Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-23.pdf

EXHIBIT 76 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-23 Filed 08/07/23 Page 1 of 6 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, Civil Action No. -against- 1:22-cv-10019-JSR JP MORGAN CHASE BANK, N.A. Defendants. - - - - - - - - - - - - - - - - - - - - x Highly Confidential-Attorneys Eyes Only Videotaped oral deposition of JUSTIN NELSON, taken pursuant to subpoena, was held BOIES SCHILLER FLEXNER, 55 Hudson Yards,New York, New York commencing April 21, 2023, 9:42 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 263-23 Filed 08/07/23 Page 2 of 6 MAGNA9 LEGAL SERVICES Page 8 1 J. Nelson - Confidential 2 discussion within that meeting that led to 09:45:54 3 the conclusion that Jeffrey Epstein was going 09:45:56 4 to be terminated as a client? 09:45:57 5 A. I don't remember specifics. 09:45:59 6 Q. What was your understanding as to 09:46:00 7 the reason or reasons that Jeffrey Epstein 09:46:02 8 was going to be terminated? 09:46:04 9 A. Reputational risk. 09:46:06 10 Q. By reputational risk, what did that 09:46:08 11 mean in this particular context, that being 09:46:14 12 related to Jeffrey Epstein? 09:46:16 13 MR. BUTTS: Objection to form. 09:46:18 14 You can answer. 09:46:20 15 A. I think we are aware of the history 09:46:21 16 of Jeffrey, Mr. Epstein, I think that's what 09:46:26 17 went into that decision. 09:46:31 18 Q. Do you remember there being a 09:46:32 19 discussion about any specific banking 09:46:36 20 activity in which he was engaged at the time, 09:46:39 21 that being 2013 time period, that also 09:46:42 22 contributed to that decision? 09:46:46 23 MR. BUTTS: Objection to form. 09:46:47 24 You may answer. 09:46:50 25 A. I don't remember. 09:46:50 Case 1:22-cv-10904-JSR Document 263-23 Filed 08/07/23 Page 3 of 6 MAGNA9 LEGAL SERVICES Page 175 1 J. Nelson - Confidential 2 Q. After Jeffrey Epstein has been 13:30:03 3 terminated, you get the permission of John 13:30:04 4 Duffy to continue a relationship with Jeffrey 13:30:10 5 Epstein where he will be a potential source 13:30:13 6 of future referrals? 13:30:15 7 MR. BUTTS: Objection to form. 13:30:17 8 You may answer. 13:30:19 9 A. Yes. 13:30:19 10 Q. Do you remember where you were when 13:30:19 11 you had these discussions with Mr. Duffy? 13:30:21 12 A. I do not. 13:30:23 13 Q. Were you given any parameters of 13:30:24 14 what is okay to do and what is not okay to do 13:30:27 15 with respect to the relationship with Jeffrey 13:30:30 16 Epstein? 13:30:33 17 A. Yes. 13:30:33 18 Q. What were they? 13:30:33 19 A. We would not engage in any type of 13:30:35 20 relationship where Mr. Epstein had control of 13:30:40 21 a relationship, where we had to interface 13:30:43 22 with him directly as a decisionmaker of any 13:30:46 23 kind. 13:30:50 24 Q. At some point in time, even if that 13:30:50 25 was the objective from the beginning to make 13:30:54 Case 1:22-cv-10904-JSR Document 263-23 Filed 08/07/23 Page 4 of 6 MAGNA9 LEGAL SERVICES Page 176 1 J. Nelson - Confidential 2 sure you didn't have to interface with him to 13:30:57 3 get to a client, isn't that what happened 13:31:00 4 with respect to Leon Black? 13:31:03 5 MR. BUTTS: Objection, 13:31:05 6 mischaracterizes testimony. 13:31:07 7 Q. You can answer. 13:31:09 8 A. No because I never interfaced. We 13:31:12 9 spoke to Mr. Epstein, but he was never a 13:31:17 10 signer on an account for anyone else that we 13:31:22 11 interacted with, he was not a decisionmaker. 13:31:25 12 Q. Was there ever a point in time 13:31:30 13 where Leon Black was the client, but you and 13:31:33 14 your team could only speak with Mr. Epstein 13:31:37 15 as opposed to Mr. Black about the client 13:31:41 16 relationship? 13:31:45 17 MR. BUTTS: Objection. 13:31:46 18 You may answer. 13:31:48 19 A. We spoke to Mr. Epstein about 13:31:48 20 things related to Leon Black, but anything 13:31:51 21 that -- to actually do anything with Leon 13:31:56 22 Black had to go through Leon Black or his 13:32:00 23 family office. 13:32:02 24 Q. And Mr. Epstein was not able to be 13:32:03 25 a signatory on Mr. Black's accounts, right? 13:32:10 Case 1:22-cv-10904-JSR Document 263-23 Filed 08/07/23 Page 5 of 6 MAGNA9 LEGAL SERVICES Page 177 1 J. Nelson - Confidential 2 A. Correct. 13:32:13 3 Q. Did there come a point in time 13:32:13 4 where there was a signatory, but Jeffrey 13:32:16 5 Epstein was the person that was making the 13:32:20 6 calls for Mr. Black? 13:32:22 7 MR. BUTTS: Objection to form. 13:32:25 8 You may answer if you are able. 13:32:26 9 A. There were times where Mr. Epstein 13:32:27 10 had a recommendation, but I can't remember 13:32:32 11 any of those things getting done, so, no. 13:32:38 12 Q. How many times do you think you 13:32:43 13 visited Mr. Epstein after he was terminated 13:32:48 14 from JPMorgan? 13:32:52 15 A. Several times. 13:32:54 16 Q. By several, ballpark what do you 13:32:55 17 think we are talking about? 13:33:01 18 A. Eight to 10, in that range. 13:33:02 19 Q. When is the last time that you 13:33:04 20 remember visiting Jeffrey Epstein, what year? 13:33:05 21 A. I don't remember. 13:33:08 22 Q. Did you visit Jeffrey Epstein as 13:33:09 23 late as 2017? 13:33:12 24 A. It is possible. 13:33:14 25 Q. Did you ever spend the night at any 13:33:16 Case 1:22-cv-10904-JSR Document 263-23 Filed 08/07/23 Page 6 of 6 MAGNA9 LEGAL SERVICES