Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-39.pdf

EXHIBIT 92 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-39 Filed 08/07/23 Page 1 of 5 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 C O N F I D E N T I A L Videotaped oral deposition of BONNIE PERRY taken pursuant to notice, was held REMOTELY, commencing May 10, 2023, 9:39 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 www.MagnaLS.com Case 1:22-cv-10904-JSR Document 263-39 Filed 08/07/23 Page 2 of 5 MAGNA9 LEGAL SERVICES Page 53 1 2 10:51:13 3 10:51:14 4 10:51:14 5 10:51:15 6 10:51:19 7 10:51:20 8 10:51:20 9 10:51:26 10 10:51:28 11 Q. Are you aware of any sex 10:51:31 12 trafficking cases coming out of the private 10:51:33 13 bank during your tenure at JPMorgan? 10:51:35 14 MR. BUTTS: Objection. 10:51:40 15 You may answer. 10:51:42 16 A. No, I don't remember any. 10:51:42 17 Q. I think we spoke about rapid 10:51:45 18 response meetings earlier in your discussion 10:51:49 19 of your responsibilities, is that right? 10:51:52 20 A. That's correct. 10:51:53 21 Q. What is a rapid response meeting? 10:51:54 22 A. So it's an escalation of 10:51:57 23 information that was brought to us, 10:52:01 24 derogatory information, where it seems 10:52:07 25 something that should be escalated up to 10:52:11 Case 1:22-cv-10904-JSR Document 263-39 Filed 08/07/23 Page 3 of 5 - - ■ MAGNA9 LEGAL SERVICES Page 54 1 B Perry 2 management and they just -- we give them the 10:52:13 3 facts, they review it and make a 10:52:20 4 determination on how they want to proceed. 10:52:22 5 Q. So by us, you mean the Americas 10:52:26 6 control group slash -- 10:52:31 7 A. Americas -- 10:52:42 8 MR. BUTTS: So that's I think a 10:52:42 9 good reminder. We are talking over each 10:52:43 10 other a little bit. 10:52:46 11 So can you, Leslie, read the last 10:52:50 12 piece of her answer or the question and 10:52:54 13 then the answer from what you got so 10:52:56 14 far. 10:53:00 15 (Record read.) 10:53:04 16 MR. BUTTS: Maybe Danny, you can 10:53:19 17 take it from the top on that question 10:53:21 18 and we can then answer. 10:53:22 19 Q. By us, you mean the Americas 10:53:23 20 control group/risk management group, right? 10:53:27 21 MR. BUTTS: Objection to form. 10:53:31 22 You may answer. 10:53:32 23 A. Yes. We received it. If I recall, 10:53:33 24 copies may have gone to the banker and their 10:53:39 25 manager, I don't remember. 10:53:42 Case 1:22-cv-10904-JSR Document 263-39 Filed 08/07/23 Page 4 of 5 MAGNA9 LEGAL SERVICES Page 187 1 B Perry 2 Q. Was it your understanding that 14:35:00 3 Mr. Epstein was using large cash withdrawals 14:35:08 4 to pay for fuel expenses when he travels to 14:35:11 5 foreign countries? 14:35:13 6 MR. BUTTS: Objection and objection 14:35:15 7 to form. 14:35:15 8 You may answer, if you are able. 14:35:19 9 A. It's probably one of the only 14:35:20 10 things I really remember because of -- fuel 14:35:23 11 expenses for an airplane, I wouldn't even -- 14:35:27 12 I have no idea what it costs, but I thought 14:35:30 13 that was interesting. 14:35:33 14 Q. Okay. I appreciate your answer. 14:35:37 15 Can you just expand upon what you 14:35:38 16 mean by interesting? 14:35:43 17 MR. BUTTS: Objection to form. 14:35:45 18 You may answer. 14:35:46 19 A. I never thought about how much it 14:35:46 20 would cost to fuel an airplane and the answer 14:35:47 21 seemed reasonable. 14:35:51 22 Q. Does it seem reasonable today that 14:35:54 23 Jeffrey Epstein was using 20,000 to $40,000 14:35:56 24 in cash to pay for fuel expenses? 14:35:59 25 MR. BUTTS: Objection and objection 14:36:03 Case 1:22-cv-10904-JSR Document 263-39 Filed 08/07/23 Page 5 of 5 MAGNA9 LEGAL SERVICES