DIGITALLY RECORDED

1 2 3 4 DIGITALLY RECORDED 5 SWORN STATEMENT 6 OF 7 8 9 OIG CASE #: 10 2019-010614 11 12 13 14 15 16 17 18 DEPARTMENT OF JUSTICE 19 OFFICE OF THE INSPECTOR GENERAL 20 JULY 12, 2021 21 22 23 24 25 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 EFTA00110989 LIMITED OFFICIAL USE 1 APPEARANCES: 2 3 OFFICE OF THE INSPECTOR GENERAL 4 BY: 5 BY: 6 7 8 WITNESS: 9 10 11 12 OTHER APPEARANCES: 13 NONE 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00110990 LIMITED OFFICIAL USE 3 1 MR. : The recorder is on. My 2 name is with the U.S. 3 Department of Justice Office of the Inspector 4 General New York Field Office and these are my 5 credentials. All right. This interview with 6 federal Bureau of Prisons lieutenant 7 is being conducted as part 8 of an official U.S. Department of Justice 9 Office of the Inspector General investigation. 10 Today's date is July 12, 2021, and the time is 11 1:06 p.m. This interview is being conducted at 12 the federal correctional institution Danbury, 13 located in Danbury, Connecticut. This is the 14 training center. What is it the -? 15 MR. : SIPE Center. 16 MR. : SIPE Center? 17 MR. : Yeah. 18 MR. : What does it stand for do 19 you know? 20 MR. : Mm.... 21 MR. : SPI - whatever. It's the 22 training center. 23 MR. : SIPE. Yeah. 24 MR. : Yeah. It's the training 25 center right outside of the FCI Danbury on the EFTA00110991 LIMITED OFFICIAL USE 4 1 FCI Danbury property. Also present is DOJ OIG 2 Special Agent . This interview 3 will be recorded by me, SSA 4 Could everyone please identify themselves for 5 the record and spell your last name. To start, 6 again I am DOJ OIG Senior Special Agent 7 8 MR. : I am Special Agent 9 10 MR. : I am Lieutenant 11 12 MR. : Thank you sir. This is 13 an official DOJ OIG investigation to the death 14 of inmate Jeffrey Epstein and the surrounding 15 circumstances, and you're being asked to 16 voluntarily provide answers to our questions. 17 Will you agree to a voluntary interview with 18 the DOJ OIG? 19 MR. : Yes. 20 MR. : Thank you sir. This is a 21 form that we have for our voluntary interviews. 22 We give this to everybody that's voluntary just 23 so you know that it is voluntary. You know you 24 can stop the interview any time. You don't 25 have to answer our questions. You can leave. EFTA00110992 LIMITED OFFICIAL USE 5 1 I'm going to read it to you for the record. 2 It's United States Department of Justice Office 3 of the Inspector General Warnings and 4 Assurances to Employee Requested to Provide 5 Information on a Voluntary Basis. You are 6 being asked to provide information as part of 7 an investigation being conducted by the Office 8 of the Inspector General. This investigation 9 is being conducted pursuant to the Inspector 10 General Act as amended. This investigation 11 pertains to job performance failure and 12 security failure. This is a voluntary 13 interview. Accordingly, you do not have to 14 answer questions. No disciplinary action will 15 be taken against you if you choose not to 16 answer questions. Any statement you furnish 17 may be used as evidence in any future criminal 18 proceedings or agency disciplinary proceedings 19 or both. Then there's the waiver which says I 20 understand the Warnings and Assurances stated 21 above and I am willing to make a statement and 22 answer questions. No promises or threats have 23 been made to me and no pressure or coercion of 24 any kind has been used against me. And there's 25 the - right here - employee signature and EFTA00110993 LIMITED OFFICIAL USE 1 employee's name. You want to read that 2 yourself. Feel free to. If you agree just 3 sign 4 MR. : So it says job performance 5 failure and security failure according to-. 6 MR. : That's for everybody. 7 We're giving that - that's just the blanket 8 statement we're providing to every single 9 person that we interview. 10 MR. -: .mm 11 MR. : It doesn't necessarily 12 mean that you've done anything wrong. It's 13 just that's what the investigation is looking 14 into. You know security failure of the 15 institution - job performance failure. Because 16 someone died in this matter. And looking into 17 the surrounding circumstances with it. 18 Everybody's being provided that same - 19 MR. : Okay. 20 21 MR. : -- that same information. 22 Okay. So I just singed my name as the Special 23 Agent. And I'm printing my name. Again this 24 is 25 MR. : This is Special Agent EFTA00110994 LIMITED OFFICIAL USE 7 1 I am signing as a witness. 2 MR. : Okay. And Special Agent 3 , if you don't mind, just place the date 4 and time. Again it is July 12, 2021, and the 5 time is 1:10 p.m. now. And the place is FCI 6 Danbury Training Center. Thank you, sir. 7 Okay. Did you understand that form? 8 MR. : Yeah. 9 MR. : Okay. Cool. Is there 10 any other questions you want to ask about that 11 though? 12 MR. : no. 13 MR. : No? 14 MR. : I mean it's voluntary is that 15 right? 16 MR. : Yeah. Exactly. 17 Voluntary. You don't have to answer. And 18 again that job performance failure - security 19 failure that's something we're telling 20 everybody that that's the purpose of our 21 interviews is to figure out - 22 MR. : Okay. 23 MR. : -- what went wrong and 24 all that kind of stuff with regard to this 25 matter. Before starting the interview, I'd EFTA00110995 LIMITED OFFICIAL USE 1 like to place you under oath. Lieutenant 2 can you please raise your right hand. 3 Do you swear to tell the truth and nothing but 4 the truth during this interview? 5 MR. : Yes. 6 MR. : Thank you sir. All 7 right. Please just let me know if you don't 8 understand these questions and I'll try to 9 rephrase them or put them in a different way 10 add clarification. So what is your home 11 address? 12 MR. -: 13 MR. : And what is your date of 14 birth? 15 MR. -: 16 MR. : And your Social Security 17 number? 18 MR. 19 MR. : Thank you. And your 20 current cell phone number. 21 MR. 22 MR. : And what's your highest 23 level of education? 24 MR. : Um bachelors. 25 MR. : Where? EFTA00110996 LIMITED OFFICIAL USE 1 MR. : Criminal justice. 2 MR. : Criminal justice. Where 3 did you get that from? 4 MR. : John Jay. 5 MR. : Is that in New York City? 6 MR. : Yeah. 7 MR. : And when did you 8 graduate? 9 MR. : 2006, I think. 10 MR. : Okay. And what did you 11 do prior to working for the BOP? 12 MR. : Uh TSA. 13 MR. : Um okay. And what did 14 you do for TSA? 15 MR. : I was a screener at JFK. 16 MR. : How long did you do that? 17 MR. : Mm six and a half years. 18 MR. : From approximately when 19 until when? 20 MR. : '02 to '09. 21 MR. : '02 to '09. Okay. And 22 do you have any military service? 23 MR. : No. 24 MR. : Okay. And how long have 25 you served with the Federal Bureau of Prisons? EFTA00110997 LIMITED OFFICIAL USE 1 MR. : Mm like about 20 years. 2 MR. : Twenty years. 3 MR. : Yeah. 4 MR. : Oh, okay. So you did it 5 while you were with TSA? 6 MR. : I did TSA is federal. And I 7 8 MR. : No-no-no. With the BOP. 9 How long have you served with the BOP? 10 MR. : The BOP? 11 MR. : Sorry. 12 MR. : Twelve years. 13 MR. : Twelve years. Okay. 14 From when until when. 15 MR. : '09 to present. 16 MR. : What was your Enter on 17 Duty Date? 18 MR. Mm June 21st I think uh 2009/ 19 MR. : Okay. Any breaks of 20 service? 21 MR. : Nah. 22 MR. : Okay. And when did you 23 do you know when you graduated BOP training? 24 MR. : Mm I think it's September or 25 August. EFTA00110998 LIMITED OFFICIAL USE 11 1 MR. : Of ;09? 2 MR. : You're talking about Glencoe, 3 right? 4 MR. : Yeah. 5 MR. : Yeah '09. 6 MR. : '09. Okay. And when and 7 where was your first office assignment with the 8 BOP? 9 MR. : New York. 10 MR. : Uh which institution? 11 MR. : MCC. 12 MR. : Were you with MCC the 13 whole time? 14 MR. : Yeah. 15 MR. : Oh, okay. And when did 16 you become a lieutenant? 17 MR. : What's this '21 - 2019, 118 18 I think December 17th I did a temp. 19 MR. : December of 2017? 20 MR. '17. Yeah. 21 MR. : And when did you leave 22 the MCC? 23 MR. : I left December '19. 24 MR. : December of 2019? 25 MR. : Yeah. EFTA00110999 LIMITED OFFICIAL USE 12 1 MR. : And then is that when you 2 came here to the FCI Danbury? 3 MR. : Yeah. 4 MR. : And um did you come here 5 for a promotion? 6 MR. : Yeah. 7 MR. : So were you a GS9 8 lieutenant? 9 MR. : I was a 9 there but I got TDY 10 down there. So I was 11 also there. 11 MR. : Oh you were? 12 MR. : Yeah. I got TDY for about 13 four months. 14 MR. : Okay. Can you just - 15 what does that mean? 16 MR. : Temporary Duty. Like I 17 was picked up. I got my promotion, but I had 18 to stay down there for a few months until I 19 came up here. 20 MR. : Okay. So FCI Danbury. 21 You were promoted to an 11 but they had you 22 stay down there as an 11 for four months? 23 MR. : Yeah. 24 MR. : So when were you actually 25 picked up? EFTA00111000 LIMITED OFFICIAL USE 1 MR. : About three months. In 2 October, September, October, November, three 3 months. Yeah. 4 MR. : So when did you actually 5 get your promotion? 6 MR. Mm September. 7 MR. : Of 2019? 8 MR. : Yeah. 9 MR. : And when did you 10 physically come to the FCI Danbury? 11 MR. : December. 12 MR. : December. Okay. And 13 your current position is still GS11 lieutenant? 14 MR. : Yeah. 15 MR. : And what was your 16 position at the MCC on August 9th and 10th of 17 2019? 18 MR. : Uh August you said 10th? 19 MR. : Yeah. So August - you 20 said September you got your 11 so I'm assuming 21 in August of 2019 you were 22 MR. : I was a 9 then. 23 MR. : -- a 9 lieutenant. 24 MR. : Yeah. In August yeah. 25 MR. : And this is just for my EFTA00111001 LIMITED OFFICIAL USE 14 1 own knowledge. What is the difference between 2 a 9 lieutenant and an 11 lieutenant? 3 MR. : Pretty much you could - 4 if you at 9 you can't run the institution. 5 Because it's not a higher rank. So like 11 or 6 the only ones who can without a captain. 7 You're the highest. But a 9 you can't be the 8 highest. 9 MR. : So does that mean like as 10 far as like being the ops lieutenant versus the 11 activities' lieutenant? 12 MR. : Nah. You could be ops as a 13 9. 14 MR. : Okay. 15 MR. : But - but -. 16 MR. : So like acting captain 17 you mean? 18 MR. : No. Say like if it's a 9, 19 it's like evening watch. Four to twelve or 20 midnight. The 11 is the highest authority. 21 MR. : Okay. 22 MR. : As a 9 you can't do that. 23 You have to have 11 or above for 9 to be in 24 authority. 25 MR. : Okay. EFTA00111002 LIMITED OFFICIAL USE 1 MR. : Yeah. 2 MR. : So you can be an ops 3 lieutenant but somebody else has to be there 4 that's higher than you? 5 MR. : Yeah. If you a 9 yeah. 6 MR. : Okay. Do you recall what 7 shift you worked on August 9th and 10th of 8 2019? 9 MR. : August 9th? What day was 10 that? 11 MR. : It's August 9th - sorry. 12 We'll just talk about August 9th. August 9th, 13 2019 that was the day before Epstein was found 14 dead. It was a Friday. 15 MR. : So the Friday. I probably 16 was day watch. 17 MR. : Okay. I'm going to give 18 you the daily roster from that date just do you 19 can reprint it. 20 MR. : Yeah. 21 MR. : Um anytime I give you a 22 document - you don't have to do it right away - 23 but you can - I'm just going to have you 24 initial and date each document. It's just for 25 the record we can say that's the document you EFTA00111003 LIMITED OFFICIAL USE 1 looked at. And we don't like replace 2 something. You know what I mean? 3 MR. : Mm-hm. 4 MR. : Um so on that can you 5 find your name and see where it is that you 6 worked just to verify? 7 MR. : Yeah. I did overtime from 8 6:00 to 2:00. 9 MR. : From 6:00 a.m. to 2:00 10 p.m.? 11 MR. : Yeah. 12 MR. : And that was on August 13 9th? 14 MR. : Yeah. 15 MR. : Do you know if you - 16 there were the specific times that you worked? 17 I know for instance the individual that was the 18 activities' lieutenant after you. She didn't 19 start until 4:00 p.m. because she had her 20 regular time shift until 4:00 p.m. 21 MR. : Mm-hm. 22 MR. : Would that mean that you 23 had worked until 4:00? Or would you still have 24 stopped at 2:00? 25 MR. : Uh I don't know. EFTA00111004 LIMITED OFFICIAL USE 17 1 MR. : Do you usually have to 2 wait until the new activities' lieutenant comes 3 on board? 4 MR. Mm that's was -. But 5 she wasn't a lieutenant here though. 6 MR. : No. She was an SIS, but 7 she got I guess temporarily promoted. At least 8 for that day to be able to be the activities' 9 lieutenant. But she was in attorney conference 10 until 4:00 p.m. And she didn't start as the 11 activities' lieutenant until 4:00 p.m. 12 MR. : I don't remember. But I know 13 we usually - even though it says 8:00 to 4:00, 14 we usually do 6:00 to 2:00, 2:00 to 10:00 15 anyway. 16 MR. : Yeah. 17 MR. : We relieve people early. 18 MR. : Right. And my 19 understanding is it's for traffic purposes. 20 MR. : So if the 9th I would have 21 came on then. She wouldn't have to stay until 22 4:00. I don't know. 23 MR. : How does that typically 24 work though I guess. Would it be - do you have 25 to be relieved before you can leave? EFTA00111005 LIMITED OFFICIAL USE 18 1 MR. Mm you mean for me? 2 MR. : Yeah. Like if you're the 3 activities' lieutenant at the MCC back in 4 August of 2019. Are you allowed to leave 5 before the new activities' lieutenant takes 6 over? Or do you have to wait until she's done? 7 I'm just trying to help refresh your memory if 8 you can -. 9 MR. : I'm not sure. I know how we 10 do it is someone day I got you. I'll cover 11 you. Then we relieved. 12 MR. : But you don't 13 specifically remember this date? 14 MR. : No. 15 MR. : Not the fact that like 16 Epstein died the day after. Does that help you 17 like kind of refresh your memory of what your 18 involvement may have been? 19 MR. : I know I was doing day watch. 20 I was doing day watch. I do know that. But as 21 far as who relieved and all that. No. I don't 22 remember that. 23 MR. : All right. We can 24 probably just grab your time and attendance 25 records then later just to try to EFTA00111006 LIMITED OFFICIAL USE 19 1 (Indiscernible * *00:12:34) that down. But you 2 just can't remember at this point? 3 MR. : What you asked me was I 4 there? 5 MR. : Yeah-yeah-yeah. Just I 6 mean from the 2:00 to 4:00. You don't remember 7 if you would have - you had to wait until 8 was actually in place before you left or 9 not. 10 MR. Nah. I don't know. I could 11 have been there at 4:00 because I left at 2:00. 12 I'm not sure. 13 MR. : Okay. Fair enough. 14 MR. : Yeah. 15 MR. : So you either worked 16 until 2:00 p.m. or 4:00 p.m. you just don't 17 recall. 18 MR. : Yeah. 19 MR. : All right. And who did 20 you - on that date - who would have you 21 primarily worked with? 22 MR. : Mm I don't know. Because 23 Friday -. I don't know why I'm doing overtime 24 on Friday. I'm trying to think. And is 25 normally not the ops lieutenant though either. EFTA00111007 LIMITED OFFICIAL USE 20 1 MR. : Is that because he was a 2 9? 3 MR. is 11. He's SHU 4 lieutenant. 5 MR. : At that time was the 6 SHU lieutenant. 7 MR. : Oh no-no-no was the SHU 8 lieutenant. Okay. So if I'm on Friday and 9 Saturday, then -. 10 MR. : Well here if -. 11 MR. : Maybe. I don't know. You 12 have my what's her name records? 13 MR. : This is Saturday. So I'm 14 giving you the daily assignment roster. 15 MR. : I'm thinking this is my day 16 off. I'm thinking Friday was my day off. So I 17 came in for the overtime on Friday. If I'm on 18 Friday and Saturday, then I would be ops. 19 That's what I'm thinking. 20 MR. : Did you work on Saturday? 21 MR. : Saturday I was off. 22 MR. : Okay. So you're not on 23 that list that I just gave you for Saturday? 24 MR. : No. I should be on day 25 watch. EFTA00111008 LIMITED OFFICIAL USE 1 MR. : Okay. 2 MR. : This the day Epstein died 3 right? 4 MR. : Yes. 5 MR. : Yeah. I wasn't there that 6 day. 7 MR. : Okay. But you just can't 8 remember if you worked until 2:00 p.m. or 4:00 9 p.m. on August 9th. 10 MR. : No. 11 MR. : Again there's no reason 12 that I'm asking you this specifically right 13 now. It's just to try to make sure we know 14 what time you worked there. 15 MR. : Well you trying to see if 16 there's a pattern of -. 17 MR. : no-no-no. Not a pattern. 18 It's not looking at you. It's just to - you 19 know when we talk to people, we say like what 20 time were you there from. Just because in 21 knowing that didn't start until - 22 because there's no reason for us at this point 23 to get your time and attendance records. 24 Because again we're just talking to everybody 25 that was there on each day. EFTA00111009 LIMITED OFFICIAL USE 1 MR. : Mm-hm. 2 MR. : I'm just trying to -. 3 When we talk to you, we just need to lock down 4 each person. What time were you there until? 5 MR. : I don't know. 6 MR. : We have specific questions 7 about what happened during the day. But if 8 you're not there during the day during that 9 specific time -. 10 MR. : Some questions might not 11 apply to you. 12 MR. : Apply to you. That's what 13 we're trying to figure out. So what time were 14 you there until. 15 MR. : I mean so you want to ask me 16 questions up until 4:00 is what you're saying? 17 MR. : We'll ask you 18 specifically questions -. 19 MR. : Well you can do it but if I 20 don' remember I just say I don't remember. 21 MR. : Yeah. That's fine. You 22 just don't. but at this point you just don't 23 know if you were there until 4:00. 24 MR. : No. 25 MR. : Um and you don't remember EFTA00111010 LIMITED OFFICIAL USE 1 relieving . Or relieving you. 2 MR. : no. 3 MR. : And do you remember being 4 relieved by anyone? 5 MR. : no. 6 MR. : No? All right. But I 7 guess then that goes back to my original 8 question. Do you need to be relieved by 9 someone in order to leave? 10 MR. : Um normally. It depends. 11 MR. : Can there be just an ops 12 lieutenant and no activities' lieutenant on 13 during the day? 14 MR. : Yeah. That could be any day. 15 MR. : Okay. 16 MR. : Yeah. 17 MR. : So it's just - there's 18 no-. these are genuine questions. We don't 19 know the answers to these. So that's not like 20 abnormal to have like just like a two-hour gap 21 where there's no activities' lieutenant? 22 MR. : No. We was going a lot of 23 work up until this. We were doing a lot of 24 work. So some days you'll be there. I'm quite 25 sure looking at the records, you'll see my name EFTA00111011 LIMITED OFFICIAL USE 1 by itself. 2 MR. : Right. 3 MR. : So. 4 MR. : On some days there was 5 just like one activity or one ops lieutenant? 6 There was nobody -? 7 MR. : Yeah. 8 MR. : Okay. And that was 9 Monday through Friday? Not just on weekends? 10 MR. : Any day. 11 MR. : Or night shifts? Or 12 morning? 13 MR. : Any days. It was a busy time 14 back then. 15 MR. : Yes. Um. Okay. Do you 16 know at that time who was your supervisor? 17 MR. : Uh the captain. Captain 18 19 MR. : Okay. And as the 20 activities' lieutenant, and you said it was day 21 watch? 22 MR. : Yeah. 23 MR. : What were your duties and 24 responsibilities? 25 MR. : Rounds um orderly EFTA00111012 LIMITED OFFICIAL USE 1 institution. Running the institution. 2 MR. : And what does a round 3 consist of as a lieutenant? 4 MR. : Going up to the unit. 5 Speaking to the officer. If you want, go to 6 unit team. Do the tiers. See what's going on. 7 MR. : Now at that time, did 8 lieutenant -? When you say go do tiers. Were 9 Lieutenants responsible for conducting rounds 10 of inmates as well? Like you know walking up 11 and down the tiers to make sure? 12 MR. : Something like that. I mean 13 that's - are we - the lieutenants responsible 14 for that? 15 MR. : Yeah. I know that that's 16 the CO's primary responsibility. But when you 17 are conducting a round in like a unit, 18 specifically we'll talk about the SHU. If you 19 visit the SHU, and on this date, there was no 20 SHU lieutenant. Correct? 21 MR. : No. 22 MR. : So if you were visiting 23 the SHU, are you responsible to conduct any 24 rounds of the tiers as a lieutenant? 25 MR. : Yeah. The lieutenant has to EFTA00111013 LIMITED OFFICIAL USE 1 make a round in SHU each shift. 2 MR. : So when I say - but when 3 you visit the SHU, is it just visiting the SHU? 4 Checking in with the officers? Or do you - I 5 mean - checking in with the COs or is it 6 actually also doing a round of - where the 7 inmates are located and looking in their cells? 8 MR. : I mean yeah, you're supposed 9 to do a round. 10 MR. : Okay. So that -. 11 MR. : You mean exactly what do you 12 supposed to specifically do? 13 MR. : Yeah. I guess what I'm 14 asking is what does a lieutenant round in the 15 SHU consist of? 16 MR. : I don't know. I know for me, 17 I used to like to go down the tiers. 18 MR. : To actually check on the 19 inmates. 20 MR. : Yeah. 21 MR. : So you're actually doing 22 -? 23 MR. : Do a whole complete round. 24 MR. : So you're actually doing 25 a round of the inmates not just doing a round EFTA00111014 LIMITED OFFICIAL USE 27 1 in the SHU to say hey are you guys good with 2 the officers. 3 MR. : Nah. Unless something 4 happens. Like if something happens you know. 5 They just say you all right - it was a BA. All 6 right. I'll be back or something like that. 7 But. 8 MR. : Right-right. You mean if 9 you got called out or something like that - you 10 needed the run. 11 MR. : That or they call you. 12 MR. : Right. 13 MR. : Something specific to a 14 specific tale or -. 15 MR. : Yeah-yeah. But were you 16 responsible - and this is just in general not 17 just specifically you? It's any lieutenant. 18 If there's no SHU lieutenant responsible to do 19 a round on day watch of the inmates when they 20 visit the SHU. 21 MR. : I'm not sure. 22 MR. : You're not sure. But you 23 did. 24 MR. : That day? 25 MR. : No I mean just in EFTA00111015 LIMITED OFFICIAL USE 28 1 general. Like when you would visit the SHU you 2 would do that? 3 MR. : Yeah. Say like if I fill in 4 or whatever. And there's no SHU lieutenant to 5 say hey you got to make a round. All right. 6 Or you have activities do it or whatever. 7 MR. : So ops lieutenant tells 8 you to do the round? 9 MR. : Anyone could say hey I'm 10 going up there or hey I got the round or 11 whatever. 12 MR. : Does a lieutenant have to 13 do a round on that shift? 14 MR. : That would be yeah you have 15 to do a round. 16 MR. : Okay. So at least one 17 lieutenant on day watch on August 9, 2019, had 18 to do a round in the SHU of the inmates? 19 MR. : On day watch? 20 MR. : Yeah. 21 MR. : Uh yeah. 22 MR. : What about night watch 23 and morning watch? Do they have to do it on 24 those? 25 MR. : Night watch and morning watch EFTA00111016 LIMITED OFFICIAL USE 1 yeah. 2 MR. : So every shift a 3 lieutenant has to -. 4 MR. : Three shifts you got to do a 5 round. 6 MR. : And that -? 7 MR. : Supposed to do a round. 8 MR. : And that's with the 9 inmates not just checking in? 10 MR. : I'm not sure. 11 MR. : Oh you're not sure. But 12 you would? When you did it? 13 MR. : I'm on (Indiscernible * 14 *00:19:51). I'm trying to move around. 15 like to hit the tiers. 16 MR. : Okay. Cool. Do you remember 17 who you replaced on that day? 18 MR. : Who I relieved? 19 MR. : Yeah. 20 MR. : Who I relieved? 21 MR. : Who relieved -? 22 MR. : Nobody. 23 MR. : So because there's no 24 activities' lieutenant prior to you? 25 MR. : No. EFTA00111017 LIMITED OFFICIAL USE 30 1 MR. : And that's because yeah 2 there's only - for the morning watch is there 3 only an ops lieutenant? 4 MR. : Yep. 5 MR. : So you were the first one 6 in on that day? And you said you arrived when? 7 MR. : Um 6:00. 8 MR. : 6:00 a.m. Okay. And you 9 said you just don't recall who replaced you or 10 if you stayed until 4:00. Correct? 11 MR. : Yeah. Did you look at the 12 video? 13 MR. : We didn't - haven't had a 14 reason to yet. I just assumed you would have 15 remembered. 16 MR. : No. I don't remember. 17 MR. : Okay. 18 MR. : It was '19. 19 MR. : Yeah-yeah-yeah. No just 20 because of the - you know this was probably one 21 of the biggest things that's ever happened. 22 MR. : Yeah but that's why I'm like 23 why are they asking about it now? That's why 24 I'm like -. 25 MR. : Yeah. I mean now is just EFTA00111018 LIMITED OFFICIAL USE 31 1 because there's things that have happened in 2 the past month that now is creating a -- 3 MR. : Oh with the case. 4 MR. : Yeah. That we now have 5 to interview a ton of people to be able to find 6 out who was there, what happened, and all that 7 kind of stuff. 8 MR. : Yeah. But I'm not sure about 9 the time on that. 10 MR. : All right. And are you 11 familiar with Jeffrey Epstein? 12 MR. : Yeah. 13 MR. : Did you ever work or 14 visit the SHU while Epstein was assigned to the 15 SHU in July and August 2019? 16 MR. : Probably yeah. 17 MR. : Did Epstein have a 18 cellmate when he was in the SHU? 19 MR. : Up until that day, right? 20 MR. : Yes. And do you know if 21 there was a reason why Epstein was assigned a 22 cellmate? 23 MR. : In SHU you're supposed to be 24 double bunked. 25 MR. : Okay. So -. EFTA00111019 LIMITED OFFICIAL USE 32 1 MR. : Even if you don't have the 2 whole prior thing before. 3 MR. : So everybody in the SHU 4 is supposed to be? 5 MR. : Not everybody. But you got 6 certain cases. But he was supposed to have a 7 bunk. 8 MR. : So as far as who would - 9 who wouldn't be assigned a cellmate? 10 MR. : House alone, rec alone 11 inmates. You know hunger strike inmates, 12 NPOs... 13 MR. : But Epstein was one of 14 those inmates that should have had a cellmate? 15 MR. : Yeah. He was a regular 16 inmate. Yeah. 17 MR. : Okay. Um are you aware 18 that Epstein had attempted to commit suicide on 19 July 23, 2019? 20 MR. : Yeah. 21 MR. : And were you one of the 22 responding officers to that? 23 MR. : No. 24 MR. : Were you - did you have 25 any involvement with it? EFTA00111020 LIMITED OFFICIAL USE 1 MR. : That incident? No. 2 MR. : No. Do you know what 3 transpired? 4 MR. : They say he put something 5 around his neck. In his cell. And that was 6 it. 7 MR. : Did you ever hear any 8 rumors that his cell mate may have tried to 9 harm him? 10 MR. : Oh yeah. You're talking 11 about um -. Yeah. I heard about that. Yeah. 12 MR. : What did you hear about 13 that? 14 MR. : That it was a ploy for him to 15 get (Indiscernible *00:22:43). Something like 16 that. 17 MR. : All right. So did you -? 18 Is your understanding that he actually did try 19 to harm himself? Or was it your understanding 20 that his cell mate tried to harm him? 21 MR. : You're talking about the 22 rumor? 23 MR. : Yeah. What is your 24 understanding of -- 25 MR. : The rumor was the guy -- EFTA00111021 LIMITED OFFICIAL USE 1 MR. : -- what actually -? 2 MR. : -- also had a high-profile 3 case. 4 MR. : Okay. 5 MR. : And I think Epstein was up 6 for a bail hearing. So they made it look like 7 he was doing that in order to get better. 8 MR. : Okay. 9 MR. : Yeah. 10 MR. : Do you think there was 11 any legitimacy to the rumor? 12 MR. : I don't know. Not after 13 this. Nah. 14 MR. : No. 15 MR. : No. 16 MR. : All right. So do you 17 believe that he did actually try to harm 18 himself on July 23rd? 19 MR. : Yeah. 20 MR. : Okay. Um do you know as 21 a result of July 23rd if Epstein - if anything 22 happened with Epstein? Was he removed from the 23 SHU and placed anywhere else? 24 MR. Mm. He went to suicide 25 watch. EFTA00111022 LIMITED OFFICIAL USE 35 1 MR. : Okay. And what happens 2 on suicide watch? Is that outside of the SHU? 3 MR. : Yeah. 4 MR. : And then after you get 5 placed on suicide watch. Is that a temporary 6 thing and then you get moved over to psych 7 observation? 8 MR. : Not all the time. No. 9 That's up to psych. Psych makes that call. 10 MR. : Do you - are you aware if 11 Epstein was outside of the SHU and on suicide 12 watch or psych observation for approximately 13 one week? 14 MR. : I know he was definitely on 15 there. Because I remember seeing him. 16 MR. : You saw him there? 17 MR. : Yeah. 18 MR. : Um is that because you 19 were doing rounds? Or why did you see him 20 there? 21 MR. : I had to - because I'm the 22 one who does the showers. 23 MR. : Okay. 24 MR. : For suicide inmates. On 25 psych watch if you're down there. So he was EFTA00111023 LIMITED OFFICIAL USE 36 1 down there one day - probably a couple days. 2 But I know I took him to the shower one time. 3 Yeah. 4 MR. : Okay. So you had some 5 interaction with him. 6 MR. : Yeah. 7 MR. : While he was in suicide 8 watch. 9 MR. : Suicide watch. Yeah. 10 MR. : Okay. And I just thought 11 - I thought you were only on suicide watch for 12 like 24 hours. And then after that it was 13 called psych observation. Is that not your 14 understanding? 15 MR. : It's up to psych. 16 MR. : Okay. 17 MR. : That's a psych call. 18 MR. : But is it in the same - 19 they're in the same location. Correct? 20 MR. : Yeah but people who are on 21 suicide watch longer than 24 hours. 22 MR. : Okay. 23 MR. : Yeah. 24 MR. : So your understanding the 25 whole time he was there it was called suicide EFTA00111024 LIMITED OFFICIAL USE 1 watch? 2 MR. : I don't remember. 3 MR. : Okay. 4 MR. : The whole time he was there. 5 MR. : Um do you know when he 6 was removed from suicide watch? 7 MR. : No. 8 MR. : Do you know why he was 9 removed from suicide watch? 10 MR. : He would be moved because 11 psych said it's okay. 12 MR. : Okay. And when someone 13 is on suicide watch, what does it entail? 14 MR. : You have a suicide smock. 15 Suicide mattress. And a suicide blanket. And 16 you allow pretty much no items unless they 17 approved it, they supposed to have. 18 MR. : Okay. And what's the 19 difference? What is the difference between 20 psych observation? What does that entail? 21 MR. : You got the clothes. 22 MR. : All right. So when 23 you're on suicide watch, you don't have 24 clothes? 25 MR. : Naked. EFTA00111025 LIMITED OFFICIAL USE 38 1 MR. : You're naked the whole 2 time? And you know if Epstein was naked that 3 whole time? 4 MR. : He had a smock and a -. 5 Yeah. He didn't have no clothes. 6 MR. : He didn't have clothes 7 when he was on suicide watch? 8 MR. : You can't have clothes on 9 suicide watch. 10 MR. : Okay. All right. So 11 does it sound right that he would have been 12 removed about a week later around July 30th. 13 Does that sound like a date -- 14 MR. : I don't know. 15 MR. : -- or you're not sure? 16 MR. : Mm-hm. 17 MR. : Okay. Did you ever 18 receive any instructions from anyone with 19 regard to Epstein being assigned a cellmate 20 after he came back from suicide watch? 21 MR. : I'm not sure. 22 MR. : You don't remember any 23 verbal conversations or anything like that? 24 MR. : No. 25 MR. : All right. I'm going to EFTA00111026 LIMITED OFFICIAL USE 39 1 show you an email. And then you can tell me if 2 you remember receiving it. An email from a 3 Do you know who that is? 4 MR. : Yeah. 5 MR. : All right. It's to 6 Suicide Watch / Psych Observation Update. And 7 that's also what the subject is. And it's from 8 July 30, 2019. It says, "Inmate Epstein" and 9 it gives his reg number. "Is being taken off 10 of psych observation and needs to be housed 11 with an appropriate cellmate." Do you recall 12 receiving -? 13 MR. : Yeah. It's a generic. We 14 always get those. 15 MR. : You get those? 16 MR. : Yeah. 17 MR. : There's names on the 18 back. It shows that you were one of them and 19 that you read it. Do you see your name? Yeah. 20 It would be under J. So. It's all 21 alphabetical. 22 MR. : It's under what? 23 MR. : It would be your first 24 MR. : Oh, okay. Yeah. 25 MR. : So does that ring a bell? EFTA00111027 LIMITED OFFICIAL USE 1 Do you remember getting that? 2 MR. : Yeah. 3 MR. : Okay. Cool. And then do 4 you recall -? So you are aware that he needed 5 a cellmate then. Correct? You already said 6 that you knew he needed one because he was a 7 regular inmate. Right? 8 MR. : Yeah. But I don't know what 9 this is at 12:30 the 30th right? 10 MR. : Yeah 7:30 - so yeah. 11 MR. : Oh it was 7:30 July 30th? 12 So he got off on July 30th? 13 MR. : Correct. 14 MR. : Okay. 15 MR. : Placed back in the SHU 16 and required a cellmate. 17 MR. : Okay. 18 MR. : And just before we 19 forget. Do you mind just initialing and dating 20 each one of these documents just so that they 21 don't start piling up? And as well as that 22 email. Thank you, sir. Now do you remember 23 having any conversations with anyone else like 24 verbal. Like or anybody regarding the 25 need for him to have a cellmate? EFTA00111028 LIMITED OFFICIAL USE 41 1 MR. : No. 2 MR. : Because, I'm assuming, he 3 was the most high-profile if not one of the 4 most high-profile inmates at the time. 5 Correct? 6 MR. : Yeah. 7 MR. : So would that be 8 something that they would - people would 9 usually communicate with the activities and the 10 ops lieutenant about? 11 MR. : I mean if you got the email. 12 MR. : Okay. 13 MR. : Yeah. 14 MR. : You got a follow-up that 15 you wanted to ask something? 16 MR. : We'll finish up on this. 17 Because it's going back one. 18 MR. : No-no. Please. Go 19 ahead. 20 MR. : So you mentioned that you had 21 interacted with Epstein when he was on suicide 22 watch. You took him for his showers. 23 MR. : Yeah. 24 MR. : How was the interactions with 25 him? EFTA00111029 LIMITED OFFICIAL USE 42 1 MR. : You know, cuff up, take him 2 to the shower. 3 MR. : Did you ever talk to him? 4 MR. : Yeah. 5 MR. : Was he pleasant? Were there 6 any issues with that? 7 MR. : He was saying hey, while I'm 8 down here, pretty much he asked why he was down 9 here. I said well, he was like yeah, I'm not 10 suicidal, such-and-such. And you know let me 11 talk to psych so I could get off this. I don't 12 think he liked it. 13 MR. : This was immediately after 14 the July 23rd? 15 MR. : I don't know exactly what day 16 it was. But you know it was around there. 17 MR. : Got it. 18 MR. : We're going to follow-up 19 with some of those more lines of questioning 20 later on in the interview. Um so you don't 21 recall though receiving specific instructions 22 from Captain or anyone else with regard 23 to Epstein? You just - you do know he needed 24 one and you did get the email? 25 MR. : These come all the time. Any EFTA00111030 LIMITED OFFICIAL USE 43 1 inmate comes off of watch, they send it out. 2 MR. : And should everyone know 3 if someone comes off of watch that they are 4 required to have a cellmate? 5 MR. : I'm not sure. I mean that's 6 what they do. They come out. Anyone comes off 7 suicide watch, you put them in with a cellmate. 8 MR. : Yeah. And that's pretty 9 general, common knowledge. Correct? And where 10 do you learn that? Is that from your daily 11 operations? Or do you learn that in training 12 as well? 13 MR. : I don't know. I guess it's 14 daily operations. 15 MR. : Okay. But most people 16 should know that a person coming off of suicide 17 watch is required to have a cellmate. 18 MR. : Uh I mean it depends. I 19 don't know. I know we get these emails though. 20 They send them out any time an inmate comes 21 off. You try to put them with a cellmate. But 22 then again like I said in the SHU, it's you 23 know. Because even if they come off suicide 24 watch, they don't -. Say like they come off 25 they stay in SHU for a year. They have to have EFTA00111031 LIMITED OFFICIAL USE 44 1 a cellmate for a year. You understand what I'm 2 saying? So as far as the notice we get, but do 3 everyone know that? I'm not sure about that. 4 MR. : But you knew. 5 MR. : Yeah. 6 MR. : How did you know though? 7 MR. : I got the email. 8 MR. : Okay. So, your knowledge 9 is from the email, but earlier, you said that 10 anybody in the SHU, anyway, needs to a cell 11 mate? 12 MR. : Yeah. 13 MR. : All right. So, he had 14 basically two requirements to him. One, there 15 was the email that he received; also, the fact 16 that he was in the SHU, and he didn't have any 17 of those special requirements, like, he was 18 going to harm someone else, or something like 19 that, that he should have had a cellmate? 20 MR. : Right. 21 MR. : All right. And do you 22 know if you ever communicated that to anybody, 23 when you visited the SHU in July or August of 24 2019? 25 MR. Hmm. I'm not sure. EFTA00111032 LIMITED OFFICIAL USE 45 1 MR. : Like, the people that 2 worked in the SHU, would have you would have 3 been as the activities' lieutenant, if you're 4 doing a round in there. Is that something that 5 you would address? 6 MR. : Bring up? Yeah. If I - yeah 7 - but if he had a - one - if he had a cellmate, 8 though. 9 MR. : Right. 10 MR. : Yeah. Bring something up if 11 they didn't. Uh-huh. 12 MR. : So, you'd only bring it 13 up if you knew he didn't have one? 14 MR. : So, like, if you say, hey, 15 guys, how many single cells I have? Such and 16 such. Hey, what's going on? Hey, well, this is 17 the reason. Yeah. 18 MR. : And is that something - 19 when you would visit the SHU - is that 20 something you would ask? How many single cells 21 do you have? 22 MR. : Yeah. 23 MR. : Is that a like one of the 24 check-the-box things? Does everybody that 25 visits the SHU EFTA00111033 LIMITED OFFICIAL USE 46 1 MR. : I can't speak for everybody. 2 But I know, even as OIC, we said, hey, you know 3 the fine, we have single cells. Maneuver to 4 condense it for space. Stuff like that. 5 MR. : Okay. 6 MR. : So, I don't know if everyone 7 (Indiscernible *00:32:18) into it. 8 MR. : But that's what you would 9 do? When you were the activities' lieutenant? 10 MR. : No. Sometimes. 11 MR. : Okay. 12 MR. : If I seen someone without, 13 hey, what's going on with this dude? Well, he's 14 housed (Indiscernible *00:32:28) room. 15 MR. : Okay. 16 MR. : Okay. 17 MR. : But when you would visit 18 the SHU, was that something you would address, 19 saying how many single cells do we got? 20 MR. : I'm not the SHU lieutenant. 21 MR. : Oh, only if you're the 22 SHU lieutenant? 23 MR. : Yeah. 24 MR. : I'm talking about -- 25 MR. : The SHU lieutenant -- EFTA00111034 LIMITED OFFICIAL USE 1 MR. : -- when you do your 2 rounds. 3 MR. : -- you do the rounds, you 4 only say it if you know that someone got - a 5 new come in. Okay, you got space for him. No. 6 Right now, we've got to put him in a single 7 cell, or something like that. 8 MR. : Okay. And were you ever 9 the SHU lieutenant? 10 MR. : At MCC? 11 MR. : Yeah. 12 MR. : I don't think so. I was 13 never SHU lieutenant. 14 MR. : Okay. But do you 15 remember ever having any conversations with 16 anyone in the SHU -- 17 MR. : No. 18 MR. : -- at the MCC about 19 Epstein and his cellmate requirement? 20 MR. : No. 21 MR. : No? All right. So, 22 referring to the duty assignment roster, who 23 were the MCC's supervisor on duty, with 24 responsibility for overseeing the SHU on August 25 9, 2019, when you were working? EFTA00111035 LIMITED OFFICIAL USE 48 1 MR. : It would be me and 2 MR. : So, the two of you would 3 be responsible? 4 MR. : On day watch. Yeah. 5 MR. : Okay. And then, would it 6 be the same thing for the shift after you? 7 Would that be the activities' lieutenant and 8 the ops lieutenant? 9 MR. : Yeah. 10 MR. : And is that because, when 11 the SHU lieutenant is not there, activities' 12 lieutenant and ops lieutenant always have 13 oversight of the SHU? 14 MR. : Well, I told you we have to 15 make a round. 16 MR. : Right. 17 MR. : In SHU. Yeah. 18 MR. : But that would be the 19 lieutenants - they would be the lieutenants 20 that would have oversight over the SHU, 21 correct? 22 MR. : Yeah. Pretty much. 23 MR. : Okay. On August 9th, 24 what communications did you have with any of 25 the other lieutenants with regard to Epstein EFTA00111036 LIMITED OFFICIAL USE 49 1 being housed with the MCC, or the MCC SHU? Can 2 you recall? 3 MR. : No. 4 MR. : And again, thinking back, 5 this is like one of the biggest things that's 6 ever happened when you were there, this guy 7 dies. Can you remember any conversations you 8 had the day before, with anyone, with regards 9 to Epstein? 10 MR. : I just know that he used to 11 come legal all the time. 12 MR. : Yeah. 13 MR. : Attorney conference, pretty 14 much the whole day. 15 MR. : Right. 16 MR. : And that's about it. 17 MR. : And about what time would 18 he be moved to attorney conference? 19 MR. : Early. Like, probably 8:00 20 in the morning. 21 MR. : And who would be the 22 person that would move him there? 23 MR. : The SHU staff. Get him out 24 the SHU. 25 MR. : Okay. EFTA00111037 LIMITED OFFICIAL USE 1 MR. : He was in SHU. 2 MR. : And what would the - as 3 the activities' lieutenant, did you visit him 4 at all in attorney conference, or check on him? 5 Is that part of your round process? 6 MR. : It's not part of the rounds, 7 but if you see him in there, if you standing by 8 the elevators or something like that, yeah. 9 MR. : Okay. 10 MR. : But you're not - you don't 11 have to check. No. 12 MR. : All right. Did anyone 13 ever provide you with special instructions, 14 with regards to Epstein? 15 MR. : Special instructions? 16 MR. : Yeah. 17 MR. : Like? Something - no. 18 MR. : No? 19 MR. : With special instructions? 20 Like -? 21 MR. : Like, conversations with 22 Epstein, hey, make sure you do this. Just 23 Epstein, make sure this is going - you know? 24 guess specific instructions. Maybe "special" 25 isn't the right word -- EFTA00111038 LIMITED OFFICIAL USE 1 MR. : No. 2 MR. : -- but did anyone ever 3 specifically say, you know, this is Epstein, 4 we've got to make sure we're doing this? 5 MR. : Hmm-mm. No. Not that I 6 recall. 7 MR. : No? Did any lieutenants 8 ever talk to you about Epstein's requirement to 9 have a cellmate? 10 MR. Hmm-mm. I mean, it's not -. 11 Like I said, we've got the email. 12 MR. : Right. 13 MR. : There's no one saying, hey, 14 by the way, (Indiscernible *00:36:07), and 15 didn't he have a cellmate up until then? I 16 think he had a cellmate since he got on the 17 suicide watch. So, I don't think there was a 18 lapse in it. 19 MR. : Right. 20 MR. : Yeah. 21 MR. : So, what about up until 22 then? You're saying, so -- 23 MR. : Right. Yeah. The cellmate, 24 right? 25 MR. : -- so, what is your EFTA00111039 LIMITED OFFICIAL USE 1 understanding of what happened -- 2 MR. : What happened? 3 MR. : -- on August 9th? 4 MR. : His cellmate went to court, 5 and either went to transferred, or got 6 released, or something. And never came back. 7 And then, you know, that night, he went out, he 8 went without a cellmate. 9 MR. : Okay. 10 MR. : Yeah. 11 MR. : So, we'll get into that. 12 I'll ask you a couple more questions, then, 13 just to make sure we stay on kind of page, at 14 the bottom of this page, you see, we're going 15 to start talking about that inmate. And I'll 16 just - what you knew about that. You said the 17 lieutenants are responsible for conducting 18 rounds. Are they responsible for conducting 19 counts in the SHU? 20 MR. : No. 21 MR. : No? So, like, just 22 around, nothing to do with counts when you were 23 -? 24 MR. : Count is for officers. 25 MR. : Okay. And you don't need EFTA00111040 LIMITED OFFICIAL USE 53 1 to oversee them as the lieutenant, or anything 2 like that? 3 MR. : You could take a count, but 4 usually, you're doing patrol, you're not doing 5 the count with the officers. 6 MR. : Right. So, in physically 7 presence in the SHU, the only time that the 8 lieutenant is involved is actually with rounds, 9 not with counts? 10 MR. : Not with counts. 11 MR. : Okay. And did you 12 conduct any rounds in the SHU, on August 9, 13 2019? 14 MR. : I'm not sure. I can't 15 recall. 16 MR. : You don't remember? 17 Again, you're placing yourself back on one of 18 the biggest incidences, and you know all this 19 circus that's been going on since that time. 20 MR. : Yeah, I know. 21 MR. : So, you can't really put 22 yourself back on that day of, like, hey, what 23 was my involvement with this, and did I -? 24 MR. : No. No. I had no 25 involvement with this. EFTA00111041 LIMITED OFFICIAL USE 54 1 MR. : Well, that's what I mean, 2 but you -- 3 MR. : Mm-hmm. 4 MR. : -- were the activities' 5 lieutenant, you know, on the, you know, the day 6 before. 7 MR. : Yeah. 8 MR. : And specifically, like 9 you just said, on the day before, when his 10 cellmate was removed. 11 MR. : Yeah. 12 MR. : So, you can't remember? 13 MR. : If I did a round, then no. 14 MR. : Okay. So, you can't -. 15 Then, do you remember having any conversations 16 with any of the people listed in there, on your 17 shift, in the SHU? On that date, specifically 18 with regard to Epstein, or Reyes, his cellmate. 19 MR. : No. 20 MR. : All right. And it'll be, 21 like, a 22 Michael Thomas, Tova Noel, 23 . None of those 24 people? 25 MR. : No. EFTA00111042 LIMITED OFFICIAL USE 55 1 MR. : Okay. So, you didn't 2 speak to any of those people about Epstein 3 being required to have a celimate since his 4 celimate was gone? 5 MR. : You're talking about that 6 day? 7 MR. : Yeah. 8 MR. : Or you're just saying -- 9 MR. : On the day that -- 10 MR. I can't remember. 11 MR. : -- okay. All right. The 12 people that are in the SHU, are they 13 responsible for conducting counts and round 14 during their shift? 15 MR. : Yes. 16 MR. : As far as the shift that 17 you worked, on day watch, what is your 18 understanding of how many rounds and counts 19 they should have done? 20 MR. : There's no counts on day 21 watch. 22 MR. : Okay. What about the 23 rounds? 24 MR. : The rounds, every - you're 25 doing a certain shift, we go about. So, you do EFTA00111043 LIMITED OFFICIAL USE 56 1 one, say, like, 8:00 to 8:30, you do one. 8:30 2 to 9:00, you do one. 3 MR. : So, every 30 minutes? 4 MR. : Every 30 minutes. Not to 5 exceed 40 minutes. They're regular rounds. 6 MR. : Okay. And you're 7 supposed to do one of those rounds with them, 8 but you can't recall whether you did or not? 9 MR. : No. We're not supposed to do 10 rounds with them. No. 11 MR. : You're supposed to just 12 do your own round? 13 MR. : Yeah. 14 MR. : Okay. 15 MR. : Do our round in SHU. 16 MR. : And can you recall if you 17 did your round in SHU? 18 MR. : No, I can't. 19 MR. : You can't recall? Would 20 it be abnormal if you didn't? 21 MR. : I can't recall. 22 MR. : You can't recall if it 23 would be abnormal if you didn't? 24 MR. : If I didn't do the round? 25 MR. : Right. EFTA00111044 LIMITED OFFICIAL USE 57 1 MR. : Would it be abnormal? I mean, 2 I'm not the SHU lieutenant. That's what I'm 3 saying. 4 MR. : But there's no SHU 5 lieutenant, you said, that, you know, you or 6 would be responsible. So, I'm saying, 7 would it be abnormal if you didn't do it? So, 8 would you normally have done it? I know you 9 said you're responsible for it. 10 MR. : No. The lieutenants are 11 responsible, but if a Monday through Friday, if 12 a SHU lieutenant is there, there's no reason 13 for me to go up there. 14 MR. : But there's no SHU 15 lieutenant. 16 MR. : Right. So, but I don't 17 recall if I did a round or not. No. 18 MR. : Okay. But the last 19 question wasn't that. I'm saying, would it 20 have been abnormal if you didn't do one? I know 21 you can't recall it -- 22 MR. : Yeah. 23 MR. but would you normally 24 have done it, if there's no SHU lieutenant? 25 MR. : Yeah. EFTA00111045 LIMITED OFFICIAL USE 1 MR. : Yeah? So, knowing 2 yourself, you probably would -. 3 MR. : If there's no SHU lieutenant, 4 yeah. 5 MR. : Okay. 6 MR. : Okay. 7 MR. : When did you become aware 8 that inmate Reyes was removed from the MCC on 9 August 9, 2019? 10 MR. : I don't know. 11 MR. : What is -. 12 MR. : The only thing I heard is, I 13 know, I woke up, they're saying, I saw the 14 story. 15 MR. : What is your involvement, 16 as the activities' lieutenant that day, with 17 inmates who are going to court? 18 MR. : I didn't have no involvement. 19 MR. : So, the activities 20 MR. : (Indiscernible *00:41:32). 21 MR. : -- lieutenant is not 22 involved? 23 MR. : No. 24 MR. : Is the ops lieutenant 25 involved? EFTA00111046 LIMITED OFFICIAL USE 1 MR. : Not really, no. 2 MR. : So, who is involved? Who 3 -? 4 MR. : R&D. Receive and Discharge. 5 MR. : Okay. And do you 6 remember who was working in R&D that day, in 7 that morning? 8 MR. : No. 9 MR. : Are you able to tell by 10 looking at that -- 11 MR. : No. 12 MR. : -- sheet? How does that 13 work? How do you find out who was in R&D for 14 that day? On that morning. 15 MR. : That's the custody roster. 16 I'm not sure. 17 MR. : So, that's a different 18 roster? 19 MR. : Yeah. 20 MR. : What would that roster be 21 called? 22 MR. : I don't know. 23 MR. : You're not sure? 24 MR. : That's not our department. 25 MR. : Okay. So, did they come EFTA00111047 LIMITED OFFICIAL USE 60 1 and retrieve those individuals from the SHU, or 2 does the SHU staff bring them to R&D? 3 MR. : It depends. If it's busy, 4 you say, hey, I need help, they go up and help 5 you out. If not, the SHU crew, all right, take 6 them down. 7 MR. : So, if it were at a non- 8 busy traditional way, who would have been the 9 people on that roster? 10 MR. : The SHU crew. 11 MR. : And who on that day? 12 MR. : You mean, for the court 13 movements? 14 MR. : Yeah. Like, what time? 15 First of all, I guess I should say. 16 MR. : It depends - that's what I'm 17 saying - so, it depends on if they're going to 18 Brooklyn, or wherever, you start early at 6:00. 19 So, that would morning watch or day watch. 20 MR. : So, it would be one or 21 the other? And does not - let's say if it was 22 8:00 a.m., who would have it been? 23 MR. : The day watch crew. 24 MR. : And who was on day watch 25 that day? EFTA00111048 LIMITED OFFICIAL USE 1 MR. : Hmm. -. 2 3 MR. : And anybody - any of 4 those people - do you remember speaking about 5 Reyes? 6 MR. : No. 7 MR. : All right. And who was 8 the OIC? Who was the officer-in-charge, out of 9 that crew? 10 MR. : Hmm. 11 MR. -: was? Not 12 MR. : According to this, it was 13 14 MR. : Okay. So, on the 15 document, it's All right. I'm going 16 to show you a memo that was written by 17 on August 12, 2019. And it's the subject is, 18 "Pass information from Special Housing Unit." 19 It says, "On Friday, August 9, 2019, at 20 approximately 1:50 p.m., I, SIS 21 passed on to oncoming staff, officers and 22 present shift staff, SIS , and Officer 23 , that inmate Reyes was going WAB, and 24 possibly may not return. Also, that inmate 25 Epstein will be needing a cellmate upon arrival EFTA00111049 LIMITED OFFICIAL USE 1 from his attorney visit." So, does that 2 refresh your memory? Did you have any 3 conversations with 4 MR. : No. 5 MR. : Who would have made 6 aware that Reyes was going WAB? 7 MR. : He could see it on the 8 roster. They send a sheet up the night before. 9 MR. : So, if that's not on the 10 night before, if on the night before, there's 11 no WAB - and this is at 1:50 p.m. that this 12 notification was made note - if there's no WAB 13 Well first of all what's WAB stand for? 14 MR. : With All Belongings. 15 MR. : And if WAB is not next to 16 Reyes' name on the night before, the August 8th 17 roster, how would have he become aware at 18 around 1:50? Would normally the court call 19 R&D, and R&D pass that information along? 20 MR. : R&D could have called him. 21 MR. : So, would R&D call SHU 22 directly, or would they typically call the ops 23 or activities' lieutenant? 24 MR. : They call the SHU. 25 MR. : They do call SHU EFTA00111050 LIMITED OFFICIAL USE 63 1 directly? They wouldn't call you guys, and you 2 would have to the pass information on? 3 MR. : No. 4 MR. : Okay. So, is it your 5 belief, then, that if it's that, in fact, what 6 happened, if Reyes went to court, and then he 7 became WAB? Just tell me, what is your 8 understanding -- 9 MR. : I'm not sure how that one. 10 MR. : -- of how that would 11 work? 12 MR. : I'm not sure about that. 13 MR. : Yeah. I'm not saying, 14 specifically, how he got it. What would be the 15 typical way that would work? If an inmate 16 MR. : If an inmate -. 17 MR. : -- goes to work -- 18 MR. : Mm-hmm. 19 MR. : -- and then is released. 20 MR. : Mm-hmm. 21 MR. : How does that process 22 work? Once that inmate is released, what 23 happens from that point, for the court, how do 24 they make the notifications known to the MCC, 25 all the way down to where that inmate was EFTA00111051 LIMITED OFFICIAL USE 1 housed? Specifically, this one in the SHU. 2 MR. : R&D. Hey, that guy's not 3 coming back. 4 MR. : Okay. 5 MR. : Yeah. 6 MR. : And then, would they 7 typically say, now WAB, would that be the words 8 that they would use, or would they say, he's 9 not coming back? 10 MR. : Either/or. The WAB is 11 something that's on the roster. 12 MR. : Okay. So, is WAB 13 specific to the roster, or is WAS also if he 14 was called and told? 15 MR. : I'm not sure. I don't know. 16 I've seen it before on the roster. Like, hey, 17 this is the court list. It says WAB. 18 MR. : Right. And I'm saying -- 19 MR. : Yeah. 20 MR. -- in this circumstance, 21 if there is no WAS -- 22 MR. : I'm not sure. 23 MR. : -- next to Reyes' name 24 MR. : I'm not sure. 25 MR. : -- okay. But you didn't EFTA00111052 LIMITED OFFICIAL USE 1 have any conversations with 2 MR. : No. 3 MR. : No? And you seem pretty 4 confident with that. Not like I can't recall. 5 You did not have any conversations with 6 7 MR. : Yeah, I had no conversations 8 with him. 9 MR. : What about with 10 Did you have any conversations with abou - 11 Reyes going WAB or not coming back? 12 MR. Pfft, I can't recall that, 13 either. 14 MR. : Did you know that Reyes 15 had left that day for court? 16 MR. : No. 17 MR. : So then, therefore, did 18 you not know that he was not coming back? 19 MR. : No, I didn't know. No. 20 MR. : Okay. And you don't 21 remember if you actually did a round in the SHU 22 to see that he wasn't there? 23 MR. : No. 24 MR. : So, can you recall any 25 conversations you had that day about Reyes? EFTA00111053 LIMITED OFFICIAL USE 1 MR. : I don't think I had no 2 conversations about Reyes. 3 MR. : That's what I'm asking. 4 So, you can't recall any conversations you had 5 that day about Reyes? 6 MR. : No. 7 MR. : And you don't think you 8 had any? 9 MR. : No. 10 MR. : No? Okay. All right. 11 We're going to continue with this. 12 MR. : I've got -- 13 MR. : Go ahead. 14 MR. : -- so, just to clarification. 15 The night before, how would MCC get to know 16 that Reyes is leaving? 17 MR. : Well, like I said, the court 18 list. 19 MR. : The court list. Who creates 20 it? 21 MR. : But sometimes, that's not 22 always accurate. 23 MR. : Who creates that? 24 MR. : Hmm-mm. I guess R&D. 25 MR. : And it doesn't show who's in EFTA00111054 LIMITED OFFICIAL USE 1 R&D over there, right? 2 MR. : No. 3 MR. : No. But R&D creates the 4 court list. And what do they do with that 5 court list? 6 MR. : They send it out to all the 7 units. So, you get one. If you're a unit 8 officer, you'll get it and say, okay, I got 9 three guys leaving, because it says WAB. So, 10 you say, hey, wake up, we're packing up, and 11 leaving. 12 MR. : They send the whole list, or 13 they just did the email saying, hey, these are 14 the inmates leaving from here? 15 MR. : Yeah. I've never seen an 16 email. I've just seen the list. 17 MR. : Okay. And it's just, like, a 18 generic email that goes out to everyone? 19 MR. : It's a call list. 20 MR. : But - sorry, I want to 21 make sure that I understood what you just said 22 - is it provided by email, or is it provided by 23 24 MR. : I've never seen it provided 25 by email. EFTA00111055 LIMITED OFFICIAL USE 68 1 MR. : -- so, you've never seen 2 it on email. It's just a list that's provided. 3 So, who - R&D comes and gives it to the SHU? 4 MR. : No. They send it up. 5 MR. : So, Internal comes and 6 gets it? 7 MR. : Internal. Yeah. 8 MR. : So, on this date, would 9 you know who would have been Internal? Who 10 would have provided that list to the SHU? 11 MR. : I see who's Internal, but I'm 12 not - I don't know if they would have provided 13 it. We've got two Internals. 14 MR. : And who are the two 15 Internals? 16 MR. -: (Phonetic Sp. 17 *00:48:29) and 18 MR. -: and 19 MR. : Yeah. 20 MR. : All right. So, they're 21 the two that typically - you're not saying that 22 they did - but they're typically the people 23 that would have provided the court list? 24 MR. : Yeah. Internal. That's what 25 they usually do. It could have been a EFTA00111056 LIMITED OFFICIAL USE 1 sanitation. 2 MR. : Now, isn't the list 3 typically provided the day before, or is it 4 just created the day before? 5 MR. : I don't know. I can't -. 6 it provided the day before? 7 MR. : Yeah. 8 MR. : It was provided the same day. 9 MR. : It is? 10 MR. : You get about - you get the 11 morning watch the day of. 12 MR. : I was always - I was 13 under the understanding that the night before, 14 on August 8th, they would create the list for 15 the morning, on the August 9th. Do you know -- 16 MR. : Yeah. 17 MR. : -- was that a correct 18 understanding? 19 MR. : I'm not sure. All I know is, 20 if you're an officer, you get it the day of. 21 MR. : All right. So -. 22 MR. : Because when I was an 23 officer, I used to get it the day of. 24 MR. : All right. And you've 25 worked in the SHU before? EFTA00111057 LIMITED OFFICIAL USE 1 MR. : Yes. 2 MR. : Okay. So, when you 3 worked in the SHU, it would come in that 4 morning? 5 MR. : Yeah. 6 MR. : Around what time would it 7 arrive? 8 MR. : About 2:00 in the morning. I 9 know that's early. 10 MR. : Oh, super early. 11 MR. : Yeah. 12 MR. : So, it would come in at 13 morning watch. 14 MR. : Yeah. Morning watch. 15 MR. : Okay. And are there 16 people in Internal working at that time, around 17 2:00 a.m.? 18 MR. : Yeah. 19 MR. : And is that the same 20 people you just listed? 21 MR. : Yeah. 22 MR. : So, those morning watch 23 individuals are the ones that would probably 24 have provided the court list? 25 MR. : Yeah. EFTA00111058 LIMITED OFFICIAL USE 71 1 MR. : And do you know, is that 2 document maintained anywhere? The court list 3 document? 4 MR. : No. 5 MR. : Is that, like, uploaded 6 in any kind of system? 7 MR. : Not that I know of. 8 MR. : No? So, do you know who 9 you said R&D creates it? 10 MR. : Mm-hmm. 11 MR. : But they don't create it 12 in a system. They just -. 13 MR. : I don't know. I mean, that's 14 not my department. 15 MR. : Okay. 16 MR. : Mm-hmm. 17 MR. : Is there, like, an 18 officer-in-charge of R&D? 19 MR. : Yeah. So, you have a CMC. 20 MR. : And -- 21 MR. : Corrections. 22 MR. : -- do you know who, in 23 August, would have been that person? 24 MR. : In August, no. Because I 25 know the CMC was out for a while. And they got EFTA00111059 LIMITED OFFICIAL USE 72 1 a - they also had a supervisor. 2 MR. : And do you know who that 3 would be? 4 MR. : No. But they had a 5 supervisor. I know that's their position, but 6 I don't know who it is. 7 MR. : And that would be, like, 8 a lieutenant? 9 MR. : No. 10 MR. : Who would -? 11 MR. : Lieutenant is custody. R&D 12 is non-custody. 13 MR. : Explain to me what R&D 14 is, and as far as -. 15 MR. : That's Receiving and 16 Discharge. 17 MR. : Yeah, yeah, yeah, yeah. 18 MR. : So, they deal with the inmate 19 movement, the inmate courts, the transfers, the 20 self-surrenders. 21 MR. : And you're saying that 22 they're not called lieutenants or anything. 23 What are their titles? 24 MR. : Correctional systems officer. 25 MR. : Correctional systems EFTA00111060 LIMITED OFFICIAL USE 73 1 officers. And, like, a supervisor, would they 2 still be, like -? 3 MR. : Supervisor correctional 4 systems officer. 5 MR. : And would that be, like, 6 a nine or an 11 type of -- 7 MR. : Something like that. 8 MR. : -- position? All right. 9 But they're just outside of, you said custody, 10 underneath -. What is the system that they're 11 underneath? 12 MR. : It's the non-custody and 13 custody. 14 MR. : Okay. 15 MR. : And they have correctional 16 officer, a correctional worker, as opposed to 17 custody is a correctional officer. 18 MR. : Okay. And who would be - 19 Does the captain also have oversight over 20 them? 21 MR. : No. 22 MR. : Who has oversight over 23 them? Non-custody. 24 MR. : The CMC. They have a 25 supervisor. EFTA00111061 LIMITED OFFICIAL USE 74 1 MR. : What does the CMC mean? 2 MR. : Correctional Management 3 Coordinator. 4 MR. : Okay. And that is 5 outside of the captain's purview? 6 MR. Yup. 7 MR. : And you don't remember 8 who that was, at that time? 9 MR. : No. 10 MR. : Okay. And you said you 11 did not have any conversations at all. So, you 12 didn't have any conversations with about 13 Reyes? 14 MR. : No. Not that I remember. 15 No. 16 MR. : What about with 17 MR. : Hmm. No. 18 MR. : No? But he would have 19 been - he relieved 20 MR. : I can't recall. 21 MR. : No? 22 MR. : Hmm-mm. 23 MR. : And was , do you 24 remember if you had any kind of interaction 25 with her at all on August 9th? EFTA00111062 LIMITED OFFICIAL USE 1 MR. : No. 2 MR. : No? So, obviously, you 3 can't remember if you had any conversations 4 about Reyes? 5 MR. : No. I don't remember 6 discussing Reyes. 7 MR. : Right. 8 MR. : No. 9 MR. : So, did you ever receive 10 any call around 1:50, or at any time, saying 11 MR. : No. 12 MR. : -- that Reyes was going 13 WAB? No? So, at this point in time, obviously, 14 you're saying you didn't know anything at that 15 point in time. Now, after the fact, what do 16 you know about Reyes being removed from the 17 MMC? 18 MR. : I just know he went to court, 19 and never came back. And that was it. 20 MR. : Do you know any 21 information about who was informed that he 22 wasn't coming back? 23 MR. : No. 24 MR. : So, even after the fact, 25 you don't know? EFTA00111063 LIMITED OFFICIAL USE 1 MR. : No. 2 MR. : Do you know anything -. 3 I mean, was it at all discussed about, like, 4 hey, somebody dropped the ball there? 5 MR. : No. 6 MR. : No? There wasn't even a 7 conversation? 8 MR. : I mean, that's the thing. I 9 don't recall him going - I didn't know he was 10 me personally - didn't know he was going WAB. 11 And I don't think a lot of other people did, 12 either. Yeah. 13 MR. : Did anyone ever ask you 14 about that -- 15 MR. : About Reyes? 16 MR. : -- yeah. 17 MR. : No. 18 MR. : Even after? 19 MR. : No. 20 MR. : So, like, on August 10th, 21 August 11th, August 12th, did anyone come up to 22 you and say, hey, did you know Reyes wasn't 23 coming back? 24 MR. : No. 25 MR. : And have you ever been EFTA00111064 LIMITED OFFICIAL USE 1 interviewed for this matter before? 2 MR. : No. 3 MR. : No? Did you have 4 conversations with people like , or 5 , or anyone, regarding this matter, 6 after Epstein was found? 7 MR. : What matter? 8 MR. : Epstein being found, and 9 not having a cellmate? 10 MR. : No. 11 MR. : No? You never talked to 12 anybody in the institution about that? 13 MR. : About him not having a 14 cellmate, or are you talking about him being 15 found? 16 MR. : No. About him not having 17 a cellmate. 18 MR. : I mean, not in a -. I mean, 19 we sent a, hey, what happened, or, like, what 20 happened to his cellmate? Oh, he got released. 21 Okay. It was - he said it like that, but 22 nothing -. No. Not like that. 23 MR. : Was it any conversation 24 of, like, hey, why didn't they put a new 25 cellmate with him? EFTA00111065 LIMITED OFFICIAL USE 1 MR. : No. 2 MR. : No? So, if, at around 3 1:50 -. 4 MR. : That's what I'm saying. 5 That's the time. That's why I'm looking at 6 you, saying 1:50. Yeah. 7 MR. : Yeah. I mean, this is 8 where -- 9 MR. : Yeah. 10 MR. : I'm getting the 1:50, 11 is because -- 12 MR. : Because these guys -- 13 MR. : -- it says 14 MR. -- they go to court -. 15 MR. • knows that, 16 at least by 1:50, he's going WAB. 17 MR. : Mm-hmm. 18 MR. : Should have he 19 communicated with either or about that? 20 MR. : I don't know. I don't know 21 how he communicated with. 22 MR. : No. I'm not asking who 23 he did. I'm asking you, should have he? 24 MR. : I mean, I know when I was 25 OIC, and they give us call it, okay. So, if he EFTA00111066 LIMITED OFFICIAL USE 79 1 didn't say nothing to the lieutenant, I could 2 see why. I mean, you're telling me, I'm the 3 OIC. And okay, I got the notification. 4 MR. : So -. 5 MR. : So, if he didn't pass nothing 6 on, it's -. 7 MR. : Is it abnormal that he 8 didn't pass it on, though? Should have he 9 passed it to you? Because -. 10 MR. : It's not. It's not -. I 11 mean -. 12 MR. : Could have he placed 13 another inmate with someone like Epstein? 14 MR. : I'm not sure because then, 15 again, it says possibly. WABs get cancelled. 16 They get cancelled. 17 MR. : Sure. 18 MR. : That's why the 1:50, we don't 19 know until after, like, hey, who is this guy 20 coming back? R&D is open at 8:00, 9:00. 21 MR. : So, about what time would 22 they normally make that notification that, okay 23 -? 24 MR. : After 4:00. 25 MR. : After 4:00? EFTA00111067 LIMITED OFFICIAL USE 1 MR. : Yes. 2 MR. : And is it some - when you 3 say after 4:00 - is it usually between 4:00 and 4 5:00? 5 MR. : After 4:00. Any time after 6 4:00. 7 MR. : So, anywhere from 4:00 to 8 5:00, 4:00 to 6:00, 4:00 to 8:00. What -? 9 MR. : After the count. 10 MR. : So, after the 4:00 p.m. 11 count. 12 MR. : After the 4:00 p.m. count. 13 MR. : And why is it after the 14 count? 15 MR. : Because that's when the guys 16 come back, after the count. We do the 4:00 17 count. And then, you get an (Indiscernible 18 *00:56:31) base count training is like this. 19 You get 20 guys came back from court, this WAB 20 got cancelled. 21 MR. : So, as far as the 4:00 22 count, or is it at that point, do people start 23 saying, where are these guys, and start making 24 calls, are they coming back or not? 25 MR. : At 4:00? No. EFTA00111068 LIMITED OFFICIAL USE 81 1 MR. : No? So, when is the next 2 time that they would be listed on that count? 3 MR. : The 9:00 count. 4 MR. : The 10:00 count? 5 MR. : Oh, the 10:00 count. Yeah. 6 MR. : Do you want to ask some 7 more questions on that line? I'm just trying to 8 Because I thought it was at - I felt people 9 have told at 4:00, that's when they start 10 making calls to say, is this guy coming back or 11 not. That's not your understanding? 12 MR. : Why would you make a call at 13 4:00? 14 MR. : Because you've got to 15 know if they're coming back to the unit or not 16 coming back. 17 MR. : Well, the count, 3:45 is 18 over. So, you're in the unit or not. So, at 19 4:00, we do the count. After the count, that's 20 when the guys come in from court. 21 MR. : Okay. 22 MR. : That's when we get the guys 23 coming back to SHU and going back to their 24 units. 25 MR. : And would you be - would EFTA00111069 LIMITED OFFICIAL USE 82 1 anybody be notified, prior to 4:00, that people 2 were, or were not, coming back? 3 MR. : Not to my understanding. No. 4 MR. : All right. So, to your 5 understanding, it's not until 4:00 or later, 6 that this, you know, people would know Reyes 7 was not coming back? 8 MR. : Yeah. 9 MR. : All right. So, if Reyes 10 doesn't come back after 4:00 p.m., who, on that 11 daily assignment roster, would be responsible 12 for making notifications, or determining that 13 Epstein needed a cellmate? 14 MR. : I mean, the notification is 15 here. We already have the notification. 16 MR. : Yeah. I know you're 17 pointing to the email that says that he 18 requires to have a cellmate. What I'm asking 19 is, okay, now 4:00 on, at some point after 20 4:00, you're saying Reyes - it's known that 21 Reyes is now not coming back. 22 MR. : Mm-hmm. 23 MR. : Not - possibly not coming 24 back, but he's not coming back. Who would be 25 responsible for placing - for making EFTA00111070 LIMITED OFFICIAL USE 83 1 notifications that, hey, Reyes is out, Epstein 2 does not have a cellmate, we need to start 3 making some notifications? 4 MR. : I mean, I don't know. 5 There's no notifications. That's if he doesn't 6 have a cellmate, we give him a cellmate. 7 MR. : Yeah. So, what I'm 8 saying is -. 9 MR. : But the lieutenant is not 10 saying, hey, by the way, you know? If they 11 catch it, they'll say it, but if they don't -. 12 MR. : And I'm not saying it's - 13 14 MR. : Yeah. 15 MR. : -- a lieutenant's 16 responsibility. What I'm asking is, whose 17 responsibility is it? 18 MR. : To say, hey, this guy, get 19 him a cellmate, or make a notification? 20 MR. : Yes. Like, who would be 21 the first one to know that Reyes is no longer 22 there? Would it be the SHU? 23 MR. : I'd say R&D. 24 MR. : So, R&D would be there. 25 What is R&D's responsibility, at that point? EFTA00111071 LIMITED OFFICIAL USE 84 1 MR. : Oh, hey, we've got all the 2 inmates back. It's such and such. And that's 3 it. You ain't get him? Then they're not coming 4 back. They're gone. 5 MR. : But would R&D be 6 responsible for saying, hey, SHU, Reyes isn't 7 coming back, or would they say, hey, ops 8 lieutenant, Reyes isn't coming back. Who would 9 R&D notify? 10 MR. : I'm not sure. In the past, I 11 would say they calling SHU directly. 12 MR. : SHU directly? 13 MR. : Yeah. 14 MR. : All right. So, in the 15 SHU, after 4:00, who was working? 16 MR. -: , Noel, and 17 MR. -: , Noel, and 18 Are they the only three there? 19 MR. : That's the only three listed. 20 MR. : Okay. So, one of those 21 three were likely notified? 22 MR. : I'm not sure. 23 MR. : Okay. And if they 24 weren't notified, at what point would they know 25 Reyes isn't coming back? EFTA00111072 LIMITED OFFICIAL USE 1 MR. : I'll say about 8:00. 2 MR. : And how would they be 3 notified? 4 MR. : Because usually, all the 5 inmates are by then, you know, talking to the 6 lieutenant, hey, is anyone else down there? 7 That's like a (Indiscernible *01:00:27) call. 8 MR. : Is there some point when 9 they should be saying, hey, this guy left at 10 8:00 this morning, he's still not back? 11 MR. : No. You said, is it at some 12 point? Yeah. 13 MR. : So, and at what point is 14 that? Is it during a count? Or is it just - is 15 there, like, you know, duties that they're 16 doing prior to the count, where they've got to 17 make sure people are there? How does that work? 18 MR. : I mean -. 19 MR. : You've worked in the SHU, 20 so from your recollection, from when you worked 21 in the SHU, how would that work? Especially 22 being that MCC is a jail, not a prison, where 23 people could, at any time, be released or 24 moved. How does that work in the SHU? 25 MR. : I used to have, like, that, I EFTA00111073 LIMITED OFFICIAL USE 86 1 think, set by 8:00. 2 MR. : I'm sorry. What did you 3 say about 8:00? 4 MR. : By 8:00, is when I say, hey, 5 is anyone else coming up? And this is the base 6 count. Like, I want to get everything straight 7 in the computer. 8 MR. : Okay. 9 MR. : I'll say by 8:00. 10 MR. : And on that date, when 11 those three people were working, who would 12 typically be responsible for doing something 13 like that? Is it, like, SHU one, SHU two, two 14 three, or is it just anybody, any one of them, 15 or how does that work? 16 MR. : To do what? 17 MR. : To say, like, hey, we've 18 got to make sure our base count is correct. 19 MR. : I mean, it could be any one 20 of them. 21 MR. : Any one of them? 22 MR. : Yeah. 23 MR. : But it's not like 24 someone's job? It's just someone should take 25 that role. EFTA00111074 LIMITED OFFICIAL USE 87 1 MR. : I mean, but they've got to 2 have the base count right, for the 10:00 count. 3 MR. : So, one of those people 4 should have got the base count right, but it's 5 not one specific person's duty? Or is it 6 something that they're supposed to collaborate 7 on all together? 8 MR. : I mean, it depends. It 9 depends. If you're working, hey, such and such 10 (Indiscernible *01:02:01). If you're number 11 two, you know, you go to the board, you could 12 change it yourself. You know, the OIC. All 13 right, you know, making sure everything is in 14 order. 15 MR. : Was there an OIC on that 16 night? 17 MR. : Yes. 18 MR. : Who? 19 MR. -: 20 MR. : So, was the OIC? 21 MR. : Yes. 22 MR. : So, technically, he's 23 probably the one who should have been 24 responsible to catch the fact that their base 25 count changed, and he wasn't coming back? EFTA00111075 LIMITED OFFICIAL USE 1 MR. : I'm not sure about that. 2 Because he was non-custody. I'm not sure. 3 MR. : Okay. 4 MR. : Because, you see, he's non- 5 custody. Mine was bon-custody. He's just up 6 there for overtime. So, I'm not sure. 7 MR. : Okay. Now, as far the 8 lieutenants' job. So, at that point in time, 9 it was that was the ops, and hat 10 was the activities. What is their role in 11 ensuring that Reyes is, one, back; and two, 12 Epstein is placed with a new cellmate? 13 MR. : Yeah. 14 MR. : Do they have any role? Or 15 is it all on the SHU? 16 MR. : I mean, it's - they don't 17 have a role. You know, it's -. 18 MR. : What about when they're 19 conducting their rounds, as part of their 20 responsibility to say, to check that kind of 21 stuff, or is it just to see what inmates are 22 there, and that the inmates that are there, are 23 okay? 24 MR. : Pretty much. You've got to 25 do a round. EFTA00111076 LIMITED OFFICIAL USE 89 1 MR. : Does that round entail 2 verifying that Epstein has a cellmate and Reyes 3 isn't there? 4 MR. : I'm not sure of that. We 5 just know we do our rounds. 6 MR. : So, that goes back to, 7 what does a round entail? Does that mean that 8 you need to verify that the people that are on 9 the books are there, and other people are 10 removed? 11 MR. : Yes, with staff and 12 accountability. For the most part. You know? 13 Inmates banging, hey, all right, I'll be up, 14 doing my round. I'll deal with this when I get 15 up there. 16 MR. : But when you say for 17 accountability, what does that entail? 18 MR. : Presence of inmates, 19 depending on who goes up there. They know, 20 okay, this is on - they try certain things, 21 they won't try certain things. 22 MR. : Are you comparing a list 23 of the inmates that you know to be in the SHU, 24 with who's actually in the SHU? 25 MR. : No. Not for a round. No. EFTA00111077 LIMITED OFFICIAL USE 90 1 MR. : No? All right. So, as 2 far as a round conducted by a lieutenant, would 3 they know - would they be able to figure out 4 that Reyes was removed? 5 MR. : Depending on what time the 6 round was. 7 MR. : And can you give me more 8 explanation? What time would that change? 9 MR. : If I do an early round, and 10 Epstein's in a cell by his self, okay, I still 11 have time, still doing court movements, and it 12 raise no suspicion or no alarm. 13 MR. : Okay. So, about what 14 time would there be a suspicion or alarm that 15 be raised? 16 MR. : I told you. At about 8:00. 17 MR. : 8:00? 18 MR. : Yeah. 19 MR. : Because Reyes hasn't been 20 back? 21 MR. : Yeah. 22 MR. : Okay. Were you ever 23 provided any instructions on what actions 24 should be taken if Reyes was removed as 25 Epstein's cellmate? EFTA00111078 LIMITED OFFICIAL USE 91 1 MR. : No. 2 MR. : What actions should have 3 been taken once Reyes was removed? 4 MR. Hmm. Honestly, I mean, like 5 I said, we bunk all the inmates together. So, 6 if he were to move, look for him a new bunkie. 7 MR. : And is that something - 8 should have they notified - when they say look 9 for a new bunkie, I'm assuming you're talking 10 about the people in the SHU? 11 MR. : Yeah. A new cellmate. Yeah. 12 MR. : So, I think you said 13 , and Noel? 14 MR. : Yeah. 15 MR. : Could have they placed 16 him with a new cellmate, or would have they had 17 you make notification to the ops and/or 18 activities' lieutenant? 19 MR. : You know, they don't need to 20 make notification. 21 MR. : What about when someone 22 is high-profile as an inmate as Epstein? 23 MR. : No, he didn't make 24 notification. 25 MR. : So, you don't think that EFTA00111079 LIMITED OFFICIAL USE 92 1 they would have. Do you know if Epstein's 2 cellmates were vetted by the captain and above? 3 MR. : I think I heard something 4 like that. I think so. 5 MR. : Now, does that play into 6 that answer? About if they could have just 7 placed anyone with him? 8 MR. : I'm not sure. 9 MR. : Okay. 10 MR. : But I think someone vetted 11 like that, pre-approved or something like that. 12 I think - I'm not sure - but I think I did hear 13 something like that. 14 MR. : Okay. But to your 15 knowledge, they could have placed anyone with 16 him? Not anyone, but, like, they could have 17 placed a new inmate with him. 18 MR. : Yeah, they could have. 19 MR. : Okay. Should have they? 20 MR. : I'm not sure. Like you said, 21 the whole vetted thing, yeah. I'm not sure. 22 MR. : So, if they knew that 23 Reyes was vetted, and was placed with him, at 24 that point, should have they done anything 25 else? Such as called the lieutenant to say, EFTA00111080 LIMITED OFFICIAL USE 93 1 hey, he's not back, we need to get him a new 2 celimate. Can I place someone with him, or 3 should have they just taken action on their 4 own? 5 MR. : I don't know. 6 MR. : If you were - I know you 7 were day watch - but if you were evening watch, 8 would of you expected them to notify you? 9 MR. : Yeah. 10 MR. : So, in this case, should 11 have they notified or should have they 12 notified , or either of them? 13 MR. : I'm not sure. 14 MR. : Should have -. 15 MR. : That was non-custody. 16 MR. : Should have the person 17 notified them by telephone, or when one of 18 those lieutenants did their rounds? 19 MR. : You said should they have? 20 MR. : Yeah. 21 MR. : If they would have? Yeah, 22 either/or. Both. Call, email, whatever. 23 MR. : Now, someone like -. So, 24 was the activities' lieutenant that 25 night, correct? EFTA00111081 LIMITED OFFICIAL USE 1 MR. : Yes. 2 MR. : Since she was not a 3 lieutenant, she was an SIS, do you feel that 4 she had the knowledge and capabilities to be 5 able to do that job, at that time? 6 MR. : What job are you talking 7 about? 8 MR. : Activities' lieutenant. 9 MR. : Yeah. I think she was 10 training, right? 11 MR. : Well, I -. 12 MR. : I think she was training. 13 It's that temporary post, right? 14 MR. : So -. 15 MR. : Yeah, but that still wouldn't 16 be on her, though. 17 MR. : If she's the one who did 18 a round in the SHU for her shift. 19 MR. : Yeah. 20 MR. : Is that something that 21 she should have checked on? Hey, where's Reyes? 22 There's nobody in -. Because not only - I 23 mean, everyone knows what cellmate Epstein is 24 in. So, even if Epstein's not in there, and 25 he's still down at attorney conference, nobody EFTA00111082 LIMITED OFFICIAL USE 1 is in there. So, shouldn't that have been 2 something that you'd say, hey, where is this 3 guy? Is he coming back? Should that be 4 something that was -? 5 MR. : That kind of depends on the 6 time. 7 MR. : And when you're saying 8 that you just mean because he possibly could be 9 coming back? 10 MR. : Yes. 11 MR. : But if no one is there, 12 and she knows he's out at court, shouldn't she 13 at least have followed up on, hey, anybody 14 check on his? Is he coming back? 15 MR. : Well, that's R&D. R&D 16 notifies us if they're coming back or not. 17 MR. : All right. So, when 18 doing rounds, that's not something being that, 19 hey, we've got to make sure that Epstein has a 20 cellmate. Not something that should be, like, 21 a, hey, nobody's in Epstein's cell. What's 22 going on there? 23 MR. : I mean, that's what I'm 24 saying. We get this notice, not just with 25 Epstein, with every inmate -- EFTA00111083 LIMITED OFFICIAL USE 1 MR. : Okay. 2 MR. : -- that comes on suicide 3 watch. 4 MR. : So, did you ever see - 5 when you were visiting the cell - did you ever 6 see this sign up in the SHU? 7 MR. : No. 8 MR. : And I'm showing you a 9 colored note, saying, "Mandatory rounds must be 10 conducted every 30 minutes on Epstein, number 11 76318-054, as per guide." 12 MR. : Nah. 13 MR. : You never noticed that? 14 MR. : No. 15 MR. : All right. So, that's 16 nothing you ever saw in any of your times 17 visiting there? 18 MR. : No. 19 MR. : All right. If that was 20 up - sorry. 21 MR. : Sorry. 22 MR. : Please. 23 MR. : No, no. If you have. 24 MR. : No. 25 MR. : I have a -- EFTA00111084 LIMITED OFFICIAL USE 1 MR. : No, no, no. 2 MR. : I have a funny joke, 3 that's why. 4 MR. : I was just going to say, 5 if that is up for people to see, doing rounds 6 in the SHU, does that change any of those 7 answers of, hey, where is Epstein's cellmate? 8 MR. : I mean, this is - if it's 9 rounds - that's something different than me 10 saying single bunk. So, if they're saying 11 we're doing rounds on them, that wouldn't make 12 them to think about, why is this guy - where is 13 his bunkie? 14 MR. : You don't think so? So, 15 if you're actually looking into his cell and 16 saying, you know he needs a bunkie, I'm looking 17 in his cell, and there is no one else with him, 18 you don't think that those are correlated? 19 MR. : Yeah, but not because of 20 this. No. That's just saying rounds, hey, 21 make sure you do your rounds. 22 MR. : It says specifically -- 23 MR. : Than when it's not -- 24 MR. : -- rounds on -? 25 MR. : -- yea, but normal, it's not EFTA00111085 LIMITED OFFICIAL USE 98 1 going to think just because - it's not going to 2 mix this with this. 3 MR. : So, even though they're 4 looking in on Epstein, seeing that he's not - 5 he's by himself, that won't alert them to the 6 fact -? 7 MR. : No. Not that sign. No. 8 MR. : No? 9 MR. : No. 10 MR. : You don't think so? 11 MR. : It says, "Mandatory rounds." 12 MR. : Do you know of any other 13 signs that were in the SHU, saying that he was 14 required to have a cellmate? 15 MR. : Hmm. I can't recall. 16 MR. : What about the hot list? 17 Tell me about, what is a hot list? 18 MR. : The hot list is inmates who 19 have suicidal behavior or attempts in the past. 20 MR. : And people on the hot 21 list, are they required to have a cellmate? 22 MR. : Yeah. 23 MR. : Do you remember seeing 24 the hot list that was in the SHU? 25 MR. : No. EFTA00111086 LIMITED OFFICIAL USE 1 MR. : Is that as part, as a 2 lieutenant, would they check out the hot list 3 when they would go down there? 4 MR. : No. We would just - no - we 5 would just check to see if it's updated. 6 MR. : Okay. So, Epstein's 7 listed on the hot list. 8 MR. : Mm-hmm. 9 MR. : What does that, then, 10 tell these people working in the SHU? 11 MR. : He needs a cellmate. 12 MR. : And do all of them know, 13 if Epstein's on the hot list, those people need 14 cellmates? 15 MR. : I'm not sure if all of them 16 knew. 17 MR. : But are they supposed to? 18 MR. : I don't know. Yeah. 19 MR. : All right. So, you feel 20 like the hot list is even more important than 21 the sign I just showed you, for cellmate 22 purposes? 23 MR. : This sign? Where the sign 24 come from? 25 MR. : If this sign was in the EFTA00111087 LIMITED OFFICIAL USE 100 1 SHU -- 2 MR. : You said "if"? 3 MR. : -- well, I'm not saying 4 I can't say if - yeah - I can't tell you -- 5 MR. : Oh. 6 MR. : -- exactly what is and 7 what isn't. I'm just saying, assuming that 8 this was in the SHU. 9 MR. : Mm-hmm. 10 MR. : What was your question? 11 MR. : That's what I'm saying. 12 This, I don't think this was up there. 13 MR. : You don't think that was 14 in the SHU? 15 MR. : No. 16 MR. : Because -. 17 MR. : I mean, not in no tier or 18 nothing like that. 19 MR. : Okay. But around, like, 20 the officers -? 21 MR. : The hot list is up there, 22 though. 23 MR. : But what about, like, up 24 on, like, the desk area? Would you be around 25 the officer's desk area? EFTA00111088 LIMITED OFFICIAL USE 101 1 MR. : Hmm. I mean, if I had to. 2 MR. : But you didn't notice 3 that -- 4 MR. : But not normally. 5 MR. : -- in the desk area? 6 MR. : No. 7 MR. : All right. Where would 8 the hot list be located? 9 MR. : So, behind the desks, like, a 10 wall we have, that we keep it up there. 11 MR. : All right. And they're 12 supposed to be checking that, and making sure 13 those people are, one) checked on, and two) 14 have cellmates? Is that the purpose? 15 MR. : The hot list is just any - 16 it's pretty much any inmate that comes from the 17 housing unit. They come from the housing unit. 18 This guy psych alert, hey, make sure this guy 19 gets a bunkie. That's the initial check. 20 That's what the hot list is for. 21 MR. : And are they supposed to 22 check that list every day, to make those same - 23 24 MR. : I mean, you don't - no, you 25 get up there, it's, hey, on the suicide watch, EFTA00111089 LIMITED OFFICIAL USE 102 1 is he on the hot list? So, it's not common to 2 check it every day. No. 3 MR. : All right. So, it's not 4 common to check it every day? 5 MR. : Every day, no. Unless it's 6 updated. 7 MR. : Only when it's updated, 8 you check it. 9 MR. : Yeah, if the guy is still on 10 it. 11 MR. : But wouldn't - again, the 12 fact that the MCC is a jail, not a prison - 13 wouldn't it be pretty regular that people are 14 being moved in and out? 15 MR. : Not on the hot list. 16 MR. : No, but the people that 17 they're bunked with. If they're required to 18 have a cellmate -- 19 MR. : Mm-hmm. 20 MR. : -- wouldn't it be pretty 21 regular that they would have to - their 22 cellmates might be leaving? Because if it's a 23 jail, not a prison. 24 MR. : Yeah. 25 MR. : So, that's what I'm EFTA00111090 LIMITED OFFICIAL USE 103 1 saying. So, how are they always ensuring that 2 those people that are required to have 3 cellmates have cellmates? 4 MR. : That's when you say, hey, I 5 got a single cell up there. 6 MR. : And at what point is that 7 reviewed? 8 MR. : The single cells? 9 MR. : Yeah. Is that supposed 10 to be a daily occurrence? 11 MR. : Yeah. 12 MR. : And is that - what time 13 is that? The 8:00 time that you're talking 14 about? 15 MR. : No. Usually, that's in the 16 morning. So, like, if I come in, hey, you 17 know, I'm going to - who's in the single cell? 18 You know? 19 MR. : Well, what about -. 20 MR. : At night, it's just not -. 21 At night, it's -. 22 MR. : Even when people are left 23 during the day, and then come back from court? 24 Some people come back, some people don't. 25 MR. : Yeah. EFTA00111091 LIMITED OFFICIAL USE 104 1 MR. : Wouldn't that be another 2 time that they do it, or they don't do it at 3 that time? 4 MR. : I mean, I mean, like I said, 5 after that cut off time, that's when you start 6 saying, okay, we've got a single cell, of such 7 and such. Then again, remember, MCC get 8 inmates throughout the night. 9 MR. : They do? 10 MR. : Yeah. 11 MR. : Placed in the SHU? 12 MR. : Yeah. 13 MR. : Okay. And you didn't 14 work that night. Do you know of any people 15 that were placed in the SHU that night, on 16 August 9th? 17 MR. : No. Not according to this, 18 no. 19 MR. : And did you conduct any 20 counts or rounds in the SHU on August 9th? 21 MR. : I can't recall. 22 MR. : And what is the purpose? 23 Why do COs conduct counts and rounds in the 24 SHU? 25 MR. : To make sure they're alive. EFTA00111092 LIMITED OFFICIAL USE 105 1 MR. : Is it also to make sure 2 everyone is there? 3 MR. : Yeah. 4 MR. : And are cells and counts 5 - are counts and rounds documented? 6 MR. Yup. 7 MR. : And how 8 MR. : Probably. 9 MR. : -- how are they 10 documented? 11 MR. : 30-minute log in in TruScope. 12 MR. : So, 30-minute log for 13 rounds? 14 MR. : Yeah. 15 MR. : And what is the TruScope? 16 MR. : Rounds. 17 MR. : That's rounds, as well? 18 MR. : You put rounds in there, too, 19 but all the counts. 20 MR. : So, counts -- 21 MR. : Mainly counts, yeah. 22 MR. : -- so, are counts also 23 are there, like, little slips that are filled 24 out? 25 MR. : Yeah. EFTA00111093 LIMITED OFFICIAL USE 106 1 MR. : Who fills them out? 2 MR. : All the officers. 3 MR. : And what do they do with 4 them? 5 MR. : Give it to Internal. 6 MR. : And does Internal come to 7 the SHU, or does the SHU go to Internal? 8 MR. : It depends. 9 Not before this incident. 10 MR. -: MR. : Or it does 11 it both ways? 12 MR. : Both ways. Just get it to 13 control. 14 MR. : Okay. Do all COs who 15 work in the SHU know how to properly conduct 16 and report counts and rounds? 17 MR. : I'm not sure. 18 MR. : Should they know how to 19 conduct counts and rounds? 20 MR. : Yeah. 21 MR. : And how should they know? 22 MR. : Training. 23 MR. : And do you think everyone 24 there got enough training to know how to do a 25 count and a round? EFTA00111094 LIMITED OFFICIAL USE 1 MR. : Yeah. 2 MR. : Did you ever hear of 3 people, like, filling out count slips, or round 4 sheets? Either before, or at the very start of 5 their shift, for their entire shift, or at the 6 end of the shift for their entire shift? 7 MR. : Not before this incident. 8 MR. : Did you hear about that 9 after this incident? 10 MR. : Yeah. 11 MR. : What did you hear about 12 that? 13 MR. : That they didn't count. 14 mean, it was filling out slips. It wasn't 15 counted. Wasn't making rounds. 16 MR. : And who was it that you 17 heard that wasn't conducting counts and rounds? 18 MR. : Thomas and Noel. 19 MR. : Anybody else in there? 20 MR. : No. 21 MR. : Did you hear anything 22 about counts and rounds not being conducted 23 prior to midnight on August 10th? So, any time 24 on August 9th, did you hear about any of those 25 counts and rounds not being conducted? EFTA00111095 LIMITED OFFICIAL USE 108 1 MR. : On the watch then? 2 MR. : Any time on August 9th. 3 So, this date. 4 MR. : No. 5 MR. : Even after the fact, you 6 never heard about, like, the 10:00 p.m. count, 7 or the 4:00 p.m. count, the counts not being 8 conducted? 9 MR. : No. 10 MR. : You haven't heard that? 11 MR. : No. I don't know. Not that 12 I know of. Some, what, counts on these days? 13 MR. : Yeah. 14 MR. : No. You have the 4:00 count. 15 You have the 10:00 count. Yeah, the midnight 16 count. Yeah. 17 MR. : Right. So, what I'm 18 asking, did you -- 19 MR. : Have I heard that -- 20 MR. : -- did you hear 21 MR. -- 4:00 and 10:00 -- 22 MR. : -- that (Indiscernible 23 *01:18:33) -- 24 MR. : -- wasn't done? 25 MR. : Right. EFTA00111096 LIMITED OFFICIAL USE 109 1 MR. : No. 2 MR. : Now, do lieutenants sign 3 the counts or the rounds? 4 MR. : The rounds. Not the counts. 5 MR. : So, what is the 6 lieutenants' responsibility for signing the 7 round sheets? 8 MR. : Making sure they're in 9 compliance with the policy. 10 MR. : All right. And do they 11 have to - is there any way for them to verify 12 if, like, the rounds were actually done? 13 MR. Hmm. No. Unless you're 14 doing a - checking a video. 15 MR. : You just - is what you do 16 is just to make sure that the - it's actually 17 filled out? 18 MR. : Correctly. 19 MR. : Correctly filled out? All 20 right. I'm going to - I apologize for this, 21 it's gotten a little longer - so, I'm going to 22 show you. What is this that I'm showing you? 23 MR. : It's a round sheet. 24 MR. : All right. And what is 25 the round sheet from? EFTA00111097 LIMITED OFFICIAL USE 110 1 MR. : The 9th. 2 MR. : The 9th. Did you have 3 anything - well, as the activities' lieutenant 4 - would of you had anything to do with signing 5 off on any of these? 6 MR. : Yeah. 7 MR. : Which ones would of you 8 signed off on? 9 MR. : Day watch. 10 MR. : Okay. And are you on 11 that? Did you sign any of that? 12 MR. : Yeah. 13 MR. : Where is your signature? 14 MR. : On the day shift. 15 MR. : So, that's your actual 16 signature? 17 MR. : Yeah. 18 MR. : Is that for the SHU? 19 MR. : Yeah. 20 MR. : Who else signed that? 21 MR. : The officer. 22 MR. : Which officer? 23 MR. : I'm not sure. 24 MR. : You can't tell by looking 25 at that? EFTA00111098 LIMITED OFFICIAL USE 1 MR. : No. 2 MR. : All right. And around 3 what time would of you signed that? Do you 4 know? 5 MR. : Some time on my shift. 6 MR. : All right. So, does that 7 indicate that you would have, then, conducted a 8 round in the SHU? 9 MR. : I'm not sure. 10 MR. : Would of you signed that 11 in the SHU? 12 MR. : Honestly, I'm not sure. 13 MR. : How else would of you 14 gotten it? 15 MR. : I'm not sure. 16 MR. : So, is the SHU sheet ever 17 sent outside of the SHU for the lieutenant to 18 sign? 19 MR. : I'm not sure. I can't recs.: 20 on this day. 21 MR. : But what I'm asking is, 22 like, have you ever signed one of these round 23 sheets outside of the SHU? 24 MR. : I'm not sure. 25 MR. : Or is it typically that EFTA00111099 LIMITED OFFICIAL USE 112 1 the lieutenant would sign the sheet in the SHU? 2 Because aren't they maintained in the SHU? 3 MR. : Typically, that's what would 4 happen. 5 MR. : So, typically, you would 6 have signed this in the SHU. Correct? 7 MR. : Yeah. 8 MR. : And would of you signed 9 this after the last one was filled out? I'm 10 assuming they wouldn't fill one out after you 11 signed it, would they? 12 13 14 2:07. Wouldn't that typically mean that you 15 would have been there at least 2:00? 16 MR. : I'm not sure. 17 MR. : But by looking at this 18 document, does that indicate to you, that if 19 you signed it, you would have signed it? Do you 20 ever sign -. Are these continued to be filled 21 out after the - sorry - after the lieutenant 22 signs it? 23 MR. : Yeah. 24 MR. : So, even for day watch 25 right here? MR. : I'm not sure. MR. : So, this one say