EFTA00115849

1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: NONE OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL AUGUST 5, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 3 4 1 YR. : This is special agent 1 General. And these are 2 . The recorder is now on. My name is 2 my credentia s. 3 . I'm a special agent with the 3 MR. Okay. And my name is 4 U.S. Department of Justice, Office of the 4 Senior Officer with the Federal Bureau S Inspector General, New York Field Office, and 5 of Prisons. 6 these are m, credentials. 6 MR. : And spell your last name, 7 MR. : All right. 7 too. 8 MR. : This interview is with 8 MR. 9 Federal Bureau of Prisons employee, 9 MR. : Thank you, sir. 10 It is being conducted as part of an 10 YR. : This is an official DOJ/OIG 11 official U.S. Department of Justice, Office of 11 investigation into the death of inmate, Jeffrey 12 the Inspector General investigation. Today is 12 Epstein, and the surrounding circumstances. 13 August 5th, 2021, and the time is 6:19 p.m. 13 You are being asked to voluntarily provide 14 This interview is being conducted at the 14 answers to our questions. Will you agree to a 15 Metropolitan Correctional Center, MCC, 150 Park 15 voluntary interview with the DOJ/OIG? 16 Row, New York City. Also resent is DOJ/OIG 16 MR. : Yes. 17 Senior Special Agent, . This 17 MR. : Please review DOJ/OIG form 18 interview will be recorded by me, Special Agent 18 III-226/2. It states, the United States 19 . Could everyone please identify 19 Department of Justice, Office of the Inspector 20 themselves for the record, and spell your last 20 General, Warnings and Assurances to Employee 21 name? To start, a ain, I am DOJ/OIG Special 21 Requested to Provide Information on a Voluntary 22 Agent, 22 Basis. "You are being asked to provide 23 MR. : M name is senior special 23 information as part of an investigation being 24 agent, , with the U.S. 24 conducted by the Office of the Inspector 25 Department of Justice, Office of the Inspector 25 General. This investigation is being conducted EFTA00115849 S 6 1 pursuant to the Inspector General Act of 1978, 1 MR. : Here's a pen for you, if 2 as amended. This investigation pertains to job 2 you need one. 3 performance failure, security failure, and 3 MR. So, do I need a union rep for 4 false certifications. This is a voluntary 4 this? 5 interview. Accordingly -- S MR. : You could have one, if 6 MR. Mm-hmm. 6 you want, but like we mentioned, it's going to 7 MR. : -- you do not have to answer 7 be primarily to review the statement that you 8 any questions. No disciplinary action will be 8 already provided. 9 taken against you if you choose not to answer 9 MR. • Okay. 10 any questions. 10 MR. : And just to ask for some 11 MR. Uh-huh. 11 clarification on some of the information that 12 MR. : Any statement you furnish may 12 you provided. 13 be used as evidence in any future criminal 13 MR. : Let's get this over with. 14 proceedings, or agency disciplinary 14 MR. : Thank you for signing. This 15 proceedin s, or both." 15 is Agent . I'm going to put the date as 16 MR. : Uh-huh. 16 August Sth, 2021. And the time is 6:22 p.m. 17 MR. : The waiver states, "I 17 The place is MCC, New York. I'm signing at the 18 understand the Warnings and Assurances stated 18 line for signature of the Office of the 19 above and I am willing to make a statement and 19 Inspector General, Special Agent. Senior 20 answer questions. No promises or threats have 20 Special A ent would you sign it? 21 been made to me, and no pressure or coercion of 21 MR. : This is 22 any kind has been used against me." Please 22 . I'm signing as the witness. 23 review the form. If you understand and agree, 23 MR. : Did you understand the form? 24 sign your name, and print your name right below 24 MR. Yes. 25 it. 25 MR. : You understand it's a 7 8 1 voluntary interview -- 1 MR. Yup. 2 MR. Yeah. 2 MR. IIIIII!ii!hat is your current home 3 MR. : -- and you can end the 3 address? 4 interview. 4 rent home address would S MR. Like -. be 6 MR. : You don't have to answer if 6 MR. : W ere is that? 7 you don't rant to. 7 MR. In 8 MR. : It's been like this every 8 MR. • art? 9 time. 9 MR. • 10 MR. : Yes. 10 MR. • Okay. 11 MR. Yeah. 11 What is your date o irt ? 12 MR. : Before starting the 12 MR. 13 interview, I would like to place you under 13 MR. : What is your social security 14 oath. Can you please raise your right hand? 14 number? 15 Mr. , do you swear to tell the truth and 15 MR. 16 nothing but the truth during this interview? 16 MR. : IM current phone 17 MR. : Yes. 17 number? 18 MR. : Thank you. You can put your 18 MR. 19 hand down. Mr. , please let me know if 19 MR. : What is your highest level of 20 you do not understand any questions I ask, and 20 education? 21 I will try and repeat it, or try to rephrase it 21 MR. High school with some college. 22 for you. 22 MR. : What hi h school? 23 MR. Mm-hmm. 23 • 24 MR. : Okay. I just wanted to show 24 25 the recorder is right there. 25 MR. : Okay. And some college. Did EFTA00115850 9 10 1 you earn a de ree? 1 MR. : What was your enter on duty 2 MR. : No. I haven't finished that. 2 date? 3 I started in 3 MR. • It can be a month and 4 And then, I did online. So, 4 year. 5 and now, Iacing here. MR. : Yeah. MR. What major are you following? 6 MR. : Yeah. It was MR. It was criminal justice. 7 Yeah. Because I just made 'ears. 8 MR. : Were you planning - you were 8 But I could et that, as -- 9 going to finish that up, you said? 9 MR. • Oh, that's easy. 10 MR. I want to. 10 MR. • -- a paper. 11 MR. • Okay. Do you have any 11 MR. : It's fine. It's just a 12 military service? 12 know approximately when you started. 13 MR. : Yes. 13 MR. : Okay. And what did you prior 14 MR. : What branch? 14 to working at the Metropolitan Correctional 15 MR. 15 Center? 16 MR. : Honorably discharged? 16 MR. • Cleaning job. And car 17 MR. : Yes. 17 dealershiiiiiiintil I landed this. 18 MR. : When did serve? 18 MR. : Okay. And what year did you 19 MR. to 19 start here a al. 20 MR. And what grade were you when 20 MR. 21 you left? 21 MR. : With the MCC? 22 MR. I was an E4 when I left. 22 MR. Yes. 23 MR. : Okay. How long have you 23 MR. : Have you been here at the MCC 24 served with the Federal Bureau of Prisons? 24 the whole time? 25 MR. : Approximately lillyears now. 25 MR. : Yes. 11 12 1 MR. : Okay. What is your current 1 previously interviewed by the FBI and OIG 2 position with the MCC? 2 regarding the Epstein investigation? 3 MR. Senior Officer. 3 MR. Yes. 4 MR. : Who is your current 4 MR. : I'm going to read you a 5 supervisor? 5 summary of the FBI's notes. The reason, these 6 MR. The Operations Lieutenant. 6 notes belong to the FBI, but because the OIG 7 MR. : What's the name? 7 was present, we do have the notes along with 8 MR. . I think is the 8 you, too. So I'm going to read it -- 9 Operations tonight. 9 MR. Uh-huh. 10 MR. : Operations Lieutenant. Do 10 MR. : -- just tell me if there's 11 you -? 11 any corrections, or -- 12 MR. : So, what do you mean by 12 MR. : Okay. 13 that? It's every day, it's a different one, or 13 MR. -- anything that's missing. 14 (Indiscernible *00:06:1S)? 14 MR. Okay. 15 MR. : It can very well be. So, the 15 MR. : I'm going to go right into 16 lieutenants sometimes will work on a different 16 it. " informed that he has been a guard 17 schedule than us. So, our schedule, like, a 17 with the Bureau" -. 18 schedule mi ht not line up, like, tonight I'm 18 MR. : Yeah, yeah. Start from 19 working, is workinillit now, but some - 19 the beginfling,_ 20 like, yesterday, it was that was 20 MR. 'I'll': All right. So, "On September 21 working. 21 25, 2019, at approximately 11:30 hours, the 22 MR. : Sure. 22 d, along with Special Agent 23 MR. So, you know, you never know. 23 of the Offic ctor 24 MR. : Okay. 24 General, Special Agent of the 25 MR. : Do you recall being 25 Federal Bureau of Investigation, and Assistant EFTA00115851 13 14 1 United States Attornexidajltatifin 1 quick, and just et this over with. 2 district of New York, and 2 MR. : Okay. 3 did interview Federal Bureau of 3 MR. informed that he has 4 Prisons Correctional Guard, 4 completed all the basic and required training 5 Date of birth: at the Southern S for being a guard in the BOP, and that he is 6 District of New York. This interview was currently the senior officer in the Special 7 conducted in the presence of attorney. 7 Housing Unit SHU)." 8 informed that he has been a guard with 8 MR. : Well, then I was. 9 the Bureau of Prisons (BOP) for approximately 9 MR. : At that point. Okay. And 10 three years, all of which have been at the 10 August 2019? 11 Metropolitan Correctional Center." 11 MR. Mm-hmm. 12 MR. : Mm-hmm. 12 MR. : Okay. Did you -? 13 MR. : So, are you represented 13 MR. I wasn't the number one 14 in this matter? Are you represented in this 14 officer that night, but -. 15 matter? 15 MR. : Who was that number one 16 MR. Yeah. I guess so. I mean, I 16 officer? 17 had a law er -- 17 MR. I'm not even sure. 18 MR. : Yeah. So, this is -- 18 MR. : Here's the daily 19 MR. -- then. 19 assignment roster from that night. 20 MR. . -- so, I do want to make 20 MR. : Can you see it, by looking at 21 sure you understand this is a voluntary 21 the -? We provided the MCC New York roster for 22 interview. I know that you had an attorney 22 August 94'11219. 23 there. Are you good with us reviewing this 23 MR. IIIII: Okay. He was on OT. Yeah. I 24 report, and -? 24 was the number three man. 25 MR. : Yeah. We could review it real 25 MR. : You were number three. Who 15 16 1 was number one? Are you pointing to III 1 MR. : Okay. 2 2 MR. : You know, I worked in there 3 MR. Yeah. 3 every day, at that point in time, but what am I 4 MR. : Okay. 4 supposed to tell the man, like, yo, you're 5 MR. : Now, was - was number one, what am I supposed to anybody? 6 he non-custod , though? 6 MR. : Sure. So, technically, 7 MR. : Yeah. because he's number one, he was the OIC? 8 MR. : So, being that he was 8 MR. Yeah. 9 non-custody, mould you actually be kind of the 9 MR. : I gotcha. 10 OIC, being that you were, like, were you more 10 MR. But, you know, that's -. 11 senior, or -? 11 MR. : Have you received MCC 12 MR. : No. Actually, he has more 12 refresher training? Annual refresher training? 13 time in the Bureau than I do. 13 MR. In SHU? 14 MR. : He does? Okay. So, he 14 MR. : In SHU, MCC training, and 15 would be kind of responsible, at the time, 15 also in SHU. 16 then? 16 MR. : Oh, like, oh, yeah, the annual 17 MR. : Yeah. Like, the way it's a 17 18 very tricky thing, the way that that works 18 MR. : Yeah. 19 here. 19 MR. • -- training or whatever? 20 MR. : Okay. 20 MR. : Yeah. 21 MR. : You know, so, even if - 21 MR. : Like, yeah. I just did that 22 because he has more time than me, he's not - 22 on the com uter this year. 23 because he started in custody - he has more 23 MR. : Ask him -- 24 time than me, so I guess when they gave him the 24 MR. : Did you have -. 25 overtime, they just, like, filled in the slot. 25 MR. : -- you know, you want to EFTA00115852 17 18 1 ask him about at the time. 1 preventioiliiiiiiii? In 2019. 2 MR. : I'm going back. Yeah. In 2 MR. : That would have been part 3 2019, did you receive the annual MCC refresher 3 of the SHU. 4 training? 4 MR. : Part of the SHU training. S MR. : I believe so. I don't even S MR. : Yeah, as well as part of remember at this point, but I could look it up 7 in the comuter 7 MR. : Yeah. 8 MR. : Everybody pretty much 8 MR. : -- the annual refresher 9 does every year, though. Correct? 9 training. 10 MR. Yeah. 10 MR. : Yeah. I've seen that on the 11 MR. : So, you (Indiscernible 11 computer before, too. Now, in 2019, I don't 12 *00:10:10). 12 remember. It was -- 13 MR. : But we're supposed to. But 13 MR. : Sure. 14 sometimes we'll be off. 14 MR. : -- It was too --. 15 MR. : Sure. 15 MR. : Okay. We're going to go -- 16 MR. : Do you recall, in 2019, if 16 MR. : Maybe it was something that 17 you received the SHU training? 17 was mentioned in the course, that -- 18 MR. : Quarterly training. 18 MR. : Right. Yeah, yeah. 19 MR. arterly training. 19 MR. -- it's 2021, right? 20 MR. : In order to your -. You 20 MR. : Yeah, yeah, yeah, yeah. 21 were, like assigned to the SHU. 21 MR. : I understand. "When asked 22 MR. : Yeah. At some point in time, 22 about his activities for August 9th, 2019, 23 I probably did. What the dates are, I don't 23 replied, 'I assumed that's Epstein day.' 24 remember. 24 informed that, as far as he can recall, 25 MR. : Okay. What about the suicide 25 he worked the 2:00 p.m. by 10:00 p.m. shift." 19 20 1 MR. . Yes. 1 started, • - you said 2 MR. : Can you let me know who else 2 , and was still there? 3 worked with you during that shift? According to 3 MR. Mm-hmm. 4 when you - if you can refer to the roster. 4 MR. : And at 4:00 p.m., S MR. : Okay. For 2:00 to 10:00, this S came on? 6 is me right here, coming in at 2:00 to 10:00. MR. left when I came in, 7 And so, when I came in, some of these people because he's 1400. His time ended. 8 from the dayshift was still here. 8 MR. : Okay. And then, at 4:00 9 MR. : Can you - because we're 9 p.m., came in? 10 recording -- 10 MR. Yeah. He came up for 11 MR. : Oh. 11 overtime. came in for her regular shift. 12 MR. -- say the names that you're 12 MR. : Okay. I'm going to continue 13 pointing to. 13 on. 14 MR. : Okay. So, when I came in to 14 MR. Mm-hmm. 15 do SHU number three, you had 15 MR. : And I'm going to read that 16 still working. And then, at 4:00, when 16 line again. informed that, as far as he 17 the shift change came_gns_Iliis is when these 17 can recall, he worked a 2:00 p.m. by 10:00 p.m. 18 individuals came on, IIIIIIII, IIII. Well, 18 shift, and did not see Epstein for the majority 19 IIII was already there, I believe. Because she 19 of his shift because Epstein was with his 20 got stuck for overtime that night. But that's 20 lawyers all day." 21 when they came in. And then, nobody was 21 MR. Yes. 22 assigned to SHU four, after 4:00. 22 MR. first recalls seeing 23 MR. : So, you started 2:00 p.m.? 23 Epstein at approximately 8:00 p.m., and at that 24 MR. I started at 2:00 p.m. 24 time, informed BOP guard 25 MR. : And during the time that you 25 that's EFTA00115853 21 22 1 MR. : Mm-hmm. 1 MR. : That's only because of 2 MR. : "That Epstein needed to make 2 this. 3 a phone call. informed that he made the 3 MR. Yeah, yeah. 4 4 MR. : You know, picking it up. MR. 'I'll' That's backwards. S MR. : So -- 6 MR. : Go ahead. Clarify that for 6 MR. : I knew what you meant. me. 7 MR. : -- that night,1/22you in 8 MR. : What happened was is, 8 the SHU when this happened? Did IIIIIII 9 informed me that he needed to make a phone 9 approach ou in the SHU? 10 call. That's, like, because I can't make that 10 MR. : Yes. 11 determination, and that's not an officer, 11 MR. : So, that night, when that 12 that's a unit manager. 12 happened, I'm running around, as I normally do, 13 MR. : So, is a unit 13 doing things in the SHU. I get the call on the 14 manager? 14 radio. You know, you've got to return, coming 15 MR. Yeah. 15 into SHU, or whatever. So, when he gets 16 MR. Do you know his first name, 16 brought in or whatever -- 17 offhand? 17 MR. : Who gets brought in? 18 MR. : No. 18 MR. -- Epstein. 19 MR. : Okay. 19 MR. : Okay. 20 MR. ? Is that a yes? 20 MR. : Epstein gets brought into the 21 MR. Yes. 21 SHU. lust like normal, you know, like, you 22 MR. Okay. 22 take them, pat search them, and everything like 23 MR. : That's all right. 23 that before you put them in the cell. So, 24 MR. Sorry. 24 informed me, hey, he needs to make a 25 MR. : No problem. 25 phone call, I don't know if, like, you know, 23 24 1 the judge or anybody tell him that, like, yeah, 1 he came back. That day, a specific time, I 2 he gets to make a phone call or whatever. So, 2 can't remember. But I know it was around 8:00 3 okay, no problem. You know, you're owing me at 3 ish, you know 8:00, 9:00 ish. 4 this point in time or whatever. So, now, at 4 MR. : That's fine. 5 that point in time, there was a lot of stuff 5 MR. : Because the legal visits 6 going on. That, I do remember. There was a 6 usually end about 8:00. But, you know, there 7 lot of things going on. Two other inmates 7 was other thins going on. You know that? 8 attempted suicides, and, you know -. 8 MR. : Who brought him back? 9 MR. : We'll come to -. I'm going 9 MR. handed him off to me. 10 to go throw h that, too. 10 MR. : So -- 11 MR. : Okay. 11 MR. If I remember correctly. 12 MR. : You said, so, approximately 12 MR. -- so, he brought him back 13 what time did Epstein get brought back? Do you 13 from attorne visiting? 14 recall? 14 MR. : Yes. 15 MR. : It was 8:00 something, but it 15 MR. : Okay. 16 was, like, very close to, like, the end of the 16 MR. : So, he handed him off to me, 17 day. It was locking time. The day was done. 17 and told me he needed a phone call or whatever. 18 Because Epstein usually did that. He would 18 So, I had to put Epstein, you know - where'd I 19 stay with his lawyers from the time in the 19 put him? - I had to put him in the shower 20 morning, to the end, when they couldn't stay no 20 because I couldn't put him in the room, with 21 more. 21 the phone, by himself, and I'm pulling out 22 MR. : Okay. 22 other inmates at the time, because one of them 23 MR. : So, he would wait all the way 23 had a noose tied around his neck. He was 24 to the very end. And he came back after the 24 probably playing it, but you can't joke like 25 legal visits were done, that's around the time 25 that. EFTA00115854 25 26 1 MR. : Which inmate? Do you recall? 1 like, did walk with you to the -? Did 2 MR. I don't remember his name at 2 he come into the shower area with you? 3 the moment. 3 MR. No. 4 MR. : Okay. And so, you put him in 4 MR. : Well, who provided him S the shower, ou said? S the call? Did give him the phone, or 6 MR. : Yeah. 6 did you give him the phone? 7 MR. : And what did instruct 7 MR. I think gave him the 8 you? 8 phone. 9 MR. : And what - oh, just to give 9 MR. : All right. 10 him a social call, and that's it. 10 MR. Because I didn't hand him the 11 MR. : So, it was a social call, he 11 phone. 12 mentioned? 12 MR. : OkaL_____ 13 MR. Mm-hmm. 13 MR. I mean, IIIIIII told me what 14 MR. : Not a legal call? 14 he, you know, what he needed or whatever. 15 MR. I believe it was a social 15 Okay. No problem. Took him over there to the 16 call. 16 shower, put him in there, and then, I can't 17 MR. : And do you recall, who 17 remember who plugged in the phone, to give him 18 plugged thuhione in? Was it you or M? 18 the phone call. I don't remember right now. 19 MR. IIIII: I don't remember who plugged 19 MR. : Because did you -- 20 the phone in. 20 MR. : You might add -. 21 MR. : Okay. And do you remember 21 MR. : -- ever finish that 22 who he said that Epstein wanted to talk to? 22 sentence? So finish the sentence -- 23 MR. : No. He never told me who 23 MR. Yeah. 24 Epstein wanted to talk to. 24 MR. : -- before asking the 25 MR. : Was any of the instructions, 25 questions. 27 28 1 MR. Like -. 1 MR. Yeah. 2 MR. : Okay. 2 MR. : Okay. 3 MR. : Because it was two years 3 MR. : I'm going to read that. 4 ago. He's got to -. And doesn't it say in 4 " informed that he made the decision to S there -- S have Epstein call from the G-tier shower to 6 MR. : Yeah. It'll go. 6 make the call, and believes guards and 7 MR. : -- that -. 7 were present, as well. informed 8 MR. • " informed that he made 8 that dialed the number for Epstein." 9 the decision to have Epstein call from G-tier 9 MR. There we go. Yeah, because 10 shower to make the call, and believes -." 10 this was iiiiii time 11 MR. : That, I did. Because I told 11 MR. • "IIIII further informed that 12 him, put him over here. Because we couldn't 12 he did not overhear the conversation, and that 13 put him next to these other inmates. That, 13 was present for the call initially. 14 yeah. 14 And then, left before the call ended. 15 MR. : Okay. Because those are the 15 says that durin the Epstein call, another 16 inmates that was threatening suicide? 16 inmate, was claiming to want to come 17 MR. Yeah. 17 in from suici e, so that diverted some guards 18 MR. : Okay. 18 from Epstein." And do you know how long 19 MR. They were, and they were on 19 Epstein's call lasted? 20 his tier. 20 MR. : I'm not sure how long that 21 MR. : Okay. 21 call lasted. I'm sure we could look on the 22 MR. : So, on L-tier? 22 computer and 23 MR. Yeah. 23 MR. : Do you know if 24 MR. : Was, people were 24 plugged that line into the legal line, or the - 2S threatening suicide? 2S ? EFTA00115855 29 30 1 MR. I'll" I don't. 1 MR. : That should have been. Okay. 2 MR. : You don't know if it was a 2 And it should not have been on the legal line? 3 recorded hone call? 3 MR. No. 4 MR. : I don't. 4 MR. : And do you recall if S MR. : Okay. And was that normal? S stayed with him for a little bit? Did he listen 6 Does normally do that? Allow calls on 6 to the conversation? Did anybody listen to the 7 the legal line, or -? 7 conversation? 8 MR. : Not without permission, to my 8 MR. : I don't think so. Well, 9 knowledge. 9 that's -. 10 MR. : Who would have to give 10 MR. : Well, it says in here 11 permission? 11 that - so ust read the 12 MR. : Like, I've heard times that, 12 MR. Yeah. 13 you know, a judge may call, like, this person 13 MR. : -- yeah. 14 needs a legal call. And when that happens or 14 MR. Because I know was up 15 whatever, like, all right, we got to get these 15 there for a while. 16 people a legal call. And so, that does happen, 16 MR. : Do you know how long 17 but I've never known him to do that on his own 17 was there? Was he there for the 18 accord. 18 majority of the conversation, or just a 19 MR. : Okay. Our understanding is, 19 portion? 20 based on the investigation, I think Epstein 20 MR. : Oh, maybe a portion, but I was 21 stated that he wanted to call his mother. So, 21 busy at the time, so I couldn't -- 22 you think that would have been on the - that 22 MR. : Sure. 23 should have been on the -? 23 MR. -- wasn't looking at him the 24 MR. : That should have been on the 24 whole time. 25 recorded line. 25 MR. : Because we have other 31 32 1 iithat were in there, that stated that 1 over to L-tier. 2 3 iiiiiYR. basically gave him a call, and left. : Okay. 2 3 MR. MR. : To his cell. : Or into his cell. Okay. 4 MR. : And then, later, called 4 MR. : So, when you went to get S back and said, hey, his phone call is up, go S Epstein out of the cell, was the phone still in get the phone from him. 6 there with him? MR. : Mm-hmm. 7 MR. : I don't remember. 8 MR. : Does that sound right? 8 MR. : Okay. And do you know how 9 MR. : That sounds about right or 9 long after he started the phone call, you 10 whatever. I don't think I took that call. But 10 brought him back to the cell? 11 I do remember when -- 11 MR. With everything going on -- 12 MR. : Yeah. I don't think you 12 MR. : Just read it. 13 did, either. 13 MR. : I mean -. 14 MR. : -- yeah, but I know when 14 MR. : I think it says it in 15 everything was all said and done, then dealing 15 there. So, you could keep on reading, and 16 with the other inmates, you know, I can't 16 then, it'll robably get to that. 17 remember who took the phone out. I do remember 17 MR. : "After all the guards dealt 18 helping somebody bring Epstein back to his 18 with inmate , Epstein needed to be 19 cell, and put him in the cell, because I think 19 placed back in the cell. recalls no 20 I was the one that put him in the cell. 20 other guard getting up to move Epstein, so he 21 MR. : You put him back into his 21 made the move at approximately 9:30 p.m." 22 cell? 22 MR. Mm-hmm. 23 MR. : In his cell. 23 MR. recalls guard IIII 24 MR. : Okay. You know, from the 24 filing out the 30-minute round paperwork, while 25 shower, you brought Epstein back from G-tier 25 he did some of the administrative computer EFTA00115856 33 34 1 stuff. informed that -." 1 around -? 2 MR. : Before we get onto that, 2 MR. : Because ifihisiihone calls 3 though -- 3 ended after 15-minutes, if did call 4 MR. • Yeah. 4 back or whatever, and that phone call - that MR. -- does that sound right? 5 phone is supposed to die, it's supposed to go 6 9:30 p.m.? Was that when -- 6 off anywa after a certain timeframe. 7 MR. : Mm-hmm. 7 MR. : Even on a legal line? 8 MR. : -- so, he basically was 8 MR. Not on a legal line. 9 put in there - what does it sound like? - 9 MR. : Right. So, the 10 around 8:00 and then, about -- 10 information we have is, it was actually a legal 11 MR. : Mm-hmm. 11 line call. 12 MR. -- 9:30, you moved him 12 MR. : Okay. 13 back? 13 MR. : And that's what we're a 14 MR. : Yeah. Because I, like, he had 14 little confused about, why he was given a 15 to stay in there a little longer than probably 15 personal call on a legal line. But do you know 16 we wanted, because so much stuff was going on 16 anything about that? 17 that day. 17 MR. : I know up there in that SHU, 18 MR. : Right. 18 that if - and it's very difficult, especially 19 MR. Do you -. Go ahead. 19 when you're short-staffed - you know, you have 20 MR. : So, being that he was in 20 orderlies that walk around and, you know, try 21 there for probably an hour, maybe an hour and a 21 to help keep the place clean. If you're short 22 half, the majority of that time wasn't spent on 22 staffed, and you can't be everywhere, and you 23 the phone. Correct? 23 have an orderly cleaning the tier, they will 24 MR. : No. 24 take those little things, and flip the, you 25 MR. : Can you estimate, like, 25 know? Like, so, if you have somebody that's 35 36 1 coming up to SHU to work overtime, who doesn't 1 trying to get, like, all right, well, how long 2 work up there all the time, they don't know 2 was that call, and how long did he monitor? Do 3 that the inmate pulled a fast one, and moved 3 you know? 4 the thing that says legal down to social, and 4 MR. : Gotcha. vice versa. 5 MR. : And do you know that? 6 MR. : Oh, well, the information 6 MR. : That, I don't know. Because I 7 we have is actually, it was an intentional 7 8 legal line. So, not that, like, an orderly 8 MR. So, if it lasted 15 9 actually misplaced it, but it was intentionally 9 minutes, do you think he was there for, like, 10 10 five minutes? The fact that he had to go back 11 MR. : No, no, no. Not the orderly 11 somewhere, and then call, and say, hey, his 12 putting the line in or whatever. What I'm 12 call is u et that -- 13 saying is the stickers on the jacks on the 13 MR. : Yeah. 14 wall. 14 MR. : -- phone from him. Do 15 MR. : Yeah, no, our information 15 you remember -? lust because you put in there 16 is that actually was instructed, or 16 that he did stay for the call. Can you -- 17 provided, was provided approval to give a legal 17 MR. : Yes, I'm -- 18 call. 18 MR. : -- in your recollection 19 MR. Oh, okay. 19 at all, can you think about, about how long he 20 MR. : And do a legal line. But 20 was even there? 21 the instructions were also, that we understand, 21 MR. : Probably somewhere between 22 that was supposed to monitor the entire 22 five to ten minutes, but, like -- 23 call. 23 MR. : Okay. 24 MR. 24 MR. I mean, like, all that time 25 MR. : And that's where we're 25 passed now, and I was running around, and -- EFTA00115857 37 38 1 MR. : Sure. But just, you know 1 MR. : Mm-hmm. 2 he wasn't there for the whole entire thing? 2 MR. But I can't even - you know - 3 MR. : Right. 3 I can't sit there and listen to him make his 4 MR. : Okay. Sure. 4 S MR. : Mm-hmm. S : Sure. 6 MR. :,AcHust to clarify, you 6 So, I, you know -? 7 don't recall if gave instructions to 7 : So, either way, you 8 you or if you overheard him give instructions 8 didn't think you had to listen, because if it 9 to S or about -- 9 was a legal line, you can't listen; if it was 10 MR. No. 10 social line it was supposed to be recorded? 11 MR. -- monitoring the call? 11 MR. : Right. 12 MR. No. 12 MR. : All right. And then, do 13 MR. : Okay. 13 you -? 14 MR. : Like, because usually, on a 14 MR. And if we had more time, if I 15 social call, you don't really have to monitor, 15 knew, you know -- 16 because you could just go on the computer, and 16 MR. : Yeah, yeah, yeah. 17 listen to the phone call. You know, on legal 17 MR. -- what to do. 18 calls, you know, they have attorney/client 18 MR. : Absolutely. But do you 19 privilege, so you can't listen anyway. So, any 19 remember, did he instruct you to monitor the 20 time I know it may be a legal call going on, 20 call after he left? 21 and I know I can't listen in, it's because they 21 MR. No. 22 - well, this is now - but they put inmates in a 22 MR. : No. 23 little visit room for their legal calls, so 23 MR. No. 24 they could do the teleconference because of 24 MR. : Okay. Okay. 25 COVID. 25 MR. : Any other questions on that? 39 40 1 MR. : No. 1 MR. : Okay. And you were working 2 MR. : Because I'm goin to jump 2 during evenin watch, right? 3 off. Okay. recalls guard IIII filling 3 MR. : From 2:00 to 10:00. 4 out the 30-minute round paperwork while he did 4 MR. : So, who was doing the round S some administrative computer stuff." sheets? 6 MR. Mm-hmm. 6 MR. : So, this is IIII right here. 7 MR. : Do you know if she pre-filled MR. : Who's on the other one? 8 the 30-minute round paperwork? 8 MR. This one? 9 MR. I do not. 9 MR. : Yeah. 10 MR. : Okay. 10 MR. I have no idea whose signature 11 MR. : Is this the paperwork? 11 this is. This is day shift. Yeah. I don't 12 What's this? 12 know whose si nature this is right here. 13 MR. : Yeah. 13 MR. : Is it -. 14 MR. That's the 30-minute round 14 MR. Actual 15 sheet. Yeah. 15 MR. : Like, 16 MR. : So, it's on August 9th, 16 MR. : It a y mig t 'e. eah. 17 2019? 17 That looks like an 'll" Yeah. 18 MR. : Is that for the SHU? 18 MR. : You're not sure, but 19 MR. Mm-hmm. Nope. This is L- 19 maybe though? 20 tier. 20 MR. Yeah. Maybe. 21 MR. : This would be during evening 21 MR. : Because it stops, it 22 watch? 22 looks like, at about 2:00 p.m., and wasn't 23 MR. : This is morning watch. 23 done by, like, around 2:00 p.m.? 24 MR. : R1-hmm. 24 MR. : That's exactly right, because 25 MR. : Day watch. Evening watch. 25 that's when I came in. So, I relieved EFTA00115858 41 42 1 that day. So he stopped right here. 1 2 MR. : And is that why they 2 MR. : Why they wouldn't be llieah. 3 stopped there because he left? 3 filled in? 4 MR. : He -- 4 MR. : For the day watch. The end S MR. : So, it looks like they S of day watch, and that would be from -- 6 weren't -- 6 MR. : From 2:00 to 4:00. MR. : -- yeah, so, I guess the 7 MR. : -- 2:00 p.m. -. Yeah. 8 8 MR. : Or 2:30, in this case. From 9 MR. : -- filled in for the rest 9 2:30 to 4:00. I'm going to assume that they 10 of the -- 10 were forgetting because, like, from what I'm 11 MR. -- right, because the -- 11 looking at here - and this is just an 12 MR. • -- time. 12 assumption - from what I'm looking at here, 13 MR. -- date, when I relieved him, 13 from the time got into work, he was 14 I guess he must have been the one controlling 14 the one filling out this paper. Nobody else 15 this paper. So, I relieved him. And the crew 15 probably thou ht about it. 16 here didn't continue it. I just came in. So, 16 MR. : Okay. So, when you 17 I probably didn't know at the time or whatever. 17 mentioned that was filling out the 30- 18 But I think we probably did say later, like, 18 minute round sheets, you're talking about over 19 what the hell is this? 19 here? 20 MR. : Okay. So, it's probably 20 MR. : Yeah. 21 . And then, as you noticed, the other 21 MR. : Okay. So, she was 22 -. Do you know why the other round counts 22 filling out the -- 23 wouldn't be filled - the round -? 23 MR. : Yeah -- 24 MR. : These? 24 MR. • -- the day watch. 25 MR. : Yeah. 25 MR. -- because she wasn't here 43 44 1 yet. 1 okay, cool, we just did that round. And I'm on 2 MR. : All right. 2 the computer doin the other admin work. 3 MR. She wasn't at work yet. 3 MR. : Okay. So, you just -- 4 MR. : Gotcha. So, what -. So, 4 MR. Because -. S we have information, the investigation has MR. • -- saw her doing informed us that she actually pre-populated the 6 something, but you weren't really watching over 7 round sheets that she filled out. Do you know 7 her? 8 anything about her? When you say that she 8 MR. : Yeah. Because the thing is, 9 filled out these things, did she fill them all 9 because remember when you asked me about the 10 out in front of you? Did you see that? 10 SHU one position, and I'm SHU three? This is 11 MR. : Huh-uh. I didn't see her do 11 the tricky part. may be on paper as 12 that. 12 SHU one, but he's on overtime. I worked up 13 MR. : You didn't see her pre- 13 there every day. I'm the only one who has 14 populate it? Okay. Go ahead. 14 access to do the stuff on the computer. 15 MR. : " informed that, before 15 MR. : Okay. 16 he left -." 16 MR. : So -. 17 MR. : I'm sorry. Sorry. I 17 MR. : And what type of stuff 18 should follow up. What did you see her do? 18 were you g2in2 on the computer? 19 Since you said that you saw her filling out the 19 MR. IIIII: So, the computer, you do S83s. 20 round sheets. 20 You do the - there's another SHU log-in there - 21 MR. Yeah. So -- 21 you do the -. 22 MR. : What did you see? 22 MR. : When you say 583, that's 23 MR. : -- yeah, I just saw the round 23 an incident report, right? 24 sheet sitting there, and she was doing it. So, 24 MR. : Yeah. The incident reports. 25 I'm assuming that she's just doing it for, 2S You do the daily, like, inmates took showers, EFTA00115859 45 46 1 and then, the OIC thing has to have a 1 round, did you conduct a round through all the 2 signature, but because nobody else has the 2 tiers, or just around up to Epstein, just to 3 access to it, that portion will fall on me 3 check on him? 4 because the paperwork still has to get done 4 MR. : I specifically went to anyway. S Epstein. 6 MR. : Right. So, you were the 6 MR. : Okay. 7 one on your shift that had access to the actual 7 MR. IIIII! I specifically went to that 8 computer s stems -- 8 dude. 9 MR. : Right. 9 MR. : And you checked on him? 10 MR. -- and the databases. 10 MR. And I checked. I looked at 11 MR. Mm-hmm. 11 him. Yo, you good? He gave me a thumbs up or 12 MR. : Okay. 12 whatever. All 13 MR. Yeah, because they don't. So, 13 MR. : So, what do you mean? 14 I'm, like 14 Yeah. So, that, I think what his clarification 15 MR. : Sure. 15 is, you did a round on Epstein. You didn't do 16 MR. -- handle this paperwork. The 16 a round throughout the SHU. Correct? 17 physical paperwork. I'll take care of the 17 MR. IIIII: No. Not throughout the SHU. 18 computerized. 18 I have specificall checked on him. 19 MR. : Okay. 19 MR. : Oh, gotcha. Okay. 20 MR. informed that, before 20 MR. • " said that, before he 21 he left, he conducted a round and spoke to 21 left, he went back to guards IIII and 22 Epstein, and asked, 'Are you good?', to which 22 and -", oh, this -. "IIIII said that, before 23 Epstein gave a thumbs up response." 23 he left he went back to guards IIII and 24 MR. : Yes. 24 , and 'Make sure you watch him.' 25 MR. : When you say conducted a 25 Referring to Epstein, "He's your priority." 47 48 1 The wording on this is wrong. Do you recall 1 MR. : I do remember seeing that. 2 stating that to and IIII? "Make sure 2 Where it was actually posted or whatever, I 3 you watch him"? 3 don't know. 4 MR. Yes, I did. 4 MR. • I think it was on one of 5 MR. : "He's your priority."? S the computers. 6 MR. Yeah, I did. 6 MR. : Yeah. I do remember seeing 7 MR. : Why would you state something 7 that. Yeah. 8 like that? 8 MR. • So, I'm assuming that's 9 MR. I just didn't like the way he 9 also part of the reason why you checked on 10 was looking. I can't determine what this man 10 Epstein. Correct? 11 was thinking, but -. And he normally, you 11 MR. : Mm-hmm. 12 know, saying, you ask him a question, if it's a 12 MR. • Because he was the SHU 13 yes or a no question, he would normally just 13 priority? 14 give you a thumbs up or whatever, and stuff, 14 MR. Yeah. 15 like, pretty much just not want to be bothered 15 MR. • Yeah. And then, you were 16 with you, for the most part. 16 just reinforcing two of the people when you 17 MR. : Well, it was -. Wasn't 17 left, "Make sure you got him"? 18 it not true that he was kind of the priority 18 MR. : Mm-hmm. 19 for the whole SHU? Was this sign up in the SHU, 19 MR. : Okay. 20 saying that, "Mandatory rounds must be 20 MR. : And then, I looked at the guy, 21 conducted every 30 minutes on Epstein, as per 21 and then, you, you know, he just had a look on 22 God." 22 his face. I'm, like, and then, that -. And 23 MR. : Yeah. That was in the SHU. 23 I'm, like eah. I stopped. 24 MR. : So, do you remember 24 MR. : So, you actually thought 2S seeing that? 25 something might be up? EFTA00115860 49 so 1 MR. : Yeah. Because I'm looking at 1 MR. : Yeah. I didn't give them no 2 him, he gave me the thumbs up or whatever. 2 details...1 'i. id, "Watch this guy." 3 I'm, like, he just looked different. I can't 3 MR. : Did you have a feeling 4 explain it. But he just looked different. You 4 that he might hurt himself or anything like S know, he didn't look like himself. He's an S that? 6 entitled -- 6 MR. : I didn't know, but I just felt 7 MR. : Yeah, yeah. 7 that it was the best thing to just keep an eye 8 MR. -- you know, rich guy or 8 on this dude. 9 whatever. You know? Just very nonchalantly or 9 MR. : Okay. 10 whatever, I'm, like, you don't usually do it 10 MR. Mm-hmm. 11 that way. 11 MR. : Something - your spidey 12 MR. : Okay. So, you -- 12 senses went and said - something -- 13 MR. But that's my personal 13 MR. : Mm-hmm. 14 opinion. 14 MR. • -- something is amiss 15 MR. : Yeah. 15 here, or make sure you're watching him. 16 MR. That's not a fact. 16 MR. Yeah. 17 MR. : Did you mention that at 17 MR. : And your positive you 18 all to -? 18 told them that? 19 MR. : I didn't tell them that part. 19 MR. Yeah. 20 I just said, "Watch this guy." 20 MR. : Okay. And to both of 21 MR. : All right. So, you 21 them? Or you just said it both at the same 22 didn't sa wh to watch him -- 22 time, or individually? 23 MR. : Hmm-mm. 23 MR. : I said it both at the same 24 MR. : -- you just said, "Make 24 time. 25 sure you watch him"? 25 MR. : All right. 51 52 1 MR. : So -. 1 and date the top of them? It's not to test 2 MR. : And that would have been 2 what's on the documents, it's more to -- 3 right around 10:00 p.m. 3 MR. To show you that -- 4 MR. : Yeah. Right before I left, I 4 MR. : -- for our records, that -. S was, like, reah, keep an eye on that dude. S MR. • -- I saw it. 6 MR. : Okay. 6 MR. : You saw it. These are 7 MR. And right out the door. 7 documents we showed you. 8 MR. : Okay. 8 MR. And you want me to sign and 9 MR. : Did they respond to you? Did 9 date? 10 they say SE 10 MR. : Initial and date. Today is 11 MR. IIIII: I don't even remember if they 11 8/5/2021. 12 did. I know they heard me because I was 12 MR. : And you said it was 8/S -? 13 standing right in front of them, but I don't 13 MR. : '21. The same thing for the 14 even remember if they responded or not. 14 other ones too. Excuse me. This one, too? 15 MR. : And then, when he gave you a 15 MR. IIIIII: Yes, please. This, we'll 16 thumbs up, did he say anything else to you? 16 keep, just in case we go back and refer to it. 17 MR. : Hmm-mm. 17 So, I'm going to read that line back, and 18 MR. There was no verbal 18 finish off the paragraph. " said that, 19 conversation? 19 before he left, he went back to guards IIII and 20 MR. : No. 20 and, 'Make sure you watch him," 21 MR. : Okay. 21 referring -." 22 MR. : He very rarely talked unless 22 MR. : And stated. 23 he wanted something. Yeah. 23 MR. : Yeah. 24 MR. : Okay. And just because I'm 24 MR. : Make sure you have that 25 showing you these documents, can you initial 25 word. EFTA00115861 53 54 1 MR. : "And stated," just make sure 1 So, and then, you got dudes over here acting 2 I put that, "And stated, 'Make sure you watch 2 like they want to commit suicide. So now, as 3 him,' referring to Epstein, 'He's your 3 you're doing rounds, and everything is going 4 priority.'" 4 on, you talk to one inmate, now this inmate has S MR. Mm-hmm. S a problem. You may forget sometimes to go up MR. stated that Epstein there and just write it, you know, write it in 7 seemed normal and he was just sitting there." 7 or whatever. So, sometimes they might be, 8 MR. : And that's correct. 8 like, shit, fuck, I forgot. And then, they'll 9 Right? 9 go back or whatever. I'm not saying, but 10 MR. : Mm-hmm. Yeah because, like, 10 that's just, you know, normal or whatever, 11 it's an o inion of mine. I can't tell you -- 11 like, oh, man, I forgot. And you just go write 12 MR. : Sure. 12 in it. That's just normal, how they do it. 13 MR. - what I'm thinking. 13 That's why I hate these papers. I rather just 14 MR. : Absolutely. We just want 14 do it on the computer because you can't miss. 15 to make sure that the report is accurate. 15 MR. : You have questions on that? 16 MR. " explained the 30- 16 MR. : But there's still some 17 minute rounds, and when asked about the 17 more, right? 18 paperwork, stated that the exact times are 18 MR. : Yeah. "When told that there 19 probably off because they are estimates." What 19 is a video of the SHU area, stated that 20 do you mean "Estimates"? 20 he would be surprised to see video of the 21 MR. IIIII: Because, at that point in 21 rounds not being conducted." 22 time, it wLgglythree of us in there. You 22 MR. : Mm-hmm. 23 know, so, IIIIIIII is working overtime. So, 23 MR. : When asked about -. 24 he's doing multiple things. He's doing his 24 MR. : Because they were on their 25 regular job, and SHU stuff at the same time. 25 feet all day. 55 56 1 MR. : So, you're saying that they 1 MR. ..kay. 2 went in and they did the rounds? 2 MR. : Just finish the thing, 3 MR. : Yeah. I've seen it. Because 3 and then -- 4 as I'm doing my paperwork and talking to 4 5 inmates and stuff like that, they were moving MR. : -- you can ask the MR. IIIIIIillieah. 6 the whole time. I, you know, like, if I 6 additionaiiiiiitions. 7 remember correctly, I barely saw them sit down. 7 MR. : "When asked about the round 8 MR. : So, you saw them moving. Did 8 sheets and the sign-off procedures, could 9 you actually see them do the rounds, or you 9 not clearly remember who did what rounds 10 just saw them move? 10 exactly, or what, if any, rounds he did. Only 11 MR. : I saw themiiiiiiiin and out of 11 that -- 12 tiers or whatever, because -. I know 12 MR. Mm-hmm. 13 had a blue bin, at one point in time, 13 MR. : -- he would not have signed 14 he was going from tier to tier, doing 14 off on the rounds had they not been conducted." 15 something. And I think IIII had the key. You 15 MR. That's true. 16 know, but it was a lot of movement that day. 16 MR. : And based on the round 17 So, I guess that's the best way to put it. 17 sheets, you're saying that you saw IIII? 18 MR. : So, you saw movement, but you 18 MR. : Mm-hmm. 19 don't -. You didn't actually see 19 MR. : Is that signature on - 20 (Indiscernible *00:34:18)? 20 21 MR. : They had to go down the range, 21 MR. That's IIII. 22 but I didn't, like -. Every single time, at 22 MR. -- on the evening watch? 23 every 30-minute mark -- 23 MR. Mm-hmm. 24 MR. : Yeah. 24 MR. : Is that for all the tiers? 25 MR. . I don't know. 25 (Indiscernible *00:34:50). EFTA00115862 57 58 1 MR. This is -- 1 MR. : Explain that. 2 MR. : That's for L-tier, right? 2 MR. 'I'll! Like, I don't know. Because 3 MR. -- this is for L-tier. Each 3 if you were doing the round here, how did you - 4 sheet is for a different tier. And this is 3- 4 ? Unless something happened at that time, at S tier. So, 3-tier didn't get finished. K-tier S night, but I wasn't at work at that time. 6 didn't get finished. Because this is after -- 7 MR. : What do you mean, they didn't 7 MR. : Okay. 8 get finished? 8 MR. -- this is after 10:00. 9 MR. : There's blank spots. 9 MR. : After 10:00. 10 MR. For what time? 10 MR. So, I wasn't here for this. 11 MR. 11:00 and 12:00. 11 MR. : So, you're saying there's 12 MR. : What were they doing? 12 about three tiers where it wasn't finished off, 13 MR. 11:00 - excuse me - 11:00 and 13 right? The K-tier. 14 through 11:30 14 MR. : Mm-hmm. 15 MR. : What's your take -- 15 MR. : That's 3-tier. 16 MR. So -. 16 MR. That's 3. 17 MR. -- on why they would be 17 MR. : And -. 18 empty? 18 MR. 3-tier. K-tier. H. 19 MR. : Maybe they didn't -. Maybe 19 MR. : H-tier. 20 they didn't do it. I don't know. I don't know 20 MR. And G. 21 why it would be empty. I'm thinking too much 21 MR. : They weren't finished off? 22 now because I'm, like, if this was finished, 22 MR. Hmm-mm. 23 why wasn't -? 23 MR. : Okay. Do you know where? 24 MR. : What is it? You hesitated. 24 Where were these round sheets kept in the SHU? 25 MR. Yeah. 25 MR. : There's been so many changes 59 60 1 in here. 1 do a round or whatever, you go and do a whole 2 MR. : On August 9th and 10th -- 2 round, when you get to the end of the range, 3 MR. Yeah. 3 the paper is right there on the clipboard. So, 4 MR. -- do you recall where these 4 you could sign it, and finish the round, and S forms were? 5 come out. MR. I believe this was by the 6 MR. : lust to ensure that they're 7 desk. 7 actually -- 8 MR. : On the officer's desk? 8 MR. :•• Right. 9 MR. I believe so. 9 MR. -- doing their rounds. Okay. 10 MR. : Where are the forms supposed 10 And how many people are needed to conduct 11 to be kept? 11 rounds? 12 MR. When initially I was trained, 12 MR. : Only one person is needed to 13 they were on the desk. As time went on, they 13 conduct a round. 14 said they wanted them on the tiers. So, a 14 MR. : Not two people? 15 definitive answer on that, the instruction on 15 MR. No. Two people are needed for 16 that has changed so much, like, you know, one - 16 a count. 17 17 MR. : And -. 18 MR. : Mm-hmm. 18 MR. : Because, you know, like, in 19 MR. -- one day, they was, like, 19 the -. Unless it's one -. 20 keep them on the ranges, another day you come 20 MR. : Was that per policy, or 21 in or whatever, leave it right here so you 21 is that p!E_Rfactice? 22 can't miss it so you don't lose any papers. 22 MR. IIIII: Per practice. When you do a 23 MR. : Why do they keep it on the 23 round, it's one person that opens the grill, 24 ranges? 24 and one person goes down. Is that what you 25 MR. : So, on the ranges, when you do 25 mean? Because, you know, a count, one person EFTA00115863 61 62 1 goes down, comes out, and then, the next person 1 everything that we're saying is that a round 2 goes down and comes out. But for a round, only 2 and a count is exactly the same. Two people 3 one person. 3 are needed. The only difference is, during a 4 MR. : So, we were informed by 4 count, you count. per policy, at least, counts and rounds are S MR. : Hmm. No. I don't -- 6 conducted exactly the same way. The only thing 6 MR. : You've never heard of 7 difference is that, in a count, you count 7 that? inmates. Is that not correct? 8 MR. : I don't remember - after 9 MR. : Not the way I was taught, but 9 that incident - I don't remember having that 10 that's per - I'm going to be honest - that's 10 discussion with 11 per practice. 11 MR. : So, your understanding is 12 MR. : And is that even to date, 12 only one erson -- 13 that's what they do? 13 MR. : That's my -- 14 MR. : I haven't been in the SHU 14 MR. • -- per count -- 15 since -- 15 MR. -- that's my understanding. 16 MR. : Okay. 16 MR. : per round. Okay. 17 MR. -- so, I don't know what 17 MR. : Okay. Any other questions on 18 they're dging_mpLliere. 18 the rounds? 19 MR. IIIIIIIIII: Oh, you haven't been in 19 MR. : Yeah. So, as far as, do 20 SHU since this date? 20 you know if these rounds that were on this 21 MR. : I've been in there after that 21 round sheet, were they all conducted as it's 22 date, but I haven't been in the SHU in months. 22 filled out? 23 MR. : Okay. So, when you were, 23 MR. : That, I don't know, because -- 24 after that date, though, they never went over, 24 MR. : You're not sure? 25 like, how to conduct a round? And so, yeah, 25 MR. -- I'm not sure. 63 64 1 MR. : So, what is your 1 thought process is with this. 2 understanding, if the one person is only 2 MR. : So, how it mentioned 3 filling out the count, is she filling it out on 3 there that, you know, the video would be 4 behalf of - so, in this case, it was IIII - is 4 reviewed. That video has been reviewed, in 5 she filling it out on behalf of everybody in 5 detail. 6 the SHU, or is she only saying that she 6 MR. : Mm-hmm. 7 conducted the round? 7 MR. : Do you believe that all 8 MR. : I'm going to assume that she 8 these rounds were conducted on that date? 9 was filling it out for everybody that was 9 MR. : I believe the vast majority of 10 Like, so, if she did a round, and 10 them should have been. Now, were all of them? 11 did a round, she just filled it out, 11 Because I know for a fact, me personally, I 12 in that case. I learned my lesson from that, 12 wasn't the one to do every -- 13 so I onlyiiiiiiiiiien I did it. 13 MR. : So, you -- 14 MR. : Yeah, yeah, yeah. For 14 MR. • -- single round. 15 that point forward, correct? 15 MR. • -- so, you weren't the 16 MR. : Hell no. I knew that, learned 16 one conducting the round, but you can't say if 17 that before it. 17 the other eo le were? 18 MR. : All right. 18 MR. : I can't -- 19 MR. : So, you only would fill it 19 MR. : You can only -. 20 out. So, you're not, obviously, on here. But 20 MR. -- I can't say that. 21 is she filling it out for both you and 21 MR. : All right. Do you 22 as well? 22 believe all those rounds were conducted? 23 MR. : I'm going to assume, maybe. 23 MR. : I believe, I definitely 24 MR. : Okay. 24 believe this - what is this? L and M, and I'm 25 MR. : But I don't know what her 25 just confused as to the rest. EFTA00115864 65 66 1 MR. : Because again -- 1 about -. 2 MR. But -- 2 MR. : I can't say that that's for 3 MR. -- we have -. Like, our 3 sure what she did. 4 investigation has showed that that was all pre- 4 MR. : But by reviewing it -- S filled out. S MR. : I could see where -- MR. : So, yeah. And that -. Wait a MR. -- from your knowledge -. 7 minute. 7 MR. -- I could see where that MR. : And I don't know why she 8 assumption would come from. 9 would pre-fill out some of them, but not the 9 MR. : But from your knowledge 10 rest. 10 and experience, by looking at the way that 11 MR. : I see. I see why. Yeah. 11 that's filled out, you would say that that's 12 MR. Explain. 12 pre-filled? 13 MR. : Yeah. Because of the times. 13 MR. : Yes. Uh-huh. It's a 14 01:02, 33:34. 03 to 04. And then, then you 14 possibiliiiiIIIIIII 15 flip the page, it's the same thing. It's just 15 MR. : And have you ever pre- 16 a minute difference. I see why. 16 filled out round sheets? 17 MR. : So, now that you're 17 MR. No. 18 looking at it, do you believe that those are 18 MR. : Do people -- 19 accurate? 19 MR. Not to my knowledge. 20 MR. : This stuff. It's pre-filled. 20 MR. • -- do people in general 21 MR. : It's pre-filled? These 21 fill out round sheets, and they fill them out, 22 are pre-filled? 22 pre-fill them? 23 MR. : That - and yeah - it's a good 23 MR. : I'm sure they don't now. 24 possibiliix_Ib2ILI_pre-filled. 24 MR. : But did they at the time, 25 MR. IIIIIIIIII: And what do you know 25 though? 67 68 1 MR. : At the time, usually, I 1 jammed up for it? 2 stopped messing with this after my first 2 MR. : If I'm not getting jammed up, 3 incident, and dealing with this round sheet. 3 if I did it, I sign it; if I didn't do it, and 4 So, if I do a round, I fill it out. If I 4 you did it, because I won't sign for anybody 5 wasn't the one that did it, I don't sign it. 5 else. 6 MR. : Yeah, yeah. So, what I'm 6 MR. : I gotcha. So, she was 7 talking about, from August, basically 10th, 7 signing for everybody else, but you wouldn't 8 from the time he was found, previous to that, 8 sign for ever ody else. 9 would you re-populate round sheets? 9 MR. : Yeah. I didn't even -. I 10 MR. : No, I didn't pre-populate. 10 didn't toiiiiiiiiiiaper at all that night. 11 MR. : Okay. 11 MR. : Okay. But previous to 12 MR. : Because I learned something 12 that, woullnu have touched the papers? 13 before that time, to -- 13 MR. IIIII: Previous to that, I probably 14 MR. : Oh, what did you learn 14 would have done rounds. But I wouldn't have 15 before? 15 pre-populated the whole thing, like that. 16 MR. : Because that was a problem, 16 MR. : Would you ever pre- 17 with people doing that before, and nobody 17 populate 22y_part of it? 18 wanting to sign round sheets, for what reason 18 MR. IIIII: No. I don't think I pre- 19 or whatever. So, I was, like, okay, if I did 19 populate. I don't remember a time that I did 20 it, sign it; if I didn't do it, not sign it. 20 pre-populate a thing or whatever. Now, what I 21 That's how I learned my lesson. That's why my 21 will say, because I know it's common or 22 name is not on this. 22 whatever, in the beginning, I probably had 23 MR. : Okay. So, your name 23 something pre-prepped for the count, and that 24 wasn't specifically on that round sheet because 24 messed up or whatever. 25 you're, like, I'm not signing it, and getting 25 MR. : So, you would pre-prep EFTA00115865 69 70 1 the count. Not a round. 1 or whatever you -. I wrote it out. I don't 2 MR. : I pre-prepped the count slip 2 remember if I put a number in there or not yet, 3 or whateviiiiiiiiii-prepped it. 3 or whatever. And then, the count was supposed 4 MR. : Okay. So, you pre- 4 to take place. So, I pre-wrote it or whatever. S prepped the count slips, but not the round S And then, we just kept working. But there was sheets. 6 a lot goidSn ot iat day. So. 7 MR. : I didn't do this. 7 MR. : Perfect. So, going to 8 MR. : Okay. 8 that para ra h, and then -- 9 MR. No. 9 MR. : Okay. 10 MR. : Fair enough. 10 MR. -- you can clarify it. 11 MR. And that's a lesson learned. 11 MR. Yeah. So -. 12 So, I learned lesson -- 12 MR. : "When asked about the count 13 MR. : Sure. 13 number in the SHU, for the -." 14 MR. -- from that. 14 MR. : Finish the paragraph, 15 MR. : Fair enough. Okay. 15 too. Don't -. 16 MR. : Okay. And when you said you 16 MR. : Yeah. "When asked about the 17 pre-prepped the count, are you talking about 17 count number in the SHU, for the date, and the 18 the night of August 9th? 18 number matching the MCC master number, 19 MR. 4:00 p.m. 19 stated, 'This would be a mistake on my part.' 20 MR. : The 4:00 p.m. count. That 20 He probably just used the numbers off the 21 was pre-prfpol? 21 master sheet, and that there was probably 22 MR. IIIII: Mm-hmm. I pre-prepped it 22 signing off, down in response to pressure, and 23 because of my -. There was so much going on, 23 having the count cleared." 24 everybody's leaving, some people coming in, and 24 MR. So, was this what you're 25 stuff like that. I'm, like, okay, count time 25 referring to? 71 72 1 MR. : Mm-hmm. 1 MR. : -- if you say that would 2 MR. : All right. So, you're 2 have been during this interview, then -- 3 saying that -. 3 MR. : Like, because I don't think I 4 MR. : Because you will get pressured 4 had access to the El at that time. I think I S to hurry up and finish the count, even though 5 had -. It's another roster that we have in the 6 the job to work in the SHU, the crew is 6 SHU. Like, not a running board. What is the 7 supposed to be four. Very rarely, you're going 7 damn thing? I ain't been in there in a while. 8 to have four. You're asked to do the job with 8 SHU located. We have a SHU locater. And in 9 four people, with sometimes three, and 9 that or whatever, when people move, you change 10 sometimes two. 10 it on that paper or whatever. Like, now - if 11 MR. : Right. 11 you've been up there - there's a board up there 12 MR. : So, you're going to -. Your 12 now. 13 phone is ringing, you're getting pressured, 13 MR. : Okay. 14 you're getting supervisors coming at you. So, 14 MR. : You know? So, when you - on 15 if you don't have a way, you're going to find a 15 that locater or whatever, that's probably what 16 way. 16 I used because I don't believe I had access to 17 MR. : But that's what the 17 this at that time. 18 master sheet that you refer to? 18 MR. All right. So, you 19 MR. The El. 19 probably -- 20 MR. : Oh, did you have access 20 MR. : Because I wasn't working 21 to the El? 21 control at that time. 22 MR. : I don't think I had access to 22 MR. : -- so, at the time, you 23 the El at that time. 23 used the SHU locator, and the amount of inmates 24 MR. : So, how -- 24 that were listed on the SHU locater, to fill 2S MR. Yeah. 25 out the 4:00 p.m. count sheet? EFTA00115866 73 74 1 MR. : Yeah. Because, like, when 1 MR. : Yeah. So, this is the 4:00 2 you're up there or whatever, like, the day 2 p.m. count, because this is printed out on 3 shift, they got to keep that SHU locater right 3 15:41. 4 for the most part. You know what I'm saying? 4 MR. : Take a look at the back, for S You can't reall screw that up. 5 your CV, at the count slip that you - for that. 6 MR. : Okay. 6 Keep goiniiiiiiiiiithere? 7 MR. : So, I was, like, okay. Boom. 7 MR. : Just highlight it, so 8 And I - but like I said - I don't remember 8 that we can -. All right. So, ZA. That's the 9 writing a number in there or whatever, but if I 9 SHU. Correct? 10 did, I did. That's my mistake. I own that. 10 MR. : Mm-hmm. 11 MR. : But you do remember that 11 MR. : And it shows 7S? 12 you pre-po ulated it, though? 12 MR. : Mm-hmm. 13 MR. : I do remember that. 13 MR. : And then, done at 4:00 14 MR. : Because it's -. 14 p.m. Who is listed on here? 15 MR. : Like, I know I wrote my name, 15 MR. Mir and IIII. 16 and then I wrote the date, and stuff like that, 16 MR. : All right. So, that's 17 or whatever. 17 yourself, correct? And then, you say you're the 18 MR. : Let's take a look. I'm 18 one who filled that out right? 19 showing you the El. 19 MR. : Yeah. 20 MR. Mm-hmm. 20 MR. : Is that your handwriting? 21 MR. : And the count sheets for -. 21 MR. Yeah. It looks like mine. 22 Is this for the 4:00 p.m. count on August 9th? 22 MR. : All right. Cool. 23 MR. Mm-hmm. 23 MR. : The date? 24 MR. : Can you - this is the El on 24 MR. : Yeah, but I didn't -. But I 25 the front, right? 25 didn't put the -. I don't recall putting the 75 76 1 number in here. I know I put the date and the 1 MR. : You thought that they 2 time, and then I signed down here. 2 did, thou h? 3 MR. : Does that number look 3 MR. : I thought that they did. 4 like it v 4 MR. : Do you know if they did? MR. It looks like it -- 5 MR. : I think they did that, but I 6 MR. : Okay. 6 don't know for sure right now. No. 7 MR. -- but I don't recall doing 7 MR. : You're not sure? 8 it. 8 MR. It's been too long. 9 MR. : Okay. 9 MR. : You didn't. 10 MR. I do not recall 10 MR. Yeah. 11 doing that. 11 MR. : You signed it. 12 MR. : Do you know if you 12 MR. I didn't. 13 conducted the count at 4:00 p.m.? 13 MR. But you don't know if -. 14 MR. : No. 14 All right. So, now you can go into those 15 MR. : So, does that mean you 15 questions. 16 did not conduct the 4:00 p.m. count? 16 MR. : So. 17 MR. : I did not. Because, like, I 17 MR. : How many people are needed to 18 was -. That's why I'm at the bottom. I was, 18 do the count? 19 like, I filled it out or whatever. All right. 19 MR. At least two. 20 We going to do this. We going to do that. And 20 MR. : At least two? 21 I was running, too. I was ripping and running 21 MR. Mm-hmm. 22 or not. iiiiiiiiiithat they did. So. 22 MR. : And you said that you don't 23 MR. : All right. But you 23 know if the did, but since you -- 24 didn't conduct the 4:00 p.m. count? 24 MR. : Yeah. I was -- 25 MR. : No. 25 MR. : -- signed it, it -- EFTA00115867 77 78 1 MR. : -- it was an assumption. So, 1 there. So, if the base count was 76, that's 2 that was m fault. So, I take that. 2 because E stein was at his legal visit. 3 MR. : Okay. So, technically, it 3 MR. : Okay. I'm going to -. Let's 4 should have been you and whoever else -- 4 start off with the 4:00 p.m. count. MR. Mm-hmm. S MR. : (Indiscernible 6 MR. -- signed off on it, should 6 *00:48:03). This stuff. That's all. All have done -- 7 there. 8 MR. Mm-hmm. 8 MR. : Okay. I'm oin to show ou 9 MR. -- but you don't recall doing 9 a memo. It's an email from 10 the count? 10 to IIII , and it's regarding to a shot. 11 MR. Hmm-mm. 11 Right before inmate, hmm, Leonardo Fernandez, 12 MR. : No, not to recall. He 12 do you recall Fernandez - inmate Fernandez - 13 said he did not do the recall. 13 being in the SHU that day? 14 MR. : Yeah. 14 MR. I don't even know who that is. 15 MR. : Yeah. 15 MR. : He was an inmate in the SHU. 16 MR. : He just said -- 16 And if you can read the -. 17 MR. That he did not. 17 MR. : You can just it for him. 18 MR. -- he doesn't know if the 18 You don't have to ask. 19 other two did. 19 MR. : Yeah. Well, yeah. This is 20 MR. : Okay. Now, do you know if 20 filled out by . It's in regards to 21 that number was accurate? 21 Leonardo Fernandez. The incident date is 22 MR. : If - I'm going to find out 22 8/9/2019. It's at 1:40 p.m. 23 now. I'm sor . 23 MR. Mm-hmm. 24 MR. : Yeah. No problem. 24 MR. : "On August 9th, 2019, at 25 MR. : So, that number was accurate 25 approximately 1:40 p.m., I, SOS , while 79 80 1 assigned as a Special Housing Unit officer, I 1 MR. Mm-hmm. And wait, the time 2 proceeded to enter the Nine South visiting 2 for this one was -? 3 room. As I walked towards the door, I observed 3 MR. : That just states the daily 4 through the visiting room door, inmate 4 sensitive information. So, this is -- 5 Fernandez, register number 86824-054, attempt MR. 'I'll' Okay. 6 to grab an unknown item from his visitor. Once 6 MR. : -- this is at 3:15 p.m. So, 7 inmate Fernandez reached to grab the item, I 7 I'm going to show you the midnight sheet count. 8 called the door, and called for a lieutenant. 8 MR. Mm-hmm. 9 Once I was able to enter the visiting room, I 9 MR. : From August 10th. This is 10 gave inmate Fernandez a direct order to walk 10 August 10th. Inmate Fernandez is - again - it 11 the visiting room, walk off the visiting room, 11 states there. If you notice, 12:35 a.m., it 12 to conduct a visual search. Inmate Fernandez 12 was corrected. Inmate Fernandez was removed 13 complied, and a visual search was conducted. 13 from the SHU at 3:15 p.m., and was never keyed 14 The operations lieutenant was contacted, and 14 out of the SHU. 15 inmate Fernandez was removed from the unit." 15 MR. : Show him the quarterly 16 MR. III" Mm-hmm. 16 assignment roster. 17 MR. : Now, this is the lieutenant 17 MR. : Yeah. 18 logs for that day. This is for August 9th. 18 MR. : That's all in order. 19 This is da watch. 19 Here it is. 20 MR. : Mm-hmm. 20 MR. : So, whaiiiiiiened was when 21 MR. : The lieutenant log states, 21 the midnight lieutenant, came 22 "Inmate Fernandez, 86824054, on dry cell with 23 staff watch in R80." If you look down here, 24 3:15 p.m., inmate Fernandez was placed on dry 22 on -- 23 24 MR. MR. a : Mm-hmm. -- she realized there was a - 25 cell. 25 EFTA00115868 81 82 1 MR. A discrepancy. 1 MR. : Yeah. 2 MR. -- a discrepancy. 2 MR. : Look at this. 3 MR. : Mm-hmm. 3 MR. Okay. 4 MR. : So, she went in, she checked 4 MR. So, it should have been 74. S it, and she corrected it at 12:35. If you S MR. : So, now, you understand that 6 paid, if you look at the inmate history, of the 6 it was 74 inmates. 7 quarters for Fernandez, he was assigned to the 7 MR. Yes. 8 SHU -- 8 MR. : Is that count accurate for 9 MR. : Mm-hmm. 9 4:00 p.m.? 10 MR. -- from August 2nd, at -- 10 MR. 11 MR. 14:33. 11 MR. So, was the count 12 MR. -- 14:33. And he was keyed 12 conducted? 13 out on -- 13 MR. No. 14 MR. On the 10th. 14 MR. No? 15 MR. -- August 10th. At 12:35 15 MR. No. 16 a.m. 16 MR. : Sorry, I didn't hear what 17 MR. : Mm-hmm. 17 you -. Did ou say -? 18 MR. : Now, if you -. Well, if he 18 MR. No. 19 was out of the SHU. Now, the day started off 19 MR. : No. All right. So, do 20 with 77 inmates. 20 you know now that the count was not conducted? 21 MR. : Mm-hmm. 21 MR. : Yes. 22 MR. : And let's remember, don't 22 MR. : Okay. Great. 23 23 MR. : Can you - same thing as 24 MR. : So, that should have been 74. 24 before - can you initial these documents to say 25 MR. : -- don't look at this. 25 that these are the ones we showed you. 83 84 1 MR. : What's today's date again? 1 MR. : Yes. 2 Seventh? 2 MR. : Good. Thank you. 3 MR. : 8/S. 3 MR. : This is the memo. Could you 4 MR. 8/5. 4 just initial and date this for me? Do you have 5 MR. So, like you said, you 5 anything else on that? 6 just took the number off the master list and 6 MR. No. 7 filled that in? 7 MR. : On that count. Sorry. This 8 MR. : Yeah. 8 is the 5:00 p.m. count. Just initial the -. 9 MR. : So. 9 Initial and date the 5:00 p.m. count here. 10 MR. Yeah. 10 MR. • 4:00 p.m. 11 MR. : And when you say master 11 MR. : I mean 4:00 p.m. I keep 12 list, I mean actually, you called it something 12 reading the bottom. 13 different. 13 MR. : It's all good. 14 MR. : The locator. 14 MR. : Move on? 15 MR. : The inmate locator. 15 MR. : Yup. 16 Okay. 16 MR. : All right. " was asked 17 MR. This one, too. 17 several questions abouiliiiiiin, and 18 MR. : So, does that refresh 18 specifically if guard advised about 19 your memor now, though -- 19 Epstein needing a cell mate, to which 20 MR. : Mm-hmm. 20 responded 'No.'" Do you -? 21 MR. : -- that they didn't 21 MR. Read that again. 22 provide you a number, you just filled that in 22 MR. • " was asked several 23 off of that? 23 questions about Epstein, and specifically, if 24 MR. : Mm-hmm. 24 guard advised about Epstein needing a 25 MR. : Yes? 25 cell mate, to which responded, 'No.'" EFTA00115869 85 86 1 MR. : Yeah. I didn't get that. 1 happened because, like, because I remember, 2 Okay. I thought you said I said that Epstein 2 when I put him in the cell, I was, like, where 3 didn't need -- 3 the hell iiiiiiiiiicking cell mate at? 4 MR. : No. 4 MR. : So, you actually -. When 5 MR. -- an inmate. Yeah. I'm, 5 you put E stein back from the shower, you mean? 6 like, nah, that -. I didn't have a -. I don't 6 MR. : Yeah. 7 remember having a conversation with 7 MR. : You asked him where his - 8 about him telling me that Epstein needed a cell 8 9 mate or an thing like that. No. 9 MR. : I asked where, you know, where 10 MR. : What -? 10 is your cellee? Or whatever. So, he said, 11 MR. : But he was supposed to have a 11 like, he got released. So, I don't -. Like, I 12 cell mate. 12 don't know if he actually did get released or 13 MR. : He was supposed to have a 13 not, or whatever, but that was the question, 14 cell mate? 14 like, but we don't have anybody else to put him 15 MR. : He had a cell mate. 15 with. I don't remember who I spoke to that 16 MR. : So, why was he supposed to 16 night or whatever. But I asked that question, 17 have a cell mate? 17 like, there's no cell mate in there with this 18 MR. : Well, no, I'm saying he had a 18 guy. 19 cell mate. It was the little, short dude. 19 MR. : So, you asked someone? 20 That was his cell mate. I think his cell mate 20 MR. : I asked someone, but who it 21 got released that day. 21 was, I don't remember who it was. 22 MR. : How do you know the cell mate 22 MR. : Would it have been a 23 got released that day? 23 lieutenant? 24 MR. : Oh, just word of mouth, 24 MR. : It would have been a 25 because, like, I'm trying to remember what 25 lieutenant. But my question -. But, like, 87 88 1 with that, he's supposed to have. But you 1 schedule -- 2 can't put him with anybody. 2 MR. Mm-hmm. 3 MR. : No, but you know -- 3 MR. : -- schedule, to - on the 4 MR. , some -. 4 roster. 5 MR. • -- you notified a MR. This is all -- 6 lieutenant? 6 MR. : And I'm talking about MR. : Yeah. So, somebody has to 7 what time -- 8 tell me who they want me to put in there with 8 MR. • (Indiscernible *00:55:12). 9 him. Because if you tell me to put somebody in 9 MR. • -- it would be, because I 10 there, aniiiiiiiiiison beats him up. 10 mean, I think there's a shift change -- 11 MR. : All right. So, if you 11 MR. : Yeah. There's a shift change 12 put him in at, you said, 9:30. Correct? Was 12 13 that when_122 Lre talking about? 13 MR. • -- back then, at 10:00 -- 14 MR. IIIII: Yeah. When I - yeah - after 14 MR. -- and then -- 15 the shower. After he had his little phone call 15 MR. : -- 10:00 p.m. is when 16 and I put him back or whatever. Yeah, I asked, 16 there's that shift change. 17 like, does anybody want me to put him in there 17 MR. : The lieutenant shift changes. 18 with -. 18 I don't even know what time it was. 19 MR. : So, you're acting like 19 (Indiscernible *00:55:21) 20 you're talking on the phone. So, did you get 20 MR. • They show it was two 21 on the phone with someone? 21 hours prior to -- 22 MR. : Yeah. I got on the phone with 22 MR. Indiscernible *00:55:23). 23 someone, and I, like, who it was at that time, 23 MR. : -- to what the schedule 24 I don't remember. 24 said back then. So, the Ops Lieutenant would 25 MR. : So, this, can you check the 25 have been relieved at 10:00 p.m., and a new Ops EFTA00115870 89 90 1 Lieutenant would have come back. So, if that 1 MR. : Mm-hmm. 2 rings a bell. 2 MR. -- officer who would have 3 MR. : Yeah. 3 come in the ni ht before, at 10:00 p.m., and 4 MR. : I think it would have 4 relieved 5 been either -- 5 MR. : Over here, actually, it 6 MR. Because I know -- 6 states, there's two possible lieutenants, 7 MR. • -- it would have -. 7 right? There's -- 8 MR. -- well, I know this. I know 8 MR. 9 it wasn't -- 9 MR. was the acting -- 10 MR. : Here. 10 MR. -- who was that, until 10:00 11 MR. -- I know I didn't speak to 11 p.m.? 12 Lieutenant 12 MR. -- Activities until 10:00 13 MR. All right. So, this is 13 p.m. 14 MR. : You know you didn't speak 14 MR. : Mm-hmm. 15 to -. So, this would -- 15 MR. And then, there was 16 MR. -- no, this is -. 16 MR. 17 MR. -- this was the 10th. 17 MR. That was there from -- 18 So, replaced . So, it would 18 MR. Until midnight. 19 have been either - I'm assuming - it would have 19 MR. -- yeah, until midnight. So, 20 been either or . Now, what -- 20 this conversation, when you went to Epstein's 21 MR. So, it had to -- 21 cell, around what time do you think? You - 22 MR. • -- what I'm showing you 22 based on that memo - you took him out around 23 right now is the daily assignment roster for 23 9:30. 24 Saturda , Au ust 10th, where it says that 24 MR. : Put him in -- 25 was the morning watch -- 25 MR. : Put him in. 91 92 1 MR. : -- at 9:30. 1 MR. : Okay. So, you 2 MR. : Put him. You took him out of 2 specificall recall -- 3 the -- 3 MR. Asking. 4 MR. Yeah, yeah, yeah. 4 MR. -- and that you asked 5 MR. • -- the showers. 5 someone? 6 MR. The showers. 6 MR. : I asked someone. 7 MR. : And then, brought him over to 7 MR. : And do you recall that it 8 the cell. 8 was a lieutenant? 9 MR. Mm-hmm. 9 MR. : Yeah. It had to be. Because 10 MR. : So, let's say 9:30 onwards, 10 I called the lieutenant's office. 11 who wouldiiiiiiiiiii(Indiscernible *00:56:29)? 11 MR. : You called. So, you know 12 MR. : Well, no, no, no. Let's 12 that you called the lieutenant's office and 13 clarify that, though. Is it before the shower, 13 said -- 14 when he was brought back to the SHU, or was it 14 MR. : Mm-hmm. Like, yeah, this -- 15 after the shower that you noticed that there 15 MR. : -- he doesn't have a cell 16 wasn't a -- 16 mate? 17 MR. : After the shower. 17 MR. : -- there's no cell mate here. 18 MR. : -- so, it was definitely 18 What do you want me to do? Or whatever. What 19 after the shower, and after the phone call? 19 actually happened after that, I don't even 20 MR. : Yeah. 20 remember because I never even gave it a second 21 MR. : Okay. And that's when 21 thought, after the fact. 22 you (Indiscernible *00:56:43) -. 22 MR. : All right. So, after you 23 MR. : And that's - and it's locking 23 called, though, do you remember how that person 24 time, so now, at that time, once you put him 24 responded? 25 back, there is no more movement. 25 MR. : Nah. I never even thought EFTA00115871 93 94 1 about it again. I never thought about it again 1 necessarily have to be a lieutenant in the 2 until now. Now, I'm trying to rack my brain to 2 lieutenant's office. 3 remember. 3 MR. : Not all the time, because 4 MR. : Do you remember if it was 4 things happen. Sometimes the lieutenant may S a man or a woman? S call you, hey, I need you to go to this unit, MR. : I believe it was a man. But I 6 do X, Y, and Z. Now they're on the phone or 7 whatever. Grab that phone for me real quick. MR. : You believe it was a man. 8 It happens, but you know, you just relay the 9 MR. r. I believe it was a man, but 9 messages and what have you. 10 I don't remember. I really don't. 10 MR. : Okay. All right. 11 MR. : Okay. Because if it was 11 MR. : And you said that could be 12 a man, it would have had to been 12 the internal? 13 MR. : It would have been 13 MR. It could be. Is it? I don't 14 MR. : Right? 14 know. But I'm just saying, I know that I asked 15 MR. Yeah. It would have been 15 that question. Who I did ask that question to, 16 16 I don't know at this time. 17 MR. : And you know it wasn't -- 17 MR. : Okay. 18 MR. : Bec 18 MR. I don't remember. 19 MR. : 19 MR. : So, just walk us through 20 MR. -- but Ilirr!!!!ro, that 20 what questions you asked and what response were 21 when - if I'm working internally, and then, 21 you given. 22 like, I have to speak to a lieutenant, 22 MR. : Yeah. I know I said, hey, 23 sometimes the lieutenant is busy. I may pick 23 this dude ain't got no cellee. I did say that. 24 up the phone and I'm not a lieutenant. 24 This dude ain't got no cellee or whatever. And 25 MR. : Okay. So, it doesn't 25 after that, what actual response I got, I don't 95 96 1 know, because I was so busy that day, that I'm 1 you made the phone call, or when, first of all, 2 just, like -- 2 the phone call, do you remember the response 3 MR. : This would have been -- 3 that you were given? When you said -- 4 MR. I got enough. 4 MR. IIIIIiiiiidon't know. S MR. : -- this would have been S MR. : -- why doesn't this guy at the vely_Lid of your shift? have a cellee? Did you -? 7 MR. IIIII: This would have been at the 7 MR. IIIIIiiiiidon't remember. 8 very end of m shift. 8 MR. : Did they say that they 9 MR. : So, would it have been 9 would look into it, that they would check on 10 before you went up and checked on him, at that 10 it? 11 11 MR. : Probably, but I really don't 12 MR. : That would have been -- 12 remember because I'm, like, after you get 13 MR. : -- next round? 13 frustrated, all right, I got this to do, I got 14 MR. : -- yeah, that would have been 14 that to do and then, you just -. 15 15 MR. : Okay. Did you notify 16 MR. : Or after? 16 and that he doesn't have a cell 17 MR. r that would have been 17 mate? 18 before, and then, I checked on him again, 18 MR. Well, they knew, but -- 19 before I left. So, like, when I noticed it, 19 MR. : They knew he didn't have 20 put him in, and I noticed that, made the phone 20 a cell mate? 21 call. Then, before I leave, I check on him 21 MR. -- yeah, because they were up 22 again, and tell -- 22 there -- 23 MR. : Okay. 23 MR. : They know? 24 MR. -- hey, watch this guy. 24 MR. E yeah. 25 MR. : Okay. Did you - after 25 MR. : And did they know that he EFTA00115872 97 98 1 was required to have a cell mate? 1 After -- 2 MR. : Required. I don't know if 2 MR. Shower? 3 they knew that he was required to have a cell 3 MR. : -- yeah, after the shower. 4 mate. ThAti_I_LTIt know. 4 That this conversation between you, MR. IIIIIIIIII: But everybody that comes MR. : This was after the shower. 6 off -. He was in suicide watch, previously. 6 MR. -- took place. 7 Correct? 7 MR. Well, after the shower is 8 MR. : Right. 8 when you called, but what you're saying is 9 MR. : And every inmate that 9 that, at - or are you saying that, after the 10 comes off of suicide watch -- 10 shower, after the phone call -- 11 MR. Suicide watch. Should have a 11 MR. : Right. 12 cell mate. 12 MR. : -- so, not after the 13 MR. : So, based upon that, they 13 shower, but after the phone call in the shower, 14 knew he was required to have a cell mate. 14 is that when you had the conversation with IIII 15 Correct? 15 and 16 MR. Yeah, based off of that, they 16 MR. : Yeah. 17 would know. 17 MR. So, you think at that 18 MR. : Okay. And was that a 18 point -- 19 discussion that you had with anyone in there, 19 MR. : Because that's when I, like, 20 that day, about, hey, where is his cell mate? 20 oh, shit, the dude ain't got no cell mate. 21 MR. : I think we did ask that 21 MR. : And you would have -- 22 question amongst ourselves, too, like, this 22 MR. : Sorry. Excuse my language. 23 dude is supposed to have a cell mate. I think 23 MR. : -- and you would have 24 we did. 24 conversed, saying, like, hey, he doesn't have a 25 MR. : Is this before or after? 25 cell mate right now? 99 100 1 MR. : Yeah. So, that's definitely 1 And it waiiiiiiiillago now. 2 the discussion that -. That would have 2 MR. : Was there any 3 happened after I took him out of the shower and 3 conversation about, like, hey, we need to 4 put him in his cell, and realized there was no 4 notify somebody to get him a cell mate? 5 cell mate in there. That would have been the 5 MR. : Probably was, but I know I 6 discussion afterwards. 6 made a phone call to someone, like, hey, what 7 MR. : And ou do remember 7 do you want me to do with this guy? He ain't 8 talking with both and IIII, saying he 8 got no cellee. I know I made a phone call to 9 doesn't have a cell mate? 9 someone. Who it was, at this point, I don't 10 MR. : Yup. Briefly, though. There 10 remember. 11 wasn't, like. a long, drawn-out -. 11 MR. : And that -. 12 MR. : Sure. Do you remember 12 MR. I wish they would have asked 13 what their responses were? 13 me that question earlier because I probably 14 MR. : I think it was just something, 14 would have remembered then. 15 like, yeah, we're just telling each other 15 MR. : Right. So, and that's, 16 what's goin on. And continue business. 16 like, under oath, this is, like, if you were on 17 MR. : Was there anything talked 17 the stand, literally in front of a judge -- 18 about, like where is he? 18 MR. : Mm-hmm. 19 MR. IIIII: Yeah, and that's when we found 19 MR. : -- you swear under oath 20 out, like, this guy must be released or 20 that you made a phone call and notified 21 whatever. So, there was a conversation about 21 someone? 22 that. But who actually said, oh, this dude got 22 MR. : I notified someone. Who it 23 released, or whatever, I don't remember. 23 was, I don't know. 24 MR. : Okay. 24 MR. : Okay. So, if we checked 25 MR. Everything was moving so fast. 25 the, like, the lines and the recordings, we'll EFTA00115873 101 102 1 be able to find -- 1 that day. So, here, I'm going to show you a 2 MR. : You should be able to find 2 document, and this is - again - that 3 that, yes. 3 lieutenant's log, saying that, at 8:38 a.m., 4 MR. : -- okay. And then, 4 Reyes was pre-removed. And do you know that, S again, that would be, like, a penalty and S when you're pre-removed, that means you're 6 perjury of law, like, you know -- 6 released from the MCC. Correct? 7 MR. : Mm-hmm. 7 MR. : Mm-hmm. 8 MR. : -- you could get - you 8 MR. : Do you know that? 9 can literally get charged if you're lying to us 9 MR. : That, well, yeah. It's a 10 because we're federal agents and you're under 10 So, could I see that? 11 oath. 11 MR. : Yeah. 12 MR. : Mm-hmm. 12 MR. So. 13 MR. : So, you're positive about 13 MR. : And here is the 38 to go 14 that statement, that you called someone and 14 along with that, and the daily log. 15 notified them around 9:30 at night? 15 MR. : Okay. 16 MR. : I believe so. But if -. 16 MR. : Which shows that he was 17 Because I spoke to people about this. I know I 17 pre-removed at 8:38. 18 spoke to eo le about this. 18 MR. : A.m. 19 MR. : So, yeah. Just remember, 19 MR. : A.m. 20 any -. We're just going to shut up for a 20 MR. Okay. 21 second, and let you think about who did you 21 MR. : So, he left. He left the 22 speak with and what conversations were had. 22 SHU, I'm assuming, before then. That's when he 23 What was stated? 23 was keyed out. 24 MR. : Mm-hmm. 24 MR. : Mm-hmm. 25 MR. : From the beginning of 25 MR. : By R&D. Correct? 103 104 1 MR. Mm-hmm. 1 believe that you would have received this 2 MR. : And then, is there -. 2 email, but I'm just showing you. 3 Did we -? No, we didn't print out any of those 3 MR. : Mm-hmm. 4 other documents. So, he was gone from the MCC 4 MR. : You can say if you S by 8:00, at least 8:30 a.m. S remember it. This is -. Did you ever see one 6 MR. : Okay. 6 of these? This is a prisoner's schedule. 7 MR. : So, you started at 2:00 7 MR. : No. 8 p.m. What conversations can you remember that 8 MR. : The Marshal Service. So, 9 you had, regarding Reyes being gone from the 9 the Reyes right here, it shows that he was 10 institution? 10 gone, transferred within - per the judge - from 11 MR. : I don't. I remember finding 11 the MCC to GO. Do you know what GEO is? 12 out that Reyes was gone when I put Epstein back 12 MR. : I've heard that term before, 13 in his cell. That's when I remember that he 13 but -. 14 was gone. 14 MR. : So, GEO is a -- 15 MR. : So, you -. 15 MR. : Contract. 16 MR. IIIII!ii!imean, that's when I realized 16 MR. : -- contract -- 17 that he was gone because I'm, like, there's 17 MR. : Yeah. (Indiscernible 18 supposed to be two people in here 18 *01:04:23 19 MR. : So, prior to that time, 19 MR. : -- which was going around 20 you didn't know, at all, that Reyes was gone? 20 here. 21 MR. : Yeah, because I'm thinking 21 MR. : Okay. 22 about it to m self. as we walk -. 22 MR. : This would have been sent 23 MR. : Sorry. He's giving me 23 to all these people in custody, from R&D, as 24 documents to show you what happened to him. 24 well as to all the lieutenants. 2S So, this is from the Marshal Service. I don't 25 N.R. : Okay. EFTA00115874 105 106 1 MR. : So, based upon this, they 1 MR. : I don't remember seeing that 2 would have generated what's called, I think, a 2 call out list. I do not. 3 call out list. Do you know that? 3 MR. : And in general, would the 4 MR. : I know what a call out list 4 call out list be maintained in the SHU, though? S is. Yes. MR. : No. The call out list is 6 MR. : And then, we're of the 6 basically before R&D leaves for the night. 7 understanding, based upon this information, They print out the call out sheets for the next 8 next to Reyes name would have been WAR. Do you 8 day, and over the course of the morning shift, 9 know what that means? 9 internal, when they give out the daily rosters, 10 MR. : Yes. 10 will give out the call out sheets to every 11 MR. : What does that mean? 11 unit. 12 MR. : Like, I mean, offhand, I don't 12 MR. : Mm-hmm. 13 know what the actual acronym means, but it does 13 MR. : For the following day. For 14 mean that somebody is getting removed from the 14 the next'rig, 15 building, whether they're being released, sent 15 MR. : And then, is that call 16 to another institution, what have you. 16 out list, though, like, for instance, the call 17 MR. : All right. So, that 17 out list of the SHU, was that maintained in the 18 would have -. It means, "With All Belongings." 18 SHU at all, when they (Indiscernible 19 And it means that they take all their stuff 19 *01:05:3422___ 20 because the 're leaving. 20 MR. IIIII: Yeah. Once you have it in the 21 MR. : Mm-hmm. 21 SHU or whatever, usually, they'll have it on 22 MR. : Do you remember, that 22 the desk with the rest of the paperwork. So, 23 date, seeing that call out list? Would that be 23 you know what you're looking at. If you've got 24 maintained in the SHU for the (Indiscernible 24 to get soiiiiiiiiiidy. 25 *01:05:06)? 25 MR. : Okay. So -- 107 108 1 MR. : Yeah. 1 another -. 2 MR. : -- so, is that something 2 MR. • Wouldn't that all be 3 that they kee in the SHU all day long? 3 listed on the call -- 4 MR. IIIII: Yeah. Once you receive it. 4 MR. : Yeah. 5 All for the morning shift, because usually, MR. • -- list, though? 6 morning shift, depending on your internal, you 6 MR. It would. Yeah, it would. 7 might get that paperwork probably about 3:00 or 7 MR. : So, point being is if, 8 something. You know, after you - as you're 8 like, if you're doing counts at 4:00 p.m., you 9 conducting counts. So, you conduct counts, and 9 have that call list to be able to say, oh, 10 they come through and they hand you your roster 10 shit, this guy is at court, he's not back yet. 11 for the day. The call out sheets, the separate 11 I need to find out where he is. Is that what 12 rosters. 12 happens? 13 MR. : And is that maintained, 13 MR. : Mm-hmm. Yeah. That's what's 14 though -- 14 supposed Ig]mal Yes. 15 MR. : Yes. 15 MR. So, the questions that 16 MR. -- throughout the day? 16 all of that was, do you remember seeing that 17 So, that, like -- 17 call out list on August 9, 2019? 18 MR. : It's supposed to be. 18 MR. : I don't remember seeing it. 19 MR. : -- for instance -. Okay. 19 MR. • No? 20 So, if somebody goes to court, you know, on 20 MR. No. 21 that list, it says this guy is court, it says 21 MR. : But would it have been 22 this guy is WAB, it says, you know, so that you 22 there? 23 know where inmates are? 23 MR. : It should have been there, but 24 MR. : Well, R&D will have the -. It 24 I don't remember seeing it. 25 will be a court roster for R&D. And it's 25 MR. • Okay. EFTA00115875 109 110 1 MR. : Everybody waves differently. 1 higher than me. Because I can't make that 2 So, I may put my paperwork on the clipboard. 2 decision. 3 Somebody else may like to have three stacks of 3 MR. Sure. And you think it 4 paper over here. 4 was a man? You don't think it was MR. : Okay. But what you're MR. : I think it was - 6 saying is that you did know, on August 9th, 6 MR. Or -? 7 that Reyes was gone, and he was Epstein's cell 7 MR. • -- I'm pretty sure it was a 8 mate, and Epstein was without a cell mate. But 8 male. I think it was a man. But being that it 9 you're saying you didn't know it until 9:30 9 was so long ago, I can't remember exactly what 10 p.m.? 10 I said on a brief phone call -- 11 MR. : Yeah. 11 MR. • Sure. 12 MR. : And at that point, you 12 MR. -- you know -- 13 did call someone, in the lieutenant's office? 13 MR. : I understand. Yeah. I 14 MR. : Yeah. 14 mean, we're Yeah -- 15 MR. : So, you definitely know 15 MR. -- I'm just being honest with 16 it was the lieutenant's office -- 16 you. 17 MR. : I know. 17 MR. • -- we're two years later. 18 MR. -- that you called? 18 I got you. 19 MR. : I called someone. So, like, 19 MR. : You know? 20 let me rephrase and put it like this. That I 20 MR. : And so -. 21 noticed it. I had discussions with, you know, 21 MR. : And honestly, I thought this 22 (Indiscernible *01:07:29), I said something 22 was over. So I was, like -- 23 about it to them, and I called someone. Who I 23 MR. : Right. Yeah. No. This 24 spoke to, I do not remember. But I know I 24 is where -. That's why we're back, coming back 25 called someone. And it had to be somebody 25 to people to try to, like -. Part of the 111 112 1 reason why we're reading this to you is to, 1 definitel assed that information onto you -- 2 one) make sure that you -- 2 MR. : You got a -- 3 MR. : That it's accurate. 3 MR. : -- and he's got this 4 MR. : -- it's accurate, but 4 memo. 5 also to refresh your memory. This is what you 5 MR. : Mm-hmm. 6 stated to these people, is that accurate, and - 6 MR. : That he also did. Do you 7 again - to fill in some of these blanks. Now, 7 believe he's lying about it? 8 we have a memo that was drafted on August 12th, 8 MR. : If he did, you might want to 9 2019. Let's see if it was - it says United 9 ask about that one because I do not 10 States government, Federal Bureau of Prisons 10 recall him s eakin to me about this one. 11 memo. And it says, past information from 11 MR. : Okay. 12 Special Housing Unit. It says, "On Friday, 12 MR. : I don't necessarily want to 13 August 9th, 2019, at approximately 1:50 p.m., 13 call anyone a liar, per se, but I don't 14 I, SOS , assed on to oncoming staff 14 remember him spealiimso me about this. So, 15 member, Officer and present staff, SOS 15 maybe he spoke to and maybe I was 16 and Officer , that inmate Reyes 16 standing there and he thought I heard him. 17 was going WAB, and possibly may return, also 17 MR. : Okay. 18 that inmate Epstein will be needing a cell mate 18 MR. : But that's my assumption, but 19 upon arrival from his attorney visit." Do you 19 I do not remember having this conversation with 20 know if -? 20 him at all. 21 MR. : I don't remember having that 21 MR. : All right. So, if he's 22 conversation with 22 saying, you know, was standing ther2s_i_ 23 MR. : Do you remember that that 23 relayed the information specifically to IIIII, 24 conversation had, or do you believe that he's 24 saying, hey, what you call, it's WAB, Epstein 25 lying to us? If he swore under oath that he 25 is going to need a new cell mate. You do not EFTA00115876 113 114 1 recall that conversation? 1 stuff is packed up or whatever, and then, 2 MR. : I don't recall that 2 something happens, and then, they can't go -. 3 conversation. 3 They can't leave. Like, but that's usually if 4 MR. : Now, what is your opinion 4 they're going to another institution or S of the fact that, if an inmate is WAB, that S something. Now, if this dude actually got 6 means that he's not coming home -- 6 released or whatever, I don't see why - any 7 MR. : Yeah. 7 reason. Unless the judge put a hold on him. 8 MR. : -- right? What is your 8 MR. : Well, he didn't get 9 opinion of the fact that he said, possibly may 9 released. Like I showed you. He got 10 not return? Why would he say - if someone is 10 transferred. 11 WAB - why would he say possibly may not return? 11 MR. : Yeah. So, yeah. So, I don't 12 MR. : I don't know. 12 see, you know, like, unless the judge 13 MR. : Because your 13 miraculously put a hold on you or something 14 understandin was, if someone was WAB -- 14 like thatj_j_42nLI_know why he said possibly. 15 MR. : If it was WAB -- 15 MR. So, I guess my question 16 MR. -- you're not -. 16 on that would be, then, if he's at least by 17 MR. -- he's supposed to be gone. 17 8:38 a.m., WAB, gone from the SHU, should 18 MR. : He was gone. Correct? 18 someone have -- 19 MR. But - okay, so, with that -- 19 MR. Yes. 20 MR. : So, if -. 20 MR. -- replaced him 21 MR. -- if he says possibly may 21 beforehand? 22 return or whatever, because this has happened, 22 MR. : Yes. Replaced him and, yeah, 23 usually, I've seen it before with other 23 somebody should have -. Like, because during 24 inmates. You see somebody that says if they're 24 the day shift or whatever, this dude leaves, he 25 WAB, they're supposed to leave this date, their 25 goes to WAB or whatever, and you know that it's 11s 116 1 Epstein is in the cell, because I'm assuming 1 authority to do that. Because if I was to -- 2 with how it happened, I'm assuming he goes WAB, 2 MR. • So, who has the 3 Epstein goes to a legal visit, now your day is 3 authority? 4 going on and everything like that. And it's 4 MR. : -- if I was to make that S just esca ed ever body. 5 decision, and something happened to him, now 6 MR. : Mm-hmm. 6 I'm screwed. 7 MR. : That's what I'm thinking 7 MR. : So, who should have 8 happened. But yeah, he should have been 8 placed him with a cell mate? That's place 9 replaced durin that shift. 9 Epstein with a new cell mate. 10 MR. : Mm-hmm. 10 MR. : It would have been one of us 11 MR. : But if you don't have the 11 to probably put the inmate in that cell. But 12 numbers, that's another question, that I'll 12 that determination would either come from the 13 ask. If you don't have the numbers in the SHU, 13 operations lieutenant, the SHU lieutenant, or 14 if you have, like, an odd number, and you can't 14 the captain. 15 put anybody with him. What are you going to 15 MR. : Okay. 16 do? 16 MR. anybody above that. 17 MR. : Or are you aware that 17 MR. : Sure. 18 Epstein's cell mates were all vetted at the 18 MR. : But that's where the decision 19 highest level? 19 would come from. They'll probably just tell 20 MR. : No. 20 me, like, he Iiiiiiiiiiute. 21 MR. : So, in your opinion, if 21 MR. : So, in your opinion, 22 you knew that Epstein was required to have a 22 based upon the information that we have, with 23 cell mate, could have you just placed a cell 23 him going WAB, should the activities, ops, or a 24 mate with him? 24 captain have been notified, and those people 25 MR. : No. I don't have that 25 should have ensured that Epstein was -? EFTA00115877 117 118 1 MR. : Yes. Because if - like, all 1 MR. : Depending on how they looking 2 right, after all the stuff that we've seen here 2 at it, like, because - like I said before - if 3 - if I was to, like, let's just say I was to 3 he's WAB and, like, maybe the bus got cancelled 4 put somebody in that cell, and something 4 or whatever, and then, somebody would have to S happened. Now I made the wrong decision, and S come back. If you're thinking about it that 6 then, the next question is going to be, well, 6 way, then yes. But if he was gone at 8:00 7 why didn't ou ask questions? 7 something in the morning, then he ain't never 8 MR. : Mm-hmm. 8 coming back. 9 MR. : So, I would not put somebody 9 MR. : At 2:00 p.m., he's still 10 in there without somebody giving me the green 10 not back, wouldn't they know by then if that 11 light to do so. 11 was -- 12 MR. : Now, if - was 12 MR. That's what I -- 13 the OIC back then? 13 MR. -- truly WAB? 14 MR. : I think so. 14 MR. • -- that's what I would think. 15 MR. : All right. So -- 15 MR. : Okay. But you do not 16 MR. For the day shift. 16 recall him s ecifically saying that to you? 17 MR. : -- so, is the 17 MR. : Hmm-mm. 18 OIC. If him, the activities lieutenant, and 18 MR. : So, you believe, the 19 the ops lieutenant, all for that day shift are 19 first time that you - you did know, on August 20 saying, well, we didn't know if Reyes was going 20 9th - but you believe the first time that you 21 to come back or not, so we thought it was 21 knew was at 9:30 p.m. 22 premature to place a new cell mate in there 22 MR. : That's the first time I think 23 with him. Is that a legit excuse, do you 23 I knew, because it was too much running around. 24 think, or a reason, if the person is listed 24 I don't not remember this conversation at all. 25 with WAB next to their name? 25 MR. : Okay. And that's 119 120 1 because, once you got there, you were just 1 going. And then, you know, you just keep going 2 running? 2 or whatever. So, like, it should have dawned 3 MR. : I was running, hopping and 3 on me then, but I'm thinking about this guy 4 popping the whole time. 4 over here, that may have, you know, that had S MR. : Okay. S the noose around him, and he wants to play that 6 MR. : Pretty much. I'm sweating. 6 game. And then, you got another inmate on 7 Everythin . 7 another tier, doing some other crazy nonsense. 8 MR. : Okay. 8 There was just a lot of moving pieces that day. 9 MR. : But we were all tired that 9 So, even in my movement around or whatever, 10 day. 10 like, it missed - it escaped it - it missed me. 11 MR. : Okay. 11 MR. : Yeah. And that was what 12 MR. : I know you didn't know until 12 I was going to go to, after that, is the fact 13 9:30 p.m. When do you think would have been 13 that, would this have been the only - this 14 the first time you should have caught up to the 14 mandatory rounds must be conducted every 30 15 fact thatjt12s was not there? 15 minutes on Epstein, as per God - would that 16 MR. IIIII: I was doing rounds, because in 16 have been the only orange card that was up 17 my mind, because I'm thinking about it, like, 17 there? Saying to make sure that Epstein is your 18 like how Epstein is the priority. So, if I'm 18 priority in the SHU right now? 19 working out ranges, and I'm talking to inmates 19 MR. : It shouldn't have been. Like, 20 here and there, and I had two other inmates on 20 I don't remember if there was anything on his 21 that tier where Epstein was, that wanted to 21 door, or anything like that, or whatever. But 22 play the suicide game, you know, as I walked 22 I remember that. That, you know, that was per 23 through there, or whatever, I know this is 23 God, obviousl that's a joke. 24 Epstein's cell. I know Epstein is not here. 24 MR. : Yeah, yeah, yeah. 2S Even when you look in there, you just keep 25 MR. : But I do remember, it was EFTA00115878 121 122 1 something else on a wall, at some point in 1 notice Epstein's cell mate is gone? 2 time, about, like, yeah, make sure you watch 2 MR. : Right. And now, this right 3 this guy. So, I don't remember if it was a 3 here 4 memo or something, but it was something else. 4 MR. : And I'm not talking about S But I definitely remember that one. If I'm not S just your watch. So, night watch -- 6 mistaken, there was more than one copy of that : Yeah. 7 thing. 7 -- as well as day watch. 8 MR. : Okay. So, but what I'm 8 Yeah. So, day watch, oh, no, 9 asking, was there anybody, any other inmate 9 this is morning watch. So, okay. 10 names, such as this, or was inmate your 10 : Yeah. This is day watch. 11 priority when you were in the SHU? 11 MR. . Yeah. So, day watch. Like, 12 MR. : No. No. I don't remember any 12 obviously, through here, they got rid of him. 13 of the inmates' name. I just remember that. 13 And, like, that, there should have been 14 MR. : So, this is the one guy 14 something done there. 15 that's up on the desk, on the officer's 15 MR. : Yeah. I mean, he's 16 station, saying, making sure you're checking on 16 the guy who was apparently, you 17 him -- 17 know, is apparently signing this, I 18 MR. : Mm-hmm. 18 believe, for all these. He's claiming, yeah, I 19 MR. : -- on Epstein. So, that 19 passed on the information, he's gone, he's 20 was what I was going to get at. If these 20 going to need a new cell mate, if he, in fact, 21 rounds were actually conducted on L-tier, 21 doesn't come back. 22 through that whole time, that that cell is 22 MR. : Mm-hmm. 23 empty -- 23 MR. : So, all right, he's 24 MR. : Mm-hmm. 24 swearing under oath that, and he wrote a memo, 25 MR. : -- how did people not 25 as well. And he swore a couple times to that. 123 124 1 As far as -- 1 to 9:30, if you're saying you noticed at 9:30, 2 MR. : Okay. So, now I got to write 2 that that cell was empty? If this guy is your 3 a memo, ri ht? 3 number ortpljority. 4 MR. IIIIIIIIII: -- so, well, that's what 4 MR. IIIII: Because I was looking for S - you don't have to write a memo, we're talking 5 Epstein. Yeah, I was just, like, my mind, and 6 to you. So, as far as this goes, the question 6 on that s ecific cell, it was him. 7 would be: how are anybody that's working - so, 7 MR. : Right. 8 it's you -- 8 MR. And I knew he was at a legal 9 MR. Mr 9 visit. 10 MR. : -- did start 10 MR. : Yeah, yeah. So, and I 11 then? 11 get it, that you said you did a round on 12 MR. : I think comes in at 12 Epstein when he came back. But if rounds are 13 4:00. 13 being conducted in entire SHU -- 14 MR. : So, it's at -. Okay. So 14 15 -- 15 MR. IIIIIillii-hmm. MR. : -- wouldn't people 16 MR. He's already here. 16 notice, hey, it's claiming that one, two, 17 MR. : -- you four -- 17 three, four, you know, however many there are 18 MR. He's on (Indiscernible 18 there, throughout the day, you're going down 19 *01:17:22 19 everything, how did someone not notice that 20 MR. -- it said four. It's 20 cell was jelpsy? 21 you, , and 21 MR. IIIII: Hmm. And you're absolutely 22 MR. Mm-hmm. 22 right. Now -. 23 MR. : How was it not noticed 23 MR. : So, the point being is, 24 if these rounds on this round sheet were 24 does that mean that these rounds weren't 25 conducted - how was it not noticed, even prior 25 conducted? EFTA00115879 125 126 1 MR. : I'm not going to say that 1 MR. : I wasn't here for those. 2 because I know those people went down, down 2 MR. : That's a - yeah, I know, 3 range, you know, but what I'm going to say is, 3 you left before 10:00 p.m. - so, that's when 4 like, if that dude was gone, and you know, the 4 you would believe it would have been caught, is 5 number one priority is Epstein, and you're just during the counts, not the rounds? 6 doing rounds because you know that you're going 6 MR. : I believe it would have been 7 to have to count anyway. caught more so during the counts, and with the 8 MR. : Yeah, yeah. 8 rounds, you can catch it, but with a million 9 MR. : You know what I'm saying? So, 9 things goin on, it's a little bit harder. 10 when you go through on the count, that's when 10 MR. : I gotcha. 11 you will catch that. 11 MR. You know, -- 12 MR. : So, yeah. In this case, 12 MR. : So, the counts, the more 13 the 4:00 13 official thing, where there's two inmates where 14 MR. Exactly. 14 you're actually counting inmates. So, the fact 15 MR. : -- count wasn't 15 that the 4:00 p.m. count wasn't conducted, 16 conducted? 16 that's why you believe you didn't actually 17 MR. Exactly. 17 catch it until 9:30? 18 MR. : So, the 4:00 p.m. count 18 MR. : Yeah. 19 wasn't conducted. And then -- 19 MR. : Okay. 20 MR. : Yeah. 20 MR. That's why I believe I didn't 21 MR. : -- you have reason to 21 catch it. 22 believe the 10:00 p.m. count wasn't conducted, 22 MR. : All right. But you did 23 either. Nor the 12:00 p.m. Nor the 3:00 a.m. 23 catch it at 9:30 -- 24 And not the S:00 a.m. So, none of those counts 24 MR. Yeah. I did catch it. 25 were conducted. 25 MR. -- and you do believe you 127 128 1 notified someone? 1 didn't call the lieutenant's office - who would 2 MR. : Yes. 2 it be thktily would have called? 3 MR. : And do believe you 3 MR. IIIII: It might have been a unit 4 told both and IIII? 4 manager, or somebody. If anybody was still in S MR. Yeah. Yes. 5 the building at the time. But I called MR. : Yes. And are you 6 somebody. I spoke to someone, higher than me, 7 confident of both those things? Can you state 7 that could make a decision about this 8 iiinalty and perjury of law, I told 8 situation. 9 10 iiiiiMR. and , he did not have a cell mate? 9 : Yes. MR. : All right. So, that was 10 going to be my next question. Are you sure, 11 MR. : What about, are you 11 not only did you call, but you actually spoke 12 confident under penalty and perjury of law, I 12 with someone? 13 called the lieutenant's office and notified 13 MR. : Yes. I spoke with someone. 14 them that_fpirein did not have a cell mate? 14 Who it yial_atthis point, I don't remember. 15 MR. IIIII: I'm confident that I called, 15 MR. IIIIIIIIII: Okay. So, someone. You 16 but who was on the other end of that phone -- 16 did make that notification, and you're saying 17 MR. : Right. 17 someone else (Indiscernible *01:20:44). 18 MR. -- is my issue. 18 MR. : I made that notification, yes. 19 MR. : Right. And what I'm 19 MR. : And ou did - and you're 20 saying is, are you confident you called the 20 positive /2Linformed IIIIIIII and IIII? 21 lieutenant's office, though? 21 MR. IIIII: Yeah. Because we were all 22 MR. : No, I can't say I'm confident 22 talking. Like, it was, like, yeah. This dude 23 I called the lieutenant, but I want to say yes, 23 is (Indiscernible *01:20:54). Like, it was a 24 because that's normally what I would do. 24 conversation. A brief conversation, but a 25 MR. : Right. So, who - if you 25 conversation nonetheless. EFTA00115880 129 130 1 MR. : And you had the three of 1 MR. : Did anyone instruct you? Any 2 you had it? 2 instructions come down? 3 MR. : Yeah. Like, it was, like, you 3 MR. : The instructions started 4 know, I said something, he said something, she 4 coming down about him needing a cell mate after S said something. And then, it's back to S his first so-called suicide attempt or 6 business because it doesn't stop just because - 6 whatever, and that's when they started picking, 7 . You've got to kind of figure things out, as 7 and that's when, you know, like, how - well, 8 you move. So -. 8 what's the other guy's name, Tartaglione? And 9 MR. : Okay. What do you got on 9 that's why we, as officers, can't determine who 10 that? 10 we're going to put in there with this guy. You 11 MR. : When we initially asked you 11 know, like, because if I -. Like, let's say I 12 the question about Epstein and his cell mate, 12 ought to put somebody else in there with him or 13 you said that Epstein must have a cell mate. 13 whatever, and because Epstein is saying that 14 Right? To that effect. You knew that Epstein 14 Tartaglione attacked him, and this, and that, 15 needed a cell mate. 15 and the third. That would fall on me. You 16 MR. : Hmm, and I knew, and when I 16 know, you want a supervisor to make that 17 said that, I mean, I knew that he had one 17 determination. 18 before. I knew he had one before. Because 18 MR. : So, let's talk about -- 19 that's why I was, like, oh, like, where did 19 MR. IIIII: So -. 20 this guy 20 MR. : -- that. Were you there for 21 MR. : Other than the fact that he 21 that incident, when that happened, the first 22 came off psych observation, was there any other 22 attempt of suicide? 23 reason why you felt that Epstein needed a cell 23 MR. I wasn't there for that, no. 24 mate? 24 MR. : Do you know what happened 25 MR. : Personally? 25 between Epstein and Tartaglione? 131 132 1 MR. : Only from what I heard. I 1 find out ri ht now. 2 don't know. 2 MR. : He was not working on -? 3 MR. : Have you heard that, if 3 MR. : He was not working that night, 4 Tartaglione attacked Epstein, did he try to 4 though. kill him, or did Epstein try to hang himself? MR. : No. He was off that day? 6 MR. : I heard that Epstein tried to 6 MR. Mm-hmm. Yeah. Let's see. So 7 hang himself and that, you know, he blamed 7 8 Tartaglione. 8 MR. : So, it came from Lieutenant 9 MR. : Okay. Now, you said from 9 IIII. You think it came from Lieutenant 10 that point onwards, instructions started coming 10 also? 11 down. From who? 11 MR. : Yeah. Because I, like, I 12 MR. : The instructions started 12 didn't speak to IIII recently during that 13 coming down from the SHU lieutenant. I know 13 timeframe, I don't believe. I think, like, 14 Lieutenant would come in. He would -. 14 because I think it was, like I know one time 15 MR. : So, who is the SHU 15 ,specifically, Lieutenant IIIII was, like, by - 16 lieutenant? 16 he specifically said - boss's do, not that 17 MR. Now? 17 night, though. But, you know, he specifically, 18 MR. : No, no. At that point. 18 like, that's one of the first people that was, 19 MR. At that_point in time, I think 19 like, was adamant about keep an eye on this 20 it was still Lieutenant 20 guy. This is why we put him in this cell. 21 MR. : Was it ? 21 MR. : Well, what about the cell 22 MR. Was it Lieutenant.? 22 mate requirement? 23 MR. was in there, too. Mm- 23 MR. : The cell mate requirement 24 hmm. - yeah - was. I think . was 24 thing. That was something that it was 25 SHU Lieutenant at that time. In fact, I can 25 conversations amongst other SHU crew members EFTA00115881 133 134 1 from day, evening, morning shift, or whatever. 1 then, they -. We had to find a cell mate for 2 Like -- 2 him real quick. But like I said, like, this is 3 MR. : Yeah. 3 - it's bits and pieces here. 4 MR. -- we knew we couldn't just 4 MR. : Which SHU staff do you recall 5 make a decision. So, that was a thing, like, having that conversation with? 6 everybody was, like, yo, call the lieutenants, 6 MR. : Pfft. Usually, those are the 7 like, make -- 7 little quick conversations you have during MR. : Mm-hmm. 8 shift change. So, this is, like, hi, bye, 9 MR. -- like, have them tell you 9 blah, blah, blah, blah, blah. 10 who to put in there with this person. 10 MR. : But you don't recall if it 11 MR. : When was this conversation? 11 happened? 12 MR. IIIII! This is over the course of 12 MR. : Yeah. I don't recall it. 13 time. You know, a couple days. Because we, 13 MR. : I have a question. That 14 like, people get - people leave this 14 memo. So, you said you've relived 15 institution, and people come back in. So, 15 Do you recall relieving at 16 usually, you never really know. So, this is, 16 what time? 17 like, you know, days leading, you know, days 17 MR. (Indiscernible 18 leading up to this or whatever. We just, like, 18 *01:24:59 19 idle conversations, that, amongst staff, that 19 MR. : Hmm. 2:00. Yeah. 20 we have had. 20 MR. : At 2:00? 21 MR. : That Epstein needed a 21 MR. : Yeah. 2:00. Maybe a little - 22 cellmate at all times. 22 23 MR. : Yeah. And then, like, you 23 MR. : Do you recall if he left the 24 know, like, because I believe, at one point in 24 institution? 25 time, he had a cell mate, somebody left, and 25 MR. : I don't know. 135 136 1 MR. : But he was no longer in the 1 was still in the institution at 6:00 2 SHU, at taLpoint? 2 p.m. We're trying to figure out why. What 3 MR. IIIII: But yeah, after I relieved 3 would he have been doing in there? Would he -? 4 him, I think he -. I don't know if he went 4 MR. IIIIIiiiiidon't know. home, or if he went somewhere else. I don't 5 MR. : No? And he's not listed 6 know. 6 on that daily roster. Correct? It's signed MR. : Okay. Does that sound right? 7 from 8 MR. : Yeah. So, what you want 8 MR. : That's the 10th. Look at the 9 to say is, this -- 9 9th. 10 MR. Last page. 10 MR. After he left. Can you 11 MR. -- so, this -- 11 find his name on there? 12 MR. Last page. 12 MR. : It's -. 13 MR. : No, no. Not that one. It's 13 MR. : What's the schedule show him 14 the other one. Not this one. I need the other 14 leaving at? 15 one. 15 MR. : 2:00. We saw him leaving at 16 MR. : Yeah. The email. 16 2:00 because I'm his relief. 17 MR. The email. 17 MR. : And you know he was not 18 MR. : So, this email from 18 in the SHU. Correct? 19 to , who was the ops lieutenant 19 MR. : Right. 20 at the time, was sent at 6:07 p.m., where he 20 MR. : Do you guys have access to 21 wrote this - you wrote that, the shot, where 21 BOP -? 22 everyone would call it the -- 22 MR. : Let him look first. 23 MR. : So, look at the date on top. 23 MR. : Okay. 24 At the time. 24 MR. : I don't know. And what was 25 MR. : -- so, it appears that 25 your question again? EFTA00115882 137 138 1 MR. : Do you have access to BOP 1 to a BOP email outside of the MCC. 2 email outside of work? 2 MR. IIIIIIIIII: But what he's saying is, 3 MR. No. 3 would he have access to his BOP email outside 4 MR. : The only way to send an email 4 of the MCC? Would he have been able to send it S is from where? S 6 MR. : I could send an email to a BOP MR. Oh, would -- 7 address. 7 MR. -- yeah. 8 MR. : No, no. From your BOP email 8 MR. -- would has access 9 to another BOP. Like, let's say he was sending 9 to -. Oh. Not to my knowledge. I don't know 10 an email to , right? Could he have done 10 how to do that. 11 it from outside the institution? Or does he 11 MR. : Okay. Yeah, no. And we 12 have to be inside the MCC to get that? 12 already know that. 13 MR. : Like, say it one more time. 13 MR. : And you didn't see him all 14 MR. : So, in order for him to send 14 day? After he had left. 15 this email -- 15 MR. Hmm-mm. 16 MR. : Yes, in order for to 16 MR. : And you relieved him. You 17 send an email to -- 17 didn't see him in the SHU? 18 MR. : This email. 18 MR. : No. 19 MR. 19 MR. : He never came back? 20 MR. : This email. 20 MR. Hmm-mm. 21 MR. Mm-hmm. 21 MR. : Okay. So, we have all these 22 MR. : In order for him to send this 22 documents that we showed you. Just initial 23 email, can he do it outside of the MCC, or does 23 them, please. 24 he have to be inside the MCC to send it? 24 MR. : Okay. Hmm. And this. This 25 MR. : Oh, no. You can send an email 25 one, too, or no? 139 140 1 MR. : Yes. Anything we showed you. 1 talking to inmates and I'm, like, hey, you. 2 MR. Okay. 2 So, I probably wouldn't even notice it was 3 MR. : Just down there. 3 Reyes. You know? 4 MR. What is this one? 4 MR. : But would you -- 5 MR. : This is the one -. S MR. : But if you -. 6 MR. Okay. 6 MR. : -- you would have noticed 7 MR. : Schedule report. That's the 7 that there was no one in the cell, is what 8 one that shows that inmate Reyes, he had left. 8 we're sayin 9 MR. Gotcha. 9 MR. : Right. 10 MR. : And you'll notice, he was 10 MR. : Now, we asked you about, have 11 transferred within, and he went from MCC -- 11 you ever re-filled -- 12 MR. : To GEO. 12 MR. : Mm-hmm. 13 MR. -- to GEO. 13 MR. -- round sheets -- 14 MR. Thank you, sir. 14 MR. Mm-hmm. 15 MR. : And we probably covered this, 15 MR. -- or count sheets. You said 16 but just want to ask one more time. If that 16 yes to the count sheets. Right? 17 4:00 p.m. count was done, would it have been 17 MR. Mm-hmm. 18 caught that Reyes was not in the institution, 18 MR. : Do you recall ever pre- 19 and Epstein needed a cell mate? 19 filling round sheets at all? 20 MR. : There would have -. It would 20 MR. : I don't recall pre-filling 21 have been caught that, you know, that he wasn't 21 round sheets. I remember being taught about 22 in the institution, but, like, when you count, 22 it, at one oint in time. 23 even though you're looking at living, breathing 23 MR. : Taught about it by who? 24 bodies, you know, sometimes you'll be, like, I 24 MR. : That was when I was a daisy 25 don't remember everybody's name. Sometimes I'm 25 fresh rookie. EFTA00115883 141 142 1 MR. : Okay. 1 don't know. 2 MR. 'III!! So, I knew that that was 2 MR. : I don't need - who have you 3 something that was done. 3 heard about? - I don't need dates or anything, 4 MR. : The pre-filling? 4 but who have you heard about pre-filling the S MR. Yeah. 5 rounds and counts sheets? MR. : By who? 6 MR. : You know, some of the old 7 MR. I want to say it was 7 school staff, like, you know, like, when, like, 8 but I was a rookie back then. I was -- 8 but these people don't even work here anymore. 9 MR. : By who? 9 You know, like, I mean, I don't know these 10 MR. -- (Indiscernible *01:30:15), 10 people. They don't work here anymore. They, 11 though. but that was -. I was a rookie 11 you know, like, they had a whole SHU crew. 12 by then. 12 Like, there was a whole system of things that - 13 MR. : Who is= 13 they had it on lock. That was just how it 14 MR. He don't work here no more. 14 worked. 15 MR. : Do you recall his first name? 15 MR. : So, you said SHU -- 16 MR. No. 16 MR. : So, I remember, as a rookie, I 17 MR. : Okay. Do you recall hearing 17 would go in there. And then, you know, they 18 or seeing anybody else pre-fill round sheets or 18 teach you things or whatever, and then, you 19 count sheets? 19 know, like, I guess they've been working so 20 MR. : Yeah. You hear about it, but 20 long, you know, they know the short cuts that 21 21 they do. So, I remember learning about it then 22 MR. : Like, who? 22 or whatever. And then, I even got taught at 23 MR. : You know what I'm saying, 23 one point, or whatever. I'm, like, okay. But 24 like, I've heard about it from multiple people. 24 I wasn't working up there then. 25 Names and dates of when they did it. Like, I 25 MR. : So, the names. I know you 143 144 1 mentioned the SHU crew. So, the names. What 1 MR. and 2 are the names? 2 3 MR. : From all these -. From back 3 MR. : Yeah. 4 then or whatever, it was a whole slew of 4 N.R. : Have you seen them pre-fill - people. have you heard or seen them - pre-fill round 6 MR. : Which is fine. Any names you 6 sheets or count sheets? 7 recall. Because you said you learned it from 7 MR. : I've heard of it. But, you 8 people, ri ht? know, like, I haven't seen them do it, but I've 9 MR. Yeah. 9 heard of it or whatever. And I do remember who 10 MR. And so -. 10 it was, though. I remember, at one point in 11 MR. So, like, as me learning, 11 time, somebody showed me, like, oh, yeah, this 12 like, well, now, I kno started, 12 is how you -. Teaching me how to do the round 13 was up there. (Phonetic Sp. 13 sheets. And taught me that way. 14 *01:31:49). was 14 MR. : What did they teach you 15 MR. 15 exactly? 16 MR. Oh. How do you 16 MR. : Like, I start here. So, the 17 spell that? 17 time is 4:05. And you start at 4:05, finish at 18 MR. He doesn't work here no more. 18 4:06. The next one, you do at 4:07, 4:08. 19 MR. : Okay. 19 MR. : So, that's why you, when you 20 MR. : Who else used to work up 20 saw that -. 21 there? Some dude that used to work here, named 21 MR. : That's when I saw that, and I 22 used to work up there. It's a bunch of 22 recognized it. 23 people. 23 MR. : So, you think that's -- 24 MR. : So, you've got -- 24 MR. That's -. 25 MR. : Track of all these names. 25 MR. -- that's how it was taught EFTA00115884 145 146 1 for -- 1 But obviously, I learned a valuable lesson from 2 MR. : Mm-hmm. 2 that one. 3 MR. -- how many round sheets have 3 MR. : So, I know on that one, that 4 you done? (Indiscernible *01:32:58) that it was 4 a count wasn't actually done. Have there been 5 pre-filled? 5 any other situations -- 6 MR. : Pre-filled? 6 MR. : No. 7 MR. : Yeah. 7 MR. -- where the counts haven't 8 MR. : I don't recall doing any pre- 8 been done? 9 filled round sheets on my career. Because it 9 MR. No. 10 was a situation -. Well, that's another story, 10 MR. : Do you know of any employees 11 so I'm not even going to get into that. 11 that haven't been doing rounds or counts? 12 MR. : Okay. 12 MR. : In SHU or just in the prison 13 MR. Yeah, but -. 13 in general? 14 MR. : You've never, on the round 14 MR. : lust in general. 15 sheets. 15 MR. Yeah. 16 MR. Hmm-mm. 16 MR. : The SHU is what we 17 MR. : How many count sheets have 17 concentrated -- 18 you? 18 MR. Yeah. 19 MR. : Now, the count sheets, on the 19 MR. -- but if you know in 20 other hand, if, you know, you're in a hurry, 20 general. 21 you fill it out -- 21 MR. : Nah, and - pfft - and 22 MR. : Mm-hmm. 22 especialliiiiiir all of this. 23 MR. : -- you execute it. And then, 23 MR. : No. Let's talk about - 24 you put it out. Because you're just, like, you 24 starting at that time, too - were you aware of 25 don't want to waste time just doing paperwork. 25 employees not doing rounds and counts? 147 148 1 MR. : No. But they were all -. I 1 MR. : I don't even remember when it 2 do recall an incident where, I guess there was 2 is. But I remember that was -. I remember 3 a bad count. No. There was two good counts. 3 that was a thing because it was, like, some 4 It was two good counts, and then, they figured 4 people were supposed to get in trouble for 5 out it was a bad count the next shift or 5 that. 6 whatever. So, basically, what people were 6 MR. : Do you recall if 7 doing, they would look in on the computer to 7 IIII, or any of the SHU staff had access to the 8 see what the number was, fill out the paper, 8 El? Even yourself. Did you guys have access to 9 and send it down. I remember that happening a 9 the El document? 10 while back. 10 MR. : No. I didn't have access to 11 MR. : They looked on the computer 11 the El at that time. No. 12 for the number? 12 MR. : What about the rest of the 13 MR. : Yeah. 13 staff? 14 MR. : How do you look -- 14 MR. : I don't think so. 15 MR. Like -- 15 MR. : How would they have the 16 MR. -- on the computer? 16 count? 17 MR. -- they, I guess, like, you 17 MR. He already said. 18 know, somebody must have had work control, and 18 MR. : No, he did, but I'm going to 19 had El access and just looked up the number -- 19 ask about the 10:00 p.m. and the midnight. How 20 MR. : Rh-hmm. 20 would they know to go off the -? I know you 21 MR. : -- of what control would have 21 went off the master sheet, right? 22 on the El, then filled it out, and then said, 22 MR. Mm-hmm. 23 here you go. And turned it in. And that went 23 MR. : What sheet -? What number -? 24 on for some time or whatever. So -. 24 Where would they have got the number two? Not 25 MR. : When was this? 25 for a 10:00 p.m. and a midnight. EFTA00115885 149 150 1 MR. : With that -- 1 right. So, let's just say for the sake of 2 MR. : (Indiscernible *01:35:18). 2 argument, if 9:30, right? It's 9:30, lock the 3 MR. -- yeah, what would have 3 institution down, you count, you take a count 4 happened with that is, is you just, like, when, 4 at 10:00. You count at 10:00, and at this S like, I'm leaving at 10:00. So, I'm leaving at 5 point in time, you know, 12:00, you're off or 10:00. And they were there for the 4:00 count. 6 whatever. So, midnight comes around, your 7 So, they already know numbers. 7 relief comes in, or whatever the case. But in 8 MR. : From the 4:00? 8 this particular case, the onl erson that went 9 MR. : They already know the numbers. 9 home was . Because was still 10 MR. : So, they're going based 10 here. So, if was coming in, or 11 upon the 4:00 count (Indiscernible *01:35:37) - 11 whatever, yo, was here the whole time. 12 12 She knows all the numbers. 13 MR. IIIIIiiiiight. 13 MR. : Right. 14 MR. : -- and if anybody left, 14 MR. : He ain't got to do nothing. 15 they would just subtract them from that number 15 MR. : So, she know that the 16 16 4:00 count cleared, the number that you called 17 MR. : Right. 17 in was good at the time -- 18 MR. -- that you used? 18 MR. : Mm-hmm. 19 MR. Mm-hmm. 19 MR. -- or at least they said 20 MR. : Because they know that 20 it was good. 21 the 4:00 count -- 21 MR. : And nobody else left, or came 22 MR. : Yeah. So, like -- 22 in, and this -. 23 MR. -- (Indiscernible 23 MR. : So, they could just use 24 *01:35:44). 24 that number -- 25 MR. : put, like, this -. All 25 MR. : Mm-hmm. 151 152 1 MR. : -- as their base count, 1 you were working - have you heard about SHU 2 and at the 10:00 p.m., anything that changed, 2 employees sleeping on the job? 3 because was -- 3 MR. : Rumors, but I never observed 4 MR. Mm-hmm. 4 it. S MR. : -- you know, constant. S MR. : Okay. When you were those She was there the whole time. three of you u s in there, did you observe 7 MR. Yes. 7 or sleeping -- 8 MR. : Okay. 8 MR. No. 9 MR. : Have you ever slept on the 9 MR. -- during the shift on August 10 job while ou was -- 10 9th? 11 MR. : Not intentionally. 11 MR. : No. I don't know how they 12 MR. -- while you're sitting on 12 would because we was running the whole time. 13 the computer. 13 MR. There's going to be a lot 14 MR. Like, you know, you sitting on 14 of unnecessary stuff in there, but if you want 15 the computer tou might. 15 to ask those. 16 MR. : Dose off. 16 MR. : Okay. Well, how do you 17 MR. : A box of sandman. Especially 17 answer some of these questions, you said last 18 if you'reliiiii 16 hours on the regular basis. 18 time you interacted with Epstein, something 19 MR. : Did you sleep on August 9th - 19 triggered in our mind, ri ht? And so, that's 20 20 why you told and 21 MR. No. 21 MR. Yeah. 22 MR. -- when you were working? 22 MR. -- to keep an eye on him. 23 MR. No. 23 Okay. Do you know if there was any threats 24 MR. : Have you heard of a SHU - 24 made to Epstein? 25 let's just talk about SHU employees whenever 25 MR. : No. EFTA00115886 153 154 1 MR. : Did you know why Epstein was 1 MR. : What is your understanding of 2 in prison? 2 what happened to him? 3 MR. Well, yeah. I watch the news. 3 MR. : -- that he hung himself. He 4 MR. : Okay. Did you have any 4 hung himself in the cell. 5 feelings re arding why he was in prison? 5 MR. : What is your - you said he 6 MR. : No. 6 hung himself? 7 MR. : Did Epstein have -. Go 7 MR. : Yeah. That's my understanding 8 ahead. You were going to say something. 8 of what hiiiiiid. 9 MR. : Like, feelings, what you did 9 MR. : Do you have any information 10 is what you did. My personal feelings don't 10 with regard to any suspicious activity that 11 matter. It's a job. You know what I'm saying? 11 occurred on August 9th and 10th, 2019, leading 12 So, like, I do my best for something like that. 12 up to the discovery of Epstein in his cell? 13 That's why I don't personally like to read 13 MR. : No. 14 people's paperwork. Because once you know, you 14 MR. : What do you know about 15 can't un-know it. 15 someone else taking Epstein's life? 16 MR. : Mm-hmm. 16 MR. Ililli Nothing. 17 MR. : So, but nah, I didn't have any 17 MR. : What do you know about 18 feelings towards him or whatever. I'm, like, 18 other's assisting in taking Epstein's life? 19 okay, he needs to go here, he needs to go -. 19 MR. Nothing. 20 All right. There you go. There you go. 20 MR. : Did Epstein take his own 21 MR. : What is your understanding of 21 life? 22 what happened to Epstein on August 9th and 10th 22 MR. : I wasn't there, but I would 23 of 2019? 23 assume so. 24 MR. : My understanding of it was 24 MR. : Did Epstein act alone in 25 that -- 25 taking his own life? 155 156 1 MR. : I would assume so. I wasn't 1 in there. Do you think that that would have 2 there. I didn't see anything, but -. 2 potentially helped to actually somebody else in 3 MR. : Did you have any involvement 3 there? 4 with Epstein's death? 4 MR. : Yes and no. I think it might 5 MR. No. 5 have deterred him for a bit, but, you know? 6 MR. : What would have prevented 6 MR. : He would have found a 7 Epstein's death? What actions could have been 7 way? 8 taken to pfLigt his death? 8 MR. : He would have found a way. If 9 MR. IIIII: I mean, personally, I feel 9 that's really what you wanted to do, you would 10 that if a person wants to take their own life, 10 have founiiiiwa iiiiiiBut that's an opinion. 11 they're going to do it. You know? So, I do not 11 MR. : At least in this specific 12 know. 12 circumstance, you think that, between the 13 MR. : Do you think them actually, 13 counts and the rounds, and then getting an 14 if the C.O.s actually did the rounds and the 14 actual cell mate in there for him, because he 15 counts, it could have helped? 15 was required to have a cell mate, do you think 16 MR. : I think it could have been a 16 that those things would have at least helped? 17 deterrent, but the truth of the matter is, if 17 MR. : I think it would have helped. 18 somebody is actually attempting to do that, 18 Yes. 19 they're going to do it. That's not going to 19 MR. : What is some of the 20 stop. And the only reason I say that is 20 systematic problems inside the MCC - and 21 because of my mother's (Indiscernible 21 specifically, the SHU - that allowed for 22 *01:40:12). If you want to do it, you're going 22 Epstein to die? 23 to do it. 23 MR. : A lack of staff. Overworked 24 MR. : What about in a cell? In 24 staff. Not getting clear instructions on what 25 a cell, though, if he actually had a cell mate 25 to do in certain instances; i.e., you know, he EFTA00115887 157 158 1 doesn't have a cell mate, but there was no 1 was. El Chapo never touched a unit. He went 2 directive of who to put in there. Like I said, 2 straight to Ten South. Why would you put 3 if you have an odd number, you don't have a 3 somebody that high-profile, you know, that 4 body to put there. 4 close to iiiiiiiilivery day inmates. MR. : Hmm. 5 MR. : Now, if people are in Ten 6 MR. : You can't just take an inmate 6 South, can they have attorney visits? from another house that didn't do anything, 7 MR. : Yes. 8 just because you trust him, and put him in 8 MR. : So, they can still do 9 there. 9 that attorne visit all day long -- 10 MR. : So, you're saying there 10 MR. : But they don't -- 11 should have been a backup inmate? 11 MR. : -- if -. 12 MR. . There should have been a 12 MR. • -- they could. But in Ten 13 backup plan for that. You know, and it was -. 13 South, the attorney goes up to Ten South. 14 To me, it was decisions made, on the part of 14 There is a room where it's a barrier between - 15 the institution, that were wrong. And because 15 they can talk to each other, but it's a glass 16 they made these decisions, now those other two 16 and stuff in there, anything that needs to get 17 officers have to pay for it. You know, 17 handed, you know, search it, and then, you pass 18 Epstein, as high-profile as he is, should not 18 it over. You could obviously can't read 19 have been in SHU. He should have been in Ten 19 anybody's legal work, but you make sure that 20 South. 20 there's no contraband in there, when it has -. 21 MR. : Why do you say that? 21 And there's another room in there with a slot 22 MR. That's not a decision that we 22 that they can, that the lawyer could do that, 23 get to make. Because he's too high a profile. 23 but the lawyer has to show it to you first, and 24 Look, after that thing hit the news, the world 24 then hand it to the inmate. 25 knew who he was. The world knew who El Chapo 25 MR. : Do you think that the 159 160 1 attorney visits had anything to do with the 1 that you said that you made some time between 2 fact that he wasn't placed in Ten South? 2 9:30 and 10:00. Would it have potentially been 3 MR. : I definitely think that's a 3 to the control center? 4 possibility. You hear lawyer, and they jump, 4 MR. : I guess it's possible. It was 5 too. 5 definitely possible. Because if anything or 6 MR. : Right. 6 whatever, like, because that is one of the 7 MR. : Perfect example is - and this 7 places that we call, control, the lieutenant's 8 is more so the systemic problems that are here 8 office, the unit team, and, you know, sometimes 9 - if an inmate says, I want to talk to my 9 you might make a phone call, like, oh, no, this 10 family, I want to -. For whatever reason, you 10 person ain't here, try this person, try control 11 know, and they get a call from the judge, the 11 center. it's possible. 12 lawyer, anything of the sort. They're going 12 MR. 1111111111: So, looking at the 9th, 13 to, oh, you've got to give this inmate a phone 13 that roster, who would have been on between 14 call, even though this inmate just had his 14 9:30 and 10:00 -- 15 required phone call, and it's not time for that 15 MR. : This is -- 16 phone call again. As soon as you hear lawyer 16 MR. -- in control center -- 17 or judge or whatever, they're going to tell you 17 MR. -- the 9th. 18 to do that. 18 MR. -- or the lieutenant's 19 MR. : Sure. 19 office? Who could have been some potential 20 MR. : Even though he's supposed to 20 possibilities that you spoke with? 21 wait his time. You know, so, but that's how -. 21 MR. : iiirow, I could have 22 I hope that answers your question. 22 possibly spoke to I could have - and 23 MR. : Yeah. 23 honestly, enough - I could havel ly, 24 MR. Fair enough. That's enough. 24 possibly spoke to or too. 25 MR. : Just back to the call 25 But yeah. I wouldn't have asked him. EFTA00115888 161 162 1 MR. IIIIIIiiiikay. 1 information when I'm trying to learn something. 2 MR. : Was there any that you 2 So, I might have asked him. 3 said you definitely would have spoken to 3 MR. : And so, now - and again, 4 someone higher than you? Are you any of those 4 thinking back on, like, how, like you're S people higher than you? S saying, this is such a higher profile thing, MR. : I mean -- and this was so in the media, and everybody who 7 MR. : Or r 7 knew who he was after this - thinking back to 8 MR. : -- well, 8 that, and thinking, like, oh, shit, I knew he 9 (Indiscernible *01:44:52), I'm a seven, they're 9 didn't have a cell mate, I know I called 10 eights. 10 somebody, that doesn't help jog your memory of 11 MR. : Okay. 11 what was said, or what was done, and the fact 12 MR. You know, and they've been in 12 that you're involved now, specifically, with 13 the buildin for so long, that they -- 13 central -- 14 MR. : Sure, sure, sure. 14 MR. Yeah. And I'm -- 15 MR. -- they know every nook and 15 MR. : -- (Indiscernible 16 cranny in here. 16 *01:45:41). 17 MR. : Yeah, yeah, yeah. 17 MR. -- and I'm trying to remember 18 MR. So, that's, like, that's one 18 exactly who I oke to. I really am. 19 of the people, like, oh, wait a minute, I don't 19 MR. : Because I mean -- 20 know how to do something. Hey, can you teach 20 MR. Yeah. 21 me how to do this? 21 MR. : -- wouldn't you have 22 MR. : Sure. 22 thought of that, like, even, like, that day 23 MR. : You know, so, they always gave 23 after, like, oh, man, good thing I called that 24 me good information. So, I would have probably 24 person and told them? 25 asked them. is always giving me good 25 MR. : Yeah. And, like, the only 163 164 1 reason, I'm assuming that the reason that I 1 MR. : Initial. Just initial this 2 don't remember is because I was just moving so 2 one, too. 3 fast. Like, I'm usually very, very detailed 3 MR. : Do you know anything 4 and trying to remember things, and -- 4 about Epstein being prematurely removed from MR. : Sure, sure. suicide watch; and the reasons why, if he was? 6 MR. : -- you know, but -. 6 MR. : Prematurely removed? Factually 7 MR. : All right. And then, do 7 speaking, I don't know if it's premature. I'm 8 you know anything about, if the 10:00 p.m. not psych. Personally speaking, yeah, I think 9 count was conducted? 9 it's probiliiiiiiiitle fast. 10 MR. That, I don't know. 10 MR. : Do you know if anybody 11 MR. : You just -- 11 had any influence on him being removed from 12 MR. That -- 12 suicide watch? 13 MR. . -- you were gone. 13 MR. : That, I don't know. 14 MR. - I was gone. 14 MR. : Okay. So, you don't know 15 MR. : Okay. So, you were 15 anything about, like, attorneys, or judges, or 16 definitel one by -- 16 wardens, or anything -- 17 MR. Yeah. I was definitely gone. 17 MR. No. 18 MR. -- before the 10:00 p.m. 18 MR. : -- who had contact with 19 count. All right. Do you want to ask 19 him? 20 anything? 20 MR. Yeah. I don't get to be privy 21 MR. : No. 21 to that. 22 MR. : Do we have - on the other 22 MR. : Sure. Do you know 23 interview sheets, I had, like, the list of 23 anything about the MCC SHU cameras being 24 (Indiscernible *01:46:33). Some here. Let me 24 tampered with or manipulated? 25 just look. 25 MR. : No. EFTA00115889 165 166 1 MR. : No. Do you know anything 1 MR. : That's a collective. Really. 2 about Epstein being in his assigned cell on 2 You know, in the SHU, there's supposed to be 3 August 10th? Not being in his assigned cell on 3 the OIC. And probably with a little help from 4 August 1011)2.019? 4 C&A. On a regular housing unit, you get a new S MR. IIIII: No. Not being in his assigned 5 inmate, hey, C&A, I got this new inmate, here's _-? You mean, that's because the 10th is when he 6 his numbers, and here's the bed assignment, and 7 was discovered? 7 C&A keys it in. In SHU, usually - because it's MR. : Correct. 8 supposed to be four people in there - the SHU 9 MR. mm. No. 9 OIC wouldiiiiiiiiinmate in, when they arrive. 10 MR. : So, you don't -. 10 MR. : Okay. So, if after 11 MR. : Like, so, he was -. Because, 11 they're -. So, if he arrives from suicide 12 I mean, like, I worked that day, but I worked 12 watch on July 30th, 2019, and he's placed in 13 at 2:00. So -. 13 cell A -- 14 MR. : Who's in charge of making 14 MR. : Mm-hmm. 15 sure that the inmates are in the cells that 15 MR. : -- but for whatever 16 shows within the - I don't know if it was 16 reason, a few hours later, it's determined he 17 Sentry or what system would I be that inmate 17 can't be in cell A, he's got to be in cell B, 18 cell assignments are in? 18 and him and his roommate, Reyes, were moved 19 MR. IIIII: Oh, like, the Sentry. Sentry. 19 over to cell B. Who's responsible for making 20 Yes. 20 that chap e? 21 MR. : So, whose job is it to 21 MR. IIIII: For making it physically or on 22 ensure that -- 22 the computer? 23 MR. : That the -. 23 MR. : In the computer. 24 MR. -- Sentry matches what 24 MR. : You, like, you, normally, you 25 cells they're in? 25 would want it to be the OIC. For this 167 168 1 particular case, I would assume that a 1 MR. To see who is in -. And 2 lieutenant would have been all over that, and 2 how often is that audited, do you know? 3 they would have made sure it was done properly. 3 MR. : I don't know right off hand. 4 MR. : So, in this case, should 4 MR. : Okay. 5 it have been Lieutenant IIII, who was the SHU 5 MR. But yeah. SHU lieutenant 6 lieutenant? 6 should have cau ht that one. 7 MR. : Yeah. 7 MR. : And does that -- 8 MR. : All right. So, he should 8 MR. : Yeah. 9 have been making sure -. So, I mean, it's from 9 MR. -- have anything to do 10 July 30th all the way to August 10th. He's in 10 with the OIC on the different shifts, to say, 11 a cell that doesn't match up with what Sentry 11 like, all right, are these inmates in their 12 says. 12 appropriate cells, or is Sentry up to date? 13 MR. : Yeah. That's not good. 13 MR. : We can ask one another these 14 MR. : So, who, during that 14 questions or whatever, but it's very difficult 15 period, should have caught that -- 15 16 MR. : That would have been -- 16 MR. • Okay. 17 MR. -- (Indiscernible 17 MR. • -- to, you know, do that with 18 *01:49:3322___ 18 everything that's going on, because even during 19 MR. -- that would have been the 19 shift change, nothing stops moving. So, the 20 SHU lieutenant. 20 way I was taught is, like, the morning watch 21 MR. : The SHU lieutenant -- 21 shift, because things slowed down, is they're 22 MR. Yeah. 22 supposed to go through the paperwork and check 23 MR. -- would have audited 23 it, and fix ever thing. 24 those reports? 24 MR. : Okay. 25 MR. : Yeah. 25 MR. : This is the way that I was EFTA00115890 169 170 1 taught how to do it. You know? So. 1 out like that, it's impossible to do that. So, 2 MR. : Yeah, but ultimately, you 2 when you do your searches in SHU, you search 3 believe it was the SHU lieutenant that should 3 kind of, like, the common areas, and, you know, 4 have been responsible? 4 things of that nature, during the day, you S MR. • Yes. S know, because inmates are going to recreation, MR. : Is that a yes or no? 6 medical, and all this, and things of that 7 MR. Yes. 7 nature, or whatever. And so, and you have more 8 MR. : Do you know -. Did we 8 people. So, it's a lot easier to move people 9 ever talk about cell searches? 9 from one place, holding cell over here, search 10 10 the cell, put them back. It's a lot easier. 11 MR. : Do you know if cell 11 When I'm on the evening shift, if, you know, if 12 searches were being conducted in the SHU in 12 I'm doing social visits - social visits, well, 13 July and AL., 22 t of 2019? 13 that, too - social visits, or phone calls, or 14 MR. IIIII: On my shift, no. On the day 14 cell sanitation, meaning that, you know, 15 shift, that's when they're supposed to be 15 inmates get the broom and sweeps out his cell, 16 conducted, because you have more staff, and you 16 I hold the bag up to the slot, he throws his 17 can pull inmates out and actually execute that. 17 trash out, and then I'm onto the next one. You 18 On the evening shift, you don't have enough 18 know, it's -- 19 staff to do that. 19 MR. • Okay. 20 MR. : Per policy, in the SHU, 20 MR. : -- yeah. 21 aren't you supposed to - even at that time - to 21 MR. • So, are you aware that, 22 be doing five cell searches per shift? 22 at the time, in August 2019, though, it was a 23 MR. : Yeah. You're supposed to do 23 policy at least, maybe not practice, but a 24 five cell searches per shift, but being that 24 policy, that five cell searches were supposed 25 they're in the SHU and you can't just pull them 25 to be being conducted during the evening watch? 171 172 1 MR. : No. 1 MR. : Mm-hmm. 2 MR. : You didn't even know 2 MR. : Okay. Overworked and 3 that? 3 understaffed? 4 MR. : No. 4 MR. : Yes. S MR. : So, they were not being S MR. : Okay. Do you remember 6 conducted then? 6 them ever being done at night watch? 7 MR. No. Not cells. 7 MR. : No. I've never seen a cell 8 MR. : Yeah. 8 search conducted on the evening shift. 9 MR. Because you don't have the 9 MR. : Okay. That's all I got. 10 people -- 10 MR. : That's all I got, too. 11 MR. : Sure. 11 MR. : Anything - you've got 12 MR. -- to pull these inmates out. 12 questions for us? - or anything you want to ask 13 MR. : And the morning watch, 13 about this stuff, or -? 14 that was the policy, that you just conduct 14 MR. : Hmm. Where do I stand in the 15 searches of the common areas. But during day 15 mix of alL__,_this at this point? 16 watch, and night watch, you were supposed to be 16 MR. IIIIIIIIII: We don't -. This is a 17 doing cell searches. 17 big investigation. We're talking to a ton of 18 MR. : Easier enough if you have a 18 people. 19 full crew -- 19 MR. : Mm-hmm. 20 MR. : Right. 20 MR. : So, as far as what we do 21 MR. • -- but if you don't have a 21 is, we just basically put the puzzle together. 22 full crewjyL21.2_you going to execute that? 22 MR. : Mm-hmm. 23 MR. IIIIIIIIII: So, the reason why they 23 MR. : We don't, you know, say 24 weren't being done is because you were 24 this person or, you know? We basically give our 25 understaffed? 25 report to the BOP, and the BOP determines -- EFTA00115891 173 174 1 MR. : Mm-hmm. 1 time. So -- 2 MR. : -- what it is that's 2 MR. : Sure. 3 going to happen to people. So, I can't 3 MR. : -- to be expected to remember 4 necessarily say this or that, how you stand, or 4 S how you don't stand. We're the fact finders. S MR. : I totally understand. 6 MR. : Mm-hmm. 6 MR. : -- something from 2019, all 7 MR. : You know, we, you know, 7 the way to 2021, and since that timeframe, I've 8 we present information. We don't make 8 had other inmates attempt suicide, I've had -- 9 determinations. So, based upon, you know - and 9 MR. : Sure. 10 again, I think you've already provided all this 10 MR. : -- other inmates attack staff 11 information in the past - it's just now, we 11 members. I've had to, you know, be a part of a 12 needed to gain clarification of exactly what 12 use of force teams. Multiple things. And I 13 you meant from what you said -- 13 got to go back to 2019 and try to remember 14 MR. : Okay. 14 specific details -- 15 MR. : -- and that was, again, 15 MR. : Absolutely. No, and that 16 the purpose of this. So, we can't really say. 16 is -- 17 What we can say is that - again - you're kind 17 MR. -- do you know how difficult 18 of, like, a small piece of this puzzle. 18 that is? 19 MR. : Mm-hmm. My next question is, 19 MR. : I couldn't agree more, 20 even though this happened so long ago, why wait 20 and those details should have been provided in 21 so long? 21 2019. They should have been asked. It's part 22 MR. : And then, that's -- 22 of the reason why a senior special agent is on 23 MR. : Because that's not the only -. 23 this, is to make sure that these questions are 24 Like, that's an incident, yes, and it's a big 24 being asked -- 25 one, but working in here, things happen all the 25 MR. : Oh. 175 176 1 MR. : -- and it's also why 1 in the future of, like, well, now we can say 2 there's a new case agent. So - you know, on 2 exactly what was the question that was asked, 3 this - so, to make sure that we're going 3 what was stated -- 4 through these things, it's, like, why weren't 4 MR. : Stated -- S these questions asked? Why weren't, you know, S MR. -- in response. 6 that's part of the reason -- MR. -- and what was meant. 7 MR. : Yeah. 7 MR. : Right. 8 MR. : -- why we're here. 8 MR. Mm-hmm. 9 MR. And -. 9 MR. : And so, that's part of 10 MR. : Is to say, like, all 10 it. The old case agent, at least from us, is 11 right, well, we'll reading this, but what does 11 no longer with us. So, that's another reason 12 he mean b that? You know what I mean? 12 why, you know, there's a lot of reasons why 13 MR. : Mm-hmm. 13 we're doing it now, and we weren't able to do 14 MR. : So, that's - again - why 14 it for a time period. 15 we're here, is, like, all right, I could see 15 MR. : Mm-hmm. 16 that you said whatever it is you said, but it's 16 MR. : I'm just not -. I'm not 17 not clear at all with what you meant. 17 sure that I can, you know, I can disclose what 18 MR. : Right. 18 those -- 19 MR. : And so, that's why we're 19 MR. : Mm-hmm. 20 here, is to just get clarity on exactly what it 20 MR. : -- reasons were. But 21 was that was stated, and it's also part of the 21 there were reasons. And now, we're trying to 22 reason wh we've -- 22 move as fast as we can. I don't know if you've 23 MR. : Got the recorder. 23 heard, but we've been in here talking to a lot 24 MR. : -- recorded every single 24 of people. 25 on these, is so that we don't have that problem 25 MR. : Yeah. I've heard. I heard EFTA00115892 177 178 1 that somebody was here. Who it was, I don't 1 we pass it along. When that will happen, I 2 know. 2 couldn't tell you that. 3 MR. • Yeah. Yeah. 3 MR. : Okay. 4 MR. But now, I do. 4 MR. : Ultimately, though, I S MR. : Yeah. So, we're talking S would think what would, you know, if you're 6 to a lot of people, especially a lot of people 6 talking about what happens specifically with 7 that, you know, worked August 9th and 10th, 7 you, that would be in the hands of the BOP. 8 because we've got to, you know -- 8 So, and who in the BOP? I don't know about 9 MR. : Mm-hmm. 9 that. 10 MR. : -- got to make sure that 10 MR. : Okay. 11 we have our information right. Not just that 11 MR. : I don't know if it 12 we talked to people, but we've got to make sure 12 happens with the warden level. I don't know if 13 that that's the actual, accurate information. 13 it happens with OIA. I don't know what happens 14 So -- 14 there. But yeah. Timing. Like, I don't know. 15 MR. : Fair enough. 15 All I know is we're not judge and jury. All we 16 MR. : -- so, that's why we're 16 are is the -- 17 back out here, is primarily to make sure that 17 MR. Mm-hmm. 18 things are accurate. 18 MR. : -- the questioners. 19 MR. : Okay. Not a problem. And so, 19 MR. : Do the -. Find the facts. 20 with all this and everything like that, so, 20 MR. Gotcha. 21 what's the next course of action? So, I've been 21 MR. : Can I see all the documents 22 interviewed, you're still interviewing other 22 we showed? You si ned all? 23 people. So what happens next? 23 MR. : Yeah, he did. 24 MR. That's what we're kind of 24 MR. : You sure. All right. 25 saying, is, like, we take the information and 25 Anything in there, right? I think this -- 179 180 1 MR. : Nope. 1 MR. No. I never had either one of 2 MR. M.- I think this part right 2 their phone numbers. 3 here now.iiiiiiiiii 3 MR. IIIIIIii ikay. 4 MR. : All right. Anything 4 MR. : Okay. Great. Well, I S else? S appreciate your time. Thank you very much for 6 MR. : If you can think of anything 6 your cooperation. It is -- 7 else, anything else you think that you forgot 7 MR. : 8:16. 8 to share with us -- 8 MR. • -- is 9 MR. Mm-hmm. 9 Senior Special Agent , and I'm 10 MR. : -- you're (Indiscernible 10 turning off the recorder. 11 *01:57:23iiIIIIIII 11 12 MR. : Now, on that note, 12 13 though, being that this will be reviewed, is 13 14 there anytim you want to say for the record? 14 15 MR. IIIII: Pretty much that, like, 15 16 although it may be a tragedy that he's gone, I 16 17 wasn't here, I didn't have anything to do with 17 18 d I really don't think that, you know, 18 19 and IIII should be going through what 19 20 t ey re going through. I'm not saying that 20 21 they didn't make a mistake. But that's 21 22 personal o inion. 22 23 MR. : Okay. 23 24 MR. : Are you still in 24 25 communication with them? 25 EFTA00115893 181 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 Brianna Rose Burton, Transcriber EFTA00115894