DIGITALLY RECORDED

1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL AUGUST 4, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00061061 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00061062 3 1 MR. : The recorder is on. My 2 name is , and I'm a Senior 3 Special Agent with the U.S. Department of 4 Justice, Office of the Inspector General, New 5 York Field Office, and these are my 6 credentials. This interview with Federal 7 Bureau of Prisons employee is 8 being conducted as part of an official U.S. 9 Department of Justice, Office of the Inspector 10 General investigation. Today's date is August 11 4, 2021, and the time is 9:24 a.m. This 12 interview is being conducted at the 13 Metropolitan Correctional Center, known as the 14 MCC, located in New York, New York. Also 15 present is DOJ/OIG Special Agent 16 Do you want to show him your credentials? 17 MR. : Thank you. 18 MR. : This interview will be 19 recorded by me, SSA . Could 20 everyone please identify themselves for the 21 record and spell your last name? To start, 22 again, I am DOJ/OIG Senior Special Agent 23 24 MR. : I am DOJ/OIG Special Agent 25 EFTA00061063 4 1 MR. : And you, sir? 2 MR. : I am Correctional Counselor 3 4 MR. : Correctional Counselor? 5 MR. : Yes, sir. 6 MR. : And what did you say 7 that, what level was that? Nine? 8 MR. : GS-9. 9 MR. : GS-9. Great. Thank you, 10 sir. This is an official DOJ/OIG investigation 11 into the death of inmate Jeffrey Epstein, and 12 the surrounding circumstances, and you are 13 being asked to voluntarily provide answers to 14 our questions. Will you agree to a voluntary 15 interview with the DOJ/OIG? 16 MR. : Yes. 17 MR. : Thank you, sir. We have 18 a form, it's the DOJ/OIG form 3-226/2. It's 19 the United States Department of Justice, Office 20 of the Inspector General, Warnings and 21 Assurances to Employee Requested to Provide 22 Information on a Voluntary Basis. "You are 23 being asked to provide information as part of 24 an investigation being conducted by the Office 25 of the Inspector General. This investigation EFTA00061064 5 1 is being conducted, pursuant to the Inspector 2 General Act of 1978, as amended. This 3 investigation pertains to job performance 4 failure and security failure. This is a 5 voluntary interview. Accordingly, you do not 6 have to answer questions. No disciplinary 7 action will be taken against you if you choose 8 not to answer questions. Any statement you 9 furnish may be used as evidence in any future 10 criminal proceedings or agency disciplinary 11 proceedings, or both." 12 And there's a waiver section. It says, "I 13 understand the Warnings and Assurances stated 14 above, and I am willing to make a statement and 15 answer questions. No promises or threats have 16 been made to me, and no pressure or coercion of 17 any kind has been used against me." If you 18 want to take a second to look at that, if you 19 agree with it, you can, there's an employee 20 signature where you would sign, and then you 21 would print your name under here, where it says 22 employee's name. 23 Thank you, sir, for signing. Do you 24 understand the form? 25 MR. : Yes. EFTA00061065 6 1 MR. : Thank you. All right. 2 The date and time, Wednesday, August -- 3 MR. : Fourth. 4 MR. : -- 4, 2021, and the time 5 is 9:26 a.m. now. So, 8/4/21, at 9:26 a.m. 6 Place: MCC, New York. I am signing as the top 7 line. Once again, this is 8 and printing below. Special Agent can 9 you just sign as a witness and then put your 10 name below? Thank you. 11 MR. : This is Agent . I'm 12 signing as a witness and printing my name. 13 MR. : All right. So, before we 14 start the interview, I would like to place you 15 under oath. Mr. , can you please raise 16 your right hand? Do you swear to tell the 17 truth and nothing but the truth during this 18 interview? 19 MR. : Yes. 20 MR. : Thank you, sir. What is 21 your date of birth? 22 MR. : February 26, 1975. 23 MR. : And your SSN? 24 MR. : 055-60-8216. 25 MR. : Thank you. And your EFTA00061066 7 1 current home address? 2 MR. : 31 Wansor Avenue, Sayville, 3 New York, 11709. 4 MR. : And your current 5 cellphone number? 6 MR. -: 7 MR. : And what is your current 8 position again? 9 MR. : Correctional Counselor. 10 MR. : And how long have you 11 been in that position? 12 MR. : Since February 2020. 13 MR. : Okay. And what were you 14 prior to that? 15 MR. : A Lieutenant. 16 MR. : Great. Were you 17 previously interviewed under this 18 investigation? 19 MR. : Yes. 20 MR. : All right. Awesome. I'm 21 just going to review the report that was 22 generated, based upon your interview. I'm 23 going to go kind of, a little slower through 24 it, so that you can actually grasp and 25 understand what it is that they wrote. I just EFTA00061067 8 1 want to make sure that everything that they 2 wrote is accurate. 3 MR. : Uh -huh. 4 MR. : And just stop me if 5 anything is not accurate. 6 MR. : Okay. 7 MR. : All right. It says, "The 8 following interview was conducted by Assistant 9 United States Attorney, AUSA, 10 and Office of the 11 Inspector General, Special Agent 12 . Also present for the interview was 13 Federal Bureau of Investigation Special Agent 14 15 ," and it says your date 16 of birth, "was interviewed at the United States 17 Attorney's Office, 1 St. Andrew Plaza, New 18 York, New York. After being advised of the 19 nature of the interview, and the identities of 20 the interviewing AUSA and Special Agents, 21 provided the following information." 22 stated he worked for the Bureau %•% 23 of Prisons, BOP, since approximately January 24 15, 2001." 25 MR. : Yes. EFTA00061068 9 1 MR. : "Prior to employment with 2 the BOP, worked for the Building and 3 Maintenance Union, the Marine Corps Reserve, 4 and the New York Police Department Auxiliary." 5 MR. : Yes. 6 MR. stated he joined 7 the BOP as a Correctional Officer and was 8 promoted to Lieutenant in October 2015." 9 MR. : Yes. 10 MR. : "He spent one year at the 11 Federal Correctional Institution, Fort Dix, 12 when he first joined the BOP and had spent the 13 remainder of his tenure at the Metropolitan 14 Correctional Center." 15 MR. : Yes. 16 MR. "Captain 17 was his supervisor." 18 MR. : Yes. 19 MR. : Who is your supervisor 20 now? 21 MR. : Right now, it's 22 Bullock. (Phonetic Sp. *00:06:15) He's my Unit 23 Manager. 24 MR. : Okay. stated a 25 GS-9 Lieutenant's responsibilities depend EFTA00061069 10 1 largely on which area of the prison he or she 2 was assigned to, which rotated on a quarterly 3 basis." 4 MR. : Yes. 5 MR. : "Those duties include 6 operations, activities, solitary housing, 7 special investigations, and administration, as 8 well as possible collateral duties, such as 9 emergency protection." 10 MR. 11 Same thing. 12 MR. Emergency preparedness. : Okay. Preparedness? 13 MR. : It would be the EPO is what 14 the title was. 15 MR. : Sure. I understand. 16 " stated he was assigned as the 17 Activities Lieutenant at the time of the 18 interview, and worked the regular 2 p.m. to 10 19 p.m. shift." 20 MR. : Yes. 21 MR. : And then on the daily 22 schedule, it actually listed 4 to 12, correct? 23 You just came in two hours early? 24 MR. : Well, what lieutenants were 25 doing, we always did two hour reliefs for each EFTA00061070 11 1 other. 2 MR. : Okay. But if I was to 3 actually look at that daily schedule -- 4 MR. : I believe it would show 4 to 5 12, or actually, if it was activities, 6 Activities Lieutenants at that time were 6 to 2 7 and 2 to 10. Operations Lieutenants were on 8 the 8 to 4, 4 to 12, 12 to 8 rotation. 9 MR. : Okay. I see what you're 10 saying. So, there's no actual two hour change, 11 when you're looking at an Activities 12 Lieutenant? 13 MR. : Yeah, no. 14 MR. : It is what the actual 15 daily assigned roster said? 16 MR. : It is what the time, yeah. 17 I forgot what the, it's been a while. I forgot 18 the shift number. 19 MR. : Absolutely. But, so, the 20 Activities and the Ops Lieutenant were working 21 the same hours? 22 MR. : They will, they piggyback, 23 but let's say, like, the 2 p.m. Activities 24 Lieutenant, I would be here on the, still under 25 the Day Watch Lieutenant, and then the Evening EFTA00061071 12 1 Watch Lieutenant would roll in, if they're 2 going by 8 to 4. Cause I, as an Evening Watch 3 Activities Lieutenant, I worked 2 p.m. to 10 4 p.m. But if, like, if the Day Watch Lieutenant 5 was still there 8 to 4, I would be working two 6 hours with him or her. 7 MR. : Yeah, so, I guess what 8 I'm asking is, I thought at this time, in 9 August of 2019, they were allowing the Ops 10 Lieutenants to come in two -- 11 MR. : We were. We were doing two 12 hour reliefs for each other. 13 MR. : So, you were actually 14 working the same hours? 15 MR. : Same hours. 16 MR. : Okay. 17 MR. : Yes, sir. 18 MR. : Great. So, you were, 19 both Ops and Activities were 2 to 10 at the 20 time? 21 MR. : Yes. 22 MR. : Perfect. 23 MR. : Well, I think that's what I 24 was assigned to. I can't recall 100%. 25 MR. : Sure. And these are EFTA00061072 13 1 MR. : When I got interviewed. 2 MR. : Sure. So, I'm going to 3 give you, right now, the daily assignment 4 rosters for both Friday, August 9, 2019, and 5 Saturday, August 10, 2019. 6 MR. : Uh-huh. 7 MR. : It's just so that, if it 8 helps you refresh your memory, cause we're 9 talking about so long ago. All right. 10 stated he was assigned as the 11 Activities Lieutenant at the time of the 12 interview and worked the regular 2 p.m. to 10 13 p.m. shift. His regular days off were Mondays 14 and Tuesdays. He would, on occasion, work 15 overtime hours or switch shifts with other 16 officers." 17 MR. : Wait, I'm sorry. Can you 18 read that again? I apologize. 19 MR. : Absolutely. Okay. So, 20 after the 2 p.m. to 10 p.m. shift, which we 21 just discussed. 22 MR. : Uh-huh. 23 MR. : It says, "His regular 24 days off were Mondays and Tuesdays. He would, 25 on occasion, work overtime hours or switch EFTA00061073 14 1 shifts with other officers." 2 MR. : We're not officers. We're 3 lieutenants. 4 MR. : That's probably what they 5 (Indiscernible *00:09:11). 6 MR. : Okay. 7 MR. : So, switched shifts with 8 other lieutenants, to be able to fill in for 9 the Activities Lieutenant, is what you're 10 saying? 11 MR. : Yeah. Or, a lot of the 12 times, we got mandated to stay. 13 MR. : Right. But only 14 lieutenants could actually fill those 15 positions, is what you're saying? 16 MR. : Yeah. Only, well, a 17 lieutenant, only a lieutenant can fill an 18 Operations Lieutenant. 19 MR. : Correct. 20 MR. : You could have a GS-8 21 Officer cover as an Activities Lieutenant. 22 MR. : Okay. 23 MR. : Cause, like, that Friday 24 evening, the night before, I was Operations and 25 I had an 8 as my Activities Lieutenant. I had EFTA00061074 15 1 an officer acting as Activities. 2 MR. : Okay. So, then, people 3 could switch, that were officers? 4 MR. : No. Only, a lieutenant 5 can't switch with an officer to fill a post. 6 They can backfill, if there's, a lieutenant 7 calls in sick. If a lieutenant is not there. 8 MR. : Okay. So you can't 9 MR. : They can use a GS -- 10 MR. : -- you can't ask an 8, 11 say, hey, can you switch with me? It's only if 12 -- 13 MR. : No. Like, as an Activities 14 Lieutenant, I would have to call in sick to the 15 Captain. If I wanted a shift off, I could 16 switch with another officer. I can't 17 necessarily switch with an 8 officer. 18 MR. : Okay. And looking at 19 this daily assignment roster, I'm assuming you 20 noticed that you were actually Ops Lieutenant? 21 MR. : Yes. I was Evening Watch 22 Operations the night before. 23 MR. : On August 9th? And then 24 was actually an 8, Acting Lieutenant? 25 MR. : Yeah, she was a GS-8 EFTA00061075 16 1 officer. 2 MR. 3 MR. 4 night. 5 MR. : Okay. : She was my Activities that : I got you. All right. 6 "As there were no Activity Lieutenants assigned 7 during the overnight hours, he had no relief 8 officers." I don't know why they would have 9 wrote that sentence in there. So, I'm going to 10 read this paragraph again, just to help clarify 11 this. ` stated he was assigned as the 12 Activities Lieutenant at the time of the 13 interview and worked the regular 2 p.m. to 10 14 p.m. shift." 15 Again, on Friday, August 9, you were 16 actually the Ops Lieutenant and was the 17 Activities Lieutenant. It says, "His regular 18 days off were Mondays and Tuesdays. He would, 19 on occasion, work overtime hours or switch 20 shifts with other lieutenants." And in this 21 case, again, you explained 22 MR. : Uh-huh. 23 MR. : -- that you can't 24 actually switch with lieutenants, only if you 25 get bumped and that position is filled, can an EFTA00061076 17 1 8 officer -- 2 MR. : Yes. 3 MR. : And then it says, "As 4 there were no Activity Lieutenants assigned 5 during the overnight hours, he had no relief 6 officers." You weren't doing overnight? 7 MR. : No. I got relieved and went 8 home that evening. 9 MR. : I'm not exactly, were you 10 doing overtime shifts for the morning watch? 11 Is that why they would have wrote that? 12 MR. : It could possibly be. I 13 mean, we worked overtime shifts constantly. At 14 one point in time, we were short-staffed 15 lieutenants like you wouldn't believe. We were 16 filling this building with five or six 17 lieutenants, we were running the whole 18 building. That's one of the reasons why I 19 became a counselor. I was never home. 20 MR. : Okay. So that is a 21 little confusing. What it's trying to say, 22 though, is that if you're the Ops Lieutenant, 23 on the morning watch, there is no Activities 24 Lieutenant? 25 MR. : No. Yeah, that, no. EFTA00061077 18 1 There's only an Activities Lieutenant until 10 2 p.m. 3 MR. : Right. stated 4 the responsibilities of an Activities 5 Lieutenant include making rounds and placing 6 inmates in Special Housing. During rounds, 7 they ensure officers are properly carrying out 8 their job responsibilities and give the inmates 9 the opportunity to address with them any 10 concerns. stated he often attempted to 11 walk all the tiers, based on time." 12 So, on this, we have heard different 13 things from different people. As an Ops 14 Lieutenant, or an Activities Lieutenant, are 15 you required to go into the SHU, and I'm 16 talking specifically at this time, so August 17 9th, August 10th of 2019. Was a lieutenant, or a 18 SHU lieutenant, was a lieutenant responsible to 19 go to the SHU and walk the tiers and do a round 20 with the inmates? 21 MR. : With the inmates? 22 MR. : Yeah. So -- 23 MR. : Well, a lieutenant is 24 supposed to, is mandatory, supposed to make 25 rounds. EFTA00061078 19 1 MR. : So what is the definition 2 of a lieutenant round? 3 MR. : A lieutenant round? Well, 4 in the Special Housing or general pop? 5 MR. : Let's talk just Special 6 Housing. 7 MR. : Okay. Special Housing, one, 8 the lieutenant walks through the 27 door, 9 that's the outer door of the SHU. Sign in, in 10 the log book. Go in, go, sit down on the 11 computer, login, do the True Scope rounds. Got 12 to enter your rounds in SHU. Go up to 10 13 South. Make the rounds up there. Same thing. 14 Enter the information in True Scope. 15 MR. : So, when you go into 9 16 South, though, and you're entering in that you 17 conducted a round, what does the round entail? 18 MR. : Well, making sure that the 19 officers are doing their job. And like I said, 20 if time permits, if you can, you know, do it, 21 go down the range. Go one range, two ranges, 22 three ranges. 23 MR. : And that's where, so, 24 this is where we have gotten, some people are 25 saying they had to do, in order to conduct an EFTA00061079 20 1 actual round, you have to actually walk the 2 tiers. Do you know that to be the case? 3 MR. : Well, yeah. Cause the 4 officer has to let you down range. 5 MR. : Okay. 6 MR. : The officer has the grill 7 key. Nobody could just go down range in SHU. 8 MR. : Sure. 9 MR. : So, the officer would have 10 to open the grill. You go down range and then 11 have to sign the rounds sheet at the end of 12 each range. 13 MR. : And I think I understand 14 what you're saying. You're saying sometimes, 15 there just wasn't time to do it 16 MR. : Uh-huh. 17 MR. : -- but does that actually 18 constitute a round, actually walking down the 19 range for a lieutenant? 20 MR. : Well, not so much, the 21 officers are supposed to be making the 30 22 minute rounds. 23 MR. : Sure. 24 MR. : The lieutenant just has to 25 make sure that that that, he or she has to go EFTA00061080 21 1 in that unit and make sure that the officers 2 are doing their rounds. Check the rounds 3 sheets or the log book, log into True Scope, 4 and, you know, make, basically, is that 5 lieutenant is confirming that staff are doing 6 their job. 7 MR. : So, the lieutenant didn't 8 actually have to walk the tiers? 9 MR. : No. 10 MR. : Okay. 11 MR. : No. 12 MR. : And the ranges? All 13 right. So, that was your understanding? So 14 when you're assigning the actual round that you 15 conducted, it's to say that you basically did a 16 round with your officers, to ensure they were 17 doing their job? 18 MR. : Their job, and you go into 19 the 10 South and do the same. 20 MR. : Okay. But not that 21 you're actually conducting a round? 22 MR. : Huh-uh. 23 MR. : Like, as far as 24 conducting a round with inmates? 25 MR. : No. No, that's, the whole EFTA00061081 22 1 purpose behind the 30 minute log book. 2 MR. : Right. 3 MR. : The 30 minute round sheets. 4 MR. : Okay. stated on 5 weekdays, the prison takes a count at 4 p.m. 6 The Activities and Operations Lieutenant take a 7 verbal count by speaking with each unit and 8 match that number with the count slip from 9 Internal. If correct, they clear the 10 institution count. They cannot clear a count 11 until they receive a good verbal count from 12 every unit. He was not aware of any instances 13 in which the count was cleared without speaking 14 with every unit." 15 MR. : No. 16 MR. : So that's correct, 17 though? 18 MR. : Yeah. Yeah. 19 MR. : stated he would 20 attempt to watch the camera monitors as the 21 corrections officers performed the count to 22 ensure officers were properly counting. He 23 could not monitor at all times, due to the 24 amount of activity in the Control Room." 25 MR. : Well, it depends. During EFTA00061082 23 1 the count, my job is mainly taking the count. 2 MR. : Right. 3 MR. : You know, I could look up at 4 the cameras, you know, but you have a lot of 5 movement going around in Control. 6 MR. : Sure. 7 MR. : You know, throwing keys. 8 If, let's, and there's been many times where we 9 were so short-staffed, we had one officer in 10 Control. 11 MR. : Uh-huh. 12 MR. : So, while I'm taking the 13 count, I'm also doing C . I'm helping him 14 throw keys. You know, but as far as clearing 15 the count, yes. You cannot clear the count 16 until you get a verbal, verbal, good verbal 17 count from the Unit Officer, cause we have the 18 PP1, the El, in front of us with the actual 19 accurate count, as per Sentry. So we have to 20 compare those numbers. You write it down. We 21 compare it. So, you cross it off on the Sentry 22 paperwork, okay, 7, I'll call in a good count. 23 MR. : But, as far as, like, the 24 4 p.m. count, the Activities or Ops Lieutenant 25 has to actually be present in Control to do EFTA00061083 24 1 that? 2 MR. : Yes. 3 MR. : And about how many people 4 are present in Control when that count is being 5 conducted? 6 MR. : If we're fully staffed, 7 we'll have two officers and the lieutenant in 8 the Control Center. 9 MR. : Okay. Okay. So it's 10 three people in there? 11 MR. : Yeah. It's the Control Room 12 Officer, the C&A Officer, and it would be the 13 lieutenant, Activities or Ops. 14 MR. : What does C&A stand for? 15 MR. : Counts, truth be told, I 16 have a total brain (Indiscernible *00:17:03). 17 Count -- 18 MR. : So, it's like Control 19 Number 1, Control Number 2 -- 20 MR. : Two, yeah. 21 MR. : -- and you're saying 22 Control Number 2 is --23 MR. : Control Number 2 is C&A. 24 MR. : Okay. 25 MR. : Old school, it used to be EFTA00061084 25 1 called C&A. 2 MR. : Okay. 3 MR. : I know it's Counts and 4 Accountability, I think is what the acronym 5 was. 6 MR. : Okay. So that's the 7 person who actually, like, receives the counts 8 from people? 9 MR. : Yes. 10 MR. : Is that what you're 11 saying? 12 MR. : C&A is the one that does all 13 the Sentry work for all the movement, you know, 14 to make sure the roster is accurate, the 15 counts, or the unit base counts and unit counts 16 are accurate. 17 MR. : That's Control Number 2? 18 MR. : Yeah. 19 MR. : So, in this case, if 20 you're looking at August, Friday, August 9, 21 2019, would that Control Officer Number 2, can 22 you tell me who that would have been? 23 MR. : (Phonetic Sp. 24 *00:17:49) for the 6 to 2 shift, and 25 (Phonetic Sp. *00:17:51) for the 2 to EFTA00061085 26 1 10. 2 MR. : So, as far as the 4 p.m. 3 count, that would not have been 4 MR. : Well, would have been 5 in Control, cause he would have been the 6 Control 1 Officer. 7 MR. : Oh, I thought it was 8 Control 2 for him. 9 MR. : Control, no, Control 1, 10 is Control 1 and is Control 2. 11 MR. : Oh, okay. So, okay. So, 12 what would Control l's typical responsibilities 13 have been? 14 MR. : At 4:00, the same thing. At 15 4:00, people are leaving, so that person would 16 be over at the window, throwing keys. We call 17 it throwing keys. 18 MR. : Okay. 19 MR. : It's just, it's an 20 expression. He would be taking the keys, 21 radios, OC and stuff like that from the 22 departing staff, putting it back on the board, 23 giving them their chits and receiving chits for 24 equipment for the oncoming staff. 25 MR. : Okay. So, in this case, EFTA00061086 27 1 it should have been, at least at 4 p.m., the 2 person that would be signing the documents and 3 taking the count should have been this 4 and not 5 MR. : With the lieutenant. 6 MR. : With the lieutenant. 7 Okay. And after we're done with this, we'll 8 just go over some of the counts, just to -- 9 MR. : Okay. 10 MR. : But we'll move on, just 11 to make sure we can keep moving on this. I'm 12 just going to read it over to, I can't remember 13 exactly where I left off. 14 MR. : Fourth paragraph. 15 MR. : Third paragraph? 16 MR. : Fourth. stated he 17 was normally relieved (Indiscernible *00:19:24) 18 before 10 p.m. 19 MR. : I'm just going to read 20 this last paragraph over. stated he 21 would attempt to watch the camera monitors as 22 the corrections officers performed the count to 23 ensure officers were properly counting. He 24 could not monitor at all times, due to the 25 amount of activity in the Control Room." EFTA00061087 28 1 Again, you said that you might glance up, but 2 you're not actually, like 3 MR. 4 staring. 5 MR. : Yeah. Yeah, I wasn't : Sure. Absolutely. 6 MR. : You know? I would be 7 answering the phones, writing down the actual 8 count -- 9 MR. : Totally. 10 MR. : -- you know, the crossing 11 off, and, you know, making the, especially if I 12 had seen that, like, if a count was being 13 delayed, I would be, like, what's the problem? 14 And I would look. You know. 15 MR. : I got you. So, you're 16 not, like, yeah, making sure they're doing 17 their job -- 18 MR. : It's not, I'm not glued to 19 the camera. 20 MR. : -- cause you have your 21 own job to be doing, is what you're saying? 22 MR. : Yeah. 23 MR. : Okay. stated he 24 would normally relieve, be relieved before 10 25 P•m• • prior to evening count. He had heard of EFTA00061088 29 1 an instance where the count was not properly 2 completed, but he had, but it had been some 3 time in the past." So, if you're that 2 to 10 4 shift, do you do the 4, the relieving shift 5 would typically do the 10 p.m., is what you're 6 saying? 7 MR. : Yes. 8 MR. : Okay. Do you ever do the 9 10 p.m.? 10 MR. : On nights that I was coming 11 in for the overnight. 12 MR. : But, I mean, as the 2 to 13 10 shift, do you ever do the 10 p.m.? 14 MR. : I probably have, but I can't 15 even recall when the last time I was. 16 MR. : Yeah, yeah. It's 17 typically that relieving officer's duty, 18 though? 19 MR. : Yeah. The relieving 20 lieutenant. 21 MR. : Lieutenant, right. 22 MR. : Yeah. 23 MR. : And then it says, "He had 24 heard of an instance where the count was not 25 properly completed, but it had been some time EFTA00061089 30 1 in the past." Any information on that? 2 MR. : No. I mean, it was 3 probably, I remember when I said that. It was, 4 you always hear of the horror stories, and when 5 you come home, come in off your days off, you 6 would be, like, oh, you know, what happened the 7 other day? Or this, that, and the third. You 8 know. 9 MR. : Right. 10 MR. : That kind of thing. 11 MR. : Okay. 12 MR. : But I have never heard it 13 where it has been detrimental. 14 MR. : Okay. But it wasn't 15 talking specifically about, like, August 9th 16 (Indiscernible *00:21:12). 17 MR. : No, no. I'm talking, like, 18 ten years. I wasn't even a lieutenant at the 19 time. 20 MR. : Okay. 21 MR. : You know, I was still an 22 officer. 23 MR. stated, as a 24 lieutenant, he worked to enforce policy through 25 verbal counseling and by example. Taking the EFTA00061090 31 1 count is one of the most important duties 2 corrections," I keep on saying corrections, but 3 I know it's correctional officers "perform as 4 professionals." 5 MR. : Right. It's accountability. 6 Inmate accountability is the most important 7 thing here. Maintain security. 8 MR. : Okay. 9 MR. : You got to make sure that 10 they're all here at the end of the day. 11 MR. : So, are you saying, like, 12 basically, counts and rounds are the most 13 important things that a correctional officer 14 does? 15 MR. : Count, I mean, everything, 16 controlling contraband, shaking down. 17 Nowadays, with the K2, it's ridiculous. 18 MR. : Right. 19 MR. : You know, there's a lot on 20 an officer's shoulders. 21 MR. : Right. 22 MR. : But of course, you know, we 23 only do the counts at certain periods 24 throughout the day. You know? The officers 25 making rounds are what helps reduce the fact of EFTA00061091 32 1 them doing the K2 or, you know, making weapons 2 or tattooing or things of that nature. 3 MR. : Sure. 4 MR. : You know, so, of course, 5 making rounds, being visible. That's what we 6 like to say, and, like, when we're training or 7 whatever. Be visible. 8 MR. : Sure. 9 MR. : Make the inmates see you. 10 MR. : So, counts are basically 11 to ensure everybody is there. And rounds are 12 to ensure that inmates are kind of doing what 13 they're supposed to be doing? 14 MR. : Yes. 15 MR. : Okay. 16 MR. : And that's a perfect, what's 17 the word I'm looking for? Perfect expression. 18 MR. : Okay. Perfect example. 19 Okay. 20 MR. : Yeah. 21 MR. -: ` stated the 22 Special Housing Unit is responsible for doing 23 rounds every 30 minutes. As the lieutenant, he 24 would sign round forms, if they were correct. 25 He had never signed off on forms that were EFTA00061092 33 1 filled out in advance, and would report any 2 instances of that to his supervisors, if he was 3 aware of it." So, I'm assuming what you mean 4 there is, if you knew they were filled out in 5 advance? 6 MR. : I wouldn't sign them. 7 MR. : Right. 8 MR. : I'm not putting my John 9 Hancock on that. I would tell them 10 (Indiscernible *00:22:58). 11 MR. : But, how would you know 12 if they had filled it out in advance? You 13 mean, if -- 14 MR. : If I went there and sat, and 15 if I walked into the SHU unit and it was 1:00, 16 I'm just throwing the time out there -- 17 MR. : Sure. 18 MR. : 1:00 p.m., but I saw the 19 rounds sheet, it was 1:00 when I walked in, but 20 I look at the rounds sheet and the 1:30 rounds 21 are already filled out. 22 MR. : And would that happen? 23 MR. : Very rarely. But I might, I 24 don't think I have seen it as a lieutenant, but 25 I have heard of it happening. EFTA00061093 34 1 MR. : But you never really, you 2 never witnessed it? 3 MR. : But, I was trained 4 differently. I was trained, you don't put your 5 ink to paper unless it's the way it's supposed 6 to be, and if it is, tell the boss. 7 MR. : Now, back then, August of 8 2019, had you heard that people were filling 9 them out in advance? 10 MR. : No. I didn't. 11 MR. : No? 12 MR. : No. 13 MR. : Okay. So you're not 14 aware of anybody filling them out in advance? 15 MR. : No. I have no personal 16 knowledge. 17 MR. : "He trained officers to 18 defer their round patterns, so inmates would 19 not be aware of their timing." 20 MR. : Yes. 21 MR. : And that means it's just 22 not to be on an exactly 30 minute -- 23 MR. : Yeah. Don't always make 24 your rounds at 1:05, 1:35, 1:45. Alternate 25 your rounds. The policy states, every 30 EFTA00061094 35 1 minutes, not to exceed 40. 2 MR. : Right. 3 MR. : You know? 4 MR. -: ` stated he had 5 heard stories of officers not completing their 6 30 minute rounds in the SHU. Other than the 7 Jeffrey Epstein death, he had not heard of an 8 instance for approximately five to ten years." 9 MR. : Yes. 10 MR. : So, I'm assuming what 11 you're saying here is 12 MR. : Back in the days. 13 MR. : But I'm assuming what you 14 said, when you say other than Jeffrey Epstein, 15 you did hear that they did not complete their 16 30 minute rounds? 17 MR. : I mean, bureau-wide. People 18 have gotten in trouble for it before. 19 MR. : Right. 20 MR. : That's why, like, this 21 whole, this was all new with the fact that how 22 serious it got. 23 MR. : Okay. But you had heard 24 that, had you heard that on August 9th and 10th, 25 then, and I am assuming this means after the EFTA00061095 36 1 fact, that people weren't conducting their 30 2 minute rounds? 3 MR. : The only thing I heard is 4 the same thing everybody else has heard, out on 5 the street. 6 MR. : Okay. 7 MR. : What you hear in the media, 8 what you hear on social media, what you hear in 9 the newspapers. They were very quiet here. 10 MR. : Okay. 11 MR. : I was here that morning of, 12 after the fact, and we didn't get told 13 anything. 14 MR. : Are you talking about 15 August 10th? 16 MR. : Yeah. That Saturday. 17 MR. : Okay. 18 MR. : You know. There was a total 19 blackout. We were kept in the dark. 20 MR. : And you hadn't heard 21 anything about, like, people not conducting 22 counts or rounds? 23 MR. : No. Just, well, like I 24 said, the same thing you heard out on the 25 street. EFTA00061096 37 1 MR. : But, I mean, not from 2 inside the institution? 3 MR. : No. 4 MR. : No one was speaking about 5 that? 6 MR. : Well, I mean, the whispers, 7 here and there, but nothing was confirmed. 8 MR. : Okay. 9 MR. : You know? Of course, when 10 something like this, look, it's, I have been 11 doing this almost 21 years. When something, 12 God forbid happens like this, everybody Monday 13 morning quarterbacks. 14 MR. : Sure. 15 MR. : Everybody talks, oh, they 16 must have done this, or they didn't do this. 17 That's all I have heard. 18 MR. : Uh-huh. 19 MR. : I didn't hear nothing 20 official, if that's what you're asking. 21 MR. : Yeah. No, no, no. 22 MR. : I have heard rumor mills. 23 MR. : I just wanted to know -- 24 MR. : There were whispers. This, 25 that, and the other thing. EFTA00061097 38 1 MR. : I would just assume 2 people would have been talking inside the 3 institution. I wanted to make sure that you 4 also heard it inside the institution, not just 5 through the media? 6 MR. : Yeah. No, I mean, I, like, 7 as far as a whisper here and a rumor here, I 8 chose to stay away from it, because, one, I was 9 a supervisor and two, I know what was coming 10 down. 11 MR. : Sure. 12 MR. : I knew how serious it was 13 going to be. And I was not going to entertain 14 any of that. 15 MR. : Sure. So, you had heard 16 people saying that there were rounds and counts 17 weren't complete; however, you didn't put any 18 credibility to it -- 19 MR. : No. 20 MR. : -- because it wasn't 21 official? 22 MR. : No. It wasn't, it wasn't 23 official. It was just rumor mills. It was 24 whispers. It was Monday morning 25 quarterbacking, for lack of better terms. EFTA00061098 39 1 MR. : Okay. But that was a 2 correct, was that a correct assessment, which I 3 just -- 4 MR. : Yes. Yes. 5 MR. : Okay. 6 MR. : I apologize. I don't mean 7 to go long-winded on it. 8 MR. : No, no, no. Just cause 9 when I said it, you said, no, but I just wanted 10 to make sure you actually meant yes. 11 MR. : Yeah, no. Like, I heard -- 12 MR. : With what, I know, I 13 understand -- 14 MR. nothing official. Yeah. 15 MR. : Right, yeah, yeah. I 16 just, cause for the transcript, it will read 17 that you're contradicting what I said, and I 18 just want to make sure -- 19 MR. : No problem. 20 MR. : -- what I said was 21 actually accurate. Okay. 22 MR. : Uh-huh. 23 MR. stated he 24 recalled suicides taking place in MCC in 2003 25 and another several years later." So, I guess, EFTA00061099 40 1 what you're saying is that since you have 2 worked, maybe there was about two suicides? 3 MR. : I had one, I was personally 4 involved in one in 2003, and that's the one 5 that I was, that I referenced. There was one 6 years later. I don't recall what year it was, 7 or the outcome of that one. I just know that 8 the one that I was involved in, the officer in 9 charge in the SHU unit got suspended for it. 10 MR. : Okay. 11 MR. : So, the rounds were made, 12 but they weren't within that 30 to 40 minute, 13 so the OIC got hit on that one. 14 MR. : And do you know why the 15 OIC? 16 MR. : I think the rounds, I think, 17 if I can recall correctly, I think when he 18 entered the round, about 40 minutes, but it 19 turned out it didn't jive with the camera. So 20 they suspended him. 21 MR. : All right. So, if the 22 time that he wrote on the paper didn't show -- 23 MR. : Didn't jive with the camera. 24 MR. : (Indiscernible 25 *00:27:38). EFTA00061100 41 1 MR. : Like, the reason, the camera 2 showed we were making rounds. We just didn't 3 make them between 30 and 40, that 30 minute, 4 not to exceed 40, I believe it just didn't jive 5 with the camera. 6 MR. : Okay. 7 MR. : And they hit him. 8 MR. : And were you actually 9 working in the SHU at the time? 10 MR. : I was in the SHU at the 11 time. 12 MR. : Okay. 13 MR. : I was one of the officers 14 that cut that inmate down and we tried to do 15 CPR on him. We did CPR on him. We got him 16 down to Medical, and then they rushed him out 17 in an ambulance. 18 MR. : And just out of 19 curiosity, in that case, at about what time was 20 he found? 21 MR. : Oh, that was, like, 3:30 22 something. 23 MR. : In the afternoon? 24 MR. : It was before the 4 p.m. 25 count. EFTA00061101 42 1 MR. : Okay. So it happened 2 actually in the afternoon? 3 MR. : Yeah. That was on day 4 shift. 5 MR. : Did he have a cellmate at 6 the time? 7 MR. : Yes, he did. 8 MR. : And the cellmate didn't 9 notice? 10 MR. : His cellmate said, yo, you 11 want to take care of this? 12 MR. : Oh, wow. 13 MR. : And he was strung up. 14 MR. : Was it also from, where 15 was it, where was he hanging from? 16 MR. : He had the thing tied up. 17 He was between the bunk and the window. 18 MR. : Okay. Was he attached to 19 the bunk or what was he attached to? 20 MR. : I think he was attached to 21 the window, if I recall. I honestly don't 22 remember. That was a long time ago. 23 MR. : Sure, sure, sure. 24 MR. : It was either the top of the 25 bunk or to the window. He was between, I do EFTA00061102 43 1 remember he was between the bunk and the 2 window. 3 MR. : But that's important to 4 note. So he actually had a cellmate at the 5 time? 6 MR. : Uh-huh. 7 MR. : And he still was able to 8 successfully - 9 MR. : Yes. 10 MR. : -- and it was deemed a 11 suicide, not a murder? 12 MR. : Yes. 13 MR. : Okay. 14 MR. : Cause his cellmate never got 15 charged. 16 MR. : And do you know what he 17 used to hang himself? 18 MR. : I believe it was cut-up 19 bedsheets. 20 MR. : Okay. 21 MR. : If I recall correctly. 22 MR. : All right. And that was 23 the 2001 or 24 MR. : That was 2003. 25 MR. : That was the 2003 one? EFTA00061103 44 1 MR. : I don't remember exactly the 2 dates or the stipulations on the one that 3 happened years later. 4 MR. : Do you happen to remember 5 the name of that inmate? 6 MR. : Of that committed suicide? 7 Edwards, I believe. 8 MR. : Edwards? 9 MR. : Yeah. 10 MR. : Okay. stated he 11 was on duty the night Epstein was brought to 12 MCC. He was received at the rear gate and 13 observed him being processed in." 14 MR. : Uh-huh. 15 MR. : "At the time of his 16 arrival, Epstein was deemed okay to go to 17 general population. was unaware of his 18 high profile." 19 MR. : Yes. I remember when he 20 came in. The only thing that I remember that 21 stuck out in my mind, he went to the same high 22 school that I did. 23 MR. : Okay. 24 MR. : I graduated from the same 25 high school. Cause the cop, I think he was an EFTA00061104 45 1 NYPD task force guy with the FBI, he was from 2 Brooklyn and we chatted, cause we had Brooklyn 3 accents, and come, you know, me and the cop 4 were from, like, basically, the same area in 5 Brooklyn, and he was, like, what high school 6 did you graduate from? And I said, Lafayette, 7 and Epstein actually said, so did I. I 8 graduated from Lafayette High School. 9 MR. : Interesting. 10 MR. : I processed him. Sent him 11 up. I actually found out that they moved him 12 to the Special Housing because of his profile 13 status when I came back to work. 14 MR. : So, you had no idea who 15 he was? 16 MR. : I had no idea who he was. 17 As a matter of fact, the next morning, my wife 18 actually said, you'll probably be getting him 19 soon. And showed me the phone, you know, the 20 news feed, and I said, soon? We got him last 21 night. Then I knew who he was. 22 MR. : Okay. 23 MR. : And then when I came, by the 24 time I came back to work, though, he was 25 already in SEC (Phonetic Sp. *00:30:35). EFTA00061105 46 1 MR. : Interesting. Okay. So, 2 it was just within 24 hours, he was moved from 3 general population to SHU? 4 MR. : I believe so. I believe, 5 less, I believe less than 48, definitely. 6 MR. : Okay. All right. 7 stated he knew Epstein to be in visits 8 often with his legal counsel." 9 MR. : Yes. 10 MR. : "Often until 7 to 8 p.m." 11 MR. : Yes. 12 MR. : "Other than the intake 13 questions Epstein answered on his arrival, 14 had no other personal interaction with 15 him." 16 MR. : No. 17 MR. : So you never just, you 18 never -- 19 MR. : Never chatted with him. I 20 would just escort him. Cause at one point in 21 time, a lieutenant had to move him. 22 MR. : Okay. And what about 23 when you would visit the SHU? Would you ever 24 check in on his cell or anything like that? 25 Would you ever look through the door or say, EFTA00061106 47 1 hey, what's up? 2 MR. : Right. When he was on, 3 like, when he would be on one tier, I remember, 4 I think, at one point in time, he was on H 5 tier, if I'm not mistaken. The only time I 6 would really see him on the tier is when I 7 would escort him. 8 MR. : And what would you, what 9 would be the purpose of escorting him? 10 MR. : Down to attorney conference, 11 for his legal visits. 12 MR. : Okay. So, would that be, 13 then, in the morning, you would do that? 14 MR. : It would be all day long. 15 He would get legal visits all day, into the 16 evening. 17 MR. : And he would be going 18 back and forth between the SHU? 19 MR. : Well, most of the time, he 20 would get brought downstairs and he would be 21 there for hours. 22 MR. : Right. 23 MR. : There would be times he 24 would be in legal visits through the count. 25 MR. : Yeah. EFTA00061107 48 1 MR. : The officers would have to 2 do the out count. 3 MR. : Yeah, so my understanding 4 was that he would basically be brought down 5 around 8 a.m. and stay until almost 8 p.m. Is 6 that -- 7 MR. : A lot of the times, he 8 would. 9 MR. : So not always, though? 10 MR. : Sometimes, he would go back 11 to SHU and then a different attorney would come 12 in and he would be brought back down in the 13 afternoon. 14 MR. : Oh, I see. 15 MR. : You know, he had legal 16 visits in and out of here all day long. 17 MR. : Okay. So, you talk about 18 when you would escort him, would be that kind 19 of middle timeframe? 20 MR. : Yeah. 21 MR. : So if he ever went back 22 to the SHU -- 23 MR. : Depending on what shift I 24 was on. 25 MR. : Okay. And when you were EFTA00061108 49 1 escorting him, would you communicate with him? 2 MR. : Basically, how are you 3 doing? All right. Well, I don't, I don't get 4 too chummy with inmates. 5 MR. : Sure. I would just, you 6 know, with Epstein, I'm assuming, it might 7 stand out in your little, you know, in your 8 head a little bit more. Do you know the last 9 time that you had escorted him or 10 (Indiscernible *00:32:35)? 11 MR. : I was about to escort him 12 the night before he died. 13 MR. : And what happened? 14 MR. : I was in the lieutenant's 15 office, and the attorney conference officer 16 said, hey, Lou, he's ready to go. But Mr. 17 Bullock was here, and Bullock was, like, Lou, I 18 will take him up. 19 MR. : Okay. 20 MR. : And he said, you know, by 21 the way, I'm going to take him up. I'm going 22 to give him a legal call. 23 MR. : Okay. 24 MR. : I was, like, okay. No 25 problem. Bullock is a GS-12, so. I was like, EFTA00061109 50 1 no problem. He was being escorted by a 2 supervisor, so I went back into the 3 lieutenant's office. 4 MR. 5 MR. 6 saw him. 7 MR. : All right. : And that was the last time I : So, Bullock is the one 8 who escorted him from attorney conferences on 9 August 9th? 10 MR. : Was it the 9th or 19th? 11 MR. : The 9th. So, August 9, 12 2019. 13 MR. : Okay. Yeah. That Friday 14 night. 15 MR. : He was found on August 16 10th. 17 MR. : The Friday night. 18 MR. : Right. Okay. 19 MR. : I forget the actual date. I 20 remember it being a Friday. I just forgot the 21 date. 22 MR. : And do you remember, 23 though, the last time you had interacted with 24 him? 25 MR. : No, I do not. I don't EFTA00061110 51 1 2 3 recall. MR. again, back to SHU, : No? Okay. And then when you would visit the 4 SHU and do a round, would you peek in on his 5 window or anything? Would you check with him 6 and say, everything -- 7 MR. : I mean, sometimes, his cell 8 was right over where the OIC desk was. 9 MR. : Right. 10 MR. : And I could look right into 11 his cell, and most of the time, I would see him 12 in it. 13 MR. : Okay. 14 MR. : And didn't interact with him 15 though. 16 MR. : But not actually check in 17 and say, are you good or anything like that? 18 MR. : No. If I was making a round 19 downrange, I would peek in. I would peek in 20 all the cells, if I'm downrange. 21 MR. : Right. 22 MR. : But not on a regular basis, 23 no. 24 MR. : Okay. stated he 25 was not involved officially in regard to EFTA00061111 52 1 Epstein's first alleged suicide attempt. His 2 only other involvement with Epstein was to 3 bring him food while in the SHU." 4 MR. : Yeah, if he was on G tier. 5 MR. : Okay. 6 MR. : Cause on G tier, the 7 lieutenants have to, have the key to the wicket 8 to be able to feed, but if he was on a regular 9 tier, no. There was times when, and when he 10 was a lieutenant hold, a lieutenant had to open 11 his, be there every time his slot was opened. 12 But he wasn't always on a lieutenant hold. 13 MR. : Can you explain that 14 more? Cause G tier is like the 10 South of the 15 SHU, right? 16 MR. : G tier is like a mini, it's 17 almost like 10 South. The inmates are self- 18 sustained in there. They have their own 19 shower. They have their own, you know, it's 20 basically, it's a bigger room. It's almost 21 like the 10 South rooms. But also the same 22 thing, the SHU lieutenant, or if the SHU 23 lieutenant, afterhours, there's no SHU 24 lieutenant, only a lieutenant can open those 25 (Indiscernible *00:34:50) boxes. The wickets. EFTA00061112 53 1 MR. : So, was Epstein ever on G 2 tier? 3 MR. : I don't recall. I don't 4 remember. 5 MR. : So what does this mean by 6 his only other involvement with Epstein was to 7 bring him food? 8 MR. : Food. When they're a 9 lieutenant hold, even if they're in a regular 10 SHU cell, a lieutenant has to be present to 11 open the slot. Even though the lieutenant 12 doesn't have to open it himself, the lieutenant 13 has to be there when the slot is opened. 14 MR. : So, anytime inmates are 15 served food in the SHU, a lieutenant has to be 16 present? 17 MR. : No. Not every inmate. Only 18 if the inmate is a lieutenant move. Like, if a 19 lieutenant has to be present, like, high 20 security. Like if they're assaultive. Inmates 21 could be put -- 22 MR. : So, was Epstein ever a 23 lieutenant move? 24 MR. : I'm not 100% sure. 25 MR. : So, that's where I'm just EFTA00061113 54 1 trying to get the accuracy of this thing, so 2 it's only -- 3 MR. : I don't, I don't remember. 4 That's the problem. I remember -- 5 MR. : So, do you remember ever 6 bringing Epstein food in the SHU? 7 MR. : I fed him before. But that 8 might have also been just because I happened to 9 be downrange. I can't recall if, I don't 10 recall if he was ever actually a lieutenant 11 hold. 12 MR. : Okay. 13 MR. : I remember he had to be 14 escorted from attorney conference. So that's 15 what, cause that's what -- 16 MR. : How would his feeding be 17 done, when he was in attorney conference? 18 Would they, would you feed him? 19 MR. : Sometimes, they would get a 20 bag lunch. And they would take it up with 21 them. 22 MR. : So, as in, like, when -- 23 MR. : I don't remember if he ever 24 ate in the attorney conference room, but he 25 wouldn't get the food from the food cart there. EFTA00061114 55 1 He would get, like, the bag lunch from R&D. 2 MR. : So, like, if he, when he 3 was escorted in the morning, they would give 4 him a bag lunch to bring into the attorney -- 5 MR. : Yeah. Well, like, they 6 have, sometimes, I believe, he would get, I'm 7 not sure, he could be escorted back to the 8 Special Housing to eat his meal. 9 MR. : Okay. 10 MR. : Use the restroom or 11 whatever, and go down, but they get to use the 12 restroom when they're in attorney conference, 13 anyway. 14 MR. : Okay. So you're not 15 exactly sure how he was fed, then? 16 MR. : Not down in attorney 17 conference, no. 18 MR. : Okay. Cause he was there 19 every day, right? 20 MR. : Yes. He was there pretty 21 much every day. 22 MR. : Okay. 23 MR. : That I recall. 24 MR. : All right. So, the food, 25 I'm assuming, would have taken place more at, EFTA00061115 56 1 like, what time, you know, when he would get, 2 return back at the 8 p.m. mark. Would that be 3 when he would be fed? 4 MR. : Well, he would, if he was 5 given the food in R&D, like, not R&D, the bag 6 lunches, he would have it given to him in 7 attorney conference and he would take it with 8 him. 9 MR. : Okay. 10 MR. : You know, if he was going to 11 eat past dinnertime, but also, a lot of the 12 times, too, if he was, like, not just him. Any 13 inmate. If they're downstairs, the officers 14 could also place the food in his cell, and he 15 could have the food when he comes back from 16 attorney conference. 17 MR. : Okay. So, they can go in 18 his cell ahead of time, put it in there, even 19 if he had a cellmate? 20 MR. : Yes. 21 MR. : Okay. And there was 22 never problems with, like, the other cellmate - 23 - 24 MR. : No. I mean, for the most 25 part, the inmates respect each other. EFTA00061116 57 1 MR. : Okay. stated he 2 was aware Epstein had been moved back to the 3 SHU, and that he was required to have a 4 roommate, per a mass email he had received." 5 MR. : Yeah. It went out to all 6 lieutenants. 7 MR. : So, you received an 8 email, saying that Epstein was required to have 9 a cellmate? 10 MR. : Yes. 11 MR. : Okay. And was that 12 requirement still in place on August 9, 2019? 13 MR. : I believe so. 14 MR. : Okay. stated he 15 did not have any conversations with anyone 16 regarding Epstein's need for a roommate, a 17 cellmate." So no one ever verbalized that to 18 you? 19 MR. : Just in the email. 20 MR. : Just the -- 21 MR. : And Psychology would let us 22 know. 23 MR. : Would Psychology actually 24 verbalize it? 25 MR. : I mean, basically, yeah. EFTA00061117 58 1 Like, for lack of, they would say that, you 2 know, not on a daily basis. They would just 3 say, any kind of, especially if they have had a 4 suicide attempt in the past, they get put on 5 what's called the hot list. Psychology threats 6 are always on the hot list. Inmates that are 7 on the hot list should always have a bunkie. 8 MR. : Okay. So, anybody on the 9 hot list gets a bunkie? 10 MR. : As long, if it's dictated in 11 there by Psychology. Psychology fills out the 12 hot list. 13 MR. : Right. 14 MR. : And it gets, they update it. 15 MR. : So, is Psychology's hot 16 list, is it just for the people that need 17 cellmates or is it also people that can't have 18 cellmates? What is the hot list? 19 MR. : What do you mean? Can or 20 can't? What do you mean? 21 MR. : Can't, cause aren't there 22 some people that have, like, you know, 23 (Indiscernible *00:38:34). 24 MR. : Separation, no, the hot list 25 doesn't pertain, the hot list is psychological. EFTA00061118 59 1 It's from Psychology. Psychology generates it. 2 MR. : So, if you're on the hot 3 list, everybody gets a cellmate? 4 MR. : Yeah. If it's annotated in 5 there. It will, every inmate's, in the hot 6 list, a picture of the inmate is in there. 7 That is, whether he or she is in for a Psych 8 study or a forensic study or what have you, and 9 it will say, you know, suicide attempts in the 10 past. Or cutter. Or what have you. 11 MR. : And where would that hot 12 list be? 13 MR. : The hot list is kept in SHU. 14 MR. : Where in the SHU? 15 MR. : It should be in a, either on 16 a clipboard or in a folder. 17 MR. : And do you know where it 18 was on August 9, 2019? 19 MR. : It should have been, I'm not 20 100% sure. I can't recall, but it should have 21 been on a clipboard on the hook. 22 MR. : And are the officers -- 23 MR. : By the officers' station. 24 MR. : Are the officers that are 25 in SHU required to look at that hot list? EFTA00061119 60 1 MR. : Yes. 2 MR. : All right. So, they 3 should know 4 MR. : They should be familiar with 5 who is on the hot list. 6 MR. : So, is everybody that 7 worked in the SHU, should have they known that 8 Epstein was required to have a cellmate? 9 MR. : Yes. 10 MR. : Is there any reason for 11 someone to say that they didn't know that 12 Epstein was required to have a cellmate? 13 MR. : Unless they weren't assigned 14 to the post and they were thrown in there on 15 overtime or mandated to work overtime and they 16 weren't familiar with it, that can happen. But 17 if you're steady, assigned to that post, you 18 should be familiar with the hot list. 19 MR. : Okay. And is there any 20 kind of requirement for people, like, overtime 21 that are, you know, not regularly working in 22 the SHU, to be either briefed on the hot list 23 or to review the hot list when they joined? 24 MR. : It all depends. Like, I 25 mean, a good SHU officer, worth his weight in EFTA00061120 61 1 salt, would at least talk the staff member 2 through it. But, like I said, there was plenty 3 of times where the entire SHU crew were all 4 overtimers. 5 MR. : Right. 6 MR. : So, nobody came to work. 7 MR. : Okay. 8 MR. : And a lot of the times, you 9 would have SHU crews, never mind just SHU 10 crews, institutional staff that would be 11 zombies, because they had been getting stuck 12 four days in a row. So a lot of the times, 13 things, you know, it's a lot to absorb. You 14 just, you're trying to do the job. 15 MR. : Okay. So, looking at the 16 August 9, 2019, roster, and I'm going to say 17 from the 8 a.m. hour on to the end of the day, 18 for the people that were working in the SHU, 19 can you tell me who you believe should have 20 known that he was required to have a cellmate? 21 MR. : For the day shift or the 22 evening shift? 23 MR. : Just from 8 a.m. on. 24 MR. : 8 a.m. on. All right. 25 Well, it looks, there was three officers, EFTA00061121 62 1 , and basically, is 6 to 2. 2 is a senior staff member. 3 (Phonetic Sp. *00:41:12) was a rookie. Officer 4 is a senior staff member. So, three out 5 of the four on the day shift. 6 MR. : So, you're saying 7 everybody but 8 MR. : Yeah. 9 MR. : -- should have known? 10 Okay. What about for the evening shift? 11 MR. : Evening shift? All right. 12 had a couple of years on the job. The 13 SHU floor was unassigned, because we were 14 short. There was only three officers. 15 is non-custody. So, would 16 not be super familiar with it, because he 17 worked warehouse. 18 MR. : Okay. 19 MR. : And he's with commissary. 20 MR. : Was he a -- 21 MR. was fairly new. She 22 had, maybe, just a little over a year on the 23 job. 24 MR. : But if was a regular 25 SHU person, that was her quarterly post, should EFTA00061122 63 1 she have known what the hot list was? 2 MR. : Yes. 3 MR. : And should have she known 4 that Epstein was required to have a cellmate? 5 MR. : Yes. You have to sign for 6 the hot, you have to sign that you reviewed the 7 hot list. 8 MR. : Oh, you do have to sign 9 that? 10 MR. : Yeah. Uh-huh. 11 MR. : All right. And who, when 12 do you sign that? 13 MR. : Last I checked, I don't, I 14 can't get quoted on this, cause I'm not 100% 15 certain. We would sign it a lot, like, well, 16 at least the lieutenants, would sign it when we 17 would do lieutenants meetings and meet with 18 Psychology and go, review the hot list, we 19 would all sign for it. 20 MR. : Now, I'm assuming the hot 21 list is ever-changing, correct? 22 MR. : Yes. Psychology always 23 updates it. 24 MR. : So, how often does the 25 hot list have to be signed? EFTA00061123 64 1 MR. : Every time it gets updated, 2 and they put a new one, it should be reviewed. 3 MR. : Okay. 4 MR. : And I don't, I honestly 5 haven't seen it in a while, cause now, my 6 contact with Special Housing is limited, now 7 that I'm a counselor. 8 MR. : Did you make that note? 9 MR. : Yeah. Can I ask a question 10 on that? 11 MR. : Yes. 12 MR. : What exactly are you signing? 13 MR. : That you reviewed the hot 14 list. 15 MR. : But, is that, like, a form or 16 is it on the copy -- 17 MR. : It's a sign-in sheet. 18 MR. : A sign-in sheet? 19 MR. : Yeah. 20 MR. : Okay. 21 MR. : And you know that 22 lieutenants had to, but do you believe the 23 officers had to sign the review of the hot 24 list? 25 MR. : I'm not 100% sure, but I EFTA00061124 65 1 know, as they have, they're require to review 2 the hot list. They should be familiar with 3 that hot list. Know who their psychological 4 inmates are, just as well as reviewing the 5 posted picture file. 6 MR. : Okay. 7 MR. : To know who your high 8 profile and your dangerous inmates are. 9 MR. : All right. So, at that 10 time, you being an Activities or in this case, 11 an Ops Lieutenant, would have you had to have 12 reviewed and signed the hot list in the SHU? 13 MR. : No, no, no. It's, I would 14 sign it here. Like I said, in the lieutenants 15 meetings, we would go over it with Psychology. 16 MR. : Sorry. I mean, the SHU 17 hot list, is what I mean. 18 MR. : No, that's the one that 19 would be there. The hot list is just generated 20 by Psychology. It's not like there's one for 21 SHU, one for the lieutenant's office, one for 22 here. It stays in SHU, but Psychology would 23 always make sure we familiarize ourselves with 24 it. 25 MR. : And is it only, is there EFTA00061125 66 1 only a hot list in SHU? 2 MR. : That I know of. 3 MR. : Okay. So, my question, 4 sorry, I probably was unclear, is at this time, 5 the SHU hot list, you being the Activities 6 Lieutenant, or, in this case, the Ops 7 Lieutenant on that specific date, August 9th, 8 would you have reviewed and signed that hot 9 list? 10 MR. : Not every day. 11 MR. : Yeah, yeah. But, like, 12 when it was -- 13 MR. : Generated, yes. 14 MR. : Right. So, point being, 15 like, if Epstein was on the hot list, you would 16 have signed and reviewed it? 17 MR. : Yes. Of course. I mean, 18 like I said, anybody at that point in time 19 should have known that he was going to be on 20 the hot list. 21 MR. : Okay. 22 MR. : Especially after the first 23 suicide attempt. 24 MR. : Okay. And do you think 25 anybody in the institution, with his high- EFTA00061126 67 1 profile nature and the fact that he had a first 2 suicide, suicide attempt, including these 3 people that you mentioned in the SHU, is there 4 any reason for anybody to say they didn't know 5 that Epstein was required to have a cellmate? 6 MR. : I don't know. 7 MR. : You don't know? 8 MR. : No. I mean, the people that 9 are assigned to SHU, but the problem is, if you 10 look, overtime. He wasn't assigned. Overtime. 11 She got assigned to that post, but it probably, 12 I don't believe it was her post for the 13 quarter. You know? I'm not, I don't, I can't 14 recall 100%. 15 MR. : But as far as, aren't 16 people that work in this facility, correctional 17 officers first? 18 MR. : Of course. Of course. 19 That's the thing. 20 MR. : And if they know that the 21 high-profile nature and the fact that he tried 22 to commit suicide, don't all officers pretty 23 much know, if you try to commit suicide, you're 24 required to have a cellmate? 25 MR. : Of course. EFTA00061127 68 1 MR. : So, shouldn't everyone 2 have known that he was required to have a 3 cellmate? 4 MR. : In that sense, yes. 5 MR. : All right. And 6 especially the fact that he is in the SHU, he 7 is, at the time, I think, your most high- 8 profile inmate. 9 MR. : Uh-huh. 10 MR. : Do you believe that they 11 should have known that he was required to have 12 a cellmate? 13 MR. : Yes. 14 MR. : Okay. stated 15 Lieutenant Rice was the SHU lieutenant. He 16 believed Lieutenant Rice would have known 17 Epstein required a roommate or a cellmate as it 18 is a regular responsibility. He believed 19 Lieutenant Rice would have enforced the 20 roommate rule. stated he had worked 21 the 2 p.m. to 10 p.m. shift on August 9, 2019. 22 He was relieved around 9:50 to 9:55 p.m. that 23 evening. He was not aware that Epstein did not 24 have a roommate." 25 MR. : No. EFTA00061128 69 1 MR. : "He did not know 2 Epstein's former roommate, had left MCC, 3 leaving Epstein without a roommate. 4 found out the following morning. He had been 5 working as Operations Lieutenant that evening. 6 R. had been working as Activities 7 Lieutenant. She had made the rounds." 8 All right, so on this, I'll guess we'll 9 just go one sentence at a time. So you didn't 10 know that day that had left the 11 institution, is what you said? 12 MR. : No. No. 13 MR. : Now, is that -- 14 MR. : I was unaware. 15 MR. : Now, is that something 16 that if he, if he had left, is that something 17 that you should have known? 18 MR. : No. What happens is, when 19 inmates go to court, and then they get released 20 or transferred out, they don't necessarily tell 21 us. Basically, what happens is then, the only 22 way we're going to know anybody moved is when 23 we do the PP30 at the end of the night. Right? 24 Just to, you know, write down who -- 25 MR. : Is it PP30 or 38? EFTA00061129 70 1 MR. : PP, I believe it might be a 2 38. I don't, off the top of my head, I don't 3 remember. I know it's the quarter's, the 4 movement roster. I haven't done it in a while. 5 MR. : Well, there's some of 6 those things we're going to review after 7 MR. : Yeah. But I know it's a 8 Sentry, it's got to be entered in Sentry, and 9 then basically, it gets transferred over to the 10 lieutenant's log. 11 MR. : Okay. 12 MR. : Right? At, you know, to 13 monitor what movement you had, just to make 14 sure your numbers jive with the institution 15 numbers at the end of each shift. 16 MR. : Okay. So, in this case, 17 do you believe someone should have, being that 18 it was Epstein, and Epstein's cellmate, 19 left the institution? Should someone have told 20 you this? 21 MR. : Should somebody have told me 22 directly? 23 MR. : Yeah, as the Ops 24 Lieutenant, you have Epstein, your most high- 25 profile. He is required to have a cellmate. EFTA00061130 71 1 , his cellmate, leaves the institution. 2 Should someone have notified you? 3 MR. : I would have liked to be 4 notified. 5 MR. : So, who should have 6 notified you that was -- 7 MR. : When he departed the 8 institution, somebody should have been 9 notified. Maybe not me, but somebody should 10 have known. 11 MR. : Okay. So, if he departed 12 the institution at 8:38 a.m., and he's listed 13 as pre-remove, removed off of the records, how 14 should have that went down? 15 MR. : If he was known to not come 16 back, then he should have had gotten a new 17 cellie. 18 MR. : Like right away? 19 MR. : As soon as humanly possible. 20 MR. : Okay. So, if people 21 claim that they didn't, they weren't, they 22 assumed he wasn't coming back, cause he went 23 With All Belongings. So, if someone goes With 24 All Belongings -- 25 MR. : WAB means With All EFTA00061131 72 1 Belongings. That means they're not coming 2 back. 3 MR. : And that's pretty much -- 4 MR. : Most of the time, they're 5 not coming back. There are occasions where 6 they cancel the bus, or they cancel the 7 transport or Air America, they will cancel, and 8 then they'll come back, but most of the time, 9 when they go WAB, that means they're going. 10 They're either going home or going to whatever 11 institution they're getting moved to. 12 MR. : Right. So, in this case, 13 if people know that leaves at 8:30, he's 14 moved down by the OIC from the SHU to R&D, WAB. 15 What should have happened at that point? 16 MR. : So, I would assume that 17 during the day, on a Friday, the lieutenant, 18 the SHU lieutenant is here. 19 MR. : So, if the SHU lieutenant 20 is actually off that day, no SHU lieutenant, 21 you got -- 22 MR. : A lieutenant should have, a 23 SHU, a supervisor should have been notified. 24 MR. : Okay. 25 MR. : And been like, hey, he don't EFTA00061132 73 1 have a bunkie no more. 2 MR. : Okay. And if that -- 3 MR. : And then it should be, you 4 know, then get him one. 5 MR. : All right. So, and if 6 the OIC, let's, for the benefit of the doubt, 7 OIC does inform one of the lieutenants, let's 8 say in this case, it looks like Activities was 9 And the Ops was 10 MR. : Uh-huh. 11 MR. : And no action is taken by 12 them. What would be the next thing that could 13 have happened with this, to make sure, you 14 know, Epstein, high-profile, doesn't have a 15 cellmate. What should have, how could this 16 catch up to itself? How could we rectify the 17 fact that Epstein was -- 18 MR. : Well, that's, then, if 19 nobody is notified, no one knows. 20 MR. : Right. So, would the 21 SHU, after is gone, the next, you 22 know, and his crew leaves and then the next SHU 23 crew comes in, should have they, then, said, 24 hey, isn't here. We're doing our rounds. 25 There's nobody in there. EFTA00061133 74 1 MR. : Uh-huh. 2 MR. : Should they have notified 3 the lieutenant? 4 MR. : I should have been notified. 5 MR. : And who should have you 6 been notified by? 7 MR. : At least the SHU crew. They 8 should have been, like, hey, this guy doesn't 9 have a cellmate. 10 MR. : If , the former Ops 11 Lieutenant, knows that, at the very least, 12 left the institution 13 MR. : Uh-huh. 14 MR. : -- possibly for court. 15 Maybe he doesn't know he's WAB, but he knows 16 that he left. Should he have notified you that 17 was -- 18 MR. : Well, if he had knowledge, 19 you know, that's part of taking over. You 20 know, the changeover. Hey, anything happen? 21 Anything I need to know? (Indiscernible 22 *00:51:00). 23 MR. : In this case, 24 knowing that, if he knew was Epstein's 25 cellmate, had left the institution, should have EFTA00061134 75 1 he notified you of that? 2 MR. : I mean, if he had direct 3 knowledge, possibly. Like, that's the thing. 4 It was, no one knew. 5 MR. : But, if he says he knew, 6 he knew that, well, let's say if says, 7 yeah, I knew left. I just wasn't certain 8 he wasn't coming back. 9 MR. : That's possible. 10 MR. : But should have he 11 notified you? 12 MR. : I should have known about 13 it. Whether or not it was from or from 14 the SHU crew, especially cause he was a hot 15 inmate. 16 MR. : Okay. So, either 17 or the SHU crew should have informed you? 18 MR. : Yes. 19 MR. : And no one informed you? 20 MR. : I wasn't informed. 21 MR. : Okay. 22 MR. : I found out the next day. 23 MR. : Right. What about, I 24 know your Activities Lieutenant, you said, is 25 the one who did the round, correct? EFTA00061135 76 1 MR. : Yes. 2 MR. : Should she have known, 3 is gone. Epstein is without a cellmate, 4 when she did her round? 5 MR. : If she found it. I don't 6 know, cause I wasn't there. 7 MR. : No, no, no. I'm saying, 8 should she have, should that be, like, when she 9 is doing her round in the SHU, is that 10 something that she should have recognized? 11 MR. : If she went downrange, 12 maybe. But if she didn't go downrange, and no 13 one told her, it would be the same ballpark. 14 No one told her. She is, you know, it's 15 unbeknownst to her. 16 MR. : When she went to the SHU, 17 should -- 18 (knocking on door) 19 MR. : -- we're in here. When 20 she went into the SHU, should the OIC crew, or 21 not the OIC, the SHU crew have told her, 22 is gone, Epstein is without a cellmate? 23 MR. : Possibly. Yeah. I mean, a 24 lieutenant is not going to know anything unless 25 the officers relay that information to the EFTA00061136 77 1 lieutenant. We're not superhuman. 2 MR. : So, if she did her 3 rounds, and again, you said that she is the one 4 who did the rounds, do you believe it was their 5 responsibility to say, hey, Activities 6 Lieutenant, just so you know, no one is in that 7 cell. is gone. Just want to give you 8 the heads up. Should that have happened? 9 MR. : Yes. 10 MR. : Okay. And then she would 11 have then informed you -- 12 MR. : Of course, listen, she would 13 have definitely notified me. She is, for the 14 lack of better terms, and I don't mean to use 15 profanity, she is a shit hot lieutenant. 16 MR. : Okay. 17 MR. : She is on her job. 18 MR. : Yep. 19 MR. : She would have definitely, 20 if she knew, she would have let me know. 21 MR. : Okay. 22 MR. : And we would have fixed it. 23 MR. : So, whoever was working 24 on her, on that shift, when she visited, should 25 certainly have informed her that was EFTA00061137 78 1 gone? 2 MR. : To my understanding, yes. 3 MR. : And never told you 4 as -- 5 MR. : No. I don't recall her 6 telling me. And like I said, just knowing her, 7 and her caliber, she would have told me. 8 MR. : Right. stated 9 if he had known Epstein did not have a 10 roommate, he would have ensured he did." 11 MR. : Yes. 12 MR. : "And he knew him to be on 13 the hot list." 14 MR. : Yes. 15 MR. stated the 16 following morning, August 10, 2019, at 17 approximately 6:30 to 6:45 a.m., he received a 18 call from Lieutenant Stanley informing 19 him that Epstein had attempted suicide and he 20 should go straight to the hospital, instead of 21 reporting to the jail for duty." 22 MR. : Yes. That's what I did, I 23 went straight to Hospital. 24 MR. : Okay. stated, 25 at the hospital, the escorting staff informed EFTA00061138 79 1 him that Epstein had passed away." 2 MR. : Yes. 3 MR. : "He saw his body and told 4 his officers not to speak to anyone and direct 5 any questions to the prison public relations 6 officer." 7 MR. : Yes. 8 MR. : Do you know who that was 9 at the time? 10 MR. : It's usually the Executive 11 Assistant, so it should have been III 12 MR. : Okay. So, Ill 13 MR. -: is the public -- 14 MR. : Yeah. "He said the same 15 to the hospital security." 16 MR. : Yes. 17 MR. : Okay. So that was not 18 people that were BOP, but the hospital -- 19 MR. : No, yeah. There was 20 hospital security around the room, too, and I 21 was, like, no one goes in here unless it's 22 hospital staff or Bureau staff. 23 MR. : Okay. stated 24 officers-, (Phonetic Sp. *00:54:46) S. 25 , and were on-scene at the EFTA00061139 80 1 hospital." 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. : Yes. MR. : Now, were they people that escorted Epstein to the hospital? MR. : That's what I believe, yeah. They had to be, because, like I said, I was on my way to the hospital. I went straight to the hospital. I believe those were the three staff members that they got to be the escorting staff. MR. : Okay. Now, as far as Epstein going to the hospital, do you know when he actually was deceased? MR. : I remember, my mission at that point, Lieutenant had told me, go straight to the hospital, tell the officers, you know, keep the area secure and record time of death. I think the hospital told me it was, like, 7 something. I don't recall the actual time, and then I called Lieutenant and gave him that time, and then he was, like, all right. We already got it. Bring yourself back to the institution. MR. : So, do you know if, prior 25 to that time, he had shown any signs of life? EFTA00061140 81 1 MR. : No. I am unaware. No. 2 MR. : Okay. So did anyone 3 mention to you or state to you, he died 4 actually at the prison? 5 MR. : No. 6 MR. : They just pronounced him 7 dead there? 8 MR. : They told me they pronounced 9 him dead. I don't remember the actual time. 10 It was 7 something, which was the time of death 11 that the hospital recorded. 12 MR. : Okay. 13 MR. : And that's what I relayed 14 back to Lieutenant and then he said, all 15 right, we got it already. Come to the 16 institution. And then I left the hospital. 17 MR. : Do you believe that when 18 he was found at the BOP institution, he was 19 actually dead on scene? 20 MR. : I don't, I don't know. I 21 can't, I can't answer yes or no. 22 MR. : Okay. 23 MR. : I just know, when I saw his 24 body in the thing here, the intubation tube in 25 his neck and down his throat, and it looked EFTA00061141 82 1 like they were working on him. 2 MR. : And they were still 3 working on him? 4 MR. : No, no, no. They had worked 5 on him. 6 MR. : Okay. 7 MR. : He was already deceased, but 8 he still had the intubation tube down his 9 throat. 10 MR. : Okay. stated he 11 had not taken any photographs of Epstein's body 12 and advised his officers to stay with the body 13 until they could be relieved." 14 MR. : Yes. 15 MR. -: stated, back at 16 the prison, he resumed his activities as 17 lieutenant and was guided to collect log books 18 and escort FBI agents as part of the death 19 investigation." 20 MR. : Yes. 21 MR. : Were any OIG there at the 22 time? 23 MR. : Not that I know of. There 24 were so many agents and people coming in and 25 out, taking computers, I don't, I could have EFTA00061142 83 1 been escorting OIG and I didn't even know. 2 MR. : Sure. 3 MR. : Basically, Captain 4 just made me go along and go and try, assist in 5 any way I could, anytime, any documents they 6 needed or whatever. That's what I did. 7 MR. : Sure. 8 MR. : Pretty much the rest of the 9 day. 10 MR. : Okay. stated he 11 was not aware of the destruction of any 12 records." 13 MR. : No. 14 MR. • ' stated he knew 15 Officer Thomas for a few years and knew Officer 16 Noel as a newer officer, but had no personal 17 relationship with either." 18 MR. : No. 19 MR. : All right. Cool. 20 Anything that they missed or failed to capture? 21 MR. : No. I was being refreshed, 22 as you were reading it. 23 MR. : And that's for future, is 24 what I'm talking about. 25 MR. : Okay. EFTA00061143 84 1 MR. : All right. Great. So 2 now, so, everything seemed accurate, as far as 3 this was written? 4 MR. : Yes. 5 MR. : Okay. Perfect. 6 MR. : I just have a couple of 7 follow-ups. 8 MR. : Yep. Please. Go ahead. 9 MR. : You mentioned round sheets. 10 Do you recall if here, at the MCC, in the SHU, 11 the round sheets are kept at the end of each 12 tier? Or are they kept on the desk? 13 MR. : They're supposed to be kept 14 at the end of each range. 15 MR. : So, as a lieutenant, at that 16 point, when you made your, if you had made your 17 rounds -- 18 MR. : If I have seen the sheets on 19 the desk, I would always tell the officers they 20 need to be downrange, not on your desk. 21 MR. : Okay. 22 MR. : And I would not initial 23 them, unless they were, I wouldn't initial them 24 unless they were accurate. 25 MR. : Okay. EFTA00061144 85 1 MR. : Uh-huh. 2 MR. : So, on that note, then, 3 when you would go into sign that document, 4 would you always go downrange to grab it? 5 MR. : No. There was times where I 6 would see it on the desk and I would be, like, 7 these need to be downrange. 8 MR. : So, you're, when you walk 9 into the SHU, you are supposed to walk 10 downrange to do -- 11 MR. : To sign it. 12 MR. : -- to sign it there? 13 MR. : Uh-huh. 14 MR. : But oftentimes, that 15 would -- 16 MR. : As of late, as of late, that 17 is where they are now. It all depends on what 18 shift, because the morning watch lieutenant, 19 the overnight lieutenant, has those sheets 20 already sent down to that person. 21 MR. : Uh-huh. 22 MR. : In the thing, but you still 23 have to go up and sign the round sheets anyway. 24 Every shift, those round sheets have to be 25 signed. Cause you have to ensure that the EFTA00061145 86 1 officers are doing their rounds. 2 MR. : So, when did her 3 round on August 9, 2019, should she have had to 4 have gone downrange, especially on the range 5 that Epstein was on? 6 MR. : If the round sheets were 7 downrange. 8 MR. : Right. And that's where 9 they are supposed to be? 10 MR. : Like they're supposed to be. 11 MR. : Okay. And if they 12 weren't, she should have notified SHU. Hey, 13 you guys got to be keeping these down here? 14 MR. : Yes. 15 MR. : All right. And is the 16 purpose of that, though, to ensure that people 17 are doing rounds and that's where it, when they 18 sign that? 19 MR. : Well, that's where they're 20 supposed to be, for the sake of the officers, 21 that's, it's to prevent fudging the round 22 sheets. 23 MR. : Right. 24 MR. : You know, if they're down on 25 the desk, and you can just write whatever you EFTA00061146 87 1 want, for lack of better terms. Look, I'm 2 (Indiscernible *00:59:40) I'll call a spade a 3 space. Right? If somebody is going to fudge 4 around, it's easier for them to do it that way. 5 MR. : Uh-huh. 6 MR. : Then if it's downrange. If 7 it's downrange, you have to go downrange. 8 MR. : Right. 9 MR. : So, you're going to look in 10 each cell and then when you get to the end of 11 that tier, that's when you scribble your time. 12 That's why it's easier for that round sheet and 13 that camera to jive. 14 MR. : Uh-huh. 15 MR. : Cause they're downrange. 16 MR. : Okay. Sorry. 17 MR. : Sorry. 18 MR. : No, no. And the point of the 19 lieutenant signing it is not that the 20 lieutenant did the rounds -- 21 MR. : It's to make sure that the 22 officers are doing what they're supposed to be. 23 MR. : Okay. Do you recall any 24 special instructions coming down from the 25 Warden or the Captain, regarding Epstein? EFTA00061147 88 1 MR. : Nothing as far as, like, 2 that he was high-profile. You know. 3 MR. : What was the, you mentioned 4 instructions from Psychology, right? 5 MR. : Uh-huh. Which were 6 basically the same, like, you know, he needs a 7 bunkie. He is high-profile. 8 MR. : But there was no 9 instructions, like you are never, as a 10 lieutenant, there was no special instructions 11 (Indiscernible *01:00:36). 12 MR. : If he was a lieutenant move, 13 our instructions were a lieutenant has to be 14 present when he moved. So, a lieutenant has to 15 escort him, that I recall. 16 MR. : That email you mentioned that 17 you got. Who was that from? The mass email? 18 MR. : I believe it was from the 19 Captain. 20 MR. : We're going to go through 21 all that. 22 MR. : Or Correctional Services. 23 I'm not, I'm not exactly sure who sent that 24 out. 25 MR. : Okay. EFTA00061148 89 1 MR. : It would be generated from 2 all the department heads. 3 MR. : Okay. That's it. That's all 4 I had. 5 MR. : Okay. But you're 6 familiar with the SHU, correct? 7 MR. : Yes. Yes. 8 MR. : (Indiscernible *01:01:15) 9 all right. Great. Looking at this camera 10 angle, this is a still shot. Can you tell me 11 what it is that we're looking at here? 12 MR. : This is the camera that's up 13 in, on the upper tier, by the 46 door, which is 14 going into 10 South. This camera view right 15 here is of the multipurpose area. These stairs 16 right here, that you can barely make out, this 17 would be G tier. 18 MR. : Okay. 19 MR. : H tier. J, K tier down 20 there. You can't see L and M. This little 21 shadow right here is the pipe, but that's about 22 all you can see of L tier. And then M tier is 23 down those steps, and that's the OIC's station. 24 MR. : So, from this camera 25 angle, this, if Epstein is in L tier, would you EFTA00061149 90 1 be able to see if people were going up and down 2 L tier, from this camera angle? 3 MR. : You would be able to see a 4 quick movement, but not the full, cause you 5 can't see the steps. 6 MR. : Is there a way for them, 7 over this way, to like, go over here and go up 8 here without you seeing them come up, or is 9 this so close -- 10 MR. : No, no, no. This is 11 totally, this is elevated. This area right 12 here, this is a staircase door. 13 MR. : Okay. 14 MR. : This is an elevated 15 position. You can't, this camera would see 16 staff coming up. 17 MR. : Oh, but as far as this 18 angle, though, could you, could you, if anybody 19 was going up and down L tier -- 20 MR. : And if anybody was coming 21 this way 22 MR. : -- could you tell that 23 from here? 24 MR. and going up, you would 25 be able to, like I said, you would be able to EFTA00061150 91 1 see a flash of movement, but you really 2 wouldn't be able to see, judging from the way 3 this picture is, you really wouldn't be able to 4 see much of the actual step climbing. 5 MR. : Okay. But could anybody 6 get up to L tier without you seeing from this 7 angle in the SHU? 8 MR. : Well, you would see them go 9 this way. But whether or not they were walking 10 towards the kitchen or going up to L tier would 11 be hard to distinguish, just from looking at 12 this. If the camera were there -- 13 MR. : So, is this a blind spot? 14 Could someone come from this way and go up L 15 tier without you seeing? 16 MR. : Yes. Yeah. Without a 17 doubt. 18 MR. : Okay. 19 MR. : From, you could come from 20 straight outside and then go up. 21 MR. : All right. And what, 22 this staircase that is clearly visible, this is 23 the officer's station, right? 24 MR. : Yes. 25 MR. : And right to the left of EFTA00061151 92 1 the officer's station, what is that staircase 2 going to? 3 MR. : That's going to J tier. 4 MR. : Okay. Awesome. Can you, 5 on this SHU map, so this first page is the 6 first tier. 7 MR. : Wait. Which, first tier? 8 MR. : So, this is the, we have 9 the SHU layout. It's not perfect, but this is 10 what was provided to us. 11 MR. : Yeah. Cause I'm trying to, 12 all right, so -- 13 MR. : So, this is, like, for 14 instance, you know, you will see the first 15 letter is what the, so this is G tier. It 16 looks like this is M tier. And the second one, 17 over here, this is the second floor, this is my 18 understanding. Here's J, L. 19 MR. : I can barely see it. 20 MR. : Yeah. Maybe that's G. I 21 don't know. 22 MR. : May I? 23 MR. : Absolutely. This is, so, 24 what I'm going to ask you to do is, from 25 looking at this -- EFTA00061152 93 1 MR. : J. Okay. There it is. J. 2 MR. : -- keeping in mind where 3 the officers' station is 4 MR. : And this is L. Okay. 5 MR. : -- and where this is, can 6 you kind of point to me, can you put the 7 location of where this camera is on here? 8 MR. : Oh, shit. 9 MR. : Looking down? 10 MR. : Recreation. 11 MR. : So, if you're looking at 12 -- 13 MR. : It would be up here. 14 MR. : Right. So, like, the 15 angle, like, you can put a circle, and I'm 16 pointing towards, so I guess put a big circle 17 where the officers' station would be. 18 MR. : All right. This is J tier. 19 That's right there. And there's the wall, 20 right there, so, right there, this is L tier, 21 going up and M would be down, yeah. That's 22 right. So, this is basically where the -- 23 MR. : So then you can put OC in 24 the middle. 25 MR. : OIC. EFTA00061153 94 1 MR. : For OIC, perfect. And 2 then, so, if you're looking straight at this, 3 this is that, can you put a star next to 4 whatever, whatever staircase you're looking at 5 in this video? 6 MR. : Okay. This is J tier, right 7 here. 8 MR. : J tier. All right. 9 MR. : J. And this is M. 10 MR. : Okay. 11 MR. : I'm assuming that's the one 12 going down. 13 MR. : Okay. Great. And then 14 as far as, this is what you're looking at, 15 right here, where would you believe the camera 16 would be? 17 MR. : Judging from the way this 18 is, it looks like the camera is panning from, 19 like, here. That way. 20 MR. : Oh, right. So, if this 21 is, this is G tier 22 MR. : G. 23 MR. : -- right, so, would it 24 be, like, kind of over here? 25 MR. : Here's the, this is the EFTA00061154 95 1 lieutenant's office up there. That's here, in 2 the corner. And I think the camera is above 3 the lieutenant's office. 4 MR. : Okay. 5 MR. : So, maybe like right here, 6 maybe? I'm not 100% certain. But it should 7 be, it's somewhere over here, the camera and 8 the camera pans that way. 9 MR. : Can you just put a star 10 there and in that open spot next to it, just 11 write camera? All right. Perfect. Do you 12 mind just initialing and dating that? And then 13 we're also -- 14 MR. : Eight, today is the 4th, 15 cause it's my daughter's birthday. 16 MR. : Oh, is it? Happy 17 Birthday. 18 MR. : Twenty-one. 19 MR. : How old? 20 MR. : Twenty-one. 21 MR. : Oh, wow. Can you initial 22 and date that, that we're looking -- 23 MR. : Sure. Date it, too? 24 MR. : Yes, please. All right. 25 So, all right. Thank you. That confirms what EFTA00061155 96 1 this is, thank you. And this is someone else's 2 drawing. I just want to see, this kind of 3 (Indiscernible *01:06:32) this is actually what 4 we said here. Yeah, so it looks like, and this 5 is everything. Cool. Now, was there, you 6 said, you mentioned a bulletin board that had 7 the hot list? Where would that be? 8 MR. : Well, I can't, right here, 9 it's hard to tell from that, but usually, the 10 hot list should be somewhere right up there on 11 the hook. 12 MR. : Okay, so this is the 13 bulletin board here? 14 MR. : Yeah. And there's also, 15 now, I don't, not then, but there was, there's, 16 there was stuff up here, but not, I don't 17 believe it was a bulletin board. It's a 18 bulletin board now, if you go up there. 19 MR. : All right. 20 MR. : But there was, the hot list 21 used to be right there. It should have been 22 right there, by where the phone was. 23 MR. : All right. So, I'm going 24 to write above it, B board. So this is where 25 the bulletin board was? EFTA00061156 97 1 MR. : Yeah. 2 MR. : And you believe the hot 3 list would have been on that, is what you're 4 saying? 5 MR. : Yes. 6 MR. : And this was, you said J 7 tier? 8 MR. : That was, those are the 9 steps going up to J tier. 10 MR. : So I'm going to write J 11 right here with an arrow going up. 12 MR. : Uh-huh. And K tier would be 13 the one going down. 14 MR. : And is that going down 15 here? 16 MR. : Yeah. 17 MR. : Or over that way? 18 MR. : No. Down that way. There, 19 to the left. 20 MR. : Okay. But J was going 21 up? 22 MR. : Yes. 23 MR. : All right. And then I'm 24 going to write up here, L tier would have been 25 right here, going up? EFTA00061157 98 1 MR. : Yes. 2 MR. : All right. So that's all 3 accurate? 4 MR. Yep. 5 MR. : Perfect. Okay. So, you 6 said that this one also checked out, this looks 7 exactly the same as where you were. Oh, do you 8 know where Epstein was located? 9 MR. : He was on L tier. 10 MR. : And do you know where, 11 like, in looking at this, where his -- 12 MR. : It should be right there. 13 MR. : That one? Can you put a, 14 I don't know, a box in there, I guess, and put, 15 yeah, JE or something there? 16 MR. : JE. 17 MR. : Perfect. Thanks. 18 MR. : His cell could look right 19 down onto the OIC desk. If he looked outside 20 his window -- 21 MR. : So he could see? 22 MR. : -- he could look right down 23 at the officers. 24 MR. : Okay. And you already 25 initialed and dated this. Great. So, if EFTA00061158 99 1 you're looking at this photo, is this a photo 2 of L tier, going up? 3 MR. : Yep. 4 MR. : And would he be over 5 here? 6 MR. : He would be the first cell, 7 right, in this corner most, right here, is the 8 shower. But right next to the shower is the 9 first cell. 10 MR. : So if you're walking up 11 the tier, you open the door, he's right to the 12 right? 13 MR. : He's going to be the first 14 cell to the right. 15 MR. : The first cell to the 16 right. Okay. And I know you can't really make 17 out this. Do you have any reason to believe 18 that wouldn't be his cell? 19 MR. : Well, I can't even make out 20 the number. 21 MR. : Right. And then, you 22 know, this is the tier. This is L tier, going 23 down. Is this a camera, right here? 24 MR. : Yes. 25 MR. : Is this camera supposed EFTA00061159 100 1 to be recording everything going on here? 2 MR. : That's supposed to be 3 recording everything, facing this way. So, 4 like, it would see you walk, it would see, if 5 this is me, first person, coming up this way, 6 it would film everything from the grill back to 7 where it is. 8 MR. : And is this where the 9 round sheet is supposed to be located? 10 MR. : Yes. 11 MR. : Is there, do you even see 12 anything, where it could be? 13 MR. : It might be that speck 14 right, no, that's too high. It might be, there 15 might be a little hole, I can't tell. 16 MR. : But that's where it's 17 supposed to be located? 18 MR. : Yeah. At the end of the 19 MR. : Right underneath the 20 camera? 21 MR. : No. I'm sorry. They had 22 gotten moved. I believe that right now, 23 they're down there, but they might, I think 24 they were on the wall here, at the beginning of 25 the tier or on the other side. I'm not 100% EFTA00061160 101 1 certain. 2 MR. : Okay. So, back then, 3 they wouldn't have been at the end of the hall? 4 They were probably at the beginning of the 5 tier? 6 MR. : I know at one point in time, 7 they were, the clipboard was being rested on 8 that coax pipe. 9 MR. : Would this be underneath 10 L tier, or would that be where it would be? 11 MR. : No. It's always on the 12 inside of the range. 13 MR. : Always on the inside? 14 Okay. 15 MR. : Yeah. 16 MR. : So it would have been 17 after you opened the range door, but not at the 18 end of the hall at that time? 19 MR. : I know I, like I said, at 20 one point, they had it on the wall to the side, 21 but at one point in time, they were putting the 22 clipboard, they were just resting it on that 23 pipe. 24 MR. : Okay. 25 MR. : As long as it was downrange, EFTA00061161 102 1 it needed to be downrange. 2 MR. : So, even at that time, it 3 was supposed to be downrange? 4 MR. : They always have to be 5 downrange. 6 MR. : Okay. 7 MR. : Yes. 8 MR. : Per BOP policy? 9 MR. : Yes. 10 MR. : Okay. And this is just, 11 so, we had to review a lot of emails and I see, 12 this one, I think, was directed to you. It 13 says, "BOP official legal hold notice for 14 inmate's death." What was your, was your 15 understanding of that not to destroy any 16 documents? 17 MR. : Yes. 18 MR. : All right. Did you 19 destroy any documents? 20 MR. : No. Not at all. 21 MR. : So you still have all 22 your emails from then and everything? 23 MR. : I don't have anything. 24 Like, I know the AUSA had my memo. I don't 25 even have a copy of my memo. EFTA00061162 103 1 MR. : Okay. 2 MR. : And I don't, I didn't tear 3 up anything. 4 MR. : Perfect. 5 MR. : And I've been getting these 6 periodically from you guys. 7 MR. : Oh, you still do? Okay. 8 MR. : Yeah. 9 MR. : Do you still have, like, 10 all the emails from back then and everything? 11 MR. : No. I mean, anything that I 12 had, I either just closed out of, but the thing 13 is, I didn't, I don't even remember having any 14 direct emails. All the official emails, like, 15 I, like, sent them to my trash bin, like even 16 these, I mean, this was just telling me not to 17 destroy anything, and I didn't destroy 18 anything. 19 MR. : Okay. 20 MR. : So, I didn't save these. 21 MR. : Okay. But as far as, so, 22 did you understand, like, as far as if you 23 received an email pertaining to Epstein, were 24 you supposed to save that, or could have you 25 deleted that? EFTA00061163 104 1 MR. : What do you mean? In, like, 2 as far as from staff? 3 MR. : Yeah, like, for instance, 4 this is another one that, I think this is the 5 email that you would have received, regarding 6 Epstein being required to have a cellmate from 7 July 30, 2019? 8 MR. : Oh, yeah, yeah. No, these, 9 I would get them and delete them. 10 MR. : All right. So you would 11 delete those? 12 MR. : Yeah. And as long as I 13 knew, you know, that was it. 14 MR. : So, you didn't 15 understand, like, this to mean, like, not to 16 delete anything pertaining to Epstein? 17 MR. : No, but the thing is, at 18 least I never got anything like this, after it 19 happened. 20 MR. : Yeah, yeah, yeah. I'm 21 talking about, like, prior to, I think that 22 this is asking you to save anything that was 23 related to Epstein, correct? 24 MR. : Yeah, no. I get what that, 25 you know, that, I didn't think that that was EFTA00061164 105 1 what it meant. Like these. These were just 2 routine things. I thought it meant -- 3 MR. : Okay. Well, that came 4 from yours. So, you didn't, I was able to get 5 it, at least 6 MR. : Okay. 7 MR. : You may have deleted it, 8 but my point being is, like -- 9 MR. : Uh-huh. Well, I 10 misunderstood, maybe. I'm thinking destroying 11 means shredding. 12 MR. : But if you received an 13 email pertaining to Epstein, you thought you 14 could delete it? 15 MR. : Yeah. I guess so. 16 MR. : Right. Fair enough. 17 MR. : There's, like, stuff like 18 this, if it's sitting in my trash bin. I don't 19 always empty my trash. I mean, anybody in the 20 Bureau could pull those emails anyway. 21 MR. : Okay. Let me see how -- 22 MR. : Yeah, I thought it meant, 23 like, physically, like, destroying stuff. 24 Like, I wish I could even have a copy of my 25 memo, but AUSA has it. EFTA00061165 106 1 MR. : Cause, like, for 2 instance, this says, "Please preserve all 3 electronic files; example, emails or 4 documents." 5 MR. : Right. I missed, I totally 6 misunderstood. 7 MR. : All right. So, you 8 misunderstood that? 9 MR. : Yeah. 10 MR. : Okay. 11 MR. : I wouldn't do it 12 maliciously. 13 MR. : Yeah, yeah, yeah. No, 14 and that's what I wanted to know -- 15 MR. : Uh-huh. 16 MR. : -- cause a lot of people 17 got this, so you're the first person I'm even 18 asking about this. 19 MR. : Uh-huh. 20 MR. : So I was just curious, 21 it's like, what is your understanding. So, did 22 you not know 23 MR. : Yeah. I thought it meant, 24 actually, like, physically, like, destroying 25 things, like, you know, in the shredder. EFTA00061166 107 1 MR. : Right. All right. So, 2 yeah. So you didn't actually read it, I'm 3 assuming, like, where it says emails? That's 4 the first thing it says. 5 MR. : I probably mis, no, like, I 6 remember the first one I received, I called the 7 staff attorney. I was, like, what does this 8 mean? And he was like, just that you're still, 9 it's still active. 10 MR. : Okay. Would you mind, 11 just, anything we talk to you, it's just 12 initialing and dating. 13 MR. : Yeah. No problem. 14 MR. : It's just to say what it 15 is what we looked at and talked about. 16 MR. : Uh-huh. 17 MR. : And you already 18 mentioned, you remember receiving this email 19 from Psychology -- 20 MR. : Yeah. 21 MR. : from 22 23 MR. : Yeah. Dr. 24 MR. : Yeah. 25 MR. : Yeah. EFTA00061167 108 1 MR. : Saying that he was 2 required to have a cellmate? 3 MR. : Have a cellmate. 4 MR. : So you do remember that? 5 Okay, great. 6 MR. : Uh-huh. 7 MR. : And you knew he was 8 required to have a cellmate? 9 MR. : Yes. 10 MR. : Do you mind just 11 initialing and dating that? 12 MR. : Sure. 13 MR. : Was that the same email that 14 you mentioned before? Cause you mentioned that 15 there was an email from Captain 16 MR. : I believe there was one, as 17 far as when he, anytime he would be put as a 18 lieutenant hold. This is the one I was talking 19 about, like, Psychology would send out that, 20 about having the cellmate. 21 MR. : Oh. 22 MR. : Thank you, sir. Now, as 23 far as this, you said no one told you. So, 24 this is a memo from, at the time, SOS 25 MR. : Uh-huh. EFTA00061168 109 1 MR. . It 2 says, "Past information from Special Housing 3 Unit." It says, "On Friday, August 9, 2019, at 4 approximately 1:50 p.m., I, SOS 5 passed on to oncoming staff member, Officer 6 and present shift staff, SOS and 7 Officer , that inmate was going WAB 8 and possibly may not return. Also that inmate 9 Epstein will be needing a cellmate upon arrival 10 from his attorney visit." Did you know 11 anything about that? 12 MR. : No. 13 MR. : Is this the first you're 14 seeing of this memo? 15 MR. : That's the first I'm seeing 16 of it. 17 MR. : All right. So, a couple 18 things. First, if passed on to these 19 people and those are the people that worked on 20 your shift? 21 MR. : Yeah. Yes. Right here. 22 No, wait. What does it say? No, 23 was day shift. was day shift. 24 is the only one. 25 MR. : Okay. So, oncoming staff EFTA00061169 110 1 2 members , and Officer , so let's see. When would have been working 3 on this, like, what -- 4 MR. : 2 to 10. 5 MR. : So, would have been 6 2 to 10. 7 MR. : Uh-huh. 8 MR. : And the present ones were 9 When would he have been working? 10 MR. : 8 to 4. 11 MR. : And 12 MR. : 8 to 4. 13 MR. : All right. So, I think 14 would have only been working as 15 MR. : Till 2:00. 16 MR. : 2:00. So, if he told, 17 before he left, 2:00, , and 18 19 MR. -: 20 MR. : Right. Should any of 21 those people have notified either you or 22 , that he was, that was gone and -- 23 MR. : Yes. 24 MR. : Yes? Okay. And nobody 25 did? EFTA00061170 111 1 MR. : I wasn't told. Like I said, 2 I found out the day after it happened. Well, 3 the day that it happened, when I came in. 4 MR. : Now, on the second note 5 of this, if knew that was WAB, 6 should have he ensured that he got a cellmate 7 prior to his departure, at 1:50 p.m.? So, if 8 left at 8:38 a.m., WAB, into R&D, he's 9 keyed out of the system. Should a new cellmate 10 have been assigned to Epstein, even prior to 11 leaving? 12 MR. : It would have been prudent 13 to do it as soon as possible. 14 MR. : Okay. So, should 15 have then notified any, you know, 16 , and it looks like , during his 17 shift, that, hey, we need to get Epstein a new