EXHIBIT Case Document Filed Page of Case Document Filed Page of CAR JACOBS U.S 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 MORGAN CHASE BANK N.A Defendant VIDEO RECORDED DEPOSITION OF CAROL THOMAS JACOBS THURSDAY JULY REPORTED BY DENISE HARPER FORDE Certified Shorthand Reporte CSR Certified RealTime Reporter CRR Certified LiveNote Reporter CLR Registered Professional Reporter RPR Notary Pu lic FLORIDA Jul DEPO Esqu i reSo lu i ons.com Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE A I reviewed the file and I consulted with Shani regarding course of action Jul Okay And what did you decide to do A I decide to modify his waiver that was in there that he had before the And when you say you decided to modify the waiver that he had before can you explain to me A Well what you mean A Wel Attorney Genera Frazer Uh-huh A had granted Mr Epstein a waiver of certain requirements which and so I after I reviewed I decided to modify that waiver And why did you decide to modify the wa i ver A Because I did not upon my review Uh-huh DE Es quir So luti co Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE A I did not see anything in the file to support the waiver kay When had the waiver occurred as best you can recall A I am I don recall right now i tting here Jul All right Well look at some documents in a minute A kay But did Shani explain to you withdrawn Mr Frazer had been the AG from the to time period Does that sound right A Yes kay And so this was a waiver that had been at least several years prior to when Shani came to you A It was kay Did Shani explain why she was coming to you now about a waiver from many years ago ATTORNEY ACKERMAN Well objection You can answer that DE Es quir So luti co Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE conduct BY ATTORNEY NEIMAN So from your point of view part of this notification requirement is for the protection of the community ATTORNEY ACKERMAN Object to form Jul THE WITNESS Yes that just a thats the purpose BY ATTORNEY NEIMAN When you looked at this issue about the adequacy of what had been done with regard to Mr Epstein notification requirements in the past ATTORNEY ACKERMAN Object to form THE WITNESS Yes I was concerned BY ATTORNEY NEIMAN Can you explain A Wel I after on my review I thought that every effort should be made to comply with the DE Es quir So luti co Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE statute as closely as possible Okay And had that been done in the past ATTORNEY ACKERMAN Object to form THE WITNESS Well I think the statutes allows their Attorney General the discretion to make modifications and so to the basic requirements And I felt that I wanted to stick closer to the basic requirements of the statute BY ATTORNEY NEIMAN kay And why was that A Again because to protect our community Uh-huh Were you surprised when you saw the waivers that had been granted to Mr Epstein previously ATTORNEY ACKERMAN Object to form Jul THE WITNESS Was I surprised Yes BY ATTORNEY NEIMAN Exp ain Es quir So luti co Case Document Filed Page of CAROL JACOBS VIRGIN ISLANDS vs JP MORGAN CHASE A I was how do I explain I was surprised Thats I just felt that at least for me the better course would have been to have him comply as strictly as possible to the statute July Okay What happened after you sent this letter ATTORNEY ACKERMAN Object to form THE WITNESS Well what happened is that I think it was sent to him BY ATTORNEY NEIMAN Uh-huh A My understanding it was sent to him and that he had to come in in person to if hes to notify us Uh-huh A I believe and I believe that was done Because if wasnt done I want to believe Shani would have notified me Uh-huh Okay And did you ever get contacted by anybody either Esquire Solutions com Case Document Filed Page of CAROL JACOBS VIRGIN ISLANDS vs JP MORGAN CHASE Uh-huh A I dont have all the facts before me I dont know i there were other communications I just dont know So again I dont think Im the best person to ask I th i nk the best person would be the person who is responsible for the sex offender registration BY ATTORNEY NEIMAN Okay But ust for purposes of my questions now ust assume for a second with me that the context the compliance checks reflected in these documents are the only compliance checks that were done Okay Just assume that for a second And assume again that the description of what happened in those compliance checks in these documents is accurate Okay A Uh-huh July With those two assumptions do you think that the Virgin Islands did an adequate job in its compliance Esquire Solutions com Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE checks regarding Mr Epstein ATTORNEY ACKERMAN Object to form Jul THE WITNESS I think Epstein Mr Epstein was evasive BY ATTORNEY NEIMAN Uh-huh A and clever in avoiding the verifications if nothing else And do you think that evasiveness should have triggered some follow-up by the Virgin Islands Department of Justice which after all was charged with protecting the community ATTORNEY ACKERMAN Object to form THE WITNESS Again I you know I don they may have been And if they wasnt they should have been BY ATTORNEY NEIMAN kay Did you ever look at the question of whether Mr Epstein was appropriately assified at the Es quir So luti co Case Document Filed Page of CAROL JACOBS VIRGIN ISLANDS vs JP MORGAN CHASE some information about Mr Epstein Do you see that ATTORNEY ACKERMAN Object to form BY ATTORNEY NEIMAN The writer writes When was Epstein last visited by the DOJ at his little island palace When was the last time Epstein signed in to the DOJ in St Thomas If I do not get a response from you and the AG I will result to plan which is to embarrass the VIDOJ if need be Remember I work as a private chef under my LLC We private chefs here on the island are tight and we see and hear everything specially what goes on in Little St James island We have pictures audio video of it all going on Do you see that A Yes You agree with me that pictures audio and video of what was going on on Little St James would be July Esquire Solutions com Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE of interest if there were interest in finding out whether Mr Epstein was engaged in any sexual misconduct ATTORNEY ACKERMAN Object to form THE WITNESS Yes BY ATTORNEY NEIMAN All right And you would therefore expect that the Virgin Islands would follow up when somebody claimed to have such pictures audio and video ATTORNEY ACKERMAN Object to form THE WITNESS They should have BY ATTORNEY NEIMAN Do you any if any withdrawn Was this ever brought to your attention A I don recall this And you agree that fo low-up would have been appropriate ATTORNEY ACKERMAN bject to Jul DE Es quir So luti co Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE form BY ATTORNEY NEIMAN Do you know if any follow-up happened A I dont know Did the Virgin Islands to your knowledge do anything to monitor press accounts related to Mr Epstein to see whether there was reason to be concerned that he was reoffending ATTORNEY ACKERMAN Object to form THE WITNESS I don know when you say monitor But if there are press accounts I sure the Virgin I slands would be aware of any national press accounts BY ATTORNEY NEIMAN Okay And do you know if anything ATTORNEY ACKERMAN You can put that document aside BY ATTORNEY NEIMAN was ever done THE WITNESS Oh I was just Jul Es quir So luti co Case Document Filed Page of CAROL JACOBS VIRGIN ISLANDS vs JP MORGAN CHASE Do you see that A Yes And then if you continue to the next page youll see in paragraph that the lawsuit alleges that one occasion after suffering verbal abuse and threats by Defendants Epstein Maxwell and Kellen Plaintiff attempted to escape from Defendant Epsteins private island and a search party located her and physically returned her to the main house on the island Do you see that A I do Do you agree with me that these are the kind of allegations that the Virgin Islands had a responsibility to follow up on ATTORNEY ACKERMAN Object to form THE WITNESS If the Virgin Islands knew of these allegations they would yes I would say they have a responsibility I dont know July Esquire Solutions com Case Document Filed Page of AR ACO VIR IN I A ND vs JP MORGA ASE in at least I wasn aware and I don know if anyone at Attorney General Office was aware of these allegations in BY ATTORNEY NEIMAN And do you know if the Attorney Generals Office in the Virgin I slands 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 Jul THE WITNESS I not aware of any BY ATTORNEY NEIMAN Would you agree with me that it would have been appropriate for the i rgin I slands to make efforts to find out what kind of al egations were being made against a prominent resident like Mr Epstein in publicly i led lawsuits ATTORNEY ACKERMAN Object to Es quir So luti co
9,162 characters
