EXHIBIT 306¶
UNITED STATES DISTRICT COURT¶
SOUTHERN DISTRICT OF NEW YORK¶
CASE NO. 22-CV-10904¶
GOVERNMENT OF THE UNITED STATES V.I.,¶
Plaintiff,¶
vs.¶
JPMORGAN CHASE BANK, N.A.,¶
Defendant.¶
***CONFIDENTIAL***¶
July 7, 2023¶
x¶
x¶
Confidential Remote Video-Recorded¶
30(b)(6) Deposition of¶
GVI BY JEAN-PIERRE ORIOL¶
Stenographically Reported By:¶
Mark Richman, CSR, CCR, RPR, CM¶
Job No. J9913116¶
2 page.¶
3 MR. ACKERMAN: Okay.¶
4 A. No, nothing privileged.¶
5 Q. Okay. Could you read in that¶
6 7 half page of notes, just read it aloud, please.¶
8 A. Sure. The --¶
9 MR. ACKERMAN: Objection. You¶
10 can go ahead.¶
11 A. Lieutenant -Ann Cannonier,¶
12 she's currently the director of¶
13 investigations for VIPD for the last two¶
14 and a half years. She's been with the¶
15 VIPD for 26 years. If the complaint was¶
16 lodged with VIPD a case number would¶
17 have been developed and generated. VIPD¶
18 asserts that there have been no¶
19 complaints made.¶
20 And then for me, what my¶
21 understanding of this proceeding is, is¶
22 that I'm prepared to answer questions on¶
23 investigations and investigation¶
24 monitoring steps.¶
25 Q. Is that all the notes? 01:13¶
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1 2 JP ORIOL - 7.7.23 - CONFIDENTIAL related to DPNR duties.¶
3 4 5 6 Q. So that's what I was getting at. The subject matter of all of the six or seven depositions, you were testifying in connection with your work for DPNR?¶
7 A. Yes.¶
8 9 10 Q. Were you testifying in your individual capacity or as a corporate designee?¶
11 A. As an agent for the department.¶
12 13 14 Q. So do you understand today that you've been designated as a witness pursuant to Rule 30(b)(6)?¶
15 A. Yes.¶
16 17 Q. What is your understanding of what that means?¶
18 MR. ACKERMAN: Objection.¶
19 20 A. That I am representing the GVI and not just DPNR.¶
21 22 23 24 25 Q. So in your -- in the prior deposition you gave in this case, you testified in a personal capacity, but here you're testifying as a representative of the government,¶
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2 3 4 5 6 7 8 9 10 A. I would say that it's going further from my, me personally going out to the island having done investigation work, but from a natural resource perspective. And then if, again speaking on behalf of the government, that there were questions from VIPD and whether or not they did any investigations or monitoring.¶
11 12 13 14 15 16 17 Q. Okay. So I'm going to read you the topic which is "investigations or investigative or monitoring steps concerning Epstein or his companies undertaken by the Virgin Islands Police Department or the DPNR that occurred prior to December 1st, 2020."¶
18 19 20 Is that what you understand you've been designated to testify about today?¶
21 A. Yes.¶
22 23 24 25 Q. So it's really two topics, one is about the VIPD's investigations and monitoring prior to December 1, 2020 and one is about DPNR's, correct?¶
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2 A. Yes, I understand.¶
3 4 5 Q. So let's start with the first one, VIPD. Are you prepared to testify on that topic today?¶
6 A. To the best of my ability, yes.¶
7 8 9 Q. And what did you do to prepare to testify as to investigations or investigative monitoring steps¶
10 11 concerning Epstein or his companies undertaken by the VIPD?¶
12 A. Met with the Lieutenant¶
13 14 15 16 -Ann Cannonier who is the director of investigations for the VIPD, and asking if there was any investigations into Mr. Epstein I guess prior to 2020.¶
17 18 19 Q. Do you know how long Lieutenant Cannonier was the director of investigations?¶
20 A. Two and a half years.¶
21 22 23 24 25 Q. Do you know if the information that Lieutenant Cannonier provided to you was based only on the two and a half years or was it based on the full period from December 1, 2020 backwards?¶
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2 3 4 A. So what I know is that the purchase of Little St. James happened around 1999.¶
5 6 7 Q. Okay. And then Mr. Epstein died in approximately 2019, or in 2019, correct?¶
8 A. Correct.¶
9 10 Q. So for approximately 20 years he was a resident of the USVI?¶
11 12 MR. ACKERMAN: Objection, scope, asked and answered, speculation.¶
13 14 15 16 A. Yeah, I don't know the -- I don't know when he was actually claiming residency here in the territory. I only know when he purchased this property.¶
17 18 Q. He owned property on USVI for 20 years, correct?¶
19 A. Yes.¶
20 MR. ACKERMAN: Objection, scope.¶
21 22 23 Q. And during that 20-year period, how many times did VIPD visit Epstein's island?¶
24 25 A. I don't know that any visits were made.¶
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2 3 4 Q. And no, during that 20 year span, no complaints were received regarding Epstein, correct?¶
5 A. That's correct.¶
6 7 8 9 Q. Beyond formal complaints, do you know if there were any interactions between VIPD and Epstein during that 20-year period?¶
10 MR. ACKERMAN: Objection.¶
11 A. No --¶
12 13 14 15 MR. ACKERMAN: Hold on, Commissioner, let me just get my objections in. Objection, scope, form. Go ahead.¶
16 A. No, I do not.¶
17 18 Q. Do you know if VIPD had any interaction with Epstein's companies?¶
19 20 MR. ACKERMAN: Objection, scope, form.¶
21 A. No, I do not.¶
22 23 Q. Let's pull up tab 40 and enter it as exhibit 1.¶
24 25 (Exhibit 1, document produced to JPMorgan by the USVI titled 2010¶
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2 3 VI-JPM-OOOO796O1 was marked for identification.)¶
4 A. Okay.¶
5 Q. This is an email chain that¶
6 starts with a July 16, 2O19 email from a¶
7 Curt of CNN.com and it asks¶
8 certain questions of the VI Police¶
9 Department including "Has US Virgin¶
1O Islands Police Department participated¶
11 in (or been asked to participate in) any¶
12 investigation related to Mr. Jeffrey¶
13 Epstein?"¶
14 Do you see that?¶
15 A. Yes.¶
16 Q. Do you know what the answer to¶
17 that question is?¶
18 A. Has the US Virgin Islands Police¶
19 Department received any complaints? So,¶
2O again, from what was reported to me,¶
21 that there were no complaints.¶
22 Q. Sorry, I was focused on the¶
23 second question which is has US Virgin¶
24 Islands police participated in or been¶
25 asked to participate in any 02:03¶
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JP ORIOL - 7.7.23 - CONFIDENTIAL¶
Q. So this is a response by Glenn
Dratte to the CNN reporter and he's
reporting, "I did a complete check with
the VIPD criminal investigations bureau
and no complaints has been filed against
Mr. Jeffrey Epstein with the Virgin
Islands Police Department. If there's
anything further I can assist please
reach out to my office."¶
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Do you see that?¶
A. Yes.¶
Q. So that is the answer as of July
18, 2019.¶
Do you know if subsequent to that
date there was any investigation?¶
02:06¶
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MR. ACKERMAN: Objection, scope,
form.¶
A. No, I do not know. Or at least
what was reported to me was that there
was no investigation. There is no case
number that has been assigned with
anything related to Mr. Epstein, so --¶
Q. And that's -- that's --¶
A. So I would say no.¶
2 3 Q. And that's ever, there's no date restriction on that?¶
4 5 6 7 A. Well that i -- based on what was reported to me as of this year, in them looking back, that there is no case number.¶
8 9 10 Q. Okay. Would there be any investigation that wouldn't be assigned a case number?¶
11 12 13 A. That I don't know. PD would have to assign -- PD would have to indicate that directly.¶
14 15 Q. Did you ask Lieutenant Cannonier that question?¶
16 17 18 19 20 A. What Lieutenant Cannonier did state is that if there was a complaint received or that they were opening an investigation, that there would be a case number.¶
21 22 23 Q. Okay. So no USVI individual ever came to VIPD to say they were a victim of Jeffrey Epstein, correct?¶
24 25 A. To my understanding, that's correct.¶
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2 3 4 5 6 Q. When you are conducting -- you or other DPNR officials are conducting investigations for DPNR, are you doing that within the confines of DPNR's jurisdiction?¶
7 A. Correct.¶
8 9 Q. If you saw suspicious activity that was outside DPNR's jurisdiction,¶
10 11 12 would you or other DPNR investigators have reported that activity to the proper authorities?¶
13 A. Yes, that's correct.¶
14 15 16 Q. And does that include, by the way, the visit to Epstein's island where you saw Epstein with a woman?¶
17 A. Yes.¶
18 19 20 21 22 Q. Thank you. And earlier today there was a, there was an exhibit with Jason Marsh, it was an email and attachment. Do you recall that set of documents? It's exhibits 4 and 5.¶
23 24 25 A. I can go back to it. I mean I know we saw a number of, a number of emails that I think Jason was copied on. 04:07¶
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2 3 4 Q. Yes. I'm referring to the one, the PDF title is 8 and 8A if you have that.¶
5 A. Okay, yes.¶
6 7 8 9 Q. All right. 8, the part of the exhibit that is exhibit 5, the one that is titled 8A, how many pages is that PDF document?¶
10 A. 48.¶
11 12 13 14 Q. And do you know whether Mr. Marsh was forwarding only one article in the Virgin Islands Daily News or whether he was forwarding the entire paper?¶
15 A. I have no clue.¶
16 MR. O'LAUGHLIN: Objection.¶
17 18 19 Q. Do you know, do you know which article in the 48 pages Mr. Marsh was forwarding to this email address?¶
20 A. No, I have no clue.¶
21 22 23 Q. All right. We can put that document aside. Commissioner Oriol, that's all I have. Thank you very much.¶
24 THE WITNESS: Okay.¶
25 MR. O'LAUGHLIN: So we're going 04:09¶
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