Jes Staley And His Unredacted Motion To Exclude JP Morgan's Expert Witness Opinions (Part 1) (10/7/26)

Jes Staley asked Judge Jed Rakoff to exclude expert testimony JPMorgan planned to use against him in the litigation stemming from the bank’s relationship with Jeffrey Epstein. JPMorgan had brought third-party claims against its former executive, arguing that Staley should bear responsibility for some or all of the bank’s potential liability because of his close relationship with Epstein and his role inside JPMorgan. Staley attacked the bank’s experts under Federal Rule of Evidence 702 and the Daubert standard, arguing that their opinions were speculative, lacked a sufficient factual foundation, and did not reliably connect their methodologies to the actual issues the jury would have to decide. His motion was designed to prevent JPMorgan from using expert witnesses to strengthen its effort to shift blame and damages onto him.

Staley also argued that allowing the challenged opinions would create unfair prejudice and risk confusing the jury by presenting conclusions that, in his view, went beyond proper expert analysis and into speculation about causation, responsibility and damages. The motion fit into his broader defense that JPMorgan was attempting to make him the principal fall guy for a relationship with Epstein that the bank itself maintained for years despite repeated warning signs. By seeking to exclude the experts entirely, Staley was trying to narrow the evidence JPMorgan could present in support of its indemnification and contribution claims and make it harder for the bank to prove that his conduct, rather than JPMorgan’s own institutional decisions, was responsible for the losses tied to the Epstein litigation.



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