Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/267-08.pdf

EXHIBIT 203 Case 1:22-cv-10904-JSR Document 267-8 Filed 08/07/23 Page 1 of 13 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff, v, No. 22-cv-10904-JSR JPMORGAN BANK, N.A., Defendant. _________________________________ JPMORGAN CHASE BANK, N.A., Third-Party Plaintiff v. JAMES EDWARD STALEY, Third-Party Defendant. __________________________________ THE ORAL DEPOSITION OF ALBERT BRYAN, JR. was taken on the 6th day of June, 2023, at the Law Offices of Joel Holt, 2132 Company Street, Christiansted, St. Croix, U.S. Virgin Islands, between the hours of 8:42 a.m. and 3:47 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) 777-6466 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 267-8 Filed 08/07/23 Page 2 of 13 162 ALBERT BRYAN, JR. -- DIRECT running in this election? A. Six. Q. Okay. A. At least I think. Don't quote me. I'm guessing. Q. Was that a normal number or was this a particularly crowded field? A. Lately it's been pretty crowded. Q. And then Epstein reports that you won. And Farkas writes back, Know him? Mr. Epstein writes, Very, Very. You see that? A. Eh-hmm. Q. You have any idea why he was describing your relationship that way other than what we've already discussed? MR. ACKERMAN: Objection speculation. THE WITNESS: No, sir. Q. (By Mr. Neiman:) Do you recall talking to Mrs. de Jongh in or around this time period when you were elected and when you began serving in office about the topic of donations that Mr. Epstein's company might make? A. Yeah. 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 267-8 Filed 08/07/23 Page 3 of 13 163 ALBERT BRYAN, JR. -- DIRECT Q. Take a look at some of those indications. Take a look first at Exhibit 8, which we'll mark as Exhibit 20. MR. ACKERMAN: I got it as 19. MR. NEIMAN: Well, let's make it 19, then. (Deposition Exhibit No. 19 was marked for identification.) Q. All right. I'm showing you Exhibit 19 which is a short exchange between Mrs. de Jongh and you copied to Richard Kahn. Do you see that? A. Between Mrs. de Jongh and me? Q. No. Between Mrs. de Jongh and Mr. Epstein copied to Richard Kahn. A. Correct. Yeah. Q. So Richard Kahn there, you could see the name spelled out full. Was that someone that contributed to any of your campaigns? A. I don't know Richard Kahn, sir. Q. You don't know one way or the other whether they contributed to your campaigns? A. No, I don't. Q. And Mrs. de Jongh is saying to Mr. Epstein that she spoke to Albert. That reference to you? A. Right. 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 267-8 Filed 08/07/23 Page 4 of 13 164 ALBERT BRYAN, JR. -- DIRECT Q. And he will let us know where he thinks STC's giving would be most impactful. He said, "Thank You." You see that? A. Yes. Q. Do you recall this discussion with de Jongh about where the giving would be most impactful? A. Yes. Q. How did you go about thinking about where the giving would be most impactful? A. Well, I mean, people -- normally non-profits usually contact government, like I said. But I mean, when you're running an election, you speak to everybody. I mean, it's only 11,000 votes, you could shake 11,000 hands. But I have -- the autism project is very near and dear to me. Of course Junior Achievement. I know places that were hit hard. You know, one of my things, Little League. I always thought -- you know, when I played Little League, we always had uniforms and really -- I mean, looked professional. And you know, the kids play in t-shirts now. I mean, I just think they just get a better feeling when they go out there. Q. Okay. And Junior Achievement was the place you had worked before you became governor? 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 267-8 Filed 08/07/23 Page 5 of 13 165 ALBERT BRYAN, JR. -- DIRECT A. Yes. Q. And so one of the things that you did when Mrs. de Jongh asked you, you know, where STC's giving would be most impactful, you said junior achievement? A. Yes. Q. You believed in the organization? A. Yeah. I worked for $40,000 a year. You know, I didn't do it for the money. I did it because, you know, I really believed that kids need financial literacy. Q. So, that was one of the things that you recommended? A. Yes. Q. So Mrs. de Jongh knew that was an issue that is personally important to you? A. I'm am sure she did. She knows I was essentially volunteering to be there. Q. So by giving to Junior Achievement, Mr. Epstein would be making contribution, then, would not only help the island but would be something that would be appreciated by you personally, right? MR. ACKERMAN: Objection to form. THE WITNESS: All contributions to our charities are appreciated by me personally. 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 267-8 Filed 08/07/23 Page 6 of 13 166 ALBERT BRYAN, JR. -- DIRECT Q. (By Ms. Neiman:) But this is a charity that you particularly invested in, right? A. If you're asking if it bought favor because he invested in Junior Achievement? Not particularly. Q. I didn't ask you that. I asked you -- A. I felt like I was helping them out more than they were helping me out. Q. Sure. But you were helping them out by suggesting that they contribute to a charity that you were quite close to, right? A. Right. I think in the documents I was shown, though, I said it would be self-serving for me to recommend Junior Achievement. So I didn't want to do that, you know. Because, I mean, those are my people. Q. But then you actually suggest Junior Achievement? A. Yeah, but I said it will be self-serving for me to do so. Q. So you suggested that it will be self-serving? A. Yeah. Q. And then they decided to give to Junior Achievement, right? 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 267-8 Filed 08/07/23 Page 7 of 13 167 ALBERT BRYAN, JR. -- DIRECT A. I don't know. Q. Fair enough. All right. Let's take a look at -- well, this time I'm showing you Exhibit 20. This is another email exchange to Mrs. de Jongh and Epstein in December of 2018. Between the time when you were elected and began to serve as Governor, correct? (Deposition Exhibit No. 20 was marked for identification.) A. Eh-hmm. Q. It's a tough one for the court reporter. A. Yes. MR. ACKERMAN: Objection to form. The last question, I think there were two questions in there. MR. NEIMAN: Okay. Q. (By Mr. Neiman:) Now, if you look at the bottom of the page, you could see that Mrs. de Jongh writes, Good afternoon Jeffrey, Albert suggested a school for autistic children and Junior Achievement. Do you see that? A. Yes. Q. Autism is another issue that's personally important to you? A. Yes. 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 267-8 Filed 08/07/23 Page 8 of 13 172 ALBERT BRYAN, JR. -- DIRECT on each islands, three balls, three inaugurations, three church services. Q. So