gov.uscourts.nysd.447706.1327.25.pdf

Case 1:15-cv-07433-LAP Document 1327-25 Filed 01/05/24 Page 1 of 12 EXHIBIT 8 (Filed Under Seal)  Case 1:15-cv-07433-LAP Document 1327-25 Filed 01/05/24 Page 2 of 12 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 1327-25 Filed 01/05/24 Page 3 of 12 Page 55 1 A. One was in cabana. One, the other second one 2 was in living room and one was in small office next to 3 the kitchen. 4 Q. All right. In your time at the house 5 prior to that, is it fair to say those computers had 6 never been removed before? 7 A. I remember that there was to bring some new 8 ones to replace them at some point. I don't know 9 remember exactly if it was for upgrading, but they 10 change computers very often I would say. 11 Q. All right. But the computers -- the 12 removal by Adriana and this individual, that wasn't 13 done -- we're talking about a different -- that's 14 not a time where they were replacing computers. 15 This was just removing computers from the house? 16 A. Yes. 17 Q. And did you receive any explanation as to 18 why the computers were being removed from the house? 19 A. No. 20 Q. Did you ever have occasion to use any of 21 the three computers that were removed from the 22 house? 23 A. No. I never, I never, you know, touch them, 24 never use them. I have my own computer in my office, so 25 I use this computer. (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 GIUFFRE004478  Case 1:15-cv-07433-LAP Document 1327-25 Filed 01/05/24 Page 4 of 12 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 1327-25 Filed 01/05/24 Page 5 of 12 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 1327-25 Filed 01/05/24 Page 6 of 12 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 1327-25 Filed 01/05/24 Page 7 of 12 Page 59 1 THE WITNESS: K-l-e-n. 2 MR. MERMELSTEIN: K-l-e-n. 3 BY MR. EDWARDS: 4 Q. And in addition to Bella Klen, who else 5 would you have considered to be in Jeffrey Epstein's 6 organization? 7 A. Rich Kahn. Richard Kahn. 8 Q. And how do you spell the last name? 9 A. K-a-h-n. 10 Q. And where is he located? 11 A. New York office. 12 Q. What does he do? 13 A. I guess he was involved with the accounting. 14 Q. And who else? 15 A. Leslie. I would think I would say secretary. 16 Q. Leslie Groff? 17 A. Yes. 18 Q. And is she also in the New York office? 19 A. Yes. 20 Q. What do you understand her role to be? 21 A. Secretary I would say. 22 Q. Did she also schedule appointments for 23 these young females to come to Jeffrey Epstein's 24 house? 25 MR. GOLDBERGER: Form. (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 GIUFFRE004482  Case 1:15-cv-07433-LAP Document 1327-25 Filed 01/05/24 Page 8 of 12 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 1327-25 Filed 01/05/24 Page 9 of 12 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  Case 1:15-cv-07433-LAP Document 1327-25 Filed 01/05/24 Page 10 of 12 Page 62 1 Q. Right. The one who helped Adriana move 2 it. 3 A. No, it wasn't. 4 Q. Had you ever seen that individual on the 5 property, on Mr. Epstein's property at 358 Albrillo 6 Way prior to him assisting Adriana in removing the 7 computers from the home? 8 A. No. 9 Q. That was their first time seeing him? 10 A. Yes. 11 Q. Had you ever seen him since that date? 12 A. No. 13 Q. And to this date you don't know who that 14 individual was? 15 A. No. 16 Q. Were you told that the -- let me rephrase 17 that. I guess you told me that anything that 18 happened in the home in terms of guests coming over 19 or things of that nature, you would be forwarned 20 about it, right? 21 A. Right. 22 Q. So, when was the first time that you 23 learned that Adriana and some gentleman that you had 24 never met would be coming to the home to remove the 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 GIUFFRE004485  Case 1:15-cv-07433-LAP Document 1327-25 Filed 01/05/24 Page 11 of 12 Page 63 1 A. I got the phone call from her that there would 2 be -- I don't know what time it was in the house in 3 certain time and they would pick up those computers. 4 Q. Okay. And you got a phone call from 5 Adriana? 6 A. Right. 7 Q. Why were you called by Adriana to tell you 8 that Adriana and would be coming over to, with some 9 other gentleman to remove the computers. Do you 10 know why you were told that? 11 A. No. 12 Q. Would Adriana call every time she would 13 come over? 14 A. Yes. 15 Q. Okay. 16 A. I mean, any, any time coming to the house, 17 they always let me know who is coming when they are 18 arriving or whatever. 19 Q. Back in 2000, sorry. 20 A. I said even if Jeffrey Epstein arriving at the 21 house, I always know what time and which day he would be 22 here or another person, so I would be aware of what was 23 going on and I would be prepared. 24 Q. Who besides you back in 2005 lived at the 25 house full time; just you? (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 GIUFFRE004486  Case 1:15-cv-07433-LAP Document 1327-25 Filed 01/05/24 Page 12 of 12 Page 191 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 JANUSZ BANASIAK personally appeared before me 8 and was duly sworn on the 16th day of February, 9 2010. 10 11 Dated this 28th day of February, 2010. 12 13 14 15 _________________________________ 16 Cynthia Hopkins, RPR, FPR 17 Notary Public - State of Florida My Commission Expires: February 25, 2011 18 My Commission No.: DD 643788 19 20 21 22 23 24 25 (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 GIUFFRE004614