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efta-efta00064194DOJ Data Set 9Other

APPEARANCES:

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EFTA 00064194
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1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: BY: DIGITALLY RECORDED WITNESS: SWORN STATEMENT OF OTHER APPEARANCES: OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL SEPTEMBER 29, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 NONE 3 4 1 MR. The recorder has started. 1 wain, I am DOJ/OIC Senior Special Agent, 2 My name is , and I am a Senior 2 3 Special Agent with the U.S. Department of 3 : I am Assistant Special Agent- 4 Justice, Office of the Inspector General, New 4 in-Charge, . . 5 York Field Office, and these are my 5 MR. • 6 credentials. 6 Electronics tech. Bureau of Prisons. . 7 MR. : Okay. I see them. 7 . 8 MR. : This interview with 8 MR. : This is Special Agent 9 Federal Bureau of Prisons employee, 9 10 is being conducted as part of an 10 MR. All right. Thank you. 11 official U.S. Department of Justice, Office of 11

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1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: BY: DIGITALLY RECORDED WITNESS: SWORN STATEMENT OF OTHER APPEARANCES: OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL SEPTEMBER 29, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 NONE 3 4 1 MR. The recorder has started. 1 wain, I am DOJ/OIC Senior Special Agent, 2 My name is , and I am a Senior 2 3 Special Agent with the U.S. Department of 3 : I am Assistant Special Agent- 4 Justice, Office of the Inspector General, New 4 in-Charge, . . 5 York Field Office, and these are my 5 MR. 6 credentials. 6 Electronics tech. Bureau of Prisons. . 7 MR. : Okay. I see them. 7 . 8 MR. : This interview with 8 MR. : This is Special Agent 9 Federal Bureau of Prisons employee, 9 10 is being conducted as part of an 10 MR. All right. Thank you. 11 official U.S. Department of Justice, Office of 11 This is an official DOJ/OIG investigation into 12 the Inspector General, or DOJ/OIG 12 the death of inmate Jeffrey Epstein, and the 13 investigation. Today's date is September 29th, 13 surrounding circumstances, and you are being 14 2021. And the time is 8:16 a.m. This 14 asked to voluntarily provide answers to our 15 interview is being conducted at the OIG New 15 questions. Will you agree to a voluntary 16 York Field Office, located at 1 Battery Park 16 interview with the DOJ/OIG? 17 Plaza, New York, New York. Also present is 17 MR. : Yes. 18 DOJ/OIG ASAC or Assistant Special Agent-in- 18 MR. : Thank you, sir. So, this 19 Charge, . He is in person. And 19 is the official Warnings and Assurances to 20 Special Agent is joining us by 20 Employees Requested to Provide Information on a 21 22 telephone. He is also with the DOJ/OIG. This interview will be recorded b me, Senior 21 22 Voluntary Basis. And in this line, I'm i, to say, this investigation pertains to, , 23 Special Agent . Could 23 it's job performance failure and security 24 everyone please identify themselves for the 24 failure, correct? 25 record, and spell their last name? To start, 25 MR. : Yes. EFTA00064194 6 1 MR. : Job performance failure. 2 All right. So, it says, United States 3 Department of Justice, Office of the Inspector 4 General, Warnings and Assurances to Employees 5 Requested to Provide Information on a Voluntary 6 Basis. "You are being asked to provide 7 information as part of an investigation being 8 conducted by the Office of the Inspector 9 General. This investigation is being conducted 10 pursuant to the Inspector General Act of 1978, 11 as amended. This investigation pertains to job 12 performance failure and security failure. This 13 is a voluntary interview. 14 Accordingly, you do not have to answer 15 questions. No disciplinary action will be 16 taken against you if you choose not to answer 17 questions. Any statement you furnish may be 18 used as evidence in any future criminal 19 proceedings, or agency disciplinary 20 proceedings, or both." And there is a waiver 21 section. And it says, "I understand the 22 Warnings and Assurances stated above and I am 23 willing to make a statement and answer 24 questions. No promises or threats have been 25 made to me, and no pressure or coercion of any 7 1 MR. • -- during this interview? 2 MR. Yes. 3 MR. : Thank you, sir. Again, 4 it's a voluntary interview, if you don't 5 understand any of my questions, please ask me 6 to rephrase. 7 MR. Yeah. 8 MR. : Or ask for any 9 clarification. I would be happy to provide it. 10 Were you previously interviewed by the OIG at 11 the MCC on Jul 15th, 2019? 12 MR. • Yes. 13 MR. : Great. And that was by 14 me and Special A ent . Correct? 15 MR. : Yes. 16 MR. : Great. Is it correct 17 that the MCC camera -. Or sorry. Before I go 18 on that, are ou still at the MCC? 19 MR. : Yes, I am. 20 MR. : Are you still the 21 electronics technician? 22 MR. M i Yes, I am. 23 MR. : Great. Has anything 24 changed since we spoke on July 15th, 2019? 25 MR. : No. 1 kind has been used against me." 2 So, take a look. If you understand it, 3 and are agreeing, and are willing to continue, 4 can you just please sign where it says employee 5 signature? Thank you very much for signing. 6 DO you understand the form? 7 MR. Mm-hmm. Yes, I do. 8 MR. : Okay. Do you understand 9 this is a voluntary interview? 10 MR. M i Yes. 11 MR. : Perfect. Thank you. 12 Okay. Today's date, again, is September 29th. 13 So, I'm writing 09/29/21. The place is OIG, 14 MYFO. And the time is 8:19 a.m. And I am 15 signing my name as the Special Agent. ASAC 16 can ou sign as a witness, please? 17 : Mm-hmm. 18 MR. : Thank you, sir. 19 Thank you. 20 MR. : All right. Before 21 starting the interview, I would like to place 22 you under oath. Mr. , can you please 23 raise your right hand? Do you swear to tell 24 the truth and nothing but the truth -- 25 MR. : Yes. 8 1 MR. : No. Great. Is it 2 correct that the MCC cameras were not working 3 properly ini m i • J ust 2019? 4 MR. : Yeah. Well, the recorders 5 wasn't working. The cameras were working. The 6 recorders weren't working. 7 MR. : So, the live feed was 8 working, but the recordings were not. 9 MR. a Yes. 10 MR. : Correct. When did you 11 first learn that the MCC cameras were not 12 working pia" 13 MR. : That day. This was, I 14 believe, that day. Towards the end of my 15 shift. I'm not sure what time. 16 MR. : So, you still think it 17 was August 9th, 2019, that you learned? 18 MR. Yes. 19 MR. : After giving it some 20 thought, do you think maybe it happened the day 21 before, oiliiiiiii8th, 2019? 22 MR. : I don't know if I spoke to 23 somebody. I don't know why it would be the 24 8th. 25 MR. All right. When we go EFTA00064195 9 1 over the reports, we will see if that can help 2 freshen, you know, help you recall. First, 3 we're just going to ask you some questions for, 4 like, you know, so you can, from memory, recall 5 exactly -- 6 MR. M i l What happened. 7 MR. : -- when it was, and then 8 we will go over the reports, and see if that 9 helps jog anything. But to your recollection, 10 it was on Au ust 9th, 2019? 11 MR. : Yes. 12 MR. : And what is -- 13 MR. : It was that Friday. 14 MR. • -- what is it that makes 15 you think that it was on that Friday? 16 MR. : Because that's when I went 17 to the room. That's the only thing I really 18 remember. Because it was a lot of hours after 19 that. 20 MR. : Okay. 21 MR. That day. 22 MR. So, it was just -- 23 MR. : Yeah. 24 MR. • -- it was a lot of things 25 going on. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 10 MR. : Yeah. There was a lot of things going on. But I remember the 9th because everything happened the next day. MR. MR. Okay. On Saturday. MR. And are you aware, now, after the fact, that the cameras stopped recording on Jul 29th, 2019? MR. : No. MR. : So, you're not aware of that? MR. : No. Nobody. It's the first time somebod has told me that. MR. : Okay. So, by reviewing the recording system, or anything like that, you didn't learn that they stopped on July 29th? MR. : No. The recorders were still working. Because the recorders were still working for the building. All the -. Not all the cameras were working, but some of the recorders were working. (Indiscernible *00:06:26iiIIIIIIII MR. : So, when we spoke last time, you explained to us that on, like, August 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. MR. on DVR-2. MR. MR. those DVRs, 11 9th, is when you first noticed it, and that half of the cameras, or -- : Half of them was on -- . -- half the cameras on -- -- DVR-1. DVR-1, and half were DVR-2. And one of the, one of which included half of the cameras MR. Cameras. MR. -- they stopped -- MR. Yeah. Stopped working. MR. -- working. MR. Yeah. MR. So, what is your knowledge or recollection of when those half of cameras -? MR. : I don't know when those half the cameras stopped working? MR. : So, when you were trying to obtain video after the fact, you never learned, like when they're -- MR. : This is the first time -- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 MR. MI -- the last video? MR. : -- yeah, this is the first time I heard that was July. MR. Okay. MR. Yeah. MR. So, when is the first time you found out, then, that the recordings were, in fact not working? MR. IIIIIIIII: When I went to go try to fix it on that Friday. MR. : Okay. On the 9th? MR. : Yeah. MR. : Okay. But on the 9th, did you -. I thought you had told us you couldn't gain access to it on the 9th. So, when did you actually gain access to the room, to be able to -- MR. : I went up there -- MR. -- determine -? MR. : -- in the afternoon, to _22 do work. They said I couldn't stay because III had to leave, so the video room. MR. MR. MR. Okay. Yeah. So, III had to leave, so EFTA00064196 13 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you couldiiiiiiiiito do the work? MR. : Yeah. I couldn't stay to do the work, because I don't have a key, I don't have access to the room. Because it's the propeiiiiiiiiii MR. : And when you say "they," who was it that told you this? MR. : I was talking to Officer I. But it's no -. Everybody knows that SIS, that's their room, and I don't have access to go in the room. At the time, I didn't have access to fix the recorders. MR. Okay. Did you ever talk to a MR. That day? MR. : Any day, about these recordings. MR. : Yeah. I've talked to people numerous times about me getting access to the room, that I should have access to the room. MR. : No, I'm talking about, like, on August 8th or August 9th, about the cameras. Do you recall having a conversation - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. a I don't recall. MR. : -- with 7 MR. : No. MR. : No. Or III MI? The MR. I don't remember. MR. No. Okay. So, you don't remember learning that, on July 29th, 2019, the cameras sto ed recording? MR. : This is the first time -- MR. : From (Indiscernible *00:08:19). MR. Mi -- I heard it. MR. : That's the very first time you heard? MR. : That it was July. Yeah. MR. : Okay. MR. : Because that's, like, two weeks out, I wouldn't - not know it was recording for two weeks. That doesn't make any sense. MR. : Okay. So, you don't think that that would be accurate? MR. : No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 MR. All right. Do you know what stopiiiiiiiiifrom recording? MR. : I just know that the system wal_21ils_mil it had a lot of problems. MR. IIIIIIIIII: Okay. Do you know if someone did, like, an improper shutdown, or that poweiliiiiiiireated it to shut off? MR. : They were on UPSs, and no power surge that would have created it. It would have just been mechanical. MR. MR. MR. MR. and tear. MR. Okay. And again, on August 8th, you don't recall ever having conversations with anybody regarding these cameras, or first learning on August 8th that the cameras went down? MR. : August 8th? The day before? I don't really recall (Indiscernible *00:09:09iiIIIIIIII MR. : And you don't recall having the conversation with SIS Yes. Okay. Or, yeah, yeah. : Just from age? : Just from age, and wear 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 16 and IIII, about the cameras not recording on Au ust 8th, 2019? On Thursday? MR. : No. I don't recall. MR. : You don't. Do you remember them, towards the end of your shift, bringing you in the office because they couldn't get the recordings to rewind, and asked you to fix the problem? : On the 8th? • On the 8th. Hmm. I don't recall that. MR. MR. MR. No. MR. Do you remember having - at any time - a conversation prior to E stein's il2/h. with and MR. time? No. I MR. MR. , with SIS : Together? At the same don't recall it. Yeah. What about separately? : Separately, probably. We probably talked about it. But not together. At the same time. MR. : Well, do you recall the conversations that you had, then, prior to Epstein dying on the - or being found - on the EFTA00064197 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 10th. What conversations did you have with each of those individuals? MR. : Right. I was just busy working. On the 10th, the day it happened, or -? MR. No. Prior to the 10th. So, the 8th, the 9th, or anywhere back to the July 29thi_1±211/L MR. IIIIIIIII: Oh. That we were working o the problem, trying to figure out what was causing it, and that's when I ordered new hard drives to replace all the drives. That was my next step. That's what I was going to do that day. But I couldn't. MR. : And what made you do that, though? Who told you to replace the hard drives? MR. : Talking_slircigah SigNet, and the former com tech, IIIIIIIIII, he's the computer services manager and we talked about buying hard drives. I actually got a purchase order, too. Yeah. MR. So, who was the computer service mai MR. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. and last name? MR. MR. 1. MR. Yeah MR. MR. MR. MR. MR. MR. MR. MR. I'm sorry. end. MR. And 18 Can you spell the first IIII. And And did you say : II Yes. That's an or -? Yeah. So, no • Noll : Okay. And that's an II And that was the CSM? : YuL it's anl. Not an At the • All right. So, MR. Yes. MR. Okay. Great. And who was that kao ? MR. : He was the previous com tech before I got there, and now, he was - at 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 that present time - he was the computer services mana er. MR. • He was? MR. Yes. MR. • Okay. So, he was actually workin at the MCC? MR. : Yes. MR. MR. And he was your boss? : No. It's just, I talked to him about computer stuff, because he knows a little bit more than I do. That's his specialty. MR. : Okay. What was his kind of, like,iol e at the time? MR. : His job role was to take care of the computers. Infrastructure of the building. MR. MR. MR. Okay. Yeah. : And what was the conversation with him, and where? MR. : I think, that's when we were talking about actually just replacing all of the hard drives because they keep failing all the time. So, the next step was to replace 20 1 all the hard drives. 2 MR. : And do you remember when 3 you had that conversation? 4 MR. : A few days before this 5 happened. And we've had numerous conversations 6 about this for weeks because - and probably 7 months - because of the way the hard drives 8 kept failing. The drives would, the recorders 9 would stop working. 10 MR. : So, did you know, then, a 11 few days before this? I'm assuming, when you 12 say "this," August 9th, 2019, that the hard 13 drives had failed? 14 MR. : I knew it was a 15 possibility they failed. At the time, or the 16 before I left I knew everything was working. 17 MR. : Before you left when? 18 MR. : I'm not too sure, but I'm 19 just saying, like, overall, as far as, like, as 20 far as everything recording, because I've 21 checked the recorders. It looked like 22 everythingiiiiiiirding. 23 MR. : What day are you speaking 24 about, thou h? 25 MR. : Oh, specifically, before EFTA00064198 21 22 1 the incidiiiiiiiiiied, on the 9th. 2 MR. : So, on the 9th, 3 everythin was 4 MR. : Well, when I checked it, 5 of course it wasn't recording. That's why I 6 went up there to check. 7 MR. It was not? 8 MR. It was not recording. 9 MR. Okay. So, when is the 10 first time you found out that it was not 11 recording? 12 MR. : Oh. I guess the 9th. 13 Everybody keep saying the 8th, but I don't 14 really remember the 8th. 15 MR. Okay. So, the 9th, and 16 is that when ou -- 17 MR. : Because I -. 18 MR. -- are saying you had the 19 conversation with 20 MR. : Yes. Well, I had the 21 conversation before, with , about what I 22 was going to do next. 23 MR. MI Okay. 24 MR. : Because it happened 25 before, so the next step was just to replace 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 all the hard drives. MR. Like, it happened long before, or when are you talking about -- MR. : It happened -- MR. -- (Indiscernible *00:13:11iIIIIIIII MR. : -- multiple times before, where the recorders would stop working. MR. Okay. MR. Yes. MR. So, you were trying to preemptive) sto that from happening? MR. : Happening again, yes. MR. Okay. So -- MR. So -. MR. : -- you didn't talk to him based upon the system stopping recording. You were talking about it -- Mm-hmm. -- doing preventative MR. MR. maintenance? MR. MR. MR. MR. Maintenance. Yes. Is that correct? Yes. Okay. But you don't 23 1 remember exact) you spoke with him? 2 MR. : No. Some time around that 3 time, because I have to get the purchase, I 4 have to get the parts to make the repairs, or 5 change the drives out. 6 MR. : All right. So, until we 7 go over this, I'm going to run through these, 8 just so we keep on track. But it sounds like 9 I'm going to have to show you these documents, 10 to help ma be clarify some things. 11 MR. : Mm-hmm. 12 MR. : Do you know, did you know 13 that the recorders - that the cameras weren't 14 recordingliiiiiiii August 9th, 2019? 15 MR. : Yeah. I know there was 16 failures iiiiiiiiiitem. Yes. 17 MR. : So, you knew that they 18 were not 19 MR. : Not that day. But I know 20 that, overall, there was going to be system 21 failures. 22 MR. : And did you know that it 23 was half of them all on DVR-1 or 2? 24 MR. : I wasn't too sure what it 25 was. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 24 MR. : Okay. MR. : But I know there was a failure. I didn't check to see exactly where they were. MR. : So, you knew there was a failure with the system, prior to August 9th. You just didn't know what the failure was? MR. : Yes. MR. And how did you know that? MR. : Well, I would have to go check if there was video, there was no recorder videos, live videos, but there was no recorder video. MR. : So, you personally had checked to see if there were recorded video? MR. : Yes. MR. : And when did you do that? MR. : I had, well, I had checked that day, before I had to go upstairs to look at everythin MR. MR. August 9th? August 9th. Yes. MR. So, that's where I'm saying. So, when you say, prior to the time, EFTA00064199 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 MR. Yes. MR. MR. I'm not too sure. MR. 25 you're talking about the same day, August 9th, is when you checked the -- MR. : Checked the recording. MR. -- the recording. MR. Yeah. MR. : Prior to August 9th, did you check the recording to see if it (Indiscernible *00:14:46)? : Multiple times before. . And were they recorded? From what I believe, yes. Okay. Would you check that system to check on the recordings, every day? MR. that says MR. : No. There was no thing I have to check it. Sure. MR. : The thing with the recorders is, I'm not really supposed to, like, 22 mess with the system. I just, I'm maintenance. 23 I'm not really supposed to, like, oh, tail 24 SIS, that's their job to tell me, hey, 25 there is no video, or something, there is a 26 1 problem. 2 MR. So, how did you know that 3 the recording wasn't being able to rewind, and 4 check recording? Why were you in there 5 checking that? 6 MR. : I just, I guess I spoke to 7 somebody, or maybe I checked it. I'm not too 8 sure. 9 MR. : But it would have been 10 based upon someone requesting you to do so? 11 MR. : Yes. 12 MR. And you believe that 13 happened on the 9th? 14 MR. Yes. 15 MR. Okay. 16 : And iL i and the call 17 dropped. Let me 'et back on. 18 MR. Absolutel . 19 MR. : A ent 20 : Hey, . You hear us fine 21 now? 22 MR. : Yes. I apologize. I 23 don't know why the call dropped. 24 MR. : Mm-hmm. 25 : Okay. 27 1 MR. All right. So, we were 2 iiiiiialking about the recording and how Mr. 3 would not go in and review a recording 4 without someone requesting him to do so. He 5 doesn't recall specifically who made that 6 request for him to review the recording, but he 7 believes that he reviewed the recording on the 8 9th, and that's when he determined that it 9 wasn't recordin roperly. Is that correct? 10 MR. : Yes. 11 MR. : All right. And you - and 12 again - you don't remember why you were 13 reviewing that recording? 14 MR. : No. Because we're in the 15 middle of a -. Well, no, this -. Before 16 Epstein happened, we were in the middle of a 17 camera project, we had people TDY. So, I was, 18 like, the lead in the building, trying to tell 19 everybody what needs to get done. And I think 20 the day before, I was on 10 South, I was 21 putting in a (Indiscernible *00:16:52), so I 22 was busy that I had a TDY guy on me. 23 MR. : And when you - on the 24 8th? 25 MR. : Yeah. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. you. MR. Yeah. You got a TD guy with 28 MR. And who was that TD guy Y? (Indiscernible *00:16:59). MR. . His last name was , and I don't remember his first name. He was an electrician. MR. : An electrician. Do you know which facility he came from? : No. I'm not too sure. You don't know the first MR. MR. name? MR. : I forgot his first name. We just call ever body by their last name. MR. But he's not from MCC? MR. No. He's not in from MCC. MR. After the interview, can you just see if you can identify who that person is, and then send me an email? MR. : Okay. MR. Of the person's name. But the Au ust 8th, 2019, you believe this -- MR. : Yeah. MR. : -- this TOY employee, EFTA00064200 29 30 1 wiiiiiiiliou? 2 MR. : Yeah. He was with me. We 3 were together all day because we were doing the 4 piping, and tr in to put the rack in. 5 MR. : And what is a rack? 6 MR. : Where the -. Well, for 7 the new camera system, that's where the power 8 supply, the switch would go, the camera feed, 9 the (Indiscernible *00:17:38) five cables would 10 go. Ever thin will go on the rack. 11 MR. : So, it had to do with the 12 camera system? 13 MR. : The upgrading the new 14 camera system. Yes. 15 MR. : Is that anything that 16 could have possibly caused the cameras to stop 17 recording? 18 MR. : No. That's -. Nothing 19 was hooked up. It was just the hardware. 20 There was no or nothing. 21 MR. : Okay. So, that could not 22 have affected the camera? 23 MR. Mi The cameras? No. 24 MR. : All right. And do you 25 remember, prior to August 9th, checking on the 1 camera system, though, to make sure it was 2 recording? 3 MR. : Yes. After we had the 4 problem, 5 MR. : No, no, no. Prior to the 6 9th. 7 MR. : Yes. Prior to the 9th. 8 MR. And when did you check 9 on, prior, like, how many days before? Do you 10 remember? 11 MR. : I don't really remember. 12 MR. • Are you talking about, 13 like, a few days leading up, a day leading up, 14 or are you talkin about, like, a month or two? 15 MR. : Maybe, like, weeks. Not 16 months. It wouldn't have been a month. 18 MR. M! 17 MR. : Like, a few weeks? Yeah, because I had to 19 order the parts. I don't know when I ordered 20 the parts. But I had to know that they weren't 21 working. 22 MR. : But I thought you just 23 said that they were working, and you only 24 ordered tiiiiiiiiieventative maintenance? 25 MR. : Well, I - yeah -. Well, 31 1 they weren't working before. So, I had to 2 rebuild one of the drives. I had to change one 3 of the drives out. 4 MR. : Okay. 5 MR. : That's when I went to say, 6 let me order a whole bunch of drives, to 7 replace all the drives together, at once. 8 MR. : And are you able to 9 determine when made that order? 10 MR. : Yes. We have a purchase 11 order. Yes. 12 MR. : All right. So, those two 13 I l ls so far. Can you give me the name of 14 , and the second thing is the purchase 15 order, with re and to -- 16 MR. : Yeah. 17 MR. : -- when you made that 18 order -- 19 MR. : Yeah. 20 MR. • -- for the new drives? 21 MR. Mm-hmm. 22 I'll send you an email 23 after this. 24 MR. Okay. 25 MR. : lust kind of reminding 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 you of what it is we're hoping to get. And there, but again, you ordered that because there was a problem with the -- MR. : Recorders. MR. -- with the recorders MR. Yes. MR. -- you fixed that problem. MR. : Temporarily. But I knew it was going to happen again. And the best thing to iiiiiiiiiilace all the drives. MR. : Okay. So, you knew that it would iiiiiiiiirding again? MR. : I knew there was going to be a problem a ain. Yes. MR. : Okay. And what made you know that talking the age of the unit, MR. : Talking to the vendor, and because it was, like, 15 years old. And the fact that it's on 365, 24 days, and on 24 hours a day, like, it just constantly goes on. And then, when you try to do maintenance, something as simple as changing the time, the recording would stop for, like, a whole day, day and a EFTA00064201 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 half. Because for the drives rebuilding, you have to chap e the time. MR. : Okay. MR. : And before all of this happened, I actually put in a camera project. That's why I was in the middle of a camera project, to everything. MR. : Now, when you say that the people you spoke to, you mentioned and then, you said the customer service people MR. : Yeah. SigNet. MR. -- Signet. MR. : Yeah. Mainly , and I would talk to him. MR. was your main point of contact? MR. : Yes. MR. What about a ?Iiiiiiiliou recall -? MR. : was the one that came after Epstein. That's the guy that showed up when we had to put in the new drives. Because we ordered the new -. We ordered the new recorders. But everything was downstairs in 34 1 the basement. And we weren't really a priority 2 on the list until, of course, Epstein happened. 3 That's when SigNet came the next day, and put 4 the new recorders in. 5 MR. Okay. So, prior to 6 August 10th, 2019 our main point of contact 7 was SigNet, with 8 MR. 9 MR. 10 MR. . Yes. 11 MR. : And what was his role and 12 responsibiiiiiiiiih SigNet? 13 MR. : He is just, like, the guy 14 we will call if there is a problem, or if 15 training, or if I don't know the system. 16 Because, like, this system, I never had 17 training on it. So, like, when I saw it, 18 because the last institution I was, was, like, 19 maybe two versions ahead of this one. So, when 20 I saw this recording, I was, like, this stuff 21 is old, like, I don't know anything about it. 22 Like what should I do? So, I called 23 and IIIIII, like, pretty much would walk me 24 through trouble shooting, if there is a 25 problem. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. again? MR. : Raid (Phonetic Sp. *00:21:08). MR. like that? MR. a raid system. that's what he MR. MR. MR. 35 And what was the system Nice Pro, or something : I don't -. I know it was A raid array. I remember kept saying. Raid array. • Okay. It was raid. • And do you know what that means? MR. : Just the way the drives would go. So, if, the way he explained that to me, if one drive would go bad, that's not so bad. But as soon as two drives go bad, that's when all the recordings pretty much stops. MR. • So -- MR. : Because it was a redundant system. MR. -- okay. So, when one drive goes bad, does any, do any recordings stop? MR. : No. It will keep 36 1 recording. 2 MR. So, it will automatically 3 shift over to the other drive? 4 MR. : To the other slot. Yes. 5 MR. : Okay. 6 MR. : And then, when two drives 7 go bad, that's when all the recordings stop. 8 MR. : So, what is the 9 difference between ours, where is one -. Is 10 what you're talking about a DVR-1 and a DVR-2? 11 MR. : No. That's the drive in 12 the DVRs, because there's 16 drives. That's 13 what - I think - that's what it was. So, out 14 of the 16 like, in DVR-1, if one goes bad, 15 that's not a problem. As soon as the second 16 drive goes bad, then that's when you have a 17 problem. And that's when the recording would 18 stop. 19 MR. Okay. So, what is your 20 understandin of what happened here? 21 : Oh. The drive went bad. 22 : One of them? 23 Two of them. Yeah. 24 Two of them -- 25 : I believe. MR. MR. MR. MR. MR. EFTA00064202 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 37 MR. IIIIIIIIII: -- did go bad? MR. IIIIIIIII: Yes. Because that's why - MR. : And is it two of 16, or is it two out of two? MR. : Two out of 16. MR. : So, if two out of 16 go bad -- MR. MR. MR. MR. MR. MR. MR. MR. MR. recording sto s. MR. : And the DVR-1 and DVR-2, that's sim l the recording system? MR. : Yes. MR. : That's not the anything to do with the -. The drives are what's making MR. Go bad. -- then -- Mm-hmm. -- they all. The recordings stop. Yes. : For all of them? Yes. : Okay. : On that drive. All the : (Indiscernible *00:22:32) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. they're savin MR. MR. MR. : -- the recording, but it to DVR-1 -- Yes. -- and DVR-2. Yes. 38 MR. : So, what is the difference between if a DVR-1 goes bad, but not DVR-2? Is that ust -? MR. : The physical location over it. Because everything on the old system was analog. So, like, cameras one through whatever are on this drive, on DVR-1, and our other cameras are on DVR-2. MR. : So, does each DVR have 16 drives? MR. : Yes. MR. : All right. So -- MR. So -. MR. • -- DVR-1 has 16 drives. DVR-2 has 16 drives. MR. Mi Yes. MR. : And either DVR-1 or DVR- 2, two of those drives went bad? MR. : Yes. MR. : And stopped that DVR-2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 from recordin . MR. : From recording. Yes. MR. : But the drives on DVR-1 were all ood? MR. MR. MR. All good. Yes. Okay. : And another thing I've learned also, through my time, is that SigNet replied to me this, you could look at the camera software, until you physically look at the drives, you would think that everything is recording. That's something we went over recently. MR. : Well, what about a -. I was told that there was an application that you would have, that was called Supervision. MR. _: Yeah. I don't look at Supervision. MR. You don't. MR. : You can. I have access to look at it, but I didn't get trained on it, so I don't really look at Superivision. I would just go in the regular Nice Vision, and look at it that MR. : Yeah. We were told that, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 40 in order to determine if there were problems with the drives MR. : The drives. You would have to -- MR. -- that's through -- MR. -- yes. MR. -- yeah, you go into Supervision, and that would, in fact, tell you? MR. : And which, I have no training on. MR. So, you've never -- MR. Obviously. MR. -- looked at that? MR. No. MR. Did anyone else have health -- MR. At the time, no. MR. -- did anyone else have access? MR. MR. person with access MR. MR. No. So, you were the only to Supervision? Yes. Pretty much. Yes. All right. And do you know if someone accessed the application EFTA00064203 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 41 Supervision, they could have taken the drives offline, or the recordings offline? MR. : Hmm, yeah. But yeah, nobody would have that access. MR. : Would they be able to do it from there though? MR. : Yes. They probably would, yes. MR. But you are confident no one had access to it? MR. M i No. MR. : Okay. So, you would be the one and only person with access to Supervision? MR. a Yes. MR. : And there is no, like, if you're not there, somebody else has -- MR. : There is nobody -- MR. • -- a way to -- MR. -- there is nobody. Yeah. MR. • -- how would they do that? Frill? To get access again. MR. : Oh, no. They would just have to know the to log in. MR. IIIIIIIIII: Well, that's what I mean. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 42 So, if you ended up not being able to show up, or you left, or something like that, how would someone gain access to that? MR. : That's something they would have to try to figure out, but yeah. I don't -. MR. : But to your knowledge, you're the only person that had the password to access Su ervisioN? MR. : Yes. MR. Okay. And SigNet wouldn't be able to remote in? MR. : No. They have no access to remote it. That's BOP. They don't want them to be able to backdoor remote in to anything. MR. Okay. And when did you MR. : Oh. Well, they -. The old system, they were able to, if you had a 56K (Phonetic Sp. *00:25:06) modem, they were able to do maintenance, and tell me, like, the status of the drives. But I would have to physically hook up S6k modem. But at the time, that wasn't hooked up. Because we did some 43 1 repairs before, when I was trying to figure 2 stuff out, and I couldn't figure it out, where 3 they would - through a modem - they would 4 remote into the -. Well, I would have to grant 5 them access to look at the drives, to 6 (Indiscernible *00:25:26) of the drives. 7 MR. • So, how -- 8 MR. : And we've done that 9 before. Yes. 10 MR. -- so, you had to grant 11 them access. The couldn't go in there -- 12 MR. : No 13 MR. • -- without your -. 14 MR. : Physically. And 15 physicall ou have to put a cable in. 16 MR. : Okay. 17 MR. Yeah. 18 MR. So, you are the one and 19 only person with access, remotely, that could 20 have accessed those servers? 21 MR. M i Yes. 22 MR. : Okay. And do you 23 remember the last time you would have accessed 24 that application? 25 MR. : I have no idea. 44 1 MR. No? Would it have been 2 leading u to Au ust 9th, 2019? 3 MR. Probably. Yeah. 4 MR. : And do you know around 5 how long before that? 6 MR. M i l No. 7 MR. : Is there a way to 8 determine? Do they have, like, some thing that 9 you can see when your last log ons were, or 10 anything like that? 11 MR. : You could call computer 12 services, then they could tell you my 13 keystrokes or whatever, whatever I logged into. 14 But that'iilliliiiihe only time. Yeah. 15 MR. : Okay. 16 MR. IIM7 But there is really 17 nothing to sa when I logged in. 18 MR. : But to your recollection, 19 you were not accessing Supervision at all? 20 MR. : Hmm. I mean, they showed 21 me how to do some stuff on it, but I don't 22 really even think I remembered how to - at that 23 time - I don't really remember. 24 MR. : But the point being, in 25 this case, you didn't find out the recordings EFTA00064204 45 46 1 had stopped because of that application, 2 Supervision. Correct? 3 MR. M i I don't believe so. No. 4 MR. : Okay. And you did not 5 take the cameras, or recordings, offline from 6 Supervision. Correct? 7 MR. : No. I can't. Yeah. No. 8 I've never been able to do that. So, no. 9 MR. : So, you don't even -. 10 Sorry. I thought you told me before you could 11 do it. DO ou think -- 12 MR. : You have access to do it, 13 yes, if you are in Supervision. Yeah. There 14 is stuff you can do on Supervision to stop the 15 recordings. Yes. 16 MR. : Now, if you weren't 17 really familiar with the application, is it 18 possible that you were in there, and you 19 accidental) knocked them offline? 20 MR. : No. 21 MR. • Okay. 22 MR. : I wouldn't knock anything 23 offline. 24 MR. No. You don't believe 25 so? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. a No. MR. : Okay. And what would be a reason for you to go into the application, Supervision? MR. : Just to see what was going on, who's logging on, or just to, if something looks funky to me, or just doesn't feel right, to see what was going on. MR. MR. MR. Okay. Yeah. And do you have any examples, prior to August 9th, 2019, when you would have done that? MR. : I know there was one time, like, when they remoted in, they were showing me stuff on the drives. And I was talking to SigNet over the phone, and they were showing me how to fix the drives before. MR. : Okay. MR. : But other than that, like, I don't really remember me using Supervision that much. MR. : And that would have been, they would have had a log of when that happened? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 47 MR. : Yeah. Supervision has a - . Every time you log into Supervision, you see a username and who logged in. That's always kept on Su ervision. MR. : Okay. And do you have that now, to be able to -- Yes. • -- determine? Yes. • So, it shows that Well, that -- -- it shows -. -- well, whatever system you can log into it, and see what you access to MR. MR. MR. MR. MR. MR. MR. you have, have on it in Su ervision. MR. : And when you logged in, and when ou lo ed out? MR. : Yeah. MR. : So, would you still have the ability now, to go back to see when you logged in and lo ed out? MR. : For the old system, no. MR. • No? Not for the old system. MR. : Old system, no. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. MR. MR. MR. MR. MR. should be regard to MR. MR. there. MR. MR. went in there, you? MR. out. But not MR. again, August that you knew recording. 48 MR. Okay. But SigNet would probably have a call log of you -- Of who's on. -- talking with them? Yes. Going over -- Supervision. • -- Supervision? -- yes. All right. So, SigNet able to provide us something, with Supervision. Yes. • -- when they had you in Yeah. And do you think that you though, aside from them showing : Maybe to check some stuff really. : Okay. All right. So, 9th is the first time you think that the cameras weren't EFTA00064205 49 1 MR. : Mm-hmm. 2 MR. : If we were to tell you 3 that the cameras actually stopped the recording 4 on July 29th, 2019, you said that's news to 5 you? 6 MR. : Yes. That's kind of a 7 long time for me not to notice that the cameras 8 -. That's like a week and a half. 9 MR. Something like that. 10 MR. Yeah. 11 MR. : Yeah. 12 MR. . For me not to notice that 13 they stop ed recording. 14 MR. • So -. 15 MR. : But I could see where, if 16 I didn't do it, because we were busy with a 17 project, maybe I didn't check it. But that's 18 kind of hard. And for SIS, or nobody to tell 19 me, like, hey, the cameras weren't recording, 20 or we've tried to pull video and it wasn't 21 working. That's kind of weird, too. 22 MR. : All right. All right. 23 So, since you don't remember these, we're going 24 to start ilao -- 25 MR. : Sure. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 August 9th MR. MR. MR. Yes. MR. : Okay. MR. Somebody did tell me about the drives. MR. And who was it that told you? MR. : I think it was SIS. Somebody in SIS. It might have been But I'm pretty sure it's somebody from SIS that told me, hey, the cameras stopped working. Or here, there is a problem. 50 MR. -- some of these -. I'm just, again, because I assumed you were going to remember this stuff, I'm going to cover these questions to make sure that I don't miss anything. MR. : Mm-hmm. MR. And then, we will have to, maybe, refresh with some of them. So, did IIII, or tell you to fix the cameras on 2019? On August 8th -- : 8th. -- or 9th, 2019. : Yes. The 8th or 9th. 51 1 MR. And can you just recall 2 that conversation, of what they told you, and 3 what happened and where it was? 4 MR. : It's pretty simple. Like, 5 hey, , the camera is not working, this 6 and that, (Indiscernible *00:30:03). Like, I 7 just go and do 8 MR. : And did they tell you, 9 fix it immediate) ? 10 MR. : No. 11 MR. : Did they tell you that 12 they were informing the captain? 13 MR. a No. 14 MR. : And you don't recall 15 being involved? 16 MR. : Pfft. This is two years 17 (Indiscernible *00:30:16) get involved, as far 18 as I know. 19 MR. IIIIIIIIII: Well -. 20 MR. : I mean, after the fact, 21 everybody is involved, but -. 22 MR. : So the information we 23 have is and were 24 attemptiniiiiiiiiiew video on August 8th -- 25 MR. : Oh, okay. 2019. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 52 MR. MR. W. Okay. They were looking : 2019. at video -- MR. MR. MR. at video MR. MR. And -- -- for some reason. -- and they were looking they called you. Okay. • And had you come up. And had you determine what was going on. MR. MR. said, on August 8th, she said, make sure that you get this thin fixed. MR. : Mm-hmm. MR. : She, then, she said she didn't work on August 9th, and the schedule for August 9th reflects that. MR. : Okay. So, if that happened, I'm not saying this happened, but if it that did happen, I probably noticed that the drive went back and probably was trying to rebuild the drive. But I'm not sure if that's exactly -. Honestly, I don't remember the day before what happened. EFTA00064206 53 54 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. And that's what I'm trying to, ou know -- MR. Mm-hmm. MR. -- refresh your recollection. So, on August 8th, 2019, she said it happened some time before 2:00 p.m., that's whiiiiiiiiioke to you about this. MR. : So, I would have went in there. MR. : And she said -. MR. : And if I was upstairs, I would haviiiiiiiiiiht in the room. MR. : And she - yeah - she said that -- MR. : But I don't remember. MR. : -- she was under the understanding that, on August 8th, you were fixing it. MR. MR. : She said, she didn't work on August 9th, and she hadn't planned on working on Au ust 10th -- MR. : Mm-hmm. MR. • -- but she got called in. MR. : Mm-hmm. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 on? 22 23 24 25 MR. On August 10th -- MR. August 10th. MR. -- because of what -- MR. Yeah. Epstein. MR. -- happened with Epstein. MR. Yes. MR. She said, when she saw you on August 10th, she had learned that the camera system wasn't fixed -- MR. MR. recording. MR. MR. didn't this get her was, I came MR. MR. MR. MR. : Yeah. -- and they weren't : Yeah. And she said, , why fixed? And your response to in today to do that. : Yeah. Does that all help you -- Yes. -- recollect what's going MR. : Yes. MR. Does that sound accurate? MR. : It sounds accurate, but -. So, if something happened on the 8th, I don't 55 1 think I would wait until the 9th to fix it. 2 So, if it did happen on the 8th, I don't really 3 remember the 8th. I remember the 9th more 4 specifically. But it did happen on the 8th. I 5 would have went to the room, and just replaced 6 the drives, because that's the only thing I 7 would do. 8 MR. : All right. I'm going to 9 skip ahead and do, I'm going to read you - and 10 I'll continue on with this - I'm going to -- 11 MR. : Yeah. 12 MR. : -- read you the FBI 13 interview re ort from when you -- 14 MR. Mm-hmm. 15 MR. -- do you remember, you 16 said that ou were interviewed by the FBI? 17 MR. : Yes. I was. 18 MR. : All right. So, this says 19 you were interviewed by the FBI on March 12th, 20 2020. Is that correct? 21 MR. M i Yes. 22 MR. : All right. So, I'm going 23 to just read, I'll just read the whole thing, 24 so that we're not missin anithin . It says, 25 "On March 12, 2020, ," it says 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 56 your date of birth and telephone number, "was interviewed b Assistant United States Attorney, (Phonetic Sp. *00:32:42), Task Force Officer Detective (Phonetic Sp. *00:32:45), and Special Agent , at the United States Attorney's Office, Southern District of New York, 1 St. Andrew Plaza, New York, New York. During the interview, provided the following details." Does that all sound correct so far? MR. Yes. MR. And we're just going to stop after each aragraph, to have you -- MR. : Mm-hmm. MR. -- to check in with you. started working for the Bureau of Prisons in 2003 and worked in both New York and Indiana. had some colle e education, , and had ten years' experience in electronics." Correct? MR. M i l Yes. MR. : "In 2016, in charge of all the cameras at the was put EFTA00064207 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 57 Metropolitan Correctional Center (MCC). advised that the camera at MCC were out of date. The recorders frequently went bad, and the cameras were all analog, and not maintained properly." MR. MR. : Yes. • "The camera system was over 20 years old. Sometimes, the screen would be active, indicating that the camera was working. However, the video would not be recording." MR. : Yes. MR. advised that only one hard drive of the camera system was working, at the time of the incident, on August 10th, 2019. When a DVR went bad, none of the cameras recorded. There was a system failure of DVR-2 on July 29th, 2019, and the motherboard failed on DVR-2 on August 8th, 2019. The hard drive failure occurred on August 10th, 2019." Is that something that you provided to them? MR. : Yeah. I probably did. Yes. MR. So, can you just explain 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 58 to me what we're talking about here, because it says -? MR. : That was -. MR. It says, specifically, there was a s stem failure -- MR. Yes. S li : MR. : -- of DVR-2, on July 29th MR. 29th. MR. -- 2019. MR. : That was a month before. Well, yeah. MR. That's that week and a half. MR. (Indiscernible *00:34:34). MR. That's the July 29th, 2019 -- MR. Yes. MR. -- that we were talking about. So, what would have happened with the system failure? MR. : That's when I had to replace the motherboard on the DVR-2. MR. And what does that mean? MR. : DVR-2 was really old, and 59 1 SigNet didn't have the arts to replace it, so 2 I had to call with , I contacted another 3 BOP facility, and then, I took the computer 4 apart, and he just pretty much replaced the 5 motherboard, and got the DVR-2 to start 6 working. 7 MR. MI On the 29th? 8 MR. : If that's what it says, 9 yes. 10 MR. : Well, it just says -. It 11 doesn't say when you got it to stop working. 12 It just says there was a system failure of DVR- 13 2 on July 29th, 2019. 14 MR. : I believe they probably 15 spoke to Signet then. I'm not too sure with 16 the dates because everything is -. I've been 17 super busy. The dates, I'm not really good 18 with. 19 MR. : Okay. But on July 29th, 20 2019, with the system failure, would have that 21 stopped the recordings? 22 MR. : Yes. A system failure 23 would haviiiiiiiiiithe recordings. 24 MR. : Okay. And is it your 25 understanding that, after July 29th, the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 recordings were working? MR. MR. MR. Yes. All right. : Because he would have 60 logged into Nice Vision, and he would have seen things MR. : But I thought you said that -- MR. a And that's, well -- MR. : -- you'll only see if it was working, if it was live feed. I thought you said see recording. MR. : No. If you log into the Nice Vision, with the live feed, you would think everything is still recording because everything looks green. It's when you try to play back the video and, like, oh, wow, there's nothing being recorded. That's when you would know there is a problem. MR. MR. MR. MR. Yeah. MR. Okay. So -- So, if somebody has -- -- the way you check -- -- to pull the video. -- like, the way you EFTA00064208 61 62 1 checked was to try to rewind video? 2 MR. : Yeah. That's the only way 3 you could check it, is try to pull video from 4 the days orior 5 MR. All right. So, you are 6 aware, though, on July 29th, 2019, it stopped 7 recording, but your understanding was that you 8 got it toliiiiiiiiin? 9 MR. : Yes. Everything started 10 working a ain. 11 MR. : All right. And do you 12 know if you checked on it for say, let's say 13 the 30th of Jul or -? 14 MR. : I was in the middle of a 15 project, so I can't say I was just focused on 16 that, because there was a lot going on. 17 MR. : So, you only recall that 18 you would have checked on the 29th? 19 MR. : Yeah. 20 MR. : Of July. 21 MR. : Yeah. I don't think I 22 would have had reason to check, unless somebody 23 told me it wasn't working. 24 MR. : Okay. And it says, "And 25 the motherboard failed on DVR-2, on August 8th, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2019." What does that mean? MR. : So, the motherboard, that's the one I had to get replaced on August 8th, 2019. MR. : Right. So, this says August 8th. And you've been saying that you first learned on August 9th. So, where does this come into play? How do we know that the motherboard failed on DVR-2 on August 8th, 2019? MR. : August 8th. That's the motherboard I wrote, I must have replaced. Because I remember replacing a motherboard. MR. : And what does a motherboard do? What is that? MR. Everythin MR. MR. MR. MR. MR. running in circles -- MR. '1R. : When ago did this happen? happened on the Epstein, that was -- Epstein was the 10t . -- 10th. : And just to help -- So, that's -- -- so, just so we're not 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 63 the SigNet service call, as well. MR. M i Yeah. MR. : So, this is the SigNet service re uest number 24975. MR. : Mm-hmm. Mm-hmm. MR. : It says, assigned to IIII MR. MR. MR. : Mm-hmm. (Indiscernible *00:37:33 ii MR. IIIIIIII : -- and Date created, Au ust 8th, 2019. MR. : Okay. MR. : And then, if we go down and we look at the, well, we'll read the comment section. MR. MR. : Mm-hmm. : Okay. So, there is a comment by on August 8th, 2019, at 3:38 p.m. It says, "Hi, IIII. Unable to locate anything official. The basic steps are as follows. Set the raid level to none and save. It will restart it with all drives being J. Replace any faulty drives. Two, set the raid level to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 -- yeah, that -. . -- let me just read you 64 five, and save. It will restart and being, and initialization." And obviously, these words seem to be wTon . I'm sure -- MR. : Mm-hmm. MR. : -- it's supposed to say, it will restart and begin initialization. MR. I n Mm-hmm. MR. : It talks about the password. And it talks about different directions to ao forward -- MR. MR. -- with. And then, there is a comment by on Au ust 14, 2019, at 8:02 p.m. This says, " called us on Thursday, August 8th, stating that he had two bad drives on his raid unit." MR. Mi Mm-hmm. MR. : "Of the Nice Vision Pro unit, NVR. We advised him to get replacement drives." MR. MR. Once they are replaced, they should start to -- MR. : Initialize. MR. -- initialize -- : Mm-hmm. Mm-hmm. EFTA00064209 65 1 MR. l a Yes. 1 MR. : -- to become available 2 2 3 for the raid array. did not have 3 4 drives readil y available." 4 5 MR. : Mm-hmm. 5 6 MR. : "He checked with his 6 7 local CSM " again -- 7 8 MR. : Mm-hmm. 8 9 MR. _zz_you said was -- 9 10 MR. 'I'll. 10 11 MR. : -- okay. "To see if they 11 12 had any spare replacement drives. Once he 12 13 located replacement drives on Friday, August 13 14 9th, he did not have access to the DVR room to 14 15 replace them. He called SigNet for phone 15 16 support, on Saturday, August 10th -- 16 17 MR. : Mm-hmm. 17 18 MR. -- when he gained access 18 19 to the DVR room. 19 20 MR. : Mm-hmm. 20 21 MR. : "He attempted to replace 21 22 the drives, and they started to rebuild. 22 23 During the rebuild process of the drives, the 23 24 drives were required to be taken out of the 24 25 raid on DVR-2." 1 25 67 1 MR. All right. And it was 2 the 8th that someone told you that the 3 recorders -- 4 MR. : (Indiscernible *00:40:04), 5 and I probably went to go look at the room. 6 Yes. And then, I probably went back the next 7 day, on the 9th, because the Thursday, when he 8 told me to put the drives in, I probably went 9 to put the drives in, and replace them. And 10 then, Friday, is when I'm stopped to see if the 11 drives finished that rebuilding. 12 MR. : I'm sorry. Can you 13 repeat What happened? 14 MR. : Okay. Okay. Now, it's 15 making more sense. 16 MR. So, on the 8tliwas it - 17 can you recall - was it that 18 told -? 19 MR. : Somebody told me what was 20 going on, on the 8th. 21 MR. : At the time, was there 22 only SIS people workin there, 23 , and SIS Tech 24 MR. 25 MR. -- is it -? 66 MR. : Yeah. MR. : "Once the drives are removed without proper shutdown of the recorder, the video database becomes corrupted. Typically, any time the raid on a raid five configuration loses two drives -- MR. I n Mm-hmm. MR. : -- the raid needs to be rebuilt, and all data is wiped from the raid." MR. : Mm-hmm. Mm-hmm. MR. : Do you want to just review that ourself? MR. : Uh-huh. MR. : So that I'm not just reading it to you, and tell me if that sounds accurate if,. MR. : Yes. That sounds a little bit betters_lill2aiihat happened. MR. IIIIIIIIII: So, is this now refreshing your recollection that, actually, on August 8th, is when you found out? MR. : Yes. Okay. It was the 8th, MR. W. The 8th. Yes. MR. It was the 8th? : 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. MR. they were the onl MR. MR. MR. MR. Yes. Were they -? I think No -- Two working. -- at the time. Yes. So, would it have been one of the two of them? MR. : Two of them. Yes. MR. Okay. And they told you that the MR. MR. MR. MR. 68 Recorders went bad. -- was -. Yes. Okay. So -. MR. : And then, and that's probably when I called SigNet, okay, two drives, two bad drives. So, I probably got the drives. I started to rebuild it. And then, the next da that's when I checked. MR. : But it sounds like, from this, you didn't have the drives on the 8th. Is that correct? EFTA00064210 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 69 MR. : I probably - because there was spare drives on the room - so, I probably started to rebuild on the 8th. I'm not too sure. Hog, MR. : All right. Well, this is really important for us to get you to try to remember. MR. MR. I know. : Because this is, like, a big piece of this, the fact that the cameras were down when E stein -- MR. : Yeah, I know, but I -- MR. -- and -. MR. -- I was doing, like, a million things, and I've been doing a million things after, like -- MR. MR. MR. : Sure. -- this happened. : So, on the 8th, you actually believe that, from reading this -- MR. a i This. Yes. MR. : -- you believe that you actually did tr to rebuild on the 8th -- MR. : Yes. MR. : -- and not on the 10th? 70 1 MR. : Not on the 10th. Yes. 2 MR. : All right. Because that 3 way that it reads, I thought was that, you 4 didn't have them on the 8th. On the 9th, you 5 didn't have access, "And then, on the 10th, 6 when he gained access to the DVR room, he 7 attempted to replace the drives, and they 8 started to rebuild." That's how this reads. 9 MR. : That sounds about -. That 10 sounds ri ht. Yeah. 11 MR. : So, now you're thinking, 12 you actually did it on the 10th, and not the 13 8th? 14 MR. : Yeah, I know I replaced 15 the drives on the 10th, because that's when 16 they told me, like, not to do it, and it got 17 crazy. 18 MR. : All right. So, now 19 you're thinking it actually you didn't do 20 anything on the 8th. 21 MR. : Hmm. I probably know 22 about those drives being bad, and I went to go 23 get drives. 25 MR. M I! Yes. 24 MR. So -- : 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. went to look for MR. MR. them on the 8th? MR. : Hmm. I came back the next day, and that's when I replaced them. Well, the next day was MR. the 9th -- MR. MR. 71 -- so, on the 8th, you drives? : Yes. Do you think you located : The 9th. . -- and it says that you didn't have access to -- MR. : Just to replace -- MR. • -- replace. MR. -- yeah, I can't go in the room. MR. So then, it sounds like, so, you didn't do anything on the 8th -- MR. : Or the 9th. MR. • -- or the 9th. MR. Mm-hmm. MR. You obtained the hardware, but then, on the 10th -- MR. : That's when I got access to the room. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 72 MR. -- and previously, what you told us that, is that you found out on the 9th, and then on the 10th, you didn't have access to the room, so on the 10th, you did overtime that MR. overtime anyway. regardless. MR. there on the 10th MR. people there. MR. Okay. So, you were going to be working on the 10th, overtime, regardless of this camera issue? MR. : Yeah. Regardless. I was -. Because this had nothing to do with my overtime. I was doing a project. MR. : All right. Because we talked in pretty detail, in July, when and I spoke with you about, like, how someone approved your overtime to work on the 10th, specificaiiiiiiiiirk on this camera issue. MR. : No. This was not for that. ou could do it then. : I was going to be doing So, I was going to be there : You were going to be regardless? : Yeah, because we had TDY EFTA00064211 73 74 1 MR. And you -- 2 MR. No. And that's -- 3 MR. -- and then, you went on 4 where, like, on in detail about -- 5 MR. No. That's -- 6 MR. -- like, who would have 7 approved it -- 8 MR. No. What -- 9 MR. -- would it have been 10 Would it have been one of the AWs? 11 The captain? 12 MR. : I don't know who approved 13 it, but we were already working on the camera 14 project. So that's what I was doing. 15 MR. : Okay. 16 MR. I was already -- 17 MR. So, you weren't -- 18 MR. -- this had nothing to do 19 with anythin iiiiiiiiii 20 MR. : -- so, you weren't there 21 on -- 22 MR. : So, specifically, to just 23 deal with this. And if I said, okay, I'll deal 24 with it tomorrow, I probably, said, okay, I 25 don't have time today, I could deal with it 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 first thiligjiLI12_morning tomorrow. 2 MR. IIIIIIIIII: Okay. So, if you didn't 3 deal with it on the 9th, because you couldn't 4 gain access to -- 5 MR. 6 MR. MR. MR. : Yes. -- the SIS room? Yeah. How were you going to get access to the SIS room -- MR. MR. *00:43:42). MR. MR. Somebody was there -- -- (Indiscernible -- on Saturday. • Now, someone is always there from SIS on Saturday? MR. : Not always, but there was going to be somebody there on Saturday -- MR. . Okay. MR. -- because I think I asked III if he was oin g to be there Saturday MR. : All right. And III -- MR. And there was -. MR. . -- wasn't actually an SIS (Indiscernible *00:43:55)? MR. : Yes. He was an SIS. He 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 75 was just in the video room. MR. He was a telephone monitor -- MR. MR. MR. MR. work for SIS. MR. ■ been a reason why I said I'm coming back tomorrow because somebody would have been in the office tomorrow for me to get access. MR. : So, you believe either III, or one of the SIS -. So, III could gain access without an SIS employee letting him in? MR. : He has the key for the room. MR. MR. MR. believe : Monitor. -- guy. Yes. • But he didn't actually Correct? ■: No. But there would have He did? Yes. • All right. So, you , then, was going to be there on Saturday, and he was going to grant you access? MR. : Somebody was going to be there to iiiiiiiiiiccess. MR. : And previously, when you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 76 said that III was -. You said III was there on the 9th, or he was there on the 8th? MR. : That's his main post. So, he is alwa s like, there. MR. : So, he is always in the SIS room? MR. : So, for the week, yeah. That's what he's -. He's just in the room. MR. Okay. ■. As in, MR. questions. MR. MR. MR. if, can see if SIS MR. MR. *00:45:01). MR. : She is listed for August 10th. At 7:00 a.m. to 3:00 p.m. on OST number one. MR. Oh. Is that OST number : Yes. I have a couple of Oh, yeah. But what I -- (Indiscernible *00:44:50). -- was going to ask is u check the roster for the 10th, and was scheduled, or IIII, or : Okay. : Yeah. Hold on a minute. (Indiscernible EFTA00064212 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 77 one, is that the -? MR. : No. That's OSP-1. That's outside perimeter. But he still had, would have the key. So, he probably would have given me access to the room. MR. : And do you believe that you actuaiiiiiiiii with him about any of this? MR. : Yeah. We spoke about it, like -- MR. • Prior to the 10th? MR. -- yeah. MR. : When would have you spoken with him? MR. : When I went in the room, like, because he was leaving for the day, he was, like, well, you can't have access. I'll be back tomorrow. And then, I would have came MR. tell you that? MR. MR. MR. MR. check, was 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. MR. Well, and what day did he On the 8th or the 9th? That was that Friday. So, the 9th? Yeah. All right. Can you just in on that Friday? 1 MR. • 2 see his name 3 However, ou 4 MR. 5 the way that 6 MR. 7 MR. 8 MR. 9 monitor. 78 : Yeah. Let me -. I don't on the first couple of pages. want to go through the rest. : All right. So, again, this reads is -. I think you said, Excuse me? is listed for phone 10 MR. So, III is there? 11 MR. : Yeah. It looks like he 12 was assigned monitor. 13 MR. : All right. And phone 14 monitor would have been in the SIS room? 15 MR. : Yes. 16 MR. All right. And -- 17 MR. In the SIS room. 18 MR. -- and how do they -- 19 MR. (Indiscernible *00:47:43). 20 MR. -- is that M? 21 MR. It's . 22 MR. Okay. Great. All right. 23 So, he would have been the phone monitor. So, 24 your understanding, then, is on the 8th, that's 25 when it was noticed that this thing wasn't -- Right. • -- recording. Yes. And that was by an SIS 79 official? MR.I : Mm-hmm. MR. : Somebody, either a MR. : Mm-hmm. MR. • -- or a IIII. MR. Yeah. MR. : On the 9th, you went in to go fix MR. : Yes. MR. But ou went towards the end of yoili_ltifts when III was leaving? MR. IIIIIIIII: I started doing something before then, but it was going to be too late for the drives to rebuild, so even if I replaced them, it wasn't going to be, like, right away. The drives were going to start working. MR. : Well, didn't you say that it took about ei ht hours for the drives to -? MR. : A whole day. 24 hours. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. So -- MR. M i. Not eight hours. Not : eight hours. A whole 24 hours. -- so, why wouldn't you MR. have rebuilt them -- MR. MR. 9th, so that MR. MR. MR. didn't have drives, drives. MR. Well, this says that, on the 8th, you didn't have the drives. On the 9th -- MR. : Mm-hmm. MR. • -- he had -- MR. Yeah. MR. -- he did not access to the DVR -- MR. MR. MR. MR. 80 Mm-hmm. -- during the day, on the ou could check back in on the -- Probably -- -- 10th? -- well, like I said, I or I was trying to get the Mm-hmm. DVR room. Mm-hmm. -- to replace them. EFTA00064213 81 1 MR. : To replace the drives. 2 Yeah. So, it was probably later, in the end of 3 the day, I had all the drives, and I went to go 4 replace them. And that's when I couldn't go in 5 the room. 6 MR. : Okay. And then, you 7 talked to at that time, and said you would 8 be back on Saturday to do it? 9 MR. : Yeah. Yeah. 10 MR. All right. Now, in 11 talking to , she explained 12 that this was an extremely urgent matter, and 13 that she spoke to - she wrote a memo on it. 14 And she talked to the captain, and they said, 15 make sure ou et this done today. And that -- 16 MR. : Yeah. 17 MR. : -- on the 10th, when she 18 saw you -- 19 MR. : That sounds like -- 20 MR. • -- she said -- 21 MR. -- a lot of B.S. I'm 22 sorry to sa like -- 23 MR. • -- okay. 24 MR. -- that doesn't -. 25 Because this thing happened so many times, as 82 1 I've been there. Like, why would this day be 2 different from the months leading up to it, 3 where this kept happening? Like, why would -. 4 I know Epstein happened. Everybody is trying 5 to say -- 6 MR. : Yeah. 7 MR. : -- okay, this is what 8 happened, but before that, nobody even cared. 9 To be honest with ou. 10 MR. : So -- 11 MR. : I'm just going to be 12 honest. Nobody cared that the drives were bad, 13 or the recordings aren't working. Oh, those 14 recorders weren't working. Okay. Fix it, 15 And then, we will go from there. But 16 nobody, before Epstein, this was, like, a known 17 thing. 18 MR. : Okay. 19 MR. : Like, the drives would go 20 bad. There would be no video. It was no big 21 deal to arallEtirLthat building. 22 MR. IIIIIIIIII: Because you said, in 23 every other institution, within the BOP -- 24 MR. : Yeah. 25 MR. . -- this would have been 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 83 very (Indiscernible *00:49:57). MR. : This is a big deal. This is, like, you can't leave. You've got to stay here. MR. : Well, that's what she says, she said she actually wrote a memo, provided it to the captain, both said, yes, this has of to et done on the 8th. MR. : Well, if that was the case, they would have gave, me access and I would have stayed in the building. I would never get to go home. And that's what I've done before in my other institution. Any time anything fails, or if there is a big failure, you stay until it's fixed. MR. Right. And that's where MR. doing now. MR. reconcile. MR. MR. : And that's what they are -- what we're trying to : Yeah. Because the memo was written on the 8th, provided to the captain. They said, "Make sure it's fixed." She's 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 84 saying that the next time she saw you, on the 10th, and finds out that the video wasn't recorded, she says to you, why didn't you fix this on the 8th? MR. : Yeah. Good luck. Yeah. And because it doesn't even take me a day to fix -. Those problems, it takes me a couple of days, because I have to rebuild drives. Even when I rebuild the drive, the next day it's not going to work. MR. : Right. MR. : It's going to take a couple of days. And after I rebuild the drives, you have no video from the days prior. I don't even know what video you have after the drives start working. You have to go look to see what iiiiiiiiiihave. MR. : Okay. So, again, I guess that's the question of, why didn't you start working on it immediately, on the 8th? : Because I have no idea. Well -- : Well, I was working on it, MR. MR. MR. but yeah. MR. -- it was -. EFTA00064214 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 85 MR. : But, like, it looks like, it was a pattern of, okay, , it's a priority, but it's not a priority. MR. : Okay. MR. : And for somebody to say they wrote a memo to the captain, like, where is there a memos before when this happened? MR. And then, we'll have to ask, I guess -- MR. MR. : Yeah. -- (Indiscernible *00:51:16iiiiiiiiirevious memos. MR. : Yeah. There's got to be previous memos. MR. Okay. MR. : Yeah. This is - yeah, that right there. MR. So, you don't think that that's accurate? MR. : No. I would not say that that's accurate. I'm not trying to throw anybody under the bus, but to say, like, this, this day, like, it's bigger than any other time it happening, like, come on, this has been happening for months now. 86 1 MR. : Okay. 2 MR. : It's been happening since 3 I got in that building. And I was at a 4 previous institution and like I said, if this 5 was a big deal, I wouldn't even go home. 6 you've got to stay for overtime. 7 You've got to call SigNet. I'm going to give 8 you the ke for the room. 9 MR. : Well, that's what the room. 9 MR. 10 said that they did. Or at least 11 is saying that she told you that this is 12 a big deal ou've got to do it. 13 MR. : Pfft. 14 MR. : Right now. And -- 15 MR. : Oh, yeah. Everybody is 16 trying to cover their tracks. No. This is not 17 the case. I could honestly say this is not the 18 case. 19 MR. 20 MR. : And it has never been 21 previous ractice before. I had a facility 22 manager, (Phonetic Sp. 23 *00:52:05), my previous facility manager, I'm, 24 like, hey, the first time this happened, I 25 remember it because it was so weird to me that • All right. 87 1 they told me to go home. I was, like, well, at 2 my other jail, if something wasn't working, I 3 couldn't leave. Like, if he radios go down, I 4 have to stay there until the radios are fixed. 5 Like, two months ago, the radios failed, and - 6 oh, three months ago - they failed in Brooklyn. 7 They called me from MCC New York, to go to 8 Brooklyn to hel them with their radio system. 9 MR. : Right. 10 MR. : Their console. So, if 11 that was the case, they would have called MCC 12 to come, if I couldn't stay to fix the problem. 13 So, that's never been previous practice over 14 there. No. 15 MR. Okay. 16 MR. That's, like, that's news 17 to me. 18 MR. Now, are you aware that 19 the captain was notified? 20 MR. : He probably - he should 21 have been notified. It's the captain's 22 equipment every time the camera is not 23 recording. 24 MR. All right. So, but you 25 do recall, you did speak on the 8th with the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. MR. MR. 88 , with an -- Yes. -- one of the two -- (Indiscernible *00:53:00). SIS. : I talked to somebody on the 8th. Yes. MR. And you just can't specifically even kind of put yourself back into that? MR. : No. MR. Doliiiiiemember, though, on the 10th, saying, why didn't you fix this? MR. : I was so busy with everything else. Like, I don't even remember that. MR. So, you don't remember that. MR. : No. MR. Do believe it wasn't spoke with on the 8th? MR. : No. I don't believe so. MR. You don't believe you I don't. ou have any reason to that you EFTA00064215 89 1 spoke with her, or you don't -. 2 MR. : No. I believe I spoke to 3 somebody from SIS. Because that's when who -. 4 If they were trying to pull video, and they 5 couldn't pull the video, that's when they would 6 tell me, he 7 MR. • Right. 8 MR. -- there is a problem. 9 But other than that 10 MR. : So -- 11 MR. -- there is no reason for 12 me to talk to an body from SIS. 13 MR. : So, it's a likely that it 14 was 15 MR. Yes. 16 MR. : And is it likely that, on 17 the 10th, asked you why 18 wasn't this fixed? 19 MR. : If she was there, yeah. 20 MR. : Okay. 21 MR. Yeah. 22 MR. . And is it likely that you 23 told her, on the 10th, that's why I'm here 24 today, to fix it? 25 MR. Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 90 MR. Okay. Is there anything that I read to you, from this, on the, you know, on the 8th is when you determined; on the 9th you couldn't gain access; and on the 10th is when you ained access to the DVR room -- MR. Mm-hmm. MR. -- and you attempted to replace the drives. Does that all sound accurate? MR. : That sounds accurate. Yes. MR. All right. So, it is that, on the 8th, you found out; the 9th, you couldn't iiiiiiiiss -- MR. : (Indiscernible *00:54:11). Yeah. MR. -- and the 10th -. MR. M! It was all (Indiscernible : *00:54:15iiiiiiiii, MR. : Okay. So, now going forward, though, we can at least have a -- MR. MR. MR. MR. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 91 MR. a -- yes. Happened. MR. : -- that happened. So now, these questions might make a little more sense. MR. MR. MR. something? MR. MR. MR. MR. MR. MR. Okay. And -. : Hey, can I ask him Yeah. Before we go. : Please. Okay. : Please do. : So, there is something contradictory in between the 302 and the SigNet. On the 302, it states that there was a motherboard failed on DVR-2, on August 8th. MR. : Mm-hmm. MR. : It doesn't say that the hard drives failed. It says the hard drives failed on Au ust 10th. MR. . Yeah. Could you -. MR. : That's two different things. MR. : Mm-hmm. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. MR. asked, what ha MR. call. I'm not everythiniiIIIIIIII MR. : But this is, so, this was the, this is the interview of you. MR. a Mm-hmm. Yes. MR. : So, the assumption is, that you are the one who provided them this information. Correct? MR. a Yes. I am. MR. : So, with you telling them that a system failure of DVR-2 occurred on July 29th, 2019 -? MR. : I don't think I would have given them exact dates because I don't remember when all that stuff happened, to tell you the truth. Me giving exact dates, that's, I can't give exact dates. MR. Okay. MR. : Yeah. (Indiscernible *00:54:18). • -- a story of -- For what happened -- -- for what it is -- 92 So, yeah. So -- So, as -- -- accordin -- Agent ened, and when did it happen? : That, you would have to too sure the dates of EFTA00064216 93 1 MR. And then, so you think 2 that they actually located these dates on 3 themselves? 4 MR. : Yeah. They probably would 5 have to to get the exact dates. 6 MR. : So, you don't think that 7 this is actually the information you provided 8 them duriiiiiiiiiiterview? 9 MR. : No. Because I wouldn't 10 have gave them -. There is no way I would have 11 had that, or remembered this. No. 12 MR. : Okay. And then, saying 13 that the motherboard failed on DVR-2, on August 14 8th, 2019. 15 MR. : That's something -. Yeah. 16 That's information they would have got from 17 SigNet. 18 MR. : So, you don't believe 19 that this, you actually - this paragraph right 20 here - that you told them? You think that they 21 got that information -- 22 MR. : Yeah. They probably -- 23 MR. -- outside of your 24 interview? 25 MR. -- collaborated it with 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 94 SigNet. Yes. Because me and - I don't even remember exact dates today. So, like, there's no way I could remember exact dates. MR. : All right. , did you want to follow up on that? MR. : No. I mean, yeah, it comes from -. So, you're saying that the statement in the 302 is inaccurate? MR. No. MR. No. MR. No. He's not saying that's inaccurate. MR. I'm saying it's accurate, but they •ol i,ipl f r ound out dates. MR. : He's saying that he thinks that they got this information based upon another source, not from him. MR. : Not from me. MR. : Okay. MR. : Because I can't give you exact dates. That's all. MR. : All right. So, there is - just while we're on this 302 - there is another part that says, "After the incident," and that's the Epstein incident. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 95 MR. a I know. MR. : ' was asked about the cameras." MR. : Mm-hmm. MR. : Who asked you about the cameras? iiiiiiiiiecall? MR. : Pfft. The warden. Everybody. Anybody that could think about asking me uestions asked. MR. : All right. "There were two new hard drives to install." MR. a Yeah. MR. : "But installing the new hard drives would mean that all prior data -- : Yeah. MR. MR. MR. -- would be lost. : Lost. Yeah. You would lose all video. MR. lose all recording? MR. : All the old video. Yes. MR. : Oh, so, the recording of the old video? MR. : Yes. Yeah. MR. So, when you install Oh. Lose all video or 96 1 these new hard drives -- 2 MR. : The two new drives, and 3 everythin would be gone. 4 MR. -- everything is wiped. 5 MR. : So, whatever video they 6 were looking for, it would be gone. So, 7 whatever iiii iiiiii: Okay. "The trying to, it would be gone. 8 MR. 9 Warden wanted video, and so was told to 10 start workin on the system." 11 MR. : Yes. 12 MR. : So, at this time, was it 13 prior to re lacin the new, the two new drives? 14 MR. : Well, this time, that's 15 when I probabl started replacing the drives. 16 MR. : But if -- 17 MR. Yeah. 18 MR. -- if you replaced them 19 and all recordin gets -- 20 MR. : Wiped. 21 MR. -- wiped. 22 MR. Yeah. 23 MR. • Then how would you be 24 able to obtain the video? 25 MR. : Yeah, there is no video EFTA00064217 97 98 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 obtained. MR. : So, that's what I'm just trying to make sense of what this states. So, "The Warden wanted video, so MR. : They wanted me to start -- MR. -- was told -." MR. -- they wanted me to start that day recording video. We will get the recorder to work, though -- : Oh. -- (Indiscernible MR. MR. *00:57:52). MR. video of the incident -- MR. Mi Incident. MR. : -- he wanted video to (Indiscernible *00:57:56). MR. : And then, he was trying to see if there was video from the incident, and I'm, like, there is no video. And that's when, the next day, I find out there was a video on the other recorder -- MR. : Okay. MR. -- that, yeah, that other camera. : Well, he didn't want 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. : So, that helped explain it. When you were saying the warden wanted video, you're talking about from that point forward, the video -- MR. M i The video. Yeah. MR. : -- he wanted the recording to be working -- : Yeah. He -- -- not the video of the MR. MR. incident. MR. : -- well, they wanted a video of the incident, and the recorder to start working. I'm, like, there's no video, there's nothing I could do. I can't find any video. MR. : Okay. MR. That recorder is gone. MR. : I gotcha. MR. : So then, it was at that point, okay, we'll get the recorder working, and do whatever you got to do to get the recorder workin . MR. : Okay. So, it says, started removing the bad drives in order to rebuild the DVR." 99 1 MR. : Yeah. 2 MR. : Is that correct? 3 MR. Yes. 4 MR. : So, are you the ones that 5 actually removed the two -- 6 MR. : The drives. 7 MR. -- drives? 8 MR. Yeah. 9 MR. : And you -- 10 MR. And I labeled everything. 11 Yeah. 12 MR. -- and you put the new, 13 two new drives in? 14 MR. : Yes. 15 MR. All right. 16 MR. : And then, the FBI came and 17 stopped me in the middle of ever thin 18 MR. : It says, " advised 19 that the FBI agent was the one who pulled out 20 the DVR." 21 MR. : Yeah. Because I told 22 them, if you pull out the drives, that you're 23 going to have problems, there's going to be 24 corruption, because like I, like I told you 25 before, you pull out two drives, like, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 100 everything is wiped. Even if there is a video from before. You just, you're, like, out of luck. Because it's going to -- MR. : Now, can you just explain that? What is it that they pulled? : Two of the drives. • They pulled the two MR. MR. drives? MR. was -. See, what happened was, I was going to start rebuilding the drives, so I labeled everything. It was, it was the best. So, they wanted me to -. Let me if I can (Indiscernible *00:59:23). So, ever stopped working. I go in the room, IIIIII, you've got to get the recorder working. Well, I got to pull the drives out to get the recorder working. So, the two drives that I pulled out. And so, the two old drives, and the two new drives, I labeled them, because I knew that it was going to be a big thing. So, I got to pay attention to what I'm doing. And then, in the midst of all that, that's when they took the drives, and said, hey, we need to stop doing everything. MR. So, who is it that : Yeah. Yeah. Because I EFTA00064218 101 1 actually pulled the bad drives out? You or the 2 FBI? 3 MR. : I pulled the bad drives 4 out to re lace them with good drives. Yes. 5 MR. : And you put the two new 6 drives in? 7 MR. : Drives in. Yes. 8 MR. : So, what is it that the 9 FBI pulled? 10 MR. 11 drives. 12 MR. : So, you were rebuilding 13 it. And when you rebuilt it, they came in and 14 they justiiiiiiiihem all out? 15 MR. : Yeah. They would pull 16 them all. 17 MR. : So, it was never able to 18 rebuild? 19 MR. : Yes. 20 MR. : All right. So, they 21 pulled all the drives. And so, when they said 22 the DVR. Is that different from -? 23 MR. : Yeah. The DVR because 24 they pulled everything from DVR-1, and that was 25 the one that wasn't working. And then, DVR-2, : They pulled all the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 102 the one that was working, the next day, I had to get all the - well, the same day - I could get all the important parts of the prison on DVR-1, that wasn't working, on DVR-2, which I probably should have done the day before, but - MR. speaking about. MR. drive. MR. : Oh, DVR-2 was the good drive? MR. : Yes. MR. : But DVR-1 wasn't. Okay. So, DVR. MR. : And what does this say? DVR. DVR-2 is the good drive. DVR-1 is the bad drive. MR. IIIIIIIII!: Okay. So, DVR-1 -- MR. That's not - no - that's not what you said before. You said DVR-1 was all good. DVR-2 went bad. MR. : Yes. MR. : Okay. So, DVR-2 was the bad drive. : So, it's DVR-2 that we're Correct? : Yes. That was the good 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 103 MR. a Yes. MR. : So, as far as DVR-2 being the bad drive, is the DVR, is that the 16 drives, or is there a separate box -- MR. : No. It's the 16 drives, and then, you have, like, the brain, some motherboard, you know, the other computer on the bottom, but -. MR. : So, when you say, when they say that the FBI agent was the one who pulled out the DVR, you're talking about all 16 MR. : All the, they probably pulled the -- MR. -- drives and motherboard. MR. : -- they probably pulled -. Yeah. They probably took all of the recordings. But they had it take -. When I'm talking about that the next day, because we already had the new set, when all this happened, SigNet came the next day, and we had the new system up and running. Everything was in boxes. So, he had to just come in and install it. 1 MR. 2 MR. 3 took both 4 MR. 5 came and 6 MR. 7 MR. 8 MR. 9 MR. 10 says that, " 11 that, by replacing both hard drives, the system 12 would be wi ed. 13 MR. : Mm-hmm. 14 MR. : And that he had advised 15 personnel at MCC of that." 16 MR. Yes. 17 MR. : Now, when you say, 18 "Wiped," it means just everything -- 19 MR. : It means -- 20 MR. -- that was on it before? 21 MR. -- everything is gone. 22 Yes. There is no video. There's nothing. 23 MR. : And do you know how far 24 that wouliiiiiiiiine back to? 25 MR. : No. 104 Okay. So -- : So, the next day, the FBI DVR-1 and 2. So, on the 11th, the FBI ust took it all? They took it all. Yes. Everything? Everything. All right. Okay. So, it also advised that he knew EFTA00064219 105 1 MR. No? 2 MR. No. 3 MR. : So, was that the case, 4 could have we obtained video off of those -? 5 MR. : Other drives? Yes, before 6 I started rebuilding. Yes. But that's what I 7 was told to do. So, that's what I was 8 (Indiscernible *01:02:17). 9 MR. : So, just explain that. 10 What could have vie got off of it? And you're 11 talking about DVR-2 now, the bad drive. Right? 12 MR. a DVR-1 is the bad drive. 13 MR. : So, this is where I'm 14 getting confused. I thought we just said that 15 DVR-2 is the bad drive. I've got to get this 16 straight. , you just - I thought we 17 said, we did say that, but then you just chimed 18 in and said it was DVR-2 that was bad. Which 19 one was it? DVR-1 or 2 that was bad? 20 MR. : DVR-1 is bad. 21 MR. : In the initial part of the 22 interview, he stated that DVR-2 went bad, and 23 DVR-1 drives were all good. 24 MR. All right. Because yeah, 25 on the thing, it says -- 106 1 MR. : Yeah, because everything 2 was on DVR-2. 3 MR. -- "He attempted to 4 replace the drives, and he started to rebuild. 5 During the rebuild process of the drives, the 6 drives were required to be taken out of raid on 7 DVR-2." 8 MR. : Yeah. I would say on DVR- 9 2. I'm sorr confused. 10 MR. : All right. So, DVR-2 is 11 the bad drive -- 12 MR. : The bad drive. Yes. 13 MR. All right. So, on DVR-2, 14 the bad drive -- 15 MR. Yeah. 16 MR. -- could video have been 17 obtained? 18 MR. : Yes, before I started 19 doing anythin 20 MR. : So, prior to you pulling 21 them out, vie may have been able to obtain video 22 from the 9th? MR. 24 MR. 25 MR. 23 : Hmm. No. : August 9th? : No. Because it wasn't 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 recording. MR. MR. drives. MR. 107 All right. Because you had two bad So, what video are you talking about when we said we could have obtained video? MR. : Oh, well, saying that stuff there is a possibility in the background, even if you have two bad drives that stuff could have been recording over it, but that's their technical jazz. Like, I don't know anything about that. MR. MR. MR. So, in saying that -- But saying that -. -- it sounds like, okay, it is possible that we could have gotten video MR. a Video. MR. : -- for August 9th and 10th. MR. : Yes. It is a possibility. Not a strpappil2ility, but yeah. MR. IIIIIIIIII: So, it is possible, but once the two drives -- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. MR. became -- MR. MR. MR. MR. those two drives, official told you able to go back - MR. MR. 108 Yes. -- were pulled -- : Pulled. Yes. That was a -- that possibility : Yeah. • -- impossible. It was gone. Yes. All right. Now, are are you -? When the SIS on the 8th that they weren't : To do. -- and review the video - MR. : Mm-hmm. MR. • -- if something was recording in the background, would you have been - you know, like you were talking about, there is a possibility - would you have been able to tell at that time? MR. : No. I wouldn't have been able to tell. That's something SigNet would have, or some expert, video expert, would have EFTA00064220 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. MR. action to re MR. MR. 109 . All right. That's nothing above me. : Was your only course of lace those two bad drives? : Yes. • So, would, regardless, that video have been, at some point, deleted? MR. a Yes. MR. : And you were -. Who instructed you to actually pull out those bad drives? MR. : I would just have to - (Indiscernible *01:04:53) to SigNet, or -. Well, and I told SIS this before, like, if I pulled two drives, there is no video, especiall if it was bad. MR. : Did you talk to anybody on August 10th, prior to pulling them, that there was a possibility that video of the Epstein incident could have been retrieved? MR. : No. MR. : So, you didn't tell anybody that? MR. : I'm not saying I didn't 110 1 tell anybody that, but that was -. I think 2 that's something I found out later. Because 3 that's when SigNet was talking to me. But 4 that's not something I would have known before 5 Epstein. 6 MR. : All right. 7 MR. la Because that was something 8 we talked about, like, the days after that 9 happened. 10 MR. : Because this 302 says, 11 " advised that an Fg122ent was the one 12 who pulled out the DVR. also advised 13 that he knew that, by replacing both hard 14 drives, the system would be wiped, and that he 15 had advised ersonnel at MCC of that." 16 MR. : Mm-hmm. There would be no 17 video. 18 MR. : When did you do that? 19 MR. la Before I started doing 20 anything. If I'm going to change drives, 21 you're going to know, like, it's -. Because I 22 know this was going to be bigger than just me 23 fixing the recorders. Like, there is other 24 things that are going to happen, but I'm going 25 to tell you, hey, if I do this, this is what's 111 1 going to ha en. 2 MR. : But I thought you just 3 said that that's something you found out later. 4 MR. : Later. But no, as far as 5 there bein video on the background. 6 MR. Oh. 7 MR. Yeah. As far as -- 8 MR. So -. 9 MR. -- me pulling out the 10 drives, I already knew that before because 11 that's what happened the last time, when I 12 replaced two drives, that there was no old 13 video. It was ust the new video. 14 MR. : So, on the 10th, your 15 understanding, that there was no video from the 16 9th -- 17 MR. : Or the 10th. 18 MR. • -- or 10th. 19 MR. : Yes. That was my 20 understandin iiiiiiiiii 21 MR. : So, therefore, yeah, and 22 at that time, you didn't know that there was a 23 possibilit -- 24 MR. : Possibility -- 25 MR. : If things were recording 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. background. MR. MR. MR. the two dri became -- MR. MR. MR. 112 -- going in the -- in the background. Yes. And once the DVR, that ves were pulled, that possibility Became an impossibility. • -- an impossibility. Yes. MR. Okay. Before we move on from that, did anybody want to clarify any of that? MR. a drive -- MR. : Yeah. What -- : Go ahead. -- technically, when you pull : Mm-hmm. • -- like, what happens? It might be a technical question. MR. Yeah. : Like, how does everything wipe? Is that -? EFTA00064221 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 113 MR. : Oh, well, it's, like, looking for ones and zeros, and if nothing is lined up, from what the SigNet explained to me, if one drive being bad is not really a problem, because the other drives are going to -. It's the redundant. So, it's the backup, it's going to take over for that drive that's not working. Okay. MR. : But now, since this drive is not working, and this one that's working is taking, any drive is taking over for this drive, and that drive goes bad, that means we have two bad drives. That means nothing is going to be recording. : So, they work in conjunction - MR. MR. MR. MR. *01:07:25). : Yeah. -- with the other one? : Yeah. But the death of -- : The redundant. - the death of one -- : (Indiscernible *01:07:27). -- is (Indiscernible Gotcha. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 114 MR. : And then, when they both die, .lo edone. : Gotcha. And there's no way to recover an : Well, at the time, they told me no, and then they said, well, there is a possibility that it could have been recording eah. MR. IIIIIIIII: -- in the background, after the fact. ME.kay. MR. : But that was something more technical than my understanding, because of the time, if something goes bad, just, you know, take the drives out, put it in. And then, this became a bigger thing. So now, we're, like, well, there was still kind of a possibility that more things would have been happening. From my understanding. That's what SigNet told me. Okay. MR. : All right. And then, for clarity purposes, when - again, on the 8th, you found out that this was an issue, and that you 115 1 had to re lace the drives -- 2 MR. : Mm-hmm. 3 MR. : -- when did you obtain 4 the new drives? 5 MR. : It had to be some time 6 during that day or the next day. I probably 7 was lookin for drives, because if I -- 8 MR. Because you said -- 9 MR. -- if I knew -- 10 MR. -- you got them, and you 11 got them from the CSM? 12 MR. : Yeah. 13 MR. Okay. And you just don't 14 know if that, you got them from CSM on the 8th 15 or the 9th? 16 MR. : The 9th. Yeah. I know I 17 got some drives from him before because we've 18 gotten, I've gotten old drives from him before. 19 And I know we've ordered drives. I'm not too 20 sure if I ordered a whole bunch of drives to 21 just replace all 16, or whatever, how many are 22 in the raid. But we were, that was going to be 23 the next iiiiiiiiigust rebuild everything. 24 MR. : Now, if it was your 25 project, and you are the camera guy, why did he 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 116 have the drives and not you? MR. : Because he has all the hard drives in the building. Like, me having the hard drives is not part of my job description. But -- MR. : All right. So -- MR. la -- I could have them, but he's got more, like, readily available ones. And everything that I had was from the old stuff that wasn't working from before. MR. : Okay. MR. M! So, if I pulled something from that, something that wasn't working before, I don't know if it was bad. That's why it's on the shelf. Because nothing was labeled bad. It was just on the shelf. That's, it was a mess, that whole area was a mess. MR. equipment stored? MR. MR. MR. MR. near the -? MR. Okay. Where was his Oh, the CSM? Yes. His is in the server room. Is that within the SIS, : No. That's downstairs, in EFTA00064222 117 1 the first floor. 2 MR. Okay. So, the server 3 room is in the computer server room? 4 MR. : Yes. Yeah. 5 MR. • Nothing to do with the 6 cameras? 7 MR. : No. 8 MR. All right. So, you would 9 have had to have one to him -- 10 MR. : Gone up to him -- 11 MR. -- within the -? 12 MR. -- with the, yeah, at the 13 time, like, hey, , you got some drives? I 14 don't haviiiiiiiiiies. 15 MR. : Okay. So, what -? Can 16 you just explain what steps it is? You found 17 out on the 8th. What steps did you take in 18 order to resolve this issue? Do you know if 19 you -? Did you call SigNet on the 8th, or did 20 you call them on the 10th? Because the way 21 that this -. The way that this reads, just 22 look at these comments. It says this comment 23 was made on the 8th, at 3:38 p.m. -- 24 MR. : Mm-hmm. 25 MR. . -- and where it says, "Hi 118 1 IIII. Unable to locate anything official -- 2 MR. Mm-hmm. 3 MR. : -- the basic steps are as 4 follows. Set the raid level -- 5 MR. M i Oh huh. 6 MR. : -- it none and save. It 7 will -." So, what is going on here? What are 8 these instructions? This is supposed to be 9 specific to this incident. 10 MR. : Mm-hmm. 11 MR. Do you follow what's 12 going on there? 13 MR. : Yeah. Oh, so, I called 14 them on Thursday. And I probably started to 15 rebuild on Friday. But I couldn't do the 16 rebuild 17 MR. : So, you called them on 18 Thursday?__412Ia_to obtain the instructions? 19 MR. IIIIIIIII: I already knew what I had 20 to do. I always just call them to make sure 21 I'm doing ever right. 22 MR. : All right. So, on 23 Thursday, ou called them. 24 MR. : Mm-hmm. 25 MR. : And are these 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 119 instructions that I'm looking at, though, on this comment from August 8th, 2019, at 3:38 p.m.? MR. : Yeah. It looks like that's right. When I - that's where I do the rebuild, probably. Those are probably the instructions to do the rebuild. MR. MR. . Yeah. For two drives. MR. : And do ou understand who it's - when it says, "Hi IIII. Unable to locate anything official." - do you know who it is that is talkin there? MR. : It could be or MR. : Hey. Can I -- MR. : That was MR. -- can I clarify that? Because I didn't -. We know that that comment right there is by (Phonetic Sp. *01:11:18). He's a Qognify support engineer. MR. : Okay. MR. : And that's the instructions that he provided to give you MR. Okay. 120 1 MR. a Okay. 2 MR. : All right. And do you 3 know when you would have received those 4 instructions? Would it have been on the 8th? 5 MR. a i Yes. 6 MR. : Okay. And you're saying, 7 the reason why you didn't do it on the 8th is 8 because -- 9 MR. 10 MR. 11 drives -- 12 MR. 13 MR. 14 MR. 15 MR. 16 the 9th, 17 MR. 18 MR. 19 MR. 20 MR. 21 the day -- 22 MR. 23 MR. 24 MR. 25 access to go in I didn't have the drives. -- you didn't have the : Uh-huh. -- to do it? Yeah. All right. So then, on The drives. --

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