Case Document Filed Page of EXHIBIT Case Document Filed Page of DENISE GEORGE ol II Go Virgin Islands JP Morgan Chase UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NUMBER CV JSR ACTION FOR DAMAGES GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Plaintiff vs JP ORGAN 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 Re orter CRR Certified LiveNote Reporter CLR Registered Professional Reporter RPR Notary Pu bl ic FLORIDA July DEPO Esqu i reSo lu i ons.com Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase anything Any other types of contact that would not have anything to do with the litigation and the you know the enforcement action against him or against the Estate ul Okay So have you ever spoken with former Attorney General Frazer about Epstein A No Okay Have you ever spoken with Governor former Governor Mapp about Epstein A No And we have already talked about you have spoken of course with Governor Bryan We talked about that on Monday correct A Yes Okay You mentioned that as part of the process that you undertook when you assumed the position of AG was you were curious and you went looking for articles and information about Epstein corre ATTORNEY ACKERMAN Object to DEPO Es qui re So lu i co Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase form THE WITNESS What I that is not entirely what I said as I indicated I didnt just start looking for articles on Epstein Once I came on board as Attorney General in April there was a lot of media allegations or reports and everything from the media Even inquiries from the media with respect to allegations and reports of misconduct sex trafficking and those things by Mr Epstein on Little St James island And that allegations had been going on for many years and a lot of victims of this sex trafficking and its sex sexual exploitation These are reports that were corning from the media even members of the media would be would have been calling and even before I got there And I was advised when I got there that this was that there had been a lot of inquiries with respect to that July Esquire Solutions com Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase issue about you know Epsteins misconduct in the sex trafficking operation occurring on Little St James So having heard all of that of course it was all what I consider hearsay because you know it comes from just reports from the media and everything I was of course interested in looking because the allegations were really horrific So I then started to really not only inquire about whether we have solid complaints But I started to really you know just research read the news read the news articles media As well as reports from regarding Courts and Court documents that were available just to study and to get a background And get a gist of you know just whether or not you know theres anything credible or anything that occurred with respect to this to actually understand what went on ul DEPO Es qui re So lu i co Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase E-mail and then the second is the attachment to it A Oh okay July ATTORNEY OLAUGHLIN In fact Madam Court Reporter if we could enter it as a single exhibit that might be better but defer to defer to you THE WITNESS Okay BY ATTORNEY OLAUGHLIN Do you know who Jason Marsh is A Yes Jason Marsh is a law enforcement officer I think when I became Attorney General in he may have been acting police commissioner at the time before Governor Bryan appointed a police commissioner Okay So Jason Marsh is sending a PDF scan hes made of the Virgin Is la nds Daily News source with the title Lawmakers issue call for investigation of Epstein deal Do you see that Esquire Solutions com Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase ATTORNEY ACKERMAN Object to form foundation THE WITNESS Give me a second Okay I see the second page ATTORNEY OLAUGHLIN Yeah THE WITNESS Im looking at page in Thats thats dated Saturday December 8th ATTORNEY OLAUGHLIN Yes THE WITNESS I mean THE WITNESS Okay Yes Im seeing it BY ATTORNEY OLAUGHLIN And theres a paragraph thats in the fourth column in from the left that starts with the words The Heralds examination A Okay It says The Heralds examination yes So it says The Heralds examination of thousands of court records E-mails and FBI records also showed that after the deal was struck it effectively shut down an ongoing July Esquire Solutions com Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase is but I dont know her I didnt even know her at this time Okay So this is the first this letter that you received is the first time you had interacted with her A Yes I believe though that I may have been introduced to her a couple of years ago before I was even an AG at the but Im not Im not sure I think she was in a group of people But other than that Ive never had any contact with her or anything July Okay And what was the reason for the outreach A The reason for this Uh-huh A Well as per Governor Bryan telling me that you know Jeffrey Epstein wants to have this waiver of the travel requirements and that he said that his attorneys will be contacting me and encouraged me to meet with the attorneys to consider Esquire Solutions com Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase it I this must be the follow-up letter In this letter in their is a letter where she is requesting on behalf of Jeffrey Epstein for a waiver and for as she indicated a reinstatement of the waiver that Attorney Vincent Frazer had entered years ago years before And I suppose a revocation of what Thomas-Jacobs did So she went through that whole thing about what was done Were you aware of what the previous conditions granted by Attorney Frazer were A At this point I was because in anticipation of you know after speaking with the Governor I had gotten as I indicated I went to the Deputy Attorney General Attorney Jacobs to get that briefing the background And it was in getting that from Attorney Jacobs that yes that July Esquire Solutions com Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase answer A Oh okay I said that Im not looking for any specific documents because Im not I dont know what to look for You need to know what the proof is You know because I looked at this and it seems sort of silly to me because you know its like youre making a motion its like making a motion before the court and then asking the judge Can you tell me judge what I need to produce in order to prove this so you can grant it I mean its whatever is the proof that they have only they can have it I dont have it But if they cant find proof that he has engaged or he has to be engaged in legitimate business or for legitimate business purposes internationally to the to the level that he is going to need a waiver of the travel requirements Its only for them to know what that is And if they dont have it July Esquire Solutions com Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase then they dont have it But I just wanted to make it clear that thats the only way that Im going to consider a request if they submit that proof And if you dont know what that those documents are to prove that thats it seemed to me that well maybe you dont have it But Im not going to answer that question like what specific things that you need when I dont know Thats for her to do Thats for the for Jeffrey Epstein to do And A submit that proof And prior to receiving this E-mail you had looked through Epsteins sex offender registration file to see if there was any reasonable and re lia le proof correct A Based on what was in there Based on what was in there I saw nothing that convinced me that there July Esquire Solutions com Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S Virg in I ands vs JP Morga Chase was any reasonable or reliable proof You know nothing satisfied me with respect to that that would have warranted or justified any waiver So as it was thats why my decision was no that I would not do it unless proof is shown But nothing was shown there And I just had to make it clear that unless they show that show proof and submit proof Im not going to even consider it much less act favorably on the request irrespective and I said I realized there was some political maneuvering that he was doing Just the fact that he as a sex offender got the Governor to come to me for that request which is unusual Which I imagine is unusual because a sex offender ust goes and applies to the Attorney General directly if they want some kind of a waiver So I know that was in play and I just wanted to again let them know and reiterate that the only thing ly DEPO Es quir So lu i co Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase it is not so much a problem Using his political influence is what it appeared to me that Jeffrey Epstein was doing was trying to use political influence that he may have had with the Governor in order to boost or help me to rule favorably And thats what I was thinking at the time And so it just my position was just to make sure that he knows that is not happening I would not be a part of that and to let him know what hel need to submit BY ATTORNEY OLAUGHLIN What led you to think that Epstein was exerting political influence A Well I think ATTORNEY ACKERMAN Object to form THE WITNESS Well for me what what led me to think that is just the fact that the Governor approached me on behalf of him requesting about this request July Esquire Solutions com Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase saying that he requested it that that alone Because not every sexual offender or any person you know are in the position to have the Governor make the request to the Attorney General rather than just coming and making it on their own directly to the Attorney General That by itself indicated to me that he was flexing his political influence over or with the Governor in an effort to get a favorable result in what I considered to be definitely a law enforcement issue by the Attorney General And so thats what certainly just that alone raised that red flag And then the subsequent reminder coming from the Governor not by Attorney Kellerhals and not by Jeffrey Epstein But coming from the Governor to remind me that I have to make or I need to make a decision on Epstein that also indicated to me definitely that theyre using that ul DEPO Es quir So lu i co Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase political influence or that there that there is or there exists some degree of political influence that Epstein is willing to use through the Governor Because even then you know the question is why is this a priority Well maybe to show that this is the Governors priority or some for some reason But to answer your questions those are what was in my mind that made it clear to me that he is exercising some kind of political power in order to get a certain result from me with respect to applying the laws here BY ATTORNEY OLAUGHLIN Did you think that the outreach by the Governor on behalf of Epstein was improper ATTORNEY ACKERMAN Object to form THE WITNESS I do BY ATTORNEY OLAUGHLIN ul DEPO Es quir So lu i co Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase Why A My thoughts about that even then in particular then it did not sit right with me Because my thing is first of all why is the Governor you know getting involved in this matter that is a law enforcement matter Or only the Attorney General to make based on law and that he was doing so on behalf of a convicted sex offender a sexual offender child predator this person Jeffrey Jeffrey Epstein That was troubling to me I didnt go much further than that but that was definitely troubling to me Were there A that he made he said it will come in and I would definitely the request came in and then I did just as any request would come I waited until the request came from the attorney and then I responded once that a request came properly came ul DEPO Es quir So lu i co Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase You testified on Monday that there were several other outreaches by the Government by the Governor involving Epstein correct A Pre-litigation there was just that additional reminder on May 14th that was a text reminder regarding the sex offender registry where he said you must you need to make a decision on Epstein So were A So I but yeah So were there any other outreaches of a similar nature from the Governor ATTORNEY ACKERMAN Object to form And hold on because theres privilege issues here Are you talking about pre-litigation or post-litigation ATTORNEY OLAUGHLIN Pre-litigation ATTORNEY ACKERMAN Yeah pre-litigation okay THE WITNESS And youre July Esquire Solutions com Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase complete my testimony with respect to the communications with the Governor regarding the sex offender registry issue kay 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 ul 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 it there to protect the community and the importance of that DEPO Es quir So lu i co Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase 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 July Esquire Solutions com Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase occurred soon after I came on So in that sense probably around the same time BY ATTORNEY OLAUGHLIN And so did that background research and investigation you were doing into Epstein impact the way in which you viewed the Governors request to you ATTORNEY ACKERMAN Object to form THE WITNESS No I wouldnt say that impacted it Just the fact that the request was made on behalf of Jeffrey Epstein a sex offender through the Governor instead of the regular channels was was mainly what was concerning with respect to that BY ATTORNEY OLAUGHLIN Right But werent you finding through your own research that he wasnt just a registered sex offender There seemed to be a lot more information out there about his ul DEPO Es qui re So lu i co Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase misconduct correct A Well ATTORNEY ACKERMAN Object to form ul THE WITNESS Well there were allegations yes definitely Allegations of what happened before Remember hes not just a registered sex offender Hes a convicted child a child molester a predator I don you know so that was in and of itself sufficient to raise concern for me The fact that all of this other stuff was corning in Im still in the process of processing it actually and looking it up and all of that It may have you know at the time maybe it was part of why I wanted to make sure that its legitimate business And I didnt see that you know anything any proof that the business would have was legitimate And thats why I was looking for that DEPO Es qui re So ut i co Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase specific information that there would be legitimate purposes for him to want to go to these countries BY ATTORNEY OLAUGHLIN So you were particularly sensitive to a request regarding Epstein from the Governor because at the same time you were seeing all of this reporting through your own investigation correct A I wouldnt say ATTORNEY ACKERMAN Objection THE WITNESS that it was ATTORNEY ACKERMAN Hold on Attorney George Objection to form misstates prior testimony argumentative THE WITNESS Yeah I didnt say I was particularly sensitive with respect to that It was just just that just corning from the Governor a request of Jeffrey Epstein that was that should have come directly to the ul DEPO Es quir So lu i co Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase Attorney General But going towards him he gave me the impression that he was using political influence to try to get a result a favorable result that he wanted Any other even if it was another sex offender and the Governor came to me I would have been like um you know because it the correct channels would be well go and you know you make your request to the Attorney Generals Office BY ATTORNEY OLAUGHLIN Were there any other instances of the Governor reaching out regarding Epstein through what you viewed as the incorrect channels ATTORNEY ACKERMAN Object to form and object to form You can answer THE WITNESS Yeah This sounds like the question you asked me before we went on break I dont know if it any different But as I was ul DEPO Es quir So lu i co Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase 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 Governor 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 ul DEPO Es quir So lu i co Case Document Filed Page of DENISE GEORGE Vol II Gov U.S Virgin Islands vs JP Morgan Chase to form THE WITNESS I believe at the beg I believe its likely BY ATTORNEY OLAUGHLIN Why ATTORNEY ACKERMAN Objection THE WITNESS Its likely that it did because I was doing something where I was you know doing my work and doing my job without respect to any political interference or anything And he did not ask he did not tell me what decision to make but at the same time for whatever I dont know how it would have impacted him But I think that it could have because I am always determined to stand for what it is that I believe is right based on my on my position as to having make law enforcement decisions And I make them irrespective of anything as far as who the people are or what or whatever July Esquire Solutions com Case Document Filed Page of DEN I SE GEORGE Vol II Gov U.S i rg in I ands vs JP Morga Chase political influence or power they may have And maybe that might have been the first time that he might have been faced with that I dont know what his response was but I will say that it could be very well the beginning of of that and it could have impacted it BY ATTORNEY OLAUGHLIN Do you think that your approach of standing for what is right impacted your career as the Attorney General of the USVI ATTORNEY ACKERMAN Objection No Ob ection This is well outside the scope This has no relation to the topics I am instructing the witness not to answer This has nothing to do with the sex offender registry ATTORNEY OLAUGHLIN Okay Lets go to the Court David ATTORNEY ACKERMAN Let go what ul DEPO Es qui re So ut i co
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