EXHIBIT 119¶
1 2 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶
3 4 GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, CASE NO.¶
5 1:22-CV-10904 Plaintiff, -JSR¶
6 v.¶
7 JPMORGAN CHASE BANK, N.A.,¶
8 Defendant/Third Party Plaintiff.¶
9¶
10 JPMORGAN CHASE BANK, N.A.,¶
11 Third Party Plaintiff,¶
12 v.¶
13 JAMES EDWARD STALEY,¶
14 Third Party Defendant.¶
15 CONFIDENTIAL - ATTORNEYS' EYES ONLY¶
16 May 3, 2023¶
17 18 19 20 21 22 Videotaped deposition of WILLIAM D. LANGFORD, taken pursuant to notice, was held at the law offices of Boies Schiller Flexner LLP, 55 Hudson Yards, New York, New York, and remotely, beginning at 9.37 a.m., on the above date, before L. Gray, a Registered Professional Reporter, Certified Shorthand Reporter, Certified Realtime Reporter, and Notary Public.¶
23 24 GOLKOW LITIGATION SERVICES 877.370.3377 ph l 917.591.5672 deps@golkow.com¶
1 asked to provide a briefing to JPMorgan's board or a board committee that included discussion of Jeffrey Epstein?¶
A. No, I don't believe I was.¶
5 Q. And did you ever talk to the bank's operating committee about Jeffrey Epstein?¶
8 A. No, I did not.¶
Q. Do you believe -- did you lo believe, while you worked at JPMorgan, 11 that JPMorgan should have continued to provide banking services and credit to Jeffrey Epstein?¶
MR. KRAUSE: Objection.¶
THE WITNESS: Sorry. Did I believe that we should not have?¶
BY¶
Q. That they should have -- that JPMorgan should have provided banking services and credit to Jeffrey Epstein.¶
MR. KRAUSE: Objection.¶
THE WITNESS: My view was that we should exit Jeffrey¶
1 Epstein as a client.¶
BY¶
Q. Do you remember when you formed that view?¶
A. Yes.¶
Q. And when was that?¶
A. End of 2010, early 2011.¶
Q. And what prompted you to come to that opinion?¶
A. The facts and information 11 provided by Phil and Maryanne to me.¶
Q. And by Phil and Maryanne, you mean Phil DeLuca and Maryanne Ryan?¶
A. Yes. Yes.¶
Q. We all feel like we know them too, Mr. Langford.¶
And when you say "facts and information," I think is what you said, what -- what stands out in your memory about what caused you to reach the opinion that JPMorgan should not be doing business with Jeffrey Epstein?¶
A. That he pled guilty to soliciting sex with an underage girl. Epstein. I don't have patience."¶
Did you have reason to¶
believe that McCleerey was waffling?¶
A. I don't believe so, no.¶
Q. And when you say no patience¶
for this, was there something that had¶
happened that had tried your patience?¶
8 A. Not specifically, no. Exit¶
decisions are always a bit of a¶
lo challenge, generally, in a bank. And to¶
11 me it was clear what we needed to do.¶
And McCleerey had agreed, according to¶
Phil. And we needed to execute.¶
Q. Had an exit decision been¶
made about Jeffrey Epstein at this point?¶
MR. KRAUSE: Objection.¶
THE WITNESS: No, I hadn't¶
escalated it yet. We were pushing¶
it. I had ask that this be¶
redone, to push again, to say it's¶
time that we exit Epstein.¶
BY¶
Q. And who had you asked?¶