Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/267-12.pdf

Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 1 of 14 EXHIBIT 207 Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 2 of 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STACEY E. PLASKETT Confidential GOV. OF U.S. vs JPMORGAN CHASE BANK May 09, 2023 1 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES OF AMERICA, Plaintiff, v Case No. l:22-cv-10904-UA JPMORGAN CHASE BANK, N . A . , Defendant, CONFIDENTIAL VIDEOTAPED DEPOSITION OF STACEY E . PLASKETT Tuesday, May 9 , 2023 9:00 a . m . EST Reported by: Goldy Gold, RPR Job No. J9647388 800.211.DEPO (3376) EsquireSo lutions.com Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 3 of 14 1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 19 20 21 22 23 24 25 STACEY E. PLASKETT Confidential May 09, 2023 14 GOV. OF U.S. vs JPMORGAN CHASE BANK Q. A . STACEY PLASKETT -CONFIDENTIAL What was your book going to be? It was going to be a historical book about earlier life, maybe a generation or so ago, in the Virgin Islands. Q. And what was the law firm that you worked for initially? A . Q. Newman Logan? A. Q. I worked with Nichols Newman Logan. And how long were you with Nichols I was there until 2007. Which was how --I didn' t ask you actually when you first moved down? A. I think I moved down in 2005, so approximately two years. Q. Okay. And what kind of work were you doing at Nichols Newman for those two years? A . Primarily transactional. And also in the Virgin Islands at that time, a l l attorneys d i d court-appointed work. Most of the lawyers in the firm were not courtroom attorneys, and so I d i d a lot of the courtroom appearances for the law firm. Q. new job? Okay. And then 2007, you moved to a 800.211.DEPO (3376) Es quire Solutions. com 09:23 09:23 09:23 09:23 09:23 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 09:24 Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 4 of 14 1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 19 20 21 22 23 24 25 STACEY E. PLASKETT Confidential May 09, 2023 15 GOV. OF U.S. vs JPMORGAN CHASE BANK A. Q . A. STACEY PLASKETT -CONFIDENTIAL Yes. What was that? I was hired as the counsel for the Virgin Islands Economic Development Authority. (Court reporter clarification. ) BY MR. NEIMAN: Q . What is the Virgin Islands Economic Development Authority? A . The Virgin Islands Economic Development Authority is a semi-autonomous agency in the Virgin Islands, which handles many incentives to bring as well as grow businesses in the territory through various vehicles: A government development bank, which gives loans to businesses, small businesses predominantly; a tax incentive program under the U . S . code, which allows businesses and individuals to receive tax reductions on federal taxes for businesses and employment that they bring to the territory. Q . And you described this as a semi-autonomous agency? that? A. Q. Correct. Can you explain what you meant by 800.211.DEPO (3376) Esquire Solutions. com 09:24 09:24 09:24 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:25 09:26 09:26 09:26 09:26 Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 5 of 14 1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 19 20 21 22 23 24 25 STACEY E. PLASKETT Confidential May 09, 2023 86 GOV. OF U.S. vs JPMORGAN CHASE BANK STACEY PLASKETT -CONFIDENTIAL you were going to run for Congress again? A. Q. When I l ost. Okay. And when you went to work for the Kellerhals firm, how long did you work there? A. I don' t recall the time frame, but it would have been 2013. Q. I know that in the past, a t least, Ms. Kellerhals had done work for Mr. Epstein and/or his companies. Did you, while you were at the firm, do any work for Epstein or any Epstein-related businesses? firm? A. Q. A. I don' t recall. What kind of work did you do at the Predominantl y transactional for companies that were in the Virgin Islands and for a few advice related to the economic development. Q. And I take it that Epstein and his businesses remained a client of the Kellerhals f irm during the time that you were there; is that fair? A. Q. Yes. Al l right. Let' s talk about a 800.211.DEPO (3376) Esquire Solutions. com 11: 04 11: 04 11: 04 11: 04 11: 04 11: 04 11:04 11: 04 11: 04 11: 04 11: 04 11: 04 11: 04 11: 04 11: 04 11:04 11: 04 11: 05 11: 05 11: 05 11: 05 11: 05 11: 05 Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 6 of 14 1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 19 20 21 22 23 24 25 STACEY E. PLASKETT Confidential May 09, 2023 148 GOV. OF U.S. vs JPMORGAN CHASE BANK STACEY PLASKETT -CONFIDENTIAL A. I don' t recall. Q. Did you talk to Mr. Epstein about this press release? A . I don't recall. Q. Just going back to the press release for a moment. I 'm sorry. You' l l see in the third paragraph, there' s a description of you having received $5,400 i n two separate contributions from Epstein on August 2nd, according to federal campaign finance records, right? A . Q. Yes. And that was true, right? You had gotten two donations from Mr. Epstein personally on or about August 2nd of 2016? A. Q. Yes, totaling $5,400. Okay. And that was --so August 2nd was about two weeks after the text exchange with Erika about what building you should be going to for a meeting with Mr . Epstein, right? That' s Exhibit 20? A. Q. A . State the date again? I said it' s about two weeks a fter -- Yes. 800.211.DEPO (3376) Esquire Solutions. com 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:28 12:29 12:29 12:29 12:29 12:29 12:29 12:29 12:29 12:29 12:29 Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 7 of 14 1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 19 20 21 22 23 24 25 STACEY E. PLASKETT Confidential May 09, 2023 219 GOV. OF U.S. vs JPMORGAN CHASE BANK STACEY PLASKETT -CONFIDENTIAL A. Virgin Islands' politics, national politics, campaign contribution. was? Q. A. Q. Okay. Do you remember what your ask No. Were you trying to raise money for the DCCC at this time? A. I think I was always trying to raise money for the Democratic Congressional Campaign Committee. Q. That's one of the jobs of being a Democratic congressperson, correct? A. Q. Yes. And you had a total of $250,000 that you were supposed to try to raise? A. Members of Congress, based upon their seniority and committee assignments, have dues as well as raise amounts that are requested. Q. And do you recall yours being around $250,000 in this time period? A. I don' t recall at that time period what it was, but that does not sound unreasonable. Q . It does not sound unreasonable? 800.211.DEPO (3376) Esquire Solutions. com 02: 16 02: 16 02: 16 02: 16 02: 16 02: 16 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 02: 17 Case 1:22-cv-10904-JSR Document 267-12 Filed 08/07/23 Page 8 of 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STACEY E. PLASKETT Confidential May 09, 2023 220 GOV. OF U.S. vs JPMORGAN CHASE BANK A. Q. A. Q. STACEY PLASKETT -CONFIDENTIAL No. Okay. And that's a lot of money? Yes. So who were your prospects for raising that kind of money? A. Individuals who had donated before, alumni, individuals who were interested in the