Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-68.pdf

EXHIBIT 121 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-68 Filed 08/07/23 Page 1 of 4 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-10018-JSR DEUTSCHE BANK AKTEINGESELLSCHAFT, et al., Defendants. - - - - - - - - - - - - - - - - - - - - x 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 C O N F I D E N T I A L Videotaped oral deposition of PAUL MORRIS, taken pursuant to subpoena, was held REMOTELY, commencing April 18, 2023, 9:00 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 Case 1:22-cv-10904-JSR Document 263-68 Filed 08/07/23 Page 2 of 4 MAGNA9 LEGAL SERVICES Page 337 1 P. Morris - Confidential 2 and questions about that. And I recall our 19:14:44 3 CEO spoke to Epstein and, you know, got 19:14:52 4 answers on that. 19:14:58 5 Q. Do you remember what Jeffrey 19:15:00 6 Epstein's answers were for the cash 19:15:01 7 withdrawals in 2012 from Hyperion Air? 19:15:05 8 A. I believe they were for -- his 19:15:11 9 answer was they were for fuel. 19:15:16 10 Q. Did you ever attempt to determine 19:15:18 11 whether the cash was actually used for the 19:15:22 12 payment of fuel? 19:15:31 13 MR. BOUCHOUX: Objection to form. 19:15:36 14 A. I did not. 19:15:38 15 Q. Did it ever concern you that 19:15:41 16 perhaps the cash was being withdrawn for the 19:15:47 17 payment related to sexual abuse or sex 19:15:51 18 trafficking? 19:15:55 19 MR. BOUCHOUX: Objection to form. 19:15:56 20 A. It never occurred to me that that's 19:16:00 21 what was happening. 19:16:02 22 Q. To your knowledge, did anyone 19:16:05 23 around you at JP Morgan ever indicate that 19:16:07 24 they suspected that the cash withdrawals were 19:16:11 25 being used or could be used for sexual abuse 19:16:17 Case 1:22-cv-10904-JSR Document 263-68 Filed 08/07/23 Page 3 of 4 MAGNA9 LEGAL SERVICES Page 338 1 P. Morris - Confidential 2 or sex trafficking? 19:16:20 3 MR. BOUCHOUX: Objection to form. 19:16:23 4 A. Absolutely not, never heard that. 19:16:25 5 Q. Same question at Deutsche Bank, did 19:16:28 6 anyone around you ever suggest that the cash 19:16:34 7 withdrawal activity from Jeffrey Epstein's 19:16:39 8 accounts was potentially being used by him to 19:16:42 9 sexually abuse or sex traffic? 19:16:48 10 A. Absolutely not, I never heard that. 19:16:52 11 Q. Do you recall from time to time at 19:17:01 12 JP Morgan being sent negative news articles 19:17:04 13 about Jeffrey Epstein connected to human 19:17:07 14 trafficking? 19:17:09 15 MS. BEBCHICK: Objection. 19:17:12 16 A. I recall getting the negative news 19:17:15 17 stories from time to time, but I don't recall 19:17:20 18 them being about trafficking. 19:17:24 19 Q. Did you ever speak with Steven 19:17:47 20 Cutler about Jeffrey Epstein? 19:17:51 21 A. No, never spoke to him. 19:17:52 22 Q. Did you ever attend any rapid 19:18:02 23 response meeting that was called as a 19:18:06 24 consequence of any negative news articles 19:18:08 25 related to Jeffrey Epstein? 19:18:12 Case 1:22-cv-10904-JSR Document 263-68 Filed 08/07/23 Page 4 of 4 MAGNA9 LEGAL SERVICES