## EXHIBIT 316

## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, No. 22-cv-10904-JSR

Plaintiff,

v.

JPMORGAN CHASE BANK, N.A.,

Defendant.

JPMORGAN CHASE BANK, N.A., Third-Party Plaintiff,

v.

JAMES EDWARD STALEY, Third-Party Defendant.

THE ORAL DEPOSITION OF INAIS BORQUE was taken on the 26th day of May, 2023 at the Ritz-Carlton Hotel, 6900 Great Bay, Nazareth, St. , U.S. Virgin Islands, between the hours of 9:07 a.m. and 3:33 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) 777-6466

1 than a half an hour.

2 Q. (By Mr. Ackerman:) Okay. Thank you.

3 4 Did you review documents in preparation for the deposition?

5 A. Yes.

6 7 8 Q. And did the documents you reviewed include the sex offender file material that counsel showed you during this deposition?

9 A. Yes.

10 11 12 Q. Okay. I want to ask you about the compliance checks, which is the last topic you spoke with me about.

13 14 You testified about weekly compliance checks for sex offenders. Do you recall that?

15 A. Yes, I do.

16 17 18 Q. Please explain what you mean when you are referring to weekly sex offense -- compliance check for sex offenders?

19 20 21 22 23 A. What I meant by that is now that an investigator is designated for the sex offender unit is when we apply the every -- the weekly checkups, random checkups. Doesn't have to necessarily be - it's not monitoring. It's random.

24 25 Q. Is there any rule requiring a weekly checkup of every sex offender in the Virgin Islands? 1 A. No.

2 3 Q. Okay. You said "now." For how long has that practice been in effect?

4 A. I would say 2019.

5 6 7 Q. Okay. Do you know whether prior to 2019 there were weekly checkups of sex offenders in the Virgin Islands?

8 9 10 A. I'm not sure because there wasn't an investigator designated to the sex offender unit, but they we did have the yearly checkups.

11 Q. Okay.

12 A. Which was the roundup.

13 14 Q. Explain to me -- explain to us what the yearly checkup is.

15 16 17 18 19 A. The yearly checkup is just a random checkup where we check all offenders in that one week. We just randomly pop up at their residence to make sure and confirm that they live at that residence.

20 21 Q. Okay. When you say check all offenders in one week, what do you mean by that?

22 23 A. Just randomly do compliance checks in that one week, either in St. Croix or St.

24 25 Q. Okay. And when you say either in St. Croix or St. , Mr. Epstein didn't live on the island