## EXHIBIT 310 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NUMBER: 22-CV-10904-JSR ACTION FOR DAMAGES GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff, VS. JP CHASE BANK, N.A., Defendant. > VIDEO RECORDED DEPOSITION OF SHANI A. PINNEY 30(B)(6) WITNESS TUESDAY, JULY 18, 2023 REPORTED BY: DENISE D. HARPER-FORDE Certified Shorthand Reporter (CSR) Certified RealTime Reporter (CRR) Certified LiveNote Reporter (CLR) Registered Professional Reporter (RPR) Notary Public (FLORIDA) ![](_page_1_Picture_8.jpeg) 1 THE WITNESS: About the 2 tuition being paid? 3 (BY ATTORNEY O'LAUGHLIN): 4 Q. About the relationship between 5 Governor John de Jongh, the First Lady 6 and Epstein. 7 ATTORNEY ACKERMAN: Objection 8 to form, scope. 9 THE WITNESS: I cannot recall 10 when I was first -- when I became 11 aware of these -- the relationship 12 between Epstein and the former 13 Governor. 14 (BY ATTORNEY O'LAUGHLIN): 15 Q. Did the relationship between 16 Epstein and the de Jongh family ever 17 play any role in DoJ's monitoring of 18 Epstein as a sex offender? 19 A. No. 20 Q. Did either Cecile de Jongh or 21 John de Jongh ever reach out to anyone 22 involved in sex offender monitoring at 23 DoJ regarding Epstein? 24 A. To my knowledge, no. 25 ATTORNEY O'LAUGHLIN: Let's 1 an online media search. 2 (BY ATTORNEY O'LAUGHLIN): 3 4 5 Q. And did DoJ at any time take steps to do this kind of search into Epstein? 6 7 8 9 ATTORNEY ACKERMAN: Object to form, vague, scope to the extent it's outside sex offender registration and monitoring. 10 11 12 13 14 15 16 THE WITNESS: In my position, you know, with the registry, we kept our focus primarily on what he was convicted of and assuring that he was fulfilling those obligations to register as a sex offender in the VIrgin Islands. 17 18 19 20 21 22 23 I didn't have the time to do these -- to do searches of this nature, because I was also monitoring about 70-something other offenders who had real allegations against them, you know, filed with the US DoJ -- with VI DoJ. I'm sorry. 24 (BY ATTORNEY O'LAUGHLIN): 25 Q So these allegations against 1 Epstein weren't real? 2 3 ATTORNEY ACKERMAN: Object to form. 4 5 THE WITNESS: You're asking me if they were real? 6 (BY ATTORNEY O'LAUGHLIN): 7 8 9 Q. Well, you said you were focused on the offenders with real allegations. So now -- 10 11 12 13 14 15 16 A. Okay. When I say "real," I mean that they were actually complaints filed with VI DoJ against offenders here in the Virgin Islands who were currently committing other sexual offenses here in the Virgin Islands. 17 18 19 20 21 22 23 24 So we actually had you know, real complaints you know, filed from you know from real victims from you know, that weren't rumors. They actually were coming in and saying, Hey, this guy is on your registry, but he's still raping his 15-year-old daughter who's now pregnant. 25 So, you know, in addition, I'm 1 2 3 4 5 6 7 8 9 10 11 12 saying that I didn't have time to sit down and you know, and do Google searches because I was working on working with the investigators on you know, not only monitoring about 70-something other offenders, but also working on cases for offenders who were absconding also who were also in -- who we received -- you know, filed allegations about them conducting other sexual offenses in the Virgin Islands. 13 14 15 16 17 Q. So the answer to the question that I posed, which was: Did anyone at DoJ ever take any steps to do this kind of news report investigation, the answer is "no," correct? 18 19 20 21 ATTORNEY ACKERMAN: Objection to form, misstates prior testimony. The answer is reflected in the record. 22 THE WITNESS: No. 23 ATTORNEY O'LAUGHLIN: Okay. 24 Let's go off the record. 25 VIDEOGRAPHER: Off the record. 1 they fall into a Tier 3 as well too. 2 3 4 5 6 7 And then you would see, you know -- if we want to say more serious in terms, you know, to first degree would actually be enforceable rape. You will see the more serious offenses in Tier 3 compared to Tier 1. 8 9 10 11 Q. Okay. And then as a result of being put into a higher tier, are there differences in the monitoring requirements? 12 13 14 15 A. The monitoring requirements the only difference was in regards to the frequency of their appearance at VI DoJ to register in-person. 16 17 Q. How does it change between tiers? 18 19 20 21 22 A. So for Tier 1 it was once a year. And that I think it was 15 years. Tier 2, was every six months I believe for 25 years, and then Tier 3 was every three months for life. 23 24 25 Q. And were there any other monitoring differences associated with the tiers other than the ones you just 1 discussed? 2 3 A. No. They were all monitored the same. 4 5 6 Q. Okay. What tier -- we've discussed this. But Epstein was classified as Tier 1, correct? 7 A. That's correct. 8 9 Q. Okay. What was the basis for classifying Epstein as Tier 1? 10 11 12 ATTORNEY ACKERMAN: Object to form. I think it's asked and answered, but you can go ahead. 13 14 15 16 17 18 THE WITNESS: Okay. I understood that once Epstein -- what was received from Florida was reviewed. That that conviction, that was what was used to determine his placement into a Tier 1. 19 (BY ATTORNEY O'LAUGHLIN): 20 21 22 Q. Okay. The procuring a minor for prosecution was a Tier 1 offense according to USVI law? 23 24 25 A. That determination was made by an Attorney within DoJ, which I -- if I remember correctly, was Attorney 1 2 3 dates where we can have this operation to verify the addresses of sex offenders in the Virgin Islands. 4 5 Q. So the sweeps were run by who? 6 7 8 9 10 11 12 13 A. Nothing within the statute speaks about sweeps having to occur. So the only thing that is within the statute, if I remember, speaks about an offender moves to the territory within a set amount of dates, VI DoJ officials go out to verify that address. 14 15 16 17 18 19 20 21 22 23 In regards to the sex offender address compliance checks, that was an effort from the US Marshals Services. And if I remember correctly, a part of US DoJ is that the US Marshals Services, that they assist states, you know in the offices who oversee the sexual -- the sex offenders; that they assist them with the operation to include the address verifications. 24 25 Q. How frequently do sweeps occur? 1 2 3 4 5 6 7 8 A. How frequent the sweeps occur? There was no set-in- time for the frequency of the sweeps to occur. It would be something where we were in constant communication with the US Marshals Services. And they will let us know, Hey, you know, this will be the time for an upcoming sweep. 9 10 Q. Do you have an estimate of how frequently they occurred? 11 12 A. I would say perhaps once a year depending on funding. 13 Q. Okay. Funding from where? 14 15 16 17 A. Funding that the US Marshals Services received. So the US Marshals is Federal funding to conduct the operational sweeps. 18 19 Q. Okay. And during a sweep, what was the objective? 20 21 22 23 A. The objective was to verify the address of the -- that the sex offender had on record as their permanent residence. 24 Q. What does verify mean? 25 A. Verify, verification process 1 2 3 4 5 private chefs here on the island are tight, and we see and hear everything, especially what goes on in Little St. James island. We have pictures, audio, video of it all going on." 6 7 8 9 Is this the E-mail that you were talking earlier about as the only time that you received a tip about Epstein? 10 11 12 13 A. If you want to say a tip, you know, when I actually received anything, you know, about allegations of what was going on with Epstein. 14 15 16 17 Q. Was there any follow-up on the report that this individual had audio and video of what was going on on Little St. James? 18 19 20 21 22 A. He never provided audio or visuals on what was going on on Little St. James. He never did. Not to my knowledge, he ever did. He never provided anything to me. 23 24 Q. Was there ever any outreach to him to obtain any audio/video? 25 A. My response is here, and the 1 2 3 4 5 6 7 8 tone of it is, you know, very threatening. So I reminded him of his need to register as a sexual offender and also that we're not at liberty to discuss any registration status of any offender, the same how we would not discuss his act with any other offender either. 9 10 11 12 13 14 15 16 He had all -- if he did have any pictures, audio, video of Epstein on Little St. James, they were never provided to DoJ. And if he really wanted, you know, to provide something, he never did. He never followed up and write anything to my knowledge. 17 18 19 20 Q. So that's not the question. The question is: Did USVI DoJ ever follow up with him to obtain audio or video? 21 22 ATTORNEY ACKERMAN: Object to form. 23 Go ahead. 24 25 THE WITNESS: You're asking if VI DoJ or if myself ever asked him for 1 go off the record. 2 VIDEOGRAPHER: Off the record. 3 The time is 6:31. 4 (Off the record) 5 (Back on the record) 6 VIDEOGRAPHER: On the record 7 at 6:42. 8 CROSS EXAMINATION 9 (BY ATTORNEY ACKERMAN): 10 11 12 13 14 15 Q. Okay. Ms. Pinney, it has been a long day. We have met before. My name is David Ackerman with the law firm of Motley Rice representing the Government of the US Virgin Islands. I just have a few questions 16 A. Uh-huh. 17 18 19 20 21 Q. -- for you. And I want to start with the topic of address verifications. I think you said some of this before, but I just want to make sure that I have it clear. 22 23 Who selects the date that the address verifications occur? 24 25 A. US Marshal Services would have sent, you know, different windows and 1 2 3 4 asked which works best for us. But it was the Marshals Service who would essentially, you know, decide which dates were best. 5 6 7 8 9 Q. Okay. And by the way, are the address verifications the same thing as the sweeps that you described, that you -- it was a term you used earlier? 10 11 12 13 A. Yes. So the US Marshals Services, they titled those. They called the operation as Operation Island Sweep. 14 15 16 Q. Okay. And when -- what is the purpose of the sweep or the address verification? 17 18 19 20 21 22 A. The purpose is to confirm that what the offender has provided as their permanent residence, and also instances may also be their employer address, that that is true and -- and correct. 23 24 25 Q. Okay. When you performed or when the DoJ performed sweeps to verify Mr. Epstein's address, did DoJ 1 2 already know where Mr. Epstein was living? 3 A. Yes, we did. 4 5 6 7 Q. Okay. Was there any doubt in your mind or in the SORNA unit's mind as to whether Mr. Epstein had moved to a different address? 8 A. No, there was not. 9 Q. Why not? 10 11 12 13 14 A. Well, for one, he did not provide any notice of change. We received no tips saying that he was no longer living on Little St. James and living at another residence, and yeah. 15 16 17 Q. Okay. Was there an instance where Mr. Epstein's verification was conducted at his office? 18 A. Yes, there was. 19 20 Q. Okay. Did you participate in that verification? 21 A. From my recollection, I did. 22 23 24 Q. Okay. And tell me what you recall about that verification when you met Mr. Epstein at his office. 25 A. So we ended up -- when we went 1 2 3 to his island, he wasn't there. So at that point we decided that we can meet him at his -- at his office. 4 5 6 7 8 9 When we went to the island, his staff was there, his employees were there. They confirmed, you know, that this was Little St. James and that this was Jeffrey Epstein's, if you want to say his island, you know. 10 11 12 13 14 15 16 And just like how the decision was made in other address checks for other offenders, since he wasn't at home, that was not determined to be that he was in noncompliance. We simply just said, Okay. We'll go to his employer address. 17 18 19 Q. Did you verify other sex offenders in the Virgin Islands at their employer's address? 20 A. Yes, we did. 21 22 23 24 Q. Okay. Are the address verifications or the sweeps required by any Virgin Islands statute to your knowledge? 25 A. No. 1 2 3 Q. When you performed the address verifications or the sweeps, do you have a warrant? 4 A. No, we do not. 5 6 7 8 9 10 Q. Do you have an understanding as to whether there is any limit on your ability to search or enter a person's, a sex offender's property during an address verification or sweep? 11 12 13 14 15 16 17 A. An address verification does not constitute that VI DoJ has the right to search an offender's home. If we go to the address and we say, Hi, we're here to conduct an address verification, can we come inside, they have the right to say no. 18 19 20 21 Them saying no does not put them in noncompliance because it is not a search warrant. We don't have a search warrant to search the home. 22 23 24 25 So in many instances, we have conducted address -- checks in an offender's yard, on their front porch, and they were found to still be in 1 2 3 compliance because a search of their home was not required to complete that address verification. 4 Q. Okay. Thank you. 5 6 7 8 You testified earlier one of the things you did in preparation for this deposition was to review the testimony of Inais Borque, right? 9 A. Yes. 10 11 12 13 Q. Okay. There was testimony in Ms. Borque's deposition about performing weekly checks of offenders. Do you recall that testimony? 14 15 A. I do recall reading that in her -- in her deposition, yes. 16 17 18 19 20 Q. Okay. Was it the practice of the Virgin Islands DoJ SORNA office to conduct weekly checks of sex offenders during the time period that you worked in that office? 21 A. No, it was not. 22 Q. Thank you. 23 24 25 I want to go through a few exhibits, and I'll try to just go quickly. But let's start with Exhibit