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1 
as to whether or not these girls were in the house 
2 
at the same time that Mr. Brunel was in the house? 
3 
A. 
Could be. 
4 
Q. 
But if they came over, you don't remember 
5 
whether Mr. Brunel was also given a massage? 
6 
A. 
No, I don't, I don't remember. I don't even 
7 
know. 
8 
Q. 
Other than massages for Mr. Epstein by 
9 
these young females, are you able to say that 
10 
anybody else received a massage from any of these 
11 
girls? 
12 
MR. GOLDBERGER: Form. 
13 
THE WITNESS: I don't know. 
14 
BY MR. EDWARDS: 
15 
Q. 
Are you saying it could have happened, it 
16 
might not have happened; you just don't remember? 
17 
A. 
I haven't seen, no --
18 
MR. GOLDBERGER: Form. 
19 
THE WITNESS: -- or being told it. 
20 
MR. EDWARDS: Okay. 
21 
THE WITNESS: This other person has some 
22 
kind of massage. 
23 
BY MR. EDWARDS: 
24 
Q. 
Okay. Did Mr. Brunel ever arrive with 
25 
other females to stay on any of the occasions back 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
3507.011 
Pagc 181 of 200 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
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Page 182 
1 
in 2005? 
2 
A. 
I don't remember. I haven't seen him. 
3 
Q. 
Excuse me? 
4 
A. 
I don't remember. I haven't seen him coming 
5 
with the other, I would say guests or other company, or 
6 
I have seen him coming alone. Every time I pick him up, 
7 
he was alone. 
8 
Q. 
Did you talk to him when you would give 
9 
him rides to and from the airport or to and from 
10 
Miami? 
11 
A. 
Yeah. We talk on the way to Miami. 
12 
Q. 
Would he tell you why he was here or what 
13 
he was doing, business? 
14 
A. 
No. Just, you know, pep talk I would say. 
15 
Q. 
Pep talk? Who was giving who the pep 
16 
talk? 
17 
A. 
He was the one who talk a lot. 
18 
Q. 
It's my understanding that Mr. Epstein 
19 
does not drink, right? 
20 
A. 
Right. 
21 
Q. 
And by that I mean I am talking about 
22 
alcohol, obviously. 
23 
A. 
Yes. 
24 
Q. 
How about Mr. Brunel? 
25 
A. 
I haven't seen him drinking either. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2C5a91d4eaa-0113tUflUdle 
3507-011 
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1 
Q. 
Okay. Also my understanding Mr. Epstein 
2 
doesn't smoke, use drugs, any of those things? 
3 
A. 
That's true, yes. 
4 
Q. 
Mr. Brunel, have you seen him? 
5 
A. 
No. 
6 
Q. 
Have you seen him smoke? 
7 
A. 
Yeah, he smokes. 
8 
Q. 
He does? 
9 
A. 
Yes. 
10 
Q. 
Use drugs? 
11 
A. 
(Witness shakes head.) 
12 
Q. 
Not that you've seen? 
13 
A. 
No. 
14 
Q. 
Have you ever gone on any of the airplanes 
15 
that are owned by Mr. Epstein? 
16 
A. 
Yes. I was once when I got this job first 
17 
time because I came here first time without my 
18 
belongings. So, I told them can I get a ride to New 
19 
York, pick up my stuff and I went here. So, one time I 
20 
flew from here to New York. 
21 
Q. 
Was anybody else on the airplane that 
22 
time? 
23 
A. 
Yeah. It was 
, him, 
. That's it . 
24 
Q. 
And is it your understanding that 
25 
has ever been intimately involved with Mr. Epstein? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2d75891d-3eaa-42b3-ae22-b5d3c7182dle 
3507.011 
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2 
3 
4 
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6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A. 
No. 
Q. 
How about Ghislaine Maxwell? 
A. 
No. 
Q. 
To the best of your knowledge you never 
knew anything about that? 
A. 
I don't know what's going on. 
Q. 
All right. Have you ever heard the name 
A. 
No. 
Q. 
, do you know who that is? 
A. 
No. 
Q. 
, do you know her? 
A. 
Yes. 
Q. 
How do you know 
A. 
She works for Ghislaine Maxwell, her 
assistant. 
Q. 
In New York? 
A. 
In New York. 
Q. 
And have you ever known 
to have 
been linked to Mr. Epstein in a physical 
relationship? 
A. 
No. 
Q. 
What do you think that she does for 
Ghislaine Maxwell? 
A. 
I guess she organize her schedule and do some, 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2C5aMd4eaa-2b3-ae22-bSacflUdle 
3507-011 
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1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
23 
24 
25 
some stuff for her. 
Q. 
Well, what does Ghislaine Maxwell do that 
needs organizing, do you know? 
A. 
I guess she has a lot of social events. 
Q. 
Okay. Have you ever met? 
A. 
Put down --
Q. 
I'm sorry. 
A. 
She has to put down everything. 
Q. 
Have you ever met 
A. 
Yes. 
Q. 
Was that at the Palm Beach house? 
A. 
She was here a few times, and I met her up in 
New York. 
Q. 
When was the last time that you met Dana 
Burns or saw 
A. 
I would say two years ago. 
Q. 
A. 
Q. 
A. 
Just before Mr. Epstein was in jail? 
Or after. 
Where did you see her? 
Yeah. I think, yeah, she was here for a few 
days working 
Q. 
And is that during the time period when 
Mr. Epstein was out on work release? 
A. 
Yes. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2C5aMd4eaa-2b3-ae22-bSacflUdle 
3507-011 
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Cade 18(' 
9 
10 
11 
12 
13 
14 
16 
17 
18 
19 
23 
24 
Q. 
Nobody. So, when 
was working 
do you know what 
she was doing? 
A. 
She was in the office answering phone calls, 
doing some e-mails, answering mail I guess. 
Q. 
Okay. And you saw her 
A. 
Yes. 
Q. 
Okay. Did she stay at 
or at 
when she was in town? 
A. 
No, no. 
Q. 
What is your, what is your understanding 
as to the names of the employees that work for= 
Mr. Epstein, who else? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
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Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d7Sagld-3eaa-4263-ae2265d3c7182dle 
3507-011 
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Page 187 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
16 
A. 
Yes. 
17 
Q. 
And Mr. 
18 
A. 
Yes. 
19 
Q. 
And Ms. 
20 
A. 
Yes. 
21 
Q. 
And who 
22 
their own office 
23 
A. 
Nobody. 
24 
conference room. 
25 
Q. 
Okay. 
A. 
Q. 
A. 
Do you know what he does? 
is involved too. 
Q. 
Do you know what 
does for the 
Florida Science Foundation? 
A. 
No. 
Q. 
That's just somebody who you've seen 
working 
A. 
Yes. 
Q. 
When you've had occasion to go there, and 
I am assuming you have been there numerous times, 
right? 
A. 
Right. 
Q. 
The people who have offices within III 
are Mr. Epstein? 
? I am asking. 
else within that office has, has 
There are three offices, one 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2dnaMd-Usa-42b3-ae22-bSacflUdle 
3507-011 
Page 187 of 2(X) 
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Page 188 
1 
A. 
So, one is for 
another is for 
2 
3 
Q. 
So, to the best of your knowledge the 
4 
regular employees, based on your observations, are 
5 
Mr. Epstein, Mr. 
and Ms. 
6 
A. 
Yes. 
7 
Q. 
Okay. And at least on a couple of 
8 
occasions you have seen 
there? 
9 
A. 
Right. 
10 
MR. EDWARDS: All right. 
11 
RECROSS (JANUSZ BANASIAK) 
12 
BY MR. MERMELSTEIN: 
13 
Q. 
I have just one follow-up question. What 
14 
is the reason that you come to the office on a 
15 
regular basis 
16 
A. 
I bring Mr. Epstein from jail. 
17 
Q. 
You bring him from jail? 
18 
A. 
Right, to the office and take him back to 
19 
jail. 
20 
Q. 
That was when he was on work release, 
21 
right? 
22 
A. 
Right. 
23 
Q. 
Is there any other occasion that you 
24 
for that purpose you were given a card for access to 
25 
the garage? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2d75a9td4eaa42b3-m224MUTIWWle 
3507.011 
Pagc 188 of 200 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
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Page 189 
1 
A. 
Yes, yes. 
2 
Q. 
Before Mr. Epstein was in jail, were there 
3 
occasions where you came to the office here? 
4 
A. 
Before jail? 
5 
Q. 
Before jail. 
6 
A. 
Yeah. I was, I was the one who organize, you 
7 
know, put everything together, bring furniture, bring 
8 
some things over there. 
9 
Q. 
You set up the office? 
10 
A. 
Yes. 
11 
Q. 
When was that? 
12 
A. 
Oh, I don't remember exactly. When he was in 
13 
jail. 
14 
Q. 
Before he was in jail or during the time 
15 
he was in jail? 
16 
A. 
I think before. 
17 
Q. 
How long before he went to jail did you 
18 
set up the office? 
19 
A. 
A few months, two, three. I don't remember. 
20 
Q. 
After you set up the office, were there 
21 
occasions where you would come to the Florida 
22 
Science Foundation office? 
23 
A. 
Yes, very often. 
24 
Q. 
What would you come for? 
25 
A. 
They call me to bring some food for them, 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthla hopkins (601-051-976-2934) 
Electronically signed by cynthla hopkins (601-051-976-2934) 
Electronically signed by cynthla hopkins (601-051-976-2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7192dle 
3507-011 
Page 189 of 200 
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Page 190 
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lunch, pick up some, bring some papers, office supplies. 
2 
That's it 
3 
Q. 
You would run errands for the office? 
4 
A. 
Yes. 
5 
MR. MERMELSTEIN: Nothing further. 
6 
MR. EDWARDS: All right. Are you going to 
7 
read or waive? 
8 
MR. GOLDBERGER: We will read. All right. 
9 
THE COURT REPORTER: Did you want to order 
10 
this? 
11 
MR. EDWARDS: Yes, please. 
12 
THE COURT REPORTER: Did you want a copy, 
13 
Mr. Mermelstein? 
14 
MR. MERMELSTEIN: Yes. 
15 
THE COURT REPORTER: Mr. Goldberger, do 
16 
you want a copy? 
17 
MR. GOLDBERGER: Yes. Send it to Critton. 
18 
Bill him, seriously. 
19 
(Witness excused.) 
20 
(Deposition was concluded.) 
21 
22 
23 
24 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2dnaMd-Usa-2b3-ae22-b5d3c7182dle 
3507-011 
Page 190 of 2(X) 
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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 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Dated this 28th day of February, 2010. 
AS
Cynthia Hopkins, RPR, FPR 
Notary Public - State of Florida 
My Commission Expires: February 25, 2011 
My Commission No.: DD 643788 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2e5aMd-Usa4a63-ae22-b5d3crindle 
3507-01 
Page 191 of 2(X) 
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Page 192 
1 
CERTIFICATE 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
I, Cynthia Hopkins, Registered Professional 
Reporter, Florida Professional Reporter and Notary 
6 
Public in and for the State of Florida at large, do 
hereby certify that I was authorized to and did 
7 
report said deposition in stenotype; and that the 
foregoing pages are a true and correct transcription 
8 
of my shorthand notes of said deposition. 
9 
I further certify that said deposition was 
taken at the time and place hereinabove set forth 
10 
and that the taking of said deposition was commenced 
and completed as hereinabove set out. 
11 
I further certify that I am not attorney or 
12 
counsel of any of the parties, nor am I a relative 
or employee of any attorney or counsel of party 
13 
connected with the action, nor am I financially 
interested in the action. 
14 
The foregoing certification of this transcript 
15 
does not apply to any reproduction of the same by 
any means unless under the direct control and/or 
16 
direction of the certifying reporter. 
17 
Dated this 28th day of February, 2010. 
18 
19 
20 
AA 
21 
 
C4/61 AJAS
C thia Hopkins, R R, FPR 
22 
23 
24 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2d75891d-Uaa-42b3-ae22-bSa0182dle 
3507-0II 
Page 192 of 2(X) 
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Page 193 
1 
5 
6 
DATE: 
February 28th, 2010 
TO: 
JANUSZ BANASIAK 
c/o Jack Alan Goldberger, Esquire 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
IN RE: 
III. vs. Epstein 
CASE NO.: 502008CA028051XXXXMB AB 
Please take notice that on Tuesday, the 16th of 
February, 2010, you gave your deposition in the 
above-referred matter. At that time, you did not 
waive signature. It is now necessary that you sign 
your deposition. 
As previously agreed to, the transcript will be 
furnished to you through your counsel. Please read 
11 
the following instructions carefully: 
At the end of the transcript you will find an 
12 
errata sheet. As you read your deposition, any 
changes or corrections that you wish to make should 
13 
be noted on the errata sheet, citing page and line 
number of said change. DO NOT write on the 
14 
transcript itself. Once you have read the 
transcript and noted any changes, be sure to sign 
15 
and date the errata sheet and return these pages to 
me. 
16 
If you do not read and sign the deposition 
within a reasonable time, the original, which has 
17 
already been forwarded to the ordering attorney, may 
be filed with the Clerk of the Court. If you wish 
18 
to waive your signature, sign your name in the blank 
at the bottom of this letter and return it to us. 
19 
Very truly yours, 
20 
21 
Cynthia Hopkins, RPR, FPR 
22 
23 
I do hereby waive my signature. 
24 
25 
JANUSZ BANASIAK 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hooking (601-051-976-2934) 
Electronically signed by cynthia hooking (601-051-976-2934) 
Electronically signed by cynthia hooking (601-051-976-2934) 
(561) 832-7506 
2W5a9W4eaa42113-m224,MUTIMMU 
3507.011 
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Page 194 
1 
CERTIFICATE 
2 
- - - 
3 
THE STATE OF FLORIDA 
4 
COUNTY OF PALM BEACH 
5 
I hereby certify that I have read the foregoing 
6 
deposition by me given, and that the statements 
7 
contained herein are true and correct to the best of 
8 
my knowledge and belief, with the exception of any 
9 
corrections or notations made on the errata sheet, 
10 
if one was executed. 
11 
12 
Dated this 
day of  
13 
2010. 
14 
15 
16 
17 
18 
19 
JANUSZ BANASIAK 
20 
Job #1317 
21 
22 
23 
24 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2C5aMd4eaa-42b3-ae22-bSa0lUdle 
3507-0 I I 
Page 194 of 2(X) 
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Page 195 
1 
ERRATA 
SHEET 
2 
IN RE: 
III. VS. EPSTEIN 
CR: 
Cynthia Hopkins 
3 
DEPOSITION OF: JANUSZ BANASIAK 
TAKEN: 
February 16, 2010 
4 
JOB NO.: 1317 
5 
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
PAGE # LINE # 
CHANGE 
REASON 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
Please forward the original signed errata sheet to 
this office so that copies may be distributed to all 
18 
parties. 
19 
Under penalty of perjury, I declare that I have read 
my deposition and that it is true and correct 
20 
subject to any changes in form or substance entered 
here. 
21 
22 
DATE: 
23 
24 
SIGNATURE OF 
DEPONENT: 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
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) 
(561) 832-7506 
2W5a9W-308a42113-m224M3O182Ale 
3507.011 
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3507-011 
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3507-011 
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EFTA_0000686 I 
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3507-011 
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EFTA_00006862 
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3507-011 
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EFTA_00006863 
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A Jr Ezatow_C_ 
rya...01k  Rilz 
3507-011 
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