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

Ms Wiggins had limited comments on the first draft. She suggested inserting that Mr Staley’s last contact with Mr Epstein had been before he joined Barclays in 2015 (rather than just in 2015) and corrected a typographical error. These comments were fed into the next draft.

Of significance is that both drafts stated:

“Jes has assured us that since Mr. Epstein’s release from prison, he had only occasional meetings with him.”

As the Authority observed, this statement reflected the Bowdoin College Talking Points, which had talked about “limited contact” after 2009. Mr Staley’s evidence in his witness statement was that the statement that there had been occasional meetings with Mr Epstein after his release from prison was an accurate statement.

It appears that Mr Staley was shown one of these drafts, because on 6 October 2019, when Mr Hoyt sent Mr Staley the near-final version to review, he indicated that later draft was “only slightly revised from the draft I showed you last week”. It does not appear that Mr Staley took issue with the statement in both of those drafts that they had only been occasional meetings between himself and Mr Epstein since Mr Epstein’s release from prison.