Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/326-151.pdf

EXHIBIT 151 Case 1:22-cv-10904-JSR Document 326-151 Filed 09/08/23 Page 1 of 17 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x JANE DOE 1, individually and on behalf of all others similarly situated, Plaintiff, Case No. -against- 1:22-cv-10019-JSR JPMORGAN Chase BANK NA, Defendants. - - - - - - - - - - - - - - - - - - - - x C O N F I D E N T I A L Videotaped oral deposition of MARYANNE RYAN taken pursuant to notice, was held at BOIES SCHILLER FLEXNER LLP, commencing May 24, 2023, 9:39 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES (866) 624-6221 www.MagnaLS.com Case 1:22-cv-10904-JSR Document 326-151 Filed 09/08/23 Page 2 of 17 MAGNA9 LEGAL SERVICES Page 70 1 M. Ryan - Confidential 12 Q. It was your understanding at that 11:23:01 13 time that Jeffrey Epstein was not using any 11:23:03 14 bank accounts or wire services in his 11:23:06 15 exploitation of women or children? 11:23:11 16 MR. KRAUSE: Objection. 11:23:14 17 A. If I had thought, I would have 11:23:16 18 acted on it. 11:23:18 19 Q. When Phil says, I hope -- sorry, he 11:23:19 20 doesn't say I -- he says, Hope that they do 11:23:28 21 not cave. 11:23:32 22 What did you understand that to 11:23:32 23 mean? 11:23:34 24 A. We were presenting to the business 11:23:37 25 to tee it back up again to make a decision on 11:23:41 Case 1:22-cv-10904-JSR Document 326-151 Filed 09/08/23 Page 3 of 17 I ■ - I -- I ■ -- I - I - I - I - I - ■ - ■ ■ -- MAGNA9 LEGAL SERVICES Page 71 1 M. Ryan - Confidential 2 retention. So Phil was of the mindset, as 11:23:44 3 was I, that he had to go. 11:23:49 4 Q. Why did you think he had to go? 11:23:52 5 A. He was a reputational risk to the 11:23:57 6 bank. 11:24:00 7 Q. Why was it a reputational risk to 11:24:01 8 the bank? 11:24:04 9 A. Any client that would be 11:24:05 10 consistently in the news for any variety of 11:24:10 11 reasons would present reputational risk to 11:24:15 12 the bank. 11:24:18 13 Q. But in this particular instance, 11:24:18 14 what was the reputational risk to the bank? 11:24:20 15 A. There were allegations and there 11:24:23 16 was a conviction about improper behavior with 11:24:25 17 a minor. 11:24:30 18 Q. And at that time you believed those 11:24:35 19 allegations? 11:24:39 20 MR. KRAUSE: Objection. 11:24:41 21 A. I had no firsthand knowledge. I 11:24:45 22 was reading what I read in the paper, and I 11:24:47 23 thought it was disturbing enough that the 11:24:50 24 customer should be re-reviewed for exit 11:24:53 25 determination by JPMorgan. 11:24:57 Case 1:22-cv-10904-JSR Document 326-151 Filed 09/08/23 Page 4 of 17 MAGNA9 LEGAL SERVICES Page 129 1 M. Ryan - Confidential 2 know what -- I didn't know what Cutler knew 13:26:08 3 or didn't know about the bank's HT work. 13:26:10 4 Q. I'm just trying to understand why 13:26:16 5 you think Steve Cutler may feel differently, 13:26:21 10 MR. KRAUSE: Objection. Asked and 13:26:37 11 answered. 13:26:39 12 A. We were trying to get him out on 13:26:39 13 reputational risk reasons. Marrying together 13:26:44 14 the current work that the department was 13:26:49 15 doing, coupled with his old approval would 13:26:54 16 have given him a complete picture to 13:26:57 17 reapprove or relook at whether or not he was 13:27:00 18 still comfortable. 13:27:02 19 Q. You then write, I circled back with 13:27:04 20 PB and that was the reason for the RR meeting 13:27:07 21 on Friday. Seems -- no, let's stop there. 13:27:12 22 I will restate that. You write, I 13:27:19 23 circled back with PB and that was the reason 13:27:21 24 for the RR meeting on Friday. 13:27:23 25 Do you see that? 13:27:26 Case 1:22-cv-10904-JSR Document 326-151 Filed 09/08/23 Page 5 of 17 I I I I - - - - - MAGNA9 LEGAL SERVICES Page 133 1 M. Ryan - Confidential 2 that if it were up to them, they would have 13:31:13 3 terminated their relationship with Jeffrey 13:31:16 4 Epstein? 13:31:19 5 MR. WOHLGEMUTH: Objection. 13:31:19 6 A. I don't recall anything specific 13:31:21 7 said. 13:31:24 8 Q. You then write, Digging will take a 13:31:35 9 few days, I will get back to you when I am 13:31:38 10 done. The guy likes cash so the paper trail 13:31:40 11 could be hard. 13:31:48 12 Do you see that? 13:31:50 13 A. I do. 13:31:50 14 Q. What did you mean when you said, 13:31:50 15 the guy likes cash so the paper trail could 13:31:53 16 be hard? 13:31:56 17 A. As I recall, there were not credit 13:32:01 18 cards activity so I couldn't place people in 13:32:10 19 places at a certain time which is something 13:32:16 20 we might look at credit card data for because 13:32:18 21 paid -- he took out a lot of cash. 13:32:22 Case 1:22-cv-10904-JSR Document 326-151 Filed 09/08/23 Page 6 of 17 ■ ■ ■ ■ ■ ■ - - - - MAGNA9 LEGAL SERVICES Page 134 1 M. Ryan - Confidential 11 MR. LAW: This will be Exhibit 10, 13:33:41 12 Bates number JPM-SDNYLIT-W-00021929. 13:33:43 13 (Ryan Exhibit 10, Email Chain, 13:33:54 14 marked for identification.) 13:33:54 15 THE WITNESS: Okay. 13:34:59 Case 1:22-cv-10904-JSR Document 326-151 Filed 09/08/23 Page 7 of 17 I ■ - I - I -- I - I ■ - I - I - I - ■ - ■ ■ - ■ - ■ - ■ -- ■ ■ -- ■ ■ - ■ - ■ - ■ -- ■ ■ - MAGNA9 LEGAL SERVICES Page 139 1 M. Ryan - Confidential 19 MR. LAW: This is Exhibit 11, Bates 13:43:13 20 number JPM-SDNYLIT-00194154. 13:43:16 21 (Ryan Exhibit 11, Email, marked for 13:43:24 22 identification.)