EXHIBIT Case Document Filed Page of IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Plaintiff vs No JPMORGAN CHASE BANK N.A Defendant JPMORGAN CHASE BANK N.A Third-Party Plaintiff JAMES EDWARD STALEY Third-Party Defendant THE ORAL DEPOSITION OF CECILE DE JONGH was taken on the 29th day of May at the Ritz-Carlton Hotel Great Bay Nazareth St Thomas U.S Virgin Islands between the hours of a.m and p.m pursuant to Notice and Federal Rules of Civil Procedure Reported by DESIREE HILL Registered Merit Reporter Hills Reporting Services P.O Box St Thomas Virgin Islands Case Document Filed Page of CECILE DE JONGH DIRECT government agencies as part of your job Yes How about Port Authority Was that one of them I did interact with the Port Authority more so on the latter part because Mr Epstein wanted a hangar for his helicopter And so I negotiated the lease with the Port Authority Okay Now there came a time when your husband became governor Yes That was Yes And he served two terms Correct Okay Did that create any issues given your government-facing role for Mr Epstein I dont understand the question Okay Well let me ask it to you this way Did you change how you interacted with the government in any way after you had after your husband became governor I dont think so With the exception of the fact that I would occasionally ask him for direction as to who I should go to You know if I Case Document Filed Page of CECILE DE JONGH DIRECT had an issue who should I talk to to get something done Okay All right And did your husband have any process for recusing himself from issues that related to the company you worked for I dont know if he had any process Okay Youre not aware of any I said I dont know Okay Youre not aware of him recusing himself from any issue regarding Mr Epstein Im not aware of that no Okay All right Now when your husband became the governor did you sort of get a second job result of that as the first lady of the Virgin Islands Yes And what did that job entail Giving a lot of speeches I mean he ran twice So he ran in and lost I was not very involved in that campaign And between and you know right after we discovered that our youngest son had some serious health issues So I was very focused on that We both were And then he subsequently decided to run in and I was very involved in making sure that our Case Document Filed Page of CECILE DE JONGH DIRECT newsworthy at the time So there was just a lot on my plate And then I was also very involved in the National Governors Association THE REPORTER Im sorry THE WITNESS The National Governors Association because a lot of the first ladies were involved in mostly of childrens activities And the thing that I chose to do was to to focus on literacy because there are many children in the Virgin Islands that didnt have when we would do door-to-door during the campaign one of the things I discovered that a lot of the household didnt have books in them So my big project every year was to find a local author and have them write a book and give the books away for free because I didnt want to give toys and I didnt want to give candy And so wed have holiday parties and give away the books So I would raise money during the year for that And which you know took up a lot of time But I also got a lot of requests for just give a lot of speeches Case Document Filed Page of CECILE DE JONGH DIRECT And did you have an office as first lady No Did you have like an office address No Do you have like an official Twitter feed Somebody set up a I think a FaceBook something for me Im Im not on Im not on Twitter I actually dont know how Twitter works And I know that I had I had an email that was set up for me that I never really used because I had to go into the government system and then do something else and something else to get into it And so I just asked the head of protocol Raul Carrillo I said if anything comes in because it was it was the email address that they would give out to people saying you know if you want the First Lady to you know give a speech or show up somewhere you know email her at this email address And so that was what was done so I said can you just monitor it and if you know just send me whatever and Ill see whether it fits into my schedule and I would either do it or not do it Okay And did you have any staff that helped you in your role as First Lady Case Document Filed Page of CECILE DE JONGH DIRECT Well I had the chief of protocol But everybody all those people worked for Government House So it was the expectation that if there was a social event if there was a social event I was responsible for it I found it sometimes very misogynistic Sure But it was what it was That if you know if there was going to be sort of an event after the State of the Territory that I should be pick the caterer I should do this you know And so the chief of protocol had one or two staff members and so I would have you know I would run over to Government House and say okay what are we doing You know who are we inviting And they would sort of handle everything But they worked for they didnt exclusively work for me They worked for Government House Got it All right Lets look at Exhibit MS WARREN Tab Exhibit MR NEIMAN Yeah Tab I will ask the reporter to mark as Exhibit a one-page document Case Document Filed Page of CECILE DE JONGH DIRECT Deposition Exhibit No was marked for identification By Mr Neiman All right Ms de Jongh I handed you a one-page document which is the Twitter printout for ceciledeJongh firstlady.vi Do you see that Yes You recognize that This is a Twitter account It is Okay But I never these arent this is not something that I typed up All right So you can see in the at the sort of top half of the page theres a picture right Yes Thats you That is me Okay And it says under that that its the official Twitter account of U.S Virgin Islands First Lady Cecile de Jongh Do you see that Em-hmm And then it indicates that it was joined in September of You see that Yeah And that was during the time when you were Case Document Filed Page of CECILE DE JONGH DIRECT the first lady Correct And then theres a bunch of Tweets Right Do you know who wrote them I dont Would it had been somebody working for the government It might have been somebody working for the government yeah Okay You didnt hire someone separate from the government to manage this I didnt have money to do that Sure Sure Okay Just I mean theres no office of the first lady with a budget There was there was nothing Okay So lets take a look at I show you another document which we will mark as Exhibit MR SCHIFFMAN Is it possible to share these through chat at the same theyre being introduced so that we could Ill look at them as well online MR NEIMAN Sure Okay Case Document Filed Page of CECILE DE JONGH DIRECT Deposition Exhibit No was marked for identification By Mr Neiman Okay I placed in front of you Ms de Jongh Exhibit which is a printout from the archives of the internet of the official website of the Governor of the U.S Virgin Islands Do you see that Yes Eh-hmm And this announces that you had your own website Do you see that Eh-hmm Do you recall that I recall that yeah MR SCHIFFMAN Im sorry counsel was there an answer to that question as to whether documents are going to be shared in the chat MR NEIMAN Yeah The answer was yes MR SCHIFFMAN Okay Im sorry I just missed it MR NEIMAN And its in the chat now By Mr Neiman Okay Sorry to interrupt We were talking about the website Tell us about the first lady website that was set up That was something I think the P.R that the governors P.R department John Greaux and his Case Document Filed Page of CECILE DE JONGH DIRECT staff put up because I was you know I was doing things So they wanted to put it out there Right And you mentioned that you had to give a lot of speeches in this in this job Did you have someone who could write the speeches for you Yeah Julia I cant remember her last name worked in the P.R department So a lot of times I would draft something and I would send it to her and say you know what are your thoughts And she would clean it up and send it to me and thats how it was done Okay And Julia was an employee of the government Correct Okay And if you look at this little printout you could see it says First Lady Launches Website Eh-hmm And then in the second paragraph theres a little quote attributed to you Do you see that Yes And it says at the bottom that Its important that residents and other interested individuals have access to the ongoing work of the first lady on behalf of all Virgin Islanders Case Document Filed Page of CECILE DE JONGH DIRECT Do you see that Yes Is that sort of how you saw your role as working on behalf of all the Virgin Islanders Yes Okay All right And you can see that to the left there theres a little box that says Office of the First Lady Eh-hmm Do you see that And then theres a phone number and a Im sorry yes Yeah she cant write it down unless you say it Yes I know yes Let me just say one other thing very normal in regular conversation for us to kind of both be talking at the same time I apologize Super hard for her Yeah So I will try not to And I will try as well Great So you can see in this box it says Office of the First Lady and then theres an Case Document Filed Page of CECILE DE JONGH DIRECT address listed Do you see that Eh-hmm Yes And thats the address where the governors office is Correct Okay And theres a phone number and a fax number there as well Do you see that Yes And who would answer if that phone number was called Thats thats the same number as Government House Okay Thats the general switchboard number for Government House Yes Okay And would that call find its way to you eventually Yes I didnt work at Government House THE REPORTER Im sorry THE WITNESS I didnt work at Government House By Mr Neiman Okay So if someone called the number that the website is saying is the number for the office of First Lady what happens They would probably get Raul Carrillo or Case Document Filed Page of CECILE DE JONGH DIRECT No Do you remember a person named The name I do recognize yeah What do you remember about this person The thing I remember correctly is there was a who was when I was out getting my knee replacement in I was gone for a while and I came back and I think Jeanne told me that there was a who was going to be working with us And I said who And then who who worked with us And by the time I came back she was off and on the payroll You mean she had gone on the payroll and then off the payroll Yeah And you were in New York for like two weeks No I was gone for about a month About a month Yeah And am I correct that you stayed in an apartment provided by Mr Epstein in New York Correct Did you know anything about the other Case Document Filed Page of CECILE DE JONGH DIRECT THE WITNESS Yes By Mr Neiman I know its hard At the top theres an email from you to Mr Epstein and copied to Mr Kahn correct Yes Okay And you will see at the bottom Mr Epstein is asking you something about whether theres an CB5 visa regional center in the V.I Also tuition is approved Do you see that Eh-hmm Yes Okay So what is that what is he talking about there first with the CB5 visa regional center As I sit here now I dont know Okay And then you will see it also says Also tuition is approved Do you see that Yes Whats that talking about Thats probably tuition for our kids And am I correct that Mr Epstein paid the college tuition of your children Of mine and everybody else who had kids at Financial Trust yes Who elses tuitions did he pay other than Case Document Filed Page of CECILE DE JONGH DIRECT really cant do anything to influence cant do anything or influence Hancock since this the private sector issue Do you see that Yes Who is Kenn Hobson I think was the head of VIPA at the time Got it And you say This is why Kenn gave us a possible alternative Do you see that Eh-hmm Yes What are you referring to there Well I think thats referring to To item in the previous email Yeah Okay And then you go and say in the next paragraph of your email in Exhibit that John has said if you get the fuel prices together to show how Hancock is gouging he can take it to VIPA board Thoughts on this Do you see that Yes So youre bringing up again the point you made in the prior email that one way to deal with this issue was to have your husband the governor take it to the VIPA board right Case Document Filed Page of CECILE DE JONGH DIRECT anybody about getting it approved It was presented I think by Mr Epstein and Erika Kellerhals at the time By Mr Neiman Okay I think my question to you was did you stay out of it entirely I did I did stay well yes The answer is yes I stayed out of it All right Let me show you a document marked I will have the reporter mark as Exhibit Deposition Exhibit No was marked for identification By Mr Neiman And you will see that Exhibit is an email exchange involving Carol Chapman Percival Clouden and Jennifer Nugent-Hill Do you see that Yes And Carol Chapman worked for the Economic Development Authority correct I dont know her You dont know her You know Percival Clouden though I do He was who I think he was the executive director I think is the right term Right Yeah I think its Case Document Filed Page of CECILE DE JONGH DIRECT the right title He was the executive director of the Economic Development Yes Agency Yes I believe so at the time Okay And Jennifer Nugent-Hill Honestly I dont know what her title was She also had a role with the Economic Development But she worked there yes Okay And lets take a look at Ms Chapmans email to Ms Hill In the middle of the page she writes Hope you had a great Christmas and birthday The CEO called a few moments ago and asked me to give you his best regards Do you remember who the CEO was No I dont Okay All right You certainly would have known at the time who the CEO of the EDC was I dont recall Okay But I mean you were a pretty senior person Yeah on the island with lots of contacts Case Document Filed Page of CECILE DE JONGH DIRECT Did you know at the time even if you cant remember today who it was I would probably know then yes And youll see that what Ms Hill writes is that The CEO called a few minutes ago asked me to give you his best regards And then it goes down to the next paragraph He asked me to let you know he had a call from the First Lady and she has asked that Epstein be on the board agenda at the public hearing for the January 9th meeting Do you see that Yes So what Ms Hill is relating is that you had made a phone call to the CEO of the EDC right Yes Do you have any reason to dispute that Nope Okay And the purpose of your call was to get an issue related to Mr Epsteins certificate in front of the agency right MS BOGGS Objection Mischaracterizes this document THE WITNESS The EDC was notoriously always postponing postponing postponing Case Document Filed Page of CECILE DE JONGH DIRECT And so I can only sitting here today assume that either Erika Kellerhals or said can somebody please make a phone call to see if we can get on somebodys agenda so we could get this over with By Mr Neiman And you made the call I made the call Deposition Exhibit No was marked for identification By Mr Neiman All right Lets take a look now at all right Ms de Jongh Im handing you a document marked Exhibit And Exhibit is a email exchange between you and Jeffrey Epstein Do you see that Yes I do And at the bottom of the page Mr Epstein is asking you who is in charge of Customs in the Virgin Islands Do you see that Yes And am I correct that although the Virgin Islands is part of the United States its not part of the United States Its customs zone Correct Case Document Filed Page of CECILE DE JONGH DIRECT And that means that even if youre coming from the United States and going back to the United States you have to clear Customs before you get on a plane and go back to the United States Correct And so if Mr Epstein had guests with him and they were flying on his plane back to the United States theyd have to go through Customs before they left Correct So Customs would see whoever was with Mr Epstein on his plane MR TEAGUE Objection form You could answer THE WITNESS I would I guess I would assume so I mean I never been on his plane so I dont know By Mr Neiman Sure But according to how the rules work thats how it would work I mean whenever I leave here I have to go through customs Okay And Mr Epstein is writing to you and asking you who was in charge of customs for the Virgin Islands Eh-hmm Case Document Filed Page of CECILE DE JONGH DIRECT MR TEAGUE You to answer out loud THE WITNESS Im sorry yes By Mr Neiman Okay Im sorry And thats a federal official Yes Okay And he writes I used to have great relationship with Gloria Lambert the airport supervisor Do you know who Gloria Lambert is No I do not Okay And he writes I would like to know who is now in her place or her boss with Kenn Hobson now Do you see that I see that There is a Mr Carpenter who has been difficult lately not sure why Do you know who Mr Carpenter was I do not Okay And then you write back on this request from Mr Epstein to find out whose running Customs in the Virgin Islands You say I spoke to Kenn Do you see that Yes So Mr Epstein had this question about who is running Customs and wondered whether Kenn Hobson Case Document Filed Page of CECILE DE JONGH DIRECT would know And you followed up with Kenn Hobson Correct And Kenn Hobson was running the Port Authority at the time Correct And the Port Authority would have interactions with Customs I would assume yeah they would Right And in fact Mr when you withdrawn When you spoke to Mr Hobson he told you who was running customs in the Virgin Islands this Mr Harrigan right Yes And then you forwarded that information on to Mr Epstein Do you see that Yes And do you know anything about what the nature of Mr Epsteins relationship was with Mr Harrigan I do not Do you know whether Mr Epstein gave gifts to the folks at Customs I am not aware I was not involved I know that I think he asked me once about my Case Document Filed Page of CECILE DE JONGH DIRECT thoughts of giving turkeys or something but other than that Okay You remember Mr Epstein asked you if you thought it was okay for him to give a turkey to all the people who work at Customs at the airport I vaguely remember that people who would see who was on his airplane Yeah I vaguely remember that yes And you said that was okay Yeah I mean Did you check with anyone first before you gave that advice Well down here people usually give gifts to people at Department of Finance they give you know they give gifts to people who they normally interact with on a regular basis You know its similar to you know when you know my brother-in-law lives in a building where everybody gives a gift to the doorman you know So thats where I was thinking I had no reason to think anything untoward was happening Sure But you would recognize that Customs officials are not like the doorman in your building They are law enforcement officers right Case Document Filed Page of CECILE DE JONGH DIRECT Correct But And so my question to you was did you check with anyone before you told Mr Epstein it was okay to give this gift to the Customs official who could see who was on his plane Well MR TEAGUE Objection to form You can answer THE WITNESS No I didnt check with anyone but it doesnt matter whether I checked with anybody or not It was his decision whether he wanted to do that or not It wasnt my say-so By Mr Neiman Okay But you thought it was okay I just said okay if thats what you want to do Did Mr Epstein have relationships with other governors besides your husband MS BOGGS Objection vague MR TEAGUE Objection form Mischaracterization You can answer THE WITNESS Yes By Mr Neiman Which other governors did Mr Epstein have relationships with Case Document Filed Page of CECILE DE JONGH DIRECT Governor Mapp and Governor Bryan THE REPORTER With who THE WITNESS Bryan By Mr Neiman What was the nature of Mr Epsteins relationship with Governor Mapp as you perceived it Well Governor Mapp was not a friend of mine Okay And which reason I am pretty sure you are aware But I was just aware of the fact that he visited the island a few times and that I think that I was ccd on a few emails of schedules of meetings and things like that But I was never involved in any meetings never you know participated in any of the meetings and I never knew whatever it is they talked about I do know that and I dont know the dates I could only say that its I think Mapp got into office in and he was out in That Mr Epstein visited him at Government House once but I dont know when So thats the nature Okay And you said that Governor Mapp was not a friend and that I would know why What were you referring to Case Document Filed Page of CECILE DE JONGH DIRECT Well the fact that shortly after my husband left office he had him arrested THE REPORTER Im sorry THE WITNESS He had him arrested By Mr Neiman For what Because we decided not to live in Catherineberg because it was mold infested and I didnt want my children living there So we decided to live in our own home And they put up a security a little security house and a fence and got the funding through they passed it through the legislature And for political reasons people made hay of it And my husband you know three or four years before he came out of office said its okay when we get out of office Ill just pay everything back which we were in the process of doing and Governor Mapp decided that I believe because he never wanted my husband to ever run again decided to arrest him What happened And what happened was that they then said well you dont want to go to jail just pay all this money which was about a hundred and something thousand dollars more than what we determined was the Case Document Filed Page of CECILE DE JONGH DIRECT depreciated value And we had a certain date certain that we had to pay it back So what happened We paid it back Where did you get the money to do that We got some money from my mothers trust and Mr Epstein called me up and said Is everything okay whats happening And I said this is the position were in and were going to refinance our house for the rest of the money but I dont think that were going to be able to do it in time So he offered to lend us the money which he did immediately I asked him if we could pay it back within three years and he said No you have to pay it back within a year with interest And so he did that and we paid it back Okay So about how much money did Mr Epstein loan you at this time How did you pay it back We refinanced our house We took out we got we were able to get out We paid And then I for I had to forego any bonuses And then the rest of it we paid out of pocket Okay So a portion of the repayment was Case Document Filed Page of CECILE DE JONGH DIRECT foregoing bonuses you might otherwise have earned from your job Well it would be just give me the bonus and I had to write a check and pay it back Okay About how much of the repayment came from these bonuses All right How about Governor Bryan what was the relationship between Mr Epstein and the current governor I sort of had less knowledge of what was going on there Erika Kellerhals was close to Governor Bryan I mean Ive known Governor Bryan obviously because he was commissioner of Labor under my husband and he sat on a committee that I ran THE REPORTER That I THE WITNESS Pardon THE REPORTER It sat on a committee that THE WITNESS That I ran Childrens Cabinet that I ran And but I knew that Erika Kellerhals had arranged some meetings with him By Mr Neiman Okay Some meetings between Mr Epstein and Mr Bryan Case Document Filed Page of CECILE DE JONGH DIRECT Correct What is this Childrens Cabinet that youre referring to Its something that other states had done and we tried to replicate it here where we were you know we have Department of Education Department of Labor sort of heads of all the all the departments not all departments but departments that deal with children Police department And we would come together like every two months And so theyd help me with my book drives We did things like I would go to department of the police department and talk to the police about ADD and ADHD and how that affected especially young boys and that their acting out wasnt necessarily something that they needed to get arrested for go to juvie but to sensitize the police on how to treat children with that especially because you know it was more prevalent especially with ADHD more prevalent in boys We worked with the NEEKC Foundation on early childhood education and got implemented that all the early childhood centers one of our goals was to make sure that every child caretaker at least had a high school degree and that they worked Case Document Filed Page of CECILE DE JONGH DIRECT towards an associate degree because you know in the Virgin Islands at the time that we you know that John got into office it was felt that people would focus more on education in high school years and that really what we should focus on is the most important thing was zero to five And that if we had a solid zero to five then those kids could learn anything anywhere And that we wanted to sort of flip the dynamic And in order to do that we had to get everybody on board for that So we held quite a few symposiums on that and in acting with the NEEKC Foundation And so those were some of our goals Okay And you were the chair of the childrens Cabinet Yes And this was the other members of this cabinet were senior government officials Correct And then you ran it Yes Okay And that Childrens Cabinet helped to implement the governments policy Yes Well we tried to make sure that we Case Document Filed Page of CECILE DE JONGH DIRECT were in sync with governments policy THE REPORTER Im sorry in sync THE WITNESS In sync with the governments policy By Mr Neiman And as you were talking sort of this focus on early childhood that was an example of kind of implementing what the government wanted to do Correct Okay So do you recall Mr Epstein being influential in who the current governor appointed to various positions MS BOGGS Objection form THE WITNESS Of him being influential By Mr Neiman Yeah I would make some sort of recommendations of you know who I thought would be good in terms of because what he was seemed to be mainly concerned about was being able to build whatever he wanted to build on Little St James That was always a point of contention for me and for Erika because you know we never went over there So he would build whatever he would build Some with permits some without DPNR would find out They would get Case Document Filed Page of CECILE DE JONGH DIRECT upset Wed say you know here we are again He would get fined you know we call it a NOVA Notice of Violation I think he was got a Notice of Violation like three or four times under Johns administration I dont know about under Mapps administration The other thing that was very important to him was being able to get a hangar down at the at the airport He as I told you earlier I worked out a lease which took two long years to get for his helicopter and then he subsequently wanted to be able to get a lease or have a hangar built for his plane Okay So he cared who was running the Port Authority Because he wanted to be able to build a hangar All right And you remember enlisting Mr Epstein to support a particular candidate to become the head of the Port Authority Yes Tell me about that Just he seemed to have the ear of Albert Case Document Filed Page of CECILE DE JONGH DIRECT Bryan Who seemed to have the ear Jeffrey Epstein Eh-hmm And so I just said you know that Carlton Dowe would probably be you know best for you in terms of being able to get the hangar that you want Okay And you say that Jeffrey Epstein seemed to have the work of the ear right withdrawn Let me start again You said that Jeffrey Epstein seemed to have the ear of Governor Bryan What did you mean by that Well he I knew that I knew that they spoke And when Governor Bryan was setting up his cabinet and I knew that I knew that Carlton Dowe wanted I think he was there before Mapp let him go and he wanted to go back And I thought he did a brilliant job when he was there before and he would probably do a brilliant job again And that he would probably you know he seemed to be more business friendly rather than status quo When he was there before hed you know put in all these beautiful palm trees and Case Document Filed Page of CECILE DE JONGH DIRECT certainly made you know just made the place look welcoming And you know right now hes you know putting in new parking its you know its going well And so I just thought you know this is probably the guy that you would want to talk to to be able to build a hangar And so you suggested to Mr Epstein that he talk to Governor Bryan about appointing Mr Dowe Yeah Because you thought that Mr Epstein might be able to be helpful in getting Mr Dowe appointed Yeah Yes Okay And Mr Epstein agreed to do that Yes And he spoke to the governor about it That I dont know He didnt he he rarely ever came back circled back to me and told me what he spoke about Got it Okay So lets take a look at what we will mark Exhibit Deposition Exhibit No was marked for identification By Mr Neiman Exhibit is a email exchange between you and Jeffrey Epstein Case Document Filed Page of CECILE DE JONGH DIRECT Well yeah I know that Carlton had been appointed Do you remember I do recall that one of the reasons why it was necessary to do well we felt it was necessary to do that is because Erika Kellerhals was obviously Mr Epsteins attorney and Mr Epstein told me that she was dead set against Mr Dowe being going back to the Port Authority And so that was why we you know why I said hey if you can give him a good word give him a good word because I know that Erika Kellerhals was saying something else Got it So this was a situation where it was not a sure thing that Mr Dowe would get this job Yeah Correct Correct And you thought Mr Epstein could be influential in getting him the job Well I knew that he listened a lot to Erika Who listened a lot to Erika Mr Epstein I see So you were trying to persuade him Case Document Filed Page of CECILE DE JONGH DIRECT to back somebody that your thought Erika was trying to persuade him not to back Right I see Its a small island Understood Okay Tell me who Celestino White is Hes a former senator here I cant remember how many terms Maybe ten terms here Okay And he became a consultant Did he do work for Mr Epstein He did What was the nature of the work that Celestino White did for Mr Epstein He started out doing work for actually for Andrew Farkas The second time that John that my John ever met with Mr Epstein was in I think Mr Farkas was very very very upset and livid that when taxi drivers got picked up from WICO dock that they would completely bypass Yacht Haven Grande and go straight to town And he had all these shops and every you know invested all of this money And also that Case Document Filed Page of CECILE DE JONGH DIRECT people Okay And that but Celestino White was the specific recommendation of one person who might fit that role Yes And that Mr Farkas and Mr Epstein therefore thereafter hired Mr White Yes Okay Do you know how much they paid him No That no I dont Does your husband have any kind of financial relationship with Mr White No Do you have any kind of financial relationship No I do not Okay But may I complete my Sure Go ahead So and then subsequent to that Mr Epstein did hire Celestino White to he came up with the idea that he wanted to change the name of Little St James to Little St Jeff And he asked me and I said I have no clue how one would go about doing that And so he Case Document Filed Page of CECILE DE JONGH DIRECT called up Celestino White and went and did a contract with him And Celestino presented something and my did my own THE REPORTER Im sorry THE WITNESS Presented did a did a written proposal or something and it kind of died there By Mr Neiman Okay Did you ever recommend Celestine White to Mr Epstein I think might I have recommended it for the Little St Jeff thing For anything else Not that I can recall Okay Lets take a look at a couple of documents First let me show you what Im going to ask the reporter to mark as page a one-page document Deposition Exhibit No was marked for identification By Mr Neiman All right And this is an email from you to Mr Epstein on February Do you see that Yes This was Little St Jeff Let me just ask the questions so I make sure I got it Case Document Filed Page of CECILE DE JONGH DIRECT All right So this is in February of Yeah And youre recommending to Mr Epstein that he put Celestino on what you call a monthly retainer correct Eh-hmm What did you mean by that MR TEAGUE You have to answer out loud THE WITNESS Im sorry yes By Mr Neiman What did you mean by a monthly retainer in this context Because I knew Celestino wouldnt do anything for cheap Okay What do you mean by that I just knew he wouldnt you know if you paid him he would be like hes not going to do anything much but you know thats and when he wanted to do Little St Jeff this is probably the person that you and you know the one thing that I knew if you wanted to change a name you have to go to the legislature to do that And I am just said Im not the person to go down to the legislature to convince somebody to Case Document Filed Page of CECILE DE JONGH DIRECT change the name an island I got it And you write that after you say you should consider putting Celestino on some sort of monthly retainer you write That will get you his loyalty and access Do you see that Eh-hmm Well he is a consultant So what did you mean his loyalty and access Usually when you pay people you know I mean I dont know I dont know why I said that Just that he would he would be responsive to you He would he would you know make you a priority All right Do you remember Celestino doing any other work besides the Little St Jeff work He may have but I dont recall Okay Let me show you a document marked Exhibit Deposition Exhibit No was marked for identification By Mr Neiman Do you recognize Exhibit as an email exchange between you and Mr Epstein in August of I dont even know what this is referring to Well you see that the subject is Case Document Filed Page of CECILE DE JONGH DIRECT You see that Yes That was true right I was for a period of time yes And it also says he pays for the education of the governors children at the exclusive Antilles School on St Thomas That was true also He paid for my children and everybody elses children yes Well when you say everybody elses children you mean other employees of FTC Correct And other EDC companies that is normal par for the course for other EDCs to pay for their children It was normal and customary Okay We were not special Okay And you see down at the bottom of the page and this is good classic New York Post speak it says in the last paragraph de Jonghs flack didnt return our call Do you see that Eh-hmm Do you remember hearing that the New York Post was covering this issue I dont read the Post Sorry Case Document Filed Page of CECILE DE JONGH DIRECT Deposition Exhibit No was marked for identification By Mr Neiman Okay Lets take a look now at Exhibit You see at the bottom of the page Mr Epstein writes back to you I can enroll if that helps the school Do you see that Eh-hmm So hes now identified a third person with an Eastern European name who could benefit from English as a second language classes right MR TEAGUE Objection form You could answer THE WITNESS Yes those three names were there By Mr Neiman Okay Did it ever cross your mind to wonder whether there was something wrong with this convicted sex offender telling you I have three women who Id like to help learn to speak English MS BOGGS Objection vague argumentative THE WITNESS This is this is a person who had one offense had to register as a sex offender Didnt see him with any Case Document Filed Page of CECILE DE JONGH DIRECT Deposition Exhibit No was marked for identification By Mr Neiman Ms de Jongh this is an email exchange between you and Jeffrey Epstein in September of Do you see that Yes All right Looking at the email at the bottom of the page from Mr Epstein to you he writes I will play any role in this you guys like I could lend John the money so he immediately has it I would gladly be on the phone anonymous with John Quinn and the prosecutor offering suggestions a year for yours now with an income tax for the full amount now and in years et cetera Whats going on here Thats the note that I told you about when John got arrested with Mapp Ah So it is not John Quinn It is John and Quinn Its Mike Quinn Johns attorney Ah So he just didnt put a comma I guess Got it And this reference to a year for years now with an income tax credit for the full amount now and in years whats Case Document Filed Page of CECILE DE JONGH DIRECT that talking about I actually never knew what he meant by that because it was just you know we needed like or a little shy of So I just said I would you know discuss it with John You know he wanted you know to see if we wanted him if we wanted him to pay for our legal fees and we said no we got that covered It was just the issue of the Mapp administration at the time trying to squeeze us to pay immediately or go to jail which we thought seemed you know if its a criminal offense why ask us for money you know So And Mr Epstein was giving some advice about how to handle this criminal problem His advice was dont go to court just pay the money Okay And but he is offering here some various proposed structures for how to pay Is that fair Thats fair And one of them was to pay now but get an income tax credit for the full amount Yeah Case Document Filed Page of CECILE DE JONGH DIRECT And to do that as a convicted felon he needed to get his supervision moved from Florida to the Virgin Islands right Correct And you were passing on information related to that to the governor and the attorney general of the Virgin Islands About how to go about how one would go about doing that Right And then you spoke to your husband about it Yes And got some advice about what the best way it was to proceed right Yes Like who who would you talk to to get this done Did you also talk to the attorney general about it I didnt speak directly to Vincent THE REPORTER Sorry I couldnt THE WITNESS I dont I dont believe I talked directly to Vincent about it By Mr Neiman So your husband talked to the attorney general I think he did Case Document Filed Page of CECILE DE JONGH DIRECT And then relayed to you this information that youve set out in your email to Mr Epstein Yeah What he needed to do in order to get transferred here So you the attorney general and the governor are together helping Mr Epstein sort through how he can transfer supervision from Florida to the Virgin Islands How to legally get transferred here yes Okay All right You mentioned that he was in jail at this time Eh-hmm I dont I think he was on work release He was I never spoke to him once he was in jail Okay But he was withdrawn Do you remember him being on work release in the daytime and then going to jail at night I didnt I never knew his schedule Okay I just know that I hadnt spoken to him the whole time that he was incarcerated or in even on work release Okay But at some point in you were speaking to him about getting his future supervision Case Document Filed Page of CECILE DE JONGH DIRECT transferred Emailing yeah Well emailing but he says at the beginning of the email Call me when you get a chance right Right And usually I would call like Lesley Groth and she would THE REPORTER Who THE WITNESS Lesley Groff Because tens out of ten times out of ten I wouldnt have a number for him By Mr Neiman So you would call Lesley and she could reach him And she would patch me in to him Got it Okay All right Lets talk about a topic we touched on earlier today which is the sex offender registry Eh-hmm Do you recall discussing the topic of the sex offender registry as it related to Mr Epstein with your husband Yes Who else did you talk about that topic besides the governor Just the governor Case Document Filed Page of CECILE DE JONGH DIRECT You never talked to the attorney general about that topic No he talked to the attorney general about the topic Okay Tell me what he told you about his conversations with the attorney general on that topic Just that I asked him let me start backwards Sure Darren and Erika alerted me that you know all the states and the territories had to come up with their own SORNA laws and there was money attached to it and this was coming down the pike for the Virgin Islands Darren then said you know hey I read through everything and this particular portion is going to work for Mr Epstein because hes got a you know private plane whatever and he would like the notice to be shorter How do we go about doing that I talked to John about that He says well have whoever whoever Epsteins lawyer is talk to the attorney general And I believe at the time they asked Maria Hodge to do that in conjunction with Darren and also Erika Kellerhals Okay And there was kind of a back and Case Document Filed Page of CECILE DE JONGH DIRECT Through his attorney Maria Hodge yes And theyve reached agreement with his attorneys on what that legislation should look like correct Eh-hmm Yes Yes MS BOGGS Objection form By Mr Neiman And the attorney general endorsed the version that reflected the input of Mr Epstein and his lawyers correct MS BOGGS Objection to form THE WITNESS It appears so yes By Mr Neiman And then there was a state senator who needed to weigh in correct Correct Thats Mr Russell Correct Is that a first name or last name Senator Russell Senator Russell Hes the senate president I think he was the senate president at the time yes Yeah And you report in your email that Case Document Filed Page of CECILE DE JONGH DIRECT Senator Russell said this morning that he would accept the amendments and introduce them tomorrow Do you see that Yes How did you know that I think I called him and I asked him if he got everything if he got this and he said yeah yeah And now I cant remember whether I called him or I saw him at the seaplane shuttle or something and I brought it up and he said oh yeah I saw everything and its fine with me Got it So you had a conversation a direct one-on-one conversation with Senator Russell where he confirmed that he was okay with the version that had been worked out between the attorney generals office and Mr Epsteins lawyers Yeah I told him that Maria Hodge wrote something that was amending it and that and he said as long as the AG was fine with it I said it appears that he is and he said okay well lets bring it to the senate floor And there came a time when Senator Russell changed his mind Yeah He had no intention of making any changes Case Document Filed Page of CECILE DE JONGH DIRECT Or he did something that was different from what he told you is that fair It was par for his course Okay But am I correct that he told you one thing and then did something else Correct And what he told you was he was okay with what had been worked out between the attorney general and Mr Epstein correct In retrospect at the time I realized that he probably read anything He was just like yeah yeah yeah And then when it came down to the senate and he did read it he was he just wanted to go back to the way it was before Which And also I dont think the AG really pushed it either Do you know that or youre guessing No Im pretty sure that the AG did not push it either How do you know that I just remember that that he was not you know he was fine either way that if if if it went as original he was fine with it Got it Case Document Filed Page of CECILE DE JONGH DIRECT That we shouldnt make necessarily make any special arrangements for anyone So there was a process of working out a deal with the attorney generals office that the attorney general signed off on correct Eh-hmm Yes Yes But he didnt push for it with the legislature Is that what youre saying Correct Okay And then you write you send all this news to Mr Epstein and say Please call me when you have a moment Do you see that Yes Did you talk to Mr Epstein about it I probably did and just told him what happened Okay Lets take a look at do you remember what his reaction was To this Yeah I dont recall what his reaction was no Okay Lets take a look at another document which may help Case Document Filed Page of CECILE DE JONGH DIRECT off the improvements on the house right Yes Okay So thats one example Didnt you also ask him to contribute to a reception for Yes your husband Yes You You said campaign Okay Im just asking the question I know And Im just answering the question specifically what youre asking me Well you did ask him to raise money for a political event State of the Territory reception Yes Okay And Mr Epstein contributed to that event He did How much did he give I do not recall Okay Lets take a look Deposition Exhibit No was marked for identification By Mr Neiman is an email exchange between you and Mr Epstein Subject Fundraising Question You see that Yes Case Document Filed Page of CECILE DE JONGH DIRECT And you indicate in your email to Mr Epstein at a.m on January 24th that you are fund raising for the governors final State of the Territory reception correct Correct Thats a political event Yes And you needed to fund that event Well yeah I needed we had raised and we wanted to match the other All right So youre asking him if he would contribute to this political event Correct For the benefit of your husband Yes And Mr Epstein agreed to do that Yes Okay And then let me show you next do you recall asking Mr Epstein to contribute to the Democratic Party I may have I dont youd have to jog my memory Your husband was a Democrat correct Yes Okay So he would benefit by raising more Case Document Filed Page of CECILE DE JONGH DIRECT funds for the Democratic Party true Didnt seem to help him at the time but yes Okay Ill ask the court reporter to mark the next document Exhibit Deposition Exhibit No was marked for identification By Mr Neiman Exhibit is another email exchange with Jeffrey Epstein this one in October correct Eh-hmm And you asked Mr Epstein in the middle of the page How much would you like to give to the St Croix District Democratic Party Do you see that Eh-hmm And he says Yeah Do you recall any other donations that Mr Epstein made to the Democratic party This one is not on behalf of John Okay This is not solicited on behalf of John Well its do you recall any other contributions to the Democratic party that you asked Case Document Filed Page of CECILE DE JONGH DIRECT Mr Epstein to make other than this one Youd have to refresh my memory Im sure you have other emails so refresh my memory Do you recall asking him to contribute to particular Democratic candidates Yeah I always did And how about Stacey Plaskett in particular Do you remember asking Mr Epstein to contribute to her campaign Yeah I did Why did you do that I liked her All right Ill show you another document Ill ask the court reporter to mark Exhibit Deposition Exhibit No was marked for identification By Mr Neiman All right This is an email exchange between you and Jeffrey Epstein on June 19th correct Yes All right And you told Mr Epstein that his help was needed to try to get Stacey Plaskett elected to congress Do you see that Eh-hmm And you note that Shawn Malone the current Case Document Filed Page of CECILE DE JONGH DIRECT All right And so you told Mr Epstein that Shawn needed to be defeated and that Stacey was a friend and asked if any of his friends would give to her campaign Do you see that Eh-hmm Why were you asking for contributions from the friends instead of from Mr Epstein personally Dont I ask him for it too THE REPORTER Im sorry THE WITNESS I said am I arent I asking him in this for him too to give By Mr Neiman Do you read the sentence Do you think any of your friends would give to her campaign as a request for Mr Epstein to give Im reading this as you your friends Thats how Im reading this So you thought you were asking Mr Epstein in his email whether he or any of his friends Or any of his friends yeah Okay Why were you asking him to give to Ms Plaskett if you didnt ask him to give to your husbands campaign I just never Im I was notoriously bad about asking anybody for Johns campaign Case Document Filed Page of CECILE DE JONGH DIRECT against Got it And then Mr Epstein writes back to you Im sure darren rich bella ana would Do you see that Yes So hes identifying four employees of his who he thought could give to the campaign correct Yes And you say Ok should I ask them And he said Yes individually Do you see that Yes And did you go ask out and ask each of them I think more than likely I did yes And when you did that did you let them know that you know Mr Epstein wanted them to give Yeah And that was I take it you had to let them know that so that they would do it I didnt want them to think it was me It is not something I am comfortable with so it was easier for me to say Mr Epstein said Understood And were they all willing to give once they heard that this is what Mr Epstein wanted Case Document Filed Page of CECILE DE JONGH DIRECT Yeah All right Do you remember also asking Mr Epstein to give to the Democratic Party for Ms Plasketts benefit Yes I think that was on behalf of Erika as well Did he agree to do that I dont recall All right What year was that Do you recall in making that request No I dont All right How about Oh go ahead Im sorry I didnt mean to cut you off Thats fine What were you going to say No I just said I know that there was a donation later than that that he made that was rejected by the Democratic Party When okay Im sorry THE WITNESS Did you hear what he said THE REPORTER Yes By Mr Neiman Yeah Okay When did you hear that Case Document Filed Page of CECILE DE JONGH DIRECT I think that was trying to think of the years that she ran So she runs every two-years so it might have been Okay And What did you hear I didnt know I didnt know anything about the payment but then I heard in the office it was sort of a hubbub and Richard called down and was like theyre returning his money and then I think it became a story And Rich said he got yelled at by Jeffrey about you know why this money was sent and Jeanne Brennan who worked in the office said you know Cecile the instructions were explicitly said to send the money to you know to this so why is everybody upset at me Right And I said I dont know Sorry about that but you know they returned the money and that was the end of it THE REPORTER They were THE WITNESS They returned the money and that was the end of it By Mr Neiman Did you have any Case Document Filed Page of CECILE DE JONGH DIRECT understanding as to why the Democratic party Yeah because Im sorry just let me finish the question Just so that she can do her job Thats all I know you anticipate what Im asking you Did you have any understanding of what the Democratic Party decided not to accept the money from Mr Epstein Because he was a registered sex offender Did the fact that the Democratic Party wouldnt take his money give you any concern about whether you should continue Yes I was concerned that they were concerned yeah Did you do anything about it No I didnt do anything about it Do you remember Mr Epstein donation to a Super PAC for Mr Mapp No yeah Yeah I dont recall that Okay Let me show you a document which I shall ask the reporter the mark as Exhibit Case Document Filed Page of CECILE DE JONGH DIRECT Deposition Exhibit No was marked for identification By Mr Neiman All right You see there an email from Mr Epstein to you in September of asking the check be prepared for Mr Mapps Super PAC for Yeah You see that Eh-hmm Do you remember what this Super PAC was I dont because I dont I dont cut checks Eh-hmm I think he I see Rich is on here Hes got Governor Mapp on here So Rich would have been the one to cut the check Got it And so youre not sure who it was No I wouldnt I in all honesty wanted to know as little as possible about Mapp as possible Understood MR TEAGUE Could we take a break in about five minutes I need to take a restroom break too MR NEIMAN Absolutely Ask the reporter to mark this three-page Case Document Filed Page of CECILE DE JONGH DIRECT Internal Revenue they would deem it as like a hotel because he had so many buildings Eh-hmm Separate buildings and we had to convince them that it wasnt it wasnt a hotel And he and also he would bring in so many like tons of furniture Just a lot of supplies Eh-hmm And so through Customs and excise or whatever And so they just kept saying oh this has got to be a hotel or a small boutique hotel So wed always have to you know Darren or Erika would have to write a letter saying this not a hotel its a home Okay Was part of what was raising all those questions the number of people who were coming to the island No It had more to do with the fact that why are you bringing in all this all this stuff that comes through Tropical and has to be cleared through Customs all his trees all his all construction supply materials Okay Do you remember there being times when the government of the Virgin Islands itself turned to Mr Epstein as a potential source of cash Case Document Filed Page of CECILE DE JONGH DIRECT I vaguely remember him asking about collateralization or something but What do you remember about that Just him asking if I could ask John about how one goes about collateralizing a loan to the government So the idea was that Mr Epstein could loan the government of the Virgin Islands cash in exchange for the government posting properties as security Yes Thats the gist of it yes Are we done with this Yeah All right So take a quick look at this document which well have the court reporter mark as Exhibit Deposition Exhibit No was marked for identification By Mr Neiman So youll see at the bottom of the first page of Exhibit theres an email from Mr Epstein to you that says the government The vi government is desperate for cash Do you see that Yes And then he asks Does John know of any asset they might have that I can use as collateral Islands etc Do you see that Case Document Filed Page of CECILE DE JONGH DIRECT Yes Where did Mr Epstein get the idea that Virgin Islands government was desperate for the cash It wasnt from my husband because my husband was not governor at the time Ah this is after your husband left Do do you have any idea where he got the idea that the government was desperate for cash Well do you want me to make an assumption Tell me what you think What I think is that he was probably speaking to Governor Mapp and Governor Mapp probably said we only have amount of money left in the coffers to pay you know payroll et cetera and I need we need cash And MR TEAGUE I just want to object to the extent that this calls for speculation But you can continue to answer By Mr Neiman You can continue And you know he turned to Mr Epstein and said youre a finance guy you know could you help me out The idea being maybe you Mr Epstein could loan me some money Case Document Filed Page of CECILE DE JONGH DIRECT MR TEAGUE Same objection THE WITNESS Sorry I didnt mean to shake my head I am making that assumption yes By Mr Neiman Thats what you understood from this email exchange you had with Mr Epstein Yes Well I didnt think that hed want to take property for million just for nothing THE REPORTER He wouldnt THE WITNESS He wouldnt want to take wouldnt want to take property as collateralization just for nothing And he starts out the email by saying the V.I government is desperate for cash By Mr Neiman Right So as you understood it from your communications with Mr Epstein the problem was that the government was desperate for cash correct Correct MS BOGGS Objection Calls for speculation By Mr Neiman And as you understood from your discussions with Mr Epstein the potential solution was for Mr Epstein to provide some cash in Case Document Filed Page of CECILE DE JONGH DIRECT exchange for islands as collateral Or land as collateral yes Okay And being short of cash is kind of a perpetual problem for the Virgin Islands government fair MS BOGGS Objection speculation MR TEAGUE Same objection form THE WITNESS It was until about three or four years ago yes By Mr Neiman What happened three or four years ago COVID Ah And that was good for the Virgin Islands Very good MR TEAGUE Objection form THE WITNESS Oh MR TEAGUE You can answer By Mr Neiman You can answer Yes Seemed very good yes Okay Prior to COVID for a long time the Virgin Islands had been strapped for cash Well since the MS BOGGS Objection Speculation THE WITNESS Since the financial crash Case Document Filed Page of
57,068 characters
