Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-13.pdf

EXHIBIT 66 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-13 Filed 08/07/23 Page 1 of 9 Mary Casey - Confidential, Attorneys' Eyes Only 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 15 FRIDAY, APRIL 7, 2023 16 CONFIDENTIAL - ATTORNEYS' EYES ONLY 17 – – – 18 Videotaped deposition of Mary Casey, held at the offices of Boies Schiller 19 & Flexner, 100 SE 2nd Street, Suite 2800, Miami, Florida, commencing at 9:23 a.m. 20 Eastern, on the above date, before Carrie A. Campbell, Registered Diplomate Reporter, 21 Certified Realtime Reporter, Illinois, California & Texas Certified Shorthand 22 Reporter, Missouri, Kansas, Louisiana & New Jersey Certified Court Reporter. 23 – – – 24 GOLKOW LITIGATION SERVICES 877.370.DEPS 25 deps@golkow.com Case 1:22-cv-10904-JSR Document 263-13 Filed 08/07/23 Page 2 of 9 Mary Casey - Confidential, Attorneys' Eyes Only Golkow Litigation ServicesPage 34 1 Epstein's accounts? 2 MR. BUTTS: Objection. 3 You may answer. 4 THE WITNESS: Escalate 5 concerns? No. 6 QUESTIONS BY MS. LIU: 7 Q. Escalate anything else? 8 A. Yes. 9 Q. What would that be? 10 A. I escalated concerns for 11 reputational risk. I also, in response to a 12 request from compliance -- well, escalated 13 concerns with respect to reputational risk, I 14 would say. 15 Q. And what does that mean? 16 A. I would escalate my concerns 17 for whether -- my concerns around the 18 reputation of the firm and who we were 19 working with at the time. 20 Q. Specifically what concerns did 21 you escalate for reputational risk with 22 respect to Jeffrey Epstein's accounts? 23 A. Post-2006, when there was media 24 reports with respect to his behavior, I would 25 share my concerns with respect to the media Case 1:22-cv-10904-JSR Document 263-13 Filed 08/07/23 Page 3 of 9 Mary Casey - Confidential, Attorneys' Eyes Only Golkow Litigation ServicesPage 93 1 THE WITNESS: I escalated a 2 concern. 3 QUESTIONS BY MS. LIU: 4 Q. And what was your concern? 5 A. My concern was the reputational 6 risk of the client. 7 Q. And that was based on seeing 8 these news reports, correct? 9 A. That is correct. 10 Q. And Mary Erdoes also saw these 11 news reports, correct? 12 She was on the same e-mail from 13 Philip Schlakman to you forwarding the news 14 report, correct? 15 MR. BUTTS: Objection to form. 16 You may answer. 17 THE WITNESS: She was on that 18 e-mail, yes. 19 QUESTIONS BY MS. LIU: 20 Q. Do you know if she was worried, 21 too? 22 A. I do not know. 23 Q. And you were uncertain after 24 seeing those news reports whether you wanted 25 to continue to cover Jeffrey Epstein, Case 1:22-cv-10904-JSR Document 263-13 Filed 08/07/23 Page 4 of 9 Mary Casey - Confidential, Attorneys' Eyes Only Golkow Litigation ServicesPage 117 1 Q. And you wrote those words in 2 April of 2004, correct? 3 A. Correct. 4 Q. "The Epstein/Wexner 5 relationship generated over 8.5 million in 6 revenue in 2003." 7 Do you see that? 8 A. I do. 9 Q. And at the end of that e-mail 10 you say, "Please thank him" -- I believe 11 you're referring to Mr. Indyke -- "for his 12 consistent support to us on such a, quote, 13 crucial relationship to the private bank." 14 Do you see that? 15 A. I do. 16 Q. Does that refresh your 17 recollection that the Epstein/Wexner 18 relationship was generating over 8.5 million 19 in revenue in 2003? 20 A. That refers to the Wexner 21 relationship and the Epstein relationship, 22 yes, combined. 23 Q. And you believe that that 24 relationship was a, quote, crucial 25 relationship to the private bank; is that Case 1:22-cv-10904-JSR Document 263-13 Filed 08/07/23 Page 5 of 9 Mary Casey - Confidential, Attorneys' Eyes Only Golkow Litigation ServicesPage 118 1 fair? 2 A. Mr. Wexner was a crucial 3 relationship to the private bank, yes. 4 Q. And Mr. Epstein? 5 A. Mr. Epstein was the money 6 manager for Mr. Wexner, yes. So, therefore, 7 he was part of an important relationship. 8 Q. And Mr. Epstein had, at one 9 point under you, 72 accounts with over 10 $120 million with the bank, correct? 11 A. I don't know. 12 Q. Mr. Epstein was also a crucial 13 relationship to the bank, correct? 14 A. Those are your words, not mine. 15 Q. I'm asking you. Those are 16 actually your words in this e-mail, 17 Ms. Casey. 18 A. My e-mail refers to Leslie 19 Wexner. 20 Q. The Epstein/Wexner 21 relationship. 22 A. Correct, because Mr. Epstein 23 was the money manager for Mr. Wexner. 24 Q. And the crucial relationship 25 was the Epstein/Wexner relationship, correct? Case 1:22-cv-10904-JSR Document 263-13 Filed 08/07/23 Page 6 of 9 Mary Casey - Confidential, Attorneys' Eyes Only Golkow Litigation ServicesPage 194 1 compliance department that I believe taps 2 into -- again, this is institution 3 organizational structure that I'm -- 4 Q. Okay. So you might be 5 getting -- 6 MR. BUTTS: Hold on. I don't 7 think she finished. 8 Did you finish your answer? 9 THE WITNESS: Yeah. So, I 10 mean, I'm familiar with it in a 11 general way. I can't speak to it with 12 specificity. 13 QUESTIONS BY MS. LIU: 14 Q. Do you recall being involved in 15 a rapid response team meeting for Jeffrey 16 Epstein in October of 2006? 17 A. I don't recall specific 18 meetings, no. 19 Q. Do you know what a rapid 20 response team meeting is? 21 A. So -- yes. 22 Q. What is a rapid response team 23 meeting? 24 A. So a rapid response meeting is 25 the result of -- it's an escalation point Case 1:22-cv-10904-JSR Document 263-13 Filed 08/07/23 Page 7 of 9 Mary Casey - Confidential, Attorneys' Eyes Only Golkow Litigation ServicesPage 195 1 when derogatory information or something of 2 note happens in a given client relationship. 3 Q. And do you recall participating 4 in rapid responses team meetings for any 5 other clients besides Jeffrey Epstein? 6 A. I don't recall specific 7 meetings, no. 8 Q. Would you agree or disagree 9 that it's rare for there to be a rapid 10 response team meeting for a private bank 11 client? 12 A. It is not rare. 13 Q. And do you recall that in total 14 there were four rapid response team meetings 15 related to Jeffrey Epstein? 16 A. I don't know the exact number. 17 Q. Do you have any reason to think 18 that there might have been more than four 19 rapid response team meetings related to 20 Je