EXHIBIT 208¶
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS,¶
Plaintiff,¶
vs.¶
JPMORGAN CHASE BANK, N.A.,¶
Defendant.¶
JPMORGAN CHASE BANK, N.A.,¶
Third-Party Plaintiff,¶
v.¶
JAMES EDWARD STALEY, Third-Party Defendant. No. 22-cv-10904-JSR¶
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. , 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. Registered Merit Reporter Reporting Services P.O. Box 307501 St. Virgin Islands (340) 714-0269¶
1 government agencies as part of your job?¶
2 A. Yes.¶
3 4 Q. them? How about Port Authority? Was that one of¶
5 6 7 8 A. I did interact with the Port Authority more so on the latter part because Mr. Epstein wanted a hangar for his helicopter. And -- so, I negotiated the lease with the Port Authority.¶
9 10 Q. Okay. Now, there came a time when your husband became governor.¶
11 A. Yes.¶
12 Q. That was 2007?¶
13 A. Yes.¶
14 Q. And he served two terms?¶
15 A. Correct.¶
16 17 Q. Okay. Did that create any issues given your government-facing role for Mr. Epstein?¶
18 A. I don't understand the question.¶
19 20 21 22 Q. Okay. Well, let me ask it to you this way: Did you change how you interacted with the government in any way after you had -- after your husband became governor?¶
23 24 25 A. I don't think so. With the exception of the fact that I would occasionally ask him for direction as to who I should go to. You know, if I 1 2 had an issue, who should I talk to to get something done.¶
3 4 5 Q. Okay. All right. And did your husband have any process for recusing himself from issues that related to the company you worked for?¶
6 A. I don't know if he had any process.¶
7 Q. Okay. You're not aware of any?¶
8 A. I said I don't know.¶
10 Q. Okay. You're not aware of him recusing himself from any issue regarding Mr. Epstein?¶
11 A. I'm not aware of that, no.¶
12 13 14 15 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?¶
16 A. Yes.¶
17 Q. And what did that job entail?¶
18 19 20 21 22 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.¶
23 24 25 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¶
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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 Q. And did you have an office as first lady?¶
2 A. No.¶
3 Q. Did you have, like, an office address?¶
4 A. No.¶
5 6 Q. Do you have, like, an official Twitter feed?¶
7 8 9 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.¶
10 11 12 13 14 15 16 17 18 19 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.¶
20 21 22 23 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.¶
24 25 Q. Okay. And did you have any staff that helped you in your role as First Lady?¶
1 2 3 4 5 6 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.¶
7 Q. Sure.¶
8 9 10 11 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.¶
12 13 14 15 16 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.¶
17 18 19 But they worked for -- they didn't exclusively work for me. They worked for Government House.¶
20 21 Q. Got it. All right. Let's look at Exhibit 3.¶
22 : Tab 3, Exhibit 1.¶
23 24 25 MR. NEIMAN: Yeah, Tab 3. I will ask the reporter to mark as Exhibit 1 a one-page document.¶
(Deposition Exhibit No. 1 was marked for identification.)¶
Q. (By Mr. Neiman:) All right. Ms. de Jongh, I handed you a one-page document, which is the Twitter printout for ceciledeJongh@firstlady.vi. Do you see that?¶
A. Yes.¶
Q. You recognize that?¶
A. This is a Twitter account?¶
Q. It is.¶
A. Okay. But I never -- these aren't -- this is not something that I typed up.¶
Q. All right. So you can see in the -- at the sort of top half of the page there's a picture; right?¶
A. Yes.¶
Q. That's you?¶
A. That is me.¶
Q. Okay. And it says under that that it's the official Twitter account of U.S. Virgin Islands' First Lady, Cecile de Jongh. Do you see that?¶
A. Em-hmm.¶
Q. And then it indicates that it was joined in September of 2012? You see that?¶
A. Yeah.¶
1 the first lady?¶
2 A. Correct.¶
3 Q. And then there's a bunch of Tweets?¶
4 A. Right.¶
5 Q. Do you know who wrote them?¶
6 A. I don't.¶
7 8 Q. Would it had been somebody working for the government?¶
9 10 A. It might have been somebody working for the government, yeah.¶
11 12 Q. Okay. You didn't hire someone separate from the government to manage this?¶
13 A. I didn't have money to do that.¶
14 Q. Sure. Sure. Okay.¶
15 16 17 A. Just -- I mean, there's no office of the first lady with a budget. There was -- there was nothing.¶
18 19 Q. Okay. So let's take a look at -- I show you another document which we will mark as Exhibit 2.¶
20 21 22 23 MR. SCHIFFMAN: Is it possible to share these through chat at the same they're being introduced so that we could -- I'll look at them as well online.¶
24 MR. NEIMAN: Sure. Okay.¶
1 2 (Deposition Exhibit No. 2 was marked for identification.)¶
3 4 5 6 7 Q. (By Mr. Neiman:) Okay. I placed in front of you, Ms. de Jongh, Exhibit 2, which is a printout from the archives of the internet of the official website of the Governor of the U.S. Virgin Islands. Do you see that?¶
8 A. Yes. Eh-hmm.¶
9 10 Q. And this announces that you had your own website. Do you see that?¶
11 A. Eh-hmm.¶
12 Q. Do you recall that?¶
13 A. I recall that, yeah.¶
14 15 16 MR. SCHIFFMAN: I'm sorry, counsel, was there an answer to that question as to whether documents are going to be shared in the chat?¶
17 MR. NEIMAN: Yeah. The answer was yes.¶
18 19 MR. SCHIFFMAN: Okay. I'm sorry. I just missed it.¶
20 MR. NEIMAN: And it's in the chat now.¶
21 22 23 Q. (By Mr. Neiman:) Okay. Sorry to interrupt. We were talking about the website. Tell us about the first lady website that was set up.¶
24 25 A. That was something I think the P.R., that the governor's P.R. department, John Greaux and his¶
1 2 staff put up because I was, you know, I was doing things. So they wanted to put it out there.¶
3 4 5 Q. Right. And you mentioned that you had to give a lot of speeches in this in this job. Did you have someone who could write the speeches for you?¶
6 7 8 9 10 11 A. Yeah. Julia, I can't remember her last name, worked in the P.R. department. So a lot of times I would draft something and I would send it to her and say, you know, what are your thoughts. And she would clean it up and send it to me, and that's how it was done.¶
12 13 Q. Okay. And Julia was an employee of the government?¶
14 A. Correct.¶
15 16 17 Q. Okay. And if you look at this little printout, you could see it says, "First Lady Launches Website."¶
18 A. Eh-hmm.¶
19 20 Q. And then in the second paragraph, there's a little quote attributed to you. Do you see that?¶
21 A. Yes.¶
22 23 24 25 Q. And it says at the bottom, that "It's important that residents and other interested individuals have access to the ongoing work of the first lady on behalf of all Virgin Islanders."¶
1 Do you see that?¶
2 A. Yes.¶
3 4 Q. Is that sort of how you saw your role as working on behalf of all the Virgin Islanders?¶
5 A. Yes.¶
6 7 8 Q. Okay. All right. And you can see that to the left there there's a little box that says "Office of the First Lady."¶
9 A. Eh-hmm.¶
10 Q. Do you see that?¶
11 And then there's a phone number and a --¶
12 A. I'm sorry, yes.¶
13 14 Q. Yeah, she can't write it down unless you say it.¶
15 A. Yes. I know, yes.¶
16 17 18 Q. Let me just say one other thing, very normal in regular conversation for us to kind of both be talking at the same time?¶
19 A. I apologize.¶
20 Q. Super hard for her.¶
21 A. Yeah.¶
22 Q. So I will try not to¶
23 A. And I will try as well.¶
24 25 Q. Great. So you can see in this box it says "Office of the First Lady," and then there's an¶
1 address listed. Do you see that?¶
2 A. Eh-hmm. Yes.¶
3 4 Q. And that's the address where the governor's office is?¶
5 A. Correct.¶
6 7 Q. Okay. And there's a phone number and a fax number there as well. Do you see that?¶
8 A. Yes.¶
9 10 Q. And who would answer if that phone number was called?¶
11 12 A. That's -- that's the same number as Government House.¶
13 14 Q. Okay. That's the general switchboard number for Government House?¶
15 A. Yes.¶
16 17 Q. Okay. And would that call find its way to you, eventually?¶
18 A. Yes. I didn't work at Government House.¶
19 THE REPORTER: I'm sorry.¶
20 21 THE WITNESS: I didn't work at Government House.¶
22 23 24 Q. (By Mr. Neiman:) Okay. So if someone called the number that the website is saying is the number for the office of First Lady, what happens?¶
1 A. No.¶
2 Q. Do you remember a person named ?¶
3 A. The name I do recognize, yeah.¶
4 Q. What do you remember about this person,¶
5¶
6 7 8 9 10 11 12 13 A. The thing I remember correctly is there was a who was, when I was out getting my knee replacement in 2017, I was gone for a while, and I came back, and I think Jeanne told me that there was a who was going to be working with us. And I said, who? And then -- who -- who worked with us. And by the time I came back, she was off and on the payroll.¶
14 15 Q. You mean she had gone on the payroll and then off the payroll?¶
16 A. Yeah.¶
17 18 Q. And you were in New York for, like, two weeks?¶
19 A. No. I was gone for about a month.¶
20 Q. About a month.¶
21 A. Yeah.¶
22 23 Q. And am I correct that you stayed in an apartment provided by Mr. Epstein in New York?¶
24 A. Correct.¶
1 THE WITNESS: Yes.¶
2 3 4 Q. (By Mr. Neiman:) I know it's hard. At the top, there's an email from you to Mr. Epstein and copied to Mr. Kahn, correct?¶
5 A. Yes.¶
6 7 8 9 Q. Okay. And you will see at the bottom Mr. Epstein is asking you something about whether there's an CB5 visa regional center in the V.I. Also, tuition is approved. Do you see that?¶
10 A. Eh-hmm. Yes.¶
11 12 13 Q. Okay. So what is that -- what is he talking about there, first, with the CB5 visa regional center?¶
14 A. As I sit here now, I don't know.¶
15 16 Q. Okay. And then you will see it also says "Also tuition is approved."¶
17 Do you see that?¶
18 A. Yes.¶
19 Q. What's that talking about?¶
20 A. That's probably tuition for our kids.¶
21 22 Q. And am I correct that Mr. Epstein paid the college tuition of your children.¶
23 24 A. Of mine and everybody else who had kids at Financial Trust, yes.¶
1 2 3 really can't do anything to influence -- can't do anything or influence Hancock since this the private sector issue. Do you see that?¶
4 A. Yes.¶
5 Q. Who is Kenn Hobson?¶
6 A. I think was the head of VIPA at the time.¶
7 8 Q. Got it. And you say, "This is why Kenn gave us a possible alternative."¶
9 Do you see that?¶
10 A. Eh-hmm. Yes.¶
11 Q. What are you referring to there?¶
12 A. Well, I think that's referring to --¶
13 Q. To item 2 in the previous email?¶
14 A. Yeah.¶
15 16 17 18 19 Q. Okay. And then you go and say, in the next paragraph of your email, in Exhibit 9, that, "John has said if you get the fuel prices together to show how Hancock is gouging, he can take it to VIPA board. Thoughts on this."¶
20 Do you see that?¶
21 A. Yes.¶
22 23 24 25 Q. So you're bringing up, again, the point you made in the prior email that one way to deal with this issue was to have your husband, the governor, take it to the VIPA board, right?¶
1 anybody about getting it approved.¶
2 3 It was presented, I think, by Mr. Epstein and Erika Kellerhals at the time.¶
4 5 Q. (By Mr. Neiman:) Okay. I think my question to you was did you stay out of it entirely?¶
6 7 A. I did. I did stay -- well, yes. The answer is yes, I stayed out of it.¶
8 9 Q. All right. Let me show you a document marked -- I will have the reporter mark as Exhibit 14.¶
10 11 (Deposition Exhibit No. 14 was marked for identification.)¶
12 13 14 15 Q. (By Mr. Neiman:) And you will see that Exhibit 14 is an email exchange involving Carol Chapman, Nugent Do you see that?¶
16 A. Yes.¶
17 18 Q. And Carol Chapman worked for the Economic Development Authority, correct?¶
19 A. I don't know her.¶
20 21 Q. You don't know her. You know Clouden, though?¶
22 A. I do.¶
23 Q. He was who?¶
24 25 A. I think he was the executive director, I think is the right term. Right. Yeah. I think it's¶
1 the right title.¶
2 3 Q. He was the executive director of the Economic Development --¶
4 A. Yes.¶
5 Q. -- Agency?¶
6 A. Yes. I believe so, at the time.¶
7 Q. Okay. And Jennifer Nugent-_?¶
8 A. Honestly, I don't know what her title was.¶
9 10 Q. She also had a role with the Economic Development?¶
11 A. But she worked there, yes.¶
12 13 14 15 16 Q. Okay. And let's take a look at Ms. Chapman's email to In the middle of the page she writes, "Hope you had a great Christmas and birthday. The CEO called a few moments ago and asked me to give you his best regards."¶
17 Do you remember who the CEO was?¶
18 A. No, I don't.¶
19 20 Q. Okay. All right. You certainly would have known at the time who the CEO of the EDC was.¶
21 A. I don't recall.¶
22 23 Q. Okay. But I mean, you were a pretty senior person --¶
24 A. Yeah.¶
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Did you know at the time, even if you can't remember today who it was?¶
A. I would probably know then, yes.¶
Q. And you'll see that what writes is that, "The CEO called a few minutes ago, asked me to give you his best regards."¶
And then it goes down to the next paragraph, "He asked me to let you know he had a call from the First Lady, and she has asked that Epstein be on the board agenda at the public hearing for the January 9th meeting."¶
Do you see that?¶
A. Yes.¶
Q. So, what is relating is that you had made a phone call to the CEO of the EDC, right?¶
A. Yes.¶
Q. Do you have any reason to dispute that?¶
A. Nope.¶
Q. Okay. And the purpose of your call was to get an issue related to Mr. Epstein's certificate in front of the agency, right?¶
MS. BOGGS: Objection. Mischaracterizes this document.¶
THE WITNESS: The EDC was notoriously always postponing, postponing, postponing.¶
1 2 3 4 5 And so I can only sitting here today assume that either Erika Kellerhals or -- said, can somebody please make a phone call to see if we can get on somebody's agenda so we could get this over with.¶
6 Q. (By Mr. Neiman:) And you made the call?¶
7 A. I made the call.¶
8 9 (Deposition Exhibit No. 15 was marked for identification.)¶
10 11 12 Q. (By Mr. Neiman:) All right. Let's take a look now at -- all right. Ms. de Jongh, I'm handing you a document marked Exhibit 15.¶
13 14 And Exhibit 15 is a 2010 email exchange between you and Jeffrey Epstein.¶
15 Do you see that?¶
16 A. Yes, I do.¶
17 18 19 Q. And at the bottom of the page, Mr. Epstein is asking you who is in charge of Customs in the Virgin Islands.¶
20 Do you see that?¶
21 A. Yes.¶
22 23 24 Q. And am I correct that although the Virgin Islands is part of the United States, it's not part of the United States. It's customs zone.¶
1 2 3 4 Q. And that means that even if you're coming from the United States and going back to the United States, you have to clear Customs before you get on a plane and go back to the United States.¶
5 A. Correct.¶
6 7 8 9 Q. And so if Mr. Epstein had guests with him and they were flying on his plane back to the United States, they'd have to go through Customs before they left?¶
10 A. Correct.¶
11 12 Q. So Customs would see whoever was with Mr. Epstein on his plane?¶
13 14 MR. TEAGUE: Objection, form. You could answer.¶
15 16 17 THE WITNESS: I would -- I guess I would assume so. I mean, I never been on his plane, so I don't know.¶
18 19 Q. (By Mr. Neiman:) Sure. But according to how the rules work, that's how it would work?¶
20 21 A. I mean, whenever I leave here I have to go through customs.¶
22 23 24 Q. Okay. And Mr. Epstein is writing to you and asking you who was in charge of customs for the Virgin Islands?¶
1 MR. TEAGUE: You to answer out loud.¶
2 THE WITNESS: I'm sorry, yes.¶
3 4 Q. (By Mr. Neiman:) Okay. I'm sorry. And that's a federal official?¶
5 A. Yes.¶
6 7 8 Q. Okay. And he writes, "I used to have great relationship with Gloria Lambert, the airport supervisor."¶
9 Do you know who Gloria Lambert is?¶
10 A. No, I do not.¶
11 12 13 Q. Okay. And he writes, "I would like to know who is now in her place or her boss with Kenn Hobson now." Do you see that?¶
14 A. I see that.¶
15 16 Q. "There is a Mr. Carpenter who has been difficult lately; not sure why."¶
17 Do you know who Mr. Carpenter was?¶
18 A. I do not.¶
19 20 21 22 Q. Okay. And then you write back on this request from Mr. Epstein to find out whose running Customs in the Virgin Islands. You say, "I spoke to Kenn." Do you see that?¶
23 A. Yes.¶
24 25 Q. So Mr. Epstein had this question about who is running Customs and wondered whether Kenn Hobson¶
1 would know. And you followed up with Kenn Hobson?¶
2 A. Correct.¶
3 Q • And Kenn Hobson was running the Port¶
4 Authority at the time?¶
5 A. Correct.¶
6 Q. And the Port Authority would have¶
7 interactions with Customs?¶
8 A. I would assume, yeah, they would.¶
9 10 Q. Right. And in fact, Mr. -- when you withdrawn.¶
11 12 13 When you spoke to Mr. Hobson, he told you who was running customs in the Virgin Islands, this Mr. Harrigan, right?¶
14 A. Yes.¶
15 16 Q. And then you forwarded that information on to Mr. Epstein. Do you see that?¶
17 A. Yes.¶
18 19 20 Q. And do you know anything about what the nature of Mr. Epstein's relationship was with Mr. Harrigan?¶
21 A. I do not.¶
22 23 Q. Do you know whether Mr. Epstein gave gifts to the folks at Customs?¶
24 25 A. I am not aware. I was not involved. I know that -- I think he asked me once about my¶
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thoughts of giving turkeys or something, but other than that.¶
Q. Okay. You remember Mr. Epstein asked you if you thought it was okay for him to give a turkey to all the people who work at Customs at the airport --¶
A. I vaguely remember that.¶
Q. -- people who would see who was on his airplane?¶
A. Yeah. I vaguely remember that, yes.¶
Q. And you said that was okay?¶
A. Yeah. I mean --¶
Q. Did you check with anyone first before you gave that advice?¶
A. Well, down here, people usually give gifts to people at Department of Finance, they give, you know, they give gifts to people who they normally interact with on a regular basis.¶
You know, it's similar to, you know, when, you know, my brother-in-law lives in a building where everybody gives a gift to the doorman, you know. So that's where I was thinking, I had no reason to think anything untoward was happening.¶
Q. Sure. But you would recognize that Customs officials are not like the doorman in your building. They are law enforcement officers, right?¶
1 A. Correct. But --¶
2 3 4 5 Q. And so my question to you was did you check with anyone before you told Mr. Epstein it was okay to give this gift to the Customs official who could see who was on his plane?¶
6 A. Well --¶
7 8 MR. TEAGUE: Objection to form. You can answer.¶
9 10 11 12 13 THE WITNESS: No, I didn't check with anyone, but it doesn't matter whether I checked with anybody or not. It was his decision whether he wanted to do that or not. It wasn't my say-so.¶
14 15 Q. (By Mr. Neiman:) Okay. But you thought it was okay?¶
16 17 A. I just said, okay, if that's what you want to do.¶
18 19 Q. Did Mr. Epstein have relationships with other governors besides your husband?¶
20 MS. BOGGS: Objection, vague.¶
21 MR. TEAGUE: Objection, form.¶
22 Mischaracterization. You can answer.¶
23 THE WITNESS: Yes.¶
24 25 Q. (By Mr. Neiman:) Which other governors did Mr. Epstein have relationships with?¶
1 A. Governor Mapp and Governor Bryan.¶
2 THE REPORTER: With who?¶
3 THE WITNESS: Bryan.¶
4 5 6 Q. (By Mr. Neiman:) What was the nature of Mr. Epstein's relationship with Governor Mapp as you perceived it?¶
7 8 A. Well, Governor Mapp was not a friend of mine.¶
9 Q. Okay.¶
10 11 12 13 14 15 16 17 A. And which reason I am pretty sure you are aware. But I was just aware of the fact that he visited the island a few times, and that -- I think that I was cc'd on a few emails of schedules of meetings and things like that. But I was never involved in any meetings, never, you know, participated in any of the meetings, and I never knew whatever it is they talked about.¶
18 19 20 21 22 I do know that -- and I don't know the dates. I could only say that it's -- I think Mapp got into office in 2015 and he was out in 2018. That Mr. Epstein visited him at Government House once, but I don't know when. So that's the nature.¶
23 24 25 Q. Okay. And you said that Governor Mapp was not a friend and that I would know why. What were you referring to?¶
1 2 A. Well, the fact that shortly after my husband left office he had him arrested.¶
3 THE REPORTER: I'm sorry.¶
4 THE WITNESS: He had him arrested.¶
5 Q. (By Mr. Neiman:) For what?¶
6 7 8 9 A. Because we decided not to live in Catherineberg because it was mold infested and I didn't want my children living there. So we decided to live in our own home.¶
10 11 12 13 And they put up a security -- a little security house and a fence, and got the funding through -- they passed it through the legislature. And for political reasons, people made III of it.¶
14 15 16 17 18 19 20 And my husband, you know, three or four years before he came out of office said, it's okay, when we get out of office, I'll just pay everything back, which we were in the process of doing, and Governor Mapp decided that, I believe because he never wanted my husband to ever run again decided to arrest him.¶
21 Q. What happened?¶
22 23 24 25 A. And what happened was that they then said, well, you don't want to go to jail, just pay all this money, which was about a hundred and something thousand dollars more than what we determined was the¶
1 2 depreciated value. And we had a certain -- date certain that we had to pay it back.¶
3 Q. So what happened?¶
4 A. We paid it back.¶
5 Q. Where did you get the money to do that?¶
6 7 8 9 10 11 A. We got some money from my mother's trust and Mr. Epstein called me up and said, "Is everything okay, what's happening?" And I said this is the position we're in, and we're going to refinance our house for the rest of the money, but I don't think that we're going to be able to do it in time.¶
12 13 14 15 16 So he offered to lend us the money, which he did immediately. I asked him if we could pay it back within three years, and he said, "No, you have to pay it back within a year, with interest." And so he did that and we paid it back.¶
17 18 Q. Okay. So about how much money did Mr. Epstein loan you at this time?¶
19 A. 200,000.¶
20 Q. How did you pay it back?¶
21 22 23 24 A. We refinanced our house. We took out 150 -- we got -- we were able to get $150,000 out. We paid. And then I for -- I had to forego any bonuses. And then the rest of it, we paid out of pocket.¶
1 2 foregoing bonuses you might otherwise have earned from your job?¶
3 4 A. Well, it would be just give me the bonus and I had to write a check and pay it back.¶
5 6 Q. Okay. About how much of the repayment came from these bonuses?¶
7 A. 20,000.¶
8 9 10 Q. All right. How about Governor Bryan, what was the relationship between Mr. Epstein and the current governor?¶
11 12 13 14 15 A. I sort of had less knowledge of what was going on there. Erika Kellerhals was close to Governor Bryan. I mean, I've known Governor Bryan, obviously, because he was commissioner of Labor under my husband, and he sat on a committee that I ran.¶
16 THE REPORTER: That I --¶
17 THE WITNESS: Pardon.¶
18 19 THE REPORTER: It sat on a committee that --¶
20 21 THE WITNESS: That I ran. Children's Cabinet that I ran.¶
22 23 And -- but I knew that Erika Kellerhals had arranged some meetings with him.¶
24 25 Q. (By Mr. Neiman:) Okay. Some meetings between Mr. Epstein and Mr. Bryan?¶
1 A. Correct.¶
2 3 Q. What is this Children's Cabinet that you're referring to?¶
4 5 6 7 8 9 10 11 A. It's something that other states had done and we tried to replicate it here where we were you know, we have Department of Education, Department of Labor, sort of heads of all the -- all the departments -- not all departments, but departments that deal with children. Police department. And we would come together, like, every two months. And so they'd help me with my book drives.¶
12 13 14 15 16 17 18 19 20 We did things, like, I would go to department of -- the police department and talk to the police about ADD and ADHD and how that affected especially young boys, and that their acting out wasn't necessarily something that they needed to get arrested for, go to juvie, but to sensitize the police on how to treat children with that, especially because, you know, it was more prevalent, especially with ADHD, more prevalent in boys.¶
21 22 23 24 25 We worked with the NEEKC Foundation on early childhood education, and got implemented that all the early childhood centers, one of our goals was to make sure that every child caretaker, at least, had a high school degree, and that they worked¶
1 2 3 4 5 6 towards an associate degree because, you know, in the Virgin Islands, at the time that we -- you know, that John got into office, it was felt that people would focus more on education in high school years, and that really what we should focus on is, the most important thing was zero to five.¶
7 8 9 10 11 And that if we had a solid zero to five, then those kids could learn anything anywhere. And that we wanted to sort of flip the dynamic. And in order to do that, we had to get everybody on board for that.¶
12 13 14 So we held quite a few symposiums on that, and in acting with the NEEKC Foundation. And so those were some of our goals.¶
15 16 Q. Okay. And you were the chair of the children's Cabinet?¶
17 A. Yes.¶
18 19 Q. And this was -- the other members of this cabinet were senior government officials?¶
20 A. Correct.¶
21 Q. And then you ran it?¶
22 A. Yes.¶
23 24 Q. Okay. And that Children's Cabinet helped to implement the government's policy?¶
1 were in sync with government's policy.¶
2 THE REPORTER: I'm sorry, in sync?¶
3 THE WITNESS: In sync with the¶
4 government's policy.¶
5 6 7 8 Q. (By Mr. Neiman:) And as you were talking sort of this focus on early childhood, that was an example of kind of implementing what the government wanted to do?¶
9 A. Correct.¶
10 11 12 Q. Okay. So, do you recall Mr. Epstein being influential in who the current governor appointed to various positions?¶
13 MS. BOGGS: Objection, form.¶
14 THE WITNESS: Of him being influential?¶
15 Q. (By Mr. Neiman:) Yeah.¶
16 17 18 19 20 21 22 23 24 A. I would make some sort of recommendations of, you know, who I thought would be good in terms of -- because what he was -- seemed to be mainly concerned about was being able to build whatever he wanted to build on Little St. James. That was always a point of contention for me and for Erika because, you know, we never went over there. So he would build whatever he would build. Some with permits; some without.¶
1 2 3 upset. We'd say, you know, here we are again. He would get fined, you know, we call it a NOVA, Notice of Violation.¶
4 5 6 7 I think he was -- got a Notice of Violation like three or four times under John's administration. I don't know about under Mapp's administration.¶
8 9 10 The other thing that was very important to him was being able to get a hangar down at the at the airport.¶
11 12 13 14 15 He -- as I told you earlier I worked out a lease which took two long years to get for his helicopter, and then he subsequently wanted to be able to get a lease, or have a hangar built for his plane.¶
16 17 Q. Okay. So he cared who was running the Port Authority?¶
18 19 A. Because he wanted to be able to build a hangar.¶
20 21 22 Q. All right. And you remember enlisting Mr. Epstein to support a particular candidate to become the head of the Port Authority?¶
23 A. Yes.¶
24 Q. Tell me about that.¶
1 Bryan.¶
2 Q. Who seemed to have the ear?¶
3 A. Jeffrey Epstein.¶
4 Q. Eh-hmm.¶
5 A. And so I just said, you know, that Carlton¶
6 7 Dowe would probably be, you know, best for you in terms of being able to get the hangar that you want.¶
8 9 10 Q. Okay. And you say that Jeffrey Epstein seemed to have the work of -- the ear, right - withdrawn.¶
11 Let me start again.¶
12 13 14 You said that Jeffrey Epstein seemed to have the ear of Governor Bryan. What did you mean by that?¶
15 16 17 18 19 20 21 22 23 A. Well, he -- I knew that -- I knew that they spoke. And when Governor Bryan was setting up his cabinet, and I knew that -- I knew that Carlton Dowe wanted -- I think he was there before, Mapp let him go, and he wanted to go back. And I thought he did a brilliant job when he was there before, and he would probably do a brilliant job again. And that he would probably -- you know, he seemed to be more business friendly rather than status quo.¶
24 25 When he was there before, he'd, you know, put in all these beautiful palm trees and¶
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certainly made, you know, just made the place look welcoming.¶
And, you know, right now he's, you know, putting in new parking, it's -- you know, it's going well. And so I just thought, you know, this is probably the guy that you would want to talk to to be able to build a hangar.¶
Q. And so you suggested to Mr. Epstein that he talk to Governor Bryan about appointing Mr. Dowe?¶
A. Yeah.¶
Q. Because you thought that Mr. Epstein might be able to be helpful in getting Mr. Dowe appointed?¶
A. Yeah. Yes.¶
Q. Okay. And Mr. Epstein agreed to do that?¶
A. Yes.¶
Q. And he spoke to the governor about it?¶
A. That I don't know. He didn't -- he -- he rarely ever came back -- circled back to me and told me what he spoke about.¶
Q. Got it. Okay. So let's take a look at what we will mark Exhibit 16.¶
(Deposition Exhibit No. 16 was marked for identification.)
¶
Q. (By Mr. Neiman:) Exhibit 16 is a 2018 email exchange between you and Jeffrey Epstein,¶
1 2 A. Well, yeah, I know that Carlton had been appointed.¶
3 Q. Do you remember --¶
4 5 6 7 8 9 10 11 12 13 A. I do recall that one of the reasons why it was necessary to do -- well, we felt it was necessary to do that is because Erika Kellerhals was, obviously, Mr. Epstein's attorney, and Mr. Epstein told me that she was dead set against Mr. Dowe being -- going back to the Port Authority. And so that was why we -- you know, why I said, hey, if you can give him a good word, give him a good word, because I know that Erika Kellerhals was saying something else.¶
14 15 Q. Got it. So this was a situation where it was not a sure thing that Mr. Dowe would get this job?¶
16 A. Yeah.¶
17 Q. Correct?¶
18 A. Correct.¶
19 20 Q. And you thought Mr. Epstein could be influential in getting him the job?¶
21 22 A. Well, I knew that he listened a lot to Erika.¶
23 Q. Who listened a lot to Erika?¶
24 A. Mr. Epstein.¶
1 2 to back somebody that your thought Erika was trying to persuade him not to back?¶
3 A. Right.¶
4 Q. I see.¶
5 A. It's a small island.¶
6 7 Q. Understood. Okay. Tell me who Celestino is?¶
8 9 A. He's a former senator here. I can't remember how many terms. Maybe ten terms here.¶
10 Q. Okay.¶
11 A. And he became a consultant.¶
12 Q. Did he do work for Mr. Epstein?¶
13 A. He did.¶
14 15 Q. What was the nature of the work that Celestino did for Mr. Epstein?¶
16 17 18 19 A. He started out doing work for -- actually, for Andrew Farkas. The second time that John -- that my John ever met with Mr. Epstein was in 2014, I think.¶
20 21 22 23 Mr. Farkas was very, very, very upset and livid that when taxi drivers got picked up from WICO dock, that they would completely bypass Yacht Haven Grande and go straight to town.¶
24 25 And he had all these shops and every - you know, invested all of this money. And also that 1 people.¶
2 3 4 Q. Okay. And that -- but Celestino was the specific recommendation of one person who might fit that role?¶
5 A. Yes.¶
6 7 Q. And that Mr. Farkas and Mr. Epstein, therefore -- thereafter, hired Mr. ?¶
8 A. Yes.¶
9 Q. Okay. Do you know how much they paid him?¶
10 A. No. That -- no, I don't.¶
11 12 Q. Does your husband have any kind of financial relationship with Mr. ?¶
13 A. No.¶
14 15 Q. Do you have any kind of financial relationship?¶
16 A. No, I do not.¶
17 Q. Okay.¶
18 A. But may I complete my¶
19 Q. Sure. Go ahead.¶
20 21 22 23 A. So -- and then subsequent to that, Mr. Epstein did hire Celestino to -- he came up with the idea that he wanted to change the name of Little St. James to Little St. Jeff.¶
24 25 And he asked me, and I said I have no clue how one would go about doing that. And so he¶
1 2 3 called up Celestino and went and did a contract with him. And Celestino presented something, and my -- did my own --¶
4 THE REPORTER: I'm sorry.¶
5 6 7 THE WITNESS: Presented, did a -- did a written proposal or something, and it kind of died there.¶
8 9 Q. (By Mr. Neiman:) Okay. Did you ever recommend Celestine to Mr. Epstein?¶
10 11 A. I think might I have recommended it for the Little St. Jeff thing.¶
12 Q. For anything else?¶
13 A. Not that I can recall.¶
14 15 Q. Okay. Let's take a look at a couple of documents. First, let me show you what 281.¶
16 17 I'm going to ask the reporter to mark as page 18, a one-page document.¶
18 19 (Deposition Exhibit No. 18 was marked for identification.)¶
20 21 22 Q. (By Mr. Neiman:) All right. And this is an email from you to Mr. Epstein on February 11, 2015. Do you see that?¶
23 A. Yes. This was Little St. Jeff.¶
24 25 Q. Let me just ask the questions so I make sure I got it.¶
1 A. All right.¶
2 Q. So this is in February of 2015?¶
3 A. Yeah.¶
4 5 6 Q. And you're recommending to Mr. Epstein that he put Celestino on what you call a monthly retainer, correct?¶
7 A. Eh-hmm.¶
8 Q. What did you mean by that?¶
9 10 MR. TEAGUE: You have to answer out loud.¶
11 THE WITNESS: I'm sorry, yes.¶
12 13 Q. (By Mr. Neiman:) What did you mean by a monthly retainer in this context?¶
14 15 A. Because I knew Celestino wouldn't do anything for cheap.¶
16 Q. Okay. What do you mean by that?¶
17 18 19 20 21 22 23 A. I just knew he wouldn't, you know -- if you paid him $2,000, he would be, like, he's not going to do anything much, but, you know, that's - and when he wanted to do Little St. Jeff, this is probably the person that you -- and, you know, the one thing that I knew, if you wanted to change a name you have to go to the legislature to do that.¶
24 25 And I am just said, I'm not the person to go down to the legislature to convince somebody to¶
1 change the name an island.¶
2 3 4 5 Q. I got it. And you write that after you say you should consider putting Celestino on some sort of monthly retainer, you write, "That will get you his loyalty and access." Do you see that?¶
6 A. Eh-hmm. Well, he is a consultant.¶
7 8 Q. So what did you mean his loyalty and access?¶
9 10 11 12 A. Usually when you pay people -- you know, I mean -- I don't know. I don't know why I said that. Just that he would -- he would be responsive to you. He would -- he would, you know, make you a priority.¶
13 14 Q. All right. Do you remember Celestino doing any other work besides the Little St. Jeff work?¶
15 A. He may have, but I don't recall.¶
16 17 Q. Okay. Let me show you a document marked Exhibit 19.¶
18 19 (Deposition Exhibit No. 19 was marked for identification.)¶
20 21 22 Q. (By Mr. Neiman:) Do you recognize Exhibit 19 as an email exchange between you and Mr. Epstein in August of 2015?¶
23 24 A. I don't even know what this is referring to.¶
1 You see that?¶
2 A. Yes.¶
3 Q. That was true, right?¶
4 A. I was for a period of time, yes.¶
5 6 7 Q. And it also says he pays for the education of the governor's children at the exclusive Antilles School on St. . That was true also?¶
8 9 A. He paid for my children and everybody else's children, yes.¶
10 11 Q. Well, when you say everybody else's children, you mean other employees of FTC?¶
12 13 14 A. Correct. And other EDC companies, that is normal par for the course for other EDCs to pay for their children. It was normal and customary.¶
15 Q. Okay.¶
16 A. We were not special.¶
17 18 19 20 Q. Okay. And you see down at the bottom of the page, and this is good classic New York Post speak, it says in the last paragraph, "de Jongh's flack didn't return our call."¶
21 Do you see that?¶
22 A. Eh-hmm.¶
23 24 Q. Do you remember hearing that the New York Post was covering this issue?¶
1 2 (Deposition Exhibit No. 26 was marked for identification.)¶
3 4 5 6 7 Q. (By Mr. Neiman:) Okay. Let's take a look now at Exhibit 26. You see at the bottom of the page, Mr. Epstein writes back to you, "I can enroll if that helps the school." Do you see that?¶
8 A. Eh-hmm.¶
9 10 11 Q. So he's now identified a third person with an Eastern European name who could benefit from English as a second language classes, right?¶
12 13 MR. TEAGUE: Objection, form. You could answer.¶
14 15 THE WITNESS: Yes, those three names were there.¶
16 17 18 19 20 Q. (By Mr. Neiman:) Okay. Did it ever cross your mind to wonder whether there was something wrong with this convicted sex offender telling you I have three women who I'd like to help learn to speak English?¶
21 22 MS. BOGGS: Objection, vague, argumentative.¶
23 24 25 THE WITNESS: This is -- this is a person who had one offense, had to register as a sex offender. Didn't see him with any --¶
1 2 (Deposition Exhibit No. 35 was marked for identification.)¶
3 4 5 Q. (By Mr. Neiman:) Ms. de Jongh, this is an email exchange between you and Jeffrey Epstein in September of 2015. Do you see that?¶
6 A. Yes.¶
7 8 9 10 11 12 13 14 Q. All right. Looking at the email at the bottom of the page from Mr. Epstein to you, he writes, "I will play any role in this you guys like. I could lend John the money so he immediately has it. I would gladly be on the phone (anonymous) with John Quinn and the prosecutor offering suggestions. 25 a year for 20 yours, 490 now, with an income tax for the full amount. 250 now and 250 in 15 years, et cetera."¶
15 What's going on here?¶
16 17 A. That's the note that I told you about when John got arrested, with Mapp.¶
18 Q. Ah.¶
19 20 A. So it is not John Quinn. It is John and Quinn. It's Mike Quinn, John's attorney.¶
21 Q. Ah.¶
22 A. So he just didn't put a comma, I guess.¶
23 24 25 Q. Got it. And this reference to 25 a year for 20 years, 490 now with an income tax credit for the full amount, 250 now and 250 in 15 years, what's¶
1 that talking about?¶
2 3 4 A. I actually never knew what he meant by that because it was just, you know, we needed like 400,000, or a little shy of 400,000.¶
5 6 7 8 9 So I just said I would, you know, discuss it with John. You know, he wanted, you know, to see if we wanted him -- if we wanted him to pay for our legal fees, and we said, no, we got that covered.¶
10 11 12 13 14 It was just the issue of the Mapp administration at the time trying to squeeze us to pay immediately or go to jail, which we thought seemed, you know, if it's a criminal offense, why ask us for money, you know. So --¶
15 16 Q. And Mr. Epstein was giving some advice about how to handle this criminal problem?¶
17 18 A. His advice was, don't go to court, just pay the money.¶
19 20 21 Q. Okay. And -- but he is offering here some various proposed structures for how to pay. Is that fair?¶
22 A. That's fair.¶
23 24 Q. And one of them was to pay 490,000 now, but get an income tax credit for the full amount?¶
1 2 3 Q. And to do that as a convicted felon, he needed to get his supervision moved from Florida to the Virgin Islands, right?¶
4 A. Correct.¶
5 6 7 Q. And you were passing on information related to that to the governor and the attorney general of the Virgin Islands.¶
8 9 A. About how to go about -- how one would go about doing that.¶
10 11 Q. Right. And then you spoke to your husband about it?¶
12 A. Yes.¶
13 14 Q. And got some advice about what the best way it was to proceed, right?¶
15 16 A. Yes. Like who who would you talk to to get this done.¶
17 18 Q. Did you also talk to the attorney general about it?¶
19 A. I didn't speak directly to Vincent.¶
20 THE REPORTER: Sorry, I couldn't --¶
21 THE WITNESS: I don't -- I don't believe¶
22 I talked directly to Vincent about it.¶
23 24 Q. (By Mr. Neiman:) So your husband talked to the attorney general?¶
1 2 Q. And then relayed to you this information that you've set out in your email to Mr. Epstein?¶
3 4 A. Yeah. What he needed to do in order to get transferred here.¶
5 6 7 8 Q. So you, the attorney general, and the governor are together helping Mr. Epstein sort through how he can transfer supervision from Florida to the Virgin Islands?¶
9 A. How to legally get transferred here, yes.¶
10 Q. Okay. All right.¶
11 12 A. You mentioned that he was in jail at this time?¶
13 Q. Eh-hmm.¶
14 15 A. I don't -- I think he was on work release. He was -- I never spoke to him once he was in jail.¶
16 17 18 Q. Okay. But he was -- withdrawn. Do you remember him being on work release in the daytime and then going to jail at night?¶
19 A. I didn't -- I never knew his schedule.¶
20 Q. Okay.¶
21 22 23 A. I just know that I hadn't spoken to him the whole time that he was incarcerated or in -- even on work release.¶
24 25 Q. Okay. But at some point in 2009 you were speaking to him about getting his future supervision¶
1 transferred?¶
2 A. Emailing, yeah.¶
3 4 5 Q. Well, emailing, but he says at the beginning of the email, "Call me when you get a chance," right?¶
6 7 A. Right. And usually I would call, like, Lesley Groth and she would --¶
8 THE REPORTER: Who?¶
9 10 11 THE WITNESS: Lesley Groff. Because tens out of -- ten times out of ten I wouldn't have a number for him.¶
12 13 Q. (By Mr. Neiman:) So you would call Lesley and she could reach him?¶
14 A. And she would patch me in to him.¶
15 16 17 Q. Got it. Okay. All right. Let's talk about a topic we touched on earlier today which is the sex offender registry.¶
18 A. Eh-hmm.¶
19 20 21 Q. Do you recall discussing the topic of the sex offender registry as it related to Mr. Epstein with your husband?¶
22 A. Yes.¶
23 24 Q. Who else did you talk about that topic besides the governor?¶
1 2 Q. You never talked to the attorney general about that topic?¶
3 4 A. No, he talked to the attorney general about the topic.¶
5 6 Q. Okay. Tell me what he told you about his conversations with the attorney general on that topic?¶
7 8 A. Just that -- I asked him -- let me start backwards?¶
9 Q. Sure.¶
10 11 12 13 14 A. Darren and Erika alerted me that, you know, all the states and the territories had to come up with their own SORNA laws, and there was money attached to it and this was coming down the pike for the Virgin Islands.¶
15 16 17 18 19 Darren then said, you know, hey, I read through everything, and this particular portion is going to work for Mr. Epstein because he's got a, you know, private plane, whatever, and he would like the notice to be shorter. How do we go about doing that?¶
20 21 22 23 24 I talked to John about that. He says, well, have whoever -- whoever Epstein's lawyer is talk to the attorney general. And I believe at the time they asked Maria Hodge to do that in conjunction with Darren and also Erika Kellerhals.¶
1 A. Through his attorney, Maria Hodge, yes.¶
2 3 4 Q. And they've reached agreement with his attorneys on what that legislation should look like, correct?¶
5 A. Eh-hmm.¶
6 Q. Yes?¶
7 A. Yes.¶
8 MS. BOGGS: Objection, form.¶
9 10 11 Q. (By Mr. Neiman:) And the attorney general endorsed the version that reflected the input of Mr. Epstein and his lawyers, correct?¶
12 MS. BOGGS: Objection to form.¶
13 THE WITNESS: It appears so, yes.¶
14 15 Q. (By Mr. Neiman:) And then there was a state senator who needed to weigh in, correct?¶
16 A. Correct.¶
17 Q. That's Mr.¶
18 A. Correct.¶
19 Q. Is that a first name or last name?¶
20 A. Senator¶
21 22 Q. Senator . He's the senate president?¶
23 24 A. I think he was the senate president at the time, yes.¶
1 2 3 Senator said this morning that he would accept the amendments and introduce them tomorrow. Do you see that?¶
4 A. Yes.¶
5 Q. How did you know that?¶
6 7 8 9 10 11 A. I think I called him and I asked him if he got everything -- if he got this, and he said, yeah, yeah. And now I can't remember whether I called him or I saw him at the seaplane shuttle or something, and I brought it up and he said, II, yeah, I saw everything and it's fine with me.¶
12 13 14 15 16 Q. Got it. So you had a conversation, a direct one-on-one conversation with Senator where he confirmed that he was okay with the version that had been worked out between the attorney general's office and Mr. Epstein's lawyers?¶
17 18 19 20 21 A. Yeah. I told him that Maria Hodge wrote something that was amending it, and that -- and he said as long as the AG was fine with it. I said, it appears that he is, and he said, okay, well, let's bring it to the senate floor.¶
22 23 Q. And there came a time when Senator changed his mind?¶
24 25 A. Yeah. He had no intention of making any changes.¶
1 2 Q. Or he did something that was different from what he told you, is that fair?¶
3 A. It was par for his course.¶
4 5 Q. Okay. But am I correct that he told you one thing and then did something else?¶
6 A. Correct.¶
7 8 9 Q. And what he told you was he was okay with what had been worked out between the attorney general and Mr. Epstein, correct?¶
10 11 12 13 14 A. In retrospect at the time, I realized that he probably read anything. He was just like, yeah, yeah, yeah. And then when it came down to the senate and he did read it, he was he just wanted to go back to the way it was before.¶
15 Q. Which --¶
16 17 A. And also I don't think the AG really pushed it either.¶
18 Q. Do you know that or you're guessing?¶
19 20 A. No. I'm pretty sure that the AG did not push it either.¶
21 Q. How do you know that?¶
22 23 24 A. I just remember that, that he was not - you know, he was fine either way, that if -- if -- if it went as original, he was fine with it.¶
1 2 A. That we shouldn't make -- necessarily make any special arrangements for anyone.¶
3 4 5 Q. So there was a process of working out a deal with the attorney general's office that the attorney general signed off on, correct?¶
6 A. Eh-hmm.¶
7 Q. Yes?¶
8 A. Yes.¶
9 10 Q. But he didn't push for it with the legislature. Is that what you're saying?¶
11 A. Correct.¶
12 13 14 Q. Okay. And then you write, you send all this news to Mr. Epstein and say, "Please call me when you have a moment." Do you see that?¶
15 A. Yes.¶
16 Q. Did you talk to Mr. Epstein about it?¶
17 18 A. I probably did and just told him what happened.¶
19 20 Q. Okay. Let's take a look at do you remember what his reaction was?¶
21 A. To this?¶
22 Q. Yeah.¶
23 A. I don't recall what his reaction was, no.¶
24 25 Q. Okay. Let's take a look at another document which may help. 42.¶
1 off the improvements on the house, right?¶
2 A. Yes.¶
3 4 Q. Okay. So that's one example. Didn't you also ask him to contribute to a reception for --¶
5 A. Yes.¶
6 Q. -- your husband?¶
7 A. Yes. You. You said campaign.¶
8 Q. Okay. I'm just asking the question.¶
9 10 A. I know. And I'm just answering the question specifically what you're asking me.¶
11 12 Q. Well, you did ask him to raise money for a political event, State of the Territory reception?¶
13 A. Yes.¶
14 15 Q. Okay. And Mr. Epstein contributed to that event?¶
16 A. He did.¶
17 Q. How much did he give?¶
18 A. I do not recall.¶
19 Q. Okay. Let's take a look. 131.¶
20 21 (Deposition Exhibit No. 44 was marked for identification.)¶
22 23 24 Q. (By Mr. Neiman:) 131 is an email exchange between you and Mr. Epstein, Subject: Fundraising Question. You see that?¶
1 2 3 4 Q. And you indicate in your email to Mr. Epstein at 10:51 a.m. on January 24th, 2014, that you are fund raising for the governor's final State of the Territory reception, correct?¶
5 A. Correct.¶
6 Q. That's a political event.¶
7 A. Yes.¶
8 Q. And you needed $35,000 to fund that event?¶
9 10 A. Well, yeah, I needed 35,000, we had raised 15, and we wanted to match the other 15.¶
11 12 Q. All right. So you're asking him if he would contribute $15,000 to this political event?¶
13 A. Correct.¶
14 Q. For the benefit of your husband?¶
15 A. Yes.¶
16 Q. And Mr. Epstein agreed to do that?¶
17 A. Yes.¶
18 19 20 Q. Okay. And then let me show you next -- do you recall asking Mr. Epstein to contribute to the Democratic Party?¶
21 22 A. I may have. I don't -- you'd have to jog my memory.¶
23 Q. Your husband was a Democrat, correct?¶
24 A. Yes.¶
1 funds for the Democratic Party, true?¶
2 3 A. Didn't seem to help him at the time, but, yes.¶
4 5 Q. Okay. I'll ask the court reporter to mark the next document, Exhibit 45.¶
6 7 (Deposition Exhibit No. 45 was marked for identification.)¶
8 9 10 Q. (By Mr. Neiman:) Exhibit 45 is another email exchange with Jeffrey Epstein, this one in October 2014, correct?¶
11 A. Eh-hmm.¶
12 13 14 15 Q. And you asked Mr. Epstein in the middle of the page, "How much would you like to give to the St. Croix District Democratic Party?" Do you see that?¶
16 A. Eh-hmm.¶
17 Q. And he says, "15K."¶
18 A. Yeah.¶
19 20 Q. Do you recall any other donations that Mr. Epstein made to the Democratic party?¶
21 A. This one is not on behalf of John.¶
22 Q. Okay.¶
23 A. This is not solicited on behalf of John.¶
24 25 Q. Well, it's -- do you recall any other contributions to the Democratic party that you asked¶
1 Mr. Epstein to make other than this one?¶
2 3 A. You'd have to refresh my memory. I'm sure you have other emails, so refresh my memory.¶
4 5 Q. Do you recall asking him to contribute to particular Democratic candidates?¶
6 A. Yeah, I always did.¶
7 8 9 Q. And how about Stacey Plaskett in particular? Do you remember asking Mr. Epstein to contribute to her campaign?¶
10 A. Yeah, I did.¶
11 Q. Why did you do that?¶
12 A. I liked her.¶
13 14 Q. All right. I'll show you another document I'll ask the court reporter to mark Exhibit 46.¶
15 16 (Deposition Exhibit No. 46 was marked for identification.)¶
17 18 19 Q. (By Mr. Neiman:) All right. This is an email exchange between you and Jeffrey Epstein on June 19th, 2014, correct?¶
20 A. Yes.¶
21 22 23 Q. All right. And you told Mr. Epstein that his help was needed to try to get Stacey Plaskett elected to congress. Do you see that?¶
24 A. Eh-hmm.¶
1 2 3 4 Q. All right. And so you told Mr. Epstein that Shawn needed to be defeated and that Stacey was a friend, and asked if any of his friends would give to her campaign.¶
5 Do you see that?¶
6 A. Eh-hmm.¶
7 8 Q. Why were you asking for contributions from the friends instead of from Mr. Epstein personally?¶
9 A. Don't I ask him for it, too?¶
10 THE REPORTER: I'm sorry.¶
11 12 THE WITNESS: I said am I -- aren't I asking him in this for him, too, to give?¶
13 14 15 Q. (By Mr. Neiman:) Do you read the sentence, "Do you think any of your friends would give to her campaign," as a request for Mr. Epstein to give?¶
16 17 A. I'm reading this as you, your friends. That's how I'm reading this.¶
18 19 Q. So, you thought you were asking Mr. Epstein in his email whether he or any of his friends --¶
20 A. Or any of his friends, yeah.¶
21 22 23 Q. Okay. Why were you asking him to give to Ms. Plaskett if you didn't ask him to give to your husband's campaign?¶
24 25 A. I just never I'm -- I was notoriously bad about asking anybody for John's campaign.¶
1 against.¶
2 3 Q. Got it. And then Mr. Epstein writes back to you, "I'm sure darren rich bella ana would."¶
4 Do you see that?¶
5 A. Yes.¶
6 7 Q. So he's identifying four employees of his who he thought could give to the campaign, correct?¶
8 A. Yes.¶
9 10 Q. And you say, "Ok, should I ask them?" And he said, "Yes, individually." Do you see that?¶
11 A. Yes.¶
12 13 Q. And did you go ask -- out and ask each of them?¶
14 A. I think more than likely I did, yes.¶
15 16 Q. And when you did that, did you let them know that, you know, Mr. Epstein wanted them to give?¶
17 A. Yeah.¶
18 19 Q. And that was, I take it -- you had to let them know that so that they would do it.¶
20 21 22 A. I didn't want them to think it was me. It is not something I am comfortable with, so it was easier for me to say Mr. Epstein said.¶
23 24 25 Q. Understood. And were they all willing to give once they heard that this is what Mr. Epstein wanted?¶
1 A. Yeah.¶
2 3 4 Q. All right. Do you remember also asking Mr. Epstein to give $13,000 to the Democratic Party for Ms. Plaskett's benefit?¶
5 6 A. Yes. I think that was on behalf of Erika as well.¶
7 Q. Did he agree to do that?¶
8 A. I don't recall.¶
9 Q. All right.¶
10 A. What year was that?¶
11 Q. Do you recall in 2014 making that request?¶
12 A. No, I don't.¶
13 Q. All right. How about¶
14 A. go ahead.¶
15 Q. I'm sorry, I didn't mean to cut you off.¶
16 A. That's fine.¶
17 Q. What were you going to say?¶
18 19 20 A. No, I just said I know that there was a donation later than that that he made that was rejected by the Democratic Party.¶
21 Q. When -- okay. I'm sorry.¶
22 THE WITNESS: Did you hear what he said?¶
23 THE REPORTER: Yes.¶
24 25 Q. (By Mr. Neiman:) Yeah. Okay. When did you hear that?¶
1 2 3 A. I think that was -- trying to think of the years that she ran. So she runs every two-years, so it might have been 2018¶
4 Q. Okay.¶
5 A. And --¶
6 Q. What did you hear?¶
7 8 9 10 11 A. I didn't know. I didn't know anything about the payment, but then I heard in the office, it was sort of a hubbub and Richard called down and was like they're returning his money and then I think it became a story.¶
12 13 14 15 16 17 And Rich said he got yelled at by Jeffrey about, you know, why this money was sent, and Jeanne, who worked in the office, said, you know, Cecile, the instructions were explicitly said to send the money to, you know, to this, so why is everybody upset at me?¶
18 Q. Right.¶
19 20 21 A. And I said, I don't know. Sorry about that, but, you know, they returned the money and that was the end of it.¶
22 THE REPORTER: They were --¶
23 24 THE WITNESS: They returned the money and that was the end of it.¶
1 understanding as to why the Democratic party --¶
2 A. Yeah, because --¶
3 Q. I'm sorry, just let me finish the question.¶
4 Just so that she can do her job. That's all. I know¶
5 you anticipate what I'm asking you.¶
6 Did you have any understanding of what¶
7 the Democratic Party decided not to accept the¶
8 money from Mr. Epstein?¶
9 A. Because he was a registered sex offender.¶
10 Q. Did the fact that the Democratic Party¶
11 wouldn't take his money give you any concern about¶
12 whether you should continue?¶
13 A. Yes, I was concerned that they were¶
14 concerned, yeah.¶
15 Q. Did you do anything about it?¶
16 A. No, I didn't do anything about it.¶
17 Q. Do you remember Mr. Epstein donation¶
18 $75,000 to a Super PAC for Mr. Mapp?¶
19 A. No -- yeah.¶
20 Q. Yeah?¶
21 A. I don't recall that.¶
22 Q. Okay. Let me show you a document which I¶
23 shall ask the reporter the mark as Exhibit 47.¶
24¶
1 2 (Deposition Exhibit No. 47 was marked for identification.)¶
3 4 5 6 Q. (By Mr. Neiman:) All right. You see there an email from Mr. Epstein to you in September of 2016 asking the check be prepared for Mr. Mapp's Super PAC for $75,000?¶
7 A. Yeah.¶
8 Q. You see that?¶
9 A. Eh-hmm.¶
10 Q. Do you remember what this Super PAC was?¶
11 12 A. I don't -- because I don't -- I don't cut checks.¶
13 Q. Eh-hmm.¶
14 15 16 A. I think he -- I see Rich is on here. He's got Governor Mapp on here. So Rich would have been the one to cut the check.¶
17 Q. Got it. And so you're not sure who it was?¶
18 19 A. No, I wouldn't. I, in all honesty, wanted to know as little as possible about Mapp as possible.¶
20 Q. Understood.¶
21 22 23 MR. TEAGUE: Could we take a break in about five minutes? I need to take a restroom break, too.¶
24 MR. NEIMAN: Absolutely.¶
1 2 Internal Revenue, they would deem it as like a hotel because he had so many buildings.¶
3 Q. Eh-hmm.¶
4 5 6 7 A. Separate buildings, and we had to convince them that it wasn't -- it wasn't a hotel. And he - and also he would bring in so many, like, tons of furniture. Just a lot of supplies.¶
8 Q. Eh-hmm.¶
9 10 11 12 13 14 A. And so through Customs and excise or whatever. And so they just kept saying, II, this has got to be a hotel, or a small boutique hotel. So we'd always have to -- you know, Darren or Erika would have to write a letter saying this not a hotel, it's a home.¶
15 16 17 Q. Okay. Was part of what was raising all those questions the number of people who were coming to the island?¶
18 19 20 21 22 A. No. It had more to do with the fact that why are you bringing in all this -- all this stuff that comes through Tropical and has to be cleared through Customs, all his trees, all his -- all construction supply -- materials.¶
23 24 25 Q. Okay. Do you remember there being times when the government of the Virgin Islands itself turned to Mr. Epstein as a potential source of cash?¶
1 2 A. I vaguely remember him asking about collateralization or something, but --¶
3 Q. What do you remember about that?¶
4 5 6 A. Just him asking if I could ask John about how one goes about collateralizing a loan to the government.¶
7 8 9 Q. So the idea was that Mr. Epstein could loan the government of the Virgin Islands cash in exchange for the government posting properties as security?¶
10 A. Yes. That's the gist of it, yes.¶
11 Are we done with this?¶
12 13 14 Q. Yeah. All right. So take a quick look at this document, which we'll have the court reporter mark as Exhibit 50.¶
15 16 (Deposition Exhibit No. 50 was marked for identification.)¶
17 18 19 20 21 Q. (By Mr. Neiman:) So you'll see at the bottom of the first page of Exhibit 50, there's an email from Mr. Epstein to you that says the government -- "The vi government is desperate for cash." Do you see that?¶
22 A. Yes.¶
23 24 25 Q. And then he asks, "Does John know of any asset they might have that I can use as collateral. Islands, etc." Do you see that?¶
1 A. Yes.¶
2 3 Q. Where did Mr. Epstein get the idea that Virgin Islands government was desperate for the cash?¶
4 5 A. It wasn't from my husband because my husband was not governor at the time.¶
6 7 8 Q. Ah, this is after your husband left. Do do you have any idea where he got the idea that the government was desperate for cash?¶
9 10 A. Well, do you want me to make an assumption?¶
11 Q. Tell me what you think?¶
12 13 14 15 16 A. What I think is that he was probably speaking to Governor Mapp, and Governor Mapp probably said we only have X amount of money left in the coffers to pay, you know, payroll, et cetera, and I need -- we need cash. And --¶
17 18 MR. TEAGUE: I just want to object to the extent that this calls for speculation.¶
19 But you can continue to answer.¶
20 Q. (By Mr. Neiman:) You can continue.¶
21 22 23 A. And, you know, he turned to Mr. Epstein and said, you're a finance guy, you know, could you help me out?¶
24 25 Q. The idea being maybe you, Mr. Epstein, could loan me some money?¶
1 MR. TEAGUE: Same objection.¶
2 3 4 THE WITNESS: Sorry, I didn't mean to shake my head. I am making that assumption, yes.¶
5 6 7 Q. (By Mr. Neiman:) That's what you understood from this email exchange you had with Mr. Epstein?¶
8 9 A. Yes. Well, I didn't think that he'd want to take property for $50 million just for nothing.¶
10 THE REPORTER: He wouldn't --¶
11 12 13 14 15 THE WITNESS: He wouldn't want to take -- wouldn't want to take property as collateralization just for nothing. And he starts out the email by saying the V.I. government is desperate for cash.¶
16 17 18 19 Q. (By Mr. Neiman:) Right. So as you understood it from your communications with Mr. Epstein, the problem was that the government was desperate for cash, correct?¶
20 A. Correct.¶
21 22 MS. BOGGS: Objection. Calls for speculation.¶
23 24 25 Q. (By Mr. Neiman:) And as you understood from your discussions with Mr. Epstein, the potential solution was for Mr. Epstein to provide some cash in¶
1 exchange for islands as collateral?¶
2 A. Or land as collateral, yes.¶
3 4 5 Q. Okay. And being short of cash is kind of a perpetual problem for the Virgin Islands government, fair?¶
6 MS. BOGGS: Objection, speculation.¶
7 MR. TEAGUE: Same objection, form.¶
8 9 THE WITNESS: It was until about three or four years ago, yes.¶
10 11 Q. (By Mr. Neiman:) What happened three or four years ago?¶
12 A. COVID.¶
13 14 Q. Ah. And that was good for the Virgin Islands?¶
15 A. Very good.¶
16 MR. TEAGUE: Objection, form.¶
17 THE WITNESS: ■.¶
18 MR. TEAGUE: You can answer.¶
19 Q. (By Mr. Neiman:) You can answer.¶
20 A. Yes. Seemed very good, yes.¶
21 22 Q. Okay. Prior to COVID, for a long time the Virgin Islands had been strapped for cash?¶
23 A. Well, since the --¶
24 MS. BOGGS: Objection. Speculation.¶