Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-55.pdf

EXHIBIT 108 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 1 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 1 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 2 GOVERNMENT OF THE : 3 UNITED STATES VIRGIN : ISLANDS, : CASE NO. 4 : 1:22-CV-10904 Plaintiff, : -JSR 5 : v. : 6 : JPMORGAN CHASE BANK, : 7 N.A., : : 8 Defendant/Third Party : Plaintiff. : 9 ______________________ : JPMORGAN CHASE BANK, : 10 N.A., : : 11 Third Party Plaintiff, : : 12 v. : : 13 JAMES EDWARD STALEY, : : 14 Third Party Defendant. : 15 CONFIDENTIAL - ATTORNEYS' EYES ONLY - - - 16 May 3, 2023 - - - 17 Videotaped deposition 18 of WILLIAM D. LANGFORD, taken pursuant to notice, was held at the law offices of 19 Boies Schiller Flexner LLP, 55 Hudson Yards, New York, New York, and remotely, 20 beginning at 9:37 a.m., on the above date, before Michelle L. Gray, a 21 Registered Professional Reporter, Certified Shorthand Reporter, Certified 22 Realtime Reporter, and Notary Public. 23 GOLKOW LITIGATION SERVICES 877.370.3377 ph| 917.591.5672 24 deps@golkow.com Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 2 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 169 1 that -- that is a fair characterization 2 of the initiative? 3 A. Yes. 4 Q. Okay. Okay. You can put 5 that aside. 6 In looking at the 7 transactional activity associated with 8 human trafficking. Would you agree that 9 cash is an important red flag of 10 potential trafficking? 11 MR. KRAUSE: Objection. 12 THE WITNESS: So, again, I 13 need to go back to what we were 14 looking at. The cash components 15 of it, we were focused, 16 appropriately so, on the business 17 of trafficking. That is, people 18 who set up the criminal enterprise 19 to capture, imprison, move, and 20 sell the services, right, and 21 generate the criminal proceeds, 22 just like drug trafficking. 23 So what we -- what we 24 focused on, you know, it wasn't -- Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 3 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 170 1 the cash usage actually wasn't all 2 that helpful, but it was, rather, 3 other indicia that we actually 4 found where you could start to 5 link it to people who were 6 promoting the trafficking, the 7 prostitution for example, using 8 otherwise benign retail accounts. 9 That was really the focus -- ended 10 up finding, I should say. 11 BY MS. SINGER: 12 Q. Okay. And so, again, I want 13 to focus not just on what you were doing, 14 what you were implementing at JPMorgan in 15 the human trafficking initiative, but 16 kind of the learnings that cash is 17 specifically suggestive of human 18 trafficking. 19 Do you agree with that 20 statement? 21 MR. KRAUSE: Objection. 22 THE WITNESS: So again, 23 partially. What we were looking 24 for, what I really wanted to find, Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 4 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 220 1 derogatory information and identifiable 2 activity, this was identifiable activity 3 related to the information that was 4 available on Jeffrey Epstein's conduct, 5 correct? 6 MR. GAIL: Objection. 7 THE WITNESS: Yeah, so I 8 have to say, I've not seen an 9 instance where, in response to 10 negative media, we would have 11 pulled an affidavit like this. 12 Doesn't mean it doesn't happen. 13 I'm saying that's not typically 14 what I would have done as an 15 investigator, but I've never been 16 an investigator. So I've not seen 17 it in the context of the 18 investigations done. 19 Is it relevant. Everything 20 is relevant when you're assessing 21 conduct. But at the end of the 22 day, the question of using the 23 bank to conduct the activity, 24 spending money, sure, I'd like to Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 5 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 221 1 know. 2 But at the end of the day, 3 withdrawal of cash is a withdrawal 4 of cash. And so especially small 5 dollars, wealthy people withdraw 6 cash. They do a lot of different 7 things. 8 So it's in contrast, 9 perhaps, to the receipt of 10 information, the criminal 11 enterprise like we talked about. 12 So it presents more of a 13 challenge. 14 MS. SINGER: So move to 15 strike that answer. 16 BY MS. SINGER: 17 Q. I appreciate it. But I 18 think it was different than my question. 19 And I want to ask the 20 question again, which is, the fact that 21 Jeffrey Epstein, from whatever source, 22 right, The New York Times article, the 23 supporting documents, was known to pay 24 cash to girls who he was sexually abusing Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 6 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 283 1 customer, shortly before the break. 2 So if corporate compliance 3 or AML Ops wanted -- wanted Epstein 4 terminated, and the Private Bank 5 disagreed, what would happen? 6 A. So to answer that question, 7 we need to distinguish. 8 In the context of a question 9 of reputational risk, I -- my view is, 10 and doctrine, I would have a vote but 11 would not be a decisive vote. 12 To the extent it involved 13 active ongoing violations of law and 14 someone disagreed with me, then I would 15 escalate above that line of business up 16 to CEO, up to board of directors, up to 17 and including resignation, if it didn't 18 resolve as I thought it should. 19 Q. Okay. And by CEO, you mean 20 CEO of JPMorgan, Jamie Dimon? 21 A. If that were the case, yes. 22 Q. Okay. And who would -- what 23 would be the chain of escalating? So 24 before you got to Jamie Dimon, who would Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 7 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 284 1 you go to? 2 A. So, again, that wasn't this 3 case. 4 Q. Yep. 5 A. But if I ever had a 6 situation where I had said it's time to 7 exit, the line of business said no, I 8 would first go to Steve Cutler, who would 9 have been my boss at the time. If Steve 10 Cutler disagreed and didn't convince me 11 otherwise, then I would push it up 12 further, probably to Jamie at that point. 13 And then if I still felt like I wasn't 14 getting heard and it was an active 15 ongoing issue, then I would go to the 16 board. 17 18 19 20 21 22 23 24 Case 1:22-cv-10904-JSR Document 263-55 Filed 08/07/23 Page 8 of 26 William Langford - Confidential Attorneys' Eyes Only Golkow Litigation ServicesPage 309 1 there was such a meeting, that there 2 would be documents ab