Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-08.pdf

EXHIBIT 61 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-8 Filed 08/07/23 Page 1 of 9 Mary Erdoes Golkow Litigation ServicesPage 1 1 UNITED STATES DISTRICT COURT FOR THE 2 SOUTHERN DISTRICT OF NEW YORK 3 ---------------------------------------X 4 Jane Doe 1, individually and on behalf of all others similarly situated, 5 6 Plaintiff, Case No. 1:22-cv-10019 (JSR) 7 v. 8 JPMorgan Chase Bank, N.A., Defendant. 9 --------------------------------------- 10 GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, 11 Case No. 1:22-cv-10904 (JSR) 12 Plaintiff, 13 v. 14 JPMORGAN CHASE BANK, N.A., 15 Defendant 16 ---------------------------------------- 17 ** CONFIDENTIAL PORTION UNDER SEPARATE COVER ** 18 ** DEPOSITION OF MARY ERDOES ** 19 Wednesday, March 15, 2023 20 21 22 23 Reported by: 24 Angela M. Shaw-Crockett, CCR, CRR, RMR Case 1:22-cv-10904-JSR Document 263-8 Filed 08/07/23 Page 2 of 9 Mary Erdoes Golkow Litigation ServicesPage 180 1 A. No. 2 Q. It's not something that you would ever 3 hope anyone at the bank would condone, right? 4 A. Correct. 5 Q. And if the bank was aware or became aware 6 that Jeffrey Epstein was abusing young girls or 7 women, you would recommend that he be terminated as 8 a client at the bank, correct? 9 A. I wasn't -- I wasn't part of those 10 conversations, and there's -- those conversations 11 have lots of facts and circumstances around them. 12 So it would just -- it would depend. 13 Q. I must have asked a bad question. So my 14 question is hypothetically, if you were to learn and 15 believe that Jeffrey Epstein was sexually abusing 16 children and young women, would it be your position 17 that Jeffrey Epstein should be terminated as a 18 client at the bank? 19 A. If I learned and believed that he was 20 sexually abusing young children, yes, he would be -- 21 I would ask to have him exited from the bank. 22 Q. And if you hypothetically learned that 23 Jeffrey Epstein was running a particular type of 24 sexual abuse scheme where he was inviting young Case 1:22-cv-10904-JSR Document 263-8 Filed 08/07/23 Page 3 of 9 Mary Erdoes Golkow Litigation ServicesPage 182 1 hush payments to victims and recruiters and things 2 of that nature, correct? 3 A. Those two things, unfortunately, never 4 came together in my mind. 5 Q. Okay. It's not until right now that we're 6 having this discussion that things are kind of 7 starting to -- the puzzle is coming together? 8 MR. JOHNSON: Objection. 9 You can answer. 10 A. At the time, the concern was the cash 11 payments, and at the time, the cash payments were 12 related to airplane usage. 13 And never at the time was that something 14 that I was connecting in my mind with anything to do 15 with any of the allegations of what he may or may 16 not have done, and I wasn't aware of any ongoing 17 things that Mr. Epstein was doing, and the two 18 things never -- they never came to my mind to 19 connect them. 20 BY MR. EDWARDS: 21 Q. With respect to the cash payments, if you 22 believed that he was withdrawing cash because that's 23 the way -- that's the way it was necessary to make 24 payments for jet fuel, that's not somebody that you Case 1:22-cv-10904-JSR Document 263-8 Filed 08/07/23 Page 4 of 9 Mary Erdoes Golkow Litigation ServicesPage 183 1 would terminate from the bank if you believed that 2 story, right? 3 A. Correct. 4 Q. So he gave an explanation as to why these 5 massive amounts of cash were being withdrawn from 6 the bank, but fair to say it was not a believable 7 explanation, correct? 8 A. I thought the explanation was an outsized 9 amount of cash, and even though that was his 10 explanation for where the cash was being used, that 11 in conjunction with the culmination of everything 12 else and the fact that I didn't know or like 13 Mr. Epstein, I had no reason to vouch for 14 Mr. Epstein to be a client of the bank, and I 15 recommended exit and we exited. 16 Q. Do you believe that just with the analysis 17 that you did in 2013 that you made the right 18 decision, the responsible decision on behalf of the 19 bank, to exit Mr. Epstein as a client? 20 A. I am glad I exited Mr. Epstein from the 21 bank. 22 Q. And when he was exited from the bank, did 23 you learn immediately that he was going to set up 24 new accounts at Deutsche Bank? Case 1:22-cv-10904-JSR Document 263-8 Filed 08/07/23 Page 5 of 9 Mary Erdoes Golkow Litigation ServicesPage 212 1 Q. Do you know what that zone was? 2 A. I don't. I just don't. 3 Q. Do you agree each client's AML risk should 4 be reassessed if material new information or 5 unexpected account activity is identified? 6 A. I believe that generally happens. 7 Q. And do you believe financial institutions 8 must establish criteria for determining when a 9 client relationship poses too high a risk and 10 therefore must be terminated? 11 A. I don't know what -- generally, what you 12 said, yes. 13 Q. With respect to the news articles that 14 were presented to you over the time that you were at 15 JPMorgan, do you remember that allegations against 16 Jeffrey Epstein began as early as March 2005 with an 17 accusation that he paid a 14-year-old girl for a 18 massage? 19 A. I don't remember the specific allegations. 20 Q. Do you remember allegations that the 21 Palm Beach police uncovered dozens of underage 22 victims of sexual abuse? 23 A. I don't -- I don't remember the -- aside 24 from what we just saw earlier, I don't remember what Case 1:22-cv-10904-JSR Document 263-8 Filed 08/07/23 Page 6 of 9 Mary Erdoes Golkow Litigation ServicesPage 213 1 the specifics were. 2 Q. When you were hearing the allegations over 3 time, let's say -- do you remember when 4 Jeffrey Epstein was first arrested in 2006? 5 A. Yes. 6 Q. And because of the nature of the charges, 7 that it's allegedly sex with minors, that's a big 8 deal, right, for a client? 9 A. Any allegation is taken very seriously. 10 Q. But if it's an allegation of trespassing, 11 it's taken less seriously than sex with a minor? 12 A. I can't judge the seriousness with which 13 they take it. 14 Q. Okay. Did you speak with Jes Staley in 15 the 2006 time period about the fact that 16 Jeffrey Epstein had been arrested? 17 A. I remember Jes discussing that -- I sort 18 of don't know where or when -- that his 19 characterization of Jeffrey was very different than 20 the press situation. And -- yeah, that's what I 21 remember. 22 Q. Did you know that Jes was going to visit 23 Jeffrey at various houses of his? 24 A. So I remember the email that I think we Case 1:22-cv-10904-JSR Document 263-8 Filed 08/07/23 Page 7 of 9 Mary Erdoes Golkow Litigation ServicesPage 302 1 BY MR. NARWOLD: 2 Q. This is a series of emails between you and 3 Mr. Duffy, and this is just about the time you were 4 exiting Mr. Epstein, correct? 5 A. Yes. Sorry. I'm just reading through it 6 first here. 7 Q. Yep. 8 A. Okay. 9 Q. If you look at the bottom email on the 10 first page, it's from Mr. Duffy to you. It says "Re 11 JE." 12 And can you tell, from the content of this 13 email, this is Mr. Epstein? 14 A. It was around the time that we were 15 exiting Mr. Epstein, so might be, yes. 16 Q. You see the sentence talking about the 17 impact of his cash activities? 18 A. Yes. 19 Q. The second paragraph says: 20