Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/326-15.pdf

EXHIBIT 15 Case 1:22-cv-10904-JSR Document 326-15 Filed 09/08/23 Page 1 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 1 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 - - - 16 July 13, 2023 - - - 17 Videotaped deposition of 18 JOHN R. DUFFY, taken pursuant to notice, was held at Wilmer Hale, Seven World 19 Trade Center, New York, New York, beginning at 9:17 a.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 326-15 Filed 09/08/23 Page 2 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 21 1 A. Personal relationship, as -- 2 as you are posing the question, to me, 3 feels like something beyond business. 4 And rapport is an 5 understanding and a dialogue that flows 6 freely where you understand that person, 7 they understand you, and it helps in 8 business to be well understood and to 9 understand the person you're trying to 10 serve. 11 Q. Did you have any personal 12 relationships with any of your clients 13 at -- while you were at JPMorgan? 14 A. I had rapport with many 15 clients. 16 Q. Did you have any personal 17 relationships with them? 18 A. I would -- I'd probably say 19 I don't have relationships that I would 20 have called personal. I think all was 21 business. 22 Q. Did you ever have a social 23 dinner with a client? 24 A. Not that I can think of. Case 1:22-cv-10904-JSR Document 326-15 Filed 09/08/23 Page 3 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 62 1 anybody else? 2 A. Not that I recall. 3 Jes was the senior person on 4 that relationship, and for me, that was 5 the right person to raise that with. 6 Q. What do you mean "senior 7 person on that relationship"? 8 A. Jes was involved with, to my 9 knowledge, Mr. Epstein's relationship 10 with JPMorgan right from the very 11 beginning, whenever that was. 12 And to my knowledge, it 13 continued after he was outside of the 14 Private Bank. And Jes kept in touch with 15 many clients in the Private Bank, post 16 his days in the Private Bank. 17 Q. Do you know whether Jes had 18 a formal role in approving Mr. Epstein's 19 retention by the bank as a client when he 20 was in charge of the Private Bank? 21 MR. JOHNSON: Objection. 22 THE WITNESS: Sorry, can you 23 say that again. 24 BY MR. SCHIFFMANN: Case 1:22-cv-10904-JSR Document 326-15 Filed 09/08/23 Page 4 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 63 1 Q. Sure. 2 As far as you know, did 3 Mr. Staley have any formal role in 4 deciding whether Mr. Epstein should 5 remain a client of the Private Bank while 6 he was in charge of the investment bank? 7 MR. JOHNSON: Objection. 8 THE WITNESS: As a senior 9 member of the firm and a member of 10 the operating committee, who 11 continued to work on that account 12 in some way or fashion, some of it 13 visible to me, some of it not 14 visible to me, Jes was a part of 15 that relationship. And I would 16 have expected, if there was 17 something that I should have 18 known, he would have told me. 19 We relied upon Jes, in this 20 instance and in -- and in others, 21 as it related to his judgment 22 about an account. And in this 23 case we're talking about 24 Mr. Epstein's account. Case 1:22-cv-10904-JSR Document 326-15 Filed 09/08/23 Page 5 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 64 1 BY MR. SCHIFFMANN: 2 Q. And you say "we." Who do 3 you mean by "we"? 4 A. Broadly speaking, the 5 Private Bank. Coverage team, CEO of the 6 asset and wealth management business, 7 myself. 8 Q. There were other people also 9 responsible for the relationship with 10 Mr. Epstein, right? 11 A. Oh, for sure. There are 12 people who are doing the work, day in and 13 day out. 14 Q. So at most, Mr. Staley was 15 part of a broader team that was in charge 16 of deciding whether Mr. Epstein should 17 remain a client? 18 A. Most senior member, 19 operating committee member. Little bit 20 different than everybody else on the 21 team. 22 Q. What do you mean by that? 23 A. Most senior person and, you 24 know, a person who you look up to, to Case 1:22-cv-10904-JSR Document 326-15 Filed 09/08/23 Page 6 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 65 1 hold up the code of conduct of the firm, 2 and fiduciary responsibility to clients 3 and shareholders. 4 Q. Do you think other members 5 of the team also had an obligation to 6 uphold the code of conduct? 7 A. Well, everyone does. 8 Q. Do you think other members 9 of that team also had a fiduciary 10 responsibility to clients and 11 shareholders? 12 A. Yes, I do. 13 Q. And as you said, those other 14 members of the team were doing the work, 15 day in and day out, right? 16 A. Yes. 17 Q. And those other members of 18 the team were closer to Mr. Epstein's 19 actual account activity, right? 20 A. Yes. 21 Q. And you'd agree that those 22 other members of the team also had an 23 important role in the decision of whether 24 Mr. Epstein should remain a client? Case 1:22-cv-10904-JSR Document 326-15 Filed 09/08/23 Page 7 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 67 1 time frame, situation. 2 It's just not that cut and 3 dry. It was a heavy influence. 4 Q. What was the basis for that 5 influence? 6 A. Seniority, history with the 7 client. 8 Q. Going to your next 9 conversation with Mr. Staley about 10 Mr. Epstein, I think you testified that 11 in -- you had another conversation with 12 him in 2011 after you became CEO of the 13 investment bank? 14 A. Of the Private Bank. 15 Q. Yes, sorry, Private Bank. 16 A. Yes, that's correct. 17 Q. And do you remember how long 18 after your elevation to CEO of the 19 Private Bank you had that conversation? 20 A. Yeah. It was pretty quickly 21 after. Weeks. 22 Q. And where was that 23 conversation? 24 A. In his office at the Case 1:22-cv-10904-JSR Document 326-15 Filed 09/08/23 Page 8 of 42 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 68 1 investment bank, arranged by his 2 assistant. 3 Q. Did he arrange that meeting 4 or did you? 5