EXHIBIT Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Plaintiff vs JPMORGAN CHASE BANK N.A Defendant/Third Party Plaintiff JPMORGAN CHASE BANK N.A Third-Party Plaintiff vs JAMES EDWARD STALEY Third-Party Defendant THURSDAY JULY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER Videotaped deposition of Special Agent Joseph Fonseca FBI Retired held at the offices of WilmerHale Greenwich Street New York New York commencing at a.m Eastern on the above date before Carrie A Campbell Registered Diplomate Reporter and Certified Realtime Reporter GOLKOW LITIGATION SERVICES ph fax deps golkow.com Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa relates to fraud and anything else thats from the Act I honestly I cant tell you QUESTIONS BY MR PENDELL Well and my question was a little bit broader than that and I apologize if I asked a bad question That may happen from time to time Im notorious for asking bad questions But Im interested generally in do you think that people and businesses have an obligation to comply with the law whatever that law is A I would agree yes Do you have any opinion as to whether JPMorgan A I do not No opinion one way or the other A I dont Okay Mr Fonseca what subject areas do you consider yourself to be an expert in Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa A Anything relevant to crimes against children Okay You are not a certified public accountant is that correct A That is correct Okay During your tenure as an FBI special agent I understand that based on your CV and were going to talk about it a little bit more later you had some supervisory authority for other special agents is that true A That is correct Okay And during your time with that supervisory authority over other FBI special agents did you expect that those agents that you supervised were going to gather as much evidence as possible for an investigation that you were pursuing MR BOUCHOUX Objection to the form THE WITNESS I expected them to do their job Collecting evidence was part of them doing their job yes QUESTIONS BY MR PENDELL Do you ever recall a time when Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa under the age of and the responsibility for investigating that would fall outside of crimes against children A That is correct That would if youre referring back to the human trafficking scenario I just provided if they were here and not documented and they were underage the human trafficking squad the public corruption squad and their agent that worked human trafficking there for undocumented and Ill say women because that is pretty much what we saw was women they would work that case correct And what about so if you had sex trafficking of people under the age of that were US citizens would that fall under crimes against children A Correct Adult or child yes Okay When you say adult or children if somebody if there was a sex trafficking operation and everyone involved was over the age of would crimes against children would that what do you call it a bureau or squad A The squad Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa Is it fair to say that your responsibility was in carrying out the policies MR BOUCHOUX Objection to form THE WITNESS I would say my obligations were to follow protocols and to follow my experience in cases QUESTIONS BY MR PENDELL While employed by the FBI were you responsible for providing official opinions interpreting FBI investigative policy A No I was not While employed by the FBI were you responsible for setting any other FBI policies A No We talked a little bit about your experience with the FBI in the crimes against children squad I want to focus a little bit more on your work within that department specifically investigating sex trafficking How many investigations were Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa you involved in at the FBI that specifically involved sex trafficking A Thats a difficult question to answer specifically because I was involved as an investigator and as a coordinator for a task force that saw a dozen cases a week So it was it could be more than that So its difficult to answer that question A lot Well let me ask you this You had talked earlier about an example of a case you worked on with I dont want to call him a gentleman because I would argue that hes not but a man who lured an underage person over the Internet across state lines for the purposes of sex Although reprehensible and a criminal act would you agree that that particular instance is not sex trafficking MR BOUCHOUX Objection to the form THE WITNESS I cant tell you what he was I cant tell you what he was charged with if were talking about that case with Smith and Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa QUESTIONS BY MR PENDELL Do you think that the case against Mr Epstein was a routine sex trafficking case in your opinion MR BOUCHOUX Objection to the form THE WITNESS Can you define routine QUESTIONS BY MR PENDELL Well Im sort of interested in let me well let me ask it this way Youve come here and youve testified based on your experience A Uh-huh that youve worked on several numerous many sex trafficking cases and youve never worked on one that involved an individual with Mr Epsteins wealth So would you agree with me that the sex trafficking case against Mr Epstein was not routine A No You would not agree with me Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa A I would not agree Why not A The supposition that wealth matters when you are working a case that has to do with paying juveniles small amounts of money which we saw in every case to sexually abuse them is not unusual Your wealth has nothing to do with those points of the sexual abuse Well fair enough But were not just talking about wealth here right Let me ask you this question How many sex trafficking cases have you been involved in where there were over a hundred victims MR BOUCHOUX Objection to the form THE WITNESS I dont think any QUESTIONS BY MR PENDELL So would you agree with me that a sex trafficking case with over a hundred victims is not a routine case A From the amount of victim point Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa of view I would say based on my experience that is unusual to see that amount of victims The way of investigating the case would not be unusual A hundred victims is a lot isnt it A A hundred victims is a lot compared to just one victim yes And one victim is bad enough A hundred is A Absolutely unfathomable right A Absolutely You said something about wealth had nothing to do with making it routine or not routine Im paraphrasing here because you said something about small amounts of money that were paid Have you looked at how much money was involved specifically in this case MR BOUCHOUX Objection to the form THE WITNESS From the payments that were made to the victims I have reviewed statements from the victims Case Document Filed Page of Confidential Pursuant to Protective Order Golkow Liti ation Services Pa to the term banking information Vague Ambiguous THE WITNESS I know what part of our team would be our intelligence analysts but I never used banking information so I dont I dont know who Id assign that responsibility to except an intelligence analyst I guess QUESTIONS BY MR PENDELL And let me ask you another question in light of counsels objection which was fair During your tenure with the FBI investigating sex trafficking of children were you ever responsible for reviewing the financial information of a suspect A And to be clear too sex trafficking is not just with children We investigated adults as well But the financial interest Your question about that was Yes Did you ever review the financial information of a suspect MR BOUCHOUX Objection to the Case Document Filed Page of
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