Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-66.pdf

EXHIBIT 119 FILED UNDER SEAL Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 1 of 8 Confidential - Attorneys' Eyes Only Golkow Litigation ServicesPage 1 1 IN THE UNITED STATES DISTRICT COURT 2 FOR THE SOUTHERN DISTRICT OF NEW YORK 3 ___________________________ | 4 GOVERNMENT OF THE UNITED | STATES VIRGIN ISLANDS, | 5 | Plaintiff, | 6 | vs. | Case No. 7 | 1:22-cv-10904-JSR JPMORGAN CHASE BANK, N.A., | 8 | Defendant. | 9 ___________________________| | 10 JPMORGAN CHASE BANK, N.A., | | 11 Third-Party | Plaintiff, | 12 | vs. | 13 | JAMES EDWARD STALEY, | 14 | Third-Party | 15 Defendant. | ___________________________| 16 17 Wednesday, April 19, 2023 18 CONFIDENTIAL - ATTORNEYS' EYES ONLY 19 Videotaped deposition of Phillip DeLuca, held 20 at the offices of Ulmer & Berne, 65 East State Street, Columbus, Ohio, commencing at 9:06 a.m., on the above 21 date, before Carol A. Kirk, Registered Merit Reporter, Certified Shorthand Reporter, and Notary Public. 22 23 GOLKOW LITIGATION SERVICES 877.370.DEPS 24 deps@golkow.com Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 2 of 8 Confidential - Attorneys' Eyes Only Golkow Litigation ServicesPage 85 1 Jeffrey Epstein from the bank? 2 MR. KRAUSE: Objection. 3 You can answer. 4 A. Do I understand -- can you repeat 5 that, please? 6 Q. Do you know the basis for AML 7 Investigations' recommendation to exit 8 Mr. Epstein from the bank? 9 A. I believe it was reputational 10 risk. 11 Q. Reputational risk based on what? 12 A. Based on a prior conviction. 13 Q. A prior conviction for what? 14 A. Some type of sexual activity. 15 Q. Do you know when relative to 16 Mr. Epstein's conviction the recommendation to 17 exit him from the bank was made? 18 A. No, I don't. 19 Q. Do you recall whether AML 20 Investigations recommended more than once that 21 Mr. Epstein be exited from the bank? 22 A. I don't recall. 23 Q. Did you speak with Mr. Langford 24 about the disagreement between Private Bank and Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 3 of 8 Confidential - Attorneys' Eyes Only Golkow Litigation ServicesPage 298 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 4 of 8 ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Confidential - Attorneys' Eyes Only Golkow Litigation ServicesPage 299 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 BY MS. OLIVER: 21 22 23 24 Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 5 of 8 ■ ■ ■ - ■ - ■ ■ - ■ ■ ■ ■ ■ - - Confidential - Attorneys' Eyes Only Golkow Litigation ServicesPage 330 1 Q. What did he say in response? 2 A. "I'll get back to you." 3 Q. Do you recall anything else? 4 A. Pardon? 5 Q. Do you recall anything else about 6 the call? 7 A. No. 8 Q. How was it left? 9 A. That he would get back to me. 10 Q. So did you ever hear back from 11 Mr. Moyer? 12 A. About that? No. 13 Q. Did you ever hear back from anyone 14 else at the FBI, whether an investigator, an 15 agent, or otherwise? 16 A. No. 17 Q. Given your consistent dealings 18 with law enforcement, how did you interpret the 19 fact that the FBI never got back to you about 20 Epstein? 21 A. That they weren't interested. 22 Q. Okay. One more topic, and then 23 we'll be done. 24 Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 6 of 8 Confidential - Attorneys' Eyes Only Golkow Litigation ServicesPage 331 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Q. Did anyone from JPMorgan's 19 Private Bank ever at any time try to dissuade 20 you personally from doing anything at all in 21 connection with Jeffrey Epstein? 22 A. No. 23 Q. Are you aware of any instance 24 where anyone from any of JPMorgan's businesses Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 7 of 8 ■ ■ ■ - Confidential - Attorneys' Eyes Only Golkow Litigation ServicesPage 332 1 tried to dissuade you or any of your colleagues 2 from doing anything at all relating to 3 Jeffrey Epstein? 4 A. I'm not aware of any of them. 5 6 7 8 9 10 11 12 13 14 15 Q. You did or did not develop a good 16 understanding of Maryanne Ryan's temperament and 17 skills from your time working with her? 18 A. Yes. 19 Q. How skilled was Maryanne as an 20 investigator? 21 A. Maryanne was extremely skilled. 22 Q. You did or did not develop a good 23 understanding of Maryanne Ryan's temperament 24 from your time working with her? Case 1:22-cv-10904-JSR Document 263-66 Filed 08/07/23 Page 8 of 8 ■ ■ ■ ■