Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/238-21.pdf

EXHIBIT 46 Case 1:22-cv-10904-JSR Document 238-21 Filed 07/25/23 Page 1 of 42 Confidential - Pursuant to Protective Order Golkow Litigation Services Page 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 238-21 Filed 07/25/23 Page 2 of 42 Confidential - Pursuant to Protective Order Golkow Litigation Services Page 17 1 QUESTIONS BY MS. LIU: 2 Q. Mr. Staley, on or about the end 3 of July 2006, after Jeffrey Epstein was 4 indicted on child sex offenses, did you speak 5 with Mr. Dimon about the fact that 6 Mr. Epstein had been indicted? 7 A. My recollection is yes. 8 Q. And how soon after the 9 indictment do you recall speaking to 10 Mr. Dimon? 11 A. I don't recall. 12 Q. And what was the context in 13 which you would have spoken to Mr. Dimon 14 about Jeffrey Epstein's indictment? 15 A. I don't recall the exact 16 conversation. 17 Q. And to the extent this was July 18 of 2006, at that time you were the head of 19 asset and wealth management and you reported 20 directly to Mr. Dimon, correct? 21 A. That's correct. 22 Q. Do you recall if you were 23 bringing this information to his attention 24 because he was your boss? 25 A. Yes. Case 1:22-cv-10904-JSR Document 238-21 Filed 07/25/23 Page 3 of 42 Confidential - Pursuant to Protective Order Golkow Litigation Services Page 18 1 Q. Do you recall if there was 2 anyone else present during your conversation 3 with Mr. Dimon? 4 A. No. 5 Q. Do you recall where the 6 conversation took place? 7 A. No. 8 Q. Where was your office at that 9 time in 2006? 10 A. It was in one of two buildings. 11 There was a building across the street from 12 the bank headquarters, and then there was 13 another building that was about four blocks 14 away. I'm not sure which building I was in 15 at that time. 16 Q. And do you recall if you sat in 17 the same building as Mr. Dimon at that time? 18 A. In 2006? 19 Q. Yes. 20 A. I don't believe so. 21 Q. Do you recall if the 22 conversation took place in person or by 23 phone? 24 A. My recollection is it was by 25 phone. Case 1:22-cv-10904-JSR Document 238-21 Filed 07/25/23 Page 4 of 42 Confidential - Pursuant to Protective Order Golkow Litigation Services Page 19 1 Q. And what, if anything, do you 2 recall about that conversation? 3 A. Just to let Jamie know that a 4 client of the bank had been indicted. 5 Q. And do you recall if at that 6 time when you were letting Jamie Dimon know 7 that Jeffrey Epstein had been indicted, if 8 Mr. Dimon already knew who Jeffrey Epstein 9 was? 10 A. I don't recall. 11 Q. Why was it that you would have 12 raised this information with Mr. Dimon 13 following Mr. Epstein's indictment? 14 A. Epstein was a client of the 15 bank. It was a -- and the indictment was a 16 very public event. 17 Q. Do you recall if at the time 18 you raised Jeffrey Epstein's indictment with 19 Mr. Dimon that he had already heard about it 20 in the news? 21 A. I don't recall. 22 Q. And do you recall anything 23 about Mr. Dimon's response to your sharing 24 the information about Jeffrey Epstein's 25 indictment? Case 1:22-cv-10904-JSR Document 238-21 Filed 07/25/23 Page 5 of 42 Confidential - Pursuant to Protective Order Golkow Litigation Services Page 45 1 wealth management, she had conversations with 2 Mr. Dimon about Jeffrey Epstein? 3 A. I would imagine so. 4 MR. GAIL: Objection. 5 QUESTIONS BY MS. LIU: 6 Q. Okay. You would imagine so, 7 but you're not aware of any actual 8 conversation; is that fair? 9 A. That's fair. 10 Q. So your testimony is that given 11 her role as the head of asset and wealth 12 management, you would have expected, as you 13 had done, that she would have reported or 14 talked to Mr. Dimon about the problems with 15 Mr. Epstein; is that fair? 16 A. That's what I would expect, 17 yes. 18 Q. Is it the case that Sandy 19 Warner had interactions with Mr. Epstein? 20 A. I believe so. 21 Q. And tell me about that. 22 MR. GAIL: Objection. 23 THE WITNESS: Sandy Warner was 24 the individual who asked that I meet 25 with Epstein, and my recollection, it Case 1:22-cv-10904-JSR Document 238-21 Filed 07/25/23 Page 6 of 42 Confidential - Pursuant to Protective Order Golkow Litigation Services Page 46 1 was following a meeting that Sandy 2 Warner had with Jeffrey Epstein. 3 QUESTIONS BY MS. LIU: 4 Q. And was that in or about the 5 2000 time period? 6 A. Yes. 7 Q. And that -- and during that 8 time period, Mr. Warner was the CEO of 9 JPMorgan, correct? 10 A. That's correct. 11 Q. And you knew Mr. Warner because 12 you worked at JPMorgan; is that fair? 13 A. That's correct. 14 Q. And tell me what you recall 15 about Mr. Warner asking you to meet with 16 Jeffrey Epstein. 17 A. Sandy Warner had met with 18 Epstein, he said, and recently he also had 19 made me head of the private bank. 20 And Sandy said, you should meet 21 Epstein. He's one of the most connected 22 people I know of in New York. 23 Q. And you did meet with 24 Mr. Epstein at that time? 25 A. Yes. Case 1:22-cv-10904-JSR Document 238-21 Filed 07/25/23 Page 7 of 42 Confidential - Pursuant to Protective Order Golkow Litigation Services Page 47 1 Q. And do you recall if you ever 2 reported back to Mr. Warner, I met with 3 Mr. Epstein? 4 A. I would imagine I did, yes. 5 Q. And Mr. Epstein became a client 6 of the private bank at the time? 7 A. No, he was a client already. 8 He was a client before I met him. 9 Q. And who had the direct client 10 relationship with Jeffrey Epstein at the time 11 you met him? 12 A. I don't know. 13 Q. Did you ultimately take over 14 the client relationship with Mr. Epstein on 15 or about that 2000 time period? 16 A. No, I did not. 17 Q. What was your professional 18 rela