UT (Tax & Chancery) UT-2023-000064 - [2025] UKUT 00203 (TCC)

Further evidence that Mr Staley’s relationship with Mr Epstein at this time went beyond a purely professional relationship derives from the considerable assistance Mr Epstein gave to Mr Staley’s daughter, Alexa. We should emphasise, as the Authority did in its own submissions, and Mr Staley stated in his evidence, that we do not seek to detract from Ms Staley’s own personal achievements in her academic career in setting out the facts in this regard.

Mr Epstein’s connection to influential scientists was of particular interest to Mr Staley’s daughter, Alexa, who was an aspiring physicist. When Mr Epstein discovered this, he introduced her to a Professor at Columbia University who was of considerable assistance in supporting Mr Staley's daughter's study of Physics at Columbia University. Mr Staley was deeply appreciative of Mr Epstein's assistance in supporting his daughter’s educational achievements which, as we shall see, led to Mr Staley describing Mr Epstein in his communications with him in endearing terms.

As the Authority observed, over the course of 2009, Mr Epstein (i) sent Mr Staley a list of contacts in the science sector with whom Ms Staley could “meet have dinner lunch a weekend” (an email Mr Staley forwarded to his daughter with the covering email: “This is from uncle Jeffrey.”); (ii) commented on Ms Staley’s draft thesis, sent to him by Mr Staley; (iii) arranged for a space for Mr Staley’s daughter at a Physics conference and arranged for a professor at Harvard University to call Ms Staley and “meet up”. When asked about the connection, Mr Epstein replied: “HER FATHER IS A CLOSE FRIEND BANKER JPM.” As the Authority submitted, Mr Epstein was disposed to provide considerable assistance to Mr Staley’s daughter in the light of the closeness of his relationship with Mr Staley.

Over the course of 2010, Mr Epstein (i) arranged for Mr Staley’s daughter to meet academics he knew; and (ii) seems to have given advice and offered to use his connections in order to assist Mr Staley’s daughter with her university applications. Mr Staley kept Mr Epstein closely apprised of his daughter’s progress with her applications. Later, when Ms Staley graduated in 2015, Mr Staley described the assistance given by Mr Epstein as “a great gift of friendship”.

Finally, in this period there were in evidence a significant number of emails which it is difficult to characterise as anything other than of a personal rather than a purely professional nature. These emails related to subject matter and were of a tone such that they could only reasonably be expected to be sent between two people who know each other well and have a close personal relationship. As the Authority submitted, these emails show that Mr Staley and Mr Epstein were used to speaking freely about personal matters and trusted one another.

When cross examined on these emails, Mr Staley’s answers were either evasive or defensive. As indicated below, it was often the case that Mr Staley said he could not recall the emails or the context in which they were sent. We therefore have to let the material speak for itself and draw inferences accordingly.

When Mr Staley was on a trip to London, there was an email exchange in which on 27 August 2009 Mr Epstein asked Mr Staley: “how long london? do you need anything there?”; and in response Mr Staley wrote simply: “Yep.” On being asked whether he understood the nature of Mr Epstein’s request, he responded that he did not recall.There was then a subsequent email from Mr Epstein to a woman which stated: “jes staley is staying at the berkeley hotel in London tonight” Mr Staley emailed Mr Epstein the next day: “I should have taken your offer”Mr Staley accepted this indicated he and Mr Epstein had spoken about it. When asked whether he stood by his explanation given at interview that the emails might have related to an offer from Mr Epstein to connect him to people in the British Government, Mr Staley said he could not specifically recall, but noted that Mr Epstein had connected him with the Royal Family and people in the British Government. This clearly is an email which relates purely to Mr Staley’s private life rather than representing an effort to make connections of a professional or business nature.

In December 2009, Mr Epstein sent Mr Staley a photograph of a woman with the covering email: “you were with larry , and i had to put up with…”.As the Authority submitted, although not indecent, this was not the kind of photograph sent between two individuals whose relationship is strictly professional in nature, even though it was not unknown at this time for emails of this nature to be sent between financial services professionals using their employer’s systems. Mr Staley did not seek to admonish Mr Epstein for sending such material nor did he ignore it. He responded: “Don’t tell me a French wine.” He was not able to tell the Tribunal what this meant in context and said that he did not recall the exchange.Mr Epstein responded: “always thoughts of alcohol”

In June 2010, whilst in London, Mr Staley emailed Mr Epstein: “Andrew just sat next to me at dinner…Any word on M? This is fun.” The next day, Mr Staley emailed Mr Epstein asking: “Is she free tonight?” Mr Epstein asked Mr Staley to call, and Mr Staley declined, explaining: “I’m w A.” As to who “she” was, Mr Staley could not assist.Mr Staley said he could not recall, but that “M” might have been Lord Mandelson.

In July 2010, Mr Staley emailed Mr Epstein: “Maybe they’re tracking u [sic]?? That was fun. Say hi to Snow White”. Mr Epstein asked: “what character would you like next” On Mr Staley responding, “Beauty and the Beast”, Mr Epstein replied: “well one side is available [sic].”Mr Staley has not explained this correspondence, maintaining in cross-examination that he could not recollect this exchange. In the absence of any explanation, the only inference to be drawn is that this email, in common with the others referred to above is not consistent with a purely professional relationship and was clearly personal in nature and tone.

In November 2010, Mr Staley emailed Mr Epstein from a debutante ball, stating: “I'm here at some ball with Vera. She says u [sic] slept with her!!”. It was followed by Mr Staley sending a separate email to Mr Epstein saying “At a debutante [sic] ball at the Plaza. Nuts. Sick”. Mr Staley implausibly denied in cross-examination that he was commenting on Mr Epstein’s sex life and the email is clearly personal in tone and nature.

In July 2011, Mr Epstein sent Mr Staley an email in respect of a scandal that had emerged in respect of Dominique Strauss-Kahn, the former Managing Director of the International Monetary Fund who resigned due to a sex scandal with a maid in a hotel room, stating: “the maids deal was have sex,,,,leave the money in the room,, he had sex. she left to go clean the other room, when she returned she didn;t [sic] find the money,, went beserk,, ( my new explanation.)” Mr Staley said in his cross-examination that he did not know whether “my new explanation” was a reference to the fact that Mr Epstein had previously provided a different hypothesis, and that they had previously discussed the matter. However, that is the obvious inference to draw. Mr Staley, implausibly in our view, did not accept that the email was not consistent with a purely professional relationship.

Also in July 2011, Mr Epstein forwarded, without comment in the email, a hyperlink to a press article that related to a woman being accused of cutting off her husband’s penis using a 10-inch kitchen knife. Mr Staley again did not recall the email and would not speculate on Mr Epstein’s reasons for sending it. While he accepted that it was “a very odd email” for Mr Epstein to send, Mr Staley would not be drawn on whether the terms were consistent with a purely professional relationship. In our view it is obviously the case that they were not. Mr Staley’s approach in relation to such emails was to ignore them and not respond, rather than suggest that they were inappropriate communications in a purely professional relationship, which is the response that we would expect to have been made were the relationship a purely professional one.