Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-63.pdf

EXHIBIT 116 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-63 Filed 08/07/23 Page 1 of 7 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x JANE DOE 1, individually and on behalf of all others similarly situated, Plaintiff, Case No. -against- 1:22-cv-10019-JSR JPMORGAN Chase BANK NA, Defendants. - - - - - - - - - - - - - - - - - - - - x UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------------------x GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff Vs. JPMORGAN CHASE BANK, N.A. ---------------------------------------x C O N F I D E N T I A L Videotaped oral deposition of FRANCIS PEARN taken pursuant to notice, was held at BOIES SCHILLER FLEXNER LLP, commencing May 30, 2023, 9:34 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES (866) 624-6221 Case 1:22-cv-10904-JSR Document 263-63 Filed 08/07/23 Page 2 of 7 MAGNA9 LEGAL SERVICES Page 105 1 F Pearn - Attorneys' Eyes Only 2 11:42:39 3 11:42:41 4 11:42:41 5 11:42:44 6 11:42:47 7 11:42:48 8 11:42:51 9 11:42:58 10 11:43:02 11 11:43:11 12 11:43:15 13 11:43:19 14 11:43:22 15 11:43:26 16 11:43:31 17 11:43:34 18 11:43:36 19 11:43:40 20 11:43:47 21 11:43:51 22 11:43:55 23 11:43:56 24 11:43:58 25 11:43:59 Case 1:22-cv-10904-JSR Document 263-63 Filed 08/07/23 Page 3 of 7 MAGNA9 LEGAL SERVICES Page 106 1 F Pearn - Attorneys' Eyes Only 2 11:44:04 3 11:44:04 4 11:44:06 5 11:44:07 6 11:44:10 7 11:44:13 8 11:44:17 9 11:44:24 10 11:44:29 11 11:44:33 12 11:44:33 13 11:44:36 14 11:44:37 15 11:44:37 16 11:44:41 17 11:44:47 18 11:44:50 19 11:44:55 20 11:45:03 21 11:45:04 22 11:45:06 23 11:45:09 24 11:45:11 25 11:45:16 Case 1:22-cv-10904-JSR Document 263-63 Filed 08/07/23 Page 4 of 7 MAGNA9 LEGAL SERVICES Page 107 1 F Pearn - Attorneys' Eyes Only 2 11:45:18 3 11:45:22 4 11:45:26 5 11:45:30 6 11:45:32 7 11:45:33 8 11:45:34 9 11:45:36 10 11:45:38 11 11:45:38 12 11:45:40 13 11:45:40 14 Q. What is the compliance purpose of 11:45:41 15 informing a client how to avoid being flagged 11:45:45 16 for structuring, if it doesn't stop the 11:45:48 17 underlying cash withdrawals? 11:45:51 18 MR. BUTTS: Objection. 11:45:52 19 You may answer as a 30(b)(1) 11:45:54 20 witness, if you can. 11:45:55 21 A. Sure. We would -- there was no 11:45:58 22 reason to prevent individuals or corporations 11:46:02 23 from transacting in cash. Doing it to avoid 11:46:05 24 CTR reporting requirements is the problem, 11:46:11 25 and we make customers aware of their 11:46:15 Case 1:22-cv-10904-JSR Document 263-63 Filed 08/07/23 Page 5 of 7 MAGNA9 LEGAL SERVICES Page 164 1 F Pearn 2 that year or the year prior? 13:32:57 3 MR. BUTTS: Objection, 13:32:59 4 argumentative, harassing, 13:33:00 5 mischaracterizes the testimony, wasting 13:32:59 6 time. 13:33:02 7 A. I don't know how a banker in 2009 13:33:02 8 would discuss his or her bonus, not my 13:33:05 9 responsibility then nor now. 13:33:14 10 Q. Did Jeffrey Epstein receive a fee 13:33:15 11 for facilitating JPMorgan's acquisition of 13:33:17 12 Highbridge? 13:33:20 13 MR. BUTTS: Objection. 13:33:21 14 From whom? 13:33:25 15 Q. Receive a fee from JPMorgan? 13:33:39 16 A. Not from JPMorgan. 13:33:44 17 Q. What is your understanding of who 13:33:46 18 Jeffrey Epstein received a fee for? 13:33:48 19 A. I understand he received a fee from 13:33:49 20 Highbridge. 13:33:51 21 Q. In what amount? 13:33:52 22 A. I do not know the amount. 13:33:53 23 Q. Do you have an estimate of what the 13:33:55 24 amount was? 13:33:58 25 A. I do not. 13:33:58 Case 1:22-cv-10904-JSR Document 263-63 Filed 08/07/23 Page 6 of 7 MAGNA9 LEGAL SERVICES Page 182 1 F Pearn 2 customer? 14:00:22 3 A. Sorry, what do you mean and that 14:00:26 4 customer? 14:00:29 5 Q. Did Epstein have a role in 14:00:29 6 introducing JPMorgan to Leon Black or 14:00:31 7 expanding his accounts at JPMorgan? 14:00:34 8 MR. BUTTS: Object to form. 14:00:37 9 You may answer. 14:00:38 10 A. As the founder and one of the 14:00:39 11 senior leaders at Apollo Global Management, 14:00:44 12 the bank had a long established relationship 14:00:47 13 with Apollo and with Mr. Black. 14:00:50 14 My understanding is that Leon Black 14:00:57 15 was one of Mr. Epstein's clients as a money 14:01:01 16 manager. And as far as I've been able to 14:01:05 17 determine, we don't see any -- or I don't see 14:01:12 18 any introduction of Leon Black as a private 14:01:16 19 bank client through Mr. Epstein. 14:01:21 20 Q. What about Bill Gates, what's your 14:01:23 21 understanding of the relationship between 14:01:26 22 Jeffrey Epstein and Bill Gates and did he 14:01:29 23 facilitate either the creation of accounts 14:01:32 24 with JPMorgan or an expansion of his business 14:01:36 25 with JPMorgan? 14:01:38 Case 1:22-cv-10904-JSR Document 263-63 Filed 08/07/23 Page 7 of 7 MAGNA9 LEGAL SERVICES