Text extracted via OCR from the original document. May contain errors from the scanning process.
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SWORN STATEMENT
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OF
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OIG CASE #:
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2019-010614
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SEPTEMBER 29, 2021
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28632 Roadside Drive, Suite 285
Agoura Hills, CA 91301
Phone: (818) 431-5800
EFTA00141893
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APPEARANCES:
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BY:
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BY:
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BY:
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WITNESS:
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NONE
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EFTA00141894
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1
MR.
: The recorder has started.
2
My name is
and I am a Senior
3
Special Agent with the U.S. Department of
4
Justice, Office of the Inspector General, New
5
York Field Office, and these are my
6
credentials.
7
MR. I.
: Okay. I see them.
8
MR.
: This interview with
9
Federal Bureau of Prisons employee,
10
, is being conducted as part of an
11
official U.S. Department of Justice, Office of
12
the Inspector General, or DOJ/OIG
13
investigation. Today's date is September 29th,
14
2021. And the time is 8:16 a.m. This
15
interview is being conducted at the OIG New
16
York Field Office, located at 1 Battery Park
17
Plaza, New York, New York. Also present is
18
DOJ/OIG ASAC, or Assistant Special Agent-in-
19
Charge,
. He is in person. And
20
Special Agent
is joining us by
21
telephone. He is also with the DOJ/OIG. This
22
interview will be recorded by me, Senior
23
Special Agent
. Could
24
everyone please identify themselves for the
25
record, and spell their last name? To start,
EFTA00141895
1
again, I am DOJ/OIG Senior Special Agent
2
3
MR.
: I am Assistant Special Agent-
4
in-Charge
5
MR. I.
6
Electronics tech. Bureau of Prisons.
7
8
MR. I.
: This is Special Agent
9
10
MR.
: All right. Thank you.
11
This is an official DOJ/OIG investigation into
12
the death of inmate Jeffrey Epstein, and the
13
surrounding circumstances, and you are being
14
asked to voluntarily provide answers to our
15
questions. Will you agree to a voluntary
16
interview with the DOJ/OIG?
17
MR. I.
: Yes.
18
MR.
: Thank you, sir. So, this
19
is the official Warnings and Assurances to
20
Employees Requested to Provide Information on a
21
Voluntary Basis. And in this line, I'm going
22
to say, this investigation pertains to,
23
it's job performance failure and security
24
failure, correct?
25
MR. I.
: Yes.
EFTA00141896
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1
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8
9
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MR.
: Job performance failure.
All right. So, it says, United States
Department of Justice, Office of the Inspector
General, Warnings and Assurances to Employees
Requested to Provide Information on a Voluntary
Basis. "You are being asked to provide
information as part of an investigation being
conducted by the Office of the Inspector
General. This investigation is being conducted
pursuant to
as amended.
performance
the Inspector General Act of 1978,
This investigation pertains to job
failure and security failure. This
is a voluntary interview.
Accordingly, you do not have to answer
questions. No disciplinary action will be
taken against you if you choose not to answer
questions. Any statement you furnish may be
used as evidence in any future criminal
proceedings, or agency disciplinary
proceedings, or both." And there is a waiver
section. And it says, "I understand the
Warnings and Assurances stated above and I an.
willing to make a statement and answer
questions. No promises or threats have been
made to me, and no pressure or coercion of any
EFTA00141897
1
kind has been used against me."
2
So, take a look. If you understand it,
3
and are agreeing, and are willing to continue,
4
can you just please sign where it says employee
5
signature? Thank you very much for signing.
6
DO you understand the form?
7
MR. I.
: Mm-hmm. Yes, I do.
8
MR.
: Okay. Do you understand
9
this is a voluntary interview?
10
MR. I.
: Yes.
11
MR.
: Perfect. Thank you.
12
Okay. Today's date, again, is September 29th.
13
So, I'm writing 09/29/21. The place is OIG,
14
NYFO. And the time is 8:19 a.m. And I am
15
signing my name as the Special Agent. ASAC
16
, can you sign as a witness, please?
17
MR.
: Mm-hmm.
18
MR.
: Thank you, sir.
19
MR.
: Thank you.
20
MR.
: All right. Before
21
starting the interview, I would like to place
22
you under oath. Mr.
, can you please
23
raise your right hand? Do you swear to tell
24
the truth and nothing but the truth --
25
MR. I.
: Yes.
EFTA00141898
7
1
MR.
: -- during this interview?
2
MR. I.
: Yes.
3
MR.
: Thank you, sir. Again,
4
it's a voluntary interview, if you don't
5
understand any of my questions, please ask me
6
to rephrase.
7
MR. I.
: Yeah.
8
MR.
: Or ask for any
9
clarification. I would be happy to provide it.
10
Were you previously interviewed by the OIG at
11
the MCC on July 15th, 2021?
12
MR. I.
: Yes.
13
MR.
: Great. And that was by
14
me and Special Agent
Correct?
15
MR. I.
: Yes.
16
MR.
: Great. Is it correct
17
that the MCC camera -. Or sorry. Before I go
18
on that, are you still at the MCC?
19
MR. I.
:
Yes, I am.
20
MR.
: Are you still the
21
electronics technician?
22
MR. I.
:
Yes, I am.
23
MR.
: Great. Has anything
24
changed since we spoke on July 15th, 2021?
25
MR. I.
:
No.
EFTA00141899
1
MR.
: No. Great. Is it
2
correct that the MCC cameras were not working
3
properly in August 2019?
4
MR. I.
: Yeah. Well, the recorders
5
wasn't working. The cameras were working. The
6
recorders weren't working.
7
MR.
: So, the live feed was
8
working, but the recordings were not.
9
MR. I.
: Yes.
10
MR.
: Correct. When did you
11
first learn that the MCC cameras were not
12
working properly?
13
MR. I.
: That day. This was, I
14
believe, that day. Towards the end of my
15
shift. I'm not sure what time.
16
MR.
: So, you still think it
17
was August 9th, 2019, that you learned?
18
MR. I.
: Yes.
19
MR.
: After giving it some
20
thought, do you think maybe it happened the day
21
before, on August 8th, 2019?
22
MR. I.
: I don't know if I spoke to
23
somebody. I don't know why it would be the
24
8th.
25
MR.
: All right. When we go
EFTA00141900
9
1
over the reports, we will see if that can help
2
freshen, you know, help you recall. First,
3
we're just going to ask you some questions for,
4
like, you know, so you can, from memory, recall
5
exactly --
6
MR. I.
: What happened.
7
MR.
: -- when it was, and then
8
we will go over the reports, and see if that
9
helps jog anything. But to your recollection,
10
it was on August 9th, 2019?
11
MR. I.
: Yes.
12
MR.
: And what is --
13
MR. I.
: It was that Friday.
14
MR.
: -- what is it that makes
15
you think that it was on that Friday?
16
MR. I.
: Because that's when I went
17
to the room. That's the only thing I really
18
remember. Because it was a lot of hours after
19
that.
20
MR.
: Okay.
21
MR. I.
:
That day.
22
MR.
:
So, it was just
23
MR. I.
:
Yeah.
24
MR.
: -- it was a lot of things
25
going on.
EFTA00141901
10
1
MR. I.
: Yeah. There was a lot of
2
things going on. But I remember the 9th
3
because everything happened the next day.
4
MR.
: Okay.
5
MR. I.
: On Saturday.
6
MR.
: And are you aware, now,
7
after the fact, that the cameras stopped
8
recording on July 29th, 2019?
9
MR. I.
: No.
10
MR.
: So, you're not aware of
11
that?
12
MR. I.
: No. Nobody. It's the
13
first time somebody has told me that.
14
MR.
: Okay. So, by reviewing
15
the recording system, or anything like that,
16
you didn't learn that they stopped on July
17
29th?
18
MR. I.
: No. The recorders were
19
still working. Because the recorders were
20
still working for the building. All the -.
21
Not all the cameras were working, but some of
22
the recorders were working. (Indiscernible
23
*00:06:26).
24
MR.
: So, when we spoke last
25
time, you explained to us that on, like, August
EFTA00141902
11
1
9th, is when you first noticed it, and that
2
half of the cameras, or --
3
MR. I.
: Half of them was on --
4
MR.
: -- half the cameras on --
5
MR. I.
:
DVR-1.
6
MR.
:
DVR-1, and half were
7
on DVR-2.
8
MR. I.
:
DVR-2.
9
MR.
: And one of the, one of
10
those DVRs, which included half of the cameras
11
12
MR. I.
: Cameras.
13
MR.
: -- they stopped --
14
MR. I.
:
Yeah. Stopped working.
15
MR.
: -- working.
16
MR. I.
:
Yeah.
17
MR.
:
So, what is your
18
knowledge or recollection of when those half of
19
cameras -?
20
MR. I.
: I don't know when those
21
half the cameras stopped working?
22
MR.
:
So, when you were trying
23
to obtain video after the fact, you never
24
learned, like, when they're --
25
MR. I.
:
This is the first time
EFTA00141903
12
1
MR.
: -- the last video?
2
MR. I.
: -- yeah, this is the first
3
time I heard that, was July.
4
MR.
: Okay.
5
MR. I.
: Yeah.
6
MR.
:
So, when is the first
7
time you found out, then, that the recordings
8
were, in fact, not working?
9
MR. I.
:
When I went to go try to
10
fix it on that Friday.
11
MR.
: Okay. On the 9th?
12
MR. I.
:
Yeah.
13
MR.
: Okay. But on the 9th,
14
did you -. I thought you had told us you
15
couldn't gain access to it on the 9th. So,
16
when did you actually gain access to the room,
17
to be able to --
18
MR. I.
: I went up there --
19
MR.
: -- determine -?
20
MR. I.
: -- in the afternoon, to go
21
do work. They said I couldn't stay because III
22
had to leave, so the video room.
23
MR.
: Okay.
24
MR. I.
: Yeah.
25
MR.
So, III had to leave, so
EFTA00141904
13
1
you couldn't stay to do the work?
2
MR. I.
: Yeah. I couldn't stay to
3
do the work, because I don't have a key, I
4
don't have access to the room. Because it's
5
the property room.
6
MR.
: And when you say "they,"
7
who was it that told you this?
8
MR. I.
: I was talking to Officer
9
III. But it's no
Everybody knows that SIS,
10
that's their room, and I don't have access to
11
go in the room. At the time, I didn't have
12
access to fix the recorders.
13
MR.
: Okay. Did you ever talk
14
to a lieutenant
15
MR. I.
: That day?
16
MR.
: Any day, about these
17
recordings.
18
MR. I.
: Yeah. I've talked to
19
people numerous times about me getting access
20
to the room, that I should have access to the
21
room.
22
MR.
: No, I'm talking about,
23
like, on August 8th or August 9th, about the
24
cameras. Do you recall having a conversation -
25
EFTA00141905
1
MR. I.
: I don't recall.
2
MR.
: -- with lieutenant
3
4
MR. I.
:
No.
5
MR.
:
No. Or AW
? The
6
Associate Warden.
7
MR. I.
: I don't remember.
8
MR.
:
No. Okay. So, you don't
9
remember learning that, on July 29th, 2019, the
10
cameras stopped recording?
11
MR. I.
: This is the first time
12
MR.
:
From (Indiscernible
13
*00:08:19).
14
MR. I.
:
I heard it.
15
MR.
: That's the very first
16
time you heard?
17
MR. I.
:
That it was July. Yeah.
18
MR.
: Okay.
19
MR. I.
: Because that's, like, two
20
weeks out, I wouldn't - not know it was
21
recording for two weeks. That doesn't make any
22
sense.
23
MR.
: Okay. So, you don't
24
think that that would be accurate?
25
MR. I.
:
No.
EFTA00141906
15
1
MR.
: All right. Do you know
2
what stopped them from recording?
3
MR. I.
: I just know that the
4
system was old, and it had a lot of problems.
5
MR.
: Okay. Do you know if
6
someone did, like, an improper shutdown, or
7
that power surge created it to shut off?
8
MR. I.
: They were on UPSs, and no
9
power surge that would have created it. It
10
would have just been mechanical.
11
MR.
: Okay.
12
MR. I.
: Or, yeah, yeah.
13
MR.
: Just from age?
14
MR. I.
: Just from age, and wear
15
and tear. Yes.
16
MR.
: Okay. And again, on
17
August 8th, you don't recall ever having
18
conversations with anybody regarding these
19
cameras, or first learning on August 8th that
20
the cameras went down?
21
MR. I.
: August 8th? The day
22
before? I don't really recall (Indiscernible
23
*00:09:09).
24
MR.
: And you don't recall
25
having the conversation with SIS Lieutenant
EFTA00141907
1
and AW
about the cameras not
2
recording on August 8th, 2019? On Thursday?
3
MR. I.
: No. I don't recall.
4
MR.
: You don't. Do you
5
remember them, towards the end of your shift,
6
bringing you in the office because they
7
couldn't get the recordings to rewind, and
8
asked you to fix the problem?
9
MR. I.
: On the 8th?
10
MR.
: On the 8th.
11
MR. I.
: Hmm. I don't recall that.
12
No.
13
MR.
: Do you remember having -
14
at any time - a conversation prior to Epstein's
15
death, with lieutenant, with SIS Lieutenant
16
and AN
17
MR. I.
: Together? At the same
18
time? No. I don't recall it. Yeah.
19
MR.
: What about separately?
20
MR. I.
: Separately, probably. We
21
probably talked about it. But not together.
22
At the same time.
23
MR.
: Well, do you recall the
24
conversations that you had, then, prior to
25
Epstein dying on the - or being found - on the
EFTA00141908
17
1
10th. What conversations did you have with
2
each of those individuals?
3
MR. I.
: Right. I was just busy
4
working. On the 10th, the day it happened, or
5
-?
6
MR.
: No. Prior to the 10th.
7
So, the 8th, the 9th, or anywhere back to the
8
July 29th, really.
9
MR. I.
: Oh. That we were working
10
on the problem, trying to figure out what was
11
causing it, and that's when I ordered new hard
12
drives to replace all the drives. That was my
13
next step. That's what I was going to do that
14
day. But I couldn't.
15
MR.
: And what made you do
16
that, though? Who told you to replace the hard
17
drives?
18
MR. I.
: Talking through SigNet,
19
and the former com tech,
, he's the
20
computer services manager and we talked about
21
buying hard drives. I actually got a purchase
22
order, too. Yeah.
23
MR.
: So, who was the computer
24
service manager?
25
MR. I.
EFTA00141909
18
1
MR.
: Can you spell the first
2
and last name?
3
MR. I.
. And
4
5
MR.
: And did you say
6
7
MR. I.
• III Yes. That's an
8
•
Yeah.
9
MR.
, or -?
10
MR. I.
Yeah. III
11
MR.
:
So, no E?
12
MR. I.
No I.
13
MR.
: Okay.
14
MR. I.
: And that's all.
15
MR.
: And that was the CSM?
16
MR. I.
: Yup.
17
I'm sorry. And it's an ■
Not an
At the
18
end.
19
MR.
: All right. So,
20
-M?
21
MR. I.
: Yes.
22
MR.
: Okay. Great. And who
23
was that person?
24
MR. I.
: He was the previous com
25
tech before I got there, and now, he was - at
EFTA00141910
1
that present time - he was the computer
2
services manager.
3
MR.
: He was?
4
MR. I.
: Yes.
5
MR.
: Okay. So, he was
6
actually working at the MCC?
7
MR. I.
: Yes.
8
MR.
: And he was your boss?
9
MR. I.
: No. It's just, I talked
10
to him about computer stuff, because he knows a
11
little bit more than I do. That's his
12
specialty.
13
MR.
: Okay. What was his kind
14
of, like, job role at the time?
15
MR. I.
: His job role was to take
16
care of the computers. Infrastructure of the
17
building.
18
MR.
: Okay.
19
MR.
: Yeah.
20
MR.
: And what was the
21
conversation you had with him, and where?
22
MR. I.
: I think, that's when we
23
were talking about actually just replacing all
24
of the hard drives because they keep failing
25
all the time. So, the next step was to replace
EFTA00141911
1
all the hard drives.
2
MR.
: And do you remember when
3
you had that conversation?
4
MR. I.
: A few days before this
5
happened. And we've had numerous conversations
6
about this for weeks because - and probably
7
months - because of the way the hard drives
8
kept failing. The drives would, the recorders
9
would stop working.
10
MR.
: So, did you know, then, a
11
few days before this? I'm assuming, when you
12
say "this," August 9th, 2019, that the hard
13
drives had failed?
14
MR. I.
: I knew it was a
15
possibility they failed. At the time, or the
16
before I left, I knew everything was working.
17
MR.
: Before you left when?
18
MR. I.
: I'm not too sure, but I'm
19
just saying, like, overall, as far as, like, as
20
far as everything recording, because I've
21
checked the recorders. It looked like
22
everything was recording.
23
MR.
: What day are you speaking
24
about, though?
25
MR. I.
: Oh, specifically, before
EFTA00141912
1
the incident happened, on the 9th.
2
MR.
:
So, on the 9th,
3
everything was recording?
4
MR. I.
: Well, when I checked it,
5
of course it wasn't recording. That's why I
6
went up there to check.
7
MR.
:
It was not?
8
MR. I.
: It was not recording.
9
MR.
: Okay. So, when is the
10
first time you found out that it was not
11
recording?
12
MR. I.
: Oh. I guess the 9th.
13
Everybody keep saying the 8th, but I don't
14
really remember the 8th.
15
MR.
: Okay. So, the 9th, and
16
is that when you --
17
MR. I.
: Because I -.
18
MR.
: -- are saying you had the
19
conversation with
20
MR. I.
: Yes. Well, I had the
21
conversation before, with
about what I
22
was going to do next.
23
MR.
: Okay.
24
MR. I.
: Because it happened
25
before, so the next step was just to replace
EFTA00141913
1
all the hard drives.
2
MR.
:
Like, it happened long
3
before, or when are you talking about --
4
MR. I.
: It happened --
5
MR.
: -- it happened?
6
MR. I.
: -- multiple times before,
7
where the recorders would stop working.
8
MR.
: Okay.
9
MR. I.
: Yes.
10
MR.
:
So, you were trying to
11
preemptively stop that from happening?
12
MR. I.
: Happening again, yes.
13
MR.
: Okay. So --
14
MR. I.
: So -.
15
MR.
: -- you didn't talk to
16
him based upon the system stopping recording.
17
You were talking about it --
18
MR. I.
: Mm-hmm.
19
MR.
: -- doing preventative
20
maintenance?
21
MR. I.
: Maintenance. Yes.
22
MR.
:
Is that correct?
23
MR. I.
: Yes.
24
MR.
: Okay.
But you don't
25
remember exactly when you spoke with him?
EFTA00141914
23
1
MR. I.
: No. Some time around that
2
time, because I have to get the purchase, I
3
have to get the parts to make the repairs, or
4
change the drives out.
5
MR.
: All right. So, until we
6
go over this, I'm going to run through these,
7
just so we keep on track. But it sounds like
8
I'm going to have to show you these documents,
9
to help maybe clarify some things.
10
MR. I.
: Mm-hmm.
11
MR.
: Do you know, did you know
12
that the recorders - that the cameras weren't
13
recording prior to August 9th, 2019?
14
MR. I.
: Yeah. I know there was
15
failures in the system. Yes.
16
MR.
: So, you knew that they
17
were not recording?
18
MR. I.
: Not that day. But I know
19
that, overall, there was going to be system
20
failures.
21
MR.
: And did you know that it
22
was half of them, all on DVR-1 or 2?
23
MR. I.
: I wasn't too sure what it
24
was.
25
MR.
: Okay.
EFTA00141915
1
MR. I.
: But I know there was
2
failure. I didn't check to see exactly where
3
they were.
4
MR.
: So, you knew there was a
5
failure with the system, prior to August 9th.
6
You just didn't know what the failure was?
7
MR. I.
: Yes.
8
MR.
: And how did you know
9
that?
10
MR. I.
: Well, I would have to go
11
check if there was video, there was no recorder
12
videos, live videos, but there was no recorder
13
video.
14
MR.
: So, you personally had
15
checked to see if there were recorded video?
16
MR. I.
: Yes.
17
MR.
: And when did you do that?
18
MR. I.
: I had, well, I had checked
19
that day, before I had to go upstairs to look
20
at everything.
21
MR.
: August 9th?
22
MR. I.
: August 9th. Yes.
23
MR.
: So, that's where I'm
24
saying. So, when you say, prior to the time,
25
you're talking about the same day, August 9th,
EFTA00141916
1
is when you checked the --
2
MR. I.
: Checked the recording.
3
MR.
: -- the recording.
4
MR. I.
: Yeah.
5
MR.
: Prior to August 9th, did
6
you check the recording to see if it was
7
recording?
8
MR. I.
: Multiple times before.
9
Yes.
10
MR.
: And were they recorded?
11
MR. I.
: From what I believe, yes.
12
I'm not too sure.
13
MR.
: Okay. Would you check
14
that system to check on the recordings, every
15
day?
16
MR. I.
: No. There was nothing
17
that says I have to check it.
18
MR.
: Sure.
19
MR. I.
: The thing with the
20
recorders is, I'm not really supposed to, like,
21
mess with the system. I just, I'm maintenance.
22
I'm not really supposed to, like, oh, today,
23
SIS, that's their job to tell me, hey,
24
there is no video, or something, there is
25
problem.
EFTA00141917
26
1
MR.
:
So, how did you know that
2
the recording wasn't being able to rewind, and
3
check recording? Why were you in there
4
checking that?
5
MR. I.
: I just, I guess I spoke to
6
somebody, or maybe I checked it. I'm not too
7
sure.
8
MR.
: But it would have been
9
based upon someone requesting you to do so?
10
MR. I.
: Yes.
11
MR.
: And you believe that
12
happened on the 9th?
13
MR. I.
: Yes.
14
MR.
: Okay.
15
MR.
:
And just, and the call
16
dropped. Let me get
back on.
17
MR.
:
Absolutely.
18
MR. I.
: Agent
19
MR.
:
Hey,
. You hear us fine
20
now?
21
MR. I.
:
Yes. I apologize.
22
don't know why the call dropped.
23
MR. I.
: Mm-hmm.
24
MR.
: Okay.
25
MR.
: All right. So, we were
EFTA00141918
27
1
just talking about the recording and how Mr.
2
would not go in and review a recording
3
without someone requesting him to do so. He
4
doesn't recall specifically who made that
5
request for him to review the recording, but he
6
believes that he reviewed the recording on the
7
9th, and that's when he determined that it
8
wasn't recording properly. Is that correct?
9
MR. I.
: Yes.
10
MR.
: All right. And you - and
11
again - you don't remember why you were
12
reviewing that recording?
13
MR. I.
: No. Because we're in the
14
middle of a
Well, no, this -. Before
15
Epstein happened, we were in the middle of a
16
camera project, we had people TDY. So, I was,
17
like, the lead in the building, trying to tell
18
everybody what needs to get done. And I think
19
the day before, I was on 10 South, I was
20
putting in a rack or something, so I was busy
21
that day, and I had a TDY guy on me.
22
MR.
: And when you - on the
23
8th?
24
MR. I.
: Yeah.
25
MR.
: You got a TDY guy with
EFTA00141919
1
you.
2
MR. I.
: Yeah.
3
MR.
: And who was that TDY guy?
4
With you?
5
MR. I.
His last name was
6
, and I don't remember his first name.
7
He was an electrician.
8
MR.
: An electrician. Do you
9
know which facility he came from?
10
MR. I.
:
No. I'm not too sure.
11
MR.
:
You don't know the first
12
name?
13
MR. I.
: I forgot his first name.
14
We just call everybody by their last name.
15
MR.
: But he's not from MCC?
16
MR. I.
: No. He's not in from MCC.
17
MR.
: After the interview, can
18
you just see if you can identify who that
19
person is, and then send me an email?
20
MR. I.
: Okay.
21
MR.
: Of the person's name.
22
But the August 8th, 2019, you believe this --
23
MR. I.
: Yeah.
24
MR.
: -- this TDY employee,
25
, was with you?
EFTA00141920
29
1
MR. I.
: Yeah. He was with me. We
2
were together all day because we were doing the
3
piping, and trying to put the rack in.
4
MR.
: And what is a rack?
5
MR. I.
: Where the -. Well, for
6
the new camera system, that's where the power
7
supply, the switch would go, the camera feed,
8
the cat five cables would go. Everything will
9
go on the rack.
10
MR.
: So, it had to do with the
11
camera system?
12
MR. I.
: The upgrading the new
13
camera system. Yes.
14
MR.
: Is that anything that
15
could have possibly caused the cameras to stop
16
recording?
17
MR. I.
: No. That's -. Nothing
18
was hooked up. It was just the hardware.
19
There was no wiring or nothing.
20
MR.
: Okay. So, that could not
21
have affected the camera?
22
MR. I.
: The cameras? No.
23
MR.
: All right. And do you
24
remember, prior to August 9th, checking on the
25
camera system, though, to make sure it was
EFTA00141921
1
recording?
2
MR. I.
: Yes. After we had the
3
problem, yes.
4
MR.
: No, no, no. Prior to the
5
9th.
6
MR. I.
: Yes. Prior to the 9th.
7
MR.
: And when did you check
8
on, prior, like, how many days before? Do you
9
remember?
10
MR. I.
: I don't really remember.
11
MR.
: Are you talking about,
12
like, a few days leading up, a day leading up,
13
or are you talking about, like, a month or two?
14
MR. I.
: Maybe, like, weeks. Not
15
months. It wouldn't have been a month.
16
MR.
: Like, a few weeks?
17
MR. I.
: Yeah, because I had to
18
order the parts. I don't know when I ordered
19
the parts. But I had to know that they weren't
20
working.
21
MR.
: But I thought you just
22
said that they were working, and you only
23
ordered them as preventative maintenance?
24
MR. I.
: Well, I - yeah -. Well,
25
they weren't working before. So, I had to
EFTA00141922
31
1
rebuild one of the drives. I had to change one
2
of the drives out.
3
MR.
: Okay.
4
MR. I.
: That's when I went to say,
5
let me order a whole bunch of drives, to
6
replace all the drives together, at once.
7
MR.
: And are you able to
8
determine when you made that order?
9
MR. I.
: Yes. We have a purchase
10
order. Yes.
11
MR.
: All right. So, those two
12
things so far. Can you give me the name of
13
, and the second thing is the purchase
14
order, with regard to --
15
MR. I.
: Yeah.
16
MR.
: -- when you made that
17
order --
18
MR. I.
: Yeah.
19
MR.
: -- for the new drives?
20
MR. I.
: Mm-hmm.
21
MR.
: I'll send you an email
22
after this.
23
MR. I.
: Okay.
24
MR.
: Just kind of reminding
25
you of what it is we're hoping to get. And
EFTA00141923
1
there, but again, you ordered that because
2
there was a problem with the --
3
MR. I.
: Recorders.
4
MR.
: -- with the recorders --
5
MR. I.
: Yes.
6
MR.
: -- you fixed that
7
problem.
8
MR. I.
: Temporarily. But I knew
9
it was going to happen again. And the best
10
thing to do was replace all the drives.
11
MR.
: Okay. So, you knew that
12
it would stop recording again?
13
MR. I.
: I knew there was going to
14
be a problem again. Yes.
15
MR.
: Okay. And what made you
16
know that
17
MR. I.
: Talking to the vendor, and
18
talking to
, and the age of the unit,
19
because it was, like, 15 years old. And the
20
fact that it's on 365, 24 days, and on 24 hours
21
a day, like, it just constantly goes on. And
22
then, when you try to do maintenance, something
23
as simple as changing the time, the recording
24
would stop for, like, a whole day, day and a
25
half. Because for the drives rebuilding, you
EFTA00141924
1
have to change the time.
2
MR.
: Okay.
3
MR. I.
: And before all of this
4
happened, I actually put in a camera project.
5
That's why I was in the middle of a camera
6
project, to replace everything.
7
MR.
: Now, when you say that
8
the people you spoke to, you mentioned
9
and then, you said the customer service people
10
11
MR. I.
: Yeah. SigNet.
12
MR.
: -- Signet.
13
MR. I.
: Yeah. Mainly Justin
14
Houston, and I would talk to him.
15
MR.
: Justin Houston was your
16
main point of contact?
17
MR. I.
: Yes.
18
MR.
: What about a Jeff
19
McKenzie? Would you recall -?
20
MR. I.
: Jeff was the one that came
21
after Epstein. That's the guy that showed up
22
when we had to put in the new drives. Because
23
we ordered the new -. We ordered the new
24
recorders. But everything was downstairs in
25
the basement. And we weren't really a priority
EFTA00141925
34
1
on the list until, of course, Epstein happened.
2
That's when SigNet came the next day, and put
3
the new recorders in.
4
MR.
: Okay. So, prior to
5
August 10th, 2019, your main point of contact
6
was SigNet, with Jeff Houston?
7
MR. I.
: Justin.
8
MR.
: I mean, Justin.
9
MR. I.
: Justin Houston. Yes.
10
MR.
: And what was his role and
11
responsibility with SigNet?
12
MR. I.
: He is just, like, the guy
13
we will call if there is a problem, or if
14
training, or if I don't know the system.
15
Because, like, this system, I never had
16
training on it. So, like, when I saw it,
17
because the last institution I was, was, like,
18
maybe two versions ahead of this one. So, when
19
I saw this recording, I was, like, this stuff
20
is old, like, I don't know anything about it.
21
Like, what should I do? So, I called Justin,
22
and Justin, like, pretty much would walk me
23
through trouble shooting, if there is a
24
problem.
25
MR.
: And what was the system
EFTA00141926
1
again?
2
MR. I.
: Raid (Phonetic Sp.
3
*00:21:08).
4
MR.
:
Nice Pro, or something
5
like that?
6
MR. I.
: I don't -. I know it was
7
a raid system. A raid array. I remember
8
that's what he kept saying. Raid array.
9
MR.
: Okay.
10
MR. I.
: It was raid.
11
MR.
: And do you know what that
12
means? Raid array?
13
MR. I.
:
Just the way the drives
14
would go. So, if, the way he explained that to
15
me, if one drive would go bad, that's not so
16
bad. But as soon as two drives go bad, that's
17
when all the recordings pretty much stops.
18
MR.
:
So --
19
MR. I.
: Because it was a redundant
20
system.
21
MR.
: -- okay. So, when one
22
drive goes bad, does any, do any recordings
23
stop?
24
MR. I.
:
No. It will keep
25
recording.
EFTA00141927
36
1
MR.
:
So, it will automatically
2
shift over to the other drive?
3
MR. I.
: To the other slot. Yo-
4
MR.
: Okay.
5
MR. I.
: And then, when two drives
6
go bad, that's when all the recordings stop.
7
MR.
:
So, what is the
8
difference between ours, where is one -. Is
9
what you're talking about a DVR-1 and a DVR-2?
10
MR. I.
:
No. That's the drive in
11
the DVRs, because there's 16 drives. That's
12
what - I think - that's what it was. So, out
13
of the 16 like, in DVR-1, if one goes bad,
14
that's not a problem. As soon as the second
15
drive goes bad, then that's when you have a
16
problem. And that's when the recording would
17
stop.
18
MR.
: Okay. So, what is your
19
understanding of what happened here?
20
MR. I.
: Oh. The drive went bad.
21
MR.
: One of them?
22
MR. I.
:
Two of them. Yeah.
23
MR.
: Two of them
24
MR. I.
: I believe.
25
MR.
: -- did go bad?
EFTA00141928
37
1
MR. I.
: Yes. Because that's why -
2
3
MR.
: And is it two of 16, or
4
is it two out of two?
5
MR. I.
:
Two out of 16.
6
MR.
:
So, if two out of 16 go
7
bad --
8
MR. I.
: Go bad.
9
MR.
: -- then --
10
MR. I.
: Mm-hmm.
11
MR.
they all.
12
MR. I.
: The recordings stop. Yes.
13
MR.
:
For all of them?
14
MR. I.
: Yes.
15
MR.
: Okay.
16
MR. I.
: On that drive. All the
17
recording stops.
18
MR.
: And the DVR-1 and DVR-2,
19
that's simply the recording system?
20
MR. I.
: Yes.
21
MR.
: That's not the, anything
22
to do with the -. The drives are what's making
23
24
MR. I.
: Mm Hmm.
25
MR.
: -- the recording, but
EFTA00141929
1
they're saving it to DVR-1
2
MR. I.
: Yes.
3
MR.
: -- and DVR-2.
4
MR. I.
: Yes.
5
MR.
:
So, what is the
6
difference between if a DVR-1 goes bad, but not
7
DVR-2? Is that just -?
8
MR. I.
: The physical location over
9
it. Because everything on the old system was
10
analog. So, like, cameras one through whatever
11
are on this drive, on DVR-1, and our other
12
cameras are on DVR-2.
13
MR.
:
So, does each DVR have 16
14
drives?
15
MR. I.
: Yes.
16
MR.
: All right. So --
17
MR. I.
: So -.
18
MR.
:
DVR-1 has 16 drives.
19
DVR-2 has 16 drives.
20
MR. I.
: Yes.
21
MR.
: And either DVR-1 or DV:<-
22
2, two of those drives went bad?
23
MR. I.
:
Yes.
24
MR.
: And stopped that DVR-2
25
from recording.
EFTA00141930
1
MR. I.
: From recording. Yes.
2
MR.
: But the drives on DVR-1
3
were all good?
4
MR. I.
: All good. Yes.
5
MR.
: Okay.
6
MR. I.
: And another thing I've
7
learned also, through my time, is that SigNet
8
replied to me this, you could look at the
9
camera software, until you physically look at
10
the drives, you would think that everything is
11
recording. That's something we went over
12
recently.
13
MR.
: Well, what about a -. I
14
was told that there was an application that you
15
would have, that was called Supervision.
16
MR. I.
: Yeah. I don't look at
17
Supervision.
18
MR.
: You don't.
19
MR. I.
: You can. I have access to
20
look at it, but I didn't get trained on it, so
21
I don't really look at Supervision. I would
22
just go in the regular Nice Vision, and look at
23
it that way.
24
MR.
: Yeah. We were told that,
25
in order to determine if there were problems
EFTA00141931
1
with the drives
2
MR. I.
: The drives. You would
3
have to --
4
MR.
: -- that's through --
5
MR. I.
: -- yes.
6
MR.
: -- yeah, you go into
7
Supervision, and that would, in fact, tell you?
8
MR. I.
: And which, I have no
9
training on.
10
MR.
:
So, you've never --
11
MR. I.
: Obviously.
12
MR.
: -- looked at that?
13
MR. I.
:
No.
14
MR.
:
Did anyone else have
15
health --
16
MR. I.
: At the time, no.
17
MR.
: -- did anyone else have
18
access?
19
MR. I.
:
No.
20
MR.
:
So, you were the only
21
person with access to Supervision?
22
MR. I.
: Yes. Pretty much. Yes.
23
MR.
: All right.
And do you
24
know if someone accessed the application
25
Supervision, they could have taken the drives
EFTA00141932
1
offline, or the recordings offline?
2
MR. I.
: Hmm, yeah. But yeah,
3
nobody would have that access.
4
MR.
: Would they be able to do
5
it from there, though?
6
MR. I.
: Yes. They probably would,
7
yes.
8
MR.
: But you are confident no
9
one had access to it?
10
MR. I.
: No.
11
MR.
: Okay. So, you would be
12
the one and only person with access to
13
Supervision?
14
MR. I.
: Yes.
15
MR.
: And there is no, like, if
16
you're not there, somebody else has
17
MR. I.
: There is nobody --
18
MR.
: -- a way to --
19
MR. I.
: -- there is nobody. Yeah.
20
MR.
: -- how would they do
21
that? From SigNet? To get access again.
22
MR. I.
: Oh, no. They would just
23
have to know the password, to log in.
24
MR.
: Well, that's what I mean.
25
So, if you ended up not being able to show up,
EFTA00141933
42
1
or you left, or something like that, how would
2
someone gain access to that?
3
MR. I.
: That's something they
4
would have to try to figure out, but yeah. I
5
don't -.
6
MR.
: But to your knowledge,
7
you're the only person that had the password to
8
access Supervision?
9
MR. I.
: Yes.
10
MR.
: Okay. And SigNet
11
wouldn't be able to remote in?
12
MR. I.
: No. They have no access
13
to remote in. That's BOP. They don't want
14
them to be able to backdoor remote into
15
anything.
16
MR.
: Okay. And when did you -
17
18
MR. I.
: Oh. Well, they -. The
19
old system, they were able to, if you had a 56K
20
(Phonetic Sp. *00:25:06) modem, they were able
21
to do maintenance, and tell me, like, the
22
status of the drives. But I would have to
23
physically hook up 56k modem. But at the time,
24
that wasn't hooked up. Because we did some
25
repairs before, when I was trying to figure
EFTA00141934
43
1
stuff out, and I couldn't figure it out, where
2
they would - through a modem - they would
3
remote into the -. Well, I would have to grant
4
them access to look at the drives, to help with
5
the drives.
6
MR.
: So, how --
7
MR.
: And we've done that
8
before. Yes.
9
MR.
: -- so, you had to grant
10
them access. They couldn't go in there --
11
MR. I.
: No
12
MR.
: -- without your
13
MR.
: Physically. And
14
physically, you have to put a cable in.
15
MR.
: Okay.
16
MR.
: Yeah.
17
MR.
: So, you are the one and
18
only person with access, remotely, that could
19
have accessed those servers?
20
MR. I.
: Yes.
21
MR.
: Okay. And do you
22
remember the last time you would have accessed
23
that application?
24
MR.
: I have no idea.
25
MR.
: No? Would it have been
EFTA00141935
1
leading up to August 9th, 2019?
2
MR. I.
: Probably. Yeah.
3
MR.
: And do you know around
4
how long before that?
5
MR. I.
: No.
6
MR.
: Is there a way to
7
determine? Do they have, like, some thing that
8
you can see when your last log ons were, or
9
anything like that?
10
MR. I.
: You could call computer
11
services, then they could tell you my
12
keystrokes or whatever, whatever I logged into.
13
But that's, like, the only time. Yeah.
14
MR.
: Okay.
15
MR. I.
: But there is really
16
nothing to say when I logged in.
17
MR.
: But to your recollection,
18
you were not accessing Supervision at all?
19
MR. I.
: Hmm. I mean, they showed
20
me how to do some stuff on it, but I don't
21
really even think I remembered how to - at tnat
22
time - I don't really remember.
23
MR.
: But the point being, in
24
this case, you didn't find out the recordings
25
had stopped because of that application,
EFTA00141936
1
Supervision. Correct?
2
MR. I.
: I don't believe so. No.
3
MR.
: Okay. And you did not
4
take the cameras, or recordings, offline from
5
Supervision. Correct?
6
MR. I.
: No. I can't. Yeah. No.
7
I've never been able to do that. So, no.
8
MR.
: So, you don't even -.
9
Sorry. I thought you told me before you could
10
do it. DO you think --
11
MR. I.
: You have access to do it,
12
yes, if you are in Supervision. Yeah. There
13
is stuff you can do on Supervision to stop the
14
recordings. Yes.
15
MR.
: Now, if you weren't
16
really familiar with the application, is it
17
possible that you were in there, and you
18
accidentally knocked them offline?
19
MR. I.
: No.
20
MR.
: Okay.
21
MR. I.
: I wouldn't knock anything
22
offline.
23
MR.
: No. You don't believe
24
so?
25
MR. I.
: No.
EFTA00141937
46
1
MR.
: Okay. And what would be
2
a reason for you to go into the application,
3
Supervision?
4
MR. I.
: Just to see what was going
5
on, who's logging on, or just to, if something
6
looks funky to me, or just doesn't feel right,
7
to see what was going on.
8
MR.
: Okay.
9
MR. I.
: Yeah.
10
MR.
: And do you have any
11
examples, prior to August 9th, 2019, when you
12
would have done that?
13
MR. I.
: I know there was one time,
14
like, when they remoted in, they were showing
15
me stuff on the drives. And I was talking to
16
SigNet over the phone, and they were showing me
17
how to fix the drives before.
18
MR.
: Okay.
19
MR. I.
: But other than that, like,
20
I don't really remember me using Supervision
21
that much.
22
MR.
: And that would have been,
23
they would have had a log of when that
24
happened?
25
MR. I.
: Yeah. Supervision has a -
EFTA00141938
47
1
Every time you log into Supervision, you see
2
a username and who logged in. That's always
3
kept on Supervision.
4
MR.
: Okay. And do you have
5
access to that now, to be able to --
6
MR. I.
: Yes.
7
MR.
: -- determine?
8
MR. I.
: Yes.
9
MR.
:
So, it shows that
10
MR. I.
: Well, that --
11
MR.
: -- it shows -.
12
MR. I.
: -- well, whatever system
13
you have, you can log into it, and see what you
14
have on it, in Supervision.
15
MR.
: And when you logged in,
16
and when you logged out?
17
MR. I.
: Yeah.
18
MR.
:
So, would you still have
19
the ability now, to go back to see when you
20
logged in and logged out?
21
MR.
:
For the old system, no.
22
MR.
:
No? Not for the old
23
system.
24
MR. I.
: Old system, no.
25
MR.
: Okay. But SigNet would
EFTA00141939
1
probably have a call log of you --
2
MR. I.
: Of who's on.
3
MR.
: -- talking with them?
4
MR. I.
: Yes.
5
MR.
: Going over --
6
MR. I.
: Supervision.
7
MR.
: -- Supervision?
8
MR. I.
: -- yes.
9
MR.
: All right. So, SigNet
10
should be able to provide us something, with
11
regard to
12
MR. I.
: Supervision. Yes.
13
MR.
: -- when they had you in
14
there.
15
MR. I.
: Yeah.
16
MR.
:
And do you think that you
17
went in there, though, aside from them showing
18
you?
19
MR. I.
: Maybe to check some stuff
20
out. But not really.
21
MR.
: Okay. All right. So,
22
again, August 9th is the first time you think
23
that you knew that the cameras weren't
24
recording.
25
MR. I.
: Mm-hmm.
EFTA00141940
49
1
MR.
: If we were to tell you
2
that the cameras actually stopped the recording
3
on July 29th, 2019, you said that's news to
4
you?
5
MR. I.
: Yes. That's kind of a
6
long time for me not to notice that the cameras
7
That's, like, a week and a half.
8
MR.
: Something like that.
9
MR. I.
: Yeah.
10
MR.
: Yeah.
11
MR. I.
: For me not to notice that
12
they stopped recording.
13
MR.
: So
14
MR. I.
: But I could see where, if
15
I didn't do it, because we were busy with a
16
project, maybe I didn't check it. But that's
17
kind of hard. And for SIS, or nobody to tell
18
me, like, hey, the cameras weren't recording,
19
or we've tried to pull video and it wasn't
20
working. That's kind of weird, too.
21
MR.
: All right. All right.
22
So, since you don't remember these, we're going
23
to start going into --
24
MR. I.
: Sure.
25
MR.
: -- some of these -.
EFTA00141941
50
1
just, again, because I assumed you were going
2
to remember this stuff, I'm going to cover
3
these questions to make sure that I don't miss
4
anything.
5
MR. I.
: Mm-hmm.
6
MR.
: And then, we will have
7
to, maybe, refresh with some of them. So, did
8
Lieutenant
, Associate Warden
, or
9
Captain
tell you to fix the cameras on
10
August 9th, 2019? On August 8th --
11
MR. I.
: 8th.
12
MR.
: -- or 9th, 2019.
13
MR. I.
: Yes. The 8th or 9th.
14
Yes.
15
MR.
: Okay.
16
MR. I.
: Somebody did tell me about
17
the drives.
18
MR.
: And who was it that told
19
you?
20
MR. I.
: I think it was SIS.
21
Somebody in SIS. It might have been
22
But I'm pretty sure it's somebody from SIS that
23
told me, hey, the cameras stopped working. Or
24
here, there is a problem.
25
MR.
: And can you just recall
EFTA00141942
51
1
that conversation, of what they told you, and
2
what happened, and where it was?
3
MR. I.
: It's pretty simple. Like,
4
hey,
, the camera is not working, this
5
and that, it's not really elaborate.
Like, I
6
just go and do my thing.
7
MR.
: And did they tell you,
8
fix it immediately?
9
MR. I.
:
No.
10
MR.
:
Did they tell you that
11
they were informing the captain?
12
MR. I.
:
No.
13
MR.
: And you don't recall AW
14
being involved?
15
MR. I.
: Pfft. This is news to me,
16
she doesn't really get involved, as far as I
17
know.
18
MR.
:
Well -.
19
MR. I.
: I mean, after the fact,
20
everybody is involved, but
21
MR.
:
So, the information we
22
have is Lieutenant
and AW
were
23
attempting to review video on August 8th --
24
MR. I.
: Oh, okay. 2019.
25
MR.
:
2019.
EFTA00141943
52
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
MR.
at video
MR.
MR. I.
MR.
at video. So,
MR. I.
: Okay. They were looking
: And --
: -- for some reason.
: -- and they were looking
they called you.
: Okay.
MR.
: And had you come up. And
had you determine what was going on.
MR. I.
: Okay.
MR.
: Lieutenant
said,
on August 8th, she said, make sure that you get
this thing fixed.
MR. I.
: Mm-hmm.
MR.
: She, then, she said she
didn't work on August 9th, and the schedule for
August 9th reflects that.
MR. I.
: Okay. So, if that
happened, I'm not saying this happened, but if
it that did happen, I probably noticed that the
drive went back and probably was trying to
rebuild the drive. But I'm not sure if that's
exactly -. Honestly, I don't remember the day
before what happened.
MR.
: And that's what I'm
EFTA00141944
1
trying to, you know
2
MR. I.
: Mm-hmm.
3
MR.
: -- refresh your
4
recollection. So, on August 8th, 2019, she
5
said it happened some time before 2:00 p.m.,
6
that's when she spoke to you about this.
7
MR. I.
: So, I would have went in
8
there.
9
MR.
: And she said -.
10
MR. I.
: And if I was upstairs, I
11
would have went right in the room.
12
MR.
: And she - yeah - she said
13
that --
14
MR. I.
: But I don't remember.
15
MR.
: -- she was under the
16
understanding that, on August 8th, you were
17
fixing it.
18
MR. I.
: Yeah.
19
MR.
: She said, she didn't work
20
on August 9th, and she hadn't planned on
21
working on August 10th --
22
MR. I.
: Mm-hmm.
23
MR.
: -- but she got called in.
24
MR. I.
: Mm-hmm.
25
MR.
: On August 10th --
EFTA00141945
1
MR. I.
: August 10th.
2
MR.
: -- because of what --
3
MR. I.
: Yeah. Epstein.
4
MR.
: -- happened with Epstein.
5
MR. I.
: Yes.
6
MR.
:
She said, when she saw
7
you on August 10th, she had learned that the
8
camera system wasn't fixed --
9
MR. I.
: Yeah.
10
MR.
: -- and they weren't
11
recording.
12
MR. I.
: Yeah.
13
MR.
: And she said,
, why
14
didn't this get fixed? And your response to
15
her was, I came in today to do that.
16
MR. I.
: Yeah.
17
MR.
:
Does that all help you
18
MR. I.
: Yes.
19
MR.
: -- recollect what's going
20
on?
21
MR. I.
: Yes.
22
MR.
:
Does that sound accurate?
23
MR. I.
: It sounds accurate, but -.
24
So, if something happened on the 8th, I don't
25
think I would wait until the 9th to fix it.
EFTA00141946
55
1
So, if it did happen on the 8th, I don't really
2
remember the 8th. I remember the 9th more
3
specifically. But it did happen on the 8th. I
4
would have went to the room, and just replaced
5
the drives, because that's the only thing I
6
would do.
7
MR.
: All right. I'm going to
8
skip ahead and do, I'm going to read you - and
9
I'll continue on with this - I'm going to
10
MR. I.
: Yeah.
11
MR.
: -- read you the FBI
12
interview report from when you --
13
MR. I.
: Mm-hmm.
14
MR.
: -- do you remember, you
15
said that you were interviewed by the FBI?
16
MR. I.
: Yes. I was.
17
MR.
: All right. So, this says
18
you were interviewed by the FBI on March 12th,
19
2020. Is that correct?
20
MR. I.
: Yes.
21
MR.
: All right. So, I'm going
22
to just read, I'll just read the whole thing,
23
so that we're not missing anything. It says,
24
"On March 12, 2020,
," it says
25
your date of birth and telephone number, "was
EFTA00141947
1
interviewed by Assistant United States
2
Attorney,
(Phonetic Sp.
3
*00:32:42), Task Force Officer Detective
4
(Phonetic Sp. *00:32:45), and
5
Special Agent
, at the United
6
States Attorney's Office, Southern District of
7
New York, 1 St. Andrew Plaza, New York, New
8
York. During the interview,
provided
9
the following details." Does that all sound
10
correct so far?
11
MR. I.
: Yes.
12
MR.
: And we're just going to
13
stop after each paragraph, to have you --
14
MR. I.
: Mm-hmm.
15
MR.
: -- to check in with you.
16
started working for the Bureau of
17
Prisons in 2003, and worked in both New York
18
and Indiana.
had some college
19
education, was in the United States Marine
20
Corps for four years, and had ten years'
21
experience in electronics." Correct?
22
MR. I.
: Yes.
23
MR.
"In 2016,
was put
24
in charge of all the cameras at the
25
Metropolitan Correctional Center (MCC).
EFTA00141948
57
1
advised that the cameras at MCC were out of
2
date. The recorders frequently went bad, and
3
the cameras were all analog, and not maintained
4
properly."
5
MR. I.
: Yes.
6
MR.
: "The camera system was
7
over 20 years old. Sometimes, the screen would
8
be active, indicating that the camera was
9
working. However, the video would not be
10
recording."
11
MR. I.
: Yes.
12
MR. -:
advised that only
13
one hard drive of the camera system was
14
working, at the time of the incident, on August
15
10th, 2019. When a DVR went bad, none of the
16
cameras recorded. There was a system failure
17
of DVR-2 on July 29th, 2019, and the
18
motherboard failed on DVR-2 on August 8th,
19
2019. The hard drive failure occurred on
20
August 10th, 2019." Is that something that you
21
provided to them?
22
MR. I.
: Yeah. I probably did.
23
Yes.
24
MR.
: So, can you just explain
25
to me what we're talking about here, because it
EFTA00141949
1
says -?
2
MR. I.
:
That was -.
3
MR.
: It says, specifically,
4
there was a system failure --
5
MR. I.
: Yes.
6
MR.
: -- of DVR-2, on July 29th
7
8
MR. I.
: 29th.
9
MR.
: -- 2019.
10
MR. I.
:
That was a month before.
11
Well, yeah.
12
MR.
: That's that week and a
13
half.
14
MR. I.
(Indiscernible *00:34:34).
15
MR.
: That's the July 29th,
16
2019 --
17
MR. I.
: Yes.
18
MR.
: -- that we were talking
19
about. So, what would have happened with the
20
system failure?
21
MR. I.
:
That's when I had to
22
replace the motherboard on the DVR-2.
23
MR.
: And what does that mean?
24
MR. I.
:
DVR-2 was really old, and
25
SigNet didn't have the parts to replace it, so
EFTA00141950
59
1
I had to call with Justin, I contacted another
2
BOP facility, and then, I took the computer
3
apart, and he just pretty much replaced the
4
motherboard, and got the DVR-2 to start
5
working.
6
MR.
: On the 29th?
7
MR. I.
: If that's what it says,
8
yes.
9
MR.
: Well, it just says -. It
10
doesn't say when you got it to stop working.
11
It just says there was a system failure of DVR-
12
2 on July 29th, 2019.
13
MR. I.
: I believe they probably
14
spoke to Signet then. I'm not too sure with
15
the dates because everything is
I've been
16
super busy. The dates, I'm not really good
17
with.
18
MR.
: Okay. But on July 29th,
19
2019, with the system failure, would have that
20
stopped the recordings?
21
MR. I.
: Yes. A system failure
22
would have stopped the recordings.
23
MR.
: Okay. And is it your
24
understanding that, after July 29th, the
25
recordings were working?
EFTA00141951
1
MR. I.
: Yes.
2
MR.
: All right.
3
MR. I.
: Because he would have
4
logged into Nice Vision, and he would have seen
5
things was working.
6
MR.
: But I thought you said
7
that --
8
MR. I.
: And that's, well --
9
MR.
: -- you'll only see if it
10
was working, if it was live feed. I thought
11
you said you wouldn't see recording.
12
MR. I.
: No. If you log into the
13
Nice Vision, with the live feed, you would
14
think everything is still recording because
15
everything looks green. It's when you try to
16
play back the video and, like, oh, wow, there's
17
nothing being recorded. That's when you would
18
know there is a problem.
19
MR.
: Okay. So --
20
MR. I.
: So, if somebody has
21
MR.
the way you check --
22
MR. I.
: -- to pull the video.
23
Yeah.
24
MR.
: -- like, the way you
25
checked was to try to rewind video?
EFTA00141952
61
1
MR. I.
: Yeah. That's the only way
2
you could check it, is try to pull video from
3
the days prior.
4
MR.
: All right. So, you are
5
aware, though, on July 29th, 2019, it stopped
6
recording, but your understanding was that you
7
got it to work again?
8
MR. I.
: Yes. Everything started
9
working again.
10
MR.
: All right. And do you
11
know if you checked on it for say, let's say
12
the 30th of July, or -?
13
MR. I.
: I was in the middle of a
14
project, so I can't say I was just focused on
15
that, because there was a lot going on.
16
MR.
: So, you only recall that
17
you would have checked on the 29th?
18
MR. I.
: Yeah.
19
MR.
: Of July.
20
MR. I.
: Yeah. I don't think I
21
would have had reason to check, unless somebody
22
told me it wasn't working.
23
MR.
: Okay. And it says, "And
24
the motherboard failed on DVR-2, on August 8th,
25
2019." What does that mean?
EFTA00141953
62
1
MR. I.
: So, the motherboard,
2
that's the one I had to get replaced on August
3
8th, 2019.
4
MR.
: Right. So, this says
5
August 8th. And you've been saying that you
6
first learned on August 9th. So, where does
7
this come into play? How do we know that the
8
motherboard failed on DVR-2 on August 8th,
9
2019?
10
MR. I.
: August 8th. That's the
11
motherboard I wrote, I must have replaced.
12
Because I remember replacing a motherboard.
13
MR.
: And what does a
14
motherboard do? What is that?
15
MR. I.
: When did this happen?
16
Everything happened on the Epstein, that was --
17
MR.
: Epstein was the 10t .
18
MR. I.
:
10th.
19
MR.
: And just to help --
20
MR. I.
: So, that's --
21
MR.
: -- so, just so we're not
22
running in circles --
23
MR. I.
: -- yeah, that -.
24
MR.
: -- let me just read you
25
the SigNet service call, as well.
EFTA00141954
1
MR. I.
: Yeah.
2
MR.
: So, this is the SigNet
3
service request, number 24975.
4
MR. I.
: Mm-hmm. Mm-hmm.
5
MR.
: It says, assigned to Jeff
6
Cranor --
7
MR. I.
: Mm-hmm.
8
MR.
: -- Jeff McKenzie
9
MR. I.
: Mm-hmm. (Indiscernible
10
*00:37:33).
11
MR.
: -- and Justin Houston.
12
Date created, August 8th, 2019.
13
MR. I.
: Okay.
14
MR.
: And then, if we go down
15
and we look at the, well, we'll read the
16
comment section.
17
MR. I.
: Okay.
18
MR.
: So, there is a comment by
19
Jeff McKenzie on August 8th, 2019, at 3:38 p.m.
20
It says, "Hi, Jeff. Unable to locate anything
21
official.
The basic steps are as follows.
22
One, set the raid level to none and save. It
23
will restart it with all drives being J.
24
Replace any faulty drives. Two, set the raid
25
level to five, and save. It will restart and
EFTA00141955
64
1
being an initialization." And obviously, these
2
words seem to be wrong. I'm sure
3
MR. I.
: Mm-hmm.
4
MR.
: -- it's supposed to say,
5
it will restart and begin initialization.
6
MR. I.
: Mm-hmm.
7
MR.
:
It talks about the
8
password. And it talks about different
9
directions to go forward --
10
MR. I.
: Mm-hmm.
11
MR.
: -- with. And then, there
12
is a comment by Jeff McKenzie on August 14,
13
2019, at 8:02 p.m. This says, "
14
called us on Thursday, August 8th, stating that
15
he had two bad drives on his raid unit."
16
MR. I.
: Mm-hmm.
17
MR.
: "Of the Nice Vision Pro
18
Unit NVR. We advised him to get replacement
19
drives."
20
MR. I.
: Mm-hmm.
21
MR.
: Once they are replaced,
22
they should start to
23
MR. I.
: Initialize.
24
MR. -:
-- initialize
25
MR. I.
: Yes.
EFTA00141956
65
1
MR.
: -- to become available
2
for the raid array.
did not have
3
drives readily available."
4
MR. I.
: Mm-hmm.
5
MR.
: "He checked with his
6
local CSM," which again --
7
MR. I.
: Mm-hmm.
8
MR.
: -- you said was --
9
MR. I.
10
MR.
: -- okay. "To see if they
11
had any spare replacement drives. Once he
12
located replacement drives on Friday, August
13
9th, he did not have access to the DVR room to
14
replace them. He called SigNet for phone
15
support, on Saturday, August 10th --
16
MR. I.
: Mm-hmm.
17
MR.
: -- when he gained access
18
to the DVR room.
19
MR. I.
: Mm-hmm.
20
MR.
"He attempted to replace
21
the drives, and they started to rebuild.
22
During the rebuild process of the drives, the
23
drives were required to be taken out of the
24
raid on DVR-2."
25
MR. I.
: Yeah.
EFTA00141957
1
MR.
: "Once the drives are
2
removed without proper shutdown of the
3
recorder, the video database becomes corrupted.
4
Typically, any time the raid on a raid five
5
configuration loses two drives
6
MR. I.
: Mm-hmm.
7
MR.
the raid needs to be
8
rebuilt, and all data is wiped from the raid."
9
MR. I.
: Mm-hmm. Mm-hmm.
10
MR.
: Do you want to just
11
review that yourself?
12
MR. I.
: Uh-huh.
13
MR.
: So that I'm not just
14
reading it to you, and tell me if that sounds
15
accurate to you.
16
MR. I.
: Yes. That sounds a little
17
bit better, like, what happened.
18
MR.
: So, is this now
19
refreshing your recollection that, actually, on
20
August 8th, is when you found out?
21
MR. I.
: Yes. Okay. It was the
22
8th,
23
MR.
: It was the 8th?
24
MR. I.
: The 8th. Yes.
25
MR.
: All right. And it was
EFTA00141958
1
the 8th that someone told you that the
2
recorders --
3
MR.
: (Indiscernible *00:40:04),
4
and I probably went to go look at the room.
5
Yes.
And then, I probably went back the next
6
day, on the 9th, because the Thursday, when he
7
told me to put the drives in, I probably went
8
to put the drives in, and replace them. And
9
then, Friday, is when I'm stopped to see if the
10
drives finished that rebuilding.
11
MR.
: I'm sorry. Can you
12
repeat this again? What happened?
13
MR. I.
: Okay. Okay. Now, it's
14
making more sense.
15
MR.
: So, on the 8th, was it
16
can you recall - was it Lieutenant
that
17
told -?
18
MR.
: Somebody told me what was
19
going on, on the 8th.
20
MR.
: At the time, was there
21
only two SIS people working there, Lieutenant
22
, and SIS Tech
23
MR. I.
24
MR.
: -- is it -?
25
MR. I.
EFTA00141959
1
2
3
4
MR.
MR. I.
MR. •
Yes.
:
Were they -? I think
they were the only two --
5
MR. I.
:
Two working.
6
MR.
: -- at the time.
7
MR. I.
: Yes.
8
MR.
:
So, would it have been
9
one of the two of them?
10
MR. I.
:
Two of them. Yes.
11
MR.
: Okay. And they told you
12
that the recording --
13
MR.
: Recorders went bad.
14
MR.
: -- was -.
15
MR. I.
: Yes.
16
MR.
: Okay. So -.
17
MR. I.
: And then, and that's
18
probably when I called SigNet, okay, two
19
drives, two bad drives. So, I probably got the
20
drives. I started to rebuild it. And then,
21
the next day, that's when I checked.
22
MR.
: But it sounds like, from
23
this, you didn't have the drives on the 8th.
24
Is that correct?
25
MR. I.
: I probably - because there
EFTA00141960
69
1
was spare drives on the room - so, I probably
2
started to rebuild on the 8th. I'm not too
3
sure. Honestly.
4
MR.
: All right. Well, this is
5
really important for us to get you to try to
6
remember.
7
MR. I.
: I know.
8
MR.
: Because this is, like, a
9
big piece of this, the fact that the cameras
10
were down when Epstein
11
MR. I.
: Yeah, I know, but I --
12
MR.
-- and -.
13
MR. I.
:
I was doing, like, a
14
million things, and I've been doing a million
15
things after, like --
16
MR.
:
Sure.
17
MR. I.
: -- this happened.
18
MR.
:
So, on the 8th, you
19
actually believe that, from reading this --
20
MR. I.
: This. Yes.
21
MR.
: -- you believe that you
22
actually did try to rebuild on the 8th --
23
MR. I.
: Yes.
24
MR.
: -- and not on the 10th?
25
MR. I.
:
Not on the 10th. Yes.
EFTA00141961
70
1
MR.
: All right. Because that
2
way that it reads, I thought was that, you
3
didn't have them on the 8th. On the 9th, you
4
didn't have access, "And then, on the 10th,
5
when he gained access to the DVR room, he
6
attempted to replace the drives, and they
7
started to rebuild." That's how this reads.
8
MR. I.
: That sounds about
That
9
sounds right. Yeah.
10
MR.
: So, now you're thinking,
11
you actually did it on the 10th, and not the
12
8th?
13
MR. I.
: Yeah, I know I replaced
14
the drives on the 10th, because that's when
15
they told me, like, not to do it, and it got
16
crazy.
17
MR.
: All right. So, now
18
you're thinking that actually you didn't do
19
anything on the 8th.
20
MR. I.
: Hmm. I probably know
21
about those drives being bad, and I went to go
22
get drives.
23
MR.
: So --
24
MR. I.
: Yes.
25
MR.
: -- so, on the 8th, you
EFTA00141962
1
went to look for drives?
2
MR. I.
: Yes.
3
MR.
:
Do you think you located
4
them on the 8th?
5
MR. I.
: Hmm. I came back the next
6
day, and that's when I replaced them.
7
MR.
:
Well, the next day was
8
the 9th --
9
MR. I.
:
The 9th.
10
MR.
: -- and it says that you
11
didn't have access to --
12
MR. I.
:
Just to replace
13
MR.
: -- replace.
14
MR. I.
: -- yeah, I can't go in the
15
room.
16
MR.
:
So then, it sounds like,
17
so, you didn't do anything on the 8th --
18
MR. I.
: Or the 9th.
19
MR.
: -- or the 9th.
20
MR. I.
: Mm-hmm.
21
MR.
:
You obtained the
22
hardware, but then, on the 10th --
23
MR. I.
:
That's when I got access
24
to the room.
25
MR.
: -- and previously, what
EFTA00141963
72
1
you told us that, is that you found out on the
2
9th, and then on the 10th, you didn't have
3
access to the room, so on the 10th, you did
4
overtime so that you could do it then.
5
MR. I.
: I was going to be doing
6
overtime anyway. So, I was going to be there
7
regardless.
8
MR.
: You were going to be
9
there on the 10th, regardless?
10
MR.
: Yeah, because we had TDY
11
people there.
12
MR.
: Okay. So, you were going
13
to be working on the 10th, overtime, regardless
14
of this camera issue?
15
MR.
: Yeah. Regardless. I was
16
Because this had nothing to do with my
17
overtime. I was doing a project.
18
MR.
: All right. Because we
19
talked in pretty detail, in July, when
20
and I spoke with you about, like, how someone
21
approved your overtime to work on the 10th,
22
specifically to work on this camera issue.
23
MR. 1.
: No. This was not for
24
that.
25
MR.
: And you --
EFTA00141964
1
MR. I.
:
No. And that's --
2
MR.
: -- and then, you went on
3
where, like, on, in detail about --
4
MR. I.
:
No. That's --
5
MR.
: -- like, who would have
6
approved it --
7
MR. I.
:
No. What --
8
MR.
: -- would it have been
9
? Would it have been one of the AWs?
10
The captain?
11
MR. I.
: I don't know who approved
12
it, but we were already working on the camera
13
project. So, that's what I was doing.
14
MR.
: Okay.
15
MR. I.
: I was already --
16
MR.
:
So, you weren't --
17
MR. I.
: -- this had nothing to do
18
with anything.
19
MR.
: -- so, you weren't there
20
on --
21
MR. I.
: So, specifically, to just
22
deal with this. And if I said, okay, I'll deal
23
with it tomorrow, I probably, said, okay, I
24
don't have time today, I could deal with it
25
first thing in the morning tomorrow.
EFTA00141965
74
1
MR.
: Okay. So, if you didn't
2
deal with it on the 9th, because you couldn't
3
gain access to --
4
MR. I.
: Yes.
5
MR.
: -- the SIS room?
6
MR. I.
: Yeah.
7
MR.
:
How were you going to get
8
access to the SIS room --
9
MR. I.
: Somebody was there
10
MR.
: -- (Indiscernible
11
*00:43:42).
12
MR. I.
: -- on Saturday.
13
MR.
:
Now, someone is always
14
there from SIS on Saturday?
15
MR. I.
:
Not always, but there was
16
going to be somebody there on Saturday --
17
MR.
: Okay.
18
MR. I.
: -- because I think I asked
19
III if he was going to be there Saturday.
20
MR.
: All right. And III --
21
MR. I.
: And there was -.
22
MR.
: -- wasn't actually an SIS
23
employee, correct?
24
MR. I.
: Yes. He was an SIS. He
25
was just in the video room.
EFTA00141966
1
MR.
: He was a telephone
2
monitor --
3
MR. I.
: Monitor.
4
MR.
: -- guy.
5
MR. I.
: Yes.
6
MR.
: But he didn't actually
7
work for SIS. Correct?
8
MR. I.
: No. But there would have
9
been a reason why I said I'm coming back
10
tomorrow because somebody would have been in
11
the office tomorrow for me to get access.
12
MR.
: So, you believe either
13
or one of the SIS
So, III could gain
14
access without an SIS employee letting him in?
15
MR. I.
: He has the key for the
16
room.
17
MR.
: He did?
18
MR. I.
: Yes.
19
MR.
: All right. So, you
20
believe III, then, was going to be there on
21
Saturday, and he was going to grant you access?
22
MR. I.
: Somebody was going to be
23
there to grant me access.
24
MR.
: And previously, when you
25
said that III was
You said III was there on
EFTA00141967
1
the 9th, or he was there on the 8th?
2
MR. I.
: That's his main post.
3
So, he is always, like, there.
4
MR.
: So, he is always in the
5
SIS room?
6
MR.
: So, for the week, yeah.
7
That's what he's -. He's just in the room.
8
MR.
: Okay.
. As in,
9
10
MR. I.
: Yes. I have a couple of
11
questions.
12
MR.
: Oh, yeah. But what I --
13
MR. I.
(Indiscernible *00:44:50).
14
MR. -:
-- was going to ask is
15
if, can you check the roster for the 10th, and
16
see if III was scheduled, or America
, or
17
SIS Lieutenant
18
MR. I.
: Okay. Hold on a minute.
19
MR. I.
: Yeah. (Indiscernible
20
*00:45:01).
21
MR.
III is listed for August
22
10th. At 7:00 a.m. to 3:00 p.m. on OSP number
23
one.
24
MR.
: Oh. Is that OSP number
25
one, is that the -?
EFTA00141968
77
1
MR. I.
: No. That's OSP-1. That's
2
outside perimeter. But he still had, would
3
have the key. So, he probably would have given
4
me access to the room.
5
MR.
: And do you believe that
6
you actually spoke with him about any of this?
7
MR. I.
: Yeah. We spoke about it,
8
like --
9
MR.
: Prior to the 10th?
10
MR. I.
: -- yeah.
11
MR.
: When would have you
12
spoken with him?
13
MR. I.
: When I went in the room,
14
like, because he was leaving for the day, he
15
was, like, well, you can't have access. I'll
16
be back tomorrow. And then, I would have came
17
18
MR.
: Well, and what day did he
19
tell you that? On the 8th or the 9th?
20
MR. I.
: That was that Friday.
21
MR.
: So, the 9th?
22
MR. I.
: Yeah.
23
MR.
: All right. Can you just
24
check, was III in on that Friday?
25
MR. I.
: Yeah. Let me -. I don't
EFTA00141969
1
see his name on the first couple of pages.
2
However, you want to go through the rest.
3
MR.
: All right. So, again,
4
the way that this reads is
5
MR. I.
: I think you said, M. III?
6
MR.
: Excuse me?
7
MR. I.
: M. III is listed for phone
8
monitor.
9
MR.
So,
is there?
10
MR. I.
: Yeah. It looks like he
11
was assigned to phone monitor.
12
MR.
: All right. And phone
13
monitor would have been in the SIS room?
14
MR. I.
: Yes.
15
MR.
: All right. And --
16
MR. I.
: In the SIS room.
17
MR.
: -- and how do they
18
MR. I.
(Indiscernible *00:47:43).
19
MR.
: -- is that
20
MR. I.
: It's
21
MR.
: Okay. Great. All right.
22
So, he would have been the phone monitor. So,
23
your understanding, then, is on the 8th, that's
24
when it was noticed that this thing wasn't --
25
MR. I.
: Right.
EFTA00141970
1
MR.
: -- recording.
2
MR. I.
: Yes.
3
MR.
: And that was by an SIS
4
official?
5
MR. I.
:
Mm-hmm.
6
MR.
:
Somebody, either a
7
8
MR. I.
: Mm-hmm.
9
MR.
: -- or a
10
MR. I.
: Yeah.
11
MR.
: On the 9th, you went in
12
to go fix it?
13
MR. I.
: Yes.
14
MR.
: But you went towards the
15
end of your shift, when III was leaving?
16
MR. I.
: I started doing something
17
before then, but it was going to be too late
18
for the drives to rebuild, so even if I
19
replaced them, it wasn't going to be, like,
20
right away. The drives were going to start
21
working.
22
MR.
:
Well, didn't you say that
23
it took about eight hours for the drives to -?
24
MR. I.
: A whole day. 24 hours.
25
MR.
:
So --
EFTA00141971
1
MR. I.
:
Not eight hours. Not
2
eight hours. A whole 24 hours.
3
MR.
: -- so, why wouldn't you
4
have rebuilt them --
5
MR. I.
: Mm-hmm.
6
MR.
: -- during the day, on the
7
9th, so that you could check back in on the
8
MR. I.
: Probably --
9
MR.
:
10th?
10
MR. I.
: -- well, like I said, I
11
didn't have drives, or I was trying to get the
12
drives.
13
MR.
:
Well, this says that, on
14
the 8th, you didn't have the drives. On the
15
9th --
16
MR. I.
:
Mm-hmm.
17
MR.
: -- he had --
18
MR. I.
:
Yeah.
19
MR.
: -- he did not access to
20
the DVR --
21
MR. I.
: Mm-hmm.
22
MR.
:
DVR room.
23
MR. I.
: Mm-hmm.
24
MR.
: -- to replace them.
25
MR. I.
:
To replace the drives.
EFTA00141972
81
1
Yeah. So, it was probably later, in the end of
2
the day, I had all the drives, and I went to go
3
replace them. And that's when I couldn't go in
4
the room.
5
MR.
: Okay. And then, you
6
talked to III at that time, and said you would
7
be back on Saturday to do it?
8
MR. I.
: Yeah. Yeah.
9
MR.
: All right. Now, in
10
talking to Lieutenant
she explained
11
that this was an extremely urgent matter, and
12
that she spoke to - she wrote a memo on it.
13
And she talked to the captain, and they said,
14
make sure you get this done today. And that --
15
MR. I.
: Yeah.
16
MR.
: -- on the 10th, when she
17
saw you --
18
MR. I.
: That sounds like --
19
MR.
: -- she said --
20
MR. I.
: -- a lot of B.S. I'ff
21
sorry to say like --
22
MR.
: -- okay.
23
MR. I.
: -- that doesn't -.
24
Because this thing happened so many times, as
25
I've been there. Like, why would this day be
EFTA00141973
1
different from the months leading up to it,
2
where this kept happening? Like, why would
3
I know Epstein happened. Everybody is trying
4
to say --
5
MR.
: Yeah.
6
MR. 1.
-- okay, this is what
7
happened, but before that, nobody even cared.
8
To be honest with you.
9
MR.
: So
10
MR. I.
: I'm just going to be
11
honest. Nobody cared that the drives were bad,
12
or the recordings aren't working. Oh, those
13
recorders weren't working. Okay. Fix it,
14
. And then, we will go from there. But
15
nobody, before Epstein. This was, like, a known
16
thing.
17
MR.
: Okay.
18
MR. I.
: Like, the drives would go
19
bad. There would be no video. It was no big
20
deal to anybody in that building.
21
MR.
: Because you said, in
22
every other institution, within the BOP --
23
MR. I.
: Yeah.
24
MR.
: -- this would have been
25
very (Indiscernible *00:49:57).
EFTA00141974
83
1
MR. I.
: This is a big deal. This
2
is, like, you can't leave. You've got to stay
3
here.
4
MR.
: Well, that's what she
5
says, she said she actually wrote a memo,
6
provided it to the captain, both said, yes,
7
this has got to get done on the 8th.
8
MR. I.
: Well, if that was the
9
case, they would have gave me access and I
10
would have stayed in the building. I would
11
never get to go home. And that's what I've
12
done before in my other institution. Any time
13
anything fails, or if there is a big failure,
14
you stay until it's fixed.
15
MR.
: Right. And that's where
16
17
MR. I.
: And that's what they are
18
doing now.
19
MR.
: -- what we're trying to
20
reconcile.
21
MR. I.
: Yeah.
22
MR.
: Because the memo was
23
written on the 8th, provided to the captain.
24
They said, "Make sure it's fixed." She's
25
saying that the next time she saw you, on the
EFTA00141975
1
10th, and finds out that the video wasn't
2
recorded, she says to you, why didn't you fix
3
this on the 8th?
4
MR. I.
: Yeah. Good luck. Yeah.
5
And because it doesn't even take me a day to
6
fix -. Those problems, it takes me a couple of
7
days, because I have to rebuild drives. Even
8
when I rebuild the drive, the next day it's not
9
going to work.
10
MR.
: Right.
11
MR. I.
: It's going to take a
12
couple of days. And after I rebuild the
13
drives, you have no video from the days prior.
14
I don't even know what video you have after the
15
drives start working. You have to go look to
16
see what video you have.
17
MR.
: Okay. So, again, I guess
18
that's the question of, why didn't you start
19
working on it immediately, on the 8th?
20
MR. I.
: Because I have no idea.
21
MR.
: Well --
22
MR. I.
: Well, I was working on it,
23
but yeah.
24
MR.
: -- it was -.
25
MR. I.
: But, like, it looks like,
EFTA00141976
1
it was a pattern of, okay,
, it's a
2
priority, but it's not a priority.
3
MR.
: Okay.
4
MR. I.
: And for somebody to say
5
they wrote a memo to the captain, like, where
6
is there a memos before when this happened?
7
MR.
: And then, we'll have to
8
ask, I guess --
9
MR. I.
: Yeah.
10
MR.
: -- (Indiscernible
11
*00:51:16) about previous memos.
12
MR.
: Yeah. There's got to be
13
previous memos.
14
MR.
: Okay.
15
MR. I.
: Yeah. This is - yeah,
16
that right there.
17
MR.
: So, you don't think that
18
that's accurate?
19
MR. I.
: No. I would not say that
20
that's accurate. I'm not trying to throw
21
anybody under the bus, but to say, like, this,
22
this day, like, it's bigger than any other time
23
it happened, like, come on, this has been
24
happening for months now.
25
MR.
: Okay.
EFTA00141977
86
1
MR. I.
: It's been happening since
2
I got in that building. And I was at a
3
previous institution and like I said, if this
4
was a big deal, I wouldn't even go home.
5
, you've got to stay for overtime.
6
You've got to call SigNet. I'm going to give
7
you the key for the room.
8
MR.
: Well, that's what they
9
said that they did. Or at least Lieutenant
10
is saying that she told you that this is
11
a big deal, you've got to do it.
12
MR. I.
: Pfft.
13
MR.
: Right now. And --
14
MR. I.
: Oh, yeah. Everybody is
15
trying to cover their tracks. No. This is not
16
the case. I could honestly say this is not the
17
case.
18
MR.
: All right.
19
MR. I.
: And it has never been
20
previous practice before. I had a facility
21
manager,
(Phonetic Sp.
22
*00:52:05),my previous facility manager, I'm,
23
like, hey, the first time this happened, I
24
remember it because it was so weird to me that
25
they told me to go home. I was, like, well, at
EFTA00141978
87
1
my other jail, if something wasn't working, I
2
couldn't leave. Like, if he radios go down, I
3
have to stay there until the radios are fixed.
4
Like, two months ago, the radios failed, and -
5
oh, three months ago - they failed in Brooklyn.
6
They called me from MCC New York, to go to
7
Brooklyn to help them with their radio system.
8
MR.
: Right.
9
MR. I.
: Their console. So, if
10
that was the case, they would have called MCC
11
to come, if I couldn't stay to fix the problem.
12
So, that's never been previous practice over
13
there. No.
14
MR.
: Okay.
15
MR. I.
: That's, like, that's news
16
to me.
17
MR.
: Now, are you aware that
18
the captain was notified?
19
MR. I.
: He probably - he should
20
have been notified. It's the captain's
21
equipment every time the camera is not
22
recording.
23
MR.
: All right. So, but you
24
do recall, you did speak on the 8th with the
25
lieutenant, with an --
EFTA00141979
1
MR. I.
: Yes.
2
MR.
: -- one of the two --
3
MR. I.
(Indiscernible *00:53:00).
4
MR.
:
SIS.
5
MR. I.
: I talked to somebody on
6
the 8th. Yes.
7
MR.
: And you just can't
8
specifically even kind of put yourself back
9
into that?
10
MR. I.
:
No.
11
MR.
:
Do you remember, though,
12
on the 10th, Lieutenant
saying, why
13
didn't you fix this?
14
MR. I.
: I was so busy with
15
everything else. Like, I don't even remember
16
that.
17
MR.
:
So, you don't remember
18
that.
19
MR. I.
:
No. I don't.
20
MR.
:
Do you have any reason to
21
believe it wasn't Lieutenant
that you
22
spoke with on the 8th?
23
MR. I.
:
No. I don't believe so.
24
MR.
:
You don't believe you
25
spoke with her, or you don't -.
EFTA00141980
89
1
MR. I.
:
No. I believe I spoke to
2
somebody from SIS. Because that's when who
3
If they were trying to pull video, and they
4
couldn't pull the video, that's when they would
5
tell me, hey,
6
MR.
:
Right.
7
MR. I.
: -- there is a problem.
8
But other than that --
9
MR.
:
So --
10
MR. I.
: -- there is no reason for
11
me to talk to anybody from SIS.
12
MR.
:
So, it's a likely that it
13
was Lieutenant
14
MR. I.
: Yes.
15
MR.
: And is it likely that, on
16
the 10th, Lieutenant
asked you why
17
wasn't this fixed?
18
MR. I.
: If she was there, yeah.
19
MR.
: Okay.
20
MR. I.
: Yeah.
21
MR.
: And is it likely that you
22
told her, on the 10th, that's why I'm here
23
today, to fix it?
24
MR. I.
: Yes.
25
MR.
: Okay. Is there anything
EFTA00141981
90
1
that I read to you, from this, on the, you
2
know, on the 8th is when you determined; on the
3
9th you couldn't gain access; and on the 10th
4
is when you gained access to the DVR room --
5
MR. I.
: Mm-hmm.
6
MR.
: -- and you attempted to
7
replace the drives. Does that all sound
8
accurate?
9
MR.
: That sounds accurate.
10
Yes.
11
MR.
: All right. So, it is
12
that, on the 8th, you found out; the 9th, you
13
couldn't gain access
14
MR. I.
: (Indiscernible *00:54:11).
15
Yeah.
16
MR.
: -- and the 10th -.
17
MR. I.
: It was all (Indiscernible
18
*00:54:15). Yeah.
19
MR.
: Okay. So, now going
20
forward, though, we can at least have a --
21
MR. I.
(Indiscernible *00:54:18).
22
MR.
a story of --
23
MR. I.
: For what happened --
24
MR.
for what it is --
25
MR. I.
: -- yes. Happened.
EFTA00141982
91
1
MR.
: -- that happened. So
2
now, these questions might make a little more
3
sense.
4
MR. I.
: Okay.
5
MR.
: And -.
6
MR. I.
: Hey, can I ask him
7
something?
8
MR.
:
Yeah.
9
MR. I.
: Before we go.
10
MR.
:
Please.
11
MR. I.
: Okay.
12
MR.
:
Please do.
13
MR. I.
: So, there is something
14
contradictory in between the 302 and the
15
SigNet. On the 302, it states that there was a
16
motherboard failed on DVR-2, on August 8th.
17
MR. I.
: Mm-hmm.
18
MR. I.
: It doesn't say that the
19
hard drives failed. It says the hard drives
20
failed on August 10th.
21
MR.
:
Yeah. Could you -.
22
MR. I.
:
That's two different
23
things.
24
MR. I.
: Mm-hmm.
25
MR.
:
So, yeah. So --
EFTA00141983
1
MR. I.
: So, as --
2
MR.
: -- according -.
3
MR. I.
: -- Agent
4
asked, what happened, and when did it happen?
5
MR. I.
: That, you would have to
6
call. I'm not too sure the dates of
7
everything.
8
MR.
: But this is, so, this was
9
the, this is the interview of you.
10
MR. I.
: Mm-hmm. Yes.
11
MR.
:
So, the assumption is,
12
that you are the one who provided them this
13
information. Correct?
14
MR. I.
: Yes. I am.
15
MR.
:
So, with you telling them
16
that a system failure of DVR-2 occurred on July
17
29th, 2019 -?
18
MR. I.
: I don't think I would have
19
given them exact dates because I don't remember
20
when all that stuff happened, to tell you the
21
truth. Me giving exact dates, that's, I can't
22
give exact dates.
23
MR.
: Okay.
24
MR. I.
:
Yeah.
25
MR.
: And then, so you think
EFTA00141984
1
that they actually located these dates on
2
themselves?
3
MR. I.
: Yeah. They probably would
4
have to call SigNet to get the exact dates.
5
MR.
: So, you don't think that
6
this is actually the information you provided
7
them during the interview?
8
MR. I.
: No. Because I wouldn't
9
have gave them -. There is no way I would have
10
had that, or remembered this. No.
11
MR.
: Okay. And then, saying
12
that the motherboard failed on DVR-2, on August
13
8th, 2019.
14
MR. I.
: That's something -. Yeah.
15
That's information they would have got from
16
SigNet.
17
MR.
: So, you don't believe
18
that this, you actually - this paragraph right
19
here - that you told them? You think that they
20
got that information --
21
MR. I.
: Yeah. They probably --
22
MR.
: -- outside of your
23
interview?
24
MR. I.
: -- collaborated it with
25
SigNet. Yes. Because me and - I don't even
EFTA00141985
94
1
remember exact dates today. So, like, there's
2
no way I could remember exact dates.
3
MR.
: All right.
, did
4
you want to follow up on that?
5
MR. I.
: No. I mean, yeah, it
6
comes from -. So, you're saying that the
7
statement in the 302 is inaccurate?
8
MR.
: No.
9
MR. I.
: No.
10
MR.
: No. He's not saying
11
that's inaccurate.
12
MR. I.
: I'm saying it's accurate,
13
but they probably found out dates.
14
MR.
: He's saying that he
15
thinks that they got this information based
16
upon another source, not from him.
17
MR. I.
: Not from me.
18
MR. I.
: Okay.
19
MR. I.
: Because I can't give you
20
exact dates. That's all.
21
MR.
: All right. So, there is
22
- just while we're on this 302 - there is
23
another part that says, "After the incident,"
24
and that's the Epstein incident.
25
MR. I.
: I know.
EFTA00141986
95
1
MR.
:
was asked about
2
the cameras."
3
MR. I.
: Mm-hmm.
4
MR.
: Who asked you about the
5
cameras? Do you recall?
6
MR. I.
: Pfft. The warden.
7
Everybody. Anybody that could think about
8
asking me questions asked.
9
MR.
: All right. "There were
10
two new hard drives to install."
11
MR. I.
: Yeah.
12
MR.
: "But installing the new
13
hard drives would mean that all prior data --
14
MR. I.
: Yeah.
15
MR.
: -- would be lost.
16
MR. I.
: Lost. Yeah. You would
17
lose all video.
18
MR.
: Oh. Lose all video or
19
lose all recording?
20
MR. I.
: All the old video. Yes.
21
MR.
: Oh, so, the recording of
22
the old video?
23
MR. I.
: Yes. Yeah.
24
MR.
: So, when you install
25
these new hard drives --
EFTA00141987
96
1
MR. I.
: The two new drives, and
2
everything would be gone.
3
MR.
everything is wiped.
4
MR. I.
: So, whatever video they
5
were looking for, it would be gone. So,
6
whatever they were trying to, it would be gone.
7
MR.
: Okay. It says, "The
8
Warden wanted video, and so
was told to
9
start working on the system."
10
MR. I.
: Yes.
11
MR.
: So, at this time, was it
12
prior to replacing the new, the two new drives?
13
MR. I.
: Well, this time, that's
14
when I probably started replacing the drives.
15
MR.
: But if --
16
MR. I.
: Yeah.
17
MR.
: -- if you replaced then-
18
and all recording gets --
19
MR. I.
: Wiped.
20
MR.
: -- wiped.
21
MR. I.
: Yeah.
22
MR.
: Then how would you be
23
able to obtain the video?
24
MR. I.
: Yeah, there is no video
25
obtained.
EFTA00141988
97
1
MR.
:
So, that's what I'm just
2
trying to make sense of what this states. So,
3
"The Warden wanted video, so
4
MR. I.
: They wanted me to start --
5
MR.
-- was told -."
6
MR. I.
: -- they wanted me to start
7
that day recording video. We will get the
8
recorder to work, though --
9
MR.
: Oh.
10
MR. I.
: -- (Indiscernible
11
*00:57:52).
12
MR.
:
Well, he didn't want
13
video of the incident --
14
MR. I.
: Incident.
15
MR.
: -- he wanted video to
16
(Indiscernible *00:57:56).
17
MR. I.
: And then, he was trying to
18
see if there was video from the incident, and
19
I'm, like, there is no video. And that's when,
20
the next day, I find out there was a video on
21
the other recorder --
22
MR.
: Okay.
23
MR. I.
: -- that, yeah, that other
24
camera.
25
MR.
:
So, that helped explain
EFTA00141989
98
1
it. When you were saying the warden wanted
2
video, you're talking about from that point
3
forward, the video
4
MR. I.
: The video. Yeah.
5
MR.
: -- he wanted the
6
recording to be working --
7
MR. I.
: Yeah. He --
8
MR.
: -- not the video of the
9
incident.
10
MR. I.
: -- well, they wanted
11
video of the incident, and the recorder to
12
start working. I'm, like, there's no video,
13
there's nothing I could do. I can't find any
14
video.
15
MR.
: Okay.
16
MR. I.
: That recorder is gone.
17
MR.
: I gotcha.
18
MR. I.
: So then, it was at that
19
point, okay, we'll get the recorder working,
20
and do whatever you got to do to get the
21
recorder working.
22
MR.
: Okay. So, it says,
23
started removing the bad drives in
24
order to rebuild the DVR."
25
MR. I.
: Yeah.
EFTA00141990
1
MR.
: Is that correct?
2
MR. I.
: Yes.
3
MR.
:
So, are you the one that
4
actually removed the two --
5
MR. I.
: The drives.
6
MR.
: -- drives?
7
MR. I.
: Yeah.
8
MR.
: And you
9
MR. I.
: And I labeled everything.
10
Yeah.
11
MR.
: -- and you put the new,
12
two new drives in?
13
MR. I.
: Yes.
14
MR.
: All right.
15
MR. I.
: And then, the FBI came and
16
stopped me in the middle of everything.
17
MR.
:
It says, "
advised
18
that the FBI agent was the one who pulled out
19
the DVR."
20
MR. I.
: Yeah. Because I told
21
them, if you pull out the drives, that you're
22
going to have problems, there's going to be
23
corruption, because like I, like I told you
24
before, you pull out two drives, like,
25
everything is wiped. Even if there is a video
EFTA00141991
100
1
from before. You just, you're, like, out of
2
luck. Because it's going to --
3
MR.
: Now, can you just explain
4
that? What is it that they pulled?
5
MR. I.
: Two of the drives.
6
MR.
: They pulled the two
7
drives?
8
MR. I.
: Yeah. Yeah. Because I
9
was -. See, what happened was, I was going to
10
start rebuilding the drives, so I labeled
11
everything. It was, it was a mess. So, they
12
wanted me to -. Let me if I can think about
13
it. So, everything stopped working. I go in
14
the room,
, you've got to get the
15
recorder working. Well, I got to pull the
16
drives out to get the recorder working. So,
17
the two drives that I pulled out. And so, the
18
two old drives, and the two new drives, I
19
labeled them, because I knew that it was going
20
to be a big thing. So, I got to pay attention
21
to what I'm doing. And then, in the midst of
22
all that, that's when they took the drives, and
23
said, hey, we need to stop doing everything.
24
MR.
: So, who is it that
25
actually pulled the bad drives out? You or the
EFTA00141992
101
1
FBI?
2
MR. I.
: I pulled the bad drives
3
out to replace them with good drives. Yes.
4
MR.
: And you put the two new
5
drives in?
6
MR. I.
: Drives in. Yes.
7
MR.
: So, what is it that the
8
FBI pulled?
9
MR. I.
: They pulled all the
10
drives.
11
MR.
: So, you were rebuilding
12
it. And when you rebuilt it, they came in and
13
they just pulled them all out?
14
MR. I.
: Yeah. They would pull
15
them all.
16
MR.
: So, it was never able to
17
rebuild?
18
MR. I.
: Yes.
19
MR.
: All right. So, they
20
pulled all the drives. And so, when they said
21
the DVR. Is that different from -?
22
MR. I.
: Yeah. The DVR because
23
they pulled everything from DVR-1, and that was
24
the one that wasn't working. And then, DVR-2,
25
the one that was working, the next day, I had
EFTA00141993
102
1
to get all the - well, the same day - I could
2
get all the important parts of the prison on
3
DVR-1, that wasn't working, on DVR-2, which I
4
probably should have done the day before, but
5
6
MR.
:
So, it's DVR-2 that we're
7
speaking about. Correct?
8
MR. I.
: Yes. That was the good
9
drive.
10
MR.
: Oh, DVR-2 was the good
11
drive?
12
MR. I.
: Yes.
13
MR.
: But DVR-1 wasn't. Okay.
14
So, DVR.
15
MR. I.
: And what does this say?
16
DVR. DVR-2 is the good drive. DVR-1 is the
17
bad drive.
18
MR.
: Okay. So, DVR-1 --
19
MR. I.
: That's not - no - that's
20
not what you said before. You said DVR-1 was
21
all good. DVR-2 went bad.
22
MR. I.
: Yes.
23
MR.
: Okay. So, DVR-2 was the
24
bad drive.
25
MR. I.
: Yes.
EFTA00141994
103
1
MR.
: So, as far as DVR-2 being
2
the bad drive, is the DVR, is that the 16
3
drives, or is there a separate box --
4
MR. I.
: No. It's the 16 drives,
5
and then, you have, like, the brain, some
6
motherboard, you know, the other computer on
7
the bottom, but -.
8
MR.
: So, when you say, when
9
they say that the FBI agent was the one who
10
pulled out the DVR, you're talking about all 16
11
12
MR. I.
: All the, they probably
13
pulled the --
14
MR.
: -- drives and
15
motherboard.
16
MR. I.
: -- they probably pulled -.
17
Yeah. They probably took all of the
18
recordings. But they had to take -. When I'm
19
talking about that the next day, because we
20
already had the new set, when all this
21
happened, SigNet came the next day, and we haa
22
the new system up and running. Everything was
23
in boxes. So, he had to just come in and
24
install it.
25
MR.
: Okay. So --
EFTA00141995
104
1
MR. I.
: So, the next day, the FBI
2
took both drives, DVR-1 and 2.
3
MR.
:
So, on the 11th, the FBI
4
came and just took it all?
5
MR. I.
: They took it all. Yes.
6
MR.
: Everything?
7
MR. I.
: Everything.
8
MR.
: All right. Okay. So, it
9
says that, "
also advised that he knew
10
that, by replacing both hard drives, the system
11
would be wiped.
12
MR. I.
: Mm-hmm.
13
MR.
: And that he had advised
14
personnel at MCC of that."
15
MR. I.
: Yes.
16
MR.
:
Now, when you say,
17
"Wiped," it means just everything --
18
MR. I.
: It means --
19
MR.
: -- that was on it before?
20
MR. I.
: -- everything is gone.
21
Yes. There is no video. There's nothing.
22
MR.
: And do you know how far
23
that would have gone back to?
24
MR. I.
:
No.
25
MR.
:
No?
EFTA00141996
105
1
MR. I.
: No.
2
MR.
: So, was that the case,
3
could have we obtained video off of those -?
4
MR. I.
: Other drives? Yes, before
5
I started rebuilding. Yes. But that's what I
6
was told to do. So, that's what I was
7
(Indiscernible *01:02:17).
8
MR.
: So, just explain that.
9
What could have we got off of it? And you're
10
talking about DVR-2 now, the bad drive. Right?
11
MR. I.
: DVR-1 is the bad drive.
12
MR.
: So, this is where I'm
13
getting confused. I thought we just said that
14
DVR-2 is the bad drive. I've got to get this
15
straight.
, you just - I thought we
16
said, we did say that, but then you just chimed
17
in and said it was DVR-2 that was bad. Which
18
one was it? DVR-1 or 2 that was bad?
19
MR. I.
: DVR-1 is bad.
20
MR. I.
: In the initial part of the
21
interview, he stated that DVR-2 went bad, and
22
DVR-1 drives were all good.
23
MR.
: All right. Because yeah,
24
on the Jeff thing, it says --
25
MR. I.
: Yeah, because everything
EFTA00141997
106
1
was on DVR-2.
2
MR.
: -- "He attempted to
3
replace the drives, and he started to rebuild.
4
During the rebuild process of the drives, the
5
drives were required to be taken out of raid on
6
DVR-2."
7
MR. I.
: Yeah. I would say on DVR-
8
2. I'm sorry. I got confused.
9
MR.
: All right. So, DVR-2 is
10
the bad drive
11
MR. I.
: The bad drive. Yes.
12
MR.
: All right. So, on DVR-2,
13
the bad drive
14
MR. I.
: Yeah.
15
MR.
: -- could video have been
16
obtained?
17
MR. I.
:
Yes, before I started
18
doing anything. Yes.
19
MR.
: So, prior to you pulling
20
them out, we may have been able to obtain video
21
from the 9th?
22
MR. I.
: Hmm. No.
23
MR.
: August 9th?
24
MR. I.
:
No. Because it wasn't
25
recording.
EFTA00141998
li
1
MR.
: All right.
2
MR. I.
: Because you had two bad
3
drives.
4
MR.
: So, what video are you
5
talking about when we said we could have
6
obtained video?
7
MR. I.
: Oh, well, saying that
8
stuff there is a possibility in the background,
9
even if you have two bad drives that stuff
10
could have been recording over it, but that's
11
their technical jazz. Like, I don't know
12
anything about that.
13
MR.
: So, in saying that
14
MR. I.
: But saying that -.
15
MR.
it sounds like, okay,
16
it is possible that we could have gotten video
17
18
MR. I.
: Video.
19
MR.
: -- for August 9th and
20
10th.
21
MR. I.
: Yes. It is a possibility.
22
Not a strong possibility, but yeah.
23
MR.
: So, it is possible, but
24
once the two drives --
25
MR. I.
: Yes.
EFTA00141999
108
1
MR.
: -- were pulled --
2
MR. I.
: Pulled. Yes. That was a
3
4
MR.
: -- that possibility
5
became --
6
MR. I.
: Yeah.
7
MR.
: -- impossible.
8
MR. I.
: It was gone. Yes.
9
MR.
: All right. Now, are
10
those two drives, are you -? When the SIS
11
official told you on the 8th that they weren't
12
able to go back --
13
MR. I.
: To do.
14
MR.
: -- and review the video -
15
16
MR. I.
: Mm-hmm.
17
MR.
: -- if something was
18
recording in the background, would you have
19
been - you know, like you were talking about,
20
there is a possibility - would you have been
21
able to tell at that time?
22
MR. I.
: No. I wouldn't have been
23
able to tell. That's something SigNet would
24
have, or some expert, video expert, would have
25
EFTA00142000
109
1
MR.
: All right.
2
MR. I.
: That's nothing above me.
3
MR.
: Was your only course of
4
action to replace those two bad drives?
5
MR. I.
: Yes.
6
MR.
: So, would, regardless,
7
that video have been, at some point, deleted?
8
MR. I.
: Yes.
9
MR.
: And you were -. Whc
10
instructed you to actually pull out those two
11
bad drives?
12
MR. I.
: I would just have to -
13
probably talked to SigNet, or -. Well, and I
14
told SIS this before, like, if I pulled two
15
drives, there is no video, especially if it was
16
bad.
17
MR.
: Did you talk to anybody
18
on August 10th, prior to pulling them, that
19
there was a possibility that video of the
20
Epstein incident could have been retrieved?
21
MR. I.
: No.
22
MR.
: So, you didn't tell
23
anybody that?
24
MR. I.
: I'm not saying I didn't
25
tell anybody that, but that was -. I think
EFTA00142001
110
1
that's something I found out later. Because
2
that's when SigNet was talking to me. But
3
that's not something I would have known before
4
Epstein.
5
MR.
: All right.
6
MR. I.
: Because that was something
7
we talked about, like, the days after that
8
happened.
9
MR.
: Because this 302 says,
10
advised that an FBI agent was the one
11
who pulled out the DVR.
also advised
12
that he knew that, by replacing both hard
13
drives, the system would be wiped, and that he
14
had advised personnel at MCC of that."
15
MR. I.
: Mm-hmm. There would be no
16
video.
17
MR.
: When did you do that:
18
MR. I.
: Before I started doing
19
anything. If I'm going to change drives,
20
you're going to know, like, it's -. Because
21
know this was going to be bigger than just me
22
fixing the recorders. Like, there is other
23
things that are going to happen, but I'm going
24
to tell you, hey, if I do this, this is what's
25
going to happen.
EFTA00142002
111
1
MR.
: But I thought you just
2
said that that's something you found out later.
3
MR. I.
: Later. But no, as far as
4
there being video on the background.
5
MR.
: Oh.
6
MR. I.
: Yeah. As far as --
7
MR.
: So -.
8
MR. I.
: -- me pulling out the
9
drives, I already knew that before because
10
that's what happened the last time, when I
11
replaced two drives, that there was no old
12
video. It was just the new video.
13
MR.
: So, on the 10th, your
14
understanding, that there was no video from the
15
9th --
16
MR. I.
: Or the 10th.
17
MR.
: -- or 10th.
18
MR. I.
: Yes. That was my
19
understanding.
20
MR.
: So, therefore, yeah, and
21
at that time, you didn't know that there was a
22
possibility
23
MR. I.
: Possibility --
24
MR.
: If things were recording
25
EFTA00142003
1
MR. I.
: -- going in the
2
background.
3
MR.
: -- in the background.