gov.uscourts.nysd.447706.1330.14.pdf

Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 1 of 7 COMPOSITE EXHIBIT 2 (FILE UNDER SEAL)  Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 2 of 7 Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB L.M. Plaintiff, -vs- JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. ______________________________/ DEPOSITION OF JANUSZ BANASIAK Tuesday, February 16, 2010 10:09 - 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004424  Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 3 of 7 Page 56 1 Q. Is your computer in your office -- 2 A. Yes. 3 Q. Let me finish. Is the computer in your 4 office linked up with the three computers that were 5 removed from the house? Meaning, can you look at 6 the system and see what is on those three computers? 7 A. No, no. 8 Q. Is it your understanding that those three 9 computers are linked with one another or do you 10 know? 11 A. I don't know, but I, I doubt it. They are 12 separate I guess. 13 Q. Okay. Were you aware that Mr. Epstein 14 used a Citrix program to link various computers? 15 Did you know that? 16 A. Yeah. I use Citrix too in my computer for 17 exchanging e-mails and get through Internet. 18 Q. Okay. So, is it your understanding that 19 the only connection then through Citrix with these 20 computers, these various computers that were in 21 Mr. Epstein's home, was for e-mail purposes? 22 A. Yes. 23 Q. Okay. To your knowledge, you're not 24 familiar with those computers sharing other files or 25 information? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004479  Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 4 of 7 Page 57 1 A. No. 2 Q. That's not something that you were, you 3 were privy to? You weren't, you weren't in the loop 4 of the sharing of information in the house in terms 5 of the computers being connected through any server? 6 A. I don't really know what, how, how to answer 7 your question because Citrix is for the whole 8 organization to exchange e-mail between employees. 9 Q. All right. You used the term? 10 A. So, even my computer is connected to Citrix. 11 I can receive mail and I can e-mail information to 12 employee within organization. But I don't know if you 13 can see to each computer what is going on on another 14 computer. 15 Q. You don't know about -- 16 A. Is that your question? 17 Q. You don't know about shared files? 18 A. No. 19 Q. You only know that the one computer can 20 e-mail the other? 21 A. Right. 22 Q. But that can happen with any two computers 23 in the world pretty much. You can send e-mails to 24 each other, right. 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004480  Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 5 of 7 Page 58 1 Q. You have used the term organization, you 2 can share within the organization. What do you -- 3 just so I can understand what you're calling the 4 organization, what do you mean by that word? 5 A. People employed by Jeffrey Epstein. There are 6 a few groups of people, his office in New York and I 7 guess -- 8 Q. Who are those people by name that you 9 would consider within the Jeffrey Epstein 10 organization? 11 A. His accountant, his -- 12 Q. Who is that? 13 A. Bella Klen. 14 Q. What is it? 15 A. Bella Klen. K-l-i-n. E-n, I'm sorry. 16 Q. Bella, B-e-l-l-a? 17 A. Yes. 18 Q. Is that somebody in New York? 19 A. Yes. 20 Q. Is that a male or female? 21 A. Female. 22 Q. And you understand that's his accountant? 23 A. Right. 24 MR. GOLDBERGER: Just to get the spelling 25 correct is it K-l-e-i-n? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004481  Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 6 of 7 Page 60 1 THE WITNESS: I don't know. 2 BY MR. EDWARDS: 3 Q. We'll go back to that but I tell you why I 4 ask. If you don't know then you don't know, but in 5 the course of Mr. Epstein's -- you're aware that he 6 did plead guilty to a couple felonies in state 7 court, right? 8 A. Right. 9 Q. Well, in the course of the negotiation 10 with the federal government and the U.S. Attorney's 11 Office, they, the agreement between Mr. Epstein and 12 the U.S. Attorney's office mentions people that are 13 called co-conspirators of Epstein. And Leslie Groff 14 is named as one of those co-conspirators. 15 Do you know what involvement, if any, that 16 she had with the crimes that were being 17 investigated? 18 A. No. 19 Q. Okay. 20 A. I am not aware of this. 21 Q. Okay. The other people mentioned as 22 co-conspirators are Sarah Kellen, Adriana Ross, and 23 Nadia Marcinkova. So we'll get to them in a minute 24 but first just so we stay on the track of who was in 25 the organization, is Sarah Kellen, Adriana Ross and (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004483  Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 7 of 7 Page 61 1 Nadia Marcinkova all people that you would also 2 consider within the organization? 3 A. Yes. 4 Q. Okay. So, we just added three more names 5 to it. Who else would you consider, Ghislaine 6 Maxwell? 7 A. Yes. 8 Q. And who else? 9 A. Who was working there? 10 Q. Bella, Richard Kahn, Leslie Groff, 11 Ghislaine Maxwell, Nadia, Sarah, Adriana. 12 A. I think Harry was involved with the 13 accounting. 14 Q. Okay. 15 A. I don't recall his last name. 16 Q. Somebody else involved with the 17 accounting? 18 A. Yes. 19 Q. Okay. Any of those people that you just 20 named, were any of those people that you just named 21 the person that you described as the gentleman that 22 assisted Adriana in removing the computers from the 23 house prior to the search warrant being executed? 24 A. No. You mean the one who show up to do those 25 computers? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e GIUFFRE004484