Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/267-13.pdf

EXHIBIT 208 Case 1:22-cv-10904-JSR Document 267-13 Filed 08/07/23 Page 1 of 68 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff, vs. No. 22-cv-10904-JSR JPMORGAN CHASE BANK, N.A., Defendant. _______________________________ JPMORGAN CHASE BANK, N.A., Third-Party Plaintiff, v. JAMES EDWARD STALEY, Third-Party Defendant. __________________________________ THE ORAL DEPOSITION OF CECILE DE JONGH was taken on the 29th day of May, 2021 at the Ritz-Carlton Hotel, 6900 Great Bay, Nazareth, St. Thomas, U.S. Virgin Islands, between the hours of 9:02 a.m. and 2:22 p.m. pursuant to Notice and Federal Rules of Civil Procedure. ____________________ Reported by: DESIREE D. HILL Registered Merit Reporter Hill's Reporting Services P.O. Box 307501 St. Thomas, Virgin Islands (340) 714-0269 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:22-cv-10904-JSR Document 267-13 Filed 08/07/23 Page 2 of 68 16 CECILE DE JONGH -- DIRECT government agencies as part of your job? A. Yes. Q. How about Port Authority? Was that one of them? A. I did interact with the Port Authority more so on the latter part because Mr. Epstein wanted a hangar for his helicopter. And -- so, I negotiated the lease with the Port Authority. Q. Okay. Now, there came a time when your husband became governor. A. Yes. Q. That was 2007? A. Yes. Q. And he served two terms? A. Correct. Q. Okay. Did that create any issues given your government-facing role for Mr. Epstein? A. I don't understand the question. Q. Okay. Well, let me ask it to you this way: Did you change how you interacted with the government in any way after you had -- after your husband became governor? A. I don't think so. With the exception of the fact that I would occasionally ask him for direction as to who I should go to. You know, if I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:22-cv-10904-JSR Document 267-13 Filed 08/07/23 Page 3 of 68 17 CECILE DE JONGH -- DIRECT had an issue, who should I talk to to get something done. Q. Okay. All right. And did your husband have any process for recusing himself from issues that related to the company you worked for? A. I don't know if he had any process. Q. Okay. You're not aware of any? A. I said I don't know. Q. Okay. You're not aware of him recusing himself from any issue regarding Mr. Epstein? A. I'm not aware of that, no. Q. Okay. All right. Now, when your husband became the governor, did you sort of get a second job result of that as the first lady of the Virgin Islands? A. Yes. Q. And what did that job entail? A. Giving a lot of speeches. I mean, he ran twice. So he ran in 2002 and lost. I was not very involved in that campaign. And between 2002 and 2006, you know, right after 2002, we discovered that our youngest son had some serious health issues. So I was very focused on that. We both were. And then he subsequently decided to run in 2006, and I was very involved in making sure that our 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:22-cv-10904-JSR Document 267-13 Filed 08/07/23 Page 4 of 68 19 CECILE DE JONGH -- DIRECT newsworthy at the time. So there was just a lot on my plate. And then I was also very involved in the National Governors Association. THE REPORTER: I'm sorry. THE WITNESS: The National Governors Association, because a lot of the first ladies were involved in mostly of children's activities. And the thing that I chose to do was to -- to focus on literacy, because there are many children in the Virgin Islands that didn't have -- when we would do door-to-door, during the campaign, one of the things I discovered that a lot of the household didn't have books in them. So my big project every year was to find a local author and have them write a book and give the books away for free because I didn't want to give toys and I didn't want to give candy. And so we'd have holiday parties and give away the books. So I would raise money during the year for that. And which, you know, took up a lot of time. But I also got a lot of requests for -- just give a lot of speeches. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:22-cv-10904-JSR Document 267-13 Filed 08/07/23 Page 5 of 68 20 CECILE DE JONGH -- DIRECT Q. And did you have an office as first lady? A. No. Q. Did you have, like, an office address? A. No. Q. Do you have, like, an official Twitter feed? A. Somebody set up a, I think a FaceBook something for me. I'm -- I'm not on -- I'm not on Twitter. I actually don't know how Twitter works. And I know that I had -- I had an email that was set up for me that I never really used because I had to go into the government system and then do something else and something else to get into it. And so I just asked the head of protocol, Raul Carrillo, I said if anything comes in, because it was -- it was the email address that they would give out to people saying, you know, if you want the First Lady to, you know, give a speech or show up somewhere, you know, email her at this email address. And so that was what was done. so I said can you just monitor it and if -- you know, just send me whatever and I'll see whether it fits into my schedule and I would either do it or not do it. Q. Okay. And did you have any staff that helped you in your role as First Lady? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:22-cv-10904-JSR Document 267-13 Filed 08/07/23 Page 6 of 68 21 CECILE DE JONGH -- DIRECT A. Well, I had the chief of protocol. But everybody -- all those people worked for Government House. So it was the expectation that if there was a social event -- if there was a social event, I was responsible for it. I found it sometimes very misogynistic. Q. Sure. A. But it was what it was. That if -- you know, if there was going to be sort of an event after the State of the Territory, that I should be pick the caterer, I should do this, you know. And so the chief of protocol had one or two staff members, and so I would have -- you know, I would run over to Government House and say, okay, what are we doing? You know, who are we inviting? And they would sort of handle everything. But they worked for -- they didn't exclusively work for me. They worked for Government House. Q. Got it. All right. Let's look at Exhibit 3. MS. WARREN: Tab 3, Exhibit 1. MR. NEIMAN: Yeah, Tab 3. I will ask the reporter to mark as Exhibit 1 a one-page document. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:22-cv-10904-JSR Document 267-13 Filed 08/07/23 Page 7 of 68 22 CECILE DE JONGH -- DIRECT (Deposition Exhibit No. 1 was marked for identification.) Q. (By Mr. Neiman:) All right. Ms. de Jongh, I handed you a one-page document, which is the Twitter printout for ceciledeJongh@firstlady.vi. Do you see that? A. Yes. Q. You recognize that? A. This is a Twitter account? Q. It is. A. Okay. But I never -- these aren't -- this is not something that I typed up. Q. All right. So you can see in the -- at the sort of top half of the page there's a picture; right? A. Yes. Q. That's you? A. That is me. Q. Okay. And it says under that that it's the official Twitter account of U.S. Virgin Islands' First Lady, Cecile de Jongh. Do you see that? A. Em-hmm. Q. And then it indicates that it was jo