Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/245-22.pdf

EXHIBIT 297 Case 1:22-cv-10904-JSR Document 245-22 Filed 07/25/23 Page 1 of 27 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 245-22 Filed 07/25/23 Page 2 of 27 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 245-22 Filed 07/25/23 Page 3 of 27 18 CECILE DE JONGH -- DIRECT son was okay. I also had my great aunt who was in failing health. She had had breast cancer. And so part of that -- I mean, he actually made me a promise that I would never have to give a speech, and that was not true. And he asked me to head up -- well, he and his team asked me to head up the Women For de Jongh- Francis at the time, and -- which I did. And so we did -- you know -- so during the campaign part, we did things like, you know, gatherings for children, walking -- you know, doing walks and just sort of -- and food sales and things like that. And I tried to do as many things as I could that wouldn't take away time from either work or from my children. And then once he won, it became very overwhelming because my aunt passed away within two months of my husband becoming governor. I had to settle her affairs, and my mother was diagnosed with Alzheimer's, and my sister, who was bipolar -- Q.I'm sorry. I saw in the emails about your sister -- you don't have to talk about that if you prefer not to. A.She had a very public breakdown which was 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 245-22 Filed 07/25/23 Page 4 of 27 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 245-22 Filed 07/25/23 Page 5 of 27 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 245-22 Filed 07/25/23 Page 6 of 27 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 245-22 Filed 07/25/23 Page 7 of 27 33 CECILE DE JONGH -- DIRECT with them to inspect it. So, here's your R.O. plant, here's the generator. So I did that, and I think they came over like three different times for that. Q.Okay. A.One for the R.O. plant, and I think twice for the generator because I think, if I remember correctly, something, they needed something for the spill kit, wasn't there. So he come back and make sure whatever needed to be in the spill kit was there. Q.Okay. Is that all the meetings that you remember -- withdrawn. All the times that you remember going to Little St. James? A.Little St. James, yes. Q.Okay. Did there come a time when you learned that Mr. Epstein had been arrested in F