EXH-4 BI-3 LED UN-5 DER EA-5 Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS CASE NO Plaintiff JSR JPMORGAN CHASE BANK N.A Defendant/Third Party Plaintiff JPMORGAN CHASE BANK N.A Third Party Plaintiff JAMES EDWARD STALEY Third Party Defendant CONFIDENTIAL ATTORNEYS EYES ONLY May Videotaped deposition of WILLIAM LANGFORD taken pursuant to notice was held at the law offices of Boies Schiller Flexner LLP Hudson Yards New York New York and remotely beginning at a.m on the above date before Michelle Gray a Registered Professional Reporter Certified Shorthand Reporter Certified Realtime Reporter and Notary Public GOLKOW LITIGATION SERVICES ph deps golkow.com Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa that that is a fair characterization of the initiative A Yes Okay Okay You can put that aside In looking at the transactional activity associated with human trafficking Would you agree that cash is an important red flag of potential trafficking MR KRAUSE Objection THE WITNESS So again I need to go back to what we were looking at The cash components of it we were focused appropriately so on the business of trafficking That is people who set up the criminal enterprise to capture imprison move and sell the services right and generate the criminal proceeds just like drug trafficking So what we what we focused on you know it wasnt Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa the cash usage actually wasnt all that helpful but it was rather other indicia that we actually found where you could start to link it to people who were promoting the trafficking the prostitution for example using otherwise benign retail accounts That was really the focus ended up finding I should say BY MS SINGER Okay And so again I want to focus not just on what you were doing what you were implementing at JPMorgan in the human trafficking initiative but kind of the learnings that cash is specifically suggestive of human trafficking Do you agree with that statement MR KRAUSE Objection THE WITNESS So again partially What we were looking for what I really wanted to find Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa derogatory information and identifiable activity this was identifiable activity related to the information that was available on Jeffrey Epsteins conduct correct MR GAIL Objection THE WITNESS Yeah so I have to say Ive not seen an instance where in response to negative media we would have pulled an affidavit like this Doesnt mean it doesnt happen Im saying thats not typically what I would have done as an investigator but Ive never been an investigator So Ive not seen it in the context of the investigations done Is it relevant Everything is relevant when youre assessing conduct But at the end of the day the question of using the bank to conduct the activity spending money sure Id like to Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa know But at the end of the day withdrawal of cash is a withdrawal of cash And so especially small dollars wealthy people withdraw cash They do a lot of different things So its in contrast perhaps to the receipt of information the criminal enterprise like we talked about So it presents more of a challenge MS SINGER So move to strike that answer BY MS SINGER I appreciate it But I think it was different than my question And I want to ask the question again which is the fact that Jeffrey Epstein from whatever source right The New York Times article the supporting documents was known to pay cash to girls who he was sexually abusing Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa customer shortly before the break So if corporate compliance or AML Ops wanted wanted Epstein terminated and the Private Bank disagreed what would happen A So to answer that question we need to distinguish In the context of a question of reputational risk I my view is and doctrine I would have a vote but would not be a decisive vote To the extent it involved active ongoing violations of law and someone disagreed with me then I would escalate above that line of business up to CEO up to board of directors up to and including resignation if it didnt resolve as I thought it should Okay And by CEO you mean CEO of JPMorgan Jamie Dimon A If that were the case yes Okay And who would what would be the chain of escalating So before you got to Jamie Dimon who would Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa you go to A So again that wasnt this case Yep A But if I ever had a situation where I had said its time to exit the line of business said no I would first go to Steve Cutler who would have been my boss at the time If Steve Cutler disagreed and didnt convince me otherwise then I would push it up further probably to Jamie at that point And then if I still felt like I wasnt getting heard and it was an active ongoing issue then I would go to the board Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa there was such a meeting that there would be documents about it correct A I would expect there would be documents yeah Okay All right So the conclusion reports Further meetings held with Jes Staley to discuss LOB decision for re-approval Do you know what Jes Staleys position was within JP within JPMorgan as of January A Yes What was his position A He was the head of the investment bank So why was Jes Staley being consulted about Jeffrey Epstein when Jes Staley was the head of the investment bank A I can only say what I understood and was told I was told as I mentioned that Epstein was Jes Staleys client And it says Banker Paul Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa In any other context had anyone explained it to you A Not in terms of why we didnt terminate Thats right A Well here it was to refer to Jes to have that discussion Speaking with Jes at the later time was Jess view was he didnt do it shouldnt have pled guilty et cetera wasnt responsible for it So thats thats what I was told in the context of the retention or decision not to terminate I should say Okay So in prior to this meeting on January 7th because the conversation I think with Jes Staley and Epstein was after this meeting Prior to this meeting did you have an understanding why Private Bank didnt want to exit or hadnt exited Jeffrey Epstein A I dont I dont recall specifically no Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa transactions enlightening as compared to countless stories related to his escapades Lots of salon lingerie shops drug stores NY Palm Beach and in St Thomas his place of residence Plus lots of videos like Girls Gone Wild and some other shops not fit for my good Catholic upbringing The transactions are old to Besides frequent frequent spa like charges it has died down Surprised she was never subpoenaed Have I read that correctly A Yes Based on your understanding of human trafficking and the knowledge you had gained through the initiative you recognized those charges may not have been escapades but potentially human trafficking correct MR KRAUSE Objection THE WITNESS Yeah well in many respects its inconsistent with the types of things that we Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa saw in human trafficking You know having her own account providing money providing documented expenses The human trafficking enterprises that we were focused on were designed to traffic the individuals keep them down do do the business and keep it off the radar This was different I mean its its pretty I dont like the behavior But its different from the typology of human trafficking that we had been focused on BY MS SINGER Right Those enterprises that you were looking at on the retail side correct A No no no No The accounts were on the retail side It was the enterprise of criminal enterprise right Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa BY MS SINGER And you would you would agree that his relationship with MC2 is of concern given Epsteins history of sexual conduct with girls MR KRAUSE Objection THE WITNESS Again its hard Knowing what I know today sure Back then I dont know that that necessarily its negative media It made the allegation I would expect us to track it down pay attention to it yeah How significant it is its hard to say at this point looking back BY MS SINGER Quite clearly significant enough that Maryanne is raising it in her e-mail A Sure She raised it ostensibly because thats the allegation in the media So it says in Maryannes Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa e-mail that Jes would be deciding the next steps correct A Yes Was it your understanding that Jes Staley was the decisionmaker as to whether Jeff Epstein would be exited from the bank A So again I was escalating my my position my view we should exit Epstein and told that Jes owned the client relationship So from that perspective I suppose he would be the one to help make that decision or to make that decision Do you know whether anybody else at the bank John Duffy or Mary Erdoes whether any of them said that it shouldnt be Jes Staleys decision A Im not aware of anybody saying that no All right And then if we turn to the front page of this e-mail This is the part of the chain from Phil DeLuca to Nina Nichols ccing you And Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa MR KRAUSE Objection THE WITNESS I dont know unusual But it would you know again if youre looking back and saying what are the totality of facts I would want to understand them under the circumstances along with a lot of other information BY MS SINGER And so you would expect that there would be some inquiry or investigation into whether there was a business or other legitimate reason for these payments correct MR KRAUSE Objection THE WITNESS So again looking back and deciding all relevant facts versus what was looked at at the time you know Id want to presented with this today sure Id want to know BY MS SINGER And again this is all Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa to Phil DeLuca back on January 10th A To Phil Nina and Maryanne yeah Okay And just an understanding what you meant here Is it fair to say that you were that modeling agencies was one piece of the puzzle but that you would want to know more or tell me what you were saying A You know so to frame the entire context one I didnt need any of this to recommend kicking him out of our bank period What I was asking for is there anything else we can point to Are there any other linkages to ongoing activity that could make this decision even easier point to more potentially suspicious activity that sort of thing The modeling agency is just that it didnt tell us anything and our ability as a bank to know whats really going on in a modeling agency is extremely limited Especially he is a Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa when he when he responded I dont recall anybody else articulating a view on exit at that time Did Catherine Keating speak at all A I dont remember her speaking And you said Jes Staley responded What did he say A So Jess response was with regard to the conviction no that was not accurate his lawyers are working to get the conviction thrown or excuse me the plea the plea get the plea thrown out he didnt actually do that and that we should be talking to his lawyers And how were things left and did you respond to Jes Staley by the way when he said that A I dont remember specific responses but the takeaways were that we would go and speak with Mr Epsteins attorney Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa Do you know or did you hear that anybody had gone with Jes Staley when this conversation took place A Again no I dont have any information on it Is it surprising to you that the report was that Jeffrey Epstein had denied the allegations A No Do you think that a conversation between Jes Staley and Jeffrey Epstein was likely to yield useful information about whether Jeffrey Epstein was engaged in human trafficking MR KRAUSE Objection THE WITNESS So look at the time Jes was the lead banker right That was his client and it would not surprise it would not be unusual to have a banker to have a conversation with the client even something as unsavory as this So back then versus what we Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa Page And do you see Jeffrey Epstein Row at the top of Page A Yes Okay And that entry is dated July correct A Yes And it says here Catherine will go back to Jes to tell him we are uncomfortable with Epstein and do not want to go to Cutler for approval Have I read that correctly A Yes Do you understand JES to be the acronym for Jes Staley A That is what I think it means yes And Catherine is presumably Catherine Keating A That would be my assumption Do you know that Catherine Keating do you know if Catherine Keating went to Jes Staley and told him that Private Bank was uncomfortable with Epstein and didnt want to seek Steve Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa reputational component would include this but not as specific as that was the discussion and Steve said no change I dont I dont know that that was accurate or right I cant Im not aware of that put it that way BY MS SINGER Were any was the conversation that you had with Steve Cutler the one that you recall did that include any piece that was about legal advice any of those issues or was it was it entirely on the reputational side A My recollection it was based on the reputational side because thats what my point was Did you ever reach out to outside counsel about how to handle Jeffrey Epsteins accounts A I dont believe I ever did Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa Did anyone from JPMorgans Private Bank ever at any time try to dissuade you from doing anything A Sorry do that one again Sure Did anyone from the Private Bank ever at any time try to dissuade you from doing anything A No No Are you aware of any instance where anyone from the Private Bank tried to dissuade any of your colleagues from doing anything A No Did anyone from any of JPMorgans businesses ever at any time try to dissuade you from filing a SAR related in any way to a customer A No Are you aware of any instance where anyone from any of Case Document Filed Page of I William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa JPMorgans line of business tried to dissuade any of your colleagues from filing a SAR relating to a customer A No At any point during your time at JPMorgan did you ever come to believe that a SAR should be filed in a particular instance but where you decided not to do so because the customer was particularly large or valuable A No Are you aware of any instance where anyone at JPMorgan thought a SAR should be filed but failed to do so because the client was particularly large or valuable A No You testified earlier that you never discussed between I think it was and then your departure from the bank Do you recall that A Yes Do you believe that Epstein Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa to use your words should go because you believed he was engaging in continued illegal activity after his plea A No Fair to say your focus was on the reputational risk of keeping Epstein youd have focused on that had you thought there was yes Case Document Filed Page of I I I William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa A Yes why were you discussing Epstein with others at JPMorgan A Because I believed he should not be a client of the bank because of his plea and his reputational risk period Okay Weve seen work relating to Epstein by Maryanne Ryan You did or did not develop a good understanding of Maryanne Ryans temperament and skills during your time at JPMorgan A I did How skilled was Maryanne as an investigator A One of the best You did or did not develop a good understanding of Maryanne Ryans temperament through your time working with her at JPMorgan Case Document Filed Page of I I I William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa DeLuca with the most recent e-mail dated January Have I got that right A Yes Lets take a look at Ms Ryans e-mail to you on January 13th I think in the beginning of the page Do any of Ms Ryans findings indicate that JPMorgan is participating in a sex trafficking ring MS SINGER Objection THE WITNESS That JPMorgan is BY MR GAIL Yeah A No Why not MS SINGER Objection THE WITNESS Again she outlines what she finds right It doesnt establish a link between JPMorgan and the operation by Epstein of a sex trafficking ring through the bank on its Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa face in my opinion BY MR GAIL Do any of Ms Ryans findings as you see them there indicate that as of Epstein was using the bank to perpetrate sex trafficking MS SINGER Objection THE WITNESS So again the findings that she cites are old In et cetera she notes that And notes though the activity not continuing necessarily BY MR GAIL You testified that you had a call with Ken Starr following your conversation with Jes Staley Do you recall that A Yes Now counsel for the U.S Virgin Islands referred to Epsteins criminal defense attorney What was Ken Starrs position at the time you were speaking to him Case Document Filed Page of
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