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← Back to Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1;22-cv-10904 (S.D.N.Y. 2022)
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SEA1.2L EXHIBI-1.1T Case Document Filed Page of UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NUMBER ACTION FOR DAMAGES GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Plaintiff VS JP MORGAN CHASE BANK N.A Defendant VIDEO RECORDED DEPOSITION OF SHANI A PINNEY WITNESS TUESDAY JULY REPORTED BY DENISE HARPER-FORDE Certified Shorthand Reporter CSR Certified RealTime Reporter CRR Certified LiveNote Reporter CLR Registered Professional Reporter RPR Notary Public FLORIDA Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com Justice Did any of the jobs you had before working for DoJ involve law enforcement A No Did they involve sex offender monitoring in any way A No When did your employment with DoJ begin A In November What position did you have A Sexual offender registry I believe its now it was coordinator And what were your roles and responsibilities A My role was for the St Thomas St John Jurisdiction to register sexual offenders who were living or working on the two Islands Anything else A Paperwork Updating the online registry for the sexual offenders to reflect their addresses Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com Ackerman It was just myself and Attorney Ackerman So what was the reference you just made to Attorney Carbon or Monica Carbon A So I understand that Attorney Carbon met with Attorney Ackerman and her a brief review of of that meeting was provided to me as well too Okay So you never met with Ms Carbon but a summary of that meeting was provided to you A Thats correct Okay Do you have that document with you today A No I dont Does your Counsel ATTORNEY ACKERMAN Yes I have it I can provide it ATTORNEY OLAUGHLIN Okay Could you enter it as the first exhibit please ATTORNEY ACKERMAN Well so Im going to enter it into the Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com ATTORNEY ACKERMAN Okay BY ATTORNEY OLAUGHLIN Is this the document that you reviewed in preparation for your testimony today A Yes I skimmed over this yesterday evening So the first time you saw this document was yesterday evening A Yes And how did this document help you prepare for your testimony today ATTORNEY ACKERMAN Object to form THE WITNESS How it helped me to prepare for today It explained the beginning of how the sexual offender registry statute came to be How it was how and why it was improved here in the Virgin Islands And then ATTORNEY ACKERMAN You can scroll this document if you need to Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com THE WITNESS Thank you And then it also went on to explain you know the in regards to Jeffrey Epstein and his classification and his registration here in the Virgin Islands BY ATTORNEY OLAUGHLIN What is the sex offender registry for A The sex offender registry board was a combination of professionals here in the Virgin Islands And within the statute it details that their duties are you know to review if I recall is to review sex offender their classifications You know to also review sex offenders who seek to be removed from the registry Thats like some of thats like one or two of the duties that the SOR board Im not that familiar with it because while I was there it was defunct You know it Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com questions THE WITNESS Im sorry ATTORNEY OLAUGHLIN Yes THE WITNESS Sorry sorry sorry BY ATTORNEY OLAUGHLIN Theres a section at the end that says Monitoring visits to LSJ when she wasnt there This section is about what A The bullets under here The first bullet says She doesnt recall much She has to be Attorney Carbon She just recalls that Pinney myself mentioned a question as to whether they had the authority to go past the dock Okay So that first bullet The second one She recalls the U.S Marshals will go out and invite them because they had the boat She doesnt recall a discussions regarding getting a warrant If there were concerns shed have passed it on to the AAG but does not recall Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f COURT REPORTER Speak up please THE WITNESS If there were concerns she would have passed it to the AAG but does not recall ever doing so Okay So this section here refers to when we would do our address verifications for all registered offenders here in the Virgin Islands She doesnt recall much but shes saying that I mentioned to her question because where they had the authority to go past the dock Okay So the question was whether or not the dock was Jeffrey Epsteins front door to his home When we do the address verifications they are not search warrants We go we knock on the door and we introduce ourselves We say Hello you know Were here Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f with the This is DoJ Were here with the U.S Marshals here Were VIPD And we are here to conduct an address verification At that point they can say whether or not we can enter into their home They have that right to say no This question in regards to being able to pass his dock Because the question came up whether his dock would be his front door So essentially if we pull up there you know with U.S Marshals services with VIPD and we used to go out on if I recall one time we went on the U.S Coast Guard boat Another time we went out on a vessel from DPNR The question amongst all of the entities was essentially is this dock his front door Do we have the legal authority to actually force ourselves past the Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f dock since he actually owned the island So that is what that first bullet is referencing BY ATTORNEY OLAUGHLIN Was that question resolved A Was that question resolved Basically when even when we had a telephone call with our liaisons from USDoJ they were not able to provide any real guidance on that because he he owned the island And so like I said before when we knock on the door they can say yes or no you can come in So we have conducted address verifications in the yard of a sexual offender It doesnt have to be inside their home So they were really unsure as to what the laws are They they really were not able to provide any real guidance regarding whether or not Epsteins dock was essentially you know representative of his front door So there was a question but Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f DoJ never determined the answer A DoJ wasnt able was unable to provide guidance Thats correct No no answer was every really received from DoJ about that Why not ATTORNEY ACKERMAN Object to form THE WITNESS Im not sure why not They werent sure BY ATTORNEY OLAUGHLIN And in the absence of guidance from DoJ how did you approach the question of whether you could go past the dock or not ATTORNEY ACKERMAN Object to form You can answer THE WITNESS So if Epstein was on-island or if his staff allowed us to that would be when we would go past the dock BY ATTORNEY OLAUGHLIN Okay A and actually be on the island actually on the island Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f itself So barring guidance to the contrary you treated the dock as a front door ATTORNEY ACKERMAN Object to form THE WITNESS It was agreed amongst the different entities the U.S Marshals services VIPD and also DoJ that the dock had to be considered as his front door BY ATTORNEY OLAUGHLIN So it was agreed that thats the way you would all proceed but there was never a formal decision that that was in fact the right answer correct ATTORNEY ACKERMAN Object to form THE WITNESS When you say formal decision do you mean some what do you mean when you say formal decision BY ATTORNEY OLAUGHLIN Well you said you never got Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f the guidance you were looking for So thats what I mean A From USDoJ no we did not Okay But you but USVIDoJ did have come to a conclusion even though USDoJ didnt ATTORNEY ACKERMAN Object to form THE WITNESS Okay So we concluded that his dock was his front door That was the conclusion amongst jointly amongst all of the entities there that You know U.S Marshals services were not sure neither was VIPD So we said Okay Lets consider his dock as his front door BY ATTORNEY OLAUGHLIN Okay So USVI Department of Justice did have a view that the dock was the front door And the thing they were wanting confirmation from was USDoJ And thats the opinion Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f they never got ATTORNEY ACKERMAN Object to form THE WITNESS I wouldnt say that we had that view If we were able to we would like to go into the homes of all offenders you know to because the offender address checks are not warrants The same way that we would not force ourselves into any offenders home through their front door we did not want to force our way onto his island pass the dock So we said we will conduct the checks if they were allowed to come on the island from Epstein or from his employers his staff we would go past the dock onto the island And that will be the same way if any offender if John Doe on the registry said we can come in we would come into their home past your front door as well too Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f Got it And USVIDoJ had thought about the question and had determined were going to treat the dock as his front door for our purposes ATTORNEY ACKERMAN Object to form Asked and answered Misstates prior testimony You can answer THE WITNESS Yes So you know the the sex offender address checks you know it was done by U.S Marshals services VIPD and DoJ And its important to understand also that these address checks are really a function of the U.S Marshal services You know that is something that they receive funding to do throughout the U.S So they would bring down their team of Marshals from Florida and Georgia I guess you know the Southeast region Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f So we although we were registering the offenders here in the Virgin Islands we were also taking their lead as to since it was essentially I dont want to say their operation But they received the funding and they would let us know you know when the possible dates for the we used to refer to them as registration sweeps you know when the sweeps could occur So I also want to highlight that even U.S Marshals services you know the Marshals they were also not percent sure as to whether or not we can actually you know just go on and pass the dock without the permission So the you know that guidance you know the a little bit of unsure from USDoJ as well too We said Okay That must mean that we have to consider his dock as his front Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f door Did we want to do it that way No You know we would have loved to And it was actually you know like I said we would love to be able to go into the home of every offender including Epstein when when he was registering But we came to the you know the decision that his dock had to essentially be considered as his as his front door BY ATTORNEY OLAUGHLIN Why werent you on the Friday call with Ms Carbon A Oh Ive been on family vacation I just came back yesterday evening Ive been gone since July 5th So I wasnt available for the call on Friday Actually Ms the E-mail invite for for that meeting Okay So you were invited to the meeting by your counsel but you didnt see the invite and so didnt Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f well Do you recall which of these attorneys were specifically involved with Epstein ATTORNEY ACKERMAN Object to form THE WITNESS All of the offend all of the attorneys assisted with the offenders Okay So if I backtrack I said it would be attorneys specifically will assist with any warrants any absconders Epstein didnt have any warrants You know he always appeared to register So there you Know there were no warrants for him or anything But in regards to his initial classification the attorney who dealt with that would have been Attorney Carbon BY ATTORNEY OLAUGHLIN Okay And then did the Attorney Generals the Attorneys Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f General themselves get involved in monitoring Epstein at any point ATTORNEY ACKERMAN Object to form THE WITNESS In monitoring Epstein no That those were the duties of the coordinators myself as a manager and also the investigators So the attorneys were not involved in the monitoring of the offenders BY ATTORNEY OLAUGHLIN Were they involved in any way with Epstein ATTORNEY ACKERMAN Object to form THE WITNESS Only in regards to his classification Epstein was not Epstein was never found to be in noncompliance So there was never a warrant for an attorney to be involved with him in that aspect With regards to his classification regarding which tier he fell into Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f there was there was an attorney who dealt with that BY ATTORNEY OLAUGHLIN So Im talking specifically about the Attorneys General of the USVI during your time period there And Im asking were they involved in any way with Epsteins sex offender registration or monitoring ATTORNEY ACKERMAN Object to form THE WITNESS In any way when he first came on Attorney Carbon you know she dealt with him in regards to his classification Okay ATTORNEY ACKERMAN Ms Pinney hes asking you about Attorney General THE WITNESS Attorneys General ATTORNEY ACKERMAN Attorneys General THE WITNESS Okay ATTORNEY ACKERMAN Yes Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f Okay So let me ask the question this way If there was a new employee in the group and you had to give them an orientation you would hand them the statute and say read this And then you would describe the practices but there wasnt a handbook or any other thing you would give them to be like this is how we do our work ATTORNEY ACKERMAN Objection to form scope BY ATTORNEY OLAUGHLIN Correct A Outside of the statute there was no other written handbook or policy for employees relative to the sex offender registry Okay And you so with regard to the practices you said there was a practice regarding interaction with VIPD correct A Uh-huh What was that practice Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f A That VIPD will assist the US Marshals Services and VI DoJ with the sex offender registration sweeps What would you need to do what would DoJ need to do in order to get that assistance ATTORNEY ACKERMAN Object to form scope THE WITNESS The AAG will draft a letter to the head of VIPD requesting assistance BY ATTORNEY OLAUGHLIN Were there ever times that DoJ would reach out for help with a specific sex offender ATTORNEY ACKERMAN Object to form scope THE WITNESS No BY ATTORNEY OLAUGHLIN So at no point in the time that you were at DoJ did USVI DoJ ever reach out to you US VIPD for assistance with any registered sex offender ATTORNEY ACKERMAN Objection Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f registered sex offenders and our statutes Any questions that we may have had such as what we spoke about you know the dock of Epstein Who at US DoJ would you reach out to with those questions A I cant remember the title but at one point it was Lori McPherson How many times did you reach out to Lori McPherson regarding Epstein A Oh I I cannot recall the amount of times I I cant recall Were there times A The only time I can recall in what would have been in regards to the dock and that was held when I attended a training for you know for for they had a training for all SORNA all sex offender registries to attend And in person when I saw Ms McPherson we spoke about you know the question regarding Epstein and his Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f dock Okay What did you say to her A I explained to her that we were doing the address verifications And I mean I cant remember word for word But all in all the scope was whether or not we can forcibly come onto the island or you know is when I say forcibly I mean you know if we can actually go past the dock and you know walk on the island until we see you know perhaps where he rests You know where where he lays his head Or is or is there any guidance with regards to offenders who own islands you know And the response I got back was that Epstein was unique in that most offenders dont own islands However theyre they drew the comparison to lets say an offender lives in the Midwest you know where there are you know mass amounts of land You know and the offender has Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f a gate you know and he owns probably you know 20-something ares of land If his home is within the middle of that he can argue that his fence is his front door So you know that was the comparison that was that was drawn to Epstein And did they give you that comparison as a means of saying and we think the dock is the same ATTORNEY ACKERMAN Object to form THE WITNESS Pretty much you know they said that they were not sure But you know they drew that comparison to show that that essentially you know that was how another juris another state had to deal with with their offender So yeah you know its its their property BY ATTORNEY OLAUGHLIN Do you know what Lori Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f what was said in Brissons E-mail What year was that E-mail that you escalated A Oh I dont recall but I do remember reviewing that document with Attorney Ackerman Okay Aside from that one escalation there were no other escalations by DoJ regarding Epstein correct A Correct No other no Okay You said that in your role expanded to include looking at the budget for DoJ correct A Uh-huh And for the sex offender monitoring group specifically correct A And for the sex oh overseeing the other employees yes How is the sex offender monitoring program funded A Its a Federally funded program from VI from US DoJ and Sex Offender Registry Notification Act Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f You know so by by enhancing our laws in that made us eligible to us being the Virgin Islands eligible to receive funding for employees to to monitor offenders in the Virgin Islands Was that funding adequate to do the job that you guys had to do ATTORNEY ACKERMAN Object to form scope THE WITNESS If it was the pos that funding was used for salaries Other and funding was also received from US Marshals Services as well too you know to purchase like iPads you know for us to use to be able to monitor offenders outside of the office You know to be able to update the registry the online registry outside the office as well too So from from from US DoJ that funding was used for salaries the salaries being you know for the three positions Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com to form scope to the extent its outside the sex offender registry topic THE WITNESS To my knowledge no BY ATTORNEY OLAUGHLIN Do you know if First Lady Cecile de Jongh ever interacted with DoJ regarding Epstein A I cannot say that I was aware of that during my during my time So no Do you know if Governor de Jongh ever interacted with VI DoJ on behalf of Epstein A I ATTORNEY ACKERMAN Im just going to object on scope to this line of questioning And you can go ahead THE WITNESS To my knowledge no BY ATTORNEY OLAUGHLIN What about Governor Bryan A To my knowledge no Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com THE WITNESS About the tuition being paid BY ATTORNEY OLAUGHLIN About the relationship between Governor John de Jongh the First Lady and Epstein ATTORNEY ACKERMAN Objection to form scope THE WITNESS I cannot recall when I was first when I became aware of these the relationship between Epstein and the former Governor BY ATTORNEY OLAUGHLIN Did the relationship between Epstein and the de Jongh family ever play any role in DoJs monitoring of Epstein as a sex offender A No Did either Cecile de Jongh or John de Jongh ever reach out to anyone involved in sex offender monitoring at DoJ regarding Epstein A To my knowledge no ATTORNEY OLAUGHLIN Lets Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com A Uh-huh ATTORNEY ACKERMAN Same objection speculation THE WITNESS No BY ATTORNEY OLAUGHLIN Do you agree with the statement that there was no information available to the USVI to trigger an investigation ATTORNEY ACKERMAN Objection scope THE WITNESS Youre talking about the Attorney General Georges statements BY ATTORNEY OLAUGHLIN Yes A Yes I agree with that Isnt all of the information that we just looked at information about complaints of criminal activity by Epstein on Little St James ATTORNEY ACKERMAN Objection to form scope THE WITNESS So like what Denise George says here an Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f investigation can only be launched if someone launches if someone files a criminal Complaint Im understanding that to be a Complaint being filed locally you know with VI DoJ or you know with VIPD BY ATTORNEY OLAUGHLIN Why does it need to be a locally filed Complaint A Im saying thats what I understand and ATTORNEY ACKERMAN Hold on Objection scope You can go ahead THE WITNESS Yes Im saying thats what I understand you know the AGs meaning to be here in this sentence Nothing was ever filed directly with VI DoJ or VIPD to launch an investigation BY ATTORNEY OLAUGHLIN And DoJs position is that unless something was filed directly with them there was no need to do any Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com kind of investigation into Epstein ATTORNEY ACKERMAN Objection to form scope THE WITNESS Yeah You know it cannot be a no hearsay It cannot be rumors whispers It has to actually be someone actually filing a Complaint That would have been the means you know for any sexual offender to start spark an investigation or you know if information was shared directly you know with the victim you know to VI DoJ It would have to have been dir it would have had to have been direct communication BY ATTORNEY OLAUGHLIN Did anyone within DoJ ever push for more to be done with respect to investigating Epstein ATTORNEY ACKERMAN Objection to form scope THE WITNESS No BY ATTORNEY OLAUGHLIN Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f BY ATTORNEY OLAUGHLIN No you dont know or you dont think they were A If other offenders were granted this I would have been aware since I was registering the offenders Okay And youre not aware of any other offenders that got these sorts of waivers A No Okay A I do want to say though you said if they if anyone ever made requests We got complaints all the time you know So offenders you know complain about the frequency everything all the time So it was just wasnt to the extent you know of this What was the reason for the original regime of having the 21-day notice requirement ATTORNEY ACKERMAN Object to Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f form scope THE WITNESS I am not sure I dont know I wasnt involved in the in the creation of it Guidance was received from US DoJ So that may have been perhaps what US DoJ recommended However in the end even with the changes US DoJ still approved this SORNA for us to receive the funding for we had to receive the funding BY ATTORNEY OLAUGHLIN Were was the 21-day requirement part of what you described as making the laws more strict surrounding the sex offender monitoring A I ATTORNEY ACKERMAN Object to form You can answer THE WITNESS I assume so Yes BY ATTORNEY OLAUGHLIN Okay And was the requirement Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f notify via E-mail BY ATTORNEY OLAUGHLIN Okay So between the period when Attorney General Vincent Frazer left office and then was replaced by Attorney General by acting Attorney General Thomas-Jacobs you dont recall any particular incidents outside of the ones that you just discussed A No I do not ATTORNEY OLAUGHLIN Okay So lets enter Tab as Exhibit Whereupon Defendants Exhibit No MetaData Documents was marked for identification THE WITNESS And I do also want to add in there you know that that when I remember more I think the statute speaks about traveling outside of the United States So you know it was more so like a policy that we have for offenders to notify us of any travel Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f outside of the Virgin Islands But the statute really clearly spoke about outside of the United States And since we are a US territory you know travel to Florida or to Minnesota or to New York or New Jersey would have still be considered inside the United States So we got a policy in place where we wanted the offenders to notify us of you know any travel to include outside the territory BY ATTORNEY OLAUGHLIN So let me see if I understand Was there a change was there a change between whether international travel required reporting versus travel within the United States A Well you know now that were speaking and I spoke specifically about the travel to DR to the Dominican Republic Im remembering now that within the statute it spoke about notifying VI DoJ if any offender has notified any of any travel Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f outside the United States Okay A However we adopted you know a policy you know within VI DoJ We wanted offenders to notify us of any travel outside of the territory as well So not just outside the United States So if they were going to Puerto Rico we wanted to know they were going to Tortola we wanted to know that as well too Okay Was that different from the regime that had been in place before Like if they had gone to Florida before would they have needed to notify ATTORNEY ACKERMAN Object to form THE WITNESS When you say different from before what time frame You mean prior to BY ATTORNEY OLAUGHLIN The well when do you think the change if there was a change Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f her response was to that I cannot recall BY ATTORNEY OLAUGHLIN Okay So you dont remember what her view was about the previous grants ATTORNEY ACKERMAN Object to form THE WITNESS No BY ATTORNEY OLAUGHLIN Okay You dont know whether she opposed the grants that Frazer had put in place ATTORNEY ACKERMAN Object to form THE WITNESS No BY ATTORNEY OLAUGHLIN Okay You talked about sweeps What is a sweep A So the sweep was the name that the US Marshals gave the the operation It was called Operation Island Sweep And that was when US Marshals Services they would come in They would let us know the Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f dates where we can have this operation to verify the addresses of sex offenders in the Virgin Islands So the sweeps were run by who 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 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 How frequently do sweeps occur Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f A How frequent the sweeps occur There was no set-in-stone 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 Do you have an estimate of how frequently they occurred A I would say perhaps once a year depending on funding Okay Funding from where A Funding that the US Marshals Services received So the US Marshals is Federal funding to conduct the operational sweeps Okay And during a sweep what was the objective A The objective was to verify the address of the that the sex offender had on record as their permanent residence What does verify mean A Verify verification process Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f confirm with Epstein to complete his compliance check within that time period they would have tried But once they went back that was it You know the operation ended at that point And there wouldnt have been any further follow-up correct A Further follow-up in regards to verifying his address Yeah A Well if we go there and Epstein remember I said before another person in the home can you know confirm that the offender was living there Ideally we do want to see the offender in person However an offender not being at the address does not does not immediately mean that they are in noncompliance or you know it it wouldnt immediately mean they were in noncompliance if within the team if it was agreed that okay you know hes off island right now or you Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f know we can meet him at his office then that would have been enough to you know to at the time for you know during the week of the checks You testified earlier that USVI DoJ SOR unit purchased a car A Uh-huh Why A I testified earlier that the vehicle was used to conduct the verification checks So A the compliance checks So the car was only used approximately once a year A No Remember I also said that that during the year we would also verify the addresses of offenders you know if they relocated if they had a new address Within that time I think its seven days that we would also go out to verify their addresses Were there any other reasons a car would be used Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f The news articles that we went over earlier today and the article that we looked at or sorry I think it was July Daily Beast article with the allegations against Epstein did any of that reporting cause USVI DoJ to initiate a check on Epstein ATTORNEY ACKERMAN Object to form THE WITNESS No Like I stated before there were no written concrete allegations that were submitted to VI DoJ to constitute you know or to elevate for for an investigation And the article was there I saw the article from The Daily Beast and yeah I mean I remember seeing that here with you and yeah BY ATTORNEY OLAUGHLIN Thats fine You dont need to find it A Im not sure how There was no follow-up here Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com already know where Mr Epstein was living A Yes we did Okay Was there any doubt in your mind or in the SORNA units mind as to whether Mr Epstein had moved to a different address A No there was not Why not 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 Okay Was there an instance where Mr Epsteins verification was conducted at his office A Yes there was Okay Did you participate in that verification A From my recollection I did Okay And tell me what you recall about that verification when you met Mr Epstein at his office A So we ended up when we went Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f to his island he wasnt there So at that point we decided that we can meet him at his at his office 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 Epsteins if you want to say his island you know And just like how the decision was made in other address checks for other offenders since he wasnt at home that was not determined to be that he was in noncompliance We simply just said Okay Well go to his employer address Did you verify other sex offenders in the Virgin Islands at their employers address A Yes we did Okay Are the address verifications or the sweeps required by any Virgin Islands statute to your knowledge A No Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f When you performed the address verifications or the sweeps do you have a warrant A No we do not Do you have an understanding as to whether there is any limit on your ability to search or enter a persons a sex offenders property during an address verification or sweep A An address verification does not constitute that VI DoJ has the right to search an offenders home If we go to the address and we say Hi were here to conduct an address verification can we come inside they have the right to say no Them saying no does not put them in noncompliance because it is not a search warrant We dont have a search warrant to search the home So in many instances we have conducted address checks in an offenders yard on their front porch and they were found to still be in Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f compliance because a search of their home was not required to complete that address verification Okay Thank you You testified earlier one of the things you did in preparation for this deposition was to review the testimony of Inais Borque right A Yes Okay There was testimony in Ms Borques deposition about performing weekly checks of offenders Do you recall that testimony A I do recall reading that in her in her deposition yes 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 A No it was not Thank you I want to go through a few exhibits and Ill try to just go quickly But lets start with Exhibit Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f if you would Do you have Exhibit in front of you A Yes I do Okay And this is the Virgin Islands daily news article from April 3rd Do you see that A Yes Okay And counsel read you a quote that said Were not a lenient jurisdiction because we know registration reduces the frequencies of sex offenses against new victims Did I read that correctly A Yes Did Mr Epstein ever fail to register in the Virgin Islands A No Okay We can put that aside Lets look quickly at Exhibit Do you have Exhibit in front of you A Yes Okay And Exhibit is the E-mail chain with a sex offender His name is redacted on this document Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f had to be creditable it had to have been a clear indication that the offender was in noncompliance BY ATTORNEY ACKERMAN In your exper given your experience do you believe news reports would have been sufficient to obtain a warrant to search Mr Epsteins property ATTORNEY OLAUGHLIN Objection THE WITNESS No BY ATTORNEY ACKERMAN Why not A The media has a way of sensationalizing a lot of things Thats for one And it would have to be something that is concrete that has evidence It would have to be a victim actually coming forward or a witness actually coming forward and saying putting it you know on record and you know a full statement to VI DoJ would have been needed from thats Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f what I think would have been needed to move forward with an investigation against Epstein from VI DoJ I dont think that a media source of allegations would have been enough for us to go forward to a judge to request an investigation or a warrant to search to search the island During your tenure at the SORNA unit are you aware of any of Epsteins victims or any witness to Epsteins crimes coming forward to DoJ prior to his arrest A No I want to give you the opportunity to I think explain something You earlier in this deposition used the term real complaints and real victims Do you recall that phrase A I think I was explaining about what if allegations were reported to VI DoJ about offenders Yes I do Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f Yes Were you meaning to suggest that the victims of Mr Epstein werent real A Oh of course not no Thats not what I meant at all I was trying to just draw the comparison to show how you know a news report of allegations from victims that was not going that was not going to be considered as something concrete In comparison to other offenders weve had where there have been written allegations you know victims coming forward saying that you know for example John Doe on the registry is still committing sexual offenses against children for example And with that that would have been enough proof for us to do an investigation to contact human services to contact VIPD as well in those instances But it was not to say in any way that that the allegations from any of those victims Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f you know that they were not real Thank you You described earlier a discussion with Denise George concerning Mr Epstein Do you recall that testimony A Yes Was that discussion specific to Mr Epstein or did Mr Epstein come up in the context of a discussion of sex offenders generally A If I recall he came up in a conversation of sexual of sex offenders generally He came up within the discussion Thank you Are you aware whether the Attorney General is involved in monitoring sex or strike that Let me ask the question differently During your tenure tenure at the SORNA unit was the Attorney General involved directly in monitoring sex offenders ATTORNEY OLAUGHLIN Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f ATTORNEY OLAUGHLIN Objection THE WITNESS Im not sure but I can say that every jurisdiction has their own set of statutes that they use to determine how frequently or the or the duration of time that offenders must appear or how long they have to register BY ATTORNEY ACKERMAN Okay There was some discussion about the changes in legislation the changes in the SORNA legislation correct A Yes And do you recall testimony about whether drafts of that legislation were shared with Mr Epstein or his lawyers A Yes Are you aware whether any proposed legislation required approval from the US DoJ A It would have had to have been approved by US DoJ So it was Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com approved prior to the amendment After the amendment it was still approved by VI by US DoJ to be in compliance with SORNA Okay The proposed legislation what role did the legislature play in A The legis that process ATTORNEY OLAUGHLIN Objection THE WITNESS The role that the legislature played in the in the proposed the legislature they had to pass it you know they enacted it BY ATTORNEY ACKERMAN Could DoJ have put that legislation in effect by itself A No I want to if you would pull out Exhibit Let me know when you have that A Okay I have it in front of you Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f A No Did the Virgin Department of Justice have access to how often he withdrew cash from his accounts A No Did the Virgin Islands have Department of Justice have access to the amounts of cash withdrawals that Mr Epstein made from his accounts A No The Department of Justice couldnt get that information without a unless it had a warrant right A I assume that would have that would be what would have been needed So yes ATTORNEY OLAUGHLIN Objection BY ATTORNEY ACKERMAN None of that materi none of what I just mentioned is listed on this checklist is it A No Okay Ms Pinney you were at the SORNA unit for close to ten years Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f is that right A Yes Did you do everything in your power to appropriately monitor Mr Epstein A Absolutely yes Do you believe that the SORNA unit is responsible for Mr Epsteins crimes A No If you had any information that Mr Epstein was committing crimes on his island what would you have done A I would have reported that information to our investigator VIPD criminal the AG Did you ever participate in a cover-up of Mr Epsteins crimes A Absolutely not No MR ACKERMAN I have nothing further REDIRECT EXAMINATION BY ATTORNEY OLAUGHLIN Ms Pinney counsel for USVI Case Document Filed Page of SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com SHANI A PINNEY Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com
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