IBIT 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 CAROL THOMAS JACOBS THURSDAY 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 CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com in at least I wasnt aware and I dont know if anyone at Attorney Generals Office was aware of these allegations in BY ATTORNEY NEIMAN And do you know if the Attorney Generals Office in the Virgin Islands did anything at anytime prior to to try to see what kind of allegations were being made in publicly filed lawsuits regarding Jeffrey Epstein ATTORNEY ACKERMAN Object to form THE WITNESS Im not aware of any BY ATTORNEY NEIMAN Would you agree with me that it would have been appropriate for the Virgin Islands to make efforts to find out what kind of allegations were being made against a prominent resident like Mr Epstein in publicly filed lawsuits ATTORNEY ACKERMAN Object to Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f form THE WITNESS If they were aware But like I say I dont know if anyone at the Virgin I dont know if anyone at least I can only speak as to myself I know I wasnt aware and I dont know if anyone in the Attorney Generals Office was aware BY ATTORNEY NEIMAN No I understand that But Im asking you a slightly different question which is given that Mr Epstein was a registered sex offender living on the Virgin Islands and given that he had been granted various waivers of the ordinary registration notification requirements and given the difficulties that the Virgin Islands had with the annual monitoring visits do you agree with me that it would have been appropriate given those facts for the law enforcement in the Virgin Islands to make efforts affirmatively to monitor what was Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f being alleged about Mr Epstein in publicly filed civil lawsuits ATTORNEY ACKERMAN Object to form THE WITNESS If they were aware of the publicly filed lawsuits and I I have no information that the Virgin Islands was aware of this lawsuit in BY ATTORNEY NEIMAN Are you aware that it is not hard to learn of publicly filed lawsuits if you tried ATTORNEY ACKERMAN Object to form THE WITNESS You know I dont know I dont know what I dont know BY ATTORNEY NEIMAN Okay Do you think that the Virgin Islands should have at least tried to find out what was going alleged in publicly what was being alleged in publicly filed lawsuits regarding Mr Epstein Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f ATTORNEY ACKERMAN Object to form Asked and answered THE WITNESS The Virgin Islands can only respond to what they know And like I said I dont know if anyone in the Virgin Islands knew I was not aware and I dont know if anyone was aware in BY ATTORNEY NEIMAN All right Im going to ask my question in a slightly different way but same same question Do you think part of the Virgin Islands responsibility for protecting the community included making efforts to try to learn what was being alleged about Mr Epstein in publicly filed lawsuits ATTORNEY ACKERMAN Object to form THE WITNESS The Virgin Islands can only take action on what they know And Ive said it I have no information that they were aware of this Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f We have met before I am David Ackerman with the law firm of Motley Rice We represent the Government of the Virgin Islands in this action Im just going to have a few questions for you And I want to start with that document that was marked as Exhibit Can you pull that in front of you A Yes And this is a document thats entitled Complaint Do you see that A Yes Okay Does the document indicate where the Complaint was filed A It says United States District Court Southern District of New York Was this Complaint filed in the Virgin Islands A No it was not Okay In your opinion do you believe law enforcement has an Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f obligation to monitor public dockets of every court in the country for allegations that may reference the Virgin Islands A I dont I think its unreasonable It would be an unreasonable obligation on the Virgin Islands Okay Thank you We can put that document aside Lets go to Exhibit which is that big document And I want to start with the page that is I apologize I need to find it near the end of the document Are you there A Yes And this is the E-mail chain that counsel showed you involving Clive Rivers and Denise George And you were copied on several of these E-mails is that correct A Yes Okay If you would look please at the second page at the very Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f bottom And there is an E-mail that AG George sent to Attorney Kellerhals and Attorney Rivers on June 2nd A Uh-huh Do you see that A Yes And then that E-mail continues over to the next page correct A Yes And if you look at the second full paragraph on the next page which is Bates numbered A Yes do you see the section that says While my predecessors have apparently had differing interpretations of Title Section of the Virgin Islands code Did I read that correctly A Yes Okay In your experience in government is it unusual for different office holders to have differing interpretations of statutory provisions Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f A This is something you know it happens Different Attorney Generals give different can have a different opinion on a particular issue Okay Are you familiar with Section of the Virgin Islands code A Yes And did you become familiar with that section in connection with your review of materials relating to Mr Epsteins sex offender registration ATTORNEY NEIMAN Objection to form leading THE WITNESS Yes I did BY ATTORNEY ACKERMAN Okay Let me ask the question differently How did you become familiar with that section A When the matter was the issue was brought to me by Attorney Shani I reviewed the statute Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f Okay Does that statute say anything about the Attorney Generals role in the notification requirements A It gives the Attorney General the discretion to modify the notification requirements Okay Do you have any any understanding as to whether Attorney General Frazer was exercising his discretion in granting a waiver A From his letter thats what it appears Okay Do you believe that Attorney General Frazer did anything inconsistent with the statute in granting the waiver to Mr Epstein A Attorney Generals are free to exercise their discretion however they see fit And he exercised his discretion one way and I when I was sitting Attorney General I exercised my discretion in a different manner When you were sitting Attorney Case Document Filed Page of CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com YVer1f CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com CAROL JACOBS U.S VIRGIN ISLANDS vs JP MORGAN CHASE July EsquireSolutions.com
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