FILED UNDER SEAL¶
EXHIBIT 287¶
IN THE UNITED STATES DISTRICT COURT IN 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 MARGARITA was taken on the 26th day of May, 2023 at the Ritz-Carlton Hotel, Virgin 6900 Great Bay, Nazareth, St. Islands, between the hours of 3:50 , U.S. p.m. and 9:22 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) 777-6466¶
1 Q. And how did you inform yourself?¶
2 3 4 A. That the benefits that were received by Financial Trust, Inc. and Southern Trust, Inc. is what's under request for rebate or claim.¶
5 6 Q. So it includes both the benefits to Financial Trust and to Southern Trust Company?¶
7 A. Yes, sir.¶
8 9 Q. And it does not include benefits extended to AYH, correct?¶
10 A. That is correct, yes.¶
11 12 13 14 15 Q. And are there date restrictions on those benefits? For example, is it only a portion of benefits to Southern Trust, or only a portion of the benefits to Financial Trust, or is it all the benefits?¶
16 17 A. If there is an issue with the client, it would be all of the benefits.¶
18 19 Q. What group of individuals within EDA are responsible for extending benefits to beneficiaries?¶
20 MR. ACKERMAN: Object to form.¶
21 22 23 24 THE WITNESS: At the time, based on which time, the prior period, the board would make recommendations to the Governor and the Governor had the final decision.¶
1 ranges was that, the arrangement?¶
2 3 A. That would be from 1998 to 2013, thereabouts.¶
4 5 Q. And then after the change, who was responsible for extending benefits?¶
6 7 A. The beard of directors of the Economic Development Authority Commission.¶
8 9 Q. And the change was they no longer required the approval of the Governor?¶
10 A. That is correct.¶
11 Q. Why was that change made?¶
12 13 MR. ACKERMAN: Object to form. Scope. You can answer.¶
14 THE WITNESS: Okay. Based on the --¶
15 16 17 18 19 based on the changes in the law was to facilitate the process of applicants that were stuck in the pipeline for some time. That's my exposure to discussions when the legislative amendments went down.¶
20 21 22 23 24 Q. (By Mr. O'Laughlin:) So there was essentially a backlog in the governor's office. And so to clear that backlog, it was deemed that the Governor would no longer be the final sign-off so that they could expedite those. Is that right?¶
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Q. (By Mr. O'Laughlin:) And where are the unique situations or the qualitative conditions that would be different?¶
MR. ACKERMAN: Let me just do this in order to avoid interrupting each time. I'm just gonna have a standing objection to scope on this sort of general line of questioning, but I'm not instructing the witness not to answer.¶
THE WITNESS: Okay. So we have hotels; we have manufacturers; we have service industries. And it may be based on what that particular product is or service that they're bringing to the industry, whether it's new, whether we have skill sets here in the territory. We dictate some of those things, whether the company is bringing in needed services. So if we had a manufacturer of, for example, renewable energy products, which is we're looking towards moving in that direction in the economy, they weight it in terms of the qualitative impact may be different from, based on each company and what they bring to the table.¶
1 2 individuals involved in making the decisions about which entities are extending benefits?¶
3 MR. ACKERMAN: Object to form.¶
4 5 6 THE WITNESS: The board of directors currently has the final decision. Prior, the governor had the final decision.¶
7 8 9 Q. (By Mr. O'Laughlin:) Who were the board of directors involved in the grant of benefits to Southern Trust Company?¶
10 11 12 13 A. I can't remember exactly who all was sitting at each time, but there were different board members at different times. I would have to go back to the transcript.¶
14 Q. Are there some you could remember?¶
15 16 17 MR. ACKERMAN: I'm sorry, you spoke over each other there. Can you repeat that question, please?¶
18 19 20 21 THE WITNESS: No. I said I would have to go back to the transcript, which would have the names of those board members on the transcript.¶
22 23 Q. (By Mr. O'Laughlin:) Okay. You can't remember a single board member?¶
24 25 A. I can remember board members over the years. Jose Penn was one of our board members that 1 companies over an extended period of time.¶
2 3 4 Q. But the answer says only one company. It says, "The entity is Southern Trust Company." Correct.¶
5 MR. ACKERMAN: Object to form.¶
6 Argumentative.¶
7 8 9 THE WITNESS: First, the business was known as Financial Trust. So I'm assuming that it's also inclusive of Financial Trust.¶
10 11 12 13 14 Q. (By Mr. O'Laughlin:) So the benefits that form the basis of the government's claim for damages in this action are not limited to just Southern Trust Company? They include both Southern Trust Company and Financial Trust Company?¶
15 A. That is my understanding, sir.¶
16 17 Q. Okay. And why is the total 80.5 million if it's across both companies?¶
18 19 20 21 MR. ACKERMAN: Object to form. And this is -- this is not a topic, Andy. You're asking her why something says something in an interrogatory response? That's privileged.¶
22 23 MR. O'LAUGHLIN: This is the core of the topic.¶
24 MR. ACKERMAN: No.¶
1 approved in these certificate of tax incentives.¶
2 3 MR. ACKERMAN: Be sure to keep your voice up.¶
4 5 6 7 8 Q. (By Mr. O'Laughlin:) And is part of the compliance function and the application function within EDC to verify that Financial Trust Company actually did what it claimed to be doing in this paragraph?¶
9 10 11 A. If it's a startup company, we would go based on what historical information we would have gotten on the background.¶
12 13 14 15 16 17 18 If the company was in prior operation or the owner had experience in the particular market or field, and so that's where, from the application standpoint. Once they're in operation, as part of the site visit, the compliance officers would review records or contracts to see that they were engaged in similar-type activities.¶
19 20 21 Q. Okay. And what sorts of contracts were reviewed to verify the Financial Trust Company was actually engaged in this business?¶
22 23 24 A. The compliance officer assigned would have the specifics, but usually it would be engagements between the client and the beneficiary.¶
1 2 3 modification. They also committed to contribute the salary of that person to the work force development fund.¶
4 5 Q. (By Mr. O'Laughlin:) A salary of what person?¶
6 A. The reduction from 11 to 10 employees.¶
7 8 9 Q. And what did the reduction from 11 to 10 employees have to do with the company's extension application?¶
10 11 12 13 14 A. It included a modification of its employment numbers. And so in order to ensure that there was no loss in commitments, there was an agreement that they would contribute the salary to the Workforce Development Fund.¶
15 16 Q. Okay. What was the reason FTC gave for wanting another five years of benefit?¶
17 18 MR. ACKERMAN: Objection, scope. You can answer.¶
19 20 21 22 23 24 25 THE WITNESS: Any applicant doesn't have to give a reason for wanting it. The law provided for an applicant to apply and the board could look at the parameters to determine whether the applicant met the compliance with their previous contract, and also in negotiating that extension what¶
1 2 additional commitments and benefits that the territory may receive.¶
3 4 5 6 7 8 9 Q. memory, kind of reason. (By Mr. O'Laughlin:) Okay. So FTC, to your didn't provide, like, a look, we're in this economic hardship or some other concrete They just said we want to extend our benefits, and the board said, well, we find them to be in compliance, so they're eligible for extension. Is that right?¶
10 11 12 A. transcript that would It's not as cut and dried as such. The would define all the specific discussions have had on record.¶
13 14 Q. transcript And do you know what the date of that would be?¶
15 16 A. It would be the date of the decision meeting that's outlined in the document before you.¶
17 Q. And is that a public transcript?¶
18 19 20 21 A. I believe -- public hearings are public transcripts. Executive sessions are closed transcripts. But I believe the transcripts were provided as part of the request for information.¶
22 23 24 Q. But do you know whether -- so you think they've been produced in this case, but you don't whether they were public at the time? Is that right?¶
1 2 3 made, once they go into executive session, is closed meeting. So they would just report out on the decision in the open meeting section.¶
4 5 6 7 But for the public hearing where the client represents and speak on the merit of their application, that would be an open meeting and available to the public at the time, yes.¶
8 9 Q. Do you see the paragraph that starts with "by letter dated April 4, 2012"?¶
10 A. Yes.¶
11 12 13 Q. And it goes on to say that Erika Kellerhals notified the V.I. EDC that they will no longer take benefits as of March 23, 2012, correct?¶
14 A. Correct.¶
15 Q. Who is Erika Kellerhals?¶
16 17 A. She was the legal representative on record for Financial Trust Company.¶
18 19 Q. And why did Financial Trust Company no longer take benefits as of March 23, 2012?¶
20 MR. ACKERMAN: Objection, scope.¶
21 THE REPORTER: As of March --¶
22 MR. O'LAUGHLIN: 23rd, 2021.¶
23 24 MR. ACKERMAN: Objection. Scope and form?¶
1 2 3 4 says we can keep going. The defendant attorney says we're nearing the time for a break, but not necessarily. We don't have to break right now.¶
5 THE WITNESS: I'm good.¶
6 VIDEOGRAPHER: Ask the witness.¶
7 THE WITNESS: I'm good.¶
8 VIDEOGRAPHER: All right.¶
9 10 11 12 13 MR. O'LAUGHLIN: We'll keep going a little longer. I appreciate we're getting later in the day, so folks should shout if they need a bathroom break or food or whatever it is.¶
14 15 MR. ACKERMAN: We could check for other reasons, also.¶
16 MR. O'LAUGHLIN: Noted.¶
17 18 MR. ACKERMAN: You are allowed to laugh on the record. All right. Go ahead.¶
19 20 Q. (By Mr. O'Laughlin:) Okay. Let's enter Tab 48 as the next exhibit.¶
21 22 : Tab 48 is in the chat as Exhibit 14.¶
23 24 (Deposition Exhibit No. 14 was marked for identification.)¶
1 document?¶
2 A. It's up. I'm reading.¶
3 Thank you. Yes.¶
4 Q. What is it?¶
5 6 7 A. It is communication between Mr. Paul Fleming, Attorney Stacey Plaskett. Copied on there was Clouden, the board chairman, and myself.¶
8 9 10 11 12 13 14 And he was providing ratios that was taken from the cost benefit model, the results of those ratios. I responded basically summarizing that just given the unfavorable ratios itself without the other part doesn't give the full picture to anyone, so it can be misleading, and that's in the summary of what I was trying to say.¶
15 16 17 18 19 20 21 And then she said that she would be disseminating the information and will redact the none for your required information. So it may have been as a result based on what she is saying, for your, someone would have requested information from the record. And it does say the subject, press inquiry.¶
22 23 Q. And this is a June 28, 2011 email chain, correct?¶
24 A. Correct.¶
1 2 A. He would have been the director of Applications at that time.¶
3 Q. And who is Stacey Plaskett?¶
4 5 A. She would have been the legal counsel for the Authority.¶
6 Q. Who is Clouden?¶
7 A. The chief executive officer.¶
8 Q. Who was Albert Bryan?¶
9 A. The chairman of the board.¶
10 11 Q. Well, you mentioned the cost benefit model, what is that?¶
12 13 14 15 16 17 18 19 A. For companies that apply for benefits, they are required to file a five-year projection that reflects their anticipated revenues and expenses over the initial five years of 7benefits, and based on that, we put it into our model so that we can see what would be the outputs if they operated at that level. And so basically that's what the cost benefit model is.¶
20 21 22 It also shows us based on what would have been the taxes due, what the exemption value would be.¶
23 24 25 Q. And how does the cost benefit model bear on the EDC's decision on whether or not to extend benefits?¶
1 2 MR. ACKERMAN: Objection, scope. You can answer.¶
3 4 5 6 7 THE WITNESS: Yes. It is part of their model that we use but there are varying factors and other additional factors that would lead to a decision. Just not solely on the cost benefit analysis.¶
8 9 Q. (By Mr. O'Laughlin:) When you wrote these ratios are not favorable, what did you mean?¶
10 11 12 13 A. In and of itself, meaning that if someone reads the ratios without having full context of the information, that they would tend to interpret it that their findings are all negative.¶
14 Q. What would not favorable ratios mean?¶
15 MR. ACKERMAN: Object to form.¶
16 17 18 19 20 THE WITNESS: Not favorable ratios, for most of -- for our cost benefit model, in order for you to be able to get the taxes foregone and taxes -- taxes received by the beneficiary, it must have numbers in there.¶
21 22 23 24 However, some of the -- some of the factors that would guide whether the cost benefit is favorable or not favorable is whether the company was even operating in the territory.¶
1 2 3 were removing them off of the tax roll, then the projections would be more realistic in terms of the cost benefit ratio.¶
4 5 6 7 8 9 But if a company was not existing in the territory, there was no tax dollars being paid to the territory. So where it says, taxes foregone, it is not realistically foregone because the company would not have been in the territory and be in a tax-paying company.¶
10 11 Q. So what did you mean exactly when you said the ratio is not favorable?¶
12 13 MR. ACKERMAN: Objection. Asked and answered. Scope.¶
14 15 16 17 18 THE WITNESS: So, if one is the base line and it's -- you said we're going to have even numbers, it will be one-to-one, we will start off first to say that -- what you're giving and what you're receiving is equal.¶
19 20 21 22 23 So anything below one would be looked at as not favorable. But looking at just the cost benefit ratio is not all because we have to also look at value added to the gross territorial product and other factors.¶
24 25 So just given the ratio does not explain the whole analysis, and also does not include¶
1 2 other qualitative factors that we would consider on an applicant.¶
3 4 5 6 7 Q. So, just to be clear, when you say one to one, that means for every dollar in tax incentive given to the beneficiary, they are returning one dollar back to the USVI economy. That would be a one-to-one ratio?¶
8 A. Correct.¶
9 10 11 12 Q. And so if the ratio was say two to one, that means that for every dollar in incentive given, they're actually returning two dollars back to the USVI economy, correct?¶
13¶
14 15 THE WITNESS: That would be the primary basis for the interpretation of the ratios.¶
16 17 18 19 20 21 However, based on the circumstance, if the company is not operating in the territory, the dollar amount of taxes foregone will not be realistic as that company was not paying and that company is coming on to the program as a non-taxpayer.¶
22 23 24 4. (By Mr. O'Laughlin:) So I understand that, but that's not my question. I'm just trying to understand very basically --¶
MR. ACKERMAN: Objection, scope.¶
1 John P. de Jongh.¶
2 3 4 Q. And if you scroll down to the very bottom of the document, there's a signature and an approval date of May 31, 2013. Who is on that signature line?¶
5 A. Approved, John P. de Jongh, Jr., Governor.¶
6 7 Q. So the approval here was by Governor John de Jongh, correct?¶
8 A. Correct.¶
9 10 Q. And Southern Trust employed Cecile de Jongh, correct?¶
11 A. Correct.¶
12 13 Q. What's the relationship between Cecile de Jongh and Governor John de Jongh?¶
14 A. It's publicly known that it is his wife.¶
15 16 17 Q. And was there any concern by EDC that Governor John de Jongh was signing off on benefits extended to the company managed by his wife?¶
18 MR. ACKERMAN: Object to form.¶
19 20 21 THE WITNESS: I cannot speak for the Board members, but I did not hear any discussion as such.¶
22 23 24 25 Q. (By Mr. O'Laughlin:) So you are designated as a corporate designee on the benefits extended to Southern Trust. You're also designated on investigations into Epstein and his business entities.¶
1 2 3 companies for an 18-year period, if there was something new, mathematician employees, presumably she would be able to identify that, correct?¶
4 MR. ACKERMAN: Object to form.¶
5 6 THE WITNESS: I do not recall that there was a specific job title of mathematician.¶
7 8 9 10 But yes, if there was a new title on the employment report, she would have recognized it because they would have to report any new hires and identify them.¶
11 12 13 14 Q. (By Mr. O'Laughlin:) So Southern Trust passed the site visit to establish that it had transitioned over to doing the DNA work, is that right?¶
15 16 17 18 19 20 A. Based on her records she saw that there were servers and equipment that wasn't purchased based on their financial reporting, and that she was shown a program that they were developing or had developed for the DNA sequencing that they were doing.¶
21 THE REPORTER: The DNA?¶
22 THE WITNESS: Sequencing.¶
23 24 25 And if I may put a caveat, this is my conversation with Sandra Bess after we were doing our final report, as I 7was not the¶
1 2 director of Compliance at the time that she did the site visit.¶
3 4 5 Q. (By Mr. O'Laughlin:) So there were no red flags identified in the 2018 operations of Southern trust as a DNA company by the EDC, correct?¶
6 7 A. Not that was communicated to me or that I saw in the records.¶
8 9 MR. O'LAUGHLIN: Let's enter Tab 59 as the next exhibit.¶
10 11 : Tab 59 is in the chat as Exhibit 24.¶
12 13 14 THE WITNESS: Tab 59 is downloaded. (Deposition Exhibit No. 24 was marked for identification.)¶
15 16 Q. (By Mr. O'Laughlin:) So if you scroll to the second page.¶
17 A. Eh-hmm.¶
18 19 20 21 22 Q. It's an email from Ms. Sandra Bess to First Lady de Jongh saying she's in the process of completing a compliance review of Southern Trust's tax incentive certificate and would like to schedule a visit.¶
23 24 25 And she says that, "At that site visit, procurement and other documentation required to properly complete the compliance record will be¶
1 2 A. The year before or so that he was -- had served his sentence in the Florida case.¶
3 Q. And that was what prompted the inquiry?¶
4 MR. ACKERMAN: Object to form.¶
5 THE WITNESS: Yes.¶
6 7 Q. (By Mr. O'Laughlin:) And what was the nature of the Florida conviction?¶
8 9 A. Sexual -- if I recall, with an underage female and prostitution.¶
10 Q. So EDC was aware of those charges in 2011?¶
11 A. Yes.¶
12 13 Q. And they were aware that Epstein pled guilty to those charges?¶
14 A. Yes.¶
15 Q. How was that fact evaluated by EDC?¶
16 17 18 A. There was no evaluation as it relates to the specific business operation that was approved for benefits.¶
19 20 21 Q. So Epstein's conviction for procuring a minor for sex had no bearing on the EDC's analysis of extending him tax benefits?¶
22 23 24 A. No. It was not based on our law connected to the business activity. We had no findings of that.¶
1 2 that once we receive request for information, that we notify the client.¶
3 4 Q. (By Mr. O'Laughlin:) Were there any concerns by EDC based on this average from Newsweek?¶
5 MR. ACKERMAN: Object to form, scope.¶
6 THE WITNESS: No, not that I'm aware of.¶
7 8 Q. (By Mr. O'Laughlin:) And was any investigation undertaken in response to this request?¶
9 A. Could you repeat that?¶
10 11 Q. Was there any investigation into Epstein undertaken in response to this inquiry?¶
12 13 14 15 A. No. All the inquiries was relative to the application. We tied into his conviction which did not have anything directly to do with the business operation.¶
16 17 MR. O'LAUGHLIN: Let's enter Tab 39 as the next exhibit.¶
18 19 : Tab 39 is in the chat as Exhibit 28.¶
20 21 (Deposition Exhibit No. 28 was marked for identification.)¶
22 23 MR. ACKERMAN: Counsel, are you asking questions about the top part of this email?¶
24 25 MR. O'LAUGHLIN: No, I am going to focus on the bottom. : Tab 43 is in the chat as Exhibit 31.¶
(Deposition Exhibit No. 31 was marked for identification.)
¶
MR. ACKERMAN: Objection to the scope on this line of questioning.¶
Q. (By Mr. O'Laughlin:) So the bottom email in this chain is a January 27, 2016 email from Semele to Jennifer Nugent- and Tracy Bhola, with the importance designated as high, and sending immediate inquiry received from reporter from the Guardian inquiring about Southern Trust Company and seeking information regarding a decision meeting held on January 23rd, 2014.¶
Do you recall in your function with any EDC receiving notice of this inquiry?¶
A. There were several inquiries from different medias that I was copied on, and this one I was copied on the response going from the assistant CEO to¶
Q. What was your understanding of why EDC was getting all of these inquiries?¶
MR. ACKERMAN: Object to form, scope. THE WITNESS: The application for
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1 2 hearing for board decision and the owner is Jeffrey Epstein, hence, the inquiries.¶
3 4 5 Q • (By Mr. O'Laughlin:) Why would the fact that the owner was Jeffrey Epstein generate all this interest?¶
6 7 MR. ACKERMAN: Object to form, scope. Speculation. Foundation.¶
8 9 10 11 12 13 14 15 THE WITNESS: I would not know specifically what the requesters were thinking, but I know in some of the communications, it was really around whether or not he was eligible for exemptions, or whether or not the fact that he was charged in a criminal offense whether the company should be eligible for exemptions.¶
16 17 Q. (By Mr. O'Laughlin:) And what was the EDC's position on those questions?¶
18 MR. ACKERMAN: Objection, form. Scope.¶
19 20 21 22 23 THE WITNESS: If the criminal activity was not connected to the business activity, then it was two different issues. It's a personal issue versus one related to the business operation.¶
24 25 Q. (By Mr. O'Laughlin:) So EDC viewed Mr. Epstein's criminal misconduct as strictly a 1¶
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personal issue that didn't impact his business, correct?¶
MR. ACKERMAN: Object to form, scope.¶
THE WITNESS: Title 29, Chapter 12,¶
Section 722 explains what happens if there is a company that is found with any criminal offenses, or an owner, and it must be connected to the business activity.¶
Q. (By Mr. O'Laughlin:) And EDC's view is that the criminal offenses of Mr. Epstein were not connected to his business entities, correct?¶
MR. ACKERMAN: Objection to form.¶
THE WITNESS: As far as we knew at the time.¶
Q. (By Mr. O'Laughlin:) And did EDC undertake any investigation in light of all these media inquiries to evaluate whether or not the criminal activity was connected to the business entities?¶
A. Not that I'm aware of. There was no reason to believe said was connected.¶
Q. Why was there no reason to believe there wasn't a connection?¶
MR. ACKERMAN: Objection.¶
THE WITNESS: Because of the type of charge, that it was not connected to the¶
1 2 3 business operations. There was no findings that it was connected to the business operations.¶
4 5 6 7 Q. (By Mr. O'Laughlin:) So there was no reason to think that the charge of procuring a minor for prostitution was linked to any of Mr. Epstein's business activities, correct?¶
8 MR. ACKERMAN: Objection to form.¶
9 THE WITNESS: Correct.¶
10 11 MR. O'LAUGHLIN: Let's enter Tab 58 as the next exhibit.¶
12 13 : Tab 58 is in the chat as Exhibit 32.¶
14 15 (Deposition Exhibit No. 32 was marked for identification.)¶
16 THE WITNESS: I've read.¶
17 18 19 20 Q. (By Mr. O'Laughlin:) So this is a January 7th, 2015 letter sent via certified mail to Mr. Epstein by Ms. Stephanie Berry, the director of Compliance for EDA, correct?¶
21 A. Yes.¶
22 23 24 25 Q. And in the letter she writes, "Dear Mr. Epstein: Given the current media discussion surrounding principal of Southern Trust Company, the USVI Economic Development Authority requests that no 1¶
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later than January 9, 2015 an assessment of the potential impact, if any, on the business activities of Southern Trust Company as approved by the USVI Economic Development Commission be provided to the VI EDA."¶
Did I read that correctly?¶
A. Yes.¶
Q. What were the current media discussions that are referenced in this letter?¶
A. I cannot speak to what specific ones she was, but around that time, again, it was all about Jeffrey Epstein being the owner for Southern Trust Company, which was the recipient of EDC tax incentives.¶
Q. So the reference here to a principal of Southern Trust Company is a reference to Mr. Epstein, correct?¶
A. Yes.¶
Q. And USVI EDA is requesting an assessment of the impacts of these media discussions on business activities of Southern Trust, correct?¶
A. Yes.¶
Q. Did it receive such an assessment?¶
A. It would have received a response. I was not, at the time, specifically involved in the¶
1 2 compliance unit, but the record should have received a response.¶
3 Q. And do you recall what the response was?¶
4 5 A. If I recall, the response would have been from their legal counsel.¶
6 Q. Would have been, sorry, from who?¶
7 A. Their legal counsel.¶
8 9 Q. But do you recall what the substance of the response was?¶
10 A. That there was no impact.¶
11 12 Q. And did EDA agree with that response and find it satisfactory?¶
13 14 15 16 17 A. I cannot speak to EDA at that time as I am only seeing these documents -- that particular document now in reviewing for this. I have -- I was not privy to that specific conversation around the response back then.¶
18 19 Q. But this is an investigation by EDA into Southern Trust based on the media reviews, correct?¶
20 MR. ACKERMAN: Object to form.¶
21 22 THE WITNESS: It is a request for information from the director of compliance,¶
23 Ms. Stephanie Berry.¶
24 25 Q. (By Mr. O'Laughlin:) And you are designated to give testimony on investigations into Epstein and¶