10 11 12 13 14 18 19 20 21 22 23 24 26 DIGITALLY RECORDED SWORN OF STATEMENT OIG CASE #: 2019-010614 DEPARTMENT OFFICE OF THE INSPECTOR GENERAL OF JUSTICE SEPTEMBER 1, 2021 RESOLUTE DOCUMENTATION SERVICES side Drive, Suite Hills, (818) CA 91301 431-5800 285 EFTA00061431

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1 oO wo oO co WITN OR GENERAL EFTA00061432

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LIMITED OFFICIAL USE 3 wo 12 New 13 17 rt, EFTA00061433

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LIMITED OFFICIAL USE 10 11 12 13 14 16 17 18 19 20 21 22 23 24 es | ti‘ iésl Thank you. This is an official DOJ OIG investigation into the death of inmate Jeffrey Epstein and the surrounding circumstances and you’re being asked to voluntarily provide answers to our questions. Will you agree to a voluntary interview with the DOJ OIG? ee : Thank you. So we have the Warnings and Assurances to Employee Requested to Provide Information on a Voluntary Basis. Sorry. 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 the Inspector General Act of 1978 as amended. This investigation pertains to job performance 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 proceeding or agency disciplinary EFTA00061434

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LIMITED OFFICIAL USE w ~] ive) uw proceeding or both. And there’s a waiver section. It says, I understand the Warnings and Assurances stated above and I am willing to make a statement and answer questions. No promises or threats have been made to me and no pressure or coercion of any kind has been used against me. This is the form if you want to take a look and read it. If you agree, there’s a place where you can sign for employee signature. ee : You want employee you said? ae : Yeah, the employee signature. ae : Print your name below that. a : Thank you very much for signing and printing your name. I appreciate that. I’m going to put in the date. Again it is September 1, 2021 and the time is now 12:25 p-m. And I am signing as the OIG Special Agent and printing my name. a : This is Special Agent a. I’m signing as a witness. ee : And you just fill out the rest and say place for MCC. Yeah. All right. EFTA00061435

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LIMITED wo And did you understand the form that you were vided? Great. Thank view, I’d like under oath. Lieutenant | your right hand. your current position with the B dates, y interviewed. at. Thank you. ur transcript from June 14, AL USE 6 EFTA00061436

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LIMITED OFFICIAL USE 10 11 12 13 14 16 17 18 19 20 21 22 23 24 your answers were a little unclear and we are here today in hope that we can clear up some of those answers. Is it correct that you worked on August 10th, morning watch shift, at the MCC starting on August 9, 2019 at 10:00 p.m. through August 10, 2019 when you were relieved by oncoming lieutenant at approximately 5:30 a.m.? Here’s the Friday, August 9th and Saturday August 10th are the daily assignment rosters. And this is - the dates that we’re talking about is the day before Epstein was discovered and the day Epstein was discovered. So the Friday and Saturday. EE: «= According to the roster, I worked the morning watch shift on Friday August 9th and Saturday August 10th. | tti(‘aiéisl And at that time, is it correct that the morning watch shift actually started the night two hours prior to what the schedule says. You would actually have started at 10:00 p.m. instead of midnight. that we relieved each other. Yes. ee : Okay. So in this case, so it’s specifically talking about your August EFTA00061437

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LIMITED OFFICIAL USE 8 n 1 10th shift. Would have y tarted on Aug 9th at 10:00 p.m. and that shift would have er igust 10th? 5 on 6 8 ie) ct ie) us, but is it true st 10, 2019, later 13 15 16 interv i 17 heard about and went up to help with feeding. Do 19 you recall what you doing from finishing EFTA00061438

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LIMITED ies) w fos) wo ive) co OFFICIAL USE 9 previous shift, yes. paperwork. paperwork do you finish up before paperwork. I don’t - I can’t remember that night if I had had an still working on 583 pa @ port that we had to do every night. I still -. I don’t remember stly what I was doing, but I don’t know if I was doing the -. I forgot what it’s called now. But it’s a - like a report that we do of what happens throughout the di: - ¥y ee: The lieutenant log? lieutenant’s log. But I could EFTA00061439

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LIMITED ies) w fos) wo ive) oo OFFICIAL USE 10 0) ntries into the lieutenant’s log as well. ee : The daily activity the daily - at least with ours, we - that goes along with the , the daily activit y report, the log. I might have been still doing changes in the roster at the last minute. Things to that effect. ii) y- And do you recall ee: Right. y¢ ecall for approximately for how long? You said you went is) fe) re) fe a] up there around 7:00 a.m. to help with the feeding. Do you recall how long you were I was up there because there were no other staff members there. And as other staff EFTA00061440

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LIMITED OFFICIAL USE 11 1 members came, it was us - I said I’m going to had additional staff. The onl oO time wo ot) oO t oo (D kK D iss = t+ a) EFTA00061441

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LIMITED oO wo oO co OFFIC himself. So d him with And d though? don’t ld have i remember I went got the When you recall. I t been right if you EFTA00061442

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LIMITED OFFICIAL USE 13 1 stayed there that long? 2 ee : I don’t think it was 3 - It wasn’t right after. It wasn’t 4 immediately after feeding because like I said, 5 there was nobody there. So and then 6 eventually - she eventually left. I think by 7 the time we were finishing up feedings there at 8 some point I think she left. And a couple of 9 staff came. And then some of them ended up 10 having other things to do because we were so 11 shorthanded. 3 ee : During that time that 4 there was just nobody. We didn’t’ have any 15 bodies. 16 a : Sure. Do you remember 7 though, putting yourself back into that day, do 8 you remember what you would have done after the 9 feeding? 20 Ee: §= don’t remember what 21 I did. If I wasn’t finished with what I was 22 doing, I finished that up and I’m sure I went 23 home. 24 ee : No-no-no. I’m sorry. 25 When you were in the SHU. Do you remember -? EFTA00061443

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LIMITED OFFICIAL USE 14 10 11 12 13 14 16 17 18 19 20 21 22 23 24 I’m talking specifically about the SHU right now. After the feeding was done, you and | were done. Do you remember if you did any other tasks or anything while you were in the SHU? I don’t remember. I don’t remember doing anything else because we fed and then you go the grace point where you’re waiting to see - waiting for the inmates to finish so you can get the things from them. But no. No. Nothing in particular comes to mind from like that. ae : You mentioned you would have finished up whatever you were - that you didn’t get a chance to complete. What was it that you’re talking about? You said that after the feeding, you would have finished up whatever else that you couldn’t get a chance to complete. You would have finished up -. | Right. Like if I had - if there was work that I still needed - paperwork that I still needed to get done or do or something like that for my shift. I would EFTA00061444

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LIMITED OFFICIAL USE 15 ies) w ~] wo 10 11 ive) have finished that up if that was still due. I don’t even know if I even -. I don’t -. I don’t know if I came and got my stuff and left or if I finished doing the paperwork. I don’t know in what order I did that. Okay. So from our end, we had to review like all the emails and stuff you know for everybody. And see what was going on especially with the daily activities - what we just talked about - the daily activities report and with the lieutenant’s log. So this is the email that you sent out. I guess this is what you - maybe you were working on. The daily activity report. sent out at 9:26 a.m. on August 10th. Okay. So do you believe that may have been what you were working on? Like I said, like I said previously, if was - if I had additional paperwork to do, it was the daily log and probably my lieutenant log or something to that EFTA00061445

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LIMITED OFFICIAL USE 16 10 11 12 13 14 16 17 18 19 20 21 22 23 24 effect. I don’t -. Because I can’t remember if I had a 583 packet that I was working on. ee : Okay. And then what time are these emails with the daily activity report and lieutenant’s log. What time are they typically sent out in the mornings? ee : Whenever we finish them. I mean we try and have them done before the end of our shift. But at that particular time because we didn’t have any bodies. And everything took longer. There were times when - sometimes you had things that you didn’t expect. Or rounds or something like that took longer. Hiring overtime or something like that took longer. That everything didn’t get done. ee : And plus, you know, when you’re making rounds -. We were so short and officers were doing so many - officers were being mandated every day during that time. And they have been being mandated every day - five days a week - for months by then. That the officers, you know, they were so tired and exhausted that you spent an additional amount of time talking to them and making sure that EFTA00061446

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LIMITED OFFICIAL USE 17 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 they were okay. So everything just ran on. | ti‘ iésl Okay. So the part - the reason why we’re asking is we have - we looked at all the other lieutenant logs that were - this is stapled - sorry. So here, we looked, you know leading up to it. So here’s the one you sent from Tuesday, August 6th. It was sent out at 5:16 a.m. And you sent one out of Wednesday, August 7th at 5:03 a.m. You weren’t - we didn’t’ find Thursday’s but then you sent one out on Friday, August 9th at 5:11 a.m. So this one is Saturday. This one was at 9:26 a.m. And then Sunday’s was sent out at 6:15 a.m. And then Monday’s August 12th, again at 6:30 a.m. So just does this help you recall what could have possibly been happening? I know you said you went up at 7:00 a.m. to help with the feeding. So do you know what you would have been doing up until that 7:00 a.m. hour? Being that all these were sent out, you know, anywhere from as early as 5:00 a.m. to as late as, you know, 6:30, 6:30 something a.m. working. EFTA00061447

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LIMITED OFFICIAL USE 18 was doing, t it was pertaining to work. I wasn’t si ting 3 here. When I got 4 would 5 been no reason for me to 8 wanted to be here. te) Mm-hm. 11 work that I needed to complete during that Nas working on ive) fea] what I would oo been doing on ts) 19 that day. Or I don’t even recall everything 20 that happened during the cours 21 You know to and try and -. No Ww 24 for at that - EFTA00061448

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LIMITED OFFICIAL USE 19 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 around that time though, what would you typically be working on aside from the daily activity report and lieutenant’s log? ee : It would be - I would be filling overtime. I would be -. There were a number of things that I could have been doing. I could have been talking to staff or somebody on the phone about something that was going on. It could have been anything. It could have been anything. ee: Okay. This is the daily activities report and lieutenant’s log from August 10th and August llth. So these are the ones that we just discussed that were in those emails. If you can flip to the actual lieutenant’s log. Would you during your shift be reviewing the lieutenant’s log and be constantly filling it out as well as the, you know, what happened prior to your shift? wouldn’t necessarily -. I have to look at what occurred prior to my shift unless -. Usually - When I did that, in order to fill this out - the daily activity report. In order to do this, sometimes I would reference the EFTA00061449

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LIMITED OFFICIAL USE 20 1 lieutenant report if I didn’t get a pass down 2 or something like that just to make sure that 3 the information that I felt should be included 4 in this should be documented. But as far as to 5 just look at the lieutenant’s log prior to me 6 arriving for - if I wasn’t looking for 7 something. Yeah. 8 ee : So the only time you 9 really reviewed the lieutenant’s log is if like 10 you need to go back and look for things? 2 If I wanted to look at the information to see 3 if there was something that they documented 4 that they didn’t tell me prior to them leaving 15 and shift change or something like that. 16 a : And did you - would you 7 typically, if you’re going back and reviewing 8 the lieutenant’s logs from the previous shifts, 9 would you modify those as well? 21 Ee: You don’t ever do that? 23 HE: 81) right. 24 wouldn’t have gone back and modified like a, 25 you know, August 9th that night watch or the EFTA00061450

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LIMITED OFFICIAL USE 21 N w ~] ive) day watch. ee : If there was something that occurred between 10:00 and 12:00, since the shift officially ended at 12:00. Like the count or something like that. would put that in. But that never - I don’t even remember when that would have occurred. I mean that was rare if any that that would occur. Now would you be authorized though to make changes to the lieutenant’s logs for the shift -? That’s not making changes. That’s adding stuff to it. No, I’m saying prior to. So you came on at 10:00 p.m., so going to the 4:10 p.m. are you allowed to -? And I’m asking this as a genuine question. Are you allowed to make modifications or changes to the lieutenant’s logs prior to when you came on board? considered a modification or a change. That would be additional information that occurred during that time to the log. EFTA00061451

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LIMITED ies) w fos) ive) oo OFFICIAL USE 22 You know. There were times when I would go in and put the time that was the count cleared or something to that ay. What about the count numbers or things like happened. If an inmate left or something like need to be changed in order for the information to be accurate. Yeah. I mean if something like that would have occurred. But like I said, there was really don’t remember offhand this late in - at this time - an instance would have to change that. w Oo on (e) Oo c KK ) ie] fu br bh i) EFTA00061452

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LIMITED Ww oO wo fea] oo 19 t rar No KK OFFICIAL USE months So that’s about. talking pointing to on this like Friday 2019, all th different count have 1e back and r count numbers? a ta rh o a ct 1 io) somethin inmate that was in R&D wouldn’t yur interview in that what I’m where I’m , Aug numbers. It depends on what it ha EFTA00061453

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LIMITED OFFIC 1 the institution count. The count would have oO ie) | | in R&D. institution c¢ The institution 13 count would still remain the same. 15 on 16 that we have to make 17 to his assignment 18 _ Well it would 20 changed with what I’m pointing to is the SHU unt. EFTA00061454

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LIMITED OFFICIAL USE 25 1 South. Okay. Okay. ut the SHU count. Ww | w | Okay. That would 5 have -. It would have changed the -. It would 6 have changed the SHU count if it hadn’t have been changed previously. fe) So then would you recall wo if you went in and actually made these changes 0 to make this accurate? I mean if it was t = 2 wrong. I probably did. Offhand, I can’t tell 3 you if I actually went in there and changed it 4 from what it previously was. Because I don’t 15 know - sitting here today, I couldn’t tell you 16 what the count was on that day. J Okay. Do you remember if 8 you went in here and there’s a - a line in here 9 - let me see - earlier in the day. Let me just 20 highlight some things so you don’t have to find 21 it. Okay. So we can just go through this. I 22 highlighted them so you don’t have to be 23 searching. Do you know if you made this 24 addition or change with regard to || being 25 pre-removed. So it was at 8:38 a.m. || to EFTA00061455

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LIMITED OFFICIAL USE 26 (D -remove? 1 pr why I would be doing that. 4 Ee : No, you wouldn’t have ive) 5 added that pre-remove 6 8 wo ive) 14 did it. It’s on the day watch ros 15 couldn’t sit here and an ho o s to who made that change. t o wu oo You wouldn’t have done that? its) yen know who EFTA00061456

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LIMITED ies) w fos) ite) ive) oo OFFICIAL USE 27 the people who were assigned that day abo t that because -- i) -- I would only be that in there probably would have lieutenant for the been working when it’s their roster. But quite honestly, I couldn’t tell a : Yeah-yeah-yeah. I know. and I’m not asking - I’m asking you who would who did it. I really can’t. be responsible. I was asking first if did it 1a A aid you didn’t. you s wu EFTA00061457

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LIMITED oO wo ive) fea] oo wo OFFICIAL USE 28 watch is responsible for their rosters. Evening watch is res wn lieutenant rosters. And morning watch i What | was the inmate that -old us about from i. ES: don’t know if 1 did =>d him in R&D, right? in R&D. He was already in R&D. EFTA00061458

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LIMITED ho ho ho No No w wo fea] co ite) ies) OFFICIAL USE wasn’t like he was in there unattended. Ee : No-no-no. in the SHU up until you made the you told us about after midnight. how the inmate was to be counted I think it was. And I didn’t know that the inmate was in I was like well let me get a little bit more information on what’s going on. You be - it could have @ a Oo a Qo EFTA00061459

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LIMITED ies) w fos) wo ive) oo OFFICIAL USE 30 been a new commit in effect that was going placed in the unit or something like that. help you kind of recollect what we talked about. Here’s the daily log. And on the third So here’s the PY one. It shows that - yeah, he was - this is when - and I believe re the one who told us that you did this. But on 8/10/2019, in R&D. So ee: And you had mentioned before that this is during the count, you realized that the count was off, so you had to and place him in R&D. Yes. Or at some point during when you did EFTA00061460

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LIMITED OFFICIAL USE 31 Ww w ~] ive) your shift did you - or after your shift - just in general - did you make the additions to | with - up here - | being on dry cell and R&D. And then here fF being placed on dry cell from i. did that. ee : Is that something you would have done? Ee : It depends on what was already in the log. I don’t -. I don’t know. I don’t. I mean -. It would have depended on what was in log. I don’t even know if I went back to the log to see what was reflected in the log. Because as long as I made the change on my shift, I don’t know -. I mean I don’t mess with people’s logs. So as long as I make the change on my shift and made sure that it reflected correctly on my shift, I can’t see going beck looking at what somebody else wrote on their sheet. GS: kay. So the reason why we think maybe you did - and we’re just asking if it was you who may have did it - because if you notice, when you came on the end of your EFTA00061461

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LIMITED oO wo oO from that EFTA00061462

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LIMITED ies) w oO fos) wo 3 3 OFFICIAL US rst WW it’s going into August 10th. So I 11:59. But on this it count 10:43 p.m. - 72. b i) caus 0) fu 2t 12:00 when I came in, that was the count that was noted. | ti‘ ‘és -- but these counts also yn the count slip in the El wa n 3, but someone must have ee : Okay. I don’t know if I did that. yne back and changed it to 72. you would have done? ust trying to figure out why are these numbers not showing that. Because like I said, I’m concerned about what’s on my roster. If my roster reflects would I in turn go back and day’s count to 7 That “ 3 ral] a oO w EFTA00061463

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LIMITED OFFICIAL USE 34 ee : Well that’s what we’re 2 trying to figure out because -- : : okey, well 1 -. 4 ee : -- these counts aren’t matching up with what the Els were saying or w 6 what the counts slips J] Oo — wu te well I can’t 8 help you with that. 9 MS: so we're just - since 10 you’re the one who figured out that [RR - 11 he was being counted in the SHU up until this 12 point. He was - according to this roster, this 3 lieutenant log, at 3:15, he was moved. Well he 14 Was never moved on any of the count slips or 15 any of the Els or any of that. He was always 16 being counted in the SHU. Although, the 17 lieutenant’s log is showing that he wasn’t. So 8 the lieutenant logs are saying one thing but 9 the El and the count slips are saying something 20 different. So we’re trying to figure out who 21 went back and changed these numbers? Who went 22 back and made these additions. The only 23 logical explanation would be since you’re the 24 one who actually coded him from the SHU to R&D, 25 the thought is, oh you must have. You must EFTA00061464

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LIMITED ies) w oO fos) wo 3 3 OFFICIAL USE Ww have went bac came to that conclusion that it w and corrected everything. me when -. he’s completely - » Okay, sorry. I didn’t want to interrupt you. When what? why would I go ba shift -- you started - and change their - The 10:00 mean —-. changed what you wrote? discovered it. You have down to that 72 number dc to 72. These numl never showed 73. It said 72. EFTA00061465

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LIMITED ies) w fos) wo ive) fea] oo OFFICIAL USE Wo fen) to ecause this is what if] its] he had - 72. That is what he had. He had 2 and before I came on duty. He had Here’s the 10:00 p.m. count - 73. And this was - you were there Eee : The 10:00 p.m. count s already in progress by the time I get there. ee : A lot of the times. is when it was cleared. And on the lieutenant’s log, the 10:43 p.m. clear you, I wasn’t even aware that this dude was in there was We have - on this 10:00 p.m. count, you notice on all the count slips, EFTA00061466

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LIMITED OFFIC RA. oO 10 way 15 16 a count slip. It shows R And 17 we have a || count slip that says 73 plus 18 _ 21 think it maybe was suppo And we’re not sure. 24 a count slip 25 so if all of EFTA00061467

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LIMITED OFFICIAL USE ies) w ~] wo i=) 11 ive) Wo o count slips are crossed off. These count slips are not. So the R&D count slip is not crossed Fh off. The SHU count slip is not crossed of When we talked to the a. who says - doing the count slip, who was doing the count, = fu i) he said this -. It says 95 plus one. And this 3 plus one, would never have -. He would have never written that without the approval of the ops lieutenant if he actually wrote that. Ee : Okay. Well you probably should ask him what ops lieutenant gave him the approval to do that. ops lieutenant on duty. ee : I did not find out anything about this inmate being in R&D until the 12:00 count. ee: Okay. So at 12:00, we’ve talked to the people that were in the SHU. And they said they never had such a conversation with you. So the thought is maybe you had the conversation at 10:00. ee : No. Look, no. No. ee : We’re just trying to put the pieces together because it doesn’t make EFTA00061468

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LIMITED wo 3 OFFI CIAL USE 39 sen n Ph Fh going to put pieces use I didn’t find I think it was a. | was EFTA00061469

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LIMITED ies) w fos) ive) oo OFFICIAL USE the changes and make sure that Well this El was printed out at where’s the MA Quarter History? printed out the exact same minu oO ie. change was made. co 40 unt, the El is that the things, how is the El printed out at 00:35 and the quarter - the change made from him going from the SHU to R&D also at effected, we have to run a new th e count is El. then ee : So you were able to that figure all that out rather than quickly during this count be able to like And the EFTA00061470

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LIMITED OFFICIAL USE 41 10 11 12 13 14 16 17 18 19 20 21 22 23 24 theory that we have is that - and I don’t know that there’s anything wrong with this. We just need to put the pieces together. ee : I can’t help you put the pieces together because -- Ee: Do you know -? ee : -- what I’m telling you is that at 12:00, when I was taking the 12:00 count, that was the count that I always took for the most part, because I was busy doing overtime trying to fill overtime and stuff like that when I first got in. So the first count that I would have taken was the 12:00 count. That’s when it came to my attention. That’s when I happened - after I figured out what was going on - that’s when we did the change in the computer so that it would reflect the accurate count. I would never have someone turn in a count slip with seven plus something on there. That’s not even how the count slip - that I’m accustomed to doing - is done. ee : Okay, so do you mean for this 10:00 p.m. count, you know nothing about this 9S plus one or this 73 plus one? EFTA00061471

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LIMITED oO Oo OFFICIAL USE 42 -- to take the 12:00 n working at 10:00 p.m. the individuals who punt. EFTA00061472

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LIMITED OFFICIAL USE 43 ies) w ~] wo 10 11 ive) come in until 12:00 a.m. | does not recall ever having a conversation with you. ee : Okay, well that doesn’t surprise me. I mean FY has witnessed a traumatic event. I mean - and you’re talking about a timeframe that was several years ago. I’m telling you what I just said. Now if the pieces doesn’t fit or if you’ re speculating somehow that, you know, I did all of this, then I don’t know what I can do to change your mind. ee: No-no-no. ee : I’m telling you. I’m telling you. You asked me a question. I’ve given you an answer. And I would prefer to ove on. | ti‘ aiésll Okay. So to wrap it up then, what you are saying is you had no involvement with the 10:00 p.m. count? Ee: )= did not having nothing to do with the 10:00 p.m. count as far as the count slips and in reference to this inmate being in R&D. Because I wasn’t even aware that we had an inmate in R&D. And most especially to the point whereby he wasn’t EFTA00061473

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LIMITED OFFICIAL USE 44 w ~] 10 11 12 18 19 20 already moved or whatever. Changes to his status hadn’t even been moved. ee : And do you know if || or anyone else would have gone back to - after you made the discovery - would they have gone back and wrote in this 9S plus one? MEN: this -. RE: «2 why would 1 even -? If I didn’t know it was happening, why would I have any reason to believe that? ee: Well the reason why I’m asking is obviously because like I showed you before on the daily activities lieutenant - or the daily log - the lieutenant’s log - it shows 73 when you - your shift technically started on paper at 12:00. But at 10:00 p.m. it showed 72. But again, at 10:00 p.m. we got a count slip that says 73 and now plus one. And we have an El that says 73. So someone made changes. So someone made changes. We’re just trying to figure out who made these changes. Because you’re the only one that would have access to the lieutenant’s log. And you didn’t send out the lieutenant’s log -- EFTA00061474

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LIMITED oO WwW oO oo OFFICIAL USE 45 person -- who what we were probably working and lieutenant’s log. out this day until now and make 0 EFTA00061475

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LIMITED OFFICIAL USE an 0] mail where you sent it out. So we know the 2 exact lieutenant’s log 3 because we have them. you Between the wi 6 time that I sent those logs out and the next day, so anybody who have access to those to fos) c bh i) =] ct @ s fu =] rt w bt ° Q Qa Oo c ~ jon a fu o 3 fa Q o 0 a wu .Q oO if) oO ct 3 ® ] i=) a : Isn’t it true they’re on 1 a shared folder that only the lieutenants have 2 access to? 3 ee : Anyone who had - 4 everyone who has access to those lieutenant’s 5 logs, at any point in time can go in there and r oO 3 wu i oO Q changes to it. 7 | ti‘ aiésll So on the morning watch, lieutenant’s log? 20 in the building. 21 ee : So you’re the high 22 ranking official as the ops lieutenant in the fos) 5 Oo ion a 7] wu e) ie] o mn n ct Oo rt a @ 23 building, right? 25 all - I mean we all know that I have access EFTA00061476

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LIMITED OFFICIAL USE 47 w 1 the rosters. ut I’m not the only person who 2 have access to the lieutenant’s logs. There ies) wu K o ie) other people in this building who have 4 access to the lieutenant’s ac nt that has 5 the lieutenant’s log. 6 Ee: But the captain wasn’t 7 here in the morning - on the morning watch. 9 changes was even made on morning watch? i=) You sent out tt email at R wo =] a Nm oO pat fu ke K oO Cc ct fu BH ny b- =] Q ive) about the day before the day watch and all of 4 this other stuff. §& 5 ee : No, I’m talking a on 16 August 10, 2019, at 9:26 a.m., where it was 7 sent out at like almost closer to 5:00 8 a.m. the days before, and you even said, I was 9 probably working on the activities report and 20 the daily lieutenant’s log. 21 ee : My lieutenant’s log. 22 I: «Right. So the thing that 23 you sent out was - sent out both of these. 24 a5 279 EFTA00061477

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LIMITED OFFICIAL USE 48 N w ~] ive) the first day. ee : Correct. But the big thing that was discovered on your shift had to do with a . fF was always - the whole day on August 9th - including the 10:00 p.m. count - was still keyed into the SHU. He was never keyed out of the SHU and placed into R&D even though we have R&D count slips. There’s nothing on the Els that say anything about R&D - about him being in R&D - it’s only that he’s ever been in the SHU. So we’re just trying to figure out. You sent this out. Your email - it was your email. You’re the one who sent this out. So the fact that you were working on it and you sent it out, you’re the only one there that had access to it from 10:00 p.m. to 6:00 a.m. that we are aware of. Who else could have made those changes? ee : What changes - what changes are you talking about? Ee: We’re asking about, like I said, this addition saying fF was on dry cell at - you must have done this one at EFTA00061478

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LIMITED oO ~ wo oO co wo t rar No No OFFICIAL USE 49 ee : And the -. ee : Again, look. This is -- ee : No, I’m not. No. igust 10th. i) | 9th. And then 12 hav e like I was going to ike you made -. I thought wanted to say p.m., FY was actually placed on dry cell from on dry cell So what would ren’t in EFTA00061479

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LIMITED No No No ies) w fos) ive) oo its) iat) OFFICIAL USE the runs from previou have to do with me? right. They’re wrong wrong on the count sli You don’t going to ch numbers show how many Although the El - ins count slips show that aren’t’ was in -. I didn’t know. I didn’ so somebody had to -. in R&D. was sly? all the numbers 7, what do that The numbers are actually on the E2 and they’re God. eck. So these were actually in count - and the titution he was in SHU. So the only found person who out SHU and was in R&D I didn’t find found out in SHU t. He was in No, he wasn’t in EFTA00061480

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LIMITED OFFICIAL USE wo ray 1 before he was in R&D. So. How did he get to 2 R&D? I guess I put him in R&D too? And then I 3 had somebody call me and tell me he was in R&D? 4 Ee : No, that’s what -. The 5 question was going to be next, how did you 6 learn that he was actually placed in the SHU 7 from R&D. I mean you were included on an email 8 that was sent from the SHU OIC to the previous 9 ops lieutenant stating what happened. So that 10 would be - that was going to be a follow-up 11 question. Is this how you learned? So here is 2 an email. It’s from fF and it’s to 3 - you’re one of the individuals - and it 15 Leonardo, Friday, August 9, 2019, at 3:11 p.m. 16 So this is the assumption was that you probably 7 went back to your emails when you were doing 8 the verification. And said oh, this must have 9 been when it happened. 23 lieutenant email. It has all of the 24 lieutenants on it. EFTA00061481

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LIMITED ies) w oO fos) wo i=) 3 OFFICIAL USE wi S) SHU to R&D. That was He was in the wrong place. do somehow I was involved. So you can get the inguiring information that I EFTA00061482

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LIMITED ho No i) ie) wo ive) wo Ww wi OFFI CIAL USE 53 with that because I have given you -- answer them directly. So we’re just asking the direct question. Did the numbers on this questions to the best of my ability pertaining So you can either say on? How many know how aling with in and everything that I remember from EFTA00061483

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LIMITED OFFICIAL USE 54 oO 13 15 t o How did you ~] oo 19 ee : That is not an answer. Well I don’t EFTA00061484

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LIMITED oO wo ot) oO oo OFFICIAL USE 55 I don’t know what to sitting here tryi kK k =] ct did I did it. And I can’t do of “I don’t know.” u wu 1) iw) at the beginning of my shift. And since it said 73 at the beginning of my shift - ee : What time did your shift Jo pr EFTA00061485

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LIMITED ies) w oO fos) i=) ive) 15 OFFICIAL USE wi fen) n 10:00 p.m. I just told you that it wasn’t a good Remember? You told me it wasn’t an answer. So I don’t know what answer provided an answer, Ma'am. be Ou an t of my ability based upon what I remember during that time. ke ha to a] =] e 7] oO Qa wn remember at that time, did you m the August 9, 2019 numbers that are listed here Ma'am we can sit here all day. EFTA00061486

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LIMITED OFFIC oO wo oO oo of my shift, which it ion 21 what re on w ld I have to go back ster way from the 95 EFTA00061487

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) uw o ee : Ma'am, what time did you shift on that date? n ct i 5 ct et ie) = K Ee: Okay. So you started at approximately 10:00 p.m. At 10:00 p.m., like we covered, it shows 72. At 12:00 a.m. - and then again at 12:00 a.m. on the - it says 72 and then it ys 73. This all happened during your shift. ee : How do you know that it happened during my shift? That’s -. ee : What I’m saying is you saying that the beginning of your shift it says 73. No, it didn’t. At the beginning of your shift it said 72. | | te 12:00, when I discovered that that inmate was in SHU, the count at that time was 73. There were times at the beginning of my shift I don’t even start my ros i) ter at the beginning of my shift - the lieutenant’s log. The lieutenant’s log is something that I do towards the end of my shift - especially on morning watch because there’s EFTA00061488

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LIMITED OFFICIAL USE 59 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 not a whole lot going on but the count. So there’s not going to be a lot of - a whole lot of entries going on during that time. So simply because you seen an entry at a particular time don’t mean that I’m sitting there looking at the clock at every hour doing an entry into my log. He: «No. §=The thought is - the thought is that like you said you were working from approximately 5:30 a.m. until 7:00 a.m. on your paperwork and then again it sounds like from probably about 8:00 a.m. until you sent out the email at 9:26 a.m. on your paperwork. And we talked about this is the paperwork that you would have been working on. So for approximately three plus hours you may have been working on this. ee : You asked me what type of work do I normally do during the course of my shift. And what paperwork would I have been working on if I was late. And I told you more than likely the daily log, the finishing up my lieutenant’s log or something to that effect. I could have been doing the roster. I could have been doing a bunch of things. I EFTA00061489

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LIMITED OFFICIAL USE 60 w ~] 10 11 12 18 19 20 don’t recall everything that I did verbatim during the course of that night. There was a lot of things going on at that time. ee : And that’s why we covered ahead of time that all of these emails that you sent out previously, they were all sent out way before the 6:30 timeframe with the daily activities log and the lieutenant’s log. don’t stay late every day. I only stay late when I don’t have - when I haven’t had the opportunity to finish -- ee : -- all of my work during my shift. a : So you told us previously that you were relieved at approximately 5:30 a.m. that day. And we have confirmed that. And at 7:00 a.m. you went up to help with feeding. And then at approximately 8:00 a.m., you went back to do other things. And then at approximately 9:30 a.m., you sent this out. So aside from the feeding, if you weren’t working on this, what else would you have been working on? EFTA00061490

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LIMITED oO wo ive) fea] oo wo OFFICIAL USE 61 don’t remember. That is an actual the next question is did you change on Aut 9th the numbers in the SHU to refle you made the additi ed on dry cell from adding this addition at 3:15 p.m. being pla ' o ou a ket fe) c fw 5 uu Cc n ct bh o wu 0 so I can know what it is EFTA00061491

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LIMITED OFFICIAL USE 62 10 11 12 13 14 16 17 18 19 20 21 22 23 24 remember. So on this August 9, 2019, on the lieutenant’s log it shows that at 8:38 a.m. | went from i to pre-remove. And then here’s the daily log which says again | | pre-removed and it shows 8/9/2019 at 0838. What does pre-remove mean? ee : That is something - that’s an R&D thing. You’ll have to ask R&D what that means. If the count change, that meant that he was removed from this institution. ee: All right. So you’re saying that if you see something listed as pre- remove on the lieutenant’s log - it literally says it on the lieutenant’s log, so I would think a lieutenant would know what that means. And the count did change. But do you know what pre-remove means being that it’s on the lieutenant’s log? HE: §= Sst because it’s on the lieutenant’s log and because it says pre- remove, doesn’t mean that we know the exact meaning of pre-remove. That is an R&D term that they use when they are changing the inmate’s status. EFTA00061492

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LIMITED ho ho ho No No ive) w wo Oo) co ite) ies) OFFICIAL USE bo you know system. that to It mean institution. And not com ing b EFTA00061493

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LIMITED OFFICIAL USE 64 w ~] 10 11 12 18 19 20 and we check - and when we check the status - the movements - he could be back on there. So it’s not definitive that when he leaves, that he’s definitely for certain not coming back. Ee : So a pre-remove actually leaves the institution, to your understanding, could actually come back? ee : If something changes, for some particular reason, he could come back. You would have to get with R&D. | ti‘ ‘és So with getting with R&D, we have these emails from the U.S. Marshals Service on August 8, 2019. One at 10:33 a.m. and the next one at 3:36 p.m. And they all talk about a prisoner production. All the lieutenants were sent the second one that was sent at 3:36 p.m. The initial email that was sent at 10:33 p.m. specifically says, “the following prisoners are to be transferred.” The second name down says ,. HJ. 4nd the one that you had received for lieutenants is a prisoner schedule report. It n oF) a y ‘ COR a. transfer within. It says Judge MCC to GEO. Do you know what GEO is, G-E-O? EFTA00061494

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LIMITED No No No ies) w fos) ive) oo its) iat) OFFICIAL USE 65 private institution. ee : Correct. So from these documents if you want to take look so that wu I’m not showing you them from a few feet away. that he was oO O oO U ct 7 w + Za oO te] he Oo c ct oO ity o transferred - he was not coming back? this didn’t even occur on my shift. | tti‘iéS No, that was the day before. It said that that’s where he was going. You were on the email. And then on the lieutenant’s log for August 9th when you st i rted - you worked on August 9th in the morning as well as August 9th in You know up until 6:00 a.m. on August 9th, and then started a in at 10:00 p.m. on August 9th. was pre-remove —- |g wu g It shows that h i) was pre-remove? EFTA00061495

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LIMITED OFFICIAL USE fo) fen) 1 got off at 6:00, that period after I got off. 2 ee : Yes, it did. It happened but then you came back on later that day. ies) w An =] ion = w uw t ue] fo ct oO b =] i) 8 ee : And Epstein was required 9 to have a cellmate. So if the lieutenant’s log 10 says he’s pre-remove and you have emails 11 showing that he was transferred, how come - as 2 the ops lieutenant - you didn’t have Epstein 3 assigned a new cellmate? 15 no knowledge of who Epstein’s cellmate was. 16 And I had no knowledge that Epstein was even 7 supposed to have a cellie. So -. 8 ee: So those two things we 9 were told by everyone that that is not an 20 acceptable answer. You were involved in the 21 July 23, 2019 incident where he tried to kill 22 himself. And everyone - especially the 23 lieutenants - know that cellmates that try to 24 kill themselves have to have -. Inmates that 25 try to kill themselves have to have cellmates. EFTA00061496

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LIMITED No No No 5 fe) 4 a wu rt ~ 1) ies) w fos) ive) oo its) iat) OFFICIAL USE 67 not true. W a fu crt nN not tru training. It’s reviewed in quarterly SHU knowledge. attempts to commit a : And then can you -? ee : They do not have an order. There is no such thing as a restrictive r saying that an inmate coming off of suicide watch is not sup ed to have a cellie. all have cellmates. here is nothing in writing. Nobody giv what you’re | EFTA00061497

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LIMITED oO wo oO oo OFFIC ing in writing s of suicide er done in said. writing. that an inmate - say writing. Ww Well the 1 the Saw But you ju writir You sa But it was You when No-no-no. ast time we st said id that - done in Isn’t there - EFTA00061498

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LIMITED OFFICIAL USE 69 1 don’t inmates have restrictive orders placed on 2 them if you go into like one of the BC 3 databases saying this inmate needs to be celled 4 alone because they are a threat or something. 5 nts them from being able to h a 6 8 ything like that. 9 | tti‘iéS Okay. you’re not 10 aware of inma that aren’t allowed to have 11 other cellmates? 2 ee : I have never seen a 3 memo or email or something like that saying 4 inmates are not supposed to have a cellie or 5 t fon) c tan w ke And that’s fine. But you must know, as a oo 9 lieutenant who has been, you know, here for a 20 long time, and worked for the BOP for a long 21 time, that inmates that attempt to commit 22 suicide - when they come off of suicide watch 23 they’ re supposed to have a cellmate. 24 ee : That is not 25 automatic That has never been automatic EFTA00061499

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LIMITED OFFICIAL USE 70 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Those - if an inmate is definitively supposed to have a cellie, psychology would let us know or someone would let us know. Who’s aware of that information. ee : Psychology sent you an email. ee : That is - that is never - like standard procedure. Inmates go - inmates that come off of suicide watch are often - most especially here - put in a cell by themselves. I mean that’s not something - the psychologists would - psychology services. They would be the ones who determine whether or not - based upon their interactions with that inmate or what they diagnose as his - what you know and dealing with that inmate and his mental needs, whether or not that particular inmate is supposed to have a cellie or not. That is not something that’s understood or something that we should know automatically. That’s not true. That is not true. ae: So two things to that. One, psychology did send out an email saying that he was required to have a cellmate. And you did - you were a recipient of that email. EFTA00061500

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LIMITED OFFICIAL USE 71 ive) 4 that come off suicide watch 5 6 not true 8 true? 9 not tri ple that interviewed a So if that was fea] oo wo 20 lieutenant when he left. lieutenant who entered the entr t rar ho No 25 a : But you were - that we EFTA00061501

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LIMITED w wo ive) fea] oo No Ww OFFICIAL USE ie) lieutenant during -- Well no. I just said can’t recall things. So entire shift, that he was - it was less than lieutenant when he did not have a cellmate. SHU lieutenant or You were the last EFTA00061502

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LIMITED OFFICIAL USE 73 1 GS: «that if Epstein killed 2 himself, it happened on y 4 Epstein killed himself if it was on my watch or ur watch. Correct? ies) after I got off. 6 Ee: Right. So the question 7 to you is | | left the w titution. It’s 8 listed on the lieutenant’s log that he’s gone. 9 said that you did a round in the SHU. 10 Why wasn’t Epstein placed with a new cellmate? 2 placed with a new cellm te as soon as the first fu ive) ) 3 one - as soon as the cellmate left? t oO Why when -? 7 | ti‘ aiésll We asked the same to everybody that’s been involved with Les] Q c o n rt k 3) 5 9 this. And we’re -? Why would -? 22 something that’s so critical. No ox) knew it, if this was standard 24 would psychology have to send out an email 25 period? To let everybody know that he needed a EFTA00061503

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LIMITED OFFICIAL USE 74 1 cellie if everybody knew it already. 3 ee : If it was standard 4 procedure, and there was policy, and everybody 5 knew it, then we shouldn’t even be having this 6 - sitting here. Why was Jeffrey Epstein placed 7 in SHU? 8 ee : So you’re the only person 9 that I know of that is saying that you didn’t 10 know he was supposed to have a cellmate. 2 the only person that’s saying that, then 3 Jeffrey Epstein - if having a cellie - which we 4 already know from his previous attempted 15 suicide - would not have prevented him from 16 trying to kill himself. 7 | ti‘ aiésll Well that did prevent him 8 from killing himself. The - his cellmate is 9 the one who notified guards that he was 20 attempting to harm himself. 21 ee : But he still tried to 22 kill himself. That didn’t stop him from doing 23 that. The fact that he had a cellie. Did that 24 stop him from trying to do it then. 25 ee: He tried but wasn’t EFTA00061504

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LIMITED ies) w fos) wo ive) co OFFICIAL USE 75 ssful because his had a cellmate, correct? everybody knew to have a cellie and it was understoc it was standard would have b i) email because and what ev o 5 ' case, then way before I got here, way before I came on duty, he should have had a cellie. HS: «absolutely agree with one knows it EFTA00061505

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LIMITED ies) w oO wo i=) nN ive) fea] oo wo No N No Wa OFFICIAL USE C from their training experience and everyone knew it because psychology put the placement on it. So the question to you is why didn’t you replace the cellmate? Why didn’t assign -? ein did not have a cellie. I wasn’t aware that Epstein was supposed to have a cellie. either that Epstein didn’t have cellie or that you didn’t know he was required to have a cellie. ee: And as a lieutenant who has worked for the BOP for that long, you’re i] correct. sticking - who actually responded to the July 23, 2019 incident where Epstein attempted harm himself. You’re sticking with you didn’t know he was required to have a cellmate? ee : I did not know that Jeffrey Epstein was required to have a cellie. ee : That was nothing that - no one said anything to me about that. I didn’t see the email from a because if email, she should have followed up. That’s not EFTA00061506

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LIMITED OFFICIAL USE 77 10 11 12 13 14 16 17 18 19 20 21 22 23 24 something that - something of that importance. If you feel as though his life depended on it, I don’t know why you would be taking him off suicide watch anyway. If he had to be guarded around the clock by an inmate, then he should have - he should have been - he should have stayed on watch. Because apparently, that says to me that you’re not secure in the fact that you don’t feel that he’s not capable of committing suicide. So why would you take him off of watch if he needs 24-hour watch? And if that was the case, then why didn’t they put him on Ten South where he would have had cameras on him all day and all night, 24 hours a day. A staff member watching him 24 hours, 7 days a week. I mean you had El Chapo here. El Chapo didn’t commit suicide. They had extra lieutenants on him 24 hours. They had all kinds of extra staff on him 24 hours a day, seven days a week. So -. ee : Sure. And you had mentioned that before. ee : So why wasn’t -? ee : You thought he -. ee : So why wasn’t Epstein EFTA00061507

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) treated - why was he treated any differently. ee : Because those are for SAMS inmates. But that’s a different - that’s a different story. So point being though, you just answered you did not know that he was required to have a cellmate and you also did not know that he didn’t have a cellmate, correct? ee : Jeffrey Epstein was high profile. He was a rich inmate. So that in a lot of ways made him victim to a lot of things. So Ten South would have been the perfect place for him to be. ee : Okay. And I’m not going to argue with that. That’s a great opinion. And that’s duly noted. But the question to this is you - or the answer I believe you provided is you said you did not know that he was required to have a cellmate, correct? Ee: §= tid not know Jeffrey Epstein was required to have a cellie. And I did not know that his cellie had left. ee : I didn’t even know who his cellie was. ~) oo EFTA00061508

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LIMITED ive) oO wo ive) fea] oo OFFICIAL USE 79 ee : And when you did a round in the SHU on August 10th, 2019, did tein’s cell to Ep ther Oo No I did not. And why not? to ause I didn’ rt for me to do was - what was stein that was that? And it wasn’t just for you know? look in his cell without certified that 1ducted a round in ti n't SHU, a round of inmates? on the inmates in EFTA00061509

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LIMITED OFFICIAL USE 80 = ro) Pom wu he So when you 2 certified on -. It says that you certify on 3 August 10th, at 5:21 that you conducted a 4 round in the SHU. What is your understanding - 5 ? So here’s your -. I’m giving you this where 6 it s the Federal Bureau of Prisons of 7 TruIntel Supervisory Rounds. So the start date 8 /2019 and the 8/10/2019. And this, if 9 you’1ll notice, the top here it shows your name. 10 It two rounds here conducted. One 11 was on 8 5:14 a.m. And the other one 2 was 8/10/2019 at 5:21 a.m. Are these entries 3 that you would have made? If you hadn’t made it who w would would have made it. fea] oo 20 rounds in TruIntel? 21 ee : I do make entries 22 into TruIntel concerning the rounds of inmates, 23 that’s correct. 24 | tti‘ésS®@ Okay. And then here is 25 the actual 30-minute round shee on 8/10. Is ct w EFTA00061510

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LIMITED OFFICIAL USE 81 1 this your signature right there? ies) signature. round in the SHU. conducted w wu oO K 0) 1) 8 understanding of these two certifications that 9 you made? What did those - what does that 10 round consist of to went and I visited SHU. 4 instead of conducting a round in SHU? Nm ive) 16 didn’t - I don’t conduct rounds in any unit. I 7 mean I go, I visit with the officers, I sign - 8 I speak with them, make sure that they’re okay. 9 And if something occurs that requires me to go 20 into the range and investigate it, I do. 21 Sometimes if the count was announced. There 22 were random times when I would check the 23 officers’ count. Or I would stand at the gate 24 and stand there while they counted or something 25 like that. But no, there was no - there was no EFTA00061511

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LIMITED ho ho ho No i) ive) w wo fea] oo © Ww OFFICIAL USE - nothing formal make - literally and talking to the - talking thing like that. So are ju aware that other lieutenants do rounds when the - but tt especially the actually a round in the ee: But you do not believe to do that? aid, at the time, now you but wu iad D talking about to do a round now? to do now. EFTA00061512

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LIMITED OFFICIAL USE 83 1 ee : Okay. What about after 2 the - since the Epstein incident on August 3 10th, 2019, at any time afterwards did they say 4 that you had to start doing rounds of the 5 inmates when you conducted rounds? 7 a : So they’ve never told you 10 a : And prior to that, you’ve 11 never done round With inmates? 2 EE: |= ike I just said. If 3 there was something - if there was a reason for 4 me to go around and make rounds or to go into a 15 particular range in SHU, sure. At night when 16 the inmates are sleeping. When the inmates - 7 when it’s quiet and it’s nice and quiet and 8 there’s nothing going on or the officers aren’t 9 indicating to me that they’re having an issue 20 or a problem, no. There’s no - there was no 21 reason for me to enter the range and go into 22 the ranges. I mean I’m confident that my 23 officers that are on the pos are doing their 24 jobs effectively. ee: Now is that a confidence EFTA00061513

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LIMITED OFFICIAL USE 84 1 that was misplaced then? Since people were not 2 doing rounds or counts during your - when you ies) were the ops lieutenant? +] ay 5 that it was misplaced, but I know how tired the 6 staff members were at that time. So anything 7 could have happened wo Hed staff member could 10 have died during that time. I’m not going 11 to say it was misplaced. These were not crappy 2 officers Wa ro) ioe i) he 15 but she was - she spent time with seasoned 16 staff and officers that she knew were good at 7 what they did to get trained. Officer FY 8 was a good officer. Officer | stood by 9 Epstein’s door the whole night. Stood there. 20 He didn’t even take a seat. He had a seat 21 right there and could ha observed him through 22 the window. He stayed in his cell the night 23 that he attempted suicide the whole night. 24 | tti‘ésS®@ You mean on July 23rd, 25 2019 EFTA00061514

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LIMITED ies) w fos) ite) ive) oo © No N No Ww OFFICIAL USE 85 Suicide, yes. worked numerous They understanding was you weren’t supposed to do rounds of the inmates. wasn’t a requ around to each individ - and check on the inmates -- pre dure or something like that. Or told. ee : Now this round sheet that fill out and which Where is that EFTA00061515

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LIMITED ies) w fos) wo WwW oo OFFICIAL USE a located? other plac it’s in the rang When it’s in the range, you know you g to go up in the range and physically sign it. So that encourages you to make rounds in SHU. was an walked past the cells. choice. lieutenants though, correct? They also have to sign them tt round sheet? EFTA00061516

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LIMITED ho ho ho No i) ive) w wo fea] oo © Ww OFFICIAL USE 87 don’t bring the count - those ee: But weren’t they supposed though? to be on the rar I was pulled down from my them in the range. EFTA00061517

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LIMITED Ww w wo WwW fea] oo © OFFICIAL USE 88 you not working dme if I left - if I walked going to put a case me and pull me off my post. And that’s what he did. ee: How long ago did that ed I think from August 10th, 2019 to April still working, correct, as a -- EFTA00061518

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LIMITED OFFICIAL USE 89 10 11 12 13 14 16 17 18 19 20 21 22 23 24 being in the range. ee : All right. So to your recollection, those were always on the desk and MCC is just different than all the other BOP institutions? ee : I mean you putting it -. That’s just the way that they did things here. I mean you making it sound like, you know, out of all places I have been this place does things differently. It does. And it does in a lot of ways which is why we’re in the predicament that we’re in. Because there are a lot of things that are done here. And if you don’t work here, I guess it’s hard for you to believe. But there are a lot of people here who can attest to that, most especially people who have been at other institutions and have come here. There are a lot of things that they do here that they don’t do at other places. HE: «kay. What’s the hotlist? ee : The hotlist is like a list of inmates that have like special circumstances and stuff like that. I haven’t seen a hotlist in a while though. EFTA00061519

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LIMITED oO wo ive) fea] oo wo OFFICIAL USE 90 ee : On August 9th and 10th or list in + a D i) rt wu Hh hh hotlist? wo s cellmate | was listed as roximately ongings, that’s an indica EFTA00061520

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LIMITED OFFICIAL USE 91 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that he’s leaving. | ti‘ iésl Yeah, I know. He was WAB. He left in the morning of August 9, 2010 - sorry, August 9th, 2019 as WAB. And then he was listed as pre-remove on all the documentation. So they removed him from the institution. What should have happened? If he was required to have a cellmate? If the SHU OIC brings him down to R&D as a WAB. So he’s got all of his belongings. What should have happened if it is known that Epstein’s cellmate, ia. and everybody knows that Epstein - and I’m not talking about you - everybody that brings him down knows that Epstein is required to have a cellmate. What should have happened at the time that the OIC of the SHU brought || - Epstein cellmate - down to R&D as a WAB? ee : First, they should have ensured that he was actually leaving and never coming back. If they were aware of that information. And they should have put forth that action to notify someone that his cellmate was leaving. If they knew that he was supposed to have a cellie and they knew for a fact that EFTA00061521

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LIMITED OFFICIAL USE 92 1 this inmate was leaving and not coming back. 2 ee : Okay. So when you said 3 ensure that he’s leaving and not coming back. 4 He’s listed as WAB. Doesn’t that indicate that 5 he’s leaving and not coming back? 6 ee : That indicates that 7 he’s leaving. He’s scheduled to leave. You 8 can have - something can go wrong and the 9 inmate could come back. It doesn’t happen 10 often but there are inmates who have been 11 placed on pre-remove and a lot of things that 2 somehow has ended up coming back - have shows 3 back up on the roster and placed back in the 4 housing unit or somewhere for whatever reason. 15 I don’t question R&D as to why that happened. 16 If there’s an inmate that shows -. 7 | ti‘ aiésll Well R&D said he was 8 gone. R&D clearly says no, he was listed as -- 20 ss 2 opre-removed. He was 21 not coming back. 23 ee : So my question is the OIC 24 or SHU brings him down to R&D as a WAB. R&D is 25 already saying yeah, this guy’s gone. He’s EFTA00061522

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wo LIMITED OFFICIAL USE 1 being transferred. You saw the documentation. It shows he’s ies) t institution. 4 ee : That don’t mean that had that disc w ght 6 them down. That fos) wo him down know what a WAB Ww wu mn c + an w ' = o i) elongings. sking them then. 16 a : No-no-no. I’m just 17 asking as an ops lieutenant yund that time 18 period. done? 19 20 No N No Ww 24 not - I’m not saying that it’s 25 not 2n thinking in that manner EFTA00061523

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LIMITED OFFICIAL USE 94 1 absolutely nothing to do with me. I don’t know 2 what’s in the guy’s head. I don’t know what 3 he’s thinking. I don’t know what he knows. I 4 don’t know what information he’s aware of. I 5 mean you would have to pose that question to 6 him. Or her. And let - have them give you an 7 answer. I mean. 8 ee : Okay. We can move on. 9 So we already talked about the count slips. So 10 you only were involved with the 12:00 a.m. 11 count on August 10, 2019? me that? ive) 15 going in order now. I’m just saying you 16 weren’t involved with any other counts? And 7 we’re not going to get back into it. I just 8 want to make sure that I’m asking you that this 9 is the only count that you were actually 20 involved with. 21 ee : The 12:00 count is 22 the count that I took. 23 ee : Okay. And you weren’t 24 involved with the other counts? EFTA00061524

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LIMITED 3 OFFI wo wi CIAL USE know what on morning ing with | about ertain it So the last time, she EFTA00061525

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LIMITED Ww w oO wo 3 23 OFFICIAL US w a 1h] ctly. All right. almost certain it was ma but you’re not certain it was a: Is that what I don’t think it a n I remember the was about there being an inmate in R&D and I think he mentioned how the were number that was on the - and then the o how many - period. How 0) i] many inmates are supposed to be up there? Because I wanted to make sure that we knew what s. And this other he doing Things to that EFTA00061526

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LIMITED OFFICIAL USE 97 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 effect. But I also wanted to go check and make sure myself so I could see what was actually going on. So I would know what was - what the situation and the circumstances were. ee : So you physically went to R&D and saw? ee : At some point. I think after the - I think I went - after the count, I think I called. I don’t know. When I made - because I know after the count I went up to R&D and physical saw the guy up there, talked to the officer, saw that he was on - I think he was on dry cell or something to that effect. And but I think before that we made phone calls to make sure that the inmate - because I want to say one of the - somebody in SHU knew. I mean somebody in control was aware that the inmate was in R&D as well. So once we verified that the inmate was in R&D, he was in dry cell, then we can move forward and make the change because if he was on dry cell in R&D, then that’s where he was. That was the decision that somebody had made and because I don’t even think there was any room. There was any room anywhere for him to go. I don’t think EFTA00061527

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LIMITED ho ho ho No i) ive) w wo fea] oo its) Ww OFFICIAL USE wo on] was any room in SHU for him to be on dry All right. And then - re going to go back your handwritir Any of it for what I’m Ee : So nothing. Even the ws. to see about this. He said he couldn’t remember if the plus were his or EFTA00061528

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LIMITED ies) w oO wo i=) Nm ive) fea] oo OFFICIAL USE ite] ite) someone else’s. But he said that the ops lieutenant is the one that I would have gotten the approval to do this with. He was confident Well that don’t mean that I was that ops lieutenant. lieutenant on duty. ME: 2st because 1 was the only ops lieutenant on duty, those counts are verified prior to them being conducted. ee: Well your name was mentioned. ee : Yeah, but I wasn’t the lieutenant that was here when the inmate was placed in R&D. | ti‘ aiésll But you were the lieutenant here when these counts slips were collected and reviewed. | )= Because the count is [ going to go on irregardles i) c]). You know unless something is going on in the institution and we call control and hey, hold off on y the count until I call you back or atever. Until we do some type of instruction to hold EFTA00061529

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LIMITED oO wo ot) oO oo 22 OFFICIAL USE 100 off on the count. The continue because those be done. That’s - proval. If that was the case, why would I bother to bother to had to If that’s the + why would I changing it at EFTA00061530

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LIMITED OFFICIAL USE 101 ies) w ~] wo 10 11 ive) 7) rt theory was hat you actually figured it out at 10:00 and just forgot to make the change. And that’s why you were table to -- Ee : -- you were table to fix it so quickly. wrong because that’s not even how -. Why would I do that? Why would 1? If that was - if that was -. | ti‘ ‘és Well because | doesn’t - says he never had a conversation with you. So we’re thinking, oh well on the 10:00 count, there’s actually these plus one numbers. Maybe she actually had the conversation with a . Does that logic make sense to you where I’m going with that? ee : No, that doesn’t make sense to me where you’re going with that. Because you’re making an assumption. And you’re trying to put together a puzzle that’s not even fitting. If I went through the trouble of finding out all this information on this inmate so that I could adequately place him right. Why would I forget - why would I EFTA00061531

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LIMITED OFFICIAL USE 102 1 wait until - why would I say okay I’m not going 2 to do this right now. The time of the count is 3 the time of the count. And whatever happens at 4 the time of that count is supposed to be 5 reflected So why would I let - why would I mething. What 8 ee : Exactly. That’s what we're trying to figure out. wo 11 to call somebody else in. WwW un wu = oO wi ie) Oo ~ oO rt Oo | wu =] Q un J 0) “i wu im oF t wi I mean you can go 16 back to and talk to however and tell them 7 whatever. You know? What I’m telling 8 there would be no reason for me to wait for two 9 hours or three hours before making a change to 20 something and to have them void. Just 21 okay, well you know, go ahead, and do that. 22 That to me -. 23 ee : Yeah, but like you said, 24 you get busy though. EFTA00061532

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LIMITED ive) w wo ive) fea] oo No Ww OFFICIAL USE 103 If all it was the activities report and the lieutenant’s log 10th was becau is - why ee: Not everything is on you. You’re just taking it that way. a @ ning watch. The 10:00 count is the responsibility of whatever rtains to the fe) OQ c 6 0] o fe) a] ct a ia ct o) 7 p Hh rt Hi fail bh rt ) would hz with the person who was there who was there at EFTA00061533

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LIMITED USE 104 who was 4 until 10:00. elie oO t 3) aid probably around 9: D ops lieut i) @ nant on duty from 10:00 =} 3] I be the 13 14 one 15 16 17 the 18 EFTA00061534

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LIMITED OFFICIAL USE 105 2 didn’t know it. So you did not learn this 3 until 12:35. And you did not authorize those 4 things on that 10:00 p.m. count. Correct? 5 EE: «NO It didnot. Have 6 you talked to -? I mean you may want to talk to some other people because -. wo You know you -. 10 a : Can I different line of 11 questioning on this? 2 ee: Absolutely. 3 a : So let’s talk about the 10:00 4 p.m. count, right? So on the 10:00 p.m. count, 5 you see the El sheet? It It s 16 zero Right? This has nothing to do with him. 7 Just asking in general. If you were - if the 8 person - control officer. Right? This says RA 9 zero. Gets a sheet for R&D - a count slip - 20 that says one in there. And the El shows zero. 21 What should h happened? Right here. This 22 says - you said RA is zero. That’s R&D, right? 24 talk to - like I said - you would have to talk 25 to the people who all - who shift all of this EFTA00061535

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LIMITED ies) w fos) wo ive) oo OFFICIAL USE 106 happened on. shift. when the count was when this dude - all this stuff was going with this dude. ee: You weren’t here at 3:15 But just explain it. a : No-no-no. A hundred percent. That’s the same thing I’m asking. You’re the at this point because shift at this int. The - ia. Right? Who looks at go through here, they EFTA00061536

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LIMITED ies) w fos) wo ive) co OFFICIAL USE 107 comes through is when they verify that - the ee : Okay. RA, which is R&D, on El it shows zero. a : They get a count slip from R&D. plain that to you. happened because that depends on were told by whoever they spoke with being conducted as to how they w ' - now listen. You're know. But here thing. You’re the lieutenant on, The count - control slip from R&D. EFTA00061537

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LIMITED ies) w fos) wo ive) co OFFICIAL USE 108 rt he El shows 0) iO) Even though El shows that there - there’s nobody in R&D. They’re getting a count slip showing one in R&D. Right? Is there an issue with the count at that point? nds on what that that was how they were to why would that be a problem? one look at that. ' oO a oO fC 5 ee : Count shows All right. The El document one. It shows zero. Right here. The El. This is the main document that EFTA00061538

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LIMITED ies) w fos) ive) oo OFFICIAL USE 109 count? There’s a problem El should be reflecting what with the inmate is still physical inside the There’s a problem - institution. So the count - as far as the base during the count and it’s off. They could have ghosted the inmate. I don’t know what was going on at the time. a : So here’s the thing. That ee : I don’t know where he EFTA00061539

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LIMITED OFFICIAL USE 110 wi ~] 10 11 12 13 14 16 17 18 19 20 21 22 23 24 was sitting at the 10:00 count. I don’t know where he was sitting. Because I wasn’t aware that we had an inmate in R&D. a : All right. Exactly. If the control officer, right, matches up every number. Every number that comes on the count slip matches up to the El document exed out for R&D. And R&D shows that there is one. But every other unit shows that it matches the El document. Isn’t there something wrong with the count? ee : Not if he’s aware that the inmate -. If he was told that that’s how his count was supposed to be conducted, that he - if he was told that he was supposed to fill out a count slip for one in R&D or whatever. Then -. a : But that means another unit has a wrong count. Ee: «Sic. 6 can’t answer these questions to you about what they was told about how to do the 10:00 count. ee : Well you already hit it. And what he’s saying the person who took this count - | | - said that he did a ghost count EFTA00061540

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LIMITED OFFICIAL USE 111 7 me when I didn’t aware that tt oO ke he was lying ss) ct a Oo 22 a : Then that’s the question. 23 We're not -- 25 that EFTA00061541

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LIMITED ies) w fos) wo ive) oo OFFICIAL USE 112 e asking you, did you? kK No, I did not approve Okay. oO when you looked at these, you can q& ack to oO them to help. But when we look at these round eets that did in the SHU. Would that have been when you visited the SHU? it wouldn’t have - this is where you logged in. It ike you logged all of your rounds in at the exact same time - within a minute or two. You must have done them from office, a.m., I think it was in the 4:00 or 4:30 range, It might have been before 4:00 and I - and I exited after 4:00. Mm-hm. I’m not sure exactly EFTA00061542

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LIMITED ive) oO wo fea] oo t rar ho No OFFICIAL USE 113 what time it was. But I think it was after I left. I don’t know exac ee: No? So you didn’t roll up a newspaper and hit him with it wake up? CS: | it him witha wasn’t to wake him up. What was it for? hit him with EFTA00061543

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LIMITED OFFICIAL U 114 1 up - 3 ee : That wasn’t the case? J Ao J D was not falling 18 Ee : No? All right. And at 19 that time, did you know that thy we you recall what dis: s you had with th 25 Ee : Well what can you EFTA00061544

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LIMITED OFFICIAL USE 115 w ~] 10 11 12 18 19 20 You obviously remember rolling up the paper and hitting him. What was that conversation? ee : Because he was just talking about - we was just talking about things in general. I don’t specifically recall exactly what it was that we was talking about. Because generally, we would be talking about things that were going on in the institution. Sometimes if somebody brought up another subject or something like that, we would discuss that. Or if something happened when I went upstairs. Or something to that effect. But no. ee: So and again, if they’re saying, no she did that because he was falling asleep in front of her. You know putting his arms down or getting ready to fall asleep. You said that it was because they rolled up and said stay awake. That wasn’t the case? Ee: Okay. So you weren’t trying to keep them awake? Es: «NO. If I was - if that was the case, I would have told him to get up and go wash his - walk around and wash his EFTA00061545

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LIMITED ive) w wo ive) fea] oo its) OFFICIAL USE 116 face. Go do some rounds or something like ee : Okay. Now what is your understanding of what happened with Epstein on August 9th and 10th of 2019? of what happened to him other circ than he committ ide. n’t been information with that oc activ =>d on August 9th or 10th -- leading up to the very of Epstein in his cell? that Epstein was prematurely rem from suicide watch on July 30, 2019? that if there was all these special circumsta surrounding him -. I don’t EFTA00061546

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LIMITED OFFICIAL USE 117 1 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 agree with the fact that Epstein should have been on SHU. Personally. Epstein should not have been on SHU. He should have been in um - he should have been on Ten South. If he required that type of supervision. Inmates - BOP policy states that inmates are not even responsible for other inmates. So for you to even put a requirement on his to say that he had to have another inmate - and expect that inmate to supervise another inmate is irresponsible to begin with. You have - I’ve seen a lot of inmates during my time in the Bureau who have had cellies that have fallen out and been unconscious. And they waited until you actively made rounds to let you know, hey you may want to check on this inmate. So that’s why the BOP has that policy that inmates are not responsible for other inmates. I don’t even like the inmates that they put on suicide watch to watch other inmates. Because I’ve seen them sit there and agitate the inmates that are on watch. So that’s ineffective to expect another inmate is irresponsible to expect another inmate to care that much about another inmate. EFTA00061547

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LIMITED ho ho ho No i) ive) w wo fea] oo © Ww OFFICIAL USE 118 Now do tu know why from suicide watch? not. and SHU cameras 9th and 10th of 2019? un August 9th and 10th 2019? camera in there was working. If it wasn’t, I would in a work order or emailed or for it to be you know who had be able to like intentionally take them offline? EFTA00061548

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LIMITED 1 oO WwW oO oo 95 OFFICIAL USE 119 know who could know how that Are you aware if 2019? Was Epstein in his assigne » ugust 10, 2019? he was not in his the cell that the I don’t know that EFTA00061549

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LIMITED OFFICIAL USE 120 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 there’s anyone that would have been responsible for that. Because there’s no - there’s - it may not have been a mistake. It could have been an oversight or something like that. You know during this time, we were so short and everybody was so busy. We had so many things going on. We had the inmates in the institution was - were going crazy at that time because they were unhappy. A lot of their - especially in the SHU - a lot of the services that stuff that they were supposed to have weren’t being given to them. You know so there was a lot going on in the institution at that time. And you had very few people working. So you was doing numerous - you had one or two people doing the jobs of what would normally be four or five people. So there was just a lot going on at that time. ee : So you think that the mistake would have been - if it was a mistake rather than intentional, someone intentionally doing it -. ee : I mean I can’t answer that. Because I don’t know what Epstein’s assigned cell was in relations to -- EFTA00061550

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LIMITED oO wo WwW fea] oo wo OFFICIAL USE 121 ee : The question is simply - and I didn’t say it was or wasn’t. I just said he was. 0) onsible no one EFTA00061551

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LIMITED OFFICIAL USE 122 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 don’t know if there’s anybody up in SHU that reviews on a daily basis or whatever timeframe where each inmate is located especially at that time. I mean there was so much going on. A lot of that is why we’re here. Because we didn’t have the resources in grave numbers that we needed to do a whole lot of things. We didn’t even have the adequate amount of staff to do uses of forces. Do you know how grave that is to safety and security? We had a ton of contraband in the building at the time. We had so many things that we were dealing with and so many - such a lack of staff. To do those things with that we were just doing the best that we could with what we had. Because nobody was giving us anything else. Nobody was giving us anything else to work with. And then on top of that, you had officers that were being mandated. You can check around at any other institution in the Bureau. You will never see that. But officers are being mandated five days a week. And there were days when they was fed an additional two, two and a half hours on their shift in addition to doing EFTA00061552

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LIMITED ies) w fos) wo ive) co OFFICIAL USE 123 16 hours because there was nobody to relive them at that point. erworked and understaffed. ly understaff Why don’t some follow-1 pre-filling round sheets or count sheets? Like et on a shift, as S¢ as they WQ a : What about like a -? Would were prefilling them out? Like when in, they fill out the times right on the that’s when I And th yrding to what out? If they could. D« shift started at 8:00 a.m. They would get on EFTA00061553

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LIMITED OFFICIAL USE 124 10 11 12 13 14 18 19 20 21 22 23 24 shift. They would take their round sheet, fill out all the rounds that they did - will do, right? And they try to time it and try to go out at that point? surprised if that happened. a : Is that something they’re supposed to do? entered when you do the rounds. ee : Why do you have to enter that round - like why can’t you prefill it out? ee : I mean you can - as long as you know when you did your rounds, you can put it on a scrap sheet of paper or anything. As long as you know what time you did it. They’re not going to always have time after you make a round to run downstairs and jot it. Because there are things that interrupt it or interfere with that. Anything could happen after you’ve made rounds that would prevent you from notating it. If you have the time to do so, yes. But if you don’t it is not unheard of for staff members to document their - the times of their rounds EFTA00061554

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LIMITED OFFICIAL USE 125 w ~] ive) after they’ve done their rounds at a later time. Or sometimes even towards - before they leave - before they get off work. Because they’ ve documented it on a scratch sheet of paper or something like that. Because they didn’t have time to document them because of something that happened or something that occurred. a : And if | and || - they turned around and they prefilled the round sheets and the count sheets, would that be an ue? i“ is) ae : To you, if you found out that they did do it, what does that tell you about the rounds and the counts? Were they actually done? prefilled, how would -? They couldn’t have been done. If they prefilled, how could they be done if that time hasn’t arrived? a : Do you have questions? ee : I’1ll just ask you these general questions. What do you know about EFTA00061555

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LIMITED ive) oO wo fea] oo 19 t rar ho No OFFICIAL USE someone else taking Epstein’s life? know but from what I understand own life? vement with Epstein’s death? J And the last thin an email. And this captain. But the “Lieutenant . I’m reminding you it because there’s no anything s life. about li g I have is just to EFTA00061556

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LIMITED OFFICIAL USE 127 1 submit your supervisor memorandum for the 2 Inmate Epstein incident that occurred on 3 8/10/2019. Please have complete and ready for 4 submission on 8/13/19. Tha 1.” And that was 5 from MM». c2ptain. Then you 6 responded on August 12, 2019, saying, “in your 7 email you state ‘I am reminding you.’ I haven’t 8 spoken to you or anyone else regarding the 9 incident involving Inmate Epstein or anyone - 10 or anything - pertaining -.” Sorry. 11 “Involving Inmate Epstein or anything else 2 pertaining to August 10, 2019. So how is it 3 possible for you to be reminding me? Second, 4 I’ve been properly relieved prior to the 15 incident involving Inmate Epstein.” Do you 16 7 8 - was there any 9 other further communication on 21 Ee: Were required to do a 22 memorandum? 23 ee : No because I wasn’t 24 involved in the incident. ee: Okay. So you never wrote EFTA00061557

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LIMITED OFFICIAL USE 1 ie) o 1 one? 3 ee : Okay. Just before we 4 leave, these - I’ve been keeping these in front 5 of you. I just - I didn’t want to keep on 6 bothering you. I just wanted you to look. Can 7 you just initial and date these just so that we 8 know that these are the documents that we 9 discussed? So that - just the front obviously 10 of each would be very helpful just so that we 11 don’t -. So for these group of emails right 2 here, you don’t have to. See how they were 3 like stapled You can just do the front one. 4 So you don’t have to do all of those. Were 15 these - where you discussed it. 16 ee : You say initial them? 7 HE: «Just initial and date. 8 Today’s date is 9/1/21. Yeah, I believe it’s 9 (Indiscernible *02:01:03). You can ask her 20 after she’s done. 21 25 a : Thank you for initialing. EFTA00061558

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LIMITED OFFICIAL USE 1 2 ee : There’s just one follow- up that we made a - I think you can ask. 4 ee : Yeah. Last time we spoke, No ite] ies) 5 you spoke about the midnight count. The 12:00 6 a.m. count on August 10th. And you mentioned 7 there was discrepancy, (Indiscernible 8 *02:03:33) to discrepancy, right? You 9 mentioned you spoke to | that night. And 10 you told him - he wrongly - uh, your 11 conversation with P| - what 2 instructed him? When they sent up the slip, 3 what was the count slip showing? Was there an 4 error with the count slip? 15 ee : I think when you 16 showed me the count slip the last time, I think there was an error with the count slip. you recall talking to oo Oo 12) 9 | about the error on the count slip? 20 Ee: )=cemember telling 21 them to - after we determined that - after we 22 moved the inmate, the count slip had to be 23 corrected. 24 ae : And if there is an error with 25 the count slip, what are they supposed to do? EFTA00061559

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LIMITED OFFICIAL USE 130 ay 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was submitted, there wasn’t an error. Because that’s what - that’s what the number of inmates that they had as far as they knew that was pertaining to the SHU count. They weren’t sure as to whether or not - I said what should be placed on the count because that was - because there was an inmate in R&D. That’s how all of this came about. So it wasn’t necessarily an error, it was how the count slip had been completed because they didn’t know at the time what the situation was with the inmate in R&D. So that’s why they called - they notified me to see if - to see what I wanted them to do about it. So we made - once we verified that the inmate was in R&D, we made the change in Sentry and on the El which effectively changed the El, and a new count slip should have been routed. a : You instructed them to send a new count slip? ee : I asked - well they knew to do a new count slip. And yes, you know, do a new count slip, and send a new slip down. a : Do you know if that count EFTA00061560

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LIMITED OFFICIAL USE 131 w ~] 10 11 12 18 19 20 slip was ever sent over? from the last time - when we spoke the last time, I don’t think it - I don’t - it wasn’t attached to - from you all’s records and what you had, you know, the copies that you had, it appeared that it wasn’t attached to the count slips themselves - to the count. So whether or not it arrived and someone discarded it because they didn’t’ know if it was the new one or an old one or whether it fell off. I don’t know. ee: So when we last spoke, you said that when you spoke with them, you hadn’t even received their count slip yet. And then you said that you didn’t know if you actually told them to do a new count slip or not. Do you remember? do - they knew to do a new count slip because - actually told them to do a new count slip. You just assumed they would have known to do one? everything. Because their count slips - when EFTA00061561

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LIMITED OFFICIAL USE 132 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 they were saying that the count slip had - that they - the count that they had on their unit - of course, we - I - we went thought everything that they were supposed to do. Go head. You know do a fresh count, make sure that what you have on your unit is what you have. And doa count - resubmit the count slip. Because I think the guys that was there previously had counted. The officers that was there previously, I think they may have counted prior to them getting there. ee : Right. So the question to that is do you know if they were calling in their 73 here and one in R&D? Is that what they were trying to say? Do you know? Because their count slip said 73 and it still to this day is attached as 73. And their books show that there was 73. And the people that were in the previous - all the previous counts - the - you know, leading up to this - the 10:00 p.m. and then - what is the one before that, the 4:00 p.m. - 5:00 p.m.? ee : 4:00 p.m. HE: «2:00 p.m. So the 4:00 p-m. count, the 10:00 p.m. count and the 12:00 EFTA00061562

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LIMITED ies) w fos) wo ive) fea] oo OFFICIAL USE p-m. count are all wro So do you know if when 73. right count. 133 ng. They’re all off one. were calling it in ave 73. So that’s why And I think the count It did. And that’s the wrong in the SHU. So ow if during 3. So it’s either, the was wrong and their 4:00 wrong. So they’re all the question is do you EFTA00061563

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LIMITED OFFICIAL USE 134 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 they -. I don’t remember if they said. I don’t remember if that was the conversation. If they had -. I don’t remember the plus one. ee : So you just remember they said they have a count and there’s one in R&D? ee : I remember them -. I remember them when they -. I think I was calling in the count. Because I don’t know what other reason. Unless he was calling me to tell me. He was either calling in the count - well it was at the time of the count. So when he called me, he was like there’s a - there’s seven - whatever number. They had issues - 73 or whatever it was. I don’t remember the number. And - but there’s a guy in - there’s a guy in R&D from here. And I think they wanted to know what did they want me to do about the count - about the inmate in R&D as far as the count slip went. You know. Because | - | already knows that I don’t play around with -. | knew me because we had worked together long enough for him to know that there was just certain things that he needed to consult with me about because he knew that I was - if it was supposed to be a certain way EFTA00061564

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LIMITED OFFICIAL USE 1 Wo w 1 then that was how I wanted it to be done. So. 2 ee : So is it correct, though, 3 to say they called in a number. You don’t know 4 if they said 72 or 73 - and they had an 5 additional person that was in R&D. u’re talking 7 about the plus one thing, no. I don’t remember 8 that. 9 | tti‘iéS Yeah-yeah-yeah. No, I’m 10 not talking specifically about the 10:00 p.m. 11 count. I’m talking about when you did speak 2 with him. I’m just trying to rectify because 3 they still sent in the 73. So in my mind, 4 since their books show that there was 73 in 15 there, my thought is they probably thought 16 there was actually 73 and one in R&D as opposed 7 to 72 and one in R&D. 8 ee : I don’t - I don’t - I 9 don’t know what they - I don’t know what they 20 was thinking. And I don’t know if -. I don’t’ 21 ever remember the number 74 coming up. 74 24 number 74 25 ee: Do you know how for the EFTA00061565

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LIMITED ive) w wo ive) fea] oo its) OFFICIAL USE 136 3:00 a.m. count they knew to go down to 72 brought to my attention that the gi R&D. re confident that | is the one who told there’s somebody in the SHU - there’s somebo I would have sworn it was a. I don’t think it was anybo don’t think it because I think by that time, the other guys had left alrea them to do that and not talk to the If they were there, I would just asked them. You know, what’s going on? - why - what’s up with the count? What happened? And I would have had EFTA00061566

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LIMITED OFFICIAL US 137 w ~] 10 11 12 18 19 20 21 22 them give me an explanation as to what happened that led up to that because that would have been part of me determining, you know, one finding out what was going on. And determining in the end what I needed to do about it. You know. ee : And why was it like that? Because R&D isn’t a place where we house inmates. So that was out of the ordinary. So it’s like why do we have an inmate in R&D? And especially one that’s bedded down for the night. So that - that just - that just raised a lot of questions for me that I needed to get answers to prior to make a determination as to whether or not this inmate needed to go back up to the SHU. Or if there was no reason other than to let him stay on R&D. ee : And then final question. What did you do to determine that he was there and the documentation was correct? ME: 22 do you mean? ee : So this just goes back to you said you called - you either called or visited R&D. EFTA00061567

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LIMITED OFFICIAL USE 138 10 11 12 13 14 16 17 18 19 20 21 22 23 24 And I think we called to make sure - to verify - that the inmate - that there was actually an inmate there. And I want to say that somebody in control that was saying yeah, there is an inmate in R&D. So I can’t remember offhand how, but I’m sure we made a phone call to verify that there was an inmate in R&D. And that the circumstances of why he was there. And at some point, I went and visited R&D. | ti‘ ‘és Okay. And again, just to give you the backstory of what we have, all of the people - the 10:00 p.m. count and the 4:00 p.m. -? ae : 4:00 p.m. a : 4:00 p.m. count. They’ve already told us we didn’t do the count. We didn’t count them. We know at 12:00 a.m. they didn’t do the count. They did not count them. No counts were conducted. So this just - I want you to know that for the back of your head, especially since they were counting fF in their count that they thought that they were doing that was accurate. Are you sure you had a conversation with someone in the EFTA00061568

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LIMITED OFFICIAL USE 139 w ~] 10 11 12 18 19 20 SHU about the count being - you know and them - and them providing you the information as opposed to you providing them the information? ee : What do you mean? As far as me calling -? started at midnight and they didn’t seem to know. So the people that were doing the counts and they were doing it wrong, they were all like, “Well we didn’t’ know that. We didn’t know our count was wrong. We weren’t intentionally ghost counting.” So | started at midnight. The fact that he would be calling you with that information just seems very unlikely since no one before him knew about that. ee : Why was that - why would that be unlikely? ae: Because he started at midnight. And the people that were in the SHU weren’t aware of the FY mistake, which caused all their counts to be wrong and now we know that they all counted wrong and they’ ve all admitted it. Yep, we didn’t’ count. So lI just want to make - because this is the one EFTA00061569

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LIMITED OFFICIAL USE 140 1 part of our story that doesn’t really add up is 2 the fact that you’re saying he told you there 3 was somebody in dry cell when nobody else 4 seemed to know. And he just started that 5 shift. 6 ee : So what’s unusual 7 about that? 8 ee : The 4:00 p.m. count was 9 wrong. The 10:00 p.m. count was wrong. And 10 the 12:00 p.m. count was wrong - or 12:00 a.m. 11 count - I’m sorry - was wrong and the person 2 that just started at 12:00 a.m., the only way 3 that I would think he would know that someone 4 was in the R&D dry cell, was if someone 15 previous to him told him that. So what I’m 16 asking is are you sure that he told you? Or 7 did you say there’s someone in R&D. That guy 8 came from SHU. 9 ee : No. How would I have 20 known? 21 Ee: I don’t know, because 22 there was an R&D count slip? 23 ee : You're talking about 24 an R&D count slip for 10:00? 25 ee: There’s also one at EFTA00061570

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LIMITED oO wo ive) fea] oo wo No Ww OFFIC USE 142 ee : And that’s why - no-no-no that. u this information. the one Yeah, I mean -. ving that owing that the 4:00 That doesn’t change Well it chang 2r took did the counts. EFTA00061572

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LIMITED OFFICIAL USE 144 1 confident are the one who provide 2 you with that information? 4 he was the one that I had the conve 5 with. I’m almost - I mean a male, QR, 1 6 don’t remember talking to the 7 previous shift because I think they were gone 8 at that point. Because if they weren’t, I 9 would have just got simply had one of them get 10 on the phone and asked them the information -- -- about the guy in nN Ww m7 R o | | have known. 7 | ti‘ aiésll Well that’s my question. It sounds like you just may have answered it fea] i] oo 9 there. I understand that you had a 20 conversation with someone. What I’m gs ing is, 21 did they provide you the information or did you 22 provide them? 23 ee : I’ve told you 24 numerous times that they provided me with it. called me and mentioned to me that this - EFTA00061574

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LIMITED OFFICIAL USE 145 10 11 12 13 14 16 17 18 19 20 21 22 23 24 26 that they - that there was an inmate in R&D and was going - wanting to know how I wanted them to fill out the count slip. ee : Okay. And that’s your recollection. Great. Thank you for your time. It is - this is Senior Special Agent | PF with the U.S. Department of Justice Office of the Inspector General. It is 2:41 p-m. and I am turning off the recorder. EFTA00061575

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