APPEARANCES:

1 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: 2 DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: NONE OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL AUGUST 4, 2021 RESOLUTE DOCUMENTATION SERVICES Suite 285 Agoura Hills CA 91301 Phone: 3 4 1 MR. : The recorder is on. My 1 MR. : And you, sir? 2 name is , and I'm a Senior 2 MR. : I am Correctional Counselor 3 Special Agent with the U.S. Department of 3 . 4 Justice, Office of the Inspector General, New 4 MR. : Correctional Counselor? S York Field Office, and these are my S MR. : Yes, sir. 6 credentials. This interview with Federal 6 MR. : And what did you say 7 Bureau of Prisons employee is 7 that, what level was that? Nine? 8 being conducted as part of an official U.S. 8 MR. : GS-9. 9 Department of Justice, Office of the Inspector 9 MR. : GS-9. Great. Thank you, 10 General investigation. Today's date is August 10 sir. This is an official DO]/OIG investigation 11 4, 2021, and the time is 9:24 a.m. This 11 into the death of inmate Jeffrey Epstein, and 12 interview is being conducted at the 12 the surrounding circumstances, and you are 13 Metropolitan Correctional Center, known as the 13 being asked to voluntarily provide answers to 14 MCC, located in New York, New York. Also 14 our questions. Will you agree to a voluntary 15 present is DOJ/OIG Special Agent 15 interview with the DO]/OIG? 16 Do you want to show him your credentials? 16 MR. : Yes. 17 MR. : Thank you. 17 MR. : Thank you, sir. We have 18 MR. : This interview will be 18 a form, it's the DO]/OIG form 3-226/2. It's 19 recorded by me, SSA Could 19 the United States Department of Justice, Office 20 everyone please identify themselves for the 20 of the Inspector General, Warnings and 21 record and spell your last name? To start, 21 Assurances to Employee Requested to Provide 22 wain I am DOJ OIG Senior Special Agent 22 Information on a Voluntary Basis. "You are 23 23 being asked to provide information as part of 24 MR. I am DO]/OIG Special Agent 24 an investigation being conducted by the Office 25 , 25 of the Inspector General. This investigation EFTA00114414 5 6 1 is being conducted, pursuant to the Inspector 1 MR. : Thank you. All right. 2 General Act of 1978, as amended. This 2 The date and time, Wednesday, August -- 3 investigation pertains to job performance 3 MR. : Fourth. 4 failure and security failure. This is a 4 MR. : -- 4, 2021, and the time S voluntary interview. Accordingly, you do not S is 9:26 a.m. now. So, 8/4/21, at 9:26 a.m. 6 have to answer questions. No disciplinary 6 Place: MCC, New York. I am s tiring as the top 7 action will be taken against you if you choose 7 line. Once again, this is , 8 not to answer questions. Any statement you 8 and printing below. Special Agent , can 9 furnish may be used as evidence in any future 9 you just sign as a witness and then put your 10 criminal proceedings or agency disciplinary 10 name below? Thank you. 11 proceedings, or both." 11 MR. : This is Agent . I'm 12 And there's a waiver section. It says, "I 12 signing as a witness and printing my name. 13 understand the Warnings and Assurances stated 13 MR. : All right. So, before we 14 above, and I am willing to make a statement and 14 start the interview I would like to place you 15 answer questions. No promises or threats have 15 under oath. Mr. , can you please raise 16 been made to me, and no pressure or coercion of 16 your right hand? Do you swear to tell the 17 any kind has been used against me." If you 17 truth and nothing but the truth during this 18 want to take a second to look at that, if you 18 interview? 19 agree with it, you can, there's an employee 19 MR. : Yes. 20 signature where you would sign, and then you 20 MR. : Thank you, sir. What is 21 would print your name under here, where it says 21 your date of birth? 22 employee's name. 22 MR. 23 Thank you, sir, for signing. Do you 23 MR. : And our SSN? 24 understand the form? 24 MR. . 25 MR. : Yes. 25 MR. : Thank you. And your 7 8 1 current home address? 1 want to make sure that everything that they 2 MR. : , Bayville, 2 wrote is accurate. 3 New York, 11709. 3 MR. : Uh-huh. 4 MR. : And your current 4 MR. : And just stop me if S cellphone number? S anything is not accurate. 6 MR. . . 6 MR. : Okay. 7 MR. : And what is your current 7 MR. : All right. It says, "The 8 9 position wain? MR. : Correctional Counselor. 8 9 following interview was conduciiiiiilAssistant United States Attorne , AUSA, 10 MR. : And how long have you 10 , , and Office of the 11 been in that 'osition? 11 Insiector General, Special Agent 12 MR. : Since February 2020. 12 . Also present for the interview was 13 MR. : Okay. And what were you 13 Federal Bureau of Investigation Special Agent 14 prior to that? 14 15 MR. : A Lieutenant. 15 11 ," and it says your date 16 MR. : Great. Were you 16 of birth, "was interviewed at the United States 17 previously interviewed under this 17 Attorney's Office, , New 18 investigation? 18 York, New York. After being advised of the 19 MR. : Yes. 19 nature of the interview, and the identities of 20 MR. : All right. Awesome. I'm 20 the interviewing AUSA and Special Agents, 21 just going to review the report that was 21 $ ovided the following information." 22 generated, based upon your interview. I'm 22 " stated he worked for the Bureau 23 going to go kind of, a little slower through 23 of Prisons, BOP, since approximately January 24 it, so that you can actually grasp and 24 15, 2001." 25 understand what it is that they wrote. I just 25 MR. : Yes. EFTA00114415 9 10 1 MR. : "Prior to employment with 1 largely on which area of the prison he or she 2 the BOP, worked for the Building and 2 was assigned to, which rotated on a quarterly 3 Maintenance Union, the Marine Corps Reserve, 3 basis." 4 and the New York Police Department Auxiliary." 4 MR. : Yes. S MR. Yes. : . S MR. : "Those duties include 6 MR. stated he joined 6 operations, activities, solitary housing, 7 the BOP as a Correctional Officer and was 7 special investigations, and administration, as 8 promoted to Lieutenant in October 2015." 8 well as possible collateral duties, such as 9 MR. : Yes. 9 emergency irotection." 10 MR. : "He spent one year at the 10 MR. : Emergency preparedness. 11 Federal Correctional Institution, Fort Dix, 11 Same thin'. 12 when he first joined the BOP and had spent the 12 MR. : Okay. Preparedness? 13 remainder of his tenure at the Metropolitan 13 MR. : It would be the EPO is what 14 Correctional Center." 14 the title was. 15 MR. : Yes. 15 MR. : Sure. I understand. 16 MR. : "Captain 16 " stated he was assigned as the 17 was his supervisor." 17 Activities Lieutenant at the time of the 18 MR. : Yes. 18 interview, and worked the regular 2 p.m. to 10 19 MR. : Who is your supervisor 19 p.m. shift." 20 now? 20 MR. : Yes. 21 MR. : Right now, it's 21 MR. : And then on the daily 22 (Phonetic Sp. *00:06:15) He's my Unit 22 schedule, it actually listed 4 to 12, correct? 23 Manager. 23 You just came in two hours early? 24 MR. : Okay. " stated a 24 MR. : Well, what lieutenants were 25 GS-9 Lieutenant's responsibilities depend 25 doing, we always did two hour reliefs for each 11 12 1 other. 1 Watch Lieutenant would roll in, if they're 2 MR. : Okay. But if I was to 2 going by 8 to 4. Cause I, as an Evening Watch 3 actually look at that daily schedule -- 3 Activities Lieutenant, I worked 2 p.m. to 10 4 MR. : I believe it would show 4 to 4 p.m. But if, like, if the Day Watch Lieutenant 5 12, or actually, if it was activities, S was still there 8 to 4, I would be working two 6 Activities Lieutenants at that time were 6 to 2 6 hours with him or her. 7 and 2 to 10. Operations Lieutenants were on 7 MR. : Yeah, so, I guess what 8 the 8 to 4, 4 to 12, 12 to 8 rotation. 8 I'm asking is, I thought at this time, in 9 MR. : Okay. I see what you're 9 August of 2019, they were allowing the Ops 10 saying. So, there's no actual two hour change, 10 Lieutenants to come in two -- 11 when you're looking at an Activities 11 MR. : We were. We were doing two 12 Lieutenant? 12 hour reliefs for each other. 13 MR. : Yeah, no. 13 MR. : So, you were actually 14 MR. : It is what the actual 14 working the same hours? 15 daily assiiiiilioster said? 15 MR. : Same hours. 16 MR. : It is what the time, yeah. 16 MR. : Okay. 17 I forgot what the, it's been a while. I forgot 17 MR. : Yes, sir. 18 the shift number. 18 MR. : Great. So, you were, 19 MR. : Absolutely. But, so, the 19 both Ops and Activities were 2 to 10 at the 20 Activities and the Ops Lieutenant were working 20 time? 21 the same hours? 21 MR. : Yes. 22 MR. : They will, they piggyback, 22 MR. : Perfect. 23 but let's say, like, the 2 p.m. Activities 23 MR. : Well, I think that's what I 24 Lieutenant, I would be here on the, still under 24 was assigned to. I can't recall 100%. 25 the Day Watch Lieutenant, and then the Evening 25 MR. : Sure. And these are -- EFTA00114416 13 14 1 MR. : When I got interviewed. 1 shifts with other officers." 2 MR. : Sure. So, I'm going to 2 MR. : We're not officers. We're 3 give you, right now, the daily assignment 3 lieutenants. 4 rosters for both Friday, August 9, 2019, and 4 MR. : That's probably what they S Saturday, Au ust 10, 2019. S (Indiscernible *00:09:11). 6 MR. : Uh-huh. 6 MR. Okay. : 7 MR. : It's just so that, if it 7 MR. : So, switched shifts with 8 helps you refresh your memory, cause we're 8 other lieutenants, to be able to fill in for 9 tiiiiiii about so long ago. All right. 9 the Activities Lieutenant, is what you're 10 " stated he was assigned as the 10 saying? 11 Activities Lieutenant at the time of the 11 MR. : Yeah. Or, a lot of the 12 interview and worked the regular 2 p.m. to 10 12 times, we •ot mandated to stay. 13 p.m. shift. His regular days off were Mondays 13 MR. : Right. But only 14 and Tuesdays. He would, on occasion, work 14 lieutenants could actually fill those 15 overtime hours or switch shifts with other 1S positions is what you're saying? 16 officers." 16 MR. : Yeah. Only, well, a 17 MR. : Wait, I'm sorry. Can you 17 lieutenant, only a lieutenant can fill an 18 read that wain? I apologize. 18 Operations Lieutenant. 19 MR. : Absolutely. Okay. So, 19 MR. : Correct. 20 after the 2 p.m. to 10 p.m. shift, which we 20 MR. : You could have a GS-8 21 just discussed. 21 Officer cover as an Activities Lieutenant. 22 MR. : Uh-huh. 22 MR. : Okay. 23 MR. : It says, "His regular 23 MR. : Cause, like, that Friday 24 days off were Mondays and Tuesdays. He would, 24 evening, the night before, I was Operations and 25 on occasion, work overtime hours or switch 25 I had an 8 as my Activities Lieutenant. I had 15 16 1 an officer actin. as Activities. 1 officer. 2 MR. : Okay. So, then, people 2 MR. : Okay. 3 could switch that were officers? 3 MR. : She was my Activities that 4 MR. : No. Only, a lieutenant 4 night. S can't switch with an officer to fill a post. S MR. : I got you. All right. 6 They can backfill, if there's, a lieutenant 6 "As there were no Activity Lieutenants assigned 7 calls in sick. If a lieutenant is not there. 7 during the overnight hours, he had no relief 8 MR. : Okay. So you can't -- 8 officers." I don't know why they would have 9 MR. : They can use a GS -- 9 wrote that sentence in there. So, I'm going to 10 MR. : -- you can't ask an 8, 10 read thi2magraph again, just to help clarify 11 say, hey, can you switch with me? It's only if 11 this. "IIIIIII stated he was assigned as the 12 -- 12 Activities Lieutenant at the time of the 13 MR. : No. Like, as an Activities 13 interview and worked the regular 2 p.m. to 10 14 Lieutenant, I would have to call in sick to the 14 p.m. shift." 15 Captain. If I wanted a shift off, I could 15 Again, on Friday, August 9,12gliere 16 switch with another officer. I can't 16 actually the Ops Lieutenant and 'I'll' was the 17 18 necessarikSi sp with an 8 officer. MR. : Okay. And looking at 17 18 Activities Lieutenant. It says, "His regular days off were Mondays and Tuesdays. He would, 19 this daily assignment roster, I'm assuming you 19 on occasion, work overtime hours or switch 20 noticed that were actually Ops Lieutenant? 20 shifts with other lieutenants." And in this 21 MR. : Yes. I was Evening Watch 21 case, again, ou explained -- 22 Operations the night before. 22 MR. : Uh-huh. 23 MR. : On August 9th? And then 23 MR. : -- that you can't 24 was actually an 8, Acting Lieutenant? 24 actually switch with lieutenants, only if you 25 MR. : Yeah, she was a GS-8 25 get bumped and that position is filled, can an EFTA00114417 17 18 1 8 officer -- 1 There's only an Activities Lieutenant until 10 2 MR. : Yes. 2 p.m. 3 MR. : And then it says, "As 3 MR. : Right. " stated 4 there were no Activity Lieutenants assigned 4 the responsibilities of an Activities S during the overnight hours, he had no relief S Lieutenant include making rounds and placing 6 officers." You weren't doing overnight? 6 inmates in Special Housing. During rounds, 7 MR. : No. I got relieved and went 7 they ensure officers are properly carrying out 8 home that evenin'. 8 their job responsibilities and give the inmates 9 MR. : I'm not exactly, were you 9 the opportunity to address with them any 10 doing overtime shifts for the morning watch? 10 concerns. stated he often attempted to 11 12 Is that wilHie would have wrote that? MR. : It could possibly be. I 11 12 walk all the tiers, based on time." So, on this, we have heard different 13 mean, we worked overtime shifts constantly. At 13 things from different people. As an Ops 14 one point in time, we were short-staffed 14 Lieutenant, or an Activities Lieutenant, are 15 lieutenants like you wouldn't believe. We were 15 you required to go into the SHU, and I'm 16 filling this building with five or six 16 talking specifically at this time, so August 17 lieutenants, we were running the whole 17 9th, August 10th of 2019. Was a lieutenant, or a 18 building. That's one of the reasons why I 18 SHU lieutenant, was a lieutenant responsible to 19 became a counselor. I was never home. 19 go to the SHU and walk the tiers and do a round 20 MR. : Okay. So that is a 20 with the inmates? 21 little confusing. What it's trying to say, 21 MR. : With the inmates? 22 though, is that if you're the Ops Lieutenant, 22 MR. : Yeah. So -- 23 on the morning watch, there is no Activities 23 MR. : Well, a lieutenant is 24 Lieutenant? 24 supposed to, is mandatory, supposed to make 25 MR. : No. Yeah, that, no. 25 rounds. 19 20 1 MR. : So what is the definition 1 actual round, you have to actually walk the 2 3 of a lieutenant round? MR. : A lieutenant round? Well, 2 3 tiers. Diiiiiiinow that to be the case? MR. : Well, yeah. Cause the 4 in the Special Housing or general pop? 4 officer has to let you down range. S MR. : Let's talk just Special S MR. : Okay. 6 Housing. 6 MR. : The officer has the grill 7 MR. : Okay. Special Housing, one, 7 key. Nobody could just go down range in SHU. 8 the lieutenant walks through the 27 door, 8 MR. : Sure. 9 that's the outer door of the SHU. Sign in, in 9 MR. : So, the officer would have 10 the log book. Go in, go, sit down on the 10 to open the grill. You go down range and then 11 computer, login, do the True Scope rounds. Got 11 have to sign the rounds sheet at the end of 12 to enter your rounds in SHU. Go up to 10 12 each range. 13 South. Make the rounds up there. Same thing. 13 MR. : And I think I understand 14 Enter the information in True Scope. 14 what you're saying. You're saying sometimes, 15 MR. : So, when you go into 9 15 there just wasn't time to do it -- 16 South, though, and you're entering in that you 16 MR. : Uh-huh. 17 conducted a round, what does the round entail? 17 MR. : -- but does that actually 18 MR. : Well, making sure that the 18 constitute a round, actually walking down the 19 officers are doing their job. And like I said, 19 range for a lieutenant? 20 if time permits, if you can, you know, do it, 20 MR. : Well, not so much, the 21 go down the range. Go one range, two ranges, 21 officers are supposed to be making the 30 22 three ranies. 22 minute rounds. 23 MR. : And that's where, so, 23 MR. : Sure. 24 this is where we have gotten, some people are 24 MR. : The lieutenant just has to 25 saying they had to do, in order to conduct an 25 make sure that that that, he or she has to go EFTA00114418 21 22 1 in that unit and make sure that the officers 1 purpose behind the 30 minute log book. 2 are doing their rounds. Check the rounds 2 MR. : Right. 3 sheets or the log book, log into True Scope, 3 MR. : The 30 minute round sheets. 4 and, you know, make, basically, is that 4 MR. : Okay. " stated on S lieutenant is confirming that staff are doing S weekdays, the prison takes a count at 4 p.m. 6 their job. 6 The Activities and Operations Lieutenant take a 7 MR. : So, the lieutenant didn't 7 verbal count by speaking with each unit and 8 actually have to walk the tiers? 8 match that number with the count slip from 9 MR. : No. 9 Internal. If correct, they clear the 10 MR. : Okay. 10 institution count. They cannot clear a count 11 MR. : No. 11 until they receive a good verbal count from 12 MR. : And the ranges? All 12 every unit. He was not aware of any instances 13 right. So, that was your understanding? So 13 in which the count was cleared without speaking 14 when you're assigning the actual round that you 14 with ever unit." 15 conducted, it's to say that you basically did a 15 MR. : No. 16 round with your officers, to ensure they were 16 MR. : So that's correct, 17 doing their ob? 17 though? 18 MR. : Their job, and you go into 18 : MR. Yeah. Yeah. 19 the 10 South and do the same. 19 MR. . stated he would 20 MR. : Okay. But not that 20 attempt to watch the camera monitors as the 21 you're actuall conducting a round? 21 corrections officers performed the count to 22 MR. : Huh-uh. 22 ensure officers were properly counting. He 23 MR. : Like, as far as 23 could not monitor at all times, due to the 24 conductiniiiiiiind with inmates? 24 amount of activity in the Control Room." 25 MR. : No. No, that's, the whole 25 MR. : Well, it depends. During 23 24 1 the count m job is mainly taking the count. 1 that? 2 MR. : Right. 2 MR. : Yes. 3 MR. : You know, I could look up at 3 MR. : And about how many people 4 the cameras, you know, but you have a lot of 4 are present in Control when that count is being S movement oin around in Control. S conducted? 6 MR. : Sure. 6 MR. : If we're fully staffed, 7 MR. : You know, throwing keys. 7 we'll have two officers and the lieutenant in 8 If, let's, and there's been many times where we 8 the Control Center. 9 were so short-staffed, we had one officer in 9 MR. : Okay. Okay. So it's 10 Control. 10 three peoile in there? 11 MR. : Uh-huh. 11 MR. : Yeah. It's the Control Room 12 MR. : So, while I'm taking the 12 Officer, the C&A Officer, and it would be the 13 count, I'm also doing C&A. I'm helping him 13 lieutenant, Activities or Ops. 14 throw keys. You know, but as far as clearing 14 MR. : What does C&A stand for? 15 the count, yes. You cannot clear the count 15 MR. : Counts, truth be told, I 16 until you get a verbal, verbal, good verbal 16 have a total brain (Indiscernible *00:17:03). 17 count from the Unit Officer, cause we have the 17 Count -- 18 PP1, the El, in front of us with the actual 18 MR. : So, it's like Control 19 accurate count, as per Sentry. So we have to 19 Number 1, Control Number 2 -- 20 compare those numbers. You write it down. We 20 MR. : Two, yeah. 21 compare it. So, you cross it off on the Sentry 21 MR. : -- and you're saying 22 paperwork... ol I'll call in a good count. 22 Control Number 2 is --23 MR. : But, as far as, like, the 23 MR. : Control Number 2 is C&A. 24 4 p.m. count, the Activities or Ops Lieutenant 24 MR. : Okay. 25 has to actually be present in Control to do 25 MR. : Old school, it used to be EFTA00114419 25 26 1 called C&A. 1 10. 2 MR. : Okay. 2 MR. : So, as far as the 4 p.m. 3 MR. : I know it's Counts and 3 count, that would not have been ? 4 Accountability, I think is what the acronym 4 MR. : Well, viould have been 5 was. 5 in Control, cause he would have been the 6 MR. : Okay. So that's the 6 Control 1 Officer. 7 person who actually, like, receives the counts 7 MR. : Oh, I thought it was 8 from people? 8 Control 2 for him. 9 MR. : Yes. 9 MR. : Control, no, Control 1, 10 MR. : Is that what you're 10 is Control 1 and is Control 2. 11 saying? 11 MR. : Oh, okay. So, okay. So, 12 MR. : C&A is the one that does all 12 what would Control l's typical responsibilities 13 the Sentry work for all the movement, you know, 13 have been? 14 to make sure the roster is accurate, the 14 MR. : At 4:00, the same thing. At 15 counts, or the unit base counts and unit counts 15 4:00, people are leaving, so that person would 16 are accurate. 16 be over at the window, throwing keys. We call 17 MR. : That's Control Number 2? 17 it throwin ke s. 18 MR. : Yeah. 18 MR. : Okay. 19 MR. : So, in this case, if 19 MR. : It's just, it's an 20 you're looking at August, Friday, August 9, 20 expression. He would be taking the keys, 21 2019, would that Control Officer Number 2, can 21 radios, OC and stuff like that from the 22 you tell me who that would have been? 22 departing staff, putting it back on the board, 23 MR. : (Phonetic2. 23 giving them their chits and receiving chits for 24 1)0:17:49) for the 6 to 2 shift, and IIII 24 equipment for the oncoming staff. 25 (Phonetic Sp. *00:17:51) for the 2 to 25 MR. : Okay. So, in this case, 27 28 1 it should have been, at least at 4 p.m., the 1 Again, you said that you might glance up, but 2 person that would be signing the documents and 2 you're not actually, like -- 3 taking the count should have been this 3 MR. : Yeah. Yeah, I wasn't 4 and not 2 4 staring. S MR. : With the lieutenant. S MR. : Sure. Absolutely. 6 MR. : With the lieutenant. 6 MR. : You know? I would be 7 Okay. And after we're done with this, we'll 7 answering the phones, writing down the actual 8 just go over some of the counts, just to -- 8 count -- 9 MR. : Okay. 9 MR. : Totally. 10 MR. : But we'll move on, just 10 MR. : -- you know, the crossing 11 to make sure we can keep moving on this. I'm 11 off, and, you know, making the, especially if I 12 just going to read it over to, I can't remember 12 had seen that, like, if a count was being 13 exactly where I left off. 13 delayed, I would be, like, what's the problem? 14 MR. : Fourth paragraph. 14 And I would look. You know. 15 MR. : Third_p_lagraph? 15 MR. : I got you. So, you're 16 MR. : Fourth. M stated he 16 not, like, yeah, making sure they're doing 17 was normally relieved (Indiscernible *00:19:24) 17 their job -- 18 before 10 •.m. 18 MR. : It's not, I'm not glued to 19 MR. : I'm just to read 19 the camera. 20 this last paragraph over. "IIIIIII stated he 20 MR. : -- cause you have your 21 would attempt to watch the camera monitors as 21 own job to be doing, is what you're saying? 22 the corrections officers performed the count to 22 MR. : Yeah. 23 ensure officers were properly counting. He 23 MR. : Okay. " stated he 24 could not monitor at all times, due to the 24 would normally relieve, be relieved before 10 25 amount of activity in the Control Room." 25 p.m., prior to evening count. He had heard of EFTA00114420 29 30 1 an instance where the count was not properly 1 in the past." Any information on that? 2 completed, but he had, but it had been some 2 MR. : No. I mean, it was 3 time in the past." So, if you're that 2 to 10 3 probably, I remember when I said that. It was, 4 shift, do you do the 4, the relieving shift 4 you always hear of the horror stories, and when S would typically do the 10 p.m., is what you're S you come home, come in off your days off, you 6 saying? 6 would be, like, oh, you know, what happened the 7 MR. : Yes. 7 other day? Or this, that, and the third. You 8 MR. : Okay. Do you ever do the 8 know. 9 10 p.m.? 9 MR. : Right. 10 MR. : On nights that I was coming 10 MR. : That kind of thing. 11 in for the overni'ht. 11 MR. : Okay. 12 MR. : But, I mean, as the 2 to 12 MR. : But I have never heard it 13 10 shift, do ever do the 10 p.m.? 13 where it has been detrimental. 14 MR. : I probably have, but I can't 14 MR. : Okay. But it wasn't 15 even recall when the last time I was. 15 talking specifically about, like, August 9th 16 MR. : Yeah, yeah. It's 16 (Indiscernible *00:21:12). 17 typically that relieving officer's duty, 17 MR. : No, no. I'm talking, like, 18 though? 18 ten years. I wasn't even a lieutenant at the 19 MR. : Yeah. The relieving 19 time. 20 lieutenant. 20 MR. : Okay. 21 MR. : Lieutenant, right. 21 MR. : You know, I was still an 22 MR. : Yeah. 22 officer. 23 MR. : And then it says, "He had 23 MR. .. " stated, as a 24 heard of an instance where the count was not 24 lieutenant, he viorked to enforce policy through 25 properly completed, but it had been some time 25 verbal counseling and by example. Taking the 31 32 1 count is one of the most important duties 1 them doing the K2 or, you know, making weapons 2 corrections," I keep on saying corrections, but 2 or tattooin' or things of that nature. 3 I know it's correctional officers "perform as 3 MR. : Sure. 4 professionals." 4 MR. : You know, so, of course, S MR. : Right. It's accountability. S making rounds, being visible. That's what we 6 Inmate accountability is the most important 6 like to say, and, like, when we're training or 7 thing here. Maintain security. 7 whatever. Be visible. 8 MR. : Okay. 8 MR. : Sure. 9 MR. : You got to make sure that 9 MR. : Make the inmates see you. 10 they're all here at the end of the day. 10 MR. : So, counts are basically 11 MR. : So, are you saying, like, 11 to ensure everybody is there. And rounds are 12 basically, counts and rounds are the most 12 to ensure that inmates are kind of doing what 13 important things that a correctional officer 13 they're su osed to be doing? 14 does? 14 MR. : Yes. 15 MR. : Count, I mean, everything, 15 MR. : Okay. 16 controlling contraband, shaking down. 16 MR. : And that's a perfect, what's 17 Nowadays, with the K2, it's ridiculous. 17 the word I'm looking for? Perfect expression. 18 MR. : Right. 18 MR. : Okay. Perfect example. 19 MR. : You know, there's a lot on 19 Okay. 20 an officer's shoulders. 20 MR. : Yeah. 21 MR. : Right. 21 MR. : " stated the 22 MR. : But of course, you know, we 22 Special Housing Unit is responsible for doing 23 only do the counts at certain periods 23 rounds every 30 minutes. As the lieutenant, he 24 throughout the day. You know? The officers 24 would sign round forms, if they were correct. 25 making rounds are what helps reduce the fact of 25 He had never signed off on forms that were EFTA00114421 33 34 1 filled out in advance, and would report any 2 instances of that to his supervisors, if he was 3 aware of it." So, I'm assuming what you mean 4 there is, if you knew they were filled out in S advance? 6 MR. : I wouldn't sign them. 7 MR. : Right. 8 MR. : I'm not putting my John 9 Hancock on that. I would tell them 10 (Indiscernible *00:22:58). 11 MR. : But, how would you know 12 if they had filled it out in advance? You 13 mean, if -- 14 MR. : If I went there and sat, and 15 if I walked into the SHU unit and it was 1:00, 16 I'm just throwin the time out there -- 17 MR. : Sure. 18 MR. : 1:00 p.m., but I saw the 19 rounds sheet, it was 1:00 when I walked in, but 20 I look at the rounds sheet and the 1:30 rounds 21 are alread filled out. 22 MR. : And would that happen? 23 MR. : Very rarely. But I might, I 24 don't think I have seen it as a lieutenant, but 25 I have heard of it happening. 1 MR. : But you never really, you 2 never witnessed it? 3 MR. : But, I was trained 4 differently. I was trained, you don't put your S ink to paper unless it's the way it's supposed 6 to be, and if it is, tell the boss. 7 MR. : Now, back then, August of 8 2019, had you heard that people were filling 9 them out in advance? 10 MR. : No. I didn't. 11 MR. : No? 12 MR. : No. 13 MR. : Okay. So you're not 14 aware of anybod filling them out in advance? 15 MR. : No. I have no personal 16 knowledge. 17 MR. : "He trained officers to 18 defer their round patterns, so inmates would 19 not be aware of their timing." 20 MR. : Yes. 21 MR. : And that means it's just 22 not to be on an exactly 30 minute -- 23 MR. : Yeah. Don't always make 24 your rounds at 1:05, 1:35, 1:45. Alternate 25 your rounds. The policy states, every 30 35 1 minutes, not to exceed 40. 2 MR. : Right. 3 MR. : You know? 4 MR. stated he had S heard stories of officers not completing their 6 30 minute rounds in the SHU. Other than the 7 Jeffrey Epstein death, he had not heard of an 8 instance for a roximately five to ten years." 9 MR. : Yes. 10 MR. : So, I'm assuming what 11 you're sa in here is -- 12 MR. : Back in the days. 13 MR. : But I'm assuming what you 14 said, when you say other than Jeffrey Epstein, 15 you did hear that they did not complete their 16 30 minute rounds? 17 MR. : I mean, bureau-wide. People 18 have gotten in trouble for it before. 19 MR. Right. 20 MR. why, like, this : 21 whole, this was all new with the fact that how 22 serious it ot. 23 MR. : Okay. But you had heard 24 that, had you heard that on August 9th and 10th, 25 then, and I am assuming this means after the 36 1 fact, that people weren't conducting their 30 2 minute rounds? 3 MR. : The only thing I heard is 4 the same thing everybody else has heard, out on S the street. 6 MR. : Okay. 7 MR. : What you hear in the media, 8 what you hear on social media, what you hear in 9 the newspa ers. They were very quiet here. 10 MR. : Okay. 11 MR. : I was here that morning of, 12 after the fact, and we didn't get told 13 anything. 14 MR. : Are you talking about 15 August 10th? 16 MR. : Yeah. That Saturday. 17 MR. : Okay. 18 MR. : You know. There was a total 19 blackout. We were kept in the dark. 20 MR. : And you hadn't heard 21 anything about, like, people not conducting 22 counts or rounds? 23 MR. : No. Just, well, like I 24 said, the same thing you heard out on the 25 street. EFTA00114422 1 37 MR. : But, I mean, not from 1 38 MR. : I would just assume 2 inside the institution? 2 people would have been talking inside the 3 MR. : No. 3 institution. I wanted to make sure that you 4 MR. : No one was speaking about 4 also heard it inside the institution, not just S that? S through the media? 6 MR. : Well, I mean, the whispers, 6 MR. : Yeah. No, I mean, I, like, 7 here and there but nothing was confirmed. 7 as far as a whisper here and a rumor here, I 8 MR. : Okay. 8 chose to stay away from it, because, one, I was 9 MR. : You know? Of course, when 9 a supervisor and two, I know what was coming 10 something like this, look, it's, I have been 10 down. 11 doing this almost 21 years. When something, 11 MR. : Sure. 12 God forbid happens like this, everybody Monday 12 MR. : I knew how serious it was 13 morning quarterbacks. 13 going to be. And I was not going to entertain 14 MR. : Sure. 14 any of that. 15 MR. : Everybody talks, oh, they 15 MR. : Sure. So, you had heard 16 must have done this, or they didn't do this. 16 people saying that there were rounds and counts 17 That's all I have heard. 17 weren't complete; however, you didn't put any 18 MR. : Uh-huh. 18 credibilit to it -- 19 MR. : I didn't hear nothing 19 MR. : No. 20 official, if that's what you're asking. 20 MR. : -- because it wasn't 21 MR. : Yeah. No, no, no. 21 official? 22 MR. : I have heard rumor mills. 22 MR. : No. It wasn't, it wasn't 23 MR. : I just wanted to know -- 23 official. It was just rumor mills. It was 24 MR. : There were whispers. This, 24 whispers. It was Monday morning 25 that, and the other thing. 25 quarterbacking, for lack of better terms. 39 40 1 MR. : Okay. But that was a 1 what you're saying is that since you have 2 correct, was that a correct assessment, which I 2 worked, miiiiiiiere was about two suicides? 3 just -- 3 MR. : I had one, I was personally 4 MR. : Yes. Yes. 4 involved in one in 2003, and that's the one S MR. : Okay. S that I was, that I referenced. There was one 6 MR. : I apologize. I don't mean 6 years later. I don't recall what year it was, 7 to go lone-winded on it. 7 or the outcome of that one. I just know that 8 MR. : No, no, no. lust cause 8 the one that I was involved in, the officer in 9 when I said it, you said, no, but I just wanted 9 charge in the SHU unit got suspended for it. 10 to make sure 'au actually meant yes. 10 MR. : Okay. 11 MR. : Yeah, no. Like, I heard -- 11 MR. : So, the rounds were made, 12 MR. : With what, I know, I 12 but they weren't within that 30 to 40 minute, 13 understand -- 13 so the OIC sot hit on that one. 14 MR. : -- nothing official. Yeah. 14 MR. . And do you know why the 15 MR. : Right, yeah, yeah. I 15 OIC? 16 just, cause for the transcript, it will read 16 MR. : I think the rounds, I think, 17 that you're contradicting what I said, and I 17 if I can recall correctly, I think when he 18 just want to make sure -- 18 entered the round, about 40 minutes, but it 19 MR. : No problem. 19 turned out it didn't jive with the camera. So 20 MR. : -- what I said was 20 they suspended him. 21 actually accurate. Okay. 21 MR. : All right. So, if the 22 MR. : Uh-huh. 22 time that he wrote on the paper didn't show -- 23 MR. . stated he 23 MR. Didn't jive with the camera. : 24 recalled suicides taking place in MCC in 2003 24 MR. : (Indiscernible 25 and another several years later." So, I guess, 25 *00:27:38). EFTA00114423 41 42 1 MR. : Like, the reason, the camera 1 MR. : Okay. So it happened 2 showed we were making rounds. We just didn't 2 actually in the afternoon? 3 make them between 30 and 40, that 30 minute, 3 MR. : Yeah. That was on day 4 not to exceed 40, I believe it just didn't jive 4 shift. S with the camera. 5 MR. : Did he have a cellmate at 6 MR. : Okay. 6 the time? 7 MR. : And they hit him. 7 MR. Yes, he did. : 8 MR. : And were you actually 8 MR. : And the cellmate didn't 9 working in the SHU at the time? 9 notice? 10 MR. : I was in the SHU at the 10 MR. : His cellmate said, yo, you 11 time. 11 want to take care of this? 12 MR. : Okay. 12 MR. : Oh, wow. 13 MR. : I was one of the officers 13 MR. : And he was strung up. 14 that cut that inmate down and we tried to do 14 MR. : Was it also from, where 15 CPR on him. We did CPR on him. We got him 15 was it, where was he hanging from? 16 down to Medical, and then they rushed him out 16 MR. : He had the thing tied up. 17 in an ambulance. 17 He was between the bunk and the window. 18 MR. : And just out of 18 MR. : Okay. Was he attached to 19 curiosity, in that case, at about what time was 19 the bunk or what was he attached to? 20 he found? 20 MR. : I think he was attached to 21 MR. : Oh, that was, like, 3:30 21 the window, if I recall. I honestly don't 22 something. 22 remember. That was a long time ago. 23 MR. : In the afternoon? 23 MR. : Sure, sure, sure. 24 MR. : It was before the 4 p.m. 24 MR. : It was either the top of the 25 count. 25 bunk or to the window. He was between, I do 43 44 1 remember he was between the bunk and the 1 MR. : I don't remember exactly the 2 window. 2 dates or the stipulations on the one that 3 MR. : But that's important to 3 happened ears later. 4 note. So he actually had a cellmate at the 4 MR. : Do you happen to remember 5 time? S the name of that inmate? 6 MR. : Uh-huh. 6 MR. : Of that committed suicide? 7 MR. : And he still was able to 7 , I believe. 8 successful) - 8 MR. . ? 9 MR. : Yes. 9 MR. : Yeah. 10 MR. • -- and it was deemed a 10 MR. : Okay. " stated he 11 suicide, not a murder? 11 was on duty the night Epstein was brought to 12 MR. : Yes. 12 MCC. He was received at the rear gate and 13 MR. : Okay. 13 observed him being processed in." 14 MR. : Cause his cellmate never got 14 MR. : Uh-huh. 15 charged. 15 MR. : "At the time of his 16 MR. : And do you know what he 16 arrival, Epstein was deemed okay to go to 17 used to h!ag_tiliself? 17 general population. was unaware of his 18 MR. IIIIIII: I believe it was cut-up 18 high profile." 19 bedsheets. 19 MR. : Yes. I remember when he 20 MR. : Okay. 20 came in. The only thing that I remember that 21 MR. : If I recall correctly. 21 stuck out in my mind, he went to the same high 22 MR. : All right. And that was 22 school that I did. 23 the 2001 or -- 23 MR. : Okay. 24 MR. : That was 2003. 24 MR. : I graduated from the same 25 MR. : That was the 2003 one? 25 high school. Cause the cop, I think he was an EFTA00114424 45 46 1 NYPD task force guy with the FBI, he was from 1 MR. : Interesting. Okay. So, 2 Brooklyn and we chatted, cause we had Brooklyn 2 it was just within 24 hours, he was moved from 3 accents, and come, you know, me and the cop 3 general polulation to SHU? 4 were from, like, basically, the same area in 4 MR. : I believe so. I believe, S Brooklyn, and he was, like, what high school S less, I believe less than 48, definitely. 6 did you graduate from? And I said, Lafayette, 6 MR. : Okay. All right. 7 and Epstein actually said, so did I. I 7 " stated he knew Epstein to be in visits 8 graduated from Lafayette High School. 8 often with his legal counsel." 9 MR. : Interesting. 9 MR. : Yes. 10 MR. : I processed him. Sent him 10 MR. : "Often until 7 to 8 p.m." 11 up. I actually found out that they moved him 11 MR. : Yes. 12 to the Special Housing because of his profile 12 MR. : "Other than the intake 13 status when I came back to work. 13 questions Epstein answered on his arrival, 14 MR. : So, you had no idea who 14 IIIIIII had no other personal interaction with 15 he was? 15 him." 16 MR. : I had no idea who he was. 16 MR. : No. 17 As a matter of fact, the next morning, my wife 17 MR. : So you never just, you 18 actually said, you'll probably be getting him 18 never -- 19 soon. And showed me the phone, you know, the 19 MR. : Never chatted with him. I 20 news feed, and I said, soon? We got him last 20 would just escort him. Cause at one point in 21 night. Then I knew who he was. 21 time, a lieutenant had to move him. 22 MR. : Okay. 22 MR. : Okay. And what about 23 MR. : And then when I came, by the 23 when you would visit the SHU? Would you ever 24 time I came back to work, though, he was 24 check in on his cell or anything like that? 25 already in SEC (Phonetic Sp. *00:30:35). 25 Would you ever look through the door or say, 47 48 1 hey, what's u.? 1 MR. : The officers would have to 2 MR. : Right. When he was on, 2 do the out count. 3 like, when he would be on one tier, I remember, 3 MR. : Yeah, so my understanding 4 I think, at one point in time, he was on H 4 was that he would basically be brought down S tier, if I'm not mistaken. The only time I S around 8 a.m. and stay until almost 8 p.m. Is 6 would really see him on the tier is when I 6 that -- 7 would escort him. 7 MR. : A lot of the times, he 8 MR. : And what would you, what 8 would. 9 would be the 'urpose of escorting him? 9 MR. : So not always, though? 10 MR. : Down to attorney conference, 10 MR. : Sometimes, he would go back 11 for his liiiiiiiiiis. 11 to SHU and then a different attorney would come 12 MR. : Okay. So, would that be, 12 in and he would be brought back down in the 13 then, in the morning, you would do that? 13 afternoon. 14 MR. : It would be all day long. 14 MR. : Oh, I see. 15 He would get legal visits all day, into the 15 MR. : You know, he had legal 16 evening. 16 visits in and out of here all day long. 17 MR. : And he would be going 17 MR. : Okay. So, you talk about 18 back and forth between the SHU? 18 when you would escort him, would be that kind 19 MR. : Well, most of the time, he 19 of middle timeframe? 20 would get brought downstairs and he would be 20 MR. : Yeah. 21 there for hours. 21 MR. : So if he ever went back 22 MR. : Right. 22 to the SHU -- 23 MR. : There would be times he 23 MR. : Depending on what shift I 24 would be through the count. 24 was on. 25 iiiiiiiiiiisits MR. : Yeah. 25 MR. : Okay. And when you were EFTA00114425 49 50 1 escorting him, would you communicate with him? 1 no problem. He was being escorted by a 2 MR. : Basically, how are you 2 supervisor, so I went back into the 3 doing? All right. Well, I don't, I don't get 3 lieutenant's office. 4 too churn with inmates. 4 MR. : All right. S MR. : Sure. I would just, you S MR. : And that was the last time I 6 know, with Epstein, I'm assuming, it might 6 saw him. 7 stand out in your little, you know, in your 7 MR. : So, is the one 8 head a little bit more. Do you know the last 8 who escorted him from attorney conferences on 9 time that you had escorted him or 9 August 9th? 10 (Indiscernible *00:32:35)? 10 MR. : Was it the 9th or 19th? 11 MR. : I was about to escort him 11 MR. : The 9th. So, August 9, 12 the night before he died. 12 2019. 13 MR. : And what happened? 13 MR. : Okay. Yeah. That Friday 14 MR. : I was in the lieutenant's 14 night. 15 office, and the attorney conference officer 15 MR. : He was found on August 16 said hey, he's rill") go. But Mr. 16 10th. 17 was here, and was, like, , I 17 MR. : The Friday night. 18 will take him u'. 18 MR. : Right. Okay. 19 MR. : Okay. 19 MR. : I forget the actual date. I 20 MR. : And he said, you know, by 20 remember it being a Friday. I just forgot the 21 the way, I'm going to take him up. I'm going 21 date. 22 to give him a le al call. 22 MR. : And do you remember, 23 MR. : Okay. 23 though, the last time you had interacted with 24 MR. : I was, like, okay. No 24 him? 25 problem. is a GS-12, so. I was like, 25 MR. : No, I do not. I don't 51 52 1 recall. 1 Epstein's first alleged suicide attempt. His 2 MR. : No? Okay. And then 2 only other involvement with Epstein was to 3 again, back to SHU, when you would visit the 3 bring him food while in the SHU." 4 SHU and do a round, would you peek in on his 4 MR. : Yeah, if he was on I tier. S window or anything? Would you check with him S MR. : Okay. 6 and say, thing -- 6 MR. : Cause on I tier, the 7 MR. : I mean, sometimes, his cell ail 7 lieutenants have to, have the key to the wicket 8 was right over where the OIC desk was. 8 to be able to feed, but if he was on a regular 9 MR. : Right. 9 tier, no. There was times when, and when he 10 MR. : And I could look right into 10 was a lieutenant hold, a lieutenant had to open 11 his cell, and most of the time, I would see him 11 his, be there every time his slot was opened. 12 in it. 12 But he wasn't alwa son a lieutenant hold. 13 MR. Okay. 13 MR. : Can you explain that 14 : MR. And didn't interact with him 14 more? Cause tier is like the 10 South of the 15 though. 15 SHU, right? 16 MR. : But not actually check in 16 MR. : I tier is like a mini, it's 17 and say, are good or anything like that? 17 almost like 10 South. The inmates are self- 18 MR. : No. If I was making a round 18 sustained in there. They have their own 19 downrange, I would peek in. I would peek in 19 shower. They have their own, you know, it's 20 all the cells, if I'm downrange. 20 basically, it's a bigger room. It's almost 21 MR. : Right. 21 like the 10 South rooms. But also the same 22 MR. : But not on a regular basis, 22 thing, the SHU lieutenant, or if the SHU 23 no. 23 lieutenant, afterhours, there's no SHU 24 MR. : Okay. " stated he 24 lieutenant, only a lieutenant can open those 25 was not involved officially in regard to 25 (Indiscernible *00:34:50) boxes. The wickets. EFTA00114426 53 54 1 MR. : So, was Epstein ever on I 1 trying to get the accuracy of this thing, so 2 tier? 2 it's only -- 3 MR. : I don't recall. I don't 3 MR. : I don't, I don't remember. 4 remember. 4 That's the i oblem I remember -- S MR. : So what does this mean by S MR. • So, do you remember ever 6 his only other involvement with Epstein was to 6 bringing food in the SHU? 7 bring him food? 7 MR. : I fed him before. But that i• 8 MR. : Food. When they're a 8 might have also been just because I happened to 9 lieutenant hold, even if they're in a regular 9 be downrange. I can't recall if, I don't 10 SHU cell, a lieutenant has to be present to 10 recall if he was ever actually a lieutenant 11 open the slot. Even though the lieutenant 11 hold. 12 doesn't have to open it himself, the lieutenant 12 MR. : Okay. 13 has to be there when the slot is opened. 13 MR. : I remember he had to be 14 MR. : So, anytime inmates are 14 escorted from attorney conference. So that's 15 served food in the SHU, a lieutenant has to be 15 what, cause that's what -- 16 present? 16 MR. : How would his feeding be 17 MR. : No. Not every inmate. Only 17 done, when he was in attorney conference? 18 if the inmate is a lieutenant move. Like, if a 18 Would the would you feed him? 19 lieutenant has to be present, like, high 19 MR. : Sometimes, they would get a 20 security. Like if they're assaultive. Inmates 20 bag lunch. And they would take it up with 21 could be 'ut -- 21 them. 22 MR. : So, was Epstein ever a 22 MR. : So, as in, like, when -- 23 lieutenant move? 23 MR. : I don't remember if he ever 24 MR. : I'm not 100% sure. 24 ate in the attorney conference room, but he 25 MR. : So, that's where I'm just 25 wouldn't get the food from the food cart there. 55 56 1 He would get, like, the bag lunch from . 1 like, what time, you know, when he would get, 2 MR. IIIIIIIIII: So, like, if he, when he 2 return back at the 8 p.m. mark. Would that be 3 was escorted in the morning, they would give 3 when he would be fed? 4 him a bag lunch to bring into the attorney -- 4 MR. : Well, he would if he was S MR. : Yeah. Well, like, they S given the food in , like, not III, the bag 6 have, sometimes, I believe, he would get, I'm 6 lunches, he would have it given to him in 7 not sure, he could be escorted back to the 7 attorney conference and he would take it with 8 Special Housini to eat his meal. 8 him. 9 MR. : Okay. 9 MR. : Okay. 10 MR. : Use the restroom or 10 MR. : You know, if he was going to 11 whatever, and go down, but they get to use the 11 eat past dinnertime, but also, a lot of the 12 restroom when they're in attorney conference, 12 times, too, if he was, like, not just him. Any 13 anyway. 13 inmate. If they're downstairs, the officers 14 MR. : Okay. So you're not 14 could also place the food in his cell, and he 15 exactly sure how he was fed, then? 15 could have the food when he comes back from 16 MR. : Not down in attorney 16 attorney conference. 17 conference, no. 17 MR. : Okay. So, they can go in 18 MR. : Okay. Cause he was there 18 his cell ahead of time, put it in there, even 19 every dayiliiiii? 19 if he had a cellmate? 20 MR. : Yes. He was there pretty 20 MR. : Yes. 21 much ever day. 21 MR. : Okay. And there was 22 MR. : Okay. 22 never problems with, like, the other cellmate - 23 MR. : That I recall. 23 - 24 MR. : All right. So, the food, 24 MR. : No. I mean, for the most 25 I'm assuming, would have taken place more at, 25 part, the inmates respect each other. EFTA00114427 57 1 MR. : Okay. ' stated he 2 was aware Epstein had been moved back to the 3 SHU, and that he was required to have a 4 roommate,Iiiiiiimass email he had received." S MR. : Yeah. It went out to all 6 lieutenants. 7 MR. : So, you received an 8 email, saying that Epstein was required to have 9 a cellmate? 10 MR. Yes. M 11 MR. : Okay. And was that 12 requirement still in place on August 9, 2019? 13 MR. I believe so. 14 MR. : Okay. " stated he 15 did not have any conversations with anyone 16 regarding Epstein's need for a roommate, a 17 cellmate." So no one ever verbalized that to 18 you? 19 MR. Just in the email. 20 MR. : Just the -- 21 MR. And Psychology would let us 22 know. 23 MR. : Would Psychology actually 24 verbalize it? 25 MR. : I mean, basically, yeah. 58 1 Like, for lack of, they would say that, you 2 know, not on a daily basis. They would just 3 say, any kind of, especially if they have had a 4 suicide attempt in the past, they get put on S what's called the hot list. Psychology threats 6 are always on the hot list. Inmates that are 7 on the hot list should always have a bunkie. 8 MR. : Okay. So, anybody on the 9 hot list iiiiiiibunkie? 10 MR. : As long, if it's dictated in 11 there by Psychology. Psychology fills out the 12 hot list. 13 MR. : Right. 14 MR. And it gets, they update it. 15 MR. : So, is Psychology's hot 16 list, is it just for the people that need 17 cellmates or is it also people that can't have 18 cellmates? What is the hot list? 19 MR. : What do you mean? Can or 20 can't? What mean? 21 MR. : Can't, cause aren't there 22 some people that have, like, you know, 23 (Indiscernible *00:38:34). 24 MR. : Separation, no, the hot list 25 doesn't pertain, the hot list is psychological. 59 1 It's from Ps Psychology generates it. 2 MR. : So, if you're on the hot 3 list, eveiiiiiiigets a cellmate? 4 MR. : Yeah. If it's annotated in S there. It will, every inmate's, in the hot 6 list, a picture of the inmate is in there. 7 That is, whether he or she is in for a Psych 8 study or a forensic study or what have you, and 9 it will say, you know, suicide attempts in the 10 past. Or cutter. Or what have you. 11 MR. : And where would that hot 12 list be? 13 MR. : The hot list is kept in SHU. 14 MR. : Where in the SHU? 15 MR. : It should be in a, either on 16 a clipboard or in a folder. 17 MR. : And do you know where it 18 was on August 9, 2019? 19 MR. : It should have been, I'm not 20 100% sure. I can't recall, but it should have 21 been on a cli board on the hook. 22 MR. : And are the officers -- 23 MR. By the officers' station. 24 MR. : Are the officers that are 25 in SHU required to look at that hot list? 60 1 MR. llYes. 2 MR. : All right. So, they 3 should know -- 4 MR. : They should be familiar with 5 who is on the hot list. 6 MR. : So, is everybody that 7 worked in the SHU, should have they known that 8 Epstein was required to have a cellmate? 9 MR. : Yes. 10 MR. : Is there any reason for 11 someone to say that they didn't know that 12 Epstein was re to have a cellmate? 13 MR. : Unless they weren't assigned 14 to the post and they were thrown in there on 15 overtime or mandated to work overtime and they 16 weren't familiar with it, that can happen. But 17 if you're steady, assigned to that post, you 18 should be familiar with the hot list. 19 MR. : Okay. And is there any 20 kind of requirement for people, like, overtime 21 that are, you know, not regularly working in 22 the SHU, to be either briefed on the hot list 23 or to review the hot list when they joined? 24 MR. : It all depends. Like, I 25 mean, a good SHU officer, worth his weight in EFTA00114428 61 62 1 salt, would at least talk the staff member 1 , and basically, is 6 to 2. 2 through it. But, like I said, there was plenty 2 is a senior staff member. 3 of times where the entire SHU crew were all 3 IPhonetic Sp. *00:41:12) was a rookie. Officer 4 overtimers. 4 IIIII is a senior staff member. So, three out S MR. : Right. 5 of the four on the day shift. 6 MR. : So, nobody came to work. 6 MR. : So, you're saying 7 MR. : Okay. 7 everybody but -- 8 MR. : And a lot of the times, you 8 MR. : Yeah. 9 would have SHU crews, never mind just SHU 9 MR. : -- should have known? 10 crews, institutional staff that would be 10 Okay. What about for the evening shift? 11 zombies, because they had been getting stuck 11 MR. : Evening shift? All right. 12 four days in a row. So a lot of the times, 12 had a couple of years on the job. The 13 things, you know, it's a lot to absorb. You 13 SHU floor was unassigned, because we were 14 just, you•iiThr i to do the job. 14 short. There was only three officers. 15 MR. : Okay. So, looking at the 15 is non-custody. So, would 16 August 9, 2019, roster, and I'm going to say 16 not be super familiar with it, because he 17 from the 8 a.m. hour on to the end of the day, 17 worked warehouse. 18 for the people that were working in the SHU, 18 MR. : Okay. 19 can you tell me who you believe should have 19 MR. : And he's with commissary. 20 known that he was required to have a cellmate? 20 MR. : Was he a -- 21 MR. : For the day shift or the 21 MR. : Noel was fairly new. She 22 evening shift? 22 had, maybe, just a little over a year on the 23 MR. : Just from 8 a.m. on. 23 job. 24 MR. : 8 a.m. on. All right. 24 MR. : But if Noel was a regular 25 Well, it looks, there was three officers, 25 SHU person, that was her quarterly post, should 63 64 1 she have known what the hot list was? 1 MR. : Every time it gets updated, 2 MR. : Yes. 2 and they out a new one, it should be reviewed. 3 MR. : And should have she known 3 MR. : Okay. 4 that Epstein was required to have a cellmate? 4 MR. : And I don't, I honestly S MR. : Yes. You have to sign for S haven't seen it in a while, cause now, my 6 the hot, you have to sign that you reviewed the 6 contact with Special Housing is limited, now 7 hot list. 7 that I'm a counselor. 8 MR. : Oh, you do have to sign 8 MR. : Did you make that note? 9 that? 9 MR. : Yeah. Can I ask a question 10 MR. : Yeah. Uh-huh. 10 on that? 11 MR. : All right. And who, when 11 MR. : Yes. 12 13 do you siiiiiii? MR. : Last I checked, I don't, I 12 13 MR. MR. : Mat exactly are you signing? : That you reviewed the hot 14 can't get quoted on this, cause I'm not 100% 14 list. 15 certain. We would sign it a lot, like, well, 15 MR. : But, is that, like, a form or 16 at least the lieutenants, would sign it when we 16 is it on the coo), -- 17 would do lieutenants meetings and meet with 17 MR. : It's a sign-in sheet. 18 Psychology and go, review the hot list, we 18 MR. : A sign-in sheet? 19 would alliiiiiiiiiit. 19 MR. : Yeah. 20 MR. : Now, I'm assuming the hot 20 MR. : Okay. 21 list is ever-changing, correct? 21 MR. : And you know that 22 MR. : Yes. Psychology always 22 lieutenants had to, but do you believe the 23 updates it. 23 officers had to sign the review of the hot 24 MR. : So, how often does the 24 list? 25 hot list have to be signed? 25 MR. : I'm not 100% sure, but I EFTA00114429 65 66 1 know, as they have, they're require to review 1 only a hot list in SHU? 2 the hot list. They should be familiar with 2 MR. : That I know of. 3 that hot list. Know who their psychological 3 MR. : Okay. So, my question, 4 inmates are, just as well as reviewing the 4 sorry, I probably was unclear, is at this time, S posted picture file. S the SHU hot list, you being the Activities 6 MR. : Okay. 6 Lieutenant, or, in this case, the Ops 7 MR. : To know who your high 7 Lieutenant on that specific date, August 9th, 8 profile and our dangerous inmates are. 8 would you have reviewed and signed that hot 9 MR. : All right. So, at that 9 list? 10 time, you being an Activities or in this case, 10 MR. : Not every day. 11 an Ops Lieutenant, would have you had to have 11 MR. : Yeah, yeah. But, like, 12 reviewed and the hot list in the SHU? 12 when it was -- 13 MR. : No, no, no. It's, I would 13 MR. : Generated, yes. 14 sign it here. Like I said, in the lieutenants 14 MR. : Right. So, point being, 15 meetings, we would go over it with Psychology. 15 like, if Epstein was on the hot list, you would 16 MR. : Sorry. I mean, the SHU 16 have signed and reviewed it? 17 hot list, is what I mean. 17 MR. : Yes. Of course. I mean, 18 MR. : No, that's the one that 18 like I said, anybody at that point in time 19 would be there. The hot list is just generated 19 should have knovm that he was going to be on 20 by Psychology. It's not like there's one for 20 the hot list. 21 SHU, one for the lieutenant's office, one for 21 MR. : Okay. 22 here. It stays in SHU, but Psychology would 22 MR. : Especially after the first 23 always make sure we familiarize ourselves with 23 suicide attempt. 24 it. 24 MR. . Okay. And do you think 25 MR. : And is it only, is there 25 anybody in the institution, with his high- 67 68 1 profile nature and the fact that he had a first 1 MR. : So, shouldn't everyone 2 suicide, suicide attempt, including these 2 have known that he was required to have a 3 people that you mentioned in the SHU, is there 3 cellmate? 4 any reason for anybody to say they didn't know 4 MR. : In that sense, yes. S that Epstein was required to have a cellmate? S MR. : All right. And 6 MR. : I don't know. 6 especially the fact that he is in the SHU, he 7 MR. : You don't know? 7 is, at the time, I think, your most high- 8 MR. : No. I mean, the people that 8 profile inmate. 9 are assigned to SHU, but the problem is, if you 9 MR. : Uh-huh. 10 look, overtime. He wasn't assigned. Overtime. 10 MR. : Do you believe that they 11 She got assigned to that post, but it probably, 11 should have known that he was required to have 12 I don't believe it was her post for the 12 a cellmate? 13 quarter. You know? I'm not, I don't, I can't 13 MR. : Yes. 14 recall 100%. 14 MR. : Okay. " stated 15 MR. : But as far as, aren't 15 Lieutenant was the SHU lieutenant. He 16 people that work in this facility, correctional 16 believed Lieutenant would have known 17 officers first? 17 Epstein required a roommate or a cellmate as it 18 MR. : Of course. Of course. 18 is a regular responsibility. He believed 19 That's the thin,. 19 Lieutenant would have enforced the 20 MR. : And if they know that the 20 roommate rule. stated he had worked 21 high-profile nature and the fact that he tried 21 the 2 p.m. to 10 p.m. shift on August 9, 2019. 22 to commit suicide, don't all officers pretty 22 He was relieved around 9:50 to 9:55 p.m. that 23 much know, if you try to commit suicide, you're 23 evening. He was not aware that Epstein did not 24 required to have a cellmate? 24 have a roommate." 25 MR. : Of course. 25 MR. : No. EFTA00114430 69 70 1 MR. : "He did not know , 1 MR. : PP, I believe it might be a 2 Epstein's former roommate, had left MCC 2 38. I don't, off the top of my head, I don't 3 leaving Epstein without a roommate. 3 remember. I know it's the quarter's, the 4 found out the following morning. He had been 4 movement roster. I haven't done it in a while. 5 workiag_25 Operations Lieutenant that evening. S MR. : Well, there's some of 6 7 I. IIIIII had been working as Activities Lieutenant. She had made the rounds." 6 7 those thiiiiiiiire going to review after -- MR. : Yeah. But I know it's a 8 All right, so on this, I'll guess we'll 8 Sentry, it's got to be entered in Sentry, and 9 just go one sentence at a time. So you didn't 9 then basically, it gets transferred over to the 10 know that day that Reyes had left the 10 lieutenant's lo'. 11 institution is what you said? 11 MR. : Okay. 12 MR. : No. No. 12 MR. : Right? At, you know, to 13 MR. : Now, is that -- 13 monitor what movement you had, just to make 14 MR. : I was unaware. 14 sure your numbers jive with the institution 15 MR. : Now, is that something 15 numbers at the end of each shift. 16 that if he, if he had left, is that something 16 MR. : Okay. So, in this case, 17 that you should have known? 17 do you believe someone should have, being that 18 MR. : No. What happens is, when 18 it was Epstein, and Epstein's cellmate, Reyes, 19 inmates go to court, and then they get released 19 left the institution? Should someone have told 20 or transferred out, they don't necessarily tell 20 you this? 21 us. Basically, what happens is then, the only 21 MR. : Should somebody have told me 22 way we're going to know anybody moved is when 22 directly? 23 we do the PP30 at the end of the night. Right? 23 MR. : Yeah, as the Ops 24 25 Just to, iiiiiiiiiwrite down who -- MR. : Is it PP30 or 38? 24 25 Lieutenant, you have Epstein, your most high- profile. He is required to have a cellmate. 71 72 1 , his cellmate, leaves the institution. 1 Belongings. That means they're not coming 2 Should someone have notified you? 2 back. 3 MR. : I would have liked to be 3 MR. : And that's pretty much -- 4 notified. 4 MR. : Most of the time, they're S MR. : So, who should have S not coming back. There are occasions where 6 7 notified iiiiiiit Reyes was -- MR. : When he departed the 6 7 they cancel the bus, or they cancel the transport or Air America, they will cancel, and 8 institution, somebody should have been 8 then they'll come back, but most of the time, 9 notified. Maybe not me, but somebody should 9 when they go WAB, that means they're going. 10 have known. 10 They're either going home or going to whatever 11 MR. : Okay. So, if he departed 11 institution the getting moved to. 12 the institution at 8:38 a.m., and he's listed 12 MR. : Right. So, in this case, 13 as pre-remove, removed off of the records, how 13 if people know that Reyes leaves at 8:30, he's 14 should have that went down? 14 moved down by the OIC from the SHU to , WAB. 15 MR. : If he was known to not come 15 What should have happened at that point? 16 back, then he should have had gotten a new 16 MR. : So, I would assume that 17 cellie. 17 during the day, on a Friday, the lieutenant, 18 MR. : Like right away? 18 the SHU lieutenant is here. 19 MR. : As soon as humanly possible. 19 MR. : So, if the SHU lieutenant 20 MR. : Okay. So, if people 20 is actually off that day, no SHU lieutenant, 21 claim that they didn't, they weren't, they 21 you got -- 22 assumed he wasn't coming back, cause he went 22 MR. : A lieutenant should have, a 23 With All Belongings. So, if someone goes With 23 SHU, a su'ervisor should have been notified. 24 25 All Beloniiiiii- MR. : WAB means With All 24 25 MR. : Okay. MR. : And been like, hey, he don't EFTA00114431 73 74 1 have a bunkie no more. 1 MR. : Uh-huh. 2 MR. : Okay. And if that -- 2 MR. : Should they have notified 3 MR. : And then it should be, you 3 the lieutenant? 4 know, then 'et him one. 4 : MR. I should have been notified. S MR. : All right. So, and if S MR. : And who should have you 6 7 the OIC, let's, for the benefit of the doubt, OIC does inform one of the lieutenants, let's 6 7 been notified MR. iii? : At least the SHU crew. They 8 say this case, it looks like Activities was 8 should have been, like, hey, this guy doesn't 9 IIIIII. And the Ops was . 9 have a cellmate. 10 R. : Uh-huh. 10 MR. : If , the former Ops 11 MR. : And no action is taken by 11 Lieutenant, knows that, at the very least, 12 them. What would be the next thing that could 12 Reyes left the institution -- 13 have happened with this, to make sure, you 13 MR. : Uh-huh. 14 know, Epstein, high-profile, doesn't have a 14 MR. : -- possibly for court. 15 cellmate. What should have, how could this 15 Maybe he doesn't know he's WAR, but he knows 16 catch up to itself? How could we rectify the 16 that he left. Should he have notified you that 17 fact that Eistein was -- 17 Reyes was -- 18 MR. : Well, that's, then, if 18 MR. : Well, if he had knowledge, 19 nobody is notified no one knows. 19 you know, that's part of taking over. You 20 MR. : Right. So, would the 20 know, the changeover. Hey, anything happen? 21 SHU, after is gone, the next, you 21 Anything I need to know? (Indiscernible 22 know, and his crew leaves and then the next SHU 22 *00:51:00 23 crew comes in, should have they, then, said, 23 MR. : In this case, Reyes, 24 hey, Reyes isn't here. We're doing our rounds. 24 knowing that, if he knew Reyes was Epstein's 25 There's nobody in there. 25 cellmate, had left the institution, should have 75 76 1 2 he notified that? MR. : I mean, if he had direct 1 2 MR. Yes. MR. : : Should she have known, 3 knowledge, possibly. Like, that's the thing. 3 Reyes is gone. Epstein is without a cellmate, 4 It was, no one knew. 4 when she did her round? S MR. : But, if he say2he knew, S MR. : If she found it. I don't 6 he knew that, well, let's say if IIIII says, 6 know, cause I wasn't there. 7 yeah, I knew Reyes left. I just wasn't certain 7 MR. : No, no, no. I'm saying, 8 he wasn't comin' back. 8 should she have, should that be, like, when she 9 MR. : That's possible. 9 is doing her round in the SHU, is that 10 MR. : But should have he 10 something that she should have recognized? 11 notified "ill, 11 MR. : If she went downrange, 12 MR. : I should have known about 12 maybe. But if she didn't go downrange, and no 13 it. Whether or not it was from or from 13 one told her, it would be the same ballpark. 14 the SHU crew, especially cause he was a hot 14 No one told her. She is, you know, it's 15 inmate. 15 unbeknownst to her. 16 MR. : Okay. So, either 16 MR. : When she went to the SHU, 17 or the SHU crew should have informed you? 17 should -- 18 MR. : Yes. 18 (knockin' on door) 19 MR. : And no one informed you? 19 MR. • -- we're in here. When 20 MR. : I wasn't informed. 20 she went into the SHU, should the OIC crew, or 21 MR. : Okay. 21 not the OIC, the SHU crew have told her, Reyes 22 23 MR. : I found out the next day. MR. : Right. What about, I 22 23 is gone, • is without a cellmate? MR. : Possibly. Yeah. I mean, a 24 know your Activities Lieutenant, you said, is 24 lieutenant is not going to know anything unless 2S the one who did the round, correct? 25 the officers relay that information to the EFTA00114432 77 78 1 lieutenant. We're not superhuman. 1 gone? 2 MR. : So, if she did her 2 MR. : To my understanding, yes. 3 rounds, and again, you said that she is the one 3 MR. : And never told you 4 who did the rounds, do you believe it was their 4 as -- S responsibility to say, hey, Activities S MR. : No. I don't recall her 6 Lieutenant, just so you know, no one is in that 6 telling me. And like I said, just knowing her, 7 cell. Reyes is gone. Just want to give you 7 and her caliber she would have told me. 8 the heads u'. Should that have happened? 8 MR. : Right. " stated 9 MR. : Yes. 9 if he had known Epstein did not have a 10 MR. : Okay. And then she would 10 roommate, he would have ensured he did." 11 have then informed you -- 11 MR. : Yes. 12 MR. : Of course, listen, she would 12 MR. : "And he knew him to be on 13 have definitely notified me. She is, for the 13 the hot list." 14 lack of better terms, and I don't mean to use 14 MR. : Yes. 15 profanity she is a shit hot lieutenant. 15 MR. . stated the 16 MR. : Okay. 16 following morning, August 10, 2019, at 17 MR. : She is on her job. 17 approximately 6:30 to 6:45 a.m., he received a 18 MR. : Yep. 18 call from Lieutenant , informing 19 MR. : She would have definitely, 19 him that Epstein had attempted suicide and he 20 if she knew, she would have let me know. 20 should go straight to the hospital, instead of 21 MR. : Okay. 21 reporting to the jail for duty." 22 MR. : And we would have fixed it. 22 MR. : Yes. That's what I did, I 23 MR. : So, whoever was working 23 went straiiiiiiiiiiekman Hospital. 24 on her, on that shift, when she visited, should 24 MR. : Okay. " stated, 25 certainly have informed her that Reyes was 25 at the hospital, the escorting staff informed 79 80 1 him that Eistein had passed away." 1 hospital." 2 MR. : Yes. 2 MR. : Yes. 3 MR. : "He saw his body and told 3 MR. : Now, were they people 4 his officers not to speak to anyone and direct 4 that escoiiiiiiistein to the hospital? S any questions to the prison public relations S MR. : That's what I believe, yeah. 6 officer." 6 They had to be, because, like I said, I was on 7 MR. : Yes. 7 my way to the hospital. I went straight to the 8 MR. : Do you know who that was 8 hospital. I believe those were the three staff 9 at the time? 9 members that they got to be the escorting 10 MR. : It's usually the Executive 10 staff. 11 Assistant so it should have been Lee Plourde. 11 MR. : Okay. Now, as far as 12 MR. : Okay. So, Lee Plourde? 12 Epstein going to the hospital, do you know when 13 MR. : Lee Plourde is the public -- 13 he actualiiiiiiideceased? 14 MR. : Yeah. "He said the same 14 MR. : I remember, my mission at 15 to the hospital security." 15 that point, Lieutenant had told me, go 16 MR. : Yes. 16 straight to the hospital, tell the officers, 17 MR. : Okay. So that was not 17 you know, keep the area secure and record time 18 people that were BOP, but the hospital -- 18 of death. I think the hospital told me it was, 19 MR. : No, yeah. There was 19 like, 7 something. I don't recall the actual 20 hospital security around the room, too, and I 20 time, and then I called Lieutenant and 21 was, like, no one goes in here unless it's 21 gave him that time, and then he was, like, all 22 hospital staff or Bureau staff. 22 right. We already got it. Bring yourself back 23 MR. : Okay. " stated 23 to the institution. 24 officers , (Phonetic Sp. *00:54:46) 24 MR. : So, do you know if, prior 25 , and were on-scene at the 25 to that time, he had skean any signs of life? EFTA00114433 1 81 MR. : No. I am unaware. No. 1 82 like they were working on him. 2 MR. : Okay. So did anyone 2 MR. : And they were still 3 mention to you or state to you, he died 3 working on him? 4 actually at the prison? 4 MR. : No, no, no. They had worked S MR. : No. S on him. 6 MR. : They just pronounced him 6 MR. Okay. 7 dead there? 7 : MR. He was already deceased, but 8 MR. : They told me they pronounced 8 he still had the intubation tube down his 9 him dead. I don't remember the actual time. 9 throat. 10 It was 7 something, which was the time of death 10 MR. : Okay. " stated he 11 that the hosiital recorded. 11 had not taken any photographs of Epstein's body 12 MR. : Okay. 12 and advised his officers to stay with the body 13 MR. : And that's what I relayed 13 until the could be relieved." 14 back to Lieutenant and then he said, all 14 MR. : Yes. 15 right, we got it already. Come to the 15 MR. • " stated, back at 16 institution. And then I left the hospital. 16 the prison, he resumed his activities as 17 MR. : Do you believe that when 17 lieutenant and was guided to collect log books 18 he was found at the BOP institution, he was 18 and escort FBI agents as part of the death 19 actually dead on scene? 19 investigation." 20 MR. : I don't, I don't know. I 20 MR. : Yes. 21 can't, I can't answer yes or no. 21 MR. : Were any OIG there at the 22 MR. : Okay. 22 time? 23 MR. : I just know, when I saw his 23 MR. : Not that I know of. There 24 body in the thing here, the intubation tube in 24 were so many agents and people coming in and 25 his neck and dorm his throat, and it looked 25 out, taking computers, I don't, I could have 83 84 1 been escorting OIG and I didn't even know. 1 MR. : All right. Great. So 2 MR. : Sure. 2 now, so, everything seemed accurate, as far as 3 MR. : Basically, Captain 3 this was written? 4 just made me go along and go and try, assist in 4 MR. : Yes. S any way I could, anytime, any documents they S MR. : Okay. Perfect. 6 needed or whatever. That's what I did. 6 MR. I just have a couple of 7 MR. : Sure. 7 follow-ups. 8 MR. : Pretty much the rest of the 8 MR. Yep. Please. Go ahead. 9 day. 9 MR. You mentioned round sheets. 10 MR. : Okay. " stated he 10 Do you recall if here, at the MCC, in the SHU, 11 was not aware of the destruction of any 11 the round sheets are kept at the end of each 12 records." 12 tier? Or are they kept on the desk? 13 MR. : No. 13 MR. : They're supposed to be kept 14 MR. ' •. stated he knew 14 at the end of each range. 15 Officer Thomas for a few years and knew Officer 15 MR. : So, as a lieutenant, at that 16 Noel as a newer officer, but had no personal 16 point, when you made your, if you had made your 17 relationshi' with either." 17 rounds -- 18 MR. : No. 18 MR. : If I have seen the sheets on 19 MR. : All right. Cool. 19 the desk, I would always tell the officers they 20 Anything that they missed or failed to capture? 20 need to be downrange, not on your desk. 21 MR. : No. I was being refreshed, 21 MR. : Okay. 22 as you were readin' it. 22 MR. : And I would not initial 23 MR. : And that's for future, is 23 them, unless they were, I wouldn't initial them 24 what I'm talking about. 24 unless the were accurate. 25 MR. : Okay. 25 MR. 'I'll': Okay. EFTA00114434 85 86 1 MR. : Uh-huh. 1 officers are doini their rounds. 2 MR. : So, on that note, then, 2 MR. : So, when did her 3 when you would go into sign that document, 3 round on August 9, 2019, should she have had to 4 would you, go downrange to grab it? 4 have gone downrange, especially on the range 5 MR. : No. There was times where I S that Epstein was on? 6 would see it on the desk and I would be, like, 6 MR. : If the round sheets were 7 these need to be downrange. 7 downrange. 8 MR. : So, you're, when you walk 8 MR. : Right. And that's where 9 into the SHU, you are supposed to walk 9 they are su osed to be? 10 downrange to do -- 10 MR. : Like they're supposed to be. 11 MR. : To sign it. 11 MR. : Okay. And if they 12 MR. : -- to sign it there? 12 weren't, she should have notified SHU. Hey, 13 MR. : Uh-huh. 13 you guys lot to be keeping these down here? 14 MR. : But oftentimes, that 14 MR. : Yes. 15 would -- 15 MR. : All right. And is the 16 MR. : As of late, as of late, that 16 purpose of that, though, to ensure that people 17 is where they are now. It all depends on what 17 are doing rounds and that's where it, when they 18 shift, because the morning watch lieutenant, 18 sign that? 19 the overnight lieutenant, has those sheets 19 MR. : Well, that's where they're 20 already sent dorm to that person. 20 supposed to be, for the sake of the officers, 21 MR. : Uh-huh. 21 that's, it's to prevent fudging the round 22 MR. : In the thing, but you still 22 sheets. 23 have to go up and sign the round sheets anyway. 23 MR. : Right. 24 Every shift, those round sheets have to be 24 MR. : You know, if they're down on 25 signed. Cause you have to ensure that the 25 the desk, and you can just write whatever you 87 88 1 want, for lack of better terms. Look, I'm 1 MR. : Nothing as far as, like, 2 (Indiscernible *00:59:40) I'll call a spade a 2 that he was hi'h-profile. You know. 3 space. Right? If somebody is going to fudge 3 MR. What was the, you mentioned 4 around, it's easier for them to do it that way. 4 instructions from Psychology, right? S MR. : Uh-huh. S MR. : Uh-huh. Which were 6 MR. : Then if it's downrange. If 6 basically the same, like, you know, he needs a 7 it's downran e ou have to go downrange. 7 bunkie. He is high-profile. 8 MR. : Right. 8 MR. : But there was no 9 MR. : So, you're going to look in 9 instructions, like you are never, as a 10 each cell and then when you get to the end of 10 lieutenant, there was no special instructions 11 that tier, that's when you scribble your time. 11 (Indiscernible *01:00:36). 12 That's why it's easier for that round sheet and 12 MR. : If he was a lieutenant move, 13 that camera to jive. 13 our instructions were a lieutenant has to be 14 MR. : Uh-huh. 14 present when he moved. So, a lieutenant has to 15 MR. : Cause they're downrange. 15 escort him that I recall. 16 MR. : Okay. Sorry. 16 MR. That email you mentioned that 17 MR. : Sorry. 17 you got. Who was that from? The mass email? 18 MR. : No, no. And the point of the 18 MR. : I believe it was from the 19 lieutenant signing it is not that the 19 Captain. 20 lieutenant did the rounds -- 20 MR. : We're going to go through 21 MR. : It's to make sure that the 21 all that. 22 officers are doing what they're supposed to be. 22 MR. : Or Correctional Services. 23 MR. : Okay. Do you recall any 23 I'm not, I'm not exactly sure who sent that 24 special instructions coming down from the 24 out. 25 Warden or the Captain, regarding Epstein? 25 MR. Okay. EFTA00114435 89 90 1 MR. : It would be generated from 1 be able to see if people were going up and down 2 all the department heads. 2 L tier, from this camera angle? 3 MR. IIIIII: Okay. That's it. That's all 3 MR. : You would be able to see a 4 I had. 4 quick movement, but not the full, cause you S MR. : Okay. But you're S can't see the ste s. 6 familiar with the SHU, correct? 6 MR. : Is there a way for them, 7 MR. : Yes. Yes. 7 over this way, to like, go over here and go up 8 MR. : (Indiscernible *01:01:15) 8 here without you seeing them come up, or is 9 all right. Great. Looking at this camera 9 this so close -- 10 angle, this is a still shot. Can you tell me 10 MR. : No, no, no. This is 11 what it is that we're looking at here? 11 totally, this is elevated. This area right 12 MR. : This is the camera that's up 12 here, this is a staircase door. 13 in, on the upper tier, by the 46 door, which is 13 MR. : Okay. 14 going into 10 South. This camera view right 14 MR. : This is an elevated 15 here is of the multipurpose area. These stairs 15 position. You can't, this camera would see 16 right here, that you can barely make out, this 16 staff comin., 17 would be tier. 17 MR. : Oh, but as far as this 18 MR. : Okay. 18 angle, though, could you, could you, if anybody 19 MR. : H tier. J, K tier down 19 was going us and down L tier -- 20 there. You can't see L and M. This little 20 MR. : And if anybody was coming 21 shadow right here is the pipe, but that's about 21 this way -- 22 all you can see of L tier. And then M tier is 22 MR. -- could you tell that 23 down thosiiiiiiiiiind that's the OIC's station. 23 from here? 24 MR. : So, from this camera 24 MR. : -- and going up, you would 25 angle, this, if Epstein is in L tier, would you 25 be able to, like I said, you would be able to 91 92 1 see a flash of movement, but you really 1 the officer's station, what is that staircase 2 wouldn't be able to see, judging from the way 2 going to? 3 this picture is, you really wouldn't be able to 3 MR. : That's going to ) tier. 4 see much of the actual step climbing. 4 MR. : Okay. Awesome. Can you, S MR. : Okay. But could anybody S on this SHU map, so this first page is the 6 get up to L tier without you seeing from this 6 first tier. 7 angle in the SHU? 7 MR. : Wait. Which, first tier? 8 MR. : Well, you would see them go 8 MR. : So, this is the, we have 9 this way. But whether or not they were walking 9 the SHU layout. It's not perfect, but this is 10 towards the kitchen or going up to L tier would 10 what was 'rovided to us. 11 be hard to distinguish, just from looking at 11 MR. : Yeah. Cause I'm trying to, 12 this. If the camera were there -- 12 all right so -- 13 MR. : So, is this a blind spot? 13 MR. : So, this is, like, for 14 Could someone come from this way and go up L 14 instance, you know, you will see the first 15 16 tier with,' seeing? MR. : Yes. Yeah. Without a 15 16 letter is what the, so this is I tier. It looks like this is M tier. And the second one, 17 doubt. 17 over here, this is the second floor, this is my 18 MR. : Okay. 18 understandin'. Here's ), L. 19 MR. : From, you could come from 19 MR. : I can barely see it. 20 straight outside and then go up. 20 MR. : Yeah. Maybe that's I. I 21 MR. : All right. And what, 21 don't know. 22 this staircase that is clearly visible, this is 22 MR. : May I? 23 the officer's station, right? 23 MR. : Absolutely. This is, so, 24 MR. : Yes. 24 what I'm going to ask you to do is, from 25 MR. : And right to the left of 25 looking at this -- EFTA00114436 93 94 1 MR. : J. Okay. There it is. 3. 1 MR. : For OIC, perfect. And 2 MR. : -- keeping in mind where 2 then, so, if you're looking straight at this, 3 the officers' station is -- 3 this is that, can you put a star next to 4 MR. : And this is L. Okay. 4 whatever, whatever staircase you're looking at S MR. : -- and where this is, can S in this video? 6 you kind of point to me, can you put the 6 MR. : Okay. This is 3 tier, right 7 location of where this camera is on here? 7 here. 8 MR. : Oh, shit. 8 MR. : 3 tier. All right. 9 MR. : Looking down? 9 MR. : J. And this is M. 10 MR. : Recreation. 10 MR. : Okay. 11 MR. : So, if you're looking at 11 MR. : I'm assuming that's the one 12 -- 12 going down. 13 MR. : It would be up here. 13 MR. : Okay. Great. And then 14 MR. : Right. So, like, the 14 as far as, this is what you're looking at, 15 angle, like, you can put a circle, and I'm 15 right here, where would you believe the camera 16 pointing towards, so I guess put a big circle 16 would be? 17 where the officers' station would be. 17 MR. : Judging from the way this 18 MR. : All right. This is 3 tier. 18 is, it looks like the camera is panning from, 19 That's right there. And there's the wall, 19 like, here. That way. 20 right there, so, right there, this is L tier, 20 MR. : Oh, right. So, if this 21 going up and M would be down, yeah. That's 21 is, this is tier -- 22 right. So this is basically where the -- 22 MR. . . 23 MR. : So then you can put OC in 23 MR. : -- right, so, would it 24 the middle. 24 be, like, kind of over here? 25 MR. : OIC. 25 MR. : Here's the, this is the 95 96 1 lieutenant's office up there. That's here, in 1 this is, thank you. And this is someone else's 2 the corner. And I think the camera is above 2 drawing. I just want to see, this kind of 3 the lieutenant's office. 3 (Indiscernible *01:06:32) this is actually what 4 MR. : Okay. 4 we said here. Yeah, so it looks like, and this S MR. : So, maybe like right here, 5 is everything. Cool. Now, was there, you 6 maybe? I'm not 100% certain. But it should 6 said, you mentioned a bulletin board that had 7 be, it's somewhere over here, the camera and 7 the hot list? Where would that be? 8 the camera •ans that way. 8 MR. : Well, I can't, right here, 9 MR. : Can you just put a star 9 it's hard to tell from that, but usually, the 10 there and in that open spot next to it, just 10 hot list should be somewhere right up there on 11 write camera? All right. Perfect. Do you 11 the hook. 12 mind just initialing and dating that? And then 12 MR. : Okay, so this is the 13 we're also -- 13 bulletin board here? 14 MR. : Eight, today is the 4th, 14 MR. : Yeah. And there's also, 15 cause it'iliiiiiiiiter's birthday. 15 now, I don't, not then, but there was, there's, 16 MR. : Oh, is it? Happy 16 there was stuff up here, but not, I don't 17 Birthday. 17 believe it was a bulletin board. It's a 18 MR. : Twenty-one. 18 bulletin board now if you go up there. 19 MR. : How old? 19 MR. : All right. 20 MR. : Twenty-one. 20 MR. : But there was, the hot list 21 MR. : Oh, wow. Can you initial 21 used to be right there. It should have been 22 and date that that we're looking -- 22 right theiiiiiiiiiire the phone was. 23 MR. : Sure. Date it, too? 23 MR. : All right. So, I'm going 24 MR. : Yes, please. All right. 24 to write above it, B board. So this is where 25 So, all right. Thank you. That confirms what 25 the bulletin board was? EFTA00114437 1 2 3 4 S 6 7 8 97 MR. : Yeah. MR. : And you believe the hot list would have been on that, is what you're saying? MR. : Yes. MR. : And this was, you said ] tier? MR. : That was, those are the 1 2 3 4 S 6 7 8 98 MR. : Yes. MR. : All right. So that's all accurate? MR. : Yep. MR. : Perfect. Okay. So, you said that this one also checked out, this looks exactly the same as where you were. Oh, do you know where ['stein was located? 9 10 steps gm.. tier. MR. : So I'm going to write ) 9 10 MR. MR. : He was on L tier. : And do you know where, 11 right here with an arrow going up. 11 like, in lookin' at this, where his -- 12 MR. : Uh-huh. And K tier would be 12 MR. : It should be right there. 13 the one goini down. 13 MR. . That one? Can you put a, 14 MR. : And is that going down 14 I don't know, a box in there, I guess, and put, 15 here? 15 yeah, JE or something there? 16 MR. : Yeah. 16 MR. : )E. 17 MR. : Or over that way? 17 MR. : Perfect. Thanks. 18 MR. : No. Down that way. There, 18 MR. : His cell could look right 19 to the left. 19 down onto the OIC desk. If he looked outside 20 MR. : Okay. But ) was going 20 his window -- 21 up? 21 MR. : So he could see? 22 MR. Yes. : 22 MR. : -- he could look right down 23 MR. : All right. And then I'm 23 at the officers. 24 going to write up here, L tier would have been 24 MR. : Okay. And you already 25 right here, going up? 25 initialed and dated this. Great. So, if 99 100 1 2 you're looking at this photo, is this a photo of L tier oin up? 1 2 to be reciiiiiiieverything going on here? MR. : That's supposed to be 3 MR. : Yep. 3 recording everything, facing this way. So, 4 MR. : And would he be over 4 like, it would see you walk, it would see, if S here? S this is me, first person, coming up this way, 6 MR. : He would be the first cell, 6 it would film everything from the grill back to 7 right, in this corner most, right here, is the 7 where it is. 8 shower. But right next to the shower is the 8 MR. : And is this where the 9 first cell. 9 round sheet is supposed to be located? 10 MR. : So if you're walking up 10 : MR. Yes. 11 the tier, you open the door, he's right to the 11 MR. : Is there, do you even see 12 right? 12 anything, where it could be? 13 MR. : He's going to be the first 13 MR. : It might be that speck 14 cell to the right. 14 right, no, that's too high. It might be, there 15 MR. : The first cell to the 15 might be a little hole, I can't tell. 16 right. Okay. And I know you can't really make 16 MR. : But that's where it's 17 out this. Do you have any reason to believe 17 supposed to be located? 18 that wouldn't be his cell? 18 MR. : Yeah. At the end of the -- 19 MR. : Well, I can't even make out 19 MR. : Right underneath the 20 the number. 20 camera? 21 MR. : Right. And then, you 21 MR. : No. I'm sorry. They had 22 know, this is the tier. This is L tier, going 22 gotten moved. I believe that right now, 23 down. Is this a camera, right here? 23 they're down there, but they might, I think 24 MR. : Yes. 24 they were on the wall here, at the beginning of 25 MR. : Is this camera supposed 25 the tier or on the other side. I'm not 100% EFTA00114438 101 102 1 certain. 1 it needed to be downrange. 2 MR. : Okay. So, back then, 2 MR. : So, even at that time, it 3 they wouldn't have been at the end of the hall? 3 was supposed to be downrange? 4 They were probably at the beginning of the 4 MR. : They always have to be S tier? S downrange. 6 MR. : I know at one point in time, 6 MR. : Okay. 7 they were, the clipboard was being rested on 7 MR. : Yes. 8 that coax ii 8 MR. : Per BOP policy? 9 MR. : Would this be underneath 9 MR. : Yes. 10 L tier, or would that be where it would be? 10 MR. : Okay. And this is just, 11 MR. : No. It's always on the 11 so, we had to review a lot of emails and I see, 12 inside of the range. 12 this one, I think, was directed to you. It 13 MR. : Always on the inside? 13 says, "BOP official legal hold notice for 14 Okay. 14 inmate's death." What was your, was your 15 MR. : Yeah. 15 understanding of that not to destroy any 16 MR. : So it would have been 16 documents? 17 after you opened the range door, but not at the 17 MR. : Yes. 18 end of the hall at that time? 18 MR. : All right. Did you 19 MR. : I know I, like I said, at 19 destroy an documents? 20 one point, they had it on the wall to the side, 20 MR. : No. Not at all. 21 but at one point in time, they were putting the 21 MR. : So you still have all 22 clipboard, they were just resting it on that 22 your emails from then and everything? 23 pipe. 23 MR. : I don't have anything. 24 MR. : Okay. 24 Like, I know the AUSA had my memo. I don't 25 MR. : As long as it was downrange, 25 even have a copy of my memo. 103 104 1 MR. Okay. 1 MR. : What do you mean? In, like, 2 MR. And I don't, I didn't tear : 2 as far as from staff? 3 up anythin'. 3 MR. : Yeah, like, for instance, 4 MR. : Perfect. 4 this is another one that, I think this is the S MR. : And I've been getting these S email that you would have received, regarding 6 periodically from iou guys. 6 Epstein being required to have a cellmate from 7 MR. : Oh, you still do? Okay. 7 July 30, 2019? 8 MR. : Yeah. 8 MR. : Oh, yeah, yeah. No, these, 9 MR. : Do you still have, like, 9 I would get them and delete them. 10 all the emails from back then and everything? 10 MR. : All right. So you would 11 MR. : No. I mean, anything that I 11 delete those? 12 had, I either just closed out of, but the thing 12 MR. : Yeah. And as long as I 13 is, I didn't, I don't even remember having any 13 knew, you know, that was it. 14 direct emails. All the official emails, like, 14 MR. : So, you didn't 15 I, like, sent them to my trash bin, like even 15 understand, like, this to mean, like, not to 16 these, I mean, this was just telling me not to 16 delete an thin to Epstein? 17 destroy anything, and I didn't destroy 17 MR. : No, but the thing is, at 18 anything. 18 least I never got anything like this, after it 19 MR. : Okay. 19 happened. 20 MR. : So, I didn't save these. 20 MR. : Yeah, yeah, yeah. I'm 21 MR. : Okay. But as far as, so, 21 talking about, like, prior to, I think that 22 did you understand, like, as far as if you 22 this is asking you to save anything that was 23 received an email pertaining to Epstein, were 23 related tiiiiiiiin, correct? 24 you supposed to save that, or could have you 24 MR. : Yeah, no. I get what that, 25 deleted that? 25 you know, that, I didn't think that that was EFTA00114439 1 2 3 4 S 6 7 8 105 what it meant. Like these. These were just routine thin's. I thought it meant -- MR. : Okay. Well, that came from yours. So, you didn't, I was able to get it, at least. MR. : Okay. MR. : You may have deleted it, but my point being is, like -- 1 2 3 4 S 6 7 8 106 MR. : Cause, like, for instance, this says, "Please preserve all electronic files; example, emails or documents." MR. : Right. I missed, I totally misunderstood. MR. : All right. So, you misunderstood that? 9 MR. : Uh-huh. Well, I 9 MR. : Yeah. 10 misunderstood, maybe. I'm thinking destroying 10 MR. : Okay. 11 means shreddin.. 11 MR. : I wouldn't do it 12 MR. : But if you received an 12 malicious) . 13 email pertaining to Epstein, you thought you 13 MR. : Yeah, yeah, yeah. No, 14 could delete it? 14 and that's what I wanted to know -- 15 MR. : Yeah. I guess so. 15 : MR. Uh-huh. 16 MR. : Right. Fair enough. 16 MR. : -- cause a lot of people 17 MR. : There's, like, stuff like 17 got this, so you're the first person I'm even 18 this, if it's sitting in my trash bin. I don't 18 asking about this. 19 always empty my trash. I mean, anybody in the 19 MR. : Uh-huh. 20 Bureau could lull those emails anyway. 20 MR. : So I was just curious, 21 MR. : Okay. Let me see how -- 21 it's like, what is your understanding. So, did 22 MR. : Yeah, I thought it meant, 22 you not know -- 23 like, physically, like, destroying stuff. 23 MR. : Yeah. I thought it meant, 24 Like, I wish I could even have a copy of my 24 actually, like, physically, like, destroying 25 memo, but AUSA has it. 25 things, like, you know, in the shredder. 107 108 1 MR. : Right. All right. So, 1 MR. : Saying that he was 2 yeah. So you didn't actually read it, I'm 2 required to have a cellmate? 3 assuming, like, where it says emails? That's 3 MR. : Have a cellmate. 4 the first thin says. 4 MR. : So you do remember that? S MR. : I probably mis, no, like, I S Okay, great. 6 remember the first one I received, I called the 6 MR. : Uh-huh. 7 staff attorney. I was, like, what does this 7 MR. : And you knew he was 8 mean? And he was like, just that you're still, 8 required to have a cellmate? 9 it's still active. 9 MR. : Yes. 10 MR. : Okay. Would you mind, 10 MR. : Do you mind just 11 just, anything we talk to you, it's just 11 initialin and dating that? 12 initialin• and dating. 12 MR. : Sure. 13 MR. : Yeah. No problem. 13 MR. Was that the same email that 14 MR. : It's just to say what it 14 you mentioned before? Cause you mentioned that 15 is what we looked at and talked about. 15 there was an email from Captain . 16 MR. : Uh-huh. 16 MR. : I believe there was one, as 17 MR. : And you already 17 far as when he, anytime he would be put as a 18 mentioned, you remember receiving this email 18 lieutenant hold. This is the one I was talking 19 from Psycholo -- 19 about, like, Psychology would send out that, 20 MR. : Yeah. 20 about havin' the cellmate. 21 MR. : from , 21 MR. : Oh. 22 . 22 MR. : Thank you, sir. Now, as 23 MR. : Yeah. Dr. . 23 far as this, you said no one told you. So 24 MR. : Yeah. 24 this is a memo from, at the time, SOS . 25 MR. : Yeah. 25 MR. : Uh-huh. EFTA00114440 109 1 MR. It 2 says, "Past information from Special Housing 3 Unit." It says, "On Friday, AuggI2s_019, at 4 approximately 1:50 p.m., I, SOS IIIIIIII, S passed on to oncoming staff member, Officer 6 andiiiiient shift staff. SOS and , that inmate was going WAB 7 Officer 8 and possibly may not return. Also that inmate 9 Epstein will be needing a cellmate upon arrival 10 from his attorney visit." Did you know 11 anything about that? 12 MR. 13 MR. : Is this the first you're 14 seeing of this memo? 15 MR. : That's the first I'm seeing 16 of it. 17 MR. : All right. So, a couple 18 things. First, if passed on to these 19 people and those are the people that worked on 20 your shift? 21 MR. : Yeah. Yes. Right here. 22 . No, wait. What does it say? No, 23 was day shift. was day shift. is the onl one. 25 MR. 24 : Okay. So, oncoming staff 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 110 members , and Officer , so let's see. When would have been working on this, like what -- MR. : 2 to 10. MR. : So, would have been 2 to 10. MR. Uh-huh. MR. : And the present ones were . When would he have been working? MR. 8 to 4. MR. And MR. : 8 to 4. MR. All right. So, I think would have only been working as -- MR. : Till 2:00. MR. : 2:00. So, if he told, before he left, 2:00, , and 7 MR. MR. Right. Should any of those people have notified either you or , that he was, that Reyes was gone and -- MR. : Yes. MR. Yes? Okay. And nobody did? 111 1 MR. : I wasn't told. Like I said, 2 I found out the day after it happened. Well, 3 the day that it ha pened, when I came in. 4 MR. : Now, on the second note S of this, if knew that Reyes was WAR, 6 should have he ensured that he got a cellmate 7 prior to his departure, at 1:50 p.m.? So, if 8 Reyes left at 8:38 a.m., WAR, into III, he's 9 keyed out of the system. Should a new cellmate 10 have been assigned to Epstein, even prior to 11 12 MR. : It would have been prudent 13 to do it as soon as possible. 14 MR. : Okay. So, should 15 have then notified any, you know, 16 , and it looks like IIIII, during his 17 shift, that, hey, we need to get Epstein a new 18 cellmate? 19 MR. : Anybody that was on that, 20 that is mentioned there, should have been, if 21 the knowledge got passed, it was never passed 22 to the lieutenants. 23 MR. : Okay. But, okay. And 24 then if the lieutenants knew, so, for instance, 25 and , if told them, hey, 112 1 Reyes is gone, should have he notified them 2 that he was WAB gone? Or, so, if he believed 3 he was at court WAB -- 4 MR. : Uh-huh. 5 MR. -- and let's say, for 6 instance, is the Ops, so he's kind of 7 like the boss, right? 8 MR. : Uh-huh. 9 MR. : If knew, yep, I 10 know Reyes is gone. I know he is Epstein's 11 cellmate. Is there any reason, and especially 12 if he went WAB is there any reason, any 13 argument for IIIII to be made that, well, I 14 didn't know if he was coming back or not? 15 MR. : If he wasn't notified that 16 he was WAILit_wcald, you wouldn't know. 17 MR. IIIIIIIIII: Okay. So, if he wasn't, 18 if he didn't know he was WAR, it is an argument 19 to be made to say, well, he could have come 20 back, is that correct? 21 MR. Yes. M 22 MR. : Okay. So, he would have 23 had to have knovm that he was