Paul Morris deposition record and missing transcript pages
Snapshot
Paul Morris’s April 18, 2023 deposition is represented in the recovered public records by 18 unique numbered transcript pages: one title page and 17 pages of testimony. The complete transcript, its final page and its reporter’s certificate have not been recovered.
| Field | Verified position |
|---|---|
| Witness and date | Paul Morris, April 18, 2023 |
| Reporting service | Magna Legal Services; court reporter Leslie Fagin |
| Recovered numbered pages | 1; 14 to 18; 38 to 41; 46; 48 to 49; 53 to 54; 173; 337 to 338 |
| Missing within pages 1 through 338 | 320 pages across seven ranges |
| Complete transcript length | Unknown; page 338 is the highest recovered page |
| Additional citation leads | Pages 7 and 56, cited in court filings but not recovered |
| Principal evidence issue | A 2011 email discussing trafficking reporting compared with Morris’s 2023 recollection |
| FBI interview status | No verified Morris FD-302 or individual report serial identified |
The 320 missing pages are absent from the recovered set within pages 1 through 338. That count does not establish the complete transcript’s length, deliberate withholding, or absence from every public collection.
Record identity and significance
The deposition title page identifies a confidential, remote, videotaped examination beginning at 9 a.m. on April 18, 2023. It carries the captions of Jane Doe 1 v. Deutsche Bank, case 1:22-cv-10018-JSR, and Jane Doe 1 v. JPMorgan, case 1:22-cv-10019-JSR. Both were Southern District of New York actions. Excerpts were also filed in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., case 1:22-cv-10904-JSR.
EpsteinWiki’s Paul Morris profile provides the broader banking chronology. This page records the available deposition evidence, the missing continuations, the public access history and the separate search for a specifically identified Morris FBI interview report.
EFTA02813106 contains the fragment that prompted the transcript search: an exhibit cover, the title page, and testimony pages 337 and 338. The final page stops at a question about a rapid response meeting. Another recovered excerpt stops at a question about an introduction fee. Neither includes the following answer.
The concern raised by these omissions is evidentiary. Readers can examine selected denials and commercial dealings without seeing the entire examination or the witness’s responses at important boundaries. Contemporary emails also provide a basis for testing his later recollection. The missing context matters, but it does not reveal what an absent answer says. The files are expressly excerpts; routine litigation selection, confidentiality designations and survivor privacy are relevant to their limited coverage.
Evidence appearances and duplicate copies
Exhibit 160, ECF 241-30, filed July 25, 2023, supplies the largest recovered excerpt. Exhibit 121, ECF 263-68, filed August 7, supplies the two later testimony pages. Exhibit 153, ECF 326-153, filed September 8, repeats the latter material. Different docket headers do not add testimony.
| Released record | Original USVI court filing | PDF pages | Printed transcript pages |
|---|---|---|---|
| EFTA02811568 | ECF 241-30, Exhibit 160 | 17 | 1; 14 to 18; 38 to 41; 46; 48 to 49; 53 to 54; 173 |
| EFTA02813106 | ECF 263-68, Exhibit 121 | 4 | 1; 337 to 338 |
| EFTA02818052 | ECF 326-153, Exhibit 153 | 4 | 1; 337 to 338, duplicated |
| Total after deduplication | Three filed copies | 25 source PDF pages | 18 unique numbered pages |
A PDF page is its position inside a downloaded file. A printed transcript page is the reporter’s numbered page. ECF attachments and exhibit numbers identify court filings, while EFTA identifiers identify released records or pages. These systems must be kept separate from one another and from FBI identifiers.
The 25 source PDF pages include three exhibit covers and repeated title and testimony pages. The partial research compilation contains the 18 unique original transcript pages plus an editorial coverage note. It is not a certified reconstruction of the complete deposition. The retrieved Exhibit 121 contains transcript pages despite its cover’s filed under seal label, illustrating why the contents of each copy must be checked rather than inferred from a cover alone.
Exact page coverage
The recovered transcript pages and the final available excerpt establish coverage within the defined interval of printed pages 1 through 338.
| Recovered range | Pages recovered | Missing range | Pages missing |
|---|---|---|---|
| 1, title page | 1 | 2 to 13 | 12 |
| 14 to 18 | 5 | 19 to 37 | 19 |
| 38 to 41 | 4 | 42 to 45 | 4 |
| 46 | 1 | 47 | 1 |
| 48 to 49 | 2 | 50 to 52 | 3 |
| 53 to 54 | 2 | 55 to 172 | 118 |
| 173 | 1 | 174 to 336 | 163 |
| 337 to 338 | 2 | None counted beyond 338 | Not established |
| Total within 1 through 338 | 18 | Total within 1 through 338 | 320 |
Coverage within pages 1 through 338: 18 recovered, 320 unrecovered. This is approximately 5.3 percent recovered and 94.7 percent unrecovered within that interval. The percentages describe coverage, not a redaction rate or proof of suppression. 18 recovered pages · 5.3% 320 unrecovered pages · 94.7%
The title page is included among the 18 recovered pages. Unverified pages after 338 are excluded
No final testimony page, index, errata sheet or reporter’s certificate establishing the end of the deposition was recovered. Pages after 338, if any, are outside the 320 page calculation. Because page 338 ends with a question, its continuation is a priority even though the ultimate transcript length remains unknown.
Missing continuations and their significance
| Location | What the recovered record shows | Unresolved point |
|---|---|---|
| 173:22 to 25 | A question about an introduction fee after testimony about a Black related art loan | The following response; page 174 is the immediate retrieval target |
| 337:2 to 4 | An answer already in progress referring to a CEO speaking with Epstein | The preceding question and context on page 336 |
| 338:22 to 25 | A question about rapid response meeting attendance | The continuation after page 338, beginning with the page 339 target |
| 7:22 to 25 and 56:17 to 23 | Visible citations to Staley Exhibit 25 | The actual testimony and the redacted assertions surrounding it |
| Pages 18 and 54 | Breaks during questioning involving Josh Harris and the Deutsche Bank relationship | The next portions of those discussions |
A lawyer’s question does not establish that its premise is true or that the witness accepted it. The introduction fee question cannot be reported as Morris admitting a fee existed or was paid. Similarly, the rapid response question supplies no admission or denial of attendance.
John Duffy’s contemporary email makes him the strongest contextual lead for the unnamed CEO reference on page 337. Without page 336, that identification remains an inference about the incomplete answer. Attributing the passage to Jamie Dimon is unsupported.
What Morris said in the recovered testimony
Referrals and prospective clients
Pages 14 through 18 record Morris acknowledging introductions by Epstein involving Leon Black, David Mitchell and Andrew Farkas. Morris initially believed Black became his client, then qualified that he did not remember whether the account opened. Mitchell and Farkas did not become his clients. Farkas was another banker’s prospect.
Boris Nikolic appears in an answer to a compound question about people Epstein referred or indicated he would arrange to meet. That answer does not unequivocally establish a completed introduction. Across these passages, a proposed meeting, an introduction, a prospect and an opened client account remain different stages of a possible business relationship.
Pages 38 through 41 address Morris’s understanding that Epstein worked for Black, uncertainty about when and how he learned it, a meeting with Black and Epstein, and meetings with Black’s family office representatives and Deutsche Bank colleagues. The interactions should not all be assigned to the JPMorgan period.
Compensation and commercial importance
Page 46 describes Morris’s JPMorgan compensation as a salary and discretionary annual bonus, with business development, revenue and client coverage among the factors. He did not describe a fixed formula. The salary figure in the question is redacted. Pages 48 and 49 distinguish assets held in accounts from revenue producing management or trading activity. The testimony does not calculate his personal earnings from Epstein or establish a particular commission.
Pages 53 and 54 concern the later Deutsche Bank relationship. Morris characterized Epstein’s activity as limited, described Black as an important prospect, and rejected counsel’s suggestion that nothing was more important than Epstein and Black. The rejected premise is not an admission. The bank, period and distinction between a prospect and an existing client are essential to interpreting the answer.
Art loan and cash withdrawals
Page 173, lines 8 through 21 records Morris agreeing that Epstein wanted to bring him into a Black related art loan. He did not believe he joined the deal and did not recall why. The subsequent introduction fee question has no recovered response.
Page 337, lines 5 through 21 records Morris recalling Epstein’s explanation that the 2012 Hyperion Air cash withdrawals were for fuel. Asked whether he tried to determine if the cash was actually used for fuel, Morris said he did not. He said that use for sexual abuse or trafficking had not occurred to him. These answers do not establish the cash’s ultimate destination.
Trafficking concerns and news reports
Page 338, lines 2 through 21 contains Morris’s denials of hearing suggestions from people around him at JPMorgan or Deutsche Bank that the cash withdrawals were being used for sexual abuse or trafficking. That is a denial concerning suspected cash use, not a categorical denial of ever hearing allegations about Epstein.
In the same passage, Morris recalled receiving negative news stories but did not recall their being about trafficking. He said he never spoke with Cutler. The next question asks about rapid response meeting attendance and is unanswered in the recovered record.
The 2011 email and the 2023 recollection
The January 27, 2011 Morris email, ECF 326-16, PDF page 2, Bates JPM-SDNYLIT-00012641, provides the clearest contemporary comparison with page 338. Sent to James Dalessio as a proposed due diligence addition, it expressly connects 2010 news reporting with human trafficking.
The email describes a coverage team meeting involving Catherine Keating and William Langford, relays that Jes Staley discussed the allegations with Epstein, records Epstein’s denial, and states that account and cash monitoring would continue. The denial is attributed to Epstein; the email does not independently establish its accuracy.
The answer at 338:11 to 18 says Morris remembered negative stories but did not recall them being about trafficking. His earlier written discussion creates a specific documentary tension with that later recollection. It is a reason to examine the complete questioning and any explanation he gave when shown the email.
The distinction between awareness of reporting and knowledge of actual crimes remains central. The available pages do not establish that the memory failure was deliberate, that Morris knew allegations were true, or that the promised monitoring was performed. They also do not reveal whether counsel confronted him with this particular email elsewhere in the deposition. The contemporary record supports scrutiny; the missing examination prevents a complete assessment of his response.
Related contemporary exhibits
| Original exhibit | Date | Evidence and limits |
|---|---|---|
| ECF 326-137, PDF pages 2 to 4 | January 2011 | Rapid Response Team memorandum records Morris’s cash discussion and an instruction to update Hyperion’s KYC. It does not establish that the update occurred or answer the attendance question |
| ECF 326-16, PDF page 2 | January 27, 2011 | Morris discusses trafficking reporting, internal review and monitoring; principal comparison with his 2023 recollection |
| ECF 326-145, PDF page 2 | August 29, 2011 | Dalessio supplies Duffy a requested withdrawal list, raises a Maxwell related concern and records a call in to Morris |
| ECF 326-148, PDF pages 2 to 7 | March 23 to 28, 2012 | Duffy describes a direct cash and fuel conversation with Epstein; follow through concerns aviation accounts and KYC |
| ECF 243-3, Exhibit 213, PDF page 2 | July 9 to 10, 2012 | Loan discussion and claimed introduction involving a redacted client; the visible email does not mention an introduction fee |
| ECF 243-2, Exhibit 212, PDF pages 2 to 3 | August 14 to 15, 2013 | Willingness to work through clients’ accounts while excluding Epstein’s own entities; no proof a proposed transaction closed |
Cash review and the Duffy connection
The rapid response memorandum’s conclusion, Bates JPM-SDNYLIT-00127932, records Morris speaking with Epstein about large cash withdrawals and being instructed to document a foreign fuel explanation in Hyperion’s know your customer record. It also records that the standby letter of credit would not be renewed. These are attributed actions and instructions, distinct from proof of implementation.
Dalessio’s August 2011 email, Bates JPM-SDNYLIT-00755043, supplies the withdrawal history since 2010 and raises concern about a Maxwell related entity’s personnel recruitment business. Its call to Morris is a lead to a proposed inquiry, not evidence of his response.
Duffy’s March 28, 2012 email, Bates JPM-SDNYLIT-00230825, describes discussing cash withdrawals with Epstein, hearing the foreign fuel explanation, asking him to use the aviation account and proposing an inquiry to Harry Beller. Bonnie Perry proposed updating Hyperion’s KYC and marking it high risk; Duffy approved for the time being. His signature identifies him as Chief Executive Officer of the U.S. Private Bank. JPMorgan’s opposition, printed page 7, supplies consistent litigation context for his role.
Loan and client account arrangements
The July 2012 loan email, Bates JPM-SDNYLIT-00022569, records Duffy relaying Epstein’s claimed prior introduction of a person whose name is redacted. Erdoes asks why Epstein should stand between the bank and that person. The visible text neither identifies an art purchase nor discusses a fee. USVI’s paragraph 344, printed page 129, identifies a Black art loan and cites this email together with Morris 173:8 to 21. That identification comes from the party filing, not an unredacted name in the email.
The August 2013 chain, Bates JPM-SDNYLIT-00101010 through 00101011, records Duffy saying the bank could work with Epstein through clients’ accounts while excluding Epstein’s own entities, with Erdoes agreeing. Later messages discuss authority and a potential debt deal. The client’s name is redacted. USVI’s paragraphs 341 and 354 supply the Black identification. These emails document the proposed accommodation without proving a transaction closed.
Litigation positions and source attribution
USVI’s factual statement, paragraphs 341 through 347, links Black’s importance, proposed financing and Epstein’s intermediary role. JPMorgan’s responses, paragraphs 307 and 309, acknowledge Morris’s testimony about Farkas and Mitchell introductions while disputing their significance because neither became his client. JPMorgan’s opposition, printed page 25, also disputes that Epstein originated its relationship with Black, saying Black was already a private bank client. These are opposing litigation positions, not judicial findings.
USVI’s paragraph 268 asserts that Morris listed Epstein as his top client in December 2010, citing Exhibit 167. The retrieved ECF 242-7 copy is a placeholder, so the underlying ranking was not recovered. In any event, a 2010 JPMorgan ranking concerns a different period from Morris’s later Deutsche Bank testimony. A comparison that omits that distinction would overstate any apparent inconsistency.
Staley Exhibit 25 and the sealing record
Stephen L. Wohlgemuth’s declaration, ECF 311, paragraph 26, identifies Staley Exhibit 25 as confidential excerpts from Morris’s April 18, 2023 deposition filed under seal. The public ECF 311-25 attachment contains one placeholder page. The parallel Doe JPMorgan ECF 205-25 has the same status in the retrieved copy. Authentication by counsel establishes the filed excerpt’s identity, not current custody of the complete transcript.
Staley’s paragraph 33 cites Exhibit 25 at 7:22 to 25 and 56:17 to 23. JPMorgan’s counterstatement and parallel Doe filings repeat the references while the surrounding assertions and response remain redacted. This establishes citation metadata for two missing pages and adds no recovered testimony. Both pages already fall within the 320 page gap.
Other citations in ECF 325 concern different witnesses: 174:15 to 175:10 belongs to John Duffy in JPMorgan Exhibit 15. The 336:4 to 14 references, on PDF pages 33 and 36, concern William Langford in JPMorgan Exhibit 113. Neither fills a Morris gap. The separate 2024 unsealing dispute and Staley opposition concern Jane Doe’s March 3, 2023 deposition, not release of Morris’s Exhibit 25.
USVI’s September 4, 2025 filing, ECF 371, asks that Exhibit 160 retain its existing sealing because it belongs to a category containing survivor identifying information. The October 24, 2025 order, ECF 381, footnote 5 across pages 7 and 8, leaves that category unaddressed because the requesting news organizations were not seeking it. It does not freshly determine that the complete Morris deposition must remain sealed indefinitely.
The same order’s page 8 separately directs that USVI Exhibits 211 through 216 be unsealed subject to privacy redactions. The retrieved mirror copies of ECF 243-4 through 243-6 still contain placeholders. Their mirror state is therefore not proof that Exhibits 214 through 216 remain legally sealed. No fuller Morris release was established by the reviewed orders or current mirror versions.
Access obstacles and the reporting service
Senator Ron Wyden’s August 4, 2026 report, page 60 and footnote 211, states that lawyers for Deutsche Bank and JPMorgan declined to provide Morris’s deposition to his investigators. It identifies requests to Deutsche Bank counsel on June 1, 2026, and JPMorgan counsel on June 2. This is evidence of an actual reported access obstacle, independent of the public search, without establishing the transcript’s complete length or the banks’ reasons.
Magna and Leslie Fagin are the verified reporting identities on Morris’s cover. Magna Online Office provides a repository route, while the official order form requests a job number and creates payment responsibility. Current custody, release conditions, availability to a nonparty and cost remain unconfirmed. The reporting identity alone does not establish public access.
The Golkow document is Duffy’s deposition
EFTA02812868 corresponds to ECF 263-24, Exhibit 77, John R. Duffy’s July 13, 2023 deposition, reported by Michelle L. Gray for Golkow Litigation Services. Its 16 PDF pages contain an exhibit cover and printed pages 1, 125, 174 through 177, 207, 212, 225 through 226, 345 through 346, 365, and 382 through 383. Duffy’s page 174 does not fill Morris’s page 174.
Golkow’s migration information identifies it as part of Veritext and describes an archived or missing record route. Golkow also appears on other bank case deposition covers, including Mary Casey and Mary Erdoes. No connection to Morris’s April 18 session, second Morris session or Golkow to Magna rebranding was verified.
The unresolved Morris FBI interview report
A civil deposition transcript records sworn questions and answers. An FD-302 is an FBI report of an interview, generally an agent’s summary rather than a verbatim transcript. An investigative file number identifies a case file; a serial identifies an individual record within it. EFTA disclosure identifiers supply neither by themselves.
No retrieved record establishes a completed Paul Morris FBI interview together with its resulting FD-302 and individual serial. Related banking reports are useful comparisons, but retain the identities of their actual witnesses.
| Released record | Actual witness or event | FBI file information | Status |
|---|---|---|---|
| EFTA00128765 through EFTA00128779 | Amanda Kirby, August 10, 2021 interview | 272B-NY-6764158 | Kirby’s FD-302; no individual serial established |
| EFTA00128968 through EFTA00128972 | Cherie Quigley, October 10, 2019 interview | 272B-NY-3125676 | Quigley’s FD-302; no individual serial established |
| EFTA00128987 through EFTA00128993 | Tammy Hill-McFadden, July 12, 2019 interview | File number redacted | No file or serial assigned by association |
| EFTA00037187 through EFTA00037188 | March and August 2020 Morris proffer correspondence | No Morris file or serial established | Proposed proffer; completion unverified |
| EFTA01681984 through EFTA01681986 | September 12, 2019 Deutsche Bank attorney proffer | No Morris file or serial established | Attorney presentation, not Morris testimony |
| EFTA01731021 | Serial export manifest | 50D-NY-3027571 | No verified Morris serial; not a complete banking case index |
Related witness evidence
Kirby’s report is the closest substantive comparison. Pages 3 and 13 through 14, EFTA00128767 and EFTA00128777 through 00128778, address Black account opening and introductions. Pages 4 and 5, EFTA00128768 through 00128769, discuss research prepared for Morris and colleagues. These overlap the deposition’s business development and due diligence topics, without answering the missing fee question.
Kirby described Epstein as Morris’s only client during her work with him, approximately 2013 through 2015, and discussed rankings, bonuses and pressure for quick responses. Her qualifications matter: she did not recall Morris’s reaction to the research, did not identify illegal conduct by him, and said on page 14 that she did not observe bank policy violations. She also said the particular wire email discussed in the interview was not motivated by compensation.
Quigley’s pages 4 and 5 concern Deutsche Bank monitoring and recurring $7,500 withdrawals involving Darren Indyke. Hill-McFadden’s pages 6 and 7 concern compliance warnings, wires and reporting related to Epstein’s lawyer. These are different transactions and accounts from JPMorgan’s Hyperion withdrawals. They do not establish cash use, Morris’s personal knowledge or what another person told him.
The Kirby and Quigley file identifiers were checked against full extracted text and repeated continuation headers, without newly available images of those headers. Hill-McFadden’s redacted file field was visually checked and remains unassigned.
The prospective proffer and serial search
The August 4, 2020 email describes engagement with Morris the previous day and an anticipated proffer. It does not establish that the interview occurred, its date or a resulting FD-302. EpsteinWiki’s proffer article examines the correspondence separately. The September 2019 notes identify a Deutsche Bank attorney proffer and cannot be relabeled as Morris’s own interview.
The Clemente declaration and indexes 34-6 and 34-7 were searched without establishing a Morris serial inventory. The declaration’s August 11, 2020 cutoff does not exclude later records. Anonymous manifest serials cannot be assigned to Morris by date alone. The missing link is affirmative evidence joining his identity, a completed interview and a particular report, file and serial.
Public search coverage
The recovery used witness, date, reporter, transcript header, exhibit and subject searches across related court filings and public document collections. Original pages, citations, declarations and duplicate copies were distinguished throughout. The following chart records the scope checked rather than claiming that every public or private source was exhausted.
| Search area | Coverage established | Result or limitation |
|---|---|---|
| Three related bank cases | Public excerpts, declarations, exhibit lists, factual statements and opposing briefs | 18 unique numbered Morris pages; further citations to 7 and 56 |
| Difficult PDF contents | OCR of 295 sparse pages within 307 pages of ECF 284 attachments 2 through 5 | No additional unrecovered Morris range established |
| Embedded material | 47 distinct source PDFs totaling 1,303 pages checked for embedded files, attachments, associated files and portfolios | None found in that inspected set |
| Staley exhibit history | Two dockets and current Archive manifests | Placeholder copies; no verified fuller release; not every historical docket replacement |
| Reddit archive lead and Archive ZIP | Directory of a roughly 1.0 GB USVI ZIP with 1,840 PDF entries; four selected members checked | Known 17, 4 and 4 page excerpts plus the Exhibit 25 placeholder; no extra Morris pages |
| FULL_EPSTEIN_INDEX | Linked CSV searched in full: 8,531 rows, 4,084 distinct IDs, highest EFTA00008998 | No target match; listed range precedes the target court records |
| Epstein-research-data and epstein-docs | Dataset mapping and repository file tree | Mapping ended at EFTA02731783; 2.3 GB database not searched. The 29,439 JSON file contents were not searched in full |
| Other public repositories | 39 document manifest, small document archive, code project, news and litigation mirrors | Older records, software or known excerpts; no verified complete Morris transcript |
| DocumentCloud filing lead and other inaccessible leads | Public indexing could be reviewed, but some underlying copies could not | Incomplete inspection rather than a conclusive negative search |
The public Archive collections remain useful because a transcript can be indexed under a docket attachment rather than a witness name. News mirrors produced complaints, declarations or existing excerpts; for example, the Courthouse News complaint predates the deposition. Title matches and repository size alone do not establish a complete or unredacted transcript.
The review did not examine private reporter repositories, attorney discovery collections or sealed contents. A court archive contains publicly filed material, which may be only a subset of discovery. Search indexing, OCR and mirror completeness remain limits on any absence finding.
Public court collections
| Case | Docket | Public collection | PDF entries in checked manifest |
|---|---|---|---|
| Doe 1 v. Deutsche Bank, 1:22-cv-10018-JSR | CourtListener | Archive 590047 | 211 |
| Doe 1 v. JPMorgan, 1:22-cv-10019-JSR | CourtListener | Archive 590048 | 813 |
| USVI v. JPMorgan, 1:22-cv-10904-JSR | CourtListener | Archive 591653 | 1,948 |
The checked manifests listed approximately 1.85 GB of PDFs in total. Counts include attachments and possible duplicates and may change as mirrors update. They are not counts of unique evidence items or proof of complete discovery production.
Evidence needed to complete the record
The complete numbered testimony, final page and reporter’s certificate would establish transcript length and continuity. Any errata and exhibit index would help identify corrections and referenced material. Further excerpts can improve the page ledger, but cannot be treated as a complete transcript without that verification.
Magna’s cover identification supplies the clearest provider lead for a lawful availability inquiry identifying Morris, April 18, 2023, Leslie Fagin and the two survivor case captions. Current custody, the job number and required consent or court authorization would need confirmation before any order. Counsel’s authentication of filed excerpts is a separate lead, not proof of present possession or release authority.
The 2020 proffer correspondence supplies the most specific unresolved FBI trail: subsequent scheduling or cancellation messages, a proffer agreement, interview notes, any resulting FD-302 and its file and serial. A nearby date or another banker’s case number cannot substitute for that identity link.
The record supports continued scrutiny of the testimony and contemporary emails. It presently supports neither reconstruction of the missing answers nor a conclusion that Morris committed a crime, lied under oath or caused the transcript’s limited public availability.
Outstanding questions
- What is the complete transcript length, and where are its final page and reporter’s certificate?
- What follows the introduction fee question on page 173?
- What is the full context of the CEO reference across pages 336 and 337?
- What follows the rapid response meeting question on page 338?
- Was Morris shown his January 27, 2011 email, and what explanation did he give?
- What do the cited passages on pages 7 and 56 say?
- Who holds the complete transcript, and what lawful release conditions apply?
- Did the anticipated 2020 proffer occur, and what records identify its date, report, file and serial?
Sources
Deposition excerpts and contemporary exhibits
- ECF 241-30, Exhibit 160, filed July 25, 2023; EFTA02811568
- ECF 263-68, Exhibit 121, filed August 7, 2023; EFTA02813106
- ECF 326-153, Exhibit 153, filed September 8, 2023; EFTA02818052
- ECF 326-16, January 27, 2011 email, PDF page 2, Bates JPM-SDNYLIT-00012641
- ECF 326-137, rapid response memorandum, PDF pages 2 to 4, Bates JPM-SDNYLIT-00127930 through 00127932
- ECF 326-145, August 29, 2011 email, PDF page 2, Bates JPM-SDNYLIT-00755043
- ECF 326-148, March 2012 emails, PDF pages 2 to 7, Bates JPM-SDNYLIT-00230825 through 00230830
- ECF 243-3, July 2012 loan email, PDF page 2, Bates JPM-SDNYLIT-00022569
- ECF 243-2, August 2013 emails, PDF pages 2 to 3, Bates JPM-SDNYLIT-00101010 through 00101011
Litigation access and identification
- USVI statement, ECF 285-2, paragraphs 268, 341 through 347 and 354; JPMorgan responses, ECF 284-4, paragraphs 307 and 309; opposition, ECF 284-1, printed pages 7 and 25
- Wohlgemuth declaration, ECF 311, paragraph 26; Exhibit 25 placeholder, ECF 311-25; parallel Doe declaration, ECF 205, paragraph 26; Doe ECF 205-25
- Staley ECF 312, paragraph 33; JPMorgan ECF 325, paragraph 33; parallel Doe ECF 204 and ECF 211
- USVI ECF 371, September 4, 2025, page 2; ECF 381, October 24, 2025, pages 7 and 8, including footnote 5
- ECF 352 and ECF 355, separate Jane Doe deposition dispute
- Wyden’s August 4, 2026 report, page 60 and footnote 211
- Duffy deposition, ECF 263-24; EFTA02812868
- Magna order information, Magna Online Office, and Golkow migration information
FBI records and public collections
- Kirby FD-302, EFTA00128765 through EFTA00128779; Quigley FD-302, EFTA00128968 through EFTA00128972; Hill-McFadden FD-302, EFTA00128987 through EFTA00128993
- Morris proffer correspondence, EFTA00037187 through EFTA00037188; attorney proffer notes, EFTA01681984 through EFTA01681986; serial manifest, EFTA01731021
- Clemente declaration 34-4, index 34-6, and index 34-7
- Deutsche Bank collection, Doe JPMorgan collection, USVI collection, and USAvJeffreyEpstein archive
Source note: Original court records support the transcript and exhibit analysis. Party assertions, witness accounts and reported access obstacles are attributed to their sources. Search results and repository inventories establish only the scope inspected. EFTA links identify released records; printed transcript numbering remains separate from PDF positions and FBI identifiers.