Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-02.pdf

EXHIBIT 55 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-2 Filed 08/07/23 Page 1 of 7 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 FRIDAY, MAY 26, 2023 15 CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER 16 **CONFIDENTIAL BSA PORTIONS UNDER SEPARATE COVER** 17 – – – 18 Videotaped deposition of James Dimon, held at the offices of JPMorgan Chase, 19 383 Madison Avenue, New York, New York, commencing at 9:02 a.m. Eastern, on the above 20 date, before Carrie A. Campbell, Registered Diplomate Reporter and Certified Realtime 21 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 263-2 Filed 08/07/23 Page 2 of 7 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 11 1 DIRECT EXAMINATION 2 QUESTIONS BY MR. SULLIVAN: 3 Q. Good morning, sir. My name is 4 Brendan Sullivan, counsel for Jes Staley, and 5 I'll begin the questioning today. 6 First off, I want you to focus 7 on the year 2006. Mr. Epstein was indicted 8 in Florida in the summer of 2006. 9 Were you informed of that 10 indictment by personnel in the bank? 11 A. I do not believe I was. 12 Q. Did you speak with Jes Staley 13 about the fact that Mr. Epstein had been 14 indicted? 15 A. I did not. 16 Q. Did you receive a report from 17 Jes Staley that he had visited with 18 Mr. Epstein the day or so after the 19 indictment? 20 A. I did not. 21 Q. Did Mr. Staley inform you what 22 Mr. Epstein said with respect to the 23 indictment which had been returned a day or 24 two before? 25 A. Nope. Case 1:22-cv-10904-JSR Document 263-2 Filed 08/07/23 Page 3 of 7 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 12 1 Q. Did you speak with Mr. Staley 2 at all in the year 2006 about Mr. Epstein? 3 A. I don't recall ever having a 4 conversation with him about Jeff Epstein. 5 Q. Do you -- strike that. 6 During the year 2006, did you 7 speak at any time with Mary Erdoes about the 8 Epstein indictment and whether or not he 9 should continue as a customer of the bank? 10 A. Nope. 11 Q. During the year 2006, did you 12 speak with general counsel Steve Cutler with 13 respect to Mr. Epstein having been indicted 14 and whether he should remain a customer of 15 the bank? 16 MR. BUTTS: Objection. 17 And I'll instruct you -- you 18 may answer the question yes or no, and 19 we'll take it from there. 20 THE WITNESS: No. 21 QUESTIONS BY MR. SULLIVAN: 22 Q. Were you aware of the fact that 23 Mr. Epstein had been indicted, through any 24 source other than bank personnel, in the year 25 2006? Case 1:22-cv-10904-JSR Document 263-2 Filed 08/07/23 Page 4 of 7 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 57 1 Q. And therefore -- well, did you 2 ever have a conversation with him on the 3 telephone? 4 A. No. 5 (Discussion off the record.) 6 Q. I would like to focus you, sir, 7 on the transaction known as Highbridge. 8 Do you remember what year that 9 arose? 10 A. I don't recall the specific 11 year, no. 12 Q. Well, what is Highbridge? 13 A. It was a hedge fund. A money 14 manager. 15 Q. And how was it it came to be 16 acquired by the bank? 17 A. Jes Staley was running asset 18 management, and he brought it to our 19 attention. He wanted to acquire it. 20 Q. And a decision was made to 21 acquire it? 22 A. After review, yes. 23 Q. And what was it -- did it turn 24 out to be a good decision, productive for the 25 bank? Case 1:22-cv-10904-JSR Document 263-2 Filed 08/07/23 Page 5 of 7 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 58 1 A. Not really. 2 Q. Was Jeffrey Epstein involved in 3 the transaction at all? 4 A. I don't recall any involvement 5 on his part. Back then. 6 Q. Were you informed that Jeffrey 7 Epstein received a $15 million fee for his 8 work in connection with that transaction? 9 MR. BUTTS: Again, at the time? 10 MR. SULLIVAN: Yes, at the 11 time. 12 THE WITNESS: No. 13 QUESTIONS BY MR. SULLIVAN: 14 Q. And I don't mean by -- paid by 15 the bank. Paid by -- 16 A. No. 17 Q. Have you, sir, at any time 18 spoken with regulators in the UK about 19 Mr. Staley? 20 A. Regulators? I don't believe 21 so. 22 Q. Now, there came a time -- sir, 23 have you spoken to any official of Barclays 24 Bank about Jes Staley? 25 A. Yes. Case 1:22-cv-10904-JSR Document 263-2 Filed 08/07/23 Page 6 of 7 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 253 1 A. I don't think Jeff Epstein ever 2 arranged for me to meet with anybody, to my 3 knowledge. And I knew Ehud Barak. We did 4 not need introductions to anybody. 5 (Dimon Exhibit 113 marked for 6 identification.) 7 QUESTIONS BY MR. BOIES: 8 Q. Let me ask you to look at a 9 document that has been previously marked as 10 Exhibit 113. 11 This is a series of e-mails. 12 The one at the bottom, January 23, 2008, at 13 12:44 p.m., says, "Hello Rosa, I think 14 may have already e-mailed you, but wanted to 15 follow up just in case. Jeffrey was talking 16 to me on the phone and to who was 17 standing with him at the same time, so not 18 sure which one of us was actually to e-mail 19 you. Jeffrey requested that we give you the 20 contact e-mail for Ehud Barak so that you 21 could organize the meeting with Jamie Dimon 22 and Barak on your end for simplification." 23 And then Rosa writes to Jes 24 Staley, "Jes, is it okay for me to contact 25 Ehud Barak directly to arrange a meeting with Case 1:22-cv-10904-JSR Document 263-2 Filed 08/07/23 Page 7 of 7 - -