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 DENISE GEORGE VOLUME II 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 DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com Attorney General And in waiving that I think he reduced it to I dont remember whether it was a day or something like that Im not sure But he definitely waived the reporting requirement BY ATTORNEY OLAUGHLIN Do you know what the basis for that waiver was A I cant say what the basis of it is because you know Im not going to go into his heads My main thing is that you know he did that I reviewed some documents that she she attached And so I dont know I cant speak for him or what was before him or or what went through his mind I was only looking to that because I had to make a decision as far as what was before me and so And in preparing yourself to make that decision did you uncover any basis for what the prior waiver Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f grant was ATTORNEY ACKERMAN Object to form THE WITNESS Not really I was just you know Im not there I dont know what his what the Attorney General is facing So I can only look at the files and I can look at this record and the record in the files as far as when he entered the waiver and just read whats there But I have no way of knowing what else the Attorney General at the time was looking at or anything like that But just based on just what I saw I had to make an assessment of whether or not theres anything in there that would be sufficient for me to even consider whether or not he ought to get a waiver BY ATTORNEY OLAUGHLIN The change the resending of the waiver under Attorney Thomas-Jacobs Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f think that there was justification for it I think overall thats what it seemed that I saw from her review of it Okay So it had the earlier waiver been improperly granted because there was no justification for it A Well I wouldnt say that I wouldnt say that that it was improperly I dont know whether it I have nothing to do with what any prior person did In under the law it states that a waiver can be granted if it is if it is shown or proof is shown to the satisfaction of the Attorney General that the person the sex offender travels internationally frequently for business or for other legitimate purpose So thats what is for the Attorney General to decide So as far as Im concerned whatever happened before that was of no concern to me My thing is that there is a request Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f thats before me and Im going to have to make the decision based on whats before me and it had to be information thats satisfactory to me But it its obviously a discretionary thing But I had to make it according to what is satisfactory to me It really didnt matter so much to me as far as what was satisfactory to Vincent to Attorney Vincent Frazer or what was satisfactory to Attorney Jacobs Once I stepped in and the request was made to me I had to look at everything that was before me and make that decision independent of anything that happened previously What did you do in response to this letter ATTORNEY ACKERMAN Object to form THE WITNESS Well I did I did eventually send a an answer to her and my decision Giving her my decision and making it clear that Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f that purpose So you didnt see any evidence that would have supported a granting a waiver under USVI law correct ATTORNEY ACKERMAN Object to form THE WITNESS That would have been satisfactory to me No That has been satisfactory to me I saw nothing that would have that would have proven to me giving reliable proof that thats what hed be doing in order to warrant any kind of waiver BY ATTORNEY OLAUGHLIN So were the previous waiver grants improper under USVI law A Previous waiver grants Yes ATTORNEY ACKERMAN Object to form THE WITNESS I wouldnt well the reason why I would not say it I would not say it is And the only reason why is because its a Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f discretionary matter Maybe it was satisfactory to I guess it was only Vincent Frazer that issued the waiver But maybe maybe it was satisfactory to him I dont know Im not in a position to know what he was considering or what was before him I just knew my whole thing is like irrespective of what he looked at or what was satisfactory to him or what was satisfactory to Attorney Jacobs I had to make the decision as far as what was satisfactory to me And I was there at that time And in looking at that I made it very clear that it can only be waived upon that showing I made that clear because I wanted to make sure make it clear to Jeffrey Epstein that hes going to have to comply with the law and what is required in order to get a waiver And that I will not be a part of him trying to exert any kind of you know political influence or anything like Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f that Im not going to be a part of that Hes going to have to look at the law Hes going to have to produce the proof as required by law that is to my satisfactory satisfaction And I did not see that BY ATTORNEY OLAUGHLIN Do you think that the prior decision may have been politically influenced A I have no ATTORNEY ACKERMAN Object to form THE WITNESS I have no idea BY ATTORNEY OLAUGHLIN Is it possible A I do not I have nothing to say regarding that because I was not there and I was I have no idea what you know I dont know I cant comment on what you know prior Attorney General had That wasnt thats not even my role to do that I Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f THE WITNESS Yeah I dont mind speaking with you ATTORNEY ACKERMAN Okay We need to go off the record because I need to know what this answer concerns before I can determine whether its privileged or not ATTORNEY OLAUGHLIN Okay Lets go off the record VIDEOGRAPHER Off the record at Off the record Back on the record VIDEOGRAPHER On the record The time is P.M BY ATTORNEY OLAUGHLIN Okay Ms George I understand that you have had the opportunity to confer with your counsel Correct A Yes Yes And theres theres a communication prior to litigation that you wanted to give testimony about A Yes I just wanted to Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f complete my testimony with respect to the communications with the Governor regarding the sex offender registry issue Okay A So that letter the date that letter was sent that E-mail correspondence was sent to Attorney Kellerhals and Attorney Rivers I also sent one to Governor Bryan a similar one But just explaining to him the what the laws are and that there is a requirement that he comply with providing proof And that my decision was until that proof was provided that I would not be able to consider I would not consider you know any waiver I also indicated to him that the reasons for it and the reasons the reasons that the reason or the purpose behind the statute And that its there to protect the community and the importance of that Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f And I did that just so that you know that he can have an understanding I felt that he needed an understanding as to the importance and the magnitude of that requirement And then he just responded well thank you for your well Im seeing what his response is But he was just he just said Well thank you for your work on this And after that there was nothing And the response from the Governor was that in E-mail form as well A Yes That was E-mailed to me Okay Was anyone copied on that E-mail A No Do you still have a copy of that E-mail A I might have a printed version but I might Okay Was this request that you received from the Governor were Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f saying that there was I dont recall any conversation or anything where the Governor reached out since that you know last communication And which is why I indicated there was a response to my letter to him that ended the communication Nothing else after that pre-litigation BY ATTORNEY OLAUGHLIN Did the position that you took in response to the Governors request regarding Jeffrey Epsteins sex offender monitoring impact your standing with the Governor ATTORNEY ACKERMAN Object to form THE WITNESS At that time I dont know with respect to how he perceived it but his response to my decision was just thank you for the work you did on it and thats it BY ATTORNEY OLAUGHLIN Knowing what you know now do you think it impacted your standing ATTORNEY ACKERMAN Objection Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com YVer1f DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase July EsquireSolutions.com
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