVIN, paralegal, Motley
Rice
11
GINA VELDMAN, trial technician,
12 Precision Trial Solutions (VIA ZOOM)
13
14 V I D E O G R A P H E R :
DAN LAWLOR,
15 Golkow Litigation Services
16 – – –
17
18
19
20
21
22
23
24
25

1 INDEX
2 PAGE
3 APPEARANCES.................................. 2
4 EXAMINATIONS
5 BY MR. SULLIVAN............................ 11
6 BY MS. SINGER.............................. 82
7 BY MR. BOIES............................... 218
8 BY MS. SINGER.............................. 376
9
10 EXHIBITS
11 No. Description Page
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19 CERTIFICATE..................................414
20 ACKNOWLEDGMENT OF DEPONENT...................416
21 ERRATA.......................................417
22 LAWYER'S NOTES...............................418
23
24
25

1 VIDEOGRAPHER: We are now on

2 the record. My name is Dan Lawlor.
3 I'm a videographer representing Golkow
4 Litigation Services.
5 Today's date is May 26, 2023,
6 and the time is 9:02 a.m.
7 This video deposition is being
8 held in New York City, New York, in
9 the matter of Jane Doe 1, Government
10 of the United States Virgin Islands v.
11 JPMorgan Chase Bank, N.A.
12 The deponent is Jamie Dimon.
13 Counsel will be noted on the
14 stenographic record.
15 The court reporter is Carrie
16 Campbell and will now swear in the
17 witness.
18
19 JAMES DIMON,
20 of lawful age, having been first duly sworn
21 to tell the truth, the whole truth and
22 nothing but the truth, deposes and says on
23 behalf of the Plaintiff, as follows.
24 /
25 /

1 DIRECT EXAMINATION
2 QUESTIONS BY MR. SULLIVAN:
3 Q. Good morning, sir. My name is
4 Brendan Sullivan, counsel for Jes Staley, and
5 I'll begin the questioning today.
6 First off, I want you to focus
7 on the year 2006. Mr. Epstein was indicted
8 in Florida in the summer of 2006.
9 Were you informed of that
10 indictment by personnel in the bank?
11 A. I do not believe I was.
12 Q. Did you speak with Jes Staley
13 about the fact that Mr. Epstein had been
14 indicted?
15 A. I did not.
16 Q. Did you receive a report from
17 Jes Staley that he had visited with
18 Mr. Epstein the day or so after the
19 indictment?
20 A. I did not.
21 Q. Did Mr. Staley inform you what
22 Mr. Epstein said with respect to the
23 indictment which had been returned a day or
24 two before?
25 A. Nope.

1 Q. Did you speak with Mr. Staley

2 at all in the year 2006 about Mr. Epstein?
3 A. I don't recall ever having a
4 conversation with him about Jeff Epstein.
5 Q. Do you -- strike that.
6 During the year 2006, did you
7 speak at any time with Mary Erdoes about the
8 Epstein indictment and whether or not he
9 should continue as a customer of the bank?
10 A. Nope.
11 Q. During the year 2006, did you
12 speak with general counsel Steve Cutler with
13 respect to Mr. Epstein having been indicted
14 and whether he should remain a customer of
15 the bank?
16 MR. BUTTS: Objection.
17 And I'll instruct you -- you
18 may answer the question yes or no, and
19 we'll take it from there.
20 THE WITNESS: No.
22 Q. Were you aware of the fact that
23 Mr. Epstein had been indicted, through any
24 source other than bank personnel, in the year
25 2006?

1 A. Not to my knowledge, no.

2 Q. Were you aware that personnel
3 of the bank were investigating to determine
4 the status of Mr. Epstein as a bank client --
7 Q. -- in 2006?
8 MR. BUTTS: Objection to form.
9 You may answer.
10 THE WITNESS: No.
12 Q. Did any bank personnel or
13 employee have a conversation with you about
14 the internal investigation being conducted
15 with respect to Mr. Epstein shortly after the
16 indictment in July 2006?
17 MR. BUTTS: Objection. Form.
18 You may answer.
19 THE WITNESS: No.
21 Q. Do you know what a rapid
22 response team is?
23 Again, focusing on 2006.
24 Things may have changed, but I'm interested
25 in focusing on 2006.

1 MR. BUTTS: Are you asking what

2 he knew in 2006 or what he knows
3 now --
4 MR. SULLIVAN: Only what he
5 knew --
6 MR. BUTTS: In 2006.
7 MR. SULLIVAN: That's what I'm
8 making clear. I'm trying to make
9 clear to him we're focusing on the
10 year 2006.
12 Q. When we move to 2007, I'll give
13 you a heads-up on it.
14 A. Okay.
15 Q. Focus just on 2006.
16 My question is, in 2006, were
17 you aware that there was a rapid response
18 team in the bank focusing on the fact that
19 Mr. Epstein had been indicted and whether or
20 not he should remain as a customer of the
21 bank?
23 You may answer.
24 THE WITNESS: No.
25 MR. SULLIVAN: You want to

1 state what that objection is? Because

2 I thought it was a rather perfect
3 question.
4 MR. BUTTS: Yeah, I objected to
5 form, and it was compound, and there
6 were vague pieces to your question.
7 But if you'd like an answer,
8 he's going -- I think he's given it.
9 MR. SULLIVAN: Uh-huh. Let me
10 try again. I guess I've forgotten how
11 to ask a question.
13 Q. During the year 2006, were you
14 aware that a rapid response team was formed
15 in the bank to investigate the status of
16 Mr. Epstein's remaining a client of the bank?
17 A. No.
18 Q. Do you know what a rapid
19 response team is as it existed in 2006? Are
20 you familiar with the term?
21 A. No. I am today. I wasn't
22 then.
23 Q. That's why I'm trying to make
24 it clear. If I'm confusing, just say so, and
25 I'll repeat it.

1 In 2006, what was Mary Casey's

2 position at the bank?
3 A. I don't know.
4 Q. Do you know Mary Casey?
5 A. I know who she is now.
6 Q. Okay. But you did not know in
7 2006; is that your --
8 A. Not that I recall, no.
9 Q. Okay. Is it your understanding
10 that when an indictment of a client is
11 returned, that the bank does examine the
12 relationship between the client and the bank
13 as a matter of course in 2006? Do you know?
14 A. I don't remember what I would
15 have thought about that in 2006, but I would
16 expect that to be true.
17 Q. Okay. Do you know what a
18 derogatory information report is? In 2006.
19 A. Not in 2006. I mean, I know
20 what they are, but...
21 Q. Do you know in 2006 whether the
22 bank had a team called "security services,"
23 or was that an outside vendor?
24 A. I don't recall.
25 Q. Were you aware in 2006 that the

1 bank had access to numerous press reports

2 which referenced the crimes allegedly
3 committed by Mr. Epstein?
4 A. No.
5 Q. Were you aware that there was a
6 recommendation by a number of people in the
7 bank as to the change of Epstein's status as
8 a customer of the bank in 2006?
9 A. No.
10 Q. In 2006, after the indictment
11 was returned against Mr. Epstein, did you
12 have a conversation with Catherine Keating
13 about that matter?
14 A. Not that I recall.
15 Q. In 2006, did you have a
16 conversation with John Duffy about that
17 matter?
18 A. I don't believe so.
19 Q. Did you know John Duffy in
20 2006?
21 A. I believe I did.
22 Q. What was his position then?
23 A. I don't specifically recall,
24 but he -- I think he was running the US
25 private bank.

1 Q. And what was Catherine

2 Keating's position in 2006?
3 A. I believe she was a private
4 banker.
5 Q. What does that term mean,
6 "private banker," in 2006?
7 A. That they cover clients.
8 Q. Were you aware that a
9 conclusion was drawn by the rapid response
10 team that Mr. Epstein's relationship with the
11 bank would be changed and diminished in the
12 year 2006?
13 A. No.
14 Q. Were you told in 2006 that a
15 decision was made that Mr. Epstein would
16 remain solely as a banking client and on a
17 reactive client service basis?
18 A. No.
19 Q. Could you define the term, if
20 you understand it, "reactive client basis"?
21 A. I can't.
22 Q. Were you told by any banking
23 official or employee of the bank in 2006 that
24 a decision would be made not to proactively
25 solicit new investment business from

1 Mr. Epstein?
3 You may answer.
4 THE WITNESS: No.
6 Q. Is it your testimony, then,
7 from 2006 that you did not speak with any
8 bank officer, director, employee or agent
9 with respect to Mr. Epstein's indictment in
10 the summer of 2006?
11 A. Yes. As best as I can recall,
12 yes.
13 Q. In 2006, did the indictment of
14 Mr. Epstein come to your attention from any
15 source, not limiting to employees of the
16 bank?
17 A. Not that I can recall.
18 Q. Do you -- did you read any
19 newspaper article or did any media
20 information come to your attention in 2006
21 with respect to the indictment of Mr. Epstein
22 in Florida?
24 Q. In the year 2007, did it come
25 to your attention that the bank continued to

1 examine the relationship between Mr. Epstein

2 on the one hand and the bank?
4 Q. Did you have any conversation
5 with Mr. Jes Staley in the year 2007 about
6 Mr. Epstein and his relationship with the
7 bank and/or his -- and the indictment of
8 Mr. Epstein?
10 Q. In the year 2007, in the fall,
11 September 20, 2007, or thereabouts, did you
12 receive any information with respect to a
13 potential plea deal entered into between
14 Mr. Epstein on the one hand and the State of
15 Florida on the other?
16 A. No.
17 Q. In the year 2007, were you
18 informed by any bank official that there were
19 lawsuits filed against Mr. Epstein by young
20 women alleging that they were sexually
21 abused?
23 You may answer.
24 THE WITNESS: No.
25


2 Q. In the fall of 2007, did you
3 receive any information from any employee of
4 the bank with respect to Mr. Epstein's
5 potential plea agreement with the State of
6 Florida?
7 A. No.
8 Q. Do you know Howard Rubenstein?
9 A. I know the name.
11 with Mr. Rubenstein about Jeffrey Epstein in
12 the year 2007?
13 A. I don't recall any such
14 conversation.
16 aware that Mr. Epstein was represented by
17 Alan Dershowitz, Gerald Lefcourt, Roy Black
18 and/or Ken Starr in the year 2007?
19 A. No.
20 Q. Do you know any of those
21 lawyers? In the year 2007.
22 A. Let me see. "Know." Do I know
23 them personally, or do I know who they might
24 be?
25 Q. Let's try personal first.

1 A. I don't think so. I may have

2 met Alan Dershowitz.
3 Q. But is it your testimony you
4 had no conversation with any of those lawyers
5 with respect to Mr. Epstein in the year 2007?
6 A. To the best of my recollection.
7 Q. Did it come to your attention
8 that there was litigation filed in which more
9 than several women made allegations of sexual
10 abuse by Jeffrey Epstein in the year 2007?
12 You may answer.
13 THE WITNESS: No.
15 Q. In the year 2007, did you know
16 a bank employee Lisa Waters?
19 a Phil Dilorio, D-i-l-o-r-i-o?
20 A. Yes.
21 Q. What was his position in the
22 year 2007?
23 A. He was a senior person in the
24 private bank.
25 Q. In the year 2007, did you

1 customarily read New York newspapers?

2 A. It's a broad question. The New
3 York Times, yes.
4 Q. Did you ever read The New York
5 Post in the year 2007?
7 Q. Are you familiar with the
8 column known as Page Six, known to all
9 New Yorkers?
10 A. I didn't get the Post back
11 then, but I probably knew what Page Six was,
12 yes.
13 Q. In the year 2007, did Mary
14 Erdoes discuss with you any of the publicity
15 in the media related to Jeffrey Epstein and
16 his alleged criminal conduct?
18 Q. Did Mary Erdoes ever forward to
19 you any of the newspaper articles she
20 received in the year 2007 related to
21 Mr. Epstein and his alleged sexual
22 misconduct?
24 Q. In the year 2007, did you learn
25 about the allegations pending about

1 Mr. Epstein from any source other than an

2 employee of the bank?
4 Q. Were you aware that in the year
5 2008 bank officials examined the allegations
6 against Mr. Epstein in order to determine
7 whether he should remain a client of the
8 bank?
10 You can answer.
11 THE WITNESS: No.
14 informed that the bank officials were waiting
15 for the entry of a plea by Epstein in the
16 criminal matter in Florida?
18 You may answer.
19 THE WITNESS: No.
22 informed by anyone at the bank that there
23 were additional lawsuits filed in the state
24 of Florida against Mr. Epstein for sexual
25 misconduct?


2 Q. In or about July 1, 2008, were
3 you informed that Mr. Epstein entered a plea
4 of guilty to the indictment in Florida?
5 A. No.
6 Q. Were you informed in the year
7 2008 that Mr. Epstein began a prison sentence
8 as a result of pleading guilty to the
9 criminal charges in Florida?
10 A. No.
11 Q. Were you informed by Mary
12 Erdoes that Mr. Epstein had pled guilty in
13 the summer of 2008?
14 A. No.
15 Q. Or that Mr. Epstein began a
16 jail sentence in the summer of 2008?
17 A. No.
18 Q. Did you have a conversation
19 with Jes Staley in 2008 with respect to the
20 fact that Mr. Epstein had pled guilty and
21 gone to jail?
22 A. No.
24 2008, the bank once again reviewed the status
25 of Jeffrey Epstein and whether he should

1 remain a customer of the bank due to his

2 guilty plea entered in Florida?
3 A. No.
4 Q. Did you travel to the
5 Democratic Convention at the end of August in
6 the year 2008 with Jes Staley?
7 A. I don't recall specifically.
8 Where was the convention? I
9 might have. I don't recall if I went with
10 Jes Staley or not.
11 Q. Where was Jes Staley's office
12 located compared to your office in the year
13 2008?
14 A. To the best of my recollection,
15 he was on a different floor until he became
16 the head of the investment bank.
17 Q. What year did he become the
18 head of the investment bank?
20 sometime in 2009.
21 Q. So before -- after he became
22 head of the investment bank, was he on the
23 same floor as your office?
24 A. At one point, yes.
25 Q. And what building was that in?

1 A. 270 Park Avenue.

2 Q. And how far from your office
3 was his office?
4 A. He was on -- I was on one
5 corner, he was on the other corner, so a
6 couple hundred feet.
7 Q. Okay. And in the year 2008,
8 where was Mr. Staley's office at that time?
11 2008 that there was a second rapid response
12 team examination of the relationship between
13 Epstein and the bank?
14 A. No.
15 Q. In 2008, what was the position
16 of Mary Casey?
17 A. I do not know.
18 Q. Do you know a Marc Sheridan and
19 his position in the year 2008?
21 Q. Would you expect that -- strike
22 that.
23 Were you told in the year 2008
24 that Epstein was sentenced to a period of
25 12 months in jail for solicitation and an

1 additional six months for procuring a person

2 under the age of 18 for prostitution?
3 A. No.
4 Q. Were you informed in 2008 that
5 he would be in prisoned for a period of
6 18 months, followed by a one-year term of
7 probation?
8 A. No.
10 2008 that after an examination by the rapid
11 response team that the conclusion was reached
12 that there would be no change to the
13 relationship between Epstein and the bank,
14 despite the fact that he had pled guilty,
15 sentenced to jail?
16 A. No.
17 Q. Did you have a conversation
18 with Mr. Cutler about that decision or
19 about -- strike that -- about that decision?
21 And you may answer the question
22 yes or no.
23 THE WITNESS: No.
25 Q. At any time in 2008, did you

1 have a conversation with Jes Staley about the

2 development that Mr. Epstein had pled guilty
3 and gone to jail?
5 Q. In 2008, did you become aware
6 that Mr. Epstein's plea had resulted in a
7 jail term from any source other than someone
8 in the bank?
10 Q. Did you read or receive any
11 media reports about Mr. Epstein's involvement
12 in the criminal system resulting in the plea
13 of guilty and a prison term?
15 Q. You just indicated, I believe,
16 that Jes Staley was promoted to head of the
17 investment bank in 2009.
18 Is that correct?
19 A. I believe it was sometime in
20 2009, yes.
21 Q. And whatever that date was, his
22 office would then have moved, according to
23 your memory --
24 A. At one point --
25 Q. -- on the same -- excuse me, on

1 the same floor as your office, correct?

2 A. At some point after his
3 appointment, yes.
4 Q. And what was the address of
5 your office in 2009 and the floor on which it
6 was located?
8 You may answer.
9 THE WITNESS: 270 Park Avenue,
10 and it was the 48th floor.
11 QUESTIONS BY MR. SHERIDAN:
12 Q. Okay.
13 A. 48th, I think.
14 Q. During the year 2009, did you
15 receive any information from any employee of
16 the bank with respect to the status of
17 Mr. Epstein's continued involvement as a bank
18 customer?
19 A. No.
21 with Mary Erdoes in the year 2009 with
22 respect to Jeffrey Epstein?
23 A. No.
25 with Jes Staley at any time during the year

1 2009 with respect to Mr. Epstein and his

2 relationship to the bank?
3 A. No.
4 Q. In 2009, did you speak with
5 Steve Cutler about the continued relationship
6 that Epstein had with the bank?
8 And again, you may answer yes
9 or no.
10 THE WITNESS: Okay. No.
12 Q. In the year 2010, did you
13 receive information that the bank was once
14 again looking into the relationship between
15 Mr. Epstein and the bank?
16 A. No.
17 Q. Were you told in the year 2010
18 that there were news reports indicating that
19 federal authorities were looking into
20 additional criminal conduct by Mr. Epstein?
21 A. No.
22 Q. Did you have a conversation in
23 the year 2010 with Mr. Jes Staley about
24 Mr. Epstein and his continued relationship
25 with the bank?

1 A. No.
2 Q. Did you have a discussion with
3 Mr. Cutler in the year 2010 about
4 Mr. Epstein's continued relationship with the
5 bank?
7 And, again, yes or no.
8 THE WITNESS: No.
10 Q. In 2010, were you familiar with
11 the term "due diligence review," or shorthand
12 "DDR"?
13 A. Not specifically.
14 Q. Did Mary Erdoes discuss with
15 you in the year 2010 the fact that it
16 appeared that federal authorities were
17 conducting a new investigation with respect
18 to Mr. Epstein's alleged misconduct?
19 A. No.
20 Q. In the year 2010, did you have
21 a discussion with Jes Staley with respect to
22 the fact that federal authorities were
23 conducting a renewed investigation into the
24 alleged misconduct of Mr. Epstein?
25 A. No.

1 Q. Did Mary Erdoes ever explain to

2 you that there were new allegations against
3 Mr. Epstein with respect to inviting young
4 women to his Palm Beach home?
6 You may answer.
7 THE WITNESS: No.
9 Q. Did Mary Erdoes ever inform you
10 that Mr. Epstein had settled several lawsuits
11 brought by underage women in the year 2010?
12 A. No.
13 Q. What was Ms. Mary Erdoes'
14 position in 2010?
15 A. I believe she was head of asset
16 management.
17 Q. And did she report directly to
18 you in that capacity?
19 A. I believe so, yes.
20 Q. Was there any personnel between
21 you, or was she a direct report?
22 A. I believe direct.
23 Q. And during the year 2010, could
24 you tell me whether you met with Ms. Mary
25 Erdoes on a frequent basis?


2 You may answer.
3 THE WITNESS: What is
4 "frequent"?
6 Q. I was going to let you decide
7 that.
8 Let me -- twice a week?
9 A. I travel a lot, she travels a
10 lot, but it -- some weeks it was twice a
11 week, yes.
12 Q. Okay. It wasn't once every few
13 months?
14 A. No.
15 Q. Tell me again, where was her
16 office located?
17 A. In 2010? I believe it was on
18 the same floor as me.
19 Q. Same floor?
20 A. I believe. She moved at one
21 point, but --
22 Q. Right.
23 A. -- I'm sure you can get those
24 records.
25 Q. We have a lot of records. I'm

1 not sure we need the -- that now, but...

2 Your current recollection is
3 that she was on the floor?
4 A. Yeah.
5 Q. And would she walk into your
6 office on occasion?
8 You may answer.
9 THE WITNESS: Occasionally,
10 yes.
12 Q. And you -- would you -- do you
13 tend to wander out of your office, or do
14 people tend to come to your office?
16 You may answer.
17 THE WITNESS: Both.
19 Q. Both.
20 And you had a good relationship
21 with Mary Erdoes?
22 A. Yes, and I still do.
23 Q. And during the calendar year
24 2010, you had no discussion with Mary Erdoes
25 about the developments in the Jeffrey Epstein

1 saga?
3 Q. Were you aware during the year
4 2010 that the bank continued to examine the
5 relationship between Epstein on the one hand
6 and the bank on the other as a result of his
7 criminal conviction and the subsequent
8 information that the federal authorities were
9 renewing their investigation into his
10 criminal conduct?
11 A. No.
12 Q. In the year 2010, would you
13 have received any information about
14 Mr. Epstein from sources other than bank
15 employees?
17 You may answer.
18 THE WITNESS: Not that I
19 recall.
22 informed of the fact that there was a further
23 review of Mr. Epstein's status as a bank
24 client?
25 A. No.

1 Q. Were you aware in the year 2011

2 that a rapid response team once again
3 reviewed the status of Mr. Epstein as a bank
4 client?
5 A. No.
7 Mr. Paul Morris?
9 Q. During -- do you know what his
10 position was?
11 A. I don't recall him at all.
12 Q. Do you know during the year
13 2011 what Mary Casey's position was?
14 A. No.
15 Q. Were you aware that even from
16 the very beginning in 2006 -- strike that.
17 Were you aware that the bank
18 reviewed the relationship with Mr. Epstein --
19 want to take a quick break?
20 A. Nope.
21 Q. I'll start again.
22 MR. BUTTS: Okay.
24 Q. Were you aware that each and
25 every time that the bank reviewed the status

1 of Mr. Epstein, they focused on cash

2 transactions that he had engaged in?
3 MR. BUTTS: Is that the end?
4 Objection to form.
5 You may answer.
6 THE WITNESS: No.
8 Q. In the years 2006, '7, '8, '9
9 and '11, did you learn from any bank employee
10 that one area of inquiry in the Epstein
11 relationship was his use of large cash
12 withdrawals?
14 You may answer.
15 THE WITNESS: No.
18 generally aware that officials of the bank
19 monitored cash withdrawals?
21 You may answer.
22 THE WITNESS: Generally, yes.
24 Q. What's your understanding of
25 the bank's duty with respect to that

1 monitoring obligation?
2 A. It's a very broad question.
3 Number one, you have to file
4 currency reports if it's over $10,000. And
5 second, we do work on activity in bank
6 accounts, including cash, for asset -- for
7 money laundering and things like that.
8 Q. And has that been true from
9 2006 up through 2011?
10 A. Yes. But the rules and
11 requirements and technology changes during
12 the course of time, but, yes.
13 Q. And is it your testimony that
14 as of 2011 you were not informed by any bank
15 employee that the cash activity of
16 Mr. Epstein's accounts was of concern?
17 A. No.
19 2011 that there were further allegations
20 about Mr. Epstein's criminal activities?
21 A. No.
22 Q. Were you informed by anyone
23 that the federal investigation was continuing
24 despite the fact that Epstein was released
25 from prison and no longer on parole?


2 Q. Do you have a home in Florida?
3 A. I didn't then.
4 Q. Did you between the -- between
5 the years of 2006 and 2013 have a home in
6 Florida?
7 A. No.
9 2011 by bank personnel that they knew that
10 there were two dozen lawsuits filed by women
11 making claims against Epstein that they were
12 abused under age?
13 A. No.
14 Q. Were you aware in -- strike
15 that.
16 Were you informed by any bank
17 personnel that Jeffrey Epstein had been
18 labeled a lifelong registered sex offender in
19 the year 2011?
20 A. No.
22 who William Langford was?
23 A. I knew who he was. I don't
24 know if I knew who he was in 2011.
25 Q. You know now who he was -- who

1 he is?
2 A. Yeah. I remember him, yeah.
3 Q. In 2011, did you have any
4 discussion with William Langford about the
5 status of Mr. Epstein's relationship with the
6 bank?
7 A. I do not believe so.
8 Q. What was Mr. Langford's role in
9 2011?
10 A. I don't know his specific role
11 in 2011.
12 Q. In the year 2011, did you have
13 any conversation with Jes Staley about
14 Jeffrey Epstein and his relationship with the
15 bank?
16 A. No.
18 with Jes Staley about the alleged misconduct
19 of Jeffrey Epstein?
20 A. No.
21 Q. Did you receive any information
22 from Jes Staley with respect to knowledge he
23 had about Mr. Epstein?
25 You may answer.


2 recall.
4 Q. Were you informed by Mr. Cutler
5 in the year 2011 that he had reapproved the
6 status of Mr. Epstein as a bank client?
9 with Mr. Cutler in the year 2011 about
10 Jeffrey Epstein?
11 A. No.
12 Q. Were you informed by Langford
13 or Cutler or anyone else in compliance or
14 legal that they had independently reached out
15 to Mr. Epstein's lawyer, Ken Starr, in the
16 year 2011?
18 Q. Were you ever informed that
19 there were cons -- there was one or more
20 conversations between Ken Starr and
21 Mr. Langford about Jeffrey Epstein?
23 Q. Were you aware in 2000 --
24 strike that.
25 Were you informed in 2011 that

1 the bank was continuing to examine the

2 relationship between Epstein on the one hand
3 and the bank on the other?
4 A. No.
5 Q. Did anyone inform you that Ken
6 Starr informed the bank that in his views no
7 crimes had been committed by Mr. Epstein?
8 A. No.
9 Q. Were you informed that Mr. Ken
10 Starr related to bank officials that he and
11 other counsel for Epstein were attempting to
12 have the plea entered in the summer of 2008
13 dismissed?
15 You may answer.
16 THE WITNESS: No.
18 Q. In 2011, did you have any
19 conversation with Mr. Cutler about the status
20 of Jeffrey Epstein as a customer of the bank?
21 A. No.
23 informed that a New York court had upheld the
24 status of Jeffrey Epstein as a habitual
25 sexual offender?

1 A. No.
2 Q. Did any person in the bank,
3 Mary Erdoes, Cutler, Langford, Keating, Casey
4 or others, inform you in the year 2011 of the
5 New York court's decision with respect to
6 Mr. Epstein remaining as -- on a sexual
7 offender list?
9 You may answer.
11 recall.
13 Q. Were you aware that there was
14 an additional evaluation of the Epstein and
15 bank relationship in the year 2011?
16 A. No.
17 Q. Were you informed that the
18 basic status of Epstein was maintained each
19 and every time it was reviewed from '06
20 through 2011?
22 You may answer.
23 THE WITNESS: No.

1 2011 the conclusion from the rapid response

2 team was that there was no change to the
3 relationship approach with Jeffrey Epstein?
4 A. No.
6 2011 that the bank still observed Epstein
7 withdrawals in the amount of 20 to $40,000 in
8 cash per month?
9 A. No.
10 Q. Had you ever been told that one
11 explanation for the cash withdrawal was to
12 pay for jet fuel in Epstein's excursions
13 around the world?
14 A. No.
15 Q. In 2011 when the determination
16 was made that Epstein would continue to be a,
17 quote, banking client only, end of quote,
18 what does that mean according to your
19 understanding, "banking client only"?
21 You're asking him just what
22 does he understand by the term?
23 MR. SULLIVAN: What does he
24 understand by the term "banking client
25 only" as the head of the bank. If he

1 has an understanding.
2 THE WITNESS: I would just kind
3 of guess, but that's about it.
5 Q. Well, we don't need guesses.
6 I'm sure your client -- your lawyer will
7 object to that. I do.
8 Do you have any understanding
9 as of 2011 that the bank did restrict
10 Mr. Epstein in the years 2006, '7, '8, '9,
11 '10 and '11?
12 A. No.
13 Q. Do you have any knowledge that
14 there was any restriction on Mr. Epstein
15 during those years?
16 A. No.
17 Q. During the year 2011, were any
18 reports made to you that news stories
19 regarding Jeffrey Epstein were now suggesting
20 that he was involved in human trafficking?
21 A. No, not that I recall.
22 Q. Did the bank, in 2011, have a
23 program directed to identifying potential
24 human trafficking by customers?

1 You may answer.

2 THE WITNESS: Yeah, I don't
3 know specifically about that.
5 Q. Have you ever heard -- strike
6 that.
7 In the years 2006 through 2013,
8 were you aware that there was any program in
9 the bank which focused on the serious problem
10 of human trafficking?
12 You may answer.
13 THE WITNESS: I don't recall
14 the specific years, no.
16 Q. Do you recall whether or not
17 there was a program?
19 You may answer.
20 THE WITNESS: I think it was
21 generally part of our anti-money
22 laundering program, yes.
24 Q. And who was in charge of that
25 in the year 2011; do you know?

1 A. I don't know.
2 Q. Were you aware that in 2011
3 personnel Catherine Keating and William
4 Langford and Steve Cutler met to discuss the
5 implications of human trafficking with
6 respect to the Jeffrey Epstein banking
7 relationship?
8 A. No.
9 Q. In 2011, did Mr. Cutler
10 indicate to you that he approved a
11 continuation of the Epstein banking
12 relationship?
13 A. No.
14 Q. Where is Mr. Cutler's office
15 compared to your office?
16 MR. BUTTS: In 2011?
17 MR. SULLIVAN: In 2011. I do
18 slip up. I try to put those dates in
19 there, but you catch me every time.
20 MR. BUTTS: I'm helping you
21 with a clear record.
22 MR. SULLIVAN: Thank you.
23 THE WITNESS: He had the office
24 right next to me.
25


2 Q. He did?
3 A. Yes.
4 Q. For how many years -- strike
5 that.
6 During the years 2006
7 through 2013, was his office next door to
8 you?
9 A. I forgot the year we hired him.
10 MS. FRIEDMAN: When did Joe --
11 THE WITNESS: Around --
12 sometime around 2006, I think. Yeah,
13 he was very close to me most of that
14 time. I don't know when we moved in.
15 He never moved out until he retired.
17 Q. Okay. So fair to say his
18 office was as close to yours as it could get?
19 A. Yes.
20 Q. During that period roughly 2006
21 through 2013?
22 A. Yes.
23 Q. Were you informed that there
24 was a disagreement about whether Mr. Epstein
25 should remain as a client of the bank?

1 A. No.
2 Q. Were you informed -- what
3 was -- strike that.
4 What was Mr. Langford's
5 position in 2011?
6 A. I don't recall specifically. I
7 know he was in compliance.
8 Q. Was it your understanding that
9 Mr. Cutler had to approve himself the
10 decision that Epstein would remain a banking
11 client, having been guilty of a felony?
13 Q. During this period '6 through
14 '11, did compliance report to Mr. Cutler?
16 Q. Did any banking official inform
17 you that after officials met in August
18 of 2011, it was decided that Epstein remain
19 as a client but would be flagged as high
20 risk?
21 A. No.
22 Q. Did anyone inform you that as a
23 high-risk client the bank would proceed with
24 business as usual?

1 You may answer.

2 THE WITNESS: No.
4 Q. Were you informed that Epstein
5 would remain as a banking client only?
6 A. No.
7 Q. Can you explain your
8 understanding in 2011 of what the words
9 "bank" -- quote, "banking client only," end
10 quote, mean?
11 A. Not specifically, no. I can
12 guess, if you want.
13 Q. No, counsel would be mad at me.
14 MR. BUTTS: True.
15 THE WITNESS: He'd be mad at
16 me, too.
17 MR. SULLIVAN: Don't need that
18 on a holiday weekend, do we?
19 MR. BUTTS: Is it a holiday
20 weekend?
22 Q. In the original analysis done
23 by the rapid response team on October 17,
24 2006, the bottom-line conclusion was that the
25 bank would not, quote, "proactively solicit

1 new investment business from Epstein," end of

2 quote.
3 Can you inform me as to what
4 those words mean in the banking world in
5 2006?
6 A. Could you repeat the question?
7 Q. Yes.
8 MR. BUTTS: When you -- it may
9 be helpful -- do you have -- you're
10 reading from a document.
11 Would you like to see the
12 document?
13 THE WITNESS: It's up to him.
14 MR. BUTTS: Okay.
15 MR. SULLIVAN: Thank you. I
16 was just going to say that; it's up to
17 me.
19 Q. The conclusion, sir, was that,
20 quote, "We will not proactively solicit new
21 investment business from him," end quote.
22 I'm just asking in 2006, as the
23 head of the bank, what does that mean to you?
24 A. I think the words speak for
25 themselves. That I assume that's what they

1 mean.
2 Q. Okay. Just clearly what they
3 say.
4 Focusing on 2011 for a few
5 moments more, tell me, is Mr. Cutler -- does
6 he directly report to you?
7 A. What year did you say?
8 Q. 2011.
9 MR. BUTTS: 2011.
10 THE WITNESS: Yes.
12 Q. And does he have a reporting
13 responsibility to the board of directors as
14 well?
15 A. At least indirectly, yes.
16 Q. Did Mr. Cutler ever make a
17 report to the board about Mr. Epstein and the
18 limitations the bank had imposed upon
19 Epstein?
20 A. I do not know.
21 Q. During the years 2006 to 2011,
22 at any time did you discuss Mr. Epstein and
23 his relationship with the bank with the board
24 of directors?

1 Q. Did you, during that period of

2 time, have any discussion with any single
3 member of the board about that subject?
5 Q. Did Mr. Cutler regularly attend
6 board meetings?
7 A. Yes.
8 Q. Were you informed that in the
9 year 2012 Mr. Cutler once again reapproved
10 the status of Mr. Epstein as a bank customer?
11 A. No.
12 Q. Did you have any discussion
13 with Mr. Staley in the year 2011 or 2012 with
14 respect to Mr. Epstein?
15 A. No.
16 Q. I'm going backward in time,
17 sir, not to confuse anybody, but could you
18 inform us when you became the CEO of Bank
19 One?
20 A. Is that a question?
21 Q. When did you become the CEO of
22 Bank One?
23 A. I believe it was April 1,
24 2000 -- the year 2000.
25 Q. And in connection with your --

1 had you been at the bank before, or did you

2 come from other places?
3 A. I came from other place.
4 Q. Where was your prior?
5 A. I was the president of
6 Citigroup. Citibank. Citigroup at the time.
7 Q. In connection with your service
8 at Bank One, did you get to know Mr.
9 ?
10 A. I don't remember when I got to
11 know him. It may very well have been before
12 that.
13 Q. Was he a big customer of Bank
14 One?
15 A. Not really, no.
16 Q. How did you get to know
17 Mr. ?
19 Q. What was the nature of your
20 relationship with him?
21 A. Well, he was the
22 , running a large company, or the
23 president of a large company, and I think
24 somewhere along there I just, like, met him
25 in the ordinary course.

1 Q. Was he a customer of Bank One?

2 A. I don't recall specifically,
3 but I know he had been at one -- at a minimum
4 had been at one point.
5 Q. Over the years, did you have
6 occasion to meet Jeffrey Epstein as -- in
7 connection with being a financial advisor to
8 Mr. ?
9 A. No.
10 Q. You never met Mr. Epstein?
11 A. I don't believe I ever met
12 Mr. Epstein, no.
13 Q. Well, were you aware that
14 Mr. Epstein was an advisor to ?
15 A. Back then? No.
16 Q. Yes.
17 A. As of today, yes.
18 Q. Just interested in the -- we're
19 focusing on, you know, 2000 and -- the period
20 you were a Bank One executive.
21 A. Right.
22 Q. Is it your testimony then that
23 to this day you don't believe you ever met
24 Mr. Epstein?
25 A. Yes.

1 Q. And therefore -- well, did you

2 ever have a conversation with him on the
3 telephone?
4 A. No.
5 (Discussion off the record.)
6 Q. I would like to focus you, sir,
7 on the transaction known as Highbridge.
8 Do you remember what year that
9 arose?
10 A. I don't recall the specific
11 year, no.
12 Q. Well, what is Highbridge?
13 A. It was a hedge fund. A money
14 manager.
15 Q. And how was it it came to be
16 acquired by the bank?
17 A. Jes Staley was running asset
18 management, and he brought it to our
19 attention. He wanted to acquire it.
20 Q. And a decision was made to
21 acquire it?
22 A. After review, yes.
23 Q. And what was it -- did it turn
24 out to be a good decision, productive for the
25 bank?

1 A. Not really.
2 Q. Was Jeffrey Epstein involved in
3 the transaction at all?
4 A. I don't recall any involvement
5 on his part. Back then.
6 Q. Were you informed that Jeffrey
7 Epstein received a $15 million fee for his
8 work in connection with that transaction?
9 MR. BUTTS: Again, at the time?
10 MR. SULLIVAN: Yes, at the
11 time.
12 THE WITNESS: No.
14 Q. And I don't mean by -- paid by
15 the bank. Paid by --
16 A. No.
17 Q. Have you, sir, at any time
18 spoken with regulators in the UK about
19 Mr. Staley?
20 A. Regulators? I don't believe
21 so.
22 Q. Now, there came a time -- sir,
23 have you spoken to any official of Barclays
24 Bank about Jes Staley?
25 A. Yes.

1 Q. And who would that be?

2 A. John McFarlane.
3 Q. And when did the conversation
4 occur?
5 A. It was right before they hired
6 Jes.
7 Q. And what was the nature of the
8 conversation?
9 A. It was very short, and he -- I
10 think he was required to check, and he wanted
11 to know if I knew of any reason that Jes --
12 and he had -- he used a more specific term
13 than that, that Jes shouldn't be the CEO of
14 Barclays.
15 Q. And I assume you gave him a
16 good recommendation?
17 A. Nope. I gave a one answer --
18 one answer to that. I said no.
19 Q. It was a true answer?
20 A. I thought so at the time.
21 Q. Yes.
22 In fact, you were -- you spoke
23 very highly of Jes Staley at the time he left
24 the bank.
25 Am I correct?

1 A. That's a very vague question.

2 I don't know if that's true.
5 Q. Maybe I should say not spoke,
6 but wrote very complimentary things about
7 him.
8 Do you recall that?
9 MR. BUTTS: Same objection.
10 You may answer.
12 what I wrote about him when he left
13 the firm.
15 Q. Do you recall that you sent a
16 message about Mr. Staley to employees dated
17 January 8, 2013, in which you indicated he
18 had been an extraordinary leader?
19 A. I -- I'll take your word for
20 it.
21 Q. Well, is it inconsistent with
22 your memory?
23 A. Absolutely.
24 Q. It is?
25 A. Yes.

1 Q. It's inconsistent with your

2 memory?
3 A. Yes.
4 Q. You don't think you said that?
5 A. No, I'm taking your word that I
6 wrote that down somewhere.
7 Q. Okay. I'm sorry. I think we
8 may have a word problem there. Let me start
9 again.
10 Is it consistent with your
11 memory that you wrote that Jes Staley has
12 been an extraordinary leader?
13 A. I don't remember that.
14 Q. Yes.
15 A. I'll take your word for it.
16 Q. Do you recall that you
17 indicated he was a valued partner for many of
18 us at JPMorgan?
19 MR. BUTTS: Do you re --
20 indicated that in the same writing?
21 THE WITNESS: You're reading to
22 me a press release? I mean...
24 Q. I'm just asking what you
25 recall. I have the writing.

1 A. Do I recall what the press

2 release said?
3 Q. Do you recall what you said,
4 yeah.
5 A. I do not recall specifically
6 what I said.
7 Q. Do you recall that you said
8 words to the effect that he has served with
9 distinction?
10 A. Not specifically, but I'm sure
11 I said something semi-nice.
12 Q. Jes Staley was promoted several
13 times by you over the years.
14 Am I right?
15 A. I recall one time, but go --
16 yes.
17 Q. And certainly you praised him
18 before the board.
19 Am I correct?
20 A. At what time period?
21 Q. During the time he was a direct
22 report to you.
23 A. There was a time when he was a
24 direct report to me that I praised him to the
25 board.

1 Q. What was the reason you asked

2 Jes Staley to leave the bank?
3 A. I thought he was not doing a
4 good job running the investment bank.
5 Q. Did your decision --
6 A. And so did my board.
7 Q. Did your decision have anything
8 to do with Epstein?
9 A. No.
10 Q. Now, recently you have made
11 statements to the media, CNN and to
12 Bloomberg, indicating you have some of the
13 best lawyers in the world in compliance, and
14 you take those kinds of people out of the
15 Justice Department and out of the security --
16 the SEC.
17 Am I right?
18 A. Yes.
19 Q. And you indicated recently that
20 those are important functions in the bank.
21 Am I right?
22 A. Yes.
23 Q. When you made that statement,
24 were you referring to Mr. Cutler, for
25 example, who'd been a high-ranking official

1 at the SEC?
2 A. Absolutely.
3 Q. Who else did you have in mind
4 when you praised the expertise and the
5 experience of the persons in those important
6 roles?
7 A. Back then, I don't recall the
8 other names of people there, but we did hire
9 some of the best people out of the DOJ, SEC
10 enforcement, anti-money laundering experts.
11 We wanted to have the best.
12 Q. And how long has that been the
13 practice?
14 A. Since I got to the company.
15 Q. Okay. Certainly in 2000 --
16 A. To the best of our ability.
17 Q. Yes.
18 That certainly applies in the
19 years 2006 through 2013, correct?
20 A. Yep. They may not all have
21 been perfect, but, yes.
22 Q. But that was your mission and
23 your goal?
24 A. Yes.
25 Q. And what did you expect of your

1 compliance people specifically when you

2 brought them in having distinguished
3 government backgrounds?
5 You may answer.
6 THE WITNESS: That they would
7 set up the proper programs and
8 reviews, use their best judgment when
9 they weigh and measure some of these
10 complex issues. That's what I
11 expected from them.
13 Q. Did you expect -- well, strike
14 that.
15 I gather it's fair to say that
16 as the CEO you certainly relied upon them to
17 do their jobs, correct?
18 A. Yes.
19 Q. And you -- despite the fact you
20 knew nothing about the Epstein matter, you
21 relied upon them to make sure that compliance
22 was functioning properly through the years
23 2006 through 2013, correct?
24 A. There -- yes, though there were
25 reviews of the function periodically.

1 Q. Is there some other star among

2 those personnel other than Steve Cutler?
4 You may answer if you're able.
5 THE WITNESS: What years are
6 you referring to?
8 Q. I'm focusing on 2006 to 2013.
9 A. I recall William Langford being
10 quite respected.
11 Was Jay Balacek there at the
12 time? I can't remember when he joined the
13 company.
14 Stacey, whenever you joined the
15 company. Yes.
16 Q. Can't put in a plug for people
17 here.
18 A. I hope you-all like the fact
19 that I like good lawyers.
20 Q. Yeah.
21 A. And need good lawyers.
22 Q. Did Mr. Cutler make periodic
23 reports to the board about compliance on a
24 regular basis?

1 You may answer.

2 THE WITNESS: In general, yes.
4 Q. And your recollection is during
5 2006 through 2013, he would have never made a
6 report about the work the bank did or had
7 undertaken with respect to the --
8 Mr. Epstein.
9 Is that correct?
10 A. I don't recall anything
11 relating to Mr. Epstein.
12 Q. And while we focused on years
13 2006 to 2013, I believe in the course of the
14 litigation you have authorized your lawyers
15 to file an answer to an interrogatory which
16 essentially says that during the period 2000
17 through 2018, that's 18 years, you received
18 no information from any officer, director,
19 employee or agent of the bank, any
20 information about Jeffrey Epstein.
21 Is that a fair statement?
23 Objection.
24 You may answer.
25 THE WITNESS: That is what I

1 recall, and I believe that's what your

2 document review showed.
4 Q. Sir, what do you understand by
5 the term "reputational risk assessment"?
6 A. It means different things at
7 different parts of the company, but in
8 general, are we -- it's a judgment call about
9 whether doing business with someone creates
10 reputational risk to the company.
11 Q. And is there a separate section
12 or division within compliance that is called
13 a reputational risk group?
14 A. I don't know. I don't know if
15 it's a special group or it's just part of a
16 review of people.
17 Q. Does it tend to come under
18 compliance, or is it associated with
19 compliance?
21 You may answer.
22 THE WITNESS: I think
23 compliance is part of it.
25 Q. You testified that you don't

1 recall any reputational review.

2 Have you ever heard of a
3 reputational risk meeting?
4 A. Not specifically called that,
5 no.
6 Q. Do you know whether in 2011
7 there was such a meeting and a report written
8 by persons participating in an assessment of
9 the Epstein banking relationship?
11 You may answer.
12 THE WITNESS: I didn't know
13 then, no.
15 Q. As the head of the bank, sir,
16 were you familiar with an action by the SEC
17 in which the bank settled SE charges of
18 misleading investors tied to the housing
19 market in the year 2011?
20 A. Not specifically, but I do know
21 there were things like that, yes.
22 Q. Did you recall that JPMorgan
23 paid approximately $153 million to resolve
24 those claims about misleading investors?

1 dollar amount, the specific claims, but I do

2 recall a settlement like that.
3 Q. As CEO do you recall an action
4 by the Department of Justice in July 2011 in
5 which JPMorgan admits to anticompetitive
6 conduct and ended up paying $228 million --
9 Q. -- to federal and state
10 agencies?
11 A. I don't re --
12 MR. BUTTS: I'm sorry.
13 Objection.
14 You may answer.
16 the specific one, no.
18 Q. Do you recall generally that
19 there was an action taken against the bank?
21 You may answer.
22 THE WITNESS: Not that one.
23 I'm not denying it; just don't
24 remember it.
25


2 Q. Do you recall in about February
3 of 2012 that there was another Department of
4 Justice action taken in which the bank paid
5 $5 billion? That was the one in which the
6 government state Attorney Generals reached a
7 settlement in the mortgage services industry.
9 You may answer.
11 the specific time, but I do remember
12 such a settlement.
14 Q. Do you recall, for example, in
15 November of 2012 that the SEC charged
16 JPMorgan with misleading investors with
17 respect to mortgage -- mortgage portfolio?
19 You may answer.
21 the specific thing you're talking
22 about.
24 Q. Do you recall that JPMorgan
25 agreed to paid 296 million to settle the

1 SEC's charges in or about May of 2012?

3 You may answer.
5 the specific charge or the specific
6 date.
8 Q. Do you --
9 A. But I'm not denying that.
10 Q. Right.
11 Do you recall generally that
12 the bank was embroiled in the controversy and
13 resolved it?
15 You may answer.
16 MR. SULLIVAN: He answered, did
17 you say?
18 MR. BUTTS: No. I said,
19 objection, you may answer.
21 like the word "embroiled," but, yes.
23 Q. Do you recall that in September
24 of 2013, JPMorgan agreed to pay $200 million
25 and admitted wrongdoing to settle SEC charges

1 then pending?
3 You may answer.
4 THE WITNESS: I don't recall --
5 MR. SULLIVAN: What's the
6 objection?
7 MR. BUTTS: Relevance.
9 the specific thing that you're talking
10 about.
12 Q. You don't recall anything about
13 that one?
14 That's the one in which the
15 bank admitted facts underlying the charges
16 and knowledge that it violated the federal
17 securities laws?
19 You may answer.
21 the specific case.
23 Q. Do you recall generally that
24 that case was resolved?
25 A. Yes.


2 You may answer.
4 Q. Do you recall that in or around
5 November '13 there was an additional action
6 by the Department of Justice, along with
7 state partners, that announced a $13 billion
8 settlement with JPMorgan in which that was
9 the largest settlement of a single entity in
10 American history to resolve federal and state
11 claims arising out of packaging, marketing,
12 sale and insurance of residential
13 mortgage-backed securities?
16 You may answer.
17 THE WITNESS: Yes, but I'll add
18 it was on behalf of JPMorgan, Bear
19 Stearns and Washington Mutual.
21 Q. Okay. Do you recall that in
22 January '14 JPMorgan admitted violations of
23 the Bank Secrecy Act and was fined
24 $461 million?

1 You may answer.

3 the specific, but...
5 Q. Do you remember generally that
6 that occurred and --
7 A. Yes.
8 Q. -- and the bank resolved it?
10 You may answer.
12 MR. SULLIVAN: Objection what?
13 You may answer.
14 You say it so fast, I don't
15 hear it all.
16 MR. BUTTS: I'm trying to not
17 disturb you, Brendan.
19 Q. Do you recall that the
20 Commodities Future Trading Commission ordered
21 five banks, including yours, to pay over
22 1.4 billion in penalties for manipulation of
23 foreign exchange and benchmark rates?
25 You may answer.


3 Q. And JPMorgan paid 290 million
4 there?
6 You may answer.
8 the number.
10 Q. Roughly?
12 You may answer.
13 THE WITNESS: I don't remember.
15 Q. Do you recall that in May of
16 '15, again a Department of Justice action, in
17 which JPMorgan paid $550 million fine? Do
18 you recall that matter?
21 Q. And here you were charged with
22 conspiring to manipulate the price of US
23 dollars and euros, exchange in foreign
24 currency, spot market?


2 Q. Do you recall that?
4 You may answer.
5 THE WITNESS: I'll take your
6 word for it, yes.
8 Q. Well, I mean, you just -- this
9 is only in '15, right?
11 You may answer.
13 the specific -- or the specific date.
15 Q. Okay. Do you recall that in or
16 about December '15 the Securities and
17 Exchange Commission brought charges -- and
18 you settled that one for 260 million -- 267
19 million for disclosure failures?
21 You may answer.
23 that.
24 MR. BUTTS: He gave you an
25 answer.


2 Q. Do you recall the Securities
3 and Exchange Commission issued an order in --
4 ordering the bank to cease and desist with
5 respect to JPMorgan's failure to devise and
6 maintain a system of internal accounting and
7 controls around its hiring practices?
9 You may answer.
12 Q. And in connection with that,
13 the SEC found violations of the antibribery,
14 books and records and internal controls
15 provision of the Foreign Corrupt Payments Act
16 {sic}?
19 You may answer.
22 Q. Do you recall that in December
23 of '18 there was a further order from the
24 Securities Exchange Commission in which the
25 bank paid $135 million?


2 You may answer.
4 that specific thing.
6 Q. Do you recall that the bank
7 entered into a deferred prosecution agreement
8 in which $920 million was paid?
10 You may answer.
13 Q. And that was when the
14 government charged the company with a
15 two-count criminal information alleging wire
16 fraud?
18 You may answer.
20 those specifics, but I do recall that.
22 Q. And do you recall also that the
23 underlying offense was -- involved tens of
24 thousands of instances of unlawful trading in
25 gold, silver, platinum, futures contracts?


3 You may answer.
6 Q. And do you recall that the
7 company was penalized because it had a prior
8 criminal history, including a guilty plea on
9 May 20, 2015, for similar conduct involving
10 manipulative and deceptive trading practices
11 in the foreign currency exchange market?
13 You may answer.
15 the specific thing you're talking
16 about, no.
18 Q. This would be paid $920 million
19 to resolve it.
21 You may answer.
22 THE WITNESS: It sounds like
23 the same one from before, but, yes.
25 Q. Do you know -- do you know what

1 a deferred prosecution agreement is?

3 You may answer.
6 Q. And that means that you
7 essentially plead guilty, but they don't do
8 anything except take your money for a number
9 of years. But if you do it again, it's
10 more -- they can prosecute you for the
11 original matter.
12 Do you understand that?
14 You may answer.
15 THE WITNESS: I'm not a lawyer,
16 but generally I understand it that
17 way, yes.
19 Q. Most of us lawyers don't
20 understand it. It's what it is.
21 MR. SULLIVAN: Thank you, sir.
22 That's all I have.
23 MR. BUTTS: Thank you.
24 MR. SULLIVAN: Have a good day.
25 Nice holiday. I have to go. I have a

1 trial Monday. Take care.

2 MR. BUTTS: Sounds like no
3 holiday for you.
4 MS. FRIEDMAN: Should we take a
5 break?
6 MR. BUTTS: Yeah, let's do.
7 VIDEOGRAPHER: We're going off
8 record. The time is 10:30.
9 (Off the record at 10:30 a.m.)
10 VIDEOGRAPHER: We're going back
11 on record. The time is 10:39.
13 QUESTIONS BY MS. SINGER:
14 Q. Good morning, Mr. Dimon. My
15 name is Linda Singer. I would like to say I
16 bring down the average age of the examiners
17 on our side, but I don't know that that's
18 true, actually, so I'm going to skip that.
19 I don't think we did this at
20 the outset, so could you state your position
21 for the record, please?
22 A. I am chairman and chief
23 executive officer of JPMorgan Chase.
24 Q. And where generally do you
25 reside?

1 A. New York City.

2 Q. And do you have any plans of
3 moving your residence between now and
4 November of 2023?
5 A. No.
6 Q. When did you first learn that
7 Jeffrey Epstein was a customer of JPMorgan?
8 A. I don't recall knowing anything
9 about Jeffrey Epstein until the stories broke
10 sometime in 2019. And I was surprised that I
11 didn't even -- had never even heard of the
12 guy, pretty much, and how involved he was
13 with so many people.
14 Q. Were you aware that Jeffrey
15 Epstein was promoting you to contacts as a
16 candidate for Secretary of the Treasury?
18 You may answer.
19 THE WITNESS: Nope.
21 Q. Were you aware that JPMorgan
22 entered into a settlement or settlements with
23 Jeffrey Epstein?
24 A. Not until recently, no.
25 Q. When did you learn that?

1 A. I think as part of this case.

2 Q. Okay. So as part of your
3 preparation for this deposition or at some
4 other time?
5 A. No, it was part of preparation
6 for this deposition.
7 (Dimon Exhibit 15 marked for
8 identification.)
10 Q. We want to play a clip from an
11 interview that you did recently on CNN.
12 Hopefully, that will work.
13 (Video played.)
14 Q. All right. Mr. Dimon, does
15 that segment from CNN accurately reflect what
16 you said during the interview with Poppy
17 Harlin {sic}?
18 MS. FRIEDMAN: Harlow.
19 THE WITNESS: You know, there
20 was a teeny piece of the interview,
21 but, yes.
23 Q. Okay.
24 A. That piece was accurate, I
25 think.

1 Q. And what did you rely on to

2 state that JPMorgan did not have
3 contemporaneous knowledge of Epstein's
4 offenses?
6 THE WITNESS: I didn't say
7 that.
9 Q. Okay. You did say hindsight is
10 fabulous, correct?
11 A. I did.
12 Q. Okay. So prior to your
13 interview, what information did you have
14 about what JPMorgan knew or didn't know about
15 Jeffrey Epstein and JPMorgan's handling of
16 his accounts?
17 MR. BUTTS: Objection. And
18 I'll instruct you not to answer to the
19 extent that any knowledge comes from
20 counsel.
21 THE WITNESS: I knew very
22 little about any of this until this
23 case was opened. And then of course
24 I've learned quite a bit since then.
25


2 Q. Okay. So in making your
3 comment that hindsight is fabulous, what
4 information had you reviewed about what
5 JPMorgan knew or didn't know about its
6 handling of Jeffrey Epstein's business?
8 And the same caution, you
9 should not reveal any information you
10 reviewed in the context of discussions
11 with counsel.
12 THE WITNESS: Well, I mean,
13 almost all of it was done in
14 consultation with counsel.
15 MR. BUTTS: Then you can't
16 answer the question.
17 THE WITNESS: Okay.
19 Q. Other than conversations with
20 your lawyers, which I never mean for you to
21 reveal, nor would Mr. Butts allow you, did
22 you have any knowledge of what JPMorgan had
23 done or knew about Jeffrey Epstein prior to
24 your interview with CNN?

1 You may answer.

3 the specific knowledge I had before I
4 sat down with counsel relating to
5 these lawsuits.
7 Q. And --
8 A. And that was after I sat down
9 with counsel.
10 MR. BUTTS: The interview was
11 after --
12 THE WITNESS: The interview was
13 after I spent considerable time with
14 counsel.
16 Q. And apart from your preparation
17 in connection with this litigation, how much
18 time have you spent personally looking at the
19 bank's conduct with respect to Jeffrey
20 Epstein?
22 THE WITNESS: Before these
23 lawsuits and the time with counsel,
24 very little.
25


2 Q. Could you give me a rough sense
3 of how much time we're talking about?
4 A. I can't.
5 Q. Is it less than a full day?
6 A. Probably, yes.
7 Q. Less than an hour?
8 A. I don't recall the specifics.
9 Q. Now, JPMorgan continued to bank
10 Jeffrey Epstein for about seven years after
11 he was indicted for child sex offenses.
12 Correct?
14 THE WITNESS: Indicted or
15 pleaded guilty. But after he pleaded
16 guilty to the crime he pleaded guilty
17 to, he -- we unfortunately continued
18 to bank him, yes.
20 Q. Okay. Have you, in preparation
21 for this deposition or litigation or
22 otherwise, determined how many payments
23 JPMorgan made to young women and girls from
24 Jeffrey Epstein during the period you
25 provided banking services to him?

1 MR. BUTTS: I'm sorry, could

2 you give me a moment?
3 Objection.
4 And you should not reveal
5 anything that you learned about --
6 with discussion -- through discussions
7 with counsel.
8 THE WITNESS: It was all
9 through discussions with counsel.
11 Q. So apart from your discussions
12 with counsel, you've made -- you've
13 undertaken no review, nor have you been
14 informed, about how much money JPMorgan
15 transferred to women or girls from Jeffrey
16 Epstein.
18 You may answer.
20 Q. Correct?
21 A. When you say, you did not do a
22 review, that review was done. And it was
23 asked to be done, partially by me, to make
24 sure we're doing the right things, and
25 counsel took it from there.

1 Q. Okay. And that review that you

2 just referenced in your answer, was that done
3 in connection with this litigation?
4 A. I would have to defer to my
5 counsel about when that actually started.
6 MR. BUTTS: Either way, it's a
7 yes or no, and that's it.
8 THE WITNESS: It was with my
9 internal counsel, yeah.
11 Q. Okay. So is that a yes or a
12 no?
13 A. Can you repeat the question?
14 Q. Yes.
15 The review that you referenced
16 in your prior answer about the bank's
17 handling of money for Jeffrey Epstein and his
18 payments to women, was that review conducted
19 exclusively in connection with this
20 litigation or apart from this litigation?
21 MR. BUTTS: And objection.
22 You may answer the question yes
23 or no.
24 THE WITNESS: I don't know.
25


2 Q. Do you have any recollection of
3 conducting or being briefed on a review of
4 JPMorgan's handling of Jeffrey Epstein's
5 accounts prior to this litigation being
6 filed?
7 A. I would have to ask my general
8 counsel when that happened.
9 MR. BUTTS: And the answer --
10 those discussions are off the table,
11 so...
12 THE WITNESS: Okay. Even
13 before the litigation?
14 MR. BUTTS: Yes.
15 THE WITNESS: Uh-huh.
17 Q. So your only discussion about
18 Jeffrey Epstein and the bank's handling of
19 Jeffrey Epstein's account were conversations
20 with counsel inside or outside JPMorgan.
21 Is that correct?
23 yes.
24 Q. Have you ever, outside of your
25 conversations with counsel inside or outside

1 of JPMorgan, ever looked at or been informed

2 about how much cash Jeffrey Epstein took from
3 his accounts at JPMorgan?
4 A. No. Not that I recall.
5 Q. How much time, Mr. Dimon, did
6 you spend preparing for this deposition?
7 MR. BUTTS: Yeah, you may
8 answer that question. It's a
9 numerical --
10 THE WITNESS: Yeah, I'm just
11 saying, five hours? Seven hours?
13 Q. And did you prepare with
14 lawyers at WilmerHale?
15 A. Yes.
16 Q. And did you also prepare with
17 counsel inside JPMorgan Chase?
18 A. Yes.
19 Q. Was anybody else involved in
20 your preparation for this deposition other
21 than your counsel inside and outside JPMorgan
22 Chase?
23 A. I don't believe so, no.
24 Q. Have you received any talking
25 points from your communications staff at

1 JPMorgan for addressing questions regarding

2 Jeffrey Epstein and JPMorgan's handling of
3 Jeffrey Epstein's relationship?
5 You may answer.
6 THE WITNESS: Yes.
8 Q. And when did you receive those
9 talking points for guidance?
10 A. Periodically over the last six
11 months, I think.
12 Q. Was that guidance or -- were
13 those talking points in writing or were they
14 conveyed to you verbally?
16 You may answer it yes or no.
17 Excuse me. You may answer in
18 writing or verbally.
19 THE WITNESS: Yeah.
20 MS. SINGER: That would have
21 been impressive, but not very helpful.
22 MR. BUTTS: Yeah, yeah, yeah.
23 THE WITNESS: A little of both.
24 Some from my general counsel.
25 MR. BUTTS: Yeah. And so to

1 the extent your general counsel is

2 involved with discussions with others,
3 that is still a privileged
4 conversation --
6 MR. BUTTS: -- that will not be
7 revealed.
9 Q. Okay. So I want to make sure
10 we have a clear record --
11 MR. BUTTS: Sure.
13 Q. -- and answer on this.
14 So did you receive written
15 guidance from communications employees at
16 JPMorgan or outside communications firms
17 about how to respond to questions about
18 Jeffrey Epstein and the bank's handling of
19 Jeffrey Epstein's relationship?
21 You may answer yes or no.
24 Q. And do you recall roughly when
25 you received that guidance?

1 A. Sometime over the last several

2 months.
3 Q. So turning from the CNN
4 interview clip that we played and the
5 "hindsight" comment, I want to turn to some
6 questions about what JPMorgan -- what
7 information JPMorgan had and what it did
8 prior to its termination of Jeffrey Epstein.
9 And before I do that, I
10 actually want to return to a question that
11 Mr. Sullivan asked you. He asked you what
12 you like -- what newspapers you read. And I
13 think you indicated that you read The New
14 York Times.
15 Is that right?
16 A. Yes.
17 Q. And you said you don't read The
18 New York Post?
19 A. I said I didn't get it back
20 then.
21 Q. Okay. When did you start --
22 A. And I didn't read it back then
23 either.
24 Q. When did you -- when did you
25 start reading The New York Post?

1 A. I don't really read The

2 New York Post. I do get it. Now I get it.
3 Q. Do you recall whether you were
4 reading The New York Post prior to 2013?
6 You may answer.
7 THE WITNESS: I don't believe I
8 got it prior to 2013.
10 Q. Do you believe you read it
11 prior to 2013?
13 You may answer.
14 THE WITNESS: Almost never.
15 Unless someone sent me something.
17 Q. And prior to 2013, you were
18 reading The New York Times, correct?
20 You may answer.
21 THE WITNESS: The New York
22 Times, The Financial Times, The
23 Washington Post.
25 Q. Not The Wall Street Journal?

1 A. And The Wall Street Journal,

2 yes.
3 Q. But it's your testimony that
4 you did not read any of those newspapers'
5 coverage of Jeffrey Epstein related to his
6 arrest or guilty plea.
7 Is that right?
8 A. I -- what I said is I don't
9 recall reading any of those stories. That is
10 right, yes.
11 Q. Okay. Or any other stories
12 related to Jeffrey Epstein prior to 2013.
13 Is that right?
14 A. Yes. To the best of my
15 recollection, yes.
17 identification.)
19 Q. So we're going to start our
20 heaving of the exhibits. We're going to
21 start with what we'll mark as Exhibit
22 Number 1.
23 We will also put them up on the
24 screen, so whichever way you prefer to look
25 at them.

1 So I'm showing you what we've

2 marked as Exhibit Number 1, which for the
3 record is JPM-SDNYLIT-00000314, which is a
4 September 5, 2006 e-mail.
5 Do you see that, Mr. Dimon?
6 A. Yes.
7 Q. Okay. Do you recognize the
8 name Philip Schlakman?
9 A. No.
10 Q. I think you mentioned Mary
11 Casey in your previous examination.
12 Is that a name that's familiar
13 to you?
14 A. I didn't mention her. Brendan
15 mentioned here.
16 Q. Okay. Mary Erdoes, that's a
17 name that's familiar to you, correct?
18 A. Yes. Yes.
19 Q. Okay. And this e-mail subject
20 line is Epstein news.
21 Correct?
22 A. Yes.
23 Q. And the first line says, "Did
24 you see this article in the NYT this weekend?
25 Lovely guy to work with."

1 Have I read that correctly?

2 A. Yes.
3 Q. And then the e-mail circulates
4 an article from The New York Times.
5 Is that right?
6 A. Yes.
7 Q. And the article is titled
8 "Questions of Preferential Treatment Are
9 Raised in Sex Case Against Money Manager."
10 Is that right?
11 A. Yes.
12 Q. Okay. And by the way, this an
13 e-mail among various employees at JPMorgan
14 Chase, is it not?
15 A. Yes.
16 Q. Okay. So I want to read a
17 little bit from this article. We'll start in
18 the middle of the first page. And it says,
19 "In sworn statements to the police" -- do you
20 see where I'm?
21 A. Yes.
22 Q. "In sworn statements to the
23 police, the 14-year-old and other teenage
24 girls said a friend had arranged for them to
25 visit Mr. Epstein's home and give him

1 massages, usually in their underwear, in

2 exchange for cash."
4 A. Yes.
5 Q. "Most of the girls, according
6 to police, said Mr. Epstein had masturbated
7 during the massages, and a few said he had
8 penetrated them with his fingers or penis.
9 They identified him in photos and accurately
10 described the inside of his home."
11 Have I also read that
12 correctly?
13 A. Yes.
14 Q. And these were the facts that
15 were -- this was the information that was
16 reported in The New York Times and circulated
17 by JPMorgan employees in 2006, right?
19 You may answer.
22 Q. And if we turn to the next
23 page, going about two-thirds of the way down,
24 you'll see the third paragraph in the bottom
25 says, "The girl, the report said."

1 Do you see where I am?

2 A. The next page, not two-thirds.
3 Q. Yep. Third paragraph from the
4 bottom.
5 A. Yes.
6 Q. Okay. In the middle of that
7 paragraph it says -- I'm sorry, I'll start at
8 the beginning.
9 "The girl, the report said,
10 told the police that an older friend had
11 offered her an opportunity to make money and
12 had driven her to Mr. Epstein's house one
13 Sunday. The friend, identified by the police
14 as , a local community college
15 student, told the girl to say she was 18 if
16 Mr. Epstein asked."
18 A. I think so, yes.
19 Q. Okay. And then at the bottom
20 of the page it says, "In October the police
21 interviewed Ms. , then 19, who told
22 them Mr. Epstein had routinely paid her to
23 bring teenage girls to his home. The police
24 then interviewed a total of five alleged
25 victims and 17 witnesses, many of whom told

1 similar stories about what they had observed

2 or participated in at Mr. Epstein's home.
3 According to the report, at least one said
4 Mr. Epstein had engaged in intercourse with
5 her."
7 correctly?
8 A. Yes.
9 Q. Were you aware that according
10 to documents produced by JPMorgan
11 was a client of the bank who the bank
12 terminated in 2019?
14 You may answer.
15 THE WITNESS: No.
17 Q. No, you were not aware of that?
18 A. Repeat the question.
19 Q. Yes. Long question.
20 Were you aware that
21 was a client of JPMorgan?
23 You may answer.
24 THE WITNESS: No.
25


2 Q. Okay. The article in the
3 middle of page 2. If we see the paragraph,
4 "Neither the police nor the state's attorney
5 office" --
7 A. Yes.
8 Q. Okay.
9 -- "would discuss the case in
10 detail, but the police released a thick
11 report on the 13-month investigation after
12 the indictment was unsealed in late July."
13 A. Yes.
14 Q. Are you aware of the report
15 that was released by the police in 2006 --
16 MR. BUTTS: And I --
18 Q. -- related to Jeffrey Epstein?
19 MR. BUTTS: I'll give you a
20 general instruction that none of
21 Ms. Singer's questions relate to
22 anything that you've learned of
23 through counsel, so it's prior to
24 counsel or through something else.
25 THE WITNESS: I did not know at

1 the time.
3 Q. Okay. And have you learned
4 about it since?
5 A. Generally, yes.
6 (Langford Exhibit 15
7 introduced.)
9 Q. Okay. All right. We're going
10 to mark as Exhibit 2 {sic} the probable cause
11 affidavit, which I'll represent that we
12 pulled from the Internet where it was posted
13 on July 25, 2006, by ABC News and other
14 sources.
15 It is exhibit -- I'm sorry,
16 we're going -- it's Langford Exhibit
17 Number 15, and it's titled "Probable Cause
18 Affidavit" for the Palm Beach Police
19 Department.
20 Other than your preparation for
21 this case for this deposition in this
22 litigation, have you previously seen that
23 probable cause affidavit?
24 A. No.
25 Q. Did you review that probable

1 cause affidavit before testifying this

2 morning?
3 MR. BUTTS: You -- okay. Go
4 ahead.
6 this specific thing, but I reviewed
7 other documents with counsel.
9 Q. Okay. So the contents of this
10 are quite graphic and awful, and I'm not
11 going to go through the details, but I want
12 to ask you whether the information in the
13 probable cause affidavit in 2006 would have
14 been relevant, in your view, to JPMorgan in
15 assessing its relationship with Jeffrey
16 Epstein.
18 You may answer.
19 THE WITNESS: I would hope that
20 our top professionals, you know,
21 looking at all the facts of the case,
22 look at what they think is the
23 appropriate thing to look at.
24 I'm not a legal expert, and I
25 don't know specifically what they

1 looked at, what they didn't look at.

3 Q. Okay. But do you think it
4 would have been useful and appropriate, or
5 useful or appropriate, for your compliance
6 team to have looked at this?
8 You may answer.
9 THE WITNESS: Among all the
10 things we know today, yes. I don't
11 know if they did or they didn't.
13 Q. And I am not asking you if they
14 did or they didn't, but whether you would
15 hope that they would have looked at this kind
16 of information.
17 A. In hindsight, with knowing all
18 I know, I would have hoped, yes.
20 identification.)
22 Q. So we're going to go through a
23 slide to avoid going through this document in
24 detail. So can you see that on your screen,
25 Mr. Dimon?

1 And we can hand out what we'll

2 mark as Exhibit 3 {sic} for the record. And
3 let me know when you've read it and are able
4 to --
5 MR. BUTTS: Do you prefer to
6 see that in paper? It sounds like
7 they have a slide.
8 THE WITNESS: It's okay.
9 MS. SINGER: Let's mark it as
10 an exhibit, please.
11 MR. BUTTS: Obviously, we
12 haven't had time to go back and track
13 the exhibit to your demonstrative,
14 so --
15 MS. SINGER: Understood.
16 MR. BUTTS: But that's a
17 separate issue.
18 MS. SINGER: And if you-all
19 find anything that we've gotten wrong,
20 you will let us know before this is
21 final. But let's go through it, and
22 we have page citations on the slide.
24 Q. But the probable cause
25 affidavit indicates that victim, name

1 redacted, was paid $300 in cash from Epstein

2 that told victim that she would -- she
3 received $200 that day for bringing her.
5 A. Yes.
6 Q. And then it says, "After the
7 massage, Epstein stated to that he
8 understood she was not comfortable, but he
9 would pay her if she brought over some girls.
10 He told her the younger, the better.
11 stated she once tried to bring a 23-year-old
12 female, and Epstein stated that the female
13 was too old. stated that in total she
14 only remembers six girls that she brought to
15 see Epstein. Each time she was paid $200.
16 said that at the time she brought
17 these girls to Epstein's house, they were all
18 14 through 16 years of age."
20 A. Yes.
21 Q. It indicates that at the
22 conclusion of a shower, a girl was paid
23 either 350 or $400; that another was paid
24 $200 for a massage; and that one of the
25 victims began going to the house when she was

1 16 years of age and had been there a lot more

2 times to provide massages over the past two
3 years.
4 Have I recounted all of that
5 correctly?
7 Q. Fair enough.
8 And "Alessi," who I'll
9 represent is one of Epstein's employees,
10 "stated that Epstein received three massages
11 a day."
12 Is that also correct from the
13 slide?
14 A. Yes.
15 Q. Okay. Are those -- actually,
16 let's keep going through it.
17 On the second slide --
18 MR. BUTTS: This is page 2 of
19 the document.
21 Q. Okay. Also in Exhibit 3, it
22 indicates that "Epstein would photograph
23 and her naked and having sex and
24 proudly display the photographs within the
25 home."

1 Refers to " bringing girls

2 upstairs into a master bathroom -- a
3 bathroom, where Epstein subsequently paid her
4 $300 for a massage; that she was notified by
5 that Epstein was in town and
6 would ask her to work."
7 Have I read those two bullets
8 roughly accurately?
9 A. Yes.
10 Q. "Epstein told her that if she
11 told anyone what happened at his house, that
12 bad things could happen." And she "wanted to
13 notify authorities; however, she was afraid
14 of what would happen to either her or her
15 family."
16 Have I also read that roughly
17 correctly?
18 A. Yes.
19 Q. Another girl says, "She met
20 Epstein when she was 15 years of age," when
21 she was approached by a friend from the Royal
22 Palm Beach High School. "She was originally
23 told that she would be able to model lingerie
24 for a wealthy Palm Beacher."
25 Also roughly accurate, correct?

1 As I've read it. I'm not asking you to

2 attest to the facts.
3 A. Yes.
4 Q. And finally that "analysis of
5 these records" -- that's referring to phone
6 message -- cell phone records -- "was
7 conducted and found numerous telephone calls
8 were made between and the
9 victims."
11 correctly?
12 A. Roughly, yes.
13 Q. Would the fact regarding the
14 use of cash by Epstein to pay for three
15 massages a day been relevant to JPMorgan in
16 monitoring, reporting and deciding whether to
17 keep Epstein's accounts?
19 You may answer.
20 THE WITNESS: I don't know. I
21 mean, these amounts of money would not
22 have triggered anything as far as I
23 know.
24 In hindsight, of course, you
25 know, you would have looked at --

1 maybe looked at something like that.

3 Q. Okay. But this was information
4 that was available publicly in 2006?
6 MS. SINGER: I'll withdraw
7 that.
9 Q. And you talked about the money
10 not triggering. I am loathed to do math with
11 a banker, but I'm going to do my best.
12 If it's three massages a day at
13 $200 per girl and $200 per recruiter, that's
14 $1,200 a day.
17 Q. Correct?
19 You may answer.
20 THE WITNESS: Yes, if your math
21 is right.
23 Q. The financial system will
24 collapse if you don't get this right, so take
25 a minute.

1 $1,200, 30 days a week {sic} is

2 $36,000 --
5 Q. -- a month, correct?
6 A. Your math might be accurate,
7 yes.
8 Q. Okay. 31 days, $37,200,
9 roughly?
10 A. If. If and if, yes.
11 Q. Okay. Okay. Would the fact
12 that girls felt threatened by Epstein been
13 useful to JPMorgan in evaluating whether they
14 wanted to continue to do business with him?
16 You may answer.
17 THE WITNESS: I don't know what
18 our people saw or reviewed or looked
19 at at the time.
20 And I -- just so you know how
21 much I detest the man and all the
22 things that happened, as does almost
23 everyone at this company.
25 Q. And everyone here would share

1 that.
2 A. Yeah.
3 Q. And I'm not asking what people
4 knew. I'm asking whether this information --
5 whether you as CEO and chairman of JPMorgan
6 Chase believe that this is information that
7 would have been relevant to the bank.
8 A. I would have asked our top
9 legal people and compliance people to do the
10 proper job and look at the things they need
11 to look at to make reputational type of
12 decisions. I don't know if they saw this or
13 not.
14 Q. Okay. And again, I'm not
15 asking if they saw it. I'm asking if this
16 information about girls feeling threatened,
17 about underage girls being paid in cash,
18 whether that's the kind of information that
19 the bank should have been looking at, if
20 available, to make a decision about whether
21 to do business with him.
23 You may answer.
24 THE WITNESS: I would say the
25 same thing. I think if you have -- if

1 I've asked you to review something and

2 do the best job, yes, you should look
3 at what you think is relevant and then
4 weigh and measure the information you
5 have.
7 Q. And in particular, given the
8 bank's financial relationship with
9 Mr. Epstein, would you agree that monitoring
10 his use of cash and -- would be important for
11 the bank to keep abreast of?
13 You may answer.
14 THE WITNESS: I think it would
15 be one of the many things that the
16 group should look at and take into
17 consideration, yes.
19 Q. Was JPMorgan, to your
20 knowledge, aware that Epstein -- that Jeffrey
21 Epstein promised girls careers in modeling or
22 schooling if they cooperated with him?
24 You may answer.
25 THE WITNESS: At the time, I

1 had no knowledge about that. Since

2 we've been doing this, I have
3 knowledge about that. I don't know if
4 it's true or not.
6 Q. Were you aware that
7 , one of the names mentioned in the
8 probable cause affidavit, was a customer of
9 JPMorgan's private bank at Epstein's request?
10 A. Not back then I wasn't, no.
11 Q. Have you learned that
12 subsequently?
13 A. Yes, only as a result of --
14 MR. BUTTS: It's a not
15 through -- no questions today will ask
16 you about anything that you learned
17 from counsel.
18 THE WITNESS: Okay. Okay.
19 Okay. Yeah.
22 received numerous transfers from
23 Jeffrey Epstein's accounts at JPMorgan Chase?
25 You may answer.

1 THE WITNESS: No.

4 , who was also mentioned in the
5 affidavit, was a customer of JPMorgan and
6 received numerous transfers from Jeffrey
7 Epstein's accounts at JPMorgan?
9 THE WITNESS: No. No.
11 Q. Do you know what, if anything,
12 JPMorgan employees did in response to the
13 news of Jeffrey Epstein's indictment and the
14 facts that became public with his indictment?
15 A. Not back then I didn't, no.
16 Q. If one of these girls in the
17 probable cause affidavit was the daughter of
18 an employee of JPMorgan or a customer of
19 JPMorgan, what would you have wanted the bank
20 to do when this information became public?
22 THE WITNESS: You'll have to
23 rephrase that question for me.
25 Q. If one of the girls --

1 A. Wanted? Wished?
2 Q. Yeah. What would you, as CEO
3 of this bank, as a parent, what would you
4 have wanted the bank to do to determine
5 whether it was providing banking services to
6 the person accused of paying cash for
7 nonconsensual sex with minors?
9 You may answer.
10 THE WITNESS: It's a long
11 question.
12 If I knew something like that,
13 I would take the information I have
14 and hand it to my general counsel and
15 ask them to do the proper review.
17 Q. And looking back, what do you
18 think, what do you hope, as the leader of
19 this bank that the bank would have done in
20 response to this information?
22 Asked and answered.
23 THE WITNESS: That they did the
24 proper review based on what they knew.
25


2 Q. And what would the proper
3 review have been based on the information
4 you've seen?
5 A. Well, the review -- this
6 information -- I don't know if they saw that
7 information. The review would have been, you
8 give it to your counsel, they sit down, they
9 get the right people, they review it and
10 other alle -- and these are still
11 allegations, and decide what is the right
12 thing to do.
13 Q. And that would be your
14 expectation, a thorough, diligent review, and
15 doing the right thing with that information?
16 A. Yes.
17 Q. If at the time the general
18 counsel -- "at the time," I mean 2006, after
19 Jeffrey Epstein was indicted -- had decided
20 that Jeffrey Epstein should have been
21 terminated as a customer of the bank, what
22 would have happened?
23 A. You're asking me to guess, but
24 he -- if my general counsel had wanted to
25 terminate someone, he would have been

1 terminated.
3 identification.)
5 Q. Okay. Let's turn to what we'll
6 mark as Exhibit Number 4 {sic}. For the
7 record, it's JPM-SDNYLIT-00269651.
8 All right. And this is an
9 e-mail dated October 23, 2007, between James
10 Dalessio and Bonnie Perry, both at JPMorgan.
11 Is that correct?
12 A. That's what it says.
13 Q. Okay. Do you recognize either
14 of those names, Mr. Dimon?
15 A. No.
16 Q. Okay. And the subject is
17 Epstein -- Forward: Epstein, correct?
18 A. Yes.
19 Q. Okay. And in it, Jim Dalessio
20 indicates to Bonnie Perry, "He hit the front
21 page of The NY Post the other day."
23 A. Yes.
24 Q. Okay. Do you recall seeing an
25 article in The New York Post in 2007 about

1 Jeffrey Epstein?
2 A. No.
3 Q. Okay. And then going down...
4 A. This is attached.
5 Q. Okay. Looking down the page of
6 that e-mail, about halfway through, you see
7 an e-mail between -- an e-mail to Anne
8 Verdon.
9 Do you see that? About halfway
10 down the first page?
11 A. Yes.
12 Q. Do you recognize the name Anne
13 Verdon?
14 A. Yes.
15 Q. And who is that?
16 A. I believe she's a lawyer at the
17 company or was a lawyer at the company.
18 Q. And about halfway through that
19 e-mail, it describes notable activity in
20 Epstein's personal account.
22 A. Yes.
23 Q. Cash withdrawals - CTRs filed -
24 2007 YTD, $400,000, parens, ten $40,000
25 withdrawals; 2006, 914,796, which is 18

1 $40,000 withdrawals, one 60,000, another

2 60,000, 30,000, plus 25,000; 2007 transaction
3 activity, $50,000.
4 Roughly what the e-mail says?
5 A. Yes.
6 Q. And then it goes on to say
7 below the attachments, "One of the accounts
8 in the Epstein's relationship is for
9 'girlfriend/model' . Funds
10 into her account are transfers from Epstein,"
11 $25,000 on March 19, 2007; another $50,000
12 June 8, 2007.
13 Then it mentions two others.
14 " and are not PB
15 clients."
16 Have I read all of that
17 generally correctly?
18 A. Yes.
19 Q. And do you understand PB to
20 stand for private bank?
21 A. That would be my general view,
22 yes.
23 Q. Okay. And they do appear to
24 have retail credit cards. That's what the
25 e-mail says, correct?


2 Q. Okay. You're aware, are you
3 not, that Epstein purported to be a money
4 manager or a financial advisor, correct?
5 A. I was not aware at the time.
6 Q. Okay. Have you since learned
7 that that was Epstein's public persona?
8 MR. BUTTS: And you should not
9 reveal, again, anything you learned
10 through counsel.
11 THE WITNESS: I don't really
12 know what his public persona was, even
13 today.
15 Q. Do you have any idea why
16 Jeffrey Epstein would have been transferring
17 these amounts of cash?
19 THE WITNESS: Back then? I
20 didn't know.
22 Q. Uh-huh.
23 And do you know whether
24 JPMorgan had an understanding in 2007 why
25 Jeffrey Epstein was moving those amounts of

1 cash?
3 THE WITNESS: No, I do not.
5 Q. So at this point in
6 October 2007, JPMorgan knew that Jeffrey
7 Epstein was charged with sex crimes involving
8 cash and moving large amounts of cash.
9 Is that correct?
11 You may answer.
12 THE WITNESS: Yeah. When you
13 say "JPMorgan knew," yes, there were
14 people here who obviously knew some of
15 that, yes.
17 Q. Okay. We can put this document
18 aside. We're going to move to Dimon
19 Number 5 -- or Exhibit 4.
20 MS. FRIEDMAN: That was 4, yes.
21 MR. BUTTS: I think you said 4.
22 It was 3. Now you're on 4.
23 MS. SINGER: This is why I
24 don't do math during these
25 depositions.

1 MR. BOUCHOUX: Let's just be

2 clear on exhibits.
3 Exhibit 1 was the Schlakman.
4 Exhibit 2, did you mark that,
5 or is that just going in as
6 Langford 15?
7 MR. BOIES: I think's that's
8 Langford 15.
9 MR. BOUCHOUX: That's just
10 Langford 15, correct? Yep.
11 Exhibit 3 is the probable cause
12 affidavit that we reviewed with the
13 excerpts. Am I right?
14 And then -- sorry, that's
15 actual Exhibit 2 is the probable
16 cause.
17 3 is what --
18 MS. SINGER: 3 is the slide.
19 MR. BOUCHOUX: -- we just
20 looked at.
21 MS. SINGER: Yes.
22 MR. BOUCHOUX: And now we're
23 getting what?
24 MS. SINGER: 4.
25 MR. BOUCHOUX: Exhibit 4.

1 Thank you.
2 MR. BUTTS: And while we're on
3 housekeeping, we'll designate the
4 whole transcript as confidential.
6 identification.)
8 Q. All right. So 4 is
9 JPM-SDNYLIT-00269663.
10 MR. BOIES: Excuse me. I'm
11 confused on the exhibit numbers.
12 MS. SINGER: Do we want to go
13 off the record then? I'm --
14 MR. BUTTS: No.
15 MS. SINGER: -- mindful of
16 time.
17 MR. BUTTS: We are as well, so
18 we're staying on the record.
19 MR. BOIES: Exhibit 1 is the
20 article dated in 2006.
21 Exhibit 2 is what?
22 MS. OLIVER: The slides of the
23 probable cause affidavit.
24 MR. BOIES: The slide, that's
25 Exhibit 2?

1 MS. OLIVER: That's Exhibit 2.

2 MS. SINGER: Mr. Boies, can we
3 do this on a break? I promise we'll
4 get this straight before you're up.
5 And I'm sorry for making it messy.
7 Q. Okay. So focusing on our
8 current Exhibit 4, I will represent to you
9 that this document produced by JPMorgan
10 relates to various high-risk clients with
11 criminal records.
12 And we're going to look at -- I
13 printed the whole thing, but we're going to
14 focus on tab -- on the tab for 2006, which is
15 the first page of the document.
16 And if you look at row 2, do
17 you see the name Jeffrey Epstein?
18 A. Yes.
19 Q. And it indicates -- so that's
20 under the client name, correct?
21 A. Yes.
22 Q. Okay. And under the Reason, it
23 indicates "Several newspaper articles were
24 found that detail the indictment of Jeffrey
25 Epstein in Florida on felony charges of

1 soliciting underage prostitutes."

3 A. Yes.
4 Q. And the date is 10/17/2006,
5 correct?
7 Q. And the decision is -- I'm
8 sorry, the outcome is "Retain."
9 Correct?
11 Q. Okay. And you understand that
12 to mean that Jeffrey Epstein would remain a
13 client of JPMorgan, correct?
15 Q. And then underneath Jeffrey
16 Epstein is the name .
17 Correct?
18 A. Yes.
19 Q. And are you familiar with that
20 name?
22 You may answer.
25 Q. Okay. And in -- under Reason

1 for , it indicates that an

2 article dated
3 .
4 Is that correct?
6 Q. Result is "Exit Relationship."
9 Q. Correct?
10 A. Yes.
11 Q. Okay. And that means, as you
12 would understand it, that JPMorgan ceased
13 doing business with Mr. , correct?
15 You may answer.
16 THE WITNESS: Whatever -- it
17 means that, yes, I think.
19 Q. Okay. And there's no
20 indication here that had been
21 convicted or pled guilty, correct?
23 You may answer.
24 THE WITNESS: That's what this
25 says. I had no idea about all the

1 other things about , so I

2 don't know what they looked at.
4 Q. Okay. And everybody else here,
5 by the way, on the charge just -- on the
6 chart, looking at just the first page and the
7 back of the first page, which is 2006,
8 everyone else was retained, correct?
10 You may answer.
11 THE WITNESS: Are you talking
12 about this one page?
14 Q. The one page and the back. The
15 page which is 2006.
17 You may answer.
18 THE WITNESS: Yeah, but I --
19 okay. That's was just -- both sides
20 of it?
22 Q. Yes.
23 A. That's what it says, yes.
24 Q. Okay. Do you know why
25 was terminated based on the

1 information JPMorgan had and not Jeffrey

2 Epstein?
3 MR. BUTTS: You're asking him
4 to read the document or --
5 MS. SINGER: No, I'm asking if
6 he knows.
7 MR. BUTTS: If you know.
8 Objection.
9 You may answer.
10 THE WITNESS: I do not know.
12 identification.)
14 Q. Okay. Let's turn to exhibit --
15 what we'll mark as Exhibit 5, and that's
16 JPM-SDNY-00134475.
17 All right. Exhibit 5 is an
18 e-mail between and Mary Erdoes.
19 Do you know who
20 is?
21 A. I believe this is ?
22 Q. Okay. And --
23 A. I do.
24 Q. Okay. It's dated May 28, 2008,
25 correct?

1 A. Yes.
2 Q. Okay. And it looks like Mary
3 Erdoes is complaining to -- or remarking to
4 that she's at a cheesy broker
5 fest of a function.
6 Do you see where I'm reading?
7 A. Yes.
8 Q. In the middle of page?
9 A. Yes.
10 Q. And at the top,
11 responds, responds to say,
12 "Epstein there with Miley Cyrus?"
14 A. Yes.
15 Q. Do you think it was appropriate
16 that Mary Erdoes was involved with a joke
17 with about Jeffrey Epstein's
18 appetite for young girls?
20 You may answer.
21 THE WITNESS: I have no idea
22 what this means.
24 Q. You don't know what it means
25 that was asking if Epstein was

1 there with Miley Cyrus, a young girl?

3 You may answer.
4 THE WITNESS: I don't know her
5 age at the time. I don't know whether
6 he's asking a serious question or not.
7 Maybe she was -- I have no idea.
8 You're asking a question I couldn't
9 possibly know.
11 identification.)
13 Q. Okay. All right. Let's turn
14 to another one then. JPM-SDNYLIT-00099337,
15 which will be Exhibit 6.
16 And this is an e-mail between
17 Mary Erdoes and Jes Staley, is it not?
18 A. Yes.
19 Q. And it's dated August 27, 2006,
20 correct?
21 A. Yes.
22 Q. Okay. And in the middle of the
23 page is a -- part of the chain from Jes
24 Staley to Mary Erdoes. And Mr. Staley
25 e-mails, "Last night went to the Huggy Bear

1 concert. The age difference between husbands

2 and wives would have fit in well with
3 Jeffrey. What a joke."
5 A. Yes.
6 Q. Do you regard this as an
7 appropriate exchange between JPMorgan
8 executives regarding a customer charged with
9 sexual offenses with minors?
11 You may answer.
13 they meant by this.
15 Q. Okay. Seems that they're
16 commenting on a large disparity in age
17 between men and women at an event.
18 Does that suggest to you -- I
19 mean, does that seem right to you?
21 You may answer.
22 THE WITNESS: He's talking
23 about an age difference between
24 husbands and wives. I mean, I read
25 that as second wives.


2 Q. Okay. Okay. And the
3 connection to unmarried Jeffrey Epstein is
4 not apparent to you?
6 THE WITNESS: That he likes
7 younger wives, I guess. I don't know.
9 Q. And there's nothing about this
10 e-mail that you find troubling in the context
11 of Jeffrey Epstein's criminal -- the
12 allegations against Jeffrey Epstein?
14 You may answer.
15 THE WITNESS: I don't like the
16 e-mail, but I don't know what they
17 mean. It's just gossip.
19 identification.)
21 Q. Okay. All right. Let's turn
22 to what we'll mark as Exhibit 6? 7.
23 Exhibit 7 is
25 And I think you told

1 Mr. Sullivan that you are not familiar with

2 rapid response teams; is that right?
3 MR. BUTTS: Well, give him a
4 minute. You handed him a large
5 document. I think he needs some time
6 to see what it is.
7 THE WITNESS: It's the same
8 document as before.
10 Q. No, this is a different one.
11 MR. BUTTS: No, it's not.
12 THE WITNESS: Well, the first
13 page is the same.
14 MR. BUTTS: It's the same
15 document.
16 THE WITNESS: The whole
17 document is the same?
18 MR. BUTTS: Uh-huh.
19 MS. SINGER: We'll get to a
20 different part of it.
23 Q. So before we turn to a specific
24 section, are you -- I think you testified
25 that you're not familiar with the term "rapid

1 response" or "rapid response teams" as it

2 relates to reviewing JPMorgan high-risk
3 customers.
5 You may answer.
6 THE WITNESS: I don't remember
7 being familiar with that term.
9 Q. Okay. This, I'll represent to
10 you, is a tracking database of rapid response
11 meetings, and I want to look at page -- I'm
12 sorry, I want to look at row 21. That's
13 not --
14 A. Item 21?
15 Q. Row 21.
16 MS. FRIEDMAN: Mine's blank.
17 MR. BUTTS: Yeah. Redacted,
18 privilege? Is that what you want?
19 MS. FRIEDMAN: No.
20 What year?
21 MS. SINGER: Okay. I'm sorry.
22 And it should be dated July 15, 2008.
23 We can also find it on the screen,
24 which may be easier.


2 Q. All right. Do you have it in
3 front of you now?
4 A. Yes.
5 Q. Okay. So row 21 relates to
6 Jeffrey Epstein; is that right?
7 A. Yes.
8 Q. Okay. And it says in the
9 fourth column, "Catherine will go back to JES
10 to tell him we are uncomfortable with Epstein
11 and do not want to go to Cutler for
12 approval."
14 A. Yes.
15 Q. Do you understand "Catherine"
16 to refer to Catherine Keating?
17 A. I'll accept that.
18 Q. Okay.
19 A. I don't know who exactly it
20 refers to.
21 Q. Okay. And JES you would
22 understand to be Jes Staley, correct?
23 A. I would assume so, yes.
24 Q. Okay. And the date of this
25 entry is July 15, 2008, according to the

1 chart, correct?
2 A. Yes.
3 Q. Is it fair to say -- let me ask
4 it differently.
5 In 2008, were you aware -- I'm
6 going to try this a third time. Maybe I'll
7 get it right.
8 Catherine Keating's position in
9 2008 was as CEO of the private bank; is that
10 right?
11 A. I don't recall when she became
12 CEO of the private bank, but I'll accept that
13 if you tell me that's true.
14 Q. Okay. And she was CEO of the
15 private bank at some point, correct?
17 Q. Okay. And were you aware in
18 2008 that Catherine didn't want to ask
19 Cutler's approval to retain Jeffrey Epstein
20 as a customer?
21 A. I was unaware of it at the
22 time.
23 Q. Okay. This doesn't appear to
24 be an after-the-fact judgment, does it,
25 Mr. Dimon?


3 you mean by that.
5 Q. Meaning in 2008, it looks as if
6 the senior executive at JPMorgan is
7 indicating that she doesn't want approval --
10 Q. -- to keep Jeffrey Epstein as a
11 customer of the bank.
13 THE WITNESS: I'll accept it
14 based on what it says here. I know
15 nothing else about this.
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20 identification.)
22 Q. We're going to turn to what
23 we'll mark as Exhibit 9, which is a
24 demonstrative slide that we prepared. Yep,
25 that's right.

1 This is not a bank-produced

2 document. It's a document that we prepared
3 based on records produced to us by JPMorgan.
4 And I think you already
5 testified, Mr. Dimon, that you've never
6 reviewed the cash history in Jeffrey
7 Epstein's apart -- outside of your
8 preparation for this deposition.
9 Is that correct?
10 A. Yes.
11 Q. Okay. And you can see from
12 this chart that Jeffrey Epstein's cash
13 withdrawals in 2004, 2005 and 2006 were even
14 greater than the cash activities reported in
15 2007 and 2008; is that correct?
16 MR. BUTTS: And I want to
17 interject for a moment.
18 You can ask whatever questions
19 you'd like about your demonstrative.
20 It is incorrect. But go ahead.
21 MS. SINGER: Well, that's your
22 representation.
23 MR. BUTTS: That is -- and so
24 is your demon -- this demonstrative is
25 supposed to be yours, but I want that

1 to be on the record, and now you may

2 ask the question.
3 MS. SINGER: And we can
4 disagree about that.
6 Q. But you would agree, based on
7 this demonstrative, Mr. Dimon, that the cash
8 activity in 2004, 2005, 2006, was
9 substantially greater than the cash activity
10 reported in 2007 and 2008, correct?
12 THE WITNESS: If --
13 MR. BUTTS: You may answer.
14 THE WITNESS: -- this is
15 accurate, yes.
17 Q. Okay. And that cash activity
18 is all visible to JPMorgan in realtime, is it
19 not?
21 You may answer.
24 identification.)
25


2 Q. Okay. All right. We can put
3 the demonstrative aside. We're going to turn
4 to Exhibit 9?
5 Is that right?
6 MR. BOUCHOUX: That was 9.
7 MS. SINGER: 10. 10.
9 Q. And that's JPM-SDNYLIT-
10 00099606.
11 All right. Exhibit 10 -- 9 --
12 Exhibit 9 -- is it 10? -- 10 is an e-mail
13 between Mary Erdoes and Tamyka Clarke.
14 Is that right?
15 A. Yes.
16 Q. Okay. And if we go all the way
17 down -- and I'm sorry, it's dated
18 September 9, 2008, correct?
19 A. Yep.
20 Q. Okay. Let's go to the second
21 page of this e-mail, which is Bates
22 number 607.
23 A. The second page?
24 Q. The second page, that's right.
25 And that is an e-mail between

1 Catherine Keating and Mary Casey, correct,

2 cc'ing Marcus Sheridan, right?
3 A. Yes.
4 Q. And it's a few days earlier,
5 September 4, 2008, correct?
6 A. Yes.
7 Q. And it indicates, "I,"
8 Catherine Keating, "spoke to Mary about
9 Epstein relationship several weeks ago. She
10 did not want me to go to Jes at that time."
12 A. Yes.
13 Q. Okay. And it says -- then goes
14 on to say, "I think you and me and Kevin and
15 Anne should speak with her."
17 A. Yes.
18 Q. All right. And then there's
19 more e-mail traffic which we don't need to
20 spend time on, but we'll go to the first
21 page, bottom of first page.
22 Catherine Keating again
23 e-mails, "Please schedule time with Mary E.
24 for me and Anne Verdon to discuss Epstein."
25 Correct?

1 A. Yes.
2 Q. And you would understand
3 Mary E. to be Mary Erdoes, correct?
4 A. I'll take that as stipulated,
5 yes.
6 Q. Okay. And at the top, Mary
7 Erdoes responds -- that's 9/9/2008 e-mail --
8 "Oh, boy."
10 A. At the top? Yes.
11 Q. Yes.
12 Do you recall that earlier
13 rapid response database we looked at
14 indicated that Keating did not want to go --
15 Catherine Keating did not want to go to Steve
16 Cutler to get approval to retain Jeffrey
17 Epstein?
20 Q. Do you recall that document?
24 Q. Okay. And it seems here that
25 Catherine Keating is asking for permission to

1 go to Jes Staley; is that right?

2 A. Where are you looking at?
3 Q. That very first part of the
4 e-mail we covered on page 2. "She did not
5 want me to go to Jes at that time."
6 A. Yes.
7 Q. Okay.
8 A. So what's the question?
9 Q. Did you understand -- do you
10 understand that Catherine Keating was asking
11 to go talk to Jes Staley?
12 MR. BUTTS: Did he understand
13 this at the time, or are you asking
14 him to read somebody else's e-mail and
15 see what --
16 MS. SINGER: I'm asking if he
17 understands that to be what this
18 e-mail means.
19 THE WITNESS: I didn't know at
20 the time.
22 Q. Didn't know at the time.
23 Do you understand this e-mail
24 looking at it now?
25 A. Well, yeah. I don't know the

1 reasons or why, so -- but, yes, I read it.

2 The way you do, yes.
3 Q. Okay. You read it, and you
4 understand it to be Catherine Keating asking
5 to go talk to Jes Staley, correct?
7 THE WITNESS: "I spoke to Mary.
8 She did not want me to go to Jes."
9 Yeah, so she thinks that Mary
10 doesn't want her to go to Jes, yes.
12 Q. Okay. All right. Were you
13 aware in 2008 --
14 MR. BUTTS: I --
16 Q. -- about Catherine Keating's
17 views about Jeffrey Epstein?
19 THE WITNESS: No.
21 Q. Were you aware of Mary Erdoes'
22 views about Jeffrey Epstein in 2008?
23 A. No.
24 Q. And were you aware in 2008 of
25 Jes Staley's views about Jeffrey Epstein?

1 A. No.
2 Q. Okay.
3 MR. BUTTS: Are you finished
4 with this document?
5 MS. SINGER: Yes, if y'all want
6 a break.
7 MR. BUTTS: Hold on. I think
8 it's been an hour. It's 11:40.
9 What's -- do you want --
10 THE WITNESS: I eat at 12, so
11 let's go right to -- let's wait until
12 12 to eat lunch.
13 MR. BUTTS: Yeah, there it is.
15 identification.)
17 Q. Okay. All right. Let's go to
18 Exhibit 11, which is going to be
20 All right. This document is an
21 e-mail between Jes Staley and Jeffrey
22 Epstein, correct?
23 A. Yes.
24 Q. Okay. And it's dated
25 August 30, 2009, at the very top, correct?

1 A. Yes.
2 Q. Prior to your preparation for
3 this deposition, had you seen this e-mail
4 before?
5 A. No.
6 Q. And if we go to the middle of
7 this e-mail, Jes Staley indicates to Jeffrey
8 Epstein, "Back in the saddle Monday in London
9 with Jamie mid-week."
10 Do you recall a trip to Jes
11 Staley -- a trip to London with Jes Staley in
12 August or September 2009?
13 A. Do I recall it, like, back
14 then, no, but as a part of preparing for
15 this. And my records are known, so you guys
16 can just check.
17 And I think I went there for a
18 big conference, not for Jes.
19 Q. Okay. But you don't have an
20 independent recollection of a trip to London
21 that Jes Staley was also on in August 2009,
22 correct?
23 A. Correct.
24 Q. Okay. At the top of the -- I'm
25 sorry. Towards the top of the e-mail,

1 Jeffrey Epstein asked Jes Staley, "How long

2 London? Do you need anything there?"
3 And Jes Staley responds, "Yep."
4 Have I read both of those
5 segments correctly?
6 A. Yes.
7 Q. Were you aware of this
8 interaction between -- I'm sorry. Were you
9 aware of -- I'm going to try one more time on
10 this one.
11 Are you currently aware of what
12 happened between Jeffrey Epstein and Jes
13 Staley with regards to this e-mail?
14 MR. BUTTS: And is the question
15 about your current awareness --
16 THE WITNESS: I'm neither
17 currently aware, nor was I back then.
19 Q. Okay. So you don't know what
20 this exchange refers to, do you?
21 MR. WOHLGEMUTH: Objection.
22 THE WITNESS: Who objected?
23 MR. BUTTS: That's -- that's --
24 that's right. You can answer the
25 question. That's Mr. Staley's

1 counsel.
2 THE WITNESS: Oh.
3 Repeat the question?
5 Q. Yes.
6 Do you have any understanding
7 of what this e-mail exchange between Jeffrey
8 Epstein and Jes Staley refers to?
10 THE WITNESS: No.
12 Q. Were you aware of -- are you
13 currently -- are you currently aware that
14 Jeffrey Epstein transferred $3,000 to a woman
15 named on August 31st from Jeffrey
16 Epstein's account at JPMorgan?
17 MR. BUTTS: Objection. You
18 should not answer to the extent you're
19 revealing anything learned form
20 counsel.
21 THE WITNESS: I was not aware.
23 Q. When did you first learn of the
24 transfer that Jeffrey Epstein made to ?
25 MR. BUTTS: Same objection and

1 instruction.
2 THE WITNESS: Only after being
3 prepared for this.
5 Q. Okay. This wasn't -- and
6 you've since come to understand that Jeffrey
7 Epstein did make a transfer to a woman named
8 around this time, correct?
10 And you may ask {sic} that
11 question based on your state of
12 knowledge prior to starting your
13 preparation for this deposition.
14 THE WITNESS: I do not know.
16 Q. Okay.
17 A. I don't know if it took place
18 or didn't take place or...
19 Q. Are you aware of other
20 transfers that Jeffrey Epstein made to women
21 from his JPMorgan accounts?
23 instruction.
24 THE WITNESS: I was not aware.
25


2 Q. And at no point prior to 2019
3 did you become aware of Jeffrey Epstein's
4 payments to women from his JPMorgan accounts.
5 Is that correct?
6 A. I don't recall being aware, no.
7 And I don't know when I became aware of some
8 of it, so...
9 Q. Would you expect, in light of
10 Jeffrey Epstein's sex offenses, that JPMorgan
11 would pay special attention to payments he
12 was making to women?
14 You may answer.
15 THE WITNESS: I would expect my
16 experts to review what they thought
17 was appropriate to review.
19 Q. And do you think that would
20 include for a sex offender like Jeffrey
21 Epstein paying for women -- paying women and
22 recruiters for sex, that that would include
23 review of his payments to women?
25 You may answer.

1 THE WITNESS: I would have

2 asked them to make sure they do proper
3 reviews of all things, yes.
5 Q. And sitting here today, do you
6 have an opinion as to whether that would
7 include -- do you have a view as to whether
8 that would include looking at his transfers
9 of money to women?
11 objection to form.
12 You may answer.
13 THE WITNESS: My expectation
14 would be they would be looking at
15 things like that, among all of the
16 other things they looked at. And I
17 don't know if it was put in front of
18 the group. I don't know if they saw
19 it.
21 Q. And when you refer to "group"
22 in your response, you don't know if that was
23 put in front of the group, what do you mean
24 by "group"?
25 A. The people who review these

1 types of things.
2 Q. Compliance, regulatory, the
3 bankers --
5 Q. -- correct?
6 Okay. All right. On
7 September 1, 2009, Jes Staley became CEO of
8 JPMorgan's investment bank; is that right?
9 A. I'll accept the date from you.
10 Yeah. I don't know -- I don't remember the
11 exact date.
12 Q. Okay. But you do recall
13 somewhere around there, he became CEO of
14 JPMorgan's investment bank, correct?
15 A. Yes.
16 Q. And that was a change that you
17 directed, Mr. Dimon?
18 A. Yes.
19 Q. Why did you -- well, was it a
20 promotion?
21 A. I would say so, yes.
22 Q. Okay. And why did you direct
23 that change?
24 A. I had -- for a whole bunch of
25 reasons, I had to make a change. I wanted to

1 use someone internal. We reviewed several

2 people, and this also went to the board. And
3 with all the people reviewed, we thought Jes
4 would be the best person at the time to do
5 the job.
6 Q. And after Jes Staley became CEO
7 of the investment bank, Mary Erdoes became
8 the CEO of the private bank, or the asset and
9 wealth management unit, correct?
10 A. I believe that happened at the
11 same time, yes.
12 Q. Okay. As CEO of private bank
13 or asset and wealth management, Mary Erdoes
14 could have decided to terminate Jeffrey
15 Epstein as a customer, as a client, of
16 JPMorgan; is that right?
18 You may answer.
19 THE WITNESS: I generally would
20 say that's true, yes.
22 identification.)
24 Q. Let's go to Exhibit 11. 12.
25 Clock's right twice a day, so once I'm going

1 to get an exhibit number right.

2 This is JPM-SDNYLIT-00008363.
3 Exhibit 12.
4 I think you testified earlier
5 that the name Paul Morris is not familiar to
6 you, correct?
7 A. Yes.
8 Q. Okay. This is an e-mail,
9 though, among JPMorgan employees dated
10 June 18, 2020.
11 Is that correct?
12 A. 2010.
13 Q. 2010, thank you.
14 Is that correct?
15 A. Yes.
16 Q. Okay. And in the middle of
17 this e-mail, Bonnie Perry is asking Paul
18 Morris, "Please update the transaction
19 profile/expected account activity -
20 specifically, please note monthly cash
21 withdrawal activity ranging 30k to 50k and
22 the purpose of these cash withdrawals."
24 A. Yes.
25 Q. Okay. And this is, by the way,

1 under the heading DDR name Jeffrey Epstein,

2 correct?
3 A. Yes.
4 Q. Do you understand now, reading
5 this e-mail, that JPMorgan employees are
6 asking questions again about Jeffrey
7 Epstein's use of cash?
9 I -- you're asking him to read
10 the e-mail and say -- and talk --
11 characterize it? I don't know what
12 the relevance of this is your time,
13 but --
14 MS. SINGER: If that's an
15 objection --
16 MR. BUTTS: It is an objection.
17 THE WITNESS: It says, "Please
18 note." It does -- not asking
19 questions.
21 Q. Okay.
22 A. Okay. They're observing cash
23 activities in Jeffrey Epstein's account,
24 correct?

1 You may answer.

2 THE WITNESS: Bonnie is asking
3 Paul to note that there are cash
4 withdrawals.
6 Q. Okay.
7 A. Yeah.
8 Q. And then goes on to say,
9 "Please update the summary to include the
10 client's current personal circumstances,
11 business activities."
12 Correct?
13 A. Yes.
14 Q. Okay. And so I think the place
15 where you're disagreeing is that it doesn't
16 indicate that they're raising questions;
17 simply that they are acknowledging or
18 observing it, correct?
20 You may answer, if you're able.
23 identification.)
25 Q. All right. Let's turn to

1 Exhibit 13 -- 14 -- 13, which is

3 And while we're getting you
4 that exhibit, just a general question.
5 Are you generally familiar,
6 Mr. Dimon, with what kind of review
7 JPMorgan's compliance team would do of
8 somebody with a criminal history -- a
9 customer with a criminal history?
11 You may answer.
12 THE WITNESS: I know they
13 review clients periodically, and among
14 the things that would have a
15 heightened review would be something
16 with criminal activity.
18 Q. And for somebody with criminal
19 activity, do you have a sense of what that
20 periodic review consists of?
21 A. Not specifically, no.
22 Q. Okay. So the --
23 MR. BUTTS: If you're going to
24 go into the document, he needs a
25 chance to familiarize himself with it.


2 Q. Uh-huh. Whenever you're ready,
3 Mr. Dimon.
4 And I'm not going to ask you
5 about the particulars of this customer.
6 A. Oh.
7 Q. But I am going to ask, are you
8 ever involved in making the final decision
9 about whether to keep a customer with a
10 criminal history at JPMorgan?
12 You may answer.
14 Q. And I'm asking just generally.
15 A. What was the question again?
16 Q. Are you ever involved in the
17 decision of whether to retain a customer with
18 a criminal -- retain a customer of JPMorgan
19 with a criminal history?
21 You may answer.
22 THE WITNESS: I don't believe
23 that I've ever been involved in a
24 decision like that.
25


2 Q. Okay.
3 A. I delegate that to general
4 counsel for very good reason, and I don't
5 remember ever making it myself.
6 Q. Okay.
7 A. That doesn't mean there isn't
8 an exception somewhere, but...
9 Q. And what is the good reason
10 that prompts you to delegate that decision
11 about whether to keep a customer with a
12 criminal history?
13 A. So you don't automatically
14 terminate someone with a criminal history.
15 In fact, you know, there are a lot of
16 occasions we try to give people second
17 chances and things like that. And these
18 become very complex matters, and you want the
19 people who know a lot about taxes and money
20 laundering, criminal history, trafficking,
21 whatever it is, to take the time and the
22 effort, and you have people do that.
23 And I think that is the right
24 way to do it, and I still think that's the
25 right way to do it.

1 Q. Meaning it should be a
2 compliance-based decision?
3 A. Compliance --
5 You may answer.
6 THE WITNESS: I think there are
7 reputational-based decisions and
8 legal-based decisions, and in both
9 cases the ultimate arbiter, if there's
10 a disagreement, which sometimes there
11 is, would be my general counsel.
13 Q. So at the end of this document,
14 if you go to the bottom of the very last
15 page -- I'm sorry, the second bullet towards
16 the bottom of the page.
17 A. I read it, yeah.
18 Q. "Follow with IB to
19 determine" -- whoops, second page. Looking
20 at the screen. Second bullet. "Follow with
21 IB under recommendation."
22 "Follow with IB to determine if
23 a request was made to J. Dimon to approve
24 under sponsorship policy requirement for" --
25 "sponsorship policy requirement for convicted

1 felons."
2 Do you recall a review in this
3 instance of being sent to you
4 for your determination to approve whether he
5 could remain a customer of the bank?
7 You may answer.
8 THE WITNESS: No.
10 Q. Okay. Do you know why, in this
11 instance, the response team's rapid response
12 summary would indicate that a request might
13 have been made to you to approve the
14 continued business with a convicted felon?
16 If you're able --
17 THE WITNESS: I will speculate
18 that --
19 MR. BUTTS: Don't -- I don't
20 think they want you to speculate --
22 Q. I'm asking if you know.
23 MR. BUTTS: -- and you don't
24 have to speculate.
25


2 Q. Do you know?
3 A. I don't know why they asked --
4 that was put in there.
5 Q. Okay. Okay. And you have no
6 personal knowledge of , do you?
8 You may answer.
10 recall.
11 MS. SINGER: Okay. So I'm
12 going to go into another block. I
13 know it's 11:56. I think you
14 indicated a 12 o'clock --
16 MR. BUTTS: You want to just --
17 THE WITNESS: Yes. Want to
18 keep going a little bit more?
19 MR. BUTTS: I was thinking it's
20 probably the right time --
21 THE WITNESS: Okay. That's
22 good.
23 MR. BUTTS: -- if they're going
24 into another block.
25 THE WITNESS: Okay. What is a

1 block?
2 MR. BUTTS: It's a set of
3 questions.
4 MS. SINGER: It's very painful.
5 THE WITNESS: Okay. Lunch.
6 MR. BUTTS: Before we go --
7 before we go off the record, it's your
8 time, plaintiffs get five hours
9 together.
10 My general commentary, I know
11 you won't agree with it, is it's been
12 a lot of questioning of Mr. Dimon
13 about what did other people write and
14 reading documents that you've asked
15 about with others.
16 You don't -- I know you don't
17 agree with it, but you're not using
18 your time well. That's my position.
19 And I want to give you fair warning,
20 whatever questions you need with this
21 man about his involvement in this
22 case, which should be very, very
23 little, make sure you get it within
24 your window.
25 That's all I'll say. You can

1 say you disagree.

2 MS. SINGER: I strongly
3 disagree.
4 MR. BOIES: And I disagree that
5 it's five hours.
6 MR. BUTTS: Yeah, well, we'll
7 see.
8 MR. BOIES: I think the judge
9 said what he said.
10 MR. BUTTS: We're going to deal
11 with that later. But now we can go
12 off the record.
13 MS. SINGER: We'll add that to
14 your time.
16 the record. The time is 11:58.
17 (Off the record at 11:58 a.m.)
20 (Dimon Exhibits 16 and 17
21 marked for identification.)
23 Q. All right. Mr. Dimon, we're
24 going to start by going back to the tape. So
25 we're going to show another clip from your

1 interview with CNN and one with Bloomberg,

2 and then I'm going to ask you about both of
3 them.
4 So, Ms. Veldman, please go
5 ahead.
6 (Video played.)
7 Q. All right. Mr. Dimon, those
8 are interviews that you gave both with CNN
9 and Bloomberg News, correct?
10 A. Yes.
11 Q. Okay. And do those accurately
12 reflect your views about how you and JPMorgan
13 addressed Jeffrey Epstein's accounts and
14 activities?
16 Q. Isn't it the case that your
17 lawyers and compliance personnel at JPMorgan
18 did not support retaining Jeffrey Epstein as
19 a customer of JPMorgan beginning in at least
20 2011?
22 You may answer apart from any
23 information that you learned through
24 counsel.
25 THE WITNESS: Well, then I have

1 no information.
3 Q. Okay. We can talk about facts
4 and information --
5 A. Okay.
6 Q. -- that you -- that you're
7 aware of, not advice from counsel.
8 But are you aware that
9 compliance personnel and lawyers did not
10 favor retaining Jeffrey Epstein as a customer
11 of Jeffrey -- of JPMorgan?
13 instruction.
14 THE WITNESS: Yeah, I was not
15 aware at the time, no.
17 Q. And have you become aware
18 since?
20 instruction.
23 Q. And when did you become aware
24 that your compliance personnel and lawyers
25 did not support retaining Jeffrey Epstein as

1 a customer?
2 MR. BUTTS: And --
3 THE WITNESS: I don't agree
4 with that statement. Obviously the
5 group met, and the ultimate decision
6 was to allow it.
8 Q. Okay. So we'll come back to
9 that.
10 A. Yeah.
11 Q. But do you remember when you
12 first heard that?
13 MR. BUTTS: The same objection
14 and instruction.
15 THE WITNESS: You know, I do
16 not remember anything back then, no.
18 Q. Okay. Do you remember whether
19 you learned that lawyers and compliance
20 people at JPMorgan did not support retaining
21 Jeffrey Epstein as a customer before your
22 interview with CNN or Bloomberg?
24 instruction.
25 THE WITNESS: Yeah, I -- almost

1 everything I learned, I learned after

2 this case was opened, and I started to
3 see the details.
5 Q. Understood.
6 But was that before or after
7 your interviews with CNN and Bloomberg about
8 this litigation?
10 instruction.
11 THE WITNESS: I don't recall.
13 Q. Okay. Two of your top
14 deputies, Jes Staley and Mary Erdoes, made
15 the decision to retain Jeffrey Epstein as a
16 customer of JPMorgan.
17 Is that correct?
18 A. Again, all I know is what I
19 learned after you opened it.
20 MR. BUTTS: And I'll again say,
21 nothing you learned through counsel in
22 connection with this litigation is
23 within the scope of this deposition.
24 MS. SINGER: He can't speak to
25 advice of counsel, but he can speak to

1 what he knows and believes.

2 MR. BUTTS: In the context --
3 he can't speak to the -- in the
4 context of giving advice, lawyers have
5 discussions with clients, and clients
6 have a privilege over those. And he
7 doesn't have to share what he learned
8 in those conversations.
9 MS. SINGER: As legal advice,
10 but not as facts.
11 MR. BUTTS: Yeah. The
12 instruction -- the instruction's the
13 same.
14 MS. SINGER: Okay. We may have
15 to call the Court about that --
16 MR. BUTTS: Do whatever you
17 like.
18 MS. SINGER: -- but we'll see
19 how far we can get.
21 Q. So the question, Mr. Dimon,
22 was, isn't it true that two of your top
23 deputies, Jes Staley and Mary Erdoes, made
24 the decision to retain Jeffrey Epstein as a
25 customer of JPMorgan?


2 instruction.
3 THE WITNESS: Meaning I don't
4 answer it?
5 MR. BUTTS: Yeah. Don't -- if
6 you know something outside of
7 conversations with counsel in
8 connection with this litigation, you
9 may answer it. If you don't, then you
10 don't have an answer.
11 THE WITNESS: The only thing
12 I'd say in addition is that they
13 cannot make that decision alone.
15 Q. And Jes Staley and Jeffrey --
16 I'm sorry. Jes Staley and Mary Erdoes cannot
17 make that decision without consulting with
18 regulatory and legal counsel? Is that what
19 you're indicating?
20 A. I think the ultimate decider
21 would have been the general counsel of the
22 company. That was true then; it's true
23 today. And that person cannot be overridden
24 by a businessperson.

1 identification.)
3 Q. So let's turn to -- we're going
4 to show you Exhibit 14, which is a slide and
5 two backup documents, which are
6 JPM-SDNYLIT-00274561 and
7 JPM-SDNYLIT-00135958_R. It's Exhibit 14.
8 So, Mr. Dimon, let's start with
9 the slide first. You have a hard copy. It's
10 up on your screen.
11 MR. BUTTS: Yeah. And for the
12 record, this is a slide -- a
13 demonstrative that you created.
14 MS. SINGER: That's correct.
16 Q. So do you recognize Steve
17 Cutler as your general counsel at JPMorgan
18 Chase prior to 2013?
19 A. Yes.
20 Q. Okay. And are you aware that
21 in 2011 Mr. Cutler wrote in an e-mail, "This
22 is not an honorable person in any way. He
23 should not be a client," referring to Jeffrey
24 Epstein?

1 instruction --
2 THE WITNESS: I wasn't aware at
3 the time.
5 Q. And have you since learned
6 that?
8 Do not reveal discussions with
9 counsel.
11 Q. So you're not going to answer
12 that question?
13 A. I know it today.
14 Q. Okay. And were you -- are you
15 aware that Stephen Cutler also wrote -- and
16 let's go, actually, to the document itself.
17 So let's turn to the first of the exhibits,
18 the first of the backup documents, ending
19 7 -- 274561.
20 So you can see here an e-mail
21 from Stephen Cutler to James Condren, Jes
22 Staley, Mary Erdoes and Nina Shenker.
23 Correct?
24 A. Yes.
25 Q. Okay. And it's dated July 20,

1 2011, correct?
2 A. Yes.
3 Q. And do you recognize James
4 Condren's name?
5 A. No.
6 Q. We've talked about Mr. Staley
7 and Ms. Erdoes.
8 What about Nina Shenker, do you
9 recognize her name?
10 A. Yes.
11 Q. And what was her position at
12 JPMorgan in 2011?
13 A. I believe she was general
14 counsel of asset management.
15 Q. Okay. And you can see here
16 that Mr. Cutler wrote, "This is not an
17 honorable person in any way. He should not
18 be a client."
19 Correct?
20 A. Yes.
21 Q. Okay. And then let's go to the
22 second document, and that is Bates number
23 ending 35958_R.
24 A. Yes.
25 Q. And if you look at the top is

1 an e-mail from Stephen Cutler to Mary Erdoes,

2 correct?
3 A. Yes.
4 Q. And it's dated July 21, 2011,
5 correct?
6 A. Yes.
7 Q. And Mr. Cutler writes, on
8 number 1 -- "On 1, I would like to put it and
9 him behind us. Not a person we should do
10 business with, period."
12 A. Yes.
13 Q. Okay. And if we look -- hold
14 on one second.
15 Ah, yes. And if you can see
16 down at the bottom of this chain, you see
17 it's an e-mail from Jeffrey Epstein to Mary
18 Erdoes that is being forwarded, correct?
19 A. Yes.
20 Q. Okay. All right. Then let's
21 turn to what we will mark as Exhibit 15,
22 which is another demonstrative that we've
23 created. And with it are
24 JPM-SDNYLIT-00152756, 00194062, 00152738,
25 which is Langford 23.

1 And you know what? Let's --

2 you can sit down. While we're pulling those
3 together, let's do a couple of other
4 questions. I'm sorry.
5 Are you aware that Mr. Cutler
6 was deposed in this litigation earlier this
7 week?
8 A. Yes.
9 Q. And are you aware that he
10 testified under oath that Jes Staley and Mary
11 Erdoes made the decision to retain Jeffrey
12 Epstein as a customer of the bank?
14 You should not reveal any
15 knowledge that you obtained through
16 discussions with counsel.
18 Q. Can you answer the question?
19 A. What's the question again?
20 Q. Are you aware that Mr. Cutler
23 Epstein as a customer of JPMorgan?
24 MR. BUTTS: Same instruction.
25 THE WITNESS: Want an opinion?


2 Q. I'm asking if you --
3 MR. BUTTS: She's asking --
5 Q. -- know that Mr. Cutler
6 testified.
7 MR. BUTTS: -- if you're aware
8 of what she's purporting.
9 THE WITNESS: Mr. Cutler had
10 the ultimate authority to kick him out
11 if he thought it had gone that far.
12 He was delegating reputational
13 decisions to somebody else.
15 Q. So are you aware that he
18 Epstein as a customer of the bank?
19 A. I am not --
21 Mischaracterizes.
22 THE WITNESS: I'm not aware of
23 what he said or the context of what he
24 said or anything like that, so...
25


2 Q. Okay. But if he testified to
3 that, you believe that that was inaccurate?
5 You may answer.
6 THE WITNESS: I believe that he
7 also would have said that if he wanted
8 to, he could have made a definitive
9 judgment himself.
11 Q. And do you have any basis to
12 disagree, based on your personal knowledge,
13 that Jes Staley and Mary Erdoes were the ones
14 who decided to retain Mr. Epstein following
15 his indictment in 2006?
17 You may answer.
18 THE WITNESS: I had no personal
19 knowledge at the time.
21 Q. Okay. And Mr. Cutler also
22 testified under oath that he and the lawyers
23 and compliance staff who reported to him did
24 review Jeffrey Epstein at the time and did
25 not think he should be a customer of the

1 bank.
4 Q. Did you -- are you aware that
5 Mr. Cutler testified to that?
6 MR. BUTTS: If you -- are you
7 aware of any dis -- any content of
8 Cutler's deposition, one way or the
9 other, outside of discussions with
10 counsel?
11 THE WITNESS: Nope. I am not.
13 Q. Okay. Let's pull up,
14 Ms. Veldman, the deposition transcript.
15 And while we do that, do you
16 have any basis to disagree with Steve Cutler
17 that he and his team of lawyers and
18 compliance personnel did review Jeffrey
19 Epstein and did not want to retain him? Do
20 you have any personal knowledge of that?
21 MR. BUTTS: Objection. And you
22 should not reveal any discussions that
23 you had with counsel.
24 THE WITNESS: I have the utmost
25 respect for Steve Cutler. He's one of

1 the finest individuals and lawyers I

2 know. He had the ability to override
3 it. If he allowed them to make that
4 judgment, it's because he didn't step
5 in and say, you have to go. But he
6 could have done that.
8 Q. Okay.
9 A. That doesn't mean he did it.
10 Sometimes he's more advising a client about a
11 matter of judgment than he is making the
12 decision.
13 Q. So not the question I asked
14 you.
15 A. Have I read the --
16 MR. BUTTS: Hold on. I don't
17 think he was finished.
18 THE WITNESS: And if I read all
19 the transcript, I -- my guess would be
20 that would be in the transcript
21 somewhere.
22 MR. BUTTS: Okay.
24 Q. Okay. So what I asked you is,
25 do you have a basis to disagree with his

1 testimony that he and his compliance team

2 reviewed Jeffrey Epstein and did not want to
3 keep him as a customer of the bank?
4 MR. BUTTS: Objection. Asked
5 and answered.
6 And you should not reveal any
7 discussions that you've had with
8 counsel.
9 THE WITNESS: Yeah, I do not
10 know what he meant and what he said in
11 his testimony.
13 Q. I'm asking you, Mr. Dimon,
14 whether you have a basis to believe --
15 whether you have personal knowledge that
16 Steve Cutler and his compliance team did
17 anything other than -- had any view other
18 than a desire to terminate Jeffrey Epstein as
19 a customer of the bank.
21 Asked and answered.
22 You shouldn't reveal anything
23 you had with counsel, discussions with
24 counsel.
25 THE WITNESS: I trust Steve

1 Cutler's judgment.
3 Q. Are you aware -- I'm sorry, did
4 you finish?
5 A. No. Yeah, I did. Yeah.
6 Q. Okay. Are you aware of any
7 compliance or legal personnel at JPMorgan
8 prior to 2013 who supported the decision to
9 retain Jeffrey Epstein as a customer of
10 JPMorgan?
12 You should not reveal any
13 discussions you had with counsel in
14 connection with this litigation.
15 THE WITNESS: Yeah, I surely
16 didn't know at the time.
18 Q. I'm sorry?
19 A. I didn't know at the time, no.
20 Q. Okay. And do you know of
21 anyone as you sit here today?
23 instruction.
24 THE WITNESS: When we -- after
25 being briefed by my counsel.

1 MS. SINGER: I need to confer

2 for one minute.
3 All right. We're -- thank you.
4 Sorry about that.
5 I think we're going to need to
6 adjourn and call the Court for a
7 ruling on this issue.
8 MR. BUTTS: You want to call
9 the Court for a ruling on what our
10 discussions have been with Mr. Dimon?
11 MS. SINGER: No. I want a
12 ruling that he can testify as to his
13 own views and knowledge that aren't --
14 that do not consist of advice from
15 counsel.
16 MR. BUTTS: I -- he can testify
17 on his own views and knowledge, not on
18 the base -- knowledge based on
20 MS. SINGER: He can based on
21 facts that are -- he's aware of. It
22 doesn't matter if counsel showed it to
23 him.
24 But let's go off the record.
25 We're going to need to get a ruling

1 from the Court.

2 MR. BUTTS: No, let's keep
3 going. There is a long list --
4 there's a long line of people here.
5 Somebody else can go and do that.
6 You've got a fact witness. That's not
7 the only topic of your deposition.
8 Let's go.
9 MS. SINGER: He has not
10 answered numerous questions on your
11 advice and objections.
12 MR. BUTTS: So keep going with
13 something --
14 MS. SINGER: No. No.
15 MR. BUTTS: -- else while
16 somebody else --
17 MS. SINGER: No. No.
18 MR. BUTTS: -- goes and calls
19 the Court.
20 MS. SINGER: No. No. No. No.
21 MR. BOIES: No. No. She has a
22 right. She has a right to call the
23 Court on an instruction, and we have a
24 right to participate in that call.
25 So we can do this quickly.

1 Maybe the judge is not available, but

2 let's not waste time talking about it.
3 Let's let her make the call, and then
4 we'll see whether the judge can take
5 it or not.
6 MR. BOUCHOUX: Get the judge on
7 the line if he's going to be
8 available. Why waste time. Let's see
9 if he's available.
10 MR. BUTTS: There's many
11 lawyers here who can deal with a phone
12 call, and we can step out at an
13 appropriate time.
14 MS. SINGER: We need to get
15 advice. He's not answering numerous
16 questions, and we need to, to use
17 everyone's time mere productively, get
18 a ruling from the Court, if we can.
19 So let's go off the record,
20 please.
21 MR. BOIES: Yes.
22 VIDEOGRAPHER: We are going off
24 MR. BUTTS: Hold on a second.
25 We're not off the record.

1 MS. SINGER: We are.

2 MR. BUTTS: Okay. Are you on?
3 Okay.
4 So this is -- we've given you
5 an opportunity to use the time wisely,
6 to have one of the one, two, three,
7 four, five, six, seven lawyers on the
8 plaintiff side make the call with one
9 of the additional lawyers on our side,
10 and our view is the clock is running.
11 We'll do whatever you like, but the
12 clock is on.
13 MR. BOIES: Let's call the
14 judge and see whether the clock is
15 running. Okay? If you're going to
16 take that position --
17 MR. BUTTS: That's the
18 position.
19 MS. SINGER: I think the
20 witness should probably be excused for
21 the call.
22 MS. FRIEDMAN: Jamie.
23 (Off the record at 1:07 p.m.)


2 Q. All right. Mr. Dimon, you
3 recognize that banks have an obligation to
4 know their customer, correct?
5 A. Yes.
6 Q. And do you know if JPMorgan
7 ever examined Jeffrey Epstein's source of
8 wealth?
9 MR. BUTTS: And same
10 instruction. Generally not anything
11 you learned from us.
13 anything about Jeff Epstein when all
14 that stuff was taking place. I know
15 after the fact that they did some of
16 that.
18 Q. Okay. Do you -- did you know
19 prior to 2013 whether JPMorgan ever
20 investigated where Jeffrey Epstein's money
21 came from or who his clients were?
22 A. No.
23 Q. And have you since asked
24 your employees at JPMorgan where Jeffrey
25 Epstein's money came from?

1 MR. BUTTS: And instruction not

2 to answer to the extent your answer
3 would reveal discussions with
4 Ms. Friedman or her team.
5 THE WITNESS: No.
7 Q. All right. We'll come back to
8 that one.
9 Are you familiar -- or were you
10 familiar prior to 2013 with Ghislaine
11 Maxwell?
12 A. No.
13 Q. You hadn't heard her name prior
14 to 2013?
16 Q. Were you aware prior to 2013
17 that she was a customer of JPMorgan?
18 A. No.
19 Q. Did you become aware prior to
20 this litigation that a witness from JPMorgan
21 testified at Ghislaine Maxwell's criminal
22 trial?
24 Q. Were you -- did you learn prior
25 to this litigation that funds transferred by

1 Jeffrey Epstein from his JPMorgan account to

2 Ghislaine Maxwell at her JPMorgan account
3 were used to purchase a helicopter?
5 Q. Did you ever hear that Jeffrey
6 Epstein used a helicopter to transport girls
7 to his private island, Little St. James?
9 instruction about conversations with
10 counsel.
12 then, and I don't really know now.
14 Q. Okay. Have you ever heard the
15 name ?
18 identification.)
20 Q. Okay. We're going to show you
21 a picture to see if that ignites any
22 recognition.
23 Have you seen in the media or
24 otherwise this picture of and
25 Jeffrey Epstein in a helicopter, Mr. Dimon?


2 Q. Did you --
3 MR. BOIES: Have we marked this
4 as exhibit?
5 MS. SINGER: Yes, I'm sorry.
6 Thank you.
7 So to clean up some exhibits,
8 we're going to make the first CNN
9 interview we played Exhibit 15, the
10 second CNN clip will be Exhibit 16,
11 the Bloomberg clip will be 17, and
12 this photo will be Exhibit 18.
14 Q. So -- and I'm sorry, now I need
15 to remind myself.
16 Did you know that ,
17 this girl, was a customer of JPMorgan's
18 private bank through Jeffrey Epstein?
20 Q. Okay. So you obviously didn't
21 know she was a teenager when JPMorgan opened
22 that account?
23 A. Nope.
24 Q. Were you aware at any time
25 prior to this litigation that JPMorgan

1 transferred money from Jeffrey Epstein's

2 account to account in amount of
3 $36,000, roughly?
4 A. No.
5 Q. All right. We're going to go
6 back to what we'll mark as Exhibit 19.
7 MS. OLIVER: It was previously
8 marked as DeLuca 26.
9 MS. SINGER: Okay.
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2 ***END BSA SENSITIVE SECTION***

3 (Langford Exhibit 21
4 introduced.)
6 Q. Let's go to what was
7 Langford 21. We won't mark it.
8 So I'll represent to you that
9 Langford 21 is an exhibit that we've created,
10 not a JPMorgan document. It was created
11 based on documents we reviewed from JPMorgan,
12 and it compiles Epstein's payments to women
13 from his JPMorgan accounts between 2003 and
14 2013.
15 Just to be clear, since it's
16 been a long day already, you've never
17 reviewed Jeffrey Epstein's payments to women
18 or girls from his accounts at JPMorgan, is
19 that right, outside of conversations you've
20 had with counsel?
21 A. That is correct.
22 Q. Okay. However, these payments,
23 these wire transfers or checks, would have
24 been evident to JPMorgan at the time the
25 transfers were made, correct?


2 You may answer.
3 THE WITNESS: I mean, I don't
4 know what -- in what form or format,
5 but somewhere in JPMorgan -- if these
6 numbers are right, we would have known
7 somewhere, yes.
9 Q. And are you -- would you have
10 expected, given Jeffrey Epstein's criminal
11 history, that JPMorgan would have looked into
12 his transfers to women from his bank account?
14 You may answer.
15 THE WITNESS: Probably.
17 Q. And do you believe that given
18 Jeffrey Epstein's history, that JPMorgan
19 should have looked into the ages of the women
20 to whom he was transferring money?
22 You may answer.
23 THE WITNESS: I don't -- I
24 think maybe if they could have gotten
25 that information.


2 Q. We talked earlier about the
3 name .
4 Do you remember that?
5 A. Yes.
6 Q. Are you aware that
7 was a customer of JPMorgan? And
8 forgive me if I asked that earlier.
9 A. I was not aware.
11 identification.)
13 Q. I want to turn to a picture of
14 , please. And I want to see
15 if that --
16 A. Are you done with this one?
17 Q. -- refreshes your recollection.
18 We're done with that one, yes.
19 So we'll mark her picture as
20 Exhibit 19. And you can see it on your
21 screen, Mr. Dimon, in the meantime.
22 Does that refresh your
23 recollection? Are you familiar that that is
24 a woman, ?
25 A. Not that I can recall, no.

1 Q. Were you aware that prior to

2 2013 or 2015 that employees at JPMorgan
3 circulated her picture?
5 You may answer.
6 THE WITNESS: No.
8 Q. Were you aware that JPMorgan
9 made transfers from Jeffrey Epstein's account
10 to between 2004 and 2013?
11 A. No.
12 Q. I want to go back to Exhibit 3,
13 which hopefully still lives in your pile.
14 Actual Exhibit 3.
15 Exhibit 3 --
16 MR. BUTTS: Hold on. Give me a
17 second.
18 MS. SINGER: Okay.
20 Q. -- references -- we have it up
21 on the screen, too, if that helps -- payments
22 of 25,000 and $50,000 to .
23 You can see it about two-thirds of the way
24 down.
25 A. Yes.

1 Q. Did you know that JPMorgan was

2 aware of those payments back at the time of
3 this e-mail in 2007?
4 A. No.
5 ***BEGIN BSA SENSITIVE PORTION***
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24 Q. I want to pose a question to
25 you that was suggested by one of Epstein's

1 survivors who JPMorgan banked --

2 MR. BUTTS: All right. We
3 don't need the windup. Just give him
4 the question, please.
5 MS. SINGER: You can object,
6 John.
7 MR. BUTTS: I just did.
8 MS. SINGER: Okay.
10 Q. She wanted to know -- so let me
11 set up this question.
12 For women who JPMorgan banked
13 or to whom it sent money from Jeffrey
14 Epstein's accounts, she wanted to know why
15 JPMorgan never reached out to her to ask what
16 was going on and whether she was okay.
19 Q. Do you think JPMorgan should
20 have reached out to her and other women to
21 whom it was sending money from Jeffrey
22 Epstein to find out what was going on?
25 THE WITNESS: I'm going to give

1 you two answers. I mean, I'll give

2 you one.
3 I mean, you -- I want you to
4 know, I want her to know, how
5 disgusted I am over all this. I wish
6 we were never involved with this
7 despicable human being. I hope she
8 gets justice against the people who
9 perpetrated the crime, which was not
10 us.
11 And the people who were -- the
12 question you just asked -- is the
13 question, is the issue that it was
14 dealt with by top people that we hired
15 from the DOJ and the SEC, people that
16 maybe some of the lawyers in this room
17 know, who is as respected as they
18 come, who were making judgments at
19 that time about what the right thing
20 to do is based on all the information
21 they had.
23 Q. So I'm asking you, Mr. Dimon,
24 sitting here, do you think JPMorgan should
25 have reached out to her and the other women

1 to whom you sent checks from Jeffrey

2 Epstein's account or for whom he paid in
3 cash, should you have asked these women who
4 were known to you, are they okay, or what is
5 going on?
7 You may answer again.
8 THE WITNESS: I've already
9 answered it.
10 MS. SINGER: I don't think you
11 have.
12 MR. BUTTS: He did.
13 THE WITNESS: I've already
14 answered it.
16 Q. So the other question that she
17 had was whether certain customers of JPMorgan
18 matter than other -- matter more than other
19 customers of JPMorgan.
20 How do you answer that
21 question?
23 You may answer.
24 THE WITNESS: I feel terrible
25 about anyone who was abused, man or

1 woman, for any reason at all. And I

2 would expect that we would treat them
3 all the same, which is respectfully
4 and decently, and do our job as best
5 as we can.
6 We do bank 30 million people,
7 and so I don't know all those
8 decisions people make of when they do
9 things and when they don't and what
10 all the facts that are in front of
11 them that make them do those things.
13 Q. But you --
14 A. And my heart goes out to these
15 women. It really does. And you can ask me
16 85 different ways.
17 We did -- you know, a lot of
18 the information you asked for did go to the
19 legal profession and did go to the law -- you
20 know, the law and enforcement, and they had
21 ample opportunity to do a lot of things, too.
22 So we were trying to do our job
23 as best as we can. And of course we are not
24 the law -- the legal profession. We are not
25 law enforcement.

1 Q. So then I'm asking about you as

2 the CEO and chairman of JPMorgan.
3 Do you think that you acted
4 respectfully towards these women who received
5 the payments that JPMorgan didn't look into?
6 MR. BUTTS: Objection. Assumes
7 facts. Asked and answered.
8 THE WITNESS: Are you asking
9 you or --
10 MS. SINGER: I'm asking you,
11 Jamie Dimon.
12 THE WITNESS: Jamie Dimon.
13 What's the question again?
15 Q. Do you think JPMorgan acted
16 respectfully or decently -- I'm trying to use
17 your adjectives -- towards these women --
18 MR. BUTTS: Hold on a second.
19 Are you finished with your
20 question?
21 MS. SINGER: I am.
23 You may answer.
25 JPMorgan did, so I can't answer that

1 question.
3 Q. Mr. Dimon, are you aware
4 that -- I think you testified earlier that
5 for good reason you did not review the
6 decision to retain customers with criminal
7 histories.
8 Is that accurate?
10 Q. Okay. Do you recall reviewing
11 the decision of whether to retain
12 as a customer of JPMorgan?
13 A. .
14 Q. .
15 A. I did not make that decision.
16 I do remember being asked if I'd have an
17 objection if we brought him back as a client.
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6 MS. SINGER: Okay. All right.
7 I want to be respectful of Mr. Boies'
8 time, so we're going to switch over
9 with a caveat that I will reserve time
10 for a call to the Court later, if
11 needed.
12 VIDEOGRAPHER: Go off the
13 record while we switch?
14 MS. SINGER: Yes.
16 record. Time is 1:56.
18 VIDEOGRAPHER: We are going
19 back on record. The time is 1:59.
21 QUESTIONS BY MR. BOIES:
22 Q. Good afternoon, Mr. Dimon.
23 As you know, I'm David Boies,
24 and I represent the Doe plaintiffs here.
25 When did you first hear of

1 Jeffrey Epstein?
2 A. I recall not hearing about
3 Jeffrey Epstein until about 2018 or sometime
4 in 2019 when the story blew wide open. He
5 was arrested, and all the stories came out
6 about all the people he knows.
7 And the reason I remember that
8 is I was surprised that I didn't know about
9 it before.
10 Q. I think that would have been
11 probably 2019 when he was arrested. And -- I
12 think it was July of 2019.
13 And before he was arrested, you
14 hadn't ever even heard the name Jeffrey
15 Epstein.
16 Is that right?
18 Q. Now, did there come a time --
19 and I'm not going to be asking you about what
20 you learned in connection with the
21 litigation, but I do want to ask you what you
22 learned after 2019 in your capacity as
23 chairman and chief executive officer of the
24 bank.
25 There came a time when you

1 understood that Jeffrey Epstein had been a

2 customer of JPMorgan, correct?
3 A. To my great chagrin, yes.
4 Q. And was that after he was
5 arrested?
6 A. I don't recall the exact date.
7 Q. Well, just in terms of timing,
8 if you never heard of him before he was
9 arrested, you wouldn't have known he was a
10 customer of the bank until he was -- after he
11 was arrested; is that fair?
12 A. I don't know when the stories
13 came out and when the arrest took place, but
14 somewhere around then.
15 Q. And the stories that you're
16 talking about are the stories about how
17 widespread his contacts were in the financial
18 industry, things like that.
19 Is that right?
21 You may answer.
22 THE WITNESS: Yeah. That's
23 what I recall, yeah.
25 Q. How did you find out that he

1 was -- had been a customer of the bank?

3 Q. Did somebody from the bank tell
4 you that?
5 A. Most likely my general counsel
6 right there.
7 Q. Now, when you found out that
8 this person had been a customer of the bank
9 and you found out that he had been engaged in
10 this sex trafficking, did you, in your
11 capacity as chief executive officer and
12 chairman of the bank, try to find out what
13 the facts had been concerning the bank's
14 relationship to Mr. Epstein?
16 And for the moment, I'll let
17 you do a yes -- a yes or no answer to
18 the question.
19 THE WITNESS: What is the
20 question again?
22 Q. After you found out that
23 Jeffrey Epstein existed, that he'd been a sex
24 trafficker and he'd been a customer of the
25 bank, did you, in your capacity as CEO and

1 chairman, want to find out what the

2 circumstances were concerning the bank's
3 relationship to this man?
4 MS. FRIEDMAN: Can I just -- I
5 just want to make sure of privilege.
6 THE WITNESS: This is
7 privileged, yeah. I can --
8 MS. FRIEDMAN: Just give me a
9 minute.
10 MR. BUTTS: Okay. Yeah, so you
11 should not reveal anything you learned
12 or -- in connection with Ms. Friedman,
13 her staff or outside counsel.
14 THE WITNESS: Okay. What --
15 MR. BOIES: Remember, all I
16 asked him is whether he wanted to find
17 out. It's a yes or no question.
18 MR. BUTTS: Okay. I'll give
19 you that yes or no. That's fine.
20 MS. FRIEDMAN: We're fine.
21 THE WITNESS: The protocol,
22 what I did, was I asked my general
23 counsel there, do what you got to do.
24 Do everything.
25 It wasn't about whether I had

1 personal knowledge. It was about

2 whether we, the company, were doing
3 the right things.
4 MR. BUTTS: Okay.
5 THE WITNESS: And then after
6 that, she did give me some of that
7 information I didn't have before.
9 Q. In order to determine whether
10 the company was, in your words, doing the
11 right thing, did you, as chairman and chief
12 executive officer, want to know what the
13 facts were?
14 MR. BUTTS: Did you want to
15 know what the facts were.
16 THE WITNESS: Did I want to
17 know?
18 I wanted to know what I should
19 know. I didn't spend hours and hours
20 going through "the facts."
22 Q. Well, when you say you wanted
23 to know what you should know, what did you
24 think you should know?
25 A. That the company was properly

1 working with law enforcement, that we should

2 look -- that we should make sure that it's in
3 the general counsel's court and not somewhere
4 in the bowels of the company, and if there
5 were lessons learned, we should deploy those,
6 too.
7 Q. Okay. Now, in terms of lessons
8 learned and deploying those lessons, did you
9 make an attempt to find out whether there
10 were lessons to have been learned from this
11 experience that would change your business
12 practices?
13 A. Well, we're still in the
14 process because we're obviously -- I'm being
15 distracted doing this today, but I have never
16 in my life not experienced a thing where you
17 don't learn lessons and try to do better in
18 the future than you did in the past.
19 Q. I agree with that.
20 And what did you do -- and
21 again, I'm not asking you about what you did
22 in this litigation and what you did for this
23 litigation.
24 I'm simply asking, what did you
25 do for your business? What did you do as


2 bank to improve things, to make things
3 better, to learn from what happened here?
5 You may answer.
6 THE WITNESS: I asked my
7 general counsel, do you -- are you
8 doing all the things you need to be
9 doing? When there are lessons
10 learned, let's share them. We can do
11 a better job going forward.
12 We've already -- she already
13 had some comments, had some things we
14 might have learned. I still expect to
15 be doing that.
16 I would expect that when this
17 is said and done, we will have the
18 best -- you know, we want to improve
19 and be at the highest standards on
20 anything relating to human
21 trafficking. And anything we can
22 improve, we will improve.
24 Q. And --
25 A. And we cannot do law

1 enforcement's job.
2 Q. Well, and you keep talking
3 about doing law enforcement job, and now I
4 just want to be clear.
5 I'm not asking you anything
6 about law enforcement here. I'm just trying
7 to talk to you about the bank.
8 A. Uh-huh.
9 Q. And in terms of trying to
10 figure out whether you ought to continue to
11 do business with people that end up being sex
12 traffickers, you end up knowing that they've
13 been sex traffickers, did you want to consult
14 anybody other than your general counsel?
16 You may answer.
18 Q. That's just a yes or no
19 question, sir.
20 A. I have complete trust in my
21 general counsel, and I vaguely recall asking
22 her to make sure that she had the right
23 experts.
24 Q. I'm not suggesting you
25 shouldn't have great confidence in your

1 general counsel.
2 What I'm asking you is whether
3 it ever occurred to you that this was
4 something other than a legal problem, that
5 this was a problem that needed to be
6 addressed other than simply by talking to
7 lawyers.
9 You may answer.
10 THE WITNESS: I asked her to do
11 exactly what you just said - not as a
12 legal matter, as a matter representing
13 working for the company to try to make
14 sure we set best standards.
15 She's still in the middle of
16 doing that.
18 Q. And has she -- and again, not
19 as a legal matter but as best practices for
20 the company, has she given you some feedback,
21 some interim feedback, so far?
22 A. A little bit, mostly as a
23 result of this case.
24 Q. How has this case affected the
25 business judgment as to how the company ought

1 to operate?
2 A. We are looking at all the de --
3 I can repeat this over and over. Looking at
4 all the details of this case, I'm expecting
5 my general counsel, in consultation with
6 everyone she needs consult, to talk about not
7 just a legal matter, what are the things that
8 we can do, what can go wrong, what can go
9 right, are there things that we should we
10 adopting so we can have the best standards in
11 anti-money laundering in general, human
12 trafficking, et cetera.
13 That will take place, and
14 hopefully one day you will be very proud of
15 it, too.
16 Q. Okay. Well, I thank you.
17 And I should say that I'm not
18 meaning to suggest that this is a unique
19 problem for your bank. The -- this is a --
20 this is a problem generally.
21 But what I'm -- what I'm trying
22 to get at is, what are you doing, or what are
23 you -- or maybe a better question.
24 What do you think you ought to
25 do to have better controls?


2 and answered.
3 THE WITNESS: I want you to
4 review controls at banks around the
5 world, other people, what we've done
6 and haven't done, best practices, what
7 we're allowed to do, what we're not
8 allowed to do. And when you're ready,
9 Stacey, come back to me and talk to me
10 about it. Have other people in the
11 room that would be happy to do it.
13 Q. When did you --
14 A. It's called delegation. I
15 can't do that myself.
16 Q. Okay. When did you first ask
17 your general counsel to begin this project of
18 identifying best practices and how you could
19 improve controls?
20 A. Well, we've been doing it my
21 whole career when it comes to multiple
22 things, including AML. The laws change, the
23 requirements change, the regulations change.
24 About this particular matter?
25 About anything relating to the human

1 trafficking? I think that came up because of

2 this case.
3 Q. And this case was filed a few
4 months ago; is that correct?
6 THE WITNESS: I meant it came
7 up as a result of the Epstein
8 indictment, suicide.
10 Q. Okay. Now, focusing on what
11 you did before this litigation was filed,
12 before the litigation was filed against Chase
13 Bank, before that litigation was filed, were
14 you concerned that the bank had any legal
15 liability for what happened?
17 And you should not reveal any
18 information or view you had based on
20 MR. BOIES: This is still just
21 a yes or no question.
22 MR. BUTTS: It was not a yes or
23 no question. You asked him about
24 concern about legal liability.
25 MR. BOIES: Well, I said did he

1 have any.
2 MR. BUTTS: Yeah. Well, and
3 baked into the assumption of that is
4 going to reveal information.
5 And if so, if you have a view
6 that is informed by your discussions
7 with counsel, you should not share.
8 THE WITNESS: I had discussions
9 with counsel about liability, what we
10 should be doing generally. We did not
11 commit the crime, so I wasn't
12 concerned about that.
14 Q. Well, were you concerned about
15 civil liability?
17 caution.
18 THE WITNESS: That -- yeah, I
19 have -- I have conversations with
20 counsel about things like that all the
21 time.
23 Q. My question to you, sir, is in
24 between the time that you first heard of
25 Jeffrey Epstein and the time that the bank

1 was sued in this litigation, did you have a

2 concern that the bank had civil liability?
3 MR. BUTTS: And, again, the
4 same instruction.
5 THE WITNESS: I answered that
6 by saying I asked my general counsel,
7 should we be concerned.
8 MR. BUTTS: And you
9 shouldn't -- go no further.
11 Q. When --
12 A. That's how I find out. I can't
13 know.
14 Q. When did you first -- when did
15 you first ask your counsel whether you should
16 be concerned, as you put it, about possible
17 civil liability for the bank's work with
18 Jeffrey Epstein?
19 A. I'll correct that. Concerned
20 about anything, but I don't remember the
21 date.
22 Q. Approximately?
23 A. I literally don't remember the
24 date.
25 Q. Was it before we actually sued

1 the bank?
2 A. I really don't recall. I
3 would -- I would think it might have been,
4 but I don't recall specifically.
5 Q. Would it be fair that this
6 inquiry that you made to your general counsel
7 would have been either in 2021 or 2022, not
8 before that?
9 A. I don't recall. I'm not trying
10 to be evasive. I just don't recall.
11 Q. Some of us nowadays measure
12 time as before and after the pandemic.
13 Was this inquiry that you made
14 to your general counsel about whether the
15 bank had any civil liability for its work
16 with Jeffrey Epstein before or after the
17 pandemic?
19 Mischaracterizes his testimony.
20 You may answer.
21 THE WITNESS: Yeah, I'm not
22 sure I specifically was asked about
23 civil liability. Just look at this,
24 risks, et cetera.
25 But I don't remember.


2 Q. I may have misunderstood. I
3 thought you said that you had asked your
4 general counsel, should we be concerned about
5 civil liability in connection with Jeffrey
6 Epstein.
7 A. I did say that. But I'm saying
8 I asked a more generic question. Should we
9 be concerned. Let's get on top of this.
10 Let's understand all the issues, et cetera.
11 Yeah.
12 Q. And what I'm asking is, did
13 that conversation happen before or after the
14 pandemic?
15 A. I've been working the whole
16 time, so you may make that distinction. It's
17 hard for me to make that distinction.
18 I just don't recall.
19 Q. Okay. Have you, in your
20 capacity as chairman and chief executive
21 officer of the bank, since you first heard of
22 Jeffrey Epstein, learn facts that have caused
23 you to believe that the bank should do
24 something different in the future than it has
25 done in the past?


2 And you should not answer to
3 the extent you're revealing
5 THE WITNESS: They were all
7 MR. BOIES: My question doesn't
8 have to do with conversations with
9 counsel.
10 MR. BUTTS: Apart from
11 conversations with counsel, has he
12 learned anything?
13 MR. BOIES: No. My question is
14 whether or not in his capacity as
15 chairman and chief executive officer
16 of the bank, has he learned facts --
17 MR. BUTTS: Right.
18 MR. BOIES: -- that has led him
19 to conclude that the bank should do
20 something different in the future than
21 it has in the past.
22 MR. BUTTS: And my instruction
23 was because in his capacity as
24 chairman and chief executive officer
25 of the bank he obtains legal advice,

1 and has obtained legal advice, and we

2 just got a ruling that that is not
3 fair game for this deposition.
4 If you have a question apart
5 from counsel, you're welcome to ask
6 it.
7 MR. BOIES: Let me ask the
8 question again --
10 MR. BOIES: -- because I
11 don't -- I don't think this is one
12 that the judge ruled on.
15 Q. Have you, in your capacity as
17 bank, concluded that as a result of anything
18 that you have learned in connection with
19 Jeffrey Epstein and the bank's relationship
20 with him, that the bank should do something
21 different as a business matter with its
22 business procedures than it has in the past?
23 MR. BUTTS: And the same issue.
24 You should not reveal to the extent --
25 you can reveal to the extent it is not

1 from -- in connection with legal

2 advice, particularly in connection
3 with this litigation.
5 MR. BOIES: Would you mark that
6 so we can --
7 MR. BUTTS: Yeah.
8 MR. BOIES: -- come back to
9 that?
10 MR. BUTTS: Sure.
11 THE WITNESS: Can I say that
12 unfortunately this area is in her
13 area. So all the conversations I have
14 about this kind of thing is with my
15 general counsel, who has ultimate
16 responsibility also for compliance,
17 legal matters and, at the end of the
18 day, reputational matters.
19 If you ask me about risk in
20 China, that's a conversation with the
21 head of risk. Or if you ask me about
22 financial matters or investment
23 matters, I have it with other people.
24 But this particular thing is
25 her responsibility. So you're asking

1 me questions that she's the first

2 person I would go to in almost any
3 matter like this.
4 And, yes, I think there are
5 things we learned, but that's part of
6 this case.
8 Q. And what I'm asking you about
9 is whether you believe that the bank ought to
10 change not its legal work --
11 A. I understand.
12 Q. -- but its business procedures
13 and whether you reached that conclusion as a
14 result of the Jeffrey Epstein experience.
15 A. Only after consultation with my
16 general counsel. But at the end of the day,
17 I think that will happen. Maybe it's already
18 happened a little bit, so...
19 Q. What has happened so far?
20 A. Well, only after consultation
21 with my general counsel. But you -- I've
22 used the word "heightened standards." I'll
23 let her, if you want -- I can't talk any more
24 about it because that was a conversation with
25 my general counsel.

1 Q. Well, when you talk about

2 heightened standards, you're taking about how
3 you operate your business, correct?
4 A. Well, define "business" for me.
5 Q. You define "business" for me.
6 You're the -- you're the lawyer -- you're the
7 witness.
8 A. This is matters of compliance,
9 reputational risk, legal risk. The ultimate
10 arbiter is the general counsel.
11 There are other business
12 matters, like I've said, around finance,
13 investments, lending, China, European
14 regulations, which are not in her court.
15 Q. Is it your testimony that the
16 issue of reputational risk and, for example,
17 whether you're being a banker to sex
18 traffickers is something that is exclusively
19 in the arena for the general counsel to
20 decide?
21 A. As a matter of ultimate
22 responsibility, not that other people don't
23 get involved, the answer is yes.
24 And then to me, of course,
25 but...

1 Q. Well, that's what I'm trying to

2 get at, the then to you, of course.
3 You, as the chief executive
4 officer, have got a responsibility to
5 determine what controls the bank has about
6 dealing with sex traffickers, correct?
7 A. Ultimately, yes.
8 Q. And I think it's fair to say --
9 correct me if I'm wrong, but I don't think
10 I'm wrong -- from some of the things you've
11 said, is you don't believe that the bank as a
12 business matter -- regardless of what the law
13 says, you don't think the bank as a business
14 matter ought to be dealing with sex
15 traffickers, correct?
17 THE WITNESS: That's too broad
18 a statement.
20 Q. What?
21 A. That's too broad a statement.
22 Q. Okay.
23 A. And as a -- again, as a
24 matter -- everything you're asking me is all
25 legitimate, but if you were my general

1 counsel, I'd be asking you to do those

2 things. Make the determinations. Put the
3 rules in place. Get the process in place.
4 Hire the right people.
5 Q. I understand you've got a lot
6 of confidence in your general counsel, but
7 you're the chief executive, right?
8 A. Uh-huh.
9 Q. And you've got the ultimate
10 responsibility for how the bank operates,
11 correct?
12 A. Ultimately, yes. Well, the
13 board ultimately, but, yeah.
14 Q. And what I'm asking is, what,
15 if anything, have you done to make sure that
16 the bank doesn't do business with sex
17 traffickers?
20 Q. Other than ask your general
21 counsel.
23 You may answer.
24 THE WITNESS: Ready? Don't do
25 business with sex traffickers. That's

1 what I did.
2 MS. FRIEDMAN: Let's take a --
3 let's take a five-minute break. Yeah.
4 MR. BOIES: Now --
5 MR. BUTTS: David, we have been
6 going a bit. There was a transfer
7 there. Let's take five, and we'll
8 come right back.
9 MR. BOIES: Okay. Sure.
10 MR. BUTTS: Okay?
11 VIDEOGRAPHER: All right. We
12 are going off record. The time is
13 2:22.
15 VIDEOGRAPHER: We are going
16 back on the record. The time is 2:29.
18 Q. Let me ask you about some
19 people.
20 Do you know a Paul Morris?
22 and answered.
24 recall.

1 identification.)
3 Q. Let me ask you to look at a
4 document that has been previously marked as
5 Exhibit 114.
6 And the e-mail I'm interested
7 in is the e-mail at the top which is from
8 Paul Morris to Jeffrey Epstein, dated
9 June 30, 2012, at 1:49 a.m.
10 Do you see that e-mail?
11 A. Yes.
12 Q. And it's a short e-mail, and
13 I'll just read it for the record.
14 "Jeffrey, sorry for being so
15 limited on the e-mails, but I guess I'm too
16 discrete. Anyway, I really appreciate
17 everything you're doing, and this is a
18 fantastic opportunity that you are opening
19 the door to. I briefed our CEO, and I think
20 he will get a sense of the relationship
21 over the weekend. Come back to you ASAP, and
22 thank you again. Paul Morris, JPMorgan
23 private bank."
24 Did Mr. Epstein help JPMorgan
25 develop a relationship with ?


2 You may answer.
3 THE WITNESS: I don't know if
4 that's what refers to.
5 We've -- I've known
6 for -- way before this, and the
7 company has been doing business with
8 for a long time. So we didn't
9 need his introduction.
11 Q. You know Mr. ?
12 A. I do know Mr. .
13 Q. Have you --
14 A. This could have been
15 , and the was unlikely not me --
16 was likely not me.
17 MR. BUTTS: The testimony has
18 been it's not you.
19 THE WITNESS: Right.
21 Q. Did you ever discuss
22 Mr. Epstein with Mr. ?
23 A. No.
24 Q. When was the last time you
25 talked to Mr. ?

1 A. Three or four years ago.

2 Q. Prior to the time that
3 Mr. Epstein was arrested?
4 A. I don't recall the exact date.
5 Q. You're aware of press reports
6 linking Mr. to Mr. Epstein, are you?
7 A. Yes.
8 Q. Did you have any discussion
9 with Mr. after those press reports?
11 Q. Did you ever discuss those
12 press reports with Mr. ?
13 A. No, not that I recall.
14 Q. Who was responsible for the
15 relationship with the bank?
16 A. Until Jimmy Lee died, it was
17 probably Jimmy Lee. After that, I believe it
18 was Carlos Hernandez.
19 There are lots of people
20 involved in the relationship with a group as
21 large as . I mean, literally a
22 hundred.
23 Q. In addition to the work with
24 , did JPMorgan do business with
25 personally?

1 A. I don't recall specifically,

2 but I would not be surprised.
3 Q. And do you know who was
4 responsible for that relationship?
6 You may answer.
8 know who would be the direct banker on
9 that relationship, if he -- if we had
10 a private banking relationship.
12 Q. Do you know who Lanny Davis is?
13 A. Yes. He's a lawyer.
15 identification.)
17 Q. Let me ask you to look at
18 Exhibit 138. This is an e-mail that
19 Mr. Davis sent you on January 9, 2015, at
20 8:39 p.m.
21 Do you see that?
22 A. Yes.
23 Q. Do you recall receiving this
24 e-mail?
25 A. No.

1 Q. Do you have any reason to doubt

2 you did not receive the e-mail?
4 You may answer.
5 THE WITNESS: I don't know if I
6 read it, but I will assume it was sent
7 to my e-mail account.
9 Q. Let me ask you to look at the
10 fifth paragraph down where this says,
11 "Several years ago, two anonymous underage
12 girls filed suit against the federal
13 government for agreeing to a guilty plea by
14 billionaire investor Jeffrey Epstein without
15 consulting with the two child victims,
16 allegedly in violation of a victim's rights
17 law."
18 Do you see that?
19 A. Yes.
20 Q. Do you recall Mr. Davis writing
21 you in 2015 about Jeffrey Epstein?
22 A. I do not.
24 identification.)
25


4 Exhibit 155.
5 First, do you know who
6 is?
7 A. I do not. Or I don't recall.
8 Q. In the middle of the first page
9 of Exhibit 155, there is an e-mail from
10 Jeffrey Epstein to dated
11 February 19, 2013, at 6:08 a.m.
12 Do you see that?
13 A. I see a -- oh, yeah, I see it.
14 Yeah.
15 Q. And the entire text of that
16 e-mail from Mr. Epstein to Mr. is,
17 quote, "If your boy wants Jamie Dimon, easy,"
18 close quote.
19 Do you see that?
20 A. Yes.
21 Q. Do you have any idea what
22 Mr. Epstein was referring to there?
24 You may answer.
25 THE WITNESS: I don't.


2 identification.)
4 Q. I'm going to ask you to look
5 next at Exhibit 104 -- 101.
6 This is an exchange of e-mails
7 between Mr. Staley and Mr. Epstein on
8 June 17, 2009.
9 Mr. Epstein writes Mr. Staley.
10 " will be staying at 71st Street over
11 the weekend. Do you want to organize either
12 you, or you and Jamie, quietly? Up to you."
13 Do you see that?
14 A. Yes.
15 Q. Did you meet with Mr. Epstein
16 and/or Mr. Staley at 71st Street over the
17 weekend?
18 A. Absolutely not.
19 Q. Do you know what Mr. Epstein is
20 referring to here?
21 A. I think I've testified many
22 times, I didn't know Jeff Epstein. I never
23 met Jeff Epstein. I never went to his house.
24 I never went to his island. And I do not
25 know exactly what he's referring to here.

1 Maybe -- I mean, I can surmise

2 that he wanted Jes to introduce me to him --
3 introduce me to him.
4 Q. Now, Mr. Staley responds the
5 next day to Mr. Epstein, saying, "Jamie is in
6 Asia. I just got back from London, and I'm
7 in Boston. Let me what's up for the weekend.
8 If I'm in the city, for sure."
9 Do you have any explanation as
10 to why Mr. Staley would write that e-mail if
11 you had no contact at all with Mr. Epstein?
15 THE WITNESS: I have no idea.
17 identification.)
19 Q. Let me ask you look -- to look
20 next at the document that's been previously
21 marked as Exhibit 102.
22 And do you know who Lesley
23 Groff is, by any chance?
25 Q. Have you seen her mentioned in

1 connection with Mr. Epstein?

2 A. No.
3 Q. Are you aware of whether or not
4 she worked for Mr. Epstein?
5 A. Nope.
6 Q. On February 26, 2010, Lesley
7 Groff writes Mr. Epstein on the subject of
8 , Jes and Jamie. "Shall I have Lynn
9 prepare heavy snacks for your evening
10 appointments with , Jes Staley
11 and Jamie Dimon? Or is this to be a nice,
12 sit-down dinner at 9 p.m.?"
13 And Mr. Epstein replies,
14 "Snacks."
15 Do you see that?
16 A. Yes.
17 Q. Did you in fact have an
18 appointment with , Jes Staley
19 and Jamie Dimon?
20 A. I have never had an appointment
21 with Jeff Epstein. I've never met Jeff
22 Epstein. I never knew Jeff Epstein. I never
23 went to Jeff Epstein's house. I never had a
24 meal with Jeff Epstein. I have no idea what
25 they're referring to here.

1 I did know , and

2 obviously I knew Jes.
3 Q. Do you have an explanation why
4 Lesley Groff would have written this e-mail?
6 You may answer.
7 THE WITNESS: Likely
8 misinformed. Not likely.
9 Misinformed.
11 Q. Now, Mr. Epstein does not write
12 back to her saying, you're misinformed, Jamie
13 Dimon is not coming.
14 You see that?
15 A. I don't know what he thought at
16 the time. He was obviously misinformed. I
17 never -- this never took place.
18 Q. Okay. Did Mr. Epstein arrange
19 for you to meet with ?
20 A. Who?
22 You may answer.
23 THE WITNESS: Who?
25 Q. .

1 A. I don't think Jeff Epstein ever

2 arranged for me to meet with anybody, to my
3 knowledge. And I knew . We did
4 not need introductions to anybody.
6 identification.)
10 Exhibit 113.
11 This is a series of e-mails.
12 The one at the bottom, January 23, 2008, at
13 12:44 p.m., says, "Hello Rosa, I think
14 may have already e-mailed you, but wanted to
15 follow up just in case. Jeffrey was talking
16 to me on the phone and to who was
17 standing with him at the same time, so not
18 sure which one of us was actually to e-mail
19 you. Jeffrey requested that we give you the
20 contact e-mail for so that you
21 could organize the meeting with Jamie Dimon
22 and on your end for simplification."
23 And then Rosa writes to Jes
24 Staley, "Jes, is it okay for me to contact
25 directly to arrange a meeting with

1 Jamie?"
2 And Jes Staley responds, "Go
3 through Jamie's office."
4 Do you see that?
5 A. Uh-huh.
6 Q. And did Rosa M. da Silva go
7 through your office to arrange a meeting with
8 ?
9 A. It would almost certainly have
10 to have gone through my office. I don't
11 know -- I've met with . I don't
12 know -- I don't need a Jeff Epstein to meet
13 with , so I don't know what he had
14 to do with all of that, but I have met with
15 him a couple of times.
16 MR. BUTTS: He being
17 ?
18 THE WITNESS: , yeah.
20 identification.)
23 Exhibit 154.
24 Exhibit 113 that we were just
25 looking at before was dated back in 2008.


2 A. Say it again?
3 MR. BUTTS: We don't have the
4 document yet.
5 MR. BOIES: The exhibit we were
6 looking at before.
7 MR. BUTTS: 113?
8 MR. BOIES: 113.
10 Q. That's from 2008.
11 Do you see that?
12 A. Yes.
13 Q. Okay. Now we're going to jump
14 ahead to 2013.
15 And at the bottom of the first
16 page, there is an e-mail to you from
17 dated January 29, 2013.
18 Do you see that?
19 A. Yes.
20 Q. Where he says, "Dear Jamie, I
21 really enjoyed our short conversation."
22 Do you see that?
23 A. And then there's an e-mail on
24 January 29th of 2013, at 12:37 p.m., from
25 e-mail address to Jeffrey

1 Epstein, "Can your secretary find the e-mail

2 address of Jamie?"
3 Do you see that?
5 You may answer.
6 THE WITNESS: That's from who?
7 That's ?
9 Q. Yeah, that's the -- that's the
10 e-mail address that -- from which
11 e-mail to you at 10:32 a.m. had come
12 from, correct?
14 You may answer.
15 THE WITNESS: I don't -- I
16 assume it is, but I don't understand.
17 This is to Jeff Epstein.
19 Q. Let me go back to Exhibit 113.
20 Maybe we can clear up this.
22 THE WITNESS: He already
23 e-mailed me. I don't know why he was
24 calling and asking for my e-mail
25 address.

1 MR. BUTTS: He's going to

2 get -- Mr. Boies is going to give you
3 another question from 113.
6 Q. Do you see 113 again?
7 A. Yeah.
8 Q. The last paragraph, remember we
9 had this -- we directed your attention --
10 "Jeffrey requested that we give you the
11 e-mail for so you can organize the
12 meeting with Jamie Dimon and ."
13 A. Yeah.
14 Q. And it then goes on to say,
15 " handles itinerary.
16
17
18 "
19 Do you see that?
20 A. Yes.
21 Q. And that is the e-mail
22 address -- that's the e-mail
23 address, --
24 A. Yeah.
25 Q. -- that writes to Jeffrey

1 Epstein on January 29, 2013, at 12:37 p.m.,

2 "Can your secretary find the e-mail address
3 of Jamie?"
4 Do you see that?
5 A. Yes.
6 Q. And then --
7 A. I don't understand the times in
8 this thing, but, okay. But, yeah, go ahead,
9 yeah.
10 Q. I think it has two different
11 time zones.
12 A. Okay.
13 MS. FRIEDMAN: No, I think the
14 point is that he doesn't have Jamie's
15 contact information.
17 Q. Then Jeffrey Epstein responds,
18 "Get from Rosa."
19 Do you see that?
20 A. Yes.
21 Q. And then Lesley Groff sends to
22 Jeffrey Epstein on January 29, 2013, at
23 5:09 p.m., "Will you send the below to ?"
24 And it is your e-mail address,
25 correct?

1 A. Yes.
2 Q. Do you have any reason to doubt
3 that Mr. Epstein was getting your e-mail
4 address for ?
6 You may answer.
7 THE WITNESS: It looks like he
8 was asking Jes's office who he can
9 call to contact me.
10 MS. FRIEDMAN: He doesn't know
11 him.
13 Q. The -- who was asking Jes's
14 office?
16 THE WITNESS: You tell me.
18 Q. Well, you say, "It looks like
19 he was asking Jes's office who he can call to
20 contact me."
21 A. Right. So, I mean,
22 was told to get it from Rosa, who I think was
23 Jes Staley's secretary.
24 MR. BUTTS: You're asking him
25 to read an e-mail and interpret an

1 e-mail that he's not on.

3 MR. BUTTS: I think it's a
4 difficult thing to do.
5 MR. BOIES: I didn't actually
6 ask him to do that.
7 MR. BUTTS: Well, it seems
8 otherwise.
9 MR. BOIES: All I'm doing is
10 following up a statement that he made.
11 MR. BUTTS: Okay.
12 THE WITNESS: Okay. Go ahead.
14 Q. What you said, "It looks like
15 he is asking."
16 Who is the "he" there?
17 MR. BUTTS: Yeah --
18 THE WITNESS: Well, the
19 ultimate he or she was the ,
20 who was asking Rosa for my e-mail.
21 That's what it says to me.
23 Q. Well, , who has been
24 previously identified in connection with
25 in Exhibit 113, was asking that of

1 Jeffrey Epstein, correct?

2 A. Yes. And then he said, "get it
3 from Rosa."
4 Q. Jeffrey Epstein said, "get it
5 from Rosa."
6 A. Yes. And then she got it from
7 Rosa.
8 Q. Yes.
9 A. Right. Okay. Now we're in
10 agreement.
11 Q. Yes.
12 And do you have any
13 understanding as to why was
14 seeking your e-mail from Jeffrey Epstein?
16 You may answer.
17 THE WITNESS: I think it was to
18 send me the e-mail down below.
20 Q. Let me turn to another subject
21 that was touched on briefly by other counsel
22 earlier, and that is Highbridge Capital.
23 And there came a time when
24 JPMorgan acquired an interest in Highbridge
25 Capital.

1 Is that correct?
2 A. Yes.
3 Q. And what was your involvement
4 in that acquisition?
5 A. Well --
6 Q. If any.
7 A. Well, I had ultimate approval
8 of the transaction.
9 Q. And you did approve the
10 transaction, correct?
11 A. I did.
12 Q. And what was Mr. Epstein's role
13 in that transaction?
17 anything that had any role at the
18 time, and I didn't know him at the
19 time.
21 identification.)
23 Q. Let me ask you to take a look
24 at a document that has been previously marked
25 as Exhibit 107.

1 Now, this is an e-mail -- not

2 an e-mail. This is a memorandum on JPMorgan
3 Chase stationery to you, Bill Harrison and
4 David Coulter from Jes Staley and some other
5 people dated March 18, 20 -- 2004.
6 Do you see that?
7 A. Yes.
8 Q. And this says, "Overview of a
9 potential partnership with and investment in
10 Highbridge Capital Management."
11 Do you see that?
12 A. Yes.
13 Q. And did you receive this
14 memorandum at or about the time it was sent?
16 Yeah, why don't you give him a
17 moment.
18 THE WITNESS: Yeah, give me a
19 moment.
20 MR. BUTTS: He hasn't had time
21 to read the document.
23 Q. When you're finished reviewing
24 it and prepared to answer questions, please
25 let me know.

1 A. Yeah, I don't recall receiving

2 this specific document.
3 Q. Do you have any reason to
4 believe you did not receive it?
6 THE WITNESS: I --
7 MR. BUTTS: This looks like a
8 draft. Do you have the final?
9 THE WITNESS: I do, because I
10 don't remember it, and I don't know
11 why they'd be sending it to me at all.
13 Q. The --
14 A. Can you check the date when we
15 did the JPMorgan/Bank One deal? Could you
16 just Google it?
17 MR. BUTTS: Was it July 1st?
18 THE WITNESS: July 1, '04.
19 MR. BUTTS: It was '04.
20 MR. BOIES: July 1, 2004.
21 MR. BUTTS: Yeah, there you go.
22 THE WITNESS: We didn't merge
23 the companies until July 1st of 2004.
24 They weren't legally merged until
25 January of '05. So I don't even know

1 why I'm on this memo.

3 Q. This was produced from the
4 JPMorgan files. So if it was a --
5 MR. BUTTS: Draft.
7 Q. -- fabricated document, it was
8 fabricated by somebody at JPMorgan?
9 A. It may not be fabricated. It
10 may be the draft had my name on it and there
11 was -- and they -- and they never sent it to
12 me.
13 If they did send it, it would
14 probably be in my e-mail somewhere, and so...
15 MR. BOIES: Well, I guess we
16 would -- if there is a -- if there's a
17 claim that this is a draft and that
18 there was a final version, I guess we
19 would request that that be produced.
20 MR. BUTTS: I'll look into
21 that. I assume that you got
22 everything it is, but this is
23 obviously a draft. There's bracketed
24 text in about five places.
25 THE WITNESS: And Highbridge

1 wasn't bought for years after this, if

2 I recall correctly, too.
3 MR. BOIES: I don't agree with
4 your characterization --
5 MR. BUTTS: Okay.
6 MR. BOIES: -- that it's a
7 draft, but it is what it is.
8 MR. BUTTS: Yeah.
9 MR. BOIES: And if there is
10 another version of this, we would ask
11 that it be produced.
12 MR. BUTTS: Okay. We'll make a
13 note.
14 THE WITNESS: Do you know when
15 we bought Highbridge?
16 MS. FRIEDMAN: You don't have
17 to -- this isn't a test to study for.
18 MS. SINGER: I don't think it's
19 appropriate for counsel to be coaching
20 the witness on answers.
21 MR. BUTTS: Well, I don't think
22 it's appropriate for one counsel to be
23 talking about another portion's
24 examination. You had your turn.
25 Mr. Boies, go ahead.

1 MS. SINGER: I am objecting

2 appropriately, Mr. Butts, to counsel
3 counseling the witness. This has
4 happened a number of times. I'm
5 noting it for the record, and I would
6 ask that it stop.
7 MR. BUTTS: Mr. Boies, do you
8 have another question?
9 THE WITNESS: I was just
10 asking for -- I was just asking for a
11 fact. I wasn't looking for
12 counseling.
13 I don't think we bought
14 Highbridge for years after this, and I
15 don't remember getting this and --
16 MR. BUTTS: Mr. Boies will give
17 you a new question.
18 THE WITNESS: -- we had --
19 yeah.
20 MR. BOIES: She represents
21 another party in this litigation, so I
22 think she can make objections.
23 MR. BUTTS: Well, we'll
24 disagree. I think you were doing fine
25 on your own, but go ahead.

1 What's the next question?

3 Q. Let me direct your attention to
4 the page that bears the Bates number ending
5 8063.
6 A. Yes.
7 Q. And in this document dated
8 March 18, 2004, that is addressed to you and
9 others, it says at the top, "Highbridge has
10 approached JB, JPMC based on an existing
11 relationship with the founders/owners, and
12 with Jeffrey Epstein, open brackets, a
13 founding investor in Highbridge, close
14 brackets."
15 Do you see that?
16 A. Yes.
17 Q. Do you recall being told in or
18 about 2004 that Highbridge had approached
19 JPMC based on its existing relationship with
20 the founders and owners and with Jeffrey
21 Epstein?
22 A. No. And I was the chairman and
23 CEO of Bank One at the time.
24 Q. When had you been selected to
25 become CEO of JPMorgan Chase?

1 A. The merger closed sometime in

2 January of 2005, and I became the CEO
3 approximately 18 months later.
4 Q. But had that been -- had you
5 been designated as that earlier?
6 A. No, that was part of the
7 contract, which was signed literally in July
8 of 2005.
9 Q. And prior to the signing of
10 that contract, what discussions had there
11 been about you becoming CEO?
12 A. I'd had some conversations with
13 Bill Harrison about does a merger make sense,
14 how would it work, what we call the social
15 engineering around it.
16 These decisions obviously are
17 also up to boards. Those things didn't get
18 the boards and reviewed until late in the
19 process.
20 I don't think in March there
21 was a -- known who would be the CEO of the
22 combined company.
23 Q. You know Mr. Dubin, correct?
24 A. I do.
25 Q. And was Mr. Dubin told that

1 this Highbridge investment would have to be

2 approved by you ultimately because you were
3 going to become the CEO?
4 A. That -- I don't believe that
5 was known at the time, so I don't think I
6 would have had to approve any JPMorgan Chase
7 transaction in March of 2004.
8 Q. Do you have any explanation at
9 all as to why, in March 8 -- 18th of 2004,
10 Mr. Staley would be writing to you about the
11 Highbridge Capital transaction and Jeffrey
12 Epstein?
13 A. You got me.
16 identification.)
19 Exhibit 136.
20 And first, at the top of the
21 page there is an e-mail from Mary Erdoes to
22 Stacey Friedman dated August 8, 2019, at
23 1:29 p.m.
24 Do you see that?
25 A. Yes.

1 Q. Who is Stacey Friedman?

2 A. She's this wonderful woman
3 right here, general counsel of JPMorgan
4 Chase.
5 Q. And you got a copy of the
6 e-mail below, but did you ever have a
7 discussion with either Mary Erdoes or Stacey
8 Friedman concerning Mary Erdoes' e-mail?
9 MR. BUTTS: You may answer that
10 question -- well, the question is yes
11 or no at this point.
14 Q. Okay.
15 A. I don't know what's in this, so
16 it's hard for me to tell if I've had a
17 conversation about it.
18 Q. What?
19 A. I don't know -- this is from
20 Mary to Stacey. I don't know if I was
21 ever -- talked about this. I'm copied on the
22 one down below.
23 Q. And you're not shown to be a
24 copy on this e-mail?
25 A. Right.

1 MR. BUTTS: The top one.

2 MR. BOIES: The top one.
3 MR. BUTTS: Yeah.
5 Q. And so I -- the reason why I
6 was asking is whether you ever had any
7 conversations about it.
8 A. I don't -- I can't recall
9 because I don't know what "it" is, you know.
10 Q. Let's focus on the e-mail then
11 that you did get a copy of.
12 This is from Joseph Evangelista
13 to Mary Erdoes, Stacey Friedman, yourself,
14 with copies to other people.
15 Do you see that?
16 A. Yes.
17 Q. And it says -- "New York Times
18 story this morning" is the subject.
19 Do you see that?
20 A. Yes.
21 Q. And it says, "The New York
22 Times plans to run a story later this
23 morning. They said it will be very prominent
24 and will say there was a virtual, quote,
25 brawl, close quote, between 2008 and 2012

1 between Mary and compliance/legal regarding

2 keeping Jeffrey Epstein as a client."
3 Do you see that?
4 A. Yes.
5 Q. It goes on to say that "The New
6 York Times said they have five former
7 JPMorgan executives, and they're 100 percent
8 confident in their information."
9 Do you see that?
10 A. Yes.
11 Q. Do you recall receiving this
12 e-mail?
13 A. Not this specific one, but I
14 recall the issue coming up and talking to
15 Stacey about it.
17 with Mary Erdoes about this?
18 A. Possibly a little bit, but I --
19 this -- it was around this time I found out
20 about all this stuff, or a little before, and
21 I put it in the jurisdiction of my general
22 counsel. And I probably told Mary, let her
23 take -- you know, let her take it from here
24 and...
25 Q. When you say, "I probably told

1 Mary, let her take it from here," is the

2 "her" there Ms. Friedman?
3 A. Yes.
4 Q. Now, Mary Erdoes was a direct
5 report to you; is that correct?
6 A. Yes.
7 Q. And is it fair to say that
8 while you delegate to your direct reports,
9 you have the responsibility for supervising
10 them?
11 A. I do.
12 Q. And as part of supervising Mary
13 Erdoes, did you want to know what this
14 virtual brawl was about whether to keep
15 Epstein as a client?
16 MR. BUTTS: Objection. Assumes
17 facts.
18 You may answer.
19 THE WITNESS: "Brawl" is a
20 press word. They like things like
21 that.
22 Clearly there were
23 disagreements among the people who
24 were reviewing the account, which I
25 know today. I did not know -- I

1 probably didn't even know at that

2 point and...
4 Q. But by this point you knew that
5 Jeffrey Epstein was a sex trafficker, and you
6 knew that he had been a client of the bank,
7 correct?
9 You may answer.
10 THE WITNESS: I believe so,
11 yes. I don't know how much of all
12 that I knew, but, yeah.
14 Q. And is it fair to say that at
15 this point you knew that you would have
16 rather Mr. Epstein never have been a client
17 of the bank?
18 A. That's fair to say.
19 Q. Okay. And so when you found
20 out that there was this virtual brawl -- and
21 brawl, I agree, it's a colloquial term -- but
22 dispute between Mary Erdoes and
23 compliance/legal about whether to keep him as
24 a client going all the way back to 2008, did
25 you want to find out what the relative

1 positions of the parties were?

2 MR. BUTTS: Objection, and
4 You may answer.
5 THE WITNESS: He was no longer
6 a client after 2013, and I'm not
7 agreeing to the brawl between Mary and
8 compliance/legal.
9 I did not know that at the
10 time, and I'm not even sure it's true.
11 I wouldn't describe it that way. This
12 person described it that way.
14 Q. This reporter described it way,
15 and I agree.
16 A. I know the press.
17 Q. And I'm not ever going to say
18 the press always gets it right.
19 MR. BUTTS: Did we get that?
21 Q. But the -- but, you know,
22 this is --
23 A. We can all agree on that,
24 right?
25 MR. BUTTS: Exactly.


2 Q. This is The New York Times,
3 which I read as well as you, and they said
4 they had four former JPM executives saying
5 this.
6 So even though you don't
7 necessarily know it personally, it's
8 something that is at least plausible.
9 Is that fair?
11 Objection to form.
12 You may answer.
13 THE WITNESS: It's fair, yes.
15 Q. And recognizing that, is it
16 fair to say that you wanted to find out
17 whether it was true or not?
18 A. I don't recall my concern just
19 being whether it's true or not. I do recall
20 starting conversations with my general
21 counsel about what happened.
22 Q. And when you say --
23 A. And why.
24 Q. Is the "what happened" what
25 happened in terms of that dispute, whether

1 there was such a dispute?

2 A. Yes, and what it was about and
3 who was in it and who decided and those kind
4 of issues.
5 And I asked Stacey to do that
6 and also to make sure we didn't mislead The
7 New York Times with statements we made.
8 Q. And did you get back to The New
9 York Times on this?
10 A. I did not. I don't know if we
11 commented at all on this particular thing. I
12 would be surprised if we didn't say
13 something, but...
14 Q. Did you try to find out
15 anything about the facts about this, quote,
16 brawl, close quote, or dispute, if that's a
17 better term to use --
19 and answered.
21 Q. -- other than asking your
22 general counsel?
23 A. I asked Stacey. I tried to
24 find out general facts, not every fact, but
25 just the general skeleton of the thing. And

1 I found out as part of working with Stacey,

2 primarily.
3 Q. When you say "primarily," did
4 you do anything at all, other -- to find out
5 the facts about the dispute that is alleged
6 here to have existed between Mary Erdoes and
7 compliance about whether to keep Mr. Epstein
8 as a client, other than to ask your general
9 counsel?
10 A. I don't recall calling anyone
11 else up to ask them detailed questions about
12 it. I was not going to call Jes. The people
13 here were being interviewed by Stacey. So I
14 don't recall talking to anyone else about it.
15 Q. You said in the answer, "I
16 don't recall calling anyone else to ask them
17 detailed questions."
18 Did you communicate with anyone
19 other than your general counsel about this at
20 all, whether it was detailed or not?
21 A. I spoke to Mary a little bit.
22 And I don't know if we ever met -- when we --
23 we did mention it at the board. I don't know
24 when we did that.
25 Q. When you spoke to Mary, what

1 did you say to her?

2 A. Just --
3 Q. In substance.
4 A. Just confirming that he was
5 fired in 2013; that -- the time she remembers
6 meeting him is going to his house to fire
7 him; and that we did have him as a client;
8 and that the primary person vouching for him
9 was Jes Staley, not Mary.
10 Q. That's what Mary told you?
11 A. That's what Mary told me, and
12 that's what all the documents that were
13 reviewed basically show.
14 Q. Did you ask her whether there
15 had been a dispute between herself and
16 compliance regarding whether to keep Epstein
17 as a client?
18 A. Not specifically. Or not
19 specifically that I recall.
20 Q. Did you do that generally?
21 A. I mean, we weren't denying that
22 there was a dispute. We knew that, that the
23 people were arguing about whether he should
24 be kept or not.
25 Q. How did you know that there was

1 that dispute?
2 MR. BUTTS: Hold on.
3 THE WITNESS: I spoke to my
4 general counsel.
5 MR. BUTTS: Okay. So you
6 shouldn't reveal any more.
8 MR. BUTTS: And we should go to
9 the next question.
11 Q. Now, you said you also
12 discussed this dispute with the board at some
13 point.
14 MR. BUTTS: And hold on a
15 second.
17 Q. Is that right?
18 MR. BUTTS: Let me -- finish
19 your question, and then I have
20 something.
21 MR. BOIES: I'm finished.
22 MR. BUTTS: Okay. So
23 discussions with the board, which I
24 understand in 2019 by Ms. Friedman as
25 part of a legal update are also

1 privileged.
3 MR. BUTTS: If there is a
4 conversation that is outside of
5 Ms. Friedman's discussions with the
6 board and legal update, you may
7 answer, but otherwise no.
8 THE WITNESS: I don't believe
9 there were.
11 Q. Is your testimony that the only
12 thing that was discussed with the board about
13 this issue of whether Epstein should have
14 been kept as a client was legal advice?
15 A. No. I think when Stacey
16 reviews a case with them, she reviews the
17 case, not just the legal part of the case.
18 Q. Was the board -- you're a
19 member of the board, right?
20 A. Yes.
21 Q. In addition to being the
22 chairman?
23 A. Yes.
24 Q. Was the board interested in
25 whether the bank had the proper procedures

1 and protocols for deciding whether to keep a

2 high-risk client as a client?
3 A. The board conversations --
5 reveal anything that happened in
6 connection with Ms. Friedman's legal
7 update to the board.
8 MR. BOIES: Yeah. And my
9 question has to do not with what she
10 said. It was what the board was
11 interested in.
12 MR. BUTTS: Any interest or
13 knowledge or statements reflected as
14 part of her legal update to the board
15 in a two-way conversation are
16 privileged, and you shouldn't be
17 revealing that.
18 THE WITNESS: They were
19 briefed.
21 Q. I'm now not asking what they
22 were briefed on. I wasn't even asking
23 whether they were briefed.
24 A. I know, and you got to get the
25 timetable separately, so...

1 Q. What I'm asking is whether the

2 board as the board of the bank was trying to
3 figure out whether the bank's procedures and
4 protocols for handling high-risk clients like
5 Jeffrey Epstein were appropriate or not.
6 Were they trying to find that
7 out?
9 whatever the board was or was not
10 trying to do in connection with the
11 legal update, same instruction.
12 THE WITNESS: And the board is
13 12 people, so all slightly different.
14 But they were briefed, and of course
15 they're interested in this company.
17 Q. Since you're the only member of
18 the board who is here now, let me ask you.
19 Were you, as a board member, as
20 the chairman and the chief executive officer,
21 trying to determine, as a matter of your
22 business operations, whether those business
23 operations needed to be changed?
24 MR. BUTTS: In 2019?
25 THE WITNESS: Regarding?


2 Q. Regarding how you decided
3 whether to continue to do business with
4 somebody who had been convicted of sex
5 trafficking and was withdrawing tens of
6 thousands of dollars of cash every month.
7 MR. BUTTS: And exited in 2013?
8 MR. BOIES: We're talking about
9 2008 to 2012 --
10 MR. BUTTS: Okay.
11 MR. BOIES: -- by this e-mail.
12 THE WITNESS: I mean, I think I
13 said in prior testimony, from the time
14 I got to this company to today,
15 certain of these procedures are always
16 being changed, enhanced, regulate --
17 new regulations, new technology, so
18 it's always -- that question is a
19 permanent thing. Yes, of course.
20 Every day of every month we are
21 trying to get that better. Minimize
22 mistakes, minimize -- maximize your
23 standards. So the whole time it was
24 true.
25


2 Q. In the entire time that you
3 have been the chief executive officer of the
4 bank, who are the three bank customers whose
5 business with the bank has been most
6 reputationally damaging to the bank?
8 You may answer.
9 THE WITNESS: The three. It's
10 hard for me to say.
12 Q. Huh?
13 MR. BUTTS: If you have an
14 answer, you may give one. If you
15 don't have an answer, you don't have
16 an answer.
17 THE WITNESS: Probably buying
18 Bear Stearns.
20 Q. I'm talking about customers of
21 the bank. I'm not talking about mistakes you
22 made.
23 A. I know. But you said
24 reputational.
25 I don't know -- I can't give

1 you a specific answer to that.

2 Q. What?
3 A. I can't give you a specific
4 answer to that.
5 Q. Well, is there any customer of
6 the bank, during the time that you were the
7 CEO, that caused the bank as much
8 reputational damage as Jeffrey Epstein?
10 You may answer.
11 THE WITNESS: I don't know the
12 answer to that.
14 Q. Well, think about it for a
15 minute. Can you think of anybody?
18 THE WITNESS: Lots of things
19 related to Bear Stearns is the only
20 thing that comes to mind.
22 Q. Well, Bear Stearns was a
23 company that you acquired, correct?
24 A. Yes.
25 Q. In fact, there's a conference

1 room across the hall named the Bear Stearns

2 conference room.
3 A. Okay. I thought of one.
4 WorldCon -- WorldCom, which I
5 inherited when I got here.
6 Q. And they were --
7 A. And Enron, which I inherited
8 what I got here. So now you've got three.
9 Q. All right. But those were not
10 people who you got in trouble with because
11 they were customers of the bank.
12 MR. BUTTS: Well, you asked
13 about customers.
14 THE WITNESS: They were
15 customers.
17 Q. The -- anybody else?
18 And those are all institutions,
19 correct?
20 A. Well, and people. I mean --
21 Q. Well, Enron is not a person.
22 A. Well, Jeff Skilling was a
23 person.
24 Q. WorldCom is not a person and --
25 A. And Ebbers was a person, but --

1 Q. And do you think Ebbers was the

2 person who caused the bank as much
3 reputational damage as Jeffrey Epstein?
4 A. I -- it's hard for me to weigh
5 and measure, but damn close, yes.
6 Q. So having Mr. Ebbers and
7 Mr. Epstein as clients of the bank caused the
8 bank significant reputational damage; is that
9 correct?
10 A. Yes.
11 Q. And when was Mr. Ebbers a
12 customer of the bank?
13 A. It predated me. I said I
14 inherited it when I got here. Legally in
15 '05, January of '05.
16 Q. And you recall my question was,
17 during the time you had been CEO of the bank,
18 who were the people who had caused the most
19 reputational damage.
20 Do you remember that was the
21 time frame?
22 A. You mean that started while I
23 was the CEO of the bank?
24 Q. Yeah. Right.
25 Look, let me -- to be fair --

1 A. Yeah.
2 Q. -- Jeffrey Epstein was a
3 disaster --
4 A. A disaster.
5 Q. -- okay?
6 A. Terrible.
7 Q. Terrible.
8 A. Piece of shit. Yes, all of
9 that, we know.
10 Q. And what I'm asking is, this
11 disaster happens to the bank. As the CEO --
12 forget legal. Just from the standpoint of
13 the CEO, you want to do something about it
14 for your business, fair?
15 A. We try to protect the company,
16 yes.
17 Q. Okay. And what I'm asking is
18 not what do you do for liability, not what do
19 you do for law enforcement, not what do you
20 do for your legal requirements.
21 What do you do in terms of just
22 wanting to operate a good business? What
23 changes are you thinking about making to
24 improve your business as a result of what
25 you've learned from the Jeffrey Epstein

1 disaster?
2 A. I feel like I answered this
3 already.
4 MR. BUTTS: Uh-huh. Many
5 times.
6 THE WITNESS: In my life, we've
7 never stopped trying to improve. And
8 as a result of this, we've asked a lot
9 of questions -- and it was me -- this
10 is me to Stacey -- about what can we
11 improve, are there best practices, are
12 there other technologies, are there
13 better ways with the legal profession.
14 We do share some of that with
15 the rest of the operating committee,
16 with people that report to me, so they
17 can incorporate that in their thinking
18 about how they run their business.
20 Q. And have you done that with the
21 operating committee?
22 A. A little bit.
23 Q. What have you done with the
24 operating committee with respect to what
25 you've learned with -- from the Jeffrey

1 Epstein episode?
2 A. They were briefed, kind of like
3 other people were briefed. They don't know
4 all the stuff that Stacey knows. Anything
5 relating to the lawsuits and stuff like that
6 has been stayed, I think, here for now. But
7 we will execute best practices if we find
8 additional things.
9 Q. What I'm trying to do is --
10 A. Yeah.
11 Q. -- get beyond the generality.
12 A. Right.
13 Q. We want to have best practices,
14 always improving.
15 A. Yeah.
16 Q. To see if you can tell me
17 anything specific that you're doing.
18 A. There are one or two, maybe,
19 but that's in conversation with general
20 counsel that I'm not supposed to talk about.
21 I will be -- we would be happy
22 to share best practices when this is over,
23 and I think you'll be very proud of it. The
24 things we've done before, the things we're
25 trying to do now, particularly around human

1 trafficking.
2 Q. Let me approach it this way.
3 A. Like, for example, we can
4 probably apply AI to it at one point. That
5 will enhance it.
6 Q. Uh-huh. And I recognize that
7 some things like AI weren't around in 2008 to
8 2012.
9 But there were things that
10 could have been done in 2008 to 2012 to have
11 avoided this, fair?
12 A. There -- I would say maybe, but
13 there are lots of things that were done
14 between '08 and 2013, and a lot done between
15 2013 and 2018 to always enhance these things.
16 Q. But let me approach it this
17 way.
18 If you had known in 2010 that
19 Jeffrey Epstein was a sex trafficker, that
20 Jeffrey Epstein was a client of the bank,
21 that Jeffrey Epstein was withdrawing tens of
22 thousands of dollars of cash every month,
23 would you, as the chief executive officer of
24 the bank, said, we need to get rid of this
25 guy, regardless of whether the general

1 counsel told you that that was the right

2 thing to do?
5 Q. Would you, in your supervisory
6 responsibility, have taken that step?
8 You may answer.
9 THE WITNESS: I think everyone
10 involved, had they known then what is
11 known today, including me, would have
12 taken that position.
13 MR. BUTTS: David, is this a
14 good time for --
15 MR. BOIES: Sure.
16 MR. BUTTS: -- five or ten?
17 MR. BOIES: Absolutely.
18 Absolutely.
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16 Q. Now, you said several times
17 that if you knew then, back in 2008 to 2012
18 or earlier, what you know now, that anyone
19 would have terminated Epstein, correct?
21 You may answer.
22 THE WITNESS: I think most
23 people at JPMorgan Chase would have
24 terminated him, yes.
25


2 Q. Including yourself?
3 A. Well, I wouldn't consider that
4 my job. We have people who do that. I do
5 not do that, but I think it would have
6 happened, yes.
7 Q. Let me put it this way.
8 You would have expected the
9 people who do that job to have done it.
11 You may answer.
13 Q. Correct?
14 A. Had they known everything that
15 we know today --
16 Q. Yes.
17 A. -- back then, I would have
18 expected that would have been the outcome.
19 Q. Okay. Now, is there anything
20 that you know today that was not known by Jes
21 Staley and Mary Erdoes in 2006, '7, '8, '9,
22 '10, '11?
24 You may answer.

1 they knew, so it's hard for me to

2 answer. But there's a lot more today
3 after his arrest in 2019, her --
4 Ghislaine Maxwell's guilt in 2020, all
5 the different information. So there's
6 a lot more out today that -- I don't
7 know what Jes knew.
9 Q. Well, you say "there's a lot
10 more out."
11 Other than the convictions,
12 what more is known today than what was known
13 to Mary Erdoes and Jes Staley when
14 Mr. Epstein was still a client of the --
16 You may answer.
18 Q. -- bank?
19 MR. WOHLGEMUTH: Join.
20 THE WITNESS: I would separate
21 Mary and Jes.
23 Q. Okay. Let's take them one at a
24 time.
25 A. I don't know if she knew at the

1 time. My view is, had she known what we know

2 today, she'd be saying exactly the same thing
3 I said.
4 There's a chance that Jes knew.
5 That's why they're different.
6 Q. But when you say "a chance" --
7 A. Well --
8 Q. Let me try to -- and you can
9 only tell me what you know.
10 A. Thank you.
11 Q. But -- and you're pretty good
12 about that as opposed to some other witnesses
13 that I've had.
14 But can you tell me anything
15 that you know today that you believe was not
16 known by Jes Staley in 2006, '7, '8, '9, '10,
17 '11, '12?
19 I'll instruct you not to answer
20 to the extent you're revealing
21 information you gained through counsel
22 in connection with the litigation.
24 THE WITNESS: So I'm not going
25 to answer because I know a lot more

1 about it today than I ever knew -- and

2 we know a lot more about it even
3 recently than we knew even in 2019.
5 Q. What do you know more now than
6 you knew in 2019?
8 instruction.
9 MR. BOIES: No. No. No. He
10 just made a statement about he knows a
11 lot more. I'm entitled to ask him --
12 MR. BUTTS: Sure.
13 MR. BOIES: -- what more he
14 knows.
15 MR. BUTTS: Yeah, sure. You're
16 entitled to ask him, but not about
17 what information that came from
18 counsel.
19 MR. BOIES: If -- if when he
20 says, we know a lot more now than we
21 knew then, if he's referring to
22 counsel, I am entitled to follow up on
23 that.
24 MR. BUTTS: No, you're not. We
25 just did that with the Court.

1 MR. BOIES: No. No. Not

2 when -- that was not a question
3 following up a statement that the
4 witness had made.
5 MR. BUTTS: Okay. So the
6 objection stands.
7 But go ahead.
8 THE WITNESS: What's the
9 question again?
11 Q. Sure.
12 You said a moment ago that you
13 knew a lot more now than you did in 2019.
15 A. In 2019, he was indicted and
16 put in jail and committed suicide. There was
17 a lot of learning there. A lot of stuff has
18 come out since then.
19 And I guess in 2020, she was
20 found guilty of sex trafficking, and a lot of
21 information came out there.
22 And then what I don't want to
23 mention is the information that came out in
24 all of these -- work you're doing about Jes,
25 which you guys probably know better than me.

1 So I'll stop there.

2 Q. First, nothing has come out
3 about Mr. Staley that Mr. Staley did not
4 know, fair?
8 he really knew and when he really knew
9 it, but it came out to us after 2020.
11 Q. Well, Mr. Staley knew that
12 Mr. Epstein was withdrawing very large
13 amounts of cash on a consistent basis,
14 correct?
16 You may answer.
18 Lacks foundation.
19 THE WITNESS: I don't know
20 specifically what Jes Staley knew.
22 Q. Did you ever try to find out?
23 A. Only as a result -- only as a
24 result of all of this. Now I kind of know.
25 Q. Did you ever try to find out --

1 MR. WOHLGEMUTH: Move to strike

2 the answer.
4 Q. -- as a business matter --
5 forget the lawyers. Forget what you think
6 the legal obligation is.
7 Did you ever just try to find
8 out because you're the chairman and chief
9 executive officer of the bank and you wanted
10 the bank to operate in a businesslike way?
12 And same instructions as we've
13 given all day.
14 THE WITNESS: I did ask my
15 folks to do exactly what you're
16 saying.
18 Q. And the folks that you're
19 referring to there is your general counsel?
20 A. My general counsel.
21 Q. Other than the fact that there
22 were a conviction and a suicide, is there any
23 fact that you're aware of today that was not
24 known to officers of the bank in 2006, '7,
25 '8, '9, '10, '11?


2 and answered.
3 And the same instruction as
4 we've been giving all day.
6 THE WITNESS: Again, I don't
7 understand the question.
9 Q. Okay.
10 A. Facts have been coming out
11 because of the conviction, because of
12 Ghislaine Maxwell, and because of all these
13 depositions and additional information that's
14 been going on nonstop.
15 I don't know what Jes knew in
16 2015.
17 Q. What are those facts that have
18 come out?
19 MR. BUTTS: No. No. No.
20 THE WITNESS: That's not what
21 I'm supposed to --
22 MR. BUTTS: Yeah, we're not
23 giving you --
24 THE WITNESS: I think you
25 actually probably have the same facts

1 that I've learned.

2 MR. BUTTS: Right. You do.
5 Q. What did you do -- we had the
6 same facts --
7 MR. BUTTS: Discovery. We've
8 been doing discovery for months on
9 end. There's been deposition after
10 deposition.
11 MR. BOIES: No. No. No. No.
12 He said that a lot of facts had come
13 out --
14 MR. BUTTS: Yes.
15 MR. BOIES: -- at the time of
16 the arrest, in terms of the Maxwell
17 trial.
19 Q. Do you remember saying that,
20 sir?
21 A. Yes.
22 Q. Okay. What I'm asking you is,
23 what are those facts? What are those facts?
24 Not the facts that came from
25 your general counsel, the facts that came out

1 from that trial and the arrest.

2 MR. BUTTS: He's testified that
3 his -- he was talking with his general
4 counsel in 2019 when these issues came
5 about, and all of that is off limits.
7 Q. Let me ask you a yes or no
8 question.
9 Did your counsel tell you what
10 facts had come out at the Maxwell trial?
12 instruction not to answer.
14 Q. Did your counsel tell you what
15 facts had been reported in the newspaper?
17 instruction not to answer.
19 Q. Was it part of your general
20 counsel's responsibility to keep you informed
21 about what facts were being reported in the
22 newspaper about the Jeffrey Epstein episode?
24 And you may answer that
25 question yes or no.

1 THE WITNESS: Not really. If

2 it was material or a decision played a
3 thing, but not to keep me briefed like
4 a gossip person.
6 Q. Well, we're not talking about a
7 gossip person. I'm talking about -- I'm just
8 asking. Your lawyer has instructed you not
9 to answer what she told you about the facts
10 that were being reported.
11 What I'm asking you is whether
12 it was part of her responsibility to tell you
13 that.
14 A. She decides when she -- I need
15 to know something, and she did brief me on
16 certain facts during the course of all this.
17 Q. So that -- what -- so what
18 facts she conveyed to you about the Jeffrey
19 Epstein episode was, in your view, entirely
20 up to her; is that fair?
21 A. In her judgment, yes.
22 Q. Okay.
23 A. And other lawyers she was
24 working with.
25 Q. Her and the people working for

1 her?
2 A. The team, yeah.
3 Q. Did you feel any responsibility
4 to find out facts not for a legal purpose but
5 for a business purpose?
6 A. I would say yes.
7 Q. Okay. What did you do to
8 fulfill that responsibility?
9 A. I think I answered this. I
10 asked my general counsel to look at the
11 practices and procedures around -- again,
12 because again, we told you we do it all the
13 time -- to talk to the right people and to
14 look at those things that we can do that can
15 enhance the practices and procedures and
16 lessons through this episode and other ones.
17 Q. Uh-huh.
18 A. And we're going to share it
19 with you when it's said and done, so you'll
20 hopefully be happy with it. I told you that,
21 too.
22 Q. I'm sorry, say that --
23 A. We'll share it to you when all
24 this is all said and done. And if you have
25 ideas for us, we'll take them, too.

1 Q. Do you believe that -- whether

2 or not it was intended, do you believe the
3 fact that you continued as the bank to do
4 business with Jeffrey Epstein --
5 MR. BUTTS: "You" is the
6 company?
7 MR. BOIES: Yeah, the bank.
8 MR. BUTTS: Okay.
9 MR. BOIES: That's why I'm
10 trying to be clear.
11 MR. BUTTS: Okay. I just
12 wanted to make sure I'm clear.
14 Q. When I say "you," I don't mean
15 you personally. I don't mean you personally.
16 I mean the bank.
17 A. Yeah.
18 Q. Do you believe that the fact
19 that JPMorgan continued to do business with
20 Jeffrey Epstein as long as it did facilitated
21 the scope and scale of Jeffrey Epstein's
22 operations?
25 If you're able to answer

1 something like that.

2 THE WITNESS: I do not know the
3 answer to that question.
6 A. That's part of what we're doing
7 now. It's a good question about what we
8 could have done differently that might have
9 made a difference, including working with
10 the -- with law enforcement.
11 Q. And that's a -- that is an
12 inquiry that you have given to your general
13 counsel.
14 Is that correct?
15 A. Yes.
16 Q. And that you do not have
17 anything to say about that that you are
18 prepared to say at this time.
19 Is that fair?
20 A. Nothing I'm allowed to say at
21 this time.
22 Q. When you say not allowed,
23 because your counsel instructs you; is that
24 right?
25 A. Because it happened after the

1 start, yes.
2 Q. After what?
3 A. It was a conversation with
4 counsel, yes. There's nothing I'm
5 embarrassed about.
6 Q. The --
7 MR. BOIES: Well, move to
8 strike the last sentence on the
9 grounds that I can't cross-examine it.
10 MR. BUTTS: Okay. Well, noted,
11 and then next question, please.
12 THE WITNESS: Join the club.
14 Q. Do you believe as the chairman
15 and chief executive officer of JPMorgan that
16 the bank, in the way it dealt with Jeffrey
17 Epstein, acted in a way that is inconsistent
18 with the way that you would like to have seen
19 the bank operate?
21 And again, you should not
22 reveal to the extent that your
23 discussions are with counsel in
24 connection --
25 MR. BOIES: This is a yes or no

1 question.
2 MR. BUTTS: It's the same.
3 It's yes or no with regard to a
4 conclusion baked in. So he should not
5 answer to the extent that it's
6 reflective of counsel's -- discussions
7 with counsel.
8 THE WITNESS: What is the
9 question again?
11 Q. Do you, as the chairman and
12 chief executive officer of JPMorgan, believe
13 that the bank dealt with Jeffrey Epstein
14 consistent with the business procedures that
15 you believe are appropriate for the bank?
17 You may answer.
18 THE WITNESS: Yeah, I think the
19 people who are the experts at the time
20 would have answered that yes.
21 Knowing what we know today,
22 we've asked to see how we can improve
23 some of the things that we do, and if
24 they were improvable back then.
25 Technology has changed, the

1 regulations have changed, requirements

2 have changed.
4 Q. Who were the experts at the
5 time that you're referring to?
6 A. Steve Cutler would be the
7 primary one that I would refer to, and he had
8 a whole team of people, some of whom had been
9 for -- in the prosecutor's and the Department
10 of Justice. He had been the SEC enforcement
11 chief, and very many capable people in
12 compliance and experts in AML sanctions, et
13 cetera.
14 Q. Is it fair to say that you
15 believe the bank should have done what
16 Mr. Cutler concluded was the appropriate
17 thing to do?
18 MR. BUTTS: Objection. Same
19 instruction.
20 You may answer.
21 THE WITNESS: Cutler was the
22 ultimate authority. It didn't mean
23 that because he didn't like something
24 he wouldn't allow a businessperson to
25 make a different judgment call.

1 If he had felt that it had gone

2 over the line, he would have kicked it
3 out, and he had the authority to do
4 it.
5 So, yes.
7 Q. Well, I'm not sure I understand
8 that answer.
9 You said that the experts were
10 the people in charge when Jeffrey Epstein was
11 a customer of the bank.
12 Correct?
13 A. Yes.
14 Q. And I asked you who those
15 experts were, and you said Mr. Cutler.
16 Correct?
17 A. A team of experts.
18 Q. What?
19 A. A team of experts. I said
20 compliance, legal, AML, people who would have
21 been in enforcement, people who would have
22 been out of the DOJ prosecution. He was the
23 most senior of them --
24 Q. Okay.
25 MR. BUTTS: Let him finish.

1 THE WITNESS: -- and the one

2 who could override a businessperson.
4 Q. If a businessperson -- who are
5 the businesspersons you're referring to?
6 A. Any businessperson.
7 Q. With respect to Jeffrey
8 Epstein. You said "experts." You said this
9 was handled by the experts.
10 A. Jes Staley in this case.
11 Q. Jes Staley?
12 A. He could have overridden Jes
13 Staley, yes.
14 Q. Now, if Jes Staley and
15 Mr. Cutler disagreed, did that mean that what
16 Mr. Cutler wanted to do prevailed, or did it
17 mean sometimes Mr. Staley and sometimes
18 Mr. Cutler?
20 THE WITNESS: I would say a --
22 THE WITNESS: -- 100 percent
23 Steve Cutler.
25 Q. Okay.

1 A. And Jes Staley could have asked

2 for an appeal. As far as I know, no one ever
3 has, because I will not override my general
4 counsel.
5 Q. So if you have a disagreement
6 between the businessperson and Mr. Cutler,
7 Mr. Cutler prevails unless there's an appeal
8 to you, and there's never been a successful
9 appeal to you; is that fair?
10 A. I don't remember there being an
11 appeal to me.
12 Q. Okay. There's never even been
13 an appeal?
14 A. Right. Because they all know
15 what my answer would be.
16 Q. So that -- in the case of
17 Mr. Epstein and everybody else, Mr. Cutler's
18 view would be the view that prevailed in
19 terms of whether somebody was terminated; is
20 that fair?
22 You may answer.
23 THE WITNESS: I'm trying to be
24 really clear on this. He had the
25 ultimate authority, but he would allow

1 people to use their judgment, which he

2 can override.
3 So he may disagree with their
4 judgment, but it may not have hit the
5 level that he thinks he should have
6 override it at.
8 Q. What was that level?
9 A. Well, I -- if you were my
10 lawyer, my general -- I would say to you,
11 David, you are the ultimate decider, but
12 there are disputes, there are things, there
13 are legitimate things, you're getting people
14 to vouch for people, people do different
15 things; that you were the ultimate decider,
16 and there will be cases which, you know, the
17 business people want to keep and general
18 counsel you're making a mistake, but it's
19 your judgment.
20 There will be other cases where
21 the general counsel will say, this is not --
22 this is my judgment, you can't do it.
23 Q. With respect, I don't
24 understand what that -- what that means.
25 MR. BUTTS: Strike the comment.

1 He gave you an answer to your

2 question.
3 MR. BOIES: No, I don't think
4 he did --
5 THE WITNESS: I thought it was
6 very clear.
7 MR. BUTTS: I did, too.
8 MR. BOIES: No, he didn't
9 answer the question.
10 You can have your view; I've
11 got mine.
12 MR. BUTTS: Hold on. So let's
13 take a fresh question, David.
14 MR. BOIES: I will if you'll
15 stop talking.
17 Q. You seem to be saying, and
18 correct me if I'm wrong, that sometimes
19 Mr. Cutler will think somebody ought to be
20 terminated, but they won't be terminated; is
21 that right?
23 Mischaracterizes.
24 THE WITNESS: Totally
25 incorrect.


2 Q. Well, then let me try to get at
3 it.
4 If you've got a disagreement
5 between Mr. Cutler and the businessperson as
6 to whether to terminate a client, is
7 Mr. Cutler's view always going to prevail?
9 and answered.
11 Q. Or is he sometimes going to let
12 the businessperson do something he disagrees
13 with?
15 THE WITNESS: I'm sure in your
16 life you've said to someone, I don't
17 agree with you, I wouldn't do it, but
18 it's your call, as opposed to, I don't
19 agree with you, I wouldn't do it, and
20 you cannot do it.
22 Q. Absolutely.
23 A. Okay.
24 Q. They're two different
25 differences.

1 A. He had the right to do the

2 second, and he had the right to do the first.
3 Q. Okay. So there is --
4 MR. BUTTS: David, please let
5 him finish.
6 THE WITNESS: In his judgment,
7 he would make that decision.
9 Q. Okay. So he could --
10 MR. BUTTS: Are you finished?
12 MR. BUTTS: Okay. Now your
13 turn.
15 Q. So he could decide to let the
16 businessperson make the call not to terminate
17 Mr. Epstein, even though he believed that
18 Mr. Epstein should be terminated; is that
19 fair?
21 and answered.
22 THE WITNESS: I think it was
23 quite clear because you're kind of
24 changing my meaning.
25 If he thought it rose to the

1 level -- an excess level, he would

2 have said, you can't.
3 If he didn't, sometimes he
4 said, my advice is you shouldn't do
5 it, but it's your call.
7 Q. And what this excess level is
8 that you refer to is not anything that's
9 written down; that's just a question of
10 judgment, right?
11 A. There's a group of people who
12 review these things, and they all -- I think
13 they all know at the end of the day that if
14 there's a dispute, he is the final arbiter.
15 Q. Didn't you just tell me that he
16 might think somebody ought to be terminated,
17 but he had the right to say to the
18 businessperson, it's your call, if you don't
19 want to terminate him, let him continue to be
20 a customer?
22 and answered.
23 THE WITNESS: It's the weight
24 of the scale. People disagree, and he
25 doesn't think it hit the level where

1 he should mandate it.

3 Q. But what's that level?
4 A. We all do that. That's called
5 judgment.
6 Q. What's that level?
7 MR. BUTTS: David, you're
8 interrupting him a lot.
9 MR. BOIES: No, I'm not
10 interrupting him.
11 MR. BUTTS: You are
13 MR. BOIES: Okay. You're
14 interrupting me.
15 MR. BUTTS: I am --
16 MR. BOIES: Okay.
17 MR. BUTTS: -- because you're
19 If you ask a question --
20 MR. BOIES: You've got to let
21 me finish my sentence. I've let him
22 finish every sentence. I've let him
23 finish every sentence. You've got to
24 let me finish my sentence.
25 MR. BUTTS: David, if you ask a

1 question, you have to give the witness

2 a chance to give a complete answer.
3 MR. BOIES: And I am.
4 MR. BUTTS: All right. Let's
5 go. Give a question.
7 Q. Well, have you finished your
8 answer, sir?
9 A. When you're applying business
10 judgment, it's the weight of the scale.
11 Q. Who is applying business
12 judgment?
13 A. In this case, Steve Cutler --
14 Q. Okay.
15 A. -- after talking to the other
16 people and Jes Staley.
17 Q. Okay.
18 A. Okay.
19 Q. I just wanted to understand
20 that Mr. Cutler was applying a business
21 judgment.
22 Now, when Mr. Cutler applies
23 this business judgment, is the criteria for
24 that judgement written down anywhere?

1 You may answer.

2 THE WITNESS: It's all the
3 issues they review about a situation.
5 Q. But is it written down
6 anywhere?
7 A. It's written down the things
8 you should review, but not how you weigh and
9 measure each individual thing. There's no
10 math for that.
11 Q. Where is it written down what
12 you ought to look at?
13
14
15
16
17
18 Q. Is it written down in any

19 JPMorgan document?
20 A. I don't have specific knowledge
21 about the document. I know there's
22 procedures.
23 Q. Without -- what I'm asking is,
24 are these procedures for deciding when you
25 overrule a businessperson's view written down

1 anywhere?
2 A. No, not that I know of. I
3 mean, it might be, but --
4 Q. Okay. Do you think they should
5 be?
7 You may answer.
8 THE WITNESS: I believe it's
9 written -- I believe what's written
10 down, or at least well-known, is the
11 general counsel is the ultimate
12 arbitrator about those decisions.
13 They may not agree with you and let
14 you do it. They may disagree with you
15 and not let you do it.
17 Q. Mr. Dimon, what I'm trying to
18 get you to focus on is the criteria that
19 guides the general counsel in terms of
20 deciding, when do I let the businessperson do
21 something I disagree with.
22 Do you understand that?
23 A. Yes.
24 Q. Okay. And you've told me, I
25 think, that those criteria are not written

1 down anywhere, correct?

2 A. I don't --
3 MR. BUTTS: And you're asking
4 about Cutler?
5 MR. BOIES: Yes.
6 MR. BUTTS: For that period
7 that Cutler is there?
8 MR. BOIES: Yes. Yes.
9 MR. BUTTS: Okay.
11 specifically -- there are things
12 written down. I don't know if they
13 can answer that question.
15 Q. Okay. Do you think they should
16 be written down somewhere?
18 You may answer.
20 Q. That people could reference?
21 A. I am not sure you can write
22 them down in a way that solve -- is trying to
23 get to what you're getting at.
24 Q. Has anybody ever tried?


10 Q. Now, one way of approaching it
11 would be to say anytime the general counsel
12 believes that somebody should be terminated,
13 that's it. You know, he doesn't ever defer
14 to the businessperson. He or she just
15 terminates.
17 You may answer.
18 THE WITNESS: I wish the world
19 were that black and white.
21 Q. Well, there's no reason that it
22 couldn't be that black and white in this
23 particular instance, because all you're doing
24 is deciding who gets to decide, right?

1 You may answer.

2 THE WITNESS: The only way to
3 make a proper decision when you're
4 using judgment is to look at and weigh
5 all the facts and all the issues and
6 hear what people have to say,
7 particularly when it comes to clients,
8 reputation, character, prior problems,
9 future promises.
10 It's silly to say, I will make
11 a decision but not look at any of the
12 relevant facts, and I will not weigh
13 and measure them.
15 Q. My question is, why don't you
16 have a rule that says that the general
17 counsel weighs all those things and makes a
18 decision and never defers to businesspeople
19 who may have a contrary view?
21 You may answer.
22 THE WITNESS: But they're
23 not -- I think -- they're not
24 deferring. If they think it's goes
25 over the line, they do not defer.


2 Q. Where is that line?
3 A. You have to weigh and measure
4 all of the various things, the issues that
5 come up and, you know, that's what you have
6 to do. That's what takes place in business.
7 It's true for every loan you
8 make. It's true for every client we have.
9 Q. Why don't you just let the
10 general counsel weigh that as opposed to
11 having the general counsel defer unless it
12 crosses some unknown line?
13 MR. BUTTS: He's told you five
14 times.
15 MR. BOIES: I don't think he
16 has. But it doesn't make any
17 difference what the two of us think.
19 THE WITNESS: Do you have
20 children?
22 Q. I do.
23 A. Have you told them sometimes, I
24 wouldn't do that, but it's your decision?
25 Q. Absolutely.

1 And you know why?

2 A. But would -- but would you
3 say --
4 MR. BUTTS: Hold on. Hold on.
5 We're talking over each other.
6 THE WITNESS: But would you
7 say, I wouldn't -- if I say, I
8 wouldn't do that, you can never do it,
9 or you listen to what they have to say
10 first?
12 Q. Well, first of all, I would
13 listen to what they have to say.
14 A. Exactly. Bingo.
15 Q. And then with my children, I
16 would sometimes let them do something that I
17 wouldn't, because I think it's important that
18 they have that experience and that they learn
19 to grow and make small mistakes before they
20 have to make big mistakes.
21 But after the general counsel
22 has listened and heard that all, why doesn't
23 the general counsel just make the decision?
25


2 Q. Because he's not trying to
3 teach the businesspeople to make little
4 mistakes, right?
6 THE WITNESS: I don't agree
7 with what you just said. I think
8 there's occasions where you want
9 people to learn and make mistakes, and
10 obviously not related to human
11 trafficking. But it's called
12 management.
13 You weigh and measure things.
14 There are a lot of things to look at.
15 You listen to other people
16 respectfully. And they will always
17 end up in a position where there's a
18 line which they will not allow the
19 business to cross. And there's a line
20 which in they might not agree, but
21 they leave it to the business's
22 business judgment.
24 Q. And that's what happened with
25 Mr. Epstein, right?


3 the extent that your answer is based
4 on discussions with counsel.
6 Foundation.
7 THE WITNESS: I -- it looks
8 that way to me.
10 Q. Okay. Now, I understand that
11 it is your position that the bank didn't do
12 anything illegal, didn't create any liability
13 for itself. And I'm not debating that at
14 this moment. Okay? We'll debate it some
15 other time, but not now.
16 My question has to do with your
17 role as the chairman and chief executive
18 officer of the bank. And in that capacity,
19 do you think that the bank owes an apology to
20 some of the victims of Jeffrey Epstein's sex
21 trafficking that suffered in the period after
22 the bank was proposed to terminate him but
23 didn't?
25 You may answer.

1 THE WITNESS: I think what

2 happened to these women is atrocious,
3 and I'm horrified at the amount of
4 human trafficking that takes place.
5 And I wouldn't mind personally
6 apologizing to them, not because we
7 committed the crime, we did not, and
8 not because we believe we're
9 responsible, but that any potential
10 thing, what little role that we could
11 have eased it or helped catch it
12 quicker or something like that, or get
13 it to law enforcement quicker or get
14 law enforcement to react to it
15 quicker, which they obviously didn't,
16 you know, I would apologize to them
17 for that, yes.
19 Q. Okay. And, for example, would
20 you expect the bank to cooperate with the
21 victims when they were suing Jeffrey Epstein?
24 asked -- I would assume we would and
25 did to the extent we can. But I think

1 that becomes a very legal issue about

2 what we're allowed to do and not
3 allowed to do.
5 Q. To the extent that you were
6 allowed to cooperate, it would have been the
7 right thing to do, right?
9 You may answer.
11 thought we would have done that, yes.
13
14
15
16
17
18
19
20
21
22
23

25 Q. Did you ever ask anybody to

1 investigate whether the bank should

2 criticize, discipline people who were
3 involved in the decision to continue to keep
4 Mr. Epstein as a client?
6 and answered.
8 Foundation.
10 THE WITNESS: It's a part of
11 what Stacey is reviewing. If things
12 come up that rise to that, that will
13 take place.
15 Q. Has anything come up yet?
16 A. If Jes Staley was still here,
17 yes.
18 MR. WOHLGEMUTH: Move to
19 strike.
21 Q. If you had known what you know
22 now when you were asked by Barclays as to
23 whether there was any reason why they should
24 not offer the CEO to Mr. Staley, would you
25 have answered the way you did?


2 You may answer.
5 THE WITNESS: Absolutely not.
7 Q. Okay. Why not?
9 THE WITNESS: At the time when
10 I questioned Jes's judgment, I had no
11 reason to believe that he did anything
12 like the stuff he's being accused of
13 today. Zero.
15 Q. Okay. Is there anything that
16 you have discovered that you believe you
17 should have been told contemporaneously?
19 You may answer, but should not
20 reveal anything you discovered in the
21 context of discussions with counsel.
22 THE WITNESS: Not at the time,
23 no. I mean, with what we know today,
24 you know, possible that someone could
25 have raised some of these issues

1 earlier.
3 Q. But, for example, you now know
4 today about the fact that Mr. Epstein had
5 been convicted in 2008, correct?
6 A. Yes.
7 Q. You now know that Mr. Epstein
8 made consistent, large cash deposits --
9 withdrawals, correct?
11 You may answer.
14 Q. You now know that when he was a
15 customer of the bank, he had accounts opened
16 for a number of girls that he then
17 transferred money into?
19 You should not answer to the
20 extent that you're revealing any
21 information you learned in connection
22 with the litigation through counsel.
23 THE WITNESS: Which was all of
24 it, so...
25 MR. BUTTS: So there you go.


2 Q. Well, you know from bank
3 records that you've seen,
4 that Mr. Epstein was
5 transferring cash to accounts for girls,
6 correct?
9 Q. That didn't just come from your
10 counsel.
11 MR. BUTTS: Hold on. Same
12 objection and instruction.
13 If you have something you'd
14 like him to look at, we're welcome
15 to --
16 MR. BOIES: I don't. No, I'm
17 asking --
18 THE WITNESS: You used the word
19 "girls." I don't know what that
20 means.
21 There are a lot of people on
22 those pieces of paper. I don't know
23 who they were. I don't know what
24 their ages were. I still don't know
25 that today.


3 A. There's work taking place,
4 and...
5 MR. BUTTS: Yeah, that's it.
7 Q. Other than by asking your
8 lawyers, whose answers you won't tell me, did
9 you ever try to find out who these girls were
10 and how old they were?
11 A. When you say by "your lawyers,"
12 you act like I'm standing behind my lawyers.
13 Q. I am.
14 A. The answer is yes.
15 MR. BUTTS: Hold on. Let him
16 finish.
17 THE WITNESS: But the question
18 I asked to get that was from the
19 lawyers.
20 MR. BUTTS: Yes.
21 THE WITNESS: Not because it's
22 legal. Because that's who I delegated
23 it to.
24 MR. BUTTS: David, I think
25 we're at about an hour. So I'll give

1 you another question, if you like, but

2 let's take a break.
3 MR. BOIES: Okay. Sure.
4 MR. BUTTS: Okay.
9 on record. Time is 5:13.
11 Q. I have been told that I did not
12 get an answer to my question. I thought I
13 had, but -- and if I did get an answer, I
14 apologize for asking again.
15 Is there anything that you
16 believe you should have been told
17 contemporaneously that you now know that you
18 were not told?
20 instruction about things you know as a
21 result of communications with counsel.
22 MR. BOIES: And this is -- I'm
23 not asking what they were. I am
24 asking simply whether or not he now
25 knows something about the Jeffrey

1 Epstein episode that he believes he

2 should have been told
3 contemporaneously but was not.
5 THE WITNESS: Essentially, not
6 really.
7 The right people were looking
8 at the facts at the time. That's
9 their job.
11 Q. You're the supervisor of these
12 people. They're your direct reports,
13 correct?
14 A. Yes.
15 Q. And --
16 A. Well, some of them. Some of
17 them, yeah.
18 Q. But certainly Mr. Cutler and
19 Mr. Staley and Ms. Erdoes, all direct
20 reports, correct?
21 A. Yes.
22 I'll take back my answer. Jes
23 Staley should have told me some things. He
24 should have told the group some things. This
25 may have turned out differently.


2 Move to strike.
4 Q. Now, were there things that you
5 believe Mr. Staley knew that Ms. Erdoes did
6 not know?
8 Foundation.
10 reveal anything you learned through
11 counsel. But I think our counter --
12 our claims against Mr. Staley speak
13 for themselves.
14 THE WITNESS: I'm fairly sure
15 that Mary did not know what Jes knew.
17 Q. Can you give me any examples?
19 Foundation.
21 THE WITNESS: Only that I've
22 learned in this process. You know
23 what they are. The Court will know
24 what they are.
25


2 Q. And would your answer be the
3 same with respect to Mr. Cutler as with
4 respect to Ms. Erdoes?
5 A. I have trust and respect in
6 both of them. I think they were both trying
7 to do the right thing.
8 Q. No. No. I apologize. My
9 question wasn't clear.
10 Is there anything that
11 Mr. Staley knew who you believe Mr. Cutler
12 did not know?
13 MR. WOHLGEMUTH: Foundation.
14 MR. BUTTS: Same objections and
15 instruction.
16 THE WITNESS: Of course.
18 Q. Can you give me some examples?
19 MR. BUTTS: I --
20 MR. WOHLGEMUTH: Foundation.
21 THE WITNESS: All the things
22 you already know.
24 Q. Well, but -- I know, but for
25 the record I've got to have --

1 A. You've got to read the stuff

2 that's come out. That's --
3 MR. BUTTS: Yeah, I think you
4 have the record. He's not here to
5 translate what he's learned from us.
6 MR. BOIES: Well --
7 THE WITNESS: Maybe he doesn't
8 know.
9 MR. BUTTS: Yeah. I -- either
10 you or your team has the same
11 discovery we have.
12 MR. BOIES: Well, but he's --
13 THE WITNESS: There are
14 terrible -- there are terrible --
15 MR. BOIES: He's the chief
16 executive, and I'm not.
17 THE WITNESS: There are
18 terrible allegations, which, if true,
19 meant that he knew a lot of things
20 sometime during that period that we
21 didn't. And I would include in that
22 Steve Cutler and Mary Erdoes.
24 Q. But what I'm trying to get at
25 is, what are those serious allegations?

1 MR. BUTTS: Your client

2 testified to them.
3 THE WITNESS: How am I supposed
4 to answer that question? And to the
5 Court, they know what it is.
6 MR. BOIES: What I'm trying to
7 do is get his testimony.
8 THE WITNESS: They are terrible
9 allegations.
10 MR. BOIES: He's the chief
11 executive officer.
12 MS. FRIEDMAN: You want him to
13 say the word "rape" on -- you want him
14 to say "rape." That's what you want
15 him to say?
16 MR. BOIES: Okay.
17 MR. WOHLGEMUTH: This is very
18 strange.
19 MR. BOIES: Let me --
21 Q. Other than -- other than the
22 allegation that Mr. Staley personally engaged
23 in sexual abuse, let me leave that aside.
24 A. Other than that, Mrs. Lincoln,
25 how was the play?

1 Q. No, I understand -- I
2 understand that's a big deal. All right.
3 I'm not minimizing it in the slightest.
4 A. There were other things, like
5 certain visits to islands and -- at which
6 point he might have had knowledge that would
7 have been relevant to the decisions that
8 would be made by JPMorgan.
9 Q. Okay.
10 A. I don't know what he knew when
11 he knew it. But if any of these allegations
12 are accurate, there was significant data he
13 had that other people didn't have.
14 Q. And that it was important for
15 other people to have, particularly
16 Mr. Cutler, correct?
17 A. It would have been definitive.
19 Lacks foundation.
21 Q. I just have a few more things
22 to cover.
23 First, let me ask you to look
24 at Exhibit 147.
25 MR. BUTTS: Do we have that or

1 not yet?
2 MR. BOIES: No, these are...
4 identification.)
6 Q. And then I'm going to go 139
7 and then 161. So you can get those ready.
8 This is an e-mail to you dated
9 July 22, 2019, at 5:13 p.m., attaching a New
10 York Times story.
11 Do you see that?
12 A. Yes.
13 Q. And I want to direct your
14 attention to the last sentence of the second
15 paragraph of that New York Times story.
16 A. Yes.
17 Q. It says, "Over the years,
18 Mr. Epstein had funneled dozens of wealthy
19 clients to Mr. Staley and his bank."
20 Do you see that?
21 A. Yes.
22 Q. Did you read this at the time
23 it was sent to you?
24 A. I believe I did.
25 Q. And did you ask anyone to

1 investigate or determine whether Mr. Epstein

2 had in fact funneled dozens of wealthy
3 clients to Mr. Staley and JPMorgan?
4 A. It is one of the questions I
5 asked our general counsel. It's an absurd
6 notion to think we would turn the eye. And
7 in any event, none of this was material, and
8 we knew all of the clients anyway.
9 Jeffrey Epstein was always
10 representing himself to be something he
11 wasn't, so I just think both sides is wrong.
12 Not that material. He didn't do a lot. He
13 always tried to take credit for stuff.
14 MR. BOIES: Move to strike the
15 answer as nonresponsive.
17 Q. My question is simply whether
18 you asked anyone to investigate or determine
19 whether Mr. Epstein had in fact funneled
20 dozens of wealthy clients to Mr. Staley and
21 JPMorgan.
23 and answered in the first sentence of
24 your preceding answer.
25 THE WITNESS: Yes, and --


2 Q. And who did you ask?
3 A. Stacey Friedman.
4 Q. Did you ask anyone else?
5 A. No, but I -- this one, the
6 answer is not relevant to the company. It's
7 immaterial, and it really didn't happen.
8 MR. BOIES: Move to strike as
9 nonresponsive everything after the
10 word "no."
11 THE WITNESS: Maybe the courts
12 would like to know that.
13 MR. BUTTS: I think so, too,
14 but that will be decided at another
15 day.
17 MR. BUTTS: The court reporter
18 will get it on the transcript and --
19 THE WITNESS: Okay. Yeah.
20 Okay.
22 Q. The --
23 THE WITNESS: So the strike
24 doesn't come off the transcript?
25 MR. BUTTS: That's right. It's

1 just he's preserving that for the

2 record --
3 THE WITNESS: Okay. Okay.
4 MR. BUTTS: -- and somebody
5 will decide it later.
7 Q. Did you ever receive a report
8 from your general counsel as to whether
9 Mr. Epstein had funneled dozens of wealthy
10 clients to Mr. Staley and JPMorgan?
11 A. I --
12 MR. BUTTS: You may --
13 objection.
14 And you may answer that
15 question yes or no.
16 THE WITNESS: I wouldn't say
17 one report, but some information back,
18 yes.
20 Q. Was that report oral or in
21 writing?
22 A. Oral.
23 Q. Who was present when the report
24 was made?
25 A. I think Stacey and maybe some

1 of the other counsel in the room.

2 It wasn't a report. It was
3 just update that -- what was true and what
4 wasn't true.
5 Q. When did you receive that?
7 Q. Approximately?
8 A. Around this article. Before or
9 after.
10 Q. It wouldn't have been before,
11 would it?
12 A. I don't remember exactly when I
13 found out, when all these issues came up and
14 if this is the first story or not, so I don't
15 know exactly when it started. But I
16 certainly got it after, and I certainly got
17 it after these lawsuits started.
18 Q. Now, you then forward this
19 e-mail and article to Kathleen Will, correct?
20 A. Yes.
21 Q. Who is Kathleen Will?
22 A. She's my assistant. Executive
23 assistant.
24 Q. And what was the purpose of
25 forwarding it to Kathleen Will?

1 A. I often forward things I want

2 printed, to be put in my mail wherever I am.
3 It's the procedure.
4 Q. And I take it that was true
5 with respect to this particular e-mail and
6 article?
7 A. Yes.
9 identification.)
11 Q. Let me ask you next to look at
12 Exhibit 139. This is an e-mail from Mary
13 Erdoes to Ms. Friedman and yourself dated
14 July 25, 2019.
15 Correct?
16 A. Yes.
17 Q. Did you have an understanding
18 when you received this why Ms. Erdoes was
19 writing you about Jeffrey Epstein?
20 A. I don't remember receiving it.
21 I'm sure I did, but I don't recall the
22 reason.
23 Q. You know, she is informing you
24 that Jeffrey Epstein was in jail and had a
25 possible suicide attempt.

1 Do you see that?

2 A. Yes.
3 Q. Do you know why she thought you
4 and Ms. Friedman would be interested in that?
6 Q. Had you been told as of this
7 time that Mr. Epstein was a former client of
8 the bank?
9 A. Somewhere around this time, in
10 this envelope of time, yes, I knew that. I
11 just don't know if it was before this or
12 after. It was probably before this, but I
13 don't know.
14 Q. Do you know who told you that?
15 A. I don't recall who specifically
16 told me.
17 Q. Have you discussed with anyone
18 other than counsel the fact that Mr. Epstein
19 was a customer of the bank?
20 A. I think I've already mentioned
21 that Mary and I had brief conversation, and
22 obviously the board was briefed.
23 Q. But the only conversation with
24 Ms. Erdoes or the board was the one that you
25 referred to previously.

1 Is that correct?
2 A. I don't recall exactly the -- I
3 don't -- there may be more than one. I don't
4 recall what the exact conversations were.
5 There may be someone else, too,
6 but I just don't recall anyone else.
7 Q. Would you tell me the full
8 extent of what you recall about your
9 communications with Ms. Erdoes about
10 Mr. Epstein?
12 and answered.
13 THE WITNESS: I think I did.
14 How terrible it was that she was the
15 one who had to go to his house to fire
16 him and that more information would be
17 coming out. So I don't remember
18 anything more specific than that.
20 Q. And did you ever tell the board
21 anything about Mr. Epstein?
24 the extent you're revealing
25 discussions with Ms. Friedman and the

1 board.
2 THE WITNESS: I don't remember
3 what I told the board. She briefed
4 the board on several occasions.
6 Q. But you don't remember anything
7 that you told the board about Mr. Epstein?
9 Q. Do you remember anything
10 generally that you told the board?
11 A. I may have simply relied on
12 Stacey doing it. I may have made a comment.
13 I just don't remember.
14 Q. If you made a comment, you
15 don't remember what the comment was.
16 Is that correct?
17 A. I can guess.
18 MR. BUTTS: Don't guess.
21 Q. Well, no, unlike some other
22 counsel, I want you to guess.
23 MR. BUTTS: I don't.
24 MR. BOIES: But you don't get
25 to choose.

1 MR. BUTTS: Yeah.

2 MR. BOIES: I'm entitled to get
3 what he characterizes as a guess.
5 him. That I'd never met him. I
6 hadn't gone to his house. I hadn't
7 gone to his island. That this is
8 terrible.
10 identification.)
12 Q. Okay. Let me ask you to look
13 at a document that has been marked as
14 Exhibit 161.
15 This purports to be a letter to
16 you from .
17 MR. BUTTS: Where did you get
18 this? I don't see a Bates number on
19 it.
20 MR. BOIES: This is a letter
21 that was sent to Mr. Dimon.
22 MR. BUTTS: No, I know, but
23 where did you get it? I don't see a
24 Bates number on it.
25 MR. BOIES: I got it from

1 .
2 MR. BUTTS: And why didn't you
3 produce the documents that you were
4 planning on asking Mr. Dimon about?
5 MR. BOIES: I didn't know that
6 that was obligated.
7 MR. BUTTS: Well, it is.
8 MR. BOIES: Well, what is the
9 obligation to have -- to see all the
10 documents that we're going to raise?
11 MR. BUTTS: Yeah. Well,
12 there's been countless discovery
13 requests to the plaintiffs for
14 everything related to this. And it
15 seems like you've had something that
16 you withheld, and now you're trying to
17 use it in a deposition, and two days
18 left of discovery.
19 MR. BOIES: I haven't withheld
20 anything. This is a document that was
21 sent to him.
22 MR. BUTTS: Well, you got it.
23 MR. BOIES: This was sent to
24 him contemporaneously.
25 MR. BUTTS: Yeah.

1 MR. BOIES: All right? This is

2 something that one of the -- one of
3 the -- one of the survivors sent to
4 him.
5 MR. BUTTS: Yeah.
6 MR. BOIES: And I just want --
7 I want to know whether he got it,
8 whether he --
9 MR. BOUCHOUX: How do we know
10 it's from ?
11 MR. BOIES: What?
12 MR. BOUCHOUX: What's your
13 basis? You're representing it's from
14 her?
15 MR. BOIES: I can't personally
16 represent it.
17 MR. BOUCHOUX: It's your
18 exhibit, sir.
19 MR. BOIES: What? Yeah, it's
20 my exhibit because I'm told that this
21 was sent.
22 If he tells me that he didn't
23 get it, the first question is just, is
24 this a document -- is this something
25 that you received.

1 MR. BUTTS: So we'll object to

2 the line.
3 Go ahead, subject to that
4 objection.
5 MR. BOIES: Okay. Fine.
7 this specific document, no.
9 Q. Did you receive -- do you
10 recall receiving letters from any of the
11 survivors?
12 A. I don't, but I can't say it
13 didn't happen. And generally they would be
14 given directly to the general counsel.
15 Q. I'm sorry, you said?
16 A. And generally they'd be handed
17 directly to the general counsel.
18 Q. That is, you would not even
19 read them?
20 A. I don't remember getting this,
21 and I might have. I don't remember. I'm
22 sorry.
23 Q. Okay.
24 A. And I have enormous sympathy
25 for her, okay?

1 Q. And the reason I raise it is --

2 and I don't have personal knowledge about
3 this. But my understanding was that she did
4 write you and that you -- she never got a
5 response. And I just wanted to understand
6 whether you had gotten it and whether this is
7 something that was the kind of thing that you
8 would respond to.
9 MR. BUTTS: Yeah, and he told
10 you he doesn't know.
11 THE WITNESS: I don't know.
13 Q. Okay. Let me ask you about an
14 answer that you gave this morning to other
15 counsel.
16 You said that you wanted to
17 review the facts to be sure we did the right
18 thing.
20 A. I assume it's accurate.
21 Q. Have you done anything to be
22 sure that the bank did the right thing, other
23 than ask your general counsel to do whatever
24 it is the general counsel is doing?
25 A. That's who I assigned the task

1 to.
2 Q. And that's the only person you
3 assigned the task to?
4 A. No, that person has lots of
5 other people she's running --
6 MR. BUTTS: Hold on. Let him
7 finish, please.
8 THE WITNESS: She's running the
9 group that's doing the work, both
10 looking backwards and looking forward.
12 Q. My question is, have you
13 assigned a portion of these tasks to members
14 of that group, or have you assigned it to her
15 and given her the responsibility to assign it
16 to people that she needs to reassign it to?
17 A. I give it to her.
18 Q. Okay. That's what I was
19 asking.
20 A. Okay.
21 Q. The only person that you have
22 reached out to on this is her, understanding
23 she's got a whole group.
24 A. Well, there are a lot of people
25 here, a lot of smart people, so, yeah. And

1 she has to get all the right people involved.

2 Q. No, I understand.
3 A. Okay.
4 Q. Before I close, is there
5 anything that you have not said today that
6 you would like to say to the victims of
7 Jeffrey Epstein?
9 You may answer.
10 THE WITNESS: I think I've
11 already made a statement twice about
12 how sorry I am to any woman that was
13 hurt by this monstrous man. It's
14 terrible. I hope you get justice
15 against the people who perpetrated the
16 crime, and so sorry it happened.
18 Q. Is there anything that you'd
19 like to say to the victims about what
20 responsibility, if any, JPMorgan takes for
21 that?
23 and answered.
24 THE WITNESS: Not while we're
25 having a lawsuit, no.

1 MR. BOIES: Okay. Thank you

2 for your time.
3 The -- I yield back my time to
4 whoever -- if anybody wants to use it.
6 record. The time is 5 --
7 MR. BUTTS: No, keep it going.
8 Keep it going.
9 VIDEOGRAPHER: You want me to
10 stay on?
11 MR. BUTTS: Yes.
12 VIDEOGRAPHER: Okay.
13 MR. BOUCHOUX: Can we get a
14 time check?
15 VIDEOGRAPHER: The total is
16 6:10.
17 MR. BOUCHOUX: 6:10. Thank
18 you.
19 REDIRECT EXAMINATION
21 Q. All right, Mr. Dimon, while
22 everyone's getting settled, in the interest
23 of time, is there anybody else who receives
24 e-mails on your behalf?
25 A. Yeah.

1 Q. Who else receives e-mails on

2 your behalf?
3 A. Judy Miller, my chief of staff.
4 Q. And who is that?
5 A. She's my chief of staff.
6 Q. Okay. And I'm sorry, what is
7 that person's name?
8 A. Judy B. Miller.
9 Q. Okay. And other than
10 Ms. Miller, is there anybody else who
11 receives e-mails for you?
12 A. Well, Kathleen Will, my
13 assistant, and a woman called Ruth Peterson,
14 who works for both my chief of staff and me.
15 Q. And does anybody other than
16 those three individuals, or including those
17 three individuals, ever send e-mails on your
18 behalf?
19 A. Other than those three?
20 Q. Yes.
21 A. When you say on my behalf, I'm
22 sure people do a lot of things they say is on
23 my behalf.
24 Q. Understood.
25 A. But if the e-mail is coming out

1 of my office, it's coming from one of the

2 four of us.
3 Q. Okay. And do those three
4 individuals sometimes, in fact, send e-mails
5 from your office?
6 A. Yes.
7 Q. And you mentioned that you had
8 Ms. Will, I think, sometimes print e-mails to
9 send to you.
10 A. Yes.
11 Q. What happens to those
12 e-mails -- those printouts of the e-mails?
13 A. They get sent to me at home or
14 wherever I am around the world or -- because
15 I like -- I'm still a hardcopy reader. And
16 in the car when it comes to pick me up.
17 Whatever it is.
18 Q. Okay. And by the way, when I
19 asked about people sending or receiving
20 e-mail for you, is that addressed to your
21 e-mail address or theirs?
22 A. It -- when you say "for" me, it
23 depends. Sometimes on my behalf, but it's
24 not directly from my e-mail account. Often
25 it's from my e-mail account is me talking to

1 you. I may dictate what that is, but it's

2 from my e-mail account.
3 Q. But if, for instance, Ms. Will
4 was sending an e-mail for you, would she do
5 it from your Jamie Dimon e-mail account or
6 from her own e-mail account?
7 A. If it's for me, it's almost
8 always from the Jamie Dimon account.
9 Q. Okay.
10 A. If it was from her own account,
11 it would be she's just asking a question of
12 someone on my behalf, like what time is --
13 yeah.
14 Q. And when Ms. Will or Ms. Miller
15 or anyone else you mentioned is receiving an
16 e-mail for you, is that from the Jamie Dimon
17 account or at their own e-mail addresses as
18 well?
19 A. Both.
20 Q. Okay. And do you keep a -- as
21 a paper person, do you keep a hardcopy
22 calendar?
23 A. Yes.
24 Q. And how long have you kept a
25 hardcopy calendar? Is that going back in

1 time?
2 A. I think so, yes.
3 Q. Okay. And do you keep your
4 calendar from year to year?
5 A. As long as it's required by
6 law. And maybe longer.
7 Q. Okay. And does anybody
8 regularly delete e-mails from your e-mail
9 account?
11 You may answer.
12 THE WITNESS: All the time.
14 Q. Do you know how often?
15 A. Yeah. Every e-mail gets
16 deleted at one point.
17 Q. And do you think how long your
18 e-mails are saved?
19 A. Whatever the law is, they're
20 saved that long. And in my case, longer. I
21 think it's seven years, and then probably
22 goes back a lot more than that for me.
23 Q. Okay.
24 A. They're deleted from my
25 account. They're not deleted from the firm.

1 Q. Understood.
2 A. Yeah.
4
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

10
11
12
13
14
15
16
17
18
19
20

23 Q. Next question --
24 MR. BUTTS: Are we off that
25 section?

1 MS. SINGER: We are. We're

2 back to non-BSA-sensitive. Thank you.
4 identification.)
6 Q. I want to show you what we will
7 mark as -- we're going to call it Exhibit 21,
8 and it is JPM-SDNYLIT-00390677.
10 e-mail from Ann Borowiec? Have I -- do you
11 recognize that name?
12 A. Yes.
13 Q. And who is she?
14 A. She was a senior private banker
15 at the time.
16 Q. And it's dated 1/25/2007.
17 Do you also know Maria
18 Rivera-Jones? Is that a name that's familiar
19 to you?
21 Q. Okay. If we look down the
22 chain -- I'm sorry.
23 First of all, the subject at
24 the top, you can see, Forward: Epstein client
25 referrals.

1 Do you see that subject line?

2 A. Where does it say that?
3 Q. The subject line at the very
4 top.
5 A. Yes.
6 Q. Okay. And again, going down
7 halfway down, it indicates, " is a
8 prospect of Dennis Sheeran, CEO, and a
9 prospect of Andrew Young, fin spon."
10 I take it CEO there corresponds
11 to CEO of the private bank or some division.
12 Is that right?
14 You may answer.
16 Dennis Sheeran.
18 Q. Okay. And fin spon, do you
19 understand that to mean financial sponsor or
20 something else?
21 A. Financial sponsor, I
22 understand, yes.
23 Q. Okay. Okay. And let's go to
24 the attachment, which is the third page I
25 gave you.

1 Can you see that it lists

2 as the second name on this list?
3 A. What page are you on?
4 Q. I'm on the very last page, the
5 third page.
6 A. Yes.
7 Q. All right. And you see
8 listed as status prospect, correct?
9 A. Yes.
10 Q. Okay. And was it your
11 understanding that -- and forgive
12 me if I'm treading ground that was covered --
13 was a prospect referred by Jeffrey Epstein?
15 instruction about --
16 THE WITNESS: No one needed a
17 Jeffrey Epstein referral to get to
18 . He was a major client of
19 the firm already, at least in the
20 corporate side, and for all I know,
21 he's a client of the private bank
22 before that.
24 Q. Although here he's listed as a
25 prospect.

1 Is that not right?

2 A. That's what it lists. I don't
3 know if it's true.
5 identification.)
7 Q. Okay. We're also going to take
8 a look at Exhibit 22, JPM-SDNYLIT-00150148_R.
9 Do you recognize Project Jeep,
10 Mr. Dimon?
11 A. I do not.
12 Q. Okay. So this document is
13 headed "Project Jeep - Client Review October
14 2019."
15 Correct?
16 A. Yes.
17 Q. And have you seen this document
18 before?
19 A. No.
20 Q. At the top --
22 Q. Okay. At the top, it indicates
23 that it is reviewing three client
24 relationships related to Jeffrey Epstein
25 media.

1 Correct?
2 A. Yes.
3 Q. Okay. And one of those, if you
4 look about a third of the way down, is
5 , correct?
6 A. Yes.
7 Q. And if we turn to the second
8 page, Bates number 148, you can see that the
9 relationship assets are valued at,
10 when you add them together, $465 million.
11 Is that correct?
12 A. That's what this says.
13 Q. And do you have any independent
14 knowledge of the value of assets
15 at JPMorgan in 2019?
16 A. I don't.
17 Q. Okay. You can put that one
18 aside, please.
19 We saw on JPMorgan's privilege
20 log for this deposition an October 4, 2019
21 e-mail to you about Project Yellow.
22 Are you familiar with Project
23 Yellow?
25 Q. Okay. You don't have any sense

1 of what that term is?

2 A. No.
4 identification.)
6 Q. All right. Let's turn to
7 Exhibit 25, I think? No? 23. And it's
9 And if you look down the
10 chain -- well, first of all, this is an
11 e-mail from James Dalessio to a number of
12 other people at JPMorgan, correct?
13 A. Yes.
14 Q. And if you look at the subject
15 line here, it indicates, Forward: Jamie Dimon
16 review.
17 Is that correct?
19 Q. And it's dated March 13, 2013,
20 correct?
22 Q. And at the bottom of the
23 page --
24 MR. BUTTS: Are you talking
25 about the bottom of the first page --

1 or the lowest one on the e-mail

2 string?
3 MS. SINGER: I think they're
4 all March 13th.
5 MR. BUTTS: Well, I just want
6 to know which one, bottom.
7 MS. SINGER: Okay. Yes, so I'm
8 sorry.
10 Q. The bottom of the --
11 MR. BUTTS: There's a back
12 page.
14 Q. -- page you're on, you'll see a
15 chart.
16 A. Oh, let me just look. Yeah.
17 Q. And you can see that Jason
18 Snodgrass --
19 And is that a name that's
20 familiar to you?
21 A. No.
22
23
24
25

1 And PB/JPMS, does that refer to

2 JPMorgan investment?
6 PB means in this context. JPMS was
7 probably the brokers from Bear
8 Stearns.
10
11
12
13
14
15
16 Q. And do you understand, or do

17 you have any knowledge or recollection, as to
18 why those were being gathered for you?
20 THE WITNESS: I ask a lot of
21 questions. I probably asked them that
22 question, and they made it part of the
23 business review.
25 Q. Okay. And do you recall that

1 it was in January of 2013 that JPMorgan

2 entered into a cease and desist consent order
3 with the Office of the Comptroller of
4 Currency?
5 A. I don't recall the date, but,
6 yes, I do remember the consent order, yeah.
7 Q. And does that refresh your
8 recollection in any way as to whether this
9 report to you may have been related to that
10 consent cease and desist order?
12 You may answer.
13 THE WITNESS: I don't remember,
14 but it may have been what prompted me
15 to ask.
17 Q. Okay. We can put that document
18 aside.
19 All right. Were you aware,
20 Mr. Dimon, of efforts at JPMorgan to launch a
21 donor-advised fund with and
22 ?
23 A. Only as a result of this --
24 these lawsuits.
25 Q. Okay. So at no time --

1 A. Or what came out with Epstein

2 before.
3 Q. So prior to 2015, were you
4 aware of efforts at JPMorgan to launch a
5 donor-advised fund with through
6 ?
7 A. I don't -- I was not, no.
8 Q. Okay. So I take it you also
9 were not aware that Jeffrey Epstein played a
10 role in those discussions?
12 You may answer.
13 THE WITNESS: Oh, absolutely I
14 was not aware. Nor do we need Jeff
15 Epstein to talk to .
17 Q. Were you aware that Mary Erdoes
18 and Jes Staley had regular communications
19 with Jeffrey Epstein about that donor-advised
20 fund?
21 A. I am now.
24 Q. And were you aware that the
25 hope was that donor-advised fund would reach

1 $100 billion?
3 THE WITNESS: You got me there.
5 Q. Is that the kind of initiative
6 that would typically be brought to your
7 attention as CEO?
9 You may answer.
10 THE WITNESS: No. People
11 dreaming about $100 billion DAF fund
12 would not be brought to my attention.
13 And they would do work on it before
14 they thought it was real.
15 And it never came to -- as far
16 as I know, it never came to fruition.
17 And plus, I don't think Jeff Epstein
18 would ever have been a part of it.
20 identification.)
22 Q. Okay. Let's look at what we'll
23 mark as Exhibit 24. ESTATE_JPM003729.
25 e-mail exchange between Jeffrey Epstein and

1 Jes Staley, correct?

2 A. Yes.
3 Q. And it says, "I understand
4 Jamie invited" -- forgive the spelling --
5 " to Miami in Jan. I would like to get
6 the DAF faster than that. Some of the
7 foundation people are suggesting it get its
8 big announcement then. Everyone moves so
9 slow."
11 A. You did.
12 Q. And did -- do you recall
13 inviting to an event or meeting in
14 January in 2011?
16 You may answer.
17 THE WITNESS: I recall inviting
18 him to many events, and I'll take it
19 at face value here.
21 Q. Okay. But you don't have a
22 specific recollection of an event in Miami in
23 2011 with ?
24 A. No. We do large investment
25 events in Miami in January, so -- and we can

1 get the records if you want.

2 Q. Okay. But I'm asking again.
3 Do you have a recollection?
6 identification.)
8 Q. Okay. Let's look at
9 ESTATE_JPM027395. And we'll mark that
10 Exhibit 25.
11 And this is an e-mail chain
12 between and Jeffrey Epstein
13 dated Sunday, August 28, 2011.
14 Do you recognize the name
15 ?
16 A. Only if I reviewed it with
17 these guys at one point.
18 Q. Okay. But you don't have any
19 recollection as you sit here today
20 independent of that?
21 A. No.
22 Q. Okay. And it says, "The invite
23 itself came from Jamie Dimon, but I think
24 that Erdoes instrumented it. If easy to
25 postpone, it might be a good idea. You can

1 see," tomorrow, "TMR what is the extent of

2 damage."
3 Do you have any recollection of
4 Mary Erdoes arranging for you to invite
5 to an event?
7 You may answer.
9 the specific event. That happened
10 typically, yes.
12 Q. Okay. Do you know Ace
13 Greenberg?
14 A. I did. He's dead.
15 Q. I should have asked it in the
16 past tense. I'm sorry.
17 And who did you know him to be?
18 A. The chairman of Bear Stearns.
19 And then when we bought Bear Stearns, he came
20 over as an investment advisor.
21 Q. Okay. And you know him
22 personally, or you knew him personally, I
23 take it?
24 A. For 40 years.
25 Q. I'm sorry.

1 Did Ace Greenberg ever talk to

2 you about his desire that JPMorgan retain
3 Jeffrey Epstein as a client of the bank?
4 A. He did not.
5 Q. Okay. You've talked a little
6 bit about Jes Staley's departure from
7 JPMorgan and the terms and tenor of his
8 departure.
9 Is one of the reasons for Jes
10 Staley's departure from JPMorgan your
11 understanding that Mr. Staley had made
12 unauthorized statements to the press about
13 the London Whale?
15 You may answer.
16 THE WITNESS: That was a part
17 of it.
19 Q. And what were those statements,
20 to your understanding?
22 You may answer.
24 specifically today.
25


2 Q. Were the statements that you
3 understood Mr. Staley had made to the press
4 about London Whale related to your role in
5 the London Whale?
7 You may answer.
8 THE WITNESS: Probably. I just
9 don't recall specifically.
11 Q. And why do you say "probably"?
13 You may answer.
14 THE WITNESS: I just don't
15 recall specifically.
17 Q. And did, to your knowledge,
18 Mr. Staley make any effort to have you
19 displaced as CEO or chairman of JPMorgan as a
20 result of the London Whale?
22 You may answer.
24 Q. Trade or for any other reason?
25 A. For what?

1 Q. As a result of London Whale

2 trade or for any other reason.
3 A. I think there's some evidence
4 of that, yeah.
5 Q. And what is that evidence?
6 A. He at one point admitted to me
7 that he should have made that call, and he
8 thought I'd lose my job and that he could be
9 the guy and...
10 Q. And when was that conversation?
11 A. Which, of course, just so you
12 know, never would have happened. Because
13 there's no way that -- and he would have been
14 asked to leave the company anyway, the London
15 Whale aside. And the board never would have
16 put him in the job.
17 Q. Again, I have to remember my
18 question.
19 When was that conversation?
21 dates.
22 Q. Was it before or after
23 Mr. Staley had left JPMorgan?
24 A. Which conversation?
25 Q. The conversation between you

1 and Mr. Staley about efforts to displace you

2 as CEO.
3 A. It was before.
4 Q. And you said you had concerns,
5 I think, about Mr. Staley's judgment.
6 Is that correct?
7 A. Some of his judgment, yes.
8 Q. Okay. And you said you
9 conveyed those concerns to Barclays in the
10 context of --
11 A. I did not.
12 Q. Okay.
13 MR. BUTTS: He did not say
14 that.
15 MS. SINGER: Okay.
16 THE WITNESS: I did not say
17 that, yeah.
18

20 Q. Okay. But you did have
21 concerns that you, I think, indicated you
22 would have voiced to Barclays?
24 THE WITNESS: I was very
25 specific. The chairman called me up

1 and asked me a very specific question,

2 I said no.
3 I was asked a question later on
4 that had -- if I knew what I know
5 today, would I have said no, that
6 the -- no deep concerns about Jes's
7 stuff. I definitely would have
8 answered differently.
10 Q. Okay.
11 A. It would have been yes.
12 Q. I misunderstood your prior
13 answer.
14 A. Okay.
15 Q. And the question to which you
16 answered no was whether -- I'm sorry. Let's
17 just be clear, and I won't try to speak for
18 you.
19 What was the question you were
20 asked by the -- by Barclays about Jes Staley
21 to which you answered no?
22 A. There were already rumors about
23 him becoming the CEO, which I had heard
24 extensively with people. I thought they had
25 already offered him the job.

1 John McFarlane, who I believe

2 was the chairman at the time, basically
3 crossing a T and dotting an I, called me up
4 and asked me something like -- I don't
5 remember the exact question -- is there any
6 deep reason you know about that Jes should
7 not be the CEO of Barclays, to which I
8 responded no. There were no additional
9 questions.
10 Q. Okay. After Mr. Staley became
11 the CEO of Barclays, he hired several
12 employees from JPMorgan.
13 Is that correct?
15 You may answer.
16 THE WITNESS: When you say
17 "from," they were current employees of
18 JPMorgan?
19 Yeah, I -- several people, some
20 of who were not current employees.
21 But, yes, he did. Yeah.
23 identification.)
25 Q. Okay. And -- well, let's turn

1 to the Irish Times article. We'll mark that

2 as Exhibit 26.
3 So Exhibit 26 is an article
4 titled "Barclays hirings come under scrutiny
5 in US. Department of Justice is exploring
6 whether it broke antitrust laws and no poach
7 promise to JPMorgan."
8 Have you seen this article
9 before?
10 A. I vaguely remember seeing it,
11 yes.
12 Q. Okay. Let's turn to page 3.
13 And in the -- about two-thirds of the way
14 down it indicates, "Defectors from JPMorgan
15 to Barclays last year include," and it gives
16 a list of names, Tim Throsby, Paul Compton,
17 and then I'm not even going to try to say the
18 last name. Maybe you can.
19 A. Uh-huh.
20 Q. CS --
21 A. Vencat. We call him Vencat.
22 Q. Okay. Is that accurate, that
23 these three individuals were hired to
24 Barclays from JPMorgan?

1 You may answer.

2 THE WITNESS: I believe they
3 went from JPMorgan to Barclays. There
4 may have been a stop in between,
5 but...
7 Q. And were there others who were
8 hired from JPMorgan to join Barclays after
9 Mr. Staley became CEO?
11 You may answer.
13 I'm sure there are. I don't recall
14 specifically.
16 Q. Okay. And then the article on
17 the first page indicates that -- in the third
18 paragraph down. I'm sorry, it's the first
19 full page, so the second page of the article.
20 A. Uh-huh.
21 Q. If you look at the third
22 paragraph. "The Financial Times reported
23 last year that Jamie Dimon, the head of
24 JPMorgan, called John McFarlane, Barclays'
25 chairman, to complain about the defections.

1 It was also reported Mr. Staley then spoke to

2 Daniel Pinto, the head of JPMorgan's
3 investment bank."
4 Do you recall a conver -- let
5 me ask this. Did you have a conversation
6 with the chairman of Barclays, John
7 McFarlane, about the hirings of former or
8 current JPMorgan employees to Barclays?
10 What's the relevance of this to
11 this case? We're in hour 6.
12 MS. SINGER: It has to do with
13 the relationship between Mr. Dimon and
14 Mr. Staley, who y'all have then
15 pleaded.
16 I'm almost done.
17 MR. BUTTS: You should be done
18 quickly, because we're way afield.
19 MR. WOHLGEMUTH: I disagree.
21 Q. So, Mr. Dimon, was that --
22 A. I do remember a conversation
23 like that.
24 Q. Okay. And I take it it was a
25 contentious conversation, that you weren't

1 pleased about the hiring?

3 You may answer.
4 THE WITNESS: Not really.
5 Calling up to complain about something
6 is not contentious. He kind of agreed
7 with me, they hired too many people
8 from Barclays {sic}. There was no
9 poaching agreement.
10 If you got the data, you'd see
11 the companies continue to hire from
12 each other every month and every day,
13 which is why the DOJ never followed up
14 on this.
16 Q. Okay. But it was of enough
17 concern that you reached out to the chairman
18 of Barclays, correct?
20 THE WITNESS: Yes. Yes.
22 Q. Okay. Okay. We can leave
23 this.
24 You indicated, I think, that
25 there were other reasons for Mr. Staley's

1 departure, that the London Whale and comments

2 about the London Whale in the effort to,
3 however futile, dislodge you were among the
4 reasons for Mr. Staley's departure.
5 What were the other reasons?
7 You may answer.
8 THE WITNESS: I said that it
9 would have happened anyway.
10 Jes wasn't up to running the
11 investment bank. He had all the
12 senior people complaining. He didn't
13 go to risk meetings. He wasn't
14 effective at client briefings and et
15 cetera.
16 I had complaints from -- he
17 didn't go to the trading floors. He
18 didn't get involved in major
19 decisions. That he'd have a
20 management meeting and they -- then a
21 small group would go make decisions
22 away from the management meeting.
23 I told him all of this early
24 on, which was a bridge too far for
25 him.


2 identification.)
4 Q. All right. Let's turn to what
5 we'll mark as Exhibit 27.
6 All right. Are you familiar
7 with a Claman Countdown on Fox News?
8 A. I know her, yes.
9 Q. Okay. And this is very rough
10 transcript from a story that ran May 18,
11 2023.
12 Do you see that at the bottom?
13 A. I take your word for it.
14 Q. Okay.
15 A. I do not see it.
16 Q. Fox Business, May 18, 2023, the
17 bold text. Right?
18 A. That was like a couple days
19 ago, yeah.
20 Q. Okay. Okay. The last
21 paragraph says, "Internally, he," referring
22 to you, "has been saying this is a huge
23 mistake. He should have monitored his direct
24 reports," Liz asked Jeff Staley. The
25 response. "Jeff Staley, as you know,

1 JPMorgan is suing Jeff Staley as a matter of

2 fact."
3 Have you indicated internally
4 that you should have monitored Jes Staley
5 more closely?
7 THE WITNESS: I think these are
8 now third- and fourth-hand kind of
9 comments from people who heard me and
10 told her on TV.
11 I think that I have mentioned
12 enjoying a huge regret knowing what we
13 know today.
14 And we're suing Jes Staley
15 because we don't think he told us what
16 he knew, and the decisions may have
17 come out differently.
19 Q. Okay. And did you also say
20 internally that you felt that you should have
21 monitored Mr. Staley more closely?
22 A. I don't recall saying that to
23 anyone internally.
24 Q. Okay. And do you believe you
25 should have monitored him more closely?

1 A. At the time, no.

2 Q. Okay. I think my last
3 question.
4 At a town hall for JPMorgan
5 employees, I think in the Philippines in
6 2011, you said, "The most" -- and I'll quote.
7 Quote, "The most important thing we do
8 every" --
9 A. Pretty good you get information
10 like that.
11 Q. What?
12 A. It's pretty good you get
13 information from a town hall in the
14 Philippines.
15 Q. "The most important thing we do
16 every day is manage our exposures and our
17 risk. I don't just mean credit risk. I also
18 mean who we take on as clients. We should
19 only do first-class business in a first-class
20 way," close quote.
21 Do you agree with that
22 statement?
23 A. Yes.
24 MS. SINGER: I have nothing
25 further.

1 MR. BUTTS: Okay.

2 MR. BOIES: Done.
3 MR. BUTTS: We are done.
4 I will say as a parting one,
5 I'll just remind everybody of the
6 protective order. We've gotten word
7 that some other depositions and
8 redacted information has gone to
9 reporters.
10 I'm going to trust you that you
11 will be abiding by it. We certainly
12 will as well.
13 Have a nice weekend.
14 MR. BOIES: Yeah, and just --
15 and this whole thing is now designated
16 confidential. Is that --
17 MR. BUTTS: That's correct.
18 MS. FRIEDMAN: Right.
19 But the last time we didn't
20 designate something confidential, the
21 whole transcript went to The
22 Washington Post.
23 MR. BOIES: The what?
24 MS. FRIEDMAN: The whole
25 transcript went to The Washington

1 Post.
2 MS. SINGER: Are we off the
3 record?
4 MR. BUTTS: With possession --
5 no, we can keep it on the record.
6 Someone with possession of
7 confidentially designated information
8 from the Erdoes transcript leaked it
9 to The Washington Post. It was not
10 anybody from here.
11 I'm not going to point fingers,
12 but I'm going to say that we're -- I'm
13 going to give you all of that as a
14 cautionary tale to ask you to make
15 sure that people on your teams are
16 doing what they're supposed to be
17 doing.
18 MS. SINGER: I think that's
19 well directed.
20 THE WITNESS: Is that illegal
21 or just unethical?
22 MR. BUTTS: Both.
23 MR. BOIES: I think that's
24 fair.
25 MS. SINGER: Well directed all

1 around.
2 VIDEOGRAPHER: Okay. Can we go
3 off?
4 MR. BUTTS: Yes.
5 MS. SINGER: Yes.
6 VIDEOGRAPHER: All right.
7 We're going off record. This
8 concludes today's deposition. The
9 time is 6:07.
10 (Deposition concluded at 6:07 p.m.)
11 – – – – – – –
12
13
14
15
16
17
18
19
20
21
22
23
24
25

1 CERTIFICATE
2 I, CARRIE A. CAMPBELL, Registered
Diplomate Reporter, Certified Realtime
3 Reporter and Certified Shorthand Reporter, do
hereby certify that prior to the commencement
4 of the examination, James Dimon, was duly
sworn by me to testify to the truth, the
5 whole truth and nothing but the truth.
6 I DO FURTHER CERTIFY that the
foregoing is a verbatim transcript of the
7 testimony as taken stenographically by and
before me at the time, place and on the date
8 hereinbefore set forth, to the best of my
ability.
9
I DO FURTHER CERTIFY that I am
10 neither a relative nor employee nor attorney
nor counsel of any of the parties to this
11 action, and that I am neither a relative nor
employee of such attorney or counsel, and
12 that I am not financially interested in the
action.
13
14
15
____________________________
16 CARRIE A. CAMPBELL,
NCRA Registered Diplomate Reporter
17 Certified Realtime Reporter
Notary Public
18
19
20
21
22
23
Dated: May 31, 2023
24
25

1 INSTRUCTIONS TO WITNESS
2
3 Please read your deposition over

4 carefully and make any necessary corrections.
5 You should state the reason in the
6 appropriate space on the errata sheet for any
7 corrections that are made.
8 After doing so, please sign the
9 errata sheet and date it. You are signing
10 same subject to the changes you have noted on
11 the errata sheet, which will be attached to
12 your deposition.
13 It is imperative that you return
14 the original errata sheet to the deposing
15 attorney within thirty (30) days of receipt
16 of the deposition transcript by you. If you
17 fail to do so, the deposition transcript may
18 be deemed to be accurate and may be used in
19 court.
20
21
22
23
24
25

1 ACKNOWLEDGMENT OF DEPONENT
2
3
4 I,______________________, do
hereby certify that I have read the foregoing
5 pages and that the same is a correct
transcription of the answers given by me to
6 the questions therein propounded, except for
the corrections or changes in form or
7 substance, if any, noted in the attached
Errata Sheet.
8
9
10
11
12 ________________________________________
James Dimon Date
13
14
15 Subscribed and sworn to before me this
16 _______ day of _______________, 20 _____.
17 My commission expires: _______________
18
19 Notary Public
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Jamie Dimon Deposition in U.S. Virgin Islands v. JP Morgan

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Confidential - Pursuant to Protective Order

1 UNITED STATES DISTRICT COURT

Golkow Litigation Services Page 1

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1 WILLIAMS & CONNOLLY LLP

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1 VIDEOGRAPHER: We are now on

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1 Q. Did you speak with Mr. Staley

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1 A. Not to my knowledge, no.

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1 MR. BUTTS: Are you asking what

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1 state what that objection is? Because

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1 In 2006, what was Mary Casey's

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1 bank had access to numerous press reports

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1 Q. And what was Catherine

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1 examine the relationship between Mr. Epstein

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1 QUESTIONS BY MR. SULLIVAN:

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1 A. I don't think so. I may have

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1 customarily read New York newspapers?

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1 Mr. Epstein from any source other than an

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1 A. Not that I recall.

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1 remain a customer of the bank due to his

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1 A. 270 Park Avenue.

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1 additional six months for procuring a person

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1 have a conversation with Jes Staley about the

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1 the same floor as your office, correct?

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1 2009 with respect to Mr. Epstein and his

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1 Q. Did Mary Erdoes ever explain to

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1 MR. BUTTS: Objection. Form.

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1 not sure we need the -- that now, but...