10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JULY 12, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 ra Hills, CA 91301 (818) 431-5800 EFTA00110695

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LIMITED OFFICIAL USE 1 APPEARANC ies) OFFICE OF THE INSPEC OR GENERAL co co EFTA00110696

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LIMITED OFFICIAL USE 1 MR. Ee : The recorder is on. My ios) 3 Department of Justice Office of the Inspector 4 General New York Field Office and these are my 5 credentials All right This interview with 6 federal Bureau of sons lieutenant 7 Po | is being conducted as part 8 of an official U.S. Department of Justice 9 Office of the Inspector General investigation. 10 Today’s date is July 12, 2021, and the time is 11 1:06 p.m. This interview is being conducted at 2 the federal correctional institution Danbury 3 located in Danbury, Connecticut. This is the 4 training center. What is it the -? 5 MR. QJ: §9Smre center. SIPE Center? t oO a Lee) 5 What does it stand for do 23 MR. QJ: 9SIre. Yeah. 4 MR. a : Yeah. It’s the training er right outside of the FCI Danbury on the ho No w EFTA00110697

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LIMITED No No iN ies) w co ioe) co © ion) OFFICIAL USE 4 FCI Danbury property. Also present is DOJ OIG nt | a. This interview will be recorded by me, SSA | a . Could everyone ple ial Ag oO To start, Thank you sir. This i 07) an official DOJ OIG investigation to the death of inmate Jeffrey Epstein and the surrounding circums voluntarily provide answers to our Will agree to a voluntary interview with MR. a : Yes. MR. Ee : Thank you sir. This isa form that we have for our voluntary interviews. We give this to everybody t so you know that it is have to answer our questi EFTA00110698

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LIMITED OFFICIAL USE 1 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I’m going to read it to you for the record. It’s United States Department of Justice Office of the Inspector General Warnings and Assurances to Employee Requested to Provide Information on a Voluntary Basis. You are being asked to provide information as part of an investigation being conducted by the Office of the Inspector General. This investigation is being conducted pursuant to the Inspector General Act 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 proceedings or agency disciplinary proceedings or both. Then there’s the waiver which 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. And there’s the - right here - employee signature and EFTA00110699

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LIMITED OFFICIAL USE w ~] employee’s name. You want to read that yourself. Feel free to. If you agree just sign MR. a : So it says job performance failure and security failure according to-. MR. a : That’s for everybody. We're giving that - that’s just the blanket statement we’re providing to every single person that we interview. MR. a: -™mm MR. a : It doesn’t necessarily mean that you’ve done anything wrong. It’s just that’s what the investigation is looking into. You know security failure of the institution - job performance failure. Because someone died in this matter. And looking into the surrounding circumstances with it. Everybody’s being provided that same - MR. QJ: 9 Okay. MR. a : -- that same information. Okay. So I just singed my name as the Special Agent. And I’m printing my name. Again this MR. a: This is Special Agent a. EFTA00110700

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LIMITED w ~] wo 10 11 ive) OFFICIAL USE I am signing as a witness. MR. a : Okay. And Special Agent a. if you don’t mind, just place the date and time. Again it is July 12, 2021, and the time is 1:10 p.m. now. And the place is FCI Danbury Training Center. Thank you, sir. Okay. Did you understand that form? MR. QJ: 9 Yeah. MR. a : Okay. Cool. Is there any other questions you want to ask about that though? MR. a: no. MR. SJ: No? MR. a: I mean it’s voluntary is that right? MR. Ee : Yeah. Exactly. Voluntary. You don’t have to answer. And again that job performance failure - security failure that’s something we’re telling everybody that that’s the purpose of our interviews is to figure out - MR. QJ: 9 Okay. MR. a : -- what went wrong and all that kind of stuff with regard to this matter. Before starting the interview, I’d EFTA00110701

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LIMITED ioe) io ioe) oO oo OFFICIAL USE u under oath. Lieutenant raise your right Do you swear to tell the truth and nothing but the truth during this interview? sir. All know if you don’t and I’llt to rephrase them or put them in a different way your home numbe tad MR. a : Thank current you. And your your hig! EFTA00110702

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LIMITED ioe) io OFFICIAL USE MR. a: Criminal justice. MR. a : Criminal justice. Where in New York MR. a : And when did you I think. ay. And wit 1 what did MR. Ee : How long did you do that? MR. a: Mm six and a half years. MR. a : From approximately when until when? And how long EFTA00110703

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LIMITED ioe) w io ioe) its) OFFICIAL How lc USE e you when 10 So you did it were with a : No-no-no. With the BOP. d with the BOP? BOP? until when. do you know when rs ¢ Q S MR. y- And wi EFTA00110704

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LIMITED OFFICIAL USE oO io wo MR. MR. right? MR. J D 6 0) = ry) BOP? fn 11 o> 7UD? You’re talking a GLYNCO K o wu J > re) when and 1 oO Se) oO c K be bh H n rt Oo fh Bh be. ie] fv] wu fo n rm 5 @ 5] ct with the I | a K 0 in a whole time? - 2019, *18 think December 17th I did a temp. MR. MR. MR. MR. a : December of 2017? a: ‘17. Yeah. And when did you le left December ‘19. ecember of 2019? EFTA00110705

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LIMITED OFFICIAL USE 12 1 MR. Ee : And then is that when you 2 came here to the FCI Danbury? 4 MR. a : And um did you come here for a promotion? ies) w 7 MR. a : So were you a 8 lieutenant? 9 MR. a : I was a 9 there but I got TDY 10 down there. So I was 11 also there. 1 MR. Ee : Oh you were? 2 MR. ae: Yeah. I got TDY for about WwW Hh 18) Cc 5 3 is) 5 rt a n 5 what does that mean 16 MR. Ee : Temporary D - Like Il was picked up. I got my promotion, but I had co to stay down there for few months until I wu 9 came up here. 21 You were promoted to an 11 but they had you Danbury. 22 stay down there as an 11 for four months? Ye 24 MR. a : So when were you ac No Ww 5 EFTA00110706

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LIMITED ies) w co ioe) co OFFICIAL USE 13 MR. a: About three months. In October, September, October, November, three MR. a : And when did you MR. a : December. your current position is still MR. a : And what was your 9th and 10th of position at the M Aug 2019? MR. a : Uh August you said 10th? MR. Ee : Yeah. So August - you in August of 2019 you were MR. a: I was a 9 then. MR. a : -- a 9 lieutenant. EFTA00110707

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LIMITED OFFICIAL USE 14 1 own knowledge. What is the difference between 2 a 9 lieutenant and an 11 lieutenant? 3 MR. a : Pretty much you could - 4 if you at 9 you can’t run the institution. 5 Because it’s not a higher rank. So like 11 or 6 the only one 7) who can without a captain. ~] You’re the highest. But a 9 you can’t be the 8 highest. 9 MR. a : So does that mean like as 10 far as like being the ops lieutenant versus the 11 activities’ lieutenant? 2 MR. a : Nah. You could be ops as a 3 9. 4 MR. QR: Okay. MR. QJ: «But - but -. 16 MR. Ee : So like acting captain you mean? 8 MR. a : No. Say like if it’s a Q, 9 it’s like evening watch. Four to twelve or w 20 midnight. The 11 is the highest authority. 21 MR. QR: okay. 22 MR. BJ: a 23 You have to have 11 or above for 9 to be in A 3s a 9 you can’t do that. if 24 authority. 25 MR. QR: okay. EFTA00110708

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LIMITED w ~] wo 10 11 ive) OFFICIAL USE 15 MR. a : So you can be an ops lieutenant but somebody else has to be there that’s higher than you? MR. a: Yeah. If you a 9 yeah. MR. a : Okay. Do you recall what shift you worked on August 9th and 10th of MR. BMJ: «August 9th? What d that? MR. Ee : It’s August 9th - sorry. We'll just talk about August 9th. August 9th, ia y was 2019 that wa wo the day before Epstein was found is] dead. It was a Friday. MR. a: So the Friday. I probably was day watch. MR. ae : Okay. I’m going to give you the daily roster from that date just do you can reprint it. MR. BJ: 9 Yeah. MR. a : Um anytime I give you a document - you don’t have to do it right away - but you can - I’m just going to have you Hh initial and date each document. It’s just for the record we can say that’s the document you EFTA00110709

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LIMITED OFFICIAL USE 16 1 looked at. And we don’t like replace 2 something. You know what I mean? 3 mR. QR: «9 vm-hn. 4 MR. a : Um so on that can you 5 find your name and see where it is that you 6 worked just to verify? 7 MR. a : Yeah. I did overtime from 8 6:00 to 2:00 9 MR. a : From 6:00 a.m. to 2:00 10 p.m 11 MR. a: Yeah 2 MR. a : And that was on August 3 9th? 4 MR. QJ: 9 veah 15 MR. a : Do you know if you - 16 there were the specific times that you worked? 7 I know for instance the individual that was the 8 activities’ lieutenant after you. She didn’t 9 start until 4:00 p.m. because she had her 20 regular time shift until 4:00 p.m. 21 MR. QR: 9 w-hn. 22 MR. ae : Would that mean that you 23 had worked until 4:00? Or would you still have 24 stopped at 2:00? 25 MR. ae: Uh I don’t know. EFTA00110710

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LIMITED OFFICIAL USE 17 w ~] wo 10 11 MR. Ee : Do you usually have to wait until the new activities’ lieutenant comes on board? MR. QJ: «om that’s QJ was -. But she wasn’t a lieutenant here though. MR. QJ: No.) She was an SIS, but she got I guess temporarily promoted. At least for that day to be able to be the activities’ lieutenant. But she was in attorney conference until 4:00 p.m. And she didn’t start as the activities’ lieutenant until 4:00 p.m. MR. a: I don’t remember. But I know we usually - even though it says 8:00 to 4:00, we usually do 6:00 to 2:00, 2:00 to 10:00 anyway. MR. QJ: |= Yeah. MR. a: We relieve people early. MR. a : Right. And my understanding is it’s for traffic purposes. MR. QJ: 9 So if the 9th I would have came on then. She wouldn’t have to stay until 4:00. I don’t know. MR. a : How does that typically work though I guess. Would it be - do you have to be relieved before you can leave? EFTA00110711

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LIMITED OFFICIAL USE 18 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a: Mm you mean for me? MR. a : Yeah. Like if you’re the activities’ lieutenant at the MCC back in August of 2019. Are you allowed to leave before the new activities’ lieutenant takes over? Or do you have to wait until she’s done? I’m just trying to help refresh your memory if you can -. MR. a: I’m not sure. I know how we do it is someone day I got you. I’11 cover you. Then we relieved. MR. a : But you don’t specifically remember this date? MR. EJ: No. MR. a : Not the fact that like Epstein died the day after. Does that help you like kind of refresh your memory of what your involvement may have been? MR. a: I know I was doing day watch. I was doing day watch. I do know that. But as far as who relieved and all that. No. I don’t remember that. MR. a : All right. We can probably just grab your time and attendance records then later just to try to EFTA00110712

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LIMITED OFFICIAL USE 1 ~] wo 10 11 \o (Indiscernible * *00:12:34) that down. But you just can’t remember at this point? MR. a: What you asked me was I there? MR. a : Yeah-yeah-yeah. Just I mean from the 2:00 to 4:00. You don’t remember if you would have - you had to wait until | was actually in place before you left or not. MR. a: Nah. I don’t know. I could have been there at 4:00 because I left at 2:00. I’m not sure. MR. a : Okay. Fair enough. MR. a : So you either worked until 2:00 p.m. or 4:00 p.m. you just don’t recall. mR. QJ: 9 Yeah. MR. Ee : All right. And who did you - on that date - who would have you primarily worked with? MR. a: Mm ... I don’t know. Because Friday -. I don’t know why I’m doing overtime on Friday. I’m trying to think. And | | is normally not the ops lieutenant though either. EFTA00110713

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LIMITED OFFICIAL USE 20 1 MR. Ee : Is that because he was a 3 mR. BR: QJ is 11. He’s suu 4 lieutenant. MR. a : At that time || was th 6 SHU lieutenant. 7 MR. ae: Oh no-no-no | | was the SHU 8 lieutenant. Okay. So if I’m on Friday and w oO o 129) fu ct c 4K Q fu kK - .) @ =) | 10 MR. QJ: Well here if -. 11 MR. a: Maybe. I don’t know. You what’s her name records? N > wy 0 3 3 ive) Fs) This is Saturday. So I’m 4 giving you the daily assignment roster. I’m thinking Friday was my day off. §S iT] kK t oO oO Ph fh ie) Hi 7 came in for the overtime on Friday. If I’m on 8 Friday and Saturday, then I would be ops. 9 That’s what I’m thinking. 20 MR. Ee : Did you work on Saturday? 21 MR. ae: Saturday I was off. 22 MR. ae : Okay. So you’re not on 23 that list that I just gave you for Saturday? EFTA00110714

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LIMITED OFFICIAL USE 21 w ~] wo 10 11 ive) MR. a: This the day Epstein died MR. a: Yeah. I wasn’t there that day. MR. a : Okay. But you just can’t remember if you worked until 2:00 p.m. or 4:00 MR. Ee : Again there’s no reason that I’m asking you this specifically right now. It’s just tot K y to make sure we know what time you worked there. MR. a: Well you trying to see if there’s a pattern of -. MR. ae : no-no-no. Not a pattern. It’s not looking at you. It’s just to - you know when we talk to people, we say like what time were you there from. Just because in maz didn’t start until - because there’s no reason for us at this point rr knowing tha to get your time and attendance records. Because again we’re just talking to everybody that was there on each day. EFTA00110715

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LIMITED OFFICIAL USE 22 1 MR. QJ: «9 vr-hn. 2 MR. a : I’m just trying to -. 3 When we talk to you, we just need to lock down 4 each person. What time were you there until? 5 MR. a: I don’t know. 6 MR. ae: We have specific questions 7 about what happened during the day. But if 8 you’re not there during the day during that 9 specific time -. 10 MR. a : Some questions might not 11 apply to you. 2 MR. a : Apply to you. That’s what 3 we’re trying to figure out. So what time were 4 you there until. 15 MR. a: I mean so you want to ask me 16 questions up until 4:00 is what you’re saying? 7 MR. ae : We’ll ask you 8 specifically questions -. 9 MR. a : Well you can do it but if I 20 don’ remember I just say I don’t remember. 21 MR. ae : Yeah. That’s fine. You 22 just don’t. but at this point you just don’t 23 know if you were there until 4:00. 24 mR. GR: No. 25 MR. a : Um and you don’t remember EFTA00110716

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LIMITED OFFICIAL USE 23 1 relieving a. Or ma relieving you. ies) a And do you remember being no. fon) w a a No? All right. But I 7 guess then that goes back to my original 8 question. Do you need to be relieved by 9 someone in order to leave? 10 MR a: Um normally. It depends. 11 MR. Ee : Can there be just an ops 2 lieutenant and no activities’ lieutenant on ive) That could be any day. 15 Okay. 16 7 So it’s just - there’s 8 no-. these are genuine questio We don’t 9 know the answers to these. So that’s not like 20 abnormal to have like just like a two-hour gap 21 where there’s no lieutenant? 22 MR. a: No. We was going a lot of 23 work up until this. We were doing a lot of 24 work. So some days you’ll be there. I’m quite 25 sure looking at the records, you’ll see my name EFTA00110717

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LIMITED No No iN ies) w co io ioe) co © ion) OFFICIAL morning? know activities’ lieutenant, and you said it was day I MR. QJ: Right. A On some days there was like one activity or one o lieutenant? here was nobody -? MR. ae: Yeah. And that was MR. Ee : Or night shifts? Or Ae) 3 ke oO fu a) ie) H ct = wu U w at that time who was your supervisor? MR. a: Uh the captain. Captain watch? 5 ts 7) fu J What were and ig nsibilities? MR. ae: Rounds um orderly EFTA00110718

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LIMITED OFFICIAL USE 25 10 11 12 13 14 16 17 18 19 20 21 22 23 24 institution. Running the institution. MR. a : And what does a round consist of as a lieutenant? MR. a : Going up to the unit. Speaking to the officer. If you want, go to unit team. Do the tiers. See what’s going on. MR. a : Now at that time, did lieutenant -? When you say go do tiers. Were Lieutenants responsible for conducting rounds of inmates as well? Like you know walking up and down the tiers to make sure? MR. a: Something like that. I mean that’s - are we - the lieutenants responsible for that? MR. a : Yeah. I know that that’s the CO’s primary responsibility. But when you are conducting a round in like a unit, specifically we’ll talk about the SHU. If you visit the SHU, and on this date, there was no SHU lieutenant. Correct? MR. a : So if you were visiting the SHU, are you responsible to conduct any rounds of the tiers as a lieutenant? MR. a: Yeah. The lieutenant has to EFTA00110719

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LIMITED OFFICIAL USE 1 make a 2 MR. round in SHU ho on each shift. when I - but when say 3 you visit the SHU, is it just visiting the SHU? 4 Checking in with the officers? Or do you - I 5 mean -— checking in with the COs or is it 6 actually also doing a round of - where the 7 inmates are located and looking in their cells? 8 MR. a: I mean yeah, you’re supposed 9 to do a round. 10 MR. QJ: Okay. So that -. 11 MR. a: You mean exactly what do you 2 supposed to specifically do? 3 MR. a : Yeah. I guess what I’m 4 asking is what does a lieutenant round in the 15 SHU consist of? 16 MR. ae: I don’t know. I know for me, 7 used to like to go down the tiers. 8 MR. a : To actually check on the 9 inmates. 20 MR. BJ: 9 Yeah. 21 MR. ae : So you’re actually doing 22 -? 23 MR. a: Do a whole complete round. 24 MR. a : So you’re actually doing 25 a round of the inmates not just doing a round EFTA00110720

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LIMITED OFFICIAL USE 27 ~] wo 10 11 in the SHU to say hey are you guys good with the officers. MR. a: Yeah. Unless something happens. Like if something happens you know. They just say you all right - it was a BA. All right. I’11 be back or something like that. MR. a : Right-right. You mean if you got called out or something like that - you needed the run. MR. a: That or they call you. MR. QJ: Right. MR. a: Something specific to a specific tale or -. MR. a : Yeah-yeah. But were you on ini rr es ible - and this is us fr) "oO ifs] in general not J ust specifically you? It’s any lieutenant. ue If there’s no SHU lieutenant responsible to do a round on day watch of the inmates when they visit the SHU. MR. a: I’m not sure. MR. ae : You’re not sure. But you did. MR. a: That day? MR. a : No I mean just in EFTA00110721

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LIMITED OFFICIAL USE 28 1 general. Like when you would visit the SHU you 2 would do that? 3 MR. QJ: 9=veah. Say like if I fill in 4 or whatever. And there’s no SHU lieutenant to 5 say hey you got to make a round. All right. 6 Or you have activities do it or whatever. 7 MR. a : So ops lieutenant tells 8 you to do the round? 9 MR. a : Anyone could say hey I’m 10 going up there or hey I got the round or 11 whatever. 2 MR. a : Does a lieutenant have to 3 do a round on that shift? 4 MR. a: That would be yeah you h 15 to do a round. 16 MR. Ee : Okay. So at least one lieutenant on day watch on August 9, 2019, had 8 to do a round in the SHU of the inmates? 9 MR. a : On day watch? 20 MR. QJ: Yeah. 22 MR. ae : What about night watch 23 and morning watch? Do they have to do it on 24 those? 25 MR. ae: Night watch and morning wa EFTA00110722

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LIMITED ioe) w io ioe) its) OFFICIAL USE 29 ah. i) V not just checking in? Oh you’re not sure. But 5 When you did it? a] I’m on (Indiscernible * around. I I’m trying to like to hit the tiers. MR you remember who MR. MR. MR activities’ lieutenant prior to EFTA00110723

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) for only an ops And Um said you just don’t r if you stayed until MR. video? on to yet. I A reas u remembered. the 4:00. Yea And that’ morning lieutenant? So we you you said y 6:00. 6:00 a.m ecall who Corr h. Did you We didn’t just assumed you would I don’t Okay. ‘19. was Yeah-yeah - you know this was p ev h but that because yeah 7) y watch is there re the first one it) ou arrived when? ect? - haven’t had a remember. -yeah. No just robably one er happened. ‘s why I’m like That’s why EFTA00110724

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LIMITED OFFICIAL USE Ww Pp 7] 1 because there’s things that have happened in the past month that now is creating a -- ies) a Oh with the case. 4 MR. a : Yeah. That we now have 5 to interview a ton of people to be able to find 6 out who was there, what happened, and all that 7 kind of stuff. 8 MR. a: Yeah. But I’m not sure about 9 the time on that. 10 MR. a : All right. And are you 3 MR a : Did you ever work or 4 visit the SHU while Epstein was assigned to the 15 SHU in July and August 2019? t oO a) 7 MR. ae : Did Epstein have a 8 cellmate when he was in the SHU? 9 MR. a : Up until that day, right? 20 MR. QJ: Yes. And do you know if 21 there was a reason why Epstein was assigned a 22 cellmate? 23 MR. a: In SHU you’re supposed to be 24 double bunked. EFTA00110725

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LIMITED OFFICIAL USE 1 MR. a: Even if you don’t have the 2 whole prior thing before. Ww ies) a So everybody in the SHU w Oo) fe] oO K rt i] » =] Qo i] n 1] its to ra} rt a 1) = wu n w c ue] ue} Oo w oO 2. rt ° ies wv < wu rh ar as who would - who wouldn’t be as wo f igned a cellmate? i=) a House alone, rec alone 11 inmates. You know hunger strike inmates, N Oo 7] ive) Fs) But Epstein was one of 4 those inmates that should have had a cellmate? 5 MR. a: Yeah. He was a regular f fo] t 3 | wu ct oO K @ wu oe 7 MR. ae : Okay. Um are you aware tempted to commit suicide on Les] ct ~ ul] rt in] ve] n ct 0) r 5 7 h io) uN] rt 21 MR. ae : And were you one of the 22 responding officers to that? 23 MR. QR: No. 4 MR. a : Were you - did you have any involvement with it? ho No w EFTA00110726

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE wo ios) MR. a: That incident? No. MR. a : No. Do you know what transpired? MR. ae: They say he put something around his neck. In his cell. And that was Did you ever hear any rumors that his cell mate may have tried to harm him? about um -. Yeah. I heard about that. Yeah. You’ re talking What did you hear about MR. a: That it was a ploy for him to Something like that. did you -? Ss your understanding that he actually did try to harm himself? Or was it your understanding that his cell mate tried to harm him? You’ re talking Yeah. What is your MR. a : The rumor was the guy -- -- what actually -? EFTA00110727

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LIMITED co wo co OFFICIAL USE 34 MR. a: -- also had a high-profile MR. ae: And I think Epstein was up for a bail hearing. So they made it look like MR. a : Do you think there was MR. a: I don’t know. Not after this. Nah. MR. QJ: 4.11 right. believe that he did actually try to harm do you himself on July 23rd? MR. Ee : Okay. Um do you know as a result of July 23rd if Epst 7) + oO 3 | happened with Epstein? Was he removed from the ep) r G mu] 4 om 'o »laced anywhere else? MR. a: Mm. He went to suicide watch. EFTA00110728

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) Ww wi on suicide watch? Is that outside of the SHU? MR. QJ: 39 Yeah. MR. a : And then after you get placed on suicide watch. Is that a temporary thing and then you get moved over to psych observation? MR. a : Not all the time. No. ych makes that call. MR. a : Do you - are you aware if Epstein was outside of the SHU and on suicide watch or psych observation for approximately one week? MR. a: I know he was definitely on there. Because I remember seeing him. MR. a : You saw him there? were doing rounds? Or why did you see him there? MR. QJ: 931 had to - because I’m the one who does the showers. MR. QJ: okay. MR. a: For suicide inmates. Or psych watch if you’re down there. So he was down there one day - probably a couple days. EFTA00110729

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LIMITED OFFICIAL USE wo fen) 1 But I know I took him to the shower one time. 2 Yeah. ies) MR. a : Okay. So you had some 4 interaction with him. w 3) was on suicide Suicide watch. Yeah. - I thought oo 5 oO a t thought i=) were only on suicide wa 1 like 24 hours. And then after that it was 2 called psych observation. Is ive) understanding? a H ct fs] c ue] t 12] ue] U k 7 f foal 5 4 wu rt +) wu ie] n he ie] I Q fw } bh 8 they’ re in the same location. Correct? Yeah but people who are on wo a3 20 suicide watch longer than 24 it) Okay. No nN Fs K Pry fv) ory wu 1 So your understanding the 24 whole time he 25 watch? EFTA00110730

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LIMITED ies) w oO wo i=) nN ive) oO co 23 OFFICIAL MR. QJ: 31 don’t Oka who Um was removed from suicide Do ed from suicide watc e woul : Oka what And a ie] p Hh Bh i) r ) 5 Q 0) ) wv rt bh it) All watch, suicide Ww ~] remember. ve le time he was there. do you know when he watch? you know why he was h? d be moved because And when someone ve does it entail? suicide smock. suicide blanket. And does that entail? right. So when you don’t have whole EFTA00110731

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LIMITED OFFICIAL USE wo o 1 time? And you know if Epstein was naked that 2 whole time? 3 MR. ae : He had a smock anda -. 4 Yeah. He didn’t have no clothes. 5 MR. a : He didn’t have clothes 6 when he was on suicide watch? 7 MR. a : You can’t have clothes on 8 suicide watch. 9 MR. a : Okay. All right. So 10 does it sound right that he would have been 11 removed about a week later around July 30th. 2 Does that sound like a date -- 3 MR. a: I don’t know. 4 MR. ae : -- or you’re not sure? 15 MR. a: Mm-hm I don’t know. 16 MR. Ee : Okay. Did you ever 7 receive any instructions from anyone with 8 regard to Epstein being assigned a cellmate 9 after he came back from suicide watch? 20 MR. QJ: §=«1’m not sure. 21 MR. ae : You don’t remember any 22 verbal conversations or anything like that? 23 MR. QR: No. 24 MR. a : All right. I’m going to 5 show you an email. And then you can tell me if EFTA00110732

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LIMITED OFFICIAL USE Ww wo 1 you remember receiving it. An email froma 2 | a. Do you know who that is? 3 mR. QJ: 9 Yeah. 4 MR. a : All right. It’s to 5 Suicide Watch / Psych Observation Update. And 6 that’s also what the subject is. And it’s from 7 It ys, “Inmate Epstein” and 8 it gives his reg number. “Is being taken off 9 of psych observation and needs to be housed 10 with an appropriate cellmate.” Do you recall 11 receiving -? 2 MR. ae: Yeah. It’s a generic. We Wa wu be = fu ke n Q o rt ct a ie] 7] 0] 4 MR. ae : You get those? t wi bd K oO wu y 16 MR. Ee : There’s names on the 7 back. It shows that you were one of them and 8 that you read it. Do you see your name? Yeah. 9 It would be under J. So. It’s all 20 alphabetical. 21 MR. ae: It’s under what? 22 MR. ae : It would be your first -. 23 MR. a: Oh, okay. Yeah. 24 MR. a : So does that ring a bell? 25 Do you remember getting that? EFTA00110733

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LIMITED OFFICIAL USE 40 1 MR. a: Yeah. 2 MR. a : Okay. Cool. And then do 3 you recall -? So you are aware that he needed 4 a cellmate then. Correct? You already said 5 that you knew he needed one because he was a 6 regular inmate. Right? 7 MR. a : Yeah. But I don’t know what 8 this is at 12:30 the 30th right? wo i a K Oo fu a J Wo o | a) ° ke oO fu io ive) Fs) Okay. 4 MR. ae : Placed back in the SHU and required a cellmate. w 8 forget. Do you mind just initialing and dating 9 each one of these documents just so that they 20 don’t start piling up? And as well as that 21 email. Thank you, sir. Now do you remember 22 having any conversations with anyone else like 23 verbal. Like | or anybody regarding the 24 need for him to have a cellmate? 25 MR. EJ: No. EFTA00110734

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 41 Because, I’m assuming, he was the most high-profile if not one of the most high-profile inmates at the time. o wu MR. a : So would that be something that they would - people would usually communicate with the activities and the ops lieutenant about? MR. a: I mean if you got the email. Okay. You got a follow-up that you wanted to ask something? Because it’s going back one. We’ll finish up on this. No-no. Please. Go So you mentioned that you had interacted with Epstein when he was on suicide watch. You took him for his showers. MR. QJ: 9 Yeah. MR. a: How was the interactions with him? You know, cuff up, take him EFTA00110735

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LIMITED OFFICIAL USE 42 10 11 12 13 14 16 18 19 20 21 22 23 24 to the shower. MR. a: Did you ever talk to him? MR. a: Yeah. MR. a : Was he pleasant? Were there any issues with that? MR. a: He was saying hey, while I’m down here, pretty much he asked why he was down here. I said well, he was like yeah, I’m not suicidal, such-and-such. And you know let me talk to psych so I could get off this. I don’t think he liked it. MR. a: This was immediately after the July 23rd? MR. QJ: 391 don’t know exactly what day it was. But you know it was around there. MR. QJ: «Got it. MR. ae : We’re going to follow-up with some of those more lines of questioning later on in the interview. Um so you don’t recall though receiving specific instructions from Captain | or anyone else with regard to Epstein? You just - you do know he needed one and you did get the email? MR. a: These come all the time. Any inmate comes off of watch, they send it out. EFTA00110736

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LIMITED OFFICIAL USE 43 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. a : And should everyone know if someone comes off of watch that they are required to have a cellmate? MR. a : I’m not sure. I mean that’s what they do. They come out. Anyone comes off suicide watch, you put them in with a cellmate. MR. es : Yeah. And that’s pretty general, common knowledge. Correct? And where do you learn that? Is that from your daily operations? Or do you learn that in training as well? MR. a: I don’t know. I guess it’s daily operations. MR. QJ: Okay. =But most people should know that a person coming off of suicide watch is required to have a cellmate. MR. a : Uh I mean it depends. I don’t know. I know we get these emails though. They send them out any time an inmate comes off. You try to put them with a cellmate. But then again like I said in the SHU, it’s you know. Because even if they come off suicide watch, they don’t -. Say like they come off they stay in SHU for a year. They have to have a cellmate for a year. You understand what I’m EFTA00110737

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LIMITED ies) w ~] wo 10 11 ive) OFFICIAL USE saying? So as far as th everyone know that? I’m ve. : 2u MR. QJ: 9 veah. ae: vR. a : but e MR. Ho I got MR. Ok is from the email, in the SHU, anyooay anyw mate? ue. J: ve. a: basically two requiremen Yeah. Al the email that he re was that he was in the SHU, of those special requirements, 44 e notice we get, but do not sure about that. t you knew. w did you know though? the email. ay. So, your knowledge arlier, you said that ay, needs to a cell l right. So, he had ts to him. One, there ceived; also, the fact and he didn't have any like, he was going to harm someone else, or something like that, that he should have had a cellmate? MR. QJ: «9 Right. Al know if you ever communi when you visited the SHU 2019? ve. ER: aon. Li l right. And do you cated that to anybody, in July or August of I'm not sure. ke, the people that EFTA00110738

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LIMITED OFFICIAL USE 45 w ~] worked in the SHU, would have you would have been as the activities’ lieutenant, if you’re doing a round in there. Is that something that you would address? MR. QM: Bring up? Yeah. If I - yeah - but if he had a - one - if he had a cellmate, though. MR. QM: Right. MR. a: Yeah. Bring something up if they didn't. Uh-huh. MR. a : So, you’d only bring it up if you knew he didn't have one? MR. a: So, like, if you say, hey, guys, how many single cells I have? Such and such. Hey, what’s going on? Hey, well, this is the reason. Yeah. MR. ae : And is that something - when you would visit the SHU - is that something you would ask? How many single cells do you have? MR. QJ: 9 veah. MR. ae : Is that a like one of the check-the-box things? Does everybody that visits the SHU -- MR. a: I can't speak for everybody. EFTA00110739

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LIMITED ies) w co wo ive) co OFFICIAL USE 46 But I know, even as OIC, we said, hey, you know th Maneuver to wo fine, we have single cells. condense it for space. Stuff like that. MR. QJ: 9 So, I don't know if everyone (Indiscernible *0 MR. QM: «But that’s do? When you were you would lieutenant? MR. a: If I seen someone with hey, what’s going on with this dude? Well, he’s housed (Indiscernible *00:32:28) room. MR. Ee : But when you would visit the SHU, was that something you would address “sr saying how many single MR. a : I'm not the SHU lieutenant. only if cells do we got? 7] > SHU lieutenant? MR. a : I'm talking about -- lieutenant -- MR. a : -- when you do EFTA00110740

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LIMITED OFFICIAL USE 47 1 rounds. 2 MR. a: -- you do the rounds, you 3 only say it if you know that someone got - a 4 new come in. Okay, you got space for him. No. 5 Right now, we’ve got to put him in a single 6 cell, or something like that. 7 MR. a : Okay. And were you ever 8 9 10 MR. QJ: | sveah. 11 MR. QJ: 91 don’t think 2 never SHU lieutenant. WwW 5 fe) x it) kK tw Cc rt Qo ie) ‘ 2) oc 4 remember ever having any 5 — 16 No. 7 MR. ae : -- at the MCC about fos) i] ue] n rt 0) po 45 fu 3 a. =a P 7) Qa 0) ea bt 3 fu ct 1) La] 0) Q co p- ta] i) 3 i) 5 rt 20 MR. QM: N0? All right. So, 21 referring to the duty assignment roster, who 22 were the MCC’s supervisors on duty, with 23 responsibility for overseeing the SHU on August 24 9, when you were working? MR. ae: It would be me and i. EFTA00110741

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LIMITED OFFICIAL USE 1 MR. QJ: so, the two of 2 be responsible? WwW a oO 5 jon FY] watch. Yeah. 4 MR. a : Okay. And then, 48 would would it 5 be the same thing for the shift after 6 Would that be the activities’ lieutenant and 7 the ops lieutenant? 8 MR. QJ: 9 Yeah. 9 MR. a : And is that because, when 10 the SHU lieutenant is not there, activities’ 11 lieutenant and ops lieutenant always have 2 oversight of the SHU? 4 make a round. F w a wm = Q > rt 16 MR. QJ: «on seu. Yeah. 20 correct? 21 MR. ae: Yeah. Pretty much. Ww 7] ~ a H rr fe) pe 2. Oo cS 0 > ny 0 dt rs) 7 MR. ae : But that would be the 8 lieutenants - they would be the lieutenants 9 that would have oversight over the SH 22 MR. ae : Okay. On August 9th, 23 what communications did you have with any of 24 the other lieutenants with regard to Epstein 25 being housed with the MCC, or the MCC Can EFTA00110742

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LIMITED OFFICIAL USE 4 its] 1 you recall? 2 MR. QJ: No. a : And again, thinking back, 4 this is like one o ies) i Ph the biggest things that’s 5 ever happened when you were there, this gi 6 dies. Can you remember any conversations you 7 had the day before, with anyone, with regards oO 8 to Epstein? 9 MR. a : I just know that he used to 10 come to legal all tt time. 11 MR. Ee : Yeah. MR. ae: Attorney conference, pretty the whole day. 4 MR. QJ: Right. 5 MR. a: And that’s about it. And about what time would N Fs Ww 3 G a > t oO a 7 he be moved to attorney conference? MR. a : Early. Like, probably 8:00 in the morning. 20 MR. Ee : And who would be the 21 person that would move him there? co J wo 22 MR. QJ: 9The sHu staff. Get him out EFTA00110743

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LIMITED OFFICIAL USE 50 1 MR. QJ: And what would the - as 2 the activities’ lieutenant, did you visit him 3 at all in attorney conference, or check on him? 4 Is that part of your round process? w a It’s not part of the rounds, oO ion is] cr Bb hh ke fe} Cc see him in there, if you standing by 7 the elevators or something like that, yeah. co Fs) Okay. MR. a : But you’re not - you don’t have to check. No. 11 MR. Ee : All right. Did anyone wo i=) 2 ever provide you with special instructions, 3 with regards to Epstein? 4 MR. a: Special instructio Like? Something - no. With special instructions? a io t oO a Lee) 5 9 Like -? 20 MR. QJ: bike, conversations with 21 Epstein, hey, make sure you do this ust 22 Epstein, make sure this is going - you know? 23 guess specific instructions. Maybe “special” 24 isn't the right word -- 25 MR. EJ: No. EFTA00110744

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LIMITED OFFICIAL USE 1 MR. Ee : -- but did anyone ever wo rary 2 specifically say, you know, this is Epstein, 3 we've got to make sure we’re doing this? 4 MR. QJ: 9omm-mm. No. Not that 1 Ww iad oO Q fu bh f 6 MR. a : No? Did any lieutenants ever talk to you about Epstein’s requirement to wo F Hmm-mm. I mean, it’s not -. i=) Like I said, we’ve got the email. 2 MR. ae: There’s no one saying, 3 by the way, from my understanding didn't he 4 have a cellmate up until then? I think he had a 5 cellmate since he got out of the suicide watch. 16 So, I don't think there was a lapse in it. 7 MR. QJ: Right. 8 MR. a : Yeah. 9 MR. Ee : So, what about up until 20 then? You’re saying, so -- 21 wR. QJ: «Right. The cellmate, 23 MR. a : -- so, what is your understanding of what happened -- MR. ae: What happened? ho No w EFTA00110745

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LIMITED OFFICIAL USE 52 w ~] MR. Ee : -- on August 9th? MR. a: His cellmate went to court, and either went to transferred, or got released, or something. And never came back. And then, you know, that night, he went out, he went without a cellmate. MR. a : Okay. MR. QJ: 9 Yeah. MR. a : So, we’ll get into that. I’lla f I you a couple more questions, then, just to make sure we stay on kind of page, at the bottom of this page, you see, we’re going to start talking about that inmate. And I’1l just - what you knew about that. You said the lieutenants are responsible for conducting rounds. Are they responsible for conducting counts in the SHU? mR. BR: No. MR. Ee : No? So, like, just around, nothing to do with counts when you were -? MR. a: Count is for officers. MR. a : Okay. And you don’t need to oversee them as the lieutenant, or anything like that? EFTA00110746

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LIMITED OFFICIAL USE ~] wo 10 11 uw ios) MR. a: You could take a count, but usually, you’re doing patrol, you’re not doing the count with the officers. MR. QM: «Right. So, in physically presence in the SHU, the only time that the lieutenant is involved is actually with rounds, not with counts? MR. a: Not with counts. MR. a : Okay. And did you conduct any rounds in the SHU, on August 3, 2019? MR. a: I'm not sure. I can't MR. ae : You don’t remember? Again, you’re placing yourself back on one of the biggest incidences, and you know all this circus that’s been going on since that time. MR. a: Yeah, I know. MR. Ee : So, you can't really put yourself back on that day of, like, hey, what was my involvement with this, and did I -? MR. QJ: No. No. TI had no involvement with this. MR. a : Well, that’s what I mean, but you -- EFTA00110747

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LIMITED OFFICIAL U 2 MR. a : You were the activities’ 3 lieutenant, know, on the, you know, the day Oo 11 MR. a: If I did a round, 15 18 MR. QJ: «411 right. And it’1l be, you didn't EFTA00110748

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LIMITED OFFICIAL USE wo wi 1 being required to have a cellmate since his 2 cellmate was gone? 3 MR. ae : You’ re talking about that 4 day? 5 MR. a : Yeah. 6 MR. ae: Or you’re just saying -- 7 MR. a : On the day that -- 8 MR. a: -- I can't remember. 9 MR. a : -- okay. All right. The 10 people that are in the SHU, are they 11 responsible for conducting counts and round 2 during their shift? 3 MR. QJ: Yes. far as the shift that its) 15 you worked, on day watch, what is your 16 understanding of how many rounds and counts 7 they should have done? 8 MR. a : There’s no counts on day 9 watch. 20 MR. QJ: Okay. What about the 21 rounds? 22 MR. a: The rounds, every - you’re 23 doing a certain shift, we go about. So, you do 24 one, say, like, 8:00 to 8:30, you do one. 8:30 25 to 9:00, you do one. EFTA00110749

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LIMITED OFFICIAL USE 56 Nh 5 ies) oO wd 0 oO o e] 40 minutes. 5 rounds with tt 6 you did or not? 7 supposed to do 8 rounds with them. No. 9 MR. ust 10 do your own ro Do our round in SHU. t ioe) Fs) 17 MR. ae : You can't recall? Would it be abnormal if you didn't? 19 MR. a : I can't recall. 20 MR. Ee : You can't recall if it 21 would be abnormal if you didn't? co 24 MR. a : Would it be abnormal? I mean, 25 I'm not the SHU lieutenant. That’s what I'm EFTA00110750

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LIMITED OFFICIAL USE w ~] ive) J uw saying. MR. a : But there’s no SHU lieutenant, you said, that, you know, you or | | would be responsible. So, I'm saying, would it be abnormal if you didn't do it? So, would you normally have done it? I know you said you’re responsible for it. MR. a: No. The lieutenants are responsible, but if a Monday through Friday, if a SHU lieutenant is there, there’s no reason for me to go up there. MR. a : But there’s no SHU lieutenant. MR. QJ: «Right. So, but I don’t recall if I did a round or not. No. MR. Ee : Okay. But the last question wasn’t that. I'm saying, would it have been abnormal if you didn't do one? I know you can't recall it -- MR. BJ: 9 Yeah. MR. a : -- but would you normally have done it, if there’s no SHU lieutenant? MR. QJ: 9 yeah. MR. a : Yeah? So, knowing yourself, you probably would -. EFTA00110751

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LIMITED OFFICIAL USE 58 1 MR. a: If there’ 3) no SHU lieutenant, Ww Ps) ry ke w a Ss o did you become aware 6 that inmate || was removed from ~] .] What is -. 9 a] only thing I heard is, I I woke up, they’re ing, I saw the ioe) 16 MR. QJ: 91 didn't have 17 MR. ae : So, the activities -- its) No. 24 MR. a : Not really, no. if who i) a Fa O a oO ' n EFTA00110752

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LIMITED No No No ies) w co ive) co wo ion) OFFICIAL USE un \o MR. QJ: = Rep. MR. a : Okay. And do you remember who was working in R&D that day, in ceive and Discharge. that morning? MR. GJ: No. MR. a : Are you able to tell by looking at that -- -? How does that do you find out who was in R&D for that day? On that morning. MR. a: That’s the custody roster. ure. What would that roster be 5 called? I don't know. MR. You’re hat’s not our department. individuals bring them to R&D? EFTA00110753

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE you say, hey, you out If not, the them down. busy movements? First of all, I saying - so, it Brooklyn, or It depends. I need help, 60 If it’s busy, they go up and help SHU crew, take all right, So, if it were at a non- who would have been the SHU crew. And who on that day? mean, for the court depends - that’s what I'm depends on if they’re going to you start early at 6:00. So, that would be morning watch or day watch. MR. a : So, it would be one or the other? And does not - let’s say if it was 8:00 a.m., who would ! Hmm. watch crew. who was on day watch EFTA00110754

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LIMITED No No No ies) w co ive) co wo ion) OFFICIAL USE Epstein from his refresh remember speaking about - any of MMM: 811 right. and Who was the officer-in-charge, out of According to this, it was , it’s a. All right. I'm going you a memo that was written by | the subject is, that inmate | | was going WAB, and may not return. Also, that inmate will be needing a cellmate upon arrival attorr visit.” your memory? Did you have any EFTA00110755

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LIMITED OFFICIAL USE a ie) Who would have made 4 | aware that | was going WAB? ies) a 5 MR. a: He could see it on the 6 roster They send a sheet up the night before. 7 MR. a : So, if that’s not on the 8 night before, if on the night before, there’s 9 no WAB - and this is at 1:50 p.m. that this 10 notification was made note - if there’s no WAB 11 -. Well first of all what’s WAB stand for 2 MR. ae: With All Belongings. 3 MR. a : And if WAB is not next to 4 a’ name on the night before, the August 8th 15 roster, how would have he become aware at 16 around 1:50? Would normally the court call 7 R&D, and R&D pass that information along? 8 MR. a : R&D could have called him. 9 MR. QJ: So, would R&D call sHu 20 directly, or would they typically call the ops 21 or activities’ lieutenant? 22 MR. QJ: 9 They call the sHu. 23 MR. QM: They do call sHU 24 directly? They wouldn’t call you guys, and you 25 would have to the pass information on? EFTA00110756

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LIMITED OFFICIAL USE 63 1 MR. GJ: No. 2 MR. a : Okay. So, is it your that if it’s that, in fact, what WwW on o be bh o Hh . rt a o S 4 happened, if || went to court, and then he w on oO Q w =| @ Re w =) Cc n rt tell me, what is your oO c 5 ron oO 4K n rr w o on pe =] Q I \ 7 MR. ae: I'm not sure how that or 8 MR. a : -- of how that would e. wo is) a] tan 10 MR. a: I'm not sure about that. 11 MR. Ee : Yeah. I'm not sayir specifically, how he got it. What would be the g , N ive) typical way that would work? If an inmate -- 4 MR. a: If an inmate -. 5 MR. a : -- goes to court -- F oO i} | 7 MR. ae : -- and then is released. Mm-hmm. Lee) 5 wo a3 How does that process Once that inmate is released, what 21 happens from that point, for the court, how do 22 they make the notifications k to the MCC, 23 all the way down to where that inmate was 24 housed? Specifically, this one in the SHU. 25 MR. ae: R&D. Hey, that guy’s not EFTA00110757

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LIMITED ies) w co ioe) co OFFICIAL USE MR. a : And then, woul typically say, now WAB, would that be would use, or would th something that specific to the was called and told? MR. a: I'm not sure. I don’t Like, hey, I’ve oe 7 H 1) b A + a D Q oO £ in] + hb = t b t But d you have any conversations with a: know. didn't EFTA00110758

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wi LIMITED OFFICIAL USE 6 1 MR. Ee : No? And you seem pretty confident with that. Not like I can't recall. ies) You did not have any conve w 6 with him. 7 MR. a : What about with | og || about rsations witt co io coming back? 10 MR. : Pfft, I can't recall that, 12 MR. a : Did you know that | had left that day for court? 16 you not know that he was not coming back? 17 MR. a: No, I didn't know. No. a : Okay. And you don’t actually did a round in the SHU ioe) b @ 5 F ts 8 o 3 0) 3 a o wR bh rh that he wasn’t there? 22 MR. ae : So, can you recall any ou had that day about | og I don't think I had no EFTA00110759

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LIMITED ies) w co io ioe) co OFFICIAL USE 6 oy you can't that day about | og MR. QJ: nd you don’t had any? All right. this. w -- so, jl to clarification. how would get to know the court MR. a: The court list. Who creates in R&D over there, right? EFTA00110760

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LIMITED OFFICIAL USE 67 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a: No. But R&D creates the court list. And what do they do with that court list? MR. a : They send it out to all the units. So, you get one. If you’re a unit officer, you’ll get it and say, okay, I got three guys leaving, because it says WAB. So, you say, hey, wake up, we’re packing up, and leaving. MR. a: They send the whole list, or they just did the email saying, hey, these are the inmates leaving from here? MR. a : Yeah. I’ve never seen an email. I’ve just seen the list. MR. a: Okay. And it’s just, like, a generic email that goes out to everyone? MR. a: It’s a call list. MR. a : But - sorry, I want to make sure that I understood what you just said - is it provided by email, or is it provided by MR. a : I’ve never seen it provided MR. a : -- so, you’ve never seen it on email. It’s just a list that’s provided. EFTA00110761

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LIMITED ies) w co wo ive) co OFFICIAL USE 6 co So, who - R&D comes and gives it MR. QJ: §=oInternal. Yeah. MR. a : So, on this date, would you know who would have been Internal? Who would have provided that to the SHU? MR. a : I see who’s Internal, but I'm not - I don't know if they would have it. We’ve got two Internal i) MR. a : And who are the two Internals? It sanitation. MR. a : Now, isn't the list EFTA00110762

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LIMITED OFFICIAL USE fo)) ite) i] B- ct 1 typically provided the day before, or is i) 2 just created the day before? et 7] ies) a I don't know. I can't -. 4 it provided the day before? 6 MR. ae: It was provided the same day. w 3) 8 MR. QJ: 9 You get about - 9 morning watch the day of. 10 MR. QJ: «1 was always - I was 1 under the understanding that the night before, 5) 3 8th, they would create the list for ive) the morning, on the August 4 MR. a: Yeah. 5 MR. a : -- was that a correct understanding? 7 MR. a: I'm not sure. All I know is, if you’re an officer, you get it 9 MR. Ee : All right. 20 MR. a: Because when I was an I used to get it the day of. 22 MR. QM: «411 right. And you've 23 worked in the SHU before? Do you know -- oO co EFTA00110763

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LIMITED OFFICIAL USE 10 1 worked in the SHU, it would come in that 2 morning? 4 MR. a : Around what time would it arrive? Ww o wu w the 7 know th 8 MR 9 MR. 1 morning watch. 2 MR. ae: Yeah. Morning watch. ay. And are there ive) Fs) at that time, arou t o Fs K 4) w x 7 MR. ae : And is that the same Les] ue) om Oo 0 aa i.) re} c 4 U rt be be i) o jon morning watch duals are the ones that would probably ovided the court list? 23 MR. a: Yeah. 25 document maintained anywher is that EFTA00110764

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LIMITED ies) w co io ioe) co OFFICIAL USE 71 MR. QJ: No. MR. a : Is that, like, uploaded in any kind of system? MR. QJ: §9Not that I know of. o, do you know who - -- do you know who, in n that person? EFTA00110765

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 72 would be? MR. a: No. But they had a supervisor. I know that’s their position, but I don't know who it is. MR. a : And that would be, like, fw bh im cu] c ct oO 3 w 5 rt MR. QM: Who would -? MR. a : Lieutenant is custody. R&D is non-custody. MR. Ee : Explain to me what R&D MR. a: That’s Receiving and MR. a : Yeah, yeah, yeah, yeah. MR. ae: So, they deal with the inmate movement, the inmate courts, the transfers, the self-surrenders. MR. Ee : And you’re saying that they’re not called lieutenants or anything. What are their titles? 5 £ m ifs 2) Hh n Correctional sy ms icer. 5 Correctional syst om m 7] officer is] And, like, a supervisor, would they still be, like -? EFTA00110766

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LIMITED OFFICIAL USE 73 1 MR. a: Supervisor correctional ies) a And would that be, like, 4 a nine or an 11 type of -- wi aw Something like that. 6 MR. a : -- position? All right. 7 But they’re just outside of, you said custody, 8 underneath -. What is wo underneath? Ww Nm oO Oo = wu And they have correctional 4 officer, a correctional worker, as opposed to is a correctional officer. t oO a Okay. And who would b oO Does the captain also have oversight over fw Les] rt a i) 3 wo a oO 20 MR. Ee : Who has oversight over 22 MR. QJ: The cmc. They have a 23 supervisor. 24 MR. a : What does the CMC mean? 25 MR. ae: Correctional Management EFTA00110767

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LIMITED oO io ioe) oO oo wo OFFICIAL No. been a : Okay. And tt a : And you don’t remember rsations at all. So, you tions with || abc ae: No. Not that I remember. Ee : No? But he would h EFTA00110768

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LIMITED No No No ies) w co ive) co wo ion) OFFICIAL USE 75 its] you had any conversation MR. ae : No. I don’t remember MR. a : So, did you ever receive saying -- ng you didn't know anything at that point in time. you know about | being remo MMC? MR. ae: I just know he went to court, h fer came back. And t atl was if. Do you know any 5 information about who was informed that he wasn’t coming back? 5 wn oO o om S ny] Hh rt oO Kh rt is m fact, MR. a : Do you know anything -. EFTA00110769

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LIMITED ies) w co ive) oO co OFFICIAL USE om is ts] a ag a u © Q wv o fe) Ee rt . hey, No? There wasn’t even a that’s I mean, thing. don’t recall him going - I didn't know he was he was going WAB. onally - didn't know of ott And I lot don’t think a ople did, w 7 vy a. August 11th, So, like, on did an August 12th, you and say, hey, did you wasn’t coming back? you ever been No. EFTA00110770

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 77 MR. QJ: 9 No? Did you have conversations with people like i. or i. or anyone, regarding this matter, after Epstein was found? MR. a: What matter? MR. a : Epstein being found, and not having a cellmate? MR. GJ: No. MR. a : No? You never talked to anybody in the institution about that? MR. a: About him not havi cellmate, or are you talking about him being ga MR. ae : No. About him not having MR, ae: I mean, not in we sent a, hey, what happened, or, like, what fw i} H 3 oO w s happened to his cellmate? Oh, he got released. Okay. It was - he said it like that, but nothing -. No. Not like that. MR. ae : Was it any conversation of, like, hey, they put a new cellmate with him? MR. a : No? So, if, at around EFTA00110771

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LIMITED ies) w co ioe) co OFFICIAL USE 78 MR. a: That’s what I'm saying. That’s the time. That’s I'm looking at this is MR. Ee : Should have he communicated with either or || about that? MR. a : I don't know. I don't know how he communicated with. MR. Ee : No. I'm not asking who he did. MR. a: I mean, I know when I was OIC, and they h didn't to the lieutenant, I could I mean, you’re telling me, I'm the EFTA00110772

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LIMITED OFFICIAL USE \o 1 OIC. And okay, I got the notification. he didn't pass nothing Ww 5 u : | I U Oo bh ht Is it abnormal that he uw a 6 didn't pass it on, though? Should have he passed it to you? Because -. MR. a: It’s not. It’s co ts) 3 oO w o | t i=) Fa Could have he placed 1 another inmate with someone like Epstein? 2 MR. ae: I'm not sure because then, 5 WABs get cancelled. WwW wu Q fw a 3 a r n fu Ke n Me, 12] it) n m7 o pa 5 16 1:50, we don’t 7 know until after, like, hey, who is this 8 coming back? R&D is open at 8:00, 9:00. 9 MR. Ee : So, about what time would tification that, ok 25 MR. a : And is it some - when EFTA00110773

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ies) w ~] oo wo i=) ive) w say after 4:00 - is it usually between 4:00 and MR. ae : After 4:00. Any time after MR. a : So, anywhere from 4:00 to MR. a : After the count. MR. a : So, after the 4:00 i. MR. a: After the 4:00 i. count. MR. Ee : And why is it after the count? MR. a: Because that’s when the guys come back, after the count. We do the 4:00 count. And then, you get an (Indiscernible *00:56:31) base count change is like this. You get 20 guys came back from court, this WAB got cancelled. MR. Ee : So, as far as the 4:00 count, or is it at that point, do people start saying, where are thes oO guys, and start making calls, are they coming back or not? MR. QJ: «at 4:00? No. MR. a : No? So, when is the next time that they would be listed on that count? EFTA00110774

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LIMITED OFFICIAL USE 81 w ~] wo 10 11 MR. a: The 9:00 count. MR. a : The 10:00 count? MR. a: Oh, the 10:00 count. Yeah. MR. a : Do you want to ask some more questions on that line? I'm just trying to -. Because I thought it was at - I felt people have told at 4:00, that’s when they start if] making calls to say, is this guy coming back or not. That’s not your understanding? MR. a: Why would you make a call at 4:00? MR. a : Because you’ve got to know if they’re coming back to the unit or not coming back. MR. a: Well, the count, 3:45 is over. So, you’re in the unit or not. So, at 4:00, we do the count. After the count, that’s when the guys come in from court. MR. QJ: Okay. MR. QJ: 9 That’s when we get the guys coming back to SHU and going back to their units. MR. a : And would you be - would anybody be notified, prior to 4:00, that people were, or were not, coming back? EFTA00110775

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LIMITED OFFICIAL USE B82 w ~] wo 10 11 ive) MR. a: Not to my understanding. No. MR. a : All right. So, to your understanding, it’s not until 4:00 or later, that this, you know, people would know || was not coming back? MR. QJ: Ss vean. MR. QJ: «411 right. so, it doesn’t come back after 4:00 .. who, on that daily assignment roster, would be responsible for making notifications, or determining that Epstein needed a cellmate? MR. a: I mean, the notification is here. We already have the notification. MR. ae : Yeah. I know you’re pointing to the email that ys that he requires to have a cellmate. What I'm asking is, okay, now 4:00 on, at some point after 4:00, you’re saying | - it’s known that | | is now not coming back. MR. J: 9 m-hon.. back, but he’s not coming back. Who would be ibly not coming to responsible for placing - for making notifications that, hey, 7 i out, Epstein if] does not have a cellmate, we need to start EFTA00110776

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LIMITED OFFICIAL USE 83 1 making some notifications? 2 MR. a: I mean, I don't know. 3 There’s no notifications. That’s if he doesn't 4 have a cellmate, we give him a cellmate. 5 MR. a : Yeah. So, what I'm 6 saying is -. 7 MR. a : But the lieutenant is not 8 saying, hey, by the way, you know? If they 9 catch it, they’1ll say it, but if they don’t -. 10 MR. a : And I'm not saying it’s - 11 - 2 MR. QJ: 9 Yeah. 3 MR. a : -- a lieutenant’s 4 responsibility. What I'm asking is, whose 15 responsibility is it? 16 MR. ae: To say, hey, this guy, get him a cellmate, or make a notification? 8 MR. a : Yes. Like, who would be 9 the first one to know that 7 is no longer 20 there? Would it be the SHU? 21 MR. QJ: ss’ say Rab. 22 MR. ae : So, R&D would be there. 23 What is R&D’s responsibility, at that point? 24 MR. a : Oh, hey, we’ve got all the 25 inmates back. It’s such and such. And that’s EFTA00110777

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LIMITED OFFICIAL USE Ww a) saying would ant, w ie] 2) 3 P- 3 W isn' I'm io would say calling “= EN.» ae: SHU, 5 ioe) 4:00, who w t = wu is) mh ct oO K t n Fy) t o Ae} ia i) ct tom om ory ke 19 three were likely noti 20 MR. BJ: «ot'm 22 weren’t notified, at w 23 || isn't coming bac I’il 25 MR. 84 Then they’re not coming But be would R&D ’ they say, t coming ba not SHU directl All right. as working? fied? not sure. Okay. And if they hat point would they k? And how would they be EFTA00110778

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LIMITED OFFICIAL USE 85 10 11 12 13 14 16 18 19 20 21 22 23 24 notified? MR. a: Because usually, all the inmates are by then, you know, talking to the lieutenant, hey, is anyone else down there? That’s like a follow up call. MR. a : Is there some point when they should be saying, hey, this guy left at 8:00 this morning, he’s still not back? MR. a: No. You said, is it at some point? Yeah. MR. a : So, and at what point is that? Is it during a count? Or is it just - is there, like, you know, duties that they’re doing prior to the count, where they’ve got to make sure people are there? How does that work? MR. a: I mean -. MR. ae : You've worked in the SHU, so from your recollection, from when you worked in the SHU, how would that work? Especially being that MCC is a jail, not a prison, where people could, at any time, be released or moved. How does that work in the SHU? MR. a: I used to have, like, that, I think, set by 8:00. MR. a: I'm sorry. What did you EFTA00110779

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LIMITED OFFICIAL USE 8 on 1 say about 8:00? 2 MR. a: By 8:00, is when I say, hey, 3 is anyone else coming up? And this is the base 4 count. Like, I want to get everything straight 5 in the computer. 6 wR. I: okay. 7 MR. QJ: 91/11 say by 8:00. 8 MR. a : And on that date, when 9 those three people were working, who would 10 typically be responsible for doing something 11 like that? Is it, like, SHU one, SHU two, two 2 three, or is it just anybody, any one of them, 3 or how does that work? 4 MR. QJ: §9=To do what? 15 MR. a : To say, like, hey, we’ve 16 got to make sure our base count is correct. 7 MR. a: I mean, it could be any one 8 of them. 9 MR. Ee : Any one of them? 20 MR. BJ: 9 Yeah. 21 MR. ae : But it’s not like 22 someone’s job? It’s just someone should take 23 that role. 24 MR. a : I mean, but they 25 have the base count right, for the 10:00 count. EFTA00110780

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LIMITED OFFICIAL USE oo ~~] 1 MR. Ee : So, one of those people 2 should have got the base count right, but it’s 3 not one specific person’s duty? Or is it 4 something that they’re supposed to collaborate 5 on all together? 6 MR. ae: I mean, it depends. It 7 depends. If you’re working, hey, such and such 8 (Indiscernible *01:02:01). If you’re number 9 two, you know, you go to the board, you could 10 change it yourself. You know, the OIC. All 11 right, you know, making sure everything is in 2 order. ive) MR. here an OIC on that = wu is] rt 4 night? w MR. 16 MR. a Zz a a : mm: - a 8 MR. So, | was the OIC? 9 MR. es. 20 MR. : So, technically, he’s 21 probably the one who should have been 22 responsible to catch the fact that their base 23 count changed, and he wasn’t coming back? 24 MR. a : I'm not sure about that. 25 Because he was non-custody. I'm not sure. EFTA00110781

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LIMITED OFFICIAL USE 88 2 MR. a: Because, you see, he’s non- 3 custody Mine was non-custody He’s just up 4 there for overtime. So, I'm not sure wi md a Cc tan wu Now, as far the Oo lieutenants’ job. So, at that point in time, 7 it was ft that was the ops, and | hat 8 was the activities. What is their role in 9 ensuring that i is, one, back; and two, 10 Epstein is placed with a new cellmate? 11 MR. a: Yeah. 2 MR. a : Do they have any role? Or is it all on the SHU? 4 MR. a: I mean, it’s - they don’t ive) 15 have a role. You know, it’s -. 16 MR. Ee : What about when they’re conducting their rounds, as part of their 8 responsibility to say, to check that kind of 9 stuff, or is it just to see what inmates are 20 there, and that the inmates that are there, are 21 22 MR. a: Pretty much. You’ve got to 23 do a round. 24 MR. a : Does that round entail a cellmate and P| 25 verifying that Eps EFTA00110782

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LIMITED OFFICIAL USE 89 wi ~] 10 11 12 13 14 16 17 18 19 20 21 22 23 24 isn't there? MR. a: I'm not sure of that. We just know we do our rounds. MR. a : So, that goes back to, what does a round entail? Does that mean that you need to verify that the people that are on the books are there, and other people are removed? MR. QJ: 9s ves, with staff and accountability. For the most part. You know? Inmates banging, hey, all right, I’11 be up, doing my round. I1’11 deal with this when I get up there. MR. QJ: | But when you say for accountability, what does that entail? MR. a: Presence of inmates, depending on who goes up there. They know, okay, this is on - they try certain things, they won't try certain things. MR. QJ: Are you comparing a list of the inmates that you know to be in the SHU, with who’s actually in the SHU? MR. a: No. Not for a round. No. MR. a : No? All right. So, as far as a round conducted by a lieutenant, would EFTA00110783

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LIMITED OFFICIAL USE 90 1 they know - would 2 that | was removed? MR. ae : Depending on what time the 4 round was. MR. a : And can you give me more 6 explanation? What time would that change? ies) w 7 MR. ae: If I do an early round, and oo i] ue] 77) r i) } 3 s in a cell by his self, 9 have time, still doing court movement and it 10 wouldn’t raise no suspicion or no alarm. 2 time would there be a suspicion or alarm that it what ive) d? be rais 4 MR. a: I told you. At about oO t fea) m3 Ke oO w x fee) oO w 0 a) 20 MR. PF : Okay. Were 21 provided any instructions on what actions 22 should be taken if || was removed as 23 Epstein’s cellmate? 24 mR. GR: No. 25 MR. a : What actions sh¢ EFTA00110784

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LIMITED OFFICIAL USE 91 1 been taken once || was removed? 2 MR. a: Hmm. Honestly, I mean, like 3 I said, we bunk all the inmates together. So, 4 if he was removed, look for him a new bunkie. 5 MR. a : And is that something - 6 should have they notified - when they say look 7 for a new bunkie, I'm assuming you’re talking 8 about the people in the SHU? wo F Yeah. A new cellmate. Yeah. i=) a So, I think you said 2 MR. QJ: 9 Yeah. Could have they placed ive) Fs) 4 him with a new cellmate, or would have they had 15 you make notification to the ops and/or 16 activities’ lieutenant? 7 MR. a: You know, they don’t need to co make notification. 9 MR. Ee : What about when someone 20 is high-profile as an inmate as Epstein? 21 MR. ae: No, he didn't make 22 notification. 23 MR. a : So, you don’t think that 24 they would have. Do you know if Epstein’s 25 cellmates were vetted by the captain and above? EFTA00110785

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LIMITED OFFICIAL USE 92 ~] wo 10 11 MR. a: I think I heard something like that. I think so. MR. a : Now, does that play into that answer? About if they could have just placed anyone with him? MR. a: I'm not sure. MR. a : Okay. MR. a: But I think someone vetted like that, pre-approved or something like that. I think - I'm not sure - but I think I did hear something like that. MR. a : Okay. But to your knowledge, they could have placed anyone with him? Not anyone, but, like, they could have placed a new inmate with him. MR. a: Yeah, they could have. MR. ae : Okay. Should have they? MR. a: I'm not sure. Like you said, the whole vetted thing, yeah. I'm not sure. MR. QJ: So, if they knew that | | was vetted, and was placed with him, at that point, should have they done anything else? Such as called the lieutenant to say, hey, he’s not back, we need to get him a new cellmate. Can I place someone with him, or EFTA00110786

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LIMITED ies) w fos) Ww oo OFFICIAL USE should have they he u. c i) rt own? watch - were day Fh would o MR. but if you expected them to notify w ot) action on their know. you were - I know you were ev @ ning watch, you? notified them by telephon did the You sai Yea If Call, ctivities ay wa rt Dp it) w they Now, of them? e, or when one of ir rounds? d should they have? h. would hav Yeah, email, whatever. someone like -. ’ lieutenant that EFTA00110787

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LIMITED OFFICIAL USE 94 w ~] ive) lieutenant, she was an SOS, do you feel that she had the knowledge and capabilities to be able to do that job, at that time? MR. a : What job are you talking MR. a : Activities’ lieutenant. MR. a: Yeah. I think she wa training, right? MR. QJ: well, 1 -. MR. a: I think she was training. 7) It’s that temporary post, right? MR. QJ: sso —-«. MR. a: Yeah, but that still wouldn’t be on her, though. MR. a : If she’s the one who did round in the SHU for her shift. MR. a: Yeah. MR. a : Is that something that she should have checked on? Hey, where’s | og wu There’s nobody in -. Because not only - I mean, everyone knows what cellmate Epstein is in. So, even if Epstein’s not in there, and he’s still down at attorney conference, nobody is in there. So, shouldn’t that have been something that you’d say, hey, where is this EFTA00110788

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LIMITED OFFICIAL USE 95 w ~] 10 11 12 18 19 20 guy? Is he coming back? Should that be something that was -? MR. a: That kind of depends on the time. MR. a : And when you’re saying that you just mean because he possibly could be coming back? MR. GJ: = ves. MR. a : But if no one is there, and she knows he’s out at court, shouldn’t she at least have followed up on, hey, anybody check on him? Is he coming back? MR. QJ: «Well, that’s R&D. R&D notifies us if they’re coming back or not. MR. a : All right. So, when doing rounds, that’s not something being that, hey, we’ve got to make sure that Epstein has a cellmate. Not something that should be, like, a, hey, nobody’s in Epstein’s cell. What’s going on there? MR. a: I mean, that’s what I'm saying. We get this notice, not just with Epstein, with every inmate -- MR. QR: okay. MR. a: -- that comes on suicide EFTA00110789

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LIMITED ioe) w io ioe) its) OFFICIAL USE wo o watch. MR. a : So, did you ever see - you were visiting the cell - did you ever see this sign up in the SHU? MR. a : And I'm showing jy you a colored note, saying, “Mandatory rounds must be number MR. QJ: 4.11 right. nothing you All right. If that EFTA00110790

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LIMITED OFFICIAL USE 97 10 11 12 13 14 16 18 19 20 21 22 23 24 that’s why. MR. a : I was just going to say, if that is up for people to see, doing rounds in the SHU, does that change any of those answers of, hey, where is Epstein’s cellmate? MR. a: I mean, this is - if it’s rounds - that’s something different than me saying single bunk. So, if they’re saying we’re doing rounds on them, that wouldn’t make them to think about, why is this guy - where is his bunkie? MR. a : You don’t think so? So, if you’re actually looking into his cell and saying, you know he needs a bunkie, I'm looking in his cell, and there is no one else with him, you don’t think that those are correlated? MR. a: Yeah, but not because of this. No. That’s just saying rounds, hey, make sure you do your rounds. MR. a : It says specifically -- MR. a: Than when it’s not -- MR. a : -- rounds on -? MR. a: -- yea, but normal, it’s not going to think just because - it’s not going to mix this with this. EFTA00110791

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LIMITED ies) w co wo ive) co OFFICIAL USE MR. looking ’ h o fact s by Tell me have suicidal behavior or attempts in the SHU, So, even though th in on Epstein, seeing that he’s that won't alert them Not that sign. No? You don’t think says, “Mandatory rounds.” cellmate? I can't recall. What about the hot hot list is inmates s that as ue] io co Do you know of any other saying that he was art, check out the hot EFTA00110792

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LIMITED OFFICIAL USE 99 1 when they would go down there? 2 MR. a: No. We would just - no - we would just check to see if it’s updated. listed on the hot list. 6 MR. QJ: 9 n-hon. 7 MR. a : What does that, then, 8 tell these people working in the SHU? ies) w oO a He needs a cellmate. 10 MR. a : And do all of them know, 11 if Epstein’s on the hot list, those people need nN Qo iu) b be =] rT] rt i) n I'm not sure if all of them ive) Fs) 5 MR. a : But are the know. Yeah. 7 MR. QM: 11 right. t oO a Hi Q Oo ct 8 like the hot list is even more important t 9 the sign I just showed you, for cellmate 20 purposes? 21 MR. ae: This sign? Where the s 22 come from? 23 MR. a : If this sign was in the 25 MR. ae: You said “if”? EFTA00110793

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LIMITED OFFICIAL USE 100 1 MR. Ee : -- well, I'm not saying - ies) a > a uw 5 w at isn't. I'm just saying, assuming that 6 this was in the SHU. 7 MR. J: 9 vn-hon.. MR. a : What wa 10 This, I don’t think th 11 MR. Ee : You don’t think that was co was up there. ' Ww Fs) oO 15 MR. ae: I mean, not in no tier or 16 nothing like that. 17 MR. ae : Okay. But a th ound, like, co officers -? o 19 MR. a : Tr is up there, 20 But what about, like, up rea? Would you be around 24 MR. : Hmm. I mean, if I had to. But you didn't notice EFTA00110794

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LIMITED OFFICIAL USE 101 w ~] 10 11 12 18 19 20 that -- MR. a: But not normally. MR. a : -- in the desk area? MR. J: No. MR. a : All right. Where would the hot list be located? MR. QJ: So, behind the desks, like, a wall we have, that we keep it up there. MR. a : All right. And they’re supposed to be checking that, and making sure those people are, one) checked on, and two) have cellmates? Is that the purpose? MR. a: The hot list is just any - it’s pretty much any inmate that comes from the housing unit. They come from the housing unit. This guy psych alert, hey, make sure this guy gets a bunkie. That’s the initial check. That’s what the hot list is for. MR. Ee : And are they supposed to hat list every day, to make those same - rr check MR. a: I mean, you don’t - no, you get up there, it’s, hey, on the suicide watch, is he on the hot list? So, it’s not common to check it every day. No. EFTA00110795

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LIMITED OFFICIAL USE 102 1 MR. QJ: «411 right. common to check it every day? ies) a Every day, no. Unless it’s w a Only when it’s updated, fon) he Oo c 2] a o 0 tae f rt 7 MR. a : Yeah, if the guy is still on co mm wo F But wouldn’t - again, the i=) fact that the MCC is a jail, a prison - 11 wouldn’t it be pre regular that people are 2 being moved in and out? Not on the hot list. 4 MR. ae : No, but the people that ive) Fs) 15 they’re bunked with. If they’re required to 16 have a cellmate -- 7 MR. QJ: 9 vm-hon. -- wouldn’t it be pretty Lee) 5 9 regular that they would have to - their 20 cellmates might be leaving? Because if it’s a 21 jail, not a prison. 22 MR. QJ: 9 Yeah. 23 MR. a : So, that’s what I'm 24 saying. So, how are they always ensuring that 25 those people that are required to have EFTA00110796

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LIMITED ies) w wo i=) N ive) oO co ho No w OFFICIAL USE cellmates have cellmates? MR. a: That’s when got a single cell up there. MR. QJ: and at viewed? 6 oO to be a daily No. morning. if I know, You know? Well, At night, during the day, and then Some people come back, time that they do it, Usually, come I'm going to - who’s in come back from Wouldn't you u wu for ~ 0) te . HH what point is that cells? Is that supposed that - what time that’s in the in, the single cell? Even when people are left court? some people don’t. that be another or they don’t do it at EFTA00110797

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LIMITED OFFICIAL USE 104 1 that time? 2 MR. a: I mean, I mean, like I said, 3 after that cut off time, that’s when you start 4 saying, okay, we’ve got a single cell, of such 5 and such. Then again, remember, MCC get 6 inmates throughout the night. 7 MR. QM: they do? 8 MR. QJ: 9 Yeah. Placed in the SHU? wo F 11 MR. Ee : Okay. And you didn't work that night. Do you know of any people N ive) that were placed in the SHU that night, on 4 August 9th? 5 MR. a: No. Not according to this, oO = O 7 MR. ae : And did you conduct any counts or rounds in the SHU on August 93th? co I can't recall. 20 MR. Ee : And what is the purpose? wo a3 21 Why do conduct counts and rounds in the 22 SHU? No ion) 5 4 Oo 3 fu Se! oO sure they’re alive. everyone is there? EFTA00110798

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LIMITED OFFICIAL USE o a 7 MR. 8 documented? io 10 MR. 11 rounds? t ioe) a) o 7] oo 19 MR. 20 MR. Ee : -- so, are counts t rar wu K oO there, 22 out? 23 MR. 24 MR. 25 MR. 105 And are cells and counts unds documented? Yup. And how -- Probably. -- how are tt 30-minute log in in Trus 30-minute log for And what is the TruSc Rounds. That’s rounds, as well? You put rounds in there, too, Who fills them out? EFTA00110799

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LIMITED ies) w co io ioe) co OFFICIAL USE 106 MR. Ee : And what do they do with to Internal. does Internal come to go to Internal? It depends. work in the SHU know how to properly cond ie) 3 a i ie] rt Should they know how to conduct counts and rounds? there « And how should they know? Training. D ot enough training to know how to do a wQ count and a round? EFTA00110800

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LIMITED OFFICIAL USE 107 1 people, like, filling out count slips, or round 2 sheets? Either before, or at the very start of 3 their shift, for their entire shift, or at the 4 end of the shift for their entire shift? Not before this incident. 6 MR. a : Did you hear about that 7 after this incident? 8 MR. QJ: 9 Yeah. What did you hear about w a wo F mean, it was filling out slips. It wasn’t N ive) counted. Wasn’t making rounds. 4 MR. ae : And who was it that you 5 heard that wasn’t conducting counts and rounds? 7 MR. ae : Anybody else in there? Ma: 9 MR. Ee : Did you hear anything Lee) 5 20 about counts and rounds not being conducted 21 prior to midnight on August 10th? So, any time 22 on August 9th, did you hear about any of those 23 counts and rounds not being conducted? 24 MR. a : On the morning watch then? No w bd a : Any time on August 9th. EFTA00110801

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LIMITED ioe) w io ioe) its) OFFICIAL USE MR. MR. MR. know MR. MR. MR. ot) MR. om Pp Q k re) is | | Ww ri) fw > ! = Pry 1 rr wu No. nt, the counts not being 108 10:00 i. count, rd tt I don't know. Not that Right. So, what I'm wasn’t done? Right. Now, do lieute EFTA00110802

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LIMITED OFFICIAL USE 109 1 the counts or the rounds? 2 MR. a: The rounds. Not the counts. ies) a So, what is the 4 lieutenants’ responsibility for si Q ning the w round sheets? 6 MR. ae: Making sure they’re in compliance with the policy. 8 MR. a : All right. And do they 9 have to - is there any way for them to verify 10 if the rounds 11 MR. a: Hmm. No. Unless you’re 2 doing a - checking a video. 3 MR. a : You just - is what you do 4 is just to make sure that the - it’s actually 5 filled out? f Co w a fe) 5 H oO is} rt } oC 7 MR. ae : Correctly filled out? All 8 right. I'm going to - I apologize for this, 9 it’s gotten a little longer - so, I'm going to 20 show you. What is this that I'm showing you? 21 MR. ae: It’s a round sheet. 22 MR. QJ: 411 right. And what is No 5 4 ST 0 wo th No w bd The 9th. Did you have EFTA00110803

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LIMITED OFFICIAL USE 110 nything - well, as the activities’ lieutenant - would of you had anything to do with signing would of oO wo 11 MR. Ee : Where is your signature? ' Ww c rs] ie) t o Bs F co rs 22 MR. QJ: | You can't tell by looking 25 MR. a : All right. And around EFTA00110804

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 111 what time would of you signed that? Do you know? MR. ae : Some time on my shift. MR. a : All right. So, does that indicate that you would have, then, conducted a 1) MR. ae: I'm not sure. MR. a : Would of you signed that MR. Ee : How else would of you MR. a: I'm not sure. MR. ae : So, is the SHU sheet ever sent outside of the SHU for the lieutenant to sign? MR. a: I'm not sure. I can't recall MR. Ee : But what I'm asking is, like, have you ever signed one of these round sheets outside of tt Ps) Oo 5 b w bh rt ct het te] fw i?) fw bh = le ct a fu rt the lieutenant would sign the sheet in the SHU? i Because aren't they maintained in the SHU? u EFTA00110805

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LIMITED OFFICIAL USE 112 1 MR. a: Typically, that’s what would 2 happen. WwW 5 w is) ypically, you would 4 have signed this in the SHU. Correct? oO w a a Sd it) w x ' And would of you signed 7 this after the last one was filled out? I'm 8 assuming they wouldn’t fill one out after you 9 signed it, would they? I'm not sure. i=) a N i) Wouldn't that typically mean that you ive) would have been there at least 2:00? 4 MR. a: I'm not sure. 5 at this 16 that if 7 it? Do you 8 ever sign -. Are these continued to be filled 9 out after the - sorry - after the lieutenant 20 signs it? 22 MR. ae : So, even for day watch ho So, you can sign it at No w bd EFTA00110806

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 113 any point during this, and then, they continue to fill it out? MR. | : Yeah. And that’s a) All right. what I'm asking. How does that work? I don't know. So, I'm asking. MR. ae: I mean, it’s MR. a : So, at any point, from .. you could eight hours. 8:00 a.m. until basically have signed that? Okay. And these are genuine questions. Tt y’re not I trick you. I'm just asking -- MR. a: No. I understand. seem like that, is what I'm saying. But it QA ie} o ta) And then, I'm not -- just asking, like, this isn't, like, an “I gotcha” moment. There’s no -- MR. a : -- I gotcha moments in this. This is just asking for your, like, your Mm-hmm. EFTA00110807

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LIMITED OFFICIAL USE 114 ies) w ~] wo 10 11 ive) recollection on this. MR. a: Yeah, I understand that. But that’s why I said, I'm not sure about that. I don't know when I signed it. MR. a : All right. And that’s - so, what I'm asking you, like, is this something, typically, that you would have done? And again, it’s not an I gotcha. MR. a : Yeah. But again -- MR. a : It’s just, it’s a genuine MR. a : -- I'm not sure. MR. a : -- but so, you don’t know if -. But so, most of the time, I mean, these are maintained in the SHU, and this is - again - this is our learning experience, by talking to people like you, lieutenants -- mR. QJ: 9 Yeah. MR. Ee : -- that were there. It’s, again, not an “I gotcha.” It’s trying to figure out, how does this process work? MR. a: But also, I'm not trying to incriminate myself. MR. QJ: t got -. MR. ae: Or nothing. That’s what I'm EFTA00110808

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LIMITED OFFICIAL USE 1 saying. I'm not sure. 115 2 MR. a : But what I'm asking, I 3 guess, is just - and I don’t even know what 4 there would be to incriminate you with - but, 5 like, what I'm asking is, like, how does this 6 process work? If you give this person a round 7 sheet, are these round sheets signed in the 8 SHU? 9 MR. a : Typically 10 MR. a : Typically. All right. 11 And are you aware of them ever not being signed 2 in the SHU? 3 MR. a: I'm not sure. Not that I 4 know of, no. 15 MR. QM: «411 right. So, at least 16 more likely than not, you signed this document 7 in the SHU, at some point, between 8:00 and 8 2:00 -? 9 MR. QJ: 9 veah. 20 MR. QJ: So, that means you 21 probably did a round in there? 22 MR. ER: Yeah. All right. And if it was 24 between 8:00 and 2:00 .. both | and 25 Epstein were not in their cell at that time, EFTA00110809

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LIMITED OFFICIAL USE 116 w ~] wo 10 11 then, correct? MR. a: Okay. MR. a : I mean, this isn't, like - again - an I gotcha. I'm just trying to figure out, like, where you fall in this whole thing. MR. a: So, that’s what I'm trying to figure out. Where do I fall in this whole thing? MR. a : Because this is your idea. That’s what we’re -. We’re talking to you just specifically about, all right, i was gone, at some point, he goes WAB. We don’t know -. MR. a: So, you’re trying to say who’s to blame for it, or -? MR. a: Well, it’s also just trying to figure out what happened. We’ve got to talk to -. MR. QJ: de left. And that’s what happened. MR. ae : Right. And you, when you were there, there was no conversations that you had with anyone? MR. a : No conspiracy. No. It’s not EFTA00110810

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LIMITED OFFICIAL USE 117 2 MR. a : No, no, no, and we’re not Ww fu if) a h- 5 iQ | | 4 MR. ae: -- nothing like that. -- for a conspiracy. wi aw 6 It’s just, we need to know who, what conversations happened, where, where did the -- 8 MR. a: I didn't know nothing about it until after I saw it in the nei 10 MR. a : And this is also me 11 showing you this now is more letting you know, wo 2 like, okay, that looks like you probably were 3 help spark recollection? 4 I had no conversation with 5 neither one of them that day. Not that I 16 recall 7 MR. ae : None of them that day? No. Lee) 5 wo a3 All right. you tell, 20 does this look like an RCS to you? 21 MR. ae: I don't know who -- 22 MR. ae : Why don’t you have a look EFTA00110811

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LIMITED OFFICIAL USE 118 1 watch, there was all a. i. i a. 2 a. As well as a . Does that look like any of those people to you? 4 MR. ae: Hmm. I'm not sure. Okay. All right. So, ies) w a 6 you do not recall. And as we go, do you mind 7 just initialing or whatever? Okay. You got 8 those, too, if you don’t mind initialing this, 9 and this, and this. Now, although it is 10 voluntary, I guess, we do ye to just make 11 sure we know, it also has to be the answers are 2 truthful, you’re under oath. So, that also - 3 so, lack of candor can also be constituted by 4 not providing full information or, like, hiding 15 information. 16 MR. ae: No. If I remember, it’ll - 7 and I don’t hide nothing - but if I remember, 8 then I will say it. 9 MR. Ee : Okay. 20 MR. QJ: 9 But when you come with these 21 -- 22 MR. ae : So, it’s just -- 23 MR. a: -- saying it looks like, hey, 24 by the way -- 25 MR. a : -- and again -- EFTA00110812

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LIMITED OFFICIAL USE 119 1 MR. QJ: 9 -- yeah, and if I'm, like -. 2 MR. a : -- our purpose, you would have been interviewed a lot earlier, if there ies) 4 was, like, you know -- Oo wm ‘2 2 a a * o wu J \ = | ion = ia o ct 4 u o ct } I b b i} 1 7 MR. a : -- I know, I know being that 8 day, I know it was a big profile case. Hey, 9 let’s get such and such, they fill this, and 10 then -- 11 MR. Ee : Yeah, yeah. 2 MR. ae: -- and I'm, like, come on. 3 MR. a : And we just need to know, 4 like, as, you know, we've got make sure that, 15 like, hey, what you do remember, you can tell 16 us. Again, it’s voluntary, but, like -- 7 MR. QJ: 9 Yeah. 8 MR. a : -- all right. So, these, 9 I'm going to give you these count slips from 20 August 9th up until midnight of August 10th. 21 And is it your understanding that ZA on the 22 count slip, that stands for the SHU? 23 MR. QJ: 9 yeah. 24 MR. a : All right. Can you just 25 kind of look through those? I'm going to move EFTA00110813

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LIMITED ies) w oO wo i=) N ive) oO co No N N ion) OFFICIAL USE 120 certi th to in seen today. aside for you, so the papers don’t get of mixed up. them back to you, a. eah. (Indiscernible K MR. a : (Indiscernible MR. a: What am I initialing for? To wv rt MR. a : So, when we initial these s, it’s just to say what we showed you. fying anything, or that you received ing. It’s any document we place in you, what we do for everybody. We ask them itial and date this -- MR. a : -- no, that today you’ ve this, not ve seen it before It’s just that, today, while we’re J ‘ Ps EFTA00110814

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LIMITED ies) w wo i=) N ive) oO co ho No w OFFICIAL USE talking we're di starting. gave So, you? Is 121 A to this is in fact the document if n you, were talking about. Okay. a : It’s not certifying its It’s not saying you saw it before It’s simply to say that’s the document scussing right now. a: And I'm looking for this for a : Thank you, sir. Ee : So, look at the ZAs, So, you’re - what is this one that I the - this is the 9th at 5:02. So, 5:00 count. a.m. So, okay, so, I gave you a.m. count on the 9th Can you just ook at the numbers? You can look at that - what’s this first page called? All right. look at oO, And then, look at the count slip for when you're looking at El, just make EFTA00110815

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 122 note of what is the number that says o 3) a ct a 0) tf t ~ and then, go back to probably the last page, maybe the second to last page, for each, and look at the ZA number, to make sure that it matches with what the El shows. And I just want you to do that for the one -. You said the El and the what? 5 Ps) : 4 ae ea os @ a io} = 5 rt 0) bh c ue} nm w 5 oO bh s ct D oO MR or the second to last MR. GJ: = wher morning? that’s 5:00 in the MR. 4 i} i} is) 5 rt a o io rt a U morning So, what do those numbers show? Bo oO 4 oe fe) * i] N o J od ie) ~) v oO rn) Bb rt w ny] y both of them, 5 On the El, yeah. a) All right. Cool. Now, EFTA00110816

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LIMITED OFFICIAL USE 123 1 you can just initial and date that, and move it 2 aside. Again, these aren't I gotcha moments. 3 These just help us explain some stuff. All 4 right. So, this El, well, can you tell me what 5 it the ZA on this one? And this is, 6 what, the 5:00 i. count? What is this? 7 MR. 8 MR 9 MR mean 10 MR But yeah 11 So, that ZA is 75. 2 MR. a : 75. And the last one was 2 77 5 MR. a : And what does that f Co 5 _) Sal 7 MR. QJ: 811 right. 75. Cool. 8 Can you just initial that and put that on the 9 side? And you’1ll understand the question after 20 you look at these. And again, it’s not an I 21 gotcha. It’s to help us explain something. ho No w bd a : The count changes, and EFTA00110817

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LIMITED OFFICIAL USE 124 1 I'm going to ask you how you can - if there’s a 2 way for you to be able to figure out how this 3 count changed. All right. Can you look at the 4 El on here, and compare it to the count slip 5 back there? What is the -? 6 MR. ae: And it’s the 10:00 count, ~] oo Fs) 10:00 i. count on Ks] A=] o a c uw ct io ct a 11 MR. Ee : 73? On both? And is there 2 a count - does the count slip say something 3 weird on that one? 4 MR. a: No, I'm just looking at the 15 seven 16 MR. Ee : Does it say, like, 73 plus one on there? 8 MR. a : Oh, yeah. It does. 9 MR. Ee : Have you ever seen a plus 20 one on any before, or could you understand a 21 reason why someone will put plus one? 22 MR. a: Plus one. No. I don’t know 23 about a plus one. 24 MR. a : All right. Now, this is 25 the one that I really want you to look at. EFTA00110818

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LIMITED OFFICIAL US ies) w ~] wo 10 11 ive) 4 125 Look at this El This is now August 10th at midnight. Check out what it says for ZA on the El. What number does that say? MR. a : All right. And check out MR. a : What does the count slip say? MR. a : So, 73, but the top one, that was clear, it says MR. J: 9 vm-hon.. MR. a : And I’1l give you one more, just so it’s not a magic trick, look at this page first, for the August 10th, and I have the rest of them, too, if you want to see them, but 3:00 a.m. on August 10th, and then, the last page where it says the count slip. What does it say on the El on the next one? MR. QJ: nd on the El. And then, MR. a : So, in looking at all this, does that tell you - as a lieutenant and someone who worked in the SHU - does that tell EFTA00110819

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LIMITED OFFICIAL USE 126 w ~] wo 10 11 you something? MR. a: Yeah, but the thing is, this one had up, though. MR. a : That’s exactly -- MR. a: That way and clear the count. MR. a : -- that’s exactly right. So, we’re trying to figure out where did this count change down the 72? And does it indicate to you that these counts were not actually conducted? And this is not -- MR. QJ: 9 (Indiscernible *01:33:00). MR. a : -- and MR. a: It’s the 9:00 count. MR. ae : -- we have no reason to believe you were involved in this. So, I want ct hi n = n =] Oo rt I i to make sure you’re -. We’re actually just looking for your help here. As someone who worked in the SHU, and as someone that is familiar with these kinds of documents, can you help us put this puzzle together? How - so we have reason to believe that they called in at midnight 73 -- MR. QJ: 9 Mm-hon. MR. a : -- and the control lieutenant, who was working that night, figured EFTA00110820

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LIMITED OFFICIAL USE 127 10 11 12 13 14 18 19 20 21 22 23 24 out there’s actually only 72 people in there. They’ ve been calling in 73, but there’s only 72 people in the SHU. Is there any way, from looking - and that’s from this point forward, they’re now start -- MR. QJ: 9 n-hon. MR. a : -- calling in 72 - is there any way, from looking at these, you’re able to determine, with your knowledge and experience, where that changed? I would say that it changed from the 10:00 count. This was 5 printed at 9:33. So, it has 73. And then, at 9:33, attorney conference ain’t open. So, Epstein would have probably been up by then. He would have went back to the SHU. MR. Ee : So, he would have been listed on -. Epstein would have been back at least by 8:00 .. right? MR. QJ: = Yeah. MR. QJ: So, that would have -- MR. a: So, he should have been on this count. MR. : -- he should have been on this one. MR. a: So, he threw it, yeah. EFTA00110821

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LIMITED OFFICIAL USE 128 1 MR. Ee : And can you see where on 2 the - let’s talk about, I gue ifs) ss, what’s the one ies) before? The 5:00 p.m.? The 4:00 p.m.? 4 MR. ae: Yeah, he would have been at attorney conference. Yeah. w Oo wz a And it would have showed 7 him at attorney conference on one of these, 8 correct? On the El? 9 MR a : Yeah. At 3:00, at attorney 10 conference. Well, from SHU. 11 MR. Ee : And then, does it show 2 that he’s already in SHU in this one? Is there 3 any way an attorney conference at the 10:00 4 p-m. count? 15 MR. a: No. But see, what I was 16 telling you before about the numbers, see how I 7 had 76? 8 MR. QR: xup. 9 MR. a : And this is at the 4:00 20 count. And then, it went down to 73? 21 MR. QM: Right 22 MR. a: So, you don’t know until 23 after the count, about the whole cellmate 24 coming back 25 MR. a : Right. But then, the EFTA00110822

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LIMITED OFFICIAL USE 129 w ~] ive) weird part about it is going from 73 to 72, with no movement. MR. a : So, we don’t know, okay, so, they’re taking off, you know, if they’re going from - what does it say? 76? MR. QJ: Ss vean. MR. a : Down to 73. That’s three people, and one person vanishes. MR. a : When it gets to 72. Are you able to tell where that person vanished from, or is it impossible because, possibly, all of these counts were not conducted, and that’s - I know you weren’t here for any of these counts, apparently, so it’s, again, I'm just asking for your guidance - is that correct? You weren’t even working when any of these counts were conducted? MR. a: Yeah, well, if I was - you said 4:00, right? MR. a : Well, you possibly worked up until 4:00. MR. QJ: 9 yeah. MR. QJ: But -~ MR. a : So, I wasn’t here. I wasn’t EFTA00110823

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LIMITED OFFICIAL USE 130 1 there for the count. 4 MR. a : -- I want to reassure you this isn’t an I gotcha moment. We’re just ies) a w 6 trying to help -- 7 MR. ae: No, no, but you know it feels co i b- a oO k rt oO a a : Yeah, yeah, yeah -- 10 MR. QJ: 39 (indiscernible *01 1 MR. Ee : -- and I get that because 2 you’ve got special agents talking t ive) Fs) Yeah. 4 MR. ae : -- it’s just all about the puzzle together. So, we f fo] = oO oO jen help with people like yourself, to be able 7 to say, what the hell happened? You know what I Les] 3 i) fu =] 9 MR. a : Yeah. Well, there’s also rom (Indiscernible *01:36:28). I 22 MR. ae : And we’ve had other -- 23 MR. a: -- and we hadn’t keyed them 24 out, that’s what it is. EFTA00110824

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LIMITED OFFICIAL USE 131 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. a: Oh, they hadn’t keyed them out. But then, they would have keyed them out. R&D leaves at 10:00. They leave at 10:00. Now, they could have left somebody on, and then came out. Because like you said, it’s no movement. The only way you get it is you key out. Like, key a guy unless somebody went to the hospital or something. MR. a : Yeah, and if there is nothing that happened, but no inmates were moved after 10:00 a. If we know that, does this indicate that they were just going off on numbers and just falsifying their counts, or are you able to tell, by looking at these at all -- MR. a: Mm-hmm. MR. ee: -- if these counts are legit or not? Are you able to kind of, like, give us any insight into that? MR. a: I mean, the one with the plus one is a question because I don’t see why they would -. Then again, you’ve got R&D with a plus one, too. I don't know. I don't know what’s going on. They got R&D, (Indiscernible *01:37:57) cell plus one. EFTA00110825

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LIMITED OFFICIAL USE 132 1 MR. Ee : And by looking at that 2 person in R&D, are you able to tell who that ies) Hmm-mm. wi aw Not by looking at that 7 MR. ae: Not by the name. I mean, Ss no out count. Don’t have the out oO 0 is) c o ct Don’t have the out count? i=) a nN And what time is that ive) Fs) 5 MR. a: Well, I can't - have the out count. 7 MR. ae : No, what time are you looking at? don’t oO co wo 5 out count on it? MR. a: I mean, it don’t add up se - yeah, something is not right - No Nm a No Ww oO i) 0 fu c n 24 because R&D is not on here. Unless they moved. 25 I mean, some time, they say count, but EFTA00110826

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LIMITED ies) w co wo ive) co OFFICIAL USE count mean? key him in, but I'm verifying that he’s down like, the gu didn't have time to here with me, and put him on my count MR. looks likey P| (Phonetic Sp. *01:39:27 Do you know any -- one. its) this Yeah. so, is that somebody’s in R&D, and someone was told to watch that person there, would the person - at 10:00 wo ot) EFTA00110827

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LIMITED ies) w ~] wo 10 11 ive) OFFICIAL USE 134 someone was still there at night? MR. a: Well, yeah, because you could watch them down here, yeah. MR. a : And is that like a small (Indiscernible *01:39:52)? Is it kind of like you’d be able to - that person would know if somebody was there or not? MR. QJ: 9 Yeah. MR. a : Verify it. MR. a: Because someone could have came in before the count, too. A U.S. Marshal could have brung one in, and they said, hey, watch this guy. He’s going to 9-South. That’ why the plus one is throwing me off. MR. a : Have you ever seen plus one on anything before? MR. a: No. I heard people calling in with a plus one. But then, again, I say MR. ae: But it mess up the base count, though. MR. a : -- but seeing, especially looking at the 72 -- MR. ae: Yeah, I don't know how that EFTA00110828

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LIMITED OFFICIAL USE 135 ~] wo 10 11 happened. MR. a : -- and does this at all tell you anything about any of these counts? MR. GJ: «sun. MR. a : Like, we’ve had other people, you know, in higher positions saying, to me, it tells me that the counts weren’t done. Does that tell you that? MR. a : Yeah, but mean, yeah. I don't know, man. Yeah. I mean, t 10:00? Pfft, I wu couldn’t tell you, man. MR. a : All right. So -. MR. a: I couldn’t tell you. know. I don't understand that. MR. QM: okay. So, is it just a baffling type of deal? Because it’s baffling -- MR. a: Yeah. MR. a : -- to us, and then, we’re just hoping that people can kind of help us - don't 4 especially people that were there -. MR. ae: I don’t know. See, that’s why I don’t understand that. I don’t see how they get 73 at the 10:00 count, and then they lose one after the 10:00 count. MR. a : And that’s the same EFTA00110829

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LIMITED OFFICIAL USE 136 w ~] 10 11 12 18 19 20 thing. We’re trying to figure that out. MR. a: Unless it wasn’t keyed in the system. MR. a : At what point - are you able to tell - at what point it should have been keyed in the system by that? MR. a: Well, if a guy came into R&D, and they keyed him in SHU, and then put him back in R&D. MR. a : So if he like went to SHU MR. a: He never went to SHU. MR. a : -- and then back? MR. QJ: 9They keyed him in the SHU. They put him on this count. But he didn't make it. So, the medical and stuff taking the guy out. So, they say, hey, leave him down there, and count him in R&D. I could see that happening. MR. QJ: So if, like, he’s in medical, and they can't -- MR. a: Well, so like, medical comes down there, and they checking him out, and he don’t make it up time in SHU, for the time, seeing they could say, hey, well, I'm not EFTA00110830

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LIMITED OFFICIAL USE 137 1 putting him on our count, put him down there. 2 MR. QM: So, that would be like the ghost count you’re talking about? 4 MR. ae: No, that’s a real count. But if he’s -. ies) w 3) someone put him in there but took him out. wo i=) nN WwW | J wu rt un wy in o 4 MR. ae : And does it 5 in R&D over on this one? MR. ae: Well, there’s no out count, 7 and that’s what I'm saying. There’s no out oO co count with that one. wo a3 oS \ \ So, this R 20 MR. QJ: «RA and R&D are separate. 22 MR. a: You need an out count for 23 this. You don’t need an out count for that. 25 MR. a : But as far as this goes, EFTA00110831

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LIMITED ies) co io ioe) co OFFICIAL we’re looking at the midnight USE i. , right? RAI, MR. MR. and K o ct he you know -- for MR. MR. MR. 0 in] ih oO is] rt rt oO P) » wo =] tr i] fe os wu (Indiscernible wu ct ot om midnight, 5) J rt ct * and the 10:00 So, at midnight, there 10:00 i. but at the Right. two hours earlier, s how they l« > ere is a count slip? y Ae) ) bar Ps) C he talking about? bR lo , ‘s the thing. That it -- isn't the count slip 01:43:21). he top. a yuld have mess had the RA count slip Hh co someone. d or EFTA00110832

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LIMITED OFFICIAL USE 1 that one. 2 MR. QJ: §9=what’s the differ 3 RA and R&D? 4 MR a : RA is a real unit w the guys come back from court, they 6 status. R&D is when they keyed out 7 MR. a: To go to leave? 8 MR. a: To go to court. 9 come back, they came back in their 10 they don’t come back, they release 11 R&D. But RA is technically a unit. 12 MR. a: And it doesn't co 13 it doesn't show up as R&D? 14 MR. a: No. (Indiscernib 15 *01:43:57) 16 MR. Ee : Where would t 17 - that says R&D in there - where wo 18 show up here? 19 MR a: That would be rig 20 But they don’t have nobody in R&D. 21 MR. a : So, there’s - 22 that even weirder, the fact that, a 23 i. count, there’s a count slip fo 24 there’s nobody for R&D on this? 25 MR. a: That’s why I thin 139 ence between . So, when ‘re in RA But if they unit. If them from unt le hat one slip uld that ht here. and so, t the 10:00 r R&D, and k they put EFTA00110833

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LIMITED OFFICIAL USE 140 1 him, and they keyed him in SHU. They keyed him 2 in SHU, the inmate, and then put him down in ies) R&D. And then, changed it after the count. Or 4 they could have changed it right after this w count cleared, and set it up for the next 6 count, say the inmates, the inmate is in - this 8 MR. a : Yeah, that one is the wo b oOo f=) 10 MR. a: Yeah. And you have the Ww N Od K ee fii) n H a it) ct n the midnight one Oh. 7 MR. a: See, (Indiscernible 01:44:44) right here. 9 MR. QJ: 0h, 1 think I took it. 20 MR. QJ: §9=So, whoever was in SHU, they t oO a co * 21 put him, and they keyed him into RA and R&D. 22 MR. QJ: «this is the midnight. 23 MR. a: Yeah. So that’s what happened. ho wi MR. ae: Does R&D have like a dry cell No EFTA00110834

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LIMITED OFFICIAL USE 141 1 or room? 2 MR. a: No, they got cells. You see, wu Qo K k 3 they got RA right here. Yeah, that’s what 4 happened. I think the guy came from SHU and 5 went to RA That’s they lost one. oO a ‘ And can you think of why 7 a person would go from SHU to RA, at that late 8 at night? 9 MR. a : Body scan. Probably pulled 10 something. And they kept him down there, put 11 him through the x-ray. 2 MR. a : And is there any way - by looking at the ive) 3) e - you can see how -. Is there 4 - you said the 4:00 Hi.’ Is the person in R&D at t wi a t oO a 7 4:00 i. Are you able to tell by this? 8 MR. a : Let me see. You know the inmate that was down there or no? 20 MR. QJ: 1 think Fernandez. Is oO 22 MR. a: Was he a witsec dude? 23 MR. a : Do you anything about 24 him? 25 MR. QJ: 9=No, I don't. EFTA00110835

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LIMITED OFFICIAL USE 142 10 11 12 13 14 16 17 18 19 20 21 22 23 24 MR. a: Yeah, but that’s what it looks like. It looks like they took a guy to SHU, and put him in R&D, but instead of keying him in R&D, they keyed him RA. Yeah. That’s what it looks like. MR. a : So, at the 4:00 .. was he anything to do with Fernandez on that, or anything to do with somebody in -? MR. a: Well, the 4:00 i. is - no, because no one is out from R&D. Let me see. You’ve got one from 11-South. You’ve got no one else from R&D. MR. a : But it’s also said that at the 10:00 .. right? Or I don't know which one I'm looking at right there, but -. MR. a: No, you have one out here. Yeah. But it looks like this inmate, from 10:00, they did the count at 10:00. Plus one. Yeah. Plus one. Yeah. It seemed like they got screwed up by something. Either moving this guy to R&D, or whatever. I mean, the count slip shouldn’t have accepted anyway, though. So, in the 9-South, plus one. Like, I don't know why that was written, but -- EFTA00110836

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LIMITED OFFICIAL USE 143 1 MR. a: -- that’s what it looked 2 like. The guy came from 9-South, he went in 3 the RA He stayed there throughout the night. 4 Whoever the inmate was -- 5 MR. a : Yeah, yeah. 6 MR ae: -- right there. 7 MR. a : And we have reason to 8 believe that that is the case. That there is a 9 guy that was in, you know, he did stay there at 10 the night, and he had somebody on him, and 11 that’s one of the reasons why we want to talk 2 to somebody that was in R&D to be able to 3 verify hey, was that guy really there? t wi a And by looking at that, 16 would that be that individual we just talked 7 about? 9 MR a : Yeah. 20 MR. MJ: | Who did the count slip? 21 MR. ae: It’s based on the count slip 22 (Indiscernible *01:48:18). 23 MR. QJ: 9 yeah. 24 MR. a : Um all right. Does this 25 tell you anything else? Just before we move EFTA00110837

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LIMITED OFFICIAL USE 144 1 on. 2 MR. a: I mean just -. I don’t know. 3 Yeah. I don’t know. I don’t understand it. 4 That’s the only thing I think they probably 5 took him down for that then. 6 MR. a : Is there - from 7 looking at these, what basic like counts seem 8 bad to you? Does t! 10:00 i. one seem like 9 a bad count to you? The way that it - what you 10 just looked at? When there’s nothing on the El 11 and there’s a count slip? 2 MR. J: oun. 3 MR. a: If you were working that 4 night and you got a count like that, is that a 15 good count or bad count? 16 MR. ae: I would have said bad count. 7 MR. ae : And who - can you tell by 8 looking at this - who was the one who took this 9 count? 21 MR. ae : | £ And was there 22 lieutenants involved with this? 23 MR. a: I mean there could have been. 24 I’m not sure. 25 MR. QJ: | Bot by looking at it like EFTA00110838

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LIMITED ies) w oO wo i=) N ive) oO co wo No N N ion) OFFICIAL USE 145 I think like probably the midnight one there was an actual ops lieutenant. Are you able to tell that by looking at the - I think the ops lieutenant is the one who caught it at midnight? Are you able to tell that that -? MR. ae: Oh this one here? MR. a : Yeah. Are you able to - by looking at these, are you able to tell when the lieutenant actually took the count? MR. QJ: «ott was - count - | took the count at midnigt MR. QJ: 411 right. And it shows | on it? I’m looking at it upside down so I can’t even see. »k the MR. Ee : And on this one does it show any lieutenant was involved? MR. Ee : So it would just been Does it show the lieutenant’s name on the 4:00 p.m.? EFTA00110839

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LIMITED OFFICIAL USE 146 Ww Hh bh a un ct =) my 3 o bh if) But this does seem like a oO w 3) 7 MR. ae: El seems good. But um -. 8 MR. a : Even though that no one 2 k w bh bh n ct o o Oo 5 ys) e oO nN 5 w @ Q wu Go n @ ct om U =] you say WwW ct J i) K o ifs] wu a fe) & a tt fr] ran pb ue] rh 12] R \ 5 MR. a : Wasn’t that just one that was printed? Oh. Because the numbers a oO ns oO printed on that? fos) id K o wu x wo 5 H ts] © e what you’re saying. =thing changed? 21 MR. ae: So that could be two things. 22 Either the Marshals was trying to get one in 23 before the count and they thought they had 24 enough time to process him upstairs. And then 25 when in the count, it’s wrong. Like EFTA00110840

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LIMITED OFFICIAL USE 147 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 hold on that’s not it. Yeah. MR. a : And that’s what I mean by wouldn’t this be incorrect if they get a count slip that’s not listed on the El? MR. a: Yeah. They got a - which one did they get? R&D? Yeah. Yep. That would be a bad one. MR. a : All right. So for this it seems like the 10:00 i. on August 9th was a bad El and as far as the midnight, it seems like it’s the count slip that’s a bad slip. Is that correct? Whatever that’s (Indiscernible *01:51:13). I’m sorry, I’m in the -. So it seems like the El is good at midnight, but the count slip is bad at midnight for ZA. And we're primarily asking you this stuff just because we’ve got to write a report about what we’re finding. And we don’t want to sound - we don’t want to be wrong. You know what I mean? MR. a: Yeah. Yeah so, the count slip is wrong on this one. MR. a : So midnight count slip is wrong, El seems right. The El at 10:00 i. seems wrong, but the count slips seems right. At least for R&D. I - we have reason to EFTA00110841

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LIMITED OFFICIAL USE 148 w ~] wo 10 11 believe the count slip for ZA is also wrong for MR. a: Yeah-yeah-yeah. MR. a : -- 10:00 i. because -. Well it depends, I guess, like you said, what time the individual was moved to R&D. We’ve been told that after the you know -. People are all moved prior to this time. So if that person was in R&D, it would have been prior to the 10:00 i. count. Does that sound right to you? MR. a: That’s what I’m saying. I mean something could have happened. And you know taken this guy downstairs. MR. a : And that’s why we need to talk to people. So by looking at this, are you able to like figure out who we can talk to? To see if something happened at 10:00 i. to change this count and make this -? MR. QJ: Did you see the log already? MR. a : The lieutenant’s log? MR. a: Yeah. MR. a : Do we have it? Yeah. I have it. MR. a: Anything with log? EFTA00110842

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LIMITED OFFICIAL USE 149 10 11 12 13 14 16 17 18 19 20 21 22 23 24 MR. a : Um so here’s the - yeah. So here’s the log from the day you were on. That’s the August - it says August 10th, but you know it’s the August 9th log in there. Are you able to tell by looking at that? And here’s the day after. So this is the - you’ve got the August 9th -- MR. a: Okay. So moving him to the dry cell. MR. a : -- and the August 10th. MR. a: Okay. So he put someone in dry cell. MR. a : Dry cell is in the SHU isn’t it? MR. a: Yeah. If there’s space. Okay. So it looks like they didn’t key the guy up. He went to dry cell depending on what time. MR. Ee : And are you able to tell by these lieutenant’s - I think you’ve got the actual lieutenant log back there and I would assume that that’s when it should be documented when people are moved. Correct? Are you able to tell by looking at that when someone - you know this person was moved to dry cell? EFTA00110843

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LIMITED OFFICIAL USE 150 1 MR. QJ: Eb. 2 MR. a : Oh. And also if you've 3 got that, are you able to tell by looking at 4 that when you worked until? No? 5 MR. a: No. I wouldn’t have done a 6 log that day from activiti 7 MR. a : Yeah. I just didn’t know 8 if it like mentioned when people - you know ops 9 or activities started or stopped. 10 MR. a: No. It doesn’t say when he - 11 - (It just says Inmate Fernandez on dry cell. 2 It doesn’t say when he went though. 3 MR. a: There’s no time associated 4 with the movement on there? 15 MR. a : Should have there been? 16 MR. ae: I mean that’s good to put in 7 there yeah. 8 MR. a : So you said you wouldn’t 9 have been associated with the lieutenant’s log. 20 Who does the lieutenant’s log? 21 MR. ae: Ops should take care of it. 22 MR. ae : Ops would so on your 23 shift it would have been Jr 24 MR. a : Yeah. But Fernandez is 25 already on dry cell on day watch it says. EFTA00110844

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LIMITED OFFICIAL USE 151 1 MR. Ee : And that’s where we get 2 confused. And that’s why we have reason to 3 believe - because it seems like Fernandez was 4 put on day watch. 5 15. Yeah 6 Does it say 3:15 he was 7 8 Yeah. 9 So that indicates to us 10 10:00 i. count were 11 also both bad. He wasn’t in the SHU. Does 2 that make sense to you ive) Fs) I think he was -. Yeah. He 4 wasn’t in the SHU, but he was he was still w keyed in SHU. 16 MR. Ee : He was still keyed in the 7 SHU, but he wasn’t there? 8 mR. QJ: 9 Yeah. 9 MR. Ee : Right. So for the Els, 20 they would still show it. The only way the 21 people in control would know it is if SHU 22 actually did their count and said we only got 23 72 people in here not 73. Right? 24 MR. a : I mean.... 25 MR. a : Because people working in EFTA00110845

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LIMITED OFFICIAL USE 152 w ~] the SHU. They know hey, we only count bodies that are present. MR. QJ: «0h hold on. This is the 9th. Okay. So he went to -. Transfer to special housing - dry cell at 4:00. MR. a : At 4:00 it says? MR. a: On the 9th. This is done on the night before. Okay. Okay. MR. a : Can you -? And again I promise you, not a “gotcha.” You’re being a very extremely help. Can you just note on there where you’re seeing these different things? If you can tell at what time he was moved? MR. QJ: 9wWell this just looks like the log is the same. MR. ae : We also have reason to believe that people manipulated the log after the fact. MR. QJ: Yeah. That’s what I’m saying. Some things are (Indiscernible *01:57:13). MR. : Do you know anything about that? While I mentioned that? MR. a: No. I see SHU corrections; EFTA00110846

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LIMITED ies) w co io ioe) co OFFICIAL USE 153 Fernandez; dry cell; RA; Saturday. Yeah. So lI mean that’s pretty much whatever. think that the e dial was still keyed in the SHU. MR. a : But as far as -- a 8 a ny Is that wrong? MR. a : Or was it that EFTA00110847

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LIMITED OFFICIAL USE 154 10 11 12 13 14 16 17 18 19 20 21 22 23 24 her? MR. a: I don’t know. I’m not sure. MR. a : Would that be like a possibility? Like can they do that? Even if you’re activities’ lieutenant, if she wants to leave and you’re there and | - who is the ops lieutenant - wasn’t? Can they say that you relieved her even though you were activities’ lieutenant? MR. a : Or is she not supposed to write that? Or not supposed to be in there? MR. a : So who wrote that? MR. QJ: Uh I don’t know. It could be - that’s the thing. It could be a - it’s like a from the days prior. So if you don’t catch it, you just going to keep it the same. So it’s like - because I’m ops - I know I was ops. That’s what I’m saying. So I must have came in on doing overtime that day. So normally I would relieve her. So she probably left it that way anyway thinking okay it’s the same. You’re not changing that. You know? *01:59:23 MR. a: Oh you mean the day EFTA00110848

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LIMITED OFFICIAL USE 155 1 before you were ops is what you’re saying? 2 MR. a: Yeah. I think I was ops that whole quarter though. I think so yeah. 4 MR. a : So you were - that whole r you were ops? Why were you -? ies) w Q = w 6 ct @ 7 MR. a : So overtime was a F Oo wo oe a at ‘e 0 fw p So you were the ops 11 lieutenant up until that day? You were N activities’ lieutenant that day though? Wa id K © wu > I think so. 5 ops, were you also potentially acting as like F oO ct fo) Oo uel H bh Pp. @ G ct oO 5 wv =] ct s in like since Les] id tC B * 0) w 9 that were your normal duties would have you 20 also took - taken that on? Like hey, I know A i] 21 I’m activities, but I’1l do the ops role? And 22 this is, again, just to try to help recollect - I don’t know. a : -- what you were doing. No 5 No w bd EFTA00110849

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LIMITED OFFICIAL USE 156 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a: I think I was ops that quarter though. MR. QM: okay. MR. a : Yeah. I was ops. MR. a : Again we don’t have your records. There was no reason for us to be grabbing your records or anything like that. So everything we’re asking you about is simply to help us fill in the blanks. MR. a: So based on what you said, you think it’s - the log is from previous date. It was just a spite edit that wasn’t caught on to. MR. QJ: Yeah. The dry cell stuff. I don’t know about all that. But that’s what it looks like. It looked like the guy was in there and they didn’t key him out even though he was in R&D. MR. a: So let’s say if I’m in SHU and I wanted to move somebody. Or you wanted to move somebody in the SHU. MR. a : Yeah. MR. a: You’ re going to - do you key it in, or do you call in to somebody and tell them to key it in? Who keys it in? EFTA00110850

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LIMITED w ~] wo 10 11 ive) OFFICIAL USE 157 You can do it by yourself. Is someone supposed to be notified hey, listen You can do it if you want to. And let’s say you move it. this person is moved? Or you - the SHU CO’s can move the inmates by themselves? unit? Someone from a different MR. a: Yeah. Like control or R&D? control. must be notified? but I mean, they taking a count it’s good to No you tell - you can call I don’t know if it’s policy, know. Hey, this is what’s going on - got to move this guy down to dry cell. ahead. MR. QJ: «1 was going to say I guess - are you asking like who is responsible And let’s say - sorry. Go for doing the keying? Yeah who -? MR. : un. SE: It could be CNA. What’s CNA? Control number two. EFTA00110851

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LIMITED OFFICIAL USE 1 1 MR. Ee : Okay. But control would 2 be responsible for him. It’s not ops or SHU uw o ies) that would have been responsible for 4 (Indiscernible *02:01:28). It’s control that w was -- Co 5 could -- I mean J 5 -- responsible for -? u th oo 5 \ \ =] w =f rn} fw t change though. Oo a wn ie could? f c b °o OG K o o wu x H rt A =] is) rt wu =] is) ue. o nN ai 1) ie ie} Oo =] oa rm Oo Pp , b rt y or activiti Ww 5 eal 3 oO D o } rh rt oy oO ie it) w ~ oO 2 H 4 need this guy in dry cell. You know. Okay. You notify them. You know hey, move him. t o Fs Okay. I guess though what we’re saying is like under the regular ctice - I understand that other - some fee) ue] ai a 9 people have the ability to do it. But who 20 s e it 21 MR. ae: Should have moved keyed the 23 MR. a : Yeah-yeah-yeah. 24 mR. QJ: «9 -- suv to Rep? EFTA00110852

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LIMITED OFFICIAL USE 1 w ~] wo 10 11 uw \o MR. a: Uh CNA, control. MR. a : Control should have? MR. a: Number two. Yeah. MR. a : And how should have they been notified that they needed to make that change? Who should have notified them that that change needed to be made? MR. a: Mm. I mean SHU could have called ahead. This guy is keyed up here. He’s keyed down there. MR. a : So I guess what I’m saying is like once an inmate is moved, and control needs to be notified. Hey, this guy that was in SHU is now in R&A. Who needs to notify control to make those changes in the system? MR. QJ: The sHu. Hey this guy is down there. MR. QM: So the suv. MR. QJ: 9 They’11 call control. Yeah. MR. a : Okay. So whenever - let’s say for instance we believe Fernandez was moved from the SHU to R&A on dry cell. The SHU should have contacted control and said we just made this movement. He needs to be rekeyed. EFTA00110853

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LIMITED OFFICIAL USE 160 w ~] wo 10 11 MR. a: Yeah. MR. a : All right. That’s the way it works? MR. QJ: 9 veah. MR. a : And again, these are just questions. We don’t know. MR. a: It could be that or the lieutenant could do it. Either or. Hey, I’m moving this guy. I’m moving him here. MR. a : So should have a lieutenant been involved in that? MR. a: Not necessarily. MR. a : Okay. And that’s why we're just trying to figure out what is the standard operating procedure? Like what is - typically - what is supposed to happen? MR. a: I mean there’s no typical. You get it done. Hey, I’m telling you to move him. Or I say I’m moving this guy. The lieutenant told me to move him. And yeah. MR. a : I guess but if anybody can do it and no one is told to do it, I gue Ss i] - I would assume - that it would quite frequently not be done because everyone would be like “well he could have done it - he should EFTA00110854

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LIMITED OFFICIAL USE 161 ~] wo 10 11 have done it.” I’m saying like who is usually supposed to do it? Who is like supposed to take the lead of - make sure that that’s done or “we just moved this guy - control you know like key that out.” Like how is it supposed to be done? Because otherwise, it’s always going to fall apart because then everyone is going to say. say, well that person could have done it - that person could have done it.” MR. QJ: 9 Yeah. MR. Ee : So is there anybody that’s supposed to do it? MR. a: To notify? MR. ae : Yeah. To make the notifications so that the numbers can be changed on the El? MR. a: Yeah. I would say the SHU f. MR. QJ: su staff. MR. QJ: 9 They kind of say hey, this Ph sta guy is not up there. check to see where he’s at. MR. QM: 4.11 right. MR. a: Maybe key him to R&D. MR. a : Sorry I didn’t mean -. EFTA00110855

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LIMITED OFFICIAL USE 162 w ~] wo 10 11 MR. a: No-no. That’s exactly what I was thinking or trying to get to. You said the 07) SHU staff could also key it in. If they keyed it in, would this El document get updated? MR. a: Well these -. MR. a: Or would control have to update it? MR. a: Control will update it. MR. a: So no matter even if the SHU staff decided if they wanted to update it, control manually has to update this document - specifically. MR. a: Yeah. Put a number on it. Because this is the last one that was printed. And then you make a change after that it’s not going to show. MR. a: Okay. This was -. mR. QJ: 99:30. MR. a: 9:30. But let’s see the 4:00 i. count. I just want to see what time that was printed. MR. QJ: 93:40. MR. a: And according to that, the inmate was supposed to be moved at 3:15? MR. QJ: = Nah. EFTA00110856

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LIMITED OFFICIAL USE 1 w ~] wo 10 11 is) Ww MR. a: The daily log -? MR. a : Well you said two different - I was going to back to that. You said - one time you said 3:15 and the other time you said 4:00 i. Are you able to tell? MR. a: Yeah. It looks like -. Okay. So let’s start with this. This is the wo ct a - right? mR. QJ: ves. MR. a: So you got nobody starting the shift on dry cell. So this says 3:15 inmate Fernandez placed on dry cell from SHU. MR. a : Can you just put a star next to that? All right. So then you believe that that is where things got screwed up? They never keyed him out. MR. a: Yeah. Inmate Fernandez placed on dry cell; 75 in SHU; I do believe .... All right. So at 9:00 on August 9th Friday he goes in at 3:15 in dry cell. And he stays in there overnight. So the 4:00 count, he’s still keyed in there though, right? MR. a : Well that’s what we’re trying to figure out. MR. QJ: 9 yeah. EFTA00110857

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LIMITED OFFICIAL USE 164 10 11 12 18 19 20 21 22 MR. Ee : Because it’s not caught until -. So we believe from people that we talked to, it was caught at midnight. And that person who caught it said like this person is on dry cell and then revised the numbers and the count. MR. QJ: 9 vm-hn. MR. a : Now we’re trying to determine were the counts ever conducted in the SHU? MR. QE: =n. MR. a : It doesn’t appear to us that they would have been. Because they would have caught that at 4:00 J. and the 10:00 i. They would have said this is the number of people we physically have present. MR. a: Yeah but I don’t see -. MR. a : And even at midnight it still says 73. And it’s changed to 72. And to us it suggests - and everyone else that we’re talking to - that we haven’t shared this information with many people. You’re one of a very select few that we’re even showing this stuff to. MR. QJ: 9 wm-hn. EFTA00110858

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LIMITED OFFICIAL USE 165 uw ~] 10 11 12 18 19 20 21 22 MR. Ee : But the people that we’ve showed it to before says, hey the fact that they’ re reporting 73 and the actual count is 72, they’re basically getting the number from this and just writing that down. They’re not actually conducting the counts. Would you agree with that statement? MR. a: They could do that. Or they could actually be counting but not counting. Making sure that they’re just walking and making sure they’re alive. MR. a : So doing more of a round than a count? MR. QJ: 9 Yeah. MR. a : And that is also one of the things that we believe happened. Is that at least on one of the instances, they did do a round, but they didn’t do an actual count. MR. a: Yeah. Because honestly, I don’t see it on this end. A 4:00 and a 10:00. MR. a : You don’t see what? MR. a : Yeah. The fact that they missed both seems very unlikely. EFTA00110859

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LIMITED OFFICIAL USE 166 2 MR. a : If they’re actually counting. Correct? 6 - and it ies) w if) why we believe they didn’t 4:00 a:UU, actually or the 8 midnight No. I mean I’m thinking they o a a ror w o oO ie) i] c 5 ct o rt 7 Qo . o a) 10 did to the 4:00 and the 10:00. 11 MR. Ee : Even though the numbers 2 are wrong? 3 MR. a: Yeah. They probably just 4 went off the numbers. you think -- t oO a What -- 7 MR. a: -- they conducted the round? Lee) 5 They conducted a round wo not a count. 20 MR. QJ: Yeah. Or something. 21 MR. ae : I mean because they 22 miss the number if they’re actually counting 23 numbers both at 4:00 - or all not just both. 24 At 4:00, at 10:00, and at midnight, all of the 25 count slips are wro g. EFTA00110860

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LIMITED OFFICIAL USE 1 ~] wo 10 11 oa ~] MR. a: Yeah but then that’s what those (Indiscernible *02:08:32) to plus one. It’s like they know they got someone, but then it’s like -. Like maybe they was told -. MR. a : But they’re still using the 73 plus one. It should be 72 plus one if they’ re doing that. MR. a: Yeah. Yeah. MR. a : Unless it was 73 minus = one. Then they could do it. But 73 plus one seems to indicate they’re using the number that’s provided -- MR. QJ: 9 On the £1. MR. ae : -- and saying we got one more down there. MR. a: Yeah. I don’t know what was going on with this. That’s baffling. MR. a : All right. To your knowledge, if they’re not doing the count though that’s all on the SHU? The people that are in there right now? Nothing to do with lieutenants. MR. QR: No. MR. a : Okay. There’s no way for like anyone else other than the people in the EFTA00110861

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LIMITED OFFICIAL USE 168 10 11 12 13 14 16 18 19 20 21 22 23 24 SHU -. Or let me ask it a different way. Is there any way for anyone other than the SHU to know that they’re not doing the counts? MR. J: No. MR. a : No? Okay. Anything that you didn’t initial, just again to say what it is we showed you. MR. QJ: 9 (Indiscernible *02:09:41) MR. a : Is this one you or me? MR. a: That’s (Indiscernible *02:09:48) MR. a: So what does this pertain all to - | and a: MR. QJ: Well it’s everybody know. Because everybody that’s in the SHU. Right? We've got to talk to them. Hey, did you conduct these counts. Or these you know? Because this just brought to light the fact that it doesn’t appear that the counts were ever being conducted. So we’ve got to - that’s why we’ve got to talk to the people that we want to talk to first. People like yourself that were lieutenants on duty. Hey, do you know anything about this? Did you - do you know? EFTA00110862

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LIMITED OFFICIAL USE 169 1 MR. a: I mean they wasn’t counting. 2 MR. a : Yeah-yeah-yeah. I know. 3 But I mean just letting you know like, oh yeah, 4 first we want to know about the cellmate. Hey, 5 about this Did you - it 6 From the way 7 assumed that eith 8 he’s WAB. Make sure he gets a 9 Because that’s one of the reasons 10 why we want to talk -. 11 MR. a: Based on that memo? 2 MR. a : Yeah. because like the 3 fact that - He’s saying, I knew. I knew he 4 was going WAB. And I told him. ke sure he gets a co 21 said he’s going WAB. Make sure he gets a 22 cellmate. 23 MR. GE: on. 4 MR. QJ: Bot it you’re saying is you don’t -. You didn’t even like what ho No w ~ D EFTA00110863

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LIMITED ~] wo 10 11 OFFICIAL USE 170 know, and you never had that conversation. MR. a: With || and everything. No. I don’t even know - I never knew the dude until that thing came out. You know what I mean. He would have been notified. MR. QJ: | Right. MR. a : But then again, I mean, we do get notified. But usually R&D calls us up. Hey, those two guys ain’t coming back. MR. a : And is it your belief though by that -? Would it be -? All right. If you said you dint’ speak to him. So probably he was notified directly from control? Or R&D? MR. a: I would say probably R&D. MR. Ee : So R&D wouldn’t call control. And control wouldn’t call him? R&D would call directly to the SHU? MR. a : That’s how we used to do it. MR. QJ: Okay.) That’s how it would always be? So when you were in the SHU - MR. a: They call up -. MR. a : R&D would call you directly? EFTA00110864

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LIMITED OFFICIAL USE 1 wi ~] 10 11 12 13 14 16 17 18 19 20 21 22 23 24 MR. a: But again that’s evening watch. Again that’s on evening watch. MR. RR: | ight. And that’s when it notified. All right. So if he doesn’t have WAB listed on his name on the court list that morning. And that’s what people have told us. So we’re going on the assumption that - and this is an assumption. That he was - somebody was contacted in the SHU saying hey, it looks like he’s not coming back. He did write possibly. But that’s the first that we’re seeing WAB. MR. QR: 0 m-hn. MR. Ee : So the thought is that someone contacted a . We haven’t - we’ve got to talk to him. But like and say, hey, doesn’t look like he’s coming back. You know we're just notifying you now. MR. QJ: «9 wm-ho. MR. ae : And again we were told typically the way it works - and it sounds like you’re correcting us - R&D typically calls control. Control calls ops. Ops calls SHU. ~) BR EFTA00110865

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LIMITED ies) w fos) ive) oO oo OFFICIAL USE 172 s that not correct? MR. a: What. When an inmate doesn’t come back? MR. a : No? It doesn’t work that way? So R&D you’re saying typic go straight to MR. a : That’s a heads up. That’s a court MR. ae: Hey, this guy’s not coming back. Control knows. But usually they call in you call know call me? I don’t know. MR. a : You know? MR. Ee : That’s just what we were told. MR. a: Hey, this guy’s not coming MR. a : And then again, we’re only as good as who the people we talk to. EFTA00110866

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LIMITED OFFICIAL USE 17 ~] wo 10 11 ~) a MR. QJ: «9 vr-hn. MR. a : Whatever information we get is like people like yourself trying to like -. Hey, I know it’s probably like yourself it sounds like. At least in the beginning of this thing, you seemed pretty nervous to talk to us because we’re really just trying to -- MR. a: No-no. The thing about it -. The thing is. I know this. This is a high- profile case, looking to point fingers. MR. Ee : Right-right-right-right. MR. a: Blame someone. Who dropped the ball? Who did this and that? MR. ae : Totally get it. MR. a: I mean two years later, now it’s still like okay, let’s go down and see. MR. ae : And the reason why and I’m sure you saw on the papers what happened recently. MR. BJ: 9 Yeah. MR. a : Well that now allows us to try to come back and try to figure out. All right. Now we can do -. MR. a: Yeah. But you’re going to go after a whole shift. You know. EFTA00110867

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LIMITED ies) w oO wo i=) N ive) oO co No Nm No ion) OFFICIAL USE 174 after the whole shift. But we’ve got to figure out what went wrong at the MCC. And what needs MR. a: I mean -. MR. a : But I get -. Trust me -. MR. ae: Just to deal - they have you know what I’m saying? MR. a : Yeah-yeah-yeah. Totally. MR. a: He just happened to be a high-profile or MR. a : Right. And because it’s so high-profile, and the fact that there were - MR. a: The other things with the -- MR. ae : All these other things are going on now. It looks like there was some false you know slips that were created. MR. ae : They weren’t doing these sig MR. a : Yeah but that stuff is -- MR. a : -- hey, you’re supposed EFTA00110868

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LIMITED ies) w co wo ive) co OFFICIAL USE 175 to check on him every -. MR. a: -- not the normal though. MR. a : Right-right-right-right. MR. ae: That’s not the normal. yeah. And re right. It’s because it’s a high-profile MR. a : I was there used to do that stuff and all 107) H w normal. MR. a : What’s not normal? MR. a: Missed counts and all this MR. a: It’s definitely abnormal. MR. a : When you were in the SHU, were you ever - did you ever le not doing counts? MR. ae : People always did counts when you were there? EFTA00110869

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LIMITED OFFICIAL USE 176 w ~] wo 10 11 ~) oO MR. a : You know and that’s what people - that’s what the conspiracy theorists fu ct come in and all th kind of stuff. Like wow, this is one day? And that’s where we’ve got to -. All right. Well let’s figure out what actually happened. Is this abnormal or is it normal? You’re saying that this seems to be a very abnormal day. MR. a: I’m talking about that’s why the counts and the slips and the rounds and the falsifying stuff like that. But everything else, I mean, this place is a busy place. MR. QJ: Yeah. MR. a: You know? They lose - inmates go out WAB all the time. New inmates come in. MR. QJ: yeah. MR. a: So this is a revolving door. MR. QJ: 411 right. I know we’re taking a lot longer than we thought. Let me just go through a lot of these things now. Just back to the round sheet where -. MR. QJ: 9 Yeah. MR. a : What is the purpose of a EFTA00110870

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LIMITED OFFICIAL USE 177 10 11 12 13 14 16 18 19 20 21 22 23 24 supervisor actually signing this round sheet? MR. a: Making sure the officer is following and doing their rounds how they’re supposed to be. MR. a : And we don’t really need to look at it. Just. All right. So it’s not to verify that they were done. It’s to verify that the sheets are being kept up? MR. a: So if I go up there and I see the times. You all made a round after 40 minutes. What happened here? MR. a : So you ask them about that. MR. J: 9 Right. MR. a : But on this date you can’t - you don’t remember going and speaking to them? MR. a: I said I could have went. don’t recall. MR. QJ: Okay. And again just going forward, know that these are just simply questions to see what we can find out about that day. And as well as you know the point being you saying that this is such an abnormal day. And it was such a big event that’s been EFTA00110871

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LIMITED OFFICIAL USE 1 ~) o 1 in the news now for two years. 3 MR. a : Just try and really place 4 yourself. What was your role on that day? w 5 o ah. Like I said I just 6 know I worked. And that was it. 7 MR. a : All right. And as far as 8 you know, were rounds being conducted in the 9 at that time? 10 MR. a: Yeah. It’s day watch. 11 You’ve got to make rounds. 2 MR. a : On day watch you’ve got 3 to? 4 MR. a: There’s no way you can avoid 5 a round on day watch. 16 MR. Ee : What about for - and I’m 7 not talking about just your shift - I’m saying 8 the SHU in general. Are you aware that rounds 9 weren’t being conducted on evening watch or 20 morning watch? 21 MR. ae: Weren’t? Yeah. Were not. No No Ww Nm OD Evening watch you’ve got to 24 make rounds too. I worked SHU for year MR. a : Yeah-yeah. 103) EFTA00110872

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LIMITED OFFICIAL USE 179 10 11 12 13 14 16 17 18 19 20 21 22 23 24 MR. a: You have to. You’ve got to go. Yeah MR. a : So when you were there they were being conducted? MR. a: Yeah. That’s why I’m saying. The whole mess of the count thing. I’m like I don’t know. That’s -. MR. a : Any of those people that we discussed that were on day watch and you know anybody working in the SHU on August 9th and August 10th. Do you have any recollection of speaking with any of those people about morning watch or -? I mean not morning watch. About speaking with about rounds or counts. MR. BR: No. MR. Ee : No. And now being that you were an ops - the ops lieutenant. It sounds like your quarterly post. Would that be something that you would visit with them and just say hey guys make sure you’re doing your rounds or anything like that? Would that be a duty or responsibility of an ops lieutenant? MR. a: Yeah. But not - it’s not really my responsibility. It’s the SHU lieutenant. EFTA00110873

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LIMITED OFFICIAL USE 180 1 MR. Ee : Yeah-yeah. Did you have 2 any conversations with the SHU lieutenant? At Ww ct : D ct c =| D I talked to the SHU Yeah. 1] w f Bb oO oc rt oO 3 wu o rt 6 MR. a : Yeah-yeah-yeah. Right? co c a Fs) me a] bh 5 t fr] 0] i) 5 J BP 3 un bh 5 0 o 15 MR. QJ: Prior -? No. What I’m 16 asking about is up until August 10th. 17 MR. QJ: 9 vm-hn. co EFTA00110874

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LIMITED OFFICIAL USE 181 w ~] wo 10 11 MR. a : Right. The email saying he needs a cellmate. MR. QJ: Yeah-yeah. And all the lieutenants know. They say oh no, such-and- such we got the email. He was off of watch. You know? MR. a : Do you think it’s acceptable for any lieutenant to say that they didn’t know that Epstein needed a cellmate? MR. a: Some people say they didn’t know the cellmate left. MR. a : No. The - if they’re saying that -. Let’s talk about just the people on that day. Let’s talk about like for instance somebody that maybe wasn’t normally a lieutenant. Can you - a. mR. QJ: «9 m-hn. MR. Ee : All right. So she’s in - you said ba m or) ically she’s in training. She’s like an acting lieutenant. She’s the person -. MR. a: I don’t think she was acting that day either though. I mean MR. a : Well I just mean that she was activities’ lieutenant. EFTA00110875

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LIMITED OFFICIAL USE Sorry. 182 Yeah-yeah. She was the 3 activities’ lieutenant and she was either 4 training or she’s typically an SOS at the time 5 though. Should have she known by Epstein being 6 on the hotlist and Epstein you know coming off 7 suicide watch. Should she have known that he 8 was required to have a cellmate? 9 MR. Uh-uh. a: 11 Should he have kn 12 ve. a: own? ive) aware though. 15 you’re - first of all, 1? MR. QE: Well, No? If I’m not aware ‘ I thought you Just by -? No. What about a: I mean that’s only if you’re the guy left. 4 MR. ae : I thought you said if said that n no. 8 MR. a : Everybody knows that in 9 the SHU you’re supposed to have a cellmate 20 unless you’re a certain classification. 21 MR. a: Yeah. But sometimes it be an 22 odd number and they can’t have one. 23 MR. a : But then the second thing 24 would be he’s on the hotlist. Everybody knows 25 if you’re on the hotlist you’re supposed to EFTA00110876

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 1 oo ios) have a cellmate. Right? MR. a : And then the third thing would be that there’s an actual email that was sent out and that said he’s supposed to have a cellmate So that’s where -. With a that all in mind -. And I’m not -- , MR. a: About the notifications -. MR. Ee : -- pointing to one person out in particular. What I’m just asking is these people that were working. So you’re not like throwing somebody under the bus. MR. Ee : I’m just asking like as far as these people. Should || have known that there should have been -? And I’m not saying that he knew. These people may very well have not have known that J -. I’m just asking like -. 5 feah but I’m thinking. MR. a : In general with their positions. MR. ae: In general. Well | EFTA00110877

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LIMITED ies) w co ioe) co OFFICIAL USE 184 probably never got the email. He knew. Should | have MR. QJ: §=o1 think all lieutenants should know. MR. a : What about -? MR. a: But then again, we all - if inmate’s leaving, MR. a: That the guy’s not coming back or something. MR. Ee : He’s not coming back. MR. a : So that’s where I’m going lieutenants o o EFTA00110878

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LIMITED ies) w co wo ive) co OFFICIAL USE morning, needed a wasn’t a MR. we all kn MR. sounds li happens a cellmate? I lieutenant? Ke ew. |g ke there ll the time though. should could see her not was suicide an email a Because Not only the email though. Yeah, 185 Should J - who she have known that he knowing. And is that because she a lieutenant. Okay. What about not a lieutenant. So should have he known? wn wu bP io] Or knew. Like I You all knew. what about then And It late. w Q i) be ; =] j Should have watch. was sent out to Should have a cellmate. but two and three Like the guy EFTA00110879

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LIMITED OFFICIAL USE 186 10 11 12 13 14 16 18 19 20 21 22 23 24 comes off suicide watch. You put him in SHU with a cellmate. And then again, that’s not forever. MR. a : Yeah-yeah. But in this case, you know, July 30th to August 9th or 10th. MR. QJ: «put is it a set -? I don’t think -. That’s up to psychology. Because we have guys that - suicide watch. Same thing. Once they leave, they didn’t commit suicide and it’s nothing. MR. a : So if you get this email then on July 30th saying make sure he’s got a cellmate. MR. a: There’s no time on it. MR. Ee : In your mind, is that -? Well two weeks from now? He doesn’t need one anymore. MR. a: There’s no set time. It’s just immediately this guy’s coming off. A guy maybe got kicked to the unit. MR. a : Okay. So in his case -. All right. How should it have been -? What kind of notification should have been made then? EFTA00110880

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LIMITED OFFICIAL USE 187 1 MR. a: This is a tough one. But if 2 a guy goes to court and he leaves, you know and 3 you’re doing your daily operations. There’s so 4 much going on. Epstein ain’t the - I know he’s 5 high-profile out to the outside. , oO a i] But I mean he still on Yeah. wo co OD So he’s on the hotlist i=) still. So doesn’t that indicate he needs a ct 11 cellmate? If he’s still on the hotlist. 2 MR. QJ: yeah. But he had one. Ww a ip. QQ a rt 4 MR. ae : Right. And that’s why 15 ying. By - we’re knocking you and we’re 16 knocking || out of this thing because you’re 7 saying 8:00. So let’s now look at 8:00 on. 8 Let’s say - even for this instance let’s even 9 say , and fe they didn’t know. Now 20 let’s look at -MMM. certainly by 21 midnight you should have known. Right? 22 MR. a: Yeah. But not a lieutenant 23 though. 24 ve. SR: «0? 25 MR. ae: Like if the information isn’t EFTA00110881

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LIMITED OFFICIAL USE 18 ao o 1 told to me -. 2 MR. a : But if they’re coming in 3 = You said that they needed to do a around. 4 Right? Don’t these - for this case | or 5 | needed to do a round in the SHU. 6 Correct? 7 MR. QJ: 9 vm-hn. 8 MR. a : Check on all the inmates. 9 MR. a : Check inmates, feeding, or 10 officers - making sure they doing the rounds or 11 got to go to SHU. 3 required to check on all the inmates and do a 4 round? 15 MR. a: When she was probably doing a 16 round. Yeah. 7 MR. ae : All right. So as far as 8 her. that point, now we’ve only got -. You 9 know we’re now -. You know let’s say that 20 she’s the one that corrected you know the count 21 slip. She caught that. She goes. She visited 22 - She’s supposed to go to the SHU. She’s 23 supposed to actually visit all the tiers and do 24 a round? 25 MR. ae: I mean our policy is really EFTA00110882

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LIMITED OFFICIAL USE 189 10 11 12 13 14 16 17 18 19 20 21 22 23 24 to say you’ve got to do a round in the SHU. You know. So you in SHU, you in SHU. I don’t know what did she do. MR. a : And that’s where I was getting to before. Is doing a round in the SHU for a lieutenant - does that mean just walking into the SHU and walking out? Or does that entail actually doing something when you’re in there? MR. a: I don’t think -. There’s no guidance on that. MR. a : So we've had other people tell us that when you - a lieutenant is actually required to walk the tiers and conduct a round. Not to list it on the round sheet, but like it were - like the people who list those rounds on the rounds sheet. Is that you’re understanding of what you were supposed to do? MR. a: I mean yeah. MR. a : So is that what she should have done? She should have walked the tiers and checked on the inmates? MR. a: Yeah. I mean -. MR. a: By policy I’m saying. EFTA00110883

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LIMITED OFFICIAL USE 190 ies) w ~] wo 10 11 ive) MR. a: By policy you’ve got to make a round. MR. a : And that round is classified as like a round like the COs who are in the SHU do a round? MR. ae: I’ve got to double check on MR. a : Okay. MR. a : To tell you the truth. MR. a : And that’s what’s unsure? MR. QJ: 9 Yeah. MR. a : You’re unclear? Okay. And that’s where I’m still trying. Because we've also had less people - but some people have also said no, a round for a lieutenant and a round for a CO is different. A round for a lieutenant is visiting the SHU and checking in with the officers. We’ve had more people say no-no-no-no-no. You need to go into the SHU. You need to check in with the officers, but you also need to walk the tier. MR. QJ: 9 Right. MR. a : And I’m trying to get that like -. MR. ae: It depends on the lieutenant. EFTA00110884

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LIMITED OFFICIAL USE 191 1 MR. QJ: | and then their 2 interpretation? 3 MR. ae : Yeah. 4 MR. a : But there’s no -? 5 MR. a: Like I said that’s why I 6 really don’t - I’1l have to check on that part. 7 MR. a : Okay. And what policy would that be in? Where it would spell that co oO oO c ct That would be in inmate t i=) a 2 probably be in psy 3 MR. a : So it would be psyc! 4 for if the lieutenant needs to do it? 5 MR. a: I know it’s about 30 and everything. 7 MR. ae : But it would also be like a 5 fe) ha ° Q A oO oa | 9 MR. a : But for lieutenants -. 20 MR. Ee : It would also be like a 22 MR. a: Yeah. But I’m thinking it’s 23 more -. You got the polices? 24 MR. QM: Well 1 got the sHu I don’t hz EFTA00110885

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LIMITED OFFICIAL USE 192 1 MR. QJ: oIsn’t it in there? 2 MR. a : I don’t know. I w going to look. 4 MR. ae: Yeah. Let me see. It might w N wu 7] ies) 5 be. Psychology is definitely the 30-minute 6 rounds. I know. 7 MR. a : Again these aren’t “I 8 gotcha.” These are just genuine questions 9 MR 10 MR hology you think it with like lieutenants -. MR. FJ: §9wWell they definitely with the 30 minutes. The -. 4 MR. ae : Yeah. I mean the 5 policy clearly states that rounds need to be N Fs) ive) oO conducted. I just haven’t seen anything that 7 said lieutenants need to do it. And that’s 8 where - I mean you can look through them if you 9 want. 21 MR. ae : If you can -. 22 MR. QJ: «st think it’s in there. It 23 may not be in this, but it’s definitely in 24 there. 25 MR a : Speaking of lieutenants, EFTA00110886

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LIMITED OFFICIAL USE 193 fu tan 0) 1 we don’t need to m you look in this. We’1l 2 look it up. WwW ii 4 a } its] je fo ue] 2) n t orders. 4 MR. QJ: We’ 11 dig into that. wi aw 6 MR. a : But you think it’s 7 probably in the 8 MR. a: Yeah. It’s a round, but to 9 say specific go =ck on and all that. I 10 don’t know if it says all 1 MR. Ee : All right. It just says 2 you need to conduct a round. And then ive) different people interpret it different way. MR. ae: But then again, if she don’t 1 said -. t oO a get the information, I can see it being missed. Lee) 5 Right. 9 MR. a : Because if no one tells me that I 22 know QJ left, I know Epstein is by himself. 23 But I didn’t know he needed a cellmate. 24 MR. QR: 9 vm-hn. EFTA00110887

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LIMITED OFFICIAL USE 194 wi ~] 10 11 12 13 14 16 17 18 19 20 21 22 23 24 you at all? MR. a: I mean. Unless she didn’t read the email or she’s not -. I don’t know how it is. Maybe she wasn’t aware. MR. a : But I mean that fact that - again - those three things we talked about. I understand you say like odd number or you know that kind of stuff. But the fact that there’s an email that went out, there’s the hotlist that has his name on it, and the fact that he’s in the SHU and he’s not one of those. So one of those three, she should have at least known, right, that Epstein was required to have a cellmate? MR. Ee : So her saying I didn’t know. Is that to you like, of course you knew. You’ ve been around for a long time. Whereas -. MR. a: I mean I’m thinking she needs - no one told her. MR. a : No one verbalized it to her. MR. a: Yeah. Yeah. MR. a : But do you think that that’s an appropriate excuse for a lieutenant? EFTA00110888

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LIMITED OFFICIAL USE 195 10 11 12 13 14 16 17 18 19 20 21 22 23 24 Saying that I didn’t know if those three things are in place? MR. a: I’m not sure. MR. a : You’re not sure. And I know you don’t want to like - you know - but like - I’m just trying to reconcile it too. Like alright, if you’re saying you didn’t know, how is that possible if everybody else -. Everybody else I talked to seems to know. MR. a: Then again, I told you the hotlist and all that. That’s things that’s like -. Like the email, even though it’s out, that’s - there’s no timeframe on that. MR. QJ: yeah. But the fact that they’re still on the hotlist, I would think that that would continue because the email went out -- MR. a: Yeah. MR. Ee : -- but then you’re also placed on the hotlist. And if you’re on the hotlist it basically corresponds with that email. Correct? MR. a: Yeah. But the hotlist is for initial. So you get locked up, that’s when I’m checking. I know I’m checking to see if this EFTA00110889

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LIMITED OFFICIAL USE 196 w ~] 10 11 12 18 19 20 inmate is on the hotlist. Initially. MR. a : So only when the hotlist changes? You’re not looking at the people that are still on the hotlist? MR. a: Well I’m saying like if there’s ten on there. anda guy gets locked up - Williams from 11 North. He comes and he just got a psych alert and we make sure he get a bunkie. He got a bunkie. He goes a month with a bunkie. Day 31 we’re not still - you know. MR. a : Yeah-yeah. So in this case you think even July 30th to August 9th when the guy leaves that could be enough time to say he doesn’t need one anymore? MR. a: I mean I’m not psychology. MR. Ee : All right. And you don’t know of psychology making any more -? No one told you -? MR. a: No one specified the time frame - MR. a : I need to -. MR. a: -- about how long he was going to be -. MR. a : Did anyone after July 30th after receiving that email, did anyone EFTA00110890

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LIMITED ies) w co wo ive) co OFFICIAL USE you about Epstein MR. : did Not that No? he in fact t should have told you? MR. ae: I say captain or another lieuten ps on y And one Anyb Anyone. don’t continue to continued like once a 197 needing a cellmate? I recall. who need a cellmate, ychology. hology? Not the It was ant? who in of them. ody? Hey, it’s email. an think that you week or ‘t even think a EFTA00110891

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LIMITED OFFICIAL USE 1 ~] wo 10 11 ite] oo know. MR. a : That was maybe ten days. MR. a: Because I don’t know. I don’t know. I know they (Indiscernible I don’t know their policy. * =) Nm Ww o Ww wo ct Oo Cc n if] oO Because I know they supposed to follow-up. And then there’s steps to it. I don’t know. I’m not familiar with that policy. MR. a : Okay. But you think it was psychology’s - they’re the ones that should have made sure like there’s people -- MR. a: Well they -. MR. a : -- in the SHU and the -. MR. a: They sent out the email to c i) MR. QJ: | Right. MR. a: They notified us. MR. a : But you’re saying like that could be like a day or two. It doesn’t mean that two weeks from there it matters. MR. a: Yeah, I mean. That happens two weeks after that? Yeah. The guy goes to court. He leaves. There’s a time and opportunity. And I don’t think it’s nobody’s fault. EFTA00110892

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 199 You think it’s just -? just don’t think it’s Okay. And do you recall Sign - hanging up saying that he needed a cellmate, or he needed to be 30-minute rounds on him? I definitely don’t recall that. Signs about y saying him needed rounds That’s the rounds. No the one that - And then you don’t -. he was required to have a cellmate. there was a sign saying that Epstein was the tn oO Q co Pp. 6 oO ion ct oO I don’t Could have been. know. I don’t be in the desk area. aware? But you know that there was a hotlist EFTA00110893

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) ve. It’s been there sin hotlist is back the Epstein was on the MR. BJ: ve. GJ: a think. Do we have didn’t even as the 200 o. The hotlist is there. ce I was working there. The re. And that’s about it. And do you know if hotlist? oO. I’m not sure. You’re not sure. o you have the hotlist? : Not with us. No. I don’t it? No. You said you ops lieutenant you don’t recall specific conversations with anybody that worked in the SHU or It was a regular day up - leading from b checking on Epstein to do with Epstein? ve. GR: tried it the first n August 9th or 10th? No? n Specific conversation, no. Y- Yeah-yeah-yeah. I mean asically July 30th to August h. About the -? About the need for or a cellmate or anything o. All I know is when he time, he went to suicide EFTA00110894

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LIMITED OFFICIAL USE 201 1 watch. Came off. And they put him with the 2 other guy. No-no. They put him with someone 3 else. I don’t know. 4 MR. QJ: «So initially he is with - wi } i) h- ct 6 MR. ae: PY he was named. 7 Yeah 8 MR a : And then he went to 9 suicide watch. 11 MR. Ee : Came back on Jul 30th 2 like that. So from July 30th to August 9th. 3 As ops lieutenant or otherwise, did you have 4 any conversations with anybody working on the 15 SHU - in the SHU - on August 93th or August 10th tein? oO about Ep 7 MR. QJ: 9 Yeah. And what were those ts) Lee) 5 9 conversations entail? 20 MR. QJ: Uh you know just hey, leave 21 him with - just gotta make sure they got down 22 here early. You’ve got legal visits. Uh I 23 know he was asking for a phone call. This is 24 like basic you know regular stuff. 25 MR. a : What about with regard to EFTA00110895

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LIMITED OFFICIAL USE 202 1 making sure they’re doing rounds or that he has a cellmate? Did you have any conversations o 3 from the time you got that email on? After you 4 got that email, did you call down to the SHU 5 and say hey, or visit the SHU, and say hey make 6 sure he’s got a - co Fs) Did you -? wo F And I wouldn’t do it if I’m 11 MR. QJ: | Right. 2 MR. ae: You know? Did you take any action ive) Fs) 4 after receiving that email? Did you talk to 15 anybody about it? can’t recall. 7 MR. ae : That email was -. Why t oO a Hi 8 was that email sent out to all the lieutenants? 9 MR. a : I told you. They send it out 20 every time someone comes off suicide watch. 21 MR. ae : Right. So what is the 22 purpose of that? 23 MR. a: For the doing they job. 24 MR. a : So by you getting it and 25 doing your job as like an ops lieutenant. Or EFTA00110896

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LIMITED OFFICIAL USE 203 10 11 12 13 14 16 18 19 20 21 22 23 24 an activities’ lieutenant. What does that - is that something that you’re supposed to make other people aware of? Or why do they provide you with that information? MR. a: I think they required to. MR. a : They’ re required to? MR. a : I think they’re required, or it could be a reminder. Hey, by the way, this guy’s getting released off suicide watch and placed him with an inmate in SHU. MR. a : But is it so you can then follow-up to make sure the CO’s know? Or there must be a reason rather than just for your own information. There’s got to be. Usually you’ re provided information for a specific reason. So why are lieutenants provided that information? Rather than just the SHU lieutenant? Why are everybody else provided it? MR. a: Uh I’m not sure. But they send an email out to everybody though. MR. a : Right. MR. a: Lieutenants (Indiscernible *02:35:05). MR. a: SO that’s what I’m EFTA00110897

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) saying. Well it’s not an all-staff email. It’s like -. MR. ae : No. It’s a correctional services and correctional systems. Right? MR. a : Oh you can tell me. Here I’1ll show you. I thought it was primarily #7) lieutenants. I mean I think a couple SHU staff might be on there. But it’s the three pages behind it. MR. a: Okay. So suicide watch psych observation update. So you got legal in here, food service, case managers, lieutenants, unit team -. MR. ae : So by reviewing that are you able to tell like is there a target audience that they’re -- MR. GJ: No. MR. a : -- sending it out to? MR. a : This is to make everybody aware. MR. ae : Because it’s not an all- staff email though is it? MR. QR: No. MR. a : So who are they sending 204 EFTA00110898

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LIMITED OFFICIAL USE 205 2 MR. a : Like how do they come up 3 with that group of people to send it to? 4 MR. ae: It’s the same way we do the 5 logs We send it to the same group every oO 5 p- Q om ct 7 MR. a : What group is that? 8 MR. a: Then Executive staff, then 9 lieutenants, then psychology, then a 10 assistant, it’s a - 11 MR. Ee : So is it all correctional 2 staff though? 3 MR a: Correctional staff yeah. 4 It’s not all correctional officers though. t wi a So is everybody but the 16 officers? 7 MR. a: You got some officers on here 8 too. 9 MR. Ee : But you’re not sure how 20 they make that decision 21 MR. ae: No. Yeah. You got medical, 22 lieutenants, food service, R&D, legal, duty 23 officer, yeah. I mean I think they would 24 probably do this it’s for your information. 25 Like FYI. EFTA00110899

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE N o C MR. Ee : But you know -. I understand where the FYI. MR. ae : Is that a target audience? MR. QJ: 9 Yeah. MR. a: (Indiscernible *02 MR. a : -- send it to those receiving it. MR. QJ: «9 Yeah, I can’t recall if I spoke to him about it up internal or not. MR. ae : And that wouldn’t be like - that’s not the way it works whereas provide the information to lieutenants and the lieutenants make sure that you provide the information the COs? MR. a : It depends on your area. Like if I’m the SHU lieutenant right now, MR. ae : Yeah-yeah-yeah. MR. a: So they y hey, | this guy’s coming in. Make sure. Okay. Make sure you know. I’m saying directly to the staff I’m EFTA00110900

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LIMITED OFFICIAL USE 207 1 supervising. 2 MR. a : Is it the ops lieutenant’s job to make sure the SHU ies) 4 lieutenant does it? Mm. fon) w a a Is there any oversight there? Does the ops lieutenant kind of have co oversight over the SHU lieutenant? wo F I mean sometimes the SHU i=) on an ops lieutenant. 11 MR. Ee : Oh. It depends on if Wa id he o wu x it’s not 4 MR. QM: 11 right. 15 based upon the position that you’re holding? 16 Like the ops lieutenant doesn’t - like that 7 position doesn’t -. 8 MR. a : I mean we don’t supervise 9 lieutenants. No lieutenant supervises 20 lieutenants. 21 ae : Okay. 22 MR. a: That’s - we have a 23 supervisor. 24 MR. a : No-no-no. And again, 25 these are questions just for us to try to EFTA00110901

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LIMITED OFFICIAL USE 208 1 understand how the operation works here. 2 MR. a: Yeah. And it again, not placing ies) a 4 blame on you whatsoever. It’s just trying to 5 figure out how is it supposed to work? If 6 they’re saying it’s you, are you supposed to do something with that information? 8 MR. a: I mean but the tt ng is they wo Kh is) pa bh g oO ‘on 1 c ue] is] So c o ct bh. be ct a im rt rr bh 3 oO 10 MR. a : What do you mean? 11 MR. a: He had a bunkie up until that N rt b- a tH) ive) Fs) Right. So they put it 4 out. He had a bunkie. And then he didn’t. And t oO a that’s what we’re trying to figure out. Lee) 5 And then (Indiscernible 20 MR. QM: «Who - where was the 21 communication breakdown? Who should have at 22 that time taken action to make sure he had a 23 bunkie? 24 mR. QR: 9 Yeah. wi the whole MR. QJ: and that’ No 3) EFTA00110902

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LIMITED OFFICIAL USE 209 1 thing we’re looking into. Who should have made 2 sure Epstein -? Once || was removed and 3 people were notified that he was removed. Who 4 should have taken action? 5 MR. a: yeah. 6 MR. a : And who in your opinion 7 should have? 8 MR. a: I don’t know man that’s a 9 tough one. Yeah. 10 MR. a : But like even position 11 wise. Not to name names. What position should 2 have taken action? 3 MR. a: Mm. I’m not sure. I’m not 4 sure with that one there. 16 MR. ae: I just - that just -. The guy left and I mean, you know. 8 MR. a : Now I’m just handing you 9 back this lieutenant log. 20 MR. J: 9 wm-hn. 21 MR. ae : You know a few page to 22 back. But um did you - were you involved with 23 that lieutenant’s log? Did you make any 24 entries on that lieutenant log on August 3th? 25 MR. ae: I’m not sure. EFTA00110903

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LIMITED ies) w co ioe) co MR. Ee : Yeah. Are you able to tell by looking at it? Like is that something can make an entry? initials or anything like it show who made No. MR. Ee : No? Does it show ing with regard to || on lieutenant’s log? MR. a: Yeah. MR. a : What does it MR. ae: | to pre-remov MR. ae : And what does that mean? MR. a : Pre-trial remove. MR. Ee : Does that mean that he’s leaving and he’s not coming ba MR. ae: Yeah Yeah MR. ae : What time does it say that? MR. a : Or -. Yeah. Or -. Yeah I OFFICIAL USE 210 rt EFTA00110904

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LIMITED OFFICIAL USE 211 w ~] wo 10 11 MR. Ee : So 8:38. Does that mean at 8:38 pretrial to remove? Does that mean that they knew at 8:38 that he wasn’t coming back? MR. a: Not necessarily. MR. a : What does it mean? MR. a: It means that’s when they put the information in. MR. a : But I’m saying like what the information says. Is that what normally that people are going to court - what it says for them - if they’ re coming back? MR. a: Mm. No. Normally they say it’s taken off the count. Pretrial is removed. So he was taken off the count from 7:00 to 6:00 he was taken off the count. MR. ae : Are people that go to court always taken off the count? MR. GJ: som. No. MR. QJ: So by looking at that, that tells you that he was already WAB? MR. a: Mm. I mean if they go to Brooklyn, sometimes they take them off or a different court. But this one here, I would say yeah, taken off the count. And again I’m EFTA00110905

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LIMITED ies) w co ive) oO co OFFICIAL USE 21 not sure. I see pre-remove proof. Pre-remove. MR. a : But by saying pre-remove, more likely that he’s -- MR. ae: HE’s taken off the count. MR. QJ: -- not coming back? MR. QJ: uh.) Yeah. And who would ! ie] s) @ n ct J ou rt 3 o ri o c ct 0) e made i 7 Mm. I’m not sure. Ps) ) Do you know if you made ct J wu rt 0) S ct K oO Hi 3 oo =] =] Oo on ct u c K 0) there’s no way to MR. Mm. MR. u Oo bet is at approximately back? Um. I’m not sure. oy fw = Q O o fs) bP rt n + 5 = b rh 7 oO No-no-no. What would If he was coming back? EFTA00110906

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LIMITED OFFICIAL USE N a Ww 1 MR. You said that’s it’s pre- Yeah. 4 MR. iv) a] . If he was coming back, what w would it show? Would it say pre-remove or 6 would it say something else? J 5 wn © o cr a wu ct w Les] 3 o fu =] 2 AJ = Pp ss oO 5 18) ct ct > w rt :) oO = wu ia 10 coming back. Like if he’s just going to court, don’t know if he’ os) coming back or not. 2 If he’s going to court. WwW 5 Ey | Ss 3 4 MR. QJ: And he’s not WAB. Would f foal Fs oO co if they thought he wasn’t coming back? wo a3 Mm. Yeah. Probably. 20 MR. All right. So then it 21 looks like from looking at that. 23 MR. a : At - by 8:38, we knew he 24 was probably not coming back? EFTA00110907

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LIMITED OFFICIAL USE w ~] wo 10 11 214 All right. And with that knowledge, should have any action - or should have any notification at least been made of hey, Epstein’s cellmate is likely not coming back. We need to start thinking about a new cellmate. For the people that knew. MR. BJ: ot’ thing is this is when not -. I could go in left and input it. un. : end of the shift. not sure. You know. The it was -. See our log is and see what time someone Mm-hm. That’s what we do. At the So at 4:00 J. this could have been updated is what you’re saying? Not at 8:30? there. Yeah. Uh probably like 3:00 around It’s not the only one. Yeah. I’m not saying specifically, I’m just saying like later in the day. MR. QJ: «stt’ aT -. But does that -. not an ongoing thing. It could have been -. So But do you wouldn’t put 8:38 - this is when that happened - if at 8:38 EFTA00110908

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LIMITED OFFICIAL USE 215 1 you dint’ know that. Would you? 2 MR. QJ: §9=owWell if I don’t check it, I wouldn’t know it. ies) Ww he Oo c 7) ue] oO Qa pe Hh fl Q fu bh bh 6 MR. ae: No I mean anybody. If I go 7 on the computer and it has a time. And it says 8 these are the people that left. That’s what 9 I’m going off of. 10 MR. QJ: «so -. 11 MR. a: If I don’t check it at 8:38 2 or - I won’t know. 3 MR. a : So when I say “you” 4 though I’m talking about BOP. So what I’m 5 saying is like the person who entered that. 16 They’re entering it as if at 8:38 it was known 7 that he was likely not coming back. Is that 8 correct? 9 MR. a : It was known to BOP nN Fs) tw fe) g 4 > in} K o n 4 fe) io] rh Ph HH a o a] ifs No w Q = = o bet o fu a EFTA00110909

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LIMITED OFFICIAL USE 216 1 MR. Ee : Yeah. And who likely 2 would have entered that? Like who has access 3 to enter that? Control and lieutenants. Who 4 else? 5 MR. a: Mm. I think that’s about it oO a All right. So at that 7 time, it would have been either you, a. or 8 control. Correct? 9 MR. a : Mm. I’m not sure. 10 MR. a : But I’m just saying like 11 it’s - you’re the only two lieutenants on. And 2 then control. Right? 3 MR. a: Again, I’m not sure 15 didn’t even realize this until we’re now 16 reviewing it. So this isn’t a - I promise you 7 this isn’t like a setup. This is just trying 8 of figure out. 9 MR. a : I’m not sure. Because what 20 if - what if I say hey, I didn’t do the log. 21 Or what if hey, you forgot the log. You have 22 to do this. 23 MR. a : What do you mean? 24 MR. a : If you get an emergency. 25 MR. a : Yeah-yeah. EFTA00110910

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LIMITED No No No ies) w co ive) co ion) OFFICIAL USE 217 MR. a: Hey listen, relieve me -- MR. a : Yeah-yeah. MR. ae : I ain’t touch the log. All got you. Right-right. know if it was -- MR. a: I don’t know. I don’t know. MR. Ee : -- or control? MR. QJ: §9= = don’t know who did it. MR. a : All right. Because I he didn’t know he wasn’t i=) mean like I know like I’m pretty s correct? - I think that’s what yc MR. a: Yeah. But the thing about it with this is if I relieve you and y didn’t do nothing. Hey, you know, look out for me. I got you next time. Okay. So just because it’s on day watch don’t mean day watch staff did it. EFTA00110911

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LIMITED ies) w co ive) oO co OFFICIAL USE =] rr wu rt prese N a co You know what I’m saying. that could have been ther than that was even that constantly MR. MR. what did it see maintained for a long period of time? 0 point in time would we MR. : 11:00 ht at n movement. and do a would So on Sentry it All movement for the day. Would that -? All the movement. And would that be ial b n refreshed? It refreshed until midnight. And then you - I could come whole 24 EFTA00110912

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LIMITED OFFICIAL USE 21 1 MR. Ee : All right. So you don’t \o ies) i ae : I don’t know who did this. 4 Was it day watch or what? 5 MR. a : And Ss no way to 6 tell by looking at it? 7 MR. EJ: No. oo 5 Is there in Sentry any 9 way to tell who entered it? 10 MR. a: We don’t do the ntry. We 1 just take the information off of Sentry. 2 MR. a : Oh. Well who would have 3 put it in 4 MR. 5 MR. Okay. R&D could have 16 put it in Sentry and then whomever - either one 7 of the lieutenants or control would have 8 it in? 9 Yeah 20 Okay. somebody. All right. So with this 23 i 8:38, would it have been - if at 24 And when I say “we” - BOP 25 control - knew that he was EFTA00110913

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LIMITED OFFICIAL USE 220 uw ~] 10 11 12 18 19 20 21 22 going and likely not coming back. Who should have started making those notifications that Epstein was without a cellmate? Is that SHU staff? Is it lieutenants? MR. a: You said they known at this time? MR. QM: yeah. «So at 8:38, he’s going WAB. He leaves with a brown paper bag and he’ got stuff with him. He knows he’s not coming back. | | is saying I’m out. I’m not coming back. MR. QJ: 9 vm-ho. MR. a : Who should have at that point should have it been the SHU staff that started making notifications? Hey, we know Epstein’s cellmate is gone. We need to start making some rounds. Is that you know the ops or the activities’ lieutenant should have said hey, he’s gone. We’ve got to notify the captain. MR. a: I mean the thing of it is. MR. ae : Like who should have -? MR. a: I don’t even know who the dude is. EFTA00110914

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LIMITED OFFICIAL USE 221 w ~] ive) MR. a: So for one, a regular staff wouldn’t even know who bunkie is. MR. a : And that’s where my question. Should SHU have started saying like this is - hey ops and activities’ lieutenant. This | guy is Epstein’s cellmate. We need to start thinking about putting a cellmate and getting a new cellmate assigned. MR. a: That’s again if they definitely knew he wasn’t coming back. Just because this - like you can get a pre-remove -. MR. a : And is that why -? MR. a: And then at 4:50 you get pre- remove to such-and-such. MR. a : Okay. So is that why fF memo that said, “possibly not coming back and will likely need a new cellmate.” Is that why that’s the appropriate response? MR. a: Possibly. Probably. Because you never could tell. MR. a : And is that why you’re saying that they would have written possibly because at this point it looks like it’s likely, but it’s not definite. MR. a: Yeah. I could see him -. I EFTA00110915

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LIMITED OFFICIAL USE 222 1 could see that happening because like you said, 2 this happens all the time. Ww id ed n n \ll right. Because again 4 it says that inmate | was going WAB and 5 possibly may not return. Also that inmate 6 Epstein will be needing a cellmate upon arrival ~] from his attorney visit. So looks like they 8 knew - SHU. Should | have told you - 9 activities’ lieutenant - or | - ops 10 lieutenant? 11 MR. a: I mean. 2 MR. a : I’m not saying that he 3 did or that you know. You already said you 4 dint’. 15 MR. a: I’m not even saying that he 16 should have. 8 MR. a : I don’t know. 20 MR. QJ: =f he was notified, and he 21 said it could be. Again I told you 8:00. 22 That’s (Indiscernible *02:49:44) guys come in 23 all the time from court. 24 MR. a : Yeah-yeah. But I’m just 25 saying with the fact that Epstein - everybody EFTA00110916

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LIMITED OFFICIAL USE 223 wi ~] 10 11 12 13 14 16 17 18 19 20 21 22 23 24 knows he needs a cellmate. Should have they notified up the chain of command at this point? MR. a: What if he came back at 8:00? MR. a : But what I’m saying is like the fact that they know it’s possible and likely. Should have they started making notifications being that you were the ops lieutenant for a long time. You were a lieutenant now it seems for a number of years. In your expert opinion as a lieutenant -- MR. QJ: 9 Mm-ho. MR. a : Should these guys have started making some notifications? MR. QJ: 3m. That’s hard to say. Because if you pass on this information, possibly the guy shows up at 8:00. What notification I need to make? MR. a : Okay. So you were the activities’ lieutenant and | was the activities’ lieutenant when that thing says 8:38. Do you believe -- MR. a : He said that um -. MR. a : -- as that person who was you know the ops and the activities’ lieutenant - those two people. Do you believe at that EFTA00110917

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LIMITED ies) w co wo ive) oO co OFFICIAL USE 224 time that these notifications should have been fu made to you? Would have you - believe you should have been made aware? At 8:30? MR. QJ: Or: any time between 8:30 If your know. this - all the time. Th come o het vn. QR: saying hey, this guy might not come back. 7 MR. 4 hat’s why I could see him y can. ytifications -. MR. Ee : If he did it this way -. If | told the oncoming staff this is took appropriate a. If he in fact EFTA00110918

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LIMITED ies) w co ive) oO co OFFICIAL USE 225 MR. a: By passing it on? MR. a : -- passed on that know he’s f cellmate. come back, definitely he’s going to need a cellmate. saying? MR. QJ: «Well this is what the oO to who you 3 ) 3 ie} n ny] Ke 7) H rt n ny] im “ ct J oN August 9, 2019, at approximately on to oncoming staff member QQ c Fh Hh b Q 1) ini | rt is fu ct b =] 3 ie) ct = fw if] anc going WAB and possibly m i] y not return. Also that inmate Epstein will be needing a cellmate upon arrival from his attorney visit.” was on day watch? sounds like what he EFTA00110919

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LIMITED OFFICIAL USE 226 ies) w ~] wo 10 11 ive) present. MR. a: So in my expert option, at that time, he did the right thing. MR. QJ: «411 right. So by this, he shouldn’t have passed it up to the ops and activities’ lieutenant. He should have kept it in-house until it was definite. MR. a: It’s premature. Yeah. MR. a : Okay. Because that would have been premature prior to this time. MR. a: Yeah. Because like I said that time. If he came back, then oh. I MR. a : And even keeping in mind that both a. or however you pronounce MR. a : Well after that I don’t think he was bunked with him after that. MR. QJ: | fim and -. No-no-no. What I’m saying is both of his previous inmates - Epstein I’m saying - || and Po - they were both vetted from the highest of levels. Even with that knowledge, you think that they should have still waited. EFTA00110920

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LIMITED OFFICIAL USE 227 1 MR. a: I mean I don’t under -. 2 MR. a : They were vetted by the captain, the warden, and the regional director. MR. a : So obviously it took 6 doing. ies) wm oO 2) 3 oO But didn’t get -. MR. a : With that knowledge, do ve told you? Or co a wo i=) 2 . a : Well I mean not I mean I don’t know. >n again, It 5 fw rt - wi Oo ive) Fs) oO oe Lo >) o »ld you about is) w Q fw t a rt I w rt H t b QQ Oo = yn’t check for it, I don’t know -. 7 MR. ae : no-no-no. I’m not saying You co 22 MR. ae : Yeah-yeah-yeah. But what ying like it appears that in looking at 24 that, it appears that they knew he was WAB EFTA00110921

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LIMITED OFFICIAL USE 228 w ~] wo 10 11 MR. a : So I’m saying between 8:38 and whatever the end of your shift is -- MR. a : No one said nothing to us. MR. a : -- do you believe someone should have said something to you? MR. a: I’m not sure. Because then again, you could look at another log where it’ll say from pre-remove to ZA. You understand? MR. a : Right. Because he didn’t actually - MR. a: So that’s why I could see him saying well I’m letting y’all know. I’m passing on to you and you because you’re going to be here. Possibly. MR. ae : Yeah. MR. a: I’m giving you the heads up. MR. Ee : So I guess -. And I understood you answered that question. But what I said was - considering the fact that it takes at least almost an entire day to vet who was even going to be placed with him, do you think that they should have started moving this up the chain of command knowing that this guy - EFTA00110922

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LIMITED OFFICIAL USE 229 uw ~] 10 11 12 18 19 20 21 22 no inmate - just a regular inmate shouldn’t be placed with this guy. He needs to be vetted. It’s vetted all the way up to the regional director’s level. MR. a: Yeah. I’m not sure on that one. MR. a : Yeah sure. Yeah. All right. Not sure. So is there anything else if it says with | Og Does it say when he was actually -- MR. a: It just says 8:38 pre- removed. That means taken off the count. Now if he comes back, it will say pre-removed to ZA. And it kind of changes. MR. a : So because it says pre- removed, there’s no reason to note when they were definitively told he wasn’t coming back? MR. a: Yeah. This just means he went to court. Right? So you have three going out. Meaning you’re off on count. MR. QR: | n-hn. MR. a: It could be in the Eastern District - whatever. If you do come back, they put you back on. MR. a: But only if you come EFTA00110923

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LIMITED OFFICIAL USE 230 1 back. Otherwise, they won’t name you again. 2 MR. a: So this isn’t definite. indefinite? WwW 5 H rt n w a All right. 6 MR. ae: I mean no this is not 7 definite. That means he’s possibly - he could 8 come back. Just because it says pre-removed, 9 he’ll come back. 10 MR. a : But what I’m saying is 11 the fact that he didn’t come back. Should have 2 there been another note saying he is now 3 definitely off of our books. 4 MR. a: No. You just don’t see it on the - you just don’t see it. F oO w n Oo just by him not being back on it that just means hey, refer back -. Les] Fs) K i) wu ion 9 MR. Ee : Hey, refer back to that 20 thing where it said that he was possibly not 21 coming back. 23 MR. a : There should not be any more notes saying like he’s gone. MR. ae: No. Only think because if ho No w EFTA00110924

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LIMITED OFFICIAL USE 231 1 I’m evening watch, the only think I’m checking 2 for is the pre-removed to the institution. So 3 these three, hey did they come back today or 4 are they off the count? So there wouldn’t be w no follow up. 6 MR. a : SO there’s no additional 7 -? There should have -. There’s not another 8 line item that shouldn’t be in there saying 9 that | wasn’t one of the individuals that 10 came back 2 MR. a : So there’s a pre-removed 3 but there’s no line for removed. 4 MR. a: No. Pre-removed means off the 15 count. He’s out the building. Now if he comes 16 back -- 7 MR. ae : -- and you -? 8 MR. a : -- you just put him back in. 9 MR. Ee : Okay. So that’s the only 20 notification that should be made - should have 21 been made on the lieutenant’s log? 22 MR. a: Yeah. This one here? 23 MR. QM: Yeah. 24 MR. QJ: 9 Yeah. 25 MR. a : All right. And do you EFTA00110925

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LIMITED OFFICIAL USE N Ww 1 mind just putting it like you did that last 2 one. Just a little star next to is. I'v ies) a o ws just got a question real w ig K oO i) ue] a oO wu it) o Q oO count, oO AJ f Be 5 va oO inf N oO This outcount that you 03) o 0 i=) oO 0 K 7 oO K oO rr N Fs) oO 5 ive) a) ZA. See that one? Is that one? Who is that one for? Is that for a: t oO a Outcount. Who normally gets marked off? fos) Oo ] rt a @ 3) ray ct J uy rt n outcount? wo 23 MR. a: You never usually see an 24 outcount for that one though. I don’t know EFTA00110926

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LIMITED OFFICIAL USE 1 MR. QE: 3 this is. I’m not You don’t know Say that again. sure what assignment what account? ios) 5 Okay. 6 MR. a: Uh. It could have been some 7 type of - 8 MR. a: I was just trying to figure 9 out if they were still counting him as hey, 10 there’s a possibility of him coming back. 11 They’ve left him as outcount. And eventually, 2 after evening they removed him from outcount. 3 MR. a: No. the outcount - oh I 4 know what you’re saying now. You’re trying to 15 Say you mean who is the one that they have at 16 attorney conference. 7 MR. a: See attorney conference we 8 know. That’s -. 9 MR. a: Yeah That’s the same thing. 20 MR. QJ: 9 That’s the same thing? 21 MR. a: Yeah. All the numbers is 22 repeats for the outcounts. 23 MR. a : So you hear what he’s 24 saying? 25 MR. QJ: 9veah. Okay EFTA00110927

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LIMITED OFFICIAL USE ~] wo 10 11 MR. Ee : Ten, one, two. That equals 13. One, one. Three plus one plus 13 plus two equals 19. MR. QJ: §9Got it. So at this point, i is completely off the count. MR. a: Yeah. 4:00. Yeah. He w off at this time. MR. a: Okay. MR. a: But the thing is he could fu fo come back. MR. QJ: «Got it. MR. a: That’s why I’m saying that -. I know you’re sayin Q rr oa fu t hey, should he have. I can’t say that. MR. a : So you’re not like upset at the fact that like he didn’t notify you and then you could have notified the captain. You don’t think that that would have been what he should have done? MR. QJ: =o. mean yeah, that’s definitely helpful. And it would have been appreciated. But to say that you know he’s in the wrong for not doing it and stuff like that. I can’t say that. MR. QM: Okay. And he didn’t EFTA00110928

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LIMITED OFFICIAL USE 2 wo wi 1 notify you? 2 MR. a: No. Not that I recall. 3 MR. a : Okay. All right. So 4 we’re going to move on from that. You can give 5 that back or you can hold onto it. Whatever 6 you want to do. Do you know about any cameras 7 in the MCC SHU that were not working on August 8 9th or 10th? 9 MR. a : No. That they wasn’t 10 working? 11 MR. Ee : Yeah-yeah-yeah. 2 MR. QR: No. 3 MR. a : Have you - did you ever - 4 were you made aware of that after August 9th? 15 Any cameras were not working? 16 MR. ae: I heard something about when they was like checking videos and stuff. 8 MR. a : What did you hear about 9 it? 20 MR. QJ: 9 That some of them was showing 21 grainy 22 MR. ae : And who would have been 23 responsible for making sure the cameras were 24 working? 25 MR. QJ: «wm. The facilities. EFTA00110929

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LIMITED oO io ioe) oO oo wo OFFICIAL USE N lo Who from facilities ver they manager is. MR. a : Do you know who that though. He would be MR. : MR. a : All right. Were that prior to that time that they in facilities? EFTA00110930

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LIMITED ies) w co io ioe) co OFFICIAL USE weren’t working? The Kh om wm ie} ie) 5 fA b oO p f b rt # oO n time? Do I’m communication with re about something but cific. N Cameras? No. Who is BOP him. you know what his would have been manager. What do that role S a supervisor of a unit What unit team at the not sure. Did you have any gard with Just with him being talked to him recall nothing Ww EFTA00110931

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N Wo co LIMITED OFFICIAL USE 2 MR. a: No communication like that. ] WwW Q 0 5 ~ 5 Oo = 4 MR. a : Did you ever provide him instructions with w B ct > wu 5 x } 3 Q fe} oo a] 0 5 fw ime wu is ie) Cc rt | o B per 11 needing a cellmate? 12 vn. QR: 14 | allowed Eps 16 MR. ae: Mm. I think I heard 17 something about that. I don’t know was it | though. 20 MR. a: I just heard something. I 21 think he made a phone call though. 22 MR. QJ: 411 right. 23 know anything about fF involved with that ioe) co you 24 phone call? EFTA00110932

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) N Wo \o MR. Ee : All right. What is your understanding of the phone call that took place on August 9th with Epstein’s telephone call? MR. ae: It was a regular phone call. MR. a : Did you hear that it was made in the shower area? MR. QJ: No. MR. a : Have you ever heard of telephone calls being made in the shower area? MR. a: In the shower area? Yeah. MR. Ee : And what’s the purpose of MR. a: The cord can’t reach. And I’1ll say we got him out taking a shower - hey I’m going to give you a phone right now while I’m - while you’re right there. I don’t have to pull you out and it’s like a time consuming method. MR. Ee : Do you know if the line that they would be using in that area would be recorded line or a legal line? MR. a: It’s two. There’s two. MR. a : Okay. So would there be any reason to provide someone with a legal line that’s not recorded? EFTA00110933

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LIMITED OFFICIAL USE 240 Ww N ns) wn ie) | Would there a be a reason? wi ir) if they provided 7 Eps a phone call in the shower area for a co legal line, at be wron 9 MR. a : You mean an unm 1 MR. a: If they gave him an WwW id v8) iB ] ay rt 4 MR. a: Yeah. Unless you didn’t know 5 which one it is 16 MR Ee : And if they did know that 8 21 it was unmonitored. 24 you mean like - I mean 25 the time. I think they could EFTA00110934

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LIMITED OFFICIAL USE 241 1 you know they let them call their legal 2 attorneys. And yeah, they do that. 3 MR a : Okay. And if they didn’t 4 do that 5 MR. a: I don’t know if it’s a 6 violation. 7 MR. QJ: Right. 8 MR. a: But it’s not common. 9 MR a : Yeah. So let’s say if 10 the captain even authorized it. Yeah, give him 11 his phone call. Just make sure you monitor it 2 and log it. ive) a) 4 MR. ae : They didn’t monitor it. 5 They didn’t log it. Would that be a problem? 16 MR ae: The captain telling me. 7 Yeah 8 MR a : All right. Did you ever 9 hear of that practice taking place in the 20 MR. QJ: 9 Unmonitored calls? 21 MR. ae : Yeah. Or like letting 22 somebody in the SHU have a phone call on an 23 unmonitored line, walking away, letting that 24 person talk? 25 MR. ae: No. Now from an officer’s EFTA00110935

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LIMITED OFFICIAL USE 242 1 standpoint? 2 MR. QM: Yeah. 3 mR. QR: No. 4 MR. a : You never seen that 5 before? Or heard about it? 6 MR. ae: Officers. No. 7 MR. a : Okay. What is the policy 8 for inmates making a calls from the SHU? 9 MR. a : Mm. I do know they could get 10 - they got to come - there’s a (Indiscernible 11 *03:04:12) in SHU that everyone has a line. A 2 compassionate phone line. And they get with 3 the chaplain they can make a phone call. Like 4 say that they might you only get one call every 15 30 days So chaplain say hey, give this guy a 16 call. They come up. They bring him. They let 7 him use the compassionate phone. 8 MR. a : And when you say -. 9 MR. a : And that’s about it. 20 MR. QJ: what’s a compassionate 21 phone? 22 MR. a: Yeah. It’s like something 23 they have a death in the family or something 24 like that 25 MR. a : But is that a monitored EFTA00110936

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LIMITED OFFICIAL USE N Ww 1 call? 2 MR. a: I don’t think so. But I mean 3 staff would stay with him. It’s monitored 4 yeah It’s monitored. w ig U ie) w 3 i o Oo 18} to b 5 ct + oO n ct w hh Hy 6 It’s either a monitored line or staff is with co a MR. a: If it’s monitored in Yeah. oO a 1 MR. Ee : So when I say monitored, 2 I mean it’s either a recorded line -. ive) Fs) Or you right there. 4 MR. ae : -- or you’re right there. And what are the reasons t oO a 7 1 an unrecorded line? Or 8 a non-recorded line? 9 Mm. I mean probably like an 20 20 22 the 23 24 MR. a : But if it was in the 25 shower area, they would actually have the EFTA00110937

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LIMITED OFFICIAL USE 244 1 ability to do either a recorded line or a non- 2 recorded line? ies) id K om wu J 4 MR. a : They’ re right next to w 6 MR. ae: It’s a jack. Yeah. 7 MR. a : Yeah. Okay. What about 8 - what’s the MCC policy on conducting searches 9 in the SHU? Cell searches. 10 MR. a: You have to search the cell. 11 MR. Ee : Do you know about them nN =] Oo rt Qa oO 3 o c Qa rt B 3 .Q 0 0) bh be un i) a] K Q io” 0) it Ww Fs) mn ct wu rh Fh 5 oO rt ie] ie) =] o is Qa ct + Ss QO r oy w tr bh ? a a Oo Bb 5s o ct wu 3 a oO ar o ia] oO ~ n 7 cell search from 9 South or the SHU on August oo oO rt > H it w fe) 5 i) a tu) ra a search. It was conducted 9 at 12:36 p.m. during the day by a . It’s 20 the only cell search that was conducted on 23 MR. a : Is that weird for you? 24 That you would see only one cell search 25 conducted on a day? EFTA00110938

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LIMITED Ww wo Ww oO oo OFFICIAL USE 245 conduct MR. MR. How many MR. a : And is it at on night watch? And during MR. a: Per shift. MR. J: «9 what’ MR. ae: Per shift. shift? Everyone’s that? 3) MR. Ee : Is that including the morning watch? mR. BR: No. MR. a : So day watch and -? MR. | : Do area watch. s es on morning EFTA00110939

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LIMITED ies) w oO wo i=) N ive) oO co No Nm No ion) OFFICIAL USE 246 MR. Ee : And are you aware if they C ve. J: on. saying before? An abnormal da MR. ae: I mean I don’t know. I wasn’t aware that they wasn’t doing it. No. MR. a : Okay. Um and is there responsibility of the ops or activities’ you were lieutenant overseeing to make sure that these cell searches are being conducted? MR. QJ: 9 yeah. MR. a : There is? tt very Ss. So MR. ae : Every cell in there is supposed to be searched every 30 day MR. a: The whole unit yeah. MR. a : Okay. And that’s where the ops lieutenant and activities’ lieutenant EFTA00110940

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LIMITED ies) w oO wo i=) N ive) oO co No Nm No ion) OFFICIAL USE 247 come in? MR. a: Any lieutenant. MR. a : Any lieutenant. asking is on August 9th there’s no lieutenant in there. As the activities’ lieutenant or the ops lieutenant on any of the watches. Should have they been like making were doing their job? Mm. I’m not sure. MR. a : You’re not sure? MR. a: Because I mean that’s in TruScope. It’s like you’re not checking TruScope at that time -- MR. a : Yeah-yeah-yeah. MR. , H —- anywi MR. QJ: | nd during your rounds -- MR. ae: And on top of that I think You know. the cells - the cameras probably show the cells being checked. I’m quite sure. They just didn’t log them. MR. a : All right. So you think EFTA00110941

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LIMITED OFFICIAL USE 248 1 that they’re actually searching them? 2 MR. a: They got to. a : And not locking it? 4 MR. ae: You got to hey, get out. ies) i 5 You’ re doing a feed and cuff up, showers, you 6 come out and yeah. So they not locked. 7 MR. a : But would it be 8 surprising to you to hear that there was a lot 9 of extra linens and clothing and all that kind 10 of stuff in the SHU? 11 MR. a: That’s not surprising. 2 MR. a : So if they’re doing cell searches, wouldn’t they take that stuff out and ive) 4 keep them with the -? I suppose so. Yeah. t t oO wi Og All right. But you 7 believe that they were actually conducting the 8 cell searches? oO a3 I’m quite sure. More than 23 MR. a : SO you think it was just 24 - this is all they logged but they probably did more? EFTA00110942

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LIMITED OFFICIAL USE ioe) w 7 MR. Pills. c rr c a 3 o oO fp. ie] nv] rt bh is) 3 They da So in 18 MR. 20 with like OD-ing or i) b MR. ae: I mean if medication, u the ho medical give Okay. Some have Like medication. the SHU they’re re ever a problem like that? it’s - depending on them. S it to no o k rh -carrying EFTA00110943

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LIMITED OFFICIAL USE 250 1 MR. Ee : All right. And so that - 2 and that’s not abnormal for them to have their ies) own pill bottles and things like that in the d SHU? wi Fs) o 6 MR. a : What can an inmate in their cell in the SH 8 MR. SE: shirt, boxes, washcl oO 9 towel, depending on what season too. Blankets, 10 two sheets. i oO ia wu 3 tall 0) rt ie) wu 5 Q rt = ie] its) om oO @ rt its) ive) Fs) Depending on the weather. 5 MR. a: And how much is available. MR. Ee : What about in August? How many blankets and sheets could have they t oO a co had? its] i = 12) 3 a 5 ke ct a oO he a is) = ~ a a5 fw o 22 MR. a: Uh. It depends. Some of 23 them -. It depends. It they say hey, let them 24 keep it, two and two, let them keep it. No n i] EFTA00110944

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LIMITED ies) w co wo ive) co OFFICIAL USE 251 They go down authorized to a) hey, you need to - you know. to one. Would it be ever two of each? How Like an extra blanket or somethin Yeah. Like if three about know heard tt wintertime the cells. depending on What about in August? extra blanket? extra linens. Nah. What about Yeah. extra I mean it wouldn’t be authorized but could could fish it themselves - they How could they get it? ould « P- Q t. They wQ inmates. You mean they like the -? over EFTA00110945

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LIMITED ies) co io ioe) co OFFICIAL USE MR. MR. being conducted tho MR. MR. MR. MR. 252 They do that? All right. And would caught on the cell search if they were ae: Not all the time. how would they miss a: What if I don’t search that during the And it has - would they Usually they take it. Like if they search their cell. EFTA00110946

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LIMITED OFFICIAL USE 2 ow ios) 2 MR. a: Books. Food. Yeah. All right. Do you know ies) a 4 if Epstein was given any special privileges to 5 have extra clothing or extra linens? 6 vR. BR: No. 7 MR. a : No? Do you know if he 8 had extra clothing or extra linens? wo F No. 10 MR. a : Who was making sure that ein had the correct amount of clothing and linens? N ive) Fs) Not sure. 4 MR. QM: Would it be like the SHU 5 staff or the lieutenant or all of the above? 16 The SHU lieutenant? 7 MR. a: I’m not sure. 8 MR a : Working in the SHU 9 though, or previously, you don’t know who would 20 -? 21 MR. ae: Who is monitoring it? I 22 mean 23 MR. a : Like who would be - who’s responsible? Not let - sounds like - looks ho No w like no one was monitoring it but who was EFTA00110947

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LIMITED OFFICIAL USE 254 ~] wo 10 11 actually responsible to make sure him and these guys aren’t supposed to have that many - that much clothing or linen. MR. ae: I’m not sure. Because when we used to do linen, you give me three, I give you three. That’s how we used to monitor it. MR. a : Yes. It’s supposed to be like a one-for-one exchange. MR. a : Yeah. So I don’t know who’s responsible to keep an eye on his things MR. a : Typically who provides inmates with their linens? MR. QJ: «ss staff. MR. a : Do lieutenants ever do MR. a: No. Not really. MR. a : So it would be the staff Ss responsible then huh? MR. QJ: Yeah. That’s why I say (Indiscernible *03:12:15) responsibility I guess then. MR. a : Okay. Does the SHU lieutenant ever do it? MR. ae: I mean, it could. I could if EFTA00110948

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LIMITED OFFICIAL USE 2 ~] wo 10 11 uw wi vant to. MR. a : Yeah. But typically it would be the SHU staff? MR. a : Okay. Any idea how Epstein’s interactions were with other inmates? Did he ever have interactions with other inmates really? MR. a: I don’t know. I know when he first got there, he told me some guy he was nervous because his face was on the TV. And guys might be trying to intimidate him. That’s about it though. MR. ae : That was something he - Epstein specifically told you? MR. a: He told the officer and then the officer told me. He said, hey I didn’t know who he was. I was like alright. Let me look into it. And then they moved him. MR. QJ: here was he? MR. a: He was on - his first unit I think was 11 North. MR. a : So was he then in general population? MR. a : When he first came here, he EFTA00110949

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LIMITED ies) w co ive) oO co OFFICIAL USE N wi a was general population. MR. a : All right. So people MR. QJ: 9 when he first got through, he was in general population. MR. a : And for how lon lation? in general po MR. a : Say about a day or two. actually moved him into the SHU? MR. QM: «who did that? MR. a : All right. But an officer reported it to you? And t! MR. a: Yeah. I know he was in general population. MR. Ee : And what did you do with the information when that was told? MR. ae : You said an officer he’s worried about safety. MR. a : Yeah. I spoke to him. w wu B Q EFTA00110950

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LIMITED OFFICIAL USE 2 w x) 1 MR. a: I wanted to know I said 2 what’s going on. I said alright, we going to 3 look into this. And then they moved him. w a 6 MR a : But I guess my question 7 was did you report that information to someone? 8 And then it was - a person? wo F I don’t remember. I know I 10 passed it on. I said hey, this guy, I think 11 he’s high profile. 2 MR. GR: okay. 3 MR. a: Look into it I think by the 4 captain or someone got together and they moved 15 him. Put him in place in the SHU. oO MR. Ee : Okay. And when was the last time you interacted with Epstein? oo 5 Ll ie) wu 5 rt Kh o 0 w i oO a3 Did you have any 20 interactions with him on August 9th? 21 MR. ae: I could have. I don’t know. 22 He’s right there on the floor. So I could 23 have. 24 MR. a : But you don’t know. So 25 again, dude dies the next day. You can’t EFTA00110951

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LIMITED OFFICIAL USE 2 ies) w ~] wo 10 11 ive) uw 8 remember if the day before you talked with this guy when it’s like the biggest case ever? MR. a : You don’t remember? MR. a: Uh-huh. ‘Cause I brung him up to SHU a few times. But I don’t know if I did that day. MR. a : I’m just saying that kind of sparks a little suspicion if -- MR. a: I know what you’re saying. MR. QJ: -- it’s like - if it’s like you can’t even remember the last - if you talked to him on that day - the day before. MR. a: I mean it’s a bigc get that. But I mean, you know, I have a job se. I wu like you know? MR. ae : Yeah-yeah. I mean, I’m just saying that that’s going to create a little -. MR. QJ: 9 Yeah but I cannot remember if I spoke to that dude that day. MR. ae : Do you remember when was the last time you saw him? MR. a : No. I’m probably assuming that day. If he was in attorney conference. EFTA00110952

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LIMITED ies) w ~] wo 10 11 ive) OFFICIAL USE 2 wo \o MR. Ee : Um. And is that because you would have visited attorney conference? MR. ae : Yeah. The elevator is right there. I’m on the third floor here. Attorney conference is there. If I wait right here in the elevator, I see him. He’s in the same room MR. a : But you can’t remember if MR. Ee : Would you typically speak with him when he was in attorney conference? MR. a: The only time I used to speak to him is if they say hey, you can bring this. Hey, you going to SHU? Can you take him up? All right. Come on. MR. QJ: 411 right. question on that? MR. Ee : Yes. Please do. MR. QJ: 9gust in case, I mean I know Fs) i?) wu 5 H w u * w you said you don’t remember, but that’s hi os) last day. That’s the last time you saw him. Do you remember who he was with that day? MR. a : His lawyers. MR. ae: Do you remember his demeanor? EFTA00110953

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LIMITED OFFICIAL USE 260 2 MR. a: Was he upset? Was he yelling? Did he complain about anything? 4 MR. ae: He used to sleep a lot. ies) 5 That’s all I know. Sometimes you see him in 6 there, he’s just laying on the table. His 7 lawyer is right there. 8 MR. a: While he’s with 9 attorneys? 10 MR. a: He was there -. He used to 11 be there from 8 from in the morning time all 2 the way to day watch and evening watch. 3 MR a : Around what time would he 4 show up there? 15 MR a: Early. He’d be the first one 16 there 7 MR. ae : And what time would that 8 be? 20 MR. QJ: And then what time would 21 he typically go back to the SHU? 22 MR. a: Before - or attorney 23 conference over at 8:00. So about 8:00. 24 MR. a : So basically 8:00 a.m. to 25 8:00 p.m.? And who were the people that would EFTA00110954

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LIMITED OFFICIAL USE 261 1 take him to attorney conference and then take 2 him back to the SHU? 3 MR. ae : I told you. Like I said, 4 I’ve done it sometimes Yeah. wi aw 6 MR. ae: But typically, hey get the guy ready in SHU. Bring him down. If R&D’s 8 out there, hey we got to move him. You know. wo I’1l take him down. 10 MR. SJ: 9 e-hn. 11 MR. J: ow MR . a : Did you take him either ney conference or back to the SHU ver’s going that way. N Fs WwW ct J i) K o rr oO w ct rr 12] K 5 MR. a: I don’t think so. I can’t foal % oO QO fu t 7 MR. QJ: | Were you still at the Mcc around 8:00 p.m. on August 9th? co wu rt a I wasn’t there at 8:00. 20 MR. Ee : And what time do y 21 believe that you left MCC on August 3th? 22 MR. QJ: 9 Uh between 2:00 and 4:00. 23 MR. a : Sometime between 2:00 and wo a oO EFTA00110955

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LIMITED OFFICIAL USE 262 1 MR. Ee : But you weren’t back? So 2 he was in attorney conference all that time. WwW a) 12) ct a @ bh wu ifs) ct ct H 3 @ you possibly could have 4 interacted with him would have been around 8:00 5 a.m. Correct? 6 MR. ae: I mean interacting like talking to him? 8 MR. a : Speaking with him. But I don’t think I - wo F i=) I can’t recall if I spoke -. I don’t think I 11 spoke to him. But -- MR. a : Yeah-yeah-yeah. a: -- I’m not sure if I did or I N Fs) ive) a) . ae: The last time would have been t oO a 7 I mean -. Yeah. If I stepped into attorney 8 conference and said something. But -. oO a * au < 20 MR. QJ: «= don’t recall that. 21 MR. ae : But you don’t recall what his demeanor was? Or state of mind? No Nm No ion) 5 4 o wu rt om wu he 24 MR. a : Yeah. Um you just mentioned the one thing where he was worried EFTA00110956

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LIMITED OFFICIAL US 263 10 11 12 18 19 20 because his - you know -. MR. a: Yeah. The first day he got here. MR. a : He told an officer. MR. a: He’s saying hey, uh officer, hey there’s this guy up here. His face is - well we get those calls all the time. MR. a : Do you know of any other complaints that he made? Did he ever complain to you or you get any other information about it? MR. a: While he was planning on getting off of suicide watch. That’s about it. MR. QJ: Okay. And was he making those complaints to you about getting off of suicide watch? MR. a: He was just saying hey, why you guys got me like -. I’m like well you talk to psych and then they’ll talk to you and they spoke to him and he went back up. MR. a : And what was this complaint about? About being -? MR. a: He was saying why he was on there yeah. He wanted his clothes and you know. EFTA00110957

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LIMITED ies) w co wo ive) co OFFICIAL USE on suicide watch? like 10 MR. EJ: = Can’t be right? on the SHU? O in 10 South. 264 So he didn’t want to be He didn’t want to. So he wanted to go back he wanted to go -. Do you know if he wanted r did he want to don’t know. Did he ever tell that to Not to me. Do you ever -? in the correct place South or G Tie he can’t be in G Tier. He to have a Bunkie, got Well. I guess. It EFTA00110958

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LIMITED OFFICIAL USE 265 1 depends on -. Do you know what the reason why 2 he would need a Bunkie? 3 MR. ae : His suicide attempt. 4 Hotlist. 5 MR. a : Do you ever put people 6 that are suicide attempts or tlist in G Tier 7 or 10 South, so they have extra eyes on them? 8 MR. a: Mm. I don’t think. No one 9 in 10 South is on the hotlist. I don’t recall. 10 MR. QJ: «what about G Tier? 11 What’s their -? Who? What’s the deal with G 2 Tier? Like who goes -- a: Single cells. 4 MR. ae : -- in there? ive) a) 15 MR a: Single cells. 16 MR Ee : Yeah-yeah-yeah. But they have cameras in there, right? Every one of 8 them gets - just like 10 South - but -? 9 MR. a : Yeah but uh 9 South some of 20 the - some cameras in some of those. Psych 22 MR. ae : Do you believe Epstein 23 should have been in a cell with a camera in it? 24 mR. GR: No. EFTA00110959

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LIMITED OFFICIAL USE w ~] wo 10 11 MR. a: I mean yeah, if you have to have two. The ones with the cameras is single cell. You can’t go there. MR. a : Yeah-yeah-yeah. MR. a: You know? MR. a : So you believe he should have had a cellmate and he should have been in the regular SHU? Because we’ve had other people say should have been on G tier. Should have been on 10 South. But you believe -. MR. a: People are saying - I mean - if you try to commit - like you just showed me the memo. Right? So either he needs an extra set of eyes on him and then the - that’s even worse. I’m going to put you in there by yourself? You saying? For an extended time? MR. ae : I guess but so people are saying because officers are watching those people at all times. Is that -? Are they watching them at all times? MR. QR: = pow? MR. ae : On the cameras I don’t know. mR. GR: No. MR. a: SO they’re not actually 266 EFTA00110960

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 267 being monitored? MR. a: They can’t watch. No one can watch someone all the time. No. MR. a : Okay. So you think that it would have been just as risky or if not more with him being in G Tier or 10 South? MR. a : Okay. Fair enough. Do you know why Epstein was in prison? MR. SJ: «why? MR. ae: Uh underage trafficking. Child molestation. Charges like that. MR. ae : And did you have any specific feelings regarding why he was in prison? MR. GR: 9 No. MR. a : How often would you speak MR. QJ: 9 Uh whenever I needed to. MR. QJ: 411 right. Any kind of conversation that had any substance to it? Like a substantive conversation? Anything that was like more than just like below? MR. QJ: 9Nah. EFTA00110961

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LIMITED ies) w co ioe) co OFFICIAL USE 268 MR. Ee : No? and you said you did not work at all on August 10th MR. ae : That’s the day it happened, MR. ae: I wasn’t there. MR. a : And then you were MR. QJ: «st think MR. Ee : And you may MR. a : When wa MR. ae: Mm. That happened on what - Saturday? MR. a : Yeah. He was found on a Saturday. MR. a: He died on Saturday, right? MR. fF : Yeah-yeah-yeah. MR. a: Saturday. I don’t know if I came in Sunday. I think I came in Sunday. MR. a : Okay. And did you at 2ak with anybody about EFTA00110962

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LIMITED OFFICIAL USE N a wo 2 MR. a: I mean I knew about it. talking about it. 4 MR. a : Yeah-yeah-yeah. So what Ww Si o K KK e) 5 oO wu ia w 6 MR. ae: He hung himself. 7 MR. a : Do you know anything 8 about anyone else taking his life? oO 3 o 10 MR. J: No? ~D 11 about anyone assisting with taking his life? MR. ae: Nah. a : No. Do you believe that 4 Epstein took his own life? Ee : Do you believe that Epstein acted alone in taking his own life? a : Yes. Ee : All right. Then there’s only three more questions here. They’re more you know anything No Fs ive) a) t oO a Lee) 5 wo a3 21 open-ended. What do you believe would have 22 prevented Eps 23 MR. a: Nothing. 24 MR. a : Nothing? Do you think wn rt ein from dying? EFTA00110963

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LIMITED OFFICIAL USE 270 ~] wo 10 11 would have done it? MR. a: If it was a regular inmate, I don’t even think we would be - you know. MR. a : Um what are some of the systematic problems inside the MCC? And specifically the SHU that allowed for Epstein to die? MR. a: Mm. Systematic problems. MR. a : You know like -. MR. a: It sound like a union question or something like that. MR. a : Well no it because like I told you, we’re trying to look into like. Hey man, you’re right. MR. QJ: 9 veah. MR. Ee : If another inmate died, we're probably not going to be here talking to you. But this is high-profile. We now need to figure out what went wrong here. How do we fix it? So in your opinion, what went wrong here? MR. a: I mean. MR. ae : And how do we fix it? We're from the government. We’re here to help. MR. a: Yeah. My opinion, the whole cellmate leaving. That’s not on nobody. I’m EFTA00110964

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LIMITED OFFICIAL USE 271 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 not. If I have the notice he had up until that time and left for one day. Then this happens. I can’t blame lieutenant, staff, notifications. You know. Remember there’s like 900 inmates in there. MR. a : Right. MR. a : I know he’s high-profile, but we also have to monitor other inmates. The round situation. If that’s true. That could have been a little bit you know -. You’ve got to make rounds in SHU. MR. a : Counts too though, right? MR. a : You’ve got to make rounds and counts. MR. a : Now going back to there. You say it’s not on anybody. But if he’s - psychology is saying he’s required to have a cellmate. It’s got to be on somebody. Right? If he’s on the hotlist. He’s in SHU where he’s supposed to have a cellmate anyway. And psychology is saying he’s got to have a cellmate. It’s got to fall to somebody to make sure. Hey, who is supposed to make sure this guy has got a cellmate? His cellmate is gone. He doesn’t have a cell mate. EFTA00110965

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LIMITED OFFICIAL USE 2 w ~] wo 10 11 MR. QJ: «9 vr-hn. MR. a : Because -. MR. a: So if I know. If I get the notice by 8:00. Right? So I’m evening watch ops. I get the notice. Hey, this guy doesn’t have a cellmate. All right. What’s my call? I just throw him in there with anybody? MR. a : My thought - and from talking to other people - are supposed to be that SHU staff should have notified the ops lieutenant or the activities’ lieutenant. Who then should have notified the captain? MR. a: Yeah. At 8:00. I could see that. But at that time on day watch, hm-mm. MR. a : Yeah-yeah-yeah. MR. a: It’s a judgment call. MR. ae : And I’m not talking about :00 a.m. I’m saying like what you just wu rt oo said -- MR. QJ: = want to say we can’t (Indiscernible *03:24:48) notice. MR. ae : -- you don’t think that the cellmate thing should be on anybody. Well but it’s like it’s got to be on somebody. If he’s required to have a cellmate, somebody’s ~) Nm EFTA00110966

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LIMITED ioe) w io ioe) its) OFFICIAL USE 27 ot to mak _ 1e’s ) cellmate. MR. sure it was right. It was overtime. I MR. a : Well no, I’m not talking vorked -. MR. a : Yeah-yeah-yeah. I’m MR. QJ: «But if I’m the OIc. MR. QR: sto think EJ anc MR. BR: so that time no more. got -. | | | | wi MR. QJ: 9 vm-hn. asn’t wasn't o post. did a double that day, MR. ae : Well she - but yea but a right? EFTA00110967

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LIMITED OFFICIAL USE 274 1 not now talking about morning watch. We’re talking a re saying 8:00 p.m., right? WwW 5 oO oO is ct | K © fw Ss 4 MR. a : So that’s evening watch. 5 So we’re looking at -. Where are we looking 6 at? 7 MR. a : So if I know - if I’m 8 notified by 8:00. And I call the captain. Say 9 hey, this guy don’t -. What’s my next move 10 then? Throw him in there with anybody? Or 11 MR. Ee : Yeah, so we hav 2 mm -: a. a: Mm-hm 4 MR. ae : So yeah, I guess-. I mean I can see them saying ive) a) t wi a t oO | = a fe) oO oO K said that. Because they say hey, Right. 9 MR. a : You know. Kick it up. Kick Lee) 5 20 the blame up top. Now if I’m on, what do you 21 want me to do? Throw the guy in there 22 anybody? Just because he have to have a 23 cellmate? 24 MR. a : Well some people have 25 said that at the very least they would have put EFTA00110968

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LIMITED OFFICIAL USE 275 w ~] ive) him on like a dry cell type of a situation where you’ve got a staff member on him until he can get placed with a cellmate. MR. QJ: Yeah. But that’s a questionable move too. MR. SR: oon. MR. a: You want me to take him and put him on - you know? MR. a : So you believe - so I =] Ww atl i Vi i h i ? ues What is your belief then m MR. a: I mean there was a time and opportunity. Guy wanted to take his life. The inmate left. He saw the time and opportunity. He did it. The officers - you know. MR. QJ: But don’t -? MR. QJ: 9 uh yeah. MR. ae : -- do you believe though a correctional officer it’s the wu 7] responsibility to ensure that we ensure that they don’t die in our custody? MR. a: Well that’s what the rounds is for. That’s why it’s so important. MR. a : All right. So that’s why you think it’s really the rounds and the cr counts. Not nece “ sarily the cellmate but the EFTA00110969

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~) LIMITED OFFICIAL USE N c 1 rounds and the counts. 2 MR. a: Well in SHU, you required to do it. You have to do it. It ies) wi aw 7 MR. a : And if they’re not doing 8 the rounds - the 30-minute rounds - that’s o 4 oO ut} an b ct 5 @ on aa wu 3 tt] a i] H oO 10 MR. a: That’s a bad situation. i) Fs) be t rt) wu oC a on o) f rt fc fu rt k Oo 5 blame it on the Ww 5 w is) oO o 4 rounds way mor would blame it on the Oo ct > fu 5 et 12] co 5 cellmate? f foal wD 4 o wu rt 1) t rt The cellmate, he Lee) 5 Yeah. You know I mean that wo a3 happened. It’s the same thing. I understand 21 they sent out the notification. There’s no 22 timeframe on that. 23 MR. a : Yeah-yeah-yeah. 24 MR. a : Is an inmate goes 25 know, by the way, this - you sent EFTA00110970

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LIMITED OFFICIAL USE 2 ~] wo 10 11 ~ I this out a month ago. He’s not suicidal no more. He said it. It’s like you know. MR. a : Well in this case I think it was like 9 day But yeah. MR. a: Yeah. But there’s still no timeframe. Some guys say they suicidal just to get out of SHU and play the game. Go back in. MR. QM: Right. MR. a: But it’s never saying hey this guy is not. There’s no memo saying he does need a cellmate. MR. a : Would you agree though that it’s both? The fact that he was required to have a cellmate and they weren’t conducting rounds? MR. a: Yeah. Yeah. MR. ae : And that’s where - when I talk about the problems. MR. a: The thing is, that happened, but it’s - that can happen. Hey oh. His Bunkie left. I didn’t put a cellmate. That can happen. MR. QM: Richt. MR. a: You know. That can happen here. EFTA00110971

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LIMITED OFFICIAL USE 278 1 MR. QJ: | Right. 2 MR. a: You get inmates that was 3 crying on level two. Hey, got to have a 4 cellmate. You moved him? Yeah. Oh you ain’t 5 check? Oh you know. 6 MR. a : Yeah. So I think what I 7 understand you saying is that the primary issue 8 is not doing rounds. Secondary and a much 9 lesser issue was that they didn’t fill up his 10 cellmate. Is that correct? 11 MR. QJ: 9 Yeah. 2 MR. a : Okay. And are there any 3 other problems or violations occurring inside 4 the MCC that we should be made aware of? 15 MR. SJ: on. 16 MR. Ee : We’re talking about the 7 mcc. 8 MR. a : Violations? 9 MR. Ee : Anything that we should 20 have known about that you think needs to be 21 fixed. 22 MR. a: You got mandated a lot. I 23 know that. You’re working. 24 MR. a : So there’s - is what 25 you’re saying then that they’re severely EFTA00110972

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LIMITED OFFICIAL USE 27 wo 1 understaffed? 2 MR. a: They was. I don’t know how 7 was. 4 MR. a : And again when did you WwW k rr B if) s fe) z w co - on oO ie w 6 MR. ae: Uh December ‘19. 7 MR. a : December of 2019? At 8 that point they were still extremely over -? wo F Extremely. 10 MR. a : What about - was there ything that was being fixed ever since when 2 Epstein died and August of 2019. Did you see 3 ything being fixed by that point? 4 MR. a: Uh. They did change the log. What does that mean? t oO a 7 MR. a: They started putting inmates 8 that go to court. Just in case. We started 9 doing them and started attaching the PP38 to 20 the log. 21 MR. ae : So they would almost be 22 part of the outcount? 23 MR. a: No. You could see. You 24 could see all the movement. EFTA00110973

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LIMITED OFFICIAL USE 280 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. a: You know. You could see all the movement. They started single cell memos. Every time I need to know- every night. Because I worked the morning. Every night I need the -. Hey whose up there - single cell? That was an every night thing. We started that um. More rounds. More reiteration of doing your rounds. Um. I know the rounds. They got tighter with the rounds. The log. Mm. It was some things. There were some things. As far as staff, I think they did hire a class like right before. But um. You know. MR. a : Now has that just been a constant problem with um with the MCC with being able to like fill -? MR. a: I mean that’s -. Yeah. That’s been a problem for a while. It wasn’t like that when I first got there though. MR. Ee : And what is - why do you think it’s so hard to keep that place staffed? MR. a: Well uh I think they can’t compete. It’s the pay. They’re not competing with other agencies. It’s a tough job. Working there is tough. EFTA00110974

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) MR. J: it’s MR. a : What it makes it so MR. a: You got a lot of unruly inmates. You doing some long hours. MR. a : Are they doing long hours though because it’s understaffed? So it sounds to me, I mean an outsider’s perspective. Is that they need a lot more employees. MR. a: No. They need that definitely more employees. MR. Ee : Is there a way for us to not only get employees but get good empl What would be a solution there? MR. a: I mean you to recruit. ' is) c QO 0 rt rt Oo rt uM] * oO ue] om is) cel } i) rt Sy wu rt BK Oo wu lly want to do EFTA00110975

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LIMITED OFFICIAL USE 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a: I mean it takes some people that. You know. Say hey, you can make this your first year. Just going to put some work in it. You’ve got people that want it. You know. That wants the money. MR. a : You think that it means they should have like a higher pay at the MCC? And the MDC? MR. a: Higher pay or you look for people that are looking for opportunity. You know. MR. a : Like as in make it like a rotating place? You have to do a certain amount of time there and then you can go to like your choice location afterwards? MR. a: I mean. MR. ae : What do you mean by opportunity? I guess I should say. MR. a: Like I don’t know. I know the - I think it’s a college requirement or credit something like that. Is it? I don’t know. I’m not sure. MR. a : I have -. We’ve definitely talked to people that don’t have bachelor’s degrees. 282 EFTA00110976

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LIMITED OFFICIAL USE 283 1 MR. a: Yeah. But I think they have 2 um credits. I think they change it for 3 credits. 4 MR. a : Yeah. Some people have said some college. w 7 MR. a : That we’ve talked to that wo F I think -. 10 MR. a : I don’t think I’ve talked 11 to anybody that said they didn’t have any fw college. But I mean I think it was like a N ive) couple credits. You know. 4 MR. a: Yeah. But I mean some people 5 without college, it’s one opportunity to 16 hey, you can make $60,000 your first year. I 7 just need you to show up and work. 8 MR. QJ: Right. 9 MR. a : Follow the rules. You know. 20 And the credit check I think was getting a lot 21 of people 22 MR. ae : Is that right? 23 MR. a: Yeah. Credit checks. I 4 think that’s what weeds out a lot of people. MR. a : Now do you believe though ho No w EFTA00110977

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) - on that note - if we’re not doing credit checks, we’re letting that slide. Wouldn’ that breed a potential problem with introduction of contraband and being paid know for brining things in? MR. QJ: «9 Brib oO ry and stuff? MR. a : Yeah. Because that’s big problem in the BOP. MR. MJ: 9s Yeah. But I think that’ 284 t you i) fw ifs) I mean you’ve got some people in there I mean. That don’t work. That don’t. no. you co be. I seen people get arrested with good credit. MR. QJ: Right. MR. a: Six figures - making six figures and do some corrupt stuff. MR. ae : Right-right. MR. a : So. That’s not it. MR. QJ: Okay. MR. QJ: §9=’m not saying take ever But you know. MR. QJ: Yeah. MR. a: It’s like if you renting somebody and you a landlord. And you say alright, I know you ain’t Q uld yone. to ot the top score, EFTA00110978

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LIMITED OFFICIAL USE 285 1 but I see you pay your bills on time. You had 2 a little student loan debt here or whatever. 3 I’1l give you a shot. 4 MR. QM: Yeah. 5 MR. a: You know. 6 MR. a : What have you MR. a: You mentioned tha 8 Epstein in the conference room. MR. a: Attorney conferen ~] wo got? t you saw ce. Yeah. 10 MR. a: And sometimes he was 11 sleeping. 2 MR. QJ: 9 It looked like he was 3 sleeping. He would lay down on the table like 4 that 15 MR. a: Is that normal for inmates to 16 be sleep in the conference room? 7 MR. a: To sleep? No. that’s not 8 normal. Most guys is trying to get out. Saying 9 hey, you need to do this and do that. 20 MR. QJ: 9 Did anyone ever tell him to 21 wake up or address it? 22 MR. a: I don’t think so. 23 MR. a: The reason I ask 24 that a privilege that was allowed t 25 To do that? is like was o Epstein? EFTA00110979

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LIMITED OFFICIAL USE 286 1 MR. a: No. It wasn’t a privilege. 2 I think the being that he was there from early 3 in the morning to whatever time. The lawyers 4 probably like alright, let’s look over this. 5 And he probably laying, and I’1l1 wait until 6 y’all finished. And then alright, let’s go. ~] But he also gets to buy out the vending machine 8 too. At first. 9 MR. a: The vending machine? 10 MR. a: Yeah. He used to get all his 11 snacks. 12 MR. a : Yeah. Because you weren’t 3 allowed to give him food in there right? 4 MR. QJ: =n the SHU? You got food. 15 MR. QJ: Not in suv. 16 MR. a: In attorney -. 17 MR. ae : Attorney conference. I 8 was told that he basically had rt o get his own 9 food from the vending machines. 20 MR. BJ: 9 Yeah. 21 MR. a : Was he allowed -? Would 22 people feed him - the BOP food - when he was in 23 attorney conference? Would they bring hima 24 tray? 25 MR. QJ: «om. No. I don’t think ifs) Oo. EFTA00110980

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LIMITED OFFICIAL USE 287 ~] wo 10 11 I don’t even think he even ate that. I’m not sure. I don’t even know if he even ate the BOP food. He probably just ate commissary. MR. a : Oh so there’s a commissary he could go to? MR. a: Sure. You could go to MR. a : No. I’m talking about because 8:00 a.m. to 8:00 p.m. he was always with attorney conference. MR. a: Yeah. So he used to get drinks and chips - snack food. MR. a : And that’s what he would just eat all day? MR. a: I don’t know about all day. But I know you know he’ll have a - hey, make sure when the lawyers come, they get his sodas and drinks and they get us his chips. MR. SR: se. MR. BJ: 9 Yeah. MR. a : Do you know anything about would he eat before he would go and then be afforded a tray as soon as he got back to SHU? h MR. a : Uh. I mean yeah . but rt wu cr EFTA00110981

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LIMITED OFFICIAL USE 288 1 wouldn’t be -. That wouldn’t be kind of 2 common. That’s what any legal visit that we 3 used to do. 4 MR. a : Yeah-yeah-yeah. I’m just 5 saying if he’s 7 days a week not eating - only 6 eating a bag of chips or something from 8:00 7 a.m. to 8:00 .. that seems like he’d get a 8 little more hungry than that. 9 MR. a : Yeah. I don’t know. I don’t 10 know - I don’t recall him getting a tray in 11 there though. 2 MR. a : Yeah-yeah-yeah. No. MR. a: Yeah. I don’t know. 4 MR. ae : I don’t know if he was or ive) 15 not That’s why I was asking 16 MR. ae: Yeah. But if he comes back from there and they said hey that’s my tray 8 from earlier and if he was in legal visit, we 9 would give it to him. 20 MR. QJ: | Right. 21 MR. ae: I mean that’s common 22 practice 23 MR | Let’s say - once || left 24 that morning. EFTA00110982

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LIMITED OFFICIAL USE 28 2 MR. P| : Okay. Once he left that morning, wo b ies) a 4 know there’s like a sheet that keeps track of 5 all the inmates in the SHU. Right? They have like a bed count sheet. oO 7 MR. a : Bed book count. 7 Bed book count. Would that co i 9 book need to be updated? 10 11 2 that I don’t know officers. Ww Fs) a po 4 MR So officers should hav 15 updated it. Now let’s say they went in 4:00 16 i. count. And then 9:00 i. count - god 7 forbid there was something off with the count. 8 They would have to pull out eh bed book and 9 verify it. Right? If you get two bad counts. 7 21 MR. ae: Two bad counts. a: Yeah. a But if no one updated the 24 book, would that be an issue? 25 MR. ae: Well if you get two bad EFTA00110983

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LIMITED OFFICIAL USE 290 10 11 12 13 14 16 17 18 19 20 21 22 23 24 counts, you’ve got to a bed book. And then you’1l find discrepancy. But then again, you know who usually updates the bed book count? MR. a : The lieutenant? MR. a: Morning watch. Because I’m now - this is the new day - 12:01. MR. a : Okay. MR. a: This person’s not here. Now I know for a fact that this is what I’m starting my day with - for the whole day. MR. I was going to show one - the same document. You mentioned that when you were working the SHU around 2:00 a.m. you would have got the court document. Right? The attorney would have brought it up. Or someone would have brought up the document. MR. a: Yeah. It comes up on morning watch. MR. a: If - I mean and we don’t know for sure if that was the same happening. Who would have got that notification at 2:00 a.m. on August 9th? MR. a: About the paperwork? MR. a: About the court documents. MR. a: Uh probably internal. EFTA00110984

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LIMITED OFFICIAL USE 291 1 MR. QJ: No who in the SHU. Who was 2 in the SHU at that point? Who would have notified? Hey, listen iz is leaving Ww .Q Oo o rt © 5 4 in the morning. w 3) 9 hift changes and -. Who 10 um — got the document? nN 5 | y =] ive) 4 control or kept track of the fact that || is 5 walking out of there? 16 MR. ae: And again I told you, see if 7 you don’t - it’s not a thought. It’s not 8 coming on my radar until -. 9 MR. a : No. I’m not saying that. 20 But who in the SHU would have been ponsible? No rary i Someone in the SHU like I If they’re k? Make sure 25 MR. ae: That’s it. I just had to EFTA00110985

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LIMITED ioe) w io ioe) its) OFFICIAL USE Who would Well depending do it at comes MR. ae : Okay. At least MR. a: Who was on shift to get || Wouldn’t it have been th in at g ivi ng EFTA00110986

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 2 ive] ios) MR. a: He was SHU 3. I mean yeah. It’s one MR. a : Okay. Cool. Anything you got (Indiscernible *03:40:03). We had a really long interview here. So I apologize for ct a fu at. But we do appreciate you bearing with us. All right. Iti if) 4:46 p.m. on Monday, July 12, 2021. This is Senior Special Agent recorder. EFTA00110987

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LIMITED OFFICIAL U 1 CERTIFICATE I hereby certify that the forego ate transcript of the 4 electronic sound recording rtment of Justi 18 23 EFTA00110988