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Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 6 of 12 Q. That's not something that you were, you were privy to? You weren't, you weren't in the loop of the sharing of information in the house in terms of the computers being connected through any server? A. I don't really know what, how, how to answer your question because Citrix is for the whole organization to exchange e-mail between employees. Q. All right. You used the term? A. So, even my computer is connected to Citrix. I can receive mail and I can e-mail information to employee within organization. But I don't know if you can see to each computer what is going on on another computer. ak Q. You have used the term organization; you can share within the organization. What do you -- just so I can understand what you're calling the organization, what do you mean by that word? A. People employed by Jeffrey Epstein. There are a few groups of people, his office in New York and I guess -- 2k Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and Nadia Marcinkova. So we'll get to them in a minute but first just so we stay on the track of who was in the organization, is Sarah Kellen, Adriana Ross and Nadia Marcinkova all people that you would also consider within the organization? A. Yes. Q. Okay. So, we just added three more names to it. Who else would you consider, Ghislaine Maxwell? A. Yes. Banasiak Deposition at 56:13-17; 57:2-14; 58:1-7; 60:21-61:7 (February 16, 2010) (Emphasis added) (McCawley Decl. at Sealed Composite Exhibit 2). As Defendant was a member of Epstein’s household, and claims to have been his employee (See McCawley Decl. at Sealed Exhibit 3, Maxwell’s April 22, 2016 Dep. Tr. at 10:7- 11:3), it is unlikely that her mindspring account was merely a “spam account” from 1999-2002. It is much more likely that this account has - or had - Defendant’s communications with co-