Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-17.pdf

EXHIBIT 70 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-17 Filed 08/07/23 Page 1 of 3 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 1 1 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 2 GOVERNMENT OF THE UNITED ) 3 STATES VIRGIN ISLANDS ) ) 4 Plaintiff, ) ) 5 vs. ) 1:22-cv-10904-JSR ) 6 JPMORGAN CHASE BANK, N.A., ) ) 7 Defendant/Third- ) Party Plaintiff. ) 8 _________________________ ) JPMORGAN CHASE BANK, N.A. ) 9 ) Third-Party ) 10 Plaintiff, ) ) 11 vs. ) ) 12 JAMES EDWARD STALEY, ) ) 13 Third-Party ) Defendant. ) 14 SATURDAY, JUNE 10, 2023 15 CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER 16 **CONFIDENTIAL BSA PORTIONS UNDER SEPARATE COVER** 17 – – – 18 Videotaped deposition of James E. Staley, held at the offices of Boies Schiller 19 Flexner, LLC, 55 Hudson Yards, New York, New York, commencing at 9:13 a.m. Eastern, on the 20 above date, before Carrie A. Campbell, Registered Diplomate Reporter and Certified 21 Realtime Reporter. 22 23 – – – 24 GOLKOW LITIGATION SERVICES 877.370.3377 ph | 917.591.5672 fax 25 deps@golkow.com Case 1:22-cv-10904-JSR Document 263-17 Filed 08/07/23 Page 2 of 3 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 386 1 don't know. 2 Q. Irrespective of your 3 involvement with his accounts, the fact that 4 he had his accounts and the size of his 5 accounts at JPMorgan benefitted JPMorgan. 6 You would agree, right? 7 A. I think no -- you know, I don't 8 think any single client is that important, 9 but he was a client of the bank. 10 Q. And he continued to refer 11 clients to JPMorgan before, during and after 12 his incarceration, correct? 13 MR. GAIL: Objection. 14 THE WITNESS: I don't think he 15 referred clients to the bank. I met 16 clients through him, but I don't think 17 he was making a referral. 18 QUESTIONS BY MR. EDWARDS: 19 Q. Do you know who Thomas McGraw 20 is? 21 A. No. 22 Q. Do you remember a Tom McGraw in 23 the tax department of JPMorgan? 24 A. I don't. 25 Q. Did you ever become aware of Case 1:22-cv-10904-JSR Document 263-17 Filed 08/07/23 Page 3 of 3