EFTA00114414.pdf

1 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: 2 DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: NONE OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL AUGUST 4, 2021 RESOLUTE DOCUMENTATION SERVICES Suite 285 Agoura Hills CA 91301 Phone: 3 4 1 MR. : The recorder is on. My 1 MR. : And you, sir? 2 name is , and I'm a Senior 2 MR. : I am Correctional Counselor 3 Special Agent with the U.S. Department of 3 . 4 Justice, Office of the Inspector General, New 4 MR. : Correctional Counselor? S York Field Office, and these are my S MR. : Yes, sir. 6 credentials. This interview with Federal 6 MR. : And what did you say 7 Bureau of Prisons employee is 7 that, what level was that? Nine? 8 being conducted as part of an official U.S. 8 MR. : GS-9. 9 Department of Justice, Office of the Inspector 9 MR. : GS-9. Great. Thank you, 10 General investigation. Today's date is August 10 sir. This is an official DO]/OIG investigation 11 4, 2021, and the time is 9:24 a.m. This 11 into the death of inmate Jeffrey Epstein, and 12 interview is being conducted at the 12 the surrounding circumstances, and you are 13 Metropolitan Correctional Center, known as the 13 being asked to voluntarily provide answers to 14 MCC, located in New York, New York. Also 14 our questions. Will you agree to a voluntary 15 present is DOJ/OIG Special Agent 15 interview with the DO]/OIG? 16 Do you want to show him your credentials? 16 MR. : Yes. 17 MR. : Thank you. 17 MR. : Thank you, sir. We have 18 MR. : This interview will be 18 a form, it's the DO]/OIG form 3-226/2. It's 19 recorded by me, SSA Could 19 the United States Department of Justice, Office 20 everyone please identify themselves for the 20 of the Inspector General, Warnings and 21 record and spell your last name? To start, 21 Assurances to Employee Requested to Provide 22 wain I am DOJ OIG Senior Special Agent 22 Information on a Voluntary Basis. "You are 23 23 being asked to provide information as part of 24 MR. I am DO]/OIG Special Agent 24 an investigation being conducted by the Office 25 , 25 of the Inspector General. This investigation EFTA00114414 5 6 1 is being conducted, pursuant to the Inspector 1 MR. : Thank you. All right. 2 General Act of 1978, as amended. This 2 The date and time, Wednesday, August -- 3 investigation pertains to job performance 3 MR. : Fourth. 4 failure and security failure. This is a 4 MR. : -- 4, 2021, and the time S voluntary interview. Accordingly, you do not S is 9:26 a.m. now. So, 8/4/21, at 9:26 a.m. 6 have to answer questions. No disciplinary 6 Place: MCC, New York. I am s tiring as the top 7 action will be taken against you if you choose 7 line. Once again, this is , 8 not to answer questions. Any statement you 8 and printing below. Special Agent , can 9 furnish may be used as evidence in any future 9 you just sign as a witness and then put your 10 criminal proceedings or agency disciplinary 10 name below? Thank you. 11 proceedings, or both." 11 MR. : This is Agent . I'm 12 And there's a waiver section. It says, "I 12 signing as a witness and printing my name. 13 understand the Warnings and Assurances stated 13 MR. : All right. So, before we 14 above, and I am willing to make a statement and 14 start the interview I would like to place you 15 answer questions. No promises or threats have 15 under oath. Mr. , can you please raise 16 been made to me, and no pressure or coercion of 16 your right hand? Do you swear to tell the 17 any kind has been used against me." If you 17 truth and nothing but the truth during this 18 want to take a second to look at that, if you 18 interview? 19 agree with it, you can, there's an employee 19 MR. : Yes. 20 signature where you would sign, and then you 20 MR. : Thank you, sir. What is 21 would print your name under here, where it says 21 your date of birth? 22 employee's name. 22 MR. 23 Thank you, sir, for signing. Do you 23 MR. : And our SSN? 24 understand the form? 24 MR. . 25 MR. : Yes. 25 MR. : Thank you. And your 7 8 1 current home address? 1 want to make sure that everything that they 2 MR. : , Bayville, 2 wrote is accurate. 3 New York, 11709. 3 MR. : Uh-huh. 4 MR. : And your current 4 MR. : And just stop me if S cellphone number? S anything is not accurate. 6 MR. . . 6 MR. : Okay. 7 MR. : And what is your current 7 MR. : All right. It says, "The 8 9 position wain? MR. : Correctional Counselor. 8 9 following interview was conduciiiiiilAssistant United States Attorne , AUSA, 10 MR. : And how long have you 10 , , and Office of the 11 been in that 'osition? 11 Insiector General, Special Agent 12 MR. : Since February 2020. 12 . Also present for the interview was 13 MR. : Okay. And what were you 13 Federal Bureau of Investigation Special Agent 14 prior to that? 14 15 MR. : A Lieutenant. 15 11 ," and it says your date 16 MR. : Great. Were you 16 of birth, "was interviewed at the United States 17 previously interviewed under this 17 Attorney's Office, , New 18 investigation? 18 York, New York. After being advised of the 19 MR. : Yes. 19 nature of the interview, and the identities of 20 MR. : All right. Awesome. I'm 20 the interviewing AUSA and Special Agents, 21 just going to review the report that was 21 $ ovided the following information." 22 generated, based upon your interview. I'm 22 " stated he worked for the Bureau 23 going to go kind of, a little slower through 23 of Prisons, BOP, since approximately January 24 it, so that you can actually grasp and 24 15, 2001." 25 understand what it is that they wrote. I just 25 MR. : Yes. EFTA00114415 9 10 1 MR. : "Prior to employment with 1 largely on which area of the prison he or she 2 the BOP, worked for the Building and 2 was assigned to, which rotated on a quarterly 3 Maintenance Union, the Marine Corps Reserve, 3 basis." 4 and the New York Police Department Auxiliary." 4 MR. : Yes. S MR. Yes. : . S MR. : "Those duties include 6 MR. stated he joined 6 operations, activities, solitary housing, 7 the BOP as a Correctional Officer and was 7 special investigations, and administration, as 8 promoted to Lieutenant in October 2015." 8 well as possible collateral duties, such as 9 MR. : Yes. 9 emergency irotection." 10 MR. : "He spent one year at the 10 MR. : Emergency preparedness. 11 Federal Correctional Institution, Fort Dix, 11 Same thin'. 12 when he first joined the BOP and had spent the 12 MR. : Okay. Preparedness? 13 remainder of his tenure at the Metropolitan 13 MR. : It would be the EPO is what 14 Correctional Center." 14 the title was. 15 MR. : Yes. 15 MR. : Sure. I understand. 16 MR. : "Captain 16 " stated he was assigned as the 17 was his supervisor." 17 Activities Lieutenant at the time of the 18 MR. : Yes. 18 interview, and worked the regular 2 p.m. to 10 19 MR. : Who is your supervisor 19 p.m. shift." 20 now? 20 MR. : Yes. 21 MR. : Right now, it's 21 MR. : And then on the daily 22 (Phonetic Sp. *00:06:15) He's my Unit 22 schedule, it actually listed 4 to 12, correct? 23 Manager. 23 You just came in two hours early? 24 MR. : Okay. " stated a 24 MR. : Well, what lieutenants were 25 GS-9 Lieutenant's responsibilities depend 25 doing, we always did two hour reliefs for each 11 12 1 other. 1 Watch Lieutenant would roll in, if they're 2 MR. : Okay. But if I was to 2 going by 8 to 4. Cause I, as an Evening Watch 3 actually look at that daily schedule -- 3 Activities Lieutenant, I worked 2 p.m. to 10 4 MR. : I believe it would show 4 to 4 p.m. But if, like, if the Day Watch Lieutenant 5 12, or actually, if it was activities, S was still there 8 to 4, I would be working two 6 Activities Lieutenants at that time were 6 to 2 6 hours with him or her. 7 and 2 to 10. Operations Lieutenants were on 7 MR. : Yeah, so, I guess what 8 the 8 to 4, 4 to 12, 12 to 8 rotation. 8 I'm asking is, I thought at this time, in 9 MR. : Okay. I see what you're 9 August of 2019, they were allowing the Ops 10 saying. So, there's no actual two hour change, 10 Lieutenants to come in two -- 11 when you're looking at an Activities 11 MR. : We were. We were doing two 12 Lieutenant? 12 hour reliefs for each other. 13 MR. : Yeah, no. 13 MR. : So, you were actually 14 MR. : It is what the actual 14 working the same hours? 15 daily assiiiiilioster said? 15 MR. : Same hours. 16 MR. : It is what the time, yeah. 16 MR. : Okay. 17 I forgot what the, it's been a while. I forgot 17 MR. : Yes, sir. 18 the shift number. 18 MR. : Great. So, you were, 19 MR. : Absolutely. But, so, the 19 both Ops and Activities were 2 to 10 at the 20 Activities and the Ops Lieutenant were working 20 time? 21 the same hours? 21 MR. : Yes. 22 MR. : They will, they piggyback, 22 MR. : Perfect. 23 but let's say, like, the 2 p.m. Activities 23 MR. : Well, I think that's what I 24 Lieutenant, I would be here on the, still under 24 was assigned to. I can't recall 100%. 25 the Day Watch Lieutenant, and then the Evening 25 MR. : Sure. And these are -- EFTA00114416 13 14 1 MR. : When I got interviewed. 1 shifts with other officers." 2 MR. : Sure. So, I'm going to 2 MR. : We're not officers. We're 3 give you, right now, the daily assignment 3 lieutenants. 4 rosters for both Friday, August 9, 2019, and 4 MR. : That's probably what they S Saturday, Au ust 10, 2019. S (Indiscernible *00:09:11). 6 MR. : Uh-huh. 6 MR. Okay. : 7 MR. : It's just so that, if it 7 MR. : So, switched shifts with 8 helps you refresh your memory, cause we're 8 other lieutenants, to be able to fill in for 9 tiiiiiii about so long ago. All right. 9 the Activities Lieutenant, is what you're 10 " stated he was assigned as the 10 saying? 11 Activities Lieutenant at the time of the 11 MR. : Yeah. Or, a lot of the 12 interview and worked the regular 2 p.m. to 10 12 times, we •ot mandated to stay. 13 p.m. shift. His regular days off were Mondays 13 MR. : Right. But only 14 and Tuesdays. He would, on occasion, work 14 lieutenants could actually fill those 15 overtime hours or switch shifts with other 1S positions is what you're saying? 16 officers." 16 MR. : Yeah. Only, well, a 17 MR. : Wait, I'm sorry. Can you 17 lieutenant, only a lieutenant can fill an 18 read that wain? I apologize. 18 Operations Lieutenant. 19 MR. : Absolutely. Okay. So, 19 MR. : Correct. 20 after the 2 p.m. to 10 p.m. shift, which we 20 MR. : You could have a GS-8 21 just discussed. 21 Officer cover as an Activities Lieutenant. 22 MR. : Uh-huh. 22 MR. : Okay. 23 MR. : It says, "His regular 23 MR. : Cause, like, that Friday 24 days off were Mondays and Tuesdays. He would, 24 evening, the night before, I was Operations and 25 on occasion, work overtime hours or switch 25 I had an 8 as my Activities Lieutenant. I had 15 16 1 an officer actin. as Activities. 1 officer. 2 MR. : Okay. So, then, people 2 MR. : Okay. 3 could switch that were officers? 3 MR. : She was my Activities that 4 MR. : No. Only, a lieutenant 4 night. S can't switch with an officer to fill a post. S MR. : I got you. All right. 6 They can backfill, if there's, a lieutenant 6 "As there were no Activity Lieutenants assigned 7 calls in sick. If a lieutenant is not there. 7 during the overnight hours, he had no relief 8 MR. : Okay. So you can't -- 8 officers." I don't know why they would have 9 MR. : They can use a GS -- 9 wrote that sentence in there. So, I'm going to 10 MR. : -- you can't ask an 8, 10 read thi2magraph again, just to help clarify 11 say, hey, can you switch with me? It's only if 11 this. "IIIIIII stated he was assigned as the 12 -- 12 Activities Lieutenant at the time of the 13 MR. : No. Like, as an Activities 13 interview and worked the regular 2 p.m. to 10 14 Lieutenant, I would have to call in sick to the 14 p.m. shift." 15 Captain. If I wanted a shift off, I could 15 Again, on Friday, August 9,12gliere 16 switch with another officer. I can't 16 actually the Ops Lieutenant and 'I'll' was the 17 18 necessarikSi sp with an 8 officer. MR. : Okay. And looking at 17 18 Activities Lieutenant. It says, "His regular days off were Mondays and Tuesdays. He would, 19 this daily assignment roster, I'm assuming you 19 on occasion, work overtime hours or switch 20 noticed that were actually Ops Lieutenant? 20 shifts with other lieutenants." And in this 21 MR. : Yes. I was Evening Watch 21 case, again, ou explained -- 22 Operations the night before. 22 MR. : Uh-huh. 23 MR. : On August 9th? And then 23 MR. : -- that you can't 24 was actually an 8, Acting Lieutenant? 24 actually switch with lieutenants, only if you 25 MR. : Yeah, she was a GS-8 25 get bumped and that position is filled, can an EFTA00114417 17 18 1 8 officer -- 1 There's only an Activities Lieutenant until 10 2 MR. : Yes. 2 p.m. 3 MR. : And then it says, "As 3 MR. : Right. " stated 4 there were no Activity Lieutenants assigned 4 the responsibilities of an Activities S during the overnight hours, he had no relief S Lieutenant include making rounds and placing 6 officers." You weren't doing overnight? 6 inmates in Special Housing. During rounds, 7 MR. : No. I got relieved and went 7 they ensure officers are properly carrying out 8 home that evenin'. 8 their job responsibilities and give the inmates 9 MR. : I'm not exactly, were you 9 the opportunity to address with them any 10 doing overtime shifts for the morning watch? 10 concerns. stated he often attempted to 11 12 Is that wilHie would have wrote that? MR. : It could possibly be. I 11 12 walk all the tiers, based on time." So, on this, we have heard different 13 mean, we worked overtime shifts constantly. At 13 things from different people. As an Ops 14 one point in time, we were short-staffed 14 Lieutenant, or an Activities Lieutenant, are 15 lieutenants like you wouldn't believe. We were 15 you required to go into the SHU, and I'm 16 filling this building with five or six 16 talking specifically at this time, so August 17 lieutenants, we were running the whole 17 9th, August 10th of 2019. Was a lieutenant, or a 18 building. That's one of the reasons why I 18 SHU lieutenant, was a lieutenant responsible to 19 became a counselor. I was never home. 19 go to the SHU and walk the tiers and do a round 20 MR. : Okay. So that is a 20 with the inmates? 21 little confusing. What it's trying to say, 21 MR. : With the inmates? 22 though, is that if you're the Ops Lieutenant, 22 MR. : Yeah. So -- 23 on the morning watch, there is no Activities 23 MR. : Well, a lieutenant is 24 Lieutenant? 24 supposed to, is mandatory, supposed to make 25 MR. : No. Yeah, that, no. 25 rounds. 19 20 1 MR. : So what is the definition 1 actual round, you have to actually walk the 2 3 of a lieutenant round? MR. : A lieutenant round? Well, 2 3 tiers. Diiiiiiinow that to be the case? MR. : Well, yeah. Cause the 4 in the Special Housing or general pop? 4 officer has to let you down range. S MR. : Let's talk just Special S MR. : Okay. 6 Housing. 6 MR. : The officer has the grill 7 MR. : Okay. Special Housing, one, 7 key. Nobody could just go down range in SHU. 8 the lieutenant walks through the 27 door, 8 MR. : Sure. 9 that's the outer door of the SHU. Sign in, in 9 MR. : So, the officer would have 10 the log book. Go in, go, sit down on the 10 to open the grill. You go down range and then 11 computer, login, do the True Scope rounds. Got 11 have to sign the rounds sheet at the end of 12 to enter your rounds in SHU. Go up to 10 12 each range. 13 South. Make the rounds up there. Same thing. 13 MR. : And I think I understand 14 Enter the information in True Scope. 14 what you're saying. You're saying sometimes, 15 MR. : So, when you go into 9 15 there just wasn't time to do it -- 16 South, though, and you're entering in that you 16 MR. : Uh-huh. 17 conducted a round, what does the round entail? 17 MR. : -- but does that actually 18 MR. : Well, making sure that the 18 constitute a round, actually walking down the 19 officers are doing their job. And like I said, 19 range for a lieutenant? 20 if time permits, if you can, you know, do it, 20 MR. : Well, not so much, the 21 go down the range. Go one range, two ranges, 21 officers are supposed to be making the 30 22 three ranies. 22 minute rounds. 23 MR. : And that's where, so, 23 MR. : Sure. 24 this is where we have gotten, some people are 24 MR. : The lieutenant just has to 25 saying they had to do, in order to conduct an 25 make sure that that that, he or she has to go EFTA00114418 21 22 1 in that unit and make sure that the officers 1 purpose behind the 30 minute log book. 2 are doing their rounds. Check the rounds 2 MR. : Right. 3 sheets or the log book, log into True Scope, 3 MR. : The 30 minute round sheets. 4 and, you know, make, basically, is that 4 MR. : Okay. " stated on S lieutenant is confirming that staff are doing S weekdays, the prison takes a count at 4 p.m. 6 their job. 6 The Activities and Operations Lieutenant take a 7 MR. : So, the lieutenant didn't 7 verbal count by speaking with each unit and 8 actually have to walk the tiers? 8 match that number with the count slip from 9 MR. : No. 9 Internal. If correct, they clear the 10 MR. : Okay. 10 institution count. They cannot clear a count 11 MR. : No. 11 until they receive a good verbal count from 12 MR. : And the ranges? All 12 every unit. He was not aware of any instances 13 right. So, that was your understanding? So 13 in which the count was cleared without speaking 14 when you're assigning the actual round that you 14 with ever unit." 15 conducted, it's to say that you basically did a 15 MR. : No. 16 round with your officers, to ensure they were 16 MR. : So that's correct, 17 doing their ob? 17 though? 18 MR. : Their job, and you go into 18 : MR. Yeah. Yeah. 19 the 10 South and do the same. 19 MR. . stated he would 20 MR. : Okay. But not that 20 attempt to watch the camera monitors as the 21 you're actuall conducting a round? 21 corrections officers performed the count to 22 MR. : Huh-uh. 22 ensure officers were properly counting. He 23 MR. : Like, as far as 23 could not monitor at all times, due to the 24 conductiniiiiiiind with inmates? 24 amount of activity in the Control Room." 25 MR. : No. No, that's, the whole 25 MR. : Well, it depends. During 23 24 1 the count m job is mainly taking the count. 1 that? 2 MR. : Right. 2 MR. : Yes. 3 MR. : You know, I could look up at 3 MR. : And about how many people 4 the cameras, you know, but you have a lot of 4 are present in Control when that count is being S movement oin around in Control. S conducted? 6 MR. : Sure. 6 MR. : If we're fully staffed, 7 MR. : You know, throwing keys. 7 we'll have two officers and the lieutenant in 8 If, let's, and there's been many times where we 8 the Control Center. 9 were so short-staffed, we had one officer in 9 MR. : Okay. Okay. So it's 10 Control. 10 three peoile in there? 11 MR. : Uh-huh. 11 MR. : Yeah. It's the Control Room 12 MR. : So, while I'm taking the 12 Officer, the C&A Officer, and it would be the 13 count, I'm also doing C&A. I'm helping him 13 lieutenant, Activities or Ops. 14 throw keys. You know, but as far as clearing 14 MR. : What does C&A stand for? 15 the count, yes. You cannot clear the count 15 MR. : Counts, truth be told, I 16 until you get a verbal, verbal, good verbal 16 have a total brain (Indiscernible *00:17:03). 17 count from the Unit Officer, cause we have the 17 Count -- 18 PP1, the El, in front of us with the actual 18 MR. : So, it's like Control 19 accurate count, as per Sentry. So we have to 19 Number 1, Control Number 2 -- 20 compare those numbers. You write it down. We 20 MR. : Two, yeah. 21 compare it. So, you cross it off on the Sentry 21 MR. : -- and you're saying 22 paperwork... ol I'll call in a good count. 22 Control Number 2 is -- 23 MR. : But, as far as, like, the 23 MR. : Control Number 2 is C&A. 24 4 p.m. count, the Activities or Ops Lieutenant 24 MR. : Okay. 25 has to actually be present in Control to do 25 MR. : Old school, it used to be EFTA00114419 25 26 1 called C&A. 1 10. 2 MR. : Okay. 2 MR. : So, as far as the 4 p.m. 3 MR. : I know it's Counts and 3 count, that would not have been ? 4 Accountability, I think is what the acronym 4 MR. : Well, viould have been 5 was. 5 in Control, cause he would have been the 6 MR. : Okay. So that's the 6 Control 1 Officer. 7 person who actually, like, receives the counts 7 MR. : Oh, I thought it was 8 from people? 8 Control 2 for him. 9 MR. : Yes. 9 MR. : Control, no, Control 1, 10 MR. : Is that what you're 10 is Control 1 and is Control 2. 11 saying? 11 MR. : Oh, okay. So, okay. So, 12 MR. : C&A is the one that does all 12 what would Control l's typical responsibilities 13 the Sentry work for all the movement, you know, 13 have been? 14 to make sure the roster is accurate, the 14 MR. : At 4:00, the same thing. At 15 counts, or the unit base counts and unit counts 15 4:00, people are leaving, so that person would 16 are accurate. 16 be over at the window, throwing keys. We call 17 MR. : That's Control Number 2? 17 it throwin ke s. 18 MR. : Yeah. 18 MR. : Okay. 19 MR. : So, in this case, if 19 MR. : It's just, it's an 20 you're looking at August, Friday, August 9, 20 expression. He would be taking the keys, 21 2019, would that Control Officer Number 2, can 21 radios, OC and stuff like that from the 22 you tell me who that would have been? 22 departing staff, putting it back on the board, 23 MR. : (Phonetic2. 23 giving them their chits and receiving chits for 24 1)0:17:49) for the 6 to 2 shift, and IIII 24 equipment for the oncoming staff. 25 (Phonetic Sp. *00:17:51) for the 2 to 25 MR. : Okay. So, in this case, 27 28 1 it should have been, at least at 4 p.m., the 1 Again, you said that you might glance up, but 2 person that would be signing the documents and 2 you're not actually, like -- 3 taking the count should have been this 3 MR. : Yeah. Yeah, I wasn't 4 and not 2 4 staring. S MR. : With the lieutenant. S MR. : Sure. Absolutely. 6 MR. : With the lieutenant. 6 MR. : You know? I would be 7 Okay. And after we're done with this, we'll 7 answering the phones, writing down the actual 8 just go over some of the counts, just to -- 8 count -- 9 MR. : Okay. 9 MR. : Totally. 10 MR. : But we'll move on, just 10 MR. : -- you know, the crossing 11 to make sure we can keep moving on this. I'm 11 off, and, you know, making the, especially if I 12 just going to read it over to, I can't remember 12 had seen that, like, if a count was being 13 exactly where I left off. 13 delayed, I would be, like, what's the problem? 14 MR. : Fourth paragraph. 14 And I would look. You know. 15 MR. : Third_p_lagraph? 15 MR. : I got you. So, you're 16 MR. : Fourth. M stated he 16 not, like, yeah, making sure they're doing 17 was normally relieved (Indiscernible *00:19:24) 17 their job -- 18 before 10 •.m. 18 MR. : It's not, I'm not glued to 19 MR. : I'm just to read 19 the camera. 20 this last paragraph over. "IIIIIII stated he 20 MR. : -- cause you have your 21 would attempt to watch the camera monitors as 21 own job to be doing, is what you're saying? 22 the corrections officers performed the count to 22 MR. : Yeah. 23 ensure officers were properly counting. He 23 MR. : Okay. " stated he 24 could not monitor at all times, due to the 24 would normally relieve, be relieved before 10 25 amount of activity in the Control Room." 25 p.m., prior to evening count. He had heard of EFTA00114420 29 30 1 an instance where the count was not properly 1 in the past." Any information on that? 2 completed, but he had, but it had been some 2 MR. : No. I mean, it was 3 time in the past." So, if you're that 2 to 10 3 probably, I remember when I said that. It was, 4 shift, do you do the 4, the relieving shift 4 you always hear of the horror stories, and when S would typically do the 10 p.m., is what you're S you come home, come in off your days off, you 6 saying? 6 would be, like, oh, you know, what happened the 7 MR. : Yes. 7 other day? Or this, that, and the third. You 8 MR. : Okay. Do you ever do the 8 know. 9 10 p.m.? 9 MR. : Right. 10 MR. : On nights that I was coming 10 MR. : That kind of thing. 11 in for the overni'ht. 11 MR. : Okay. 12 MR. : But, I mean, as the 2 to 12 MR. : But I have never heard it 13 10 shift, do ever do the 10 p.m.? 13 where it has been detrimental. 14 MR. : I probably have, but I can't 14 MR. : Okay. But it wasn't 15 even recall when the last time I was. 15 talking specifically about, like, August 9th 16 MR. : Yeah, yeah. It's 16 (Indiscernible *00:21:12). 17 typically that relieving officer's duty, 17 MR. : No, no. I'm talking, like, 18 though? 18 ten years. I wasn't even a lieutenant at the 19 MR. : Yeah. The relieving 19 time. 20 lieutenant. 20 MR. : Okay. 21 MR. : Lieutenant, right. 21 MR. : You know, I was still an 22 MR. : Yeah. 22 officer. 23 MR. : And then it says, "He had 23 MR. .. " stated, as a 24 heard of an instance where the count was not 24 lieutenant, he viorked to enforce policy through 25 properly completed, but it had been some time 25 verbal counseling and by example. Taking the 31 32 1 count is one of the most important duties 1 them doing the K2 or, you know, making weapons 2 corrections," I keep on saying corrections, but 2 or tattooin' or things of that nature. 3 I know it's correctional officers "perform as 3 MR. : Sure. 4 professionals." 4 MR. : You know, so, of course, S MR. : Right. It's accountability. S making rounds, being visible. That's what we 6 Inmate accountability is the most important 6 like to say, and, like, when we're training or 7 thing here. Maintain security. 7 whatever. Be visible. 8 MR. : Okay. 8 MR. : Sure. 9 MR. : You got to make sure that 9 MR. : Make the inmates see you. 10 they're all here at the end of the day. 10 MR. : So, counts are basically 11 MR. : So, are you saying, like, 11 to ensure everybody is there. And rounds are 12 basically, counts and rounds are the most 12 to ensure that inmates are kind of doing what 13 important things that a correctional officer 13 they're su osed to be doing? 14 does? 14 MR. : Yes. 15 MR. : Count, I mean, everything, 15 MR. : Okay. 16 controlling contraband, shaking down. 16 MR. : And that's a perfect, what's 17 Nowadays, with the K2, it's ridiculous. 17 the word I'm looking for? Perfect expression. 18 MR. : Right. 18 MR. : Okay. Perfect example. 19 MR. : You know, there's a lot on 19 Okay. 20 an officer's shoulders. 20 MR. : Yeah. 21 MR. : Right. 21 MR. : " stated the 22 MR. : But of course, you know, we 22 Special Housing Unit is responsible for doing 23 only do the counts at certain periods 23 rounds every 30 minutes. As the lieutenant, he 24 throughout the day. You know? The officers 24 would sign round forms, if they were correct. 25 making rounds are what helps reduce the fact of 25 He had never signed off on forms that were EFTA00114421 33 34 1 filled out in advance, and would report any 2 instances of that to his supervisors, if he was 3 aware of it." So, I'm assuming what you mean 4 there is, if you knew they were filled out in S advance? 6 MR. : I wouldn't sign them. 7 MR. : Right. 8 MR. : I'm not putting my John 9 Hancock on that. I would tell them 10 (Indiscernible *00:22:58). 11 MR. : But, how would you know 12 if they had filled it out in advance? You 13 mean, if -- 14 MR. : If I went there and sat, and 15 if I walked into the SHU unit and it was 1:00, 16 I'm just throwin the time out there -- 17 MR. : Sure. 18 MR. : 1:00 p.m., but I saw the 19 rounds sheet, it was 1:00 when I walked in, but 20 I look at the rounds sheet and the 1:30 rounds 21 are alread filled out. 22 MR. : And would that happen? 23 MR. : Very rarely. But I might, I 24 don't think I have seen it as a lieutenant, but 25 I have heard of it happening. 1 MR. : But you never really, you 2 never witnessed it? 3 MR. : But, I was trained 4 differently. I was trained, you don't put your S ink to paper unless it's the way it's supposed 6 to be, and if it is, tell the boss. 7 MR. : Now, back then, August of 8 2019, had you heard that people were filling 9 them out in advance? 10 MR. : No. I didn't. 11 MR. : No? 12 MR. : No. 13 MR. : Okay. So you're not 14 aware of anybod filling them out in advance? 15 MR. : No. I have no personal 16 knowledge. 17 MR. : "He trained officers to 18 defer their round patterns, so inmates would 19 not be aware of their timing." 20 MR. : Yes. 21 MR. : And that means it's just 22 not to be on an exactly 30 minute -- 23 MR. : Yeah. Don't always make 24 your rounds at 1:05, 1:35, 1:45. Alternate 25 your rounds. The policy states, every 30 35 1 minutes, not to exceed 40. 2 MR. : Right. 3 MR. : You know? 4 MR. stated he had S heard stories of officers not completing their 6 30 minute rounds in the SHU. Other than the 7 Jeffrey Epstein death, he had not heard of an 8 instance for a roximately five to ten years." 9 MR. : Yes. 10 MR. : So, I'm assuming what 11 you're sa in here is -- 12 MR. : Back in the days. 13 MR. : But I'm assuming what you 14 said, when you say other than Jeffrey Epstein, 15 you did hear that they did not complete their 16 30 minute rounds? 17 MR. : I mean, bureau-wide. People 18 have gotten in trouble for it before. 19 MR. Right. 20 MR. why, like, this : 21 whole, this was all new with the fact that how 22 serious it ot. 23 MR. : Okay. But you had heard 24 that, had you heard that on August 9th and 10th, 25 then, and I am assuming this means after the 36 1 fact, that people weren't conducting their 30 2 minute rounds? 3 MR. : The only thing I heard is 4 the same thing everybody else has heard, out on S the street. 6 MR. : Okay. 7 MR. : What you hear in the media, 8 what you hear on social media, what you hear in 9 the newspa ers. They were very quiet here. 10 MR. : Okay. 11 MR. : I was here that morning of, 12 after the fact, and we didn't get told 13 anything. 14 MR. : Are you talking about 15 August 10th? 16 MR. : Yeah. That Saturday. 17 MR. : Okay. 18 MR. : You know. There was a total 19 blackout. We were kept in the dark. 20 MR. : And you hadn't heard 21 anything about, like, people not conducting 22 counts or rounds? 23 MR. : No. Just, well, like I 24 said, the same thing you heard out on the 25 street. EFTA00114422 1 37 MR. : But, I mean, not from 1 38 MR. : I would just assume 2 inside the institution? 2 people would have been talking inside the 3 MR. : No. 3 institution. I wanted to make sure that you 4 MR. : No one was speaking about 4 also heard it inside the institution, not just S that? S through the media? 6 MR. : Well, I mean, the whispers, 6 MR. : Yeah. No, I mean, I, like, 7 here and there but nothing was confirmed. 7 as far as a whisper here and a rumor here, I 8 MR. : Okay. 8 chose to stay away from it, because, one, I was 9 MR. : You know? Of course, when 9 a supervisor and two, I know what was coming 10 something like this, look, it's, I have been 10 down. 11 doing this almost 21 years. When something, 11 MR. : Sure. 12 God forbid happens like this, everybody Monday 12 MR. : I knew how serious it was 13 morning quarterbacks. 13 going to be. And I was not going to entertain 14 MR. : Sure. 14 any of that. 15 MR. : Everybody talks, oh, they 15 MR. : Sure. So, you had heard 16 must have done this, or they didn't do this. 16 people saying that there were rounds and counts 17 That's all I have heard. 17 weren't complete; however, you didn't put any 18 MR. : Uh-huh. 18 credibilit to it -- 19 MR. : I didn't hear nothing 19 MR. : No. 20 official, if that's what you're asking. 20 MR. : -- because it wasn't 21 MR. : Yeah. No, no, no. 21 official? 22 MR. : I have heard rumor mills. 22 MR. : No. It wasn't, it wasn't 23 MR. : I just wanted to know -- 23 official. It was just rumor mills. It was 24 MR. : There were whispers. This, 24 whispers. It was Monday morning 25 that, and the other thing. 25 quarterbacking, for lack of better terms. 39 40 1 MR. : Okay. But that was a 1 what you're saying is that since you have 2 correct, was that a correct assessment, which I 2 worked, miiiiiiiere was about two suicides? 3 just -- 3 MR. : I had one, I was personally 4 MR. : Yes. Yes. 4 involved in one in 2003, and that's the one S MR. : Okay. S that I was, that I referenced. There was one 6 MR. : I apologize. I don't mean 6 years later. I don't recall what year it was, 7 to go lone-winded on it. 7 or the outcome of that one. I just know that 8 MR. : No, no, no. lust cause 8 the one that I was involved in, the officer in 9 when I said it, you said, no, but I just wanted 9 charge in the SHU unit got suspended for it. 10 to make sure 'au actually meant yes. 10 MR. : Okay. 11 MR. : Yeah, no. Like, I heard -- 11 MR. : So, the rounds were made, 12 MR. : With what, I know, I 12 but they weren't within that 30 to 40 minute, 13 understand -- 13 so the OIC sot hit on that one. 14 MR. : -- nothing official. Yeah. 14 MR. . And do you know why the 15 MR. : Right, yeah, yeah. I 15 OIC? 16 just, cause for the transcript, it will read 16 MR. : I think the rounds, I think, 17 that you're contradicting what I said, and I 17 if I can recall correctly, I think when he 18 just want to make sure -- 18 entered the round, about 40 minutes, but it 19 MR. : No problem. 19 turned out it didn't jive with the camera. So 20 MR. : -- what I said was 20 they suspended him. 21 actually accurate. Okay. 21 MR. : All right. So, if the 22 MR. : Uh-huh. 22 time that he wrote on the paper didn't show -- 23 MR. . stated he 23 MR. Didn't jive with the camera. : 24 recalled suicides taking place in MCC in 2003 24 MR. : (Indiscernible 25 and another several years later." So, I guess, 25 *00:27:38). EFTA00114423 41 42 1 MR. : Like, the reason, the camera 1 MR. : Okay. So it happened 2 showed we were making rounds. We just didn't 2 actually in the afternoon? 3 make them between 30 and 40, that 30 minute, 3 MR. : Yeah. That was on day 4 not to exceed 40, I believe it just didn't jive 4 shift. S with the camera. 5 MR. : Did he have a cellmate at 6 MR. : Okay. 6 the time? 7 MR. : And they hit him. 7 MR. Yes, he did. : 8 MR. : And were you actually 8 MR. : And the cellmate didn't 9 working in the SHU at the time? 9 notice? 10 MR. : I was in the SHU at the 10 MR. : His cellmate said, yo, you 11 time. 11 want to take care of this? 12 MR. : Okay. 12 MR. : Oh, wow. 13 MR. : I was one of the officers 13 MR. : And he was strung up. 14 that cut that inmate down and we tried to do 14 MR. : Was it also from, where 15 CPR on him. We did CPR on him. We got him 15 was it, where was he hanging from? 16 down to Medical, and then they rushed him out 16 MR. : He had the thing tied up. 17 in an ambulance. 17 He was between the bunk and the window. 18 MR. : And just out of 18 MR. : Okay. Was he attached to 19 curiosity, in that case, at about what time was 19 the bunk or what was he attached to? 20 he found? 20 MR. : I think he was attached to 21 MR. : Oh, that was, like, 3:30 21 the window, if I recall. I honestly don't 22 something. 22 remember. That was a long time ago. 23 MR. : In the afternoon? 23 MR. : Sure, sure, sure. 24 MR. : It was before the 4 p.m. 24 MR. : It was either the top of the 25 count. 25 bunk or to the window. He was between, I do 43 44 1 remember he was between the bunk and the 1 MR. : I don't remember exactly the 2 window. 2 dates or the stipulations on the one that 3 MR. : But that's important to 3 happened ears later. 4 note. So he actually had a cellmate at the 4 MR. : Do you happen to remember 5 time? S the name of that inmate? 6 MR. : Uh-huh. 6 MR. : Of that committed suicide? 7 MR. : And he still was able to 7 , I believe. 8 successful) - 8 MR. . ? 9 MR. : Yes. 9 MR. : Yeah. 10 MR. • -- and it was deemed a 10 MR. : Okay. " stated he 11 suicide, not a murder? 11 was on duty the night Epstein was brought to 12 MR. : Yes. 12 MCC. He was received at the rear gate and 13 MR. : Okay. 13 observed him being processed in." 14 MR. : Cause his cellmate never got 14 MR. : Uh-huh. 15 charged. 15 MR. : "At the time of his 16 MR. : And do you know what he 16 arrival, Epstein was deemed okay to go to 17 used to h!ag_tiliself? 17 general population. was unaware of his 18 MR. IIIIIII: I believe it was cut-up 18 high profile." 19 bedsheets. 19 MR. : Yes. I remember when he 20 MR. : Okay. 20 came in. The only thing that I remember that 21 MR. : If I recall correctly. 21 stuck out in my mind, he went to the same high 22 MR. : All right. And that was 22 school that I did. 23 the 2001 or -- 23 MR. : Okay. 24 MR. : That was 2003. 24 MR. : I graduated from the same 25 MR. : That was the 2003 one? 25 high school. Cause the cop, I think he was an EFTA00114424 45 46 1 NYPD task force guy with the FBI, he was from 1 MR. : Interesting. Okay. So, 2 Brooklyn and we chatted, cause we had Brooklyn 2 it was just within 24 hours, he was moved from 3 accents, and come, you know, me and the cop 3 general polulation to SHU? 4 were from, like, basically, the same area in 4 MR. : I believe so. I believe, S Brooklyn, and he was, like, what high school S less, I believe less than 48, definitely. 6 did you graduate from? And I said, Lafayette, 6 MR. : Okay. All right. 7 and Epstein actually said, so did I. I 7 " stated he knew Epstein to be in visits 8 graduated from Lafayette High School. 8 often with his legal counsel." 9 MR. : Interesting. 9 MR. : Yes. 10 MR. : I processed him. Sent him 10 MR. : "Often until 7 to 8 p.m." 11 up. I actually found out that they moved him 11 MR. : Yes. 12 to the Special Housing because of his profile 12 MR. : "Other than the intake 13 status when I came back to work. 13 questions Epstein answered on his arrival, 14 MR. : So, you had no idea who 14 IIIIIII had no other personal interaction with 15 he was? 15 him." 16 MR. : I had no idea who he was. 16 MR. : No. 17 As a matter of fact, the next morning, my wife 17 MR. : So you never just, you 18 actually said, you'll probably be getting him 18 never -- 19 soon. And showed me the phone, you know, the 19 MR. : Never chatted with him. I 20 news feed, and I said, soon? We got him last 20 would just escort him. Cause at one point in 21 night. Then I knew who he was. 21 time, a lieutenant had to move him. 22 MR. : Okay. 22 MR. : Okay. And what about 23 MR. : And then when I came, by the 23 when you would visit the SHU? Would you ever 24 time I came back to work, though, he was 24 check in on his cell or anything like that? 25 already in SEC (Phonetic Sp. *00:30:35). 25 Would you ever look through the door or say, 47 48 1 hey, what's u.? 1 MR. : The officers would have to 2 MR. : Right. When he was on, 2 do the out count. 3 like, when he would be on one tier, I remember, 3 MR. : Yeah, so my understanding 4 I think, at one point in time, he was on H 4 was that he would basically be brought down S tier, if I'm not mistaken. The only time I S around 8 a.m. and stay until almost 8 p.m. Is 6 would really see him on the tier is when I 6 that -- 7 would escort him. 7 MR. : A lot of the times, he 8 MR. : And what would you, what 8 would. 9 would be the 'urpose of escorting him? 9 MR. : So not always, though? 10 MR. : Down to attorney conference, 10 MR. : Sometimes, he would go back 11 for his liiiiiiiiiis. 11 to SHU and then a different attorney would come 12 MR. : Okay. So, would that be, 12 in and he would be brought back down in the 13 then, in the morning, you would do that? 13 afternoon. 14 MR. : It would be all day long. 14 MR. : Oh, I see. 15 He would get legal visits all day, into the 15 MR. : You know, he had legal 16 evening. 16 visits in and out of here all day long. 17 MR. : And he would be going 17 MR. : Okay. So, you talk about 18 back and forth between the SHU? 18 when you would escort him, would be that kind 19 MR. : Well, most of the time, he 19 of middle timeframe? 20 would get brought downstairs and he would be 20 MR. : Yeah. 21 there for hours. 21 MR. : So if he ever went back 22 MR. : Right. 22 to the SHU -- 23 MR. : There would be times he 23 MR. : Depending on what shift I 24 would be through the count. 24 was on. 25 iiiiiiiiiiisits MR. : Yeah. 25 MR. : Okay. And when you were EFTA00114425 49 50 1 escorting him, would you communicate with him? 1 no problem. He was being escorted by a 2 MR. : Basically, how are you 2 supervisor, so I went back into the 3 doing? All right. Well, I don't, I don't get 3 lieutenant's office. 4 too churn with inmates. 4 MR. : All right. S MR. : Sure. I would just, you S MR. : And that was the last time I 6 know, with Epstein, I'm assuming, it might 6 saw him. 7 stand out in your little, you know, in your 7 MR. : So, is the one 8 head a little bit more. Do you know the last 8 who escorted him from attorney conferences on 9 time that you had escorted him or 9 August 9th? 10 (Indiscernible *00:32:35)? 10 MR. : Was it the 9th or 19th? 11 MR. : I was about to escort him 11 MR. : The 9th. So, August 9, 12 the night before he died. 12 2019. 13 MR. : And what happened? 13 MR. : Okay. Yeah. That Friday 14 MR. : I was in the lieutenant's 14 night. 15 office, and the attorney conference officer 15 MR. : He was found on August 16 said hey, he's rill") go. But Mr. 16 10th. 17 was here, and was, like, , I 17 MR. : The Friday night. 18 will take him u'. 18 MR. : Right. Okay. 19 MR. : Okay. 19 MR. : I forget the actual date. I 20 MR. : And he said, you know, by 20 remember it being a Friday. I just forgot the 21 the way, I'm going to take him up. I'm going 21 date. 22 to give him a le al call. 22 MR. : And do you remember, 23 MR. : Okay. 23 though, the last time you had interacted with 24 MR. : I was, like, okay. No 24 him? 25 problem. is a GS-12, so. I was like, 25 MR. : No, I do not. I don't 51 52 1 recall. 1 Epstein's first alleged suicide attempt. His 2 MR. : No? Okay. And then 2 only other involvement with Epstein was to 3 again, back to SHU, when you would visit the 3 bring him food while in the SHU." 4 SHU and do a round, would you peek in on his 4 MR. : Yeah, if he was on I tier. S window or anything? Would you check with him S MR. : Okay. 6 and say, thing -- 6 MR. : Cause on I tier, the 7 MR. : I mean, sometimes, his cell ail 7 lieutenants have to, have the key to the wicket 8 was right over where the OIC desk was. 8 to be able to feed, but if he was on a regular 9 MR. : Right. 9 tier, no. There was times when, and when he 10 MR. : And I could look right into 10 was a lieutenant hold, a lieutenant had to open 11 his cell, and most of the time, I would see him 11 his, be there every time his slot was opened. 12 in it. 12 But he wasn't alwa son a lieutenant hold. 13 MR. Okay. 13 MR. : Can you explain that 14 : MR. And didn't interact with him 14 more? Cause tier is like the 10 South of the 15 though. 15 SHU, right? 16 MR. : But not actually check in 16 MR. : I tier is like a mini, it's 17 and say, are good or anything like that? 17 almost like 10 South. The inmates are self- 18 MR. : No. If I was making a round 18 sustained in there. They have their own 19 downrange, I would peek in. I would peek in 19 shower. They have their own, you know, it's 20 all the cells, if I'm downrange. 20 basically, it's a bigger room. It's almost 21 MR. : Right. 21 like the 10 South rooms. But also the same 22 MR. : But not on a regular basis, 22 thing, the SHU lieutenant, or if the SHU 23 no. 23 lieutenant, afterhours, there's no SHU 24 MR. : Okay. " stated he 24 lieutenant, only a lieutenant can open those 25 was not involved officially in regard to 25 (Indiscernible *00:34:50) boxes. The wickets. EFTA00114426 53 54 1 MR. : So, was Epstein ever on I 1 trying to get the accuracy of this thing, so 2 tier? 2 it's only -- 3 MR. : I don't recall. I don't 3 MR. : I don't, I don't remember. 4 remember. 4 That's the i oblem I remember -- S MR. : So what does this mean by S MR. • So, do you remember ever 6 his only other involvement with Epstein was to 6 bringing food in the SHU? 7 bring him food? 7 MR. : I fed him before. But that i• 8 MR. : Food. When they're a 8 might have also been just because I happened to 9 lieutenant hold, even if they're in a regular 9 be downrange. I can't recall if, I don't 10 SHU cell, a lieutenant has to be present to 10 recall if he was ever actually a lieutenant 11 open the slot. Even though the lieutenant 11 hold. 12 doesn't have to open it himself, the lieutenant 12 MR. : Okay. 13 has to be there when the slot is opened. 13 MR. : I remember he had to be 14 MR. : So, anytime inmates are 14 escorted from attorney conference. So that's 15 served food in the SHU, a lieutenant has to be 15 what, cause that's what -- 16 present? 16 MR. : How would his feeding be 17 MR. : No. Not every inmate. Only 17 done, when he was in attorney conference? 18 if the inmate is a lieutenant move. Like, if a 18 Would the would you feed him? 19 lieutenant has to be present, like, high 19 MR. : Sometimes, they would get a 20 security. Like if they're assaultive. Inmates 20 bag lunch. And they would take it up with 21 could be 'ut -- 21 them. 22 MR. : So, was Epstein ever a 22 MR. : So, as in, like, when -- 23 lieutenant move? 23 MR. : I don't remember if he ever 24 MR. : I'm not 100% sure. 24 ate in the attorney conference room, but he 25 MR. : So, that's where I'm just 25 wouldn't get the food from the food cart there. 55 56 1 He would get, like, the bag lunch from . 1 like, what time, you know, when he would get, 2 MR. IIIIIIIIII: So, like, if he, when he 2 return back at the 8 p.m. mark. Would that be 3 was escorted in the morning, they would give 3 when he would be fed? 4 him a bag lunch to bring into the attorney -- 4 MR. : Well, he would if he was S MR. : Yeah. Well, like, they S given the food in , like, not III, the bag 6 have, sometimes, I believe, he would get, I'm 6 lunches, he would have it given to him in 7 not sure, he could be escorted back to the 7 attorney conference and he would take it with 8 Special Housini to eat his meal. 8 him. 9 MR. : Okay. 9 MR. : Okay. 10 MR. : Use the restroom or 10 MR. : You know, if he was going to 11 whatever, and go down, but they get to use the 11 eat past dinnertime, but also, a lot of the 12 restroom when they're in attorney conference, 12 times, too, if he was, like, not just him. Any 13 anyway. 13 inmate. If they're downstairs, the officers 14 MR. : Okay. So you're not 14 could also place the food in his cell, and he 15 exactly sure how he was fed, then? 15 could have the food when he comes back from 16 MR. : Not down in attorney 16 attorney conference. 17 conference, no. 17 MR. : Okay. So, they can go in 18 MR. : Okay. Cause he was there 18 his cell ahead of time, put it in there, even 19 every dayiliiiii? 19 if he had a cellmate? 20 MR. : Yes. He was there pretty 20 MR. : Yes. 21 much ever day. 21 MR. : Okay. And there was 22 MR. : Okay. 22 never problems with, like, the other cellmate - 23 MR. : That I recall. 23 - 24 MR. : All right. So, the food, 24 MR. : No. I mean, for the most 25 I'm assuming, would have taken place more at, 25 part, the inmates respect each other. EFTA00114427 57 1 MR. : Okay. ' stated he 2 was aware Epstein had been moved back to the 3 SHU, and that he was required to have a 4 roommate,Iiiiiiimass email he had received." S MR. : Yeah. It went out to all 6 lieutenants. 7 MR. : So, you received an 8 email, saying that Epstein was required to have 9 a cellmate? 10 MR. Yes. M 11 MR. : Okay. And was that 12 requirement still in place on August 9, 2019? 13 MR. I believe so. 14 MR. : Okay. " stated he 15 did not have any conversations with anyone 16 regarding Epstein's need for a roommate, a 17 cellmate." So no one ever verbalized that to 18 you? 19 MR. Just in the email. 20 MR. : Just the -- 21 MR. And Psychology would let us 22 know. 23 MR. : Would Psychology actually 24 verbalize it? 25 MR. : I mean, basically, yeah. 58 1 Like, for lack of, they would say that, you 2 know, not on a daily basis. They would just 3 say, any kind of, especially if they have had a 4 suicide attempt in the past, they get put on S what's called the hot list. Psychology threats 6 are always on the hot list. Inmates that are 7 on the hot list should always have a bunkie. 8 MR. : Okay. So, anybody on the 9 hot list iiiiiiibunkie? 10 MR. : As long, if it's dictated in 11 there by Psychology. Psychology fills out the 12 hot list. 13 MR. : Right. 14 MR. And it gets, they update it. 15 MR. : So, is Psychology's hot 16 list, is it just for the people that need 17 cellmates or is it also people that can't have 18 cellmates? What is the hot list? 19 MR. : What do you mean? Can or 20 can't? What mean? 21 MR. : Can't, cause aren't there 22 some people that have, like, you know, 23 (Indiscernible *00:38:34). 24 MR. : Separation, no, the hot list 25 doesn't pertain, the hot list is psychological. 59 1 It's from Ps Psychology generates it. 2 MR. : So, if you're on the hot 3 list, eveiiiiiiigets a cellmate? 4 MR. : Yeah. If it's annotated in S there. It will, every inmate's, in the hot 6 list, a picture of the inmate is in there. 7 That is, whether he or she is in for a Psych 8 study or a forensic study or what have you, and 9 it will say, you know, suicide attempts in the 10 past. Or cutter. Or what have you. 11 MR. : And where would that hot 12 list be? 13 MR. : The hot list is kept in SHU. 14 MR. : Where in the SHU? 15 MR. : It should be in a, either on 16 a clipboard or in a folder. 17 MR. : And do you know where it 18 was on August 9, 2019? 19 MR. : It should have been, I'm not 20 100% sure. I can't recall, but it should have 21 been on a cli board on the hook. 22 MR. : And are the officers -- 23 MR. By the officers' station. 24 MR. : Are the officers that are 25 in SHU required to look at that hot list? 60 1 MR. llYes. 2 MR. : All right. So, they 3 should know -- 4 MR. : They should be familiar with 5 who is on the hot list. 6 MR. : So, is everybody that 7 worked in the SHU, should have they known that 8 Epstein was required to have a cellmate? 9 MR. : Yes. 10 MR. : Is there any reason for 11 someone to say that they didn't know that 12 Epstein was re to have a cellmate? 13 MR. : Unless they weren't assigned 14 to the post and they were thrown in there on 15 overtime or mandated to work overtime and they 16 weren't familiar with it, that can happen. But 17 if you're steady, assigned to that post, you 18 should be familiar with the hot list. 19 MR. : Okay. And is there any 20 kind of requirement for people, like, overtime 21 that are, you know, not regularly working in 22 the SHU, to be either briefed on the hot list 23 or to review the hot list when they joined? 24 MR. : It all depends. Like, I 25 mean, a good SHU officer, worth his weight in EFTA00114428 61 62 1 salt, would at least talk the staff member 1 , and basically, is 6 to 2. 2 through it. But, like I said, there was plenty 2 is a senior staff member. 3 of times where the entire SHU crew were all 3 IPhonetic Sp. *00:41:12) was a rookie. Officer 4 overtimers. 4 IIIII is a senior staff member. So, three out S MR. : Right. 5 of the four on the day shift. 6 MR. : So, nobody came to work. 6 MR. : So, you're saying 7 MR. : Okay. 7 everybody but -- 8 MR. : And a lot of the times, you 8 MR. : Yeah. 9 would have SHU crews, never mind just SHU 9 MR. : -- should have known? 10 crews, institutional staff that would be 10 Okay. What about for the evening shift? 11 zombies, because they had been getting stuck 11 MR. : Evening shift? All right. 12 four days in a row. So a lot of the times, 12 had a couple of years on the job. The 13 things, you know, it's a lot to absorb. You 13 SHU floor was unassigned, because we were 14 just, you•iiThr i to do the job. 14 short. There was only three officers. 15 MR. : Okay. So, looking at the 15 is non-custody. So, would 16 August 9, 2019, roster, and I'm going to say 16 not be super familiar with it, because he 17 from the 8 a.m. hour on to the end of the day, 17 worked warehouse. 18 for the people that were working in the SHU, 18 MR. : Okay. 19 can you tell me who you believe should have 19 MR. : And he's with commissary. 20 known that he was required to have a cellmate? 20 MR. : Was he a -- 21 MR. : For the day shift or the 21 MR. : Noel was fairly new. She 22 evening shift? 22 had, maybe, just a little over a year on the 23 MR. : Just from 8 a.m. on. 23 job. 24 MR. : 8 a.m. on. All right. 24 MR. : But if Noel was a regular 25 Well, it looks, there was three officers, 25 SHU person, that was her quarterly post, should 63 64 1 she have known what the hot list was? 1 MR. : Every time it gets updated, 2 MR. : Yes. 2 and they out a new one, it should be reviewed. 3 MR. : And should have she known 3 MR. : Okay. 4 that Epstein was required to have a cellmate? 4 MR. : And I don't, I honestly S MR. : Yes. You have to sign for S haven't seen it in a while, cause now, my 6 the hot, you have to sign that you reviewed the 6 contact with Special Housing is limited, now 7 hot list. 7 that I'm a counselor. 8 MR. : Oh, you do have to sign 8 MR. : Did you make that note? 9 that? 9 MR. : Yeah. Can I ask a question 10 MR. : Yeah. Uh-huh. 10 on that? 11 MR. : All right. And who, when 11 MR. : Yes. 12 13 do you siiiiiii? MR. : Last I checked, I don't, I 12 13 MR. MR. : Mat exactly are you signing? : That you reviewed the hot 14 can't get quoted on this, cause I'm not 100% 14 list. 15 certain. We would sign it a lot, like, well, 15 MR. : But, is that, like, a form or 16 at least the lieutenants, would sign it when we 16 is it on the coo), -- 17 would do lieutenants meetings and meet with 17 MR. : It's a sign-in sheet. 18 Psychology and go, review the hot list, we 18 MR. : A sign-in sheet? 19 would alliiiiiiiiiit. 19 MR. : Yeah. 20 MR. : Now, I'm assuming the hot 20 MR. : Okay. 21 list is ever-changing, correct? 21 MR. : And you know that 22 MR. : Yes. Psychology always 22 lieutenants had to, but do you believe the 23 updates it. 23 officers had to sign the review of the hot 24 MR. : So, how often does the 24 list? 25 hot list have to be signed? 25 MR. : I'm not 100% sure, but I EFTA00114429 65 66 1 know, as they have, they're require to review 1 only a hot list in SHU? 2 the hot list. They should be familiar with 2 MR. : That I know of. 3 that hot list. Know who their psychological 3 MR. : Okay. So, my question, 4 inmates are, just as well as reviewing the 4 sorry, I probably was unclear, is at this time, S posted picture file. S the SHU hot list, you being the Activities 6 MR. : Okay. 6 Lieutenant, or, in this case, the Ops 7 MR. : To know who your high 7 Lieutenant on that specific date, August 9th, 8 profile and our dangerous inmates are. 8 would you have reviewed and signed that hot 9 MR. : All right. So, at that 9 list? 10 time, you being an Activities or in this case, 10 MR. : Not every day. 11 an Ops Lieutenant, would have you had to have 11 MR. : Yeah, yeah. But, like, 12 reviewed and the hot list in the SHU? 12 when it was -- 13 MR. : No, no, no. It's, I would 13 MR. : Generated, yes. 14 sign it here. Like I said, in the lieutenants 14 MR. : Right. So, point being, 15 meetings, we would go over it with Psychology. 15 like, if Epstein was on the hot list, you would 16 MR. : Sorry. I mean, the SHU 16 have signed and reviewed it? 17 hot list, is what I mean. 17 MR. : Yes. Of course. I mean, 18 MR. : No, that's the one that 18 like I said, anybody at that point in time 19 would be there. The hot list is just generated 19 should have knovm that he was going to be on 20 by Psychology. It's not like there's one for 20 the hot list. 21 SHU, one for the lieutenant's office, one for 21 MR. : Okay. 22 here. It stays in SHU, but Psychology would 22 MR. : Especially after the first 23 always make sure we familiarize ourselves with 23 suicide attempt. 24 it. 24 MR. . Okay. And do you think 25 MR. : And is it only, is there 25 anybody in the institution, with his high- 67 68 1 profile nature and the fact that he had a first 1 MR. : So, shouldn't everyone 2 suicide, suicide attempt, including these 2 have known that he was required to have a 3 people that you mentioned in the SHU, is there 3 cellmate? 4 any reason for anybody to say they didn't know 4 MR. : In that sense, yes. S that Epstein was required to have a cellmate? S MR. : All right. And 6 MR. : I don't know. 6 especially the fact that he is in the SHU, he 7 MR. : You don't know? 7 is, at the time, I think, your most high- 8 MR. : No. I mean, the people that 8 profile inmate. 9 are assigned to SHU, but the problem is, if you 9 MR. : Uh-huh. 10 look, overtime. He wasn't assigned. Overtime. 10 MR. : Do you believe that they 11 She got assigned to that post, but it probably, 11 should have known that he was required to have 12 I don't believe it was her post for the 12 a cellmate? 13 quarter. You know? I'm not, I don't, I can't 13 MR. : Yes. 14 recall 100%. 14 MR. : Okay. " stated 15 MR. : But as far as, aren't 15 Lieutenant was the SHU lieutenant. He 16 people that work in this facility, correctional 16 believed Lieutenant would have known 17 officers first? 17 Epstein required a roommate or a cellmate as it 18 MR. : Of course. Of course. 18 is a regular responsibility. He believed 19 That's the thin,. 19 Lieutenant would have enforced the 20 MR. : And if they know that the 20 roommate rule. stated he had worked 21 high-profile nature and the fact that he tried 21 the 2 p.m. to 10 p.m. shift on August 9, 2019. 22 to commit suicide, don't all officers pretty 22 He was relieved around 9:50 to 9:55 p.m. that 23 much know, if you try to commit suicide, you're 23 evening. He was not aware that Epstein did not 24 required to have a cellmate? 24 have a roommate." 25 MR. : Of course. 25 MR. : No. EFTA00114430 69 70 1 MR. : "He did not know , 1 MR. : PP, I believe it might be a 2 Epstein's former roommate, had left MCC 2 38. I don't, off the top of my head, I don't 3 leaving Epstein without a roommate. 3 remember. I know it's the quarter's, the 4 found out the following morning. He had been 4 movement roster. I haven't done it in a while. 5 workiag_25 Operations Lieutenant that evening. S MR. : Well, there's some of 6 7 I. IIIIII had been working as Activities Lieutenant. She had made the rounds." 6 7 those thiiiiiiiire going to review after -- MR. : Yeah. But I know it's a 8 All right, so on this, I'll guess we'll 8 Sentry, it's got to be entered in Sentry, and 9 just go one sentence at a time. So you didn't 9 then basically, it gets transferred over to the 10 know that day that Reyes had left the 10 lieutenant's lo'. 11 institution is what you said? 11 MR. : Okay. 12 MR. : No. No. 12 MR. : Right? At, you know, to 13 MR. : Now, is that -- 13 monitor what movement you had, just to make 14 MR. : I was unaware. 14 sure your numbers jive with the institution 15 MR. : Now, is that something 15 numbers at the end of each shift. 16 that if he, if he had left, is that something 16 MR. : Okay. So, in this case, 17 that you should have known? 17 do you believe someone should have, being that 18 MR. : No. What happens is, when 18 it was Epstein, and Epstein's cellmate, Reyes, 19 inmates go to court, and then they get released 19 left the institution? Should someone have told 20 or transferred out, they don't necessarily tell 20 you this? 21 us. Basically, what happens is then, the only 21 MR. : Should somebody have told me 22 way we're going to know anybody moved is when 22 directly? 23 we do the PP30 at the end of the night. Right? 23 MR. : Yeah, as the Ops 24 25 Just to, iiiiiiiiiwrite down who -- MR. : Is it PP30 or 38? 24 25 Lieutenant, you have Epstein, your most high- profile. He is required to have a cellmate. 71 72 1 , his cellmate, leaves the institution. 1 Belongings. That means they're not coming 2 Should someone have notified you? 2 back. 3 MR. : I would have liked to be 3 MR. : And that's pretty much -- 4 notified. 4 MR. : Most of the time, they're S MR. : So, who should have S not coming back. There are occasions where 6 7 notified iiiiiiit Reyes was -- MR. : When he departed the 6 7 they cancel the bus, or they cancel the transport or Air America, they will cancel, and 8 institution, somebody should have been 8 then they'll come back, but most of the time, 9 notified. Maybe not me, but somebody should 9 when they go WAB, that means they're going. 10 have known. 10 They're either going home or going to whatever 11 MR. : Okay. So, if he departed 11 institution the getting moved to. 12 the institution at 8:38 a.m., and he's listed 12 MR. : Right. So, in this case, 13 as pre-remove, removed off of the records, how 13 if people know that Reyes leaves at 8:30, he's 14 should have that went down? 14 moved down by the OIC from the SHU to , WAB. 15 MR. : If he was known to not come 15 What should have happened at that point? 16 back, then he should have had gotten a new 16 MR. : So, I would assume that 17 cellie. 17 during the day, on a Friday, the lieutenant, 18 MR. : Like right away? 18 the SHU lieutenant is here. 19 MR. : As soon as humanly possible. 19 MR. : So, if the SHU lieutenant 20 MR. : Okay. So, if people 20 is actually off that day, no SHU lieutenant, 21 claim that they didn't, they weren't, they 21 you got -- 22 assumed he wasn't coming back, cause he went 22 MR. : A lieutenant should have, a 23 With All Belongings. So, if someone goes With 23 SHU, a su'ervisor should have been notified. 24 25 All Beloniiiiii- MR. : WAB means With All 24 25 MR. : Okay. MR. : And been like, hey, he don't EFTA00114431 73 74 1 have a bunkie no more. 1 MR. : Uh-huh. 2 MR. : Okay. And if that -- 2 MR. : Should they have notified 3 MR. : And then it should be, you 3 the lieutenant? 4 know, then 'et him one. 4 : MR. I should have been notified. S MR. : All right. So, and if S MR. : And who should have you 6 7 the OIC, let's, for the benefit of the doubt, OIC does inform one of the lieutenants, let's 6 7 been notified MR. iii? : At least the SHU crew. They 8 say this case, it looks like Activities was 8 should have been, like, hey, this guy doesn't 9 IIIIII. And the Ops was . 9 have a cellmate. 10 R. : Uh-huh. 10 MR. : If , the former Ops 11 MR. : And no action is taken by 11 Lieutenant, knows that, at the very least, 12 them. What would be the next thing that could 12 Reyes left the institution -- 13 have happened with this, to make sure, you 13 MR. : Uh-huh. 14 know, Epstein, high-profile, doesn't have a 14 MR. : -- possibly for court. 15 cellmate. What should have, how could this 15 Maybe he doesn't know he's WAR, but he knows 16 catch up to itself? How could we rectify the 16 that he left. Should he have notified you that 17 fact that Eistein was -- 17 Reyes was -- 18 MR. : Well, that's, then, if 18 MR. : Well, if he had knowledge, 19 nobody is notified no one knows. 19 you know, that's part of taking over. You 20 MR. : Right. So, would the 20 know, the changeover. Hey, anything happen? 21 SHU, after is gone, the next, you 21 Anything I need to know? (Indiscernible 22 know, and his crew leaves and then the next SHU 22 *00:51:00 23 crew comes in, should have they, then, said, 23 MR. : In this case, Reyes, 24 hey, Reyes isn't here. We're doing our rounds. 24 knowing that, if he knew Reyes was Epstein's 25 There's nobody in there. 25 cellmate, had left the institution, should have 75 76 1 2 he notified that? MR. : I mean, if he had direct 1 2 MR. Yes. MR. : : Should she have known, 3 knowledge, possibly. Like, that's the thing. 3 Reyes is gone. Epstein is without a cellmate, 4 It was, no one knew. 4 when she did her round? S MR. : But, if he say2he knew, S MR. : If she found it. I don't 6 he knew that, well, let's say if IIIII says, 6 know, cause I wasn't there. 7 yeah, I knew Reyes left. I just wasn't certain 7 MR. : No, no, no. I'm saying, 8 he wasn't comin' back. 8 should she have, should that be, like, when she 9 MR. : That's possible. 9 is doing her round in the SHU, is that 10 MR. : But should have he 10 something that she should have recognized? 11 notified "ill, 11 MR. : If she went downrange, 12 MR. : I should have known about 12 maybe. But if she didn't go downrange, and no 13 it. Whether or not it was from or from 13 one told her, it would be the same ballpark. 14 the SHU crew, especially cause he was a hot 14 No one told her. She is, you know, it's 15 inmate. 15 unbeknownst to her. 16 MR. : Okay. So, either 16 MR. : When she went to the SHU, 17 or the SHU crew should have informed you? 17 should -- 18 MR. : Yes. 18 (knockin' on door) 19 MR. : And no one informed you? 19 MR. • -- we're in here. When 20 MR. : I wasn't informed. 20 she went into the SHU, should the OIC crew, or 21 MR. : Okay. 21 not the OIC, the SHU crew have told her, Reyes 22 23 MR. : I found out the next day. MR. : Right. What about, I 22 23 is gone, • is without a cellmate? MR. : Possibly. Yeah. I mean, a 24 know your Activities Lieutenant, you said, is 24 lieutenant is not going to know anything unless 2S the one who did the round, correct? 25 the officers relay that information to the EFTA00114432 77 78 1 lieutenant. We're not superhuman. 1 gone? 2 MR. : So, if she did her 2 MR. : To my understanding, yes. 3 rounds, and again, you said that she is the one 3 MR. : And never told you 4 who did the rounds, do you believe it was their 4 as -- S responsibility to say, hey, Activities S MR. : No. I don't recall her 6 Lieutenant, just so you know, no one is in that 6 telling me. And like I said, just knowing her, 7 cell. Reyes is gone. Just want to give you 7 and her caliber she would have told me. 8 the heads u'. Should that have happened? 8 MR. : Right. " stated 9 MR. : Yes. 9 if he had known Epstein did not have a 10 MR. : Okay. And then she would 10 roommate, he would have ensured he did." 11 have then informed you -- 11 MR. : Yes. 12 MR. : Of course, listen, she would 12 MR. : "And he knew him to be on 13 have definitely notified me. She is, for the 13 the hot list." 14 lack of better terms, and I don't mean to use 14 MR. : Yes. 15 profanity she is a shit hot lieutenant. 15 MR. . stated the 16 MR. : Okay. 16 following morning, August 10, 2019, at 17 MR. : She is on her job. 17 approximately 6:30 to 6:45 a.m., he received a 18 MR. : Yep. 18 call from Lieutenant , informing 19 MR. : She would have definitely, 19 him that Epstein had attempted suicide and he 20 if she knew, she would have let me know. 20 should go straight to the hospital, instead of 21 MR. : Okay. 21 reporting to the jail for duty." 22 MR. : And we would have fixed it. 22 MR. : Yes. That's what I did, I 23 MR. : So, whoever was working 23 went straiiiiiiiiiiekman Hospital. 24 on her, on that shift, when she visited, should 24 MR. : Okay. " stated, 25 certainly have informed her that Reyes was 25 at the hospital, the escorting staff informed 79 80 1 him that Eistein had passed away." 1 hospital." 2 MR. : Yes. 2 MR. : Yes. 3 MR. : "He saw his body and told 3 MR. : Now, were they people 4 his officers not to speak to anyone and direct 4 that escoiiiiiiistein to the hospital? S any questions to the prison public relations S MR. : That's what I believe, yeah. 6 officer." 6 They had to be, because, like I said, I was on 7 MR. : Yes. 7 my way to the hospital. I went straight to the 8 MR. : Do you know who that was 8 hospital. I believe those were the three staff 9 at the time? 9 members that they got to be the escorting 10 MR. : It's usually the Executive 10 staff. 11 Assistant so it should have been Lee Plourde. 11 MR. : Okay. Now, as far as 12 MR. : Okay. So, Lee Plourde? 12 Epstein going to the hospital, do you know when 13 MR. : Lee Plourde is the public -- 13 he actualiiiiiiideceased? 14 MR. : Yeah. "He said the same 14 MR. : I remember, my mission at 15 to the hospital security." 15 that point, Lieutenant had told me, go 16 MR. : Yes. 16 straight to the hospital, tell the officers, 17 MR. : Okay. So that was not 17 you know, keep the area secure and record time 18 people that were BOP, but the hospital -- 18 of death. I think the hospital told me it was, 19 MR. : No, yeah. There was 19 like, 7 something. I don't recall the actual 20 hospital security around the room, too, and I 20 time, and then I called Lieutenant and 21 was, like, no one goes in here unless it's 21 gave him that time, and then he was, like, all 22 hospital staff or Bureau staff. 22 right. We already got it. Bring yourself back 23 MR. : Okay. " stated 23 to the institution. 24 officers , (Phonetic Sp. *00:54:46) 24 MR. : So, do you know if, prior 25 , and were on-scene at the 25 to that time, he had skean any signs of life? EFTA00114433 1 81 MR. : No. I am unaware. No. 1 82 like they were working on him. 2 MR. : Okay. So did anyone 2 MR. : And they were still 3 mention to you or state to you, he died 3 working on him? 4 actually at the prison? 4 MR. : No, no, no. They had worked S MR. : No. S on him. 6 MR. : They just pronounced him 6 MR. Okay. 7 dead there? 7 : MR. He was already deceased, but 8 MR. : They told me they pronounced 8 he still had the intubation tube down his 9 him dead. I don't remember the actual time. 9 throat. 10 It was 7 something, which was the time of death 10 MR. : Okay. " stated he 11 that the hosiital recorded. 11 had not taken any photographs of Epstein's body 12 MR. : Okay. 12 and advised his officers to stay with the body 13 MR. : And that's what I relayed 13 until the could be relieved." 14 back to Lieutenant and then he said, all 14 MR. : Yes. 15 right, we got it already. Come to the 15 MR. • " stated, back at 16 institution. And then I left the hospital. 16 the prison, he resumed his activities as 17 MR. : Do you believe that when 17 lieutenant and was guided to collect log books 18 he was found at the BOP institution, he was 18 and escort FBI agents as part of the death 19 actually dead on scene? 19 investigation." 20 MR. : I don't, I don't know. I 20 MR. : Yes. 21 can't, I can't answer yes or no. 21 MR. : Were any OIG there at the 22 MR. : Okay. 22 time? 23 MR. : I just know, when I saw his 23 MR. : Not that I know of. There 24 body in the thing here, the intubation tube in 24 were so many agents and people coming in and 25 his neck and dorm his throat, and it looked 25 out, taking computers, I don't, I could have 83 84 1 been escorting OIG and I didn't even know. 1 MR. : All right. Great. So 2 MR. : Sure. 2 now, so, everything seemed accurate, as far as 3 MR. : Basically, Captain 3 this was written? 4 just made me go along and go and try, assist in 4 MR. : Yes. S any way I could, anytime, any documents they S MR. : Okay. Perfect. 6 needed or whatever. That's what I did. 6 MR. I just have a couple of 7 MR. : Sure. 7 follow-ups. 8 MR. : Pretty much the rest of the 8 MR. Yep. Please. Go ahead. 9 day. 9 MR. You mentioned round sheets. 10 MR. : Okay. " stated he 10 Do you recall if here, at the MCC, in the SHU, 11 was not aware of the destruction of any 11 the round sheets are kept at the end of each 12 records." 12 tier? Or are they kept on the desk? 13 MR. : No. 13 MR. : They're supposed to be kept 14 MR. ' •. stated he knew 14 at the end of each range. 15 Officer Thomas for a few years and knew Officer 15 MR. : So, as a lieutenant, at that 16 Noel as a newer officer, but had no personal 16 point, when you made your, if you had made your 17 relationshi' with either." 17 rounds -- 18 MR. : No. 18 MR. : If I have seen the sheets on 19 MR. : All right. Cool. 19 the desk, I would always tell the officers they 20 Anything that they missed or failed to capture? 20 need to be downrange, not on your desk. 21 MR. : No. I was being refreshed, 21 MR. : Okay. 22 as you were readin' it. 22 MR. : And I would not initial 23 MR. : And that's for future, is 23 them, unless they were, I wouldn't initial them 24 what I'm talking about. 24 unless the were accurate. 25 MR. : Okay. 25 MR. 'I'll': Okay. EFTA00114434 85 86 1 MR. : Uh-huh. 1 officers are doini their rounds. 2 MR. : So, on that note, then, 2 MR. : So, when did her 3 when you would go into sign that document, 3 round on August 9, 2019, should she have had to 4 would you, go downrange to grab it? 4 have gone downrange, especially on the range 5 MR. : No. There was times where I S that Epstein was on? 6 would see it on the desk and I would be, like, 6 MR. : If the round sheets were 7 these need to be downrange. 7 downrange. 8 MR. : So, you're, when you walk 8 MR. : Right. And that's where 9 into the SHU, you are supposed to walk 9 they are su osed to be? 10 downrange to do -- 10 MR. : Like they're supposed to be. 11 MR. : To sign it. 11 MR. : Okay. And if they 12 MR. : -- to sign it there? 12 weren't, she should have notified SHU. Hey, 13 MR. : Uh-huh. 13 you guys lot to be keeping these down here? 14 MR. : But oftentimes, that 14 MR. : Yes. 15 would -- 15 MR. : All right. And is the 16 MR. : As of late, as of late, that 16 purpose of that, though, to ensure that people 17 is where they are now. It all depends on what 17 are doing rounds and that's where it, when they 18 shift, because the morning watch lieutenant, 18 sign that? 19 the overnight lieutenant, has those sheets 19 MR. : Well, that's where they're 20 already sent dorm to that person. 20 supposed to be, for the sake of the officers, 21 MR. : Uh-huh. 21 that's, it's to prevent fudging the round 22 MR. : In the thing, but you still 22 sheets. 23 have to go up and sign the round sheets anyway. 23 MR. : Right. 24 Every shift, those round sheets have to be 24 MR. : You know, if they're down on 25 signed. Cause you have to ensure that the 25 the desk, and you can just write whatever you 87 88 1 want, for lack of better terms. Look, I'm 1 MR. : Nothing as far as, like, 2 (Indiscernible *00:59:40) I'll call a spade a 2 that he was hi'h-profile. You know. 3 space. Right? If somebody is going to fudge 3 MR. What was the, you mentioned 4 around, it's easier for them to do it that way. 4 instructions from Psychology, right? S MR. : Uh-huh. S MR. : Uh-huh. Which were 6 MR. : Then if it's downrange. If 6 basically the same, like, you know, he needs a 7 it's downran e ou have to go downrange. 7 bunkie. He is high-profile. 8 MR. : Right. 8 MR. : But there was no 9 MR. : So, you're going to look in 9 instructions, like you are never, as a 10 each cell and then when you get to the end of 10 lieutenant, there was no special instructions 11 that tier, that's when you scribble your time. 11 (Indiscernible *01:00:36). 12 That's why it's easier for that round sheet and 12 MR. : If he was a lieutenant move, 13 that camera to jive. 13 our instructions were a lieutenant has to be 14 MR. : Uh-huh. 14 present when he moved. So, a lieutenant has to 15 MR. : Cause they're downrange. 15 escort him that I recall. 16 MR. : Okay. Sorry. 16 MR. That email you mentioned that 17 MR. : Sorry. 17 you got. Who was that from? The mass email? 18 MR. : No, no. And the point of the 18 MR. : I believe it was from the 19 lieutenant signing it is not that the 19 Captain. 20 lieutenant did the rounds -- 20 MR. : We're going to go through 21 MR. : It's to make sure that the 21 all that. 22 officers are doing what they're supposed to be. 22 MR. : Or Correctional Services. 23 MR. : Okay. Do you recall any 23 I'm not, I'm not exactly sure who sent that 24 special instructions coming down from the 24 out. 25 Warden or the Captain, regarding Epstein? 25 MR. Okay. EFTA00114435 89 90 1 MR. : It would be generated from 1 be able to see if people were going up and down 2 all the department heads. 2 L tier, from this camera angle? 3 MR. IIIIII: Okay. That's it. That's all 3 MR. : You would be able to see a 4 I had. 4 quick movement, but not the full, cause you S MR. : Okay. But you're S can't see the ste s. 6 familiar with the SHU, correct? 6 MR. : Is there a way for them, 7 MR. : Yes. Yes. 7 over this way, to like, go over here and go up 8 MR. : (Indiscernible *01:01:15) 8 here without you seeing them come up, or is 9 all right. Great. Looking at this camera 9 this so close -- 10 angle, this is a still shot. Can you tell me 10 MR. : No, no, no. This is 11 what it is that we're looking at here? 11 totally, this is elevated. This area right 12 MR. : This is the camera that's up 12 here, this is a staircase door. 13 in, on the upper tier, by the 46 door, which is 13 MR. : Okay. 14 going into 10 South. This camera view right 14 MR. : This is an elevated 15 here is of the multipurpose area. These stairs 15 position. You can't, this camera would see 16 right here, that you can barely make out, this 16 staff comin., 17 would be tier. 17 MR. : Oh, but as far as this 18 MR. : Okay. 18 angle, though, could you, could you, if anybody 19 MR. : H tier. J, K tier down 19 was going us and down L tier -- 20 there. You can't see L and M. This little 20 MR. : And if anybody was coming 21 shadow right here is the pipe, but that's about 21 this way -- 22 all you can see of L tier. And then M tier is 22 MR. -- could you tell that 23 down thosiiiiiiiiiind that's the OIC's station. 23 from here? 24 MR. : So, from this camera 24 MR. : -- and going up, you would 25 angle, this, if Epstein is in L tier, would you 25 be able to, like I said, you would be able to 91 92 1 see a flash of movement, but you really 1 the officer's station, what is that staircase 2 wouldn't be able to see, judging from the way 2 going to? 3 this picture is, you really wouldn't be able to 3 MR. : That's going to ) tier. 4 see much of the actual step climbing. 4 MR. : Okay. Awesome. Can you, S MR. : Okay. But could anybody S on this SHU map, so this first page is the 6 get up to L tier without you seeing from this 6 first tier. 7 angle in the SHU? 7 MR. : Wait. Which, first tier? 8 MR. : Well, you would see them go 8 MR. : So, this is the, we have 9 this way. But whether or not they were walking 9 the SHU layout. It's not perfect, but this is 10 towards the kitchen or going up to L tier would 10 what was 'rovided to us. 11 be hard to distinguish, just from looking at 11 MR. : Yeah. Cause I'm trying to, 12 this. If the camera were there -- 12 all right so -- 13 MR. : So, is this a blind spot? 13 MR. : So, this is, like, for 14 Could someone come from this way and go up L 14 instance, you know, you will see the first 15 16 tier with,' seeing? MR. : Yes. Yeah. Without a 15 16 letter is what the, so this is I tier. It looks like this is M tier. And the second one, 17 doubt. 17 over here, this is the second floor, this is my 18 MR. : Okay. 18 understandin'. Here's ), L. 19 MR. : From, you could come from 19 MR. : I can barely see it. 20 straight outside and then go up. 20 MR. : Yeah. Maybe that's I. I 21 MR. : All right. And what, 21 don't know. 22 this staircase that is clearly visible, this is 22 MR. : May I? 23 the officer's station, right? 23 MR. : Absolutely. This is, so, 24 MR. : Yes. 24 what I'm going to ask you to do is, from 25 MR. : And right to the left of 25 looking at this -- EFTA00114436 93 94 1 MR. : J. Okay. There it is. 3. 1 MR. : For OIC, perfect. And 2 MR. : -- keeping in mind where 2 then, so, if you're looking straight at this, 3 the officers' station is -- 3 this is that, can you put a star next to 4 MR. : And this is L. Okay. 4 whatever, whatever staircase you're looking at S MR. : -- and where this is, can S in this video? 6 you kind of point to me, can you put the 6 MR. : Okay. This is 3 tier, right 7 location of where this camera is on here? 7 here. 8 MR. : Oh, shit. 8 MR. : 3 tier. All right. 9 MR. : Looking down? 9 MR. : J. And this is M. 10 MR. : Recreation. 10 MR. : Okay. 11 MR. : So, if you're looking at 11 MR. : I'm assuming that's the one 12 -- 12 going down. 13 MR. : It would be up here. 13 MR. : Okay. Great. And then 14 MR. : Right. So, like, the 14 as far as, this is what you're looking at, 15 angle, like, you can put a circle, and I'm 15 right here, where would you believe the camera 16 pointing towards, so I guess put a big circle 16 would be? 17 where the officers' station would be. 17 MR. : Judging from the way this 18 MR. : All right. This is 3 tier. 18 is, it looks like the camera is panning from, 19 That's right there. And there's the wall, 19 like, here. That way. 20 right there, so, right there, this is L tier, 20 MR. : Oh, right. So, if this 21 going up and M would be down, yeah. That's 21 is, this is tier -- 22 right. So this is basically where the -- 22 MR. . . 23 MR. : So then you can put OC in 23 MR. : -- right, so, would it 24 the middle. 24 be, like, kind of over here? 25 MR. : OIC. 25 MR. : Here's the, this is the 95 96 1 lieutenant's office up there. That's here, in 1 this is, thank you. And this is someone else's 2 the corner. And I think the camera is above 2 drawing. I just want to see, this kind of 3 the lieutenant's office. 3 (Indiscernible *01:06:32) this is actually what 4 MR. : Okay. 4 we said here. Yeah, so it looks like, and this S MR. : So, maybe like right here, 5 is everything. Cool. Now, was there, you 6 maybe? I'm not 100% certain. But it should 6 said, you mentioned a bulletin board that had 7 be, it's somewhere over here, the camera and 7 the hot list? Where would that be? 8 the camera •ans that way. 8 MR. : Well, I can't, right here, 9 MR. : Can you just put a star 9 it's hard to tell from that, but usually, the 10 there and in that open spot next to it, just 10 hot list should be somewhere right up there on 11 write camera? All right. Perfect. Do you 11 the hook. 12 mind just initialing and dating that? And then 12 MR. : Okay, so this is the 13 we're also -- 13 bulletin board here? 14 MR. : Eight, today is the 4th, 14 MR. : Yeah. And there's also, 15 cause it'iliiiiiiiiter's birthday. 15 now, I don't, not then, but there was, there's, 16 MR. : Oh, is it? Happy 16 there was stuff up here, but not, I don't 17 Birthday. 17 believe it was a bulletin board. It's a 18 MR. : Twenty-one. 18 bulletin board now if you go up there. 19 MR. : How old? 19 MR. : All right. 20 MR. : Twenty-one. 20 MR. : But there was, the hot list 21 MR. : Oh, wow. Can you initial 21 used to be right there. It should have been 22 and date that that we're looking -- 22 right theiiiiiiiiiire the phone was. 23 MR. : Sure. Date it, too? 23 MR. : All right. So, I'm going 24 MR. : Yes, please. All right. 24 to write above it, B board. So this is where 25 So, all right. Thank you. That confirms what 25 the bulletin board was? EFTA00114437 1 2 3 4 S 6 7 8 97 MR. : Yeah. MR. : And you believe the hot list would have been on that, is what you're saying? MR. : Yes. MR. : And this was, you said ] tier? MR. : That was, those are the 1 2 3 4 S 6 7 8 98 MR. : Yes. MR. : All right. So that's all accurate? MR. : Yep. MR. : Perfect. Okay. So, you said that this one also checked out, this looks exactly the same as where you were. Oh, do you know where ['stein was located? 9 10 steps gm.. tier. MR. : So I'm going to write ) 9 10 MR. MR. : He was on L tier. : And do you know where, 11 right here with an arrow going up. 11 like, in lookin' at this, where his -- 12 MR. : Uh-huh. And K tier would be 12 MR. : It should be right there. 13 the one goini down. 13 MR. . That one? Can you put a, 14 MR. : And is that going down 14 I don't know, a box in there, I guess, and put, 15 here? 15 yeah, JE or something there? 16 MR. : Yeah. 16 MR. : )E. 17 MR. : Or over that way? 17 MR. : Perfect. Thanks. 18 MR. : No. Down that way. There, 18 MR. : His cell could look right 19 to the left. 19 down onto the OIC desk. If he looked outside 20 MR. : Okay. But ) was going 20 his window -- 21 up? 21 MR. : So he could see? 22 MR. Yes. : 22 MR. : -- he could look right down 23 MR. : All right. And then I'm 23 at the officers. 24 going to write up here, L tier would have been 24 MR. : Okay. And you already 25 right here, going up? 25 initialed and dated this. Great. So, if 99 100 1 2 you're looking at this photo, is this a photo of L tier oin up? 1 2 to be reciiiiiiieverything going on here? MR. : That's supposed to be 3 MR. : Yep. 3 recording everything, facing this way. So, 4 MR. : And would he be over 4 like, it would see you walk, it would see, if S here? S this is me, first person, coming up this way, 6 MR. : He would be the first cell, 6 it would film everything from the grill back to 7 right, in this corner most, right here, is the 7 where it is. 8 shower. But right next to the shower is the 8 MR. : And is this where the 9 first cell. 9 round sheet is supposed to be located? 10 MR. : So if you're walking up 10 : MR. Yes. 11 the tier, you open the door, he's right to the 11 MR. : Is there, do you even see 12 right? 12 anything, where it could be? 13 MR. : He's going to be the first 13 MR. : It might be that speck 14 cell to the right. 14 right, no, that's too high. It might be, there 15 MR. : The first cell to the 15 might be a little hole, I can't tell. 16 right. Okay. And I know you can't really make 16 MR. : But that's where it's 17 out this. Do you have any reason to believe 17 supposed to be located? 18 that wouldn't be his cell? 18 MR. : Yeah. At the end of the -- 19 MR. : Well, I can't even make out 19 MR. : Right underneath the 20 the number. 20 camera? 21 MR. : Right. And then, you 21 MR. : No. I'm sorry. They had 22 know, this is the tier. This is L tier, going 22 gotten moved. I believe that right now, 23 down. Is this a camera, right here? 23 they're down there, but they might, I think 24 MR. : Yes. 24 they were on the wall here, at the beginning of 25 MR. : Is this camera supposed 25 the tier or on the other side. I'm not 100% EFTA00114438 101 102 1 certain. 1 it needed to be downrange. 2 MR. : Okay. So, back then, 2 MR. : So, even at that time, it 3 they wouldn't have been at the end of the hall? 3 was supposed to be downrange? 4 They were probably at the beginning of the 4 MR. : They always have to be S tier? S downrange. 6 MR. : I know at one point in time, 6 MR. : Okay. 7 they were, the clipboard was being rested on 7 MR. : Yes. 8 that coax ii 8 MR. : Per BOP policy? 9 MR. : Would this be underneath 9 MR. : Yes. 10 L tier, or would that be where it would be? 10 MR. : Okay. And this is just, 11 MR. : No. It's always on the 11 so, we had to review a lot of emails and I see, 12 inside of the range. 12 this one, I think, was directed to you. It 13 MR. : Always on the inside? 13 says, "BOP official legal hold notice for 14 Okay. 14 inmate's death." What was your, was your 15 MR. : Yeah. 15 understanding of that not to destroy any 16 MR. : So it would have been 16 documents? 17 after you opened the range door, but not at the 17 MR. : Yes. 18 end of the hall at that time? 18 MR. : All right. Did you 19 MR. : I know I, like I said, at 19 destroy an documents? 20 one point, they had it on the wall to the side, 20 MR. : No. Not at all. 21 but at one point in time, they were putting the 21 MR. : So you still have all 22 clipboard, they were just resting it on that 22 your emails from then and everything? 23 pipe. 23 MR. : I don't have anything. 24 MR. : Okay. 24 Like, I know the AUSA had my memo. I don't 25 MR. : As long as it was downrange, 25 even have a copy of my memo. 103 104 1 MR. Okay. 1 MR. : What do you mean? In, like, 2 MR. And I don't, I didn't tear : 2 as far as from staff? 3 up anythin'. 3 MR. : Yeah, like, for instance, 4 MR. : Perfect. 4 this is another one that, I think this is the S MR. : And I've been getting these S email that you would have received, regarding 6 periodically from iou guys. 6 Epstein being required to have a cellmate from 7 MR. : Oh, you still do? Okay. 7 July 30, 2019? 8 MR. : Yeah. 8 MR. : Oh, yeah, yeah. No, these, 9 MR. : Do you still have, like, 9 I would get them and delete them. 10 all the emails from back then and everything? 10 MR. : All right. So you would 11 MR. : No. I mean, anything that I 11 delete those? 12 had, I either just closed out of, but the thing 12 MR. : Yeah. And as long as I 13 is, I didn't, I don't even remember having any 13 knew, you know, that was it. 14 direct emails. All the official emails, like, 14 MR. : So, you didn't 15 I, like, sent them to my trash bin, like even 15 understand, like, this to mean, like, not to 16 these, I mean, this was just telling me not to 16 delete an thin to Epstein? 17 destroy anything, and I didn't destroy 17 MR. : No, but the thing is, at 18 anything. 18 least I never got anything like this, after it 19 MR. : Okay. 19 happened. 20 MR. : So, I didn't save these. 20 MR. : Yeah, yeah, yeah. I'm 21 MR. : Okay. But as far as, so, 21 talking about, like, prior to, I think that 22 did you understand, like, as far as if you 22 this is asking you to save anything that was 23 received an email pertaining to Epstein, were 23 related tiiiiiiiin, correct? 24 you supposed to save that, or could have you 24 MR. : Yeah, no. I get what that, 25 deleted that? 25 you know, that, I didn't think that that was EFTA00114439 1 2 3 4 S 6 7 8 105 what it meant. Like these. These were just routine thin's. I thought it meant -- MR. : Okay. Well, that came from yours. So, you didn't, I was able to get it, at least. MR. : Okay. MR. : You may have deleted it, but my point being is, like -- 1 2 3 4 S 6 7 8 106 MR. : Cause, like, for instance, this says, "Please preserve all electronic files; example, emails or documents." MR. : Right. I missed, I totally misunderstood. MR. : All right. So, you misunderstood that? 9 MR. : Uh-huh. Well, I 9 MR. : Yeah. 10 misunderstood, maybe. I'm thinking destroying 10 MR. : Okay. 11 means shreddin.. 11 MR. : I wouldn't do it 12 MR. : But if you received an 12 malicious) . 13 email pertaining to Epstein, you thought you 13 MR. : Yeah, yeah, yeah. No, 14 could delete it? 14 and that's what I wanted to know -- 15 MR. : Yeah. I guess so. 15 : MR. Uh-huh. 16 MR. : Right. Fair enough. 16 MR. : -- cause a lot of people 17 MR. : There's, like, stuff like 17 got this, so you're the first person I'm even 18 this, if it's sitting in my trash bin. I don't 18 asking about this. 19 always empty my trash. I mean, anybody in the 19 MR. : Uh-huh. 20 Bureau could lull those emails anyway. 20 MR. : So I was just curious, 21 MR. : Okay. Let me see how -- 21 it's like, what is your understanding. So, did 22 MR. : Yeah, I thought it meant, 22 you not know -- 23 like, physically, like, destroying stuff. 23 MR. : Yeah. I thought it meant, 24 Like, I wish I could even have a copy of my 24 actually, like, physically, like, destroying 25 memo, but AUSA has it. 25 things, like, you know, in the shredder. 107 108 1 MR. : Right. All right. So, 1 MR. : Saying that he was 2 yeah. So you didn't actually read it, I'm 2 required to have a cellmate? 3 assuming, like, where it says emails? That's 3 MR. : Have a cellmate. 4 the first thin says. 4 MR. : So you do remember that? S MR. : I probably mis, no, like, I S Okay, great. 6 remember the first one I received, I called the 6 MR. : Uh-huh. 7 staff attorney. I was, like, what does this 7 MR. : And you knew he was 8 mean? And he was like, just that you're still, 8 required to have a cellmate? 9 it's still active. 9 MR. : Yes. 10 MR. : Okay. Would you mind, 10 MR. : Do you mind just 11 just, anything we talk to you, it's just 11 initialin and dating that? 12 initialin• and dating. 12 MR. : Sure. 13 MR. : Yeah. No problem. 13 MR. Was that the same email that 14 MR. : It's just to say what it 14 you mentioned before? Cause you mentioned that 15 is what we looked at and talked about. 15 there was an email from Captain . 16 MR. : Uh-huh. 16 MR. : I believe there was one, as 17 MR. : And you already 17 far as when he, anytime he would be put as a 18 mentioned, you remember receiving this email 18 lieutenant hold. This is the one I was talking 19 from Psycholo -- 19 about, like, Psychology would send out that, 20 MR. : Yeah. 20 about havin' the cellmate. 21 MR. : from , 21 MR. : Oh. 22 . 22 MR. : Thank you, sir. Now, as 23 MR. : Yeah. Dr. . 23 far as this, you said no one told you. So 24 MR. : Yeah. 24 this is a memo from, at the time, SOS . 25 MR. : Yeah. 25 MR. : Uh-huh. EFTA00114440 109 1 MR. It 2 says, "Past information from Special Housing 3 Unit." It says, "On Friday, AuggI2s_019, at 4 approximately 1:50 p.m., I, SOS IIIIIIII, S passed on to oncoming staff member, Officer 6 andiiiiient shift staff. SOS and , that inmate was going WAB 7 Officer 8 and possibly may not return. Also that inmate 9 Epstein will be needing a cellmate upon arrival 10 from his attorney visit." Did you know 11 anything about that? 12 MR. 13 MR. : Is this the first you're 14 seeing of this memo? 15 MR. : That's the first I'm seeing 16 of it. 17 MR. : All right. So, a couple 18 things. First, if passed on to these 19 people and those are the people that worked on 20 your shift? 21 MR. : Yeah. Yes. Right here. 22 . No, wait. What does it say? No, 23 was day shift. was day shift. is the onl one. 25 MR. 24 : Okay. So, oncoming staff 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 110 members , and Officer , so let's see. When would have been working on this, like what -- MR. : 2 to 10. MR. : So, would have been 2 to 10. MR. Uh-huh. MR. : And the present ones were . When would he have been working? MR. 8 to 4. MR. And MR. : 8 to 4. MR. All right. So, I think would have only been working as -- MR. : Till 2:00. MR. : 2:00. So, if he told, before he left, 2:00, , and 7 MR. MR. Right. Should any of those people have notified either you or , that he was, that Reyes was gone and -- MR. : Yes. MR. Yes? Okay. And nobody did? 111 1 MR. : I wasn't told. Like I said, 2 I found out the day after it happened. Well, 3 the day that it ha pened, when I came in. 4 MR. : Now, on the second note S of this, if knew that Reyes was WAR, 6 should have he ensured that he got a cellmate 7 prior to his departure, at 1:50 p.m.? So, if 8 Reyes left at 8:38 a.m., WAR, into III, he's 9 keyed out of the system. Should a new cellmate 10 have been assigned to Epstein, even prior to 11 12 MR. : It would have been prudent 13 to do it as soon as possible. 14 MR. : Okay. So, should 15 have then notified any, you know, 16 , and it looks like IIIII, during his 17 shift, that, hey, we need to get Epstein a new 18 cellmate? 19 MR. : Anybody that was on that, 20 that is mentioned there, should have been, if 21 the knowledge got passed, it was never passed 22 to the lieutenants. 23 MR. : Okay. But, okay. And 24 then if the lieutenants knew, so, for instance, 25 and , if told them, hey, 112 1 Reyes is gone, should have he notified them 2 that he was WAB gone? Or, so, if he believed 3 he was at court WAB -- 4 MR. : Uh-huh. 5 MR. -- and let's say, for 6 instance, is the Ops, so he's kind of 7 like the boss, right? 8 MR. : Uh-huh. 9 MR. : If knew, yep, I 10 know Reyes is gone. I know he is Epstein's 11 cellmate. Is there any reason, and especially 12 if he went WAB is there any reason, any 13 argument for IIIII to be made that, well, I 14 didn't know if he was coming back or not? 15 MR. : If he wasn't notified that 16 he was WAILit_wcald, you wouldn't know. 17 MR. IIIIIIIIII: Okay. So, if he wasn't, 18 if he didn't know he was WAR, it is an argument 19 to be made to say, well, he could have come 20 back, is that correct? 21 MR. Yes. M 22 MR. : Okay. So, he would have 23 had to have knovm that he was WAB? 24 MR. : If he didn't, he would have 25 had to have known he was WAR, if he knew he EFTA00114441 113 114 1 wasn't coming home, like, coming home, coming 1 he was alone, but you're talking day watch, 2 back to the ail. 2 there's constant movement. 3 MR. : Okay. All right. If he 3 MR. : Well, if Epstein's down 4 5 knew he was WAR, he should have acted and gotten him a new cellmate. If he didn't know 4 S in attorniiiiiiits until 8 p.m. -- MR. : Yeah. That's probably what 6 he was WAR, then it was okay for him not to 6 happened. 7 issue him a new cellmate? 7 MR. : Yeah. 8 MR. : Yeah. If he didn't know he 8 MR. : He's in attorney conference, 9 wasn't coming back or if he was even gone, he 9 thinking by the time he goes back upstairs, 10 wouldn't know. That's why I said, if the white 10 this guy is comini back from court. 11 shirts didn't get notified, we don't know 11 MR. : Okay. 12 what's hapier . 12 MR. : I'm assuming. 13 MR. IIIIIIIIII: Yeah, yeah. Ltiou had, 13 MR. : And what time did 14 so, let me ask you separately. If IIIII says, 14 work until until that day? 15 yep, I knew Reyes was, I knew Reyes was gone. 15 MR. : I relieved him at just about 16 I knew Reyes was Epstein's cellmate. And he 16 probably 2:00. 17 didn't know he was WAB. Was it okay for him 17 MR. : Okay. So, if he is 18 not to have acted? 18 saying, I knew was gone, but I didn't 19 MR. : No. If he was told, it was 19 know he wasn't coming back, would that 20 not okay. 20 translate to mean he didn't know he was WAB? 21 MR. : But if he wasn't told 21 MR. : Yes. 22 that he was WAR, he was just told he went to 22 MR. : Okay. So, if he didn't 23 court. 23 know he was WAR, was it okay for not to 24 MR. : I mean, at that point in 24 tell you that Reyes was gone? 25 time, I would have been a little worried that 25 MR. : If he didn't think that 115 116 1 there was an issue, no. 1 MR. : He says he knew he went 2 MR. : Should have he told you 2 to court. He just didn't know that he wasn't 3 that there was gone, being that it was Epstein, 3 coming back. 4 he was required to have a cellmate, and Reyes 4 MR. : That's different. If he S was at court? S knew, if he said he knew, then something should 6 MR. : If he knew, then he should 6 have happened. 7 have notified me. 7 MR. : So, if he knew he went to 8 MR. : So, regardless if he was 8 court, even if he says, I didn't know if he 9 WAR or not, he should have notified you that 9 wasn't coming back or not, he should have at 10 was at least at court? 10 least notified you, though, hey, heads-up, 11 MR. : At that point in time, so, 11 Reyes is at court? 12 see, this is where it's hard to tell. Look, 12 MR. : Uh-huh. Yeah. Or it was 13 when you're Operations Lieutenant, you're 13 just, or at least tell the OIC, like, listen, 14 moving, you're working the entire institution. 14 if Epstein comes back up and this guy is not 15 MR. : Yep. 15 back from court yet, make sure Epstein has a 16 MR. : You're filling overtime. As 16 bunkie. 17 you can see, filling that roster was a 17 MR. : Okay. 18 nightmare. 18 MR. : You know, something should 19 MR. : Uh-huh. 19 have been_p2Lin_place. 20 MR. : All right? You're doing 20 MR. IIIIIIIIII: So, should have at 21 this, you're doing that. You're doing a 21 least, should have notified either, should have 22 million things. Right? You may not even know 22 notified, it sounds like, both you, as well as, 23 that this u even went to court. 23 in this case who was the OIC at the time? 24 MR. : But if he says he knew? 24 MR. : Day watch OIC? . 25 MR. : If he says he knew -- 25 MR. : So, ? EFTA00114442 1 2 3 117 MR. : SHU-1 is OIC. MR. : Oka . So, but even though , so was the OIC, 1 2 3 118 MR. : That make sure that if Epstein, when Epstein comes back from legal visit, he 'ets a bunkie. 4 though, I think, for, like, the whole is it 4 MR. • Okay. And never S always SHU-1? Cause I thought was S informed 6 just the OIC, like, in the SHU, I thought it 6 MR. No. 7 worked that like, was -- 7 MR. : Okay. And should have he 8 MR. : Whoever is assigned as SHU-1 8 informed ou? 9 is the OIC. That's the OIC position. 9 MR. : If he knew -- 10 MR. : All right. Cause my 10 MR. : If he knew that he was in 11 understanding was that at this period of time, 11 court? 12 was known as the OIC of the SHU. 12 MR. : -- that he wasn't going to 13 MR. : If he, unless he is 13 get a bunkie, I should have been told. 14 assigned, if he is assigned to SHU-1 -- 14 MR. : Great. But what I'm 15 MR. : lust SHU-1? 15 asking, sorr I think we're confusing here -- 16 MR. : -- for the quarter, then 16 MR. : If he knew that he was -- 17 you're the OIC. 17 MR. -- even if he didn't know 18 MR. : jay. So, in this case, 18 that he was, so if his argument is -- 19 rat, . So, IIIII should have notified 19 MR. : lust the fact that he was 20 M? 20 out. 21 MR. : If he knew. 21 MR. : Right. 22 MR. : If he knew that, if he 22 MR. : If he knew, yes, I should 23 knew that he was at court, but again, wasn't 23 have been told. 24 sure he wasn't coming back, what should have he 24 MR. : So, if he knew he was at 25 told ? 25 court, he should have let you know? 119 120 1 MR. : If he knew that, if he knew 1 that information to you? 2 that he was going to not have a bunkie, I 2 MR. : Yes. Especially because of 3 should have been, I should have known, being 3 the profile found. 4 that I was comin' on. 4 MR. : Okay. So, he should have S MR. • So, this is where I'm S relayed that information? 6 trying, just tr to focus on my words. 6 MR. : Yeah. 7 MR. : I'm sorry. 7 MR. : Okay. I just wanted to 8 MR. : Right non, I'm asking, if 8 get to that. Do you mind just initialing and 9 was at court, but IIIII didn't know that 9 date that? 10 he wasn't coming back. He just knew that Reyes 10 MR. : Uh-huh. 11 was at court should have he told you? 11 MR. : And he did not, correct? 12 MR. : Yes. 12 MR. : No. 13 MR. : Okay. So, regardless if 13 MR. : Thank you, sir. Do you 14 he was coming back or not, he should have 14 remember, while we're at it do you remember in 15 notified iiiiiiii 15 this case being that shift says it 16 MR. : Well, see, that's the thing. 16 ends at 2. Well, , she's on an overtime 17 We don't always, we don't know who went to 17 shift. So, she doesn't actually start until 4. 18 court until we do that roster of the movement. 18 MR. : Uh-huh. 19 MR. : But if we talk to 19 MR. : Is it okay, do you know 20 and he sa s e , I know Reyes was at court. 20 if would have had to have stayed from 2 21 MR. : Uh-huh. 21 to 4 until he was -- 22 MR. : I just didn't know if he 22 MR. : Not necessarily. As long as 23 was mint back or not. 23 there's a lieutenant on the desk. 24 MR. : Yeah. 24 MR. : Okay. So, the fact that 25 MR. • Should have he relayed 25 if you're, you know, either you or is EFTA00114443 1 2 3 4 S there, could MR. : MR. from 2 to 4 with -- MR. : 121 have ended at 2? Yes. : And there could be a gap Yeah. That was actually 1 2 3 4 S 122 MR. • Uh-huh. MR. : It's from, it says -- MR. MR. -- MR. : Yeah, he used to work here. 6 common. 6 Now he works for the U.S. Marshals. 7 MR. : Okay. 7 MR. : Okay. 8 MR. : You know. Especially when 8 MR. : Yeah. 9 we didn't have a regular lieutenant scheduled 9 MR. : And then this is the 10 for the 2 to 10 activities. 10 attachment to it. 11 MR. : Okay. So, would you 11 MR. : Uh-huh. 12 always get, as a lieutenant, especially as Ops 12 MR. : So, it says the second 13 and Activities, would you get the prisoner 13 list down was Efrain Reyes. Are you able to 14 production lists? 14 tell from this at all what it was that was 15 MR. : Yes. From . 15 going on with Efrain Reyes that day? 16 MR. : And then was that 16 MR. : Sorry. That would probably 17 something that were supposed to review? 17 be the time that he had to go down to court. 18 MR. IIIIIII: It's basically, if we needed 18 MR. : Okay. 19 it. 19 MR. : Down to III. 20 MR. : Okay. 20 MR. : Does this transfer within 21 22 MR. : Yeah. MR. : So, for instance, this 21 22 mean anyt, MR. : I'm not familiar. It 23 24 one. It shows that it was dated Thursday, August 8, 2019, prisoner production for August 23 24 doesn't s ig. our stuff. MR. : But this would have been 25 9, 2019. 25 what you got, right? This is the email that 1 123 was sent to the lieutenants? 1 124 remove? 2 MR. : Yeah. 2 MR. : No. It would, I believe it 3 MR. : I pulled this from your 3 would say SDNY or EDNY, or whatever, whatever 4 S emails. MR. : No, I got it. 4 S court he iiiiiiiiiito. MR. : So, if it was listed as 6 MR. : So, I'm just, I'm 6 pre-remove -- 7 curious, is this something that, like -- 7 MR. : Uh-huh. 8 MR. : Transfer within doesn't, it 8 MR. : -- does that assume that 9 don't jump out at me, cause I'm used to seeing, 9 he's not coming back? 10 like, pre-remove ire-hold. 10 MR. : Yes. 11 MR. : Okay. So, there's the 11 MR. : Okay. So, at 8:38 -- 12 PP38 that ou were talking about. 12 MR. : Now, that has changed 13 MR. Okay. 13 before. Like, they've been pre-removed and 14 MR. : It shows from 8/9/2019. 14 then come back -- 15 MR. Uh-huh. 15 MR. : Okay. 16 MR. : So that's the daily log. 16 MR. : -- because something got 17 MR. : Yeah. 17 cancelled. 18 MR. : On the third page, it 18 MR. : All right. So, is this 19 says, " ire-remove, 8:38." 19 something that you got, like, as the Ops and 20 MR. : Yes. 20 the Activities Lieutenant, are you supposed to 21 MR. : If he was just going -- 21 be kind of aware of this stuff? 22 MR. : That's the time that he was 22 MR. : Well, we would get sent 23 keyed out of the institution. 23 this, mainly, I hate to say this, there would 24 MR. : So, if he was just going 24 be sometimes issues with the officers in the 25 to court, would have he been listed to pre- 25 morning, getting the inmates out to court. EFTA00114444 125 126 1 MR. : Okay. 1 MR. : In New York? 2 MR. : And they wouldn't have the 2 MR. : Yes. I believe it's in New 3 actual court list, so if they had to call us 3 York. I'm not sure. 4 and be, like, hey, you know, U is 4 MR. : Okay. And this one is S calling for this guy and I would just bring S also dated Thursday, August 8, 2019. It says, 6 this up, and be like, yeah, he's on the list. 6 "The following prisoners are to be 7 But we wouldn't study this. We would just, we 7 transferred." Here it says, "Reyes, Efrain." 8 were included in the Marshals loop, because we 8 And his reg number. "Please schedule a 9 would be the suiervisors. 9 transfer for Friday, 8/9/2019." Do you know 10 MR. : Now, if he was actually 10 why he would be listed on this email, on August 11 being transferred to another institution -- 11 8th, as well as a prisoner production on August 12 MR. : Uh-huh. 12 8th? Is there any -- 13 MR. : -- would he be also 13 MR. : No. No. That's whatever 14 listed on the court list? 14 the Marshals were doing. 15 MR. : No, he would be on the moves 15 MR. : Have you ever seen 16 for the da . 16 something like that before? 17 MR. : All right. So, here is 17 MR. What, moving an inmate? : 18 an email from also the U.S. Marshals Service, 18 MR. : Well, so, on this, it 19 from a -- 19 says he's oin to court, right? 20 MR. : Okay. 20 MR. : Uh-huh. 21 MR. : -- subject, "Transfer of 21 MR. : But on this one, it says 22 23 Prisoners from NYM to GEO." MR. : GEO. GEO. 22 23 he's beiniiiiiiiferred. MR. : Quite honestly, it's, I know 24 MR. : What's GEO? 24 I've seen, like I said, like on the 38, I'm 25 MR. : It's the private jail. 25 just going, I'm sorry, I'm going BOP-wise. 127 128 1 MR. : And then the 38 -- 1 MR. : And do you know if this 2 MR. : On the 38, see, like, GCT 2 thing next to him would be that transfer within 3 release, full-time release, FT release, or like 3 thing? Would that be -- 4 you see here, the pre-remove status and stuff 4 MR. : I don't know. Honestly, I S like that. 5 have, I can't answer that. 6 MR. : Yeah, so that's kind of 6 MR. : Okay. 7 where we're trying to, we're trying to put 7 (Phonetic Si 01:29:42). Where's that guy? 8 these pieces together. Why would he be on an 8 Yeah, so, officer says transfer -- 9 email here, saying that prisoner schedule 9 MR. : Pre-remove. 10 report, listing him as court. Here, saying 10 MR. -- and he's pre-remove. 11 he's beini transferred, excuse me, to the GEO. 11 But these other guys don't seem to say transfer 12 MR. . GEO. 12 within. So, is this something like, if this is 13 MR. : And then on the 38, 13 being sent to the lieutenant, should you be 14 showing he's Ire-removed. 14 able to look at this and say, like, transfer 15 MR. : Yeah. I guess, I'm 15 within, that means he's out of here? 16 assuming, I could be wrong, this is just the 16 MR. : Honestly, I can't answer 17 way our computer, the way our system puts it 17 that. 18 in. Like, this right here, the FT release, 18 MR. : Okay. 19 that means this guy maxed out. He's not going 19 MR. : I have never looked, I have 20 to, like, a halfway house or anything like 20 honestly never looked at that part. 21 that. Where is it? Pre-remove means he's 21 MR. : Okay. 22 being transferred. 22 MR. : I have never looked at it. 23 MR. : Pre-remove means he's 23 MR. : So, when you receive 24 being transferred? 24 this, do you, as the Ops Lieutenant, Activities 25 MR. : Transferred. 25 Lieutenant, look at these things, these EFTA00114445 129 130 1 prisoner lists? 1 8:38, he is listed as pre-remove. So, we're 2 iiiiiiiion MR. : I would glance at it, and I 2 being notified that Reyes is leaving the 3 would see what it is, but I would normally, I'm 3 institution. With these notifications from the 4 not going to lie. I would put it off to the 4 U.S. Marshals Service, who should have acted? S side, because I would only really use that if S Who should have known, Reyes isn't coming back? 6 there was a problem with the officers getting 6 MR. : I mean, whoever saw it 7 the inmates to court. 7 first. 8 MR. : Okay. 8 MR. : Who, is there somebody, 9 MR. : And then, you know, 9 like, that's responsible for, like, saying, 10 calling the lieutenants over, saying, hey, I'm 10 like, alliiiiit? 11 trying to get this dude down from 7 North, and 11 MR. : Everybody in this address 12 they're not sendin' him, and then I would look. 12 box gets it from the Marshals. It goes out at 13 MR. : All right. 13 the same time. 14 MR. : I didn't look at it every 14 MR. : Sure. 15 day. 15 MR. : And that's what I mean, 16 MR. : So, the fact that these 16 there's a lot of people there. 17 are being sent to the MCC -- 17 MR. : Yeah. And that's the thing. 18 : MR. Uh-huh. 18 MR. : There's a lot of people 19 MR. : -- saying he's transfer 19 here, and there's less people on this one. 20 within here, and he's here being, you know, 20 MR. : Uh-huh. 21 this one is, the prison production list, and 21 MR. : This one, it looks like 22 this one is being the transfer order for these 22 it's, does this look, can you indicate from the 23 two people. 23 transfer email, can you tell at that time who 24 MR. : Uh-huh. 24 those people would have been? 25 MR. : And then obviously at 25 MR. : Okay. Everybody here is the 131 132 1 staff. 1 being transferred within, is it the captain 2 MR. : Okay. So, gets the 2 that should have known it? Is it, who is the 3 actual transfer notice. 3 one that should have said, like, yes, we know 4 MR. : Uh-huh. 4 he's leaving this institution. This is 5 MR. : On this prisoner S Epstein's cellmate. Who should have been able 6 production list, it looks like, you know, 6 to take action on this? 7 Efrain Reyes saying that he's leaving and it 7 MR. : I can't, I can't, I don't 8 says a transfer within. 8 know. 9 MR. : Uh-huh. 9 MR. : You don't know? 10 MR. : As does the other person 10 MR. : I don't know. I don't know 11 on this email. 11 who would have been the main person responsible 12 MR. : Yeah. 12 for it. I mean, I guess everybody, I guess 13 MR. : This -- 13 it's for everybody's eyes, but it wasn't 14 • MR. . . 14 something that routinely got utilized. 15 MR. • -- also says 15 MR. : Is this something that 16 transfer within. 16 would have been, if this is a transfer within, 17 MR. : Uh-huh. 17 this transfer notice, is this something that 18 MR. : None of the other guys 18 the SHU staff would have been notified of? 19 seem to say transfer within. They all say, 19 Saying -- 20 like, status hearing, sentencing, change of 20 MR. : No. SHU, I don't believe 21 plea. All that kind of stuff. 21 SHU -- 22 MR. : Uh-huh. 22 MR. : Cause they're not on 23 MR. : So, being that we got 23 this. 24 this going to , then we got this going to, 24 MR. : -- the COs were tagged on 25 also, custody, saying that, you know, he is 25 it. EFTA00114446 133 134 1 MR. : But I'm saying, like, as 1 institutions? 2 far as, here's the, you know, whatever -- 2 MR. : No. Everybody on the court 3 MR. : Well, the inmates, whatever 3 list, it would say exactly what they are. If 4 comes on that, whatever gets from the 4 they're on the court list, it would say, you S Marshals Service, they put out their own court S know, court. It would say, or, it would say, 6 list to the staff. 6 you know, WAB. 7 MR. : Huh. 7 MR. : Okay. 8 MR. : The officers get regular 8 MR. : So, and then they send that 9 court lists generated. So those names of those 9 out to the housin, units, including SHU. 10 inmates would get put on the court, the call 10 MR. : So,Igai if, you know, 11 out list. 11 going back to that memo, knows, it 12 MR. : Okay. 12 says, would it say WAB or court? Or both? 13 MR. : And for the court list, and 13 MR. : I believe it just says, if 14 that court list 'ets handed out in the morning. 14 it's WAB, it would say, it would say, I think 15 MR. : Okay. So, as far as 15 it says FT remove, or I'm not 100% sure. I 16 this, it looks like we know he's being 16 haven't seen one in so long. 17 transferred, and now that we're seeing that 17 MR. : Okay. All right. So 18 these two guys that were being transferred are 18 you're not exactly sure what it said, but -- 19 both listed on this prisoner schedule report as 19 MR. : No. 20 transfer within -- 20 MR. : -- it's all the same 21 MR. : Uh-huh. 21 document of the people they need to bring down 22 MR. : -- what should have 22 that morning? 23 done? Should have they, are the people that 23 MR. : Yeah, but it's, all of this 24 are listed on that court list, are they also 24 is not on that. 25 the people that are being transferred to other 25 MR. : Right. 135 136 1 MR. : It would just say the 1 have, at the very least, notified his 2 inmate's name and that he's got to be in, it 2 superiors, hey, we need to get him a new 3 says a.m. court and p.m. court, from the last 3 cellmate. Is it okay that he has wrote this 4 time I saw the actual court list. A.M. court, 4 memo, saying, I passed it on. You know, I knew S meaning he's got to be down there at 6:30 in S at 8:38 he was WAB, but I passed it on to the 2 6 the mornin once opens. 6 p.m. people, make sure he gets a cellmate? 7 MR. : Okay. 7 MR. : I don't, like, can you, I'm 8 MR. : P.M. court would be 8 sorry. 9 afternoon. 9 MR. : So, I'm just trying to 10 MR. : All right. 10 figure out who messed up here. Cause 11 MR. : And SHU gets that legal, 11 obviously, Epstein's required to have a 12 that court list, just like every other housing 12 cellmate. 13 unit. 13 MR. : Uh-huh. 14 MR. : But again, if , 14 MR. : We saw from that email. 15 for instance knows that he's the one who walks 15 We know is being transferred. We know 16 him down to III, he walks Reyes down. He knows 16 he's gone. 17 he's WAB. Again, you're saying, you know he's 17 MR. : Uh-huh. 18 WAR. He ain't coming back unless something 18 MR. : So, we know the day 19 gets cancelled. 19 before it happens there's emails that go out. 20 : MR. Uh-huh. 20 We know at 8:38, III listed him as pre-remove. 21 MR. : Like a transport gets 21 He's gone from this institution. However, 22 cancelled. 22 Epstein never 'ets a new cellmate. 23 MR. : Basically. 23 MR. : Uh-huh. 24 MR. : All right. So, it sounds 24 MR. : Somebody doesn't take 25 like is the one who actually should 25 action. So, what I'm trying to figure out is, EFTA00114447 137 138 1 who should have taken action? 1 daytime thing. 2 MR. : I mean, I don't, I can't 2 MR. : I get it. 3 make that decision. I don't know. 3 MR. : What should have 4 MR. : As the Ops Lieutenant at 4 happened? knows, WAR? S the time,Iiii figure that -- S MR. : The OIC should have notified 6 iiin't MR. : I mean, as an Ops 6 day watch Oierations. 7 Lieutenant, I should have been told by 7 MR. : Okay. So, should 8 somebody. 8 have known, he should have been, he should have 9 MR. : Right. 9 known, yes, he is WAR and he needs a new 10 MR. : I should have known about 10 cellmate. 11 it. 11 MR. : Uh-huh. 12 13 MR. : Uh-huh. All riiiiiiiind so, when is passing, would 12 13 done? MR. : Then what should have he 14 have known though, if he were WAB? 14 MR. : Made sure that he got a 15 MR. : I should have been notified, 15 cellmate. 16 truth be told, the way, I was brought up in 16 MR. : Should have he notified 17 this agency, I should have been notified by the 17 the captain? Or should have he just gotten him 18 OIC. 18 the cellmate? 19 MR. : Right. So, but you 19 MR. : He should have got on the, 20 weren't on the schedule? Like, in the daytime? 20 told the SHU OIC, hey, get, he needs a bunkie, 21 MR. : In the daytime, no. 21 ASAP. 22 MR. : So that's where, I'm not 22 MR. : Okay. So, it basically 23 even focusing on you. 23 falls onto the Ops Lieutenant to have, he 24 MR. : No, I get it. I get it. 24 needed to have taken that action? 25 MR. : I'm focusing on the 25 MR. : To make sure that, ensure 139 140 1 the OIC. 1 to be presented so there's no problems, like, I 2 MR. : All right. And do you 2 said, I would only really refer to that if • 3 remember, I know you said you didn't know he 3 contacted me and said, hey, LT, this guy, I'm 4 transferred, but should his, you know, should 4 waiting an hour so far for this guy. Can you S you have known by these documentations, from S get on the office? And I'd look, okay, yeah. 6 this prisoner report? 6 Hey, ]ones, inmate (Phonetic Sp. 7 MR. : If I had read that, well, 7 *01:38:11) from 7 North, you know, you got to 8 this, I don't, I have never seen this before. 8 get him to court. 9 MR. : Right. This one. 9 MR. : Okay. 10 MR. : But that? 10 MR. : He's on the court list. 11 MR. : From looking at it? 11 MR. : All right. So, and as 12 MR. : I would just, from looking 12 the court list, does the Op, like, would 13 at it -- 13 have had that court list, sayiaga_if it said 14 MR. : Would you even know? 14 WAR, would have he had that, IIIII, the Ops 15 MR. : -- I don't remember, recall 15 Lieutenant have the court list? 16 the transfer within. I would always only look 16 MR. : Yes and no. Sometimes, the 17 at the names. And know that they have to be 17 internal would drop a copy of the court list 18 generated for a court list. 18 off to the lieutenant's office. Mainly, the 19 MR. : Okay. So you just know 19 main people that need it was internal, and the 20 these people are going to court? You don't 20 housing units. 21 even know that the transfer was (Indiscernible 21 MR. : Okay. 22 23 01:37:52 the MR. : I don't always know, off the 22 23 MR. MR. : And SHU. : All right. So, the Ops 24 top of my head, like, this guy is going here, 24 Lieutenant isn't actually provided a copy of 25 this guy is going there. I just know they have 25 the court list? EFTA00114448 141 142 1 MR. : It's not required. 1 MR. : Thank you. Thank you. 2 MR. : All right. Okay. Do you 2 MR. : This too? 3 mind just initialing and dating these? 3 MR. : Yes, please. The other 4 (Indiscernible *01:38:54). 4 way, you can keep them in order. Thank you. S MR. : While you do that, the S MR. : These too? 6 transfer email, the one that you signed, who 6 MR. : We're going to keep them, 7 was that from? 7 just so if we have to refer to them. 8 MR. : It's from . 8 MR. : Okay. 9 MR. : And you mentioned before, 9 MR. : That's easier. All 10 used to work here? 10 right. So, what time is the daily activities 11 MR. : Yeah. He used to be BOP. 11 report and the lieutenant's log usually sent 12 MR. : lust to clarify. Was he 12 out in the mornings for the day before? 13 working here during this Epstein time 13 MR. : It's done on the morning 14 (Indiscernible *01:39:07). 14 shift. 15 MR. : No, he was already gone. 15 MR. : So is it always supposed 16 MR. : Okay. 16 to be done before 6 a.m.? 17 MR. : He's from the Marshals 17 MR. : Yeah. As the morning watch 18 Service. The Marshals Service. 18 lieutenant, I have to make sure that before my 19 MR. : But before, he said he was 19 shift is done, I send out the whole thing, and 20 working here, and now he's, I just want to 20 that's the roster, cause if you look at the 21 clarify for the record. 21 back, the last person to sign it is the evening 22 MR. : No, he was -- 22 watch lieutenant. 23 MR. : Gone at that point? 23 MR. : Okay. 24 MR. : -- gone long before that 24 MR. : I now, as the morning watch 25 happened. 25 lieutenant, you know, the 10 to 6 or 12 to 8, 143 144 1 whichever it is, this, I have to print out the 1 9:26 a.m. Do you know why, any reason, why 2 daily log, the three daily logs from the 2 that could have happened, if, if (Indiscernible 3 midnight to 8, prior, the day shift, and the 3 *01:41:21 4 evening watch and there's a thing that, and it 4 MR. IIIIIII: You know what? It might S gets emailed to the exec staff, the captain, S have been because she didn't go home at the end 6 and I believe it used to get emailed to the 6 of her shift because that kicked off. 7 executive assistant, if I'm not mistaken. 7 MR. : But if that didn't kick 8 MR. : Okay. 8 off until 6:33 a.m. -- 9 MR. : There was a certain amount 9 MR. Uh-huh. : 10 of people on the thing. 10 MR. : -- her shift, she says 11 MR. : But is it supposed to be 11 she, the 'erson relieved her by 6 a.m. -- 12 done, basically, the morning, the morning watch 12 MR. 5:30. 13 shift ends at 6 a.m., correct? 13 MR. -- at 5, so somewhere 14 : MR. Yes. 14 between 5:30 a.m. and 6 a.m. -- 15 MR. : So it's supposed to be, 15 : MR. Uh-huh. 16 like, sent out before 6 a.m.? 16 MR. : -- is there a reason why 17 MR. : Yes. 17 she wouldn't have sent it out before her shift 18 MR. : All right. So, I have 18 ended? 19 these emails from Tuesday, August 6, 2019. 19 MR. : I don't know. 20 This one was sent at 5:16 a.m. The next one 20 MR. : You don't know? 21 from August 7th was sent at 5:03 a.m. For some 21 MR. : No, I don't know. 22 reason, I wasn't able to look at Thursday, but 22 MR. : All right. And then the 23 Friday, August 9th, was sent out at 5:11 a.m. 23 next day, though, the next couple of days, 24 And then Saturday, August 10, 2019, it wasn't 24 Sunday, August 11th, it actually doesn't, isn't 25 sent out until almost, it says almost 9:30 a.m. 25 sent out until 6:15 a.m., and then the day EFTA00114449 145 1 after that, August 12th, it actually isn't sent 2 out until 6:36 a.m. 3 MR. : Yeah. It all depends on, 4 like, what, like I said, I mean, that's a S different story. That was an emergency 6 situation, but there's things, other things 7 that happen. You get tied up. You got to get 8 pulled, you know, got to o the captain. 9 You got to go, you're in III, dealing with 10 something, and then you don't get to close out. 11 Especially if you're doing a double, too. 12 MR. : Okay. So, in this case, 13 though, in these cases, like, for the morning 14 watch Ops Lieutenant, do they sometimes get 15 relieved and that's when they work on, oh, I 16 got to get all the, I got to get the activity, 17 or I got to get the daily log and lieutenant's 18 log up-to-date now? 19 MR. : Uh-huh. 20 MR. : And then stay behind to 21 do that? 22 MR. : As far as, well, after 23 you're relieved? 24 MR. : Yep. 25 MR. : It does happen. 146 1 MR. : Right. 2 MR. IIIIIII!IlYou know, you can't, the 3 bottom line is, as a lieutenant, you should not 4 be leaviniiiiiiiiiiing stuff incomplete. S MR. : Okay. And it's that Ops 6 Lieutenant's responsibility to complete it? 7 MR. LYes. 8 MR. : And then once it's 9 completed, are they then supposed to send out, 10 send it out to everybody? 11 MR. : Yes. The morning watch 12 Operations Lieutenant -- 13 MR. : Right. 14 MR. is the one that sends out 15 the paperwork. The daily paperwork. 16 MR. : All right. So, the fact 17 that, if something wasn't sent out before 9:30, 18 does that indicate to you, you know, you, well, 19 it's because she hadn't finished it yet, so she 20 stayed behind in order to finish it? 21 MR. : That definitely could be the 22 case. 23 MR. : Okay. Do you mind just 24 initialing_ag_gating that? 25 MR. IIIIIII: Sure. 147 1 MR. : All right. Thank you. 2 Now, here is the one that we were just talking 3 about, that sent out on 4 Saturday, August 10, 2019, at 9:26 a.m. As S you'll see, this is August 10th. So I just want 6 to draw your attention to a few things. 7 Friday, August 9th, that starts at 12 a.m., then 8 we get to 8:30 a.m. On this daily activities 9 log, it shows at 8:38 a.m., Reyes, from the 10 SHU, or from Z06-220 UAD to pre-remove. Who 11 would have filled that out? Do you know? 12 MR. : The Operations Lieutenant. 13 MR. : At the time? 14 MR. Yeah. Day watch operations. 15 MR. : All right. So, is it III 16 should have called and told the Operations 17 Lieutenant, hey, this person is pre-removed and 18 that's how, how would they get that 19 information? 20 MR. : No, well, normally, we would 21 do a 38. 22 MR. : Okay. So, as in, that, 23 he would have been entered in the system at 24 that timeigi g remove? 25 MR. : Uh-huh. That would, yeah, 148 1 and then, cause as the inmates leave the 2 institutioa_Itii_bas to get updated. 3 MR. IIIIIIIIII: But wouldn't, I mean, we 4 do have the 38 that I showed you at 8:38, but S would this be II doing that, or the Operations 6 Lieutenant? 7 MR. : No. The day watch 8 Operations Lieutenant would print out a 38. 9 MR. Okay. 10 MR. To do this. To be able to 11 do this. 12 MR. : Okay. 13 MR. : Basically, we would read off 14 of that. 15 MR. : So, would only, so, for 16 this specific thing from 8 a.m. to 4 p.m., is 17 this the responsibility of, for instance, in 18 this case. 19 MR. : Day watch o erations. Yes. 20 MR. : So, would, could, 21 should, could an one after , like, you or 22 even , who sent this out -- 23 MR. : Anybody could go back in and 24 update th.lo, 25 MR. : And is that a problem, if EFTA00114450 149 150 1 they do that? 1 MR. : And then, again, if it's 2 MR. : I don't know. I guess now 2 listed as pre-removed, would they have known, 3 it is, but I don't -- 3 hey, Reyeiliiiiine? He's not coming back. 4 MR. : No, no, no. I'm not, I 4 MR. : That should be an indicator, S don't know that it's a problem or not. S yes. 6 MR. : No, we, we, we, it's common 6 MR. : Okay. And again, that 7 practice. It's like, if, you know, we could go 7 would have been , so entered this 8 back and correct, cause this way, look, also, 8 and it actually says, pre-remove. Hey, Reyes 9 if an incident happened on day watch, I'm not 9 is gone. Epstein needs a new roommate or 10 talking about this incident. If, let's say, 10 cellmate? 11 there was a use of force. 11 MR. : Uh-huh. 12 MR. : Uh-huh. 12 MR. : All right. Do you 13 MR. : And that day watch 13 remember anything regardin I know this is at 14 lieutenant is running the use of force team, 14 3:15 p.m., but it says, " , placed 15 the oncoming lieutenant could, like, update the 15 on dry cell from ZA." Do you remember anything 16 log, so that lieutenant could finish what, you 16 involving that? 17 know, he or she was doing with the move. 17 MR. : I do not. I don't recall. 18 MR. : Okay. But in this case, 18 MR. : All right. I'll show you 19 at 8:38, now, he's listed as pre-removed right 19 some emails later. But, this, again, do you 20 here. 20 believe that would have been the Ops Lieutenant 21 MR. : Uh-huh. 21 that would have entered that? 22 MR. : Who do you believe would 22 MR. : Yes. Only a lieutenant is 23 have entered that? 23 doing this lo'. 24 MR. : It should, in my opinion, it 24 MR. : Okay. 25 would be the day watch Operations Lieutenant. 25 MR. : That's the lieutenant's log. 151 152 1 MR. : So, if someone after this 1 got to go run the team. Can you just finish my 2 shift did this, would they have to, like, is 2 log? That kind of thing. 3 there a way to just kind of enter a line in 3 MR. : Okay. 4 here to do, you know, extra? How would they 4 MR. : You know? Not so much go S modify this? Would they have to modify S back to dot another lieutenant's I's and cross 6 everythin' or can you just enter in -- 6 another lieutenant's T's. 7 MR. : No. You could add a space. 7 MR. : Okay. 8 MR. : Add a space? 8 MR. : Just like piggyback off of 9 MR. : Add a space. 9 one another. 10 MR. : And then do 10 MR. : Okay. 11 (Indiscernible *01:46:31). 11 MR. : And I'm sorry, I have to 12 MR. : And then just enter the time 12 keep leanins in, cause I don't have glasses. 13 and enter it then. 13 MR. : No, no, no. I'm sorry. 14 MR. : And as far as you're 14 I'm sorry. So, 3:15, there's this, and this is 15 concerned, that's actually not an issue, if 15 where the confusing part is. We're not sure 16 they go back and correct something or -- 16 who exactl so this was your shift. 17 MR. : Not that they go back and 17 MR. : Uh-huh. 18 correct. If you go back and have to add, 18 MR. : So, would have this top 19 because now you're involved in the thing. 19 part been something that you would have added, 20 Like, let's say if I was coming on and you were 20 or then brought over? It does say it up here. 21 the day watch Operations Lieutenant, I was the 21 So, does this all just get transferred from 22 evening watch and I'm relieving you. 22 this space over to here? 23 MR. : Right. 23 MR. : Yes. Uh-huh. And then, 24 MR. : And you're like, hey, we got 24 anything then has to be added or added or taken 25 a use of force going on upstairs. Right? I 25 away. EFTA00114451 153 154 1 MR. : Okay. So, on this one, 1 MR. : -- until 12:35, although 2 it lip, dry cell with staff 2 he was removed at 3:15 p.m. We're going to get 3 in III." It says, "Good verbal count 3 into the counts now, but all these counts are 4 announced." Now, this is where it starts 4 off. That's not what the counts were. S getting a little tricky, because we have to -- S MR. : Uh-huh. 6 MR. : Uh-huh. Yeah. I had gone 6 MR. : The counts were actually 7 home almost at 10:00. This is where, like I 7 plus one for all of these, although they should 8 said, where the .i.gyback would be. 8 have been, these should have been the accurate 9 MR. : Yea. 9 numbers, but they weren't. 10 : MR. would go, just and 10 MR. : Huh. 11 close out, because she would be the one here, 11 MR. : It came over, on the 12 when the clear count took place. 12 counts, these are listed as 73, 73, 72, 74, 75, 13 MR. : Okay. So, this is where 13 76. 14 things get a little whacky, because we're 14 MR. : Always one more. 15 saying, it looks like somebody would have 15 MR. : Right. And it's because 16 possibly modified this, especially, see, look. 16 this was corrected to go back down to 72-5, and 17 This one is Saturday, August 10, 2019. 17 this was 73. So, I'm just trying to piece this 18 MR. : Uh-huh. 18 together. Would that be, why would have she 19 MR. : Starting at 12 a.m., 19 done that, if she has got listed that there was 20 Lieutenant . assumes duties. The SHU 20 this correction, why would have she gone back 21 says 73-5. Well, at 12 a.m., it actually came 21 and changed all that stuff? 22 over as 72-5. At 12:35 a.m., minus one SHU 22 MR. : I don't know. Maybe cause 23 correction, , dry cell. was 23 she didn't want to go back and change it. I 24 not keyed out of SHU -- 24 don't know. I can't -- 25 MR. : Uh-huh. 25 MR. : Does that make sense to 155 156 1 do that, though? 1 transpired. 2 MR. : I can't answer. 2 MR. : Uh-huh. 3 MR. : If it came over as 73-5, 3 MR. : I'm assuming maybe you 4 and this list is listed at 72-5, does that make 4 sent it to him or . So, here is one S any sense to do that? S that sent to you on Friday, August 9, 6 MR. : No, I would want to go back 6 2019, at 6:07 p.m. 7 and verify everything, because then if the 7 And this is the, you know, synopsis of 8 count is not right. I would want to ensure 8 what happened. "On August 9, 2019 at 9 that the count is right. 9 approximately 1:40 p.m., SOS , while 10 MR. : All right. So, let's go 10 assigned to the Special Housing Unit, proceeded 11 over the counts then. 11 to enter the 9 South visiting room. As I 12 MR. : I can't really answer the 12 walked towards the door I observed through the 13 question, though. I don't know why it was 13 visiting door inmate attempt to grab 14 done. 14 an unknown item from his visitor. Once inmate 15 MR. : So, here, just to close 15 reached to grab the item, I 16 the loop with , here is, so, for 16 (Indiscernible *01:50:55) the door and called 17 instance, here is a, to the lieutenants, it 17 for a lieutenant. Once I was able to enter the 18 sa s it's from (Phonetic Sp. *01:50:02) 18 visiting room, I gave inmate a direct 19 19 order to walk to the visiting room to conduct a 20 MR. : PA, physician's assistant. 20 visual search. Inmate complied and a 21 MR. : Okay. So, it says, you 21 visual search was conducted. Operations 22 know, inmate name. Here is another one that's 22 Lieutenant was contacted and inmate 23 from the captain to you, asking you to use a 23 was removed from the unit." 24 specific form. It looks like this is a 24 So, should have this been listed as 3:15 25 synopsis from on what actually, I guess, 25 p.m., or should it have been listed as 1:40 EFTA00114452 157 158 1 p.m.? Doliiiiiiow? 1 1:50 '.m. Is it, we're able to tell where 2 MR. : No, the 3:40 p.m. would be 2 was? 3 the time that he was placed on dry cell. 3 MR. : That's odd. That is very 4 MR. : Okay. 4 odd. S MR. : Would not necessarily be the S MR. : And it all makes sense 6 time of the incident. 6 that he was there at 6:07, because all these 7 MR. : All right. So, this, 7 inmates' emails are going back, you know, use 8 where he did the visual search -- 8 this one. That was at 4:38 p.m., from the 9 MR. : This is the time, this is 9 captain to you. And from the PA was the one at 10 the time of the incident. 10 3:11 i.m. So, I'm trying to figure out, why 11 MR. : -- but not the time, 11 was here at 6:07 p.m.? 12 okay. This is the time of the incident, dry 12 MR. : That's very odd. I don't 13 cell would have been a different thing. All 13 recall. I don't remember. 14 right. Do you remember, I mean, do you 14 MR. : No? 15 remember at all that incident on that day? 15 MR. : I don't recall. 16 MR. : I don't recall. It happened 16 MR. : But that would have had 17 so often, so. 17 to have been sent from in here? Especially 18 MR. : Sure. Now, would 18 from an officer right? 19 , it says that he sent you this at 6:07 19 MR. : That's, yeah. An officer 20 p.m. Would have he sent this to you from 20 doesn't have the outside email access. I 21 inside the institution? 21 didn't, as a lieutenant. 22 MR. : Yeah. It would have been 22 MR. : Right. So he was 23 24 from the comouter. Email. MR. : Okay. So, if he's not 23 24 definitel MR. here 6:07 p.m.? : If that came through at that 25 listed on anywhere. He's listed as leaving at 25 time, that's on the government computer. 159 160 1 MR. : Okay. Do you mind just 1 counted him. 2 initialin' and dating that? Sorry. 2 MR. : Okay. So, do you mind 3 MR. : No problem. 3 just initialing and dating that? Thank you, 4 MR. : All right. Now, here's 4 sir. All right. Now, we're going to go into S the inmate history move. lust to, so, again, S these, just while these lieutenant sheets are 6 close that loop. So, it shows , here 6 up, kind of go into some of these counts. All 7 are his inmate history quarters. And it shows 7 right. So, here we got the 8/9/2019, Federal, 8 -- 8 or, sorry, Bureau of Prisons count sheet. This 9 MR. : (Indiscernible *01:53:05) 9 is the E-1, correct? 10 MR. : -- that on 8/2/2019, he 10 : MR. Yes. 11 was brought to the SHU, Z, and then it shows on 11 MR. : And on the E-1, at ZA, 12 -- 12 what does the number 6 show? 13 MR. : 8/10, right next to it. 13 MR. : 77. 14 MR. : Yeah, I'm just, just give 14 MR. : All right. So, 77. 15 me a second. So, yeah, then it says that 15 Let's go back to this guy and see what the 16 8/10/2019, at 0035, that's when he was moved 16 number says. All right. So, it looks like 77. 17 over, I guess, to, what does that stand for? 17 Okay. Now, what does the /5 mean? 18 MR. : That's the cells. 18 MR. : 10 South. 19 MR. : So, RO1 is the • cells? 19 MR. : 10 South? 20 MR. : Uh-huh. 20 MR. : Wait, what, I'm sorry, what? 21 MR. : So, that's when he was 21 MR. : So, this /S? 22 keyed out of the system, at 0035. Which does 22 MR. : Yeah, that's 9 South/10 23 correspond to that, 12:35 a.m. 23 South. 24 MR. : Yeah, he was probably never 24 MR. : All right. So, on the 25 punched out, and they, somebody probably ghost- 25 daily, on the daily lieutenant's log, it shows EFTA00114453 161 162 1 77/5, and on the E-1, it shows 77 for ZA and 5 1 MR. : So, Epstein is in 2 for ZB. And we go, we look at the 2 attorney conference. We got one there. So, 3 corresponding count slip for ZB. It says S. 3 inside the SHU should be 75, correct? 4 For ZA, it sa s 77, correct? 4 MR. : Yes. S MR. : Yeah. S MR. : All right. So, for the 4 6 MR. : All right. Mind just 6 p.m. count, (Indiscernible *01:56:10) count in 7 initialing and dating that? 7 progress, it shows there should have been 75 or 8 MR. : Is that the SA one? 8 should, this said 76. What should that have 9 MR. : 5A, yeah. All right. 9 said there? 10 Thank you, sir. Okay. So, now this is where 10 MR. : If he was keyed out -- 11 we start getting a little bit into the weeds 11 MR. : So, looking at this E-1 - 12 here. So, this is the 4 p.m. count, correct, 12 - 13 on August 9, 2019? 13 MR. : The E-1 is showing that he 14 MR. : Uh-huh. 14 was in attorne conference. 15 MR. : All right. So, the E-1 15 MR. : Right. So, should this 16 shows for ZA, there is, it says for the census 16 number on the lieutenant's log have said 75 or 17 column 76, for the count, 75. And is that 17 76, based upon this? Should it have said this, 18 because one is -- 18 76 number or should it -- 19 MR. : One is keyed out, right 19 MR. : It's whatever this is. 20 here. Look. Right here, one is from attorney 20 MR. : So, this should have said 21 conference. This Atty right here? 21 75, as of this -- 22 MR. : Yep. 22 MR. : Yes. Yes. 23 MR. : Is attorney conference, so 23 MR. : All right. Now let's go 24 you had one out count and two attorney 24 look at the corresponding. ZB shows S. ZA 75. 25 conference. 25 MR. : 75. 163 164 1 MR. : All right. So, that's 1 MR. : All right. So, the 10 2 correct, then? 2 p.m. count, good verbal announced. What does 3 MR. : Yes. 3 that say? 4 MR. : Based upon that? 4 MR. : 72. S MR. : Yep. S MR. : 72, so the daily 6 MR. : All right. Do you mind 6 lieutenant's log says 72 here, but this says 7 initialing_ladating? 7 73. 8 MR. 'I'll': Just a question on that. 8 MR. Uh-huh. : 9 Keep in mind, you started off the day at 77. 9 MR. : Okay. Do you know why 10 MR. : Uh-huh. 10 that would be? 11 MR. : Efrain Reyes was removed. 11 MR. : I don't know. There might 12 MR. : We'll get into that. 12 have been somebody, math was messed up, as far 13 MR. : Okay. 74. 13 as the lieutenants. As long as this is right, 14 MR. : Yeah, I'm just, what's 14 and this jives with the officer's counting in 15 that? 15 the units, that's what matters. That means we 16 MR. : Shouldn't this be 74? 16 don't have an escape. This, you know, people, 17 MR. : I'm just, I just want to 17 I'm not the greatest mathematician in the 18 know, according to this, cause we can go back 18 world. 19 to things. 19 MR. : Okay. 20 MR. : Okay. 20 MR. : You know, you make a, what's 21 MR. : All right. So, here is 21 the word, an arithmetic mistake. 22 the 8/9/2019. It shows, this is for the 10 22 MR. : Sure, sure. Do you 23 p.m. count. So, this ZA says 73 and 73, 23 believe, though, this would have said 73, since 24 correct? 24 this over here says 73, on the next day? 25 MR. : Yes. 25 MR. : I mean, it should. If there EFTA00114454 165 166 1 was no movement. 1 pronounce that? 2 MR. : Right. 2 MR. . . • 3 MR. : Between the evening watch 3 • MR. . would have been, 4 and the mornin' watch. 4 but looking at the actual E-1, it looks like S MR. : Right. And we'll go S actually took the count? 6 through the numbers, like you were just 6 MR. : Yeah. Well, at 10:00, 7 suggesting, later. I'm just trying to 7 though, nobody is coming in or out, except 8 correlate what this says, what this says, with 8 basically whoever is on 2 to 10. 9 what this sa s. 9 MR. : Okay. 10 MR. : Uh-huh. 10 MR. : And also at 10:00, he's 11 MR. : You know, so they are 11 alone. 12 different numbers here. All right. So, the 12 MR. : Oh, he's alone? So, 13 fact that this says on it? 13 is not there? 14 : MR. Uh-huh. 14 MR. : Yeah, cause goes home 15 MR. : Would that mean that he 15 at 10:00. 16 would have been the one that actually takes the 16 MR. : All right. So, 17 count? 17 is there. Who was the one on the 4 p.m.? 18 MR. : He was the one that took the 18 MR. 19 count. 19 MR. : Okay. did the 4 20 MR. : So, even though, when we 20 p.m. Okay. So, is the one who did the 21 go back before you said that, I think you said 21 10 p.m. All right. Now we're on the same 22 that Control 1 would have been doing the keys 22 page. Now we're going to look at the 23 and all that stuff. 23 corresponding count slips. You would have been 24 MR. : Uh-huh. 24 gone by this count, correct? 25 MR. : And , did I 25 MR. : Yeah. 167 168 1 MR. : All right. So you're 1 MR. : Yeah, plus 1. 2 gone now. So here's U. We get 1. But on 2 MR. : Does that mean that that 3 the, where would it have shown on this? 3 actually should be 74, if they're saying plus 4 MR. : Wherever he was keyed out 4 1? S of. S MR. : Unless that's the plus 1, I 6 MR. : Would it have been this 6 don't know how they did the numbers. How they 7 RA? 7 did the math. 8 MR. : Yeah. It should have been 8 MR. : Okay. Have you ever seen 9 ZA. It should have been somewhere over here in 9 anything like this before? Plus is? 10 this column. 10 MR. : I've seen them ghost- 11 MR. : All ri ht. So, we got 11 counting. 12 no, we got a count slip for III 1. 12 MR. : Have you seen plus is on 13 MR. : Uh-huh. 13 our count sins? 14 MR. : But nothing on the E-1, 14 MR. : No. 15 saying there was anybody in there. And then 15 MR. : All right. What about 16 we've got ZA, 73. So, this one says 95 plus 1, 16 the fact that -- 17 on top of the 1, and then we go over to the 17 MR. : Cause honestly, in 21 years, 18 ZA count sli'. Or not, sorry. 18 this is the first time I'm seeing a plus 1 on a 19 MR. : 9 South plus 1. 19 count stk. 20 MR. : 9 South plus 1. Sorry. 20 MR. : Okay. So you have never 21 MR. : That's whys_they ghost- 21 seen a plus 1 before? 22 counted him from 9 South in III. 22 MR. No. : 23 MR. : All right. So, if you 23 MR. : What about, have you ever 24 read this, this one says, for ZA, says 73 plus 24 seen anything where every single count slip is 25 1. 25 crossed off, aside from these two? EFTA00114455 1 2 169 MR. : Yes. I don't know about these two. I know as, when you're taking the 1 2 170 anything to you, though, the fact that every one of these count slips is crossed off, aside 3 count -- 3 from , where there is no one actually on the 4 MR. : Yep. 4 E-1 -- S MR. : -- I normally, that's how we S MR. And SHU. : 6 get the clear count. 6 MR. : -- and then SHU, which 7 MR. : Sure. 7 has the 73 plus 1, on the E-1, it says 73. On 8 MR. : When we do the good verbal 8 the count slip, it says 73 plus 1, but on the 9 by, what we do is, We make one line. When the 9 daily log, it says 72. Any, does that indicate 10 unit officers call -- 10 anything to you, the fact that those aren't 11 MR. : On the E-1, right? 11 crossed out? 12 MR. : -- we make the one line on 12 MR. : The only thing that jumps 13 the E-1. Once I get all the paper, cause what 13 out at me is that it might have been somebody 14 we'll do is, like, once I have a good verbal, I 14 else that did these two count slips versus 15 do the one line and I see every unit has got a 15 these. 16 good verbal. That's when I tell Control, we 16 MR. : Like someone who was 17 got a good verbal count at whatever time. And 17 taking the count, like M.? Would 18 then we say, awaiting paper. And once internal 18 would have been the person that, like, crossed 19 brings down all the count slips, whoever that 19 these thii.a? 20 person is that's taking the count will have 20 MR. : I don't recall if he was a 21 those count slips in front. Not everybody does 21 crosser or not. 22 it. I do it. I would, I'm a crosser. And 22 MR. : But who, if it wasn't 23 what I do is I verify everything and that's 23 who would it have been? 24 when I make the E-1. 24 MR. : At that point in time, it 25 MR. : Does this suggest 25 was only him in Control. 171 172 1 MR. : All right. And it was -- 1 MR. : She did take it. This is 2 MR. : If the lieutenant was in 2 her signature. 3 there, she would. her name would be here. 3 MR. : All right. So, 4 MR. : So who would have taken 4 took the 10 '.m. count? S 6 7 8 9 over for you? You said you only worked until 10? MR. : I worked until 10. MR. : So who would have taken over at 10? S 6 7 8 9 MR. prepared the count. MR. : Okay. MR. : This is her, this is her loop in there, taking the count. MR. : All right. So, 10 MR. • relieved me that . 10 took the 10 p.m. count. Okay. And then, this 11 12 13 night. MR. : So, would have relieved iiiiii,10? 11 12 13 is where, so, can you tell from this E-1 on August 10 2019 at the 12 a.m. -- MR. IIIIIIIIiii 3, this is 3:40. 14 MR. : And then she worked until 6 14 MR. : Sorry. Oh, no, no no. 15 in the mornin.. 15 So, you're saying the 12 a.m. count, 16 MR. : Okay. So, she didn't 16 took? 17 start at 'lilt. She started at 10. Okay. 17 MR. : Yes. 18 MR. : Yeah. That's why I was 18 MR. : All right. Not the 10 19 20 21 saying the Ops Lieutenant, we used to do the two hour differences. MR. : So, is it possible that 19 20 21 p.m.? MR. : The 10 p.m., did by himself. 22 actually took this count? 22 MR. • took, so, forget . 23 24 MR. : I'm trying to, may I? MR. : Yeah. Absolutely. Are 23 24 that. MR. : I'm sorry, the time is, I 25 you able to even tell -- 25 mean. EFTA00114456 173 174 1 MR. : Yeah, absolutely. So, 1 MR. : One, yeah. 2 did the 10 p.m., the ones that have the 2 MR. : So, 72 in ZA, 1 in RA. 3 count sills with the 9 South plus 1, and the 73 3 MR. : This is, this is jiving with 4 plus 1. did the 12 a.m. count. 4 this. That's working. S MR. : 12, yeah. S MR. : Now it's working, here it 6 MR. : And the 12 a.m. count is 6 wasn't. 7 the one where it goes from the E-1 at 10 p.m., 7 MR. : From what I understand. 8 the day before, with 73, the 12 a.m. E-1, is 8 From what I'm, the way I'm reading it. 9 72, and now let's go to the corresponding count 9 MR. : Right. Have you ever 10 11 slips. ZA what's the number on that? : MR. 73. 10 11 seen anytiiiiiiike this before? MR. : I have never seen plus is 12 MR. : 73. So the count slip 12 written on the count slip. 13 says 73 for 12 a.m., but the E-1 says 72. 13 MR. : Plus, what about count 14 MR. : Yeah. 14 slips that aren't corresponding with what's -- 15 MR. : Can you think of why that 15 MR. : I have seen staff, but 16 would be? 16 normally, you have, you call that unit officer 17 MR. : Like I said, the only thing 17 and be, like, hey, I need a new count slip. 18 that comes to mind is a ghost count. 18 The count silo is wrong. That I have seen. 19 MR. : Okay. Then the RA still 19 MR. : All right. 20 says 1, though. Can you ghost count someone if 20 MR. : Plus ls, I have never seen. 21 they're ptijig_in count slips for 1? 21 I have never seen anybody write a plus 1 on a 22 MR. IIIIIII: No, cause then there would 22 count sill. 23 be, it would be off by plus 1. 23 MR. : Okay. And then 3 a.m. 24 MR. : And then now has 1 in 24 again is a Does this mean that -- 25 there, correct? 25 MR. : Cause he's alone, yeah. A 175 176 1 lieutenant to do one count on a shift. 1 73. The count slip says 73 plus 1. And then 2 MR. : Sure. And is there any 2 the 12 a.m. says 72. Count slip says 73. And 3 indication that anybody on here did anything, 3 then on the daily lieutenant's log, the guy, 4 other than 7 4 , is keyed out at 035 hours, because S MR. : No. That's his -- 5 he was ke ed into the SHU the whole time. 6 MR. : Okay. And then again, ZA 6 MR. : Uh-huh. 7 says 72, 72. Z-- 7 MR. : And then everything is, 8 MR. : ZB? 8 from that point forward, is corrected to 72. 9 MR. : ZB says 5. And RA says 1 9 So he was never present in the SHU. We have 10 and 1. 10 got the 10 p.m. and the 12 a.m. counts, we both 11 MR. : Uh-huh. 11 have count slips for, saying that he's there in 12 MR. : And again, there are the 12 RA, and somehow, their numbers, there is only 13 corresponding count slips now. The count slips 13 72 people in the SHU. So the count slips are 14 for ZA do say 72, and ZB says 5, and the RA 14 showing 73 people. There's only 72 people in 15 says 1. Same thing with the -- 15 there. The E-1 at 10 p.m. says 73, even though 16 MR. : 5 a.m. 16 there's onl 72 people in there. 17 MR. : -- the S a.m. count. 17 MR. : Two. 18 Same deal. We don't need to go into the rest 18 MR. : The E-1 at midnight does 19 of them for this. So, does this indicate to 19 show 72, but that's only because at 12:35 -- 20 you for all, does this indicate anything to you 20 MR. : It was corrected. 21 for all of this? Does it indicate that they 21 MR. : It was corrected. And 22 weren't conducting their counts at all? Let's 22 the count slip says 73, although there were 23 take this out of the picture and let's directly 23 only 72 people in there. Does that indicate to 24 focus on the E-1 and the count slips here. The 24 you that the people in the SHU were just 25 fact that at the 10 p.m. count, they're listed 25 basically going off of what the E-1 should have EFTA00114457 177 178 1 said, versus counting it themselves? 1 MR. : It's not, like, an official 2 MR. : It's possible. I mean, I 2 BOP thing. It's something that was brought, 3 know that they are charged with falsifying 3 it's like made in Word. It's basically like, 4 documents. 4 almost like a blueprint. But it's of, it will S MR. : Yep. S have the cells, and it will state what names, 6 MR. : I know they say that they 6 like, the SHU staff use it to also, when 7 did not conduct a count, so I guess so. I 7 they're doing the showers, right, they'll mark 8 guess that's what they, I don't know. 8 off who got their showers. 9 MR. : How would have they 9 MR. : Okay. 10 gotten the number 73? So, 73 is what is on the 10 MR. : And everything like that. 11 E-1. 11 MR. : Is that something that 12 MR. : Uh-huh. 12 only the SHU staff has? 13 MR. : There is only 72 people 13 MR. : That's only, that's 14 in the SHU. But they're listing 73 on the 14 upstairs. Unless -- 15 count sli 15 MR. : Does the E-1 people, does 16 MR. : It could have been easily, i 16 Control have access to that? 17 in my opinion, it could have been easily as 17 MR. : Not everybody has access to 18 they were going off of the SHU locator, and the 18 a PPE-1. 19 locator wasn't corrected. 19 MR. : So, the thing, though, 20 MR. : What's the SHU locator? 20 that, if they're using this thing that you 21 MR. : It's basically a chart with 21 just, what did ou call it again? 22 the cell assignments and the inmates names and 22 MR. : The locator. 23 numbers written in it. So, basically, you have 23 MR. : So, if they're, the SHU 24 what inmates are in where. Right? 24 staff is using a locator, does the people in 25 MR. : So, it's like a document? 25 Control have access to that locator? 179 180 1 MR. : Not to the locator, no. 1 MR. : You don't know? 2 That's a SHU thin 2 MR. : I do not know. 3 MR. : All right. And then some 3 MR. : Okay. 4 people in the SHU could have had access to, 4 MR. : Computer Services would have S what are the seople in the Control utilizing? S a record of who has access to what on Sentry. 6 MR. : Control have the E-1 access. 6 MR. : All right. Fair enough. 7 Lieutenants have an E-1 access. 7 And do you know anything about them falsifying 8 MR. : All right. 8 their counts? 9 MR. : Not everybody has full 9 MR. : I do not. 10 Sentry access. 10 MR. : No? 11 MR. : All right. So, going to 11 MR. : Like I said, I only know 12 this 10 p.m. count, do you know if so who, on 12 what I have read and what I hear. 13 the ZA count slip, it says and Noel, 13 MR. : Okay. And what have you 14 correct? 14 heard? 15 MR. : That's definitely . 15 MR. : The same thing that you, 16 Yeah, Noel, all right. I don't know what I'm 16 they're being charged with. I heard that they 17 looking at. I'm sorry. I don't have my 17 were sleeiiiiiiiiiihey didn't count and -- 18 readers. 18 MR. : Had you heard at all that 19 MR. : Sure. 19 either the 4 p.m. or the 10 p.m. counts weren't 20 MR. : N-O-E-L, yeah. 20 conducted? 21 MR. : Do you know if either of 21 MR. : No. I heard the overnight 22 these people would have had access to this E-1 22 counts. 23 data? 23 MR. : All right. So just the 24 MR. : I do not know if they had 24 midnight, 3, and 5? 25 it. 25 MR. : Yes. EFTA00114458 1 2 181 MR. : But you hadn't heard about the 4 or 10? 1 2 182 MR. : I don't know. I don't know. MR. : Would have she been 3 MR. : I was told that at 10:00, 3 authorized to do that? 4 not that I was told, from what I heard, at 4 MR. : No. I don't know. I can't 5 10:00, he was alive. S answer that 'uestion. I have, I'm not -- 6 MR. : Okay. Again, though, 6 MR. • But you had mentioned 7 going back to this lieutenant -- 7 that people can go in and (Indiscernible 8 MR. : Do you want me to sign this? 8 *02:11:57). 9 MR. : Yeah. I'm going to have 9 MR. : It can be done. You can go 10 you do that now. Going back to these 10 back and do it. 11 lieutenant logs, do you know why, how that 11 MR. : Now, should she have? 12 could be off, too, though, if the E-1 and the 12 MR. : No. Not that I know, unless 13 count slips are all saying 73 at 10 p.m., why 13 she saw that, unless she was trying to make the 14 15 would the be 72 here? MR. : Honestly, I don't know. 14 15 correction, to make sure that everything was right with the count. 16 Like I said, some people are better in math 16 MR. : And that's what I mean. 17 than others. It could be just a simple 17 MR. : Which we, you know, we all 18 arithmetic mistake. 18 try to look, you know, to better, at the end of 19 MR. : But do you think that 19 the day, remember, accountability is the most 20 being that it came over as 73 20 important thin . 21 is the one that corrected being out, 21 MR. : Yeah, yeah. 22 and then she doesn't send the activities report 22 MR. : So, we would try to make 23 daily log out until 9:30 a.m. Do you think 23 sure that it's there, and it's not to, like, 24 that she would have gone back in there and 24 cover up or anything like that, cause at this 25 maybe she just -- 25 point in time, nothing was wrong. So, you're 183 184 1 not covering up anything. And at that point in 1 But if there is, only one person can be in 2 time, once that happened in the morning, she 2 there at the time. 3 wouldn't have been able to do this anyway, 3 MR. : Right. 4 cause the FBI was already here, taking 4 MR. : If I try to go into that log S everythin S program and another lieutenant was on it, I 6 MR. : Well, if someone says i 6 wouldn't be able to. 7 that at 9:30, well, this is all, this is all 7 MR. : Right. So, if the 8 done electronically, right? She sent this out 8 captain notices that someone is in there, 9 electroniiiiiiii 9 modifying that log -- 10 MR. : You get, have to email that, i 10 : MR. Uh-huh. 11 yes. 11 MR. : -- at that time, is that 12 MR. : Right. And is it my 12 okay? 13 understanding that this is actually created in, 13 MR. : I'm sure that would bring, 14 like, a Word document, that is in a shared 14 like, flag something. The captain would be, 15 folder? 15 like, what's #oi • on? 16 MR. : It's in the shared folder. 16 MR. : Right. 17 It's in, but only lieutenants have access to 17 MR. : Yeah. 18 that. 18 MR. : But, okay. But if you 19 MR. : Right. 19 were , and you were the one 20 MR. : And the captain. 20 modifying this thing, and you are going back 21 MR. : So, if someone is in that 21 and basically, you know, changing this stuff, 22 shared folder, and they can tell, someone is 22 do you think that would be acceptable? Or 23 modifying that thing right now, and it's at, 23 should have she left it as it was and just left 24 like, 9:30. 24 her one saying 73, I corrected it, brought it 25 MR. : Oh, well, that's the thing. 25 back to 72 and left the day before, the August EFTA00114459 185 186 1 9th date alone and just stuck with August 10th? 1 (Indiscernible *02:14:29). 2 MR. : I believe so. 2 MR. : Like I said, like, for 3 MR. : You believe she should 3 instance, I go home at 10, right? She is 4 have just stuck with August 10th? 4 relieving me at 10, but there is still going to S MR. : I do my own things. S be a good verbal and a clear count after I'm 6 MR. : Right. 6 gone. 7 MR. : It's not my job to correct 7 MR. : And that's true. 8 another lieutenant. 8 MR. : But then she would have to 9 MR. : All right. And do you 9 go -- 10 believe there would be something wrong with her 10 MR. : She's actually starting 11 doing that, though? Going back to August 9th 11 on August 9th. 12 and changiiiiiiings? 12 MR. : She would have to be going 13 MR. : No. Because it was past 13 back into mine in order to put the, clear the 14 practice. 14 count, because she can't put 10:30 good verbal 15 MR. : Okay. 15 and 10:45 clear count on her log, cause it's 16 MR. : You know, it's something 16 after midnight. Does that make sense? So, she 17 that we have always done that, you know, from 17 will go, like, things like that, you piggyback. 18 the very first time. I personally don't like 18 Just like if, like, we end up, we do the two 19 correctin other eople. 19 hour relief thing, you know, you got to, you 20 MR. : All right. 20 piggyback, but otherwise, I don't go back to, 21 MR. : But you mentioned it would 21 like, correct another person. That's me, 22 have been that, if you piggyback off each 22 personall . 23 other. 23 MR. : But she did start on 24 MR. : Yeah. 24 August 9th, and what you're saying is you don't 25 MR. Something came up. She 25 find it problematic that she did correct 187 188 1 something? You don't think there's anything 1 Would that be where Epstein was housed for 2 wrong with it? You just wouldn't have done it? 2 8/9/2019, in the SHU? 3 MR. : I wouldn't have done it 3 : MR. Yes. 4 personall . 4 MR. : All right. And did you S MR. : Right. S say you had heard that these were not 6 MR. : But I don't think there's 6 conducted? 7 nothing wron' with what she did. 7 MR. : Well, like, for instance, 8 MR. : Did you want to talk 8 case in point, I don't know who this is, but I 9 about these an more, about the lieutenant logs? 9 wouldn't have, when I made rounds, unless he 10 MR. : No. We covered it. 10 made rounds around this time, or prior to this 11 MR. : All right. Okay. 11 time, these were never finished. 12 MR. : I don't know if there is a 12 MR. : Okay. So, this person, 13 certain order I'm supposed to -- 13 if you didn't go do the round, who, do you 14 MR. : No, yeah, I just keep it, 14 believe, would have gone in and actually signed 15 I kept them in order. They're all in order of 15 off on that? 16 the counts. Thank you for initialing and 16 MR. : It would be the either/or. 17 signing everything. And we had to go past 17 I don't reco'nize -- 18 that, so, this would be, thank you, sir. 18 MR. : Does that look like -- 19 MR. : You're welcome. 19 MR. : I know this is me. 20 MR. : This is the last thing we 20 MR. : Okay. So, you actually 21 have got. All right. So, we have only got two 21 did a round in there? 22 more documents or something. So, these are 22 MR. : I did the rounds somewhere, 23 the, what are these? 23 no, wait a minute, is this me? 24 MR. : These are the round sheets. 24 MR. : I thought you said 25 MR. : So, is this L tier? 25 did the round. EFTA00114460 189 190 1 MR. .• did make the round in 1 know I didn't make rounds up there, but that 2 SHU. I don't know why I'm, I don't know why my 2 looks like my . And this is the first I'm 3 signature is on here. 3 seeing this. 4 MR. : That is your signature, 4 MR. : Yeah. It does look S though? S exactly like what you have been doing. I 6 MR. : It looks like my I. But I 6 didn't even notice that before. So, this is 7 didn't make rounds in SHU. I know that. I 7 your signature on the 8/9/2019 -- 8 didn't make the evening watch rounds. 8 MR. : Uh-huh. 9 MR. : Shoot. I didn't print 9 MR. : -- 30 minute check sheet, 10 off the list for the lieutenants, cause 10 but you did not visit the SHU on August 9th? 11 there's, but that is your signature on there? 11 MR. : No. I did not make rounds. 12 MR. : That looks like my I. 12 My Activities Lieutenant made rounds that 13 MR. : And would have you had to 13 night. 14 have gone to the actual SHU to do that? 14 MR. : Would it have anything to 15 MR. : Yes, I would have had to 15 do with the fact that she was an Acting 16 have, and I didn't make rounds up there that 16 Activities Lieutenant? 17 night. 17 MR. : I mean, no, because I don't 18 MR. : Any idea how that would 18 remember, I don't recall signing the round 19 have gotten on there, if you didn't, you 19 sheet for that shift. 20 weren't in there? 20 MR. : Cause it looks like all 21 MR. : No. No. I don't. 21 of, it looks like all of them are you, right? 22 MR. : Do you know if anyone 22 MR. : Well, some, one thing right 23 asked you after the fact to sign off on 23 here, too. it's not signed off on here, either. 24 something? 24 MR. : So the bottom aren't 25 MR. : Not necessarily. No. But I 25 signed off on. Well, who -- 191 192 1 MR. : The morning watch went, upon 1 my signature. I didn't make rounds. The only 2 coming in, oh, you know what? I'm 2 thing I could, I could assume is maybe 3 not, I don't remember doing it, but the only 3 asked me to sign because she made the round, 4 thing I could think of is when it gets picked 4 but she is not an actual lieutenant. But I S up, but the thing is, this don't get picked up, S don't recall. 6 it don't get sent down until morning watch. 6 MR. : But would have she had, 7 So, I don't, I don't remember, I really don't 7 like, literally have been allowed to bring, 8 remember signing that. But I really don't 8 take the -- 9 remember signing that, and it looks like the 9 MR. : No. No. That's the thing. 10 morning watch lieutenant didn't sign, either. 10 They can't leave the unit until morning watch. 11 Cause then if you look at this, I wouldn't have 11 This gets sent down for the morning watch. 12 signed, if I saw rounds not done. Remember, I 12 MR. : All right. 13 said that earlier. 13 MR. : Like, when came in 14 MR. : So does this at all look 14 for Saturday morning watch -- 15 like it could have been, like, cut and paste or 15 MR. : Uh-huh. 16 why, why would that be modified? 16 MR. : -- this, after midnight, 17 MR. : I don't know. 17 between 11:30 and 12 is the last round for the 18 MR. : Do you have any reason to 18 evening shift. Then this gets sent out. 19 believe that that is not your signature? 19 That's why I'm looking at this, look, it's on 20 MR. : I don't recall signing it, 20 this one. It's on this one, but where is it 21 but that looks like my •. I always initial. 21 here? It's not here. It's not here. So, 22 I don't ever fully sign. I always do the I, 22 what, was one tier, two tiers done and not the 23 as you can see, I do the in the circle. 23 other? There's six tiers up there. 24 Yeah. Yeah, I don't, I don't know. I don't 24 MR. : And they're all for 25 recall. I don't recall signing it, but that is 25 8/9/2019? So, we got some kind of discrepancy EFTA00114461 193 194 1 going on with these. 1 MR. : That's 10 South. 2 MR. : I don't remember signing 2 MR. : But 10 South, you got to 3 that. 3 go through the SHU to get to 10 South. 4 MR. Indiscernible *02:21:12). 4 MR. : Yes. S MR. : And you would, you would S MR. : Who is that person? 6 have signed it before 10 p.m.? Before you 6 MR. : I'm not sure. I don't know. 7 left? 7 I don't recognize it. It could be 8 MR. : Yeah. Before I left. 8 It looks like an and something else. 9 MR. : So you don't remember 9 MR. : So, do you believe that 10 ever vision SHU? 10 in some way, then, do you believe that you did 11 MR. : I might have been up in the 11 not sign the 8 9/2019 count sheet? 12 SHU, like, to move an inmate or whatever have 12 MR. : I don't remember signing it. 13 you, or like, to lock somebody up, but I don't 13 MR. : Right. Right. 14 even remember if I did or not, honestly. I 14 MR. : I could have very well -- 15 don't remember. 15 MR. : I guess what I'm asking 16 MR. : Do you believe that you 16 is, like, do we now have to look into, oh, 17 didn't? 17 crap, this stuff might have been, like, copied 18 MR. : I don't remember signing it. 18 and pasted and 'ut onto something else? 19 MR. : Okay. 19 MR. : I don't know. Well, 20 MR. : I do not remember signing 20 actually, I don't know. I can't answer that 21 the round sheet and I know made rounds 21 question. I just don't, I do not, I can tell 22 that night. 22 you I do not remember signing it, but I do 23 MR. : So, what, I guess what 23 remember, I did not make rounds in SHU. I 24 25 I'm asking is, what is this? So, this one still says 8/9, but for ZB -- 24 25 don't remember it. I don't. MR. : All right. 195 196 1 MR. : But that is, I can't, that's 1 MR. : Huh-uh. But I didn't, I 2 my I. 2 wasn't there. I didn't make the round in SHU. 3 MR. : All right. So, your 3 MR. : Why do you clearly remember 4 signature is on these, but you don't recall 4 that you didn't go in the SHU that night? S signing it, and you did not do rounds? 5 MR. : I'm sorry? 6 MR. : I did not make the round in 6 MR. Why do you remember that you 7 SHU. 7 never went -- 8 MR. : So, if you didn't do a 8 MR. : Because I was trying to hire 9 round in SHU, were you off, could have you 9 overtime for the morning watch shift most of 10 signed it? 10 the night. At that point in time, with how 11 MR. : What do you mean? Wait, I'm 11 short we were lieutenants, and how short we 12 -- 12 were staffed, an Operations Lieutenant would 13 MR. : So, you signed it, saying 13 spend at least four hours a shift, trying to 14 that you did a round, but you didn't actually 14 just fill the overtime. And I remember, cause 15 do a round? 15 I even, I think, if I recall correctly, I 16 MR. : I didn't make the rounds in 16 remember, I even mandated Noel to work in SHU 17 SHU. And I don't remember signing this. 17 that night, for the overnight. 18 MR. : Okay. 18 MR. : So you think you spent most 19 MR. : Could I have signed it, 19 of the time in the office, trying to -- 20 like, hey, you missed a signature? Possibly. 20 MR. : Yes. I was doing the 21 But I don't remember signing it. Cause I know 21 roster, trying to fill the roster when 22 I didn't make rounds that night. 22 said, hey, I got it, . I'll take Epstein 23 MR. : Right. So, your 23 upstairs, the night before. 24 signature is on there, saying you did a round, 24 MR. : Do you think anyone could 25 but you did not do rounds? 25 have filled your signature in? EFTA00114462 197 198 1 MR. : Unless, unless they traced 1 this is yiiiiiiinature? 2 it. 2 MR. : I believe it's my signature, 3 MR. : But that does appear to 3 but I just don't remember signing that. I 4 be your siiiiiiie? 4 don't. S MR. : It's my , but it doesn't S MR. : And you don't remember 6 look the same on all of them, like, this one, 6 even goiniiiiiiie SHU. 7 it looks a little different than here. 7 MR. : I didn't make rounds that 8 MR. : But, for, I guess, the 8 evening, no. 9 next person to come in and sign would have been 9 MR. : And you don't remember 10 this individual. 10 actually even going into the SHU that -- 11 MR. : That's 11 MR. : Not that I recall. No. 12 MR. . . 12 MR. : So that's (Indiscernible 13 MR. : Yeah. 13 *02:25:05) like how could have your signature 14 MR. : Sljcupy have any 14 got on there? 15 reason to believe that would have 15 MR. : You would have to, you would 16 signed for ou? 16 have to, you would have to review the cameras, 17 MR. : No. No. 17 but I don't recall signing this paper. And I 18 MR. : If she noticed that this 18 know I didn't make rounds, because even when I 19 block was em t ? 19 went in with you luyiiathe FBI and the AUSA, 20 MR. : No. No. 20 she even told me name before I even 21 MR. : So you don't believe 21 said it. I said, my Activities Lieutenant made 22 would have done that? 22 rounds that night in SHU and she said, that's 23 MR. : No. I don't believe 23 Acting Lieutenant, Ms. . I 24 would have done that at all. 24 said, you are, I said, correct. I still 25 MR. : So you do believe that 25 recall, I recall that interview. 199 200 1 MR. : So, because this has such 1 MR. : That might have been when I 2 a high level focus now -- 2 signed it, but this would have, I wasn't here 3 MR. : Uh-huh. 3 on mornin. watch. 4 MR. : -- this is something that 4 MR. : What about on August 10th, S is actuall unfortunately, brand-new to us -- S when you did come back from the hospital? You 6 MR. : Uh-huh. 6 came backiiiiiii, on August 10th? 7 MR. ' -- we're going to have to 7 MR. : Yeah. I was here the whole 8 somehow resolve that. 8 day. I didn't go home. I don't remember 9 MR. : Uh-huh. 9 exactly, but I know it was, like, around 4:00 10 MR. : Do you have any, any kind 10 ish, 5:00 ish, when I got home, when I left. 11 of explanation to how that could have happened 11 MR. : So, I mean, it doesn't 12 then? You didn't do rounds in SHU. You never 12 look like, these things look like they were 13 even went in the SHU, and you could only sign 13 taken right awa , you know? 14 this document from within the SHU. 14 MR. : Uh-huh. 15 MR. : Uh-huh. 15 MR. : After Noel -- 16 MR. : And this is the documents 16 MR. : That might have very well 17 that were obtained. 17 been whatiiiiiiiiii 18 MR. : No, this could get signed in 18 MR. : That you signed it the 19 the lieutenant's office, after it's collected. 19 next day? 20 MR. : All right, so this could 20 MR. : I might have signed it when 21 have been collected -- 21 it was sittin' on the lieutenant's office pile. 22 MR. : Every night, this gets, the 22 MR. : All right. Can you give 23 six round sheets gets sent down to the 23 me the 4 p.m. count again, now that you're 24 lieutenant's office. 24 saying that it's sparking my memory that people 25 MR. : So, do you think -- 25 are saying that other documents weren't signed, EFTA00114463 201 202 1 as they should have been, the 4 p.m. count? 1 MR. •. took the count. 2 Were there places that you, as the Ops 2 MR. : Okay. And you didn't 3 Lieutenant, you were supposed to sign that you 3 participate in the 4 p.m.? 4 didn't here? 4 MR. : No. S MR. : This was, this should be S MR. : Did you participate in 6 signed off by the day watch Operations 6 the count that day? 7 Lieutenant. 7 MR. : I'm not sure. I don't 8 MR. : So that's day watch? 8 remember. I don't remember. 9 That wouldn't have been you? 9 MR. : But so at 4 p.m., you 10 MR. : Yeah. Yeah. Cause here I 10 were from 2 to 10. was only until 2. 11 am, I signed that one, right there. 11 And this is the 4, so shouldn't you have signed 12 MR. : So, you said this one on 12 that? 13 page, the third page should have been 13 MR. : I could, I could have been 14 that signed that one? 14 the one that should have signed it, cause I 15 MR. : It could have been -- 15 signed this one right here. I signed that, I 16 17 MR. : Count time, 4 p.m. MR. or myself. 16 17 know I siiiiiiiiiiiout count. MR. : So what is this one that 18 MR. : But then you say you 18 doesn't have a signature? What is that for? 19 started at 2? 19 MR. : This one right here? That's 20 MR. : Yeah. No, I'm saying, it 20 the total out count and there was one cadre 21 could have been me. 21 from 11 South out. 22 MR. : And you did the count? 22 MR. : Okay. So that one 23 MR. : It could have been , 23 doesn't have a signature, but the fourth page 24 either/or. 24 does and that's your signature, you said? 25 MR. : Who did the count? 25 MR. : That's me. 203 204 1 MR. : Anything else on here 1 , one of the two. 2 that needed to have signatures by you guys? 2 MR. : You can have 4 p.m., if 3 MR. : Yeah. I don't know who, I 3 is one 2? 4 don't know who sit:led that ht there. 4 MR. : Oh, no, no, cause he's gone S MR. : That's IIIIII, saying S at 2. Both of them were gone at 2. But that's 6 7 that she "ill-- MR. : No, that's from, it's from 6 7 not me. That's definitely not me. You see, I do the the circle everywhere. 8 . 8 MR. : So, is the one 9 MR. : Oh, cause she was still 9 that would have provided this to somebody to 10 in attorniiiiiiierence for the 4 p.m. 10 sign? 11 MR. : Yeah. This is, I don't know 11 MR. : Yeah. She would have given 12 whose signature that is. 12 the out count to the Operations Lieutenant. 13 MR. : But that's not yours? 13 MR. : All right. So we have to 14 MR. : That's not mine. 14 ask who signed this? 15 MR. : So, at 4 p.m., the 15 MR. : Yeah. Cause I don't know 16 attorney conference approved by, you can't 16 who that is. I don't know whose signature that 17 actually even make that out. 17 is. 18 MR. : I can't. I don't know who 18 MR. : And none of these people 19 that is. 19 on here that are working that day look like 20 MR. : If that's supposed to be 20 anybody that that could, that would have the 21 the Operations Lieutenant, this is not you, by 21 authority to do that? 22 looking at this daily roster can you deduce 22 MR. : No. There are only two 23 who it could have been? ? It's not 23 people, these are the only was the 24 , because -- 24 captain, the lieutenants, and , and 25 MR. : It's going to be or 25 myself are the only people. I mean -- EFTA00114464 205 206 1 MR. : It's not It's 1 like you forgot. 2 not you. 2 MR. : I forgot. 3 MR. : An acting, an acting 3 MR. . So, it would have been 4 lieutenant could sign, if they're in that 4 ? S capacity, but she was still attorney conference 5 MR. : No. was the one that 6 when this was done. 6 was in . This is the , coming from • 7 MR. : All right. 7 out count. 8 MR. : So, I don't know whose 8 MR. : So who would have 9 signature that is. 9 provided this to you, to sign it? 10 MR. : And then this -- 10 MR. . . 11 MR. : And that's mine. 11 MR. : All right. So, 12 MR. : And that one is yours, so 12 would have liven that to you to sign? 13 for the official out count. Is this weird to 13 MR. : Yeah. 14 you at all, this, the fact that somebody else's 14 MR. : But in this case, it 15 signature is on that? 15 sounds like she didn't? 16 MR. : Yeah. I don't know who the 16 MR. : No. I don't know. I don't 17 fuck, cause I know I didn't sign it. And I 17 remember if she didn't. give it to me right off 18 know, this was probably just a slip of the, I 18 the bat, or if I just forgot to sign it. It 19 forgot to si n it the other one. 19 could be, I for•ot to sign it. 20 MR. : Uh-huh. 20 MR. : Okay. 21 MR. : Because I signed everything 21 MR. : But I don't know who that is 22 else. 22 on that other one. I don't even, it looks 23 MR. : So the one, so one is 23 like, it 'ust looks like a squiggly line. 24 that you were supposed to have signed was 24 MR. : So, on the 4 p.m. count, 25 signed by someone else, and another one looks 25 after the E-1, so there's, on the third page, 207 208 1 you forgot to sign. On the fifth page, fourth 1 MR. : MI? Oh, that could 2 page, you did sign. Seventh page, shows the 2 be I ? 3 official count from I. . That is not 3 MR. : I don't know, it just, it 4 your signature. All right. And then the last 4 looks like a squiggly line. But that's S one is you as well. S definitely not my signature. You have been 6 MR. : I signed. Uh-huh. 6 watchini me sign papers all this interview. I 7 MR. : Which is the official out 7 do the circle -- 8 count from the hospital. So, the attorney 8 MR. : Yeah, no, I know it's not 9 conference room, you got to figure out whose 9 yours. That's 'that I'm just trying to figure 10 signature that is. And no one would have been 10 out who it is. 11 12 authorizeiiiiiliou know -- MR. : A lieutenant is supposed to 11 12 MR. MR. : Yeah. Yeah. I don't know. : No, there's no question. 13 sign the out count. 13 It's not yours. Do you remember that day, 14 MR. : But it could have been a 14 though, yiiiiiliositive you came in at 2? 15 lieutenant? But there are, as far as you know, 15 MR. : I don't even know why it 16 there is no other lieutenants that were 16 says non-21 :Ay_jitre. 17 actually even in the building at that time? 17 MR. IIIIIIIIII: Somebody indicated that 18 MR. : Unless this was done before, 18 someone manipulated that, and that it shouldn't 19 an out count has to be in 45 minutes prior to 19 say non-custod . 20 the count. So that means it would have had to 20 MR. : I was custody at the time. 21 be done no later than 3:15. Unless that was 21 MR. : So, somebody, somebody 22 done before went home, I don't know. 22 has told us, doesn't make any sense that 23 MR. : But it doesn't even look 23 there's an NC there. Do you agree with that? 24 like it would be a . 24 MR. : I agree 100% there. It 25 MR. : It doesn't. 25 would have said, it would have said nothing. EFTA00114465 209 210 1 It would have said nothing, because custody 1 time. Yeah. 2 don't have that, NC stands for non-custody on 2 MR. : All right. So, okay. So 3 the roster. 3 we can't put any real credence to NCs when we 4 MR. : The fact that this was 4 see the, based upon the print (Indiscernible S printed out on June 2, 2021, would that auto -- S *02:33:48). 6 MR. : That's because I was a 6 MR. : No, after, like, I became a 7 counselor alread . 7 counselor. Februar 2020. 8 MR. : -- would that populate to 8 MR. : Okay. 9 non-custoiiiiiiimatically? 9 MR. : So I have only been non- 10 MR. : Yes. Because I'm non- 10 custody since then. 11 custody now. 11 MR. : All right. And then this 12 MR. : Okay. 12 one was just an email, saying that I was, this 13 MR. : I'm a counselor. 13 is just confirming that, it's ust an email 14 MR. : So, when we printed out, 14 that you sent to someone ? 15 that date, these things would be automatically 15 MR. . . 16 generated with our name, NC. 16 MR. ' . , just saying 17 MR. : Uh-huh. Yes. 17 that you were Activities, and had to go to the 18 MR. : So would that be why then 18 hospital to make sure staff weren't bothered by 19 (Indiscernible *02:33:27). 19 media, while his body was there. "Today, I am 20 MR. : That's probably why. I 20 DW Ops." 21 didn't see that this was printed this year. 21 MR. : Day watch. 22 MR. : Okay. All right. So, it 22 MR. : Day watch Ops. Okay. 23 would be printed, based upon what you are at 23 That was just in case you had any kind of need 24 25 the time, but were custody at the time? MR. : I was a lieutenant at the 24 for recollection that you actually worked those 25 days. Here you go. So, here is something, 211 212 1 just saying that, so, in his first suicide 1 out at the same time, but otherwise, they're in 2 attempt, correct, do you remember who his 2 two separate rooms. 3 cellmate was at the time? 3 MR. : So they're not even 4 MR. : He was that cop guy. I 4 seeing each other or interacting? S forgot his name. S MR. : No. They will be in, and as 6 MR. : Tartaglione. 6 a matter of fact, they're SHU inmates, so the 7 MR. : Tartaglione. 7 SHU inmates, the SHU cell, the SHU cells, the 8 MR. : T-A-I-T-A-I-L-I-O-N-E. 8 attorney conference cells for the SHU inmates 9 MR. : Yeah. 9 are the same as the SHU cells. They're locked 10 MR. : So, there's an email 10 in with their attorney. 11 dated August 7, 2019, to all the lieutenants, 11 MR. : Okay. 12 saying that Tartaglione was going to be in 12 MR. : So, they couldn't even, 13 attorney conference on Friday, August 2, 2009. 13 like, come out and pass each other. 14 Now, (Indiscernible *02:35:03) Epstein was in 14 MR. : Okay. Do you mind just 15 there at the same time. Do you know if they 1S initialin' and dating that? 16 would have had any interaction in there? 16 MR. : Sure. 17 Together? 17 MR. : Did you have any 18 MR. : No. They were in separate 18 involvement with that initial July 23, 2019? 19 rooms. 19 MR. : No. 20 MR. : So they would not have 20 MR. : Have you heard any rumors 21 gone together? 21 about Tartaglione attempting to harm Epstein? 22 MR. : Unless, like, when they were 22 MR. : No. I heard that he was 23 going in, or cumin' out. 23 helping him. He is the one that notified the 24 MR. : Okay. 24 staff that he needed help. 25 MR. : If they were coming in or 25 MR. : Okay. EFTA00114466 213 214 1 MR. : That's what I heard. 1 the cell with them. 2 MR. : So, you didn't hear 2 MR. : Okay. But from any 3 anything about him trying to harm Epstein? 3 information that you have received, do you have 4 MR. : On the street. 4 any reason to believe? S MR. : And what -- S MR. : No. I know, from what I 6 MR. : People talking shit. 6 know of Tartaglione, he's trying to beat his 7 MR. : Do you think -- 7 case. He's trying to fight his case. So I 8 MR. : And I'm not even talking 8 don't think he would want to add any undue 9 about Bureau staff. I'm talking about, you 9 thing to his case. 10 know how much shit, pardon my language -- 10 MR. : Okay. Okay, so I'm just 11 MR. : Yeah. 11 going to, so this was after the fact, on 12 MR. : -- I know we're on camera -- 12 LLigal, August 16, 2019, the captain, 13 MR. : Yeah, yeah. 13 I'll'', , sent a message to a number 14 MR. : -- on tape here, do you know 14 of people, it looks like all the lieutenants, 15 how much trash I got from people that have 15 to include yourself. It just says, 16 known me my whole life, and I tell them 16 "Lieutenants, there has been a significant 17 straight out, I can't answer your questions. 17 change concerning the placement of inmates on 18 I'm not gain, to answer your questions. 18 suicide watch at MCC. Starting 8/16/19, when 19 MR. : Right. 19 an inmate expresses intentions to physically 20 MR. : Don't talk stupid trash to 20 harm themself or behavior warrants placement on 21 me. I was, like, don't, don't even go there. 21 watch, please make sure the captain is notified 22 MR. : Do you think there's any 22 immediately by phone. If inmate companions are 23 validity to any kind of a claim, saying that 23 needed to sit on the inmate, the overall 24 Tartaglione attempted to harm Epstein? 24 approving authority is the warden. Inmates 25 MR. : I don't know. I'm not in 25 will no longer be able to remain on SHU bed 215 216 1 space, so there should be an initiative to have 1 MR. : He wasn't, he didn't have to 2 adequate bed assignments available in the 2 be. 3 Special Housing Unit." So, were people that 3 MR. : Okay. 4 were attempting to harm themselves previously 4 MR. : As long as we notified S not being referred to suicide watch, are you S Psycholog 6 aware? 6 MR. : Sure. So, people were, 7 MR. : No. As a matter of fact, if 7 it's not a change in practice. It's a change 8 I, I, at one point in time, if I felt like a 8 in notification to the captain? 9 new intake, if I was, let's say, Operations 9 MR. : Yes. 10 Lieutenant on an off-shift, and we didn't have 10 MR. : Okay. 11 Psychology here, if I felt they were a threat 11 MR. : A lot of those things change 12 to themselves, I would put them on watch, and 12 like I chance socks. 13 then all I would have to do is notify 13 MR. • Yeah. If you don't mind, 14 Psycholog . 14 just initial and date these daily assignments, 15 MR. : Okay. 15 then. 16 MR. : Like, I would wake up the 16 MR. Sure. : 17 on-duty psychologist at home and say, hey, doc, 17 MR. : For the 9th and 10th. I 18 I'm puttin' inmate on observation. 18 know we have been keeping you awhile. Just 19 MR. : All right. So, the only 19 want to finish up these questions. 20 change here was that the captain wanted to be 20 MR. : (Indiscernible *02:38:42). 21 notified? 21 MR. : So what is your 22 MR. : Yes. I believe so. 22 understanding of what happened to Epstein on 23 MR. : All right. And he wasn't 23 August 9th and 10th, 2019? 24 notified prior to that time, is that what he's 24 MR. : My understanding is that he 25 saying? 25 committed suicide. That he hung up. EFTA00114467 1 2 217 MR. : Is that, you understand of how he died was from suicide and hanging? 1 2 218 MR. : It's a matter of the clothing. Observation, they were allowed to 3 MR. : That's what I understand. 3 have their regular attire on, with an inmate 4 Yes. 4 companion. Suicide watch, they were in the S MR. : Okay. Do you have any S smock and had the, like, the sleeping bag, the 6 7 information with regard to any suspicious activity that occurred on August 9th or 10th, 6 7 suicide siiiiiiiiiig. MR. : And that is outside of 8 2019, leading up to the discovery of Epstein in 8 the SHU, correct? 9 his cell? 9 MR. : That is outside of the SHU. 10 MR. No. : 10 MR. : What floor is that? 11 MR. : I'm just going to go over 11 MR. : In the event, in the event 12 just some broad, general issues and just ask 12 that suicide watch on second floor was 13 you if you have any information on it. So, we 13 overbooked, overfilled, we would do suicide 14 just talked about his first suicide attempt on 14 watch in SHU, but it would be a staff member 15 July 23, 2019. Are you aware if Epstein was 15 watching. 16 placed on suicide watch after that? 16 MR. : Okay. And is it your 17 MR. : I'm not sure. I'm not 100% 17 understanding, though, that Epstein was removed 18 sure. I think he was placed on observation 18 from the SHU and placed on either suicide watch 19 after that incident. 19 or psychological observation after the initial 20 21 MR. : Okay. : MR. If I'm not mistaken. 20 21 incident iiiiiiii 23rd? MR. : I've seen him down on 22 MR. : And is observation, 22 suicide watch and observation on the second 23 suicide watch, are they basically the same 23 floor. 24 thing, just a matter of, if you give your 24 MR. : So, you actually did see 25 clothes or not? 25 him there? 219 220 1 MR. : Yes. That's where I fed 1 MR. No. That was it. : 2 him. 2 MR. : Okay. Do you believe 3 MR. : Okay. 3 that Epstein was prematurely removed from 4 MR. : Cause lieutenants have to 4 psychological observation or suicide watch? S feed the inmates. S MR. : No. I mean, the Ph.D. 6 MR. : Oh, so that notation of 6 psychologist felt that it was appropriate. 7 feeding on this was actually not regarding the 7 They're the doctors. 8 -- 8 MR. : Have you heard any rumors 9 MR. : It was probably, it might 9 about anyone else having any say in him being 10 have, it may have been in the SHU, if he was a 10 removed? 11 lieutenant hold at the time. But when he was 11 MR. : No. 12 on observation I have fed him down there. 12 MR. : Have you heard any rumor 13 MR. : Okay. So you had 13 about the judge calling the warden and asking 14 interaction with him when he was actually on -- 14 him to have him removed so he could continue 15 MR. : Yeah, basically just, as far 15 with his attorney visits? 16 as opening the slot, handing him his food 16 MR. : I have never heard the 17 trays, collecting his trash, locking the slot, 17 rumor. 18 you okay? You okay? Okay. And, can I talk to 18 MR. : No? By anyone, streets 19 the Psychology Department? Go get the psyche. 19 or inside or otherwise? 20 That's it. 20 MR. : No. 21 MR. : Anything that he said to 21 MR. : Okay. We already talked 22 you that was cause for concern? 22 about Reyes being removed. Although you 23 MR. : No. 23 received that email the day before, that wasn't 24 MR. : No? Anything more than 24 something that you reviewed, so you didn't know 25 can you get me this or get me that? 25 that Reyes was actually being removed from the EFTA00114468 221 222 1 institution or transferred, correct? 1 MR. : Well, all I could say is 2 MR. : No. No. Yes. Yes. 2 this. The staff were walking around like 3 Correct. 3 zombies. 4 MR. : And no one told you? 4 MR. : Right. S MR. : No. S MR. : These guys and girls were 6 MR. : Aside from that email? 6 getting stuck four days a week, sometimes five 7 MR. : Aside from the email. 7 days a week, doing 16 hour shifts. I have 8 MR. : Okay. And that, again, 8 never in my career have seen so many write-ups 9 is that, oh, you already answered it. Do you 9 for officers refusing mandates. I have had to 10 know anything about other falsified counts 10 write-up countless officers because they 11 being conducted in the MCC prior to August 10, 11 refused a mandate, when I told them they had to 12 2019? 12 stay. And then, but at the same time, I 13 MR. : No. 13 didn't, I felt bad for them. 14 MR. : Do you believe that 14 MR. : Uh-huh. 15 counts were being conducted in the MCC, prior 15 MR. : I really did. Because they 16 to August 9th and 10th, 2019? 16 were zombies. I was a zombie. And I was only 17 MR. : I would hope so. 17 getting hit, like, twice a week. 18 MR. : Anything about the SHU, 18 MR. Okay. 19 though, I mean, if they're sleeping in the SHU, 19 MR. And I was a zombie. I'm : 20 we have heard rumors that maybe in the SHU, 20 also pushing 47 now. I'm not a young kid 21 they were sleeping a lot. Had you heard 21 anymore, and some of these kids, 20 something 22 anything about that, them sleeping during their 22 years old, they would literally, they would be 23 shifts in the SHU? 23 standing u' and exhausted. 24 MR. : What, the staff? 24 MR. : So people are just too 25 MR. : Yeah. 25 exhausted to do their job, is it? 223 224 1 MR. : How, I mean, I spent time in 1 MR. : But you're unaware for 2 the Marine Corps and I remember going 36, 40 2 both? 3 hours on three hours of sleep and that was 3 MR. : I'm unaware. 4 rough at 18 19 ears old. 4 MR. : Okay. S MR. : Right. S MR. : I can't confirm. 6 MR. : You know? Doing 16 hours, 6 MR. : All right. What do you 7 it's not human. 7 know about the %ICC, and particularly the SHU 8 MR. : Uh-huh. 8 cameras not working on August 9th and 10th, 2019? 9 MR. : Our bodies are not made for 9 MR. : I found that out when 10 that. 10 everybody else did. I honestly didn't know 11 MR. : Okay. So, being that 11 they weren't working. 12 they were exhausted and people were sleeping 12 MR. : So, during your, 13 during their shifts, especially with the 13 especially on August 9th, when you were working, 14 focusing in on the SHU. Do you believe that 14 did anyone ever notify you that the cameras 15 it's likely that counts weren't being conducted 15 were not recording? 16 prior to August 9, 2019? 16 MR. : No. 17 MR. : I hope to God not. 17 MR. : Is there any way for you 18 MR. : Okay. 18 to have known? 19 MR. : I really do. I can't 19 MR. : No. I don't know. The only 20 confirm niiiiiiiiii I just hope to God not. 20 thing, like in the lieutenant's office and in 21 MR. : What about rounds? Do 21 control, we can see the cameras, but we don't 22 you know if they were being conducted in the 22 know if the,'re actually recording or not. 23 SHU prior to that? 23 MR. : So, there's nothing to 24 MR. : I would hope, once again, I 24 indicate if the recording? 25 would hope so. 25 MR. : Like, that's kept somewhere EFTA00114469 225 226 1 else, like in the Computer Services people. 1 MR. : And do you know anything 2 MR. : Do you know at the time 2 about anyone knocking the cameras offline? 3 where that was kept? 3 MR. : No. I do not. 4 MR. : I think, if I'm not 4 MR. : Have you heard any rumors S mistaken, there's one on 3, by the com room, S about that? 6 and I'm not sure if there is one down here on 6 MR. : No. 7 1. 7 MR. : Do you have any kind of, 8 MR. : Do you know if, at the 8 even theory or explanation of why the cameras 9 time, do you know if the cameras where the 9 were not recording specifically in the SHU? 10 recording would have been kept in the SIS 10 MR. : No. 11 office? 11 MR. : No? And you hadn't heard 12 MR. : Well, there's, where the 12 anything about that? 13 cameras, like, the hard drives are in the back 13 MR. : Not until I heard it from, 14 of where the com room is. 14 you know, what everybody else going on around, 15 MR. : Okay. 15 like, yo, the cameras didn't work. The cameras 16 MR. : Which is part of the whole 16 didn't piiiiiiiiiiig up. And the newspapers. 17 SIS shop back there. 17 MR. : Is that surprising to 18 MR. : So, if someone wanted to 18 you, for iiiiiiihear? 19 knock the cameras offline and intentionally 19 MR. : No. Cause everything here 20 stop them from recording, like, where could 20 is gone. This building is decrepit. 21 have they done that from? 21 MR. : Okay. 22 MR. : I'm not 100% certain. I 22 MR. : I'm sorry. I can't put it 23 don't know if it could be done from back there 23 lightly. 24 or not. I just know that that's where the room 24 MR. : Oh, no. That's why we're 25 is. 25 here, is to figure out -- 227 228 1 MR. : I've been here, listen, I've 1 else. 2 been here 20 out of my 21 years on the job. 2 MR. : So 3 I'm rounding it off. I mean, I don't have 3 MR. • 4 exactly 21 years. I've seen this place on a 4 MR. : Do you know if S steady decline. S would have been here at the time? 6 MR. : I know. What about the 6 MR. : I don't remember. I don't 7 cameras? Weren't they all fixed? 7 remember when he started. 8 MR. : They were just recently 8 MR. : Okay. 9 fixed. Now the cameras are phenomenal. 9 MR. : He's the head of Facilities, 10 MR. : Okay. 10 so. 11 MR. : Like, when I was a 11 MR. : And who is, what's his 12 lieutenant, I wished the cameras were as good 12 name? what? 13 as they are now. You could actually see faces 13 MR. 14 of inmates fi htin . 14 MR. : Who is ? 15 MR. : Uh-huh. 15 MR. : Right now, he is the lock 16 MR. : And identify them. But 16 shop. The Chief of the lock shop. Lock and 17 18 before thiiiiiiiiiiuldn't. MR. : Who is responsible for 17 18 Security -- MR. : Do you know where he 19 the cameras? 19 would have been at the time? 20 MR. : The com room. I'm sorry. 20 MR. : I don't remember. I think 21 Not the com room. The com shop, the com techs. 21 he was, was he plumbing at the time or was he 22 MR. : And do you know who that 22 in the lock sho'? I'm not sure. 23 would have been at the time? 23 MR. : Do you know if he had 24 MR. : Who was here? I think 24 anything to do with cameras? 25 . I think . I'm not sure of who 25 MR. : I'm not, I'm not 100% EFTA00114470 229 1 certain. 2 MR. : So, is in charge 3 of the cameras. Who would have he reported to, 4 do you know? MR. 6 MR. : Yeah. 7 MR. Well, I think, I guess his 8 boss would be and the assistant. 9 MR. : The assistant, who? 10 MR. Facilities Manager. 11 MR. : All right. So, there's a 12 Facilities Manager and an Assistant Facilities 13 Manager? 14 MR. : They are, and they're not. 15 MR. : Okay. 16 MR. : When we're fully staffed, 17 there is usuall a boss and an assistant. 18 MR. : Okay. 19 MR. : I don't recall who it was at 20 the time. 21 MR. : Do you know if Epstein 22 was in his assigned cell on August 10, 2019, 23 when he was found? 24 MR. : I'm not 100% sure. I know 25 he was in that corner cell, that's all I know. 230 1 MR. : Who would be responsible, 2 if he, in the BOP database, the system, he is 3 assigned to a different cell than he is 4 actually physically located? Who would be S responsible for making that change within the 6 BOP? 7 MR. 8 MR. 9 MR. _Oh, within Sentry? : Yeah. : As soon as the, basically, 10 the SHU Lieutenant would have to stay up on top 11 of that. 12 MR. : So, it's the SHU 13 Lieutenant's responsibility for that? 14 MR. : To make sure that everything 15 is where iiiiiiiiiised to be in his unit. 16 MR. : Does Ops or lieutenants 17 or anybody that visits the SHU and do rounds, 18 are they responsible at all for -- 19 MR. : No. You're not going to 20 pick up a PP30 -- 21 MR. : Sure. 22 MR. : -- when you're making 23 rounds. Like I said, your predominant, the 24 predominant function of doing the rounds is 25 make sure the officers are doing their job. to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 231 MR. : Do you have, do you know if Epstein was always in that cell that you described? MR. : No. Like I said, at one point in time, I think he was down on H tier. I do know -- MR. : Let's say, after he returned from suicide watch or psychological observation, do you know if he was always -- MR. : I don't remember. MR. : You don't remember? MR. : I don't remember. MR. : Do you know if, at least for the days leading up to August 9th, was he in that same cell? MR. : I mean, at least a couple of days, I believe, yes. I'm not 100% certain, though. MR. : Okay. And you mentioned, mentioned that you knew that this will be the last of the you was allowing Epstein to place a telephone call on August 9, 2019? MR. : Yeah. When I came around to escort him, he said, I got it. I'm going to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 232 bring him up to SHU, and I'm going to give him a legal call. I said, okay. MR. : And do you know why he was being afforded a legal call? MR. No, I do not. MR. : Especially the fact that he is alreail with his attorneys? MR. : And his attorney had left already. I do not know. MR. : Do you know if it was actually a le al call that he placed? MR. I don't know. I don't know. MR. : Do you know anything about it at all? MR. : Other than he brought him on the elevator and that was the last I saw of Epstein. MR. : And did you talk to about that at all after the fact? : No. No. : Did you see after MR. MR. he returned him? MR. : No. I think he went home. I think he left the buil. MR. EFTA00114471 233 234 1 MR. : Yeah. 1 MR. : Right. 2 MR. : All right. Did you find 2 MR. : I'm not going to put you on 3 it unusual that he was being allowed to place a 3 with the attorney and then sit there and hear 4 -- 4 you say, oh, hi, Mom. No. Cause if you tell S MR. : No. I mean, we have done it S me a legal call, I'm giving you a legal call. 6 for other inmates before, too. Like, if, let's 6 MR. : Do you know, would have 7 say, you know, oh, I forgot to ask my lawyer, 7 needed approval to allow him to place a 8 it's all about, what's the word I'm looking 8 call like that? 9 for? Convenience. If it's not inconveniencing 9 MR. : Well, you, is a unit 10 the person or the time, or if it's going to be 10 team member, and unit team would normally do 11 an issue or a security issue, or something like 11 the legal calls for the inmates. 12 that, and you feel like doing it, you can do 12 MR. : Okay. So, would have, if 13 it. There's nothing to say -- 13 it was a legal call they provided him, but not 14 MR. : What if Epstein told them 14 to his legal team, to his mother, would have he 15 that he is actually not calling his lawyer, but 15 needed to obtain approval for that? 16 he's callin' his -- 16 MR. : I don't know. I'm assuming 17 MR. : Mother. 17 yes. I don't know. I never heard of any, I 18 MR. : -- mother? 18 never heard that it was to his mom. I always, 19 MR. : I don't know. 19 he told miiiiiiiiiiing him a call. 20 MR. Is that at all, do you : 20 MR. : Okay. So that's all you 21 believe that to be an acceptable practice, to - 21 know about it? 22 - 22 MR. : That's all I know about it, 23 MR. : I wouldn't, I wouldn't do 23 and he got on the elevator and brought him up 24 it. If you're telling me you need a legal 24 to SHU. 25 call, you're going to call your attorney. 25 MR. : Okay. What do you know 235 236 1 about someone else taking Epstein's life? 1 MR. : Did you have any 2 MR. : Nothing. Except for the, 2 involvement with Epstein -- 3 pardon my language, the BS rumors that you hear 3 MR. : Absolutely not. 4 out in the media, on social media, and in the 4 MR. : What would have prevented S public. S Epstein's death, in (Indiscernible *02:S2:11)? 6 MR. : Okay. What do you know 6 MR. : In all actuality, if he 7 about others assisting with taking Epstein's 7 really wanted to commit suicide, nothing would 8 life? 8 have prevented it, because anybody that really 9 MR. : I don't believe that. 9 wants to kill themselves can kill themselves. 10 MR. : What do you, when you say 10 Epstein's cell overlooked the OIC's desk. He 11 you don't believe it, do you know of any rumors 11 was watching the staff. He knew when he could 12 or -- 12 and when he couldn't. 13 MR. : No, I don't know of 13 MR. : Okay. So do you think 14 anything, and I don't believe it. I don't, 14 that if they were actually conducting their 15 there is nothing I know about it. And I have 15 counts and rounds as they should have, would 16 seen, not just at MCC New York, you hear about 16 have that," in preventing the death? 17 it throughout the Bureau. Somebody could hang 17 MR. : It could have helped, but it 18 themselves, just leaning forward on a bed. And 18 wouldn't have totally prevented it, because it 19 it only takes a couple of minutes. 19 just takes minutes to kill yourself. If I 20 MR. : So, did Epstein take his 20 wanted to do it, I would wait for you to make 21 own life? 21 your round. I now know, I have 30 minutes to 22 MR. : I believe so, yes. 22 kill myself. It only takes two or three. 23 MR. : Did Epstein act alone in 23 MR. : What about the fact that 24 taking his own life? 24 he was mandated to have a cellmate, and the 25 MR. : I believe so. 25 cellmate was removed and no one backfilled it? EFTA00114472 237 238 1 Do you think that would have helped? 1 staff -- 2 MR. : Yes or no. Remember what I 2 MR. : Uh-huh. 3 told you, in 2003. That dude committed suicide 3 MR. : -- and people didn't act 4 and he had a bunkie. 4 in order to get him a new cellmate, what are S MR. : And then in the same S some of the other problems, systematic 6 token, though, you said Tartaglione was the one 6 problems? It sounded like you may have 7 that notified them when he attempted the first 7 mentioned that people were too tired to work 8 time. 8 (Indiscernible *02:54:04). 9 MR. : Yeah. So, like, yes and no. 9 MR. : Well, that's the only thing 10 That's why I said yes and no. Like, if that 10 I got. Especially at that time. Right now, 11 inmate is asleep, and let's say that inmate is 11 staffing got a little better. It got a lot 12 a heavy sleeper, Epstein could have strung up 12 better, and staff got put on 12 hour shifts. 13 while he was aslee . 13 So, this way, they have more time off. And 14 MR. : Okay. And then this is 14 they can't get stuck for 16s every day. Right? 15 just the last overall question that I have and 15 That's now. Then, they were tired. They were 16 then I'll turn it over. What are some of the 16 tired. And you also didn't, you never had a 17 systematic problems inside the MCC, and 17 regular crew. What I mean by a regular crew, 18 specifically, the SHU that allowed for Epstein 18 you never, you didn't always have the 19 to die? 19 consistent staff in there. And you had staff 20 MR. : I'm sorry. Can you just 20 that were exhausted, on top of exhaustion. And 21 restate tiiiiiiiiiin? 21 the SHU unit, in my opinion, always has, when I 22 MR. : So, what are some of the 22 was even, when I was a SHU officer back in the 23 problems in the SHU? We just talked about, 23 early 2000s, that was the post. That was one 24 obviously, if they didn't conduct their rounds 24 of the most high-profile posts in this 25 and the counts as they should have, the SHU 25 building. 239 240 1 MR. : The SHU was? 1 let's say, for instance, on a staff member 2 MR. : SHU. Yeah. I mean, even 2 that's totally exhausted. There's only six 3 until this whole thing happened. 3 cells up there. And you don't have to crawl up 4 MR. : Why? 4 and down stairs. You walk from the first cell, S MR. : We had, we had El Chapo for S it's like a U, almost. 6 two years. 6 MR. : Is it also true that 7 MR. : Right. 7 every cell has their own individual camera? 8 MR. : Without a hitch. With 8 : MR. Yes. 9 nothing. 9 MR. : And who monitors those 10 MR. : But he was also not in 10 cameras? 11 SHU. He was in 10 South. 11 MR. : The officer that is working 12 MR. : He was in 10 South. 12 the unit has the screens up and, right in front 13 MR. : Do you believe that 13 of his or her station and the same cameras can 14 Epstein should have been in 10 South or I tier? 14 be seen in the com room. 15 MR. : I mean, my personal opinion 15 MR. : Okay. So, is anybody 16 really doesn't matter with the grand scope of 16 actually monitoring in the com room? 17 things. I'm not a decision maker. 17 MR. : Not on the off-shifts. 18 MR. : Well, just with 20 years 18 MR. : Okay. What shifts? 19 20 at MCC, diiiiiiielieve he should have -- MR. : I feel he should have been 19 20 MR. MR. : Day shift. : Just day shift? 21 on 10 South. 21 MR. : There used to be, when the 22 MR. : Okay. And why? 22 staff was available, the night shift. But for 23 24 MR. : Because that is the Super Max Unit. That's even more higher security 23 24 the most MR. : "'lilies the day shift. Okay. So, but the person 25 than SHU. And it's also a lot, it's easier, 25 that's actually assigned to 10 South, and is EFTA00114473 241 242 1 this the same for, does the 10 South guy also 1 MR. You have about covered 2 review I South? The I tier cameras, as well? 2 everything. Just a last question. Are COs 3 MR. : I believe the cameras are in 3 allowed to conduct rounds, counts by 4 there, too. You can see them on that screen, 4 themselves? S yes. S MR. : If there's less than five 6 MR. : So, 10 South would watch 6 inmates. 7 both -- 7 MR. If, let's say in the SHU. 8 MR. : Yeah. Uh-huh. 8 Are they allowed to do counts by themselves? 9 MR. : -- 10 South, as well as I 9 MR. : No. There's more than five 10 tier? 10 inmates. Ten South, if there's four inmates on 11 MR. : I believe so. 11 10 South, the officer doesn't need another 12 MR. : And all of them have 12 officer to count. 13 cameras? 13 MR. : If they did the count by 14 MR. : I could be wrong, but I 14 themselves, is that an actual count? Is it 15 believe so. 15 considered as a count? 16 MR. : Okay. But you believe 16 MR. : It's not a proper count. 17 that by placing him on 10 South, he would have 17 It's not a proper count. I mean, I could 18 had more visibility? 18 count, easily count 96 inmates, 100 inmates, 20 19 MR. : Yes. That's my personal 19 inmates, whatever it is, by myself. It's not 20 opinion. 20 going to be an official count unless you have a 21 MR. : Okay. Is there anything 21 back-up person. You have, the way the policy 22 else that you want to add that we haven't 22 works is one officer is supposed to stay at the 23 addressed? 23 end of the range, one officer goes downrange, 24 MR. : No. 24 counts the inmates, come back and that other 25 MR. : No? =? 25 officer goes duo and counts the range. And 243 244 1 then when you meet back up at the front, I got CERTIFICATE 2 15, 15, okay. Then they go to the next tier. I hereby certify that the foregoing pages 3 Cause I might have 15 and you might have represent an accurate transcript of the 4 counted 14. We got to redo that count. And electronic sound recording of the proceedings S then until we both jive, and then go to the before the Department of Justice, Office of the 6 next tier, same thing, another tier, another Inspector General in the matter of: 7 tier, whatever, how many tiers there are in the 8 unit, then we come up with our total number, Interview of 9 and that's what we call into Control. Say, 10 hey, ZA, and Smith, I got 55. Fifty- 11 five is a good verbal. All right. Thank you. 12 Sign the count slip. You sign, I give it to 13 you, you sign the count slip. Send it down to Transcriber 14 internal to control. , 15 MR. : Nothing from me. 16 MR. : Nothing? All right. 17 Nothing else? 18 MR. : No. 19 MR. : Any questions for us? 20 MR. : Nope. 21 MR. : All right. It is 22 currently 12:22 p.m. on Wednesday, Aiiiii4, 23 2021. This is Senior Special Agent 24 , and I am turning off the recorder. 25 EFTA00114474