EFTA00116060.pdf

1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JULY 14, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 EFTA00116060 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00116061 3 1 MR. The recorder is on. My 2 name is nd I'm a Senior 3 Special Agent with the U.S. Department of 4 Justice, Office of the Inspector General, New 5 York Field Office and these are my credentials. 6 MR. Thank you, sir. 7 MR. Z: This interview with the 8 Federal Bureau of Prisons, employee, 9 is being conducted as part of an 10 official U.S. Department of Justice, Office of 11 the Inspector General investigation. Today's 12 date is July 14, 2021 and the time is 1:14 13 p.m.? 14 MR. Yes. 15 MR. This interview is being 16 conducted at the Metropolitan Correctional 17 Center in New York, New York, also known as the 18 MCC. Also present is DOJ OIG Special Agent 19 This interview will be recorded 20 by me, SSA Could everyone 21 please identify themselves for the record and 22 spell your last name. To start, again, I am 23 DOJ OIG Senior Special Agent 24 25 MR. 'Ill.,: This is DOJ OIG Special Agent EFTA00116062 4 1 2 MR.IMIN Lieutenant 3 work for the Bureau of Prisons at MCC 4 New York. 5 MR. MATULEWICZ: Could you just spell your 6 last name for the record? 7 MR. 8 MR. : Thank you, sir. This is 9 an official DOJ OIG investigation into the 10 death of inmate Jeffery Epstein and the 11 surrounding circumstances and you're being 12 asked to voluntarily provide answers to our 13 questions. Will you agree to a voluntary 14 interview with the DOJ OIG? 15 MR. Yes. 16 MR. : Yes, thank you. All 17 right, so we got that form, it's the DOJ OIG 18 form 11I-226/2. It says, "The United States 19 Department of Justice, Office of the Inspector 20 General Warnings and Assurances to Employee 21 Requested to Provide Information on a Voluntary 22 Basis. You are being asked to provide 23 information as part of an investigation being 24 conducted by the Office of the Inspector 25 General. This investigation is being conducted EFTA00116063 5 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 pursuant to the Inspector General Act of 1978, as amended. This investigation pertains to security failure and job performance failure. This is a voluntary interview. Accordingly, you do not have to answer questions. No disciplinary action will be taken against you if you choose not to answer questions. Any statement you furnish may be used as evidence in any future criminal proceedings or agency disciplinary proceeding or both." And there's a waiver section. It says, "I understand the warnings and assurances stated above and I am willing to questions. made to me make a statement and answer No promises or threats have been and no pressure or coercion of any kind has been used against me." And as mentioned, this is something that we provide everybody for voluntary interviews, so you're being asked, you know, we just provide these warnings to everyone just knowing it's voluntary, you can stop at any time, you don't have to answer our questions. Do you understanding? MR. Yes, sir, I understand. MR. All right. So, if you EFTA00116064 6 1 want to review it yourself, please feel free 2 otherwise there's employee signature and then 3 employee name below. Thank you for signing, 4 sir. I'm going to sign for the Office of the 5 Inspector General Special Agent. And I'm 6 writing my name, The date 7 is 7/14/2021. 8 MR. 1:16. 9 MR. The place is - the time 10 is 1:16 -- 11 MR. Sixteen. 12 MR. -- p.m. The place is MCC 13 New York. Special Agent can you please 14 sign as the signature witness and place your 15 name as the name of witness. 16 MR. This is Special Ageni 17 I'm signing at a witness. 18 MR. And as I mentioned, 19 Lieutenant I believe, were you 20 interviewed prior by the OIG and the FBI? 21 MR. Yes, I was. 22 MR. •: All right, as mentioned, 23 there's a report that I have here. I don't 24 even think that it's worth going over because 25 there's not really much in it. So, the reason EFTA00116065 7 1 for us to - for interviewing you is to kind of 2 - you were the OIC is our understanding on 3 August 9th, is that correct -- 4 MR. Yes. 5 MR. -- of 2019? And just to 6 kind of ask you questions related to what you 7 know about what happened on August 9th and 8 August 10th of 2019. Before starting the 9 interview, I'd like to place you under oath, 10 Lieutenantl i Can you please raise your 11 right hand. Do you swear to tell the truth and 12 nothing but the truth during this interview? 13 MR Yes, I do. 14 MR. Thank you, sir. If it's 15 something that you don't understand, just ask 16 me to rephrase and I'll try to clarify anything 17 like that. What is your current home address? 18 MR. 19 20 MR. : And what is your date of 21 birth? 22 MR. 23 MR. And what is your social 24 security number? 25 MR. EFTA00116066 8 1 MR. What is your current cell 2 phone? 3 MR. MOM 4 MR. And what is your highest 5 level of education? 6 MR. 7 MR. And where did you go to 8 high school? 9 MR. Graphic Arts in the city. 10 MR. In New York City? 11 MR. Yes, New York City. 12 MR. And what was it called. 13 MR. Graphic Communication of 14 Arts. 15 MR. Okay. Cool. Is that 16 like some kind of like -. 17 MR. It's on 49th Street and 18 10th Avenue. It was a -- 19 MR. S Like a -. 20 MR. -- advertisement high 21 school. 22 MR. : Oh, that's neat. 23 MR. Yeah. It was cool. 24 MR. This is not really to do 25 with the interview, but is that like something EFTA00116067 9 1 you get to, like -. 2 MR. Well I can draw a little 3 bit and do a little bit of graphic design 4 MR. Oh, neat. 5 -- from high school. Not 6 too much but that's what I went to high school 7 for. 8 MR. IMO. : That's neat. What did 9 you do prior to working for the BOP? 10 MR. I was in the United States 11 Army and I worked for a hotel. 12 MR. Okay. As far as being 13 with the Army, when were you in the Army? MR. MOM 14 I started in 1998. I was 15 in the National Guard and then I went active 16 duty in 2005. 17 MR. Okay. When did you - are 18 you still in the Reserves? 19 MR. No, I'm completely done 20 with the military. 21 MR. When did you get out? 22 MR. 2011. 23 MR. Was it an honorable 24 discharge? 25 MR. Yes it was. EFTA00116068 10 1 MR. : And what was your rank at 2 -. 3 MR. Corporal. 4 MR. : Corporal? And what was 5 that? E what? 6 MR. E-4. 7 MR. E-4. Thank you for your 8 service. And then you said you worked for a 9 hotel, how long did you do that? 10 MR. Before the military, I did 11 it for three years. I came back, I did it for 12 one year and then I got this job. 13 MR. Okay. So just prior to 14 being with the BOP 15 MR. Correct. 16 MR. -- you did - and what did 17 you do there? 18 MR. Banquet Steward. 19 MR. : And everything go with 20 leaving there, was everything copacetic? 21 MR. : Correct. 22 MR Okay. How long have you 23 served with the Federal Bureau of Prisons? 24 MR. Since 2014, September 21st 25 would make seven years. EFTA00116069 11 1 MR Seven years? Okay. And 2 do you know your specific enter on duty date? 3 MR. September 21, 2014. 4 MR. Thank you, sir. When did 5 you graduate from BOP training? 6 MR. 2015, April. April 2015. 7 MR. Okay. And how long have 8 you been with the MCC? 9 MR. The whole time, seven years 10 11 MR. Okay. 12 MR. in September. 13 MR. : You're here the whole 14 time. 15 MR. Correct. 16 MR. : All right. And you said 17 you're currently a Lieutenant? 18 MR. Correct. 19 MR. When were you promoted to 20 Lieutenant? 21 MR. March 1, 2020, last year. 22 MR. Okay. And what was your 23 rank or title in August of 2019? 24 MR. I was a Senior Office 25 Specialist. EFTA00116070 12 1 MR. Okay. And I have a staff 2 roster here. Here's the - it's going to be on 3 August 9th and then August 10th, it's just for 4 you to refer to, so you don't have to 5 necessarily recall. But what shift did you 6 work on August 9th and August 10th? 7 MR. So, August 10th, which that 8 should be a Saturday, I was off the weekend and 9 Friday I worked from 6:00 to 2:00 in the 10 Special Housing Unit. 11 MR. Okay. And what was your 12 position when you were in the Special Housing 13 Unit? 14 MR. I was an OIC. 15 MR. And what does OIC stand 16 for? 17 MR. The Officer in Charge. 18 MR. And what were those 19 duties and responsibilities as the OIC of the 20 SHU? 21 MR. Pretty much maintaining 22 paperwork, making sure everything is conducted 23 according to BOP policy. 24 MR. Okay. And who was your 25 supervisor? EFTA00116071 13 1 MR. ieutenant Perez. 2 MR. Lieutenant Perez? It 3 wasn't Lieutenant Rice? 4 MR. Well, actually yes, yes, 5 Lieutenant Rice, I'm sorry, yes. 6 MR. And he was the SHU 7 Lieutenant? 8 MR. Yes. 9 MR. Okay. Great. Now I'm 10 going to - we're going to keep these documents 11 in front of you because as we go through the 12 interview, I'll probably ask you about 13 different people and you can just refer to it. 14 When I do provide you - do you have an extra 15 pen? When I do provide you with documents, do 16 you mind just so that for interview purposes, 17 we - it's not to certify anything is accurate, 18 it's simply to say this is the document that I 19 showed you. So can you just like initial and 20 date on the top of each document that I show 21 you, and it doesn't mean, go through the 22 packet, it's just the top page. So, this one 23 for instance, is the daily assignment roster 24 for Saturday, August 10, 2019 and this one is 25 the daily assignment roster for Friday, August EFTA00116072 14 1 9, 2019. And again, it's simply to - you don't 2 have to do each page, it's just -. 3 MR You're not attesting to it. 4 MR. Yeah. 5 MR. It's just 6 MR. Yeah. 7 MR. It's just 8 MR. You're not attesting that 9 it's certified or anything, you know, that it's 10 accurate. It's just to say that these are the 11 documents that we looked at. 12 MR. : Yes, sir. 13 MR. Would you mind - thank 14 you for initialing. You mind just putting the 15 date? It's 7/14 -- 16 MR. 14. 17 MR. -- 2021. Thank you, sir. 18 All right. Are you familiar with inmate 19 Jeffrey Epstein? 20 MR. Yes. 21 MR. Did you work in the SHU 22 while Epstein was assigned to the SHU in July 23 and August of 2019? 24 MR. Yes. 25 MR. During that time, did EFTA00116073 15 1 2 3 4 Epstein have a cell mate? MR. es, he did. MR. Do you recall who that cell mate was? 5 MR. I don't know, it was a 6 Spanish guy, I don't remember his name exactly. 7 MR. So I'm assuming you're 8 talking about the second of the two inmates. 9 MR. The first one was 10 Tartaglione. The second one maybe Perez. 11 MR. Reyes, does that sound 12 MR. eyes, yes. 13 MR. Okay. So -. 14 MR. older gentleman -- 15 MR. Okay. 16 MR. - walked with a cane. 17 MR. And do you know if there 18 was a specific reason why those cell mates were 19 assigned to Epstein? 20 MR. I think Psychology said 21 22 it's just their category, they're older, same age. 23 MR. Okay. So are you aware, 24 since you said Psychology, did Psychology say 25 that Epstein was required to have a cell mate? EFTA00116074 16 1 MR. Well, we always practice, 2 if somebody comes off of suicide watch, they 3 have to go with a cell mate until Psychology 4 clears them to be alone. 5 MR Okay. 6 MR. But whoever has history of 7 trying to commit suicide has to go with a 8 bunkie. 9 MR Okay. So were you aware 10 that Epstein had attempted to commit suicide on 11 July 23rd -- 12 MR. Yes, I was. 13 MR. -- of 2019? Were you one 14 of the responding officers? 15 MR. o, I was not. 16 MR. Do you know what 17 transpired on that date? 18 MR. No, I do not. 19 MR. Did you hear anything 20 about him either trying to commit suicide or 21 potentially that Tartaglione attempted to harm 22 him? 23 MR. I saw that in the papers 24 that Tartaglione wanted to harm him but all I 25 heard that he was trying to commit suicide. EFTA00116075 17 1 MR. All right, do you - is 2 there any reason for you to believe that 3 Tartaglione was trying to harm him? 4 MR. o. 5 MR. No? 6 MR. hey always got along. 7 MR. They did always get 8 along? 9 MR. Yes, sir. They'd always 10 get along. 11 MR Okay. And then you said, 12 following that attempt, he was placed - Epstein 13 was placed on suicide watch? 14 MR. Yes, with being watched on 15 the second floor. 16 MR. Okay. And what floor is 17 the SHU on? 18 MR. 9th. 19 MR. The 9th floor. Okay. So 20 the suicide watch and the psychological 21 observation area is all on the 2nd floor? 22 MR. orrect. 23 MR. All right. Was he 24 removed from suicide watch? 25 MR. Yes he was, afterwards. EFTA00116076 18 1 MR. Do you have any idea 2 around when that was? 3 MR. That I do not remember. 4 MR. Does July 30, 2019 sound 5 about right? 6 MR wouldn't -. 7 MR Or, I guess I should ask 8 this question first. Is there a difference 9 between suicide watch and psychological 10 observation? 11 MR. Well, psychological 12 observation, you would have all your clothes 13 on. 14 MR. Okay. 15 MR. Suicide watch is because 16 you attempted suicide so you're going to be 17 with a smock, in the nude, just a suicide smock 18 and some booties 19 MR. Okay. 20 MR. - with nothing else. 21 MR. And do you know if the 22 entire time that Epstein was on the 2nd floor 23 outside of the SHU, was he in the suicide watch 24 or was he both suicide watch and psychological? 25 MR. If I'm not mistaken, he was EFTA00116077 19 1 on suicide watch the whole time. 2 MR. Okay. So you believe 3 that he was actually -- 4 MR. Yes. 5 MR. -- in a smock the whole 6 time. 7 MR. orrect. 8 MR. Okay. And what does 9 suicide watch entail? 10 MR. You're being watched 24 11 hours. 12 MR By who? 13 MR By an inmate or staff. 14 MR Okay. And do you know if 15 Epstein was watched by either or, or both. 16 MR. I think he was just by 17 inmates, if I'm not mistaken. 18 MR. : Inmates and what is the 19 inmates' responsibilities while they're 20 watching him? 21 MR. : Well, they constantly 22 observe you in every - they got to annotate 23 every rounds that they do, or every 15 minutes 24 they write down what the inmate is doing. 25 MR. Okay. Did you ever hear EFTA00116078 20 1 of any issues or anything while he was on 2 there? 3 MR 4 MRS No? 5 MR 6 MR And what's the 7 difference, what does the psychological 8 observation? 9 MR. Psychological observation 10 is pretty much is - you're in the same place, 11 just with your clothes on. 12 MR. : And same, you have an 13 inmate (Indiscernible *00:12:35) -. 14 MR.-: You have an inmate watching 15 you at all times, yes. 16 MR. Okay. So for both, it's 17 the same, just the clothes is the only 18 difference? 19 MR. Correct. 20 MR. Okay. Did you receive 21 instructions from anyone regarding Epstein 22 being assigned a cell mate after he came back 23 from the 2nd floor and placed back into the 24 SHU? 25 MR. No. I just did it on my EFTA00116079 21 1 own. 2 MR. : Okay. So no one - you 3 don't recall ever being instructed -- 4 MR. o I -. 5 MR. -- to place him with -. 6 MR. don't recall getting a 7 phone call saying, "Put him -" - like I said 8 before, it's we practice, if you're leaving the 9 2nd floor, you automatically go upstairs with a 10 cell mate. 11 MR. : Okay. So, did you ever 12 receive any kind of information from either 13 Lieutenant Rice or Psychology saying that 14 Epstein was required to be housed with a cell 15 mate? 16 MR. : Well we knew already and 17 Lieutenant Rice pretty much said, "G, don't 18 forget to put him with a bunkie." 19 MR. : Okay. Did you - and I 20 don't believe that you received it directly, 21 but did you ever see this email? It says - 22 sorry, let me see, it's who is 23 that? 24 MR. That used to - she was a 25 Psychologist, one of the Psychologists in the EFTA00116080 22 1 building. 2 MR. Okay. And it says, it's 3 to "Suicide Watch/Psych Observation update." 4 It says it's dated July 30, 2019 at 12:30 p.m. 5 The subject of the email says, "Inmate Epstein 6 is being taken off of psych observation and 7 needs to be housed with an appropriate cell 8 mate." Did you ever see that by chance? 9 MR. : No. I don't remember this. 10 MR. IMINIIIMM Okay. But you knew that 11 he was required to have a cell mate. 12 MR. Yes. 13 MR. : All right. And you said 14 Lieutenant did inform you? 15 MR. Correct. 16 MR. Okay. Did you mind just 17 -- 18 MR. Oh. 19 MR. -- initialing and dating 20 that? So you don't recall ever receiving any 21 other written -- 22 MR. No. 23 MR. -- communication 24 regarding the matter? After Lieutenant 25 spoke with you about him being required to have EFTA00116081 23 1 a cell mate, did you communicate that 2 requirement to anyone else in the SHU? 3 MR. Just in SHU. "All right 4 guys, he needs a bunkie." 5 MR. Okay. And was that 6 something that you communicated only on the 7 date he came back on July 30 or would that be 8 something that you all would communicate 9 throughout his stay in the SHU? 10 MR. Well, we constantly just 11 made sure since he was a high-profile inmate 12 and we actually placed him right on the top 13 tier so where we can see - where the OIC bubble 14 was right on top just because of that reason 15 and we, "Hey, you got a bunkie?" "Yes." 16 Because he was always going to his legal visits 17 pretty much the whole day. 18 MR. : Right. 19 MR. When he came back, made 20 sure he had a bunkie. 21 MR. a: Okay. And would you also 22 work then that night watch in the SHU? 23 MR as I working? 24 MR Not that day, but in 25 between July 30th and August 9th, do you know EFTA00116082 24 1 if you would have worked that night watch? 2 MR. I'm pretty sure I did. I'm 3 pretty sure I did. And all my overtime was 4 always in the SHU. 5 MR. Okay. And do you believe 6 then that everyone who worked in the SHU would 7 have known that inmate Epstein was required to 8 have a cell mate? 9 MR. Yes. 10 MR. All right. And what 11 makes you believe that? 12 MR. : It's part of pretty much 13 the SHU training. 14 MR. Okay. When you say, "SHU 15 training," what training are you referring to 16 and what was taught? 17 MR. Special Housing Unit 18 training is, once again, the policy of what to 19 do in Special Housing Unit, how to conduct 20 rounds, how to deal with an inmate that is 21 coming off of suicide watch and part of our SHU 22 training is the psychologists speaking to us 23 and breaking down and what to do when an inmate 24 comes off suicide watch, what signs to look for 25 and pretty much making sure you're doing the EFTA00116083 25 1 right thing when somebody comes up from suicide 2 watch. 3 MR. Okay. So is there any 4 way that people would know that if they didn't 5 attend the quarterly - you're talking about the 6 quarterly SHU training? 7 MR. orrect. 8 MR. Is there any way that 9 people that didn't - like people on overtime 10 shifts or people that didn't actually get to 11 take that quarterly training yet, would know 12 that Epstein was required to have a cell mate? 13 No, they would not know 14 that. 15 MR. They would not know? 16 MR. hey would not know that. 17 MR. And did you communicate 18 with people though? I know you're saying that 19 they knew based upon training, but did you ever 20 communicate with the people working in the SHU 21 that Epstein was required to have a bunk mate 22 at all times? 23 MR. Well, whoever worked in SHU 24 would pass it down, "Hey, make sure this guy 25 stays with -" - whether it's him or anybody EFTA00116084 26 1 else, I know we're talking specifically about 2 him, but whether it was him or anybody else, we 3 all would say, "Hey, make sure this guy has a 4 bunkie." 5 MR. : Okay. But you can't 6 remember any specific conversations? 7 MR. No. No. 8 MR. Okay. Were there any 9 signs hanging up anywhere in the SHU that said 10 Epstein was required to have a cell mate? 11 MR. No. 12 MR. All right. 13 MR. No that I -. 14 MR. So someone mentioned that 15 -. 16 MR. So, I put one of my own - 17 it was in bright orange paper. I put it next 18 to the computer. It's nothing like from BOP or 19 anything, it was just something between us, 20 that said, "Make sure rounds are conducted and 21 he has a bunkie at all times." Yes, that was 22 me. 23 MR. Okay. So this document 24 I'm showing, it says, "Mandatory rounds must be 25 conducted every 30 minutes on Epstein, as per EFTA00116085 27 1 God." This is what you're referring to? And 2 where was this hanging? 3 MR. On the SHU OIC computer, 4 right next to it. 5 MR. All right. Awesome. So 6 I was assuming that this might be a confusion, 7 but someone mentioned that there was also a 8 color document saying that Epstein was required 9 to have a cell mate. Was that ever on the OIC 10 computer or anywhere else? 11 MR. IIIIIIIII You know what? If it was 12 color, it was - I probably made it because we 13 always had a stack of orange, that was my 14 telling everybody, "Do what you're supposed to 15 do." 16 MR. Okay. 17 MR. But I did this, I know, 18 because I typed it up and I put it up there. 19 Now the -. 20 MR. So this is the one that 21 you remember is the -- 22 MR. Correct. 23 MR. -- one I just showed you. 24 MR. Correct. 25 MR. Okay. And that was on EFTA00116086 28 1 the OIC's computer? 2 MR. There's two computers on 3 the desk. If you see, it's right like you 4 can't miss it. 5 MR. And is -. 6 MR. It's bright orange paper 7 and black lettering. 8 MR. And is that where 9 everybody that works in the SHU, are they all 10 in that same area? 11 MR. Everybody goes to that 12 station. 13 MR. So everybody that was in 14 the SHU or ever worked in the SHU would have 15 seen at least that document that you created? 16 MR es. 17 MR And do you remember when 18 that document was created? 19 MR. I think I did that maybe a 20 couple of weeks after he came upstairs. 21 MR. And is that initially or 22 after he came back from suicide watch? 23 MR. The first time he went 24 down, when he came up the second time. 25 MR. Okay. EFTA00116087 29 1 MR. 'hat - when he was 2 MR. Sometime after July 30th 3 but prior to August 9th -- 4 MR. Correct. 5 MR. -- it would have been up. 6 MR. Correct. 7 MR. Okay. You can't remember 8 - sometime between there. Definitely prior to 9 August 9th. 10 MR. Definitely prior to him 11 coming - or that happening. 12 MR. And do you believe it was 13 at least a few days prior to that as well? 14 MR. : It think it was maybe as 15 soon as he came upstairs from suicide watch -- 16 MR. Okay. 17 MR. - I put it up there. 18 MR. Okay. But certainly 19 prior to August 9, 2019. 20 MR. Correct, yes. 21 MR. Okay. 22 MR. Yes. 23 MR. And you do not require 24 any signs identifying Epstein's cell mate 25 requirement? Was there ever anything on EFTA00116088 30 1 Epstein's cell door, even on July 30th or 2 anything like that? Do you recall anything 3 like that? 4 MRIIIIIIIIIII I mean, we had orange paper 5 hanging all over the place, but I don't recall 6 one saying he has to have a bunkie. 7 MR. Okay. 8 MR. e practice, you come up 9 from suicide watch, you get a bunkie 10 MR. 11 MR. -- no matter who you are. 12 MR Got a question here. 13 MR. Yeah, go ahead. 14 MR As for God, is that referring 15 to somebody or God? 16 MR. That's just, you know, 17 okay, God is watching us, we got to do the 18 right thing. 19 MR. Okay. 20 MR. So you're referring to 21 this is the question I had before. Are you 22 referring to God himself, not calling the 23 Warden or the Captain or somebody God? 24 MR. Oh no, just God himself. 25 MR. All right. So that's the : All right. EFTA00116089 31 1 one sign you can remember that was up -- 2 MR Yes. 3 MR -- requiring rounds but 4 nothing to do with a cell mate. 5 MR. Nothing to do with a cell 6 mate. 7 MR. All right. What is the 8 hot list? 9 The hot list is inmates 10 that have tried to commit suicide in the past 11 and that's posted in Special Housing Unit. 12 MR. Okay. And where in the 13 Special Housing Unit would have been the hot 14 list located on August 9th? 15 MR. Right next to the second 16 phone, next to the cage where we keep MIR 17 (Phonetic Sp. *00:20:31), camera, radio 18 holders. 19 MR. •: Would it have been like 20 on the desk or behind the desk or -. 21 MR 11, we have a hot list, 22 it's next to the phone, that's where it's at. 23 It's a yellow - or it was a yellow binder. 24 MR. Is there only one phone 25 in the SHU? EFTA00116090 32 1 MR. here's three. 2 MR. Three? 3 MR. hree. 4 MR. So one of the phones it 5 was next to? 6 MR. 7 MR. Was it hanging on the 8 wall? 9 MR. es. 10 MR. Okay. Is it like some 11 kind of a bulletin board type of area or like - 12 . 13 MR. It's a - we have our cage 14 with some of the equipment -- 15 MR. Okay. 16 MR. -- and the phone right next 17 to it, it's right in between. That's where it 18 was before. 19 MR. And do you know if 20 Epstein was listed on the hot list on or around 21 August 9th? 22 MR. If I'm not mistaken, I 23 think he was. 24 MR. : Okay. 25 MR. I think he was. Correct. EFTA00116091 33 1 MR. Would have he been listed 2 on the hot list when he came back on July 30? 3 MR. es. 4 MR. Okay. And how do people 5 get placed on - if he was on July 30th, when 6 would an inmate be removed from that hot list? 7 MR. Well, that's Psychology 8 once their finished with their whatever they 9 do, reports or evaluations on the inmate. 10 MR. So how does that work? 11 Is it they - an inmate is removed from the hot 12 list if they're no longer a threat of 13 committing suicide? 14 MR. think that's what it is. 15 MR. Okay. 16 MR. never really looked into 17 that one 18 MR. And does Epstein - I 19 mean, not does Epstein, does Psychology, are 20 they the ones that provide you the hot list? 21 MR. Yes. 22 MR. Who do they provide it 23 to? 24 MR. They usually come upstairs 25 and change it on their own. EFTA00116092 34 1 MR. So they actually post it 2 on the -- 3 MR. Yes. 4 MR. -- board themselves? 5 MR. Yes. 6 MR. Does everybody that works 7 in the SHU know what the hot list is? 8 MR. Yes. 9 MR. Z: Do you believe 10 MR. It's part of our training. 11 MR. Z: As a -. 12 MR. Not just the SHU training, 13 but that's like when you start working here, 14 everybody should know that that's - when 15 Psychology Department comes to see you, they 16 make you - or they tell you to be aware of the 17 hot list. 18 MR. Okay. That's a good 19 point. On your annual training that you take 20 at the MCC, would that hot list information be 21 provided during that training? 22 MR. Yes, it should. 23 MR. What about the training 24 that we talked about previously when we talked 25 - EFTA00116093 35 1 MR. The SHU training? 2 MR. Yes. 3 MR. That definitely is. 4 MR. And in the annual? 5 MR. Yes. 6 MR. So, in the annual, the 7 training that you said, you know, we talked 8 about of, they're not in the SHU training, they 9 might not have gotten it, that same information 10 would have been passed along during the annual 11 training? 12 MR. Yes. 13 MR. And that's with 14 Psychology letting people know that people -. 15 MR. Psychology does their part 16 on the training in their class time and they 17 should have or they should because I think 18 that's what they always do. Psychology - any 19 training, everybody takes it and you go over 20 everything pretty much from when you first 21 start -- 22 MR. Okay. 23 MR. -- on what to do as an 24 officer. 25 MR. So, point being, if EFTA00116094 36 1 people come off of suicide watch and are placed 2 in somewhere like the SHU, during annual 3 training, they tell everybody that takes that 4 training that they need to. 5 MR. Make sure you go over the 6 hot list and deal with who is on it -- 7 MR. And who was your 8 MR. - and if you feel somebody 9 should be on it, just pass it down to 10 Psychology. 11 MR. To make sure those people 12 have cell mates? 13 MR. orrect. 14 MR. Okay. And is that right, 15 if you're on the hot list, unless you have some 16 kind of requirement next to you that you can't 17 be housed with a bunkie, you're supposed to 18 housed with a cell mate? 19 MR. 20 MR. es, yes. Okay. And is that kind 21 of the purpose of it, to make sure that you're 22 knowing that they're not only suicidal but 23 they're also required to have a cell mate? 24 MR Correct. 25 MR : Okay. EFTA00116095 37 1 MR. In comparison to the OIC 2 desk, where would that hot list be? Like if 3 you're looking at the desk right now, where -. 4 MR. So, if I'm sitting on the 5 desk, it should be about not even 10 feet away 6 from me on the next phone. 7 MR. Okay. 8 MR. : And do the other COs that 9 worked in the SHU know that everyone on the hot 10 list was required to have a cell mate? 11 MR. They should. 12 MR. : They should, okay. 13 MR. There's a lot of "shoulds" 14 in this building. 15 MR. Who replaced you in the 16 SHU on August 9, 2019? Do you remember? And 17 here's the -. 18 MR. It should have been Officer 19 and Officer 20 MR. MATULEWICZ: Okay. Do you need to 21 refer to this at all or you just know that from 22 memory? 23 MR. I think I'm right. 24 MR. And I think you're right 25 as well, but I just want to make sure that -. EFTA00116096 38 1 MR. Memory is so far so good, 2 yes. 3 MR. So you're looking at the 4 daily assigned roster. 5 MRIIIIIIIIII: Yeah, it's and 6 7 MR. Anyone else? 8 MR. No, I only saw those two. 9 MR. Was there Joiner also? 10 Did he replace you? 11 MR. So I left that 2:00. 12 MR. : Okay. 13 MR. I knew was coming 14 because that's usually my relief and was 15 a 2:00 to 10:00 officer. 16 MR. Okay. And where did 17 fit in on this? Do you know? 18 MR. He was probably doing 19 just coming in. 20 MR. kay. So we have a memo. 21 Is this - do you - this memo, it says it's from 22 you and it's dated August 12, 2019. Is this - 23 do you recognize that memo? 24 MR No, that's me. 25 MR Okay. And did you create EFTA00116097 39 1 that memo? 2 MR. Yes, I did. 3 MR. All right. Great. So 4 what it says is, it says it's to the Warden. 5 How do you pronounce the Warden's last 6 MR. 7 MR. It says, "On 8 Friday, August 9, 2019 at approximately 1:50 9 p.m., I, SOS passed on to oncoming 10 staff member Officer and present shift 11 staff SOS and Officer that inmate 12 Reyes, number 85993-054, was going WAS and 13 possibly may not return. Also that inmate 14 Epstein will be needing a cell mate upon 15 arrival from his attorney visit." What does 16 WAS mean? 17 MR. With all belongings. 18 MR. : Okay. And is that -. 19 MR. That's when you leave the 20 institution. 21 MR Okay. Great. And do you 22 recall actually passing that information on to 23 24 MR. I - 25 probably did speak to them, but in -. EFTA00116098 40 1 MR. Okay. So I guess I 2 should ask, the way that I interpreted this was 3 that you told-but those other people were 4 present in the SHU. Did you have a 5 conversation then, you believe, with both 6 and 7 MR. EMI: I had a conversation with 8 because he relieved me at 2 o'clock. 9 MR. Okay. 10 MR. And I told him, "Make sure 11 you pass it down to - but I don't - I know I 12 spoke t. because I was still town driver 13 and I saw him outside, but , I don't 14 remember seeing him. 15 MR Okay. What do you 16 remember - what specifically do you recall 17 saying to 18 MR. Like, "Reyes is going, he's 19 leaving, so make sure Epstein gets a bunkie." 20 MR. : And what do you remember 21 specifically telling to 22 MR. Same thing. "Hey, you 23 know, I think Reyes is going to be gone, 24 Epstein needs a bunkie." "All right. 25 MR. Okay. And again, who is EFTA00116099 41 1 inmate Efrain Reyes? 2 MR. That was Epstein's bunkie. 3 MR. Up until August 9th it 4 sounds like? 5 MR. orrect. 6 MR. Okay. And do you know 7 how he was selected to be Epstein's cell mate? 8 MR. Through, again, Psychology 9 recommends, "Oh, they're about the same age. 10 They both are pretty much have -" - not similar 11 charges, but, "This guy is an older man. This 12 guy has a cane. There's not going to be any 13 problems, we should put them in together." 14 MR. Are you aware of anything 15 like the Captain and the Warden and even the 16 Regional Director going through and vetting 17 Epstein's cell mates or are you unaware of 18 that? 19 MR o. 20 MR All right. So, you're 21 understanding was that Psychology made that 22 determination? 23 MR Correct. 24 MR Okay. When did you 25 become aware that inmate Efrain Reyes was EFTA00116100 42 1 likely to be removed from the MCC on August 9, 2 2019? 3 MR. When I walked both of them 4 to the door. 5 MR. And what time would that 6 have been? 7 MR. I would say - because R&D 8 usually starts calling people down around 9 9 o'clock, 9:00, 9:30, and that's pretty much 10 around the same time that Epstein is walking to 11 go to his legal visit. 12 MR. : Okay. 13 MR. I won't - well, it's not me 14 alone with the two of them, but we walked 15 towards the door and I told him he needed - he 16 was going to get a bunkie. 17 18 both together? 19 MR 20 MR 21 22 23 24 25 Reyes wasn't coming back or likely -. So were Reyes and Epstein orrect. And you're the one who was - one of you that was escorting them? MR. Yes. MR. And at that point, at 9:00 a.m. on August 9th, you did know that EFTA00116101 43 1 MR. I knew he was going 2 downstairs. So, WAB means with all belongings. 3 You go to R&D, you're supposed to leave within 4 probably an hour and not come back, but there 5 has been times that they go downstairs with all 6 their stuff and they come right back upstairs. 7 Whether it's to SHU or to a unit. 8 MR Okay. 9 MR So -. 10 MR So, are you confident 11 that Reyes was actually WAB at 9:00 a.m.? 12 MR. No, I know I was walking 13 him downstairs to leave the building at that 14 time. 15 MR. Was he with all 16 belongings at that time? 17 MR. Yes. 18 MR. So he -- 19 MR. Yes. 20 MR. -- already - he did have 21 his belongings? 22 MR. He did have his belongings. 23 He was ready to go. But again, it's not always 24 guaranteed that once we're taking downstairs, 25 even though they call us and tell us, "Oh, this EFTA00116102 44 1 guy is going WAB," they just leave. 2 MR. : Okay. 3 MR. There's been a lot of times 4 that we take them downstairs, two, three hours 5 later, something happened, "You know what? Go 6 right back upstairs, you leave tomorrow or the 7 next day." 8 MR. Okay. And does R&D stand 9 for Receiving and Discharging? 10 MR. Yes. 11 MR. Okay. What floor is that 12 on? 13 MR. hat's on the 3rd floor. 14 MR. Okay. Do you get a - let 15 me go through this. So, I got a Lieutenant log 16 and a daily log. So let me find those. So 17 here's the - this top report, the daily 18 activity report is from August 10, 2019 and 19 behind it, it has the Lieutenant's log from 20 Friday, August 9, 2019. So that's what I'm 21 going to refer you to and I'm going to refer 22 you specifically to where it says, "8:00 a.m.," 23 on down. It says, "According to the 24 Lieutenant's log and the daily log," so this is 25 the daily log. I think he's on the third page. EFTA00116103 45 1 It says, "Reyes was pre-removed from the SHU at 2 8:38 a.m." What does that mean? 3 MR. That's just when they put 4 him on the system that he gets downstairs. 5 MR. Does it have anything to 6 do with WAB or that he's likely not going to 7 come back? 8 MR. 9 means he left. 10 MR. That just means he left? 11 MR. es, that means he's left. 12 MR. But does that mean, like, 13 he's going to court and he's likely not going 14 to come back or it just means he left? Does it 15 have anything to do with the fact that not only 16 did he leave the building, but he's likely not 17 going to return? 18 MR. Well, that he left the 19 building and most likely he's not going to 20 return. Well, that pretty much 21 MR. Okay. And is there a 22 difference? Like what would it say if he just 23 left for a regular court date and he was going 24 to return, (Indiscernible *00:30:47)? 25 MR. Well, it would say, EFTA00116104 46 1 "Court." 2 MR. Just, "Court?" 3 MR. If he was going to court, 4 it would say, "Court." 5 MR.-: It wouldn't say, "Pre- 6 remove?" 7 MR. No, it would just say, 8 "Court." 9 MR. So is, "Pre-remove," and, 10 "WAB," somewhat the same thing? 11 MR. 12 MR. orrect. Okay. So does that mean 13 that - so I've been told that there's some kind 14 of a court list that comes out either on like 15 late August 8, 2019 or early August 9, 2019 16 would have said something with WAB next to his 17 name. 18 MR. Yes. 19 MR. : What is that called? 20 MR. That's the court list that 21 we get. So when I walk in or any officer walks 22 into the unit, they would have a court list. 23 Court list would have - I'll say, "Court," or, 24 "WAB." 25 MR. All right. And I have EFTA00116105 47 1 not seen that document. Do you recall if that 2 actually said, "WAB?" 3 MR. Not that, I cannot 4 remember. 5 MR. If it - looking at the 6 Lieutenant's log as well as this daily log, the 7 fact that said, "Pre-remove," does that mean it 8 likely said, "WAB?" 9 MR. Yes. 10 MR. Okay. 11 MR. Yes. 12 MR. Because you said if it 13 said just, "Court," or, "WAB," if it said, 14 "Court," it would say, "Court," next to his 15 name 16 MR. Right. 17 MR. on this. 18 MR. Right. So, we get 19 something like this, just like this one. 20 MR. So on the daily log, 21 right? 22 MR. On the daily log, but it 23 would be like a court roster. Name, where 24 they're housed in and next to it, it would say, 25 "Court, WAB, transfer," or something like that. EFTA00116106 48 1 MR. Okay. So, but based upon 2 the fact that this says, "Pre-remove," on it. 3 Do you believe that the court list said, "WAB?" 4 MR Yes. 5 MR Okay. 6 MR Yes. That's the only 7 reason we would take them down. 8 MR. Right. 9 MR. Unless he got - he made 10 bail and all of a sudden, "Hey, we got an early 11 release." 12 MR. Okay. So when you say 13 it's the only reason you would take them down, 14 wouldn't you take them down also if he was just 15 going to court? 16 MR. orrect. 17 MR. Okay. But, I guess what 18 I'm saying is, the difference between court and 19 WAB. It's the same 20 MR 21 list and I have a court inmate and a WAB 22 inmate, they would both go to R&D and if it's 23 the same time, they would go down at the same 24 time. Then after that is where it would still 25 say the same thing. Well, one would still say, It's - well, if I have a EFTA00116107 49 1 "WAB," and the other one still would, I mean, 2 would say, "Court." Only difference is one 3 would most likely not come back. 4 MR. Okay. What about the 5 difference between what they're bringing with 6 them? Would they both be bringing all their 7 belongings? 8 MR. o, they would not. 9 MR. So a person with court 10 wouldn't have something like Reyes did. 11 MR. Correct. 12 MR. So Reyes likely had his 13 bag. 14 MR. His bag with all his items 15 and the person going out to court would most 16 likely just have a folder or legal 17 documentations that he's taking with him. 18 MR. All right. So that's 19 another reason why you believe that that 20 document would have said, "WAB?" 21 MR. Correct. 22 MR. Okay. Thank you. I'm 23 going to just so we can start getting these 24 things away from you. Do you mind just sign 25 and dating. This is the daily log. And EFTA00116108 50 1 exactly, do you know what the daily log is? 2 This one that you're initialing and dating 3 right now -- 4 MR. Well -- 5 MR. -- for August 9, 2019? 6 MR. -- this we would print out 7 just so we could know how to update the 8 Lieutenant's log 9 MR. Okay. So -. 10 MR. -- now. 11 MR. So this daily log is used 12 to update the Lieutenant's log? 13 MR. Correct. 14 MR. All right. So would have 15 this (Indiscernible *00:33:56) in daily log or 16 if we were just reviewing, it's the last page 17 which is - although it does say, "Page 1 of 18 or over here, it's this page, I'm going to 19 circle this page, 3 of 3 and I'm going to star 20 next to Reyes's name. Would this have been 21 filled for - would this have been used to fill 22 out this daily log -- 23 MR. es. 24 MR. -- after the fact? So at 25 8:38, would the Lieutenant's log have been EFTA00116109 51 1 filled out? I'm going to star next to this. 2 Or would it have been at this time where it 3 says, you know, "9:30 -- 4 MR. 9:30? 5 MR. -- at night," would have 6 been filled out? 7 MR. : No, it would have been 8 filled out according to the times that are on 9 the log. 10 MR Okay. So, the 11 Lieutenant's log is actually typically filled 12 out after these things happen? 13 MR. Yes. 14 MR. Later in the day. 15 MR. Correct. 16 MR. Not as they transpire. 17 MR. Correct. 18 MR. Okay. Good to know. 19 MR. Well, it depends on who the 20 Lieutenant is. 21 Right. Okay. 22 Sometimes they'll do it 23 throughout the day so they're not stuck doing 24 all these changes or putting all the 25 information on the Lieutenant's log, they'll EFTA00116110 52 1 just go by the time. 2 MR. : Okay. 3 MR. Like, "Oh, it's 8:30, five 4 guys left, I'm going to put it in the 5 Lieutenant's log." 6 MR. All right. 7 MR. "Five guys left." 8 MR. Is there any kind of a 9 requirement that Lieutenants need to fill out 10 the Lieutenant's log as things transpire or 11 does that not matter? 12 MR. 13 by the closing of the day, everything is up to 14 date -- 15 MR. Okay. 16 MR. and the numbers are 17 accurate 18 MR. Doesn't matter, so long as So, prior to leaving your 19 shift it's supposed to be updated? 20 MR. Yes. 21 MR. : Okay. All right. So if 22 you can just 23 MR. _I have the Lieutenant, yes. 24 MR. So if you don't mind 25 initialing and dating both of those. EFTA00116111 53 1 MR. While you're doing that, I 2 just had a question. You said that Reyes had 3 his belongings. What exactly did he have in 4 his hands? 5 MR. Think it was a bag with a 6 couple of commissary items, nothing -. 7 MR. Like a plastic bag or -. 8 MR. A plastic bag. We don't 9 give them anything else to take. 10 MR. And you also mentioned, "We," 11 who is we when you were bringing him down? 12 MR. Oh, myself and the Internal 13 Officer, which - usually if it's two inmates, 14 it has to be at two or three staff members 15 bringing them down. 16 MR. You wouldn't happen to, by 17 off that list, know who that is? 18 MR. MEI Internal was 19 (Phonetic Sp. *00:36:01) think it was 20 (Phonetic Sp. *00:36:05), it was probably him. 21 Sign and -. 22 MR. Yeah, do you mind just 23 that's your memo and wouldn't mind just 24 initialing and dating. Thank you, sir. All 25 right, so and just to sum all that up by what EFTA00116112 54 1 you just saw and by your understanding, you 2 thought Reyes was unlikely to return to the 3 MCC. 4 MR. Yes. 5 MR. Okay. And did you 6 receive any kind of call or any other 7 notification on August 19, 2019 saying that 8 Reyes was not returning to the MCC? 9 MR. I don't remember that one. 10 MR. Okay. So, when would or 11 would a notification have been made informing 12 the SHU or the MCC in general, that Reyes was 13 in fact not coming back? How does that process 14 work? 15 MR. So, if he's going WAB, we 16 already assume that he's not going to be coming 17 back and the way we confirm it is right before 18 the count, "Hey, is he coming back R&D?" "No, 19 he already left, he's gone." 20 MR. And what count is that? 21 MR. The 4:00 p.m. count. 22 MR. All right. So at 4:00 23 p.m., someone from the SHU should have 24 contacted, you said R&D? 25 MR. Yes. EFTA00116113 55 1 MR. And said, "Is he coming 2 back?" 3 MR. orrect. 4 MR. All right. Is that 5 standard operating procedure? 6 MR No, it's just pretty much 7 us confirming that he's not coming back or 8 sometimes they give us a call, "Hey, this guy 9 is not coming back." 10 MR. : Okay. 11 MR. But we already assume that 12 he's not coming back because he's going WAB. 13 MR. Okay. So do you know if 14 any notification was ever made to the SHU 15 saying that he was not in fact coming back? 16 MR. I don't remember. 17 MR. No? And there's no 18 standard operating procedure on that. 19 MR. No. 20 MR. Do you believe that there 21 should be? 22 MR. 111111'1: I mean, we should go off 23 the roster, but R&D should always, "Hey, this 24 guy is not coming back," think a courtesy call 25 EFTA00116114 56 1 MR. Okay. 2 MR. -- "This guy is not coming 3 back." 4 MR. And how is R&D made aware 5 that an inmate is not coming back? 6 MR. Once they leave here. So 7 they all go downstairs with (Indiscernible 8 *00:38:15). 9 MR. No, no, no. So would it 10 be when the other court people, inmates return 11 or would it be prior to that? So, yes, you 12 said, he's likely not coming back at 13 approximately 8:38 when you bring him down. He 14 leaves, it's kind of assumed that he's not 15 coming back. We're trying to figure out, when 16 is it known he's definitely not coming back. 17 Is that when the other inmates that went to 18 court are returned to the MCC or they return at 19 different times or how does that work? 20 MR. : Well, the inmates, they 21 don't all return together. They return 22 different times. 23 MR. Z: Okay. 24 MR. But, that's actually a good 25 question. I want to find that out too. I EFTA00116115 57 1 don't know if they're going to - they just 2 locked it. 3 MR. SIM Thank you for locking us 4 in. 5 UNIDENTIFIED MALE: Oh, sorry. 6 MR. Thank you. Okay, so 7 you're not exactly sure. 8 MR. I'm not sure how they're 9 like notified or how do they know this guy is 10 not coming back or, excuse me, this guy is not 11 coming back, this guy had got time served or 12 I'm not sure how they know that. 13 MR. Okay. Do you know 14 anything about possibly the Marshals providing 15 some kind of a court list or anything like that 16 or is this a question for R&D? 17 MR. It's a question for R&D. 18 MR. : Okay. But as far as you 19 know, either R&D would call the SHU, making the 20 notification, and if they didn't do that by the 21 4:00 p.m. count -- 22 MR. Yeah. 23 MR. -- the SHU should be 24 contacting R&D? 25 MR. Yes, to make sure he's not EFTA00116116 58 1 coming back or to make sure that he might be 2 downstairs and we've got to pick him up. 3 MR. : And is -. 4 MR. But if he returns, R&D 5 calls us. Anybody from SHU leaves, once they 6 return from wherever they went, "You've got a 7 pick up on three." 8 MR. Okay. Now as far as that 9 goes, so just walk me through like, it just 10 seems so like a non-definite, like you know 11 what I mean? You assume that he's gone. Would 12 the people that are working in the SHU at 4:00 13 even know to call R&D to find out where Reyes 14 is? 15 MR Uh-huh. 16 MR : They would? And how 17 would they know that? 18 MR. To verify the count. 19 MR. Okay. 20 MR. We count every day, so. 21 MR. So would Reyes remain on 22 the count at that point? 23 MR. If he's not returning? 24 MR. So in this case, with the 25 pre-remove, does that mean that he was removed EFTA00116117 59 1 from the count? 2 MR. Correct. 3 MR. : So, that's - so he's 4 already removed from the SHU count. How would 5 the people that are working in the SHU know to 6 check on him if he's been removed from the 7 count? 8 MR. The court list stays on top 9 of the desk, usually we have a morning court 10 MR. : Okay. 11 MR. -- and afternoon court. 12 MR. : So anybody that's on the 13 court list, you need to - that's how people 14 know every day, they call and say, "What 15 happened to these people at court?" 16 MR. Yes. 17 MR. All right. And is that 18 like at a certain time that a person calls? 19 MR. Usually 3:00, 3 o'clock, no 20 later than 3:30 because of the count. 21 MR. And on August 9th, by 22 knowing the people you said that were in there 23 and looking at this daily assignment roster, 24 are you able to determine if there's one person 25 that should have called or was their EFTA00116118 60 1 responsibility or is it -. 2 MR. Well, ■ and would 3 have called. 4 MR. : So one of those two? 5 MR. Yeah, one of those would 6 have called. 7 MR. But not 8 MR. was pretty new and 9 so was 10 MR. Okay. 11 MR. Pretty new officers, so. 12 MR. But every day that's 13 done? 14 MR. If they don't come back, 15 then we assume they're not coming back and if 16 they do come back, R&D usually tells us, "Come 17 pick up on three." 18 MR. : Okay. So the way that 19 that was answered, it sounds like you don't 20 always call based on the court list, you just 21 assume they did - if they didn't show up and RD 22 didn't call you, you 23 MR. Then, we're like, "Oh, he's 24 not coming back." 25 MR. All right. So then those EFTA00116119 61 1 two may not have called then, they just would 2 have assumed he was gone? 3 MR. : I mean, Officer got 4 good enough time in that I think he would have 5 called. 6 MR. : And would you always call 7 8 MR. I think he would have 9 called, but -. 10 MR. on those dates that 11 you worked in the SHU at that 4:00, you know, 12 around 4:00 p.m. time, would you have always 13 called? 14 MR. Myself? Yes. I usually 15 call like around 3 o'clock -- 16 MR. And is that 17 MR. - just in case I really 18 dirty, I'll go home early, so. 19 MR. Now is that like also 20 like a standard operating procedure or is that 21 just based upon whatever the people that are 22 working there want to do? 23 MR. That's whatever people 24 working there. 25 MR. : Okay. So is there any EFTA00116120 62 1 training on that that you should call at a 2 certain time? 3 MR. No. 4 MR. No? 5 MR. No. 6 MR. So that's just like 7 basically good, I guess, logistics and good -- 8 MR. Yes. 9 MR. record keeping. Were 10 you ever instructed on what action should be 11 taken if Reyes, who was assigned to Epstein as 12 a cell mate, was removed from the institution? 13 MR. If anybody, not only 14 Epstein, loses a bunkie, and he was already on 15 suicide watch, then that's pretty much our 16 training. If he returned from suicide watch, 17 he needs a bunkie. If he has a bunkie and the 18 bunkie leaves, we get him another one. 19 MR. n Okay. Okay, so in this 20 case then, it was Reyes was likely to have been 21 removed from the institution. What actions 22 should have been taken to replace Reyes and 23 when should have they been taken? MR' 24 Well, as soon as it was 25 verified or confirmed that he left the EFTA00116121 63 1 building, and Epstein was coming up from his 2 attorney visit, which was probably around 8:00 3 because that's the last, like the last call on 4 attorney conference, last legal visit has to be 5 out of the legal department by 8 o'clock. So, 6 as soon as we find out that - if Reyes wasn't 7 there for the 4 o'clock count, it should have 8 been, "Okay, let's find Epstein another bunkie 9 so by the time he comes upstairs, he has one 10 already." 11 MR. Okay. So based upon your 12 conversations with at least and you 13 believe as well as should have they at 14 the 4:00 p.m. count started making some 15 notifications or started replacing Reyes? 16 MR. Oh, definitely. 17 Definitely. 18 MR. So was it their two 19 their - do you believe it was their, then, 20 responsibility to replace Reyes? 21 MR. I think it was everybody's 22 responsibility. They should have notified 23 somebody. 24 MR. Okay. Did you have any 25 communica- let me just go in order so I don't EFTA00116122 64 1 get - so, let me just make sure I understand. 2 So at 4:00 p.m., they should have been making 3 some notifications or at least requesting 4 information on Reyes's location, correct? 5 MR. 1 Correct. 6 MR. By 8:00 p.m., when 7 Epstein returned from attorney conference, 8 you're saying at least by that time, that's 9 when a new cell mate should have been assigned 10 or -. 11 MR orrect. 12 MR Okay. And who was 13 responsible for assigning Epstein with a new 14 cell mate? 15 MR. So, anyone in SHU could do 16 it. Just got to make sure he doesn't have any 17 separations from another inmate. But, Epstein, 18 when he came to the building was a big deal to 19 everybody, so everybody wants to be involved. 20 So I think they should just notify whoever it 21 was, the Lieutenant, and let the Lieutenant ask 22 around or speak to Psychology who you recommend 23 to be his bunkie. 24 MR. Okay. And so, being that 25 Epstein was a big deal and people wanted to be EFTA00116123 65 1 involved, when should that notification had 2 been made? 3 MR. As soon as they found out 4 he wasn't coming back. 5 MR So once it was verified 6 and so-. 7 MR. That he's not coming back, 8 yes. 9 MR. So at approximately 4:00 10 p.m.? 11 MR. 4:00 p.m. 12 MR. Okay. After Reyes left 13 for court, should you have begun a process for 14 an inmate or you or whoever else was working in 15 the SHU, should you began that process for a 16 new selected inmate for Epstein? 17 MR. Well, again, I assumed he 18 was not coming back, I wasn't sure he wasn't 19 coming back. 20 MR. Okay. So -. 21 MR. And by the time I left, he 22 still had another - he still had about an hour 23 and a half to come back if he was coming back. 24 MR. Okay. So, by the time 25 you left, there was still a possibility that EFTA00116124 66 1 MR. That he could come back. 2 MR. Okay. 3 MR. Yes. 4 MR. Did you make any 5 notifications to anyone aside from Illilland 6 that Reyes was Epstein's cell mate and 7 he was likely not coming back? 8 MR don't remember that. 9 MR Do you remember if you, 10 you know, communicated with any of the 11 Lieutenants? 12 MR. I don't even remember who - 13 which Lieutenant was on. 14 MR. You got the daily roster. 15 MR. But -. 16 MR. Think it was and 17- 18 MR. I actually - I say I know I 19 remember Lieutenant So I think I - see, 20 I don't want to say I did tell somebody, but I 21 was always kind of anal working the SHU, so I 22 probably said, "Look, he might not be coming 23 back," and when Reyes left, he leave through 24 the 3rd floor which everybody in the 25 Lieutenant's office sees him and R&D sees him EFTA00116125 67 1 and at the same time, I told Epstein, "You're 2 getting a bunkie," he's like, "No, I'm good." 3 And Reyes was like, "No, he's going to make 4 sure you get a bunkie." Because -. 5 MR. Can you repeat that last 6 thing? What's this? 7 MR. So, when I walked them 8 towards the door, said, "Oh, Reyes, you might 9 be leaving today." "Yeah, G. and you're going 10 to get a bunkie." Epstein is like, "No, I'm 11 good." Said, "No, you're going to get a 12 bunkie," and Reyes is like, "Yeah," you know, 13 "He does this by the book, you're going to get 14 a bunkie later if I leave or if I don't come 15 back." 16 MR. I got you. So the way 17 you answered the question before, it sounded 18 like you may have told or you 19 just don't specifically recall? 20 MR. I do not recall. 21 MR. Like -. 22 MR. Again, we brought them 23 down, so 24 MR. Okay. No, no, no, I'm 25 talking about like, - or let me - I'll just go EFTA00116126 68 1 in order. Do you remember at 9:00 a.m. who 2 would have been the Activities and Operations 3 Lieutenant? 4 MR. Well, Operations comes in 5 at 6 o'clock in the morning. 6 MR. Okay. And who on this 7 date would have been that person? 8 MR. Lieutenant and 9 came in at 4 o'clock. 10 MR. So III'. was Activities 11 though, right? 12 MR. Correct. At 6:00 and then 13 Lieutenant was at 8:00. 14 MR. Okay. So at 6:00 a.m., 15 would have been in? 16 MR. Yes, 6:00 to 2:00 and 17 Lieutenant 8:00 to 4:00. 18 MR. : Okay. So at that 9 19 o'clock time when you're bringing them down, 20 would you 21 MR. They both should have been 22 there. 23 MR. -- would have you been in 24 any interactions with Lieutenants at that 25 point? EFTA00116127 69 1 MR. Yes, because they usually 2 come upstairs to feed. 3 MR. Okay. And do you 4 remember if specifically if specifically if you 5 can place yourself back in that day, I know 6 it's a long time ago, but being that that was 7 the day before Epstein died, can you remember 8 at all thinking about any conversations you had 9 with them? 10 MR. I remember seeing both of 11 them. 12 MR. : Both - you remember 13 MR. Both - both -- 14 MR. seeing both 15 MR. -- Lieutenant and 16 Lieutenant that day, but (Indiscernible 17 *00:49:03) when - I'm sure, but I'm not a 18 hundred percent positive that I did tell him -- 19 MR. : Okay. 20 MR. -- "Hey," specifically, 21 "Reyes might be leaving, you got to get Epstein 22 a bunkie." 23 MR. : So you believe it's more 24 likely than not that you mentioned it to the 25 Lieutenants. EFTA00116128 70 1 MR. Correct. 2 MR. : Okay. 3 MR. There you go. 4 MR. : But you just can't 5 specifically recall. 6 MR. Yes. 7 MR. Okay. And do you believe 8 it was more likely or not that you told one of 9 those Lieutenants over another? 10 MR. I talked to both of them 11 and I think I probably just told Lieutenant 12 and then he passed it down or vice versa. 13 MR. Okay. And did you have 14 more of a friendly relationship with one or the 15 other? 16 MR No, just -- 17 MR No? 18 MR -- even both of them. 19 MR And do you remember 20 having any conversations with R&D on August 21 9th? 22 MR. No. 23 MR. No? So when you would 24 drop the inmates off, was there any kind of 25 conversations or EFTA00116129 71 1 MR. 2 good?" "Yeah, okay." 3 MR. Okay. 4 MR. ah. Go right back 5 upstairs. 6 MR. And do you know when it 7 was known that Reyes wasn't returning to the 8 MCC? 9 MR. o. 10 MR. Even after the fact? 11 Like after August 9th, you never learned that? 12 MR. No, I never -. 13 MR. There wasn't any kind of 14 like little internal investigation trying to 15 figure out what that was all about? 16 MR. No. I -. 17 MR. But under normal 18 circumstances, you're saying, either R&D would 19 call and let that be known or at the 4:00 p.m. 20 count, the SHU staff should have called down to 21 find out -- 22 MR. : Yeah. 23 MR. -- based upon the court 24 list -- 25 MR. Usually -- Yeah, "What's up? You guys EFTA00116130 72 1 MR. -- that was in front of 2 them? 3 MR. -- we do just to make sure 4 this guy is not coming back or R&D would tell 5 us. 6 MR. Okay. And you're saying 7 that that's normal but certainly by 8:00 p.m. 8 when Epstein came back from attorney client, 9 his attorney visit, they should have known? 10 MR. Correct. 11 MR. Okay. And who - can you, 12 by referring to this roster, can you tell me 13 who was working at 8:00 p.m.? 14 MR. 8:00 p.m., the people that 15 were working were and 16 MR. Z: Was Noel also? 17 MR. And - well, the evening 18 watch, Noel, and 19 MR. So at 8:00 p.m., were all 20 those people on? 21 MR. No. because he 22 leaves at 10:00, Noel, she does 4:00 to 12:00, 23 4:00 to 12:00. 24 MR. Okay. And do you believe 25 all of those people would have known - those EFTA00116131 73 1 three people that you just listed, would have 2 they known that Epstein was required to have a 3 cell mate? 4 MR. Well, the one that most 5 likely should have known was because he's 6 worked SHU before. Noel worked SHU once in a 7 while and he wasn't even in the SHU 8 department. 9 MR. : Okay. So certainly 10 would have known and Noel should have? 11 MR. Yes. 12 MR. ould go either 13 way? 14 MR. Either way. 15 MR. Okay. And what action 16 should have they taken? Once they bring 17 Epstein back to the cell, they notice they're 18 putting Epstein - would they know when they 19 brought Epstein back to his cell that Epstein 20 was alone in that cell? 21 MR. Yes. 22 MR. : And how would they know 23 that? 24 MR. Well, first we have name 25 tags on the door. Usually when the inmate EFTA00116132 74 1 leaves, we remove the name tag. And of course 2 -- 3 MR. Can you silence that? 4 MR. -- the sheets should not 5 have been on the bed. 6 MR. So Reyes's sheets should 7 have been removed? 8 MR. Correct. 9 MR. Do you know if they were? 10 MR. I don't remember. 11 MR. And what time should 12 those sheets be removed? 13 MR. Well, he's not coming back, 14 let's get them. 15 MR. So sometime between 4:00 16 p.m. and -. 17 MR. And 8 o'clock. 18 MR. : Okay. And then, is that 19 - is it - are they ever removed when someone is 20 WAB? 21 MR. Yes. When, so, again, WAB, 22 with all belongings, everything should come out 23 with you when you're WAB. 24 MR. So do those linens then 25 (Indiscernible *00:53:10)? EFTA00116133 75 1 MR. Yes. 2 MR. Do you know if they did 3 for Reyes that day? 4 MR. No, I don't remember that. 5 MR. Okay. And is that like a 6 policy thing? 7 MR. You got to return your 8 linen. 9 MR. : Okay. 10 MR. I don't think it's in 11 policy that I know of. 12 MR. All right. So, they 13 should have been removed when Reyes left, but 14 you don't know if they were? 15 MR. Correct. 16 MR. And then they certainly 17 should have been removed once it was verified 18 that Reyes wasn't coming back? 19 MR. Yes. 20 MR. And that verification 21 would have been made at either 4:00 p.m. or 22 certainly by 8:00 p.m. 23 MR. Yes. 24 MR. Okay. Did you conduct 25 any counts or rounds in the SHU during your EFTA00116134 76 1 shift on August 9th? 2 MR. No. 3 MR. Rounds? 4 MR. Well, rounds, yes. Not 5 counts. 6 MR. Okay. So, sorry, I said 7 counts or rounds. 8 MR. Oh. 9 MR. So you did conduct rounds 10 though? 11 MR. Yes. And Friday is a 12 shower day so we're - meaning, we got to shower 13 everybody in SHU, so at one point or another, 14 everybody that worked in SHU before 4 o'clock 15 in the afternoon, went in and out the tiers at 16 least a good 40 times. 17 MR. Okay. What time are 18 inmates showered? 19 MR. We start at 6:00. 20 MR. Okay. Was Epstein 21 showered on that date then? 22 MR. Yes he was because he goes 23 to his attorney visit. 24 MR. And he gets showered 25 prior to going? EFTA00116135 77 1 MR. Correct. 2 MR. Okay. All right, these 3 are the - you said you weren't involved in any 4 counts, so we'll give you the count sheet. 5 These are the round sheets from August 9, 2019. 6 I can't make out this stuff. Does any of that 7 - your signatures or initials? 8 MR. The RCG right in the 9 middle. 10 MR. You're RCG? Okay. 11 MR. Correct. Middle. 12 MR. All right. And then 13 all right, so you were involved in those rounds 14 that are listed on there. Why do COs conduct 15 counts and rounds? 16 MR. To make sure the inmates 17 are - why they conduct rounds? 18 MR. Sure, we'll do each. Why 19 do COs conduct rounds? 20 MR. To make sure everybody is 21 breathing 22 MR. And why -. 23 MR. - and make sure everybody 24 is still there. 25 MR. And why do they conduct EFTA00116136 78 1 counts? 2 MR. To count and make sure all 3 the bodies are there. 4 MR. Okay. Do all the COs who 5 work in the SHU know how to properly conduct 6 and report counts and rounds? 7 MR. Yes. If they got the ART 8 training, which is the initial training when 9 you start or the new training, we go over the 10 count time and we go over rounds. And when we 11 do the SHU training, we also go over the 12 rounds. 13 MR. So in that annual 14 refresher training, do they go over SHU counts 15 and rounds as well or just general 16 MR. Well -- 17 MR. : -- institution? 18 MR. -- general institution 19 counts. 20 MR. : Okay. 21 MR. Now the rounds in the units 22 are different than the SHU rounds, but it is 23 part of the annual training because there's a 24 section that says, "SHU." 25 MR. Okay. So during that EFTA00116137 79 1 section that's title, "SHU," for the annual 2 refresher training, they actually talk about 3 conducting counts and rounds? 4 MR. 5 MR. orrect. Okay. And I'm assuming 6 everybody that worked that day would have at 7 least taken the annual refresher training. 8 MR. Yes. 9 MR. Do all COs who work in 10 the SHU know how to properly document counts 11 and rounds? 12 MR. Yes. 13 MR. And how do they know how 14 to document? 15 MR. 16 MR. Do they - so during that ell, through the training. 17 annual refresher training and entry training 18 they teach you how to document as well? 19 MR. Well, we just log in. 20 Whenever you do a round, you got to log it in, 21 so that's kind of the way they tell us. 22 MR. And when you say, "Log it 23 in," how do you log it in? 24 MR. GRIJALVA: Well, you could log in your 25 rounds on TRUSCOPE or you could in the SHU, EFTA00116138 80 1 which the rounds sheets we still have, that's 2 the actual paper you write it in. 3 MR. Do they - have they done 4 both? Do you not only have this paper that I 5 just showed you there with the rounds, do they 6 also have - do you also have to go into 7 TRUSCOPE and log them in manually as well? 8 MR. Yes. But not the every 30 9 minute rounds. Like, in the unit, you document 10 your rounds. In SHU, you have to do it on the 11 paper, you don't have to write on TRUSCOPE, "I 12 did a round 30 minutes, I did a round within 40 13 minutes, I did a round in 30 minutes." You 14 don't have to write it over and over and over 15 on TRUSCOPE. 16 MR. When do you have to do it 17 in TRUSCOPE? 18 MR. Just throughout your shift 19 that you conducted rounds. 20 MR. So it's not every 30 21 minutes but at some point you've got to go in? 22 MR. Yes. 23 MR. And do you have to 24 document, like within TRUSCOPE that you did it 25 every 30 minutes or just that it - how does EFTA00116139 81 1 that -. 2 MR. That they were done. 3 MR. That they were done. 4 MR. Yes. 5 MR. So it's not like it's 6 where every 30 minutes you have to see what 7 time it is -. 8 MR. Correct. 9 MR. Okay. Is it ever 10 acceptable for a CO to document a count or a 11 round prior to conducting the count or a round? 12 MR.IIIIIIIIIIIINo. 13 MR. What do you know about 14 COs assigned to the SHU doing this? 15 Documenting the rounds and the count slips 16 prior to ever conducting the rounds or the 17 count slips? 18 MR. The time that I'm there, it 19 was never done. 20 MR. It was never done? 21 MR. No. 22 MR. Do you know anything 23 about that? 24 MR. No. 25 MR. Even after the fact, have EFTA00116140 82 1 you heard about that? 2 MR. 3 MR. yen after the fact. Who else is responsible 4 for conducting counts and rounds inside the MC 5 SHU aside from the people that are actually 6 working in the SHU? 7 MR. Well, the SHU Lieutenant, 8 the Operations Lieutenant, they both have to 9 conduct rounds on all ranges in SHU. 10 MR. So when Opera- so there 11 was no SHU Lieutenant on August 9, 2019, 12 correct? 13 MR. Correct. Lieutenant 14 was hurt, if (Indiscernible *00:58:37) think he 15 was hurt. 16 Think he was on leave and 17 then got hurt that weekend, but yes. So he 18 wasn't there, so that would have placed the 19 responsibility on the Operations Lieutenant? 20 MR. Well, regardless, the 21 Operations Lieutenant has to do his or her 22 rounds. 23 MR. Oh, okay. So, even if 24 the SHU Lieutenant is there, the Operations 25 Lieutenant also has to conduct a round in the EFTA00116141 83 1 SHU? 2 MR. Correct. 3 MR. And is it once per shift? 4 MR. Yes. 5 MR. And what does a round for 6 the Operations Lieutenant look like? What does 7 it entail? Is it just them visiting the SHU or 8 do they actually have to walk the tiers? 9 MR. They have to walk the 10 tiers. 11 MR. Z: Is that policy? 12 MR. There's a sign in book and 13 then there's these little papers on the end of 14 every range that they have to sign on the 15 bottom. 16 MR. So on your shift, it 17 appears that Lieutenant_is actually the 18 one that conducted a round, is that correct? 19 MR. Yes. 20 MR. Now, by that 21 certification, mean that he actually walked the 22 tiers? 23 MR. GRIJALVA: Yes. 24 MR. Okay. So if Lieutenant 25 was the person to have walked the tiers, EFTA00116142 84 1 would have that - would that refresh your 2 memory? Would that conversation the fact that 3 Epstein's cell is now empty, would that have 4 come up? 5 MR. It depends on the time he 6 walked around. 7 MR. Okay. 8 MR. That just means he walked 9 in from 6:00 to 2 o'clock in the afternoon. It 10 doesn't tell - like, it's not even specific 11 that when he went up there I was there 12 MR. Okay. 13 MR. -- or any other officer 14 spoke to him. 15 MR. Would you believe that 16 Lieutenant if he's doing the rounds, 17 should have been tipped off on the fact that 18 that cell was empty? 19 MR. Yeah, depending on the time 20 that he did. 21 MR. Okay. 22 MR. The time that he did walk. 23 MR. Was there any action that 24 he should have taken at that point? 25 MR. Well, if - I'm guessing if EFTA00116143 85 1 he saw an empty cell, everybody is asking, you 2 know, he should have asked where he went. 3 MR. : Right. 4 MR. Well, went downstairs, 5 depending who he asked. 6 MR. And by this, are you able 7 to tell when Lieutenant_actually 8 conducted that round? 9 MR. No. 10 MR. You're not able to tell? 11 MR. No. 12 MR. Where is that Lieutenant 13 log? I know it's here - some - oh, no, no, no. 14 I have another one right here. 15 MR. (Indiscernible *01:00:45). 16 MR. No, no, no, it's - 17 there's Lieutenant round logs. So what is this 18 that I'm showing you? 19 MR. These are from TRUSCOPE. 20 MR. And is that how - can you 21 find where during your shift, a Lieutenant - is 22 that when Lieutenants do rounds, that's where 23 they log in and they say when they did a round? 24 MR. Correct. On TRUSCOPE. 25 MR. : Okay. Can you find EFTA00116144 86 1 during your shift who is says that their round 2 in the SHU. 3 MR. Lieutenant did a 4 round in 9-South at 11:27 and he did it on 10- 5 South at 11:28. 6 MR. Okay. And 10-South is 7 the -. 8 MR. The upper level. 9 MR. Of the SHU? 10 MR. Yes. 11 MR. Correct? And it's like a 12 separate unit in the SHU? 13 MR. Yes. 14 MR. For the high-profile and 15 single cell inmates? 16 MR. Yes. 17 MR. And where Epstein was 18 housed, that would have been in 9-South? 19 MR. Correct. 20 MR. Okay. Great. So -. 21 MR. 11:27 a.m., that's when he 22 -- 23 MR. That's when he would have 24 visited. 25 MR. -- should have did the EFTA00116145 87 1 round. 2 MR. Okay. 3 MR. Or more or less. 4 MR. But you don't recall 5 having a conversation with him at that time? 6 MR. No. 7 MR. No? And you're sure in 8 August of 2019 that Lieutenants at that time 9 did actually did conduct rounds of the entire 10 unit to include walking the tiers? 11 MR. Yes. 12 MR. Check? Okay. So if 13 Lieutenants tell us now when we're talking to 14 them, "No, no, no, no, that's the Lieutenant's 15 discretion. They can just pop in, check with 16 the staff and then leave." Is that -. 17 MR. No. You have to - by 18 policy, do a round throughout the whole 19 building and make sure you log it in. And in 20 SHU, we have the round sheets which that's part 21 of your SHU round. You can't just walk into 22 SHU, do a 360 and walk right back out. You 23 have to sign the round sheets. 24 MR. And what's your opinion 25 if Lieutenants are telling us, "No, no, no, no, EFTA00116146 88 1 no, we don't actually have to walk the tiers, 2 we can just check with the COs and go to the 3 next unit." What's your opinion of that? 4 MR. Say that's crap. 5 MR. Do you believe those 6 people know better and they know that they need 7 to actually conduct rounds? 8 MR. Every Lieutenant should 9 know that they have to do rounds in Special 10 Housing, walk around every tier and every 11 range. 12 MR. And how do they know 13 that? Is that something provided at training 14 or how do they know? 15 MR. Well, I became a Lieutenant 16 and that was pretty much, "This is what you got 17 to do. When you do rounds, that's part of your 18 SHU rounds," not just -- 19 MR. : And -. 20 MR. -- go and sign the book and 21 leave. 22 MR. And at the time we're 23 talking about, August 9, 2019, you were not 24 actually a Lieutenant yet, but you do know that 25 that was still policy at that time? EFTA00116147 89 1 MR. Correct. 2 MR. Do you know where that 3 policy is found? Is that a SHU policy or is it 4 a Psychology policy or is there -. 5 MR. I think that's a Lieutenant 6 policy. 7 MR And there's a separate 8 Lieutenant's book that shows all your policies? 9 MR. Well, we have the 10 Lieutenant's log and just like when staff does 11 their round, we have to insert it into 12 TRUSCOPE. So the Lieutenant, when they do 13 their rounds, they have to log into TRUSCOPE 14 and say they conducted rounds in Special 15 Housing. 16 MR. But do we know where that 17 policy is found? 18 MR. hat I do not know. 19 MR. Okay. Do you know if 20 it's found in the SHU policy? 21 MR. don't know that. 22 MR. You don't know? Okay, no 23 problem. So what are the OIC's 24 responsibilities when it comes to conducting 25 counts and rounds? EFTA00116148 90 1 MR. Well, when it comes to 2 conducting rounds, you got to make sure 3 everybody does a round 30 minutes, within 40 4 minutes, throughout the day and we got to make 5 sure the round sheets are filled out. We got 6 to make sure the counts - make sure that 7 there's - it's an accurate count and we got to 8 make sure the count slip is filled out the 9 right way. 10 MR. And you said that on this 11 one specifically, you said you're all the 12 MR. he 2 o'clock. 13 MR. The 2 o'clock ones? 14 MR. Uh-huh. 15 MR Okay. So that's all your 16 initials are. 17 MR. Correct. 18 MR. And were those, do you 19 remember, were those rounds conducted? 20 MR. Yes. 21 MR. Yes? 22 MR. I know for a fact those 23 rounds - like I said, it was shower day, so 24 usually shower days, we're in and out, in and 25 out, in and out, throughout the whole day and EFTA00116149 91 1 we don't finish showers until about 2:00, 2 sometimes 3 o'clock in the afternoon. 3 MR. Okay. So you're 4 constantly interacting with each -- 5 MR. Yes. 6 MR. each. So as far as 7 the times go though, are they like specific 8 times or do you kind of like add those later on 9 in the day? How does that work? 10 MR. Well, we usually go in, 11 sign it, if I forget, I already know that I 12 went back another 20 minutes, 30 minutes -- 13 MR. : Right. 14 MR. -- then I'll fill it out. 15 MR. : Okay. 16 MR. You try to make it as 17 accurate as I could when I'm there, but we're 18 all human. Sometimes I - just because I didn't 19 write it down, doesn't mean I didn't go down 20 the range. 21 MR. Yeah. 22 MR. I just forgot to write it 23 down. 24 MR. Well, what is the purpose 25 of signing a 30 minute round sheet? EFTA00116150 92 1 MR. To confirm that you did 2 your round. 3 MR. Okay. And aside from 4 when you were there and you were signing it in, 5 do you know if on August 9th specifically, if 6 the people that signed this document also 7 conducted their rounds? 8 MR. No. I would assume they 9 did 10 MR. You do? 11 MR. -- just signing it. 12 MR. Do you know anything 13 about people writing down that they did it when 14 they actually in fact did not do it? 15 MR. The only thing I know is 16 part of the times it would be off. Like, all 17 right, like I said before, I walked around but 18 I didn't write it, "Oh, shit, what time did I 19 do the round? 7:15, maybe it was actually 20 7:05," but, you know, I'll guess the time. Not 21 that I wrote it down and I didn't walk around 22 at all. 23 MR. Now, you're off at 2:00, 24 correct? 25 MR. Yes. EFTA00116151 93 1 MR. Should someone have 2 filled in the other -- 3 MR. 4 MR. 5 have -. 6 MR. 7 MR. 8 that out? 9 MR. Yes -- times? Who should We should have. Who should have filled 10 MR. should have filled 11 that out? 12 MR. Or anybody else that was 13 there. 14 MR. Okay. And do you see 15 these initials over here where it says, 16 "Signature," from 4:00 p.m. until midnight, do 17 you know who that would have been? Would have 18 been -. 19 MR. If it's a JN, it should be 20 Noel. 21 MR. : Okay. Or TN -- 22 MR. Hold on. 23 MR. • -- maybe. 24 MR. Right, (Indiscernible 25 *01:06:57). EFTA00116152 94 1 MR. I don't know if it's T or 2 a J. 3 MR. J or a -. 4 MR. It's T. 5 MR. T? 6 MR. T and so Tova Noel? 7 MR. Yes. 8 MR. But you believe is 9 the one that should have certified the 2:00 to 10 4:00? 11 MR. Yeah. 12 MR. Do you believe 13 should have also while he was on duty, been the 14 one that had a signature from 4:00 p.m. on? 15 MR. He could have. He could 16 have. It's not - you don't have to be the 17 person (Indiscernible *01:07:18). Anybody 18 could sign the rounds but I just did it because 19 I was in and out the range, so I always signed 20 them. But anybody could have signed the rounds 21 as long as they did them. 22 MR. So what would your 23 opinion be if I tell you that someone like a 24 Tova Noel says that they actually fill this in 25 at the very start of their shift prior to ever EFTA00116153 95 1 conducting any rounds just to make sure that 2 it's filled out correctly. What would you say 3 to that? 4 MR. They fucked up because they 5 still not done it. Sorry. 6 MR. No. 7 MR. Excuse my language. 8 MR. That's what we're looking 9 for is some kind of, you know, honest answer. 10 MR. Yeah. No. That's a big no 11 go. 12 MR. Do you know if anyone was 13 doing that? 14 MR. I never worked with her 15 like that. I know she worked in SHU a couple 16 of times, but - and she was pretty new, so. 17 MR. So she - let's say 18 hypothetically, she's saying that she's doing 19 it, not based upon what people are telling her, 20 but watching other people and that's how they 21 did it. Do you know of anybody else that ever 22 did it that way? 23 MR. No. Again, I - if it was - 24 if they were working with me, it never 25 happened. EFTA00116154 96 1 MR. Okay. 2 MR. Yeah. You know, I got, like 3 I said, not to toot my own horn, but I very 4 prideful of my job and I was Officer of the 5 Year, Rookie of the Year, also won numerous 6 awards and I got promoted within five year. 7 MR. Okay. I got you. 8 MR. Obviously I was doing 9 something right. 10 MR. Sure. So being that, you 11 know, you've been around the block and you 12 sound like you're an ideal employee - how do I 13 ask this question? Would it surprise you that 14 she's saying that that's the way she thought it 15 was supposed to be done? 16 MR. Yes, definitely. 17 MR. And why? 18 MR. And we always say, "If you 19 see somebody else doing something wrong, 20 correct it, don't follow it." 21 MR. Okay. 22 MR. So, I think - yes. 23 MR. Do you remember ever 24 speaking with Tova Noel about how to fill out 25 round sheets? EFTA00116155 97 1 MR. No. 2 MR. : No? And even as the OIC 3 and she's newer, would that have been something 4 that you dealt with her with and try to like 5 train her on it? 6 MR. I mean, I always decide to 7 do rounds within 30 to 40 minutes. 8 MR. Right. 9 MR. Yeah. 10 MR. But did you ever talk 11 about the actual documentation of it? 12 MR. No. 13 MR. No? 14 MR. Not specifically to her, 15 no. 16 MR. All right. And speaking 17 of Tova on August 9th, referring back to that 18 Lieutenant log, are you able to determine who 19 it was that would have been the supervisor on 20 duty that -- 21 MR. For that night? 22 MR. : -- that conducted a round 23 during - between 4:00 p.m. and midnight? 24 MR. That should have been 25 Lieutenant EFTA00116156 98 1 MR. : Lieutenant 2 MR. It says here - I don't know 3 Lieutenant - on the 9th. 4 MR. On the 9th, correct, so 5 not the 10th, the 9th. 6 MR. Oh, okay. 7 MR. Would have been or 8 9 MR. Well, was Acting 10 Lieutenant so she made the round at 7:31 p.m. 11 MR. Okay. And at 7:31 p.m. 12 on August 9th -- 13 MR. Correct. 14 MR. -- when she conducted a 15 round, would she have known that she had to 16 actually conduct the round and walk down the 17 tiers being that she was an Acting Lieutenant. 18 MR. Yes. 19 MR. So how would she know 20 that? 21 MR. She's the Acting 22 Lieutenant, so usually if you're an Acting 23 Lieutenant then you pretty much have to do 24 everything that the actual Lieutenant does 25 which is also part of conducting your rounds. EFTA00116157 99 1 Now, it's her and another Lieutenant working 2 that night. Sometimes the other Lieutenant 3 might say, "Don't worry about SHU, I'll do the 4 rounds." But according to the log, she did the 5 rounds at that time. 6 MR. : Now, is that 7 certification that they make at the bottom of 8 these round sheets, is that certifying that 9 they actually conducted a round of the tiers? 10 MR. Yes. 11 MR. : All right. So that's not 12 just saying that they visited the SHU, but 13 actually that they conducted a round in the 14 SHU. 15 MR. Yes. 16 MR. Okay. Do you recall 17 having any conversations with anyone with 18 regard to rounds on August 9th, 2019? It could 19 be Epstein rounds, rounds in the SHU, anything 20 like that? 21 MR. Just staff, "Hey, let's 22 make sure we got these - keep these rounds up. 23 MR. Okay. But you are - you 24 said you did create the round sheet that 25 specifically said that Epstein rounds needed to EFTA00116158 100 1 be done every 30 minutes (Indiscernible 2 *01:11:54). 3 MR. Right. 4 MR. Okay. And do you 5 remember if, you know, when you're 6 MR. : So whoever was there, they 7 watched - saw that paper. Monday I came in and 8 that paper wasn't there anymore. 9 MR. So it was there when you 10 left at 2:00 p.m. on Friday, August 9th. 11 MR. Yeah, was here. 12 MR. And that was gone by 13 Monday. 14 MR. By Monday. 15 MR. Okay. 16 MR. I was off weekends. 17 MR. But it was definitely 18 there on August 9th? 19 MR. For a fact, yes. 20 MR. Okay. And you said it 21 was hanging right on the computer? 22 MR. eah. 23 MR. So it was like blocking 24 the screen or how -. 25 MR. No, it was right next to EFTA00116159 101 1 the screen. 2 MR. : Right next to the screen. 3 MR. It wasn't blocking the 4 screen. It was next to the screen. 5 MR. Is it hanging on the PC? 6 MR. Yeah. 7 MR. So, not the monitor -- 8 MR. Oh, no. 9 MR. -- but the actual computer 10 itself. 11 MR. Yeah, like on the side. 12 MR. And not only, obviously, 13 that's a big orange document, was it the same 14 size as what we're showing you or is that 15 enlarged? 16 MR. It was -- 17 MR. The same size as -- 18 MR. -- the same exact -. 19 MR. -- as a regular piece of 20 paper. 21 MR. That, but a little bright 22 orange paper with black letter. 23 MR. So roughly 11" by 12" or 24 13" or whatever those are. Okay. And so 25 obviously that's a notice for everyone. Do you EFTA00116160 102 1 remember on August 9th though specifically 2 talking with anyone about conducting rounds on 3 Epstein? 4 MR. It was something we spoke 5 about every day. 6 MR. Oh, you did. 7 MR. Like -- 8 MR. There were conversations, 9 "Make sure you -." 10 MR. -- "Hey, look, this guy is 11 still here. He's right there," you know, 12 "Let's make sure -." 13 MR. Even though he was in 14 attorney conference though? 15 MR. No. Make sure we're doing 16 rounds. And everybody spoke about it, "Make 17 sure we're doing round, make sure we're doing 18 rounds." 19 MR. So even though he's gone 20 for the majority of your day at least, was that 21 something, you know, when you were like leaving 22 your shift, would you have said, "Hey, make 23 sure 24 MR. Oh, yeah. Yeah. 25 MR. -- you know, for God, EFTA00116161 103 1 make sure." 2 MR. Hell yeah. And, everybody 3 already got like from the Warden, Lieutenants, 4 "Hey, make sure you guys do your rounds." 5 MR. So that was going to be 6 my next question. So, who else was instructing 7 you on doing rounds and specifically doing 8 rounds on Epstein? 9 MR. Everybody. 10 MR. And can you remember -- 11 MR. So -. 12 MR. -- any specific direction 13 coming from anyone? 14 MR. So, Warden used to 15 walk around a lot in SHU and he say, "Hey, make 16 sure you guys keep an eye on him," pretty much 17 directly, but in the indirectly telling us to 18 do our job. 19 MR. : Right. 20 MR. Same thing with Lieutenant 21 He used to walk around, "Hey guys, make 22 sure you do your rounds." And, you know, 23 Lieutenant the same thing, "Hey, make 24 sure you guys do rounds." 25 MR. Now being that you were EFTA00116162 104 1 the OIC and was the SHU Lieutenant, can 2 you remember any specific conversations with 3 him with regard to Epstein and doing rounds or 4 anything? 5 MR. Well, he used to tell us 6 just, "Make sure you're on top of it. 7 MR. Do you know from the time 8 that Reyes was placed with on July 30th and the 9 need for Epstein to be placed with an inmate, a 10 cell mate. Can you recall any conversations 11 specifically with with regards to Epstein? 12 MR. I think he told us to put 13 him in with Reyes. Uh-huh. 14 MR. And again, do you know 15 why he was - Reyes was chosen? Now, I know you 16 said he was an older gentleman 17 MR. Right. 18 MR. -- and he had a cane or 19 something like that, but I mean, you -- 20 MR. So I think -. 21 MR. : -- you don't know 22 anything other than the fact that Psychology 23 MR.M: Psychology probably 24 recommended him or they looked through the 25 whole SHU roster and felt he was probably the EFTA00116163 105 1 safest person to put him with. 2 MR. Okay. And do you know if 3 people were conducting rounds on Epstein like 4 your sign said? Because you weren't there when 5 he was there, so do you know if -. 6 MR. So, after 2 o'clock, they 7 should have been conducting rounds. 8 MR. Right. 9 MR. And I don't remember - 10 MR. Well, he would get back 11 around like 8 o'clock, right? 12 MR. Right. I don't -- 13 MR. So, like 8:00 p.m. on -. 14 MR. -- remember if we started 15 showers or not going on but they should - 16 regardless while he was there or not, they 17 should have still continued the rounds. 18 MR. And I know that they 19 should have, but do you know if they were. 20 MR. I can't say, "Yes, they 21 did," or, "No, they did not. 22 MR. : But whenever you were 23 there, they were being done? 24 MR. Yes. 25 MR. Okay. EFTA00116164 106 1 MR. e were all over the place. 2 MR. All right. So this is 3 where it's going to get a little complicated, 4 so just bear with me. I'm going to show you 5 these count slips from August 9th up until 6 midnight of August 10th. I'm just going to 7 have you help - this is where, remember, I said 8 I was going to help you, you know, put this 9 puzzle together. Believe we already know the 10 answers but I don't want to give you the 11 answers in fear that I'm wrong. So this is 12 from the 5:00 a.m. count to the midnight count 13 and I want to show you the Lieutenant's log 14 which, where is that? So here's the 15 Lieutenant's log. And we didn't print out that 16 paper that I made, did I? 17 MR. Which one? 18 MR. The one that I drafted 19 yesterday and said, "Make sure we print this 20 out." All right, so, we'll just start with 21 8:00 a.m., since that's when you came in, so we 22 can actually - the reason I was showing you the 23 5:00 a.m. is because I really wanted you to 24 notice - okay, two. Is ZA the SHU? 25 MR. : Yes. EFTA00116165 107 1 MR. : And so 77 is the total 2 count in the SHU for inmates? 3 MR. Correct. 4 MR. Then we look back at 5 these count slips and we see - sorry I'm 6 looking over you, but, ZA says -. 7 MR. Thomas. 8 MR. : And at 10:00 it says, 9 "77," correct? 10 MR. Yes. 11 MR. : all right. So we'll put 12 that here. It says on the Lieutenant's log, 13 "77," -- 14 MR. 77, yes. 15 MR. : -- correct? All right. 16 So now where are we at? We're at the 4:00 p.m. 17 count. 18 MR. 4:00 p.m., yes. 19 MR. Correct? So for ZA, it 20 shows 76 total, right? 21 MR. Yes. 22 MR. One in attorney client, 23 brings it down to 75. 24 MR. Yes. 25 MR. So what should the count EFTA00116166 108 1 slip reflect then? 2 MR. At this time? 3 MR. : Yes. 4 MR. The count, the physical 5 bodies in SHU. 6 MR. Okay. So it should 7 reflect -- 8 MR. 75. 9 MR. -- 75. Okay, great. So 10 here where ZA, ZA shows 75, correct? 11 MR. Yes. 12 MR. Okay. Now we're looking 13 at 10:00 p.m. ZA says 73, right? 73 total 14 bodies it says at 10:00 p.m.? Now the ZA - 15 where is it? ZA count slip says, "73 plus 1." 16 First, can you think of any reason why it would 17 say, "Plus 1?" 18 MR It shouldn't say, "Plus 19 unless somebody came in at night. 20 MR. Z: Okay. 21 MR. But regardless, that 22 shouldn't be like that, it should be 74. 23 MR. Okay. 24 MR. Not 73 plus 1. 25 MR. So this is where you're EFTA00116167 109 1 going to start getting interested. So at 2 midnight, the ZA count says, "72." "72," 3 right? So the count slip says, "73." Now, 4 reviewing this, the E-1 says, "72," same 5 institutional count, says, "72," the count slip 6 still says, "73." Now let's look at this. And 7 granted, you just told us this could have been 8 done later in the day so maybe this wasn't done 9 at the time. 10 MR. By that time, it should 11 have been done. 12 MR. So 8:00 a.m. So we have 13 these different places where it says these 14 people were moved. So the 8:30 a.m., do you 15 agree that inmate Reyes was removed and it 16 brings the count down to 76? 17 MR. Yes. 18 MR. All right. So we go down 19 to 75. is placed on dry cell from 20 ZA. 21 MR. Okay. 22 MR. Moves it down to -- 23 MR. 75. 24 MR. -- 75. All right. So 25 that 4:00 should have said - the 4:00 p.m. EFTA00116168 110 1 count should have said -. 2 MR. : Should have been 75. Which 3 is 75. 4 MR. Right. But, shouldn't 5 have this said, "75?" 6 MR. No. 7 MR. Because the 75, one 8 person in attorney, that should be 74, right? 9 MR. ■ 10 76. So now 11 MR. • : Yes. So this is fine at : But that, isn't that 12 referring to Epstein being in attorney? 13 MR. Yes. 14 MR. So, shouldn't this say 75 15 based upon this? 16 MR. Reyes was moved before that. 17 MR. Unless -. 18 MR. : So this is at 3:15, the 19 count goes down to 75, so shouldn't this E-1 20 say 75 here? 21 MR. No, because this guy could 22 have still been doing dry cell in SHU. 23 MR. Okay. 24 MR. Meaning, dry cell, he's 25 inside a cell. The water is off, he doesn't EFTA00116169 111 1 have any clothes. He uses the bathroom inside 2 of SHU. 3 MR. So -. 4 MR. : Let me keep my thought. 5 All right. So then this brings it down. So 6 3:15, now we go over to - brings it down to 74 7 here, IIIIIIIIII Brings that count 8 (Indiscernible *01:20:17) 74. 9 MR. He got kicked out. 10 MR. : Reid gets 73. 11 MR. He got kicked out. 12 MR. • goes down to 71. 13 MR. Another one -. 14 MR. • comes in, goes to 15 72. That's at 8:28 p.m. So 72 is the count at 16 8:28 p.m. ZA still says 73. Now let's look at 17 that. It says now, R&D now has one in it. 18 Fernandez is in R&D dry cell. It actually 19 doesn't even say he's on it in this thing. 20 MR. No. 21 MR. But, ZA says, "73," 22 there's no one for that one, correct? 23 MR. Right. 24 MR. And this is where it 25 says, "73 plus 1." Would the thought maybe EFTA00116170 112 1 saying, "73 plus 1," that one being Fernandez 2 on dry cell and they're using the institutional 3 count 73? 4 MR. Should have been, if he's 5 in dry cell in SHU, he's counted inside of SHU. 6 MR. Right. So -. 7 MR. If he's not in SHU, then he 8 shouldn't be counted. 9 MR. : So he's not in SHU. 10 MR. Correct. So that means, 11 the count should have been 73. 12 MR. And should have that 13 count been changed way back here if he's not in 14 SHU? Should have this, like we talked about, 15 this 4:00 p.m. -- 16 MR. Yes. 17 MR. -- should have said 75? 18 MR. Correct. 19 MR. And why is that? 20 MR. You count physical bodies. 21 MR. Physical bodies. You 22 don't count ghost count or you don't count 23 people that aren't in your -. 24 MR. No. if you don't see the 25 flesh and it's a stand up count, so every EFTA00116171 113 1 person or inmate, whether it's in SHU or in a 2 unit, they have to stand up for the count and 3 you verify it, one, two, three, four, five, 4 six, then the person behind you has to verify 5 that count. 6 All right, and so what is 7 your -. 8 MR. If it's a body there, he 9 gets counted. 10 MR. What is your opinion then 11 if in fact that 3:15, Fernandez is moved out of 12 the SHU and placed -- 13 MR. Then the count just 14 dropped. 15 MR. -- and placed into - 16 right. But the fact that the count slip for ZA 17 matches still what the E-1 says. Does that 18 tell you anything about if the count was 19 conducted or not? 20 It should have been - and 21 everything is should have. So -- 22 MR. So that should have said 23 - the 4:00 p.m. count should have in fact, if 24 Fernandez isn't in there, that should have 25 actually said, "74," correct? EFTA00116172 114 1 MR. Yes. 2 MR. So does that tell you 3 that they did or did not conduct the count in 4 the SHU? 5 MR. : If they counted 75 physical 6 bodies, then that's a good count. 7 MR. Right. 8 MR. But now, if there is not 75 9 physical bodies in the SHU, then they went off 10 whatever it is they were going off and verified 11 it with this paper right here, which not 12 everybody has access to it. This is the E-1 13 that we keep count on. 14 MR. So would the SHU people 15 that are in the SHU, would they have access to 16 know what the count was for this E-1, what 17 they're utilizing for that count? 18 MR. No. Unless somebody says, 19 "Hey, you're missing one, your count is 75." 20 MR. So the only way someone 21 in the SHU would be able to actually know what 22 number to provide is by actually doing the 23 count? 24 MR. orrect. 25 MR. Really? All right. So EFTA00116173 115 1 if we know that Fernandez is now not in the 2 SHU, how are they coming up with that 75 number 3 and for 4:00 p.m. and then as well as 10:00 4 p.m., they're coming up with a wrong number and 5 again at midnight, they're writing down the 6 wrong number. They're writing down the number 7 that they think the institutional count is, but 8 there's not that many people that are actually 9 in SHU. How do we explain that? 10 MR. So, the only thing I can 11 think of is they put - they locked somebody up 12 between the 4 o'clock count and the 10 o'clock 13 count meaning somebody from the unit did 14 something wrong and they ended up in the 15 Special Housing Unit. So that's how the 16 numbers would be different. 17 MR. So if we have information 18 that -. 19 MR. And - sorry to interrupt. 20 MR. : No, go ahead. 21 MR. Again, everybody is human 22 and everybody makes mistakes, unless somebody 23 write in the log missed one inmate going from a 24 unit out or leaving from SHU to a unit. 25 MR. Well, that's exactly EFTA00116174 116 2 out of the 3 until this 4 MR. 5 cell where? 6 MR. - 1 right. So at 3:15, Fernandez was never keyed SHU. He wasn't keyed out of the SHU count at midnight. So he was placed in dry So, at - he was placed in 7 dry cell at - are R&D and RA the same thing? 8 9 MR. ■ MR. 10 what it is that 11 *01:25:01) -- 12 13 14 15 16 MR. MR. MR. MR. MR. 17 read it, so. Okay. That's right. Yeah, can you just read you showed (Indiscernible Oh, I'm sorry. I'm sorry. ■ -- no -- Okay. Sorry. -- I mean, you should 18 MR. Just, I pointed to the line 19 that states, on the day watch for Friday, 20 August 9th, there's a line that says, "Inmate 21 Fernandez, 86824054 on dry cell with staff 22 watch in R&D." Is R- Agent asked a question. 23 MR. a So, with this knowledge 24 and now also, with like I showed you - or first 25 of all, are count slips for RA and R&D, are EFTA00116175 117 1 they the same thing? 2 MR. Well it should be just R&D. 3 There's - 4 MR. Because one was on one of 5 these - let me see. It's at 12:00 a.m. It 6 actually says, "RA." 7 MR. That should be a B. 8 MR. Instead of a D? 9 MR. Yes. It should be a BA 10 which is on the second floor of persons placed 11 on watch, that's where they go. 12 MR. I=M Should that - instead of 13 saying, "RA," -- 14 MR. So -. 15 MR. -- it should say, "BA?" 16 MR. Correct. If it's -. 17 MR. Because that -. 18 MR. If it's there. But they 19 probably wrote R&D. 20 MR Well, it doesn't - so 21 this one says R&D. At 10:00 p.m. there's a 22 count slip from R&D that says, "1." It says 23 that's (Phonetic Sp. *01:26:12). 24 MR. , yes. 25 MR. 10:00 p.m. And just from EFTA00116176 118 1 reviewing this stuff, I'm assuming that this 2 one at 10:00 p.m. and this one that says, "RA," 3 at 12:00 a.m. are one in the same. Would that 4 be your logic as well? 5 MR. : Yes. It should have the 6 same number. 7 MR. So why is it - one say, 8 "RA" and one say "R&D?" 9 MR. Maybe he spelled the name - 10 spelled it wrong. 11 MR. All right, so the "RA" is 12 the one that's wrong? 13 MR. It should have been "R&D." 14 MR. R&D. 15 MR. Correct. 16 MR. Instead of RA. Okay. So 17 this RA is just - but that - you believe that's 18 actually the same 19 MR. Yes. 20 MR. -- the same location. 21 MR. Yes. 22 MR. All right. So with all 23 that information now, knowing that he's in dry 24 cell, he's out of the SHU, however somehow, 25 their count slips are matching what the EFTA00116177 119 1 institutional counts show, how do we explain 2 that if they don't have access to the 3 institutional count? 4 MR. Well they shouldn't have 5 access. 6 MR. Is there a way that they 7 can? Like how would they know to write that 8 number if only, for instance - let's even just 9 talk about 12:00 a.m. Only 72 people are 10 physically in the SHU but they're writing 73 11 and they're off ever since you leave. So 4:00 12 p.m. 13 MR. IIIIIII 10:00 p.m. 14 MR. -- 10:00 p.m. and 12:00 15 a.m. counts are all off and we're trying to - 16 this is where we're saying we're hoping that as 17 the OIC you can help us 18 MR. So -- 19 MR. -- put that puzzle 20 together. 21 MR. -- my only assumption would 22 be, whoever was working that night, had access 23 to the E-1, which is that's what we use. 24 MR. And do you know if - I IIIIII 25 think you said it was, what, EFTA00116178 120 1 Who was it that was -. 2 MR. I don't think 3 would have access. 4 MR. But they're not actually 5 supposed to have access? 6 MR. Correct. 7 MR. So yeah, I'm just trying 8 to -- 9 MR. And -. 10 MR. -- rectify this thing. 11 MR. Unless they cheated and 12 said, "Hey, how many do we have up here?" 13 That's my only - it's either they had access, 14 they looked at it. 15 MR. : Because we've also been 16 told at least by one of these people that they 17 write the count slips before ever doing the 18 count. So how would they know what number to 19 put in the count slips if they didn't actually 20 do the count? 21 MR. So they shouldn't and my 22 other explanation is they actually did have the 23 bodies, but one of them was in SHU and was 24 never written on the log. So now, there's this 25 other thing called a PB-38 that shows who goes EFTA00116179 121 1 in and outside of the building and what moves 2 are being made inside the building. 3 MR. : So would that help us 4 rectify this? 5 MR. That would actually help 6 you because it would - that's our little cheat 7 sheet, like I told you before, that we log in 8 during the day or right before I get relieved 9 at 2 o'clock, I'm going to print out that PB- 10 38, it's going to show me every inmate movement 11 in the building and whatever specific date I 12 want it. So if I'm doing today, three from SHU 13 just saying, "Left to another institution, to 14 Brooklyn." On that PB-38, it would say, 15 "Jones, Smith, Roberts moved to Brooklyn." So 16 now, I go that, I have 757, I just lost three. 17 Now I'm going down to 754. And just like it is 18 here, inmate 123 left to Brooklyn so now my 19 numbers go down. Again, we're all human, 20 sometimes there's a lot of movement, we might 21 miss one or two. So this right here -. 22 MR. But if these numbers 23 appear to all add up starting the day at 77 -- 24 MR. orrect. 25 MR. -- I showed you at 5:00 EFTA00116180 122 1 a.m., then I can show you all the way through 2 after Epstein, you know, die where I'm assuming 3 they definitely did the counts because there's 4 a - here's one that was done at 11:00 a.m., I 5 guess that was the 10:00 a.m. count on Saturday 6 7 MR. On Saturday, yes. 8 MR. : -- as well as the 5:00 9 p.m. count on Saturday. They're now all adding 10 up with what the numbers claim to be on this 11 Lieutenant's log. So, I'm assuming if they 12 were wrong on the Lieutenant's log and be right 13 on this, that would be reflected in these later 14 counts, correct? 15 MR. Yes. Yes. 16 MR. So that - so I'll 17 definitely get this document that you just 18 suggested, but does this information suggest to 19 you that the counts were or were not conducted 20 in the SHU? 21 MR. I think they were conducted 22 wrong. If the names - the only way I would 23 actually confirm it is the 38. Because an 24 inmate could be in SHU, he's already keyed in 25 SHU. Maybe he's on staff watch, it's still in EFTA00116181 123 1 SHU. 2 MR. : Right. 3 MR. So there's no need to key 4 him out. 5 MR._: And the 38 will able 6 to tell you this? 7 MR. Correct. The 38 will be 8 able to tell you if inmate Smith, inmate 9 Johnson was keyed out of SHU. 10 MR. Okay. Now -. 11 MR. And it would reflect on 12 this. So if the 38 - if you keyed out an 13 inmate, the count would be different. It would 14 be 75 and that's a hundred percent accurate 15 comparing everything. 16 MR. Yeah, so in talking with 17 the Lieutenant, Ops Lieutenant that was on at 18 midnight, that person said, "Fernandez was 19 never keyed out," and that's why the counts 20 were off and she keyed him out at midnight and 21 placed him over - does that give you any more 22 indication? 23 MR. So, that means 24 MR. So, (Indiscernible 25 *01:31:29). EFTA00116182 124 1 MR. -- the counts weren't 2 conducted correctly -- 3 MR. Yeah, so -- 4 MR. - until -. 5 MR. -- so the Ops Lieutenant 6 at midnight says, "Hey, I found this 7 discrepancy. This inmate Fernandez was place 8 on dry cell. I had to verify that that's in 9 fact where the person was. I had to key him 10 out of SHU and place him into there." 11 MR. That's the reason you got a 12 later -- 13 MR. Yeah. 14 MR. - out count for R&D. 15 MR. Yeah. That's the reason 16 for the change at midnight. 17 MR. Yes. 18 MR. And that, to me, tells me 19 that's the reason why all these counts were 20 actually wrong. 21 MR. Correct. And they were 22 just written - somebody must have had access to 23 this and -. 24 MR. : Right. But as far as you 25 know, no one actually knows how many inmates EFTA00116183 125 1 are actually in there unless you actually count 2 them? 3 MR. Correct. You have to count 4 them. 5 MR. Yes. 6 MR. You can't assume -. 7 MR. That's - so it would just 8 kind of like them trying to keep track or 9 something on a piece of paper doing adding and 10 subtracting? Would that be a possible way that 11 they would get the count that they're using? 12 MR. So, the way you count -. 13 MR. If they're not actually 14 counting, and they're -- 15 MR. They're assuming -. 16 MR. -- just - because 17 MR. They're - they're -. 18 MR. one of these people, 19 again, told us, "I write the count slips before 20 I ever do the counts." 21 mR.S So, if that person has 22 access or that person just assumes that the 23 count that started in the morning - because we 24 don't count at 10 o'clock in the morning during 25 Monday through Friday -- EFTA00116184 126 1 MR. : Yeah. 2 MR. -- unless it's a holiday. 3 MR. : Right. 4 MR. So if the count at 5 5 o'clock in the morning was 75, not me 6 personally, the person could have said, "I'm 7 going to go with that count unless I see 8 somebody leaving," and just 9 MR. So -. 10 MR. -- it is a possibility that 11 person, he or she, could have wrote it. 12 MR. So, for instance, at the 13 4:00 p.m. count, someone would have gone off of 14 the 5:00 a.m. count -- 15 MR. In the morning, yes. 16 MR. -- and just how many 17 people they remembered that came and went? 18 MR. Correct. 19 MR. As a - okay. But it's 20 not like they knew what the institutional count 21 would actually have been. 22 MR. Correct, unless whoever was 23 there had access to this. 24 MR. So let's look at the 4:00 25 p.m. then. EFTA00116185 127 1 MR. And this is called the PB- 2 El. 3 MR. So at 4:00 p.m. count, 4 this is August 9th. That's ZA, it looks like 5 it was signed by who? 6 MR. oel and 7 MR. Does have access? 8 MR. hat I wouldn't be able to 9 tell you if he did or didn't. He has more time 10 than she does. So it could have been a 11 possibility that he had access. 12 MR. Okay. And being that 13 this number lists 75 whereas we believe it 14 should have been 74 -- 15 MR. Yes. 16 MR. do you believe that 17 they actually conducted that count? 18 MR. My - I would give them the 19 benefit of the doubt that they did. 20 MR. Okay. And how would the 21 come - if they actually did, how would they get 22 the wrong number and specifically the number 23 that the institution had? 24 MR MMII They didn't have everybody 25 stand up and just assumed that they were right. EFTA00116186 128 1 MR. So I guess that's what 2 I'm asking is, if they actually didn't conduct 3 the count, (Indiscernible *01:34:37) -. 4 MR. They could have just walked 5 around, looked in but not actually -. 6 MR. And that's what I mean, 7 and that's where beginning I was saying, 8 "What's the difference between a count and a 9 round," so count, you're actually counting the 10 inmates, correct? 11 MR. So the way you're supposed 12 to do -. 13 MR. Not just conducting a 14 round. 15 MR. Correct. If you're doing a 16 stand up count which every count is a stand up 17 count, you stand at the door, acknowledge your 18 presence, stand up count, okay, Johnson is 19 standing up, Smith is standing up, that's two. 20 I go all the way around, I do that to every 21 single cell, the eight cells. By the time I 22 get to the end, I counted 15, I write 15. Then 23 the next person behind me has to do the same 24 exact thing. Most likely, they start from this 25 way, the opposite way and not - and actually EFTA00116187 129 1 count and you confirm the number, "I got 15, 2 how many you got?" "I got 14." "Oh, okay, now 3 we got to count again." Everybody stand up. 4 Now we have the same count, write down 15, we 5 go down to next tier. That's how a count 6 should be conducted. 7 MR. Okay. But is that how 8 they were conducted in the SHU? 9 MR. That's how I did them when 10 we were there. 11 MR. Z: Okay. So as far as this 12 one though, if they actually conducted the 13 count, and I get that you're giving them the 14 benefit of the doubt, would you find it 15 extremely coincidental that they got the same 16 number that the institution had which were both 17 wrong? 18 MR. So if they did conduct the 19 count, they would have had the numbers wrong 20 from the institution. 21 MR. So institution had it 22 wrong and they have everybody keyed and the one 23 guy never was keyed out. 24 MR. So, the institution -. 25 MR. And they just EFTA00116188 130 1 coincidentally got the same exact number that 2 the institution had. 3 MR. So if the institution - the 4 institution wouldn't only know if it was keyed 5 out. 6 MR. That's what I'm saying. 7 That's what I'm saying. 8 MR. Correct. 9 MR. So the institution didn't 10 know because somebody didn't key out Fernandez. 11 MR. They probably -. 12 MR. Z: But -. 13 MR. They probably fucked up and 14 didn't actually count and just wrote it - it 15 comes down to that. Excuse my language, but -. 16 MR. No, then that's what I'm 17 assuming happened but I just want - I want to 18 know from you, why? Why do you believe that? 19 MR. Laziness maybe. 20 MR. : No, no, no, no, no, why 21 do you - so, why do you believe -. 22 MR. So sorry. 23 MR. What makes you believe 24 that the count wasn't conducted? I basically 25 gave you the answer. But, like, I'm just EFTA00116189 131 1 looking for you, if you're agreeing with my 2 logic and if that actually is the same logic 3 you have. I'm not trying to provide you that 4 answer, I'm just trying to see, like, "Hey, in 5 your 6 MR. o they 7 MR. You're the OIC, you're 8 the expert in this matter basically. Does this 9 information tell you that that count wasn't 10 done? 11 MR. Yes. It does tell me that 12 the count was not done and they just assumed 13 and went by the cheat sheet -- 14 MR. : Okay. 15 MR. -- because the body wasn't 16 even there. 17 MR. But going back to what 18 you said before, they don't actually have a 19 cheat sheet, they'd have to just kind of guess? 20 MR. Go off the count that was 21 at 5 o'clock in the morning if it was the same 22 number. Or they logged in where there was -. 23 MR. And there's no log that 24 can - there's no screen that they can say who's 25 logged into this right now, who's there, what's EFTA00116190 132 1 our total count in here? 2 MR. No, it's just a - E - well, 3 that, no, that part, because I can log in and 4 tell you how much - how many inmates every unit 5 has right now. 6 MR. Because you're a 7 Lieutenant. 8 MR. Without physically 9 counting. Yes. 10 MR. But what about the people 11 that work in the SHU? 12 MR. If you work Control before, 13 you would have that access. 14 MR. Right. Oh, so if you've 15 been in Control prior to that date. 16 MR. Correct. You would have 17 access. 18 MR. So, if for instance, 19 worked in Control, he could have access - 20 - 21 MR. Yes. 22 MR. -- to see, what's the 23 number. 24 MR. If she worked in Control I 25 two days prior, she would have a cess because EFTA00116191 133 1 that's what you do in Control. You 2 MR. : When you say, "She," are 3 you talking about Tova Noel? 4 MR. Correct, Noel. If she 5 worked in Control before, she would have access 6 and reason they give us access - well, all the 7 Lieutenants have access, but the reason they 8 give the officers access is because you work in 9 Control and you have to print out this sheet, 10 which is the E-1 that gives all the numbers of 11 all the units. 12 MR. : Okay. 13 MR. So if worked there 14 before, he would have access and he would have, 15 you know -. 16 MR. Would he have indefinite 17 access? When do they take that access away? 18 MR. Usually when we have 19 program review and unless you're assigned to 20 Control, you cannot have access 21 MR. Okay. 22 MR. -- and they just take it 23 back from you. 24 MR All right. So is it - am 25 I understanding correctly, likely someone EFTA00116192 134 1 worked in Control and had access and they 2 looked to see what the institutional count was 3 and they just wrote that down? 4 MR. Yes. 5 MR. Okay. But you do believe 6 that this - what did you call it, 38, is 7 MR. PB-38. 8 MR. will help us? 9 MR. That has more - that paper 10 would not lie. 11 MR. And is that paper what 12 the Lieutenants use to fill out their logs? 13 MR. Yes. 14 MR. Okay. And as far as the 15 Lieutenant log goes though, that could have 16 been created at any time though during the day 17 and specifically after all the stuff actually 18 happened? 19 MR. Yes. 20 MR. All right. And would it 21 be likely that it was created once the 22 Lieutenant at midnight actually noticed this 23 discrepancy, would they have the ability to go 24 in and then correct everything? 25 MR. Yes. So now we have a day EFTA00116193 135 1 watch Lieutenant log, an evening watch 2 Lieutenant log, and a morning watch Lieutenant 3 log. 4 MR. : So would this - would the 5 - let's say, would the morning watch at 6 midnight have access to the day before 7 Lieutenant log? 8 MR. Yes. 9 MR. So they -- 10 MR. Yes. 11 MR. -- could actually go it - 12 so the person -- 13 MR. And fix it. 14 MR. -- that worked at 15 midnight on August 10th could have gone into 16 August 9th and fixed everything? 17 MR. Correct, the discrepancies 18 on the numbers. 19 MR. Okay. 20 MR. Yes. 21 MR. All right. 22 MR. Or correct based on the 38. 23 MR. Right. And they probably 24 referenced the 38 to fill out the -- 25 Yes, because if you saw EFTA00116194 136 1 MR. Z: -- Lieutenant's log. 2 MR. -- on the 38 you had - 3 again, let's say Fernandez wasn't on the 4 Lieutenant's log but then on the 38 you saw 5 that he moved to R&D, you go back and key him 6 out because the numbers have to be accurate by 7 the time of every shift, the ending of every 8 shift. 9 MR. Right. And when we read 10 this for this Fernandez on dry cell with staff 11 watching R&D, is it possible that Fernandez was 12 in SHU dry watch and then later in the day 13 moved to R&D dry watch? 14 MR. He could have went from a 15 unit into dry watch or Special Housing, SHU, to 16 dry watch. 17 MR. How does that typically 18 work? If you're on dry watch, is there a 19 reason for them to bring you from the SHU on 20 dry watch to R&D on dry watch or would it 21 typically just go right from the SHU to dry 22 watch in R&D? 23 MR. MM. It would go - there's no 24 reason to take you out of SHU -- 25 MR. : Yeah, why would -. EFTA00116195 137 1 MR. -- unless you're short 2 staffed. 3 MR. 4 MR. 5 MR. Okay. f there's two -. So in this case, do you 6 believe they were short staffed? 7 MR. 8 two officers and one on morning watch. 9 MR. Okay. And morning watch, 10 right. So what about the day watch? 11 MR. Then you're supposed to 12 have four officers in SHU during the day. If 13 it would have been three, then removing one 14 officer would have left it with just two 15 officers in SHU. So if you have just three 16 officers and I'm going to put, for example, 17 Officer to do dry watch and I'm 18 sitting there and I cannot move, I have to 19 watch this inmate throughout the whole day. 20 MR. So with that being said, 21 do you believe it's more likely than not that 22 he was moved to the dry cell in R&D at through, 23 whatever time we said it was, 3:15? 24 MR. It could have been. 25 MR. Or because it does - Yes, because there was only EFTA00116196 138 1 because at 3:15, it says, "Fernandez 2 MR. rom. 3 MR. -- placed on dry cell 4 from ZA." 5 MR. SHU, that's SHU. 6 MR. So to me, it looks like 7 he left. 8 MR. So, he was -. 9 MR. So according to this, 10 it's saying he left 11 MR. SHU. 12 MR. SHU. 13 MR. Yes. So he should have 14 been keyed out from Special Housing -- 15 MR. And who was 16 MR. -- at that time. 17 MR. -- responsible for keying 18 him out? 19 MR. Control or the OIC in SHU. 20 MR. And who would have been 21 the OIC at that time after you left? 22 MR. At that time, it should 23 have been because he came in at 4:OO. 24 No. he had - would have been more 25 experienced because he worked that floor, so if EFTA00116197 139 1 anything, it should have been , but 2 anybody from SHU could call Control, "Control, 3 I just lost Fernandez," in that case, "Key him 4 out for me." "Okay." 5 MR. Okay. So the people that 6 are in the SHU may not have been able to do it 7 themselves is what you're saying? 8 MR. Correct. 9 MR. So they should have 10 contacted Control? 11 MR. Yes. 12 MR. And Control should have 13 made that 14 MR. Made that change, yes. 15 MR. : All right. 16 MR. But now, Control cannot 17 make the change if they do not know about it. 18 MR. Right. And in this case, 19 we know that that key - the key - he wasn't 20 keyed out until midnight -- 21 MR. Correct. 22 MR. • -- so likely that 23 notification wasn't made. 24 MR. Right. They probably just 25 took him down to R&D, like if he was leaving EFTA00116198 140 1 the building, made out count for him and just 2 forgot about him. 3 MR. And that 38 would verify 4 if Fernandez in fact was gone from the SHU at 5 3:15 p.m.? 6 MR. Yes. 7 MR. Okay. So we got to get 8 that 38. 9 MR. Where can we access that 38? 10 MR. On SENTRY. 11 MR. SENTRY has it? 12 MR. Yes. 13 MR. All right. Is there 14 anything else before we move on, kind of -. 15 MR. You covered that. 16 MR. We kind of really covered 17 it. I just wanted to make sure. That was kind 18 of the primary reason for - I wanted to make 19 sure what your opinion was on that whole thing 20 and specifically if that indicates to you that 21 those counts were not actually conducted. And 22 again, for my understanding, from your 23 response, you believe now that they were not 24 conducted, correct? 25 MR. Correct. EFTA00116199 141 1 MR. And that's if Fernandez 2 was in fact moved at 3:15. 3 MR. ight. 4 MR. All right. Just, I know 5 there's a lot of documents. Can you just make 6 sure that whatever we reviewed here, just 7 initialing, date the tops of them. 8 MR. Did you show him the 5:30? 9 Now, right? 10 MR. : Yeah, because I showed 11 him that that was the good count for the 12 counts. It started that day. 13 MR. You got one more. 14 MR. It's been pain in the ass, 15 man. 16 MR. Yes, it has. 17 MR. Excuse me. 18 MR. Again, it's just -- 19 MR. Excuse me, guys. 20 MR. you know, there's a 21 lot of documents that we talked about. 22 MR. Just like, man. 23 MR. All right. So, how oft- 24 being that we believe now that those counts 25 were falsified by staff working the SHU, how EFTA00116200 142 1 often were counts falsified by staff in the SHU 2 and was this a common practice? 3 MR. See, that happened four 4 years in and I was just working the SHU for 5 about almost, I would say, six months. So from 6 - again, when I started working in the SHU, it 7 was six of us throughout during the day. By 8 the time I got out of SHU, it was three of us. 9 So when I - it's human nature, people get lazy, 10 but the whole time that I was there, I didn't 11 hear about, "Oh, this guy is going to write the 12 rounds," or, "This guy is going to count," and 13 just give in the slips. So, again, I was 14 pretty new in SHU. I've always worked the unit 15 and when I counted the unit, I had to count 16 with somebody. 17 MR. Did anyone ever, since 18 you were new to the unit, ever tell you, "Oh, 19 this is the way we do it in SHU, we don't 20 actually do counts." 21 MR. No. No. 22 MR. : So you -. 23 MR. I worked with pretty - some 24 solid guys then. 25 MR. So do you know of anybody EFTA00116201 143 1 that were falsifying their counts? 2 MR. No. 3 MR. Would it surprise you if 4 those people we just discussed, specifically I 5 guess it's since Noel was new, would it 6 surprise you if falsified a count? 7 MR. , I don't think he 8 would. 9 MR. You don't think he would 10 falsify it. 11 MR. I don't think he would 12 falsify a count. 13 MR. All right. 14 MR. Noel, I didn't know too 15 much. 16 MR. : But being that we, you 17 know, somehow they miraculously get the same 18 number that the institution had because 19 Fernandez wasn't keyed out, that doesn't make 20 you believe that it was falsified, correct? 21 MR. : I don't know how to answer 22 that. I would hope not. I really would hope 23 not, but it's kind of too easy to figure out. 24 MR. Right. 25 MR. Again, I think -. EFTA00116202 144 1 MR. So the evidence suggests 2 he did, you just hope it's not 3 MR. Correct. 4 MR. Okay. 5 MR. Correct. 6 MR. So, but knowing him, 7 there's no reason for you to believe that -. 8 MR. That he actually did 9 falsify. 10 MR. Right. So you don't 11 believe him to be a very dishonest person. 12 MR. Correct. And he left that 13 work, that 10 o'clock because he relieved me 14 from 2:00 to 10:00, so. 15 MR. Right. So is he - he's a 16 good employee otherwise? 17 MR. Yes. He would have did the 18 4 o'clock count. He should do the 10 o'clock 19 count, but sometimes we leave at 9:50. 20 MR. Sure. 21 MR. And then, there's always 22 two people left, so the two people could 23 conduct the count. 24 MR. IIIIIIIIIII Is still here at 25 the MCC? EFTA00116203 145 1 MR. Yes. 2 MR. : What's his current 3 position? 4 MR. 5 MR. Senior Officer 6 Specialist? Okay. 7 MR. 8 MR. He's a Senior Officer. Just a Senior Officer. Just Senior Officer? 9 Okay. So do you recall what conversations you 10 had with SHU staff who worked on August 9, 11 2019, including Michael Thomas and Tova Noel 12 about making entries related to counts and 13 rounds? So, specifically what I'm asking here 14 is that you're the OIC. Do you remember any 15 conversations that you would have had with any 16 of the people that worked in the SHU? 17 MR. Well, I didn't see Noel. 18 MR. I don't mean 19 MR. The 9th? 20 MR. I don't mean on the 9th - 21 - 22 MR. Like -. 23 MR. -- people that worked on 24 the 9th, did you ever have conversations with 25 the people that worked on the 9th about, "Make EFTA00116204 146 1 sure you're doing it correctly and this is how 2 it's supposed to be done." 3 MR. I do, I would say, "Do what 4 you're supposed to do," as I'm leaving. 5 MR. : Yeah, yeah, yeah. 6 MR. "Don't fuck it up. Do what 7 you got to do." 8 MR. And do you follow what 9 I'm saying though? I'm not saying that you 10 would have had a conversation with them on the 11 9th. I'm saying -- 12 MR. Like in general? 13 MR. : -- of the people that 14 worked on the 9th. So these people are the 15 ones like Noel, , you know, these 16 are the people that actually worked on the 9th. 17 Ever leading up to the 9th, so any day leading 18 up to the 9th, would have you had a 19 conversation with them to say, "Make sure 20 you're doing your rounds and counts correctly." 21 MR. Yep. I'm sure I've told 22 them - because everybody wants to work SHU. 23 SHU is a pain in the butt, but, if you want to 24 work SHU, you got to do your rounds and do your 25 stuff how you're supposed to do it. EFTA00116205 147 1 MR. : All right. Can you 2 remember any specific conversations or when 3 those conversations would have taken place? 4 MR. Probably walking around, 5 talking to them, seeing during or watching 6 (Indiscernible *01:49:49) anybody. Thomas has 7 been working for the Bureau for a very long 8 time, even before I did, so he's worked SHU 9 before and he knows what to do in SHU. 10 MR. : Right. 11 MR. But he's not - he works in 12 a different department. But -. 13 MR. What about the newer 14 people like -- 15 MR. =ewer people? Everybody -. 16 MR. Tova Noel? She's 17 newer to the - she was reportedly been at post, 18 you're the OIC, do you know if you had any 19 conversations with her or would have you? 20 MR. I would have said, "Do what 21 you got to do. Don't fuck it up for us." Just 22 like that. But that's just the way I speak. 23 MR. When you say, "Do what 24 you got to do," though, what does that mean? 25 MR. Follow the rules and do EFTA00116206 148 1 what's according to policy. 2 MR. Okay. So not, do what 3 you got to do, it's like, do what you're 4 supposed to do. 5 MR. Do - do - yeah, I should 6 have rephrased it a little bit, but that's the 7 way I speak to everybody -- 8 MR. Yeah, yeah, yeah. 9 MR. -- so it's pretty much, 10 we're cool, but I'm still telling you to do 11 what you have to do based on the policy, make 12 sure you do anything that's not supposed - that 13 you're not supposed to - against policy. If 14 it's in black and white, that's how you got to 15 do it. 16 MR. Okay. And do you recall 17 ever saying that to Tova Noel being that she 18 was newer? 19 MR. That's - I'm sure I - 20 because again, I speak like that to everybody. 21 MR. Okay. 22 MR. Even now as Lieutenant, I 23 talk to you more as a co-worker than, "I'm your 24 supervisor." 25 MR. Sure. EFTA00116207 149 1 MR. But I always tell everyone, 2 "Do your job. It's simple, just do your job." 3 MR. And I know I'm hammering 4 this, but I mean, are you confident you would 5 have had that conversation -- 6 MR. .es. 7 MR. -- with Tova Noel? 8 MR. .es. 9 MR. Or -- 10 MR. es. 11 MR. -- would have you had 12 that conversation with Michael Thomas being 13 that he's not typically a -. 14 MR. Probably not. 15 MR. No? 16 MR. Just because he has way 17 more time than I do. 18 MR. : Okay. What about 19 MR. the same thing, he 20 worked with us in SHU I think before that or 21 maybe after. He got - I was the SHU OIC during 22 the day and he was the SHU OIC at night. 23 MR. : Okay. So 24 MR. So -. 25 MR. -- knew what to do. EFTA00116208 150 1 MR. Yes. 2 MR. : And he knew the right way 3 to do it. 4 MR. 5 MR. 6 7 MR. Yes. Okay. And what about was 8 pretty new. Excuse me. He was pretty new and 9 I think he already worked for the warehouse. 10 MR. Okay. 11 MR. So, same thing. 12 MR. So -- 13 MR. do-. 14 MR. -- if was working, 15 was the OIC at night? 16 MR. Yes. 17 MR. So would do you 18 believe, have had that conversation with 19 IIIIIIIII 20 MR. Yes. 21 MR. : To do what's -. 22 MR. Same thing with Shakir, he 23 would have, "Hey, do the right thing." 24 MR. : Okay. And you didn't 25 work on August 10th you said, correct? EFTA00116209 151 1 MR. Correct. 2 MR. : Is there any way you 3 would have been able to know if the counts on 4 August 10th were correct? 5 MR No. 6 MR No. 7 MR No way. 8 MR What - I know we just 9 talked about it, but what is the daily 10 Lieutenant's log? 11 It's a log that we have in 12 the system that every Lieutenant has to pretty 13 much fill out every single day and make sure 14 it's accurate right before their shift ends. 15 MR. Does a Lieutenant have 16 their own Lieutenant's log or is it an overall 17 Lieutenant's log? 18 MR. It's an overall 19 Lieutenant's log. 20 MR. So every Lieutenant has 21 access to that same log. 22 MR.IIIIIIIII Correct, it's on the share 23 drive. 24 MR. So I was going to say, 25 where can it be found and accessed? What's the EFTA00116210 152 1 share drive? 2 MR. IIIIIIIII The share drive, you log 3 into - well, here in this building, you log in, 4 you go to I think it's the G drive, double 5 click and you're going to see Lieutenant's log. 6 MR. : So is it just like a 7 document and you'd go into like a shared folder 8 or would be on something like a SENTRY or 9 (Indiscernible *01:53:09)? 10 MR. Share folder. 11 MR. A share folder? So just 12 a document that you create every day -- 13 MR. Yes. 14 MR. -- and you - so it's not 15 actually in a system? 16 MR. 17 MR. 18 MR. No. : All right. It's in a share folder. 19 It's not like on TRUSCOPE or SENTRY or anything 20 like that. 21 MR. And at the end of the 22 day, is that then uploaded into some kind of 23 BOP system? 24 MR. It stays on the drive and 25 once you log in, you open the Lieutenant's log, EFTA00116211 153 1 you make the changes to the number, you save it 2 and every day it gets saved. 3 MR. : Okay. And is there 4 anything that's done with that though? Is it 5 then uploaded into something or it just stays 6 in the share folder? 7 It stays in the share 8 folder, from my knowledge. 9 MR. Okay. And does anyone 10 aside from Lieutenants have access to change 11 that log? 12 MR. No, just the - well, the 13 Captain, the AW and the Warden. 14 MR. Yeah. 15 MR. But -. 16 MR. So Lieutenants and above? 17 MR. Correct. 18 MR. Nobody below a 19 Lieutenant? 20 MR. : Nobody below Lieutenant. 21 MR. What about the people in 22 Control? 23 MR. No, they don't have access 24 to that. 25 MR. So even Control doesn't - EFTA00116212 154 1 - 2 MR. No. 3 MR. -- can't manipulate -- 4 MR. No. 5 MR. -- the Lieutenant's log? 6 MR. Correct. 7 MR. Okay. And I don't know 8 that you'll be able to answer this, but are the 9 times listed on the Lieutenant's log that you 10 just reviewed accurate? 11 MR. I don't know. 12 MR. Is it all based upon 13 whoever is entering it? 14 MR. Yes. 15 MR. Okay. Is there any kind 16 of a verifying process? Like does anybody 17 oversight over that to kind of audit the 18 documents? 19 MR. The only way you could 20 verify it and the only thing would be the 21 moves. So if inmate movement in the 22 institution, you could verify it because you go 23 to the PB-38. 24 MR. And who creates that 25 document, the 38? EFTA00116213 155 1 MR. : The 38? You would call 2 Control, "Inmate Joe Smith left today." Or, 3 "Inmate Joe Smith was in 11 South, he was 4 moved." "Okay." I could call downstairs at 5 1O:3O, that's the time he moved, but it could 6 be off within a couple of - it could be off a 7 few minutes -- 8 MR. So even -. 9 MR. -- because Control has to 10 key it in. 11 MR. All right, so, that's 12 something that's created by Control. But what 13 we just said, we were going to use that to 14 verify if Fernandez left at 3:15, if the people 15 in the SHU never called Control to log 16 Fernandez out, would that be listed on the 38? 17 MR. No. 18 MR. So therefore, that might 19 not actually be the accurate document because 20 if they didn't call, the BP-38 wouldn't 21 (Indiscernible *O1:55:27). 22 MR. The 38 would only verify 23 the movement and the time that it was keyed in. 24 MR. : That it was keyed. 25 MR. Correct. EFTA00116214 156 1 MR. So if it wasn't keyed 2 until midnight, which -- 3 MR. hen 4 MR. what the Lieutenant 5 said, like, "I found out that this person moved 6 earlier and he's actually in a different 7 location, I needed to make that key change at 8 midnight." 9 MR. The time that he -- 10 MR. : That's what -- 11 MR. -- actually moved? 12 MR. : -- reflected on the 38. 13 MR. Correct. Because it's the 14 time, not the time it was keyed in the 15 Lieutenant's log -- 16 MR. All right. So there -. 17 MR. -- because I can change 18 those logs. 19 MR. So in this instance, the 20 38 would actually be incorrect if he wasn't 21 keyed out when he actually moved. 22 MR. Correct. It wouldn't be 23 anything because he was never keyed. 24 MR. All right. So therefore, 25 this 38 actually would make it even more EFTA00116215 157 1 confusing. 2 MR. Not really because it would 3 tell you if he got moved and at what time he 4 got moved. 5 MR. All right. So the 38 6 would list probably the same thing in the 7 Lieutenant's log, that's at midnight, Fernandez 8 was moved at 3:15 p.m. to dry - from ZA. 9 MR. So the 38 would have the 10 actual time he was keyed in. 11 MR. : Yeah, the keyed. 12 MR. So it would show you - 13 let's say the Lieutenant said she didn't find 14 out or he didn't find out until midnight that 15 this inmate, Fernandez, was moved and never 16 keyed out. She keys him out, now the date on 17 the 38 would be August 10th because it's after 18 midnight. 19 MR. Right. 20 MR. August 10th, 1:45 in the 21 morning, that's what the 38 would say. But in 22 the log, it would say he got moved at 3:30, 23 because that's when -. 24 MR. In the Lieutenant's log. 25 MR. Correct. EFTA00116216 158 1 MR. So in this case, probably 2 the Lieutenant's log is the more accurate one. 3 MR. Yes. 4 MR. All right. Good to know. 5 MR. Just had a question. If 6 you're moving an inmate, right, doesn't the 7 outer doors of the SHU have to be buzzed by 8 Control? 9 MR. Yes. 10 MR. When Control - does Control 11 have eyes on 12 MR. Yes. 13 MR. -- on - wouldn't they see an 14 inmate being moved? 15 MR. Yes. 16 MR. nd wouldn't they question, 17 "How come he's not keyed in?" 18 MR. Well, depending on the 19 time. So like when let's say it was between 8 20 o'clock in the morning and 2 o'clock in the 21 afternoon, inmates are going in and out, in and 22 out, even SHU, like medical, dental, court, 23 attorney visits. So now you have six, seven 24 inmates going in and out, not at all times 25 you're looking, "Oh, is an inmate coming out," EFTA00116217 159 1 they pop - you know, you call for the door. 2 You probably could just open the door right 3 there, but then have to run to the window, give 4 somebody a set of keys. 5 MR. Okay. And then just to 6 clarify on that same question. If that PB-38 7 will show the key in time of when the 8 Lieutenant puts it in, what do you think the 9 Lieutenant or whoever updated that document got 10 the 3:15 time? 11 MR. Or she called R&D and said, 12 "Hey, what time this inmate got downstairs?" 13 "Oh, he came around 3:30." "All right. Well, 14 you should have told me, you know, key him 15 out," or whatever. 16 MR. At midnight, would that 17 employee that was on shift during evening watch 18 still be on there? 19 MR. ep. 20 MR. What was that last 21 question? Was what? 22 MR. The employee in R&D, would 23 that person still be on shift at midnight. 24 MR. What is the time for the 25 shifts -- EFTA00116218 160 1 MR. So, it would be -. 2 MR. -- in R&D? 3 MR. The shifts are 4:00 to 4 12:00, 4:00 to midnight. But usually, if 5 you're on dry cell -- 6 MR. Yeah. 7 MR. -- watching somebody, you 8 would not leave exactly at midnight. You would 9 leave a couple of minutes after unless you were 10 doing a double doing dry cell. 11 MR. : All right. Let's talk - 12 the fact that that this guy Fernandez wasn't 13 specifically tied to Epstein, is there any 14 chance two years later we're going to be able 15 to talk to anybody to verify when he got the 16 dry cell? 17 MR. No. He probably is not 18 even in the institution anymore, Fernandez. 19 MR. That's what I mean. So 20 like even talking to R&D, do you think that 21 there's any way that they'd even remember when 22 this guy placed down there? 23 MR. No, because who knows who 24 was in R&D that day, who knows if they're still 25 working here. EFTA00116219 161 1 MR. But what about, like for 2 instance, we have the count slips at least for 3 10:00 p.m. Actually, where there was no count 4 slip for him at 4:00 p.m. but we have the count 5 slips for R&D and RA at 10:00 p.m. and 6 midnight. Do you believe that even they would 7 be able to recall if it was Fernandez that they 8 watched? 9 MR. No. No. 10 MR. And why is that? 11 MR. Just because a lot of 12 inmate movement. 13 MR. How reliable do you 14 believe that that Lieutenant log saying that he 15 left at 3:15, how reliable at this point, us 16 looking at it back then and the person making 17 that change potentially at midnight that night, 18 how reliable do you view that 3:15 time? 19 MR. If it's Lieutenant 20 that's - she's very by the book. I'm 21 not saying that everybody else is not. 22 MR. Right. 23 MR. But and she knows her job. 24 MR. Do you -. 25 MR. So if that would probably EFTA00116220 162 1 be maybe the only Lieutenant, especially on 2 morning watch, that would catch a mistake like 3 that. 4 MR. : Okay. 5 MR. And she - numbers didn't 6 add up, she went back and changed it, made it 7 accurate 8 MR. Okay. And certainly you 9 believe that the institutional count was made 10 accurate for her, but what I guess I'm 11 specifically requesting, you know, wondering, 12 how accurate do you think she would have made 13 the movement of 3:15 moved ZA from - or moved 14 to dry cell from ZA? 15 MR. Very. 16 MR. Very? 17 MR. Very accurate, yes. 18 MR. So you believe that that 19 3:15 then is probably the right time? 20 MR. Around the time that he got 21 moved, yes. 22 MR. Okay. Sounds good. And 23 no one in the SHU has access to the 24 Lieutenant's log? 25 MR. No. EFTA00116221 163 1 MR. All right. We're going 2 to move on now. 3 MR. Oh, sorry. 4 MR. What - no, I'm sorry, 5 this is - again, like I said, you're kind of 6 like - when I saw that one page interview 7 report, I was like, "Oh, this is the guy that, 8 you know, has all the answers." But what is 9 the MCC policy on conducting cell searches in 10 the SHU? And let's specifically talk about, if 11 you can remember, in August. So in August of 12 2019, do you remember what the MCC policy was 13 on conducting cell searches in the SHU? 14 MR. You got to conduct cell 15 search every time an inmate comes out. I don't 16 know if that's actual policy or not. 17 MR. Was it something like 18 some of the shifts you had to do five cell 19 searches -- 20 MR. Per shift 21 MR. -- during that shift? 22 MR. Yes. 23 MR. Or if the person may be, 24 you know, in the day watch, maybe if someone 25 went to rec, you're supposed to -. EFTA00116222 164 1 MR. So, the way we did it, you 2 came out to the shower, that was our cell 3 search. 4 MR. Okay. 5 MR. So, every Monday, Wednesday 6 and Friday we showered everybody, everybody's 7 cell was searched. 8 MR. So every Monday, 9 Wednesday and Friday everyone's cell was 10 searched? 11 MR. Yes, because everybody got 12 a shower. So we took that as okay -. 13 MR. And officers would 14 actually go in and search their cells? 15 MR. Yes. 16 MR. Okay. And what about the 17 non-shower days, how would you do searches or 18 would you -. 19 MR.M= When somebody went to rec, 20 when somebody went to R&D, if somebody has to 21 go to medical, we'll bring you out and we 22 search the cell. 23 MR. : Okay. And then, what is 24 the responsibility of the SHU OIC with regard 25 to SHU cell searches, if anything? EFTA00116223 165 1 MR. To make sure they're logged 2 in and make sure they get conducted. 3 MR. Okay. So like, is the 4 OIC the one - were you the one that would 5 actually log them into like TRUSCOPE? 6 MR. : Well, anybody could log 7 them in but most the time I did it or I was 8 searching the cell myself. 9 MR. : And what is the 10 responsibility of the SHU Lieutenant with 11 regard to cell searches, if any? 12 MR. To make sure the OIC got it 13 done. 14 MR. Okay. And were cell 15 searches being conducted and logged in to 16 TRUSCOPE for the SHU in August of 2019? 17 MR. hey should have. Yes. 18 MR. All right. So we 19 requested to - just because we're going to get 20 into what was found in Epstein's cell later, 21 but you're the one who logged this in, but we 22 only found one cell search for June 9, 2019. 23 MR. August 9th. 24 MR. Or sorry, August 9 - is 25 that June 9th or August 9th? What does that EFTA00116224 166 1 say? 2 MR. August 9th. 3 MR. : Okay. August 9, 2019. 4 Does that - would that be normal that there 5 would only be one logged in? 6 MR. : No. Again, it's depending 7 what was going on during the day -. 8 MR. : So that would have been 9 one of those shower days, I guess, though. 10 MR. And I worked - yes, from 11 1:00 - I worked until 2 o'clock that day. 12 MR. : But do you believe that 13 there was only one cell search conducted or do 14 you believe that there were more? 15 MR. There was one cell search 16 probably logged in. 17 MR. Okay. But all of them 18 were conducted? 19 MR. ould have been conducted, 20 yes. 21 MR. And do you believe that - 22 I know we're talking two years ago. Do you 23 believe that all of them were conducted? 24 MR. The majority. 25 MR. Yeah. EFTA00116225 167 1 MR. The majority. 2 MR. Any reason - do you know 3 if Epstein's cell would have been searched on 4 August 9th? 5 MR. It should have been because 6 him and Reyes both left at the same time. 7 MR. Right And who would 8 have done that cell search? 9 MR. Well, took them out to the 10 shower. 11 MR. Okay. And is that like 12 everybody? Does everybody - how does that 13 work? Who 14 MR. So, technically the OIC is 15 not supposed to - he has the big set which is 16 the keys to the - on the ranges and the door 17 and everybody else goes in and out the tiers. 18 MR. Okay. 19 MR. But we were all involved. 20 We all moved inmates from this tier to another 21 tier. Okay, "You two on that side, okay, bring 22 them out," search their cell. If I'm on this 23 side, I'm going to bring them out, do the cell 24 search. 25 MR. Okay. And this isn't - EFTA00116226 168 1 I'm not trying to be and I gotcha, at all at 2 any moment, I'm just trying to get a greater 3 understanding. So if all of the cells were 4 searched, why would only one search be entered 5 for that day? 6 MR. I'm busy during the day. 7 MR. And was that like does 8 that happen often though like it's too busy to 9 actually log the searches in? 10 MR. The system is kind of a 11 pain in the butt because you've got to do one 12 by one by one, you know, unless you do all of 13 them. I mean, unless you do one, then enter, 14 then another one and enter. It's not like you 15 could do multiple cell searches or click them 16 that you did them at one time. 17 MR. Okay. Now it's my 18 understanding that after you left, the night 19 watch is then responsible for conducting on 20 every shift, five cell searches, correct? 21 MR. Yes. 22 MR. And who would have logged 23 that in? 24 MR. Anybody could have logged 25 it. EFTA00116227 169 1 MR. Anyone? 2 MR. But it should be the OIC. 3 MR. So that would have been 4 who should have done that? 5 MR. Correct. Yes. 6 MR. : All right. And does the 7 fact that you had your one that you entered 8 earlier in the day, the fact that there's none 9 for the rest of the day, is that problematic in 10 your opinion? 11 MR. Not really because 12 throughout the day, we pretty much do the 13 showers. So we went into every single cell. 14 MR. Okay. 15 MR. Now maybe it should have 16 been keyed so it could reflect because if 17 there's no cameras, you can say, "Yeah, all 18 right," -- 19 MR. Right. 20 MR. -- you only did one because 21 you keyed in one. But, you know, they should 22 because they also have rec at night time. When 23 you bring back an inmate or you bring them out 24 to attorney visit, you're still bringing the 25 inmates out. EFTA00116228 170 1 MR. : Okay. 2 MR. So they should have been 3 keyed in. 4 MR. So although they were not 5 keyed in, do you believe that they were being 6 conducted on August 9, 2019? 7 MR. Yes. 8 MR. Yes? 9 MR. Yes. 10 MR. What about after you 11 left, do you believe that there would have been 12 - the five cell searches would have been 13 conducted on 2019 at this point? 14 MR. They should have because I 15 know we had legal visits and maybe we had 16 regular like visits for the inmates with their 17 family members. 18 MR. Do you recall, what is 19 the policy at least in August of 2019 related 20 to what inmates are allowed to have in their 21 cells? 22 MR. Well, no contraband of 23 course. Five hard cover books only. 24 MR. : What about like medical? 25 MR. Two sheets, one blanket. EFTA00116229 171 1 2 3 If you have the CPAP machine, you can get that. MR. How - and just for the record, how do you spell that? What is it? 4 That machine? 5 MR. What, the CPAP? 6 MR. Is it CPAC or CPAP? 7 MR. CPAP, CPAP. 8 MR. Is it for snoring? 9 MR. Yes. 10 MR. That's what you're 11 talking about? So you can breathe better? 12 MR. .es. 13 MR. Okay. 14 MR. o CPAP, right? 15 MR. I actually don't know. 16 MR. is it? 17 MR. That's why I was asking. 18 MR. Is it C-P-A-P? 19 MR. I think that's what it is. 20 Not even sure. But it was a machine that you 21 use to help you breathe in the middle of the 22 night -- 23 MR. : I just know 24 MR. -- and you go to sleep with 25 it. EFTA00116230 172 1 MR. (Indiscernible *02:08:22). 2 MR. I just know the 3 transcriber for this would be like, "What the 4 heck is he saying?" 5 MR. Is that for sleep apnea? 6 MR. Yes. That's - I think it 7 helps you - it clears your whatever it is, your 8 nose or your throat so you can be able to 9 breathe better in the middle of the night. 10 MR. : And I did interrupt, I 11 apologize, when you were getting into the 12 linens. How many sheets and blankets and all 13 that? Can you 14 MR. It should be - if it's 15 August, it should be two sheets, one blanket. 16 MR. Two sheets, one blanket. 17 That's for each individual -- 18 MR. Yes. 19 MR. -- inmate. So, for each 20 cell, if there's two inmates, it would be four 21 sheets and two blankets. 22 MR. Correct. 23 MR. : Okay. 24 MR. And the wintertime, it's 25 two sheets, two blankets. EFTA00116231 173 1 MR. : Okay. Was Epstein 2 authorized to have pills in his cell within the 3 SHU? 4 MR. Well, if you have 5 medication, yes, you can have your own 6 medication. 7 MR. And that's - okay. 8 MR. We don't set a number on 9 that. 10 MR. Who is responsible for 11 determining what medication inmates have? 12 MR. The Medical Department. 13 MR. And do they provide it to 14 them? 15 MR. Yes. 16 MR. And then they're able to 17 just keep it in their cell and take it? 18 MR. Yes. 19 MR. Is there ever a problem 20 with like overdose or anything like that? 21 MR. I mean, we've had inmates 22 take more than they're supposed to take. 23 MR. Is it dependent upon what 24 type of medication if they can have it in their 25 cell or not? EFTA00116232 174 1 MR. IIIIIIII: So, certain medication, the 2 pill line, which is Medical, they'll come 3 around and give it to you daily if that's what 4 - you're only supposed to have it daily, 5 Medical Department will come around and give it 6 to the inmates themselves. 7 MR. : Okay. 8 MR. Anything else, if you have 9 your own medication, it would be in your cell. 10 MR. Okay. I'm going to just 11 show you some pictures of August 10th and I 12 just wanted, if you can just kind of let me 13 know what I'm looking at. Is this L Tier, is 14 that where Epstein would have been housed? 15 MR. Yes. 16 MR. : Okay. And then another 17 picture of L Tier. This wasn't his cell there. 18 MR. No. 19 MR. Do you remember what cell 20 number he was in? 21 MR. I know exactly. It was the 22 first one to the right, 221 maybe? 23 MR. 221 or maybe 222 or 24 something? 25 MR. (Indiscernible *02:10:30). EFTA00116233 175 1 MR. All right. I think it's 2 220, but is this his tier? 3 MR. That's L Tier, yes, here on 4 the right. 5 MR. Does this look like it 6 would have been - it looks like it would have 7 been 220. 8 MR. eah. 9 MR. But would that have been 10 Epstein's cell? 11 MR. Yes. 12 MR. All right. So 220 was 13 the first door on the right when you're walking 14 down the -- 15 MR. Yes. 16 MR. -- the tier? 17 MR. hen you walk into - yes. 18 MR. All right. So, I want to 19 just - I'll let you look through these. Can 20 you just let me know if this looks like an 21 abnormal amount of linens and blankets and 22 clothing? And we don't know, so that's why 23 we're asking. And that's again, not a gotcha, 24 I don't know if it's more than should be or 25 what. EFTA00116234 176 1 MR. : No, I think this was his 2 and his bunkie's. 3 MR. So does that make you 4 believe that his bunkie's was never removed? 5 And when should have they been removed? 6 MR. As soon as they figure out 7 that he's not coming back. 8 MR. So at either 4:00 p.m. or 9 certainly before 8:00 p.m.? 10 MR. Yes. 11 MR. : Would it have been when 12 Epstein was returned to attorney client visit, 13 definitely at that time, should have they made 14 sure -. 15 MR. : Well, by 8 o'clock, they 16 should - while walking Epstein back into the 17 cell, they should have said, "Oh shit, he 18 doesn't have a bunkie," and, "Oh shit, his 19 bunkie is gone." 20 MR. All right. So by looking 21 at those photos, you just believe that that was 22 actually both Epstein and Reyes's? 23 MR. Yes. 24 MR. Okay. 25 MR. It probably -. EFTA00116235 177 1 MR. So it does look like more 2 than one inmate so it looks like that would be 3 the amount of linens and clothing for two 4 inmates? 5 MR. Well, probably a couple of 6 extra sheets in there. 7 MR. And do you know if 8 Epstein was provided extra sheets than he was 9 supposed to have been provided? 10 MR. He shouldn't have. 11 MR. Can you just explain to 12 me, how does that work? How does the process 13 14 MR. : Well, when the inmate comes 15 into the Special Housing Unit, we give them two 16 sheets, one blanket. When they do the showers, 17 we should go in there - initial these two? 18 MR. Please. Not all of them, 19 we just need the top picture. 20 MR. When we should go - when we 21 go in there when we bring them out to the 22 shower, we should go in there and shake it 23 down, that's when we go in there and take 24 anything extra that they're not supposed to 25 have. EFTA00116236 178 1 MR. So if he took a shower 2 that day on August 9th - so you believe from 3 looking at those pictures, he actually had even 4 more than if it were just him and Reyes, he had 5 some extra 6 MR. Yes, he probably had like 7 two extra blankets. 8 MR. Is that an issue? 9 MR. They should never have 10 that. 11 MR. Okay. So, if that cell 12 was searched on August 9th, at that point, 13 someone should have removed them? 14 MR. Yes. Somebody should 15 remove all the extra, left him with what he's 16 supposed to have and nothing more. 17 MR. And on that date, who 18 would have been responsible for doing that? 19 MR. When we brought them out to 20 the shower. 21 MR. So not only do they bring 22 them out to the shower but they also are 23 responsible for (Indiscernible *02:13:15). 24 MR. Correct. Might as well. 25 If you're on the same tier, you put them in the EFTA00116237 179 1 shower, it takes two seconds. 2 So where is the shower? 3 Are the showers on the same tier? 4 MR. Yes. 5 MR. Okay. 6 MR. So on that tier, if you 7 look at his cell, right to the right. 8 MR. So -. 9 MR. This is the shower here. 10 MR. Okay. Like there? 11 MR. Yeah. 12 MR. Okay. So it's kind of 13 like almost in the middle or the start is like 14 almost like the second door. 15 MR. Yes. 16 MR. : This one? 17 MR. No, it's actually, see this 18 little gate? 19 MR. (Indiscernible 20 *02:13:46). 21 MR. You can't really see it. 22 MR. Can you see it from here? 23 MR. No. 24 MR. Like it's the start of 25 the tier? EFTA00116238 180 1 MR. Yeah. So if you come in, 2 you walk in, you kind of make a right turn. 3 You see this gate right here? 4 MR. : Maybe I'll have you - if 5 you can mark it on either SHU map here that 6 we're going to - I'm going to show you for a 7 second just so you can - I'm going to ask you 8 about like the cameras and what cameras should 9 have been in there, that kind of stuff, so you 10 can just show me where. So do you know if 11 Epstein was provided any of these special 12 privileges to have extra clothing or linen? 13 MR. No, I know he should not 14 have. 15 MR. : Okay. 16 MR. But he always asked for a 17 clean uniform every time he showered. 18 Would he give his other 19 uniform -- 20 MR. es. 21 MR. -- back though? 22 MR. es. 23 MR. So what is your believe 24 on why he would have had extra blankets? 25 MR. Somebody who doesn't EFTA00116239 181 1 normally work SHU just said, "Okay," or he 2 probably asked for one because he was cold. 3 MR.-: And how would people that 4 worked in the SHU know what the rules were with 5 as far as exchanging your linens and your 6 clothing? 7 MR. Well, we talk about it. 8 Two sheets, one blanket. 9 MR. Is that not provided at 10 training? 11 MR. I don't remember. I don't 12 think that's in the SHU training, but it also 13 tells you not to have an excess of linen inside 14 the SHU. 15 MR. The training does? 16 MR. es. 17 MR. Okay. So at training, 18 they do say they're not supposed to have, you 19 know, extra? 20 MR. -Correct. 21 MR. And then, from working in 22 the SHU, would it be the OIC to tell people, 23 (Indiscernible *02:15:10). 24 MR. The OIC or anybody who kind 25 of -. EFTA00116240 182 1 MR. Works in there? 2 MR. Because OIC is not always 3 there, so. 4 MR. All right. During 5 showers, who would have been working on August 6 9, 2019 looking at the daily assignment roster? 7 MR. Would have been 8 and myself. 9 MR. Okay. As far as, did you 10 notice that there was an extra mattress in 11 Epstein's cell. 12 MR. There's one on the floor. 13 MR. Yes. We're told that 14 Epstein actually had two mattresses, one on the 15 floor, one on the bottom bunk and then Reyes 16 had one as well. Would that be abnormal that 17 he was provided two mattresses? 18 MR. Definitely shouldn't have 19 happened. Somebody probably felt bad for him 20 because he maybe said his back hurts. 21 MR. Do you know where Epstein 22 slept? 23 MR. Well, this only shows two 24 right here. 25 MR. It's the height of the EFTA00116241 183 1 mattress. 2 MR. I think he slept on the bed 3 and Reyes slept on the floor. 4 MR. Oh, that's your belief? 5 MR. I think so. 6 MR. Oh, we were told the 7 opposite. 8 MR. Opposite? 9 MR. So you believe Reyes was 10 actually on the floor? 11 MR. I think so. 12 MR. Okay. But if they had - 13 if there in fact were three mattresses in there 14 -. 15 MR. There weren't supposed to 16 be three mattresses in there. 17 MR. 18 that happened? 19 MR. When and how would have Maybe one of them wasn't 20 thick enough, somebody else gave him another 21 one or they just didn't see the mattress 22 because a lot of times, the inmates put it on 23 the wall and if you don't physically go inside 24 the cell, you just give them another mattress. 25 MR. : So it - how would they EFTA00116242 184 1 explain the fact that they didn't have a 2 mattress? 3 One would be standing 4 against the wall. 5 MR. : But, I mean, would they 6 say like somebody came in and took it? 7 MR. No, just sometimes we move 8 mattresses around because we're going to put 9 two inmates over there. They only have one, 10 then we'll take it. 11 12 13 14 15 16 17 18 19 20 21 22 MR. problem if there are MR. depending who is MR. MR. Okay. Is that a big extra mattresses then? You're not supposed to, in charge that's there -- Yeah. -- and at night time, if but you don't want to deal with it - well, not me or - but if some people don't want to deal with it, like, "All right, here's another mattress." MR. So what's the purpose of making sure that inmates only have one mattress as well as the correct amount of linens and 23 blankets? 24 MR. Well, the linen because 25 just so we can have for everybody. The EFTA00116243 185 1 mattress, the same thing, you only have one 2 mattress, that's all you're allowed. 3 MR. Are there any kind of 4 security issues that go along with it? 5 MR. Unless it's a troubled 6 inmate, they'll put the mattress to barricade 7 the door. 8 MR. No, I mean like is there 9 any security issues that go along with making 10 sure an inmate doesn't have extra linens or 11 doesn't have extra blankets, is something, 12 like, to do with, like, potentially escaping or 13 harming themselves or anything like that. Is 14 that ever taught or do you know anything about 15 that? Or was it more of an administrative 16 thing? 17 MR. It's more an administrative 18 thing. 19 MR. : Okay. So your 20 understanding was administrative, nothing to do 21 with like harming themselves or escaping. 22 MR. : Right. I don't think the 23 mattress or linen have anything to do with 24 that. 25 MR. : Okay. Who did you say EFTA00116244 186 1 was responsible for making sure that inmates 2 had the correct amount of linens and mattresses 3 and things? 4 MR. Everybody. 5 MR. Everybody? 6 MR. Everybody. 7 MR. Okay. What - can you 8 just explain - we're going to move to the next 9 one. What - did you want to follow up on 10 anything with that? 11 MR. No, no. 12 MR. Can you explain cell 13 rotations in the SHU for me? 14 MR. : Cell rotations have to be 15 conducted every 21 days. 16 MR. Every 21 days? 17 MR. es. 18 MR. And is that like every 21 19 days from the time that the inmate arrives at 20 the SHU or is it like on a set schedule, this 21 is the day, this is the 21st day? 22 MR. GRIJALVA: From the inmate arrives to 23 the cell. 24 MR. : Okay. So every inmate is 25 different. EFTA00116245 187 1 MR. So if an inmate comes in 2 and he's assigned to cell 101 today, within 21 3 days or at 21 days, he needs to move to another 4 cell that is not cell 101. 5 MR. Okay. And who is 6 responsible for kind of making sure that that 7 happens? 8 MR. IIIIIIII: The Lieutenant should 9 oversee but usually we all go and assist them 10 and we have a print out of the 21 - "Oh, this 11 guy is on 18 days, it's time for him to move." 12 "Oh, this guy is on 21 days, let's move him." 13 MR. So is it has to be done 14 by 21 days, it can be done prior to 21? Is 15 that what you're saying? 16 MR. Yes. 17 MR. : Okay. So it's not like 18 the OIC's responsibility, it's everybody's 19 joint responsibility? 20 MR. Yes. As long as you're not 21 in the same cell for more than 21 days, you can 22 move every 15 and you can move every 10 as long 23 as it doesn't go over 21. 24 MR. So, who is like checking 25 to make sure that that's done or is it some EFTA00116246 188 1 kind of an alert that is provided? 2 MR. Excuse me. Usually the OIC 3 and the Lieutenant. 4 MR. MIRRIIIRILIF Are the ones saying, "Let 5 these go." Yeah. 6 MR. "Hey, we got to move these 7 guys." The Lieutenant goes like, "Hey, OIC, 8 you got to get these guys moved." 9 MR. All right. And then 10 after they're moved, who is responsible for 11 keying the movement? 12 MR. Well, the OIC could do it - 13 - 14 MR. Okay. 15 MR. -- but usually we'll call 16 Control. 17 MR. So Control or the OIC? 18 MR. Yes. 19 MR. All right. As the OIC 20 though, is that kind of like your job every 21 21 days to make sure and then you can either call 22 Control or is it -. 23 MR. : Well, I used to do it on my 24 own because I can 25 MR. : Right, right. EFTA00116247 189 1 MR. Instead of calling Control, 2 waiting five minutes for them to pick up, I 3 just do it on my own. 4 MR. : Now are you aware that 5 Epstein was in the wrong cell on August 9th and 6 10th of 2019? 7 MR. No. 8 MR. And so he was in cell 220 9 as we just discussed and in the system he's 10 logged in at 206L. Do you know anything about 11 that? 12 MR. I actually found that out 13 the week after. 14 MR. : (Indiscernible *02:20:49) 15 so, if you found out, do you know why that is, 16 like what happened? Because obviously the 17 conspiracy theorists are going to be all over 18 that if that gets out, that he was in the wrong 19 cell. So, do you know if it would have been 20 one of those things that - was he ever moved or 21 was he just moved in the system or vice versa? 22 Do you know how that 23 MR. I think -. 24 MR. -- discrepancy happened? 25 MR. I think what happened was EFTA00116248 190 1 when he was moved up from suicide watch, he was 2 placed in, let's say, 206. And then, after he 3 went to attorney conference, when they got him 4 with his bunkie - I mean, once, let's say, he 5 went - he did go to attorney conference, "Okay, 6 he's coming back, we're going to put him with 7 this bunkie," we're just going to move him and 8 somebody forgot to key him in to the right 9 cell. 10 MR. So do you know if Epstein 11 was ever in a different cell other than 220? 12 MR. IIIIIIIII No. He was actually with 13 Tartaglione. 14 MR. So that was - so when he 15 was with Tartaglione prior to July 23rd, he was 16 actually in a different cell? 17 MR. Yes. 18 MR. Is that listed on that? 19 Does it show? 20 MR. Trying to remember what 21 cell is downstairs right from above that one. 22 MR. Well, I have a list of 23 the SHU map if that helps you out. It's the 24 first and second floor. I can't remember which 25 one is the first page and - I would just assume EFTA00116249 191 1 that whatever L Tier is on, that's the second 2 floor, correct? 3 MR. : Yes. Now -. 4 MR. So the letter corresponds -. 5 MR. The numbers are off -- 6 MR. Yeah. 7 MR. -- on that for some 8 reason. 9 MR. Definitely. 10 MR. And we all - and we can't 11 explain that, why that SHU map shows the wrong 12 letters or the wrong numbers, I mean. Seems 13 like they say the wrong - they show the wrong 14 or the correct letters although the numbers 15 appear to be wrong. 16 MR. This is also - I'm not - is 17 this the second floor? 18 MR. : Here, let me see. 19 MR. I'm not 20 MR. : My understanding would be 21 since this says, "L," that this would be the 22 second floor and this would be the first floor. 23 Is H, K, M, are they on the first floor? 24 MR. Yes. H is on the bottom. 25 MR. So H is on the - H is not EFTA00116250 192 1 even on the same thing as K and M? Oh yeah -- 2 MR. They're on 3 MR. -- because this is 4 showing -- 5 MR. They're on -. 6 MR. -- stairs, so I guess - 7 so is this like - this is what you're - is 8 there like three levels then? 9 MR. No, there's only two, but 10 so H is downstairs, GT is right upstairs and 11 then there's J, K, L, M. 12 MR. So does this not make 13 sense the way that this is -. 14 MR. o, not really. 15 MR. So, okay. So even 16 looking at this, this doesn't even add up 17 MR. No. 18 MR. -- the way you're looking 19 at it? 20 MR. Because this is the 21 officer's station and the office is the second 22 floor G Tier. This is a weird - but he 23 MR. So this doesn't add up to 24 you? So we're going to have to see about 25 getting a different SHU map. EFTA00116251 193 1 MR. No. 2 MR. But, from your 3 understanding, does this kind of look right 4 though? If this is the officer's station over 5 there, is this where -- 6 MR. o 7 Epstein was housed? 8 Looking at it that way? 9 MR. No, so this is the office. 10 That probably means the Lieutenant's office 11 which is on the second floor -- 12 MR. So that's the LT's 13 office? 14 MR. -- right next to G Tier. 15 Correct. 16 MR. : Okay. So that's where 17 MR. And then recreation -- 18 MR. • • we thought this was 19 MR. -- would be downstairs. 20 MR. : So this office and this 21 are not even on the same floor? 22 MR. No. This is on the second 23 floor and this is downstairs. 24 MR. All right. 25 MR. So these might be the EFTA00116252 194 1 original blue prints where the rooms might have 2 been changed over time. 3 MR. All right. Yeah, we're 4 probably going to have to just as the SIA to 5 give us a tour. Where - so if this is - if 6 we're going to assume that this is the second 7 floor -- 8 MR. That's if -. 9 MR. 10 MR. That's LT and then the 11 officer's station should be right here. 12 MR. Right here? 13 MR. ecause I could look up to 14 the office. 15 MR. So I'm going to write : -- because it has L. 16 this circle where you're pointing and just put 17 OS for Officer's Station. And this would be 18 Epstein? 19 MR. Yes. 20 MR. I11 write E there. 21 MR. And this is the shower 22 MR. Does -. 23 MR. -- like I was telling 24 earlier. 25 MR. Oh, so this is the shower EFTA00116253 195 1 here? All right, so shower is actually outside 2 of the tier. 3 MR. Yes. 4 MR. Shower. And then, if 5 this is 220, where would 206 be? 6 MR. 19, 18 -- 7 MR. It's all the way down? 8 MR. -- 17, 16, 15, 14, 13. 9 MR. Or is there even? I 10 mean, this sheet says 206 -. 11 MR. How many cells are in there? 12 MR. There's four on one side 13 and four on the opposite side. 14 MR. And would you understand 15 it to mean 206L for 206 L Tier? 16 MR. No, 206 is lower. That's 17 the -. 18 MR. Oh, so this wouldn't even 19 mean that he was on the L Tier. 206 -. 20 MR. Lower and then like upper. 21 MR. Because this is where it 22 says, if I'm reading this correctly, does it 23 say that on 8/10/2019 that's where he should 24 have been assigned -- 25 MR. Correct. EFTA00116254 196 1 MR. -- 206 lower? Does that 2 show you at all - it says, "Z range," right? 3 MR. Yeah. So -. 4 MR. What does that -- 5 MR. So -. 6 MR. show you that where 7 it's saying that is that he was assigned? And 8 it seems like he had a lot of assignments in 9 there. 10 MR. So H is the suicide watch. 11 MR. Okay. So where it says, 12 "H," next to -. 13 MR. : So he went from 201, which 14 that's G Tier, to suicide watch on the 8th of 15 August, then he went to SHU. 16 MR. The 8th of August? 17 MR. Of July, I'm sorry, of 18 July. DOS. 19 MR. So July 23rd is when he 20 should have been placed in the -. 21 MR. hat's when actually -. 22 MR. And July 30th he should 23 have returned. 24 MR. July 23rd he was in suicide 25 watch. EFTA00116255 197 1 MR. Right. 2 MR. July 29th, he went to SHU - 3 - 4 MR. What -. 5 MR. -- and -. 6 MR. What cell was he placed in? 7 MR. 206 on July 29th. Then 8 hmm. He has - so he was never placed on 220. 9 We never keyed him in to 220. 10 MR. Well, does it show that 11 he was in 206 ever since the time he came back? 12 MR. Yeah. 13 MR. ould you -. 14 MR. So it says the 29th he was 15 in H001 then the next day - the next date would 16 be 206. 17 MR. And by the number 206, 18 does that tell you at all where that is in the 19 SHU? 20 MR. 206, I have to -. 21 MR. I mean, do they - is it 22 so each tier doesn't have like their own 23 number? Is it just, you know, 206 could be 24 like G Tier or 25 MR. So I think - little EFTA00116256 198 1 confusing because I think it goes H Tier is 2 one, two, three, four, these are all four, 205, 3 five, six, then this one should be 06, L Tier 4 should be 06. 5 MR. L Tier -- 6 MR. I have to see it. 7 MR. -- should be 206? 8 MR. I have to see it, sorry. 9 MR. Yeah, yeah, and I get it. 10 MR. See, because it's a little 11 confusing. 12 MR. : Trying to - absolutely. 13 MR. Because the way they have 14 it is the opposite. Like one is on the bottom, 15 two is on top and then three back to the 16 bottom, four to the top. 17 MR. Yeah, so we'll definitely 18 have to check on that. But do you know, was he 19 even ever in 206 after he returned from suicide 20 watch? 21 MR. If -. 22 MR. So he returned from 23 suicide watch, it sounds like, like you just 24 said, on the 29th of July. I guess I thought 25 it was the 30th based upon that email. So the EFTA00116257 199 1 29th of July through August 9th, 21 days does 2 not even elapse. 3 MR. He should be on 220. So he 4 should have got keyed into 220 because that's 5 where 6 MR. So someone -- 7 MR. -- what it says. 8 MR. -- keyed him in 9 incorrectly is what it sounds like? 10 Unless they put him there 11 and said, "Oh, shit, he needs a bunkie and then 12 moved him. But once they moved him, he was 13 never keyed into the right cell. 14 MR. All right. And do you 15 know who would have keyed in the 206? 16 MR. Maybe Control the day they 17 came upstairs? Maybe whoever was working SHU? 18 MR. All right, then -. 19 MR. So probably maybe even me, 20 but I don't think I would put him in the wrong 21 cell. 22 MR So from the time - and 23 you're the one that put him in the cell? 24 MR. Yeah, like, I wouldn't put 25 him - if you came to 205, that's where I would EFTA00116258 200 1 key you into, 205. 2 MR. So, are you - but are you 3 the one that placed him initially into 220? 4 MR. 5 MR. Do you know who did? 6 MR. I don't remember that. 7 MR. Do you know how it was 8 decided that he went into 220? My 9 understanding is he was placed in that cell 10 because you could see - you could all - you 11 could see his door up front. 12 MR. They put him there so we 13 can see him, but maybe Reyes was in that cell 14 already. 15 MR ' Who made the 16 determination to place him in that cell? 17 MR. I don't know. Not me. 18 Like I said, maybe because Reyes was already in 19 there. 20 MR. Z: Yeah, yeah. 21 MR. Could have been in there, 22 so, you know, it's easier to move him in with 23 Reyes. 24 MR. Oh, yeah. So, that's 25 what I was saying before. I thought the EFTA00116259 201 1 determination was made because from the 2 officer's station, like you said 3 MR. You could -. 4 MR. -- where I circled 5 MR. You could see him. 6 MR. -- you could see the 7 door. 8 MR. Yes. 9 MR. So that's why I thought 10 it was decided to put Epstein in that one. 11 MR. Right. Because it's right 12 off the -. 13 MR. So what I'm asking is, do 14 you know who made that decision? 15 MR. Probably between the 16 Captain, AW and the Warden. 17 MR. So at that point, he's in 18 220. Who is responsible for making sure that 19 he's coded at 220? 20 MR. Well, when he came - when 21 he comes up from suicide watch, it should have 22 been Control. 23 MR. So Control apparently put 24 him in, what you're saying, is 206? 25 MR. Correct. EFTA00116260 202 1 MR. So after he's now in - 2 he's not in 206, he's in 220, who is 3 responsible for making that change? 4 MR. Well, (Indiscernible 5 *02:31:27) notices it or when we conduct the 6 bed book count which most likely we didn't. It 7 regularly should have been me to key him, "Oh, 8 okay, he's there," but I never saw that he was 9 in the wrong cell. 10 MR. So that's what I guess, 11 so how would that - so I guess the question is, 12 how would it be noticed that he was in the 13 wrong cell? Is that something that's supposed 14 to be like reviewed or you're supposed to be 15 checking? How does that 16 MR. When you conduct a bed -. 17 MR. -- and I don't know, so 18 again -. 19 MR. Well, no, when you conduct 20 a bed book count, which now, it happens every 21 week, before, maybe once a month, or the next 22 time you notice would be, "Oh, 21 days to move 23 him," you would have came out that cell and he 24 was never in that cell. But you still see him, 25 you see who is there. EFTA00116261 203 1 MR. Yeah, yeah. 2 MR. But you just don't verify 3 with the bed book count. 4 MR. : Now, are you confident 5 that he was always in 220 though from the time 6 he returned from suicide watch? 7 MR. That I remember? Yes. 8 MR. All right. 9 MR. The only time I remember he 10 was in another cell, was when he was in 11 Tartaglione's cell, which that was right before 12 he went to suicide watch. 13 MR. Okay. From the time he 14 came back from suicide watch, he was always in 15 220. 16 MR. Yes. 17 MR. And this, 206, was that 18 just an administrative error? 19 MR. That most likely was. 20 MR. Okay. 21 MR. Because i know he was up 22 there. 23 MR. All right. 24 MR. So after Tartaglione, which 25 I wasn't even here when that happened, after he EFTA00116262 204 1 was his bunkie, he was placed on suicide watch 2 and I think I came back and he was already up 3 there in the cell. 4 MR. : All right. So the only 5 two cells that you know of is when he was with 6 Tartaglione and then when he returned from -. 7 MR. Yes. 8 MR. So from basically July, 9 at least 30th, the 29th, to August 10th, 220 is 10 the cell he was always in? 11 MR. Yes. 12 MR. This 206 thing was an 13 administrative error. 14 MR. Correct. 15 MR. And it would have been 16 caught if there were weekly bed book counts 17 done. 18 MR. Yes. 19 MR. All right, and that's 20 other than that bed book count, is there 21 another time that that would have been that 22 that could have been or should have been 23 caught? 24 MR. Maybe when if you were 25 moving him, if you were moving his bunkie, but EFTA00116263 205 1 there's no -. 2 MR. Okay, get a note to make 3 sure we ask for Reyes's cell assignment. And 4 he was always from 220 - I mean, from 7/29 to 5 8/10 - July 29th to August 10th, he was always 6 with Reyes? 7 MR. Okay. All right. Now 8 we're going to talk about - do you mind just 9 initialing. Now would the Lieutenant have any 10 oversight over this as well? 11 MR. f he was there, yes. 12 MR. Is that something he 13 suppo- he's, you know, I think it was we were 14 told that the Lieutenant comes in and audits 15 the books and things like that. Is this 16 somethin that he would have been auditing? 17 MR. I'm not sure if that's - 18 because I haven't worked like as a SHU 19 Lieutenant, but he does have to confirm the 20 rounds. Only way he would order that is 21 probably before the SHU meeting, which the SHU 22 meetings we usually had on Thursdays. 23 MR. Okay. Anything more you 24 want to ask on that? 25 MR. : I don't know if you want him EFTA00116264 206 1 to sign the SHU. 2 MR. We're still going to look 3 at that. So, this has been a great confusion 4 too that we're hoping you can help us. What 5 cameras are actually located in the SHU outside 6 of 10 South and G Tier? 7 MR. At this point in time. 8 MR. So, not at this point in 9 time, in August of 2019. 10 MR. So in August we only had 11 MR. I'm sorry, man. Sorry. 12 MR. -- one camera at the end of 13 the range. So you walk in through the rear 14 door. 15 MR. Can you - again, I guess 16 this is too confusing. 17 MR. So -. 18 MR. Are you able to determine 19 - if we're saying that this is the second 20 floor, here is L Tier. There is Epstein's cell 21 -- 22 MR. So there was always -- 23 MR. -- officer's station. 24 MR. -- a camera right here. 25 MR. That points down this EFTA00116265 207 1 range? 2 MR. Yeah. 3 MR. All right. So that 4 should have been at least where Epstein's cell 5 was located. 6 MR. : Well, it wouldn't - it 7 would see both. 8 MR. We have this camera 9 angle. Where is this camera? This is the 10 officer's station. 11 MR. That - this is outside of 12 10 South, which is the second floor and this is 13 the other office that I was in, the 14 Lieutenant's office on top. 15 MR. Okay. So the 16 Lieutenant's office is here. 17 MR. Yes. 18 MR. So, LT right there. 19 MR. Uh-huh. 20 MR. And then this floor 21 though is 10 South? 22 MR. Yes. This is the entrance 23 to 10 South. 24 MR. : 10 - I'm putting 10 South 25 on the door and pointing to the LT's door. Is EFTA00116266 208 1 this the officer's station? 2 MR. Yes. 3 MR. I'm circling the 4 officer's station. Where would Epstein have 5 been located? 6 MR.MI It's up - you can't see it 7 through there. 8 MR. This over here? 9 MR. Yeah. 10 MR. So I'm going to put E and 11 pointing to it. So that's where Epstein's cell 12 would have been. What is this over here? 13 MR. That's on J Tier. 14 MR. That would have been G 15 Tier? All right, so I'm going to put G 16 MR. J, J. 17 MR. J? Oh. 18 MR. Yeah, J as in Jack. 19 MR. J up that way. All 20 right. So that's our point of reference. What 21 other cameras other than this should have there 22 been in the SHU? 23 MR. Well, there's another one 24 out here that focused on the whole MPA, which 25 the MPA is this general right here area. EFTA00116267 209 1 MR. Okay. 2 MR. And then every range, when 3 you walk in, has a camera towards the end. 4 This is -- 5 MR. So every range -- 6 MR. -- in August. 7 MR. -- is supposed to have a 8 camera? 9 MR. Yes. They did. They still 10 have them there. 11 MR. So when you call it a 12 range, you're talking about -- 13 MR. All right, so -. 14 MR. each tier? 15 MR. Yes, each tier. So, I walk 16 into the tier, there's a camera at the end of 17 all of them. Now -. 18 MR. So, every one of them 19 should have had a camera. 20 MR. 21 they are still there. 22 MR. That should have been 23 working. 24 MR. orrect. 25 MR. (Indiscernible Yes. They did have camera, EFTA00116268 210 1 *02:37:22). 2 MR. They're still there, the 3 cameras. 4 MR. Are you able to tell, 5 what is this a picture of? 6 MR That's the Sally port, the 7 visiting elevator. 8 MR. On the 9th floor? 9 MR. Yep. 10 MR. So when you say, 11 "Visiting elevator," what does that mean? 12 MR. So you walk in through the 13 first floor and only - if there's visitors, you 14 can come out through there. So -. 15 MR. : You can visit the SHU? 16 MR. Yes. 17 MR. : Like outsiders? 18 MR. Yes. Visit the SHU 19 inmates. 20 MR. I didn't know that. So 21 instead of bring the SHU, the inmates down 22 (Indiscernible *02:37:47) the visitors actually 23 24 MR. ep. 25 MR. -- come into the SHU? EFTA00116269 211 1 MR. 2 in here, they sit down with their visitors. 3 MR So this is called the -. 4 MR Sally - 9 visiting Sally. 5 MR 9 -- 6 MR isiting Sally. 7 MR -- visiting - is Sally, 8 S-A-L-L-Y? 9 MR. Yes. 10 MR. All right, the second one 11 we just went over. That's from 10 South 12 outside of. What is this? 13 MR. That's 10 South. 14 MR. This is 10 South? And 15 this again is 10 South? 16 MR. Yes. 17 MR. : And again, 10 South. Is 18 there a reason why - did you want to identify - 19 20 MR. No, no, it's okay. 21 MR. I'm going to actually 22 take those -- 23 MR. Yeah. 24 MR. -- pictures out of this 25 and just look at those three. All right. So And they walk into the room EFTA00116270 212 1 the fact that we only have these three camera 2 angles and saying that these are the three that 3 are only working, do you know anything about 4 that? Do you know if all those other cameras 5 should have been working on each of the ranges? 6 MR. Well, they should have. 7 MR. All right. So, each 8 tier, to your knowledge on every single one, 9 including on L Tier where Epstein was located, 10 should have had a camera that pointed down. 11 MR. : They should have a working 12 camera. They still have the camera. It works. 13 At that time, I don't know if it did or didn't, 14 but the camera was on the wall. It's there on 15 the wall. 16 MR. On the wall of every 17 tier. 18 MR. Correct. 19 MR. Including Epstein's tier. 20 MR. Yes. 21 MR. Do you know anything 22 about those cameras not working on August 9th 23 or August 10th? 24 MR No. 25 MR Do you know anything EFTA00116271 213 1 about Epstein's tier, that camera not working 2 on -. 3 MR. No. 4 MR. Who is responsible for 5 making sure that the cameras were working? 6 MR. think the Com Department. 7 Com Tech 8 MR. And do you remember in 9 August 2019 who was working in the Com 10 Department? Anybody? Is there a Mr.IIIIIIII? 11 MR. I think that's the 12 only one. The only Com Tech that we've had and 13 that we still have. 14 MR. And he's still here? 15 MR. 16 MR. 17 would 18 this? 19 MR. Yes. All right, so be the person to talk to about Maybe tell you more or less 20 if what cameras worked or didn't work at that 21 time. 22 MR. : Okay. But no one ever 23 talked to you? Is there any way that as the 24 OIC or anybody that worked in the SHU that you 25 would have known that the cameras were or were EFTA00116272 214 1 not working? 2 MR. No. 3 MR. : So who - is there anybody 4 that live monitors any of those cameras? 5 MR. That I know of? No. 6 MR. : All right. So you don't 7 know anything else about the cameras? Is this 8 the first you're hearing that these cameras 9 were down? 10 MR. I mean, I've heard it in 11 the news, but not from the building. 12 MR. Is that - does that raise 13 any suspicion for you the fact that these 14 cameras aren't - they don't have video of these 15 cameras? 16 MR. Not really. This building, 17 there's always something going wrong in the 18 building. So, it wouldn't surprise me or 19 didn't surprise me when they said the cameras 20 weren't working. 21 MR All right. But, I mean, 22 that many? If we have how many tiers are in 23 you just do this top page. That many -. 24 MR. In six tiers. 25 MR. Six tiers and we don't EFTA00116273 215 1 have any cameras for any of the six tiers then. 2 Is that to you like, "Wait, what?" Does -. 3 MR. Not really. 4 MR. : No? 5 MR. No, not really. Like I 6 said, sometimes the lights go off in the tier 7 and we got to reset the breaker, so ever since 8 I started, there's always been a problem with 9 something not working in this building. So the 10 camera doesn't surprise me, it's just another 11 thing that didn't work for the moment. 12 MR.-: So this is where like, 13 it's just like, what are your - what is your 14 opinion on the fact that we got no cameras 15 working on at least, you know, definitely on 16 Epstein's tier, he's in the wrong cell, you 17 know, we could always - you know, the counts 18 are basically, you know, potentially falsified, 19 the counts weren't done. Is there anything 20 that you're seeing here that you're like, 21 "Somebody is covering up for somebody," or, 22 "Somebody is like manipulating things or 23 deleting cameras or taking anything down?" Is 24 there a reason for you to believe any of that? 25 MR.IIIIIIIII: Mm, not really. I said, EFTA00116274 216 1 going on seven years now, a lot of stuff has 2 gone wrong in this building and I highly doubt 3 that stuff was on purpose. My -. 4 MR. What about even to just 5 cover up -- 6 MR. My belief -. 7 MR. from what they were 8 doing administratively? Is there anybody that 9 would have been able to, like, knock cameras 10 out or knock them down or manipulate them? 11 MR. o, because -. 12 MR. Do Lieutenants have the 13 ability to do that? 14 MR. No, the Lieutenants don't 15 and leaves at like, I think, at 2:00 in 16 the afternoon. 17 MR. So like, for instance, if 18 an Ops Lieutenant, would that - would an Ops 19 Lieutenant be able to -- 20 MR. Go somewhere 21 MR. -- manipulate the 22 cameras 23 MR. -- and turn the syst-. 24 MR. -- or anything? 25 MR. No. EFTA00116275 217 1 MR. No? 2 MR. No. 3 MR. Even from like the camera 4 room or anything like that? 5 MR. No, we don't have access to 6 the camera room. 7 MR. Okay. 8 MR. We could log in to the 9 camera system, but we can't turn on or turn off 10 any camera. 11 MR. So who has the ability to 12 turn on and turn off cameras? 13 MR. That should be the Com 14 shop. 15 MR. All right, so just 16 Daniels 17 MR. Yes. 18 MR. -- is the only person 19 that can do it? Okay. Do you know who BOP 20 employee is? 21 MR. He's a case manager here. 22 MR. Okay. Still here? 23 MR. Yes. 24 MR. All right. Are you aware 25 on August 9, 2019, when worked and what EFTA00116276 218 1 his responsibilities were, like in - I don't 2 even know if he's on here, let me see. 3 MR. I didn't even think he was 4 here that day. 5 MR. He was. Yeah, okay. So, 6 if you can find him on there and tell me if you 7 can figure out what his role and 8 responsibilities were, looking at the daily 9 assignment roster. 10 MR. 11 MR. : Yes. 12 MR. He's Unit Team, he wouldn't 13 be on this roster. 14 MR. Well, if you look at the 15 bottom, you'll find his name at least. 16 MR. That's 17 MR. That's a different one? 18 MR. Correct. 19 MR. All right. So Unit Team, 20 does that mean he's non-custody? 21 MR. Yes. 22 MR. Okay. And what were his 23 roles and responsibilities, do you know? 24 MR. He's a Case Manager, pretty 25 much serving incident reports, referring them EFTA00116277 219 5 MR. 6 MR. -- is one of things that 7 -. 8 MR. gal paperwork. 9 MR. y. So -- 10 MR. copies. 11 MR. did you have any 12 conversations with on August 9, 2019 13 regarding Epstein? 14 MR. No. 15 MR. Did you ever - did you 16 remember ever talking with about 17 Epstein? 18 MR. Huh-uh. 19 MR. Do you know anything 20 about llowing Epstein to make a 21 telephone call on the evening of August 9, 22 2019? 23 MR. No. 24 MR. : Did you hear anything 25 about that after the fact? 1 to DHO, give out legal phone calls. 2 MR. Okay. 3 MR. Deal with some -- 4 MR. Legal phone calls -- kind of legal -- EFTA00116278 220 1 MR. No, and that's new. 2 MR. So do you know anything 3 about Epstein being authorized a telephone call 4 from the SHU? 5 MR. =los 6 MR. You ever hear anything 7 about Epstein making a telephone call from 8 inside the shower area? 9 MR. No. 10 MR. Do you know about inmates 11 in general ever making telephone calls from 12 that shower? 13 MR. They're not supposed to. 14 MR. They're not supposed to? 15 MR. No. 16 MR. Is there a jack there 17 though? 18 MR. There's no jack close to 19 the shower. Usually for a phone call, we plug 20 in the phone to the jack and give them the 21 phone through the slot. They make their phone 22 call, 15 minutes are up, you take the phone 23 back. 24 MR. So Epstein placed a 25 telephone call from the shower, they plugged in EFTA00116279 221 1 the thing, gave Epstein the telephone and then 2 closed the shower doors I guess and allowed him 3 to speak in there. Has that ever happened 4 before? 5 MR. The only place that I think 6 that would reach would be G Tier. Because 7 they're inside the tiers, the jacks weren't 8 working. 9 MR. ': And am I saying that 10 correctly? 11 MR. : Yeah, I think the shower was 12 in the G Tier. I think one -. 13 MR. It was a shower in the G 14 Tier 15 MR Yeah. 16 MR. -- not in the L Tier, so 17 he placed a telephone call from a shower, not 18 necessarily the L Tier shower. So he placed a 19 telephone call from the shower, a shower and it 20 was plugged into a non-recorded line. 21 MR. Well, those are the legal 22 phone calls because we can't listen to the - or 23 the attorney phone calls aren't supposed to be 24 on a recorded line, from my understanding. 25 MR. All right. So is that EFTA00116280 222 1 something that you would allow inmates to do? 2 MR. Personally, I put them 3 downstairs. 4 MR. When you say, 5 "Downstairs," where is that? 6 MR. In the recreation area, the 7 law library. 8 MR. So outside of the SHU? 9 MR. Correct. No, it's actually 10 inside the SHU 11 MR. : Okay. 12 MR. -- but it's like a cage 13 that where the computers were and plug in the 14 phone in the tier and make it reach all the way 15 downstairs. 16 MR. Is it abnormal -- 17 MR. Not the shower. 18 MR. -- that they allowed 19 Epstein to place a call from the shower, 20 whichever shower it was, it sounds like G Tier 21 and us a legal line? 22 MR. Not really, unless there's 23 no - couldn't put him on the library or you 24 couldn't put him in the rec cage then. 25 MR. What if you told the officer EFTA00116281 223 1 that he wanted to call his mother? 2 MR. You got social calls for 3 that and those calls, they would be recorded. 4 MR. And what would be a 5 reason why that it would be on a legal line to 6 call his, quote, unquote, mother? 7 MR. There shouldn't be. 8 MR. Z: There should be? 9 MR. There shouldn't be. Use 10 your minutes. 11 MR. So you hadn't heard 12 anything about this? 13 MR. No. 14 MR. This is the first you're 15 hearing of it? 16 MR. Yes. 17 MR. Okay. Would it be 18 abnormal that would have set this up 19 for him to be able to call his mother from the 20 shower then and plug it in the legal line? 21 MR. Unless he told him he was 22 calling his attorney, but even with that, 23 you've got to verify the attorney, "This is - 24 is this attorney such and such?" "Yes, okay, 25 I'm going to put your client on the phone." EFTA00116282 224 1 That's how it should have been. 2 MR. And even at that, is 3 someone supposed to monitor that telephone 4 call? 5 MR. : Well, he can't sit there 6 and listen to it, but once your time is up 7 then, "All right, give me the phone back." 8 MR. : Okay. So no one is 9 actually supposed to sit there and actually 10 monitor the call even though it's not recorded? 11 MR. Correct. 12 MR. : They are not? 13 MR. They are not because of 14 it's a legal call. 15 MR. Okay. And it's only a 16 legal call that's not supposed to be monitored? 17 MR. 18 MR. orrect. As far as a call to his 19 mother or anybody other than a legal call, it 20 should have been recorded? 21 MR. s. On a recorded line, 22 yes. 23 MR. And does everybody in the 24 SHU know that? 25 MR. Yes. EFTA00116283 225 1 MR. Should known 2 that? 3 MR. Definitely. 4 MR. Okay. And when inmates 5 place calls from the SHU, how is that - how do 6 you keep track of that, if at all? 7 MR. Well, we have - on SENTRY, 8 we have the TRUFONE, so we just print that or 9 in SHU we should - I don't know if they're 10 still doing it, they had a log book so you 11 request for the phone, I give it to you, I fill 12 it - I put your name down that you had a phone 13 call. 14 MR. So I guess that's what - 15 is it tr- Epstein didn't actually have one of 16 those like keypad things. 17 MR. C and PIN. 18 MR. Oh, he didn't have one? 19 MR. So if he didn't have one, 20 how would he place a call? 21 MR. He can't. 22 MR. : So the only way he could 23 place a call is from an actual -. 24 MR. Unit Team, yes. 25 MR. So if the - if in those EFTA00116284 226 1 cases, are the calls supposed to be monitored? 2 MR. Yes. 3 MR. So in this case, if 4 Epstein placed a call and was told, like - my 5 understanding is got the approval to 6 allow him to place a call but left him in the 7 shower area, left the unit, and no one 8 monitored the call. Is that a problem? 9 MR. es. So -- 10 MR. Who -. 11 MR. - if it's -. 12 MR. Who should have been 13 responsible for monitoring that call? 14 MR. He should have. 15 MR. 16 MR. Yes. He should just not 17 stand there and listen to his conversation, but 18 he should have verified -- 19 MR. Even if it's not a legal 20 call. 21 MR. Well, if he said -. 22 MR. So he doesn't have one of 23 these PAC and PINs, or whatever it's called and 24 they said he -. 25 MR. Then it's not going to be a EFTA00116285 227 1 social call, then it's going to be a legal 2 call. 3 MR. No, no, no. What I'm 4 saying is, he doesn't have the ability to make 5 a social call, but he's provided the approval, 6 "Yes, allow him to make this call, but monitor 7 it," stood there. 8 He should have stood by 9 there. 10 MR. : And is the one 11 who should have done that? 12 MR. IIIIIIII : Yes. Because he's the one 13 who put him on the phone. 14 MR. All right. And he 15 shouldn't have passed that responsibility off 16 to someone in the SHU? 17 MR. Correct. 18 MR. Okay. 19 MR. So if, for instance, the 20 Warden says, "Give Mr. Smith a phone call, a 21 five minute phone call but make sure you stand 22 there and monitor it," then, "Here's the phone, 23 it's going to be on a non-recorded line," but I 24 am going to stand there and listen to your 25 conversation because it's not a legal phone EFTA00116286 228 1 call -- 2 MR. Right. 3 MR. -- it's just kind of like a 4 courtesy phone call, you're given the 5 opportunity to call your family. "Okay, you're 6 phone call is done? Thank you." Hang up the 7 phone and walk away. 8 MR. And how are those calls 9 allowed, did you say? 10 MR. hould be a book. 11 MR. In a written book? 12 MR. log book. Yes. 13 MR. Okay. Not in anything in 14 like a TRUSCOPE or anything 15 MR. No. 16 MR. -- like that? SENTRY? 17 MR. You could put it on 18 TRUSCOPE, just to kind of - in case something 19 like this happens, cover yourself. 20 MR. Okay. 21 MR. Let's say an order like that 22 did come down. Are they allowed to call any 23 person they wanted or does it have to be a 24 specific number off a list? 25 MR. It has to be a legal phone EFTA00116287 229 1 call only. 2 MR. No, no, no. If -. 3 MR. Only to your attorneys. 4 MR. If he doesn't have the 5 ability to make a social call and they say 6 that, "Yes, allow him to have this social 7 call," would he even have a list if he never 8 MR. No. No, he could just call 9 whoever he wants to on the phone. 10 MR. Okay. 11 MR. But I guess though, I 12 want to make sure you're understanding that 13 question. When you're given the ability to 14 make phone calls, they vet people and you have 15 a list of people that you're allowed to call, 16 correct? 17 MR. ight. 18 MR. Like the monitored calls. 19 If you're never given that - what's it called? 20 PAC and -. 21 MR. IN and PAC. 22 MR. PIN and PAC, if you're 23 never given a PIN and PAC, do we even have a 24 list of people that you -. 25 MR. No. EFTA00116288 230 1 MR. So he wouldn't actually 2 have a list. 3 MR. Correct. 4 MR. If you want to follow up 5 on that -- 6 MR. No, no, no. 7 MR. -- that's fine. But do 8 you know if he had a list or not? 9 MR. There was a - I think that 10 someone has mentioned that there was a list, 11 but I'm not aware, I haven't seen a list, so I 12 just wondered if he would know. 13 MR. : But if he doesn't have 14 the PIN and PAC, no list would have ever -- 15 MR. Just nothing would -- 16 MR. -- been generated, right? 17 MR. -- exist. 18 MR. Right. 19 MR. Unless his list of 20 attorneys, that would be the only list he 21 should have. 22 MR. Okay. 23 MR. When inmates are brought into 24 the MCC, are they asked for a list of people 25 that they would like to call or keep as a EFTA00116289 231 1 contact, anything like that? 2 MR. So you're asked for an 3 emergency contact, and that's it. When you see 4 Unit Team, you give Unit Team a list of family 5 members or whoever you want to call, they put 6 it into the system. 7 MR. Okay. 8 MR. If it's attorneys, they 9 also have a list of attorneys that you can call 10 and you only make that phone call with Unit 11 Team there present. 12 MR. If he did give that name to 13 the Unit Team, where would they put it? 14 MR. That would be Unit Team. I 15 don't know where they have -. 16 MR. Or it's not like in 17 MR. No, it's not in SENTRY -- 18 MR. Okay. 19 MR. -- like that. 20 MR. And to you, though, is 21 that extremely abnormal? Have you ever heard 22 of something like that before? Somebody being 23 provided a phone call? 24 MR. t's happened before. 25 MR. Not having one of these EFTA00116290 232 1 PAC and PINs and then walking away and letting 2 them just speak? 3 MR. Well, it's happened where 4 they've given inmates a phone call or transfer 5 a phone call when they don't have a PIN and 6 PAC, but most of the time it's a five minutes 7 call whoever you're going to call, just like if 8 the Chaplain receives a death notification in 9 the family, he brings you up, he gives you that 10 five minute phone call, but he's sitting there 11 next to you listening to your phone call. Once 12 your phone call is done, "Okay, go back to your 13 cell." 14 MR. But as far as, if this in 15 fact happened where gave him a call, 16 leaves the tier, 15 minutes calls somebody in 17 the SHU and say, "Hey, let Epstein know his 18 telephone call is done and get the phone back." 19 Is that -- 20 MR. t's-. 21 MR. -- pretty problematic or 22 is it just -. 23 MR. It shouldn't happen, but 24 it's happened. 25 MR. Okay. EFTA00116291 233 1 MR. t's happened. 2 MR. Do you think it's because 3 it was Epstein, he was a guy - "I want to give 4 him his privacy because he's got this --" you 5 know, "--he's -- 6 MR. Mm. 7 MR. -- he's got this air 8 around him, he's a big deal," or why do you 9 think would have done that? 10 MR. Probably a million things 11 on his head to do. 12 MR. Okay. How severe do you 13 believe that that would be though or if at all? 14 MR. Should not have did that 15 because of what happened. 16 MR Right. 17 MR But if it didn't happen, 18 then it would be another regular inmate. 19 MR Okay. Anything more on 20 that? How - we're getting - we're almost 21 there, I promise. How was Epstein's 22 interactions with other inmates? 23 MR. Well, he only spoke to two, 24 which was Tartaglione and Reyes. 25 MR. Never really any other EFTA00116292 234 1 dealings? 2 MR. Everybody was always trying 3 to talk to him. 4 MR. But he wouldn't talk 5 back? 6 MR. Just regular conversation, 7 nothing crazy. 8 MR. Well, how, I guess, how 9 were his interactions, I guess, with his cell 10 mates then, Tartaglione and Reyes? 11 MR. Well, he always got along 12 with Tartaglione -- 13 MR. He did? 14 MR. -- that I understood. They 15 were both always talking. They never had issue 16 with each other. 17 MR. What about with Reyes? 18 MR. None either. 19 MR. Okay. So both seemed to 20 get along fine? 21 :1= es. 22 Okay. When was the last 23 time you interacted with or saw Epstein? 24 MR. That should have been, 25 what, August 9th. EFTA00116293 235 1 MR. So August 9th, the day 2 you left work - last - what was his state of 3 mind at that time? 4 MR. He seemed calm. 5 MR. Yeah? Anything -- 6 MR. He actually -- 7 MR. -- any 8 MR. -- joked around because he 9 asked for a new jumper and I told him, "No." 10 And he said, "Why not?" I was like, "It's a 11 jail, this is what you got to do. Nobody else 12 gets a jumper, it's not Versace," you know. 13 He's, "Ha, ha, ha, ha," he laughed and that's 14 it. I brought him downstairs to attorney 15 visit. 16 MR. Okay. Nothing abnormal 17 though or out of the ordinary? 18 MR No. 19 MR Okay. 20 MR He was very polite. 21 MR Was he complaining about 22 anything? 23 MR. No. 24 MR. Aside from the jumper? 25 MR. Not really. EFTA00116294 236 1 MR. Did he talk about any 2 other inmates or anything? 3 MR. o, he just like normal. 4 MR. Express that he was in 5 fear or anything like that? 6 MR. No. He was just, you know, 7 always worried about his attorney visit. 8 MR. Were any threats made to 9 Epstein that you're aware of? 10 MR. ■ 11 MR. 12 was in prison? 13 MR. No. Do you know why Epstein Because of - what is it, 14 the child molestation and a bunch of other 15 stuff according to the news. 16 MR. And did you have any 17 specific feelings with regard to why he was in 18 prison? 19 MR. of really, to me, just an 20 inmate. 21 MR. And would you have pretty 22 frequent conversations with Epstein? 23 MR. Mornings, I mean, "What's 24 up? You all right?" "Yeah, I'm good." 25 "Okay." EFTA00116295 237 1 MR. Anything of substance 2 other than just, "Hello?" 3 MR. No. 4 MR. No? And you said you 5 didn't work on August 10th, correct? 6 MR. Correct. 7 MR. When was your next shift? 8 MR. Monday, whatever date the 9 Monday was. 10 MR. And did you speak with 11 BOP employees at that time about Epstein's 12 death? 13 MR. Everybody was talking a 14 lot, like, "Oh, shit, you hear what happened?" 15 "Yeah." That's like regular - nothing into 16 details. 17 MR.-: What was your 18 understanding of how he died? 19 MR. According to what I hear 20 and they said it was a suicide. 21 MR. Suicide? And do you know 22 anything about anyone else taking Epstein's 23 life? 24 MR. No. 25 MR. Do you know anything EFTA00116296 238 1 about others assisting with taking Epstein's 2 life? 3 MR. Definitely, no. 4 MR. : Do you believe that 5 Epstein took his own life? 6 MR. Yes. 7 MR. : Did Epstein act alone in 8 taking his own life? 9 MR. Yes. 10 MR. : What would have prevented 11 Epstein's death? 12 MR. if he was still on suicide 13 watch. 14 MR. So you believe he should 15 have still been on suicide watch? 16 MR. If he was still on suicide 17 watch, he would have had 24/7 supervision. 18 MR. On that note, do you 19 think he was appropriately placed in SHU or 20 should have he been on like 10 South or G Tier? 21 MR. : Well, if he was on 10 22 South, he would have been alone. If he was on 23 G Tier, he still would have been alone. 24 MR. And you think it was very 25 important because of Psychology that he was EFTA00116297 239 1 with someone else? 2 MR. Correct. 3 MR. Okay. 4 MR. I feel, if he already tried 5 once, what's the chances he's going to not try 6 again. 7 MR. And do you believe he 8 should have still been on suicide watch? 9 MR 10 MR 11 MR Yes. You do? I think it was, what, two 12 weeks maybe or one week and then he came into 13 population -- 14 MR. Well, how -. 15 MR. - or he came to Special 16 Housing. 17 MR. How often are inmates 18 typically on suicide watch or psych 19 observation? 20 MR. Well, if you actually 21 committed or did the noose and all that stuff, 22 then at least two weeks. 23 MR. So at least two weeks -- 24 MR. At least two weeks. 25 MR. -- he should have been? EFTA00116298 240 1 MR. Yes. 2 MR. And what is your belief, 3 why did they release him early from suicide 4 watch or (Indiscernible *02:58:21)? 5 MR. Because he was Epstein. 6 MR. So you think it was 7 because he requested it? 8 MR. Yes. Well, this is my - 9 he's according to everybody, very important, 10 so. 11 MR. Right. And with all that 12 we talked about and like, you know, again, 13 speaking about the cameras, the, you know, 14 logs, the count shifts, you know, all this kind 15 of stuff, do you believe there's any suspicious 16 activity at play with regards to Epstein's 17 death? 18 I think, maybe when he came 19 to maybe a round or a count sheet, yes, could 20 have been stuff messed up, but any foul play 21 with staff, I don't think so. 22 MR. What about even with like 23 Psychology placing him into the SHU a little 24 early? I know you said it's because he was 25 Epstein, but do you think that it had anything EFTA00116299 241 1 to do with people hoping he killed himself? 2 MR. don't think so. 3 MR. No? 4 MR. don't think so. I think 5 this building is always under the radar with 6 everything so instead of attracting attention, 7 "Let's get him out of -" - because if not, his 8 lawyer is going to eat MCC alive, that's what a 9 lot I feel. This building is worried about 10 being on the paper. 11 MR. Okay. 12 MR. nd what happens? They 13 were on the paper. 14 MR. Right. Now -. 15 MR. If I'm not mistaken, 16 another institution the same day, two inmates 17 also committed suicide. 18 MR. (Indiscernible 19 *02:59:46). Now what about, did anyone ever 20 approach you, either inside or outside the 21 institution about Epstein while he was here? 22 23 MR=No. MR With regard to harming 24 him or assisting him? 25 EFTA00116300 242 1 MR. No? Okay. What are some 2 of the systematic problems inside the MCC and 3 specifically the SHU that allowed for Epstein 4 to die? 5 MR. The shortage of staff. 6 Staff constantly working doubles with little 7 sleep in between. I think that's - we don't 8 have enough equipment, like, you know, we don't 9 have enough tools to make this SHU specifically 10 succeed. 11 MR. What about if you're told 12 that people weren't doing counts and rounds, do 13 you think that played into it as well? 14 MR. Yes. 15 MR. Do you think if rounds 16 were actually conducted, he would at least be 17 alive on August 10th? 18 MR. It takes three minutes for 19 a person to - when that's something look the 20 line. If he wanted to commit suicide, he would 21 have whether the staff would conduct the rounds 22 or not. 23 MR. What about if he had a 24 cell mate with him? 25 MR. Depending who the cell mate EFTA00116301 243 1 is and how the cell mate sleeps, because Reyes 2 also had medical problems. I think it would 3 have been more of a chance for him to be alive 4 if he had a cell mate. Not that -- 5 MR. So on that note 6 MR. -- he definitely would not 7 have tried. 8 MR. Right. So on that note, 9 who out of all the people here, who do you 10 believe holds the most responsibility for 11 reassigning Epstein with a cell mate? 12 MR. I think everybody played a 13 little bit of part. 14 MR. And can - and this will 15 be the last question, tell me what people - 16 what part people played in like how that could 17 have been rectified as far as getting him a new 18 cell mate? 19 MR. 20 MR. Where it should have 21 begun, where it should it have end? 22 MR. So it started with his 23 bunkie leaving. So, yes, I told my relief he 24 needs a bunkie. Maybe R&D should have called, 25 say, "Hey, this is Epstein's -" - the whole EFTA00116302 244 1 building knew who Epstein's bunkie was. R&D 2 should -. 3 MR. So is it acceptable for 4 anybody to say, "I had no idea who Reyes was 5 and I didn't know that Reyes was Epstein's 6 bunkie?" 7 MR. o. 8 MR. Did everybody in the 9 building at the know? 10 MR. Everybody in the building. 11 MR. And how did they know 12 that? 13 MR. Just word. 14 MR. Word of mouth? 15 MR. Everybody talks and it's 16 not that many of us in this building, so. 17 MR. Okay. And I apologize 18 for interrupting, I just wanted to ask this. 19 MR. That's known. 20 MR. : Sorry. 21 MR. So, R&D, "Hey, we're losing 22 this guy, Reyes is leaving." The Lieutenant, 23 "Hey, Psychology, Reyes is leaving." Everybody 24 and since it was a Friday -. 25 MR. So who should have EFTA00116303 245 1 notified the Lieutenants? 2 MR. I think maybe I should have 3 said, "Hey, sir, Reyes is leaving." 4 MR. And do you - 5 MR. "We got to get him a 6 bunkie." Instead of, "Hey, sir, you know, 7 Reyes is leaving today, Epstein needs a 8 bunkie," and just me leaving. 9 MR. And do you believe that 10 you did tell a Lieutenant? 11 MR. Oh, I definitely, without a 12 doubt, strongly believe I told more than one 13 person that Reyes was leaving. 14 MR. I know you have the memo 15 saying that you specifically told as well 16 as and were present, but as far 17 as Lieutenants, do you have that belief that 18 you, without saying I can actually put myself 19 there, do you believe that you told a 20 Lieutenant? 21 MR. Yes. I think I spoke to 22 Lieutenant and 23 MR. 24 you told them? 25 MR. And what do you believe "Reyes is leaving, Epstein EFTA00116304 246 1 is going to need a bunkie." 2 MR. All right. So if they 3 say, "We knew Reyes left, but we didn't know 4 that he wasn't coming back," do you that that's 5 true? 6 MR. Yes. Because, like I 7 explained before, there's a lot of WABs that go 8 downstairs and within one hour, two hours, 9 sometimes right before the 10 o'clock count, 10 they end up coming back. Or they say they're 11 going to court, they'll spend two, three hours 12 in R&D and come back. So it's not always 13 because it says WAB on the paper, a hundred 14 percent guarantee that they're not going to 15 come back. Whether they take all their stuff 16 or not. 17 MR. So you think it's 18 extremely likely you told, not only Perez, but 19 also Durant? Should they have made the 20 notification to either the Captain or to the 21 relief? 22 MR. Maybe they did. I'm sure 23 they did because of 24 MR. Well, if I can tell you - 25 - EFTA00116305 247 1 MR. who Lieutenant -. 2 MR. -- nobody notified the 3 Captain. Should have they notified the 4 Captain? 5 MR. Yeah. 6 MR. If it's claimed that they 7 didn't tell their relief, should have they 8 notified their relief? 9 MR. Yes. 10 MR. All right. 11 MR. So something everybody, 12 especially being Epstein, you pass it down. 13 MR Okay. Now let's say this 14 is a unique situation. Let's say he's 15 working from 6:00 to 2:00. 16 MR. Correct. He leaves the 17 same time I leave. 18 MR. his relief, she's 19 on a regular time shift until 4:00 so she can't 20 start the Activities Lieutenant until 4:00. 21 MR. Correct. 22 MR. What would happen with 23 those two hours in between? He leaves at 2:00, 24 she starts at 4:00. Was he supposed to stay 25 until 4:00 -- EFTA00116306 248 1 MR. No. 2 MR. : -- until he's relieved or 3 can he leave at 2:00 and then just the 4 Activities Lieutenant goes unfilled for two 5 hours? 6 MR. He could leave at 2:00 7 because you have Operations Lieutenant until 4 8 o'clock. 9 MR. Okay. So because - well, 10 I thought both Activities and Lieutenant - 11 thought they both stopped at 2:00. 12 MR. No, one is 6:00 to 2:00, 13 another was 8:00 to 4:00. 14 MR. Okay. So at that time 15 when someone is doing the - 16 MR. Somebody has to be in that 17 position until the next Lieutenant comes in and 18 take over, and 19 MR. But at that time, 20 they're allowing the Ops Lieutenants to leave 21 two hours earlier than their shift due to 22 traffic. So the Ops Lieutenant actually is 23 leaving at 2:00 as well -- 24 MR. 25 MR. -- and then he's being EFTA00116307 249 1 replaced by who is, although the 2 assignment says 4:00, he actually comes in at 3 2:00. 4 MR. So, if -. 5 MR. Because is there, 6 can and both leave? 7 MR. Yes, because is 8 still in the building. 9 MR. : Although doesn't 10 take on Activities shift until 4:00? 11 MR. Until 4 o'clock, correct, 12 yes. 13 MR.-: So there can be just one 14 Ops Lieutenant from 2:00 to 4:00? 15 MR. Yes. 16 MR. Okay. 17 MR. Just like now, there's only 18 one Ops Lieutenant from 6:00 to 10:00 -- 19 MR. Okay. 20 MR. - by themselves. 21 MR. So, anc= if 22 they both knew, they didn't notify the Captain 23 or their relief, what should have happened 24 next? Should -- 25 MR. IIIIIIIII If they did not -. EFTA00116308 250 1 MRS -- at the 4 o'clock 2 count, is that when - so you're saying you kind 3 of could take a little bit of responsibility 4 but you also believe that you not only notified 5 your relief, but you also passed it up the 6 chain, correct? 7 MR. orrect. 8 MR. So now it gets passed up 9 the chain and nothing happens. When should - 10 what should have happened next with regard to 11 the cell mate? When should have the next time 12 this thing have been brought back up? The 4:00 13 -. 14 MR. Whenever - whoever was - 15 the first person that found out that Reyes was 16 not coming back, that person should have passed 17 it down to everybody again. 18 MR. And that would have been, 19 you believe somebody like or one of 20 those? 21 MR. It could have been 22 It could have been R&D that the first person 23 pretty much, like, "Oh, you know, Reyes is not 24 coming back." "Okay." Let's say R&D found out 25 first, then they should have called the Captain EFTA00116309 251 1 or even they should have just notified the 2 Lieutenant. If Reyes found out -. 3 MR. So R&D would actually to 4 straight to the Captain? 5 MR. Or most likely the 6 Lieutenant first, then, "Okay, I did my part, 7 that's pretty much - I did my part, I told the 8 Lieutenant," that's the rest is on - it's on 9 them because I did my part in notifying 10 somebody. 11 MR. : Now, if we're told that 12 R&D usually just goes direct to the SHU, does 13 that sound right to you or do they usually go 14 first to like the Ops or Activity and then 15 somebody else -. 16 MR. ike inform? 17 MR. Yeah, so if they know, 18 "Hey, Reyes isn't - we now know he didn't come 19 back, he was released." R&D is the first 20 person to get that word. What is their typical 21 procedure? Do they contact both the SHU and 22 the Lieutenant or do they contact one or the 23 other? 24 MR. Depending who is working. 25 Sometimes they'll tell both of them, sometimes EFTA00116310 252 1 they'll call SHU, sometimes they'll just call 2 the Lieutenant, the Lieutenant calls SHU and 3 says, "Hey, this guy is not coming back." Or 4 if they call SHU, then SHU would fix it on the 5 computer or SHU would call Control, say, "Can 6 you take Reyes off the count?" 7 MR. And would the person that 8 got contacted in R&D, you said everybody knew, 9 would the person in R&D know that Reyes was 10 Epstein's cell mate? 11 MR. would assume they did. 12 MR. And are they on this 13 form? 14 MR. Are they, no. 15 MR. How would we find out who 16 was working at approximately 4:00 - what does 17 their shift go from? You said 2:00 to 10:00? 18 MR. Yes. Think -. 19 MR. How would we find out 20 MR. There was one that -. 21 MR. -- who was - do we know 22 who was working -- 23 MR. It's -. 24 MR. : -- 2:00 to 10:00? 25 MR. They're 6:00 to 2:00 -- EFTA00116311 253 1 MR. Not for R&D. 2 MR. -- 2:00 to 10:00 and 12:00 3 to 8:00, R&D. 6:00 to 2:00, 12:00 to 8:00 and 4 2:00 to 10:00, that's R&D's schedule. 5 MR. So the 2:00 to 10:00 6 would be the people that would have found out, 7 I'm assuming. 8 MR. es. 9 MR. How do we find out at 10 this point who was working in R&D from 2:00 to 11 10:00? 12 MR. You would have to get with 13 an R&D supervisor. 14 MR. Who is an R&D supervisor 15 that we can get with right now? 16 MR. Is that Ms. 17 MR. Ms. doesn't know. We 18 reached out already. 19 MR. Oh. 20 MR. She said she doesn't know 21 but wouldn't they keep track of like who worked 22 23 MR. (Indiscernible *03:10:02) did 24 and she didn't seem to know. Is there like a 25 schedule? Do they keep it somewhere? EFTA00116312 254 1 MR. That - because, this is our 2 schedule and that goes back for years, so. 3 MR. That's why I would think 4 that also R&D would have something similar. 5 6 7 8 9 MR. MR. ut with them -- So let's go with -- MR. - they're not MR. -- Beth Arie (Phonetic Sp. *03:10:17), let's ask her MR. Okay. MR. -- about that. MR. hey're not on our 13 they're not on a roster. The only time they 14 would be on a roster if it's - if they're doing 15 overtime with us. 16 MR. Uh-huh. 17 MR. So we could say they do 18 night off, then we would put them on our roster 19 for night off. 20 MR. Okay. So it sounds like 21 you have very limited liability because you do 22 believe, in fact, you not only - and you're 23 confident you passed it to 24 MR. 25 MR. m very. Under oath, like, "Yes, I EFTA00116313 255 1 did," or is it like, "I believe I did?" 2 MR. No, like, very, very, very 3 confident. 4 MR. Like you can actually 5 recall passing that information? 6 MR. Yes. The same thing with 7 Shak being there too. 8 MR. So you specifically 9 recall, like almost like you can see, you can 10 remember 11 MR. See -- 12 MR. -- I said this. 13 MR. -- I'm in SHU, is 14 walking in, we're there, "Make sure this guy 15 gets a bunkie." "All right, G." 16 MR. You said, "Make sure 17 Epstein," or, "This guy?" What did you say? 18 MR. Well, Epstein 19 MR. Okay. And is the 20 one that said, "All right, G?" 21 MR Uh-huh. 22 MR All right. And you 23 believe, although you can't recall with such 24 clarity that you passed it to the Lieutenants. 25 MR. Correct. EFTA00116314 256 1 MR. Okay. 2 MR. If-or or any one 3 of them turns around and says that, "Hey 4 listen, you never told them," would they be 5 lying? 6 MR. : Most like, I don't think 7 they would tell you that, but -. 8 MR. No, no, but I'm asking, I 9 said, you know, I have to cover both sides. 10 MR. : Yeah. 11 MR. Would they be lying if they - 12 . 13 MR._: They - I strongly believe 14 they wouldn't tell you that -- 15 MR. : Because, again, it's a little 16 bit of people, we're always - it was only us 17 throughout the whole time. So I strongly, 18 strongly believe that I spoke to - 19 even forgot 20 I . yes. 21 MR. was there, but, and On the same note, if we ask 22 the same thing towards Lieutenant Perez or 23IIIIIIII -- 24 MR. 'I'll'' I didn't speak tr 25 I don't even remember seeing him that day. EFTA00116315 257 1 MR. But 2 MR. But Lieutenant and 3 yes. 4 MR. They would say that you spoke 5 to them about it? 6 MR. Yeah. 7 MR. Okay. 8 MR. Although, if they claim, 9 "Yeah, we know he went but we didn't know that 10 he was not coming back," that also holds 11 weight? 12 MR. I was actually - because, 13 again, not everybody has WAB. 14 MR. 15 MR. 16 MR. Sure. oesn't So could have you - could 17 have a new cell mate been assigned to Epstein 18 prior to 4:00 p.m.? 19 MR. 20 that Reyes is not coming back. 21 MR. Only if it was confirmed But a new cell mate can 22 not be - so, a new cell mate cannot be assigned 23 to Epstein until it's confirmed that Reyes 24 isn't coming back? 25 MR. I mean, you could assign EFTA00116316 258 1 them even with Reyes being there. 2 MR. I know, but I'm just 3 saying, like in this case, that's his cell 4 mate. 5 MR That's his cell. He's -. 6 MR So you -. 7 MR He's keyed into that cell. 8 MR Right. 9 MR So until we know for a 10 fact, "You know what? Reyes is not coming 11 back, we're going to key him out," then, "Shit, 12 let's get him -" - now we have from let's say 13 we found out Reyes left the building at 1 14 o'clock in the afternoon, we have until 8 15 o'clock to get him a bunkie because he's in 16 attorney visit. 17 MR. And was it confirmed that 18 Reyes wasn't coming back while you were on 19 duty? 20 MR. No. 21 MR. So no one ever told you 22 he was not -- 23 MR. No. 24 MR. -- coming back. 25 MR. All I saw was that WAB and EFTA00116317 259 1 I assumed he's not. 2 MR. You assumed, but, yeah, 3 but you didn't - but you be- -- 4 MR. But I didn't know for sure. 5 MR. -- but you didn't believe 6 you should -. 7 MR. Get him a bunkie because, 8 "Hey, there's still a chance this guy could 9 come back." 10 MR. Okay. 11 MR. If I would have known for a 12 fact, we wouldn't even be here I think. 13 MR. And is that the reason 14 why you told.. Did you also say, "Hey, if 15 Reyes doesn't come back, get him a bunkie," or 16 did you just say, "Hey, Reyes isn't coming 17 back, get him a bunkie?" 18 MR. No, I know I didn't tell 19 him he is not coming back because I didn't 20 know. 21 MR. Right. 22 MR. So -. 23 MR. So what do you think you 24 actually said? 25 MR. "Hey, you know, if Reyes EFTA00116318 260 1 doesn't come back, he needs a bunkie." 2 MR. Okay. 3 MR. Which he already knows 4 Epstein needs a bunkie. 5 MR. And you said that? You 6 believe you said the same thing to both 7 and 8 MR. eah. 9 MR. And that would have been 10 probably, leaving doing his rounds at 11 about 11:30? Would have that been when you 12 told him or do you believe you would have 13 called? 14 MR. No, probably when he's 15 doing his rounds. 16 MR. Doing his rounds? And 17 you said you actually do remember speaking with 18 that day? 19 MR. I remember him being 20 there and just told him, I always talk to him. 21 MR. Would it be like talking 22 to him in the SHU? 23 MR. Yeah. 24 MR. So both_nd 25 would have visit -. EFTA00116319 261 1 MR. One at a time. 2 MR. But they both would do 3 it? 4 MR. They both would have walked 5 over, yes. 6 MR. And are they both 7 actually required to do it or just one? 8 MR. No, they're both required 9 to do the rounds. 10 MR. Oh, they are? 11 MR. eah. 12 MR. All right. I thought it 13 was one or the other. So looking at that 14 sheet, was also Perez on it? Would he had to 15 have logged in like something when he did a 16 round in the SHU? Can you get me that 17 Lieutenant's log? So both the Activities and 18 the Ops Lieutenant are both required to do a 19 round in the SHU. 20 MR. Correct. At least once per 21 shift. 22 MR. And that was also the 23 case in August of 2019? 24 MR. Yes. But like on the round 25 sheets, if one signed it, the other is not EFTA00116320 262 1 going to sign over it. 2 MR. (Indiscernible *03:15:35). 3 MR. There it is. 4 MR. It's right here, sorry. 5 MR. So is on this at 6 all? Can ask, but I don't remember him there. 7 MR. No, he's actually not. 8 MR. So -- 9 MR. Unless -. 10 MR. -- should have there been 11 a -. 12 MR. Unless because did 13 it. He didn't do it. Just like on -. 14 MR. Because we were told if 15 the Ops Lieutenant is too busy, he just tells 16 Activities Lieutenant to go do it. But you 17 believe -- 18 MR. I mean - I mean -- 19 MR. -- they actually both 20 MR. -- physically and you 21 actually both Activities and Operations have to 22 walk and do the rounds. 23 MR 24 together though. 25 MR. And you actually - not Not together. EFTA00116321 263 1 MR. Separately. 2 MR. That's - and one or the 3 other fills it in on TRUSCOPE. 4 MR. Okay. So is it 5 surprising you to see that doesn't even 6 have anything logged on this day? 7 MR. No, not really. 8 MR. No? And does this 9 suggest - when they sign this, does it show 10 where it was signed from? 11 MR. No. 12 MR. No? Just they can change 13 like this -. 14 MR. Well, wherever you logged 15 it from, that, I don't even know how it shows 16 up somewhere else. 17 MR. Okay. Because aren't 18 they supposed to actually log it from the 19 actual unit themselves? 20 MR. Well, now, if as long as 21 you do it one, you could log in from 22 downstairs, let's say the Lieutenant's office 23 and logged in a unit. 24 MR. But are you supposed - 25 like if someone visits the SHU, aren't they EFTA00116322 264 1 supposed to actually log the round from the 2 SHU? 3 MR. Yes, log it in the computer 4 and log it in. 5 MR. Yeah, yeah, yeah, that's 6 what I was - okay. Did I get - so we said the 7 cell mate - so you said, told at least 8 and you remember that specifically. You 9 believe that the other two, and them, 10 they should have - once it was actually 11 verified that he wasn't coming back, that's 12 when it really should have been done though. 13 MR. orrect. 14 MR. But we just don't know 15 exactly when it was verified or how it was 16 verified. 17 MR. orrect. 18 MR. And you believe R&D - how 19 does R&D receive that verification? 20 MR. I think through the 21 Marshals. 22 MR. So the Marshals tell them 23 and then they're supposed to make the proper 24 notifications? Are they supposed to go, you 25 said it depends on who is in R&D but they're EFTA00116323 265 1 supposed to notify the appropriate housing 2 unit? 3 MR._: No, they can just call the 4 housing unit, "Hey, this guy is not coming 5 back," or call Control. 6 MR. And let Control know. 7 MR. orrect. 8 MR. All right. And do we 9 know who at - let me see that August 9th one - 10 who in Control - would Control always be in the 11 loop with that? 12 MR. Not really because there's 13 times that R&D would call SHU and if there's 14 somebody in SHU that has enough knowledge to 15 just key him back in, they'll key them back in, 16 or R&D would key them back in. So now, you 17 don't need to speak to R&D, I mean, you don't 18 need to speak to Control because the inmate is 19 walking back up to SHU and R&D already keyed 20 him back into the building. 21 MR. All right. And then, 22 what is the - what about like when Noel and 23 Thomas are working on their morning shift, 24 should they have recognized that Reyes wasn't 25 there? EFTA00116324 266 1 MR. Definitely by that time 2 they - by 10 o'clock, it's way after, they 3 should have known that he's not coming back. 4 MR. But I just mean the start 5 of a new shift now. Now midnight starts a new 6 shift, we're now on morning watch. Should they 7 have recognized, "Hey, Epstein is by himself." 8 MR. Yes. 9 MR. And when and how? 10 MR. Yes. 11 MR. No, when should have they 12 noticed and how? 13 MR. Right on their first round 14 on morning watch. 15 MR. So, during a round they 16 should have 17 MR. You have to do a count at 18 midnight, so, at that time you should have saw 19 he was by himself. That's a little light 20 should have went off in your head saying -. 21 MR. : So immediately, right 22 away, midnight, Epstein is by himself. If the 23 count was done, they would have known, "We've 24 got to make this notification?" 25 MR. Yes. EFTA00116325 267 1 MR. And would have they known 2 that that notification needed to be made? 3 MR es. 4 MR And do you believe that 5 both Thomas and Noel knew that Epstein was 6 required to have a cell mate? 7 MR. They should have known, 8 yes. 9 MR. : And how should have they 10 known? 11 MR. Due to the little paper I 12 had there and -. 13 MR. Well, the paper said, "Do 14 rounds," right? 15 MR. And supposedly somebody 16 else had another paper there saying that he 17 needed a bunkie, but -. 18 MR. Now, so this - so you 19 know of a different paper that was 20 MR. No, from what you told me 21 earlier. 22 MR. No, that was somebody 23 saying that you created another paper saying 24 that he -. 25 MR. Oh, that 1 don't remember. EFTA00116326 268 1 MR. So you don't remember 2 ever creating a paper saying he needed a 3 bunkie. 4 MR. Maybe I did, but I don't 5 remember doing it. 6 MR. Okay. 7 MR. I remember this just 8 because it has the God phrase and it was kind 9 of funny to us. 10 MR. Yeah, yeah, yeah. 11 MR. But we all know that if an 12 inmate comes from suicide watch, he has to have 13 a bunkie. 14 MR. : And everybody knows that. 15 MR. Everybody knows that. 16 MR. : All right. Any other 17 questions? 18 MR. Just a couple follow ups. Do 19 you know why Tartaglione was in the SHU? 20 MR. If - I think he got into 21 a fight or somebody hit him while he was in 11 22 South. 23 MR. So he -. 24 MR. On that time. 25 MR. So he was put in there for EFTA00116327 269 1 his own protection or did he -- 2 MR. Yes. 3 MR. -- assault somebody end up in 4 that? 5 MR. So, I think he had a fight 6 or somebody assaulted him and they both ended 7 up in SHU. 8 MR. What about Reyes? 9 MR. Reyes, I think it was 10 because of smoking, I think. No. 11 MR. Contraband? 12 MR. Yeah, contraband. Nothing 13 that I can remember. 14 MR. iou got something else? 15 MR. The only other question I 16 would say is, outside of the SHU, now we got 17 and we got nd then we also have 18 later on. If they were actually 19 conducting rounds as they should have, would 20 have they at that time known Epstein was by 21 himself and needed a cell mate? Should have 22 they known if they're conducting rounds after 23 4:00 p.m.? 24 MR. Yes. 25 MR. So all of them have some EFTA00116328 270 1 liability then too to know, "Hey, this guy - 2 where is Epstein's cell mate?" 3 MR. Well, maybe at 4 o'clock, 4 depending what time they did the rounds, no, 5 because Epstein was always downstairs in his 6 attorney visit until 8 o'clock at night. 7 MR. But if no one is actually 8 in Epstein's cell, wouldn't they notice that? 9 MR. They would notice that it 10 was empty, but, "Hey, where's Epstein?" "Oh, 11 he's in -" - because you - people don't ask for 12 Reyes usually. 13 MR. Right. 14 MR. "Where's Epstein?" "He's 15 in his legal visit." "Oh, okay." And the 16 Lieutenant, the Lieutenant's office is like ten 17 steps away from the attorney conference so you 18 would know that Epstein is still there and you 19 got to (Indiscernible *03:22:21) count. 20 MR. All right. And when you 21 were there, do you recall that the Activities 22 and the Ops Lieutenant were actually conducting 23 rounds in the SHU? 24 MR' I knower for a fact 25 and then Lieutenant he always just EFTA00116329 271 1 walked around to see what was going on. 2 MR. Who would? 3 MR. ieutenant 4 MR. So he wouldn't actually 5 do the -. 6 MR. : No, he would walk around 7 just to see what was going on because he 8 MR. : What 9 MR. -- was the SHU Lieutenant 10 before too. 11 MR. What about 12 MR. , he's always 13 walking, but I didn't see him that day. 14 MR. What about 15 16 MR. I know for a fact she 17 always does her rounds. 18 MR. So if she says that she 19 wasn't required to walk the tier, she just 20 needed to check in, do you think that - what 21 would you say to that? 22 MR.M. Maybe she knows something I 23 don't know. Because, I mean, I'm a new 24 Lieutenant, I still - I walk around every 25 range, every tier. EFTA00116330 272 1 MR. But when you were the SHU 2 OIC, you recall all these Lieutenants coming in 3 and actually walking the tiers? 4 MR. Yes, because that round 5 sheet, on the bottom of it, it says, 6 "Operations Lieutenant." 7 MR. And, yeah. 8 MR. If you look at it. 9 MR. Yes. And that actually 10 is for conducting rounds of the tiers, not just 11 doing rounds with your -. 12 MR. : In the Special Housing 13 Unit, correct. 14 MR. Yeah, yeah, yeah. I 15 guess what I'm saying is, some people are 16 saying, "No, it's I'm doing a round with my 17 staff. I'm not doing a round on inmates, it's 18 the staff's members to do the round on inmates, 19 I'm doing a round with my staff." 20 MR. But, again, that bottom 21 MR. That bottom. 22 MR. -- little square says, 23 "Operations Lieutenant," which even if you 24 don't know anything about it, if you read it, 25 it says, "Operations Lieutenant." EFTA00116331 273 1 MR. Doing a round of the 2 actual inmates. 3 MR. Or does it also mean that 4 they're certifying that those other rounds by 5 the COs were conducted? 6 MR. It could be that, but 7 regardless, you got to sign it and go down the 8 range. 9 MR. Yeah, that's where I 10 wasn't sure if this was signed to make sure 11 that you guys were doing their job. 12 MR. I understand as to make 13 sure you did your round. 14 MR. Okay. Now, let's do 15 that. 16 MR. That the Lieutenant. 17 MR. : Lieutenant. 18 MR. Lieutenant. 19 MR. : Yes. 20 MR. Okay. 21 MR. Okay. I'm sure we could 22 sit here and just pick your brain all day long, 23 but we've been here a long time, so, are we 24 missing an thin ? 25 MR. No. That's it. I hope, EFTA00116332 274 1 you know, everybody takes this as a learning 2 experience, you're fucking up, stop fucking up. 3 Excuse my language. 4 MR. Now, do you think one 5 person fucked up more than another in this? 6 No, I mean, I think it was 7 going to happen if you wanted it to happen, 8 regardless whether rounds were done, whether he 9 had a cell mate, maybe less likely that he 10 would have with a cell mate, but also, a cell 11 mate could go to the law library, you know. 12 Thirty minutes is a long time, 40 minutes is a 13 long time, so. 14 MR. Yeah, so, but you do 15 believe it's the cell mate thing that would 16 have actually helped keep him alive. 17 MR. I think it would have 18 helped a little bit. 19 MR. : Right. 20 MR. If he wanted to do it, he 21 was going to do it. 22 MR. Uh-huh. And you think 23 everybody from the point that you left on plays 24 a large responsibility in the fact that he 25 wasn't assigned a new cell, especially since EFTA00116333 275 1 you specifically told people, "Make sure he 2 gets a bunkie if Reyes doesn't come back." 3 MR. I mean, I don't blame 4 anybody. I think everybody should maybe pass 5 the information a little more. Maybe it got 6 lost in miscommunication. 7 MR. All right. 8 MR. No, that's it. 9 MR. But you don't believe 10 that the people that you told will actually 11 admit that they were told it? 12 MR. Correct. 13 MR. Right. And you are 14 swearing, again, under oath, under penalty of 15 perjury of law that you did tell them that? 16 MR. I'm very, very confident 17 that I told more than one person. 18 MR. And who are you confident 19 that you told? 20 MR..= I told was 21 there. Lieutenant saw Reyes leaving, 22 but even Reyes we weren't sure -. 23 MR. SollIIIIIIFctually saw 24 Reyes leaving? 25 MR. : He was downstairs, I think, EFTA00116334 276 1 -- 2 MR. : Okay. 3 MR. -- and saw. But, again, I 4 don't blame anybody and it's just unfortunate 5 everybody got to go through this. 6 MR. Yeah. Okay. You good? 7 MR. I'm good. 8 MR. Anything else you want to 9 add for us? 10 MR. That's it. 11 MR. Thank you, sir. 12 MR. Thank you for -- 13 MR. : I can't thank you enough. 14 MR. -- taking three hours of my 15 day. What time is it now? 16 MR. You got a nice cozy seat, 17 you know, we gave you the most comfortable one 18 we had. 19 MR. Turn up the heat. 20 MR. 4:39. 21 MR. All right. It's 4:40 22 p.m. on Wednesday, July 14, 2021. This is 23 Senior Special Agent and I'm 24 turning off the recorder. 25 EFTA00116335 277 CERTIFICATE I hereby certify that the foregoing pages represent an accurate transcript of the electronic sound recording of the proceedings before the Department of Justice, Office of the Inspector General in the matter of: Interview of Wendy Brewer, Transcriber EFTA00116336 A Ability - 134:23, 216:13, 217:11, 227:4, 229:5, 229:13 Abnormal - 175:21, 182:16, 222:16, 223:18, 231:21, 235:16 Above - 5:12, 153:16, 190:21 Absolutely - 198:12 Acceptable - 81:10, 244:3 Accessed - 151:25 According - 12:23, 44:23, 51:8, 99:4, 138:9, 148:1, 236:15, 237:19, 240:9 Accordingly - 5:4 Accurate - 13:17, 14:10, 52:17, 90:7, 91:17, 123:14, 136:6, 151:14, 154:10, 155:19, 158:2, 162:7, 162:10, 162:12, 162:17 Acknowledge - 128 :17 Act - 5:1, 238:7 Acting - 98:9, 98:17, 98:21, 98:22 Action - 5:6, 62:10, 73:15, 84:23 Actions - 62:21 Active - 9:15 Activities - 68:2, 68:10, 247:20, 248:4, 248:10, 249:10, 261:17, 262:16, 262:21, 270:21 Activity -44:18, 240:16, 251:14 Actual - 80:2, 97:11, 98:24, 101:9, 157:10, 163:16, 225:23, 263:19, 273:2 Add - 91:8, 121:23, 162:6, 192:16, 192:23, 276:9 Adding - 122:9, 125:9 Address - 7:17 Administrative -18 5:15, 185:17, 185:20, 203:18, 204:13 Administratively - 216:8 Admit - 275:11 Advertisement - 8: 20 Afternoon - 59:11, 76:15, 84:9, 91:2, 158:21,216:16, 258:14 Afterwards - 17:25 Against - 5:6, 5:16, 148:13, 184:4 Age - 15:22, 41:9 Agency - 5:9 Agent - 3:3, 3:18, 3:23, 3:25, 6:5, 6:13, 6:16, 116:22, 276:23 Ago - 69:6, 166:22 Agree - 4:13, 109:15 Agreeing - 131:1 Ahead - 30:13, 115:20 Air - 233:7 Alert -188:1 Alive - 241:8, 242:17, 243:3, 274:16 Allow - 222:1, 226:6, 227:6, 229:6 Allowed - 170:20, 185:2, 221:2, 222:18, 228:9, 228:22, 229:15, 242:3 Allowing - 219:20, 248:20 Almost - 142:5, 179:13, 179:14, 233:20, 255:9 Alone - 16:4, 42:14, 73:20, 238:7, 238:22, 238:23 Along - 17:6, 17:8, 17:10, 35:10, 185:4, 185:9, 234:11, 234:20 Although - 50:17, 170:4, 191:14, 249:1, 249:9, 255:23, 257:8 Am - 3:22, 5:12, 133:24, 221:9, 227:24 Amended - 5:2 Amount - 175:21, 177:3, 184:22, 186:2 Anal - 66:21 161:20, 269:18, 271:14 Angle - 207:9 Angles - 212:2 An notate -19:22 Annual - 34:19, 35:4, 35:6, 35:10, 36:2, 78:13, 78:23, 79:1, 79:7, 79:17 Answer - 5:5, 5:7, 5:13, 5:22, 95:9, 130:25, 131:4, 143:21, 154:8 Answered - 60:19, 67:17 Answers - 4:12, 106:10, 106:11, 163:8 Anymore - 100:8, 160:18 Anyone - 20:21, 23:2, 38:7, 64:15, 66:5, 95:12, 99:17, 102:2, 103:13, 142:17, 153:9, 169:1, 237:22, 241:19 Anywhere - 26:9, 27:10 Apnea - 172:5 Apologize - 172:11, 244:17 Apparently - 201:23 Appear - 121:23, 191:15 Appears - 83:17 Approach - 241:20 Appropriate - 22:7, 265:1 Appropriately - 238 :19 Approval - 226:5, 227:5 Approximately - 39 :8, 56:13, 65:9, 252:16 April - 11:6 Arafat - 117:23, 117:24 Area - 17:21, 28:10, 32:11, 208:25, 220:8, 222:6, 226:7 Aren't - 112:23, 214:14, 221:23, 263:17, 263:25 Arie - 254:8 Army - 9:11, 9:13 Arrival - 39:15 Arrives - 186:19, 186:22 ART - 78:7 Arts - 8:9, 8:14 Aside - 66:5, 82:5, 92:3, 153:10, 235:24 Ask - 7:6, 7:15, 13:12, 18:7, 40:2, 64:21, 96:13, 180:7, 205:3, 205:24, 244:18, 254:9, 256:21, 262:6, 270:11 Asked - 4:12, 4:22, 5:19, 85:2, 85:5, 116:22, 180:16, 181:2, 230:24, 231:2, 235:9 Asking - 85:1, 128:2, 145:13, 171:17, 175:23, 201:13, 256:8 Ass - 141:14 Assault - 269:3 Assaulted - 269:6 Assign - 257:25 Assigned - 14:22, 15:19, 20:22, 38:4, 62:11, 64:9, 81:14, 133:19, 187:2, 195:24, 196:7, 257:17, 257:22, 274:25 Assigning - 64:13 Assignment -13:23 , 13:25, 59:23, 182:6, 205:3, 218:9, 249:2 Assignments -196: 8 Assist - 187:9 Assisting - 238:1, 241:24 Assume - 54:16, 55:11, 58:11, 60:15, 60:21, 92:8, 125:6, 190:25, 194:6, 252:11 Assumed - 56:14, 61:2, 65:17, 127:25, 131:12, 259:1, 259:2 Assumes - 125:22 Assuming - 15:7, 27:6, 79:5, 118:1, 122:2, 122:11, 125:15, 130:17, 253:7 Assumption - 119:2 1 Assurances - 4:20, 5:12 Attempt - 17:12 Attempted - 16:10, 16:21, 18:16 Attend -25:5 Attention -241:6 Attesting - 14:3, 14:8 Attorneys - 229:3, 230:20, 231:8, 231:9 Attracting - 241:6 Audit - 154:17 Auditing - 205:16 Audits - 205:14 Authorized - 173:2, 220:3 Automatically - 21: 9 Avenue - 8:18 AW - 153:13, 201:16 Awards - 96:6 Aware - 15:23, 16:9, 34:16, 41:14, 41:25, 56:4, 189:4, 217:24, 230:11,236:9 Away - 37:5, 49:24, 133:17, 228:7, 232:1, 266:22, 270:17 Awesome - 27:5 B BA - 117:9, 117:15 Bad - 182:19 Bag - 49:13, 49:14, 53:5, 53:7, 53:8 Bail - 48:10 Banquet - 10:18 Barricade - 185:6 Based - 25:19, 48:1, 60:20, 61:21, 63:11, 71:23, 95:19, 110:15, 135:22, 148:11, 154:12, 198:25 Basically - 62:7, 130:24, 131:8, 204:8, 215:18 Basis - 4:22 Bathroom - 111:1 Bear - 106:4 Became - 88:15 Become - 41:25 Bed - 74:5, 183:2, 202:6, 202:16, 202:20, 203:3, 204:16, 204:20 Began - 65:15 Beginning - 128:7 Begun - 65:13, 243:21 Behind - 31:20, 44:19, 113:4, 128:23 Belief - 183:4, EFTA00116337 216:6, 240:2, 245:17 Belongings - 39:17, 43:2, 43:16, 43:21, 43:22, 49:7, 53:3, 74:22 Below - 6:3, 153:18, 153:20 Benefit - 127:19, 129:14 Beth - 254:8 Better - 88:6, 171:11, 172:9 Between - 18:9, 23:25, 26:19, 29:8, 32:17, 48:18, 49:5, 74:15, 97:23, 115:12, 128:8, 158:19, 201:15, 242:7, 247:23 Big - 64:18, 64:25, 95:10, 101:13, 167:15, 184:11, 233:8 Binder - 31:23 Birth - 7:21 Bit - 9:3, 148:6, 243:13, 250:3, 256:16, 274:18 Black - 28:7, 101:22, 148:14 Blame - 275:3, 276:4 Blanket - 170:25, 172:15, 172:16, 177:16, 181:8 Blankets - 172:12, 172:21, 172:25, 175:21, 178:7, 180:24, 184:23, 185:11 Block - 96:11 Blocking - 100:23, 101:3 Blue - 194:1 Board - 32:11, 34:4 Bodies - 78:3, 108:5, 108:14, 112:20, 112:21, 114:6, 114:9, 120:23 Body - 113:8, 131:15 72:18, 72:23, 73:7, 73:12, 120:1, 120:2, 150:6, 150:7, 150:13, 150:19 Book - 67:13, 83:12, 88:20, 89:8, 161:20, 202:6, 202:20, 203:3, 204:16, 204:20, 225:10, 228:10, 228:11, 228:12 Books - 170:23, 205:15 Booties - 18:18 BOP - 9:9, 10:14, 11:5, 12:23, 26:18, 152:23, 217:19, 237:11 Bottom - 83:15, 99:7, 182:15, 191:24, 198:14, 198:16, 218:15, 272:5, 272:20, 272:21 BP - 155:20 Brain - 273:22 Breaker - 215:7 Breaking - 24:23 Breathe - 171:11, 171:21, 172:9 Breathing - 77:21 Bright - 26:17, 28:6, 101:21 Bring - 56:13, 73:16, 136:19, 164:21, 167:21, 167:23, 169:23, 177:21, 178:21, 210:21 Bringing - 49:5, 49:6, 53:11, 53:15, 68:19, 169:24 Brings - 107:23, 109:16, 111:5, 111:6, 111:7, 232:9 Bronx - 7:18 Brooklyn - 121:14, 121:15, 121:18 Brought - 67:22, 73:19, 178:19, 230:23, 235:14, 250:12 Bubble - 23:13 Bulletin - 32:11 Bullock - 217:20, 217:25, 218:10, 218:16, 219:12, 219:16, 219:20, 223:18, 225:1, 226:5, 226:15, 227:10, 232:15, 233:9 Bunch - 236:14 Bunk - 25:21, 182:15 Bunkie's - 176:2, 176:4 Bureau - 3:8, 4:3, 10:23, 147:7 Busy - 168:6, 168:8, 262:15 Butt - 146:23, 168:11 Buzzed - 158:7 C Cage - 31:16, 32:13, 222:12, 222:24 Calling - 30:22, 42:8, 189:1, 223:22 Calls - 58:5, 59:18, 219:1, 219:4, 220:11, 221:22, 221:23, 223:2, 223:3, 225:5, 226:1, 228:8, 229:14, 229:18, 232:16, 252:2 Calm - 235:4 Cane - 15:16, 41:12, - 249:1, 756:23, 256:24, 269:17, 271:11, 271:12 Cannot - 47:3, 133:20, 137:18, 139:16, 257:22 Captain - 30:23, 41:15, 153:13, 201:16, 246:20, 247:3, 247:4, 249:22, 250:25, 251:4 Case - 58:24, 61:17, 62:20, 137:5, 139:3, 139:18, 158:1, 217:21, 218:24, 226:3, 228:18, 258:3, 261:23 Cases - 226:1 Catch - 162:2 Category - 15:21 Caught - 204:16, 204:23 Cells - 128:21, 164:14, 168:3, 170:21, 195:11, 204:5 Center - 3:17 Certain - 59:18, 62:2, 174:1 Certainly - 29:18, 72:7, 73:9, 75:16, 75:22, 162:8, 176:9 Certification - 83:2 1, 99:7 Certified - 14:9, 94:9 Certify - 13:17 Certifying - 99:8, 273:4 Chain - 250:6, 250:9 Chance - 22:8, 160:14, 243:3, 259:8 Chances - 239:5 Change - 33:25, 124:16, 139:14, 139:17, 153:10, 156:7, 156:17, 161:17, 202:3, 263:12 Changed - 112:13, 162:6, 194:2 Changes - 51:24, 153:1 Chaplain - 232:8 Charge - 12:17, 184:14 Charges - 41:11 Cheat - 121:6, 131:13, 131:19 Cheated - 120:11 Check - 59:6, 87:12, 87:15, 88:2, 198:18, 271:20 Checking - 187:24, 202:15 Child - 236:14 Choose - 5:7 Chosen - 104:15 Circle - 50:19, 194:16 Circled -201:4 Circling - 208:3 Circumstances - 4: 11, 71:18 City - 8:9, 8:10, 8:11 Claim - 122:10, 257:8 Claimed - 247:6 Clarify - 7:16, 159:6 Clarity - 255:24 Class - 35:16 Clean - 180:17 Clears - 16:4, 172:7 Click - 152:5, 168:15 Client - 72:8, 107:22, 176:12, 223:25 Close - 220:18 Closed - 221:2 Closing - 52:13 Clothes - 18:12, 20:11, 20:17, 111:1 Clothing - 175:22, 177:3, 180:12, 181:6 CO - 81:10, 148:23 Coded - 201:19 Coercion - 5:15 Coincidental - 129: 15 Coincidentally -13 0:1 Cold - 181:2 Color - 27:8, 27:12 Com - 213:6, 213:7, 213:9, 213:12, 217:13 Comes - 16:2, 24:24, 25:1, 34:15, 46:14, 63:9, 68:4, 89:24, 90:1, 111:14, 130:15, 163:15, 177:14, 187:1, 201:21, 205:14, 248:17, 249:2, 268:12 Comfortable - 276: 17 Commissary - 53:6 Commit - 16:7, 16:10, 16:20, 16:25, 31:10, 242:20 Committed - 239:21 , 241:17 Committing - 33:13 Common - 142:2 Communica - 63:25 Communicate - 23: 1, 23:8, 25:17, 25:20 Communicated - 2 3:6, 66:10 Communication - 8 :13, 22:23 Comparing - 123:1 5 Comparison - 37:1 Complaining - 235: 21 Completely - 9:19 Complicated - 106: 3 Computer - 26:18, 27:3, 27:10, 28:1, 100:21, 101:9, 252:5, 264:3 Computers - 28:2, 222:13 Conducting - 79:3, 81:11, 81:16, 82:4, 89:24, 90:2, 95:1, 98:25, 102:2, 105:3, 105:7, 128:13, 163:9, 163:13, 168:19, 269:19, EFTA00116338 269:22, 270:22, 272:10 Conference - 63:4, 64:7, 102:14, 190:3, 190:5, 270:17 Confident - 43:10, 149:4, 203:4, 254:23, 255:3, 275:16, 275:18 Confirm - 54:17, 92:1, 122:23, 129:1, 205:19 Confirmed - 62:25, 257:19, 257:23, 258:17 Confirming - 55:7 Confusing - 157:1, 198:1, 198:11, 206:16 Confusion - 27:6, 206:3 Conspiracy - 189:1 7 Constantly - 19:21, 23:10, 91:4, 242:6 Contact - 231:1, 231:3, 251:21, 251:22 Contacted - 54:24, 139:10, 252:8 Contacting - 57:24 Continued - 105:17 Contraband - 170:2 2, 269:11, 269:12 Conversation - 40: 5, 40:7, 84:2, 87:5, 146:10, 146:19, 149:5, 149:12, 150:18, 226:17, 227:25, 234:6 Conversations - 26 :6, 63:12, 69:8, 70:20, 70:25, 99:17, 102:8, 104:2, 104:10, 145:9, 145:15, 145:24, 147:2, 147:3, 147:19, 219:12, 236:22 Cool - 8:15, 8:23, 148:10 Copacetic - 10:20 Copies - 219:10 Corporal - 10:3, 10:4 Correctional - 3:16 Correctly - 95:2, 124:2, 133:25, 146:1, 146:20, 195:22, 221:10 Corresponds - 191: 4 Cos - 37:8, 77:14, 77:19, 78:4, 79:9, 81:14, 88:2, 273:5 Couldn't - 222:23, 222:24 Counted - 112:5, 112:8, 113:9, 114:5, 128:22, 142:15 Counting - 125:14, 128:9, 132:9 Couple - 28:20, 53:6, 95:15, 155:6, 160:9, 177:5, 268:18 Course - 74:1, 170:23 Courtesy - 55:24, 228:4 Cover - 170:23, 216:5, 228:19, 256:9 Covered - 140:15, 140:16 Covering - 215:21 Cozy - 276:16 CPAC - 171:6 CPAP - 171:1, 171:5, 171:6, 171:7, 171:14 Crap - 88:4 Crazy - 234:7 Create - 38:25, 99:24, 152:12 Created - 28:15, 28:18, 134:16, 134:21, 155:12, 267:23 Creates - 154:24 Creating - 268:2 Credentials - 3:5 Criminal - 5:9 Current - 7:17, 8:1, 145:2 Currently - 11:17 Custody - 218:20 D 18 213:10, 213:11, 213:16, glipf17:16 - 21:22 :12, 6:6, 7:20, 11:2, 13:20, 14:15, 16:17, 23:7, 45:23, 52:14, 68:7, 76:21, 121:11, 132:15, 141:7, 157:16, 178:17, 197:15, 237:8 Dated - 22:4, 38:22 Dates - 61:10 Dating - 22:19, 49:25, 50:2, 52:25, 53:24 Days - 29:13, 90:24, 132:25, 164:17, 166:9, 186:15, 186:16, 186:19, 187:3, 187:11, 187:12, 187:14, 187:21, 188:21, 199:1, 202:22 De - 53:18 Deal - 24:20, 36:6, 64:18, 64:25, 184:17, 184:18, 219:3, 233:8 Dealings - 234:1 Dealt - 97:4 Death - 4:10, 232:8, 237:12, 238:11, 240:17 Decide - 97:6 Decided - 200:8, 201:10 Decision - 201:14 Definite - 58:10 Deleting - 215:23 Dennis - 3:2, 3:20, 3:23, 6:6, 276:23 Dental - 158:22 Department - 3:3, 3:10, 4:19, 34:15, 63:5, 73:8, 147:12, 173:12, 174:5, 213:6, 213:10 Dependent - 173:23 Depending - 84:19, 85:5, 158:18, 166:6, 184:14, 242:25, 251:24, 270:4 Depends - 51:19, 84:5, 264:25 Design - 9:3 Desk - 28:3, 31:20, 37:2, 37:3, 37:5, 59:9 Details - 237:16 Determination - 41: 22, 200:16, 201:1 Determine - 59:24, 97:18, 206:18 Determining - 173:1 1 DHO 219:1 Die - 122:2, 242:4 Died - 69:7, 237:18 Difference - 18:8, 20:7, 20:18, 45:22, 48:18, 49:2, 49:5, 128:8 Different - 13:13, 56:19, 56:22, 78:22, 109:13, 115:16, 123:13, 147:12, 156:6, 186:25, 190:11, 190:16, 192:25, 218:17, 267:19 Direct - 251:12 Direction - 103:12 Directly - 21:20, 103:17 Director - 41:16 Dirty - 61:18 Discharge - 9:24 Discharging - 44:9 Disciplinary - 5:6, 5:10 Discrepancies -13 5:17 Discrepancy - 124: 7, 134:23, 189:24 Discretion - 87:15 Discussed - 143:4, 189:9 Dishonest - 144:11 Documentation - 9 7:11 Documentations - 49:17 Documenting - 81: 15 Documents - 13:10, 13:15, 14:11, 141:5, 141:21, 154:18 DOJ - 3:18, 3:23, 3:25, 4:9, 4:14, 4:17 Door - 30:1, 42:4, 42:15, 67:8, 73:25, 128:17, 159:1, 159:2, 167:16, 175:13, 179:14, 185:7, 200:11, 201:7, 206:14, 207:25 Doors - 158:7, 221:2 Double - 152:4, 160:10 Doubles - 242:6 Doubt - 127:19, 129:14, 216:2, 245:12 Drafted - 106:18 Draw - 9:2 Drive - 151:23, 152:1, 152:2, 152:4, 152:24 Driver - 40:12 Drop - 70:24 Dropped - 113:14 Due - 248:21, 267:11 Duties - 12:19 Duty - 9:16, 11:2, 94:13, 97:20, 258:19 E El - 1272 Each - 13:20, 14:2, 77:18, 91:4, 91:6, 172:17, 172:19, 197:22, 209:14, 209:15, 212:5, 212:7, 234:16 Earlier - 156:6, 169:8, 194:24, 248:21, 267:21 Early - 46:15, 48:10, 61:18, 240:3, 240:24 Easier - 200:22 Easy - 143:23 Eat - 241:8 Education - 8:5 Efrain - 41:1, 41:25 Eight - 128:21 Either - 16:20, 19:15, 21:12, 46:14, 57:19, 71:18, 73:12, 73:14, 75:21, 120:13, 176:8, 180:5, 188:21, 234:18, 241:20, 246:20 Elapse - 199:2 Elevator - 210:7, 210:11 Email - 21:21, 22:5, 198:25 Emergency - 231:3 Employee - 3:8, 4:20, 6:2, 6:3, 96:12, 144:16, 159:17, 159:22, 217:20 Employees - 237:11 Empty - 84:3, 84:18, 85:1, 270:10 End - 83:13, 128:22, 152:21, 206:12, 209:3, 209:16, 243:21, 246:10, 269:3 Ended - 115:14, 269:6 Ending - 136:7 Ends - 151:14 Enlarged - 101:15 Enough - 61:4, EFTA00116339 183:20, 242:8, 242:9, 265:14, 276:13 Entail - 19:9, 83:7 Enter -11:2, 168:13, 168:14 Entered - 168:4, 169:7 Entering - 154:13 Entire - 18:22, 87:9 Entrance - 207:22 Entries - 145:12 Entry - 79:17 Equipment - 32:14, 242:8 Error - 203:18, 204:13 Escaping - 185:12, 185:21 Escorting - 42:21 Especially - 162:1, 247:12, 274:25 Evaluations - 33:9 Evening - 72:17, 135:1, 159:17, 219:21 Everybody's - 63:2 1, 164:6, 187:18 Everyone - 3:20, 5:20, 24:6, 37:9, 101:25, 149:1 Everyone's - 164:9 Everything - 10:19, 10:20, 12:22, 35:20, 52:13, 74:22, 98:24, 113:21, 123:15, 134:24, 135:16, 241:6 Evidence - 5:8, 144:1 Exact - 101:18, 128:24, 130:1 Exactly - 15:6, 50:1, 53:3, 57:7, 115:25, 160:8, 174:21, 264:15 Example - 137:16 Excess - 181:13 Exchanging - 181:5 Excuse - 57:10, 95:7, 130:15, 141:17, 141:19, 150:8, 188:2, 274:3 Exist - 230:17 Experience - 274:2 Experienced - 138: 25 Expert - 131:8 Explain - 115:9, 119:1, 177:11, 184:1, 186:8, 186:12, 191:11 Explained - 246:7 Explanation - 120:2 2 Express - 236:4 Extra - 13:14, 177:6, 177:8, 177:24, 178:5, 178:7, 178:15, 180:12, 180:24, 181:19, 182:10, 184:12, 185:10, 185:11 Extremely - 129:15, 231:21,246:18 Eye - 103:16 Eyes - 158:11 F Failure - 5:3 Falsified - 141:25, 142:1, 143:6, 143:20, 215:18 Falsify - 143:10, 143:12, 144:9 Falsifying - 143:1 Familiar - 14:18 Family - 170:17, 228:5, 231:4, 232:9 Far - 9:12, 38:1, 57:18, 58:8, 91:6, 124:24, 129:11, 134:14, 181:5, 182:9, 224:18, 232:14, 243:17, 245:16 FBI - 6:20 Fear - 106:11, 236:5 Federal - 3:8, 10:23 Feed - 69:2 Feel - 6:1, 36:8, 239:4, 241:9 Feelings - 236:17 Feet - 37:5 Felix - 111:12 Felt - 104:25, 182:19 Few - 29:13, 155:7 Field - 3:5 Fight - 268:21, 269:5 Figure - 56:15, 71:15, 143:23, 176:6, 218:7 Fill - 50:21, 52:9, 91:14, 94:24, 96:24, 134:12, 135:24, 151:13, 225:11 Filled - 50:21, 51:1, 51:6, 51:8, 51:11, 90:5, 90:8, 93:2, 93:7, 93:10, 95:2 Fills - 263:3 Find - 44:16, 56:25, 58:13, 63:6, 63:8, 71:21, 85:21, 85:25, 129:14, 157:13, 157:14, 218:6, 218:15, 252:15, 252:19, 253:9 Fine - 110:9, 230:7, 234:20 Finish - 91:1 Finished - 33:8 Fit - 38:17 Five - 52:3, 52:7, 96:6, 113:3, 163:18, 168:20, 170:12, 170:23, 189:2, 198:3, 227:21, 232:6, 232:10 Fix - 135:13, 252:4 Fixed - 135:16 Flesh - 112:25 Focused - 208:24 Folder - 49:16, 152:7, 152:10, 152:11, 152:18, 153:6, 153:8 Follow - 96:20, 146:8, 147:25, 186:9, 230:4, 268:18 Following - 17:12 Forget - 21:18, 91:11 Forgot - 91:22, 140:2, 190:8, 256:19 Form - 4:17, 4:18, 252:13 Foul - 240:20 Found - 65:3, 89:3, 89:17, 89:20, 124:6, 151:25, 156:5, 165:20, 165:22, 189:12, 189:15, 250:15, 250:24, 251:2, 253:6, 258:13 Four - 113:3, 137:12, 142:3, 172:20, 195:12, 195:13, 198:2, 198:16 Free - 6:1 Frequent - 236:22 Friday - 12:9, 13:25, 39:8, 44:20, 76:11, 100:10, 116:19, 125:25, 164:6, 164:9, 244:24 Friendly - 70:14 Front - 13:11, 72:1, 200:11 Fuck - 146:6, 147:21 Fucked - 95:4, 130:13, 274:5 Fucking - 274:2 Funny - 268:9 Furnish - 5:8 Future - 5:9 G Garcia - 111:14 Gate - 179:18, 180:3 Gave - 130:25, 183:20, 221:1, 232:15, 276:17 General - 3:4, 3:11, 4:20, 4:25, 5:1, 6:5, 54:12, 78:15, 78:18, 146:12, 208:25, 220:11 Generated - 230:16 Gentleman - 15:14, 104:16 Gets - 40:19, 45:4, 76:24, 111:10, 113:9, 153:2, 189:18, 235:12, 250:8, 255:15, 275:2 Getting - 21:6, 49:23, 67:2, 109:1, 172:11, 192:25, 233:20, 243:17 Ghost - 112:22 Given - 228:4, 229:13, 229:19, 229:23, 232:4 Gives - 133:10, 232:9 Giving - 129:13 God -27:1, 30:14, 30:15, 30:17, 30:22, 30:23, 30:24, 102:25, 268:8 Goes - 28:11, 58:9, 76:22, 110:19, 111:12, 111:14, 120:25, 134:15, 167:17, 188:7, 198:1, 248:4, 251:12, 254:2 Gone - 40:23, 54:19, 58:11, 61:2, 100:12, 102:19, 126:13, 135:15, 140:4, 176:19, 216:2 Good - 34:18, 38:1, 51:18, 56:24, 61:4, 62:7, 67:2, 67:11, 71:2, 76:16, 114:6, 141:11, 144:16, 158:4, 162:22, 236:24, 276:6, 276:7 Gotcha - 168:1, 175:23 Gotten - 35:9 Graduate - 11:5 Granted - 109:7 Graphic - 8:9, 8:13, 9:3 Great - 13:9, 39:3, 39:21, 86:20, 108:9, 206:3 Greater - 168:2 Green - 7:18 GT - 192:10 Guarantee - 246:14 Guaranteed - 43:24 Guard - 9:15 Guessing - 84:25 Guys - 23:4, 52:4, 52:7, 71:1, 103:4, 103:16, 103:21, 103:24, 141:19, 142:24, 188:7, 188:8, 273:11 H H001 - 197:15 Ha - 235:13 Hadn't - 223:11 Half - 65:23 Hammering - 149:3 Hand - 7:11 Hands - 53:4 Hang - 228:6 Hanging - 26:9, 27:2, 30:5, 32:7, 100:21, 101:5 Happen - 51:12, 53:16, 168:8, 232:23, 233:17, 247:22, 274:7 Happening - 29:11 Happens - 187:7, 202:20, 228:19, 241:12, 250:9 Hard - 170:23 Harm - 16:21, 16:24, 17:3 Harming - 185:13, 185:21, 241:23 Haven't - 205:18, 230:11 Having - 70:20, 87:5, 99:17, 231:25 Head - 233:11, EFTA00116340 266:20 Hear - 16:19, 19:25, 142:11, 219:24, 220:6, 237:14, 237:19 Heard - 16:25, 82:1, 214:10, 223:11, 231:21 Hearing - 214:8, 223:15 Heat - 276:19 Heck - 172:4 Height - 182:25 Hell - 103:2 Hello - 237:2 Help - 106:7, 106:8, 119:17, 121:3, 121:5, 134:8, 171:21, 206:4 Helped - 274:16, 274:18 Helps - 172:7. - 111: 7 Her - 82:21, 95:14, 95:19, 97:4, 97:5, 97:14, 99:1, 147:19, 161:23, 162:10, 254:9, 271:17 Here's - 12:2, 37:17, 44:17, 106:14, 122:4, 184:19, 227:22 High - 8:6, 8:8, 8:20, 9:5, 9:6, 23:11, 86:14 Highest - 8:4 Highly - 216:2 Himself - 30:22, 30:24, 241:1, 266:7, 266:19, 266:22, 269:21 History - 16:6 Hit - 268:21 Hmm - 197:8 Hold - 93:22 Holders - 31:18 Holds - 243:10, 257:10 Holiday - 126:2 Home - 7:17, 61:18 Honest - 95:9 Honorable - 9:23 Hope - 143:22, 144:2, 273:25 Hoping - 119:16, 206:4, 241:1 Horn - 96:3 Hot - 31:8, 31:9, 31:13, 31:21, 32:20, 33:2, 33:6, 33:11, 33:20, 34:7, 34:17, 34:20, 36:6, 36:15, 37:2, 37:9 Hotel - 9:11, 10:9 Hour - 43:4, 65:22, 246:8 Hours - 19:11, 44:4, 246:8, 246:11, 247:23, 248:5, 248:21,276:14 Housed - 21:14, 22:7, 36:17, 36:18, 47:24, 86:18, 174:14, 193:7 Housing - 12:10, 12:12, 24:17, 24:19, 31:11, 31:13, 88:10, 89:15, 115:15, 136:15, 138:14, 177:15, 239:16, 265:1, 265:4, 272:12 However - 118:24 Huh - 58:15, 90:14, 104:13, 207:19, 219:18, 254:16, 255:21, 274:22 Human - 91:18, 115:21, 121:19, 142:9 Hundred - 69:18, 123:14, 246:13 Hurt - 82:14, 82:15, 82:17 Hurts - 182:20 Hypothetically - 95: 18 I'd - 7:9 Idea - 18:1, 244:4 Ideal - 96:12 Identify - 3:21, 211:18 Identifying - 29:24 III - 4:18 III - 194:20 I'll - 7:16, 13:12, 46:23, 61:18, 67:25, 91:14, 92:20, 99:3, 122:16, 175:19, 180:4 Imeri - 21:22 Immediately - 266:2 1 Important - 238:25, 240:9 Incident - 218:25 Include - 87:10 Including - 145:11, 212:9, 212:19 Incorrect - 156:20 Incorrectly - 199:9 Indefinite - 133:16 Indicates - 140:20 Indication - 123:22 Indirectly - 103:17 Individual - 172:17 Inform - 22:14, 251:16 Information - 4:21, 4:23, 21:12, 34:20, 35:9, 39:22, 51:25, 64:4, 115:17, 118:23, 122:18, 131:9, 255:5, 275:5 Informing - 54:11 Initial - 13:19, 78:8, 177:17 Initialing - 14:14, 22:19, 50:2, 52:25, 53:24, 141:7, 205:9 Initially - 28:21, 200:3 Initials - 77:7, 90:16, 93:15 Inmates' - 19:19 Insert - 89:11 Inside - 82:4, 110:25, 111:1, 112:5, 121:2, 181:13, 183:23, 220:8, 221:7, 222:10, 241:20, 242:2 Inspector - 3:4, 3:11, 4:19, 4:24, 5:1, 6:5 Instance - 13:23, 119:8, 126:12, 132:18, 156:19, 161:2, 216:17, 227:19 Instead - 117:8, 117:12, 118:16, 189:1, 210:21, 241:6, 245:6 Institutional - 109:5 , 112:2, 115:7, 119:1, 119:3, 126:20, 134:2, 162:9 Instructed - 21:3, 62:10 Instructing - 103:6 Instructions - 20:21 Interacted - 234:23 Interacting - 91:4 Interactions - 68:24 233:22, 234:9 Interested - 109:1 Internal - 53:12, 53:18, 71:14 Interpreted - 40:2 Interrupt - 115:19, 172:10 Interrupting - 244:1 8 Interview - 3:7, 3:15, 3:19, 4:14, 5:4, 7:9, 7:12, 8:25, 13:12, 13:16, 163:6 Interviewed - 6:20 Interviewing - 7:1 Interviews - 5:18 Investigation - 3:11 , 4:9, 4:23, 4:25, 5:2, 71:14 Involved - 64:19, 65:1, 77:3, 77:13, 167:19 Isn't - 110:11, 113:24, 167:25, 251:18, 257:24, 259:16 Issue - 178:8, 234:15 Issues - 20:1, 185:4, 185:9 Items - 49:14, 53:6 Itself - 101:10 I've - 46:13, 142:14, 146:21, 214:10 J - 208:18, 220:16, 220:18, 220:20 Jacks - 221:7 Jail - 235:11 Jean - 97:25, 98:1 Jeffery - 4:10 Jeffrey - 14:19 Jesus - 53:18 JN - 93:19 Job - 5:3, 10:12, 96:4, 103:18, 149:2, 161:23, 188:20, 273:11 Joe - 155:2, 155:3 - 123:9, 128:18 Joiner - 38:9, 38:17, 39:11, 39:24, 40:13, 60:7, 60:8, 72:15, 119:25, 146:15, 182:8, 245:16 Joint - 187:19 235:8 121:15 - 256:18, 256:19 Jumper - 235:9, 235:12, 235:24 June - 165:22, 165:25 Justice - 3:4, 3:10, 4:19 K Keep - 13:10, 31:16, 99:22, 103:16, 111:4, 114:13, 125:8, 173:17, 225:6, 230:25, 253:21, 253:25, 274:16 Keeping - 62:9 Key - 123:3, 124:9, 130:10, 136:5, 139:3, 139:19, 155:10, 156:7, 159:7, 159:14, 190:8, 200:1, 202:7, 258:11, 265:15, 265:16 Keying - 138:17, 188:11 Keypad - 225:16 Keys - 157:16, 159:4, 167:16 Kicked - 111:9, 111:11 Killed - 241:1 Knew - 21:16, 22:10, 25:19, 38:13, 43:1, 126:20, 149:25, 150:2, 244:1, 246:3, 249:22, 252:8, 267:5 Knock - 216:9, 216:10 Knowing - 5:20, 36:22, 59:22, 118:23, 144:6 Knowledge - 116:2 3, 153:8, 212:8, 265:14 Knows - 124:25, 147:9, 160:23, 160:24, 161:23, 260:3, 268:14, 268:15, 271:22 I- Language - 95:7, 130:15, 274:3 Large - 274:24 Last - 3:22, 4:6, 11:21, 39:5, 50:16, EFTA00116341 63:3, 63:4, 67:5, 159:20, 234:22, 235:2, 243:15 Late - 46:15 Later - 44:5, 51:14, 59:20, 67:14, 91:8, 109:8, 122:13, 124:12, 136:12, 160:14, 165:20, 269:18 Laughed - 235:13 Law - 222:7, 274:11, 275:15 Lawyer - 241:8 Layne - 269:18, 271:15 Laziness - 130:19 Lazy - 142:9 Leading - 146:17 Learned - 71:11 Learning - 274:1 Leaves - 56:14, 58:5, 62:18, 72:22, 74:1, 216:15, 232:16, 247:16, 247:23 Less - 87:3, 213:19, 274:9 Let - 21:22, 44:14, 44:16, 63:25, 64:1, 64:21, 67:25, 71:19, 111:4, 117:5, 174:12, 175:19, 175:20, 188:4, 191:18, 218:2, 232:17, 265:6, 265:9 Letter - 101:22, 191:4 Lettering - 28:7 Letters - 191:12, 191:14 Letting - 35:14, 232:1 Level - 8:5, 86:8 Levels - 192:8 Liability - 254:21, 270:1 Library - 222:7, 222:23, 274:11 Lie - 134:10 Life - 237:23, 238:2, 238:5, 238:8 Light - 266:19 Lights - 215:6 Limited - 254:21 Line - 116:18, 116:20, 174:2, 221:20, 221:24, 222:21, 223:5, 223:20, 224:21, 227:23, 242:20 Linen - 75:8, 180:12, 181:13, 184:24, 185:23 Linens - 74:24, 172:12, 175:21, 177:3, 181:5, 184:22, 185:10, 186:2 Listed - 32:20, 33:1, 73:1, 77:14, 154:9, 155:16, 190:18 Listen - 221:22, 224:6, 226:17, 227:24, 256:4 Listening - 232:11 Lists - 127:13 Live - 214:4 Located - 31:14, 206:5, 207:5, 208:5, 212:9 Location - 64:4, 118:20, 156:7 Locked - 57:2, 115:11 Locking - 57:3 Logged - 131:22, 131:25, 165:1, 165:15, 165:21, 166:5, 166:16, 168:22, 168:24, 189:10, 261:15, 263:6, 263:14, 263:23 Logic - 118:4, 131:2 Logistics - 62:7 Logs - 85:17, 134:12, 156:18, 240:14 Long - 10:9, 10:22, 11:7, 52:12, 69:6, 94:21, 147:7, 187:20, 187:22, 263:20, 273:22, 273:23, 274:12, 274:13 Longer - 33:12 Look - 24:24, 66:22, 83:6, 102:10, 107:4, 109:6, 111:16, 126:24, 175:5, 175:19, 177:1, 179:7, 193:3, 194:13, 206:2, 211:25, 218:14, 242:19, 272:8 Looked - 14:11, 33:16, 104:24, 120:14, 128:5, 134:2 Looking - 37:3, 38:3, 47:5, 59:23, 95:8, 107:6, 108:12, 131:1, 158:25, 161:16, 174:13, 176:20, 178:3, 182:6, 192:16, 192:18, 193:8, 218:8, 261:13 Looks - 127:4, 138:6, 175:6, 175:20, 177:2 Loop - 265:11 Loses -62:14 Losing - 244:21 Lost - 121:16, 139:3, 275:6 Lot - 37:13, 44:3, 103:15, 121:20, 141:5, 141:21, 161:11, 183:22, 196:8, 216:1, 237:14, 241:9, 246:7 Lower - 195:16, 195:20, 196:1 LT - 194:10, 207:18 LT's - 193:12, 207:25 - 3:19, 4:1, Lying - 256:5, 256:11 M Machine 171:1, 171:4, 171:20 Maintaining - 12:21 Majority - 102:20, 166:24, 167:1 Makes - 24:11, 115:22, 130:23 Making - 12:22, 24:25, 57:19, 63:14, 64:2, 145:12, 161:16, 184:21, 185:9, 186:1, 187:6, 201:18, 202:3, 213:5, 220:7, 220:11 MALE - 57:5 Man -41:11, 141:15, 141:22, 206:11 Manager - 217:21, 218:24 Mandatory - 26:24 Manipulate - 154:3, 216:10, 216:21 Manipulating - 215: 22 Manually - 80:7 Many - 115:8, 120:12, 124:25, 126:16, 129:2, 132:4, 172:12, 195:11, 214:22, 214:23, 244:16 Map - 180:5, 190:23, 191:11, 192:25 March - 11:21 Mark - 180:5 Marshals - 57:14, 264:21, 264:22 Matches - 113:17 Matching - 118:25 Mates - 15:18, 36:12, 41:17, 234:10 Matter - 22:24, 30:11, 52:11, 52:12, 131:8 Mattress - 182:10, 183:1, 183:21, 183:24, 184:2, 184:19, 184:21, 185:1, 185:2, 185:6, 185:23 Mattresses - 182:14 , 182:17, 183:13, 183:16, 184:8, 184:12, 186:2 May - 5:8, 39:13, 61:1, 67:18, 139:6, 163:23 MC - 82:4 MCC - 3:18, 4:3, 6:12, 11:8, 34:20, 42:1, 54:3, 54:8, 54:12, 56:18, 71:8, 144:25, 163:9, 163:12, 230:24, 241:8, 242:2 Meaning - 76:12, 110:24, 115:13 Means - 43:2, 45:9, 45:10, 45:11, 45:14, 84:8, 112:10, 123:23, 193:10 Medical - 158:22, 164:21, 170:24, 173:12, 174:2, 174:5, 243:2 Medication - 173:5, 173:6, 173:11, 173:24, 174:1, 174:9 Meeting - 205:21 Meetings - 205:22 Member - 39:10 Members - 53:14, 170:17, 231:5, 272:18 Memo - 38:20, 38:21, 38:23, 39:1, 53:23, 245:14 Memory - 37:22, 38:1, 84:2 Mentioned - 5:17, 6:18, 6:22, 26:14, 27:7, 53:10, 69:24, 230:10 Messed - 240:20 Metropolitan - 3:16 Michael - 145:11, 149:12 Middle - 77:9, 77:11, 171:21, 172:9, 179:13 Might - 27:6, 35:9, 58:1, 66:22, 67:8, 69:21, 99:3, 121:20, 155:18, 178:24, 193:25, 194:1 Military - 9:20, 10:10 Million - 233:10 Mind - 13:16, 14:13, 14:14, 22:16, 49:24, 52:24, 53:22, 53:23, 205:8, 235:3 Minute - 80:9, 91:25, 227:21, 232:10 MIR - 31:16 Miraculously - 143: 17 Miscommu- nication - 275:6 Miss - 28:4, 121:21 Missed - 115:23 Missing - 114:19, 273:24 Mistake - 162:2 Mistaken - 18:25, 19:17, 32:22, 241:15 Mistakes - 115:22 Mm - 215:25, 233:6 Molestation - 236:1 4 Moment - 168:2, 215:11 Monday - 100:7, 100:13, 100:14, 125:25, 164:5, 164:8, 237:8, 237:9 Monge 182:8 Monitor - 101:7, 224:3, 224:10, 227:6, 227:22 Monitored - 224:16, 226:1, 226:8, 229:18 Monitoring - 226:13 Monitors - 214:4 EFTA00116342 Month - 202:21 Months - 142:5 Morning - 59:9, 68:5, 125:23, 125:24, 126:5, 126:15, 131:21, 135:2, 135:5, 137:8, 137:9, 157:21, 158:20, 162:2, 265:23, 266:6, 266:14 Mornings - 236:23 Most -45:19, 49:3, 49:15, 73:4, 128:24, 165:7, 202:6, 203:19, 232:6, 243:10, 251:5, 256:6, 276:17 Mother - 223:1, 223:6, 223:19, 224:19 Mouth - 244:14 Move - 137:18, 140:14, 163:2, 184:7, 186:8, 187:3, 187:11, 187:12, 187:22, 188:6, 190:7, 200:22, 202:22 Movement - 121:10, 121:20, 154:21, 155:23, 161:12, 162:13, 188:11 Moves - 109:22, 121:1, 154:21 Moving - 158:6, 204:25 MPA - 208:24, 208:25 Ms - 253:16, 253:17 Multiple - 168:15 Must - 26:24, 124:22 Myself - 53:12, 61:14, 165:8, 182:8, 245:18 I N Name - 3:2, 3:22, 4:6, 6:3, 6:6, 6:15, 15:6, 46:17, 47:15, 47:23, 50:20, 73:24, 74:1, 118:9, 218:15, 225:12, 231:12 Names - 122:22 Nathaniel - 217:20 National -9:15 Nature - 142:9 IMPS 39:6, 39:7, 103:14 Neat - 8:22, 9:4, 9:8 Necessarily - 12:5, 221:18 Need - 36:4, 37:20, 52:9, 59:13, 88:6, 104:9, 123:3, 177:19, 246:1, 265:17, 265:18 Needed - 42:15, 99:25, 156:7, 267:2, 267:17, 268:2, 269:21,271:20 Needing - 39:14 Needs - 22:7, 23:4, 40:24, 62:17, 187:3, 199:11, 243:24, 245:7, 260:1, 260:4 Newer - 97:3, 147:13, 147:15, 147:17, 148:18 News - 214:11, 236:15 Nice - 276:16 Night - 23:22, 24:1, 51:5, 97:21, 99:2, 108:19, 119:22, 149:22, 150:15, 161:17, 168:18, 169:22, 171:22, 172:9, 184:16, 254:18, 254:19, 270:6 Nobody - 153:18, 153:20, 235:11, 247:2 Non - 58:10, 164:17, 218:20, 221:20, 227:23 None - 169:8, 234:18 Noose - 239:21 Normal - 71:17, 72:7, 166:4, 236:3 Normally - 181:1 Nose - 172:8 Note - 205:2, 238:18, 243:5, 243:8, 256:21 Nothing - 7:12, 18:20, 26:18, 31:4, 31:5, 53:6, 178:16, 185:20, 230:15, 234:7, 235:16, 237:15, 250:9, 269:12 Notice - 73:17, 101:25, 106:24, 182:10, 202:22, 270:8, 270:9 Noticed - 134:22, 202:12, 266:12 Notices - 202:5 Notification - 54:7, 54:11, 55:14, 57:20, 65:1, 139:23, 232:8, 246:20, 266:24, 267:2 Notifications - 63:1 5, 64:3, 66:5, 264:24 Notified - 57:9, 63:22, 245:1, 247:2, 247:3, 247:8, 250:4, 251:1 Notify - 64:20, 249:22, 265:1 Notifying - 251:9 Nude - 18:17 Numbers - 52:16, 115:16, 121:19, 121:22, 122:10, 129:19, 133:10, 135:18, 136:6, 162:5, 191:5, 191:12, 191:14 Numerous - 96:5 O Oath - 7:9, 254:25, 275:14 Observation - 17:2 1, 18:10, 18:12, 20:8, 20:9, 22:3, 22:6, 239:19 Observe - 19:22 Obviously - 96:8, 101:12, 101:25, 189:16 Office - 3:4, 3:5, 3:10, 4:19, 4:24, 6:4, 11:24, 66:25, 192:21, 193:9, 193:10, 193:13, 193:20, 194:14, 207:13, 207:14, 207:16, 263:22, 270:16 Officer - 12:17, 35:24, 37:18, 37:19, 38:15, 39:10, 39:11, 46:21, 53:13, 61:3, 84:13, 96:4, 137:14, 137:17, 145:4, 145:5, 145:7, 145:8, 222:25 Officers - 16:14, 60:11, 133:8, 137:8, 137:12, 137:15, 137:16, 164:13 Officer's - 192:21, 193:4, 194:11, 194:17, 201:2, 206:23, 207:10, 208:1, 208:4 Official - 3:10, 4:9 Oft - 141:23 Often - 142:1, 168:8, 239:17 OIC's - 28:1, 89:23, 187:18 OIG - 3:18, 3:23, 3:25, 4:9, 4:14, 4:17, 6:20 Older - 15:14, 15:21, 41:11, 104:16 Oncoming - 39:9 Ones - 33:20, 90:13, 146:15, 188:4 Open - 152:25, 159:2 Opera - 82:10 Operating - 55:5, 55:18, 61:20 Operations - 68:2, 68:4, 82:8, 82:19, 82:21, 82:24, 83:6, 248:7, 262:21, 272:6, 272:23, 272:25 Opinion - 87:24, 88:3, 94:23, 113:10, 140:19, 169:10, 215:14 Opportunity - 228:5 Opposite - 128:25, 183:7, 183:8, 195:13, 198:14 Ops - 123:17, 124:5, 216:18, 248:20, 248:22, 249:14, 249:18, 251:14, 261:18, 262:15, 270:22 Orange - 26:17, 27:13, 28:6, 30:4, 101:13, 101:22 Order - 63:25, 68:1, 205:20, 228:21 Ordinary - 235:17 Original - 194:1 OS - 194:17 Others - 238:1 Otherwise - 6:2, 144:16 Our - 4:12, 5:22, 7:2, 24:21, 32:13, 34:10, 62:15, 103:18, 121:6, 132:1, 164:2, 208:20, 254:1, 254:12, 254:18 Outer - 158:7 Outside - 18:23, 40:13, 121:1, 195:1, 206:5, 207:11, 211:12, 222:8, 241:20, 269:16 Outsiders - 210:17 Overall - 151:16, 151:18 Overdose - 173:20 Oversee - 187:9 Oversight - 154:17, 205:10 Overtime - 24:3, 25:9, 254:15 Overton - 53:19 Own - 21:1, 26:16, 33:25, 96:3, 151:16, 173:5, 174:9, 188:24, 189:3, 197:22, 238:5, 238:8, 269:1 P PAC - 225:17, 226:23, 229:20, 229:21, 229:22, 229:23, 230:14, 232:1, 232:6 Packet - 13:22 Page - 13:22, 14:2, 44:25, 50:16, 50:17, 50:18, 50:19, 163:6, 190:25,214:23 Pain - 141:14, 146:23, 168:11 Papers - 16:23, 83:13 Paperwork - 12:22, 219:8 Part - 3:9, 4:23, 24:12, 24:21, 34:10, 35:15, 78:23, 87:20, 88:17, 92:16, 98:25, 132:3, 243:13, 243:16, 251:6, 251:7, 251:9 Pass - 25:24, 36:9, 40:11, 247:12, 275:4 Passed - 35:10, 39:9, 70:12, 227:15, 250:5, 250:8, 250:16, 254:23, 255:24 Passing - 39:22, 255:5 Past - 31:10 PB - 120:25, 121:9, 121:14, 127:1, 134:7, 154:23, 159:6 EFTA00116343 PC - 101:5 68:25, 76:13, 80:21, 81:11, 81:16, 94:25, Pursuant - 5:1 Receive - 20:20, Pen - 13:15 84:24, 161:15, 132:15, 132:25, Puts - 159:8 21:12, 54:6, 264:19 Penalty - 275:14 170:13, 178:12, 187:14, 190:15, Putting - 14:14, Received - 21:20 Per - 26:25, 83:3, 201:17, 206:7, 257:18 51:24, 73:18, 207:24 Receives - 232:8 163:20, 261:20 206:8, 208:20, Prison - 236:12, Puzzle - 106:9, Receiving - 22:20, Percent - 69:18, 253:10, 274:23 236:18 119:19 44:9 123:14, 246:14 Performance - 5:3 Pointed - 116:18, 212:10 Prisons - 3:8, 4:3, 10:23 Recognize - 38:23 Recognized - 265:2 0 Perjury - 275:15 Personally - 126:6, 222:2 Persons - 117:10 Pertains - 5:2 Phones - 32:4 Phonetic - 31:17, 53:19, 53:20, 117:23, 254:8 Photos - 176:21 Phrase - 268:8 Physical - 108:4, 112:20, 112:21, 114:5, 114:9 Physically - 119:10, 132:8, 183:23, 262:20 Pointing - 194:16, 207:25, 208:11 Points - 206:25 Policies - 89:8 Policy - 12:23, 24:18, 75:6, 75:11, 83:11, 87:18, 88:25, 89:3, 89:4, 89:6, 89:17, 89:20, 148:1, 148:11, 148:13, 163:9, 163:12, 163:16, 170:19 Polite - 235:20 Pop - 87:15, 159:1 Population - 239:13 Port - 210:6 Position - 12:12, Privacy - 233:4 Privileges - 180:12 Problem - 89:23, 173:19, 184:12, 215:8, 226:8 Problematic - 169:9 , 232:21 Problems - 41:13, 242:2, 243:2 Procedure - 55:5, 55:18, 61:20, 251:21 Proceeding - 5:10 Proceedings - 5:9 Process - 54:13, 65:13, 65:15, 154:16, 177:12 Profile - 23:11, Quarterly - 25:5, 25:6, 25:11 Question - 18:8, 30:12, 30:21, 53:2, 56:25, 57:16, 57:17, 67:17, 96:13, 103:6, 116:22, 158:5, 158:16, 159:6, 159:21, 202:11, 229:13, 243:15, 269:15 Questions -4:13, 5:5, 5:7, 5:14, 5:22, 7:6, 268:17 Quote - 223:6 4, 266:7 Recommend - 64:2 2 Recommended - 10 4:24 Recommends -41: 9 Record - 3:21, 4:6, 62:9, 171:3 Recorded - 3:19, 221:20, 221:24, 223:3, 224:10, 224:20, 224:21, 227:23 Recorder - 3:1, 276:24 Recreation - 193:17 R Pick - 58:2, 58:7, 60:17, 189:2, 273:22 145:3, 248:17 Positive - 69:18 86:14 Program - 133:19 , 222:6 Rectified - 243:17 R&D's - 253:4 Picture - 174:17, Possibility - 65:25, Promise - 233:21 RA - 116:7, 116:25, Rectify - 120:10, 177:19, 210:5 126:10, 127:11 Promises - 5:14 117:6, 117:13, 121:4 Pictures - 174:11, Possible - 125:10, Promoted - 11:19, 118:2, 118:8, 118:11, Refer - 12:4, 13:13, 178:3, 211:24 136:11 96:6 118:16, 118:17, 37:21, 44:21 Piece - 101:19, Possibly - 39:13, Pronounce - 39:5 161:5 Reference - 208:20 125:9 57:14 Proper - 264:23 Radar - 241:5 Referenced - 135:2 Pill - 174:2 Post - 34:1, 147:17 Properly - 78:5, Radio - 31:17 4 Pills - 173:2 Posted - 31:11 79:10 Raise - 7:10, 214:12 Referring - 24:15, PIN - 225:17, Potentially - 16:21, Protection - 269:1 Range - 83:14, 27:1, 30:14, 30:20, 229:21, 229:22, 161:17, 185:12, Provide - 4:12, 88:11, 91:20, 94:19, 30:22, 72:12, 97:17, 229:23, 230:14, 215:18 4:21, 4:22, 5:17, 196:2, 206:13, 110:12, 218:25 232:5 Practice - 16:1, 5:19, 13:14, 13:15, 207:1, 209:2, 209:5, Reflect - 108:1, Pins - 226:23, 232:1 21:8, 30:8, 142:2 33:20, 33:22, 209:12, 271:25, 108:7, 123:11, Places - 109:13 Pre -45:1, 46:5, 114:22, 131:3, 273:8 169:16 Placing - 240:23 46:9, 47:7, 48:2, 173:13 Ranges - 82:9, Reflected - 122:13, Plastic - 53:7, 53:8 58:25 Provided - 34:21, 167:16, 212:5 156:12 Play - 240:16, Presence - 128:18 88:13, 177:8, 177:9, Rank - 10:1, 11:23 Refresh - 84:1 240:20 Present - 3:18, 180:11, 181:9, RCG - 77:8, 77:10 Refresher - 78:14, Played - 242:13, 39:10, 40:4, 231:11, 182:17, 188:1, RD - 60:21 79:2, 79:7, 79:17 243:12, 243:16 245:16 227:5, 231:23 Reach - 221:6, Regard - 99:18, Plays - 274:23 Pressure - 5:15 Providing - 57:14 222:14 104:3, 164:24, Please - 3:21, 6:1, Prevented - 238:10 Psych - 22:6, Reached - 253:18 165:11, 236:17, 6:13, 7:10, 177:18 Previously - 34:24 239:18 Read - 116:9, 241:23, 250:10 Plug - 220:19, Prideful - 96:4 Psychological - 17: 116:17, 136:9, Regarding - 20:21, 222:13, 223:20 Primary - 140:18 20, 18:9, 18:11, 272:24 22:24, 219:13 Plugged - 220:25, Print - 50:6, 106:15, 18:24, 20:7, 20:9 Reading - 195:22 Regardless - 82:20, 221:20 106:19, 121:9, Psychologist - 21:2 Ready - 43:23 105:16, 108:21, Plus - 108:15, 133:9, 187:10, 225:8 5 Rear - 206:13 273:7, 274:8 108:17, 108:18, Prints - 194:1 Psychologists - 21: Reassigning - 243: Regards - 104:11, 108:24, 111:25, Prior - 6:20, 9:9, 25, 24:22 11 240:16 112:1 10:13, 29:3, 29:8, Purpose - 36:21, Rec - 163:25, Regional - 41:16 Point - 34:19, 29:10, 29:13, 29:19, 91:24, 184:20, 216:3 164:19, 169:22, Regular - 45:23, 35:25, 42:23, 58:22, 52:18, 56:11, 76:25, Purposes - 13:16 222:24 101:19, 170:16, EFTA00116344 233:18, 234:6, 237:15, 247:19 Regularly - 202:7 Reid - 111:10 Related - 7:6, 145:12, 170:19 Relationship - 70:1 4 Release - 48:11, 240:3 Released - 251:19 Reliable - 161:13, 161:15, 161:18 Relief - 38:14, 243:23, 246:21, 247:7, 247:8, 247:18, 249:23, 250:5 Relieved - 40:8, 121:8, 144:13, 248:2 Remain - 58:21 Remembered - 126: 17 Remove - 46:6, 46:9, 47:7, 48:2, 58:25, 74:1, 178:15 Removed - 17:24, 33:6, 33:11, 42:1, 45:1, 58:25, 59:4, 59:6, 62:12, 62:21, 74:7, 74:12, 74:19, 75:13, 75:17, 109:15, 176:4, 176:5, 178:13 Removing - 137:13 Repeat - 67:5 Rephrase - 7:16 Rephrased - 148:6 Replace - 38:10, 62:22, 63:20 Replaced - 37:15, 249:1 Replacing - 63:15 Report - 6:23, 44:17, 44:18, 78:6, 163:7 Reportedly - 147:17 Reports - 33:9, 218:25 Request - 225:11 Requested -4:21, 165:19, 240:7 Requesting - 64:3, 162:11 Require - 29:23 Required - 15:25, 21:14, 22:11, 22:25, 24:7, 25:12, 25:21, 26:10, 27:8, 36:23, 37:10, 73:2, 261:7, 261:8, 261:18, 267:6, 271:19 Requirement - 23:2 , 29:25, 36:16, 52:9 Requiring - 31:3 Reserves - 9:18 Reset - 215:7 Responding - 16:14 Response - 140:23 Responsibilities -1 2:19, 19:19, 89:24, 218:1, 218:8, 218:23 Responsibility - 60: 1, 63:20, 63:22, 82:19, 164:24, 165:10, 187:18, 187:19, 227:15, 243:10, 250:3, 274:24 Responsible - 64:1 3, 82:3, 138:17, 168:19, 173:10, 178:18, 178:23, 186:1, 187:6, 188:10, 201:18, 202:3, 213:4, 226:13 Rest - 169:9, 251:8 Return - 39:13, 45:17, 45:20, 45:24, 54:2, 56:10, 56:18, 56:21, 58:6, 75:7 Returned - 56:18, 62:16, 64:7, 176:12, 196:23, 198:19, 198:22, 203:6, 204:6 Returning - 54:8, 58:23, 71:7 Returns - 58:4 Review - 6:1, 133:19 Reviewed - 141:6, 154:10, 202:14 Reviewing - 50:16, 109:4, 118:1 Reyes's - 50:20, 64:4, 74:6, 176:22, 205:3 Rice - 13:3, 13:5, 21:13, 21:17, 22:14, 22:24, 82:13, 103:23, 104:1, 8 11114:3 121:15 Role - 218:7 Roles - 218:23 Rookie - 96:5 Room - 211:1, 217:4, 217:6 Rooms - 194:1 Roster - 12:2, 13:23, 13:25, 38:4, 47:23, 55:23, 59:23, 66:14, 72:12, 104:25, 182:6, 218:9, 218:13, 254:13, 254:14, 254:18 Rotations - 186:13, 186:14 Roughly - 101:23 Rules - 147:25, 181:4 Run - 159:3 S Safest - 105:1 Sally - 210:6, 211:4, 211:6, 211:7 Saturday - 12:8, 13:24, 122:5, 122:7, 122:9 Save - 153:1 Saved -153:2 Saw - 16:23, 38:8, 40:13, 54:1, 85:1, 100:7, 135:25, 136:4, 163:6, 202:8, 234:23, 258:25, 266:18, 275:21, 275:23, 276:3 Schedule - 186:20, 253:4, 253:25, 254:2 School - 8:6, 8:8, 8:21, 9:5, 9:6 Screen - 100:24, 101:1, 101:2, 101:4, 4 - 218:16 Search 163:15, 164:3, 164:14, 164:22, 165:22, 166:13, 166:15, 167:8, 167:22, 167:24, 168:4 Searched - 164:7, 164:10, 167:3, 168:4, 178:12 Searches - 163:9, 163:13, 163:19, 164:17, 164:25, 165:11, 165:15, 168:9, 168:15, 168:20, 170:12 Searching -165:8 Seat - 276:16 Second - 15:8, 15:10, 17:15, 28:24, 31:15, 117:10, 179:14, 180:7, 190:24, 191:1, 191:17, 191:22, 192:21, 193:11, 193:22, 194:6, 206:19, 207:12, 211:10 Seconds - 179:1 Section - 5:11, 78:24, 79:1 Security - 5:3, 7:24, 185:4, 185:9 Seeing - 40:14, 69:10, 69:14, 147:5, 215:20, 256:25 Seem - 253:24 Seemed - 234:19, 235:4 Seems - 58:10, 191:12, 196:8 Seen - 28:15, 47:1, 230:11 Sees - 66:25 Selected - 41:7, 65:16 Senior - 3:2, 3:23, 11:24, 145:4, 145:5, 145:7, 145:8, 276:23 Sense - 192:13 SENTRY - 140:10, 140:11, 152:8, 152:19, 225:7, 228:16, 231:17 Separate - 86:12, 89:7 Separately - 263:1 Separations - 64:17 September - 7:22, 10:24, 11:3, 11:12 Served - 10:23, 57:11 Service - 10:8 Serving - 218:25 Set - 159:4, 167:15, 173:8, 186:20, 223:18 Seven - 10:25, 11:1, 11:9, 158:23, 216:1 awe 233:12 - 38:13, 39:24, 40:6, 40:12, 60:2, 61:3, 63:13, 182:7, 255:7, 256:2, 256:19, 275:20 Shake - 177:22 - 37:19, 38:6, 39:11, 40:21, 66:6, 72:15, 138:23, 150:22, 245:16 Share - 151:22, 152:1, 152:2, 152:10, 152:11, 152:18, 153:6, 153:7 Shared - 152:7 Sheet - 77:4, 91:25, 99:24, 121:7, 131:13, 131:19, 133:9, 195:10, 240:19, 261:14, 272:5 She's 95:18, 96:14, 97:3, 98:21, 147:16, 161:20, 247:18 Shifts - 25:10, 159:25, 160:3, 163:18, 240:14 Shit - 92:18, 176:17, 176:18, 199:11, 237:14, 258:11 Shop - 217:14 Short - 137:1, 137:6 Shortage - 242:5 Shouldn't - 108:18, 108:22, 110:4, 110:14, 110:19, 112:8, 119:4, 120:21, 177:10, 182:18, 223:7, 223:9, 227:15, 232:23 Shoulds - 37:13 Show - 13:20, 60:21, 106:4, 106:13, 119:1, 121:10, 122:1, 141:8, 157:12, 159:7, 174:11, 180:6, 180:10, 190:19, 191:13, 196:2, 196:6, 197:10, 263:9 Showed - 13:19, 27:23, 80:5, 116:10, 116:24, 121:25, 141:10 Showered - 76:18, 76:21, 76:24, 164:6, 180:17 Showers - 91:1, 105:15, 169:13, 177:16, 179:3, 182:5 Showing - 26:24, 85:18, 101:14, 106:22, 192:4 Shows - 89:8, 107:20, 108:10, 120:25, 182:23, 191:11, 263:15 SIA - 194:4 EFTA00116345 Side - 101:11, 167:21, 167:23, 195:12, 195:13 Sides - 256:9 Sign - 6:4, 6:14, 31:1, 49:24, 53:21, 83:12, 83:14, 87:23, 88:20, 91:11, 94:18, 105:4, 206:1, 262:1, 263:9, 273:7 Signature - 6:2, 6:14, 93:16, 94:14 Signatures - 77:7 Signed - 92:6, 94:19, 94:20, 127:5, 261:25, 263:10, 273:10 Signing - 6:3, 6:17, 91:25, 92:4, 92:11 Signs - 24:24, 26:9, 29:24 S e - 74:3 - 68:9, 98:7, 47:18, 249:7, 249:9, 269:17 Similar - 41:10, 254:4 Simple - 149:2 Simply - 13:18, 14:1 Since - 10:24, 15:24, 23:11, 106:21, 119:11, 142:17, 143:5, 191:21, 197:11, 215:7, 244:24, 274:25 Single - 86:15, 128:21, 151:13, 169:13, 212:8 Sir - 3:6, 4:8, 5:24, 6:4, 7:14, 11:4, 14:12, 14:17, 17:9, 53:24, 245:3, 245:6, 276:11 Sit - 211:2, 224:5, 224:9, 273:22 Sitting - 37:4, 137:18, 232:10 Situation - 247:14 Six - 113:4, 142:5, 142:7, 158:23, 198:3, 214:24, 214:25, 215:1 Sixteen - 6:11 Size - 101:14, 101:17 Sleep - 171:24, 172:5, 242:7 Sleeps - 243:1 Slept - 182:22, 183:2, 183:3 Slip - 90:8, 108:1, 108:15, 109:3, 109:5, 113:16, 117:22, 161:4 Slips - 81:15, 81:17, 106:5, 107:5, 116:25, 118:25, 120:17, 120:19, 125:19, 142:13, 161:2, 161:5 Slot - 220:21 Smith - 121:15, 123:8, 128:19, 155:2, 155:3, 227:20, 253:16, 253:17 Smock - 18:17, 19:5 Smoking - 269:10 Snoring - 171:8 Social - 7:23, 223:2, 227:1, 227:5, 229:5, 229:6 Solid - 142:24 Somehow - 118:24, 143:17 Someone - 26:14, 27:7, 54:23, 74:19, 93:1, 94:23, 114:20, 126:13, 133:25, 163:24, 178:13, 199:6, 224:3, 227:16, 230:10, 239:1, 248:15, 263:25 Sometime - 29:2, 29:8, 74:15 Sometimes - 51:22, 55:8, 91:2, 91:18, 99:2, 121:20, 144:19, 184:7, 215:6, 246:9, 251:25, 252:1 Somewhat - 46:10 Somewhere - 36:2, 216:20, 253:25, 263:16 Soon - 29:15, 62:24, 63:6, 65:3, 176:6 Sorry - 13:5, 21:22, 57:5, 76:6, 95:5, 107:5, 115:19, 116:12, 116:13, 116:15, 130:22, 163:3, 163:4, 165:24, 196:17, 198:8, 206:11, 244:20, 262:4 SOS - 39:9, 39:11 Sound - 15:11, 18:4, 96:12, 251:13 Sounded - 67:17 Sounds - 41:4, 60:19, 162:22, 198:23, 199:9, 222:20, 254:20 South - 86:4, 86:5, 86:6, 86:18, 155:3, 206:6, 207:12, 207:21, 207:23, 207:24, 211:11, 211:13, 211:14, 211:15, 211:17, 238:20, 238:22, 268:22 Sp - 31:17, 53:19, 53:20, 117:23, 254:9 Spanish - 15:6 Speak - 39:25, 64:22, 147:22, 148:7, 148:20, 221:3, 232:2, 237:10, 256:24, 265:17, 265:18 Speaking - 24:22, 96:24, 97:16, 240:13, 260:17 Specialist - 11:25, 145:6 Specific - 11:2, 15:18, 26:6, 84:10, 91:7, 103:12, 104:2, 121:11, 147:2, 228:24,236:17 Spell - 3:22, 4:5, 171:3 Spelled - 118:9, 118:10 Spend - 246:11 Spoke - 22:25, 40:12, 84:14, 102:4, 102:16, 233:23, 245:21,256:18, 257:4 Square - 272:22 SSA - 3:20 Stack - 27:13 Staffed - 137:2, 137:6 Staff's - 272:18 Stairs - 192:6 Stand - 12:15, 44:8, 112:25, 113:2, 127:25, 128:16, 128:17, 128:18, 129:3, 226:17, 227:21, 227:24 Standard - 55:5, 55:18, 61:20 Standing - 128:19, 184:3 Star - 50:19, 51:1 Start - 3:22, 34:13, 35:21, 49:23, 76:19, 78:9, 94:25, 106:20, 109:1, 128:24, 179:13, 179:24, 247:20, 266:4 Started - 9:14, 63:14, 63:15, 105:14, 125:23, 141:12, 142:6, 215:8, 243:22 Starting - 7:8, 121:23 Starts - 42:8, 247:24, 266:5 State - 235:2 Stated - 5:12 Statement - 5:8, 5:13 States - 4:18, 9:10, 116:19 Station - 28:12, 192:21, 193:4, 194:11, 194:17, 201:2, 206:23, 207:10, 208:1, 208:4 Stay - 23:9, 247:24 Stays - 25:25, 59:8, 152:24, 153:5, 153:7 Steps - 270:17 Steward - 10:18 Stood - 227:7, 227:8 Stop - 5:21, 274:2 Stopped - 248:11 Straight - 251:4 Street - 8:17 Strongly - 245:12, 256:13, 256:17, 256:18 Stuck - 51:23 Stuff - 43:6, 77:6, 118:1, 134:17, 146:25, 180:9, 216:1, 216:3, 236:15, 239:21, 240:15, 240:20, 246:15 Subject - 22:5 Substance - 237:1 Subtracting - 125:1 0 Succeed - 242:10 Such - 223:24, 255:23 Sudden - 48:10 Suggest - 122:18, 263:9 Suggested - 122:18 Suggests - 144:1 Suicidal - 36:22 Sum - 53:25 Supervision - 238:1 7 Supervisor - 12:25, 97:19, 148:24, 253:13, 253:14 Suppo - 205:13 Supposedly - 267:1 5 Surprise - 96:13, 143:3, 143:6, 214:18, 214:19, 215:10 Surprising - 263:5 Surrounding -4:11 Suspicion - 214:13 Suspicious - 240:1 5 Swear - 7:11 Swearing - 275:14 Syst - 216:23 System -45:4, 151:12, 152:15, 152:23, 168:10, 189:9, 189:21, 217:9, 231:6 Systematic - 242:2 T Tag - 74:1 Tags - 73:25 Taken - 5:6, 22:6, 62:11, 62:22, 62:23, 73:16, 79:7, 84:24, 147:3 Takes - 35:19, 36:3, 179:1, 242:18, 274:1 Taking - 43:24, 49:17, 215:23, 237:22, 238:1, 238:8, 276:14 Talk - 79:2, 97:10, 119:9, 148:23, 160:11, 160:15, 163:10, 181:7, 205:8, 213:17, 234:3, 234:4, 236:1, 260:20 Talked - 34:24, 35:7, 70:10, 112:14, 141:21, 151:9, 213:23, 240:12 Talking - 15:8, 25:5, 26:1, 67:25, 87:13, 88:23, 102:2, 123:16, 133:3, EFTA00116346 147:5, 160:20, 166:22, 171:11, 209:12, 219:16, 234:15, 237:13, 260:21 Talks - 244:15 Tartaglione - 15:10, 16:21, 16:24, 17:3, 190:13, 190:15, 203:24, 204:6, 233:24, 234:10, 234:12, 268:19 Tartaglione's - 203: 11 Taught - 24:16, 185:14 Teach - 79:18 Team - 218:12, 218:19, 225:24, 231:4, 231:11, 231:13, 231:14 Tech - 213:7, 213:12 Technically - 167:1 4 Telephone - 219:21, 220:3, 220:7, 220:11, 220:25, 221:1, 221:17, 221:19, 224:3, 232:18 Telling - 27:14, 40:21, 87:25, 95:19, 103:17, 148:10, 194:23 Tells - 60:16, 124:18, 181:13, 262:15 Ten - 270:16 Thank - 3:6, 4:8, 4:16, 6:3, 7:14, 10:7, 11:4, 14:13, 14:17, 49:22, 53:24, 57:3, 57:6, 228:6, 276:11, 276:12, 276:13 Themselves - 3:21, 34:4, 139:7, 174:6, 185:13, 185:21, 249:20, 263:19 Theorists - 189:17 Therefore - 155:18, 156:24 They'd - 17:9, 131:19, 160:21 They'll - 51:22, 51:25, 174:2, 185:6, 246:11, 251:25, 252:1, 265:15 They've - 232:4 Thick - 183:20 Things - 49:24, 51:12, 52:10, 186:3, 189:20, 205:15, 215:22, 219:6, 225:16, 233:10 Thinking - 69:8 Third - 44:25 Thirty - 274:12 Thomas - 107:7, 145:11, 147:6, 149:12, 265:23, 267:5 Thought - 54:2, 96:14, 111:4, 111:25, 193:18, 198:24, 200:25, 201:9, 248:10, 248:11, 261:12 Threat - 33:12 Threats - 5:14, 236:8 Throat - 172:8 Throughout - 23:9, 51:23, 80:18, 87:18, 90:4, 90:25, 137:19, 142:7, 169:12, 256:17 Thursdays - 205:22 Tied - 160:13 Tiers - 76:15, 83:8, 83:10, 83:22, 83:25, 87:10, 88:1, 98:17, 99:9, 167:17, 214:22, 214:24, 214:25, 215:1, 221:7, 272:3, 272:10 limes - 20:15, 25:22, 26:21, 43:5, 44:3, 51:8, 56:19, 56:22, 76:16, 91:7, 91:8, 92:16, 93:4, 95:16, 154:9, 158:24, 183:22, 265:13 Tipped - 84:17 Title - 11:23, 79:1 TN - 93:21 Today - 67:9, 121:12, 155:2, 187:2, 245:7 Today's - 3:11 Together - 41:13, 42:18, 56:21, 106:9, 119:20, 262:24, 262:25 Tomorrow - 44:6 Too - 9:6, 56:25, 143:14, 143:23, 168:8, 206:4, 206:16, 255:7, 262:15, 270:1, 271:10 Took - 139:25, 164:12, 167:9, 178:1, 184:6, 238:5 Tools - 242:9 Toot - 96:3 Top - 13:20, 13:22, 23:12, 23:14, 44:17 59:8, 104:6, 177:19, 198:15, 198:16, 207:14, 214:23 Tops - 141:7 Total - 107:1, 107:20, 108:13, 132:1 Tour - 194:5 Tova - 94:6, 94:24, 96:24, 97:17, 133:3, 145:11, 147:16, 148:17, 149:7 Towards -42:15, 67:8, 209:3, 256:22 Town -40:12 Tr - 225:15 Track - 125:8, 225:6, 253:21 Traffic - 248:22 Train - 97:5 Transcriber - 172:3 Transfer - 47:25, 232:4 Transpire - 51:16, 52:10 Transpired - 16:17 Tried - 31:10, 239:4, 243:7 Troubled - 185:5 True - 246:5 TRUFONE - 225:8 TRUSCOPE - 79:25 , 80:7, 80:11, 80:15, 80:17, 80:24, 85:19, 85:24, 89:12, 89:13, 152:19, 165:5, 165:16, 228:14, 228:18, 263:3 Truth - 7:11, 7:12 Try - 7:16, 91:16, 97:4, 239:5 Trying - 16:7, 16:20, 16:25, 17.3, 56:15, 71:14, 119:15, 120:7, 125:8, 131:3, 131:4, 168:1, 168:2, 190:20, 198:12, 234:2 Turn - 180:2, 216:23, 217:9, 217:12, 276:19 Turning - 276:24 Turns - 256:3 Type - 32:11, 173:24 Typed - 27:18 Typical - 251:20 Typically - 51:11, 136:17, 136:21, 149:13, 239:18 U Uh 58:15, 90:14, 104:13, 207:19, 219:18, 254:16, 255:21, 274:22 Um - 243:19 Unaware - 41:17 Under - 7:9, 71:17, 241:5, 254:25, 275:14 Understand - 5:11, 5:24, 7:15, 64:1, 195:14, 273:12 Understanding - 5: 23, 7:2, 41:21, 54:1, 133:25, 140:22, 168:3, 168:18, 185:20, 191:20. 193:3, 200:9, 221:24, 226:5, 229:12, 237:18 Understood - 234:1 4 Unfilled - 248:4 Unfortunate - 276:4 UNIDENTIFIED - 57 :5 Uniform - 180:17, 180:19 Unique - 247:14 United - 4:18, 9:10 Units - 78:21, 133:11 Unlikely - 54:2 Unquote - 223:6 Update -22:3, 50:7, 50:12 Updated - 52:19, 159:9 Uploaded - 152:22, 153:5 Upon - 25:19, 39:14, 48:1, 61:21, 63:11, 71:23, 95:19, 110:15, 154:12, 173:23, 198:25 Upper - 86:8, 195:20 Ups - 268:18 Upstairs - 21:9, 28:20, 29:15, 33:24, 43:6, 44:6, 63:9, 69:2, 71:5, 192:10, 199:17 Use - 119:23, 134:12, 155:13, 171:21,223:9 Used - 5:8, 5:16, 21:24, 50:11, 50:21, 103:14, 103:21, 104:5, 188:23 Uses - 111:1 Using - 112:2, 125:11 Utilizing - 114:17 V Verification - 75:20, 264:19 Verified - 62:25, 65:5, 75:17, 114:10, 226:18, 264:11, 264:15, 264:16 Verify - 58:18, 113:3, 113:4, 124:8, 140:3, 154:20, 154:22, 155:14, 155:22, 160:15, 203:2, 223:23 Verifying - 154:16 Versa - 70:12, 189:21 Versace - 235:12 Very - 94:25, 96:3, 144:11, 147:7, 161:20, 162:15, 162:16, 162:17, 235:20, 238:24, 240:9, 254:21, 254:24, 255:2, 275:16 Vet - 229:14 Vetting -41:16 Vice - 70:12, 189:21 Video - 214:14 View - 161:18 Visit - 39:15, 42:11, 63:2, 63:4, 72:9, 76:23, 169:24, 176:12, 210:15, 210:18, 235:15, 236:7, 258:16, 260:25, 270:6, 270:15 Visited - 86:24, 99:12 Visiting - 83:7, 210:7, 210:11, 211:4, 211:6, 211:7 Visitors - 210:13, 210:22, 211:2 EFTA00116347 Visits - 23:16, 158:23, 170:15, 170:16, 263:25 Voluntarily - 4:12 Voluntary - 4:13, 4:21, 5:4, 5:18, 5:21 W Wabs - 246:7 Wait - 215:2 Waiting - 189:2 Waiver - 5:11 Walked - 15:16, 42:3, 42:14, 67:7, 83:21, 83:25, 84:6, 84:8, 92:17, 128:4, 261:4,271:1 Walking - 42:10, 43:12, 87:10, 147:4, 175:13, 176:16, 232:1, 255:14, 265:19, 271:13, 272:3 Walks -46:21 Wall - 32:8, 183:23, 184:4, 212:14, 212:15, 212:16 Wanted - 16:24, 64:25, 106:23, 140:17, 140:18, 174:12, 223:1, 228:23, 242:20, 244:18, 274:7, 274:20 Wants - 64:19, 146:22, 229:9 Warden - 30:23, 39:4, 41:15, 103:3, 103:14, 153:13, 201:16, 227:20 Warden's - 39:5 Warehouse - 150:9 Warnings - 4:20, 5:12, 5:20 Washington - 60:9 WatchlPsych - 22:3 Watched - 17:14, 19:10, 19:15, 100:7, 161:8 Watching - 19:20, 20:14, 30:17, 95:20, 136:11, 147:5, 160:7 Water - 110:25 Wednesday -164:5 , 164:9, 276:22 Week - 189:13, 202:21, 239:12 Weekend - 12:8, 82:17 Weekends - 100:16 Weekly - 204:16 Weeks - 28:20, 239:12, 239:22, 239:23, 239:24 Weight - 257:11 Weird - 192:22 We'll - 77:4, 77:18, 106:20, 107:11, 164:21, 184:10, 188:15, 198:17 Weren't - 77:3, 105:4, 124:1, 183:15, 214:20, 215:19, 221:7, 242:12, 275:22 We've - 58:2, 120:15, 173:21, 213:12, 266:23, 273:23 Whatever - 33:8, 61:21, 61:23, 101:24, 114:10, 121:11, 137:23, 141:6, 159:15, 172:7, 191:1, 226:23, 237:8 What's - 20:6, 67:6, 71:1, 87:24, 88:3, 128:8, 131:25, 132:22, 145:2, 148:1, 150:21, 151:25, 184:20, 229:19, 236:23, 239:5 Whenever - 79:20, 105:22, 250:14 Whereas - 127:13 Where's - 270:10, 270:14 Wherever - 58:6, 263:14 Whether - 25:25, 26:2, 43:7, 113:1, 242:21, 246:15, 274:8 Whichever - 222:20 While - 14:22, 19:19, 20:1, 53:1, 73:7, 94:13, 105:16, 176:16, 241:21, 258:18, 268:21 White - 148:14 Whoever -16:6, 25:23, 64:20, 65:14, 100:6, 119:22, 126:22, 154:13, 159:9, 199:17, 229:9, 231:5, 232:7, 250:14 Whole -11:9, 11:13, 19:1, 19:5, 23:17, 87:18, 90:25, 104:25, 137:19, 140:19, 142:10, 208:24, 243:25, 256:17 Who's - 131:24, 131:25 Will - 3:19, 4:13, 5:6, 39:14, 123:5, 123:7, 134:8, 159:7, 174:5, 243:14, 275:10 Willing - 5:13 Window - 159:3 Wintertime - 172:24 Within - 43:3, 80:12, 80:24, 90:3, 96:6, 97:7, 155:6, 173:2, 187:2, 246:8 Without - 132:8, 245:11, 245:18 Witness - 6:14, 6:15, 6:17 Won - 96:5 Wondered - 230:12 Wondering - 162:11 Won't - 42:13 Word - 244:13, 244:14, 251:20 Worker - 148:23 Works - 28:9, 34:6, 147:11, 182:1, 212:12 Worried - 236:7, 241:9 Worry - 99:3 Worth - 6:24 Write - 19:24, 80:2, 80:11, 80:14, 91:19, 91:22, 92:18, 115:23, 119:7, 120:17, 125:19, 128:22, 129:4, 142:11, 194:15, 194:20 Writing - 6:6, 92:13, 115:5, 115:6, 119:10 Written - 22:21, 120:24, 124:22, 228:11 Wrote - 92:21, 117:19, 126:11, 130:14, 134:3 Y Year - 10:12, 11:21, 96:5, 96:6 Years - 10:11, 10:25, 11:1, 11:9, 142:4, 160:14, 166:22, 216:1, 254:2 Yellow - 31:23 Yep - 146:21, 159:19, 210:9, 210:24 Yesterday - 106:19 Yet - 25:11, 88:24 York - 3:5, 3:17, 4:4, 6:13, 7:19, 8:10, 8:11 You'd - 152:7 You'll - 154:8, 218:15 Yourself - 6:1, 69:5, 228:19 You've - 58:6, 80:21, 96:11, 132:14, 168:11, 223:23 Z ZA - 106:24, 107:6, 107:19, 108:10, 108:13, 108:14, 108:15, 109:2, 109:20, 111:16, 111:21, 113:16, 127:4, 138:4, 157:8, 162:13, 162:14 '79 - 7:22 0 j 00:12:35 - 20:13 00:20:31 -31:17 00:30:47 - 45:24 00:33:56 - 50:15 00:36:01 -53:19 00:36:05 - 53:20 00:38:15 - 56:8 00:49:03 - 69:17 00:53:10 - 74:25 00:58:37 - 82:14 01:00:45 - 85:15 01:06:57 - 93:25 01:07:18 - 94:17 01:11:54 - 100:2 01:20:17 - 111:8 01:25:01 - 116:11 01:26:12 - 117:23 01:31:29 - 123:25 01:34:37 - 128:3 01:49:49 - 147:6 01:53:09 - 152:9 01:55:27 - 155:21 02:08:22 - 172:1 02:10:30 - 174:25 02:13:15 - 178:23 02:13:46 - 179:20 02:15:10 - 181:23 02:20:49 - 189:14 02:31:27 - 202:5 02:37:22 - 210:1 02:37:47 - 210:22 02:58:21 - 240:4 02:59:46 - 241:19 03:10:02 - 253:23 03:10:17 - 254:9 03:15:35 - 262:2 03:22:21 - 270:19 06 - 198:3, 198:4 1 1:00 - 166:11 1:14 - 3:12 1:16 - 6:8, 6:10 1:45 - 157:20 1:50 - 39:8 10:30 - 155:5 101 - 187:2, 187:4 10465 - 7:19 10th - 7:8, 8:18, 12:3, 12:6, 12:7, 98:5, 106:6, 135:15, 150:25, 151:4, 157:17, 157:20, 174:11, 189:6, 204:9, 205:5, 212:23, 237:5, 242:17 11 - 101:23, 155:3, 268:21 11:00 - 122:4 11:27 - 86:4, 86:21 11:28 - 86:5 11:30 - 260:11 12 - 38:22, 101:23 12:00 - 72:22, 72:23, 117:5, 118:3, 119:9, 119:14, 160:4, 253:2, 253:3 12:30 - 22:4 122-62-3749 - 7:25 123 - 121:18 13 - 101:24, 195:8 14 - 3:12, 14:16, 129:2, 195:8, 276:22 15 - 19:23, 128:22, 129:1, 129:4, 187:22, 195:8, 220:22,232:16 16 -195:8 17 - 195:8 18 - 187:11, 195:6 19 - 54:7, 195:6 1978 - 5:1 1998 - 9:14 EFTA00116348 2 20 - 91:12 2005 - 9:16 201 - 196:13 2011 - 9:22 2014 - 10:24, 11:3 2015 -11:6 2020 -11:21 2021 - 3:12, 14:17, 276:22 205 - 198:2, 199:25, 200:1 206L - 189:10, 195:15 21 - 11:3, 186:15, 186:16, 186:18, 187:2, 187:3, 187:10, 187:12, 187:14, 187:21, 187:23, 188:20, 199:1, 202:22 21st - 10:24, 186:21 220 - 175:2, 175:7, 175:12, 189:8, 190:11, 195:5, 197:8, 197:9, 199:3, 199:4, 200:3, 200:8, 201:18, 201:19, 202:2, 203:5, 203:15, 204:9, 205:4 221 - 174:22, 174:23 222 - 174:23 226/2 -4:18 23rd - 16:11, 190:15, 196:19, 196:24 24 - 19:10 24/7 - 238:17 2911 - 7:18 29th - 197:2, 197:7, 197:14, 198:24, 199:1, 204:9, 205:5 2nd - 17:21, 18:22, 20:23, 21:9 3 3:00 - 59:19 3:15 - 110:18, 111:6, 113:11, 116:1, 137:23, 138:1, 140:5, 141:2, 155:14, 157:8, 159:10, 161:15, 161:18, 162:13, 162:19 3:30 - 59:20, 157:22, 159:13 30 - 18:4, 22:4, 23:7, 26:25, 33:2, 80:8, 80:12, 80:13, 80:20, 80:25, 81:6, 90:3, 91:12, 91:25, 97:7, 100:1 30th - 23:25, 29:2, 30:1, 33:5, 104:8, 196:22, 198:25, 204:9 360 - 87:22 3rd - 44:13, 66:24 4 4:39 - 276:20 4:40 - 276:21 40 - 76:16, 80:12, 90:3, 97:7, 274:12 49th - 8:17 5 5:00 - 106:12, 106:23, 121:25, 122:8, 126:14 5:30 - 141:8 6 6:00 - 12:9, 68:12, 68:14, 68:16, 76:19, 84:9, 247:15, 248:12, 249:18, 252:25, 253:3 646-400-2919 - 8:3 7 I 7/14 - 14:15 7/14/2021 - 6:7 7/29 - 205:4 7:05 - 92:20 7:15 - 92:19 7:31 - 98:10, 98:11 71 - 111:12 72 - 109:2, 109:4, 109:5, 111:15, 119:9 73 - 108:13, 108:15, 108:24, 109:3, 109:6, 111:10, 111:16, 111:21, 111:25, 112:1, 112:3, 112:11, 119:10 74 - 108:22, 110:8, 111:6, 111:8, 113:25, 127:14 754 - 121:17 757 - 121:16 76 - 107:20, 109:16, 110:10 77 - 107:1, 107:9, 107:13, 107:14, 121:23 8 8/10 - 205:5 8/10/2019 - 195:23 8:00 - 44:22, 63:2, 64:6, 68:13, 68:17, 72:7, 72:13, 72:14, 72:19, 75:22, 105:13, 106:21, 109:12, 176:9, 248:13, 253:3 8:28 - 111:15, 111:16 8:30 - 52:3, 109:14 8:38 - 45:2, 50:25, 56:13 85993-054 - 39:12 86824054 - 116:21 8th - 196:14, 196:16 9 9:00 - 42:9, 42:24, 43:11, 68:1 9:30 - 42:9, 51:3, 51:4 9:50 - 144:19 EFTA00116349