Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/326-125.pdf

EXHIBIT 125 Case 1:22-cv-10904-JSR Document 326-125 Filed 09/08/23 Page 1 of 5 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 472 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 2 GOVERNMENT OF THE : 3 UNITED STATES VIRGIN : ISLANDS, : CASE NO. 4 : 1:22-CV-10904 Plaintiff, : -JSR 5 : v. : 6 : JPMORGAN CHASE BANK, : 7 N.A., : : 8 Defendant/Third Party : Plaintiff. : 9 ______________________ : JPMORGAN CHASE BANK, : 10 N.A., : : 11 Third Party Plaintiff, : : 12 v. : : 13 JAMES EDWARD STALEY, : : 14 Third Party Defendant. : 15 CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER VOLUME II 16 - - - July 6, 2023 17 - - - 18 Continued videotaped deposition of MARY CASEY, taken pursuant to notice, was 19 held remotely via Zoom Videoconference beginning at 2:07 p.m., on the above 20 date, before Michelle L. Gray, a Registered Professional Reporter, 21 Certified Shorthand Reporter, Certified Realtime Reporter, and Notary Public. 22 GOLKOW LITIGATION SERVICES 23 877.370.3377 ph | 917.591.5672 fax deps@golkow.com 24 Case 1:22-cv-10904-JSR Document 326-125 Filed 09/08/23 Page 2 of 5 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 541 1 that way? 2 A. She wasn't comfortable with 3 him. 4 Q. Because of the conviction in 5 Florida? 6 A. Correct. 7 Q. Did you ever ask her why she 8 continued to approve his due diligence 9 reports? 10 A. No. But I -- so I didn't 11 ask her specifically why she would 12 approve them. But, again, as I had taken 13 the reasonable steps as part of the same 14 policy, she's subject to the same policy. 15 She would also be taking reasonable steps 16 to be comfortable with the sponsorships, 17 since she's signing it as well. Those 18 reasonable steps would include 19 conversations, particularly with 20 Mr. Staley, who knew Mr. Epstein best. 21 Q. But, again, all you can 22 remember Mr. Staley saying to you, at 23 least, was that he felt Mr. Epstein 24 should remain a client of the Private Case 1:22-cv-10904-JSR Document 326-125 Filed 09/08/23 Page 3 of 5 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 559 1 They were part of what would bring the 2 due diligence reports together. So they 3 were part of the due diligence process. 4 I don't know about, when you 5 say "discuss," I'm not sure if you mean 6 discuss, like, we did have meetings about 7 him, et cetera. 8 Q. So when you are -- I'm just 9 speaking now about -- 10 A. Yeah. 11 Q. -- the due diligence that 12 you did to form the judgment that the 13 appropriate thing to do with respect to 14 Mr. Epstein is to approve his due 15 diligence report. 16 A. Mm-hmm. 17 Q. Did you discuss that issue 18 with the compliance group? 19 A. So in our -- part of how I 20 formed my reasonable judgment to approve 21 the DDRs as part of the sponsorship 22 policy, I would call upon or, if you 23 will, part of my diligence was escalating 24 and participating in brisk discussions Case 1:22-cv-10904-JSR Document 326-125 Filed 09/08/23 Page 4 of 5 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 560 1 with senior management, compliance 2 included in that, about his relationship 3 with the firm. That was part of what I 4 consider reasonable steps to then be able 5 to approve a DDR, based on the 6 sponsorship policy. 7 Q. And aside from compliance 8 and legal, who else are you including in 9 your definition of senior management? 10 A. So my definition of senior 11 management would be both my chain of 12 management, if you will, my boss up to 13 the head of the Private Bank. And it 14 would also include Mr. Staley, who 15 sometimes was my direct line and 16 sometimes was not, when he moved to the 17 investment bank. But he would be part of 18 those discussions as well and part of the 19 diligence I would do. 20 Q. And when you say -- I forget 21 whether you used -- I think the word 22 "direct line" -- 23 A. Yes. 24 Q. You used direct line. Case 1:22-cv-10904-JSR Document 326-125 Filed 09/08/23 Page 5 of 5