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Transcript

Mega Edition: Jeffrey Epstein And The Transcript From His 1981 SEC Deposition (10/11/26) · The Vault: The Epstein Files

• 0:00
  Speaker 1: What's up everyone and welcome to another episode of the
• 0:03
  Speaker 1: Epstein Chronicles. In this episode, we're going to start taking
• 0:06
  Speaker 1: a look at Jeffrey Epstein's deposition with the SEC. And
• 0:11
  Speaker 1: this deposition was taken back in 1981. Your boy was
• 0:16
  Speaker 1: one years old. And it's a very, very telling and
• 0:21
  Speaker 1: informative deposition when it comes to Jeffrey Epstein and who
• 0:25
  Speaker 1: the man was at the time. And it also, in
• 0:29
  Speaker 1: my opinion, is the genesis of his usefulness to the government.
• 0:34
  Speaker 1: So with that said, let's dive in. On the record,
• 0:38
  Speaker 1: we're located in the conference room at the offices of
• 0:41
  Speaker 1: the United States Security and Exchange Commission, New York Regional Office. Sir,
• 0:45
  Speaker 1: my name is Redacted. I'm a member of the staff
• 0:48
  Speaker 1: of the U.S. Security and Exchange Commission, and in connection
• 0:51
  Speaker 1: with a matter of interest to the commission, A formal
• 0:54
  Speaker 1: order directing private investigation has been authorized by the commission,
• 0:58
  Speaker 1: and I've been delegated with certain authorities by the commission,
• 1:02
  Speaker 1: as have certain other individuals on the staff. In connection
• 1:06
  Speaker 1: with those authorities, I have the power to swear you
• 1:08
  Speaker 1: in as a witness. I would like you to rise
• 1:11
  Speaker 1: and please raise your right hand. Whereupon, Jeffrey Epstein, having
• 1:15
  Speaker 1: been first duly sworn, was examined and testified as follows.
• 1:20
  Speaker 1: As is customary in proceedings of this type, I'd like
• 1:23
  Speaker 1: to advise you that the Security and Exchange Commission is
• 1:25
  Speaker 1: involved in investigation into certain transactions and securities relating to
• 1:30
  Speaker 1: the St. Joe's Mineral Corporation. As you may also be aware,
• 1:34
  Speaker 1: there has been a recent tender offer, and there's been
• 1:37
  Speaker 1: a good deal of litigation in connection with that. Mr. Lehman,
• 1:41
  Speaker 1: there are two recent tender offers. Redacted, well, okay, specifically,
• 1:45
  Speaker 1: I'm referring to the Seagram's tender offer. There's been a
• 1:48
  Speaker 1: good deal of litigation, and as you've probably all read,
• 1:51
  Speaker 1: The commission is investigating this matter. Mr. Lehman, please answer
• 1:55
  Speaker 1: the question, if he asks it, by responding yes or no. Redacted, yes,
• 2:00
  Speaker 1: you have to answer yes or no for the record.
• 2:02
  Speaker 1: I would like to ask you a number of questions
• 2:04
  Speaker 1: in connection with our investigation, but before I ask you
• 2:07
  Speaker 1: any questions, or you give any answers, I must advise
• 2:10
  Speaker 1: you of certain of your rights under the law. Epstein, okay.
• 2:15
  Speaker 1: The record should reflect that prior to going on the
• 2:17
  Speaker 1: record today, I made available to counsel and Mr. Epstein
• 2:20
  Speaker 1: a copy of the order directing private investigation. Have you
• 2:24
  Speaker 1: had an opportunity to look at this document, Epstein? I'd
• 2:28
  Speaker 1: just like to see it again for a second, please.
• 2:30
  Speaker 1: Proves as the document, thank you. Mr. Lehman, yes, we have. Redacted,
• 2:35
  Speaker 1: I will leave it on the table during our discussions today,
• 2:38
  Speaker 1: and it'll be available to you if you wish to
• 2:40
  Speaker 1: review it at any time. Epstein, thank you. Question, also.
• 2:45
  Speaker 1: Prior to going on the record, I attended to the
• 2:47
  Speaker 1: witness and counsel a multi-page document entitled Exhibit to be
• 2:51
  Speaker 1: used in formal investigations. Mr. Epstein, have you received that document? Epstein, yes,
• 2:57
  Speaker 1: I have. Question, have you had an opportunity to review
• 3:01
  Speaker 1: the document with your counsel? Epstein, yes, sir. Question, may
• 3:05
  Speaker 1: I have your copy back, please? All right, I've marked
• 3:07
  Speaker 1: a copy, identical copy, Division Exhibit 1 Epstein. If you
• 3:11
  Speaker 1: would like to take a look at them and compare
• 3:13
  Speaker 1: them to make sure they are one and the same,
• 3:16
  Speaker 1: you may do so. Epstein, yes, fine. They're the same. Question.
• 3:21
  Speaker 1: I will ask the reporter to mark Division Exhibit 1. Epstein,
• 3:25
  Speaker 1: and I will leave this copy with you for your
• 3:27
  Speaker 1: own purposes. Mr. Epstein, I'd like to advise you that
• 3:31
  Speaker 1: at this time that you have the right to be accompanied, advised,
• 3:34
  Speaker 1: and represented by counsel of your own choosing in your
• 3:37
  Speaker 1: appearance before the staff of this commission. Epstein, do you
• 3:42
  Speaker 1: understand that? Epstein answers, yes. Question, do you have counsel
• 3:46
  Speaker 1: with you today? Epstein, yes, I do. Question, would counsel
• 3:50
  Speaker 1: please identify himself for the record? Mr. Lehman, yes, my
• 3:54
  Speaker 1: name is Mark E. Lehman, L-E-H-M-A-N. Redacted, Mr. Lehman, you,
• 4:01
  Speaker 1: your firm or employer? Mr. Lehman, I'm employed by Barristerns
• 4:05
  Speaker 1: and Company as the Assistant Director of Law and Compliance.
• 4:09
  Speaker 1: Redacted in Barristern's address and phone number. Gives the phone number. Question, Mr. Epstein.
• 4:14
  Speaker 1: You've been asked to come down today on a voluntary basis.
• 4:17
  Speaker 1: I should advise you that the staff does have subpoena power,
• 4:20
  Speaker 1: but in the particular instance today, you have appeared on
• 4:23
  Speaker 1: a voluntary basis. The witness, we will so stipulate. Redacted. Accordingly,
• 4:29
  Speaker 1: you can discontinue this examination at any time that you
• 4:32
  Speaker 1: feel fit to do so. Epstein, fine, thank you. Question,
• 4:36
  Speaker 1: all right, now you've also been asked to appear on
• 4:38
  Speaker 1: a personal basis, rather than on a representative basis as
• 4:42
  Speaker 1: an employee of a firm or organization. Do you understand that? Epstein, yes. Question, counsel,
• 4:48
  Speaker 1: in what capacity do you appear today on Mr. Epstein's behalf? Mr. Lehman,
• 4:53
  Speaker 1: I appear in both capacities, the capacity as his individual attorney,
• 4:57
  Speaker 1: and also I've disclosed to him, as he well knows,
• 5:01
  Speaker 1: that I'm an attorney for Bear Stearns and Company. Redacted,
• 5:04
  Speaker 1: very well, counselor. In the event that a conflict of
• 5:07
  Speaker 1: interest arises, or a potential conflict of interest arises, I
• 5:10
  Speaker 1: will leave it to your sound exercise of discretion to
• 5:13
  Speaker 1: make that known to the witness, and to make the
• 5:16
  Speaker 1: appropriate arrangements at that time. Mr. Lehman, for the record,
• 5:20
  Speaker 1: I would note, as we had met with the commission before,
• 5:23
  Speaker 1: and were questioned before, and in this order pertains to
• 5:26
  Speaker 1: an investigation into the trading of a tender offer for St.
• 5:30
  Speaker 1: Joe's Minerals, and in that Mr. Epstein is no longer
• 5:33
  Speaker 1: employed by my firm. but his registration had absolutely nothing
• 5:38
  Speaker 1: to do with St. Joe Minerals. I have discussed this
• 5:40
  Speaker 1: in detail with Mr. Epstein, and he understands, and I
• 5:43
  Speaker 1: will use my own judgment, if there is any possible
• 5:46
  Speaker 1: conflict of interest. Redacted very well. All right, Mr. Epstein,
• 5:50
  Speaker 1: I wish to advise you that any evidence you give
• 5:53
  Speaker 1: today may be used against you. Under the Fifth Amendment
• 5:56
  Speaker 1: of the United States Constitution, you are under no obligation
• 5:59
  Speaker 1: or compulsion to incriminate yourself or hold yourself out to fine, forfeiture,
• 6:04
  Speaker 1: or punishment. Epstein, I understand. Redacted, you should also know
• 6:09
  Speaker 1: that under Title 18, Section 1001 of the U.S. Code,
• 6:13
  Speaker 1: whomever may make a false statement to members of the
• 6:15
  Speaker 1: staff may be subject to fine, punishment, or imprisonment. Do
• 6:19
  Speaker 1: you understand that? Epstein, yes, I do. Question, you should
• 6:24
  Speaker 1: also know that anyone making false statements to members of
• 6:27
  Speaker 1: the staff under oath may be subject to perjury charges.
• 6:30
  Speaker 1: Do you understand that? Epstein, yes, I do. Question, if
• 6:34
  Speaker 1: at any time during the course of the examination today
• 6:37
  Speaker 1: you wish to consult with counsel outside the hearing or
• 6:40
  Speaker 1: presence of the staff members or the reporter, please indicate
• 6:43
  Speaker 1: that to me and we will make suitable arrangements. Understand? Epstein,
• 6:48
  Speaker 1: yes I do. Redacted, you should also know that the
• 6:52
  Speaker 1: reporter will not terminate or stop the record at your
• 6:54
  Speaker 1: request or your counsel's request. The reporter will only stop
• 6:58
  Speaker 1: it at my request or another member of the staff's.
• 7:01
  Speaker 1: Do you understand? Epstein, yes, I do. Question accordingly. If
• 7:06
  Speaker 1: you wish to stop the record for any purpose, please
• 7:09
  Speaker 1: indicate to me or one of the other staff members,
• 7:12
  Speaker 1: and we'll make the suitable and appropriate arrangements. Epstein, yes,
• 7:15
  Speaker 1: thank you. Redacted. Question. Mr. Epstein, when I spoke with
• 7:20
  Speaker 1: you the other day, I asked if when you came
• 7:22
  Speaker 1: down today, you would provide us, if you have any,
• 7:25
  Speaker 1: with any documents in your possession relating to your resignation
• 7:29
  Speaker 1: or termination at Bear Stearns. Do you have any documents
• 7:32
  Speaker 1: with you today? Epstein, I have a copy of my
• 7:36
  Speaker 1: resignation letter. Redacted, let the record reflect that Mr. Epstein
• 7:40
  Speaker 1: just handed me a two-page document on the letterhead Jeffrey E. Epstein,
• 7:44
  Speaker 1: Bear Stearns and Company, dated March 25th, 1981. It's addressed
• 7:48
  Speaker 1: to the executive committee. I asked the reporter to mark
• 7:51
  Speaker 1: this as agency exhibit two. Mr. Lehman, in addition, I
• 7:56
  Speaker 1: have a statement that was issued by the executive committee
• 7:59
  Speaker 1: that was issued to the firm and also a cover
• 8:01
  Speaker 1: memo dated March 12th, 1981 from Mr. Epstein to the
• 8:06
  Speaker 1: executive committee. Redacted, thank you. Let the record reflect that
• 8:09
  Speaker 1: I've been handed by Mr. Epstein three pages stapled together.
• 8:13
  Speaker 1: The topmost page on the letterhead, Jeffrey E. Epstein, Bear
• 8:16
  Speaker 1: Stearns and Company, dated March 12th, 1981. And the executive
• 8:20
  Speaker 1: committee and the signature block appears to be the signature
• 8:23
  Speaker 1: of Jeffrey E. Epstein. Is that correct? Epstein, that's correct. Redacted,
• 8:27
  Speaker 1: that's your signature. Epstein, that's correct. Question. The second page
• 8:32
  Speaker 1: is entitled Memo. It's on the letterhead of Bear Stearns,
• 8:35
  Speaker 1: dated March 12th, 1981, and addressed to all partners, all
• 8:39
  Speaker 1: branch managers, account executives from the executive committee, and this
• 8:43
  Speaker 1: memo appears to relate to Mr. Epstein. The third sheet
• 8:46
  Speaker 1: is entitled Uniform Termination Notice for Securities Industry, Representative and
• 8:51
  Speaker 1: or Agent. Number one, the topmost line, individual's name, Jeffrey
• 8:56
  Speaker 1: Epstein Middle, initial E. Mr. Lehman, I call your attention
• 9:01
  Speaker 1: redacted to the reverse side of the last document. There's
• 9:03
  Speaker 1: writing there also. Redacted, okay, very well. The last most document.
• 9:07
  Speaker 1: The one captioned at the top uniform, termination notice. There
• 9:11
  Speaker 1: is three type paragraphs on the back of that document.
• 9:14
  Speaker 1: I'd ask the reporter to mark these. Exhibit number three. Question, Mr. Epstein,
• 9:20
  Speaker 1: have you ever gone by any other name? Other than
• 9:22
  Speaker 1: Jeffrey E. Epstein? Or any other known by any other name? Answer, no. Question,
• 9:28
  Speaker 1: what does E stand for? Answer, Edward. Question, may I
• 9:31
  Speaker 1: have your date of birth and place of birth? Answer,
• 9:34
  Speaker 1: January 20th, 1953, Brooklyn, New York. Question, may I have
• 9:38
  Speaker 1: your present home address and telephone number? Gives them that. Question,
• 9:43
  Speaker 1: do you maintain any other address or residence? Answer, I
• 9:46
  Speaker 1: maintain a residence at 265 East 66th Street, Phone number
• 9:51
  Speaker 1: is 772-9416. Question, that's New York City. Answer, New York,
• 9:57
  Speaker 1: New York. Redacted, the record should reflect that redacted has
• 10:01
  Speaker 1: now entered the room and joined the table. Redacted, this
• 10:04
  Speaker 1: is Mr. Lehman. Mr. Epstein. Question, Mr. Epstein, do you
• 10:09
  Speaker 1: maintain a telephone credit card? Answer, no. Question, are you
• 10:13
  Speaker 1: presently employed? Answer, no. Question, Mr. Lehman. Please, Mr. Epstein,
• 10:17
  Speaker 1: You don't have to look at me. You can answer
• 10:19
  Speaker 1: Redacted's question. Answer, no. Question, when was your most recent
• 10:23
  Speaker 1: date of employment? Answer, I left Bear Stearns on March 12th, 1981. Question,
• 10:31
  Speaker 1: and at that time, what was your capacity at Bear Stearns? Answer,
• 10:34
  Speaker 1: I was a limited partner at Bear Stearns. Question, what
• 10:37
  Speaker 1: were your functions as a limited partner? Answer, no. I
• 10:41
  Speaker 1: was a representative, account executive designated to help out with
• 10:45
  Speaker 1: commodities and financial futures recommendations to the sales force. Question,
• 10:50
  Speaker 1: how long were you with Bear Stearns? Answer, five years. Question,
• 10:54
  Speaker 1: and where were you previous to that? Answer, Dalton School. Question,
• 10:58
  Speaker 1: as part of your education? Answer, no, I was just teaching. Question,
• 11:02
  Speaker 1: how long were you there? Answer, two years. Question, have
• 11:05
  Speaker 1: you held any other position in the securities industry other
• 11:09
  Speaker 1: than gets cut off? By Epstein, no, I have not. Question,
• 11:13
  Speaker 1: may I have a brief resume of your educational background? Answer, sure,
• 11:17
  Speaker 1: by Epstein. I went to Lafayette High School in Brooklyn,
• 11:20
  Speaker 1: which I graduated from. Then I went to Cooper Union,
• 11:23
  Speaker 1: which I did not graduate from. And I spent some
• 11:26
  Speaker 1: time at New York University Graduate School, which I did
• 11:29
  Speaker 1: not graduate from. Question, did you ever serve in the military? Answer, no. Question,
• 11:34
  Speaker 1: Other than your position as a limited partner of Bear Stearns,
• 11:37
  Speaker 1: do you presently or have you in the past year
• 11:40
  Speaker 1: held a position in any managerial capacity in any other firm?
• 11:44
  Speaker 1: Answer no. Question, are you a 5% stockholder in any corporation?
• 11:50
  Speaker 1: Answer no. Question, are you an officer or director of
• 11:53
  Speaker 1: any corporation? Answer no. Question, have you been in the
• 11:56
  Speaker 1: past year? Answer no. Question, have you been a member
• 12:00
  Speaker 1: of any other limited partnerships? Answer no. Question, have you
• 12:04
  Speaker 1: been in the past year? Answer, no. Question, do you
• 12:07
  Speaker 1: maintain any brokerage accounts, security brokerage accounts? Answer, yes, I do. Question,
• 12:12
  Speaker 1: where are those brokerage accounts? Answer, Bear Stearns. Question, do
• 12:16
  Speaker 1: you have any other accounts other than Bear Stearns? Epstein, no. Question,
• 12:21
  Speaker 1: have you had any accounts at any other firm other
• 12:23
  Speaker 1: than Bear Stearns? Answer, no. Question, would you know your
• 12:26
  Speaker 1: account number offhand? Gives it to him. Question, are you married? Answer, no. Question,
• 12:31
  Speaker 1: have you been? Answer, no. Do you have children? Answer, no. Question,
• 12:36
  Speaker 1: do you maintain any bank accounts? Answer, yes. Question, where
• 12:40
  Speaker 1: do you maintain those bank accounts, checking and savings? Answer,
• 12:44
  Speaker 1: Chemical Bank, 55 Water Street. That's my checking account. And
• 12:48
  Speaker 1: Immigrant Savings Bank, it's right across the street. It's Water
• 12:51
  Speaker 1: Street as well. That's my savings account. Do you maintain
• 12:54
  Speaker 1: a safe deposit box? Question, answer, no. Question, have you
• 12:58
  Speaker 1: in the past year? Answer, no. Question, Have you maintained
• 13:02
  Speaker 1: any other bank account in the past year? Answer, Citibank,
• 13:05
  Speaker 1: a checking account and savings account, but no money in
• 13:08
  Speaker 1: the checking account and $ 500 in the savings account. Answer,
• 13:11
  Speaker 1: are those accounts still active? Answer, no. Question, in connection
• 13:15
  Speaker 1: with your employment at Bear Stearns, do you maintain a
• 13:18
  Speaker 1: personal calendar, desk diary, appointment book, or telephone log? Answer,
• 13:23
  Speaker 1: I do maintain somewhat of a diary, but not a
• 13:25
  Speaker 1: telephone log. Question, do you have that diary with you today? Answer, no. Question,
• 13:30
  Speaker 1: do you have it in your possession in some other place? Answer, yes. Question,
• 13:36
  Speaker 1: I would ask you to provide that to the staff.
• 13:38
  Speaker 1: Answer a copy of it or question the original. Mr. Lehman,
• 13:42
  Speaker 1: for what time period? Question, the past six months. Mr. Lehman,
• 13:46
  Speaker 1: any particular subject matter in the diary? May he excise
• 13:50
  Speaker 1: personal matters from that? Redacted, well, perhaps what we can
• 13:53
  Speaker 1: do if you want to sit down with me, we
• 13:55
  Speaker 1: can go over it. And if there are matters that
• 13:57
  Speaker 1: should be excised, we can do that at that point.
• 14:00
  Speaker 1: I'm sure we can work in a joint action. Question, sir,
• 14:04
  Speaker 1: have you ever been convicted of a crime or indicted
• 14:06
  Speaker 1: for a crime? Answer, I've been convicted of a crime
• 14:09
  Speaker 1: in Great Britain at one point. I don't believe it's
• 14:12
  Speaker 1: no federal jurisdiction. Question, do you know offhand whether it
• 14:16
  Speaker 1: was a felony or a misdemeanor? Answer, no, I don't. Question,
• 14:20
  Speaker 1: what did it concern? What was the allegation and what
• 14:23
  Speaker 1: was the conviction? The witness, Epstein, the allegation was I
• 14:27
  Speaker 1: bought an antique sword stick and they said that could
• 14:30
  Speaker 1: not be carried in the country. It had to be
• 14:32
  Speaker 1: shipped out. Question, do you belong to any business societies, fraternities,
• 14:36
  Speaker 1: or social clubs? Answer, by Epstein, the Atrium Club in
• 14:40
  Speaker 1: New York and Pool Club, but no. Question, you don't
• 14:43
  Speaker 1: belong to any professional organizations? Answer, no. All right, folks,
• 14:47
  Speaker 1: we're going to wrap up right here. And in the
• 14:50
  Speaker 1: next episode dealing with a topic we're going to pick
• 14:52
  Speaker 1: up where we left off. All the information that goes
• 14:55
  Speaker 1: with this episode can be found in the description box
• 14:58
  Speaker 1: what's up everyone and welcome to another episode of the
• 15:01
  Speaker 1: Epstein Chronicles in this episode we're going to pick up
• 15:04
  Speaker 1: where we left off with the Jeffrey Epstein deposition with
• 15:08
  Speaker 1: the SEC during the Bear Stearns investigation back in 1981
• 15:15
  Speaker 1: question when did you resign from Bear Stearns answer March
• 15:18
  Speaker 1: 12th question and what was the reason for your resignation
• 15:22
  Speaker 1: answer totally unrelated to St. Joe question may I have
• 15:25
  Speaker 1: an answer to my question What was the basis for
• 15:28
  Speaker 1: your resignation? Answer. It was a disagreement with the way
• 15:32
  Speaker 1: a situation was handled regarding potential violations of a red D. Question. Well,
• 15:37
  Speaker 1: could you elaborate upon the situation you just spoke of? Mr.
• 15:40
  Speaker 1: Lehman jumps in. I believe I will allow the witness
• 15:43
  Speaker 1: to go a little bit into the area. However, it
• 15:46
  Speaker 1: apparently has nothing to do with whatever the subject of
• 15:49
  Speaker 1: the formal order of investigation. And I really hope that
• 15:53
  Speaker 1: we don't dwell on this matter to the extent. that
• 15:56
  Speaker 1: he can briefly touch upon it, I'll allow him to
• 15:58
  Speaker 1: go ahead. Question, okay. Epstein, answers. There's a conflict that
• 16:04
  Speaker 1: arose that I made people aware of personally when I
• 16:06
  Speaker 1: found out a situation in discussions unrelated to one topic.
• 16:10
  Speaker 1: It was brought to my attention to anyone to buy stock.
• 16:13
  Speaker 1: It was my understanding that as a broker, I could
• 16:16
  Speaker 1: not participate in any profits or losses, but I was
• 16:19
  Speaker 1: not aware of the fact that you could not just
• 16:22
  Speaker 1: strictly lend money to a friend. I, in fact, made
• 16:24
  Speaker 1: two members of the executive committee aware of the fact
• 16:28
  Speaker 1: that the full details involved in it. The way it
• 16:30
  Speaker 1: was handled subsequently was offensive to me, and I decided
• 16:33
  Speaker 1: to resign. Question, when did you have your first conversation
• 16:37
  Speaker 1: with the executive committee? Answer, approximately March 3rd. Question, do
• 16:42
  Speaker 1: you know if the executive committee was aware of this
• 16:45
  Speaker 1: incident prior to March 3rd? Epstein, absolutely not. Redacted, do
• 16:50
  Speaker 1: you know if any member of the executive committee were
• 16:53
  Speaker 1: aware of the incident? Epstein, no. Question, do you know
• 16:56
  Speaker 1: how it first came to the attention of the executive committee? Answer,
• 17:01
  Speaker 1: when it was in a discussion regarding the distribution of
• 17:04
  Speaker 1: new issues, they'd asked me a question, have I lent
• 17:08
  Speaker 1: money to someone to buy stocks? And I said, absolutely not.
• 17:11
  Speaker 1: But in fact, was that a question? Then I learned
• 17:14
  Speaker 1: that a broker could not, in fact, lend money. And I,
• 17:17
  Speaker 1: in one instance, did lend money to a friend. Question,
• 17:20
  Speaker 1: and you say, it was in connection with what? This
• 17:23
  Speaker 1: came up in connection with an offering? Answer, no, no.
• 17:26
  Speaker 1: It was in connection with a discussion regarding someone, a
• 17:29
  Speaker 1: client of mine's account, and the way they had received
• 17:31
  Speaker 1: new issue distributions. Question, and do you remember what the
• 17:36
  Speaker 1: new issue distribution was? Answer, it was a series of
• 17:40
  Speaker 1: new issue distribution. It wasn't a new issue distribution. Mr. Lehman,
• 17:44
  Speaker 1: are you asking for the name of the security? Question, yes.
• 17:48
  Speaker 1: The transaction that prompted, Mr. Lehman, why don't you just
• 17:51
  Speaker 1: tell them the securities? Epstein, it was a series of
• 17:54
  Speaker 1: new issue distributions. It wasn't a one transaction. They wanted
• 17:58
  Speaker 1: to know, in fact, they were asking questions about why
• 18:01
  Speaker 1: I had a client who had received a series of
• 18:03
  Speaker 1: new issues, not one particular one. Question, and in that connection,
• 18:09
  Speaker 1: that they asked you if you had any loan money
• 18:11
  Speaker 1: to any customers? Answer, that's correct. Question, now who was
• 18:15
  Speaker 1: it that asked you this? Epstein, it was redacted, as
• 18:19
  Speaker 1: in my letter of resignation, redacted and redacted two members
• 18:22
  Speaker 1: of the executive committee. Question, and did anyone else participate
• 18:26
  Speaker 1: in the conversation? Answer, no. Question, and what happened? Did they?
• 18:31
  Speaker 1: Maybe you can just give me a little bit more
• 18:33
  Speaker 1: of a narrative on this. They ask you, in connection
• 18:35
  Speaker 1: with this one particular matter, if you had loaned any
• 18:38
  Speaker 1: money to customers and you said no. Answer, they were
• 18:41
  Speaker 1: talking about, that's right, if I had lent money to
• 18:44
  Speaker 1: the particular customer. question and you ask them why is
• 18:47
  Speaker 1: that a problem in words or substance is that correct
• 18:50
  Speaker 1: answer that is correct question and then they explained that
• 18:54
  Speaker 1: if it was a problem to you is that correct
• 18:57
  Speaker 1: answer correct question and then when did you tell them
• 19:01
  Speaker 1: gets cut off by Epstein immediately I said well approximately
• 19:04
  Speaker 1: six or seven months ago I did lend money in
• 19:07
  Speaker 1: one instance to my closest friend and the record would
• 19:10
  Speaker 1: show that in fact that was the case Question, the
• 19:13
  Speaker 1: record would show that you had loaned the money? Answer,
• 19:15
  Speaker 1: that's right. Question, how would that show? Answer, because it
• 19:19
  Speaker 1: was right on his account statement that my check was
• 19:21
  Speaker 1: deposited in his account. There was no attempt to conceal anything. Question,
• 19:26
  Speaker 1: I understand that, but did it say on the statement
• 19:28
  Speaker 1: that the check was deposited as a loan? Answer, no. Question,
• 19:33
  Speaker 1: what did these two individuals say that is redacted and redacted? Answer,
• 19:36
  Speaker 1: just redacted. Mr. Lehman, redacted. Question, It ends with an
• 19:41
  Speaker 1: S though, doesn't it? Mr. Lehman, no. Redacted, it does not. Mr. Lehman, no. Epstein,
• 19:47
  Speaker 1: they said that it was a possible violation of Red D.
• 19:50
  Speaker 1: and they'd look into it. Question, did they at any
• 19:53
  Speaker 1: point suggest that there would be any action taken? Answer,
• 19:56
  Speaker 1: they said that the issue could be serious or serious
• 19:59
  Speaker 1: and they would look into it and see what should
• 20:02
  Speaker 1: be done. Question, did they ask you how much money
• 20:04
  Speaker 1: you had loaned to your customer? Answer, yes, sir. Question,
• 20:08
  Speaker 1: and what was your answer? Answer, it was $ 15, 000. Question,
• 20:12
  Speaker 1: and did they ask you if the loan had been
• 20:14
  Speaker 1: paid off? Answer, yes, it was, yes. Question, and was,
• 20:17
  Speaker 1: in fact, the loan paid off? Answer, yes. Mr. Lehman,
• 20:22
  Speaker 1: I think we're beyond the scope of the formal order
• 20:24
  Speaker 1: at this point. Can I ask that the questions be
• 20:26
  Speaker 1: directed to the questions concerning Joe's Minerals? Redacted, we will
• 20:30
  Speaker 1: reserve our right to come back to this area if
• 20:33
  Speaker 1: it's appropriate. Mr. Lehman, okay. Redacted, when was your next meeting,
• 20:37
  Speaker 1: if any meeting, after the first one? Answer, it was
• 20:40
  Speaker 1: the subsequent two days. Question, you're talking about March 5th now? Answer,
• 20:45
  Speaker 1: March 4th, I believe. March 3rd was the first meeting
• 20:48
  Speaker 1: and the 4th and the 5th. Question, did anyone additional
• 20:51
  Speaker 1: to redacted and redacted participate in the subsequent meetings? Answer, no. Question,
• 20:57
  Speaker 1: was anyone else present other than those two individuals and yourself? Answer, no. Question,
• 21:03
  Speaker 1: were any matters other than the matters discussed at the
• 21:05
  Speaker 1: first meeting discussed at these later meetings? Answer, no. Question,
• 21:10
  Speaker 1: did you have any meetings with these gentlemen subsequent to
• 21:13
  Speaker 1: those two meetings? Answer, not regarding anything to do with this. Redacted,
• 21:17
  Speaker 1: this being? Epstein, this being the issue of the loan
• 21:20
  Speaker 1: to the customer that's described in my resignation. Question, did
• 21:24
  Speaker 1: you have any occasion to meet with any members of
• 21:26
  Speaker 1: the executive committee the week of March 9th? Answer, which
• 21:31
  Speaker 1: is the following week? Yes. Question, when was the first meeting? Answer,
• 21:36
  Speaker 1: I believe it was Tuesday. Again, I'm not sure of
• 21:38
  Speaker 1: my dates. It was a Tuesday that I met with
• 21:40
  Speaker 1: redacted and redacted again. Question, anyone else present? Answer, no. Question,
• 21:46
  Speaker 1: what was the nature of the discussion at that time? Answer,
• 21:50
  Speaker 1: the fact that they thought a $ 2, 500 fine was in
• 21:53
  Speaker 1: order for the violation, but since I had made a
• 21:55
  Speaker 1: voluntary disclosure and it was a single instance. Question, did
• 22:00
  Speaker 1: they indicate to you whether this matter had been discussed
• 22:02
  Speaker 1: with anyone else on the executive committee? Answer, no. But
• 22:06
  Speaker 1: in fact, they had indicated that there was executive committee
• 22:09
  Speaker 1: meetings going on regarding the subject. Question, when did that
• 22:13
  Speaker 1: come to your attention? Answer, probably on the first day.
• 22:16
  Speaker 1: Was it the third? That this is an area that
• 22:19
  Speaker 1: these two people had been assigned to. Question, by the
• 22:22
  Speaker 1: executive committee to explore? Answer, right. Question, did they indicate
• 22:26
  Speaker 1: to you who on the executive committee had asked them
• 22:29
  Speaker 1: to look into this matter? Answer, no. Question, did you
• 22:33
  Speaker 1: ever come to learn who asked them to look into
• 22:35
  Speaker 1: the matter? Answer, the executive committee. I don't know. Question,
• 22:39
  Speaker 1: both of these individuals are members of the committee. Answer,
• 22:42
  Speaker 1: that's correct. Mr. Lehman, just to clarify, I'm not sure
• 22:45
  Speaker 1: that either redacted or redacted are in fact members of
• 22:49
  Speaker 1: the executive committee. Redacted and redacted, but whether the executive
• 22:53
  Speaker 1: committee has seven members. Redacted may in fact be a member.
• 22:57
  Speaker 1: Epstein jumps in and may be redacted as of May 1st,
• 23:00
  Speaker 1: but he's... There's a question in my mind as to
• 23:04
  Speaker 1: whether or not they're actually members. Question. During the course
• 23:08
  Speaker 1: of any of your meetings with Redacted, was St. Joe
• 23:12
  Speaker 1: Mineral Corporation discussed at any of these meetings? Answer. No. Question.
• 23:17
  Speaker 1: Did you have occasion to speak with anyone else on
• 23:19
  Speaker 1: the Executive Committee or any members of the Executive Committee
• 23:22
  Speaker 1: regarding St. Joe Minerals? Answer. No. Question. Did it ever
• 23:26
  Speaker 1: come to your attention that certain individuals at the firm
• 23:29
  Speaker 1: were trading in St. Joe Minerals during the week of
• 23:32
  Speaker 1: March 9th? Answer. No. After our discussions on an informal basis, yes. Question,
• 23:39
  Speaker 1: are you referring to the discussion that you and counsel?
• 23:42
  Speaker 1: And I had last week, I believe it was. Answer,
• 23:44
  Speaker 1: that is correct. Question, I think it was on Friday
• 23:47
  Speaker 1: or Thursday. And that was the first that you were
• 23:50
  Speaker 1: aware of it? Answer, I was aware that there was
• 23:53
  Speaker 1: an investigation into members of the firm, as far as
• 23:55
  Speaker 1: I knew, who had participated in St. Joe. That's all
• 23:58
  Speaker 1: I knew. Question, how did that come to your attention? Answer,
• 24:02
  Speaker 1: it was hearsay around the firm. It was no specific individual. Redacted.
• 24:08
  Speaker 1: When did you become aware of that? Epstein, it's hard
• 24:10
  Speaker 1: to say. I'm not really sure. Question, was it before
• 24:13
  Speaker 1: or after you resigned? Answer, oh, after. Question, and after
• 24:17
  Speaker 1: you resigned, did you continue to come into the office? Answer, yes. Question,
• 24:21
  Speaker 1: for how long? Answer, off and on continuously. I'm cleaning
• 24:25
  Speaker 1: out my office. Question, do you still have access to
• 24:28
  Speaker 1: that office now? Answer, that's correct. Question, when were you
• 24:31
  Speaker 1: there most recently? Answer, Friday. Mr. Lehman, he was there today.
• 24:36
  Speaker 1: The witness, oh yeah, today, sorry. Question, prior to today,
• 24:40
  Speaker 1: when was the last time you were there? Answer, Friday.
• 24:44
  Speaker 1: Question of last week, Epstein, yes sir. Question, did you
• 24:47
  Speaker 1: have any occasion to meet with anyone while you were
• 24:50
  Speaker 1: in the office there on Friday? Answer, many different brokers
• 24:53
  Speaker 1: who came in to talk to me. Question, did you
• 24:56
  Speaker 1: have occasion to speak with any members of the executive
• 24:59
  Speaker 1: committee while you were there on Friday? Answer, no. Question,
• 25:03
  Speaker 1: have you had any discussions with any of the executive
• 25:05
  Speaker 1: committee since the date of your letter of resignation, which
• 25:08
  Speaker 1: I believe is March 12th, 1981? Answer, yes, I have. Question,
• 25:14
  Speaker 1: you've had conversations with them? Answer, yes. Question, and with
• 25:17
  Speaker 1: whom have you spoken? Answer, redacted, redacted, and a brief
• 25:21
  Speaker 1: discussion right after the resignation with redacted. Question, when was
• 25:25
  Speaker 1: your conversation with redacted or conversations? Answer, continuously, I'd say.
• 25:30
  Speaker 1: Not Friday, but the 25th. When I handed in my thing,
• 25:33
  Speaker 1: I handed it to redacted. Question, did you discuss this
• 25:37
  Speaker 1: matter with redacted at the time? Answer, which matter? Question
• 25:40
  Speaker 1: the matter. You said you had handed in a certain document.
• 25:43
  Speaker 1: Are you referring to this document, Division Exhibit 2? Answer, yes. Question,
• 25:48
  Speaker 1: and what was the nature of the conversation you had
• 25:50
  Speaker 1: when Division Exhibit 2 was tendered to redacted? Answer, just
• 25:54
  Speaker 1: that here's my resignation, the full letter that accompanied my resignation. Question,
• 25:59
  Speaker 1: what prompted this letter? Answer by Epstein, my wanting to
• 26:03
  Speaker 1: make the facts known because I wanted it clear to
• 26:06
  Speaker 1: people why I had left the firm. Question, take a
• 26:09
  Speaker 1: look when you had just answered, you were referring to
• 26:11
  Speaker 1: a letter that's prepared by you. Is that correct? Answer,
• 26:14
  Speaker 1: that is correct. Question, and it was sent to the
• 26:16
  Speaker 1: executive committee. Answer, it was delivered to redacted by myself
• 26:20
  Speaker 1: on March 25th. Question, and would you take a look
• 26:23
  Speaker 1: at what's been marked as Exhibit 2? Answer, yeah, that's it. Question,
• 26:28
  Speaker 1: prior to your submission of this letter, Division Exhibit 2,
• 26:31
  Speaker 1: Had you submitted anything else to Bear Stearns indicating that
• 26:34
  Speaker 1: you were resigning or about to resign? Answer, yeah. I
• 26:38
  Speaker 1: handed in a letter on March 12th. It was a
• 26:40
  Speaker 1: simple statement that I would like to resign from the
• 26:43
  Speaker 1: firm as a limited partner. Question, I show you what's
• 26:47
  Speaker 1: been marked, what we've marked into evidence as Division Exhibit 3. Answer,
• 26:52
  Speaker 1: it's the first page of Exhibit 3. Question, would you
• 26:54
  Speaker 1: read that into the record, please? Answer, with this letter
• 26:58
  Speaker 1: and accompanying statement, I hereby resign as a limited partner
• 27:01
  Speaker 1: at Bear Stearns, effective immediately. Question now, sir. The letter
• 27:07
  Speaker 1: that's been tendered to us dated March 12th, and as
• 27:10
  Speaker 1: you just read back for the record, speaks of an
• 27:13
  Speaker 1: accompanying statement. Answer right. I didn't make that accompanying statement
• 27:16
  Speaker 1: available to the executive committee until I was sure that
• 27:19
  Speaker 1: I was comfortable with what I had written and handed
• 27:22
  Speaker 1: it to them on the 25th. Question. You provided no
• 27:25
  Speaker 1: other written documents to the executive committee besides the one-page
• 27:28
  Speaker 1: document that's dated March 12th? Answer. On March 12th. Question.
• 27:34
  Speaker 1: Which is the first page of Division Exhibit 3? Is
• 27:36
  Speaker 1: that correct? Answer. That's correct. On March 12th. That's the
• 27:40
  Speaker 1: only thing that I handed them. Alright folks, that's going
• 27:44
  Speaker 1: to do it for this one. And in the next
• 27:45
  Speaker 1: episode dealing with the topic, we're going to pick up
• 27:47
  Speaker 1: where we left off. All the information that goes with
• 27:50
  Speaker 1: this episode can be found in the description box. What's
• 27:54
  Speaker 1: up everyone and welcome to another episode of the Epstein Chronicles.
• 27:58
  Speaker 1: In this episode, we're going to dive right back in
• 28:00
  Speaker 1: to the SEC deposition with Jeffrey Epstein from 1981. Question. Question. Answer. Answer. Answer. Answer.
• 28:35
  Speaker 1: I handed the two-page thing to, I'm trying to remember
• 28:38
  Speaker 1: who I gave it to, on March 12th. Yes, I did. Question,
• 28:42
  Speaker 1: that's your best recollection. Answer, yes. Question, did he ask
• 28:46
  Speaker 1: you where the accompanying statement was? Answer, yes. Question, what
• 28:50
  Speaker 1: did you say? Answer, I said I would have it
• 28:52
  Speaker 1: to him as soon as possible, as soon as it's finished. Question,
• 28:56
  Speaker 1: the two-page document dated March 25th, 1981, Division Exhibit 2,
• 29:01
  Speaker 1: the one that's addressed to the Executive Committee. Was this
• 29:04
  Speaker 1: letter prepared in consultation with anyone else? Answer, no. Question,
• 29:10
  Speaker 1: did anyone else, was anyone else, aware that you were
• 29:13
  Speaker 1: preparing this letter? Answer, anyone else being? Question, at Bear Stearns. Mr.
• 29:18
  Speaker 1: Lehman jumps in. You mean other than redacted? Well, did
• 29:22
  Speaker 1: anyone at Bear Stearns know that you were preparing this
• 29:24
  Speaker 1: two-page document? Epstein, as far as I know, I told
• 29:28
  Speaker 1: the executive committee when I handed in this document on
• 29:30
  Speaker 1: March 12th that I would in fact Have a resignation
• 29:33
  Speaker 1: to accompany that for the letter for the record. Question,
• 29:37
  Speaker 1: and that was redacted. Did you discuss that with anyone else?
• 29:40
  Speaker 1: at Bear Stearns? Answer, no. Question, you said you had
• 29:44
  Speaker 1: some discussions with redacted since the time you submitted your
• 29:48
  Speaker 1: resignation on March 12th of 1981. Is that correct? Answer,
• 29:52
  Speaker 1: that's correct. Question, when were these conversations held and where? Answer,
• 29:57
  Speaker 1: immediately after surrendering my resignation on March 12th. I was
• 30:01
  Speaker 1: just redacted and I made it clear that I, in fact,
• 30:04
  Speaker 1: had handed in my resignation and would be clearing out
• 30:07
  Speaker 1: my office and trying to make a transition as best
• 30:10
  Speaker 1: as possible for the firm and myself. Question, this is redacted. Answer, yes. Question,
• 30:17
  Speaker 1: was redacted aware that you had intended to resign? Or
• 30:20
  Speaker 1: did you consult them before you actually submitted your letter
• 30:23
  Speaker 1: of resignation? Answer, did I consult with them before? Question, yes. Answer,
• 30:28
  Speaker 1: I believe he was aware of what was going on
• 30:30
  Speaker 1: in the executive committee and the way the matter here
• 30:33
  Speaker 1: was being handled. Question, what's the basis for your belief? Answer,
• 30:38
  Speaker 1: he's a member of the executive committee and it's my
• 30:40
  Speaker 1: understanding that the executive committee was looking into it. Question,
• 30:44
  Speaker 1: prior to submitting the letter on March 12th, did you
• 30:47
  Speaker 1: have any conversation with anyone at Bear Stearns regarding resigning
• 30:51
  Speaker 1: from the firm? Answer, no. Question, did redacted Ever have
• 30:55
  Speaker 1: any occasion from March 9th to the present to discuss St.
• 30:58
  Speaker 1: Joe's minerals? Answer, no. Question, did you ever discuss St.
• 31:02
  Speaker 1: Joe minerals with Redacted since March 9th? Answer, no. Question,
• 31:07
  Speaker 1: so you've had some conversations with Redacted. When was the
• 31:10
  Speaker 1: most recent? Answer, that was on March 12th, I believe. Question,
• 31:14
  Speaker 1: what was the nature of that conversation? Answer, just saying,
• 31:18
  Speaker 1: explaining that I was, in fact, very dissatisfied with the
• 31:21
  Speaker 1: way this whole thing was handled and that I was
• 31:23
  Speaker 1: going to resign. and I had, in fact, just handed
• 31:26
  Speaker 1: the resignation to Redacted. Question, you had no conversations with
• 31:30
  Speaker 1: Redacted about St. Joe Minerals? Answer, absolutely not. Question, sir,
• 31:35
  Speaker 1: are you aware that certain rumors may have been circulating
• 31:38
  Speaker 1: around your firm in connection with your reasons for leaving
• 31:41
  Speaker 1: the firm? Answer, I'm aware that there were many rumors. Question,
• 31:45
  Speaker 1: what were the rumors that you heard? Answer, nothing to
• 31:49
  Speaker 1: do with St. Joe. Question, can you relate what you heard? Answer,
• 31:53
  Speaker 1: It was having to do with an illicit affair with
• 31:56
  Speaker 1: the secretary. Question. Have you heard any other rumors suggesting
• 32:00
  Speaker 1: that you had made a presentation or a communication to
• 32:02
  Speaker 1: the executive committee concerning alleged improprieties by other members or
• 32:07
  Speaker 1: employees of Bear Stearns? Answer. I, in fact, have heard
• 32:11
  Speaker 1: that rumor, but it's been from redacted in our conversation
• 32:14
  Speaker 1: last week. Question. Have you heard it from anyone else? Answer. No. Question.
• 32:19
  Speaker 1: Are you aware of the same rumor with respect to
• 32:21
  Speaker 1: any discussion with the executive committee about improprieties by Barra
• 32:25
  Speaker 1: Stearns employees may have been circulating about anyone else in
• 32:29
  Speaker 1: the firm? Answer, no, I am not. Question, do you
• 32:31
  Speaker 1: know an individual named Redacted? Answer, no. Question, if he's
• 32:35
  Speaker 1: a rep at Barra Stearns? Redacted, no, I don't think. Question, Mr. Lehman,
• 32:39
  Speaker 1: I think there is or was a rep named Redacted. Yes, Redacted,
• 32:43
  Speaker 1: I believe it was. Question, you don't know the individual? Answer, no. Question,
• 32:48
  Speaker 1: did it ever come to your attention, while you were
• 32:50
  Speaker 1: still in the employ of Bear Stearns, that certain reps
• 32:53
  Speaker 1: at the firm, during the week of March 9th, were
• 32:56
  Speaker 1: buying options of stock in St. Joe's Mineral Corporation? Answer,
• 32:59
  Speaker 1: at the time, no. Question, did you subsequently come to
• 33:02
  Speaker 1: learn that? Answer, yes. Question, through what source? Answer, through,
• 33:06
  Speaker 1: I believe, you mentioned, it when you called me, and
• 33:09
  Speaker 1: you had asked me about Redacted. Question, is that the
• 33:12
  Speaker 1: first time you'd heard such a statement? Answer, that's correct. Question,
• 33:16
  Speaker 1: It never came to your attention while you were at
• 33:18
  Speaker 1: the firm itself that Redacted was trading in Securities of St. Joe? Answer, no. Question,
• 33:24
  Speaker 1: where did you have your desk? Answer, excuse me? Answer,
• 33:27
  Speaker 1: where did you have your desk? Where did you sit
• 33:29
  Speaker 1: at Bear Stearns before you left? Answer, in a windowed
• 33:33
  Speaker 1: office on the north side of the building. Question, in
• 33:36
  Speaker 1: relation to Redacted's offices? Answer, on the opposite side of
• 33:40
  Speaker 1: the building. Question, on the opposite side. Answer, yeah, they
• 33:43
  Speaker 1: face south, I face north. Question, and did redacted have
• 33:47
  Speaker 1: any type of supervisory relationship to you? Answer, no, absolutely not. Question,
• 33:52
  Speaker 1: your immediate supervisor was redacted? Answer, yes, sir. Question, did
• 33:57
  Speaker 1: you ever hear while you were at Bear Stearns that
• 33:59
  Speaker 1: redacted may have traitor or inside information in connection with St.
• 34:03
  Speaker 1: Joe's Mineral Corporation? Answer, no. Question, did redacted ever have
• 34:07
  Speaker 1: conversations with you about St. Joe's Minerals? Answer, no. Question,
• 34:11
  Speaker 1: did you happen to overhear any conversation between redacted and
• 34:15
  Speaker 1: anyone else regarding St. Joe Minerals? Answer, no. Question, do
• 34:19
  Speaker 1: you know someone named Redacted? Answer, no. Question, do you
• 34:22
  Speaker 1: keep a weekend home or a summer home anyplace? Answer, no. Question,
• 34:27
  Speaker 1: did you ever occasion to be at 400 South Ocean
• 34:30
  Speaker 1: Boulevard in Palm Beach, Florida? Do you know anyone who
• 34:33
  Speaker 1: resides at that address? Answer, I in fact looked at
• 34:36
  Speaker 1: an apartment there. Question, sorry. Answer, I in fact looked
• 34:40
  Speaker 1: at an apartment there about two months ago. Question, why
• 34:42
  Speaker 1: did you look there? Answer, it was advertised in the
• 34:45
  Speaker 1: Palm Beach paper. Question, do you know anyone who lives
• 34:48
  Speaker 1: in Palm Beach? Answer, I know many people who live
• 34:50
  Speaker 1: in Palm Beach. Question, who do you know that lives
• 34:53
  Speaker 1: in Palm Beach? Answer, redacted. Question, can you give us
• 34:57
  Speaker 1: the place of employment of these individuals, if you know? Answer,
• 35:01
  Speaker 1: New York Law Journal, mostly girls, and I can't tell
• 35:03
  Speaker 1: you where, sorry. Redacted, why don't you just give us
• 35:07
  Speaker 1: the names? Redacted, redacted, and the others are just first names. Question,
• 35:11
  Speaker 1: do you have relatives living in Florida? Answer, somewhere. Question,
• 35:15
  Speaker 1: not in Palm Beach. Answer, no. Question, what are the
• 35:18
  Speaker 1: names of your relatives that live in Florida? Answer, I
• 35:21
  Speaker 1: don't even know. It's relatives on my mom's side that
• 35:23
  Speaker 1: I don't even see or speak to. Question, what's your
• 35:26
  Speaker 1: mother's maiden name? Answer, redacted. Question, do you know any
• 35:30
  Speaker 1: of the names of any of your relatives? Answer, I
• 35:33
  Speaker 1: just don't recollect at the moment, but I'm sure I do. Question,
• 35:37
  Speaker 1: you said that there was an ad that you saw
• 35:39
  Speaker 1: approximately two months ago in the with respect to the
• 35:42
  Speaker 1: apartment in Palm Beach? Answer, right. Question, where did you
• 35:46
  Speaker 1: see the ad? Answer, it was in the Palm Beach paper. Question,
• 35:50
  Speaker 1: what were the circumstances as to why you were looking
• 35:52
  Speaker 1: in Palm Beach? Answer, only because I enjoy Palm Beach. Question,
• 35:56
  Speaker 1: do you go there fairly regularly? Answer, yes, sir. Question,
• 36:00
  Speaker 1: how often would you say you go there in a month? Answer,
• 36:03
  Speaker 1: once a month. Question, once a month. In connection with
• 36:07
  Speaker 1: any of your visits to Palm Beach, did you discuss
• 36:09
  Speaker 1: with anyone on the topic of St. Joe or stock
• 36:12
  Speaker 1: issued by St. Joe or options in St. Joe's Mineral? Answer,
• 36:16
  Speaker 1: absolutely not. Question. Do you know anyone at Bear Stearns
• 36:19
  Speaker 1: who maintains an account in a Swiss bank, either a
• 36:22
  Speaker 1: trading account or a bank account? Answer, no. Question. It
• 36:26
  Speaker 1: never came to your attention that any of the partners
• 36:28
  Speaker 1: or traders there may have maintained accounts in Swiss banks? Answer, no. Question.
• 36:34
  Speaker 1: When you went to this apartment in Palm Beach, did
• 36:36
  Speaker 1: you go by yourself? Answer. I was with a real
• 36:38
  Speaker 1: estate agent. Question. And what was the name of the
• 36:42
  Speaker 1: real estate agent? Answer. I don't remember. Question. Did you
• 36:45
  Speaker 1: look at the apartment? Answer. Yes. Question. Did you look
• 36:48
  Speaker 1: at several apartments? Answer. No. Question. Only one? Answer. Yes. Question.
• 36:53
  Speaker 1: Was it occupied? Answer. No. It was empty. Question. Was
• 36:56
  Speaker 1: it a rental or was it a purchase situation? Answer,
• 37:00
  Speaker 1: it was a purchase situation. It was an estate sale.
• 37:02
  Speaker 1: Someone had died, obviously, if it was an estate sale,
• 37:05
  Speaker 1: and the son couldn't get rid of it. Question, did
• 37:07
  Speaker 1: you meet the son? Answer, no. Question, did you know
• 37:10
  Speaker 1: the son? Answer, no. Question, did you know anybody connected
• 37:14
  Speaker 1: with the estate? Answer, no. Question, was this piece of
• 37:18
  Speaker 1: property in the paper, or was it just a general
• 37:20
  Speaker 1: ad for the building? Answer, the building was not mentioned.
• 37:23
  Speaker 1: It was an ad saying, sacrifice apartment. Question, did you
• 37:28
  Speaker 1: speak to anybody about this apartment before you went to
• 37:30
  Speaker 1: look at it besides the real estate agent? Answer, no. Question,
• 37:33
  Speaker 1: were you familiar with the building? Answer, I had passed
• 37:37
  Speaker 1: by a number of times. Question, do you know anybody
• 37:40
  Speaker 1: that lives in that building? Answer, no. Question, do you
• 37:43
  Speaker 1: know any other individuals at Bear Stearns who also vacation
• 37:46
  Speaker 1: in Palm Beach? Answer, many people tell me that they've
• 37:49
  Speaker 1: been there, but I don't know about vacations. Question, do
• 37:52
  Speaker 1: you know if Redacted maintains an apartment in Palm Beach? Answer,
• 37:55
  Speaker 1: I don't believe so. I don't know. Question, do you
• 37:59
  Speaker 1: know if Redacted does? Answer, I don't know. Question, do
• 38:02
  Speaker 1: you know if any Bear Stearns employees have relatives that
• 38:04
  Speaker 1: live in Palm Beach? Answer, I'm sure they do, but
• 38:07
  Speaker 1: I don't know about it. Question, do you know any? Answer, no. Question,
• 38:11
  Speaker 1: do you know any Bear Stearns employees who have vacationed
• 38:13
  Speaker 1: in Palm Beach during the past three weeks? Answer, no. Question,
• 38:18
  Speaker 1: do you know anybody at the firm, or at any
• 38:20
  Speaker 1: firm other than Bear Stearns, who vacations or maintains a
• 38:23
  Speaker 1: residence in Palm Beach, who's worked for any other brokerage firm? Answer, no.
• 38:27
  Speaker 1: Any other brokerage firm? I know this redacted. Who has
• 38:31
  Speaker 1: an apartment, but I don't know if he works for
• 38:33
  Speaker 1: a brokerage firm? By redacted. Question. Who is redacted? Answer.
• 38:37
  Speaker 1: He used to be redacted at Bear Stearns. Question. In
• 38:41
  Speaker 1: connection with your employment at Bear Stearns, do you have
• 38:43
  Speaker 1: any clients who are Swiss bankers? Or do you have
• 38:46
  Speaker 1: any trading through Swiss banks? Answer. No. Question. Do you
• 38:49
  Speaker 1: know if Bear Stearns has clients who are Swiss banks
• 38:52
  Speaker 1: or deals with Swiss banks up there? Answer. No. Question.
• 38:55
  Speaker 1: Do you know if the firm... Has any clients who
• 38:57
  Speaker 1: are Swiss banks? Answer, no. Question, can we go off
• 39:00
  Speaker 1: the record for a second? They come back on. Mr. Epstein,
• 39:04
  Speaker 1: there were no conversations of a substantive nature between us
• 39:07
  Speaker 1: while we were off the record, were there? Witness, no. Question,
• 39:11
  Speaker 1: do you know anyone, name redacted, that name familiar to
• 39:14
  Speaker 1: you at all? Answer, not at all. Question, now if
• 39:18
  Speaker 1: you know, is in possession of the original of Division
• 39:21
  Speaker 1: Exhibit 2, the letter dated March 25th, 1981? Answer again.
• 39:26
  Speaker 1: I handed it to Redacted on that day. So as
• 39:28
  Speaker 1: far as I know, he was the one who had it. it. Question.
• 39:31
  Speaker 1: Have you ever made any other presentation or communication to
• 39:34
  Speaker 1: the Bear Stearns Executive Committee besides what's reflected by Exhibit
• 39:38
  Speaker 1: 3 and Exhibit 2? Mr. Lehman, in connection with circumstances
• 39:42
  Speaker 1: on anything at all? Redacted on anything. Answer. The full
• 39:46
  Speaker 1: Executive Committee? Maybe two years ago I made a presentation.
• 39:50
  Speaker 1: question did you do it in person or by letter
• 39:52
  Speaker 1: answer in person all right folks we're going to wrap
• 39:54
  Speaker 1: up right here and in the next episode dealing with
• 39:56
  Speaker 1: the topic we're going to pick up where we left
• 39:58
  Speaker 1: off all the information that goes with this episode can
• 40:01
  Speaker 1: be found in the description box what's up everyone and
• 40:05
  Speaker 1: welcome to another episode of the epstein chronicles in this
• 40:09
  Speaker 1: episode we're going to pick up where we left off
• 40:11
  Speaker 1: with jeffrey epstein and his deposition with the sec from
• 40:15
  Speaker 1: 1981 Question, have you communicated orally by smoke signal? Answer,
• 40:25
  Speaker 1: nothing to do with St. Joe. Question, I didn't ask
• 40:28
  Speaker 1: if it was restricted to St. Joe. I'm asking if
• 40:31
  Speaker 1: you had any communication with the executive committee other than
• 40:34
  Speaker 1: Exhibit 2 and Exhibit 3. Answer, I have spoken, again,
• 40:39
  Speaker 1: as I've stated, to a redacted afterward, after I handed
• 40:43
  Speaker 1: in the resignation regarding the resignation circumstances. Question, did redacted
• 40:48
  Speaker 1: come up with this conversation or come up in this conversation? Answer,
• 40:52
  Speaker 1: only my feelings for redacted being as he's someone who's
• 40:55
  Speaker 1: helped me along. Question, would help you in what way? Answer,
• 40:58
  Speaker 1: you know, that he had helped me. Question, that he
• 41:01
  Speaker 1: had helped you? Answer, yeah, and I felt that remorse
• 41:04
  Speaker 1: at leaving the firm. Question, how had redacted helped you? Answer,
• 41:08
  Speaker 1: he had explained many things to me in the firm.
• 41:10
  Speaker 1: He'd been a friend. Question, completely redacted. Question, Was there
• 41:16
  Speaker 1: any discussion in connection with the circumstances of your leaving
• 41:19
  Speaker 1: concerning expense accounts and claims for reimbursement of expenses by
• 41:24
  Speaker 1: you against Bear Stearns? Answer. There was a discussion on March,
• 41:28
  Speaker 1: that second discussion, March 9th, regarding, they had asked me
• 41:32
  Speaker 1: what the situation was with some expenses I had put in,
• 41:35
  Speaker 1: and it was my recollection that none of the expenses
• 41:38
  Speaker 1: went back to 1978. And then they came back and said, yeah,
• 41:41
  Speaker 1: in fact, someone who is the financial officer, had said
• 41:45
  Speaker 1: the expenses did go back to 1978. That's all. Question.
• 41:50
  Speaker 1: How much was involved in expenses back into 1978? Answer.
• 41:54
  Speaker 1: In 78? Question. Yeah. Answer. I don't really know. I
• 41:58
  Speaker 1: have never seen the expenses that they... Gets cut off
• 42:01
  Speaker 1: by the guy asking questions. Who was it that you
• 42:04
  Speaker 1: spoke to about this? Epstein. Redacted. Question. Was there any
• 42:09
  Speaker 1: allegation or suggestion that there may have been... Putting in
• 42:12
  Speaker 1: claims for reimbursement that you were not entitled to? Answer.
• 42:16
  Speaker 1: There was discussion whether in fact I had ever put
• 42:18
  Speaker 1: in an airline ticket for someone else and not myself.
• 42:22
  Speaker 1: And I said that it was possible in fact since
• 42:24
  Speaker 1: my secretary handles my expenses. I was sure that if
• 42:27
  Speaker 1: someone else's airline ticket was in there, it wasn't asked
• 42:30
  Speaker 1: for reimbursement for two people. It was in fact the
• 42:33
  Speaker 1: wrong ticket. But I never saw the expenses. It wasn't shown. Question.
• 42:38
  Speaker 1: Do you know how much was in dispute? Answer. Well,
• 42:41
  Speaker 1: if it was an airline ticket, it couldn't have been
• 42:43
  Speaker 1: much money, but I don't really know. I don't think
• 42:46
  Speaker 1: it was any money in dispute. They asked me whether
• 42:49
  Speaker 1: or not I had put it in for someone else.
• 42:52
  Speaker 1: I said not to my recollection, and they came back
• 42:54
  Speaker 1: and said someone remembers seeing a different airline ticket, and
• 42:57
  Speaker 1: that's the extent of it. Question. This was someone had
• 43:01
  Speaker 1: remembered seeing a different airline ticket. Did they tell you
• 43:04
  Speaker 1: how long ago? Answer. No. Question. Do you know why
• 43:07
  Speaker 1: that subject was brought up at the time? Answer. There
• 43:10
  Speaker 1: was a fact about, again, going over that had gone on.
• 43:14
  Speaker 1: I think this is fine regarding the violation of fee.
• 43:16
  Speaker 1: It's ridiculous. I think it's excessive. And there was a
• 43:20
  Speaker 1: fact about carelessness. You've been careless in the past. That's
• 43:23
  Speaker 1: how it was brought up. Question. Do you have an
• 43:26
  Speaker 1: understanding that anyone, other than the people that we've mentioned
• 43:29
  Speaker 1: in this testimony, have traded in St. Joe's stock or options? Answer. No. Question.
• 43:35
  Speaker 1: Upon your termination or resignation at Bear Stearns, were you
• 43:38
  Speaker 1: promised or did you come to expect? Any sort of
• 43:41
  Speaker 1: compensation package? Answer. I, in fact, I get paid on
• 43:44
  Speaker 1: a yearly basis. I get a salary plus a bonus.
• 43:48
  Speaker 1: I was paid normally in May. And in fact, he
• 43:50
  Speaker 1: said that I would get paid for my work until
• 43:52
  Speaker 1: March 12th. Question. What about the bonus? Answer. That's when
• 43:56
  Speaker 1: I draw the money. Question. So you anticipate receiving that
• 43:59
  Speaker 1: bonus in May sometime? Answer. Yes. Question. How substantial is
• 44:04
  Speaker 1: that bonus? Answer. I don't know what you mean by substantial.
• 44:08
  Speaker 1: It's a lot of money. Question, how much money is involved? Answer,
• 44:12
  Speaker 1: it's a subjective bonus, so it's very questionable. It could
• 44:15
  Speaker 1: be anywhere between $ 50, 000 and $ 150, 000. Question, what are your expectations? Answer,
• 44:21
  Speaker 1: it's unclear. My guess is about $ 100, 000. Question, what is
• 44:25
  Speaker 1: the bonus based on? Answer, the system with the firm
• 44:28
  Speaker 1: works is based on many different factors. Commissions generated, I
• 44:32
  Speaker 1: don't have salaried employees, are given a very low salary
• 44:36
  Speaker 1: and then compensated at the end of the year broadly based.
• 44:39
  Speaker 1: on how the firm does as a total entity and
• 44:42
  Speaker 1: your participation towards those profits. Question, you're a salaried employee
• 44:46
  Speaker 1: or were a salaried employee. Is that right? Answer, I
• 44:49
  Speaker 1: was a salaried employee and I received commissions and a bonus. Question,
• 44:53
  Speaker 1: what was your salary? Answer, $ 42, 000. Question, you understood that
• 44:58
  Speaker 1: in connection with your resignation, you would receive your salary
• 45:01
  Speaker 1: through March 12th. Is that correct? Answer, yes, sir. Question,
• 45:05
  Speaker 1: did you have any understanding that you would receive any
• 45:07
  Speaker 1: additional salary Beyond March 12th? Answer, no sir. Question, was
• 45:11
  Speaker 1: that ever discussed? Answer, no sir. Question, with anyone? Answer,
• 45:15
  Speaker 1: no sir. Again, the bonus was in fact discussed. Question,
• 45:19
  Speaker 1: and how much of a bonus did you make the
• 45:21
  Speaker 1: previous year in total? Answer, well, bonus in total. My
• 45:25
  Speaker 1: total compensation, you see, we discussed things in terms of
• 45:27
  Speaker 1: total compensation, and last year was over $ 200, 000. Question, and
• 45:31
  Speaker 1: of that $ 200, 000, some of it was? Answer, $ 135, 000 was
• 45:33
  Speaker 1: the bonus. Question, 135 was the bonus. And you know
• 45:41
  Speaker 1: how you came to expect 100,000 in bonus for your
• 45:44
  Speaker 1: employment through March? Answer again. It's a subjective thing. I
• 45:48
  Speaker 1: felt that I had done a good job this year
• 45:50
  Speaker 1: as last year. Question, but you've only been there for
• 45:54
  Speaker 1: three months of the year. Answer, no, we're on a
• 45:56
  Speaker 1: May year. So it's 10 out of the 12 months. Question,
• 46:00
  Speaker 1: was there any discussion about buying your interest out of
• 46:02
  Speaker 1: the limited partnership over and above any compensation that you
• 46:06
  Speaker 1: may have received by reason of your annual salary and bonus? Answer, no.
• 46:11
  Speaker 1: As a matter of fact, there's a question that's not
• 46:13
  Speaker 1: been discussed yet. I don't believe whether in fact I
• 46:16
  Speaker 1: can get my limited partnership money out as it stands. Question,
• 46:20
  Speaker 1: how much is tied up? Answer, $ 30, 000 approximately. It's a
• 46:24
  Speaker 1: 20 plus participation. So the participation again is based upon
• 46:28
  Speaker 1: a full year. then prorated back to 10. Question, who
• 46:32
  Speaker 1: have you had those discussions with? Answer, redacted. Question, what
• 46:36
  Speaker 1: seems to be the snag? Answer, the firm policy is,
• 46:38
  Speaker 1: varies for the different people as far as when they decide.
• 46:42
  Speaker 1: A general partnership is structured such that you don't want
• 46:45
  Speaker 1: your partners taking out their capital, so that most partners
• 46:48
  Speaker 1: get their capital distributed over a certain number of years.
• 46:51
  Speaker 1: The number of years I'm not sure of, and I
• 46:53
  Speaker 1: don't know whether that's clear or not, whether that applies
• 46:56
  Speaker 1: to limited partners or not. Question, so it would be
• 47:00
  Speaker 1: your expectation that you would receive your money over a
• 47:03
  Speaker 1: period of time, as opposed to one lump sum? Answer, no,
• 47:06
  Speaker 1: I believe it'll come in one lump, because the money
• 47:09
  Speaker 1: is insignificant compared to the amount of money in the partnership. Question,
• 47:13
  Speaker 1: do you anticipate then being bought out of the partnership
• 47:16
  Speaker 1: in some formal fashion? Answer, I anticipate receiving my money back. Question,
• 47:21
  Speaker 1: do you have a lawyer in connection with these negotiations? Answer,
• 47:25
  Speaker 1: there's no negotiation. Question, This is a conversation between you
• 47:29
  Speaker 1: and redacted. Answer, yes. Question, do you have any sisters? Answer,
• 47:34
  Speaker 1: I do not. Question, do you have any brothers? Answer, yes. Question,
• 47:38
  Speaker 1: are any of them married? Answer, no. I have one brother. Question,
• 47:41
  Speaker 1: one brother. What is his name? Gives him the name.
• 47:44
  Speaker 1: Where does he live? All of this is redacted. Where
• 47:47
  Speaker 1: is he employed? What does he do? Have you had
• 47:50
  Speaker 1: any type of business dealings with redacted? Question, there's no
• 47:53
  Speaker 1: relationship with Bear Stearns. Question, pardon? Answer, other than Bear Stearns, no. Question,
• 47:59
  Speaker 1: have you been participant in any type of business ventures
• 48:02
  Speaker 1: with Redacted? Answer, no. Question, do you have any expectations
• 48:08
  Speaker 1: of participating in any business ventures with Redacted? Answer, no. Question,
• 48:13
  Speaker 1: have you had any business participations with Redacted? Answer, no.
• 48:17
  Speaker 1: Nor do I anticipate any. Question, Mr. Epstein, did anyone
• 48:20
  Speaker 1: at Bear Stearns tell you in words or substance that
• 48:23
  Speaker 1: you should not divulge anything about St. Joe Minerals to
• 48:26
  Speaker 1: the staff of the Securities and Exchange Commission? Answer, no. Question,
• 48:31
  Speaker 1: has anyone indicated to you in any way, either directly
• 48:34
  Speaker 1: or indirectly in words or substance, that your compensation for
• 48:38
  Speaker 1: the past year or any future monies coming to you
• 48:41
  Speaker 1: from Bear Stearns will be contingent upon your not divulging
• 48:44
  Speaker 1: information to the Securities and Exchange Commission? Answer, no. Question,
• 48:50
  Speaker 1: now I think earlier we asked for your phone number
• 48:53
  Speaker 1: and we got your phone number. Is that correct? Answer, yes,
• 48:56
  Speaker 1: two phone numbers. Question, two phone numbers. Those are for
• 48:59
  Speaker 1: your house in the city. Answer, in Brooklyn. Question, and
• 49:02
  Speaker 1: in Brooklyn. Can we get the phone records for those
• 49:05
  Speaker 1: two numbers from the 1st of the year, January 12th
• 49:09
  Speaker 1: or January 1st? Mr. Lehman, do you have in your
• 49:11
  Speaker 1: possession your phone records for the period of time? The witness,
• 49:15
  Speaker 1: the phone bills? Question the toll charges. The sheet with
• 49:19
  Speaker 1: the toll charges. Epstein, I would doubt it. I could,
• 49:23
  Speaker 1: I guess, get them from the phone company. I don't
• 49:25
  Speaker 1: have them. Mr. Lehman, the commission can certainly subpoena the
• 49:28
  Speaker 1: telephone company for whatever phone records it wants. Redacted, all right. Question,
• 49:34
  Speaker 1: do you presently have your March bill at least, or
• 49:36
  Speaker 1: have you received your March bill yet? Answer, I don't
• 49:39
  Speaker 1: really know. The March bill being you're talking about, March
• 49:42
  Speaker 1: 1st to date? Is the question? Answer, no, I don't
• 49:45
  Speaker 1: believe so. Question, all right. We would ask that once
• 49:48
  Speaker 1: it's received by you, that you forward it to us. Answer, okay. Mr. Lehman,
• 49:53
  Speaker 1: we will also ask to see the original of the
• 49:56
  Speaker 1: March 25th letter, Division Exhibit 2. Mr. Lehman, again, I'll
• 50:01
  Speaker 1: check to see if it's available. We certainly have no objection. Question,
• 50:05
  Speaker 1: I would also ask to speak with a responsible official
• 50:08
  Speaker 1: to call their file to see if there's any other
• 50:10
  Speaker 1: documents in their possession. Tending to Mr. Epstein's March 12th,
• 50:15
  Speaker 1: 1981 letter of resignation. That's Divisions Exhibit 3. Mr. Lehman, again,
• 50:20
  Speaker 1: I'll check to see if it's available. I have no problem.
• 50:23
  Speaker 1: I'll ship it up here by messenger if you would like,
• 50:25
  Speaker 1: whatever you want. Question, including copies of Mr. Epstein's diary. Lehman,
• 50:29
  Speaker 1: for the last six months. Question, right, Lehman, we will
• 50:33
  Speaker 1: endeavor to provide that to you. Mr. Harris, okay. Question.
• 50:37
  Speaker 1: Last question today. Is it your testimony under oath today
• 50:41
  Speaker 1: that during the period of March 9th through March 13th, 1981,
• 50:44
  Speaker 1: you did not have any information regarding a proposed takeover
• 50:48
  Speaker 1: of St. Joe Minerals Corporation by Seagram's? Answer. That's correct. Answer.
• 50:53
  Speaker 1: Is it also your testimony that you're unaware that anyone
• 50:56
  Speaker 1: else at Bear Stearns had such information available? Answer. That's correct. Question.
• 51:02
  Speaker 1: And furthermore, that you're aware of Anyone outside of Bear
• 51:06
  Speaker 1: Stearns who may have had this information in their possession
• 51:09
  Speaker 1: before the public announcement of Seagram's takeover? Answer, that's correct. Epstein,
• 51:15
  Speaker 1: before you go off the record, I just want to
• 51:17
  Speaker 1: make it clear that to facilitate a non-listing in the
• 51:19
  Speaker 1: phone book, my telephone is listed under Jeffrey Edwards. I
• 51:23
  Speaker 1: just want to make that clear. Question, all right. Are
• 51:26
  Speaker 1: you speaking of the Manhattan? Answer, that's correct. Question, Mr. Lehman.
• 51:32
  Speaker 1: I'd like to provide you with an opportunity before we
• 51:34
  Speaker 1: go off the record for you to clarify any points
• 51:37
  Speaker 1: that you feel need clarification. Mr. Lehman, I see no need.
• 51:41
  Speaker 1: I think his testimony was crystal clear that he knew
• 51:44
  Speaker 1: nothing about St. Joe's minerals. Question? Okay, very well. We'll
• 51:48
  Speaker 1: adjourn for the record for today. Of course, the staff
• 51:51
  Speaker 1: reserves the right to recall you sometime in the future
• 51:54
  Speaker 1: if we deem it necessary or appropriate. That being the case,
• 51:57
  Speaker 1: we'll adjourn. Until 5.30. Alright, so that is the conclusion
• 52:01
  Speaker 1: of the 1981 deposition that Jeffrey Epstein gave to the SEC.
• 52:07
  Speaker 1: All the information that goes with that episode can be
• 52:09
  Speaker 1: found in the description box.