EXHIBIT 125¶
20 21 22 Continued videotaped deposition of MARY, taken pursuant to notice, was 19 held remotely via Zoom Videoconference beginning at 2:07 p.m., on the above date, before L. Gray, a Registered Professional Reporter, Certified Shorthand Reporter, Certified Realtime Reporter, and Notary Public. 18¶
23 24 GOLKOW LITIGATION SERVICES 877.370.3377 ph I 917.591.5672 fax deps@golkow.com¶
1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶
2 3 4 GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, CASE NO. 1:22-CV-10904¶
5 6 v.¶
7 JPMORGAN CHASE BANK, N.A.,¶
8 Defendant/Third Party Plaintiff.¶
9¶
Plaintiff, -JSR¶
JPMORGAN CHASE BANK, 10 N.A.,¶
11 Third Party Plaintiff, :¶
12 v.¶
13 JAMES EDWARD STALEY,¶
14 Third Party Defendant. : 15 CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER VOLUME II¶
16 - - - July 6, 2023 - - - 17¶
that way?¶
A. She wasn't comfortable with him.¶
Q. Because of the conviction in Florida?¶
A. Correct.¶
Q. Did you ever ask her why she 8 continued to approve his due diligence reports?¶
lo A. No. But I -- so I didn't 11 ask her specifically why she would 12 approve them. But, again, as I had taken the reasonable steps as part of the same policy, she's subject to the same policy. She would also be taking reasonable steps to be comfortable with the sponsorships, since she's signing it as well. Those reasonable steps would include conversations, particularly with Mr. Staley, who knew Mr. Epstein best.¶
Q. But, again, all you can remember Mr. Staley saying to you, at least, was that he felt Mr. Epstein should remain a client of the Private 1 They were part of what would bring the due diligence reports together. So they were part of the due diligence process.¶
I don't know about, when you say "discuss," I'm not sure if you mean discuss, like, we did have meetings about him, et cetera.¶
Q. So when you are -- I'm just speaking now about --¶
10 A. Yeah.¶
11 Q. -- the due diligence that you did to form the judgment that the appropriate thing to do with respect to Mr. Epstein is to approve his due diligence report.¶
A. Mm-hmm.¶
Q. Did you discuss that issue with the compliance group?¶
A. So in our -- part of how I formed my reasonable judgment to approve the DDRs as part of the sponsorship policy, I would call upon or, if you will, part of my diligence was escalating and participating in brisk discussions¶
1 with senior management, compliance included in that, about his relationship with the firm. That was part of what I consider reasonable steps to then be able to approve a DDR, based on the sponsorship policy.¶
Q. And aside from compliance 8 and legal, who else are you including in your definition of senior management?¶
lo A. So my definition of senior 11 management would be both my chain of management, if you will, my boss up to the head of the Private Bank. And it would also include Mr. Staley, who sometimes was my direct line and sometimes was not, when he moved to the investment bank. But he would be part of those discussions as well and part of the diligence I would do.¶
Q. And when you say -- I forget whether you used -- I think the word "direct line" --¶
A. Yes.¶