Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/326-22.pdf

EXHIBIT 22 Case 1:22-cv-10904-JSR Document 326-22 Filed 09/08/23 Page 1 of 5 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 THURSDAY, JULY 13, 2023 15 CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER 16 – – – 17 Videotaped deposition of 30(b)(6) JPMorgan Chase Bank, N.A., designee Francis 18 Pearn, held at the offices of Williams & Connolly, 650 Fifth Avenue, Suite 1500, 19 New York, New York, commencing at 9:41 a.m. Eastern, on the above date, before Carrie A. 20 Campbell, Registered Diplomate Reporter and Certified Realtime Reporter. 21 22 – – – 23 GOLKOW LITIGATION SERVICES 24 877.370.3377 ph | 917.591.5672 fax deps@golkow.com 25 Case 1:22-cv-10904-JSR Document 326-22 Filed 09/08/23 Page 2 of 5 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 153 1 case, what was found. 2 QUESTIONS BY MR. WOHLGEMUTH: 3 Q. So JPMorgan's view is that the 4 cash activity that Mr. Epstein was engaging 5 in was, in fact, consistent with the 6 explanation that he provided? 7 A. That's correct. 8 Q. Has any other private banking 9 client of JPMorgan ever said, I'm withdrawing 10 hundreds of thousands of dollars in cash 11 every year to pay for private aviation 12 expenses? Is that an explanation that's ever 13 been provided to your knowledge, sir? 14 MR. BUTTS: Objection. Beyond 15 the scope. 16 You may answer as a 30(b)(1) 17 witness. 18 THE WITNESS: I have no idea or 19 have heard of that being an 20 explanation for large cash. 21 That said, I have seen very 22 large amounts of cash be taken out of 23 the bank by private bank clients over 24 my time at the bank. 25 Case 1:22-cv-10904-JSR Document 326-22 Filed 09/08/23 Page 3 of 5 Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 157 1 So I just want to be more 2 precise as to how that investigation began. 3 Q. Understood. 4 And as it related to 5 Mr. Staley, that investigation began at what 6 time? 7 A. So that would have been in 8 probably end of September, beginning of 9 October 2019 when we were in, I'd say, very 10 much the heaviest part of the investigation 11 around Mr. Epstein and Ms. Maxwell, for that 12 matter, in response to those subpoenas. 13 The e-mails that we found 14 between Mr. Staley and Mr. Epstein was part 15 of that investigation, and those e-mails were 16 provided to our AML investigators who then 17 did the work that you saw resulting in the -- 18 what I'll call the connection of wires from 19 Mr. Epstein's accounts to the woman , 20 what have you, and then linking it to the 21 e-mails between Mr. Staley and Mr. Epstein 22 . 23 Q. JPMorgan was aware before this 24 e-mail review that you've mentioned that 25 Mr. Staley had a relationship with Case 1:22-cv-10904-JSR Document 326-22 Filed 09/08/23 Page 4 of 5 - Confidential - Pursuant to Protective Order Golkow Litigation ServicesPage 158 1 Mr. Epstein, correct? 2 A. That's correct. 3 Q. JPMorgan was aware that 4 Mr. Epstein hosted Mr. Staley at his home, 5 correct? 6 A. That's correct. 7 Q. On a number of occasions, 8 correct? 9 A. Correct. 10 Q. JPMorgan was aware that 11 Mr. Staley visited other properties owned by 12 Mr. Epstein, fair? 13 A. That's correct. 14 Q. And when communicating with 15 Mr. Epstein, Mr. Staley used his JPMorgan 16 account primarily it's fair to say, right? 17 MR. BUTTS: Objection. 18 You may answer as a 30(b)(1) 19 witness if you -- 20 THE WITNESS: I honestly don't 21 know. I can only comment on what I 22 saw through the JPMorgan e-mail 23 account. 24 QUESTIONS BY MR. WOHLGEMUTH: 25 Q. Okay. That's fair. Let me put Case 1:22-cv-10904-JSR Document 326-22 Filed 09/08/23 Page 5 of 5